Jacksons vs AEG Testimonys

[manu29]

Jackson V AEG – Det Martinez

Jackson Family in court. Mrs Jackson. Rebbie(her daughter)
Jessica Stebbins attorney for AEGLive objected to Rebbie’s presence in court, citing the Judge stated only
Randy could be in court to support his mother, this is not correct. Panish explained various family
members will be in court. One at a time and that Randy and other family members have commitments so
cannot be in court everyday for next five months, Judge allowed Rebbie to remain in court to show
support for her Mother(Mrs Katherine Jackson)
ORLANDO MARTINEZ

(Detective for the Los Angeles Police Department, LAPD)
Plaintiff’s Witness.
Continued direct examination by Jackson attorney, Brian Panish.
Panish with Detective Martinez, continuing to present official document exhibits which show Conrad
Murray was in desperate, dire straits financially — revealing a financial motive.
Murray’s Experian credit report: Mortgage with Bank for $1, 606, 000. Delinquent $95,166.
Murray’s Equifax credit report: Mortgage with Bank for $1, 644, 644. Delinquent $95,166.

Detective Martinez is not a forensic document authenticator. Murray’s credit reports were obtained only to
check the health of his finances.
Next document: A Default Judgment for 233,000.
Panish moves on, asks Martinez about fingerprints on the propofol bottles. Detective Martinez: Some of
the fingerprints were identified as Conrad Murray’s. Some of the fingerprints were unidentifiable.
Murray’s cell phone records from June 12th to June 26th. Drug Enforcement Administration (DEA)
assisted in recovering data from Murray’s cell phone. Panish plays a recorded voicemail from June 20,
2009 sent by Frank Dileo to Murray.
Dileo: Dr. Murray, it’s Frank Dileo, Michael‘s manager. Please call me. I’m sure you’re aware he had an
episode last night. He’s sick. I’m on my way back tomorrow. I think you need to get a blood test on him.
We have to see what he’s doing.
In the course of his investigation, Detective Martinez found no blood test that was ever done on Michael
Jackson between June 20th and the day he died.
Warranted search on Texas storage unit owned by Murray. Items located: 1.) May 1, 2008 letter from
Doctor’s Hospital suspending Murray’s medical privileges, in treating of patients. 2.) Another letter to
Murray citing issues of his disregard of medical policies and procedures. 3.) Another document citing
problems with Murray’s practice of medicine. 4.) Notice to Murray that he had to pay his taxes.
Detective Martinez did not investigate the relationship between AEG and Conrad Murray, as it was not part
of the crime he was investigating. He focused on the 12-hour period of care during the early morning
hours of June 25, 2009.
Panish: Based on your years of experience, after viewing all of these documents and all you’ve seen, was
there any doubt in your mind that Conrad Murray was in severe, desperate financial straits as of May-
June-July 2009?
Detective Martinez: No, there’s no doubt.
Cross examination by Marvin Putnam.
Putnam refers to the interview Detective Martinez and other detective did with Murray on June 27, 2009.
He asks Martinez if he hadn’t asked Murray about his relationship with AEG during the interview. Martinez:
Very vaguely.
Detective Martinez with LAPD for 19 years, in Robbery/Homicide. Assigned to investigate death of Michael
Jackson on June 25, 2009. Detective Dan Myres and Detective Smith — his partners on the case.
Putnam asks about Martinez being at the UCLA Medical Center on June 25, 2009. When he and his
partners looked for Murray at the hospital, he was gone. They traced his cell phone to Santa Monica.
Murray was not answering phone. Murray’s car was at Carolwood house.
Putnam: Regarding Panish’s question about Murray having spoken with AEG representatives at the
hospital, how do you know that? Martinez: Based on my interview with him on the 27th, Murray said so.
Martinez went to the Carolwood house after the hospital.
Judge: While you were at the hospital, was the Carolwood location secured? Martinez: Yes, three
detectives, on site security guards, police vehicle parked on street.

Putnam: Were any family members at Carolwood house when you arrived the night of the 25th, after
leaving the hospital. Detective Martinez: When I arrived, Michael’s children were there, Randy Jackson.
Later, I believe Michael’s father and mother, Rebbie and LaToya Jackson arrived.
Putnam refers to the mapping of the Carolwood house, done by the detectives as part of the
investigation. He goes through a lengthy naming of all the rooms in the house, first and second floors.
Putnam: Was there a “mess” in any of the rooms on the first floor like the “state of disarray” in the master
bedroom were the incident occurred? Detective Martinez: No. Putnam: So downstairs was “all pristine and
clean” and the upstairs looked like this (referring to an LAPD evidence photo). Martinez: Yes.
Putnam then shows a photo of the master bath “in disarray” and makes the same comparative inference
about the downstairs being neat and clean and the upstairs being in disarray. Like night and day.
Putnam: How much time were just your officers — not the family, not security — securing the house?
Martinez: From about 2:30pm until about midnight on June 25th. Putnam: So other than the times you
were there on the 25th 26th and the 29th, family members and security were allowed to come in and out
of the house? Martinez: Yes.
Detective Martinez obtained a search warrant to go back into the house the next day, on the 26th of
June, based on information from the coroner‘s office and from Jeffrey Phillips (on the 26th). Putnam
shows exhibit of the sealing order with Martinez’s notation that staff was not allowed upstairs, other than
the chef, Kai Chase, to drop off food. He found this out when he interviewed the staff.
Putnam: Someone told you on the 26th that there were other things around, that they had found while
looking through luggage. So you had an understanding that people were going through things before you
arrived on the 26th? Martinez: Yes.
Judge wants to know if these were law enforcement people. Putnam says he’s getting to that question.
Detective Martinez: Family members and friends of the Jackson family.
Putnam: Do you know if they’d been doing that prior to you arriving on the 25th?
Detective Martinez: Security told me that had not happened.
Putnam: Hadn’t happened? So they hadn’t been going through stuff on the 25th, but they had gone
through stuff prior to your arrival on the 26th?
Detective Martinez: That’s correct.
Putnam: The reason I’m asking is because that state of disarray we saw, that was prior to anyone going
through stuff?
Detective Martinez: Yes.
Putnam: Did any family members hand anything over to you to be investigated?
Detective Martinez: Not to me, but to chief coroner/investigator Winter, who gave it to me.
As of the 26th the investigation was for cause of death. It had not yet been turned into a criminal
investigation.
Detective Martinez was finally contacted by Conrad Murray’s lawyers to set up the June 27th interview
with Murray by the detectives. The interview was recorded and transcribed. Murray said he was Michael
Jackson’s personal doctor. Murray mentioned that he had left his medical bag in the foyer closet in master
bedroom. Martinez went in with a search warrant and found the bag with propofol bottles. Martinez had
known about the propofol prior to the interview. He had found a vile of it under the nightstand on the
25th.
Putnam: So prior to Murray telling you “there‘s a bag of propofol, you should go look at it“, you hadn’t
found that bag of propofol?

Panish: Objection. Vague.
Judge: Sustained.
Putnam: As a result of the interview, you found the bag with all that propofol in it?
Martinez: There were bags.
Putnam: That’s something you hadn’t found previously?
Martinez: Yes.
(afternoon break)
Typed by ToMJRespectIsDue
Detective Orlando Martinez on the Stand, Cross by AEG
After the interview with Conrad Murray, Detective Martinez went to the CarolWood estate where the
investigation continued. Just as the day before Martinez confirmed the images he was shown in the photos
these are the photos that were taken to help Martinez build a case and determine motive.
As early as April 6 2009, Murray was ordering propofol in Las Vegas and then shipped it to Santa Monica.
This was determined through the department’s investigation via search warrants and subpoenas.
Counsel (AEG) wants to go over Michael’s room again and talk about the various medical equipment like IV
stands, ambu bags oxygen tanks that were discovered in the room. Counsel (AEG) asked if the detective
ever determined how Murray obtained the equipment and Det. Martinez says that Conrad Murray rented
the equipment from a medical company in California. When asked who paid for the equipment, Murray is
the person who supposedly paid for the items and he was also paying for the propofol to be shipped to
California
July 24 2009 Murray was declared a suspect and on August 24 coroner’s report was completed and
Michael’s death declared a homicide. Murray was charged with involuntary manslaughter on February 28
2010
Thru a search warrant and physical search of Dr. Murray’s storage unit, Det. Martinez learned that Dr.
Murray was being cited by Sunrise Hospital in Las Vegas because his patient medical records were not up
to date. He was also failing to respond to hospital calls within the 20 minute time frame; many times he
would return the calls around an hour or so later. The frequency of these occurrences caused the hospital
to send warning letters and when those warnings were ignored, the hospital decided to suspend his
privileges. AEG attorney asked if this type of information would be obtainable by someone without a
certain classification by going to the medical board.
AEG went on to ask, if it was at all possible to easily access evidence whether or not Murray at any point
during his career, was sued for medical malpractice. Martinez says no that there is no national database
and that you would have to know the doctor’s malpractice insurance company.
Martinez though got a call from someone that had in fact sued Murray because this patient had heard that
Det. Martinez was investigating Conrad Murray. However, he says that he did not obtain the court
documents or include the incident into evidence because it was not pertinent to the current investigation.
AEG then rhetorically asks if Murray went through a criminal trial for involuntary manslaughter , asked was
he found guilty, asked whether he was sentenced to the max of four years and concludes by
acknowledging that Murray is currently on appeal attempting to have his conviction overturned. Detective
Orlando Martinez, agrees and says correct.
Redirect of Orlando Martinez by Jackson Attorney Brian Panish

Panish asks Martinez, if AEG counsel had just spoke to him about the law in regards to getting Murrays
financial background records. He goes on to point out that Martinez would be able to obtain a credit report
from the reporting bureau if the consumer gives his written consent and in this case the consumer would
be Conrad Murray. So if Conrad Murray signed a written consent to Mr. Putnam or AEG either of these
entities could get his credit report, yes… Det. Martinez replies, yes. Panish is showing that once again
obtaining information about Murray’s finances and lack thereof was an easy task for AEG. Panish then
shows Martinez an exhibit; a form entitled “acknowledgement and authorization”, this is a type of
authorization form that potential employees and actual employees sign all over the country for their
employers to do a background check.
*AEG counsel objects, stating that no one has ever seen this form. Panish says your honor, it’s an AEG
form. The judge then overrules and Panish continues*
The consumer authorization shown was a blank AEG form given as an example which states that AEG can
use this signed form at its leisure to obtain a background check and that doing so, was in fact legal and not
subject to court orders/subpoena as AEG counsel previously stated. Once again AEG could have had
Murray sign one of these authorization forms as part of his contract and AEG of course knows this.
Mr. Panish now wants to talk about the medical board and says that counsel (AEG) wants to insinuate that
Murray was a good doctor, do you (Martinez) believe that Murray was a good doctor. Mr. Panish says isn’t
it true you (Martinez) had found out that Murray had already killed someone and that counsel (AEG) had
just asked about this.
*AEG lawyers Objects*
Panish again says isn’t it true that you (Martinez) found that Dr. Murray had in fact killed someone else
before Mr. Jackson and that counsel (AEG) just asked about that.
*AEG objects on misstate and judge overrules.*
Detective Martinez responds correct. Mr. Panish goes on to point out that Dr. Murray never told the
detective the name of his malpractice insurance company, the detective responds no. Mr. Panish says its
nothing for you to ask which malpractice insurance the doctor carries, AEG could ask Mr. Putnam could
ask and Panish says even me. So talks in regards to whether or not Murray had been involved in medical
malpractice or not, that this information could not be found out because Murray’s malpractice insurance
carrier was unknown, is complete rubbish. There are alternative channels to obtain this vital information.
Mr. Panish added that this medical board info may not be readily available to the public but entities like an
AEG have capabilities that the average do not, ignorance on any aspect of Dr. Conrad Murray’s history is
unacceptable. Panish re-introduces evidence which showed that Murray had his doctor privileges
suspended from Sunrise Medical Center in Las Vegas for ten months for not calling back on time and
updating patient medical records. Mr. Panish also reminds the court that Murray no longer has a medical
license and then enters a medical board questionnaire that Murray himself filled out and signed into
evidence. On the questionnaire, Murray is asked to list all hospitals where he had his staff privileges denied
suspended limited revoked or non-renewed and Dr. Murray answers:
Valerie Medical Hospital in Shadow Lane, Las Vegas –suspension of coronary peripheral
international from 2000 – the present
Sunrise Hospital – suspension of coronary peripheral international from January 2001 – May
2001 and suspended again in 2008 for ten months and then again 2010, in connection with
Michael’s murder.
Panish then says if someone tried to say that Murray had never been suspended before would they be
incorrect and/or lying, the detective responds yes.
The detective is asked about his suspicions about Murray when they started and he says when he saw
Murray in the room with Mrs. Jackson

The detective goes on to say that, his suspicions were increased when he searched Conrad Murray’s car
after impounding it and obtaining a search warrant. Because he found a contract stating that Murray was
to get paid $150,000 a month and had Randy Phillip’s business card with private cell number on the back
of the card; these findings prompted him to want to investigate Murray financially for motive. Mr. Panish
asked the detective if he was aware that Michael’s beautiful home which included the furnishings was
rented, the detective says yes. Mr. Panish asked if he knew that rent was paid for by AEG, the detective
says no.
Panish asks if when the detective entered the CarolWood estate was Michael’s bedroom locked and then
Martinez replies, yes. One bedroom had been open, the fire place on and the TV was on and the radio on
playing Cds, Mr. Panish adds that this would allude that someone was in there and the detective responds
that is correct. When asked whose room was this, detective replied it was Mr. Jackson’s room when he
was not on medication; the latter about when Michael slept in his room is the detective’s assumption.
Michael was found in an adjacent room, not his bedroom.
The discussion turns to the day the detective was able to speak with Michael’s Mom and noted she and the
kids were visibly upset still. Mrs. Jackson graciously answered the detectives question without a lawyer
present. Mrs. Jackson said that she Loved her son and then candidly spoke about Michael’s use of
prescription drugs at times and this only when the pain which caused stress, go too much. The detective
said t was good to have it out there as he heard the rumors but did not want to be disrespectful.
The detective said he had interviewed AEG employees whom had attorneys with them and told him they
had no knowledge that Michael used prescription drugs off and on throughout his life. The detective
reviewed the whole case file of AEG employee interviews and not one acknowledged that they not so
much as even heard a rumor about the prescription use. Panish asked if the detective was in possession of
any emails that AEG sent Murray and he was only given one. And that email was regarding a meeting on
June 20 2009. Mr. Panish asked if the detective had ever heard that Conrad Murray wanted 5 million
dollars to be to be Michael’s physician. The detective says that either Mr. Phillips or Mr. Gongaware told his
partners that Murray wanted $5 million dollars for caring for Michael.
Mr. Panish asked if there is anywhere in the penal code section that having a messy room is against the
law, the detective says no. Panish then says a person’s room not being clean, could be an indication of
someone not feeling well and can’t get to it and the Martinez says at times. Panish asked if he noticed there
as mobbing boxes in Michael house and Martinez yes, did you know that Michael was moving to London
Martinez says yes in a week or to week.
The detective said that he learned that Murray had been giving Michael propofol for two months before he
died. Panish then asks if the detective remembers questions about Murray, being Michael long time private
physician and the detective says yes. Mr. Panish asks what did he find out about that and Martinez says
that, Murray treated Michael and his kids intermittently 2006. In opening Panish already established, that
from ’06 to ’08 that Murray saw Michael a total of 7 times only.
After the card with Phillips number on it and the contract was found in Murray’s BMW, the detective
requested to interview Dr. Murray again. Mr. Panish asked if Det. Martinez was able to do so and the
detective said the request was denied. Mr. Panish asked if this request could have been forced and he said
no.
Mr. Panish asks the detective as a result of his investigation did he find that Dr. Murray gave Michael
propofol and benzodiazepines and Martinez replies yes. Mr. Panish says with the judgments and such
would it be fare to say that Dr. Murray as of May and June of 2009 was in debt over $1 million dollars the
detective replies yes. Panish then says with all the of questions that counsel (AEG) asked you, does it
change your mind in May and June of 2009 that Dr. Murray was in severe financial distress, the detective
replies no. Panish then ask of all the questions that counsel (AEG) has asked you does it change your
mind that Dr. Conrad Murray’s course of action that resulted in death was finances and money as the
motivating factor for Dr. Murray’s downfall, the detective replies no they(AEG) do not change mind. Mr.
Panish then says thank you I have no further questions.
Cross of Orlando Martinez by AEG Counsel
Counsel says Conrad Murray was certainly in debt long before May & June of 2009 and Michael as still alive
then, right…the detective says yes. Counsel says that Mr. Panish asked about suspensions and then asks if
he understands the difference between having a hospital suspension and a license suspension. The

detective said yes the difference is having hospital privileges suspended and a license suspension means
that you can’t practice in the state.
Counsel asks were told that Dr. Conrad Murray was giving Michael Jackson propofol for 2months, the
detective responds yes. As an investigator did you suspect that it had been longer than 2 months, the
detective says yes. How much longer adds counsel, as early as April 6 said Detective Orlando Martinez.
Counsel asks the detective weren’t there questions and information that he received from AEG Live that he
asked for and didn’t have to subpoena, detective says yes. Asked did he get all the documents he asked
for and was he able to talk with anyone that he wanted to at AEG Live and the detective said that is
correct. Counsel said that the DA also talked with people at AEG Live and got documents from them and
at times the DA offered Martinez to come along on those interviews and at times he would go.
Counsel then asks about the medical malpractice and the detective now says his office received the call
about Murray’s former patient. AEG counsel then submits a statement form which was taken by Martinez’s
colleague, Detective Meyers; this intake was done in April of 2010. On the form it stated that the patient
had died of a heart attack however the coroner declared it as natural causes, counsel asks if the detective
read the document clearly and Martinez replies yea I was wrong.
The detective gets asked if his suspicions about the Murray receiving $150,000 a month were based on
the source of the money or that Murray would do something anything for the money. Detective said that
at the time it didn’t matter to the investigation about the source of the money; it was whether Murray
would do anything for the money, bend the rules, due harm to make sure that he got the money.
Counsel says, so it’s not that the money was coming from AEG Live, so if for example the
money was being paid by Michael Jackson, your suspicions were because he was getting paid
this type of money… The detective says yes, it was the suspicion that Murray would do anything in
relation to medical care given because of the tour. Counsel has no further questions.
Redirect of Orlando Martinez by Jackson Attorney Brian Panish
Panish asks as far as the contract goes, Murray started May 1 2009. Panish then says the fact that there
wasn’t a lawsuit, in regards to the former client; it doesn’t mean that Murray wasn’t liable for malpractice.
Martinez’s responds the lawsuit didn’t happen because they simply ran out of time and there are strict laws
about this in the state of Nevada.
Panish says counsel talks about the differences in suspension yet as an interventionist cardiologist they
perform their work in a hospital and that you do need hospital privileges because without them you can’t
give catheters angiograms and angioplasties etc. and the detective agreed, yes that is correct.
Panish says so in terms of when Murray was giving propofol the start date you are just assuming it was
earlier, the detective replies yes circumstantial evidence. Panish says well in April propofol was bought in
Nevada hen was it shipped to California; Martinez says that he would have to look at the UPS record, but it
was within the week.
Mr. Panish asks in regards to the documents counsel talked about AEG produced to you, how many
documents, rather how many emails in regards to Murray did they produce to you, as counsel have said
that you received everything in reference to Murray; Martinez says to the police department that was one
email. Panish then says you don’t know do you, if AEG has other emails that they didn’t produce to the
police department and Martinez says no I do not.
Is there any question in your mind after being on the stand all these hours today and the past few days,
that Dr. Murray was in financial trouble, is there any doubt in your mind that Dr. Conrad Murray done this
because of a need for financial gain and the detective replies no there isn’t.
End of Examination
Putnam states he may call Detective Martinez back in the future
Judge Yvette Palazuelos releases Detective Orlando Martinez from the stand and closes the
court. The judge also states that court will be closed Friday May 3 and that the court will
resume on Monday.
.
Hier ist der Link dazu:

http://teammichaeljackson.com/archives/8267

[manu29]

