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Levine,Jolie

Robson v. MJJ Productions,INC.

SIIPFsRIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE

COIINTY OF LOS ANGELES

WADE ROBSON, an individual,

Plaintiff,

vs.

)CASE NO.:BC508502

MJJ PRODIICTIONS, INC., a California,

corporation; MJJ VENTURES, INC., a

California corporation;

inclusive,

and DOES 4-50,

Defendants.

CONFIDENTIAL

1

VIDEOTAP$D DEPOSITION OF

JOLIE LEVINE

WEDNESDAY, JANUARY 11, 2017

10:18 A.M.

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Levine,Jolie

Robson v. MJJ Productions,INC.

JOLIE LEVINE,

CALLED AS A WITNESS

BY AND ON BEHALF

OF THE PLAINTIFF,

AFTER BEING DULY SWORN, WAS

EXAMINED AND TESTIFIED AS

FOLLOWS:

UNIDENTIFIED SPEAKER:

off paperwork for you.

I have someone dropping

MR. JOHNSON:

on the back.

And the next set,

there's copies

MR. FINALDI:

Okay.

Thank you.

MR. JOHNSON:

Cool.

EXAMINATION

BY MR. FINALDI:

Q

Good morning.

A

Good morning.

Q

How are you?

A

I'm okay.

Q

Alrighty. You understand

that the oath that

you just took has the

same force and effect

said in a court of law?

as if it were

A

Yes, I do.

Q

Okay.

You understand that oath compels you to

tell the truth under

penalty of perjury?

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Levine,Jolie

Robson v. MJJ Productions, INC.

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A

Yes.

Q

Okay.

When is the last time you spoke with

Norma 3taikos?

A

Oh.

Well, before I got fired.

Q

Never communicated with her since?

A

No.

MR. FINALDI:

Do you have questions?

MS. MacISAAC: Yes.

MR. FINALDI:

MS. MacISAAC:

Do you want to sit here?

Yeah.

It might make it a little

11 easier.

12

THE VIDEOGRAPHER:

Off record, 4:05.

13

(Off the record.)

14

04:06:45 15

p.m.

THE VIDEOGR.APHER:

Returning to record, 4:06

16

17

18

EXAMINATION

19 BY MS. MacISAAC:

04:06:47 20

21

Q Good afternoon, Mise Levine.

When you worked for MJJ Productions, did you

22 have an understanding of who owned the company?

23

24

04:06:55 25

A

Yes.

Q

And who was that?

A

Michael.

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Levine,Jolie Robson v. MJJ Productions, INC.

Q When you worked for MJJ Productions, did you

have an understanding of who had the ultimate power and

control over the company?

MR. FINALDI:

Calls for a legal conclusion,

calls for speculation, vague and ambiguous, compound.

THE WITNESS: Yes.

company.

BY MS. MacISAAC:

Michael Jackson owned the

Q And it was your understanding that he

controlled the company?

A Oh, definitely.

MR. FINALDI:

BY MS. MacISAAC:

Same objections.

Q As far as you were aware, did Michael Jackson

ever have a boss at MJJ Productions?

A No. Michael was the boss.

MR. FINALDI:

BY MS. MacISAAC:

Same objections.

Q As far as you knew was there anyone at Michael

Jackson -- at MJJ Productions while you were there that

in any way supervised Michael Jackson or had the power

or

authority to tell him what to do?

A No.

Michael was the boss.

the -- he was the power.

He was -- he had

Q I think you testified earlier that you don't

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Levine,Jolie Robson v. MJJ Productions, INC.

0.4:07:49

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believe Michael Jackson's a pedophile?

2

A

No, I don't.

I never believed that he was a

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pedophile and I still do not believe that Michael was --

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is a -- was a pedophile.

 

04:07:57

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Q

Did you ever see Michael Jackson touch a child

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in a way that you thought was inappropriate?

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A

Never.

