wervanauns SHERIFF'S DEPARTMENT CONTINUATION SHEET 03-5670 1A} UST CONTMUATION. {0} DESEARE: PHYSICAL EVIDENCE LOCATION FOUND & DISPOSITION, [6] HARRATNE, (9) CHPOSTION. “PAGES [3 (HIESIb z : a eSend eiilataat “aed sete te tome abe. innitoce, of these The next item of evidence I reviewed, was Teem Number 507, which was described as being 2 piece of notebook paper, which had the same logo as Item Number 504. 1 found this item te be a blank sheet of notebook paper, which had the samc (boy sitting within a cizele) drawing as noted with regard to Item Numbor S0¢. There was no visible writing on the front, oz rear of this item. Sy holding the dtem at an oblique angle tc che available lighting, I could see what appeared to be impressions made by someone writing on the pieces of pazer, which were on top of this item. I could not decipher the latent writings on thie item. Thia item would need to be forensicaliy processed in orde= to develop any latent writings. The next item of evidence I reviewed was Item S04, which described a book depicting nude children. Thie item was located in the upstairs library xcom of the video/arcade area. I found this to be @ soft-covered book titled, Sex. 1 RO listed authn. I reviewed each page of this book and did oot locate any foreign pictures and/ or writings insezced within the book. The vast majority of the pictures were of teenagers and/ or young adulzs. Some of the pictures depicted individuals wearing no lething, or in a state of partial drsas. The theme of the bock seemed to be adolescents and counter culture. None of the material within this book would meet the legal requirements to be considered child pornography. Based on my training, this typ cf material can be used as pert of a “grooming” process by which people (thosa seeking to molest children) aze able to lower the inhibitions of their intended victims and facilitate the molestation of said victims. The next item ef evidence I eviewed wae Item Numbez 509. This item waa described as a beok depicting nude childzen, which was located in the upstairs library room of the video /arcade area. f found this item to be a hard-covered book titled. Seagea. suchen Pere Formiguers. 1 reviewed each page of the book and did net find any inserced pictures and/ cx writings, which did not appear te be an original port “of the book. The book appeared to be a compilation of numercus photograchs depicting men, women, end childzen of both sexs. The majority of the photographs depicted the subjects completely unclothed, including the male and female chijdren. The apparent Uheme of this book was the depiction of ot?t PLE hey X3S HEYNOF FHL iwarnusuns SHERIFF'S DEPARTMENT GONTINUATION SHEET TA] UST CONMNUATION. (2} DESCRIE: PHYSICAL EVIDENER, LOCATION FOUND & DISPOSITION, (6) NAARATIVE. [2 DISPOSITION, physiesl and/ or appearance changes of people as they aged. None of the material within this bock vould meet the legal requixements to be considered child pornography. Aased on my training, this typo of naverial csnabeallGiaSt Partai d "grooming" process by which people (those seeking to molest children) are able to lower the inhibitions of their intended victims and facilitate the molestation ef said victims. - The next item of evidence I reviewed was Item Numer $10. This iten was described aa heing two bags of miscellancous underclothes and bloodied hed linen. ‘These items were located in the upstairs library room of the video/ arcade axea. The firet bag was 2 plastic Disneyland bag and the second was a plaotic Garden City Hotel bag. The Disneyland bag contained a red Prada brand, leng-sleeve shizt, size 39/15%. The bag alco contained numerous ompty small plastic bags and several dirty socks, which appeared to be of adult size. Z Slsc fousd the bag to contain a white cotton sheet with reddish brown staine on it, which I believed ware consistent with blood staining. The Garden City Hotel bag had a white Harbor Bey long-sleeved cotton shirt, size 2xLT; a folded cotton bed saeet; a pair of bright orange, size 4 pants, possibly for a young girl; a new pair of Spiderman socks with label attached; and numerous pairs of size 30 cotten briefs (various brand names including Jockey, ‘Calvin Mein, Fruit of the Loom, Nordstrom's. and Sake 5” avenue). The underwear sppeared to he used but were clean. ‘Two of the Jockey Brand briefs were size 32. In total, there were nine pair of men’s cotton brief underwear. Some of the briefs had discoloratione and/ er stains, but all pairs appeared to have been washed. 