This is the official testimony of Wade Robson in the 2005 Michael Jackson trial in Santa Maria, CA.  These are official court documents that were sent to me directly from Mr. Thomas Mesereau, the lead defense counsel for the case.

 

THE COURT:  The Court’s going to deny the

15   1118 motion.  The request to dismiss the charges is

16   denied.

17           I’m going to bring in the jury.  Are you

18   prepared to call your first witness?

19           MR. SANGER:  Yes, Your Honor.

20           THE COURT:  All right.

21           MR. MESEREAU:  Excuse me, Your Honor?

22   There’s a motion in limine that the prosecution made

23   about a couple witnesses we plan to call.

24           THE COURT:  They don’t seem to be the first

25   two.

26           MR. MESEREAU:  They’re not the first two.

27           THE COURT:  So I’ll put that off.

28           Get the jury in.

9089

1           MR. MESEREAU:  Okay.  Thank you.

2

3           (The following proceedings were held in

4   open court in the presence and hearing of the

5   jury:)

6

7           THE COURT:  Good afternoon.

8           THE JURY:  (In unison) Good afternoon.

9           THE COURT:  You may proceed.

10           THE CLERK:  Judge, we need to swear the

11   witness.

12           THE COURT:  All right.  Please raise your

13   right hand and face the clerk.

14

15                         WADE J. ROBSON

16           Having been sworn, testified as follows:

17

18           THE WITNESS:  I do.

19           THE CLERK:  Please be seated.  State and

20   spell your name for the record.

21           THE WITNESS:  My name is Wade J. Robson,

22   spelled W-a-d-e, initial J., R-o-b-s-o-n.

23           THE CLERK:  Thank you.

24           MR. MESEREAU:  May I proceed, Your Honor?

25           THE COURT:  You may.

26  //

27  //

28  //

9090

1                      DIRECT EXAMINATION

2   BY MR. MESEREAU:

3       Q.  Good afternoon, Mr. Robson.

4       A.  How you doing.

5       Q.  How old are you?

6       A.  I am 22.

7       Q.  And would you please give the — please just

8   summarize your employment history.

9       A.  My employment history.

10           I started dancing when I was two,

11   professionally when I was five.  In Australia

12   originally.  And moved to America when I was eight.

13   Became a professional dancer.  Started teaching

14   dance classes when I was 12.  I was in a rap duo

15   when I was 11 and 12.  Started choreographing for

16   different artists when I was 14, and now I’m

17   directing film.

18       Q.  And where do you live at the moment?

19       A.  I live in Tarzana, California.

20       Q.  Okay.  And you say you’re directing films?

21       A.  Yeah.

22       Q.  And can you summarize what you’re doing in

23   that regard?

24       A.  The main focus right now, I did a short film

25   that I wrote and produced and directed last year,

26   and that’s doing the whole film festival circuit

27   right now.  And I have a three-picture deal with

28   Disney as a film director, and we’re developing an

9091

1   original musical.

2       Q.  Do you know the fellow seated at counsel

3   table to my right?

4       A.  Yes.

5       Q.  And who is that?

6       A.  That’s Michael Jackson.

7       Q.  How do you know him?

8       A.  I met him first when I was five years old.

9   I think it was ’87.  And Michael was touring, he was

10   doing the “Bad” tour.  And I was imitating him as a

11   dancer at that point.  And he was holding these —

12   it was in connection with Target or something like

13   that, holding these dance, like, contests all around

14   wherever he traveled.  So I entered one of the dance

15   contests and ended up winning it, went on to the

16   finals and won that, and then the prize was to meet

17   Michael.

18           So I met him after one of his concerts in

19   Brisbane, Australia.  And it was just like in a

20   meet-and-greet sort of room.  And we met, and I was

21   in my whole, you know, “Bad” outfit and everything.

22   He was sort of laughing and tripping out on my

23   outfit and asked if I danced.  I said, “Yeah.”  And

24   he asked me to perform with him in the show the next

25   night.

26           So after — it was like the end of the

27   concert, I pulled up, performed in the show with

28   him.  The next — the next — I think within the

9092

1   next couple of days, my mother and I went to visit

2   him at his hotel room, and we stayed for a couple of

3   hours.  It was in Brisbane, Australia.  Just talking

4   about what I want to do.  And then that was kind of

5   it at first.

6           And then for the next two years, we didn’t

7   have any contact at all.  And I continued pursuing

8   my dance career in Australia.  And then the company

9   that I was with, the dance company, was traveling to

10   America to do a performance at Disneyland.

11           So we all went.  Came out, did that

12   performance.  As I said, we’d had no contact with

13   Michael or anything.  Somehow my mother got in

14   contact with Michael’s secretary at that time, who

15   was Norma Stokes.

16           MR. ZONEN:  Your Honor, I’m going to object

17   to the narrative form of the answer.

18           THE COURT:  Sustained.

19       Q.  BY MR. MESEREAU:  After your mother got in

20   contact with Norma Stakos, what happened next?

21       A.  She talked to Michael about — we wanted to

22   see if we could hook up with him again and meet him

23   again.  She talked to Michael.  Michael remembered

24   me from when I met him when I was five years old,

25   wanted to meet me again.

26           So I was out there with my mother, sister,

27   my father, and grandparents.  We all went to meet

28   him at Record One Recording Studios.  And this

9093

1   was — this was ’89.

2       Q.  Where is Record One Recording Studios?

3       A.  I don’t remember exactly.  It’s somewhere in

4   the valley, yeah.  In California.  Yeah.

5       Q.  And what happened next?

6       A.  We met up with him.  He was in between, you

7   know, working on music and that sort of thing.  He

8   was doing a photo shoot at the time at the studio.

9   We took some photos with him.  My family and I all

10   went into his — sort of like the green room, and

11   played him some videotapes of all the dancing stuff

12   that I’ve been doing over the last two years.  And,

13   you know, he was just really excited, checking out

14   everything I had done.  And then by the end of the

15   time, he invited my family and I up to the ranch

16   that weekend.

17       Q.  And did you begin a friendship with Mr.

18   Jackson?

19       A.  Yes.

20       Q.  Did you spend much time at Neverland?

21       A.  Yeah.  Spent a lot of time, yeah.

22       Q.  When do you think you first went to

23   Neverland?

24       A.  It was right after that visit.  I’m pretty

25   sure it was that night that we went, my whole family

26   went to the ranch.  And, you know, we stayed for, I

27   don’t know, about a week or something like that.

28       Q.  And approximately what year do you think you

9094

1   first went to Neverland, Mr. Robson?

2       A.  That was 1989.

3       Q.  Okay.  And who did you go to Neverland with

4   the first time?

5       A.  Went with my mother, my sister, my father,

6   and my grandfather, grandmother.

7       Q.  And how long did you stay during that first

8   visit?

9       A.  I think it was about a week.

10       Q.  And after you spent a week at Neverland,

11   what did you do?

12       A.  Went back to Australia.

13       Q.  Okay.  Did you see Mr. Jackson again?

14       A.  Yeah.  We would — I don’t remember exact

15   dates, but over the next two years, my mother and I

16   would come out, I don’t know, maybe twice a year,

17   something like that, and spend a couple of weeks

18   with Michael.

19       Q.  Would you spend the night at Neverland?

20       A.  Some of it was at Neverland.  Sometimes it

21   would be at the — he had an apartment in I think it

22   was Westwood at that point that we would stay at

23   sometimes, too.

24       Q.  That’s your mother and you would stay at the

25   apartment in Westwood?

26       A.  Yeah.  That first time, I think a couple

27   times, sometimes I would stay by myself.  Always —

28   I think — sometimes — most of the time my mother

9095

1   and I went to the ranch together.  I think once I

2   was there by myself without my mother.  There was

3   other people there.

4       Q.  And did you stay in contact Mr. Jackson

5   through those years?

6       A.  Yes.

7       Q.  And how would you communicate with Mr.

8   Jackson?

9       A.  When we weren’t there, you know, we’d talk

10   on the phone or we’d send faxes back and forth.

11       Q.  At some point did you move to the United

12   States permanently?

13       A.  Yeah.  We moved in September of 1991.  My

14   mother and sister and I.

15       Q.  Have you lived here ever since?

16       A.  Yes.

17       Q.  Have you lived in Los Angeles ever since?

18       A.  Yes.

19       Q.  Now, your mother’s name is?

20       A.  Joy Robson.

21       Q.  And how about your sister?

22       A.  Chantel Robson.

23       Q.  Okay.  How many times do you think you’ve

24   stayed at Neverland?

25       A.  Um, it’s got to be somewhere in the twenties

26   or something like that.  Mid-twenties.

27       Q.  And have you stayed there for varying

28   periods of time?

9096

1       A.  Yeah.  Most of the time it’s usually like a

2   weekend, you know.  Friday, Saturday, Sunday.

3       Q.  What’s the longest amount of time, do you

4   think, you’ve ever stayed at Neverland?

5       A.  You know, I would say a week to a week and a

6   half.

7       Q.  Do you consider Michael Jackson your friend?

8       A.  Yes.

9       Q.  Do you consider him a close friend?

10       A.  Yes.

11       Q.  You’re aware of the allegations in this

12   case, are you not?

13       A.  Yes.

14       Q.  And are you aware, as you sit here today,

15   that there’s been allegations that Mr. Jackson

16   molested you?

17       A.  Yes.

18       Q.  Mr. Robson, did Michael Jackson ever molest

19   you at any time?

20       A.  Absolutely not.

21       Q.  Mr. Robson, did Michael Jackson ever touch

22   you in a sexual way?

23       A.  Never, no.

24       Q.  Mr. Robson, has Mr. Jackson ever

25   inappropriately touched any part of your body at any

26   time?

27       A.  No.

28       Q.  When you first visited Neverland — and I

9097

1   think you said it was about a week you and your mom

2   stayed there?

3       A.  Yeah.

4       Q.  Where did you stay?

5       A.  I stayed in Michael’s room.

6       Q.  And could you please describe the room for

7   the jury?

8       A.  When you walk in, there’s — there’s a bed,

9   sort of like the main bed, diagonally to your left.

10   Wood floors.  There’s a second floor that you go

11   around to the right and up, which also has another

12   bed.  There’s a bathroom to the left.  There’s

13   bathrooms on both sides of the main bed on the first

14   floor.

15       Q.  And you stayed in Mr. Jackson’s room?

16       A.  Yes.

17       Q.  The first time you were there?

18       A.  Yes.

19       Q.  To your knowledge, has your mother ever

20   stayed in Mr. Jackson’s room?

21       A.  In the room?  No.

22       Q.  How about your sister?

23       A.  Yes.

24       Q.  And when do you recall your sister staying

25   in the room?

26       A.  On that first trip, the first time we went

27   to Neverland.

28       Q.  Okay.  What do you recall doing at Neverland

9098

1   during that first visit when you spent approximately

2   a week?

3       A.  Well, at that point he didn’t have many of

4   the rides.  We would watch movies in the theater.

5   You know, we’d play video games.  We’d drive around

6   on the golf carts, look at the animals.  Those sort

7   of things.

8       Q.  Has Mr. Jackson ever helped you with your

9   career?

10       A.  Yes.

11       Q.  What has he done?

12       A.  When I first moved out here, when I was

13   nine, he put me in a couple of his music videos.  I

14   was in the “Jam” music video, “Black or White” music

15   video, and “Heal the World.”  And that sort of

16   helped me get a dance agent, dance agency, and —

17   and, yeah.

18           And then the next thing, when I said I was

19   in a rap duo when I was 11 and 12, that was on

20   Michael Jackson’s label under Sony.

21       Q.  Do you recall the second time you ever

22   visited Neverland?

23       A.  No, I don’t.

24       Q.  Do you recall staying in Mr. Jackson’s room

25   on other occasions?

26       A.  Yes.

27       Q.  And typically when you’d stay in Mr.

28   Jackson’s room, what would you do?

9099

1       A.  What would we do as far as just —

2       Q.  Sure.  Anything.

3       A.  Yeah.  We’d watch — same thing.  We’d watch

4   movies, we’d play video games, you know, we’d have a

5   pillow fight every now and then.  We’d talk.  Hang

6   out.

7       Q.  How many times do you think you’ve stayed in

8   Mr. Jackson’s room at Neverland?

9       A.  Same amount of times as I’ve been there.

10   Well, no, that’s not true, I’m sorry.  I’ve been

11   there a bunch of times without Michael, just with

12   other friends and family traveling there.  But, I

13   don’t know, maybe 15 to 20.

14       Q.  And at no time has any sexual contact ever

15   occurred between you and Mr. Jackson, right?

16       A.  Never.

17       Q.  Have you ever taken a shower with Mr.

18   Jackson?

19       A.  No.

20       Q.  Have you ever gone swimming with Mr.

21   Jackson?

22       A.  Yes.

23       Q.  And please explain what you mean.

24       A.  One time with my sister and I, my sister and

25   I and Michael, we went in the Jacuzzi at Neverland

26   Ranch.

27       Q.  And do you know approximately when that was?

28       A.  I don’t.  I can’t say for sure.  I have a

9100

1   feeling that it was within that first trip in ’89

2   when I went there.

3       Q.  Do you recall what Mr. Jackson was wearing

4   in the Jacuzzi?

5       A.  From my recollection, he was wearing shorts.

6   You know, like swimming shorts.  And that was it.

7       Q.  Did anything inappropriate ever happen in

8   that Jacuzzi?

9       A.  No.

10       Q.  Has anything inappropriate ever happened in

11   any shower with you and Mr. Jackson?

12       A.  No.  Never been in a shower with him.

13       Q.  Did you get to know any of the employees at

14   Neverland when you were there?

15       A.  I wouldn’t say “get to know.”  You know, I

16   knew of them and we’d know each other’s names, but

17   it never went beyond that.

18       Q.  Do you recall someone named Blanca Francia?

19       A.  Yes, I remember her name.  And I remember

20   her presence.  I can’t place her.  I can’t remember

21   what she looks like or anything like that.

22       Q.  Do you know whether or not Blanca Francia

23   ever was in a room when you were with Mr. Jackson?

24       A.  Not that I can remember.

25       Q.  Okay.  Did you ever meet anyone named Ralph

26   Chacon?

27       A.  No.

28       Q.  How about Kassim Abdool?

9101

1       A.  No.

2       Q.  Do you recall anyone named Adrian McManus?

3       A.  No.

4       Q.  Did you have much interaction with the

5   security people when you were visiting and staying

6   at Neverland?

7       A.  No.  The only interaction would be is, I

8   don’t know, if — if they were trying — if we were

9   out, you know, watching a movie or something like

10   that, they’d come tell us that dinner was ready or

11   something like that.

12           In later years, when I would go there and

13   just visit with my family and that sort of thing,

14   sometimes we’d have water fights and get the

15   security involved.  But other than that, no.

16       Q.  Did you come across anyone named Mrs.

17   Chandler when you were at Neverland?

18       A.  Yes.

19       Q.  And when do you think this was?

20       A.  I think I was about 13.  But I can’t

21   pinpoint any more — anything more definitive than

22   that.  Around that time.

23       Q.  Do you recall ever seeing someone at

24   Neverland talking to Mrs. Chandler?

25       A.  Sorry?  Can you repeat that?

26       Q.  Did you ever see Mrs. Chandler talking to

27   anyone at Neverland?

28       A.  Yeah, I mean, maybe chefs or — you know, or

9102

1   maids or something like that.

2       Q.  What do you recall Mrs. Chandler doing at

3   Neverland?

4       A.  I think I mainly saw her if we’d sit down to

5   eat dinner or something like that.  That’s the only

6   time I saw her.

7       Q.  Did you ever see her ordering people around

8   at Neverland?

