Tohme Tohme

Presiding Judge Mark V. Holmes ***MISSED FIRST 30 MINUTES IF TESTIMONY**** Jackson’s estate Jackson’s estate is represented by Avram Salkin, Charles Paul Rettig, Steven Richard Toscher, R obert S. Horwitz, Edward M. Robbins Jr., Sharyn M. Fisk and Lacey E. Strachan of Hochman Sa lkin Rettig Toscher & Perez PC, Paul Gordon Hoffman, Jeryll S. Cohen and Loretta Siciliano of Hoffman Sabban & Watenmaker and Howard L. Weitzman of Kinsella Weitzman Iser Kump & Aldisert LLP. The IRS is represented by its attorneys Donna F. Herbert, Malone Camp, Sebastian Voth, Jordan Mus en and Laura Mullin. Voth is lawyer directing questions to Tohme Tohme. Toh me. For IRS Howard. Weitzman for John Branc. TT: ... Los Angeles... In five days I will see him ... And I was seeing him almost on a daily basis but at least once a week.. After ……….??????.after we had meeting to Help Michael Mr Voth ……..?????????? TT. According to Tom Barrack... Steve Motze from Haifa who was taking takin g care of Michael’s affairs Michael’s affairs at that time in ......and we had a meeting with regard to that issue how we can help Michael move out of his debts HW: Your honor if I might inquire through the court we have a time and date ... Idea ,,, you Mr Voth Sure. Great suggestion HW: Thank you Mr Voth: You are welcome Mr.Voth: What do you recall? recall? What year did this meeting take place that you you started having sub sequent meetings with Michel Jackson to try to help h elp him? TT: 2008 Voth: And approximately what month? TT: I don’t ... don’t ... I can’t really can’t really recall the exact date, day. April or May,... I can’t recall... can’t recall... Voth: So April or May of 2008? TT: 2008. Yes. I think. I am not sure

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Mr.Voth: OK. So you you are describing these meetings regarding figuring out how to help Michael Jackson out with with his bills. bills. What happened next? Did you you eventually? TT Oh, after that we decided to have a ... to have a meeting ... very rough meeting that took plac e also in Las Vegas with Tom Barrack and three four guys from Colony. We met at the Topeka B rothers? office in North Las Vegas or somewhere else. And Michael was there. I was there. Tom Barrack and a few other people, We were trying to see... we were trying to see how we can enga ge Michael in some performance or o r something to generate money for him. Voth: Did you become... were you his manager at this time? TT: At that time.... it was a... he asked me ... But there was nothing in writing at that time. Voth: OK. Who proposed that you should be his manager? TT: Michael himself. Voth: One word your honor. Your honor may I approach the court to have a ... JDG: You may IRS: Exhibit 672R ... Occupation Mr.Voth: May I ask ask the court to provide to ... witness duplicates ... to hand over.. Just please tak tak e a moment to review this document marked Exhibit 672 R. Please. Just briefly take a look and le t me know when you are done. HW: I need marked as one of three separate documents? Mark them as one of the three Voth: So we have three related agreements that are being marked as one Exhibit. HW: Yeah. But they are not... Mr.Voth: So we have three agreements....to Tohme ... May I answer Mr.Weitzman’s question Mr.Weitzman’s question y our honor? JDG: Sure. HW: Point of order... Because they are part of litigation that the estate has with Mr. Tohme. They are three separate documents from three separate purposes. And ... Voth: It is only for convenience your honor















Judge: you get to call whoever…. Voth: Yes HW. So it comes in as unrelated subject your honor **Estate female attorney laughs out loud*** JDG: Go ahead Mr.Voth ... Mr.Voth: Alright. So lets take a look at the first document that dates May 2nd , 2008. TT.Yes Voth:And it’s about it’s about 5 pages, including schedule A and schedule B. Do you recognize this docum ent? TT: Yes. Voth: What is it? TT: It’s the It’s the management agreement, and service agreement, and indemnity agreement. Mr.Voth: So I am only asking you about the first one , the first first 5 pages, pages, relating to the the agreemen t date of My 2, 2008. TT: OK HW: I am sorry the first 5 pages relates to Ma y 2nd and to July Jul y 2nd documents. I just want the re cord clear ...because you are referring to the first 5 pages. Voth: Actually... You are right ... so lets refer to the first two pages Jdg: Thank you Mr Voth Voth: so for verification we are referring to first few pages TT; Yes Mr.Voth: y?

