JACKSON V AEG LIVE July 25

th
2013
Scott David Saunders (MJ Doctor)
By way of video depostion
The court: thank you. Ms. Cahan, you're going to introduce a video?
Ms. Cahan: yes. Defendants call to testify via video Dr. Scott David Saunders, s-a-u-n-
d-e-r-s.
The court: thank you.

Excerpts of the videotaped deposition of Scott David Saunders were played.

Mr. Boyle: can we stop your honor?
The court: yes.
Mr. Boyle: we're just going to object. If this is not his medical record, it does not refresh
his recollection; it should not be shown to the jury or in evidence. I thought all of these were his
medical records. I didn't realize they were going to try to refresh his recollection with something
other than his --
Ms. Cahan: we discussed this specific issue before the jury came in and they said they had no
objection to any of the pages being shown.
Mr. Panish: no. Any pages that were his.
Ms. Cahan: that's not what they said.
The court: all right. I'm overruling the objection. Keep going.
(Excerpts of the videotaped deposition of Scott David Saunders were played.)
Q. Could you, please, spell your full name for the record.
A. Scott David Saunders

Q. Where did you attend college?

A. Brigham Young University.
Q. What year did you graduate?
A. 1997.
Q. Did you attend any school after attending Brigham Young University?
A. UCLA.
Q. was there a particular department or field of study that you studied at UCLA?
A. Medical school.
Q. Did you graduate from medical school?

A. Yes.
Q. What year was that?
A. 1992.
Q. And did you receive any further training in the medical field after you graduated from the
UCLA medical school in 1992?
A. Yes.
Q. You can, please, describe that further training.
A. I went to Northridge Hospital Family Practice Residency Program and completed an
internship in residency in the field of family practice. And following that, in 1995, I was board
certified in family practice.

Q. And just briefly, what does family practice involve?

A. It's a broadbased specialty that includes taking care of people at any age and for any
problem, anything from delivery of babies to hospice care at the end of life.
Q. Do you currently practice at the Buellton Medical Center?
A. Yes.
Q. Do you work with any other physicians at Buellton Medical Center?
A. Yes.
Q. What physicians are those?
A. Dr. Barnie Van Valin.

Q. Besides Dr. Van Valin, are there any other physicians that you work with at Buellton Medical
Center.
A. That I work with, no.
Q. That work at.
A. I have met some that come there sometimes, one other one that I have met.
Q. Do you recall his or her name?
A. Her name is Debra Weinstein.
Q. When is the first time you met Dr. Weinstein?
A. I dont recall.

Q. Do you know if Dr. Weinstein worked at the Santa Ynez Valley Cottage Hospital?
A. Yes.
Q. Can you, please, mark this as Exhibit 7.
Q. Do you have Exhibit 7 in front of you, Dr. Saunders?
A. Yes, I do.
Q. Do you recognize Exhibit 7?
A. Yes, I do.
Q. What is Exhibit 7?
A. It is a blog post. It says "The Love Triangle," published Saturday, September 10, 2011.

Q. And does your picture appear on Exhibit 7?

A. Yes, it does.
Q. Did you write the blog post entitled "The Love Triangle"?
A. Yes.
Q. And this is a printout of that blog, correct?
A. Yes.
Q. I would like to direct your attention just to the first page. The last sentence or the last
paragraph - excuse me --says, "I had a friend, Michael Jackson, who was 'loved' by millions of
people but was very lonely because he didn't love. There were very few people that he felt he
could trust and love." Did I read that correctly?

A. Yes.
Q. Did you write that?
A. I did.
Q. Did you have a friend named Michael Jackson?
A. Yes, I did.
Q. Was that Michael Jackson, the legendary pop star Michael Jackson?
A. Yes.
Q. How did he become your friend?
A. He invited me to his ranch.

Q. When was the first time that you met Mr. Jackson?
A. I dont know.
Q. Do you remember the day that he invited you to his ranch?
A. No.
Q. Do you remember where his ranch is located?
A. Yes.
Q. Did you ever visit his ranch?
A. Yes.

Q. How long ago did you visit his ranch?

A. A long time ago.
Q. More than 10 years ago?
A. Yes.
A. More than 15 year ago?
A. No.
Q. Did Michael Jackson ever come to you for medical treatment?
A. Yes.

