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May 9th, 2005 Trial Analysis: Francin Contreras, Gayle Goforth, Violet Silva, Ramon Velasco, Joseph Marcus, Part 1 of 4

January 27, 2015



The next defense witness was Francin Contreras, a former Neverland employee who worked at the ranch from 1991 through 1993. She was subpoenaed to testify in order to refute the testimony of Adrian McManus, who claimed to have witnessed Jackson abusing Macaulay Culkin in 1993.

Contreras testified that McManus always spoke good about Jackson, and never confided in her that she witnessed any inappropriate sexual contact by Jackson towards any child. She also testified that she observed several stolen items from Neverland at McManus’s home, including watches, clothes, and toys that were meant for underprivileged children.




27 Q. Good morning. Miss Contreras, were you

28 known by another name at one point? 9441

1 A. Francin Orozco.

2 Q. Okay. And Contreras is —

3 A. My married name.

4 Q. Your married name. So you were married

5 since then?

6 A. Yes.

7 Q. All right. And have you worked at Neverland

8 Valley Ranch?

9 A. Yes.

10 Q. When did you first start working there?

11 A. I believe it was ‘91, ‘92. I’m not sure.

12 ‘91.

13 Q. In 1991. And how long did you work there?

14 A. About two years.

15 Q. How are you presently employed?

16 A. I’m at Foods Co., Lompoc, California, lead

17 cashier.

18 Q. All right. Now, in the time period of 1991

19 and ‘92, did you have occasion to work with Adrian

20 McManus?

21 A. Yes.

22 Q. Can you describe your relationship with Ms.

23 McManus?

24 A. A good friend at that time.

25 Q. And at that time, did you go to her house,

26 she go to your house?

27 A. Yes.

28 Q. Did you know her husband? 9442

1 A. Yes.

2 Q. All right. Did you remain friends after you

3 stopped working at Neverland Ranch?

4 A. For a bit.

5 Q. Okay. During the time that you knew Ms.

6 McManus, did she ever make any statements to you

7 whatsoever with regard to the molestation charges

8 against or accusations against Mr. Jackson back at

9 that time, in 1993?

10 A. Never.

11 Q. What did she tell you, if anything?

12 You have to sit forward, first of all, a

13 little bit, because that microphone —

14 A. Oh, sorry.

15 Q. Everybody has that problem. You just have

16 to talk into the microphone.

17 A. All right.

18 Q. Did she say anything one way or the other


19 about the charges, and about Mr. Jackson?


20 A. Never. She always talked good about him.

21 Q. All right. Now, at one point, were you

22 aware that she filed a lawsuit against Mr. Jackson?

23 A. That’s when I didn’t talk to her no more.

24 We didn’t see each other.

25 Q. All right. What was — did you talk to her

26 at some point right at the end, right when that

27 breakup occurred? Did she tell you what she was

28 doing with her lawsuit, if anything? 9443

1 A. She just — well, meaning — I really don’t

2 know what you mean.

3 Q. Okay. Did she talk to you about her

4 lawsuit? You say you stopped seeing her at some

5 point after she filed the lawsuit, right?

6 A. Right.

7 Q. Okay. Did she tell you why she was filing a

8 lawsuit?

9 A. No.

10 Q. All right. Now, did you visit the house of

11 Mr. and Mrs. McManus?

12 A. Yes.

13 Q. Where did they live?

14 A. In Santa Maria.

15 Q. And did you visit there while Ms. McManus


16 was working for Mr. Jackson?


17 A. Yes.


18 Q. What did you observe at her house?


19 A. In all her rooms?


20 Q. Yeah. Let’s talk about — was there a room


21 that had some —


22 A. Yes.


23 Q. — Michael Jackson items?


24 Can you tell us about that?


25 A. She had hats that belonged to Mr. Jackson.


26 Pajamas. Watches, T-shirts. Items that belonged to


27 the ranch.


28 Q. Okay. Now, did you ever see her take items 9444

1 from the ranch?


2 A. Yeah.


3 Q. And how did she do that?


4 A. In a laundry basket. She used to take home


5 Mr. Jackson’s clothes. She said she was going to


6 iron them. But there was, like, a hat underneath


7 there, and you can’t iron a hat.

8 Q. Okay. Was there an occasion where you all

9 were asked to wrap Christmas presents for needy

10 children?

11 A. Yes.

12 Q. Sit a little closer. I’m sorry.

13 A. Yes.

14 Q. Everybody has to do it. It’s not

15 comfortable, sorry.

16 What can you tell us about that?

17 A. We were sent home — because there was,


18 like, lots of toys and gifts for the children. And


19 we really couldn’t do all the wrapping at the ranch,


20 because it was quite a bit, so we were asked to take


21 some of the toys home to wrap, and bring them back,


22 because they didn’t belong to us. And I noticed


23 that Adrian had kept some Super Soakers and other


24 items of toys for her son.

25 MR. SANGER: All right. Okay. Very well.

26 I have no further questions.

27 //

28 // 9445

Zonen made Contreras clarify exactly what she witnessed regarding McManus’s theft of Jackson’s clothes, and she testified that she thought it was actually part of her job duties to iron Jackson’s clothes at her own residence:



3 Q. I’m sorry, is it Miss Contreras or Mrs.

4 Orozco?

5 A. Contreras.

6 Q. Miss Contreras, was it more than one

7 occasion that you saw Adrian McManus taking a

8 laundry basket with items home?

9 A. Yes.

10 Q. Was that a fairly regular occurrence?

11 A. Yes.

12 Q. And would she stop to show you the items

13 that she had in the laundry basket?

14 A. She didn’t stop.

15 Q. So she wasn’t showing you what she had and

16 what she was taking home?

17 A. I seen them. We were walking together out

18 to her car.

19 Q. All right. And she would have it in a

20 laundry basket covered with items, but you would,

21 nonetheless, see the items because you were looking

22 through them?

23 A. No.

24 Q. You understood at the time that she was

25 stealing at that time?

26 A. No. I thought she was taking them home to

27 iron.

28 Q. She was taking a hat home to iron? 9446

1 A. That’s what I said before, how could you

2 iron a hat?

3 Q. That’s my question to you. Did you see on

4 each of the occasions that she took items home to

5 iron, she had items that you believe that she was

6 stealing?

7 A. No. She was taking them home to iron.

8 Q. All right. On only one occasion did she

9 take home an item that you believed she was

10 stealing?

11 A. No, because we were taking toys home, all of

12 us were, to wrap. And they were supposed to be

13 returned.

14 Q. I’m asking questions specifically about the

15 occasions when you saw her bringing items in a

16 laundry basket covered with laundry.

17 A. Right.

18 Q. Now, she did take items home to iron that

19 were Mr. Jackson’s items and she would bring them

20 back; is that right?

21 A. I don’t know if she brought them back. I

22 didn’t see her bring them back.

23 Q. Was that part of her job as you understood

24 it?

25 A. To take them home and iron, yes.

26 Q. It was part of her job to take items that

27 were, in fact, Mr. Jackson’s personal clothing, to

28 iron them for Mr. Jackson, and return them ironed to 9447

1 Mr. Jackson; is that correct?

2 A. I believe so.

3 Q. And she did that on a fairly regular basis?

4 A. Yes.

5 Q. She would work at home doing ironing for Mr.

6 Jackson?

7 A. I never seen her ironing them, so I couldn’t

8 tell you, sir.

9 Q. She would — she would take it — a laundry

10 basket with his clothing to iron and she would tell

11 you that that’s what she was doing?

12 A. Yes.

13 Q. You have no reason to believe she wasn’t

14 bringing them back; is that right?

15 A. Right.

16 Q. On one occasion you saw a felt hat that

17 didn’t need ironing?

18 A. Yes. I don’t know what she was doing. She

19 could have took it home to mend. I have no idea,

20 sir.

21 Q. She could have mended it and brought it back

22 the next day?

23 A. I suppose so.

24 Q. Did you ever ask her about that?

25 A. Nope.

26 Q. Did you ever ask her about the Super Soakers

27 that were in there?

