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vs.
Defendants.
1
ich
CONFIDENTIAL
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VIDEOTAP$D DEPOSITION OF
JOLIE LEVINE
10:18 A.M.
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Jilio-Ryan Court Reporters
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Levine, Jolie
Robson v. MJJ Productions, INC.
10:20:14 1
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JOLIE LEVINE,
10:20:14
ily
5
13 EXAMINATION
14
7
Jilio-Ryan Court Reporters
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Levine, Jolie
Robson v. MJJ Productions, INC.
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04:05:15 1 A Yes.
3 Norma 3taikos?
6 A No.
11 easier.
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12 THE VIDEOGRAPHER: Off record, 4:05.
04:06:45 15 p.m.
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16
17 EXAMINATION
18
19 BY MS. MacISAAC:
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23 A Yes.
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04:06:55 25 A Michael.
227
Jilio-Ryan Court Reporters
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Levine, Jolie
Robson v. MJJ Productions, INC.
7 company.
8 BY MS. MacISAAC:
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9 Q And it was your understanding that he
11 A Oh, definitely.
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12 MR. FINALDI: Same objections.
13 BY MS. MacISAAC:
18 BY MS. MacISAAC:
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4 is a -- was a pedophile.
7 A Never.
04:08:07 10 A Never.
13 A Never.
16 times?
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17 A I always packed Michael's room whenever we
04:08:35 20 over 50 times that you packed and unpacked his room?
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21 A At least, yeah.
23 pornography?
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24 A Never.
229
Jilio-Ryan Court Reporters
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Levine, Jolie
Robson v. MJJ Productions, INC.
04:08:45 1 A Never.
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2 Q Did you ever see any photos of children that
4 A Never.
04:09:08 15 Miss Levine receives it, review it, sign it under penalty
16 of perjury.
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17 You can make any corrections you deem
21 credibility.
230
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
vs.
Defendants.
ich
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VIDEOTAPED DEPOSITION OF
GARY HEARNE
10:07 A.M.
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1
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
10:07:55 1
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MR. FINALDI: Vince Finaldi for Plaintiff Wade
2 Robson.
6 GARY HEARNE,
10:08:13 10
11 EXAMINATION
ich
is
13 BY MR. FINALDI:
10:30:37 5 Q Okay.
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6 A And then everything else will flourish in some
7 way and you don't worry about this flower or that leaf or
8 whatever.
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9 Q So is it -- is it a true statement that in your
10:30:51 10 entire life up 'til now, you've never had any type of
13 A Uh-huh.
14 Q -- or a weekend course --
10:30:58 15 A Uh-huh.
19 training.
23 A Yes.
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25
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
10:31.:20 1 A Yes.
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2 Q You worked for one of his companies, right?
4 companies, yes.
11 Q And just --
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12 MR. STEINSAPIR: Were you going to say --
13 THE WITNESS: No. Just, you know, I understand
14 the situation where I'm not supposed to suppose, so I
16 Productions.
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17 MR. FINALDI: Okay. Yeah. That's fine.
18 THE WITNESS: Yeah.
19 BY MR. FINALDI:
21 knoav.
22 A Okay.
23 Q Sometimes I'm --
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24 A Likewise.
26
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
7 A Yes.
10:32:19 10 A Yes.
21 A Yes.
27
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
19 A Uh-huh.
10:33:50 20 Q -- arork?
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21 A Yes.
23 right?
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24 A Uh-huh.
22 A Yes.
24 professional driver?
.
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
11:40:09 1 A Yes.
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2 Q -- taught kids as well?
3 A Pardon me?
7 A Seldom.
11:40:30 10 A No.
13 A Correct.
11:40:38 15 for that job there, did you ever have any training on
11:40:59 20 right?
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21 A That's right.
24 Staikos.
72
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
4 interviear?
7 Q Okay.
13 driving record?
24
73
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
3 A Correct.
11:42:54 10 A No.
14 duties.
16 job duties?
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17 A No. I think the purpose of me meeting Mr.
21 Q Okay.
22 A And --
24 A No.
11:43:19 25 Q Okay.
74
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
3 A No.
8 A No, no.
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9 Q No?
11:43:31 10 A No.