Karen Faye
(Hair and Makeup)
Plaintiff’s Witness



Direct examination by Brian Panish.
Q How are you employed? What is your background?
A I’m a makeup and hair artist. I’ve worked in television, videos. I’ve worked with Kevin Costner,
Smokey Robinson.
Q Did you ever work with Michael Jackson? When did you start working with him?
A Yes. In 1982, for the cover of the Thriller album. I was hired by the photographer.
(Panish exhibits Thriller LP inside liner notes/credits)
11.05.13 Karen Faye |
teammichaeljackson.com/archives/8324#.UY3Y8ZRXPPU.twitter 2/19
Q Drawing of Paul McCartney and Michael Jackson – drawn by Michael for The Girl Is Mine. Produced
by Quincy Jones. Co-produced by Michael Jackson. Please read this credit line, what does it say?
A “This album is lovingly dedicated to Katherine Jackson.”
Q Did you continue to work with Michael after this?
A Yes. Michael asked me to work on the ET photoshoot. Michael did the narration for the ET album. I
went on set and saw Michael with ET. It was magical.
Q What you do – what is involved in doing someone’s makeup and hair?
A I have to make sure skin tone is even and fix their hair so it’s perfect. I have to get to know
someone. It becomes very personal.
Q Sometime in the 1980’s, Michael suffered an injury while making a commercial.How did that effect
how you worked with him?
A I had to use hair pieces because his scalp was badly burned.
Q How long did you work with Michael Jackson?
A About 27 years.
Q You traveled with Michael Jackson. Where did you travel?
A All over the world. Europe, Asia, North and South American, Australia.
Q What was it like traveling and working with Michael?
A I found myself working with this magical person. He took me all over the world. Experiences
beyond my dreams.
Q How would you describe your relationship with Michael Jackson?
A We knew each other for years. We were very close. Like brother and sister relationship. I was
having problems and we would talk about it. We talked. We shared.
Q Did you ever go on any tour with Michael?
A I went on three world tours with him — Bad, Dangerous and first part of History. Also worked on
other projects such as the Super Bowl.
Q Did you ever meet dignitaries with Michael?
A Yes. I met Princess Diana, President Clinton, officials all over Europe and Asia.
Q Did you spend time with Michael Jackson when he wasn’t doing a concert or on a tour?
A Yes. Even during the tours, Michael would go to hospitals and orphanages in between shows. I
went to Neverland. He gave me my wedding shower there.
Q Talk about his work as a humanitarian. Were you involved in the work Michael did throughout the
world to help the world?
A I have to say no, only because — it’s something he just did. He wasn’t thinking about press or
anything. It was just something he did. He did not want attention for it. I did see it. We would go to
hospitals and orphanages to visit the children. He said: I only tour to go to these countries for the kids in
the hospitals and the orphans.
Q How would you describe Michael’s personality?
A He was brilliant. Sense of humor — we laughed a lot. A creative genius. Very much a perfectionist.
Q What was his relationship with his fans?
A (sighs) He loved his fans. He would interact with them.
Q Were you there in the good times and the bad?
A Yes.
(Panish exhibits photo of Michael and Karen Faye)
Q Who’s in this photo? Tell us about this photo.
A That’s Michael and me. The day before this was taken, Lisa Marie Presley was calling Michael,
begging him not to divorce her. They weren’t getting along. She said let’s try to work this out. Michael
kept saying: No I don’t think it’s going to work. She begged and begged: Please don’t file, please don’t file.
So, he promised her that he wouldn’t file for divorce. The next morning it was all over the press — she filed
for divorce. He was devastated. He had decided to really try again with her. Then she turned around and
did that.
(Panish shows several other photos of Karen Faye with Michael, establishing an ongoing
relationship. Also shows photos of Michael from various photoshoots.)
Q Did famous photographers like to take pictures of Michael?
A They fought over who was going to take his picture.
Q Here’s a shot of Michael with tape on his fingers. Why did he put tape on his fingers?
A That was Michael’s genius. He thought up things that no one else had thought of. Like the glove
and the white socks. To get the audience’s attention when he danced — the visual, the movement. He
was a genius. I never worked for anybody else who saw things like that.
Q Over the years you were at many, many shows and performances of Michael Jackson, correct?
A Yes.
(Panish plays clip of Michael performing Man In The Mirror live in concert in Bucharest,
Romania. He asks about all the people reacting to Michael — fainting, ecstatic, exhausted,
being carried on stretchers.)
Q Were there a lot of people at the concerts?
A Yes. There were lots of people. (laughter) Hundreds of thousands. I had to go out on stage for
moment. There were so many people that I couldn’t see beyond them. I’d be nervous going out. Michael
would just laugh and be at ease.
Q You’ve worked with other artists. Have you ever seen anything like this?
A No sir.
Q This was ROMANIA. And you said places like Russia.. Do they even speak English in Romania?
A They — Michael would talk to them in English and some of their own language.
Q When Michael performed would he sweat very hard?
A He would get so into his performance. He would lose all of his water weight. He would drink
Gatorade in between. Some of the extras on stage were passing out. And Michael would be fine. He would
be able to do it. His stamina was — I never saw anything like it.
Q Were you involved with a Pepsi commercial Michael made?
A Pepsi sponsored Michael’s tours. Michael was on stage, in the background. There were explosions
and he was to come down the stairs. On third take, the director said: I want a bigger explosion, and
Michael to come out sooner. Michael did it and I saw his head was on FIRE. Flames shooting out. I was
screaming. Michael didn’t know. Miko Brando had to wrestle him to the ground and got the fire out. They
brought him to the hospital.
(Panish exhibit’s a photo of Michael’s scalp burn)
Q As a result of this, did Michael have surgeries on the scalp?
A I was at home crying watching Michael on TV. So worried about him. When he was in the hospital,
he was visiting all the other patients. I saw this on TV. I thought: Oh he’s okay. He really cared about them
more than he cared about himself. Regarding operations — he had 1st, 2nd and 3rd degree burns on the
top of his scalp. At first they tried to have it heal. Later he had surgeries.
Q Did he have problems that continued after the surgeries?
A He was basically okay afterward the initial burn. His skin healed. We used a small hair piece that
would cover the top of his head were he’d been burned. Doing that wasn’t the best for performances so
Michael had an operation on his scalp for the hair to grow back. A bladder had to be inserted under his skin
and stretch the skin.
Q Did he have any physical or emotional distress after that?
A His schedule was so busy that he never had time to heal from the surgery. He did a short film
Addams Family Values, or something like that. His scalp was healing from the operation, but he was getting
chronic migraine headaches from this operation. It caused incredible pain.
Q Did he do something for the hospital at which he was treated?
A That was before the surgery. He asked that they build a burn center for burn victims.
Q Were you in Munich, Germany when Michael suffered injuries?
A Yes. He did two corresponding benefit shows, one was in Munich. On the stage there was a bridge.
A high bridge. Michael would run up the bridge and it would split in three parts, with him suspended on
center part. In Munich, Michael ran up the bridge, the bridge was lifted, then the whole bridge collapsed
with Michael on it.
Q Did he fall down?
A Right down past the audience. When I saw what happened, I thought he was dead. That was a
tragic accident. I was devastated. Then I saw an arm go on stage. Then another arm. And then his leg.
And he got up — and he finished that song. We wanted to take him to the hospital. He said: I can’t, I
can’t. I can’t disappoint the audience. He finished the show. After he went backstage and he collapsed.
(Panish plays the video clip of the accident)
Q Do you know if he suffered any pains as a result of that?
A Yes sir. He suffered back pain from that moment on. He only ever mentioned about his back being
in pain when he was under physical or emotional stress.
Q Were there other instances were Michael had something happen out of the norm but he continued
to perform? How about in Seoul, Korea?
(Panish plays the video clip as Faye answers)
A Oh, Yes. Michael was suspended up on the cherry picker (crane) performing Earth Song. A fan ran
up the rail of the crane to Michael. Michael was holding him.
Q Is that part of the show?
A NO it’s not. Michael was so scared for him. He kept singing but he was holding onto him for dear
life.
Q Were you familiar with Michael making music videos?
A Yes. I worked on them.
Q Did you work on one called Thriller? Was that a popular music video?
(laughter in courtroom)
A Um, yes.
Q Why was it popular?
A It was the longest music video ever made. Elaborate set. Special effects. Makeup. Directed by John
Landis.
(Panish plays clip from Thriller video)
Q Before that one, had anybody done music videos like this?
A No sir.
Q Were you involved with a performance Michael did at the Super Bowl.
A Yes.
Q Was that the first time a big artist like that had performed at the Super Bowl? Was that a big deal?
A Yes. It was a very big deal. Michael started the trend of having big artists play at the Super Bowl.
Q Did you know a lot of people watched his performance?
A A lot of people watched.
(Panish plays clip from Michael’s Super Bowl performance)
(break)
(Panish plays clip from 1995 MTV Awards performance)
Q Did you work with Michael for this performance?
A Yes. (watching video clip) He could moonwalk in a circle.
Q What is a short film?
A Michael didn’t ever call his short films, music videos. He called them short films. Because they were
so much more.
Q Did it required a lot of stamina and physical endurance to do all of these performances?
A Oh yeah.
Q Did Michael ever talk to you about him having difficulty sleeping when on tour?
A Yes sir. What would happen is his adrenaline would pump through his body. He would do a 2 hour
or longer show and his adrenaline level was so high that it took him at least 24 hours to relax and be able
to sleep. Sometimes it would take him 2 days. So he would have trouble trying to sleep.
Q When he would have insomnia, what would he do?
A In the beginning when we first started out, he shows would be scheduled far enough apart where
he had a chance to unwind and be able to sleep. He’d do 1 or 2 concerts a week. Then time to relax. But
as the tours went on, the shows got closer and closer together. So he would have trouble sleeping. It
would start out okay, but it got worse and worse as the tours progressed and he couldn’t get sleep. So to
perform — he tried to find ways to sleep.
Q Did he rely on certain people to help him try to sleep?
A Doctors. Michael always believed that a doctor had his best interest at heart. He always believed
that if he had something from a doctor that it was safe.
Q Do you know if he ever took prescription medications after performances for pain or to sleep?
A I really don’t know. He never took them in front of me.
Q Did he ever tell you he took prescription medications after performances for pain or to sleep?
A No.
Q Did you see doctors around him?
A Yes, I did sir.
Q Were you on the Dangerous Tour with Michael?
A Yes.
Q Did anything unusual happen before the tour started?
A Yes. We were doing the short film for Addams Family. Michael was going through the pain from the
scalp surgery with the inserted balloon (bladder). He was having slow release pain medication patches put
on his scalp to help him.
Q Do you know if he was having injects of pain medication?
A Debbie Rowe would come to the trailer with a little bag.
Q Were you ever asked to carry any medicine on the tour?
AEG: Objection Judge: Overruled
A Yes. Jim Morey, the manager of the tour asked me if I would carry packages of medical patches
into Bangkok. And Debbie Rowe asked me if I would give Michael injections.
Q Did you do it?
A I thought about it and I said: No. I’m not qualified to give any medication.
Q Was Paul Gongaware tour manager/director on the Dangerous Tour? He oversaw everything?
A He was in charge of logistics of moving, hotel reservation, the band, passports.
Q At a point in Bangkok, there was a doctor on the Dangerous Tour. What was his name?
A Dr. Stewart Finkelstein.
Q Was he friends with Mr. Gongaware?
A I found out he called Paul Gongaware when I said I wouldn’t carry the packages into Bangkok.
Q Do you know if Dr. Finkelstein gave any treatments to Michael Jackson during that tour?
A Yes. I assumed it was his job to take care of Michael.
Q What did he give him?
A He wouldn’t be specific with me. I initially thought I was being asked to carry patches. But when I
met him in the lobby for the first time he said to me: It’s a good thing you weren’t carrying the package I
received. It has vials and syringes in it. If you’d carried it, you might not be here.
Q Were there any other doctors on the tour?
A There was another doctor — Dr. Forcast. I don’t know where he came from.
Q Did you learn that Mr. Jackson was being given various medications in Bangkok?
A I learned they were administering a balance of medications, strong enough to overcome Michael’s
pain, but not strong enough that he couldn’t perform.
Q Did you ever see Mr. Gongaware hanging out with Dr. Finklestein?
A Yes. Quite often because they were friendly. They were friends.
Q Dr. Forcast. Was it your understand that he was a medical doctor?
A I just knew he was brought on. He was the insurance doctor.
Q There was a time on the tour you discovered Michael had been given too many drugs and couldn’t
perform. What did you learn?
A Yes. Michael came into the dressing room. He was stumbling. He had a hard time walking. He
actually fell over a potted plant/tree. Dr. Forcast was there. I told him: Michael can’t go on. He has to entire
on a toaster. Toasters are very small. You have to curl up and be shot out of it. He could lose an arm. I’m
seeing Michael in this state and I said you can’t put him in this position. I feared for his safety. I feared for
his life. I told Dr. Forcast: You can’t. You can’t make him go out there like this. I put my arms around
Michael and said: You can’t take him. And he said: Yes I can. He put his hands around my neck, backed
me against the wall and said: You don’t know what your doing. I couldn’t breathe. I almost fainted. I fell to
the floor. He grabbed Michael and took him off to the stage.
Q That was Dr. Forcast.
A That was Dr. Forcast.
Q Did that show eventually get cancelled?
A Yes sir.
Q Were there other shows in that tour that were cancelled because Michael Jackson was unable to
perform?
A Yes.
Q Did there come a time in that tour when you felt Michael was getting worse?
A Yes. Michael was under a lot of stress at that time because that’s when the first child allegations
were made public. (becoming emotional) And Michael had to go on stage every night, literally with the
whole world thinking he was a pedophile. He had to stand up through all of that slander and all of those
things. The visible pain this had — He had to perform and be up there. To this day, I don’t know how he
did that.
Q Did he ever complain to you at this time of any emotional pain or physical pain?
A He didn’t say anything to me. He always wanted to be so brave and strong.
Q Did you observe at this time that doctors were giving him more and more prescription
medications?
A Yes.
Q Paul Gongaware was still there on the tour?
A Yes sir.
Q Did the tour go to another location after Bangkok?
A Mexico City. That’s where it ended.
Q Did the tour end on time, early, late?
A It ended early.
Q Why did the tour end early?
A Because everyone knew Michael had a problem. Elizabeth Taylor came to Mexico and took Michael
to rehab. We all went home.
Q And where did Michael go?
A At first I didn’t know. They wouldn’t tell me because the media was everywhere and they were
looking for him. I had to wear a disguise so the media wouldn’t follow me to get to him. I was taken to him.
He was in England, outside of London. It was a beautiful country home. There were other rehab patients
there. They would have sessions and talk. Work through their issues.
Q How did that experience make you feel about doctors on tour with Michael?
A Every time I saw a doctor, I got worried. I was afraid Michael was in emotional or physical pain and
that a doctor was treating him for that.
Q Mr. Gongaware. Was he responsible for cancelling the shows?
A Yes.
Q Where you with Michael on the History Tour.
A I was on the first leg of the tour.
Q Do you know a Dr. Ratner? Did you see him on the History Tour?
A I saw him at the end of the first leg of the tour.
Q Was Mr. Gongaware on that tour?
A Yes sir.
Q What was his position?
A He had a lot more responsibility. He’d climbed the ladder. More executive.
Q Was there an HBO Special in the 1990’s that you were a part of?
A Yes.
Q Did something happen to Michael during rehearsals for that special?
A It was more of a media event, not a rehearsal. He collapsed on stage. The diagnosis was
dehydration and over exhaustion.
Q Did you work on 30th Anniversary event at Madison Square Garden?
A Yes.
Q Did anything happen while preparing for that? Tell us.
A Yes sir. I went to get him ready for the show, two hours before he was due at Madison Square
Garden. There was a doctor there. He was surprised to see me. He said you can’t come in here now. I’ve
given Michael something and he’s going to be asleep for 5-6 hours. I said this can’t happen. I think it was
Frank Cascio, helped me get him up. I did his makeup and hair while he was almost out. I was walking him
around. I gave him Gatorade and a bagel, trying to get whatever they put in his system out. His fans and
everyone were all there waiting. It was a desperate situation. He was still sleepy. But he did get there and
he did perform.
Q After that, in 2005, was there a criminal trial where Mr. Jackson was accused of something?
A Yes sir.
Q Did you work and help him through the criminal trial?
A Yes.
Q Was he acquitted in the criminal trial?
A Yes sir.
Q Then where did he go?
A Bahrain.
Q How was he doing through the criminal trial?
A He was being really brave. I would go to Neverland Ranch at 3am every morning to get him ready
by 7am. We had to be out the door by 6-7am to get to the trial. If we didn’t show up on time they’d
throw him in jail. They made it a parade, every single day. They had a red carpet, making him go into that
courthouse every day. And the media. All the media. Other people, the witnesses got to go in around the
back. They made him — every single day — walk the red carpet. Just to put him on display, and give the
media bites. Michael — we got him dressed every day. We made sure he looked really good. I washed his
hair. Every day, get him ready. Every day, we would hug — be arm and arm together and cry. I’d blow
dry his hair. We’d listen to classical music. We’d watch Three Stooges videos.
Q Alright. And then what happened?
A He got worse, sir. He wasn‘t eating. He was getting thinner. His physical pain. His back pain. He
started losing weight. He said he couldn’t eat because he didn’t want to throw up. He had to watch all the
people that he loved and cared about, be worried about him. He wouldn’t go to the bathroom at the
court because the guard would stand behind him and he was too shy for that, he was too much of a
gentleman. He could never go to the bathroom with someone watching him. So he wouldn’t drink before
we left. Then he had fallen and hurt his back. The media called it “pajama day”. You all saw it. He was taken
to the hospital. They gave him some pain killers. The court said he had to be there or he would be put in
jail. They put him in the car. We followed in another car with his clothes. We hoped we’d be able to dress
him somewhere, but there was no time. They kept saying: He has to be here or he goes to jail. So he had
to go to court in his pajamas.
(afternoon break)
Direct Examination continues of Karen Faye by Jackson attorney Brian Panish
Q. Where you contacted by anyone about getting involved with the production
A. The first very person who to give me a call Michael Amir and he identified himself as Michael’s rep and
said that Michael wanted to speak to me and if I’d be available to talk to him
Q. Michael Amir is he also the one that goes by Brother Michael
A. Yes
Q. And then did you speak with Michael himself
A. Yes Michael called a few hours later
Q. Where you happy to hear from him
A. Very much so
Q. How long did you speak with him at that time?
A. We didn’t speak for a long time maybe about 45 minutes or so
Q. Other than general pleasantries what was the gist of the conversation with Michael
A. Well he explained to me that he would be doing concerts in London and I said yea I know I saw it on TV
and I he said I’d really like to work with me on that
Q. And what did you say
A. And I said I’d love to Michael
Q. So you agreed then that you work with him on the concerts
A. Yes
Q. Now did you have any concerns at that time, when Michael first contacted you about the concerts?
A. Yes I did, I had a problem with Raymone Baine management they didn’t like me and they were pretty
much responsible for me not being there for four years.
Q. At some point did you have any concerns about the number of shows or Michael doing the shows or
anything like that?
A. After the conversation and I told him that I wanted to do it I went on line to the website and I viewed his
scheduled that they had for him. And upon looking at that, I was like he can’t do this. The shows are far
too close together and I know what he needs more to recuperate in between shows and with schedule he
may last a week. I was really concerned with that. So I got in touch with Kenny Ortega and I said Kenny
there has to be some changes if you really want Michael to do this schedule and he kind of laughed it off
and he didn’t seem real concerned about that. So the next conversation I had about that was with Michael
himself.
Q. What was it that concerned you about the shows being real close together?
A. Well like I said before Michael has a lot of adrenaline and what it takes for him to do a show physically
and emotional and mentally to be able to perform at that…with the effort it took, what he himself took put
into a show. As I was explaining with that adrenaline he needed that time between shows he needed more
time to rest and sleep for him to be healthy for him to maintain any kind of longevity
Q. Eventually did you get hired to work on the This Is It Project?
A. Yes
Q. Who was it, that you worked with to get an agreement to work on the this is it project
A. Well I got to sign and negotiate my rate with Paul Gongaware
Q. What was your understanding of Mr. Gongaware’s involvement, what was his position?
A. He worked for with AEG
Q. Did you send negotiations back and for the forth with Mr. Gongaware
A. Not too much, we negotiated the rate which I think… he was very pleased with it, because it wasn’t that
high. He was like oh that’s great. So that wasn’t really an issue
Q. Did you eventually get a written contract with AEG?
A. Yes I did
Q. Prior to having a written contract did you do work for the production
A. Yes, because it took a while to get the contract and all that stuff together. I actually felt I started when
Michael said can you do work for me
Q. So you started doing work before you had a written agreement signed
A. Correct
Q. AEG… Mr. Gongaware authorized you to go ahead and do work
AEG objects on foundation, Judge asks Panish to repeat the question
Q. You started working at some point in time
A. Yes
Q. Who had you been talking to about work on the project, after you talked to Michael Jackson
A. Paul Gongaware was the first person and then I started talks with Tim Woolley
Q. And what was your understanding of who Tim Woolley was
A. He… I remember I had to give him my passport and he handles actually like money
Q. Did you hear somebody say yesterday that he was the guy that gave out the checks?
A. Yes
Q. Was it your understanding that you worked for AEG
A. Yes
Q. Did he give you checks from AEG?
A. no they were wired into my account
Q. Was it like direct deposit do you know
A. I don’t know too much about that stuff, but I have a rep who handles all that.
Q. Did you say a rep?
A. Yes, she helps me… negotiates for me and represents me
Q. Prior to getting a written contract did you have an agreement to do work?
A. Yes
Q. Before you had the written contract what work did you do
A. Makeup and hair
Q. And did you get paid for the work you did without the contract
A. No… Not really, no…Because I was working and the contract had to be signed. They told me, we will
pay you when it’s (contract) done, should be done in a couple of weeks and we will pay you a couple of
weeks in your first pay check
Q. So in other words without the agreement you been working and once you got the agreement you got
paid and they pay you for the previous work you did.
A. Right
Q. Even though Michael had asked you to work the tour, who was directing and managing what you did
A. AEG was
Q. Who were the AEG personnel that you knew was dealing with this project?
A. Do you mean who I answering to sir?
Q. Who did you take directions from?
A. I took directions from Frank Dileo, I took directions from Kenny Ortega, I reported to Tim Woolley and
once in a while I spoke to Randy
Q. To who?
A. Randy Phillips?
Q. Do you know what Mr. Phillips position was with AEG at that time?
A. I think he was the head of it all
Q. The head of the company?
A. Yes sir he was close to the top
Q. You heard the term CEO it’s the chief executive officer
A. Correct
Q. Is that your understanding of what Mr. Phillips was within AEG?
A. Yes Sir
Q. And Mr. Gongaware what was your understanding of what he was?
A. He was I think the other Randy Phillips, like the co CEO or something of that nature
Q. Did the Mr. Gongaware come to rehearsal?
A. Yes sir
Q. Would you say often…infrequently? Frequently… how would you describe his attendance at the
rehearsals?
A. Every day
Q. How about Mr. Phillips, how would you describe his attendance at rehearsals?
A. Once in a while
Q. Not as often as Mr. Gongaware
A. No
Q. But you did see booth of them there
A. Correct
Q. Kenny Ortega you mentioned, what was your understanding of his role within this production
A. He was like Creative Director
Q. Did you see Michael Jackson in April and May of 2009?
A. Yes sir
Q. When you saw him did you speak to him?
A. Yes sir
Q. Did you discus with him how he was doing
A. Yes sir
Q. What did you discuss, not what you said to each other, just the topics you discussed?
A. The show in general, some personal stuff.
Q. Well this conversation was just between you Michael Jackson
A. That’s correct
Q. Well I need to know the topics you discussed not what you said
A. I needed to do services for him and had to discuss compensation and other stuff. General stuff some
personal stuff.
Q. Did Mr. Jackson discuss with you any concerns that he had about the show with you?
AEG objection hearsay, side bar
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Q. When you saw Mr. Jackson, was he frustrated, don’t tell me what he said, just was he frustrated?
A. Yes Michael was frustrated
Q. And was he concerned about his frustration, don’t tell me what he said? Wait… bad question
Q. When you saw Mr. Jackson can you tell he was frustrated?
A. Yes
Q. What was your impression of his condition, how he was doing
A. When
Q. In the beginning
A. In the very beginning, when I first saw him I thought he looked great very happy very healthy very
clear but he was on the thin side for starting a tour
Q. When you saw him based on his physical appearance was it your impression that he could do all the
shows requested
A. At that time in the very beginning, I thought he had plenty of time to put on body mass, some muscle
mass. Usually performers even thru rehearsal, start gain some weight and building muscle weight. The
dancers thru routines they start working out. Thru diet I thought he probably could
Q. Did you believe or did you have and understanding that all of this was important to Michael
A. It was important for him to do the shows financially and he wanted to do it for his children so they’d be
able to see him perform live because they never saw him. He wanted to do it for his family, they haven’t
seen him in a long time and Michael’s fans are really really important to him.
Q. Did you have an understanding about Michael’s feeling about live performances and touring
A. He hated it
Q. Didn’t like it, as I understand it, what was your understanding
A. It was just too hard on him, he used to say the only reason why he did like the to go on tour, was so
he could visit the hospitals and the orphanages
Q. Did you believe in the beginning that Michael would get in better shape to do the performances?
A. I thought it was possible
Q. As time went on did you feel it was still possible?
A. It was looking grim
Q. What did you see that made you feel that it was looking grim?
A. The first time he actually got on the stage I saw the change in him at first rehearsal was just about
meetings and collaborations. Things like colors lighting, stage positions; a lot of production meetings. As
soon as he had to go on stage and actually rehearse I saw the change in him
Q. Why did Michael have to go on stage and rehearse?
A. Everyone had to
Q. Whose responsibility was it to make sure that Michael was up on stage rehearsing?
A. Kenny Ortega
Q. Was anyone insisting that Michael Jackson get up on the stage and rehearse?
A. Yes
Q. Who was that?
A. Randy Phillips
Q. Did you ever see anyone else besides Kenny Ortega and Randy Phillips insist that Michael get up on the
stage and rehearse?
A. No that was it
Now I’m going to show you a time sequence
Q. Is it your recollection that events were happening at Center Staging in May
A. Yes
Q. Is it to your recollections that events where happening in June up to the 20 at the Forum where you
then went to the Staple Center
A. Yes, we were also doing the video content for the show at the Culver City Studios
Q. And those would be at night time
A. We work long hrs.
Q. Did you see any changes in Michael when this was occurring?
A. Yes
Q. Did you notice whether he was losing weight
A. He was getting thinner and thinner every month
Q. Did you notice whether not he was talking to himself
A. He was repeating himself a lot, repetition…. Saying the same things over and over
Q. Did that concern you?
A. Yes
Q. Did you start to notice if there were any emotional issues?
A. In the beginning time frame he seemed happy I was with him, I’d touch him up and he’d seemed
relatively normal.
Q. When did that change.
A. Well I felt the turning point happened when he got on the stage.
Panish: So you told us about the skin and you told us about the weight
Karen Faye: His eyes were very dry
Q. Anything else, you told us about him repeating himself
A. For instance whenever before he’d get on the stage for a scene. He would say make sure you stand
wear I can see you and he would say it repeatedly.
Q. Did you know whether people in the production were aware and concerned about Michael’s condition in
early June of 2009? This is a yes or no question
AEG objects, Panish: this is a yes or no answer, Judge overruled
A. No
Q. Now you know who Mr. Gongaware is, do you know if Mr. Gongaware did anything in regards to
removing Michael’s security guards and keeping his fans away from Michael Jackson?
A. Well I don’t who did but fans told me about that. But what I did see and experience because I went to
Paul Gongaware’s office, he was on the phone with one of Michael’s security guards. You have to get him
out of the bathroom, he’s locked himself in the bathroom
Q. And who said that
A. Paul Gongaware
Q. And you heard that yourself
A. I heard that myself
Q. Did you ever hear Mr. Gongaware scream at Michael Amir about Michael locking himself in the
bathroom?
A. Yes on that phone call
Q. Did you express your concerns to anyone about what was happening?
A. Yes.
Q. Who was the first person that you went op raise your concerns
A. Kenny Ortega
Q. Was Michael going to rehearsals at this time?
A. He was missing some
Q. Where you concerned when he wasn’t making them
A. Yes
Q. Did you raise concerns about Michael’s psychological well being?
A. Yes
Q. Did you discuss with Mr. Ortega whether or not a psychologist would be brought into the picture?
A. Kenny Ortega told me that….
AEG objects, sidebar.
Break
Q. Did Kenny Ortega tell you about the intentions or the plans of the producers to help Michael Jackson
A. He told me Randy Phillips hired the top ten doctors in the country
Q. Did you ever hear anything about Dr. Conrad Murray?
A. No
Q. Did you ever see Dr. Conrad Murray?
A. No not that much
Q. Have you ever spoke to Dr. Conrad Murray?
A. No
Q. Before Michael Jackson died, did you ever speak to Randy Phillips about Michael missing rehearsal?
A. I ran into Randy in the hallway and everybody was a sad about Michel missing rehearsal
Q. What did Randy say to you?
A. I had scrape Michael off the floor in London to get him to the announcement because he was so drunk
Q. What was the reason you had this discussion with Randy Phillips
A. Because Michael was missing rehearsals and it was a concern
Q. Did Randy Phillips ever tell you why it was so important to get Michael to do the tour
A. Randy said that he has been trying to get Michael tour for a while and that Michael wouldn’t accept. It
was very important to him (Randy) because wanted to see Michael’s success
Q. Did Randy ever tell you whether or not he had a dream?
A. He wanted to be the one to bring Michael back to his success and he felt that Michael’s popularity had
waned and he wanted to bring that back
Q. After you had talked with Kenny and he said that they had these top ten doctors did you continue to
have concerns about Michael’s condition
A. Yes
Q. What were you concerned about, what did you see
11.05.13 Karen Faye |
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A. Michael was very cold, his body was cold to the touch
Q. Did you ever have an understanding that Mr. Jackson was having problems sleeping?
A. Yes
Q. Where you ever told at any point in time, to communicate with someone directly, if you had a
concerns about Michael Jackson
A. Yes, Frank Dileo
Q. Did you have an understanding of who Mr. Dileo was working for?
A. AEG
Q. And it was your understanding that, if you had any concerns, you were to relay your problems that
you were worried about, to Mr. Dileo
A. Yes
Q. You ever heard the word chain of command
A. Yes
Q. What was the chain of command in relation to you, who would have to talk to, if you were having
problems or saw problems?
A. Frank Dileo
Q. Did you have an understanding of who Frank Dileo reported those problems to?
Objection, overruled
A. Paul Gongaware
Q. And did you relay concerns that you had to Frank Dileo
A. Yes
Q. How did you do that
A. Phone and email
Q. What did you tell Mr. Dileo on the phone?
A. I told him I was worried about Michael’s state of health
Q. Did you also send emails to Mr. Dileo in that regard?
A. Yes
Q. Did something happen that precipitated on who you should listen to
A. Michael was late for rehearsal and he was to meet with Kenny at 5/6 pm and Kenny went to Michael’s
house
Q. You weren’t there when he talked to Michael, right
A. No
Q. Did you ever get instruction from AEG, about who you should take instructions from afterward?
A. I was instructed by Kenny Ortega
Q. Where you ever instructed not to listen to what Michael Jackson told you to do
A. Yes
Q. What was your understanding of who you were to listen to and take direction from
A. Randy Phillips
Q. Where you ever told to get Michael on stage with his ear pieces in, even though he didn’t want that
A. Yes
Q. Did you know the pressures to get Michael on the stage and not to listen to you?
A. Yes
Q. Did you feel torn over who to listen to?
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A. Yes
Q. After the meeting, when Mr. Ortega came back, did he give any instructions on what to do with Mr.
Jackson?
A. Yes
Q. What did he instruct you to do?
A. To not listen to what he (MJ) tells me
Q. Did you have a conversation with Mr. Dileo and Mr. Ortega around this June 16 time period about
Michael’s physical condition?
A. Yes
Q. Did they seem to listen to you?
A. No
Q. Did you see anything change?
A. No
Q. Around this time were you getting communication from fans?
A. Yes
Q. Where these communications concerning you
A. I was very concerned
Q. Did you forward those communication on to Mr. Dileo as you have been instructed to do?
A. Yes
Q. Did you ever to talk to Randy Phillips that you received from the fans and forwarded to Mr. Dileo
A. I didn’t give the emails to him
Q. Did Mr. Phillips ever say anything to you about the emails?
A. Yes
Q. Where was it when Mr. Phillips said something to you about the emails?
A. Studio
Q. What did Mr. Phillips say to you?
A. He said that he had read the emails that I had sent to Frank Dileo and that he would try to do
everything that he could
Q. On June 18 did Michael come to rehearsal
A. He came later
Q. How was he doing on that day?
A. He was very stoic
Q. Did you ever see him a condition like that before
A. No
Q. On that day without you telling what you said did you ever get to talk to Mr. Jackson?
A. Very little
Q. Did he rehearse that evening?
A. No
Q. Where you able to get him to laugh that evening
A. No
Q. When you say stoic, did he look unhappy sad how you would describe how he looked
A. Frightened
Q. Was the last rehearsal that was scheduled for the forum supposed to be June 19th?
A. Yes
Q. Where you instructed by that point not to communicate with the foams anymore
A. Yes
Q. Who instructed you not to?
A. Frank Dileo
Q. Is this after you had sent him the emails
A. No, this was before
Q. Did anything unusual happen on June 19 at the rehearsal
A. Yes
Q. Tell us about that
A. That was the day that Michael was cold like ice cubes, he was shivering and shaking and couldn’t get
warm. I got my space heater and put it next to him and wrapped him a blanket.
Q. Did you tell anyone about how he was doing?
A. I asked Mr. Ortega to please call his doctor
Q. Do you know whether Mr. Ortega called the doctor?
A. To my recollection he didn’t
Q. What did you do after that?
A. I just followed the instructions
Q. Were you and Mr. Ortega together that day with Michael
A. Yes
Q. Where were you
A. We were in his personal dressing room
Q. And what if anything did Mr. Ortega do for Michael at that time
A. He gave him feet massages before he sent home
Q. Did Mr. Ortega do anything else for Michael that day?
A. He cut his chicken and fed him, he was trying to get him to eat
Q. Was Michael shaking that day?
A. Yes
Mr. Panish enters into exhibit emails where Karen Faye forwarded fan emails with her own
comments to Frank Dileo as she was directed to.
Q. Was there a reason why you were sending these emails (the ones from fans) to Mr. Dileo?
A. I don’t remember the reason
Mr. Panish wants Karen to read to the court what she wrote in an email sent to Frank Dileo
Q. Just read us what you wrote on June 20 2009 five days before Michael Jackson died
A. “Frank unfortunately she is right. With low spiritual he will make himself so sick he will die. If
he don’t do this show….”
Panish: Now let’s move down to an email that you forwarded
“Hi Karen I will try to make this short but I don’t know if I will be able to. Last week I was in
LA trying to see Michael. We got really luck and were invited over on the set of the 3d thriller.
We were trying to give jacket to him. He was dressed with white pants, they were tight with a
white shirt and white T and he had a red small jacket on. We told Michael to try it on, when he
came to put it on, he couldn’t really fit it. He took his jacket off and we saw something
horrible, a skeleton and then we saw his back and we were still in shock. We don’t know if he is
anorexic and stop eating or if it’s something more complicated than that. Well in the case, if he
has stopped eating, here is what I want to tell you. If you do nothing he will die. I know that it
is humanly impossible for a human being to be a skeleton & dance for two hours straight and
not be in danger.”

