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March 30th, 2005 Trial Analysis: Cynthia Bell (Cross Examination), Dr. Stan Katz, William Dickerman, & Jeff Klapakis (Direct & Cross Examination), Part 3 of 4

October 16, 2012

Mesereau recross-examined Dr. Katz and (as you would expect) asked him about celebrities who have been targeted with false claims for money; pay attention to what he said about the children who make false allegations! He unknowingly gave the perfect description of the Arvizos!





19 Q. Other than Mr. Jackson, how many cases of


20 alleged molestation have you worked on involving


21 well-known celebrities?


22 A. Probably less than half a dozen.


23 Q. Have you ever published an article about


24 sexual allegations against celebrities?


25 A. I don’t think so. I don’t recall ever


26 publishing anything like that.


27 Q. In any of your books, have you ever authored


28 anything about the subject of sexual allegations 4305


1 made against celebrities?


2 A. Well, I — I may have referred to cases, but


3 I didn’t refer to a personal concern.


4 Q. You said something about children who are


5 making false allegations tend to be inconsistent


6 when they describe those false allegations, correct?


7 A. No. What I said was, in fact, it’s the


8 opposite. Children who make false allegations are


9 usually very consistent and almost scripted in what


10 they say. They exaggerate, they embellish, they


11 take every opportunity to make a positive into a


12 negative.


13 Children who have been molested tend to be


14 inconsistent. They have problems with memory


15 retrieval. Their data storage is not great. They


16 don’t remember dates and times, and they don’t


17 remember exactly what happened. And they don’t tend


18 to embellish and exaggerate. When you interview


19 these children and you ask them if something


20 happened, they won’t say, “Oh, yeah, that happened


21 too.” They’ll say, “No, that didn’t happen.”


22 Children who fabricate will all of a sudden


23 tell you that everything happened to them by


24 everybody, and so they exaggerate because they don’t


25 know intellectually when to stop.


26 Q. So what you’re telling the jury is, in your


27 experience, exaggeration and embellishment can be


28 signs of false allegations of sexual abuse? 4306


1 A. That is correct.


2 Q. And if you were investigating an allegation


3 of sexual abuse, and if you, as a professional, were


4 to learn that there was a history of false


5 allegations before, would that be something that you


6 would consider?


7 A. A false allegation of sexual abuse?


8 Q. Yes.


9 A. And the false allegations have been


10 determined to be false?


11 Q. Or you think they’re false, because you see


12 a lot of exaggeration and embellishment in what the


13 children say.


14 A. Well, you can’t simplify it. These are just


15 two factors. So I’m saying that children tend to do


16 these things. They tend to exaggerate and


17 embellish. That does not predict that they are


18 lying. But if children do embellish and exaggerate,


19 I’d be suspect of what the motivation is for making


20 the comments.


21 Q. And if, in any of these cases, there is no


22 physical evidence to support the allegation of


23 sexual abuse, the decision regarding whether or not


24 you believe the allegation is true is really a


25 subjective one, right?


26 A. Well, there’s rarely evidence in these kinds


27 of cases. I’ve been involved in thousands. Rarely


28 see evidence, physical evidence, like trauma to the 4307


1 genitals, for example. It’s subjective evaluation


2 based on an assessment and many data sources to


3 actually determine what happened.


4 Q. Doctor, in cases involving sexual abuse in


5 the criminal courts, you’re seeing more DNA evidence


6 all the time used in these cases, correct?


7 A. In some sexual abuse cases, yes.


8 Q. You’re seeing evidence of semen, DNA, and


9 things of that sort, correct?


10 A. In some of the cases, yes.


11 Q. And if you don’t have any physical evidence,


12 it becomes pretty much a subjective determination


13 regarding credibility, correct?


14 A. Well, there may be other evidence which is


15 more objective. But certainly if you don’t have the


16 physical evidence, you’re missing one — the


17 physical trauma, you’re missing one piece.


18 But sexual abuse is not physically


19 traumatic. Fondling does not leave marks and


20 bruises and semen.


21 Q. But sexual abuse can leave marks or bruises


22 or semen, true?


23 A. Yes, sir.


24 Q. Depending on the nature of it?


25 A. Yes, it can.


26 Q. And if it leaves marks or bruises or semen


27 and there’s evidence of that, it would support a


28 claim, correct? 4308


1 A. That’s correct.


2 Q. Now, when you say exaggeration or


3 embellishment can be indications of a false claim,


4 that could certainly include stories changing, could


5 it not?


6 A. Well, as I said before, stories changing


7 suggests that the child may be actually telling the


8 truth, because children cannot retain memories very


9 well. Their storage retrieval system is not very


10 sophisticated. And as you can tell, even us


11 professionals can’t remember everything we did a


12 year ago, let alone two years ago.


13 So it’s very hard for a child to do that,


14 and that would not be predictive whatsoever of a


15 false claim.


16 THE COURT: All right. Let’s take a break.




18 (Recess taken.)


19 THE COURT: You may proceed.

To summarize what Dr. Katz just stated, real victims of child abuse have MEMORIES that change over time, but false victims of child abuse have STORIES that change over time! Read this post to see a list of summaries of the lies of Star, Davellin, and Gavin Arvizo (with Janet coming soon!)

Next, Mesereau questioned Dr. Katz about his articles (which I included in the previous post):

20 MR. MESEREAU: Thank you, Your Honor.


21 Q. Dr. Katz, are you suggesting to the jury


22 that you don’t often see false claims of sexual


23 abuse by teenagers?


24 A. Yes.


25 Q. Have you published any articles on that


26 subject?


27 A. I have not.


28 Q. What research have you done on that subject? 4309


1 A. I have read probably all the current


2 research on “Jeopardy in the Courtroom,” which cites


3 all the research regarding children in the courtroom


4 regarding molestation.


5 Q. Now, tell me what research you’ve done into


6 how many civil cases have been filed by plaintiffs


7 who are teenagers in the area of sexual abuse and


8 how many have been won or lost?


9 A. I have no research about that.


10 MR. MESEREAU: No further questions.

Zonen had additional questions under further redirect examination regarding his experience with false accusations made for profit; Dr. Katz stated that he didn’t recall any cases where money was the motivating factor, although civil lawsuits were eventually filed:





14 Q. Doctor, do you have personal experiences


15 involving your own caseload over the past 20-plus


16 years that you’ve been doing this where you believe


17 there were cases that were allegations, false


18 allegations, of molestation that were motivated by


19 profit?


