JACKSON V AEG LIVE July 19 th 2013
Kather#e Ja$.so#
(Michael Jackson's Beloved Mother, Jackson Family Matriarch, Plaintiff) Plaintiff' Witness.
%ll right. &kay. &kay. all them in. Ju!+e& Is there anything e need to talk a!o"t !efore e call the #"ry$ %ll he ury e#ters the $ourtroo4
ill yo" make yo"r Ju!+e& atherine Jackson vers"s %* +ive. *ood morning, every!ody. o"nsel, ill aearances$ Plaintiffs. %r( %r( Pa#sh& -es. *ood morning. Brian Panish for the Plaintiffs. %r( 5oyle& *ood morning. evin Boyle Bo yle for the Plaintiffs. %s( Cha#+& *ood morning. e!orah hang for the Plaintiffs. Plaintiffs. %s( Ste))#s& Jessica /te!!ins Bina for the efendants.
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%s( *o)#so#& *ood morning. +a"ra 0o!inson for the efendants. %r( Put#a& %nd Marvin P"tnam for the efendants. efendants.
-o" may !e seated. Plaintiffs, yo" can call yo"r ne2t itness. Ju!+e& 1hank yo". -o" atherine Jackson at this time. %r( %r( Pa#sh& -es. Plaintiffs call atherine Kather#e Ja$.so#6 $alle! as a /t#ess )y the Pla#t""s6 /as s/or# a#! test"e! as "ollo/s& he $ler.& Wo"ld yo" raise yo"r right hand$ o yo" solemnly state that the testimony yo"'re a!o"t to give in the ca"se no ending !efore this co"rt shall !e the tr"th, the hole tr"th, and nothing !"t the tr"th, so hel yo" *od$ he /t#ess& I do.
-o" may have a seat. %nd, ma'am, can yo" lease state and sell yo"r he $ler.& 1hank yo", ma'am. -o" first and last name for the record$ he /t#ess& My name is atherine sther Jackson. 3a3t3h3e3r3i3n3e, 3a3t3h3e3r3i3n3e, #3a3c3k3s3o3n. #3a3c3k3s3o3n. he $ler.& 1hank yo".
-o" may !egin. Ju!+e& 1hank yo", ma'am. -o"
-re$t e7a#ato# )y 5ra# Pa#sh&
4. -es. *ood morning, Mrs. Jackson. %. *ood morning. 4. First of all, hat is yo"r date of !irth$ %. I as !orn may 5th, 6789. 4. I kno this is not a great :"estion, !"t ho old old are yo"$ %. I'm ;8 years old. 4. Is this the first time time yo"'ve ever testified in a co"rt ith a #"ry like this$
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4. id yo" get a lot of slee slee last night$ night$ %.
%. *ood morning. %r( %r( Pa#sh& Better$ Ju!+e& -o" ant her to "se the the !ook$ %r( %r( Pa#sh& *ood idea.
4. &kay. &kay. We're We're #"st trying to ad#"st the microhone. +et's try that. *ood morning. %. *ood morning. 4. Pretend yo"'re singing in the choir. choir. 1ry to get it o"t a little little !it. I kno it's hard for yo". &kay$ %. &kay. 4. %ll right. Mrs. Jackson, I kno that yo" come from a famo"s m"sical family. family. %re yo" yo" a rivate
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%. -es, it is. 1he most diffic"lt thing is to sit here in this co"rt and listen to all the !ad things they say a!o"t my son. 4. %nd hy is that diffic"lt diffic"lt for yo"$ %. Pardon$ 4. Why is that that diffic"lt for yo"$ %. Well, a lot of the things that have !een said are not the tr"th. =e's not here to seak for himself. 4. /o are yo" here to seak for yo"r son, Michael$ %. I'll try my !est. 4. %nd hy is it that that yo"'re here to testify today$ %. Beca"se I ant to kno hat really really haened to my son, and that's hy I'm here. 4. %nd do yo" !elieve that yo"r son as a !ad erson, or some of the things that have !een said$ %nd the efendants have said, >It's "gly,> and they're >*oing to e2ose the "gly of yo"r family and yo"r son.> Mr. P"tnam said that at the !eginning of the case. o yo" !elieve that's the case$ honor. Misstates the testimony and my comments. %r( Put#a& &!#ection, yo"r honor. 4. Mr. P"tnam said said in his oening statement. id yo" sit here, hear his oening statement$ %. -es, I did. 4. id Mr. Mr. P"tnam take yo"r deosition for for many days$ %. -es, he did. 4. id he ask yo" many :"estions yo" yo" didn't like$ %. -es, he did. 4. %nd ho does it make yo" feel to hear that they're going to tell everyone that yo"r son is a !ad erson$ %. Makes me feel real !ad, !eca"se I kno my son as a very good erson. =e loved every!ody. every!ody. =e
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4. What as the the name of the ton$ %. Bar!o"r o"nty. o"nty. 1on$ 1on$ "fa"la as the name of the ton. 4. "fa"la, %la!ama$ %. -es. 4. +et me ask yo"? %nd hat as yo"r 33 ell, ell, ho ere yo"r arents$ %. My father as Prince /cr"se, /cr"se, and my mother as Martha Martha @sha. @sha. %r( %r( Pa#sh& I ant to sho e2hi!it e2hi!it 699A. %ll these have !een given to co"nsel.
