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  • Jackson V AEG - June 18th-Kai Chase (Michael Jackson Chef 2009)

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    VIEW OUR FULL SITE FOR ALL TRANSCRIPTS http://teammichaeljackson.com/ Los Angeles (CNN) -- Paris and Prince Jackson made their first appearances Tuesday in the wrongful death trial against their father's last concert promoter. AEG Live lawyers played short video clips from the depositions of Michael Jackson's oldest children in court to counter testimony from their chef. Kai Chase, who cooked for the singer and his three children in the last months of his life, had described what she said was Jackson's physical deterioration just before his death. Jackson was strong, healthy and active in April, but was so weak by June that Prince, then 12, had to help his father walk up stairs, Chase testified. Chase also repeated the testimony she gave in the criminal trial of Dr. Conrad Murray about the day Jackson died. Paris Jackson's 'cry for help' Who\'s who in Jackson trial Who's who in Jackson trial Photos: All in the Jackson family Photos: All in the Jackson family Photos: Michael Jackson, King of Pop Photos: Michael Jackson, King of Pop But her most dramatic words were about how Michael Jackson's death affected his children -- Prince, Paris and Blanket Jackson, for whom she now cooks at their grandmother's home. "They talk about their father a lot," Chase said. "It's just something that they'll never get over -- the love and how much they miss their father." Jackson's mother and three children are suing AEG Live, contending the concert promoter was liable in his death because it negligently hired, retained or supervised Murray, who was convicted of involuntary manslaughter. Murray told police he used the surgical anesthetic propofol to treat Jackson's insomnia. The coroner ruled propofol killed him. AEG Live lawyers argue Jackson chose and supervised Murray, and their executives had no way of knowing the doctor was using the dangerous treatment. Watch: Anderson Cooper interviews Conrad Murray Paris testifies

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    VIEW OUR FULL SITE FOR ALL TRANSCRIPTS http://teammichaeljackson.com/ Los Angeles (CNN) -- Paris and Prince Jackson made their first appearances Tuesday in the wrongful death trial against their father's last concert promoter. AEG Live lawyers played short video clips from the depositions of Michael Jackson's oldest children in court to counter testimony from their chef. Kai Chase, who cooked for the singer and his three children in the last months of his life, had described what she said was Jackson's physical deterioration just before his death. Jackson was strong, healthy and active in April, but was so weak by June that Prince, then 12, had to help his father walk up stairs, Chase testified. Chase also repeated the testimony she gave in the criminal trial of Dr. Conrad Murray about the day Jackson died. Paris Jackson's 'cry for help' Who\'s who in Jackson trial Who's who in Jackson trial Photos: All in the Jackson family Photos: All in the Jackson family Photos: Michael Jackson, King of Pop Photos: Michael Jackson, King of Pop But her most dramatic words were about how Michael Jackson's death affected his children -- Prince, Paris and Blanket Jackson, for whom she now cooks at their grandmother's home. "They talk about their father a lot," Chase said. "It's just something that they'll never get over -- the love and how much they miss their father." Jackson's mother and three children are suing AEG Live, contending the concert promoter was liable in his death because it negligently hired, retained or supervised Murray, who was convicted of involuntary manslaughter. Murray told police he used the surgical anesthetic propofol to treat Jackson's insomnia. The coroner ruled propofol killed him. AEG Live lawyers argue Jackson chose and supervised Murray, and their executives had no way of knowing the doctor was using the dangerous treatment. Watch: Anderson Cooper interviews Conrad Murray Paris testifies

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    10K views108 pages

    Jackson V AEG - June 18th-Kai Chase (Michael Jackson Chef 2009)

    Uploaded by

    TeamMichael
    VIEW OUR FULL SITE FOR ALL TRANSCRIPTS http://teammichaeljackson.com/ Los Angeles (CNN) -- Paris and Prince Jackson made their first appearances Tuesday in the wrongful death trial against their father's last concert promoter. AEG Live lawyers played short video clips from the depositions of Michael Jackson's oldest children in court to counter testimony from their chef. Kai Chase, who cooked for the singer and his three children in the last months of his life, had described what she said was Jackson's physical deterioration just before his death. Jackson was strong, healthy and active in April, but was so weak by June that Prince, then 12, had to help his father walk up stairs, Chase testified. Chase also repeated the testimony she gave in the criminal trial of Dr. Conrad Murray about the day Jackson died. Paris Jackson's 'cry for help' Who\'s who in Jackson trial Who's who in Jackson trial Photos: All in the Jackson family Photos: All in the Jackson family Photos: Michael Jackson, King of Pop Photos: Michael Jackson, King of Pop But her most dramatic words were about how Michael Jackson's death affected his children -- Prince, Paris and Blanket Jackson, for whom she now cooks at their grandmother's home. "They talk about their father a lot," Chase said. "It's just something that they'll never get over -- the love and how much they miss their father." Jackson's mother and three children are suing AEG Live, contending the concert promoter was liable in his death because it negligently hired, retained or supervised Murray, who was convicted of involuntary manslaughter. Murray told police he used the surgical anesthetic propofol to treat Jackson's insomnia. The coroner ruled propofol killed him. AEG Live lawyers argue Jackson chose and supervised Murray, and their executives had no way of knowing the doctor was using the dangerous treatment. Watch: Anderson Cooper interviews Conrad Murray Paris testifies

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    JACKSON V AEG June 18

    th
    2013 Please help us! To continue providing you transcripts
    Hearing prior to Kai Chase being called
    Court: OK. Somebody wanted to talk to me?
    Mr. Panish: yeah I do your honor. I mean I have multiple issues but I know the jury is coming in at 10.
    Is it OK to bring it up now?
    Court: yes you can.
    Mr. Panish: well first obviously we need to finish Dr. Finkelstein the rulings and the arguments and such.
    Court: yes. That's short. Was there ...
    Mr. Boyle: well we each have a few more but I don't think it will take that long.
    Court: I was hoping you could resolve them not come up with more.
    Mr. Boyle: I know.
    Mr. Panish: well that's par for the course. We have more.
    Court: all right.
    Mr. Panish: so the second thing is for tomorrow as witnesses I'm having a real problem.
    My first suggestion would be ... And I discussed this with Mr. Putnam and he doesn't know yet whether it
    would work for him. Is that right you don't know yet?
    Mr. Putnam: right. I'll try to check at lunch and see if I can reschedule Friday afternoon.
    Mr. Panish: I was trying to see if it's possible to have half a day Wednesday and a full day Friday. For
    two reasons: one I have witness issues and two Ms. Faye is going to take according to Mr. Putnam's
    estimate at least a day. And maybe we could finish her on Friday if she came for the whole day. I don't
    know if the court has plans. Mr. Putnam mentioned that he might have another matter but he's going to
    see if it's possible at noon if he could reschedule that. Now I don't know whether any juror has made
    plans in light of the scheduling so
    Court: this plan the jurors came up with it so we can ask.
    Mr. Panish: and then if no one has made any plans and if Mr. Putnam can rearrange I would like to do
    that if it's possible.
    Court: OK.
    Mr. Putnam what is it you need to do to see if

    Mr. Putnam: parenting.


    Court: oh parenting issues.
    Mr. Panish: I can relate to that.
    Mr. Putnam: so see if I can be covered.
    Court: you need coverage for Friday?
    Mr. Putnam: exactly. I just want to check.
    Mr. Panish: so if Mr. Putnam can work that issue out and assuming no jurors have a problem then we
    have the issue of Mr. Leiweke which we want to play. I don't know in light of the court stayed here late
    last night and it's been pretty busy today I don't know if the court had a chance to look at that.
    Court: no.
    Mr. Panish: and there are a lot of objections to Mr. Leiweke's transcript. So we need to somehow get that
    figured out in time for tomorrow. I don't know how we're going to do that. Then there's
    Court: well he's not being ... Is he being called live as well?
    Mr. Panish: no. We're going to try to do it by video.
    Mr. Boyle: depending on the rulings on the video we would play him by video. But as Mr. Panish
    Said there are a lot of objections and if the video gets gutted then we'll have to call him live.
    Mr. Panish: so we don't know about that issue. And then there's a private issue I need to discuss with the
    court in chambers
    Court: OK.
    Mr. Panish: ... Which I've preliminarily discussed with Mr. Putnam but I want to discuss it with the
    court. And Mr. Putnam and I have talked and we're going to further talk on that issue but I think I need
    to raise that with the court.
    Court: OK. Anything else?
    Mr. Putnam: I have something your honor. So yesterday when alternate no. 6 came the ... I thought that
    it sounded familiar. And so I went back into the transcripts to look at the prior two times he brought this
    up. And what he indicated both prior times as well as this time is that he would be trying to buy the place
    in Atlanta by the 28th of June. And if that was on schedule then he would have to be there august 28th.
    And you informed him that second time that when he sold just to let us know which is what I think he
    was doing. I don't think in light of that that there's reason to let him go at this point. If Mr. Panish is able
    to keep to the schedule they've indicated I don't know what the evidence is going to show but I believe
    timing-wise this shouldn't be an issue.
    Court: all right. We can ask him.

    Mr. Putnam: and if it is I would like to revisit it in two weeks. One thing I'm sure of ... And I've done
    other longer ones before ... Once you start to lose you lose more. So the longer we can wait on that I think
    is prudent. I would hate more than anything for that to become an issue given how long we've done this.
    Court: I can ask him further inquire say "initially you told us august 28th." he would be able to serve
    until about that time. That's when he needed to return to Georgia.
    Mr. Putnam: take up residency yes.
    Court: and if that's still the case perhaps we can keep him. We'll talk to him.
    Mr. Putnam: we can even tell him we can revisit it at the end of their case.
    Mr. Panish: at the end of what?
    Mr. Putnam: of your case.
    Court: OK. So we'll revisit that with him. Half day and full day ... When do you think you'll know?
    Mr. Putnam: I have to find out ... I just have to get someone to cover me. I can get that at the break. You
    want me to do that before we ask the jurors? I can do that if you prefer.
    Court: yeah. You can do that at the break.
    Mr. Putnam: OK.
    Court: but I want to make sure that it's doable before I suggest that to the jurors.
    Mr. Putnam: in fact your honor while you're doing the objections I can go out and try to do it then.
    Court: OK.
    Mr. Putnam: is that all right with you?
    Court: sure.
    Mr. Putnam: OK.
    Court: let's do the objections and then do the private issue when you come back.
    Mr. Putnam: all right. I'll be right back.
    Mr. Boyle: OK your honor. So one ...
    Court: i'll need to get Finkelstein though. OK. All right. Let's talk about Finkelstein.
    Mr. Boyle: OK your honor. So as an initial matter after all the rulings are done ... And we hate to put the
    court through all this work if it's going to be unnecessary but we're going to need to look at the script to
    see if what we have left is enough and if we're going to have to have Dr. Finkelstein in live anyway. So I
    apologize if that happens. I don't want you to think we're putting you through needless work. We'd like
    to do this through video if we can but if there's some foundational things that will be kept out there are

    some issues that we think we can lay the foundation live. But anyway where we kind of left off was the
    court was going to sustain defendants' objection to page 66 line 23 through 67 line 7
    Court: 66/23?
    Mr. Boyle: correct. 66/23.
    Court: I overruled that one unless I changed my mind about that one. But I'm looking at ... Am looking
    at the correct thing? Yeah. Finkelstein page 66 lines 23 through 25 I overruled.
    Ms. Cahan: and your honor we had argued that yesterday and you had sustained it conditionally. That
    was the one where Mr. Boyle said that he thought there was definitive testimony making the statement
    that was stated in a speculative way and I think he found the definitive testimony. And it's our
    understanding that in that circumstance your honor would sustain the objection since they have it in
    another place where there is no an objectionable question and answer.
    Court: I would overrule it if there is no prejudice to it.
    Mr. Boyle: that was my understanding of what I was looking for because basically in 66 he's saying
    Court: otherwise it doesn't make sense to delete it out of the deposition.
    Mr. Boyle: right.
    "is it a fair assumption that you would have told Mr. Gongaware what was going on?" and he says "yes."
    So then your honor at lines ... I'm sorry. Let's go back first. At lines 53 ... Page 53/21 through page 54 line
    16.
    Court: 53/21?
    Mr. Boyle: correct.
    "and sir when the second Bangkok show got postponed was it Mr. Gongaware that postponed the show?" the
    witness: "I thought I postponed it. "OK. Well did you inform Mr. Gongaware of the situation with the artist?"
    answer: "yes sir. "and what did you tell Mr. Gongaware in regard to the situation with the artist?" answer: "I
    said 'I think we're going to have a problem.'" question: "and did you elaborate on that?" answer: "I don't ... I'm
    going to say 'yes' but I wouldn't know exactly what I said or ..." question: "well did you tell Mr. Gongaware you
    thought that Mr. Jackson had a dependency on opiates?" answer: "yes." so Bangkok was early on in the tour
    which I mean when he assumed later in testimony he told him he did tell him.
    So I think 66/23 should stay in.
    Court: all right. I'll ... It stays in.
    Mr. Boyle: OK your honor. Then on that same line I would like to direct the court's attention to page 76
    lines 21 through 24.
    Court: 76?
    Mr. Boyle: yes. 76 lines 21 through 24. And this is a question that was:

    Question: "and it was your understanding that Mr. Gongaware was aware of the opiate problems that
    Mr. Jackson was having; correct?" answer: "yes."
    And so by that same token the fact that Mr. Gongaware told ... The fact that Dr. Finkelstein told Mr.
    Gongaware is the foundation for him understanding he's aware.
    Court: OK.
    Mr. Boyle: so I think that should be in. I think the objection should be overruled.
    Court: let me just clarify. This is 76/21 through 24; correct?
    Mr. Boyle: correct.
    Court: OK.
    Ms. Cahan: your honor the context of that one is a little bit different. They're discussing the period
    between Bangkok and Mexico city that approximately three- to three-and-a-half-month period. And so
    the testimony from Dr. Finkelstein was that he remembers telling Mr. Gongaware and others in Bangkok
    at the very beginning of the leg of the tour "I think he may have a problem with opiate dependency."
    and then he didn't treat ... Dr. Finkelstein didn't treat Mr. Jackson or provide any medical care to him
    for that three-and-a-half-month period. So this question where it comes Mr. Gongaware was aware of the
    opiate problems that Mr. Jackson was having that's discussed in that intervening three-and-a-half-month
    period and that was the basis for the objection. Because it's not talking about what was discussed in
    Bangkok. It's talking about what happened in the tour over that three and a half months. Mr. Boyle:
    Bangkok happened first. That's where he gained the understanding. And then things happened like Dr.
    Forecast broke into his bag to steal opiates for Michael. And so that's ... He had an understanding. I
    think that has to come in.
    Court: is your argument that Mr. Gongaware wouldn't have had an understanding in the subsequent
    three months?
    Ms. Cahan: so ...
    Court: he's made aware but then he's otherwise not made aware the following three months?
    Ms. Cahan: right. So the series of questions is ... Mr. Gongaware is informed by Dr. Finkelstein in
    Bangkok "I think he may have a problem with opiates." then the tour goes on for three and a half
    months Mr. Jackson is performing Dr. Finkelstein is not treating Mr. Jackson.
    Court: OK.
    Ms. Cahan: he's not involved with his medical care. But these series of questions about the interactions
    between Dr. Forecast and Dr. Finkelstein on the tour Dr. Finkelstein is traveling with ... Dr. Finkelstein is
    the doctor for all the 160 people on the tour and not for Mr. Jackson. So the series of questions makes
    clear that although it's not stated in this one question and answer that the line of questions ... And this
    question is really about the intervening three and a half months from Bangkok to Mexico city "were you
    aware there was an opiate problem during that time?"
    Court: and why wouldn't Mr. Gongaware be aware of that?
    Ms. Cahan: he was aware that there was a problem ...

    Court: right.
    Ms. Cahan: ... Dr. Finkelstein had a concern about a problem in Bangkok.
    Court: right.
    Ms. Cahan: but there's no evidence whatsoever that anyone either Dr. Finkelstein or Mr. Gongaware had
    an awareness of whether Mr. Jackson was continuing to uses opiates had been detoxed was using other
    medications at that time.
    Court: but isn't that an inference that can be drawn?
    Mr. Boyle: I believe so your honor. What he became aware of in Bangkok was very severe and also other
    things happened like the breaking into the bag of Dr. Forecast. And the question is just simply "is it your
    understanding that Mr. Gongaware was aware of the opiate problem?" "yes."
    Ms. Cahan: and that's ...
    Mr. Boyle: you know.
    Ms. Cahan: I'm sorry. Didn't mean to cut you off.
    Mr. Boyle: so based on the prior testimony that he told Mr. Gongaware about it having an understanding
    that he's aware I think is a perfectly reasonable thing to ...
    Ms. Cahan: I think it's fair to let the jury draw the inference ...
    Court: yes.
    Ms. Cahan: ... That if he knew in Bangkok he must have assumed things continued to happen. But here
    Dr. Finkelstein is speculating about what Mr. Gongaware knew or didn't know three and a half months
    later when there is not a foundation that either Dr. Finkelstein knew anything about Mr. Jackson's
    medical care in the intervening three and a half months or that he discussed it with Mr. Gongaware to
    the extent he knew something.
    Court: OK. I'm going to overrule that objection.
    Mr. Boyle: OK.
    Court: that was 76/21 through 24; correct?
    Mr. Boyle: yes your honor. Thank you.
    Court: so are there similar ...
    Mr. Boyle: no. Actually because of that I'm going to skip two of them then. I'm not going to do the one on
    86 or 87. If your honor would go to ... These will be quick. 73/24 to 25.
    Ms. Cahan: that's not one that you had mentioned to me.

    Mr. Boyle: 73/24 to 25 this is discussing Michael's opiate use. And there was a question that no one
    objected to. And the question: "now is it a caricature (sic) flaw for someone to be addicted to opiates?"
    answer: "no." so then a few lines later I asked ...
    Court: "does it make him a bad person?"
    Mr. Boyle: "would that make him a bad person?" right. And the objection was "unduly prejudicial." but
    that only would mean that they are trying to prejudice Mr. Jackson by making people think he's a bad
    person. And I don't see why we can't use an addiction expert to say you're not a bad person if you have
    an addiction.
    Court: well is it really relevant whether somebody is a bad person or a good person if they're using
    drugs? I mean does that have any connection?
    Mr. Boyle: well in this case ...
    Court: you can be a good person and use drugs; you can be a bad person and use drugs.
    Mr. Boyle: it goes to the noneconomic loss. I mean if you lose a loved one if they're ... You know if they're
    some bad scumbag bad person drug addict that might make it less ...
    Court: that would make it less painful for someone who loses a relative because they're ...
    Mr. Boyle: well that's part of the defense here. "ugly things will come out in this trial" "ugly things will
    come out about Michael." and now we have a doctor saying "he's not a bad person because he was
    addicted to opiates." I don't know how that's prejudicial for anybody.
    Ms. Cahan: your honor to make the record completely clear we are not taking that position. And the
    issue here is ... There are a couple issues. I think one is that they do have addiction experts retained
    experts who they can come testify. Dr. Schnoll was going to come at one point. He's not currently on the
    48-hour schedule but presumably he will be coming or could come. The larger issue here is that Dr.
    Finkelstein's testimony is clear that he treated Mr. Jackson twice in 1993 I believe he treated him once in
    1995 for a back pain issue and then had no contact with him for 14 subsequent years until Mr. Jackson
    passed. And so it really is irrelevant. It does lack foundation. And I have no objection to their addiction
    expert offering ... Their retained expert offering that testimony.
    Court: when is it ever relevant whether someone is a good person or bad person? I mean either you're
    liable; you're not liable; you're a drug addict; you're not a drug addict. But whether you're a good
    person or a bad person ...
    Mr. Boyle: I think in noneconomic wrongful death cases the jury evaluates the value of the loss and what
    is lost. And the loss of a horrible person is probably you know not as valuable as the loss of a great
    person. But more importantly it's to dispel the myth that addicts are somehow lesser people you know.
    And this guy is a non-retained expert by the defendants and a non-retained expert by the plaintiffs. And
    he's saying addicts aren't bad people. I don't see how that's prejudicial. I don't understand ...
    Court: well you do have in here: "now is it a character flaw for somebody to be addicted to opiates?" I
    allowed that. But "good person" "bad person" I'm going to sustain that.
    Mr. Boyle: OK.
    Court: you're free to argue that in closing.

    Mr. Boyle: I understand. That will take care of a couple of them then. And then I think I just have one
    more. So your honor one is 73 ... Page 70 line 3 through page 70 line 11.
    Ms. Cahan: that was sustained as a hearsay objection.
    Court: 70 line 3 through 7. OK. I see that. All right. Give me a minute.
    Mr. Boyle: I just wanted to clarify. Is the reason the court sustained the objection based on hearsay?
    Court: hold on. (reviewing document.) Well he goes on to say "you'd be calling ... "you'd be asking me to
    speculate." I think that's where I had the ... "but if you want me to speculate the answer is 'yes.'"
    Mr. Boyle: yes. I wasn't going to argue that part of it. I was just talking about 70/3 through 11:
    "based on your communication with Dr. Forecast did you have an understanding that Mr. Jackson was
    receiving pain medication on a consistent basis for the three and a half months between Bangkok and Mexico
    city?" answer: "yes."
    So Dr. Finkelstein did have an understanding that Michael was consistently getting medication for those
    three months. And I think that fits in.
    Ms. Cahan: classic hearsay your honor. And actually the points that I wanted to raise this morning are
    related points about Dr. Forecast ... What Dr. Forecast told Dr. Finkelstein.
    Court: there's a lot of communication between Dr. Forecast and Dr. Finkelstein.
    Mr. Boyle: but your honor an expert can rely on hearsay.
    Court: well the other thing ...
    Ms. Cahan: he's not a retained ...
    Court: ... This is all in connection with Michael Jackson's treatment isn't it?
    Mr. Panish: yes.
    Court: so I mean wouldn't it be somewhat well inherently reliable that they're talking to each other about
    treatment for Michael Jackson?
    Ms. Cahan: Dr. Finkelstein was not Michael Jackson's treating physician. He treated him on two
    occasions when Dr. Forecast wasn't available: once at the beginning of the leg of the tour and once at the
    end in Bangkok and Mexico city.
    Court: OK.
    Ms. Cahan: so they weren't having ongoing communications about Mr. Jackson's medical care. Dr.
    Forecast is somebody plaintiffs could have located and deposed in this case had they wanted to. His
    statements to Dr. Finkelstein are classic hearsay and we think that they are inadmissible. And it's here as
    well as a couple other examples that I wanted to bring up with your honor.
    Court: well are you suggesting ... Well forecast and Finkelstein were on the same tour; right?

    Mr. Boyle: correct.