9       A.  Yeah, well —

10           MR. ZONEN:  I’m going to object as leading.

11           THE COURT:  Sustained.

12       Q.  BY MR. MESEREAU:  When you saw Mrs. Chandler

13   talking to these people at Neverland, what do you

14   recall her doing?

15           MR. ZONEN:  I’ll object as irrelevant and

16   vague.

17           MR. MESEREAU:  There’s been testimony by

18   her, Your Honor, about what she saw.

19           THE COURT:  I’ll allow the question.

20           You may answer.  Do you want it read back?

21           THE WITNESS:  Yes, please.

22           (Record read.)

23           THE WITNESS:  I remember her, you know,

24   ordering food, that sort of thing, from maids or

25   chefs, or whatever.

26           And, you know, the thing I sort of noticed

27   was she was always sort of — you know, she would

28   sort of act like the place was hers, you know.  Sort

9103

1   of order people around a bit.

2           And, you know, I guess I noticed it because

3   my mother, when we went there, she always made it

4   really clear that this was Michael Jackson’s house.

5   This was somebody’s house and —

6           MR. ZONEN:  I’m going to object as

7   nonresponsive to the question and narrative.

8           THE COURT:  All right.  The last sentence is

9   stricken.

10       Q.  BY MR. MESEREAU:  Mr. Robson, has anyone

11   told you what to say in this courtroom today?

12       A.  No.

13       Q.  Is everything you’ve said the complete and

14   honest truth?

15       A.  Yes.

16       Q.  Did Mr. Jackson ever do anything wrong with

17   you?

18       A.  No.

19           MR. MESEREAU:  No further questions.

20           THE COURT:  Cross-examine?

21

22                       CROSS-EXAMINATION

23  BY MR. ZONEN:

24       Q.  Mr. Robson, good afternoon.

25       A.  Good afternoon.

26       Q.  Have you been living in the United States

27   continuously since you were eight years old?

28       A.  Yes.

9104

1       Q.  Was Mr. Jackson instrumental in your being

2   able to move to the United States to pursue your

3   career?

4       A.  Yes.

5       Q.  Are you grateful for Mr. Jackson’s help and

6   assistance in the development of your career?

7       A.  Yes.

8       Q.  Did you go to high school or college at all?

9       A.  No.

10       Q.  Not either one?

11       A.  I didn’t go to a public high school.  I did

12   home studies.

13       Q.  You did home studies all through high

14   school?

15       A.  Yeah.

16       Q.  And no college at all?

17       A.  No.

18       Q.  So you began your dance career early on and

19   continued through to today; is that correct?

20       A.  Yes.

21       Q.  All right.  Now, the first time that you

22   slept with Mr. Jackson you were seven years old; is

23   that correct?

24       A.  I slept in the same bed with him.  But, yes,

25   I was seven.

26       Q.  Did you understand my question to mean

27   something other than that?

28       A.  Sounded like it.

9105

1       Q.  All right.  But you slept in the same bed

2   with him when you were seven years old; is that

3   correct?

4       A.  Yes.

5       Q.  Was anybody else in that bed with you?

6       A.  My sister, Chantel Robson.

7       Q.  She was ten years old; is that right?

8       A.  Yes.

9       Q.  Is it true that there was not another adult

10   anywhere in that room at the time you crawled into

11   bed with Mr. Jackson?

12       A.  True.

13       Q.  And in fact, you continued to sleep with Mr.

14   Jackson through the balance of that week during your

15   seventh year; is that right?

16       A.  Yes.

17       Q.  Was your sister there the entire time during

18   that week as well?

19       A.  Yes.

20       Q.  Was she in that bed with you as well?

21       A.  Yes.

22       Q.  Did she continue to share a bed with you and

23   Mr. Jackson thereafter, or did you sleep only with

24   Mr. Jackson thereafter?

25       A.  What do you mean by “thereafter”?

26       Q.  Well, on all the occasions that you returned

27   to visit Mr. Jackson’s ranch, did you stay in his

28   room, by yourself, with him?

9106

1       A.  Yes.  But my sister wasn’t in — wasn’t with

2   us at all in America.

3       Q.  All right.  So when you moved here — and

4   incidentally, your father was there during that

5   first week when you were seven years old; is that

6   right?

7       A.  Yes.

8       Q.  But your father did not return to visit

9   thereafter?

10       A.  No.

11       Q.  All right.  So you stayed in the United

12   States.  Your father stayed in Australia.

13       A.  Yes.

14       Q.  Did your mother stay in the United States?

15       A.  Yes.

16       Q.  For the balance of the next number of years,

17   your father was simply not in the picture while you

18   were in the United States; is that right?

19       A.  He wasn’t there with us, no.

20       Q.  And Mr. Jackson understood that as well, did

21   he not, that your father was not in the picture

22   while you were at Neverland?

23       A.  Well, he understood that he wasn’t there,

24   yes.

25       Q.  Okay.  And did you have any contact with

26   your father at all?

27       A.  Yes.  We talked on the phone.

28       Q.  By telephone?

9107

1       A.  Yeah.

2       Q.  Did you visit him?

3       A.  I’m sorry, are we talking about once I moved

4   to America?

5       Q.  Yes.

6       A.  Oh, yes, we would go back at least every two

7   years for Christmas.

8       Q.  Did he ever come to the United States to

9   visit you?

10       A.  Yes.

11       Q.  Did he have any other visits with you at

12   Neverland?

13       A.  No.

14       Q.  Did you talk with your mother, prior to that

15   first week that you slept with Mr. Jackson with your

16   sister, about the sleeping arrangements at all?

17       A.  Well, yeah, the first day that we got there,

18   to Neverland Ranch — you know, I think we got there

19   in about the afternoon.  We hung out a bit.

20           When it was time to go bed, I asked Michael

21   if I could stay with him in his room.  And then

22   Michael and I went to — mom was staying in a guest

23   room.  We went to her room and I asked her.  Michael

24   asked her if that was okay.  And she said yes.

25       Q.  All right.  Now, you asked Michael Jackson

26   if you could share his room with him.  Now, what

27   caused you to do that?  You were seven years old.

28   What caused you to ask him if you could stay with

9108

1   him in his room?

2       A.  Well, it’s the same way with any child.

3   When you — you know, when you have a best friend or

4   a new friend that you found, you always want to stay

5   in the same room with them.

6       Q.  He was in his mid 30s; is that right?

7       A.  Yes, I guess so.

8       Q.  Had you ever crawled into bed with a

9   30-year-old man prior to that day?

10       A.  My father.

11       Q.  Okay.

12       A.  But other than that, no.

13       Q.  Any person who you had just met?

14       A.  No.

15       Q.  All right.  And in fact, throughout your

16   entire adolescent years, you had never slept with

17   any other man other than Michael Jackson and your

18   father; is that correct?

19       A.  Never slept in a bed with any other man, no.

20       Q.  Now, you had a conversation with your mother

21   about where you would sleep that night, that first

22   time.  Again, you’re seven years old; is that right?

23       A.  Yeah.

24       Q.  Did your mother talk to you about perhaps

25   you should stay with her in the guest cottage?

26       A.  No.

27       Q.  Was she the one who suggested that your

28   sister should go with you and stay in that room with

9109

1   Mr. Jackson?

2       A.  I don’t remember that.  I remember Chantel,

3   my sister, wanted to as well.

4       Q.  Had your mother actually seen the room

5   that — or the rooms that constitute Mr. Jackson’s

6   bedroom suite?

7       A.  Yeah.  When we first got to the ranch, he

8   took us around, a tour around everywhere, in his

9   room.

10       Q.  So she understood at the time that the

11   bedroom suite was composed of a number of different

12   rooms with actually beds in at least two of them; is

13   that right?

14       A.  Yes.

15       Q.  And there were bathrooms on both levels; is

16   that right?

17       A.  I don’t think there’s a bathroom on the

18   second level.  There’s two on the first level.

19       Q.  Was your mother under the impression that

20   you would be sleeping in a different location from

21   Michael Jackson when you first went to his room at

22   age seven?

23       A.  Not that I know of.

24       Q.  All right.  Had you talked with her the next

25   day about where you actually slept that prior night?

26       A.  No, not that I remember.

27       Q.  At any time during that first week when you

28   were there at age seven, did you ever tell your

9110

1   mother that you actually shared the bed with Michael

2   Jackson?

3       A.  I’m sure.

4       Q.  You think you did?

5       A.  Yeah.

6       Q.  Do you remember your mother’s response to

7   hearing that?

8       A.  No.

9       Q.  Did your sister, in your presence, tell your

10   mother that she was also sleeping in the same bed

11   with Michael Jackson at age ten?

12       A.  I can’t say for sure.  I don’t remember,

13   but —

14       Q.  At any time during that first week that you

15   were there, did you have any conversation with your

16   mother wherein your mother expressed concern about

17   where you were sleeping?

18       A.  No.

19       Q.  Were you seeing your mother during the day?

20       A.  Yes.

21       Q.  All right.  After that first week, did you

22   go back to Australia?

23       A.  Yeah.

24       Q.  You were in Australia for what, about a

25   year?

26       A.  I think so.  I don’t remember.

27       Q.  And then you returned to the United States

28   for good at that point?

9111

1       A.  Well, we had a couple of visits back to

2   America before we returned in ’91 for good.

3       Q.  With what rate of frequency did you continue

4   to visit with Michael Jackson after returning at age

5   eight?

6       A.  I would say twice a year.

7       Q.  All right.  And during those periods of

8   time, you would stay for up to a week at a time, no?

9       A.  Yeah.

10       Q.  Were there times that you actually stayed at

11   Neverland for many weeks at a time?

12       A.  Not that I can remember.  Like I said, a

13   week to a week and a half.  Maybe it was two weeks,

14   but I don’t remember any more than that.

15       Q.  Were there periods of time when you were at

16   Neverland and working with Mr. Jackson on dance

17   routines?

18       A.  No.  I mean, we would mess around and dance

19   a little bit in the studio every now and then, yes.

20       Q.  Was there ever an occasion where you were on

21   the dance floor with Mr. Jackson and he was showing

22   you a routine and he grabbed your crotch in a manner

23   similar to how he would grab his own crotch while

24   doing those performances?

25       A.  No, that’s not true.

26       Q.  You have no recollection of that?

27       A.  No.

28       Q.  That didn’t happen?

9112

1       A.  No.

2       Q.  During the period of time from age eight on,

3   did you stay in Mr. Jackson’s room virtually the

4   entire time?

5       A.  I’m sorry?

6       Q.  The times that you would come and visit Mr.

7   Jackson from age eight on —

8       A.  Uh-huh.

9       Q.  — did you stay in Mr. Jackson’s room?

10       A.  Yes.

11       Q.  All right.  By age 11, you were asked to

12   give a deposition, were you not?

13       A.  Yes.

14       Q.  And you actually did give testimony under

15   oath in the presence of two prosecutors from Los

16   Angeles; is that right?

17       A.  Yes.

18       Q.  There was also an attorney present who

19   represented you; is that correct?

20       A.  Yes.

21       Q.  All right.  After that deposition, did you

22   continue to sleep in Mr. Jackson’s room?

23       A.  Yes.

24       Q.  Did you continue to sleep in Mr. Jackson’s

25   bed?

26       A.  Yes.

27       Q.  All right.  Now, during that period of time

28   from age eight until age 11, did you frequently

9113

1   visit Mr. Jackson?

2       A.  From — I’m sorry, from eight to 11?

3       Q.  Age eight to age 11, did you frequently

4   visit Mr. Jackson?

5       A.  Yeah.  Same amount of time.  Maybe twice a

6   year, or every couple of months, something like

7   that.

8       Q.  Is it safe to say that during each of those

9   visits, you stayed in Mr. Jackson’s room?

10       A.  Yes.

11       Q.  All right.  Were there ever occasions where

12   you went to visit Mr. Jackson when your mother

13   wasn’t there?

14       A.  Yes.  I think a couple of times he had an

15   apartment in Century City that my mother would drop

16   me off and I’d stay for, you know, a night or so by

17   myself with Michael there.

18       Q.  Was that a place called “The Hideout”?

19       A.  I remember a place called “The Hideout.”

20   I don’t remember if it was that place.

21       Q.  Were there more places where you visited and

22   stayed overnight in Century City?

23       A.  Yeah, there was a hotel that was — I mean,

24   I’m sorry, an apartment that was in Westwood and

25   then one that was in Century City.

26       Q.  Was there a place where Mr. Jackson was

27   living in, either Westwood or Century City, where

28   there was a hotel across the street?

9114

1       A.  Yes.

2       Q.  And would it be the case that periodically

3   you would visit him there, your mother would stay in

4   the hotel, but you would stay with him in his room?

5       A.  One time when we came over, we stayed — I

6   think it was the Westwood apartment, his Westwood

7   apartment.  There was a Holiday Inn that was across

8   and we stayed there most of the time.  And then

9   certain nights I would go over to Michael and stay

10   with him.

11       Q.  Mr. Robson, were there ever occasions where

12   you stayed with Michael Jackson where you didn’t

13   sleep with him in his bed?

14       A.  Yes.

15       Q.  How often did that happen?

16       A.  I don’t know.  Maybe three, four times.

17       Q.  Three or four times over years we’re talking

18   about; is that right?

19       A.  Yes.

20       Q.  So, for the most part, the overwhelming

21   majority of times you shared his bed with him?

22       A.  Yes.

23       Q.  Now, at any time did you start to develop

24   conversations with your mother about the propriety

25   of sleeping with this man who’s now well into his

26   30s?

27       A.  No.

28       Q.  Did you consider it unusual at all?

9115

1       A.  No.

2       Q.  Did your mother consider it unusual?

3       A.  No.

4       Q.  Did you ever talk to your father about it?

5       A.  Yeah.

6       Q.  You talked to your father about your

7   sleeping with Michael Jackson?

8       A.  No, I mean, you know, everybody knew, and

9   nobody ever said that it was — we never talked

10   about it being unusual or anything like that.

11       Q.  Did your mother ever ask you if anything

12   inappropriate happened in bed with him?

13       A.  No.

14       Q.  Did she simply assume nothing happened?

15       A.  Yes.

16       Q.  You’re telling us nothing happened; is that

17   right?

18       A.  Yes.

19       Q.  All right.  What you’re really telling us is

20   nothing happened while you were awake; isn’t that

21   true?

22       A.  I’m telling you that nothing ever happened.

23       Q.  Mr. Robson, when you were asleep, you

24   wouldn’t have known what had happened, particularly

25   at age seven, would you have?

26       A.  I would think something like that would wake

27   me up.

28       Q.  On those occasions that you were at

9116

1   Neverland, you used to play very actively, did you

2   not?

3       A.  Yes.

4       Q.  All right.  There was a lot to do at

5   Neverland; is that right?

6       A.  Yes.

7       Q.  And on some days you were actually working

8   out heavily with the defendant, engaged in dance

9   routines, weren’t you?

10       A.  Yeah.

11       Q.  And on other occasions you would be playing

12   very actively.  There’s just a host of things that a

13   seven-year-old can do and have fun with; is that

14   right?

15       A.  Yes.

16       Q.  And you can play — all manner of video

17   games that exist anywhere in the world can be found

18   at Neverland; is that right?

19       A.  Yeah.

20       Q.  And there’s video games, there’s movies,

21   there’s a zoo, there’s all kinds of parks, and the

22   trains.  You’re very active during the entire day;

23   is that right?

24       A.  Yes.

25       Q.  And at night you’d go back to his room and

26   you’d play more video games or you’d watch

27   television; is that right?

28       A.  Yes.

9117

1       Q.  And there’s movies of any kind that you can

2   see with Mr. Jackson?

3       A.  Yes.

4       Q.  Did your mother ever complain to you that

5   you were losing contact with her and that she was

6   losing her contact with you?  Did she ever say that?

