Michael Jackson Mexico Deposition 1993

Original video was removed ..  Here’s another version ..

NOTICE the transcrition below was done from the two videos posted above that have now been removed by Web Sheriff. We have found another video with Spanish subtitles- to follow along with the transcript.

We very much appreciate the dedication of our transcriptionist (who wishes to remain nameless) who labored many hours with the love of Michael in her heart to bring this 93 transcript of this video deposition of Michael Jackson  to the MJGlobal family.

Atty 2:            Howard Manning, Co Council for Plaintiff’s as well

Atty 1:            Will you administer the oath please.

Will you raise your right hand please.  Do you swear the testimony you are about to give and now under your consideration shall be the truth, the whole truth and nothing but the truth so help you God?

MJ:            Yes.

Atty 1:            Mr. Jackson, what is your occupation?

MJ:            Entertainer, dancer, singer, songwriter.

Atty 1:            How long have you been an entertainer?

MJ:            Since the age of 5.

Atty 1:            Without going into too much detail could you tell me how you started as an entertainer?

MJ:            Well, singing around the house, dancing, making noises, you know, sounds. Making my own rhythms, making my own music. Singing, you know that type of thing.

Atty 1:            Do you remember how old you were when you started performing professionally?

MJ:            Maybe 10 years old.

Atty 1:            What was the name of the group you performed with when you first started?

MJ:            The Jackson 5.

Atty 1:            Who was the Jackson 5?

MJ:            Marlon, Tito, Jackie, Jermaine and Randy.  That’s it.

Atty 1:            At some point did you become a solo performer?

MJ:            Yes.

Atty 1:            Do you remember when that was?

MJ:            Well I did solo work before, songs like Ben, Got to be There, Rockin’ Robin, I Wanna Be Where You Are.  All these are solo songs while still with The Jackson 5. Not meaning I’d left the group.

Atty 1:            You say one of your professions is a songwriter, when did you start writing songs?

MJ:            I started writing songs, gee as young as, I’d say eight years old. Eight or Nine.

Atty 1:            Have you had songs that you’ve written and recorded?

MJ:            Some, yes.

Atty 1:            About how many songs that you have written have been released?

MJ:            Oh boy, I’ve never counted.  Probably over 30 – 40.

Atty 1:            Again, without going into too much detail, have you ever won any awards?

MJ:            Lots of awards.

Atty 1:             Could you give me some of them.

MJ:            Well, Grammy Awards, American Music Awards, NAACP Awards, Black Caucus Awards – there’s all kinds of awards in my field. (clears his throat) Excuse me I know that kills the microphone man (laughing, smiling and pointing)

Atty 1:            You have not been feeling well the last few days.

MJ:            Yes, that’s very true.

Atty 1:            You’ve had some oral surgery?

MJ:            Yes.

Atty 1:            If at any time, you’re not feeling well or uncomfortable, will you let me know and we’ll take a break?

MJ:            I sure will.

Atty 1:            What was the first song that was released that you wrote if you recall?

MJ:            A song called Blues Away on one of The Jacksons albums.

Atty 1:            Do you remember which one it was?

MJ:            I think the album was called either Goin Places or Destiny, I’m not sure.

Atty 1:            You had albums as a solo artist?

MJ:            Yes.

Atty 1:            Can you name them for me please?

MJ:            Ben, Got To Be There, Music and Me, there are a couple of others on Motown but I can’t think of them right now.  There’s Off the Wall, Thriller, Bad, Dangerous.

Atty 1:            Can you recall when the album Off the Wall came out?

MJ:            Seventy something, but I’m not positive.

Atty 1:            Let me see if I can refresh your recollection. I hope this is easy to read if not, we can move on again.

(Hands MJ documents, which MJ reads)

MJ:            ’79.

Atty 1:            Do you recognize the document that I am showing you?

MJ:            Yes.

Atty 1:            What is that?

MJ:            The cover of Off the Wall.

Atty 1:            Did you write any of the songs that were included on the album Off the Wall?

MJ:            Yes.

Atty 1:            Which ones?

MJ:            Don’t Stop Til You Get Enough and Working Day and Night and I co-wrote one with another musician called Get on the Floor.

Atty 1:            Who was that other musician?

MJ:            His name is uhhh – oh boy, I can’t think of his name right now.

Atty 1:            Well that’s okay.  Did the group The Jacksons also do an album called Triumph?

MJ:            Triumph.  Yes.

Atty 1:            Do you recall when that was?

MJ:            No.

Atty 1:            Take a look at this document.

MJ:            I’m pretty bad with dates.

Atty 1:            That’s okay, see if the document I’m showing you refreshes your recollection (Hands MJ documents, MJ reads it) What is the document I am showing you?

MJ:            The Jacksons – it says “Triumph 1980”

Atty 1:            What is that, is that the cassette cover?

MJ:            It’s the cassette cover.

Atty 1:            Mr. Jackson did you write any of the songs that appeared on the Triumph album?

MJ:            Yes.

Atty 1:            Which ones?

MJ:            I co wrote Can You Feel It with my brothers — um, That’s What you Get for Being Polite with my brother — um All Night with my brother, Jack Still I think it’s called with my brother.  I think there’s a couple of others, I just can’t think of the names right now (smiles).

Atty 1:            I’d like to turn Mr Jackson, right now to generally how you write songs. Can you tell me what process you go through when you’re writing a song, if there is a general process?

MJ:            Well the process I go through is — um– songs kind of just come, they create themselves. Like I’ve said before, I’m just the source through which they come and it’s a beautiful thing.  It’s very spiritual. It’s like standing under a tree and letting a leaf fall and trying to catch it, it’s that beautiful and what I do is – it comes into my head – I could be walking along, you know, on a road or I could be sitting on a bench at Disneyland or something eating peanuts (smiles) and there it is, it’s in my head or I could be in the shower or I can wake up, like I did when I wrote We Are The World.  There the song is, it’s right in my head, the entire composition you know. That’s how it happens.

Atty 1:            Once you have the song in your head what do you do next to get the song?

MJ:            I go to a tape recorder and I put the sounds down. Orally, with my mouth, Making sounds of how I want the bass or the strings or the drums or each part to go. The way I hear it, because the key is to get exactly what you’re hearing in you’re head on that tape. (smiles)

Atty 1:            You realize that one of the songs at issue in this lawsuit is a song called The Girl Is Mine?  Are you aware of that?

MJ:            Yes

Atty 1:            Who wrote The Girl Is Mine?

MJ:            I wrote The Girl Is Mine.

Atty 1:            What album did The Girl Is Mine appear on?

MJ:            (Clears his throat and smiles at “microphone man”) Sorry!  That’s The Thriller album

Atty 1:            Was it also released a single?

MJ:            Yes, the first single off of Thriller.

Atty 1:            The lyric?  What’s The Girl is Mine about?

MJ:            It’s about — it’s very simple, it’s two guys kind of quarreling over the same girl, which happens.  “No, she’s mine”, “No, she’s mine”, “No, she loves ME” okay, you know, that type of thing. “She always looks at me” that type of thing and it’s just quarreling over the same girl.  That’s what it’s about.

Atty 1:            How did you get the idea for that?  What you just described?

MJ:            It just came!  It just came!  Quincy said to me “you know write a song that you and Paul McCartney can sing together”  so I guess I went to sleep and when I woke up the next day there it was and I ran to the tape recorder and I started to put down what I heard in my head.

Atty 1:            You mentioned Quincy who is Quincy?

MJ:            Quincy Jones is a producer, songwriter. He’s a really great guy. He’s wonderful, I love him. (Smiles)

Atty 1:            You’ve worked with him before

MJ:            (Big smile) Yes

Atty 1:            When did you first work with Quincy Jones?

MJ:            At first, I’m not positive but I think I was nine years old, yeah I was nine years old and I met him with Sammy Davis Jr. and I was at Sammy’s house and that’s when I first set eyes on him.  I never knew that we would end up working together professionally.  Then we did The Wiz, which was in New York City and then after The Wiz we did an album called Off the Wall.

Atty 1:            The Wiz was a motion picture?

MJ:            Yes – Universal (smiles)

Atty 1:            Now, at some point you made a tape recording of The Girl is Mine, a work tape?

MJ:            Yes.

Atty 1:            I’d like to play for you a document that has previously been marked as Exhibit 489 and what I will do is give this to the reporter after we’re done so that he can hold his custody.  I’ll just play a little bit of it at first Mr. Jackson and ask you to tell me whether you recognize Exhibit 489?  My question is I am going to play Exhibit 489 and again, Mr. Jackson ask you whether you recognize it, I’ll just play a portion of it.

11:40 – 12:01 (A very early demo of The Girl Is Mine is played with Michael only making sounds on the tape and Michael immediately starts to move to it)

Atty 1:            I am going to stop it Exhibit 489 for a  moment and ask you Mr. Jackson whether you recognize that?

MJ:            Yes.  That’s me writing the parts to The Girl Is Mine, creating it. (Clears throat) Sorry!

Atty 1:            What were the circumstances under which you started making Exhibit 489?

MJ:            Well, just a tape recorder there and making sounds like (12:26-12:38 Begins to beatbox The Girl Is Mine)

Atty 2:            Objection, are we can have… is this?

MJ:            (12:38 – MJ begins to sing “Every night she walks right in my dreams, since I met her from the start)

Atty 2:            Objection.  I have an objection

MJ:            Well, that’s how I did it.

Atty 1:            How did you come to, you may have told me already, but I don’t think you did,  how did you come to get the song, the music on Exhibit 489 in mind?

MJ:            Like I’ve said before songs create themselves, they just come out of me. You know, they just come from inside – out and I think I’m just the source through which it comes and you asked me how I created and I started to perform it to give you an example of how it’s done, I’ve how I created songs and when I create my music I make these sounds. I wrote a song called Who Is It

Atty 2:             Objection!

Atty 1:            Do you recall where you were when the song The Girl Is Mine came to you Mr. Jackson?

MJ:            I think I was at the Encino house or a condominium because we were rebuilding the Encino house and staying in a smaller place.

Atty 1:            Let me play for you some more of Exhibit 489 and I’m going to stop it at some point and ask some more questions.

(14:12  Plays The Girl is Mine demo when (14:26) Michael Sings along “the doggone girl is mine

MJ:            Yep, that’s The Girl Is Mine.

Atty 2:            Objection!

(14:34 With tape still playing Michael continues to sing along “the doggone girl is mine”)

Atty 2:            Objection! Is there a question before the witness?

Atty 1:            Would you show us what you were doing on that tape?

MJ:            Yeah.  (14:38-15:06) MJ begins to sing “Every night she walks right in my dreams since I met her from the start, I’m so proud I am the only one who is special in her heart, the girl is mine, the doggone girl is mine (14:57 begins to beatbox) Don’t waste your time, because the doggone girl is mine”

Atty 1:            When you were — you were making some sounds with your mouth.  What was the purpose of that?

MJ:            The sounds are the rhythms that I make. I wrote a song on the Dangerous album called Who Is It? and what I do is I go to a tape recorder and I put down the sounds, the way I’m hearing it in my head, and I’m hearing the bass, I’m hearing the percussion, I’m hearing the drums and the Who is It  lick goes umm (15:35 – 15:46 Michael begins to beatbox Who is It?)

Atty 2:            Objection to strike!   Move to strike!

MJ:            That’s how it’s done so what I do is…

Atty 2:             Objection!

MJ:            I go to a tape recorder and I just put exactly what I’m hearing in my head down on tape, and that’s how I pretty much do it.

Atty 1:            Would you briefly show us how you made the rhythm sounds on The Girl Is Mine tape.

MJ:            Sure!  (16:03-16:13  Michael beatboxes and sings to show how he created The Girl is Mine) Like that!

Atty 1:            I’d like to play….

MJ:            (Singing “The girl is mine”)  Sorry my voice. I’m really hoarse.  I had a concert last night.  My throat is really bad.

Atty 2:            Objection. Move to Strike!

Atty 1:            Now I’ve stopped the tape, you were singing some lyrics but not others, is that right?

MJ:            Pardon?

Atty 1:            You were singing some lyrics but not others.

MJ:            Yes.

Atty 1:            Why was that?

MJ:            Because certain words come into your head at a certain time.  The feeling for the melody umm.. certain words come with the melody at the same time that it’s created. You know (16:54 Michael begins singing Heal the World) I mean I didn’t think about it, it just came. (16:59 Michael continues singing “make it a better place”)  So it came with the melody. “Heal the World” when I thought about it, I thought “that’s nice, heal the world, let’s heal our planet”.

Atty 1:            Let me play some more of Exhibit 489.

(17:12 -17:29:  tape plays of Michael creating The Girl is Mine) Michael hears something and laughs)

Atty 1:            I’ll stop there, you were making some noise where you just laughed. What were you doing there on The Girl Is Mine?

MJ:            I was doing a … I was imitating a Moog bass where you play the bass on a keyboard but you have this little — it’s like a stick where you go (17:45-17:46 Michael makes a sound) like noises like that. (17:46 -17:53 Michael makes more sounds) like that.

Atty 1:            Thank you.

(17:54 -18:00:  Continues to play The Girl is Mine tape and MJ makes some high tones with his voice)

Atty 1:            You’re singing some high notes there.

Atty 2:            Objection!

Atty 1:            What were you singing at that point, right before I stopped the tape?

MJ:            I’m singing what I hear over the chorus, like a string part (18:09 – 18:16 Michael sings the part and then “the girl is mine”)

(18:17: – 18:34  Tape continues to play with MJ singing some random words)

Atty 1:            You just sang… did you just hear some words on the tape?

MJ:            Yeah (pointing), that part of the song I never used.

Atty 1:            Why not?

MJ:            Because it went in another direction and I can tell by listening to that (pointing) where it’s going to go. It’s probably going to go (18:51 – 18:54 sings a melody)  Because that’s where it most likely to go in that direction and I haven’t heard this (points) since then.

(18:57-19:00 exactly the same melody MJ sang is played on the tape)

MJ:            There it is!

(19:01 – 19:08 tape continues to play The Girl Is Mine creation)

 

MJ:            (19:08 – 19:10 Michael sings the same melody along with the tape while it is playing) his hands move up and down as he hits high and low notes)

Atty 2:            Objection. There is no question for the witness!

(19:11 – 19:25 Tape continues to play and Michael smiles)

MJ            19:15 I haven’t heard this in so long (laughing)  19:25 Michael sings along with the tape “the girl is mine, the doggone girl is mine”

(19:15 – 19:55 Tape continues to play)

Atty 1:            What part were you singing just before I stopped the tape?

MJ:            Counter lines, musical counter lines that can go against the main part.

 

(20:06 – 20:08  Michael sings a melody to the Girl is Mine)  Could be a key board, it could be a flute, it could be a string part, it’s like a tapestry of sound which is what the law of music is.

