March 14th, 2005 Trial Analysis: Gavin Arvizo (Cross Examination), Part 1 of 4
There was no witness testimony on Friday, March 12th, and Mesereau’s cross examination of Gavin resumed on March 14th. He challenged Gavin’s previous statements that Jackson told him that “men must masturbate”, when he initially told detectives that it was his grandmother who told him that! When Gavin realized that he was caught in his own lie, he tried to explain that it was a weird coincidence that Jackson first taught him that, and then after escaping from Neverland his grandmother just happened to teach him the same thing, but not in the same exact words! Gavin tried to cover his lies by saying that he was “sure” that he told detectives in another interview that Jackson told him to masturbate!
21 CROSS-EXAMINATION (Continued)
22 BY MR. MESEREAU:
23 Q. Mr. Arvizo, on Thursday you testified about
24 how you learned what masturbation was. Remember
26 A. I believe so.
27 Q. Pardon me.
28 A. I believe so. 1797
1 Q. Okay. And you testified that Mr. Jackson
2 told you what masturbation is, right.
3 A. Uh-huh.
4 Q. Is that true.
5 A. Yes.
6 Q. And you testified to the jury that Mr.
7 Jackson said that if men don’t masturbate, that they
8 can get to a level where they can — might rape a
9 girl. Remember that.
10 A. Uh-huh.
11 Q. Do you remember saying that.
12 A. Yes.
13 Q. Do you remember being interviewed by the
14 Santa Barbara Sheriff’s Department on a number of
16 A. Yes.
17 Q. And do you remember who interviewed you.
18 A. Most likely Steve Robel or Paul Zelis.
19 Q. Do you remember being asked, “Before we get
20 started on the next set of questions, can you
21 describe to us what your opinion is, what you think
22 masturbation is.” Do you remember one of the
23 sheriffs asked you that during an interview.
24 A. I believe so.
25 Q. And you knew those interviews were being
26 recorded, right.
27 A. Yes.
28 Q. Remember you said, “My grandma explained it 1798
1 to me. She told me that — that your — the only
2 reason is because like if — if men don’t do it, men
3 might get to a point where they might go ahead and
4 rape a woman”. Do you remember saying that to the
6 A. I believe so.
7 Q. Why did your story change between that
8 interview and your testimony last Thursday.
9 A. Well, what do you mean “changed”.
10 Q. Well, you told the police your grandmother
11 made that quote to you, and you came into court
12 under oath and told the jury Mr. Jackson made that
13 quote to you.
14 A. That didn’t change. Because Michael tried
15 to explain to me first. And I — he was more
16 pushing on me that men have to masturbate.
17 Now, later when I came back from Neverland,
18 I guess my grandmother saw that I was very confused
19 about sexuality and things like that. And my
20 grandmother explained to me a lot of things.
21 Q. So it just so happened that after Mr.
22 Jackson told you, “If a man doesn’t do it, they may
23 get to a point where they rape a woman,” your
24 grandmother made the almost identical quote to you.
25 Is that what you’re saying.
26 A. Not really. She didn’t make the same exact
27 thing that Michael said. But I’m not exactly sure
28 what my grandmother said. I know my grandmother 1799
1 explained a lot of things to me.
2 Q. Would it refresh your recollection if I show
3 you a transcript of your sheriff’s interview.
4 A. Probably.
5 MR. MESEREAU: May I approach, Your Honor.
6 THE COURT: Yes.
7 MR. MESEREAU: Whoops, I’m sorry.
8 Your Honor, I spilled a little water with my
9 notebook, so —
10 THE BAILIFF: How about you put that over
12 Q. BY MR. MESEREAU: Mr. Arvizo, have you had a
13 chance to look at that page of transcript.
14 A. Yes.
15 Q. Does it refresh your recollection about what
16 you told the sheriffs about what masturbation was.
17 THE COURT: Just a moment, Counsel.
18 THE WITNESS: It refreshes my —
19 THE COURT: Just a moment. Let’s take care
20 of one thing at a time.
21 You may start again on that.
22 MR. MESEREAU: Yes, thank you, Your Honor.
23 Q. Mr. Arvizo, have you had a chance to look at
24 that page of transcript of your sheriff’s interview.
25 A. Uh-huh.
26 Q. Does it refresh your recollection about what
27 you told the sheriffs your grandmother said.
28 A. It refreshes — I can recall what my 1800
1 grandmother was telling me. She was — she saw that
2 I was embarrassed about things like masturbation and
3 growing up, and my mother was telling me that it’s
4 okay to do it. And Michael was telling me that you
5 have to do it.
6 Q. Well, Mr. Arvizo, I understand your
7 position. But when the sheriffs asked you what
8 masturbation was, you didn’t say, “Mr. Jackson told
9 me if a man doesn’t do it, he may rape a woman.”
10 You said if — “My grandmother told me that if a man
11 doesn’t do it, he may rape a woman,” correct.
12 A. I believe so. That’s what you showed me.
13 But —
14 Q. And between the time of that interview —
15 MR. SNEDDON: Excuse me.
16 Your Honor, he was about to say something
17 when he got cut off by counsel.
18 MR. MESEREAU: Oh, I apologize. I had no
20 THE WITNESS: But —
21 MR. MESEREAU: Excuse me. Go ahead.
22 THE WITNESS: But that still doesn’t mean
23 that Michael did not tell me.
24 Q. BY MR. MESEREAU: But what you’re telling
25 the jury is it was sort of a coincidence that both
26 your grandmother and Michael used almost the
27 identical phrase about raping a woman.
28 A. Both my grandmother and Michael were trying 1801
1 to talk to me about the — pretty much the birds and
2 the bees story.
3 Q. Okay. And they pretty much said the
4 identical thing, is that what you’re telling me.
5 A. Not exactly.
6 Q. Not exactly.
7 A. No.
8 Q. Well, the quotes are almost identical,
9 aren’t they.
10 A. You see, Michael was trying to tell me that
11 I have to masturbate. My mom — my grandmother was
12 actually telling me — giving me the talk. Michael
13 was just talking about masturbation.
14 Q. But your grandmother said to you, “If men
15 don’t do it, men might get to a point where they
16 might go ahead and rape a woman,” correct.
17 A. Michael also told me that.
18 Q. Well — so you’re saying they basically said
19 the same thing.
20 A. My grandmother said it’s okay to do it,
21 because sometimes, some men, they can’t control
22 themselves and might do that.
