JACKSON V AEGLive May 10

th
2013
Traduzione in Italiano
05/28/13 Please help us!
Karen Faye
(Hair and Makeup)
Plaintiffs Witness.

Typed by WendyLovesMJ
Direct examination by Brian Panish.


Q W happened at the rehearsal?
A Michael sweat a lot when he was rehearsing. Michael Bush took him to the
bathroom to give him dry clothing. I was in the living room. Bush came out of the
bathroom, He said to me: Oh my God Turkle, I can see Michaels heart beating through
the skin on his chest.

Q Did you say anything back?
A I know. Hes thin.

Q Whos Turkle?
A That was Michaels nickname for me.

Q How were you both?
A We were shocked, upset.

Q Yesterday you said you received no written response to your email to Delio, about
your concerns, you were worried Michael would get so sick and die, is that right?
A Correct.

Q Did Mr. Dileo say anything to you about those emails?
A No, but I asked if he received them. He did not respond.

Q Did Mr. Dileo say anything to you about Michael Jacksons eating or physical
condition?
A I told him Michaels losing weight rapidly. To ask Michael Bush to verify how
much weight hes losing? Later I saw him talking to Michael Bush. I heard him asking
something about Michaels weight, I heard Bush verify

(Panish stops Karen Faye, tells her not to state what she heard Michael Bush say)

Q Did you hear Mr. Dileo make a statement about Michaels food?

A Yes.

Q What did he say?
A Get him a bucket of chicken.

Q How did that make you feel?
A Sir (crying) It was so cold.

Q How did you hear that Michael Jackson had died?
A I was in the hallway at the Staples Center. Kenny Ortega came up to me, put his
arms around me and told me.

Q How did you deal with it?
A I cant describe it.

Q How did Mr. Ortega deal with it?
A He and the people there continued on with the business of the situation

Q Did you have any responsibility of preparing Michaels body for funeral service?
A Yes sir.

Q What did you do?
A (crying) I prepared his body for his family to view him in his casket.

Q Did you learn a movie was going to be made from some of the performances that
was videotaped?

A Yes.

Q Were you ever asked to be part of that project?
A Yes.

Q What were you asked to do?
A Help retouch the footage.

Q And did you do that?
A No sir, I did not.

Q Why not?
A Because it was a lie. I didnt want to lie.

Q What do you mean?
A Everybody was saying Michael was well. And they knew he wasnt. I felt
retouching Michael was just a part of that lie.

(Panish plays The Way You Make Me Feel clip)

Q Does this accurately depict how Mr. Jackson looked in the last days of his life?
AEG: Objection. No foundation. Judge: Overruled
A He looked better to me in real life than this. Especially in his legs.

(Panish exhibits a photo Michael in last days of his life)

Q Did he look robust, muscular, skeletal? How would you describe this?
A Skeletal.

Q What do you see there in his face that lead you to say that?
A His eyes, his jaw, his ears, his neck, his lips are dry.

(Panish exhibits a photo of Michael in his History Tour gold pants on the right, next
to a photo of Michael in the red pants from This Is It footage on the left)

Q What differences do you see in Michael?
A On the right is how he used to look to perform. On the left is how he looked for
This Is It.

(Panish exhibits two more photos side by side. On the right, a photo taken of
Michael in fitting room of This Is It. On the left, a photo from This Is It video taken
2 days before he died)

Q Can you tell us what you see in these photos that concern you?
A In the photo on the right, his arms bones. The one on the left is blurry. I cant
make out too much. plus hes got a lot of clothes on. He got a tee shirt on, under another
shirt, and another, and another.

Q One is on the 19
th
and one 23
rd
, thats 4 days.
A Yes.

Q Is there any question in your mind on This Is It that Michael Jacksons appearance
was concerning to you?

A I was very concerned. I was scared.

Cross examination by Marvin Putnam.

Q You had previously retouched footage that was going to be used in concerts?
A I personally was not. I was working with the technicians to show them what was
best for Michael.

Q You said no to retouching the This Is It footage. Why?
A I was torn. This movie was going out. I wanted him to look good. But not lie. I
contacted my rep for advice. I did not participate.

Q This rep, is that Ms. Wilkie? Your long-term rep?
A Not long-term, several years.

Q What is Ms. Wilkies personal relationship with the Jackson family?
A Shes known Randy Jackson for a very long time.

Q Randy Jackson, what do you mean?
A They had a relationship.

Q Was that long-term?
A On and off, sir.

Q A long-term on and off relationship?
A Yes sir.

Q You said you talked with Frank Dileo and he said get him a bucket of chicken?
A That wasnt with me. I heard it through a partition.

Q At Staples Center the 23
rd
and the 24
th
that would have been on one of those two
days?
A Yes sir.

Q You previously testified on those days Mr. Jackson looked good?
A I didnt say he LOOKED good. Theres no way somebody could look good that
quickly. His rehearsal was better, sir.

Q He had better rehearsal on the 23
rd
24
th
but you still thought he was too thin?
A Absolutely, sir. he was cold. very cold.

Q In fact you thought he looked too thin the entire time you were back in Mr.
Jacksons life in 2009?
A Comparatively, not too thin initially. he didnt have enough muscle mass to do a
concert at that time. He progressively got thinner.

Q And your main concern was Mr. Jackson was too thin, right?
A That was only one of my concerns. his psychological -- his state of mind, sir.

Q The concern about his psychological state, was that through the whole time back
you were with him May and June?
A It came to a peak in the last week. I progressively became more worried.
especially when he started miss rehearsals.

Q So that was starting on the week of June 8

th
?
A I cant remember the date, once we reached the Forum rehearsals started, I began
noticing -- it was obvious to everybody -- he was periodically missing rehearsals or
coming late.

Q Its important to be accurate.
A Absolutely, sir.

Q So what Im going to do is go through your testimony and be accurate as to
EXACTLY what happened, okay?
A Yes sir.

Q So you said the first week of June, that was at Culver?
A Sir, I dont remember the exact dates we were at Culver City before we started
rehearsing at the Forum.

Q So let me represent to you your prior testimony in your deposition is that in the
first week, was when you were at Culver City working on videos?
Panish: Objection. Improper use of the deposition. Judge: Overruled.

Q You said that was the first week you were in Culver?
A Ok.

Q Is that when you grew concerned for him psychologically or was it after?
A Im sorry. I cant verify dates exactly, sir. I would say that I was starting to
become concerned at that time.

Q 25
th
is the day of Mr. Jacksons passing, right?

A Yes.

Q 23
rd
and 24
th
were the only days at the Staple Center, correct?
A Yes.

Q So Im going to go back through the history. Ask you some questions to clear
something up.
A I will do my best.

Q Lets start with your work history with Mr. Jackson. You started working with him
in 1982 on the Thriller album, correct?
A Correct.

Q You mentioned a man named Frank Dileo. Michael Jacksons manager. Did you
meet him?
A Yes.

Q So you met Frank Dileo on the photoshoot in 1982.
A Oh no. Frank Dileo wasnt the manager then. He had a different manager think it
was DeMann. Frank Dileo wasnt Michaels manager until Thriller started taking off.
Frank quit his job at Sony to become Michaels manager.