20 A. In addition to all the cases that I’ve

21 seen – I’ve supervised numerous interns and other


22 professionals – I don’t recall seeing any


23 adolescents or preadolescents who were making


24 allegations for profit.


25 I do and have been involved with lawsuits


26 where children have alleged molestation, and there


27 have been civil suits and they’ve been awarded


28 damages. So that wasn’t the motivation, but they 4310


1 did proceed with the civil case and they were


2 awarded damages.


3 Q. All right. But in terms of where you


4 believe that the allegation itself was false —


5 A. No.


6 Q. — that was motivated by profit?


7 A. No.


8 MR. ZONEN: No further questions.


9 MR. MESEREAU: No further questions, Your


10 Honor.


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


12 THE WITNESS: Thank you, Your Honor.


Summary of the testimony of Dr. Stan Katz

1. The Arvizo family was referred to Dr. Stan Katz by attorney Larry Feldman, who was referred to the Arivos by their attorney William Dickerman.

2. Dr. Katz was on retainer for Larry Feldman in 1993, and was hired to “analyze” several videotapes of Jordan Chandler’s interview with Dr. Richard Gardner in October 1993. Once the criminal case was closed, Dr. Katz had nothing more to do with the case or Larry Feldman.

3. Dr. Katz interviewed the Arvizos on May 15th, 16th, 21st, 29th, and June 11th, 2003, and during these interviews the possibility of suing Jackson was discussed with the family. His rate was $300 dollars per hour, and he was paid a grand total of $4,800 dollars by Larry Feldman’s law firm. After his interviews were concluded, Dr. Katz contacted the Department of Children and Family Services on June 12th, 2003.

4. On June 1st, 2003, Dr. Katz spoke with Det. Paul Zelis of the Santa Barbara Police Department, and they spoke about the current state of the investigation into Jackson. Dr. Katz didn’t know the phone call was being recorded, and he stated that he didn’t believe that Jackson was a pedophile, but rather a “regressed 10 year old”, and Det. Zelis agreed with him! They also discussed some of what Gavin told Dr. Katz during his interview, including a reference to Jordan Chandler not being able to “stop” Jackson from abusing other boys!

5. Dr. Katz was questioned by Mesereau about two pieces of literature that he wrote about false allegations of child abuse; an article in the New York Times in 1984, and an excerpt from a book he co-authored in 1992 (both can be downloaded in part 2 of this series). This was an attempt by Mesereau to get Dr. Katz to acknowledge that there are many false allegations of child abuse, and many times the accusers come from the same types of dysfunctional families as the Arvizos.

6. In order to sully Dr. Katz’s credibility, Mesereau questioned him about his role in the infamous McMartin Preschool Trial, in which dozens of children were harassed and bullied into making false allegations of abuse against their teachers, and a few years later they were all acquitted. Dr. Katz was the director of training and professional education at the agency that interviewed all of the children.

7. When asked by Mesereau to discuss the characteristics of false accusers, Dr. Katz stated that real victims of child abuse have MEMORIES that change and evolve over time, but false victims have STORIES that change over time!

8. Under cross examination, Dr. Katz admitted to Mesereau that he had spoken to William Dickerman, another prosuctiton witness, in violation of the judge’s gag order. The defense would later use this is one of many reasons why a mistrial should be declared by Judge Melville (who ultimately ruled against it).


The next prosecution witness was attorney William Dickerman, who briefly worked with the Arvizos and referred them to attorney Larry Feldman; she met them via his prior professional representation of Jamie Masada:





14 Q. Mr. Dickerman, good afternoon.


15 A. Good afternoon.


16 Q. Sir, what is your current occupation?


17 A. I’m an attorney at law.


18 Q. And you’ve been an attorney for how long?


19 A. Since 1977.


20 Q. It won’t be a long direct examination. I


21 don’t think I have much voice left, so we’ll keep it


22 brief.


23 THE COURT: You need to be closer to the


24 mike, Mr. Dickerman.


25 And they’re not hearing you either, probably


26 because of your cold.


27 THE WITNESS: Is that better now?


28 THE COURT: Yes, thanks. 4312


1 MR. ZONEN: Is that better now?




3 Q. BY MR. ZONEN: Sir, what kind of a practice


4 do you have?


5 A. I’m a civil litigator/trial lawyer.


6 Q. Are you a sole practitioner or do you work


7 in a law firm?


8 A. I am a sole practitioner.


9 Q. What kinds of cases do you handle typically?


10 A. Well, generally civil, or strictly civil


11 rather than criminal, which means anything from


12 contract breaches, to torts, negligence cases,


13 unfair competition, copyright infringement. A whole


14 broad array of noncriminal cases.


15 Q. Do you know Jamie Masada?


16 A. I do.


17 Q. Is he is a client of yours?


18 A. Yes.


19 Q. And you have represented him at different


20 times over the years?


21 A. I have.


22 Q. Do you know Janet Arvizo?


23 A. I do.


24 Q. Is she a client, or was she a client of


25 yours?


26 A. She was, and I believe she thinks she still


27 is, so I’m assuming that she is.


28 Q. Okay. When did you first meet Janet Arvizo? 4313


1 A. February 21st, I think, 2003.


2 (Off-the-record discussion held at counsel


3 table.)


4 MR. ZONEN: Excuse me.


5 Q. I’m sorry, tell me the date of your first


6 meeting with her.


7 A. February 21st, 2003.


8 Q. 2003. And who was it who introduced you to


9 her?


10 A. Jamie Masada.


11 Q. And what was your understanding of the


12 nature of the problem?


13 A. Well, I have to be careful about disclosing


14 any attorney-client privilege. And it’s my


15 understanding that Miss Arvizo and her family have


16 not waived the privilege, so I’ve got to be careful


17 about saying what I was told.


18 Q. Let me ask you differently, then. Did you


19 meet with her on a few occasions?


20 A. Yes, I did.


21 Q. Was Mr. Masada present on those occasions?


22 A. Some he was; some he was not. The initial


23 meetings he was.


24 Q. Approximately how many meetings did you have


25 with Ms. Arvizo where Jamie Masada was present?


26 A. I’d say a total of three or four in either


27 my office or at The Laugh Factory, and — oh, gosh,


28 there were other times during the representation 4314


1 when we were all together.


2 Q. Okay. Did — you did have a meeting with


3 her at The Laugh Factory; is that correct?


4 A. I believe there were at least two at The


5 Laugh Factory.


6 Q. What are the dates of those, if you know, or


7 if you have them written down?


8 A. One of them I know was February 25th. And


9 there was another one that I — I don’t know the


10 date of, but I believe it was not very long after


11 that date.

