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1 CASE NUMBER: BC445597
2 CASE NAME: J ACKSON VS. A. E. G.
3 LOS ANGELES, CALI FORNI A SEPTEMBER 18, 2013
4 DEPARTMENT NO. 28 HON. YVETTE M. PALAZUELOS,
5 J UDGE
6 APPEARANCES: ( AS HERETOFORE NOTED. )
7 REPORTER: RHONDA NORBERG, CSR 9265
8 TI ME: 1: 42 P. M.
9
10 ( THE FOLLOWI NG PROCEEDI NGS WERE HELD
11 I N OPEN COURT, OUTSI DE THE PRESENCE
12 OF THE J URY: )
13
14 THE COURT: J ACKSON VERSUS A. E. G. LI VE, BC445597.
15 GOOD AFTERNOON, EVERYBODY.
16 OKAY. THE ONLY NEWTHI NG I HAVE FOR YOU I S
17 A NOTE FROM J UROR NUMBER 2. AND THE NOTE SAYS " TO
18 J UDGE. I AM J UROR NUMBER 2. I WOULD LI KE AN EXCUSE ON
19 SEPTEMBER 24TH A FEWHOURS I N THE MORNI NG. I HAVE AN
20 APPOI NTMENT AT 8: 00 A. M. FOR ONE HOUR. I WI LL FI NI SH
21 AND TRAVEL BACK TO COURT APPROXI MATELY 10: 00. THANK
22 YOU. "
23 I THI NK THAT' S FI NE.
24 MR. PUTNAM: FI NE. THAT' S WHEN WE WERE GOI NG TO
25 START ANYWAY, YOUR HONOR. I F WE' RE DELAYED BY 15
26 MI NUTES, THAT' S FI NE.
27 MR. PANI SH: THAT WI LL BE FI NE.
28 DOES THE COURT KNOWWHAT TI ME WE WOULD BE

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1 STARTI NG TOMORROW?
2 THE COURT: I HAVE TO CHECK MY CALENDAR.
3 MR. PANI SH: AND THEN ALSO, J UST TO UPDATE YOU,
4 MS. CAHAN AND I HAVE COMMUNI CATED OVER LUNCH, AND WE' RE
5 CLOSE ON A STI PULATI ON. SHE' S CHECKI NG ONE THI NG, AND
6 SHE' S GOI NG TO GET BACK TO ME BY THE BREAK TI ME.
7 MS. CAHAN: AND I ACTUALLY J UST GOT AN E- MAI L
8 ABOUT THAT. I T WAS REFERRED TO AS THE SANTA BARBARA
9 SHERI FF' S DEPARTMENT OFFI CE, SO WE' LL DI SCUSS I T.
10 WE' RE DI SCUSSI NG ONE PI ECE OF WORDI NG FOR
11 I T, SO WE WI LL CONTI NUE TO DO THAT.
12 MR. PANI SH: I T' S LI KE TWO WORDS THAT WE HAVE - -
13 THE COURT: THAT' S THE STI PULATI ON CONCERNI NG - -
14 MR. PANI SH: THE SHERI FF' S REPORTS.
15 THE COURT: - - THE MEDI CAL RECORDS.
16 MR. PUTNAM: THE SANTA BARBARA' S SHERI FF' S
17 REPORT, YOUR HONOR, THE ONE THAT HAD THE J USTI CE
18 DEPARTMENT AND ALL THAT. WE' RE TRYI NG TO COME UP WI TH
19 A STI P ABOUT WHAT I T I S.
20 THE COURT: BECAUSE THERE' S ANOTHER STI P
21 CONCERNI NG LI VENATI ON.
22 MS. BI NA: THAT, I J UST SI GNED. MR. GLASSMAN AND
23 I HAVE AGREED ON THAT.
24 THE COURT: THAT' S GOOD. I CAN CHECK THAT ONE
25 OFF MY LI ST.
26 MR. PANI SH: SO WE' RE MAKI NG GOOD PROGRESS.
27 THE COURT: YES, YOU ARE.
28 MR. PANI SH: SO WE STI LL HOPE TO BE ON SCHEDULE

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1 LI KE WE DI SCUSSED THI S MORNI NG, AND I THI NK NOW
2 DEFENDANT WAS GOI NG TO CONTI NUE WI TH THE PLAYI NG OF
3 DR. METZGER' S VI DEO.
4 MR. BOYLE: AND I THI NK, YOUR HONOR, MR. GLASSMAN
5 DI D A BRI EF ON THAT NEWI NSTRUCTI ON THAT SHOULD BE
6 BEI NG FI LED AND SERVED RI GHT NOW.
7 THE COURT: OKAY. VERY GOOD.
8 AND THEN, ALSO, MY STAFF I S ATTEMPTI NG TO
9 GET FROM THE J URY WHAT THEI R OCTOBER CALENDAR LOOKS
10 LI KE. I HAVE THI NK YOU SUGGESTED WE DO THAT. THEY
11 WANT TO GO HOME AND CHECK THEI R PERSONAL CALENDAR, TOO;
12 SO THEY' RE GOI NG TO LET US KNOWTOMORROWWHAT THEI R
13 CALENDARS WI LL LOOK LI KE FOR OCTOBER. SO WE' RE WORKI NG
14 ON THAT. AND - -
15 MR. BOYLE: YOUR HONOR, DO THEY KNOWTHAT THEY' LL
16 BE DELI BERATI NG - - COULD BE DELI BERATI NG I N OCTOBER AS
17 OPPOSED TO STI LL HEARI NG EVI DENCE?
18 THE COURT: I THI NK THEY KNOWTHAT. I THI NK THEY
19 DO KNOWTHAT. AT LEAST I HOPE SO. I THI NK THEY DO.
20 MR. PANI SH: WELL, YOU' LL BE ABLE TO TELL THEM BY
21 TOMORROWANYWAY.
22 THE COURT: YES, I ' LL TELL THEM.
23 MR. PANI SH: YOU' LL GI VE THEM A SCHEDULE.
24 THE COURT: LET ME SEE ABOUT TOMORROW, WHERE WE
25 ARE I N TERMS OF MY CALENDAR.
26 YOU KNOWWHAT? WHY DON' T WE PLAN ON 10: 00
27 TOMORROW.
28 MR. PANI SH: OKAY. GOOD.

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1 MR. PUTNAM: TOTALLY FI NE.
2 THE COURT: OKAY. SO YOU HAVE YOUR VI DEO READY
3 TO ROLL?
4 MR. PUTNAM: WE DO.
5 THE COURT: ABOUT AN HOUR - -
6 MS. CAHAN: ABOUT AN HOUR AND 15 MI NUTES.
7 THE COURT: AND I T' S METZGER, RI GHT?
8 MS. CAHAN: YES.
9 THE COURT: OKAY. LET' S CALL THE J URY I N.
10
11 ( THE FOLLOWI NG PROCEEDI NGS WERE HELD
12 I N OPEN COURT, I N THE PRESENCE OF THE
13 J URORS: )
14
15 THE COURT: KATHERI NE J ACKSON VERSUS A. E. G. LI VE,
16 BC445597. GOOD AFTERNOON, EVERYBODY. WELCOME BACK.
17 COUNSEL, MAKE YOUR APPEARANCES.
18 MR. PANI SH: YES. WELCOME BACKS AND GOOD
19 AFTERNOON. BRI AN PANI SH FOR THE PLAI NTI FFS.
20 MR. BOYLE: GOOD AFTERNOON. KEVI N BOYLE FOR THE
21 PLAI NTI FFS.
22 MS. CAHAN: KATHRYN CAHAN FOR DEFENDANTS. GOOD
23 AFTERNOON.
24 MS. BI NA: GOOD AFTERNOON. J ESSI CA STEBBI NS BI NA
25 FOR THE DEFENDANTS.
26 MR. PUTNAM: AND MARVI N PUTNAM FOR THE
27 DEFENDANTS. GOOD AFTERNOON.
28 THE COURT: REALLY GOOD NEWS. WE ARE I N THE

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1 NI NTH I NNI NG. WE - - THE EVI DENCE WI LL CLOSE PROBABLY
2 WEDNESDAY MORNI NG?
3 MR. PANI SH: THURSDAY, YOU MEAN.
4 THE COURT: TOMORROWMORNI NG.
5 MR. BOYLE: EI THER TOMORROWOR, AT THE LATEST,
6 FRI DAY MORNI NG.
7 THE COURT: OKAY. AT THE LATEST, FRI DAY MORNI NG.
8 THAT' S PRETTY SOON. OKAY? THAT' S NOT I NCLUDI NG THE
9 CLOSI NG ARGUMENTS, BUT THE CLOSE OF EVI DENCE. THAT
10 MEANS NO MORE EVI DENCE. I T WI LL J UST BE ARGUMENT AFTER
11 THAT. AND THEN, OF COURSE, DELI BERATI ON. BUT I J UST
12 WANTED TO LET YOU KNOWTHE EVI DENCE WI LL CLOSE SOON.
13 THE OTHER THI NG - - WELL, J UROR NUMBER 1,
14 THANK YOU FOR COMI NG BACK; AND WE' RE GLAD TO HAVE YOU
15 BACK.
16 J UROR NUMBER 1: THANK YOU.
17 THE COURT: AND THEN J UROR NUMBER 2, WE READ YOUR
18 NOTE. 10: 00 O' CLOCK I S FI NE, WE CAN START AT
19 10: 00 O' CLOCK ON THE 24TH.
20 AND MY STAFF, I THI NK, HAS GI VEN YOU AN
21 OCTOBER CALENDAR. YOU' RE ALL GOI NG TO GO BACK AND
22 CHECK, I KNOWSOME OF YOU HAVE I SSUES FOR OCTOBER.
23 YOU' LL PROBABLY BE I N DELI BERATI ONS AT THAT TI ME, SO
24 YOU NEED TO CHECK YOUR OCTOBER CALENDAR. OKAY? I S
25 THAT RI GHT? ARE YOU AWARE THAT YOU' RE GOI NG TO HAVE TO
26 DO THAT?
27 OKAY. VERY GOOD. AND WE LEFT OFF WI TH
28 DR. METZGER I N THE MI DDLE OF PLAYI NG HI S VI DEO

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1 DEPOSI TI ON, SO DEFENDANTS WANT TO FI NI SH WI TH THAT.
2 MR. PUTNAM: PLEASE.
3 MS. CAHAN: THANK YOU, YOUR HONOR.
4 THE COURT: YOU MAY.
5
6 ( EXCERPTS OF THE VI DEOTAPED
7 DEPOSI TI ON OF ALLAN METZGER WERE
8 PLAYED. )
9
10 MS. CAHAN: THAT CONCLUDES THE VI DEO DEPOSI TI ON
11 OF DR. METZGER. THE EXHI BI T - - TRI AL EXHI BI T THAT WAS
12 SHOWN WAS EXHI BI T 9823, WHI CH HAS ALREADY BEEN MOVED
13 I NTO EVI DENCE BY AGREEMENT OF THE PARTI ES. AND THERE
14 WERE NO CORRECTI ONS TO THE TESTI MONY THAT' S BEEN SHOWN.
15 THE COURT: THANK YOU.
16 WHY DON' T WE TAKE A BREAK AND THEN
17 CONTI NUE. COME BACK AT 3: 30. OKAY? SEE YOU AT 3: 30.
18
19 ( THE FOLLOWI NG PROCEEDI NGS WERE HELD
20 I N OPEN COURT, OUTSI DE THE PRESENCE
21 OF THE J URORS: )
22
23 THE COURT: OKAY. FROM METZGER, WHO DO WE HAVE?
24 MR. PUTNAM: I ' M RESTI NG.
25 MS. BI NA: YOUR HONOR, BEFORE WE START THE
26 PLAI NTI FFS' CASE, I WANT TO PUT ON THE RECORD BRI EFLY
27 SOMETHI NG THAT I SAI D I N OUR CALL YESTERDAY REGARDI NG
28 OUR CONCERN ABOUT THE SCOPE OF THE TYPE OF TESTI MONY,

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1 AND I THI NK I T WI LL BE VERY QUI CK.
2 MR. PANI SH: WHY DON' T YOU DO I T NOW.
3 MS. BI NA: OUR UNDERSTANDI NG I S THAT THE
4 PRI NCI PAL PURPOSE FOR BEI NG BROUGHT BACK AS A REBUTTAL
5 WI TNESS I S TO ADDRESS TESTI MONY OF KATHY J ORRI E.
6 OBVI OUSLY, WE DON' T KNOWWHAT HE' S GOI NG TO
7 SAY ABOUT THAT; BUT OUR CONCERN YESTERDAY WAS I F HE
8 GOES BEYOND THAT I NTO TERRI TORY COVERED BY DETECTI VE
9 MARTI NEZ, PARTI CULARLY REGARDI NG FI NANCI AL MOTI VE,
10 REGARDI NG THE MURRAY I NVESTI GATI ON, I T REALLY WOULD BE
11 CUMULATI VE, I DON' T BELI EVE I T' S PROPER REBUTTAL.
12 I ' LL OBJ ECT AT THE TI ME, BUT DON' T WANT TO
13 HAVE A SPEAKI NG OBJ ECTI ON I N FRONT OF THE J URY, SO
14 PROBABLY SOMETHI NG LI KE, " OBJ ECTI ON, I MPROPER
15 REBUTTAL. " AND I WANTED TO LAY THAT OUT NOWI N ADVANCE
16 SO YOU WOULD HAVE SOME I DEA OF WHY I DI D THAT.
17 MR. PANI SH: I ' VE GOT TO LAY SOME FOUNDATI ON OF
18 WHAT HE DI D, BUT I UNDERSTAND WHAT REBUTTAL I S AND WHAT
19 I ' M ALLOWED TO DO.
20 THE COURT: OKAY.
21 MR. PANI SH: AND THAT WI LL BE I T FOR TODAY. I
22 THI NK THAT WAS YOUR QUESTI ON.
23 MR. PUTNAM: WHEN WE COME BACK, I ' LL REST - -
24 MR. PANI SH: I F - - HE' S HEAR, WE' LL GET HI M ON - -
25 THE COURT: HOLD ON, MR. PANI SH. I CAN' T HEAR
26 MR. PUTNAM.
27 MR. PANI SH: OH, I ' M SORRY.
28 MR. PUTNAM: WHAT I WAS GOI NG TO DO, YOUR HONOR,

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1 I S I WI LL REST SUBJ ECT TO A COUPLE OF EVI DENTI ARY
2 I SSUES, STATI NG THAT THE COURT I S AWARE OF WHAT WE
3 ALREADY DI SCUSSED, AND MOVE ON TO - -
4 THE COURT: FOR REBUTTAL, YOU HAVE SMI TH - -
5 MR. PANI SH: SMI TH, FOR TODAY.
6 HE' S GOI NG TO REST SUBJ ECT TO EXHI BI TS. I S
7 THAT THE I SSUE?
8 THE COURT: YES.
9 MR. PANI SH: FAI R ENOUGH. RI GHT. SUBJ ECT TO
10 EXHI BI TS - - I GUESS HE - - HE SAI D I T BETTER. WHAT DI D
11 YOU SAY?
12 MR. PUTNAM: I SAI D THERE ARE CERTAI N EVI DENTI ARY
13 I SSUES THAT ARE OUT UNDERSTANDI NG.
14 MR. PANI SH: ONCE YOU SAY " SUBJ ECT TO, " WE ALL
15 KNOWWHAT YOU MEAN. WE KNOWTHERE' S THE STI PULATI ON
16 I SSUES, THE EXHI BI T I SSUES. ANY OTHER I SSUES
17 UNDERSTANDI NG? I ' M J UST TRYI NG TO MAKE SURE.
18 OKAY. SO WE ALL KNOWWE' RE ON THE SAME
19 PAGE. FAI R ENOUGH.
20
21 ( 19- MI NUTE RECESS TAKEN. )
22
23 THE COURT: KATHERI NE J ACKSON VERSUS A. E. G. LI VE,
24 BC445597.
25 PLAI NTI FF - - I MEAN DEFENSE?
26 MR. PUTNAM: YES, YOUR HONOR.
27 YOUR HONOR, SUBJ ECT TO THE RESOLUTI ON OF
28 CERTAI N OUTSTANDI NG EVI DENTI ARY I SSUES, A. E. G. LI VE

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1 HEREBY RESTS I TS CASE AND I TS DEFENSE OF THI S MATTER.
2 THE COURT: THANK YOU.
3 PLAI NTI FF, DO YOU HAVE REBUTTAL?
4 MR. PANI SH: YES, YOUR HONOR. WE CALL DETECTI VE
5 SCOTT SMI TH AT THI S TI ME.
6 THE COURT: THANK YOU.
7 DETECTI VE SMI TH?
8
9 SCOTT SMI TH,
10 CALLED BY THE PLAI NTI FFS AS A WI TNESS, WAS SWORN AND
11 TESTI FI ED AS FOLLOWS:
12
13 THE CLERK: SI R, PLEASE RAI SE YOUR RI GHT HAND AND
14 BE SWORN.
15 DO YOU SOLEMNLY STATE THAT THE TESTI MONY
16 YOU MAY GI VE I N THE CAUSE NOWPENDI NG BEFORE THI S COURT
17 SHALL BE THE TRUTH, THE WHOLE TRUTH, AND NOTHI NG BUT
18 THE TRUTH, SO HELP YOU GOD?
19 THE WI TNESS: YES.
20 THE CLERK: PLEASE TAKE THE STAND, SI R.
21 SI R, PLEASE STATE AND SPELL YOUR NAME FOR
22 THE RECORD.
23 THE WI TNESS: SCOTT SMI TH; S- C- O- T- T, S- M- I - T- H.
24 THE CLERK: THANK YOU.
25 THE COURT: THANK YOU.
26 YOU MAY BEGI N.
27 MR. PANI SH: YOUR HONOR, J UST ONE THI NG FOR THE
28 RECORD. THERE I S A MOTI ON THAT I I NTEND TO BRI NG. I ' M

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1 NOT WAI VI NG I T, I ' LL J UST BRI NG I T UP AFTER THE
2 DETECTI VE I S FI NI SHED.
3 THE COURT: YES. OKAY.
4 MR. PANI SH: THANK YOU.
5
6 DI RECT EXAMI NATI ON
7 BY MR. PANI SH:
8 Q AND GOOD AFTERNOON, SI R.
9 A GOOD AFTERNOON.
10 Q AND ARE YOU HERE PURSUANT TO SUBPOENA AS AN
11 I NDEPENDENT WI TNESS?
12 A YES, I AM.
13 Q AND BY WHOM ARE YOU EMPLOYED, SI R?
14 A LOS ANGELES POLI CE DEPARTMENT.
15 Q AND COULD YOU TELL US A LI TTLE BI T ABOUT
16 YOUR BACKGROUND?
17 A I J OI NED THE DEPARTMENT BACK I N MARCH OF
18 1987, HAD VARI OUS ASSI GNMENTS, PRI MARI LY I N HOMI CI DE.
19 CURRENTLY ASSI GNED TO ROBBERY HOMI CI DE DI VI SI ON,
20 ROBBERY SPECI AL SECTI ON.
21 Q DI D YOU HAVE ACADEMY TRAI NI NG?
22 A YES.
23 Q AND AS PART OF YOUR ACADEMY TRAI NI NG, DOES
24 THAT I NCLUDE I NVESTI GATI ON OF CRI ME SCENES - - POTENTI AL
25 CRI ME SCENES?
26 A YES.
27 Q I NTERVI EWI NG OF WI TNESSES?
28 A YES.