Q So you knew him almost as long as you knew Mr. Jackson is that right?
A Almost. after Frank Dileo was fired there was a long time span, I didnt know
him as long as Michael.

Q And then he came back into Mr. Jacksons life, right?
A I saw him working on This Is It, sir.

Q There were a lot of people fired and then they came back, is that correct?
A Correct.

Q And you were one of those people?
A I was never fired, sir.

Q You werent fired?
A I was released. Im a freelance artist, sir.

Q Were you not told in the middle of a tour that your services were no longer
needed?
A Yes sir.

Q You were told that by Mr. Jacksons manager, Tarock, right?
A Yes sir. He sent me a letter of release.

Q When you were brought back into Mr. Jacksons life, you hadnt spoken to him
for years?
A Just in the last leg of the History Tour was really the only time I didnt talk to
Michael.


Q Well Mr. Jackson left the country in 2005, correct?
A He did, sir.

Q So the next time you saw him was 2009, correct?

A Yes sir.

Q So you too left Mr. Jackson for a period of time and then came back in, correct?
A Correct sir.

Q Was that an odd occurrence for people to leave and then come back in?
A Not extremely odd, sir.

Q Did that happen frequently?
A Not, but it did happen.

Q Then how would you characterize it?
A Once in a while.

Q You worked on the Moonwalker film. Were you aware that Mr. Dileo was the
executive producer on that film?
A I believe so.

Q Bad Tour. That was your first tour with Mr. Jackson. Wasnt Mr. Dileo tour
manager?
A Yes sir.

Q The Bad Tour was 1987 to 1989, right?
A If you say so. Im not sure of the dates. Sounds right..

Q Was it sponsored by Pepsi?
A To my knowledge it was. All of the posters and everything had Pepsi printed on
it.

Q And this show started in Tokyo and ended in Hawaii?
A One ended in Hawaii but I think your right -- Bad Tour ended in Orange County,
I think.

Q Well, let me see if you remember a series of concerts that were cancelled due to
sickness, postponed to the following year?

A I cant recall that, sir. It was a longtime ago. You mean the ones in Orange County
were cancelled? Um. I know we did them.

Q Did you do some several months later?
A I cant recall, sir. Im sorry.

Q No dont be sorry. Im actually not asking the question for the answer. Its to see
what your memory is. This is over a long period of time, correct maam?
A Yes sir.

Q Do you remember some things vividly?
A Yes sir.

Q And some things you remember less vividly?
A Like most people, sir.

Q Im not suggesting that you dont remember.
A Normal things of life, work and everything, youre not going to remember details
of that. When something traumatic happens, it sticks in your head, sir.

Q Yesterday you were shown certain performances and asked if you could remember
one in Romania. Do you remember?
A I was in Romania my daughter was on stage for Heal The World. That was very
easy to remember, sir.

Q You were shown several clips yesterday and asked if you could remember. So Im
going to do the same thing. Do you remember a DVD being made for a show at
Wembley? Do you remember that?
A Yes. I think Sony re-released them. But I havent seen them, sir.

Putnam: approaches KF.

Q Do you remember a series of shows in London?
A I remember being in Wembley. not number of shows. I remember the highlight
meeting Princess Diana. I was with Michael. I was not formally introduced.

Putnam: Alright. Im going to show you to clips from the DVD and ask you if you
recall them. Im not all of them, just bits of it.

(Putnam plays Beat It clip)

Q Do you recall that?

A This specific show? Sir, I have to say that we did this show many times. So for
me to say I remember this specific show would be -- I remember the performance, sir.

Q So do you remember this performance from that time period?
A I remember Beat It, yes.

Putnam: Okay. Let me play the next one, which is Smooth Criminal.

(Putnam plays Smooth Criminal clip)

Q Is that the version of Smooth Criminal that was performed during this tour?
A It appears to be, sir.

Q So you were there for the entire Bad Tour, correct?
A Yes.

Q And the next tour you were on was the Dangerous Tour?
A Yes, sir.

Q Do you remember it was 1992?
A 1992 -- okay, I will take your word for it because I cant verify the exact dates.
sir.

Q Do you remember that Kenny Ortega was on that tour?
A I dont think he was on the whole tour. He was a creative director so once the tour
was set up, Kenny went on to other things.

Q Does that mean he created the ideas on the tour.
A Along with Michael, yes.

Q So they did it together -- the concept of the show
A Yes.

Q Do you remember that tour had three legs to it -- Europe, Asia, then Asia again?
A Yes, I believe so.

Q Part of that tour was the clip we saw yesterday in Romania?
A Yes.

Q And this is the tour where you became increasingly concerned with Mr. Jackson
using drugs, is that right?
A Im sorry, can you re-phrase the question?

Q Alright. This is the tour that ended with Mr. Jackson going into rehab, correct?
A Correct.

Q And this is the tour you told us yesterday was Dr. Forcast, the Lloyds doctor?
A That was my understanding. Insurance doctor.

Q And this is when Dr. Forcast grabbed you around your throat?
A Yes sir.

Q Alright. Im trying to bring you back to what we are talking about. When you
were asked to look at that clip in Bucharest, do you remember?
A Yes sir.

Q And when you were asked to look at the footage you mentioned that there may be
as many as 500,000 people. Do you remember saying that?
A I think in Ireland, that was the count.

Q So Bucharest wasnt 500,000?
A That stadium was much smaller; he could pull as much, especially in a wide open
field. The media said -- when we were in Ireland, people had actually broken down
barriers and came in. There was about 500,000 people there, it was a tremendous
amount..

Q So yesterday when you said 500,000 people in Bucharest, that wasnt correct?
A Not in Bucharest sir, that stadium was much smaller.

Q Thats what I was going to ask you about. Because that stadium officially holds
70,000.
A Bucharest is kind of a depressed country so their facility was a lot smaller. But
there were also areas where there were big, open fields. So people would just pour in.
And it could be an exaggeration because, as you know, Im not really great with numbers
but I remember media reported 200,000, 300,000. There was a place in Ireland where it
was just tremendous. They broke down the gates.

Q So the reason Im over some of the stuff from yesterday is Im trying to get a very
accurate picture of what were doing here as best we can.
A Well Im 60 years old, sir. And youre talking about a 30 year span. Im doing the
best I can.

Q And I understand that, I promise you.
A How old are you?

Q What?

(laughter in courtroom)

A How old are you?
Q I --

Panish: You dont have to answer that.

A Is that hearsay?

(continued laughter in courtroom)

Panish: Objection.

Putnam: No. Its only hearsay if someone else said it.

Faye: Well, I heard somebody say it.

(more laughter)

Q Um. Going back to the Dangerous Tour. You indicated yesterday that Paul
Gongaware managed the tour, and had a role in cancelling that tour?
A I think that was multiple question, so I was answering. Okay. Did Paul
Gongaware actually cancel a show? He may have been involved in figuring out what to
do if something happened regarding cancelling shows. But I am not in the office and
privy to that info sir.

Q I understand. And thats why I want to make sure everybody understands.
A Yes. We were talking about chain of command, sir.

