JACKSON V AEG LIVE August 5

th
2013
Important Notice:- This week will be the last week of transcripts as donations have run out, if you want
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Michael LaPerruque(MJ Security)
Judge: Good morning. You May be seated. And Mr. Laperruque, you May take the witness stand. And you
understand you're still under oath?
Witness: Yes, your Honor.
Judge: You May continue cross-examination.
CONTINUED CROSS EXAMINATION OF MICHAEL LAPERRUQUE BY MS. CHANG
Ms. Chang: Thank you, your Honor.
Q. Good morning, Mr. Laperruque.
A. Good morning, Ms. Chang.
Q. As a refresher, on Thursday we were discussing the first period that you worked with Mr. Jackson, the
2001 to 2004 period. Do you recall that?
A. Yes.
Q. And those, you indicated, were particularly difficult years for Mr. Jackson, correct?
A. Yes.

Q. And also very busy years, correct?

A. Yes.
Q. And we were going through some of the things that Mr. Jackson was working on while you were with
him, and I just wanted to continue with that. You testified on Thursday that when you first came on board with
Mr. Jackson, he was in the middle of shooting a short film at Universal Studios. Do you recall that?
A. Yes.
Q. And was that the "You Rock My World" single?
A. Yes.
Q. And that was a single that eventually came out as part of the "Invincible" album, is that correct?
A. I wasn't aware that it was on the "Invincible" album.
Q. Okay. But you saw the film being shot?
A. Yes.
Q. And that starred Chris Tucker, who we saw last week, correct?
A. Yes.
Q. And Marlon Brando?
A. Yes.
Q. Michael Soren Madsen?
A. Madsen, yes.
Ms. Chang: Okay. And I'd like to show a short excerpt from that. That's exhibit 1057.
Ms. Bina: Your Honor, I'm just going to object. This is all beyond the scope of direct examination. We've
seen a number of videos now that are beyond the scope with me.
Mr. Panish: They asked about his physical condition during that period of time. There were numerous
questions --
Judge: Is this going to show Mr. Jackson?
Mr. Panish: Yes. What he was doing during the same period of time.
Judge: Overruled. You May play it.
Ms. Chang: Okay. 1057. (a video clip was played.)
Ms. Chang: I think that's enough.

Ms. Chang: Mr. Laperruque, you were there while this was being videotaped?
A. Some of it, yes.
Q. Okay. And I think we started going into 2002 as a busy year for Mr. Jackson as well?
A. Yes.
Q. You know that in February of 2002, Mr. Jackson's third child, Blanket, was born, correct?
A. Yes.
Q. And do you know if he was excited to be a father again, based on your conversations with him?
A. Yes, he seemed to be.
Q. And later that year in April, he -- do you recall going with him to New York at the Apollo Theater for
president Bill Clinton at the democratic national committee to lodge a campaign for registered voters?
A. Yes.
Q. And you were also there?
A. Yes.
Ms. Chang: And I'd like to show just a snippet of exhibit 1053.
Ms. Bina: Again, I'm going to object. This is beyond the scope, your Honor.
Judge: This May be.
Mr. Panish: No. 2002, Mr. Putnam asked extensive questions about Mr. Jackson's physical condition, not
only in the hotel in Orlando, Florida, but this is to rebut and respond as to how he was doing in 2002, and the
inferences they were trying to create.
Ms. Bina: Well, your Honor --
Ms. Chang: We can do it at a sidebar or in open court, but I think, your Honor, they have throughout tried to
portray Mr. Jackson as someone who was under the influence of drugs and who, through their experts and fact
witnesses, have -- didn't do any work since the "History" tour when in fact he was very productive and making
appearances and doing live performances.
Judge: Okay. Overruled.
Ms. Chang: All right. And so I'd like to just show a snippet of exhibit 1053. (a video clip was played.)
Q. By
Ms. Chang: And I think we've seen "Dangerous" before, but is that the first time you saw "Dangerous"
performed live?
A. No.