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1 Q OKAY. NOW, YOU SAI D YOU' RE I N THE ROBBERY
2 HOMI CI DE DI VI SI ON.
3 HOWLONG HAVE YOU BEEN I N THAT DI VI SI ON?
4 A APPROXI MATELY THREE YEARS.
5 Q AND WHAT DO YOU DO I N THAT DI VI SI ON?
6 A BEI NG ASSI GNED TO ROBBERY SPECI ALS,
7 I NVESTI GATE BANK ROBBERI ES, HI GH- PROFI LE CASES
8 I NVOLVI NG ROBBERI ES, KI DNAPS, EXTORTI ONS.
9 Q DO YOU KNOWDETECTI VE ORLANDO MARTI NEZ?
10 A YES, I DO.
11 Q DOES HE WORK I N THAT DI VI SI ON WI TH YOU?
12 A HE DOES WORK THAT DI VI SI ON, HE' S WORKI NG
13 HOMI CI DE, YES, SI R.
14 Q AND ABOUT HOWMANY HOMI CI DE I NVESTI GATI ONS
15 WOULD YOU SAY THAT YOU' VE WORKED ON I N YOUR CAREER?
16 A I N MY CAREER?
17 PROBABLY EXCEEDI NG A COUPLE HUNDRED.
18 Q NOW, J ANUARY - - ON J UNE 25, 2009, WERE YOU
19 WORKI NG THAT DAY I N THE ROBBERY HOMI CI DE DI VI SI ON?
20 A YES, I WAS.
21 Q AT SOME POI NT I N TI ME DI D YOU LEARN OF A
22 POTENTI AL PURPORTED DEATH OF MI CHAEL J ACKSON?
23 A YES.
24 Q HOWDI D YOU BECOME AWARE OF THAT?
25 A MY SUPERVI SOR, GREG STRENGTH, NOTI FI ED ME
26 AND I NFORMED ME THAT SOMETHI NG HAD HAPPENED TO
27 MR. J ACKSON AND TO RESPOND TO U. C. L. A. MEDI CAL CENTER.
28 Q OKAY. ABOUT WHAT TI ME WERE YOU NOTI FI ED,

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1 APPROXI MATELY?
2 A APPROXI MATELY 3: 00 P. M.
3 Q AND WERE YOU GI VEN THE ASSI GNMENT TO BE
4 I NVOLVED I N THE I NVESTI GATI ON OF THE DEATH OF
5 MI CHAEL J ACKSON?
6 A YES.
7 Q OKAY. WHAT WAS THE FI RST THI NG THAT YOU
8 DI D?
9 A THE FI RST THI NG THAT I DI D I S GO TO
10 U. C. L. A. MEDI CAL CENTER, ALONG WI TH DETECTI VE MARTI NEZ.
11 Q AND - - I ' M SORRY. DI D I CUT YOU OFF?
12 A NO. GO AHEAD, SI R.
13 Q AND ABOUT HOWLONG DI D I T TAKE YOU - -
14 YOU' RE I N DOWNTOWN; I S THAT RI GHT?
15 A I WAS AT THE ACADEMY, YES, SI R.
16 Q SO ELYSI AN PARK BY DODGER STADI UM?
17 A YES, SI R.
18 Q AND ABOUT HOWLONG DI D I T TAKE YOU TO GO
19 FROM ELYSI AN PARK, THE POLI CE ACADEMY, TO THE U. C. L. A.
20 MEDI CAL CENTER?
21 MS. BI NA: OBJ ECTI ON; RELEVANCE, I MPROPER
22 REBUTTAL, CUMULATI VE.
23 THE COURT: OVERRULED.
24 THE WI TNESS: APPROXI MATELY AN HOUR, GI VE OR
25 TAKE.
26 Q BY MR. PANI SH: AND HOWLONG DI D YOU STAY
27 AT U. C. L. A. ?
28 A I BELI EVE, WI THOUT LOOKI NG AT ANY OF MY

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1 NOTES, APPROXI MATELY A COUPLE OF HOURS.
2 Q OKAY. I NOTE THAT I BROUGHT TWO - - WHAT DO
3 YOU CALL THOSE THI NGS WI TH YOU?
4 A BI NDERS, BOOKS.
5 Q OKAY. I ' M NOT GOI NG TO GET I NTO ALL OF
6 THAT, BUT I S THAT THE WORK PRODUCT OF THE WORK THAT YOU
7 DI D I N THI S I NVESTI GATI ON?
8 A THAT' S A MI NUTE PART OF I T, YES, SI R.
9 Q OKAY. AND AS PART OF YOUR I NVESTI GATI ON,
10 AT U. C. L. A. , DI D YOU DO ANYTHI NG THERE?
11 A YES, SI R.
12 Q J UST GENERALLY, WHAT DI D YOU DO?
13 A MET WI TH MR. J ACKSON' S SECURI TY TEAM, MET
14 WI TH WEST L. A. DETECTI VES THAT HAD RESPONDED.
15 Q OKAY. WHEN YOU SAY " WEST, " I S THE
16 LOS ANGELES POLI CE DEPARTMENT DI VI DED UP I NTO VARI OUS
17 DI VI SI ONS, AND THE DI VI SI ON THAT WOULD BE RESPONSI BLE
18 FOR THE AREA WHERE MR. J ACKSON WAS LI VI NG - - WOULD THAT
19 BE CALLED THE WEST DI VI SI ON?
20 A WEST LOS ANGELES, YES, SI R.
21 Q SO AFTER YOU WERE AT U. C. L. A. AND YOU DI D
22 SOME WORK, DI D YOU GO SOMEWHERE AFTER THAT?
23 A YES.
24 Q WHERE DI D YOU GO?
25 A DI D A FOLLOWUP TO MR. J ACKSON' S RESI DENCE,
26 100 NORTH CAROLWOOD.
27 Q OKAY. AND HOWLONG DI D YOU STAY THERE,
28 APPROXI MATELY?

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1 A APPROXI MATELY SI X TO EI GHT HOURS.
2 Q EVENTUALLY WERE YOU ABLE TO CONFI RM THAT
3 MR. J ACKSON HAD PASSED AWAY?
4 A YES.
5 Q NOW, AT THAT POI NT I N TI ME, WHEN YOU WENT
6 TO CAROLWOOD, WAS THI S A HOMI CI DE OR A DEATH
7 I NVESTI GATI ON?
8 A I T WAS A DEATH I NVESTI GATI ON.
9 Q WHAT' S THE DI FFERENCE?
10 MS. BI NA: OBJ ECTI ON; CUMULATI VE.
11 MR. PANI SH: I T' S FOUNDATI ON.
12 THE COURT: OVERRULED.
13 THE WI TNESS: A DEATH I NVESTI GATI ON I S THE
14 I NVESTI GATI ON OF SOMEONE WHO I S DECEASED, THERE' S NO
15 OBVI OUS SI GNS OF TRAUMA, NO GUNSHOT WOUNDS, NO STAB
16 WOUNDS, NO OBVI OUS REASON WHY THI S PERSON WOULD BE
17 DECEASED.
18 A HOMI CI DE WOULD BE J UST THE OPPOSI TE;
19 MULTI PLE GUNSHOT WOUNDS, STAB WOUNDS, OBVI OUS SI GNS OF
20 TRAUMA.
21 Q BY MR. PANI SH: WHEN YOU FI RST WENT TO
22 CAROLWOOD AFTER U. C. L. A. , WAS I T A DEATH OR A HOMI CI DE
23 I NVESTI GATI ON?
24 A DEATH.
25 Q AT SOME POI NT I N TI ME, DI D THAT CHANGE?
26 A YES, I T DI D.
27 Q WHY DI D I T CHANGE, I F YOU KNOW?
28 A THE DOCTOR AT THE LOS ANGELES COUNTY

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1 CORONER' S OFFI CE, DR. LAKSHMANAN, RULED I T A HOMI CI DE
2 APPROXI MATELY TWO MONTHS LATER.
3 Q AFTER THAT OCCURRED, DI D YOU AND DETECTI VE
4 MARTI NEZ BEGI N I SSUI NG SUBPOENAS AND DOI NG
5 I NVESTI GATI VE WORK?
6 A YES, WE DI D.
7 Q AT SOME POI NT I N TI ME, YOU WERE SERVI NG
8 SUBPOENAS.
9 WHAT WAS THE PURPOSE OF THAT?
10 A WE WERE SERVI NG SUBPOENAS TO PRI MARI LY FI ND
11 OUT MOTI VE. WE HAD J OI NED WI TH THE DI STRI CT ATTORNEY' S
12 OFFI CE AT THAT TI ME I N OUR I NVESTI GATI ON, AND THEY HAD
13 WHAT YOU WOULD CALL A LAUNDRY LI ST OF WHAT THEY WANTED
14 DONE ALONG WI TH THI NGS THAT WE NEEDED TO FOLLOWUP ON.
15 Q OKAY. AND WERE YOU CHECKI NG I NTO, FOR
16 EXAMPLE, DR. MURRAY' S FI NANCI AL BACKGROUND AND SUCH?
17 A YES.
18 Q OKAY. AND DI D OTHER DETECTI VES OTHER THAN
19 YOURSELF AND DETECTI VE MARTI NEZ BEGI N TO ASSI ST I N THE
20 I NVESTI GATI ON?
21 A YES.
22 Q AND AS A RESULT OF DOI NG YOUR
23 I NVESTI GATI ON, DI D YOU COME ACROSS ANY I NFORMATI ON THAT
24 LED YOU TO WANT TO I NVESTI GATE ANY POTENTI AL
25 RELATI ONSHI P BETWEEN A. E. G. LI VE AND A. E. G. AND
26 DR. MURRAY?
27 MS. BI NA: I ' M GOI NG TO OBJ ECT, YOUR HONOR,
28 AGAI N; CUMULATI VE, I MPROPER REBUTTAL.

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1 THE COURT: OVERRULED.
2 THE WI TNESS: YES.
3 Q BY MR. PANI SH: WHAT WAS THAT?
4 A I N DR. MURRAY' S CAR, WE FOUND A CONTRACT
5 BETWEEN HI M AND A. E. G. I T ALSO LI STED THE NAME OF
6 MI CHAEL J ACKSON.
7 Q OKAY. AS A RESULT OF THAT, DI D YOU
8 UNDERTAKE TO I NTERVI EWI NDI VI DUALS ASSOCI ATED WI TH
9 A. E. G. ?
10 A YES.
11 Q AND WHY DI D YOU WANT TO DO THAT?
12 A TO CONFI RM THE VALI DI TY OF THE CONTRACT AND
13 ANY OTHER ADDI TI ONAL DETAI LS THAT MAY NOT HAVE BEEN I N
14 THE CONTRACT THAT WE CAN FI ND OUT.
15 Q DI D THERE COME A POI NT I N TI ME WHERE YOU
16 I NTERVI EWED AN I NDI VI DUAL ASSOCI ATED WI TH A. E. G. , A
17 LAWYER BY THE NAME OF KATHY J ORRI E?
18 A YES.
19 Q AND WHY DI D YOU SPECI FI CALLY CHOOSE TO
20 I NTERVI EWMS. J ORRI E?
21 A FROM WHAT I CAN RECALL, I N PART, WE HAD
22 CONTACT WI TH DR. MURRAY I N REGARDS TO THE CONTRACT AND
23 SOME REVI SI ONS, AND SHE MAY HAVE BEEN ALSO PARTI ALLY
24 RESPONSI BLE FOR DRAFTI NG THAT CONTRACT.
25 Q DI D YOU WANT TO GET ANY UNDERSTANDI NG OF
26 ANY OF THE PROVI SI ONS OF THE CONTRACT BY MEETI NG WI TH
27 MS. J ORRI E?
28 A YES.

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1 Q AND WHEN YOU - - I ASSUME - - WAS I T A SEARCH
2 WARRANT OR SUBPOENA THAT ENTI TLES YOU TO ENTER
3 DR. MURRAY' S CAR?
4 A SEARCH WARRANT.
5 Q AND A SEARCH WARRANT, YOU GO TO THE COURT
6 AND THEY GI VE YOU PERMI SSI ON TO, I N A BASI C SENSE,
7 ENTER SOMEONE' S PROPERTY, RESI DENCE OR SUCH?
8 A YES, SI R.
9 Q AND YOU FOUND THE CONTRACT THERE?
10 A YES, SI R.
11 Q NOW, WHEN YOU FOUND THE CONTRACT, WHY WAS
12 I T I MPORTANT TO YOUR I NVESTI GATI ON TO I NVESTI GATE ANY
13 RELATI ONSHI P BETWEEN A. E. G. AND DR. MURRAY?
14 A I T WAS GOI NG TO MOTI VE.
15 Q WHAT DO YOU MEAN WHEN YOU SAY THAT?
16 A LOOKI NG I NTO DR. MURRAY, WHO WAS MORE THAN
17 A PERSON OF I NTEREST, LET' S SAY, HE WAS A SUSPECT I N
18 THI S CASE, WE WANTED TO BE THOROUGH I N OUR BACKGROUND
19 OF DR. MURRAY. THAT WOULD I NCLUDE HI S FI NANCI AL
20 STATUS.
21 Q OKAY. AND DI D YOU DO THAT?
22 A YES.
23 Q DI D YOU - - DI D YOU GET I NFORMATI ON THAT LED
24 YOU TO CONTI NUE ON WI TH THAT I NVESTI GATI ON?
25 A YES.
26 Q WHAT WAS THAT?
27 MS. BI NA: OBJ ECTI ON. AGAI N, YOUR HONOR, THI S I S
28 CUMULATI VE OF DETECTI VE MARTI NEZ.

