Some information :
Estate's only involvement in AEG - Jackson lawsuit is in regard to Michael's medical records. Estate as the representative of Michael claimed patient - doctor privilege and was against giving Michael's medical records. Judge ruled against MJ Estate and said Michael's medical records will be a part of discovery. Estate then pushed for a protective order in regards to Michael's medical records. Now the doctors send Michael's medical records to MJ Estate, MJ Estate goes over them, redacts any personal and irrelevant information and then marks them confidential and sends it to parties.
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AEG wants to get Jermaine Jackson's book drafts.
Media reports parties want to depose Arnold Klein
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I have some tidbits
Randy has papers from Michael's briefcase, the notes from his house and the private family autopsy results.
and if it's not cancelled Randy is being deposed today
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October 2012
Got the AEG motion files, it's a lot of back and forth emails between AEG and Katherine's lawyers trying to set date for depositions and cancellations and trying to set dates again. They spent 10 months trying to depose Randy and Jermaine.
Hearing had happened on October 5 and judge ORDERED Randy and Jermaine to sit for deposition within 21 days , in other words by October 26.
There's still 6 months till the discovery cut off date but it seems AEG is trying to get everything done by the summary judgement cut off date which is in 2 months - December 2012.
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I still can't see documents filed by KJ side but from AEG documents it can be understood that they filed declarations saying they didn't leak the documents / emails. KJ's lawyers then blame multiple parties - initially Lloyds , then Mann acted alone, a secret criminal that broke into lawyers offices and took the documents , a rogue contract attorney, AEG's lawyers and leak before confidentiality agreement was signed etc.
Lloyds is cleared as they didn't have access to all documents, neither did AEG lawyers some documents were only provided to KJ's lawyers, document production only started was after confidentiality agreement, Mann couldn't have done this alone as he didn't have access to those either. A secret criminal wouldn't have access to the stamped docs too. No contract attorney had access to those documents either.
Mann is caught because 1 day before the article he sends an email to Lloyds lawyers saying he's the source and look out for the article about AEG. Mann later call his email stupid and his actions stupidity that started all this.
KJ's lawyers asked AEG to withdraw their motion stating that they didn't have the "smoking gun" and they can't blame KJ as there could be many other possible scenarios- AEG refused. KJ's lawyer now asking sanctions against AEG. AEG is firm in their position that there could be no other possible scenarios, Mann couldn't acted alone and he's too connected to Katherine to be considered a third party.
AEG hired a forensic expert for the documents, who determined that Ortega documents came from the copies given to KJ's lawyers for certain. Even though Ortega gave the same documents to Lloyds, AEG and KJ's lawyers, Lloyds documents had a large confidential mark over them (like how we do with documents), the copies didn't have those. The copies given to KJ's lawyers and AEG's lawyers were hand stamped which meant the confidential stamps were at different locations. It was a perfect match to the copies given to KJ.
The leaked AEG Live emails also had the same copier marks (a ghost line on the right side of the paper) as KJ's lawyers printer. So the forensic expert says he believes those leaked AEG emails were copied / printed at KJ's lawyers office. Confidential stamps were cut. (He can't say for sure because he didn't have access to the copier / printer machine)
Mann refused to identify his sources citing journalistic confidentiality. No one else sat for depositions. AEG wanted to depose Katherine and her lawyers.
Mann says he gave a box of documents to the reporter and did not know what was in the box. he now says there might be other sources.
Mann says his friend Randall Sullivan introduced him to Perry Sanders whom he recommended Katherine to hire. Mann says he has a copy of Sander's retainer agreement with Katherine. It should have been a confidential document / private document for Katherine and no access to Mann. AEG uses this to argue that the documents could have been given to Mann by Sanders.
KJ's assistant said KJ's lawyers brought a binder of documents to KJ's house in spring. She said she doesn't know what happened to binder.
AEG wanted to bring a forensic computer specialist and examine computers of both sides of attorneys. KJ's lawyers refused.
AEG wants sanctions, further investigations and depositions by a special master.
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Let me add this as well
http://www.scribd.com/doc/110489504/AEG-Reply-Motion
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AEG has filed multiple documents on October 17. The 12 page motion that I posted in full publicly.
The rests are
- multiple sworn statements that they (AEG lawyers did not leak the documents).
- the forensic document expert report - which is highly redacted and the findings are nicely summarized in the motion
- parts from Howard Mann and Janice Smith (Katherine's assistant) depositions.
I'll now provide some more info based on the partial depositions.
Janice Smith snippets is really short and it just consists of her saying in spring 2012 Katherine's lawyers brought a big binder of documents to Katherine's house to go over them. Janice didn't see the documents, Janice doesn't know what happened to the binder.
AEG is using this to debunk Katherine's sworn statement in which she said she was not ever in possession of the confidential documents.
Mann's deposition is like I said is also partial. Mann's connection to Sanders through Sullivan, how he got him hired, and how he got Katherine's personal retainer agreement is used to show it's a possibility that Sanders might have given documents to Mann. Briefly Lowell Henry giving documents previously as well is also mentioned. So although the examples of documents given by Sanders and Henry is not relevant to this case they bring the suspicion that they might have given other stuff as well.
Katherine's business agreements with Mann is also explored - there's nothing that we don't know - to demonstrate that Mann has close ties to Katherine and not just a random outsider third party.
Mann is really vague about what he gave to LA Times reporter. He says he doesn't know what he gave to her. He says he only knows the box had a copy of the will and the trust he got it from the internet and he doesn't know the 99% of the rest of the documents. This seems fishy given that he sent an email to Lloyds stating to look out for the article about AEG's inside dealings.
It turns out Alan Duke found about the email Mann sent to Lloyds (probably Lloyds were denying that they were the leak and telling everyone what Mann sent to them) and asked Mann to confirm. Of course at that point Mann calls his email to Lloyds as stupidity and the thing that started this all. He wasn't very smart in hiding his involvement.
He says Radar Online and News of the World reporters also told him that they had access to these documents / emails. He denies giving it to them. Mann really trashes Radar Online and also says that he worked with / employed News of the World before. (Didn't News of the World was the one that leaked Michael's trust documents?)
Mann says it's true that he got some of the stuff from the fans but the rest is not filed. So we don't know the details.
Mann explains his actions as to formulate a relationship with Lloyds and LA Times reporter. He wanted to exchange information and become a common adversary to MJ Estate. It seems like he emailed Lloyds before about "MJ Estate / AEG fraud" which Lloyds ignored too.
Now you are going to ask what is the "MJ Estate / AEG Fraud". Mann believes the insurance money should have been directly paid to the beneficiaries and MJ Estate and AEG is in an active fraud to get the money to themselves. What Mann fails to realize is that it's Lloyds who filed that lawsuit not to pay anything to anyone. He also fails to understand that this was a cancellation policy that MJ Company was a party. It wasn't a personal insurance.
Mann mentions 4 additional sources but refuses to name them or provide any information based on journalistic privilege.
Oh and not surprisingly we learn that Randy Phillips and Roger Friedman had exchanged emails about Michael dating back to at least 2009. So KJ's lawyers claims that Phillips is the source of Friedman's articles how AEG will seek sanctions against the leaks. They also claim AEG gave the motion to Friedman before they were served. AEG counters this saying that Friedman got it after it was filed publicly. (Normally parties first file the motion with the clerks office and then serve it to the opposite side overnight. So any reporter can get the motion earlier if they get paper copies from the clerks office as they are filed)