Q. When was that?

A. I don't recall.
Q. Did he come to your office to receive
medical treatment?
A. Yes.
Q. When was the first time he came to your office to receive medical treatment?
A. I don't recall.
Q. What office were you practicing at?
A. The Buellton Medical Center ~ no, I am sorry. The Buellton Medical Clinic.

Q. Clinic?
A. Clinic.
Q. You worked from the Buellton Medical Clinic from approximately 1998 to approximately
2003 correct?
A. Correct.
Q. So the first time that you saw Michael Jackson would have been sometime between 1998
and 2000.
A. Correct.
Q. Do you know if Michael Jackson was referred to you by anyone?
A. No.

Q. Did he call you on the phone to request treatment?

A. No.
Q. How did you meet him?
A. I received a phone call from a woman who declined to identify herself, then asked if I would
be willing to make a house call. And I said yes and she gave me the address.
Q. And when did the woman ask you to make that house call? Was it that day?
A. Explain-- Yes.
Q. And did you treat Michael Jackson that day?
A. Yes.

Q. And what was the nature of the medical treatment that day?
A. He had an upper respiratory infection.
Q. How did you get to Michael Jacksons home that day?
A. I drove
Q. When you pulled up to the house, in front of the Neverland house in your car, what
happened next? I want you to walk me through.
A. So I drive up. There is a little kiosk thing there. I push the button and they say yes, may I
help you. And I say yes, I am here and. They say okay, drive ahead. And I drove ahead and then I
was behind a car. And they I followed a car in to a large house and was and then
someone came from the house and led me into the house and said wait here. And I waited there
for a I don't know a half an hour and I was just getting ready to get up to leave and
somebody came in and said "Follow me, please." They were nice.
Q. Do you remember if that was a man or a woman?

A. That was a man. And they took me into a bedroom and there was a guy lying in the bed and
he said, "I am Michael Jackson." And I said, "Nice to meet you, Mr. Jackson." And he said, "I'm
sick."
Q. Did he ask for your help?
A. Well, of course. That's why I was there.
Q. Before the person lying in the bed in the bedroom that day identified himself as Michael
Jackson, did you recognize him as Michael Jackson?
A. No. The room was dark.
Q. Do you recall if there was a lock outside the bedroom door?
A. There was a keypad that the man pushed a series of numbers and the door opened.
Q. Do you recall the approximate time that you went? Was it day or night?

A. It was after work hours.

Q. At that time, was it common for you to see patients after work hours?
A. Yes.
Q. Was that part of your regular practice?
A. Yes.
Q. Do you currently practice with Dr. Van Valin?
A. Yes.
Q. Have you ever talked with Dr. Van Valin about the treatment of Michael Jackson?

A. Treatment, no.
Q. Have you ever talked about being friends with Michael Jackson
A. Yes.
Q. with Dr. Van Valin?
A. Yes.
Q. Have you ever talked about any medical treatment given to Michael Jackson with Dr. Van
Valin?
A. Not that I recall.
Q. Did you ever see Michael Jackson and Dr. Van Valin together at the same time?

A. Yes.
Q. When was that?
A. We were all at a gathering on Michael Jackson's ranch. We watched a movie in his theater.
Q. Is that the theater that was up the road from the main house?
A. It was not attached to the house.
Q. Do you remember the movie that you watched?
A. I think it was "Spiderman."
Q. After that first time you treated Michael Jackson after work, were there other times that you
also treated Mr. Jackson?

A. Yes.
Q. Approximately how many times?
A. I don't know.
Q. More than once?
A. Yes.
Q. More than five times?
A. Yes.
Q. More than 10 times?
A. That's getting in there somewhere.

Q. Less than 50 times?

A. Less than 50 times.
Q. Less than 25?
A. Probably less than yes, less than 25.
Q. You told me about treating Mr. Jackson for an upper respiratory tract infection.
A. Yes.
Q. What other conditions or medical medical conditions did you treat him for. If you could
just tell me all of them that you can remember.
A. Pain. Thats all I remember.

Q. Was there a specific location of Mr. Jackson's pain that you treated him for?
A. I don't recall.
Q. What treatments did you give Mr. Jackson for his pain?
A. Medication, pain medications.
Q. What pain medications do you recall giving Mr. Jackson?
A. I don't recall.
Q. Do you recall giving Mr. Jackson Demerol?
A. I dont recall.

