The exhibits attached to the Motion are as follows:

Exhibit 1-10: Company documents of MJJ Productions and MJJ Ventures.

Exhibit 11: Deposition of Joy Robson - September 30, 2016 (excerpts)

Exhibit 12: Deposition of Jolie Levine - January 11, 2017 (excerpts)

Exhibit 13: Deposition of Gary Hearne - September 2, 2016 (excerpts)

Exhibit 14: Deposition of Gayle Goforth - October 24, 2016 (excerpts)

Exhibit 15: November 17, 2012 E-mail Between Joy Robson and Wade Robson

Exhibit 16: Trial Testimony of Wade Robson (May 5, 2005)

Exhibit 17: Screenshot of Page on Website of McDonald Selznick Associates

Exhibit 18: Order Denying the Petition of Wade Robson for Order Allowing Filing of a Late Claim Against the Estate of Michael J. Jackson

Exhibit 19: Excerpts of Draft Book of Wade Robson (conditionally filed under seal)

Exhibit 20: E-mail Sent from Wade Robson to Himself, October 22, 2013 (conditionally filed under seal)

Exhibit 21-22 : Declaration and Certificate of Merit of Henry Gradstein in Support of Complaint Against Doe 2 & Doe 3 (conditionally filed under seal)

This post will discuss in detail the bolded exhibits in the list above. Before we start, we would like to add a clarification about the ones are not included in this post. Exhibit 1-10 are company documents of MJJ Productions (MJJP) and MJJ Ventures (MJJV), which prove the Estate’s claim that MJ was the sole shareholder of MJJP and MJJV, at all relevant times. There isn’t much more to add about that, so we have found it it unnecessary to include 85 more pages of company documents. Two other exhibits, Wade Robson’s testimony from 2005 (Exhibit 16) and  Judge Beckloff’s ruling to dismiss Wade’s Probate petition (Exhibit 18) are already well-known and available online. Exhibit 19-22 are conditionally under seal as per Robson’s request and are therefore not available in the redacted  public version of the Motion.The other exhibits and declaration of John Branca can be found below.

John Branca Declaration:

Joy Robson Deposition Excerpts and email:

Jolie Levine, Gary Hearne and Gayle Goforth Deposition Excerpts:

Deposition of Joy Robson

Possibly the most interesting piece in this motion, are the excerpts from Joy Robson’s deposition. In what we can only assume to be unintentional, Joy’s deposition is pretty damning to Wade. Not only it contradicts Wade’s legal arguments that Wade was exposed to Michael Jackson as an inherent part of the environment created by the relationship between Michael and MJ Companies, it also exposes Wade as an unscrupulous liar, who is willing to claim just about anything to get the money he wants.

Let us get this straight: Joy is on Wade’s side. She says she believes him and his current allegations. At times she goes out of her way to be supportive of Wade, but from what we could gather from these excerpts, she is basically telling the same story she has told in 2005, at MJ’s trial. Only in the hindsight of Wade’s allegations, she occasionally reevaluates certain events and attaches remarks (Things that Wade is telling her now), loaded language and perhaps embellishments, to be supportive of Wade’s current claims. Her core story, however, is actually consistent with the one she told under oath in 2005 (at least in these parts that we are discussing here. We do not have all of her deposition, only what is relevant for the purpose of this summary judgement).

Indeed, Joy’s story, is totally contradictory to the story that Wade is telling in his complaint. Taking into consideration the fact that Joy stated in her deposition she had not been talking to Wade about his lawsuit because “I don’t consider that my business”, we do wonder if Joy is even aware of everything her son alleges. Maybe she prefers to remain in blissful ignorance about that, otherwise she would have to concede that her son is a shameless liar.

So let’s see what Wade alleges vs. what Joy says one by one.

The dance contest that Wade won in 1987 and the resulting “meet-and-greet”

Wade Robson’s allegation: "Plaintiff alleges these "meet and greets" were purposely orchestrated by MJJ Productions and MJJ Ventures as a sexual grooming mechanism to acquire minor sexual abuse victims for Michael Jackson, disguised as charitable events for minors." (Robson’s Fourth Amended Complaint - FAC, page 5)

Joy Robson’s deposition: Far from what Wade alleges, Joy testified that the contest was sponsored by Target, Pepsi and CBS Records. Not only that, but after a meet-and-greet that they had with MJ and a performance on stage the next night, it were the Robsons who sought contact with MJ again by delivering a “thank you” note to him in his hotel room. After a one and a half hour meeting, they left and they did not meet or even talk to MJ again until 1990, when once again the Robsons were the ones who were seeking to contact with him.