OK. Do you recognize the first first few pages of this document marked with a date 6th Jul

TT: Yes. HW: And then your honor for the record there is a redaction on the bottom ... I’ve not I’ve not seen this d ocument before ...so I was going to ask the court to ask you JDG: Plaintiff..















JDG: ... Perfectly reasonable Mr Voth. Go ahead. ah ead. Voth: Alright lets go to page 2 of o f Exhibit of May 2nd , 2008 agreement. Is that your signature on page 2? TT: Yes. Voth: Alright. Lets move on to the Services Agreement. Do you recognize the document titled S ervice Agreement? TT: Yes. Voth: What is it? TT: It’s and It’s and agreement between me and Michael Jackson and ....Masood??... Voth: And if we go to page 3 of the Services Agreement, is that your signature on page 3 of Serv ices Agreement? TT: Yes. Voth: Now if you look at the Services Agreement and please go to Article 22.1, it mentions a 50% commission there. You see that? We are at first first page Services Agreement Article 2.1. TT: Yes. Voth: Did you come up with this 50% commission? TT: No. Peter :Lopez came up with that because Michael at that time he offered 50% and I refus ed. And then I said “Mr. Jackson. “Mr. Jackson. No. I cannot do that.” And that.” And then I checked with Peter. I told Pet er. And Peter said 50% is common. Voth: OK. So lets move on to the last document of Exhibit 672R marked for notation and titled “ Indemnity Agreement.” Do Agreement.” Do you recognize this document? TT: Yes. Voth: What is it? TT: It’s and It’s and Indemnity Agreement.















Voth: Is that your signature on the last page pa ge of the Indemnity Agreement? TT: Yes. Voth: So we’ve been we’ve been talking about these 3 different agreements, Did you draft these 3 agreement s? TT: No. The attorneys did. Voth: And by “the attorneys “the attorneys did” what did” what are you referring to? TT: Dennis Hawk, Peter Lopez and Tom McClain. Voth. Now respondent moves to to enter document marked marked with notation 672R into evidence... Judge. Submitted HW. We like to add we have no objection Voth.Alright. So we’ve talked we’ve talked ... we have to talk about how you became Michael Jackson’s mana Jackson’s mana ger. Did you have any prior experience representing artists? TT: No. Voth: Aright. Now you’ve formally you’ve formally started representing Michael Jackson. You.. we have here in Exhibit 672R in May of 2008. Can you walk us through as to what happened next? Your relati onship with Michael Jackson. HW/ Estate: Your honor I object... vague... I am just looking for the time JDG: ...time ...please do it... Voth: Sure. So we are in May of 2008. Do you recall what happened next with respect respect to your re presentation of Michael Jackson? TT: Well. I can’t remember can’t remember exactly what took place then. It’s been It’s been almost 10 years. But what ha ppened is we realized that he needs to clean house ... Voth: Stop right there. there. What do you mean by “clean house”? TT: Well he was ... His life was in in disarray, as far as I am concerned. And he was around, you k now, people that he shouldn’t be shouldn’t be around. And he was acting like he was ... with the wheel chair and mask ... with all these things . And I told him that this is not the way to keep living. And I tol