Q. Did this concern you?
A. Yes
Q. Did you try to get Mr. Dileo and AEG to do something?
A. Yes
Q. Did Mr. Dileo ever say something to you about this, don’t tell us what he said, just tell us if he did
A. Yes
Q. Two days later on June 22 did you send Frank Dileo another email about your concerns for Michael?
A. Yes
Q. Did you receive another email from a fan?
A. Yes
Q. And did you send a note to Mr. Dileo
A. Yes
Q. This is June 22 and you wrote to Mr. Dileo and you’re telling him that you are concerned about
Michael, is that right
A. Yes
Q. And did you tell Mr. Dileo that Michael suffers from serious stuff physically and mentally and this puts a
void on his health and to please intervene, concerts is not worth jeopardizing his life for
A. Yes
Q. Did Mr. Dileo respond with an email to that?
A. No
Q. Did Mr. Phillips or Gongaware ever come ask you anything about this?
A. No
Q. Do you know Ms. Sankey?
A. Yes
Q. Without telling me what you said did you discus with her and Mr. Ortega about concerns about Michael
A. Not then
Q. During the last two days of Michael’s life would you say that he was doing better?
A. Yes
Q. Did you feel a little bit of relief?
A. Yes
Q. The 23 was he cold then
A. He was still cold
Q. Was Michael repeating, did he continue repeating things
A. Yes
Q. Were you concerned about Michael’s psychological wellbeing?
A. Yes
Q. Did you ever see him doing that in all the 27 yrs that you worked with him
A. Never
Q. Did you ever learn that Randy Phillips put a person in Michael’s dressing room
A. Yes
Q. Do you know who put that person in there?
A. Randy Phillips
Q. You told us that Mr. Gongaware was constantly at concert rehearsals, is that right
A. Every time I was there he was there
Q. Do you know that Mr. Phillips was there on the 24 the day before Michael passed away?
A. Yes
Judge Yvette Palazuelos, closes court for the day and Ms. Karen Faye will return to the stand
tomorrow morning, May 10 2013


Der Link dazu: http://teammichaeljackson.com/archives/8324

[manu29]

Daniel Wohlgelernter, M.D.
M.D., F.A.C.C.
Expertise: Interventional Cardiology, Clinical & Preventive Cardiology
Dr. Wohlgelernter earned his medical degree from the Yale University School of Medicine in New Haven,
Connecticut. He completed his internship and residency in Internal Medicine, as well as a fourth year as
chief medical resident, at the Yale Medical Center.
He trained in cardiology at Yale, and served on the Yale medical school faculty for two years before joining
the UCLA faculty in 1985. He is Board Certified in Internal Medicine and Cardiology (Cardiovascular
Disease). He is a Fellow of the American College of Cardiology.
Dr. Wohlgelernter has authored numerous medical journal articles and textbook chapters on a variety of
topics pertaining to the diagnosis and treatment of heart disease. His special interests include preventive
cardiology, management of lipid disorders and hypertension, noninvasive management of arrhythmias,
and interventional cardiology.
Dr. Wohlgelernter was a recipient of The Thomas L. Stern, M.D. prize for excellence in teaching, awarded
by the Santa Monica-UCLA Medical Center Family Practice Residency Program. He is director of the PCCU
at St. John’s Hospital in Santa Monica. Dr. Wohlgelernter was listed as a Southern California “Super Doctor”
in the January 2010, 2011, and 2012 issues of Los Angeles Magazine and was named one of US News and
World Report’s ‘Top Doctors’ in 2012. He has also appeared on The Discovery Channel as a cardiology
commentator.

May 7th 2009
Discussion about filing motions to have Michael Bush and Kathy Hilton deposed. I was not in here when
that was going on but a reporter told me. I missed first 5 minutes. Also there is attorney argument about
showing jurors a picture of a CPR machine?
KJ and Trent present. Five fans present. (later a couple more are present)
Next witness is called out of order to accommodate his schedule, then will resume with witness (the Medical
Examiner) from yesterday:
Plaintiff’s Counsel (same from yesterday, not Panish, not Boyle),
Direct Examination of:
Daniel Wohgelernter (I need to get proper spelling!)
He is a Physician Specialist in Cardiology
Santa Monica: He is part of Cardiology Consultants of Santa Monica
He discusses where he received his degree/medical degrees: He lists university, including Yale
**Questions are asked to establish this witness’s expertise, experience, background, and training. His
background is VERY extensive** (Many answers are given regarding his background etc., too much to
type, WOW)
UCLA included, He was director of Cardiac Catheterization Dept
And other hospitals throughout Los Angeles County, several…
Including working in Coronary Care Units
Currently: Director of Post Coronary Care Unit
Holds teaching positions/credentials
Has never been suspended from any facility
Holds Board Certifications (several)
Does not practice in criminal medicine
Has received awards in field of medicine: teaching award at Santa Monica Hosp., research grant awards,
etc.,
He is considered a “super doctor” in 2010, 2011, 2012, in Cardiology, a term used by a Los Angeles
Magazine…
Is connected to various pharmaceutical companies
Is involved in and a reviewer in various medical journals
Approx 29 articles published, some collaborative efforts: he mentioned some like “Circulation” and he listed
others
This Doctor continues to outline EXTENSIVE experiences, particularly in Cardiology…
He is now answering questions about what kinds of patients he treats, how many patients, about the
frequency of his treatments/meetings with them, the treatments,
Yes he has done consultation with attorneys and on cases over the years, some he rejects based upon
not seeing any merit. He has consulted, accepted the case referrals from many sides, has done
depositions, and has testified in about 30 live trials, approximately.
He has always been qualified to testify to do the above
Exhibit 175-1 is displayed: an email from Paul Gongaware, yes this doctor read PG’s deposition
Reads $150,000 per month for MJ re: CM and talks about how much time, about 10 months to wind
down his own practice before coming on board fulltime for mj. Yes, this is a document that this doctor
considered in forming his opinion in this matter.
Exhibit 177-1: defense objection because there are personal email addresses on it so it needs to be
redacted (covered over) by a black marker first… done in court, now re-displayed. To CM, cc PG, and a
blind copy to Mr Seagal (not sure of spelling), from Tim Wooley an accountant at AEG: Pltff reads the
email, a section that mentions “probably needs” he reads list of things plus something called an “extracorporeal”
CPR unit, (not sure of spelling), one is needed at home base and at venue base (in London, in
places during tour). Doctor explains that it is an external machine that circulates blood outside the body
and then back into it, used in open heart surgery (just one example of its appropriate surgical uses) for
oxygenating blood. This witness says It’s a mistake to list this because no one who is not a qualified person
could use this…
Additional info read: AEG contract will not cover more than one month in lieu of notice of curtailing of
cessation of tour… there was more wording here but Pltff atty read it so fast… couldn’t understand fully

what was being said here….
Then reads a portion about $150k, and something about insurance. ****Exhibit 168-1: An Independent
Contractor agreement. it is effective may 1, 2009, between AEG live Prodrucer LLC,
the producer and GCA Holdings LLC, (Global Cardiovascular Associates, which is CM’s company), and
Doctor CM. yes, these are parties stated in this introduction of the Contract/Agreement, per this doctor
witness. Defense objects…
Paragraph 2: the term of this agreement: Shall commence as of may 1 2009 and continue through end of
last performance of artist unless terminated sooner under terms of this contract , … yes, this doctor
witness used this in determining his conclusion in this matter
Paragraph 7: terms may be terminated as follows: immediately by producer if concert series is cancelled or
postponed at any time and for any reasons, including things beyond control of producer, acts of GOD,
other reasons for grounds for cancellation were listed… yes, doctor used this info in reaching his decision in
this case.
Paragraph 3: the equipment will include a pulmonary resuscitation unit, CPR machine, saline, catheters,
needles, gurney, mutually agreed medical equip; producer shall pay fee for qualified assistant medical
person, the qualified medical assistant shall provide required assistance to CM for services as required by
the doctor- (meaning they were supposed to be paying for AN ASSISTANT FOR CM TO CARE FOR MJ!!)
Yes, this doctor read CM’s curricula vitae (his professional resume): his resume/his background information.
Yes this doctor is familiar with propofol and he explains under which circumstances propofol is used in
surgery, as anesthesia, etc.,
NO cardiologists do NOT administer propofol themselves.
Only trained anesthesiologists administer.
NO cardiology doctors are NOT qualified to administer propofol,
Are cardiologists fit and competent to provide medical treatment for dependency, NO not unless they are
specifically qualified through specialized training for it. NO they are not fit and competent to treat severe
sleeping disorders. NO CM was not qualified per his curriculum vitae resume/background.
Are all doctors, do doctors receive training on how to deal with people who ASK FOR SPECIFIC DRUGS:
YES. What is the training, what are you taught, what is the general good medical practice for when
patients come to you asking for specific medicines: this doctor explains why any meds should be provided,
and why they should NOT, including considering the proper indication, the benefits, the potential for
addiction, there is obligation for doctor to determine if it’s appropriate based upon such potential addiction,
consider careful surveillance.
Does it make a difference at all if the PATIENT SAYS I ALREADY KNOW THE RISK: NO, it does not make a
difference! It is up to the DOCTOR to make this determination, not have the patient dictate what he
should be receiving. This doctor further explains this…
Is it unusual for patients to come looking for certain drugs: unfortunately it is not unusual.
What is the oath that a doctor takes: it’s based upon Hippocrates, the Hippocratic Oath; and he listed
another oath. The oath to do the patient NO HARM.
Earlier this doctor said he did consult with Plaintiff’s attorneys on this case
Yes this doctor reviewed the case information and doctor CM’s standard of care: my opinion is that CM
repeatedly violated the standards of care in treating mj. It was NOT within the appropriate standard for
using propofol for example, the doctor lists why!! CM used it in a way NOT APPROVED.
The setting in which the propofol was administered is that it WAS ABSOLUTELY NOT WITHIN STANDARD
OF CARE
1) CM DID NOT HAVE APPROPR CREDENTIALS IN TERMS OF TRAIINING, KNOWLEDGE
2) ADMINISTRATION OF PROPOFOL MUST BE IN ENVIRONMENT OF CONTINUOUS MONITORING OF
VITALS, AND THE DOCTOR WITNESS SPECIFICALLY LISTS THE VITALS TO BE MONITORED; NEED FULL
RESUSCITATION EQUIPMENT IN EVENT OF RESPIRATORY FAILURE WHICH IS A KNOWN AND EXPECTED
OCCURRENCE FROM USE OF PROPOFOL.