28 A. No. 9448

Next, Zonen attempted to discredit Contreras by bringing up her past firing from Mervyn’s for trespassing, and then he quickly ended his cross examination:

1 Q. Miss Contreras, did you go to work for

2 Mervyn’s after you left Neverland?

3 A. Yes, I did.

4 Q. Did you get fired from Mervyn’s for


5 stealing?


6 A. No.


7 Q. Were you prosecuted for stealing from


8 Mervyn’s?


9 A. No, it was trespassing.


10 Q. Well, you were prosecuted for stealing; is


11 that right?


12 A. No, sir, it was trespassing.


13 Q. You were trespassing in the store that you


14 were working in —


15 A. No, sir. No.

16 Q. Were you not working in there at the time?

17 A. Yes, I was.

18 Q. You were prosecuted for trespassing in a

19 store that you were working in?

20 A. No, sir.

21 Q. Did — were you ordered by the court to make

22 restitution to Mervyn’s?

23 MR. SANGER: I’m going to object, Your

24 Honor, as to relevance.

25 THE COURT: Sustained.

26 MR. ZONEN: I have no further questions.

27 //

28 // 9449

Sanger asked Contreras to confirm that she saw a literal shrine to Jackson at McManus’s home, which consisted of stolen items from Neverland, and then ended his redirect examination. Zonen declined to further recross examine Contreras:



3 Q. At the McManus residence, was there a


4 particular room that was dedicated to the Michael


5 Jackson —

6 MR. ZONEN: Objection; exceeding the scope

7 of the cross-examination.

8 THE COURT: That’s true.

9 Did you want to reopen that?

10 MR. SANGER: Well, let me ask it a different

11 way. The Court may see where I’m going.

12 Q. Whether or not you saw things in the laundry

13 basket, did you see things from the ranch in Ms.

14 McManus’s house?

15 A. Yes, sir.

16 Q. And were they displayed in some fashion?

17 A. Yes.

18 MR. SANGER: All right. Okay. No further

19 questions.

20 MR. ZONEN: No questions.

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

22 MR. SANGER: Call Gayle Goforth.

23 THE COURT: Would counsel approach on this?

24 While she’s coming in, counsel approach. The

25 District Attorney filed an in limine statement.

26 (Discussion held off the record at sidebar.)

27 THE COURT: Good morning. I’m going to ask

28 you to face the clerk here, raise your right hand. 9450

Gayle Goforth was the next defense witness. She began working at Neverland in 1989 as a housekeeper, and was eventually promoted to supervisor. Adrian McManus was a subordinate of Goforth, and was perceived by Goforth and the other employees of having a change of attitude after she was placed in charge of cleaning Jackson’s bedroom suite.

The prosecution tried to prevent Goforth from testifying by submitted a pleading called “PLAINTIFF’S MOTION TO LIMIT PROPOSED TESTIMONY OF GAYLE GOFORTH AS A WITNESS FOR THE DEFENSE”, in which they argued that her testimony would be nothing but a character assassination of their “star witness” Janet Arvizo. The defense replied with “RESPONSE TO DISTRICT ATTORNEY’S TRIAL BRIEF RE: ADMISSIBLE EVIDENCE OF RELEVANT CHARACTER TRAITS”, in which they stated that the prosecution bolstered their ¶1108 case against Jackson by using disgruntled former employees and paid tabloid informants to testify about molestation they claimed to have witnessed, despite the fact that the alleged victims (Brett Barnes, Macaulay Culkin, and Wade Robson) all denied being abused, so they should be allowed to use witnesses to rebut them.

The court agreed, and Goforth was permitted to testify. Here’s her direct examination by Robert Sanger:



23 Q. Okay. Good morning.

24 A. Good morning.

25 Q. Do you know the gentleman seated right here?

26 A. Yes, I do.

27 Q. Who is that?

28 A. Michael Jackson. 9451

1 Q. All right. And how long have you known Mr.

2 Jackson?

3 BAILIFF CORTEZ: I need you to speak right

4 into the microphone.


6 I became employed at Neverland Valley Ranch

7 in 1989.

8 Q. BY MR. SANGER: All right. Now, every

9 single witness, even those with louder voices than

10 yours, has to sit right up to that microphone for

11 some reason it’s a little uncomfortable there. So

12 just try to project. You have a soft voice to start

13 with.

14 Okay. So you started working in 1989. And

15 what was your job when you started there?

16 A. I was a housekeeper.

17 Q. And did you eventually attain a different

18 position?

19 A. Yes, I did.

20 Q. And what was that?

21 A. I became supervisor of housekeeping.

22 Q. All right. And when did you become

23 supervisor of housekeeping?

24 A. In 1990.

25 Q. Now, did you know Adrian McManus?

26 A. Yes, I did.

27 Q. Did you know Ralph Chacon?

28 A. Yes, I did. 9452

1 Q. Did you know Kassim Abdool?

2 A. Yes, I did.

3 Q. Were they also employees at the ranch?

4 A. Yes, they were.

5 Q. Were any of them working under you?

6 A. Adrian was.

7 Q. Ms. McManus was on the housekeeping staff;

8 is that correct?

9 A. Yes, she was.

10 Q. And you were at that time the head of

11 housekeeping?

12 A. Yes, I was.

13 Q. What was her assignment when she first

14 started to work for you?

15 A. She was a housekeeper.

16 Q. Did she eventually get a new designation?

17 A. Yes, she did.

18 Q. And what was that?

19 A. She became — she — a caretaker of Mr.

20 Jackson’s room.

21 Q. All right. Now, when you say “Mr. Jackson’s

22 room,” what are you talking about?

23 A. Primarily — pardon me, primarily cleaning

24 his room and taking care of his personal items.

25 Q. All right. Now, first of all, if you’d like

26 some water you can pour yourself some there.

27 A. Okay. Thank you.

28 Q. All right. When you say “his room,” we’re 9453

1 talking about the suite that we’ve all heard about

2 that has the two floors and so on?

3 A. Yes.

4 Q. And part of her responsibilities were to

5 make sure that the place was clean, I take it.

6 A. Yes.

7 Q. And she also was responsible for making sure

8 that his laundry was done; is that correct?

9 A. Yes.

10 Q. Now, did you have facilities at the ranch to

11 do laundry?

12 A. Yes, we did.

13 Q. And during that period of time and perhaps

14 today, but during that period of time, was the

15 laundry done at the ranch?

16 A. Some of it was. A lot of the things were

17 sent to the dry cleaners.

18 Q. I’m sorry, not dry cleaning, but the actual

19 laundry, if you were going to wash sheets or wash

20 clothing that did not need to be dry cleaned.

21 A. Yes.

22 Q. And could it be ironed there?

23 A. Yes.

24 Q. You had a room to do that in; is that

25 correct?

26 A. Yes, we had a laundry room.

27 Q. All right. Was it part of Ms. McManus’s

28 duties to take clothing home, Mr. Jackson’s clothing 9454

1 home, to iron it?

2 A. Not necessarily.

3 Q. Okay. And during that period of time

4 when — can you tell us when Ms. McManus was there,

5 to the best of your recollection? Let me withdraw

6 that.

7 Why don’t you just tell us when she was

8 taking care of Mr. Jackson’s room.

9 A. I believe she started cleaning his room

10 in — around 1990, early 1991.

11 Q. Okay.

12 A. Until 1994.

13 Q. All right. Now, in 1994, did Ms. McManus


14 stop showing up for work?


15 A. Yes, she did.


16 Q. Do you recall roughly when that was?


17 A. I don’t remember exactly when.


18 Q. Sometime in 1994, though?


19 A. Yes.


20 Q. And the last time — when I say “the last


21 time,” she stopped showing up for work and then she


22 just never came back; is that correct?


23 A. That’s correct.


24 Q. Before that happened, do you recall her


25 taking any leave or being absent from work?


26 A. A lot, yes.

27 Q. And was Ms. McManus — what was her attitude

28 towards her position; do you recall? 9455

1 A. Oh, gosh. Well, she changed — when she was

2 a housekeeper, when she became — to take care of

3 Mr. Jackson’s room, she changed her attitude.

4 Q. And what did her attitude change to?


5 MR. ZONEN: I’ll object as speculative and


6 irrelevant.