Q. You've seen it before?

A. Yes.
Q. All right. Sir, about a month later, did he also perform that same performance at the 50th anniversary,
American Bandstand?
A. Yes.
Q. And that was here in Pasadena, I believe, correct?
A. Yes.
Q. And that was by -- and that was with Dick Clark there, is that correct?
A. Yes.
Q. And you were also there?
A. Yes.
Ms. Chang: Okay. And that is exhibit 1056. I just want to show a snippet of that.
Judge: Can we get a time frame? Because you're representing this occurring between 2001 and 2004, so --
Ms. Chang: This would be May 3rd, 2002, your Honor.
Judge: And the prior one was when?
Ms. Chang: April 24th, 2002.
Judge: And you are adopting those dates?
Witness: Yes.
Judge: All right.
Mr. Putnam: And, your Honor, the last clip was the clip of president Clinton, not Michael Jackson, which
would be hearsay. And this one I would like to see the performance, actually, of Mr. Jackson.
Mr. Panish: We'll go back and play the performance. Why don't we go back?
Mr. Putnam: The performance is at issue, not what people have to say about him.
Judge: Well, overruled. You May continue.
Ms. Chang: We've seen "dangerous." exhibit 1056. (a video clip was played.)
Ms. Chang: Again, Mr. Laperruque, this is the typical reactions from the crowd you saw when you were with
him, is that correct?

A. Yes, that's correct.

Q. And he gave the same performance that he gave before then, correct?
A. Month before --
A. Yes.
Q. -- in "Dangerous"? All right. Mr. Laperruque, later that year, in July of 2002, a movie came out called
"Men In Black II" do you recall that?
A. Yes.
Q. And were you also with him when he filmed his cameo appearance in that movie?
A. Yes, I was.
Q. And you indicated that you knew he liked movies, is that correct? He was kind of like a movie buff?
A. Yes, very much so.
Q. And he enjoyed the first "Men In Black"?
A. Yes, he did.
Q. And that series, Sir, for people who may not know, that starred Will Smith and Tommy Lee Jones as
agents of a government agency that fought aliens or controlled aliens, correct? Or monitored aliens?
A. That's correct.
Ms. Chang: And I want to show a portion of that excerpt there. That's exhibit 1058. (a video clip was
played.)
Ms. Chang: All right. And Mr. Laperruque, did Mr. Jackson have a good sense of humor based on when you
worked with him?
A. Yes, he did.
Q. And even about himself?
A. Yes.
Q. All right.
Judge: And when was this, again? The time frame?
Mr. Panish: July.
Ms. Chang: July 2002, your Honor.
Judge: Okay. Yes, you did.

Ms. Chang: And did you know, Sir, in 2003, Sony released the "Number Ones" album, which I just happened
to find. "Number Ones", is that correct?
A. It appears to be, yes.
Q. Okay. And I want to just briefly comment or talk about, for a brief while, the Florida incident that you
talked about on Thursday. You testified on Thursday with Mr. Putnam that in around 2001 or 2002, Mr.
Jackson was found unconscious in the hallway of his hotel suite, and his children had called 911. Do you recall
that?
A. Yes, I do.
Q. All right. Sir, would you agree, you do not know what caused his condition, correct?
A. That is correct.
Q. You do know, however, that the paramedics were called, correct?
A. Yes.
Q. And as a former Los Angeles county sheriff's department law enforcement officer with 22 years of
experience, would it be fair to say that you've worked with paramedics many times?
A. Yes.
Q. And paramedics have medical training that you do not have, is that correct?
A. That is correct.
Q. And you testified on Thursday that in your law enforcement career, you've seen individuals who have
actually overdosed and were taken to the emergency room, correct?
A. Yes.
Q. And would you agree, Sir, that in those instances, those individuals were assessed by the paramedics,
correct?
A. Yes.
Q. And you know that paramedics are trained to assess patients for drug overdose or signs of over-
medication, correct?
A. Correct.
Q. You've seen them record vital signs?
A. Yes.
Q. You've seen them assess the level of consciousness in a patient, correct?
A. Yes.