Here is Dickerman’s description of the services that he provided to the Arvizos; on March 26th, 2003, he wrote a letter to Geragos complaining about Janet’s claims of being intimidated and harassed by Jackson’s private investigators, asking for a return of her furniture which had been put into storage, and asking for her family’s passports and birth certificates to be returned to her:

12 Q. Did you engage in efforts to do things or


13 perform services on behalf of Miss Arvizo?


14 A. Yes.


15 Q. Did that involve writing letters?


16 A. Yes.


17 Q. To whom did you write letters?


18 A. Well, the first letter I wrote was to Mr.


19 Geragos, who I understood was representing Mr.


20 Jackson at the time. And there was a whole series


21 of letters to him.


22 After Mr. Geragos, I wrote — or I’m not


23 sure, maybe it was even before Mr. Geragos, I was


24 writing letters to various media outlets with regard

25 to the “Living with Michael Jackson” show.


26 Q. What was the extent of the problem as you


27 expressed it to Mr. Geragos?


28 A. There were a number of problems that I 4315


1 expressed to Geragos. And I remember I wrote a


2 letter on March 26th that covered three or four or


3 five of those things.


4 Q. Was that the first letter that you wrote?


5 A. I believe so.


6 Q. All right. Go ahead.


7 A. The most serious issue, as I recall, was an


8 intimidation/harassment/surveillance issue that I


9 expressed to him. I was asking him or directing him


10 to cut it out, or to have Mr. Jackson’s people stop


11 surveilling, harassing, intimidating my clients.


12 Q. And what else did you ask for? Did you ask


13 specifically for anything to be returned?


14 A. Yes, I believe in that letter, and in


15 several others soon thereafter, I asked for the


16 return of passports, visas, birth certificates.


17 There may have been some other papers.


18 Q. All right. And did you ask, as well, for


19 other possessions that belonged to the Arvizo


20 family?


21 A. I don’t know if it was in that first letter.


22 In one, at least one letter — in fact, several


23 letters, I asked for return of clothing that had


24 apparently been — not been returned to Gavin when


25 they left Neverland, including tap shoes, shirts,


26 socks, perhaps one or two other things.


27 Q. Okay. Were you aware as to whether or not


28 their possessions, in other words, the contents of 4316


1 their apartment, had been moved to some location?


2 A. I had been told that they had been moved to


3 some location.


4 Q. Did you make some effort to notify Mr.


5 Geragos of that fact and to ask that their


6 possessions be returned?


7 A. Yes, I believe it was in that same letter


8 and others thereafter that I asked not only — well,


9 asked that they be returned, but preliminarily, to


10 get a listing of what those items were, where they


11 were, who had control over them. I wanted a whole


12 listing of things so we would know what there was


13 and what to do with it.

Next, Zonen presented Dickerman with copies of his letters to Geragos:

14 MR. ZONEN: All right. May I approach the


15 witness, Your Honor?


16 THE COURT: Yes.


17 Q. BY MR. ZONEN: Mr. Dickerman, I’m going to


18 show you two exhibits. Exhibit No. 625 and Exhibit


19 No. 630 both appear to be a collection of materials.


20 Could you take them both? And let’s start with 625.


21 Take a moment, if you will, and look through 625,


22 and tell me if you recognize the content of that


23 exhibit.


24 A. I do recognize the content.


25 Q. All right. And what is that collection of


26 letters?


27 A. These are letters to — mostly to Mr.


28 Geragos, and at least one from him, with regard to 4317


1 those efforts that you just asked about.


2 Q. All right. Did Mr. Geragos acknowledge to


3 you that they had Miss Arvizo’s passport?


4 A. I don’t believe he ever acknowledged it.


5 Q. Did he ever acknowledge that he had any —


6 or they had any of her other possessions, including


7 the content of her apartment?


8 A. At some point he did state that they did


9 have the items in storage.


10 Q. For the period of time that you were engaged


11 in these communications by mail with Mr. Geragos —


12 a period of what appears to be a couple months; is


13 that correct?


14 A. The first one was March 26th and his last


15 letter to me apparently was June 2nd, so more than a


16 couple months.


17 Q. Were you successful in getting Miss Arvizo


18 and her family’s possessions returned to them?


19 A. Not at all.


20 Q. Did Mr. Geragos ever tell you where they


21 were?


22 A. I don’t believe so. I think he simply


23 referred to — or referred the matter to Mr. Miller,


24 Brad Miller, who then got in touch with me.


25 Q. All right. And when was that, the date of


26 that?


27 A. Well, on June 2nd, he wrote that — well, he


28 asked to have my clients, quote, “assume 4318


1 responsibility for the lockers.” I don’t know that


2 I knew at that time which lockers that he was


3 talking about.


4 But then on June 12th, or thereabouts, I


5 received from Brad Miller a letter in which he


6 specified for the first time who had moved the items


7 and where they were in storage.


8 Q. All right. Up until that point, did Mr.


9 Geragos ever tell you where your clients’


10 possessions had been taken?


11 A. No. No.


12 Q. What was your understanding of the extent of


13 those possessions?


14 A. Well, again, without breaching


15 attorney-client privilege —


16 Q. Just on the basis of your communication with


17 Mr. Geragos.


18 A. Well, he had suggested to me that there


19 might be two vaults’ worth of material, and my


20 understanding was that there was considerably less


21 than that. Of course, I don’t know what he meant by


22 a “vault,” but I was under the impression that there


23 was not very much that we were talking about at all.


24 Q. Was it all the furnishings of an apartment?


25 A. That was my understanding.


26 Q. Was this different from your request for


27 materials to be sent back that included clothing,


28 dance shoes and passports? 4319


1 A. Well, the — yes. The only things that I


2 asked him to deliver, and repeatedly, many, many


3 times, was the items that were recently


4 transportable, the passports, the visas, the birth


5 certificates and the clothing.


6 Q. Did you learn whether or not your clients’


7 possessions were actually delivered to your office


8 at some point in time?


9 A. Yes. I got a phone message the day — or


10 the day — I think it was the day that they were


11 brought over. The office manager was irate that


12 certain things had been delivered or attempted to be


13 delivered, furniture, boxes and whatnot, and it was


14 a day that I was out for a religious holiday. So I


15 was very surprised to find that this had happened.


16 And I was told that those materials had been


17 told to be returned, that they were not off-loaded.


18 And I was quite upset about that, because I had made


19 no arrangements with Mr. Geragos or anybody else for


20 those things to be delivered at any time.


