2 3 (The following proceedings were held in 4 open court in the presence and hearing of the 5 jury:) 6 7 THE COURT: Good afternoon. 8 THE JURY: (In unison) Good afternoon. 9 THE COURT: You may proceed. 10 THE CLERK: Judge, we need to swear the 11 witness. 12 THE COURT: All right. Please raise your 13 right hand and face the clerk. 14 15 WADE J. ROBSON 16 Having been sworn, testified as follows: 17 18 THE WITNESS: I do. 19 THE CLERK: Please be seated. State and 20 spell your name for the record. 21 THE WITNESS: My name is Wade J. Robson, 22 spelled W-a-d-e, initial J., R-o-b-s-o-n. 23 THE CLERK: Thank you. 24 MR. MESEREAU: May I proceed, Your Honor? 25 THE COURT: You may. 26 // 27 // 28 // 9090 1 DIRECT EXAMINATION 2 BY MR. MESEREAU: 3 Q. Good afternoon, Mr. Robson. 4 A. How you doing. 5 Q. How old are you? 6 A. I am 22. 7 Q. And would you please give the -- please just 8 summarize your employment history. 9 A. My employment history. 10 I started dancing when I was two, 11 professionally when I was five. In Australia 12 originally. And moved to America when I was eight. 13 Became a professional dancer. Started teaching 14 dance classes when I was 12. I was in a rap duo 15 when I was 11 and 12. Started choreographing for 16 different artists when I was 14, and now I’m 17 directing film. 18 Q. And where do you live at the moment? 19 A. I live in Tarzana, California. 20 Q. Okay. And you say you’re directing films? 21 A. Yeah. 22 Q. And can you summarize what you’re doing in 23 that regard? 24 A. The main focus right now, I did a short film 25 that I wrote and produced and directed last year, 26 and that’s doing the whole film festival circuit 27 right now. And I have a three-picture deal with 28 Disney as a film director, and we’re developing an 9091 1 original musical. 2 Q. Do you know the fellow seated at counsel 3 table to my right? 4 A. Yes. 5 Q. And who is that? 6 A. That’s Michael Jackson. 7 Q. How do you know him? 8 A. I met him first when I was five years old. 9 I think it was ‘87. And Michael was touring, he was 10 doing the “Bad” tour. And I was imitating him as a 11 dancer at that point. And he was holding these -- 12 it was in connection with Target or something like 13 that, holding these dance, like, contests all around 14 wherever he traveled. So I entered one of the dance 15 contests and ended up winning it, went on to the 16 finals and won that, and then the prize was to meet 17 Michael. 18 So I met him after one of his concerts in 19 Brisbane, Australia. And it was just like in a 20 meet-and-greet sort of room. And we met, and I was 21 in my whole, you know, “Bad” outfit and everything. 22 He was sort of laughing and tripping out on my 23 outfit and asked if I danced. I said, “Yeah.” And 24 he asked me to perform with him in the show the next 25 night. 26 So after -- it was like the end of the 27 concert, I pulled up, performed in the show with 28 him. The next -- the next -- I think within the 9092 1 next couple of days, my mother and I went to visit 2 him at his hotel room, and we stayed for a couple of 3 hours. It was in Brisbane, Australia. Just talking 4 about what I want to do. And then that was kind of 5 it at first. 6 And then for the next two years, we didn’t 7 have any contact at all. And I continued pursuing 8 my dance career in Australia. And then the company 9 that I was with, the dance company, was traveling to 10 America to do a performance at Disneyland. 11 So we all went. Came out, did that 12 performance. As I said, we’d had no contact with 13 Michael or anything. Somehow my mother got in 14 contact with Michael’s secretary at that time, who 15 was Norma Stokes. 16 MR. ZONEN: Your Honor, I’m going to object 17 to the narrative form of the answer. 18 THE COURT: Sustained. 19 Q. BY MR. MESEREAU: After your mother got in 20 contact with Norma Stakos, what happened next? 21 A. She talked to Michael about -- we wanted to 22 see if we could hook up with him again and meet him 23 again. She talked to Michael. Michael remembered 24 me from when I met him when I was five years old, 25 wanted to meet me again. 26 So I was out there with my mother, sister, 27 my father, and grandparents. We all went to meet 28 him at Record One Recording Studios. And this 9093 1 was -- this was ‘89. 2 Q. Where is Record One Recording Studios? 3 A. I don’t remember exactly. It’s somewhere in 4 the valley, yeah. In California. Yeah. 5 Q. And what happened next? 6 A. We met up with him. He was in between, you 7 know, working on music and that sort of thing. He 8 was doing a photo shoot at the time at the studio. 9 We took some photos with him. My family and I all 10 went into his -- sort of like the green room, and 11 played him some videotapes of all the dancing stuff 12 that I’ve been doing over the last two years. And, 13 you know, he was just really excited, checking out 14 everything I had done. And then by the end of the 15 time, he invited my family and I up to the ranch 16 that weekend. 17 Q. And did you begin a friendship with Mr. 18 Jackson? 19 A. Yes. 20 Q. Did you spend much time at Neverland? 21 A. Yeah. Spent a lot of time, yeah. 22 Q. When do you think you first went to 23 Neverland? 24 A. It was right after that visit. I’m pretty 25 sure it was that night that we went, my whole family 26 went to the ranch. And, you know, we stayed for, I 27 don’t know, about a week or something like that. 28 Q. And approximately what year do you think you 9094 1 first went to Neverland, Mr. Robson? 2 A. That was 1989. 3 Q. Okay. And who did you go to Neverland with 4 the first time? 5 A. Went with my mother, my sister, my father, 6 and my grandfather, grandmother. 7 Q. And how long did you stay during that first 8 visit? 9 A. I think it was about a week. 10 Q. And after you spent a week at Neverland, 11 what did you do? 12 A. Went back to Australia. 13 Q. Okay. Did you see Mr. Jackson again? 14 A. Yeah. We would -- I don’t remember exact 15 dates, but over the next two years, my mother and I 16 would come out, I don’t know, maybe twice a year, 17 something like that, and spend a couple of weeks 18 with Michael. 19 Q. Would you spend the night at Neverland? 20 A. Some of it was at Neverland. Sometimes it 21 would be at the -- he had an apartment in I think it 22 was Westwood at that point that we would stay at 23 sometimes, too. 24 Q. That’s your mother and you would stay at the 25 apartment in Westwood? 26 A. Yeah. That first time, I think a couple 27 times, sometimes I would stay by myself. Always -- 28 I think -- sometimes -- most of the time my mother 9095 1 and I went to the ranch together. I think once I 2 was there by myself without my mother. There was 3 other people there. 4 Q. And did you stay in contact Mr. Jackson 5 through those years? 6 A. Yes. 7 Q. And how would you communicate with Mr. 8 Jackson? 9 A. When we weren’t there, you know, we’d talk 10 on the phone or we’d send faxes back and forth. 11 Q. At some point did you move to the United 12 States permanently? 13 A. Yeah. We moved in September of 1991. My 14 mother and sister and I. 15 Q. Have you lived here ever since? 16 A. Yes. 17 Q. Have you lived in Los Angeles ever since? 18 A. Yes. 19 Q. Now, your mother’s name is? 20 A. Joy Robson. 21 Q. And how about your sister? 22 A. Chantel Robson. 23 Q. Okay. How many times do you think you’ve 24 stayed at Neverland? 25 A. Um, it’s got to be somewhere in the twenties 26 or something like that. Mid-twenties. 27 Q. And have you stayed there for varying 28 periods of time? 9096 1 A. Yeah. Most of the time it’s usually like a 2 weekend, you know. Friday, Saturday, Sunday. 3 Q. What’s the longest amount of time, do you 4 think, you’ve ever stayed at Neverland? 5 A. You know, I would say a week to a week and a 6 half. 7 Q. Do you consider Michael Jackson your friend? 8 A. Yes. 9 Q. Do you consider him a close friend? 10 A. Yes. 11 Q. You’re aware of the allegations in this 12 case, are you not? 13 A. Yes. 14 Q. And are you aware, as you sit here today, 15 that there’s been allegations that Mr. Jackson 16 molested you? 17 A. Yes. 18 Q. Mr. Robson, did Michael Jackson ever molest 19 you at any time? 20 A. Absolutely not. 21 Q. Mr. Robson, did Michael Jackson ever touch 22 you in a sexual way? 23 A. Never, no. 24 Q. Mr. Robson, has Mr. Jackson ever 25 inappropriately touched any part of your body at any 26 time? 27 A. No. 28 Q. When you first visited Neverland -- and I 9097 1 think you said it was about a week you and your mom 2 stayed there? 3 A. Yeah. 4 Q. Where did you stay? 5 A. I stayed in Michael’s room. 6 Q. And could you please describe the room for 7 the jury? 8 A. When you walk in, there’s -- there’s a bed, 9 sort of like the main bed, diagonally to your left. 10 Wood floors. There’s a second floor that you go 11 around to the right and up, which also has another 12 bed. There’s a bathroom to the left. There’s 13 bathrooms on both sides of the main bed on the first 14 floor. 15 Q. And you stayed in Mr. Jackson’s room? 16 A. Yes. 17 Q. The first time you were there? 18 A. Yes. 19 Q. To your knowledge, has your mother ever 20 stayed in Mr. Jackson’s room? 21 A. In the room? No. 22 Q. How about your sister? 23 A. Yes. 24 Q. And when do you recall your sister staying 25 in the room? 26 A. On that first trip, the first time we went 27 to Neverland. 28 Q. Okay. What do you recall doing at Neverland 9098 1 during that first visit when you spent approximately 2 a week? 3 A. Well, at that point he didn’t have many of 4 the rides. We would watch movies in the theater. 5 You know, we’d play video games. We’d drive around 6 on the golf carts, look at the animals. Those sort 7 of things. 8 Q. Has Mr. Jackson ever helped you with your 9 career? 10 A. Yes. 11 Q. What has he done? 12 A. When I first moved out here, when I was 13 nine, he put me in a couple of his music videos. I 14 was in the “Jam” music video, “Black or White” music 15 video, and “Heal the World.” And that sort of 16 helped me get a dance agent, dance agency, and -- 17 and, yeah. 18 And then the next thing, when I said I was 19 in a rap duo when I was 11 and 12, that was on 20 Michael Jackson’s label under Sony. 21 Q. Do you recall the second time you ever 22 visited Neverland? 23 A. No, I don’t. 24 Q. Do you recall staying in Mr. Jackson’s room 25 on other occasions? 26 A. Yes. 27 Q. And typically when you’d stay in Mr. 28 Jackson’s room, what would you do? 9099 1 A. What would we do as far as just -- 2 Q. Sure. Anything. 3 A. Yeah. We’d watch -- same thing. We’d watch 4 movies, we’d play video games, you know, we’d have a 5 pillow fight every now and then. We’d talk. Hang 6 out. 7 Q. How many times do you think you’ve stayed in 8 Mr. Jackson’s room at Neverland? 9 A. Same amount of times as I’ve been there. 10 Well, no, that’s not true, I’m sorry. I’ve been 11 there a bunch of times without Michael, just with 12 other friends and family traveling there. But, I 13 don’t know, maybe 15 to 20. 14 Q. And at no time has any sexual contact ever 15 occurred between you and Mr. Jackson, right? 16 A. Never. 17 Q. Have you ever taken a shower with Mr. 18 Jackson? 19 A. No. 20 Q. Have you ever gone swimming with Mr. 21 Jackson? 22 A. Yes. 23 Q. And please explain what you mean. 24 A. One time with my sister and I, my sister and 25 I and Michael, we went in the Jacuzzi at Neverland 26 Ranch. 27 Q. And do you know approximately when that was? 28 A. I don’t. I can’t say for sure. I have a 9100 1 feeling that it was within that first trip in ‘89 2 when I went there. 3 Q. Do you recall what Mr. Jackson was wearing 4 in the Jacuzzi? 5 A. From my recollection, he was wearing shorts. 6 You know, like swimming shorts. And that was it. 7 Q. Did anything inappropriate ever happen in 8 that Jacuzzi? 9 A. No. 10 Q. Has anything inappropriate ever happened in 11 any shower with you and Mr. Jackson? 12 A. No. Never been in a shower with him. 13 Q. Did you get to know any of the employees at 14 Neverland when you were there? 15 A. I wouldn’t say “get to know.” You know, I 16 knew of them and we’d know each other’s names, but 17 it never went beyond that. 18 Q. Do you recall someone named Blanca Francia? 19 A. Yes, I remember her name. And I remember 20 her presence. I can’t place her. I can’t remember 21 what she looks like or anything like that. 22 Q. Do you know whether or not Blanca Francia 23 ever was in a room when you were with Mr. Jackson? 24 A. Not that I can remember. 25 Q. Okay. Did you ever meet anyone named Ralph 26 Chacon? 27 A. No. 28 Q. How about Kassim Abdool? 9101 1 A. No. 2 Q. Do you recall anyone named Adrian McManus? 3 A. No. 4 Q. Did you have much interaction with the 5 security people when you were visiting and staying 6 at Neverland? 7 A. No. The only interaction would be is, I 8 don’t know, if -- if they were trying -- if we were 9 out, you know, watching a movie or something like 10 that, they’d come tell us that dinner was ready or 11 something like that. 12 In later years, when I would go there and 13 just visit with my family and that sort of thing, 14 sometimes we’d have water fights and get the 15 security involved. But other than that, no. 16 Q. Did you come across anyone named Mrs. 17 Chandler when you were at Neverland? 18 A. Yes. 19 Q. And when do you think this was? 20 A. I think I was about 13. But I can’t 21 pinpoint any more -- anything more definitive than 22 that. Around that time. 23 Q. Do you recall ever seeing someone at 24 Neverland talking to Mrs. Chandler? 25 A. Sorry? Can you repeat that? 26 Q. Did you ever see Mrs. Chandler talking to 27 anyone at Neverland? 28 A. Yeah, I mean, maybe chefs or -- you know, or 9102 1 maids or something like that. 2 Q. What do you recall Mrs. Chandler doing at 3 Neverland? 4 A. I think I mainly saw her if we’d sit down to 5 eat dinner or something like that. That’s the only 6 time I saw her. 7 Q. Did you ever see her ordering people around 8 at Neverland? 