4. %nd ho is in that ict"re, ma'am$ %. 1hat's my father. father. 1hat's my father father and Michael and myself. 4. %nd yo"r father's name as Prince /cr"se$
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4. Is Prince a family name name in yo"r family, family, Mrs. Jackson$ %. 1hat name goes all the ay !ack to slavery. slavery. =is father, his grandfather, grandfather, his great grandfather, grandfather, his great grandfather ere all named Prince. 4. Were yo" leased hen yo" learned that yo"r son as going to name 33 Michael as going to name his son Prince$ %. -es, I as. 4.
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4. What as yo"r father's name$ %. My father$ Prince. 4. I'm sorry. sorry. I asked yo" that already. already. I'm sorry. I'm nervo"s, too. &kay. &kay. %nd hat did yo"r father 33 hat as his m"sical talent$ %. =e layed g"itar. I layed the clarinet clarinet in the school !and. My sister layed the cello in the orchestra. Joseh's side as very talented, also. 4. Who is Joseh$ %. My h"s!and. 4. %nd yo"r h"s!and, hat a!o"t his family family side's talent$ %. 1hey ere very talented. =is !rother layed the g"itar. g"itar. &ne of them layed the sa2ohone. %nd e alays had m"sic aro"nd the ho"se, and I think that's hat enco"raged my children. 4. id yo" have any health iss"es, Mrs. Jackson, hen yo" ere groing groing "$ %. -es. I had olio as a child. It as 33 at that time it as called called infantile aralysis !eca"se most !a!ies got it at the time. B"t President 0oosevelt had it, also, and he started the March of imes. %nd that as !ack in the '59s hen I as in school. 4. %nd ho did that affect yo" hen yo" ere groing "$ %. @hm, I ore a !race from the age of A " "ntil 33 33 4. -o" ore !races$ !races $ %. J"st one !race on my left leg, and ore it " "ntil the age of 7.
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%r( Put#a&
4. Who is that$ (indicating) (indicating) there's a screen in front of yo".
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4. 1hat yo"r yo"r grad"ation ict"re$ %.
4. Mrs. Jackson, at some oint in time did yo" yo" get married$ %. I did. 4. %nd ho old ere yo"$ %. I as 67. 4. Who did yo" get married married to$ %. Joseh Jackson. 4. =o old as he$ %. 6. 4. %nd here did yo" yo" live hen yo" ere married$ %. I moved to to *ary, *ary, Indiana. 4. %nd is *ary, *ary, Indiana 33 is that close to ast hicago, Indiana$
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4. I'll #"st move it !ack a little. =oef"lly e can still hear yo". yo".
4. &kay. &kay. Is this the home yo" and yo"r h"s!and lived in$ (indicating)
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%. My oldest as my oldest oldest da"ghter, 0e!!ie. =er =er name as Ma"reen. Jackie as the the second. =is name is /igm"nd. 1ito, 1ariano 1ariano as his name. 1hen Jermaine, Marlon, Michael, 0andy and Janet. 4. /o Michael o"ld o"ld have !een yo"r Ath child$ %. -es. 4. %nd then yo" had three girls and si2 !oys$ %. -es. 4. Was that easy$ %. fo"r3room ho"se,> is this a fo"r3!edroom fo"r3!edroom ho"se$ %.