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1 MR. PUTNAM: EXACTLY - -
2 THE COURT: OVERRULED.
3 Q BY MR. PANI SH: YOU CAN TELL US.
4 A I NFORMATI ON THAT WAS OBTAI NED REVEALED THAT
5 DR. MURRAY FI NANCI ALLY WAS I N RUI NS, WAS LOSI NG HI S
6 HOUSE I N LAS VEGAS, HAD A LI EN AGAI NST HI S POOL THAT
7 WAS PUT I N HI S HOUSE I N LAS VEGAS, WAS I N ARREARS OF
8 CHI LD SUPPORT, MULTI PLE CHI LDREN BY MULTI PLE WOMEN.
9 FI NANCI ALLY HE WAS J UST A MESS.
10 MS. BI NA: AND I WOULD OBJ ECT AND MOVE TO STRI KE
11 THE PART ABOUT MULTI PLE CHI LDREN BY MULTI PLE WOMEN.
12 THE COURT: MOTI ON DENI ED.
13 Q BY MR. PANI SH: AND AS A RESULT OF THAT,
14 WERE THERE TERMS OF THE CONTRACT WHEN YOU REVI EWED I T
15 THAT LED YOU TO WANT TO I NTERVI EWPEOPLE FROM A. E. G.
16 RELATED TO THE CONTRACT?
17 A YES.
18 Q OKAY. WHAT WAS I T THAT CAUSED YOU TO WANT
19 TO I NTERVI EWTHE LAWYER, MS. J ORRI E?
20 A I T WOULD BE A. E. G. AT THAT TI ME, I DON' T
21 BELI EVE I T WAS MS. J ORRI E SPECI FI CALLY. BUT THE AMOUNT
22 THAT DR. MURRAY WAS TO BE COMPENSATED MONTHLY.
23 Q WHAT WAS YOUR UNDERSTANDI NG, BASED ON
24 THE - - THE EXHI BI T THAT YOU SEI ZED?
25 A THAT DR. MURRAY WAS TO RECEI VE $150, 000 A
26 MONTH PLUS EXPENSES.
27 Q AND AS A - - AS A HOMI CI DE - - HOMI CI DE
28 DETECTI VE, I S ONE OF THE THI NGS THAT YOU' RE TRAI NED TO

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1 DO WHEN CONDUCTI NG AN I NVESTI GATI ON TO LOOK TO MOTI VE
2 AND CHANNEL YOUR I NVESTI GATI ON AND I NTERVI EWI NG
3 WI TNESSES TO DETERMI NE WHETHER THERE' S ANY POTENTI AL
4 MOTI VE FOR WHAT HAD OCCURRED?
5 A YES.
6 Q AND I N THI S CASE, DI D YOU COME TO SUCH A
7 DETERMI NATI ON THAT LED YOU TO I NTERVI EWA. E. G.
8 PERSONNEL?
9 MS. BI NA: SAME OBJ ECTI ON, YOUR HONOR. ALSO
10 ASKED AND ANSWERED ABOUT FOUR TI MES ALREADY TODAY.
11 THE COURT: YES, I T' S BEEN ASKED AND ANSWERED.
12 MR. PANI SH: OKAY.
13 Q WAS THERE - - AS YOU SAWTHE CONTRACT, DI D
14 YOU HAVE ANY CONCERN ABOUT DR. MURRAY' S ACTI ONS THAT
15 LED YOU TO WANT TO I NTERVI EWSOMEONE FROM A. E. G. ?
16 MS. BI NA: OBJ ECTI ON; ASKED AND ANSWERED.
17 THE COURT: SUSTAI NED.
18 Q BY MR. PANI SH: DO YOU KNOWWHAT A
19 HI PPOCRATI C OATH I S?
20 A I KNOWOF I T, YES, SI R.
21 Q WAS THAT PART OF YOUR I NVESTI GATI ON?
22 A YES, SI R.
23 Q HOW?
24 A THAT HE WAS NOT TO - - AS A DOCTOR, A
25 PHYSI CI AN, I S NOT TO HARM ANYONE I N ANY WAY.
26 Q DI D YOU HAVE SOME CONCERNS ABOUT THAT?
27 A GRAVE CONCERNS, YES.
28 Q OKAY. AND SO DI D YOU I NTERVI EWMS. J ORRI E

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1 TO GET A BETTER UNDERSTANDI NG OF THE TERMS OF THE
2 A. E. G. / MURRAY CONTRACT?
3 MS. BI NA: OBJ ECTI ON; ASKED AND ANSWERED.
4 THE COURT: OVERRULED.
5 THE WI TNESS: YES.
6 Q BY MR. PANI SH: AND DURI NG YOUR I NTERVI EW
7 OF MS. J ORRI E, DI D YOU TAKE NOTES?
8 A YES, I DI D.
9 Q AND DI D YOU TYPE UP THOSE NOTES I N A FORM
10 THAT' S USED BY THE LOS ANGELES POLI CE DEPARTMENT?
11 A YES.
12 THEY WERE BOTH WRI TTEN AND TYPED, AS WELL.
13 Q AND DI D YOU MAI NTAI N THESE DOCUMENTS I N THE
14 REGULAR COURSE OF BUSI NESS FOR THE L. A. P. D. ?
15 A YES.
16 Q OKAY. DO YOU HAVE DOCUMENTS THAT WOULD
17 I NDI CATE WHEN - - OR DO YOU KNOWWHEN THE I NTERVI EWTOOK
18 PLACE?
19 A I ' D HAVE TO LOOK AT THE ACTUAL DOCUMENTS.
20 Q OKAY. I F YOU DON' T MI ND.
21 A SURE.
22 Q WOULD THAT REFRESH YOUR RECOLLECTI ON?
23 A YES, I T WI LL.
24 Q OKAY. I F YOU COULD TELL US WHEN YOU DO
25 WHAT YOU' RE LOOKI NG AT.
26 A THI S I S - - I ' D BE REFERRI NG TO ONE BOOK OF
27 WI TNESSES THAT CAME ABOUT AS A RESULT OF OUR
28 I NVESTI GATI ON OF MI CHAEL J ACKSON, AND SPECI FI CALLY I ' M

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1 LOOKI NG AT THE I NVESTI GATI VE ACTI ON STATEMENT FORM THAT
2 I TYPED, UPDATED FEBRUARY 22ND, 2011, REGARDI NG
3 KATHY J ORRI E.
4 Q OKAY. WOULD YOU RECOGNI ZE MS. J ORRI E I F
5 YOU SAWHER?
6 A YES.
7 MR. PANI SH: I WANT TO SHOWYOU 787.
8 MR. BOYLE: 878, DASH, 20.
9 MR. PANI SH: YOU' D THI NK I ' D BE BETTER BY NOW.
10 878, DASH, 20.
11 Q DO YOU RECOGNI ZE MS. J ORRI E?
12 A YES, I DO.
13 Q I S THAT WHO YOU I NTERVI EWED?
14 A YES.
15 Q WHERE DI D THE I NTERVI EWTAKE PLACE, AND
16 WHAT TI ME?
17 A THE I NTERVI EWTOOK PLACE I N HER OFFI CE; AND
18 THI S WAS, AGAI N, ON FEBRUARY 22ND AT APPROXI MATELY
19 6: 00 P. M. I N THE EVENI NG.
20 Q WAS ANYONE THERE WI TH MS. J ORRI E WHEN THE
21 I NTERVI EWTOOK PLACE?
22 A I BELI EVE MARVI N PUTNAM WAS, YES.
23 Q WOULD YOU RECOGNI ZE MR. PUTNAM I F YOU SAW
24 HI M?
25 A YES.
26 Q DO YOU SEE HI M ANYWHERE I N THE COURTROOM
27 TODAY?
28 A I DO.

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1 Q WHERE I S HE? COULD YOU POI NT HI M OUT?
2 A HE' S SEATED RI GHT HERE WAVI NG AT ME AT THE
3 END OF THE TABLE.
4 Q THE GENTLEMAN WI TH THE BLUE TI E AND THE
5 NI CE TAN?
6 A GLASSES, YES.
7 THE COURT: I DENTI FYI NG MR. PUTNAM.
8 MR. PANI SH: I DENTI FYI NG DEFENSE COUNSEL.
9 Q NOW, SI R, DURI NG YOUR I NTERVI EW, DI D YOU - -
10 DI D YOU SPEAK TO BOTH - - DO YOU KNOWWHAT MR. PUTNAM
11 WAS DOI NG THERE, WHY HE WAS THERE?
12 MS. BI NA: OBJ ECTI ON; CALLS FOR SPECULATI ON,
13 HEARSAY.
14 THE COURT: OVERRULED ON HEARSAY.
15 THE WI TNESS: I BELI EVE THAT HE WAS THERE,
16 OBVI OUSLY, I N THE I NTEREST OF A. E. G. , AND TO SEE WHAT
17 WE HAD TO SAY.
18 MR. PANI SH: OKAY.
19 Q DURI NG THE I NTERVI EW, WAS MR. PUTNAM
20 PRESENT THE ENTI RE TI ME?
21 A I BELI EVE SO, YES.
22 Q DI D MR. PUTNAM ANSWER QUESTI ONS ALONG WI TH
23 MS. J ORRI E?
24 A MS. J ORRI E ANSWERED MOST OF THE QUESTI ONS.
25 I BELI EVE MR. PUTNAM WAS SI TTI NG I N THE BACK OFF TO THE
26 SI DE.
27 Q WERE YOU I N LI KE AN OFFI CE OR A CONFERENCE
28 ROOM?

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1 A I BELI EVE I T WAS A CONFERENCE ROOM, I F I ' M
2 NOT MI STAKEN.
3 Q OKAY. NOW, WAS I T YOUR J OB THERE TO GET
4 THE FACTS, SO TO SPEAK, AND WRI TE THEM DOWN?
5 A YES.
6 Q WERE YOU THERE TO I NTERPRET ANYTHI NG OF
7 WHAT WAS BEI NG SAI D?
8 A NO.
9 Q HAVE YOU EVER BEEN I N THE CONCERT BUSI NESS?
10 A NO.
11 Q DO YOU KNOWANYTHI NG ABOUT WORLD TOURS?
12 A NOTHI NG WHATSOEVER.
13 MR. PANI SH: OKAY. I WANT TO SHOWYOU, SI R - - I
14 WANT TO PUT UP, ACTUALLY, TESTI MONY OF KATHY J ORRI E,
15 STARTI NG AT PAGE 13175, LI NE 15. I ' M HAPPY TO SHOWI T
16 TO MS. BI NA.
17 THE COURT: TESTI MONY I N THE TRI AL, A DEPO, OR - -
18 MR. PANI SH: TRI AL TESTI MONY OF MS. J ORRI E, ME
19 QUESTI ONI NG HER WHEN SHE WAS ON THAT WI TNESS STAND.
20 AND I T GOES UP THROUGH 78.
21 THE COURT: ALL RI GHT.
22 MR. PANI SH: AND WHI LE MS. BI NA I S DOI NG THAT,
23 SI R, WHEN WE GET THERE, I ' M GOI NG TO ASK YOU SOME
24 QUESTI ONS. I ' M GOI NG TO SHOWYOU MS. J ORRI E' S
25 TESTI MONY THAT SHE GAVE HERE AND ASK YOU SOME QUESTI ONS
26 ABOUT I T. OKAY?
27 THE WI TNESS: YES, SI R.
28 MS. BI NA: I ' M J UST GOI NG TO OBJ ECT THAT THE

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1 TESTI MONY I S I NCOMPLETE.
2 THE COURT: WELL, I ' LL LET YOU SHOWOTHERS I F YOU
3 HAVE OTHERS.
4 MR. PANI SH: OKAY. SO LET' S START LI NE 15. THI S
5 I S ME QUESTI ONI NG MS. J ORRI E ( READI NG) :
6 Q DI D YOU TELL - - DI D
7 MR. PUTNAM TELL THE LOS ANGELES
8 POLI CE DEPARTMENT THAT
9 MI CHAEL J ACKSON WAS GOI NG TO DO A
10 WORLD TOUR THAT WOULD LAST TWO TO
11 THREE YEARS?
12 A NOT THAT I RECALL, SI R.
13 Q DI D YOU TELL - - DI D
14 MR. PUTNAM AND MS. J ORRI E TELL THE
15 LOS ANGELES POLI CE DEPARTMENT THAT
16 THE EUROPEAN TOUR WAS J UST THE
17 BEGI NNI NG, AND THAT MI CHAEL J ACKSON
18 WAS GOI NG TO DO A WORLD TOUR THAT
19 WOULD LAST TWO TO THREE YEARS?
20 A NOT THAT I RECALL.
21 Q DO YOU DENY MAKI NG THAT
22 STATEMENT TO THE LOS ANGELES POLI CE
23 DEPARTMENT?
24 A THAT' S NOT MY STATEMENT. I
25 DI D NOT SAY THAT. I T DOESN' T REFRESH
26 MY RECOLLECTI ON OF ANY SUCH
27 CONVERSATI ON.
28 Q MS. J ORRI E, DI D YOU TELL THE

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1 LOS ANGELES POLI CE DEPARTMENT THAT
2 MR. J ACKSON, WHEN HE FI NI SHED THE
3 EUROPEAN PORTI ON I N LONDON, WAS GOI NG
4 TO GO ON A TWO- TO THREE- YEAR
5 WORLDWI DE TOUR, YES OR NO?
6 A NO.
7 Q OKAY. SO YOU DENY MAKI NG
8 THAT STATEMENT; I S THAT CORRECT?
9 A I N THAT WAY, YES.
10 Q AND YOU' RE AS SURE OF THAT AS
11 ANYTHI NG YOU' VE TESTI FI ED HERE WHEN
12 MS. BI NA WAS QUESTI ONI NG YOU,
13 CORRECT?
14 A PRETTY SURE I WOULDN' T HAVE
15 SAI D I T QUI TE THAT WAY, SI R.
16 THE COURT: " QUI TE LI KE THAT. "
17 MR. PANI SH: " QUI TE LI KE THAT. "
18 AND WE' RE GOI NG TO SKI P TO THE NEXT - - 22,
19 RI GHT DOWN BELOWTHAT.
20 ( READI NG: )
21 DI D YOU TELL THE LOS ANGELES
22 POLI CE DEPARTMENT - - FI RST OF ALL,
23 LET' S START WI TH MR. PUTNAM. DI D
24 MR. PUTNAM TELL THE LOS ANGELES
25 POLI CE DEPARTMENT THAT
26 MI CHAEL J ACKSON WAS GOI NG TO DO A
27 WORLD TOUR THAT WOULD LAST TWO TO
28 THREE YEARS?

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1 A I DON' T THI NK SO, SI R.
2 Q SO YOU DENY THAT HE SAI D
3 THAT, RI GHT?
4 A YES.
5 Q AND YOU DENY THAT YOU TOLD
6 THE LOS ANGELES POLI CE DEPARTMENT
7 THAT WHEN - - THAT MI CHAEL J ACKSON WAS
8 GOI NG TO DO A WORLD TOUR THAT WOULD
9 LAST TWO TO THREE YEARS, CORRECT?
10 A THAT' S CORRECT.
11 Q AND YOU DENY TELLI NG THAT TO
12 OFFI CER SMI TH, CORRECT?
13 A THAT' S RI GHT.
14 Q AND SO DO YOU - - YOU' RE AS
15 SURE OF THAT AS ALL THE TESTI MONY
16 YOU' VE GI VEN HERE TODAY, CORRECT?
17 A I ' M PRETTY SURE I - - YES.
18 Q SO I F MR. - - SO I F
19 DETECTI VE SMI TH WERE TO COME I N HERE
20 AND SAY YOU MADE THAT STATEMENT, THEN
21 HE' D BE LYI NG, RI GHT?
22 A HE WOULD BE MI STAKEN,
23 MR. PANI SH.
24 OKAY. WE DON' T NEED TO READ THE REST PART.
25 Q NOW, DI D YOU GET THE GI ST OF WHAT I J UST
26 READ TO YOU, SI R?
27 A YES, SI R.
28 Q OKAY. NOW, WAS THAT A TRUE TESTI MONY BASED

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1 ON YOUR I NTERVI EWOF MR. PUTNAM AND MS. J ORRI E?
2 MS. BI NA: OBJ ECTI ON; YOUR HONOR. THAT' S AN
3 I MPROPER QUESTI ON TO ASSESS MS. J ORRI E' S CREDI BI LI TY.
4 THE COURT: THAT I S A LI TTLE BI T. THAT' S NOT
5 QUI TE THE WAY - -
6 MR. PANI SH: OKAY.
7 Q DI D MS. J ORRI E, WHEN SHE DENI ED MAKI NG THAT
8 STATEMENT - - STRI KE THE QUESTI ON.
9 MS. J ORRI E DENI ED MAKI NG CERTAI N STATEMENTS
10 TO YOU THAT I J UST READ; I S THAT CORRECT?
11 MS. BI NA: OBJ ECTI ON; LEADI NG, ALSO AN I MPROPER
12 QUESTI ON, CHARACTERI ZES THE TESTI MONY, YOUR HONOR. SHE
13 SAI D REPEATEDLY, YOUR HONOR, THAT SHE DI DN' T SAY I T I N
14 THAT WAY.
15 MR. PANI SH: NO. THAT' S A SPEAKI NG - -
16 THE COURT: OVERRULED.
17 MR. PANI SH: OKAY.
18 Q DETECTI VE, TELL US, SI R, FROM YOUR
19 PERSPECTI VE OF WHAT MS. J ORRI E TOLD YOU, WAS THAT
20 ACCURATE OR NOT?
21 A SHE DI D STATE THAT THERE WAS GOI NG TO BE A
22 WORLD TOUR THAT WOULD LAST TWO TO THREE YEARS.
23 Q AND WHEN MS. J ORRI E SAI D THAT, DI D YOU TAKE
24 NOTES?
25 A YES.
26 Q DI D YOU DO I T I N THE PROCEDURES THAT YOU
27 FOLLOWAT THE LOS ANGELES POLI CE DEPARTMENT?
28 A YES.

