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May 9th, 2005 Trial Analysis: Francin Contreras, Gayle Goforth, Violet Silva, Ramon Velasco, Joseph Marcus, Part 3 of 4

February 8, 2015

Next, Sneddon repeatedly questioned Silva about Frank Cascio, his professional and personal associations with Jackson, the time period that he started using the alias “Tyson” (insinuating that Frank had a nefarious motive for using the alias), etc.:

13 Q. Now, you mentioned one of the families that

14 you saw a good deal of is the Cascio family,

15 correct?

16 A. Yes.

17 Q. And one of the people who you observed over

18 the years was Frank Cascio, correct?

19 A. Yes.

20 Q. And you know him as Cascio, right?

21 A. Yes.

22 Q. And when you first met Mr. Cascio, he was

23 just a young boy, wasn’t he?

24 A. Yes.

25 Q. In other words, he was about 11 or 12 years

26 old?

27 A. I’m not sure of his age.

28 Q. Would he — would he be about the same age 9563

1 as the other boys who were visiting around that

2 time, Brett Barnes, Wade, Jordan?

3 A. Most likely, yes.

4 Q. And he also would spend time with Mr.

5 Jackson in Mr. Jackson’s house, correct?

6 A. Yes.

7 Q. And the difference is that in this case

8 Frank Cascio used to visit with Mr. Jackson a lot,

9 correct, kept an ongoing relationship with Mr.

10 Jackson?

11 A. The family kept an ongoing relationship.

12 Q. Okay. That’s fair enough. So it was the

13 whole family, as well as Frank Cascio, that kept a

14 relationship with the defendant?

15 A. Yes.

16 Q. And you would describe, would you not, that

17 this family is very close to Mr. Jackson?

18 A. Yes.

19 Q. Based on your observations?

20 A. Yes.

21 Q. And you would — I believe you said that in

22 the year 2000, you knew that Mr. — Frank Cascio

23 went to work for Mr. Jackson, correct?

24 A. I have not said that here.

25 Q. No. I’m asking. You said that to an

26 investigator, correct?

27 A. Yes, possibly.

28 MR. SANGER: Objection; calls for hearsay. 9564

1 THE COURT: Sustained.

2 Q. BY MR. SNEDDON: Did you not tell somebody

3 that you believed he went to work for Mr. Jackson in

4 the year 2000?

5 A. Yes.

6 MR. SANGER: Objection. Excuse me. Calls

7 for hearsay.

8 THE COURT: Sustained.

9 MR. SANGER: Move to strike.

10 THE COURT: Stricken.

11 Q. BY MR. SNEDDON: Where did you get the

12 knowledge that Mr. Cascio went to work for Mr.

13 Jackson in the year 2000?

14 MR. SANGER: Objection. Calls for — facts

15 not in evidence. The Court sustained its —

16 THE COURT: Sustained.

17 MR. SANGER: Thank you.

18 Q. BY MR. SNEDDON: Were you at any time aware

19 of the fact that Mr. Cascio worked for Mr. Jackson?

20 A. I was aware that he was working on projects

21 on the property for Mr. Jackson.

22 Q. During the time frame from 2000 to 2003,

23 would that be the time period that you had reference

24 to?

25 A. Yes.

26 Q. And would you describe the relationship

27 between Mr. Jackson and Frank Cascio during this

28 period of time from 2000 to 2003, that it continued 9565

1 to be a very close relationship, correct?

2 A. Yes.

3 Q. A trusted friend, correct?

4 A. I believe so.

5 Q. Now, with regard to Mr. Frank Cascio, were

6 you aware of the fact that he changed his name or

7 was using another name?

8 A. Yes.

9 Q. And that was during the time period of

10 February and March of 2003, correct?

11 A. I believe so.

12 Q. And he used the name Frank Tyson, correct?

13 A. Yes.

14 Q. Was that the first time you ever heard him

15 use the last name of Tyson during that period,

16 February and March?

17 A. I don’t know if it was during that time

18 period, but I could safely say probably yes.

19 Q. It was during the time when the Arvizo

20 family was at the ranch, correct?

21 A. I believe it was during that time period.

22 Q. And in fact, during 2002, Mr. Tyson had

23 visited the ranch on a number of occasions, correct?

24 A. In 2002?

25 Q. Yes, ma’am.

26 A. How many times I don’t know, but he — most

27 likely he did.

28 Q. When he visited, he would have been noted in 9566

1 the logs, the ranch logs that you referenced?

2 A. Yes.

3 Q. And on each occasion he’s referenced as

4 “Cascio,” is he not?

5 A. Yes.

6 Q. Did you ever see Mr. Jackson having meetings

7 with Frank Cascio during February and March of 2003?

8 A. I’m sure they met. I don’t know what — if

9 it was an actual meeting or what it consisted of,

10 but they spoke with each other.

11 Q. They had a lot of conversations between the

12 two of them, did they not, regularly? Or conversed

13 regularly, how about that?

14 A. Well, they’re friends, so I imagine they

15 would have a lot to talk about.

Sneddon tried to absolve Gavin of all responsibility for crashing the golf carts at Neverland by having Silva confirm that Shane Brando (Miko Brando’s then 13 year old son) was a fault:

16 Q. And Dieter Weizner, did you see him having

17 conversations with the defendant during February of

18 2003?

19 A. No.

20 Q. Never?

21 A. Never.

22 Q. You never saw them in Mr. Jackson’s office

23 meeting?

24 A. I did not see that.

25 Q. But if they were meeting in the house, you

26 wouldn’t have known that either, would you?

27 A. No.

28 Q. With regard to Mr. Konitzer, did you ever 9567

1 see Mr. Jackson meeting with Mr. Konitzer?

2 A. No.

3 Q. Now, you mentioned Miko Brando. And he has

4 a son named Shane, correct?

5 A. Yes.

6 Q. And it’s correct, is it not, that actually

7 during February of 2003, Shane Brando got in an

8 accident with one of the carts and actually injured

9 Gavin, did he not?

10 A. Yes. They both crashed into each other.

11 Q. But the log reflects the fact that it was

12 Shane Brando who was at fault; isn’t that correct?

13 A. Yes.

14 Q. Now, how old is Shane Brando in 2003? About

15 the same age as Gavin?

16 A. I’m not sure how old Shane is. He’s a big

17 kid, so I don’t know exact — his exact age.

18 Actually, he’s — he’s probably about 16 now, so….

19 Q. So he would have been about 14 or 13 then?

20 A. Sure.

Sneddon went off on a tangent and questioned Silva about the security protocols at Neverland;

21 Q. You’ve talked a lot about the procedures for

22 the security on the ranch. And I wanted to ask you,

23 first of all, you’ve said that there is a procedure

24 now where people work 12 — 12/12, two shifts,

25 right?

26 A. Yes.

27 Q. That wasn’t always the case, was it?

28 A. No. 9568

1 Q. Back in 1991, ‘92, ‘93, there was a

2 graveyard shift, correct?

3 A. Yes.

4 Q. And that shift started at ten o’clock at

5 night and worked through the morning hours, correct?

6 A. During different times, we would — when I

7 initially started working, the shift started at

8 midnight till 8:00 in the morning. I don’t know

9 what year we changed that where the shift would

10 start at 10 p.m. and work till 6 a.m.

11 Q. But there was a shift that worked from

12 10:00?

13 A. Yes.

14 Q. Called the graveyard shift, correct?

15 A. Yes.

16 Q. Now, just a couple of questions about the

17 logs that you’ve described. I think you said

18 earlier in your direct examination with Mr. Sanger

19 that the logs, the gate logs, went to the

20 administrative office up on the hill, correct?

21 A. Yes.

22 Q. And how did they find their way down to the

23 security office?