7 THE COURT: Overruled.


8 You may answer.


9 THE WITNESS: I can answer?


10 Q. BY MR. SANGER: Yes.


11 A. Like she was above everybody.

12 Q. Was she a hard worker?

13 MR. ZONEN: I’ll object as irrelevant.

14 MR. SANGER: I’ll withdraw it.

15 Q. All right. Now, let me move ahead. When

16 did you stop working at the ranch?

17 A. In 2002.

She was still employed at Neverland during the Arvizo’s first few visits to the ranch. (Their initial visit was in August 2000, and there were a few more visits in 2000, no visits in 2001, and a few visits throughout 2002). Janet Arvizo asked Goforth if she would give her a job at Neverland because she was having “money problems” (despite having already received her $152k settlement from JC Penney), and she was willing to move closer to Neverland because she lived too far away to commute every day, but Goforth replied that Janet should be more concerned about her son’s health.

18 Q. All right. Were you at the ranch at the

19 time the Arvizo family came to visit?

20 A. Yes, I was.

21 Q. And do you remember — what do you remember

22 about the Arvizo family?

23 A. They were at the — their first time that

24 they came, they were very concerned about their

25 son’s health.

26 Q. Okay. And that was Gavin?

27 A. Yes.

28 Q. And he was not doing well at that time? 9456

1 A. No, he wasn’t.

2 Q. How many times did you see the Arvizo family

3 at the ranch before you left your employment there?

4 A. The first time I saw the whole family was

5 their first arrival. Thereafter, the father and the

6 two boys came back, I would say, maybe four or five

7 times.

8 Q. Okay. So the first time the whole family

9 was there, that means the mother was there as well,

10 is that what you’re saying?

11 A. Yes.

12 Q. Do you remember her name?

13 A. Janet.

14 Q. Did you have any interaction with Janet

15 Arvizo?

16 A. Yes, I did.

17 Q. And what interaction did you have?


18 A. Shortly after their arrival, she started


19 talking to me about being concerned about her son’s


20 health, and that they were having money problems,


21 and that — she asked me if I would give her a job


22 at the ranch.


23 Q. And what was your response to that?


24 A. I told her that she needed to be more


25 concerned about her son and that it was a long ways


26 to —

27 MR. ZONEN: I’m going to object to the

28 response as hearsay. 9457

1 THE COURT: Sustained.

2 MR. ZONEN: And irrelevant. Move to strike.

3 THE COURT: Stricken.

4 MR. SANGER: All right. Not for the truth

5 of the matter, Your Honor, but for the purpose of

6 the response, if I may.

7 THE COURT: The response that Janet makes to

8 her statement?

9 MR. SANGER: Yes, that’s correct.

10 THE COURT: All right.

11 Q. BY MR. SANGER: Did you say anything


12 specifically about the distance between her home and


13 the ranch?


14 A. Yes, I did.


15 Q. And what did — what did Janet Arvizo say in


16 response to that?


17 A. She told me she would move to the valley in


18 order to be closer to the ranch.


19 Q. When you say “the valley,” you mean the


20 Santa Ynez Valley?


21 A. Yes, I do.

Sanger wrapped up his direct examination by having Goforth explain Jackson’s alcohol consumption habits (he was a light drinker who she only witnessed drinking at dinner time), and attempted to have Goforth testify about Jackson’s undressing habits and personal demeanor regarding feeling comfortable undressing around others, but Judge Melville sustained Zonen’s objections. However, Goforth was able to confirm that Jackson was private and didn’t get undressed in front of others:

22 Q. Now, — excuse me, I’m sorry.

23 Going back to the entire time that you

24 worked at the ranch, did you have occasion to see

25 Mr. Jackson drink alcohol?

26 A. A few occasions.

27 Q. All right. And roughly — let’s put it this

28 way. When did you see him drink? What occasions 9458

1 would you see him drink alcohol?

2 A. At mealtime, dinnertime.

3 Q. Okay. Now, when you — at some point during

4 this period of time, or from time to time, you

5 actually took care of Mr. Jackson’s room as well; is

6 that correct?

7 A. Yes, I did.

8 Q. And so you were one of the staff people who

9 was allowed to go into his room to straighten it up

10 or do whatever needed to be done; is that correct?

11 A. That’s correct.

12 Q. And also to supervise people who would be

13 doing that; is that right?

14 A. Yes.

15 Q. All right. Did you ever see any bottles of


16 alcohol or other evidence of alcohol strewn about?


17 Can you explain what you might see?


18 A. I don’t recall.


19 Q. Okay. So you might see a glass or something


20 but you wouldn’t see — you wouldn’t see alcohol


21 just lying around his room?


22 A. No.

23 Q. All right. And let me also ask you about

24 Mr. Jackson and his personal behavior. Would you

25 say — can you describe his behavior as far as being

26 outgoing or shy or —

27 MR. ZONEN: I’m going to object as

28 irrelevant, Your Honor, and vague. 9459

1 THE COURT: Sustained.

2 MR. SANGER: On vague?

3 THE COURT: Both.

4 MR. SANGER: Both? Okay.

5 Q. Did you have any occasion to observe whether


6 or not Mr. Jackson would change his clothes in front


7 of anyone? For instance, if you were in the room


8 cleaning, would he be changing his clothes in there?


9 MR. ZONEN: Judge, that’s irrelevant as to


10 whether he would change his clothes in her presence.

11 THE COURT: Sustained.


12 MR. SANGER: All right.


13 Q. Were there occasions where you came in and


14 Mr. Jackson might be in the process of changing his


15 clothes, changing a shirt or something?


16 A. No. He was very private.

17 MR. SANGER: All right. Okay. I have no

18 further questions.

Under cross examination, Goforth was asked to elaborate in further detail her interview with the defense’s private investigator, in which she described the conversation she had with Janet Arvizo about a possible job at Neverland. Goforth testified that Janet inquired about a job as a maid at Neverland, and she tried to dissuade Janet from the idea for a variety of reasons, including the impropriety of having a guest of Neverland subsequently apply for a job there:



22 Q. Miss Goforth, you were recently interviewed

23 by an investigator for the defense; is that correct?

24 A. Yes, I was.

25 Q. And you were asked questions about that

26 conversation that you had with Janet Arvizo; is that

27 right?

28 A. Yes, I was. 9460

1 Q. Now, that conversation that you had with

2 Janet Arvizo was approximately August of 2000, was

3 it?

4 A. I don’t recall exactly. No.

5 Q. When did you leave Neverland Ranch?

6 A. I left in 2002.

7 Q. All right. You only saw Janet Arvizo on one

8 single occasion when she was at Neverland; is that

9 right?

10 A. One occasion, yes.

11 Q. And she was there with her husband and her

12 three children; is that correct?

13 A. That’s correct.

14 Q. They were there for one night, two nights?

15 A. They were there for a couple of days.

16 Q. Couple days? Did you interact with her on

17 more than one occasion during that time?

18 A. Well, yes.

19 Q. Now, you told the investigator for Mr.


20 Jackson not that she was prepared to move to the


21 valley, but that she was prepared to sleep in her


22 car outside Neverland; is that right?


23 A. Yes.


24 Q. Did you just change it to say that she was


25 prepared to live in the valley?

26 MR. SANGER: Objection; argumentative.

27 THE COURT: Sustained.

28 THE WITNESS: No, I wasn’t able to complete 9461

1 my —

2 THE COURT: Just a moment. Just a moment.

3 I sustained the objection.

4 Next question.

5 Q. BY MR. ZONEN: Now, the statement that you


6 gave was that she was prepared to sleep in her car


7 right outside the doors to Neverland; is that right?


8 A. Yes.


9 Q. All right. Now, did you ask her if she had


10 a car?


11 A. She stated that she didn’t even have a car


12 and that they were living in separate quarters.


13 Q. All right. So she told you she didn’t have


14 a car but she would sleep in the car she didn’t have


15 outside the ranch?

16 MR. SANGER: Objection; argumentative.

17 THE COURT: Sustained.

18 Q. BY MR. ZONEN: Ma’am, what exactly did she

19 tell you? Did she tell you she had a car?