9 A. Yeah, well -- 10 MR. ZONEN: I’m going to object as leading. 11 THE COURT: Sustained. 12 Q. BY MR. MESEREAU: When you saw Mrs. Chandler 13 talking to these people at Neverland, what do you 14 recall her doing? 15 MR. ZONEN: I’ll object as irrelevant and 16 vague. 17 MR. MESEREAU: There’s been testimony by 18 her, Your Honor, about what she saw. 19 THE COURT: I’ll allow the question. 20 You may answer. Do you want it read back? 21 THE WITNESS: Yes, please. 22 (Record read.) 23 THE WITNESS: I remember her, you know, 24 ordering food, that sort of thing, from maids or 25 chefs, or whatever. 26 And, you know, the thing I sort of noticed 27 was she was always sort of -- you know, she would 28 sort of act like the place was hers, you know. Sort 9103 1 of order people around a bit. 2 And, you know, I guess I noticed it because 3 my mother, when we went there, she always made it 4 really clear that this was Michael Jackson’s house. 5 This was somebody’s house and -- 6 MR. ZONEN: I’m going to object as 7 nonresponsive to the question and narrative. 8 THE COURT: All right. The last sentence is 9 stricken. 10 Q. BY MR. MESEREAU: Mr. Robson, has anyone 11 told you what to say in this courtroom today? 12 A. No. 13 Q. Is everything you’ve said the complete and 14 honest truth? 15 A. Yes. 16 Q. Did Mr. Jackson ever do anything wrong with 17 you? 18 A. No. 19 MR. MESEREAU: No further questions. 20 THE COURT: Cross-examine? 21 22 CROSS-EXAMINATION 23 BY MR. ZONEN: 24 Q. Mr. Robson, good afternoon. 25 A. Good afternoon. 26 Q. Have you been living in the United States 27 continuously since you were eight years old? 28 A. Yes. 9104 1 Q. Was Mr. Jackson instrumental in your being 2 able to move to the United States to pursue your 3 career? 4 A. Yes. 5 Q. Are you grateful for Mr. Jackson’s help and 6 assistance in the development of your career? 7 A. Yes. 8 Q. Did you go to high school or college at all? 9 A. No. 10 Q. Not either one? 11 A. I didn’t go to a public high school. I did 12 home studies. 13 Q. You did home studies all through high 14 school? 15 A. Yeah. 16 Q. And no college at all? 17 A. No. 18 Q. So you began your dance career early on and 19 continued through to today; is that correct? 20 A. Yes. 21 Q. All right. Now, the first time that you 22 slept with Mr. Jackson you were seven years old; is 23 that correct? 24 A. I slept in the same bed with him. But, yes, 25 I was seven. 26 Q. Did you understand my question to mean 27 something other than that? 28 A. Sounded like it. 9105 1 Q. All right. But you slept in the same bed 2 with him when you were seven years old; is that 3 correct? 4 A. Yes. 5 Q. Was anybody else in that bed with you? 6 A. My sister, Chantel Robson. 7 Q. She was ten years old; is that right? 8 A. Yes. 9 Q. Is it true that there was not another adult 10 anywhere in that room at the time you crawled into 11 bed with Mr. Jackson? 12 A. True. 13 Q. And in fact, you continued to sleep with Mr. 14 Jackson through the balance of that week during your 15 seventh year; is that right? 16 A. Yes. 17 Q. Was your sister there the entire time during 18 that week as well? 19 A. Yes. 20 Q. Was she in that bed with you as well? 21 A. Yes. 22 Q. Did she continue to share a bed with you and 23 Mr. Jackson thereafter, or did you sleep only with 24 Mr. Jackson thereafter? 25 A. What do you mean by “thereafter”? 26 Q. Well, on all the occasions that you returned 27 to visit Mr. Jackson’s ranch, did you stay in his 28 room, by yourself, with him? 9106 1 A. Yes. But my sister wasn’t in -- wasn’t with 2 us at all in America. 3 Q. All right. So when you moved here -- and 4 incidentally, your father was there during that 5 first week when you were seven years old; is that 6 right? 7 A. Yes. 8 Q. But your father did not return to visit 9 thereafter? 10 A. No. 11 Q. All right. So you stayed in the United 12 States. Your father stayed in Australia. 13 A. Yes. 14 Q. Did your mother stay in the United States? 15 A. Yes. 16 Q. For the balance of the next number of years, 17 your father was simply not in the picture while you 18 were in the United States; is that right? 19 A. He wasn’t there with us, no. 20 Q. And Mr. Jackson understood that as well, did 21 he not, that your father was not in the picture 22 while you were at Neverland? 23 A. Well, he understood that he wasn’t there, 24 yes. 25 Q. Okay. And did you have any contact with 26 your father at all? 27 A. Yes. We talked on the phone. 28 Q. By telephone? 9107 1 A. Yeah. 2 Q. Did you visit him? 3 A. I’m sorry, are we talking about once I moved 4 to America? 5 Q. Yes. 6 A. Oh, yes, we would go back at least every two 7 years for Christmas. 8 Q. Did he ever come to the United States to 9 visit you? 10 A. Yes. 11 Q. Did he have any other visits with you at 12 Neverland? 13 A. No. 14 Q. Did you talk with your mother, prior to that 15 first week that you slept with Mr. Jackson with your 16 sister, about the sleeping arrangements at all? 17 A. Well, yeah, the first day that we got there, 18 to Neverland Ranch -- you know, I think we got there 19 in about the afternoon. We hung out a bit. 20 When it was time to go bed, I asked Michael 21 if I could stay with him in his room. And then 22 Michael and I went to -- mom was staying in a guest 23 room. We went to her room and I asked her. Michael 24 asked her if that was okay. And she said yes. 25 Q. All right. Now, you asked Michael Jackson 26 if you could share his room with him. Now, what 27 caused you to do that? You were seven years old. 28 What caused you to ask him if you could stay with 9108 1 him in his room? 2 A. Well, it’s the same way with any child. 3 When you -- you know, when you have a best friend or 4 a new friend that you found, you always want to stay 5 in the same room with them. 6 Q. He was in his mid 30s; is that right? 7 A. Yes, I guess so. 8 Q. Had you ever crawled into bed with a 9 30-year-old man prior to that day? 10 A. My father. 11 Q. Okay. 12 A. But other than that, no. 13 Q. Any person who you had just met? 14 A. No. 15 Q. All right. And in fact, throughout your 16 entire adolescent years, you had never slept with 17 any other man other than Michael Jackson and your 18 father; is that correct? 19 A. Never slept in a bed with any other man, no. 20 Q. Now, you had a conversation with your mother 21 about where you would sleep that night, that first 22 time. Again, you’re seven years old; is that right? 23 A. Yeah. 24 Q. Did your mother talk to you about perhaps 25 you should stay with her in the guest cottage? 26 A. No. 27 Q. Was she the one who suggested that your 28 sister should go with you and stay in that room with 9109 1 Mr. Jackson? 2 A. I don’t remember that. I remember Chantel, 3 my sister, wanted to as well. 4 Q. Had your mother actually seen the room 5 that -- or the rooms that constitute Mr. Jackson’s 6 bedroom suite? 7 A. Yeah. When we first got to the ranch, he 8 took us around, a tour around everywhere, in his 9 room. 10 Q. So she understood at the time that the 11 bedroom suite was composed of a number of different 12 rooms with actually beds in at least two of them; is 13 that right? 14 A. Yes. 15 Q. And there were bathrooms on both levels; is 16 that right? 17 A. I don’t think there’s a bathroom on the 18 second level. There’s two on the first level. 19 Q. Was your mother under the impression that 20 you would be sleeping in a different location from 21 Michael Jackson when you first went to his room at 22 age seven? 23 A. Not that I know of. 24 Q. All right. Had you talked with her the next 25 day about where you actually slept that prior night? 26 A. No, not that I remember. 27 Q. At any time during that first week when you 28 were there at age seven, did you ever tell your 9110 1 mother that you actually shared the bed with Michael 2 Jackson? 3 A. I’m sure. 4 Q. You think you did? 5 A. Yeah. 6 Q. Do you remember your mother’s response to 7 hearing that? 8 A. No. 9 Q. Did your sister, in your presence, tell your 10 mother that she was also sleeping in the same bed 11 with Michael Jackson at age ten? 12 A. I can’t say for sure. I don’t remember, 13 but -- 14 Q. At any time during that first week that you 15 were there, did you have any conversation with your 16 mother wherein your mother expressed concern about 17 where you were sleeping? 18 A. No. 19 Q. Were you seeing your mother during the day? 20 A. Yes. 21 Q. All right. After that first week, did you 22 go back to Australia? 23 A. Yeah. 24 Q. You were in Australia for what, about a 25 year? 26 A. I think so. I don’t remember. 27 Q. And then you returned to the United States 28 for good at that point? 9111 1 A. Well, we had a couple of visits back to 2 America before we returned in ‘91 for good. 3 Q. With what rate of frequency did you continue 4 to visit with Michael Jackson after returning at age 5 eight? 6 A. I would say twice a year. 7 Q. All right. And during those periods of 8 time, you would stay for up to a week at a time, no? 9 A. Yeah. 10 Q. Were there times that you actually stayed at 11 Neverland for many weeks at a time? 12 A. Not that I can remember. Like I said, a 13 week to a week and a half. Maybe it was two weeks, 14 but I don’t remember any more than that. 15 Q. Were there periods of time when you were at 16 Neverland and working with Mr. Jackson on dance 17 routines? 18 A. No. I mean, we would mess around and dance 19 a little bit in the studio every now and then, yes. 20 Q. Was there ever an occasion where you were on 21 the dance floor with Mr. Jackson and he was showing 22 you a routine and he grabbed your crotch in a manner 23 similar to how he would grab his own crotch while 24 doing those performances? 25 A. No, that’s not true. 26 Q. You have no recollection of that? 27 A. No. 28 Q. That didn’t happen? 9112 1 A. No. 2 Q. During the period of time from age eight on, 3 did you stay in Mr. Jackson’s room virtually the 4 entire time? 5 A. I’m sorry? 6 Q. The times that you would come and visit Mr. 7 Jackson from age eight on -- 8 A. Uh-huh. 9 Q. -- did you stay in Mr. Jackson’s room? 10 A. Yes. 11 Q. All right. By age 11, you were asked to 12 give a deposition, were you not? 13 A. Yes. 14 Q. And you actually did give testimony under 15 oath in the presence of two prosecutors from Los 16 Angeles; is that right? 17 A. Yes. 18 Q. There was also an attorney present who 19 represented you; is that correct? 20 A. Yes. 21 Q. All right. After that deposition, did you 22 continue to sleep in Mr. Jackson’s room? 23 A. Yes. 24 Q. Did you continue to sleep in Mr. Jackson’s 25 bed? 26 A. Yes. 27 Q. All right. Now, during that period of time 28 from age eight until age 11, did you frequently 9113 1 visit Mr. Jackson? 2 A. From -- I’m sorry, from eight to 11? 3 Q. Age eight to age 11, did you frequently 4 visit Mr. Jackson? 5 A. Yeah. Same amount of time. Maybe twice a 6 year, or every couple of months, something like 7 that. 8 Q. Is it safe to say that during each of those 9 visits, you stayed in Mr. Jackson’s room? 10 A. Yes. 11 Q. All right. Were there ever occasions where 12 you went to visit Mr. Jackson when your mother 13 wasn’t there? 14 A. Yes. I think a couple of times he had an 15 apartment in Century City that my mother would drop 16 me off and I’d stay for, you know, a night or so by 17 myself with Michael there. 18 Q. Was that a place called “The Hideout”? 19 A. I remember a place called “The Hideout.” 20 I don’t remember if it was that place. 21 Q. Were there more places where you visited and 22 stayed overnight in Century City? 23 A. Yeah, there was a hotel that was -- I mean, 24 I’m sorry, an apartment that was in Westwood and 25 then one that was in Century City. 26 Q. Was there a place where Mr. Jackson was 27 living in, either Westwood or Century City, where 28 there was a hotel across the street? 9114 1 A. Yes. 2 Q. And would it be the case that periodically 3 you would visit him there, your mother would stay in 4 the hotel, but you would stay with him in his room? 5 A. One time when we came over, we stayed -- I 6 think it was the Westwood apartment, his Westwood 7 apartment. There was a Holiday Inn that was across 8 and we stayed there most of the time. And then 9 certain nights I would go over to Michael and stay 10 with him. 11 Q. Mr. Robson, were there ever occasions where 12 you stayed with Michael Jackson where you didn’t 13 sleep with him in his bed? 14 A. Yes. 15 Q. How often did that happen? 16 A. I don’t know. Maybe three, four times. 17 Q. Three or four times over years we’re talking 18 about; is that right? 19 A. Yes. 20 Q. So, for the most part, the overwhelming 21 majority of times you shared his bed with him? 22 A. Yes. 23 Q. Now, at any time did you start to develop 24 conversations with your mother about the propriety 25 of sleeping with this man who’s now well into his 26 30s? 27 A. No. 28 Q. Did you consider it unusual at all? 9115 1 A. No. 2 Q. Did your mother consider it unusual? 3 A. No. 4 Q. Did you ever talk to your father about it? 5 A. Yeah. 6 Q. You talked to your father about your 7 sleeping with Michael Jackson? 8 A. No, I mean, you know, everybody knew, and 9 nobody ever said that it was -- we never talked 10 about it being unusual or anything like that. 11 Q. Did your mother ever ask you if anything 12 inappropriate happened in bed with him? 13 A. No. 14 Q. Did she simply assume nothing happened? 15 A. Yes. 16 Q. You’re telling us nothing happened; is that 17 right? 18 A. Yes. 19 Q. All right. What you’re really telling us is 20 nothing happened while you were awake; isn’t that 21 true? 22 A. I’m telling you that nothing ever happened. 23 Q. Mr. Robson, when you were asleep, you 24 wouldn’t have known what had happened, particularly 25 at age seven, would you have? 26 A. I would think something like that would wake 27 me up. 28 Q. On those occasions that you were at 9116 1 Neverland, you used to play very actively, did you 2 not? 3 A. Yes. 4 Q. All right. There was a lot to do at 5 Neverland; is that right? 