    Ms. Cahan: but Dr. ...
    Court: and one broke into the bag of another. Sounds like they had communications ...
    Mr. Panish: they did.
    Court: ... About Michael Jackson; right?
    Mr. Boyle: correct. Correct.
    Court: anyway ... Well ...
    Mr. Boyle: yeah. You know ...
    Court: I went back and forth on this as I was reviewing this.
    Mr. Boyle: Dr. Finkelstein did treat Michael on that tour even though he was the tour doctor and forecast
    was more of a personal doctor. He did treat Michael Jackson. Finkelstein and forecast talked about the
    treatment of Michael Jackson and his problems like you said. Forecast broke into Finkelstein's bag to
    give him more drugs. I think Finkelstein having an understanding based on essentially a co-treatment
    with Dr. Forecast that Dr. Forecast was giving Michael drugs is totally admissible and non-hearsay. Also
    experts can rely on hearsay to form this understanding. And he's a non-retained expert for both sides.
    Ms. Cahan: and your honor I don't believe that that hearsay ... That's a hearsay exception that would
    apply here. Experts are allowed to rely on hearsay in order to form opinions and offer opinions but
    they're not allowed to backdoor hearsay in through sponsoring it in their expert testimony. So if Dr.
    Finkelstein were to appear in the capacity as an expert and testify about you know "I had an
    understanding that Michael Jackson had a drug dependency problem in the '90s both from my treating
    him and from things that I was informed of" that would be permissible. But what he can't say is "and
    one of the things I was informed of is was that Dr. Forecast told me" and that's hearsay and I'm not
    hearing any exception.
    Court: well isn't there an exception ... I can't recall an exception for two doctors talking to each other.
    But it does seem as though there's some inherent reliability when two doctors are talking to each other
    about treating a patient as long as the conversation is at the time the treatment is being given that there is
    some inherent reliability in that discussion.
    Ms. Cahan: and I don't think there's any foundation that there was a discussion at the time any
    treatment was being given except ... So my understanding from Dr. Finkelstein's testimony is he showed
    up in Bangkok. Dr. Forecast had not yet arrived and so he gave Michael Jackson some pain medication
    at the direction and over the phone with Dr. Metzger who was calling from California. So he had
    interaction with Dr. Metzger at the time he administered medication to Michael Jackson in Bangkok.
    Three and a half months go by he's not providing any medical treatment to Mr. Jackson. And at the time
    he treated him in Mexico city again for an urgent pain issue was at a time when Dr. Forecast was not
    available which is why Dr. Finkelstein stepped in. So it wasn't as though they are consulting physicians
    treating physicians having a conversation about the best medical care to render to Michael Jackson. It's
    one isolated incident before he ever met Dr. Forecast and one other isolated incident where Dr. Forecast
    is out of Mexico city and unavailable to take care of Michael Jackson.

    Mr. Boyle: your honor I will also ... Very shortly before that quote he also says that ... Dr. Finkelstein
    says that he saw Dr. Forecast administer medicine to Michael so he was in the same room and saw it
    happen. So that's another basis of his understanding. And I don't ... I can't cite it to you now but I think
    there is treatment exception when you have two doctors essentially combining treatment on a patient it's
    inherently reliable and that can come in.
    Court: I'm not sure there's an exception but there's that catchall where if there's some reliability to it ...
    And I went back and forth on that as I was reviewing all the various designations in terms of well is this
    something that is inherently reliable because there's two doctors who appear to be communicating about
    his treatment.
    Mr. Boyle: and your honor also ...
    Court: maybe not a lot but there's some ... It appears that the communication was contemporaneous to
    what they were doing at the time.
    Mr. Boyle: and I think you know I agree with you your honor. And the final is 1250 ... Evidence code
    1252 it's being offered to prove or explain the acts or conduct of the declarant. Prove or explain what Dr.
    Finkelstein was doing because he had this information from Dr. Forecast and to prove why what he did
    on this tour in Mexico city got the group together and said "hey Michael has a problem" et cetera et
    cetera. That is a recognized hearsay exception in addition to the other reasons.
    Ms. Cahan: and your honor I don't think that applies. I think Mr. Boyle is conflating the two situations.
    The conversation that Dr. Finkelstein had with members of the tour about his concern about Mr.
    Jackson's health was in Bangkok before Dr. Forecast arrived before anybody ever met Dr. Forecast.
    Court: OK.
    Ms. Cahan: and then the one other time he treated him was when Dr. Forecast was not there or available.
    I don't think there is ... I'm certainly willing to be corrected but I don't think in California state court
    there is an exception a catchall exception for inherently reliable testimony. And I don't think 1250 applies
    here because although the conversations may go to Dr. Forecast's understanding of Michael Jackson's
    medical condition there's no foundation that Dr. Finkelstein had any contemporaneous conversations
    with Dr. Forecast the two times the two isolated times he treated Mr. Jackson or that any conversations
    he did have with Dr. Forecast informed the way he treated Michael Jackson. He gave him pain
    medication in Mexico city and had there been conversations about opiate dependency and what might or
    might not be appropriate he did not testify as to whether the medical treatment the pain medication he
    gave Mr. Jackson in Mexico city wasninfluenced by any understanding he had from Dr. Forecast.
    Mr. Boyle: your honor in fact ... Sorry.
    Ms. Cahan: sorry. Just to add something. Ms. Faye is someone who has testified about Dr. Forecast. She
    has some pretty negative things to say about him. She recounted an incident where he grabbed her by the
    throat and held her up against the wall and choked her which caused her to leave the tour for a time. So
    to the extent that one is thinking about a situation of two physicians who are rendering medical care and
    are sort of upstanding members of the profession I don't think the record is clear as to who Dr. Forecast
    was or what his character was or the reliability of his statements is good.
    Mr. Boyle: your honor on Ms. Faye I mean I'm glad to say they put so much faith in what Ms. Faye has
    to say. I have a feeling on Friday they're going to do all they can to impeach Ms. Faye. But regardless of
    that there is evidence they had continuing communications. In fact right above the section we're talking
    about Dr. Finkelstein said: "and Dr. Forecast and I were in communications because we didn't want ...

    Kind of want to take the hit for what other doctors had done before him"; right? So they were talking
    about this the whole time. There was an issue.
    Court: well is there a catchall?
    Mr. Boyle: I think there's a catchall in ...
    Ms. Cahan: more a federal.
    Court: maybe in federal court. Is there such a thing?
    Mr. Boyle: I think the court has inherent power also because if we can get this done we don't have to call
    in a live witness.
    Court: that's not a reason to throw out the hearsay rules because it's easier.
    Ms. Cahan: your honor to be clear he wouldn't ... Our position is that if this is disallowed now it wouldn't
    be allowed in his live testimony either. There's no difference. If he comes in and sits here he's still not
    allowed to sponsor hearsay testimony.
    Mr. Boyle: we can say "based on everything you experienced with Dr. Forecast."
    Court: why don't you do some research. I know you don't want to but why don't you do some research
    and tell me whether ...
    Mr. Boyle: there's a catchall ...
    Court: catchall or maybe physicians' statements to each other. Something in the case law that might
    discuss that.
    Ms. Cahan: and your honor I don't want to take any more time on this but just for the record because
    the jury is waiting the three points I did want to argue are also about things Dr. Forecast told Dr.
    Finkelstein. And those are 129 lines 3 to 7; 129/23 to 131/5; and 136 line 24 to 137 line 8. And this is all ...
    Court: yeah this was all towards the end. OK. I remember thinking about the issue. So OK.
    Mr. Boyle: thank you.
    Court: I would appreciate it if you would look and find out. There's probably something addressing this
    in the case law.
    Mr. Boyle: thank you your honor.
    Ms. Cahan: yes your honor. We're happy to confer about that before we take up more of the court's time
    on this.
    Court: OK.
    Ms. Cahan: thank you.
    Mr. Boyle: thank you.

    Court: so there's nothing immediate that ...


    Mr. Boyle: I think all the ones we talked about will be covered if there's a catchall or the doctor thing.
    Court: you can start cutting the video and leave those things out for now.
    Mr. Boyle: correct.
    Mr. Panish: any idea when you might be able to get to Leiweke?
    Court: pardon?
    Mr. Panish: when I might be able to address Mr. Leiweke?
    Court: when? As soon as I can.
    Mr. Panish: no. I just said any idea when you might have the time to do that? That's all. Court: maybe
    tomorrow.
    Mr. Panish: not until tomorrow. So we're not going to be able to play it tomorrow?
    Court: probably not. I have six motions.
    Mr. Panish: I'm just asking.
    Court: I know.
    Mr. Panish: if you can't do it I understand. I'm just trying to get a feel for the evidence. That's all.
    Mr. Boyle: your honor do you know in terms of the new fire marshal rules if a party is having one lawyer
    at the podium can they have two lawyers sitting at the table and just switch when the does anyone
    know the rule on that?
    Court: I don't know what the rules are. I keep getting told one thing then .
    Mr. Panish: nobody said we couldn't do that.
    Court: nobody said you couldn't do that.
    Mr. Panish: OK. The clerk: we were told only four chairs at counsel table.
    Court: no he's not saying to have a chair. He's saying one person at the podium ...
    Mr. Panish: if we have four chairs we're not violating any rules.
    Court: right. So if one person stands there and two are here I guess it's not a problem.
    Mr. Boyle: OK. Thank you.
    Mr. Panish: two and two.
    Court: didn't you want to have a conference or something?

    Mr. Putnam: before we do your honor I can tell you that I can switch Friday and Wednesday.
    Court: OK. Good. Then we'll ask the jury.
    Mr. Panish: thank you.
    Court confers in chambers off the record
    Kai Chase
    (Chef April 09 Then June 09)
    Direct Examination by Ms. Chang
    Q. Good morning Ms. Chase.
    A. Good morning.
    Q. Can you tell us what your current occupation is?
    A. I'm a professional Chef.
    Q. How long have you been a professional Chef?
    A. For about 17 years.
    Q. And who do you currently work for today?

    A. I work for Katherine Jackson and the Jackson children Paris Blanket and Prince.
    Q. OK. The oldest being Prince?
    A. Yes.
    Q. The middle being?
    A. Paris.
    Q. And the youngest being?
    A. Blanket.
    Q. All right. And prior to working for mrs. Jackson did you work for Michael Jackson while he was preparing
    for the "This Is It" tour and living at 100 north Carolwood Drive?
    A. Yes I did.
    Q. OK. Is it all right with you today if I call it "the Carolwood house"?
    A. Fine. Yes.
    Q. All right. How long did you work for Mr. Jackson at the Carolwood house?
    A. I worked for Mr. Jackson for approximately two months.
    Q. All right. And was it continuous or was it separated?
    A. It was separated.
    Q. OK.
    A. I started at the end of March and was let go in May and brought back in June.
    Q. All right. So it was at the end of March for the whole month of April?
    A. Yes.
    Q. And then you did not work in may and then you came back in June ...
    A. June.
    Q. ... Is that correct?
    A. Yes.
    Q. And was that at the beginning of June?
    A. Yes it was.

    Q. Until his death?


    A. Until his death yes.
    Q. All right. Let's start a little bit and hear about your background. Can you tell us about your educational
    background?
    A. I started my culinary profession back early on at a small boutique culinary school called Epicurean. Before
    that I worked as an interviewer for a music magazine called the Urban Network and took most of my clients
    from that particular job with me into the culinary field Went to Paris France and studied at Le Cordon Bleu
    where I got my master's degree there. And I came back to the United States and started a catering company
    called "Kai Catering."
    Q. And when you say ... Is that the Le Cordon Bleu Culinary academy in Paris?
    A. In Paris France yes.
    Q. OK. Can you tell me why did you want to become a Chef after working for I think you called it Urban
    network magazine?
    A. Yes. I come from a family of artists and entertainers so my artistic gift is the culinary profession and giving
    back through my expression of love through food.
    Q. And that's your art?
    A. That's my art.
    Q. Tell us a little bit about Le Cordon Bleu Culinary academy in Paris.
    A. The Le Cordon Bleu in a very prestigious culinary campus in Paris France. It's been founded since the
    1800s. And Julia Child is one of the famous Chefs to have graduated from this school.
    Q. All right. And I'd like to show exhibit 900.
    Q. By Ms. Chang: all right. And can you tell us is that you?
    A. That's me.
    Q. And is this the famous Le Cordon Bleu culinary academy?
    A. Yes it is.
    Q. OK. There was recently a movie called "Julie & Julia"?
    A. Right. That was the famous school yes where she attended.
    Q. Meryl Streep?
    A. Meryl Streep yes.
    Q. Did you enjoy studying in Paris?

    A. I loved Paris. I loved the sights the sounds the people the Chefs. It was a very very beautiful experience.
    One that I will never forget. I still keep in contact with the friends there speak a little French. But the food was
    amazing.
    Q. Did you learn a lot about food?
    A. I learned a lot about food and technique. And the overall experience was just beautiful.
    Q. And when did you graduate from Le Cordon Bleu?
    A. '97. 1997.
    Q. All right. And what you're wearing there is that the typical what I call the Chef's outfit?
    A. That is. That is the standard uniform for Chefs.
    Q. OK. And what did you do after you graduated? I think you said you started your own catering company?
    A. I started my own catering company when I returned to the states and started acquiring the clients from the
    magazine that I worked for. So a lot of musicians producers film tv became my clients in the catering field yes.
    Q. OK. And are you accustomed to working with people in the entertainment industry?
    A. Yes. My godfather was Redd Foxx so I grew up as a little girl with you know feeding my godfather making
    him little cakes and stuff for him. So that's just been part of my world.
    Q. And I think you told us you came from a very artist-oriented family?
    A. Very artistic yes.
    Q. Can you tell us some of the clientele ...
    A. Some of the clients I've cooked for President Barrack Obama being one; Bernie Mac Steve Harvey Macy
    Gray Jaylyn Rose John Salley congresswoman Maxine Waters. The list goes on. I've worked with Wolfgang
    Puck. I worked with Pamela Anderson in her restaurant. It was the same style.
    Q. All right. So it sounds like a wide variety ... I heard a few NBA stars in there?
    A. Yeah.
    Q. Singers songwriters entertainers?
    A. Exactly.
    Q. All right. I'd like to show exhibit 901 And can you tell us what that is a picture of?
    A. That's the 1997 event that I did for President Barrack Obama for his inauguration.
    Q. He was here in Los Angeles?
    A. He was here in Los Angeles.

    Q. And how were you selected to be the Chef for President Obama?
    A. It was out of ten different caterers and executive Chefs. And I got the gig because I'm good.
    Q. Great. OK. And did you have a chance to meet with him?
    A. Yes I did.
    Q. And did you actually have a conversation with him?
    A. Yes I did. I was so honored as I am to work with any of my you know higher celebrity clients. Always
    honored. But when I got a chance to actually meet him it was two pictures. We took a picture side by side And
    then I was actually very lucky to get a second photo which was this one. And I got it in really fast so I started
    saying to him the meal that I prepared for the cocktail reception that he was having and he was very ... You
    know he was pleased to see a young African-American female actually doing her thing. So that was ... That
    picture is of proud and honor.
    Q. That's wonderful. OK. And can you tell us how long did you have your own catering company?
    A. I had my catering company for ... Since I came back to the states until 2001 when 911 hit. And I closed my
    company down at that point because I was doing a lot of catering on TV and film sets. And the high-powered
    security that the studios were having they weren't allowing a lot of outside caterers on the set. So my business
    started to slow down and small businesses were not in demand at that
    point.
    Q. Is that when restaurants also took a hit on 911?
    A. Right.
    Q. People weren't going out?
    A. Well yes. People were very fearful after that terrorist attacks.
    Q. So after you closed down your catering company where did you work after that?
    A. I worked for Wolfgang Puck catering events.
    Q. And just for some people here who don't know. Who is Wolfgang Puck?
    A. Wolfgang Puck you've probably seen his pizzas in Gelson's supermarket but Wolfgang Puck is a
    Celebrity Chef worldwide.
    Q. And I think ... Is there restaurants?
    A. Yes. He does the Oscars. He has Wolfgang Puck and Spago in Beverly Hills and Chicago.
    Q. And iron Chef?
    A. And also iron Chef.
    Q. He was.
    A. He was.

    Q. I want to also show exhibit 902 is that the Wolfgang Puck you were talking about?
    A. Yes. Me and my former boss.
    Q. Did you learn from him?
    A. Very much yes.
    Q. OK.
    A. He's very well-rounded and he loves to support up-and-coming Chefs. He's not afraid to pass the baton.
    And he's well- ... His favorite motto is "live love eat." so it's a celebration of food and good life.
    Q. How long did you work for Mr. Puck?
    A. Two years.
    Q. And what did you do after that?
    A. I went into the private Chefing world.
    Q. OK. Is that where you work as the sole Chef for someone?
    A. Yeah. I worked as a sole Chef for a CEO of a black-owned bank. One united bank he and his wife.
    So I worked for them a few years after leaving Wolfgang.
    Q. All right. Ms. Chase for all the training and experience that you've shared with us are you trained as a
    Nutritionist?
    A. No I am not.
    Q. OK. Do you have any background in the field of nutrition?
    A. Um I have ... Well not professionally but I have ... You know I've studied ... In the world of food I've
    studied nutritional ways of life as far as vegetarianism veganism macrobiotics raw living foods things of that
    nature. But as a Nutritionist I have no credentials for that.
    Q. In the culinary world is a professional Chef separate and distinct from a professional Nutritionist?
    A. Absolutely.
    Q. And you don't hold yourself out to be a Nutritionist?
    A. No.
    Q. OK. All right. Well after this experience how did you first become to be considered as a Chef for Michael
    Jackson?
    A. I got a phone call one day. This is right after I had left working for the CEO of One United
    Bank. I received a phone call from a company called

    Culinary Staffing. And they're a company I had used before with my catering company to hire out staff. So they
    called one day and they said there was
    A. Client looking for a professional Chef and they knew that I was of that status. The client was a ... It was a
    husband and wife and two kids. And the husband was a businessman. And would I be interested in the job. And
    yes I was because I had already been Private Chefing for private clients and was looking for a new job. "can
    you please send your resume over to us so the client could take a look at it?" I did just that. I got a phone call
    back within an hour and they said "the client was very impressed with your resume and would like to meet with
    you." So great. We set up a meeting to go meet at the Coffee Bean & Tea Leaf at the grove in Los Angeles.
    And ...
    Q. When you got there who did you meet with?
    A. Well I didn't know who I was meeting with and the client didn't tell me. I don't know if they even knew. But
    I met with a gentleman by the name of Michael Amir.
    Q. OK.
    A. So I was looking for this man named Michael and he didn't look like a businessman to me. He was young.
    But I thought maybe this was the client. So we interviewed back and forth and he asked
    me of course about nutrition about work schedules and things that you would speak about with another Chef.
    Q. And you thought he was your client?
    A. I thought he was my client. So I asked him I said "so you're the client?" And he said "no I am not. But this
    is who you will be working for." and he gave me a card a business card and it said "The Michael Jackson
    Company" on it. And when he handed me the card I was whoa you know. I was like wow this is really a big
    honor honestly. And he said "the client was very impressed with your resume having come from working for
    these people." this is how I in turn got the job to work for him.
    Q. Were you excited?
    A. Yes I was.
    Q. Did you have a second interview?
    A. Yes. I had a second interview which was at
    The house on Carolwood.
    Q. OK. And who was present at this second interview?
    A. Well it wasn't Mr. Jackson. It was my junior clients which were Michael's children.
    Q. OK.
    A. And they interviewed me first.
    Q. And so it was just the three children interviewing you?
    A. Yes.
    Q. And it was Prince Paris and Blanket?

    A. Yes.
    Q. All right. At the time how old were they?
    A. Prince was 12; Paris was 10 11.
    Q. About to turn 11?
    A. About to turn 11. And Blanket was 9.
    Q. OK. I'd like to show exhibit 903
    Q. By Ms. Chang: and does this photograph fairly and accurately depict what the children looked like in 2009
    when you met them?
    A. Yes.
    Q. All right. So why don't you ... Why don't I start out. And this handsome fellow here to the left who is that?
    A. That's Prince.
    Q. OK. And he's holding hands with his sister and that's?
    A. Paris.
    Q. Is that Paris?
    A. That's Paris.
    Q. And Paris is wearing a hello kitty t-shirt?
    A. She loved pink and loved hello kitty.
    Q. All right. When you first started she was still wearing hello kitty and wearing pink?
    A. Wearing pink.
    Q. And this little guy to the right is?
    A. Blanket.
    Q. I want to show 931 now. And just so that we have an idea is this about the age and how they appeared
    around the time their father died?
    A. Yes.
    Q. All right. And that's little Blanket there?
    A. Yes.

    Q. N back in March of 2009 when tou're having your second interview with your junior clients where in the
    house did the interview take place?
    A. In the kitchen. There's a little dinette dining room kitchenette in the kitchen and we sat at the table there.
    Everyone was talking ...
    Q. Was anyone else there?
    A. Their nanny Grace.
    Q. Is that Grace Rwaramba?
    A. Rwaraba. Yes.
    Q. And what was discussed at that interview?
    A. Well they were talking one over another. They were very excited. They had anticipated me coming And we
    spoke about everything from food to video games and everything in between you know. But they wanted to
    make sure that I knew how to prepare healthy meals because that was what they and their father eats and that's
    the way they eat. "We eat healthy. We don't eat any pork we don't eat any beef. Can you fix vegetarian? Daddy
    likes apricots we like fruit Blanket likes mangos." And they were very more so into making sure that I knew
    what was required for their healthy living.
    Q. And did you pass your interview?
    A. I certainly did.
    Q. OK. And did you feel like you had a connection with them at that time?
    A. Yeah. It was really interesting because it felt like immediately a bond. We were developing. It just felt like
    this is a place I need to be here. And it was a beautiful ... a beautiful beginning.
    Q. And that was approximately when that this interview took place?
    A. The end of March.
    Q. End of March of 2009?
    A. 2009 yes.
    Q. And when did you start working?
    A. The very next day.
    Q. All right. So I first want to take you through the first segment of your employment which would be the end
    of March to the end of April 2009. In your first month there as a Chef for the Jackson household can you tell us
    what your duties and responsibilities were?
    A. My duties on a daily were ... I would arrive at the home at 8:00 between 8:00 and 8:30 in the morning to get
    the kids prepared meal-wise and get their dad's breakfast ready as well. Breakfast lunch and dinner is what I
    was to prepare and snacks. And also clean up keep the pantry well stocked and grocery shop. Those were my
    duties.

    Q. And how many days a week were you at the Carolwood house?
    A. I started with seven days.
    Q. That's tough.
    A. Yeah. That was very tough. I started with seven days and then eventually moved to six days having Sundays
    off.
    Q. All right. And what were your hours? You said you came in about 8:00 or 8:30. What time did you go
    home?
    A. Around that month I would go home around ... It fluctuated. 6:00 8:00. Around those times.
    Q. Was there anything ... What had to be done before you could go home?
    A. Well clean up. You know they'd have dinner first. After the dinner was done then I'd remove the
    plates off the dinner table clean up put the dishes in the dishwasher straighten everything and go home.
    Q. Like in most households did dinner time fluctuate?
    A. Yeah.
    Q. Sometimes it could be on time and sometimes it was a little later?
    A. Depending. Depending on work schedules and things like that. But yes.
    Q. What was the normal lunchtime?
    A. 12:30.
    Q. And what was the normal dinnertime?
    A. 5:30 ... 6:30. 6:30. Sorry.
    Q. And do you remember meeting Michael Jackson for the first time?
    A. Yes. I met him about a week ... No a few days into a week later. I was at the home and he had come
    downstairs. He had some guests waiting for him in the parlor and they were getting ready to discuss his travel
    arrangements to go to London.
    Ms. Bina: objection. Hearsay. Move to strike to the extent she talks about what other people were
    discussing.
    Court: overruled.
    Q. And what was your first encounter like with Mr. Jackson?
    A. He came down the stairs. I in turn was bringing a silver platter of beverages bottled water for the guests.
    And we kind of had this introduction like bumped into one another. And I don't know if this is the way he
    wanted to meet me but we kind of looked at each other like hey "how are you" kind of like thing. And he ...