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so he as in a cri! in o"r room. 4. &kay. &kay. /o to, to and one$ %. 0ight. 4. %ll right.
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%. *osh, I kno ho to cook otatoes in every ay yo" can think of !eca"se he "sed to ick the otatoes, clean the field for otatoes and things hen he as laid off. J"st reg"lar food. food. 4.
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4. 1he mayor of *ary, *ary, Indiana, as in the ict"re$ Base!all Base!all ict"re$ %. -es. =e sonsored the team. 4. %nd hat as the name of the the team$ %. 1he name of the team as atC ittens, and his name as Mayor atC. 4. &kay. &kay. %ll right. right. %nd the one ith the !o tie there$ %. -es. 4. %nd ho is in that ict"re ict"re ith Mayor atC$ %. Jermaine is ne2t to Mayor Mayor atC, and 1ito 1ito is ne2t to Jermaine. Jermaine. 4. id yo" like to go to the the games$ %. We alays did, Marlon and Michael. %nd then the girls girls "sed to sit o"t and atch the !oys lay all the time. Michael en#oyed it !eca"se he o"ld save his little ennies and nickels, so hen they oened ", there as a refreshment stand, and he o"ld alays go there and send his money on that, on candy and cookies.
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from the other holidays. 4.
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standing there holding his hand, a !oy of three years old, and crying. 4. rying hen his !rother as sick$ %. rying hen his !rother as sick. 4. id there come a time hen yo" realiCed that yo"r Ath child had an interest in m"sic$ m"sic$ %. -es. =e as !orn that ay. ay. =e 33 hen all the kids as dancing aro"nd, he as in my arms, and he co"ldn't !e still. =e as dancing, too, to the m"sic. %nd hen he started to alk, he o"ld still dance. %nd there's a story a!o"t 33 I imagine I've told the story so many times. 4. /hare it ith "s.
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%nd at the time there ere t"!es in 1Gs, and yo" co"ld go to the dr"gstore and take yo"r old t"!e and get another and come !ack and "t it in. B"t then later on, the 1G o"ld !reak don, and then e had a 1G man. =e o"ld come and take it aay, and sometimes e didn't have the money to get it !ack. %nd that's hen the children first started singing. We o"ld sing together, sing old co"ntry songs, folk songs. 1hings like that. 4. id yo" like co"ntry m"sic$ %. I gre " on co"ntry m"sic. 4. Is that from %la!ama$ %. 1hat's hen 33 e lived in ast hicago, and my father o"ld listen to that, an old co"ntry 33 I mean, it as a co"ntry station coming o"t of hicago called the >s"ertime frolic.> and on the
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I and Michael's grandfather, Joseh's father, ent don to school. %nd he 33 and I as thinking, >=o is he going to go " there #"st at five and sing$> 4. =o old as he$ %. Five years old. %nd he sang >lim! very Mo"ntain.> and I as so nervo"s hen he alked alked o"t on the stage, !eca"se he as alays shy. %nd he started singing the song, and he sang it ith s"ch clarity and didn't miss 33 not flat or anything. Joe's father sat there and cried like a !a! y. +ooked aro"nd, and I as crying, too. =e got a standing ovation for his erformance. %nd he asn't nervo"s, and I as shocked. %nd I think he m"st feel more at home on stage. 4. =o did that that make yo" feel$ %. I felt 33 I as ro"d of him !eca"se I didn't think he co"ld do it.
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%. 1hat's Jermaine. 4. (indicating) %. 1hat's o"r dr"mmer, dr"mmer, Johnny Johnny Jackson.
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4. %nd ho did yo" get the money to !"y the instr"ments$ %. Well, e saved it. I "sed to alays arg"e and f"ss ith Joe a!o"t, >I need more rooms. I need more rooms.> and hen e o"ld save money, money, e'd !"y ! "y more instr"ments. We'd We'd !"y amlifiers and things like that.
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%. -es. 4. I g"ess that's hat they're called. %. 1hat's hat they're they're called.
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records. 4. <"m!er one records$ %. Fo"r n"m!er ones in in a ro. ro.