3) APPROPRIATE TRAINED PHYSICIAN(S), RESOURCES, APPROPRIATE PERSONNEL TO ASSIST IN
MONITORING AND TREATMENT OF PATIENT. NONE OF THIS WAS PRESENT.
NO, CM did NOT adequately monitor mj during the administration of propofol. The most striking departure
from standard of care by cm was the fact the cm left mj alone and unattended without any medical
personnel while MJ was under propofol and other sedating agents.
My opinion is that it was NOT within standard of care to administer lorazepam and other sedating agents
because of lack of appropriate equip. Also, cm’s actions once he discovered mj: it was not within standard
of care once CM did discover mj. Given CM’s own description of what he did: cm did not provide airway
breathing support, rather he did chest compression, even when there was a pulse. BREATHING
ASSISTANCE SHOULD HAVE BEEN DONE FIRST. The appropriate first response should have been, if not
patient breathing, if he has received intravenous sedatives and medicines, is to breathe for the patient,
mouth to mouth or open up the patient’s airway or use a bag to connect to patient. Instead CM’s initial
response was to do CPR, this was wrong because it was not his heart that needed to be addressed, but
the breathing!!!
My opinion is that CM did NOT call 911 in a timely fashion given the fact mj had respiratory arrest and
eventual cardiac arrest, and he didn’t have proper equipment and personnel so 911 SHOULD HAVE BEEN
CONTACTED IMMEDIATELY!!!!!!!!
My opinion is that CM was not a fit and competent doctor to provide care for mj based upon the care, he
was not trained, he administered medicines/drugs/anesthesia in a wholly unsatisfactory environment, he
listed other reasons.
My opinion is that his departures from standard of care WERE THE SUBSTANTIAL CAUSE OF MJ DEATH.
My opinion is that CM was NOT an appropriate choice to serve as MJ doc for the THIS IS IT TOUR. Based
upon his review of CM background. No he wasn’t board certified in cardiology and not in another one listed
by atty…
A CPR machine would have been more appropriate than that “extra-corporeal” (spelling not sure) machine
mentioned in that email above…
A picture of a CPR machine is shown: this doctor is going to describe it and its function. This machine
provides automated cardiac massage, externally, so you don’t have to have a person doing it. it is more
consistent more reliable more compressions to the chest, versus a human who can get tired. Can this
machine be used by one person: yes. And then another person can do airway management and admin
medic and call 911 (a scenario if there are two people present). Cardio Pulmonary Resuscitation (cpr)
A defibrillator: is it like a cpr machine: no. it is a device which delivers an electric shock to the chest wall to
help restore normal rhythm for a heart that has stopped breathing. Will it assist NOW to show the jury a
picture, yes, per the doctor, because defense had objected to showing it earlier.
A picture is now shown of a vest on a dummy, the vest is attached to a pump that is apply constant
pressure to the chest, similar to what a human does with his hand compression. Another pump is now
shown, a more elaborate pump. Doctor describes this one…
Do you have an opinion, was a cardiologist was appropriate choice for mj. A conventional or general
cardiologist was NOT trained in substance abuse, addiction medicine, sleep disorders is NOT an appropriate
candidate for MJ’s THIS IS IT TOUR.
They are competent to treat heart attack, angina, blocked arteries, things typically treated in procedure in
hospital. Cardiologist is trained to diagnose issues of the heart, blood vessels, angina, hypertension, heart
disease, high cholesterol… lists others. Is a general or conventional cardiologist fit for MJ on this is it. NO MJ
had NO history of heart disease so a cardiologist would NOT BE APPROPRIATE, it is not what mj needed.
An internist would NOT have been appropriate either for MJ’s conditions listed here….
Based upon your review of the case, should AEG have known MJ’smedical history. DEFENSE OBJECTION.
Now judge puts jurors on a break. OUTSIDE PRESENCE OF JURY: judge hears argument about this from
counsel. Defense counsel cites a case law. Defense atty Cahan is speaking… then Panish responds, and
Cahan interrupts again, and Panish asks her to stop interrupting as Panish did NOT interrupt her while she
was talking, which is true… now they all take a break. …
OUTSIDE PRESENCE OF JURORS: The attorneys and Judge resume: Panish and the attorneys are back
trying to determine how to properly phrase the LAST QUESTION that Pltff’s counsel was trying to ask right
before the break. This is going on outside the presence of the jury. Atty Cahan, Panish and the Pltff’s atty
doing the current questioning are involved in this discussion. They are discussing the emails, and
newspaper articles; I can barely hear Putnam chiming in on this discussion… defense counsel does not
want the witness “opining” about AEG’s knowledge, or basically she does not want this witness giving an
opinion about what AEG’s knowledge should or should not have been… that’s the gist of it, it seems…
11:23, now with the witness resuming the stand….
Pltff’s atty resumes, pltff’s attorney has the doctor review his answers that he previously gave regarding
CM NOT being competently trained. What exactly is it about MJ that made CM not competent. Doc says
mj has history of substance use issues, sleep disorders. He explains HOW he knows this because atty
cahan asked. Were there people from AEG that you received this information from. Yes, the doctor
witness says he got information from PG, his deposition, which he reviewed.
The PG deposition testified about his involvement in the DANGEROUS TOUR IN 1993 AND ABOUT
PROBLEMS THAT MJ HAD ON THAT TOUR WITH SUSPSECTED SUBST ABUSE, ADDICTION, PROBLEMS
WITH PRESCRIPTION MEDS. PG ALSO TESTIFIED ABOUT HIS RELATIONSHIP WITH DOC FINKELSTEIN,
DISCUSSIONS ABOUT MJ PROBS, AND THIS DOC WAS A SPECIALIST. Per PG testimony, were there other
physicians treating during Dangerous tour. Yes, an anesthesiologist, providing sleeping assistance,
medicines, this is knowledge this doc got from PG deposition. Yes, also there was a news article where this
doc gleaned his information.
Is there a manner in which CM dealt with AEG that influenced your decision in terms of his monetary
demands. Yes, cm was willing to leave his practices and become dependent upon AEG for his income
during tour (I paraphrased this… because he said it so fast)
My initial understanding was that CM wanted 5 million, a very large number, and exceeds standard income
for cardiologist. Then there was 150k issue raised.
They read a termination clause from the contract/agreement: #2: reviewing what was said above about
cancellation. Why did this part influence you? This doctor witness said it influenced me because it meant
that cm was entirely dependent on the continuation of the tour for his income/livelihood…. And that part
about CM leaving his practice in 10 days, why did that influence you.
This doctor witness said well it speaks to cm being in a position to be entirely dependent on AEG and MJ.
To shut down his practice, he would not have ongoing sources of income. What happens to a patient if a
cardio closes his practice in 10 days. Defense objection. So atty asks what would happen if HE closed his
practice. He said he has associates but it would be psychologically damaging to patients, and disruptive to
their lives and care.
The cm request for a CPR machine influenced my opinion because it is AN UNCONVENTIONAL request for
a patient with no heart disease or history of cardiac request, it is just not necessary for this patient. He
listed the reasons…
What was wrong with what AEG did: cm was credentialed in internal med, cardio, interventional cardio, not
trained in substance abuse, dependency/addiction, sleep disorder, MJ had no heart disease but did have
the things just listed. No, CM was not the right doctor for this patient. MJ did not have respiratory disease,
or need for ???
The termination clause: what position did this put CM in? defense objects. Sustained.
Why do you think the termination clause poses a problem for CM: because CM was wholly dependent
upon AEG. He had to maintain mj to perform to maintain the contract and it poses a CONFLICT OF
INTEREST in terms of being a medical doctor caring for a patient, but having the strain of worrying about,
being bound by that contract. This is a summary, not word for word…. !!!
Defense objection!!!!!!!! SUSTAINED AND THE ANSWER IS STRICKEN. A HUGE ARGUMENT STARTED
HERE!!!!!!!!!!!
WOULD THAT PROVISION, WHAT EFFECT WOULD THAT TERMINATION PROVISION HAVE ON A
DOCTOR: ok now they go to side-bar because Judge directs counsel to approach side-bar.
In summary doctor: do you believe that cm was a competent and fit physic for aeg to hire: NO
He gives his pay rate for testifying. Plus hourly rate. $450 an hour to prepare for this testimony
Now it’s defense counsel doing cross-examination: defense atty cahan
Who is paying you to testify. Pltff’s counsel is paying him
Yes he has worked for that Pltff’s counsel 3 times previously
She is asking how much time has he devoted to expert witness testifying: about 20% of his income and
15% for … ?????
Has been retained as expert wit 400 times, 200 times deposed
For Pltff attys he has been retained more ??? he gave a percentage that I couldn’t catch
Over past 30 years I have made over 1million, yes….
You said that CM was not competent and fit to be mj’s doctor, and she recites his answers previously
given
Any other basis other than his resume/curricula vitae: no
Do you know if defense knew about CM training and obligations before this case, no I don’t know what
they did and didn’t know
Doctor recites what he understood about Dangerous tour, PG’s relationship with MJ back then and PG’s
relationship with that tour doctor mentioned earlier, and referring to a newspaper article from 2008 that
reported concerns/suspicions about mj still having substance abuse back then
Cahan says let’s take that apart: yes I reviewed doc finkelstein’ deposition.
Were you aware that at the end of dangerous tour, mj announced he was going to rehab
So the public as a whole knew that mj had a substance abuse problems as result of this announcement,
not just PG: yes from back in 1993
No, doc finkelstein was not an addiction expert during 1993 dangerous tour, was later though
Another doc provided medic for sleep problems: this doc was mentioned in doc finkelstein deposition,
because cahan asked this doc how he knew this. But I couldn’t catch the other doc’s name…
Yes, there are things from PG depo that I am relying on for my testimony: yes, that PG was aware of mj
subst dependency and use issues during the 1993 Dangerous Tour.
So cahan gives a copy of Doc finkelstein’s deposition to the witness to reference: there are some
objections by pltff… then there is argument. Can the atty’s stipulate that the information that this doc
referred to IS somewhere in there…. they didn’t. (the other doctor is Dr. Forecast)
Judge says lets proceed, and let the witness try to find it…
Can you remember if doc finkelstein specifically testified about sleeping disorders: yes, there are specific
references.
Doctor points to page 45: he reads from the deposition. question to doc finkelstein, was mj suffering from
anything other than dehydration, I thought opiate, dependency, which opiates, did you understand what
I was trying to ask. Try to answer it: doc finkelstein mj had Demerol and something else I couldn’t catch.
Page 46: ….mj had high tolerance for medicines given…. Cahan’s objection was about no mention of
insomnia and nowhere here did this doctor witness find it yet where doc finkelstein mentioned it, so the
judge sustained it and the answer given earlier is stricken where this witness said it was there. so judge said
to attys to review the depo., and find it.
…. LUNCH BREAK….
After lunch: aeg defense atty resumes cross-examination:
She asks doc W if he had a chance to review the deposition of doc Finkelstein, yes he did, and no, there
was no mention of insomnia, sleep disorder in doc finkelstein’s deposition.
Aeg defense atty proceeds to review with doc W his previous testimony re: why CONRAD MURRAY was
not appropriate doc for MJ. And doc W gives brief distinction between addiction and dependency… ??
Page 91: this page is not specifically about MJ but about opiates/opiods
Yes my expertise is in cardiology, not addiction, not substance abuse, not in internal medicine but did have
some training??
From 2006 to june 2009 Conrad Murray was doing some sort of caring for MJ, this was aeg atty’s
question, it wasn’t a clear question per this doctor witness.
You reviewed records re: Conrad Murray treating MJ. Yes I saw ways in which Conrad Murray was treating
MJ other than as an internal med doc. Like heart and cardiac tests, other tests… ???
Is it your opinion that Conrad Murray was a competent internal medicine doc based upon your review
of records: yes
Conrad Murray was board certified in internal medicine. aeg atty is asking questions about his certification
in internal medicine, as an internist… aeg atty asks general questions about what Conrad Murray could do
as an internal med doctor
Exhibit is displayed: the contract/agreement they reviewed earlier. Aeg atty asks doctor witness to read
where and how Conrad Murray is certified…
To paragraph 1: GCA and Conrad Murray are mentioned, hereby agree that Conrad Murray will provide
general medical care throughout the duration of the concert terms…. Yes it is my opinion that he was to
treat as a general doctor and NOT for dependency, NOT for insomnia. aeg atty listed some other things…
Did you read info that MJ was receiving treatment from other doctors from 2006 to 2009: yes.
Do you know if they were treating MJ for psychological issues, drug dependency, sleep problems: no he
didn’t know.
So it’s possible that MJ was getting treatment from other doctors for those: it’s possible, I am not aware.
Aeg atty wants to discuss further the contract: who drafted it: I don’t know, she asked other
questions, and he said I have no knowledge of any of what she asked in terms of number of pages, when
finalized, who was involved in drafting it, etc.
Aeg atty refers to CONRAD MURRAY, GCA: was it signed by him, yes signed. But over by AEG’s
signature section, no not signed. Then doctor witness reads language about what the “undersigned” is
agreeing to… and there is a section for MJ, and aeg atty recites what that paragraph about agreement is,
did MJ sign it: no. do you know if this contract was ever finalized and in effect: no, I don’t know.
Do you know which provisions were requested by CONRAD MURRAY, or by AEG, or by MJ : doctor
witness said no, in don’t know to all of these questions.
Do you know who chose Conrad Murray: I know MJ requested him but the ultimate decision was
made by AEG LIVE. Aeg atty asks doctor witness what’s your basis for that answer: I don’t recall
where I saw it but the doctor witness refers to PG and his discussions re: physicians and MJ relationship
with CONRAD MURRAY, doctor witness says it’s based upon PG indicating this information.
Aeg atty reads a section of contract: at the artist’s request, the producer: AEG has agreed to retain
Conrad Murray per request of artist… does this affect your opinion about who made the decision: no it
doesn’t change my opinion, I already conceded that MJ made the request.
Aeg atty reads another section: producer (aeg), shall remit payment of 150k to GCA (Conrad Murray),
and she reads the timeframe when Conrad Murray would get paid. What do you make of this: it’s on the
15 day of month or five days after ???? something I couldn’t hear…
Do you know if Conrad Murray was ever paid by aeg: no I don’t know. would it change your opinion at
all if he was paid by MJ: no it would not change my opinion.
Let’s go to section, the termination section: paragraph 7.2: you were asked about this. You said it was
relevant to you re: Conrad Murray contract being subject to cancellation by the producer (aeg). There
is other information in this section re: Conrad Murray right? yes. Aeg atty reads that also the artist can
terminate Conrad Murray. does that affect your opinion at all : no.
You were asked about ??? section 7.4 says that the contract can be terminated immediately if Conrad
Murray does not obtain appropriate….???? She read what Conrad Murray was required to obtain in
terms of his licensing, do you understand this: it was re: appropriate licensing and other requirements per
law, that if Conrad Murray didn’t have this, then the contract could/would be cancelled.
Aeg atty reads re: termination could result if Conrad Murray didn’t provide legal proof/documentation to
aeg that he is licensed in the USA to practice medicine. What does this mean? The doctor witness
explains his understanding that basically Conrad Murray needed to prove his medical practice license…
Aeg atty reads about further documentation re: CM having license to practice medicine in UK. What
does this mean: the doctor witness says that it speaks for itself that if Conrad Murray does NOT have the
documentation to practice in England, then he couldn’t fulfill contract.
Paragraph 9: artist’s content: the artist must approve. Without the artist’s express approval of this
agreement… (there is more language), neither party can exercise the terms of this contract, benefit from
it, and there is some other language. What does this mean: it means that MJ must approve of this
agreement and that otherwise without MJ approval it basically can’t be a valid contract?… it can’t be
something else aeg atty said, implied… ???
Independent contractor: do you know who that is. I can’t offer legal opinion on that.
Pltff atty objects to further questioning about this doctor’s opinion on what supervising a legal contractor
means. Aeg atty moves on…
Now about the medical equipment portion language in contract: aeg atty mentions cpr equipment. are
you aware of any mention anywhere else in contract… were you aware that the contract was subject to
change? No I was not aware. do you agree that most other people not in medical field would not
understand some of this (medical equipment) language: yes I agree.
Let’s talk about cpr machine: how much does it cost: I have no idea. Aeg atty says about 15k: yes.
How much does a defibrillator machine costs: aeg atty says some dollar amount…
How common are cpr machines. Very uncommon but I have used them in training….
Have you ever seen a non-doctor’s office with a cpr machine: no
Yes, it’s ATYPICAL (meaning NOT typical) to request a cpr machine
No, it’s not atypical to request a defibrillator machine, meaning it IS common to request a defib machine.
Did you read tim wooley’s deposition: yes part of it.
Did you read the part where he mentions cpr machine: yes.
Yes, It would change my opinion if TW had said a defib machine instead of a cpr machine.
Do you know who cathy jory is: no. aeg atty explains she is atty who was part of drafting this contract,
so you don’t know her, no.
Do you know of doc steinberg: yes. Yes I knew he is an expert, yes that he gave deposition, no I didn’t
read it. so you don’t know if what was meant to be said (in the contract) was “defib” instead of cpr
machine when mentioned… no I don’t know.
You mentioned in testimony re: Conrad Murray departures/deviations from standards of care: yes. And it
led to CM’s conviction: yes.
Aeg atty reviews this doctor witness’s previous testimony from earlier today (see above). She starts listing
what this doctor witness cited as Conrad Murray’s deviations, the effects of CM deviations for MJ, all
testimony mentioned above: yes.
What did you review to come to these opinions
Police report based on interview of Conrad Murray, depositions of witnesses. Other records/info was
mentioned…
Did you read the transcripts of police interview of CM. Yes. Was that the primary basis of your opinion.
Doctor witness gives an answer that indicates it wasn’t the complete basis….
Is it your understanding that only Conrad Murray and MJ were present in late evening of the 24 and
early morning of 25 , per Conrad Murray interview: yes.
You reviewed the expert witness testimony: yes. And some of the experts’ testimonies were also based
upon Conrad Murray’s interview: yes.
And you expressed opinion on Conrad Murray leaving his practice: yes….
What is a concierge physician, we asked you about that in your deposition: this doctor witness defines it.
and he says he knows of a friend who has been doing it for 15 years. concierge physicians primarily rely
on taking care of one patient or of one family? The doctor witness describes his friend as a concierge
physician. Yes, I agree that just because a person is a concierge physician doesn’t mean they can’t be a
good doctor.
And you know about Conrad Murray asking for 5 million dollars to care for MJ: yes.
Do you know about when Conrad Murray was asked to be doctor for MJ, it seems that doctor witness
didn’t have exact timing… I think he said no.
If it was back in december 2008 would it change your opinion: no
Aeg atty asks about Conrad Murray closing down his practice and different timeframes and under which
timeframes would it have affected this doctor witness’s opinion of Conrad Murray. sometimes this doctor
witness said yes about changing his opinion based upon timeframe scenarios mentioned by aeg atty.
Atty aeg atty now gets into training of this doctor witness. Were you ever trained to administer propofol:
no
How often do cardiologist doctors administer propofol: never. I agree that cardiologist doctors don’t do
this. Aeg atty starts rattling off questions fast about who ever does this (administer propofol)….
Have you ever administered propofol: no. never. In over 30 years, no, never, not for any reasons… not
for diagnostic, not for other cardiology, certainly not for insomnia, not in home, no never written
prescription. A bunch of No No No No answers…
No never heard of a doctor giving written prescription for propofol. No never heard of any doctor
recommending or giving prescription for propofol. Does your office keep propofol: no. do you know of
any cardiologist, internist, primary care doctor, or of practitioners administering propofol: no no no. so
only anesthesiologists, yes. In proper facility: yes. With propofol equipment.
no, an anesthesiologist has not administered propofol in home, for insomnia, no never. Not before this
case. No, before this case, I never heard of anyone receiving propofol in a home for any reason.
Aeg atty asks about his training students at UCLA: areas of cardiology, cardiac catheterization, and some
other areas stated by aeg atty, and doctor witness acknowledges types of training he gives to
students… aeg atty asks him what he does train and what he was trained in himself…
Based on your experience, are most doctors trained to apply cpr: yes. How about cardiologists, primary
care physicians: yes. So it’s reasonable to expect a cardiologist, an internist could administer cpr: yes. A
primary care doctor can administer cpr, is that reasonable: yes
Aeg atty brings up Hippocratic oath and that you talked about patient not dictating the medical care
That it’s the doctor who ultimately makes decision: yes. And one expectation is that the patient will be
forthcoming about his medical history, yes; yes doctors are dependent upon their patients being honest
so that they can properly care for them, yes. Yes the doctor is dependent upon patients telling doctor
what meds they are on… and other things along this line. If a patient is not forthcoming and something
bad happens, who is responsible for that? pltff atty objects. A patient needs to fully disclose about his
medications… it’s relevant for treatment, I agree….
You were asked about your assessment of Conrad Murray’s qualification: you based some of that on
Conrad Murray’s curricula vitae: yes…
(note: sometimes aeg atty is talking so fast I couldn’t catch it all)
Exhibit displayed re: Conrad Murray’s curricula vitae: and reviews where Conrad Murray went to school.
Describes where he was a med student; aeg atty points out Conrad Murray internship, residency training,
she points out that these are respectable institutions; respectable places to do cardiology fellowship… so
based on Conrad Murray credentials, yes I agree that Conrad Murray appears to be competent as a
cardiologist.
(((even though earlier in testimony, AND in CM trial it WAS established that CM was NOT “board certified”
as a cardiologist).
Yes, CM fit as cardiologist. Nothing about these credentials suggests that CM was unqualified to practice
medicine, cardiology, internal medicine, or as primary care physician: yes I agree.
Do you see anything that suggests he had training for sleep disorders, insomnia: no. is there anything in
his training that would indicate that he would treat MJ with propofol: no. nothing that would indicate he
would do it in home: no. no, I don’t see anything that suggests that Conrad Murray would administer
propofol anywhere else, to anyone else…. Aside from him doing it with MJ. did you see anything that
suggests that Conrad Murray caused another patient to die from administering medicines: no. no, I
didn’t see any proof of Conrad Murray having been sued for malpractice. She asks other questions along
these lines to suggest that Conrad Murray’s resume would NOT give any clues or suggestions that Conrad
Murray would have done what he did….
Do you know what a rock doctor (tour doctor is) . doctor witness defines his understanding.
Is there anything in Conrad Murray’s resume to suggest that he was qualified to be a tour or “rock”
doctor: no.
—————————-
Pltff atty resumes: re-direct examination
Going back to the contract: pltff’s atty points out the parties involved in the contract again.
Atty recites parts: at the artist’s request: The PRODUCER HAS AGREED TO HIRE/RETAIN Conrad
Murray. Defense atty objects, PLtff atty says that defense atty opened this door. So Pltff atty says WHO
IS RETAINING, WHO IS THE PRODUCER! Doctor witness says I understand producer to be AEG. Who is
going to provide the medical equip: AEG Live would be providing the med equip. Pltff’s atty recites the
equipment briefly. CONRAD MURRAY is a doctor so you assume that he would know what a cpr machine
vs what a defib machine is: YES HE SHOULD KNOW. Then cites the “extra-corporeal” machine, and that
that language was later changed in contract to say CPR machine, there are defense objections.
Pltff’s atty cites Tim Wooley email to CONRAD MURRAY: from TW. Subject is the concert tour: yes.
Conrad Murray it is a pleasure meeting you on the phone. TW is talking about Contracting entity GCA,
your contact info was: info from email is recited, gives tele number of CM, which is not stated in court;
your mode of travel. And who does it say pays for professional costs including transportation? Aeg.
Then it says need the home based, venue based “extra-corporeal” cpr unit. Later it says cpr machine.
Is there a difference between those two: yes. Conrad Murray would know: yes. Do you know if AEG
ever saw CONRAD MURRAY’s curricula vitae.
Did PG say he did anything at all to check him out, in fact it says they didn’t do anything to check him
out- this doctor witness confirms all this!!!! Why is this important. doctor witness explains the obligation
for AEG to do this, cites the request for use of cpr machine, MJ’s conditions, other reasons that would
justify additional investigation into Conrad Murray by AEG….
Now back to “concierge” doctor: was this arrangement for Conrad Murray DIFFERENT FROM A
CONCIERGE DOCTOR: yes. Let’s go back to the contract: where it lists responsibilities: perform services
reasonably requested BY THE PRODUCER. So your friend, as concierge physician, who was he working
for: the family. So here if Conrad Murray is providing services to the producer, is that different from a
concierge physician: yes because my friend was obligated to serve the family. Here Conrad Murray was
responsible to a third party, that being AEG live.
What would happen if the tour got postponed or cancelled: Conrad Murray is out of a job. Yes that
entered into my consideration. You said that you didn’t know that aeg knew Conrad Murray would give
propofol: yes, i said I didn’t know. So if they didn’t know this, why is it that you said they STILL should
not have hired him: well Conrad Murray, a cardiologist, who would be willing to abandon that
practice to provide service only for an individual, to take care of a patient who doesn’t need
the services he was trained in. also it required to leave abruptly and abandon his patients, for
a patient who didn’t require his specific skills. And Conrad Murray knew there was a
contractual understanding that the contract could end at ANY TIME. also, that he requested
a cpr machine, life support machines, what was this doctor PLANNING TO DO, all this points to
red flags.
Would the fact the MJ requested him, does that matter. No, but what IS a red flag in terms of MJ is that
MJ has a history of substance abuse and addiction, and he specifically is asking for a doctor who HAS NO
TRAINING IN THIS AREA. WHY WOULD THESE TWO WANT EACH OTHER.
Now Plttf’s atty points to email from Randy Phillips: RP is saying have you read these (news article)
stories. RP says that the reporter has done a lot of research: one article is dated Dec 15, 2008. Now
Pltff’s atty scrolls into email to what the stories are: the ranch has been sold, the monkey moved out.
The moonwalker…. (All this is being recited from RP’s email about news articles he read….)
Is there any truth that MJ is staging a comeback… I can’t hear all of what atty is reading. Now on to next
page. MJ has problems with lower back, alcohol and pain killers for years. now Pltff’s atty asks doctor
witness, would you consider that story in your opinion as to AEG’s knowledge about MJ: yes. Is there a
non-invasive way that someone can be tested for drugs: yes. Have you heard of areas where people
can find out if someone still has a drug problem. Yes. Based on this article, does it seem that RP is aware
of MJ issues: yes. Did RP have to absolutely know that MJ had a problem to warrant more investigation:
no, because given the suspicions, discussions, MJ history, those factors alone mean that they could have
and should have done further investigations (on Conrad Murray).
Now showing Conrad Murray curricula vitae (resume): we don’t know whether AEG has seen it, Pltff’s
atty says. Do you know when Conrad Murray composed this: no.
Now reviewing Conrad Murray’s resume again…. They go section by section of his training, fellowships,
degrees etc., all about interventional and cardiology medicine… interventional cardiology, so between
1998 and 2006, Conrad Murray did nothing but interventional cardiology and cardiology: yes.
Now p.m. break. During break I could hear attys talking inside courtroom with no jurors, but I was outside
to clean up these notes, so I could not hear what they were saying…
Resumes after 3p.m. break:
Pltff’s atty continues with re-direct examination:
Pltff’s atty says that aeg defense attys earlier asked you about the written contract signed: Conrad
Murray signed it. do you know if it was ever even presented to MJ for signing: no I have no knowledge of
that.
An exhibit is mentioned and is about to be displayed: but first, attys go to side-bar about this exhibit.
Resume at 03:27p.m.
Pltff’s atty continues: Doctor we have been asking about the unsigned agreement. Assume that Conrad
Murray was operating under an agreement with AEG to provide services for MJ. And assume that terms of
that contract began on may 1 2009. So Conrad Murray under that contract, did he operate within
perimeters of standard of care: no.
You were asked about whether there was any evidence before Conrad Murray was hired that MJ suffered
from insomnia: yes, I was asked. So Pltff’s atty pulls up records of Conrad Murray: Pltff’s atty refers to
an exhibit. Date of this Conrad Murray record is 9-26-08: now exhibit is displayed. It is a report from
Conrad Murray about MJ and it says patient complains of insomnia, he has no evidence of mood changes,
no signs of depression, in general great health, reads other notes about MJ health… and the plan was to
treat him with Restoril (Temazepam), (I think pltff’s atty read the word Restoril/Ristoril) Do you know if
aeg even asked Conrad Murray what MJ’s problems were: no, not to my knowledge.
Assume that, in Conrad Murray’s reliance on contract with aeg, he sent a letter to all his patients in june
2009 saying I am not going to be your doctor, going on special trip… would that have put pressure on
Conrad Murray, what is your opinion. Yes I have an opinion about Conrad Murray getting MJ on stage:
yes Conrad Murray would have pressures to get MJ to perform…. (this is paraphrased) Doctor said more
about his opinion on pressure on CM…
—————————————————–
**NOTE: at times, aeg defense atty was hard to hear and hard to understand. Some of her
questions were just confusing… sorry L
aeg atty: did you review any info/contract/something? re: between MJ and aeg… no.
pltff objects.
Aeg atty cites something that says it was MJ’s expense to retain Conrad Murray.
Aeg atty cites section that says something about the contract language issues/confusion
Did anyone tell you what ms. Jory said about her testimony about this agreement: no
Atty aeg atty is asking some stuff I just can’t understand!!! L
Aeg atty cites language about atty jory and her deposition, and if this doctor witness knows anything
about this… it was not clear to me what aeg atty is saying…????
aeg atty says: Hypothetically, assume that there is a typo (typing error) there in the contract where it
says “producer” and it should have said “artist,” would that change your opinion: yes. And doctor
explains why…. essentially that it would be between MJ and Conrad Murray, not so much between Conrad
Murray and aeg, if in fact there was some sort of typing error in the contract in a certain section that atty
aeg atty tried to point out??
aeg atty is asking questions about some confusion between contracts use of the word defibrillator
machine and cpr machine… and asks this doctor witness about his opinion changes, if any, if the use of
the machine words were changed in certain sections. She is implying that someone who drafted this
contract was using the words as meaning the same thing when they are NOT the same things…. That is
what she seems to be aiming at…
aeg atty raises issue again about this doctor witness friend being a concierge doctor.
Now to section 7.2: re: producer’s rights to cancel Conrad Murray contract… looking at the header for
section 7, it says terms “may” be terminated under the following conditions, so it was not that they were
required to terminate….
Now raises issues of MJ issues during tours: she raises Dangerous tour. Doctor witness says he is only
referring to Dangerous.
Now re: news story from December 2008: aeg atty asks if this was part of his basis for saying MJ had
issues with pain killers. *for some reason, another “doctor,” Doc tohmme is mentioned at this point, not
Conrad Murray. But it was so mirky what aeg atty said!!!!!!
Fair to say that there have been a lot of stories about MJ over the years: some true, some false: yes.
Are you aware of MJ family denying any news as of 2007 stories saying that MJ had ongoing drug prob:
no I’m not.
There is a brief pause, side-bar… about something aeg atty wants to show in court
Aeg atty continues: she says: Assume that in late 2007 that certain Jackson family members issued a
statement denying MJ substance abuse, so would that change your opinion about assumptions about
knowledge of (aeg, RP, PG, etc., ???) based upon the 2008 news article (mentioned above): no.
Is it appropriate for aeg to ask certain questions about MJ health, per HIPPA law, patient/doctor
confidentiality & privacy: no. and if Conrad Murray answered, would that have been appropriate: no it
would not have been appropriate.
—————————-***NOW PLTFF ATTY: Couldn’t AEG have gotten an authorization from MJ and/or
Conrad Murray to get health info on MJ if they wanted to: yes. To your knowledge, did they: no.
to your knowledge did AEG do anything to obtain medical information from CONRAD MURRAY
about MJ: no. (it seems that the issue is AEG did not ask CONRAD MURRAY to get medical info on MJ…)
(note: this is *not* testimony, just an observation after hearing all of this back and forth on what AEG
did or didn’t do’ knew or didn’t know: some people can say that by AEG not asking CONRAD MURRAY
to get detailed medical info on MJ, for example about his medicines used for sleeping and pain, this might
“work in aeg’s favor” to paint a picture that they DID NOT KNOW what Michael was taking… but that
doesn’t fly because AEG DID KNOW, based upon their OWN executives’ depositions, their own past
relationships with MJ, like PG during tours with MJ, and what they put in those emails. So even though we
know that the AEG executives ALREADY knew that Michael needed sleeping and pain medicines during
previous tours, it was STILL THEIR responsibility when hiring CONRAD MURRAY to have CONRAD MURRAY
get medical information on MJ.
For one thing, it’s part of what THEY wrote in the contract about the doctor being able to provide the
right care for MJ– how can a doctor provide the right care if that doctor doesn’t get adequate medical
info, and if that doctor doesn’t even meet the qualifications to provide specific care needed by MJ (as
clearly pointed out by today’s expert witness), and it seems that AEG didn’t push CONRAD MURRAY to get
the info, and AEG didn’t do a thorough background check on CONRAD MURRAY, as pointed out by
today’s expert witness.
AEG didn’t CARE about having CONRAD MURRAY get certain medical info because: 1) they knew about it
already, at least in terms of MJ needing sleep and pain medicine, 2) AEG knew and ensured that they would
get profit/millions, no matter what happened to MJ, and 3) they probably did NOT WANT an
appropriately competent doctor for Michael’s specific needs, aeg would not want a doctor who WOULD
ACTUALLY CARE AND ASK THE RIGHT QUESTIONS… They hired a doctor who DID NOT CARE, a doctor
who would only care to get his money, no matter what it meant he had to do (or not do) to MJ to get it…
Court ends… but Panish requests a side-bar.