Voth: Ok. So you mentioned that there were certain people, if I understood you correctly, that sh ouldn’t be ouldn’t be around him. Explain that further. TT: Well, I think , you know, kn ow, there was some... a lot of people from the Nation of Islam at that ti me with him. And all this security and everything. ev erything. That I felt like he was kind of controlled or so mething. And that’s why that’s why I told him that he should move on and change the way he is living. Voth: And you mentioned a wheel chair and a mask. Can you further explain that part? TT: Well, when I first first met him I saw that he has a bandage around his ankle. And he said he’s h he’s h urt his leg or something. And maybe he was using it as an excuse to be in a wheel chair. I don’t k don’t k now what was it. Maybe he want ... You know... Michael was wounded from the ... what happen ed to him in Santa Barbara with regard to the child molestation. Maybe he wants people to feel s orry for him or something. I really don’t know. don’t know. But I told him this is not done... and everyone kn ows from the media that he is wearing a mask. And this and that. So I worked hard on him. And I convinced him to change his habits. Voth: What do you mean by “ to change his habits”? TT: Abandon the wheel chair, remove the mask, get back to living a normal life. And move out o f Las Vegas. And try to get back to work. Voth: Alright. Lets go back briefly briefly to 2008. Was Michael Jackson working working with any other attorn eys or advisers? TT: At that time the only other person I know that he was involved with is Peter Lopez. And they came to me at that time ... David Klaus Klaus ... David Dunn and McMillan. I forgot forgot his first first name. Voth: Ok. HW: Londell. TT: Londell McMillan Voth: Who was Peter Lopez? Lopez? TT: Peter Lopez he was an entertainment attorney. attorney. He worked with Michael as far far as I know for two years. And he was still hanging around Michael when I walked in and in the picture. And he wasn’t getting wasn’t getting paid at that time. Voth: And is he still with us? us?

















TT: Well, David Dunn he was a ... I think he was a ... That guy also he is an attorney. attorney. And he wa s working with Michael Jackson and David Klaus. And Michael wasn’t real wasn’t real involved in day to d ay ??? At the advice of Michael we asked him to audit Sony. Voth: Why was that? TT: Because Michael felt that Sony was cheating him. And they are not paying him. Voth: And what is your understanding as to the basis of that allegation? TT: I have no idea really. really. I didn’t know didn’t know and he didn’t tell didn’t tell me. But he said to t o me where is my mo ney? They stole my money. They are taking my money. I want my money. And I want to audit S ony. Voth: And did you take any steps to audit Sony? TT: Well. I told David Dunn. And I told him that Michael wants to audit Sony. And he started, I think, by approaching Sony and talking to Martin Bandier at that time. And immediately a lot of things came up. And the ...Bandier called it a witch hunt. And everybody started attacking me th en. Because they thought it’s my it’s my idea. It wasn’t my wasn’t my idea. It was Michael Jackson. Voth: And who is Martin Martin Bandier? TT: Martin Bandier is the the head of Sony/ ATV. He is in charge of the catalog. Voth: We are still in 2008 / 2009 did Michael Jackson have any plans to buy a house in Las Vegas? TT: Yes. Voth: Can you describe?

















Voth: How are are you familiar? TT: Because I used to work with Brunei about 25 years ago. And I was a consultant through his His Excellency, the Prime Minister and the Minister of Educ ation. And I used to go there almost every two months. Voth: Lets talk briefly about the “Two Seas “Two Seas Records” litigation. Records” litigation. Can you tell us about the lawsui t that took place with “Two Seas”? TT: What happened, as you know, after the ...the situation situation in that Santa Barbara ... the trial was over and he was acquitted, he decided to leave the United States. So through... He went and mov ed to Bahrain with the help of Jermaine. And he decided on Bahrain. And he was ... agreed... he had some agreement and contract with the son of the King ... to do a studio, to produce the music , to do all kind of entertainment venue and ...with Sheikh Abdullah . And at that time he decided that for sometimes ... and thing went sour with him and Sheikh Abdullah. And then he left and h e went to Ireland, before he came back to the United States. And when Sheikh Abdullah found o ut that he left he went crazy. Because when he left Bahrain Sheikh Abdullahwasn’t Abdullah wasn’t there. And t hen he demanded that he wants all the money he spent. He claimed he paid a lot of money for hi m, for the trial, for attorneys, and this and that. So we tried to speak to Sheikh Abdullah - me and Michael before he filed a lawsuit in London. But he would not take the call. So then he filed a la wsuit in the court in in London. And ... then we solved out of court court and cost about $5 Million dolla rs. Voth: Again when you say we solved it who are you referring to? TT: I am referring referring to... I spoke to his brother brother and I spoke to others that have influence with Shei kh Abdullah. And then his brother called to Bahrain and told him to drop the lawsuit. We don’t want to do it. And this is what happened. And the father was very upset about it. The King. Voth: And what were they alleging in the the lawsuit? TT: He is alleging that he spent a lot of money. And he promised promised him... And in the contract I me

