Q. Is Demerol used to treat pain?

A. Yes. There was one pain medication I used in injectable form was buprenorphine.
Q. Does that have another a name brand, if you will?
A. Several.
Q. Do you remember what those name brands are?
A. Buprenex was one of them.
Q. Is it in the same class as Demerol of medications?
A. As an opiate medication, yes.

Q. Do you recall any other do you remember giving Mr. Jackson any other opiate
medications?
A. Not specifically. '
Q. Do you know if he did receive other opiate medications from anyone?
A. Yes.
Q. How do you know?
A. He told me.
Q. What did he tell you?
A. He said he wanted to get off of pain medications.

Q. Did he tell you why he wanted to get off medications?

A. Yes.
Q. What did he say?
A. He said "I don't want to end up like my fatherinlaw."
Q. Who was his fatherinlaw?
A. Elvis Presley.
Q. Do you know what he did to address his concerns about getting off pain medications?
A. No. One of the reasons we used buprenorphine specifically was because it is an opiate
agonist-antagonist and it's often used to help people who have pain but don't want to take
addictive medications. It tends to be less addictive.

Q. Did Michael Jackson ask you specifically for that buprenorphine?

A. Yes.
Q. Do patients typically ask for a specific of medication?
A. People who take pain medications know what works for them. And so the answer to your
question is yes.
Q. Did Michael ever tell you about getting an implant to help address his addiction to pain
medication?
A. No.
Q. Are you aware of any kind of implant that could be used to help wean someone off pain
medication?
A. No.

Q. Have you ever heard the name Dr. Farshchian?

A. No
Q. Did Michael Jackson ever tell you about doctors coming to treat him at Neverland?
A. No.
Q. Did Michael Jackson ever tell you about any other doctor treating him?
A. No.
Q. When Michael Jackson was in pain, you gave him medications?
A. Correct.

Q. Did you ever go to the emergency room with Michael Jackson?

A. Yes.
Q. When was that?
A. I don't recall.
Q. What emergency room did you go to?
A. Santa Ynez Hospital Santa Ynez Valley Cottage Hospital.
Q. And when was that?
A. I don't recall.
Q. Why did you why did you go?

A. Lets see. He called me because he had fallen, I think on the stairs, and had a foot problem.
Man, this was a long time ago. Okay. I have never even thought about this. Okay. The foot
problem I think it was a foot problem. And I went I went to see him and evaluated it and it
appeared swollen. And I recommended an xray and he asked me to drive him to the emergency
department. So I took him in my car.
Q. Was anyone else with you when you drove him to the emergency room?
A. No.
Q. Just you and Michael?
A. Yes.
Q. And what happened when you got to the emergency room? Did you drop him off at the
front?
A. Well, I helped him in.

Q. Because he was having trouble walking?

A. Yes, and that's all I recall. I don't believe I stayed there with him. I probably went home to
my family.
Q. When you first got to his house before you drove him to the emergency room, did he need
any pain medication?
A. I don't recall.
Q. Did you give him any pain medication before going to the ER?
A. I don't recall.
Q. So the only reason you went with Michael to the ER was for the foot injury that you
diagnosed?
A. I had no diagnosis. He needed diagnosis.

Q. Which is why you went to the emergency room.

A. Correct.
Q. At your recommendation?
A. Yes.
Q. Do you ever remember Michael leaving a hospital against the advice of the physicians on
staff?
A. No.
Q. So said you were friends with him, with Michael Jackson, right?
A. Yes.

Q. What sorts of things did you do with him?

A. Talk.
Q. What would you talk about?
A. Everything. He was rather lonely and didn't have anyone he could trust. And so he would
call me and I would go over and he sometimes we would drive around the ranch in his
Navigator and talk and sometimes we would sit in the video library and talk and sometimes we
would sit in his office and talk. And sometimes I would be saying, you know, "I really got to go
home to my family" and, "no, no, Saunders, just stay a little while."
Q. He would want you to stay?
A. Yeah.
Q. Would you stay when he asked you to?

A. For a little while. I am not one to say.

Q. Did he talk to you about his family?
A little.
Q. Growing up. What did he tell you about growing up?
A. He said it he said he had a very difficult childhood.
Q. How so?
A. Because he was never allowed to be a child. And he said sometimes, though, he recalled
running around hotels with Donnie Osmond and that kind of thing.
Q. When he was younger?
A. When he was younger.