7       A.  No.

8       Q.  In fact, she was very upset over the fact

9   that she was losing her ability to have access to

10   her son, wasn’t she?

11       A.  No.

12       Q.  Was there, in fact, a shower at Neverland in

13   the suite, the bedroom suite?

14       A.  Yes.

15       Q.  But you didn’t use it?

16       A.  I used it by myself.

17       Q.  Was he in the room while you were using it?

18       A.  In the bedroom, not in the shower room,

19   which had its own door.

20       Q.  You were seven years old when you started

21   using that shower; is that correct?

22       A.  Yes.

23       Q.  When did you stop sleeping with Mr. Jackson?

24       A.  I guess when I was about, I don’t know,

25   maybe 13, 14, something like that.

26       Q.  Why did you stop?

27       A.  I didn’t stop sleeping with him.  I just

28   haven’t spent the night with him, I mean, in his

9118

1   room or anything like that since then, I don’t

2   think.

3       Q.  You haven’t gone back to Neverland since you

4   were 13?

5       A.  I have.  Not with him.

6       Q.  Have you gone back to Neverland since you

7   were 13 and actually stayed overnight?

8       A.  Yes.

9       Q.  On how many occasions since you were 13?

10       A.  A lot.  Same thing.  20, 25.  Something like

11   that.

12       Q.  Did he take you to other locations such as

13   Las Vegas?

14       A.  Yes.

15       Q.  And while you were at Las Vegas, you went to

16   see Siegfried & Roy?

17       A.  Yes.

18       Q.  And being with Mr. Jackson back then was a

19   very exciting experience, wasn’t it?

20       A.  Yes.

21       Q.  He was able to go anywhere he wanted in Las

22   Vegas and take you with him?

23       A.  Yeah.

24       Q.  Did you start to dress like him?

25       A.  I always did before I met him.

26       Q.  All right.  And during the time that you

27   were with him, he enjoyed you wearing clothing

28   similar to what he wore; is that correct?

9119

1           MR. MESEREAU:  Objection; calls for

2   speculation.

3           THE COURT:  Sustained.

4       Q.  BY MR. ZONEN:  Did he ever tell you that he

5   wanted you to dress like him?

6       A.  No.

7       Q.  Did he ever give you hats similar to the

8   type of hats that he wears?

9       A.  Because I would ask for them.

10       Q.  And did you, in fact, wear those types of

11   hats when you were out with him?

12       A.  Yes.

13       Q.  And when you were in Las Vegas, did you wear

14   those hats as you wandered around Las Vegas with

15   him?

16       A.  Yes.

17       Q.  When you were in Las Vegas, where did you

18   stay?

19       A.  We stayed at The Mirage Hotel.

20       Q.  Who went to Las Vegas with you?

21       A.  My mother.

22       Q.  Just your mother?

23       A.  Yeah.

24       Q.  Was your sister with you at all?

25       A.  No.

26       Q.  Did your sister move to the United States

27   with you?

28       A.  Yes.

9120

1       Q.  But she didn’t go to Las Vegas with you?

2       A.  Well, we weren’t — we didn’t live in the

3   United States at that point.  We still lived in

4   Australia.  We were out on a visit.

5       Q.  When you were in the hotel in Las Vegas, it

6   is true that you stayed with Mr. Jackson in his bed?

7       A.  Yes.

8       Q.  And your mother stayed in a separate room;

9   is that right?

10       A.  Yes.

11       Q.  Now, were there other boys that you knew

12   about who were sleeping with Michael Jackson during

13   that time?

14       A.  No, not that I knew of.  I mean, the only

15   other time I was around other boys, other kids at

16   the ranch, I think once or twice, and, you know,

17   we’d all stay in the room and we’d kind of fall

18   asleep on couches, beds, cots, wherever they were.

19       Q.  Did you know Jordie Chandler?

20       A.  Yeah.

21       Q.  You just described — you just told the jury

22   that — that you knew Jordie Chandler’s mother; is

23   that right?

24       A.  Yes.

25       Q.  What’s her name?

26       A.  I know her — June.  June Chandler.

27       Q.  All right.  Describe her for us.  What does

28   she look like?

9121

1       A.  She has dark, almost black hair.  Sort of —

2   sort of brown eyes.  I think some — kind of like

3   a — a little bit of a darker complexion.

4       Q.  Slim woman?  Heavy woman?

5       A.  Slim woman.

6       Q.  Now, do you remember her son Jordie?

7       A.  Yes.

8       Q.  On how many occasions did you meet Jordie?

9       A.  Once.

10       Q.  Only one time?

11       A.  That’s all I can remember, yes.

12       Q.  And did you spend the night with Jordie?

13       A.  Yeah, we all stayed in Michael’s room.

14       Q.  You say “we all stayed.”  Were there other

15   people there besides Jordie?

16       A.  Yeah, Macaulay Culkin was there and his

17   brother Kieran Culkin.

18       Q.  Now, Macaulay Culkin has sisters, does he

19   not?

20       A.  I don’t know.

21       Q.  Were there any girls that were staying with

22   you that night?

23       A.  Not that I remember.

24       Q.  Were there ever any girls, other than your

25   sister, at age seven, who actually spent the night

26   in Mr. Jackson’s room with you during the years that

27   you knew him and spent the night in his room?

28       A.  Yes.

9122

1       Q.  Who?

2       A.  There was Brandy Jackson.

3       Q.  I’m sorry?

4       A.  Brandy Jackson, who is Michael’s niece.

5       Q.  And she spent the night on how many

6   occasions with you?

7       A.  Only one that I can remember.

8       Q.  One night?

9       A.  Yeah.

10       Q.  All right.  So we’re talking about a period

11   of about five years; is that right?

12       A.  Yeah.

13       Q.  In the five years, you can remember Brandy.

14   Who else do you recall?

15       A.  As far as females?

16       Q.  Yes.

17       A.  My sister.  Brandy.  That’s all I remember.

18       Q.  Now, your sister actually never went back

19   into that room and spent the night with you after

20   that first week when you were seven; is that

21   correct?

22       A.  Yeah, not that I can remember.

23       Q.  Is it an accurate statement to say that the

24   boys who stayed there for long periods of time

25   started getting pretty rowdy?

26       A.  Rowdy?

27       Q.  Yeah.

28       A.  What do you mean?

9123

1       Q.  Well, goof off, and simply kids who weren’t

2   under a lot of supervision?

3       A.  Oh, yeah.  I mean, you know, boys will be

4   boys.  We’d go around and have fun.

5       Q.  Loud and boisterous?

6       A.  Yes.

7       Q.  And on occasions break things?

8       A.  Accidentally, yeah.

9       Q.  And be somewhat disobedient?

10       A.  Some of them maybe.

11       Q.  Were there ever occasions where you and Mr.

12   Jackson were throwing stones at the lion in the zoo?

13       A.  Stones at the lion.  Yeah, I think so.

14       Q.  That did happen, didn’t it?

15       A.  Yeah.

16       Q.  Mr. Jackson was throwing stones at the lion

17   in your presence; is that right?

18       A.  Yes.

19       Q.  Was he encouraging you to do the same thing?

20       A.  Yeah.  Little pebbles, but, yeah.

21       Q.  They weren’t exactly pebbles.  They were

22   good-sized stones, weren’t they?

23       A.  No, I remember small stones.

24       Q.  It was designed to irritate the lion, wasn’t

25   it?

26       A.  Yeah, we were trying get him to make some

27   noise.

28       Q.  Because it was entertaining to Mr. Jackson

9124

1   and to you?

2       A.  Yeah.

3       Q.  How old were you at the time?

4       A.  I think I would have been seven or eight.

5       Q.  Were there any other kids around at that

6   time?

7       A.  No.  Maybe my sister.

8       Q.  Now, you said that you spent one night that

9   you can recall with Jordie Chandler.  Do you know

10   Brett Barnes?

11       A.  Yes.

12       Q.  Did you ever spend a night with Brett

13   Barnes?

14       A.  No.

15       Q.  Did you ever meet Brett Barnes?

16       A.  Yes.

17       Q.  How old were you when you met Brett Barnes?

18       A.  I think I would have been nine.  It was soon

19   after we moved to America.

20       Q.  On that occasion when you spent the night

21   with Jordie Chandler, Macaulay, and his brother, was

22   Brett Barnes there as well?

23       A.  No.

24       Q.  Do you know if Brett Barnes spent nights

25   with Michael Jackson?

26       A.  I don’t know.

27       Q.  Do you know if they ever shared a bed?

28       A.  I don’t know.

9125

1       Q.  Did Michael Jackson ever talk to you about

2   the propriety of sleeping with him?

3       A.  Could you rephrase that?

4       Q.  Did Michael Jackson ever have a conversation

5   with you wherein the subject of the conversation was

6   that it was okay for you to sleep with a

7   30-something-year-old man?

8       A.  Yeah.

9       Q.  He did?

10       A.  We would both talk about it.

11       Q.  Really.  From what age?  When did that first

12   conversation happen?

13       A.  I don’t remember.

14       Q.  Were you seven?

15       A.  I don’t remember.

16       Q.  Was it the first week that you were there?

17       A.  No.

18       Q.  Do you think it was soon after you moved to

19   the United States?

20       A.  I really don’t remember.

21       Q.  What was the nature of that conversation?

22       A.  I don’t remember an exact conversation.  I’m

23   sure it’s just something, you know, we talked about

24   at some point; that — you know, that it’s fine.

25       Q.  Did Mr. Jackson ever tell you that you were

26   family to him?

27       A.  Yes.

28       Q.  Did he tell you that often?

9126

1       A.  Yes.

2       Q.  Did he tell you that he would take care of

3   you?

4       A.  No.

5       Q.  Did he tell you he would protect you?

6       A.  Yes.

7       Q.  All right.  Did he ever tell your mother in

8   your presence that you were family?

9       A.  Yes.

10       Q.  And that your mother could trust him?

11       A.  Yes.

12       Q.  In fact, the word “trust” came up in many

13   conversations with Michael Jackson, did it not?

14       A.  Yeah, we’d talk about trust in, you know,

15   other people, and that sort of thing.

16       Q.  But he encouraged you particularly to trust

17   in him, did he not?

18       A.  No, there was no particular emphasis on it.

19       Q.  How much time did you spend with Macaulay

20   Culkin?

21       A.  Um, there was that — the trip that we spoke

22   of, that I think was a couple of days.  I think I

23   was with him one other time at the Century City

24   apartment, which was a night.  I think that was

25   about it.

26       Q.  Now, the trip you described, that trip was

27   where now?

28       A.  Which trip?

9127

1       Q.  Maybe I misheard you.  Did you say “the trip

2   I just spoke of”?

3       A.  Oh, the one I spoke of.  That was the one

4   where I said where Jordie Chandler was there at

5   Neverland.

6       Q.  That was Neverland?

7       A.  Yeah.

8       Q.  He was there and you were there for what

9   period of time together?  Just one night?

10       A.  No, it was a couple days.

11       Q.  Did it go over more than one night?

12       A.  Yes.

13       Q.  On both of those nights, did both of you

14   spend that time in Mr. Jackson’s room?

15       A.  Yes.

16       Q.  Now, did either one of you actually spend

17   the night in Mr. Jackson’s bed with Mr. Jackson?

18       A.  No.  I think — from I can remember — I can

19   only remember one night in particular, and I

20   remember myself and Kieran Culkin, I think, slept on

21   Michael’s bed, and Michael slept on a cot, or

22   something, on the side of us, and I don’t know,

23   Macaulay fell asleep on a couch or something.

24       Q.  I’m sorry.

25       A.  Go ahead, no.

26       Q.  The Century City apartment, I believe you

27   said you spent some time there with Macaulay Culkin

28   as well?

9128

1       A.  Yeah.  I think it was one night there, yeah.

2       Q.  Was his brother there?

3       A.  I don’t remember for sure.  I don’t remember

4   him being there.

5       Q.  Mr. Jackson would periodically kiss you,

6   would he not?

7       A.  No.

8       Q.  Periodically hug you?

9       A.  Yes.

10       Q.  Touch you?

11       A.  Hug me.  That would be —

12       Q.  Put his hands through your hair?

13       A.  No.

14       Q.  Touch you about the head and the face?

15       A.  Yeah.

16       Q.  Did he ever kiss you on the cheek?

17       A.  Yeah.

18       Q.  Did he ever kiss you on the lips?

19       A.  No.

20       Q.  Do you remember any other children being

21   there about that time?

22       A.  Which time?

23       Q.  From the time that you were seven until the

24   time you stopped sleeping there at age 13.

25       A.  Being at the ranch?

26       Q.  Yes.

27       A.  Other than we spoke of, no.

28       Q.  Did you know Blanca Francia’s son?

9129

1       A.  No.  I knew of him.  But I don’t think I

2   ever met him.

3       Q.  What was his name?

4       A.  I don’t know.

5       Q.  Does “Jason” sound familiar?

6       A.  Yes, but I think because I’ve heard it

7   recently.  But, yeah.

8       Q.  Now, were there ever occasions after you

9   were 14 years old that you came and stayed at

10   Neverland Ranch and Michael Jackson was, in fact,

11   there?

12       A.  Yes.

13       Q.  And you did not stay with him in his room?

14       A.  The only time I can remember was a time I

15   went up there with a few family members and friends,

16   and we didn’t know he was going to be there.  And,

17   you know, we sort of ran into him and hung out a

18   bit, and, no, I didn’t sleep in his room.

19       Q.  Did you ever talk to Michael Jackson about

20   the fact that at some age it was too late for you to

21   be sleeping with him?

22       A.  No.

23       Q.  Did you ever have a conversation with him

24   about whether or not you should continue to sleep in

25   his bed?

26       A.  No.

27       Q.  Remember the last time you slept in his bed?

28       A.  The last — I think it might have been when

9130

1   I was about 14.  It was at a Sheraton Hotel in Los

2   Angeles.

3       Q.  And how did you happen to be there with him?

4       A.  I stayed with him for I think it was just

5   one night.

6       Q.  Did you call or did he call you?

7       A.  I don’t remember.

8       Q.  Was your mother there?

9       A.  No.

10       Q.  Do you remember how you got there?

11       A.  No, I don’t.

12       Q.  Were there occasions that Mr. Jackson would

13   summon you to Neverland Ranch?

14       A.  Summon me?

15       Q.  Yes.  Call you up and ask you to come and be

16   there; invite you to Neverland Ranch?

17       A.  Invite us, yeah.

18       Q.  All right.  Without your mother?

19       A.  Like ask if I could come without my mother,

20   do you mean?

21       Q.  Or just ask you to come, and you came by

22   yourself.

23       A.  The only time I remember being there —

24   sorry.  The only time I remember being there was

25   that — that trip that we spoke of by myself with

26   Jordie Chandler and Macaulay.

27       Q.  On the occasions that you stayed in bed with

28   Mr. Jackson, would you ever cuddle in bed?

9131

1       A.  No.

2       Q.  Would you lie next to one another?

3       A.  No.

4       Q.  Would you touch?

5       A.  No.

6       Q.  Would you consider it to have been

7   inappropriate to have cuddled in bed?

8       A.  Sorry?

9       Q.  Would you have considered it to be

10   inappropriate to have cuddled in bed?

11       A.  No.

12           MR. ZONEN:  I have no further questions.

13

14                    REDIRECT EXAMINATION

15   BY MR. MESEREAU:

16       Q.  Mr. Robson, the prosecutor for the

17   government asked you about your dressing like

18   Michael Jackson.

19       A.  Uh-huh.

20       Q.  And I believe you said something about you

21   dressed like him before you met him.

22       A.  Yes.

23       Q.  Would you please explain that?

24       A.  Well, you know, I became a fan of Michael

25   Jackson when I was two years old, when I saw the

26   making of “Thriller,” and started dancing like him

27   when I was, you know, three or four.  So I think

28   when I was about five, I started, because I was

9132

1   imitating him.  I got costumes made and that sort of

2   thing.  So I would dress like him from that point,

3   before I met him.