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1 Q DO YOU STI LL HAVE THOSE HANDWRI TTEN NOTES
2 THAT REFLECT WHAT WAS STATED?
3 A YES, I DO.
4 Q ARE THEY RI GHT THERE I N THAT BOOK?
5 A YES, SI R.
6 Q AND HAVE YOU CONFI RMED - - STRI KE THAT.
7 WHEN YOU FI NI SHED THE I NTERVI EW, DI D YOU
8 SAY ANYTHI NG TO MS. J ORRI E OR MS. PUTNAM ( SI C) ?
9 MS. BI NA: OBJ ECTI ON; VAGUE?
10 MR. PANI SH: I ' LL REPHRASE THE QUESTI ON.
11 Q WHEN YOU TOOK DOWN THE STATEMENT, DI D YOU
12 EVER READ I T BACK, WHAT THEY SAI D, FROM YOUR NOTES TO
13 MR. PUTNAM AND MS. J ORRI E?
14 A TYPI CALLY I WOULD; BUT I N THI S SI TUATI ON,
15 I - - I DON' T BELI EVE THAT I DI D.
16 Q OKAY. NOW, I S THERE ANY QUESTI ON I N YOUR
17 MI ND THAT YOU ACCURATELY WROTE DOWN WHAT MS. J ORRI E
18 TOLD YOU?
19 A NO QUESTI ON WHATSOEVER.
20 Q CAN YOU READ FOR US SPECI FI CALLY WHAT
21 MS. J ORRI E TOLD YOU ABOUT THE WORLD TOUR WHEN YOU
22 I NTERVI EWED HER I N HER OFFI CE I N THE PRESENCE OF
23 MR. PUTNAM?
24 CAN YOU DO THAT FOR US, PLEASE, SI R?
25 A YES.
26 MS. BI NA: AND I ' M GOI NG TO OBJ ECT TO THAT, YOUR
27 HONOR, I N THAT THE HANDWRI TTEN NOTES ARE THE
28 DETECTI VE' S NOTES, THEY' RE NOT A VERBATI M TRANSCRI PT

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1 AND THEY' RE NOT MS. J ORRI E' S WORDS, SO THEY' RE
2 HEARSAY.
3 MR. PANI SH: THEY' RE ABSOLUTELY. I T' S A PRI OR
4 I NCONSI STENT STATEMENT. I T' S I MPEACHI NG HER.
5 THE COURT: OVERRULED. YOU MAY READ I T.
6 Q BY MR. PANI SH: LET' S FI RST START WI TH THE
7 STATEMENT THAT YOU WROTE DOWN ON THE OFFI CI AL
8 LOS ANGELES POLI CE DEPARTMENT FORM.
9 A OKAY.
10 Q WHY DON' T YOU READ I T TO US, J UST ABOUT THE
11 WORLD TOUR.
12 A " MS. J ORRI E AND MR. PUTNAM STATED THAT THI S
13 WAS ONLY THE BEGI NNI NG, M. J . WAS TO DO A WORLD TOUR
14 THAT WOULD LAST TWO TO THREE YEARS. "
15 Q DI D YOU ACCURATELY WRI TE THAT DOWN?
16 A YES, I DI D.
17 Q DO YOU HAVE - - COULD YOU LOOK AT YOUR
18 HANDWRI TTEN NOTES THAT YOU TOOK THAT DAY AT THE
19 MEETI NG - - CAN YOU LOOK AT THAT?
20 A THESE ARE MY HANDWRI TTEN NOTES.
21 Q OKAY. AND DI D YOU TRANSCRI BE THOSE NOTES
22 I NTO AN OFFI CI AL LOS ANGELES POLI CE DEPARTMENT REPORT?
23 A YES, I DI D.
24 Q OKAY. CAN YOU LOOK AT THAT AND TELL US
25 EXACTLY WHAT YOU TRANSCRI BED.
26 A " MR. PUTNAM AND MS. J ORRI E STATED THAT THE
27 EUROPEAN TOUR WAS J UST THE BEGI NNI NG AND THAT
28 MI CHAEL J ACKSON WAS GOI NG TO DO A WORLD TOUR THAT WOULD

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1 LAST TWO TO THREE YEARS. "
2 Q OKAY. NOW, SI R, I S THERE ANY QUESTI ON I N
3 YOUR MI ND THAT YOU TOOK DOWN COMPLETELY ACCURATELY WHAT
4 WAS TOLD TO YOU?
5 A NO, SI R.
6 Q SO DO YOU HAVE ANY REASON TO PUT DOWN
7 SOMETHI NG FALSE THAT MR. PUTNAM OR MS. J ORRI E MI GHT
8 HAVE SAI D?
9 A NONE WHATSOEVER.
10 Q DO YOU HAVE ANY I LL WI LL TOWARDS MR. PUTNAM
11 OR MS. J ORRI E?
12 A NO, I DO NOT.
13 Q HAVE YOU EVER DEALT WI TH THEM SI NCE THAT
14 TI ME?
15 A NO, I DON' T BELI EVE SO.
16 Q NOW, FI NALLY, WHEN YOU TAKE A WI TNESS
17 STATEMENT, DO YOU TRY TO TAKE A STATEMENT AT A LOCATI ON
18 THAT' S CONVENI ENT OR I NCONVENI ENT FOR THE WI TNESS?
19 A CONVENI ENT FOR THE WI TNESS.
20 Q WHY DO YOU DO THAT?
21 A THEI R PREFERENCE OF TI ME AND LOCATI ON MAKES
22 I T MUCH MORE EASI ER FOR THEM, OBVI OUSLY; AND I BELI EVE
23 THAT' S J UST THE RI GHT WAY TO DO THI NGS.
24 Q I S THAT HOWYOU DI D I T I N THI S CASE?
25 A YES, SI R.
26 Q DO YOU LI STEN CAREFULLY OR NOT CAREFULLY
27 WHEN YOU WRI TE DOWN WHAT THEY SAY?
28 A CAREFULLY.

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1 Q DO YOU WRI TE I T DOWN CONTEMPORANEOUSLY WHEN
2 I T' S SAI D, OR SOME LATER TI ME?
3 A CONTEMPORANEOUSLY.
4 Q DI D YOU DO THAT HERE?
5 A YES, I DI D.
6 Q I S THAT HOWYOU WERE TRAI NED I N THE
7 LOS ANGELES POLI CE DEPARTMENT ACADEMY AND I N ADDI TI ONAL
8 ON- THE- J OB TRAI NI NG?
9 A YES.
10 Q WHEN YOU GO BACK TO THE STATI ON, DO YOU
11 REVI EWYOUR NOTES THAT YOU TOOK DOWN?
12 A YES.
13 Q DI D YOU DO THAT HERE?
14 A YES, I DI D.
15 Q I F THERE' S ANYTHI NG UNCLEAR, DO YOU GI VE
16 THE PERSON THAT YOU' VE I NTERVI EWED, OR PERSONS, THE
17 OPPORTUNI TY TO CLARI FY WHAT YOU SAI D TO MAKE SURE THAT
18 I T' S ACCURATE?
19 A YES.
20 Q DO YOU TYPE UP - - DI D YOU TYPE UP YOUR
21 HANDWRI TTEN NOTES FOR A REPORT?
22 A YES, I DI D.
23 Q I S THAT SOMETHI NG YOU' VE DONE MANY, MANY
24 TI MES?
25 A YES.
26 MR. PANI SH: THAT' S ALL I HAVE. THANK YOU,
27 SI R.
28 THE WI TNESS: THANK YOU.

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1 THE COURT: CROSS- EXAMI NATI ON?
2 MS. BI NA: BRI EFLY, YOUR HONOR.
3
4 CROSS- EXAMI NATI ON
5 BY MS. BI NA:
6 Q GOOD AFTERNOON, DETECTI VE SMI TH.
7 A GOOD AFTERNOON, MA' AM.
8 Q I ' LL TRY TO KEEP THESE THI NGS QUI CK HERE
9 BECAUSE I KNOWI T' S HOT. LET' S START WI TH YOUR
10 I NTERVI EWWI TH MS. J ORRI E. MS. J ORRI E AGREED TO BE
11 I NTERVI EWED BY THE POLI CE I N CONNECTI ON WI TH THI S CASE,
12 RI GHT?
13 A YES, MA' AM.
14 Q AND SHE DI DN' T RAI SE ANY OBJ ECTI ONS OR SAY
15 SHE DI DN' T WANT TO TALK TO THE POLI CE?
16 A NO.
17 Q I N FACT, SHE MET WI TH THEM A COUPLE OF
18 TI MES, AND THEN EVENTUALLY BECAME A WI TNESS I N THE
19 CRI MI NAL TRI AL AGAI NST DR. CONRAD MURRAY, RI GHT?
20 A THAT' S CORRECT.
21 Q AND YOU TOOK NOTES DURI NG YOUR MEETI NG WI TH
22 MS. J ORRI E?
23 A YES.
24 Q AND WOULD YOU DESCRI BE HER AS COOPERATI VE
25 AND HELPFUL DURI NG THAT MEETI NG?
26 A VERY COOPERATI VE AND HELPFUL.
27 Q DI D YOU GET THE SENSE THAT SHE WAS HOLDI NG
28 ANYTHI NG BACK OR TRYI NG TO, YOU KNOW, NOT GI VE YOU ANY

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1 I NFORMATI ON?
2 A NO.
3 Q AND SHE, I N FACT, TOLD YOU THAT THE DRAFT
4 CONTRACT FOUND I N THE - - I N THE CAR HAD ONLY EVER BEEN
5 SI GNED BY DR. MURRAY, RI GHT?
6 A THAT' S RI GHT.
7 MR. PANI SH: THAT' S GOI NG TO BE HEARSAY. I T' S
8 NOT BEI NG USED FOR AN APPROPRI ATE PURPOSE.
9 THE COURT: OVERRULED.
10 Q BY MS. BI NA: AND YOU NEVER SAWA VERSI ON
11 OF THE CONTRACT THAT WAS SI GNED BY A. E. G. LI VE OR BY
12 MI CHAEL J ACKSON?
13 A NO, I DI D NOT.
14 Q AND I WANTED TO ASK A LI TTLE BI T ABOUT YOUR
15 NOTES, BECAUSE THE POLI CE STATEMENT I HAVE HERE I S THE
16 SUMMARY OF YOUR - - YOUR I NTERVI EW, RI GHT?
17 A CORRECT.
18 Q AND YOU TAKE NOTES WHEN YOU' RE I NTERVI EWI NG
19 SOMEONE?
20 A I T DEPENDS.
21 Q GENERALLY SPEAKI NG?
22 A GENERALLY SPEAKI NG, YES.
23 Q AND YOU TOOK NOTES WHEN YOU WERE
24 I NTERVI EWI NG MS. J ORRI E?
25 A YES.
26 Q BUT YOU DI DN' T HAVE SOMEBODY LI KE THE COURT
27 REPORTER THERE TAKI NG DOWN EVERY WORD, RI GHT?
28 A NO, MA' AM.

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1 Q AND SO WHAT YOU TAKE I S A SUMMARY, YOUR
2 NOTES ARE A SUMMARY OF THE CONVERSATI ON, RI GHT?
3 A THAT' S CORRECT.
4 Q AND YOU TRY TO BE AS THOROUGH AND ACCURATE
5 AS YOU CAN, BUT YOU DON' T GET EVERY DETAI L, EVERY WORD,
6 EVERYTHI NG EVERYBODY SAYS DURI NG THE ENTI RE
7 CONVERSATI ON?
8 A I WOULD I MAGI NE THERE' S SOME THI NGS MI SSED.
9 Q AND I WANTED TO ASK THAT BECAUSE I WANT TO
10 SHOWYOU A LI TTLE BI T MORE OF MS. J ORRI E' S TESTI MONY
11 AND THEN ASK YOU SOME QUESTI ONS ABOUT I T. AND LET' S
12 PUT BACK UP THE PART THAT MR. PANI SH SHOWED FI RST.
13 AND THAT I S 13175, AND I ' LL REPRESENT TO
14 YOU THAT MS. J ORRI E WAS SHOWN A COPY OF THI S TWO- PAGE
15 SUMMARY THAT YOU HAD TYPED UP OF THE I NTERVI EW.
16 A OKAY.
17 Q AND, YOU KNOW, SHE - - AND THAT WAS WHAT
18 MR. PANI SH WAS ASKI NG ABOUT AT THE TI ME.
19 MR. PANI SH: WELL, THAT' S NOT WHAT I WAS ASKI NG
20 ABOUT. I ' M GOI NG TO J UST OBJ ECT TO COUNSEL' S
21 REPRESENTATI ON BECAUSE MS. J ORRI E SAI D I T REFRESHED
22 NOTHI NG, AND I DI DN' T SHOWI T TO HER BECAUSE I WASN' T
23 ALLOWED TO BECAUSE I ASKED HER HAD SHE REVI EWED I T, SHE
24 SAI D SHE HADN' T, AND I T DI DN' T REFRESH HER
25 RECOLLECTI ON.
26 MS. BI NA: YOUR HONOR, SHE SAI D SHE HAD REVI EWED
27 I T, I T DI DN' T REFRESH HER RECOLLECTI ON BECAUSE I T
28 WASN' T HER STATEMENT. BUT I T WASN' T HER STATEMENT, I T

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1 WAS SOMETHI NG THAT MR. PANI SH SHOWED, SO I WAS TRYI NG
2 TO REFRESH HER RECOLLECTI ON.
3 THE COURT: I F I T DI DN' T REFRESH HER
4 RECOLLECTI ON, SHE DI DN' T USE I T AT ALL I N CONJ UNCTI ON
5 WI TH HER TESTI MONY, SO SUSTAI NED.
6 MS. BI NA: I ' D LI KE TO GO TO THE NEXT PAGE,
7 SOMETHI NG THAT MR. PANI SH SKI PPED OVER, 13176. AND
8 LET' S START WI TH LI NE 8, AND THEN J UST GO ALL THE WAY
9 DOWN TO THE BOTTOM OF THE PAGE.
10 MR. PANI SH: I ' M J UST GOI NG TO OBJ ECT TO THE
11 STATEMENT THAT I SKI PPED OVER I T. I DI DN' T SKI P OVER
12 LI NE 8.
13 THE COURT: SUSTAI NED AS TO THE CHARACTERI ZATI ON.
14 J UST SHOWWHATEVER YOU WANT TO SHOW.
15 Q BY MS. BI NA: AND I ' D LI KE TO DRAWYOUR
16 ATTENTI ON, DETECTI VE SMI TH, TO THE LI NE AFTER HE READ,
17 " PRETTY SURE I WOULDN' T HAVE SAI D I T QUI TE LI KE THAT,
18 SI R. "
19 AND THEN WE HAVE ( READI NG) :
20 Q DI D YOU TELL THE LOS ANGELES
21 POLI CE DEPARTMENT THAT MR. J ACKSON
22 WAS GOI NG TO GO ON A WORLDWI DE TOUR
23 AFTER LONDON?
24 A I ' D BE HAPPY TO TELL YOU WHAT
25 I SAI D TO THEM I F YOU' D LI KE TO HEAR
26 I T.
27 Q CAN YOU ANSWER MY QUESTI ON,
28 PLEASE.