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4. %nd do yo" kno ho old he as there, Michael$ %. =e as a!o"t five. five. the v!eo $lp $o#t#ues to )e playe!4
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%. Moton . 4. %nd do yo" remem!er here this as$ as$ %. Pardon$
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%. Mr. Jackson as sick, sick, and he co"ldn't rehearse. 4. Well, for e2amle, yo" heard the testimony, testimony, did yo" not, ma'am, here it talks a!o"t the fact that he didn't like to rehearse for the dangero"s to"r$ %. -es. 4. %nd did yo" hear the testimony here he said he didn't like to rehearse for the history to"r$ %. laCy,> yo" don't remem!er hat that asD is that correct, ma'am$ testified to$ %r( %r( Pa#sh& &ther than hat she already testified %r( Put#a& @h3h"h -es, sir
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%. What's correct$ 4. 1hat hen yo" said that it's hard to sit here and listen to these !ad things, one mentioned the idea 33 the email here Mr. *ongaare said that he as laCy, and I'm asking yo" if yo" can remem!er hat other !ad, "ntr"e things yo"'ve heard in the last 6 eeks$ %. 1hey called him a freak. 4. %nd yo"'re talking a!o"t the email 33 %. 1hey ere making f"n of him. >Finally get a chance to meet the the freak.> 4. %nd are yo" yo" talking 33 %. %nd yo" kno 33 4. -o"'re talking a!o"t an email from someone ho isn't a arty to this las"itD correct, correct, ma'am$ 1hat as some!ody o"tside of the efendants in the las"it ho said that. o yo" remem!er that, ma'am$ %r( %r( Pa#sh& I'm going to o!#ect. It's It's not o"tside the defense. It's the general co"nsel layer. layer.
it's not general co"nsel. %r( Put#a&
4. o yo" recall that, Mrs. Jackson, that it as act"ally sent to some!ody at %* +ive, not sent from %* +ive$ -o" -o" remem!er that, ma'am$ %. I don't kno ho it as, !"t I'm #"st saying that it's hard to sit here and listen to it. 4. %nd I "nderstand that, ma'am. I do. I'm #"st trying to "nderstand. -o" -o" said it's hard to listen to the
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4. %nything else, ma'am$ %. My son is dead. =e's not here to talk for himself, so anything !ad that's said a!o"t him h"rts very m"ch. 4. B"t 33 %. %nd some eole love doing that to him. 4. oing that to yo"r son$ %. -es. 4. In fact, that as one of the hard things for yo", I'm s"re, the last fo"r years years of all the !ad things that ere said a!o"t yo"r sonD correct, ma'am$ %. -es. 4. %nd that's !eca"se eole didn't kno the Michael Michael Jackson yo" kneD correct, ma'am$ %. 1r"e. 4. 1hey only kne hat they sa e2ternallyD e2ternallyD they didn't kno hat he as act"ally like rivatelyD correct, ma'am$ %. -es. 4. In yo"r attorney's oening statements, statements, he said that yo"r son, son, Michael Jackson, as a dr"g addict. -o" remem!er hen he said that$ Misstates hat I said. %r( %r( Pa#sh& &!#ection. Misstates Ju!+e& &verr"led. 1he #"ry ill remem!er hatever yo" said.
4. 0emem!er that, ma'am$ %.
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%. -es, it o"ld !e hard to to listen to. 4. /o that as hard to listen listen to as ellD correct, ma'am$ %. I don't even remem!er him saying saying that, to tell yo" the the tr"th. 4. -o" don't, ma'am$ %.
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4. It o"ldn't !e helf"l$ %.
disc"ssions yo" had ith yo"r yo"r attorneys$ Ju!+e& Ma'am, o"ld it involve the disc"ssions he /t#ess& -es. %r( %r( Pa#sh& 1hat's an "nverified comlaint filed !y the layers. Ju!+e& %ll right.
4. id yo" have an "nderstanding that the time time came here yo" droed yo"r las"it against enny &rtega$ %r( %r( Pa#sh& /ame o!#ection.
Will yo" sti"late that that's hat haened$ Ju!+e& /"stained. Will It's in evidence. very!ody knos that. %r( %r( Pa#sh& We already !ro"ght that " already. It's Ju!+e& Is there a sti"lation sti"lation that enny &rtega as s"ed s"ed and droed from the las"it vol"ntarily$
%!sol"te ly. We ent thro"gh that ith Mr. &rtega. &rtega . %r( %r( Pa#sh& %!sol"tely. Ju!+e& %ll right.
4. id yo" have an "nderstanding hen the time came that yo" droed yo"r las"it against enny &rtega$ layers. %r( %r( Pa#sh& &ther than if yo" learned it from the layers.