Atty 1:            Continue playing Exhibit 489

(20:23 –  20:38 MJ on tape “now the piano goes like this — it starts off” .. Michael begins to make sounds)

MJ:            Yeah! (smiles)

Atty 1:            What were you doing right there?

MJ            (20:40- 30:42 “da da”) Creating another part that I heard which I did do on the demo which I played myself umm…

Atty 1:            Was there a particular musical instrument that you were… ?

MJ:            It was a piano (20:53 – 20-59 “da da do” and MJ sings melody)  the accenting “da do” like that.

(21:04 -21:20 Exhibit 489 plays)

Atty 1:            Okay I’m just going to play some more of Exhibit 489 Mr. Jackson why don’t you wait for my question.

MJ:            Okay.

(21:26 21:56: Exhibit 489 plays Michael continues to beatbox on the tape and says “strings”)  Michael laughs.

Atty 1:            What did you say right there?

MJ:            Strings.

Atty 1:            And what did you mean?

MJ:            (21:59 – 22:05  Michael begins to sing the melody of the strings)  It’s the part that would go over a verse.  Like a second verse which would climax the song, which would build it.

Atty 1:            Were you imitating a particular instrument when you made that sound?

MJ:            (Nodding) Yes.

Atty 1:            What?

MJ:            Strings.  I even said, I go “strings” (22:22 – 22:23 imitates strings with his voice and begins to laugh)

Atty 1:            I’m going to play more of Exhibit 489.

(22:29 – 22:42 Exhibit 489 is played)

Atty 1:            I am playing more of Exhibit 489

(22:45 – 22:30 Exhibit 489 is played and MJ’s voice says “Piano”)

Atty 1:            What did you just say on the tape?

MJ:            I’m not positive, but I think I said “piano” or something.

(23:07 – 23:10 Exhibit 489 plays)

MJ:            What I’m doing now after creating…

Atty 1:            Let me ask you.. what are you doing now on the tape?

MJ:            Okay (laughs) After creating the melody, I am now creating the different sounds that I want to go with the melody.  What each instrument should do to create the song.

Atty 1:            I will play more of Exhibit 489

(23:27 – 23:58 While beatboxing on the tape, Michael says “strings”)  MJ mouths the word “strings” 23:44  Michael continues to sing the melody on the tape and says “guitar”) Michael laughs

Atty 1:            What were you doing there?

MJ:            Creating a French Horn part which I never used.  (24:04-24:06 MJ sings the part of the French Horn accentuating the instrument as he sings)

Atty 1:            Thank you.

(24:09 – 24:17 while Michael is singing the melody he says “that could be soft horns”)

MJ            See (24:18)

Atty 1:            What did you just say there?

MJ:            I just said “that could be soft horns”

Atty 1:            Continue with Exhibit 489.

(24:26 – 24:57 Michael is singing the melody on tape and then says “and don’t write the song, don’t write anything let the song create itself.”)

(24:59 Michael raises both arms with fists in the air)

MJ:            That’s my law!

Atty 1:            Let me back the tape up slightly.

MJ:            (Speaking softly) That’s what I would say (smiling)

(25:15 – 25:54  Tape continues to play with Michael saying “and don’t write the song, don’t write anything, let the song create itself. Let the strings tell you what to do, where they should come. Let the piano tell you what chords to hit whatever it feels. Let the bass tell you what it should be doing.  Everything. Let it create itself. Let it form.  Let it tdo what it wants to do.  Don’t force upon the song, let the song force upon you. Let it tell you where to go.”)

Atty 1:            What did you mean by what you said on the tape?

MJ:            What I meant was a song creates itself.  I’m just the source through which it comes. It all creates itself. When a song comes to me I’m hearing the strings, I’m hearing the bass, I’m hearing the drums, I’m hearing… everything comes as a package.  It’s like catching a leaf that falls from a tree, it’s the most spiritual, beautiful thing that can ever happen and sometimes I just get on my knees and I pray to God out of thankfulness that it happened, that it came to me and that’s what I’m saying let it create itself (smiles) because it’s trying to create itself.

Atty 1:            I’ll continue with Exhibit 489.

(26:42 – 26:57 Michael says “punchline with a piano feel that goes”  Michael sings a melody and then says “there’s harmony with that – voice harmony” MJ continues to sing)

Atty 1:            What did you say right there?

MJ:            Some type of harmony part on (27:04-27:10 MJ begins to sing “the girl is mine” while singing a melody.)  What I’m trying to do is — what I’m hearing in my head is some type of counter line to build the chorus because in songwriting you should go from the verse to the chorus, and when the chorus comes… it should be like a flower blossoming in your face.  So to build that and make that happen you have to add in other sounds to make it refreshing and wonderful.  So that’s all that is.

Atty 1:            What’s the “bridge” of a song?

MJ:            27:46 – 27:47 Michael sings “I love you more than he”

Atty 2:            Objection!

Atty 1:            I was asking more of a general question.  What is a “bridge”?

MJ:            What is a bridge?  A bridge… what a bridge is it takes you from “A to B”. It’s to take you from the verse to another part. It is escapism from hearing the same mundane, trivial, ordinary thing that you’ve been hearing all the time because the ear gets tired of hearing the same sounds, so what a bridge does it takes you away from all of that.  Then when it finally comes back to do what you were doing before it’s stronger. It’s much stronger. It has a much stronger effect.

Atty 1:            Does the song The Girl Is Mine have a bridge?

MJ:            Yes it does.

Atty 1:            Could you sing that for us?

MJ:            It goes (28:34 – 29:12   “I love you more than he, take you anywhere, and I go but I love you endlessly, loving we will share. So come and go with me to on the town, but we both cannot have her, so it’s one or the other and one day we’ll discover that she’s my girl forever.  Don’t build your hopes to be let down, cus I really feel it’s time that she tell you I’m the one for her”)…that type of thing.

Atty 1:            Let me continue Mr. Jackson with Exhibit 489.  I will ask you a question at some point.

(29:21 – 31:08 Exhibit 489 continues, Michael says on the tape “here’s another bridge part, for instance” 29:29 MJ sings a melody and tries different thingsMichael listens intently to the tape and grins widely, listens and then hears something and shake his head no the exact time (30:07) on the tape that Michael says no and continues singing, trying different things and MJ says on tape (30:44) “there’s a slight change… continues to try different tones and then says (30:54)  “yeah, that’s it)  Michael smiles.

Atty 1:            On the segment that I just played what where you doing in there?

MJ:            Creating.. umm..or discovering I should say cus I try not to invent, I try to discover what’s there and I’m discovering where the song wants to go and it’s the bridge. It’s the bridge of the song and it’s these changes.  It reminds me of a song that I just wrote recently called Stranger in Moscow in Russia and I went through the same thing trying to dictate into a microphone what you’re hearing in your head — it’s very difficult sometime (smiling) because you can’t — you only have one voice but you’re hearing full chords so it’s a very difficult thing to do but you just do your best. (laughs)

Atty 1:            What’s a chord Mr. Jackson?

MJ:            What’s a chord?

Atty 1:            Yes, in music.

MJ:            A chord is harmony, it’s sound that’s pleasant, something that can be pleasant to the ear – music.

Atty 1:            Let me just state for the record that I am playing Exhibit 489 and at some point I will ask you a question about it Mr. Jackson.

(32:37 – 33:01:  Exhibit 489 plays – MJ continues to try different melodies on tape and then he says (32:56) “the chords to the bridge is” and MJ sings the chorus)

Atty 1:            What did you just say there?

MJ:            I’m saying the chords to the bridge. I’m now just bringing out what I think the chords — just defining into my head, what the chords should do to accompany the melody which is very important.

Atty 1:            I will play some more from Exhibit 489.

(33:23 – Exhibit 489 is played – Mj sings trying different melodies) (33:54) MJ says “on this part is” sings a melody “and another part” sings another melody)

Atty 1:            Mr. Jackson what were you doing there?

MJ:            I’m making background sounds, which I did on the demo which is just one of the notes (34:14 MJ sings the sounds)  Just the harmony part.  I think there’s like six different harmony notes and that’s just one of six.

Atty 1:            I’ll play further from Exhibit 489.

(34:35 – 34:45 MJ trying out different harmonies on tape)

Atty 1:            What were you doing there?

MJ:            Same thing. It’s a harmony part that goes against the other harmony I’m creating different notes which are harmonics to go against the music.  I’m creating all the harmonies and all the sounds.  Each individual sound which make up the whole of The Girl Is Mine.

Atty 1:            Play further from Exhibit 489.

(35:07 – 35:35  MJ says on tape “when the song first kicks off, I can hear some horns in the front verse and this is how the music goes”  Michael begins to harmonize again on tape (35:29)  “soft horns” )

Atty 1:            What were you doing there?

MJ:            Creating what I heard at the time umm — french horns, which are soft horns, which I felt should have gone at the time in the beginning of the song. (35:50 – 35:56 Michael begins to sing the horn part) .. that type of thing.

35:59 – 36:09 Exhibit 489 plays.  MJ harmonizing and creating The Girl Is Mine. (Michael touches his mouth)

Atty 1:            What part of the song is it that we just heard?

MJ:            You just heard the bridge.

(36:17- 36:31  Exhibit 489 plays again and Michael begins to hit it and sing “but we both cannot have her, it’s just one or the other”) Michael raises his hand in a fist

MJ:            There it is.

Atty 1:            What did you just hear?

MJ:            There it is, that’ what I was looking for, it’s the fire that builds coming out of the bridge (36:43-36:56 ) Michael sings “But we both cannot have her, so it’s one or the other and one day you’ll discover that she’s my girl forever and ever. Don’t fill your hopes to be let down”  so it’s coming out of the bridge.

Atty 1:            You okay Mr. Jackson, want to take a break?

MJ:            My mouth hurts!

********** break ************

Atty 1:            Mr. Jackson at the break, did you find it necessary to take pain medication?

MJ:            Do I find it necessary?

Atty 1:            At the break did you have to take a pain medication for your tooth?

MJ:            Yes.

Atty 1:            I really quickly want to ask you about a cassette tape that has previously been marked as Exhibit 492, an exhibit that I will give to the court reporter on completion of the deposition or break.  I just want to play a portion of it for you and ask you whether you recognize Exhibit 492

(37:43-40:13:            Exhibit 492 plays – demo with music of The Girl is Mine) MIchael listens.

Atty 1:            I’ll stop it there.  Mr. Jackson do you recognize Exhibit # 492?

MJ:            Yes.

Atty 1:            What is it?

MJ:            That’s my original demo of The Girl Is Mine.

Atty 1:            Does that demo use any of the material that you sung when you created the work tape?

MJ:            Yes.

Atty 1:            After you did the demo for The Girl Is Mine, what happened next in connection with the song?

MJ:            After that, I played it for Quincy and he loved it, he thought it was perfect for Paul and I, and we played it for Paul in Arizona and Paul loved it and we recorded it.

Atty 1:            Was it commercially released?

MJ:            Yes (smiles)

Atty 1:            Did anyone make any changes in the studio?

MJ:            Were there any changes? From that? Other than that?(Points to the cassette tape)

Atty 1:            Yes.

MJ:            Yes.

Atty 1:            What?

MJ:            There was a guitar lick that’s different that was added.

Atty 1:            Any changes to the bridge?

MJ:            Yes the bridge was extended a little.

Atty 1:            Who suggested that?

MJ:            I think it was Quincy… I think!

Atty 1:            Mr. Jackson, before this lawsuit was filed — before this lawsuit was filed did you ever hear a song “Happy Go Lucky Girl”?

MJ:            No.

Atty 1:            When you wrote The Girl Is Mine, did you copy from anyone else’s song?

MJ:            (Chuckles) NOOOO!

Atty 1:            Was The Girl Is Mine written by you, and you alone?

MJ:            Written be me and me alone.

Atty 1:            Before we go onto the next song that we’re going to talk about, I’d like to ask you some questions.  Do you know anybody names Robert Smith?

MJ:            I’ve heard of the name.

Atty 1:            Where did you hear of the name?

MJ:            I don’t know.

Atty 1:            Do you know anyone named Clifford Reubens?

MJ:            Doesn’t ring any bells.

Atty 1:            Do you know Raynard Jones?

MJ:            Yes.

Atty 1:            How do you know Raynard Jones?

MJ:            A friend of my brothers I think, over the years or something.

Atty 1:            Do you consider him a friend of yours?

MJ:            No.

Atty 1:            Why not?

MJ:            Well a friend wouldn’t do this would he?

Atty 1:            How about in the earlier years, did you ever think of him as a friend of yours?

MJ:            Not really, he’s not my age. He hung out with my brothers. He’s much older than I am.

Atty 1:            Over the years did Raynard Jones ever visit your family?

MJ:            Yes.

Atty 1:            Under what circumstances?

MJ:            Hello – Goodbye!

Atty 1:            Do you ever recall Raynard Jones playing you songs in your studio in Encino?

MJ:            No.

Atty 1:            Did you ever copy any songs provided you by Raynard Jones?

MJ:            NOOO!

Atty 1:            Ever copy any songs written by Robert Smith?

MJ:            NOOO!

Atty 1:            I’d like to you now about the song Thriller.  Are you familiar with the song Thriller?

MJ:            Yes.

Atty 1:            Who wrote Thriller Mr Jackson?

MJ:            A guy named Rod Termperton.

Atty 1:            Did you have any role in connection with the song Thriller at all?

MJ:            I sang Thriller.

Atty 1:            Did you have any role in writing the song?

MJ:            No.

Atty 1:            When did you first hear the song Thriller?

MJ:            I first heard the song, it was called… it was a different title.  I heard it in Encino, at my house in Encino, it was under a different title.

Atty 1:            What was that title?

MJ:            Starlight Sun.

Atty 1:            And who brought you that song under that different title?

MJ:            Rod Temperton

Atty 1:            Did he come to your studio… did he come to your house alone or was he with someone?

MJ:            He came with Quincy.

Atty 1:            Before Rod Temperton brought you this demo of Starlight, did you have any contact with him in connection with the song Starlight?

MJ:            No.

Atty 1:            When he got to your house what did Mr. Temperton do in connection with the song Thriller?

MJ:            He had … he came with a keyboard machine and I kind of admired the way he worked.  He had all the sounds already programmed inside the machine so when he made the sounds to another keyboard or to the main board that’s in the studio, which is the audio board umm.. they would play the sounds and the performance that he had performed somewhere else. It could have been Switzerland or Germany, so all the parts were there inside that machine done and performed already.

Atty 1:            At some point did you learn the song Thriller or Starlight at the time.  Let me withdraw that.  At some time did you learn the song Starlight?

MJ:            Yes.

Atty 1:            How did you learn it?

MJ:            Well he sings it on a tape and it’s his voice singing against uhhh..a demo.