23 Q. But in that police interview, you never
24 mentioned that Michael Jackson had said that to you,
25 did you.
26 A. I’m sure in one of the other transcript I
27 mentioned about Michael.
28 Q. Not in that interview, correct. 1802
1 A. But I’m sure in another one I did.
Here is what Gavin said during his grand jury testimony about his grandmother teaching him about masturbation:
Next, Mesereau questioned Gavin about his memory of the facts of the JC Penney case; Gavin denied speaking about the case with his mother, which is a bald faced lie because, according to his father David, Janet gave her children scripts to memorize for their deposition! You can read about it in this document in pages 7-25.
2 Q. Okay. I’d like to ask you just about the
3 allegations in the J.C. Penney case, okay. We’re
4 not going to go into the evidence, just what the
5 allegations were. Okay.
6 A. Uh-huh.
7 Q. Do you remember that case.
8 A. Uh-huh.
9 Q. And you and your mother Janet sued J.C.
10 Penney, correct.
11 A. I think we did. I’m pretty sure we did.
12 Q. Okay. And originally your family sued for
13 battery, false imprisonment and infliction of
14 emotional distress, right.
15 A. I don’t know.
16 Q. Okay. Later on, your mother amended the
17 complaint to add sexual assault. Do you remember
19 A. Not really.
20 Q. Do you remember that you were asked
21 questions about that in a sworn deposition.
22 A. I don’t remember being asked about my mom
23 being — whatever.
24 Q. Do you remember being asked questions about
25 your mother’s allegations that J.C. Penney guards
26 fondled her breasts in a parking lot.
27 MR. SNEDDON: Your Honor, I’m going to
28 object; 403. 1803
1 THE COURT: Sustained.
2 Q. BY MR. MESEREAU: Do you remember that case
3 at all.
4 A. Um, a little bit. I mean, I was in the
5 middle of my chemotherapy.
6 Q. Okay. Your chemotherapy was going on at the
7 same time.
8 A. At the same time as those depositions.
9 Q. Okay. And how many — how many appointments
10 for chemotherapy had you had at that point, if you
12 A. They would have it once a month — once
13 every three weeks, actually. Then I had ten rounds.
14 And I wasn’t like a regular kid that had cancer that
15 would just go in for a few hours and get one bag of
16 chemotherapy. I would go there for a week, in the
17 hospital, and — in a bed, and they would give me
19 Q. Okay. And approximately when did the
20 chemotherapy end.
21 A. June 2001.
Next, Mesereau questioned Gavin about the discrepancy between his timeline of being abused by Jackson, first within a few days of leaving Neverland, and then within a few weeks of leaving Neverland. Gavin denied that he spoke in detail to Sneddon about the case to refresh his memory over the long weekend, but admitted that they talked for “around 15 minutes” about Gavin’s “history”. Gavin was very coy, so Mesereau specifically asked Gavin if he spoke with Sneddon about his former teachers, and Gavin finally admitted that he had.
During their meeting, Sneddon asked Gavin about Mr. Geralt, and Gavin claimed that he told Sneddon about some of the disciplinary problems that he had when he was in his class a few years prior. When asked by Mesereau if there was anything else he discussed with Sneddon, Gavin initially couldn’t remember, but then Mesereau reminded him of their discussion of Mr. Alpert, the Dean of Gavin’s middle school. On Saturday, March 12th, Sneddon had a meeting with Mr. Alpert, and in it Mr. Alpert stated that Gavin twice denied being abused by Jackson when he was called into his office, shortly after the airing of the documentary. The reason that Sneddon and his prosecution team met with Gavin over the weekend is because they were totally unaware Mr. Alpert’s claims, and they notified Gavin at 5:00PM to let him know of their emergency meeting for later that night.
Gavin claimed that he told Sneddon that he “believed” he had a conversation with Mr. Alpert, but he “really didn’t remember too good”. However, Mesereau challenged him, and Gavin finally admitted that he indeed told Mr. Alpert that Jackson had not abused him.
Here is how the media reported this bombshell information:
Potential Surprise Witness in Jackson Trial
March 14, 2005
Prosecutors and defense attorneys in the molestation trial of Michael Jackson have interviewed a former teacher of the alleged victim, and sources tell ABC News that the teacher claims that the accuser told him that “nothing happened” between himself and “The King of Pop.”
The 15-year-old alleged victim return to the stand for cross-examination as testimony resumed today in Jackson’s trial. The boy, who was 13 at the time he was allegedly molested by Jackson, spent time at the singer’s Neverland ranch in California and appeared with him on the 2003 British documentary “Living With Michael Jackson.” Jackson, 46, has pleaded not guilty to 10 charges that include felony conspiracy with 28 overt acts involving child abduction, false imprisonment and extortion.
In a secret meeting on Saturday, Santa Barbara County, Calif., prosecutor Tom Sneddon and Jackson’s defense attorneys interviewed the teacher from Burroughs Middle School in Los Angeles, where the alleged victim was a student while he and Jackson were friends. According to sources, the teacher said that the young accuser told him in the spring of 2003 — after “Living With Michael Jackson” aired and after the alleged molestation occurred — that “nothing had happened between Michael Jackson and him.”
Thomas Forsyth, an attorney for the teacher, said the interview lasted approximately one hour and that he expects his client to be called as a witness. In testimony today, Jackson attorney Thomas Mesereau Jr. confronted the alleged victim in cross-examination about what he told the teacher, who was identified in court as Jeffrey Alpert. The boy admitted telling Alpert, “Michael didn’t do anything to me.”
22 Q. Okay. Do you remember last Thursday I asked
23 you when these alleged acts of masturbation by
24 Michael Jackson occurred. Do you remember that.
25 A. Uh-huh.
26 Q. And within an approximately 20-minute period
27 you first said a couple of days before you left with
28 Jose Salas, right. 1804
1 A. What do you mean.
2 Q. Jesus Salas, excuse me.
3 A. Couple days before I left with Jose Salas.
4 Q. Yes. You said a couple of days before you
5 left Neverland with Jose Salas the masturbation
6 occurred. Do you remember that.
7 A. No, I did not say that.
8 Q. You didn’t say that.
9 A. No, I said that it happened approximately
10 the last two weeks of when we left Neverland for
12 Q. Well, first you said a few days, and then
13 you said a week, and then you said a couple of
14 weeks, right.
15 A. Maybe you said that it was a few days.
16 Q. Did you discuss over the weekend these facts
17 with anybody.
