JACKSON V AEG LIVE August 9th, 2013

Kathy Jorrie (Outside counsel AEG Live)

(the following proceedings were heard in open court, outside the presence of the jury:)
Judge. Good morning.
Mr. Putnam. Marvin Putnam on behalf of the defendants. Your honor, the -- I just wanted you to note that
we filed this morning some papers for non-suit in light of their having concluded yesterday finally. I wanted
you to have those papers. We've done it both individually for Randy Phillips and for Paul Gongaware on the
basis of there's no evidence that they hired anyone, that they're the employer, and then as well on the other
grounds that we put forward for all the defendants. We put the papers in and provided them.
Ms. Bina. One more brief thing, your honor. And I don't want to belabor everything that we went through the
other day, but plaintiffs' counsel originally said they weren't trying to allege Ms. Jorrie did anything negligently,
you know, her knowledge was relevant to anything. They then cross-examined her asking repeatedly, asking,
"why didn't you do a bigger search? Why didn't you check his judgments?" that kind of thing. The witness
came to me afterwards and said that she really believes the fact that Dr. Murray had told her Michael Jackson
was in good health and those representations he made repeatedly affected her decisions in that regard. So I
think that the door has been opened, and I would ask that your honor reconsider the M.I.L.Issue. I just wanted
to raise it briefly. If your honor is not inclined to reconsider that, that's fine, but I do think they've put it at
issue by asking why she didn't do further searches.
Judge. Why she didn't --
Ms. Bina. Why she didn't check his finances, why -- why she was satisfied, essentially, your honor, after ten
minutes of Googling, as they put it, as opposed to doing more in-depth searches.

Mr. Panish. I didn't say that.

Mr. Bloss. William Bloss for the plaintiff, your honor. The questions, I think, were very narrow. We didn't,
"ask why didn't you do more?" that was never a topic at all. We asked, "what did you do?" and left it at that.
We didn't ask her for her reason otherwise.
Ms. Bina. They then asked, "you could have done this, too, and you could have done this, too, and you could
have done this, too," implying, your honor, that she should have done more and did not. She should be allowed
to explain her reasoning and why she did what she did and didn't do what she didn't do.
Mr. Panish. Your honor, I was very specific in my questions. They -- they brought up all this, hearsay
statements to Mr. Phillips. All I asked was what she did. I didn't get into -- now they want to make her an
expert, you know, and give an inch, take a mile, that's what they try to do. I was very specific in every question,
and when they objected that it might call for interpretation of an expert, I withdrew the question. I was very
careful in all of my questioning to do that. I didn't get into that. Now they want to get --
Mr. Bloss. If the court please, it may also open the door to communications that she may or may not have had
regarding information that Mr. Jackson was, in fact, not doing well. I think this conversation was the 19th, if I
recall. That's, of course, the day that he was sent home from practice. So does she have contrary information
from Mr. Phillips? "Did Mr. Phillips tell you that Michael was, in fact, sent home from practice, that he missed
practices earlier that week?" it does get into a fairly broad area, your honor.
Ms. Bina. To be clear, your honor, I'm only asking for her to explain the reasons why she didn't conduct
broader searches on the 18th. I think that's pretty narrow, and I do think it's relevant and been opened, but I
leave it to your honor's consideration.
Mr. Putnam. Your honor, every time that we've been down this road so far what has occurred is prior to our
witness going, something has been put before the court, a motion saying you can't go into a given arena, stop
that, don't do that, and we've been forbidden from doing that. And then each time on cross, they then open it up.
We then say, "Well, we have to be allowed to go down there" like, "Oh, no, no, no. We were very narrow in
our scope." We're going to be equally narrow in going to the door that they have now opened, your honor. They
specifically asked her, "Why didn't you do the following, this, that?" She had a reason from conversations she
was actually having with Dr. Conrad Murray, and, obviously, that's not being offered for the truth, it's being
offered for the fact that she was told this by his doctor repeatedly -- and I think she has made very clear that was
the basis for what she did and didn't do.
Mr. Panish. Your honor, they say every time. I mean, that's not true, number 1. Number 2, I was specific on
my questions, I didn't violate any restrictions that you made. Now, after they interrupted her, took her back,
prepped her up, now they want to get into this area, this expert area, after they've programmed her for what her
answer is.
Ms. Bina. To be clear, your honor, I'm not asking for any expert testimony, I'm only asking that she be able to
repeat a conversation she had with Dr. Murray on the 18th.
Mr. Panish. I was trying to talk.
Judge. What is the connection between the statement and what she did as a result?
Ms. Bina. What the witness will testify, your honor, is that she felt comfortable doing this sort of limited
search just to check that he was basically who he said he was because of his assurances that he had a long-term
relationship with Michael Jackson and had treated him for three years, he seemed, you know, to have a very

warm personal relationship, and he told her about that. And that was part of -- part of her thinking and
reasoning and part of why she conducted the search that she did, specifically that he had said, "I treated him for
three years," that kind of thing.
Judge. So she was satisfied that he was competent because --
Ms. Bina. Less a matter of competence, per se, your honor, but it's the reason she didn't feel the need to
conduct some kind of exhaustive examination. She talked to him, he had a long-term client relationship with
Mr. Jackson, she understood that Mr. Jackson had requested this agreement, and then she just did some very
brief sort of spot diligence to make sure he is who he says he is, he's got a license, no history of discipline. And
that was enough for her because of this historic relationship with Mr. Jackson that she was aware of now in two
ways.
Mr. Panish. We argued this all the other day. You made your ruling. Every time I'm trying to argue, they
like won't let me talk. Just like yesterday, I couldn't even get the objections out when they were arguing before
I could even do it. This -- this witness -- what they're trying to do now is open her up as the expert, repute that
to AEG they're trying to use this to explain Randy Phillips' e-mail.
Judge. Well, there's no communications between Jorrie and Randy Phillips on that, is there?
Mr. Panish. Yes, there is. That's what they're going to try to say, that she told Randy Phillips this, therefore,
to explain his e-mail where he says "we check everyone out," which he's already admitted is false, and they're
trying to backdoor hearsay and the expert why-she-didn't-do-this testimony. We argued this all the other day,
they tried the same thing, Ms. Bina just keeps coming back and rearguing everything.
Mr. Bloss. I think the timeline, your honor -- to put the timeline in perspective, I think the claim is that Ms.
Jorrie spoke to Murray. Ms. Jorrie then -- about where he had been admitted to practice. Ms. Jorrie then
Googled Murray and did the license check, that Murray in that prior conversation said, "I'm very successful"
and made whatever representations he made about the money, and then after that is when Jorrie --
Judge. -- had an offhanded conversation with Phillips?
Mr. Bloss. -- Phillips, talking about another --
Judge. -- talking about another case and happened to mention --
Mr. Bloss. Exactly. So now we get into did Ms. Jorrie tell Mr. Phillips that Murray said Jackson was in great
health when, in fact, Phillips knew that he was not in great health because he'd been getting reports, he had done
the, quote, intervention meeting on the 16th.
Ms. Bina. To be clear, your honor, I don't actually believe this is part of what she communicated to Mr.
Phillips.
Judge. You should know that. Have you spoken to him? Not him, her.
Ms. Bina. Her testimony, your honor -- everything she told Mr. Phillips is what she told the jury the other
day, to my knowledge. I don't think there is anything further. That's by far my understanding, that's what the
witness has told me. I don't think that's going to be opened up or brought up in any way, shape or form. I'm
literally wanting her to give and provide an explanation for her actions on June 18 because plaintiffs have put
that into issue by saying, "well, you could have done this other search and that other search," implying that she
did an inadequate search. She should be allowed to explain why she conducted the search that she did, and part
of that includes what Dr. Murray told her on the 18th.

Mr. Panish. They're the ones that brought the search up in direct. So what they've done is they've asked that,
now if I ask a single question, then they -- now -- it's all opened up. All I said is, "you did this, this and this, it
took this long." they injected it in, I objected, you allowed it. They're trying to use it to explain --
Judge. You objected to what?
Mr. Panish. To all these -- what she said she told Phillips what she did. It was totally -- it was -- I was saying
it's expert testimony, no foundation, it's hearsay if she went on Google --
Judge. Wait a minute. I thought they objected saying it was attorney/client.
Mr. Panish. No, no. Initially. Then they said --
Mr. Bloss. No.
Mr. Panish. Well, I said if they're going to bring it up, then I should be able to get on this, and they go, "oh,
no. It's just an offhanded comment, it really wasn't attorney/client, they weren't talking about a matter, they
finished a call and then she just offhandedly said by the way," blah, blah, blah, blah, blah, and it really wasn't
about that subject matter, therefore, it's not attorney/client, therefore, I can't get into the other parts of the
conversation. So then they brought it up, we objected not only on attorney/client opening up, hearsay, expert
testimony, no foundation, that was allowed, to say what she did. Now -- and then I said, "did you do this, this
and this?" fine. Now they want to go back and get all the reasons that she did this conduct, this -- these acts that
-- and stop me from getting into the attorney/client, and stop -- and get her to say that she's an expert and that's
what was reasonable in her mind and all that.
Ms. Bina. Your honor, I think Mr. Panish is expanding what's actually going on here. Your honor found that
there was a limited waiver as to the conversation with Mr. Phillips because it was conveyed to Mr. Ortega the
next day. Plaintiffs were allowed to cross-examine fully on that subject, and did so. They also, though,
however, your honor, had represented that they were not going to allege or argue that Ms. Jorrie had been
negligent in any way in her own conduct. They then cross-examined suggesting that she was, "why didn't you
do further searches?" all I wanted her to do, your honor, was be able to fully describe her call on the 18th and
how it affected her reasoning. I'm not asking that she talk about the 23rd and the repeated assurances Dr.
Murray made there, just opening this one limited subject.
Judge. And there's not going to be any testimony that she told Randy Phillips that Michael Jackson --
Mr. Bloss. If that happens, your honor, I think we're entitled to get that and whether she had any information.
Judge. So you're going to ask?
Mr. Panish. If she brings it up.
Judge. You can do that if you want, but you may not like the answer.
Mr. Bloss. We finished our cross.
Mr. Panish. We haven't got any of that information. We were blocked at the deposition in many of these
areas. Now, at the trial, they're trying to bring it up and we don't know -- we didn't have a fair opportunity --
Ms. Bina. Your honor, at the deposition, they never asked about this, despite Mr. Phillips having disclosed it
at his deposition a couple of days before.

Judge. I'm asking what is the state of the facts.

Ms. Bina. I believe that -- and I will confirm this before I put her on the stand -- that she told -- everything
she told Mr. Phillips already has been testified to and there will not be anything additional, that that is the limit
of what she told Mr. Phillips, which was, "hey, I spoke to Dr. Murray. He's successful, got these practices, he's
licensed in four states," and she thinks but isn't positive that she told him about the $1 million a month. That's
the entirety of her conversation with Randy Phillips on the subject. I will confirm that before putting her back
on the stand, but I don't believe this is going to lead to any additional --
Mr. Panish. At page 13901, Ms. Bina asked these questions, what she did, did she do anything else about Dr.
Murray, and she answered. That's page 13091 of the transcript. That's Ms. Bina questioning. Then I asked --
and I have to get the exact page.
Judge. Is that at trial, or --
Mr. Panish. The trial. Trial. They brought it up. And I just asked what she did. Now that doesn't open up
for them to get into the reasoning process of what she did and why she did it because now they're going to
argue, "see? It was adequate. She didn't do it for this reason, this reason." we don't even know what she's going
to say, but I assume they've prepped her when they met with her to say, "oh, I didn't do it because this --"
Judge. I'm overruling your objection. I'm going to allow them to inquire. But you need to go back and talk to
her, come back with a firm answer as to the answer to my question.
Mr. Bloss. If I could just clarify, are we then allowed to say that Mr. Phillips -- ask if Mr. Phillips gave her
any information to the contrary or if she conveyed that to Mr. Phillips after the conversation with Dr. Murray?
Ms. Bina. I think the conversation with Mr. Phillips on June 18th is already opened up, your honor found it
waived, so I don't object to him asking, assuming that happened on the 18th. If he's asking about some other
conversation, those would still be privileged.
Mr. Panish. No, they wouldn't. They've opened it up now. If they're going to have her say reasons and
Phillips told her other things that she didn't do further, that's opened it up. If they want to get into it, I shouldn't
be restricted again on this attorney/client privilege. We're objecting to this on numerous grounds, as we've
stated, and if she's going to get into it, why can't I ask, "did you talk to Phillips later and find this out? Why
didn't you go back and look then? Did he tell you this? Why didn't you do that?" I should be allowed to do
that.
Mr. Bloss. I think it's fair, your honor, if she's relying on this conversation from Murray for her not doing
anything else, for us to be able to ask whether she had any information to the contrary from Mr. Phillips, Mr.
Gongaware, or anything else.
Mr. Panish. Exactly.
Judge. Okay. I think that's fair.
Mr. Panish. And then I can talk about whether she communicated in writing with him, did she report back, all
that's opened now.
Judge. That's fair.