Atty 1:            And again, what was the name of the song that was on that demo?

MJ:            Starlight Sun.

Atty 1:            In your performance of what eventually became Thriller did you make any changes in connection with your performance or the music?

MJ:            (Long pause) Not that I can think of.

Atty 1:            Did you play any role whatsoever in writing the music underlying the lyrics of Thriller that go “It’s close to midnight and something evil’s lurking in the dark?”

MJ:            No.

Atty 1:            Who wrote the lyrics for Thriller?

MJ:            Rod Temperton.

Atty 1:            Who has writing credit for Thriller?

MJ:            Rod Temperton.

Atty 1:            Did you get any writing credit for Thriller?

MJ:            No.

Atty 1:            Before this lawsuit — before this lawsuit did you ever hear a song entitled Run On Man Child?

MJ:            No.

Atty 1:            At any time Mr Jackson, did you give Rod Temperton music from someone else so that Rod Temperton could put that music in Thriller?

MJ:            Noooo.

Atty 1:            Turning to another subject.  You realize that Joseph Jackson is one of the defendants in this case?

MJ:            I heard.

Atty 1:            Who is Joseph Jackson?

MJ:            My father.

Atty 1:            At any time in your professional career has Joseph Jackson ever provided music that you or your group would perform for recording purposes?

MJ:            Repeat your question.

Atty 1:            Yes. At any time during your professional career has Joseph Jackson ever had any role in selecting the songs that you or your group would perform?

MJ:            No.

Atty 1:            Did Joseph Jackson ever give you any music written by Raynard Jones?

MJ:            No.

Atty 1:            Did he ever give you any music written by Robert Smith or Cliff Reuben?

MJ:            No.

Atty 1:            Did Joseph Jackson have any role in creating Rod Temperton’s Thriller?

MJ:            No (smiles)

Atty 1:            Finally, I would like to turn to We Are The World. Who wrote the song We Are The World Mr Jackson?

MJ:            I wrote We Are The World and Lionel Ritchie also helped.

Atty 1:            How did you become involved with We Are The World?

MJ:            Quincy Jones called me on the phone.  I was in my bedroom in Encino, and he said “Smelly” he calls me “Smelly”  he said “Smelly, we need a song for the children of the world, there are a lot of children dying and I want you and Lionel Ritchie to go in and write a song.  I asked Stevie Wonder to write a song but it’s taken him quite some time. You know how Stevie is” he said “he’s brilliant but it takes him quite a while to get going”.  I said “Quincy, I just finished Thriller, I just spent all that time in the studio and I don’t feel like it. ”  and he said “but it would be very important for the children”  and as soon as he said that (smiles) he knew how I feel about children and how important that is to me.  So I said, “I’ll do it” and (laughing) so I got together with Lionel and we got together and goofed off for two days doing nothing.  Just making fun of each other and just being silly, because we go way back, since I was eight years old or something.

Atty 1:            How did you meet Lionel Ritchie?

MJ:            He used to open up for my group The Jackson 5, on our early tours as The Commodores and then after he would perform he would go out front and hold the fans back so he was like a bodyguard at the same time.  In front of the stage holding back all the kids so we had a pretty good relationship, we would laugh about old times. So we had a lot of catching up to do, so we talked and laughed and threw things at each other, and joked around and we didn’t get anything done. Then on the third day, I think it was the third day, I woke up with this melody in my head.

Atty 1:            Did Mr. Ritchie bring any melody to you at any time?

MJ:            Yes, Lionel brought something to me, he had something in his head as well.

Atty 1:            What was that. Can you sing it?

MJ:            Yes, he had umm… I think he played it on tape and he sang it to me, this is what he played.  He said this is all I have and I hope you like it.  It went (51:19 – 51:23

Michael sings what Lionel brought to him) and that was it.

Atty 1:            Did you like it?

MJ:            Yeah, I said, “that’s nice”.

Atty 1:            And then what happened?

MJ:            I said well “listen to this”  and I played him what I… no that’s not what happened… I said “I have something in my head as well” I said “but I want to go in the studio and put it all together first and then I’ll let you hear it.”  So I went in the studio and put all the sounds down (51:55-51:58  MJ sings “There comes a time when we heed a certain call, da da dum)  the whole thing, the bridge and…

Atty 1:             Can you briefly demonstrate how you went through that creative process?  Umm.. Let me back up. Did you ever put your ideas for We Are The World into a tape recorder?

MJ:            Yes I did.

Atty 1:            Do you know where that tape is?

MJ:            No (Laughing) I never keep up with my tapes.  I’m not organized in that way.

Atty 1:            Can you demonstrate for us, just briefly, how you created some of the music that you created for We Are The World?

MJ:            Okay.  I strongly remember getting on my knees and praying to God thanking him for the melody that came into my head because I was pleased with it when I woke up that morning. I said, “this is so lovely” and I went to the tape recorder and I put it down and it was (52:51-53:16  MJ sings melody to We Are The World).  Then I put in that part (53:18 continues to sing a small portion of We Are The World)

Atty 1:            When you say “that part”

MJ:            It’s the part that Lionel brought (52:23 – Sings)  Then I added again (53:28-53:34 sings another portion)  Which is the part I added on. (53:36-53:39)

Atty 1:            Did you also work on the harmony?

MJ:            The harmonies… I did it just the way I did The Girl Is Mine. No different. I did the strings, I did the bass, and I did the chords and the bridge. The same way. The same law in letting it create itself.

Atty 1:            Did you eventually make a demo of “We Are The World”?

MJ:            Yes I did.

Atty 1:            Do you remember where that was?

MJ:            I can’t find that tape to this day, I wish I knew where it was, I would like to hear it just to have some laughs.

Atty 1:            Do you remember .. did you go to a studio to make that demo?

MJ:            Yeah, it was a studio in the valley.

Atty 1:            Was there an engineer there at the studio?

MJ:            Yes.

Atty 1:            What was the name of the studio?  Let me back up.  What was the name of the studio do you recall?

 

(Michael talks to someone beside him asking “Is that for you or me? Thanks!)

MJ:            Redwing. I think that was the name of it.

Atty 1:            Do you recall what the engineer … let me back up. Was there an engineer?

MJ:            Yes.

Atty 1:            What happened next. Let me stop. Let me play you just a brief portion of a tape marked Exhibit 486 previously identified.

(54:49-55:11 Exhibit 486 is played.  A demo of We Are The World with Lionel Ritchie and Michael Jackson working on the song together)

MJ:            That’s the bridge

Atty 1:            Do you recognize Exhibit 486 Mr. Jackson?

MJ:            Yes.

Atty 1:            What is it?

MJ:            That’s the bridge to We Are The World.

Atty 1:            Do you hear anybody talking on the tape?

MJ:            It sounds like Lionel. (laughing)

Atty 1:            Let me play you a little more and umm…just a little bit more.

(55:30-55:56:  MJ and LR working together on We Are The World – Exhibit 486)

Atty 1:            You also on that tape?

MJ:            Yes.

Atty 1:            How did you come to create Exhibit 486, this tape?

MJ:            How did I create it?

Atty 1:            Yeah, how did it happen that what was going on was being taped.

MJ:            By just… because at some point I said, “I want to just tape of some of what we’re doing so we can just have it.” you know.

Atty 1:            What were you and Mr. Ritchie doing on that tape?

MJ:            Singing… goofing off.

Atty 1:            Were you writing any of the song at the time?

MJ:            Not really, we kind of goof off a lot

Atty 1:            I’ll play a little more.

(56:43-57:44:            Exhibit 486 is played.  MJ and LR working on We Are The World)

Atty 1:            In playing that does that refresh your recollection as to whether or not you and Mr. Ritchie were working on any part of the song?

MJ:            Yes, I was reciting the bridge.

Atty 1:            Let me play just a little bit more.

(MJ takes off his coat and looks at “microphone man” smiling and put back the microphone on his shirt and says to him,“is that ok”m moves it again and says, “how about there?”)

(58:07-58:43 Exhibit is played)

Atty 1:            Can you tell me now, listening to more, whether you and Mr. Ritchie are working on any part of We Are The World?

MJ:            Yes umm… working on … um … I don’t know if it was lyrics or what.  I think the lyrics we kind of fooled around with the lyrics after creating the melody.

Atty 1:            Mr. Jackson, before this lawsuit was filed, did you ever hear of a song called “What Will Become Of The Children”?

MJ:            No.

Atty 1:            Did you copy anyone’s song in writing We Are The World?

MJ:            No.

Atty 1:            Did Mr. Ritchie?

MJ:            No.

Atty 1:            Did you and Lionel Ritchie together, and with no one else, write We Are The World?

MJ:            Say that again.

Atty 1:            Did you and Mr. Ritchie, and only you and Mr. Ritchie write We Are The World?

MJ:            That’s the truth.

Atty 1:            I have no further questions.

********************************************************************************************Break

Atty 2:            Would you please state your name.

MJ:            Michael Joseph Jackson.

Atty 2:            Mr. Jackson will you spell your last name.

MJ:            J…A…C…K…S…O…N

Atty 2:            Mr. Jackson do you the name a person by the name of Raynard Jones?

MJ:            I’ve heard of the name Raynard Jones.

Atty 2:            Have you simply heard of it or do you know the person.

MJ:            Do I know the person?… I’ve met him.

Atty 2:            When did you first meet?

MJ:            I don’t remember.

Atty 2:            How long have you known him?

MJ:            I don’t remember.

Atty 2:            Did you first meet him in Los Angeles?

MJ:            No.

Atty 2:            Did you first meet him in Detroit?

MJ:            No.

Atty 2:            Did you first meet him in New York?

MJ:            No.

Atty 2:            Where did you first meet him?

MJ:            I think Indiana.

Atty 2:            What part of Indiana?

MJ:            I think Gary, Indiana.

Atty 2:            Did you live in Gary, Indiana at one time?

MJ:            Yes.

Atty 2:            Were you in fact, born in Gary, Indiana?

MJ:            Yes.

Atty 2:            Under what circumstances did you meet Raynard Jones?

MJ:            I don’t remember.

Atty 2:            But you did meet him in Gary, Indiana, that’s your recollection, is that correct?

MJ:            Yes.

Atty 2:            Okay. But you don’t recall under what circumstances you met him, is that correct?

MJ:            I don’t know.

Atty 2:            You don’t know what — You don’t know what Mr Jackson?

MJ:            Under what circumstances.

Atty 2:            Okay. Have you ever discussed music or songs with Raynard Jones?

MJ:            Not that I remember.

Atty 2:            Is it that you have not discussed musics or songs with Raynard Jones, or is that you don’t remember whether you have discussed songs and music with Raynard Jones?

MJ:            I don’t remember.

Atty 2:            What? What is it that you don’t remember?

MJ:            Discussing music or songs with Raynard Jones.

Atty 2:            Okay. Do you recall ever having any conversations with Raynard Jones?

MJ:            Yes.

Atty 2:            Approximately how many conversations do you recall that you’ve had with Raynard Jones?

MJ:            (Laughs) I don’t know.

Atty 2:            Okay. Are they too numerous too recall?

MJ:            I don’t know.

Atty 2:            So they may be too numerous for you to recall, is that right?

MJ:            No.

Atty 2:            You just don’t recall?

MJ:            I don’t recall.

Atty 2:            Would it have been more than five?

MJ:            Could be.

Atty 2:            More than ten?

MJ:            I’m not sure.

Atty 2:            More than fifteen?

MJ:            I’m not sure.

Atty 2:            More than twenty?

MJ:            I’m not sure.

Atty 2:            Do you know where any of these conversations took place?

MJ:            No.

Atty 2:            Do you know whether anyone else was present when these conversations took place?

MJ:            No.

Atty 2:            Have you ever rehearsed any songs with Raynard Jones in any location?

MJ:            Yes.

Atty 2:            Where?

MJ:            I think … um…. at his house.

Atty 2:            And where would that have been?

MJ:            In Indiana.

Atty 2:            Gary, Indiana?

MJ:            Yes.

Atty 2:            On how many occasions did you rehearse songs with Raynard Jones at his house in Gary Indiana?

MJ:            I don’t remember.

Atty 2:            On the occasions that you rehearsed songs with Raynard Jones at his home in Gary, Indiana, did you also discuss those songs with him?

MJ:            No.

Atty 2:            You just rehearsed, is that correct?

MJ:            As I remember.

Atty 2:            As you remember what?

MJ:            What you just said.

Atty 2:            As you remember, you just rehearsed and did not discuss songs with him?

MJ:            Yes.

Atty 2:            When you were growing up in Gary, Indiana, did you ever perform at Roosevelt High School?

MJ:            Yes.

Atty 2:            Did you ever perform with Raynard Jones at Roosevelt High School?

MJ:            Yes. (Michael begins to wave his hands in front of his face to cool himself down)

Atty 2:            Has Raynard Jones ever visited with you outside of Gary, Indiana?

MJ:            I think he came to California.

Atty 2:            Okay. Did he ever visit with you or any members of your family on your residence on Hayvenhurst?

MJ:            Yes.

Atty 2:            Do you recall how many times that he did that?

MJ:            No.

Atty 2:            Mr. Jackson, do you ever recall whether Raynard Jones visited at your property on Hayvenhurst while you were there?

MJ:            I’m not positive.

Atty 2:            Did he or did he not visit while you were there?

MJ:            I’m not sure.

Atty 2:            Do you recall Raynard Jones visiting the Hayvenhurst property accompanied by two other individuals?

MJ:            I don’t know.

Atty 2:            Is it your testimony that Mr. Jones never visited the Hayvenhurst property while you were present?

MJ:            I’m not sure.

Atty 2:            Alright, other than Motown, did you sign with any other record company?

MJ:            No.

Atty 2:            Is it your testimony here today that you didn’t sign a contact with CBS Records?

MJ:            Did I sign with CBS Records, is that what you’re asking me?

Atty 2:            That was the question.

MJ:            Yes.

Atty 2:            When was that?

MJ:            I’m not sure.

Atty 2:            Did your father have anything to do with the signing of the contract with CBS Records?

MJ:            I’m not sure.

Atty 2:            You’re not sure whether he was involved in any manner?

MJ:            Yes.

Atty 2:            Okay. Let me ask a question?  Was your father, to your knowledge, involved in any manner for form in the signing of the contract between you, your brothers and CBS?

MJ:            Yes.

Atty 2:            In what way?

MJ:            (laughs) I don’t know.

Atty 2:            Now you know that he was involved, but you don’t know in what way he was involved?

MJ:            Exactly.

Atty 2:            Mr. Jackson, do you have or have you ever had a collection of musical materials?

MJ:            A collection of musical materials?

Atty 2:            Or a collection?

MJ:            I love going to the record store to buy records.

Atty 2:            I’m sorry?

MJ:            I love going to the record store to buy records.