Q. Like a child?
A. Yes.
Q. Did he talk to you about performing ever?
A. No, I don't think so.
Q. Did he talk to you about his father and how his father treated him?
A. No.
Q. Did he ask you questions about your family?
A. Yes.

Q. Did he ever meet your family?

A. Yes.
Q. Who did he meet?
A. My children and my wife.
Q. And when did he meet them?
A. When he well, when he came to our house and when we went to his house.
Q. So he came to your house?
A. Yes.
Q. Was that the house that you live in now?

A. No.
Q. A different house?
A. Yes.
Q. What town was that house in?
A. Solvang.
Q. When did he come to your house in Solvang?
A. He just showed up.
Q. How did he get there?

A. He had a driver.
Q. Did you meet the driver?
A. No, the driver stayed in the car.
Q. Just dropped him off?
A. No, stayed there and waited.
Q. And he rang the doorbell?
A. Yeah, we didn't have a doorbell. He knocked on the door.
Q. And you didn't know he was coming over?

A. No.
Q. Were you surprised when he got there?
A. Yes, yes.
Q. So what did you do when he showed up at your house in Solvang?
A. "Hi, nice to see you," you know, invited him in. And we sat and talked and his kids had gone
to play with my kids.
Q. His kids were with him?
A. Yes, at one time he was there and it was during the day. So the kids wanted to go outside in
the sandbox.
Q. During that general time range you gave that you would treat Michael Jackson on and off for
medical treatments, is that is the time frame the same or different as when you would see
him socially?

A. Same. That same time period, yes, all of that happened all at the same time, in that same
time period.
Q. What about privacy of his medical care, were there was there anything, you know, that
Michael Jackson did to protect his medical privacy?
A. I don't I don't know of anything that he did to protect his medical privacy.
Q. And in your experience, treating Michael Jackson, what medications was he on?
A. Well, the only two that I knew of were Demerol and morphine. And I think I had given him
some oral pain medications like I don't know which, like Vicodin or something of that
of that type. So pain medication.
Q. And during the time that you knew Michael Jackson, did you ever try and decrease any of
the medications that he was on?
A. Yes.

Q. Which ones?
A. Well, Demerol.
Q. And why was that?
A. Because he wanted to get off of it.
Q. And do you know of any steps that were taken to get Michael Jackson off Demerol?
A. Yes.
Q. What did he do?
A. Well, he asked to use buprenorphine instead.
Q. And in addition to the buprenorphine, do you know of any other steps or what else he did?

A. No, I don't.
Q. Did you ever get any presents or gifts from Michael Jackson?
A. Yes.
Q. What did he give you?
A. He sent a box to my house for Christmas.
Q. And what was in the box?
A. I don't recall. I think my children got -- because he had all the children's names. It was like
listed on there. A PS2, but whatever else was in there, I don't know.
Q. The Play station video game?

A. Yes.
Q. So that the presents were for your family?
A. Yes.
Q. Was anything given to you by Michael Jackson?
A. He left a popcorn popper.
Q. Like a movie --
A. Yeah, like no, well, like the one at carnivals, you know, on a stand.
Q. Still have it?

A. No, I sold it at a garage sale. I actually found it later. We were trick or treating in our
neighborhood and I go, "Hey, where did you get that?" And, "Oh, we bought it across." "That
was mine. Michael Jackson gave it to me." "Really?"
Q. Going back to the Demerol, do you know if he was ever successful at getting off the
Demerol?
A. No.
Q. You don't know?
A. I don't know. Like I said, I would see him and then I would not hear from him for weeks or
months or whatever when he was I don't know -- out doing his thing wherever he was.
Q. Did you ever go with him on the road outside of California?
A. Never.
Q. Did he ever tell you about when he about his travels around the world?

A. Yeah, we talked some about that but more from early days, not recent stuff
Q. When?
A. Except for one thing.
Q. What was that?
A. His Las Vegas trips. One time he was telling me about going to Las Vegas, how much he
enjoyed Las Vegas.
Q. So just for a social trip?
A. Yeah.
Q. What kind of things did he tell you he liked buying?

A. He would go in the store and say I want that and that, antique. He was really into antiques.
Q. Do you have any idea how much money he spent on antiques?
A. No clue.
Q. He never told you ea did he ever tell you about a specific purchase?
A. No.
Q. Any favorite antique he had?
A. He said he knew them all. He knew which ones were his.
Q. Were there antiques around his house in Neverland?