1 also found 3 Jockey brand, size medium, cotton V-neck T-shirt, 2 blue Tommy Hilfiger polo ‘shirt, which did act appear te have keen worn Qabeling and price tags still on the shirt); there was also a size medium pair, of what appeared to be pajama bottoms; a-child sized off-white, short-sleeved shirc; a pair of gray, white, and blue child-sized socks, which have boy embroidery in them; ene adult~ ized, dress sock: one juvenile-sized, dress sock; end one pair of juventle-sized socks with pink roses. At this point, I insured each of che above items of ¢vidence were put back into Lheir original packaging and placed an evidence seal ot?woroMauno SHERIFF'S DEPARTMENT CONTINUATION SHEET 161 UST CONTNUATION. (5) OESCAIBE: PHYSIGAL EVIDENCE, (OEATION FOUND & ISPOSTTION, (6) NARRATIVE. [} GISPOOTTON, 03-5670 over the cut I made to remove the items from the ozigdaal packaging. I returned all items of evidence (excepting item number $17) that I: checked out during the morning of 12-2-03 to SRSO Property Officer Chuek Villarreal. I took Item Number $17 to che SBSO Ferensic Bureau and requested Detective’ Tim Sutcliffe make a working copy of Item Number $17, compact disc. I steod by ae Dotectivy Sutcliffe utilized & Forensics Bureau computer to make a duplicate of Item Number $17. Immediately after Datective Sutcliffe Einished making the copy of item Number 517, he provided the original item, as well as, the working copy to me. I repackaged the criginal CD and retained the working copy. I provided the working copy te Sergeant Rabel, who secured it within a safe. I insured item number 517 was put back into its original packaging and placed an evidence seal over the cut I made to renove che item from the original packaging. I tock item number 517 te S860 Property Officer Chuck Villarreal and returned the item into property. During the afterncon of Tuesday, 12-2-03, I xe-contacted SBSO Property Officer Chuck Villarreal and checked out additional items ef ovidencc. The purpose at cheekiny out che items cf evidence was’ te cerutinize each item and determine its evidentiary value. Specifically, I checked our Item Numbera 302, 304, 305, 206, 307, 208, 323, 515, 518, 10D1, 1002, 1003, 100¢, 1005, 1006, 1007, 1008, 2009, and 1020. I began by reviewing Item Mimbex 302, Ibem Number 302 was deseribed as being 5 pornographic magazine located within the master bathroom at the Neverland Ranch rceidence. Upon opening this item, I found it to be s periedicsl entitled, “The Bes Club", 4 : The cover of the periodical indicated was te be displayed on store shelves until June 30, 2003. I reviewed each page of this periodical and did not leeate any foreign pictures and/ or writings, which were not an original pare of tke magszine. This item appeared te be a commercially manufactured magazine and did aot contain pholugrephs that depicted illegal activities. Based on my training, this type of materia] can be used as part of a “grooming” process by which people (those seeking pioBSAAASDEIGoo~ansons SHERIFF'S DEPARTMENT PAGE 3 Santa Barbara County 03-5670 CONTINUATION SHEET The next item of evidence I reviewed was Ttem Number SoS, Thi three books with photegraphe of nude item was described as bei Upon opening the evidence packaging, I found the items te be packaged within a second sealed paper bag. I broke the seals on the second paper bag. Withir this package, I found three hazd gover books. ‘The first book was titled, UJ |, author Kelly Klein. The second book was titled, , author Simen gehan. ‘The third book was titled, Dzew and Jimmy, author Jokn Patrick Salisbury. I reviewed each page of the book titled underworld and did’ not find any inserted pictures and/ or writings, which did not appear to be an original part of the book. The book contained numerous photographs of partially and/or fully unclothed men, women, and ‘children. The majority of the pictues within thie kook are of people who were wearing only their undexwear. I reviewed each page of the book cicled Room to Flav and did not find any inserted pictures and/ or writings, which did not appear to be sn original part of the beck. This book contained numerous photegzaphs of children, some of which appeared to be altered ouch Anetnerahivg aschiidiantng onto the bedy of an older person. This “nexphing” was used to ‘sexualize’ the photos by enhancing tke child's anavemica: features. Many of the pictures expesed the private areas of the children. 