18 A. No.
19 Q. Did you discuss the case with anybody over
20 the weekend.
21 A. I had a brief conversation with Mr. Sneddon.
22 Q. Okay. And what did you talk about.
23 A. We talked about certain things that you
24 might ask me.
25 Q. And like what.
26 A. Just things about me.
27 Q. Pardon me.
28 A. Things that you might ask about me. 1805
1 Q. Like what.
2 A. Like my history.
3 Q. Your history.
4 A. Uh-huh.
5 Q. And what do you mean, your “history”.
6 A. In school maybe.
7 Q. Pardon me.
8 A. In school maybe.
9 Q. And what did Mr. Sneddon say to you about
11 A. He just told me to answer honestly.
12 Q. And what else did he talk to you about.
13 A. That’s pretty much it right there.
14 Q. How long was the discussion.
15 A. 15 minutes.
16 Q. Did he say anything to you about an
17 interview he had with a witness over the weekend.
18 A. With a witness besides me.
19 Q. Yes.
20 A. No.
21 Q. Did he ask you anything about one of your
22 teachers at school.
23 A. Um, yes. He asked me about it.
24 Q. And who was that.
25 A. My teacher.
26 Q. Yes.
27 A. It’s — he wasn’t really my teacher. His
28 name is Richard Geralt. 1806
1 Q. What did Mr. Sneddon say to you about
2 Mr. Geralt.
3 MR. SNEDDON: I’m going to object. It
4 assumes facts not in evidence that I said anything.
5 MR. MESEREAU: I’ll rephrase the question,
6 Your Honor.
7 THE COURT: All right.
8 Q. BY MR. MESEREAU: Did Mr. Sneddon say
9 something to you about Mr. Geralt.
10 MR. SNEDDON: Same objection.
11 THE COURT: Overruled.
12 THE WITNESS: Can you repeat the question.
13 Q. BY MR. MESEREAU: Did Mr. Sneddon say
14 anything to you over the weekend about Mr. Geralt.
15 A. He didn’t have to tell me anything. I told
16 him everything. I told him the facts about Mr.
18 Q. Let me ask the question again. Did Mr.
19 Sneddon over the weekend say anything to you about a
20 Mr. Geralt.
21 A. He asked me about Mr. Geralt, so it’s kind
22 of knowing, I guess.
23 Q. What did he ask you about Mr. Geralt.
24 A. He asked me what do I know of Mr. Geralt.
25 Q. And did you tell him.
26 A. Yes.
27 Q. What did you tell him.
28 A. I told him about — that I knew Mr. Geralt. 1807
1 Q. Excuse me.
2 A. I told him that I knew of Mr. Geralt.
3 Q. Did you tell him anything else.
4 A. About Mr. Geralt.
5 Q. Yes.
6 A. I told him about school and how Mr. Geralt
8 Q. And what did you tell him.
9 A. About Mr. Geralt.
10 Q. Yeah. What did you tell him about Mr.
11 Geralt and school.
12 A. I told him that — about a time when he —
13 he was a detention teacher. And I had detention,
14 and I was in there.
15 Q. Pardon me.
16 A. I was in his detention.
17 Q. Okay. What else did you tell Mr. Sneddon
18 about Mr. Geralt.
19 A. I told him that one time when I was in
20 detention, I was sitting there, and he told us we
21 had to do work, our homework. I didn’t have a
22 pencil. So I asked him, “Mr. Geralt, may I have a
23 pencil.” And then he put me against the wall,
24 because I asked if I could have a pencil.
25 Q. Did you tell Mr. Sneddon anything else about
26 Mr. Geralt.
27 A. Uh-huh.
28 Q. What else. 1808
1 A. That sometimes in the middle of his class he
2 would go outside and smoke a cigarette.
3 Q. What else.
4 A. Um, that he always tried to handle his
5 classes as if he was a drill sergeant.
6 Q. Okay. What else.
7 A. I told him a story about — that detention.
8 Q. Okay. What did you tell him.
9 A. I told him there was one time that I was in
10 detention, same — and then when I was against the
11 wall, I asked Mr. Geralt, “Why is it that I’m
12 against the wall. I would like to do my work as you
13 told me to do.”
14 Q. What else did you tell Mr. Sneddon.
15 A. And then Mr. Geralt asked me, he said if I
16 was on drugs. He said that if I was on — doing
17 marijuana or doing crack or something, and he told
18 me he was going to give me a drug test.
19 Q. What else did you tell Mr. Sneddon.
20 A. I told him that I was — “Mr. Geralt, I’m
21 not on drugs.” And then Mr. Geralt said that he’s
22 going to call the cops, and this and that, because
23 he was saying that I was on drugs. But he was doing
24 it in a way that he was making fun of me.
25 Q. Now, Mr. Geralt was a teacher, correct.
26 A. He was a teacher at the school.
27 Q. At what school.
28 A. John Burroughs Middle School. 1809
1 Q. Did you tell Mr. Sneddon anything else about
2 Mr. Geralt.
3 A. Yes.
4 Q. What else did you tell him.
5 A. I — then I told Mr. Geralt that, “Why is it
6 that you’re going to call a police officer here who
7 would rather be doing something more important than
8 something as my minute and dumb as this.”
9 Q. And anything else you told Mr. Sneddon about
10 Mr. Geralt.
11 A. And then after I told Mr. Geralt that, he
12 realized that I was right, and he put his phone
13 away. And then he called the campus supervision.
14 And then he kept on going on that I was doing drugs
15 and this and that. He said he — he was just saying
16 stuff like that.
17 And then he went into — he called campus
18 supervision, and then they took me into the office.
19 And then I told the teachers what happened, and they
20 said they know how Mr. Geralt is.
21 Q. Did you tell Mr. Sneddon anything else when
22 you spoke to him over the weekend.
23 A. No. We talked about a lot — we talked
24 about a few things. I don’t remember too much.
25 Q. You don’t remember too much.
26 A. Well, I do, and — I don’t remember the
27 exact things, I mean, word for word.
28 Q. Why don’t you just tell us generally what 1810
1 you talked about.
2 A. My history, mostly.
3 Q. Pardon me.
4 A. My history.
5 Q. Your history.
6 A. Yes.
7 Q. Please tell the jury what you told Mr.
8 Sneddon about your history.
9 A. I just told you.
10 Q. Anything else come up in that discussion.
11 A. Yeah.
12 Q. What else.
13 A. Are you trying to specify something.
14 Q. No, I’m just simply asking you to tell the
15 jury what you told Mr. Sneddon when you spoke to him
16 over the weekend about your testimony in this case.