20 A. No, she didn’t say that she had a car.

21 Q. She told you she was going to get a car?


22 A. No, she didn’t say that. She said that —


23 the conversation was, she asked me if she could have


24 a job at Neverland. I told her that it was a long


25 ways from — I assumed that they lived in the Los


26 Angeles area. And it was a long ways to come. She


27 said that she would move to the valley in order to


28 be closer to the ranch. And I told her that the 9462


1 rents and that were very expensive in the area.


2 Just trying to dissuade her from this.


3 And she said, “Well, I’ll come and I’ll


4 sleep in my car if I have to. I just need money. I


5 need to work.”


6 Q. Go ahead.


7 A. “I need” — “I need a job. I need to work.


8 We’re living in separate quarters, and we need the


9 money. Gavin’s very sick,” to that effect.


10 Q. All right. Did you take a job application


11 to give her?


12 A. No, I did not.

13 Q. All right. You decided at that time that

14 she wasn’t qualified to clean rooms at Neverland?

15 MR. SANGER: Objection; argumentative.

16 THE COURT: Sustained.

17 Q. BY MR. ZONEN: Did you make a determination


18 as to why she shouldn’t work at Neverland?


19 A. Well, I just saw her being a guest and


20 everything, that it wasn’t appropriate to — I had


21 several guests come to the ranch and ask. Everybody


22 thought it was fun to work at the ranch. And —


23 Q. But she asked specifically for a job as a


24 maid; is that right?


25 A. Yes, she did.


26 Q. About that time that job made about what,


27 eight dollars an hour?


28 A. Yes. 9463

1 Q. You knew, did you not, that she, in fact,

2 had a job, was working in Los Angeles at the time?

3 A. No, I did not.

4 Q. And in fact, she had an apartment at that

5 time?

6 A. I didn’t know. I didn’t — my job was not

7 to stand and carry conversations with the guests and

8 that. I was trying to dissuade her from, and get

9 away — out of the conversation.

Once again, Zonen tried to discredit Goforth by going into the reasons for her dismissal from Neverland. She resigned after being accused of selling Jackson’s furniture without permission because she felt that she was treated unfairly, and was offended at the accusation:

10 Q. Miss Goforth, your job at Neverland Ranch

11 ended when?

12 A. In 2002.

13 Q. And that ended because you were being

14 disciplined for stealing; is that right? Is that

15 right?

16 MR. SANGER: Objection; lack of foundation.

17 MR. ZONEN: We’re going to get there.

18 MR. SANGER: And move to strike counsel’s

19 remarks.

20 THE COURT: Sustained.

21 Q. BY MR. ZONEN: Were you, in fact, suspended


22 from your job because you were taking things that


23 you weren’t entitled to take?


24 A. I was suspended from my job over the sale of


25 some furniture that I thought was allowed to be


26 done. I was just doing what I was told by another


27 party.

28 Q. All right. So you took some items from 9464

1 Neverland and they then accused you of taking it

2 without the permission of the owner; is that right?

3 A. I didn’t personally take the items.

4 Q. Somebody else took them and you sold them?

5 A. I didn’t sell them. It was arrangements

6 that were made through someone else.

7 Q. And ultimately who made the decision to

8 discipline you for that?

9 A. I believe Mr. Jackson.

10 Q. All right. And thereafter, you terminated

11 your position voluntarily; is that right?

12 A. That’s correct.

13 Q. Because you were offended as to how you were

14 treated?

15 A. Yes, I was.

16 Q. In fact, there’s a fair amount of

17 controversy at Neverland about who can take what and

18 when they can take it; is that right?

19 MR. SANGER: Objection. Vague and

20 argumentative.

21 THE COURT: Overruled.

22 You may answer.

23 Q. BY MR. ZONEN: Please answer the question.

24 A. Could you repeat the question?

25 MR. ZONEN: Could the reporter read that

26 back?

27 THE COURT: I’ll have the reporter read it

28 back. 9465

1 (Record read.)

2 THE WITNESS: I don’t believe so. I believe


3 that no one should take anything at any time without


4 Mr. Jackson’s permission.

5 Q. BY MR. ZONEN: And — all right. But a lot

6 of people have been accused of taking things from

7 Neverland; is that right?

8 MR. SANGER: Objection. Vague as to time

9 and —

10 THE COURT: Sustained.

11 Q. BY MR. ZONEN: You’ve actually turned in

12 people for taking things at Neverland, haven’t you?

13 A. No.

14 Q. You’ve never turned in people for taking

15 things at Neverland?

16 A. Not personally myself, no.

17 Q. Didn’t you turn in Ramon Velasco for taking

18 something at Neverland?

19 A. No, I did not.

20 Q. And you never went back to work at Neverland

21 after that; is that correct?

22 A. That’s correct.

23 MR. ZONEN: No further questions.

Sanger gave Goforth an opportunity to clarify the transaction that got her fired; she was given orders to sell some of Jackson’s furniture, but not for her own benefit, but the benefit of Neverland.



27 Q. All right. With regard to this business

28 about selling items from Neverland, did you ever 9466

1 sell anything from Neverland for your own personal

2 benefit?

3 A. I did not.

4 Q. Was there somebody else who was in a

5 position higher than yours who directed that certain

6 items be sold?

7 A. Yes, there was.

8 Q. And was — were they being sold for your

9 benefit?

10 A. No.

11 Q. They were being sold for the benefit of the


12 ranch?


13 A. Yes, they were.

14 Q. And the problem was that apparently —

15 MR. ZONEN: Objection; leading.

16 MR. SANGER: That’s true. Let me withdraw

17 the beginning of that. I didn’t get it out. But it

18 would have been leading, I agree.

19 Q. What was the problem that gave rise to the


20 people involved in selling these items eventually


21 being disciplined in some way or being reprimanded?


22 MR. ZONEN: That’s vague and compound.


23 THE COURT: Overruled.


24 You may answer.


25 THE WITNESS: Apparently Mr. Jackson didn’t


26 want the furniture sold.

27 Q. BY MR. SANGER: Okay. Were the proceeds of


28 the sale intended to go to Mr. Jackson and to the 9467


1 ranch?


2 A. For the ranch, yes.


3 Q. Okay. So nobody was stealing anything; is


4 that correct?


5 A. That’s correct.

6 MR. SANGER: Okay. Thank you. I have no

7 further questions.

Goforth was asked for further details about her dismissal, and she testified that she assumed that Jackson wanted to discipline her, but she wasn’t sure, and she left Neverland immediately after this incident and never returned:



11 Q. Can we assume you told Mr. Jackson all the

12 things you just told us about this incident?

13 A. No, I did not.

14 Q. You did not? Did you have any conversation

15 with Mr. Jackson thereafter?

16 A. No, I did not.

17 Q. How did you find out that it was Mr. Jackson


18 who disciplined you?


19 A. I assumed that it was. I didn’t know that


20 for a fact.


21 Q. Did you tell anybody about what had


22 happened?


23 A. No, I immediately left the ranch.

24 MR. ZONEN: No further questions.

25 MR. SANGER: And I have no further

26 questions, Your Honor.

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

28 Call your next witness. 9468

1 MR. SANGER: Call Violet Silva.

2 THE COURT: Please remain standing. Face the

3 clerk here and raise your right hand.

The next defense witness was Violet Silva, a safety coordinator at Neverland who began working there in 1991. In this excerpt, she testified about her background and job duties at Neverland:



17 Q. I’ll let you get some water there first.

18 So take your time.

19 A. Thank you.

20 Q. All right. Miss Silva, how are you

21 employed?

22 A. I’m employed by Neverland Ranch as a safety

23 coordinator at this time.

24 Q. Okay. Now, everybody’s having this problem

25 in this courtroom. You have to sit real close.

26 A. Okay.

27 Q. It’s not — there we go. That might help.

28 And then when the air conditioner is on it 9469

1 makes it a little harder to hear.

2 A. All right.

3 Q. So repeat that again, please.

4 A. I am employed by Neverland Ranch as a safety

5 coordinator at this time.

6 Q. And where is your office?

7 A. My office is located in the administration

8 building.

9 Q. Where is the administration building with

10 respect to the ranch house, I mean, to the actual

11 house, Mr. Jackson’s house?