Q. You've seen them on occasion look at the people's eyes, correct?

A. Yes.
Q. You've seen them start iv lines when necessary, correct?
A. Yes.
Q. You've seen them assess glucose levels where necessary, is that correct?
A. I don't recall them doing that.
Q. And if necessary, you've seen them take the patient to the emergency room?
A. Yes.
Q. Would that be fair to say? Okay. Now, the paramedics attending to the Disney resort in Orlando come
from the reedy creek fire department. You recall that?
Ms. Bina: Objection. Lack of foundation.
Judge: Overruled.
Ms. Chang: He was there.
Ms. Chang: Do you recall that, Sir?
A. I don't recall the exact name of the paramedic units that came out.
Q. Okay. And would it be fair to say that whatever the entity was of the paramedics that came that day,
would it be fair to say that you never saw their report, correct?
A. That is correct.
Q. You were not in the room when Mr. Jackson was being checked by the paramedics, correct?
A. Correct.
Q. And you know that the paramedics did not take him to the hospital, is that correct?
A. That is correct.
Q. The paramedics did, however, mention to you low blood pressure, is that correct?
Ms. Bina: Objection. Calls for hearsay.
Judge: Sustained.
Ms. Chang: Okay.
Ms. Chang: And, Sir, the paramedics never took him to the hospital, correct?

Ms. Bina: Objection. Asked and answered.

Judge: Overruled.
Witness: That is correct.
Ms. Chang: All right. And this was in Florida, I think we've established that, Orlando, correct?
A. Yes.
Q. Do you recall what the temperature was that day?
A. I do not.
Q. Was it hot and humid?
A. I remember it was warm.
Q. Okay.
A. It's always humid in Orlando.
Q. And, Sir, you don't know when the last time Mr. Jackson had anything to drink or eat prior to that time
period, correct?
A. That is correct.
Q. All right. And, again, you never saw any prescription medicine bottles in his room at that time, correct?
A. Correct.
Q. And you never saw any alcohol bottles, correct?
A. No.
Q. And you never saw any type of drugs?
A. No.
Q. And no physician had been traveling with him or seeing him on that trip, is that correct?
A. That is correct.
Q. And you don't have any knowledge, as you sit here today, as to whether this incident has anything to do
with drug use, is that correct?
A. That is correct.
Q. Okay. Now, however, Sir, during your years with Mr. Jackson from 2001 to 2004, would you agree that
you saw doctors treating Mr. Jackson, some who you thought were good doctors, and some who you thought
were bad doctors? Would that be fair to say?

A. I never saw the doctors actually treating Mr. Jackson.

Q. Oh, I'm sorry.
A. I would take him to see the doctors.
Q. Okay. Let me rephrase that. I think that's a good point. You saw doctors with Mr. Jackson, some who
you thought were good, and some who you thought were bad? Would that be fair to say?
Ms. Bina: Objection. Lacks foundation as to his ability to judge doctors.
Judge: Sustained.
Ms. Chang: Okay. Well, would you agree, Sir, that whenever you saw a new doctor with Mr. Jackson, that
would give you and Grace Rwaramba, who you'd spoken to frequently and worked with, the nanny, cause for
concern?
Ms. Bina: Objection. Calls for hearsay as to what Grace's statements were.
Ms. Chang: I didn't ask what Grace's statements were.
Ms. Bina: Well, you said --
Ms. Chang: Let me rephrase the question.
Judge: Sustained.
Ms. Chang: Sir, would you agree that whenever you saw a new doctor with Mr. Jackson, that would give you
cause for concern?
A. Yes.
Q. And would you agree that sometimes you believed that some of the doctors were awe struck with Mr.
Jackson, rather than watching out for the best interests of the patient?
A. Yes.
Q. And one of those doctors would be Dr. Alex Farshchian. Would that be fair to say?
A. Yes.
Q. You thought he was awe struck, correct?
A. Yes.
Q. And you thought that awe-struck doctors, like Dr. Farshchian, sometimes over-prescribed medications to
Mr. Jackson, true?
Ms. Bina: Objection. Lacks foundation since he never saw any of these doctors treat him.
Judge: Sustained.