    One of the gentlemen said to him "this is your Chef" you know. "have you met your Chef before?" And he said
    "I'm meeting her for the first time." but he had been in and out of the house. So that was the first introduction.
    And after that it blossomed into a client/friendship relationship.
    Q. How often would you say he interacted with you?
    A. More so on a daily you know. He was very much hands-on in his children's life and their nutrition. So he'd
    always come down into the kitchen in the mornings in the afternoons. We'd hold conversations about healthy
    eating juicing that kind of thing. And just life. People places. He wanted to get to know the woman who was in
    the house that was feeding him and his family.
    Q. Did he seem interested in you and who you were?
    A. Yes. Yes.
    Q. All right. Did you have the opportunity during that month and also during the month of June to observe
    Michael Jackson and his children together?
    A. Yes I did.
    Q. And how would you describe that relationship?
    A. It was very loving. It was very loving and very ... They were together a lot. These children were his world
    you know. Out of all the words to all the songs in the world those children meant everything to him. When he
    would come home from maybe working in the studios back in April ... he was in the recording studio a lot ... the
    lunch would be served. He'd have lunch with his children privately at a beautifully-set table. And they'd sit
    together. They would crack jokes. They would tell stories. They'd play together in the house. But everything ...
    those children meant the world to him.
    Q. Can you describe what the household was like when you were there in April of 2009?
    A. The house was very warm. It was a good feeling a good energy of love in the home. Fireplaces in the rooms
    in the den in the parlor in the sitting room in the dining room were always going.
    Q. With a fire?
    A. With a fire. And music would play in the home. Sometimes Disney music would escalate from the echoes
    of the stairwells or something. It was a beautiful place and the energy ... It was a good feeling there and that's
    what he always wanted.
    Q. Was it always disney music or a variety?
    A. No. It was never always Disney. We played K-earth 101 in the kitchen. Like we'd hear the stones and David
    Bowie and things. And then he would have classical in other parts of the house. But you know he's a musician
    so it's quite right.
    Q. And you mentioned that he liked to have meals with his children. And did you serve the meals and set up for
    the meals?
    A. Every day yes.

    Q. And how did he like to have meals with his children? Can you describe that?
    A. He liked the meals with his children to be just comforting. I mean this is their time to bond. This was their
    time when daddy comes home from work after a busy day. This is his time with his children privately.
    Q. You said it was beautifully set. Did you have something to do with that?
    A. I set the table.
    Q. And did he like creativity in settings?
    A. Yes. He had a lot of different table cloths different creative types of napkins and glasses and plates so I
    would always try to make it fun. I'd try to make it fun and tried to make things just a beautiful setting. Change
    the color of the tables with the napkins and glasses so every time they sat down at the dinner table it would be a
    new experience.
    Q. And did you try to make it educational for the children as well?
    Ms. Bina: objection. Leading.
    Court: overruled.
    The witness: yes I did. We would sometimes eat in other parts of the country. So say for instance one day we
    would have East Indian food but we would discuss what part of you know India we were eating from. Or I'd go
    into the kitchen and I'd write the menu on a chalkboard that was sitting on the island in the kitchen of what the
    meal was for the day so the kids could understand and learn about food.
    Q. By Ms. Chang: they learned different words for food?
    A. Yeah. They would learn different words depending ... Say if I were making a potato puree soup ... And I
    remember one time Blanket he climbed up on the chair ... There was a chair around the end of the island where
    the chalkboard was sitting. So he climbs up there to read what his menu was going to be for dinner. And he said
    "A puree? What is a puree?" And I said "No. A puree of soup." so now he knows what soup puree is. So the
    education kept going.
    Q. So when you got there at 8:00 to 8:30 did you have a typical day?
    A. Well the typical day was getting what needed to be done on time and ... You know in a timely
    Fashion yes.
    Q. OK. And you indicated that the children had school. Did they go out to school or were they home-
    schooled?
    A. The children were home-schooled. And depending ... They were home-schooled from Monday to
    Friday. So every day was a different day. Mr. Jackson loved to keep it creative for them since they were home-
    schooled. So say Monday it would be reading day you know. Or Tuesday it would be more maybe arts and
    crafts day. Wednesday would be movie day. Maybe we would ... They would see a classic movie and have to
    write about that. So every day of the week was something different just to ... For educational purposes and for
    greater knowledge for them.
    Q. Did they learn creative writing?

    A. Yes.
    Q. Did they learn science?
    A. They learned a lot of skills children needed for school yes.
    Q. And math?
    A. Math science current affairs.
    Q. And foreign languages?
    A. And foreign languages yes.
    Q. And was there a teacher that came in?
    A. Yeah. They had a teacher that would come in in the mornings and leave in the afternoon. And then one of
    the days whatever day that was they would go into theater day or whatever else. But they were constantly being
    educated.
    Q. And did Mr. Jackson share with them things that they learned or discuss with them things they learned?
    Ms. Bina: objection. Lacks foundation calls for hearsay.
    Court: overruled.
    A. He would. You know the interaction and the development of a young child's mind is very important to
    children of a smaller age. So him being the father that he is he took great pride in helping develop you know
    the foreign languages or whatever they were taught in school and whatever they needed to ... What he was
    teaching them as far as film and art and that nature.
    Q. From what you observed in being at the home every day did the kids get on the internet and watch tv a lot?
    A. No. The children were not allowed to watch television. And I don't think that ... Mr. Jackson wasn't one of
    those types of fathers you know. TVs computers that was nothing that they were interested in doing.
    Q. And being in the household with the Jackson family what did you observe as to how he was as a
    father? Was it all fun and games or did they have ... Was he a disciplinarian? How would you describe it?
    Ms. Bina: I'm just going to object. Not trying to break up the flow. She said that she served meals.
    There's no foundation for a broader ...
    Court: sustained.
    Q. OK. Let me ask you a question Ms. Chase. Did you just stay in the kitchen cooking or did you spend time
    with the children throughout the entire house?
    A. Uhm I stayed a lot ... Most of the time in the kitchen doing a lot of the cooking. But it was an open floor
    plan in the home so where the kitchen was it extended to the den where the children would play a lot. So on
    some of my breaks down time I would interact with the children and play you know games monopoly and that
    kind of thing. So it kept the bond of us more like family.

    Q. And did they share things with you in the kitchen of what they were learning and what they were
    doing?
    A. Yes. Again it was an open floor plan so they could come and interact with me I would interact with them. I
    would teach them more about food and technique and they would teach me a lot about games and playing. And
    sometimes we'd go in the backyard and play on my breaks. And we had a nice time at the house.
    Q. You were like their friend?
    A. Their friend.
    Q. And from where you were in that open layout of that first floor did you have a chance to see and
    observe Mr. Jackson with his children?
    A. Yes.
    Q. And at mealtime?
    A. At mealtime sometimes because he dined with them privately. But a lot of the time in the den. He
    would go into the den and sometimes they would bring the bird. They had a bird that did a lot of talking. And
    the dog. So it was more of a family home setting there. So in the den it would be the dog and Mr. Jackson and
    the children and the bird and it was just a beautiful experience always.
    Q. And did you get to see him when he came home for example from a long day and see him greet his
    children?
    A. Yes. And that was something to cherish because seeing those children run up to their father when he would
    walk through the door of the living room ... He'd walk through the door and they would take off like lightning
    and they'd run and grab him around the ankles and around the waist and he had kids hanging. And just the love
    was the most beautiful thing you could ever see. It would bring tears to my eyes so much love there.
    Q. And from the time period that you observed them throughout the first floor and seeing them both at
    mealtime and otherwise was it all fun and games or did they have a schedule and did they ... Was he a father
    that expected them to follow the rules?
    A. He was a disciplinary when it was needed. Especially when it was school. If they had school the children
    had to be in bed at a certain time. Now as all children "oh I don't want to go to bed" they wanted to stay up but
    this was not something ... He was disciplined with being in bed at a certain time making sure they were at
    school at a certain time and on time. And they respected their father for that you know. They respected and they
    obeyed him.
    Q. And was he fun also?
    A. Oh he was fun. He was fun.
    Q. Were they allowed to eat sweets every day ...
    A. No.
    Q. ... And anything they wanted?

    A. No. That was a no-no. Sweets were only dictated when he said and that was very rare. Mondays through
    Fridays ... I remember this story if I can tell. I remember this story. I had written him a letter because I worked
    Monday through Friday Saturday and I did very healthy meals during the week. So I had written him this letter
    saying that you know possibly could we do a comfort food Saturday so that the kids and we can all eat things
    that are not so healthy like you know some fried chicken or maybe some ... And he loved it and he gave me a
    thumbs up for that. So we had comfort food Saturdays. It breaks up the monotony of always healthy eating.
    And it's good for the kids you know so that the kids don't start abusing unhealthy eating habits.
    Q. And did they look forward to that day?
    A. Yes.
    Q. Was that their favorite day?
    A. Yes.
    Q. Did they have sweets on weekends?
    A. That was very rare but a little bit yes.
    Q. OK. From what you observed did Mr. Jackson instill in his children any instruction as to how to live their
    life?
    Ms. Bina: I'm going to object. Lack of foundation on this.
    Court: sustained.
    Q. By Ms. Chang: did you observe activities that the children did in your presence for others?
    A. Mr. Jackson always made it a point ... First of all he was a very giving ... Has a very giving spirit very
    giving and loving nature. So he would always instill the property of "how do you see yourself giving back?"
    Ms. Bina: objection. Hearsay lack of foundation. Same issue.
    Ms. Chang: your honor it's not hearsay. It's not used for ... It's not even ... It's words of action it's words
    of instructional motivation rather than the truth of the matter asserted "how do you see yourself
    Giving back?" there's no truth or non-truth.
    Ms. Bina: I still haven't heard the foundation for it. Did she observe Mr. Jackson giving speeches to the
    children? Did the children repeat it?
    Court: sustained on foundation.
    Ms. Chang: all right
    Q. D you observe the children doing activities for others and hear conversations with their father regarding
    giving to others?
    A. Well when he would ask me how do I see myself giving back this is something that I know that he instilled
    in his children. And Paris the giver that she is I would observe her ... I saw her always ... She'd go get clothing
    that maybe she wasn't wearing or using anymore. And she'd sit there with a little sewing kit and she'd cut maybe
    jeans or shorts that she wasn't using anymore and cut them to make them into little skirts and hand sewed them.

    One day I asked her I said "what are you making there? That looks creative." She said "I'm making these little
    skirts that I'm going to put in a box and ship overseas and give to others that are more underprivileged." And
    that was a beautiful thing.
    Q. You mentioned that they had a bird that talked
    A. Lot. Were there a lot of animals in the household?
    A. A lot. We had a few animals and the bird was very cute. Siberia.
    Q. You said there was a dog. What kind of a dog was there?
    A. A chocolate lab.
    Q. Kenya?
    A. Kenya. And we had a bird Siberia. A. Talking bird. So cute. He whistled when pretty girls would come by
    especially me. He would go "woo-hoo" you know. So we got a kick out of that the kids and I did. And Prince
    had a rat. A rat he would walk around the house. So the kids loved animals. We had two cats. Katie and
    Thriller. Thriller was the black cat and Katie was the orange cat. And the children were very responsible in
    taking care of their pets. Feeding the ... Feeding the cat feeding the dog. Sometimes ... we went and got this
    cookbook for dogs. You know a cookbook for doggie treats. So for Kenya's birthday we made a cake just for
    the dog. You know a lot of interactive fun stuff we would do.
    Q. Now when you indicated that you would play with the kids outside did you also engage in activities with the
    kids outside regarding animals with Paris?
    A. Yes. The cats were you know outside. They had a rabbit. So she had a little dollhouse that her daddy had
    bought for her and the dollhouse sat in the grass by the little lake. So little tea parties with the animals.
    Sometimes the dog would swim with the kids when it was swim time on Saturdays. So it was just really ... just a
    family affair.
    Q. And did Paris like all animals?
    A. Yes. The children do. Mr. Jackson does yeah.
    Q. All right. And was there ever an occasion that you and Paris were looking for a science project or
    little animals that you thought you might get in trouble?
    A. Oh my goodness yeah. You know there was an incident where she and I we sort of were creating for school
    a science project for snails. So we decided to do a you know a snail hunt in the middle of the night you know.
    So she ... I was leaving work and she asked me she said "we've got to go outside to get snails. So far we have a
    daddy snail but we don't have a mommy and baby snail." So we go outside with these massive flashlights and
    we're looking for snails and we collected all these little snails. And so we're coming back up the stairs into the
    house and there stands their father. And at that point I knew I was going to get fired. It was like this is not good.
    I'm going to get fired. But he was fine. That's fine and he interacted with his daughter. "let me see what you
    have here." What we decided to do is we got glass vases put moss down put little cocktail umbrellas and we
    made a family of snails and put it in the kitchen. It looked like children lived there. We had Blanket's art
    coloring on the refrigerator door and a snail farm on one of the counters like any family would that has children.
    Q. And did Mr. Jackson get involved in putting the little cocktail ...

    A. Yes he did. Anything that was creative that way he participated in.
    Q. What was his personality like when he was home with the kids?
    A. His personality with his children was always interactive. It was always interactive. And it was always just
    warm and loving. And it was just a day to day these are my babies. These are my babies. And he engaged in
    games. He played games and we played Monopoly. And at dinnertime ... But everything was surrounded around
    his children when he came home.
    Q. Did he have a sense of humor?
    A. Yes he did. A huge sense of humor. They ... He was a practical jokester you know and that was one of the
    things that ... Because he would always catch you off guard. Especially ... I had no idea. So one time I was in
    the kitchen cooking getting ready for dinner and Paris comes into the kitchen and said "you have to come quick
    into the den. Your boyfriend is here." I knew I didn't have a boyfriend at the time so I said "OK." this will be
    interesting to see. So I go into the den where everybody is sitting and there's this huge bust from her
    (indicating) to the head of Ed Hardy kind of a manikin sitting at the bar wearing a white wife beater some Ray-
    bans and they had turned the lights down. So by the time I walked in there I see this figure but I'm not sure.
    And the lights go up and I screamed like "oh my gosh." something like that. Mr. Jackson jumps out from
    behind a chair Blanket's jumping up and down "we got you we got you we got you." and then everyone's
    laughing.
    So you know at that point I'm like OK I'm getting somebody in this house back.
    Q. And like in most homes was the kitchen a place where the whole family liked to be?
    A. Well the kitchen is the nucleus of the home. the kitchen is the nucleus of every home. People come into the
    kitchen to have camaraderie and to speak and to ... You know to generally be together. And that's how this
    kitchen was. Not ... Even though it was an open floor plan I made it a home there you know. I made it to
    where ... the energy was already good but I brought more love into it by putting the children's art and things into
    the kitchen.
    Q. Snails?
    A. And the ... But in jars yes.
    Q. I'd like to show exhibit 904. Can you tell us what that is?
    A. That's the chalkboard where I would write the menu for the day. And this right here is Paris's writing.
    Q. I'm going to show a laser there. Right there or the whole thing?
    A. The whole thing.
    Q. Can you read us what it says?
    A. "I love daddy." it was "love daddy" at the top; second line "I love daddy." "Smile. It's for free." and that's
    how the household was every day.
    Q. And in fact was this what was on the chalkboard the day that Mr. Jackson died?
    A. I can't recall.

    Q. OK. Fair enough. What kind of ... is that the kind of messages that was at the house when you were there?
    A. Well when I would erase the menu she would put something like that for just love. More love.
    Q. What kind of food did Michael Jackson like you to prepare for him?
    A. Mr. Jackson ... Considering he was getting ready for this tour he wanted to stay strong well and of course eat
    very healthy. So he did ... I did a lot of juicing for him a lot of beet juice. A. Lot of organic juicing with
    vegetables and fruits. He had a lot of lean proteins a lot of vegetables and overall nutrition throughout the day.
    Q. When you say "lean proteins" was that mostly chicken and fish?
    A. Chicken fish and turkey. No pork and no beef.
    Q. Was that the same for his children too?
    A. Same for his children yes.
    Q. OK. Did he have a particular favorite meal that you'd make for him?
    A. He enjoyed a lot of the things that I made. In particular he was very much into Mexican. He liked Mexican
    food a lot. So considering you know he wasn't doing the beef or the pork I decided to do a vegan ground beef
    tacos. So it consisted of blue corn tortilla shells vegan ground beef guacamole salsa. That kind of thing. And I
    remember making the plates for him where he had three tacos. Prince always wanted to be like his Dad so he
    wanted the same portion the kids had less. But he was biting into the taco and he couldn't believe ... He said
    "are you sure it's not beef? It's amazing." so you know that was one of the favorites that I would repeatedly
    make a lot.
    Q. And just to torture us a little can I show
    Exhibit 905 Is this the famous tacos?
    A. Those are the tacos.
    Q. And that was his favorite meal?
    A. That was one of his favorites yes.
    Q. Did the kids like it also?
    A. Oh yes. The kids loved that.
    Q. Now in April of 2009 which is the first full month that you worked there did the family celebrate a birthday?
    A. The family celebrated Paris's birthday.
    Q. And I think you said it was her 11th birthday?
    A. She was turning 11.
    Q. And what day was that?

    A. It was a Friday I believe. Yes.


    Q. And was that the first week of April?
    A. Yes.
    Q. All right. And can you tell us about that birthday party? Well first let me ask you: what happened on that
    day? What kind of event did you have planned?
    A. Well that day was ... Since it was a birthday it was ... Mr. Jackson had told his children "you can eat
    anything you want today. It's your birthday." And considering we're having a birthday party at the house we
    decided to decorate the dining room into the theme that she wanted. And what she wanted was ... Her daddy
    was the theme of the birthday. So we scrambled around putting up Michael Jackson posters and album covers
    taped to the walls and decorated the table very pretty with colored glass and balloons everywhere and played his
    music because this is what she wanted for her 11th birthday. So when she came in and she was surprised with
    the surprise happy birthday there was cheese pizza and hot wings and banana splits and just things that kids love
    that they don't eat on the norm you know. So this was a big you know celebration.. They ate you know they had
    a great time.
    Q. Did she have a birthday cake?
    A. She had a birthday cake.
    Q. What did she want on her birthday cake?
    A. Well at the time her favorite was Lilo & Stitch the cartoon Lilo & Stitch. So we had a cake designed by
    Hansen's cakes. And it had the Lilo & Stitch on the front and she was ecstatic. So they ate. They had a beautiful
    time. And just when you thought that wasn't enough he took his children to the backyard which he had this
    whole setup of a beautiful Cirque Du Soleil type performance for her.
    And I just remember looking out the kitchen window at this performance where it was just ... brought tears to
    my eyes. It was him and his children. They walked down the stairs and there were gentlemen on stilts and a
    woman in a big balloon like a circus act. And they sat there and they watched this private circus For her
    birthday and I cried.
    Q. Why did you cry?
    A. Because it was the most beautiful expression of love I've ever seen.
    Q. And that was the last birthday Paris had with her father?
    A. That was the last birthday she'd had with her father.
    Q. And you're working for them now. Do you know if she's ever had a birthday party like that since?
    A. No. Paris hasn't had any birthdays since.
    Q. She doesn't want to celebrate?
    A. She doesn't want to celebrate that way.
    Q. Now in April 2009 how would you describe Mr. Jackson's appearance as far as his health and
    Energy level?

    A. In April?
    Q. In April.
    A. Mr. Jackson was very ... He was very upbeat. He was very excited about what was to happen about the tour
    about having his children see him perform this greatest comeback tour. He'd come down in the kitchen
    sometimes and speak to me and talk to me a whole conversation. He would be dressed sharp. He would have
    black Levi's on and a tweed blazer glasses on Tom Ford cologne. Just energized and the Michael Jackson that I
    know him to be.
    Q. And you said that he sometimes went to the studio. Did you ever see or observe him creating music in the
    house?
    A. They had a studio ... He had a studio set up ... There was a guest house on the property so they turned that
    guest house into a recording studio.
    Q. Did you go there?
    A. Sometimes I went back there to bring him his meals because he would be back there getting the album ready
    and laying down tracks or you know hearing tracks over. So I'd go back there. Got a chance to listen to some of
    the tracks feed him his food. And he would actually ask "how does this sound to you? I'm excited. It's going to
    be the best comeback tour." So I was privy to some of that at the time.
    Q. And were you asked by him or the family to go with them to London for the "This Is It" tour?
    A. I was asked ... Prince actually told me that his Daddy wanted me to go. And he said "Daddy wants to know
    if you would accompany us to London as the Chef?" And I was honored for that and graciously said "yes."
    Q. Were the kids excited too?
    A. Yes they were excited. They wanted me there.
    Q. Did you ... You said you tried to make foods in other countries. Did you turn to British food?
    A. We did a little bit of that. Getting ready to go to London we did a couple of the shepherd's pie. We did some
    fish and chips. We practiced our British Cockney accent. So we had fun getting prepared for the flight and the
    trip over there.
    Q. And around this time period Paris's birthday and for the first two weeks of April was the nanny
    Grace Rwaramba also there?
    A. Grace was there the first week or two of April and then I didn't see her after that.
    Q. OK. And did you observe Grace's relationship with the children?
    A. Yes.
    Q. And did you gain an understanding of how long she had been their nanny?
    Ms. Bina: objection. Relevance.

    Court: overruled.
    A. Grace and the children's interaction was very warm and loving. This is the mother that they knew. This is the
    mother that ... She had been with the children and with Michael for years. She was there when they were born.
    So this is the mother that they knew and they treated her as such.
    Q. Did there come a time when you learned that Grace had been terminated by AEG live?
    A. Yes.
    Ms. Bina: objection. Lacks foundation.
    Court: sustained as to ...
    Q. Did you gain some knowledge while you were working there that Grace Rwaramba the Nanny ...
    A. Right.
    Q. ... Had been terminated?
    A. Yes I did. I was told that she had been let go.
    Q. OK. And were you told by which entity?
    Ms. Bina: objection. Calls for hearsay.
    Court: it does. Sustained.
    Ms. Chang: all right.
    Q. Did you ever learn why Grace had been terminated?
    A. No.
    Ms. Bina: I'm going to object on the grounds in the motion in limine.
    Court: I'm sorry?
    Ms. Bina: the motion in limine.
    Ms. Chang: can we have a sidebar your honor?
    Court: OK. Let's have a sidebar.
    Q. Did there come a time Ms. Chase when you were also let go?
    A. Yes. I was let go in May.
    Q. OK. And when in May?
    A. The beginning of May.

    Q. All right.
    A. First week in may.
    Q. Can you tell me the circumstances of how you were laid off?
    A. I was let go by Mr. Michael Amir. At the time they were preparing I believe for an earlier departure to go
    over to London and they were trying to make sure of the different employees that were going to be
    accompanying Mr. Jackson. So at the time I knew I was one of the ones and I mentioned to Mr. Amir you
    know. He had asked me "what is your situation with pay to go overseas?" So he had discussed a pay rate with
    me and he said "OK. Let me get that approved." He comes back and he lets me know that "there's been a
    change in management and you therefore are not going." I begged and I pleaded with him. I even said to him
    "my rate's negotiable at this point. I have been getting Mr. Jackson ... Feeding him healthy and his children
    healthy and getting him ready for this tour. So my rate's negotiable. You have to work with me." That wasn't
    the case. He said to me "Sorry. We're letting you go. There's a change in management. There's nothing I can do
    about it."
    Q. Did he indicate to you what that change in management went from to what?
    Ms. Bina: objection. Calls for hearsay.
    Court: sustained.
    Q. What was your understanding of the change of management?
    Ms. Bina: same objection. Calls for hearsay.
    Court: sustained.
    Q. And was it in preparation for the "This Is It" tour?
    A. It was in preparation for the "This Is It" tour yes.
    Q. Were you told this in person or over the telephone or by e-mail?
    A. I was told this on two occasions. first I was told that ... In person "let me see what I can do if it's negotiable."
    Then the next day I was coming in to work. I was getting in the car to drive to the home and I got a phone call
    from Mr. Amir saying "there's no need to come in. We're not going to use you. You're fired." And I asked him
    why. And once again you know "there's a change in management. We're going to get someone else."
    Q. All right.
    A. And I pleaded with them. "these are the hands that feed him and his children. You cannot do this."
    Q. Did you ever get to say goodbye to the children?
    A. No I did not.
    Q. Or Mr. Jackson?
    A. No.