24 A. The gate logs are used to verify the

25 payroll. Payroll is done on Monday mornings. So if

26 someone forgets to punch in or punch out, then they

27 refer back to the gate logs to see what time that

28 employee left, if it was needed. 9569

1 Once they’re — once they’re through with

2 them, then they’re filed back into the office and

3 they’re kept in that file for a year, until the end

4 of the year, when they’re filed in another box and

5 stored.

6 Q. By “the office,” do you mean taken

7 physically from the administrative office down to

8 the security office?

9 A. Yes.

10 Q. Would you tell me how many drawers are there

11 in the cabinet that you say you retrieved these logs

12 from?

13 A. There’s four.

14 Q. And which of the drawers was it that you

15 retrieved them from?

16 A. They were in the second drawer.

17 Q. Second from the top or the bottom?

18 A. Second to the top. Second to the top.

19 Q. Now, the keys to the house, you say they’re

20 kept in the break room, correct?

21 MR. SANGER: Objection. That misstates the

22 evidence, “The keys to the house.”

23 THE COURT: Overruled.

24 You may answer.

25 THE WITNESS: The keys to the house?

26 Q. BY MR. SNEDDON: Well, keys to the arcade.

27 I’m sorry if I said the wrong building. I’ll take

28 that back. The wine cellar. The keys to the wine 9570

1 cellar are kept in the break room?

2 A. Yes, they are kept in the break room. Yes,

3 they are kept in the break room.

4 Q. The break room has a safe, correct?

5 A. Yes.

6 Q. At any time during the time you worked

7 there, have those keys ever been locked in that

8 safe?

9 A. Yes.

10 Q. And during the time that you’ve worked

11 there, has it been the habit and custom of the

12 people working on the property that the

13 housekeepers, during the daytime, keep the key on

14 their person during the entire day?

15 A. Yes.

16 Q. In fact, you had to go retrieve the key from

17 the housekeeper the day of the search warrant to let

18 the officers in, correct?

19 A. Some of the keys I did not have access to

20 during that time period, so it was not available to

21 me. I would have to ask them for the key.

22 Q. So the answer is —

23 A. Yes.

24 Q. — on the day of the search warrant, you had

25 to go to one of the housekeepers to get the key to

26 allow the officers to get in the arcade and the wine

27 cellar, correct?

28 A. For immediacy purposes, yes. 9571

1 Q. Now, in 2003, I’m assuming that if you were

2 the head of security at that time, if you had any

3 problems, staffing problems, they would have been

4 things that you discussed with Mr. Marcus, correct?

5 A. Yes.

6 Q. And do you recall having a conversation with

7 Mr. Marcus where you discussed the fact that you

8 were very short of staff and it was becoming a

9 security issue on the ranch?

10 A. Yes.

11 MR. SANGER: Objection; calls for hearsay.

12 THE COURT: Sustained.

13 MR. SANGER: Move to strike.

14 MR. SNEDDON: All I asked was if she had a

15 conversation. I didn’t ask what was said, Your

16 Honor.

17 THE COURT: You kind of filled that in,

18 though.

19 Q. BY MR. SNEDDON: Did you have a conversation

20 with Mr. Marcus about security issues of concern to

21 you?

22 A. Yes.

23 Q. Now, let me ask a few other questions about

24 procedures at the ranch. For instance, the

25 groundskeepers, they’re day staff only?

26 A. Yes.

27 Q. So what time would they ordinarily leave?

28 A. Their working hours are from 7 a.m. to 3:30 9572

1 p.m.

2 Q. And the maintenance people, same hours,

3 basically?

4 A. Yes.

5 Q. So they would go home at 3:30?

6 A. Yes.

7 Q. And the zoo people?

8 A. Same time.

9 Q. And most of the maid staff would go home at

10 the same time, except those that were kept for the

11 night?

12 A. Yes.

13 Q. And those that were kept for the night would

14 come in at a little later time, correct?

15 A. Yes, I believe so.

16 Q. So basically, other than a few staff —

17 well, let me ask you this: The housekeeping staff

18 that was retained at night was smaller in numbers

19 than those that were there during the day, correct?

20 A. Well, it would depend on the activity. I

21 couldn’t say during that time frame — I wasn’t in

22 charge of that department, so I’m sure — just as I

23 would schedule people for the bulk of the

24 activities, so if they had something going on in the

25 evening, I’m sure they would schedule for more in

26 the evening than they would during the day.

27 Q. Fair enough. But that would be the

28 exception, not the rule, though, correct? 9573

1 A. No, that’s what we had to work with, so you

2 schedule your people when you need them.

3 Q. No. I meant, it would be the exception that

4 they would have to be there because you were having

5 an event as opposed to the normal situation. You

6 don’t have events every night?

7 A. No, we don’t have events every night. But

8 if we have large groups of guests on property, such

9 as during that time period, then, you know, dinner

10 may be served late. I’m not sure exactly what all

11 their duties are, but….

12 Q. But that would be an exception where

13 those — where you would have those kind of events.

14 Obviously you’d have to have people there to help,

15 correct?

16 A. Yes.

In yet another attempt to make Jackson look like someone who had something to hide, Sneddon questioned Silva about why security personal were not allowed inside of the main house unless they were specifically requested or there was an emergency, and then segued into the subject of children sleeping in his bedroom. Sneddon insinuated that adults were not allowed to go inside of Jackson’s bedroom once young children were in there, but Judge Melville sustained Sanger’s objection:

17 Q. Now, you say that the security staff is not

18 allowed in the building — I’m sorry, in the main

19 residence unless called by the defendant, Mr.

20 Jackson, or there’s an emergency, correct?

21 A. If it’s not necessary for you to be in the

22 house.

23 MR. SNEDDON: Move to strike as

24 nonresponsive, Your Honor.

25 THE COURT: Stricken.

26 Q. BY MR. SNEDDON: I think you told us that

27 the only two occasion where staff, security staff,

28 were allowed into the house was either because Mr. 9574

1 Jackson summoned one of you or there was an

2 emergency. Now, is that correct?

3 A. Yes.

4 Q. You have on occasion been in Mr. Jackson’s

5 bedroom, correct?

6 A. Yes.

7 Q. And you know that to get into Mr. Jackson’s

8 bedroom, as you approach the door, there’s a chime

9 that goes of inside of the room, correct?

10 A. Yes.

11 Q. And you also know that the door is locked

12 from the inside, correct?

13 A. I believe there may be a deadbolt there.

14 Q. And that a person cannot — you cannot enter

15 that room without somebody unlocking the door from

16 the inside, correct?

17 A. If there’s an emergency, I would get through

18 that door.

19 Q. I’m sure you would. I’m not trying to say

20 you wouldn’t do your job and break through it.

21 But short of breaking through the door, you

22 would have to have somebody on the inside open it

23 up, correct? Is that a fair statement?

24 A. Yes.

25 Q. And certainly if that was true of you, it

26 would certainly be true of any guest that was

27 staying at the place, correct?

28 MR. SANGER: Objection; calls for 9575

1 speculation.

2 THE COURT: Sustained.

3 Q. BY MR. SNEDDON: At the time that these

4 young boys that you’ve talked about were in the main

5 residence with Mr. Jackson, they were there

6 without — on many occasions without parental

7 supervision, correct?

8 A. I would say there were some occasions. I

9 don’t know if there were many occasions.

10 Q. I’ll settle for “some.”

11 There were some occasions where some of

12 these young boys were in the house with Mr. Jackson

13 with nobody else present; is that a fair statement?

14 A. I would say that would be fair.

15 Q. It would also be a fair statement that

16 inside of his room, that nobody would be allowed to

17 go in there and see what was going on; isn’t that a

18 fair statement?

19 MR. SANGER: Objection, Your Honor. Calls

20 for speculation; no foundation.

21 THE COURT: Sustained.

22 THE WITNESS: I would say that would be

23 normal for anyone.