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%r( Put#a& I accet the sti"lation. I ant to kno if she she kne that. %r( %r( Pa#sh& It's irrelevant.
tr"eD it's sti"lated. %nd it's Ju!+e& /"stained. 1he sti"lation acceted. 1he #"ry has to accet it. It's tr"eD also 6?99. /o 6?89. he ury e7ts the $ourtroo4 Ju!+e& &kay. &kay. 6?89. Lu#$h )rea.4 he "ollo/#+ pro$ee!#+s /ere hear! # ope# $ourt6 outs!e the prese#$e o" the ury4&
less than three ho"rs slee, she she as sleeing at l"nch, I think an ho"r or %r( %r( Pa#sh& Ms. Jackson got less so ill ro!a!ly !e her limit. Mr. P"tnam s"ggests ho"rs, so I don't think e'll finish today. today. I informed Mr. Mr. P"tnam of that. Ju!+e& &kay. &kay. We'll We'll do as m"ch as e can.
&kay. I #"st don't ant her to !e too tired. %r( %r( Pa#sh& &kay. he "ollo/#+ pro$ee!#+s /ere hel! # ope# $ourt6 # the prese#$e o" the urors4&
-o" may contin"e ith cross e2amination Ju!+e& atherine Jackson vers"s %* +ive. -o" honor. %r( Put#a& 1hank yo", yo"r honor. Co#t#ue! $ross e7a#ato# )y %arv# Put#a&
4. Mrs. Jackson, yo" remem!er earlier, earlier, !efore l"nch, I indicated if yo" had to sto at any time, e co"ld, right, ma'am$
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%. -es. 4. %nd this as in /etem!er of 969$ %. I don't remem!er, remem!er, !"t yo" remind remind me. 4. &kay. &kay. If I ere to reresent to yo" that it as /etem!er 6, 969, o"ld that so"nd right, ma'am$ %. /o"nds right. 4. %nd can yo" recall that this as !efore there had !een a criminal trial of r. r. onrad M"rray$ %.
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%r( %r( Pa#sh& B"t if she disc"ssed disc"ssed it ith her attorneys 33 Ju!+e& Well, hat yo" can do is erhas hrase it, >indeendent of any conversations yo"'ve had 33>
%!sol"tely, yo"r honor. honor. %r( Put#a& I'd !e hay to. %!sol"tely, Ju!+e& If there is no indeendent, then 33
4. /o, Mrs. Jackson 33 ell, let me ask it this ay? id id yo" consider anything in !ringing this las"it indeendent of yo"r disc"ssions ith yo"r attorneys$ %. -es. 4. -o" did. %nd did that incl"de the criminal trial of r. onrad M"rray$ %. %fter atching. 4. %fter atching$ %r( %r( Pa#sh& &!#ectionD the las"it as filed. =e said !efore the criminal trial, trial, so ho co"ld it have anything to do ith this$ %r( Put#a& 1hat's hy I'm asking. Ju!+e& &verr"led. he /t#ess& I don't "nderstand a lot of things yo"'re saying. I hear yo", !"t 33
little !it. &kay, &kay, ma'am$ %r( Put#a& +et me try to !reak it don for yo" a little 4. -o" filed yo"r las"it in /etem!er of 969, correct$ %. -es.
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co"ld something else !e a factor$ the fear is Ju!+e& If it's indeendent of the attorneyclient 33 yo" need to make it clear to her so she's 33 the that she's going to inadvertently disclose comm"nications ith her attorney, so 33 clear, Ms. Jackson. I don't ant to kno anything that yo" yo" disc"ssed %r( Put#a& +et me !e very clear, ith yo"r attorneys ever. ever. %ll right, ma'am$ Before the las"it or after the las"it. las"it. 1hat's not hat I'm asking for. What What I'm trying to determine, ma'am, is yo"r indee ndent considerations, hat yo" yo"rself tho"ght a!o"t o"tside of those conversations ith yo"r attorneys. 4. Was there anything that yo" considered e2cet hat as given to yo" !y yo"r attorneys in terms of !ringing this las"it$ %r( %r( Pa#sh& I'm going to o!#ect to >What as given to yo".> I mean, e #"st disc"ssed 33 there 33 I o!#ect to the :"estion, >given to.> Ju!+e& &verr"led.
conf"sed the ay he's asking the :"estions. he /t#ess& I'm getting conf"sed 4. Was there anything yo" tho"ght a!o"t other than yo"r disc"ssions ith yo"r attorneys hen yo" decided to !ring this las"it, ma'am$ %. 0eeat yo"rself. 4. &f co"rse. Was Was there anything other than yo"r disc"ssions ith yo"r attorneys that yo" considered in deciding to !ring this las"it in /etem!er of 969$ %. Before conrad M"rray's trial$ 4. It as, in fact, !efore !efore r. r. onrad M"rray's trial, trial, ma'am, yes. %. I don't remem!er. remem!er.