    Q. And did you ever have a personal discussion with Mr. Jackson about all of this the salary any of that?
    A. No I did not.
    Q. During this time period that you worked in April did you receive your pay on a regular basis?
    A. No I did not. The pay was very sketchy. sometimes I would be paid on time; sometimes I wouldn't get paid
    at all.
    Q. And did you ask Mr. Amir for an explanation for that?
    A. Yes I would. And he would always say to me "just be patient. Everyone hasn't gotten paid either" Which I
    didn't believe. But you know what could I do?
    Q. Did he also attribute that to the change of management going on?
    A. Yes he did.
    Q. OK. And do you know whether or not Mr. Jackson knew that you were let go?
    A. I believe he did not know.
    Q. And why do you say that?
    A. Well because that wouldn't ... I don't believe that that would happen in that way.
    Q. And in fact when you came back did he indicate to you whether he knew you had been let go?
    A. No he did not.
    Ms. Bina: objection calls for hearsay.
    Court: overruled.
    A. No he did not.
    Q. By Ms. Chang: did he tell you he knew?
    A. No. When I came back ... I came back in June and the way I came back is the kids and Mr. Jackson were
    requesting me to come back. I don't even believe that he knew that I was gone. But the kids were requesting he
    was requesting me to come back. And by the time I did come back at the top of June he came to me and pulled
    me to the side and said "I had ... Where have you gone? I had no idea that you left. I need you to keep me
    healthy. I need you to keep me and my children healthy."
    Q. Did he ask for your help?
    A. He asked for my help. He said "I need you to keep me healthy. I'm working hard. They're killing me. I need
    you to keep me healthy."
    Ms. Bina: I'm going to object and move to strike all of that as hearsay.
    Court: overruled.

    Q. All right. before we get into that Ms. Chase let me ask you this: you were let go during that first week of
    May. Did you work at all in the Carolwood house in May?
    A. No I did not.
    Q. Did you ever see Mr. Jackson at the Carolwood house in may?
    A. No I did not.
    Q. Or the children?
    A. No.
    Q. OK. How was it that you were asked to return in June of 2009?
    A. In June the beginning of June I received a phone call from Michael Amir the same one who hired me and let
    me go. I received a phone call from him saying that "Mr. Jackson and the children are requesting you to come
    back. The energy in the house is not the same."
    Q. Now first I want you to ... The time that you left Mr. Jackson in April you described him as upbeat. How
    would you describe his physical condition when you last saw him?
    A. In April?
    Q. Yes.
    A. His physical ... He was strong. He was healthy he was active. He was interactive with a lot of us.
    And ... Yeah. He looked good.
    Q. All right. now before I get into June did you reach an agreement with Mr. Amir on your new pay terms on
    the tour?
    A. Yes. When we spoke on the phone about my return I spoke to him about me possibly getting ... you know
    what my wages would be to come back and me possibly getting half of my salary upfront as ... because I was
    very nervous about not getting paid again.
    Q. Did you write him an e-mail?
    A. I wrote him an e-mail and put all of this in writing just to make sure we were on the same page.
    Ms. Chang: all right. Let's just show counsel 627-27.
    Ms. Bina: I object to this your honor as hearsay and irrelevant.
    Ms. Chang: your honor can we have a sidebar?
    Court: Don't ... let me look at it first.
    Ms. Chang: OK.
    Court: (looks at document) Is that the totality of it?

    Ms. Chang: yes. There's also a reply from Mr. Amir which I can show you now.
    Court: OK.
    Ms. Chang: 627-28 just for the judge and counsel please.
    Court: (looks at document) OK. Your objection?
    Ms. Bina: it's hearsay your honor and irrelevant.
    Court: I wouldn't say irrelevant but it could ... hearsay.
    Ms. Chang: can we have a sidebar your honor?
    Court: all right.
    Ms. Chang: or do you think this would be ...
    Court: let's go to sidebar.
    Ms. Chang: OK.
    LUNCHBREAK
    (hearing in open court, outside the presence of the jury):
    Ms. Chang: I am happy to report, your honor, that Ms. Stebbins and I met, we conferred, and we agreed and
    stipulated to I'm going to ask a series of three questions. The first one will be leading by stipulation, and to work
    out our deal, no emails will be shown, but the question will be asked as per agreed. And then I will go into two,
    and then move on to another area. So we're all in accord. And I did have a case -- I had a case that I shared with
    her, and it's all good.
    Ms. Stebbins: The case I think was actually on a different issue, but we've agreed on the factual
    foundational problem and we've got an answer.
    Judge: Okay. And the witness is aware of what she --
    Ms. Stebbins: So I've been told.
    Ms. Chang: By agreement, I said I'm going to go and make sure we had no problems, and she
    understands.
    Judge: Okay.
    Ms. Chang: And I got an assurance that there will be at least three questions that will not have an
    objection.
    Judge: Okay. I think you said that would end the examination, or --

    Mr. Panish: No.


    Judge: No. There's more. You just said you were done with that area?
    Ms. Chang: That area, yes.
    Mr. Panish: Okay. So tomorrow, we're coming in after -- the afternoon, right? Because judge has a
    busy calendar in the morning, correct?
    Judge: Is that what we decided?
    The Clerk: I thought we switched Friday for tomorrow, Friday half day for tomorrow.
    Mr. Panish: Right, right. But only in the afternoon.
    The Clerk: Yes.
    Mr. Panish: So then we really have only the video of Finkelstein, but it looks like potentially that Ms. Chase
    could carry over. I want to let judge know that. And then Thursday, I guess, we're going to have to start a little
    later because a juror has an interview, so it's possible --
    Judge: 10:30, I think she said she'd be here, at the earliest.
    Mr. Panish: So it is what it is. So thursday's witnesses potentially do carry over to friday, but Ms. Faye, we still
    have to be here whenever that witness is done to go right on on Friday.
    Judge: Well, I think if we're not done with whatever witness is on the stand, we should proceed with Ms. Faye
    just so we can get her done.
    Mr. Panish: The problem is he's coming from Boston, a doctor.
    Judge: That's all right.
    Mr. Panish: Well, he's going to have to go back to Boston and come back again.
    Judge: No. He'll just stay in LA. And follow after Faye. How much longer --
    Mr. Panish: Mr. Putnam thinks he could be a day with Ms. Faye.
    Mr. Putnam: Yes. That's what I said always.
    Judge: What's wrong with the doctor waiting a day to go back to Boston, right?
    Ms. Stebbins: Stay in town over the weekend, I think is what she's --
    Mr. Panish: Well, I haven't -- I haven't -- I don't know the -- I assume he's teaching class, I assume he's busy,
    but I will check on it. But depending how much time is left, if Ms. Faye doesn't finish, she's going to have to
    come back, I understand that, but we have a full day. I guess I shouldn't have even brought it up. Let's just wait
    and see what happens.
    Judge: I think that's a good idea.

    Mr. Panish: I was just trying to anticipate the schedule, so -- anyway.


    Judge: Was Ms. Faye -- was cross examination commenced?
    Mr. Putnam: I had just started.
    Mr. Panish: They did a half day.
    Ms. Stebbins: She was two full days of testimony.
    Mr. Panish: No, she was not.
    Ms. Stebbins: He got in a couple of hours. I have the numbers somewhere actually tallied up, how many each
    side. But just to have -- but there's a substantial amount of time on direct. Cross had begun, and it had gotten
    partially under way, and I think it was the afternoon, and then --
    Judge: Okay.
    Mr. Panish: I'm not at this time yet arguing with how much time he has. Obviously, we'll wait and see, but I've
    never objected they're taking too long. We'll see what he does. But he had begun, and he says he has a day, so
    we'll just see what happens.
    Judge: Okay.
    Mr. Panish: She was not on for two days, I recall.
    (back to open court, in presence of jurors)
    Continued direct examination by Deborah Chang:
    Q. Ms. Chase, before the lunch break, we were discussing you coming back to the Jackson household. Let me
    ask you, did you decide to come back because you understood that AEG Live would be covering your salary in
    England?
    A. Yes.
    Q. All right. And were you given a form thereafter to fill out for the UK entry permit by Mr. Amir?
    A. Yes, I was.
    Q. And what was your understanding of who that request came from to fill these papers out?
    A. My understanding was that was from AEG.
    Q. Okay. And that was the tour promoter that you understood it to be?
    A. Exactly.
    Q. Okay. So after you had a deal, so to speak, did you return to the Carolwood house?

    A. Yes, I did.
    Q. And could you tell us approximately when you did return to the Carolwood house?
    A. I returned June the 2nd.
    Q. All right. Now, previously I had asked you what Mr. Jackson was like when you had left in April, and now
    I'm going to ask you did you notice any difference in Mr. Jackson in June of 2009 from the last
    time that you had seen him.
    A. Yes. I noticed that Mr. Jackson -- he looked very different.
    Q. How did he appear to you?
    A. He appeared very -- very weak. He looked very much thinner, he looked undernourished, and he
    didn't look as well as I had seen him in April.
    Q. Would you say that the -- this was a subtle difference or an obvious difference?
    A. It was an obvious difference.
    Q. Okay. Did it alarm you?
    A. Yes, it did. It concerned me greatly.
    Q. Did you talk to Mr. Jackson that first day?
    A. Yes, I did.
    Q. Did he give you any specific instructions?
    Ms. Stebbins: Objection, hearsay.
    Ms. Chang: Actually
    Judge: Is it concerning nutrition, or
    Ms. Chang: Yes.
    Judge: Overruled.
    A. He came to me and he asked me -- actually, he told me -- he said, "I need you to keep me healthy. I don't
    know why you left, I don't -- I need you to keep me and my children healthy." I looked at him with great
    concern, and I felt bad, but he -- he was saying, basically, "I need you to take care of my health and feeding me
    healthy and feeding my children healthy. They're killing me." So when he said that to me, I thought that he was
    being overworked, he was over rehearsed.
    Ms. Stebbins: I'm going to object and move to strike the portions that don't relate to her instructions,
    specifically, "I need you to keep me and my children healthy and they're killing me." That's hearsay.
    Judge: Okay. Motion granted, the answer is stricken.

    Ms. Chang: Your honor, just in response to that, she had already testified that he said, "They're killing
    me," and it's actually not hearsay because whether or not they were killing him or not, it's just his state
    of mind and physical condition at that time, pursuant to --
    Judge: Motion granted. The answer is stricken.
    Ms. Chang: Okay. I have a case for later, but -- I will provide it.
    Judge: Okay.
    Q. In any event, when you came back and you noticed these changes in Mr. Jackson and you talked to him, did
    you assure him that you would try to keep him healthy?
    A. Yes. Actually, I said to Mr. Jackson -- he asked me, he said, "Do you have my beet juice ready? Do you have
    my juices ready? You know, I need you to keep me healthy, I need to be strong for this tour." and I said to him,
    "Yes, I do. As a matter of fact," and I started naming off a string of different juices that I had already prepared
    when I got there. And he was getting -- he sounded excited. He said, "That's what I'm talking about. That's it.
    Tell me more. Tell me more," that kind of attitude.
    Q. Now, did you notice any changes in the pantry when you got there?
    A. When I arrived at the home, you know, the first thing a chef does, checks out the environment, checks out
    what's needed for grocery shopping. The pantry was bare. There was two sides to the pantry. One side, I stored
    all the Fiji waters. Fiji is a very high-end water. Large, medium and small bottles. There were none. On the
    other side of the pantry lined were like pantry goods and staples. They were gone. And the refrigerator was
    bare. There were coca-colas, Red Bull and Starbucks coffee drinks, which I know Mr. Jackson was not
    drinking, or his children, because I never bought those items.
    Ms. Stebbins: I'm going to object, lacks foundation as to whether Mr. Jackson and his children were
    drinking those items.
    Judge: Sustained.
    Q. Had you ever seen in the time period that you were there any of the children or Mr. Jackson drink Red Bull?
    A. No, never.
    Q. All right. And so did you go to the grocery store to restock the pantry and the refrigerator?
    A. Yes, I did. I went to the whole foods market, is where I shop most of the time to buy all the
    organic ingredients for him and his kids. While there, shopping -- two full carts of groceries. Now, working
    there, I had a credit card which whole foods provides for chefs for private -- private clients.
    It's called a shopping for others account. And what they do is they put a credit card on file, the actual chef is a
    signer on the card, so whatever would be the limit for that day, that's it, you sign your name and you go. So I
    got to the check-out, pulled my -- pulled the account up, tried to sign for it, the credit
    card was declined.
    Q. Okay.
    A. So at that point, I had no other choice but to pull out my own money and pay for the groceries to feed him
    and his family.

    Q. All right. And did you try to ascertain later why the credit card was declined?
    A. Well, I had asked Mr. Amir what was going on. That was the first time. But it happened a few times after
    that again.
    Q. Okay.
    A. And I never had an answer. "Don't worry about it." Sometimes I'd have to leave the groceries at the market
    and couldn't come home with groceries, or I'd pay for them myself, or get what I could sparingly and bring it to
    the house.
    Q. All right. And this change in Mr. Jackson that you observed, did you observe anything while you
    were there in June that indicated to you that he was having difficulty going upstairs or being in pain?
    Ms. Stebbins: Objection, leading.
    Judge: Overruled.
    A. Mr. Jackson, with his rehearsals and his schedule, I could see that it was taking a toll on him. And, you
    know, one day I did observe his son Prince, the eldest, actually having to help him up the stairs into the den area
    where the children would play. At that point, he looked very thin, he looked very weak. And for a 12-year-old
    to be trying to carry his father into an area to still play with them like they used to, what they used to do back in
    April, it saddened me, and I knew that I had -- I had to get this man as healthy as possible, but I did not know
    why he was deteriorating this way.
    Q. Did you ever see Mr. Jackson need his son's help going upstairs in April?
    A. No, never.
    Q. Did you share your concerns with anyone?
    A. I shared my concerns with my parents, because it was concerning me. I didn't know who I could talk to at the
    home, so -- but my -- it concerned me, so I talked to my parents about that a lot.
    Q. Did you have the same type of conversations with Mr. Jackson in June as you did in April when you
    talked about food and music and family?
    A. Well, the conversations became very -- well, they weren't limited, but they were very far and few in between,
    knowing that his rehearsal schedule was so intense that we didn't have as much of upbeat
    conversations as we did in the past.
    Q. Now, I asked you about Mr. Jackson's reaction when you came back. Were the children glad to see you
    back?
    A. The children were excited to see me. As a matter of fact, the day that I did come back, they greeted me at the
    door and were happy to see me. Paris had created a beautiful box called -- it was a shoe box called the Box of
    Happiness.
    Q. Did she make that herself?
    A. She made it herself.

    Ms. Chang: Okay. I'd like to just show counsel exhibit 907.
    Ms. Stebbins: That's fine.
    Ms. Chang: Okay. Let's show that.
    Q. All right. Is this the Box of Happiness that Paris made you?
    A. Yes, it is.
    Q. Okay. And what was inside the Box of Happiness?
    A. What was inside were a lot of little stuffed animals and coloring books and bubbles and things that we used
    to play with together. So it was kind of like, "Glad that you're back, let's pick up where we left off, we missed
    you, we love you."
    Q. Did you make it a practice of keeping things from the kids in this Box of Happiness?
    A. No.
    Q. Okay. Did they write you notes periodically?
    A. They would write a lot of notes, a lot of thank you letters. Again, these children were very -- very much
    givers.
    Q. Okay.
    A. And very -- they appreciated and understood --
    Ms. Chang: Okay. Exhibit 908.
    Ms. Stebbins: The only thing I would ask on 908 is the foundation as to when it was created.
    Ms. Chang: Yes, that's my first question.
    Ms. Stebbins: Before we show it.
    Ms. Chang: Let's show the witness exhibit 908, please.
    Judge: Can I see it, too?
    Ms. Chang: Of course.
    Q. Looking at the screen, do you recognize this letter?
    A. Yes.
    Q. And what month was this written in, in April or June?
    A. June.

    Ms. Chang: Okay. And do you have any objection?


    Ms. Stebbins: No.
    Ms. Chang: Okay. Let's show this. There we go. Okay.
    Q. And do you want that blown up, or can you read it to us? First, tell us, who is this note from?
    A. It's from Paris Jackson.
    Q. Okay. And can you read that note to us?
    A. This says "Dear Kai, thank you for those beautiful gifts you gave us. Oh, and I'm writing this letter with
    the magic wand pen you gave me. I hope you like the presents and the pictures, and thank you for the
    presents for P.," Prince, "B.," Blanket, "and Daddy. They like them. Lots of love, Paris Jackson.
    P.S., The theme of Pirates of the Caribbean is called 'He's a Pirate' from the first movie."
    Q. Okay. Can you tell us what led to this letter?
    A. Actually, this kind of began when I had all seven days I was working, and when I finally was able to have
    my first day off, I went to Disneyland, which is one of my favorite amusement parks, so -- so I went to
    Disneyland, and I brought the kids back some gifts. As I said, you know, they were home
    schooled, and they stayed a lot in the home, and we played a lot, so I brought back magic wand pens and a lot of
    books on art, literature, and -- artistic books from Disneyland. So that's what that was. She's thanking me for the
    pen I gave her. And the gift I gave to Mr. Jackson was a table book, "The Art of the Pirates of the Caribbean,"
    because he was very much into art and the type of mystical pirates thing.
    Q. Did the family like "Pirates of the Caribbean"?
    A. That's when the movie came out, as -- close to when the movie came out, so we had a debate. It was Paris
    and I and the Dad. So we wanted to know who was -- this is how smart these kids are. We wanted to know who
    was the musical composer for the theme of Pirates of the Caribbean. So my answer was Hans Zimmer, and
    Paris says, "No, Daddy says it's Klaus Badelt." So Michael was right, of course. And that's why she put that at
    the end.
    Q. Is this typical of the kind of note she would write you?
    A. Yes.
    Q. And did you keep them all?
    A. Yes, I have.
    Q. All right. We can take that down. Thank you, josh. In addition to Mr. Jackson's -- you indicated that he
    looked thinner, that he looked like he'd lost weight or undernourished, I think is what you said. Did you notice
    any change in his appetite in June compared to April?
    A. Mr. Jackson did eat, but his portions were smaller. They were getting smaller. He made it a point to always
    eat with his children. That was always the important part. But his portions were smaller, and I did a lot of
    juicing for him.
    Q. Now, in April and in June when you came back, did you ever see Travis Payne at the house?

    A. Yes, I did.
    Q. Okay. Do you know who Travis Payne is?
    A. Yes.
    Q. And were you introduced to him?
    A. Yes, I was.
    Q. And what was your understanding of who he was?
    A. He worked with the choreographer, Kenny Ortega.
    Q. Okay.
    A. And he was part of the dance team.
    Q. All right. And how many times did you see him at the house?
    A. A few times, a couple of times. Sometimes the dance team would come and show Mr. Jackson what
    They have done in order -- for production.
    Q. All right.
    A. Yeah.
    Q. And did you ever see Mr. Payne and Mr. Jackson rehearse at the house?
    A. Yes, I have.
    Q. Okay. How many times would you say?
    A. Once.
    Q. Okay. Only one time?
    A. Yes.
    Q. All right. Now, I want to ask you, during the time period that you worked at the Carolwood
    house -- I think this is total time, end of march, April, and then when he came back in June -- did you
    ever meet Dr. Conrad Murray?
    A. Yes, I did.
    Q. When did you first meet Dr. Murray?
    A. In April.
    Q. Do you know approximately when in April?

    A. The first few weeks in April.


    Q. Okay. And how was it that you met him?
    A. He introduced himself to me as Michael's personal physician.
    Q. All right. And then would you say that you saw him more on a daily basis in April or in June?
    A. I saw him more daily in June.
    Q. Okay. Was Dr. Murray ever at the carolwood house in April in the evenings?
    Ms. Stebbins: Objection, lacks foundation. The witness has testified she left the premises at 8:00 pm.
    Ms. Chang: Let me clarify that.
    Q. While you were there, did you ever see Dr. Murray's -- present in the house in the afternoons to the evenings
    until the time that you left?
    A. In April?
    Q. In April.
    A. It was very -- he wasn't around as much in April.
    Q. Okay.
    A. Yeah.
    Q. Now, in June, were there times when you came to the house and you saw his car already there?
    A. Yes.
    Q. And based on conversations with him, did you gain an understanding that he was spending the night in June?
    Ms. Stebbins: Objection, calls for hearsay.
    Judge: Sustained.
    Ms. Chang: All right.
    Q. Did you ever see his car present at the house when you got there in April?
    A. No.
    Q. Okay. Did you ever observe Dr. Murray treating Mr. Jackson as a doctor in any way?
    A. No.
    Q. All right. Did you ever see him bring anything to the house in April?
    A. I never saw him bring anything to the house. The majority of the times when I would see Dr. Murray would

    be in the mornings when I had gotten there. So to me, it was apparent that he had been there, he had been there
    earlier or he was there the night before.
    Q. Okay.
    A. So I would see him come down the stairs in the morning because he'd come down into the kitchen
    area.
    Q. Is that in June?
    A. In June.
    Q. All right.
    A. In June --
    Q. Now, let me ask you, in June, did you ever have conversations with Dr. Murray at any time in which you
    discussed any instructions from him regarding the nutrition or Mr. Jackson?
    A. No, and I thought that was quite strange.
    Q. Why?
    A. Well, for a doctor to have a patient there, and you don't consult with their chef of eating habits or, you know,
    nutrition? It was quite strange to me.
    Q. Did you ever ask him if there was anything you should be doing?
    A. I'd asked him a couple of times, but his answer to me would always be, "You can fix him
    anything."
    Q. Okay. And in the time period that you were there, was there ever nutritionist at the house?
    A. No.
    Q. And in the time period that you were there, did Dr. Murray ever make a protein shake?
    A. No.
    Ms. Stebbins: Objection, lacks foundation as to whether Dr. Murray ever made a protein shake. She can
    say whether she saw one.
    Q. I said in the time period that you were there, did you ever see Dr. Murray make a protein shake in your
    presence?
    A. No, I never.
    Q. Did Dr. Murray ever request that you make any special type of protein shake?
    A. No.
    Q. All right. When you came back in June, did you see Dr. Murray every day in the house?

    A. In the mornings.
    Q. All right. Did you see him at any other times?
    A. No.
    Q. Okay. And did you ever ask Dr. Murray what he was doing at night, or --
    A. No. It was -- no, I never asked. It was none of my business.
    Q. Okay. Did you ever go upstairs in the house?
    A. No.
    Q. All right. Is there a reason?
    A. My room was the kitchen, and that open floor plan -- which is where I was, so there was no reason for me to
    go upstairs.
    Q. All right. I want to show you -- and counsel has already told me she doesn't have a problem with this, but let
    me ask you before I show you this picture, did you ever see Dr. Murray in June bring oxygen tanks either to the
    house or from the house to any location?
    A. I saw Dr. Murray bring oxygen tanks down in the morning, down the stairs into the kitchen.
    Q. Okay.
    A. And sometimes I'd see them lined up in the security booth. There was a security booth that was on
    the property, and I'd go back there sometimes to print out my -- to print out menus or whatever else, and I'd see
    them lined up against the wall with a sign that would say "fill up every Friday." and then I'd observe them
    sitting in the foyer by the front sometimes.
    Q. All right. Did you see oxygen tanks in the house in April?
    A. No, I did not.
    Q. All right. And when I say "oxygen tanks," I mean the ones lined up in the security booth with a sign that said
    "fill up every Friday."
    A. The same ones.
    Q. Okay. You didn't see that in April?
    A. No, I did not.
    Q. Okay. Now I want to show you exhibit 5, dash, 2438, which is from the LAPD -- police. If we can go ahead
    and show that. All right. And is this the -- are these the oxygen tanks that you observed lined up by the security
    booth?
    A. Yes.

    Q. Okay. And they're large tanks?


    A. Yes.
    Q. And are they visible to anyone coming to the house?
    A. Yes.
    Q. Okay. Would you take that down. And did the oxygen tanks concern you in any way?
    A. Yes, I was concerned. I had no idea what they were used for, I didn't ask, but it was strange.
    Q. Did you think it was strange that there was a doctor there every single day?
    A. Yes.
    Q. Did you think it was strange that there was a doctor there every single day and seeing Mr. Jackson
    in the condition that he was?
    Ms. Stebbins: Objection, leading.
    Judge: Overruled.
    A. Yes, I did. I -- I felt that it was strange that there was a doctor there but he's slowly deteriorating. I didn't
    understand that.
    Q. All right. Now, when you came back to the house in June, were you ever present when meetings took place
    between Mr. Jackson and anyone from AEG Live at the house in Carolwood?
    A. Yes. There was one meeting that took place when I was there when I returned with the participants of Paul
    Gongaware, Randy Phillips, Dr. Murray,
    Q. And Mr. Jackson?
    A. And Mr. Jackson, yes.
    Q. Okay. And had you met these gentlemen before?
    A. Yes, I have.
    Q. And they had introduced themselves to you?
    A. Yes.
    Q. All right. Were you given any instructions by Mr. Jackson prior to the meeting?
    A. Mr. Jackson asked me to fix snacks. He had guests coming, can I fix a little bit to eat for them, and that's
    what I did.
    Q. All right. And do you know -- can you pinpoint for us, or approximate, when this meeting was in June?
    A. This meeting had to be around maybe the first or second week in June, something like that.