Q And so you dont know what Paul Gongaware did on that tour, correct?
A I do know some of the things. But not the details. He was working with our
passports. visas. He was working with logistics, with rearranging schedules.

Q And in fact, when you were asked initially about what he did, you said there were
3 parts: A, B and C. And he dealt with the B part of the crew?
A During the Dangerous Tour he traveled with the B group. sir.

Q I just want to be sure. This is the tour where you said he was further down the
totem pole?
A Yes sir.

Q And do you know if during that tour Paul Gongaware had any interaction with
Michael Jackson, at all?
A Yes he did. Because there were many times when our hotel rooms were together
and intermixed. And at the stadiums there was interaction between everybody.
Q So do you remember specifically seeing interactions between Paul Gongaware
and Michael Jackson?
A Specifics, I cant recall interactions between other people, youre talking about
350 people traveling together on the tour, sir. But there were.

Q Yesterday Bangkok tour was mentioned. And you talked about Mr. Jackson
having some sort of scalp surgery, is that correct?
A Yes.

Q And he had this surgery just before going to Bangkok?
A I really dont know the exact date of the surgery, sir. I worked with him on a
shoot and the actual inflation device was under his scalp, just before we left Bangkok, the
device was removed, an operation to bring the skin together on his scalp had already been
completed.

Q And you saw his scalp every time he performed, right?
A Not every time he performed. But I had to deal with his wounds and covering
them.

Q Do you remember seeing any signs of that surgery on the prior leg of the tour?
A I do not recall on which leg of the tour, the in between stages, when he had the
surgery.

Q You do remember between legs of the tour he had the surgery and then you saw
the results, but you dont remember between which leg of the tour he had the surgery,
correct?
A Correct. Or the year?

Q That was 92-93. This was 1993, were talking about Bangkok. And to be really
specific, I can tell you it was August 23, 1993.
A And youve done your homework, sir.

Q And you said yesterday he would get headaches as a result of the surgery, correct?

A Yes. migraine headaches. He was in a lot of pain.

Q And youre trying to say this is the result of the surgery, is that correct?
A Yes sir.

Q And this was also the time that certain charges about possible child molestation
came out , is that right?
A Yes sir.

Q And are you aware that those charges occurred on the same day as the show in
Bangkok?
A I know that is happened very close to that time, yes sir.

Q So the tour goes on for several months and then finally ends in Mexico City. Did I
understand you yesterday to say this was the time you started to believe Mr. Jackson was
having a problem with pain killers?
A Yes. I believe I did. I pretty much know there was an issue because of the
patches, vials and syringes that Finkelstein told me about.

Q Let goes back to that. You said yesterday that someone asked you to bring a
package of vials and syringes to Bangkok. Who was that?
A Jim Morey and Debbie Rowe.

Q And who was Jim Morey.
A He was, I believe his manager, along with Sandy Gallin.

Q So youve already talked about a number of managers here, You talked about
Freddy DeMann, Frank Dileo. Now Jim Morey and Sandy Gallin.

A Correct.

Q So Mr. Dileo and Mr. DeMann were no longer in the picture at this point?
A No sir.

Q So you said managers and Ms. Rowe talked about bringing the medicine into
Bangkok?
A Patches. I never saw them, it was explained to me, like the nicotine smoking
patches. It releases a certain amount of nicotine at a time.

Q And do you know what those patches were for?
A It was explained to me to relieve the pain from his surgery, sir.

Q And who was Debbie Rowe working for at this time?
A She was a nurse for Dr. Klein.

Q Was Dr. Klein treating Mr. Jackson?
A As far as my knowledge is, yes, sir.

Q And so the nurse of one of this treating physicians talked to you about bringing
along a package with patches in it?
A Correct, sir.

Q Youre Mr. Jacksons makeup artist. How is it this physicians nurses came to talk
to you about taking packages into Bangkok?
A Because I was going along with him.

Q And did you know any of his doctors?

A Yes. I knew Dr. Klein before I knew Michael, sir.

Q Did you know him professionally?
A Yes, sir.

Q Were you a patient.
A Yes, sir.

Q Ultimately, you declined to bring those packages into Bangkok, correct?
A Correct, sir.

Q Did you discuss your concern about his taking pain killers with Mr Jackson? Did
you ever say to Mr. Jackson: Im concern you have a problem with pain killers?
A No sir.

Q Did you ever say anything to him about his use of pain killers during the
Dangerous Tour?
A The only time it was obvious was in Singapore when he was not able to work. He
knew I saw what happened when I tried to stop him. That was the only non-verbal
communication we had, I knew what was going on.

Q Did you ever say to him after the Singapore incident that you were really worried
about him?
A I have to say I really dont recall because everything that was occurring was very,
very painful to Michael, sir. Emotionally. Physically. And I was a place of safety and
peace for him. I didnt want to bring up the allegations sir. I wanted that to be a really
safe place.

Q And so you didnt discuss your concerns with him, correct?
A I tried very hard not to.

Q Do you remember ever discussing it with him, at all?
A I cant remember, sir. it may have come up. Especially after what happened in
that dressing room, its not anything that I would have ever brought up in our space. So I
cant recall. But I know he thanked me for what I did in Singapore. If thats what you
mean about any kind of conversation.

Q He thanked you for what?
A For stopping the show.

Q And did you ever contact Mr. Morey and tell him: Hey I think Michael Jackson
has a problem with pain killers?
A No sir. I was afraid of him.

Q And why was that?
A Because of what they asked me to do.

Q You mean because they asked you to bring these packages to Bangkok?
A Yes. It concerned me. Especially after what the doctor said was really in that
package, sir. I was very wary of them.

Q Did you ever discuss your concern with Mr. Jackson about them asking you to
bring packages to Bangkok?
A I cant recall, sir. Maybe, after the fact. We had minimal conversations about
what happened that.

Q Did you contact Dr. Klein or Debbie Rowe about your concern about Mr.
Jacksons use of pain killers during the Dangerous Tour?
A No sir.

Q Did you ever see Mr. Jackson take drugs?
A No sir.

Q Did you ever see him have any injections?
A No sir.

Q Did you ever give Mr. Jackson any drugs?
A No sir.

Q Did you ever deliver any drugs to Mr. Jackson?
A No sir.

Q Were any drugs ever prescribed in your name for Mr. Jackson?
A I have no knowledge of that occurring, sir.

Q You also mentioned another doctor yesterday -- Dr. Metzger. You indicated he was
a longtime doctor of Mr. Jackson?
A I think he was like a family doctor, that also took care of the Jacksons. He was
around as long as I can remember.

Q When you were asked to bring medication to Bangkok, did you already know Dr.
Metzger?

A Yes sir.

Q Did you discuss with Dr. Metzger about bringing those medications into
Bangkok?
A No sir.

Q And there was never a point on any tour when you ever brought Mr. Jackson any
drugs, is that correct
A (Hesitates..) If you consider Latisse a drug, sir?

Q Do you get that by prescription?
A Yes, Then I would say Latisse is something that I did bring to Michael, sir.

Q What is Latisse?
A Latisse grows eyelashes, sir.