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Q

Did you ever see Michael Jackson touch a child

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in a way that you thought vas sexual?

04:08:07 10

A

Never.

 

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Q

Did you ever see any interaction between

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Michael Jackson and a child that made you uncomfortable?

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A

Never.

14

Q

I think you said that when you were on the Bad

04:08:18 15

Tour, you packed and unpacked Michael's room several

 

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times?

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A

I always packed Michael's room whenever we

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moved to each different city so I saw everything.

19

Q

In those -- can you estimate, you know, was it

04:08:35 20

over 50 times that you packed and unpacked his room?

 

21

A

At least, yeah.

22

Q

During any of those times, did you ever see any

23

pornography?

 

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A

Never.

04:08:44 25

Q

Did you ever see any nude photos of childxen?

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Levine,Jolie Robson v. MJJ Productions,INC.

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A

Never.

2

Q

Did you ever see any photos of children that

3

were partially undressed?

 

4

A

Never.

04:08:51

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MS. MacISAAC: I have no further questions.

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MR. FINALDI:

Alrighty. I have no further

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questions.

I'd like to offer a stip that the court

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reporter be relieved of her duties under the code.

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Do you want the transcript sent to you --

04:09:02 10

 

MS. MacISAAC: Yes.

 

11

MR. FINALDI:

-- to get it to her?

12

MS. MacISAAC: That's fine.

13

MR. FINALDI:

The transcript will be sent to

14

Mr. Weitzman's office and they will see to it that

04:09:08 15

Miss Levine receives it, review it, sign it under penalty

 

16

of perjury.

17

You can make any corrections you deem

18

necessary.

If you change something of substance, we can

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comment upon it at the time of trial and in motion

04:09:20 20

practice and it may be seen as negatively affecting your

 

21

credibility.

 

22

Does that makes sense?

Yes?

23

THE WITNESS:

Yes. Sorry.

24

MR. FINALDI:

Is 30 days enough time for you to

04:09:2.9 25

review it?

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Hearne,Gary

Robson v. MJJ Productions, INC.

SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE

COUNTY OF LOS ANGELES

WADE ROBSON, an

individual,

)CASE NO.:BC508502

Plaintiff,

vs.

MJJ PRODUCTIONS,

INC., a California,

corporation; MJJ VENTURES, INC., a

California corporation;

and DOES 4-50,

inclusive,

Defendants.

VIDEOTAPED DEPOSITION

OF

GARY HEARNE

FRIDAY, SEPTEMBER 2, 2016

10:07 A.M.

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Robson v. MJJ Productions,INC.

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Robson.

MR. FINALDI: Vince Finaldi for Plaintiff

Wade

THE VIDEOGRAPHER: Would the court reporter

please now administer the oath.

GARY HEARNE,

CALLED AS A WITNESS BY

AND ON BEHALF OF THE PLAINTIFFS,

AFTER BEING DULY SWORN, WAS EXAMINED

AND TESTIFIED AS

FOLLOWS:

EXAMINATION

is

13 BY MR. FINALDI:

14

10:08:14 15

Q Good morning.

Could you please state and --

spell and state your full name for the record.

16

A My full name is Gary David

D-A-V-I-D, H-E-A-R-N-E.

17 G-A-R-Y,

Hearne.

That's

18 Q

19

A

Have you ever had your

Yea.

deposition taken before?

10:OS:3~6 20

Q

21 A

How many times?

I don't remember, but maybe five or six times.

22

Q

All right.

I wasn~t at those depositions

and I

23 doa't know if you were informed

of all the ground rules,

24 so 2'm going to run through

them really briefly to make

10:08:53 25

sure we're both on the sazae

page. Okay.

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situation or another.

Q Okay.

Hearne,Gary Robson v. MJJ Productions,INC.

A Much like when you water the roots of a plant,

you just attend to the root of it.

Q Okay.