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1 AND THEN GOES ON TO THE PART THAT WE
2 ALREADY READ ABOUT DI D MR. PUTNAM TELL THE LOS ANGELES
3 POLI CE DEPARTMENT THAT MR. J ACKSON WAS GOI NG TO DO A
4 WORLD TOUR THAT WOULD LAST TWO TO THREE YEARS.
5 AND THEN I ' D LI KE TO GO TO THE NEXT PAGE.
6 MR. PANI SH: WELL, LET' S READ THE ANSWER.
7 MS. BI NA: EXCUSE ME?
8 THE REST OF I T HAS ALREADY BEEN READ.
9 MR. PANI SH: I OBJ ECT TO I NCOMPLETE USE OF THE
10 TESTI MONY.
11 MS. BI NA: YOUR HONOR, I ' M READI NG THE PORTI ONS
12 THAT MR. PANI SH DI D NOT READ OUT LOUD DURI NG HI S
13 EXAMI NATI ON.
14 MR. PANI SH: YOUR HONOR, I READ THE ENTI RE THI NG
15 OUT LOUD AND YELLOWED I T OUT.
16 MR. PUTNAM: YOUR HONOR, THI S WAS NOT READ.
17 THE COURT: DI D YOU READ QUESTI ON, ANSWER,
18 QUESTI ON, ANSWER?
19 MR. PANI SH: YES, I DI D.
20 THE COURT: THEN YOU READ QUESTI ON, ANSWER,
21 QUESTI ON, ANSWER.
22 MS. BI NA: I DI DN' T J UST READ THE QUESTI ON, I
23 READ THE QUESTI ON AND THE ANSWER.
24 THE COURT: WHAT WAS THE ANSWER AGAI N? I MI SSED
25 I T.
26 MR. PANI SH: HER QUESTI ON WAS DI D YOU TELL - - DI D
27 MR. PUTNAM TELL - -
28 MS. BI NA: I SAI D, " DI D YOU TELL THE LOS ANGELES

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1 POLI CE DEPARTMENT THAT MR. J ACKSON WAS GOI NG TO GO ON A
2 WORLDWI DE TOUR AFTER LONDON?"
3 THE ANSWER WAS, " I ' D BE HAPPY TO TELL YOU
4 WHAT I SAI D I F YOU' D LI KE TO HEAR I T. "
5 THE NEXT QUESTI ON I S ONE MR. PANI SH READ,
6 SO I ' M MOVI NG ON TO THE NEXT PAGE. MR. PANI SH READ
7 EVERYTHI NG EXCEPT LI NES 16 THROUGH 20, SO THAT' S THE
8 PORTI ON I READ HERE.
9 MR. PANI SH: THAT' S NOT TRUE.
10 MS. BI NA: I DON' T - - MAYBE HE DI DN' T MEAN TO
11 SKI P I T, BUT HE SKI PPED LI NE 16 TO 20.
12 MR. PUTNAM: HE STARTED THE PAGE BEFORE, HE READ
13 THROUGH, HE GOT TO A PORTI ON, WHI CH WAS LI NE 15, THAT
14 YOU' RE SEEI NG THERE, YOUR HONOR. HE GOT TO THAT, AND
15 HE SAI D NOWTHAT' S SKI PPED.
16 MR. PANI SH: I S THI S A SPEAKI NG OBJ ECTI ON?
17 MR. PUTNAM: I ' M EXPLAI NI NG WHAT OCCURRED.
18 THE COURT: GO AHEAD.
19 MR. PUTNAM: HE THEN SAI D SKI P DOWN TO 22. SO
20 SHE SAI D, " YOUR HONOR, I ' M GOI NG TO OBJ ECT TO THI S ON
21 COMPLETENESS. "
22 YOU SAI D, " YOU CAN DO I T WHEN YOU GET UP
23 THERE. "
24 SHE GOT UP AND SAI D, " HERE' S THE PORTI ON
25 YOU DI DN' T READ, YOU SKI PPED THI S. "
26 MR. PANI SH: SO THEN SHE READ THE OTHER PART THAT
27 I DI D READ.
28 THE COURT: ALL RI GHT. I UNDERSTAND.

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1 MS. BI NA: THAT' S ALL I WAS - - SO, DETECTI VE
2 SMI TH, SORRY FOR THE - - I ' D LI KE TO DRAWYOUR ATTENTI ON
3 NOWTO SOMETHI NG ON THE NEXT PAGE. AND THI S I S AFTER
4 LI NE 15, WHI CH MR. PANI SH READ. I ' D LI KE TO LOOK AT
5 LI NES - - HANG ON A SECOND. I ' M ON THE WRONG PAGE HERE.
6 I ' D LI KE TO GO TO THE BOTTOM OF PAGE 13177,
7 LI NE 24 THROUGH 28. AND THEN GOI NG OVER ON TO THE NEXT
8 PAGE, THROUGH LI NE 10.
9 MR. PANI SH: GO AHEAD.
10 MS. BI NA: ( READI NG: )
11 Q BY MR. PANI SH: CAN YOU TELL
12 US, DI D DETECTI VE SMI TH NOT LI KE YOU?
13 A NO. HE WAS QUI TE FRI ENDLY,
14 ACTUALLY.
15 Q COULD YOU TELL US ANY REASON
16 THAT YOU KNOWOF WHY DETECTI VE SMI TH
17 WOULD FABRI CATE A STATEMENT MADE BY
18 MR. PUTNAM AND YOURSELF AND PUT I T I N
19 AN OFFI CI AL REPORT OF THE LOS ANGELES
20 POLI CE DEPARTMENT?
21 A YES, BECAUSE HE MI SUNDERSTOOD
22 WHAT I WAS SAYI NG TO HI M ABOUT THE
23 TOUR AGREEMENT.
24 WELL, DI D YOU CALL HI M UP AND
25 SAY, " YOU MI SUNDERSTOOD WHAT I TOLD
26 YOU" ?
27 A I DI DN' T EVEN RECEI VE THAT
28 REPORT FOR SOME TI ME.

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1 AND THEN ONE MORE SECTI ON - -
2 MR. BOYLE: I S THAT A QUESTI ON?
3 MS. BI NA: - - WHI CH I S 13390.
4 MR. PANI SH: I DON' T HAVE THAT ONE.
5 MS. BI NA: I ' LL SHOWI T TO YOU. AND THAT I S LI NE
6 23 THROUGH - - I ' LL SHOWI T TO YOU I N ONE SECOND. I ' M
7 J UST TRYI NG TO READ THE NUMBERS I NTO THE RECORD.
8 13391- 13, AND THEN 13392, LI NE 20 THROUGH 133- - - LI NE
9 7. I ' LL SHOWI T TO YOU.
10 MR. PANI SH: 13391- 13, TO 13392- 20?
11 MS. BI NA: 13390, LI NE 23, I S WHERE I T STARTS.
12 HERE. WE' VE GOT ANOTHER COPY, TRY TO DO
13 THI S SI MULTANEOUSLY.
14 MR. PANI SH: OKAY. SO WHERE ARE WE? 13390,
15 WHI CH LI NE?
16 MS. BI NA: STARTI NG WI TH LI NE 23 - -
17 MR. PANI SH: OKAY. AND THEN - -
18 MS. BI NA: - - THROUGH 13391, LI NE 13; AND THEN
19 THE NEXT PAGE, 13392, LI NE 20.
20 MR. PANI SH: LET' S DO THI S PART FI RST. 13390,
21 LI NE 20, TO 13391, LI NE 13, YOU CAN READ THAT PART
22 FI RST, I T' S LI NE 23, ACTUALLY.
23 MR. PANI SH: GO AHEAD, READ I T.
24 MS. BI NA: ( READI NG: )
25 Q AND YOU WERE ASKED A LI TTLE
26 BI T AGO ABOUT SOME STATEMENTS THAT
27 YOU MADE TO THE POLI CE REGARDI NG
28 MR. J ACKSON GOI NG ON A TWO- TO

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1 THREE- YEAR WORLD TOUR?
2 A YES.
3 Q DO YOU RECALL THAT?
4 A YES.
5 NEXT PAGE.
6 Q AND I ' D LI KE TO ASK DO YOU
7 RECALL YOU SAI D SEVERAL TI MES THAT
8 YOU REMEMBER EXACTLY WHAT YOU TOLD
9 THE POLI CE ABOUT THE WORLD TOUR
10 AGREEMENT?
11 A YES.
12 Q BUT YOU DI DN' T ACTUALLY GET
13 TO TELL US THAT?
14 A RI GHT.
15 Q WHAT DI D YOU TELL THE POLI CE
16 ABOUT THE WORLD TOUR?
17 A WELL, WHAT WE EXPLAI NED WAS
18 THAT THE TOUR AGREEMENT HAD THE
19 POTENTI AL FOR GOI NG THE LENGTH OF THE
20 TERM, BUT I T WAS THE POTENTI AL, AND
21 THEN WE TALKED ABOUT THE TERM AND HOW
22 THAT WORKED.
23 AND THERE' S ONE MORE SECTI ON.
24 MR. PANI SH: I S THERE A QUESTI ON HERE?
25 MS. BI NA: I ' M DOI NG WHAT MR. PANI SH DI D. I ' M
26 SHOWI NG TESTI MONY AND GOI NG TO ASK QUESTI ONS ABOUT I T A
27 AFTERWARDS.
28 THE COURT: OVERRULED.

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1 MR. PANI SH: I DI DN' T OBJ ECT. WHAT' S THE NEXT
2 PAGE AND LI NE?
3 MS. BI NA: 13392, LI NE 20.
4 AND, PAM, I F YOU CAN BLACK OUT LI NES 22
5 THROUGH 24.
6 AND THEN THROUGH 13393, LI NE 7.
7 Q WHAT SPECI FI CALLY DI D YOU
8 TELL THE POLI CE?
9 A WHAT I SAI D TO THE DETECTI VES
10 WAS THAT THE AGREEMENT HAD THE
11 POTENTI AL FOR EXTENDI NG FOR THE TERM
12 OF THE AGREEMENT, AND THAT THE
13 PARTI ES WOULD NEED TO MUTUALLY
14 APPROVE THE I TI NERARI ES, AND AS THEY
15 APPROVED THEM, THEN THE TOUR WOULD
16 CONTI NUE I NTO ONE COUNTRY, I NTO THE
17 NEXT.
18 Q SO YOU TOLD THE POLI CE THAT
19 MUTUALLY APPROVED LEGS COULD CONTI NUE
20 ON, AND THAT THERE WAS A POTENTI AL
21 FOR A LONGER TOUR?
22 A YES, BUT I DI DN' T GET I NTO
23 THE MECHANI CS OF THE CONTRACT, HOW
24 THAT WORKED.
25 Q SO DETECTI VE SMI TH, I WANT TO ASK YOU, AS
26 WE SI T HERE TODAY, DO YOU RECALL WORD FOR WORD EXACTLY
27 WHAT MS. J ORRI E SAI D ABOUT THE WORLD TOUR?
28 A I DO NOT.

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1 Q DO YOU RECALL WHETHER SHE SAI D I T WAS
2 DEFI NI TELY GOI NG TO BE TWO OR THREE YEARS, OR THAT I T
3 HAD THE POTENTI AL FOR THAT I F MUTUAL LEGS WERE APPROVED
4 AS THEY WENT - - FOR I NSTANCE, I F LONDON WAS A SUCCESS,
5 THEN THEY MI GHT GO ON TO ANOTHER LOCATI ON AND ANOTHER
6 LOCATI ON AFTER THAT?
7 A I DON' T RECALL THAT, NO.
8 Q WAS THAT I N ANY WAY I MPORTANT TO YOUR
9 I NVESTI GATI ON OR WHAT YOU WERE TRYI NG TO FI ND OUT ABOUT
10 DR. CONRAD MURRAY?
11 A NONE WHATSOEVER.
12 Q AND I F MS. J ORRI E ACKNOWLEDGED TALKI NG
13 ABOUT A TWO- TO THREE- YEAR TOUR, BUT SAI D I T WAS A
14 POTENTI AL TOUR, WOULD YOU HAVE ANY REASON TO DI SBELI EVE
15 HER TESTI MONY OR DOUBT THAT SHE WAS BEI NG TRUTHFUL?
16 A NO.
17 MR. PANI SH: THAT' S SPECULATI ON.
18 THE COURT: OVERRULED.
19 MS. BI NA: ALL RI GHT.
20 Q AND J UST ONE MORE THI NG, DETECTI VE SMI TH.
21 YOU TALKED A LOT ABOUT - - A LI TTLE BI T ABOUT
22 DR. MURRAY' S FI NANCI AL I SSUES AND MOTI VE.
23 I N YOUR VI EW, I S THERE EVER A REASON FOR
24 SOMEONE - - A GOOD REASON FOR SOMEONE TO BREAK THE LAW
25 AND COMMI T A CRI ME LI KE DR. MURRAY DI D I N THI S CASE?
26 A AS I T RELATES TO DR. MURRAY, NO.
27 Q AND LOTS OF PEOPLE HAVE FI NANCI AL PROBLEMS,
28 RI GHT?

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1 A YES.
2 Q AND THEY STI LL FOLLOWTHE LAW?
3 A YES.
4 Q AND I F THEY DON' T, YOU PROSECUTE THEM?
5 A YES, MA' AM.
6 MS. BI NA: THANK YOU.
7 NOTHI NG FURTHER.
8
9 REDI RECT EXAMI NATI ON
10 BY MR. PANI SH:
11 Q AND I N THI S CASE, SI R, DR. MURRAY HAD A
12 FI NANCI AL I NTEREST THAT LED YOU TO BELI EVE THAT THAT' S
13 WHY HE WOULD VI OLATE HI S HI PPOCRATI C OATH I N THI S CASE
14 FOR THE MOTI VE FOR WHAT HAPPENED TO MR. J ACKSON,
15 CORRECT?
16 A YES, SI R.
17 Q AND BASED ON THE CONTRACT THAT YOU FOUND I N
18 DR. MURRAY' S CONTRACT BETWEEN A. E. G. AND DR. MURRAY,
19 THAT DREWYOUR ATTENTI ON RI GHT AWAY TO THAT FI GURE, THE
20 AMOUNT OF MONEY THAT HE WAS GOI NG TO BE PAI D, DI D I T
21 NOT?
22 A YES, I T DI D.
23 Q AND AS A - - AS AN EXPERI ENCED HOMI CI DE
24 DETECTI VE, WHEN YOU SAW$150, 000 A MONTH, THAT RAI SED A
25 SERI OUS RED FLAG TO YOU ABOUT DR. MURRAY' S ETHI CS AND
26 WHETHER OR NOT HE WAS UNBI ASED, CORRECT?
27 MS. BI NA: OBJ ECTI ON; LEADI NG.
28 THE COURT: OVERRULED.

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1 THE WI TNESS: YES, I T DI D.
2 Q BY MR. PANI SH: AND YOU SAWTHAT A. E. G.
3 COULD TERMI NATE THE CONTRACT AT ANY TI ME, DI D YOU NOT?
4 MS. BI NA: OBJ ECTI ON; LACKS FOUNDATI ON.
5 THE COURT: OVERRULED.
6 Q BY MR. PANI SH: DO YOU HAVE THE CONTRACT
7 WI TH YOU RI GHT THERE, SI R?
8 A I T MAY BE I N HERE SOMEWHERE. I DON' T KNOW
9 EXACTLY WHERE.
10 Q OKAY. FAI R ENOUGH.
11 YOU HAD SERI OUS CONCERNS ABOUT THAT
12 CONTRACT AND DR. MURRAY' S FI NANCI AL I NTEREST AND HI S - -
13 HI S FI NANCI AL SI TUATI ON THAT HE WOULD VI OLATE HI S
14 HI PPOCRATI C OATH, CORRECT?
15 A YES, SI R.
16 Q AND I T WAS YOUR DETERMI NATI ON THAT THAT' S
17 WHY HE DI D I T, CORRECT?
18 A YES, SI R.
19 MS. BI NA: OBJ ECTI ON; BEYOND THE SCOPE OF
20 REBUTTAL.
21 MR. PANI SH: SHE GOT I NTO I T.
22 THE COURT: OVERRULED.
23 Q BY MR. PANI SH: NOW, SI R, MS. J ORRI E - - DI D
24 YOU KNOWTHAT MS. J ORRI E - - DI D MS. J ORRI E DI SCLOSE TO
25 YOU THAT SHE HAD A FI NANCI AL I NTEREST OF BEI NG PAI D
26 OVER $7 MI LLI ON I N THE PAST SEVERAL YEARS BY A. E. G. ?
27 MS. BI NA: OBJ ECTI ON; MI SREPRESENTS MS. J ORRI E' S
28 TESTI MONY, I RRELEVANT, BEYOND THE SCOPE.