http://teammichaeljackson.com/archives/8293

[manu29]

Alif Sankey
(Associate Producer, This Is It)
Plaintiff’s Witness.


Prior to questioning, AEG attorney Motion in Limine, they want this witness cautioned not to discuss
doctors’ opinions relating to Michael Jackson’s health, his ability to perform and whether the tour should
have been postponed. AEG citing hearsay objection. Jackson attorney argues that the order regarding
doctors’ opinions does not mean that they can not question about how Michael was doing in performing.
Plaintiff has right to question as means of relating to the retention and supervision of Conrad Murray.
Judge agrees.
Direct examination by Brian Panish.
Q How are you employed?
A I’m a choreographer, dancer and producer. For 30 years, since age 8. Ballet, tap, ballroom
dancing.
Q How did you become a professional dancer?
A I was trained from age 8 to 17. I’ve done TV work, concert stage, movies, music videos. Started
assisting choreographer and choreographed myself for concert stage.
Q What artists did you do music videos for?
A The biggest music video I’ve done is Michael Jackson’s Smooth Criminal in 1987. I’ve also done
music videos for Gloria Estefan, Donna Summer, Cher and others.
Q Have you ever worked on any sporting event performances?
A I did the 1994 World Cup opening ceremony with Diana Ross. I was a dancer.
Q How did you become involved with making Smooth Criminal video with Michael Jackson?
A I auditioned with over 500 other dancers. I didn’t do so well the first time. I was nervous because it
was for Michael Jackson. Choreographer Vincent Patterson was my teacher. I got a call back and was
chosen for the video.
Q Tell us about your first meeting with Michael Jackson?
A My first meeting, delightful. Then after we were into rehearsals, Vincent Patterson would have to
give us what I call “the Michael talk” – which was on the days Michael was coming on set. So get rid of all
your nervousness and excitement out of you, it‘s normal. I was a huge fan of Michael’s. And then I’m
working for him. (laughs) So Michael came on the set. We were in costume and makeup – in
position the do opening segment. Michael came over to me and I was very nervous. Michael said, “Who
did your eyes?” I told him I did. That was my first encounter with Michael Jackson.
Q What was it like to work with Michael Jackson on the Smooth Criminal video?
A It was amazing. It will always be the best job of my career. Michael’s process is genius. The way he
can envisualize. He would visualize it and it would happen. Smooth Criminal is part of the film, Moonwalker.
We got to see Michael’s imagination. That was the first time as an artist/dancer that I was completely
inspired. By his craft and attention to every detail. He never missed a thing. He paid attention to every
detail of the entire process. I was inspired. I call it magic. IT WAS ABSOLUTELY MAGICAL TO WORK WITH
HIM. I dream to this day that I will be able to create on that level of magic that Michael created. It was living
a dream to work with an artist like that. Just a dream. And I will treasure it and have it in my memory
forever.
Q How many people worked on that video?
A Smooth Criminal was a big production. 50 dancers. Large crew.
(Panish plays the Smooth Criminal video)
Q Is there a storyline to Smooth Criminal?
A Yes. Michael and Vincent came up with the theme for the video. It was inspired by the film,
Bandwagon starring Fred Astaire. We dancers all got to come up with our own stories of who we were in
the video. There was a lot of staging and choreography to keep everything moving. It was so unique.
There were individual shots such as: Michael coming to the door, Michael flipping a coin. There was also a
master shot. So the an editor of the film pulls from different angled shots. The process took about 3
months to complete the video.
Q What did Mr. Jackson call music videos?
A He called them short films.
Q Did you become friendly with Michael Jackson?
A I wouldn’t say friendly but he always remembered me, my face, over the years.
Q This was part of a larger production?
A Yes. It was part of Michael’s film, Moonwalker. First part encompassed his career with the Jackson 5
up the Bad Tour concert footage. The plot surrounded the three kids in the film and Joe Peschi was in it.
Q Did he dance?
A (laughs) No. He was the bad guy.
Q Did you ever go on tour with Michael?
A No I didn’t.
Q Do you know an individual by the name of Kenny Ortega?
A Yes.
Q Who is he?
A Kenny Ortega is a choreographer, director and producer.
Q What does a choreographer, director and producer do?
A A choreographer brings steps together and creates a dance. Director directs the overall project. A
producer oversees everything to do with the project.
Q When did you meet Kenny Ortega?
A I met him over 20 years ago. I auditioned for him as a dancer. I worked on a movie with hi called,
Spirts. Kenny and I became friends after that. I worked for him off and on as a dancer, as an assistant
choreographer, and as a personal assistant on movies and TV shows.
Q Do you know if Mr. Jackson ever worked with Mr. Ortega?
A Yes. Kenny worked with Michael on two tours – the Dangerous Tour and the History Tour.
Q Did you work with Mr. Jackson again after the Smooth Criminal video?
A Yes, I did. I worked with Michael in 1991, for the MTV 10th Anniversary Special. I was a dancer. It
was my first time on stage live with Michael. It was televised. I worked with Michael again in 1996, at the Brit
Awards in London. Michael performed, Earth Song. Next time I worked with him was October 2001. I‘m
not too sure… [United We Stand, 9-11 benefit concert from RFK Stadium]. He performed Man In The
Mirror, but it was never aired. I was part of the production team, production coordinator.
Q During all these times, were you ever concerned about Michael’s health, emotional state, physical
state or ability to perform?
A No.
Q When did you see Michael Jackson again?
A In 2006. Michael and Kenny had a creative meeting together and I got to see Michael briefly at that
point. I was Kenny’s personal assistant at the time. But I was not privy to what the meeting was about.
Q Did he look different to you then?
A Yes.
Q How was he different?
A He was very thin. He didn’t look like he did last time I saw him in 2001. I hugged him and – he felt
different. I’ve hugged Michael before. In 1996, I hugged him. And his body, as I describe – he was always
thin, but he had muscle mass. Like marble. He had a hard body. When I hugged him briefly in 2006, he
didn’t feel like that anymore. He felt THIN. He just felt thin.
Q How did you get involved with This Is It project?
A Kenny called me. I was given job as associate producer. Overseeing every aspect of shows logistics
– lighting, costumes, staging, graphics, video, makeup, hair, making sure dancers are healthy to do shows.
I was Kenny’s point person. Things would come through me and I would pass them on to Kenny or vise
versa.
Q Were you involved with emailing or receiving emails for Mr. Ortega?
A Yes.
Q And AEG were?
A AEG were promoters of the show.
Q Did you enter into an agreement with AEG to work on this project?
A Yes. I was given a contract by AEG to work on the tour.
Q Who did you discuss that with?
A My contract went through my agents – with Paul Gongaware.
Q What was your understanding of Mr. Gongaware’s role in the process?
A He was the person that put the show on. He was in charge.
Q Who were you working for?
A My point person was Kenny, but AEG – they were paying my salary. My contract was with AEG.
Q Kenny Ortega, who was he reporting to?
A He was the director and producer of the show. He was reporting to Paul Gongaware and Randy
Phillips.
Q Were you working directly for Michael Jackson during this time?
A No.
Q Who was it that paid your salary?
A AEG.
Q Who was it that could terminate your employment?
A AEG.
Q This Is It. What was this project? What was it supposed to be?
A This Is it was supposed to be Michael’s comeback. It was going to be huge. It was going to be
innovative. Knowing Michael, it was going to be something that no one’s ever seen. It all had to be new
and pioneering. Because that’s the way Michael was. His imagination was endless. And what was being
created, was taking what he had done before and taking it to the next level.
Q Was this to be a concert?
A This was to be a concert held in London at the O2 Arena.
Q Is that a big arena.
A Yes.
Q In general, how long does a concert last?
A Two hours or more. It depends on the artist.
Q Was there anyone else going to be performed?
A I don’t know for sure. I’d heard rumors that Slash was probably coming in and playing on a couple
songs. Slash used to be the guitarist for Guns ‘n Roses and he had worked with Michael on a few songs in
the past. He was actually on stage during the 1999 performance on TV. — [Michael’s accident in Germany,
when the bridge he was standing on over the stage plummeted down]
Q You auditioned the dancers. How many dancers did you audition?
A There were hundreds. Girls first, boys second. We took them in group after group. Then we —
Kenny, Travis Payne and casting — went through the elimination process.
Q Who was supposed to be singing in this show? Was Michael Jackson supposed to be singing in this
show?
A Yes.
Q Was anyone else supposed to be singing in this show?
A No.
Q So this was going to be a Michael Jackson show called, This Is It?
A Yes.
Q What were you going to do in the show?
A I was going to be performing. Just background on Earth Song.
Q Did you meet again with Mr. Jackson?
A Yes. He came to one of the final dancer auditions, we were finalizing and he was there.
Q Did you see him any other time during auditions?
A No I didn’t.
Q How did he look then?
A He was very thin.
Q Were you concerned at that time about his physical condition?
A No.
Q What is Center Staging?
A It’s a music space in Burbank where bands go to rehearse. We were through for rehearsals for
band and dancers. It was our prep space.
Q Was there a calendar, a schedule when you were supposed to rehearse?
A Yes.
(Panish shows exhibit of This Is It rehearsal calendar of April/May/June 2009)
Q What are the various entries put on the calendar? Who made the schedule?
A What days we were at rehearsals. Kenny always made the schedule. We were at Center Staging in
May. We moved to the Forum in June.
Q So according to the calendar, up until the 20th of June, rehearsals were at the Forum?
A Yes.
Q Then it looks like June 22nd to the 30th, rehearsals were at the Staples Center?
A Yes.
Q The schedule says you continued to have Sundays off, along with few other days off, is that right?
A Yes.
Q How often did you see Mr. Jackson at Center Staging in April?
A I saw him not everyday, but I saw him a bit – quite a bit. He was part of production meetings and
he was working with the band in rehearsal, singing.
Q Did you see Mr. Jackson at Center Staging in May?
A Yes. Production meetings with Kenny and working with the band, which included Michael Bearden,
musicians, background singers, sometimes Travis Payne. He worked with Travis Payne at the house were
he was staying, too.
Q During this time did you speak with Mr. Jackson.
A Yes. For moments. Not conversations. One moment: Wardrobe had come in and was showing
Michael sketches. Right in the middle of that, Michael just looked at me and said, “You lost weight. What
are you doing?” I told him I try to work out every day. He told me, “You know, you need to try and keep
going.” So I had these moments with him.
Q Was he friendly to you, Mr. Jackson? How did he treat other people?
A Yes. He was VERY friendly. Very kind.
Q At this time, did it appear to you he was excited about doing This Is It?
A Yes. Another moment I had with him: He realized he remembered my face, from making Smooth
Criminal video. At that point, he was very excited to do the show — excited to show his kids. And finally
show them who he was, and what he was all about.
Q So now we’re in April-May. How was Michael’s physical condition at that time?
A My observation — he was thin.
Q Was there a time when you received information that he was sore or that –
AEG: Objection. Hearsay.
Judge: Overruled.
A I was told, at one point, while we were at Center Staging –
AEG: Objection. Hearsay.
Q Well just tell us what is your understanding of what you heard? Actually, it isn’t hearsay. The
person who said it is another employee of AEG.
AEG: Objection. Lack of foundation.
Q Who told you this?
A Travis Payne.
Q Who is Travis Payne? Who was he working for?
A Travis Payne was choreographer of the show and he was hired by AEG.
(Sidebar)
Q So what did Mr. Payne tell you?
A Travis shared with me that Michael was complaining of his body being sore. As dancers we knew
that, as a dancer you have to stretch after you reach a certain age in order to dance. To move at a
certain level. I told Travis he should bring in a bar so Michael could stretch. Also palates, which is another
form of stretching and preparing to dance.
Q Did you go to Mr. Ortega and tell him there are other things for Michael’s physical condition that he
needed — such as a nutritionist?
AEG: Objection. Hearsay.
Judge: Overruled.
A No.
Q Did you ever notice Mr. Jackson had a problem with his shoes.
A Yes. Michael was at Center Staging. We were in a room and I happened to notice the bottom of
Michael’s shoes had holes in them. I went to Brother Michael, that was Michael’s assistant, and I told him
Michael needs new shoes. He can’t be rehearsing with holes on the bottom of his shoes.
Q Did you get him new shoes?
A Yes.
Q Was there video being made at the time?
A There was footage being filmed of — some of Michael working with the band.
Q Was there a song list made for the show?
A Yes. With Michael’s extensive catalog of songs, he would go through and, mostly what he fans
would want to hear. And there’s a lot of songs. It was very difficult to choose.
Q Mr. Ortega was the director. And he was in charge of the entire This Is It show, the production and
direction of the show which was being promoted by AEG?
A Yes.
Q Mr. Ortega was the one running the day to day preparations and operations of this show?
A Yes.
Q And he reported directly to whom?
A He reported to Paul Gongaware and Randy Phillips.
Q Who was making decisions at the rehearsals for the preparations for the show that was to be held
at the AEG arena in London and promoted by AEG? Who made all of those decisions everyday?
AEG: Objection. Lack of foundation.
Judge: Overruled.
A Kenny would relay to me the schedule that would change from day to day.
Q Who was ultimately the one responsible, whether it was at Center Staging or Staples Center for
everything on a day to day basis?
AEG: Same Objection.
Judge: Overruled.
A I would get all my information from Kenny.
Q Was there anyone telling Kenny what to do there?
AEG: Objection. Lack of foundation.
Judge: Overruled.
A I didn’t see anyone tell Kenny what to do, no.
Q Did Mr. Gongaware and Mr. Phillips show up at the rehearsals?
A Mr. Gongaware was at a lot of the rehearsals. Yes. I would see him a lot during the process. I didn’t
see Randy Phillips as much. No.
Q Then Mr. Ortega would report directly to Mr. Gongaware?
AEG: Objection. Lack of foundation.
Judge: Overruled
A Yes.
Q And you would see emails. Mr. Gongaware would be on the emails. Mr. Ortega would be on the
emails. Mr. Payne would be on the emails.
A Yes.
Q At the beginning of Michael’s involvement, how would you describe he health?
A I always felt he was thin, from the beginning.
Q Was food brought to the production?
A Yes. I was having catering come in and provide food for cast and crew.
Q Did you spend time with Mr. Jackson children in June?
A Yes. A couple of times in June. First week in June, the video content for the show was being filmed
in the mornings. Michael would bring his children. One day when we were shooting the Smooth Criminal
content, I got to hang out with the kids. It was pretty amazing. They say next to me. Paris had a purse,
and inside her purse — she told me not to tell her daddy — she had all of this candy in her purse, she
didn’t want her daddy to know. (laughs) In her purse she had these little framed pictures of her father. She
had a lot of them. Her purse was full of candy and pictures of her daddy. And she was showing me and
sharing with me all of her pictures.
Q Did you notice if the children were happy to watch there father.
A The children were really excited to be there. I showed them a picture I had of Michael and me from
the 1987 Smooth Criminal video shoot. Paris said, “That’s Daddy!” I said, “Yes, that’s your father.”
Q Did you spend time with the children and Michael Jackson outside of rehearsals?
A Once. June 7th. That was a Sunday. I got to go to the movies with Michael and the kids. Kenny
and Travis were there. We saw the Disney film, “Up” at the El Captain Theater.
Q Did you just buy the tickets at the theater and go in?
A No. It was a covert operation. We were in a private room. We got our popcorn and drinks. They
let us into the theater after the general public were seated. So no one knew Michael was there.
Q Did you have a good time?
A Yes.
Q Did you observe Mr. Jackson’s relationship with his children?
A I would see the children just looking at him. They loved him. They loved their daddy.
Q Regarding the rehearsals, did Mr. Jackson have to attend rehearsals?
A Yes. Whenever he was on the schedule to come to rehearsal, he was supposed to be at rehearsal.
Q Can’t he just do that on his own or is there a reason he needs to come to rehearse?
A He needed to come to rehearsal to be incorporated into the show with the dancers.
Q Did Mr. Ortega ever have any concern about Michael’s participation at rehearsals?
A Yes. He was frustrated. We had a conversation about it.
Q Were there emails reflecting that concern?
A Yes.
(Panish shows email exhibit)
Q Is this an email forwarded to you by Mr. Ortega?
A Yes.
Q Actually it’s CC’d to Kenny Ortega. It’s from Travis Payne to Brother Michael — MJ’s assistant. It
says: Brother Michael. We pray that all it well. God God God. If MJ is available, we’d love him to attend
tomorrow’s rehearsal. Kind regards, Travis
Was this sent during the time Mr. Ortega was expressing concerns about Michael attending rehearsals?
A Yes.
Q Six days of rehearsals began June 1st at the Forum. Did Michael attend any of these?
A He came on the 6th. Saturday.
Q How about the 1st, 2nd, 3rd, 4th or 5th?
A He didn’t attend at those times.
Q What time were rehearsals?
A We started early in the morning until about 6 or 7pm. We were shooting video content in the
mornings at Culver City Studios, and Michael would need to be there.
Q Were you concerned about Michael not getting to rehearsals? Did you communicate that with
anyone?
A Yes. Yes.
Q Who?
A Kenny Ortega. I sent an email to him. I was concerned and worried.
(Panish exhibits email)
Q At 11am, you sent this to Kenny Ortega, the one in charge, expressing your concern. It says: I left
work last night very sad and upset because I know this can not fail. Kenny, I know how to help him. I
know what needs to be said to him. Please let me help you get him back into the magical light.
What did you mean by that?
11.05.13 Alif Sankey |
teammichaeljackson.com/archives/8315 12/21
A I meant I wanted to encourage him. Reminding him to believe in himself. Reminding him that we all
believe in him. That he could do this. And help him get physically — his body able to do this. The email
when I wrote it, came from a very deep, personal place.
Q Did you think Mr. Jackson thought it was important that he do this tour?
A Yes. I mean, it was important for him.
Q Did Mr. Ortega ever respond in writing to this email?
A No, he did not.
(afternoon break)
Afternoon Session May 8 2009
Q. At break we were discussing that June 14 email at that time were you concerned about Mr. Jackson’s
physical and emotional health.
A. Yes
Q. Did anyone mention to you that Mr. Jackson was taking prescription medication at that time?
A. No
Q. Did you learn that there was going to be a meeting with Mr. Ortega and others with Mr. Jackson?
A. Yes
Q. Did you discuss that meeting with Mr. Ortega? (just yes or no)
A. Yes
Q. Did you have an understanding of what was going to occur at that meeting?
A. Yes
Q. What was your understanding?
*AEG Objection hearsay; Judge overruled, AEG says sidebar*
A. My understanding of the meeting is that there was to be talks about getting Michael to rehearsals at this
time.
Q. At this time when you spoke to Mr. Ortega was Mr. Ortega frustrated about Mr. Jackson not attending
rehearsals.
A. He was frustrated about it, yes.
Q. Where you at this time concerned about Mr. Jackson
A. I was concerned at this point about Michael, yes.
Q. Did you observe whether Mr. Jackson was nervous or erratic
A. I didn’t notice that, I just noticed that he was real thin.
Q. where you concerned about his show being able to meet the timeline for the practices
A. Not at this time
Q. Did you become concerned later on?
A. Yes
Q. Do you know when that meeting was that Mr. Ortega had, did he ever tell you about that
A. The meeting was during the first week at the forum
Q. Let’s look at the calendar, the first week at the forum was in June
A. Yes
Q. That first week started on June second
A. No it started Monday, Monday June First
Q. Was Mr. Jackson coming to rehearsal that week?
A. He was attending video content production of the show at Culver City Studios
When was the first time he showed up at the forum and he actually did rehearsal
That would have been Friday the 5 of June
Q. And to your understanding he showed up after the meeting Mr. Ortega had with Mr. Jackson
That he showed up after the meeting with Mr. Ortega
And to your understanding who went to the meeting
My understanding was that it was Kenny Paul and Randy
So it was Paul Gongaware Randy Phillips and Kenny Ortega
Correct
Did you know where that meeting was held?
At his house at Michael’s house
And when Mr. Kenny came back to he feel like he was going to get more control of Mr. Jackson coming to
rehearsal
Aeg objection speculation, overruled
Kenny had said to me that Michael would be showing up for rehearsals
And what happened from then on
A. He showed up and was in rehearsals, he did Billie Jean and Man in the Mirror
Q. And at that time did you feel better being able to do this
A. Yes
*A clip is played of Billie Jean from This Is It, rehearsal footage*
Q. Who was in that meeting?
That would be Travis Payne on the stage and one of the back singers
Ok let’s go a little more so Mr. Panish starts the clips again
MS. Sankey: that’s Kenny Ortega on the stage
Mr Panish: Says go back a little more on the video
Q. And you were there?
A. Yes I’m in red
Q. Ok so which one is Mr. Ortega
A. He’s off camera right now, alright this is Michael, Michael Bearden is on stage
Q. Who is this gentlemen in the big orange and the shorts with the muscle t shirt?
A. That would be Travis and this is Michael Bearden, Michael’s musical director
Q. So tell us what they’re doing here?
A. They’re talking about Billie Jean and how it would go for the show. Kenny is on the stage this point too.
Telling Michael where he would be standing, where the stool would go and the suitcase with his hat. All this
is planning for the rehearsal.
Q. And what do you call this
A. I would call this staging
Q. And what’s staging
A. Staging means directions of where a person would be
*Billie jean clip from this is it is played*
Q. What he (MJ) is doing, is that the speed in which he would do at a regular performance
A. No. He was doing what is called dance turn marking, which is marking the routine, he wasn’t doing it full
out, at full capacity, he was just marking.
Q. What about half speed have you heard of that, half speed quarter speed, what speed was he(MJ) that
day?
A. He(MJ) was half speed
Q. So getting the moves down before he goes to full speed
A. He was getting a feel for the stage and feel for the moves
Q. Did he ever go at full speed that day?
A. No
Q. So he was doing what you call marking at 50%, so how did he do in that regard
A. At this time he started and we were excited to see him continue watch him do the whole song
Q. So did that make you feel better at that time?