A And then everything else will flourish in some

way and you don't worry about this flower or that

whatever.

leaf or

Q So is it -- is it a true statement that in your

entire life up 'til now, you've never had any

type of

formal training or education, whether it be through a

seminar or just a class --

A

Uh-huh.

Q

-- or a weekend course --

A

Uh-huh.

Q

-- or just sit down on childhood sexual abuse;

is that true?

A

training.

No. That's true.

I have not had such

Q Alrighty. Now, when I say the Jackson

organization, what -- you know

who Michael Jackson, the

now-deceased entertainer is, correct?

A

Yes.

Q

Okay.

And you worked for him at one point in

time; is that true?

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Hearne,Gary Robson v. MJJ Productions,INC.

A

Yes.

Q

A

You worked for one of his companies, right?

Worked for him under the

auspices of one of his

companies, yes.

Q

A

And what was the name of that company?

MJJ Productions.

Q

A

Q

A

MJJ Productions, Inc., correct?

I think it may have had "Inc." on it, yeah.

Okay.

I --

Q

And just --

MR. STEINSAPIR:

THE WITNESS: No.

the situation where I'm not

Were you going to say --

Just, you know, I understand

supposed to suppose, so I

just don't -- we always referred to it as MJJ

Productions.

MR. FINALDI:

Okay.

Yeah.

That's fine.

THE WITNESS:

Yeah.

BY MR. FINALDI:

Q

knoav.

A

Q

A

Q

And if I cut you off on accident, please let me

Okay.

Sometimes I'm --

Likewise.

Okay.

So -- but you did receive -- so you

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worked for pay for the company, MJJ

Hearne,Gary Robson v. MJJ Productions,INC.

Productions?

A

Correct.

Q

And when you received your pay, how did you

receive your pay?

A

A

weekly check.

Q

Okay.

It was a hard check?

A

Yes.

Q

And you understood that the check came from

Productions?

MJJ

A

Yes.

Q

Would you have that mailed to you or would you

pick it up or would it be delivered to you?

A

It was -- I picked it up.

Q

Where would you pick it up?

A

At the MJJ offices.

Q

And was that on Wilshire?

A

Yes, it was.

Q

Do you remember the address?

A

10960 Wilshire Boulevard.

Q

Kind of by UCLA?

A

Yes.

Q

And which floor?

Do you remember?

A

I

believe it was the 22nd fln~r_

Q

Alrighty.

Do you remember when you were first

hired, what your first day of work was?

27

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Hearne,Gary Robson v. MJJ Productions, INC.

A Actually, I think I do.

I think it was

October -- the

actual official first day of work

think it was October 10th, 1991.

was -- I.

Q Okay.

history?

Have we covered your entire

educational

A Yes.

Q Okay.

history.

A Okay.

I'd like to go through your employment

Q So in high school, for example, did you have a

job?

A In high school, I earned money

as a musician.

Q What instrument do you play?

A Mostly guitar.

Q All right. Any type of music in

A Rock 'n Roll.

particular?

Q Alrighty.

How about during college?

talked a little bit about your

teacher --

You

A

Uh-huh.

Q

-- arork?

A

Yes.

Q

Both as a student teacher in the

right?

A

Uh-huh.

Q

Fine arts programs?

college,

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Hearne,Gary Robson v. MJJ Productions, INC.

Q

When did you first meet him?

A

At that center.

Q

Was he a teacher or something?

A

Well, he is a -- or was -- is a physician

connected with the Boston Medical community at the time

and he became interested in the transcendental meditation

and a related branch of Vedic knowledge called ayurved or

a yruveda, which has to do with an approach to physical

health, physical and mental well-being.

Q Okay.

with him?

A

Yes.

So that's where you became acquainted

Q

Okay.

And so it's my understanding Bill Blatt

called you on the phone.

You were in France visiting

your sister.

And he said I've got a job opening if you'd

like it?

Something to that --

A

Uh-huh

Yes.

Q

Okay.

I've heard about a job opening.