Ms. Bina. Again, your honor, I'm a little concerned when Mr. Panish says, I can talk about whether she
communicated in writing, did she report back, all that's opened now."
Mr. Panish. With this issue.
Ms. Bina. My understanding of what's opened is whether she ever heard from Mr. Phillips or -- Mr. Phillips
or, I guess, Mr. Gongaware, although I'm not sure how Mr. Gongaware came into it, that he was not in good
health.
Mr. Bloss. Anyone, because if she had contrary information from any source --
Judge. She should have done further research.
Mr. Panish. Right. What did they tell her, and did they write to her to discuss this. All that's opened.
Ms. Bina. If that's the case, your honor, I think the June 23rd statements by Dr. Murray would also come in.
Judge. What's the June 23rd statement? Was that the police statement?
Ms. Bina. No. His statements to Ms. Jorrie when he repeatedly affirmed to her again that Michael Jackson
was in good health in connection with the insurance stuff, and he'd only had his file for three years and it would
be very tiny.
Mr. Panish. See, now, an inch, mile. This is what we argued. Now she's trying to get a little bit, open, open,
and that's what's going to happen. That's why none of this should be gotten into. What she did -- it's not really
relevant what she -- they brought up what she did. We said, "is this what you did?" yeah. Okay. Now they
want to get in why, then Murray --
Judge. Well, the question isn't, "is this what you did?" it's, "you didn't do this, did you? Why didn't you do
this?" that was the question.
Mr. Panish. I did not ask that question.
Judge. If she has an explanation, she should be allowed to explain, on the other hand, if she came into
additional information, they should explore why she didn't act on additional information. It is opening up, but
that means it's opened up completely.
Mr. Boyle. We never asked why didn't she do more. We said, "could you have done this?" yes. But that's not
why, or the reasons --
Judge. Well, that's the implication.
Ms. Bina. It's the implication, your honor.
Judge. All right. Go out and ask her --
Ms. Bina. I will go. Your honor, the witness is in the ladies' room. When she comes back, I'll talk to her.
Mr. Panish. And the bills for the searches, those would be discoverable, right? The bills of the internet
searches? Because they weren't giving me that.
Judge. I don't know. Didn't she say she didn't have any?

Mr. Putnam. She said she didn't bill for that.

Mr. Panish. She says she doesn't remember. Are we going to go back and look for those days' bills?
Mr. Putnam. What's the relevance of that, your honor?
Mr. Panish. Whether she did it truthfully or not. Goes to impeach her. They've raised it up, they should
bring it to the court --
Mr. Putnam. Your honor --
Mr. Panish. Excuse --
Judge. Mr. Panish.
Mr. Panish. Your honor, it's been -- yesterday, all day, when I was trying to question, not only when I
couldn't get an objection out, they would just start arguing. Okay? I'm sorry, but it's very frustrating, and
they're doing it to interrupt me constantly at this time, and --
Judge. You were talking about billing records.
Mr. Panish. Yeah. So if she didn't do it, the billing records go to her credibility.
Judge. Well, ask her about it. Ask her if she has them, and we'll see.
Mr. Boyle. She produced one billing record from the day after the alleged research.
Mr. Panish. In a minute. In 30 seconds, she had it.
Judge. I think that was a bill on a conversation.
Mr. Putnam. That was a different bill which she showed.
Mr. Panish. But she didn't bill for that.
Mr. Boyle. Right.
Ms. Bina. Your honor, I've confirmed that the entirety of her conversation with Mr. Phillips has been testified
to, so --
Judge. Okay. Have her come in.
(the following proceedings were held in open court, in the presence of the jurors:)
Judge. Good morning, Ms. Jorrie. I believe we're still on direct. Is that right?

Mr. Panish. Redirect.

Judge. We're almost done, then.
Ms. Bina. Yes, your honor.
Judge. You may begin.
Continued redirect examination by Ms. Bina of Ms. Jorrie
Q. Good morning, Ms. Jorrie.
A. Good morning.
Q. I understand that you are not available to testify for most of this afternoon, is that right?
A. Yes.
Q. And is that because you have a family vacation with your grandchildren?
A. Yes.
Q. I do not want to keep you from that, so I'm going to go as quickly as possible as I can this morning.
A. Thank you.
Q. And I want to start -- we had just left off with a Dr. Tohme document, but I'm actually going to turn back
briefly to a provision of the tour agreement between AEG Live and Michael Jackson. Pam, can we please see
exhibit 67, pages 9 and 10. And I want to ask you, Ms. Jorrie, about paragraph 13. Do you still have that
document with you?
A. Yes, I do.
Q. Ms. Jorrie, I'd like to highlight a line in the middle of this section that begins with "Artisco hereby
represents and warrants." Pam, can you highlight that? Ms. Jorrie, could you read this line for me?
A. Yes. "Artisco hereby represents and warrants that artist does not possess any known health conditions,
injuries or ailments that would reasonably be to interfere with artist's first-class performance at each of the
shows during the term."
Q. And, again, "Artisco" is the Michael Jackson company?
A. Yes.
Q. And "Artisco" is -- and "Artist" is Michael Jackson?
A. Yes.

Q. Pam, could you turn to the signature page of this document, which -- it's in the middle. That one. And,
Ms. Jorrie, who signed this agreement attesting to that on behalf of Artisco?
A. Michael Jackson.
Q. And did Michael Jackson also sign this agreement himself?
A. Yes.
Q. So Michael Jackson represented and warranted that he did not possess any known health conditions or
ailments that would interfere with his performance?
A. Yes.
Q. Ms. Jorrie, did you ever have any information contrary to that representation and warranty made by Mr.
Jackson before his death?
Mr. Panish. It's hearsay, no foundation, attorney/client. Now it's getting --
Judge. Overruled.
A. I never had any information that suggested that Michael Jackson was not in good health.
Ms. Bina. And at any point prior to Mr. Jackson's death, were you aware of any information suggesting he
had any drug problems?
A. None whatsoever.
Q. What about insomnia or sleeping troubles?
A. I was not aware of any such troubles.
Q. Now, you talked about your tendency to Google people.
A. Yes.
Q. In connection with your work in this matter, did you ever Google Mr. Jackson?
A. Several times, of course.
Q. And in those Googling, did you ever see anything about drugs or sleep problems?
Mr. Panish. Calls for hearsay, no foundation.
Judge. Sustained.
Ms. Bina. Again, your honor, it's not offered for the truth of the matter asserted.
Judge. It is. Sustained.
Mr. Panish. It absolutely is.

Ms. Bina. Now, you were asked -- I'll move on to another --

Mr. Panish. It's also beyond the scope, all this.
Judge. Overruled on that.
Ms. Bina. So, Ms. Jorrie, in signing this agreement, Mr. Jackson made that representation and warranty that
we just saw?
Mr. Panish. It's asked and answered twice.
Judge. Repeat your question.
Ms. Bina. I was just trying to move on to another topic. I said, "in signing this, Mr. Jackson made that
representation and warranty that we just discussed?"
Mr. Panish. Same objections.
Judge. Overruled.
A. Yes.
Ms. Bina. Okay. Let's move on -- I'm trying to hit these quickly -- to go back to that document we were
looking at just before we finished up on Wednesday, and that's exhibit 372, dash, 1. Let me know if you have
that in front of you or if you need -- here you are, counsel.
A. I have it.
Ms. Bina. Your honor, do you have a copy still?
Judge. It's somewhere.
Ms. Bina. If you want one, I can bring it up.
Judge. What is it?
Ms. Bina. 372, dash, 1. It's up on the screen.
Judge. That's fine. You don't have to give me a copy. I'll look at the screen.
Ms. Bina. All right.
Q. Now, Mr. Panish asked you a lot of questions about this document which I believe you referred to as a
Tohme consent form, is that right?
A. I -- I have referred to it as that in the past. I don't think I referred to it as that here, but yes.
Q. Right. The document itself doesn't say the word "Consent Form"?
A. Correct.

Q. But you've called it that?

A. I have.
Q. And, Pam, if you could scroll down so we can see all the paragraphs. So I want to bring your attention to
paragraph 3. What does this line say?
A. Paragraph 3, "authority to sign. The undersigned, Dr. Tohme Tohme, represents and warrants that he is an
officer of Artisco and has full authority to act on behalf of Artisco and to sign this document."
Q. And if we look a little bit further down, did Dr. Tohme sign this document?
A. He did.
Q. And at the time Dr. Tohme signed this form, did you believe that he was an officer of the Michael Jackson
company?
A. I did.
Q. And as we sit here today, do you have any reason to believe that he wasn't an officer of the Michael
Jackson company at the time he signed the form?
A. I did not -- I do not. I have no reason to believe he wasn't an officer.
Q. Did Mr. Panish show you any documents showing that he wasn't an officer at that time?
A. Never.
Q. Now I'd like to turn back briefly to exhibit 58, dash, 1, which I believe Mr. Panish asked about on
Wednesday. Do you still have this one, Ms. Jorrie? I'll bring another copy for the court.
A. I'm not sure.
Ms. Bina. Getting my exercise this morning.
Judge. Thank you.
Ms. Bina. Ms. Jorrie, do you recall Mr. Panish asking you questions about this document?
A. I do.
Q. What is this document?
A. Give me one moment to read it.
Q. Uh-huh. Yes. Of course. Take your time.
A. Yes. This is an e-mail -- the top e-mail is an e-mail from Dennis hawk to me, and it's dated January 14,
2009.
Q. And it look likes in this e-mail Mr. Hawk is giving you information about the Michael Jackson Company
llc., is that right?

A. Yes. He was letting me know what the contracting entity would be for the tour agreement that they wanted
to replace what we had before -- I think it was MJJ Productions -- with the Michael Jackson Company llc.
Q. So that was actually going to be my next question. You were negotiating the tour agreement before
January 14th, 2009, right?
A. Yes.
Q. Was there a different company that was originally the contracting party for Michael Jackson?
A. There -- there was. We had put in a different company.
Q. And that was MJJ. Productions?
A. To my best recollection, yes.
Q. And then Mr. Hawk contacted you and said he wanted to switch it out with the Michael Jackson Company
llc?
A. Correct.
Q. Now, what was your understanding, if you had one, of what the Michael Jackson Company llc was at that
time?
Mr. Panish. Foundation. Objection.
Judge. Overruled.
Mr. Panish. And hearsay.
Judge. Overruled.
A. It was a limited liability company established in Delaware that had been a company that I believed had an
affiliation with Mr. Jackson.
Ms. Bina. Did you have any understanding that it was -- had previously been active in doing tours and things
of that nature with Mr. Jackson?
A. No.
Q. And Mr. Jackson hadn't toured in quite some time at this point, right?
A. That was my understanding.
Q. Did you have an understanding or an expectation, I should say, that Mr. Jackson would run all of the
activities of the Michael Jackson company llc. Personally himself?
A. Of course not.
Mr. Panish. There's no foundation.

Judge. Sustained.
Mr. Panish. Move to strike.
Judge. The motion is granted, the answer is stricken.
Ms. Bina. Would it surprise you if Mr. Jackson appointed officers to the Michael Jackson company after
January 14th, 2009?
Mr. Panish. Speculation, no foundation. It's not true. Contrary to the evidence.
Mr. Putnam. That's not an objection, your honor.
Mr. Panish. It is. Assumes facts not in evidence, number 1. Speculation, no foundation, contrary to the
evidence that will be introduced.
Ms. Bina. Your honor, I'm only trying to explain the witness's expectations at the time and why she wasn't
surprised to hear that Dr. Tohme had become an officer of the company.
Judge. So your question is "were you surprised that" what?
Ms. Bina. I was trying to get at the idea of would she have been surprised if, not was she surprised that.
Mr. Panish. Then that's speculation and no foundation. I don't want to -- I could go to the sidebar, but --
Mr. Boyle. I'm going to object, your honor. It's also irrelevant on what surprises Mrs. Jorrie.
Judge. Sustained on relevance.
Mr. Panish. Thank you.
Ms. Bina. All right. I think you testified Wednesday that you were told shortly before January 28th, 2009,
that Dr. Tohme was an officer of the Michael Jackson company.
Mr. Panish. Objection, hearsay, no foundation.
Ms. Bina. Your honor, plaintiffs' counsel elicited this information on cross, asked about it, it's already been
testified to.
Mr. Panish. I did not.
Ms. Bina. Which was that she had this understanding and had been told that by Mr. Gongaware before. I'm
just recapping.
Mr. Bloss. The question was January 28.
Ms. Bina. I said June 28, I thought.
Mr. Panish. And I asked her that question -- not that specific question, but --
Judge. You're saying the date of the conversation is different?

Ms. Bina. If I said January, your honor, I meant June. I will amend my question to say June 28.
Judge. Re-ask it.
Ms. Bina. All right.
Q. I believe you testified on Wednesday, Ms. Jorrie, and correct me if I'm wrong, that shortly before June 28,
2009, when Dr. Tohme signed that consent document, you had been told that he was an officer of the Michael
Jackson company. Is that right?
A. That's my best recollection, before the first version of that document was prepared, I was informed that he
was an officer of the Michael Jackson company, and I put that in --
Q. And then as we just saw he actually represented that himself and signed that document?
A. Yes.
Q. And is that the kind of representation that you normally rely on in your business, Ms. Jorrie?
Mr. Panish. Objection, expert, not relevant for this situation.
Judge. Overruled. You may answer.
A. Yes.
Ms. Bina. Now, Mr. Panish showed you two documents Wednesday, exhibit 173 and exhibit 468, dash, 110,
that refer to Dr. Tohme. Pam, if you can put them up side by side. Here's the one. Pass that up to the judge.
And here's the second one
A. Thank you.
Ms. Bina. Pam, can you just zoom in on the text of these documents?
Q. Ms. Jorrie, do you recall Mr. Panish asking you about these two documents?
A. Yes.
Q. And in each of these documents -- let's assume that these were, in fact, signed by Mr. Jackson -- Mr.
Jackson limited Dr. Tohme's relationship with him and his authority in some way, right?
Mr. Panish. Excuse me, your honor. First of all, this witness testified she never saw any of these documents,
so there would be no foundation for her to -- to rely on these or give testimony about them. So I object,
irrelevant, no foundation.
Judge. No foundation, sustained.
Ms. Bina. Your honor, remember the witness actually testified that she had seen these documents, just not
during Mr. Jackson's lifetime.
Mr. Panish. After Mr. Jackson died and after she had Mr. Tohme sign that. It's not relevant for anything she
did in this case. She did it without this. She's never seen these, your honor, until long after this was done. The
first time she saw it was in her deposition when she showed it to her.