Ms. Chang: All right. Did you ever raise concerns to Dr. Farshchian that you believed he over-prescribed
medications?
A. Yes.
Q. Okay. And Dr. Farshchian went to travel with Mr. Jackson as a friend to be where he was, correct?
Ms. Bina: Objection. Lacks foundation.
Judge: I'm not -- it's a little vague.
Ms. Chang: I'm sorry. Yeah.
Ms. Chang: Dr. Farshchian would often want to travel with Mr. Jackson as a friend, correct?
Ms. Bina: Objection. Calls for speculation.
Judge: Sustained.
Ms. Chang: When Dr. -- you testified on Thursday that Dr. Farshchian often accompanied Mr. Jackson and
you all on certain trips, correct?
A. Correct.
Q. Would you consider that more of a social kind of call versus a medical kind of call, based on the
interaction you saw?
Ms. Bina: Again, I'm going to object. Lack of foundation since he said he had no idea what doctors were
doing with Mr. Jackson.
Judge: Overruled. What he observed. Overruled.
Witness: It appeared, to me, that not only did the doctor accompany Mr. Jackson, it would be for both
reasons, to have a medical person with him. But there seemed to have been a social relationship between Dr.
Farshchian and Mr. Jackson.
Ms. Chang: And, for example, when he went to Berlin with Mr. Jackson when Mr. Jackson received the
Bambi award, was that more to be socially versus medically?
Ms. Bina: Your Honor, I'm going to object. It's lack of foundation whether the trip was more social than
medical. I don't think there's a foundation that this witness knows that.
Judge: Yeah. Sustained.
Ms. Chang: All right.
Ms. Chang: Sir, there are some times that you saw, for example, Dr. Farshchian extend social invitations to
Mr. Jackson just to stay at his house to visit him and his friends and family, is that correct?
A. Yes.
Q. And in fact, Mr. Jackson did go with him to his house and stay with him, correct?

A. Yes.
Q. And during that time period, you didn't witness him treating Mr. Jackson, correct?
A. No.
Q. From 2001 to 2004, Sir, would you agree that he went through -- Mr. Jackson went through a lot of pain,
stress and anxiety during those years that the normal person did not have to endure?
Ms. Bina: Objection. Vague.
Judge: Sustained.
Ms. Chang: Well, Sir, you indicated that those were very difficult time periods, including the criminal
charges, is that correct?
A. Yes.
Q. All right. And you mentioned back pain before on Thursday. Were you aware, Sir, that two years before
you started working with him, that he had sustained a bridge collapse in which he sustained a back injury?
A. Yes.
A. Bridge collapsed, and he fell.
Q. All right. And have you ever worked for or known anyone else who had been dancing and performing
since the age of five?
A. No.
Q. Were you ever personally aware of what kind of skin treatments were required for his treatment of the
vitiligo?
A. No.
Q. Were you ever aware of the kind of treatments required as a result of the burns that he had sustained on his
head from the Pepsi commercial?
A. No.
Q. Would you agree, Sir, you have never been in Michael's shoes, so to speak, and you did not know that the
prescription drugs that were being given to him were needed or unneeded?
A. That is correct.
Q. And, Sir, you came back and worked with Mr. Jackson in 2007, all the way up to the beginning part of
2008, is that correct?
A. Yes.

Q. And as of 2007 and the beginning of 2008, within that time period, Sir, you had never heard of Dr.
Conrad Murray before, correct?
A. That is correct.
Q. And you never met him at all, is that correct?
A. That is correct.
Q. Sir, you testified on Thursday that you were concerned that Mr. Jackson's use of prescription drugs could
result in his overdosing. Do you recall that?
A. Yes.
Q. And the reason for that is because you had stated that you had seen individuals overdose in your law
enforcement career, correct?
A. Correct.
Q. Would it be fair to say that during the years you worked for Mr. Jackson, you never saw him overdose?
A. That is correct.
Q. You never had to bring him into the emergency room as a result of an overdose, correct?
A. Correct.
Q. You were concerned when he displayed symptoms of being medicated, such as slurred speech and acting
sluggish, is that correct?
A. Yes.
Q. And when you grew concerned, even though he was your boss, and you did work for him, you took your
own steps to talk to doctors about his condition, is that correct?
A. Yes.
Q. You talked to Dr. Savage in San Francisco?
A. Yes.
Q. You told him about the symptoms you saw, correct?
A. Yes.
Q. And you also talked to Dr. Farshchian in Florida, correct?
A. Yes.
Q. And you indicated to Mr. Putnam that you also talked to Grace Rwaramba, the nanny, is that correct?
A. Yes.