17 A. Please be specific.
18 Q. Well, I’m just asking you. I wasn’t in the
19 conversation. What else do you remember. Please
20 tell the jury anything else that was discussed.
21 A. Talked about my father.
22 Q. Did you talk about a Mr. Alpert.
23 A. Oh, yes. Yes, we did.
24 Q. Did I just jog your memory a little bit
25 about that.
26 A. Yes.
27 Q. Did Mr. Sneddon tell you he had been in an
28 interview with a Mr. Alpert on Saturday. 1811
1 A. Yes. Well, I don’t know if — no, he said
2 if I was — if Mr. — the dean, Alpert, interviewed
3 me or talked to me.
4 Q. And did he ask you questions about any
5 discussions you ever had with Dean Alpert at John
6 Burroughs School.
7 A. Yeah, he asked some questions about it.
8 Q. In fact, Mr. Arvizo, he asked you whether
9 you had been interviewed by Dean Alpert and whether
10 you had confessed to him that Mr. Jackson never did
11 anything to you of a sexual nature, right.
12 A. Yeah.
13 Q. Why didn’t you say that at the beginning.
14 A. I told Mr. Alpert that he didn’t do anything
15 to me.
16 Q. You told Dean Alpert that twice, correct.
17 A. I don’t know how many times I told him.
18 Q. Well, that was the reason Mr. Sneddon
19 telephoned you, wasn’t it, as far as you knew.
20 A. What do you mean.
21 Q. Mr. Sneddon telephoned you —
22 A. Oh, telephoned.
23 Q. — to ask you whether you had ever confessed
24 to Dean Alpert that Michael Jackson never did
25 anything to you of a sexual nature, right.
26 A. I don’t remember Mr. Sneddon calling me and
27 asking me that question.
28 Q. You don’t recall Mr. Sneddon asking you any 1812
1 questions like that over the weekend.
2 A. Over the weekend, if Michael had done
3 anything to me.
4 Q. No, Mr. Arvizo. Let me just — let me just
5 try and rephrase it, if I have confused you.
6 Mr. Sneddon called you over the weekend,
8 MR. SNEDDON: Your Honor, I’m going to
9 object. That’s a misstatement of his testimony and
10 it assumes facts not in evidence that I called him.
11 THE COURT: Sustained.
12 Q. BY MR. MESEREAU: Did Mr. Sneddon telephone
13 you over the weekend.
14 A. No, he did not.
15 Q. Did you telephone Mr. Sneddon over the
17 A. No, I did not.
18 Q. Did you engage in a conversation with Mr.
19 Sneddon over the weekend.
20 A. Yes, I did.
21 Q. Where did that conversation take place.
22 A. In a house.
23 Q. Okay. Did Mr. Sneddon come to see you.
24 A. No.
25 Q. Did you go to see Mr. Sneddon.
26 A. Yes.
27 Q. Where did you go to see Mr. Sneddon.
28 A. In a house. 1813
1 Q. In his house.
2 A. In a house.
3 Q. Okay. Who was with you, if anybody.
4 A. Detective Robel. Mr. — Ron, Gordon and
5 Mr. Sneddon, and I believe Mr. Mag was there.
6 Q. Okay. Let me just get it straight. Mr.
7 Robel was there from the Santa Barbara Sheriffs,
9 A. Yes.
10 Q. Mr. Sneddon was there, right.
11 A. The attorneys were there.
12 Q. Prosecutors. Prosecutor Zonen was there,
14 A. All of the district — all of the attorneys
15 were there.
16 Q. Prosecutor Auchincloss was there, right.
17 A. Auchincloss.
18 Q. Yes. The fellow seated right to my left.
19 A. Oh, Gordon, yeah.
20 Q. Anyone else there besides those four.
21 A. Mag.
22 Q. Who.
23 A. Mag. I don’t know his full name.
24 Q. Okay. Is this another sheriff.
25 A. No, this is an attorney.
26 Q. Another prosecutor.
27 A. He’s another attorney.
28 Q. So you met with four prosecutors and a Santa 1814
1 Barbara Sheriff over the weekend, right.
2 MR. SNEDDON: Your Honor, I’m going to
3 object again. It assumes facts not in evidence that
4 all of those people were present during the meeting.
5 MR. MESEREAU: I think that’s what he just
7 MR. SNEDDON: No, he didn’t.
8 THE COURT: Sustained.
9 Q. BY MR. MESEREAU: Did you meet over the
10 weekend with three prosecutors.
11 A. No.
12 Q. Did you meet with four prosecutors.
13 A. No.
14 Q. Did you meet with any prosecutors.
15 A. Yes.
16 Q. Who were they.
17 A. One, Mr. Sneddon. And Steve Robel — and
18 Detective Steve Robel was present.
19 Q. Okay. Was anyone else present.
20 A. They were there, but they were in another
22 Q. Okay. Who was there but in another room.
23 A. Ron, Mr. Zonen, Gordon and Mag.
24 Q. Okay. I’m not hearing that. Is it Meg or
26 A. Mag.
27 Q. Mag. Okay. And as far as you know, Mag’s a
28 prosecutor, correct. 1815
1 A. Yes, I believe so.
2 Q. Okay. Now, what day did you have this
4 A. I believe it was yesterday.
5 Q. And approximately what time did the meeting
6 take place.
7 A. 6:00, maybe 7:00.
8 Q. So that would be last evening, right.
9 A. Uh-huh.
10 Q. Did you learn in advance that the meeting
11 was going to take place.
12 A. A couple hours before.
13 Q. And how did you learn the meeting was going
14 to take place.
15 A. They — they told me.
16 Q. Okay. Who’s “they”.
17 A. Detective Steve Robel told me.
18 Q. Okay. Did he call you on the phone.
19 A. No, he told me.
20 Q. Did he call you on the phone.
21 A. He told me.
22 Q. Okay.
23 A. No, did he not call me on the phone.
24 Q. Did you call him on the phone.
25 A. No.
26 Q. Did he show up at your house.
27 A. No. I don’t live up here.
28 Q. I’m just trying to ask you how you found out 1816
1 about the meeting. That’s all I’m asking.