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1 MR. PANI SH: SHE ASKED ABOUT MS. J ORRI E' S
2 CREDI BI LI TY.
3 THE COURT: OVERRULED.
4 THE WI TNESS: NO, SI R, I HAD NO I DEA.
5 Q BY MR. PANI SH: AND, SI R, WHEN WI TNESSES
6 ARE BEI NG I NTERVI EWED, YOU EXPECT THEM TO BE HONEST,
7 CORRECT?
8 A YES.
9 Q BUT A LOT OF TI MES THEY' RE NOT, RI GHT?
10 A I T COULD HAPPEN, YES.
11 Q AND REASONS FOR PEOPLE NOT TO BE HONEST
12 COULD BE THEY HAVE A FI NANCI AL MOTI VE NOT TO BE,
13 CORRECT?
14 A COULD BE, YES, SI R.
15 Q AND YOU DI DN' T KNOWANYTHI NG ABOUT HOWMUCH
16 MONEY THE DEFENDANTS HAVE PAI D MS. J ORRI E, DI D YOU?
17 MS. BI NA: AND I ' M J UST GOI NG TO AGAI N OBJ ECT TO
18 THE FI GURE. THAT' S NOT BEEN PAI D TO MS. J ORRI E. I T
19 MI SSTATES THE EVI DENCE.
20 MR. PANI SH: I ' LL REPHRASE.
21 Q TO MS. J ORRI E' S LAWFI RM, I N WHI CH SHE WAS
22 THE MANAGI NG PARTNER. THEY DI DN' T TELL YOU THAT, DI D
23 THEY?
24 THE COURT: YOU MAY ANSWER.
25 THE WI TNESS: NO, THEY DI D NOT.
26 MR. PANI SH: OKAY.
27 Q AND MS. J ORRI E, I F SHE HAD TOLD YOU
28 SOMETHI NG LI KE I T WAS GOI NG TO BE A TOUR OR I T MI GHT BE

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1 A TOUR OR I T WAS POTENTI ALLY A TOUR, YOU' D WRI TE DOWN
2 ACCURATELY WHAT SHE TOLD YOU, WOULDN' T YOU?
3 A YES.
4 Q AND YOU HAVE NO RECOLLECTI ON WHATSOEVER OF
5 HER OR MR. PUTNAM EVER SAYI NG THI S WAS A POTENTI AL
6 TOUR, DO YOU, SI R?
7 MS. BI NA: OBJ ECTI ON; LEADI NG, ARGUMENTATI VE.
8 THE COURT: OVERRULED.
9 THE WI TNESS: I DO NOT.
10 Q BY MR. PANI SH: AND THAT' S SOMETHI NG THAT
11 YOU WOULD HAVE WRI TTEN DOWN AS PART OF YOUR TRAI NI NG AS
12 A SWORN LOS ANGELES POLI CE DEPARTMENT OFFI CER, CORRECT?
13 A YES, SI R.
14 MR. PANI SH: NOTHI NG FURTHER.
15
16 RECROSS- EXAMI NATI ON
17 BY MS. BI NA:
18 Q BRI EFLY, DETECTI VE SMI TH, DI D I T MATTER TO
19 YOU I N YOUR I NVESTI GATI ON I N ANY WAY, SHAPE OR FORM
20 WHETHER A. E. G. LI VE OR MI CHAEL J ACKSON WAS THE ONE
21 PAYI NG DR. MURRAY?
22 A NO, MA' AM.
23 Q AND I F - - I F MI CHAEL J ACKSON SAI D THE
24 150, 000, OR I F A. E. G. LI VE DI D, OR WHOEVER DI D, I T
25 WOULD MAKE NO DI FFERENCE TO YOU?
26 A THAT' S CORRECT.
27 Q AND DO YOU HAVE ANY KNOWLEDGE ONE WAY OR
28 THE OTHER OF WHEN MI CHAEL J ACKSON ASKED DR. MURRAY TO

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1 COME ON TOUR WI TH HI M?
2 A HERE TODAY, I DON' T RECALL, NO.
3 Q AND YOUR CONCERN WAS WHETHER DR. MURRAY HAD
4 MOTI VES ONE WAY OR THE OTHER, BUT THAT WAS NOT - - LET
5 ME START THAT QUESTI ON AGAI N.
6 YOU WEREN' T I NVESTI GATI NG A. E. G. LI VE?
7 A NO, MA' AM.
8 Q YOU WERE I NVESTI GATI NG DR. CONRAD MURRAY?
9 A YES.
10 Q AND THE DETAI LS OF A. E. G. LI VE' S
11 RELATI ONSHI P WI TH DR. - - MI CHAEL J ACKSON OR THEI R
12 POTENTI AL RELATI ONSHI P WI TH DR. CONRAD MURRAY, THOSE
13 WERE NOT I MPORTANT TO YOUR I NVESTI GATI ON OTHER THAN I N
14 TERMS OF LOOKI NG AT, POTENTI ALLY, THE MONEY, RI GHT?
15 A MONEY AND MOTI VE.
16 Q AND I T WASN' T WHO WAS PAYI NG, I T WAS J UST
17 THE AMOUNT?
18 A DEFI NI TELY THE AMOUNT.
19 Q AND YOU WOULD HAVE HAD THE SAME - - YOU
20 WOULD HAVE HAD THE SAME CONCERNS I F MI CHAEL J ACKSON WAS
21 PAYI NG DR. MURRAY $150, 000 A MONTH DI RECTLY?
22 A YES.
23 Q AND THEN AS FAR AS MS. J ORRI E' S CONCERNED,
24 YOU TOOK A COUPLE OF PAGES OF NOTES FOR - - HOWLONG WAS
25 THE I NTERVI EW?
26 A I ' M GUESSI NG APPROXI MATELY AN HOUR, MAYBE A
27 LI TTLE LONGER.
28 Q AND YOU WEREN' T REALLY FI XATED ON THE

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1 DETAI LS OF THE CONTRACTUAL ARRANGEMENTS BETWEEN
2 MI CHAEL J ACKSON AND DR. MURRAY - - I ' M SORRY - -
3 MI CHAEL J ACKSON AND A. E. G. LI VE?
4 A WE WERE PROVI DED THE CONTRACT, SO I DI DN' T
5 HAVE TO BE TOO I N DEPTH.
6 Q AND AS BETWEEN YOU AND MS. J ORRI E, WHO DO
7 YOU THI NK KNOWS THE MI CHAEL J ACKSON A. E. G. LI VE
8 CONTRACT DETAI LS BETTER?
9 A BETWEEN WHO? I ' M SORRY.
10 Q AS BETWEEN YOU AND MS. J ORRI E, THE DETAI LS
11 OF THE CONTRACT BETWEEN A. E. G. LI VE AND
12 MI CHAEL J ACKSON.
13 A OF COURSE, MS. J ORRI E.
14 MS. BI NA: NOTHI NG FURTHER, YOUR HONOR.
15 THE COURT: ANYTHI NG FURTHER?
16
17 FURTHER REDI RECT EXAMI NATI ON
18 BY MR. PANI SH:
19 Q SI R, THE REASON WHY YOU WERE I NTERVI EWI NG
20 MS. J ORRI E I S BECAUSE I T WAS THE CONTRACT THAT WAS
21 FOUND I N CONRAD MURRAY' S CAR SI GNED BY HI M BY WHI CH YOU
22 BELI EVE WAS AN EXORBI TANT AMOUNT OF MONEY THAT GAVE HI M
23 A MOTI VE FOR WHY HE DI D WHAT HE DI D, RI GHT?
24 A YES.
25 MS. BI NA: OBJ ECTI ON; ASKED AND ANSWERED AT LEAST
26 SI X TI MES TODAY.
27 THE COURT: I T HAS BEEN ASKED AND ANSWERED.
28 SUSTAI NED. WE CAN GO BACK AND FORTH ASKI NG THE SAME

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1 QUESTI ONS, COUNSEL, BUT I DON' T THI NK THAT' S
2 PRODUCTI VE.
3 MR. PANI SH: I ' M GOI NG TO ASK ANOTHER QUESTI ON.
4 THE COURT: ASK A DI FFERENT ONE.
5 MR. PANI SH: OKAY. I WI LL.
6 Q AND, SI R, WHEN YOU WERE I NTERVI EWI NG
7 MS. J ORRI E, I F SHE SAI D SOMETHI NG, WHETHER I T WAS THI S
8 LEG OR THAT LEG OR POTENTI AL, OR MI GHT BE, YOU' D HAVE
9 WRI TTEN THAT DOWN, WOULDN' T YOU, SI R? THAT' S WHAT YOU
10 WERE TRAI NED TO DO?
11 MS. BI NA: OBJ ECTI ON; ASKED AND ANSWERED.
12 THE COURT: THAT ONE WAS ASKED, TOO.
13 MR. PANI SH: SHE J UST ASKED - - ALL RI GHT.
14 Q WHETHER I T WAS I MPORTANT TO YOUR
15 I NVESTI GATI ON OR NOT, LI KE MS. BI NA J UST ASKED YOU, I F
16 SHE TOLD YOU THAT I NFORMATI ON, YOU' D HAVE WRI TTEN I T
17 DOWN, WOULDN' T YOU, SI R?
18 A YES.
19 MR. PANI SH: NOTHI NG FURTHER.
20 MS. BI NA: NOTHI NG FURTHER, YOUR HONOR.
21 THE COURT: THANK YOU. YOU MAY STEP DOWN.
22 THE WI TNESS: THANK YOU, YOUR HONOR.
23 MR. PANI SH: THANK YOU, DETECTI VE. YOU CAN TAKE
24 THAT WATER WI TH YOU.
25 MR. PUTNAM: I WOULD LI KE TO NOTE THE BI AS, YOUR
26 HONOR, GI VI NG HI M WATER AND EVERYTHI NG ELSE.
27 MR. PANI SH: THAT' S A $7 MI LLI ON BOTTLE OF
28 WATER.

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1 THE COURT: ALL RI GHT. TOMORROWAT
2 10: 00 O' CLOCK. TOMORROWAT 10: 00 A. M. I N THE
3 COURTROOM. THANK YOU. I ' LL SEE YOU TOMORROW.
4
5 ( THE FOLLOWI NG PROCEEDI NGS WERE HELD
6 I N OPEN COURT, OUTSI DE THE PRESENCE
7 OF THE J URORS: )
8
9 THE COURT: TOMORROW. WHAT ARE THE WI TNESSES
10 TOMORROW?
11 MR. PANI SH: DR. METZGER.
12 THE COURT: OKAY. WE' RE GOI NG TO GO OVER METZGER
13 BECAUSE HE DI D TESTI FY THROUGH VI DEO ON A LOT OF
14 SUBJ ECTS TODAY.
15 MR. PANI SH: I UNDERSTAND.
16 THE COURT: SO WHAT' S NEW?
17 MR. PANI SH: A LOT ABOUT HI S RELATI ONSHI P - -
18 BECAUSE, SEE, A LOT OF THE QUESTI ONS WERE J UST ASKED,
19 AND THERE WAS NO FOLLOWUP, SO - -
20 MR. BOYLE: ALSO, YOUR HONOR, FI RST OF ALL, WE' VE
21 LOOKED BACK - -
22 THE COURT: THERE WAS CERTAI NLY OPPORTUNI TY.
23 MR. PANI SH: NO, THERE WASN' T.
24 MR. BOYLE: HOLD ON.
25 YOUR HONOR, WE DON' T HAVE A DUTY WHEN WE' RE
26 TAKI NG A DEPOSI TI ON TO ASK EVERY SI NGLE QUESTI ON AT THE
27 DEPOSI TI ON. THERE' S NO DUTY TO EVEN TAKE THE
28 DEPOSI TI ON. THEY NOTI CED THAT DEPOSI TI ON OF

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1 DR. METZGER, THAT' S FI NE. J UST BECAUSE - - WE COULD ASK
2 ZERO QUESTI ONS, AND THEN WHEN HE COMES LI VE AT TRI AL.
3 NOW, THE RECORD I N THI S TRI AL, THE DEFENSE
4 TOLD THE COURT ON THE RECORD THAT THEY WERE GOI NG TO
5 CALL DR. METZGER LI VE, AND WE CAN GET YOU THE CI TATI ON
6 FOR THAT. THEN THEY CHANGED THEI R MI ND, AND NOWWE' RE
7 TRYI NG TO BE STUFFED I NTO THE DEPOSI TI ON. THAT' S NOT
8 HOWI T WORKS.
9 J UST BECAUSE THEY PLAYED HI S DEPOSI TI ON - -
10 THEY SAI D THEY WERE GOI NG TO CALL HI M LI VE, THEY
11 DI DN' T, WE HAVE OTHER QUESTI ONS WE WANT TO ASK
12 DR. METZGER. HE' S GOI NG TO CLARI FY THI NGS THAT HE SAI D
13 I N HI S DEPOSI TI ON.
14 THE COURT: THEN I WANT TO KNOWWHAT.
15 MR. BOYLE: WE HAVE TO TELL THEM EVERYTHI NG THAT
16 WE' RE GOI NG TO ASK THE GUY?
17 THE COURT: I THI NK THI S I S YOUR TI ME BECAUSE I
18 DON' T WANT TO SPENT AN HOUR ON DR. METZGER BECAUSE HE
19 SPENT - -
20 MR. PANI SH: WELL, MS. CHANG I S DOI NG I T.
21 MR. PUTNAM: YOUR HONOR - - MAY I NOTE SOMETHI NG,
22 PLEASE, FOR THE RECORD, YOUR HONOR?
23 YOUR HONOR - -
24 THE COURT: I HOPE YOU DI DN' T THROWA PI ECE OF
25 PAPER LI KE THAT.
26 MR. PANI SH: I T' S I N THE TRASH CAN. I THREWI T
27 I N THE TRASH. I DI DN' T MI SS.
28 THE COURT: I DON' T LI KE TO SEE THAT TYPE OF

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1 AGGRESSI VE BEHAVI OR I N THE COURTROOM.
2 MR. PANI SH: I THREWA PI ECE OF PAPER I N THE
3 TRASH CAN TO MAKE SURE I T MADE I T I N THERE.
4 THE COURT: YES; BUT I T WAS AGGRESSI VE,
5 MR. PANI SH.
6 MR. PANI SH: I HAVE A GOOD FAST BALL. WHAT CAN I
7 SAY?
8 MR. PUTNAM: YOUR HONOR, THEY REPRESENTED TO YOUR
9 HONOR, AS THEY HAD TO I N ORDER TO ARGUE FOR A REOPENI NG
10 OF THE CASE, THAT THEY WERE UNABLE TO GET DR. METZGER
11 FOR 15 WEEKS.
12 REMEMBER, YOU HAVE TO DO THAT BECAUSE YOU
13 CAN' T DO WHAT THEY' RE DOI NG HERE, YOU' RE NOT ALLOWED
14 TO, UNDER THE LAW, WHI CH I S PUT ON A CASE FOR FOUR
15 MONTHS, THREE AND A HALF MONTHS, AND THEN COME I N AND
16 SAY, AFTER DEFENSE HAS GONE, " OH, YOU KNOWWHAT? I
17 WANT TO BRI NG SOMEBODY ELSE THAT I SHOULD HAVE
18 BROUGHT. "
19 YOU HAVE TO REPRESENT TO THE COURT, " I WAS
20 UNABLE TO DO SO, " AND THEY REPRESENTED TO YOU THEY WERE
21 UNABLE TO GET HI M. WHAT WE J UST HEARD I S NO, NO, THAT
22 WASN' T WHAT HAPPENED. WHAT HAPPENED I S WE THOUGHT THEY
23 WERE GOI NG TO CALL HI M LI VE, SO WHEN THEY DI DN' T, WE
24 DECI DED TO DO SO.
25 THAT I S, AGAI N, AN I MPROPER REOPENI NG, YOUR
26 HONOR; AND I THI NK WHAT YOU' RE DOI NG HERE, YOUR HONOR,
27 I S EXACTLY THE PROPER THI NG, WHI CH I S TO HEAR EXACTLY
28 WHAT THEY' RE CALLI NG HI M FOR AND WHY BECAUSE THEY HAD

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1 AMPLE OPPORTUNI TY TO DO SO I N THEI R CASE I N CHI EF AND
2 CHOSE NOT TO DO SO.
3 MR. BOYLE: YOUR HONOR, I ' M NOT CHANGI NG THE
4 STORY. MS. CHANG WAS I N THE COURTROOM AND TOLD ABOUT
5 HER EFFORTS TO GET DR. METZGER. I WAS J UST ADDI NG THE
6 ADDI TI ONAL POI NT ABOUT WHY WE SHOULDN' T HAVE TO BE
7 STUCK WI TH THE DEPOSI TI ON BECAUSE THEY WERE GOI NG TO
8 CALL HI M LI VE, TOO, WHEN THEY GOT TO THEI R CASE.
9 THAT DI DN' T END UP HAPPENI NG, NOWWE' RE - -
10 WE' RE BEI NG PUNI SHED FOR NOT ASKI NG CERTAI N QUESTI ONS
11 I N THE DEPOSI TI ON THAT WAS HOWEVER MANY MONTHS AGO.
12 THAT' S J UST NOT HOWI T WORKS.
13 THE COURT: I ' M NOT PUNI SHI NG ANYBODY. WHAT I
14 WANT TO KNOWI S WHAT I S I T THAT YOU' RE GOI NG TO ASK HI M
15 ABOUT NOWI N REBUTTAL THAT HASN' T BEEN COVERED I N THE
16 DEPOSI TI ON? BECAUSE WE HEARD AN HOUR AND 20 MI NUTES
17 TODAY, AND I T - - THAT WAS I N ADDI TI ON TO WHAT WE HEARD
18 A WEEK AND A HALF AGO.
19 MR. PANI SH: THEY PLAYED I T.
20 THE COURT: I UNDERSTAND THAT. BUT I T WAS
21 DESI GNATI ONS AND COUNTER DESI GNATI ONS. SO I WANT TO
22 KNOWWHAT WASN' T COVERED THAT YOU' RE GOI NG TO COVER
23 NOW.
24 MR. BOYLE: HE' S GOI NG TO CLARI FY CERTAI N
25 THI NGS.
26 THE COURT: BE SPECI FI C.
27 MR. BOYLE: I AM.
28 ABOUT DOCTOR SHOPPI NG, FOR EXAMPLE. I N THE

