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DECLARATION OF WADE ROBSON |, WADE ROBSON, declare and state, as follows: 1. Thave personal knowledge of the facts stated herein, and if called as a witness | would and could competently testify thereto, except for those matters and things sct forth upon information and belief, and as to those matters and things, I believe them to be true. 2. Myname is Wade Jeremy William Robson. 1 am 30 years old and was bom on September 17, 1982 in Brisbane, Australia to parents Lynetie Joy Robson and Leslie Dennis Robson, I have a sister, named Chantal Robson, who is three (3) years older than me and a brother named Shane Robson, who is approximately ten (10) years older than me. 3. Based upon the following set of facts und my understanding of the definition of the word “just”, [ Believe that my claim is just. . 4. When I was two (2) years old, my mother showed me her video cassette of Doe I's “Tht Making of Thriller.” I was instantly fascinated with it and waiched the video every day aad ‘emulated Doc 1's dance moves. Between the ages of two (2) and five (5), my fascination and interest in Doo 1, specifically dancing and being Like him, grew into an obsession. He became like “God” to me. 5. When I was five (5) years old, my mother entered me in a Doe 1 dance-s-like contest in Brisbane, Australia that was rua by BEGG 1 won the competition and the prize wes to meet Doe |. in November 1987, I met Qoe 1 after one of his “Bad” tour concerts in Brisbane, ‘Australia, Doe 1 then invited me to dance onstage with hiro at another one of his Australian concerts a few nights after our first meeting. As a five (5) year old, dancing with my idol Doe 1 ‘vas the biggest thing ever to happen to me. The day after our joint onstage performance, ray ow ane un mother and I spent a few hours visiting with Doe I in bis hotel suite. 6 nearly 1990 when I was seven (7) years old, Itraveled with the Johaay Young ‘Talent Schoo! located in Brisbane, Australia to perform at Disneyland. Several family members traveled with me to America. During our stay ia Los Angeles, 1 met Dot 1 at a recording studio in ‘Van Nuys, Californie. During our meeting, Doe | invited me and my whole family 10 spend the weekend at his Santa Barbsra County ranch, “Neverland Valley Ranch”, My family stayed the -1- LNG {FILED CONDITIONALLY UNDER SEALY weekend at the ranch, but then left me alone with Doe 1 for another week. The firs night a the ranch my sister Chantal and [ both slept in Doe 1"s bedroom in the same bed as Doe 1. The following night Chartal expressed enncer about sleeping in Doe 1's bed and elected instead 19 sleepin a separate bed on a difereat floor of Doe 1°stwo-floor bodroom, but I slept ia Dos 1's bed, Doe | began sexvelly abosing me on or about that night. The sexual abuse continued every nigh hough the neatly wo) weeks that peat the rach during that erty 190 vst as wel sat Doe 1°s apartment in the Westwood section of Los Angeles before my family and I rtwmed to Australia. Paragraph 15 below describes the sexual abuse, 7. From the frst instance of wbuse, Doe 1 began telling me that “we ean never tell anyone what WE ere doing, People ae ignorant and they would never understand tht we love cach other and this fs how we show it (Fanyone vere to ever find aut, OUR fives and careers would be over." I swore I would never tell a soul about what we did, and did not uncil May 2012. &. After had beer with Doc 1 fora week, my family retuned tothe ranch forthe weekend. Even while my family was tthe ranch, {continued to sleep with Dec | in his be in hia tom, and the senual abuse continued. After the week atthe ranch, ray rather, sister and [ stayed with Doe 1 for a oumber of days af Doe 1s wpartment i the Westwood section of Los ‘Angeles. sinyed with Doe 1 in his bedroom and inthe same bed athe spartment, an the sexu abuse continued. 9. _Atsome point during this 1990 tip to Los Angeles, Doe 1 gave me the nicknarme sje one." He continued to call me by tbat name al the way up until bis death in 2009. He aso segaa to fil my head with pax ove by such ws “Be in the history books" and “Imonalize youself? He also prophesized that I would one day be a film director bigger than Steven Spielberg. As far as | was concerned, Doe | had writen my fete. 10. My family and I returned to Australia following my two-week visit with Doc 1 My mother and | remained in constant const with Doe! During this period, Doe I ad! would frequently speak on the telephone for hours each week. We also would constantly send faxes back and farth to each other.