6 A. Yes. 7 Q. And on some days you were actually working 8 out heavily with the defendant, engaged in dance 9 routines, weren’t you? 10 A. Yeah. 11 Q. And on other occasions you would be playing 12 very actively. There’s just a host of things that a 13 seven-year-old can do and have fun with; is that 14 right? 15 A. Yes. 16 Q. And you can play -- all manner of video 17 games that exist anywhere in the world can be found 18 at Neverland; is that right? 19 A. Yeah. 20 Q. And there’s video games, there’s movies, 21 there’s a zoo, there’s all kinds of parks, and the 22 trains. You’re very active during the entire day; 23 is that right? 24 A. Yes. 25 Q. And at night you’d go back to his room and 26 you’d play more video games or you’d watch 27 television; is that right? 28 A. Yes. 9117 1 Q. And there’s movies of any kind that you can 2 see with Mr. Jackson? 3 A. Yes. 4 Q. Did your mother ever complain to you that 5 you were losing contact with her and that she was 6 losing her contact with you? Did she ever say that? 7 A. No. 8 Q. In fact, she was very upset over the fact 9 that she was losing her ability to have access to 10 her son, wasn’t she? 11 A. No. 12 Q. Was there, in fact, a shower at Neverland in 13 the suite, the bedroom suite? 14 A. Yes. 15 Q. But you didn’t use it? 16 A. I used it by myself. 17 Q. Was he in the room while you were using it? 18 A. In the bedroom, not in the shower room, 19 which had its own door. 20 Q. You were seven years old when you started 21 using that shower; is that correct? 22 A. Yes. 23 Q. When did you stop sleeping with Mr. Jackson? 24 A. I guess when I was about, I don’t know, 25 maybe 13, 14, something like that. 26 Q. Why did you stop? 27 A. I didn’t stop sleeping with him. I just 28 haven’t spent the night with him, I mean, in his 9118 1 room or anything like that since then, I don’t 2 think. 3 Q. You haven’t gone back to Neverland since you 4 were 13? 5 A. I have. Not with him. 6 Q. Have you gone back to Neverland since you 7 were 13 and actually stayed overnight? 8 A. Yes. 9 Q. On how many occasions since you were 13? 10 A. A lot. Same thing. 20, 25. Something like 11 that. 12 Q. Did he take you to other locations such as 13 Las Vegas? 14 A. Yes. 15 Q. And while you were at Las Vegas, you went to 16 see Siegfried & Roy? 17 A. Yes. 18 Q. And being with Mr. Jackson back then was a 19 very exciting experience, wasn’t it? 20 A. Yes. 21 Q. He was able to go anywhere he wanted in Las 22 Vegas and take you with him? 23 A. Yeah. 24 Q. Did you start to dress like him? 25 A. I always did before I met him. 26 Q. All right. And during the time that you 27 were with him, he enjoyed you wearing clothing 28 similar to what he wore; is that correct? 9119 1 MR. MESEREAU: Objection; calls for 2 speculation. 3 THE COURT: Sustained. 4 Q. BY MR. ZONEN: Did he ever tell you that he 5 wanted you to dress like him? 6 A. No. 7 Q. Did he ever give you hats similar to the 8 type of hats that he wears? 9 A. Because I would ask for them. 10 Q. And did you, in fact, wear those types of 11 hats when you were out with him? 12 A. Yes. 13 Q. And when you were in Las Vegas, did you wear 14 those hats as you wandered around Las Vegas with 15 him? 16 A. Yes. 17 Q. When you were in Las Vegas, where did you 18 stay? 19 A. We stayed at The Mirage Hotel. 20 Q. Who went to Las Vegas with you? 21 A. My mother. 22 Q. Just your mother? 23 A. Yeah. 24 Q. Was your sister with you at all? 25 A. No. 26 Q. Did your sister move to the United States 27 with you? 28 A. Yes. 9120 1 Q. But she didn’t go to Las Vegas with you? 2 A. Well, we weren’t -- we didn’t live in the 3 United States at that point. We still lived in 4 Australia. We were out on a visit. 5 Q. When you were in the hotel in Las Vegas, it 6 is true that you stayed with Mr. Jackson in his bed? 7 A. Yes. 8 Q. And your mother stayed in a separate room; 9 is that right? 10 A. Yes. 11 Q. Now, were there other boys that you knew 12 about who were sleeping with Michael Jackson during 13 that time? 14 A. No, not that I knew of. I mean, the only 15 other time I was around other boys, other kids at 16 the ranch, I think once or twice, and, you know, 17 we’d all stay in the room and we’d kind of fall 18 asleep on couches, beds, cots, wherever they were. 19 Q. Did you know Jordie Chandler? 20 A. Yeah. 21 Q. You just described -- you just told the jury 22 that -- that you knew Jordie Chandler’s mother; is 23 that right? 24 A. Yes. 25 Q. What’s her name? 26 A. I know her -- June. June Chandler. 27 Q. All right. Describe her for us. What does 28 she look like? 9121 1 A. She has dark, almost black hair. Sort of -- 2 sort of brown eyes. I think some -- kind of like 3 a -- a little bit of a darker complexion. 4 Q. Slim woman? Heavy woman? 5 A. Slim woman. 6 Q. Now, do you remember her son Jordie? 7 A. Yes. 8 Q. On how many occasions did you meet Jordie? 9 A. Once. 10 Q. Only one time? 11 A. That’s all I can remember, yes. 12 Q. And did you spend the night with Jordie? 13 A. Yeah, we all stayed in Michael’s room. 14 Q. You say “we all stayed.” Were there other 15 people there besides Jordie? 16 A. Yeah, Macaulay Culkin was there and his 17 brother Kieran Culkin. 18 Q. Now, Macaulay Culkin has sisters, does he 19 not? 20 A. I don’t know. 21 Q. Were there any girls that were staying with 22 you that night? 23 A. Not that I remember. 24 Q. Were there ever any girls, other than your 25 sister, at age seven, who actually spent the night 26 in Mr. Jackson’s room with you during the years that 27 you knew him and spent the night in his room? 28 A. Yes. 9122 1 Q. Who? 2 A. There was Brandy Jackson. 3 Q. I’m sorry? 4 A. Brandy Jackson, who is Michael’s niece. 5 Q. And she spent the night on how many 6 occasions with you? 7 A. Only one that I can remember. 8 Q. One night? 9 A. Yeah. 10 Q. All right. So we’re talking about a period 11 of about five years; is that right? 12 A. Yeah. 13 Q. In the five years, you can remember Brandy. 14 Who else do you recall? 15 A. As far as females? 16 Q. Yes. 17 A. My sister. Brandy. That’s all I remember. 18 Q. Now, your sister actually never went back 19 into that room and spent the night with you after 20 that first week when you were seven; is that 21 correct? 22 A. Yeah, not that I can remember. 23 Q. Is it an accurate statement to say that the 24 boys who stayed there for long periods of time 25 started getting pretty rowdy? 26 A. Rowdy? 27 Q. Yeah. 28 A. What do you mean? 9123 1 Q. Well, goof off, and simply kids who weren’t 2 under a lot of supervision? 3 A. Oh, yeah. I mean, you know, boys will be 4 boys. We’d go around and have fun. 5 Q. Loud and boisterous? 6 A. Yes. 7 Q. And on occasions break things? 8 A. Accidentally, yeah. 9 Q. And be somewhat disobedient? 10 A. Some of them maybe. 11 Q. Were there ever occasions where you and Mr. 12 Jackson were throwing stones at the lion in the zoo? 13 A. Stones at the lion. Yeah, I think so. 14 Q. That did happen, didn’t it? 15 A. Yeah. 16 Q. Mr. Jackson was throwing stones at the lion 17 in your presence; is that right? 18 A. Yes. 19 Q. Was he encouraging you to do the same thing? 20 A. Yeah. Little pebbles, but, yeah. 21 Q. They weren’t exactly pebbles. They were 22 good-sized stones, weren’t they? 23 A. No, I remember small stones. 24 Q. It was designed to irritate the lion, wasn’t 25 it? 26 A. Yeah, we were trying get him to make some 27 noise. 28 Q. Because it was entertaining to Mr. Jackson 9124 1 and to you? 2 A. Yeah. 3 Q. How old were you at the time? 4 A. I think I would have been seven or eight. 5 Q. Were there any other kids around at that 6 time? 7 A. No. Maybe my sister. 8 Q. Now, you said that you spent one night that 9 you can recall with Jordie Chandler. Do you know 10 Brett Barnes? 11 A. Yes. 12 Q. Did you ever spend a night with Brett 13 Barnes? 14 A. No. 15 Q. Did you ever meet Brett Barnes? 16 A. Yes. 17 Q. How old were you when you met Brett Barnes? 18 A. I think I would have been nine. It was soon 19 after we moved to America. 20 Q. On that occasion when you spent the night 21 with Jordie Chandler, Macaulay, and his brother, was 22 Brett Barnes there as well? 23 A. No. 24 Q. Do you know if Brett Barnes spent nights 25 with Michael Jackson? 26 A. I don’t know. 27 Q. Do you know if they ever shared a bed? 28 A. I don’t know. 9125 1 Q. Did Michael Jackson ever talk to you about 2 the propriety of sleeping with him? 3 A. Could you rephrase that? 4 Q. Did Michael Jackson ever have a conversation 5 with you wherein the subject of the conversation was 6 that it was okay for you to sleep with a 7 30-something-year-old man? 8 A. Yeah. 9 Q. He did? 10 A. We would both talk about it. 11 Q. Really. From what age? When did that first 12 conversation happen? 13 A. I don’t remember. 14 Q. Were you seven? 15 A. I don’t remember. 16 Q. Was it the first week that you were there? 17 A. No. 18 Q. Do you think it was soon after you moved to 19 the United States? 20 A. I really don’t remember. 21 Q. What was the nature of that conversation? 22 A. I don’t remember an exact conversation. I’m 23 sure it’s just something, you know, we talked about 24 at some point; that -- you know, that it’s fine. 25 Q. Did Mr. Jackson ever tell you that you were 26 family to him? 27 A. Yes. 28 Q. Did he tell you that often? 9126 1 A. Yes. 2 Q. Did he tell you that he would take care of 3 you? 4 A. No. 5 Q. Did he tell you he would protect you? 6 A. Yes. 7 Q. All right. Did he ever tell your mother in 8 your presence that you were family? 9 A. Yes. 10 Q. And that your mother could trust him? 11 A. Yes. 12 Q. In fact, the word “trust” came up in many 13 conversations with Michael Jackson, did it not? 14 A. Yeah, we’d talk about trust in, you know, 15 other people, and that sort of thing. 16 Q. But he encouraged you particularly to trust 17 in him, did he not? 18 A. No, there was no particular emphasis on it. 19 Q. How much time did you spend with Macaulay 20 Culkin? 21 A. Um, there was that -- the trip that we spoke 22 of, that I think was a couple of days. I think I 23 was with him one other time at the Century City 24 apartment, which was a night. I think that was 25 about it. 26 Q. Now, the trip you described, that trip was 27 where now? 28 A. Which trip? 9127 1 Q. Maybe I misheard you. Did you say “the trip 2 I just spoke of”? 3 A. Oh, the one I spoke of. That was the one 4 where I said where Jordie Chandler was there at 5 Neverland. 6 Q. That was Neverland? 7 A. Yeah. 8 Q. He was there and you were there for what 9 period of time together? Just one night? 10 A. No, it was a couple days. 11 Q. Did it go over more than one night? 12 A. Yes. 13 Q. On both of those nights, did both of you 14 spend that time in Mr. Jackson’s room? 15 A. Yes. 16 Q. Now, did either one of you actually spend 17 the night in Mr. Jackson’s bed with Mr. Jackson? 18 A. No. I think -- from I can remember -- I can 19 only remember one night in particular, and I 20 remember myself and Kieran Culkin, I think, slept on 21 Michael’s bed, and Michael slept on a cot, or 22 something, on the side of us, and I don’t know, 23 Macaulay fell asleep on a couch or something. 24 Q. I’m sorry. 25 A. Go ahead, no. 26 Q. The Century City apartment, I believe you 27 said you spent some time there with Macaulay Culkin 28 as well? 9128 1 A. Yeah. I think it was one night there, yeah. 2 Q. Was his brother there? 3 A. I don’t remember for sure. I don’t remember 4 him being there. 5 Q. Mr. Jackson would periodically kiss you, 6 would he not? 7 A. No. 8 Q. Periodically hug you? 9 A. Yes. 10 Q. Touch you? 11 A. Hug me. That would be -- 12 Q. Put his hands through your hair? 13 A. No. 14 Q. Touch you about the head and the face? 15 A. Yeah. 16 Q. Did he ever kiss you on the cheek? 17 A. Yeah. 18 Q. Did he ever kiss you on the lips? 19 A. No. 20 Q. Do you remember any other children being 21 there about that time? 22 A. Which time? 23 Q. From the time that you were seven until the 24 time you stopped sleeping there at age 13. 25 A. Being at the ranch? 26 Q. Yes. 27 A. Other than we spoke of, no. 28 Q. Did you know Blanca Francia’s son? 9129 1 A. No. I knew of him. But I don’t think I 2 ever met him. 3 Q. What was his name? 4 A. I don’t know. 5 Q. Does “Jason” sound familiar? 6 A. Yes, but I think because I’ve heard it 7 recently. But, yeah. 8 Q. Now, were there ever occasions after you 9 were 14 years old that you came and stayed at 10 Neverland Ranch and Michael Jackson was, in fact, 11 there? 12 A. Yes. 13 Q. And you did not stay with him in his room? 14 A. The only time I can remember was a time I 15 went up there with a few family members and friends, 16 and we didn’t know he was going to be there. And, 17 you know, we sort of ran into him and hung out a 18 bit, and, no, I didn’t sleep in his room. 19 Q. Did you ever talk to Michael Jackson about 20 the fact that at some age it was too late for you to 21 be sleeping with him? 22 A. No. 23 Q. Did you ever have a conversation with him 24 about whether or not you should continue to sleep in 25 his bed? 26 A. No. 27 Q. Remember the last time you slept in his bed? 28 A. The last -- I think it might have been when 9130 1 I was about 14. It was at a Sheraton Hotel in Los 2 Angeles. 3 Q. And how did you happen to be there with him? 4 A. I stayed with him for I think it was just 5 one night. 6 Q. Did you call or did he call you? 7 A. I don’t remember. 8 Q. Was your mother there? 9 A. No. 10 Q. Do you remember how you got there? 11 A. No, I don’t. 12 Q. Were there occasions that Mr. Jackson would 13 summon you to Neverland Ranch? 14 A. Summon me? 15 Q. Yes. Call you up and ask you to come and be 16 there; invite you to Neverland Ranch? 17 A. Invite us, yeah. 18 Q. All right. Without your mother? 19 A. Like ask if I could come without my mother, 20 do you mean? 21 Q. Or just ask you to come, and you came by 22 yourself. 