A. Yes
Q. How many, ballpark, would you say?
A. The house was full.
Q. And this was a large house, right?
A. It was a large house. It was full.
Q. Full of antiques?
A. No, it was full of just everything and antiques.
Q. Including antiques?

A. Yes.
Q. What about in terms of compensation for your services, were you compensated when you
provided treatment to Michael Jackson?
A. Yes.
Q. How did that arrangement work?
A. I never asked for compensation and he would always pay in cash because he had no credit
and no checks and no bank accounts.
Q. How do you know that?
A. Because he told me.
Q. I said we will send a bill and he said you can't because I don't have any checks or credit
cards or anything.

A. When you received the cash payment from Michael Jackson for your medical treatment
A. Yeah.
Q. when did that happen? Did it happen at the time of treatment?
A. Yes.
Q. And who would pay you?
A. He did.
Q. Can you please mark in as Exhibit 8.
Q. Exhibit 8 is a document production from the Santa Ynez Valley Cottage Hospital. It's Bates
numbered SYVCHOOOIEG through 000365 and there are also 14 pages without Bates numbers
on the top of Exhibit 6 beginning with -- 07 TO 119207

MR. HUNT: Exhibit 8. Thank you.

Q. The date of this document is February 24, 2001. It says "Date Seen," correct?
A. I see that.
Q. Was this generally within the time that you were seeing and treating Michael Jackson?
A. Yes.
Q. And have you had a chance to review the "History of Present Illness"?
A. Yes.
Q. Reading and referring to that section, does that refresh your memory about any medical
treatment that you gave to Michael Jackson?

A. No.
Q. Is this description consistent with the incident we spoke about earlier today when Michael
Jackson fell down the stairs at his home?
A. Im not sure that he fell down the stairs but the incident we discussed earlier, this would be
consistent with that.
Q. With that incident?
A. Yes.
Q. When you say you are not sure that he fell down the stairs, what do you mean?
A. I don't recall exactly what happened. I am trying to recall the specific incidents and how it
happened. And that was my best recollection of them.
Q. The time so your best recollection of an incident when Michael Jackson injured his foot.

A. Yes.
Q. Do you know why you would be listed as Michael Jackson's personal physician on this
medical record?
A. I can think of one of two possibilities.
Q. Okay.
A. One is because I brought him to the emergency department and I had been called to treat him
for that specific incident, or number two, if he identified to the emergency physician that I was
treating him for this before he came in.
Q. Can you turn to the next page with the Bates number 362, please.
A. Yes.

Q. And can you review the section entitled "Emergency Department Course," and let me know
when you are finished.
A. Okay.
Q. Are you finished reading?
A. I am finished.
Q. Did you read the section on the page Bates number 362 that says, "Given his inability to take
oral pain medications without extreme nausea, we have worked out with Dr. Saunders to
dispense Demerol and Phenergan IM with some needles and syringes. I have specifically stated
that a medical care professional either a physician or nurse, must
administer this medication should he need it. He is well aware of this, and in fact, Dr. Saunders
has agreed to go by the home to administer the medication if needed."
Q. Did I read that correctly?
A. Yes.

Q. Having reviewed what is written on the page numbered 362 and thinking back to 2001, do
you have any recollection of what this document is referring to?
A. No.
Q. It did not help refresh your recollection?
A. No.
Q. Did you read the section on page 362 that says, "We have dispensed the Demerol and
Phenergan IM with needles and syringes. He is well aware that a physician or nurse must
administer this and he will be calling Dr. Saunders tonight if he needs help with the
administration of this medicine." Did you read that section?
A. Yes.
Q. Do you recall having a conversation with Dr. Weinstein consistent with what is written on
this page?
A. NO.

Q. The last line the last section says, "Disposition: Discharged to home. Follow up with
Dr. Saunders sometime in the next week." Do you know why the disposition indicates that
Michael Jackson should follow up with you sometime in the next week?
A. Why. So your question is why did she say that?
Q. If you know.
A. well, I mean it's obvious. An emergency department physician is not a primary care
physician. They take care of the immediate problem. They say diagnosis, fracture; treatment,
splint, pain medication, go to your doctor for continuing
care or follow-up.
Q. After.
A. After. You don't go back to the ER over and over again for continuing care for casting, for
whatever else needs to be done to take care of that. They take care of the initial problem and then
they say they have to arrange for follow-up. So she has arranged for followup for him to
see me.