24 THE COURT: Wait. The question was

25 sustained, the objection.

26 Q. BY MR. SNEDDON: So the simple answer would

27 be, you had no idea what was going on inside the

28 house when those boys were there with Mr. Jackson? 9576

1 MR. SANGER: Objection; argumentative.

2 THE COURT: Sustained.

3 MR. SNEDDON: Do you want to take the break,

4 Your Honor?

5 THE COURT: All right. We’ll take our break.

6 (Recess taken.)

Upon returning from recess, Sneddon reintroduced the topic of Gavin’s cart crash, and Silva explained that Gavin retained his cart driving privileges after the first crash in 2002, but had them revoked in 2003. Afterwards, Sneddon continued to assert that Neverland was a haven for mayhem and mischief for its young visitors:

7 THE COURT: All right. Go ahead.

8 Q. BY MR. SNEDDON: Mrs. Silva, are you

9 familiar with a company called Ace Protective Group?

10 A. Yes.

11 Q. And do they provide security services for

12 the ranch?

13 A. Yes.

14 Q. That’s in addition to the regular staff

15 that’s on the ranch?

16 A. We used them as contract. The employees

17 were supervised, managed on the ranch, and they

18 officially paid payroll services.

19 Q. Were they just used for special occasions or

20 were they there all the time?

21 A. No, they were used from the time period of,

22 I believe, 1997 through 2003, I believe.

23 Q. So, for instance, somebody who was working

24 as a security officer on the ranch during that time

25 period, they would actually be employed by the Ace

26 Protective Group as opposed to MJJ Productions or

27 the defendant?

28 A. Yes, some were. 9577

1 Q. And some were not?

2 A. Some were not.

3 Q. But they all worked under your supervision?

4 A. Yes.

5 Q. Thank you.

6 Now, let’s talk a little bit about the

7 ranch. You described some behavior where Gavin

8 Arvizo crashed in a golf cart.

9 A. Yes.

10 Q. That happened — I believe Mr. Sanger showed

11 us it was in, as I recall, June of 2002.

12 A. Yes.

13 Q. And there’s no log entry in any of the logs

14 in 2003 that indicate that Gavin ever had his

15 driving privileges taken away on the golf carts, are

16 there?

17 A. I would have to look at the gate logs to

18 see. I believe what the report said was that a

19 verbal warning was given.

20 Q. In 2002?

21 A. Yes.

22 Q. Yes. We had that report.

23 A. Yes.

24 Q. But to your knowledge, you don’t recall any

25 situation where Gavin Arvizo was later, during the

26 time in 2003 while they were on the ranch, deprived

27 of his privileges to drive golf carts, correct?

28 A. In 2003, he did have a golf cart taken away 9578

1 from him.

2 Q. Do you recall what date that was?

3 A. It was written on the same line where I

4 believe there was an accident that happened with —

5 that involved Mr. Brando’s grandson. As a result of

6 that accident, the golf carts were taken away.

7 Q. And your recollection is it was taken away

8 from Gavin and from Shane?

9 A. Yes.

10 Q. So it would be that accident report?

11 A. Pardon me?

12 Q. It would be that accident report, correct?

13 A. I believe that incident, the golf carts were

14 temporarily taken away from them.

15 Q. You’ve described a situation where, I

16 believe, in the past that you thought that at one

17 point or another, every one of the young boys that

18 would visit that ranch got carried away, correct?

19 A. Not all of them. But I would say they had

20 fun.

21 Q. Do you recall telling — do you recall a

22 conversation that you had with a sheriff’s

23 department detective?

24 A. Yes.

25 Q. And do you recall him asking you about the

26 conduct of a couple of young boys?

27 A. Yes.

28 Q. And you said to him that they all did; “At 9579

1 one point or another, they would all have to calm

2 down, and we’d all have to take things away from

3 them, all of them”?

4 A. I would say there was an occasion where all

5 of them needed to be reminded of what the rules

6 were.

7 Q. So you didn’t tell them that on all

8 occasions, eventually somebody had to have something

9 taken away from them?

10 A. The way you asked the question, I believe

11 what you’re asking me is every single person has had

12 a golf cart taken away. Is that what you’re asking?

13 Q. No. Just the young boys.

14 A. One occasion we would have to remind them,

15 again, to follow the rules.

16 Q. And you said that — you thought the reason

17 for that was because the children felt there was so

18 much freedom at Neverland Ranch, correct?

19 A. Yes.

20 Q. And you also said that you never saw Mr.

21 Jackson ever tell the children to calm down or not

22 do anything, correct?

23 A. Yes.

24 Q. And you felt — you told the officer that

25 you felt that at times you were forced to be the bad

26 guy because Mr. Jackson wouldn’t do that when you

27 thought he should; isn’t that correct?

28 A. He’s the host, so that’s not his job. 9580

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

2 Honor. It calls for hearsay.

3 THE COURT: Overruled.

4 THE WITNESS: I didn’t hear what his reply

5 is.

6 THE COURT: You should rephrase the question.

7 It was complicated.

8 Q. BY MR. SNEDDON: You also told the

9 investigator that you felt it was unfair at times

10 that you and your security officers were placed in a

11 bad position because Mr. Jackson would not

12 discipline people?

13 MR. SANGER: Objection; calls for hearsay.

14 Q. BY MR. SNEDDON: In his presence, correct?

15 A. In his presence, it wouldn’t be appropriate

16 for him, as a host, to discipline. That would be

17 our job. So he was relying on us to do our job.

18 Q. Did you tell the officer that you felt that

19 Mr. Jackson had placed you in a position of being

20 the bad guys?

21 A. Sure.

Silva denied having any knowledge of any children being found intoxicated at Neverland:

22 Q. Now, you stated that you had no personal

23 knowledge about reports of children being

24 intoxicated on the ranch, correct?

25 A. Correct.

26 Q. As a head of security, do you review the

27 logs all the time?

28 A. At the end of the week I review them. 9581

1 Q. And you discuss with your staff any concerns

2 about things that may be going on on the ranch to

3 make sure everything’s okay?

4 A. On a daily basis.

5 Q. You did receive some reports, did you not,

6 that there were children intoxicated on the ranch?

7 A. I did not receive any direct report, someone

8 coming to me and reporting that they found someone

9 intoxicated.

10 Q. But you had information to that effect, did

11 you not, as the head of security?

12 A. There is always a concern for it, because

13 there’s alcohol available, so we would make — take

14 precautions to make sure that that wouldn’t happen.

15 Q. I think the question was, did you have

16 personal — I mean, did you have knowledge of the

17 fact from your staff that there were incidents where

18 they encountered children intoxicated?

19 A. I was not —

20 MR. SANGER: Excuse me.

21 Calls for hearsay.

22 THE COURT: Overruled.

23 You may answer.

24 Q. BY MR. SNEDDON: I think that’s a “yes” or

25 “no.”

26 A. No.

27 Q. Are you familiar with a person by the name

28 of Chris Carter? 9582

1 A. Yes.

2 Q. Who is Mr. Carter?

3 A. Mr. Carter was a personal assistant/traveling

4 security person for Mr. Jackson.

5 Q. So when Mr. Jackson was around, Mr. Carter

6 was around. He was his security, correct?

7 A. Yes. No, he was not under my supervision.

8 Q. No, I know. I mean, the jury may not know,

9 but he worked for — basically for Mr. Jackson?

10 A. Yes.

11 Q. But when Mr. Jackson was at the ranch, Mr.

12 Carter was at the ranch, right?

13 A. Most of the time.

14 Q. And did Miko Brando on occasion also serve

15 as part of the security detail for Mr. Jackson, to

16 your knowledge?

17 A. I’m not aware of that.

18 Q. And have you ever seen Mr. Jackson carry a

19 cell phone?

