Katherine Jackson v AEG Live August 21

Dr. Stephen W. Gordon(Plastic Surgeon)
Questions by Putnam
So start with the form, could you state your full name for the record, please?
A. My full name is Stephen, S-t-e-p-h-e-n; Winslow, W-i-n-s-l-o-w; Gordon, G-o-r-d-o-n. How
did you go about looking for your documents that you provided to us here today?
A. Well, we're trying to -- well, we have our records electronically saved; electronic medical
records. So it was just a matter of going back and locating the Michael Jefferson file.
Q. How did you know that they were under the name of Michael Jefferson?
A. Because that was the name that he wanted us to use with them.
Q. With "he," do you mean Michael Jackson?
A. Jackson, right.
Q. And so you were looking for your records of Michael Jackson, and to do so you looked for
Michael Jefferson?
A. Right.

Q. And so is it fair to say, then, that there was a point at which you served as a doctor to Mr.
Michael Jackson?
A. Yes.
Q. And how many times did you see him professionally?
A. Three times.
Q. Did you ever see him nonprofessionally, in a personal capacity?
A. No, sir.
Q. Did you ever see him socially?
A. No.
Q. So the only times you've ever seen Michael Jackson are those three times?
A. Right.
Q. And did you ever speak with Mr. Jackson on the phone?
A. Yes.
Q. How many times approximately?
A. Maybe twice.
Q. Were those in reference to those visits?
A. Yes.
Q. So what I will do, then, is I will, when we get to -- I'm going to go through them
chronologically in a moment. So you went to look for the records of Michael Jefferson, and did
you say that was the name that he provided?
A. Yes. And he wanted his records to be protected, so he asked that we use this other name. Or I
don't know if he asked or I just did it, but that's what we did. Now I'm going go through your
history; a little bit of it. Where were you an undergrad?
A. Howard University in Washington D.C.
Q. What was your major?
A. I was a chemistry major.

Q. And where did you go to medical school?
A. Howard University.
Q. What year did you graduate?
A. 1975.
Q. And did you do a residency?
A. Yes, sir.
Q. Where was that, sir?
A. Indianapolis.
Q. Was that at Methodist Hospital?
A. Yes.
Q. And what was the field?
A. Surgery; general surgery.
Q. Do you remember what year?
A. That was from '75 to '79.
Q. Thereafter, did you go somewhere else?
A. Yes.
Q. Where did you go sir?
A. Emory University.
Q. Was that at Emory University Hospital?
A. Emory University affiliated hospitals in Atlanta, Georgia.
Q. Did you have a field there?
A. Plastic surgery.
Q. And what years were you there?

A. I was there from '79 to '81.
Q. And any fellowships?
A. Yes.
Q. Where was your fellowship?
A. Mexico City.
Q. Do you remember the name of the institution?
A. Actually, it was -- actually it was Gea Gonzales Hospital, under the mentorship of Fernando
Ortiz Monasterio.
Q. Was that part of, and my Spanish is terrible, so you're going to have to forgive me as I butcher
this, Universidad Nacional Autonoma de Mexico?
A. Well, yeah, I was there for some -- that was part of it. It wasn't really a program or formal
residency offered by UNAM. They called it UNAM, but the UNAM hospitals were some of the
hospitals I rotated through or worked at.
Q. And what year were you there?
A. I was there from 1990 to 1991.
Q. And do you have any other degrees or certificates?
A. No, sir.
Q. Are you board certified?
A. Yes, sir.
Q. And if so, in what?
A. I was board certified in general surgery in 1981, and board certified in plastic surgery in 1987.
Q. And are you a member of any professional organizations?
A. American Society of Plastic Surgeons.
Q. After completing your training, what did you do next?
A. After I completed my training, I practiced in Atlanta, Georgia.

Q. How long did you practice there?
A. I practiced there from 1981 until 1996, December of '96, with the exception of the year that I
took off for the fellowship.
Q. And what was your area of practice?
A. Plastic and reconstructive surgery.
Q. Now, while you were there, were you part of an existing practice?
A. No.
Q. Did you have your own practice?
A. Solo practitioner.
Q. Was that true for the entire time in Atlanta?
A. Yes, sir.
Q. And what did you do next?
A. After Atlanta I came to Las Vegas and joined a doctor in practice, but that didn't work out, so
I went back out on my own.
Q. And do you share -- do you have an office?
A. Yes, sir.
Q. Do you have more than one office?
A. No, sir.
Q. What is your address?
A. 7710 West Sahara Avenue, Suite 102, Las Vegas.
Q. Do you share that space with any other doctors?
A. No, sir.
Q. Do you teach at all?
A. Yes.

Q. Where is that?
A. I teach medical students and physicians' assistants students from Touro University that will
occasionally rotate through my practice.
Q. When did you start doing that?
A. Probably about three years ago.
Q. What do you teach?
A. Plastic surgery. once I have, I'll know better. What type of procedures do you do in your
A. I do cosmetic surgery in my office.
Q. And broadly defined, what does that mean?
A. Surgery that is elective, and surgery that is intended to improve the appearance of a person, or
restore a more youthful appearance, either improve an appearance or restore, or reconstruct
sometimes, but not often.
Q. And do you perform some of those procedures in the hospital?
A. Not usually.
Q. Where do you usually perform them?
A. In my surgery center. I have an accredited surgery center.
Q. And is that part of your office?
A. Well, yes. It's an office-based surgery center, but it's a separate entity corporate-wise.
Q. And is it in the same physical location?
A. Yes.
Q. What is that entity called?
A. The Surgery Unit at ACCSC.
Q. What does ACCSC stand for?

A. Complete Cosmetic Surgery Center. ACCSC is a professional limited liability corporation.
And the surgery unit is an LLC, or something like that, that sort of thing.
Q. And what type of procedures do you perform there in the center? Is there a top three most
common that you perform?
A. Oh, it kind of depends on the season of the year. I would say that I probably do more breast
surgery than anything else, followed by body contour and facial rejuvenation.
Q. Are patients under general aesthetic when these procedures are performed in your office?
A. Most of the time.
Q. What percentage would you say of your patients go under a general anesthetic?
A. It depends on the procedure I'm doing.
Q. How does it depend?
A. Well, if it's a major surgery, then they're always under general.
Q. And when are they not under general?
A. When it's something more minor.
Q. What would be a minor?
A. Removal of a mole, removal of a retained suture. That kind of thing.
Q. What about Botox?
A. Botox is generally done under local or no anesthesia.
Q. What about a filler?
A. Filler usually has a local anesthetic component of some sort, either a regional block or local
mixed in with filler.
Q. What does "local" means?
A. Local means what you would get at the dentist, Xylocaine, that kind of thing.
Q. Is that a shot?
A. Yes.

Q. Is there an anesthetic that is typically used in your office?
A. Anesthetic?
A. type, yes.
THE WITNESS: An anesthetic? Well, we use inhalation anesthetics, and we use -- that's the
main. And we use some local in conjunction with what we're doing sometimes.
Q. What's an inhalation?
A. That's like a liquid that turns into a gas when you put it in a vaporizer.
Q. And is that typically what is used in your office?
A. That's used on all our general cases.
Q. And what type of inhalation is typically used in your office?
A. Desflurane or isoflurane, one of those. Usually desflurane now. Back in the day we used
isoflurane more.
Q. When you say "back in the day," when would that be?
A. That might have been when Mr. Jackson was there. I can't remember whether we were using
desflurane or isoflurane back then. They're both still credible.
Q. Tell me how the procedure works, if you know. Is there first an inhalation and then an
injection? Or how does one get an anesthetic when one is having a major procedure done in your
office, typically?
A. They have to get an IV started first. Then once the IV is started, then they're usually given
some type of hypnotic that puts them to sleep, like -- I'm trying to think. There's one that we used
to use. Diprivan.
Q. Diprivan? Do you have any say in what anesthetic is used by the anesthesiologist?
A. Well, since I'm the one who provides it, I guess I do in a way.
Q. Do you typically --

A. But I don't tell them how much to use and that kind of stuff. Or if they choose not to use it, I
don't interfere with their decision.
Q. Is that something you typically discuss with each patient?
A. With the patient? No.
Q. Is that something you typically discuss with each anesthesiologist, when they're administering
it to a patient?
A. It's pretty much a routine thing. So there really isn't much need to discuss it. Unless it's their
first time working with me or something like that. And I say this is how we do this, this is what
we have for that. Because there's other agents that -- some doctors have preferences for
paralytics, for instance something like succinylcholine. Some like other stuff. So it just depends.
Q. All right. Let's go back to Michael Jackson. How did it come to be that Michael Jackson
became a patient of yours?
A. He called me on the phone one evening.
Q. Did he call you personally?
A. Yeah.
Q. Can you recall approximately when this was? What year?
A. It must have been 2002. That's the first time we saw him.
Q. Were you in the office?
A. No. I was at home.
Q. So he had your home number?
A. No. He had my cell phone number.
Q. Do you know how he got your cell phone number?
A. I don't know. He might have got it from -- no, I know what it was. My answering service
called me, and they said they had somebody, they had a Mr. Jackson on the line that wanted to
speak with me, so I said okay. So I started talking to him. At first I thought it was somebody
playing a prank. I really thought it was one of my friends just, you know, fooling around. And
then he convinced -- he managed to convince me it really was him.
Q. Do you remember how he did that?