7 I reviewed each page of the book titled Drew and Jimmy and did not find any inserted pictures and/ or writings. which did not appear to be an original part of the book. ‘The book contained numerous photographs of two Caucesien male juveniles that appeared to be in their early to mid-teens. The boys in these photographe are primarily clothed with occasional photographs of them wearing swim- trunk type clothing. None of the above noted books contained materials, which depicted illegal activities (including sexual acts with children). None of the books would meet legal requirements to be considered child pornography. Based on my training, this type of materjal can he od77Brom 7? P17 my ¥wervaueuns SHERIFF'S DEPARTMENT Santa Barbara Count: 03-5670 CONTINUATION SHEET [A USTGONTFIUATION. (a) OESGRIRE, PHYSICAL EUDENGE, LOCATION POUND DISPOSITION, (€] NARRATIVE, (0 SISPOSITION, to molest children) are able to lower the inhibitions of their intended victims and facilitate the molestation of said victims. The next item of evidence I reviewed was Item Number 303, which was @escribed as being three Books that contained nude photographe, found in the master bedroom within the Neverland Ranch. The first book wus a hard-covered book titled, Scenes D/Interieur, authored by Alexander Dupouy. I reviewed each page of this book and did nét locate ‘any photographs and/ or writings within chis book, which did not appear te be an original parc af the book. The writing in this book Was a foreign language. The book consisted of @ compilation of photographs of nude and/ ox semi-nude women, in sexually explicit poses. The material within thie beck did not appear to be a vioJetion of criminal law. The accond book was a soft-covered book titled, Cams Cove ~ Photos Syéney Men, euthored by Red Mckee. I reviewed each pags of cd book snd did not locate any photographs and/ or writings within this book, which did not appear te be an original part vf the book. The book was a compilation of naked end semi-naked men. The author is described in the book as being a gay, photo artist. While the men in the photegraphs were naked and/ or sem{-naked, the photographs were not sexually explicit in nature. The third book uss a soft covered book titled, Dressup Playaces and ‘Pantseies of Childhood, authored by Starr Ockenga. I reviewed eack page 5f this book end did not locate any foreign photographs and/ or writings, which dié net appear to be an original pact of thie book. This book appeared to be a compilation of photographs that appeared to depict either pre-teen or early teen aga individuals. Some of the pictured children were nude end/ or semi-nude. None of the pictures appeared to be sexually explicit in nszure. Based onmy training, the sbove listed books contain material that can be used as part: of a "grooming" process by which people (those seeking to molest children) axe able to lower the inhibiticns of Engiteintended victims and facilitate the molestation of saic victims. The next item of evidence I reviewed was Item Number 30. This item was described as being two pornographic magazines and two nude art books found in the mestex bathroom at the Neverland Ranch. 1anon 929 aM Res D Lv rEp 1ew— hep: en edlonsastate.com/she/ popup. phen saape 9 ps ste popup ppd 12666taypeablapercu=s pe Lof2aynons 829 aM , pop ria Seavas DE’ CF wot) o- p/m adtoneattart.com/he/popup php 13666biypeablepercus2 fage ofAbebooks image Galery anon 9:35 aM Use buttons to zoom. Click and drag to pan. toomin zoom out —_rasat This photo was provided by the publisher and is not the actual image of the item available ‘rom this bookseller. ‘to:/m abahooks com on/imagesallanimagegllery.shiel=tSimapee-hitp|ceximages anazon com/images/SUAKS2FVIL Joy age Loftwevanauns 10 " 12 13 14 18 16 7 18 19 “of Pentheuse” and the July 2903 issue SHERIFF'S DEPARTMENT "Santa Barbara County 03.8670 CONTINUATION SHEET (a AT EavieOATan CESARE onrmenL BVBENCE\SATON FOUND DEPORT | MATE wi BaroerTeN_| found thia item of evidence to consiet of the July 2003 issue of cBarely Legal”; the July/ August issue of “The Girls of Penchouse”. a soft covered book titled The Art of Dave Nestler _~_ Intentions, and the last iten being a book titled The Gyneida Sgnetiest yManipulated, authored ky dajaime Sorayama. I reviewed each page of the beck titled The Manipulated and did not locate any foreign writings and/ or Pictures, which did not appear to be an ociginal part of the book. The book was a compilation of drawings, which depicted clothed ané/ a semi-clothed mon and wamen.. The hook appeared to have a fetish lage, Sadomusockiam, piercings, etc.) related theme. Z reviewed each page of the book titled - Wicked Inteations and did not locate any foreign writings and/ oF pictures, which did not appear to be an original part of the book. This book appeared to be a compilation of drawings of clothed and semi-clothed women. I re-tew2 each page of the duly/ August 2003 isaue of “The Girls jf “Barely Legal". 