Q And how did that come about?
A Dr. Metzger, sir.

Q Dr. Metzger prescribed this for Mr. Jackson?
A I wanted it because I didnt want him to wear false eyelashes, sir.

Q Was this prescribed in your name?
A I believe it was because the tour was so hectic -- This Is It -- that I wanted to be
able to pick it up close to my house.

Q So Dr. Metzger prescribed Latisse in your name for Mr. Jackson?
A And something else, sir.

Q What else, maam?
A Propecia.

Q This was also prescribed in your name?
A Yes, I picked it up at the same pharmacy.

Q And this was all for Mr. Jackson?
A Yes. It wasnt for me.

Q Is this something that Mr. Jackson went to Dr. Metzger for and then had you pick
up?
A I had a conversation with both Michael, Dr. Metzger and Dr. Klein to make sure
that these things were going to be okay for Michael to take in regard to his cosmetic look.

Q These are direct conversations you had with Dr. Metzger and Dr. Klein?
A Yes, I also discussed Botox, sir. Because everything that I was requesting was for
cosmetic purposes for This Is It.

Q So let me get this. Its Propecia, Latisse and Botox, is that right?
A No I didnt get Botox. I was just inquiring whether it was an option. I wanted to
know if its safe to suggest to Michael. Botox stops sweating, sir.

Q Is that what you inquired for?

A Yes. For his scalp. Because he wears hair that is not all his, so perspiring is a real
issue.

Q Back to the Dangerous Tour. Did you ever talk to any doctors about getting any
prescriptions for Mr. Jackson during?
A Not to my knowledge, sir.

Q Did you talk to anyone in Mr. Jacksons family about him abusing pain killers, at
the time?
A Which time, sir?

Q During the Dangerous Tour, maam.
A I did have conversations with family members about Michaels situation, I dont
think it was during the Dangerous Tour. I think it was after that.

Q With whom did you have conversations?
A The majority of my conversations were with Rebbie, sir.

Q Did you have conversations with other members of Mr. Jacksons family about
your concerns?
A I think La Toya, sir.

Q La Toya Jackson? Any other members?
A In the whole 30 years? Ive had many conversations with his family members
about concerns. I met with his mother and family after he died.

Q No. Just answer up until the time of Mr. Jacksons passing. Any conversations
youve had with any members of Mr. Jacksons family about your concerns about his
drug.
A The one that stands out in my mind is the one with Rebbie, sir.

Q The one with La Toya Jackson, that occurred after?
A Yes, sir.

Q The conversation with Rebbie Jackson happened after the Dangerous Tour?
A Yes.

Q When did it occur?
A I cant remember, sir. it occurred. In my house, in the living room. She came over
to my house.

Q Back to the Dangerous Tour. Youve testified you dont recall having any
conversations with Mr. Jackson about your concerns about his use of pain?
A I said I dont recall any details about a conversation. As Im saying, I kind of
avoided the molestation/drugs issue like the plague.

Q Im only asking about the drugs, maam.
A I avoided them both. Because they were both interconnected, sir.

Q And you said you dont recall having any discussion with Mr. Jackson about being
asked to bring any packages into Bangkok, is that right?
A Not with Mr. Jackson, No. But as I said, when we discussed it much later and it
was brought up, its possible we discussed that but Im not sure if I did.

Q You mean past Dangerous tour time?

A Yes.

Q And you talked about this thing that happened with Dr. Forcast. Where he
attacked you? Did you ever talk to Mr. Jackson about it?
A He was there, sir.

Q Did you ever bring it up to him afterwards and say anything?
A Not until later, sir. Because during that time I didnt want to bring up anything
horrible to him.

Q So then after the tour. Did you ever bring it up with any of his managers?
A No sir.

Q Did you ever bring it up with any one on the tour?
A Probably Michael Bush. Because he was up on stage in the quick change room,
after what I heard in Michaels backstage room. So he was party to the situation.

Q You say you believe this Dr. Forcast was the insurance doctor for Lloyds, is that
right?
A Its kind of what I recall, sir. That he was from Lloyds of London regarding the
insurance.

Q Do you recall why you thought this?
A Somebody told me, I guess. Or it was on a call sheet, I really dont know.

Q Did you ever get the impression that Dr. Forcast was Mr. Jacksons personal
doctor on the tour?

A I never got that impression.

Q Did anyone ever tell you that Dr. Finkelstein was also doctor for rest of the tour,
for the crew and others?
A He served in that purpose also, sir.

Q Did Dr. Finkelstein came to serve Mr. Jackson in Dr. Forcasts absence, how many
times?
A How many times? No, I dont sir.

Panish: Objection. No foundation of the facts. Counsel is testifying.

Judge: Sustained.

Q So this tour ended with Mr. Jackson going into a rehab, correct?
A Correct, sir.

Q And did you come to understand that he went into rehab because of his addiction
problem to pain killers?
A Yes sir.

Q He went to England?
A Yes sir.

Q And you said yesterday that at the time, you didnt know where hed gone until
someone contacted you and told you where he was, correct?

A Nobody ever told me where he was. They just said they wanted me to go.

Q So I want to break that down.
A Okay.

Q So by the time the tour ended, you were in Mexico, correct?
A Correct.

Q Did you talk to Mr. Jackson in Mexico about him leaving to go to England?
A No. He didnt know, sir.

Q What do you mean, he didnt know?
A I dont think he knew there was going to be someone intervening to take him
away and try and help him.

Q So you knew after he was gone. Thats not something anyone discussed with you
prior to him leaving?
A Im trying to take myself back there, I dont know if I knew Elizabeth Taylor was
coming or if she was called, or I didnt know, sir.

Q And you came to find out where he was from the television, right?
A No. The TV and media was searching for him. I dont think they knew where he
was. I wasnt even told where he was, sir. When they asked me to go.

Q Who asked you to go?
A Trying to think if it was Norma or Evvy in charge then. Those were two assistants
that overlapped at one time.

Q Assistants to whom?
A Personal assistants. They stayed at home in Los Angeles and handled secretarial
duties.

Q Personal assistants to Mr. Jackson?
A Yes.

Q So one of these personal assistants contacted you and asked you to go to Mr.
Jackson, wherever he was?
A Yes.

Q Youre back in Los Angeles by now. Did you ever try to reach out to Mr. Jackson
to see if he was okay?
A I was concerned, sir, I would have asked his people if he was okay. But it was not
my business. I wasnt to know where he was. The media wasnt to know where he is.
Thats not something I would pressure anyone to tell me

Q You came to understand that Elizabeth Taylor was involved. Did you discuss that
with her?
A No, sir.

Q When you went to visit Mr. Jackson, did you speak to anyone other than him
while you were there?
A Yes, sir.

Q Who did you speak with?

A I spoke with the person in charge of his therapy -- I cant remember his name --
maybe you can tell me, he also had worked with Elton John. He asked about my concerns
and I said I was afraid Michael could die. And he told me --

AEG (Stebbins): Objection.

Karen Faye: Oh my, are you objecting? Sidebar.
Panish: Are they objecting to their own questions now?