14 A Yes.
21 with Norma the next day. And she was telling me more
24 now, do you want me for the job? And she said, Qh, yeah,
75
11:44:23 1 Q Okay.
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2 A So that was sort of how the offer came about.
13 A Correct.
11:45:01 15 A Yes.
11:45:12 20 drivers?
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21 A No.
24 A No.
76
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
02:30.:27 5 Q Okay.
ily
6 A -- just like when you're talking to someone and
7 maybe there are other people there and you stand. And I
8 think a few times I was kind of -- you know, we would go
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9 to a meeting or something and I'd open the door for
02:30:40 10 Mr. Jackson and I'd sometimes put my hand, you know,
13 Q Okay.
14 A Yeah.
16 A Kids, right.
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17 Q Are you saying this is the vvay you saw him
18 touching kids?
02:31:23 25 memory.
166
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
02:31:24 1
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Q Okay. Why would you have remembered that?
2 A Because it would -- I think for the same reason
3 I would have remembered it if I saw any adult touching a
6 It's --
167
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
24 and answer.
02:34:08 25 THE WITNESS: As I recall, the way the protocol
168
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, INC.
02:34:14 1 was that when I, you know, pushed the little button
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to
2 say that I was here with Mr. Jackson, I would also say
4 BY MR, FINALDI:
02:34:26 5
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Q Yeah.
6 A Yeah.
13 Q Okay.
14 A But not with him because, you know, he's -- he
02:34:46 15 was the owner of the place. And I think -- anyway, I
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16 would get into all kind of speculations as to why, but
17 rrat- ~~ __
23 A 15 years.
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169
Jilio-Ryan Court Reporters
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Hearne, Gary
Robson v. MJJ Productions, iNC.
02:35:23 5 Q
ily
I'm asking did you ever tell him no? Him ask
6 you to do something or tell you to do something and you
7 said no?
8 A No. None.
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9 Q Never?
02:35:30 10 A No such time that I can remember and I think if
02:35:44 15 have.
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16 Q Do you remember ever hearing anyone tell
17 Michael Jackson no?
22 Q Okay.
23 A -- any-such time.
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24 Q Alrighty.
02:36:10 25 MR. STEINSAPIR: Can we take a break?
170
Defendants.
ich
ae
CONFIDENTIAL
1
Jilio-Ryan Court Reporters
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Goforth, Gayle
Robson v. MJJ Productions, INC.
22 GAYLE GOFORTH,
23 A WITNESS HEREIN, BEING FIRST DULY SWORN, WAS
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4
Jilio-Ryan Court Reporters
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Goforth, Gayle
Robson v. MJJ Productions, INC.
14:20:16 1 A.
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Naked kids, no. They were all like statues. He
14:20:21 2 had several statues in the home.
14:20:2.4 3 Q. Of kids and things?
14:20:26 4 A. Kids, but not naked. Like cherub-type things.
14:20:31 5
ily
Q. Bronze statutes of kids all over the property,
14:20:37 6 right?
14:20:38 7 A. Yes. But they had clothes on and there was like
14:20:45 8 cherub kids.
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14:20:57 9 MR. FINALDI: Okay. I am going to hand over the
14:20:58 10 questioning to check over my notes, but I think
2 am
14:21:03 11 pretty close to being done.
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14:21:05 12 MR. LISKIN: Why don't we take a 10-minute
14:21:07 13 break.
14:21:07 14 THE VIDEOGR.APHER: The time is 2:21 p.m. We are
14:21:10 15 now off the record.
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14:21:13 16 (Break taken.)
14:28:21 17 THE VIDEOGRAPHER: We are back on the record.
14:28:47 18 The time is 2:29 p.m.
14:28:50 19 MR. LISKIN: Good afternoon, Ms. Goforth.
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14:28:53 20 THE WITNESS: Good afternoon.
14:28:55 21 MR. LISKIN: Thanks for your time today.
14:28:57 22 THE WITNESS: Thank you.
14:28:57 23 EXAMINATION
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172
Jilio-Ryan Court Reporters
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Goforth, Gayle
Robson v. MJJ Productions, INC.
14:29:33 15 A. Yes.
14:29:55 22 A. Yes.
14:29:59 24 you say that more often than not, Michael was not even
173
177
Jilio-Ryan Court Reporters
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