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1 DEPOSI TI ON, HE WAS - -
2 THE COURT: HE DI D REFER TO THAT.
3 MR. BOYLE: AND VARI OUS DOCTORS WERE LI STED, HE
4 WAS ASKED I F HE KNEWVARI OUS DOCTORS, I NSI NUATI NG TO
5 HI M THAT THESE WERE DOCTORS THAT TREATED
6 MI CHAEL J ACKSON. FOR EXAMPLE, DR. SLAVI T.
7 WHEN - - WHEN HE WAS ASKED THAT QUESTI ON,
8 DR. METZGER DI D NOT KNOWTHAT DR. SLAVI T WAS THE
9 A. E. G. - HI RED I NSURANCE DOCTOR, NOT A TREATI NG DOCTOR,
10 AND SO WE HAVE TO POI NT ALL THAT OUT, " SO WHEN THI S
11 LI ST OF DOCTORS WERE READ TO YOU, YOU DI DN' T KNOWTHAT
12 THEY WERE NOT ACTUALLY DOCTORS WHO TREATED MI CHAEL?"
13 WE' D LI KE TO CLEAR THAT UP BECAUSE THAT
14 CAME ACROSS AS MI SLEADI NG AND NOT WHAT - - THAT WAS A
15 CLEVER DEPOSI TI ON READ THAT GOT PLAYED AT TRI AL, BUT
16 DR. METZGER SHOULD BE ABLE TO COME I N AND SAY, " WELL, I
17 DI DN' T KNOWTHOSE WEREN' T TREATI NG DOCTORS. "
18 THEY COULD HAVE SAI D, " WHAT ABOUT
19 DR. BOB SMI TH? DR. SO AND SO?"
20 THE COURT: DR. TABRI ZI , DR. TRACY.
21 MR. PANI SH: EXACTLY.
22 THE COURT: I GUESS - - MY QUESTI ON WOULD BE WHY
23 DI DN' T YOU ASK HI M AT THE DEPO?
24 MR. BOYLE: BECAUSE I DI DN' T KNOWWHO THOSE
25 PEOPLE WERE AT THE DEPO.
26 MR. PANI SH: WHEN YOU TAKE A DEPOSI TI ON OF A
27 TREATI NG DOCTOR, YOU HAVE NO OBLI GATI ON TO ASK ANY
28 QUESTI ONS. WE NEVER ASK QUESTI ONS, VERY RARELY, OF A

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1 PHYSI CI AN THAT' S LOCATED I N THE AREA. WE DON' T ASK
2 QUESTI ONS OF OUR OWN DOCTORS, GENERALLY.
3 HE ASKED A FEWQUESTI ONS, BUT THERE' S NO
4 RESPONSI BI LI TY OR OBLI GATI ON FOR SOMEONE TO QUESTI ON I N
5 A DEPOSI TI ON AND THEN FOR THE COURT TO SAY I F THE
6 DEFENDANT - -
7 THE COURT: THEN WHY DI DN' T YOU CALL HI M I N YOUR
8 CASE?
9 MR. BOYLE: MS. CHANG WAS TRYI NG TO, WE ALREADY
10 WENT THROUGH THI S ABOUT HER EFFORTS AND NOT GETTI NG
11 HI M. HE WAS OUT OF THE COUNTRY.
12 MR. PANI SH: YOU ALLOWED US TO REOPEN, WE WANTED
13 TO CALL HI M THEN, YOU GO NO, LET THEM PLAY THE DEPO,
14 THEN YOU CAN CALL HI M AFTER. SO YOU DI DN' T ALLOWUS TO
15 CALL HI M. HE WANTED TO CALL HI M FI RST, YOU SAI D NO,
16 THEY PLAYED THE DEPO FI RST.
17 SO NOWWE' RE TRYI NG TO BE SHOEHORNED I NTO
18 THE FACT THAT THE COURT ALLOWED THE DEPOSI TI ON AND SO
19 NOWWE' RE FORECLOSED ON AREAS THAT ARE NOT - - THAT ARE
20 ALLEGEDLY CUMULATI VE ON AN EXPERT - - HE' S GOI NG TO TALK
21 ABOUT, FOR EXAMPLE, DR. STOLL - - THEY' RE J UST TRYI NG TO
22 FI SH OUT EVERYTHI NG. THAT' S WHAT I T I S.
23 THE COURT: DR. STOLL. WHAT ELSE? DOCTOR
24 SHOPPI NG?
25 MR. BOYLE: HE WAS ASKED QUESTI ONS ABOUT
26 DR. STOLL, AND MY UNDERSTANDI NG I S THAT HE HAS - -
27 MR. PANI SH: HE' S GOI NG TO TALK ABOUT OTHER
28 EVENTS ON TOURS THAT HE WAS I NVOLVED I N. THEY DI DN' T

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1 GET I NTO EVERYTHI NG ON THE TOURS. HE' S GOI NG TO TALK
2 ABOUT OTHER EXAMI NATI ONS, WORK THAT HE' S DONE ON OTHER
3 TOURS, ABOUT THE OTHER PEOPLE I NVOLVED.
4 THERE' S A LOT OF THI NGS THAT HE' S GOI NG TO
5 TALK ABOUT THAT WERE NOT COVERED I N THE DEPOSI TI ON.
6 EVEN THOUGH I DI SAGREE WI TH YOU THAT NOWWE CAN BE
7 PENALI ZED I F WE ASK A QUESTI ON THAT THEY DI DN' T I N THE
8 DEPOSI TI ON, I BELI EVE THAT THE TESTI MONY WI LL NOT BE
9 THE SAME QUESTI ONS I N THE DEPOSI TI ON, BUT MORE
10 EXPANSI VE OF WHAT OCCURRED.
11 THAT WAS ALL MR. PUTNAM' S QUESTI ONI NG, BUT
12 FOR TWO PAGES OR THREE PAGES BY MR. BOYLE. ALL THE
13 QUESTI ONI NG WAS DONE BY MR. PUTNAM, NOT BY PLAI NTI FFS'
14 COUNSEL, I N THE DEPOSI TI ON; AND I T WOULD BE UNFAI R THAT
15 BECAUSE WE COUNTER DESI GNATED QUESTI ONS THAT HE ASKED,
16 THAT WE CAN' T CALL THE WI TNESS AND ASK SPECI FI C
17 QUESTI ONS.
18 THE COURT' S ALREADY MADE A FI NDI NG THAT WE
19 CAN REOPEN AS TO DR. METZGER. THEY WANT TO KEEP
20 REVI SI TI NG THAT.
21 THE COURT: EVEN I F I DI D, I DON' T WANT TO - -
22 MR. PANI SH: YOU DI D. I ' LL GET THE TRANSCRI PT.
23 THE COURT: EVEN I F I DI D, I DON' T WANT TO SPEND
24 THREE HOURS LI STENI NG TO DR. METZGER ON I SSUES THAT ARE
25 J UST GOI NG TO BE CUMULATI VE. THAT' S MY POI NT.
26 MR. PANI SH: I UNDERSTAND YOUR POI NT, AND WE
27 DON' T I NTEND TO DO I T. J UST LI KE THI S WI TNESS. OKAY?
28 THEY SAI D I T' S ALL CUMULATI VE. I T WASN' T, I T WAS

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1 DI RECTED SPECI FI CALLY TO AN AREA, I T WAS TOTALLY
2 PROPER. OKAY? THEY WANTED ME TO HAVE TO GO THROUGH
3 THI S, I T WAS TOTALLY APPROPRI ATE.
4 MS. BI NA: YOUR HONOR, I WOULD NOTE FOR THE
5 RECORD I THI NK I T ACTUALLY WAS CUMULATI VE. THEY ASKED
6 MAYBE THREE MI NUTES OF QUESTI ONS ON MS. J ORRI E AND THE
7 REST WAS AN ATTEMPT TO GET I N FRONT OF THE J URY AGAI N,
8 " OH, THE POLI CE THI NK HE WAS MOTI VATED BY THE CONTRACT
9 WI TH A. E. G. LI VE" UNDER THE GUI SE OF BACKGROUND.
10 AND MS. J ORRI E' S TESTI MONY WASN' T EVEN
11 REALLY I MPEACHMENT, THE WI TNESS ADMI TTED HE HAD NO
12 REASON TO BELI EVE WHAT SHE SAI D WASN' T A TRUTHFUL
13 CHARACTERI ZATI ON OF WHAT HE TOLD HER.
14 MR. PANI SH: COME ON.
15 MS. BI NA: SO THE POI NT BEI NG, YOUR HONOR, I T WAS
16 A PRETEXT TO BRI NG I N ON I MPEACHI NG MS. J ORRI E.
17 MR. PANI SH: NO.
18 MS. BI NA: AND I T WAS VERY CUMULATI VE AND GOT
19 BACK I N ALL THI S FI NANCI AL STUFF.
20 MR. BOYLE: THAT' S A NI CE SPI N ON I T, YOUR HONOR,
21 BUT NOT TRUE.
22 MS. CAHAN: WI TH RESPECT TO DR. METZGER, I ' M
23 TRYI NG TO WRI TE DOWN A LI ST. SO I ' VE HEARD CLARI FYI NG
24 THE DOCTOR SHOPPI NG. AND J UST TO BE CLEAR, DR. METZGER
25 GAVE TWO DEPOSI TI ONS, ONE I N THE I NSURANCE CASE, WHI CH
26 PLAI NTI FFS SOUGHT AND OBTAI NED AND NOWWAS PRODUCED I N
27 DI SCOVERY I N THI S CASE PER THE ORDER OF THE COURT I N
28 THE I NSURANCE CASE.

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1 SO WE HAVE THAT DEPOSI TI ON, AND BETWEEN
2 THAT DEPOSI TI ON AND THE DEPOSI TI ON HE GAVE I N THI S
3 CASE, HE SAI D MI CHAEL WAS A DOCTOR SHOPPER SI X TI MES.
4 THAT WAS ONE OF THE THI NG I COUNTED UP YESTERDAY.
5 MR. PANI SH: WHAT' S THE DEFI NI TI ON OF I T?
6 MS. CAHAN: I T' S NOT J UST AN I SSUE - -
7 THE COURT: COMES AS NO SURPRI SE.
8 MS. CAHAN: I ' M HAPPY TO CROSS ON THAT. I HEARD
9 THAT, I HEARD DR. STOLL, AND THEN WE WENT I NTO A VERY
10 VAGUE CATEGORI ZATI ON OF OTHER EVENTS ON TOURS.
11 THE COURT: SUCH AS - -
12 MR. PANI SH: OTHER TOURS HE WAS ON, OTHER - -
13 " HI STORY. "
14 MS. CAHAN: HE WAS ONLY I N AUSTRALI A ON THE
15 " HI STORY" TOUR, AND THAT WAS TESTI FI ED TO I N THE
16 DEPOSI TI ON WE WATCHED TO.
17 MR. PANI SH: I T WASN' T EXTENSI VELY - - THERE WAS
18 TWO QUESTI ONS ON I T.
19 THE COURT: WHAT ARE THEY? " HI STORY" AND - -
20 MR. PANI SH: " HI STORY, " AND HE HAD SOME
21 I NVOLVEMENT WI TH DI SCUSSI ONS OF PEOPLE ON THE
22 " DANGEROUS" TOUR.
23 THE COURT: HE WASN' T ON I T BUT WOULD TALK TO
24 PEOPLE?
25 MR. PANI SH: YES, YES. I DON' T THI NK HE WAS ON
26 I T.
27 MS. BI NA: HE TESTI FI ED I N THE VI DEO THAT WE
28 WATCHED THAT HE SPOKE TO DR. FI NKELSTEI N I N THAT ONE

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1 TREATMENT TI ME I N BANGKOK.
2 THE COURT: BUT HE WASN' T ACTUALLY THERE.
3 MS. CAHAN: HE DI D NOT GO ON THAT TOUR.
4 MR. PANI SH: HE GAVE ONE SENTENCE. HE CAN
5 EXPAND. THERE ARE A LOT OF AREAS - -
6 MR. PUTNAM: WHAT ARE THEY?
7 THE COURT: WHAT ELSE? J UST - -
8 MR. PANI SH: WE' RE KI ND OF AT A LOSS BECAUSE WE
9 DON' T KNOWEVERYTHI NG. BUT I ' M GOI NG TO SAY THAT - -
10 THE COURT: MR. PANI SH, THI S I S THE TI ME TO KNOW.
11 WHEN ARE YOU GOI NG TO KNOW? I T' S THE LAST DAY OF
12 TRI AL.
13 MR. PANI SH: FI RST OF ALL, MS. CHANG - -
14 MR. BOYLE: NO.
15 I DON' T THI NK I T' S GOI NG TO TAKE THREE
16 HOURS, FI RST OF ALL. I THI NK WE' RE GETTI NG - - WE' RE
17 GOI NG TO ASK THE QUESTI ONS, THEY' LL OBJ ECT I F THEY
18 THI NK I T' S CUMULATI VE. I T' S NOT GOI NG TO BE - - I MEAN,
19 SHE' S GOI NG TO ASK DI FFERENT QUESTI ONS THAN WERE ASKED
20 AT DEPO.
21 MR. PANI SH: ONE OTHER ONE WAS ABOUT THE " EARTH
22 SONG" AND THE MAKI NG OF THE " EARTH SONG" AND HI S
23 I NVOLVEMENT I N THAT. THAT' S ANOTHER THI NG HE' S GOI NG
24 TO TALK ABOUT.
25 MS. CAHAN: WHAT I S THAT RELEVANT TO?
26 THE COURT: HOWI S THAT RELEVANT, " EARTH SONG"
27 AND DR. METZGER' S I NVOLVEMENT? HOWI S HE I NVOLVED I N
28 THAT?

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1 MR. PANI SH: THEY' RE TRYI NG TO MAKE OUT THI S
2 THI NG, AND ALSO ABOUT HI S FAMI LY VI SI TS AND OTHER
3 RELATI ONSHI PS WI TH MI CHAEL J ACKSON, AND THEY' RE TRYI NG
4 TO MAKE HE' S HI S BEST FRI END AND DOES ALL THI S WI TH
5 DOCTORS. WERE THERE ANY QUESTI ONS ASKED ABOUT WHETHER
6 HE TRI ED TO TAKE ADVANTAGE OF THAT FRI ENDSHI P? NO.
7 WERE THERE QUESTI ONS ABOUT WHO WENT TO
8 MI CHAEL' S HOUSE, WAS I T HI M, WAS I T SOMEONE I N HI S
9 FAMI LY? HE HAS A RI GHT TO EXPAND ON THAT BECAUSE
10 YOU' VE THEY' VE BEEN MAKI NG A BI G DEAL ABOUT THAT I N
11 THI S CASE. I MEAN - -
12 MR. PUTNAM: SO " EARTH SONG, " YOU ASKED THE
13 QUESTI ON, AND I HAVEN' T HEARD THE ANSWER. WHAT I S THE
14 RELEVANCE OF " EARTH SONG" ?
15 MR. PANI SH: MAYBE I T' S " WE ARE THE WORLD. "
16 MR. PUTNAM: I ' M SORRY. WHAT' S THE RELEVANCE?
17 MR. PANI SH: WE' LL SEE WHEN WE GET TO I T.
18 THE COURT: NO. THI S I S THE TI ME, MR. PANI SH.
19 THI S I S THE TI ME.
20 MR. PANI SH: CAN I HAVE FI VE MI NUTES?
21 THE COURT: I F YOU DON' T KNOW, THEN LET' S BRI NG
22 MS. CHANG.
23 MR. PANI SH: THAT' S FI NE.
24 MS. CAHAN: YOUR HONOR, A REPRESENTATI ON WAS
25 MADE, AS YOU REMEMBER, ON THE REPORTED CALL YESTERDAY
26 BY MR. BOYLE THAT HE WAS NOT PREPARI NG THI S
27 EXAMI NATI ON, MS. CHANG WAS, BUT EI THER SHE WOULD BE I N
28 COURT THI S MORNI NG OR HE WOULD BE UP TO SPEED.

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1 MR. BOYLE: I DI DN' T KNOWEXACTLY WHAT QUESTI ONS
2 I WAS GOI NG TO BE ASKED.
3 THE COURT: OKAY. WHAT I ' VE HEARD, AT MOST HALF,
4 AN HOUR.
5 MR. PANI SH: NO, NO.
6 THE COURT: FROM WHAT I ' VE HEARD.
7 MR. PANI SH: CAN WE GI VE THEM A LI ST OF THE OTHER
8 THI NGS?
9 MR. PUTNAM: SHE WAS SUPPOSED TO BE HERE TODAY TO
10 LET US KNOW, YOUR HONOR.
11 THE COURT: THAT' S ALL I HEAR.
12 MR. PANI SH: CAN WE WAI T FI VE MI NUTES TO HAVE
13 MS. CHANG CALL AND LAY OUT FOR YOU MORE OF THE THI NGS?
14 THE COURT: I T' S 4: 35.
15 MR. PANI SH: FOR THE RECORD, SHOULD WE SEND THEM
16 ANY ADDI TI ONAL AREAS WE I NTEND TO I NQUI RE, OR NO? I ' M
17 ASKI NG THAT BECAUSE I ' M GOI NG TO MAKE THE RECORD I N THE
18 MORNI NG.
19 THE COURT: TALK TO THEM, THEY MAY - - THEY MAY
20 AGREE, THEY MAY NOT.
21 MR. PANI SH: THEY' RE NOT GOI NG TO AGREE TO
22 ANYTHI NG. YOU KNOWTHAT. THEY HAVEN' T AGREED TO ONE
23 SI NGLE THI NG YET.
24 MS. BI NA: YOUR HONOR, WE HAD THREE STI PULATI ONS
25 THI S MORNI NG.
26 THE COURT: I THI NK THE I DEA I S PREPARATI ON. I F
27 THEY DON' T HAVE TI ME BECAUSE YOU DON' T TELL THEM AHEAD
28 OF TI ME, HOWCAN THEY PREPARE THEI R EXAMI NATI ON?