4       Q.  Did Mr. Jackson ever encourage you to dress

5   like him?

6       A.  No.

7       Q.  Did you dress like him because you were a

8   fan and friend of his?

9       A.  Yes.

10       Q.  Now, the prosecutor talked about your

11   throwing pebbles at a lion.

12       A.  Uh-huh.

13       Q.  Would you please explain what you were

14   describing.

15       A.  Well, there’s a lion that was in a cage.

16   And, you know, went to see the lion roar, and it’s

17   pretty much just sitting there, you know, not doing

18   anything.  So we picked up a couple little stones

19   and threw them at the cage, you know.

20       Q.  And the prosecutor used the word “stones,”

21   and you said “pebbles.”  How big were these things?

22       A.  Little, you know — I don’t know,

23   quarter-inch sort of things.

24       Q.  Were you trying to hurt the lion?

25       A.  No.

26       Q.  To your knowledge, was Mr. Jackson trying to

27   hurt the lion?

28       A.  No.

9133

1       Q.  Okay.  The prosecutor asked you questions

2   about whether or not you were considered family.

3   Did you consider yourself to be part of Mr.

4   Jackson’s family?

5       A.  Yeah, I mean, in a friendship sort of way.

6   Because we were that close.  It was like family.

7       Q.  And did you use the word “family” once in a

8   while —

9       A.  Yes.

10       Q.  — when you spoke to him?

11       A.  Yes.

12       Q.  Did you hear your mother or sister using the

13   word “family”?

14       A.  Yes.

15       Q.  Did you think anything was strange about

16   that?

17       A.  No.

18       Q.  The prosecutor for the government asked

19   about Mr. Jackson giving you a kiss on the cheek.

20       A.  Uh-huh.

21       Q.  And you said that happened sometimes?

22       A.  Yes.

23       Q.  Did you think there was anything

24   inappropriate about that?

25       A.  No.

26       Q.  Did you do it in front of your mom?

27       A.  Yes.

28       Q.  Did you do it in front of your sister?

9134

1       A.  Yes.

2       Q.  Did your mother kiss him on the cheek?

3       A.  Yes.

4       Q.  Did your sister kiss him on the cheek?

5       A.  Yes.

6       Q.  Did you kiss Mr. Jackson on the cheek?

7       A.  Yes.

8       Q.  Did your mother used to hug Mr. Jackson?

9       A.  Yes.

10       Q.  Did Mr. Jackson used to hug your mother?

11           MR. ZONEN:  I’ll object as irrelevant what

12   happened with his mother.

13           THE COURT:  Overruled.  Go ahead.

14       Q.  BY MR. MESEREAU:  Did Mr. Jackson used to

15   hug your mother?

16       A.  Yes.

17       Q.  Did your sister used to hug Mr. Jackson?

18           MR. ZONEN:  I’ll object as leading as well.

19           THE COURT:  Overruled.

20       Q.  BY MR. MESEREAU:  Did your sister used to

21   hug Mr. Jackson?

22       A.  Yes.

23       Q.  And would you see Mr. Jackson hug your

24   sister?

25       A.  Yes.

26       Q.  Did you ever think there was anything

27   inappropriate about Mr. Jackson hugging any member

28   of your family?

9135

1       A.  No.

2       Q.  Did you ever think it was inappropriate to

3   see any member of your family hug Mr. Jackson?

4       A.  No.

5       Q.  Now, you said your sister would sometimes

6   stay in Mr. Jackson’s room, correct?

7       A.  Yes.

8       Q.  And how often do you recall that happening?

9       A.  I remember it just within that first trip we

10   were there.  So it was — it was, you know, three or

11   four nights or something like that.

12       Q.  And you mentioned Brandy.  Is that who you

13   mentioned?

14       A.  Yes.

15       Q.  Who was Brandy again?

16       A.  She was Michael Jackson’s niece.

17       Q.  You saw Brandy staying in his room?

18       A.  Yeah.

19       Q.  What’s the largest number of kids you ever

20   saw stay in Mr. Jackson’s room, if you remember?

21       A.  Yeah, probably four to five.

22       Q.  And what do you recall the children doing in

23   his room?

24       A.  Well, before we went to sleep, same sort of

25   things.  We’d play video games, watch movies.  Have

26   pillow fights.  You know, yeah.

27       Q.  Did you ever see anything of a sexual nature

28   between Mr. Jackson and any of those children?

9136

1       A.  Never.

2       Q.  Now, the prosecutor mentioned Macaulay

3   Culkin.  Did you get to know Macaulay Culkin at

4   Neverland?

5       A.  Yeah.  I mean, we hung out a little bit,

6   yes.

7       Q.  Was that where you first met him?

8       A.  I think I might have met him on a — on a

9   set of a commercial or one of his videos or — or,

10   no, I think I met him on “Black or White” the first

11   time, the music video.

12       Q.  Did you stay in contact with Mr. Culkin?

13       A.  No.

14       Q.  Is he someone you communicate with on a

15   regular basis?

16       A.  No.

17       Q.  Okay.  Now, would you see Mr. Culkin’s

18   family at Neverland?

19       A.  Other than his brother Kieran, I don’t

20   remember.

21       Q.  And approximately how old was his brother,

22   do you think?

23       A.  At that time, he would have been, I guess,

24   nine or ten, or something like that.

25       Q.  Have you seen Mr. Jackson hug other children

26   at Neverland?

27       A.  Yes.

28       Q.  Have you seen other children hug Mr. Jackson

9137

1   at Neverland?

2       A.  Yes.

3       Q.  Have you ever thought any of this was

4   inappropriate?

5       A.  No.

6       Q.  Have you seen Mr. Jackson kiss children at

7   Neverland?

8       A.  On the cheek, yes.  Or on the head, or on

9   the top of the head, something like that.

10       Q.  Ever seen kids kiss Mr. Jackson?

11       A.  Yes.

12       Q.  Any of that ever look inappropriate to you?

13       A.  No.

14       Q.  Have you seen lots of children visit

15   Neverland on occasion?

16       A.  Yes.

17       Q.  And what do you mean?

18       A.  I think we were there once when he had one

19   of his gatherings, like a Heal the World Foundation

20   thing where he had a bunch of kids come up there

21   and — you know, and have the day there.

22       Q.  And how many kids are you talking about, do

23   you think?

24       A.  Probably about 100 or 50.  75 to 100,

25   something like that.

26       Q.  Were there adults with those children?

27       A.  Yes.

28       Q.  And you said, “Heal the World.”  What did

9138

1   that mean to you?

2           MR. ZONEN:  I’m going to object as exceeding

3   the scope of the direct examination, and irrelevant,

4   and beyond the scope of his knowledge.

5           THE COURT:  Overruled.

6           You may answer.

7           THE WITNESS:  Could you repeat the question?

8       Q.  BY MR. MESEREAU:  Yeah.  What was “Heal the

9   World,” as far as you remember?

10       A.  As far as I knew, it was a foundation or a

11   charity that Michael had created that, you know,

12   raised money for kids with illnesses.  I don’t know

13   exactly what kind, but —

14       Q.  Did you interact with any of these kids that

15   visited that day?

16       A.  I may have, yeah, I mean, waved at them or

17   met a couple of them or something like that.

18       Q.  Did you see Mr. Jackson hugging other

19   children?

20       A.  Yes.

21       Q.  Did you see them hugging him?

22       A.  Yes.

23       Q.  Did you see Mr. Jackson kiss children?

24       A.  Yeah.

25       Q.  Have you seen them kiss him?

26       A.  Yes.

27       Q.  Ever seen anything inappropriate?

28       A.  No.

9139

1       Q.  Did you see Mr. Jackson hug adults who were

2   with those children?

3       A.  Yes.

4       Q.  Did you see adults hug Mr. Jackson who were

5   with those children?

6       A.  Yes.

7       Q.  Ever think any of that was inappropriate?

8       A.  No.

9       Q.  Now, the prosecutor for the government asked

10   you questions about whether he touched your hair.

11       A.  Uh-huh.

12       Q.  Do you recall Mr. Jackson ever touching your

13   hair?

14       A.  I can’t recall an exact thing, but it seems

15   like something he might have done at some point.

16       Q.  Do you ever recall Mr. Jackson doing

17   anything inappropriate with your hair?

18       A.  No.

19       Q.  Ever seen Mr. Jackson touch another child on

20   the head?

21       A.  Yes.

22       Q.  Have you seen that many times?

23       A.  Many times.

24       Q.  Did it ever seem like anything inappropriate

25   was going on when you saw that?

26       A.  No.

27       Q.  The prosecutor asked about disobedience at

28   Neverland, and you said you did see kids act up

9140

1   sometimes?

2       A.  Yeah, I mean, act up as far as kids go.  I

3   mean, you know, driving golf carts around and

4   throwing water balloons at each other, and things

5   that, I guess, I don’t know, maybe parents would get

6   upset about at some point, but that was the extent

7   of it.

8       Q.  And did you engage in some of that, too?

9       A.  Yes.

10       Q.  Did you ever see Michael Jackson in a water

11   balloon fight with kids?

12       A.  Yes.

13       Q.  Ever see kids throw water balloons at

14   Michael?

15       A.  Yes.

16       Q.  Ever see Michael throw water balloons at

17   kids?

18       A.  Yes.

19       Q.  Did you ever see Michael in golf carts with

20   kids?

21       A.  Yes.

22       Q.  When you used to play at Neverland during

23   the day, would Michael often be with you?

24       A.  Yes.

25       Q.  And what would Michael do with you?

26       A.  We’d go on rides together, you know, where

27   we’d drive around in the golf cart together, look at

28   animals together, watch movies together.

9141

1       Q.  Did you see Mr. Jackson act in a similar way

2   with other children?

3       A.  Yes.

4       Q.  Ever see anything inappropriate go on when

5   he was doing any of these things?

6       A.  No.

7       Q.  Now, how often do you recall your mother

8   going to Neverland with you?

9       A.  It’s been every time except for that one

10   time that I spoke of when I was there with Jordie

11   Chandler and Macaulay and I.

12       Q.  What do you recall seeing your mother do at

13   Neverland?

14       A.  A lot of the same things with us.

15       Q.  Would she sometimes be with Mr. Jackson when

16   all the kids were playing?

17       A.  Oh, yes.  She was playing along with us.

18       Q.  Now, you mentioned visiting an apartment in

19   Century City with Mr. Jackson, right?

20       A.  Yes.

21       Q.  And what do you recall doing in the

22   apartment with Mr. Jackson?

23       A.  Same sort of things.  He had arcade games

24   there.  You know, candy.  We’d eat, we’d watch, you

25   know, T.V. shows, Stooges.  Hang around, play games,

26   you know.

27       Q.  Did you ever see Mr. Jackson do anything

28   inappropriate with any child at that apartment?

9142

1       A.  No.

2       Q.  Where else have you been with Mr. Jackson?

3       A.  Like I said, we covered Las Vegas.  Westwood

4   apartment, Century City apartment.  Sheraton Hotel.

5   He came and stayed at my place once.

6       Q.  Where was that?

7       A.  That was in Hollywood.  It was — my mother

8   and I had a condo, and my sister.

9       Q.  Did you see Mr. Jackson do anything

10   inappropriate at any of these locations?

11       A.  No.

12       Q.  Ever seen Mr. Jackson touch any child in a

13   sexual way at any of these locations?

14       A.  Never.

15       Q.  Did Mr. Jackson ever touch you

16   inappropriately in any of these locations?

17       A.  No.

18       Q.  Now, have you been following media reporting

19   in this case?

20       A.  Yeah.  On and off.

21       Q.  You’re aware of allegations that were made

22   that Mr. Jackson —

23           MR. ZONEN:  I’m going to object as leading

24   and exceeding the scope of the direct — cross.

25           THE COURT:  I don’t know what the question is

26   yet.

27       Q.  BY MR. MESEREAU:  Okay.  You’ve been

28   following these reports that somehow Mr. Jackson was

9143

1   seen inappropriately touching you?

2       A.  Yes.

3       Q.  What do you think of them?

4       A.  I think it’s —

5           MR. ZONEN:  I’ll object.

6           I’ll withdraw the objection.

7           THE WITNESS:  I think it’s ridiculous.

8           MR. MESEREAU:  No further questions.

9

10                    RECROSS-EXAMINATION

11   BY MR. ZONEN:

12       Q.  When Mr. Jackson stayed with you at your

13   Hollywood apartment, how old were you?

14       A.  I would say 11 or 12.

15       Q.  Did he share your bed with you at that time?

16       A.  Yes.

17       Q.  All right.  There was one bed that you had

18   in your room; is that correct?

19       A.  No, it was actually — it was a — like a

20   futon that was our couch down in the living room.

21       Q.  So both of you stayed on the couch in the

22   living room?

23       A.  Yes.

24       Q.  Was that couch your normal residence?  Was

25   that where you normally slept?

26       A.  I think that’s where I was sleeping at that

27   point, yeah.

28       Q.  You think that’s where you were sleeping?

9144

1       A.  Yes.

2       Q.  You slept in other rooms at different times?

3       A.  Yeah.

4       Q.  Now, all those places that you mentioned are

5   all places that you mentioned, a series of places,

6   you had been with Michael Jackson.  On all of those

7   occasions you slept in the same bed with him; is

8   that correct?

9       A.  Yes.

10       Q.  Do you think that’s appropriate, for a

11   35-year-old man to be sleeping with an

12   eight-year-old boy?

13       A.  I don’t see any problem with it.

14       Q.  Suppose the 35-year-old man has an obsession

15   for sexually explicit material.  Would that change

16   your view?

17           MR. MESEREAU:  Objection; 352.

18           MR. ZONEN:  It’s in evidence.

19           MR. MESEREAU:  Calls for speculation;

20   assumes facts not in evidence.

21           THE COURT:  I’m going to sustain the

22   objection because of the use of the term

23   “obsession.”

24       Q.  BY MR. ZONEN:  If you knew that the person,

25   the 35-year-old man who was sleeping with an

26   eight-year-old boy, possessed a great quantity of

27   sexually explicit material, would that cause you

28   concern about that person’s motivations while he was

9145

1   in bed with the boy?

2       A.  Yes.

3           MR. ZONEN:  No further questions.

4

5                FURTHER REDIRECT EXAMINATION

6   BY MR. MESEREAU:

7       Q.  If you had known Michael Jackson, as a grown

8   man, was reading Playboy, Hustler, Penthouse,

9   magazines like that showing naked women, would that

10   have concerned you?

11       A.  No.  That’s what I was going to say

12   afterward.  Depends on what kind of material, what

13   kind of pornographic material you were talking

14   about.

15       Q.  Would that have concerned you?

16       A.  No.

17           MR. MESEREAU:  No further questions.

18           MR. ZONEN:  May I approach the witness?

19           THE COURT:  Yes.

20

21                 FURTHER RECROSS-EXAMINATION

22   BY MR. ZONEN:

23       Q.  I’d like to show you a couple exhibits, 841

24   and 842, that have been shown previously in this

25   court to this jury.

26           Let’s start with one titled “Boys Will Be

27   Boys.”  I’d like you to take a look at a few of the

28   pages.  Just go ahead and start turning pages,

9146

1   please.

2           Stop there for a moment.

3           Would you describe the picture on the right

4   side?

5       A.  There’s a young boy with his legs open and

6   he’s naked.

7       Q.  All right.  The picture prominently displays

8   his genitalia, does it not?

9       A.  Yes.

10       Q.  That boy looks, to you, to be approximately

11   how old?

12       A.  Maybe 11 or 12.

13       Q.  That’s how old you were when you were

14   sleeping with Michael Jackson; is that right?