23 A. The only time I remember being there -- 24 sorry. The only time I remember being there was 25 that -- that trip that we spoke of by myself with 26 Jordie Chandler and Macaulay. 27 Q. On the occasions that you stayed in bed with 28 Mr. Jackson, would you ever cuddle in bed? 9131 1 A. No. 2 Q. Would you lie next to one another? 3 A. No. 4 Q. Would you touch? 5 A. No. 6 Q. Would you consider it to have been 7 inappropriate to have cuddled in bed? 8 A. Sorry? 9 Q. Would you have considered it to be 10 inappropriate to have cuddled in bed? 11 A. No. 12 MR. ZONEN: I have no further questions. 13 14 REDIRECT EXAMINATION 15 BY MR. MESEREAU: 16 Q. Mr. Robson, the prosecutor for the 17 government asked you about your dressing like 18 Michael Jackson. 19 A. Uh-huh. 20 Q. And I believe you said something about you 21 dressed like him before you met him. 22 A. Yes. 23 Q. Would you please explain that? 24 A. Well, you know, I became a fan of Michael 25 Jackson when I was two years old, when I saw the 26 making of “Thriller,” and started dancing like him 27 when I was, you know, three or four. So I think 28 when I was about five, I started, because I was 9132 1 imitating him. I got costumes made and that sort of 2 thing. So I would dress like him from that point, 3 before I met him. 4 Q. Did Mr. Jackson ever encourage you to dress 5 like him? 6 A. No. 7 Q. Did you dress like him because you were a 8 fan and friend of his? 9 A. Yes. 10 Q. Now, the prosecutor talked about your 11 throwing pebbles at a lion. 12 A. Uh-huh. 13 Q. Would you please explain what you were 14 describing. 15 A. Well, there’s a lion that was in a cage. 16 And, you know, went to see the lion roar, and it’s 17 pretty much just sitting there, you know, not doing 18 anything. So we picked up a couple little stones 19 and threw them at the cage, you know. 20 Q. And the prosecutor used the word “stones,” 21 and you said “pebbles.” How big were these things? 22 A. Little, you know -- I don’t know, 23 quarter-inch sort of things. 24 Q. Were you trying to hurt the lion? 25 A. No. 26 Q. To your knowledge, was Mr. Jackson trying to 27 hurt the lion? 28 A. No. 9133 1 Q. Okay. The prosecutor asked you questions 2 about whether or not you were considered family. 3 Did you consider yourself to be part of Mr. 4 Jackson’s family? 5 A. Yeah, I mean, in a friendship sort of way. 6 Because we were that close. It was like family. 7 Q. And did you use the word “family” once in a 8 while -- 9 A. Yes. 10 Q. -- when you spoke to him? 11 A. Yes. 12 Q. Did you hear your mother or sister using the 13 word “family”? 14 A. Yes. 15 Q. Did you think anything was strange about 16 that? 17 A. No. 18 Q. The prosecutor for the government asked 19 about Mr. Jackson giving you a kiss on the cheek. 20 A. Uh-huh. 21 Q. And you said that happened sometimes? 22 A. Yes. 23 Q. Did you think there was anything 24 inappropriate about that? 25 A. No. 26 Q. Did you do it in front of your mom? 27 A. Yes. 28 Q. Did you do it in front of your sister? 9134 1 A. Yes. 2 Q. Did your mother kiss him on the cheek? 3 A. Yes. 4 Q. Did your sister kiss him on the cheek? 5 A. Yes. 6 Q. Did you kiss Mr. Jackson on the cheek? 7 A. Yes. 8 Q. Did your mother used to hug Mr. Jackson? 9 A. Yes. 10 Q. Did Mr. Jackson used to hug your mother? 11 MR. ZONEN: I’ll object as irrelevant what 12 happened with his mother. 13 THE COURT: Overruled. Go ahead. 14 Q. BY MR. MESEREAU: Did Mr. Jackson used to 15 hug your mother? 16 A. Yes. 17 Q. Did your sister used to hug Mr. Jackson? 18 MR. ZONEN: I’ll object as leading as well. 19 THE COURT: Overruled. 20 Q. BY MR. MESEREAU: Did your sister used to 21 hug Mr. Jackson? 22 A. Yes. 23 Q. And would you see Mr. Jackson hug your 24 sister? 25 A. Yes. 26 Q. Did you ever think there was anything 27 inappropriate about Mr. Jackson hugging any member 28 of your family? 9135 1 A. No. 2 Q. Did you ever think it was inappropriate to 3 see any member of your family hug Mr. Jackson? 4 A. No. 5 Q. Now, you said your sister would sometimes 6 stay in Mr. Jackson’s room, correct? 7 A. Yes. 8 Q. And how often do you recall that happening? 9 A. I remember it just within that first trip we 10 were there. So it was -- it was, you know, three or 11 four nights or something like that. 12 Q. And you mentioned Brandy. Is that who you 13 mentioned? 14 A. Yes. 15 Q. Who was Brandy again? 16 A. She was Michael Jackson’s niece. 17 Q. You saw Brandy staying in his room? 18 A. Yeah. 19 Q. What’s the largest number of kids you ever 20 saw stay in Mr. Jackson’s room, if you remember? 21 A. Yeah, probably four to five. 22 Q. And what do you recall the children doing in 23 his room? 24 A. Well, before we went to sleep, same sort of 25 things. We’d play video games, watch movies. Have 26 pillow fights. You know, yeah. 27 Q. Did you ever see anything of a sexual nature 28 between Mr. Jackson and any of those children? 9136 1 A. Never. 2 Q. Now, the prosecutor mentioned Macaulay 3 Culkin. Did you get to know Macaulay Culkin at 4 Neverland? 5 A. Yeah. I mean, we hung out a little bit, 6 yes. 7 Q. Was that where you first met him? 8 A. I think I might have met him on a -- on a 9 set of a commercial or one of his videos or -- or, 10 no, I think I met him on “Black or White” the first 11 time, the music video. 12 Q. Did you stay in contact with Mr. Culkin? 13 A. No. 14 Q. Is he someone you communicate with on a 15 regular basis? 16 A. No. 17 Q. Okay. Now, would you see Mr. Culkin’s 18 family at Neverland? 19 A. Other than his brother Kieran, I don’t 20 remember. 21 Q. And approximately how old was his brother, 22 do you think? 23 A. At that time, he would have been, I guess, 24 nine or ten, or something like that. 25 Q. Have you seen Mr. Jackson hug other children 26 at Neverland? 27 A. Yes. 28 Q. Have you seen other children hug Mr. Jackson 9137 1 at Neverland? 2 A. Yes. 3 Q. Have you ever thought any of this was 4 inappropriate? 5 A. No. 6 Q. Have you seen Mr. Jackson kiss children at 7 Neverland? 8 A. On the cheek, yes. Or on the head, or on 9 the top of the head, something like that. 10 Q. Ever seen kids kiss Mr. Jackson? 11 A. Yes. 12 Q. Any of that ever look inappropriate to you? 13 A. No. 14 Q. Have you seen lots of children visit 15 Neverland on occasion? 16 A. Yes. 17 Q. And what do you mean? 18 A. I think we were there once when he had one 19 of his gatherings, like a Heal the World Foundation 20 thing where he had a bunch of kids come up there 21 and -- you know, and have the day there. 22 Q. And how many kids are you talking about, do 23 you think? 24 A. Probably about 100 or 50. 75 to 100, 25 something like that. 26 Q. Were there adults with those children? 27 A. Yes. 28 Q. And you said, “Heal the World.” What did 9138 1 that mean to you? 2 MR. ZONEN: I’m going to object as exceeding 3 the scope of the direct examination, and irrelevant, 4 and beyond the scope of his knowledge. 5 THE COURT: Overruled. 6 You may answer. 7 THE WITNESS: Could you repeat the question? 8 Q. BY MR. MESEREAU: Yeah. What was “Heal the 9 World,” as far as you remember? 10 A. As far as I knew, it was a foundation or a 11 charity that Michael had created that, you know, 12 raised money for kids with illnesses. I don’t know 13 exactly what kind, but -- 14 Q. Did you interact with any of these kids that 15 visited that day? 16 A. I may have, yeah, I mean, waved at them or 17 met a couple of them or something like that. 18 Q. Did you see Mr. Jackson hugging other 19 children? 20 A. Yes. 21 Q. Did you see them hugging him? 22 A. Yes. 23 Q. Did you see Mr. Jackson kiss children? 24 A. Yeah. 25 Q. Have you seen them kiss him? 26 A. Yes. 27 Q. Ever seen anything inappropriate? 28 A. No. 9139 1 Q. Did you see Mr. Jackson hug adults who were 2 with those children? 3 A. Yes. 4 Q. Did you see adults hug Mr. Jackson who were 5 with those children? 6 A. Yes. 7 Q. Ever think any of that was inappropriate? 8 A. No. 9 Q. Now, the prosecutor for the government asked 10 you questions about whether he touched your hair. 11 A. Uh-huh. 12 Q. Do you recall Mr. Jackson ever touching your 13 hair? 14 A. I can’t recall an exact thing, but it seems 15 like something he might have done at some point. 16 Q. Do you ever recall Mr. Jackson doing 17 anything inappropriate with your hair? 18 A. No. 19 Q. Ever seen Mr. Jackson touch another child on 20 the head? 21 A. Yes. 22 Q. Have you seen that many times? 23 A. Many times. 24 Q. Did it ever seem like anything inappropriate 25 was going on when you saw that? 26 A. No. 27 Q. The prosecutor asked about disobedience at 28 Neverland, and you said you did see kids act up 9140 1 sometimes? 2 A. Yeah, I mean, act up as far as kids go. I 3 mean, you know, driving golf carts around and 4 throwing water balloons at each other, and things 5 that, I guess, I don’t know, maybe parents would get 6 upset about at some point, but that was the extent 7 of it. 8 Q. And did you engage in some of that, too? 9 A. Yes. 10 Q. Did you ever see Michael Jackson in a water 11 balloon fight with kids? 12 A. Yes. 13 Q. Ever see kids throw water balloons at 14 Michael? 15 A. Yes. 16 Q. Ever see Michael throw water balloons at 17 kids? 18 A. Yes. 19 Q. Did you ever see Michael in golf carts with 20 kids? 21 A. Yes. 22 Q. When you used to play at Neverland during 23 the day, would Michael often be with you? 24 A. Yes. 25 Q. And what would Michael do with you? 26 A. We’d go on rides together, you know, where 27 we’d drive around in the golf cart together, look at 28 animals together, watch movies together. 9141 1 Q. Did you see Mr. Jackson act in a similar way 2 with other children? 3 A. Yes. 4 Q. Ever see anything inappropriate go on when 5 he was doing any of these things? 6 A. No. 7 Q. Now, how often do you recall your mother 8 going to Neverland with you? 9 A. It’s been every time except for that one 10 time that I spoke of when I was there with Jordie 11 Chandler and Macaulay and I. 12 Q. What do you recall seeing your mother do at 13 Neverland? 14 A. A lot of the same things with us. 15 Q. Would she sometimes be with Mr. Jackson when 16 all the kids were playing? 17 A. Oh, yes. She was playing along with us. 18 Q. Now, you mentioned visiting an apartment in 19 Century City with Mr. Jackson, right? 20 A. Yes. 21 Q. And what do you recall doing in the 22 apartment with Mr. Jackson? 23 A. Same sort of things. He had arcade games 24 there. You know, candy. We’d eat, we’d watch, you 25 know, T.V. shows, Stooges. Hang around, play games, 26 you know. 27 Q. Did you ever see Mr. Jackson do anything 28 inappropriate with any child at that apartment? 9142 1 A. No. 2 Q. Where else have you been with Mr. Jackson? 3 A. Like I said, we covered Las Vegas. Westwood 4 apartment, Century City apartment. Sheraton Hotel. 5 He came and stayed at my place once. 6 Q. Where was that? 7 A. That was in Hollywood. It was -- my mother 8 and I had a condo, and my sister. 9 Q. Did you see Mr. Jackson do anything 10 inappropriate at any of these locations? 11 A. No. 12 Q. Ever seen Mr. Jackson touch any child in a 13 sexual way at any of these locations? 14 A. Never. 15 Q. Did Mr. Jackson ever touch you 16 inappropriately in any of these locations? 17 A. No. 18 Q. Now, have you been following media reporting 19 in this case? 20 A. Yeah. On and off. 21 Q. You’re aware of allegations that were made 22 that Mr. Jackson -- 23 MR. ZONEN: I’m going to object as leading 24 and exceeding the scope of the direct -- cross. 25 THE COURT: I don’t know what the question is 26 yet. 27 Q. BY MR. MESEREAU: Okay. You’ve been 28 following these reports that somehow Mr. Jackson was 9143 1 seen inappropriately touching you? 2 A. Yes. 3 Q. What do you think of them? 4 A. I think it’s -- 5 MR. ZONEN: I’ll object. 6 I’ll withdraw the objection. 7 THE WITNESS: I think it’s ridiculous. 8 MR. MESEREAU: No further questions. 9 10 RECROSS-EXAMINATION 11 BY MR. ZONEN: 12 Q. When Mr. Jackson stayed with you at your 13 Hollywood apartment, how old were you? 14 A. I would say 11 or 12. 15 Q. Did he share your bed with you at that time? 16 A. Yes. 17 Q. All right. There was one bed that you had 18 in your room; is that correct? 19 A. No, it was actually -- it was a -- like a 20 futon that was our couch down in the living room. 21 Q. So both of you stayed on the couch in the 22 living room? 23 A. Yes. 24 Q. Was that couch your normal residence? Was 25 that where you normally slept? 26 A. I think that’s where I was sleeping at that 27 point, yeah. 28 Q. You think that’s where you were sleeping? 9144 1 A. Yes. 2 Q. You slept in other rooms at different times? 3 A. Yeah. 4 Q. Now, all those places that you mentioned are 5 all places that you mentioned, a series of places, 6 you had been with Michael Jackson. On all of those 7 occasions you slept in the same bed with him; is 8 that correct? 9 A. Yes. 10 Q. Do you think that’s appropriate, for a 11 35-year-old man to be sleeping with an 12 eight-year-old boy? 13 A. I don’t see any problem with it. 14 Q. Suppose the 35-year-old man has an obsession 15 for sexually explicit material. Would that change 16 your view? 17 MR. MESEREAU: Objection; 352. 18 MR. ZONEN: It’s in evidence. 19 MR. MESEREAU: Calls for speculation; 20 assumes facts not in evidence. 21 THE COURT: I’m going to sustain the 22 objection because of the use of the term 23 “obsession.” 24 Q. BY MR. ZONEN: If you knew that the person, 25 the 35-year-old man who was sleeping with an 26 eight-year-old boy, possessed a great quantity of 27 sexually explicit material, would that cause you 28 concern about that person’s motivations while he was 9145 1 in bed with the boy? 2 A. Yes. 3 MR. ZONEN: No further questions. 4 5 FURTHER REDIRECT EXAMINATION 6 BY MR. MESEREAU: 7 Q. If you had known Michael Jackson, as a grown 8 man, was reading Playboy, Hustler, Penthouse, 9 magazines like that showing naked women, would that 10 have concerned you? 11 A. No. That’s what I was going to say 12 afterward. Depends on what kind of material, what 13 kind of pornographic material you were talking 14 about. 