2 A. I told you, he told me.
3 Q. Okay. Where did he tell you about the
5 A. He told me at a house.
6 Q. Where you’re staying, right.
7 A. Yes.
8 Q. Okay. Did he come to the house.
9 A. Yes.
10 Q. Okay. Approximately what time did Mr. Robel
11 come to the house to tell you there was going to be
12 a meeting that evening with all the prosecutors.
13 MR. SNEDDON: Your Honor, I’m going to
14 object to that question. There was no meeting with
15 all those prosecutors. Misstatement of his
17 MR. MESEREAU: I’ll rephrase it, Your Honor.
18 THE COURT: All right.
19 Q. BY MR. MESEREAU: Mr. Arvizo, at
20 approximately what time yesterday did you learn you
21 were going to travel to another location to meet
22 with Mr. Sneddon and others.
23 A. Um, other — it was around maybe 5:00 or
24 something like that.
25 Q. Okay. And you obviously attended the
26 meeting, right.
27 A. Yes.
28 Q. Do you know if the conversation was 1817
2 A. I don’t believe it was recorded.
3 Q. Do you know if anyone was taking notes.
4 A. Um, no, I don’t think anyone was taking
6 Q. Okay. Did anyone tell you what the purpose
7 of the meeting was.
8 A. No.
9 Q. No one explained why you were having a
10 meeting last night.
11 A. No. They told me that Tom was going to have
12 to talk to me about some things.
13 Q. Okay. And Mr. Sneddon did talk to you about
14 some things, correct.
15 A. Yes.
16 Q. And he talked to you about an interview that
17 had been conducted on Saturday, right.
18 A. No.
19 Q. Did Mr. Sneddon ever tell you he had
20 conducted an interview with a Mr. Alpert on
22 A. No, did he not tell me that he conducted an
24 Q. Okay. Did he ever tell you he had spoken
25 with Mr. Alpert.
26 A. Yes.
27 Q. And what did he say about that.
28 A. He asked me about Mr. Alpert. 1818
1 Q. Okay.
2 A. What I knew.
3 Q. And did he ask you if you ever had a meeting
4 with Mr. Alpert, correct.
5 A. Yes.
6 Q. And you told him you did, right.
7 A. Yes.
8 Q. You told him you met —
9 A. I told him that I’m pretty sure I did — I
10 did. Because I didn’t really remember too good.
11 Q. You didn’t remember too good that you had
12 told Mr. Alpert that Mr. Jackson had never touched
13 you sexually.
14 A. Well, I believe it happened, because he was
15 a dean of the school. And so — I’m pretty sure I
16 had a conversation with him.
17 Q. Okay. And did you tell Mr. Sneddon you were
18 pretty sure you had had a conversation with Dean
19 Alpert at John Burroughs School.
20 A. Yes.
21 Q. Did you tell Mr. Sneddon approximately when
22 you had that discussion.
23 A. No.
24 Q. Did Mr. Sneddon ever ask you when you had
25 that discussion.
26 A. No.
27 Q. Where did the discussion with Dean Alpert
28 take place. 1819
1 A. I don’t remember. It was probably in his
3 Q. Okay. And the purpose of the discussion was
4 what, if you know.
5 A. It was probably about Michael.
6 Q. Okay. You say “probably about Michael”.
7 A. Uh-huh.
8 Q. But you’re not sure.
9 A. I’m not sure what the whole conversation was
11 Q. Okay. But sometime in that conversation,
12 Dean Alpert looked you in the eye and said, “Are
13 these allegations that Mr. Jackson sexually abused
14 you true,” right.
15 A. Uh-huh.
16 Q. And you said they were not true, right.
17 A. Yeah. I told him that Michael didn’t do
18 anything to me.
19 Q. Okay. Mr. Alpert asked you twice whether or
20 not Michael Jackson had ever done anything of a
21 sexual nature to you, correct.
22 A. I don’t know if he asked me twice.
23 Q. Well, the first time he asked you, you shook
24 your head “No,” right.
25 A. I don’t know.
26 Q. And the second time he asked you, you said
27 to him, “No, he did not touch me in any sexually
28 inappropriate way,” correct. 1820
1 A. I don’t know.
2 Q. You don’t know.
3 A. I’m pretty sure I told him that.
4 Q. Okay.
5 A. But, I mean, I don’t know how exactly it
Mesereau then pivoted back to Mr. Geralt, and when he asked Gavin if he had some disciplinary problems, Gavin answered that he had a LOT of disciplinary problems! Mesereau’s goal was to show that Gavin was street tough, and capable of lying and being disruptive, and was not the perfect angel that the media painted him as. Gavin admitted to fighting and talking out lout, among other things. He also claimed to have been an advisor to the ROTC club, and admitted that he had issues with other students in the club. Gavin also rationalized his disrespect towards Mr. Geralt by saying that Mr. Geralt “brought himself down to Gavin’s level” by accusing him of being on drugs during an afterschool detention session.
7 Q. Okay. Now, based on what you’ve already
8 said, you also discussed a teacher named Geralt,
10 A. Yes.
11 Q. When I started asking you questions about
12 your discussion with Mr. Sneddon, the first person
13 you mentioned was Mr. Geralt, correct.
14 A. Yes.
15 Q. Mr. Geralt was also a teacher at the school,
17 A. Yes.
18 Q. Okay. And in summary, you had some
19 disciplinary problems with Mr. Geralt, right.
20 A. I had a lot of disciplinary problems.
21 Q. Excuse me.
22 A. I had a lot of disciplinary problems.
23 Q. You had a lot of them.
24 A. Uh-huh.
25 Q. What disciplinary problems did you have.
26 A. I would get into fights sometimes at school.
27 Q. Pardon me.
28 A. I would get into fights sometimes at school. 1821
1 Q. Okay. You got into a lot of them, didn’t
3 A. Not a lot. I got into a few.
4 Q. Okay. And were you ever asked to leave the
6 A. No, I don’t think so.
7 Q. Were you ever asked to leave class.
8 A. Yes.
9 Q. Okay. And approximately when did that
11 A. Um, well, a lot of teachers at John
12 Burroughs Middle School, once anyone even talks out
13 of turn, they’ll send you out of class.
14 Q. Well, you got up in class and accused
15 Teacher Geralt of having his balls in his mouth,
17 A. His balls in his mouth.
18 Q. Yes.
19 A. No, because I was never in one of his
21 Q. Do you deny doing that.
22 A. I don’t even remember ever doing that.
23 Q. Were you in any programs after school with
24 Teacher Geralt.
25 A. I believe he was an ROTC instructor.
26 Q. Okay. So you were in ROTC at the time,
28 A. No. Not exactly. Because I had so much 1822
1 experience in that field of marching, and military,
2 military aspects, he — they liked me being an
3 advisor there.