12 A. It’s southwest approximately less than a

13 quarter mile.

14 Q. Is it up on a hill?

15 A. Yes.

16 Q. All right. And is it outside the manicured

17 grounds of Neverland?

18 A. I would say the immediate grounds, yes.

19 Q. Not to say the administration area isn’t

20 manicured, but there is a place that’s all grass and

21 pastures and so on, right?

22 A. Yes.

23 Q. And it’s outside of that, correct?

24 A. Correct.

25 Q. Can you describe the kind of structure that

26 houses the administrative offices?

27 A. It’s a converted barn. And it has one large

28 office area with a conference area. It has two 9470

1 smaller offices. It also stations a fire engine in

2 the bay and one other small office and two — three

3 bathrooms, excuse me, and some storage areas.

4 Q. Okay. So let’s start with the fire truck.

5 That’s the fire station as it were; is that correct?

6 A. The fire brush truck is located in the

7 administration building.

8 Q. All right. So — and at this time there’s

9 one fire truck; is that right?

10 A. Yes, it’s a brush truck.

11 Q. And on prior occasions, how many fire trucks

12 have been there?

13 A. We’ve had as many as two.

14 Q. All right. Now, when you talk about the

15 brush truck, is it a fully outfitted fire truck?

16 A. Yes.

17 Q. All right. And do you have trained fire

18 personnel to man the — or staff, I should say, the

19 fire truck?

20 A. Yes. We have trained firefighter/EMTs.

21 Q. You said EMTs?

22 A. EMTs, yes.

23 Q. I’m having a little trouble hearing at the

24 end of your sentences.

25 A. Okay.

26 Q. All right. Now, the administrative office

27 is — you talked about a number of offices being in

28 there. You have an actual executive office there 9471

1 right now; is that correct?

2 A. Yes. I share it with the fire supervisor at

3 this time.

4 Q. All right. And then there’s a staff area

5 where an administrative assistant sits; is that

6 right?

7 A. Yes, and the ranch manager.

8 Q. All right. And then there’s a separate

9 office for the ranch manager, or the ranch manager

10 is out —

11 A. No, they have separate offices.

12 Q. Okay. At the current time, who is the

13 administrative assistant up there?

14 A. Tracy Chapman.

15 Q. And does she have a large phone?

16 A. Yes.

17 Q. Okay. Now, in the years — did I ask you

18 when you started there —

19 A. No.

20 Q. — I think I did.

21 Okay. When did you start working there?

22 A. July 1st, 1991.

23 Q. We’ll go back over what you’ve done there in

24 a minute.

25 A. Okay.

26 Q. But in the years you’ve been there, have you

27 had occasion to see the different phones throughout

28 the ranch? 9472

1 A. Yes.

2 Q. All right. And are there some regular,

3 smaller handset phones throughout the ranch?

4 A. Yes.

5 Q. Is the main phone in the administrative

6 office larger than those phones?

7 A. Yes. There’s a regular small phone and

8 there’s also a larger console type of phone.

9 Q. Would that be the main phone for the phone

10 system?

11 A. No, it’s not.

12 Q. All right. Where is the main phone?

13 A. The calls are mostly taken through the

14 security gate, and also at Miss Chapman’s desk,

15 depending on which number the person is calling.

16 Q. When I said “main phone,” I was asking about

17 the equipment. But you’re saying that calls are

18 answered at some of the smaller handsets; is that

19 correct?

20 A. Yes.

21 Q. And one of the places where calls are

22 routinely answered is the front gate?

23 A. Yes.

24 Q. And the other would be at Miss Chapman’s

25 desk?

26 A. Yes.

27 Q. All right. The ranch manager — who’s the

28 ranch manager at the present time? 9473

1 A. Joe Marcus.

2 Q. And does he have an office there in the same

3 administrative building?

4 A. Yes.

5 Q. When did you obtain the position that you

6 have now?

7 A. November of 2004.

8 Q. Let’s go back to when you started at the

9 ranch. And actually, before you started at the

10 ranch, did you have any particular training and

11 experience?

12 A. I had graduated from Allan Hancock Police

13 Academy in 1989, December. And shortly after, well,

14 ‘91, I applied for a position out at the ranch as a

15 security officer, which I started July 1st of ‘91.

16 Q. All right. So you went to the POST academy?

17 A. Yes.

18 Q. Police officer training academy, correct?

19 A. Yes.

20 Q. Did you receive the certificate?

21 A. I graduated but I did not receive the

22 certificate, because I did not work full time as a

23 police officer. So I guess my answer would be no to

24 that, I did not receive the POST certificate.

25 Q. So you did the education and the training

26 through Allan Hancock, but you didn’t do the

27 inservice training as a police officer; is that

28 correct? 9474

1 A. Correct.

2 Q. All right. And do you consider yourself to

3 be a peace officer or a police officer?

4 A. No.

5 Q. All right. And have you ever?

6 A. No.

7 Q. All right. So you went to work as a

8 security guard at the ranch —

9 A. Yes.

10 Q. — in 1991, correct?

11 A. Yes.

12 Q. Did the ranch have a security staff — well,

13 let’s start with that. You weren’t the only person?

14 A. No.

15 Q. Okay. And was the staff organized according

16 to rank?

17 A. Yes.

18 Q. Who was the chief of security at that time;

19 do you recall?

20 A. Terry Cooney.

21 Q. And between 1991 and 2004, did you

22 continuously work in the security department?

23 A. Yes.

24 Q. Can you tell us briefly what — how you

25 progressed through the department?

26 A. In October of ‘91, I was promoted to a

27 relief supervisor position, which would carry the

28 rank of corporal. And in January of ‘94, I believe, 9475

1 I was promoted to a full-time shift supervisor,

2 which has the rank of sergeant. In May of ‘97, I

3 was promoted to the chief’s position of security.

4 And in June of ‘98, I assumed the fire chief

5 position as well.

6 Q. All right. And you — when you were finally

7 moved into this other administrative position, as of

8 that time in 2004, you were the chief of both the

9 security and the fire department; is that correct?

10 A. Yes.

Next, Silva discussed the protocol for any employee interactions with Jackson (essentially, they couldn’t initiate any contact with him, unless it was an emergency), and vehemently denied seeing any wrongdoing by Jackson.

Personally, I was disappointed with her response to Sanger’s question regarding what actions she would have taken had she seen Jackson abusing children; it sounds awfully close to the actions that the adults took at a certain college when they were confronted with rumors of child abuse at their school……

11 Q. All right. Now, you know Mr. Jackson —

12 A. Yes.

13 Q. — correct?

14 Do you know Mr. Jackson well?

15 A. I would say so.

16 Q. All right. Do you spend — in the course of

17 your employment, do you spend a lot of time talking

18 with Mr. Jackson?

19 A. No.

20 Q. All right. And can you explain what the


21 policy is for employees at the ranch as far as


22 having contact with Mr. Jackson?


23 MR. SNEDDON: Object as immaterial, Your


24 Honor.


25 THE COURT: Overruled.


26 You may answer. You may answer.


27 THE WITNESS: I’m sorry, can you repeat the


28 question? 9476


1 THE COURT: I can have it read back.


2 MR. SANGER: Thank you.


3 (Record read.)


4 THE WITNESS: Our contact is limited to him


5 making requests. And other than that, if we have


6 any concerns about the operation of the ranch, we


7 channel those through the ranch manager.


8 Q. BY MR. SANGER: Now, that policy would


9 pertain to security, correct?


10 A. Yes.


11 Q. It would pertain to fire; is that right?


12 A. Yes.

13 Q. Did it pertain to the other departments as

14 well?

15 A. Yes.

16 Q. Okay. So housekeeping?

17 A. Yes.

18 Q. The zoo?

19 A. Yes.

20 Q. Grounds or maintenance?

21 A. Yes.

22 Q. Did I leave any out?

23 A. There’s a few.

24 Q. Okay. There’s some more. But all of the

25 different units out there have their own chain of

26 command, as it were; is that correct?

27 A. Correct. There’s employees, a department

28 head for each department, and each department is 9477

1 directly supervised by the ranch manager.