Ms. Bina. I don't believe that was her testimony, either, your honor. But, in any event, Mr. Panish questioned
her about these documents. I'm just trying to establish what they do and don't say.
Judge. What was her testimony about these documents at trial?
Mr. Panish. She never saw them, she didn't rely on them, and now she's trying to get her to interpret what the
documents say. That is, number 1, irrelevant, number 2, beyond the scope, and number 3, your rulings on this
same exact issue.
Ms. Bina. I don't think it's beyond the scope since Mr. Panish introduced these documents.
Judge. Well, if she said she hadn't seen them --
Ms. Bina. What she said is she saw them after Mr. Jackson's death. Mr. Panish established that they were
sent to her client and to try to imply that Mr. Gongaware told her something false on June 28, 2009.
Mr. Panish. No, no. She told me she hadn't seen them. Now she's asking her to interpret documents she
never saw nor used when she made these decisions. It calls for expert testimony on documents she's never seen
and foundation.
Judge. I think there's no foundation if she's never seen them, unless you can go back and show me something
else from the trial testimony.
Ms. Bina. I was just going to ask if there were words in these documents, because Mr. Panish introduced
them --
Mr. Panish. No.
Ms. Bina. Okay. Ms. Jorrie, those documents that we just saw that you didn't see at the time were dated in
the spring of 2009, April and May. Is that your recollection of what Mr. Panish showed you on Wednesday?
Mr. Panish. Objection. Come on, your honor. How many times --
Judge. You mean, "did he show you this and then you said you didn't remember --"
Ms. Bina. All I'm trying to do is establish the timeline, that those documents were in April and May.
Mr. Panish. She never saw them. It's irrelevant and no foundation. Why does she keep asking --
Mr. Putnam. Your honor --
Mr. Panish. Can I finish, please, today, maybe?
Judge. All right. You finish. You're talking. Did you finish?
Mr. Panish. No. But I guess they said I did, so -- your honor -- now -- can I read what I was saying before I
was interrupted. I'm objecting, foundation, irrelevant. She's going to try to have this witness get in things she
didn't see that had nothing to do with the decision-making process. I asked her if she saw them, and she hadn't.
It's irrelevant, no foundation.

Ms. Bina. I'm only trying to clarify the timeline because Mr. Panish was implying that it was unreasonable for
her to believe that Dr. Tohme was an officer in June of 2009. These are in May. All I was asking was what the
date was of documents that Mr. Panish himself put in front of the witness, and I was going to move on away
from the documents into a related topic.
Mr. Panish. That's argument by counsel.
Mr. Putnam. This is not an instance where one put a document before and said, "do you have any foundation
for this?" they didn't, and therefore, we moved on. What happened, "did you have a foundation?" no. Then he
goes on to say, "what does it say?" and I don't see why she can't say in this instance what the document in fact
says, or what the date of it is. She can't --
Mr. Panish. So now we're rearguing --
Mr. Putnam. I'm sorry. I hadn't realized I had finished, Mr. Panish. Your honor, I think the ability to then go
and show what the facts say, have her emphasize what it says, not interpret what it says, and then say what it
doesn't say --
Judge. So you are representing that when she was questioned by Mr. Panish, she --
Mr. Putnam. Wasn't that --
Mr. Panish. That's not what happened.
Ms. Bina. I can check. But I'm happy to move on, your honor, in the interest of saving time and letting this
witness go on vacation with her grandchildren.
Mr. Panish. She's not going on vacation. Your honor, she's not going on vacation.
Judge. Mr. Panish, you're interrupting. Remember everybody gets a chance? It's Ms. Bina's chance.
Ms. Bina. I am happy to move on, your honor. Ms. Jorrie, Mr. Panish just said you're not going on vacation
with your grandchildren.
Judge. Ms. Bina, irrelevant.
Ms. Bina. Ms. Jorrie, do you have an understanding that at some point after May 5th, 2009, Dr. Tohme was
working for Mr. Jackson in some capacity?
Mr. Panish. Objection, foundation, hearsay and attorney/client.
Judge. Sustained.
Ms. Bina. None of the above, your honor. It's not based on attorney/client communications, it's based on the
June 28 meeting, which I believe is what the witness will tell me. I was trying to lead into that subject.
Judge. All right. Overruled.
A. Dr. Tohme was invited to and attended the May 28 meeting at which we had -- you've heard about the
various people that were there. We had John Branca, Mr. Mclean, the other co-executor was on the phone, we
had various attorneys from John Branca's office, we had Frank Dileo, attorneys from the Greenberg Traurig

office, various representatives of AEG Live, and he was there speaking about things having to do with Michael
Jackson, including --
Mr. Panish. That, again, would be hearsay.
A. -- including --
Judge. Overruled.
A. I'm sorry. -- including he was talking about him taking steps to try to preserve the property that belonged to
Michael Jackson at his home so that it would be carted to the appropriate place so that the estate would
eventually be able to determine what is the appropriate disposition of that property.
Ms. Bina. And just for a clean record, Ms. Jorrie, I believe you just said May 28. Did you mean May --
A. June 28. I apologize. Thank you for correcting that.
Q. So if I understand you correctly, at the June 28 meeting called by Mr. Branca, Dr. Tohme was there
discussing Michael Jackson's business affairs?
A. In front of everybody, yes.
Q. Okay. And that authority -- his authority at that meeting was not challenged, that you saw?
Mr. Panish. Objection, no foundation. It's also calling for a legal conclusion, challenging someone's
authority.
Judge. Overruled.
A. Nobody challenged Dr. Tohme, his presence or his statements.
Judge. And were you present during the meeting?
A. I sure was, yes.
Ms. Bina. And did that help confirm your understanding that Dr. Tohme had some kind of relationship with
Mr. Jackson at that time when Mr. Jackson passed?
A. Absolutely.
Q. Now, turning back to exhibit 372, dash, 1, let's throw it back up there real quick. I'd like you to just read
the first paragraph there, the one that says "1, Budget."
A. It says "Budget. I hereby confirm that Artisco approved the attached budget of expenses, which includes
production costs and pool expenses as such terms are defined in the agreement," referring to the agreement
referenced above.
Q. And did Mr. Jackson's manager, Frank Dileo, sign a similar document also affirming that Mr. Jackson had
approved the budget of expenses?
Mr. Panish. Foundation, beyond the scope, hearsay.

Judge. Possibly lack of foundation. Sustained.

Ms. Bina. Ms. Jorrie, have you ever seen a document where --
Mr. Panish. Time.
Ms. Bina. -- where Mr. Dileo signed something similar?
Mr. Panish. Still, foundation, after this all occurred.
Judge. Overruled.
A. I have.
Ms. Bina. And did Mr. Dileo also acknowledge that the tour expenses had been approved by Mr. Jackson
prior to his death?
A. I think it was by -- it might have been by the Michael Jackson company. I'd have to look to be certain.
Q. Well, in the interest of saving --
A. I want to be precise.
Q. The document is in evidence, so in the interest of saving time, I'll skip over that for now. But it was one
or the other?
A. Or both, yes.
Q. And do you -- were you involved in another agreement where AEG Live was ultimately reimbursed by the
estate of Michael Jackson for approximately 36 million in production costs and related expenses?
Mr. Panish. Number 1, it's irrelevant as to whether or not Mr. Tohme was an officer of the company.
Number 2, this would then get into attorney/client privilege. They can't just ask that and prohibit me from
questioning her all about that, and it has nothing to do with her decision that she did this.
Ms. Bina. Your honor, I'm trying to avoid some M.I.L.Issues by asking this in an oblique fashion. I'm happy
to go to sidebar if you think there's an issue. But there's been numerous amounts of testimony in this case that
the estate did reimburse these costs. I'm just trying to confirm whether this witness is aware of that.
Judge. Overruled. You may answer.
A. I am aware that the estate reimbursed those costs from sources outside of attorney/client communications.
Ms. Bina. All right.
Q. Now, you said on Wednesday, if I recall correctly, that a man named Howard Weitzman might have been
the person that told you that Dr. Tohme had been fired at some point by Mr. Jackson.
A. Yes.
Q. Mr. Weitzman is an attorney for the estate of Michael Jackson, correct?

A. Correct.
Q. But whatever Dr. Tohme's role, the estate of Michael Jackson did agree to reimburse production costs,
right?
A. Yes.
Q. New subject. Trying to get through this quickly. On Wednesday, Mr. Panish asked you a number of
questions about whether Mr. Woolley had ever forwarded you an e-mail he received from Dr. Murray in May
2009 that said certain things. Do you recall that?
A. I do.
Q. I'd like to ask a couple of questions along the same lines. Did Mr. Woolley ever forward you an e-mail
from Dr. Murray saying that while Dr. Murray was basically in agreement with Mr. Woolley's characterization
of the phone call, he wanted his lawyer to review any draft contract with AEG Live before he signed it?
A. He did not.
Q. And I think you testified on Wednesday that Mr. Woolley never forwarded you an e-mail in which Dr.
Murray stated he was fully engaged in providing services to Mr. Jackson, is that right?
A. Yes.
Q. Would it surprise you to have heard that Dr. Murray was fully engaged with Mr. Jackson in May 2009?
Mr. Panish. It's irrelevant, no foundation whether she is surprised or not.
Judge. Overruled.
A. Not at all, Ms. Bina.
Ms. Bina. Why not?
A. Because --
Mr. Panish. Well, again, your honor, it's foundation. She's now going to -- it's -- it's irrelevant, no
foundation. And at the time, she had no -- the only information she had was from her client, so -- I was blocked
on this, now she's going to give reasons why it wouldn't surprise her, and the only information she had at the
time that all this occurred was from her client, and I was prohibited from asking about that extensively.
Judge. Overruled.
A. Because I understood from Dr. Conrad Murray and -- as well that Michael Jackson -- excuse me -- Dr.
Conrad Murray was Michael Jackson's personal physician for three years.
Ms. Bina. Dr. Murray actually told you that?
A. He did.
Q. Did you ever tell Murray -- Dr. Murray not to perform services to Mr. Jackson until his agreement with
AEG Live was fully executed?

A. Of course not.
Q. And, again, why not?
Mr. Panish. Again, your honor, it's irrelevant, what she did in this case, no foundation.
Judge. Overruled.
A. The reason, Ms. Bina, is because Dr. Conrad Murray was Michael Jackson's physician, and it would not
have been my place to suggest that he shouldn't perform services for a patient that had been his patient for a
number of years.
Ms. Bina. Did Dr. Murray need an agreement with AEG Live to treat his long-term patient?
Mr. Panish. Objection, calls for speculation, foundation, expert testimony.
Judge. Overruled.
A. No, he did not need an agreement with AEG Live to perform services for a patient of his, including Michael
Jackson.
Ms. Bina. Now I'd like to ask you a few questions about the draft agreement with Dr. Murray, exhibit 168.
And let's put that back up. And this is the -- I'll represent the last version that Dr. Murray signed.
A. Thank you.
Ms. Bina. And, Pam, if you can zoom in on the top there. Ms. Jorrie, I think you testified on Wednesday that
payment under the draft agreement would have been retroactive back to May 2009.
Q. Is that correct?
A. When -- when and if signed, yes, by all signatories.
Q. And that was represented here in the effective date and also in the provisions -- I think it's 3 that dealt with
term.
A. Yes.
Q. Were there any other provisions of this draft agreement that dealt with timing?
A. Yes. Timing of payment, Ms. Bina, or timing of something else?
Q. Timing of payment I guess is good enough.
A. Yes. Paragraph 3, if you move to that -- there's two provisions. This is one of them.
Q. And what about this dealt with timing? Just read it for us.
A. Paragraph 3, the portion dealing with timing, it says "producer shall remit payment to GCA In the amount
of $150,000 per month to be paid on the later of the 15th day of the month or five business days after the
execution and delivery of -- of the agreement."

Q. And I believe Mr. Panish asked you Wednesday if the execution date of a contract means the date the
contract is signed, and you answered yes, is that right?
A. That's my recollection.
Mr. Panish. Objection, I didn't ask that question.
Ms. Bina. Page 13236, lines 15 to 20, "the term means the execution date. That means when the contract was
signed, right?" answer, "yes."
Mr. Panish. Your honor, can I --
Judge. She's helping you out.
Mr. Panish. I doubt it. What page? What page?
Judge. Which page, Ms. Bina?
Ms. Bina. 13236, lines 15 through 20. We can put it up.
Mr. Panish. I don't need it up there. I just want to see it. Okay. The term -- you want to say on line 12?
Ms. Bina. Yes. You were asking her about a document, and you asked whether the execution date means
when the contract was signed.
Mr. Panish. This wasn't this document I was asking about. I was asking about 67. If you look right here, I'm
asking about exhibit 67's terms of the agreement, 67, dash, 18, paragraph 14. I was asking about -- it's
completely different than this agreement, so I'm glad I got a chance to look at it. And what it says is "and the
term was from December 31 to the conclusion." let's look at this. "that's page 6718, paragraph 14, that you
wrote, ma'am, that's the true agreement. This is the term," and I go into the specific term of that agreement. I
didn't ask her about this agreement.
Ms. Bina. Your honor, I understood it to be a question about the meaning of the word "exclusion." is Mr.
Panish contending that it means something different in one document than in a different document?
Mr. Panish. It says right here about the major territories of the tour as mutually selected by Artisco and
promoter. That's what I was talking about, and for her to say I asked about this document and execution date,
that's wrong, and I'm glad that I looked at it. And she wasn't helping me.
Mr. Putnam. That's not what she said.
Mr. Panish. She did say that. I asked her that question.
Ms. Bina. Your honor, may I briefly, for the record -- I asked whether Mr. Panish asked if the execution date
of a contract meant the date a contract was signed. He did, in fact, ask that. He may be talking about a different
document. Apparently he now contends that "execution date" means one thing in one document and another
thing in another document. But he asked her to define the term.
Mr. Panish. I did not ask her and I didn't ask her after execution and delivery of the agreement, as this
document says. And she just tried to say I said that, and that's not true, as proved by the transcript.

Judge. I'm sustaining the objection.