21 Q. Did you have a message on your voice mail or


22 your answer phone that — answer phone is what I


23 mean to say, indicating that you would not be in the


24 office on that particular day?


25 A. Absolutely. Yes, I did.


26 Q. That’s the day that these things were


27 delivered?


28 A. That’s the day that they were delivered. 4320


1 Q. Were they actually received or accepted by


2 the office manager?


3 A. No.


4 Q. Or the building manager?


5 A. They were not.


6 Q. Did you talk with Mr. Geragos thereafter


7 about that?


8 A. I don’t believe I spoke with him about it.


9 But we did have an exchange of letters.


10 Q. Again, during that entire — I think we’re


11 talking about eight to ten weeks, was anything ever


12 delivered to you, where you took possession of it,


13 or, to your knowledge, your client did?


14 A. Not a single item.


15 Q. Did you have actual verbal conversation with


16 Mr. Geragos during that period of time?


17 A. I believe there was at least one, perhaps


18 two.


19 Q. Did you, in the course of those


20 conversations, ask him about your clients’


21 passports?


22 A. Yes.


23 Q. And is this passports for each member of the


24 family?


25 A. I think so. May I refer to —


26 Q. Yes, please.


27 A. Yes, the passports of the entire family.


28 Q. What did Mr. Geragos tell you about the 4321


1 passports, if anything?


2 A. I don’t recall specifically, without looking


3 at the document that embodies a memo, of what I


4 talked to him about, but I don’t think he knew what


5 I was talking about. I remember him —


6 Q. Well, you have a number of letters to him


7 included in this packet that is 625 where you ask


8 him about passports, do you not?


9 A. Yes.


10 Q. Did you ask him to check into it?


11 A. Yes.


12 Q. Did you ask him about visas as well?


13 A. I don’t remember. But again, there is a


14 memo of a phone conversation I had with him, and it


15 would be in that — and that memo has been produced


16 to everybody involved in the case, as far as I know.


17 Q. Mr. Dickerman, at any time during the eight


18 to ten weeks that you were dealing with Mr. Geragos


19 and ultimately communication with Mr. Miller, did he


20 ever tell you, “Yes, we are in possession of these


21 passports, and we will return them to you and your


22 clients immediately”?


23 A. No.


24 Q. Did he ever acknowledge being in possession


25 of those passports?


26 A. No.


27 Q. Did he ever acknowledge those passports


28 existed? 4322


1 A. No.


2 Q. Those communications, 625, that you’ve


3 looked at, are those letters accurate reproductions


4 of the communications between you and Mr. Geragos in


5 writing, and in return, Mr. Geragos back to you?


6 A. Yes.

Here is the next group of letters from Dickerman to Geragos:

7 Q. Now, turn to the next group of letters,


8 please. That’s 630; is that correct?


9 A. Yes.


10 Q. Excuse me.


11 630 is a collection of what kind of


12 materials, please?


13 A. These are letters to and from — well, from


14 me to various attorneys, media outlets, with regard


15 to trying to — with regard to the Bashir show


16 “Living with Michael Jackson.”


17 Q. And among the people you wrote letters to


18 are whom?


19 A. There was Granada Television. Granada Media


20 Group. The British firm, law firm, of Addleshaw and


21 Goddard. David LeGrand at Hale, Lane, which is a


22 firm — law firm in Las Vegas.


23 Q. Addleshaw and Goddard is where, what


24 location?


25 A. In London.


26 Q. In London, okay.


27 A. And finally, the Broadcasting Standards


28 Commission in London. 4323


1 Q. All right. The purpose of these


2 communications was what?


3 A. Well, there are various purposes for the


4 different ones.


5 Q. Okay. Were you — what did they concern in


6 general?


7 A. They all concerned the “Living with Michael


8 Jackson” television program.


9 Q. All right. What was your concern about


10 that?


11 A. Well, the concern as to Granada was that


12 Granada and ITV, which was I believe a corporation


13 associated with Granada in England, they cease and


14 desist from using any program, tape, interview or


15 film footage, whether it was used in the “Living


16 with Michael Jackson” program or not, for any


17 purpose whatsoever unless they could provide valid


18 consents by my clients, who had been shot in that


19 video or in that program.


20 Q. All right. Did all of these communications


21 effectively deal with some issue pertaining to the


22 screening of “Living with Michael Jackson”?


23 A. Yes.


24 Q. Was there any mention made to you by any of


25 the people with whom you communicated over this


26 issue that they, in fact, represented the Arvizo


27 family or any of the Arvizo children in any claims


28 against those who produced the documentary “Living 4324


1 with Michael Jackson”?


2 A. Yes, the Addleshaw-Goddard firm,


3 especially — or particularly Michelle Boote, who I


4 understood was a lawyer with that firm, stated


5 numerous times that that firm had been requested by


6 Ms. Arvizo to represent her in this complaint.


7 Q. Was your purpose in this communication


8 effectively to tell them that they were not?


9 A. Yes, and to keep them from moving forward


10 with anything that they were doing on the complaint


11 supposedly on her behalf.


12 Q. And — all right. And did you instruct them


13 not to proceed on her behalf in any other


14 representation?


15 A. Yes.


16 Q. Why did you do that?


17 A. Because it was my understanding that she had


18 never given any consent for them to do so.


19 Q. And was there a reason that you didn’t want


20 them representing her?

21 A. Because they weren’t asked to represent her,


22 and she didn’t want them representing her.


23 Q. Okay. Was it your understanding that you


24 would be representing her on that particular issue


25 dealing with the ramifications of the documentary


26 “Living with Michael Jackson”?


27 A. Yes.


28 Q. Now, you sent — that collection of 4325


1 documents that you’re looking at, No. 630, is that,


2 in fact, a complete collection, if you can tell, of


3 all the communications that you had with


4 Addleshaw-Goddard and with Mr. David LeGross?


5 A. It was LeGrand.


6 Q. LeGrand, I’m sorry. As well as BBC?


7 A. Well, I know there were a number of


8 communications. I can’t be sure this is all of


9 them. I certainly produced all of them, as far as I


10 knew. I believe so.


11 Q. To the extent that you’re looking at a


12 collection of documents, each of the documents that


13 you see in that exhibit, 630, is certainly one of


14 those letters; is that correct?


15 A. Yes.


16 Q. Either to you or from you?


17 A. Yes.

Dickerman next recounted more of his work with the Arvizos, and denied filing a lawsuit on behalf of Janet against ITV and Martin Bashir, and he admitted that he and Feldman had an agreement in which he would be compensated if Feldman were to successfully sue Jackson, as he did in 1993. This should in and of itself prove what Dickerman’s true intentions were when he referred the Arvizos to Feldman!