Voth: So we are are still in ... You’ll have You’ll have to help me here ... 2008 or 2009...? TT: 2008 Voth: Ok. I’d like I’d like to move on to the issues that took place with Julien’s Auctions. Julien’s Auctions. Do you remem ber when that took place? TT: What happened is when Colony Capitol bought the note, from Fortress, in the note it state th at everything in the Neverland belonged to the the holder of the note. And Michael can only take his laptop and that’s it. that’s it. He can’t touch can’t touch anything. And there is a document like that? So I had a big pr oblem with Colony in regard to this because they want to keep everything. So I went and I spoke to Tom Barrak. I told him this is not the way to do it. I came to you to help him. Not to hurt him l ike this. So then I spoke to Paul Fuhrman ? , the attorney who was handling the transaction for C olony and Michael. And I told him: “This is “This is not acceptable.” So acceptable.” So he wrote me back, sent me an e mail, and he explained under the terms that are. In any case, at the end, we decided that Colony will not touch any of his stuff. And we were forced to remove all this stuff from Neverland. Voth: Was there a planned auction? TT: Yes. After the fact. fact. So I went back to Michael and said: said: “Why don’t we don’t we do an auction for th e stuff that I don’t want?” So want?” So I called... I forgot who I called for moving,,, I don’t know don’t know how Juli en came in ... in the picture... But somebody gave me his number. And I called him. And I said: “ You know Michael Jackson wants to do some auction for some items from Neverland.” from Neverland.” So we l eft and we went to Neverland together together and we had to move all the rides rides ... We had to move ... Th ere is a lot of stuff there that wasn’t working wasn’t working and its old. It was a mess. It wasn’t kept wasn’t kept up, you kn ow... And a lot of stuff weren’t working. weren’t working. So at that time we decided he wants to pursue it ... the a uction. Michael with Julien. And after that some elements that didn’t like didn’t like me there, they started p osting his stuff on the internet. And telling me go get all the stuff on the internet.. And this and th at. So he did not care at time. But then he decided, he said because it wasn’t an wasn’t an auction Voth: Stop right there. there. By he you are are referring to Michael Jackson? TT: Michael Jackson. He didn’t wan didn’t wan any of his personal items to be auctioned. He just wanted s

















nd of mine in the Secret S ecret Service ... Williams. And I told him to check Alfad Hussein. So we got back from Scotland Yard, he did not me, and I got the report on him. He was a heroin dealer. So I told Michael. This guy around you. I don’t want don’t want to see yoy anymore. The only things that happ ened I did not get... around... Voth: Alright now. So lets move on to some of the steps that you tried to take to revitalize Mich ael Jackson’s career. Jackson’s career. Did you try to help motivate Michael Jackson to start working? TT: You see Michael was.... Even though before I came to the picture .... He was was in Las Vegas. He was at the hotel...the... Can’t remember Can’t remember the name of the hotel... he was practicing ... you kno w... keeping himself going ...singing and practicing dancing and everything. And then when we moved from downtown to Palomino he still still was working, he was doing things. And at that time when he was on Palomino he also was working inside his music. He wants to make a movie abou t King Tut. And he wants to play King Tut in the movie. And he had unbelievable stuff he was w orking on, He had so many things he showed me. Voth: Stop right there. What do you mean by unbelievable stuff? TT: Like presentation. Short videos. Prints about what he has in his mind the way he wants the m ovie to be done. Voth: So tell us about some of the different business projects that you started , if any, that you st arted working on. TT: Well, the first project that came in is that after he moved to Los Angeles, Peter P eter Lopez came t o me and he said that, you know, we were discussing with Michael at that time that he should go back to work. And he decided that he will go back to work. And on the cond ition that the concert will be... the first performance will be is in England. So Peter Lopez came to me and said, you k now Live Nation is very interested in having h aving a contact with Michael Jackson for a tour. So I told Michael. He said “go see “go see what they have to say.” So say.” So I decided to go. So I went with Peter to Live Nation. And we had a meeting. And it didn’t work didn’t work out because Michael was demanding some ad vance cash, demanding he wants a house, he wants this this and that. So we did not get get the deal ...So I came back

