A. He just said, oh, no -- I mean, it was a very -- it was a very -- how should I describe that
experience? It was a very pleasant sort of flattering experience. Because he called me -- I'm on
the phone with this guy. He said he's Michael Jackson, he really wants to see me, he had some
things he wanted me to look at. And I said yeah, right, who is this really? And he said no, no, it's
really me. And I said, okay, I tell you what, you give me the phone number of where you are -- I
asked him where he was staying. He said he was staying at the Four Seasons. And I said okay,
well, you give me the number at the Four Seasons and your room number and I'll call you back,
and then I'll know if that's really you. And he said, okay, when you call back, don't ask for
Michael Jackson. Ask for Mr. Michael Jefferson. So I did, and then it was him again. And I said
oh, well, maybe this really is him. So we saw him shortly thereafter.
Q. So we'll go to the scene in a moment. Let's do a little bit about the call.
A. Okay.
Q. Did he tell you how he had been referred to you?
A. No, not that I recall.
Q. Did he say how he had heard about your practice or expertise?
A. No. I mean, you know, I mean, I can't recall specifically. He probably said something, but I
just don't remember.
Q. And did he indicate -- you said he told you that there's some things he wanted you to look at.
Did he say what those were?
A. No.
Q. So he was very general?
A. Yes. I got the impression he was going to be interviewing me, as much as I might be
interviewing him. I mean, once we met.
Q. Did he tell you anything in that call about his medical history?
A. No.
Q. Did he say when he wanted to see you?
A. Well, he kind of implied that he was only going to be available for a short period of time. He
wanted to see me basically when the office was closed when nobody was around, which I
thought was a reasonable idea.
Q. And that was his suggestion?

A. Yes. He might have made it known he wanted it to be as private as he possibly could. I mean,
I understand he didn't want to walk into an office with patients there, or with a lot of staff there
for that matter.
Q. And did you set up an appointment during that call for him to come in?
A. Yes.
Q. And how soon thereafter was the appointment?
A. It was within 24 hours.
Q. All right. And at what time did that take place? Was it morning, evening? You said it was
during the normal office hours.
A. Oh, that one was in the evening. The first one was in the evening.
Q. And did you see him in his hotel room?
A. No. He came to my office.
Q. Do you remember who he came with?
A. He came with his small little bodyguard entourage.
Q. More than one person?
A. Yes.
Q. How many do you recall?
A. Maybe two or three.
Q. And do you remember who they were?
A. No, I don't remember that.
Q. So he comes in with two or three people after hours. Who besides yourself was in your
A. My ex-wife and Dr. Virgil, I believe it was. Well, I don't know if he was there or what it was.
He might have been there. Or yeah, I think he was there.
Q. And why was Dr. Virgil there?

A. Because Michael gave me the impression that he might want something done or something of
that nature. I can't remember.
Q. Like something right away?
A. Yeah.
Q. So you had Dr. Virgil just in case it was an immediate --
A. Yeah. Or I might have called him or something. He might have not been there when I first got
there, but he was made aware as I recall. I'm fuzzy. That was over ten years ago.
Q. Can you recall what that intimation was of a procedure by Mr. Jackson?
A. I don't recall. But he made it sound like he did want to have some adjustment of some sort
Q. And do you know what it was an adjustment to?
A. It was something on his face as I recall. I think it was his face, yeah. It's in the record.
Q. Okay. So Mr. Jackson arrives. How long was he there during that visit?
A. Maybe a couple of hours altogether.
Q. Did you, in fact, perform a procedure?
A. It seems like I did. I mean, I might be, you know -- I might be missing some time, but I think
we did.
MR. PUTNAM: So I'm going to enter into the record three documents. The first document is a
14-page document, the first page of which says Investment Analysis, Complete Cosmetic
Surgery Center.
THE WITNESS: What was the date on that one?
MR. PUTNAM: That one has a date of 10/2/2002 with the patient's name of Michael Jackson. I
want that entered as Exhibit 2.
Q. Next is a nine-page document. Again, the first page says Investment Analysis, Complete
Cosmetic Surgery Center. Here the patient is Michael Jefferson, and this has a date of 7/30/2003.
This will be entered as Exhibit 3.
MR. PUTNAM: And then Exhibit 4, I have a two-page document. This says Complete Cosmetic
Surgery Center Progress Note. The name is Michael Jefferson, with a date of 10/2/2002.

Q. From your records here, can you tell when was the first procedure that you performed on Mr.
A. When was it? On the 2nd of October.
Q. 2nd of October? And are you making reference to Exhibit 2?
A. Yes.
Q. And is this the -- your medical record of that procedure?
A. Yes.
Q. And can you tell me what procedure you performed on Mr. Jackson during this first time?
A. Collagen injections of upper nasolabial folds, and Botox injections in his lower lid area, lower
eyelid area.
Q. For the uninitiated, could you explain what that means to do a collagen injection of the upper
nasal fold?
A. Well, where you have this nasal crease right here, fillers are routinely used to pump that out
and to give a flatter appearance, which is presumed to be more youthful.
Q. And you did that with collagen?
A. Yeah. That was before this other stuff became popular.
Q. And by "other stuff," you mean like Restalyne and stuff like that?
A. Uh-huh, the hyaluronic acids.
Q. And then you also said you did a Botox of the lower lid. What does that mean?
A. Botox injections for the crow's feet and the...
Q. I'm looking at this record. Tell me about this first page.
A. Okay.
Q. This is Investment Analysis.
A. Okay.
Q. First, it has Michael Jackson as the patient. So this being the first visit, you had his actual
name. On subsequent ones he goes by Michael Jefferson, correct?

A. Correct.
Q. And what is this first page of this document?
A. This is just an agreement as to what will be done and what the itemized charges for that
service will be.
Q. And one of those services here is the anesthesia, correct?
A. Correct.
Q. And your fee is here, as well as the operating room and like?
A. Right.
Q. And then on the second page -- the second and third page seem to go together.
A. Right.
Q. And this is the request and informed consent.
A. Right.
Q. And then here it talks about the procedure and diagnosis requiring what the procedure is.
Could you read what is written in that. I can read collagen.
A. Collagen under general anesthesia. Nasal fold and Botox injection.
Q. So those were the procedures you were doing?
A. Right.
Q. And it indicated that the collagen was administered under general anesthetic?
A. Right.
Q. Is that typical?
A. No.
Q. Do you recall why you did it in this instance?
A. He expressed a significant needle phobia, and he just really didn't want to tolerate having a
needle in his face. And he had what I think is a significant and long history of facial procedures

just as a lay observer. And so under those circumstances, it didn't seem to be an unreasonable
Q. And this was a request that he made directly to you?
A. Yes.
Q. Let's go back a second. So he comes into your office, and you have some people in the office,
and he brings them with him, correct?
A. Correct.
Q. And when you -- do you then retire to a different office to sit down and discuss what may
occur there today?
A. An exam room, yeah.
Q. And you go in the exam room. What happens in the exam room?
A. We talk about what he wants to do.
Q. And was he there by himself at that point?
A. I don't remember. Probably. Because he really divorced himself from his entourage once he
got in the building. So they were sort of either outside or they were somewhere.
Q. But you weren't dealing with them?
A. No, I wasn't dealing with them.
Q. And do you remember what Mr. Jackson told you he wanted to accomplish in terms of
medical procedures at that point?
A. Well, no. I mean, other than he just wanted to have a little bit of collagen. I mean, it wasn't
anything super -- it wasn't anything dramatic.
Q. Was he specific as to what he wanted?
A. Yes, very specific.
Q. He knew exactly what he wanted?
A. Yes.
Q. And did he specifically ask you for the general anesthetic?