15       A.  Yes.

16       Q.  Go ahead and flip a couple of more pages, if

17   you would.

18           You can stop right there, the next page.

19   What’s the picture on the left show?

20       A.  Just a young boy who’s naked standing on a

21   rock.

22       Q.  His genitalia is prominently displayed in

23   that picture; is that correct?

24       A.  Yes.

25       Q.  Appears that that child is about the same as

26   the other one?

27       A.  Yes.

28       Q.  Flip a couple more pages.  Please keep

9147

1   going.

2           Okay.  Stop right there.

3           What’s in that two pages, series of two

4   pages?

5       A.  There’s a boy, about the same age, 11 or 12,

6   who’s naked.

7       Q.  All right.  And in those pictures his

8   genitalia is prominently displayed as well; is that

9   correct?

10       A.  Yes.

11       Q.  In fact, if you’ll take just a second and

12   strum through the balance of that book — you can do

13   it fairly rapidly, if you would.  You don’t have to

14   go page by page, but as you wish.

15           Is it true, Mr. Robson, that all of the

16   pictures in that book are of boys about the same

17   age?

18       A.  Yes.

19       Q.  10, 11, 12 years old?

20       A.  Yes.

21       Q.  And that many of the photographs, if not

22   most of the photographs, depicted in that book are

23   of boys nude; is that correct?

24       A.  Yes.

25       Q.  And in fact, in most of those pictures, the

26   genitalia is prominently displayed; is that right?

27       A.  Yes.

28       Q.  Would you be concerned with a person who

9148

1   possesses a book like that?

2       A.  No.

3       Q.  Would you be concerned about having your

4   12-year-old child in bed with a person who possesses

5   a book like that?

6       A.  No.

7       Q.  You would have no such concern?

8       A.  No.  It’s — to me, it doesn’t — it’s not a

9   pornographic book.  It’s sort of, you know — I

10   don’t know, just a book.

11       Q.  I’d like — and I’d like to show you

12   Exhibit 596, please.  Take a moment and look at that

13   book.

14           Let’s stop there for a moment.

15           That’s the first, in fact, picture in that

16   book; is that correct?

17       A.  I didn’t notice, no.

18           Do you want me to go to the first picture?

19       Q.  You know, no, you can pick any picture,

20   actually.  Just go ahead and open the book at

21   random.

22           Right there.

23       A.  Oh, sorry.

24       Q.  Is it a fact, as you look through that book,

25   what is depicted in that book throughout that book

26   are a series of photographs of two men engaged in

27   sex acts with one another?

28       A.  Yes.

9149

1       Q.  And in fact, the sex acts are all acts of

2   either masturbation, oral sex or sodomy; is that

3   right?

4       A.  From what I saw, yes.

5       Q.  And sodomy, as you understand, is an act of

6   anal sex; is that correct?

7       A.  Yes.

8       Q.  Would you be concerned about a person who

9   possesses that book crawling into bed with a

10   ten-year-old boy?

11       A.  Yes, I guess so.

12           MR. ZONEN:  No further questions.

13           MR. MESEREAU:  May I approach, Your Honor?

14           THE COURT:  Yes.

15

16                FURTHER RECROSS-EXAMINATION

17   BY MR. MESEREAU:

18       Q.  Mr. Robson, I want to show you Exhibit

19   No. 841.  It says, “Boys Will Be Boys.”  Do you see

20   this?

21       A.  Yes.

22       Q.  Okay.  Now, I’d like you to read the

23   inscription on that book, okay?  Read it out loud,

24   if you would.

25       A.  Okay.  “Look at the true spirit of happiness

26   and joy in these boys’ faces.  This is the spirit of

27   boyhood, a life I never had and will always dream

28   of.  This is the life I want for my children.  MJ.”

9150

1       Q.  Having read that inscription and having

2   looked at this book, would you have any concern

3   being in bed with Michael Jackson if you knew this

4   book was found in his home?

5       A.  No.

6       Q.  Let me show you Exhibit No. 842.  Please

7   read out loud the inscription on that book.

8       A.  Is that, “To Michael”?  Yeah.  “To Michael,

9   from your fan.  Kiss, kiss, kiss, hug, hug, hug.

10   Rhonda.  1983.”

11       Q.  You’ve looked through that book – okay? –

12   and it says, “The Boy; A photographic Essay,” right?

13       A.  I didn’t look through that book.

14       Q.  Okay.  Why don’t you look through this book

15   the prosecutor showed you, and please say whether or

16   not you would have a problem being in the same

17   bedroom with Michael Jackson based upon what you see

18   in that book and the inscription.

19       A.  No.

20       Q.  Okay.  Now, let me show you — let me show

21   you Exhibit No. 596 that the prosecutor showed you.

22   Just read the cover, if you would.

23       A.  “Man, A Sexual Study of Man.  Illustrated

24   With Photographs and Art Prints.”

25       Q.  Okay.  Now, you’ve seen those photographs,

26   and you’ve said you were somewhat disturbed by the

27   pictures, right?

28       A.  Well, I wasn’t disturbed by the pictures.

9151

1       Q.  Well, if you — if you read this book, and

2   it appeared to be a book dealing with male sexuality

3   in all different areas, and you knew that this book

4   existed with hundreds of editions of Hustler,

5   Playboy, Penthouse —

6           MR. ZONEN:  I’m going to object as leading.

7       Q.  BY MR. MESEREAU:  — would that bother you?

8           MR. ZONEN:  I’m going to object as leading.

9           THE COURT:  Overruled.

10           You may answer.

11           THE WITNESS:  Can you repeat it?

12       Q.  BY MR. MESEREAU:  Sure.

13           Let’s assume that you learned that Michael

14   Jackson had ten years’ worth of Hustler, Playboy,

15   Penthouse – okay? – magazines, heterosexual-type

16   magazines, and let’s assume that — have you ever

17   seen Mr. Jackson’s library?

18       A.  Yes.

19       Q.  How many books do you think are in there?

20       A.  Thousands.

21       Q.  And let’s suppose in the middle of all those

22   books you found, “A Sexual Study of Man, Illustrated

23   With Photographs and Art Prints,” okay?

24       A.  Yes.

25       Q.  Putting all this together, would being in

26   bed with Mr. Jackson concern you?

27       A.  No.

28           MR. MESEREAU:  No further questions.

9152

1                    FURTHER RECROSS-EXAMINATION

2   BY MR. ZONEN:

3       Q.  Of course nobody’s told you where this book

4   comes from, did they?

5       A.  No.

6           MR. SNEDDON:  Ron?

7           THE COURT:  It’s time for the break.

8           MR. ZONEN:  It’s not quarter to.

9           THE COURT:  My bailiff told me.

10           (Recess taken.)

11           MR. MESEREAU:  Your Honor?

12           MR. ZONEN:  Thank you.

13           MR. MESEREAU:  I’m going to object that the

14   questions have become cumulative and there’s no

15   foundation for it to go any further.

16           BAILIFF CORTEZ:  Your microphone is off,

17   sir.

18           MR. MESEREAU:  It’s beyond the scope.  And

19   this is not a character witness.

20           MR. ZONEN:  I don’t recall which question

21   he’s referring to.

22           THE COURT:  I’m looking for it myself.

23           I don’t have a question.

24           THE REPORTER:  Would you like me to read the

25   last question, Judge?

26           MR. ZONEN:  I’m prepared to start with a new

27   question.

28           THE COURT:  All right.

9153

1       Q.  BY MR. ZONEN:  Mr. Robson, the three books

2   that are in front of you that you’ve already taken a

3   look at, I’d like to go back over the inscription

4   that — 842 is a book, and you were asked to read

5   that inscription out loud.

6           Take a look at that inscription again, would

7   you, please?

8       A.  Do you want me to read it again?

9       Q.  No, you don’t need to read it again.

10           Go to the last word, which is the name.

11   What is the name on that?

12       A.  Rhonda.

13       Q.  Notice anything unusual about the name?

14       A.  No.

15       Q.  Do you notice it’s written with quotations

16   on both sides of it?

17       A.  Yes.

18       Q.  Doesn’t that usually mean that that’s not

19   the name when somebody writes it in quotation marks?

20       A.  Not that I know of.

21       Q.  Have you ever written your name in quotation

22   marks?

23       A.  No.

24       Q.  That’s actually from somebody who’s not

25   named Rhonda, right?

26           MR. MESEREAU:  Objection; calls for

27   speculation.

28           THE COURT:  Sustained.

9154

1       Q.  BY MR. ZONEN:  The three books I’ve given

2   you so far to take a look at, they all feature

3   either boys or adult men, predominantly nude, and

4   the one on adult men is engaged in sex acts; is that

5   correct?

6           MR. MESEREAU:  I’m going to object; asked

7   and answered.  This is cumulative.

8           THE COURT:  Overruled.

9       Q.  BY MR. ZONEN:  I’m going to show you three

10   additional books now, if I could.  Let’s start with

11   Exhibit 578, if you’ll take a look at that one,

12   please.

13           MR. MESEREAU:  Same objection.  Cumulative;

14   it’s not character; it’s beyond the scope.

15           THE COURT:  Overruled.

16       Q.  BY MR. ZONEN:  I’ll start with the first

17   picture.  What do you see right there?

18       A.  I see in the center of the picture, it’s a

19   drawing.  And there’s a naked man with his genitalia

20   exposed, and there’s kangaroos on either side.

21       Q.  Okay.  Go ahead and proceed.

22           You can keep going.  Just keep going through

23   it.

24           You can stop.

25           What you’ve seen so far are all pictures of

26   naked men; is that right?

27       A.  Yes.

28       Q.  And pictures with their genitalia

9155

1   prominently displayed; is that correct?

2       A.  Yes.

3       Q.  Some of these are bondage pictures, are they

4   not?

5           MR. MESEREAU:  Objection; leading.

6           MR. ZONEN:  It’s cross-examination, Your

7   Honor.

8           MR. MESEREAU:  Assumes facts not in

9   evidence.

10           THE COURT:  Overruled.

11       Q.  BY MR. ZONEN:  Is that correct?  Like that

12   picture right there?

13       A.  Yes.

14       Q.  Would you consider this to be homoerotic

15   material?

16       A.  Yes.

17       Q.  Exhibit No. 590-B, take a look at that,

18   please.  Tell us the title.

19       A.  “Before the Hand of Man.”

20       Q.  Go ahead and take a look at the content of

21   that book.

22           That’s enough.

23           Pictures of naked young men; is that

24   correct?

25       A.  Yes.

26       Q.  Would you consider that to be homoerotic

27   material?

28       A.  No.

9156

1       Q.  Why not?

2       A.  I look at this more as sort of — it’s about

3   the photography and it’s more of an art book, to me.

4       Q.  Do you think it’s the background setting

5   that makes it unique?

6       A.  Unique?

7       Q.  Well, they’re all naked men in it; is that

8   right?

9       A.  Yes.

10       Q.  Look at No. 599, if you would.

11           You can stop.

12           Those are all pictures of boys and men, all

13   nude; is that correct?

14       A.  I didn’t see any boys.  I saw men.

15       Q.  How old do you think is the youngest person

16   you’ve seen in this book so far?

17       A.  Maybe 19.  18, 19.

18       Q.  Teenaged?

19       A.  Yeah.

20       Q.  Okay.  They’re all about that age or a

21   little bit older; is that right?

22       A.  Yeah.

23       Q.  Do you think this person is 19?

24       A.  18, 19, yeah.

25       Q.  Okay.  And in fact, in each one of them,

26   genitalia is prominently displayed; is that correct?

27       A.  Yes.

28       Q.  Take a look at this book, please, No. 590-A.

9157

1           You can stop here.

2           What are you taking a look at?  Particularly

3   the page you’re focused on at the moment, what do

4   you see?

5       A.  There’s two naked men and it looks like

6   they’re about to kiss each another.

7       Q.  In this book, in fact, each of the pictures

8   depict two naked men; is that right?

9       A.  Yes.

10       Q.  And in each instance, both of them are doing

11   something with one another of a sexual nature; is

12   that right?

13       A.  No.

14       Q.  They’re hugging, they’re touching, they’re

15   caressing?

16       A.  They’re posing.

17       Q.  They’re posing.  And they’re all naked?

18       A.  Yes.

19       Q.  Would you consider this to be homoerotic

20   art?

21       A.  Mind if I look a little more?

22       Q.  Go ahead.

23       A.  Yeah, it’s — I don’t think it’s so erotic.

24   It seems more loving in a way, like not so much

25   about sex.

26       Q.  Well, how about the one you just turned to?

27   Where is his hand?

28       A.  Down his pants.

9158

1       Q.  Okay.  You can go ahead and close that one

2   right now.

3           Mr. Robson, are you concerned about a man

4   possessing these seven books being in bed with a

5   12-year-old boy?

6       A.  If it was a man I didn’t know, maybe.  But

7   not Michael.

8       Q.  Is that because you view Mr. Jackson as

9   being, for the most part, asexual?

10       A.  No.

11       Q.  Because you believe that he doesn’t really

12   have a sexual interest?

13       A.  I believe that he has a sexual interest in

14   women.

15       Q.  Did you know that he possessed these

16   magazines?

17           MR. MESEREAU:  Objection, Your Honor, he

18   didn’t let the witness complete his answer.

19           THE COURT:  Sustained.

20           MR. MESEREAU:  Could the witness complete

21   his answer, Your Honor?

22           THE COURT:  Yes.

23           THE WITNESS:  I believe that he has a sexual

24   interest in women.

25       Q.  BY MR. ZONEN:  In women?

26       A.  Yes.

27       Q.  These books don’t suggest otherwise?

28       A.  Not necessarily.

9159

1       Q.  All right.  Let’s go to some other side of

2   the counter.

3           Exhibit No. 575, have you ever seen this

4   magazine before?

5       A.  No.

6       Q.  Not that specific one.  A magazine of that

7   nature?

8       A.  Of that nature, yes.

9       Q.  Okay.  And go ahead and turn through it.

10           You can stop there.  You don’t need to go

11   too much further.

12           This magazine depicts naked women, or a

13   woman in this case, inserting things inside of her;

14   is that right?

15       A.  Yes.

16       Q.  You would consider this to be very

17   graphic —

18       A.  Yes.

19       Q.  — in terms of sexually explicit material?

20       A.  Yes.

21       Q.  Exhibit No. 520, tell us the title of that.

22       A.  “Hard Rock Affair.”

23       Q.  Okay.  Go ahead and turn through a few

24   pages.

25           You don’t have to turn any further.

26           That magazine depicts graphic sexual

27   pictures of a man and a woman engaged in acts of

28   intercourse and oral sex; is that right?

9160

1       A.  Yes.

2       Q.  You would consider this to be pretty much as

3   hard-core as sexually graphic material goes; is that

4   right?

5           MR. MESEREAU:  Objection.  Misstates the

6   evidence; 352.

7           MR. ZONEN:  I asked him what he considered.

8           THE COURT:  Overruled.

9           You may answer.

10           THE WITNESS:  That’s as hard-core as it goes,

11   is that what you asked?

12       Q.  BY MR. ZONEN:  Yes.

13       A.  No, not as hard-core as it goes.

14       Q.  What could be more than that?

15       A.  I’ve seen crazy things, crazy bondage

16   things, all sorts of stuff.

17       Q.  You saw the bondage in the last publication;

18   is that right?

19       A.  Yeah, but they weren’t really doing

20   anything.

21       Q.  All right.  You would consider bondage to be

22   at the height?

23       A.  Yeah.  When it gets into, you know, really

24   unusual stuff.

25       Q.  What’s the title of this one?  The magazine

26   that we have here is 522.

27       A.  “Double Dicking Caroline.”

28       Q.  Go ahead and turn a couple pages.

9161

1           Okay.  That’s fine.

2           These are all photographs of a man and a

3   woman engaged in pretty much anything a man and a

4   woman can do; is that right?