What did he say the job was?

A

To be the driver for Mr. Jackson.

Q

Did you have a dxiver's license at the time?

A

Yes.

Q

And had you had any special training in being a

professional driver?

A

No. No training.

But I had a few times as

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Hearne,Gary Robson v. MJJ Productions,INC.

 

A

Q

A

Q

A

Q

A

Q

it --

 

A

Q

~

Yes.

-- taught kids as well?

Pardon me?

And you taught kids there as well sometimes?

I never taught any children there.

How often would kids be brought there?

Seldom.

All right.

Were there always kids there or avas

No.

Okay.

There were time periods where there were

no kids there?

A

Q

Correct.

All right.

And did you have any training --

for that job there, did you ever have any training on

dealing with kids or anything like that?

A

No.

Q

Alrighty.

So my understanding, you came out to

California and you

right?

interviewed with someone for the

A That's right.

job,

Q Who did you interview with?

A I interviewed with Mr. Jackson and with

Staikos.

Q Norma first, correct?

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Norma

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A

Michael.

Hearne,Gary Robson v. MJJ Productions,INC.

I met Norma just a few minutes before I met

Q And what kind of things did she ask you at the

interviear?

A

I don't recall.

I did speak with her by

telephone before I came

to Los Angeles.

Q

Okay.

A

I don't remember specifically what she asked

me.

Q

A

Did she ask about your dxiving record?

I don't remember too many questions about that.

Q

Did you have to provide them a copy of your

driving record?

A

Q

I don't recall having done that.

Okay.

What kind of stuff do you remember her

asking you or telling you about, if anything?

A She told me that Mr. Jackson had decided to

have a personal driver.

He had been having -- using a

driving service.

It was not working out so well.

I

remember her saying

that some of the drivers from the

service would be a little

too interested in whatever

Michael was doing.

They would sort of hover over him,

you know.

He was out and about shopping or whatever and

Q Okay.

And when you spoke with Mr. Jackson,

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Hearne,Gary Robson v. MJJ Productions,INC.

it's my understanding you met him at a studio in

City?

Culver

A

Correct.

Q

And exchanged pleasantries, right?

A

Yeah.

We spoke a little bit.

Q

Did he tell you a little bit about himself?

A

No, not really.

Q

Did he tell you wl~sat he expected of you in the

job duties?

 

A

No.

Q

all?

A

duties.

Did he speak about any of the job duties at

I don't recall him speaking of any of the

Q Do you remember asking him about any of your

job duties?

A No.

I think the purpose of me meeting Mr.

Jackson at that time was so that he could

just get a feel

for who I was.

I think they pretty much assumed I knew

how to drive.

Q

Okay.

A

And --

Q

Did you have a driving test?

A

No.

Q

Okay.

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Hearne,Gary Robson v. MJJ Productions, INC.

A

You mean for the job, specifically?

Q

Yeah.

A

No.

Q

Did either Michael Jackson or Norma say let's

go for a driving test?

A

Oh, no.

No.

Q

I'm going to test you and see --

A

No, no.

Q

No?

A

No.

Q

Okay.

Who offered you the job?

A

Well, it was -- it was Norma.

Q

Okay.

After you met Michael?

A

Yes.

Q

And what did she say in relation to offering

you the job?

A Well, I met them on one day.

And then she said

let's meet tomorrow morning.

So I went back to the hotel

I was staying in and I didn't have any indication

one way

or the other if they wanted me for the job.

So I met

with Norma the next day.

And she was telling me more

about the job, but I still didn't know if they really

wanted me or not.

So finally, I stopped.

I said, Well,

now, do you want me for the job?

we do.

And so --

And she said, Qh, yeah,

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Hearne,Gary Robson v. MJJ Productions, INC.

Q

Okay.

A

So that was sort of how the offer came about.

Q

And you accepted it right there?

A

Yeah.

Yes.

I think I did.

Q

Okay.