A. Yes.
Q. Did he say what type he wanted?
A. I don't remember. I mean, no, not really. Not that I can recall.
Q. And did you take his medical history at that point?
A. Yeah. Yes.
Q. As we sit here today, can you remember what his medical history was?
A. No.
Q. How long was he there? Did you say a couple of hours that day?
A. Probably, yes.
Q. If we go to the next page of this document, it's one page. It says prescription.
A. Okay.
Q. Here it becomes Michael Jefferson.
A. Okay.
Q. Is this also for Michael Jackson?
A. Yes.
Q. And this says the same date of October 2nd, correct?
A. Correct.
Q. And then there are various prescriptions?
A. Right.
Q. Could you tell me what each those prescriptions are?
A. These are all homeopathic medications. And these were given to him. We ordered them, have
them in the office and just give them to patients. But we just want to have a record of what we
gave him.
Q. So these are all things you gave him?

A. Yes.
Q. Now, the first one, what is this Arnica Montana?
A. Arnica Montana is a homeopathic slash herbal medication that's intended to reduce bruising
and swelling.
Q. And what is Bromelain?
A. Bromelain.
Q. Bromelain Joint Ease?
A. Bromelain is another medication I think that comes from pineapple extract of some sort, and
that's also used to reduce bruising and swelling.
Q. And Vitamin
A. Vitamin
A. is Vitamin
Q. What does that do?
A. Vitamin
A. has been shown -- these are all designed to reduce post operative discomfort by working
synergistically to reduce bruising and swelling. There's other ones, too, that we use, but...
Q. And why did you prescribe these to Mr. Jackson?
A. Because I wanted him to be as comfortable as possible post op. And I give them to all my
patients, every patient.
Q. Now, on the next page, it says Complete Cosmetic Surgery Center.
A. Uh-huh.
Q. Operative Summary.
A. Right.

Q. And then it talks about his condition, it was satisfactory.
A. Right.
Q. What it says under indications H&P. What does H&P stand for?
A. History and physical.
Q. Is that from your taking his history?
A. Yeah. It's just a verbal history that I took.
Q. And it says, "This patient desired correction of an unattractive area in his nasolabial folds
A. Right.
Q. That's what you were talking about before?
A. Right.
Q. And then, "Upon examination this patient is found to be in good health with no obvious
contraindication to surgery." What does that mean?
A. It means this doctor looked at that patient and said -- examined the patient, and the patient
appeared to be in good health with no obvious reasons not to do the surgery.
Q. And how complicated of a medical history do you do at this point before you --
A. We do focused exams. So we're not doing a rectal or anything.
Q. Just -- do you ask them their history?
A. Yeah. I mean, I ask them for a history that I think would be pertinent. Like had they had it
before, what did they have before, that kind of thing.
Q. Do you recall asking if he had this before?
A. Yes.
Q. And had he?
A. I'm pretty sure he did tell me yes.
Q. Now, the next page it says Anesthesia Record. Do you see that?

A. Uh-huh.
Q. And this is for October 2nd, 2002. Now, the writing here, is this your writing?
A. Yes. Well, no, no, no. I think I wrote the Zyplast at the top, but the rest of this is Dr. Virgil's
Q. All right. I'm going to ask if you can tell here what anesthetic was used.
A. It looks like propofol for induction. It looks like he used flurane, which is isoflurane. Nitrous
oxide I think, yeah. And oxygen. Well, those are anesthetics, but propofol. I don't know about
that thing under propofol. But then he used Lidocaine. I used Lidocaine.
Q. What is Lidocaine?
A. Lidocaine is a topical anesthetic.
Q. And did you use that in conjunction with the propofol?
A. Well, he might have used it to get the IV started to numb up the skin a little bit. But he was
asleep, so I didn't really need to use it for what I was doing.
Q. And so Dr. Virgil was the doctor that assisted you here?
A. No. He was the anesthesiologist. He had his job, and then I had my job. And my assistant was
that Paula Rhodes person.
Q. And then if you look in the -- two-thirds of the way down, there's a box on the right, and it
says allergies, and then there's some things afterwards. Does that mean these are allergies that
Mr. Jackson said that he had?
A. That's what it would appear.
Q. Can you read what those are?
A. Compazine, Phenergan, Phenothiazine. MS, which is morphine sulfate. Demerol. Demerol
and morphine cause nausea apparently, but Dr. Virgil needs to answer those questions, because I
didn't write this, he did.
Q. That was my next follow-up question. One other thing I want to ask. To the left of that there
are start and finish. What is start and finish?
A. Well, the anesthesia has to start before I start. And the anesthesia has to end after I end.
Q. So this talks about how long the anesthesia was administered?

A. The anesthesia -- he was doing his job from 9:00 o'clock to 9:20, and I was doing my job from
9:05 to 9:15.
Q. Looking at this, is there anything out of the ordinary that you see in this?
A. No. Was there -- as you sit here today, was there anything notable about that visit that stands
out in your mind?
Q. Anything out of the ordinary?
A. No.
Q. So as we are going at the end of the page we were on a moment ago, where it talks about
three days or call, do you remember if he had a followup visit?
A. Actually, he did. He had another visit. I think it was two days later, three days later.
Q. And what do you remember from that visit as we sit here today?
A. Well, I think he wanted -- he wasn't totally happy with his collagen injection. And I'm
inferring from the record, because I don't remember, that he had a very small additional amount
Q. Where do you see that in the record?
A. Well, I see another anesthesia record from another anesthesiologist.
Q. And is that on the next to the last page of this document?
A. Yes.
Q. Let's look at that for a second. It says Anesthesia Record.
A. Right.
Q. Michael Jefferson.
A. Right.
Q. Now we have a date two days later.
A. Right.

Q. It says today's date October 4th, 2002. It says the surgery date of October 2nd, 2002. So this is
the two-day later procedure. On the bottom it says, you know, looking at the same things that you
provided before, if I look under the start time for the anesthesia, it is 8:15, and the end time is
9:03; is that correct?
A. That's what that looks like.
Q. So this is a lot longer procedure, correct?
A. Well, yeah. Yes, it is.
Q. And then the surgery in this instance was from 8:25 to 8:55?
A. Correct.
Q. What does it say on the right there, to the extent you know? There's something written.
A. I think what he says is: Patient to OR, monitor. Something about O2. I don't know what kind
of O2, IV inserted. They use an LMA, which is a type of endo -- a type of breathing tube.
Anesthesiologist was Dr. Habashi. He's got vital signs listed. I don't remember anything about
this, though.
Q. But you do -- do you remember him coming the second time?
A. Not really. But this -- I mean, this is not anything conjured. I mean, this was in his record, and
it's got his name on it. I can't say I clearly remember it, but it would not surprise me if he came
back two days later and didn't like something. And the anesthesia times could be a little -- these
might be longer than they really were only because there may have been conversation in the
operating room for all I know. I mean, I just don't remember.
Q. Does it say again at the top what anesthesia was used?
A. It looks like he used flurane and propofol. I think that's propofol.
Q. Now, is there anything you can recall from the second visit?
A. No. I'm having a hard time remembering it. And I included it because it was part of his
record, and I wasn't trying to delete stuff. But I just know this is here. That's all I can tell you
right now.
Q. What is your record deletion policy, if any?
A. I don't have one. I'm just saying I wasn't -- I knew I would have a little trouble explaining this
to you. But, you know, all I can say is I'm pretty sure this is part of his record. And that, you
know, I can't even tell you exactly what we did.

Q. When you say you would have a little trouble explaining this to me, what made you think you
would have a little trouble explaining this to us?
A. Because there was no operative note that we could locate. Because that would, I remember
that's what I would have created, a record that I would have created. And the only thing that
makes me believe that this is part of Michael's record is the fact that his name is on here. I mean,
this could even be an anesthesia record for somebody else that has his name on it, because that's
generated from the computer, and there could have been an accident. But I don't know. I'm just --
it's here.
Q. So we have an anesthesia record for the 4th, but no surgery record for the 4th?
A. Right.
Q. So there's none of your records here, correct, for that date?
A. That's exactly right.
Q. But there is one for an anesthesiologist?
A. Right.
Q. But with your name, correct? The surgeon is there?
A. Right.
Q. And it has the surgery date that you performed two days earlier, correct?
A. Right. But, see, that's all -- today's date is the date that that anesthesia record was printed.
That's what today's date means. So this anesthesia blank record, this is a blank sheet and then the
anesthesiologist fills it in. So if for some reason they were needing an anesthesia record for
somebody in the operating room, and in some sort of a haste or some sort of mix-up they printed
one that had Michael's name on it from two days prior by accident -- I'm not saying it's an
accident, I'm just saying, then this could be for a different person. But you know, it's a little
embarrassing to admit that, but that's just the truth. So the only thing I know is Dr. Habashi was
the anesthesiologist. I was the surgeon. This came from my office. That's all that I know.
Q. Did you talk to Mr. Jackson in the days after his surgical?
A. He was hard to get ahold of. He would come and do his thing and have his thing done to him,
I guess, and then he would be hard to catch. I tried to call him. I know I tried to call him just a
post op check up phone call type courtesy thing, but he was always very difficult. You would
have to leave messages, and he really wouldn't return them.
Q. Do you remember speaking to him in this time period after the surgery?