Q. Do you have any reason to believe that these medical records as you read them here are not
an accurate description of what happened on the date indicated on the document?
A. No.
Q. Lets go to page 350. We're going to go backwards because that's the order that these were
produced to us in. Are you on page 350?
A. Yes.
Q. Is the date scene, 02/25/2001, on this document?
A. Date seen, yes.
Q. And it this date within the range you identified as having seen and treated Michael Jackson
on and off for medical conditions?
A. Yes.

Q. Could you, please, read the "History of Present Illness" on this form.
(Reading) :
"History of Present Illness. This is a 30somethingeyearold gentleman who has been seen
here twice before, actually, earlier this evening although it is now the next day, but he has been
seen twice. He has an avulsion of the proximal navicular of the foot and has required copious
amounts of pain medication who returns again in severe pain, no further trauma, no paresthesias
and states that the Demerol which we gave on his last visit has worn off and he feels the pain
escalating. The remainder of the review of systems is negative."
Q. Thank you. I believe and correct me if I am wrong that your testimony a few
minutes ago is that it was unusual for someone to return to the emergency room multiple times.
Do you recall saying something to that effect?
A. Yes.
Q. Could you explain what you meant by that.
A. Okay. What we were talking about before is different than that. What we were talking about
was followup.
Q. Okay.

A. And if somebody has a worsening of their condition, then they generally would have to go
back to the emergency department. If someone feels they're worse in any way, then they would
go back. If somebody is improving like they should, if an avulsion fracture is splinted, then you
expect that the pain is going to diminish because they're not going to be walking on it or stepping
on it. So it's immobilized. So they're not going to be moving on it and causing pain. So the
expectation is that it's going to get better somehow. And when it's not, then it's appropriate to go
back and say this is not getting better, this is getting worse ~~
Q. And in that case --
A. and reevaluate.
Q. Some more treatment might be needed?
A. Yes.
Q. Have you heard of Michael Jackson requiring copious amounts of pain medication before?
A. I have never heard that word used, that term used for that in his case, no.

Q. Have you heard similar description of --

A. Heard, I dont understand what you mean by "heard." Have I thought about it, have I heard
it, has someone else told me that. I don't recall anything like that.
Q. Do you recall talking to Dr. Weinstein about this incident?
A. No.
Q. Do you see on page 350 that next to the line "Private Physician," it says, "Currently Dr. Scott
Saunders"?
A. Yes.
Q. Do you know why this form says that says that?

A. When someone is in the emergency department, they need to know where the followup is
going to be, who is going to take care of this person when they leave the hospital.
Q. And why would your name be listed?
A. One of two possibilities, either because I brought him there or because the patient said that's
my doctor.

Q. Did you ever determine an underlying cause for Michael Jackson's addiction to pain killers?
A. No.
Q. Did Michael Jackson ever tell you if there was an underlying cause?
A. No, not that I recall.
Q. On page 330 its a good place holder. Can you read "History of Present Illness."

A. (Reading):
"History of Present Illness. The patient is here because he had a fractured cuboid on his right
foot. He has been seen multiple times for pain medication injections. He receives Demerol 200
milligrams and 50 milligrams of Vistaril each time. Today, he was casted by Dr. Scott Saunders
and is feeling somewhat better but is having some pain in his foot. At this point, it feels better in
the cast."
Q. Thank you. And this is dated O2/26/2001, correct?
A. Correct.
Q. Do you have any reason to doubt that this is an accurate statement of the medical treatment
that Michael Jackson received on that date?
A. No.
Q. Can you turn to page 291, please. Are you on -
A. Yes.

Q. Are you on that page?

A. Yes.
Q. And the date seen on this page is 12/14/2001, correct?
A. Yes.
Q. And the patient's name is listed as Jackson, Michael?
A. Yes.
Q. Can you, please, read "History or the Present Illness."
A. (Reading) :
History of the Present Illness. The patient is a 41~yearold black male who was brought in by
Dr. Saunders from the patient's home. Prior to his arrival, Dr. Saunders had called me saying that
the patient had an injection of Demerol 200 milligrams and Phenergan 50 milligrams, which he
has had on a number of occasions in the past and did well."