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%r( Put#a& riminal trial. %r( %r( Pa#sh& It's also irrelevant.
!elieve it's irrelevant, irrelevant, yo"r honor. honor. %r( Put#a& I don't !elieve %r( %r( Pa#sh& 0elevant for hat$
&kay. Why don't yo" #"st sti"late that that's the time time frame$ Ju!+e& &verr"led. &kay. %r( %r( Pa#sh& We already did. 1hey kno hen the case as filed. =e's already testified. %r( Put#a& Move to strike, strike, yo"r honor, honor, his comments.
Mr. P"tnam has already said the dates. We're We're not dis"ting the dates. %gain, there's no %r( %r( Pa#sh& Mr. iss"e a!o"t that. "nderstand her reasons s"ort !ringing !ringing the las"it, yo"r honor. honor. %r( Put#a& I'm trying to "nderstand %r( %r( Pa#sh& =er reasons for !ringing 33 %r( Put#a& I'm s"re yo"'d like to say hat they are. %nd hat I'm trying to determine is if there's anything indeendent of the conversation she had ith these attorneys that as relevant to !ringing this las"it. Ju!+e& Well, yo"'ve asked a co"le of times. I'll let yo" ask it one more time, !"t yo"'ve asked a co"le times already. B"t 33 %r( Put#a& %nd I haven't gotten an anser yet, I'm trying to fig"re o"t a ay to ask it 33 %r( %r( Pa#sh& /he has ansered the :"estion. Ju!+e& %sk it one more time. time.
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%. an yo" reeat yo"r 33 %r( %r( Pa#sh& -o" mean thro"gh her attorneys$
attorneys. %r( Put#a& -es, thro"gh her attorneys. clear. Beca"se she's not going to !e alking over to yo"r office and handing them to Ju!+e& Make it clear. yo", so make it clear that 33 4. Mrs. Jackson, did yo" rovide any doc"ments to yo"r attorneys so that they co"ld give them to "s in the three years !eteen the start of this las"it and o"r !eing at trial in this las"it$ %. My doc"ments$ Wo"ldn't that !e attorneyclient rivilege, hat she rovided to "s$ %r( %r( Pa#sh& Wait a min"te. Wo"ldn't Ju!+e& &verr"led. he /t#ess& -es.
4. -o" gave some doc"ments$ %. yes> for yo".
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%r( %r( Pa#sh& 1hat's okay. Ju!+e& Well, I #"st o"ld make a s"ggestion. J"st try to !e clear ith some of the :"estions :"estions !eca"se, o!vio"sly 33 !reak them don a little !it, esecially hen she's it's toard the end of the day, and she's getting tired. %r( %r( Pa#sh& It's very fast, the :"estions.
imroer to ask a itness hy she !ro"ght the las"it, %s( Ste))#s& -o"r honor, it's not "nfair or imroer and I think that's all that as trying to !e asked. We'll deal ith 33 %r( %r( Pa#sh& Why 33 hatever. We'll %s( Cha#+& We have the case la for it. it. %r( %r( Pa#sh& We'll deal ith it Monday. Monday. I don't need to resond.