Ms. Bina. All right.
Q. Ms. Jorrie, does "execution date" here mean the date the contract was signed?
A. Yes, by all parties.
Mr. Panish. That's expert testimony as to what -- execution of the term of the document.
Judge. Sustained.
Ms. Bina. Your honor, again, I think it's a little unfair if Mr. Panish is allowed to ask what execution means in
another document and I'm not allowed to ask what it means here.
Mr. Panish. I didn't ask what it meant in that document. It's also beyond the scope of what I asked.
Ms. Bina. "the term means the execution date. That means whether the contract was signed, right?"
Judge. Isn't that in reference to another agreement, though?
Ms. Bina. It is, your honor, but I don't see why it's not expert testimony for Mr. Panish to ask Ms. Jorrie what
that means in another contract she drafted and I'm not allowed to ask about this.
Judge. It could be different things in different agreements, that's the problem, so I'm going to sustain the
objection.
A. There's another place, as well.
Mr. Panish. There's no question pending. Is she just going to testify without questions?
Ms. Bina. I believe, your honor, she was referring back to my prior question about provisions that dealt with
timing.
Q. Is that right, Ms. Jorrie?
Judge. Overruled. You may answer.
A. Yes, that's right.
Ms. Bina. You said there was another provision?
A. Yes. Paragraph 9.
Q. Let's turn to paragraph 9. Just so we don't get into any issues in interpretation, just read paragraph 9 for
me.
A. Yes. "Artist Consent. The effect of this agreement is conditioned upon the approval and consent of the
artist. Without the artist's express and written approval of the agreement, neither -- neither party to the
agreement will have any rights or obligations to one another arising from the agreement."

Q. Now, you were also asked Wednesday about whether there was any language in this draft agreement that
specified how AEG Live would make sure that Dr. Murray was providing medical care to the greatest degree to
be expected from similarly situated members in the medical field. Do you recall that?
A. I recall the question.
Q. And you said, "of course not," if I recall correctly.
A. I -- I said that AEG would not be in a position to assess, and I didn't put anything in here that would require
AEG to assess the compliance of Dr. Murray in performing his duties as a doctor.
Q. And why not?
A. This is an independent contractor agreement. Dr. Murray was Michael Jackson's physician. He was
retained at the request and expense of Michael Jackson to perform medical services. He's an independent
contractor --
Mr. Panish. Your honor, I'm going to object to her now getting into legal -- independent contractor,
employee.
Judge. Sustained.
Mr. Panish. Again violating the motion in limine.
Judge. Sustained.
Mr. Panish. She continues to do it.
Judge. We have other people, experts, to do that, so sustained.
Mr. Panish. Yes, we do, so move to strike those answers.
Ms. Bina. Your honor, I think the first part of the answer was fine. She was just trying to explain why she
didn't put this in, which is a door opened by Mr. Panish asking why the agreement says that.
Mr. Panish. I asked is there such an agreement. That's all I asked. Now she wants to expand it in violation
of your motion in limine, the witness continually has to be admonished.
Judge. The answer is stricken.
Mr. Panish. I ask that she be admonished again on the orders of the court to not do that.
Judge. The answer is stricken.
Ms. Bina. All right. In any event, Ms. Jorrie, you didn't put a provision in for Dr. Murray to be supervised
by AEG Live?
A. Of course not.
Q. Do you know whether a company can access someone's medical records without breaking their
physician/patient privilege?

Mr. Panish. It's beyond the scope, number 1. Number 2, it would be expert testimony, not something that she
does, and I didn't ask anything about that.
Judge. Sustained.
Ms. Bina. All right. Now I'd like to look at paragraph 3.3 of exhibit 168, which deals with medical
equipment. I think I had it, Pam. Do you recall Mr. Panish asking about this provision?
A. I do.
Q. Does this provision in any way limit what equipment Dr. Murray is permitted to use in his treatment of
Mr. Jackson?
A. It does not.
Mr. Panish. Calls for -- calls for the interpretation of the agreement. All I asked was is this what the
provision says. I didn't ask her what Dr. Murray can do or can't do and have her interpret this provision, which
she's now doing.
Judge. Sustained.
Mr. Panish. And move to strike what she said.
Ms. Bina. Do any words --
Judge. Wait a minute. The motion is granted, the answer is stricken. You may be able to ask it in a different
way.
Ms. Bina. That's what I'm going to do.
Q. Are there any words in this paragraph that say Dr. Murray can only use equipment that AEG approves?
A. There are no such words.
Q. Are there any words in this equipment that say Dr. Murray can only order equipment through AEG Live
and can't get equipment from his own medical practice or elsewhere?
A. There's no such words in the agreement.
Q. Is there anything -- does anything say in here that Dr. Murray can only treat Michael Jackson with
equipment that AEG Live has approved?
A. No, there's nothing in here that says that.
Q. Does this provision say that AEG Live would provide Dr. Murray equipment when he asked for it so long
as it was approved?
A. I -- it's -- I'm not sure I understand the question. I'm sorry.
Q. It's probably a bad question. All right. Does this provision say producer shall provide Dr. Murray for his
use during the term with medical equipment requested by Dr. Murray to assist him in performing the services as
approved by producer?

A. Yes.
Q. And it doesn't say any of the other things I just asked you about?
Mr. Panish. Vague, ambiguous, asked and answered.
Judge. Asked and answered. Sustained.
Ms. Bina. All right.
Q. Did Dr. Murray ever ask you for any equipment?
A. No.
Q. Now I want to talk briefly about the end date of the draft agreement with Dr. Murray. If we go back to
page 1, I think that's paragraph 3. Actually, it might be up in the -- in recital A. Now, I believe you testified on
Wednesday that this date was originally September 30th, 2009, and it was changed to March 6th, 2010.
A. Correct.
Q. And that Dr. Murray had actually requested that change?
A. That's right.
Q. And Dr. Murray told you he had spoken with Mr. Jackson and confirmed that Mr. Jackson wanted him --
wanted to pay for him all the way through this time period?
A. That's right.
Q. And then Mr. Panish asked you if you personally checked with Mr. Jackson or his representation --
representatives before making this change. Do you recall that?
A. I do.
Q. And you said no?
A. That's right.
Q. Why didn't you check with Mr. Jackson or his representatives before making this change?
A. Because we were negotiating the contract to a point where when it was to a place where Dr. Murray was
happy with the terms, it would be presented to Michael Jackson for review and his representatives for review
and comment. And if he had comments, he would be free to provide comments and changes if he wanted to.
Q. And did you have any reason to believe that Mr. Jackson would sign this agreement if he didn't agree with
it?
Mr. Panish. Objection, speculation.
Judge. Sustained.

Mr. Panish. Foundation. She doesn't know.

Ms. Bina. Now, I think you just testified your understanding was that the agreement ultimately would be
presented to Mr. Jackson or his representatives.
A. Yes.
Q. And did that ever happen?
A. No, it didn't.
Q. Why not?
A. Michael Jackson passed away.
Q. Now, a couple more questions about this draft agreement. You testified that you based this agreement off
an agreement you used to engage an independent contractor for a King Tut exhibition, is that right?
A. Correct.
Q. Let's put that up, exhibit 1063. Again, I think you have this already, but in the interest of moving things
along -- now -- and Mr. Panish asked you about a couple of provisions that you took out of this agreement. Do
you recall that?
A. Yes.
Q. And one of them was paragraph 7.1. Actually, 7.1 and 7.2, put them both up, Pam. Do you recall being
asked about taking these out?
A. Yes.
Q. Why did you take them out?
Mr. Panish. I'm going to object. Number 1, all I asked her was it taken out, not her reasons. Now she's going
to give reasons interpreting, expert testimony. I know that's what she's going to blurt out here. So before we do
that, I want to make sure -- I know what she's going to say now.
Judge. Let's go to sidebar and have a discussion about that.
(the following proceedings were held at sidebar:)
Judge. First let's find out from Ms. Bina what you expect the witness is going to say.
Ms. Bina. What I expect the witness will say, your honor, is that these were relating to someone working for a
rival company, and that she didn't think they were applicable here. And I can ask her -- if you want, I can pull
her aside for a moment to make sure she doesn't say anything more than that. But Mr. Panish asked her and
specifically flagged that she took these provisions out. He's going to put it up in closing argument and say,
"they knew there was a conflict and that's why they took them out" when it had nothing to do with that. These

conclusions were about interactions with other companies, competitors and working for rival companies. She
should be given an opportunity to explain that.
Mr. Panish. What she's going to say -- I don't know how she knows what I'm going to argue in final argument
because I don't know that yet. All I asked was what was taken out, and she told me two provisions. Now she's
going to say, "why did you take it out?" because it wasn't applicable here, and the inference will be there's no
conflict of interest. That's not something she can testify about, and that's the inference of her testimony. That is
expert testimony. She decided -- if someone is saying, "I determined it wasn't applicable," that means they
determined there's no conflict of interest. That's not something she can testify about.
Mr. Putnam. Your honor, it literally flashed up on the screen, "What's the one thing you took out of this
agreement? Conflicts? Okay."
Mr. Panish. Two things.
Mr. Putnam. You asked for one thing, she explained there were two. But the point being, your honor, the
implication that they're trying to make is clear for everyone. We've been here for 17 weeks. I think we're
allowed to say, "Why did you not put that in there?" I think she's allowed to say why she specifically didn't put
this in there.
Ms. Bina. And I'll talk to her briefly now to make sure we don't go beyond that and get into any M.I.L.Issues.
Mr. Panish. Then I can ask her about the determinations she made to determine whether there were conflicts
of interest, and who she talked about, and did she talk to Mr. Phillips and all of them.
Judge. It sounds like she -- isn't what happened was she didn't contemplate the conflict you were thinking of,
but she did think about this conflict? That's what happened.
Mr. Putnam. She can also talk about that if that's what she's going to say.
Mr. Panish. What's she going to say about that?
Mr. Putnam. Let's see. Go ahead and ask.
Mr. Panish. You know what she's going to say. You see, your honor?
Judge. Well, you asked about the provision.
Mr. Panish. I just received the document the day she was on the stand, and I said, "is there anything you took
out?" she said these two provisions. That's all I asked.
Judge. Okay. And now they want to ask her why she took them out.
Mr. Panish. Your honor, she keeps saying -- she puts her up there --
Ms. Bina. I would just like to stay on one point per sidebar.
Mr. Panish. Well, I don't want to have to come back because now they're running out my time. They said
she's going on vacation. She's going to the airport at 5:00 o'clock, she has to pick up her grandkids, she said.
Okay? At 5:00 o'clock. So now the implication is now we're going to be at 11:00 something, my cross-
examination is going to be interrupted.

Judge. How much longer do you have, Ms. Bina?

Ms. Bina. I have about four pages left, your honor. I'm going as fast as I can. Mr. Panish is objecting a lot.
Mr. Panish. Because you're asking improper questions.
Ms. Bina. Anyway, your honor, I'm trying to move things on. If he would make shorter objections, it might
go faster. But the point is I'm nearly done.
Mr. Panish. When we add up the objections in this trial, we'll see who's making more objections.
Judge. I'm overruling the objection.
Ms. Bina. And let me talk to her, make sure there's no issues.
(the following proceedings were held in open court, in the presence of the jurors:)
Judge. You may continue.
Ms. Bina. Let me ask you quickly, Ms. Jorrie, this agreement that you based the draft Murray independent
contractor agreement, who was it between?
A. It was between an individual and arts and exhibitions international llc., which is an affiliate of AEG Live.
Q. Was that individual providing personal services to an artist?
A. No.
Q. And is paragraph 9 the artist consent provision in this draft?
A. No.
Q. Is there a signature block for the artist in this draft where it says the agreement is being made at the request
and expense of the artist?
A. There's not.
Q. So all of that is different from the draft Dr. Murray agreement?
A. Yes.
Q. Okay. And then Mr. Panish asked you about a couple of provisions that you took out, and then were there
also other provisions that you added?
A. Yes.
Q. I'd like to ask about the ones you took out briefly. And one of those was 7.1 and 7.2. Ms. Jorrie, did you
take these provisions out of this draft before you made the draft Murray agreement?

A. I did.
Q. Why?
A. Because these provisions deal with the conflict that could arise where the consultant is performing services
to third parties, and there may be a conflict there where he has information he secured from third parties and his
duties for them and his duties for arts and exhibitions here could be in conflict, and he's supposed to make a
disclosure and get appropriate waivers, and that wasn't applicable to the Dr. Murray contract.
Q. So is this -- this is a situation where the consultant might be working for a competitor of arts
entertainment?
A. Yes.
Q. And that was something that you didn't see as an issue with the Dr. Murray agreement?
Mr. Panish. Foundation, expert testimony.
Judge. Overruled.
A. That's right.
Ms. Bina. And then there was another paragraph that you took out, right? I believe it was paragraph 10?
A. Yes.
Q. Blow that up. And why did you take this provision out?
A. It's also not applicable to the Dr. Murray agreement. This provision had to do with the ownership of
intellectual property rights, trademarks that would -- belonged to the organizer, the organizer of the King Tut
exhibition, and also indicating that the work that's performed by the consultant would be original works of
authorship and that the organizer there would be the owner as the company that engaged the consultant.
Q. So you were -- you removed these two paragraphs because they were specific to the position of the
independent contractor who was working on the King Tut exhibition and the services he was providing in
connection with that agreement?
A. Yes.
Q. And did you add provisions to the draft Murray agreement that related specifically to the services that Dr.
Murray would be providing in connection with Mr. Jackson?
A. I -- I added and replaced.
Q. And I think one of the ones you added was paragraph 9, "artist consent."
A. Yes.
Q. New subject. On Wednesday, Mr. Panish asked you some questions about representations Dr. Murray
made to you, and one of those was that from his four practices in four states, Dr. Murray -- Dr. Murray was
grossing 100 million -- 100 million? -- $1 million per month. Do you recall that?