(laughter in the courtroom)

Q Um. What I was asking was -- you were telling the therapist about some concerns,
and you said you were concerned that Mr. Jackson might die.
A He asked me what why concerns were -- for Michael. I stated the worst case
scenario, that this could kill him.

Q So the only time you saw Mr. Jackson somewhat effected by drugs was that one
time in Singapore during the Dangerous Tour, is that right?
A It was always a concern. was something that I was always watching out for.
When the date was cancelled, I was concerned. There were times when he was okay, and
there were times when I was worried.

Q Can you recall any other time during the Dangerous Tour seeing him under the
influence of drugs?
A We did so many dates and traveled so much, sir. Youre talking about years ago,
and I cannot recall specifics other than the really dramatic situation that occurred.

Q So other than that really dramatic situation in Singapore, do you recall any other
time during the Dangerous Tour that you saw something --
A It was always a concern, sir.

Q I understand that. Im asking you if you remember any other times during the
Dangerous Tour where you thought he was under the influence of drugs?
A Im just really confused by this. Im telling you. That this entire leg of the tour, I
was really concerned. Doctors were telling me they were working on the BALANCE of
-- killing the pain for him, and being able to perform. I was always conscious of what was
happening during this part of the tour. Other than the traumatic ones. I cant really recall
any specific time.

Q Was this the only time you ever saw Mr. Jackson in rehab?
A Yes.

Q Youre not sure how many days you were there, right?
A I cant really recall. I believe I stayed overnight there -- for a few days.

Q Did you come to an understanding whether Mr. Jackson thought he should be
there?
A Yes. We had a conversation.

Q And did he think he should be there?
A No sir.

Q Why not?
A He didnt think he had a problem, sir.

Q Did you tell him that you thought he did have a problem?
A I encouraged the situation. I said: This is a nice place. Everybody is really nice. I
think its good for you.

Q Did you remind him what happened in Singapore?
A I dont recall.

Q Did you find out why Mr. Jackson wanted you to come and see him?
A I think he wanted me to come and maintain him -- a little bit cosmetically and I
think for moral support. I washed his hair. Did those sort of things.

Q Getting Mr. Jacksons hair ready was a somewhat involved process -- more than
just a shampoo?
A Yes it was.

Q You said yesterday that during the criminal trial a couple years later, you would
start at 3am getting him ready, correct?
A I would get there then because it was a process of him coming up to the room
where we worked. Going through the process. Yes.

Q Now. After Mr. Jackson left rehab, do you remember him making a public
announcement about going to rehab?
A He made a public announcement regarding the situation. Yes, sir. He personally
explained in his own words what was wrong.

(Putnam plays AUDIO clip of Michaels initial Nov. 1993 announcement, NOT the
televised Dec. 1993 VIDEO clip announcement from Neverland)

Q Do you remember that?

A I remember the visual of that. He had the eyelashes that I didnt -- that I hated.

Q Say that again?
A He was wearing the eyelashes. He wanted me to put the eyelashes on. I didnt
want to, but I did.

Q Are you saying you put the eyelashes on him to accompany the video?
A Yes. I went up to Neverland to get it right.

Q And you watched the filming of the announcement?
A You asked me this in the deposition. I usually was in the room, but I cant
remember if I watched him or if I did his makeup and then he went in another room to
make the announcement.

Q Now. If announcement occurred the day after the tour ended --
A Wait. It happened the day after the tour ended?

Q Let me ask that question. Do you know when this occurred?
A I have to say -- (long pause) I have to say I cant accurately say when that
happened, sir.

Q And do you know whether this happened prior to you visiting Mr. Jackson in the
UK?
A I cant recall, sir.

Q You do recall telling me that morning that Mr. Jackson left. You didnt know
where he was. You ultimately came to understand that he was in the United Kingdom?

A I did, sir.

Q Doesnt this prove you knew where he was because you helped him with this
before?
A Well if he did this announcement before -- oh gosh. This is a long time ago, how
long is this? Mexico City. (long pause) I really cant recall. I know I was there to do his
makeup for the announcement. So if he came home and did that before he left? You got
me, Im sorry.

Q Why is that?
A Well no. I mean my memory is being -- Im trying to logistically recall things,
and a lot of it is difficult for me.

Q Well let me ask you about that.
A Because youre a lawyer. And youre trying to, you know -- youre doing your
job, sir.

Q You have a long history of doing tweets online.
A Yes sir.

Q Do you blog?
A I do have, yes. I guess you could say that. I havent been there in a long time.

Q And a website?
A Yes.

Q It would be fair to say youve put out hundreds if not thousands of tweets on
Michael Jackson?

A Probably.

Q And in this blog youve written extensively about your relationship with Mr.
Jackson?
A Not extensively. I wrote for awhile. It was too painful so I stopped writing.

Q The photos we saw yesterday were photos from that blog?
A I havent been there in a very long time. The photos? On my blog? I dont know
where they are. I put them on different sites.

Q You have different sites?
A Yes. I have different accounts. I use the internet, sir.

Q And there are a number of Michael Jackson fan sites out there?
A There are.

Q Is it true youve posted and communicated on those websites?
A Well during the time that I worked for MJJSource. But I havent -- I dont go and
post on sites.

Q Whats MJJSource?
A MJJSource was a website that Michael and Randy Jackson created together to
have a vehicle for the truth to get out about the trial. The impending trial of the
molestation charges.

Q In fact, in all of these tweets and blogs you have said a number of unfavorable
things about AEG, havent you?
A Ive stated the truth as far as my experience, sir.

Q My question was not about truth. Have you or have you not posted a number of
unfavorable things about AEG?
A I have to give you the same answer on that, sir.

Q Im not asking you to give me the same answer on that. I asking you if you
understand the term unfavorable?
A I guess you -- unfavorable. Could you please define the word unfavorable?

Q Putting things on the internet about AEG in which you paint them in a light one
would consider not favorable. A bad light.
A I paint them in a truthful light based on my experience, sir.

Q Do you consider that a positive light. Are you lauding AEG on these sites?
A No Im not lauding them. Im not singing their praises.

Q You said before Id be happy if you couldnt remember the facts. Im trying to
figure out why you said that. Is it because of the various things youve said on websites?
A No because youre a lawyer, sir.

Q Lets get back to this for a minute -- rehab. You saw and heard this announcement.
And youre saying you not sure if youd been there, correct?
A Im sorry. Can you say that again?

Q You did not know where Mr. Jackson was when he was going into rehab?
A Correct.

Q But you are sure you were there for the announcement?
A I did his makeup and hair, sir. The visual.

Q And are you sure this visual, that youre sure you were present at, is the visual that
accompanied this announcement?
A I just know the visual one. Im not familiar with the written one you showed
there.

Q After you saw Mr. Jackson in rehab, did you come back to the States?
A Yes.

Q And you said when you were there that Mr. Jackson didnt think he should be
there, right?
A Correct.

Q Did you tell his family that?
A I wasnt in contact with his family.

Q Did you let his managers know that Mr. Jackson didnt think he should be there?
A I wasnt in contact with his managers, sir.

Q What about his doctors? Did you let his doctors know?
A I wasnt in contact with his doctors, sir.