A. I remember trying. I remember basically for the two times that we actually did surgery on him
in the post op period, it was difficult to get ahold of him. So, you know, I just accepted that as,
you know, part of this.
Q. And do you remember any kind of follow-up to the October 2nd surgery with Mr. Jackson?
A. Not really. I mean, he was like a phantom. He would just sort of come and disappear. Because
when he came back a year later he just popped up out of the blue, and then the visit after that was
several years later.
Q. What was your impression of Mr. Jackson's health, if you recall?
A. I thought he was healthy. He was pretty robust. He was taller than I thought he would be. And
he seemed -- and he definitely seemed, you know, physically healthy.
Q. Did you like him?
A. Yeah.
Q. Was there anything out of the ordinary about the procedure that occurred that you can recall?
A. Which one?
Q. The one where you went in for the Botox and for the collagen?
A. No.
Q. What about the administration of the anesthesia?
A. It was quick and simple. It was a simple, simple thing for those guys to do, except Michael
was a little bit of a -- he was a little bit of a whiner, a little bit of a baby about, you know, having
an IV started and about, you know, having a propofol injection.
Q. What do you recall about him being a little bit of a whiner about that?
A. Well, I mean, he made the remark that it burned. And he actually referred to propofol as milk,
which I thought was a little unusual. That I thought was a little unusual.
Q. What would he say?
A. Well, he just seemed to be more familiar with it than most people. He knew it was white and
looked like milk. And most people don't really, you know, relate to it like that.
Q. Tell me what exactly he said, if you can recall.

A. Well, I mean, that was more of a conversation between him and the anesthesiologist. But I
remember him using -- describing it as milk, and I remember him having a hard time finding a
vein. And I remember him saying it burns, it burns as he was going to sleep.
Q. But he referred to the propofol as milk?
A. Yes.
Q. And how did he bring up milk? Did he say is that the milk? What exactly did he say?
A. I just -- I don't know if he was -- let me think now. I don't know if he asked if that was going
to be used or if he -- I don't know. I don't remember.
Q. Okay.
A. It really wasn't a conversation with me. It wasn't a conversation with me.
Q. You overheard it?
A. Yes.
Q. Do you recall whether Mr. Jackson asked for any medication to help alleviate the burn?
A. Not while he was being put to sleep.
Q. Did he ask for any medication at the end of this first visit you can recall?
A. No.
Q. Now, going back to this Exhibit 2, we got to a page several months later where it was March
25th, 2003.
Q. You see there's a fax, it appears from you to someone named Evie.
A. Yes.
Q. It says "please remit."
A. Right.
Q. March 25th, 2003.
A. Uh-huh.
Q. Do you recall what this is?

A. Well, this is my office sending his bill-paying-people a copy of an investment analysis that we
talked about. And it said resubmit 3/25/03. And that was what was sent a second time to these
Q. Okay. And why did you have to send it a second time?
A. Because he didn't pay us the first time.
Q. Did he seem determined not to pay?
A. Well, let's just say whoever is on the other end of the phone, or let's just say I don't know
whether it was an accident or if it was an oversight or who knows what. I just know that we
were, you know, we were told at the time the services was rendered that just send him, you know,
the bill, it will be taken care of. Normally we were paid in advance. That's how we work. That's
how we operate. And so we, you know, took him at his word that he would take care of his
financial responsibilities. And it was a long time coming, and it was multiple communications
necessary to get paid. But we were determined to get paid.
Q. Now, for the second procedure on October 4th, do you recall whether that was paid in
A. I don't think we charged for that.
Q. You didn't charge?
A. I don't have enough supporting document to really say a whole lot about that.
Q. Is there anything --
A. My impression would be that if this is a sequel or an addendum to what was done previously,
then no further charges were made.
Q. Is there anything else you can remember about those two visits on the 2nd and the 4th?
A. No.
Q. You said that you noted that Mr. Jackson seemed familiar with the propofol, called it milk?
A. little bit, yeah.
Q. Did he seem familiar with the procedure generally?
THE WITNESS: Yeah, he did actually.

Q. In what way?
A. Well, he gave me the impression that he was used to telling doctors what he wanted them to
Q. And how did he give that you impression?
A. Well, just his specificity about what he wanted and where he wanted it and how much he
wanted and this kind of thing; how he wanted it done.
Q. And did he make those indications in terms of the propofol?
A. Not to me.
Q. Did you overhear him doing that with the anesthesiologist?
A. No, not really.
Q. And was he specific with the anesthesiologist --
Q. -- as to what he wanted?
THE WITNESS: Well, that's what we had had. That's what we used. So, you know, it wouldn't
have mattered whether he said give me propofol or not, because that's what we would have used,
because we stopped using that other stuff. I can't think of the name of it. Years ago.
Q. But he did say to use the propofol?
THE WITNESS: Well, he wasn't -- he might have asked the question about it. He made some
reference to it and he was familiar with it. I could tell that he had had it before. And, you know,
he was very much -- I mean, that's how he wanted to go to sleep.
Q. Now, did you see -- when was the next time you came to see Mr. Jackson? Was it -- was it
here on Exhibit 3?
A. Yeah. He came to see me.
Q. Between the visit on the 4th of October and the visit noted here on July 30th, 2003, did you
have any discussions with Mr. Jackson?
A. No communication whatsoever.

Q. And did you see him?
A. No.
Q. So look at what is here marked as Exhibit 3. Is Exhibit 3 a record of Mr. Jackson's next visit
to your office?
A. Yes.
Q. And it talks about a procedure to explant foreign body from abdomen area.
A. Right.
Q. And what was the procedure that was being performed that day?
A. Well, Michael claimed that he had fallen and had sustained an injury to his abdominal area,
and he believed that there was still some glass or some other foreign body in his abdomen. And
he said it was painful and he wanted me to remove it.
Q. How did it come to be that you had this conversation with Mr. Jackson? Did he telephone
A. I don't remember. Probably, yeah. Yeah, he would have because he doesn't make appointments
and come to the office.
Q. Ultimately, you had an appointment with Mr. Jackson in your office?
A. Right.
Q. And did you perform the surgery?
A. Yes.
Q. And what did the surgery entail?
A. It entailed under general anesthesia he had this wound, this area where he had an injury re-
Q. What does that mean?
A. He means we cut out the whole thing and sewed the margins back together.
Q. Did you remove anything from Mr. Jackson's abdomen?
A. I didn't remove any foreign body that I could recognize.

Q. Was there any foreign body that you couldn't recognize that you were removing?
A. Well, I mean, it wasn't sent for pathology, so I can't tell you what the microscopic exam of the
tissue would have shown. But there wasn't any glass. There wasn't any metal. There wasn't any
wood. There wasn't anything that was inorganic that wouldn't have been absorbed. So as far as I
could tell, it was a negative exploration. It didn't show any material thing.
Q. And was there evidence that something had been removed previously?
A. No.
Q. Was there already a scar there?
A. There was some sort of something. There was either a small scar or a -- yeah, a small scar or...
Q. About how big?
A. I'm going to guess it was maybe an inch or inch and a half, something like that. Not very big.
Q. If we look at the first page that we're looking at before, this procedure to explant a foreign
body from the abdomen, and then it says a procedure to temporarily paralyze the muscles on my
face for the treatment of wrinkles.
A. Right.
Q. Is that Botox?
A. Yes.
Q. So you did this procedure you mentioned a moment ago and performed Botox?
A. Yes.
Q. And is this first page your bill for that?
A. The first page? Yes.
Q. The second page is a consent for surgery.
A. Okay.
Q. And it mentions it is scheduled for 7/30/2003.
A. Okay.
Q. Would that be the day you would have performed the surgery?