A. It was pretty exciting, it was really exciting to see him do it.
Q. And how about the next week June 8 thru the 11th, was Mr. Jackson coming to rehearsal then
A. Is it ok if I see the calendar?
Panish enters schedule into evidence and says this is the week ending of June 10 11th
A. He was present during that time frame around the 10 and the 11th
Q. Was he coming on time
A. I don’t know
Q. Did he do the same type of markings on some days or what did he do
A. He never did a full on run, he did enough to do the work and bring in the quality, but he was never at
what we call full performance level.
Q. How was his rehearsals, did he come on the 12
A. No
Q. Did he come on the 13 , Saturday?
A. I don’t remember
Q. Ok, during one of those rehearsal that week, he had a bad rehearsal
A. It was a bad rehearsal toward the end of the week
Q. Did he come the day after the bad rehearsal?
A. He came the beginning of the following week uh the 16 it’s vague
Panish shows exhibit 25412 to Ms. Sankey
Let’s go to the bottom and this was sent by Travis Payne, Ms. Sankey is shown an email that reads
“Brother Michael called to say that MJ is taking a doctor ordered sick day and I ask him to call
Alif as well.”
Panish to Sankey, does this refresh your recollection about whether or not MJ was present on the 13
and she responds yes.
Q. Did he come?
A. No he did not
Q. What happened, did rehearsal go forward anyway?
A. I remember it went forward
Q. Did Mr. Ortega act happy or sad, what was his reaction, how did feel about it when Mr. Jackson didn’t
come?
A. He was frustrated
Q. Did you have any concerns about Mr. Jackson?
A. Yes
Q. What were your concerns?
A. My major concern was his weight
Q. Why was that your concern?
A. He needed to gain weight, he needed to build weight and also mass, his muscle mass was real thin;
extremely thin
Q. You told us Mr. Ortega…was he always at rehearsal. Mr. Ortega did he always show up
A. Yes, Kenny Ortega is always at rehearsal
Q. Can rehearsal go on if he(Ortega) was not there?
A. It can yes
Q. So you don’t ever remember Kenny missing rehearsals
A. He never misses rehearsals
Q. How about Mr. Gongaware, you told us that he came but not everyday
A. Not every day, I didn’t see him everyday
Q. Did he come more days than he didn’t come?
A. I saw him a lot
Q. How about this gentleman, I think his name is Hoopdall (sp?) he is also goes by the name of known of
Buncy (sp?) (In court couldn’t make out the nickname)
A. Yes
Q. Who is he?
A. He’s our stage manager
Q. Did he come to rehearsals?
A. Yes
Q. Did the band come to rehearsals?
A. Yes
Q. Do you know anyone by the name of Tim Woolley?
A. Yes
Q. Who is he?
A. He was…He was…
Q. The most powerful person there
A. Yes
Q. And then Mr. Phillips, he came
A. I saw him
Q. Who came more Mr. Gongaware or Mr. Phillips?
A. Mr. Gongaware
Q. What’s a production meeting?
A. A production meeting entails all the components of the show to produce it. In this show it would have
been lighting, video content, budget at times. Stage graphics, practices… music wardrobe, hair make up,
costumes all of that.
Q. Did you see these meeting happen?
A. I saw quite a few production meetings happening
Q. Who generally joined?
A. Paul Gongaware would be there, Kenny…and whoever else needed to be there in that moment
Q. After the June 6 the day after the meeting with Mr. Jackson, did you ever see Dr. Murray at the
Forum
A. Yes
Q. Did you have any idea who he was?
A. No not until somebody told me who he was
Q. June 13 , is a Saturday right
A. Yes
Q. Is it the same day of the email, that I just showed you were Mr. Jackson had the doctor sick day
A. Yes
Q. Did you receive an email dated June 14 , regarding Michael’s health from Mr. Ortega?
A. I was copied on the email, yes
*Email is entered as evidence*
Q. Ok now June 14 at 3:21 and June 14 was a…
A. Sunday
Q. And there was no schedules that day, Sundays were off, right
A. Yes
So Mr. Ortega at 3:21 in the afternoon is writing an email. Ok this is actually the chain from Bother
Michael’s email sent June 13 saying that MJ wasn’t coming to rehearsal. Ortega responds on the 14 of
June at 3:21 by writing to Paul Gongaware
Q. And you were copied on this:
A. Yes
“Are you aware that MJ’s doctor didn’t permit him to attend rehearsal?? Are Randy and frank
aware of this??
Q. And Randy Being Mr. Phillips and Frank being Mr. Dileo
A. Yes
Panish continues to read:
“Are Randy and frank aware of this?? Please have them stay on top of his health situation.
Personally, I feel he needs a top nutritionist and physical therapist working with him on a
regular basis.”
Q. Now is this consistent with the concerns you were expressing and discussing with Mr. Gongaware
around this time period?
*AEG upset about the phrasing wants rephrase, Panish ok I will*
Q. Is this email consistent with what you were observing?
A. Yes
Q. Is this consistent with what you and Mr. Ortega had been discussing
Yes
Do you believe that Mr. Ortega based on what it’s in this email, had the same concerns that you did?
Yes
And this says that he was expressing these concerns to Mr. Gongaware who is the promoter and producer
of the This Is It tour, correct
Yes
Then the next email that night 7:29pm. Your honor I’m sorry going forward too far. Ok wait June 14 Mr.
Ortega writes at 3:21 and then 50 minutes later Mr. Gongaware right back. Sankey says correct.
*Mr. Panish starts to read the email. AEG says I’m just objecting to the reading of the email because Mr.
Panish just went out of turn. Judge asks was MS. Sankey copied on it and Panish says yes. Judge so why
don’t she read it. Panish says Ok fine why don’t you (Ms. Sankey) read for us what Mr. Gongaware says to
Mr. Ortega at 4:11 on a Sunday afternoon, about Mr. Jackson and Conrad Murray.
Ms. Sankey begins to read the email. “Frank and I have discussed it already and have requesting a
face to face meeting with the doctor hopefully Monday. We want to remind him that it is AEG
not MJ who is paying his salary. We want him to understand what is expected of him. We have
been vouching for him so far. Paul G”
Q. So you was cc on an email where he (Dr. Murray) canceled a practice and Paul Gongaware & Frank
Dileo wanted to have a face to face with the doctor because of it, is that your understanding
A. Yes
Q. What did this email mean to you when it was sent on Sunday at 4:11 when this was sent out by Paul
Gongaware the man in charge of everything, what did it mean to you, tell us please?
A. It meant to me that Dr. Murray was definitely on board as Michael’s doctor and from my interpretation
of this email, is that he was being paid by AEG. And Kenny was voicing his concerns and this is what Paul
answered back to him.
Q. And did you have an understanding what Paul meant when says that we want to remind him to
understand what is expected of him
*AEG objection speculating as to what Paul meant, Judge sustained it’s her understanding*
A. I understand that the doctor was on board and that AEG was paying him
Q. And as far as what was expected of him do you have an understanding of what Mr. Gongaware’s
message he was trying to deliver?
A. That said to me that doctor knew, he knew what to do to treat Michael
Q. And did you have the understanding that Michael was to go to practice or not go to practice
*AEG objects speculation. Panish, it her understanding, Judge Rephrase*
Q. Did you have an understanding at this time of whether they wanted Michael to come to rehearsal or
not come to rehearsal?
A. Everybody wanted Michael to come to rehearsal
Q. And did Mr. Gongaware not care and was like go to the beach and come to rehearsal when you want to
or did he want Mr. Jackson to com rehearsal all the time.
*AEG objection recommentive, Judge sustained*
Q. Counsel told the jury in their opening statement, that Michael Jackson did not have to be at rehearsals,
is that a true or untrue statement
A. Michael Jackson needed to be at rehearsal and was on the schedule for rehearsals. Which is definitely
most of the time we had him on schedule.
Q. Was Mr. Ortega happy that Mr. Jackson didn’t come or was he unhappy that he didn’t come to
rehearsal?
A. He was frustrated every time Michael didn’t show up to rehearsal.
Q. What did you think, did you think this was normal practice in the concert business that these types of
emails were sent. Were they surprising, better yet, what were your thoughts about the tone of the emails?
*AEG objects lacks foundation, judge sustains*
Q. Have you ever seen an email like this before, in anything you have ever done in the entertainment
business?
A. No
Q. Where you worried about Mr. Jackson at that time
A. Yes
Panish shows Sankey another email from Kenny Ortega.
Q. Is this Mr. Ortega’s email in response to the email that we just went thru?
A. Yes
Q. And this is then 3 hrs. later Mr. Ortega than replies back to the email that Mr. Gongaware replied to still
on Sunday June 14
I don’t want to read it as it will just be objected to, so why don’t you read for us the first few sentences
please.
“Paul, MJ did not have a good day and he didn’t show on Saturday. I realize that he is up
against a lot. I have sympathy for what he has been thru. We must do all we can, all that we
can as a team, to stay on top of his needs every day. He requires more attention and
management. As I mentioned I truly believe he needs nourishment guidance and physical
therapy massage for his fatigued muscles and injury. He is not in great physical shape, I
believe he is hurting. He is slow at grasping all the work. We have 20 days, we can’t let him slip
I am doing all that I can every day to build up his confidence and to create a schedule that will
help him and ready him to arrive us at our goal.”
Q. Do you agree with this part of what Mr. Ortega Wrote?
A. Yes
Q. Do you believe that Mr. Jackson was slow in grasping all of the work?
A. Yes
Q. Where you concerned
A. Yes
Q. Was Mr. Ortega Concerned?
A. Yes
Q. Then when it says, to create a schedule that will help to ready him to arrive us at our goal; do you
know what he meant by goal
A. Yes
Q. And what was that
A. Our goal was to get the show up and running at full speed before we left
Q. Every time he (MJ) delays or cancels it chisels away at the possibility of getting the show up and
running
A. Yes
Q. It says, do you know about Travis, having to come to the house; what does that mean?
A. Yes it means Travis would go to Michael’s house and work with him one on one
Q. In other words he wasn’t at the rehearsal with everyone else
A. Yes
Q. Then it says he must take care of himself so that he can meet the schedule or there is going to be
consequences, do you know that means
A. It meant that he needed to take care, get healthy, get in shape, or there wouldn’t be a show basically
Q. How were the rehearsals the next week, I think that was the 15 thru the 20
A. Can I see the calendar and I can tell you?
*Panish reintroduces the schedule as evidence*
Q. The 15 thru the 20 is after that email was sent
A. Yes
Q. On the 15 and the 16 what was planned on those days
A. It was planned… actually it was one of those days when Michael came in and Kenny wanted to show
Michael the whole show from top to bottom. And Travis was standing in as Michael, doing all his parts. This
was to show him, give him visuals of how the show would run.
Q. After that what was the plan for the next two days after this
A. We was to continue rehearsals and Michael was to come.
Q. At some time was Michael dressing differently
A. He was wearing leathers
Q. Describe that please
A. He was cold and he would tell me that he was cold and a couple of times that he was cold, he would
have layers of clothing on
Q. Did he wear gloves?
A. He did wear gloves on that the day that we all sat for the run thru and his hands were cold he was just
sitting there watching the show
Q. Was it cold in the forum?
A. We had a light and a lot of lighting and the light heats up the room
Q. What was he wearing when he showed up, was it a t-shirt or was it layers on that night of the 19 ,
what did you observe
A. Michael was not dressed necessarily for rehearsal, but there was a concert fitting and it was the last
fitting. I was outside of Kenny’s office and Travis Payne and Michael Bush was the dressing room with
Michael and after about 30 minutes Travis comes and informed me that they had to take everything back
*AEG objects to Sankey speaking about what Travis Payne said, says it hearsay Panish says that Payne
will testify and based on his deposition he will say what Ms. Sankey is saying in regards to the conversation
after the last show fitting, side bar in the judge’s chambers. Sankey is sitting on the stand, jury still present
waiting for judge and plaintiff to return*
Q. Can we go back to that meeting that you had where you and Mr. Ortega that night, where you and
Mr. Ortegh crying that night
A. Yes
Q. Why were you two crying?
A. Mr. Ortega sent Michael home that night after the fitting, Michael wasn’t looking good. And he shared
with me in his office after he sent Michael home
Now hold on a second, why were you crying, why were you and Mr. Ortega crying weeping together on
the night of the 19 . I want you to explain to us what information was shared between you two that had
you weeping
A. Kenny had told me that night when he was with Michael and he was rubbing his feet that Michael told
him that he heard God speaking to him, he heard God speaking to him
Why were you crying?
Q. Where you and Mr. Ortega concerned about Mr. Jackson’s health and physical condition on the night
of June 19 2009
A. Yes I was very concerned that night
Q. What did you do, did you do anything else that night, besides crying to Mr. Ortega and discussing how
upset you were?
A. I left the forum that night and on my home when I was in my car, I pulled over and called Kenny and
that was around 1… 1:30 in the morning
Q. Is it normal for you to call Mr. Ortega that time of morning?
A. No
Q. Why was it that you called Mr. Ortega that night of June 19 I guess it would be June 20 now as it
1…1:30 in the morning
A. I had a very strong feeling that Michael was dying.
Q. Did you tell that to Mr. Ortega?
A. Yes
Q. How was the tone of your conversation, how did you sound when you called Mr. Ortega? Was your
voice slow medium high, how was your pitch? How did you sound when you called Mr. Ortega at 1…1:30
in the morning on June 20 2009?
A. I was very upset and I was screaming into the phone
Q. Did you tell Mr. Ortega that you thought something should be done with Mr. Jackson?
A. Yes
Q. What did you say?
A. I said he needs to be taken to the hospital now
Q. And what did Mr. Ortega say to you
*AEG objection speculation, Judge overruled.*
A. He kept listening to me as I was balling. I kept saying that Michael was dying, he is going to die. He needs
to go to a hospital. Please do something why won’t anyone do something please please…. please do
something. I asked why someone isn’t doing anything
Q. And what did he say
A. He said that he would go over there. And I said promise promise me that you will go over there and he
promised and we hung up and I went home.
Panish says to the court, and what did Mr. Ortega do that night, he emailed Mr. Phillips to explaining to
your(Sankey) concerns
Panish presents an email from Kenny Ortega
AEG objects, Panish says it goes in line with what she (Sankey) just said.
Q. Did you have a lot of email conversation with Mr. Ortega?
A. Yes
Q. Was it common for Mr. Ortega to send emails at 2:09 in the morning?
A. No
Q. Did you see Mr. Ortega on June 20 , June 20 is now Saturday?
A. Yes
Q. Did you have rehearsal that day?
A. We had rehearsal that day
Q. Did you see Mr. Ortega?
A. No
Q. Did you see changes in Michael Jackson’s body, physical change in his body emotional state and
wellbeing over the two months you worked with him?
A. Yes
Q. Did you discuss those changes with Mr. Ortega?
A. Yes
Q. Did Mr. Ortega say he was going to do something about it?
A. Yes
Q. Did Mr. Ortega try to relay those concerns to AEG?
A. Yes
Q. Did you see any action taken by anyone at AEG in regards to your concerns that you expressed to Mr.
Ortega?
A. No
Q. Where you concerned that nothing was happening?
A. Yes
Q. June 20 Saturday, did Mr. Ortega and you have a conversation?
A. Yes
Q. Did you learn that that Mr. Ortega was going to have a meeting at Michael’s house that night?
A. Yes
Q. And did you learn who was going to the meeting
A. Yes, Kenny had said that he and Randy Phillips were going to the house
Panish wants to play a bit of Randy Phillips’ deposition
*Aeg objects and says that its hearsay and then says that they would like the chance to review the
deposition and object to portions of it. They want Panish to finish with Sankey and stating that Panish has
gone over the allotted time and would like the opportunity to cross. Panish says that he has not had
Sankey on the stand for an hour and a half due to multi-objections and sidebars. The rules says that he
can pull the deposition any time he wants and reads portions of it. He reminds the judge and AEG counsel
that he is within his agreed upon rights. Aeg wants the video out of the presence of the witness. Another
side bar*
Break
Q. June 22 was the next day of rehearsal after the 20
A. Yes, we were moving and had moved completely into the Staples Center
Q. And why we you there
A. The center became available after the basketball season
Q. How long were you supposed to be there?
A. We were scheduled to be there thru the last day of June or two days after
Q. Was Mr. Jackson there on the 22
A. He did not come that day
Panish: In your deposition you said he came
Sankey: I was mistaken it had been a long while
Q. So he (MJ) wasn’t there on the 22
A. No he wasn’t there
Q. Now on the 23 was he there?
A. Yes
Q. How did you remember?
A. He came… he jumped in, he did a lot of the show and he was in great spirits. It was exciting, we were
excited to have him there.
Q. Now when he was there was he doing anything other than marking?
A. He still wasn’t strong or at a full production ready caliber… but he was definitely doing the work and
going a little more full out than usual
Q. Was Michael there on the 24
A. Yes he was there
Q. How was Michael dressed for rehearsal, was he dressed normally?
A. When I saw Michael that evening at the Staples Center he was layers and wrapped in a blanket
Q. Is it normal to see entertainers wrapped in a blanket?
A. No not like that
*A picture is then shown of the Staples Center*
Q. So you just walked passed Mr. Jackson
Q. How did he (MJ) look that day
A. He didn’t look good, I asked him if he was cold and he said yes
Q. Did he do songs that night?
A. He rehearsed and did two songs
Q. Is it normal to see performers with blankets wrapped around them like this?
A. No not like this
Q. And he still appeared thin, skinny
A. Yes
Q. What happened the next day?
A. We were all at the Staple Center for rehearsal
Q. Did Mr. Jackson come to practice the next day?
A. No
Q. Were you concerned that he didn’t come to practice?
A. Uh…when I got there I was told that he was in the hospital
Q. And how did that make you feel
A. Very concerned
A. Then Kenny was called outside to receive a phone call from Mr. Randy Phillips and he was then told that
Michael had died