18 Q. All right. Did you file a lawsuit on behalf


19 of Janet Arvizo or her family?


20 A. No.


21 Q. At some point in time, did you refer this


22 matter to another attorney?


23 A. Yes.


24 Q. All right. Who was that other attorney?


25 A. Larry Feldman.


26 Q. And why did you do that?


27 A. Excuse me.


28 I began representing the Arvizos in 4326


1 February. And by the time I met with Mr. Feldman,


2 it was the beginning of May. In that period of time


3 I had learned a lot of things. There were a lot of


4 allegations being made, and I realized that the best


5 thing for my clients to do, and for me personally as


6 their attorney, was to get some expert input as to


7 matters of Michael Jackson.


8 The initial things I didn’t think I really


9 needed to do that with, but as things developed, I


10 wanted to get some input. So I met with Mr.


11 Feldman, whom, by the way, I knew — not “by the


12 way.” It was very important. I knew that he was —


13 by reputation, he was one of the top trial lawyers


14 in California, if not the United States. And


15 actually, previously, not knowing him except by


16 reputation, I had referred a case to him, tried to


17 refer a case to him that I could not handle for


18 various reasons of an old client of mine.


19 And I knew that he was the go-to guy with


20 regard to Michael Jackson matters. Of course, I


21 knew about the 1993 case, so I met with him, with


22 the idea of picking his brain, actually, not to


23 refer any matters to him. And afterwards, he met


24 with them, and they — we all associated together.


25 The Arvizos hired both him and me.


26 Q. All right. Have you filed a lawsuit as of


27 this time on behalf of the Arvizos or anybody else?


28 A. No. 4327


1 Q. Is it the case that the extent of your


2 dealings with them so far, in terms of your


3 communicating with others, has been for purposes of


4 getting their property returned or dealing with the


5 consequences of “Living with Michael Jackson,” the


6 documentary?


7 A. Yes.


8 Q. Do you have an understanding with Mr.


9 Feldman that should there be a lawsuit in the


10 future, that —


11 THE COURT: They’re not hearing you.


12 MR. ZONEN: I’m sorry?


13 THE COURT: Behind; these people can’t hear


14 you.


15 MR. ZONEN: I’m terribly sorry.


16 Q. Is there an arrangement that, should there


17 be a lawsuit in the future, that there would be


18 compensation for you in any form of a settlement


19 even if you’re not participating in that lawsuit?


20 Do you know what I mean?


21 A. Well, we have an agreement.


22 Q. Okay.


23 A. It doesn’t say anything about participation


24 or not. We were retained together, and I have a


25 fee-sharing arrangement with Mr. Feldman.


26 Q. Which means what?


27 A. Which means I will get — if there is such a


28 lawsuit anytime in the future, that I will be 4328


1 entitled to a sliding scale, depending on whether


2 there’s a settlement or a judgment.


3 Q. Okay. What kind of lawsuit do you


4 anticipate?


5 A. I don’t anticipate any lawsuit. My


6 understanding is that there isn’t one in the offing.


7 Nobody’s talking about one. And I suppose if there


8 were to be one — well, that would be speculation.


9 MR. ZONEN: Okay. I have no further


10 questions.

Mesereau immediately began his cross-examination by asking Dickerman to elaborate on his fee-sharing arrangement with Larry Feldman; this was an attempt by the defense to show the jury that there was a quid pro quo between Feldman and Dickerman that incentivized the filing of a lawsuit against Jackson on behalf of the Arvizos. A quid pro quo is defined as follows:  “returning a favor; the giving of something in return for something else, often in a spirit of cooperation”.





14 Q. Good morning. Or good afternoon, I guess.


15 A. Good afternoon.


16 Q. Mr. Dickerman, my name is Tom Mesereau.


17 I speak for Mr. Jackson.


18 A. All right.


19 Q. You just told the jury you have a


20 fee-sharing arrangement with Attorney Larry Feldman,


21 right?


22 A. Correct.


23 Q. And fee-sharing arrangements among attorneys


24 are a fairly standard type of thing, are they not?


25 A. Under certain circumstances, yes.


26 Q. And typically in a fee-sharing arrangement,


27 the understanding is the following: Attorney 1


28 refers the case to Attorney 2. Attorney 2 files a 4329


1 lawsuit. And if there’s a settlement or a judgment


2 or any amount of money recovered, then Attorney 2


3 has to give Attorney 1 a percentage of the recovery


4 the attorney gets, right?


5 A. Under circumstances as they often are, yes.


6 Q. It’s typically called “a referral fee,”


7 right?


8 A. There are situations where there are


9 referral fees, and there are situations where the


10 attorney would be involved in the lawsuit and that’s


11 how he would be compensated.


12 Q. In your typical referral fee arrangement,


13 the referring attorney, being the attorney that


14 sends the business to the other attorney, has an


15 arrangement where, if the other attorney collects

16 money, he gives a percentage to the attorney that


17 referred the matter, right?


18 A. In any strict referral fee arrangement, yes.


19 Q. But what you’re telling the jury is your


20 arrangement with Larry Feldman is not a strict


21 referral fee arrangement, correct?


22 A. Correct.


23 Q. Your agreement with Larry Feldman is that


24 you both will share in any fees collected, correct?


25 A. Yes.


26 Q. And that would mean if tomorrow, or next


27 month, or this summer, you and Mr. Feldman decide to


28 file a civil suit against Mr. Jackson, you have an 4330


1 understanding that if any money is obtained, you’ll


2 get a piece of that money, right?


3 A. Yes.


4 Q. When were you retained by Janet Arvizo?


5 A. Do you mean when a fee agreement was signed?


6 Q. Yes.


7 A. Well, there are a couple of different ones,


8 and they were both around March 24th, 2003.


9 Q. Was that the first date you met her?


10 A. No. We met February 21st.


11 Q. And who was at that first meeting on


12 February 21st?


13 A. Mr. Masada, Ms. Arvizo, I was, and I think


14 the three children were there, maybe in and out. I


15 believe I met them there, but I don’t think they


16 were in on the meeting.


17 Q. Why was Masada in the meeting?


18 A. Well, Mr. Masada was the one who had brought


19 the people to me, and my understanding was that


20 there was no way that they were going to talk to me


21 without him there.


22 Q. Okay.


23 A. He was greasing the rails, as it were, to


24 get them to trust me enough to talk to me. They had


25 no reason to talk to me otherwise.