4 Q. Well, you were accused by Mr. Geralt of
5 being totally disruptive in that program, right.
6 A. In the ROTC program.
7 Q. Yes.
8 A. I don’t remember that. I remember them
9 loving me there because the whole — the whole —
10 their whole cadet corps was disciplined, and — and
11 knew what they were doing. It was getting better at
13 Q. And you accused the cadet core of being
14 stupid, right.
15 A. I might have called a few cadets — that
16 they looked stupid with their uniforms. But — if
17 their uniforms look ugly, that they need to make
18 them look better. But I don’t think I remember
19 calling the whole core stupid.
20 Q. Now, you said you were accused of being on
21 drugs, right.
22 A. Yes.
23 Q. And you say that was false, right.
24 A. Yes. I don’t — will never go on drugs.
25 Q. Okay. Who accused you of being on drugs.
26 A. Mr. Geralt.
27 Q. Okay. And did he ask you if you were on
28 drugs. 1823
1 A. He was doing it in a way that he was trying
2 to make fun of me.
3 Q. Were you escorted away from the other
4 students at one point.
5 A. During the detention.
6 Q. Yes.
7 A. Actually, all of the students in there were
8 kind of cheering me on because they all knew how
9 Mr. Geralt is, and no one’s ever stood up to him
11 Q. But you stood up to the teacher, right.
12 A. I was already standing up, so —
13 Q. Excuse me. I’m sorry, I didn’t hear what
14 you said.
15 A. I guess so.
16 Q. You did stand up to Teacher Geralt, right.
17 A. Yes.
18 Q. You confronted him, right.
19 A. Yes, after he had brought himself down to my
20 level by doing those things. By not — see, because
21 I believe teachers are higher than me because I’m
22 just a student. When a teacher does something like
23 that and makes fun of me and tries to say I’m on
24 drugs, he’s no longer the level of a teacher, he’s
25 come down to my level.
26 Q. And you were angry about that, right.
27 A. Um, I felt as if he was — didn’t deserve
28 respect as a teacher. 1824
1 Q. Didn’t deserve respect as a teacher.
2 A. No.
3 Q. Okay. So you did not respect him because
4 you didn’t think he deserved it, right.
5 A. I didn’t respect him as a person.
6 Q. And you told him that, didn’t you.
7 A. I didn’t tell him those exact words.
8 Q. Pardon me.
9 A. I didn’t tell him, “I don’t respect you.”
10 I didn’t tell him in those exact words.
11 Q. Okay. Did Teacher Geralt do anything to
12 discipline you, that you can recall.
13 A. He gave me detention once, I think.
14 Q. Okay. And when you say “detention,” what do
15 you mean.
16 A. Detention with him again.
17 Q. Excuse me.
18 A. A detention with him again.
19 Q. Okay. And what was detention. What did he
20 take you do.
21 A. He had us go in this — the auditorium,
22 because there was a lot of kids. Well, first we’d
23 be in his classroom, and usually there would be a
24 lot of kids, so we would usually move over to the
25 auditorium because it was bigger, and then we would
26 do our homework in there. It was after school.
27 Q. Okay. Since we’re on the subject of school,
28 I’d like to just ask you some questions about your 1825
1 experiences at school. Okay.
2 A. Uh-huh.
Mesereau continued to question Gavin about his different disciplinary problems at school, and one important and prophetic criticism of Gavin came from a teacher who said that Gavin “had great acting skills”. Here’s the excerpt where Mesereau asks Gavin about this criticism, and Gavin denies knowing about it.
23 Q. BY MR. MESEREAU: She also said you appeared
24 to have good acting skills, right.
25 A. I don’t know if she said that.
26 Q. Would it refresh your recollection if I show
27 you her memo to Mr. Davy.
28 A. Probably not, because I never saw the memo 1839
2 Q. Well, do you recall her ever saying anything
3 to the effect, “You have good acting skills”.
4 A. No.
After going through Gavin’s disciplinary history at school, Mesereau shifts back to the meeting with Mr. Alpert about whether Gavin had been abused by Jackson, and Gavin once again confirmed that he denied any abuse to Mr. Alpert.
24 Q. Let me get back to your conversation with
25 Mr. Sneddon last night. Did he ask you who Jeffrey
26 Alpert is.
27 A. He asked me who Dean Alpert was.
28 Q. And did you tell him who Jeffrey Alpert is. 1843
1 A. I don’t know if Dean Alpert was the same
2 Jeffrey Alpert, because, I mean, I only call him
3 Dean Alpert. So I don’t know if we’re talking about
4 the same guy, because there’s — I think there’s
5 another guy named Alpert there.
6 Q. Okay. Did you tell Mr. Sneddon you knew who
7 Dean Alpert was.
8 A. Yes.
9 Q. Did you tell him when you first met Dean
11 A. Yes. Well —
12 Q. What did you tell Mr. Sneddon.
13 A. Well, I didn’t really tell him when I first
14 met him, but I told him that I knew that I met him.
15 Q. Okay. Did the conversation begin with a
16 discussion about Mr. Alpert or Mr. Geralt.
17 A. I believe it was about Mr. Geralt first.
18 Q. Okay. And you told Mr. Sneddon your history
19 with Mr. Geralt, right.
20 A. I told him about that one story that I told
22 Q. Pardon me.
23 A. I told him about that one story that I told
25 Q. Okay. And after you finished telling Mr.
26 Sneddon about your experiences with Mr. Geralt, did
27 you then start talking about Mr. Alpert.
28 A. No, he asked me if I remember who Mr. Alpert 1844
2 Q. Okay. Now, you were sent to Mr. Alpert’s
3 office many times for disciplinary problems,
5 A. Uh-huh.
6 Q. Generally fights, correct.
7 A. Um, not really. Because I didn’t want to
8 fight in the seventh grade — well, every time I
9 would get into a fight, I would be sent there. I
10 got into one fight in seventh grade with an eighth
11 grader, and I’m not — I remember one fight, but I
12 know I got into more than one in the eighth grade.
13 Q. Okay. But you were — you had a lot of
14 meetings with him about —
15 A. Yes.
16 Q. — allegations, at least, that you were a
17 discipline problem, right.
18 A. No, I had meetings with him because I was a
19 disciplinary problem.