A. Yes.
Q. And on the second page of that document, the third page of the entire exhibit, there's a
signature. Is that Mr. Jackson's signature?
A. Yeah.
Q. And the anesthesiologist in this instance was Dr. Virgil?
A. Right.
Q. It then talks about again the EBL is nil. What does that mean, "Marcaine field block at
conclusion of surgery"?
A. That means that I used a long-lasting anesthetic to inject around the area that I operated on so
that there would be reduced need for him to have pain medications after surgery.
Q. Then there's a description of the operative procedure. It says, "Following induction of
anesthesia, the patient was prepped and draped in a normal sterile fashion, and the wound of
prior injury presumed to still contain a foreign body, parenthesis wound packing, question mark,
iodoform gauze, end parenthesis, was surgically excised." What does that mean?
A. It means that I -- I cut around what was supposed to have a foreign body in it. And the foreign
body was presumed to be wound packing or something like that. Which again, I saw no evidence
of. So it wasn't glass, it wasn't metal, but this was reminding me he thought there was still some
packing in the wound.
Q. Do you remember how much -- you say that you excised material. How much material did
you excise?
A. Probably about an inch and a half by about maybe a half inch worth of tissue.
Q. And could you read the next paragraph, the one that says hemostasis. Could you read that for
A. "Hemostasis was acquired, and wound closed in layers with monocril. There were no
Q. What does that mean?
A. That means that after we cut out this scar tissue, we made sure there was no bleeding. That's
what hemostasis is. And the wound was closed in layers, meaning more than one layer, like a
deep layer and then a mid layer, whatever. With monocril which is a type of suture.
Q. On the next page we have an anesthesia record somewhat different than the last one.

A. Right.
Q. Again, there's a place here in the top right where they say anesthesia from 10:30 to 11:45.
A. Uh-huh.
Q. So that means that the anesthesia was for about an hour and 15 minutes?
A. That's what that means.
Q. And then the procedure itself was from 10:45 to 10:40?
A. To 11:40.
Q. Sorry, strike that, 11:40.
A. Uh-huh.
Q. And that was for a little less than an hour, then?
A. Yes.
Q. And can you tell here what type of anesthesia was used?
A. Yeah. Inhalation anesthesia was used. Isoflurane was used. And Diprivan was used.
Q. Is Diprivan another name for propofol?
A. Yes.
Q. And where do you see the Diprivan?
A. Well, if you look on where it says time on the left-hand side.
Q. Yes, I see it.
A. Okay.
Q. Any other anesthesia used?
A. They used Fentanyl. That's a pain medication. They used lidocaine. That's a local anesthetic.
Q. And Dr. Virgil's name is there on the bottom?
A. Right.

Q. On the bottom there under medications, what is that?
A. Fentanyl?
Q. And what is Fentanyl?
A. It's a pain medication.
Q. And would this have been provided in the recovery room?
A. Yes.
Q. Now, you had indicated that in this instance -- is this the instance where he asked for
A. Yes.
Q. Tell me about that. What happened?
A. Well, he was getting ready to go, and he said that he wanted me to give him a shot of Demerol
for the road. And I said, Michael, I don't do that. And I said, how much did you want? Because I
was curious. And he said about 300 milligrams. And I said, oh -- I chuckled. I said there's no
way I'm going to do that, Michael. I said, That's ridiculous. I said, I've already put a block so that
you're not going to feel anything for hours, and you just need to go home and just, you know,
take it easy. It's not a big deal. So he left. I mean, and then I didn't hear from him for, what, four
Q. So first of all, what was your reaction to his request for the Demerol shot? Were you
A. Yeah, a little bit I was.
Q. What is Demerol?
A. It's a pain medication.
A. narcotic.
Q. Is it something that you commonly prescribe?
A. Well, no, I don't prescribe it. I mean we might use it as a pain -- you know, in the recovery
room for pain or even during surgery for pain. But that's not something that I prescribe routinely.
If I was in a hospital environment and I had to write post op orders on a patient I might use
Demerol. But in my particular situation, the anesthesiologist would be in charge of post op
orders, and he would write it if anyone writes it. Although either one of us can do it legally.

Q. And how is it typically administered?
A. Either IM or -- intramuscular or intravenous.
Q. And you said Mr. Jackson asked for a shot?
A. He asked for an intramuscular shot.
Q. And is there a typical milligram dosage of Demerol that is given postoperatively?
THE WITNESS: Well, yeah, I would say so. It kind of depends on the amount of pain or what
you've done and what you anticipate and things like that. But the most that we would generally
give somebody might be like 100 milligrams, and he was asking for 300.
Q. Were you surprised by the amount he requested?
A. Yeah.
Q. Why were you surprised by that?
A. Because that's a lot. And I certainly wouldn't give that to somebody and let them try to leave
my facility and get into trouble somewhere.
Q. What was Mr. Jackson's reaction, if any, to your telling him that you wouldn't provide him
with a shot of Demerol?
A. Well, I mean, I don't think he debated with me or argued too much with me about it. I think he
tried to convince me that that wasn't much for him, and that, you know, he could -- I got the
impression that he had had -- he had received Demerol from somebody before. And that he
might have -- I mean, that's all I can say with any confidence is that I got the impression that he
had favors like this done for him before. Maybe not in that amount, but...
Q. Tell me, let's go back to the beginning of that visit if you can recall. Did you see him prior to
the day -- in terms of this visit, did you see him in a preoperative sense prior to July 30th? Did he
come in for an exam?
A. Not that I have a record of or that I remember.
Q. And when he did come in, do you recall if he came with anyone?
A. He came with somebody.
Q. Do you remember who?

A. He came with his little entourage of bodyguards and limo drivers and stuff like that.
Q. So bodyguards, limo drivers. Anybody else with him?
A. No.
Q. Did anyone -- did you have a preoperative procedure that you went through with him where
you asked him questions?
A. Oh, yes. I always ask questions. And he just really wanted me to explore this thing, and so we
did. He also wanted the Botox.
Q. Did he tell you how -- why he believed that there was some remaining -- you called it
something, I can't remember.
A. He has packing. I thought that -- I remembered him saying that he had an injury, and I thought
that he said he had a foreign body in there. But for some reason in the operating record I said that
there was no packing seen. So apparently somebody had treated him and packing was in there.
So I'm missing that little bit of history at this point.
Q. You don't remember that as we sit here?
A. No.
Q. Do you recall Mr. Jackson indicating to you in any way why he believed that there was still
material left inside his abdomen?
A. He said that he could feel it or it hurt or something like that.
Q. And did he indicate to you how that material got there in the first place?
A. Well, my initial recollection was that he had had a fall or an accident or something, or had
somehow impaled himself or something to cause some kind of an injury. Reading the operative
report, it gives me the impression that he did see somebody who did something, but I mean it
was a healed wound when I saw him.
Q. Got it. And you went in to see if there was anything left?
A. Right.
Q. And you took out a piece --
A. Of tissue. When I cut it and looked at it, and I couldn't see anything.

Q. Got it. And then after the procedure, Mr. Jackson asked for Demerol. Did he ask for anything
A. No.
Q. Did you prescribe any kind of post operative medications for him?
A. He probably did have a prescription written for, you know, pain pills or something like that,
but nothing like a Demerol.
Q. And then you said you didn't hear from him again for four months; is that correct?
A. Four years.
Q. Four years, sorry.
A. Until '07.
Q. All right.
A. Although he did try to see me in between those times, but I was out of town. So I had to refer
him to somebody else.
Q. When -- what do you recall of that? Did he reach out to you and ask to see you?
A. Yeah.
Q. And do you remember what time period this was?
A. All I remember it was between '03 and when I did see him in '07.
Q. And do you recall, did he say why he wanted to see you?
A. It seems like he had -- I want to say he had a hand injury, but I'm not totally sure that's what it
Q. And you didn't see him at that point?
A. I couldn't. I think I was out of town or on my way out of town.
Q. Who did you refer him to?
A. I think I referred him to Dr. Weiland.
Q. How do you spell that?