Q. And what did Mr. Ortega do
A. Kenny collapsed
Q. And what did you do?
A. I told Mr. Woodall (sp?) to get Kenny up, get Kenny up and out of the room
Q. And then what happened
A. We went to out back offices and we sat there and just cried and cried and cried a lot and got Kenny
together to go and talk to everyone and make the announcement that Michael had died.
Another 20 mins to add, have to get notes from 4th person. sorry, but we rely on many
sources to bring you complete transcripts of the day
.

http://teammichaeljackson.com/archives/8315

[manu29]

RICHARD SENNEFF
(Paramedic with the Los Angeles Fire Department, LAFD)
PLAINTIFF’S WITNESS.

DIRECT EXAMINATION BY BRIAN PANISH.
EMPLOYED BY CITY OF LOS ANGELES FIRE DEPARTMENT. 28 YEARS. PREVIOUS WORK HISTORY: EMT
– EMERGENCY MEDICAL TECHNICIAN FOR MEDIVAC AMBULANCE IN PASADENA. 1982, A PARAMEDIC
FOR MERCY(?) AMBULANCE IN ONTARIO. JOINED LOS ANGELES FIRE DEPARTMENT IN 1980.
THE DIFFERENCE BETWEEN EMT AND PARAMEDIC: EMT – TRAINED IN BASIC FIRST AID, CPR SKILLS,
DEFIBRILLATION.
PARAMEDIC – ADDITIONAL 1000 HOURS TRAINING THROUGH A 6-MONTH PROGRAM: 2-MONTHS IN
CLASSROOM, 6-WEEKS IN EMERGENCY ROOM ICU, 2 TO 3-MONTHS ON WORKING PARAMEDIC UNIT.
WORKING PARAMEDICS USE A DEFIBRILLATOR, EKG MACHINE, ADVANCED AIRWAY, ADVANCED
CARDIAC LIFE SUPPORT, RESUSCITATION. THINGS RELATED TO TRAUMA, CARDIAC EMERGENCIES.
RA MEANS: RESCUE AMBULANCE. TO CAN CARRY SOMEONE IN THE VEHICLE.
DEFIBRILLATOR MEANS: BOX, IT REGISTERS A PATIENTS EKG – THE LITTLE BLIPS YOU SEE. IT ALSO
HAS PADDLES THAT CAN BE USED TO SHOCK THE PATIENT.
EKG MEANS: ELECTROCARDIOGRAPH MACHINE. RECORDS ELECTRICAL PATHWAYS TO HEART.
JURISDICTION OF THE CITY OF LOS ANGELES FIRE DEPARTMENT:
112 STATIONS. COVER EVERYWHERE FROM SAN PEDRO TO CHASTITY. SAN FERNANDO VALLEY,
PACIFIC PALLASADES, HOLLYWOOD — THE ENTIRE CITY OF LOS ANGELES.
THE BETWEEN COUNTY AND CITY FIRE DEPARTMENT:
COUNTY FIRE DEPARTMENT COVER CITY THAT CHOSE NOT TO HAVE THEIR OWN FIRE DEPARTMENT,
BUT RATHER CONTRACT. THEIR PARAMEDICS RIDE ON SQUADS, USE A PRIVATE AMBULANCE TO
TRANSPORT. CITY FIRE DEPARTMENT PARAMEDICS RIDE ON FIRE TRUCKS, BUT ALSO ON
AMBULANCES.
SENNEFF HAS WORKED OVER 25-YEARS WITH THE CITY OF LOS ANGELES FIRE DEPARTMENT.
AS A PARAMEDIC, SENNEFF RESPONDS TO 911 CALLS — PATIENT NOT BREATHING OR CHEST PAIN.
ALSO DELIVERING BABIES, CAR ACCIDENTS, ETC. IN 1992, HE RECEIVED FURTHER TRAINING TO
BECAME A FIREFIGHTER, AS WELL. HIS TITLE IS: FIREFIGHTER PARAMEDIC. HE’S DEALT WITH
FACTORY FIRES, HOME FIRES, BRUSH FIRES, TRASH FIRES, ETC.
SENNEFF IS CURRENTLY ASSIGNED AT THE FRANK HOTCHKIN MEMORIAL TRAINING CENTER. DO ALL
THE TRAINING FOR THE FIREFIGHTERS FOR CITY OF LOS ANGELES. FIRE AND MEDICAL TRAINING.
EVERY FIREFIGHTER IS AN EMT. HE TEACHES RE-CERTIFICATION COURSES TO THEM. HE’S BEEN AT
THAT LOCATION FOR 2 ½ YEARS.
PRIOR TO THAT SENNEFF WAS AT FIRE STATION 71, IN BEL AIR. WHERE HE WORKED AS A
PARAMEDIC.
ON JUNE 25TH 2009, HE WAS ASSIGNED AT FIRE STATION 71, IN BEL AIR.
ON JUNE 25TH 2009, SENNEFF REMEMBERS RESPONDING TO THE LOCATION OF A POTENTIAL
FATALITY. A PATIENT NOT BREATHING.
PANISH REFERS TO A BINDER SENNEFF BROUGHT WITH HIM TO COURT TODAY. THE BINDER HAS
DOCUMENTATION AS A MATTER OF BUSINESS OF THE LOS ANGELES FIRE DEPARTMENT, OF THE TIME
THE CALL WAS RECEIVED.
PANISH PROJECTS THE DOCUMENT ON SCREEN FOR JURY TO VIEW. ASKS SENNEFF TO WALK US
THROUGH THE INFORMATION IN THE BINDER.
SENNEFF READS THE DETAILS OF THE RECORDED 911 CALL, TYPED BY THE DISPATCHER:
100 NORTH CAROLWOOD DRIVE. DATE: 6-25-09. 50-YEAR OLD MALE. CRA — CARDIAC ARREST.
CARDIAC ARREST IS WHEN YOUR HEART STOPS. CODE 9E1 — HIGH PRIORITY, NOT BREATHING AT
ALL. DISPATCH TIME: 12:22 PM.
THAT WAS ALL TYPED INFORMATION FROM DISPATCH. THERE IS ALSO HANDWRITTEN INFORMATION
IN SENNEFF’S HANDWRITING. HE EXPLAINS THAT HE TAKES NOTES ON THE SCENE.
OTHERS WHO RESPONDED TO THE CALL WITH SENNEFF:
HIS PARTNER THAT DAY, MARTIN BLOUNT — HE’S ALSO FIREFIGHTER/PARAMEDIC. DRIVER OF ENGINE
71, ENGINEER BRIGANDY. CAPTAIN OF THE ENGINE, JEFF WILLS. FIREFIGHTER BRETT HARRIN. AND
PARAMEDIC MARK GOODWIN.
THEY ARRIVED AT 100 NORTH CAROLWOOD AT 12:25 PM. WHEN SENNEFF GOT TO THE PATIENT, I
WROTE DOWN 12:26 PM. WHEN THEY GOT THERE, THERE WERE A LOT OF SECURITY PERSONNEL.
THEY WERE WAVING THEM THROUGH LARGE GATES.
WHEN SENNEFF AND HIS TEAM ARRIVED AT THE SCENE THEY GOT THEIR EQUIPMENT: GURNEY,
STARTER KIT, OXYGEN KIT, EKG MONITOR, DEFIBRILLATOR.
SENNEFF WAS THE FIRST PERSON TO ENTER THE HOME.
HE FOLLOWED SECURITY. GURNEY WASN’T GOING UP STAIRS FAST, SO HE GRABBED STARTER KIT
AND RAN UP STAIRS. THE REST OF HIS TEAM FOLLOWED HIM.
WHEN SENNEFF WENT INTO THE BEDROOM, HE SAW WHO HE LATER FOUND OUT WAS DR. MURRAY,
A SECURITY GUARD AND A PATIENT LAYING ON BED. MURRAY WAS ON FAR SIDE OF THE BED, NEAR
NIGHTSTAND. MURRAY AND THE SECURITY GUARD WERE MOVING THE PATIENT ONTO THE FLOOR.
SENNEFF SAYS DOING CPR ON A BED IS VERY INEFFICIENT. HE THOUGHT MAYBE THEY WERE MOVING
PATIENT ON FLOOR TO DO CPR.
SENNEFF WAS WEARING HIS FIREFIGHTER UNIFORM. CLEARLY RECOGNIZABLE AS FIREFIGHTER.
SENNEFF ASKED MURRAY IF PATIENT HAS A DNR — DO NOT RESUSCITATE ORDER. HE ASKED THAT
BECAUSE WHEN HE WALKED INTO ROOM AND SAW THE MEDICAL EQUIPMENT, HE THOUGHT IT WAS A
HOSPICE PATIENT.
PATIENT WAS WEARING PAJAMAS, WITH TOP UNBUTTONED. A SURGICAL CAP COVERING THE HEAD.
VERY PALE. VERY VERY UNDERWEIGHT. SENNEFF COULD SEE RIBS. THAT’S WHY HE THOUGHT THIS
WAS A HOSPICE PATIENT — SOMEONE CLOSE TO DEATH, SUCH AS WITH CANCER, HAVING COME
HOME TO DIE.
WHEN SENNEFF ASKED MURRAY ABOUT THE DO NOT RESUSCITATE ORDER, MURRAY ANSWERED “NO,
NO. THAT JUST HAPPENED.” HE’S SAYS MURRAY LOOKED PALE, SWEATY, FRANTIC. MURRAY TOLD
SENNEFF HE WAS A CARDIOLOGIST. SENNEFF SAYS HE’S BEEN DOING THIS FOR MANY YEARS, BUT
EVEN IN BEVERLY HILLS IT’S UNUSUAL FOR PERSONAL DOCTOR TO BE AT THE HOUSE.
SENNEFF AND BRETT HARRIN MOVED TO SIDE OF BED WHERE PATIENT WAS. SMALL AREA. NO ROOM
TO WORK. SO THEY MOVED PATIENT TO FOOT OF BED.
SENNEFF SAW SOMETHING UNUSUAL IN THE ROOM: AN IV (INTRAVENOUS) BAG ON AN IV POLE, AND AN
OXYGEN TANK. ALSO MEDICATION BOTTLES ON NIGHTSTAND. THE PATIENT LOOKED UNDERWEIGHT.
LOOKED CHRONICALLY ILL.
INITIALLY SENNEFF DIDN’T KNOW WHO PATIENT WAS, BUT AS THE CALL PROGRESSED, SOMEONE
SAID MICHAEL JACKSON.
AS A PARAMEDIC ON THE SCENE, SENNEFF WAS TRYING TO GET INFORMATION SO HE COULD
PROPERLY TREAT THE PATIENT. HE ASKED MURRAY WHAT PATIENT’S MEDICAL HISTORY WAS.
MURRAY SAID: NOTHING. I‘M JUST TREATING HIM FOR DEHYDRATION AND EXHAUSTION, SINCE 16-
HOURS LAST NIGHT.
BASED ON SENNEFF’S 28 YEAR EXPERIENCE, WHAT HE SAW WAS NOT SOMEONE WITH DEHYDRATION
AND EXHAUSTION. DEHYDRATION AND EXHAUSTION IS RELATIVELY MILD. YOU REST, PUT SOME FLUID
BACK INTO YOU — A FEW IV BAGS. BUT YOU’RE NOT UNDERWEIGHT, PALE. IT LOOKED MUCH MORE
COMPLICATED.
HE TRIED TO FIND OUT IF MICHAEL JACKSON WAS ON ANY MEDICATION. ALL PART OF ASSESSING
PATIENT HISTORY. ACCORDING THE DR. MURRAY, NO HE WAS NOT. MURRAY NEVER MENTIONED
PROPOFOL.
SENNEFF WAS ON A CALL FOR CARDIAC ARREST. HE ASKED MURRAY: WHEN DID THIS HAPPEN.
MURRAY TOLD HIM: JUST NOW.
SENNEFF EXAMINED THE PATIENT. CHECKED PULSE, HEART, EYES. HE HAD NO PULSE. HIS EYES WERE
VERY DRY– THE PUPILS WERE FULLY DILATED. IT’S CALLED “FIXED AND DILATED.” WHEN YOUR
BODY’S HEART AND LIFE STOPS, YOUR EYES DON’T BLINK AND DRY OUT. IT’S A SIGN TIME HAD
ELAPSED BETWEEN WHEN PATIENT HAD CARDIAC ARRESTED. IT DIDN’T MAKE SENSE TO SENNEFF OR
THE OTHER PARAMEDICS ON HIS TEAM.
THE PATIENT’S SKIN WAS VERY COOL TO THE TOUCH. AGAIN, INDICATING THAT TIME HAD ELAPSED. A
LOT LONGER THAN MURRAY HAD ELUDED. SENNEFF SAYS HE THINKS LESS THAN AN HOUR, BUT THAT
IT TAKES LONG TIME FOR BODY TO GET COLD. PATIENT’S BODY WAS PALE WHITE. THE HANDS, FEET
AND LIPS WERE TINGED BLUE. THIS IS CALLED CYANOSIS — CAUSED BY STOP BREATHING. BY TIME
HANDS AND FEET TURN BLUE, PERSON HAS BEEN DEAD A LONG TIME.
AS SOON AS SENNEFF AND THE OTHER PARAMEDICS MOVED MICHAEL TO THE FLOOR, THEY
IMMEDIATELY DID CHEST COMPRESSIONS, PLACED BREATHING BAG TO HIS FACE, PATCHED
ELECTRODES ON HIM TO CHECK HIS HEART, QUESTIONED DOCTOR MURRAY, PLACED TUBE INTO
LUNGS, PLACED CARDIAC DRUGS INTO MICHAEL VIA IV. THEY TRIED AND FAILED TO PLACE IV IN BOTH
ARMS, BECAUSE WHEN SOMEONE IS FLAT-LINE WITH NO BLOOD PRESSURE, YOU CAN’T INSERT AN IV.
THEY HAD TO INSERT IT INTO MICHAEL’S NECK. WHILE THEY WERE DOING THIS, MURRAY WAS GIVING
THEM ORDERS. MURRAY TOOK DRUGS FROM THEIR BOX AND INJECTED MICHAEL WITH ADDITIONAL
EPINEPHRINE AND ATROPINE.
MURRAY SAID HE FOUND A PULSE. SENNEFF AND HIS TEAM NEVER FOUND A PULSE.
SENNEFF HAD ONGOING COMMUNICATION WITH THE HOSPITAL VIA CELL PHONE. AFTER 20-25
MINUTES AND SEVERAL FUTILE ATTEMPTS AT RESUSCITATION THE HOSPITAL SAID THEY COULD STOP
AND “CALL IT.” MURRAY SAID: NO. THEY TOLD MURRAY AS THE PERSONAL DOCTOR HE HAD THE
OVERRIDE OF THEM, BUT HE HAD TO GO WITH THEM IN AMBULANCE TO HOSPITAL. SENNEFF AND THE
OTHER PARAMEDICS STRAPPED MICHAEL ON THE GURNEY, STILL VENTILATING AND DOING CPR.
WHEN SENNEFF WENT BACK UPSTAIRS TO COLLECT EQUIPMENT HE SAW MURRAY ON SIDE OF BED
NEAR NIGHTSTAND, HOLDING A WHITE PLASTIC BAG AND PICKING THINGS UP FROM FLOOR. SENNEFF
COULDN’T SEE WHAT. MURRAY LOOKED SURPRISED WHEN HE SAW SENNEFF. HE JUST FROZE LIKE A
DEER IN HEADLIGHTS.
WHEN THEY TRIED TO LEAVE FOR THE HOSPITAL IT WAS VERY DIFFICULT TO LEAVE. SENNEFF
DESCRIBES IT AS UNBELIEVABLE. PEOPLE EVERYWHERE, IN THE WAY WITH CAMERAS. CAMERAS
PUSHING UP INTO THE AMBULANCE WINDOWS. PEOPLE ON A TOUR BUS TAKING PICTURES. SENNEFF
SAYS HE’S NEVER SEEN ANYTHING LIKE IT.
IN THE AMBULANCE, WHILE THE PARAMEDICS WERE SEATED AROUND MICHAEL ON THE GURNEY,
MURRAY WAS STANDING UP IN BACK OF AMBULANCE TALKING ON CELL PHONE. SENNEFF COULDN’T
HEAR ANYTHING SAID.
FROM SENNEFF HANDWRITTEN NOTES:
PATIENT GLUCOSE READING, CHECKING FOR LOW BLOOD SUGAR WHICH CAN CAUSE CARDIAC
ARREST.
EPINEPHRINE, A TYPE OF ADRENALINE WAS ADMINISTERED TO TRY AND SPEED UP THE HEART.
NOTATION ABOUT THORAZINE — MURRAY INDICATED THAT MICHAEL WAS ALLERGIC TO IT.
AFTER SENNEFF CALLED UCLA HOSPITAL, HE ADMINISTERED ATROPINE, AGAIN TO TRY AND SPEED UP
THE HEART.
LORAZEPAM — MURRAY INDICATED HE’D GIVEN MICHAEL JACKSON A LITTLE LORAZEPAM TO HELP HIM
SLEEP.
SODIUM BICARBONATE WAS ADMINISTERED TO REDUCE ACID — BECAUSE ACID BUILDS IN CELLS OF
SOMEONE WHO’S BEEN DOWN A WHILE, HINDERS THE HEART FROM WORKING.
CAPNOGRAPHY — MONITORING CARBON DIOXIDE (CO2) FOR WHEN THEY PUT A TUBE INTO PATIENT’S
LUNGS.
TIME PATIENT WAS TRANSPORTED TO HOSPITAL 13:07 (1:07 PM).
BELOW PATIENT IDENTIFICATION, SENNEFF WROTE: 50-YEAR OLD MALE FOUND SUPINE. CPR IN
PROGRESS BY PERSONAL DOCTOR, MURRAY. IV BY MURRAY IN LEFT LEG. NO BLOOD PRESSURE. NO
PULSE. NO RESPIRATION. EKG READING: FLAT-LINE.
ASKED BY PANISH: WAS THERE ANY INDICATION THAT DOCTOR MURRAY HAD TRIED TO ESTABLISH AN
AIRWAY OR ASSIST MICHAEL JACKSON IN BREATHING PRIOR TO YOUR ARRIVING? SENNEFF: NO, SIR.
SENNEFF AND HAD ONE MORE CALL THAT DAY. AN ELDERLY RUSSIAN WOMAN WHO HAD FAINTED IN
HER WEST L.A. APARTMENT. SHE’D HEARD THE NEWS THAT MICHAEL JACKSON HAD DIED AND SHE
FAINTED, HIT HER HEAD ON A TABLE. HER INJURIES WERE MINOR, BUT SHE WAS DEEPLY EMOTIONAL
ABOUT MICHAEL.
CROSS EXAMINATION BY AEG.
AEG ASKS ABOUT VERSED (GENERIC NAME: MIDAZOLAM) AND VALIUM (GENERIC NAME: DIAZEPAM).
SHE ASKS IF THEY ARE IN A CATEGORY OF DRUGS CALLED BENZODIAZEPINE. SENEFF SAYS YES. HE
EXPLAINS THAT THEY ARE ANTI-ANXIETY DRUGS, OFTEN CONFUSED WITH SLEEPING MEDICATION.
THEY JUST CALM YOU DOWN.
SHE ASKS ABOUT CPR. WANTS SENNEFF TO VERIFY IF IT’S BETTER TO DO CPR ON A HARD SURFACE
THAN ON A BED. AND THAT IF CPR IS DONE PROPERLY, RIBS GET BROKEN. HE CLARIFIES THAT IT’S
THE CARTILAGE AROUND THE RIBS WHICH BREAKS, NOT THE RIBS. SHE ASKS IF HE FELT MICHAEL’S
CARTILAGE BREAK. SENNEFF SAID HE WASN’T FIRST PARAMEDIC TO DO CPR ON THE SCENE.
AEG TELLS SENNEFF THAT WITH HIS TRAINING, HE MUST HAVE SEEN MANY DOCTORS PERFORM CPR
SUCCESSFULLY. HE EXPLAINS THAT DOCTORS ARE USUALLY THE GENERALS GIVING THE ORDERS TO
THE PARAMEDICS. BUT THAT ON THE LESSER AMOUNT OF TIMES HE’S SEEN DOCTOR’S DO CPR, THEY
DO SUCCESSFULLY.
SHE ASKS ABOUT USING A DEFIBRILLATOR. HE SAYS MOST PATIENTS DON’T NEED A DEFIBRILLATOR.
SENNEFF ANSWERS AGAIN THAT HE AND HIS TEAM NEVER FOUND A PULSE, BELIEVED MICHAEL WAS
DEAD LONGER THAN MURRAY WAS SAYING, AND THAT WHAT MURRAY WAS TELLING THEM WAS NOT
ADDING UP RIGHT.
AEG ASKS WHETHER SENNEFF USUALLY ASKS ABOUT RECREATIONAL DRUG USE AS PART OF PATIENT
HISTORY, AND IF SO WHY. HE SAYS YES, BECAUSE PEOPLE TEND TO KEEP RECREATIONAL DRUG USE
SECRET, BUT SOME OF THEM THE PARAMEDICS CARRY ANTIDOTES FOR.
SHE ASKS WHETHER HE’S COME ACROSS MANY PEOPLE WHO’VE USED RECREATIONAL DRUGS AND
WHOSE FAMILIES DON’T KNOW ABOUT IT — WHETHER THAT‘S COMMON. AND WHETHER SOMETIMES
THOSE DRUGS ARE PRESCRIPTION DRUGS. HE SAYS YES.
AEG ASKS IF THAT’S BECAUSE “DRUG ADDICTS” WANT TO KEEP THEY’RE DRUG USE SECRET.
PANISH OBJECTS — FOUNDATION.
JUDGE SUSTAINS.
AEG CONTINUES TO TRY AND ASK THE SAME QUESTION.
PANISH CONTINUES TO OBJECT.
SHE ASKS SENNEFF WHEN HE’S DEALING WITH SOMEONE WHO’S OVERDOSED, IS IT COMMON THAT
THEIR FAMILY MEMBERS DIDN’T KNOW THEY WERE TAKING DRUGS. SENNEFF SAYS YES.
AEG ASKS ABOUT SCLEROTIC BEING THE REASON THE PARAMEDICS COULD NOT INSERT IV IN
MICHAEL’S ARM VEINS. SENNEFF HAD EXPLAINED ON DIRECT EXAMINATION THAT IT WAS DUE TO
COLLAPSED VEINS FROM LOSE OF BLOOD PRESSURE. SENNEFF EXPLAINS THAT SCLEROTIC IS SCAR
TISSUE IN VEINS MAKING THEM HARD. HE SAYS WHEN HE PUT THE IV IN MICHAEL’S JUGULAR VEIN IN
HIS NECK, HE DID NOT FIND SCLEROSIS.
SHE ASKS IF THE IV MURRAY HAD IN MICHAEL’S LEFT CALF WAS AN UNUSUAL AREA TO PUT IV. HE SAYS
HE’S SEEN IT, BUT IT’S UNUSUAL. SHE WANTS TO KNOW WHETHER IV’S ARE USUALLY PUT IN THE
ARMS, AND WHY. SENNEFF SAYS IT’S ACCESSIBLE. WHEN ASKED, HE SAYS HE’S NEVER PUT AN IV INTO
THAT AREA.
AEG ASKS WHY DID SENNEFF ALLOW MURRAY TO GO INTO PARAMEDIC BOX FOR DRUGS. SENNEFF
SAYS MURRAY WAS A CARDIOLOGIST AND IT SEEMED REASONABLE, AT THE TIME. SAID YES, MURRAY
TOLD HIM HE WAS MICHAEL JACKSON’S PERSONAL DOCTOR.
Typed by ToMJRespectIsDue
Cross Examination by AEG of FDNY Paramedic Senneff. Testimony resumes after Lunch break
Opens with the question of whether or not Conrad Murray identified himself as Michael’s doctor to EMS
(Like really AEG does whether he did or not in a moment such as that, does it make it so or give validity to
your false claims that he was Michael’s long term physician; which has been disproven in Plaintiff’ opening
statements) Senneff responds that Dr. Murray identifies himself by saying I am his cardiologist. This was
when Paramedic Senneff and his partner arrived on the scene, at first they had no clue that they were
responding to the Michael Jackson and this because they did not recognize him. Michael was found with a
surgical cap covering all his hair when the Paramedic arrived on the scene at about 12:30 noon. Senneff
was the first person in the bedroom where he found Murray and security director Albert Alverez moving
Michael from the bed to the floor. He had an IV attached to his leg from his right side where the IV stand
was at the right foot side of the bed. AEG attorney asks, if there was medical equipment in the room and
what the EMT saw when scanning the room upon entry.
Senneff saw several oxygen tanks, an IV stand with IV bag hanging from it and bottles of medication on
the nightstand and says that the room didn’t look like a mess. (Remember how everything looked after
the “CSI” peeps came thru? They totally botched and tainted the environment; we know now it was their
mess and not Michael’s) Senneff says that Michael looked pale, his extremities were blue and he was under
weight. Senneff further noted that Michael appeared to be dead to him on first sight and at the very lease
someone who been without oxygen for quite some time. The FDNY Paramedic thought at the he was
more than like a hospice patient that simply died at home. He was asked by AEG attorney if what Senneff
saw in terms of medical equipment in Michael’s bedroom was something he would normally see at home.
He said an IV stand yes, as this can be used for various things, but the oxygen tanks were off he doesn’t
see those in a home and was wondering what course of treatment they were being used for as he did not
see any nasal tubing or other breathing equipment.
On his medical report he wrote 150lbs as an estimate at the scene he assessed the height from Michael
lying down and wrote that he was about 5’9. Senneff goes on over a hundred calls a month and has
years of experience and education; enough so to determine height and weight as sometimes patients
cannot respond for themselves, these calculations is an important component of the job. Senneff was
asked if he’d normally encountered patients that were forthright with him and how necessary was this for
him to do his job effective and save a life. Senneff says that he helps aids and assists people from all walks
of life, of all age groups and in all levels of a health crisis. What he has found is that people tell truth, there’s
no need for them to do anything else. They want to be saved and/or have their Loved ones get the
lifesaving care that is needed. He has dealt with the homeless and those that used recreational drugs and
says they tend to be a little withholding out of fear lack of trust etc. and yet Senneff’s lengthy field
experience along with common drug use identifiers, he can assess what’s going on and give vital aide.
Many times that care must be given at the scene, to stabilize the patient before him or her or they, can
even be moved to the hospital; as an emergency responder time is of the essence. When arriving on a
scene and there is a physician present he relies on the doctor to provide factual answers and guidance to