Q. And you and Grace worked closely together? Is that fair to say?
A. Very closely together.
Q. Okay. And would it be fair to say that you and Grace even tried to develop your own system to dissuade
the bad doctors from over-prescribing medications to Mr. Jackson?
A. Yes.
Q. And that included trying to keep them away from social visits with Mr. Jackson, correct?
A. Yes.
Q. And that included trying to let them know that they were being carefully watched? Would that be fair to
say?
Ms. Bina: I'm going to object to the extent this calls for hearsay as to what Ms. Rwaramba was saying and
doing. Obviously, the witness is free to answer as to his own, but to say Ms. Rwaramba --
Ms. Chang: I can rephrase it.
Ms. Chang: You had a system in which you let the bad doctors know that they were being carefully watched?
Would that be fair to say?
A. Yes.
Q. And you tried to protect Mr. Jackson, correct?
A. Yes.
Q. And on your watch, Sir, getting through these very bad years, you kept him safe, correct?
A. I did my best.
Q. All right. And during the time period -- you did talk to us about the symptoms that you saw again, he was
acting sluggish, he was slurring his words. Do you recall those?
A. Yes.
Q. In those years that you worked with him, did you ever see him with a terrible case of the chills that left
him shaking violently and shaking so badly that he couldn't even cut chicken?
A. No.
Q. Did you ever see him exhibit an alarming weight loss?
A. No.
Q. Did you ever hear anyone complain that they could see his heart beating through his chest?
A. No.

Q. Did you ever hear complaints or ever see him with -- exhibit a sudden change of emotional and physical
state that frightened you?
A. No.
Q. Did you ever see him acting lost and paranoid and mumbling to himself incoherently?
A. No.
Q. Did you ever hear him say God was talking to him?
A. No.
Q. And if you had observed any of those things, would you have taken him to a hospital?
A. I would have been very concerned. And if I thought it was something life-threatening, then, yes, I would
have taken him to a hospital.
Q. All right. Or found another doctor for him?
A. Yes.
Q. All right. Now, I want to talk briefly about this intervention that Mr. Putnam raised with you on
Thursday. Other than picking up and dropping off Mr. Jackson at Neverland ranch, you were only called to
Neverland on one occasion, correct?
A. Correct.
Q. All right. And that was when Randy Jackson appeared at the ranch by helicopter, correct?
A. Yes.
Q. And he was by himself, is that correct?
A. There was a pilot.
Q. Oh. Other than the pilot?
A. Yes.
Q. And did Mr. Jackson tell you that someone in his family was coming, and he didn't want to talk to them at
that time period, correct?
A. He said there would be family members coming.
Q. All right. Did he ever use the word "intervention"?
A. No.
Q. Did you ever hear the word "intervention" that day?

A. No.
Q. Do you even know if it was an intervention?
A. I -- no.
Q. Okay. And Randy Jackson, he did not have with him any type of intervention doctor or counselor,
correct?
A. No.
Q. No other family members were there, correct?
A. Correct.
Q. And whatever the meeting was about, it never occurred, correct?
A. That is correct.
Q. All right. And he got back in the helicopter and flew away, is that correct?
A. Yes, he did.
Q. Okay. Now, Mr. Laperruque, after you left the first time period in 2004, would it be fair to say that you
did not see Mr. Jackson again on a day-to-day basis, other than, perhaps, in the -- during the criminal trial in
2005? Would that be fair to say?
A. That's correct.
Q. You do know that he was acquitted on all counts, correct?
A. Yes.
Q. And then you know he left the country, is that correct?
A. Yes.
Q. Would it be fair to say that you never saw him in 2006?
A. That would be correct.
Q. Or the first part of 2007, correct?
A. Correct.
Q. And then you got a call from Grace Rwaramba again in around august of 2007, asking you to come back,
is that correct?
A. She gave me a call saying that she had a message from Mr. Jackson, and if I could meet with her.
Q. Okay. And at that time that she contacted you, you said that you were the head of security for the L.A.
Times, correct?