Q So that happened in 1993. Did you continue to work with Mr. Jackson after he
returned from rehab?
A Yes sir.

Q The next tour was the History Tour in 1996. In between the end of the Dangerous
Tour and the History Tour, did you work with Mr. Jackson during those 3 years?
A Im sure I did. I continued to work with Michael as a client.

Q During that period did you ever talk to him about his time in rehab?
A I can remember, sir.

Q Do you remember during this time ever being concerned about Mr. Jacksons drug
use?
A Im just trying to remember what was happening. Im not sure if we were
shooting short films or -- can you tell me what Michael was doing professionally at that
time? Because thats how I relate to see what was going on, because I worked for him.

Q How did you work for him?
A I worked as a makeup and hair artist for him, sir.

Q Im going to sorely disappoint you right now. And your understanding of lawyers.
I have no idea. Do you recall at all?
A What album was out?

Q Right now its History.
A History was coming out. Okay. There was a History trailer in Budapest. Thats
when he married Lisa Marie, I believe. During that period of time.

Q State her full name for the record.
A Lisa Marie Presley, sir. I believe he was staying in New York at the time. I went
to Budapest. I cant recall having any concerns during that period of time.

Q Did you attend Mr. Jacksons wedding?
A With Lisa Marie -- Presley? No sir.

Q Did you do his hair for it?
A No. He got married in the Dominican Republic. So I did not.

Q So the History Tour is 1996 1997. You went on this tour right?
A A portion of it.

Q But this is the tour you were informed your services were not longer needed?
A After the first leg.

Q Who asked you to be on the tour?
A Michael.

Q You indicated Mr. Ortega was on this tour. Do you know what he did?
A Creative director, as usual.

Q Was Travis Payne on this tour again?
A I believe so.

Q He was choreographer.
A A dancer, choreographer.

Q And this is the tour where Paul Gongaware had a higher position than on the
Dangerous Tour, correct?
A It appeared to be so.

Q Did you know if there was company called AEG at this time?
A I wasnt familiar with that.

Q You hadnt heard of them then, right?
A No. Not that I can recall ever hearing about.

Q Who was Paul Gongaware working for on this tour?
A I assumed Tarock and whatever organization was setup at that time.

Q Who was Tarock?
A There was a Saudi Prince or King running things at that time.

Q Was Tarock Saudi royalty?
A No. He was working with them, I believe. Youre talking again, above the line.
These were people who I never knew their exact positions. I was just doing my job as
makeup and hair artist. I wasnt inquiring what position everybody had. It was pretty
aloof.

Q What do you mean by above the line and below the line.
A The chain of command. There are the worker bees and there are people that the
worker bees work for and report to.

Q Mr. Tarock was above the line?

A Yes.

Q He was Mr. Jacksons manager?
A I wouldnt put a label on him that he was, sir.

Q You traveled with him on the History Tour?
A He traveled in a different group from me. He traveled in the A group, I traveled in
the B group. I would say he was working in a capacity similar to Paul Gongaware.
Personally negotiating my contract. Somebody making the rules.

Q When you say somebody similar to Paul Gongaware, are you talking about Paul
Gongaware role on the This Is It Tour?
A All I know is I had to go in and negotiate with Tarock on this tour, and I also had
conversations in the same regard with Paul Gongaware.

Q You had conversations with both Tarock and Paul Gongaware during the History
Tour to negotiate your contract?
A From what I gathered, it was two people I had to deal with, go through and report
to.

Q You didnt continue after the first leg of this tour. Was that after you had an
argument with this Tarock?
A Yes sir.

Q And what was that argument about?
A Tarock was trying to get rid of me, sir. And I felt that he was making things very
difficult for me. He was telling me that he would allow me to do Michaels makeup but I
wasnt allowed to speak to Michael while doing so. And my pay would be reduced. And
the figure he gave me was a very low amount. Ive got a child and a home to support and
there was no way I could financially handle that.

Q Did you understand why Tarock during History Tour wanted you to do Mr.
Jacksons hair but not speak with him?
A It was never explained to me why. But my feeling was that it was about control.

Q When you say control, what do you mean, maam?
A Most every manager that came through Michael always wanted to replace me.
Because I was in a position that stood in front of Michael and touched him. And it was
always very evident -- and Michael even told me -- about all the management wanting to
replace me with someone they wanted there in front of Michael. Its pretty common in
Hollywood. Theres a power struggle. The ones at the top want to have complete control
over people below the line. So it was pretty common for me to have someone above the
line not want me in Michaels company for long periods of time.

Q So Tarock told you that your services would no longer be needed?
A Correct.

Q Did you discuss this with Mr. Jackson?
A No. Not until afterwards.

Q When was that?
A When I came back. When Tarock was gone and Michael asked for me back. After
the History Tour.

Q Did Mr. Jackson or his manager reach out to you and ask you why you werent
returning?
A His manager. Who was his manager, sir?

Q I dont know. I asked you if Tarock was. You said you didnt know.

A Well he certainly didnt reach out to me to find out why. He was the one who
released me, sir.

Q Mr. Jackson didnt ask you why you werent there?
A No sir.

Q Your understanding is that Mr. Jackson knew that you werent going to be
continuing on the tour?
A Michael Jackson told Michael Bush. He asked Michael Bush why I wasnt there.

Q So you had an understanding that Mr. Jackson didnt know why you werent
there?
A By Michael Bush telling me that Michael Jackson was asking HIM why I wasnt
there, kind of indicated that he didnt know. But I really dont know what anyone knew or
didnt know, sir. Because I wasnt there.

Q Did you ever come to have a belief that Debbie Rowe had been involved in you
not being there?
A A little bit, sir.

Q Who was Ms. Rowe at the time?
A At the time, that was his wife.

Q You indicated a moment ago that you thought Lisa Marie Presley was his wife. So
Im a little confused.
A Pardon?

Q So at this time who -- Lisa Marie Presley was not his wife at this time?

A No. Not the History Tour, sir.

Q So you came to believe that his wife, Ms. Rowe had some role in your being
asked not to continue on tour?
A Actually, after it happened she told me she was. After I was back. She apologized
to me for playing a role in that situation.

Q Did you understand what role she played?
A This is so complicated. I needed another person to work on tour with me. Debbie
Rowe introduced me to a hairdresser named Tommy Simms, a good friend of hers. I liked
Tommy very much and I took him with me on tour to work with us. There was a lot going
on that I wasnt privy to, or didnt really understand about all of this. Debbie Rowe was
pregnant. And she was obviously in love with Michael Jackson. She had told me for
many years. That was her desire to be with him. She told me that she was jealous of me
being there as Michaels makeup artist. She thought that Michael liked me better than her.
And she felt more comfortable with her friend, Tommy Simms taking my place.

Q So you were on the first leg of the History Tour in 1996. Youd seen Mr. Jackson
in rehab in 1993. You said you were often concerned in the Dangerous Tour that Mr.
Jackson was obviously using drugs. Were you ever concerned that Mr. Jackson was using
drugs during the History Tour?
A To be honest, I was always concerned. But he seemed to be fine on this part of
the tour, sir.