2 Q. And who is the ranch manager at the current

3 time? Did I ask you that?

4 A. Yes. Joe Marcus.

5 Q. So if somebody in your department — as the

6 chief of security, if somebody in your department

7 had some question about procedure or how things

8 ought to be done, where would you expect them to go?

9 A. I expect them to immediately go to their

10 shift supervisor, to whoever the chief is at the

11 time. If I was in charge, then to me. If I

12 couldn’t answer the question, then I would go to Mr.

13 Marcus with a question.

14 Q. All right. Did you ever sit down with Mr.

15 Jackson and ask him how he’d like to have security

16 taken care of at the ranch?

17 A. No. But if he had a suggestion, he sure

18 would let me know.

19 Q. Okay. When you had — when you made policy

20 decisions about security, would you discuss those

21 with Joe Marcus or with somebody else, or how would

22 you do that?

23 A. I would discuss those with Mr. Marcus.

24 Q. All right.

25 A. And my shift supervisors as well.

26 Q. Now, you said that Mr. Jackson would let you

27 know. Did Mr. Jackson from time to time let people

28 know that he thought something ought to be done at 9478

1 the ranch?

2 A. Yes.

3 Q. Okay. And would the staff attempt to

4 fulfill those requests?

5 A. Yes.

6 Q. All right. In all the time that you were

7 there, did Mr. Jackson ever ask you to do anything

8 that you thought was inappropriate?

9 A. No.

10 Q. All right. Now, by the way, you’ve come

11 here pursuant to a subpoena; is that correct?

12 A. Yes.

13 Q. And you also interviewed with law

14 enforcement; is that correct?

15 A. Yes.

16 Q. And you have told both sides that you were

17 going to tell the truth to both sides no matter

18 what; is that correct?

19 A. Yes.

20 Q. Is that your intention, to tell the truth

21 here on the stand?

22 A. Absolutely.

23 Q. Now, in the course of the time that you


24 worked there — I asked you if Mr. Jackson ever


25 asked you to do anything that was inappropriate.


26 During the course of the time that you


27 worked at the ranch, did you ever observe anything


28 that appeared to you to be illegal or inappropriate? 9479


1 A. No.

2 Q. And if you had, what would you have done


3 about it?


4 A. Well, I would have at the time taken into


5 consideration what the action was and addressed it


6 appropriately.

7 Q. Now, before you were a chief of security, if


8 you saw anything inappropriate or illegal, would you


9 have reported it to a supervisor? Before you were


10 chief of —


11 A. Oh, absolutely, yes.


12 Q. And again, you told us about the chain of


13 command so —


14 A. Yes.


15 Q. And as the chief of security, if you saw


16 anything inappropriate or illegal, what would you


17 have done? Who would you have reported it to?


18 A. I would have followed my chain of command,


19 and notified my supervisor, who was Joe Marcus.

Next, Sanger made a subtle reference to Gavin and Star Arvizo by asking Silva what the proper protocols are for a golf cart accident (read this excerpt from Brian Barron’s testimony for information about how Star and Gavin drove Jackson’s golf carts without permission and crashed them), and how to deal with unsupervised kids at the ranch. The duties of the security officers were also discussed:

20 Q. All right. Now, during the course of the

21 time that you worked in security and you’ve been the

22 chief of security — in fact, I’m really drawing on


23 that experience as your involvement in security


24 there, whatever rank you had during the period of


25 time. What would happen if you — if anybody in


26 security observed something, let’s say a golf cart


27 accident – we’ve heard about those – what would


28 happen? 9480


1 A. Well, we would first immediately make


2 sure — whoever the driver was, make sure they


3 weren’t injured. That would be our first concern.


4 If they were — then we would attend to that.


5 Afterwards, if there was no injury or we


6 took care of the injury, then we would either make


7 sure that the vehicle, the cart, whatever it was,


8 was still roadworthy. If it was not, we would


9 remove it and take it to the mechanic’s shop and we


10 would make a report as well. And depending on why


11 it happened, if it was deemed necessary, we would


12 take that privilege away from that person if they


13 weren’t handling the cart properly.

14 Q. All right. Let’s start with the report. Is

15 there a formal reporting system that has been in

16 place at the ranch since you started there as a

17 security officer?

18 A. Yes.

19 Q. And can you explain what that is?

20 A. Well, depending on the incident or the

21 severity of it, if it’s a medical incident, then a

22 report is made, regardless of how minor or

23 insignificant it may seem. If it’s a damage report,

24 we will do the same. If we consider that there may

25 be a hazard involved, then we address the hazard as

26 well. So — and just write down a line, if there’s

27 a theft, if there’s something missing, if we have a

28 trespasser. It could be anything. 9481

1 Q. All right. Now, with regard to the

2 different kinds of reports you talked about, there

3 are medical reports. There’s actually a form to

4 make a medical report; is that correct?

5 A. Yes.

6 Q. And is that filled out every time the EMTs

7 are called to attend to somebody who might be

8 injured?

9 A. Yes.

10 Q. All right. Now, you said there’s EMTs.

11 Firefighters/EMTs. Do you generally have an EMT on

12 the property at all times?

13 A. We try to make sure that that’s covered.

14 It’s a priority for us. So we do.

15 Q. If anybody is injured anywhere on the ranch,

16 whether it’s an employee, a guest, Mr. Jackson, you

17 have somebody there who can give first aid?

18 A. Yes.

19 Q. Do the — if somebody is injured, do the

20 EMTs make the final call as to whether or not any

21 further medical assistance is needed?

22 A. They’ll make the assessment, but a patient

23 always has the right to refuse treatment. So if

24 that’s what they do, then we can just ask them to,

25 you know, seek further treatment. If not, then

26 that’s where it stops. If we feel they absolutely

27 need to go, in the event of a work injury, then

28 they’re required to go. 9482

1 Q. All right. Now, when you say “go,” we’re

2 talking about going to the local hospital or getting

3 a doctor or —

4 A. Correct. Or call whatever means is

5 necessary, whether it’s ambulance or outside of our

6 department with county fire.

7 Q. And have you had occasion at times to

8 actually call in ambulances to the ranch?

9 A. Yes.

10 Q. Even, I think, a medical helicopter

11 evacuation?

12 A. Yes.

13 MR. SNEDDON: I’m going to object as

14 immaterial and irrelevant, Your Honor.

15 THE COURT: Do you have a —

16 MR. SANGER: That was actually the last

17 question in that area. But it does tie into some

18 other evidence.

19 THE COURT: All right. I’ll overrule the

20 objection.

21 MR. SANGER: All right.

22 Q. Now, you indicated that in addition to the

23 medical reports, that the — you also have reports

24 with regard to property damage, correct?

25 A. Yes.

26 Q. And then you indicated that there are

27 occasions where a guest — let me withdraw that.

28 What happens if a guest is not being safe 9483

1 with some of the equipment?

2 A. Well, then we temporarily give them a

3 cooling-off time, or we would remove the equipment

4 from them.

5 Q. And why would you do that?

6 A. For their safety.

7 Q. Now, is one of the concerns in your

8 department safety of the guests?

9 A. Yes.

10 Q. Does that pertain to adults or children or

11 both?

12 A. Both.

13 Q. And how is that concern for safety

14 implemented in your department?

15 A. Well, when they’re initially given a cart to

16 drive, or a vehicle, or a quad runner, we give them

17 instructions on how to operate the equipment safely.

18 You know, on occasion it does happen where they get

19 a little rambunctious and we feel like maybe they

20 can’t control it properly, then we give them a

21 warning, and advise them again of the proper use of

22 the equipment. And if they continue to either cause

23 damage to the cart or other things, then we usually

24 pull the equipment.

25 Q. Now, do you have to ask Mr. Jackson first

26 before you do that?

27 A. No.

28 Q. And if you see kids who are not being 9484

1 supervised by their parents on the ranch, does

2 security try to keep — let’s put it this way: Is

3 there any additional attention given to those kids

4 by security?

5 A. Well, I would say that’s just our priority

6 in general. So — it’s what we’re doing there. So

7 it’s not — we don’t have heightened awareness.

8 It’s just what we are trained to do and what we’re

9 there for. So that’s a constant regardless of

10 whether their parents are there or not.