What was your job description when you

accepted the job?

A

It was to be the driver for Mr. Jackson.

Q

And was there set hours that you were to work?

A

No.

Q

So no set hours as far as the times that you

would work or the time periods during which you would

work, correct?

A

Correct.

Q

And you were told that before you began?

A

Yes.

Q

And you accepted that, right?

A

Yes.

Q

Alrighty.

And did they send you to any kind of

a driver's course or training for limo drivers or taxi

drivers?

A

No.

Q

Have you ever had in your entire

life any type

of training for taxi driver, limo

driver, anything --

A

No.

Q

-- of that nature?

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Hearne,Gary Robson v. MJJ Productions, INC.

A

Arm to arm or something like that.

Q

Okay.

A

Not like we were walking along with our arms

around each other but --

Q Okay.

A -- just like when you're talking to

someone and

maybe there are other people there and you

stand.

And I

think a few times I was kind of -- you know, we would go

to a meeting or something and I'd open the door for

Mr. Jackson and I'd sometimes put my hand, you know,

behind his back as to kind of -- I guess, a gesture of --

of, you know, here.

Q

Okay.

A

Yeah.

Q

But the question was him touching

kids.

A

Kids, right.

Q

Are you saying this is the vvay you saw him

touching kids?

A Something like that, yeah, I

would say. You

know, like I say, I don't specifically remember any

particular posture or position

of body.

But let me put

it this way, if it was something that was inappropriate

o r in .a sexual way, as I assume you might

be curious

about, I would have

remembered that and I have no such

memory.

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Q

Okay.

Hearne,Gary

R obson v. MJJ Productions,INC.

Why would you have remembered

that?

A Because it would -- I think for the same reason

I would have remembered it

child inappropriately.

something that's -- you know, it's a wrong thing to do.

if I saw any adult touching

That's -- you know, it's just

It's --

Q Do you remember ever bringing

any kids oa the

property at Neverland

when you went through

and having them hide in the back

the security booth?

A No. No, I don't remember anything

I can't say it didn't happen.

like that.

Q

Okay.

It may have happened.

don't remember it?

If it did, you

a

A

Correct.

Q

Okay.

Why would a kid need to hide in the back

of your limo?

A I -- well, you're -- I don't know.

Like I say,

I don't know if that ever happened.

could have happened, it's -- I mean, there's no way I

When I say something

could know, but I -- I suppose it

would suffice to say

that I just don't ever remember seeing

such a thing.

Q Okay.

3o as far as you remember, there were no

certain protocols for going

into the gate at Neverland

Ranch that changed in any way? Like, aay protection

kidnapping or any kind of, you know, standard protocol

from

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167

Hearne,Gary

Robson v. MJJ Productions, INC.

02:32:59

1 for you going

into the gates that changed?

Do you

2 remember any of that?

3

A No.

Other than very late in my career

No.

4 working for Michael, after there was

a period of time

02:33:19

5 when the Nation of

Islam was kind of allowed

to come in

6 and takeover.

Then things changed --

7

Q Yeah.

8

A -- for all of us.

9

Q I'm talking about '93 to '97.

02:33:30 10

A Oh, no.

No, I don't remember

any such thing.

11

Q Was there a rule that every time you

went

12 through that front gate, you had to roll down the window

13 and let them see Mr. Jackson or

not let them see

14 Mr. Jackson?

02:33:41 15

A No.

In fact, I'm certain

there was not a rule.

I6

Q So there were times under

the rules or as you

17 understood them at the time, it would be possible for you

18 to bring Mr. Jackson and

a child onto the Neverland Ranch

19 property without the security

guards seeing it?

02:33:57 20

MR. STEINSAPIR:

Objection --

21

THE WITNESS: Well --

22

MR. STEINSAPIR: Hold on.

That assumes facts.

23 He never testified about any rules, but you

can go ahead

24 and answer.