    Q. Okay.
    A. His manager was also at attendance in that meeting, his former manager or manager, Frank Dileo.
    Q. Oh, Frank Dileo?
    A. Yes.
    Q. And were you introduced to him, too?
    A. Yes.
    Q. And you knew who he was?
    A. Yes.
    Q. And he was present during this meeting?
    A. Yes, he was.
    Q. All right. And where did this meeting take place?
    A. The meeting took place in the room he called the parlor.
    Q. The parlor?
    A. Which was closest to the front of the house.
    Q. Okay. And were you in the parlor, in and out the parlor, during the time that the meeting took place?
    A. Yes.
    Q. And why is that?
    A. I was bringing beverages and food and napkins, that kind of thing.
    Q. Would you also come back there to refill beverages?
    A. Yes, yes.
    Ms. Chang: All right. Now I just want to show -- let's show counsel first 930, dash, 1.
    Ms. Stebbins: It's fine.
    Ms. Chang: Okay. Let's show that. All right. Let's just zoom in just a titch there. And I just want to see --
    Q. Can you tell us -- we just took out some part of it, but let me ask you this. What part of the house are we
    seeing in this exhibit?
    A. This is the hallway -- the hallway leading to the back yard.

    Q. Okay. So as I'm looking at this photograph, the doors that I'm seeing up in the front -- or the back, I should
    say, that's actually pointing to the back of the house?
    A. Yes.
    Q. Okay. There's a laser light in front of you, and if you push it once, it will be a light, but if you push it twice,
    it will stay on. Can you show us where, approximately, in this house the kitchen is?
    A. The kitchen was right around this corner right here, right down there.
    Q. Okay. And the area that you're calling the parlor, where is that?
    A. Right here.
    Q. Okay. Except I'm sure it had furniture in it.
    A. Yes.
    Q. All right. And this is where the meeting took place?
    A. Yes.
    Q. And you'd go back and forth from the kitchen?
    A. Right.
    Q. Okay. Now, when you came to the living room and when you were present, what did you observe? Well,
    first of all, did you observe Mr. Dileo, Mr. Phillips, Mr. Gongaware in the room before Mr. Jackson came
    down?
    A. Yes. I actually answered the door. Mr. Jackson would have me act as -- you know, as a hostess or a
    butler, as you would call it, to answer the door for his guests while he came -- before he came down. So I
    actually had an opportunity to seat the gentlemen, ask them if they needed any beverages, I was bringing out
    food, whatever else. So by the time he came downstairs, they were already sitting.
    Q. Okay.
    A. They were already sitting there.
    Q. And were you there when Mr. Jackson entered the room?
    A. Yes, I was.
    Q. And can you describe Mr. Jackson? First of all, what was he wearing when he came down and entered the
    room?
    A. Mr. Jackson was very covered up. He had a surgical mask on, and layers of clothing, layers -- sweat pants,
    shorts over the sweat pants, t-shirt, sweatshirt over that.
    Q. Had you ever seen him wear a surgical mask before?
    A. No.

    Q. Do you know why he had on a surgical mask?


    A. No, no.
    Q. Did his appearance alarm you?
    A. Yes, it did.
    Q. And why is that?
    A. Well, because I've never seen him in that -- that state before.
    Q. All right. In addition to his physical appearance, can you describe what you observed in his emotional or
    mental state?
    Ms. Stebbins: I'm going to object to the extent it calls for hearsay. Obviously, she can testify to her
    observations.
    Judge: As to her observations, okay.
    Mr. Panish: What's the question?
    Q. What did you observe in Mr. Jackson?
    A. I observed that he looked scared.
    Q. Why do you say he looked scared?
    A. He looked -- he just looked scared and frightened about maybe, perhaps, what this meeting would entail.
    Q. Did he look great to you?
    A. No, he did not.
    Q. Did he look fabulous to you in this meeting?
    A. No.
    Q. Okay. Did you hear anything break during this meeting?
    A. When Mr. Jackson came downstairs, and I went to go sit -- seat -- sit with his guests, I immediately heard a
    loud crash. He had a very, very expensive vase that sat right behind the chair where he
    would sit in, which was very close to the opening of that archway of that room.
    Q. Do you want to kind of point to us so that we can see?
    A. Sorry. Right here. So --
    Q. Okay. Is that where the vase was? And just for the record, it's kind of in the center of that doorway to the
    parlor where the fireplace is?

    A. Right.
    Ms. Chang: Okay.
    Ms. Stebbins: I'm going to object to lacking foundation as to the cost of the vase. I don't think there is
    any foundation for the witness to testify it's expensive or not.
    Judge: Sustained as to the cost of the vase.
    Ms. Chang: All right. We'll just call it a vase.
    Q. And what happened after you heard the vase crash?
    A. The vase crashed, and, again, it was rather large, so it was loud. So myself and one of the housekeepers ran
    into the room where the gentlemen were meeting to clean up the pieces. And at that time, I was able, you know,
    to hear some of the conversation that was going on.
    Q. Did it seem like a pleasant meeting or a tense meeting?
    A. Well, it seemed they were very firm with him. I had asked Mr. Jackson when I came into the room, "Can I
    get you any water? A beet juice?" He attempted to start eating some guacamole and chips I
    prepared. I put that right in front of him. And he's like, "Yes, thank you, I would love that." So before I
    went out of that room to go retrieve his beverages, I had heard, you know, Mr. Jackson --
    Ms. Stebbins: I'm going to object to the hearsay, your honor.
    Judge: Sustained.
    Ms. Chase: "I don't care if you have to --"
    Ms. Chang: I don't think she knows what "sustained" means. Let me re-ask the question.
    Q. From the meeting that you observed, was there voices that were louder than in a normal conversation?
    A. Well, everyone was talking at one time.
    Q. Okay. Were you concerned --
    Judge: Sorry. All talking at one time? You mean over each other?
    Ms Chase: Yeah, talking over each other, and then they were individually talking loud.
    Ms. Chang: All right.
    Q. And were you concerned for Mr. Jackson?
    A. Yes, I was.
    Q. Okay. Who left the meeting -- first let me ask you this. Based on your observations, and your
    monitoring of your guests and the drinks, how long did this meeting last with everyone in the room?
    A. The meeting lasted probably maybe about an hour.

    Q. Who left the meeting first?


    A. Mr. Jackson left first.
    Q. Okay. And did the meeting continue after he left?
    A. The gentlemen still stayed.
    Q. Okay. And that would be Dr. Murray, Paul Gongaware, Randy Phillips and Frank Dileo, is that
    correct?
    A. Right. Then Dr. Murray had left secondly.
    Q. Okay.
    A. And he came through the kitchen where I was, because there was an exit that way.
    Q. What did you observe in Dr. Murray's behavior when he came into the kitchen?
    A. He seemed --
    Ms. Stebbins: Again, I'm going to object to the extent this calls for hearsay.
    Ms. Chang: Actually, it doesn't.
    Judge: Well, observation means other than words. What did you observe about Dr. Murray? Do you
    understand?
    Ms. Chase: Yes.
    Q. Was he upset?
    A. He was upset, but he had said in passing to me --
    Ms. Stebbins: I'm going to object to the hearsay, your honor.
    Judge: Sustained.
    Ms. Chang: I think we need a sidebar, your honor.
    (sidebar):
    Judge: Okay. The witness is about to say something that Dr. Murray said to her.
    Ms. Chang: Correct. And I just wanted to state, first of all, this counters what Mr. Phillips described what was
    said in the meeting that he described taking place at carolwood, what -- he was allowed to testify as to what Dr.
    Murray stated, what was said. And basically what Dr. Murray said when he came into the kitchen is, and I
    quote, I don't need this shit, I can't handle this shit. And he was very upset, and he walked out the door. Now,
    that completely is a different type of picture, and it is not used for the truth of the matter asserted, but to show
    his highly emotive state of mind, and -- and whether he can --

    Judge: Excited utterance?


    Ms. Chang: -- whether he can handle this shit or not is not the reason we're showing it.
    Ms. Stebbins: Your honor, I don't think this meets the criteria about an excited utterance. There's no
    foundation as to what --
    Judge: Events caused it?
    Ms. Stebbins: -- what caused this, where it was from. She testified that she never asked Dr. Murray
    What he meant, she never talked to Dr. Murray about what happened at the meeting. She testified she didn't
    hear anything that was said at the meeting other than a single comment by Mr. Dileo at the beginning of the
    meeting which I objected to and you sustained that objection, that she wasn't able to hear anything else at the
    meeting, she did not observe the meeting herself, she never talked to Dr. Murray about what the basis of his
    comments was. It's not sufficiently tied to the meeting, and I don't think it meets the definition of an excited
    utterance because it has to be made contemporaneously
    And sort of based on the experience. Even if it did meet that criteria, it's more prejudicial than probative
    without any foundation as to what its cause was and whether this related to the meeting at all.
    Ms. Chang: Since defense counsel elicited from both Mr. Gongaware and Mr. Phillips a wild, elaborate
    kumbaya meeting where they were all excited, he looked fabulous, and Dr. Murray assured them everything
    would be great, and everyone was happy, and the doctor was fantastic -- this is in direct contravention to that.
    It is -- as defense indicated that theirs is not for the truth of the matter asserted, we are also saying that this is
    his existing state of mind. He was upset, it was his -- it is directly afterwards he stormed out. According to
    section 2040, it meets -- 1240, it meets all the criteria of a spontaneous statement, and his existing mental state,
    as well, to section 1250. And it was made spontaneously while the declarant was under the stress of excitement
    caused by the event.
    Ms. Stebbins: Here's the problem, your honor. We don't know what event caused it, and --
    Judge: Was there anything intervening between --
    Ms. Chang: No. He walked straight out and stormed out and said, "I can't take this shit."
    Ms. Stebbins: That's not exactly how it read at the deposition. She said that he came through the kitchen
    afterwards at some point. I can find the deposition testimony.
    Ms. Chang: I directly quoted it straight from the deposition.
    Ms. Stebbins: I'm not disputing the quote, I'm just disputing the timing.
    Ms. Chang: You can cover everything in cross.
    Ms. Stebbins: She said -- she didn't say what time it happened, she just said, "When he came through the
    kitchen, he kind of stopped and said to me, you know, 'I can't handle this shit.' He was upset and walked out the
    back." Now, she does say he was upset, she's testified to that. My concern is just with the hearsay portion. She
    can testify that Dr. Murray appeared upset, I think that is perfectly within her observations, but I think
    testifying to a statement when there's no basis for what the foundation of that statement was --
    Ms. Chang: It can't be hearsay when -- because we're not using it -- whether he can handle this shit
    is not the issue in question. It is an expression of his frustration, his upsetness. And I think given the

    wide rein that they were given --


    Judge: Is Conrad Murray's state of mind at issue? I mean, was it, "Oh, he was reassuring? He was --"
    Ms. Chang: Yes, because what we're trying to say is because of the inherent conflict, they exerted
    pressure on both Michael Jackson in Dr. Murray's presence and on Dr. Murray directly, and that would
    tend to -- the loss of $150,000 would tend to make a doctor do something that he would not ordinarily do. So
    that is part of our whole process, is the pressure, we have been saying pulling the plug. They've denied it
    vehemently, and we know differently, and we're going to establish all that. So --
    Mr. Panish: Well, your honor, under 1240, a contemporaneous or excited utterance, as it's been
    referred, state of mind is irrelevant. It doesn't matter.
    Judge: I'm just trying to think of different grounds.
    Mr. Panish: There's two prongs.
    Ms. Stebbins: Relevance always matters.
    Mr. Panish: Well, it's clearly relevant because they spent an exorbitant amount of time with both
    Phillips and Gongaware describing everything that happened.
    Ms. Chang: And how wonderful it was, the protein shakes --
    Mr. Panish: So they've clearly established that it's relevant according to them. Now, when Dr. Murray -- she
    says he is the second person to leave the meeting, goes straight through the kitchen still under the stress of the
    event, and makes that statement. Clearly it meets the requirements of evidence code section 1240. In addition,
    1250, Dr. Murray's state of mind, is relevant for his actions that eventually led to what happened.
    Ms. Stebbins: Your honor, they've argued Dr. Murray's state of mind isn't relevant, and that's why they didn't
    want to bring in his criminal interview. They're trying to have it both ways there. I think based on what I read
    in the deposition, it doesn't seem to meet the definition of an excited utterance to me. She did say he was upset,
    but he didn't shout it, he wasn't like eager and storming out in the way they're describing. She said, "I
    remember one time he came into the kitchen after the meeting that he had with AEG and Frank Dileo and he
    was leaving the meeting and he came through and kind of said something to me then, 'I don't need this shit, you
    know, I can't handle this shit,' and walked out upset." So it's not, clearly, an excited utterance to me, your
    honor. It came out very casually when she
    testified to it before. They're describing it in a very animated way, but I'm not sure the witness described it the
    same way.
    Judge: Didn't the witness describe the meeting a little differently than the way your witnesses have described it,
    talking over each other, there was elevated voices?
    Ms. Stebbins: There will be some impeachment on that, your honor.
    Judge: Vases crashing, she walks in, everything is tense, Murray walks out. She's describing a different
    scenario.
    Mr. Panish: And it doesn't have to be in a loud voice. It could be in a silent voice. For her to say he wasn't
    shouting it, that's not a requirement. It needs to be close in time to the event as a result of
    while you're still under the stress or perception of the event. And he immediately leaves, goes right to
    the kitchen -- and I don't know the distance, but it doesn't seem like it's, you know, that far in the picture. And

    that would qualify under contemporaneous statement. We're not saying Dr. Murray's state of mind for
    everything is relevant. That's why they want to bring in the police statement. We're saying as to his actions,
    whether he worked for Michael Jackson or not, as they argue in the state of mind in the police statement, is
    completely different than his actions that occurred we know eventually right after -- at least some period of time
    temporal to the time of the meeting.
    Ms. Chang: And I think the difference between what is raised with respect to his understanding of the
    employment, this truly is non-hearsay, the "I can't handle this shit," because it's not for the truth. I don't know
    whether -- what his tolerance of handling shit is. That's not what we're using it for. It's an expression of how he
    felt about that meeting, which is in stark contrast at a time that was very relevant.
    Mr. Putnam: And that precisely is the reason why it's being offered for the truth of the matter
    Asserted. In terms of -- for any expression, there is not the literal meaning, for the same reason if you
    Say, "I'm going to stab someone in the back," or "He stabbed me in the back," they're not literally saying he
    stabbed him in the back. And that's why when you talk about the hearsay cases, it is what is the gist of what is
    being said. And the gist of what's being said by him going out and saying, "I can't take this shit" is the idea that,
    "I can't take the pressure" according to your theory, as to what's being applied here. That's being offered for
    the truth of the matter asserted. That's why you want it, and that's why as a hearsay matter, it cannot be --
    Ms. Stebbins: It's being offered for the truth, your honor, that Dr. Murray couldn't handle this shit,
    collapsed, violated the hippocratic oath and killed Michael Jackson. So it is basically being offered for
    its truth, your honor.
    Mr. Panish: But 1240 is an exception to the hearsay rule.
    Judge: I'm overruling the objection.
    (back to open court)
    Q. Ms. Chase, when Dr. Murray came into the kitchen, what did you hear him say?
    A. He said, "I can't take this shit."
    Q. Was he upset?
    A. He was upset.
    Q. Okay. And did he storm out?
    A. And he left, stormed out, yes.
    Q. All right. Now, after he left, did Mr. Gongaware, Mr. Phillips and Mr. Dileo stay in the parlor?
    A. Yes, they did.
    Q. How long -- when you left for the day -- what time did you leave that day?
    A. I left around -- it was summer, so I left around like 6:00, 5:00, 6:00. Like right after the -- you know, Dr.
    Murray left, I left around then.
    Q. Okay. And were the gentlemen still seated in the parlor when you left?

    A. They were still at the home, yes.


    Q. Okay. And do you know how long they stayed?
    A. I don't know.
    Q. Okay. Did you ever talk to anyone about what the meeting was about?
    A. No.
    Q. And how did Mr. Jackson act after that meeting?
    A. I didn't see Mr. Jackson until the next day.
    Q. Right. Days after that followed.
    A. Days after. The same. You know, he was still in the same state.
    Q. Was he tense?
    Ms. Stebbins: Objection, leading.
    Judge: Sustained.
    Q. Can you describe his emotional state or what you observed in him daily after that meeting?
    A. He was -- he seemed like he was -- had a lot of -- just he was thinking, and the weight of the
    world on his shoulders, and just concerned and frightened and scared. It was a lot of -- a lot of
    those emotions.
    Ms. Stebbins: I'm going to object, lacks foundation, your honor, as to how the witness observed this and
    how often she was in contact.
    Ms. Chang: I think it's a lay witness observation, your honor.
    Judge: Overruled.
    Ms. Chang: All right.
    Q. And, Ms. Chase -- and did his demeanor and behavior concern you?
    A. Yes, it did. It concerned me greatly.
    Q. All right. And during this time period, did you ever suspect that Dr. Murray was doing something harmful to
    Mr. Jackson?
    A. No, I did not.
    Q. Even though you didn't suspect that he was doing anything harmful, were you nonetheless alarmed by some
    of the things that you saw, such as the oxygen tanks?

    A. Yes. I thought it was strange that there were oxygen tanks in a home when there was a doctor 24/7 in a
    home.
    Q. And from what you observed of Mr. Jackson in April, did you believe that he needed -- when you said he
    was vibrant and happy, did you believe he needed a doctor 24/7?
    Ms. Stebbins: Objection, lacks foundation.
    Judge: Sustained.
    Q. Now, Ms. Chase, I want to bring you to two days now, June 24th and June 25th. Let's start with June 24th.
    This is the day before Mr. Jackson died. And do you recall seeing Mr. Jackson on that day, which was
    wednesday, June 24, 2009?
    A. Yes, I do.
    Q. Okay. Did you -- what time did you arrive at the house?
    A. My usual, between 8:00 and 8:30.
    Q. And what did you do when you arrived?
    A. Prepared breakfast as normal, getting things ready for the children and Mr. Jackson.
    Q. And did you see Dr. Conrad Murray on that day?
    A. Yes, I did.
    Q. And approximately what time did you see him?
    A. I usually saw him around 10:00 in the morning.
    Q. Okay. Is that the usual time that you usually saw him when he came down?
    A. Yes.
    Q. Okay. And where was he when you first saw him?
    A. He was coming into the kitchen, his normal.
    Q. Okay. And where did he come from, if you know?
    A. From upstairs.
    Q. Okay.
    A. From the side of upstairs down into the kitchen.
    Ms. Chang: Okay. And let's show to counsel first a police photo, exhibit 462, dash, 6436. Just the bottom
    one.
    Ms. Stebbins: That's fine.

    Ms. Chang: Okay. Let's show that. There's a watermark on here, the police department -- so just try to
    ignore the watermark.
    Q. But does this show the stairs that Dr. Murray came down?
    A. Yes.
    Q. Is this his normal route to the kitchen?
    A. Yes, it is.
    Q. Okay. And does that also show the kitchen?
    A. Yes, it is.
    Q. All right. You can take that down. Thanks. And when Dr. Murray came down on that day, what did he do?
    A. When he came down on that day, he brought some juice or some kind of small breakfast item for
    Mr. Jackson to have.
    Q. To bring back upstairs to him?
    A. To bring back upstairs, yes.
    Q. And was that his usual custom in June?
    A. Not always, but sometimes, yes.
    Q. Did sometimes Mr. Jackson come down to eat breakfast?
    A. In June?
    Q. Uh-huh.
    A. Very rare, yes, but he did.
    Q. Okay. In April, did he come down to eat breakfast?
    A. Yes.
    Q. Okay. All the time?
    A. Yes, if he was not in the studio, yes.
    Q. Okay. But in June, Dr. Murray would come down and get his breakfast and bring it back up?
    A. On occasion, yes.
    Q. All right. After breakfast, do you recall seeing Mr. Jackson?
    A. Yes, I do.

    Q. And when was that?


    A. This was in the afternoon.
    Q. Okay.
    A. I was preparing a lunch for him and his children. I remember that day he was actually having
    lunch with his children, and he was going to have rehearsals that day, as well, outside of the house.
    Q. And how would you describe his appearance and mood on that day?
    A. He was dragging. You know, he was dragging a little on that day. But I did tell him, I said, "You look good,"
    You know, because I didn't want him to, you know -- to people, you know, that he -- he looked good today, give
    him some encouragement. But he was dragging, and he was tired, and I could tell that about him.
    Q. Was he happy, though, to have lunch with his kids?
    A. Well, of course, with his children, yes.
    Q. All right. And do you know whether he went to rehearsal that day?
    A. That day, he was back and forth contemplating whether he was going to go to the staples center or he was
    going to rehearse at the house. So he ultimately decided -- he went to Staples and he went to
    rehearsal.
    Q. Did you pack him something to eat?
    A. I made his lunch with the same lunch that he had eaten that afternoon with his kids. I made the
    same seared ahi tuna salad for him in the lunch bag.
    Q. And did he come home for dinner that night?
    A. Yes, I was told that he came home.
    Q. Pardon me?
    A. I was told that he had come home, yes.
    Q. Okay. Were you there, though?
    A. No.
    Q. Okay. Did you typically leave something?
    A. I left -- I was told to leave two dinner items, one for Dr. Murray and one for Mr. Jackson, in the refrigerator.
    Q. Okay. And was that typical in June, for you to make dinner for Dr. Murray?
    A. Yes.
    Q. Did you typically make dinner for Dr. Murray ever in April?

    A. No.
    Q. Okay. Only in June?
    A. In June, yes.
    Q. Okay. What time did you go home on the night of the 24th?
    A. Probably my usual time, 6:00, 6:30, 7:00.
    Q. Okay.
    A. 8:00, something like that.
    Q. Sometimes it was later?
    A. Yeah, sometimes it was later, yeah. But he wasn't there, so I made his dinner and left.
    Q. Okay. On the next morning, June 25th, which was a thursday, what time did you arrive on that
    morning?
    A. My usual time, 8:00, 8:30.
    Q. All right. What did you do when you arrived?
    A. When I got to the home, I started preparing a small meal for the children, but then I ultimately left and went
    to the market to -- to grocery shop.
    Q. Was that grocery shopping day?
    A. Yes.
    Q. Okay. How long were you at the grocery store?
    A. I was there until about -- about an hour or so.
    Q. All right. And what time did you return?
    A. Around 9:45.
    Q. Okay. And then did you notice anything unusual when you returned?
    A. No. Everything was, you know, beautiful. As usual, the kids were playing in the den. I went to the
    kitchen, started unloading the groceries, put things away, started getting things ready for lunch. At that time, it
    was getting closer to start preparing for the lunch.
    Q. Okay. What time did you start preparing lunch?
    A. Lunch was always served at around 12:30, so I probably started around 10:15, 10:30, something like that.
    Q. All right. And did you see Dr. Murray come down that morning to get Mr. Jackson's juice or breakfast?