11 Q. So if you see kids — whether the parents

12 are there or not, if you see kids riding the carts

13 and you think — in the morning you saw somebody

14 going a little fast, is security going to tend to

15 watch that kid a little more closely?

16 A. Sure.

17 Q. All right. Do you sometimes make entries in

18 the gate logs?

19 A. Yes.

20 Q. Now, we’ve seen something about gate logs,

21 so we don’t have to absolutely go back to square

22 one, but can you describe the purpose of the gate

23 logs and how they’re kept?

24 A. The purpose of the gate logs is we have

25 three different sheets, and it’s evolved over time,

26 depending on what our needs are for our department.

27 It’s mainly used to document in-and-out times for

28 our employees, contractors, guests’ arrival. 9485

1 It also documents our own activity on the

2 ranch as far as our work that we do, so if we have

3 to refer back to a time or a directive that is given

4 to us, we can refer back to it.

5 Q. How many security officers are on duty

6 generally? Let’s say in recent years, in the 2000s,

7 how many security officers would be on duty at any

8 given time during the day?

9 A. We try for four. Four is what we — is a

10 good number for us.

11 Q. All right. Would that be 24 hours a day?

12 A. Yes.

13 Q. And can you describe what the duties of the

14 four different officers would be?

15 A. Well, they would come in and get whatever

16 equipment they need. They would either report to

17 three different posts that we have, which is at the

18 front gate, the main house, or a mobile patrol.

19 Their duties vary at each of the stations.

20 The main gate is — primarily their function

21 is to ask guests — authorize guests or contractors.

22 They also dispatch a request from the owner or

23 another department that needs something. We answer

24 the phones. A lot of phone calls come through there

25 after hours as well, so —

26 Q. So you have — you generally have one

27 officer mobile – all right? – one in the gatehouse,

28 and where would the other two be? 9486

1 A. One would be at the house and hopefully the

2 other one would be a supervisor. So most of the

3 times it would be a supervisor.

4 Q. You talked about the front gate. There’s a

5 gatehouse there; is that correct?

6 A. Yes.

7 Q. And can you describe that building, about

8 how big it is?

9 A. The building is probably about 15 square

10 feet. It has a small eating area, a desk area, a

11 bathroom, has a phone. T.V.

12 Q. Okay. I am thinking 15 square feet, that’s

13 kind of small.

14 A. It works.

15 Q. Okay.

16 A. It’s all we need.

17 Q. All right. So there’s a desk in there; is

18 that correct?

19 A. Yes.

20 Q. And there’s a bathroom; is that right?

21 A. Yes.

22 Q. And there’s an area where you can sit and

23 watch a T.V., correct?

24 A. Yes.

25 Q. Now, during the course of the shift or

26 during the course of a day — let’s put it this way:

27 During the day, how many shifts are there for

28 security? 9487

1 A. We work a 12-hour shift, so we have two

2 shifts, starting from 6 a.m. to 6:30 p.m., from

3 6 p.m. to 6:30 a.m.

4 Q. All right. And I take it you have the

5 required breaks, lunch breaks and other breaks, in

6 the middle of that shift?

7 A. Yes.

8 Q. Now, in addition to security, do you have

9 fire on duty?

10 A. Yes.

11 Q. And how many fire people do you have?

12 A. How the department is worked is that our

13 firefighters do security work. So most of them, or

14 the majority of our security officers, are

15 firefighter/EMTs.

16 Q. So they also have the EMT training?

17 A. Yes.

18 Q. Did that change? Did you have a separate

19 fire staff at one time?

20 A. Yes. From the time I was first hired in

21 ‘91, the security department was separate from the

22 fire department. And in ‘98, June ‘98, when I

23 assumed the fire chief duties, our department was

24 combined at that time.

Silva was asked about Brian Barron, a peace officer who was asked by Sneddon to become an informant for the prosecution, but refused. (Here’s a summary of his testimony.) Sanger moved on to other topics without going into any details about Barron, including the confidentiality agreement that all Neverland guests are required to sign, the design of the security system, and protocols for guests who arrive at the ranch:

25 Q. By the way, Brian Barron, do you know that

26 name?

27 A. Yes.

28 Q. Do you know Brian Barron? 9488

1 A. Yes, I do.

2 Q. And is he a police officer?

3 A. Yes.

4 Q. Do you recall him working at the ranch?

5 A. Yes.

6 Q. At the time he worked at the ranch, was it

7 known to everybody in the security department that

8 he was, in fact, a sworn peace officer?

9 A. Yes.

10 MR. SNEDDON: Object; calls for speculation.

11 THE COURT: Overruled.

12 Q. BY MR. SANGER: Now, going back to the front

13 gate issue, where are the gate logs actually kept

14 during the day?

15 A. During the day, the gate logs are kept

16 there, and they’re actually kept there for the

17 entire week. And on Monday morning, they’re picked

18 up.

19 Q. And where do they go after that?

20 A. They go to the administration office.

21 Q. And the administration office, again, is the

22 building up on the hill?

23 A. Yes.

24 Q. All right. Now, there’s been discussion

25 about a security office at the end of the building

26 that has the garage, Mr. Jackson’s office, and then

27 it has the video library upstairs.

28 A. Yes. 9489

1 Q. Can you describe that security office?

2 A. The — it has two separate rooms. The first

3 office is approximately a nine-by-ten room. It has

4 a desk, a computer, a counter space that holds our

5 equipment and other things, like paper towels and

6 napkins.

7 The back area is with lockers and a table

8 for eating and refrigerator and microwave.

9 Q. All right. Now, is this a staff area?

10 A. Yes.

11 Q. All right. And this is part of that

12 structure. Does it have a door that you enter from

13 the outside or do you go inside that structure to

14 enter?

15 A. No, you enter from the outside.

16 Q. All right. And the door that you enter is

17 away from the house; is that correct?

18 A. Yes.

19 Q. What is kept generally — in the 2003 time

20 period, what is kept at that location?

21 A. At that location — excuse me, I forgot to

22 mention, we do have a file cabinet there. We have a

23 file cabinet that holds reports, our confidentiality

24 agreements. We also have our gate logs in there for

25 the entire year. They’re housed in there. And

26 whatever little bits of equipment that we may have

27 in that storage.

28 Q. All right. Now, you mentioned a 9490


1 confidentiality agreement. Can you explain what


2 that is?


3 A. The confidentiality agreement is a four-page


4 contract that all guests or anyone entering


5 Neverland reach — that read, that read it, and they


6 have to be over the age of 18. The contract, in a


7 nutshell, is that you agree to keep your visit


8 private and confidential.


9 Q. All right. Is it designed to conceal


10 illegal activity?


11 A. No.


12 Q. What’s the purpose of the confidentiality


13 agreement?


14 A. The purpose of the agreement is to keep you


15 from profiting from your experience there, selling


16 to a magazine or any sort of media.


17 Q. Okay. Does it also include a provision that


18 people are not supposed to take pictures while


19 they’re there on the ranch?


20 A. Yes, they agree to not use any sort of


21 recording agreement.

22 Q. And the purpose of that, not allowing any


23 kind of recording equipment or pictures, is what?


24 A. Is to prevent probably the profit of sale as


25 well.


26 Q. So if you didn’t have that as the chief of


27 security, you would expect that pictures and


28 recordings from the ranch would end up in the media, 9491


1 on television and in magazines otherwise; is that


2 true?


3 A. Yes.


4 Q. Is any of that designed to conceal any kind


5 of untoward or illegal activity?


6 A. No.

7 Q. All right. Now, going back to how the

8 security system is set up — I’m sorry, the security

9 operation is set up, you mentioned the front gate,

10 and we talked about that. The person — well, let’s

11 talk a little more. The person down at the front

12 gate, I think you said, answers the phones?

13 A. Yes.

14 Q. And that’s on a regular little handset

15 phone; is that correct?

16 A. Yes.

17 Q. You just forward the calls from there?

18 A. Yes.

19 Q. The person at the front gate also has the

20 responsibility of letting people in and out?