A. I do.
Q. Now, I want to clarify, did you understand Dr. Murray to be telling you he personally took home $1
million a month?
A. I didn't understand that.
Q. What did you understand?
A. That his medical practices brought in $1 million with which it would pay its various expenses, nurses,
clinics, equipment, leases, et cetera.
Q. And if I understood you correctly on Wednesday, you also testified that you didn't necessarily think that
Dr. Murray was going to close all of his practices to go on the tour?
A. I didn't think that at all.
Mr. Panish. That wasn't the question. Misstates the testimony.
Judge. I think it does. Sustained.
Ms. Bina. Did you have -- I don't think it misstated it, but let me check.
Q. Did you understand that Dr. Murray was going to be closing all four of his practices?
A. I did not.
Q. What did you understand?
A. That he told me he was leaving the -- the practices to go on tour with Michael Jackson.
Q. Did you have any understanding one way or the other as to whether the practices would be closed?
A. I -- I assume not, but --
Q. But he didn't tell you one way or the other?
A. No, he didn't.
Q. Now, Mr. Panish also asked you about your online search on Dr. Murray and what you found. And I
believe you said that you found that Dr. Murray was licensed in four states, and then you found two clinics, one
in Texas and one in Nevada, is that right?
Mr. Panish. Objection that she found two clinics. The testimony was that she found two addresses.
Judge. Sustained.
Ms. Bina. Your honor, I think the testimony was that she found two clinics and Mr. Panish tried to argue with
her and say they weren't clinics.
Judge. I sustained the objection.

Ms. Bina. What did you find, Ms. Jorrie?

A. I found that there were two places of business. Whether they're called clinics or not, I can't remember what
I said, but that's certainly what I meant.
Q. And to your understanding, these were places where Dr. Murray provided medical services to patients?
Mr. Panish. There's no foundation that she knew any of that.
Judge. It's leading. Sustained.
Ms. Bina. What was your understanding?
Mr. Panish. She has no foundation for her understanding other than she saw an address. That's what he said.
There's no foundation for what was going on at these addresses.
Ms. Bina. Your honor, her testimony was that on the state medical board she found a description of places
where services were rendered, and they sounded like medical practices.
Mr. Panish. There's nothing on the board that says services are rendered. It gives an address for that. That's
all that's there.
Judge. I'll let you go back and try to lay some foundation.
Ms. Bina. All right.
Ms. Bina. Ms. Jorrie, when you looked at these state websites, what did you find?
A. The state websites?
Q. The state medical board websites.
A. Okay. I found that Michael Jackson -- excuse me -- that Dr. Murray was licensed to practice medicine in
all four states, that he was -- that there were no disciplinary actions or complaints of any kind against Dr.
Murray in any of these four states. I recall that he was licensed in some of the states in the area of internal
medicine -- your question is broader than before -- and a cardiology or cardiovascular area. And then I recall
reference to a business, which I assumed --
Mr. Panish. Well --
A. -- was a clinic, but whether it's a clinic or a medical practice or what you call it, I'm not sure. I also did
online research, at which I saw two places of business that I assumed were clinics, but I'm not positive they're
called clinics, one in Nevada and one in Texas.
Ms. Bina. And if I represent to you that there's been testimony in this case that Dr. Murray had two clinics,
one in Nevada and one in Texas, by detective Martinez, would that be consistent with your recollection?
Mr. Panish. No. Objection. Misstates -- she didn't know that.
Judge. Sustained.
Ms. Bina. Is that what you believed at the time?

Mr. Panish. No foundation.

Judge. Overruled.
A. It is.
Judge. You may answer.
A. It is.
Ms. Bina. So you believed that there were two clinics, based on your searches?
Mr. Panish. Leading, asked and answered.
Judge. Overruled.
Mr. Panish. Foundation.
Judge. She believed it.
A. That's right.
Ms. Bina. Now, Mr. Panish also asked about the fact that you found two businesses and not four.
Q. Did that cause you to question Dr. Murray's representation that he had medical practices in four states?
A. It did not.
Q. Why not?
A. It was just a spot check. What he had told me was that he was licensed in these four states. I checked it,
he was licensed, there were no disciplinary actions, his company was a valid company that he asked that we use,
GCA Holdings llc. What he informed me was, through my, literally, spot check -- was entirely consistent.
Q. Now, Mr. Panish asked a lot of questions about additional searches you could have done, like performing a
lexis search on Dr. Murray, or looking into his personal finances. Do you recall that?
A. I do.
Q. Why didn't you perform those additional searches?
A. I had no reason to doubt the information that was provided to me. It didn't raise any red flags that would
lead me to make any such recommendation to my client or to do those types of things, nor would I have thought
that it was my place to do an investigation of Michael Jackson's personal physician from a number a years.
Q. And everything you did check on checked out, right?
A. Yes.
Ms. Bina. Nothing further at this time.

Recross-examination by Mr. Panish

Q. You said he had a valid company, is that right?
A. GCA Holdings llc.
Q. Was a valid company?
A. Yes.
Q. Because it had a license, right?
A. It was on the website that said it was valid.
Q. No, it didn't say it was valid. It said whether it was licensed or not, didn't it?
A. When -- when I looked at the Nevada Secretary of State website, it identified his company as not having
been revoked or suspended or anything like that at the time.
Q. But you didn't know whether any business was being conducted, did you?
A. GCA Holdings?
Q. Yes.
A. No, I did not.
Q. You didn't know -- you said he made a million a month, you thought gross, you don't know how many
employees he had, right?
A. I had no idea, sir.
Q. No idea how many nurses he had, right?
A. Correct.
Q. And, Ms. Jorrie, all that research, do you have a bill for the work that you did for that?
A. It was ten minutes of research, and it was part of my preparation of the tour -- of the Conrad Murray
agreement.
Q. So that would be listed in your time statements for the work you did, right?
A. It would be listed as preparation of the Conrad Murray agreement.
Q. Okay. And would you list down that you did research on Dr. Conrad Murray?
A. Not if it was a spot check of the validity of the company or if I was using that information in order to
prepare the agreement.

Q. Did you bring the bill with you?

A. I did not.
Q. Do you have it?
A. I do not.
Q. Where is it?
A. It's at my office. It was subject to the motion to quash that we filed.
Mr. Panish. Your honor, it's not subject to the motion, number 1. Number 2 --
Q. Ms. Jorrie, you brought the bill for the 19th, didn't you?
A. I brought the bill for the 19th because that bill refreshed my recollection, sir, and -- and as you recall, you
-- you --
Q. Ms. Jorrie, I asked you one question. Did you bring the bill for the 19th?
Ms. Bina. Your honor, I ask that the witness be allowed to answer the question before --
Judge. It's yes or no. Did you bring the bill for the 19th?
A. I brought a time entry for the 19th.
Mr. Panish. I'm going to mark this and offer it.
Mr. Boyle. 1065.
Mr. Panish. 1065. I'm going to show this detailed billing to you, Ms. Jorrie.
Q. Is this your bill for the 19th for work you did for AEG?
Mr. Putnam. Objection, your honor. She repeatedly said it's not her bill, it's her time entry.
Mr. Panish. Time entry, and later you get paid when you submit that to AEG Live, right?
Mr. Putnam. No. That's not how it works, your honor.
Mr. Panish. If Mr. Putnam wants to testify, I'd be happy to call him about it.
Mr. Putnam. I wish you would.
Judge. Sustained. Let's find out from the witness first.
Mr. Panish. Is that your time entry?
A. What this is it's a time entry report that shows what I described as the work that I performed on the matter
in which I performed it into our computer system.

Q. That's fairly detailed, isn't it?

A. It's fairly detailed.
Q. And then later, it's prepared in a bill, right?
A. This information gets relayed to what's called a pro forma, and then we review the pro forma, we make
edits if appropriate, and it ultimately gets put into an invoice form that would identify the work performed
during the month and the charges of the individuals who do the work.
Q. And you sent it to the client?
A. That would be our normal practice, unless there's a reason not to.
Q. And pro forma is a software program, right?
A. No.
Q. You don't put this into a software program?
A. We did. It's not called pro forma, and that's not what I was referring to.
Q. Is there anything about a Google search in this entry?
A. No, there's not. This entry -- no.
Q. Do you have the bill from the date -- what would the date be for the -- this date of work is 6/19, right?
A. Yes, it is.
Q. Okay. And the day you did the Google search was on what day?
A. It was on the 18th of June.
Q. And you have -- for work you did on AEG Live for the 18th, you'd have a detailed time entry, correct?
A. I'd have a time entry for the work that I performed in the matter in which I was preparing the Dr. Murray
contract in.
Q. And does that bill show the alleged Google search?
A. I'd have to check, sir. It wouldn't necessarily be my practice to do that.
Q. Well, I asked you two days ago about checking, didn't I?
A. No, you didn't. Not that I remember, anyway.
Q. Well, I'd like to see that bill. Do you have any objection to showing that to us?
A. It contains attorney/client communications, sir.

Q. Well, you're testifying about attorney/client communications and work you did, aren't you?
Ms. Bina. Your honor, I would object. This was all subject to a motion to quash. If they're asking for
specific billing records, that's a subject dealt with via a request, a subpoena, motion practice. I think it's
inappropriate to get into an argument on the stand with the witness on the subject.
Judge. Okay. Sustained. We can take this up outside --
Mr. Panish. Does your time entry have an entry for the work you did doing your check of Dr. Murray, yes or
no?
A. Sir, if I could look at it, it would refresh my recollection as to whether it did or not.
Q. So you didn't look at it to come testify about this specific day you did the work to refresh your recollection,
you remembered that from four years ago, right?
A. No. What I used to refresh my recollection, Mr. Panish, was the e-mails back and forth from Mr. Woolley
to me and then from me to Dr. Conrad Murray. I was very careful to review those carefully, and they all
identified every conversation I had with Dr. Murray. I did not need to look at my time records to refresh my
recollection. In this case, I did need to look at my time to refresh my recollection, and I brought it in knowing
that you would ask me, "did you refresh your recollection with anything?"
Q. That wasn't the question I had. My question was real simple. Did you -- does that bill say "Google search"
or research you did on the spot check for Dr. Murray, yes or no?
Mr. Putnam. Asked and answered four times, your honor. She said she doesn't know.
Judge. Sustained.
Mr. Panish. Okay. So you don't know. That's right. Okay.
Mr. Putnam. Five times, your honor.
Mr. Panish. That's my point. Now let's talk about red flags. You brought up red flags. What's a red flag that
you brought up? You brought up red flags -- remember? -- when Ms. Bina just questioned you, there were no
red flags, right? Didn't you just say that?
A. I -- I may have. What's your question, sir?
Q. My question is what is a red flag?
A. It's -- it's when something goes up and alerts your -- alerts you to something to consider.
Q. So as a lawyer, you -- when you're doing work for a client, you're looking for red flags, things that come
up to alert you to further evaluate a situation? How is that?
A. Yes.
Q. Okay. And so you were looking for red flags for Dr. Murray, right?
A. Not -- not any more so than I would for anything, sir.

Q. But you just told us there were no red flags raised. That was your testimony, right?
A. Yes.
Q. Okay. And there are no red flags raised based on a less-than-ten-minute Google search you did, correct?
A. That's right.
Q. Okay. And did Mr. Gongaware -- strike that. Let's start with your spot check for -- you were looking for
red flags, weren't you?
A. I was checking the information given to make sure it was consistent.
Q. You were looking for red flags, weren't you?
A. I think that's fair, yes.
Q. Okay. And you went to six spots on the internet, right?
A. I couldn't tell you how many spots I went on the internet.
Q. Well, you told us the other day at page 13008, "I took the information for Dr. Murray and I checked
online. I went to the Nevada company to check the llc.," right?
A. Yes.
Q. That's the Secretary of State of Nevada, correct?
A. Yes.
Q. Then you went on to see the four websites that he was licensed on, right?
A. Yes.
Q. And what other things did you go on?
A. The -- the Google searches allow you to, you know, meander.
Q. Did you ever do a Google search for the Michael Jackson Company?
A. I Googled Michael Jackson. I can't remember if I Googled the Michael Jackson Company, sir.
Q. Well, do you know if you do a Michael Jackson Company, it comes up right to the Delaware Secretary of
State?
A. No, but I checked the Delaware Secretary of State and I checked the Michael Jackson Company llc.
Q. So you did go on the Delaware Secretary of State. Did you see what year the Michael Jackson Corporation
was formed?
A. I did see what year it was formed.

Q. Okay. Well, let me first show counsel, because I don't have another copy, for the Delaware Secretary of
State, an official document. That will be the next exhibit, which will be what?
Mr. Boyle. 1066.
Mr. Panish. 1066.
Mr. Boyle. No. 1061.
Mr. Panish. 1061, the Secretary of State of Delaware.
Ms. Bina. And I would just ask that before this be admitted or marked relevant we establish that it was the
same sort of thing that could have been found by Ms. Jorrie --
Mr. Panish. Actually, this is a certified copy from the state of Delaware, judicial notice on official copy of a
government document.
Ms. Bina. But then it would be irrelevant, your honor, unless it was something that was available online via
the Delaware Secretary of State.
Judge. Unless you can somehow show it was available online.
Mr. Panish. It was.
Ms. Bina. I have no objection to him showing the witness the document.
Mr. Panish. Michael Jackson's Company was a sole member llc., wasn't it?
A. I can tell you what was available online, sir.
Q. Online when you go --
A. Go ahead.
Q. -- when you go on the Delaware Secretary of State, it shows the name of the company, and it says
"Michael Jackson llc., sole member," doesn't it?
A. That, I don't recall from what I looked at. And I'd be happy to look at what it says on the actual website of
the Secretary of State to refresh my recollection of exactly what it says, we could go right to it right here and
see what it says.
Q. Okay. We'll get that up for you.
A. Okay.
Mr. Panish. All right. Let's look at -
Mr. Panish. Do you know what a sole member llc. Is?
A. A sole member llc.?