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agreement that e laced on the record, and that time eriod hasn't e2ired yet. revie. 1he imression I got from her %s( Ste))#s& Monday as the day she as s"osed to revie. co"nsel as that she o"ld !e availa!le to testify ne2t eek. I'm not ositive, ositive, !"t e sho"ld confirm that, !eca"se if she is 33 and there are some iss"es ith her testimony that e may !e addressing, !"t 33 Ju!+e& Is she going to !e designated or aearing live$
so the co"rt knos, she has a very %s( Cha#+& We have to check ith her attorney, deending 33 #"st so serio"s l""s condition 33 this rivileged, rivacy for her$ %r( %r( Pa#sh& Is this %s( Cha#+& I g"ess I sho"ldn't state it, !"t I'll "t it in in a !rief "nder seal, !"t she has some severe health iss"es, and I have to address them ith her attorney. %s( Ste))#s& -o"r honor, I don't think there's any ay she co"ld aear !y designation. 1he hole "rose of her deosition, if yo"'ll recall, as she as not deosed d"ring discovery. discovery. /he testified she actively evaded discovery. /he then 33 Plaintiffs said they anted to add her to the list. %arently at the time they said they had !een comm"nicating ith her for a co"le of months. %s( Cha#+&
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testimony as in rearation for live testimony. /he stated several times on the record she intended to testify live. %t one oint, I as looking for something and Plaintiffs' co"nsel, d"ring a !reak 33 not Ms. hang, !"t her colleag"e 33 said, >hy are yo" even !othering asking her this$ -o" -o" can cover it all on cross e2amination hen she testifies.> !ring " for o!vio"s reasons, ! eca"se it as a deosition, I as trying to "nderstand hat her testimony as going to !e. It as not 33 to my "nderstanding 33 Ju!+e& It asn't trial reservation testimony. testimony.
2actl y, yo"r honor. %s( Ste))#s& 2actly %r( %r( Pa#sh& 1hat doesn't matter. matter. %r( Put#a& We ant to add her to o"r trial list,> and yo" said, >-o" >-o" only get to do that if defense gets to deose her !efore yo" do so.> to then "se that as a !ackdoor method to no have something to "t forard in this co"rt in terms of deosition testimony on video is a!sol"tely inaroriate.
thing$ I think this is is remat"re !eca"se I haven't talked to to her %s( Cha#+& an e #"st state one thing$ attorney yet, and I don't kno k no ho everything ent. /he is not a citiCen of the state of alifornia. /he lives o"tside the state, so there's ro!lem n"m!er 6. When that oman chooses 33 Ju!+e& +ike Mr. Mr. %nsch"tC.
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Ju!+e& I as s"rrised to see -o"ng -o"ng there !eca"se Plaintiffs have never mentioned -o"ng -o"ng !efore. %s( Ste))#s& We ere, too, yo"r honor. %nd e filed an o!#ection today !eca"se e !elieved that o"ld !e c"m"lative. B"t e don't ant to !egin o"r case itho"t knoing that they've finished theirs. Ju!+e& /ometimes yo" have to. %r( %r( Pa#sh& It haens like every trial. Ju!+e& 1hey're not alays that nice nice and neat and tied " in a !o. !o.
did start their their case. %r( %r( Pa#sh& %nd they already did %s( Ste))#s& B"t e'd like to have some idea, yo"r honor, is there one itness o"tstanding$ o"tstanding$ 1o$ 1o$ Fo"r$ Ju!+e& 1hat's fine. %r( %r( Pa#sh& 1hey already did start their case. 1he ay these things go, they had to call itnesses in o"r case, if e recall that. /o hen they say, >We >We don't ant to start o"r case,> they already started it a long time ago !y calling o"t of order to itnesses !eca"se of sched"ling. Ju!+e& -es. 1he oint !eing 33
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Plaintiffs' co"nsel that. to call her in in yo"r case$ Ju!+e& /o yo" ant to small ortion of her video deosition deosition to !olster their on =0 e2ert %s( Ste))#s& 1hey ant to "se a small o"t of conte2t. It's c"m"lative of testimony !y Mr. Mr. 1rell and Ms. /earight and a !it of detective martineC. 1here's no "rose to that. We've We've o!#ected to it as c"m"lative, c" m"lative, e've also rovided co"nter designations sho"ld the co"rt 33 Ju!+e& 1hat so"nds c"m"lativeD and if they're going to call her in in their case 33 %r( %r( Pa#sh& 1hey didn't say there ere. %r( 5oyle& We think their e2ert said some things that are helf"l to "s. If they're saying their e2ert is c"m"lative to o"rs, h y can they call her$ B"t I ill look at their o!#ections.