    A. No.
    Q. All right. When is the first time that you saw Dr. Murray that day?
    A. I saw Dr. Murray that early afternoon, closer to the time when lunch was supposed to be, between 12:05,
    12:10, something like that.
    Q. And what happened? How did he appear when you saw him?
    A. Well, that first time when I saw him, he came down the same stairs into the kitchen in a frantic
    Panic.
    Q. He was panicked?
    A. He was panicked.
    Q. What did he say to you?
    A. And he screamed at me and yelled, "Go get help. Go get security. Go get Prince."
    Q. Okay. What did you do in response to those instructions?
    A. I stopped what I was doing, dropped everything, and went to go get Prince, who was playing
    In the den. So the children were right in front of me, so I went to go retrieve Prince.
    Q. All right. And what did you say to him?
    A. I said to him, "Hurry. Dr. Murray needs you. There may be something wrong with your father."
    Ms. Chang: All right. Let's show to counsel exhibit 909.
    Ms. Stebbins: That's fine.
    Ms. Chang: All right. Let's go ahead and show that.
    Q. Okay. And this is -- is this a layout of the kitchen area?
    A. Yes.
    Q. Okay. And if you could orient us, is that -- the little round table that we see in this diagram, this little round
    table, is that the little round table we see right here on the right-hand side?
    A. Yes, it is.
    Q. Is that where your interview took place?
    A. Yes.
    Q. Okay. Based on this picture, and maybe it's -- using the diagram, can you tell us where the den is, using your
    laser light?

    A. The den would be right going that way.


    Q. Okay. So let's blow up that tiny picture in the right corner again. So from the orientation of where someone
    took this picture from, the den would be behind the picture taker, right?
    A. Right, going this way, yes.
    Q. All right. And, again, it was an open floor plan?
    A. Open floor plan.
    Q. Okay. And did Prince go to Dr. Murray?
    A. Yes, he did.
    Q. What happened after that?
    A. He went to Dr. Murray, and at that point, I went right back to work.
    Q. Okay. Did Dr. Murray ever tell you to call 911?
    A. No, he did not.
    Q. Okay. Did you ever go get anyone from security?
    A. No.
    Q. Okay. And you went back to work, and what happened after that?
    A. I went back to work, and I was working for a few minutes, and then all of a sudden, I noticed that the
    housekeepers, they were down in the area where I was and they were sobbing.
    Q. And who were the housekeepers at that time?
    A. Jimmy and Blanca.
    Q. Okay. Were they a married couple?
    A. Yes, they were.
    Q. Okay. And they were crying?
    A. They were crying, and I went to -- you know, to talk to them. And I was like, "What's going on? What's
    wrong?" He's like, "There may be something wrong with Mr. Jackson. Mr. Jackson may be ill."
    Q. All right. What happened after that?
    A. After that, you know, you could feel the energy in the house had started -- had changed. You know, the
    energy in the house had changed, and everyone was very concerned, we were very worried. Then all of a
    sudden, I hear Prince screaming, "Daddy, Daddy, Daddy," and then Paris screaming -- blood-curdling
    screaming "Daddy," just out of her mind screams, "Daddy." I grabbed the children
    because I -- I was just for fear that I didn't want whatever could have been happening to him -- and don't want to

    think the worst of anything, you know, but I didn't want to -- I didn't want those children to witness or feel any
    discomfort or anything that would make them sad. This was their world. I grabbed them, I held their hands, and
    I said, "Let's pray. Let's pray. Let's hold hands, let's pray. Father God, please let nothing be wrong with this
    man." People were crying, security was everywhere, paramedics were running up and down the stairs. It was --
    it was horrible. And I didn't know anything else to do but hold on to those kids.
    Q. Were they upset?
    A. They were devastated.
    Q. What happened after -- after the paramedics arrived?
    A. After the paramedics arrived, they had ran upstairs, security was upstairs, I'm downstairs with the children.
    And a security guard, alberto alvarez, asked me to leave the house.
    Q. All right. And did you leave the house?
    A. I had no choice.
    Q. Okay.
    A. I didn't want to, because I wanted to stay there for the kids. But he asked me to leave. And I asked him, "Is
    everything okay with Mr. Jackson?" "He'll be fine." And I knew that didn't -- that did not feel right. That house
    had changed. I know -- that's a feeling that you cannot deny.
    Q. And did you learn later that day that Mr. Jackson had died?
    A. Yes.
    Q. How did you find out?
    A. I heard it on the radio. I heard it on KNX, and I didn't want to believe it. I thought they were lying. I thought
    maybe he'd twisted his ankle in the shower or something, but never anything devastating like this.
    Q. All right. And after Mr. Jackson died, was there -- were you approached by a number of news
    organizations to talk about what you had seen and observed that morning?
    A. Yes, I was.
    Q. And did you go on different shows like CNN and Good Morning America and -- I think there were other
    shows like that.
    A. Yes, I did.
    Q. Okay. And did you talk about what you had seen?
    A. Yes.
    Q. Did other type of stations from foreign channels also request that you appear?
    A. Yes, they did.

    Q. All right. And did you get paid for some of those appearances?
    A. The overseas ones, and the content about those interviews was -- basically focused on the food.
    Q. And food preparation?
    A. Food preparation and the love that he had for his children.
    Q. And was the money that you were given mostly for supplies?
    A. Supplies, things of that nature.
    Q. Okay. All right. When you were on TV shows immediately after the death, did you say everything that you
    said today in this courtroom, or did you try to keep it more general?
    A. Well, it was media, so in -- to respect the privacy of my client, I was very general. Here today, we're in a
    court of law, so I'm here to tell the truth.
    Q. All right. Now, you indicated to us before that you currently work for Mrs. Jackson and Prince, Paris and
    Blanket, correct?
    A. Yes.
    Q. How did that come about?
    A. I got a phone call, and the children had been requesting me since their Daddy's death, and they
    asked if I could come work for the family, the kids really missed me and loved me, and I agreed.
    Q. When did you start working for Mrs. Jackson?
    A. July 2012.
    Q. Last year?
    A. Last year.
    Q. And in that time period from 2009 to 2012, did you have occasion to see the children?
    A. I saw the children a couple of times at their old home, and they requested to see me then so I'd go visit, stay
    and play with them for a few minutes.
    Q. Now, going back to when Mr. Jackson was alive, while you were working for him, and during
    conversations you had with him, did he ever talk to you about his mother, Katherine Jackson?
    Ms. Stebbins: Objection, calls for hearsay.
    Judge: Sustained.
    Q. Did he mention her from time to time, without telling me what he talked about?
    A. Yes, he would.

    Q. All right. Did you gather while you were there and from your observations that his mother was
    Important to him?
    Ms. Stebbins: Objection, lacks foundation.
    Judge: Lay some foundation.
    Q. You indicated that you had frequent conversations with Mr. Jackson. I think you said every day, is that right?
    A. Yes, yes.
    Q. Of all the conversations that you had with him in April and then when he came back in June,
    approximately what percentage of those conversations did you talk about family?
    A. Well, family was very important to him, so I would say a good 50 percent of it was family.
    Q. Okay. And of that 50 percent when you talked about families, what percentage would you say
    you talked about his mother?
    A. He talked about his mother a good percentage of that 50 percent.
    Q. Was she important to him?
    A. Absolutely.
    Q. Did he love her?
    A. He loved his mother and he loved his children.
    Q. All right. Now, after Mr. Jackson died, and since July of 2012 up to the present day, and here we are in June
    of 2013, did you also come to know his mother, Katherine Jackson?
    A. Yes.
    Q. And do you interact with Mrs. Jackson on a frequent basis?
    A. On a daily, every day.
    Q. And do you talk to her every day?
    A. Yes, I do.
    Q. Okay. And have you -- first let me ask you this. Are your responsibilities for Mrs. Jackson similar to the
    responsibilities that you had with Mr. Jackson?
    A. My professional duties are the same, yes. I shop for the family, do the breakfast, lunch and dinner, snacks,
    clean up and go. But it's -- I've also developed a family bond and loving respect for Mrs. Jackson, and the -- we
    have a lot in common. She has a lot -- just like her son, she loves music and art and beautiful flowers and things,
    so those are a lot of things that we talk about on a daily --
    Q. Do you find similarities between Michael Jackson and his mother?

    A. Absolutely.
    Q. And do you also speak to the children every day?
    A. Yes, I do.
    Q. And first let me ask you, have you observed how the loss of Michael Jackson's love and his
    companionship and affection -- how that has affected Katherine Jackson?
    Ms. Stebbins: I'm going to object, lacks foundation, your honor. There was a three-year gap between
    where she worked with Mr. Jackson and what she observed Mrs. Jackson -- I think there are other
    witnesses better suited to establish this.
    Ms. Chang: I'll be happy to lay some foundation, your honor.
    Judge: Okay.
    Q. Ms. Chase, in your daily conversations that you've had even three years after Mr. Jackson died, does Mrs.
    Jackson talk about her son Michael?
    A. Yes, she does. She misses him terribly.
    Q. How often does she bring up Michael Jackson?
    A. Every day.
    Q. Every single day?
    A. This is her son, this is her child, she gave birth to him. Absolutely.
    Q. All right. And she knows that you loved Michael, also?
    A. Absolutely.
    Q. That's a bond that you two share?
    A. Yes.
    Q. She knows that you were there the day he died?
    A. Yes, she does.
    Q. All right. And how have you observed Mrs. Jackson react to that loss of her son even three years later?
    A. It saddens her. She cries.
    Q. Do you have to comfort her?
    A. I comfort her. I cry.
    Q. Does she talk about what she misses about her son?

    A. She misses her son's spirit, the love that he gave to her.
    Ms. Stebbins: I object to hearsay, your honor.
    Judge: Overruled.
    A. The love that he gave to her, the -- the jokes that they would share together, the conversations, the love. And
    that's something that you cannot deny, mother and son. It's just something that's human nature.
    Q. Now, three years had passed since you had seen Prince, Paris and Blanket?
    A. Yes.
    Q. Were they grown up when you came back in July of 2012?
    A. They're huge. I told them, "You guys stop growing. I'm shrinking."
    Q. And did you notice differences in them --
    A. Well --
    Q. -- other than the fact that they were grown?
    A. Yeah. You know, they're becoming teenagers now, little young teenagers, and, you know, they're -- two of
    them are in school. They're not home schooled, and they're acquiring friends, and they're -- they are taking
    karate classes and they're into music and they're doing things that teenage kids are doing these days.
    Q. Now, you indicated that two of them are at school?
    A. Yes.
    Q. Which two children are at school, public school?
    A. I believe the school is a private.
    Q. I'm sorry. In other words, outside-of-the-house school.
    A. Yes. Prince and Paris.
    Q. All right. And little Blanket, is he still --
    A. He's home schooled.
    Q. Okay. He's still being home schooled?
    A. Yes, he is.
    Q. Okay. So he's at home?
    A. Yes.
    Q. All right. And other than them being bigger and going to school, is there a difference between

    their lives when you saw it for that April and June time period in 2009 versus now at Mrs. Jackson's house?
    A. Well, the difference that I would observe now with them is before, they were in a -- this protective type of
    special life. They are thrust into the world now, which is all new to them, and they're -- you know, being --
    becoming atiquated into learning -- you know, their skills and friendship skills. But the love in the home is the
    same. The love in the home that's given to them is very powerful and it's the same as it it was with their father.
    Q. But do they miss their father?
    A. That is very apparent. They miss their father greatly. They talk about their father a lot, what Daddy would
    have done, when we traveled this place and that place, and Daddy's music, and -- you know,
    It's just something that they'll never get over, the love and how much they miss their father. That's all
    they had, was their father.
    Q. Well, let me start with Prince. When you saw Prince in April and June of 2009, he was 12 years old?
    A. Yes.
    Q. How old is he now?
    A. He just turned 16.
    Q. Okay.
    A. Yes.
    Q. And as a 16-year-old and seeing him every day as you do, how have you seen him, how has he been affected
    by the loss of the love, companionship, affection and guidance of his father?
    A. Prince has always been -- even at 12, to me, the little man, Daddy's little man. And he always wanted -- he
    wanted his father to be very proud of him, which Michael was. And now, as -- at 16, the weight of the world is
    on his shoulders. He is kind of like the eldest, the father figure, big brother figure to his siblings, and it's a lot
    for him, growing, liking girls, trying to figure life out. And I know that he wishes his father was here to give
    him what young boys need in that -- in that growing up area. But it's dev -- it's devastating to him because he's
    missing that, and I know that's what he is longing for.
    Q. I don't want to go into too much detail about Paris, but can you tell me what you have observed
    about how Paris has been affected by the love and companionship and affection of her father?
    A. Being Daddy's little girl, she -- Paris is devastated. She's devastated and lost. She's looking for that -- there
    was so much love that was given with her and her father, and it was just so apparent in everything that she did.
    She's lost, she's searching, she's -- she's -- she's sad, and she's -- it's
    devastating to her. And she's a young girl. Every girl needs their father. I would be devastated, too, if that would
    happen to me.
    Q. Is she having a difficult time coping with the loss of her father?
    A. Yes, she is. She is. She's -- she's -- she's trying to find herself, trying to find who she is, and she's -- it's just --
    it's taking a lot of love and understanding to keep her together. She breaks down, she cries, she talks about him,
    she remembers, you know, Daddy days and her birthday. "I don't want to have another birthday again." I mean,
    these are devastating -- devastating situations for young kids, and they can leave scars for children growing up,
    and I don't want that for her.

    Q. Has the entire household been worried about Paris?


    A. Absolutely. The entire household.
    Q. And now let's turn to little Blanket. How old is Blanket now?
    A. Blanket is 11, 12 -- 11. 11, yeah. I keep thinking he's older because he's so smart.
    Q. Okay. And you said that he was being home schooled?
    A. Yes.
    Q. Did he just finish -- what -- what grade did he just finish?
    A. He just graduated grade school, so now he's in middle school. He'll be starting 6th grade, which is middle
    school.
    Q. Okay. So he just graduated 5th grade?
    A. 5th grade, yes.
    Q. Okay. And how has little Blanket been affected by the loss of the love and companionship and
    affection and guidance of his father?
    A. Well, that's the littlest. He has a lot of -- he has his older siblings to protect him, but still, I think, the -- the
    youngest child will always be more affected because they are the baby. And him being the baby, he -- you
    know, he -- he -- it's a lot of remembering, it's a lot of "remember when Daddy did, remember when Daddy
    did," and it's constant, this constant nonstop of him and his father's relationship together. He's hurt, too. This is
    all new to all of them, and especially to him because, you know, he -- he never really had growing up of an age
    to where it was father/son because he was so tiny and he was so little. So I know that he's -- he's feeling a little,
    you know, lost, as well, because now Daddy is gone, "but I have my brothers and sisters, but we're all still
    feeling the great loss and the great pain" of not having their father there.
    Q. Does he remember his father?
    A. Oh, he does.
    Q. Does he wear things that --
    A. Well, he remembers his father, he -- you know, he's home schooled Monday through Friday. Fridays are
    casual Fridays for him in home school, so he gets to wear whatever he wants, he doesn't have to
    wear his uniform. But in loving his father so much, he wears his t-shirt, the Cirque du Soleil Immortal show
    with the Michael Jackson picture on it, and it's his favorite. He wears it -- he wears it constantly.
    And -- and do, you know, dance moves like his father, or, you know, things that he's seen his father do. But he
    talks very highly of him. And, you know, these kids want to be like him in some way, film,
    musical experiences. There's a love there, a love that's lost.
    Q. All right. And even though you know that Mrs. Jackson loves her grandchildren very much, and you
    said the same amount of love, is it a different kind of love?
    A. It's definitely a different type of love. A grandmother's love is, of course, very unconditional and loving. But

    the love of a parent -- and that was their only parent, and the only parent they knew.
    Definitely it's a great loss, and they miss him. They miss him, and I believe the older they get, it may be --
    become harder.
    Ms. Chang: All right. And -- I have no further questions. Thank you.
    Judge: Cross examination?
    Ms. Stebbins: Sure, your honor. Actually, do you mind if we just take a break so I don't have to go four
    minutes and stop?
    Judge: Sure. 15 minutes.
    (break)
    Cross-examination by Jessica Stebbins:
    Q. Ms. Chase, I want to start with something that just confused me this morning, and that was about Mr.
    Obama. You said you met him in 1997, is that right?
    A. 2007.
    Q. You said 1997, so that's why I'm asking.
    A. I'm sorry. It was 2007, because he wasn't even around in '97.
    Q. That's why I asked.
    A. Thank you. I graduated culinary school in 1997. Okay. Sorry.
    Q. So you met barack obama in 2007?
    A. Yes.
    Q. That makes more sense. And you started working with Mr. Jackson at the end of March 2009, right?
    A. Yes.
    Q. And you were initially interviewed for the position by Mr. Michael Amir?
    A. Yes.
    Q. Does he also go by Michael Amir Williams? Have you heard him called that?
    A. Yes.
    Q. And if I refer to him as either Mr. Amir or Mr. Williams, will you know who I'm talking about?
    A. Yes.
    Q. Do you know whether Mr. Williams ran any kind of background check on you?

    A. I'm not aware.


    Q. Did you sign anything asking for permission to have a credit check run on you?
    A. No.
    Q. But you understood that you were going to be hired at Mr. Jackson's request, right?
    A. Exactly.
    Q. And you were going to be in his home cooking meals for him and his family?
    A. Yes.
    Q. On a daily basis?
    A. Yes.
    Q. And you worked starting the last week of March, is that right?
    A. Yes.
    Q. And then you were let go in the first week of May 2009?
    A. Yes.
    Q. And you came back June 2nd, 2009?
    A. Yes.
    Q. Now, you said you initially started working being six days a week, and then Sundays became your day off --
    seven days a week, and Sundays became your day off. When did that change happen?
    A. At the end of April. Well, in the middle -- in the middle of April, around there.
    Q. So after, maybe, a couple of weeks of work?
    A. Yes.
    Q. And that's when you went to Disneyland and got the presents for everybody?
    A. Yes, yes.
    Q. But then that note that Ms. Paris Jackson wrote you was two months later in June?
    A. When I came back, yes.
    Q. Okay. Now, when you started working for Mr. Jackson, you had not met him at that point, right?
    A. Not initially, no.

    Q. So you came, you were hired, you were working in his house before you'd ever met the man himself?
    A. Correct.
    Q. You'd been interviewed by the children?
    A. Yes.
    Q. And by Mr. Amir Williams?
    A. Yes.
    Q. And then it was about a week, I think you said, after you started work that you met Mr. Jackson?
    A. A few days to a week, yes.
    Q. And you ran into him on the staircase?
    A. He was coming down the stairs, yes.
    Q. Now, after that time, how often would you estimate that you saw Mr. Jackson?
    A. In April?
    Q. In April.
    A. I saw Mr. Jackson quite often.
    Q. You said he was at the studios working on material, right?
    A. Yes.
    Q. Was he gone for most of the day, or was he home most of the day?
    A. He would come home a lot for lunch and dinners.
    Q. So he'd come home for mealtimes?
    A. Mealtimes, yes.
    Q. About how long would he come home when he was home?
    A. Well, if he was there for lunch and dinners, he was already -- he would be in the home and he wouldn't leave.
    Q. So he would come home for lunch and dinner and then go back out?
    A. No. He'd stay.
    Q. So he'd be gone in the morning and come home for lunch and stay through dinner?
    A. Yes.

    Q. And in that time period -- I guess let's describe your typical day. How much of that time period were you in
    the kitchen?
    A. My job was his chef, so I was in the kitchen often if I wasn't in the den with the children. So it fluctuated,
    you know.
    Q. Just on average?
    A. A good 70 percent, 75 percent.
    Q. 70 to 75 percent of the time at the house, you were in the kitchen?
    A. Yes.
    Q. And then the other 20 to 25 percent, how would you estimate you spent that?
    A. Playing with the children.
    Q. And did you spend a lot of time with the children?
    A. Yes, I did.
    Q. And how often when you were playing with the children would you estimate that Mr. Jackson was
    with you?
    A. Again, he liked to have his dinners with his kids privately, so that would be their time. But I'd serve them
    dinner, so I would see him there. And then a lot of the times, since it was open floor plan, I would observe them
    from where I was in the kitchen, and then sometimes I'd -- I'd play with them together. So I guess you would
    say probably, you know, a few days out of the week.
    Q. And I'm actually trying to just break it down a little bit versus when you were interacting with Mr. Jackson
    yourself versus observing him saying you're in the kitchen and he's somewhere else because of the open floor
    plan. So in terms of the time when you yourself were interacting with the children, how often was Mr. Jackson
    also there interacting with them, as well?
    A. As often as he could. You know, I would just say maybe as many times as he could during the week when he
    would come home from work.
    Q. Can you give me some estimate?
    A. Times? Is that what you're asking?
    Q. Yes, an estimate of time.
    A. Okay. Three, four times a week.
    Q. So three, four times a week, he would be hanging out with the children and you --
    A. Yes.
    Q. -- for 25 percent of your day?

    A. Yes.
    Q. And is that true in April and June, or just in April?
    A. In April.
    Q. What about in June?
    A. In June, he was more -- I didn't see him as much in June. You know, he was back and forth at the
    Staples Center, so more rehearsal time was taken up.
    Q. So he was home less in June?
    A. A little -- yes, a little less in June.
    Q. And do you know for a fact that he was at the Staples Center at all those times, or could he have
    been other places?
    A. He could have been other places, but I was informed that he was rehearsing.
    Q. You never went upstairs at Mr. Jackson's home, did you?
    A. No.
    Q. In fact, there was sort of an unspoken rule that you weren't allowed upstairs?
    A. I don't know if it was an unspoken rule, but I was told by Mr. Amir that the client, you know,
    requested his privacy, which most clients do, and there's no need for staff to be upstairs in private
    quarters.
    Q. So Michael Amir told you, "Don't go upstairs. It's private"?
    A. Again, he had said, you know, this is how, you know -- the client's request, you know.
    Q. Now, detective martinez -- I don't imagine you're aware of this, but I'll represent to you that he's come to this
    court and testified that you went upstairs to drop food off outside of Mr. Jackson's
    door. Is that right or wrong?
    A. That's wrong. That is wrong.
    Q. How did food get upstairs?
    A. If the food was upstairs, it would be by the children.
    Q. It would be taken by the children?
    A. The children would take it upstairs to him, yes.
    Q. I think you said Dr. Murray sometimes came and took it upstairs.
    A. And Dr. Murray would take food upstairs, yes.

    Q. Now, just so I'm perfectly clear, did Dr. Murray take food upstairs in April?
    A. I didn't see Dr. Murray as much in April.
    Q. But sometimes was he there?
    A. Sometimes he was, yes.
    Q. Would you estimate he was there about three times a week in April?
    A. Something like that.
    Q. And that was starting from the beginning of April right after you started working?
    A. Yes.
    Q. And he introduced himself to you as Mr. Jackson's personal physician?
    A. Yes.
    Q. And in April, you would see Dr. Murray at the house maybe three times a week?
    A. Two, three times, something like that.
    Q. And then you saw him more often in June?
    A. Yes.
    Q. I'll come back to Dr. Murray in a bit, but I want to ask a little bit more about when you first started working
    there. You were shown an exhibit this morning I want to ask about. And that was -- I think it's on that table over
    there. Oh, no, this one. 903, dash,1. Can you put that up? Ms. Chase, I believe you testified this is about what
    the children looked like when you first arrived at the house.
    A. Yes.
    Q. In fact, this picture was taken almost a year earlier, in july 2008, wasn't it?
    A. I don't know when it was taken.
    Q. And this is actually a paparazzi or tabloid photo, isn't it?
    A. I'm not sure what it is.
    Ms. Chang: Objection, your honor, lacks foundation.
    Judge: Overruled.
    Q. You have no idea where the picture came from?
    A. No.
    Q. Do you have any family photos of the children yourself?