Atty 2:            My question to you is: Did you at any time have a collection of musical materials?

MJ:            A collection that I buy from the music store.

Atty 2:            Okay, did that collection include materials from any other source other than material that you purchased from a music store?

MJ:            (Laughs) No.

Atty 2:            When did you first begin keeping this collection?

MJ:            I don’t remember.

Atty 2:            Mr. Jackson, the collection — have you ever maintained a collection of musical materials that included unreleased songs?

MJ:            That I have written.

Atty 2:            Have you ever maintained a musical collection that contained unreleased songs written be anyone else?

MJ:            No.

Atty 2:            In 1977 did you maintain a collection of musical materials?

MJ:            My favorite record store is Tower Records.  I collect cassettes and CD’s from Tower Records.

Atty 2:            Could you read back my last question please? (asking court reporter)

(Question:  In 1977 did you maintain a collection of musical materials?)

MJ:            Same answer.

Atty 2:            Yes or no, did you or didn’t you?  Did you?

MJ:            No.

Atty 2:            You didn’t maintain a collection in 1977? Is that right?

MJ:            Music that I buy from the record store.

Atty 2:            So in 1977, you maintained a collection of music which you purchased from a record store?  Is that right?

MJ:            ’77, ’78, ’79, 76, it’s part of… I love music. I buy records.

Atty 2:            So you did maintain a collection of songs that you purchased from a music store, right? In 1977?

MJ:            (Smiles) Yes.

Atty 2:            Where did you keep you’re musical materials that you purchased from the music store?

MJ:            (Michael beings to laugh) Everywhere.

Atty 2:            There was no particular location?

MJ:            No.

Atty 2:            They were strewn everywhere, is that it?

MJ:            (Still laughing) Thrown about. I’m not organized in that way.

Atty 2:            Did you ever receive in the mail, cassettes with songs on them from other people.

MJ:            No.

Atty 2:            Is there anything in your musical collection which you did not create?

MJ:            Of course.

Atty 2:            Do you get cassettes with songs on them, through the mail from other people?

MJ:            Not that I remember.

Atty 2:            Have you ever, during the period in question, Mr. Jackson receive cassette tapes and lead sheets, and/or lead sheets from any other person?

MJ:            Repeat that question.

(Question:            Have you ever, during the period in question Mr. Jackson, receive cassette tapes and lead sheets and/or lead sheets from any other person?

MJ            During what period?

Atty 2:            1977 through1985.

MJ:            No.

Atty 2:            Prior to 1977, did you receive cassettes or lead sheets in the mail from other persons?

MJ:            No?

Atty 2:            Subsequent to 1985, have you received cassettes and lead sheets from individuals through the mail?

MJ:            I don’t remember.

Atty 2:            Is it your testimony, Mr Jackson, that you have never received cassettes and lead sheets through the mail from other individuals.

MJ:            No.

Atty 2:            Is that your testimony?

MJ:            Yes that’s my testimony.

Atty 2:            Your testimony is that you have not?

MJ:            I have not.

Atty 2:            Mr. Jackson I refer you, once again, to your deposition, (Michael laughs) dated October the 19th, 1989. Refer you to page 138. Question in line 23: “Do you receive material from other songwriters”? Answer, Line 25:  Do I?  Continuing on 139, Line 1, Question: Yes. Line 2, Answer:  I used to.

MJ:            Songs that I’ve recorded.

Atty 2:            The material that you received in the mail, cassettes or lead sheets, what did you do with them?

MJ:            I just don’t remember getting things in the mail.

Atty 2:            I draw your attention to Page 139 of your deposition, volume 1, line 25, question:  Would you receive tapes in the mail or lead sheets in the mail or lyric sheets in the mail or reel to reel tapes in the mail? Answer on page 140, line 3: Yes, but no, I wouldn’t dare take the time to listen, I’d just throw them away.  If that’s what you said, is that what you did?

MJ:            Yes.

Atty 2:            So you did receive cassettes and lead sheets in the mail from other people, is that correct?

MJ:            I’m foggy on that, I don’t quite remember.

Atty 2:            Now when you received these materials in the mail, would you throw them away?

MJ:            If I got any songs in the mail, I would never listen to them.

Atty 2:            My question to you is: The songs that you received in the mail, would you throw them away?

MJ            Absolutely?

Atty 2:            And how did you get rid of them?

MJ:            I don’t remember.

Atty 2:            Is it your testimony that while you received cassettes of songs in the mail that you never listened to those cassettes?

MJ:            Repeat your question?  (Phone rings, MJ smiles)

Question:  Is it your testimony that while you received cassettes of songs in the mail that you never listened to those cassettes?

Atty 2:            I believe I had a question for the witness, would the reporter repeat the question?

Question:  Is it your testimony that while you received cassettes of songs in the mail that you never listened to those cassettes?

MJ:            Any cassettes that come to me personally in the mail, which is very rare, I’d throw them away and our policy of tapes that come to the office is, if there are songs that are written by other people, we simply send them back.  If I’m on the street, if I’m in a record store and somebody has a song and he comes up to me and says, “Michael, I’m a songwriter I want to make it like you, listen to my song”, I say “I can’t take your tape”.  I simply do not take tapes. I am a songwriter myself and I write my own songs I don’t have to take other people’s songs

Atty 2:            My question to you is:  Is it true that the songs that you received in the mail, that you did not listen to them?

MJ:            I do not listen to them.

Atty 2:            Mr. Jackson, does the collection that you have consist of songs that you have started but you didn’t like and you let them go or you dropped them?

MJ:            There are certain songs that I have that I’ve written that I just think aren’t good enough, or I like it at the time and then something will come (smiles) along that will beat that song out.  It will be stronger to me so I’ll just leave that song there.  It’s just there.

Atty 2:            So your answer is yes?

MJ:            Yes to what?

Atty 2:            To the question?

MJ:            What’s the question?

Atty 2:            Please read it back:

MJ clears his throat and says ,“I’m sorry”

Question:   Mr. Jackson, does the collection that you have consist of songs that  you have started but you didn’t like and you let them go or you dropped them?

MJ:            Let them go? I don’t understand the terminology you’re using. Can you rephrase it?

Atty 2:            What does your collection consist of?

MJ:            Songs that I’ve written?

Atty 2:            The question is:  What does your collection consist of?

MJ:            I’m trying so hard to answer it — you mean the songs that I’ve written?

Atty 2:            No, no, no my question to you is: You have a collection, what does the collection consist of?

MJ:            Glen Campbell, Johnny Mathis, The Carpenters, The Eagles.. umm .. what else do I like?  Stevie Wonder, I love the BeeGees. I love James Brown. Aretha Franklin. All the old Motown stuff from the 60’s, umm.. do you want me to keep going?

Atty 2:            Well, if you choose to?

MJ:            I’m … okay umm..what else? I love Herman’s Hermits, I love ahh.. The Beatles I love a lot.  The Sherman Brothers who I think are very good. Who else do I like? umm. I said Stevie Wonder. That’s all that I can think of right now.

Atty 2:            Are any of the songs that you worked on, your personal songs, included in your collection?

MJ:            Now that’s what I was asking you before. Now could you repeat your question. (Smiles)

Atty 2:            Read the question back. (Reproter: The one I read previous) My last question. Just prior to the one you read previously.

 

(Question:   Mr. Jackson, does the collection that you have consist of songs that you have started but you didn’t like and you let them go or you dropped them?)

MJ:            Let them go? I just don’t understand what that means?

Atty 2:            Mr. Jackson, I call your attention to a line taken from one of your depositions taken October 19, 1989, page 129, question in line 6:  “What does your collection consist of”?  Answer Line 7:  “Songs I work on, songs that I have started and didn’t like that much so I just let it go and there’s just classical music I buy, like a great song that I enjoy listening to, show tunes,  Rogers and Hammerstein, Chuck Berry.” Do you recall that question and giving that answer?

MJ:            (Nodding) That sounds like me.

Atty 2:            My question is: Do you recall that question and do you recall giving that answer?

MJ:            No.

Atty 2:            So then what is the answer contained in your deposition, is that accurate or not?

MJ:            It sounds accurate.

Atty 2:            Okay? And did you give that answer?

MJ:            It sounds like something I would have said.

Atty 2:            My question to you is did you give that answer?

Atty 1:            Objection. Asked and answered!

MJ:            Yes.

Atty 2:            I’m sorry?

MJ:            Yes.

Atty 2:            So you gave that answer.

MJ:            Yes.  I forgot Rodgers and Hammerstein, I love them.

Atty 2:            Now, with regard to your collection, other than what you’ve already testified to, does that collection include the works of any other party or person?

MJ:            The works of any other party or person?  Yes, I like ….

Atty 2:            No, I’m not asking you a question about what you like, I’m asking you about what’s included in your collection, you’ve told us, you’ve mentioned a number of names of individuals and groups

MJ            Yes.

Atty 2:            … including songs that you work on, that are included in your collection is that right?

MJ:            Yeeesss!

Atty 2:            Are there any other persons, whose works that you have not mentioned that are included in your collection?

MJ:            No.

Atty 2:            Is it true Mr. Jackson that you started to sing The Girl Is Mine into a tape recorder?

MJ:            Yes.

Atty 2:            And have we heard that tape today?

MJ:            Yes.

Atty 2:            Mr. Jackson, you’ve indicated that you started to sing The Girl Is Mine into a tape recorder is that correct?

MJ:            Yes?

Atty 2:            And you have also testified that we have heard that tape today, is that correct?

MJ:            Yes.

Atty 2:            And is that Exhibit 489?

MJ:            I don’t know.

Atty 2:            Mr. Jackson, is that the original tape that you made for The Girl Is Mine?  Exhibit 489 which you have heard, is that an accurate description or depiction of the original tape that you made for The Girl Is Mine?

MJ:            Sounds like it to me.

Atty 2:            How long have you had that tape?

MJ:            I don’t remember.

Atty 2:            I’m sorry I couldn’t hear you?

MJ:            I don’t remember.

Atty 2:            Was there a time when that tape was lost?

MJ:            I don’t remember.

Atty 2:            Was there a time when you didn’t know where that tape was?

MJ:            I don’t remember.

Atty 2:            Sorry?

MJ:            I don’t remember.

Atty 2:            Mr. Jackson, I call your attention to your deposition taken October 19, 1989, page 128, question line 20: “When you say there it was, what did you mean by that? Answer at line 22: I started to sing in the tape recorder. Line 23, question:  “Do you still have that tape?”  Line 24, answer: I don’t have it personally, it’s somewhere”.  To page 129, question: “Do you know where it is”?   Line 2, answer:  “No” .  Do you recall those questions being asked and you giving those answers in your deposition taken on October 19, 1989?

MJ:            No.

Atty 2:            Do you recall the question on page 129, “You’ don’t know who has it?”. Answer, line 4: “No, it must be in my collection somewhere at home.”  Do you recall that question and that answer?

MJ:            I don’t remember.

Atty 2:            What is it you don’t remember?

MJ:            What you just asked.

Atty 2:            You don’t remember saying that you don’t know who has it?

MJ:            Repeat your question.

Atty 2:            You don’t remember saying “You don’t know who has it”?

MJ:            I don’t remember.

Atty 2:            You don’t remember saying that?

MJ:            I don’t remember.

Atty 2:            You don’t remember saying that?

MJ:            That’s right.

Atty 2:            I’m sorry I didn’t hear you?

MJ:            Yes.

Atty 2:            Do you remember saying in answer to the question “Do you know where it is?”  “No”.  Do you recall that answer?

MJ:            No.

Atty 2:            Mr. Jackson, with regard to the songs that you received in the mail from other people, did you return those songs?

MJ:            I answered that question.

Atty 2:            My question to you is: Did you return any of the songs that you received in the mail?

MJ:            I throw them away.

Atty 2:            Did you keep a log of any kind, or record of any of the tapes you received in the mail?

MJ:            No.

Atty 2:            Do you also consider Mr. Jones to be disloyal?

MJ            Yes.

Atty 2:            Do you feel Mr. Jones owes you some loyalty?

MJ:            I think he owes honesty.

Atty 2:            Would you say that you also owe honesty?

MJ:            I’m being very honest.

Atty 2:            That’s not my question. Do you feel that you owe honesty?

MJ:            I am honest.

Atty 2:            So then is it when you say… is it your testimony that Mr. Jones is dishonest?

MJ:            Absolutely.

Atty 2:            Why do you say that he is dishonest?

MJ:            Because he knows in his heart that he didn’t write those songs.

Atty 2:            Which songs are you referring to?

MJ:            The songs that you’re referring to.

Atty 2:            No. The question is, which songs are you referring to Mr. Jackson?

MJ:            (Sighs) The Girl Is Mine, We Are The World and Thriller.

 

Atty 2:            So is it your testimony that Mr. Jones is claiming that he wrote The Girl is Mine?

MJ:            Yes

Atty 2:            Is it your testimony that Mr. Jones is saying he wrote We Are The World?

MJ:            Yes.

Atty 2:            Is it your testimony that Mr. Jones is saying that he wrote Thriller?

MJ:            Yes.

Atty 2:            And it is on that basis that you conclude that Mr. Jones is dishonest, is that correct?

MJ:            Absolutely.

Atty 2:            In October of 1989 did you discuss this lawsuit with Bill Bray?

MJ:            I don’t remember.

Atty 2:            By the way, who is Bill Bray?

MJ:            He’s head of security.

Atty 2:            For whom?

MJ:            For MJJ Productions.

Atty 2:            And what is MJJ Productions?

MJ:            My company.

Atty 2:            And what does MJJ Productions do?

MJ:            It’s an office that administrates my personal affairs.

Atty 2:            How long has Mr. Bray is employed by MJJ Productions?

MJ:            Oh, I wouldn’t know.

Atty 2:            Okay, but he works for MJJ Productions?

MJ:            Yes he does.

Atty 2:            So in working with MJJ Productions, is it your contention that that’s different from him being employed by MJJ Productions?

MJ:            What’s your question?

Atty 2:            You said he works for MJJ Productions, is that right?

MJ:            Yes.

Atty 2:            Previously I asked you, was he employed by MJJ Productions, do you recall that question?

MJ:            Yes.

Atty 2:            Do you recall what your answer was?

MJ:            What was the answer?

Atty 2:            I’m asking you the question, do you recall?

MJ:            Yes.

Atty 2:            What was the answer.

MJ:            Was he employed by MJJ Productions?

Atty 2:            That was the question.

MJ:            The answer is yes.

Atty 2:            How long has Mr. Bray been employed by MJJ Productions?

MJ:            I’m not sure.

Atty 2:            Prior to your move to California or after your move to California?

MJ:            I’m really not sure.

Atty 2:            Is it your testimony that you don’t recall a conversation with Bill Bray concerning Raynard Jones and this particular lawsuit in October of 1989?