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did ask that. Ju!+e& I did %r( %r( Pa#sh& &kay. &kay. %nd Mr. Mr. P"tnam gave a resonse on the recordD and hat I o"ld like 33 !eca"se the to transcrits are different, I o"ld like to kno hat is the resonse. %s( Ste))#s& -o"r honor, e didn't ask for any modification of the ro"gh, so I o"ld ass"me ass"me the final transcrit is hat the co"rt reorter took don and hat as act"ally said. Ju!+e& What did the final say$
ersonally do not intend to call r. M"rray M"rray "nless it's re:"ested, yo"r %r( 5oyle& It says >e 33 I 33 I ersonally honor.> hat does that mean$ %r Pa#sh& B"t ho is going to re:"est it$
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no, might I intend. /he had to indicate %r( Put#a& Well, I s"sect she asn't saying a month from no, hat did I intend to do at the time. In my case, I do not intend to call 33 M"rray, there's a hole heck of a lot of other Ju!+e& Well, let's o"t it this ay. If yo" intend to call r. M"rray, things that need to !e done !efore that ill haenD a very lengthy hearing, his attorney has to !e resent, there has to !e all kinds of things that have to !e done !efore he co"ld testify. testify.
very, very lo. Ju!+e& %nd so the likelihood of that haening, very, %r( Put#a& Which is hy I said at the time, yo"r honor 33 as yo" recall, the conte2t in hich it arose as !eca"se, as yo" kno, for 6 eeks e have !een trying to get the ortion of r. onrad M"rray's
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%s( Ste))#s& If I "nderstand correctly ith regard to Ms. -o"ng, Plaintiffs are not going to call her no. If e do not call her in o"r case, they may raise the iss"e again, e'll still o!#ect to it as c"m"lative and raise it at that time.
rights, yes. %r( 5oyle& 0eserving all rights, Mr. &rtega %s( Caha#& Based on the reresentation that e're going to finish ith Ms. Jackson, and Mr. and Ms. 0aram!a ill !e dealt ith searately, e've !een rearing to arrange itnesses for ne2t eek. In the conte2t of that, e reared some deosition designations. %s yo"r honor may remem!er, hen e started the case, Plaintiffs' co"nsel designated 9 de ositions, and e had 5; ho"rs h o"rs to do co"nters, designations and o!#ections to those. 1hey all got lodged ith the co"rt, and then they ere "nhay ith the designation co"nted co" nted as 33 e had a difference of oinion. %nd on may 6st, yo"r honor said, >Well, >Well, hatever yo" ant to do ith the designations, Plaintiffs, in essence, I'll give yo" a eek to revise hatever yo" ant, and then e'll do that.> so !"t !efore that haened, e had essentially a
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send them on a rolling !asis. 1here's one more that e o"ld like to !e a!le to lay ne2t eek that e haven't sent over yet, e can do that today. B"t I think e #"st need some clarity o n the rocess to make s"re that the co"rt has eno"gh time, that e have eno"gh time, and that Plaintiffs have eno"gh time so that as e're sending them on a rolling !asis, e have some kind of o f ass"rance that e'll !e getting them !ack on a reg"lar !asis. Ju!+e& Mr. Boyle 33
fine ith. %r( 5oyle& Whatever the r"le as, e're fine %s( Caha#& 5; ho"rs. %r( %r( Pa#sh& It as five days, according to Ms. /trong. /trong. %s( Ste))#s& %t one oint, e had a to3art system. %fter there as some concern ith the initial
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the ones that e sent over this eek ere, altho"gh e gave them A ho"rs, and five days for anything that's not a riority, riority, and e ill send the m on a rolling !asis 33 Ju!+e& Is that acceta!le or not$ If not, hat's yo"r alternative$ alternative$
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%r( %r( Pa#sh& =o do yo" kno I'm I'm not doing doing that$ Ju!+e& Beca"se he's the one that's doing all the deos. %r( %r( Pa#sh& &kay, yo"r honor.
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Ju!+e& /o yo" may have to to call m"ltile m"ltile itnesses$ %r( Put#a& -es. 1he reason e're asking a!o"t the sched"le, making s"re the three and five and everything, is e're trying to make s"re e can do this as efficiently as ossi!le. %nd e're hoing to call many each day !eca"se e ant to get thro"gh this. 1hat's the resent intent, hich is also hy on
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Ju!+e& /o if I tell yo" yo" "t on a itness, yo" "t on a itness.
that, yo"r honor. honor. %r( Put#a& %nd I ill do that, yo" to talking hen Ju!+e& 1hey don't have to formally rest. /ame thing 33 ait a min"te. Why are yo"
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