20 Q. Okay. Okay. And do you know approximately
21 when Dean Alpert called you in his office to ask you
22 if any of these allegations involving Michael
23 Jackson were true.
24 A. I believe it was after I came back from
26 Q. Pardon me.
27 A. I’m pretty sure it was after I came back
28 from Neverland, the eighth grade. 1845
1 Q. Okay. And he looked at you, and he said,
2 “Look at me, look at me, Gavin. I can’t help you
3 unless you tell me the truth. Did any of this
4 happen. Did anything bad happen.” Remember that.
5 A. Um, yeah, I believe so.
6 Q. And your response was, “No, nothing
7 happened,” right.
8 A. Yeah.
In this excerpt, Mesereau confronts Gavin with cards that he and his family sent to Jackson, and although he initially denied it, he was forced to admit that he called Jackson “daddy” once Mesereau presented him with the cards. Gavin also confirmed that he wanted to travel to New York to watch Jackson record his music, but was unable to reach him throughout 2001.
9 Q. Okay. You used to send a lot of letters and
10 cards to Michael Jackson, correct.
11 A. Yes.
12 Q. When did you begin sending letters and cards
13 to Michael Jackson.
14 A. When I met him, I guess.
15 Q. Excuse me.
16 A. When I met him.
17 Q. Would that be the first trip to Neverland.
18 A. Yeah, I don’t think I gave him a card
19 when — the first day I met him, but, I mean, it was
20 probably around the times that I knew him.
21 Q. You also were sending cards to his assistant
22 named Evvy, right.
23 A. Yes. She was a really nice lady.
24 Q. Please tell the jury who Evvy is.
25 A. I think she’s like the assistant to Michael
26 or something like that.
27 Q. You sent a card to her saying that you loved
28 her, right. 1846
1 A. Yeah — I believe I did.
2 Q. Yeah, your whole family did, right.
3 A. I think we did.
4 Q. Said, “Evvy, sweetheart, we love you,”
6 A. I don’t know if we said that, but I mean —
7 Q. Would it refresh your recollection if I just
8 show you a copy of a card.
9 A. Sure. Yes.
10 MR. MESEREAU: May I approach, Your Honor.
11 THE COURT: Yes.
12 MR. SNEDDON: Could I see the card for just
13 a second.
14 THE WITNESS: It’s —
15 THE COURT: Just a moment. He’s just showing
16 you the card, remember.
17 THE WITNESS: Okay.
18 THE COURT: Now he’s going to ask you if it
19 refreshes your recollection.
20 THE WITNESS: All right.
21 Q. BY MR. MESEREAU: Have you had a chance to
22 look at that card.
23 A. Yes.
24 Q. Does it refresh your recollection about
25 sending a card to Evvy.
26 A. A little bit. Because I knew we sent cards
27 to Evvy.
28 Q. Okay. You called her a sweetheart and said 1847
1 you loved her, right.
2 MR. SNEDDON: Your Honor, I’m going to
3 object to that question, because counsel’s not laid
4 the foundation that he recognizes the handwriting as
5 being his.
6 THE WITNESS: That’s my mom’s —
7 THE COURT: Just a moment.
8 MR. SNEDDON: Lack of foundation.
9 MR. MESEREAU: I’ll go into it, Your Honor.
10 THE COURT: The objection is overruled.
11 THE COURT: You may answer. I’ll have the
12 question — do you want the question read back.
13 THE WITNESS: Yes.
14 (Record read.)
15 THE WITNESS: Yes.
16 Q. BY MR. MESEREAU: And you used to write
17 cards to Michael and call him “daddy,” correct.
18 A. Yes.
19 Q. And you would refer to yourself as his son,
21 A. Well, I called him “daddy,” and then he
22 would call me his son.
23 Q. Well, you yourself wrote to him and said,
24 “To Daddy Michael, from your son Gavin,” correct.
25 A. That’s probably after he called me “son.”
26 Q. Let me just ask you the question again,
27 because you got to answer the question.
28 A. Okay. 1848
1 Q. Isn’t it true that you sent a letter to
2 Michael Jackson, you addressed it to “Daddy Michael,
3 from your son Gavin”.
4 A. I mean, I’m — I don’t know every letter I
5 ever sent to him, but, I mean, I probably did.
6 Q. Do you remember doing that.
7 A. Not really.
8 Q. Would it refresh your recollection if I just
9 show you that, the letter.
10 A. Yes.
11 MR. MESEREAU: May I approach, Your Honor.
12 THE COURT: Yes.
13 THE WITNESS: Yeah.
14 Q. BY MR. MESEREAU: Have you had a chance to
15 look at that document.
16 A. Yes.
17 Q. Does it refresh your recollection about
18 sending Michael Jackson a letter that said, “To
19 Daddy Michael, from your son Gavin”.
20 A. Yes.
21 Q. Do you remember sending another card to
22 Michael Jackson that said, “I miss you, Daddy
24 A. I don’t know — I probably did send him
26 Q. Do you know for sure if that happened.
27 A. Not for sure, but I’m pretty sure I did.
28 Q. Would it refresh your recollection if I just 1849
1 show you the card.
2 A. Yes.
3 MR. MESEREAU: May I approach, Your Honor.
4 THE COURT: Yes.
5 THE WITNESS: Oh, yes.
6 Q. BY MR. MESEREAU: Okay. Have you had a
7 chance to look at that document.
8 A. Yes.
9 Q. Does it refresh your recollection about your
10 sending a card to Michael Jackson that said, “I miss
11 you, Daddy Michael”.
12 A. Yes.
13 Q. Okay. How often would you send cards or
14 letters to Michael Jackson.
15 A. I’d probably send them maybe once a month or
16 something like that.
17 Q. And you used to ask him for his phone
18 numbers, right.
19 A. He would give me some of his phone numbers.
20 Q. Pardon me.
21 A. He would give me some of his phone numbers.
22 He gave them.
23 Q. But correct me if I’m wrong, did you tell
24 the jury last week that he gave you phone numbers
25 that ended up not working.
26 A. No, I told you he gave me phone numbers, and
27 after a while they didn’t work.
28 Q. And you would then routinely ask him for 1850
1 numbers that did work, right.
2 A. Not really routinely. But, I mean, I asked
4 Q. Okay. Do you know approximately when you
5 began sending letters or cards to Michael Jackson.
6 A. Probably when the numbers didn’t work no
7 more, and all we had was Evvy to talk to.