Q So even with the previous history, you didnt see anything on this tour that was of
concern to you?
A That I can recall, sir.

Q You mentioned yesterday there were doctors you saw on this tour. Dr. Ratner?
A I think I only saw him in the hallway once, at the very end of the first leg.

Q What about Dr. Klein? Did you see Dr. Klein on this tour?
A I cant recall if I ever saw him, sir.

Q What about Dr. Metzger? You didnt see Dr. Metzger on this tour?
A I cant recall seeing him.

Q So there was a time when you started working with Mr. Jackson again, Do you
remember how that came to be?
A Just that Evvy called and said: Michael wants to talk to you and would like to
have you back. How do you feel about that? And I said: Great.

Q Did you ever explain to Mr. Jackson what happened with Tarock?
A A little bit. Because he was in the room when he asked Debbie to apologize to
me. So there was discussions and apologies regarding that situation.

Q Yesterday you talked about an incident in Munich where a bridge collapsed. Do
you recall if that was in 1999?
A I dont recall the exact year, sir.

Q It was 1999.
A Seoul and then Munich.

Q Mr. Ortega was actually working with Mr. Jackson on those two concerts, wasnt
he?
A Correct.

Q Was Mr. Payne working again, as well?

A I think so, sir.

Q Paul Gongaware had no role, correct?
A Not to my recollection.

Q You described yesterday the bridge collapsed. Mr. Jackson fell. You witnessed that
first hand, right?
A Yes.

Q You said you were devastated?
A It was frightening to watch, sir.

Q You remember saying that you thought he might be dead?
A When the bridge went past the stage and I couldnt see it -- it went into the
orchestra pit -- I didnt know what happened and I thought it was possible.

Q Im going to show you the whole clip if I may.
A Okay. Were going to watch this again.

(Putnam plays clip of Munich bridge collapse)

Q Did Mr. Jackson seem thin to you there?
A I wasnt looking for that, sir. He always slender. Well not always. There were
times when he got a little hefty, like at the end of the Mexican -- when we took him out,
he was a little heavier.

Q Let me just try and understand. So youre saying he got a little thinner at the time
he went to rehab?
A Yes sir.

Q Can you remember any other time when Mr. Jackson was heavier?
A In New York, at the release of Invincible, he was heavier.

Q At this time in Seoul and Munich, were you concerned about Mr. Jacksons drug
use?
A No sir.

Q So this is 1999. And you continued to work with Mr. Jackson at Anniversary
Show, the 30
th
--
A The Madison Square Garden show. Yes.

Q Madison in 2002.
A Yes.

Q This is the show you talked about yesterday where you said there was a doctor
who gave drugs to him?
A I just went to the door to get him ready and the doctor was present when I
knocked on the door.

Q Was this a different doctor?
A Yes sir.

Q Was this a doctor youd ever seen before?

A I didnt recognize him, sir.

Q Was this a doctor you ever saw again?
A I dont think I ever saw him after that.

Q Did you know his name?
A No sir.

Q Did you know how he knew him?
A He told me he gave Michael a sleeping aid.

Q Did he say what that sleeping aid was?
A No sir.

Q But he said it would make him sleep for 5 or 6 hours?
A He said Michael would be asleep. Come back in 5 or 6 hours.

Q Did you see Michael and concur if he was there at that time?
A Michael was there. I think Frank Cascio went up to his bedroom and got him up
for me and brought him, because I didnt go into his bedroom.

Q Why do you say that?
A Im a lady, sir. I dont go into mens bedrooms unannounced.

Q So Mr. Cascio went to get him. Who is Mr. Cascio?

A He was working as Michael Jacksons assistant, and friend.

Q Do you know who Mr. Jacksons manager was at this time?
A I dont think he had one at that time. I dont know if Dieter Weisner was there at
the time? But I dont think he was. I cant recall.

Q Is Dieter Weisner another person who served at some point as one of Mr.
Jacksons managers?
A I mean -- managers? We are throwing around that term rather loosely so -- even
when they were working for Michael it was kind of vague as to what a manager was and
who was managing and what their role was. There were people that were involved in
Michaels business -- managing his career, managing his money -- its really not clear to
me what you mean by manager. When you ask me that, I really cant answer if they were
a manager, so to speak. There were people that may have been his manager that didnt
work in a position that I would call a manager.

Q So let me ask you. Did you have an understanding whether or not someone was
Michael Jacksons manager or were these just things you presumed? For example Tarock.
You said you thought he might be his manager. Did they ever tell you that?
A To me it was above the line, and below the line. Thats as clear as it ever got for
me. As I said, I was never really sure what position the line of responsibilities went above
the line. Because there were a lot of people around. A lot. There was Charles Bobbit. I
was never sure of their position. Nor did I ask anyone to clarify that to me.

Q So at various points youve been asked if someone was a manager. Youve
indicated what role you thought someone was playing. So those are presumptions and not
something anyone ever told you?

Panish: Objection. Vague and assuming. A number of people have been named.
Judge: Overruled.

Q Your distinction is above or below the line?

A Thats one of the factors, sir. Yes.

Q Now. After that you continue to work with Mr. Jackson. Another time -- a very
difficult time -- which was in the early 2000s during the criminal trial.
A That was the mid-2000s, I believe. Oh, the charges, yes. We were in Las Vegas
when that happened. When we found out.

Q And what were you doing in Las Vegas, maam?
A We were doing a short film, sir.

Q What short film were you working on?
A It was for a song off of Invincible, I cant recall right now. [One More Chance]
It was so short. Because we --

Q This is 2003. 2005 was the actual criminal trial, correct?
A Correct.

Q You continued to serve as Mr. Jacksons hair and makeup person. You talked
yesterday about arriving there at 3am to help put his hair and makeup together for the
trial, correct?
A Correct.

Q You also said this morning that you were working with Mr. Randy Jackson. Was
that. Was this during that time period?
A I cant say I was working with Randy Jackson. I was working on the website.

Q This was the website conceived by Mr. Randy Jackson and Mr. Michael Jackson?
A Correct.

Q Were you also working with Tanya Zilkie on the website?
A Correct.

Q Ms. Zilkie who you said this morning was also your representative/agent?
A Thats how we met.

Q I just want to understand. You met working on the website?
A We met over the phone first.

Q You met over the phone. Was it regarding you coming to work on this website in
support of Mr. Michael Jackson during the criminal trial?
A Correct.

Q Ms. Zilkie later comes to represent you as your manager?
A Not a manager. She didnt manage my career. It was after the trial. The trial was
over and Michael was acquitted. That time period we all spent together was very intense.
And we got very close, sir. And -- we said now what? We were picking up the pieces of
our lives after this. She was a good organizer and we had a good rapport on the website. I
asked if she would be interested in repping me. Not managing my career, not finding me
work, but a liaison for when things arose. Its not good for artists to negotiate money with
your clients. I needed somebody to help me negotiate contracts.

Q Yesterday you said there was a time during the criminal trial when you became
concerned again about Mr. Jackson. Was that because of possible drug use?
A Sir, the signs were there.