It is not like Wade was not aware of all this when he decided to lie in his complaint. We already know by now that he filed his lawsuit, he had a very detailed e-mail correspondence with his mother about the events and circumstances around the relevant period of time. Not only that, in his 2005 trial testimony, Wade himself mentioned regarding that 1987 dance contest that it was Target who was “holding these dance, like, contests all around wherever (MJ) traveled”. Of course, he knows the story of how the Robsons first met MJ and that they were the ones who kept trying to get a hold of him, not the other way around.

There is only one conclusion to be made - Wade deliberately lies in his complaint to try to implicate the MJ companies in order to get the money he wants.

Meeting MJ again in January 1990

Wade Robson’s allegation: "Plaintiff is informed and believes, and on that basis alleges that Ms. (Norma) Staikos was acting on behalf of MJJ Productions and MJJ Ventures, as a "madam" or "procurer" of child sexual abuse victims for Michael Jackson. Although disguised as another charitable "meet and greet" between Plaintiff, his parents and Michael Jackson, this event was purposely orchestrated by Ms. Staikos, MJJ Productions and MJJ Ventures as a further means for Michael Jackson to acquire another sexual abuse victim and grooming him and his parents for such." (FAC, page 6)

Joy Robson’s deposition: Joy says she was the one initiating the next meetings with MJ's during their visit in USA, 1990. According to Joy, the companies and Norma Staikos were incidental to the event - it just happened that Joy was able to contact MJ through MJJ Productions and Staikos (MJJ Ventures did not even exist at the time). It was Joy’s goal to meet MJ.

Joy says in her deposition that between 1987-1990, she had sent MJ several letters about Wade and videos of him, hoping to get in touch with MJ again, but all of those remained unanswered. Then, in January 1990, the Robson family came to the USA for Wade and Chantal to perform at Disneyland with the Johnny Young Talent School. Before leaving Australia, Joy Robson already tried to obtain contact information of Michael, by calling Australian TV channels and asking if they had any sort of contact for him. She got a number for TriStar Pictures, and then after some more rounds she eventually managed to obtain MJJ Production’s phone number. While in the US, Joy managed to contact Norma Staikos who, at Joy’s request, arranged for the Robson family to meet Michael at a recording studio. Michael then invited the family to Neverland Ranch.

How does that make Norma Staikos “a "madam" or "procurer" of child sexual abuse victims for Michael Jackson”?

Certainly, Wade is completely aware of the true story. It was told in earlier testimonies and police interviews from 1993 and 2005, and like we pointed out he was also in a detailed e-mail correspondence with his mother about these events, to help him put together his story before j he filed his complaint.

It is clear that it was Joy Robson who “purposely orchestrated” the meeting. The conclusion can only be that Wade deliberately lies in his complaint to try to implicate and slander the MJ companies and Norma Staikos, in order to get the money he wants.

The MJ Companies’ sponsoring and/or hiring of Wade Robson and his mother

Wade Robson’s allegation: "In order to arrange for their immigration to the United States, Michael Jackson had MJJ Productions and MJJ Ventures hire Plaintiff and his mother, and arranged for Plaintiff, his mother and sister to move permanently to California. Plaintiff alleges this was done by Michael Jackson, MJJ Productions and MJJ Ventures for the explicit purpose of allowing Michael Jackson access to Plaintiff for sexual abuse." (FAC, page 10)

Joy Robson’s deposition: According to Joy, the idea of immigrating to the USA was her husband Dennis’ idea (“It was actually Dennis's idea when we were here in the January (1990) -- and we were at Disneyland. It was his idea then."). After their first January/February 1990 trip to Neverland, Joy and Wade returned to USA to participate in an L.A. Gear photo shoot with Michael in May 1990. (L.A. Gear paid for this visit - not MJ’s companies.)

Joy claims MJ was excited about Wade's talent saying things like "Little one and -- and I are going to rule the world" and this made them think more seriously about immigrating with the hope that MJ could help Wade’s career. She could not remember when she made the final decision ("perhaps after the February (1991) trip") - although they had consulted a lawyer about their plans to immigrate before November 1990. Joy clearly stated that the reason they wanted to move to the US was to pursue Wade's career in the entertainment industry.