    A. No, I don't.
    Q. I want to focus in the background of this picture there, in the top left corner. Do you see there's Mr. Jackson
    sitting in a wheelchair with a surgical mask?
    A. Yeah, yes. Is that him?
    Q. In the time that --
    Ms. Chang: Your honor, I think there's lack of foundation, and I will represent that that is not Mr.
    Jackson.
    Judge: Overruled.
    Q. I can -- does it look like there Jackson to you, or can you not tell?
    A. I can't really tell.
    Ms. Stebbins: All right. Well, in that case, I have a demonstrative. This is an exhibit I just got over lunch,
    your honor, based on this picture, so it's a new exhibit. What number are we up to?
    Ms. Chang: Your honor, can we have a sidebar on this?
    Judge: Are you looking at it?
    Ms. Chang: Yes, I am.
    Judge: Do you have an objection?
    Ms. Chang: I do.
    Judge: All right.
    (sidebar):
    Ms. Chang: Okay. Your honor, this is what -- I have been talking to various family members, and about what
    was going on during this time period. First of all, this, I don't even know if it's for the National Enquirer -- do
    you know the source of this article or what it is?
    Ms. Stebbins: Your honor, this -- these pictures were widely published in the tabloid press.
    Ms. Chang: Yes, but let me tell you what I know from my research. There are -- there are a lot of
    times that people went out and they weren't even Michael Jackson. They weren't -- and it clearly was -- they
    used decoys so that -- to make the press think that Michael Jackson went elsewhere, and they used different --
    for example, they used a nurse outfit and a mummy outfit once, and they used different things and they sent out
    different ones so that he could go to a different place. And, also, these are two separate pictures, and to show
    someone in the courtroom -- we don't know if it was like a Michael Jackson day where they were dressing up,
    or whatever. And I think we need more foundation for this, especially since we know that they used decoys to let
    him go otherwise. And for -- she has, obviously, no knowledge of this, and I was told by the family, in fact, that
    this picture was taken in 2009. So for us to be googling at lunch and looking at the National Enquirer, I think is

    silly, and --
    Mr. Panish: It's hearsay.
    Ms. Chang: It's July of 2008, and there is no way that this witness can know that that's -- I don't think there's
    anyone on earth -- and, in fact, I will represent that I don't even believe that this is Mr. Jackson because of their
    common practice.
    Ms. Stebbins: Your honor, here's the issue. I don't plan on going far down this road. The witness testified, for
    instance, that she saw Mr. Jackson wear a surgical mask. He's widely been publicly
    photographed wearing surgical masks many times. She introduced this picture, said it was a true and accurate
    representation of what the children looked like in march 2009. That confused me because,
    frankly, they look a bit too young, so I did some research over lunch to see where the picture came from. And,
    in fact, it is a tabloid photo. And you can see in the back of the photo on the screen that we just focused on there
    is a picture of a man in a wheelchair with a surgical mask who looks very much like Mr. Jackson and is
    photographed with Mr. Jackson's children, and the witness has positively
    identified them.
    Judge: What do you mean, "with his children?" They're walking and he's sitting in the background.
    Mr. Panish: Your honor, counsel, in her testimony, makes representations of fact that there's no basis. For
    example, "oh, well, this picture was taken in 2008." how does she know that? She can't testify, this lawyer, to
    that fact, number 1. Number 2, she's injecting this before she shows it to anyone in an improper method, and
    there's no foundation, it's hearsay.
    Ms. Chang: Let me stress this for the record. The reason why I know it's not Mr. Jackson is because -- and we
    will hear testimony about this later. If Mr. Jackson was ever in public with his children, they had veils on their
    faces. He would never expose his children to the public when he was present because -- we all know the reason
    why, so that people and the paparazzi would leave them alone. And what -- we will have tons of pictures of
    when he was present, they had veils on their faces. So for them to say that, you know, this person is Michael
    Jackson, you know, this -- there have been so many pictures of him in a wheelchair, sometimes intentionally, to
    be used as a decoy, but not -- I don't believe that from that corner that anyone, unless we get the photographer
    and we get it -- because I don't care what anybody says in "People" magazine, or whatever it is.
    Mr. Panish: We don't even know what the source is.
    Ms. Chang: I just think this is ridiculous.
    Mr. Putnam: Where did you get the photo that you put in today?
    Ms. Chang: From the family.
    Mr. Putnam: So this is a family photo that you provided?
    Ms. Chang: They gave me a ton of photos, and this is one of them from that pile.
    Mr. Putnam: It was an actual photo?
    Ms. Chang: It was an actual photo that we scanned in.
    Mr. Putnam: So it wasn't a still. We found it on the internet when we went to lunch and tried to find
    Out where you got it. The reason I'm asking, your honor, is this has happened repeatedly during the course of

    this trial, where they put in photos without the foundation of who they're from, the most famous of which is
    Michael in a t-shirt which is from a website on the internet that we've gone off to find.
    Judge: People have been posting things on websites from this trial, they've been posting --
    Mr. Putnam: I agree with that. But my point is, your honor, if they're going to be bringing it in -- we didn't put
    this photo in. If they're bringing it in, we can ask that person questions about the photograph that they brought
    in.
    Ms. Stebbins: Let me explain, your honor, briefly -- I'm not going far down this line of questioning. But
    two things. One, she claims to have known these children intimately and spent lots and lots of time
    with them, she's got their age totally wrong and they're dramatically younger.
    Judge: Okay. You've gone through that.
    Ms. Stebbins: The other issue, your honor, is Mr. Jackson has a history of pretending to be ill and going out in
    public in masks, in wheelchairs, in bandages, so on and so forth, as a decoy or to hide
    from the press, or maybe because he wants to get out of doing something. But I think that part of Mr. Jackson's
    history is relevant in terms of how people interacted with him in 2009, what they believed about any symptoms
    he had, and that's going to come in in our case in chief. But since they brought in this picture, and in the
    background there's a picture of Mr. Jackson in the wheelchair --
    Ms. Chang: That's not Mr. Jackson.
    Ms. Stebbins: Your honor, you can see in the second pictures he's wearing the same hat, same glasses, same --
    Judge: I understand that. Who is going to lay the foundation that this is Michael Jackson?
    Ms. Stebbins: We can ask Prince about it. I understand he's going to be testifying.
    Judge: I'm asking you now what evidence do you have that it's really him? He's not even close to
    these kids, he's sitting somewhere in the background.
    Ms. Chang: How do you know it's not an emphysema patient who is dying?
    Judge: You know, it could be him, but I don't think "could be" would be enough.
    Ms. Cahan: We're not offering it for the truth that it is, in fact, Mr. Jackson, we're offering it for the pattern of
    practice of Mr. Jackson creating an impression of varying levels of health.
    Ms. Stebbins: It could be a -- it could be -- let's take Ms. Chang's theory, it's a decoy hired by Mr. Jackson to
    pretend to be Mr. Jackson and go out with his children. That's also relevant to the image
    that Mr. Jackson chooses to present to the world of himself and his health.
    Ms. Chang: In his own house in a meeting? I don't think so. She already said she has never seen
    him with a mask before, so for her to sit there and agree with counsel that this is some paparazzi picture in
    2009, that's testifying. It's not even -- you know, she's allowed to lead, but she's testifying as to where this
    picture came from, and I disagree with where this picture came from, and I don't even know where this article
    came from.
    Mr. Putnam: But apparently she didn't disagree enough so that when they gave it to her that she didn't feel the
    need to go to the family, as she's testified, and ask the family, "is that Mr. Jackson and where is this from?"

    Ms. Chang: Because it's not. It's not Mr. Jackson.


    Mr. Putnam: But you said that you looked at the photo when they provided it and you know all about this
    because you went and asked the family. If you did that, you felt the need to do that, that's because the photo
    looks like a representation of Mr. Jackson, so much so that you asked the family that. That's what you opened
    this with.
    Ms. Chang: No, I didn't. I said this picture of the kids. This picture right here does not have Mr. Jackson in it.
    Ms. Stebbins: So the family has a photo of the kids walking out of Barnes & Noble in a public -- in a
    public place? That's a family photo, you're going to stick with that representation?
    Ms. Chang: You know what? In fairness to what she's saying, I don't know -- I was given a ton of
    photos. Where the family got it from, I don't know. But I'm telling you all the photos that I got, I went
    through with the family to see when was that taken? How old are they there? Because I don't think it's possible
    to see from a picture, "Oh, they're a lot younger." and if this was taken in July of 2008, that's not a ton younger.
    Mr. Panish: Six months.
    Ms. Stebbins: Your honor, all I was going to do with this demonstrative is blow up this larger picture and say,
    "Does this look like Mr. Jackson to you?" And have her say it does or doesn't.
    Mr. Panish: No foundation.
    Ms. Stebbins: She said she's seen Mr. Jackson wrapped in blankets wearing a mask, so she should be able to
    tell whether it's the same or not.
    Judge: Okay. This is -- can I see the full --
    Ms. Stebbins: Here's the photo they introduced. You can see Mr. Jackson wearing the same baseball cap.
    Mr. Panish: Is she going to lay the foundation for that? Ms. Stebbins is going to testify now that that's Mr.
    Jackson?
    Ms. Stebbins: You can see they're taken the same time wearing the same things. All I'm going to do is show the
    second photo and say, "Can you tell from that whether it's Mr. Jackson or not?"
    Mr. Panish: Why is he in a wheelchair?
    Ms. Chang: I think that's a little prejudicial, first of all.
    Ms. Stebbins: I can focus in on this part.
    Ms. Chang: No. I think that is absolutely prejudicial.
    Ms. Stebbins: There are plenty of photos that can be positively identified as Mr. Jackson in a wheelchair.
    Ms. Chang: Then bring them in.
    Ms. Stebbins: But this one was brought in with this witness.

    Judge: What you can do is not show the jury and show her the photograph and ask her is this
    Mr. Jackson, yes or no.
    Ms. Chang: I think that is unfair in the sense that it says "Why is Michael Jackson in a wheelchair?"
    I think that is so misleading. Then she's going to think that it is, that we all had this judicial council back here,
    and we're going to ask her -- what is a witness supposed to think when it says "why is --" how do we know that
    they didn't make this up at lunch? I don't even know where this came from.
    Ms. Stebbins: Your honor, again, this is -- this particular photo that they introduced into evidence is
    widely published in a number of tabloids. There's one where they're all wearing little pink hearts. And this is a
    spread from "People" magazine, as reposted by a blogger, which is what I could get during lunch. I'm sure I
    could break up the original "People" magazine. Again, your honor, I'm not offering
    any of the text in this article. I just want to ask the witness if the larger picture, which is clearly the
    Same person in the smaller picture -- in other words, same hat, same glasses, same -- you know, there are bits
    you can see in both pictures. And just say, "looking at the larger picture, can you tell if it's Mr. Jackson or
    not?"
    Mr. Putnam: And she can say no, your honor.
    Mr. Panish: 352. Come on.
    Judge: You can't show this one.
    Ms. Stebbins: If you want me to take some scissors I can cut it up and give her the square, just the
    Witness, not the jury.
    Ms. Chang: I think the harm has been done. You already blew it up, asked if that was Mr. Jackson. She said
    yes, then, "I don't know. Is it?" I think the point has been made. And to ask this witness --
    Judge: Okay. This one, no. You can show her this and ask her, "Can you tell whether that's Mr. Jackson in the
    back or not?"
    Ms. Stebbins: Will do.
    Mr. Putnam: Thank you, your honor.
    (back to open court)
    Q. Ms. Chase, were you present when this photo was taken?
    A. I don't know when that photo was taken.
    Q. So you don't remember being present when it was taken?
    A. No.
    Q. Can you just zoom in on the corner there, pam. And, Ms. Chase, can you tell me whether or not you can tell
    if that's Mr. Jackson or not in the background?
    A. I can't tell. I mean, he has a hat on, I can't really see what that is.
    Q. And you testified today that you saw him in a surgical mask in June 2009?

    A. Yes.
    Q. Any other times you saw him in a surgical mask?
    A. No.
    Q. Did you ever see or hear that he went out in public in a surgical mask?
    A. I had heard.
    Q. You heard that?
    A. Uh-huh.
    Q. That that was sometimes his custom?
    A. I don't know about his custom, but I had heard that.
    Q. I got a note that I should talk slower, so -- turning back to the time that you were working in Mr. Jackson's
    house in April of 2009, you said that at the time the children had a nanny named Grace Rwaramba.
    A. Yes.
    Q. And she worked there for about two weeks at the same time that you did?
    A. Yes.
    Q. And I believe you testified she was like a mother to the Jackson children?
    A. Yes.
    Q. Do you have any understanding as to how many times Mr. Jackson had fired Ms. Rwaramba over the course
    of her employment with him?
    A. I'm not aware of that.
    Q. You're not aware of any?
    A. No.
    Ms. Stebbins: I'd like to play the video deposition of Paris Jackson, page 71, line 12, to page 73, line 4.
    And, Pam, can you put the text up?
    Ms. Chang: Let me just see the page.
    Ms. Stebbins: I don't have it. Do you have it. Here you are. Okay?
    Judge: Yes, you may.
    (a video clip from Paris Jackson's deposition is played)

    Q. Ms. Chase, did you ever discuss with Mr. Jackson the reasons Ms. Rwaramba was terminated?
    A. No.
    Q. Now, after Ms. Rwaramba was terminated, there was another nanny in place, right?
    A. Yes.
    Q. A woman named sister rose?
    A. Yes.
    Q. And did she work there for the remainder of the time in April?
    A. Yes, she did.
    Q. And she was also there in June 2009?
    A. Yes.
    Q. Now, you testified today that at the time you left in the first week of May 2009 -- actually, let's go back to --
    I skipped over something. I apologize. Let's go back to when you were hired. You testified that you are not a
    nutritionist, you don't have a background in nutrition, right?
    A. As a professional nutritionist, yes.
    Q. But you did study nutrition in school -- right? -- at the culinary institutes that you attended?
    A. Yes.
    Q. And it was something that you discussed with Mr. Jackson and the family, right?
    A. I discussed this with the children when I was being interviewed by them, and with Michael Amir.
    Q. So your understanding is that -- it was your understanding that Mr. Jackson's nutrition, at least in a sense of
    food nutrition, was part of your job responsibilities?
    A. Yes.
    Q. And it was conveyed to you by Mr. Amir, who hired you, and by the children who conducted their own
    interview?
    A. Yes.
    Q. Now, you worked for Mr. Jackson for approximately four to five weeks before you were laid off?
    A. Something like that, yes.
    Q. And in that time period, were you paid?
    A. Sporadically.

    Q. Sporadically?
    A. Uh-huh.
    Q. Not your agreed upon salary?
    A. It was my agreed upon salary, but sometimes we wouldn't get those checks.
    Q. What do you mean, you wouldn't get the checks?
    A. We just wouldn't get our checks. We wouldn't get paid. We weren't getting -- we weren't getting paid, and
    when I asked him where -- you know, it was like every two weeks, or every week, or something like that, where
    the checks were, they were going through changes.
    Q. And you didn't ask Mr. Jackson about that, right?
    A. No, I did not.
    Q. Now, you talked a little bit about a birthday of Paris Jackson in May 2009, right?
    A. Yes.
    Q. You said it was a wonderful, beautiful party?
    A. Yes.
    Q. And there was a cake and decorations?
    A. Yes.
    Q. The cake that -- it sounded fancy. Was it fancy?
    A. Fancy for a little girl, yes. It was a sheet cake.
    Q. And it had Lilo & Stitch designs on it?
    A. Yes.
    Q. And then in addition to all of that, there was a private circus?
    A. A company he hired, yes.
    Q. Do you have any understanding as to how that was paid for?
    A. I have no idea.
    Q. During the time that private circus was going on in the back yard, were you getting your checks
    regularly?
    A. Oh, I don't -- I don't know. I mean, to put the two together, I -- I know during the time that the circus was
    going on, I was there preparing the lunch and watching the circus in celebration, so --

    Q. Did it ever cross your mind, "How can Mr. Jackson manage to pay a circus and not manage to
    pay me?"
    A. Well, no, because I was -- Mr. Amir always made sure that -- in order to keep the staff comfortable, "Your
    checks are coming." that's what we would hear. "Your checks are coming, don't worry about it, we're just
    having a change of management, you'll be paid next week." And then the next week. So that didn't occur to me,
    how he was paying for a circus for his daughter, no.
    Q. So you were always told your check was coming?
    A. Not always, but at times, yes.
    Q. In fact, it was an unspoken rule of the house don't say anything about not getting paid to Mr. Jackson?
    A. Or else you would be fired.
    Q. You would be fired if you raised the issue of, "Why haven't I gotten my paycheck?"
    A. Yes, according to Mr. Amir, that's what I was told.
    Q. Now, you talked about having a good relationship with Mr. Jackson, being comfortable with him, right?
    A. Yes.
    Q. But you were still afraid that he would fire you if you brought up the subject of not being paid?
    A. I was concerned about that, yeah.
    Q. And you talked this morning about an incident where you -- you went out with Paris to collect snails for the
    garden -- from the garden. And I wanted to ask, was that in April or in June?
    A. That was in April.
    Q. It was in April. And you said you went out in the middle of the night, and that confused me a bit, because
    you also said you left work about 8:00. So --
    A. It was in the night. It was in the night, so it was not the middle of the night, it was at nighttime.
    Q. So maybe just shortly after sunset kind of thing?
    A. No. It was at night.
    Q. So after 8:00 he clock?
    A. Around 8:00, 8:30, something like that.
    Q. So it was around 8:00 pm, not later than that because you wouldn't stay later than that?
    A. On that particular day, I don't remember.
    Q. And you were afraid Mr. Jackson might fire you for taking Paris out in the yard at night?

    A. Well, you know, I didn't know how he would feel about his daughter and myself out snail hunting at
    night, so it just kind of -- you know, his little girl, and here I am at night with her and the snails. I was
    uneasy about it. But he was fine.
    Q. And when you wanted to have a soul food day -- or a comfort food day, I think you called it, you had -- you
    said at your deposition, if I recall correctly, you sent him a note?
    A. Yeah. That was a little -- he was working, and if he wasn't in the home, I was told you could write him a
    little note. This is things that we did in the home, you know, draw pictures, write letters. So I wrote him a letter
    with, you know, nice magic markers, and I put it at the bottom of the stairs so when he came home -- at the
    stairwell to upstairs where he was, I wasn't privy of seeing, because I was in the kitchen, so I left it at the bottom
    of the stairs.
    Q. And was that something that you did commonly, or was that just the one time?
    A. That was that one time.
    Q. Is there a reason you left the note instead of asking him in person?
    A. He wasn't there to ask.
    Q. But you told us you saw him several times during the week?
    A. Yeah. Well, that particular day, he wasn't there, he was rehearsing, he was in the studio, wasn't there that
    day.
    Q. Got it. Did you generally communicate directly with Mr. Jackson or did you often communicate through Mr.
    Amir or another member of his staff?
    A. Regarding?
    Q. Your work, planning for the household.
    A. Yeah, most of my work was communicated through Michael Amir.
    Q. And what about meals? Did Mr. Jackson tell you directly what he wanted you to cook, or did he send that
    through Mr. Amir or the housekeepers?
    A. Well, in the beginning, Mr. Amir and I, we interviewed -- he interviewed me, and I was told the types of
    food Mr. Jackson is requesting, and allergies, and things of that nature. So -- but as we got to know one another,
    he started talking about food and different dishes, and he told me some of the things he liked and didn't like.
    Q. So you talked about it sometimes?
    A. Uh-huh, yes.
    Q. What about in terms of meal planning? Did you choose what meals were going to be had in the
    household on a regular basis?
    A. Yes.

    Q. So it wasn't set by him?


    A. No, they were set by me.
    Q. Now, when you were let go in May 2009, you believed Mr. Jackson looked healthy, right?
    A. I'm sorry?
    Q. When you were let go in May 2009, you believed Mr. Jackson looked healthy?
    A. Yes.
    Q. And you were terminated by Mr. Amir, the same person that hired you?
    A. Right.
    Q. Did you -- did Mr. Jackson discuss your termination with you at all in May 2009?
    A. No, he did not.
    Q. And after you left, did he ever call you to say, "Where are you? What happened?"
    A. No.
    Q. Did any of the children call you and say, "Where are you? What happened?"
    A. No.
    Q. Had you ever learned of other people who Mr. Jackson had terminated very suddenly without
    communicating?
    A. No, I did not know.
    Q. Is that something you would have known about given that you'd only been working for him for a
    couple of weeks?
    A. Well, again, my job was to feed him, so any of the other personal staff situations is something I would not
    have been privy to except for the one with grace rwaramba because she was directly with the children, she was
    the nanny, and I was close with the children, and that was something I would have known about.
    Q. Now, you testified earlier today that when you returned to work in June, Mr. Jackson looked weaker to you.
    Judge: I'm sorry. "Mr. Jackson --"
    Ms. Stebbins: "-- looked weaker to you." sorry, your honor.
    Q. Is that right?
    A. Yes.
    Q. Thinner?

    A. He looked thin, yes.


    Q. How much thinner?
    A. He didn't look healthy.
    Q. Do you have an estimate?
    A. He looked undernourished, a little undernourished.
    Q. Do you have an estimate of how much weight you thought he lost?
    A. I can't remember about the weight -- you know, I don't.
    Q. And you were concerned because there were no groceries in the house?
    A. Yes, there weren't.
    Q. Now, there were other household staff, weren't there?
    A. Yes, there was. There was housekeepers and
    A. Nanny.
    Q. And then there was Mr. Amir?
    A. And Mr. Amir and the other security guards that were on the outside of the house.
    Q. Did any of those people have grocery store credit cards to shop for Mr. Jackson?
    A. I don't know.
    Q. Do you know of any reason why Mr. Jackson couldn't have bought food between May and June of 2009?
    A. I don't know.
    Q. But it's your testimony there was no food -- literally no food left if the house?
    A. Well, there were -- there were food. There was nothing that -- for -- in the refrigerator, there was maybe
    mayonnaise and things of that nature, but nothing to put anything with. There wasn't bread,
    there wasn't, you know, sandwich meat or things of that nature.
    Q. So some leftover condiments and that's it?
    A. Yes, stuff like that.
    Q. Do you have any idea what Mr. Jackson was eating during the month of June --
    A. I don't -- the month of June?
    Q. The month of May. Sorry.

    A. No, I don't.
    Q. Because you weren't involved at that time?
    A. I wasn't there.
    Q. Do you have any idea whether anyone was getting him food during that time period?
    A. I don't know.
    Q. Instead, there was cupboard with Red Bull and coffee drinks and things of that nature?
    A. The refrigerator had some of those items, yes.
    Q. You never saw Mr. Jackson drink Red Bull?
    A. No.
    Q. Do you know whether he ever drank Red Bull not in your presence?
    A. I don't know. I never purchased it, I don't know.
    Q. Do you know whether he told anybody else he was drinking Red Bull to keep up his energy or anything like
    that?
    A. No.
    Q. Do you have any understanding as to whether Mr. Jackson was taking diet pills at that time?
    A. Oh, I don't know about that.
    Q. We're both talking so quiet and there's the fan in the way, I can't hear you. Aside from Mr. Jackson looking
    undernourished to you in June, you weren't aware of any other health issues that he had, were you?
    A. No.
    Q. He always seemed to you to be lucid?
    A. He was pretty strong, you know, pretty strong, you know, in April. But he -- he didn't look -- he looked good
    in April, he didn't look good in June.
    Q. But he didn't look good, but you were able to have normal conversations with him?
    A. We had a few conversations, yes.
    Q. And you never saw anything that made you think he couldn't take care of his children?
    A. No.
    Q. He was still a good parent to them in June?
    A. He was still a good parent, yes.