Q What were the signs, maam?
A Him going to the hospital. The physical pain. Because when he was under stress
-- he could not sleep, his back hurt from the injuries, and -- just the emotional of having
to go through that. Its bad enough for me here to talk about it. I cant imagine what he
endured.

Q So you started to have concerns. How long did the trial go on?
A I think 3 months, or something.

Q And during this time did you become increasingly concerned he was taking drugs
again?
A I was increasingly concerned for his well-being, sir.

Q And this morning you talked about praying together every day while getting him
ready, right?
A Yes.

Q During these endless times together, did you express your concern to Mr. Jackson
about him using drugs again?
A No sir.

Q And during any of those times, you said you were working with them at the time,
did you ever express a concern to Mr. Randy Jackson or Tanya Zilkie about Mr. Jackson
using drugs again?
A I dont think so, sir.

Q And Mrs. Jackson -- Katherine Jackson. She was there every day of the trial, is
that right?

A Yes sir.

Q Did you go to trial during the day?
A I wasnt allowed, sir. I was on the witness list.

Q Did you testify at the trial?
A No I did not.

Q Other than Randy Jackson or Tanya Zilkie, did you discuss your concerns about
Mr. Jacksons drug use with anyone else?
A Michael Bush.

Q Thats the man who was dressing Mr. Jackson?
A Correct.

Q But never with Mr. Jackson himself, correct?
A No sir.

Q And is there a reason for that?
A I have to go back to, the time I spent with him was a time of peace. Not
confrontation. He had to go into court. I didnt see him other than that space in time every
morning. It was my job. It was my duty as a friend. To make that time and space as
peaceful and calm as I could before he had to go were he had to go. I didnt want to
confront him with anything. And no matter what he was doing, I could never blame him
for that. Because of the pain. Physical, psychological, emotional pain.

Q Did Mr. Jackson ever ask you for any pain killers?
A He asked me one time.

Q And what did you tell him?
A I said no. I dont.

Q Did he ever ask you again for that?
A Never.

Q Did you say anything to him when he asked you for pain killers about your
concern about him doing drugs again?
A No sir.

Q Did you ever see Mr. Jackson use drugs during this time period?
A No sir.

Q Did you ever see him during this time where you thought he was on drugs?
A When he went to the hospital, sir. It appeared that they had given him some sort
of pain relief.

Q Any other time after the hospital when he appeared that way?
A Well on pajama day it was really evident, sir.

Q That was the day you took him back from the hospital?
A No. I watched it on TV when he got out of the car.

Q You saw him on TV, you thought he was under the influence?

A He went to the hospital. The pain increased. His stress increased. His weight went
down drastically.

Q Did you have an understanding why Mr. Jackson went to the hospital?
A Yes. He told me he was suffering extreme pain in his back.

Q Did he indicate this pain was in any way associated with the fall in Munich?
A Yes.

Q But you didnt believe him?
A I believe that. I believed he was in pain. And I believe that when he got very
slender and very weak, it aggravated that injury.

Q Did a time ever come where Mr. Jackson admitted to you he ever had a problem
with drugs?
A Admitted to me personally or admitted publicly, sir?

Q Admitted to you personally, maam.
A No sir.

Q You said a time came where you had a conversation with Ms. Rebbie Jackson
about concerns about Mr. Jacksons drug use, correct?
A Correct.

Q Was it during this time?
A As I said before, I cant remember exactly what time period it was, sir.

Q It happened at your house?

A Yes it did.

Q Did you reach out to her about your concern?
A She reached out to me, sir.

Q Did you have an understanding why she reached out to you?
A Yes, she told me. She was asking me -- about her brother.

Q Do you recall what you told her?
A Everything I could, sir. I answered all of her questions.

Q Do you know whether this happened after the criminal trial?
A I told you before, I cant recall. I really cant. I dont know. All in can say is, it
was probably between 1990 and 2005. Im just not clear when this was. I wish I could tell
you. I really do. I mean, maybe Rebbie knows. Maybe she recalls. Ask her.

Q Had you ever had this type of conversation with any member of his family
before?
A Not to this extent.

Q Did you ever have this type of conversation with any member of his family about
this after that prior to the time of his passing?
A Wait. Between when and when?

Q You said you had this conversation with Ms. Rebbie Jackson between 1990 and
2005. Did you ever have this type of conversation with any member of his family after
this conversation, up until the time of his passing?

A I believe I had conversations, but in a very brief manner, with Randy Jackson
during this time. I believe there were brief mentions with Randy Jackson because of the
trial situation during this time. There were concerns about his condition.

Q And do you know if anyone ever did anything as a result of those concerns? For
example: Was there any attempt to get him into rehab again?
A Its my understanding that there were.

Q Is it your understanding that the family actually tried to get him into rehab?
A Its my understanding that there were efforts to help Michael.

Q Do you have an understanding if that happened more than once?
A Its my understanding that there were several, sir.

Q Is it your understanding whether or not they were ever successful in getting Mr.
Jackson to go into rehab?
A I never knew that to be successful, sir.

Q Did you know it not to be successful? Did you know if they actually failed in their
attempts?
A Its my understanding that they did not succeed in getting him into rehab, sir.

Q So Rebbie Jackson had come to talk to you in connection with trying to get her
brother into rehab?
A Rebbie cared about her brother very much. And she was very, very concerned
about his well-being. And Im sure they were trying to help Michael in any way they
could.

Q Did you ask his family why they came to talk to you about Mr. Jackson and drug
use?
A They had suspicions and Im the one who spent a great deal of time with him.

Q Do you know why they had suspicions?
A No. They just had suspicions.

Q Do you know if they spoke to anyone else about these suspicions?
A Im a person they spoke to. I dont know if they spoke to anyone else.

Q The criminal trial occurred in 2005, right?
A Yes sir.

Q And at the end of the criminal trial Mr. Jackson was acquitted?
A Yes sir.

Q Did he leave the country then?
A To my knowledge he left the country.

Q Where were you when the verdict was announced and he was acquitted?
A I was in a hotel room in Solvang, sir.

Q Solvang is a town near Mr. Jacksons estate?
A Correct, sir.

Q Is that were you stayed through the criminal trial?

A Many days, yes.

Q Was anyone with you?
A Tanya and my daughter.

Q Tanya Zilkie?
A Yes.

Q How soon thereafter did you see Mr. Jackson?
A After -- I never saw him.

Q So you were in the hotel room and they announced that he was acquitted. But you
didnt see him for several years after the acquittal, right?
A I did not.

Q So youre in the hotel room. Its announced. And you had been with him every
day correct?
A Correct.

Q And the then you didnt see him again for several years?
A Correct.

Q And so he left the country. And you didnt know what happened, right?
A Not exactly, sir. I saw it in the media. People explained to me.

Q This is in 2005. Did you come to understand that hed left and gone to Bahrain?
A Yes sir.

Q When was the next time that you saw Michael Jackson?
A Saw him or talked to him?

Q Saw him.
A At Carolwood, sir.

Q At Carolwood. Thats where he was living while preparing for the This Is It tour?
A Correct.

Q So that would be 2009?
A Correct.


(Court adjourned for the day)