Voth.. When in 2008? TT: ... the last quarter of 2008... Because he moved out of the Bel Bel Air Hotel because we rented a house for him. before Christmas .. And rented a house. Voth: We are talking about different things. Just so that we are on the same page. We are primary referring to the years 2008 and 2009 TT: No we are referring referring at this time to 2008 only. We are still in 2008 Voth: 2008. OK. TT: Right. So what happened is Randy Phillips came back from London. And I don’t know don’t know how long it was. So he came and we met at the Bel Air Hotel. And I said I’ll I’ll tell Michael. So I went where Michael was in the hotel. So I went and I told him I just met with Randy and we are going to have another meeting. So at that time Tom Barrack was trying to be involved with Michael an d see if he can have him perform in Las Vegas because at that time he owned the Las Vegas Hilt on. And I told Tom he is not going to perform at the Las Vegas Hilton. In any case, what happen ed is, I received a call from Tom Barrack and he said that: “ Why don’t you don’t you have the meeting wit h Randy Phillips and AEG in the Colony office.” I office.” I said to him: “No problem.” “No problem.” So So we met ... Q; Do you remember when this meeting took place? Approximately or what year? TT: 2008. Voth: 2008. TT: 2008, So I went to Colony office in Century City and we met with Randy, Paul Gongaware was also th ere from the AEG side. And then we met it was 4,5 gu ys from Colony President... And we had th e meeting there and then I told Randy what Michael’s wishes Michael’s wishes are if he wants to sign with them. He said: “We’ll make “We’ll make it happen.” happen.” But But he said Phil Anschutz doesn’t seem doesn’t seem eager to do it because



















y were very impressed by Michael. And Phil Anschutz said: “ Absolutely. We with this. “

move forward

Voth: When was this? When exactly was this meeting with Phil Anschutz? TT: 2008 Voth: And it was in LasVegas you say? TT: In Las Vegas. At the MGM Hotel Voth: And Michael Jackson was present at this meeting TT: Yes. Michael came in and he brought with him his son Blanket. And after they want to talk t o me in detail. So Michael left. Security took him back home. And I stayed until the meeting fini shed. And then I went back to Michael and told him what took place, And then AEG started to g et engaged. Voth: Ok. Before we move into the This Is It concert series tour I have some more questions for you. Putting aside the AEG concert series were there any other projects or deals that you were w orking on? TT: Yes there was the Nike Moonwalk shoe



















forward .... Michael. And after the attorney working on it Michael agreed and he signed the deal with Nederlander. Voth: You recall any other ... Any particular business deals that weren’t enforced? weren’t enforced? TT: There was the dance video video Voth: What do you you mean by dance video TT: Michael was complaining to me. He said to me. Everywhere I go go to with my kids to to buy ga mes every artist not even close to me have a game. And I want Sony to do a game for me. So I co ntacted Sony and I said: “Michael wants “Michael wants a game. You gotta do a game for him.” Voth: By game are you you referring to to a video game? TT: Video game. So they agreed and they sent a team team from ... Idon’t I don’t know know where they came fr om ... New York or somewhere East Coast. And they came and they asked to have a big TV to d o demonstration for Michael. At that time Michael was living at the Bel Air Hotel. So we arrange d some place for them there with a TV and everything, And they brought in some small video to show him how it is. And he loved it. And they decided to move forward forward on it. And they left left and he died. Voth: When did this discussion take place?



















Voth: Do you remember how many many times? TT: At least two or three times. We met at the Bel Air Hotel. Voth: And do you recall what was the purpose of those meetings? meetings? TT: well he showed Michael some of his ideas and some of the figures he wants to do. And he brought s ome little figures.... Voth: Wait. Stop right there. What do you mean by a little figure? TT: It’s like It’s like a figure. He wants to use. Like a Mickey Mouse ... But But it wasn’t Mickey wasn’t Mickey Mouse. Fi gure like a Mickey Mouse. Something S omething that he would use in the series. Voth: Do you recall what the figure looked like? TT: I can’t remember. can’t remember. It’s like It’s like a lot of ghosts. A lot l ot of this. A lot of that. Scary things thin gs Voth: And did Michael Jackson provide any input? input? And input? TT: Michael loved it. And he couldn’t wait for it to move