26 Q. Okay. And you had represented Masada for


27 many years, correct?


28 A. Yes. 4331


1 Q. And how many years had you represented Jamie


2 Masada at the point where you first met the Arvizos?


3 A. I think I began representing Mr. Masada in


4 1991. Perhaps 1990. So that would be about 12


5 years.


6 Q. Had you represented Mr. Masada in any


7 lawsuits?


8 A. Yes.


9 Q. How many?


10 A. I couldn’t tell you precisely.


11 Q. How about generally?


12 A. Fewer than ten. Between five and ten,


13 probably. I shouldn’t say that. I represented him


14 in many matters. How many have been lawsuits, I can


15 think of three off the top of my head. So there


16 were probably five.


17 Q. Approximately five civil lawsuits?


18 A. I would say so.


19 Q. Okay. And are you a civil litigator?


20 A. Yes.


21 Q. Do you litigate civil suits from start to


22 finish?


23 A. Yes.


24 Q. And would that mean that you will litigate


25 the case either to a settlement or a trial?


26 A. Which case? You mean generally speaking?


27 Q. Yes.


28 A. Yes. 4332


1 Q. Now, you’ve indicated you represented Mr.


2 Masada in matters other than the civil lawsuits


3 you’ve just described, right?


4 A. Yes.


5 Q. Generally, what did those matters entail?


6 A. Business matters, generally speaking.


7 Q. Would you consider yourself to be Mr.


8 Masada’s principal business lawyer?


9 A. Well, he has told me I am. From time to


10 time he’s had me coordinate everything, so, yes.


11 Q. And would that mean you draft documents for


12 Mr. Masada?


13 A. I have done that. I’m not a transactional


14 attorney, so if there’s something major to draft


15 that does not involve litigation, probably not.

Next, Mesereau questioned Dickerman about the letters to Geragos; notice how Dickerman never mentioned any allegations of child abuse, alcohol, or pornography!

25 Q. BY MR. MESEREAU: Did the Arvizos retain


26 your services or did Mr. Masada?


27 A. The Arvizos.


28 Q. Okay. And would it be correct to say that 4334


1 at the time you were representing the Arvizos, you


2 were also representing Masada in other matters?


3 A. Yes.


4 Q. Now, the documents the prosecutor has given


5 you in the form of exhibits in no shape or form come


6 close to the number of letters you sent or received


7 on behalf of the Arvizos, correct?


8 A. Not correct.


9 Q. Well, are they all of them?


10 A. No.


11 Q. On March 27th, you sent a letter to the


12 executive vice-president and general counsel of Walt


13 Disney & Company, correct?


14 A. I don’t recall.


15 Q. Would it refresh your recollection if I just


16 show you a copy of the letter?


17 A. It might.


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


19 THE COURT: Yes.


20 THE WITNESS: Yes, that’s a copy of a letter


21 I wrote.


22 Q. BY MR. MESEREAU: Does that appear to be the


23 first letter you ever sent on behalf of the Arvizos;


24 do you think?


25 A. If that’s dated March 27th, I think the 26th


26 to Geragos is the first one. Actually, I’m not —


27 excuse me. There were a number of letters written


28 with regard to the “Living with Michael Jackson” 4335


1 show —


2 Q. Okay.


3 A. — that may have been well before that. I


4 don’t know. If you show them to me, obviously I


5 did.


6 Q. But they retain you on the 24th, and you


7 sent a letter to Mark Geragos on the 26th, right?


8 A. Well, when you say “retain,” they signed an


9 agreement on the 24th. As I said, they may have


10 signed — they did sign one earlier that covered


11 different matters. And that’s just the formal


12 retaining. That doesn’t mean I wasn’t their


13 attorney. I was their attorney, as far as I


14 understood, whenever they were talking to me about


15 these matters, whether they signed an agreement or


16 not.


17 Q. Now, without going into any attorney-client


18 privileged information, which is obviously


19 confidential, when you wrote a letter to Geragos on


20 the 26th, which is two days after you were retained,


21 the basis for your information in the letter had to

22 have been your client, correct?


23 A. Yes.


24 Q. And you suggested in the letter that Mr.


25 Jackson had relentlessly hounded and harassed the


26 children, right?


27 A. Yes.


28 Q. You never witnessed that yourself, correct? 4336


1 A. Correct.


2 Q. You said that Mr. Jackson had hounded,


3 harassed the mother almost daily since they left


4 Neverland, correct?


5 A. Yes.


6 Q. You never witnessed that. You just wrote a


7 letter based on the information given to you, right?


8 A. Yes.


9 Q. You suggested that Mr. Jay Jackson had been


10 harassed, correct?


11 A. Can you point me to where I said that?


12 Q. Sure. Right in the middle of that Paragraph


13 No. 1.


14 A. Yes.


15 Q. Was Jay Jackson your client at the time?


16 A. No.


17 Q. You suggested in the letter to Mr. Geragos


18 on March 26th that there had been banging on the


19 Arvizo’s door at all hours, correct?


20 A. Yes.


21 Q. And certainly you never personally witnessed


22 that, right?


23 A. Right.


24 Q. That came from your discussions with your


25 clients, right?


26 A. Right.


27 Q. You said disturbing notes had been left,


28 correct? 4337


1 A. Are you in the same paragraph?


2 Q. Yes. A little further down.


3 A. Yes.


4 Q. And that information came from your clients,


5 correct?


6 A. Yes.


7 Q. You said on March 26th, your clients


8 believed that Mr. Jackson was illegally


9 eavesdropping on their phone conversations, right?


10 A. Yes.


11 Q. And it was your understanding they weren’t


12 living at Neverland at the time, right?


13 A. Right.


14 Q. That information, of course, came from your


15 clients, right?


16 A. Right.


17 Q. At no time in that letter to Mark Geragos of


18 March 26th did you ever mention anything about child


19 molestation, right?


20 A. Right.


21 Q. Now, you talked about wanting passports and


22 visas returned, correct?


23 A. Yes.


24 Q. And at some point you learned that Mr.


25 Geragos had turned the passports in to this court,


26 correct?


27 A. I think so. But that might have been a few


28 weeks ago. Or even last week. I don’t even know 4338


1 how I learned about it, but —


2 Q. But you heard about it at some point, right?


3 A. I think so. It rings a bell.


4 Q. That Mr. Geragos had arranged to deposit


5 those passports in this courthouse?


6 MR. ZONEN: I don’t know that this witness


7 has personal knowledge. Lack-of-foundation


8 objection.