5       A.  Yes.

6       Q.  Including acts of intercourse, acts of oral

7   sex, and the picture right in front of you, acts of

8   anal sex; is that right?

9       A.  Yes.

10       Q.  This you would consider to be fairly

11   hard-core, would you not?

12       A.  Yes.

13       Q.  The title of this one, please?  No. 510.

14       A.  “Stiff Dick Lynn.”  Or “for Lynn,” sorry.

15       Q.  “For Lynn”?

16       A.  “Stiff Dick for Lynn.”

17       Q.  Let’s get our prepositions right.

18       A.  Get it right, yeah.

19       Q.  Go ahead and turn the page, if you would.

20       A.  I never thought I’d have a room of people

21   watching me do this.

22       Q.  That’s enough.

23           You would agree that this is a depiction of

24   a man and a woman engaged in virtually every

25   variation that a man and woman can do with one

26   another; is that right?

27       A.  Yes.

28       Q.  Sexually.

9162

1           The collective material that you have just

2   been shown does not cause you a moment of pause when

3   you think about the prospect of this person who

4   possesses all of this crawling into bed with a

5   ten-year-old boy?

6       A.  No.

7       Q.  And you would allow a child to crawl into

8   bed with such a person?

9       A.  If I knew the person, yes.

10       Q.  If you knew them?

11       A.  Yes.

12       Q.  Your own child, you’d have no problem

13   sleeping with a 35-, 40-year-old man?

14       A.  If I knew the person well, no.

15           MR. ZONEN:  No further questions.

16

17                FURTHER REDIRECT EXAMINATION

18   BY MR. MESEREAU:

19       Q.  Mr. Robson?

20       A.  Yes.

21       Q.  That’s your fiancee right there, correct?

22       A.  Yes.

23       Q.  You are heterosexual, correct?

24       A.  Yes.

25       Q.  You are a close friend of Michael, correct?

26       A.  Yes.

27       Q.  By the way, did Michael Jackson ever — oh,

28   I’ll ask from there.

9163

1           When you were a young child, did Michael

2   Jackson ever show you any sexually explicit

3   material?

4       A.  No.

5       Q.  Did you ever see Michael Jackson show

6   sexually explicit material to any child?

7       A.  No.

8           MR. MESEREAU:  May I approach, Your Honor?

9           THE COURT:  Yes.

10       Q.  BY MR. MESEREAU:  Now, let me show you again

11   Exhibit No. 841.  Do you see that?

12       A.  Yes.

13       Q.  And have you had a chance to flip through

14   that book?

15       A.  Yes.

16       Q.  Okay.  Let me show you again Exhibit No.

17   596.  It says, “A Sexual Study of Man.”  Do you see

18   that?

19       A.  Yes.

20       Q.  Have you had a chance to flip through that

21   book?

22       A.  Yes.

23       Q.  Okay.  And let me show you again Exhibit No.

24   842, “A boy; A Photographic Essay,” okay?  And

25   that’s the one with the inscription, “To Michael,

26   from your loving fan, Rhonda,” okay?

27       A.  Yes.

28       Q.  And have you had a chance to flip through

9164

1   that book?

2       A.  Yes.

3       Q.  In fact, you see young children with rather

4   innocent photographs of young boys, correct?

5           MR. ZONEN:  I’m going to object as leading,

6   Your Honor.

7           THE COURT:  Overruled.

8       Q.  BY MR. MESEREAU:  Innocent photographs of

9   young boys in various situations, right?

10       A.  Yes.

11       Q.  Okay.  You see a young boy hanging from a

12   tree, right?

13       A.  Yes.

14       Q.  You see a young boy sitting outside a door,

15   right?

16       A.  Yes.

17       Q.  See young boys on a beach, right?

18       A.  Yes.

19       Q.  Okay.  Now, let’s go to — quickly, to the

20   material the prosecutor for the government showed

21   you, okay?  He showed you some magazines with

22   heterosexual activity, correct?

23       A.  Yes.

24       Q.  Okay.  Have you seen one book that depicts

25   child pornography in that group?

26       A.  No.

27           MR. ZONEN:  I believe there was a Court

28   restriction on the use of that word, Your Honor, one

9165

1   initiated by the defense.  Unless that reservation

2   is finished.

3           MR. MESEREAU:  He’s correct.  And I made a

4   mistake using the word.  I’ll withdraw it, and I

5   apologize.

6           THE COURT:  All right.  The problem is that

7   sometimes it’s an appropriate word to use and

8   sometimes it’s not.  But the jury’s been instructed

9   on it.  And so if you want to rephrase it, that’s

10   fine.

11           MR. MESEREAU:  Okay.

12       Q.  In those books that the prosecutor for the

13   government showed you, you see books about men,

14   right?

15       A.  Yes.

16       Q.  You see one book that says, “A Study of Male

17   Sexuality” and shows some sexual acts between men,

18   correct?

19       A.  Yes.

20       Q.  And he showed you a number of magazines

21   involving sexual activity between men and women,

22   correct?

23       A.  Yes.

24       Q.  Okay.  Has he shown you one book involving

25   children having sex?

26       A.  No.

27       Q.  Has he shown you one book where a man is

28   having sex with a child?

9166

1       A.  No.

2       Q.  The prosecutor tried to suggest that Mr.

3   Jackson is asexual.  Do you remember that question?

4       A.  Yes.

5       Q.  Do you believe he’s asexual?

6       A.  No.

7       Q.  Have you seen Mr. Jackson with women in your

8   lifetime?

9       A.  With what kind of woman?  A woman that he’s

10   in a relationship with?

11       Q.  That he’s been married to.

12       A.  Yeah, with Lisa Marie.

13       Q.  When you were at Neverland, did you ever see

14   anything that suggested pedophilia?

15       A.  No.

16       Q.  Ever see any magazine or poster that

17   suggested pedophilia?

18       A.  Never.

19           MR. MESEREAU:  No further questions.

20

21                    FURTHER RECROSS-EXAMINATION

22   BY MR. ZONEN:

23       Q.  Mr. Robson, when did you first learn that

24   Michael Jackson possessed material of the nature

25   that’s before you right now?

26       A.  Right now I did.

27       Q.  All the years that you have known Michael —

28       A.  Actually, no one’s told me where this came

9167

1   from.

2       Q.  Assuming this comes from Michael Jackson’s

3   residence.

4       A.  Assuming it does, this is the first I know.

5       Q.  All right.  And you had never, ever known

6   that Mr. Jackson collected sexually explicit

7   material?

8       A.  No.

9       Q.  This is something new that you’re learning

10   just today; is that right?

11       A.  Yes.

12       Q.  You’re telling us that this would have no

13   effect at all on your belief that this bears on some

14   suitability for him sleeping with ten-year-old boys?

15       A.  No.

16       Q.  You knew that there were a succession of

17   ten-year-old boys that he slept with, didn’t you?

18           MR. MESEREAU:  Objection.  Misstates the

19   evidence; the Court ruling.

20           THE COURT:  Sustained.

21       Q.  BY MR. ZONEN:  Did you know about other

22   children that he had slept with?

23       A.  No.

24       Q.  Never?

25       A.  No.

26       Q.  Did you know that he was sleeping with Brett

27   Barnes?

28       A.  No.

9168

1       Q.  Did you know that he was sleeping with

2   Macaulay Culkin?

3       A.  No.

4       Q.  Did you know that he was sleeping with

5   Jordie Chandler?

6       A.  No.

7           MR. ZONEN:  No further questions.

8

9                FURTHER REDIRECT EXAMINATION

10   BY MR. MESEREAU:

11       Q.  You actually saw kids sleeping in his room

12   from time to time, correct?

13       A.  Yeah.  When he was present as well, yeah.

14       Q.  And Macaulay Culkin was there as well,

15   correct?

16       A.  Yeah.

17       Q.  Never saw anything inappropriate happen,

18   right?

19       A.  No.

20       Q.  Has anything this prosecutor for the

21   government has said to you changed your opinion of

22   Michael Jackson?

23       A.  Not at all.

24       Q.  Does it change your opinion as to whether or

25   not he ever did anything inappropriate with a child?

26       A.  Not at all.

27           MR. MESEREAU:  No further questions.

28           MR. ZONEN:  I have no questions.

9169

1           THE COURT:  Thank you.  You may step down.

2           Call your next witness.

3           MR. MESEREAU:  Your Honor, may I remove the

4   materials from the witness box?

5           THE COURT:  Yes.

6           THE BAILIFF:  Oh, I’ll get it for you.

7           THE COURT:  When you get to the witness

8   stand, please remain standing.

9           Face the clerk over here and raise your

10   right hand.

11

12                   BRETT CHRISTOPHER BARNES

13           Having been sworn, testified as follows:

14

15           THE WITNESS:  Yes.

16           THE CLERK:  Please be seated.  State and

17   spell your name for the record.

18           THE WITNESS:  My whole name?

19           THE CLERK:  Yes, please.

20           THE WITNESS:  Okay.  It’s Brett Christopher

21   Barnes.  B-r-e-double t; C-h-r-i-s-t-o-p-h-e-r;

22   B-a-r-n-e-s.

23           THE CLERK:  Thank you.

24

25                    DIRECT EXAMINATION

26   BY MR. MESEREAU:

27       Q.  Mr. Barnes, how old are you?

28       A.  I’m 23 years old.

9170

1       Q.  Where is your home?

2       A.  Melbourne, Australia.

3       Q.  And what kind of work do you do?

4       A.  Right now I’m unemployed.  I actually had to

5   quit my job to come here.

6       Q.  Okay.  And what job is that?

7       A.  I was a roulette dealer at the casino.

8       Q.  In Melbourne?

9       A.  Yes.

10       Q.  Okay.  Do you know the fellow seated to my

11   right at counsel table?

12       A.  Absolutely.

13       Q.  Who is he?

14       A.  It’s my good friend Michael Jackson.

15       Q.  And you say your good friend.  How long have

16   you known him?

17       A.  Since I was five.

18       Q.  How did you meet him?

19       A.  I actually — I was a big — well, I was as

20   big a fan as you can be at that age, of his, and he

21   was in Melbourne for the “Bad” tour.  And so my mom

22   thought it would be a good idea for us to write a

23   letter.  My sister wrote the letter, but put it in

24   my name as if I was writing the letter.

25           And we went to meet him — well, see him at

26   the airport when he touched down.  And while we were

27   there, we gave the letter to one of his dancers, and

28   then we left the airport after it was all over.

9171

1           And I’m not sure exactly how much time

2   passed, but after a little while, he — we received

3   a phone call from him, and ever since then we’ve

4   been really good friends.

5       Q.  And is he a friend of your family?

6       A.  Absolutely.

7       Q.  Okay.  Have you ever visited Neverland

8   Ranch?

9       A.  Yes, I have.

10       Q.  When did you first visit Neverland Ranch?

11       A.  It would have been December of ’91.

12       Q.  And do you remember why you visited

13   Neverland?

14       A.  Because he was there, and it’s his house, I

15   guess.

16       Q.  Who did you go with?

17       A.  My whole family went, my mother and my

18   father and my sister and myself.

19       Q.  Did you stay at Neverland?

20       A.  Yes, I did.

21       Q.  How many times do you think you visited

22   Neverland?

23       A.  Too many to remember.  Probably — it would

24   be ten or more, even.  More than ten times.

25       Q.  And how many times do you think you’ve

26   stayed over at Neverland?

27       A.  Every time.

28       Q.  Okay.  Did you ever stay in Michael

9172

1   Jackson’s room?

2       A.  Yes, I have.

3       Q.  How many times do you think you’ve done

4   that?

5       A.  Countless as well.

6       Q.  And how would you describe his room?

7       A.  It’s big.  It’s pretty cool because it’s got

8   lots of fun stuff to do there.  Video games, such as

9   stuff like that.  And it’s probably the best as I

10   can describe it.

11       Q.  Have you ever stayed in Michael Jackson’s

12   bed?

13       A.  Yes, I have.

14       Q.  How many times do you think you have?

15       A.  Countless as well.

16       Q.  Has Mr. Jackson ever molested you?

17       A.  Absolutely not.  And I can tell you right

18   now that if he had, I wouldn’t be here right now.

19       Q.  Has Mr. Jackson ever touched you in a sexual

20   way?

21       A.  Never.  I wouldn’t stand for it.

22       Q.  Has Mr. Jackson ever touched any part of

23   your body in a way that you thought was

24   inappropriate?

25       A.  Never.  It’s not the type of thing that I

26   would stand for.

27       Q.  When you stayed in Mr. Jackson’s bed —

28       A.  Uh-huh.

9173

1       Q.  — on any of those occasions was anyone else

2   there?

3       A.  Yeah.

4       Q.  Who?

5       A.  Well, I can’t — see, I was pretty young at

6   the time, so I can’t remember exactly.  But I know

7   my sister as being there, his cousins have been

8   there.  And — yeah, Macaulay has actually been

9   there as well, Macaulay Culkin.  So there’s been a

10   few people.

11       Q.  What is the longest period you think you’ve

12   ever stayed at Neverland?

13       A.  I couldn’t tell you.  I don’t remember

14   really.

15       Q.  Would it be a week, or three days?

16       A.  Longer than that.

17       Q.  Longer than that?

18       A.  Yeah.  It would probably be a couple weeks,

19   maybe a month at Neverland at one time.

20       Q.  And what do you recall doing at Neverland

21   during the times you stayed there?

22       A.  Playing arcade games.  Going

23   ATV/motorbike-riding around the property.  Going on

24   amusement park rides.  And watching plenty of

25   movies, plenty of cartoons.  Eating very good food.

26       Q.  Do you consider Michael Jackson to be your

27   family friend?

28       A.  Absolutely.

9174

1       Q.  Do you stay in communication with him?

2       A.  Absolutely.

3       Q.  And how do you typically communicate with

4   Michael Jackson?

5       A.  Like he’s a member of the family.  Just

6   always had warm conversations, reminisce about old

7   times.

8       Q.  Are you familiar with a Jacuzzi at

9   Neverland?

10       A.  Yeah.

11       Q.  Ever been in the Jacuzzi?

12       A.  Yes, I have.

13       Q.  Do you recall Michael Jackson ever being in

14   the Jacuzzi with you?

15       A.  I don’t recall.  He possibly could have, but

16   I don’t really remember.

17       Q.  Do you recall ever taking a shower with

18   Michael Jackson?

19       A.  Never.

20       Q.  Now, have you visited Neverland without your

21   parents being with you?

22       A.  Yes.

23       Q.  And how many times do you think you’ve done

24   that?

25       A.  It wouldn’t be that many.  But I couldn’t

26   give you a ballpark figure even.

27       Q.  Now, have you followed this case in the

28   media?

9175

1       A.  No, I haven’t.

2       Q.  Okay.

3       A.  I chose not to.

4       Q.  Are you aware of any allegations being made

5   that Mr. Jackson inappropriately touched you when

6   you were with him?

7       A.  Yes, I am.  And I’m very mad about that.

8       Q.  You’re mad about it?

9       A.  Yeah.

10       Q.  Why?

11       A.  Because it’s untrue, and they’re putting my

12   name through the dirt.  And I’m really, really,

13   really not happy about it.

14           MR. MESEREAU:  No further questions.

15

16                      CROSS-EXAMINATION

17   BY MR. ZONEN:

18       Q.  Mr. Barnes, do you consider it disgraceful

19   to having been molested?

20       A.  Absolutely.

21       Q.  All right.  And why would it be a disgrace

22   for somebody to have been molested?

23       A.  Well, a child is —

24           MR. MESEREAU:  Objection.  This calls for

25   speculation; foundation.

26           THE COURT:  Sustained.

27       Q.  BY MR. ZONEN:  How old were you when you

28   first started sharing a bed with Michael Jackson?