MJ:            No.

Atty 2:            Did you ever talk to Bill Bray about the deposition that you gave on October 19, 1989?

MJ:            I don’t remember.

Atty 2:            Do you recall at the deposition taken on October 19, 1989 this question, page 17, line 2:  “Anybody else that you talked to other than the lawyers about this deposition today?”  Answer, line 4:  “Security.”  Question, line 5:  “Who was that?”   Answer, line 6:  “Bill Bray and some of the guys at the studio”. Question, line 7: “What did you talk to Bill Bray about?”  Do you recall those questions and giving those answers?

MJ:            No.

Atty 2:            Did you answer the questions as I’ve read them to you on October 19, 1989?

MJ:            I must have.

Atty 2:            Do you recall the nature of your conversation with Bill Bray concerning this lawsuit and your deposition of October 19, 1989?

MJ:            No.

Atty 2:            You recall this question, page 17 of your deposition taken on October 19, 1989, line 7:

“What did you talk to Bill Bray about?” Answer line 8:  “The nature of the conversation was that Bill was very disappointed that this is happening, so was I because it’s very sad because it’s not true.”  Do you recall those questions and those answers?

MJ:            No.

Atty 2:            Did you give that answer, starting at line 8, page 17 through line 10 at your deposition as I’ve read to you on October 19, 1989?

MJ:            I must have.

Atty 2:            Do you recall the nature of your conversation with Bill Bray concerning this lawsuit in your deposition on October 19, 1989?

MJ:            No.

Atty 2:            Do you recall this question on page 17 of your deposition taken on October 19, 1989, line 7, “What did you talk to Bill Bray about?”  Answer, line 8:  “The nature of the conversation was Bill was very disappointed that this is happening, so was I because it’s very sad, because it’s not true.  Do you recall those questions and those answers?

MJ:            No.

Atty 2:            Did you give that answer starting at line 8, page 17 through line 10 at your deposition on October 19?

MJ:            I must have (smiling)

Atty 2:            To your knowledge does Bill Bray know Raynard Jones?

MJ:            Pardon?

Aty 2:            To your knowledge does Bill Bray know Raynard Jones?

MJ:            Do I have knowledge that Bill knows Raynard Jones?

Atty 2:            My question was to your knowledge does Bill Bray know Raynard Jones.

MJ:            Oh.  I’m not sure.

Atty 2:            Have you ever been in the presence of Bill Bray and Raynard Jones at the same time?

MJ:            Not that I can remember.

Atty 2:            Do you recall testifying that the conversation that Bill Bray had that took place in the “Hideout”?

MJ:            No.

Atty 2:            Call to your attention to your deposition of October 19, 1989, page 18, question on  line 2: “What did you say to Bill Bray?”:  Answer, line 3:             “I’m not sure”.  Question, line 4:  “Did you say anything to him?”  Answer, line 5:  “In agreement, it was some words in agreement”. Line 7:  “Was that in a face to face conversation?” Answer, line 8:  “Yes” Question:  “Where?”, Answer line 10:  “At the hideout”. Does that refresh your recollection as to where your conversation with Bill Bray took place?

MJ:            Yes.

Atty 2:            Okay, and did it take place in the hideout?

MJ:            It must have if that’s what I said.

Atty 2:            What did Bill Bray say to you about Raynard Jones in that conversation?

MJ:            I don’t remember.

Atty 2:            Same deposition, October 19, 1989, line 17, question, line 14: “What did you say to Bill and what did he say to you?” Answer, line 16: “Well, Bill said, the nature of this, here’s a guy whose never had a hit record, he’s trying to claim that he’s written a hit song, that type of thing”. Do you recall that question and giving that answer?

MJ:            Kind of.

Atty 2:            Did you agree with the statement made by Bill Bray?

MJ:            Absolutely.

Atty 2:            Why did you agree with this statement?

MJ:            Why do I agree with the statement?

Atty 2:            Why did you agree with this statement?

MJ:            Because it’s true.

Atty 2:            What part was true?

MJ:            He knows in his heart that he did not write those songs … he knows that!

Atty 2:            Mr. Jackson, you testified under direct examination that Lionel Richie stated to you that you write songs quickly, you could write an album in one week, do you recall that?

MJ:            Yes.

Atty 2:            When did you first receive the call from Quincy Jones with regard to creating a song that ultimately became We Are The World?

MJ:            I don’t remember.

Atty 2:            From the time that you received the request from Mr. Jones, when did you begin work on your part of that composition?

MJ:            I don’t remember working on it really.

(Inaudible conversation in the background)

Atty 2:            What was your response Mr. Jackson?

MJ:            I don’t remember working on it really.

Atty 2:            Did you work on music that ultimately became known as We Are The World?

MJ:            Yes.

Atty 2:            Okay. How soon after you received the call from Mr. Quincy Jones was it that you began that work?

MJ:            I don’ remember.

Atty 2:            How long after the call from Mr. Quincy Jones did you contact anyone else concerning that work which would ultimately become known as We are The World?

MJ:            I don’t remember.

Atty 2:            How soon after you received the call from Quincy Jones was it before (inaudible) working with the song that would ultimately become known as We Are The World?

Atty 1:            I’m sorry, could you reread the question.

(Clerk:            Question:  How soon after you received the call from Quincy Jones was it before you contacted Lionel Ritchie with regard to working on a song that would ultimately become known as We Are The World?

MJ:            I don’t think I called Lionel.

Aty 2:            Okay, so you didn’t call him. Did he call you?

MJ:            No, I think Quincy did.

Atty 2:            Quincy called who?

MJ:            Lionel Ritchie.

Atty 2:            Did there come a time when you and Mr. Ritchie talked on the telephone about the song that would ultimately become known as We Are The World?

MJ:            I don’t remember.

Atty 2:            I’m sorry I didn’t hear you.

MJ:            I don’t remember, I’m sorry.

Atty 2:            Did there come a time when you and Mr. Ritchie met to work on a song that would ultimately become known as We Are The World?

MJ:            Yes.

Atty 2:            When was that?

MJ:            I don’t remember.

Atty 2:            How many times did you and Mr. Ritchie work on a song that would ultimately become known as We Are the World?

MJ:            I don’t remember for sure. I don’t remember.

Atty 2:            Where did you and Mr. Ritchie work on the song that would ultimately become We Are the World?

MJ:            My house.

Atty 2:            Anyplace else?

Atty 2:            Well, when teaching everybody all the different parts and how to sing the song — all the different celebrities — A&M Studios I think. (Michael pauses as if in pain)

Atty 1:            Mr. Jackson how are you feeling?

MJ:            Not good.

Atty 1:            May we take a break?

***************************************************************************************  Break

MJ:            ’77 I’m not sure.

Atty 2:            Have you ever lived in Encino, California?

MJ:            (Smiles) Yes.

Atty 2:            When did you first begin living in Encino, California?

MJ:            Gee, I’m not sure!

Atty 2:            Are you familiar with a residence in Encino California on Hayvenhurst Avenue?

MJ:            Yes.

Atty 2:            Have you ever lived there?

MJ:            Yes.

Atty 2:            And do you know whether you lived there in June of 1977?

MJ:            ’77, I’m not sure.

Atty 2:            But you do recall living at that address — at the Hayvenhurst address is that right?

MJ:            Yes.

Atty 2:            When did you cease living at the Hayvenhurst address?

MJ:            I don’t remember.

Atty 2:            Do you presently live at the Hayvenhurst address?

MJ:            No.

Atty 2:            Have you ever seen Raynard Jones at the house on Hayvenhurst Avenue?

MJ:            I saw him at the gate one time as I remember trying to get in.

Atty 2:            My question is: Have you ever seen him in the house on Hayvenhurst Avenue?

MJ:            I think one time he was inside that I saw him.

Atty 2:            So you’re answer is “yes”?

MJ:            It’s foggy I’m sorry.

Atty 2:            So you’re answer is “yes” you have seen him in your house on Hayvenhurst?

MJ:            I’m not sure.

Atty 2:            Mr. Jackson, do you recall your deposition being taken on October 19, 1989?

MJ:            Yes.

Atty 2:            Page 24.  I call your attention to this question, line 1:  Has Raynard ever visited you at your home?  And your answer at line 2: “He has been there.”  Do you recall that question and that answer.

MJ:            No.

Atty 2:            How many times have you seen Raynard Jones at your house on Hayvenhurst Avenue?

MJ:            Gee, I wouldn’t remember.

Atty 2:            Have you ever listened to an audio cassette or a tape in the presence of Raynard Jones in any location?

MJ:            No. Not that I remember.

Atty 2:            Is it that you don’t remember, or that you have not?

MJ:            I have not.

Atty 2:            Have you ever seen Raynard Jones in the studio of your house on Hayvenhurst Avenue?

MJ:            I don’t remember sir.

Atty 2:            Is it that you don’t remember or that you have not seen him in your studio in your house at Hayvenhurst Avenue?

MJ:            I don’t remember.

Atty 2:            Have you ever seen Raynard Jones at your home at Hayvenhurst accompanied by other people?

MJ:            Its foggy, but I think he had a friend with him.

Atty 2:            And when would that have been?

MJ:            (Laughing) I don’t remember!

Atty 2:            Do you know whether that would have been in June 1977?

MJ:            I really don’t remember.

Atty 2:            Have you and the Jackson’s ever conducted a musical tour called The Victory Tour?

MJ:            Yes.

Atty 2:            In what year is that?

MJ:            80 something.

Atty 2:            Did The Victory Tour take place at any time during 1984?

MJ:            It could have.

Atty 2:            Is it your testimony that you do not know when The Victory Tour began?

MJ:            I’m not positive, I’m bad with dates.

Atty 2:            So you know a person by the name of Johnny Ray Nelson?

MJ:            Yes (smiles).

Atty 2:            How do you know him?

MJ:            I think he — Johnny Ray?— was my next door neighbor in Indiana.

Atty 2:            Has Johnny Ray Nelson ever been an employee of yours?

MJ:            No, not that I know of.

Atty 2:            Is it your testimony that Johnny Ray Nelson has never been employed by you or is it you don’t remember whether he was employed by you?

MJ:            I’m not sure sir.

Atty 2:            I call your attention to page 83 of your deposition taken on October 19, 1989 at line 25 do you recall this question being asked relative to Johnny Ray Nelson?  Question:  Has he ever worked for you?  Line 25, page 83. Page 84, line 1: “Yes”.  Do you recall that question and do you recall giving that answer?

MJ:            No.

Atty 2:            Okay. Is it your testimony here today that the answer that you gave in response to that question on October 19, 1989 is not accurate?

MJ:            I can’t remember what he did.

Atty 2:            That’s not my question.  My question to you is: Are you contending that the answer you gave to the question in your deposition in October, 1989, is that inaccurate?

MJ:            I’m not sure.

Atty 2:            Is it true that Johnny Ray Nelson travelled             on The Victory Tour?

MJ:            I’m not sure.

Atty 2:            Is it true during the period 1983 to 1986 you received information that Raynard Jones was complaining that you and The Jacksons were copying his music?  Is that true?

MJ:            Repeat your question.

Atty 2:            Is it true that during the period 1983 through 1986 you received information that Raynard Jones was complaining that you and The Jacksons were copying his music?

MJ:            I’m not sure of the dates.

Atty 2:            Did there come a time when you received information that Raynard Jones was complaining that you and The Jacksons were copying his music?

MJ:            Yes.

Atty 2:            When was that?

MJ:            I’m not sure.

Atty 2:            Was that before or after you moved to California?

MJ:            I think it was after we moved to California.

Atty 2:            And from whom did you receive that information?

MJ:            I’m not sure.

Atty 2:            Did you ever receive that information from Johnny Ray Nelson?

MJ:            What information?

Atty 2:            That you and The Jacksons were copying Raynard Jones’ music?

MJ:            Could you repeat your question sir?

Atty 2:            Did you receive information from Johnny Ray Nelson at any time during the period 1983 through to 1986, that Raynard Jones was complaining that you and the Jackson’s were copying his music?

MJ:            I don’t remember.

Atty 2:            Is it that you don’t remember or that you did not receive such information from Johnny Ray Nelson?

MJ:            I don’t remember.

Atty 2:            Okay. So you don’t remember whether you received information from Johnny Ray Nelson during the period 1983 through to 1986 that Raynard Jones was complaining that you and the Jackson’s were copying his music?

MJ:            I don’t remember the dates.  I don’t remember.

Atty 2:            I’m not asking you — strike the dates — you said yourself, that you had received information that Raynard Jones was complaining that you and the Jackson’s were copying his music and I asked you what year was that?  Do you recall that?

MJ:            What’s your question?

Atty 2:            My question to you is is:  You testified here that you received information that Raynard Jones was complaining that you and the jackson’s were copying his music. Is that correct?

MJ:            Yes.

Atty 2:            My question to you is: when did you receive that information?

MJ:            I don’t remember.

Atty 2:            My question to you is:  From whom did you received that information?

MJ:            I don’t know.

Atty 2:            My question to you is:  Did Johnny Ray Nelson ever convey information to you that Raynard Jones was complaining that you and the Jackson’s were copying his music?

MJ:            No.  Johnny Ray Nelson?

Atty 2:            Yes.

MJ:            No.

Atty 2:            Mr. Jackson, I call your attention to page 82 of your deposition taken on October 19, 1989.  Question at page 8: “What people?”, Answer beginning at line 9: “Well, one of the friends, one of our next door neighbors, who is a guy named Ray Nelson.  Even Ray Nelson said once we succeeded in left Gary, Indiana when we had hit after hit record and he said Raynard would come to him and say,“don’t that sound like my sound, don’t this part sound like the song I wrote, and he would try and say that we stole his song.  We didn’t even write the songs, let alone take them.”  Do you recall that question ….

Atty 2:            You didn’t finish the question.

Atty 1:            My question is to you is do you recall that question and responding as I have read to you at your deposition on October 19, 1989?

MJ:            I do remember Johnny Ray Nelson being angry at Raynard.  Johnny Ray saying something of the sort that Raynard is trying to take advantage of us because we became very successful and he didn’t, and we took off into superstardom and he didn’t. So he was trying to find any excuse, anything to (laughs) get back at us.

Atty 1:            When did Mr. Johny Ray Nelson tell you that?

MJ:            I don’t remember.

Atty 1:            Okay. My question to you was: Do you recall the question that I asked relative to your deposition and the answer that I read to you, do you recall that question and giving that answer that I read to you?

MJ:            Could you repeat that again?

Atty 1:            The question on page 82, line 8: “What people?”, Answer beginning at line 9: “Well, one of the friends, one of our next door neighbors, who is a guy named Ray Nelson.  Even Ray Nelson said once we succeeded in left Gary, Indiana we had hit after hit record and he said Raynard would come to him and say “don’t that sound like my sound, don’t this part sound like the song I wrote, and he would try to say that we stole his song.  We didn’t even write the songs, let alone take them.”  Do you recall that question and that part of your answer?