20 A. No.

21 Q. Have you ever seen Mr. Jackson use a cell

22 phone?

23 A. No.

24 Q. Did you ever see any of these personal

25 bodyguards loan Mr. Jackson a cell phone to be used?

26 A. No.

Silva had no recollection of any interactions between Jackson and Gavin Arvizo:

27 Q. Now, at the time that the Arvizos came to

28 visit in early February of 2003, did you know that 9583

1 they had come from Miami?

2 A. No.

3 Q. Did you know where they had come from?

4 A. No.

5 Q. Did you know how much clothing they had with

6 them or how long they were expected to stay at the

7 ranch?

8 A. No.

9 MR. SANGER: Compound, Your Honor. Move to

10 strike the answer.

11 MR. SNEDDON: I’ll break it up.

12 Q. Did you know —

13 MR. SANGER: Excuse me. I just need a —

14 THE COURT: He’s going to rephrase.

15 Stricken.

16 MR. SANGER: So it’s stricken. There was a

17 motion to strike the answer.

18 THE COURT: Stricken.

19 Q. BY MR. SNEDDON: Did you know how much

20 clothing they brought with them?

21 A. No.

22 Q. Did you know how long they were supposed to

23 stay?

24 A. No.

25 Q. Did you know where they had been before they

26 came to Neverland Ranch?

27 A. No.

28 Q. Did you know that they came to the ranch 9584

1 with the defendant, Mr. Jackson?

2 A. I did not see that personally.

3 Q. But you’re aware of that?

4 A. Yes.

5 Q. Now, during the time that the Arvizo

6 children were at the ranch in February of 2003, and

7 in March, you observed Mr. Jackson spend time with

8 the boys, did you not?

9 A. I recall Mr. Jackson was there, but I don’t

10 recall any specific interaction with them.

11 Q. You don’t recall Mr. Jackson spending time

12 with Gavin Arvizo?

13 A. Not specifically.

14 Q. And during most of this particular point in

15 time, you would be leaving in the early evening

16 hours to go home, correct?

17 A. My hours were varied at that time, depending

18 on the coverage that we needed.

19 Q. All right. And so — but ordinarily, you

20 would leave to go home in the early evening hours,

21 correct?

22 A. No, sir.

23 Q. So if we were to look at your time sheets

24 they would reflect the fact that — are you, by the

25 way, filled out on the logs?

26 A. Yes.

27 Q. Your name’s on the logs, so we can look at

28 the logs and we can all find out what time you 9585

1 checked in and what time you checked out for the

2 day?

3 A. Yes.

4 Q. That would be an accurate depiction of your

5 work schedule during February and March of 2003?

6 A. Yes.

7 Q. Is that correct?

8 A. Yes.

9 Q. Now, did you basically run things from the

10 administration building?

11 A. Depended on the activity. If the — if I

12 had enough officers to cover the shift, then I would

13 come down and supervise the shift and then I’d work

14 from my office. If not, I was part of the rotation

15 as well.

16 Q. So it’s your testimony that you have no

17 recollection of Mr. Jackson being in the presence of

18 Gavin Arvizo, for instance, in the arcade room

19 playing games?

20 A. I can’t recall specifically.

21 Q. You have no recollection of Gavin Arvizo

22 being with Mr. Jackson in the movie theater?

23 A. I’m sure it was possible, but you’re asking

24 me specifically, and I don’t remember an occasion.

25 There was a lot of people there during that time,

26 and people were coming and going, so —

27 Q. I’m just asking what you recall. Do you

28 recall any situation where you recall Gavin Arvizo 9586

1 being with the defendant down in the amusement park?

2 A. No.

3 Q. Do you recall any situation where Gavin

4 Arvizo was with the defendant down at the zoo?

5 A. No.

6 Q. Do you recall any incident or occasions of

7 Mr. Jackson being with Gavin Arvizo around the

8 swimming pool?

9 A. No.

10 Q. Or out at the teepee?

11 A. I believe they may have had dinner there

12 once.

13 Q. It’s true, is it not, that Gavin Arvizo

14 spent some of the nights in Mr. Jackson’s house?

15 A. Yes.

Next, Sneddon questioned Silva about the security request to not have the Arvizo children leave Neverland without permission; Gavin and Star had been caught driving several vehicles at Neverland (the keys were left on the dashboard of those vehicles), and that directive was added to the log books as a precaution to be on the lookout for any suspicious behavior form the Arvizos. Sneddon insinuated that this was done as part of the “conspiracy” to hold the Arvizos hostage because neither Jordan Chandler, Wade Robson, nor Brett Barnes had this same directive written about them:

16 Q. I’m assuming, as one of your chief

17 responsibilities there as the security officer at

18 this point in time in 2003, that you would try to be

19 very proactive about liability issues on the ranch,

20 correct?

21 A. Yes.

22 Q. In other words, sort of like a loss

23 prevention concept; you want to make sure that you

24 run things so that accidents are prevented before

25 they happen, correct?

26 A. Yes.

27 Q. And you put procedures in place to avoid

28 that kind of situation, right? 9587

1 A. Yes. We have standard operating procedures.

2 Q. And also as part of those procedures, one of

3 the things to protect yourself from a liability

4 standpoint is, if there’s something that’s

5 significant that happens on the ranch, you want to

6 put it in the logs so later, if it happens, it could

7 be documented, correct, for liability purposes?

8 A. Personally, I would do that myself. I’m

9 relying on the discretion of the officers.

10 Q. Well, you would expect, as you, they worked

11 under your supervision, correct?

12 A. Yes.

13 Q. They worked under your direction?

14 A. Right.

15 Q. And you would expect that if any significant

16 event occurred on the ranch, that would be

17 documented in the reports, correct?

18 A. Reports or gate logs, yes.

19 Q. At someplace where —

20 A. Yes.

21 Q. — something would happen that’s out of the

22 ordinary, that that would be something that you’d

23 want to document?

24 A. Yes.

25 Q. To show that if an incident occurred, that

26 you took a response to it to prevent it from

27 happening again, correct?

28 A. Yes. 9588

1 Q. You want to document that event, correct?

2 A. Yes.

3 Q. Okay. And as part of that policy, you had a

4 rule that the golf carts couldn’t go off the ranch,

5 right?

6 A. They’re not designed to go off the property.

7 They shouldn’t go off, no.

8 Q. I just asked —

9 A. Yes. Yes.

10 Q. And if somebody tried to drive a golf cart

11 off the ranch, they would be stopped by the gate

12 person and turned around and told to head back out,

13 correct, head back to the ranch?

14 A. That would be our procedure.

15 Q. That would be a standard procedure?

16 A. It would be our policy.

17 Q. Okay. And somebody who let a person off the

18 ranch with the cart would be in a little bit of

19 trouble, wouldn’t they, with you?

20 MR. SANGER: Objection; calls for

21 speculation.

22 MR. SNEDDON: Let me rephrase it. I’m

23 sorry, Judge.

24 Q. It would be a violation of your policies for

25 somebody at the gate to allow somebody off the ranch

26 with a go-cart; is that correct?

27 MR. SANGER: Well, I’m going to —

28 Are you talking about a go-cart or a golf 9589

1 cart?

2 MR. SNEDDON: Golf cart.

3 THE WITNESS: It would be against our policy

4 to allow someone — someone underage, without

5 driving privileges, to leave the property.

6 Q. BY MR. SNEDDON: So “underage” would be

7 anybody 16 and below?

8 A. Driving age, yes.

9 Q. Or below 16.

10 A. Driving age, yes.

11 Q. And the same thing was true of the quads?

12 A. Yes.

13 Q. In other words, there was a rule at the gate

14 that you just didn’t let somebody off with the

15 quads?

16 A. Yes.

17 Q. Now, in 2003, did you know how old Gavin

18 Arvizo was?

19 A. No.

20 Q. He was small for his age in 2003, was he

21 not?