The Companies’ role in all this was that when Joy eventually decided to immigrate in September 1991, the Robsons needed a sponsor. Joy Robson asked MJ to help them with that, and MJ instructed his office to do it. (He instructed them, not the other way around.) During her deposition, the lawyers brought up quotes from her 2005 testimony: "And did you ask him to do that?" And you responded: "Yes, pretty much. Basically, I asked for help, so that was the only way we could stay, so yes." Also quoted from her 2005 testimony: "Did you feel like you owed him anything after he helped sponsor your family to stay in the U.S.?" And your response is: "No, not at all."

The following quote was not mentioned in Joy’s deposition excerpts, but in 2005 Joy testified that MJ started sponsoring them only after they had already been in the US for six months:

Do you recall telling and testifying to the fact that what actually happened in September of 1991 is that Mr. Jackson was your sponsor when you came to the United States with your son?

Not initially. We were here for six months and then he offered, he offered to sponsor after we arrived.

By the way, in 2005 Joy also testified that after they immigrated to the US they hadn’t been spending a lot of time with MJ.

Q. And then from that point, from September of 1991 up till, let’s just say, September 1993 - okay? - the time frame involved, you and your son spent a great deal of time with Michael Jackson, you were around him a lot, correct?

Joy Robson: I don’t think so.

Q. You were not at the ranch on a number of occasions during 1991?

Joy Robson: My memory is in the entire time we’ve lived here since 1991, we’ve only been at the ranch with Michael on four occasions in 14 years.

Q. Four occasions?

Joy Robson: Every other time we’ve been here without him.

Q. Would that be the same for your son?

Joy Robson: Yes.

 Joy also stated that it was up to her to do everything in order to further Wade’s career and to survive in the US. The Companies’ lawyer asked Joy, quoting an interview that she had given in 2011:

“You also said: "I realized very early on that if we were going to make it here, it was going to be up to me. I couldn't really rely on" -- and you said, "Michael kind of lived in a bubble and had a different reality to ours. And so I was the one who had to find agents." Do you remember that?

JOY ROBSON: Yes. (...) The funny part is Wade -- Michael did find an agent for Wade, but it was CAA (Creative Artists Agency), and Wade was 7 years old and not known in this country. And CAA was not going to be any -- and that's why I said Michael lived in a bubble. He had no idea of anything outside of his realm. So -- Wade wasn't in that category for CAA. It would not have been beneficial for him to be with CAA.


JOY ROBSON: Michael tried to help, but he just didn't understand what needed to be done.

MS. KLEINDIENST: And when you were asked if you really had to manage Wade's career, you responded: "I did. I did everything." Is that right?

JOY ROBSON: I did what I had to do to -- to make things happen.

(Clearly, Joy’s portrayal of MJ as “living in a bubble” goes against Wade’s current portrayal of MJ as this shrewd maffia boss running “the most sophisticated child sexual abuse procurement and facilitation organization the world has ever known”.)

As we know, Joy said Wade was in three videos with MJ (Black or White, Jam and Heal The World) and he was paid around $200 each for Jam and Heal the World and $500 for Black or White. That would obviously not pay their bills and facilitate their continued stay in the USA.  “Nobody pays bills with money from videos”, said Joy in her deposition. She said they survived on their own reserves.

So rather than the immigration being arranged in some evil plot by the Companies, it was arranged because Joy wanted to move to the US with Wade and Chantal, to pursue Wade’s career. When she made this decision, she asked MJ to help them with the sponsoring and/or hiring, and in turn, after the Robsons had already been in the US for six months, MJ instructed his companies to do so. Furthermore, according to Wade’s own mother, once they moved to the US, they rarely even met MJ. Given the detailed e-mail correspondence between Wade and his mother, once again we are lead to think what Wade alleges is another deliberate lie.

The Charli Michaels story

On page 9 of his Fourth Amended Complaint (FAC), Wade Robson tells a story which is based on a witness statement by Charli Michaels from the 1993-94 investigation, to support his claims. Charli Michaels was a female security guard who was working at Neverland in 1990-92. She is one of those disgruntled ex-employees who, in the wake of the 1993 Chandler allegations, went to the tabloid media, to be paid for stories about MJ (Charli Michaels was on three of Diane Dimond’s Hard Copy shows, telling her story, and then she also joined a lawsuit against MJ, which was later dismissed).