A. W-e-i-l-a-n-d.
Q. Do you know if he actually saw Dr. Weiland?
A. I think he did see Dr. Weiland.
Q. What's Dr. Weiland's first name?
A. Stephen.
Q. So you didn't see him that time, and then the time came in 2007 when you did see him?
A. Right.
Q. And did Mr. Jackson once again reach out to you?
A. Yes. Well, actually I don't know if he did or his doctor did.
Q. And did you at that time speak to a doctor for Mr. Jackson?
A. Yes.
Q. Who was that?
A. Conrad Murray.
Q. Had you ever spoken to Dr. Murray before?
A. No.
Q. Did you ever know who he was before?
A. No.
Q. Is this the first time you ever met Dr. Murray?
A. Right.
Q. Did you speak to Dr. Murray on the telephone?
A. I might have, yeah. I guess I did.
Q. And did Dr. Murray indicate why Mr. Jackson wanted to see you?

A. I think that they were -- they were -- I don't know, what was it they were getting ready for? He
was getting ready for some concert or something, I can't remember exactly what it was. And he
wanted to have some more filler in his face.
Q. And did Dr. Murray tell you who he was when you called?
THE WITNESS: Did he tell me who he was? He said he was Dr. Murray. I later found out who
he was.
Q. How did that occur?
A. Well, when he came to the office, of course, he was -- he wasn't too secretive about being a
cardiologist and all that kind of thing.
Q. Did he indicate why he was calling on behalf of --
A. Well, he presented himself as being Mr. Jackson's personal physician and spokesperson to
some extent, and -- yeah.
Q. Did Dr. Conrad Murray come to the office with --
A. Yes. He drove him.
Q. He drove him there?
A. Yes.
Q. Was it just the two of them?
A. As I recall.
Q. And do you know -- you said this was in 2007. Do you know what month?
A. May 14th.
Q. So you spoke to Dr. Conrad Murray sometime before May 14th, and then the visit occurred
on May 14th?
A. Well, it might have been the same day. Usually stuff happened real quick, you know. So it
wasn't like a week later. It wasn't like he called for an appointment the next week or anything.
Q. Was this the first time you had spoken to any doctor who described himself as Mr. Jackson's

A. Yes.
Q. Had you ever spoken to any other doctor on behalf of Mr. Jackson before?
A. No.
Q. And so Dr. Conrad Murray arrives with Mr. Jackson. And what occurred? Did they walk in
and did...
A. Well, okay, he walks in with Mr. Jackson and he introduces himself and says that he, you
know, is his physician and they're here, you know, for some Juvederm or filler in his face. He's
very specific once again about how much. And he wants it done -- now he wanted to do it under
local. So we're going to do this under local. So getting him numb was a bit of an issue. It was,
you know, somewhat dramatic. And the thing that I thought was a little bit curious was that
Michael acted like he had never been there before. So I found myself addressing that with
Conrad. I said, you know Dr. Murray, I find this a little odd that Michael is acting like he's never
been here before; he's been here several times. So I don't know exactly what the, you know, the
deal is but, you know, I feel like he's been a patient of mine already. And I guess I'm glad you're
here, but I just want you to know that this is not his first time here. And he said, well, that's --
and he tried to placate me some kind of way with the words that would imply, well, that's really,
you know, that's okay. It's not a, you know, don't worry about it. You know, we'll make sure that
everything is. So he certainly did try to be a spokesperson for Michael. And I had never had a
doctor feel like they needed to -- I mean, if I've had a problem patient, I might communicate with
the doctor that's helping me out on it. But this was a little different. And he wrote a check to pay
for Michael's bill that same day kind of thing.
Q. Dr. Conrad Murray did?
A. Yeah.
Q. And was it, do you remember was it a personal check?
A. You'll see it. It's on the next page.
Q. So this last page here, that is the check Dr. Conrad Murray made?
A. Uh-huh.
Q. And he made that out personally to you?
A. Yeah.
Q. Did anybody else come with them besides Dr. Conrad Murray and Michael Jackson?
A. Not that I can recall.

Q. And did you have your normal premedical conversation with Mr. Jackson about his medical
history that you had on the other two occasions?
A. Well, it wasn't much to discuss because he had already had injections before. He had had
Botox before. There's not a lot of conversation that goes on with patients about facial fillers.
Primarily because this Juvederm stuff basically has almost a zero rate of allergic reaction or
problem. So there's not, you know, a whole lot to talk about.
Q. And did you perform the procedure?
A. Yeah.
Q. And was Dr. Conrad Murray present when you performed it?
A. Yes.
Q. Is that usual?
A. No.
Q. Had you ever had this happen before?
A. Well, I never had a doctor bring a patient and be their spokesperson before.
Q. So this was the first time?
A. I mean, it wasn't like we were both trying to problem solve. It was not like we were scratching
our heads saying, gee, what are we going to do with his nose? This was, you know, Michael
having a personal physician that, you know, would represent him.
Q. Have you ever had any patient do that since that time?
A. No.
Q. So this is a one time --
A. Yes.
Q. And have you ever had a doctor pay for a patient's procedure personally before?
A. No.
Q. And you said that this time he wanted a local.

A. Well, I don't know if he wanted it or what. But he was more, you know, he was more willing
to do that. And, you know, for whatever reason, maybe it was for expedience or whatever. I don't
know. I don't know what the deal was. I can't remember that.
Q. Now, with this procedure, did Mr. Jackson receive any, you know, post procedure care by
A. Not really because -- no.
Q. Did you prescribe any pain medications for this procedure?
A. No, not that I can recall. There's no record of it.
Q. Was there any request for any such?
A. Not really. Because Conrad was his -- Conrad was taking care of his day-to-day needs.
Q. And what makes you think that?
A. Because they had a very close relationship, and Conrad made it fairly clear that he was his
personal physician taking care of his needs.
Q. Did Dr. Murray make any indication as to when he started being a doctor for Mr. Jackson?
A. No. Not that I can recall. But I don't think it was -- I got -- not that I can recall, but my feeling
is that it hadn't been that long. Maybe a matter of months.
Q. What gave you that impression, if you can recall?
A. Well, because I got the impression that Conrad was wearing two hats. He was Michael's
personal physician, but he was also trying to stay in his cardiology practice, kind of a thing. So it
wasn't yet a full-time job, I didn't think. But he made himself very available to Michael. That was
pretty obvious.
Q. Did you see Mr. Jackson at any time after this date?
A. Not that I can remember.
Q. Can you recall speaking with him at any time after this date?
A. No.
Q. Did you see -- did you speak to Dr. Conrad Murray at any time after this date?
A. Not that I can remember. I mean, either the same day or the next day there might have been
some concern about, oh, he's got too much in one place or another. And I said warm compresses.

Or it might have been the same day. I think it might have been there quite a while that day
fussing over the appearance.
Q. When you were talking about having the local done, he wanted a local at this time for the --
let me make sure I have the right date, 2007. And you said --
A. Oh, yeah, yeah, yeah, yeah.
Q. What did you mean by that?
A. I meant that, you know, he was very -- I have to go really slow. I have to -- it seems like there
might have been a topical put on ahead of time, or something like that. He required a fair amount
of codling I guess is the best way to put it, even with Dr. Murray being there. But at least he was
willing to do it under local, which was progress.
Q. Why do you say that was progress?
A. Because before he wanted to have general anesthesia for this stuff.
Q. Did you speak with Mr. Jackson during this visit? It seemed like you were talking with Dr.
A. Well, I didn't speak to him as much as I had in the past.
Q. Is that because you were talking to Dr. Murray?
A. Yeah. And because Michael, you know, appeared to not remember being there before. Which
may or may not have been his intention, I don't know. But on previous visits we talked about his
music. He autographed a couple of albums that I had of his. And he talked about some of the
things he liked to collect. And he said he would like to have -- he indicated he would like me to
procure something for him. I didn't really take him serious. So we had had conversations before.
Q. But that wasn't true this time?
A. Not to the same -- no. I didn't feel like I had a personal rapport with him as doctor/patient like
I did before because I think Conrad was very much an intermediary.
Q. I'm just curious, what was the thing that he indicated he might like you to procure earlier?
A. It seemed like it was a lamp. I'm not sure.
Q. And you had mentioned that on a prior visit Mr. Jackson seemed to be in good physical
A. Yeah.