help save the patient. Murray only offered that he was treating Michael for dehydration. Senneff was asked
how a patient would get treated for dehydration and Senneff responded that you could run a saline drip.
He was then asked when you administer drugs to get the heart started in someone whose heart has
stopped would you start with a saline drip first or would you run the drugs directly into the patient. A saline
line would be started, if there is already tubing in place, a line attached to the patient, you must flush the
line first to make sure that there are no clots air and that there is no residual from medications used still
present in the line.
Dr. Murray never gave the FDNY Paramedics vital information to save Michael, he did not tell them what he
had been doing for that past several, we had not given them any information on what he had given
Michael hours before responders arrived. Propofol had been given at least an hour before EMT was on the
scene. Murray said nothing, in fact Senneff didn’t find out that propofol had been used on Michael until
some months later and that came from the media.
Panish Redirect
Mr. Panish asks Senneff if he had ever seen anyone with a cardiologist in their room that died of some type
of medical administration; Senneff replies no. Mr. Panish wanted to know if Senneff would expect a
cardiologist to give correct CPR and whether or not that would be on a bed or a floor. Senneff says that
he never saw Murray give CPR and that the American Heart Association sets the standards and his own
knowledge from 28 yrs. experience that CPR should be done on the floor on a hard surface, that doing so
on a bed would be performed incorrectly. A cardiologist should know how to give proper CPR, I mean this
would be the given. Panish gets Senneff to admit that he didn’t feel that Murray was competent or
forthright on June 25 2009. He also asks Senneff if he’d put is his weight and height estimate of Michael
at the scene against that of the coroners; Senneff responds “No, I would go with the coroner.” Mr. Panish
also asks if Senneff is neutral and if he is just doing his job by appearing today for the city of Los Angeles
Senneff replies yes. Mr. Panish asks if the patient would be the one that he’d rely upon to give him
important medical history and Mr. Senneff replies, Yes. Mr. Panish asks, what did Michael tell Mr. Senneff
about his condition when he arrived, Mr. Senneff says, Nothing. Mr. Panish says that’s because he was
already dead…Mr. Senneff responds, Yes Sir.
Fire fighter Goodwin was trying to give Michael IVs on both his arms 3 on each side but was unsuccessful.
Mr. Senneff adds that Michael was said to be in respiratory arrest, which means that you are not breathing,
your lungs are not filling with air but your heart has not yet stopped. In this situation CPR is vital and its
best to start this right away to get air back into the lungs to assist the heart. Senneff says that a
competent and fit physician to be able to do this especially a cardiologist.
Mr. Senneff says again that when he saw Michael that he looked like someone that suffered from a chronic
illness not anything that had just started in the last day or two. (Um, so how is it, that… AEG and all those
that worked around Michael had no knowledge that Michael was not well.)
End of Testimony for FDNY Paramedic Senneff so he steps down.
Court Transcripts Murray Prelim of Senneff here <<
Video of Senneff from Murray Trial here<<
Detective Orland Martinez takes the stand with direct from Jackson Attorney Brian Panish.
Detective Orlando Martinez takes the stand and identifies himself as a Detective Supervisor for the LAPD.
He was a police office for 19 years and a detective since 2001 for homicide investigation. Det. Orlando
then goes into the process of becoming and officer, what it was like of going through 7 months of the
academy, a year of field training after graduation, learning the skills to conduct a proper investigation,
learning how to use weapons etc… He explained moving through the ranks and becoming a detective and
the importance of preserving evidence. As a detective he is always presenting to a jury and he had to
learn how to do it properly, how to establish motive and how to walk his team or in a courtroom the jurors
through that process. As part of the robbery homicide division, Det. Martinez explains that he is part of an
elite unit (hmm) of the Los Angeles Police Department whom deal with murders, serial murders…
complicated murders, murders of police officers and high profile murders.
On June 25 2009 Det. Orlando Martinez received a call to investigate a death at 100 n. CarolWood Drive
so Mr. Panish asks how is it that Martinez gets the call when he is working in the downtown LA office and
should not this call have gone to the West LA division. (Paaaniiish) The scene detectives decided it was a
high profile case and so he got the call. Mr. Panish asks Martinez was he aware who the death involved and
he responded yes because his Lieutenant informed him. He was sent to UCLA and arrived a little bit after
3pm at the hospital he conferred with 2 West LA detectives at the hospital. He said there were grief
counselors in place so he then spoke to Faheem Mohammed and Alberto Alverez and some hospital staff.
Faheem Mohammed identified himself as the chief of Michael’s personal security and Alberto Alverez
identified himself as Michael’s chief of logistics. When asked if he saw any of AEG staff at the hospital
Martinez says he saw Frank Dileo and Randy Phillips and from Michael’s family he saw Michael’s Mom and
the kids and Randy. By this time this was a death investigation so he had to secure Michael’s room at the
hospital and secure the scene and gather evidence to help the LA coroner who would begin his
investigation. He wanted to speak with Murray but Murray was already gone.
When asked he asked if Det. Martinez at some point did you find out if Michael was pronounced that day
(clever rephrase of a previous question) Det. Martinez says that he found out from Dr. Cooper who was
one of the doctors working on Michael in the ER. (Now people Martinez is part of an “elite” homicide squad.
He says he got the call that was not in his jurisdiction, it was a call actually for West LA to investigate the
death but it was decided that this was a high profile crime. Martinez says he knew it was the death of
Michael Jackson because his lieutenant told him. He was then dispatched to UCLA where he arrived a little
after 3pm, Michael was already pronounced at 2:26. Martinez says that he came to secure the scene
where Michael was laid and to collect evidence to aid the coroner and also conduct interviews while
securing logistics. He…Martinez…right basically walked in the door to conduct a death investigation, so how
does he now say that he learned of Michael’s death from Dr. Cooper…*twists lips & side eyes, because I’m
really just saying right now Paaaniiish)
He says that Michael had to now go to the coroner’s office so they had to come up with the best way to
get him there, so they decided to fly him via helicopter to the coroner’s office. They didn’t want a big
scene; they didn’t want to be followed, they wanted to avoid the “messes” they had on the past as they
had a similar incident a few weeks prior. After Michael arrived to the coroner’s office, Det. Martinez then
went to CarolWood and he arrived there around a bit before 8pm it was dark already and people were all
around. Photographs were taken at the scene and these photos are introduced into evidence. They took
photographs starting with the mailbox this purpose was to give the viewer visuals thru the scene. There
were vehicles parked at CarolWood one was identified as a BMW 6 series. The purpose for identifying the
cars at the scene was to know who was there and contact potential witnesses. The BMW belonged to
Murray and was not searched at the scene and this because the detective wanted to get a search warrant
first, so that it could later be entered as clean evidence. He had Murray’s car impounded because he
wanted to give Dr. Murray a reason to come and talk to him once the car was found to be his. Later he
got the keys to Murray’s car. When asked if he knew who Jeffrey Adams was the detective said that he
was Murray’s friend and body guard and this was the man he got the car keys from (gotta ask why in the
heck does the doc have a body guard) Martinez entered the home and without a search warrant, he says
at the time it was just a death investigation. (Keep in mind that anytime your home is searched authorities
must have a warrant. Michael was already dead and not at the home, this estate needed to be locked
down only til a warrant was in hand. Panish is on point)
Martinez says that while in the Michael bedroom well the room that Michael was found in, he said that what
he noticed as unusual was an IV stand with an empty bag, he saw pill bottles and he saw an ambu bag
which is a breathing bag. He said it looked like the room had been cleaned up. The nightstand appeared to
Martinez as being cleaned up. As he is being presented with pictures he is taking the court through the
scene on what he saw that day. He sees a vial of propofol on the floor underneath the nightstand. He
sees an oxygen tank in the rooms as well but no oxygen mask attached to the oxygen tank. The court
sees pics of pill bottles supposedly found in Michael’s bathroom lorazapam and midazolam. At the scene he
Martinez said he was leaning toward accidental or natural he didn’t see anything that looked like foul play.
He came back to CarolWood on the 26 and the 29 to recover more evidence. (Again I must ask in a
high profile crime why was “evidence left and all not collected and where is the search warrant for
CarolWood, maybe I missed that) When he returned he did so because after the interview conducted with
Dr. Murray where he said there was a 3 bags filled with medication in a closet in Michael’s house. There was
an extensive search done of Michael’s home on June 29 2009, Martinez said he only stayed for part of
that. The court is showed pictures of the search of Michael’s closets dressers medicine draws and cabinets.
A blood pressure cuff was found in a closet along with propofol, in another bag there was a pulsometer
with syringes and other medical trash. He finds more IV bags some with a slice in it; the thought is so that
more of what was inside can come out. He finds lidocaine which is an agent that is supposed to be used to
decrease a burning sensation at the injection site when injecting propofol. He finds bottles of propofol
lorazapam, midazolam… etc. This portion of testimony and presentation is a rehash of the Murray criminal
trial and all the photos of Michael’s room and bathroom that media too had a field day with. Mr. Panish was
refreshing the jury’s mind about the drugs Murray administered and what was found In Michael’s home
after he was murdered and why this is HOMOCIDE NOT AN OVERDOSE!!!
Back to Murray’s car at the scene, when the plates were run it was determined that Murray’s car was
registered to Susan Rush who had a Texas address. She was contacted by Martinez and told him that she
was Murray’s sister and only registered the car for him. At the time Murray was living in Santa Monica and
Las Vegas. But when he was in Texas at the clinic he stayed with his sister, in Santa Monica he stayed with
his girlfriend and child’s mother Nicole Alverez.
Jackson Attorney Brian Panish asks LAPD’s Detective Martinez, where were Murray’s BMW housed and
searched at and what was found during that warrant led search, which took place on June 29 2009 after
it was photographed on the interior and exterior. This is 3 days after Michael’s murder and a day after
Murray sat with his attorney Ed Chernoff for a police interview. Murray’s vehicle was searched at the LAPD
police garage where Det. Martinez found in Conrad Murray’s car a business card for Randy Phillips AEG
Live’s President on the back of the business card was a written cell phone number. Also in the car was a
contract drafted by AEG attorney giving Conrad Murray employ for $150,000 a month and an envelope
with several handwritten notes on it listing several pharmacies. After the items were found the detective
wanted to interview Murray again about the items because Dr. Murray refused. Later the detective was
able to get Murrays cell records and the phone number written on the back of the business card was in
fact Randy Phillips personal cell number. On the envelope found in Murrays car was a list of directions to
various pharmacies. All items found in Murrays car was entered as exhibits by Mr. Panish. In regards to the
AEG contract it was Panish asked the Det. Martinez wanted to look into motive as there was an enormous
amount of money involved. He said he also wanted to look at Randy Phillips as he too had financial gain.
The reasons being is that Mr. Jackson was now dead and while he is no lawyer he read the contract and
motive for Michael’s death started to jump out at him off the contracts pages. He said as an investigator
this is his job, he is trained to see in this way. Mr. Panish asked as an investigator, how would one
determine motive, what type of things would be found in a person’s background that would suggest a
thing like a “financial motive”. The detective looked into Murray’s background extensively, he looked at
things like loans liens and bankruptcy, credit card debt child support or alimony if applicable and his credit
report was pulled from all three reporting agencies. It was discovered that Murray had 8 kids with 7
different women, which equates to huge financial responsibility.
There was a search warrant executed on Murray’s Las Vegas home, they had to get the assist of the Las
Vegas Metro being out of LA jurisdiction and the DEA also participated in the search. During that search
there were many things unearthed that lead law enforcement involved in the investigation to once again
look at Dr. Conrad Murray as being a person with financial motive. Conrad Murray had a loan held against
his home in the amount of $1,644,644.25 and that loan was due July 23 2009. And documents
attributing to such were entered into exhibit by Jackson attorney Brian Panish while detective Martinez
looked over and confirmed that these were in fact part of the evidence that he reviewed during his
investigation. There was also $11,000 in taxes due on Murray’s Nevada residence. As of January 2009
Conrad Murray had already been in rent areas for several months and each monthly payment was about
$3,000 + plus dollars. (Keep in mind the last time he saw Michael was November of 2008) Dr. Murray’s
home was going in to foreclosure because he was in default as he was behind on payments and accruing
interest. Dr. Murray had received a notice of default as early as July of 2008, Mr. Panish made note that
much of this information was public record. (So we gotta ask how AEG would not know the Doctor was
strapped. But hey Randy Phillips said they checked the doctor out and he was good and didn’t need the
cash) Dr. Murray had multiple liens and judgments against him from multiple creditors, such as child
support in multiple state, two in California another in Clark County some as much as $10,000. A child
support lien filed in Las Vegas for child support originating from San Jose California in the amount of
$22,000. (You do realize that not paying your child support, your driver’s license and passport can be
suspended and you can also do time in jail) And yes AEG tried to object to some of these revelations but
they were overruled by Judge Palazuelos.
In the fiscal years of 2008-2009 the Clark County assessor out of Las Vegas, Nevada determined that Dr.
Murray’s Las Vegas property had a taxable value of $1,568,060 and in fiscal year 2009-2010 1,081,253,
there was a drop in the value of the property which Murray had a 1.6 million dollar loan against. At the time
of Michael death, Murray’s property value had already decreased in significant value by half a million dollars.
(Murray was in dire financial straits and desperately needed this job, Murray was enticed by all the wealth
that he had been promised not Michael a man he hadn’t since November of 2008 until he showed up in
the spring of ’09) When Mr. Panish asked whether these occurrences revealed financial motive for Conrad
Murray, det. Martinez says yes. Det. Martinez through further investigation and found that in the city of
Las Vegas that Murray’s clinic Global Cardio Vascular Associates were being sued by a company that had
been doing business with him for well over a $100,000 and in the county of San Diego Dr. Murray’s lawyer
filed a document of income under oath stating that he was making negative 2,706 a month and that he
had significant money owed for other loans. Murray had various student loans the largest being $96,000
and even had a levy put on one of his bank accounts.
Judge stops testimony for a short day and asks Detective Martinez to return tomorrow and take the stand
at 10am.
At the end of court AEG lawyers cried about the public records of Murray should not be stated
as fact, citing that Jackson attorneys are in possessions 100s of pages of records that couldn’t
possibly be all found from public records search. They will do anything to say that they were
unaware. Mr. Panish is like look they have everything we have, they have copies of everything,
like he really doesn’t have the patience for AEG’s shenanigans. The Jackson attorneys are very
confidant and know there way around the courtroom

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