9176

1       A.  Couldn’t tell you.  Don’t really remember.

2       Q.  How old were you when you first started

3   visiting Michael Jackson?

4       A.  When I first started visiting, I was nine.

5       Q.  And you visited Neverland with whom?

6       A.  With my parents.

7       Q.  Both your mother and your father?

8       A.  And my sister as well.

9       Q.  Your sister as well.  And how long did you

10   stay at Neverland?

11       A.  The first time?

12       Q.  Yes.

13       A.  I don’t exactly remember.

14       Q.  Did you stay over the week?

15       A.  Yeah.

16       Q.  Did you then visit Neverland on a regular

17   basis thereafter?

18       A.  I wouldn’t say regular, but, yeah, it was

19   quite frequent.

20       Q.  Did you visit Neverland at least once a year

21   thereafter?

22       A.  Yeah.

23       Q.  And when you visited Neverland, would you

24   always stay with Michael Jackson?

25       A.  Yeah, most of the time.

26       Q.  All right.  Now, I asked you, I believe, the

27   age the first time you went.  Did you answer that

28   question?

9177

1       A.  Yeah.

2       Q.  And you said what?  About nine?

3       A.  Yeah.

4       Q.  Okay.  And then you would continue to go

5   each year thereafter?

6       A.  Yeah.

7       Q.  Did you sometimes go more than once a year?

8       A.  Yeah.

9       Q.  And would you stay for longer than one week

10   at a time?

11       A.  Sometimes, I guess, yeah.

12       Q.  Were there occasions where you would stay

13   two or even three weeks?

14       A.  I was young at the time, so I don’t really

15   remember the time frames.

16       Q.  Okay.

17       A.  So it would be purely speculation.

18       Q.  Would it have been summer vacation; that is,

19   your summer vacation in Australia?

20       A.  I really couldn’t tell you.

21       Q.  Did you ever go to Neverland without a

22   parent going with you?

23       A.  Yes.

24       Q.  So sometimes you would fly all the way from

25   Australia to Neverland, is that right, by yourself?

26       A.  Absolutely.

27       Q.  Were you much older than nine years old when

28   you did that?

9178

1       A.  I couldn’t tell you.  But — well, right —

2   yeah, I was older than nine.

3       Q.  Did you visit in your tenth year and your

4   eleventh year and your twelfth year as well?

5       A.  I really couldn’t tell you that.

6       Q.  Did you ever visit in your thirteenth year

7   and your fourteenth year?

8       A.  I don’t remember much about ages.

9       Q.  You can’t tell us how old you were when you

10   stopped visiting Neverland?

11       A.  I still — I continue to visit to this day.

12       Q.  Do you still sleep with Michael Jackson?

13       A.  No, I don’t.

14       Q.  How old were you when you stopped sleeping

15   with Michael Jackson?

16       A.  I couldn’t tell you that.

17       Q.  Why don’t you still sleep with Michael

18   Jackson?

19       A.  Well, he’s got kids now.

20       Q.  And?

21       A.  And I — it would be purely speculation if I

22   told you.  I could not answer that knowingly,

23   like — it’s just —

24       Q.  But during the years that you were visiting

25   Michael Jackson at Neverland, you never stayed

26   anyplace but in his room; is that correct?

27       A.  I couldn’t tell you.

28       Q.  You’re telling us that you don’t remember if

9179

1   you stayed in a guest lodge by yourself or with your

2   mother or if you shared a bed with Michael Jackson?

3       A.  I don’t remember staying in the guest lodge

4   by myself.

5       Q.  But it’s true, sir, that you stayed

6   virtually the entire time in his bedroom; is that

7   right?

8       A.  Yeah.

9       Q.  And during that time nobody else stayed in

10   the bedroom with you other than you and Michael

11   Jackson; is that true?

12       A.  No, that’s not true.

13       Q.  On what percentage of the occasions that you

14   visited Michael Jackson was there somebody else

15   staying in that room?

16       A.  I couldn’t tell you.

17       Q.  Can you tell us the names of the people who

18   stayed in the room with you?

19       A.  My sister.  Macaulay Culkin.  There was

20   Levon and Elijah.  There was Frank, Eddie, and

21   Dominick.

22       Q.  Was Frank —

23       A.  Prince as well.

24           MR. MESEREAU:  Objection, he hasn’t finished

25   the question.

26           THE WITNESS:  His son Prince as well.

27       Q.  BY MR. ZONEN:  Prince?  Prince is how old

28   now?

9180

1       A.  I’m not quite sure.

2       Q.  About what, seven?

3       A.  Yeah.  I guess so.

4       Q.  And how old was Prince when he stayed in the

5   room with you and Michael Jackson?

6       A.  I think he was three.

7       Q.  All right.  So it was about four years ago?

8       A.  Yeah.

9       Q.  So you stayed in the room with Michael

10   Jackson when you were 18 years old?

11       A.  Yeah.

12       Q.  You’re 22 now?

13       A.  23.  23.

14       Q.  So you were 19 years old?

15       A.  Yeah, I guess.

16       Q.  Did you share a bed with him at that time?

17       A.  Yeah, I did.

18       Q.  You did.  Have you been sharing a bed with

19   him consistently from age nine until age 19?

20       A.  What do you mean by “consistent”?

21       Q.  Well, in all the times that you visit,

22   predominately do you stay in his room, in his bed?

23       A.  Yeah.

24       Q.  Did you do it when you were ten years old as

25   well?

26       A.  Yeah.

27       Q.  Did you do it when you were 11 years old as

28   well?

9181

1       A.  Yes.

2       Q.  Most of the times you did it, there was

3   nobody else in the room; is that correct?

4       A.  I guess you could say that.

5       Q.  Because Macaulay Culkin was only in the room

6   with you once or twice; isn’t that true?

7       A.  I couldn’t tell you how many times.

8       Q.  Could he have been in the room 20 or 30

9   times?

10       A.  Probably not.

11       Q.  So really it’s closer to once or twice; is

12   that right?

13       A.  Yeah, I guess so.

14       Q.  All right.  And your sister stayed there the

15   first time you visited; is that right?

16       A.  Not just the first time.

17       Q.  Did she stay there the second time?

18       A.  I — look, I don’t really remember.

19       Q.  Did your sister share a bed with you and

20   Michael Jackson ever?

21       A.  I can’t recall.

22       Q.  You can’t recall if your sister shared a

23   bed?

24       A.  I can’t remember.

25       Q.  When did your sister stop visiting

26   Neverland?

27       A.  She still visits to this day.

28       Q.  Does she still share a bed with you and

9182

1   Michael Jackson?

2       A.  No.

3       Q.  When was the last time your sister shared a

4   bed with you and Michael Jackson?

5       A.  I couldn’t tell you.  I don’t know the exact

6   period of time.

7       Q.  Could you have been 15 or 16 years old?

8       A.  I couldn’t tell you.

9       Q.  Could you have been ten?

10       A.  I couldn’t tell.

11       Q.  Mr. Barnes, the best you can tell us about

12   when your sister last shared a bed with you and

13   Michael Jackson, you have no idea?

14       A.  It’s not something that I think of.  What —

15   why would I try and remember that?

16       Q.  Is there —

17       A.  Why would I think about it?

18       Q.  Is there any other 35-year-old man that you

19   slept with when you were ten years old besides

20   Michael Jackson?

21       A.  Yes.

22       Q.  Who?

23       A.  My uncle.

24       Q.  All right.  A family member.

25       A.  Yeah.

26       Q.  Who else?

27       A.  That would probably be it.  I can’t recall

28   any others.

9183

1       Q.  All right.  Now, with whom do you live at

2   this time?

3       A.  My parents and my sister.

4       Q.  And both your parents?

5       A.  Yeah.

6       Q.  And that’s in Australia?

7       A.  Yes.

8       Q.  All right.  Did your father ever visit

9   Neverland with you?

10       A.  Yes, he did.

11       Q.  When your father visited Neverland with you,

12   where did you stay?

13       A.  Both in the guesthouse and both with him.

14       Q.  Both in the guesthouse and with Mr. Jackson?

15       A.  I stayed with Mr. Jackson, yeah.

16       Q.  Did you ever have a conversation with your

17   father about the propriety of sharing a bed with a

18   35-year-old man?

19       A.  Not that I recall.

20       Q.  Did you ever have a conversation with your

21   mother about that, whether that was a wise thing to

22   do, to share a bed with a 35-year-old man?

23       A.  Not that I recall.

24       Q.  Did he ever show you any sexually explicit

25   material?

26       A.  Absolutely not.

27           MR. MESEREAU:  Objection; beyond the scope.

28           THE COURT:  Overruled.  The answer is,

9184

1   “Absolutely not.”

2       Q.  BY MR. ZONEN:  Were you aware that he

3   possessed sexually explicit material?

4       A.  No.

5       Q.  Did you ever travel with Michael Jackson

6   anywhere?

7       A.  Yes, I did.

8       Q.  Where?

9       A.  South America, North America, Africa, and

10   Europe.

11       Q.  On those occasions —

12       A.  And Australia as well, I’m sorry.

13       Q.  On those occasions did you share a bed with

14   him?

15       A.  Yes.

16       Q.  Were any other people present while you were

17   in the room with him?

18       A.  I don’t recall.  I can’t — I can’t

19   remember.

20       Q.  Was your mother with you when you traveled

21   through South America?

22       A.  I think so.

23       Q.  You think so?

24       A.  Look, when I was young, I wasn’t really

25   thinking about this sort of stuff.  I wasn’t trying

26   to retain in my memory this sort of stuff.  And

27   what’s sad is that I traveled to all these countries

28   and I really don’t remember much of them.  So it’s

9185

1   all sort of — it’s all sort of meshed into one.

2       Q.  Mr. Barnes, how old were you when you

3   traveled through South America with Mr. Jackson?

4       A.  To tell the truth, I cannot remember.

5       Q.  You can’t tell whether you were 19 or 10?

6       A.  Well, I wasn’t 19.  It was in my middle

7   teens, maybe — no, it would have been in my

8   early — early teens.

9       Q.  12?

10       A.  It could have been possibly 12.

11       Q.  So you were 12 or 13.  You don’t know if

12   your mother was there with you when you traveled

13   through South America?

14       A.  She was, actually.

15       Q.  In fact, you traveled quite a bit with Mr.

16   Jackson without your mother being present; isn’t

17   that true?

18       A.  No.

19       Q.  Did you travel through North America with

20   Mr. Jackson without your mother?

21       A.  Yes.

22       Q.  And in how many cities through North America

23   did you go without your mother and Mr. Jackson?

24       A.  I’m not too sure.

25       Q.  Six or seven, perhaps eight?

26       A.  I couldn’t tell you.

27       Q.  Was he performing at the time, Mr. Jackson?

28       A.  For which?

9186

1       Q.  On the trip through North America, was he

2   performing?

3       A.  No, he wasn’t.

4       Q.  Did you travel with him when he was

5   performing?

6       A.  Yes.

7       Q.  Was that — in South America, was he

8   performing then?

9       A.  Yes.

10       Q.  And every night after the performance, you

11   would go with him to his room; is that correct?

12       A.  Yes.

13       Q.  And you stayed in his bed that night?

14       A.  Yep.

15       Q.  In North America when you traveled, your

16   mother was not there?

17       A.  Not — well, see, she went to some cities,

18   like we all went to some cities, and sometimes we —

19   I went.  Like on some of the occasions when I was

20   gone, coming over here alone, we’d go around.  But

21   sometimes when my whole family was there, we’d go

22   around, too.

23       Q.  How many times did you come to the United

24   States by yourself?

25       A.  Probably only two or three maybe.

26       Q.  And did Mr. Jackson arrange for that to

27   happen?

28       A.  He arranged for all of our trips.

9187

1       Q.  So all of the transportation for you and

2   your family from Australia to Neverland; is that

3   correct?

4       A.  Yeah.

5       Q.  And then all the travels that you did

6   through the United States and through South America?

7       A.  Uh-huh.  I was very fortunate.

8       Q.  I’m sorry?

9       A.  I was very fortunate.

10       Q.  When you slept with Mr. Jackson, what

11   generally did you wear?

12       A.  Sorry?

13       Q.  When you slept with Mr. Jackson in the same

14   bed, what would you wear?

15       A.  Pajama pants, T-shirt, pajama top sometimes.

16       Q.  Always?

17       A.  Well, always pajama pants, always a T-shirt.

18       Q.  And Mr. Jackson?

19       A.  Exactly the same thing.

20       Q.  Always pajamas and pajama bottoms?

21       A.  Uh-huh.

22       Q.  I’d like to show you a series of photographs

23   and tell me if you recognize them, the people in

24   this photo.  Let’s start with 893.

25       A.  Yep.

26       Q.  Who’s that?

27       A.  That’s me and him.

28       Q.  Are these Polaroids?

9188

1       A.  They look so.

2       Q.  Do you remember taking these pictures?

3       A.  Not at all.

4       Q.  Do you remember where you were?

5       A.  Not at all.

6       Q.  Can you tell us about how old you were?

7       A.  Probably about 11 maybe, 10.

8       Q.  I notice you’ve changed your hairstyle since

9   then, haven’t you?

10       A.  Yes.

11       Q.  You were about nine or ten.

12           So this was early on in your meeting with

13   Mr. Jackson; is that right?

14       A.  Yeah, I would say so.

15       Q.  All right.  This is 893, and that has two

16   photos on the front, and two photos on the back; is

17   that right?

18       A.  Yep.

19       Q.  And that’s you in the two photos in the back

20   as well?

21       A.  Yep.

22       Q.  All right.  892, is that you as well?

23       A.  Yep.

24       Q.  And Mr. Jackson?

25       A.  Yep.  Yep.

26       Q.  And the two on the back?  Do these appear to

27   have been taken at the same time?

28       A.  These?

9189

1       Q.  Yes.

2       A.  Yeah, I’d say so.

3       Q.  891, who is that?

4       A.  That’s Michael Jackson.

5       Q.  Did you take those pictures?

6       A.  Couldn’t tell you.

7       Q.  They appear to have been taken at the same

8   time; no?

9       A.  Possibly.

10       Q.  All right.  If I were to tell you that they

11   were all found together, would that suggest that

12   they were all taken at the same time?

13           MR. MESEREAU:  Objection; calls for

14   speculation.

15           THE COURT:  Sustained.

16       Q.  BY MR. ZONEN:  Turn it over, if you would,

17   to the back side.  Three more pictures on the back.

18   What are they?

19       A.  Of Michael Jackson.

20       Q.  Do you remember those pictures?

21       A.  Not at all.

22       Q.  Does that look familiar to you?

23       A.  No.

24       Q.  Mr. Barnes, did you take those photographs?

25       A.  I couldn’t tell you.  I don’t — I couldn’t

26   tell you, no.

27       Q.  890, two pictures on the front.  Would you

28   take a look at those two pictures?

9190

1       A.  Uh-huh.

2       Q.  One of those is you; is that right?

3       A.  Yes, it is.

4       Q.  You appear to be in bed.

5       A.  Uh-huh.

6       Q.  The other picture is what?

7       A.  Appears to be Michael Jackson.

8       Q.  And he’s in his underwear; is that right?

9       A.  Yes, it is.

10       Q.  889, is that you?

11       A.  Yes, it is.

12       Q.  And anything on the back?

13       A.  Yep.

14       Q.  Is that you as well?

15       A.  Yes, it is.

16       Q.  All right.  Do you remember those pictures?

17       A.  Don’t remember taking them, but I can tell

18   you where they were taken.

19       Q.  Where?

20       A.  They were taken at the ranch.

21       Q.  They were taken at the ranch?

22       A.  In a photo booth.

23       Q.  There’s a photo booth at the ranch on that

24   one there?