Mr. Putnam. Objection, your honor. I thought she wasn't allowed to give legal conclusions. If she is, we're
happy to have her do so.
Mr. Panish. She talked about what she searched.
Q. Was the Michael Jackson company a sole member llc.?
Ms. Bina. Objection, asked and answered.
Judge. Overruled.
A. I'd have to check. I'm not sure what it was at that time, either. I'd have to look.
Q. So you don't remember?
A. Mr. Panish, I don't remember exactly what the website said, but I do believe I have a copy of that page
somewhere.
Q. Okay. Can I see it?
A. Well, I didn't know you'd want it, but --
Q. But I asked you the other day whether you had copies of those documents, and you said no. Have you
gone back since then and looked on the website?
A. Your question --
Ms. Bina. Objection, misstates the testimony.
Judge. Sustained.
Mr. Panish. Did you have copies the other day when I asked you this question?
Ms. Bina. Objection, misstates the testimony that this question was asked the other day. He asked about
whether she had copies of the other searches.
Judge. Sustained.
Mr. Panish. Okay. What copies do you have, ma'am?
A. I believe I have a copy of what I saw for the Delaware Secretary of State about the Michael Jackson
Company llc. I would need to double check that, but I do --
Q. Did you print that out as part of your work for the client?
A. I'd have to look at what it is. I did not bring it. I didn't know you were going to ask these questions. I
didn't review it to refresh my recollection, Mr. Panish.
Q. That wasn't my question.
A. I know what it looks like.

Q. Did you bill the client for that work that you did?
A. I would have to check my bills. I don't know whether I identified -- I often don't identify every single little
task I do if it relates to a bigger project, like preparing an agreement.
Q. Okay. The question was --
Ms. Bina. I have --
Mr. Panish. -- did you bill the client for that work, yes or no?
A. I don't know. I'd have to look at the time and see whether or not I billed the client or not.
Q. So that was work that you did on behalf of your client that you're testifying here today when Ms. Bina
questioned you, right?
A. I really would have to see, Mr. Panish. I did look at the Delaware Secretary of State. It's not the pretty
little piece of paper that you were just, you know, showing, it's --
Mr. Panish. Your honor --
A. It looks very different.
Ms. Bina. I actually have it.
Mr. Panish. Can she please answer my question? Could I have it read back? Because you didn't have any
problem before. Now when I'm getting up, there seems to be an issue. Can I ask it to be please read back and
ask the witness to answer the question?
Judge. Let's hear the question first.
(the question was read.)
Ms. Bina. And, your honor, she answered, "I really have to see." it was the third time he asked her whether
she had done this, printed it out, billed for it. She's repeatedly said she doesn't recall, has to check her records.
I would object, asked and answered.
Mr. Panish. The question is this work that you've testified to about the Michael Jackson -- you did this on
behalf of your client, AEG, correct?
Judge. Sustained. She's said she --
Mr. Panish. She said she did it.
Judge. I believe she said she did it but she needs to look at the records as far as if she put it on the time sheets.
Mr. Panish. But all I'm trying to establish is she did this on behalf of the client. Since she's testified about it,
now I can ask about the communications with the client and what occurred and the correspondence and such, as
the court has already ruled. All I'm trying to establish is that she did it on behalf of the client. Now that I've
established that, I want to proceed further.

Ms. Bina. Your honor, I don't believe that this opens the doors that Mr. Panish thinks it does. He asked
whether she checked whether the company was in good standing, she said she did and couldn't remember
whether she printed it out or not. That did not reveal any attorney/client communications, anything other than
she checked the company to see if it was in good standing, as was her practice.
Judge. Sustained.
Mr. Panish. Exhibit 58, dash, 1, let's look -- that you just showed. You just showed it to her. Okay.
Q. This is what you received on June -- excuse me -- January 14th, 2009, correct?
A. Yes.
Q. Okay. Now, from that day forward, did you ever receive a single document in writing that said that this
had changed, that Michael Jackson was a member of the -- was the sole officer of the Michael Jackson
Company llc.?
A. Other than the document signed by Dr. Tohme representing he was an officer, sir, no.
Q. You never found any government document that said otherwise, did you?
A. That information would not have been available through an online search to me, sir.
Mr. Panish. Your honor, could I ask the witness -- first of all, that's not correct.
Mr. Putnam. That is correct.
Mr. Panish. It is not correct, number 1. And I'll bring a witness in on that. And I'll ask -- they keep arguing
with me.
Judge. Don't argue. If you have an objection, state the objection, but don't argue.
Mr. Panish. They keep doing that. I asked a simple question, "did you --" and I'd ask it to be read back again.
Mr. Putnam. Your honor, I apologize. He's making statements on the record as opposed to questions, and I
move to strike his comment as to what -- I move to strike his statement that that is not the case.
Judge. We'll strike the prior question, you can re-ask your question.
Mr. Panish. Did you receive any documents that you didn't prepare, or Mr. Trell, that said that this was no
longer true, that Michael Jackson Company llc. Was the sole officer and signatory was Michael Jackson?
A. I didn't --
Ms. Bina. Objection, asked and answered.
Judge. Overruled. And the answer is no.
Mr. Panish. Did you contact the Secretary of State of Delaware business office to see if Dr. Tohme was an
officer?
A. No.

Q. Did you contact the executor of the estate to be, Mr. John Branca, and ask him if Dr. Tohme was an officer
of the Michael Jackson Company llc.?
A. I did not.
Q. Okay. Have you ever seen any document that you or Mr. Trell did not prepare that says that Dr. Tohme is
an officer of the Michael Jackson company llc.?
A. I have not.
Q. Have you ever spoken to a single representative attorney of Mr. Jackson -- strike that. Have you ever
asked a single attorney that ever represented Michael Jackson if Dr. Tohme was ever an officer or signatory for
the Michael Jackson company llc.?
A. The issue did not come up, sir.
Q. So the answer is no, correct?
A. That's right.
Q. And Mr. Branca was at the same meeting that you were at where you told us that he had identified himself
to be appointed as the executor of Michael Jackson's estate, is that right?
A. He identified himself as being designated in the will as one of the co-executors of Michael Jackson's --
Q. And you were right there at that same meeting in the same room with him, correct?
A. I was, yes.
Q. And you never once thought to ask him if Dr. Tohme was an officer of the Michael Jackson company llc.,
correct?
A. You're right.
Q. And have you seen -- and you did -- you did tell us that you were involved in proceedings subsequent, and
I want to show you -- and while your counsel is looking at that, did you ever determine whether or not the
exhibit -- strike that. Mr. Tohme never said in front of Mr. Branca or any of Mr. Jackson's representatives at
that meeting that he was an officer of the Michael Jackson company, did he?
A. I don't recall that.
Q. And did you -- in fact, when you asked Mr. Tohme that and had him sign it, you were in a separate room
with Mr. Gongaware, correct?
A. Mr. Tohme didn't sign the document on that day when I was present. I said that earlier.
Q. When you gave him the document and asked him could he sign it, in the room was you, correct?
A. Yes.
Q. Mr. Tohme, correct?

A. Yes.
Q. Mr. Gongaware, correct?
A. Yes, but it -- it wasn't "will you sign this," it was "will you review this."
Q. Review and sign?
A. No. He was to review and take his time to review the budget, as well. We didn't ask him to sit there and
review the budget at that time.
Q. And no one else was in the room, were they?
A. Not that I recall, sir.
Q. And were you aware that that attached budget that he was approving called for him to be paid $200,000?
Ms. Bina. Objection, asked and answered, lacks foundation. We had a whole thing on this the other day,
your honor, she didn't review the budget --
Mr. Panish. It's in the budget, your honor, and I'm asking was she aware that this person she's believing, she
says, was supposed to get paid $200,000 from what he would -- if he signed.
Judge. Overruled.
A. I wasn't aware, sir.
Mr. Panish. You're aware of that now, aren't you?
A. Well, I'm trusting that you're relaying that information correctly.
Q. And were you aware --
A. And this was approval, not to get paid. There was nothing in there saying to get paid.
Q. Well, you've got to get approval before you get paid, right?
A. It's confirming -- to be even more precise, it's confirming that the Michael Jackson company had
previously approved these expenses.
Q. And have you seen any document that ever approved Dr. Tohme getting paid $200,000?
A. I don't recall, sir. I may have, I may not have. I just don't remember.
Q. Have you ever -- in that document that you gave Dr. Tohme, were you aware that it called for Dr. Murray
to be paid $450,000?
A. I was not aware of that, sir.
Mr. Panish. Now I want to show you -- what exhibit number is this?

Mr. Boyle. 1062.

Mr. Panish. You told me that you had -- strike that. I'm going to show you this document. May I approach
the witness?
Judge. You may.
Ms. Bina. I would object to the relevance of this document.
Judge. Let me see it.
Mr. Panish. Sure. Show it to her honor.
Ms. Bina. It's dated July 15, your honor, 2009.
Mr. Panish. That's right.
Ms. Bina. It says nothing about before that.
Mr. Panish. It was filed with the court, your honor.
Ms. Bina. It also says nothing about the officers, so I object on relevance.
Mr. Panish. It says it's a sole member llc.
Ms. Bina. Member has nothing to do with officers, your honor.
Mr. Panish. There are -- we'll get to that.
Judge. Overruled. You may ask about it.
Mr. Panish. Okay.
Q. Ms. Jorrie, when you went to court with Mr. Trell and you prepared for court, did you review this
document?
A. What court are you speaking about?
Q. This court right here.
A. Oh, no.
Q. Not in this -- not in this courtroom, this building where you and Mr. Trell were outside -- did you come to
court?
Ms. Bina. Objection, vague.
Judge. It is vague.
Mr. Panish. I don't want to show the picture, but did you and Mr. Trell go to court together after Michael
Jackson died unrelated to this case?

A. Yes. We had several hearings in front of Judge Beckloff as part of the probate proceedings.
Q. Right. And that was where Mr. Branca was made the co-executor of Michael Jackson's estate.
A. Yes.
Q. And have you ever to this day asked Mr. Branca if Dr. Tohme was ever at any time an officer of the
Michael Jackson company?
A. I never asked that question.
Mr. Panish. Now let's talk a little bit here -- your honor, I'm sorry, but I -- if everyone would bear with me, I
want to get finished. I don't know how we're doing here --
Judge. Well, because the witness has to leave at 12:00, we're hoping to go straight through. But if somebody
has to take a break to go to the bathroom, we could let you go to the jury room now, if somebody needs to do
that. You do. We're going to wait in here while you run to the jury room.
Mr. Panish. Can I go, too?
Judge. Yes. Whoever needs -- well, you can't go with the jurors.
Mr. Panish. No.
Judge. You can go to a different bathroom.
Mr. Panish. I'm going over to the executive one over here.
Judge. Anybody else who wants to use the restroom can use the one in the jury room. We're going to wait.
No pressure, but -- (six-minute recess taken.)
Mr. Panish. Ms. Jorrie, you told us that you saw on the medical licensing board that Dr. Murray was licensed
as a cardiologist. Is that what you told us?
A. It's cardiovascular something --
Q. Is there a license for cardiovascular surgery? Do you know that, if there is?
A. I don't remember the word "surgery," sir.
Q. Well, is there a license, to your understanding, for cardiovascular medicine?
A. I don't know the term "cardiovascular medicine."
Q. Tell us what you saw -- you told us that he was licensed in internal medicine, right?
A. Yes.
Q. And what else was he licensed in?
A. It said "cardiovascular" something. I don't remember exactly what.

Q. And is it your understanding that doctors get licensed in a specific area?

A. Well, it was suggested that that was a case when I looked at the website, there was two areas -- I'm not an
expert in that area. I don't --
Q. Well, you just told us that Dr. Murray was licensed in internal medicine, didn't you?
A. I told you what I saw, sir.
Q. Well, did you see on the website that his license and board in internal medicine had lapsed in 2008?
A. I wasn't -- no, I don't remember seeing that.
Q. Well, was he licensed in internal medicine, boarded, in 2008, or not?
A. Everything I saw on the website said he was licensed, it was valid, there was no disciplinary action. I can't
give you all the details, sir, because I don't remember them.
Q. What was he licensed in? You told us -- tell us again.
A. I remember that it varied by state, and I remember the word "cardiovascular," if I remember correctly, and
I remember at least one of the states mentioned internal medicine.
Q. So it's your testimony under oath that Dr. Murray was licensed in internal medicine and cardiovascular,
correct?
A. It's my testimony under oath as best I can recall of what I saw from four years ago, yes.
Q. Did you tell Dr. Murray that he should never be expected to be paid for any services he rendered for
Michael Jackson until after there was a signed contract?
A. I did not.
Q. Did you ever tell Dr. Murray that he shouldn't be expected to be paid for --
A. I'm sorry. I misunderstood. Expected to be paid by AEG?
Q. Yes.
A. I don't remember saying that. What I said was a little different.
Q. Did you ever tell Dr. Murray that he shouldn't expect to be paid for work by AEG that he did in May and
June?
A. I said he shouldn't expect to be paid until the contract is fully executed.
Q. Did you ever say -- that wasn't my question. Did you ever say that the work that he was doing in May and
June, that he shouldn't expect to be compensated for that?
A. I didn't say it that way, no, not that I recall.
Q. By AEG

A. Right.
Q. Okay. And the contract -- we won't go into it -- had a date of starting May 1, right?
A. As of May 1.
Q. Okay. And then you told us that you sent all drafts to Dr. Murray and to Mr. Trell and each of those
people were to sign or make any corrections that they wanted to make, right?
A. You'd have to look at them, each one, but I did send all drafts to them --
Q. And you --
A. -- for comments.
Q. And you didn't send any to anybody for Mr. Jackson, right?
A. I did not send any to anybody for Mr. Jackson, correct.
Q. And you have never in your career drafted a third-party medical agreement between a party, a patient and a
physician, correct?
A. That's right.
Q. And you didn't research any issues relating to third-party medical agreements, did you?
A. I did not.
Q. Okay. And you didn't research any of the ethical considerations or conflicts that a physician could have in
a third-party medical agreement, did you?
A. I'm not sure there are any. I didn't research it.
Q. Okay. Your honor -- you didn't research it, did you?
A. I did not.
Q. And you've never researched that in your entire career, have you?
A. I have not researched what you just said, correct.
Q. Okay. And you -- because you don't do that, you don't draft third-party contracts between physicians, a
patient and a company, do you?
A. I've testified already this was the one that I prepared.
Q. And those issues between the party, the patient and the physician are beyond your area that you do,
correct?
A. I -- to be honest, I wouldn't say that, sir.