on

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Voth: Can you describe to us? TT: Yes. Also Peter Lopez he wants have Christian Audigier do a line for Michael Jackson. He was doing doin g at that time. He does Tee shirts, hats, etc, etc.. And so w hat happened is ... At that time he was doing some work with Madonna, I think. And Christian he really liked Michael a lot. And so... he wants to do a line with Michael. So I told Michael. Micha el. He sai d go look at it. So I went there with Peter Lopez to his warehouse. And I looked at his work and everything, and I asked him h im where they are selling it. It was at KMart and I don’t know don’t know what other place. So I went. I told Michael. And he felt like it’s it’s below below Mi chael to sell his product in these places. So Michael declined. He said I don’t want don’t want to do it. Voth: So there was no agreement signed? TT: No agreement signed. The we had a Louis Vuitton that time wants to make a watch for him a lso. But again... Voth: What happened there? TT: He died Voth: Was there an agreement signed with Louis Vuitton?



















Voth: And what was the phone call about? about? TT: Sorry. I missed. What were you saying? Voth: Talking about his 50th birthday birthday and phone call. TT: Yes. Phone call. I arranged the phone call. They want to talk to Michael. Voth: They ...being the people of Good Morning America? America? TT: Good morning America. Voth: OK TT: And at that time I remember they want him to endorse endorse Obama during the call to station. station. So he told me to tell them them not to ask him about Obama... And also there was the .. We were talking to Cirque du Soleil. Voth: And what do you recall recall about conversations...? conversations...? TT: We received a call from a gentleman... Wishna HW: Jack Wishna





















Voth: OK. What is your understanding of what was conveyed to Dennis Hawk? HW: Your Honor, I am sorry. Just so the record is really really clear. The testimony is going to be... M r. Tohme is going to testify what a lawyer told him.. some third person told a lawyer. Just want t o be sure ….. JDG: Overruled. Overruled. Voth: What was going going on with Cirque du Soleil? HW: What is being offered, offered, so the truth of the matter is certified certified ... Jdg. overruled





















Voth: What is it? TT: It’s an It’s an email that sent to me from Mr. Wishna. Voth: Did you have discussions about Cirque du Soleil with Jack Wishna before receiving this e mail? TT: Yes. Over the phone. Voth: Did you receive this email during the course of your representation representation of Michael Jackson? TT: Yes.





















Voth: And what was the outcome of the conversations you had with Jack Wishna regarding regarding plan s for Cirque du Soleil? TT: Well he was trying to meet with Michael. To talk to Michael and to me in regard to putting pu tting t he show. And he arranged a meeting with Cirque du Soleil personnel. Voth: So ...and... HW/ Estate: I'm sorry. Is Is the question for Mr. Mr. Tohme to repeat a conversation with Jack Wishna or is this dealing with him receiving ..? Voth: We are identifying identifying who Mr. Wishna is. JDG: Go ahead, Mr. Voth.





















Voth: Thank you, you, your honor... HW/Estate:... also calls for expert testimony... Judge: I THINK YOU NEED TO STOP DENYING MR JACKSON WAS WAS THE GREATEST ENTERTAINER ….. ….. HW: ...except I was involved ... so I have little more personal knowledge.. JDG: YOU ARE NOT A WITNESS... Go ahead Mr. Voth Voth: Have you worked overseas? overseas? Have you worked outside the United States? TT: Myself:





















HW/ Estate: im sorry Just for the record .... There is a Court ruling that people giving opinion on Mr. Jackson’s interna Jackson’s interna tional appeal because of a stream of revenue from his music sales when he wasn’t touring wasn’t touring ... Judge Why is this a big deal Mr. Weitzman.?.. we know Michael Jackson sold many records .... HW/ Estate: I cannot object to any an y of this ... I am just programmed into admissible evidence fro m the Court ... And I’ll just I’ll just let .. your honor draw ... JDG: Go ahead Mr. Voth Voth: What is your your personal knowledge of public perception of Michael Jackson?























TT: Well, he was still writing lyrics, lyrics, writing music and he had people coming to him to work wi th him. He was doing himself. And when he was in Las Vegas also he was. He told me that he ha d new songs.