15 Q. Would that have concerned you? 16 A. No. 17 MR. MESEREAU: No further questions. 18 MR. ZONEN: May I approach the witness? 19 THE COURT: Yes. 20 21 FURTHER RECROSS-EXAMINATION 22 BY MR. ZONEN: 23 Q. I’d like to show you a couple exhibits, 841 24 and 842, that have been shown previously in this 25 court to this jury. 26 Let’s start with one titled “Boys Will Be 27 Boys.” I’d like you to take a look at a few of the 28 pages. Just go ahead and start turning pages, 9146 1 please. 2 Stop there for a moment. 3 Would you describe the picture on the right 4 side? 5 A. There’s a young boy with his legs open and 6 he’s naked. 7 Q. All right. The picture prominently displays 8 his genitalia, does it not? 9 A. Yes. 10 Q. That boy looks, to you, to be approximately 11 how old? 12 A. Maybe 11 or 12. 13 Q. That’s how old you were when you were 14 sleeping with Michael Jackson; is that right? 15 A. Yes. 16 Q. Go ahead and flip a couple of more pages, if 17 you would. 18 You can stop right there, the next page. 19 What’s the picture on the left show? 20 A. Just a young boy who’s naked standing on a 21 rock. 22 Q. His genitalia is prominently displayed in 23 that picture; is that correct? 24 A. Yes. 25 Q. Appears that that child is about the same as 26 the other one? 27 A. Yes. 28 Q. Flip a couple more pages. Please keep 9147 1 going. 2 Okay. Stop right there. 3 What’s in that two pages, series of two 4 pages? 5 A. There’s a boy, about the same age, 11 or 12, 6 who’s naked. 7 Q. All right. And in those pictures his 8 genitalia is prominently displayed as well; is that 9 correct? 10 A. Yes. 11 Q. In fact, if you’ll take just a second and 12 strum through the balance of that book -- you can do 13 it fairly rapidly, if you would. You don’t have to 14 go page by page, but as you wish. 15 Is it true, Mr. Robson, that all of the 16 pictures in that book are of boys about the same 17 age? 18 A. Yes. 19 Q. 10, 11, 12 years old? 20 A. Yes. 21 Q. And that many of the photographs, if not 22 most of the photographs, depicted in that book are 23 of boys nude; is that correct? 24 A. Yes. 25 Q. And in fact, in most of those pictures, the 26 genitalia is prominently displayed; is that right? 27 A. Yes. 28 Q. Would you be concerned with a person who 9148 1 possesses a book like that? 2 A. No. 3 Q. Would you be concerned about having your 4 12-year-old child in bed with a person who possesses 5 a book like that? 6 A. No. 7 Q. You would have no such concern? 8 A. No. It’s -- to me, it doesn’t -- it’s not a 9 pornographic book. It’s sort of, you know -- I 10 don’t know, just a book. 11 Q. I’d like -- and I’d like to show you 12 Exhibit 596, please. Take a moment and look at that 13 book. 14 Let’s stop there for a moment. 15 That’s the first, in fact, picture in that 16 book; is that correct? 17 A. I didn’t notice, no. 18 Do you want me to go to the first picture? 19 Q. You know, no, you can pick any picture, 20 actually. Just go ahead and open the book at 21 random. 22 Right there. 23 A. Oh, sorry. 24 Q. Is it a fact, as you look through that book, 25 what is depicted in that book throughout that book 26 are a series of photographs of two men engaged in 27 sex acts with one another? 28 A. Yes. 9149 1 Q. And in fact, the sex acts are all acts of 2 either masturbation, oral sex or sodomy; is that 3 right? 4 A. From what I saw, yes. 5 Q. And sodomy, as you understand, is an act of 6 anal sex; is that correct? 7 A. Yes. 8 Q. Would you be concerned about a person who 9 possesses that book crawling into bed with a 10 ten-year-old boy? 11 A. Yes, I guess so. 12 MR. ZONEN: No further questions. 13 MR. MESEREAU: May I approach, Your Honor? 14 THE COURT: Yes. 15 16 FURTHER RECROSS-EXAMINATION 17 BY MR. MESEREAU: 18 Q. Mr. Robson, I want to show you Exhibit 19 No. 841. It says, “Boys Will Be Boys.” Do you see 20 this? 21 A. Yes. 22 Q. Okay. Now, I’d like you to read the 23 inscription on that book, okay? Read it out loud, 24 if you would. 25 A. Okay. “Look at the true spirit of happiness 26 and joy in these boys’ faces. This is the spirit of 27 boyhood, a life I never had and will always dream 28 of. This is the life I want for my children. MJ.” 9150 1 Q. Having read that inscription and having 2 looked at this book, would you have any concern 3 being in bed with Michael Jackson if you knew this 4 book was found in his home? 5 A. No. 6 Q. Let me show you Exhibit No. 842. Please 7 read out loud the inscription on that book. 8 A. Is that, “To Michael”? Yeah. “To Michael, 9 from your fan. Kiss, kiss, kiss, hug, hug, hug. 10 Rhonda. 1983.” 11 Q. You’ve looked through that book - okay? - 12 and it says, “The Boy; A photographic Essay,” right? 13 A. I didn’t look through that book. 14 Q. Okay. Why don’t you look through this book 15 the prosecutor showed you, and please say whether or 16 not you would have a problem being in the same 17 bedroom with Michael Jackson based upon what you see 18 in that book and the inscription. 19 A. No. 20 Q. Okay. Now, let me show you -- let me show 21 you Exhibit No. 596 that the prosecutor showed you. 22 Just read the cover, if you would. 23 A. “Man, A Sexual Study of Man. Illustrated 24 With Photographs and Art Prints.” 25 Q. Okay. Now, you’ve seen those photographs, 26 and you’ve said you were somewhat disturbed by the 27 pictures, right? 28 A. Well, I wasn’t disturbed by the pictures. 9151 1 Q. Well, if you -- if you read this book, and 2 it appeared to be a book dealing with male sexuality 3 in all different areas, and you knew that this book 4 existed with hundreds of editions of Hustler, 5 Playboy, Penthouse -- 6 MR. ZONEN: I’m going to object as leading. 7 Q. BY MR. MESEREAU: -- would that bother you? 8 MR. ZONEN: I’m going to object as leading. 9 THE COURT: Overruled. 10 You may answer. 11 THE WITNESS: Can you repeat it? 12 Q. BY MR. MESEREAU: Sure. 13 Let’s assume that you learned that Michael 14 Jackson had ten years’ worth of Hustler, Playboy, 15 Penthouse - okay? - magazines, heterosexual-type 16 magazines, and let’s assume that -- have you ever 17 seen Mr. Jackson’s library? 18 A. Yes. 19 Q. How many books do you think are in there? 20 A. Thousands. 21 Q. And let’s suppose in the middle of all those 22 books you found, “A Sexual Study of Man, Illustrated 23 With Photographs and Art Prints,” okay? 24 A. Yes. 25 Q. Putting all this together, would being in 26 bed with Mr. Jackson concern you? 27 A. No. 28 MR. MESEREAU: No further questions. 9152 1 FURTHER RECROSS-EXAMINATION 2 BY MR. ZONEN: 3 Q. Of course nobody’s told you where this book 4 comes from, did they? 5 A. No. 6 MR. SNEDDON: Ron? 7 THE COURT: It’s time for the break. 8 MR. ZONEN: It’s not quarter to. 9 THE COURT: My bailiff told me. 10 (Recess taken.) 11 MR. MESEREAU: Your Honor? 12 MR. ZONEN: Thank you. 13 MR. MESEREAU: I’m going to object that the 14 questions have become cumulative and there’s no 15 foundation for it to go any further. 16 BAILIFF CORTEZ: Your microphone is off, 17 sir. 18 MR. MESEREAU: It’s beyond the scope. And 19 this is not a character witness. 20 MR. ZONEN: I don’t recall which question 21 he’s referring to. 22 THE COURT: I’m looking for it myself. 23 I don’t have a question. 24 THE REPORTER: Would you like me to read the 25 last question, Judge? 26 MR. ZONEN: I’m prepared to start with a new 27 question. 28 THE COURT: All right. 9153 1 Q. BY MR. ZONEN: Mr. Robson, the three books 2 that are in front of you that you’ve already taken a 3 look at, I’d like to go back over the inscription 4 that -- 842 is a book, and you were asked to read 5 that inscription out loud. 6 Take a look at that inscription again, would 7 you, please? 8 A. Do you want me to read it again? 9 Q. No, you don’t need to read it again. 10 Go to the last word, which is the name. 11 What is the name on that? 12 A. Rhonda. 13 Q. Notice anything unusual about the name? 14 A. No. 15 Q. Do you notice it’s written with quotations 16 on both sides of it? 17 A. Yes. 18 Q. Doesn’t that usually mean that that’s not 19 the name when somebody writes it in quotation marks? 20 A. Not that I know of. 21 Q. Have you ever written your name in quotation 22 marks? 23 A. No. 24 Q. That’s actually from somebody who’s not 25 named Rhonda, right? 26 MR. MESEREAU: Objection; calls for 27 speculation. 28 THE COURT: Sustained. 9154 1 Q. BY MR. ZONEN: The three books I’ve given 2 you so far to take a look at, they all feature 3 either boys or adult men, predominantly nude, and 4 the one on adult men is engaged in sex acts; is that 5 correct? 6 MR. MESEREAU: I’m going to object; asked 7 and answered. This is cumulative. 8 THE COURT: Overruled. 9 Q. BY MR. ZONEN: I’m going to show you three 10 additional books now, if I could. Let’s start with 11 Exhibit 578, if you’ll take a look at that one, 12 please. 13 MR. MESEREAU: Same objection. Cumulative; 14 it’s not character; it’s beyond the scope. 15 THE COURT: Overruled. 16 Q. BY MR. ZONEN: I’ll start with the first 17 picture. What do you see right there? 18 A. I see in the center of the picture, it’s a 19 drawing. And there’s a naked man with his genitalia 20 exposed, and there’s kangaroos on either side. 21 Q. Okay. Go ahead and proceed. 22 You can keep going. Just keep going through 23 it. 24 You can stop. 25 What you’ve seen so far are all pictures of 26 naked men; is that right? 27 A. Yes. 28 Q. And pictures with their genitalia 9155 1 prominently displayed; is that correct? 2 A. Yes. 3 Q. Some of these are bondage pictures, are they 4 not? 5 MR. MESEREAU: Objection; leading. 6 MR. ZONEN: It’s cross-examination, Your 7 Honor. 8 MR. MESEREAU: Assumes facts not in 9 evidence. 10 THE COURT: Overruled. 11 Q. BY MR. ZONEN: Is that correct? Like that 12 picture right there? 13 A. Yes. 14 Q. Would you consider this to be homoerotic 15 material? 16 A. Yes. 17 Q. Exhibit No. 590-B, take a look at that, 18 please. Tell us the title. 19 A. “Before the Hand of Man.” 20 Q. Go ahead and take a look at the content of 21 that book. 22 That’s enough. 23 Pictures of naked young men; is that 24 correct? 25 A. Yes. 26 Q. Would you consider that to be homoerotic 27 material? 28 A. No. 9156 1 Q. Why not? 2 A. I look at this more as sort of -- it’s about 3 the photography and it’s more of an art book, to me. 4 Q. Do you think it’s the background setting 5 that makes it unique? 6 A. Unique? 7 Q. Well, they’re all naked men in it; is that 8 right? 9 A. Yes. 10 Q. Look at No. 599, if you would. 11 You can stop. 12 Those are all pictures of boys and men, all 13 nude; is that correct? 14 A. I didn’t see any boys. I saw men. 15 Q. How old do you think is the youngest person 16 you’ve seen in this book so far? 17 A. Maybe 19. 18, 19. 18 Q. Teenaged? 19 A. Yeah. 20 Q. Okay. They’re all about that age or a 21 little bit older; is that right? 22 A. Yeah. 23 Q. Do you think this person is 19? 24 A. 18, 19, yeah. 25 Q. Okay. And in fact, in each one of them, 26 genitalia is prominently displayed; is that correct? 27 A. Yes. 28 Q. Take a look at this book, please, No. 590-A. 9157 1 You can stop here. 2 What are you taking a look at? Particularly 3 the page you’re focused on at the moment, what do 4 you see? 5 A. There’s two naked men and it looks like 6 they’re about to kiss each another. 7 Q. In this book, in fact, each of the pictures 8 depict two naked men; is that right? 9 A. Yes. 10 Q. And in each instance, both of them are doing 11 something with one another of a sexual nature; is 12 that right? 13 A. No. 14 Q. They’re hugging, they’re touching, they’re 15 caressing? 16 A. They’re posing. 17 Q. They’re posing. And they’re all naked? 18 A. Yes. 19 Q. Would you consider this to be homoerotic 20 art? 21 A. Mind if I look a little more? 22 Q. Go ahead. 23 A. Yeah, it’s -- I don’t think it’s so erotic. 24 It seems more loving in a way, like not so much 25 about sex. 26 Q. Well, how about the one you just turned to? 27 Where is his hand? 28 A. Down his pants. 9158 1 Q. Okay. You can go ahead and close that one 2 right now. 3 Mr. Robson, are you concerned about a man 4 possessing these seven books being in bed with a 5 12-year-old boy? 6 A. If it was a man I didn’t know, maybe. But 7 not Michael. 8 Q. Is that because you view Mr. Jackson as 9 being, for the most part, asexual? 10 A. No. 11 Q. Because you believe that he doesn’t really 12 have a sexual interest? 13 A. I believe that he has a sexual interest in 14 women. 15 Q. Did you know that he possessed these 16 magazines? 17 MR. MESEREAU: Objection, Your Honor, he 18 didn’t let the witness complete his answer. 19 THE COURT: Sustained. 20 MR. MESEREAU: Could the witness complete 21 his answer, Your Honor? 22 THE COURT: Yes. 23 THE WITNESS: I believe that he has a sexual 24 interest in women. 25 Q. BY MR. ZONEN: In women? 26 A. Yes. 27 Q. These books don’t suggest otherwise? 28 A. Not necessarily. 9159 1 Q. All right. Let’s go to some other side of 2 the counter. 3 Exhibit No. 575, have you ever seen this 4 magazine before? 5 A. No. 6 Q. Not that specific one. A magazine of that 7 nature? 8 A. Of that nature, yes. 9 Q. Okay. And go ahead and turn through it. 10 You can stop there. You don’t need to go 11 too much further. 12 This magazine depicts naked women, or a 13 woman in this case, inserting things inside of her; 14 is that right? 15 A. Yes. 16 Q. You would consider this to be very 17 graphic -- 18 A. Yes. 19 Q. -- in terms of sexually explicit material? 20 A. Yes. 21 Q. Exhibit No. 520, tell us the title of that. 22 A. “Hard Rock Affair.” 23 Q. Okay. Go ahead and turn through a few 24 pages. 25 You don’t have to turn any further. 26 That magazine depicts graphic sexual 27 pictures of a man and a woman engaged in acts of 28 intercourse and oral sex; is that right? 9160 1 A. Yes. 2 Q. You would consider this to be pretty much as 3 hard-core as sexually graphic material goes; is that 4 right? 