MJ:            I remember.

Atty 2:            Was that which I read to you as part of your answer accurate at the time that you gave it?

MJ:            If I said it, it must be accurate.

Atty 2:            Now, during The Victory Tour Mr. Jackson, did you and Johnny Ray Nelson discuss Raynard Jones?

MJ:            I don’t remember.

Atty 2:            Is it that you don’t remember whether you discussed him, or that you did not discuss Raynard Jones with Johnny Ray Nelson.

MJ:            I don’t remember if his name was brought up or not.

Atty 2:            Okay. Did you ever talk with Johnny Ray Nelson about Raynard Jones at the property on Hayvenhurst?

MJ:            I don’t remember.

Atty 2:            Do you recall your deposition of October 19, 1989 on page 83, line 7 the question: “Have you ever talked to Ray Nelson about Raynard Jones?”  You answer on line 9: Answer:

“yeah.”  Question at page 10: “You don’t know when?”  Answer: “No”.  Question at page 12 “Where?” Answer: “No, could have been Hayvenhurst.” Could you have talked with Johnny Ray Nelson about Raynard Jones at the Hayvenhurst property?

MJ:            I don’t remember.

Atty 2:            So that your answer that you gave in your deposition when you say “It could have been Hayvenhurst” what that accurate then when you gave that answer?

MJ:            It could have been.

Atty 2:            Now after moving to California did you and your brothers perform in the Chicago area at any time?

MJ:            Yes.

Atty 2:            Now when you performed in the Chicago area would Raynard Jones visit you and or your brothers after your performance?

MJ:            No, I just remember my security saying he would always try to get backstage and hassle the security to try and get in.  That type of thing.

Atty 2:            On the occasions that you and your brothers performed in the Chicago area did you ever see Mr. Jones after any of your concert sessions?

MJ:            I don’t remember.

Atty 2:            On the occasions that your performed in the Chicago area after your concert sessions, did Mr. Jones ever attempt you to get you to listen to music?

MJ:            Did he ever get me to listen to music?

Atty 2:            Attempt or try to get you to listen to music?

MJ:            Not that I know of.

Atty 2:            When you would see Raynard Jones — strike that — You did see Raynard Jones in California after moving there is that correct?

Atty 3:            Mr. Jackson I’m going to show you what has been marked, as a purpose of identification Plaintiff’s Exhibit number 215 and ask that you can identify that?  Answer:  “Yes” Quesion, line 21: “Can you identify that person in that photograph?” Answer, line 23: “It’s me”.  Do you recall those questions and giving those answers at your deposition of October 19, 1989.

MJ:            If I said it then it must be accurate but it had to be a better picture than that.  I can’t see that.  (Long pause, Michael smiles)

Atty 3:            Mr. Jackson, I’m going to show what has been marked as Plaintiff’s Exhibit number 216 which is a photocopy of a photograph and ask you if you can identify it?

MJ:            Well, to me it looks like the great Al Green and Raynard Jones.  I think.

Atty 3:            Is it that you think that the other person in the photograph is Raynard Jones or is the other person in Plaintiff’s Exhibit 216 Raynard Jones?

MJ:            It looks more like Raynard Jones, it’s hard to tell on the Al Green because, again, your picture is ….

Atty 2:            Does it appear to be a photograph which includes Raynard Jones?

MJ:            Yes.

Atty 3            Mr. Jackson, can you tell me, in the context of the Thriller project and the We Are the World project what these various entities do or whether they were involved in these projects at all?  MJJ Productions.  What is MJJ Productions?

MJ:            It’s my office where they work with CBS records  on packaging, art design, answering letters, dealing with the fan club it’s umm… our way of working with the world from inside… outside.

Atty 3:            So then MJJ Productions really, promotes and distributes and has something to do with the product that you record, is that correct?

MJ:            I’m sorry, I didn’t understand.

Atty 3:            MJJ Productions has something to do with your services as a recording artist and the product that you record and sell, is that right?

MJ:            Yes.

Atty 3:            Warner Brothers Publications Inc.             Do you know what that company is?

MJ:            Yes.

Atty 3:            Can you tell us about that company?

MJ:            It’s a movie company and a record company, like CBS/Sony.

Atty 3:            So Warner Bros Publications Inc. had something to do with the projects Thriller and We Are The World?

MJ:            Not that I know of.

Atty 3:            Okay and what about Warner Tamerline Publishing Corporation?

MJ:            I’m not sure on that.

Atty 3:            And USA for Africa Foundation, do you know what that is?

MJ:            Yes?

Atty 3:            Can you tell us what that is?

MJ:            It was an organization that was set up to distribute funds – relief funds, to Africa for the project of We Are The World, which is a song that myself and Lionel Ritchie wrote for Africa.

Atty 3:            So… (Michael is still speaking) I’m sorry go ahead.

MJ:            We organized all the celebrities together and we sang the song for Africa USA. United States for Africa.

Atty 3:            So the foundation was really the beneficiary of the proceeds of the sale of the product We Are The World?

MJ:            That’s…

Atty 3:            Is that a fair statement?

MJ:            That’s the idea.

Atty 3:            And how about Mijac Music?

MJ:            I’m not sure if Mijac exists anymore. It’s a publishing company, it was a publishing company.

Atty 3:            But you’re not sure if it exists now?

MJ:            I’m not positive.

Atty 3:            Did it exist at the time that Thriller was distributed as well?

MJ:            I think so.

Atty 3:            And same is true when We Are The World was distributed?

MJ:            I’m not sure sir.

Atty 3:            Was Mijac or is Mijac your publishing company – music publishing company?

MJ:            Is it my publishing Company?

Atty 3:            Was it when it was …..I?

MJ:            Oh Yes.

Atty 3:            Its still in business as your publishing company?

MJ:            Yes.

Atty 3:            Okay and you don’t know whether it still exists?

MJ:            I’m not sure.

Atty 3:            Do you know when Mijac music was formed?

MJ:            No.

Atty 3:            But when it was in existence it was wholly owned by you?

MJ:            Yes.

Atty 3:            Did you have a publishing company before Mijac?

MJ:            Umm.. I think Mijac was the first one.

Atty 3:            Do you own another publishing company now?

MJ:            Yes.

Atty 3:            What is the name of that publishing company?

MJ:            Well, there’s ATV Music.

Atty 3:            ATV Music?

MJ:            Yes.

Atty 3:            Okay.  Is it a publishing company?

MJ:            Yes.

Atty 3:            I’ll try not to repeat some of the things that have been asked you.  Was there a time that you were the lead singer of The Jackson 5?

MJ:            Yes.

Atty 3:            And was that during the time that the Jackson 5 was under a recording contract with Motown?

MJ:            We were the Jackson 5 before signing with Motown.

Atty 3:            But you were the lead singer during the time that the Jackson 5 were signed to Motown?

MJ:            Yes.

Atty 3:            And then was there a time that the Jackson 5 became The Jacksons?

MJ:            Yes.

Atty 3:            Were you the lead singer of the group known as The Jacksons?

MJ:            Yes.

Atty 3:            Would the time when The Jackson 5 became known as The Jacksons, would that have been around 1976, ’77?

MJ:            I’m not sure.

Atty 3:            Was there a time when The Jacksons were signed under a recording agreement to CBS?

MJ:            Yes.

Atty 3:            And you were still a member of The Jacksons at that time?

MJ:            Yes.

Atty 3:            Was there a time when you became a — strike that — Was there a time when you recorded separately from The Jacksons under contract with CBS?

MJ:            Yes.

Atty 3:            Let me show you a document and ask you if you’ve ever seen it before?

Atty 1:            Show it to …. thank you.

(Michael reads over slowly the document)

Atty 3:            Could you tell us what that document is?

MJ:            It looks like a recording contract.

Atty 3:            What is the date in the right hand corner of page 1?

MJ:            November 1, 1978.

Atty 3:            Okay and it would it be fair to say that it is an agreement between The Jackson 5 Inc. and Quincy Jones Productions?

MJ:            No.

Atty 3:            Have you ever seen that before?

MJ:            I probably have but I don’t remember, I sign a million papers.

Atty 3:            I’m sure. Let me ask you to turn to the last page.  Do you recognize the signatures on the left side under The Jackson 5 Inc.?

MJ:            Yes.

Atty 3:            Can you tell us what those signatures are?

MJ:            The first one looks like “Joseph Jackson” It’s kind of hard to see. The second one looks like “Michael Jackson”.

Atty 3:            Does that look like your signature?

MJ:            (Laughs) Yes.

Atty 3:            Okay…

MJ:            And the other looks like Quincy Jones.

Atty 3:            Okay, thank you.  Now go back to page 1, paragraph number 1, could you read the last sentence in that paragraph please?

MJ:            “We shall provide that Epic shall not have any other person remix…

Atty 3:            No. I’m sorry, page 1, paragraph 1, number 1 – the last sentence.

MJ:            Paragraph 1, number 1 – the last sentence?

Atty 3:            Right.

MJ:            It’s right here isn’t it?

Atty 3:            It starts out “The time…”

MJ:            Oh paragraph, I’m sorry …. “The time and place of recording such masters, the selection of compositions to be embodied thereon and all individuals rendering services in connection with the recording of masters shall be mutually agreed upon by you and artist.”

Atty 3:            Okay.  Now, was this the agreement that was signed by Quincy Jones production for the production of your first solo album?  Do you recall Mr. Jackson if this was the  — and I’m interested in refreshing your recollection about the time — November 1, 1978…

MJ:            Okay.

Atty 3:            Would this have been about the time that you were assigned to do your first solo album?

MJ:            I’m not sure.

Atty 3:            You’re not sure?

MJ:            No.

Atty 3:            Okay do you remember what year it was that your brothers and you signed with CBS as The Jacksons?

MJ:            No.

Atty 3:             Now pick up that agreement again and i want to look at the paragraph… you’ve been in the record business for quite some time, have you not?

MJ:            Quite some time!

Atty 3:            And do you understand that second paragraph in paragraph 1, to say where it says “the selection of the composition” do you know what that means?

MJ:            Sure.

Atty 3:            What does that mean?

MJ:            “the selections choosing the songs”.

Atty 3:            Right, does that mean that — this agreement says the right to choices of the right to choose the song is between you and Quincy Jones mutually?

MJ:            Mutual agreement, yes.

Atty 3:            Ok.

MJ:            We do it together.

Atty 3:            Alright. Now, I’m going to ask you to do one more thing with this document and we can leave it alone.  Look down at the bottom of the first page, paragraph 2.  The last sentence right after the parts that have been inked out.

MJ:            Yes.

Atty 3:            Could you read that please?

MJ:            “We shall provide that Epic shall not have any other person remix or re edit any masters produced by you hereunder without first providing you with a reasonable opportunity to perform such remixing and or re editing as Epic shall require.”

Atty 3:            What do you understand that to mean?

MJ:            Well, let me read it again!  (Michael reads it silently) Well it says “without providing a reasonable opportunity to perform such remixing and/or re editing as Epic shall require.”  It’s just saying that Epic umm… that it’s between Quincy and myself to remix or re edit the songs on the albums and if any other outside person comes in and wants to work on the album, it has to be in agreement with us.

Atty 3:            Okay now, in your experience in the record business, would it be fair to say that under this agreement that Epic would have final approval on the remix or the re edit?

Atty 1:            Objection!  It’s argumentative!

Michael laughs

Atty 3:            Does the record company always have the right to approve the mix and the edit?

Atty 1:            Objection!  No final master!

MJ:            Not the final.

Atty 3:            When you deliver the master to the record company can they reject it?

MJ:            Can they what?

Atty 3:            Reject it?

MJ:            They can reject it.

Atty 3:            That’s fine, that’s all I wanted to know.

MJ:            I don’t get what this has to do with ….. (shakes his head)

Atty 3:            Now under The Jacksons first contract with CBS as recording artists, do you recall whether The Jacksons had a right to, under that contract to provide or to supply music or to produce a certain number of songs per album?

MJ:            Under the epic contract?

Atty 3:            Yes.

MJ:             I’m not positive but I think we had the right to three songs per album.

Atty 3:            Do you recall who produced the first CBS album on The Jacksons?

MJ:            Yes.

Atty 3:            Who was that?

MJ:            Gamble and Huff.

Atty 3:            And you recall how many tunes == you sang three that The Jacksons had to write to provide on that album?

MJ:            I sang three that The Jacksons….

Atty 3:            Didn’t you just say three?

MJ:            In writing.

Atty 3:            Yes.

MJ:            In writing, three, yes – me and my brothers.  I’m not positive but that’s what I think.

Atty 3:            You say in writing, but is there a difference then — you’re saying in the contract provided it had three, but in reality you had another number, is that what you’re saying now?

MJ:            No, it was the way you worded it that confused me.

Atty 3:            Well, what I’m trying to find out is — on the first album of The Jacksons under the CBS contract, how many tunes did you have the right to provide on that album?  Do you remember?

MJ:            I think it was three.

Atty 3:            You think it was three?  Now did that mean that you had the right to write three tunes, find three tunes from somebody else or what did that mean.

MJ:            (laughs) Write three tunes.

Atty 3:            Okay and did The Jacksons write three tunes on that album?

MJ:            Yes we did.

Atty 3:            Do you recall the name of the album, that first album?

MJ:            I think… I’m not sure…

Atty 3:            Would it have been Going Places?

MJ:            It could have been.  Or Destiny, I’m not sure.

Atty 3:            Now how did, if you had the contractual right to have so many songs on the album and let’s say two or three, do you recall how many songs you guys wrote for that album?

MJ:            I don’t remember.

Atty 3:            You don’t remember.  Normally in your experience in the business, if you’re going to have so many tunes on an album, how many songs would you put together for final selection?

MJ:            How many songs would we write for the album?

Atty 3:            If you had a right to provide two or three, how many songs would you have normally put together?

MJ:            Oh gee, fifteen.

Atty 3:            Now did, of those, lets assume fifteen, were all those written by The Jacksons?

MJ:            Yes

Atty 1:            Objection!

Atty 3:            No outside writers?

MJ:            No outside writers.

Atty 3:            Do you recall a tune named Blues Away?

MJ:            Yes.

Atty 3:            Who wrote that?

MJ:            I wrote that one.

Atty 3:            Was that solely by yourself or with your brother Randy?

MJ:            Solely by myself as I remember.

Atty 3:            How about a song called A Different Kind of Lady?

MJ:            What about it?

Atty 3:            Do you recall that song?

MJ:            Yes.

Atty 3:            Who wrote it?

MJ:            I think it was credited as The Jacksons.

Atty 3:            Who wrote it?

MJ:            Gee, Jackie, myself, Randy, Tito… I think we all wrote it. We all wrote it.