A. Correct.
Q. And you yourself would not sacrifice that job if you thought Mr. Jackson abused prescription drugs,
correct?
A. Correct.
Q. And when you met with Mr. Jackson, would you agree that he was energetic and enthusiastic and not
under the influence of any type of sedative that you could see?
A. That would be correct.
Q. He seemed to have a clear plan of what he wanted to do?
A. Yes.
Q. And that included continuing with his music and directing movies?
A. Yes.
Q. And based on your conversation with him, you wanted to go with him on this journey, correct?
A. Yes, I did.
Q. And in the months that you worked with him in 2007, up to 2008, you never observed any problems with
him during -- regarding prescription drugs or doctors? Would that be fair to say?
A. That is correct.
Q. And there wasn't a doctor hanging around, correct?
A. Correct.
Q. Now, Mr. Putnam raised with you some questions regarding why you left, and the financial difficulties.
Do you recall those questions?
A. I do.
Q. Sir, with respect to you not getting paid, do you have any idea of who was in charge of handling Mr.
Jackson's finances at that time?
A. Yes.
Q. And who was that?
A. At that time it would have been Raymone Bain.
Q. Okay. And did you know that Ms. Bain, Raymone Bain, had become Mr. Jackson's manager in 2006?
A. I didn't know that she had become the manager in 2006. I just knew that she was the manager at that time.

Q. Okay. You knew that before then, in your earlier years, she was Mr. Jackson's publicist?
A. I had heard that, yes.
Q. Okay. And you testified on Thursday that it was Mr. Jackson's production company that wasn't paying
you for your services. Do you recall that?
A. Yes.
Q. All right. And that's MJJ productions? Is that fair to say?
A. I believe so, yes.
Q. And were you aware, Sir, that for the years from 2006 to 2007, Raymone Bain was the president and chief
operating officer of MJJ productions?
Ms. Bina: Objection. Lacks foundation.
Ms. Chang: I asked, "were you aware of that?"
Judge: Overruled.
Witness: I didn't know what her exact title was. I knew that she signed a contract. I thought she was the
president of the company.
Ms. Chang: Okay. You received correspondence from her, in other words?
A. Correct.
Q. Okay. And she was the one that you talked to regarding your payment and your checks?
A. Correct, yes.
Q. All right. And -- did you get the sense, when you came back on in 2007, that there was some transition
going on as she was transitioning in and out of her role at MJJ productions?
A. No.
Q. Do you know when she was terminated?
Ms. Bina: Objection.
Witness: No.
Ms. Chang: Okay. And would it be fair to say that after that, Londell Macmillan took over?
A. Yes.
Q. Okay. And, Sir, do you -- you had no idea, did you, Sir, if this payment issue that you experienced had
anything to do with mismanagement or lack of funds? Would that be fair to say?
A. Correct.

Q. And you had no idea what Mr. Jackson's financial circumstances or net worth was at that time? Would
you agree?
A. I would agree.
Q. Now, on Thursday with Mr. Putnam, Sir, you testified that when Mr. Jackson moved to Las Vegas,
Raymone Bain told you to stand by and that you never heard from her or Mr. Jackson again and never got a
return call, is that correct?
A. Correct.
Q. Sir, would you agree that you did receive a call from Raymone Bain telling you that Michael had no need
for security, and he wasn't going to be doing anything?
A. Yes.
Q. All right. Now, Sir, on Thursday you were also asked by Mr. Putnam about the last time that you saw Mr.
Jackson. Do you recall that?
A. Yes.
Q. You testified, Sir, that, to the best of your knowledge, it was about two weeks before he passed away. Do
you recall that?
A. Yes.
Q. Sir, do you recall that where you saw Mr. Jackson was at what they called an anniversary party, and it was
a family event at the Chakra Indian restaurant in Beverly Hills on Doheny drive?
A. Yes.
Q. Okay. Now, Mrs. Jackson testified that the event occurred in May of 2009. Do you have any reason to
dispute that date?
A. Not at all.
Q. Okay. And just to be clear that we're talking about the same event, I want to show exhibit 1-1, which is in
evidence already (indicating). And this is -- I think that's Janet in the front. That's who you were there for, is
that correct?
A. She had hired myself and some other security personnel to provide security at the -- for the event.
Q. And we see Mr. Jackson, Mr. Michael Jackson, in the second row, and this is at the Chakra restaurant, is
that correct?
A. Yes.
Q. And you see there "May 2009" in the corner there?
A. Yes.