22 A. I don’t know.

23 MR. SANGER: Objection. Calls for

24 speculation; lack of foundation.

25 THE COURT: Sustained.

26 Q. BY MR. SNEDDON: He was a rather small

27 person, was he not?

28 A. No. 9590

1 Q. In 2003?

2 A. I don’t know how old Gavin was at the time.

3 Q. What’s your estimate?

4 A. My estimate would be that he was 15.

5 Q. 15? And how old do you think Star was?

6 A. At least 12 or 13 years old.

7 Q. You told the jury that the reason that

8 there’s a notation in the logs about the boys not

9 leaving the ranch was because they had been driving

10 vehicles around the ranch, correct, the Navigator

11 and the van?

12 MR. SANGER: Objection, Your Honor. That

13 misstates the testimony.

14 MR. SNEDDON: Well, I’m — let me go back.

15 I’ll clarify that. I thought that’s what she said.

16 I’ll withdraw the question, Your Honor.

17 THE COURT: All right.

18 Q. BY MR. SNEDDON: Was the reason that the

19 notation that Mr. Sanger showed you up there on the

20 board about the boys not to leave the ranch related

21 to their driving of the Navigator or the van?

22 A. Yes.

23 Q. Okay. So I was right. You don’t have to

24 answer that.

25 At any time in any of those logs, did you

26 ever see a notation that documented the fact that

27 those boys were driving those cars?

28 A. No. 9591

1 Q. And you say that the policy of the ranch is

2 to lock the key to the cellar in the safe, correct?

3 A. On certain occasions it is.

4 Q. But the policy of the ranch was to leave

5 keys in the cars on the ranch? You didn’t secure

6 them somewhere?

7 A. No.

8 Q. You don’t think that would be a liability

9 problem if somebody got in one of those cars and

10 drove it off?

11 MR. SANGER: Objection; argumentative.

12 THE COURT: Sustained.

13 Q. BY MR. SNEDDON: Did it ever occur to you as

14 the chief of security during this period of time

15 that there was a liability issue to the ranch by

16 leaving those keys in the cars unattended?

17 A. No.

18 Q. Did you change the procedure at any time?

19 Are they still left in the carts?

20 A. At this time, I believe they are. Some

21 vehicles are locked.

22 Q. I assume locked, and the keys aren’t locked

23 inside of them. So they’re placed somewhere else,

24 correct?

25 A. No. Correct.

26 Q. And it’s also true that at no time during

27 the time that you’ve been employed by that ranch do

28 you recall there ever being an entry in a log that 9592

1 children were not to leave the ranch, correct?

2 A. That’s correct.

3 Q. And that, as a matter of fact, on those

4 occasions you told the ladies and gentlemen of the

5 jury that, for instance, Wade Robson was at the

6 ranch without supervision, you don’t find any entry

7 saying, “Don’t let Wade Robson leave the ranch

8 unsupervised,” correct?

9 MR. SANGER: Objection. Assumes facts;

10 compound.

11 THE COURT: Overruled.

12 You may answer.

13 THE WITNESS: Answer?

14 Q. BY MR. SNEDDON: Yes. There’s nothing in

15 the logs to that effect, right?

16 A. I’d have to go through all the gate logs.

17 Q. Do you have any recollection, as the head of

18 security, that there was ever an entry like that

19 with regard to Wade Robson?

20 A. No.

21 MR. SANGER: Objection; lack of foundation.

22 THE COURT: Overruled.

23 Q. BY MR. SNEDDON: With regard to Brett

24 Barnes, you’ve told the jury already that he’s been

25 there on occasion without his parents.

26 Do you ever recall, during the time that he

27 was on that ranch, that there was a notation in the

28 logs that he was not to leave the ranch? 9593

1 A. I did not see one.

2 MR. SANGER: I’m sorry. I was trying to

3 object. Objection. One second. Objection; lack of

4 foundation.

5 THE COURT: They can’t hear.

6 MR. SANGER: Objection. Lack of foundation

7 as to the 1990 gate logs, ‘90 to ‘93.

8 THE COURT: Sustained.

9 Q. BY MR. SNEDDON: During the time that you

10 were employed on the ranch as a security officer

11 between the time period of 1991 and 1993, you’ve

12 told us that Wade Robson visited the ranch, correct?

13 A. Yes.

14 Q. And at that time, you would have been one of

15 the officers who would review the entries on the log

16 to make sure you do your job, correct?

17 A. Yes.

18 Q. And you would have done that on a daily

19 basis when you came to work; isn’t that correct?

20 A. Yes.

21 Q. And do you recall any log entries during

22 that period of time in which somebody wrote a note

23 saying, “Don’t let Wade Robson leave this ranch”?

24 A. No.

25 Q. And with regard to Brett Barnes, during the

26 same time period that you were working as a security

27 officer and you were reviewing those logs, did you

28 ever see an entry that said anything about not 9594

1 letting Brett Barnes leave the ranch?

2 A. No.

3 Q. Now, if I were to ask you the same question

4 about Jordan Chandler, your answer would be the

5 same, correct?

6 A. Correct.

7 Q. In fact, the entry that was made on the logs

8 that you testified to, that Mr. Sanger showed you,

9 was the first and only time you’ve ever seen that

10 kind of entry made on a ranch log, correct?

11 A. Yes.

Finally, Sneddon reiterated how undisciplined Jackson’s young visitors were at Neverland by asking Silva about the Coultry brothers, who lived near Neverland and allegedly egged her car, and then closed out his cross examination by having Silva confirm that Jackson possessed “very graphic” pornography:

12 Q. Are you familiar with some boys from Santa

13 Ynez called the Coultry brothers?

14 MR. SANGER: Objection; beyond the scope of

15 direct.

16 THE COURT: Overruled.

17 MR. SNEDDON: I think I’m entitled to — I

18 think….

19 Q. It’s overruled. You can answer.

20 Are you familiar with the Coultry brothers?

21 A. Yes.

22 Q. And they were visitors at the ranch quite

23 often, is that correct, during this time period,

24 2003?

25 A. I believe after that time period.

26 Q. You don’t recall them being on the ranch

27 during 2003?

28 A. Yes, but after the February time. 9595

1 Q. Yeah. No —

2 A. Not during the same time.

3 Q. — that’s fair.

4 A. Yes.

5 Q. During 2003 they were there?

6 A. Yes.

7 Q. And by your own statement to investigators,

8 I think you described them as wild, correct?

9 A. Yes.

10 MR. SANGER: Objection. Move to strike;

11 calls for hearsay. Also not relevant as to the time

12 period that what we’re talking about.

13 THE COURT: Overruled. The answer was,

14 “Yes.” Next question.

15 Q. BY MR. SNEDDON: In fact, while they were on

16 the ranch one day, they egged your car so bad that

17 you had to get it repainted, correct?

18 MR. SANGER: Objection, Your Honor.

19 Relevance.

20 THE COURT: Overruled.

21 You may answer.

22 THE WITNESS: I don’t know if it was them.

23 Q. BY MR. SNEDDON: Somebody did, correct?

24 A. Someone did, yes.

25 Q. And they were on the ranch at that time?

26 A. Yes.

27 Q. All right. During the time that you were

28 employed at the ranch, were you ever aware of who 9596

1 was sent out to buy adult magazines for Mr. Jackson?

2 A. No.

3 Q. Did you receive in your office a package of

4 adult magazines that came from Japan?

5 A. Yes.

6 Q. And those were — the contents of the

7 envelope were from Mr. Jackson’s luggage that was

8 mailed back to Neverland after he had gone to Japan,

9 correct?

10 A. I don’t know if it was from Japan, but they

11 were left in my office.

12 Q. And they were adult materials, correct?

13 A. Yes.

14 Q. And you described them, I think, as very

15 graphic?