02:34:08 25

THE WITNESS:

As I recall, the way the protocol

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Hearne,Gary

R obson v. MJJ Productions,INC.

was that when I, you know,

pushed the little button to

Jackson, I would also say

say that I was here with Mr.

the other guests.

BY MR, FINALDI:

Q

Yeah.

A

Yeah.

Q

But there was no rule, like,

you had to roll

down the window or not roll down the window

actually verify it, right?

so they can

A It could have been -- I don't

specifically

recall, but it may have been at times when Mr. Jackson

was not in the

car that that was a procedure

we would do.

Q Okay.

A But not with him because,

you know, he's -- he

was the owner of the place.

And I think -- anyway, I

would get into all kind of speculations as

rrat- ~~

to why, but

Q Okay.

So how many years did you work for

Mr. Jackson before he passed away?

A

Q

was that?

I worked a total of 15 years.

Okay. And while

he was alive, how many years

A

15 years.

Q

Did you ever tell him no?

A

You mean --

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Hearne,Gary

Robson v. MJJ Productions,iNC.

MR. STEINSAPIR:

Objection; vague.

THE WITNESS:

I may have' -- yeah, I may have

spoken the word "no" to him.

It depended --

BY MR. FINALDI:

Q I'm asking did you ever tell him

no?

you to do something or tell you to do something

said no?

A

No. None.

Him ask

and you

Q

A

Never?

No such time that I can remember and I think if

there had been such time, I'd remember it.

Q Why do you think that?

A Well, because it would have

been highly

unusual.

2 can't imagine of a circumstance where I would

have.

Q Do you remember ever hearing anyone tell

Michael Jackson no?

A

That word specifically?

Q

Yeah. Him telling them to

them saying no?

do something and

A

No, I don't remember --

Q

Okay.

A

-- any-such time.

Q

Alrighty.

MR. STEINSAPIR: Can we take a

break?

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170

Goforth,Gayle

Robson v. MJJ Productions,INC.

SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY

WADS ROBSON, AN INDIVIDIIAL,

vs.

Plaintiffs,

MJJ PRODIICTION3, INC., a

California corporation; MJJ

VENTURES, INC., a California

corporation; and DOES 4-50,

inclusive,

Defendants.

OF L03 ANGFLE$

CASE NO. BC508502

CONFIDENTIAL

VIDEOTAPED DEP03ITION OF GAYLE GOFORTH

3ANrA MARIA, CALIFORNIA

MONDAY, OCTOBER 24, 2016

10:04 A.M. - 3:54 P.M.

RSPORTfiD BY CAR.OLYNN

B. 3PFRE, CSR #10091

1

Jilio-Ryan Court Reporters

p h. 714.424.9902 info~a„?'ilioryan.com

Goforth,Gayle

Robson v. MJJ Productions,INC.

10:04:39

1

THE VIDEOGR.APHER:

Good morning.

This is the

10:04:41

2

video-recorded

deposition of Gayle Goforth, taken at

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301 South Miller Street,

Suite 110, Santa

Maria,

California, on Monday, October 24th, 2016, at 10:05 a.m.

in the matter of Robson

versus MJJ Productions,

Incorporated, being heard in the Superior Court of the

State of California, County of Los Angeles, case No.

BC508502.

This deposition is on behalf of the plaintiff.

My name is Deborah Gehrke with Dean Jones Video

Services of Santa Ana and Los Angeles,

court reporter is Carolynn

Spere.

California.

The

Would all parties, please, introduce yourselves,

beginning with the witness.

THE WITNESS: Gayle Goforth.

MR. FINALDI: Vince Finaldi, Manly,

Finaldi for the plaintiff.

defendant.

MR. LISKIN:

Aaron Liskin, Kinsella

Stewart and

Weitzman for

THE VIDEOGRAPHER: Will the court reporter,

please, administer the oath.