9 THE COURT: Sustained.


10 Q. BY MR. MESEREAU: Nowhere in this letter of


11 March 26th that you wrote to Mr. Geragos on behalf


12 of the Arvizos is there any mention of alcohol,


13 correct?


14 A. Correct.


12 Q. Now, in this letter of March 26th to Mr.


13 Geragos, there is no mention of the Arvizo family


14 ever being falsely imprisoned, correct?


15 A. I believe that’s correct.


16 Q. And in this letter of March 26th to Attorney


17 Mark Geragos, there’s no mention of the Arvizo


18 family ever being kidnapped, correct?


19 A. Correct.


20 Q. In this letter of March 26th, 2003, to Mr.


21 Geragos that you wrote, there’s no mention of any


22 extortion, right?


23 A. I believe that’s correct. I haven’t read


24 this word for word, but it sounds right.


25 Q. Okay. When you sent this letter to Mr.


26 Geragos on March 26th, 2003, two days after you had


27 been retained by the Arvizos, did you ever call the


28 police to complain about false imprisonment, 4340


1 kidnapping, molestation or alcohol?


2 A. No.


3 Q. Now, you asked for the return of personal


4 property to the Arvizos in this March 26th, 2003,


5 letter to Geragos, right?


6 A. Yes.


7 Q. And your understanding was that this


8 personal property was stored somewhere, correct?


9 A. Yes.


10 Q. How did you know it was stored somewhere?


11 A. I don’t recall specifically how I learned —


12 well, without violating the attorney-client


13 privilege, I really can’t go into it more.


14 Q. Okay. Okay. But clearly the letter says


15 you want the keys to all locations and facilities in


16 which this property has been stored, right?


17 A. Where are you?


18 Q. Page two, the very beginning.


19 A. Yes.


20 Q. Okay. Now, in this letter you wrote on


21 March 26th, you said that your clients wanted copies


22 of all tapes, films, audio recordings, photographs,


23 images on film, et cetera, of your clients, the


24 Arvizos, correct?


25 A. Yes.


26 Q. And the reason for that was, you, as their


27 lawyer, thought that any tapes or recordings of the


28 Arvizos may have monetary value, correct? 4341


1 A. Well, that gets into the work-product


2 doctrine, my opinions and thoughts, and I’m not


3 waiving that.


4 Q. Okay.


5 A. So I can’t tell you what I was thinking or


6 why I was thinking it.


7 Q. But you wanted the tape or film of the


8 Arvizos that was made in the home in the San


9 Fernando Valley within the last two months, right?


10 A. Yes.


11 Q. Okay. Have you ever seen that?


12 A. No.

In this excerpt, Dickerman testified about the legal threats he made towards Jackson on behalf of the Arvizos, in the event that he did not meet their demands for the return of their personal effects:

20 Q. Okay. Now, in this letter you wrote on


21 March 26th, you said that your clients wanted copies


22 of all tapes, films, audio recordings, photographs,

23 images on film, et cetera, of your clients, the


24 Arvizos, correct?


25 A. Yes.


26 Q. And the reason for that was, you, as their


27 lawyer, thought that any tapes or recordings of the


28 Arvizos may have monetary value, correct? 4341


1 A. Well, that gets into the work-product


2 doctrine, my opinions and thoughts, and I’m not


3 waiving that.


4 Q. Okay.


5 A. So I can’t tell you what I was thinking or


6 why I was thinking it.


7 Q. But you wanted the tape or film of the


8 Arvizos that was made in the home in the San


9 Fernando Valley within the last two months, right?


10 A. Yes.


11 Q. Okay. Have you ever seen that?


12 A. No.


13 Q. All right. You also wanted Mr. Geragos, in


14 your letter of March 26th, 2003, to provide you with


15 any releases that may have been signed by any Arvizo


16 concerning the show “Living with Michael Jackson,”


17 right?


18 A. Yes.


19 Q. And please tell the jury what you meant by


20 “release” in that letter of March 26th.


21 A. Well, typically before a production is


22 mounted, whether it’s television or movies or


23 anything that depicts an individual — I shouldn’t


24 say “generally.” Very often, if people are smart,


25 they get a release from the person who’s the subject


26 of the show, and that then protects the producers


27 and everybody else involved with the show from


28 liability from the individual who is depicted. 4342


1 Q. Was it your understanding releases had been


2 signed?


3 A. It’s my understanding that some releases,


4 some purported releases, had been signed for some


5 purpose.


6 Q. Okay.


7 A. Some —


8 Q. And you wanted those back, right?


9 A. Yes.


10 Q. Okay. You made a statement that the Arvizos


11 were hereby revoking any release they had signed in


12 favor of Mr. Jackson, right?


13 A. Yes.


14 Q. And you were making a claim that any such


15 release was obtained by fraud or undue influence,


16 correct?


17 A. Well, more fully, undue influence, fraud,


18 misrepresentation, false pretenses and/or duress.


19 Q. Okay. But you mention specifically the word


20 “fraud,” don’t you?


21 A. Yes.


22 Q. Now, as a civil litigator, you’re aware of


23 how long one has to file a fraud claim against


24 someone else in a civil suit, correct?


25 A. Yes.


26 Q. And what I’m referring to is what is called


27 a statute of limitations, correct?


28 A. Correct. 4343


1 Q. What is the statute of limitations for


2 filing a claim for fraud in civil court?


3 A. Three years from the fraud or from the time


4 that the plaintiff should have known about it.


5 Q. And based on the date of your letter, Janet


6 Arvizo would have till approximately some date in


7 2006 to file a fraud claim against Mr. Jackson if


8 she chose to, correct?


9 A. I don’t know. I don’t know when the


10 actionable events would have occurred or what


11 exactly the fraud action would have involved.


12 Q. Well, you refer to fraud, correct?


13 A. Correct.


14 Q. You refer to fraud in a specific context,


15 correct?


16 A. Right.


17 Q. The context in which you refer to fraud is a


18 suggestion that any releases signed were


19 fraudulently induced, true?


20 A. Right. So it would be three years from the


21 fraudulent inducement or the time when the plaintiff


22 should have discovered it.


23 Q. Okay. And you threaten Mr. Geragos with a


24 civil restraining order, true, in the last


25 paragraph?


26 A. Well, I wouldn’t say “threaten.” I say that


27 this is what we intended to do.


28 Q. Did you ever do that? 4344


1 A. It wasn’t against Mr. Geragos.


2 Q. It involved Mr. Jackson, true?


3 A. Yes.


4 Q. You were threatening to seek a civil


5 restraining order against Mr. Jackson, correct?