16 A. Yes.

17 MR. SNEDDON: No further questions, Your

18 Honor.

Sanger made it a point to clarify to the jury that Jackson’s young visitors usually were accompanied by their parents, which is contrary to the prosecution’s assertions that children were “dumped” at Neverland to wreak havoc and cause mayhem:



22 Q. Okay. Mr. Sneddon asked you about various

23 guests coming with or without parents, one parent or

24 the other. Do you remember that, at the beginning

25 of your cross-examination?

26 A. Yes.

27 Q. Okay. Now, the Arvizos — to your

28 knowledge, the Arvizos came with at least their 9597

1 father the first several times they came; is that

2 correct?

3 A. Yes.

4 Q. And he — did he supervise them?

5 A. Yes.

6 Q. And then there was a period of time in 2002

7 when they came with Chris Tucker; is that correct?

8 A. Yes.

9 Q. And that’s Chris Tucker the entertainer,

10 right?

11 A. Yes.

12 Q. And Mr. — was Mr. Jackson on the premises

13 or not, or sometimes on and sometimes off?

14 A. Yes.

15 Q. The latter?

16 A. Sometimes yes; sometimes no.

17 Q. All right. Was Mr. Tucker supervising the

18 Arvizo kids while he was there?

19 A. Yes.

20 Q. All right. And then after that, the Arvizo

21 kids came with their mother. That was in February

22 of 2003, correct?

23 A. Yes.

24 Q. And she was on the property most of the time

25 that they were on the property; is that right?

26 A. Yes.

27 Q. She was not there some of the time, though?

28 A. Correct. 9598

Next, Silva reasserted that the directive to not allow the Arvizo boys to leave Neverland without permission was only in effect for one day (February 19th, 2003), and was only enacted because they were caught driving adult vehicles (like the Chevy Astro van and Lincoln Navigator) without permission. That confirmation truly shot holes in the prosecution’s claims that there were nefarious reasons for that directive:

1 Q. All right. Now, you just indicated that —

2 you were asked about these gate logs going back to

3 ‘91 to ‘93. Do you remember that?

4 A. Yes.

5 Q. And from 1991 to 1993, you were not the

6 chief of security; is that correct?

7 A. That’s correct.

8 Q. So it was not your job to review all of the

9 gate logs; is that right?

10 A. That’s correct.

11 Q. It was your job to look at the gate logs

12 when you came on your shift to see if there was any

13 information that you should pick up for use during

14 your shift, correct?

15 A. Correct.

16 Q. That would include figuring out who’s on the

17 property, if there are any special instructions and

18 that sort of thing, right?

19 A. Yes.

20 Q. All right. Did you — for the purpose of

21 testifying here today, did Mr. Sneddon or anybody on

22 his staff show you the gate logs from 1991 to 1993?

23 A. No.

24 Q. Have you had a chance to review those gate

25 logs in recent years?

26 A. No.

27 Q. All right. Now, you indicated that the only

28 entry that you recall with regard to children not 9599

1 leaving the ranch was that one entry on February the

2 19th?

3 A. Yes.

4 Q. All right. And that entry was only for that

5 particular day; is that correct?

6 A. That’s correct.

7 Q. It was not carried forward beyond February

8 the 19th?

9 A. Correct. No.

10 Q. And the entry — that was the first entry,

11 so it obviously didn’t precede the 19th, correct?

12 A. Correct.

13 Q. You indicated that one of the reasons was —

14 that that — let me withdraw that.

15 You indicated that one of the reasons that

16 the notation was in the log, you believed, was

17 because of the kids driving the adult vehicles,

18 correct, the Navigator and the Astro van and so on?

19 A. Correct.

20 Q. Was it also — were there any other factors

21 related to that entry that you’re aware of?

22 A. Well, the children were there unsupervised

23 as well, so —

24 Q. Okay. So there wasn’t a parent there, or

25 somebody like Chris Tucker, to make the call as to

26 whether or not they should leave and who they should

27 leave with; is that correct?

28 A. Correct. 9600

1 Q. Do you recall if Hamid Moslehi was on the

2 property at that time?

3 A. Yes.

4 Q. Was he?

5 A. I’m sorry?

6 Q. Was he?

7 A. Yes, he was.

8 Q. All right. And did he leave that day?

9 A. I believe he did. There was an entry above

10 that that said that he was there.

11 MR. SNEDDON: Well, I’ll object as lack of

12 foundation. No personal knowledge.

13 THE COURT: Overruled.

14 MR. SANGER: I think the answer is in.

15 THE COURT: The answer is in.

16 Q. BY MR. SANGER: Do you have a personal

17 recollection of him being there around that time?

18 A. Yes.

19 Q. Okay. Do you know if he left later that day

20 with the children, with the Arvizo children?

21 A. I don’t know.

22 Q. All right. But if you wanted to find out,

23 you would probably be able to look in the log and

24 determine whether that’s the case or not; is that

25 correct?

26 A. Sure.

27 Q. And generally if somebody leaves the ranch

28 at the exact same minute, if there are a group of 9601

1 people or a number of people who leave at the exact

2 same minute, it generally means they’re in the same

3 vehicle; is that correct?

4 A. Yes.

Next, Silva explained that Wade Robson and Brett Barnes did not present any behavioral problems at Neverland, hence there was never a need to have any special security directives designed to monitor them extra closely:

5 Q. Now, I think you were asked — and I may be

6 wrong about this. I think you were asked if Wade

7 Robson and Brett Barnes had behavior problems. Let

8 me ask you, did they?

9 A. No.

10 Q. Were they polite? Impolite? How would you

11 characterize them as kids?

12 A. They were very kind and considerate.

13 Q. Okay. Did they ever, to your knowledge, get

14 into an adult vehicle and start driving around

15 without permission?

16 A. No.

Here’s another blow to the prosecution: Silva explained that not only did Frank Cascio use the alias “Tyson”, but the ENTIRE FAMILY used it as well!

17 Q. Okay. Going back towards the beginning of

18 your cross-examination, Mr. Sneddon asked you about

19 Frank Cascio. Do you recall?

20 A. Yes.

21 Q. And he asked you if Frank Cascio started

22 using a different name, that is, Tyson, at some

23 point; do you recall?

24 A. Yes.

25 Q. Did, in fact, the entire Cascio family start

26 using a different last name?

27 A. Yes.

28 Q. Did they all ask to be called “Tyson” 9602

1 instead of “Cascio”?

2 A. Yes.

3 Q. Did you honor that request?

4 A. When I could remember.

5 Q. Okay. Now, with regard to Frank

6 Cascio/Tyson, you were asked whether or not he was a

7 close, trusted friend of Mr. Jackson, I think,

8 something to that effect. Do you recall that?

9 A. Yes.

10 Q. Did Frank Cascio — did his relationship

11 with Mr. Jackson have difficulties at one point?

12 MR. SNEDDON: Object; lack of foundation.

13 THE COURT: Sustained.

14 MR. SNEDDON: And vague.

15 MR. SANGER: Okay.

16 THE COURT: Sustained as to foundation.

17 MR. SANGER: All right.

18 Q. You had indicated that Frank Cascio was a

19 close, trusted friend of Mr. Jackson —

20 A. Yes.

21 Q. — correct?

22 Was that consistently true, or was there any

23 change in that relationship from time to time?

24 MR. SNEDDON: Object. Calls for a

25 conclusion; lack of foundation.

26 THE COURT: Overruled.

27 You may answer.

28 THE WITNESS: Yes, it did change on 9603

1 occasion.

2 Q. BY MR. SANGER: Was there a time when Mr.

3 Cascio threw a big party?

4 A. Yes.

5 Q. And did that result in the depletion of

6 ranch resources?