GAYLE GOFORTH,

A WITNESS HEREIN, BEING FIRST DULY SWORN, WAS

EXAMINED AND TESTIFIED AS FOLLOWS:

4

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Goforth,Gayle

R obson v. MJJ Productions, INC.

14:20:16

1

A. Naked kids, no.

They were all like

statues.

He

14:20:21

2 had several statues

in the home.

14:20:2.4

3

Q. Of kids and things?

14:20:26

4

A. Kids, but not naked. Like

cherub-type things.

14:20:31

5

Q. Bronze statutes of kids all over the property,

14:20:37

6 right?

14:20:38

7

A. Yes.

But they had clothes

on and there was like

14:20:45

8 cherub kids.

14:20:57

9

MR. FINALDI:

Okay.

I am going to hand over the

14:20:58 10

questioning to check over my notes, but I think 2 am

14:21:03 11

pretty close to being done.

14:21:05 12

MR. LISKIN:

Why don't we take a 10-minute

14:21:07 13

break.

14:21:07 14

THE VIDEOGR.APHER:

The time is 2:21 p.m.

We are

14:21:10 15

now off the record.

14:21:13 16

(Break taken.)

14:28:21 17

THE VIDEOGRAPHER:

We are back on the record.

14:28:47 18

The time is 2:29 p.m.

14:28:50 19

MR. LISKIN: Good afternoon,

Ms. Goforth.

14:28:53 20

THE WITNESS: Good afternoon.

14:28:55 21

MR. LISKIN:

Thanks for your time today.

14:28:57 22

THE WITNESS:

Thank you.

14:28:57 23

EXAMINATION

14:28:57 24

BY MR. LISItIN

14:28:57 25

Q. Did you ever work out of

-- strike that.

172

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Goforth,Gayle Robson v. MJJ Productions,INC.

14:29:00 1

Have you ever been to MJJ Productions offices?

14:29:04 2

A.

Yes, I have.

14:29:05 3

Q.

And was that your primary place of work?

14:29:08 4

A.

No, it's not.

14:29:10

5

Q.

What was your primary place of work?

14:29:11 6

A.

Neverland Valley Ranch.

14:29:13

7

Q.

And was it your understanding that was Michael

14:29:17 8

Jackson's personal residence?

14:29:19 9

A.

Yes, it was.

14:29:19 10

Q.

So he lived there?

14:29:21 11

A.

Yes, he did.

14:29:22 12

Q.

Counsel has mentioned or asked you some

14:29:26 13

questions about a phone conversation that you had with

14:29:29 14

someone named John from my office.

14:29:33 15

A.

Yes.

14:29:34 16

Q.

Did John ask you to lie under oath?

14:29:37 17

A.

No, he did not.

14:29:38 18

Q.

Did John tell you how to testify today?

14:29:41 19

A.

No, he did not.

14:29:42 20

Q.

There was some testimony about groups coming to

14:29:53 21

the ranch at times.

14:29:55 22

A.

Yes.

14:29:57 23

Q.

I'm not sure if I remember this correctly, did

14:29:59 24

you say that more often than not, Michael was not even

14:30:03 25

there when the groups came?

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A. A high school?

Q. Yes.

A.

No.

Q. Was it a middle school?

A. No.

Goforth,Gayle

Robson v. MJJ Productions, INC.

Q. Was it an elementary school?

A. No, it was not.

Q. It was not a school, correct?

A. No, it was not a school.

It was a private home.

Q. Did you believe you had the authority

to tell

Michael what kids could or could not stay at Neverland

Valley Ranch?

A.

Of course not.

Q.

Do you believe that Blanca Francia

had the

ability to tell Michael what kids

at the ranch?

could or could not stay

A.

I don't believe.

Q.

Do you believe Ms. Staikos could

tell Michael

what kids could or could

not stay at the ranch?

A.

No.

That was entirely up to him.

Q.

Michael was in charge of things at the ranch,

correct?

A.

Yes.

Q.

And ultimately, did you believe that you worked

for Michael?

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