5 MR. MESEREAU: Objection. Misstates the 6 evidence; 352. 7 MR. ZONEN: I asked him what he considered. 8 THE COURT: Overruled. 9 You may answer. 10 THE WITNESS: That’s as hard-core as it goes, 11 is that what you asked? 12 Q. BY MR. ZONEN: Yes. 13 A. No, not as hard-core as it goes. 14 Q. What could be more than that? 15 A. I’ve seen crazy things, crazy bondage 16 things, all sorts of stuff. 17 Q. You saw the bondage in the last publication; 18 is that right? 19 A. Yeah, but they weren’t really doing 20 anything. 21 Q. All right. You would consider bondage to be 22 at the height? 23 A. Yeah. When it gets into, you know, really 24 unusual stuff. 25 Q. What’s the title of this one? The magazine 26 that we have here is 522. 27 A. “Double Dicking Caroline.” 28 Q. Go ahead and turn a couple pages. 9161 1 Okay. That’s fine. 2 These are all photographs of a man and a 3 woman engaged in pretty much anything a man and a 4 woman can do; is that right? 5 A. Yes. 6 Q. Including acts of intercourse, acts of oral 7 sex, and the picture right in front of you, acts of 8 anal sex; is that right? 9 A. Yes. 10 Q. This you would consider to be fairly 11 hard-core, would you not? 12 A. Yes. 13 Q. The title of this one, please? No. 510. 14 A. “Stiff Dick Lynn.” Or “for Lynn,” sorry. 15 Q. “For Lynn”? 16 A. “Stiff Dick for Lynn.” 17 Q. Let’s get our prepositions right. 18 A. Get it right, yeah. 19 Q. Go ahead and turn the page, if you would. 20 A. I never thought I’d have a room of people 21 watching me do this. 22 Q. That’s enough. 23 You would agree that this is a depiction of 24 a man and a woman engaged in virtually every 25 variation that a man and woman can do with one 26 another; is that right? 27 A. Yes. 28 Q. Sexually. 9162 1 The collective material that you have just 2 been shown does not cause you a moment of pause when 3 you think about the prospect of this person who 4 possesses all of this crawling into bed with a 5 ten-year-old boy? 6 A. No. 7 Q. And you would allow a child to crawl into 8 bed with such a person? 9 A. If I knew the person, yes. 10 Q. If you knew them? 11 A. Yes. 12 Q. Your own child, you’d have no problem 13 sleeping with a 35-, 40-year-old man? 14 A. If I knew the person well, no. 15 MR. ZONEN: No further questions. 16 17 FURTHER REDIRECT EXAMINATION 18 BY MR. MESEREAU: 19 Q. Mr. Robson? 20 A. Yes. 21 Q. That’s your fiancee right there, correct? 22 A. Yes. 23 Q. You are heterosexual, correct? 24 A. Yes. 25 Q. You are a close friend of Michael, correct? 26 A. Yes. 27 Q. By the way, did Michael Jackson ever -- oh, 28 I’ll ask from there. 9163 1 When you were a young child, did Michael 2 Jackson ever show you any sexually explicit 3 material? 4 A. No. 5 Q. Did you ever see Michael Jackson show 6 sexually explicit material to any child? 7 A. No. 8 MR. MESEREAU: May I approach, Your Honor? 9 THE COURT: Yes. 10 Q. BY MR. MESEREAU: Now, let me show you again 11 Exhibit No. 841. Do you see that? 12 A. Yes. 13 Q. And have you had a chance to flip through 14 that book? 15 A. Yes. 16 Q. Okay. Let me show you again Exhibit No. 17 596. It says, “A Sexual Study of Man.” Do you see 18 that? 19 A. Yes. 20 Q. Have you had a chance to flip through that 21 book? 22 A. Yes. 23 Q. Okay. And let me show you again Exhibit No. 24 842, “A boy; A Photographic Essay,” okay? And 25 that’s the one with the inscription, “To Michael, 26 from your loving fan, Rhonda,” okay? 27 A. Yes. 28 Q. And have you had a chance to flip through 9164 1 that book? 2 A. Yes. 3 Q. In fact, you see young children with rather 4 innocent photographs of young boys, correct? 5 MR. ZONEN: I’m going to object as leading, 6 Your Honor. 7 THE COURT: Overruled. 8 Q. BY MR. MESEREAU: Innocent photographs of 9 young boys in various situations, right? 10 A. Yes. 11 Q. Okay. You see a young boy hanging from a 12 tree, right? 13 A. Yes. 14 Q. You see a young boy sitting outside a door, 15 right? 16 A. Yes. 17 Q. See young boys on a beach, right? 18 A. Yes. 19 Q. Okay. Now, let’s go to -- quickly, to the 20 material the prosecutor for the government showed 21 you, okay? He showed you some magazines with 22 heterosexual activity, correct? 23 A. Yes. 24 Q. Okay. Have you seen one book that depicts 25 child pornography in that group? 26 A. No. 27 MR. ZONEN: I believe there was a Court 28 restriction on the use of that word, Your Honor, one 9165 1 initiated by the defense. Unless that reservation 2 is finished. 3 MR. MESEREAU: He’s correct. And I made a 4 mistake using the word. I’ll withdraw it, and I 5 apologize. 6 THE COURT: All right. The problem is that 7 sometimes it’s an appropriate word to use and 8 sometimes it’s not. But the jury’s been instructed 9 on it. And so if you want to rephrase it, that’s 10 fine. 11 MR. MESEREAU: Okay. 12 Q. In those books that the prosecutor for the 13 government showed you, you see books about men, 14 right? 15 A. Yes. 16 Q. You see one book that says, “A Study of Male 17 Sexuality” and shows some sexual acts between men, 18 correct? 19 A. Yes. 20 Q. And he showed you a number of magazines 21 involving sexual activity between men and women, 22 correct? 23 A. Yes. 24 Q. Okay. Has he shown you one book involving 25 children having sex? 26 A. No. 27 Q. Has he shown you one book where a man is 28 having sex with a child? 9166 1 A. No. 2 Q. The prosecutor tried to suggest that Mr. 3 Jackson is asexual. Do you remember that question? 4 A. Yes. 5 Q. Do you believe he’s asexual? 6 A. No. 7 Q. Have you seen Mr. Jackson with women in your 8 lifetime? 9 A. With what kind of woman? A woman that he’s 10 in a relationship with? 11 Q. That he’s been married to. 12 A. Yeah, with Lisa Marie. 13 Q. When you were at Neverland, did you ever see 14 anything that suggested pedophilia? 15 A. No. 16 Q. Ever see any magazine or poster that 17 suggested pedophilia? 18 A. Never. 19 MR. MESEREAU: No further questions. 20 21 FURTHER RECROSS-EXAMINATION 22 BY MR. ZONEN: 23 Q. Mr. Robson, when did you first learn that 24 Michael Jackson possessed material of the nature 25 that’s before you right now? 26 A. Right now I did. 27 Q. All the years that you have known Michael -- 28 A. Actually, no one’s told me where this came 9167 1 from. 2 Q. Assuming this comes from Michael Jackson’s 3 residence. 4 A. Assuming it does, this is the first I know. 5 Q. All right. And you had never, ever known 6 that Mr. Jackson collected sexually explicit 7 material? 8 A. No. 9 Q. This is something new that you’re learning 10 just today; is that right? 11 A. Yes. 12 Q. You’re telling us that this would have no 13 effect at all on your belief that this bears on some 14 suitability for him sleeping with ten-year-old boys? 15 A. No. 16 Q. You knew that there were a succession of 17 ten-year-old boys that he slept with, didn’t you? 18 MR. MESEREAU: Objection. Misstates the 19 evidence; the Court ruling. 20 THE COURT: Sustained. 21 Q. BY MR. ZONEN: Did you know about other 22 children that he had slept with? 23 A. No. 24 Q. Never? 25 A. No. 26 Q. Did you know that he was sleeping with Brett 27 Barnes? 28 A. No. 9168 1 Q. Did you know that he was sleeping with 2 Macaulay Culkin? 3 A. No. 4 Q. Did you know that he was sleeping with 5 Jordie Chandler? 6 A. No. 7 MR. ZONEN: No further questions. 8 9 FURTHER REDIRECT EXAMINATION 10 BY MR. MESEREAU: 11 Q. You actually saw kids sleeping in his room 12 from time to time, correct? 13 A. Yeah. When he was present as well, yeah. 14 Q. And Macaulay Culkin was there as well, 15 correct? 16 A. Yeah. 17 Q. Never saw anything inappropriate happen, 18 right? 19 A. No. 20 Q. Has anything this prosecutor for the 21 government has said to you changed your opinion of 22 Michael Jackson? 23 A. Not at all. 24 Q. Does it change your opinion as to whether or 25 not he ever did anything inappropriate with a child? 26 A. Not at all. 27 MR. MESEREAU: No further questions. 28 MR. ZONEN: I have no questions. 9169 1 THE COURT: Thank you. You may step down. 2 Call your next witness. 3 MR. MESEREAU: Your Honor, may I remove the 4 materials from the witness box? 5 THE COURT: Yes. 6 THE BAILIFF: Oh, I’ll get it for you. 7 THE COURT: When you get to the witness 8 stand, please remain standing. 9 Face the clerk over here and raise your 10 right hand. 11 12 BRETT CHRISTOPHER BARNES 13 Having been sworn, testified as follows: 14 15 THE WITNESS: Yes. 16 THE CLERK: Please be seated. State and 17 spell your name for the record. 18 THE WITNESS: My whole name? 19 THE CLERK: Yes, please. 20 THE WITNESS: Okay. It’s Brett Christopher 21 Barnes. B-r-e-double t; C-h-r-i-s-t-o-p-h-e-r; 22 B-a-r-n-e-s. 23 THE CLERK: Thank you. 24 25 DIRECT EXAMINATION 26 BY MR. MESEREAU: 27 Q. Mr. Barnes, how old are you? 28 A. I’m 23 years old. 9170 1 Q. Where is your home? 2 A. Melbourne, Australia. 3 Q. And what kind of work do you do? 4 A. Right now I’m unemployed. I actually had to 5 quit my job to come here. 6 Q. Okay. And what job is that? 7 A. I was a roulette dealer at the casino. 8 Q. In Melbourne? 9 A. Yes. 10 Q. Okay. Do you know the fellow seated to my 11 right at counsel table? 12 A. Absolutely. 13 Q. Who is he? 14 A. It’s my good friend Michael Jackson. 15 Q. And you say your good friend. How long have 16 you known him? 17 A. Since I was five. 18 Q. How did you meet him? 19 A. I actually -- I was a big -- well, I was as 20 big a fan as you can be at that age, of his, and he 21 was in Melbourne for the “Bad” tour. And so my mom 22 thought it would be a good idea for us to write a 23 letter. My sister wrote the letter, but put it in 24 my name as if I was writing the letter. 25 And we went to meet him -- well, see him at 26 the airport when he touched down. And while we were 27 there, we gave the letter to one of his dancers, and 28 then we left the airport after it was all over. 9171 1 And I’m not sure exactly how much time 2 passed, but after a little while, he -- we received 3 a phone call from him, and ever since then we’ve 4 been really good friends. 5 Q. And is he a friend of your family? 6 A. Absolutely. 7 Q. Okay. Have you ever visited Neverland 8 Ranch? 9 A. Yes, I have. 10 Q. When did you first visit Neverland Ranch? 11 A. It would have been December of ‘91. 12 Q. And do you remember why you visited 13 Neverland? 14 A. Because he was there, and it’s his house, I 15 guess. 16 Q. Who did you go with? 17 A. My whole family went, my mother and my 18 father and my sister and myself. 19 Q. Did you stay at Neverland? 20 A. Yes, I did. 21 Q. How many times do you think you visited 22 Neverland? 23 A. Too many to remember. Probably -- it would 24 be ten or more, even. More than ten times. 25 Q. And how many times do you think you’ve 26 stayed over at Neverland? 27 A. Every time. 28 Q. Okay. Did you ever stay in Michael 9172 1 Jackson’s room? 2 A. Yes, I have. 3 Q. How many times do you think you’ve done 4 that? 5 A. Countless as well. 6 Q. And how would you describe his room? 7 A. It’s big. It’s pretty cool because it’s got 8 lots of fun stuff to do there. Video games, such as 9 stuff like that. And it’s probably the best as I 10 can describe it. 11 Q. Have you ever stayed in Michael Jackson’s 12 bed? 13 A. Yes, I have. 14 Q. How many times do you think you have? 15 A. Countless as well. 16 Q. Has Mr. Jackson ever molested you? 17 A. Absolutely not. And I can tell you right 18 now that if he had, I wouldn’t be here right now. 19 Q. Has Mr. Jackson ever touched you in a sexual 20 way? 21 A. Never. I wouldn’t stand for it. 22 Q. Has Mr. Jackson ever touched any part of 23 your body in a way that you thought was 24 inappropriate? 25 A. Never. It’s not the type of thing that I 26 would stand for. 27 Q. When you stayed in Mr. Jackson’s bed -- 28 A. Uh-huh. 9173 1 Q. -- on any of those occasions was anyone else 2 there? 3 A. Yeah. 4 Q. Who? 5 A. Well, I can’t -- see, I was pretty young at 6 the time, so I can’t remember exactly. But I know 7 my sister as being there, his cousins have been 8 there. And -- yeah, Macaulay has actually been 9 there as well, Macaulay Culkin. So there’s been a 10 few people. 11 Q. What is the longest period you think you’ve 12 ever stayed at Neverland? 13 A. I couldn’t tell you. I don’t remember 14 really. 15 Q. Would it be a week, or three days? 16 A. Longer than that. 17 Q. Longer than that? 18 A. Yeah. It would probably be a couple weeks, 19 maybe a month at Neverland at one time. 20 Q. And what do you recall doing at Neverland 21 during the times you stayed there? 22 A. Playing arcade games. Going 23 ATV/motorbike-riding around the property. Going on 24 amusement park rides. And watching plenty of 25 movies, plenty of cartoons. Eating very good food. 26 Q. Do you consider Michael Jackson to be your 27 family friend? 28 A. Absolutely. 9174 1 Q. Do you stay in communication with him? 2 A. Absolutely. 3 Q. And how do you typically communicate with 4 Michael Jackson? 5 A. Like he’s a member of the family. Just 6 always had warm conversations, reminisce about old 7 times. 8 Q. Are you familiar with a Jacuzzi at 9 Neverland? 10 A. Yeah. 11 Q. Ever been in the Jacuzzi? 12 A. Yes, I have. 13 Q. Do you recall Michael Jackson ever being in 14 the Jacuzzi with you? 15 A. I don’t recall. He possibly could have, but 16 I don’t really remember. 17 Q. Do you recall ever taking a shower with 18 Michael Jackson? 19 A. Never. 20 Q. Now, have you visited Neverland without your 21 parents being with you? 22 A. Yes. 23 Q. And how many times do you think you’ve done 24 that? 25 A. It wouldn’t be that many. But I couldn’t 26 give you a ballpark figure even. 27 Q. Now, have you followed this case in the 28 media? 9175 1 A. No, I haven’t. 2 Q. Okay. 3 A. I chose not to. 4 Q. Are you aware of any allegations being made 5 that Mr. Jackson inappropriately touched you when 6 you were with him? 7 A. Yes, I am. And I’m very mad about that. 8 Q. You’re mad about it? 9 A. Yeah. 10 Q. Why? 11 A. Because it’s untrue, and they’re putting my 12 name through the dirt. And I’m really, really, 13 really not happy about it. 14 MR. MESEREAU: No further questions. 