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1 MR. BOYLE: OKAY. I CAN TELL YOU - - I CAN GI VE
2 YOU MORE NOW, YOUR HONOR. HE' S GOI NG TO CLARI FY ANY
3 CONFUSI ON REGARDI NG THE GERMAN DOCTORS AND ANY
4 DI SPARI TY BETWEEN DEBBI E ROWE TESTI MONY AND HI S OWN
5 DEPOSI TI ON TESTI MONY.
6 THE COURT: DI SCREPANCY BETWEEN ROWE AND - -
7 MR. PANI SH: BECAUSE YOU LET I N HEARSAY
8 STATEMENTS OF OTHERS THAT SAI D THEY THOUGHT HE HAD A
9 DEMEROL PROBLEM. OKAY? NOWI REMEMBER.
10 THE COURT: I DON' T KNOWABOUT LETTI NG I N ANY
11 HEARSAY STATEMENTS. THAT MI GHT BE YOUR SPI N, BUT I ' M
12 NOT ADMI TTI NG TO LETTI NG I N ANY HEARSAY STATEMENTS.
13 MR. PANI SH: YOU ALLOWED DR. METZGER, OVER OUR
14 OBJ ECTI ON, WE ARGUED I T, TO TESTI FY THAT HE HAD
15 I NFORMATI ON FROM MS. ROWE FROM ARNI E KLEI N ABOUT THI S
16 ALLEGED DEMEROL PROBLEM, AND FROM THE MEDI A. OKAY?
17 YOU - - WE OBJ ECTED, YOU ALLOWED THAT TESTI MONY.
18 THE COURT: YOU' RE TALKI NG ABOUT I N THE
19 DESI GNATI ONS?
20 MR. BOYLE: WE' RE TALKI NG ABOUT SOMETHI NG ELSE.
21 HE' S CONFUSED. THAT' S NOT RI GHT.
22 MR. PUTNAM: THAT' S NOT WHAT HAPPENED.
23 MR. PANI SH: NO.
24 THE COURT: MR. BOYLE SAYS YOU' RE CONFUSED,
25 MR. PANI SH.
26 MR. BOYLE: YOU ARE.
27 DI SPARI TY I N THE GERMAN I SSUE, I T' S GOI NG
28 TO TALK ABOUT I SSUES OF ROLES HE WAS NOT ASKED ABOUT I N

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1 HI S DEPOSI TI ON REGARDI NG HI S ROLE ON THE " HI STORY"
2 TOUR.
3 THE COURT: " HI S" MEANI NG METZGER' S ROLE?
4 MR. BOYLE: CORRECT.
5 HE' S GOI NG TO TALK ABOUT I SSUES NOT RAI SED
6 I N HI S DEPOSI TI ON ABOUT CERTAI N TREATMENTS OF
7 MR. J ACKSON OVER THE YEARS.
8 THE COURT: HE' S TREATED HI M 30 YEARS.
9 MS. CAHAN: HOWI S THAT RELEVANT?
10 MR. PANI SH: BECAUSE YOU' RE LETTI NG I N. - -
11 THE COURT: MR. PANI SH, I ' M NOT ADDRESSI NG YOU,
12 PLEASE. MR. BOYLE I S ON THE J OB. LET HI M FI NI SH.
13 MR. BOYLE: HE' S GOI NG TO - -
14 THE COURT: THE SPECI FI CS. METZGER HAS TREATED
15 HI M 30 YEARS. WHEN YOU SAY TREATMENTS OF METZGER,
16 THAT' S A LOT OF TREATMENTS. YOU NEED TO BE MORE
17 SPECI FI C. ADDI CTI ON? NUTRI TI ON? EXERCI SE? WHAT ARE
18 YOU TALKI NG ABOUT?
19 MR. BOYLE: I ' LL FI ND OUT ON THAT. ALL I KNOWI S
20 THEY' RE I SSUES NOT ASKED ABOUT I N THE DEPOSI TI ON.
21 MS. CAHAN: BECAUSE THEY' RE I RRELEVANT.
22 MR. PANI SH: TO THE MEDI CAL RECORDS, YOU ALLOWED
23 THEM TO GO BACK 30 YEARS I N PUTTI NG ON EVI DENCE OF HI S
24 MEDI CAL CONDI TI ON.
25 MR. PUTNAM: I WENT THROUGH EVERY PAGE OF THE
26 MEDI CAL RECORDS THAT WERE PROVI DED TO US, YOUR HONOR,
27 AND THAT' S WHAT YOU SAW.
28 MR. PANI SH: HE READ THEM I N. THERE WAS NO

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1 EXPLANATI ON. WE CAN ASK, " WHAT DI D YOU MEAN BY THI S, "
2 THI NGS HE DI DN' T ASK.
3 MR. PUTNAM: I F YOU RECALL, YOUR HONOR, THEY
4 WI THHELD LARGE PORTI ONS SAYI NG I T WASN' T RELEVANT - -
5 MR. PANI SH: WE DI DN' T - -
6 MR. PUTNAM: CAN I FI NI SH SPEAKI NG, PLEASE?
7 MR. PANI SH: WELL, TELL THE TRUTH.
8 MR. PUTNAM: HOWWOULD YOU KNOWWHAT THE TRUTH
9 I S?
10 MR. PANI SH: BECAUSE WE DI DN' T WI THHOLD ANY
11 RECORDS. I T WAS THE ESTATE.
12 THE COURT: MR. PANI SH - -
13 MR. PANI SH: I T WAS THE ESTATE. WE HAVE NO
14 RECORDS.
15 THE COURT: MR. PANI SH, YOU' RE TALKI NG OVER ME
16 AND YOU' RE RAI SI NG YOUR VOI CE UNNECESSARI LY.
17 MR. PUTNAM: THANK YOU, YOUR HONOR.
18 SO AS YOU RECALL, THEY ONLY HANDED OVER TO
19 US THE RECORDS THAT THEY DETERMI NED WERE RELEVANT, THE
20 ESTATE KEPT EVERYTHI NG ELSE.
21 AS YOU SAW, THEY WERE REPRESENTI NG HI M I N
22 THI S, AND I READ THROUGH EVERY SI NGLE PAGE OF WHAT THEY
23 HANDED OVER TO US, SO I F WHAT THEY' RE TALKI NG ABOUT ARE
24 TALKI NG ABOUT MEDI CAL RECORDS THAT WERE WI THHELD FROM
25 US, AND WE WERE NEVER ALLOWED TO SEE BEFORE, I THI NK
26 THAT' S WHOLLY I NAPPROPRI ATE, YOUR HONOR.
27 MR. PANI SH: WE DI DN' T WI THHOLD ANY RECORDS. WE
28 GOT THEM WHEN THEY GOT THEM. THE ESTATE, WHO I S NOT A

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1 PARTY TO THI S, HAS TAKEN DI FFERENT I NTERESTS TO US, I S
2 THE ONE THAT WAS THE GATEKEEPER, AND YOU REMEMBER
3 THAT.
4 THE COURT: YES.
5 MR. PANI SH: AND THEY WERE COMMUNI CATI NG MORE
6 WI TH THEM THAN WI TH US, SO WE DI DN' T WI THHOLD
7 ANYTHI NG.
8 MR. PUTNAM: I NEVER SAI D THEY WI THHELD I T, YOUR
9 HONOR.
10 MR. PANI SH: HE SAI D, " THEY WI THHELD. " COME
11 ON.
12 THE COURT: MR. BOYLE - -
13 MR. BOYLE: HE' S ALSO GOI NG TO TALK ABOUT HI S - -
14 THI NGS NOT ASKED I N THE DEPOSI TI ON REGARDI NG
15 COMMUNI CATI ONS HE HAD WI TH CEDARS- SI NAI REGARDI NG - - I N
16 2009 REGARDI NG THE " THI S I S I T" TOUR.
17 MR. PANI SH: I F YOU REMEMBER, THAT WAS ASKED - -
18 THE COURT: BEFORE MR. J ACKSON' S DEATH?
19 MR. BOYLE: YES, BEFORE.
20 MS. CAHAN: I N THE VI DEO HE SAI D HE CALLED
21 SOMEBODY AT CEDARS. THI S I S ALL I N THE DEPOSI TI ON. HE
22 CALLED THE HEAD OF THE ANESTHESI OLOGY AT CEDARS AND
23 ASKED HI M I F HE KNEWANYBODY I N LONDON, AND TALKED TO
24 HI M ABOUT WHAT COULD BE SAFE I NTRAVENOUS SLEEP
25 MEDI CATI ONS AND WHAT WOULDN' T BE. THAT WAS ALL I N THE
26 DEPOSI TI ON.
27 MOST OF I T GOT PLAYED. TO THE EXTENT OTHER
28 STUFF WASN' T PLAYED, WE CERTAI NLY DI DN' T SEEK TO KEEP

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1 I T OUT. I F PLAI NTI FFS DI DN' T CHOOSE TO COUNTER
2 DESI GNATE I T, I DON' T KNOWWHY.
3 MR. BOYLE: I T WASN' T ASKED I N THE DEPOSI TI ON.
4 MR. PANI SH: ABOUT THE DI SCOI D LUPUS, WHAT I T I S,
5 WHAT EFFECTS I T HAS, WHAT' S THE RELATI ONSHI P WI TH THE
6 PAI N AND HOWI T AFFECTED MR. J ACKSON. NONE OF THAT WAS
7 ASKED. WHAT I S DI SCOI D LUPUS, THAT WASN' T ASKED. HE' S
8 A RHEUMATOLOGI ST.
9 MR. PUTNAM: HE TOLD US WHAT I T WAS LAST TI ME HE
10 WAS - - NOT TODAY BUT - - HE WENT THROUGH, SAI D WHAT I T
11 WAS, WHAT THE PAI N WAS, HE WENT THROUGH ALL OF THAT.
12 THE COURT: I KNOWWE HEARD I T SOMEWHERE.
13 MR. PANI SH: I T WAS MS. ROWE THAT TALKED ABOUT
14 I T.
15 MS. CAHAN: I REREAD BOTH DEPOSI TI ONS I N THI S
16 CASE, AND THE OTHER CASE, AND HI S CRI MI NAL TRI AL
17 TESTI MONY FROM THE DR. MURRAY CASE YESTERDAY, SO I ' M
18 QUI TE FAMI LI AR. I KNOWTHAT HE TESTI FI ED TO THI S I N
19 HI S DEPOSI TI ON, AND I BELI EVE I T WAS PLAYED.
20 MR. PANI SH: I T WAS NOT PLAYED, NUMBER 1.
21 NUMBER 2, THE I NSURANCE COMPANY DEPOSI TI ON, WE WEREN' T
22 EVEN THERE. WE HAD NO I NVOLVEMENT I N THAT. YOU RULED
23 THAT THE I NTERESTS WERE COMPLETELY DI FFERENT AND WE
24 COULDN' T PLAY THE TESTI MONY FROM THAT. SO NOWTHEY' RE
25 TRYI NG TO PUT THAT ON US.
26 AND THE CRI MI NAL CASE, WE WEREN' T ASKI NG
27 ANY QUESTI ONS THERE, WE WEREN' T THERE. A. E. G. WAS
28 THERE, WE WEREN' T THERE.

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1 MR. PUTNAM: YOUR HONOR, WE WERE NOT THERE.
2 THAT' S, AGAI N, MI SREPRESENTI NG.
3 MR. PANI SH: YOU WERE THERE.
4 MR. PUTNAM: I WASN' T THERE.
5 MR. PANI SH: YOU WERE THERE MANY TI MES.
6 THE COURT: MR. BOYLE?
7 MR. BOYLE: THAT' S I T.
8 MR. PANI SH: YOU WERE THERE MANY TI MES.
9 MR. PUTNAM: I WASN' T.
10 MR. PANI SH: YOU WERE.
11 MS. CAHAN: SO THE FI RST I S TO CLARI FY THE DOCTOR
12 SHOPPI NG WI TH RESPECT TO THE LI ST OF DOCTORS WHO WERE
13 TREATI NG PHYSI CI ANS, AND WHAT THAT MI GHT MEAN THAT WE
14 HEARD TODAY; THE SECOND I S ADDRESSI NG THE DI SCREPANCY
15 BETWEEN HI S TESTI MONY AND MS. ROWE' S TESTI MONY WI TH
16 RESPECT TO DR. STOLL AND THE GERMAN DOCTORS; THE THI RD
17 I S HI S ROLE ON THE " HI STORY" TOUR, I NCLUDI NG WHEN HE
18 WAS PHYSI CALLY PRESENT I N AUSTRALI A AND HI S ROLE ON THE
19 " DANGEROUS" TOUR, THI NGS THAT WERE NOT ASKED AT
20 DEPOSI TI ON; THE HI STORY OF MEDI CAL - - HI S HI STORY OF
21 MR. J ACKSON' S MEDI CAL TREATMENT, I DON' T THI NK WE' VE
22 GOTTEN AN ANSWER ON THAT EXCEPT FOR DI SCOI D LUPUS,
23 WHI CH WAS ALREADY TESTI FI ED TO.
24 THE COURT: WHAT SPECI FI C ABOUT THAT?
25 MR. BOYLE: YOUR HONOR, I ' M SORRY. I ASKED
26 MS. CHANG TO SEND ME A LI ST, AND THAT' S WHY I WAS
27 UNPREPARED. SHE SENT ME THE LI ST, I ' M TRYI NG TO GET
28 HER TO CLARI FY WHAT SHE MEANS ON THE HI STORY OF

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1 MEDI CAL.
2 MR. PANI SH: HI S RELATI ONSHI P WI TH
3 MI CHAEL J ACKSON.
4 MS. CAHAN: AND THE COMMUNI CATI ONS WI TH CEDARS I N
5 2009 REGARDI NG " THI S I S I T. " ALSO RELATI ONSHI P WI TH
6 MR. J ACKSON.
7 MR. PANI SH: THAT' S GENERALLY I T.
8 MS. CAHAN: WHATEVER THAT MEANS. PERSONAL
9 RELATI ONSHI P, I ASSUME, ALTHOUGH THAT WAS ALSO
10 EXTENSI VELY COVERED I N THE DEPOSI TI ON.
11 MR. PUTNAM: HE WAS GREAT WI TH HI S CHI LDREN, HE
12 SAWHI M WI TH HI S CHI LDREN - -
13 THE COURT: I S THERE SOMETHI NG MORE THAN THAT.
14 MR. PANI SH: YES, THERE I S, AS TO HI S
15 I NVOLVEMENT, DI D HE GO TO NEVERLAND. THEY' RE MAKI NG
16 THI S BI G CASE. DI D SOMEBODY ELSE VI SI T, HI S FAMI LY.
17 THEY MADE A BI G DEAL I N THI S CASE ABOUT THAT. YOU' VE
18 ALLOWED TWO WI TNESSES TO TESTI FY ABOUT THAT, THEY' VE
19 PLAYED SEVEN DEPOSI TI ONS ON THOSE I SSUES.
20 THE COURT: ALL RI GHT. YOU CAN ASK ABOUT THAT.
21 MR. BOYLE: THAT' S I T.
22 THE COURT: BUT THAT WHOLE CATEGORY ABOUT MEDI CAL
23 TREATMENT OVER 30 YEARS, YOU' VE GOT TO NAI L THAT
24 DOWN.
25 MR. BOYLE: I WI LL NAI L THAT DOWN.
26 THE COURT: AND YOU' VE GOT TO COMMUNI CATE WI TH
27 MS. CAHAN WHAT THAT' S ABOUT. I F SHE HAS SOME
28 OBJ ECTI ONS I N THE MORNI NG ABOUT I T, I MAY EXCLUDE THAT.

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1 BUT FROM WHAT I HEAR, YOU' VE GOT ABOUT AN HOUR THERE.
2 MR. PANI SH: WE' LL TRY TO SPEED I T UP AS FAST AS
3 WE CAN.
4 THE COURT: YOU' VE GOT AN HOUR - -
5 MR. BOYLE: THAT' S WHAT I KI ND OF ALWAYS THOUGHT.
6 I WAS SAYI NG I WAS HOPI NG WE CAN FI NI SH BY LUNCH.
7 THE COURT: ALL RI GHT. SEE YOU TOMORROW.
8 MR. PANI SH: OH, YOUR HONOR, WE CAN TAKE THI S UP
9 TOMORROW. WE FI LED A DI RECTED VERDI CT MOTI ON.
10 THE COURT: YOU DI D, YES.
11 MR. PANI SH: SO WE CAN DEAL WI TH I T TOMORROWON
12 THE I SSUE OF THE SUPPORT TO ANY EXTENT, AND WE' LL DEAL
13 WI TH THAT, THEY CAN RESPOND, OR - -
14 MS. BI NA: I DON' T THI NK WE' VE SEEN I T YET, SO - -
15 MR. PUTNAM: I T WASN' T ACTUALLY FI LED.
16 MR. PANI SH: I T J UST HAPPENED. WE' LL GI VE YOU A
17 COPY NOW. WE CAN DEAL WI TH THAT TOMORROW. I J UST
18 WANTED TO TELL YOU THAT.
19
20 ( PROCEEDI NGS ADJ OURNED TO THURSDAY,
21 SEPTEMBER 19, 2013, AT 10: 00 A. M. )
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