7 A. Yes.

8 Q. Okay. Did that cause a problem between Mr.

9 Cascio and Mr. Jackson?

10 A. Yes.

Next, Silva stated that security was able to enter Jackson’s bedroom at will because they had the security codes to unlock the door:

11 Q. You were asked about the key to the wine

12 cellar, and the part that I’d like to get to is how

13 many keys were there to the wine cellar, to your

14 knowledge?

15 A. To my knowledge, there were a set of keys in

16 the house for the housekeeping staff, a set of keys

17 in the security office.

18 Q. Did somebody walk around with those keys, a

19 security officer walk around with the keys, or were

20 they there at the office to be retrieved?

21 A. They’re on a key ring and they’re kept with

22 the supervisor.

23 Q. Okay. And when you say “security office,”

24 are we talking about the office that’s adjacent to

25 the garage and the video library?

26 A. Yes.

27 Q. So obviously, if somebody had to use it,

28 they’d take the key ring and they go use it, right? 9604

1 A. Yes.

2 Q. Are they supposed to put it back?

3 A. Yes.

4 Q. Does that always happen?

5 A. No, not always. It stays on them sometimes.

6 Q. There was a question — I think the question

7 was about opening the wine cellar. Maybe I’m wrong

8 about that. But in any event, at the time of the

9 search, did you have the keys for the wine cellar?

10 A. Not on me.

11 Q. Okay. And the officers who wanted to search

12 asked to have the key for the wine cellar; is that

13 correct?

14 A. Yes.

15 Q. And did you retrieve the security keys or

16 the housekeeping’s keys?

17 A. I don’t recall at the time. But I may

18 have — I was talking with the housekeepers. I was

19 actually in the house at the time. So to quickly

20 retrieve the keys, I may have grabbed the keys from

21 them or asked for them from the housekeeper.

22 Q. So that — at that time, to your knowledge,

23 there was a set of keys for the security staff?

24 A. Yes.

25 Q. All right. And that included the key to the

26 wine cellar; is that correct?

27 A. Yes, that’s correct.

28 Q. Now, there was some questions about — there 9605

1 were questions about the door to Mr. Jackson’s

2 private area, sometimes called his bedroom or

3 bedroom suite, that area, all right? And you said

4 something about them being locked from the inside.

5 Do you recall that?

6 A. Mr. Sneddon asked a question.

7 Q. All right. Is it possible to open that door

8 from the outside?

9 A. With a key, yes, I imagine so.

10 Q. Okay. Was there a keypad, an electronic

11 keypad there?

12 A. Yes.

13 Q. And did certain people have the combination

14 to that keypad other than Mr. Jackson?

15 A. Yes.

16 Q. Who would have had that?

17 A. Whoever was cleaning his room at the time.

18 Certain guests. And certain house staff.

19 Q. All right. Did security have the keypad

20 number to his private quarters?

21 A. No.

22 Q. Did security have the keypad numbers to

23 other doors in the house?

24 A. Back door only.

25 Q. How about the front door?

26 A. No.

27 Q. So if security needed to get inside the

28 house, they would have to go through — without a 9606

1 key, they’d have to go through the back door?

2 A. Yes.

3 Q. That’s the door most people use anyway to

4 come in and out of that house; is that right?

5 A. Yes.

6 Q. If you’re visiting formally, you’re an

7 invited guest, you come through the front door, I

8 take it, correct?

9 A. Yes.

10 Q. At least when you arrive, right?

11 A. Yes.

12 Q. And thereafter, if you’re staying overnight,

13 you probably just go through the back door, right?

14 A. Correct.

15 Q. Now, is there also a key, as opposed to a

16 keypad, is there a key to unlock the back door?

17 A. Yes.

18 Q. And security had one of those?

19 A. Yes.

20 Q. And is it a different key or the same key to

21 unlock the front door?

22 A. Yes.

23 Q. Did security have one of those?

24 A. Yes.

25 Q. And security did not have, to your

26 knowledge, the keypad number or the key for Mr.

27 Jackson’s room?

28 A. No, we did not. 9607

1 Q. Now, you had the key to go into the back

2 patio; is that right?

3 A. It’s only locked. There’s just a lock, not

4 a keypad.

5 Q. Okay. But a key?

6 A. A key, yes.

7 Q. So did security have a key to go through the

8 patio?

9 A. Yes.

10 Q. All right. So you could get in — if you

11 needed to get in through the patio, you could go in

12 through that way; is that correct?

13 A. Yes.

14 Q. Did you have a key to the back door to Mr.

15 Jackson’s suite?

16 A. I don’t believe we did.

17 Q. You never had occasion to try it, in any

18 event; is that correct?

19 A. No.

Silva then clarified her earlier statements of having to be “the bad guy” and discipline guests and turn down some of their requests:

20 Q. Now, you were asked whether or not you were

21 put in the position of being the bad guys sometimes;

22 is that right?

23 A. Yes.

24 Q. Could you explain what you mean by that?

25 A. Well, our position is to make sure that the

26 guests are being in a safe position, they’re not

27 being jeopardized. Mr. Jackson is the host. And

28 it’s his position to be gracious and accommodating. 9608

1 That was our job. “Bad guys” is more of a — “bad

2 guys.” Not that we were bad, but it was part of our

3 job, and we did it, and we did it consistently. And

4 that’s what we did.

5 Q. All right. So, are you complaining about

6 being put in that position?

7 A. No.

8 Q. Okay. I kept interrupting. You’re getting

9 a drink of water, so I waited there for a moment.

10 A. Okay.

11 Q. In other words, that was part of your

12 function was to be the ones that would draw the line

13 on some of the safety issues, particularly with

14 regard to the equipment; is that right?

15 A. Yes.

16 Q. Sometimes people want to ride Mr. Jackson’s

17 Harley?

18 A. Yes.

19 Q. And are there times when you’d have to be

20 the bad guy with regard to that?

21 A. Yes.

22 Q. And you’d do that graciously as well?

23 A. Yes.

Next, Sanger went through the gate logs from February 6th through March 12th, 2003 (the dates that the Arvizo family were at Neverland) and asked Silva to describe her schedule. Afterwards, he asked a few more general questions about the Arvizos, the Coultry brothers, and ended his redirect examination:

24 MR. SANGER: Okay. Now, I’ve noticed Mr.

25 Sneddon is using the exhibit. I don’t object to

26 that, but I’m going to use it in just a minute,

27 so — okay. Thank you.

28 May I ask leave of the Court to approach the 9609

1 witness with the exhibit, or with the book, and it

2 includes Exhibit 335, if I may?


4 MR. SANGER: Thank you.

5 There’s some water spilled there so —

6 people do that all the time.

7 MR. SNEDDON: Counsel, what’s the date?

8 Just give me the date.

9 MR. SANGER: Just one second. I’m going to

10 start with March the 6th.

11 MR. SNEDDON: Thank you.

12 MR. SANGER: And page 00194 of Exhibit 335.

13 Q. And, Miss Silva, you might want to pull that

14 closer to you, whatever is comfortable for you to

15 read, because I’m going to ask you to go through the

16 logs from February the 6th, 2003, through March the

17 12th, 2003, and tell us, if you would, whether or

18 not you’re on the property each day and what your

19 hours were.

20 A. From February 6th —

21 MR. SNEDDON: Your Honor, I’m going to

22 object. The document speaks for itself. It’s in

23 evidence. Best evidence rule.

24 MR. SANGER: Well, the best evidence rule —

25 anyway, I won’t argue.

26 THE COURT: Overruled.

27 THE WITNESS: On this day of March 6th of

28 2003, I was already on the property. We — I was 9610

1 carried over from the previous day, and so I got off

2 my shift at 6:30 a.m.

3 Q. BY MR. SANGER: You know what I really meant

4 to do, now that I’ve said that out loud, is I meant

5 to go back to February.