Q. And if you could skip to the last paragraph.

A. (Reading):
"Dr. Saunders had told me upon arrival to the emergency room that he obtained further
information that the patient had another pain injection at sometime prior to Dr. Saunders arrival
that Dr. Saunders was not aware of. The patient only told him this after his reaction had
occurred."
Q. That's fine. Thanks. Do you have any reason to doubt the accuracy of the statements
contained on this medical record?
A. No.
Q. Reviewing this medical record, does that refresh your recollection of any events on the date
of December 14, 2001, that you interacted with Michael Jackson?
A. Specifically, no.
Q. What about generally?

A. The general idea of the large amounts of Demerol being given, yeah, I do recall that.
Q. Do you recall with a particular physician or just you generally recall it?
A. Just generally expressing the same sort of concern that the emergency department physicians
were expressing.
Q. Do you know if Michael Jackson was ever able to stop taking large amounts of Demerol?
A. Im sorry. What is the question? You want me to tell you ii he ever stops taking it?
Q. Do you know?
A. You mean he got lower doses or didn't take any at all? l don't know. Demerol lasts what? Has
a fourhour half life and then, you know, he stopped, yeah. After that one, he stopped. And then
eight
hours later, he got another one. I don't know where to go with stopped.

Q. Until the last time you saw Michael Jackson in 2003.

A. Yeah.
Q. To the best of your knowledge, did he continue to receive Demerol on a regular basis?
A. I don't know.
Q. Does this record, 291, refresh your recollection about Michael Jackson getting another pain
injection somewhere prior to your arrival that you were not aware of?
A. Yes and no.
Q. Okay.
A. Yes, what the record says I believe what the record says, but as to the specific instance,
I don't recall.

Q. Do you have any idea who the other doctor might have been?
A. No, I don't.
Q. Does it bother you that Michael Jackson got or may have got a shot of Demerol by another
physician without telling you?
A. Does it bother me now or did it bother me then?
Q. At the time.
A. Generally, yes, that's a bothersome thing.
Q. Why?
A. Because the potential reaction or the potential problems associated with Demerol are dose
dependent. So as you increase the dose, the potential for doing harm is increased. So if I am
going out to give him a Demerol injection because of his broken foot, and meanwhile, some

other doctor's going out there and giving him Demerol injections and it's too much too close
together, he could have a bad reaction.
Q. If you can just turn to the next page. It's 292. You are on 291, right?
Q. The very bottom well, let's start at the top of page. It says Jackson, Michael, correct?
A. Yes.
Q. And then at the above that it actually says Saunders, Phil M. Do you see that the very top of
this page 292?
A. Yes.
Q. And could you read the next sentence on that same allergy section?
A. (Reading):
"He has a MedAlert bracelet saying he is allergic to Demerol."

Q. Do you know what a MedAlert bracelet is?

A. Yes.
Q. What is it?
A. It's a bracelet, a plaque, that is specifically for emergency personnel. If someone is
unconscious, then the emergency personnel can come and look at his bracelet and find out what
medications he is allergic to.
Q. Who typically has a Med Alert bracelet? Is there a particular patient population?
A. People who have epilepsy, for example, or other other people who don't who
might be unconscious when a person comes. So epilepsy or people that have severe allergies, like
to bee stings or something like that. Someone who might be found unconscious will wear a
bracelet.
Q. Outside of people who might be found unconscious, is it common for someone to have a
MedAlert bracelet or is that the most common situation?

A. Some people have them because they want them, but I imagine there would be a reason you
would get one. And the reason would be there is something that you are likely some reason
you are likely to be found unconscious and not be able to tell the emergency personnel what you
are allergic to.
Q. And can a high dosage of Demerol cause unconsciousness?
A. Yes.
Q. Can you continue on on page 292. The third sentence continues onto the next page to 293.
A. (Reading):
"When questioned, he says he has had Demerol many times in the past. Indeed, I administered
Demerol to him at one time. He tells me this because he does not to be given too much
Demerol.' He has no specific reaction to Demerol, itself. He tells me has also tolerated Phenergan
on numerous occasions in the past without difficulty."
Q. Thank you. Do you have any reason to doubt the accuracy of this medical record?
A. No.

Ms. Cahan: that concludes the video of Dr. David Saunders. And for the record, the
exhibit that was referenced throughout the deposition as exhibit 8 is trial exhibit 2121.
Mr. Boyle: and for the record, your honor, we object to any medical records that weren't
actually Dr. Saunders' records.
The court: okay. Well, we can take that objection up later. But thank you for the
identification.
Ms. Cahan: thank you, your honor.
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