    Q. And you never -- Mr. Jackson never mentioned to you he had any difficulty sleeping, did he?
    A. No, he never did.
    Q. In fact, you never even had any suspicion that he suffered from insomnia?
    A. No.
    Q.
    Now, you testified earlier that Mr. Jackson told you, I think on one occasion, that he -- he was
    working a lot. And you understood he was working on the this is it tour, correct?
    A. Correct.
    Q. Do you have any understanding of what other projects he was working on in that time period?
    A. No. I believe that his main focus at that time was getting ready and prepared for this tour.
    Q. So you don't know whether he was working on something else, or you know that he was not?
    A. I don't know.
    Q. Do you know whether his family was trying to get him involved in any other projects at that point?
    A. No, I don't know.
    Q. Do you know if he was working on any studio albums?
    A. I believe he was, yes. He was working on the album for the -- for the movie This Is It, because I had heard
    some of the tracks.
    Q. What about any other projects? You just don't know one way or the other?
    A. No.
    Q. Now, you testified earlier today about an occasion in June 2009 where Mr. Jackson's son Prince
    Had to help him up the stairs, correct?
    A. Yes.
    Q. You gave several televised interviews following Mr. Jackson's death, right?
    A. Yes.
    Q. And you never mentioned that stair incident in any of those televised interviews?
    A. Okay.
    Q. Do you agree with me?
    A. I'm sorry?

    Q. I said, "Do you agree with me?"


    A. Yes.
    Q. Now, some of those interviews actually asked directly about Mr. Jackson's health and your
    observation of his health, right?
    A. Yes.
    Q. But you didn't think telling them about the stair incident was relevant to that?
    A. Well, I didn't think it was -- you know, again, I wanted to be very general with my conversations with the
    media, and in respect to his privacy, so that's why I'm saying this today.
    Q. But, in fact, you told the media that Mr. Jackson seemed pretty normal to you in the month of June 2009?
    Ms. Chang: Objection, I think that misstates her --
    Judge: Overruled.
    Ms. Chase: Again?
    Q. Did you tell the media that Mr. Jackson seemed pretty normal to you in June 2009?
    A. Yes.
    Judge: I'm sorry. This fan is -- we're having a hard time hearing.
    Ms. Stebbins: The question was, "Did you tell the media that Mr. Jackson seemed pretty normal to you
    in June 2009?" And I believe the answer was yes.
    Q. Is that right?
    A. Yes.
    Ms. Stebbins: And I will try to speak up, your honor.
    Judge: Okay.
    Q. But it is your testimony today that Mr. Jackson was so tired his son Prince had to help him up the stairs?
    A. That's the way he looked, yes.
    Ms. Stebbins: I'd like to play the deposition of Prince Jackson, page 217, lines 9 through 12. It's very
    short. Let me just give you -- I'll just show you this part. Pam, can you put it on the screen?
    Ms. Chang: Just the written part. Just me.
    Ms. Stebbins: I can show you. You can play it.

    (a video clip from Prince Jackson's deposition is played)


    Q. It's still your testimony that happened?
    A. I saw that. That happened.
    Q. You were concerned, you said, in June 2009 about Mr. Jackson's health and well being?
    A. Yes.
    Q. You were concerned that he -- you know, he might be too thin?
    A. Weak.
    Q. Weak?
    A. Weak.
    Q. Other than being thin, what made you think he was weak?
    A. His body language. You know, he was just -- just weak, walking slow, that type of thing.
    Q. He was 50 years old, right?
    A. Yes.
    Q. Been dancing a lot?
    A. He was rehearsing a lot. He was tired, and that's what I saw. I saw him tired, I saw him weak and
    over exhausted.
    Q. You would expect someone who was dancing a lot to have some soreness from rehearsals, right?
    A. Yes.
    Q. And you never told anyone other than your parents about your concerns about Mr. Jackson?
    A. No.
    Q. You never shared those concerns with Mr. Jackson himself?
    A. No. I mean, I figured if Mr. Jackson -- he had a doctor there. Wasn't that what the doctor -- I was
    assuming that's what the doctor was there for, to take care of him in that way. So I didn't feel that it was my
    place to say those things because why is there a doctor here then?
    Q. Because you trusted that his doctor would take care of him?
    A. Well, that's why I think a doctor would be there 24/7 to take care of his patient in that right.
    Q. Now, you knew Dr. Murray as a member of the household, right?
    A. I met him there, yes.

    Q. When you say he was there 24/7, do you know that for a fact or is that just an assumption on your
    part?
    A. Well, this was in June, and the days that I was there in the mornings he was there every morning.
    Q. Was he there all day, as well --
    A. No.
    Q. -- or did he leave?
    A. He'd leave.
    Q. So he'd leave during the day?
    A. Uh-huh, yes.
    Q. And then he'd come back at some point?
    A. I would be gone when he'd get back, so that's why I was told to make plates for him and Mr. Jackson,
    because they were to eat and he was going to spend the night.
    Q. So you would only see Dr. Murray in the mornings?
    A. Yes.
    Q. And you saw him in the morning in April when he would come down the stairs two to three times a
    week?
    A. Something like that. Sometimes he would just come in April, maybe, to drop things off, maybe social visits,
    things of that nature. But more so in June, he was spending the night, and he was there on the days in the
    mornings when I would see him.
    Q. Did you ever express your concerns about Mr. Jackson's health to Dr. Murray?
    A. Well, I asked -- I had asked him about him eating, and, again, he would -- "Well, he doesn't eat that much,"
    which I knew not to be true.
    Q. Did you have that conversation in June or April?
    A. That was in June.
    Q. So you testified earlier that when you first met Dr. Murray in April, you'd asked about any particular meals
    that Mr. Jackson should have or anything like that, right?
    A. Right.
    Q. Now you're saying you had another conversation with him in April -- I mean in June?
    A. In June.

    Q. Sorry. I keep mixing them up in my mind.


    A. Uh-huh, yes, in June, I mentioned that to him, yes.
    Q. So you did mention to Dr. Murray that you were concerned Mr. Jackson wasn't eating enough?
    A. No. I said to him -- I said, you know, "Is there anything that -- I could make him something different."
    "He doesn't eat that much."
    Q. Did that answer satisfy you?
    A. No. I kept doing what I was told to do, as he requested, "I need you to keep me healthy."
    Q. So --
    A. "Feed me healthy."
    Q. So you just made more food?
    A. Well, I would feed the man as I'm supposed to, breakfast, lunch and dinner.
    Q. Right. No. I know you prepared meals, but you said you kept doing what you were supposed to, and I was
    trying to figure out what, if anything, you did differently in response --
    A. No. The same.
    Q. So you just sort of kept on keeping on?
    A. Yes.
    Q. Did you ever express concerns about Dr. Murray's competence to anyone?
    A. No.
    Q. Did he seem like a good doctor to you?
    A. He seemed like a nice man, you know.
    Q. And despite having some concerns about Mr. Jackson's physical appearance in June, you were still shocked
    when you learned that he had passed away?
    A. When what?
    Q. When you learned that he had passed away?
    A. Yes.
    Q. Just -- in fact, when you heard the news, you didn't believe it?
    A. No. When I heard the news, I didn't believe it.
    Q. You never expected that he was going to die?

    A. No.
    Q. You never thought that he was in serious trouble?
    A. I didn't think he was in -- no, I didn't expect for any of that to happen in that way, no.
    Q. Now, Ms. Chase, when you were working with Mr. Jackson, you saw him frequently?
    A. Yes.
    Q. And you prepared meals for him?
    A. Yes.
    Q. Did you ever see him drink any alcohol?
    A. No, I've never seen him drink any alcohol.
    Q. No alcohol at all?
    A. I never saw any of that.
    Q. Did you ever see him appear to be under the influence of alcohol?
    A. No.
    Q. Not at all? Any time you thought he might have been drunk?
    A. No.
    Q. Do you ever have any time that you thought he might be high?
    A. No.
    Q. Did you have any knowledge of whether or not Mr. Jackson was using any kind of prescription
    medications?
    A. No.
    Q. But you never suspected that he was abusing any kind of drugs, right?
    A. No.
    Q. You saw no signs whatsoever that Mr. Jackson had a drug problem?
    A. No.
    Q. When you were working at the house, you said you'd see Dr. Murray in the mornings, right?
    A. Yes.

    Q. And you first saw him in the first week of April 2009?
    A. In April, yes.
    Q. Do you remember whether you saw him first or Mr. Jackson first?
    A. Oh, I can't recall.
    Q. Now, in April you saw him about three times a week?
    A. Two, three times a week, something like that.
    Q. And he was introduced to you as Mr. Jackson's personal physician?
    A. He introduced himself to me as that.
    Q. Did Mr. Jackson ever tell you who he was?
    A. No.
    Q. Did you ever see he and Mr. Jackson together?
    A. Yes, actually. There was an occasion where he and the children and Mr. Jackson all had dinner
    together.
    Q. Did you cook that dinner?
    A. Yes, I did.
    Q. And was that just the one time?
    A. That was the one time, yes.
    Q. Do you remember if that was in April or June?
    A. That was in June.
    Q. June. Do you remember what they had?
    A. Yeah. I made a Turkish lentil soup.
    Q. Just soup?
    A. That's what he had. It was a meal in itself, so -- lentils.
    Q. You thought that Dr. Murray seemed like a nice man?
    A. Yes.
    Q. He seemed smart?
    A. We didn't have as much interaction, but he seemed like he was a physician that was taking care of

    his patient, whatever -- in the way, maybe, he was a dancer taking care of his, you know, bones, body, however.
    He seemed like a smart man, seemed nice.
    Q. Well put together?
    A. Seemed like that.
    Q. Very respectful and well-spoken?
    A. Exactly.
    Q. Did he seem to get along well with Mr. Jackson to you?
    A. Well, the times that I saw them together, yes.
    Q. And from what you observed, acknowledging that it was somewhat limited, they had a good, friendly
    doctor/patient relationship?
    A. Yes.
    Q. And the children, Prince, Paris and Blanket, they seemed to like Dr. Murray, as well, right?
    A. Yes.
    Q. Did you have an opportunity to observe their interaction with him?
    A. Well, that day at the dinner table, they were all together, yeah, so --
    Q. Did you have any idea how long Dr. Murray had been serving as Mr. Jackson's personal physician?
    A. No.
    Q. Did the family seem to know him relatively well?
    A. I can't say that I assumed that. I got there in April, I met him then, and that's kind of where it picked up for
    me, so --
    Q. So you just didn't have any knowledge one way or the other on that?
    A. No.
    Q. What was your understanding of what Dr. Murray was doing at the house?
    A. My understanding was he was his personal physician. I don't know what the details were, but that's what he
    introduced me as, and I left it at that.
    Q. But you didn't think Mr. Jackson was sick or had some kind of chronic illness, right?
    A. No. I mean, he -- he was a dancer, and I figured this was a very, you know, exceptional tour, and maybe the
    man needs a -- a doctor to -- for aching bones or something. I mean, that's exactly what I
    would think.

    Q. So it didn't seem unreasonable to you to have a doctor in the house sort of taking care of Mr. Jackson's health
    in a positive way?
    A. Well, I don't know about having a doctor all the time, but -- but that was a question to me, why was he
    always there.
    Q. So you thought he was there too much?
    A. Well, I'm not one to -- to judge of how much is too much and too little, but yeah, it was strange. He was
    there a lot.
    Q. But it wasn't something that bothered you enough to tell anybody about at the time?
    A. No, no, I didn't.
    Q. And you never raised any concerns with Mr. Jackson?
    A. No.
    Q. And when you noticed that Mr. Jackson didn't look well to you in June 2009, you never asked Dr. Murray
    what might be wrong with Mr. Jackson?
    A. No, I did not.
    Q. When you saw Dr. Murray in the mornings at the house, he would carry oxygen tanks down the stairs, right?
    A. Yes.
    Q. And that was true in April and in June, right?
    A. In April, less, and in June, more.
    Q. But it happened in both times?
    A. Yeah. Well, you know, the ones in April that he had were not the ones that I saw in the picture today.
    Those were a little bigger. The ones in June, they were bigger. The ones that he had in April were a little
    smaller.
    Q. So he had smaller oxygen tanks in April?
    A. Yes.
    Q. And you'd see him coming down the stairs in the morning in April with one oxygen tank in each hand?
    A. Yes.
    Q. And that happened two or three times a week?
    A. I don't know how many times, but it was -- when he was there, on occasion, I'd see him with oxygen
    tanks, yes.
    Q. Did you ever ask Mr. Jackson what the oxygen tanks were for?

    A. No, I did not.


    Q. Did you ever ask Dr. Murray what the oxygen tanks were for?
    A. No, I did not.
    Q. Did you ever mention to anyone, "Hey, I don't know what's going on with these oxygen tanks. Do
    you know why they're here?"
    A. No. I figured these are -- he's a grown professional doctor, and he should, you know, know what
    He -- whatever he was doing, I would hope that it was in positivity for Mr. Jackson.
    Q. You just assumed that whatever Dr. Murray was doing, it was something that was necessary and
    proper for the treatment of his patient?
    A. No, I didn't think that. I just -- it was not my business.
    Q. So you didn't think one way or the other whether it was necessary or proper?
    A. It wasn't my business.
    Q. You just said, Ms. Chase, that he was a professional doctor so you assumed he was not doing
    something dangerous or improper, right?
    A. That's what I assumed, yes.
    Q. Okay. Now, you testified earlier, and I was a little confused by it, you didn't see Dr. Murray's car at the
    house in the morning in April, is that right?
    A. Did I see his car in the morning?
    Q. Yes.
    A. What day? Any day?
    Q. Well, any day, yeah. You testified now that sometimes in April in the mornings he would come down the
    stairs carrying the oxygen tanks.
    A. Uh-huh, right.
    Q. The times where he would come down in the mornings carrying the oxygen tanks, was his car at the house?
    A. If he was there, his car was there.
    Q. That was my question. I just --
    A. Okay.
    Q. So he always had the car, and if he was there, the car was there?
    A. Yes.

    Q. Did you see Dr. Murray in the evenings in June other than the one time you cooked dinner for him
    and the family?
    A. No. In June, I'd only seen him in the mornings when he'd leave.
    Q. And how late would you work in June?
    A. Again, my hours always fluctuated, depending on rehearsal schedules. Because it was important for Mr.
    Jackson to eat with his children, so my hours would fluctuate sometimes to 11:00 o'clock,
    sometimes to 8:00 o'clock, so it would depend.
    Q. So sometimes you'd be there until 11:00 o'clock at night?
    A. Sometimes.
    Q. And you still didn't see Dr. Murray at night?
    A. No.
    Q. So --
    A. Mr. Jackson wasn't there, so Dr. Murray wasn't there.
    Q. So did you ever see Dr. Murray at the house when Mr. Jackson wasn't there?
    A. No.
    Q. Never?
    A. No.
    Q. So if Dr. Murray was there, Mr. Jackson was there?
    A. I didn't see Mr. Jackson and Dr. Murray in the house together, yes.
    Q. So you didn't see them in the house together, or you did?
    A. Okay.
    Q. Sorry.
    A. The question you asked me, say it again, please?
    Q. Yeah. My question was, was Dr. Murray ever at the house when Mr. Jackson wasn't there?
    A. No.
    Q. And you never saw him in the evenings other than the one time he had dinner with the family?
    A. Correct.

    Q. So you don't know when he arrived in the evenings or even if he actually arrived in the mornings?
    A. No, because I'd be gone in the evenings before he arrived.
    Q. And you would see him after you arrived between 8:00 and 8:30 in the morning?
    A. Right.
    Q. And that was true in both April and June, you saw him only in the mornings and not the evenings?
    A. I saw him in the mornings, yes, in April and in the morning in June.
    Q. But in June, you understood that he was staying the night?
    A. I was told he'd be spending the night, that's why I was told to make food for him.
    Q. And did you do that every night in June?
    A. Well, it wasn't every night, but when I was told to do it, yes.
    Q. Do you have an estimation of how many times you got that instruction in June?
    A. I can't recall. I don't -- I can't even -- I can't recall how many times, no.
    Q. You can't tell whether it was more or less than half the nights in June?
    A. It was more, uh-huh.
    Q. The majority of nights, then?
    A. The majority of the nights, yes.
    Q. Do you have any idea why Dr. Murray was staying the night?
    A. I don't know.
    Q. Did you ever ask?
    A. No.
    Q. Just figured it's his doctor, must have a reason?
    A. I just figured I was to make the dinner, and that's what I did.
    Q. So you minded your own business?
    A. Yes.
    Q. You had no idea what was going on upstairs in Mr. Jackson's bedroom?
    A. No.

    Q. You had no idea Dr. Murray was giving him propofol to sleep at night?
    A. No.
    Q. Had you ever heard of propofol?
    A. During the -- the trial.
    Q. I mean before.
    A. No.
    Q. Before June 25th, 2009.
    A. No, never.
    Q. And apart from finding it odd that there were oxygen tanks, you weren't ever suspicious of Dr. Murray, were
    you?
    A. No, I wasn't really suspicious. I mean, it just -- it was just strange why he would be carrying those tanks from
    upstairs to downstairs.
    Q. But you thought -- you never suspected he was harming Mr. Jackson?
    A. No, I didn't.
    Q. Even when you saw Mr. Jackson thinner and not as well taken care of --
    A. I thought he was over-rehearsed. I thought that he was actually rehearsing too much, and they were
    overworking him, and he was rehearsing way too much, and this is the result of that. That's what I was thinking.
    Q. So you thought Mr. Jackson was over tired from rehearsal?
    A. Yes, I did.
    Q. But you didn't think Dr. Murray was harming him?
    A. I didn't think Dr. Murray was harming him, no.
    Q. Never crossed your mind?
    A. No.
    Q. Now, you mentioned earlier protein shakes, and that -- and it wasn't clear exactly in your
    testimony. Did Dr. Murray ever ask you to help with protein shakes?
    A. No.
    Q. Did he ever come into the kitchen to make protein shakes for --
    A. No.

    Q. -- Mr. Jackson?
    A. No.
    Q. Did he ever -- did he ever tell you he was making protein shakes for Mr. Jackson?
    A. No, he never told me that.
    Q. I'd like to play the deposition. And I don't know if I have this or not. Page 121, lines 9 through 21. And if
    you don't have the clip for me, just put the text up. You gave a deposition in this case, right,
    Ms. Chase?
    A. Yes.
    Q. And you were under oath to tell the truth at that deposition?
    A. Yes.
    Q. And you did tell the truth at the deposition?
    A. Yes.
    Q. So this is from your deposition. I'm going to see if -- I'm going to read the question, you read the answer.
    Okay? "Did you ever speak directly with Dr. Murray prior to Michael's death?"
    A. "In the home."
    Q. "How often would you speak to him?"
    A. "Very rarely when he'd come down, when he'd come down in the kitchen because he would drop off the
    tanks and immediately leave. But sometimes he'd come down when he would get juices and/or granola or
    whatever, and we'd -- 'how are you?' you know, 'let me get a protein shake he wants,' just a request for
    food."
    Q. So he did talk to you about protein shakes?
    A. Not making protein shakes. Those were the protein shakes that were already prepared and brought
    from the store.
    Q. So he had pre-made protein shakes?
    A. If they were, they were bought from the store.
    Q. So you did talk to Dr. Murray about getting protein shakes, but not that he was making. I understand now,
    right?
    A. Yes.
    Q. But it was your understanding that he was bringing protein shakes to Mr. Jackson?
    A. Well, I don't know if it was my understanding that he was bringing them to him, which they would be in the
    refrigerator, and they weren't the ones that he said that he made, no.

    Q. Got it. So they weren't in the refrigerator, but there were protein shakes in the house? I'm still just kind of
    confused here. Sorry. So Mr. Jackson -- Dr. Murray had protein shakes in the house?
    A. There was probably a protein shake there that he would probably grab or had brought for him.
    Q. But you didn't buy them?
    A. No. I'd make the juices for him.
    Q. So you'd make juices for Dr. Murray to take up to Mr. Jackson?
    A. I'd make juices for Mr. Jackson, and sometimes Dr. Murray would come down and retrieve some
    of the juices to take to Mr. Jackson.
    Q. And you knew that Dr. Murray also took protein shakes to Mr. Jackson sometimes, but you didn't
    know where those came from?
    A. Unless Dr. Murray brought them in. But I never purchased protein shakes.
    Q. Did you see Dr. Murray bring in protein shakes?
    A. No, I did not.
    Q. Now, you testified earlier that Dr. Murray would come down to get Michael Jackson's food in the
    mornings in June, but in April, that didn't happen as much, is that right?
    A. Well, he wasn't around as much as he was in June.
    Q. But you also testified that Mr. Jackson came down every morning and ate -- had breakfast with the family,
    right?
    A. Yes.
    Q. So in April, he didn't come down -- he came down in the mornings and Dr. Murray didn't bring food
    up to him, is that right?
    A. Right.
    Q. And then in June, it was more common for Mr. Jackson not to come down in the mornings and Dr. Murray to
    take him his food, right?
    A. Well, not more common, but it was -- he was more so rehearsing more in June, so he was not as --
    Having as much breakfast with his children in June as he was in April.
    Q. But it's your testimony that in April, Mr. Jackson generally came downstairs in the morning and Dr. Murray
    did not take up his breakfast?
    A. Correct.
    Ms. Stebbins: I want to play the deposition, 117-1, to 118-4.

    Ms. Chang: Give me one second. 117 --


    Ms. Stebbins: -- 1, to 118-4.
    Ms. Chang: Okay. That's a lot. Just give me a second.
    Ms. Stebbins: Yes. Take your time. Eight minutes left.
    Ms. Chang: Just give me one second. I'm so sorry.
    Ms. Stebbins: She's making a clip anyway, so don't rush at all.
    Ms. Chang: Okay. That's fine.
    (a video clip from chase's deposition is played):
    Q. Do you know where Murray would sleep?
    A. No. There were -- there were bedrooms downstairs, so maybe one of those, but I didn't know exactly where,
    no.
    Q. And when he came down in the mornings, why would he be coming downstairs? What would you see --
    where would you see him when he would come down the stairs?
    A. He'd come into the kitchen to go outside into the security booth, and he would have the oxygen tanks, or he
    would come from the other -- the other area and come into the kitchen, and then he would leave the oxygen
    tanks at the entrance. And the reason why I could see this is because the dining room -- I would always set the
    dining room table, so right in that area, you'd have to walk around, go into the dining room, and there would be
    the tanks.
    Q. Would he ever come to the kitchen to pick up food for Michael?
    A. Yes, he did a lot of that in April.
    Q. In April?
    A. Uh-huh.
    Q. Not in June?
    A. No.
    Q. Did he ever come in the morning to pick up food for Michael in June?
    A. He had picked up a few, you know, juices or granola or something like that.
    Q. Your deposition was taken october 26, 2012, right?
    A. Right.

    Q. So in october 2012, you recalled that Dr. Murray came down a lot in April to pick up food for Mr. Jackson,
    is that right?
    A. Right.
    Q. Is that -- is your recollection changed?
    A. Well, no, no. It's the same. He would come get food or he would drop off -- social visits or something like
    that, and that's what I would see with him.
    Q. So I guess I'm trying to understand if Mr. Jackson would come always to have breakfast with his family in
    April, why would Dr. Murray be taking food upstairs in the mornings?
    A. Well, you know, this is the thing. He's -- his schedule was always changing. Okay? And from one day to the
    next. Now, me keeping a schedule of -- of his daily rehearsal schedules was not something I was privy to, so --
    but on a day to day, you know, every now and then, he'd come, he would pick up something for him, or he'd
    leave, he'd stay, he'd go, but it was very infrequent in April.
    Q. But you just said he did that a lot in April in your deposition. That a lot of times in April, he came down in
    the morning to get food for Mr. Jackson. That was your testimony, right?
    A. Okay. Yes.
    Q. So is that not --
    A. Okay. That's right.
    Q. It is right?
    A. Right.
    Q. Okay. So a lot of times in April, he came down in the mornings to get food for Mr. Jackson?
    A. Right.
    Q. So Mr. Jackson did not always have breakfast with his children in April of 2009?
    A. He had breakfast with his children when he wasn't having breakfast upstairs.
    Q. Got it.
    A. Okay.
    Ms. Stebbins: Okay. So -- glad we cleared that up.
    Judge: There's only five minutes.
    Ms. Stebbins: I'm going into another line of questioning that is going to take a while, so maybe we want
    to go ahead --
    Judge: Okay. 1:30 tomorrow. Goodnight.

    (court adjourned for the day)

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