Katherine Jackson first amended possible Witness list - as of April 15
(Additions in green, removed names in red)
Katherine Jackson / Prince Jackson / Paris Jackson / Paul Gongaware / Randy Phillips / Jeffrey Adams / Dr. David Adams / Daniel Anderson/ Phillip Anschutz / Dr. Frederic Askin(removed) / Raymone Bain / Ramone Baines(removed - could be a typo) / Richard Barnet (removed) / Tom Barrack /Martin Blount/ Michael Bearden/ Dan Beckerman / David Berman / John Branca / Dr. Emery Neal Brown / Ellen Brunn / Michael Bush / Kai Chase / Patrick Cousins / Dr. Charles Czeisler / Jenna Daddario EMT / Kelly DiStefano / Melissa Elias / Arthur Erk/ Joyce Essex / Alimorad Farschian/ Karen Faye / Lou Ferrigno / Dr. Stuart Finkelstein / Peter Formuzis / Maritza Glassman / Paramedic Mark Goodwin / Dr. Stephen Gordon / Hosny Habashy / Dennis Hawk / Reynold Henry EMT / Cathy Hilton / Julie Hollander / Alejandra Jackson / Jackie Jackson/ Janet Jackson/ Jermaine Jackson / Marlon Jackson / Rebbie Jackson / Randy Jackson / Taj Jackson / Tarryl Jackson/ TJ Jackson / Tito Jackson / Trent Jackson / Quincy Jones / Kathy Jorrie / Michael Kane / Arnold Klein/ Michael Laperruque / Cherilyn Lee / Spike Lee / Tim Leiweke / Hendrikus Lemmens (removed) / Carlos Letelier DDS / Arlyne Lewiston / Detective Orlando Martinez / Dr. Gordon Matheson/ Cindy Medina / John Meglen / Tom Mesereau / Dr. Allan Metzger / Tom Miserendo / Amy Morrison / Roselyn Muhammad / Dr. Conrad Murray / Barry Nadell/ Prince Rogers Nelson / Kenny Ortega / Sharon Osbourne/ Ray Parker Jr / Amy Pascal/ Travis Payne / Lisa Marie Presley / Howard Rile / Dr. Christopher Rogers / Diana Ross / Debbie Rowe / Amir Dan Rubin/ Alif Sankey / Dr. Lakshamanan Sathyavagiswaran/ Madeline Schilder / Dr. Sidney Schnoll / Jean Seawright / Paramedic Richard Seneff / Dr. Myer Shimelman / Barry Siegel / Dr. David Slavit / Janice Smith/ Scott Smith/ Dr. Alon Steinberg / Dr. Barry Swerdlow / Mark Tadrisi DDS / Evvy Tavasci /Tohme Tohme / Shawn Trell / Anthony Urquidez / Carl Virgil / Daniel Wallace / Frederick Webking / Bill Whitfield / Debra Willis / Dr. Daniel Wohgelernter / Timm Woolley
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AEG Live full possible witness list - as of April 15
(Additions in green, removed names in red)
Dr. David Adams / Jeffrey Lee Adams / Marcel Avram / Irving Azoff / Tom Barrack / Michael Bearden / Daniel Beckerman / Martin Blount / John Branca / Ellen Brunn / Jeffrey Telle Cannon / Frank Cascio / Melissa Elias/ Dr. Alimorad Farshchian / Lou Ferrigno / Dr. Stuart Finkelstein / David Fournier / Kenneth Froelich / Paul Gongaware / Dr. Stephen Gordon / Dennis Hawk / Julie Hollander / Dorian Holley / Dr. Hosny Habashy / John “Bugz” Houghdahl / Janet Jackson / Jermaine Jackson / Joe Jackson / Katherine Jackson / Latoya Jackson/ Prince Jackson/ Paris Jackson / Randy Jackson / Rebbie Jackson / TJ Jackson / Tito Jackson/ Kathy Jorrie / Michael Kane/ Dr. Lawrence Koplin / Bruce Lang / Michael La Perruque / Cheryln Lee / Arlyne Lewiston / Joseph Marcus / John Meglen / Dr. Allan Metzger / Kim Moore-Mestas / Amy Morrison / Steven Lloyd Mortensen/ Roselyn Muhammad / Dr. Conrad Murray / Consuelo Ng /Sarah O’Leary Sinnorai / Kenny Ortega / Bob Parks / Travis Payne / Randy Phillips / Jeffre Phillips / Dr. Christine Quinn / Dr. Neil Ratner / Debbie Rowe / Dr. Gordon Sasaki / Dr. Scott David Saunders / Madeline Schilder / Richard Sherman / Barry Siegel / Dr. David Slavit / Janice Leigh Smith / Dr. Mark Tadrissi / Evvy Tavasci / Dr. Tohme Tohme / Shawn Trell / Anthony Urquidez / Dr. William Van Valin II / Dr. Carl Virgil / Stacy Walker / Frederick Webking / Bill Whitfield / Alan Whitman / Timm Woolley / Taunya Zilkie
Retained experts : William Ackerman / Eric Briggs / Arnold Dicke / Dr. Paul Earley / William Flynn (removed)/ Dr. Gary Green / Marty Hom / Dr. John R. Iacovino (removed) / Dr.Norman Elliott Lepor/ Dr. Petros Levounis / Mark Allen Roesler (removed) / Dr. Christine Nai-Mei Sang / Dr. Karl Williams(removed) / Rhoma Young
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Estate's motion to seal medical records / depositions dated April 15
Estate mentions they have filed 3 motions to seal in this case to protect Michael's confidential medical records and/or information. Estate points out Court of Appeals have agreed that Estate has made a convincing argument that the documents continue to be kept under seal for the time being. Estate also has 2 more motions set to be heard in August 2013.