6 A. Oh, okay.

7 Q. That was the problem.

8 What I’d like to do is just get an idea of

9 what your hours were during that time. You

10 indicated on cross-examination that you could look

11 at the logs and talk about what hours you were

12 there. And I believe you said you thought you were

13 there late from time to time. So if you can give us

14 just a quick idea as you look through the logs —

15 you can do it day by day for a while, but give us a

16 quick idea of what your general working days were

17 like at that time.

18 A. On February 7th, 2003, I was carried over

19 from the previous shift and went off duty at 0152

20 hours.

21 Q. So that meant you were there the night of

22 February 6th, and you were there past midnight and

23 then you went home; is that correct?

24 A. Yes.

25 Q. Okay. All right.

26 A. February 13th, 2003, I was carried over from

27 the previous shift and was signed out at 7 a.m.

28 Q. So if you look back to the 12th, give us an 9611

1 idea of when you started.

2 A. I started at 1500 hours, which is three

3 o’clock in the afternoon.

4 Q. So you went all night till the next morning?

5 A. Yes.

6 Q. All right. Go ahead.

7 A. On the 15th, I was carried over from the

8 previous day and continued to work and carried over

9 again, and I left my shift at 2125, which is 9 p.m.

10 Q. Okay. Well, just for the fun of it, go back

11 to the day before. Don’t move your hand. Go back

12 to the day before, when you were carried over, and

13 see when you started the day before.

14 A. I came in at 4 p.m.

15 Q. So 4 p.m., the whole night, the whole next

16 day, and didn’t leave until the day after that; is

17 that correct?

18 A. Correct.

19 Q. Now, as Mr. Sneddon said, the records speak

20 for themselves. So if somebody wanted to go

21 through, they could figure out exactly when you were

22 there; is that right?

23 A. Yes.

24 Q. But it’s safe to say that you worked many

25 evenings and many nights; is that correct?

26 A. Yes.

27 Q. You were asked if you could remember

28 specific occasions that Mr. Jackson was together 9612

1 with the Arvizo children. Do you recall that?

2 A. Yes.

3 Q. And you said you can’t recall specifically.

4 I think you recalled one dinner at the teepee; is

5 that right?

6 A. Yes.

7 Q. And was that — how many people were at that

8 dinner; do you know?

9 A. There were other people there. Exactly how

10 many and who was there, I can’t recall.

11 Q. Okay. Other than that one dinner with a

12 number of people, and the Arvizos being amongst

13 them, you say you don’t have any other specific

14 recollection during that time period in 2003 of what

15 Mr. Jackson was doing, if anything, with the Arvizo

16 kids?

17 A. I don’t recall ever seeing them together

18 during that time frame.

19 Q. Okay. So if they were together, you just

20 didn’t see them; is that safe to say?

21 A. I didn’t see them.

22 Q. Okay. Were there times during the February

23 or March period where the Arvizo children were

24 staying — the Arvizo boys were staying in the guest

25 unit?

26 A. They were assigned a guest unit, yes.

27 Q. So you didn’t go to check to make sure they

28 were in there? 9613

1 A. No.

2 Q. And this incident with the Coultry

3 brothers — how do you say that?

4 A. I don’t know.

5 Q. However you say the brothers’ names, the

6 incident you talked about where somebody egged your

7 car, first of all, you don’t know if they did it,

8 right?

9 A. I didn’t see them do it.

10 Q. And secondly, that did not occur at a time

11 when the Arvizos were on the ranch; is that correct?

12 A. That’s correct.

13 MR. SANGER: Okay. No further questions.

Sneddon went for the jugular by asking Silva if she would allow her own children to participate in the activities at Neverland, and she stated that she would not, but was not allowed to go into detail because Judge Melville sustained Sanger’s objection:



17 Q. Just a couple of questions. It won’t be

18 long.

19 A. Okay.

20 Q. Do you recall describing the atmosphere at

21 the ranch with regard to children as being one that

22 you, as a mother, would not allow your children to

23 participate in?

24 A. Yes.

25 MR. SANGER: Objection; calls for hearsay.

26 THE COURT: Sustained.

27 MR. SNEDDON: I’m asking about her

28 statement. 9614

1 THE COURT: That’s sustained.

2 Q. BY MR. SNEDDON: Based upon what you saw at

3 the ranch and your observations as a security

4 officer during the period of time from 1991 to 2003,

5 did you form an opinion with regard to whether you

6 would ever allow your children to participate in the

7 activities at the ranch as you saw them?

8 A. As a security officer, no.

9 Q. As a mother?

10 A. Yes.

11 Q. And that opinion is that you would not;

12 isn’t that correct?

13 A. That’s correct.

Silva was asked to explain to the jury why both Frank Cascio and Vinnie Amen began using the aliases “Tyson” and “Black” on February 28th and March 1st, respectively; the prosecution asserted that it was due to the conspiracy, but Judge Melville sustained Sanger’s objection, and Sneddon ended his recross examination:

14 Q. Now, you said that the entire Cascio family

15 chose to have themselves referred to as “Tyson”?

16 A. Yes.

17 Q. Did I understand you correctly?

18 A. Yes.

19 Q. And when the Cascio — when was that

20 decision made, to your knowledge?

21 A. I can’t recall at this time.

22 Q. Was it a decision that was made during

23 February and March of 2003, or after?

24 A. I believe it was around that time.

25 Q. Do you — in reviewing those logs for Mr.

26 Sanger, do you see any occasion in those logs, from

27 February 7th through March the 12th, where any

28 member of the Cascio family is referred to as 9615

1 “Tyson,” other than Frank?

2 A. I would have to go through each page.

3 Q. Do you want to do that?

4 A. Sure.

5 Q. Go ahead.

6 A. What were the dates?

7 Q. From February the 7th until March the 12th.

8 A. I have one entry here.

9 Q. What’s the date on that entry?

10 A. The date of entry is February 28th, 2003.

11 Q. And the name?

12 A. There’s an entry in the “Directive” part of

13 our log.

14 Q. And the name?

15 A. “Tyson.” “Cascio family will go by Tyson

16 family.”

17 Q. That’s on the 28th?

18 A. Yes.

19 Q. The family wasn’t on the ranch that day, was

20 it?

21 A. The gate log shows they were on property.

22 Q. They’re not listed by “Tyson” on the log,

23 are they?

24 A. No, they’re carried over from the previous

25 day. The gate entry log was at 1700 hours. They

26 left property at 1917.

27 Q. And the first date where Frank Cascio’s name

28 is transferred to “Tyson” is on March 1st; isn’t 9616

1 that correct?

2 A. Continue looking?

3 Q. Go ahead and check it.

4 A. Thank you.

5 That’s correct.

6 Q. Up to that time, it had been “Cascio” all

7 the way?

8 A. Yes.

9 Q. Are you familiar with a person by the name

10 of Vinnie Amen?

11 A. Yes.

12 Q. And he was at the ranch about the same time

13 as Mr. Tyson during February and March, correct?

14 A. Yes.

15 Q. And do you have any idea why Mr. Amen’s name

16 was changed from “Vinnie Amen” to “Vinnie Black” on

17 March 1st?

18 MR. SANGER: Beyond the scope of redirect.

19 MR. SNEDDON: Counsel opened the logs up.

20 THE COURT: Objection sustained.

21 Q. BY MR. SNEDDON: So your testimony is, then,

22 that with regard to security, and you being the

23 chief of security at the ranch, that you took

24 greater precautions with regard to the key to the

25 wine cellar than you did the keys to the cars?

26 MR. SANGER: I’m going to object. That’s

27 argumentative.

28 THE COURT: Sustained. 9617

1 MR. SNEDDON: No further questions.

To be continued:

One Comment leave one →
  1. thanks permalink
    February 11, 2015 7:16 am

    Thank you so much as always..!

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