TT: Sorry. Can you you repeat? Voth: Sure. You mentioned 2008. Can you give us an idea as to the different steps steps that were tak en to plan for the tour?























TT: No. But all I know is we sold 14,000 tickets per minute. Voth: Can you describe for us what what happened the day that Michael Jackson announced the conc ert series This It It to the media?























r. And I was with Frank DiLeo over there. Michael Jackson told him to give me a big hug. And h e said “give your “give your boss a big hug.” That’s what That’s what he told Frank DiLeo. Voth: Who is Frank DiLeo?























TT: Yes, the day he died. Voth: And Randy Phillips approached you? TT: And he told me you are the the only one who has authority. He said to me, “We need “We need you to sig



















































































































































































































































































































































































































































































TT. I don’t know don’t know that, we negotiated a deal, I don’t know what he what he is talking about we negotiated I told him all of what Michael want exactly and what Michaels wishes were and they agreed to it. HW. did Mr. Hawks speak to Mr. Phillip’s to Phillip’s to your knowledge? TT. I’m sure I’m sure he spoke but most of the time the work was done with the Kathie Jorrie and another attorney HW. Shawn Trell TT. Shawn Trell HW> And the lawyers dealt with the documentation and isn’t it accurate you and the lawyers and Mr. Phillips dealt with, err the wants and needs of o f AEG and Michael Jackson TT. I don’t understand Mr. Voth. Okay, your honor, there’s a there’s a small verification, as I understand that part of the dispute between the estate and Mr. Tohme is whether Mr. Tohme procured employment emplo yment on behalf of an artist without the appropriate license Judge. It’s okay It’s okay Mr. Voth Mr. Voth. I’m trying I’m trying to understand the relevance of this line of questioning HW. First of all, this has nothing to do with anything but what part Mr. Tohme did play and nob ody is a, is a debating part of his role in helping Michael Jackson was to negotiate the AEG tour, and as for what deal they had done in … Judge.Okay, that question is allowed, go ahead Mr Tohme TT. As I said, I was discussing with Randy Phillips is the advance, is the house in London where he was going to live in. All the transportation. What goes on at the concert house and the advances. What Michael personally wants, but the contract con tract itself was negotiated between the attorneys HW. I understand, erm, was it part of your responsibility to make it clear to randy Phillip’s, Phillip’s, on behalf of Michael Jackson what the financial demand of Michael was. What the ancillary demands was such the house and expenses and things like that, the Doctors was that part of your responsibility. To make sure AEG included that in their th eir agreement Mr. Voth. Objection. Compound your honor















TT. It was part of my responsibility as I told you. AEG not only, I told Tim Leiweke, i told Phil Anschutz that he wants advance money, he wants the house in Las Vegas he wants to buy a house in Los Angeles he needs a huge house with a statue and everything in London. And we talked about the transportation and we talked about private plane and etc. etc. etc. HW. And erm. didn’t you didn’t you or did you rather instruct the lawyers to make sure that those demands those needs would be included in the agreement TT. Everybody knew about it HW. And For the most part did the agreement include what you told AEG about what Michaels wants TT. I think there were…... were…... Some of it was in the agreement the house and, and then he demanded a movie HW. Well did you, there was film development ??? for ?? million dollars, right TT. I think so, I can’t remember can’t remember exactly what I HW. It was a deal to develop dev elop films in the future correct TT. Right HW, and then there was, ermm, (could we put exhibit 22J before the witness please mumbling with tech guy…….. just guy…….. just the front page.)) Do you recognize this document Mr. Tohme…… mumbles, this was the document between you and Michael Jackson and this was the production management agreement, for you with Mr. Jackson, erm in regards to the This Is It tour, correct? TT. Correct HW. And erm, and it specifies that you will be paid a $100,000 per month, and these are the terms, did AEG every pay you under the terms of this agreement TT. No HW. Did they ever tell you why? TT. They said to wait until they a, we start the tour, HW. And according to the back page, page 3 of the document. Is that your signature on the left?















TT. Yes HW. And Mr. Phillips signature, that’s Mr. Phillips signature TT. Yes HW. Could you go to the??? Deposition. *** LEFT COURT ROOM EARLY, IN TOO MUCH PAIN***

Tohme Tohme

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