Atty 3:            By the way did you guys have a publishing company at that time?

MJ:            Yes.

Atty 3:            What was the name of the publishing company?

MJ:            I’m not sure.

Atty 3:            Was the publishing company owned by The Jackson 5?

MJ:            Yes.

Atty 3:            Was Blues Away the first song you ever recorded — written, that was ever recorded?

MJ:            No.

Atty 3:            Had you written songs previously that had been recorded before Blues Away?

MJ:            Oh yes.

Atty 3:            Can you name some of those songs that you had written and were recorded and RELEASED?

MJ:            (Pointing and smiling) That’s different, that’s different.

Atty 1:            That’s a different question

Atty 3:            Let me go back then, was Blues Away the first song you had written that was recorded and released?

MJ:            Yes.

Atty 3:            Well, we saved ourselves a lot of time.

MJ:            (Laughing) We sure did.

Atty 3:            Do you recall the name of the second album that was recorded by The Jacksons under the CBS agreement?

MJ:            Gee, I’m not positive. I don’t know if it was Triumph or Destiny or Goin Places,..I’m not sure what order.

Atty 3:            Do you recall – were all the songs provided for that album by The Jacksons?  I mean the second CBS album, do you understand my question?

MJ:            What’s the name of the album?

Atty 2:            Well, what if I told you it was Destiny, would that sound inaccurate?

MJ:            I’m not positive.

Atty 3:            Alright, it was the Destiny album and do you recall how many songs were – were there any songs provided by outside writers on Destiny?

MJ:            I’m not sure.

Atty 3:            Do you recall who produced Destiny?

MJ:            The Jacksons produced Destiny.

Atty 2:            Would it be safe to assume that The Jacksons may have had the right to produce all the songs on that album?

MJ:            I’ m not sure.

Atty 3:            Do you know a woman named Regina Hooks?

MJ:            I’ve heard of the name but I can’t place the face.

Atty 3:            Did she provide any songs for the Destiny album?

MJ:            Not that I know of.

Atty 3:            Ded she provide any of the songs for The Jacksons album?

MJ:            I don’t even know who she is.

Atty 3:            If she provided one of the songs on the albums when it was released she would have been given credit?  Is it speculation Mr. Jackson, that if someone wrote a song for your albums that they would get credit?

MJ:            Of course they would get credit.

Atty 3:            It’s not speculation then is it?

MJ:            If someone wrote a song, we would be honest and give them credit.

Atty 2:            In fact it’s your policy. right Mr. Jackson, that whenever a musician or someone provides help on a song, whether a bridge, or something like that on an arrangement, they get credit don’t they?

MJ:            Yes.

Atty 3:            Now the other day you testified,  you’ve written and published 30 – 40 tunes as a songwriter is that right?

MJ:            Something like that, I don’t know the exact number (laughs) I’ve never counted. I don’t count them.

Atty 3:            When you write a song and it’s not co-written by anybody else, with anyone else or collaborated with and was written solely by you it’s your independent work?

MJ:            I’m sorry, I didn’t understand.

Atty 3:            If there’s a song that you write, that you take sole credit for ..

MJ:            Yes.

Atty 3:            .. You’re independent creation..by you and you only…

MJ:            Yes.

Atty 3:            And you don’t…. do you include common musical phrases in your song that you write?

MJ:            Common musical phrases?

Atty 3:            Do you know what that means?

MJ:            Yeah, but I don’t know if you know what it means?

Atty 3:            Let me ask you, why don’t you tell us what it is?

MJ:            I don’t know…

Atty 3:            What’s a “common musical phrase”?

MJ:            A common musical phrase?

Atty 3:            Yes.

MJ:            A musical phrase could mean a note, a tone.

Atty 3:            Have you ever heard the term a “Common musical phrase” before

MJ:            Yes, but the way you put it in your question is what’s different so I wasn’t sure if I understood what you meant.

Atty 3:            Okay, well let me ask you, could you tell us what a “common musical phrase” is?

MJ:            (Laughing) A “common musical phrase” is (23:04 Michael sings a note Hee”)

Atty 3:            That’s a “common musical phrase”?

MJ:            That could be a “common musical phrase”.

Atty 3:            Have you ever heard the term “Scenes Afaire”.

MJ:            Pardon?

Atty 3:            “Scenes Afaire”, have you ever heard that?

MJ:            Scenes?  Spell it.

Atty 3:            S.C.E.N.E.S.

MJ:            Yeah

Atty 3:            little line  “Afaire”

MJ:            Spell it.

Atty 3:            A.F.A.I.R.E.   Have you ever heard…

MJ:            “Scenes Afaire”…

Atty 3:            that before?

MJ:            No. I never heard that.

Atty 3:            Now, let me ask you the question again, I’m not sure you’re answer was clear to me, or maybe I missed it. When you write a song, that’s your sole song that you take credit for, by yourself…

MJ:            Yes.

Atty 3:            Do you use… is that song independently created by you?

MJ:            All the…

Atty 3:            Do you understand the question Mr. Jackson?

MJ:            Absolutely.  The songs that I take credit for on my albums that say “Written by Michael Jackson” are written by Michael Jackson.

Atty 3:            And Michael Jackson alone, right?

MJ:            Michael Jackson alone, I wouldn’t cheat anybody out of credit.

Atty 3:            I’m not suggesting that you cheated anybody anything sir. I’m just…

MJ:            I mean I’m an honest person.

Atty 3:            I’m going to ask you a question and give you a list of songs and then I’m going to ask you some questions about each of them.

MJ:            Okay.

Atty 3:            Have you heard of a song called She’s Not A Girl?

MJ:            Yes.

Atty 3:            Who wrote it?

MJ:            I wrote it.

Atty 3:            Was it released?

MJ:            Pardon?

Atty 3:            Was it recorded and released?

MJ:            It was recorded but never released.  It’s a demo.

Atty 3:            Pardon?

MJ:            It’s a demo I did, I think at the Encino house.

Atty 3:            Do you know what year?

MJ:            No.

Atty 3:            How about a song called You Ain’t Gonna Change Nothin?

MJ:            I wrote that.

Atty 3:            Was that released?

MJ:            No.

Atty 3:            How about Lucy Is In Love With Linus?

MJ:            I wrote that.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Who is the Girl With Her Hair Down?

MJ:            I wrote that.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Lonely Man?

MJ:            I wrote that.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Going To Rio?

MJ:            Going where?

Atty 3:            Going To Rio?

MJ:            Going To Rio. I wrote that.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Do you recall when you wrote it?

MJ:            No, but it was before Thriller, before Off The Wall.

Atty 3:            Tomboy?

MJ:            (Michael sings in his head and begins to move trying to recall) I wrote that.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Know when you wrote it?

MJ:            I wrote Tomboy for the Bad album and that was after Thriller so I don’t know the dates.

Atty 3:            Buffalo Bill?

MJ:            Buffalo Bill was written after I wrote.. umm.. Billie Jean, so that was written after The Thriller album.  Yes.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Al Capone?

MJ:            Al Capone was written after the Thriller album. Never released.

Atty 3:            Michael McKellar?

MJ:            (MichaelLooks shocked) Michael McKellar?

Atty 3:            Yes.

MJ:            (Laughs) How do you know about Michael McKellar?  I wrote Michael McKellar.

Atty 3:            You wrote it?

MJ:            Yes.

Atty 3:            Released?

MJ:            Never released.  (still looks surprised and continues to laugh)

Atty 3:            Thank You For Life?

MJ:            Thank You For Life. I wrote that.

Atty 3:            Do you know when?

MJ:            Thank You For Life was written .. boy, way before Off The Wall (thinking) I don’t know the date but it had to be around … If I could guess, would you like for me to guess?

Atty 3:            No, I don’t want you to guess.

MJ:            Okay, then I can’t say.

Atty 3:            Was it ever released?

MJ:            Never released.

Atty 3:            Much Too Soon?

MJ:            (Smiles) I wrote Much Too Soon.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            What A Lonely Way To Go?

MJ:            I wrote that one.

Atty 3:            Do you know when?

MJ:            (Pauses and starts to sing a song to himself) Before Off the Wall.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Who Do You Know?

MJ:            I wrote Who Do You Know.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            You Are A Liar?

MJ:            I wrote You Are A Liar.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Cry?

MJ:            I wrote Cry.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Make A Wish?

MJ:            (Thinking) I can’t recall that one… just give me a minute (holds his finger up) I can’t recall that one.

Atty 3:            Crack Kills?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Free?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Fly Away?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Children’s Hour... The Children’s Hour?

MJ:            (Pauses and smiles) I wrote that one.

Atty 3:            Was that released?

MJ:            Never released.

Atty 3:            Baby Smiles?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            A Baby Smiles?

MJ:            I wrote that one. Same one.

Atty 3:            Sister Sue?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Little Susie?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released?

Atty 3:            Tragedy of A Cheerleader?

MJ:            Tragedy Of A Cheerleader (thinking) I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Get Around?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Little Girls?

MJ:            (Pauses to think) I can’t recall that one.

Atty 3:            In The Valley?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Can you hold on a second? No… Little Girls, I do remember, yes I wrote that one. Never released.

Atty 3:            And In The Valley?

MJ:            I wrote that one.

Atty 3:            Was that released?

MJ:            Never released.

Atty 3:            Red Eye?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            I Forgive You?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Why Shy?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            I Have This Love Of Me?

MJ:            I wrote that one.

Atty 3:            Was that released?

MJ:            Never released.

Atty 3:            Llama Lola?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            California Grass?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Kentucky?

MJ:            I wrote that one.

Atty 3:            Do you know when you wrote that one?

MJ:            (Pauses to think) 70 something, I don’t remember exactly.

Atty 3:            Someone Put Your Hand Down?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            That one has an interesting story.  I wrote the original and then it was changed, in which I co wrote it with Teddy Riley and it was released but through some type of Pepsi contest. A limited edition of it was released.

Atty 3:            Do you know what year that was?

MJ:            I think it was last year, wasn’t it?  (Looks to someone beside him) I think.

Atty 3:            Do You Know Where Your Children Are?

MJ:            I wrote that one.

Atty 3:            Was that released?

MJ:            Never released?

Atty 3:            Bad Girl?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Lonely Bird?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Smooth Criminal?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Yes.

Atty 3:            What album?

MJ:            The Bad album.

Atty 3:            P.Y.T the original version?

MJ:            (Laughs) I wrote that one with Greg Phillinganes.

Atty 3:            Do you know what year that was?

MJ:            No.

Atty 3:            Cheater?

MJ:            (Michael moves his head back and forth singing silently) I wrote that one… I wrote that one, I co wrote that one.

Atty 3:            Was it released?

MJ:            Never released.

Atty 3:            People Have To Make Some Kind Of Joke?

MJ:            I wrote that one.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Is that co-written?

MJ:            I don’t think so, I’m not positive, it could have been co-written with my brother but I’m not positive. I think I wrote that one myself.

Atty 3:            Love Never Felt So Good?

MJ:            I wrote that.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Did you have a co-writer?

MJ:            Give me a minute to think. (Pauses) I’m not positive on that, there could have been a co-writer on that one.

Atty 3:            Would it have been Paul Anka?

MJ:            Could have been. Yes.

Atty 3:            Alright Now?

MJ:            I wrote that.

Atty 3:            Solely or co-written?

MJ:            I think I wrote that with my brother.

Atty 3:            Was it ever released?

MJ:            No.

Atty 3:            Scared Of The Moon?

MJ:            Yes.

Atty 3:            Scared Of The Moon?

MJ:            umm… Never been released, co-written.

Atty 3:            With Buz Kohan?

MJ:            Yes.

Atty 3:            Neverland Landing?

MJ:            Co written.

Atty 3:            Released?

MJ:            Never released?

Atty 3:            We Are The Ones?

MJ:            I wrote that one.

Atty 3:            Co-written or written solely?

MJ:            Solely.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            What Was Your Life?

MJ:            What’s Your Life? It’s called What’s Your Life.

Atty 3:            Okay.

MJ:            I wrote that with my brother Jermaine.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Fantasy?

MJ:            Co-written with my brother.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            The Sky Is The Limit?

MJ:            Co written.

Atty 3:            With whom?

MJ:            My brother.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Saved By The Bell?

MJ:            Co-written with my brother.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Chicago 1945?

MJ:            Co-written.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Make Or Break?

MJ:            Co-written.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Turning Me Off?

MJ:            I wrote that .. uhhh… co-written.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Sunset Driver?

MJ:            Co-written.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Far Far Away?

MJ:            I wrote that.

Atty 3:            Released?

MJ:            Never released.

Atty 3:            Did you have a co-writer on that one?

MJ:            Not that I can remember.

Atty 3:            State Of Shock?

MJ:            Released.  Co-written

Atty 3:            Get On The Floor?

MJ:            Released. Co-written.

Atty 3:            Let me ask you about P.Y.T... before I ask you that – of these songs that I’ve just asked you about that have never been released, do you recall when how far back they go in terms of time when you first wrote them?

MJ:            Some of them.

Atty 3:            What would you say is the furthest one — the one that goes back the furthest?

MJ:            Thank You For Life.

Atty 3:            What year?

MJ:            (Pauses to think) ’73, ’74 something like that.

Atty 3:            Now were these songs when you wrote them — you would go back to them from time to time?  Do you understand my question Mr. Jackson?

MJ:            When I wrote them, would I go back to them from time to time?

Atty 3:            Well let me ask you this: What form, when you write them – what form would they be in.  Would they be in the form of a lead sheet, would they be in a form of notes or would they be on a cassette?

MJ:            In writing, you mean pen to paper?

Atty 3:            Right.

MJ:            God, I’ve written things on toilet paper.  It could be anything whatever is the closest around, I’ve written on walls.

Atty 3:            The other day you testified that you, when you write, you hum the songs or the rhythms into a tape.

MJ:            That’s right.

Atty 3:            I’m asking you now that the songs I have just read to you, that are not released — have not been released ..

MJ:            That’s right.

Atty 3:            Are those maintained in the form of a cassette?

MJ:            Sometimes.

Atty 3:            Sometimes. Of the songs that I have just read you that were unreleased, how many of those would you say are in cassette form?

MJ:            Most of them are on cassette.

Atty 3:            And where are those maintained? Are they maintained in your collection?

MJ:            (Laughs) Yes.

Atty 3:            Now, the one song that we just talked about that was just done last year.  Do you recall for the Pepsi project or somebody’s project — got to lay my hands on it.

MJ:            Someone Put Your Hand Out.

Atty 3:            I believe it was called Someone Put Your Hand Down?

MJ:            Hand OUT!

Atty 3:            Right, that original was changed you say — it was co written with Teddy Riley..

MJ:            Yes.

Atty 3:            Was it originally co written with Teddy Riley?

MJ:            No.