Q. Okay. Does the date May 14th, 2009, sound about right to you?
A. Yes.
Q. Okay. And if it was on that date, Sir, would you agree that that was more than a month before Mr.
Jackson's death on June 25th, 2009, and not two weeks before his death?
A. I would agree.
Q. Okay. And more than a month before his death, Sir, would you agree he was thinner than you had ever
seen him before?
A. Yes.
Q. And you did not see him again for the rest of the month of May, correct?
A. Correct.
Q. You never saw him during the month of June, correct?
A. Correct.
Q. I want to show you exhibit 8-54, which is already in evidence (indicating). And I'll represent to you, Sir,
that this is a photo that was taken on June 19.
Ms. Bina: Your Honor --
Ms. Chang: Sir, when you saw him last time --
Ms. Bina: -- I'm going to object to asking any questions of this photo. There's no foundation for this witness.
He testified the last time he saw Mr. Jackson was in May.
Ms. Chang: Well, it's in evidence. I was going to ask if he appeared like this --
Judge: Overruled.
Ms. Chang: Sir, at the time that you saw him, he did not look anything like this picture in exhibit 8-54, is
that correct?
A. Correct.
Q. And if he had, you would have been alarmed, correct?
A. Yes.
Ms. Chang: All right. We can take that down.
Ms. Chang: Now, Sir, based on your years with Mr. Jackson, your total years that you worked for him, would
you describe him as a kind and gentle person?
A. Yes.

Q. And did he have a rule while you worked for him that all of his staff, including you as security personnel,
also had to be kind?
A. Yes.
Q. And did the fact that he was one of the most famous people in the world ever affect the way he treated
others, including you?
A. Not at all.
Q. Did you find him to be a charitable person?
A. Yes.
Q. And in just the little over three years that you worked for him, can you give us examples of what you
recall with respect to his charity?
A. I knew that he gave thousands of dollars to the United Way. Also, there was an incident while we were in
Florida. There was a women's shelter in Hollywood, Florida. It was around Christmastime. He asked me to go
to the toys"r"us to purchase as many toys and -- from teenage to baby toys. And what he wanted to do was to
give those presents to the children at the women's shelter. So another security personnel and I went to
toys"r"us, bought thousands of dollars worth of toys. Mr. Jackson was going to accompany us, but he decided
later to decline making the appearance. He didn't want to turn it into a media spectacle or anything like that, so
we went and donated that to the women's shelter.
Q. Okay. And were you with him when he would just drive around and see people who were in need and
would just give them money?
A. Yes.
Q. He actually stopped cars and made you get out and give some money to someone?
A. Yes. He learned that from his mother.
Q. Is that what he told you?
A. Yes.
Q. Now, during your years with Mr. Jackson, did you have occasion to observe Mr. Jackson with his mother,
Katherine Jackson?
A. Yes.
Q. How would you describe that relationship?
A. It seemed to be a very good relationship.
Q. And did he talk often about his mother?
A. Not often.
Q. But did he talk about, for example, what she taught him?

A. Yes.
Q. And based on your observations and conversations with him, did he love his mother?
A. Yes.
Q. And based on your observations when you saw them together, did she love her son?
A. Yes.
Q. And certainly, Sir, during the years that you worked with Mr. Jackson, you had the opportunity to observe
him with his three children, is that correct?
A. Yes.
Q. And that's Prince and Paris first, and then Prince, Paris and Blanket? Would that be fair to say?
A. Correct.
Q. And how would you describe their relationship with their father?
A. Excellent.
Q. And what do you mean by that?
A. It was a very loving relationship. They wanted to be with their father, and I think Michael was at his
happiest when he was with his children.
Q. Did he -- however, because he was Michael Jackson, did he spoil them rotten, that you saw?
A. Not at all.
Q. When you all went to toy stores, did he let them get whatever they wanted, or did he restrict them to one
thing?
A. He restricted them to one present and one present only.
Q. What did he tell them about that one present?
A. He said for them to choose the present they really, really wanted, and that would be their present at the toy
store.
Q. And that would be even if they were with other families that were just throwing tons of presents in their
carts, is that correct?
A. That is correct.
Q. He wanted them to really make sure they thought about what they wanted and get what they truly wanted?
A. Yes. And not only that, he would also push them towards educational-type toys. Books, toys that they
could learn from.