The problem is, this story is a false story and Wade knows it. That on Mother's Day 1990 Charli Michaels found Joy Robson crying at Neverland and upset, is true, but the rest of the story is an invention by Michaels. Joy already testified about it in 2005. She said that she was upset and crying because she could not find Wade all day and it was Mother's Day, so it hurt her that Wade would rather spend the day with MJ than with her.

However, Charli Michaels put a twist on this story. She claimed that Joy was upset "because she was restricted from seeing (Wade) while he was in the company of Michael Jackson. (Joy) said that Norma Staikos had told her that Michael Jackson and (Wade) were rehearsing a dance routine in the theater at Neverland, and that (Joy) was not to disturb them during the rehearsal. (Joy) also told Ms. Michaels that Ms. Staikos had prohibited (Joy) from sleeping in the main house at Neverland while Wade was staying in Michael Jackson's room."

Joy’s own version is totally different - and now she repeated the same story that she told in 2005: she was crying and upset because it was Mother’s Day and couldn’t find Wade and because he spent the day with MJ rather than with her. She does not claim that Norma Staikos restricted her from seeing her son while he was with MJ. In fact, her story is contradictory to Charli Michaels’ story. Michaels claimed that Staikos told Joy where Wade and MJ were (rehearsing in the theater), but she also told her not to disturb them. In contrast, Joy said she did not find them all day (“I'd spent the whole day looking for him” and “I would spend my time on a golf cart driving around the ranch looking for them”.)  Why would  she do that if she had been told by Staikos where they were?

It is also not true that Joy was prohibited from sleeping in the main house at Neverland while Wade was staying in MJ’s room. In her 2005 testimony Joy said that she would typically stay in the “rose bedroom” during their visits at Neverland. It is in the main house, the same house where MJ’s bedroom is. She also stated in her 2005 testimony that she was free to walk in and out of MJ’s bedroom while at Neverland and MJ never put any restrictions on that. She stated that she could go to MJ’s bedroom “at any time I wanted” and that she never got the feeling that anybody was trying to keep her out of MJ’s room.  

It is clear why Wade would rather want to embrace Charli Michael’s version of the story than his mother’s. Because it involves Staikos (unlike his mother’s version) and through Staikos he is trying to implicate the companies. But the thing is, Wade knows that the version he uses is untrue -  his mother told him that in an e-mail exchange on February 15, 2016. Despite of that Wade put the untrue version of the story in his Fourth Amended Complaint that was filed in September 2016.

Once again, it shows him as a person who does not have any qualms about lying in court documents and to knowingly embrace untrue stories if they serve him. (And most probably, that is the same when he embraces stories by other highly questionable “witnesses”, such as Blanca Francia or Mariano Quindoy.)

Joy Robson: “Wade should have had an Oscar”

In her deposition Joy stated that she never believed MJ molested children until her son changed his story in 2012. In fact, Joy stated that Wade was always very convincing in saying that MJ did not molest him. Through quotes from Joy’s 1994 deposition we learn that when, in the wake of the Chandler allegations, Joy asked her son if he was molested he was very convincing in saying that he was not. She still thinks he was convincing. Only in the hindsight of Wade’s allegations she adds what Wade is telling her now about allegedly being “groomed” by MJ on the phone to be that convincing.

"Did your son respond?" And you said: ' "Yes." He said: "What did your son say?". You said: "He laughed and said it was ridiculous." Was that accurate?

Joy Robson: Yes.

And you believed Wade when he said it was ridiculous, right?

Joy Robson: He was very convincing. And, you know, I --I look back at it now, and he's -- he's told me how he was groomed for this, and Michael would talk to him about that. And I -- I had no idea that that was going on. That was what these conversations were on the phone a lot, where he was being groomed and taught what to say. And he did a good job. He had me convinced. He was -- he would look me in the eye time and time again and tell me that nothing ever happened. And I believed him. I thought -- I thought that he would be telling me the truth. But he was so frightened by what he was being told on the other end, he was too afraid to tell me the truth.

That's what you've since learned, right?

Joy Robson: Yes.

But throughout the time up until passed --

Joy Robson: He was very convincing.

Yeah. And throughout -- up until after Michael passed away, he always was very consistent in his story to you that nothing ever happened?

Joy Robson: He was.

And he was believable?

Joy Robson: He was -- he should have had an Oscar. He was very convincing.

(BTW, Wade claims that MJ “groomed” him in a similar manner over the phone in 2005 as well - as an adult man.)