Atty 3:            So then was it in that form, that cassette form and then you went back and pulled it out and dressed it up with Teddy and  then you just did things to it?

MJ:            Yes, I wrote it originally years ago and put it out and Teddy loved it, I loved it, and we made some changes, just changed the verse and I gave him co-writer’s credit.

Atty 3:            Okay. Now we’ve talked a lot about your collections.  Let’s try to nail this down.  Is that the collection that you’ve maintained at your home for a very long time? Do you understand my question?

MJ:            Collection that I’ve maintained a long time…

Atty 3:              Yep.  Do you understand my question?

MJ:            Repeat your question.

Atty 3:            The collection that we’ve talked about…

MJ:            These songs…

Atty 3:            Right. These songs.

MJ:            The songs.

Atty 3:            Right.  And the cassettes that you’ve written that you go back to from time to time. We’ve loosely called it a “collection”.  It was your choice of words “a collection”.  I’m asking you were these songs maintained in that collection at your home — one central location?

MJ:            Yes.

Atty 3:            Mr. Jackson let me read you another list of songs and ask you pretty much the same type of questions — whether they were released and whatever other kinds of issues may come up on each one of them.  The song Blues Away, we just covered, but just for the sake of putting it into it’s own little pigeon hole with the others, do you recall when Blues Away was released?

MJ:            No.

Atty 3:            You don’t?  Do you recall when Blues Away was released?

MJ:            No I don’t.

Atty 3:            But that was the first song that you had written, it wasn’t released is that correct?

MJ:            Yes.

Atty 3:            Don’t Stop Til You Get Enough?  Was that tune released?

MJ:            Yes.

Atty 3:            Do you recall what year?

MJ:            It was on the Off The Wall album so ’79, was it? (asking someone and then raises his eyebrows not sure).

Atty 3:            Did Greg Phillinganes do something on that song?

MJ:            Yes, the bridge. (02:54:05 does noises to create the bridge music) He created that.

Atty 3:            Okay.  Was he given credit on that album, on that song?

MJ:            Yes he was.

Atty 3:            Was that co-arranging or arranging or what – co written?

MJ:            Arranging just arranging.

Atty 3:            Working Day and Night?

MJ:            What about it?

Atty 3:            When was that released?

MJ:            That’s the Off The Wall album again, I think ’79. I’m not sure.

Atty 3:            Wanna Be Startin’ Something, was that written by you?

MJ:            Yes.

Atty 3:            What year was that released?

MJ:            That was for the Thriller album so that would be, I think ’83.

Atty 3:            Billie Jean, was that written by you?

MJ:            Yes.

Atty 3:            Was that released.

MJ:            Yes, Billie Jean was released.

Atty 3:            What album was that?

MJ:            Thriller album.

Atty 3:            Beat It, was that released?

MJ:            That was released.

Atty 3:            Written by you?

MJ:            I wrote Beat It all by myself yes.

Atty 3:            What album was that?

MJ:            That was the Thriller album.

Atty 3:            The Girl is Mine?

MJ:            Yes.

Atty 3:            You wrote that?

MJ:            Yes.

Atty 3:            Was that released?

MJ:            That was released.

Atty 3:            Which album?

MJ:            Thriller album, first single. It was a duet.

Atty 3:            I just can’t stop loving You? Was that released?

MJ:            Yes.

Atty 3:            Was it written by you?

MJ:            Yes.

Atty 3:            What album?

MJ:            Bad album.

Atty 3:            And Bad was that written by you?

MJ:            Yes.

Atty 3:            What album?

MJ:            Bad album

Atty 2:            Do you recall the year?

MJ:            No.

Atty 3:            Beg your pardon?

MJ:            No.

Atty 3:            The Way You Make Me Feel, did you write that?

MJ:            Yes

Atty 3:            Was that released?

MJ:            Yes.

Atty 3:            What album?

MJ:            Bad.

Atty 3:            Dirty Diana?

MJ:            I wrote Dirty Diana.

Atty 3:            Was that released?

MJ:            Yes.

Atty 3:            What album?

MJ:            Bad.

Atty 3:            Speed Demon, did you write that?

MJ:            Yes.

Atty 3:            What album did that appear on?

MJ:            Bad album.

Atty 3:            Liberian Girl, did you write that?

MJ:            Yes.

Atty 3:            Was that released?

MJ:            Yes.

Atty 3:            What album?

MJ:            Bad album.

Atty 3:            Muscles, did you write that?

MJ:            (Laughs) Yes.

Atty 3:            Was that released?

MJ:            Yes.

Atty 3:            By whom?

MJ:            Diana Ross.

Atty 3:            What year, do you know?

MJ:            I don’t remember.

Atty 3:            Another Part Of Me?

MJ:            Yes.

Atty 3:            Did you write that?

MJ:            Yes.

Atty 3:            And was that released?

MJ:            Yes.

Atty 3:            What album, do you recall

MJ:            It was first released for Caption EO, which was a short film. I think it was for the Bad album.

Atty 3:            Was there a later version of P.Y.T.?

MJ:            Yes.

Atty 3:            Do you know who wrote that?

MJ:            James Ingram and Quincy Jones.

Atty 3:            Did you get co-writer’s credit on that?

MJ:            No, because I didn’t write that one.  I wrote the original with Greg Phillinganes.

Atty 3:            What happened to the original?

MJ:            Quincy wanted a fast song, mine was mid-tempo.

Atty 3:            Now I’m going to ask you of the following songs, and I’ll read them rather quickly, I’ll ask you one question about them.  Let me read them first:  Cheater, People Have To Make Some Kind Of Joke, Love Never Felt So Good, Alright Now, Scared Of The Moon, Neverland Landing, We Are The Ones, What’s Your Life?, Fantasy, The Sky Is The Limit, Saved By The Bell, Chicago 145..

MJ:            1945

Atty 3:            1945…did I say 145?  1945.  Of those songs, excuse let me add Sunset Driver, Far Far Away and State Of Shock. Are those songs in the portfolio of a publishing company? Do you understand my question?

MJ:            The first time you asked me about Far Far Away, did I tell you I didn’t remember?

Atty 3:            You said you couldn’t remember if you had written that yourself or it was co-written.

MJ:            I remember it now. It was co-written.

Atty 3:            Do you know the publishing companies that own those songs?

MJ:            No.

Atty 3:            Is it your publishing company?

MJ:            Yes but I don’t know the name.

Atty 3:            Have you ever written a song called Centipede?

MJ:            Yes.

Atty 3:            Do you know when?

MJ:            I don’t remember.

Atty 3:            Do you remember what year?

MJ:            No – co-wrote it.

Atty 3:            With whom?

MJ:            With whom?

Atty 3:            Yes.

MJ:            John Barnes.

Atty 3:            Was it released?

MJ:            Yes.

Atty 3:            Did you sister Maureen sing it?

MJ:            Yes.

Atty 3:            Do you know a woman named Joyce McCrae?

MJ:            Joyce McCrae (thinks) I think so.

Atty 3:            Did she ever work for you?

MJ:            I don’t think so.

Atty 3:            Did she ever work for Motown?

MJ:            I don’t think so.

Atty 3:            Pardon me?

MJ:            I don’t think so.

Atty 3:            Do you have a song in your collection about that time by Sam and Dave called I’m a Soul Man?

MJ:            I don’t know if I bought that or not?  I buy a lot of records, but I don’t know if that was one of the ones I bought.

Atty 3:            Do you know whether you bought I’m A Soul Man about the time you wrote on or about the time you wrote Centipede?

MJ:            Gee, I wouldn’t know. (Laughs)

Atty 3:            I beg your pardon?

MJ:            I wouldn’t know.

Atty 3:            Ever hear of a song called You Were There?

MJ:            You Were There… sure. I wrote it with Buz Kohan for Sammy Davis Jr.

Atty 3:            Was that for the 60th anniversary celebration for Sammy Davis Jr?

MJ:            Yes.

Atty 3:            Do you remember when you and Buz Kohan wrote it?

MJ:            No.

Atty 3:            Was that “No”?

MJ:            Yes.

Atty 3:            You don’t remember?

MJ:            Yes.

Atty 3:            Do you remember what year?

MJ:            No.

Atty 3:            Do you remember where he and you were when you wrote that song?

MJ:            Yes, I don’t know the exact location, it was a place like the Shrine Auditorium.  Could have been the Shrine but I’m not sure.

Atty 3:            But you wrote it with him at the Shrine?

MJ:            Yes.

Atty 3:            Is that also in the portfolio of your publishing Company?

MJ:            Yes.

Atty 3:            Now when you began work on your first album, first solo album, which was later to be called Off The Wall.  Did you have a stockpile of songs that you had written to be submitted for that album?

MJ:            For the album?

Atty 3:            Off The Wall.

MJ:            Did I have a stockpile of songs that I had written for Off The Wall?

Atty 3:            That you had written that you were submitting for the album.

MJ:            When I write songs for an album, for instance, I’ll write 50 – 60 songs for just one album. Just for nine songs, you know, and I will pick from those so..

Atty 3:            Did you write 50 – 60 songs for Off The Wall?

MJ:            Yes. A lot of songs.

Atty 3:            Can you think of any?

MJ:            You named a lot of them.

Atty 2:            A lot of them that were on the list that I named a while ago?

MJ:            Some, some of them were.

Atty 3:            How many of those… what was the procedure that you and Quincy Jones employed to select songs for that album?

MJ:            I’d write the song, do a demo and play it for him. He’d say if he liked it or not.and most likely, he’d love it and we would record it.

Atty 3:            How many songs did you have on the album Off The Wall?

MJ:            I’m not sure, but I think it’s nine.

Atty 3:            How many of those nine were yours, that you wrote?

MJ:            Don’t Stop Til You Get Enough, Get On The Floor, Working Day And Night, three or four, I’m not sure.

Atty 3:             How many did, of the three or four… let me strike that… Four on the Off The Wall album. How many of your songs that you had written, did you and Quincy consider for that album?

MJ:            I don’t remember.

Atty 3:            A moment ago you said you’d write 50 songs, about 50 songs for a nine song album?

MJ:            That’s right.

Atty 3:            Did you present or consider, with Quincy, 50 songs for that album?

MJ:            No.

Atty 3:            Now did you and Quincy consider songs by outside writers on the Off The Wall album?

MJ:            Oh boy… umm..yes, She’s Out Of My Life was written by Tom Baylor, who I’ve known for years and years, he’s an old friend.

Atty 3:            Any other outside writers?

MJ:            Paul McCartney, that’s all I can think of.

Atty 3:            Did Rod Temperton submit some songs to that album?

MJ:            Oh yeah, he wrote Off The Wall, Rock With You, Burn This Disco Out, something like that. I can’t think of any others.

Atty 3l:            When did you first meet Rod Temperton?

MJ:            I don’t remember.

Atty 3:            You don’t remember?

MJ:            No. I meet sooo many people.

Atty 3:            I’m sorry I didn’t hear you.

MJ:            (Laughs) I meet so many people.

Atty 3:            Was… when you did meet Rod Temperton during the Off The Wall project did you not?

MJ:            Yes.

Atty 3:            Was that the first time you met?

MJ:            (Pauses to think) Yes (nods head)

Atty 3:            Would that have been sometime in 1978, 1979?

MJ:            I’m not sure.

Atty 3:            Mr. Jackson, between the Off The Wall album and the Thriller album, did you meet with Rod Temperton in a hotel in London?

MJ:            (Pauses to think) A hotel in London?   I’m sorry I don’t remember that.

Atty 3:            Now Rod Temperton submitted some songs for the Thriller album.

MJ:            I think it’s those three.  Unless there’s something I’m leaving out.

Atty 3:            Was there a song called Rolling In The Dice?

MJ:            Yes Rollling The Dice. That we did a demo for at Hayvenhurst but we never released it. We didn’t think it was strong enough.

Atty 3:            Was there another song called Hot Street?

MJ:            Yeah, I like Hot Street, I love that one, but they didn’t, Quincy and Rod didn’t think it was good enough.  I thought it was wonderful.

Atty 3:            Now then, you recall when Mr Temperton for the Thriller album?

MJ:            No I don’t.

Atty 3:            Do you recall where it was that you first heard the songs that he brought for the Thriller album?

MJ:            Yes.

Atty 3:            Where were you?

MJ:            Encino house.

Atty 3:            At your residence?

MJ:            Yes. My studio.

Atty 3:            And who was present?

MJ:            Quincy Jones, Rod Temperton, Bruce Swedien and myself.

Atty 3:            Who is Bruce Swedien?

MJ:            Bruce Swedien is the Engineer.

Atty 3:            When he and Quincy came to your studio to present the songs?

MJ:            He played on cassette, which we went I think it was Quincy’s car or my van.. because we don’t have a cassette machine system in my studio but he came with a keyboard and in the keyboard is his performances of the different sounds, he can (inaudible) these sounds and put them up on tape, a 24 track and put them on tape and it was a way of testing to see if I liked the songs or not. With my voice, trying different harmonies, trying the songs.  Like I said we did Thriller which was called Gimme Some Starlight, Starlight Sun (03:12:02. begins to sing “Starlight, Starlight Sun to the same tune of Thriller, thriller night).that’s how it went, so it was a way of just testing of what I wanted to do.

Atty 3:            Now, okay, he laid the very structure of the songs out in front of you, and you sung each one of them, is that correct?

MJ:            Yes.

Atty 3:            And among the ones you had sung was Starlight?

MJ:            Right.

Atty 3:            Did you make any changes to that Starlight?

MJ:            Yes, the lyrics and the title and we added Vincent Price’s voice, we changed it into Thriller. He did ask me which would I like better?  To be a song about you know, let the sunshine in type of thing or Thriller, and I thought kids would enjoy something more fun like Thriller (smiles) so we went with the Thriller idea.

Atty 3:            Did you change Starlight muscially?

MJ:            Umm.. yes, somewhat, musically it was the same but we added other sounds and things like that.

Atty 3:            After you made the changes, do you know whether or not Mr. Tempterton created a lead sheet what was now Thriller?

MJ:            I don’t think he reads music, he doesn’t use a lead sheet.

Atty 3:            Did Quincy Jones create a lead sheet for what was now Thriller?

MJ:            I don’t think so. At least I didn’t see one.

Atty 3:            You sang the other songs as…….. (end of video)

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This entry was posted in Body Language, In His Words, Michael News, Uncategorized and tagged , , , . Bookmark the permalink.

One Response to Michael Jackson Mexico Deposition 1993

  1. J. says:

    Hello 🙂 In the part towards the end, when he’s talking about hearing Thriller for the first time (“he came with a keyboard and in the keyboard is his performances of the different sounds, he can (inaudible) these sounds”), I think what he says is “he can MIDI those sounds”, as in make them into MIDI forms. Thank you for the transcript!

    Like

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