Estate argues that some of the medical matters being discussed at Murray criminal trial does not make the rest (the ones not mentioned at Murray's trial) public. Estate also points out that the court had previously agreed that medical records and depositions discussing those medical records should be sealed.
Estate mentions they aren't a party to the case, they did nothing to put Michael's medical information at issue. Estate also points out that a criminal trial does not constitute for Estate waiving doctor-patient privilege.
(Ivy's note: Michael's medical records are still conditionally under seal but there will be hearings in this regard this week. Some of the seal / protective order might be removed or some medical records can come public during the trial)
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AEG's opposition to release jury questionnaires
AEG states that jury questions included sensitive personal information, the media have reported many personal and identifying information and zealous MJ fans are attending the proceedings and seeking out personal contact with parties and their lawyers.
AEG argues if the jury questionnaires are released such sensitive personal information that the jurors provided will be posted all around the Internet and remain there forever. This will hurt jurors privacy. AEG argues that the jurors weren't told that the questionnaires could become public and they weren't given the option to answer questions in private - and not in writing.
AEG argues that passionate MJ fans and media would use these information to identify the jurors. AEG argues MJ fans can seek out the jurors and even try to influence and intimidate and even threaten them - or at least have inappropriate communications with the jurors. AEG again mentions one specific fan and their experience with that fan as evidence that MJ fans "more than willing to resort to such extreme measures".
AEG also argues that if these questionnaires become public , in the future high profile cases potential jurors will not be honest in fear that the information they provided could become public too.
So AEG asks the judge to not release the juror questionnaires or in alternative release redacted version. The motion states that Katherine's lawyers want the jury questionnaires to be released.
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AEG's motion to preclude Katherine's past due discovery
AEG is trying to exclude 4 late trial discovery issues coming from Katherine. The information below
1. Late produced documents:
In April 2011 AEG had asked for documents from Katherine about Michael's relationship with Katherine and his kids. Katherine objected and refused to produce any documents. April 2012 before AEG filed a motion to compel Katherine, they have provided 140 pages to AEG. AEG kept asking Katherine to give them the rest - final requests being at February and March 2013.
AEG states on April 1st 2013 - one month after the discovery cutoff and 1 day before the trial start - Katherine provided them more documents including pictures and videos and said they can give other stuff later on.
AEG is asking the court to exclude these stuff that was given to them late on April 2013.
Note: Some stuff provided to AEG includes the following (not a full list)
March 6 : 5 pages of notes and doodles by MJ's kids, 68 pages of notes and ideas in MJ's handwriting, 30 pages of business documents
April 1 : May 2009 family photo, photo of a toddler and bathtub, school photograph, little league photograph, home video of Michael giving his children a puppy on Christmas & a lot of photos from MJ's photo shots with his kids.
2. Late identified witnesses
AEG is stating March 14 was the deadline to submit witness lists. Yet Katherine have added Tom Mesereau as a possible witness on March 21. On April 3rd they added Sharon Osbourne. On April 15 - one month after the witness deadline - Katherine has added 14 more people to her witness list.
AEG says Katherine only provided explanation to why she wants to call Tom Mesereau as a witness and did not give any explanation to why she wants to add the other 15 people and why they didn't do that on time.
AEG states Tom Mesereau's testimony is not necessary as AEG will stipulate that Michael was acquitted in 2005 trial. AEG argues Katherine should not be allowed to call the other 15 people that have been added late to the witness list.
3. Late identified and improper designation of William Ackerman
Ackerman is a CPA and an retained expert for AEG. He is expected to talk about Michael's finances , the support Katherine received from Michael and any alleged economic loss.
On April 9, Katherine's lawyers say that they will cross list Ackerman as a fraud expert.
AEG states a) time to designate experts have passed b) fraud is not a cause of action in this case c)fraud is not an area of expertise for Ackerman. So AEG argues Katherine's request to cross-list Ackerman as a non-retained fraud expert should be denied.
Note : the motion mentions Katherine want to elicit Ackerman's opinion that a certain document is somewhat fraudulent. This document was produced more than 9 months ago (June 27 2012).
4. Katherine's improper non-retained experts should be excluded
Katherine had listed more than 84 non-retained experts. AEG had previously went to court and the court have ordered Katherine to limit her non-retained witnesses to the ones she intends to call during trial. March 18 was the deadline for this. However Katherine have not withdraw anyone from her non-retained witness list.
AEG states on April 15 - one month after the deadline- Katherine withdraw some experts and added some new ones. Her current non-retained expert list includes entire LA Police, Fire and Coroner departments.
AEG is asking the judge to excluded parties that have not been individually identified such as "entire LA coroner"
4. Late requests from MJ Estate
January 2013 Katherine's lawyers filed a request from MJ Estate asked Estate to give them documents from AllGood and Lloyds lawsuits. Estate objected to this request stating that all the documents were protected by protective order by respective courts. Katherine's lawyers never filed a motion to compel (asking the court to order the Estate to give them the documents) April 12 - 3 months after Estate's rejection and 2 weeks after motion to compel deadline - Katherine is again asking for the same documents from MJ Estate.
AEG is asking the judge to prohibit such late discovery.