Q. Did he seem to be in good physical --
A. Yes.
Q. And did he seem alert?
A. Yeah, he was alert.
Q. Did he seem different in any measure physically than the first time?
A. Not really. After that 2007 visit, were you contacted by Dr. -- strike that -- by Michael
Jackson at any point?
A. No.
Q. All right. I do have a couple of questions. I wanted to start off with a couple of things you
mentioned at the early part of the deposition. You said that Mr. Jackson, when you met with him
in 2002, wanted to remain private and he wanted his records to be protected. Did you -- what did
he say that led you to that conclusion?
A. Well, it was more what he said about the name that he had at the hotel. And we wanted to also
make sure that his records were a little bit more difficult to locate in my office. Because we just
felt that it was -- that it was worth the effort to try to make it more difficult for someone other
than myself to put their hands on his records. So we used a different last name, the one that he
gave us.
Q. And that was your idea to use the different last name on your records?
A. Yes.
Q. Because you were just concerned that some tabloid or something might --
A. We were just wanting to make sure that we were protecting to the best of our ability the
business he had with this office.
Q. And part of that was to try to put the records under a different name?
A. Right. And to be agreeable to see him at times other than regular office hours.
Q. Now, although I do know that the informed consent was under his name, right? On Exhibit 2?
A. Uh-huh. But the chart cover that the stuff went into had Jefferson on it.
Q. So in other words, if somebody were pawing through your files, they would not be able to,
unless they went through each file individually --

A. Or unless they knew that the last name that we had given him was Jefferson. They would have
to know that.
Q. Now, I do want to ask you a couple of questions about -- and you mentioned also by the way
that you have an accredited operating room at your surgery center.
A. Yeah.
Q. And that accreditation is by what authority?
Q. I'm sorry?
Q. What is that?
A. American Association for Accreditation of Ambulatory Surgery Facilities.
Q. Does that accreditation depend on some type of state authority as well?
A. No. The state is different. And that's recent. The state accreditation is different. But -- it's a
recent requirement. But at that time, the accreditation is a national accrediting organization that I
elected to have accredit my surgery center.
Q. So it's a voluntary accreditation?
A. Yes, it was.
Q. At the time?
A. Yes. Now, in 2002, when Mr. Jackson called you, or I think you said he called your answering
service and your answering service called you. Is that your best --
A. The answering service connected us or called me. He was on the line.
Q. And when you met with Mr. Jackson, it was not a secret to you that he had had some plastic
surgeries before?
A. Right.
Q. Did you ever ask him how many plastic surgeries he had had?
A. No. Did you speak with him about either Dr. Klein or Dr. Hoeflin --

A. No.
Q. -- on any of the occasions that you saw him?
A. Never.
Q. Did you ever ask Mr. Jackson to allow you to review any of the medical records with Klein or
A. No.
Q. Now, I think you -- and I wanted to ask you some questions about the first procedure. You
said that there was a collagen injection kind of on the side of the nose?
A. In that fold right here (indicating).
Q. And so sometimes people as they age get lines in that area, and that collagen injection is
supposed to lessen the impact of those lines?
THE WITNESS: Exactly right.
Q. And you said a Botox of the lower lid area, and that's the same reason, to minimize the effects
of aging?
A. Yes.
Q. Now, I think you said that Michael Jackson expressed needle phobia; is that correct?
A. Well, yeah. Yes. In some patients for doing that kind of a procedure, you would take actually a
hypodermic needle and put shots, injections in the person's face while they are alert and watching
you? Is that the way it typically works?
A. Well, yeah. Yes, that can be done that way. But I mean, I don't encourage them to watch me.
Like a dentist doesn't encourage you to watch them approach them with a hypodermic needle.
Q. But the patient would be able to watch?
A. Yeah, I guess. I mean, yeah. I mean, I try to use little tricks of the trade just to sort of
minimize what they can see, but I don't encourage them to watch and jump and become
apprehensive about what we're doing.
Q. But he did impress to you that he was afraid of needles?
A. Well, he expressed that he definitely wanted it done under general. He did not particularly
want it done under local. And the reason, as I recall the reason had more to do with he just didn't
want to have to put up with multiple needle sticks.

Q. And was that your decision to accede to that? Or was that the anesthesiologist's decision?
A. Well, it was my decision, yeah.
Q. Did you think there was anything medically inappropriate about that request?
A. No.
Q. And --
A. I wouldn't have done it if I thought it was inappropriate.
Q. That was my next question. So you agreed to use general, and there was no further discussion
about that that you can recall for the first surgery?
A. Right.
Q. He did not ask what kind of medication would be used for the general prior to the surgery?
A. I don't remember. But -- I don't remember him asking what kind of anesthesia would be used.
I don't remember that per se.
Q. That would be up to the anesthesiologist anyway?
A. That's more anesthesiology type, right.
Q. Did you have any --
A. If he asked me I would have told him, but I don't recall him asking me specifically.
Q. Okay. You don't remember him saying, gee, I hope you use something, or I hope you don't use
A. I don't remember that.
Q. You don't remember any discussions with the anesthesiologist about bringing any kind of
particular medication, any anesthesia to the procedure on October 2nd?
A. I already had all that stuff.
Q. There was nothing unusual about using propofol for this kind of a procedure?
A. No.

Q. But as far as your records are concerned, Exhibit 2, there was no post surgery painkiller,
narcotic or non-narcotic, provided by you, correct?
A. Right.
Q. Or for that matter, by the anesthesiologist?
A. Right. Well, other than what he might have received in the recovery room.
Q. Fair enough. But in the post recovery room there's no record of anything --
A. Right.
Q. -- being provided either as a narcotic or a non-narcotic medication; is that correct?
A. That's correct.
Q. And for this particular surgery on October 2, 2002, was it Dr. Virgil's decision about what
anesthesia to use?
A. Well, he had limited choices, but it was his decision.
Q. What were his choices at the time?
A. Well, he could have used isoflurane. He could have used desflurane. He could have actually
induced anesthesia without propofol. I've seen doctors do that. But it's not common.
Q. Was there any discussion about doing it without using the propofol?
A. Not that I can -- no, I don't think so.
Q. And I think you said earlier there was nothing out of the ordinary from this particular
A. Right.
Q. The anesthesia lasted for about approximately 20 minutes, according to the record?
A. Right, that's correct.
Q. And you've said that there was another procedure on October 4th, but just there isn't a -- you
don't have an operative note for that for whatever reason?
A. Right.

Q. Do you have any thought about why that could be? It could it be misfiled or it could be --
A. I might not have done it, because if this was just a touch-up of what I did two days prior, I
might not have thought -- and it was just a filler, an injection, I might not have felt that it was
Q. I mean, there's nothing unusual about that, I take it?
A. No. Other than I don't remember, but that's a little unusual.
Q. And so you don't remember any discussion from Mr. Jackson on October 4th, 2002, about
asking for painkillers, anything like that?
A. No.
Q. I think you described Mr. Jackson as a phantom a little while ago, a little earlier today. I take
it that he was not frequently calling you asking for, either for surgeries or medications during the
2002 to 2007 time period?
A. Right.
Q. There were a total of three contacts?
A. Yes.
Q. And I think you described as it related to the October 2, 2002 procedure, that it was hard
finding a vein on Mr. Jackson?
A. Yes. Every time it was hard.
Q. Do you remember -- did you examine his arms?
A. Well, I was in the room and I could see that the anesthesiologist was having some difficulty.
Q. Did you see any evidence of any track marks of any kind on Mr. --
A. No. Just the absence of veins. I mean usable.
Q. Usable veins?
A. Yes.
Q. And there are people like that, are there not? That's not uncommon in your field?

A. Well, I mean, usually it implies that the vein had been damaged or injured. I mean, there are
some people that might be fat or, I don't know, females sometimes have a little more difficulty
finding a vein. Normally in a man, you don't have that much trouble finding veins.
Q. Did you see any signs of any kind of -- you know what track marks are?
A. Yeah.
Q. Did you see any signs of track marks, any visible signs of wounds?
A. I don't remember seeing those. I mean...
Q. You would have noted if there were track marks on his arms, would you have not?
A. Well, I might not. I might have, I might not have. I mean, I wasn't trying to make a record of
those kinds of things at the time.
Q. In any event, you don't remember seeing any?
A. I don't remember seeing any.
Q. And I had just have one question on Exhibit 2. Do you have that in front of you? Your note
from -- or your file from the first surgery.
A. Uh-huh.
Q. There is a -- on the third page under the request and informed consent, there's a line, I'm just
going to hold it up and point it to you. It says, one, multiple consultations prior to surgery. Do
you see that?
A. Yeah.
Q. What does that mean?
A. I don't know if that's a one, but he did have a consultation prior to surgery. I don't know if
that's a one per se.
Q. It could just be a checkmark?
A. It could be a checkmark, yeah.
Q. Well, I guess what I'm getting at is before the time of the surgery, you did have a full
consultation with him where you talked to him about what the procedure was going to be?
A. Yes.