25       A.  Yep.

26       Q.  Do you recognize the background on any of

27   the other photographs?

28       A.  On these?

9191

1       Q.  Yes.

2       A.  No, I don’t.  No.

3       Q.  Are all of these photographs accurate

4   photographs of the subjects depicted within?  In

5   other words, the photographs of Mr. Jackson really

6   are Mr. Jackson and the photographs of you really

7   are you?

8       A.  That one’s a bit sketchy, but the rest,

9   yeah.

10       Q.  The one in his underwear?

11       A.  Yeah.

12       Q.  You’re not sure that’s him?

13       A.  Well, you can’t really see the face

14   properly.

15       Q.  Mr. Barnes, before coming from Australia,

16   did you speak with anybody about your testimony?

17       A.  No.

18       Q.  They simply flew you from Australia to

19   California?

20       A.  Well, they explained that I’d be a witness.

21       Q.  And then they interviewed you after you got

22   here?

23       A.  The interview?

24       Q.  Yes.  You had an interview with an

25   investigator —

26       A.  Yes.

27       Q.  — who works for Mr. Mesereau; is that

28   right?

9192

1       A.  Yes.

2       Q.  And that interview took place after you got

3   to California?

4       A.  Yes, it did.

5       Q.  So they had no way of knowing what you were

6   going to say while you were still in Australia?

7       A.  No.

8       Q.  Because they never talked with you at all?

9       A.  Not about the case, not being a witness.  I

10   signed a declaration.

11       Q.  You signed a declaration from where?

12       A.  From — I was at home.  Melbourne,

13   Australia.

14       Q.  Melbourne, Australia?

15       A.  Yeah.

16       Q.  All right.  So somebody wrote a declaration

17   and they sent it to you, is that right, in

18   Australia?

19       A.  Faxed it.

20       Q.  I’m sorry?

21       A.  Faxed it.

22       Q.  They faxed it you.  But you had to have

23   talked to somebody to tell them what to put in the

24   declaration, didn’t you do that?

25       A.  Yes, I did.

26       Q.  So you did talk with somebody while you were

27   in Australia?

28       A.  Yes.

9193

1       Q.  Who was the person that you talked with

2   while you were in Australia?

3       A.  It was Brian Oxman and some — I think it

4   might be Scott Ross as well.  But I’m not exactly

5   sure.

6       Q.  And then they prepared a declaration, they

7   sent it to you; is that correct?

8       A.  That’s correct.

9           MR. ZONEN:  Madam Clerk, could I have

10   another sticker that says….

11       Q.  Let me show you 894, four photographs on it.

12           MR. MESEREAU:  Excuse me, Counsel.  Are

13   these what I saw before?  Are these what you showed

14   me earlier?

15           MR. ZONEN:  Not the first set.  Let me show

16   you.

17       Q.  893, would you take a look at that, please,

18   both sides of that?

19       A.  Yep.

20       Q.  That contains a total of six pictures, two

21   on one side, four on the back; is that right?

22       A.  That’s correct.

23       Q.  And those are all pictures of you, one

24   picture of Mr. Jackson?

25       A.  Correct.

26       Q.  894?

27       A.  Uh-huh.

28       Q.  That’s who?

9194

1       A.  Michael Jackson.

2       Q.  All four of those pictures?

3       A.  Correct.

4       Q.  Do you recognize the location?

5       A.  No, I don’t.

6       Q.  You have no recollection of that?

7       A.  No.

8       Q.  Could that have been a hotel you stayed in?

9       A.  Quite possibly.

10       Q.  All right.  896?

11       A.  Uh-huh.

12       Q.  Does any of that look familiar to you?

13       A.  Is this New York?  I don’t remember any of

14   these pictures.

15       Q.  Do you remember any of those pictures being

16   taken?

17       A.  Not at all.

18       Q.  And your age, approximately, in those

19   photographs?

20       A.  I would have absolutely no idea.

21       Q.  You would have no idea at all?

22       A.  Well, these ones of me?

23       Q.  Yes.  You.

24       A.  Probably about the same age.

25       Q.  Okay.  Does it appear that those photographs

26   were taken about the same time?

27       A.  Purely speculation, but, yes.

28       Q.  Is your hairstyle the same as —

9195

1           MR. MESEREAU:  Objection; move to strike.

2           THE COURT:  Stricken.  Speculation.

3       Q.  BY MR. ZONEN:  Based on your familiarity

4   with yourself, does it appear that you are about the

5   same age in each of the photographs so far shown to

6   you?

7       A.  Yes.

8       Q.  And all those photographs are you with

9   Michael Jackson in a room someplace; is that right?

10       A.  Yes.

11       Q.  You have no recollection of when those

12   photographs were taken?

13       A.  Absolutely not.

14       Q.  And the pictures of Mr. Jackson, you have no

15   recollection of actually taking those yourself?

16       A.  Absolutely not.

17       Q.  Were there many occasions, when you were ten

18   years old, that you traveled by yourself with Mr.

19   Jackson?

20       A.  I wouldn’t say — well, I’m not sure I

21   understand the question.

22       Q.  Did you travel more than one trip with Mr.

23   Jackson when you were about the age of 10 by

24   yourself?

25       A.  Do you mean from my home?

26       Q.  Yes.

27       A.  Around?

28           I can’t really remember.  I can’t remember

9196

1   how many times.  It might have been one, might have

2   been two.  I can’t really tell you.

3       Q.  On the occasions when you traveled with Mr.

4   Jackson and he was on tour, did you go to all of the

5   concerts?

6       A.  I’m not sure.

7       Q.  Was there ever a woman traveling with Mr.

8   Jackson while you were traveling with him?

9       A.  A woman?

10       Q.  Yes.

11       A.  I’m not — what do you mean, though?

12       Q.  Somebody with whom he was close to.  I don’t

13   mean an assistant.  I mean a friend or a girlfriend.

14       A.  Not that I recall.

15       Q.  At the time that you were traveling with him

16   in South America, was he ever traveling with a

17   woman?  And I don’t mean an assistant.  A

18   girlfriend.

19           MR. MESEREAU:  Object as beyond the scope.

20           THE COURT:  Sustained.

21       Q.  BY MR. ZONEN:  Were there ever any other

22   people traveling with you as part of your unit?

23       A.  Where?

24       Q.  When you traveled.

25       A.  Sometimes.

26       Q.  Did any of them sleep in the same room with

27   you and Mr. Jackson?

28       A.  I can’t really recall.  I don’t remember.

9197

1       Q.  Did anyone ever share a bed with you and Mr.

2   Jackson, where there were three of you in the same

3   bed together?

4       A.  Can’t really remember.

5       Q.  Did your sister ever sleep with you in the

6   same bed and Mr. Jackson?

7       A.  Unfortunately, I can’t really remember that

8   either.

9       Q.  Do you know Wade Robson?

10       A.  Yes.

11       Q.  How well do you know Wade Robson?

12       A.  Not very.

13       Q.  Have you kept up some kind of friendship

14   with Mr. Robson?

15       A.  Nope.

16       Q.  Is that a “no”?

17       A.  That’s a “no.”

18       Q.  When was the last time you spoke with Mr.

19   Robson?

20       A.  Today.

21       Q.  All right.  Today you saw him.  When was the

22   last time prior to today?

23       A.  Yesterday.

24       Q.  Okay.  So you’ve been staying at Neverland,

25   have you?

26       A.  Yes.

27       Q.  Did you have an opportunity to talk with Mr.

28   Robson?

9198

1       A.  I had an opportunity, yeah.  Yeah.

2       Q.  And did you speak with Mr. Robson?

3       A.  Yes.

4       Q.  Did you discuss your testimony?

5       A.  Absolutely not.

6       Q.  And why not?

7       A.  Because it was explained to us that we were

8   not allowed to.

9       Q.  Who was that who told you that?

10       A.  The lawyers did.

11       Q.  Did they say why you weren’t allowed to?

12       A.  Isn’t it against the law?

13       Q.  Is that what they told you, it was illegal

14   to talk with each other?

15       A.  No, they didn’t.  They just explained that

16   it wasn’t — they just said, “Don’t talk about the

17   case.”

18       Q.  Were you aware of Wade Robson spending long

19   periods of time with Michael Jackson?

20           MR. MESEREAU:  Objection.  Beyond the scope;

21   relevance.

22           THE COURT:  Sustained.

23       Q.  BY MR. ZONEN:  Did Michael Jackson ever

24   speak to you about other boys who spent nights with

25   him in his room?

26           MR. MESEREAU:  Objection.  Beyond the scope;

27   relevance; foundation.

28           THE COURT:  Sustained.

9199

1       Q.  BY MR. ZONEN:  Did you ever talk with

2   Michael Jackson about the propriety of sharing a bed

3   with him?

4           MR. MESEREAU:  Objection.  Beyond the scope;

5   foundation; and relevance.

6           THE COURT:  Overruled.

7       Q.  BY MR. ZONEN:  Go ahead and answer the

8   question.

9       A.  Not that I recall.

10       Q.  At no time did you ever have a conversation

11   with Michael Jackson where the subject of the

12   conversation was whether or not you should be

13   sharing a bed with him?

14       A.  Not that I recall.

15       Q.  Did he ever tell you that you were like

16   family to him?

17       A.  All the time.

18       Q.  All the time.  Did he ever tell you that you

19   should trust him?

20       A.  Yeah.

21       Q.  Did he ever tell you that he was like a

22   father to you?

23       A.  He may have, yes.

24       Q.  Did he ever tell you that he considered you

25   to be like a son to him?

26       A.  Yes.

27       Q.  Was that something he frequently said to

28   you?

9200

1       A.  Not frequently.

2       Q.  Was that something that he frequently said

3   to you during the early stages of your relationship

4   when you were about age eight?

5       A.  Never met him when I was age eight.

6       Q.  You were about nine?

7       A.  Yeah.

8       Q.  Okay.  So how long after you had begun

9   visiting Neverland did Mr. Jackson speak to you in

10   such terms, tell you you were like family to him or

11   like a son to him?

12       A.  I couldn’t tell you.

13       Q.  Did he ever have a conversation with your

14   mother of that nature, tell your mother that he

15   considered her to be like family to him as well?

16       A.  Wouldn’t have a clue.

17       Q.  That was never done in your presence?

18       A.  Possibly.  I don’t remember.

19       Q.  Did your mother ever have a conversation

20   with him about anything in your presence?

21       A.  Quite possibly.

22       Q.  Is it the case that when you were kids and

23   running around Neverland, on occasion you would get

24   fairly rowdy?

25       A.  Nope.

26       Q.  You were always fairly well disciplined and

27   behaved?

28       A.  I was brought up right.

9201

1       Q.  How about the other kids who were at

2   Neverland while you were there?

3       A.  As far as I remember, yeah, we were all

4   pretty — there were a couple maybe, but I never

5   really saw an outbreak.

6       Q.  You never saw what?

7       A.  An outbreak.

8       Q.  An outbreak?

9           Who were the other boys who were there about

10   the time that you were there?

11       A.  I saw Mac there, Macaulay Culkin.  His —

12   Levon and Elijah.  Frank, Eddie, Dominick —

13       Q.  How old was Frank at the time?

14           MR. MESEREAU:  Objection.  He hasn’t

15   finished his answer yet, Your Honor.

16           THE COURT:  Sustained.

17       Q.  BY MR. ZONEN:  Go ahead.

18       A.  Aldo.  Marie Nicole.  My sister, of course.

19   That’s all I really remember.

20       Q.  Of the ones that you’ve mentioned, how many

21   of them shared Michael Jackson’s bedroom while you

22   were there?

23       A.  All of them have.

24       Q.  Did — all of them?

25       A.  I’m pretty sure.

26       Q.  On how many nights do you think, all at the

27   same time?

28       A.  Not at the same time, because like one trip

9202

1   we’d see — we saw Mac, and the other trips we saw

2   everyone else.

3       Q.  And would they share the same bed with you

4   and Mr. Jackson?

5       A.  I can’t honestly recall that.

6       Q.  Do you remember any of those people who you

7   just mentioned sharing a bed with Mr. Jackson in

8   your presence?

9       A.  Yeah.

10       Q.  Who?

11       A.  Mac.

12       Q.  Macaulay Culkin?

13       A.  Yeah.

14       Q.  Who else?

15       A.  Frank.

16       Q.  Frank Cascio?

17       A.  Yeah.

18       Q.  How old was Frank Cascio at the time?

19           MR. MESEREAU:  Objection.  He hasn’t

20   finished his answer yet.

21           THE WITNESS:  Eddie.

22           THE COURT:  I can’t tell if he has or not.

23           Have you finished your answer?

24           THE WITNESS:  No, I haven’t.

25           THE COURT:  Go ahead.

26           THE WITNESS:  Eddie.  That’s probably —

27   that’s all I can recall.

28       Q.  BY MR. ZONEN:  “Eddie” is Eddie who?

9203

1       A.  Cascio.

2       Q.  That’s Frank’s brother?

3       A.  Yeah.

4       Q.  How old was Frank at that time?

5       A.  Wouldn’t be able to tell you.

6       Q.  Well, was he a child?

7       A.  I never knew him as a child.  He’s — he’s

8   older than me, so….

9       Q.  You only know Frank Cascio as an adult?

10       A.  No.  He’s like a year older, two years older

11   than me.

12       Q.  You said you never knew him as a child?

13       A.  Well, as a child, I consider to be under the

14   age of 10.

15       Q.  How about as a young teenager?

16       A.  Yeah.

17       Q.  So you saw him there as a young teenager?

18       A.  Yeah.

19       Q.  Would he share Michael Jackson’s bed as

20   well?

21       A.  If I recall correctly, yeah.

22       Q.  And Eddie, how old was Eddie during that

23   time?

24       A.  Like he’s — it would have been a young

25   teenager as well.

26       Q.  What’s the longest period of time that any

27   of those people stayed in Michael Jackson’s room

28   while you were there?  In other words, how many

9204

1   consecutive days did that happen?

2       A.  Can’t recall properly.

3       Q.  Did Michael Jackson ever tell you that he

4   loved you?

5       A.  Yeah, all the time.

6       Q.  Did he ever touch you?

7       A.  In what manner?

8       Q.  Did he ever kiss you?

9       A.  On the cheek, on the forehead, yeah.

10       Q.  Often?

11       A.  I wouldn’t say often, but, yeah.  I’ve —

12   I can’t really remember these things.  It’s not

13   something that would — you know, I would try to

14   remember.

15           MR. ZONEN:  I have no further questions.

16           MR. MESEREAU:  I have no further questions,

17   Your Honor.

18           THE COURT:  All right.  Thank you.  You may

19   step down.

20           I think we’ll start the next witness

21   tomorrow.

22           (To the jury)  I’ll see you tomorrow at

23   8:30.  Remember the admonition.  Have a good

24   evening.

25           (The proceedings adjourned at 2:30 p.m.)

26                             –o0o–

27

28

9205

1                    REPORTER’S CERTIFICATE

2

3

4   THE PEOPLE OF THE STATE OF      )

5   CALIFORNIA,                    )

6                 Plaintiff,        )

7           -vs-                   )  No. 1133603

8   MICHAEL JOE JACKSON,           )

9                Defendant.        )

10

11

12           I, MICHELE MATTSON McNEIL, RPR, CRR, CSR

13   #3304, Official Court Reporter, do hereby certify:

14           That the foregoing pages 9016 through 9205

15   contain a true and correct transcript of the

16   proceedings had in the within and above-entitled

17   matter as by me taken down in shorthand writing at

18   said proceedings on May 5, 2005, and thereafter

19   reduced to typewriting by computer-aided

20   transcription under my direction.

21              DATED: Santa Maria, California,

22   May 5, 2005.

23

24

25

26

27           MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304

28           OFFICIAL COURT REPORTER

9206