6 A. I’ll take issue again with your description


7 of “threat.”


8 Q. Well —


9 A. But we don’t need to quibble about that. I


10 suppose that’s essentially true.


11 Q. When you used the following words, “His


12 failure to heed this demand will force my clients to


13 seek a civil restraining order and perhaps to


14 vindicate their rights in other legal ways,” that


15 was a form of a legal threat, wasn’t it?


16 A. All right.


17 Q. You said if the items weren’t returned by


18 April 1st, 2003, you would seek a civil restraining


19 order, right?


20 A. No, there is not a restraining order with


21 regard to return of items. The restraining order


22 would only be related to the improper conduct, the


23 harassment, the intimidation.


24 Q. Okay. Did you ever seek that civil


25 restraining order?


26 A. No.

Dickerman describes in this excerpt how his relationship with Mark Geragos became “hostile” after Geragos made arrangements to have furniture belonging to the Arvizos delivered to his office. Mesereau also got him to admit that he never mentioned to Geragos anything about the Arvizo family being held against their will, molested, or given alcohol; notice how Dickerman said “there was no reason to do that”!

25 Q. On March 31st, 2003, you did a memo to your


26 file about a phone call from Mark Geragos, right?


27 A. I don’t recall the date, but I know there


28 was a typed memo to the file about a conversation 4347


1 with Mr. Geragos.


2 Q. And that’s when you — excuse me, let me


3 rephrase that.


4 In that call to Mark Geragos that’s referred


5 to in that memo, you talk about him telling you he


6 thinks there either is a vault or two of storage


7 with the contents of the Arvizos’ property, right?


8 A. If you give me a copy of that, or give me a


9 moment to try to dig up my own, I will be able to


10 answer that.


11 Q. I can show it to you, if it’s easier.


12 A. It will be a little quicker.


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


14 Thank you.




16 Q. BY MR. MESEREAU: Have you had a chance to

17 review that memo?


18 A. Yes.


19 Q. Does it refresh your recollection about the


20 phone call with Mr. Geragos?


21 A. Not really. It refreshes my recollection as


22 to the memo that I typed or had typed after the


23 conversation.


24 Q. Well, according to your memo, you said Mr.


25 Geragos told you he thought there were passports,


26 true?


27 A. Yes.


28 Q. According to your memo, Janet Arvizo told 4348


1 you the harassing behavior had just stopped,


2 correct?


3 A. I really need to see that again, or I have


4 to find my own copy.


5 Q. I can show you mine, if you want.


6 A. Okay.


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






10 Q. BY MR. MESEREAU: Have you taken a look at


11 the memo?


12 A. Yes.


13 Q. Does it refresh your recollection about your


14 discussions with Mr. Geragos?


15 A. It refreshes my recollection of the memo.


16 I don’t recall specifically having the contents of


17 the conversation. It was a long time ago.


18 Q. Was it your understanding that Janet told


19 you that the harassment had just stopped?


20 A. If it says that there, then, yes, it did.


21 She did.


22 Q. Well, it says that there, doesn’t it?


23 A. Yes.


24 Q. Okay. All right. You talked to Mr. Geragos


25 about the passports in a phone conversation,


26 correct?


27 A. Yes.


28 Q. And he told you he thought they existed, 4349


1 right?


2 A. Yes.


3 Q. You also asked him how to get in touch with


4 Bashir, correct?


5 A. Yes.


6 Q. And he said he would try to help you do


7 that, right?


8 A. Can you quote that language? I know he


9 mentioned something about Granada.


10 Q. “I also asked him about Granada, whether he


11 could find out how to get in touch with Bashir. He


12 said he thought it was Granada Productions, and I


13 told him I knew of Granada Television and Granada


14 LPC.” Okay?


15 A. Yes.


16 Q. “He said he would try to get me a sheet


17 showing the proper company,” right?


18 A. Okay.


19 Q. How would you describe your relationship


20 with Mr. Geragos at this point?


21 A. That was March 27th?


22 Q. Yes.


23 A. Well, at that point he had not turned


24 hostile.


25 Q. Okay.


26 A. So I would say it was just a regular old


27 relationship with opposing counsel.


28 Q. At what point do you think he turned 4350


1 hostile?


2 A. Well, he didn’t respond to any of the


3 requests, except in that phone conversation where


4 he — whatever he said about the passports. He


5 never returned anything. He didn’t respond to


6 letters. You go through these letters and I keep on


7 recounting, “I’ve written to you this date, this


8 date, this date, this date, this date. Every time


9 I’ve asked you, say, ‘Please return these things,


10 you don’t respond, you don’t give them to me, you


11 don’t give me the contents of the storage. There’s


12 no reason not to return the passports, the visas,


13 the birth certificates. You can get those to me


14 right away.”


15 And then especially when he pulls this


16 shenanigan of having the items delivered to my


17 office — not “the items,” but apparently two vaults


18 of furniture in boxes and whatnot that I had


19 specifically never asked to have returned on a date


20 that anybody who had called my office would know I


21 wasn’t going to be there, when we had no


22 arrangements whatsoever. And then he has the nerve


23 to write me later on that I had given consent


24 somehow, which of course I never had. That was


25 probably long past the time where I thought he had


26 turned hostile.


27 But obviously he wasn’t responding, and it


28 was very surprising to me to have a lawyer of 4351


1 supposedly his caliber being such a hostile and


2 oppositional, adversarial person, when there was


3 really nothing at that point that I knew to be


4 adversarial about.


5 Q. What you’re telling the jury is that a truck


6 came to your office or somebody had been instructed


7 to deliver the things that you requested and nobody


8 would accept them at your office, right?


9 A. I wasn’t there. All I know is what the


10 manager of the facility told me.


11 Q. Okay. And what you learned from the manager


12 was that a truck of furniture and goods arrived, and


13 that nobody would accept them, true?


14 A. Yes.


15 Q. Now, in all of these conversations you had


16 with Mark Geragos on behalf of the Arvizos, at no


17 time did you mention to him anything about child


18 molestation, correct?


19 A. Well, I don’t think I had more than one or


20 two conversations.


21 Q. And you never mentioned anything about child


22 molestation, correct?


23 A. That’s correct. That wasn’t the purpose of


24 the communication.


25 Q. You never mentioned anything about wine


26 allegedly being given to any of the Arvizo children,


27 correct?


28 A. Correct. There was no reason to do that. 4352

To be continued:

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