She found MJ equally convincing in stating his innocence when the Chandler allegations surfaced. MJ told her that the Chandlers were after money and that they were trying to extort him. Also based on her own encounter with June Chandler, Joy felt that June was after money.

In an e-mail she wrote to Wade on November 17, 2012 (Exhibit 15), she stated this about MJ: "He just seemed so innocent that I really never thought that there was any truth to the allegations." She also reflected on the the Chandler allegations: "When the Chandlers accepted a settlement from him, that just convinced me that it was all about money, because I would never have been able to let it go for money if I thought he had touched you. I remember saying at the time that no amount  of money would make that OK for me. I would not have stopped until he was behind bars. I still feel that way."

For the record, MJ told Joy the truth about the Chandlers: they really were after money and nothing else. For details (richly sourced from the Chandlers’ own book) see this website and particularly the following articles: The Chandlers’ Monetary Demands , The Settlement).  

Final thoughts

It is understandable that a mother would always want to stand by her son and believe the best of him, rather than thinking he is an unscrupulous liar, who could throw his dead friend under the bus like that for money. However, we do have to wonder:

  • Does Joy Robson REALLY believe that the MJ’s companies were “the most sophisticated child sexual abuse procurement and facilitation organizations the world has ever known”, that Norma Staikos was “a "madam" or "procurer" of child sexual abuse victims for Michael Jackson”, that the companies were responsible for Wade’s alleged abuse, when according to her own story they were incidental to the events and it was Joy herself, not the companies, who “purposely orchestrated” the meetings with MJ?

  • Does Joy Robson REALLY believe that the MJ she describes as “living in a bubble” could run and operate “the most sophisticated child sexual abuse procurement and facilitation organizations the world has ever known,” as Wade alleges?

  • Is Joy Robson aware of the fact that, in his complaint, Wade used Charlie Michael’s version of the Mother’s Day story, instead of hers, despite of Joy telling him in e-mail that Charli Michael’s story was not true?

  • Is Joy Robson aware that during the probate court proceedings, her son claimed that he did not know about the administration of the MJ Estate, until shortly before he filed his lawsuit in 2013 - because that’s what he needed to claim to try to make his creditor’s claim survive? And he claimed that despite meeting the executor of the MJ Estate, John Branca in latter’s office in 2011 to talk about Wade directing a Cirque du Soleil MJ show.

  • Did it ever occur to Joy Robson that maybe instead of both MJ and Wade being these convincing Oscar-winning, lifetime liars, it is NOW that her son is lying when his turnaround comes with a monetary demand?

  • And if Wade is lying about these things above what should make us think he is not lying about the sexual abuse part? This is a man who is willing to make any false claim to get around legal obstacles, and get the money he wants. That is not a sign of someone speaking “his truth,” let alone fighting for justice. The only thing that Wade is fighting for here is money, not the truth.

The Other Exhibits

The other attached deposition excerpts (Jolie Levine, Gary Hearne, Gayle Goforth) are much shorter than Joy Robson’s. (By the way, all three were called to be deposed by Robson.) The attached parts focus on the issue of who controlled the MJ Companies, and whether employees had control over MJ. All three unequivocally say that it was Michael Jackson who controlled the companies and the employees. It was not the other way around. He had no boss, he was the boss.

Jolie Levine, who used to work as a personal assistant for MJ, also stated: "I never believed that he was a pedophile and I still do not believe that Michael was -- is a -- was a pedophile." She also stated that she never saw MJ touch a child in any inappropriate or sexual way.

Gary Hearne was MJ's driver for 15 years between 1991 and 2006. He too stated that he had never seen any inappropriate or sexual behavior or touching by MJ to any child. Hearne also testified that he had never experienced any kid having to hide in the car while bringing them to Neverland.

And shortly on Exhibit 17: it is a screenshot of the McDonald/Selznick Associates talent agency which still features the comment that Wade Robson made of Michael Jackson after his death in 2009: "Michael Jackson changed the world and, more personally, my life forever. He is the reason I dance, the reason I make music, and one of the main reasons I believe in the pure goodness of human kind. He has been a close friend of mine for 20 years. His music, his movement, his personal words of inspiration and encouragement and his unconditional love will live inside of me forever. I will miss him immeasurably, but I know that he is now at peace and enchanting the heavens with a melody and a moonwalk. I love you Michael."

Ivy's note: MichaelJacksonAllegations prepared this post and another friend did the editing. I want to thank them for their colloboration and help with the Robson/Safechuck and Doe cases.