21 A. Authorized persons only.

22 Q. All right. Now, you mentioned “mobile.”

23 What does “mobile” mean?

24 A. Mobile patrol is a truck that patrols the

25 property. We also patrol about three miles of the

26 front perimeter as well. They patrol the property

27 and make sure we don’t have trespassers, that our

28 employees are safe, there are no other hazardous 9492

1 conditions going on.

2 We also respond to alarm calls on the

3 property. They also have the duties of locking up

4 certain buildings and securing the ranch at a

5 certain hour.

6 Q. Let’s talk about patrolling the front of the

7 property. Does that mean going out on Figueroa

8 Mountain Road?

9 A. Yes.

10 Q. And why do you do that?

11 A. Well, occasionally we find vehicles that are

12 parked outside of our fence line. And that would be

13 an indication that perhaps we have a person who’s

14 jumped the fence and might be on property.

15 Q. Now, part of the fence is just a split-rail

16 fence, is that correct, in the front?

17 A. Yes, approximately a half a mile of it is

18 just your typical split-rail fencing.

19 Q. So it’s not a wire meshed fence?

20 A. No.

21 Q. And is it fairly easy for people to go

22 through that fence?

23 A. Through or over.

24 Q. Now, there are parts of this ranch — how

25 big is the ranch?

26 A. The ranch is 2700 acres, or approximately

27 five square miles.

28 Q. All right. And is there any kind of a 9493

1 commercial operation on the ranch?

2 A. Yes.

3 Q. What is that?

4 A. We have cattle on the ranch.

5 Q. All right. Is that something you — you

6 have your own cattle, Michael Jackson’s cattle?

7 A. No, part of the property is —

8 MR. SNEDDON: I’m going to object as

9 immaterial and irrelevant.

10 MR. SANGER: That has to do with the

11 fencing.

12 THE COURT: Overruled.

13 You may answer.

14 THE WITNESS: Yes, it’s leased by a rancher

15 who has cattle on the property.

16 Q. BY MR. SANGER: All right. And are there

17 parts of the property that are fenced to keep the

18 cattle in?

19 A. Correct.

20 Q. And there are parts of the property that are

21 fenced to keep the cattle out, I take it?

22 A. Correct.

23 Q. When you go into Mr. Jackson’s home area,

24 let us say — do you have a term for that, the —

25 A. I would say beyond the arched gateway, we

26 call it the main house area.

27 Q. And the arched gateway, is that the golden

28 gates? 9494

1 A. The golden gates.

2 Q. The black gates with gold on them? All

3 right.

4 Now, is there fencing designed to keep

5 people on the ranch so that they cannot get off?

6 A. No.

7 Q. The golden gate that you described, does

8 that automatically open if you approach it?

9 A. You would have to approach it by a vehicle,

10 with a vehicle.

11 Q. Okay. If you have a vehicle, it

12 automatically opens?

13 A. Yes.

14 Q. There’s no requirement that you ask anybody

15 or push buttons or anything else, right?

16 A. No. There’s also a way to go around the

17 gate as well, on foot.

18 Q. Okay. We’re going to get to that. But as

19 far as the cars —

20 A. Okay.

21 Q. That’s all right.

22 As far as cars are concerned, whether you

23 are coming in or you are going out, if you just pull

24 up, it trips a sensor and the gates automatically

25 open, correct?

26 A. Right. Depending on the size of the

27 vehicle, it senses the weight or the metal. And a

28 golf cart could open it, could activate it, as well 9495

1 as a quad runner.

2 Q. And in fact, golf carts and quad runners do

3 go through that gate; is that correct?

4 A. Yes.

5 Q. Now, you said you can also walk around the

6 gate; is that right?

7 A. Yes.

8 Q. Is there any kind of a locked fence that

9 you have to get permission to go through to go past

10 that gate?

11 A. No.

12 Q. All right. All right. So you said the

13 mobile — it’s — right now it’s a little pickup

14 truck; is that correct?

15 A. Yes, a Ford.

16 Q. I’m sorry?

17 A. A Ford Ranger.

18 Q. And over the years it’s been a different

19 type of vehicle, I would take it?

20 A. Mostly that, though.

21 Q. Mostly a small Ford pickup?

22 A. We did have a Nissan as well.

23 Q. Some kind of pickup truck, right?

24 A. Yes.

25 Q. Besides patrolling from time to time

26 Figueroa Mountain Road to see if there are vehicles

27 or possible intruders, does the mobile also patrol

28 within the ranch? 9496

1 A. Yes.

2 Q. And just tell us generally where the mobile

3 unit would go.

4 A. Well, the ranch has two main roads that loop

5 throughout the property, and they meet about a

6 quarter mile from the front gate. From there —

7 from that point to the main residence is another

8 quarter mile. So we would patrol that entire area.

9 So we would do a loop approximately of about five

10 miles starting from the house security office to the

11 furthest part of the ranch, back out to the front

12 road and back.

13 Q. All right. Now, you say “the furthest part

14 of the ranch.” Do you go up past the theater into

15 the zoo area?

16 A. Yes, the furthest point would be the train

17 barn or another — another area where we have a

18 stockpile of manure, compost, gravel and sand.

19 Q. All right. Now, if you have two other

20 people on duty, you said one might be a supervisor

21 and then you’d have another security officer; is

22 that correct?

23 A. Yes.

24 Q. What would they do? We’ve got the front

25 gate person who stays at the front gate. You’ve got

26 mobile. What would the other two people be doing on

27 a typical shift?

28 A. We always have someone located at the main 9497

1 house.

2 Q. “Located at the main house” would be sitting

3 in the security house at the end or walking around

4 or both?

5 A. Both.

6 Q. And what does the person do who’s there at

7 the main house? Can you describe what their duties

8 would generally be? And they differ at night and

9 daytime, you can make that distinction.

10 A. Generally what they do is they secure —

11 they have the responsibility of securing that area,

12 which means doing a foot patrol around the house,

13 which includes the main residence, the rec room, the

14 guest units, and as far away as maybe another

15 quarter mile walking, if it’s necessary. They also

16 accommodate guests’ requests. If, you know,

17 something’s needed, they assist the house staff as

18 well.

19 Q. So if somebody calls and says, you know,

20 “I’d like to go into the theater and the theater is

21 locked,” is that something that security might take

22 care of?

23 A. Yes.

24 Q. And if a guest calls and requests some sort

25 of refreshments, what would — just tell me what

26 happens. Somebody says, you know, “We want lunch.

27 It’s lunchtime. Can we please have lunch?” What

28 would you do? 9498

1 A. We would call the kitchen and let them know

2 the guests are ready for lunch.

3 Q. Now, you said “call.” Do you have radios?

4 A. Yes.

5 Q. And what kind of radios do you have? Not

6 the brand, but, you know, is it a — does it hit a

7 repeater or what?

8 A. Yes, it hits a repeater. We also have radio

9 to radio within a mile distance.

10 Q. All right.

11 A. We have two channels.

12 Q. So one channel goes off a repeater somewhere

13 on a hill, and you’re able to make communication

14 that way?

15 A. Yes.

16 Q. And then you can do the car to car?

17 A. Yes.

18 Q. All right. Now, are the radios used just by

19 security or by other departments?

20 A. No, most of the staff carries radios.

21 Q. And they all have the two channels, the same

22 two channels?

23 A. No, we have two separate channels. We have

24 a channel strictly for security and fire and the

25 remainder of the staff operates off another channel.

26 Q. So you have two main channels off the

27 repeater and then one car to car, or station to

28 station? 9499

1 A. Sure.

2 Q. Okay. Is security often called for the

3 purpose of arranging — we talked about lunch.

4 Could security get a call about lunch, for instance?

5 A. Yes.

6 Q. And then you would then forward that to

7 housekeeping or to the cook?

8 A. Yes. They would either come into our office

9 and request it, if they wanted it somewhere

10 different than the kitchen, a lot of our guests know

11 that they can call the front gate and make a request

12 from there, and then the front gate would dispatch

13 whoever is appropriate to make — fulfill that

14 request.

15 Q. So the guests would call the phone number?

16 A. Yes.

17 Q. All right.

18 THE COURT: All right, Counsel.

19 (Recess taken.)

20 –o0o—

To be continued:

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