Q. Okay. Well, let's talk about it, then. Do you want to talk about that? Tell me about -- have you ever
published an article about the potential conflicts of interest in a three-party medical agreement?
A. I have not.
Q. Have you ever read any law review or articles about third-party medical agreements?
A. No.
Q. You never drafted one, correct?
A. Other than this draft, you're right.
Q. You never reviewed one for a client and made comments on it, did you?
A. Correct.
Q. You've never been hired by a client to do any work in that area, correct?
A. Other than this occasion.
Q. Never had any training and experience in that area specifically, have you?
A. The area of medical --
Q. Medical --
A. -- contracts?
Q. Medical conflicts.
A. I haven't had training, yes.
Q. Did you review Dr. Matheson's testimony in this case?
A. I have not.
Ms. Bina. Objection. That would violate the court's order about witnesses reviewing testimony in the case.
Mr. Panish. Well, she didn't.
Judge. About whose --
Ms. Bina. There's an order that lay witnesses cannot view testimony before testifying, so it would have been a
violation of your honor's order for her to review Dr. Matheson's testimony.
Judge. That's true.
Mr. Panish. I understand that. You didn't review, that's --
Ms. Bina. It's kind of an unfair question.

Judge. She wasn't supposed to.

A. I didn't.
Mr. Panish. That's fine.
Q. Did you read any of Dr. Matheson's articles?
A. No, Mr. Panish, I didn't.
Q. Now let's talk about you -- you were talking about provisions in the contract about monitoring Dr. Murray.
You did put in the contract the services Dr. Murray was supposed to render, correct?
A. Yes.
Q. And you did put in the contract the level of service that was supposed to be provided, correct?
A. Yes.
Q. And you said it wasn't your place to monitor Dr. Murray, correct?
A. Correct.
Q. But you did put in the contract what services you expected under the contract that Dr. Murray would
perform, right?
A. That's right.
Q. But there was no provision in any way to see whether those services were properly performed, correct?
A. I don't understand the question.
Q. Do you have any provision in there where AEG can monitor the services of Dr. Murray to see whether
he's living up to his obligations under the contract?
A. The contract said the opposite, that was Dr. Murray's job.
Q. It did? It said in the contract Dr. Murray was to monitor his own services?
A. It says he's responsible and independent for his own services in paragraph 8.
Q. He's responsible and what?
A. He's an independent contractor, and -- but the whole provision deals with his independence and that he's to
be responsible for himself.
Q. Okay. First of all, AEG was having you draft this contract, correct?
A. Yes.
Q. And AEG was the person -- someone from AEG that contacted you, correct?

A. It was Mr. Woolley who was working with AEG Live.

Q. So is that a yes?
A. You're saying AEG contacted me. No. Mr. Woolley contacted me.
Q. On behalf of AEG?
A. Yes.
Q. Now, and on those two medical -- strike that. Those two addresses you saw when you looked up Dr.
Murray, you don't know if those were post office boxes, correct?
A. I've told you what I recall. I don't recall.
Q. Okay. You don't know if Dr. Murray had even paid any of his leases or was being sued for any lease that
he had, right?
A. I didn't see anything that suggested that in my Google search, Mr. Panish.
Q. Well, you didn't look for that, did you?
A. I wasn't on the look for that.
Q. So is that a no, you didn't look for it?
A. Well, I was looking, it just wasn't there. But you're right, I didn't go out of my way to look for lease
payments or defaults or delinquencies or credit problems.
Q. Foreclosures?
A. Foreclosures.
Q. Child support delinquency, pending proceedings, nothing like that, right?
A. You're right.
Q. Now, were you -- you talked about your conversations with Mr. Phillips -- I think it was just one
conversation, is that right?
A. It was part of the conversation about the matter that you brought the time record in. It was -- yes, it was
one conversation in the note.
Q. So is that a yes, one conversation?
A. It was part of one conversation.
Q. There's no conversation that you documented on the time record, is there?
A. On the time record that you brought in, it references conversation with Randy Phillips.
Q. I didn't bring it in, you brought it in. But let's put it up.

A. Okay.
Mr. Panish. And show us where it says that you're talking to Randy Phillips about Dr. Murray and success,
or anything like that. You can put it up. It's exhibit 1061.
Mr. Boyle. 1065.
Mr. Panish. Can you look on the back? I wrote on the exhibit number.
Judge. It's not 1061.
Mr. Panish. 1065. Thank you. Okay. So here we have a lot of issues that you do, a lot of work that day.
Q. Is that standard work, about five and a half hours for that client a day?
A. This is just work on the matter identified, Mr. Panish. And this was a big matter at the time, so no, it
wasn't standard every day. And this was only one of other matters.
Q. So some days you work more than 5.5 hours for AEG?
A. That's right, yes.
Q. I guess some days you might work less?
A. That's right.
Q. But you work a lot of hours for them?
A. Yes. Depending on the month, but yes. At this time, yes.
Q. You told us 5 to 600,000 a year in billings?
A. On average.
Q. On average?
A. Yes.
Q. Okay. And it says "telephone conference with Randy Phillips --" well, we've got to go back, I guess.
"review and revise employment agreement, revise purchase agreement, prepare e-mail to G. Stiffelman, prepare
e-mail to D. Pierfy, conversation with Stiffelman, live nation, prepare carve-out language." okay. That -- is
that with the Wright entertainment group matter?
A. Yes.
Q. Then it says -- this is all what you put here -- "telephone conference with R. Phillips regarding same."
that's referring to the lines I just read, right?
A. Correct.
Q. "prepare e-mail to R. Phillips regarding same"?

A. Right.
Q. "review various Stiffelman e-mails regarding matter, prepare e-mails regarding matter, attend conference
with Stiffelman, Young and Luderer regarding agreement, exchange e-mails with Stiffelman." that's your bill,
right?
A. Yes.
Q. Is there anywhere in there that says "conference with Randy Phillips re Conrad Murray"?
A. It does not say that.
Q. Did you say anything in the follow-up e-mail that you sent to Randy Phillips about Conrad Murray?
A. I did not.
Q. So there's no written documentation of that discussion with Mr. Phillips, correct?
A. On the 19th, about Dr. Conrad Murray, not that I'm aware of.
Q. Okay. Fair enough. Now, on the 19th or 20th, were you copied on any e-mails regarding trouble at the
front with the category -- excuse me -- were you copied on the 19th and 20th on any e-mails that were entitled
"trouble at the front" regarding Mr. Jackson's physical condition?
A. I was not.
Q. Mr. Phillips, during that conversation, did he mention to you that there had been an intervention on the
16th or 17th at Mr. Jackson's home?
A. He did not say that.
Q. Did he mention that he'd been in Mr. Jackson's home with Dr. Murray?
A. No.
Q. Did Mr. Phillips tell you that -- strike that. Mr. Gongaware, you said, was the one that told you that Dr.
Tohme was an officer of the Michael Jackson company, correct?
A. To my best recollection, yes.
Q. And -- and that's the only person other than Tohme that told you, right?
A. That's the only one I recall.
Q. And you relied on Mr. Gongaware to be telling you the truth, right?
A. Yes, which -- yes.
Q. And Mr. Gongaware, did he ever tell you -- strike that. Did Mr. Phillips or Mr. Gongaware ever tell you
that an e-mail had been sent to remind Dr. Murray that it's AEG that's paying him, not M.J.?

A. He did not --
Ms. Bina. Objection, misstates the e-mail.
Judge. Overruled.
A. He didn't tell me about that and he didn't provide that e-mail to me.
Mr. Panish. So you never knew that before Mr. Jackson died, is that right?
A. That's right.
Q. Now, the other day you were telling us about third-party vendor agreements. Do you remember that?
A. Third-party vendor agreements, independent contractor agreements, sell-off agreements, quid pro
agreements. I was lumping several into one place.
Q. Here's the question. Have you ever negotiated vendor agreements in connection with other artists or events
where you did not initially send the agreement to the artist? Do you remember that question?
A. Yes.
Q. Okay. And that was vendor agreements, correct?
A. Yes, but --
Q. Is that what you testified to, ma'am?
A. Yes, but could you tell me what you mean by "vendor agreements" -- I want to make sure my answer is
correct -- as opposed to what I meant?
Q. Did you know what Ms. Bina meant when you answered that?
A. I have my own interpretation of what a vendor agreement is.
Q. What's a vendor agreement?
A. It's an agreement with a third party to perform services of some kind.
Q. Okay. And is it fair to say that Dr. Murray was a third party?
A. He was a third party.
Q. And were you preparing an agreement for him to provide services?
A. I was, yes.
Q. Now, you told us a lot about the tour agreement this morning, and that tour agreement, all the drafts that
were being prepared when the attorneys were involved, they were all sent to the attorneys for Michael Jackson,
right?
A. Yes, the drafts were sent to Dennis Hawk and -- yes, and later to Peter Lopez, to Dr. Tohme.

Q. I'm talking about the attorneys.

A. Yes.
Q. Is Dr. Tohme an attorney?
A. No, not that I know.
Q. Did you check him out to see if he was?
A. I did not check him out to see if he was an attorney, Mr. Panish.
Q. Did you go on the medical licensing board when you did your check-out of him?
A. I did not.
Q. But you didn't know whether he really was a doctor, right?
A. I did not know if he was a doctor, you're right.
Q. And you didn't think he was the real McCoy, right?
A. Yes, I put that in an e-mail at that time, I had questions about that.
Q. Okay. And so then, on this touring agreement, you talked about representations about Mr. Jackson's
physical condition. Do you remember that?
A. I do.
Q. Were you told about whether Mr. Jackson had to undergo a physical exam before he began any work for
AEG Live?
A. The only physical exam I was told about was one that's required in order for the underwriters of the
insurance company to decide whether or not they're going to issue cancelation insurance.
Q. Okay. I'm going to ask you again. That doctor, did you know that AEG paid half for that doctor?
Ms. Bina. I'm going to object to the extent that calls for attorney/client privileged information, also misstates
facts because that was also being paid for by the Estate of Michael Jackson.
Mr. Boyle. Move to strike the testimony by Ms. Bina again.
Judge. I'm going to strike the whole thing. Stricken.
Mr. Panish. Did you learn that Michael Jackson had to see a Dr. Slavit?
A. I wasn't involved in that, sir.
Q. So you don't know anything about that?
A. Correct.

Q. And you don't know anything about the insurance and what was going on back and forth between AEG
and their insurance broker?
A. My role was discussions with Dr. Conrad Murray to -- that's it.
Q. So the answer to my question was you were not involved with the insurance broker and AEG trying to
secure insurance, is that correct?
A. That's correct, to the best of my recollection.
Q. So you don't have any information about that, correct?
A. Not that I can think of.
Q. Okay. That's all I'm asking.
A. Okay.
Q. And -- I'm getting there. You guys took all my notes. Oh. I don't want to have to go put it up, but you
talked about the medical equipment where it said "mutually approved." do you remember that in the agreement?
A. I remember -- yes, I do. I'm going to open it, though, just to --
Q. Sure, sure, you can. I don't want to waste time on that.
A. I understand.
Q. Just one question was did it require the medical equipment to be mutually approved -- did the terms say
mutually approved medical equipment?
A. It says the equipment will include a portable cardiopulmonary resuscitation unit, c.p.r. machine, saline,
catheters, needles, a gurney and other mutually approved medical equipment necessary for the services.
Q. Okay. So it had listed specific things, and then it said "other mutually approved", is that right?
A. It did say that, just what I read.
Q. And you put that in there, right?
A. I did.
Q. And did you talk to Dr. Murray about that?
A. I talked to him about the c.p.r. machine.
Q. About the mutually approved additional equipment?
A. I don't recall.
Q. Did you talk to anyone from AEG about that?

Ms. Bina. Objection, calls for attorney/client communications.

Judge. Overruled.
A. I don't think so, other than the list given to me by Mr. Woolley.
Mr. Panish. Do you know who at AEG was the one that would approve the additional equipment?
A. Approve the payment by AEG of -- of equipment that they approved paying?
Q. Well, no. It said "mutually approved equipment," right?
A. Nothing restricted other equipment, Mr. Panish, from being used.
Mr. Panish. Did I -- I didn't -- your honor, come on.
Judge. Answer the question that's being asked.
A. Yes. Thank you.
Mr. Panish. Did it say "mutually approved equipment"?
A. In that line, it does say that.
Q. And who was going to approve that equipment from AEG?
A. I don't know, sir.
Q. You mentioned a person, Howard Weitzman. Do you remember him?
A. Yes.
Q. And you said that you had a conversation with him, is that right?
A. That he may have been someone who told me -- yes, I remember that conversation.
Q. And that was about whether Mr. Tohme was an officer or not, right?
A. No, I think it was about whether or not he had been terminated.
Q. Okay. So you never discussed with Mr. Weitzman at any time whether or not Dr. Tohme, Mr. Tohme, was
ever an officer of the Michael Jackson company, is that correct?
A. Not to my recollection. That's correct to my recollection.
Q. And you do know Mr. Weitzman, right?
A. I do know him.
Q. And you've dealt with him on other matters?
A. No. The only matters are Michael Jackson related matters.