15 16 CROSS-EXAMINATION 17 BY MR. ZONEN: 18 Q. Mr. Barnes, do you consider it disgraceful 19 to having been molested? 20 A. Absolutely. 21 Q. All right. And why would it be a disgrace 22 for somebody to have been molested? 23 A. Well, a child is -- 24 MR. MESEREAU: Objection. This calls for 25 speculation; foundation. 26 THE COURT: Sustained. 27 Q. BY MR. ZONEN: How old were you when you 28 first started sharing a bed with Michael Jackson? 9176 1 A. Couldn’t tell you. Don’t really remember. 2 Q. How old were you when you first started 3 visiting Michael Jackson? 4 A. When I first started visiting, I was nine. 5 Q. And you visited Neverland with whom? 6 A. With my parents. 7 Q. Both your mother and your father? 8 A. And my sister as well. 9 Q. Your sister as well. And how long did you 10 stay at Neverland? 11 A. The first time? 12 Q. Yes. 13 A. I don’t exactly remember. 14 Q. Did you stay over the week? 15 A. Yeah. 16 Q. Did you then visit Neverland on a regular 17 basis thereafter? 18 A. I wouldn’t say regular, but, yeah, it was 19 quite frequent. 20 Q. Did you visit Neverland at least once a year 21 thereafter? 22 A. Yeah. 23 Q. And when you visited Neverland, would you 24 always stay with Michael Jackson? 25 A. Yeah, most of the time. 26 Q. All right. Now, I asked you, I believe, the 27 age the first time you went. Did you answer that 28 question? 9177 1 A. Yeah. 2 Q. And you said what? About nine? 3 A. Yeah. 4 Q. Okay. And then you would continue to go 5 each year thereafter? 6 A. Yeah. 7 Q. Did you sometimes go more than once a year? 8 A. Yeah. 9 Q. And would you stay for longer than one week 10 at a time? 11 A. Sometimes, I guess, yeah. 12 Q. Were there occasions where you would stay 13 two or even three weeks? 14 A. I was young at the time, so I don’t really 15 remember the time frames. 16 Q. Okay. 17 A. So it would be purely speculation. 18 Q. Would it have been summer vacation; that is, 19 your summer vacation in Australia? 20 A. I really couldn’t tell you. 21 Q. Did you ever go to Neverland without a 22 parent going with you? 23 A. Yes. 24 Q. So sometimes you would fly all the way from 25 Australia to Neverland, is that right, by yourself? 26 A. Absolutely. 27 Q. Were you much older than nine years old when 28 you did that? 9178 1 A. I couldn’t tell you. But -- well, right -- 2 yeah, I was older than nine. 3 Q. Did you visit in your tenth year and your 4 eleventh year and your twelfth year as well? 5 A. I really couldn’t tell you that. 6 Q. Did you ever visit in your thirteenth year 7 and your fourteenth year? 8 A. I don’t remember much about ages. 9 Q. You can’t tell us how old you were when you 10 stopped visiting Neverland? 11 A. I still -- I continue to visit to this day. 12 Q. Do you still sleep with Michael Jackson? 13 A. No, I don’t. 14 Q. How old were you when you stopped sleeping 15 with Michael Jackson? 16 A. I couldn’t tell you that. 17 Q. Why don’t you still sleep with Michael 18 Jackson? 19 A. Well, he’s got kids now. 20 Q. And? 21 A. And I -- it would be purely speculation if I 22 told you. I could not answer that knowingly, 23 like -- it’s just -- 24 Q. But during the years that you were visiting 25 Michael Jackson at Neverland, you never stayed 26 anyplace but in his room; is that correct? 27 A. I couldn’t tell you. 28 Q. You’re telling us that you don’t remember if 9179 1 you stayed in a guest lodge by yourself or with your 2 mother or if you shared a bed with Michael Jackson? 3 A. I don’t remember staying in the guest lodge 4 by myself. 5 Q. But it’s true, sir, that you stayed 6 virtually the entire time in his bedroom; is that 7 right? 8 A. Yeah. 9 Q. And during that time nobody else stayed in 10 the bedroom with you other than you and Michael 11 Jackson; is that true? 12 A. No, that’s not true. 13 Q. On what percentage of the occasions that you 14 visited Michael Jackson was there somebody else 15 staying in that room? 16 A. I couldn’t tell you. 17 Q. Can you tell us the names of the people who 18 stayed in the room with you? 19 A. My sister. Macaulay Culkin. There was 20 Levon and Elijah. There was Frank, Eddie, and 21 Dominick. 22 Q. Was Frank -- 23 A. Prince as well. 24 MR. MESEREAU: Objection, he hasn’t finished 25 the question. 26 THE WITNESS: His son Prince as well. 27 Q. BY MR. ZONEN: Prince? Prince is how old 28 now? 9180 1 A. I’m not quite sure. 2 Q. About what, seven? 3 A. Yeah. I guess so. 4 Q. And how old was Prince when he stayed in the 5 room with you and Michael Jackson? 6 A. I think he was three. 7 Q. All right. So it was about four years ago? 8 A. Yeah. 9 Q. So you stayed in the room with Michael 10 Jackson when you were 18 years old? 11 A. Yeah. 12 Q. You’re 22 now? 13 A. 23. 23. 14 Q. So you were 19 years old? 15 A. Yeah, I guess. 16 Q. Did you share a bed with him at that time? 17 A. Yeah, I did. 18 Q. You did. Have you been sharing a bed with 19 him consistently from age nine until age 19? 20 A. What do you mean by “consistent”? 21 Q. Well, in all the times that you visit, 22 predominately do you stay in his room, in his bed? 23 A. Yeah. 24 Q. Did you do it when you were ten years old as 25 well? 26 A. Yeah. 27 Q. Did you do it when you were 11 years old as 28 well? 9181 1 A. Yes. 2 Q. Most of the times you did it, there was 3 nobody else in the room; is that correct? 4 A. I guess you could say that. 5 Q. Because Macaulay Culkin was only in the room 6 with you once or twice; isn’t that true? 7 A. I couldn’t tell you how many times. 8 Q. Could he have been in the room 20 or 30 9 times? 10 A. Probably not. 11 Q. So really it’s closer to once or twice; is 12 that right? 13 A. Yeah, I guess so. 14 Q. All right. And your sister stayed there the 15 first time you visited; is that right? 16 A. Not just the first time. 17 Q. Did she stay there the second time? 18 A. I -- look, I don’t really remember. 19 Q. Did your sister share a bed with you and 20 Michael Jackson ever? 21 A. I can’t recall. 22 Q. You can’t recall if your sister shared a 23 bed? 24 A. I can’t remember. 25 Q. When did your sister stop visiting 26 Neverland? 27 A. She still visits to this day. 28 Q. Does she still share a bed with you and 9182 1 Michael Jackson? 2 A. No. 3 Q. When was the last time your sister shared a 4 bed with you and Michael Jackson? 5 A. I couldn’t tell you. I don’t know the exact 6 period of time. 7 Q. Could you have been 15 or 16 years old? 8 A. I couldn’t tell you. 9 Q. Could you have been ten? 10 A. I couldn’t tell. 11 Q. Mr. Barnes, the best you can tell us about 12 when your sister last shared a bed with you and 13 Michael Jackson, you have no idea? 14 A. It’s not something that I think of. What -- 15 why would I try and remember that? 16 Q. Is there -- 17 A. Why would I think about it? 18 Q. Is there any other 35-year-old man that you 19 slept with when you were ten years old besides 20 Michael Jackson? 21 A. Yes. 22 Q. Who? 23 A. My uncle. 24 Q. All right. A family member. 25 A. Yeah. 26 Q. Who else? 27 A. That would probably be it. I can’t recall 28 any others. 9183 1 Q. All right. Now, with whom do you live at 2 this time? 3 A. My parents and my sister. 4 Q. And both your parents? 5 A. Yeah. 6 Q. And that’s in Australia? 7 A. Yes. 8 Q. All right. Did your father ever visit 9 Neverland with you? 10 A. Yes, he did. 11 Q. When your father visited Neverland with you, 12 where did you stay? 13 A. Both in the guesthouse and both with him. 14 Q. Both in the guesthouse and with Mr. Jackson? 15 A. I stayed with Mr. Jackson, yeah. 16 Q. Did you ever have a conversation with your 17 father about the propriety of sharing a bed with a 18 35-year-old man? 19 A. Not that I recall. 20 Q. Did you ever have a conversation with your 21 mother about that, whether that was a wise thing to 22 do, to share a bed with a 35-year-old man? 23 A. Not that I recall. 24 Q. Did he ever show you any sexually explicit 25 material? 26 A. Absolutely not. 27 MR. MESEREAU: Objection; beyond the scope. 28 THE COURT: Overruled. The answer is, 9184 1 “Absolutely not.” 2 Q. BY MR. ZONEN: Were you aware that he 3 possessed sexually explicit material? 4 A. No. 5 Q. Did you ever travel with Michael Jackson 6 anywhere? 7 A. Yes, I did. 8 Q. Where? 9 A. South America, North America, Africa, and 10 Europe. 11 Q. On those occasions -- 12 A. And Australia as well, I’m sorry. 13 Q. On those occasions did you share a bed with 14 him? 15 A. Yes. 16 Q. Were any other people present while you were 17 in the room with him? 18 A. I don’t recall. I can’t -- I can’t 19 remember. 20 Q. Was your mother with you when you traveled 21 through South America? 22 A. I think so. 23 Q. You think so? 24 A. Look, when I was young, I wasn’t really 25 thinking about this sort of stuff. I wasn’t trying 26 to retain in my memory this sort of stuff. And 27 what’s sad is that I traveled to all these countries 28 and I really don’t remember much of them. So it’s 9185 1 all sort of -- it’s all sort of meshed into one. 2 Q. Mr. Barnes, how old were you when you 3 traveled through South America with Mr. Jackson? 4 A. To tell the truth, I cannot remember. 5 Q. You can’t tell whether you were 19 or 10? 6 A. Well, I wasn’t 19. It was in my middle 7 teens, maybe -- no, it would have been in my 8 early -- early teens. 9 Q. 12? 10 A. It could have been possibly 12. 11 Q. So you were 12 or 13. You don’t know if 12 your mother was there with you when you traveled 13 through South America? 14 A. She was, actually. 15 Q. In fact, you traveled quite a bit with Mr. 16 Jackson without your mother being present; isn’t 17 that true? 18 A. No. 19 Q. Did you travel through North America with 20 Mr. Jackson without your mother? 21 A. Yes. 22 Q. And in how many cities through North America 23 did you go without your mother and Mr. Jackson? 24 A. I’m not too sure. 25 Q. Six or seven, perhaps eight? 26 A. I couldn’t tell you. 27 Q. Was he performing at the time, Mr. Jackson? 28 A. For which? 9186 1 Q. On the trip through North America, was he 2 performing? 3 A. No, he wasn’t. 4 Q. Did you travel with him when he was 5 performing? 6 A. Yes. 7 Q. Was that -- in South America, was he 8 performing then? 9 A. Yes. 10 Q. And every night after the performance, you 11 would go with him to his room; is that correct? 12 A. Yes. 13 Q. And you stayed in his bed that night? 14 A. Yep. 15 Q. In North America when you traveled, your 16 mother was not there? 17 A. Not -- well, see, she went to some cities, 18 like we all went to some cities, and sometimes we -- 19 I went. Like on some of the occasions when I was 20 gone, coming over here alone, we’d go around. But 21 sometimes when my whole family was there, we’d go 22 around, too. 23 Q. How many times did you come to the United 24 States by yourself? 25 A. Probably only two or three maybe. 26 Q. And did Mr. Jackson arrange for that to 27 happen? 28 A. He arranged for all of our trips. 9187 1 Q. So all of the transportation for you and 2 your family from Australia to Neverland; is that 3 correct? 4 A. Yeah. 5 Q. And then all the travels that you did 6 through the United States and through South America? 7 A. Uh-huh. I was very fortunate. 8 Q. I’m sorry? 9 A. I was very fortunate. 10 Q. When you slept with Mr. Jackson, what 11 generally did you wear? 12 A. Sorry? 13 Q. When you slept with Mr. Jackson in the same 14 bed, what would you wear? 15 A. Pajama pants, T-shirt, pajama top sometimes. 16 Q. Always? 17 A. Well, always pajama pants, always a T-shirt. 18 Q. And Mr. Jackson? 19 A. Exactly the same thing. 20 Q. Always pajamas and pajama bottoms? 21 A. Uh-huh. 22 Q. I’d like to show you a series of photographs 23 and tell me if you recognize them, the people in 24 this photo. Let’s start with 893. 25 A. Yep. 26 Q. Who’s that? 27 A. That’s me and him. 28 Q. Are these Polaroids? 9188 1 A. They look so. 2 Q. Do you remember taking these pictures? 3 A. Not at all. 4 Q. Do you remember where you were? 5 A. Not at all. 6 Q. Can you tell us about how old you were? 7 A. Probably about 11 maybe, 10. 8 Q. I notice you’ve changed your hairstyle since 9 then, haven’t you? 10 A. Yes. 11 Q. You were about nine or ten. 12 So this was early on in your meeting with 13 Mr. Jackson; is that right? 14 A. Yeah, I would say so. 15 Q. All right. This is 893, and that has two 16 photos on the front, and two photos on the back; is 17 that right? 18 A. Yep. 19 Q. And that’s you in the two photos in the back 20 as well? 21 A. Yep. 22 Q. All right. 892, is that you as well? 23 A. Yep. 24 Q. And Mr. Jackson? 25 A. Yep. Yep. 26 Q. And the two on the back? Do these appear to 27 have been taken at the same time? 28 A. These? 9189 1 Q. Yes. 2 A. Yeah, I’d say so. 3 Q. 891, who is that? 4 A. That’s Michael Jackson. 5 Q. Did you take those pictures? 6 A. Couldn’t tell you. 7 Q. They appear to have been taken at the same 8 time; no? 9 A. Possibly. 10 Q. All right. If I were to tell you that they 11 were all found together, would that suggest that 12 they were all taken at the same time? 13 MR. MESEREAU: Objection; calls for 14 speculation. 15 THE COURT: Sustained. 16 Q. BY MR. ZONEN: Turn it over, if you would, 17 to the back side. Three more pictures on the back. 18 What are they? 19 A. Of Michael Jackson. 20 Q. Do you remember those pictures? 21 A. Not at all. 22 Q. Does that look familiar to you? 23 A. No. 24 Q. Mr. Barnes, did you take those photographs? 25 A. I couldn’t tell you. I don’t -- I couldn’t 26 tell you, no. 27 Q. 890, two pictures on the front. Would you 28 take a look at those two pictures? 9190 1 A. Uh-huh. 2 Q. One of those is you; is that right? 3 A. Yes, it is. 4 Q. You appear to be in bed. 5 A. Uh-huh. 6 Q. The other picture is what? 7 A. Appears to be Michael Jackson. 8 Q. And he’s in his underwear; is that right? 