8 Q. Do you remember sending a letter to Michael
9 Jackson that said, “I love you, Daddy Michael. And
10 tell my little brother and little sister that I love
11 and care about them. Thank you for everything,
12 Daddy Michael. Thank you for being my Daddy
13 Michael. Thank you for helping me be happy and beat
14 cancer.” Do you remember sending him a letter like
16 A. Not really, but I mean I probably did.
17 Q. Would it refresh your recollection if I just
18 show you the card, or a copy of the card.
19 A. Yes.
20 MR. MESEREAU: May I approach, Your Honor.
21 THE COURT: Yes.
22 THE WITNESS: Oh, I remember.
23 Q. BY MR. MESEREAU: Have you had a chance to
24 look at that copy of a card.
25 A. Yes.
26 Q. And does it refresh your recollection that
27 you wrote to Michael Jackson yourself and thanked
28 him for helping you beat cancer. 1851
1 A. I remember that card.
2 Q. Pardon me.
3 A. I remember that card.
4 Q. You did write to Michael Jackson yourself
5 and thanked him for helping you beat cancer,
7 A. I wrote that in the letter, yes.
8 Q. Okay. You used to also write letters to
9 Michael Jackson’s children, right, Prince and Paris.
10 A. I might have.
11 Q. You called Michael, Prince and Paris your
12 very best friend — friends in the world, right.
13 A. I don’t know.
14 Q. Do you recall doing that.
15 A. No.
16 Q. Would it refresh your recollection if I show
17 you a copy of that card.
18 A. Yes.
19 MR. MESEREAU: May I approach, Your Honor.
20 THE COURT: Yes.
21 THE WITNESS: I don’t remember writing that.
22 Q. BY MR. MESEREAU: You don’t remember that.
23 A. No.
24 Q. Do you remember writing any letters that
25 were addressed to Michael, Prince and Paris.
26 A. My writing doesn’t — no.
27 Q. You don’t recall ever doing that.
28 A. No. My writing doesn’t look that good. 1852
1 Q. Pardon me.
2 A. My writing doesn’t look that good.
3 Q. Okay. Now, you used to write Evvy, Michael
4 Jackson’s personal assistant, and thank her for what
5 she had done for you, correct.
6 A. Yeah, I would thank her for, like, setting
7 up stuff and helping us.
8 Q. What nice things had Evvy done for you.
9 A. She would like — when I would — she helped
10 me set up the AOL account with the Internet.
11 Q. I’m sorry, I can’t —
12 A. She helped me set up the Internet on the
13 computer that Michael —
14 Q. What else did she do for you.
15 A. She was just a really nice lady. I mean, we
16 would call her and she would be really nice to me.
17 Q. Do you recall ever writing to Michael
18 Jackson about his injuring his foot.
19 A. Yes.
20 Q. And tell the jury what you told Michael
21 Jackson about that.
22 A. I just told him, like, I hope he feels
23 better, or stuff like that.
24 Q. You told him that your family was praying
25 for him, true.
26 A. I think so.
27 Q. You said you felt sorry about his foot being
28 broken, right. 1853
1 A. Yes.
2 Q. And you said you couldn’t wait till you
3 could play at Neverland again, right.
4 A. Yes.
5 Q. You called him “daddy” in that letter,
7 A. Yes, I believe so.
8 Q. Is that true.
9 A. I don’t know, but I’m pretty sure I did.
10 Q. Okay. You reminded him that he keeps all of
11 his promises, right.
12 A. Yeah, he would tell me he keeps every
13 promise he says.
14 Q. Okay. And you reminded him of that in your
15 letter at one time, right.
16 A. Yes.
17 Q. And you said, “I wish I could be with you in
18 New York and watch you record your music stuff.”
19 Remember that.
20 A. No.
21 Q. Would it refresh your recollection if I just
22 show you a copy of this letter.
23 A. Yes.
24 MR. MESEREAU: May I approach, Your Honor.
25 THE COURT: Yes.
26 THE WITNESS: Oh, yeah, I remember that.
27 Q. BY MR. MESEREAU: Have you had a chance to
28 look at that document. 1854
1 A. Yes.
2 Q. And you wanted to go to New York and be with
3 Mr. Jackson in a recording studio, right.
4 A. I guess. I mean, yeah.
5 Q. And that didn’t happen, right.
6 A. No.
7 Q. You never traveled with Mr. Jackson to New
9 A. I never traveled with Mr. Jackson.
10 Q. You called him the nicest, most loving
11 person in the world, right.
12 A. Yes.
13 Q. You said, “I love you, Daddy Michael,”
15 A. Yes.
16 Q. You said, “Thank you, Daddy Michael, for
17 being my best, best friend forever and ever,” right.
18 A. Yes.
19 Q. Okay. You sent another card to him and it
20 said, “Here’s a little something to make you feel
21 better while your leg is healing. Ha ha, ha ha.
22 Love you. Love, your son Gavin.” Do you remember
24 A. Yeah.
25 Q. Do you remember doing that.
26 A. Yes. Yes.
27 Q. Okay. Do you remember sending him a card
28 asking him to, “Please come back, I miss you, I love 1855
1 you”. Do you remember that.
2 A. No.
3 Q. Would it refresh your recollection if I show
4 you a copy of that card.
5 A. Yes.
6 MR. MESEREAU: May I approach, Your Honor.
7 THE COURT: Yes.
8 Q. BY MR. MESEREAU: Have you had a chance to
9 look at that document.
10 A. Yes.
11 Q. Does it refresh your recollection.
12 A. Not really.
13 Q. Okay. You don’t recall saying words to
14 Mr. Jackson, “Come back, I miss you, I love you”.
15 A. I mean, because I probably did, but I don’t
16 really remember sending a letter.
17 Q. Okay. Now, to your knowledge, other members
18 of your family were sending cards to Mr. Jackson as
19 well, right.
20 A. Yes.
21 Q. Okay. You sent a lot of cards that were
22 signed, “Your son, Gavin,” true.
23 A. Yes.
24 Q. All right. You used to refer to Michael as
25 your best friend, right.
26 A. Yes.
27 Q. You used to refer to him as “cool,” right.
28 Right. 1856
1 A. I don’t know if I said “cool,” but I
2 probably did.
3 Q. You said you liked being in the music studio
4 at Neverland.
5 A. Yes.
6 Q. Were you ever in his music studio at
8 A. Yes.
9 Q. Were you with Michael Jackson.
10 A. Yes.