Q. Okay. And I think counsel asked you your understanding is he's the attorney for whom?
A. I think he represents the Estate of Michael Jackson, or the -- I mean, it might be listed as representative of
the co-executors, and then the co-trustees.
Q. My question is do you know who he represents?
A. Well, I just answered that question.
Q. You don't know? You gave like four possibilities.
A. He represents Mr. Branca, Mr. Mclean, in whatever capacity he was representing them at the time, and I
understand them to be the representatives of the estate.
Q. Now, have you spoken with Mr. Woolley since 2009?
A. About anything?
Q. Yes.
A. Yes, I have.
Q. And what have you -- don't tell me what you discussed. What matters have you dealt with Mr. Murray --
Mr. Woolley on?
Ms. Bina. And I'm going to object that calls for attorney/client -- potentially calls for attorney/client
privileged information. He should first establish whether he was a client at that time and whether it had
anything to do with Michael Jackson, because otherwise, it would be irrelevant.
Mr. Panish. I'm not getting into any substance, I don't want to know that, if he's a client. I'm just saying in
what context have you spoken to Mr. Woolley.
Ms. Bina. If it's some undisclosed client matter -- I don't know what -- what the answer is here, your honor.
Judge. Woolley sometimes -- the testimony has been that Woolley at one point was an officer of AEG .
Ms. Bina. Back in 2001, your honor. He's not an officer now. He sometimes works with them as an
independent contractor, so I don't know whether this would be privileged or not. I'm objecting out of an
abundance of caution because I have no idea what the answer is.
Judge. So why don't you exclude the 2001 time frame.
Mr. Panish. I'm only talking since 2009. That was my question.
Judge. I'm overruling the objection.
Mr. Panish. Since 2009.
A. I have talked to him in a couple of different contexts, and in none of those occasions was he representing
the interest of a client of mine, so it would not be privileged.

Q. And tell us generally -- not what you said or anything, just what subject matters have you dealt with him
on?
A. Well, on two occasions, I visited with him at the Rolling Stones concert at the staples center and then in
Hyde park -- he is the touring manager for the Rolling Stones, and I negotiated the contract -- and said hello to
him on both of those occasions. He also was involved personally in the negotiations of the Rolling Stones
contract where he would attend certain conference calls with the attorneys for the Rolling Stones and have
discussions with me as part of those negotiations. Nothing to do with this case.
Q. Did he give you free tickets?
A. Absolutely not. I paid for my own tickets and took my whole family.
Q. And so Mr. Woolley is someone that continues to work with AEG Live, correct?
A. I don't know. I don't know. In the context of that --
Q. The Rolling Stones concert was this year, wasn't it?
A. No, he didn't work for Rolling Stones at all. He represents the band. He represents the band and the
negotiations with me in my context represents AEG Live in negotiating the tour agreement with the band. So I
was on this side for AEG Live, and he was on this side with the attorneys for the Rolling Stones, and the
discussions all occurred about the negotiations of that tour agreement, which just occurred -- just occurred this
year.
Q. Anything else you want to say about that?
A. No. What do you want me to say about that, and I'd be happy to answer your question.
Q. It doesn't matter what I want you to -- you just say what you want to say, so --
Ms. Bina. Objection.
Mr. Putnam. Motion to strike.
Judge. Motion granted. Just ask the questions.
Mr. Panish. Did you think on June 28 that Mr. Branca, as the executor of the Michael Jackson estate, could
have found out whether Mr. Tohme was an officer of the Michael Jackson Company?
A. On that day, no, I don't think he could have found out.
Q. Did you know that Mr. Branca had been representing Mr. Jackson as of that time?
A. He had been representing him from just a short period before, and he had been on vacation in Los Cabos
during that week, and he, I think, returned on the 25th of June, or thereabouts.
Q. So it's your testimony, then, that you don't think on June 28th if you asked Mr. Branca, he could have told
you whether or not Tohme was an officer of the Michael Jackson company, is that correct?
Ms. Bina. Objection, calls for speculation, your honor.

Judge. Sustained.
Mr. Panish. Whether he could have found out, I think was the question.
Q. Is it your testimony that June 28, Mr. Branca, executor, could not have found out for you who the officers
of the Michael Jackson company were, if there was more than Michael Jackson?
Ms. Bina. Objection, vague. I don't understand that question.
Judge. It still calls for speculation. Sustained.
Mr. Panish. Well -- okay. We'll do it this way.
Q. Did you consider whether Mr. Branca could have looked in the records of Michael Jackson and determined
whether or not Mr. Tohme was an officer of the Michael Jackson company?
A. I didn't consider it, I didn't speak to him about it, I didn't ask him about it, sir.
Q. And is there anything that physically prevented you from doing that?
A. From asking Mr. Branca about that? No, I -- I could have asked him if I thought he would know the
answer.
Q. Instead you relied on Paul Gongaware and Mr. Tohme, correct?
A. I relied on Paul Gongaware and Dr. Tohme Tohme, yes.
Mr. Panish. That's all I have for right now.
Ms. Bina. Very briefly, your honor.
Further redirect examination by Ms. Bina.
Q. Ms. Jorrie, why didn't you ask John Branca whether or not Dr. Tohme was an officer?
A. Because John Branca had identified himself as designated as a co-executor of the estate. He -- from my
conversation with him, he had been in Los Cabos at the prior week, and that he was not in any position to know
whether or not Michael Jackson, as a member of this entity, appointed Dr. Tohme to be an officer, so Dr.
Tohme was in a better position to know whether that actually occurred or not. In addition, if I may, to answer
your question, is that type of information is not available when you go online with the secretary of state. You
cannot get that information online, you cannot get it instantly.
Q. So do you know how long John Branca had been Mr. Jackson's attorney at this point in time?
A. My understanding was about a week, and that he was either in Los Cabos, going to Los Cabos, something
to do with Los Cabos, and he told me that.
Q. And you'd actually spoken to him the prior week?

A. I had. I had spoken to him the prior week.

Q. Okay. Now that we've clarified all that, did whether Dr. Tohme was an officer of the Michael Jackson
company or not have anything to do at all with the draft agreement with Dr. Conrad Murray?
Mr. Panish. Your honor, I'm going to object to these comments by counsel. Every time I make a comment,
they say something. It's the same thing. Come on.
Judge. Overruled.
A. No, I don't think so.
Ms. Bina. And was Dr. Tohme signing this form the only thing that was discussed at the June 28 meeting?
A. No. We had the broad meeting with all the folks there, and we were focusing on -- an awful lot on the fact
that we were in the midst of a tour with a show, with expenses, with vendors, with a lot going on, people want
refunds, and we needed to take the right direction and inform people about what needed to be done to try to
reduce costs, mitigate expenses. There was just -- we were in the midst of a tour that was supposed to be
shipped to London. It was a lot.
Q. Just one of many things going on?
A. Absolutely.
Q. And, your honor, I think this next question has been opened up, but I wanted to flag it. If you think it's not,
let me know. Mr. Panish asked you some questions about conflict of interest and the Dr. Murray agreement.
Did you believe, in drafting the Dr. Murray agreement, that there was some kind of conflict of interest that you
needed to be aware of?
Mr. Panish. Objection, calls for expert testimony. I've already established she doesn't know -- your honor,
could I please just get it out before Mr. Putnam keeps interrupting me?
Judge. I didn't hear any interruption, but --
Mr. Panish. I must be sensitive.
Judge. Do you have an objection?
Mr. Panish. Yes, I do.
Judge. State it.
Mr. Panish. Calls for expert testimony, no foundation. I already established that she doesn't know anything
about that.
Judge. I expect her answer will be no.
Ms. Bina. He asked whether she considered it. I'm asking whether she thought there was one, and why not. I
think it's been opened by plaintiffs' questioning as to whether she believed there was a conflict or not.
Judge. But she has no foundation for it. She just said, "I don't know, I've never --"

Ms. Bina. Not as to medical conflicts, your honor. But she said she was able to testify to contractual
conflicts, and Mr. Panish quickly moved on.
Mr. Panish. That shows I didn't ask her. I asked her on medical, she didn't know anything about it.
Judge. True. Are you asking about medical?
Ms. Bina. I'm asking about contractual.
Mr. Panish. I didn't ask about that, and that would call for expert testimony.
Judge. Overruled. You may ask about contractual.
Ms. Bina. In drafting this contract, did you believe there was a contractual conflict of interest relating to Dr.
Murray?
A. I believe there was not a contractual conflict of interest.
Q. Why not?
A. Because the interest of Dr. Murray, Michael Jackson and AEG Live -- those interests were all aligned, and
the -- the interest was to make sure that Michael Jackson was receiving proper medical care in compliance with
the law that would keep him healthy so that he would be able to perform at the 02 arena in accordance with the
standards that -- that -- that he had agreed to perform, a first-class performance.
Mr. Panish. I'm going to move to strike that, your honor. It's way beyond anything that has to do with any
contractual medical licensing in accordance with the law, all of that. It's improper.
Judge. Motion denied.
Mr. Panish. Okay.
Ms. Bina. And, Ms. Jorrie, was it your understanding that Mr. Jackson had specifically requested that AEG
Live enter into an agreement of this kind with Dr. Murray?
A. Yes.
Ms. Bina. Nothing further.
Further recross-examination by Mr. Panish.
Q. Ms. Jorrie?
A. Yes, Mr. Panish?
Q. Do you know about conflicts of interest in medicine and finances of doctors?
A. Mr. Panish, I actually do think I know of conflicts that pertain to an agreement like the one I drafted. But
to answer your specific question on the non-contractual side, I've already said that I -- I don't.

Q. Okay. And you're not an expert -- strike that. Let's look at 372, dash, 37, that you have right in front of
you, Ms. Jorrie, regarding the Dr. Tohme agreement. Was there, to your knowledge, in there a specific
provision for Dr. Murray to get paid $450,000?
Ms. Bina. Objection, asked and answered a couple of times.
Mr. Panish. She just asked her about it.
Ms. Bina. He asked her about that about ten minutes ago, your honor, and she said she didn't know, she never
looked at the budget.
Judge. Overruled.
Mr. Panish. Let's look at it, page 37.
Q. This is what you gave Mr. Tohme to sign, right?
A. No.
Q. Okay.
A. To be clear, I gave the top sheet to Mr. Gongaware after revising it and he attached the budget and gave
that to Mr. Tohme.
Q. And that's Mr. Gongaware is the one that you relied upon to tell you that Mr. Tohme was a director of
Michael Jackson's company, correct?
Ms. Bina. Objection, misstates the testimony.
A. Officer.
Judge. Overruled.
Mr. Panish. Officer. Okay.
Q. And did Mr. Gongaware tell you that in the budget that he was submitting, it had medical management
services for Dr. Murray?
A. He did not tell me that.
Q. Did he tell you that there was in that budget that you asked Dr. Tohme to sign -- that there was $450,000 to
be paid for Dr. Murray?
A. He did not tell me.
Q. How long would it have taken you to ask -- strike that. Did you know that Mr. Branca had had prior
relationships legally with Mr. Jackson?
A. I've read about that.
Mr. Putnam. Asks for a legal conclusion, your honor.

Judge. Overruled.
A. I've read that ten years earlier, he was representing Michael Jackson.
Mr. Panish. And how long would it have taken you to ask Mr. Branca whether he knew or could find out if
Tohme was an officer of the Michael Jackson company?
A. How long would it take for me to ask that question?
Q. Right.
A. As long as you just said it, Mr. Panish.
Q. Not very long, right?
A. That's right.
Q. And is it your experience that an attorney for an individual would have access to their corporate records?
A. An attorney for an individual who's representing the individual in their corporate matters at the time,
sometimes yes, sometimes no.
Q. And as far as you were concerned when you told us about a contractual contract -- contractual conflict of
interest, you didn't believe the fact that Dr. Murray could be terminated at any time created any conflict of
interest for Dr. Murray, correct?
A. That's right.
Q. And you think you would know that better -- or strike that. Do you think you'd know that better than a
licensed physician who specializes in medical conflicts?
A. I -- if I can answer that -- the question with an explanation, sure, I don't -- I think that here, that nothing
stopped Michael Jackson from hiring Dr. Murray himself. The contract didn't prevent that.
Q. That wasn't my question. Exactly. AEG didn't have to have a contract with Dr. Murray, did they?
A. It was an accommodation, sir.
Q. AEG didn't have to have a contract with Michael Jackson, did they?
A. With Michael Jackson?
Q. With the doctor. Strike the question.
A. Of course --
Q. AEG didn't have to have a contract for Michael Jackson, the physician and them, did they?
A. Of course they didn't have to have a contract.
Q. There was nothing stopping you from drafting the contract and giving it to Michael Jackson, was there?

A. Nothing -- no, there's nothing that would have prohibited me from doing that, no.
Q. There's nothing that would have stopped AEG from giving Michael Jackson money to pay the physician
himself and not having a contract with AEG correct?
A. Correct. In fact, they had advanced money to him already.
Q. There was nothing preventing AEG from saying, "Mr. Jackson, we're not going to make the contract with
this doctor and we're not going to pay this doctor," was there?
A. Not that I know of, sir, no.
Mr. Panish. That's all.
Further redirect examination by Ms. Bina.
Q. Ms. Jorrie, was it your understanding that Mr. Jackson had specifically requested that AEG Live enter into
a contract with his doctor so that he could bring his doctor on tour?
A. Yes, and advance the funds necessary, that he would repay.
Ms. Bina. Nothing further.
Further recross-examination by Mr. Panish
Q. And AEG could have refused to do that, couldn't they?
A. Of course.
Mr. Panish. Thank you.
Judge. Okay. Thank you. 1:30.
Mr. Panish. Your honor, I thought you had a calendar.
Judge. Oh, yeah, that's right. Come back at 2:00 o'clock. Because I have motions that I'm hearing. So 2:00
o'clock instead of 1:30.
Mr. Putnam. Thank you, your honor.
(the noon recess was taken until 2:00 p.m. Of the same day.)