9 A. Yes, it is. 10 Q. 889, is that you? 11 A. Yes, it is. 12 Q. And anything on the back? 13 A. Yep. 14 Q. Is that you as well? 15 A. Yes, it is. 16 Q. All right. Do you remember those pictures? 17 A. Don’t remember taking them, but I can tell 18 you where they were taken. 19 Q. Where? 20 A. They were taken at the ranch. 21 Q. They were taken at the ranch? 22 A. In a photo booth. 23 Q. There’s a photo booth at the ranch on that 24 one there? 25 A. Yep. 26 Q. Do you recognize the background on any of 27 the other photographs? 28 A. On these? 9191 1 Q. Yes. 2 A. No, I don’t. No. 3 Q. Are all of these photographs accurate 4 photographs of the subjects depicted within? In 5 other words, the photographs of Mr. Jackson really 6 are Mr. Jackson and the photographs of you really 7 are you? 8 A. That one’s a bit sketchy, but the rest, 9 yeah. 10 Q. The one in his underwear? 11 A. Yeah. 12 Q. You’re not sure that’s him? 13 A. Well, you can’t really see the face 14 properly. 15 Q. Mr. Barnes, before coming from Australia, 16 did you speak with anybody about your testimony? 17 A. No. 18 Q. They simply flew you from Australia to 19 California? 20 A. Well, they explained that I’d be a witness. 21 Q. And then they interviewed you after you got 22 here? 23 A. The interview? 24 Q. Yes. You had an interview with an 25 investigator -- 26 A. Yes. 27 Q. -- who works for Mr. Mesereau; is that 28 right? 9192 1 A. Yes. 2 Q. And that interview took place after you got 3 to California? 4 A. Yes, it did. 5 Q. So they had no way of knowing what you were 6 going to say while you were still in Australia? 7 A. No. 8 Q. Because they never talked with you at all? 9 A. Not about the case, not being a witness. I 10 signed a declaration. 11 Q. You signed a declaration from where? 12 A. From -- I was at home. Melbourne, 13 Australia. 14 Q. Melbourne, Australia? 15 A. Yeah. 16 Q. All right. So somebody wrote a declaration 17 and they sent it to you, is that right, in 18 Australia? 19 A. Faxed it. 20 Q. I’m sorry? 21 A. Faxed it. 22 Q. They faxed it you. But you had to have 23 talked to somebody to tell them what to put in the 24 declaration, didn’t you do that? 25 A. Yes, I did. 26 Q. So you did talk with somebody while you were 27 in Australia? 28 A. Yes. 9193 1 Q. Who was the person that you talked with 2 while you were in Australia? 3 A. It was Brian Oxman and some -- I think it 4 might be Scott Ross as well. But I’m not exactly 5 sure. 6 Q. And then they prepared a declaration, they 7 sent it to you; is that correct? 8 A. That’s correct. 9 MR. ZONEN: Madam Clerk, could I have 10 another sticker that says.... 11 Q. Let me show you 894, four photographs on it. 12 MR. MESEREAU: Excuse me, Counsel. Are 13 these what I saw before? Are these what you showed 14 me earlier? 15 MR. ZONEN: Not the first set. Let me show 16 you. 17 Q. 893, would you take a look at that, please, 18 both sides of that? 19 A. Yep. 20 Q. That contains a total of six pictures, two 21 on one side, four on the back; is that right? 22 A. That’s correct. 23 Q. And those are all pictures of you, one 24 picture of Mr. Jackson? 25 A. Correct. 26 Q. 894? 27 A. Uh-huh. 28 Q. That’s who? 9194 1 A. Michael Jackson. 2 Q. All four of those pictures? 3 A. Correct. 4 Q. Do you recognize the location? 5 A. No, I don’t. 6 Q. You have no recollection of that? 7 A. No. 8 Q. Could that have been a hotel you stayed in? 9 A. Quite possibly. 10 Q. All right. 896? 11 A. Uh-huh. 12 Q. Does any of that look familiar to you? 13 A. Is this New York? I don’t remember any of 14 these pictures. 15 Q. Do you remember any of those pictures being 16 taken? 17 A. Not at all. 18 Q. And your age, approximately, in those 19 photographs? 20 A. I would have absolutely no idea. 21 Q. You would have no idea at all? 22 A. Well, these ones of me? 23 Q. Yes. You. 24 A. Probably about the same age. 25 Q. Okay. Does it appear that those photographs 26 were taken about the same time? 27 A. Purely speculation, but, yes. 28 Q. Is your hairstyle the same as -- 9195 1 MR. MESEREAU: Objection; move to strike. 2 THE COURT: Stricken. Speculation. 3 Q. BY MR. ZONEN: Based on your familiarity 4 with yourself, does it appear that you are about the 5 same age in each of the photographs so far shown to 6 you? 7 A. Yes. 8 Q. And all those photographs are you with 9 Michael Jackson in a room someplace; is that right? 10 A. Yes. 11 Q. You have no recollection of when those 12 photographs were taken? 13 A. Absolutely not. 14 Q. And the pictures of Mr. Jackson, you have no 15 recollection of actually taking those yourself? 16 A. Absolutely not. 17 Q. Were there many occasions, when you were ten 18 years old, that you traveled by yourself with Mr. 19 Jackson? 20 A. I wouldn’t say -- well, I’m not sure I 21 understand the question. 22 Q. Did you travel more than one trip with Mr. 23 Jackson when you were about the age of 10 by 24 yourself? 25 A. Do you mean from my home? 26 Q. Yes. 27 A. Around? 28 I can’t really remember. I can’t remember 9196 1 how many times. It might have been one, might have 2 been two. I can’t really tell you. 3 Q. On the occasions when you traveled with Mr. 4 Jackson and he was on tour, did you go to all of the 5 concerts? 6 A. I’m not sure. 7 Q. Was there ever a woman traveling with Mr. 8 Jackson while you were traveling with him? 9 A. A woman? 10 Q. Yes. 11 A. I’m not -- what do you mean, though? 12 Q. Somebody with whom he was close to. I don’t 13 mean an assistant. I mean a friend or a girlfriend. 14 A. Not that I recall. 15 Q. At the time that you were traveling with him 16 in South America, was he ever traveling with a 17 woman? And I don’t mean an assistant. A 18 girlfriend. 19 MR. MESEREAU: Object as beyond the scope. 20 THE COURT: Sustained. 21 Q. BY MR. ZONEN: Were there ever any other 22 people traveling with you as part of your unit? 23 A. Where? 24 Q. When you traveled. 25 A. Sometimes. 26 Q. Did any of them sleep in the same room with 27 you and Mr. Jackson? 28 A. I can’t really recall. I don’t remember. 9197 1 Q. Did anyone ever share a bed with you and Mr. 2 Jackson, where there were three of you in the same 3 bed together? 4 A. Can’t really remember. 5 Q. Did your sister ever sleep with you in the 6 same bed and Mr. Jackson? 7 A. Unfortunately, I can’t really remember that 8 either. 9 Q. Do you know Wade Robson? 10 A. Yes. 11 Q. How well do you know Wade Robson? 12 A. Not very. 13 Q. Have you kept up some kind of friendship 14 with Mr. Robson? 15 A. Nope. 16 Q. Is that a “no”? 17 A. That’s a “no.” 18 Q. When was the last time you spoke with Mr. 19 Robson? 20 A. Today. 21 Q. All right. Today you saw him. When was the 22 last time prior to today? 23 A. Yesterday. 24 Q. Okay. So you’ve been staying at Neverland, 25 have you? 26 A. Yes. 27 Q. Did you have an opportunity to talk with Mr. 28 Robson? 9198 1 A. I had an opportunity, yeah. Yeah. 2 Q. And did you speak with Mr. Robson? 3 A. Yes. 4 Q. Did you discuss your testimony? 5 A. Absolutely not. 6 Q. And why not? 7 A. Because it was explained to us that we were 8 not allowed to. 9 Q. Who was that who told you that? 10 A. The lawyers did. 11 Q. Did they say why you weren’t allowed to? 12 A. Isn’t it against the law? 13 Q. Is that what they told you, it was illegal 14 to talk with each other? 15 A. No, they didn’t. They just explained that 16 it wasn’t -- they just said, “Don’t talk about the 17 case.” 18 Q. Were you aware of Wade Robson spending long 19 periods of time with Michael Jackson? 20 MR. MESEREAU: Objection. Beyond the scope; 21 relevance. 22 THE COURT: Sustained. 23 Q. BY MR. ZONEN: Did Michael Jackson ever 24 speak to you about other boys who spent nights with 25 him in his room? 26 MR. MESEREAU: Objection. Beyond the scope; 27 relevance; foundation. 28 THE COURT: Sustained. 9199 1 Q. BY MR. ZONEN: Did you ever talk with 2 Michael Jackson about the propriety of sharing a bed 3 with him? 4 MR. MESEREAU: Objection. Beyond the scope; 5 foundation; and relevance. 6 THE COURT: Overruled. 7 Q. BY MR. ZONEN: Go ahead and answer the 8 question. 9 A. Not that I recall. 10 Q. At no time did you ever have a conversation 11 with Michael Jackson where the subject of the 12 conversation was whether or not you should be 13 sharing a bed with him? 14 A. Not that I recall. 15 Q. Did he ever tell you that you were like 16 family to him? 17 A. All the time. 18 Q. All the time. Did he ever tell you that you 19 should trust him? 20 A. Yeah. 21 Q. Did he ever tell you that he was like a 22 father to you? 23 A. He may have, yes. 24 Q. Did he ever tell you that he considered you 25 to be like a son to him? 26 A. Yes. 27 Q. Was that something he frequently said to 28 you? 9200 1 A. Not frequently. 2 Q. Was that something that he frequently said 3 to you during the early stages of your relationship 4 when you were about age eight? 5 A. Never met him when I was age eight. 6 Q. You were about nine? 7 A. Yeah. 8 Q. Okay. So how long after you had begun 9 visiting Neverland did Mr. Jackson speak to you in 10 such terms, tell you you were like family to him or 11 like a son to him? 12 A. I couldn’t tell you. 13 Q. Did he ever have a conversation with your 14 mother of that nature, tell your mother that he 15 considered her to be like family to him as well? 16 A. Wouldn’t have a clue. 17 Q. That was never done in your presence? 18 A. Possibly. I don’t remember. 19 Q. Did your mother ever have a conversation 20 with him about anything in your presence? 21 A. Quite possibly. 22 Q. Is it the case that when you were kids and 23 running around Neverland, on occasion you would get 24 fairly rowdy? 25 A. Nope. 26 Q. You were always fairly well disciplined and 27 behaved? 28 A. I was brought up right. 9201 1 Q. How about the other kids who were at 2 Neverland while you were there? 3 A. As far as I remember, yeah, we were all 4 pretty -- there were a couple maybe, but I never 5 really saw an outbreak. 6 Q. You never saw what? 7 A. An outbreak. 8 Q. An outbreak? 9 Who were the other boys who were there about 10 the time that you were there? 11 A. I saw Mac there, Macaulay Culkin. His -- 12 Levon and Elijah. Frank, Eddie, Dominick -- 13 Q. How old was Frank at the time? 14 MR. MESEREAU: Objection. He hasn’t 15 finished his answer yet, Your Honor. 16 THE COURT: Sustained. 17 Q. BY MR. ZONEN: Go ahead. 18 A. Aldo. Marie Nicole. My sister, of course. 19 That’s all I really remember. 20 Q. Of the ones that you’ve mentioned, how many 21 of them shared Michael Jackson’s bedroom while you 22 were there? 23 A. All of them have. 24 Q. Did -- all of them? 25 A. I’m pretty sure. 26 Q. On how many nights do you think, all at the 27 same time? 28 A. Not at the same time, because like one trip 9202 1 we’d see -- we saw Mac, and the other trips we saw 2 everyone else. 3 Q. And would they share the same bed with you 4 and Mr. Jackson? 5 A. I can’t honestly recall that. 6 Q. Do you remember any of those people who you 7 just mentioned sharing a bed with Mr. Jackson in 8 your presence? 9 A. Yeah. 10 Q. Who? 11 A. Mac. 12 Q. Macaulay Culkin? 13 A. Yeah. 14 Q. Who else? 15 A. Frank. 16 Q. Frank Cascio? 17 A. Yeah. 18 Q. How old was Frank Cascio at the time? 19 MR. MESEREAU: Objection. He hasn’t 20 finished his answer yet. 21 THE WITNESS: Eddie. 22 THE COURT: I can’t tell if he has or not. 23 Have you finished your answer? 24 THE WITNESS: No, I haven’t. 25 THE COURT: Go ahead. 26 THE WITNESS: Eddie. That’s probably -- 27 that’s all I can recall. 28 Q. BY MR. ZONEN: “Eddie” is Eddie who? 9203 1 A. Cascio. 2 Q. That’s Frank’s brother? 3 A. Yeah. 4 Q. How old was Frank at that time? 5 A. Wouldn’t be able to tell you. 6 Q. Well, was he a child? 7 A. I never knew him as a child. He’s -- he’s 8 older than me, so.... 9 Q. You only know Frank Cascio as an adult? 10 A. No. He’s like a year older, two years older 11 than me. 12 Q. You said you never knew him as a child? 13 A. Well, as a child, I consider to be under the 14 age of 10. 15 Q. How about as a young teenager? 16 A. Yeah. 17 Q. So you saw him there as a young teenager? 18 A. Yeah. 19 Q. Would he share Michael Jackson’s bed as 20 well? 21 A. If I recall correctly, yeah. 22 Q. And Eddie, how old was Eddie during that 23 time? 24 A. Like he’s -- it would have been a young 25 teenager as well. 26 Q. What’s the longest period of time that any 27 of those people stayed in Michael Jackson’s room 28 while you were there? In other words, how many 9204 1 consecutive days did that happen? 2 A. Can’t recall properly. 3 Q. Did Michael Jackson ever tell you that he 4 loved you? 5 A. Yeah, all the time. 6 Q. Did he ever touch you? 7 A. In what manner? 8 Q. Did he ever kiss you? 9 A. On the cheek, on the forehead, yeah. 10 Q. Often? 11 A. I wouldn’t say often, but, yeah. I’ve -- 12 I can’t really remember these things. It’s not 13 something that would -- you know, I would try to 14 remember. 15 MR. ZONEN: I have no further questions. 16 MR. MESEREAU: I have no further questions, 17 Your Honor. 18 THE COURT: All right. Thank you. You may 19 step down. 20 I think we’ll start the next witness 21 tomorrow. 22 (To the jury) I’ll see you tomorrow at 23 8:30. Remember the admonition. Have a good 24 evening. 25 (The proceedings adjourned at 2:30 p.m.) 26 --o0o-- 27 28 9205 1 REPORTER’S CERTIFICATE 2 3 4 THE PEOPLE OF THE STATE OF ) 5 CALIFORNIA, ) 6 Plaintiff, ) 7 -vs- ) No. 1133603 8 MICHAEL JOE JACKSON, ) 9 Defendant. ) 10 11 12 I, MICHELE MATTSON McNEIL, RPR, CRR, CSR 13 #3304, Official Court Reporter, do hereby certify: 14 That the foregoing pages 9016 through 9205 15 contain a true and correct transcript of the 16 proceedings had in the within and above-entitled 17 matter as by me taken down in shorthand writing at 18 said proceedings on May 5, 2005, and thereafter 19 reduced to typewriting by computer-aided 20 transcription under my direction. 21 DATED: Santa Maria, California, 22 May 5, 2005. 23 24 25 26 27 MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304 28 OFFICIAL COURT REPORTER 9206