Q. And based on your years working with him, did you get the idea that he wanted to be remembered as the
greatest entertainer in the world or the greatest father?
A. I would say the greatest father in the world.
Q. Was that important to him, being a father?
A. Very important.
Q. Was he always kind and gentle and patient with his children?
A. Yes.
Q. And is that one of the things that you remember the most about Mr. Jackson?
A. Yes.
Ms. Chang: All right. Thank you, Sir.
Witness: You're welcome.
Judge: Redirect?
Mr. Putnam: Thank you, your Honor.
REDIRECT BY MR. PUTNAM
Q. Good morning, Mr. Laperruque. How are you?
A. Good, Sir. How are you?
Q. I just have a couple quick questions, if I may. We saw a lot on Thursday and then today. Videos of
performances, movies, videos, small films. You saw all of those, correct?
A. Yes, Sir.
Q. And you were there when all of those were shot, correct?
A. I believe most of them, yes.
Q. And that's between 2001 and 2004?
A. Yes.
Q. All right. And that's the same time period in which you received those approximately 30 calls late at night
where Mr. Jackson seemed intoxicated or otherwise out of it, correct?
A. Yes, Sir.

Q. And that's the same period of time when you went to his hotel room, you said, at least 15 times to try to
help him when he said he wanted you to come to his room?
A. Yes, Sir.
Q. And that's the same period of time where you would have to take him sometimes out of meetings because
he seemed intoxicated and on drugs, correct?
A. Yes, Sir.
Q. And that's the same period of time where you understood, from your conversations with Mr. Jackson, that
he was really trying to fight the addiction that he had, correct?
A. Yes, Sir.
Q. And that's also the same period of time where he called you up and told you that he wanted you to come
up to Neverland to make sure that his family couldn't get onto the estate to see him?
A. Yes, Sir.
Q. That's all within the same time period of 2001 to 2004?
A. Yes, Sir.
Q. And during that time period, these were all what I would call private moments. Publicly, did you ever see
him in any way not able to go perform or not able to go do what he had to do professionally because of his
intoxication or drug use?
A. No.
Q. And then when it comes to 2007, a little later when you worked with him, you didn't see any of these
issues, is that correct?
A. That is correct.
Q. And then one other question. You mentioned on Thursday that you went to this 60th anniversary party at I
think it was an Indian restaurant, is that correct?
A. Yes. It was Chakra's.
Q. And did I understand you correctly to say that Ms. Janet Jackson had rented out the restaurant?
A. Yes.
Q. So there were no other customers there, correct?
A. That is correct.
Q. Did you tell me that, nonetheless, Mr. Jackson also had a separate private room where you met him?
What were you talking about there?

A. In my course of employment with Mr. Jackson, we always made arrangements where he would have what
we called a down room, a private room, where he could go off to the side, and -- whether it was a green room or
some other type of room. Within that restaurant, there were -- there was the main restaurant, but there were also
private -- I would imagine private dining rooms. So I had reserved one of those rooms for Mr. Jackson to go
into, just because I knew that's what he usually did. So that was the room that I met him in.
Q. Even at a family function?
A. Even at a family function, yes.
Q. And that's where he went immediately when he arrived, and you talked to him before he went and then
joined his family at the event?
A. He came in, and he saw me standing at the side of the restaurant. There was a back entrance, a small
hallway that went towards the kitchen area. And he saw me standing in the restaurant area, so that's when he
first came up to me.
Mr. Putnam: Okay. I have no further questions. Thank you.
Ms. Chang: I just have two.
RECROSS-EXAMINATION BY MS. CHANG
Q. Mr. Laperruque, you only saw a family member come to the ranch on one occasion, correct?
A. Yes.
Q. And, Sir, you indicated that he was always able to perform and do what he had to do professionally,
correct?
A. Yes.
Q. And if there was ever a time that he couldn't do what was expected of him and get up on the stage and sing
and dance, that would be a huge, red flag for you, wouldn't it?
A. Yes.
Ms. Chang: Thank you, Sir.
Mr. Putnam: Nothing further, your Honor.
Judge: Anything else? Okay. Thank you, Sir. You May step down.
Witness: Thank you, your Honor.