Q. And you don't remember any discussion in that about --
A. It was more about -- I'm sorry.
Q. Was that the conversation where it was discussed that he would prefer to use general
anesthetic rather than local?
A. Probably.
Q. Was there any discussion then about what kind of general anesthetic was going to be used,
what specific drug?
A. No, there wasn't that I can recall. Because if there was, it was a matter of him perhaps asking
do you use Diprivan or do you use isoflurane, and what do you use, and I would have just
answered the question. But that would not have been noteworthy to me at the time. Not enough
to make a mental note of it.
Q. Now, the July 30th procedure.
A. Okay.
Q. You also -- you took out some scar tissue?
A. Yeah. You could call it that. Scar tissue and whatever was underneath the scar or in the scar.
Q. There was a scar in the area where he said it felt like something was in him?
A. Yes.
Q. And you took out scar tissue?
A. I took out the scar tissue and subcutaneous tissue with it.
Q. And there was no pathology done on that?
A. No. Because it was grossly negative for foreign body.
Q. And that's really all you were looking for?
A. Yes.
Q. Now, the on the second occasion there was, it appears on Exhibit 3, that Demerol was used in
that procedure.
A. I don't know.

Q. Fentanyl?
A. Which one now?
Q. June 30th, '03?
A. July 30th.
Q. I'm sorry, July 30th, 2003.
A. You're asking was Demerol used?
Q. Right.
A. I mean, you're asking me an anesthesia question here, but I will try to answer it.
Q. Well, let me ask a --
A. No, it wasn't used. Fentanyl was used.
Q. What's the difference between Fentanyl and Demerol?
A. They're two different narcotics.
Q. Whose decision was it to use Fentanyl?
A. The anesthesiologist. Same anesthesiologist that said in his first encounter that Michael got
nauseated from morphine and Demerol, so he already knew that, so he used Fentanyl.
Q. I see. Okay. I think you said earlier this is the time when Mr. Jackson said that he wanted a
shot of Demerol when he was leaving the office.
A. Right.
Q. And you declined to do that?
A. Right.
Q. And did he argue with you at all?
A. Argue? No. He might have tried to talk me into it, telling me that it's okay, he'll be all right,
and all this kind of stuff, but that's not arguing.
Q. Do you remember him doing that?
A. Yeah, I do.

Q. What did he say?
A. He said: That's okay, I've done this before, I'll be fine. I said, No, Michael, I'm not going to do
that and have you have a problem later on. I just wouldn't do it.
Q. And you didn't do it?
A. I didn't do it.
Q. And he came back to see you again?
A. Four years later with a spokesperson.
Q. Did you ask if anybody had given him Demerol before?
A. Oh, no. He told me he's been given Demerol before. During that conversation you just
referenced, he said he had had it, you know, many times, and he actually asked for it to be given
to him.
Q. Now, did he say who had given him Demerol before?
A. No.
Q. In what quantities?
A. Well, he said that 300 milligrams was not excessive for him.
Q. Did he say who had given him Demerol before?
A. No.
Q. And did you remember that he had said in 2002 that he was nauseous from Demerol?
A. I didn't know -- I didn't remember that. I didn't write that note, and I didn't -- that's -- that was
communication between he and the anesthesiologist.
Q. Fair enough. You may or may not have been present during that communication?
A. I -- well, all I know it was written on the operative -- on the anesthesia record. So when this
conversation took place between Dr. Virgil and Michael Jackson, I don't know. But he wasn't
sufficiently nauseated that kept him from asking for it.
Q. Now, in 2007, this is when you say that Murray reached out to you?

A. Yes. He said that he wanted a procedure because he was starting some kind of a tour or
A. Some negotiation for a tour.
Q. And so he wanted some touch-up on his face?
A. Right.
Q. And that was -- you thought there was nothing unreasonable about that?
A. Right.
Q. Dr. Gordon, in 2007 did Dr. Murray tell you what he was doing for Jackson medically?
A. No.
Q. Did you ask?
A. Well, he was just acting -- as he put it, he was acting as his personal physician. And he was
just taking care of the details so to speak in making Michael's interactions with physicians as
simple as possible. That was the gist of it.
Q. But was there any discussion at all about whether Jackson was being treated by Murray?
Q. For any condition?
A. Any cardiac condition?
Q. Any condition.
A. No.
Q. Did you know of Murray before?
A. No.
Q. Never heard of him?
A. Never heard of it him.

Q. The address on the check in Exhibit 4 is a Las Vegas address. And it's Global Vascular
A. Right.
Q. Had you ever heard of Global Cardiovascular Associates?
A. No.
Q. And so before May 14th, 2007, you had never heard of Murray?
A. Exactly.
Q. And up until the time that Michael Jackson passed away, had you ever heard of Murray
having a practice in Las Vegas? In other words, you heard from some other doctor --
A. Well, I knew he had a practice in Las Vegas after he visited me with Michael, and I think he
told me he had another office in Houston. Something, wow, you know, you've got an office in
Houston, you've got an office in Las Vegas, and you're Michael's personal physician, that's a lot.
Q. You thought that was too much?
A. I thought that was a lot to have on his plate. But that wasn't my business. I'm just saying that,
you know, I had already started to have some thoughts about what this guy was really capable of
doing. Something didn't -- that's, you know, if you're a successful cardiologist, then that's what
you do, you know.
Q. So you were you skeptical of Dr. Murray --
A. Kind of.
Q. And particularly his, what his --
A. Yeah. Yeah, I was. That just didn't -- I mean, it just seemed odd.
Q. The story didn't add up to you?
A. Not to say it didn't add up. There was nothing usual or customary about what he was doing at
all. -
Q. As far as you know, before Mr. Jackson passed, did Conrad Murray have any reputation
within the medical community in Las Vegas?
A. I'm not a cardiologist. I don't have a hospital practice. I have my surgery center, and I try to do
all my work right there. So I'm not out there. You know, I'm not the social butterfly at the
hospitals having lunch with the guys. I'm fairly private. I'm off to my own, you know, resources

and my own environment. I do know of other cardiologists by one way or another that I've heard
of, and Conrad Murray wasn't one of them. But I know several other cardiologists that do
practice here one way or another. But I had never heard of Conrad before he walked in the door
that day.
Q. Did you say to him how much time have you spent in Las Vegas versus Houston?
A. No.
Q. How do you know the other cardiologists?
A. Well, I either know them from social interaction, or I know them from some medical
interaction. Or actually I was referred to one guy because I wanted to have a cardiologist be my
personal physician, kind of thing.
Q. And do you have any idea, either directly or indirectly, what Murray's practice in Las Vegas
was like in 2007 and 2008?
A. Well, he would have me believe that he had a lucrative busy practice in both Texas and here. I
think it was Houston and Las Vegas. And that he did invasive cardiology. He did all kinds of
stuff. And that's why it seemed a little strange that he would be able to somehow create time to
be Michael's personal physician.
Q. So Murray in 2007 was telling you that he had this very successful --
A. Yes.
Q. -- cardio --
A. Yes.
Q. What did you call it, invasive?
A. Invasive cardiology practice.
Q. So Murray was telling you, I've got this really successful practice in Houston?
A. Right.
Q. I have this really successful practice in Las Vegas?
A. Right.
Q. You had never heard of him in Las Vegas?
A. Right.

Q. You have no reason to hear of him in Houston?
A. Right. I don't practice in Houston.
Q. But at the time, it seemed to you to not add up?
A. Well, yeah, it seemed -- you like to use not add up, and I like to use it seemed very odd.
Q. Okay, fair enough. It seemed odd to you that he was telling you that?
A. It seemed like something he was telling me perhaps was not entirely true.
Q. Okay. And you came to that conclusion in 2007?
A. Yes.
Q. Because after your communications with him in 2007, you were not impressed with him; is
that fair to say?
A. Well, it's fair to say that the whole situation seemed very odd and didn't add up.
Q. And you thought that --
A. And that makes me not fully trust a situation or a person.
Q. You thought Dr. Murray -- in 2007 you thought that Dr. Murray was misrepresenting
something about his practice?
A. Well, I felt that a successful cardiologist doesn't go around being somebody's private
physician and speaking for them, in my experience.
Q. Okay. And did you -- I think you may have -- forgive me if you've already answered this
earlier, but each of the times you saw Mr. Jackson in '02, '03 and '07, he was physically healthy?
A. Yes. Did you ever ask for any information from any of Michael Jackson's doctors before any
of your procedures?
THE WITNESS: No, I never asked for any information.
Q. Because for what you were doing, was there any need to?
A. Not really.

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