7 did not locate any foreign writings and/ or pictures, which did not appear to be an original part of the periodicals. Hoth of these magazines contained pornographic images and writings. All four of these periodicaly appeased to be of commercial manufacture. None of the books end magazines contained pictures that depicted illegal ectivities, such as child pornography. Based on my training, this type of material can be waed as pert of a “grooming” process by which people (those seeking to molest children) are able to lower the inhibitions of their intended victims and facilitate the molestation of said vietima. The next item I reviewed was Item Number 305. This item was Seseribed as being a photograph of McCauley Caulkin, which wes lecated in the master bathroom of Neverland Ranch residence. This was # photograph of McCauley Caulkin. taken froma scene from one o£ the “Home Alone” movies. The photograph was signed and hed o message written on it. The message stated, “To Apple head. Always remember keep Apple head Club Doo Doo Head alive.” It wae signed “meCauley Caulkin" and in parenthesis “Doo Deo Head." ow’: : g a 3war anraons “lower the inhibitions of their intended victims and facilitate the SHERIFF'S DEPARTMENT PAGE 9 Santa Barbara Count: CONTINUATION SHEET /SICAL EVIERNEE LOCATION FOLNG 4 DISPOSITION, (E) NARAATVE (} CIEPOSTION 12) UBT EOTAUATION, (B] DESCRIBE. The next item of evidence : reviewed was Item Numbex 306. This was described as being a pornosraphic magazine located within a metal brief case in the master bathroom-at the Neverland Rench residence. This periodical wes the Volume 7, Issue 2, of "Couples". I reviewed cach page of thie magazine and did not loeats any writings and/ cr pictures, which were not an original part of the magazine. The magazine did not depict eny illegal activities, including child pornography. Based on my training, this typo of material cen be used as part of a "grooming" process by which people (those seeking te molest children) are able to lower the inhibitions of their intended victims and facilitate che molestation of said wicrims. The next item of evidence I reviewed was Item Wumber 307. This item was described as being e back, which contained nude photegraphs of men. This item was found in the master bathroom cf the Neverland Ranch residence. <= found this ‘tem te be a hardback beok titled Bidgood, authored by James Bidgood. I reviewed each page of this book and did not locate any writings and/ or Photographs, which did not eppear to be an original part cf this book. The bock cppeare? to be a compilation of photcgrapke Gepicting nude and/ or semi-nude men. Although a majority of the models were nude, or semi-nude, the models were not depicted engaging in sexually explicit activities. Based on my treining, this type of material can be used as part ef a “grooming” process by which people (chose seeking te molest children) are able molestation of said victims. The next item of evidence I reviewed was Item Number 30°, This item vas described as being a black leather bag, which contained pornographic magazines and pornographic DVD's. It should be noted that while reviewing this item, I removed the DVD's and re-booked Usem into evidence ss Item Number 303A, The purpose of this action was to separate the DVD's so as to not necessitate the entire item be disturbed in order for the DVD's to be reviewed at a later time. I did not zeview the content of the DvD's on 12-02-03. pen opening this item, I found it to be = Taxgus black-leathor, laptop computer case/briefcase. I opened tke front compartment of the beg and located a pen and miscellaneous loose papers. One of the loose papeze was a page, which appeared to have been ripped out of » magazine. One side of ths page waco a Guess (clothing) advertisement. Th: other side of the page listed contributors to ovaee ee ee = ee ee Aptana ne ee see eee eee Se i rs Fe es ee oe es a ces «a ae hs Sone re eee ea we ee Spo wc Pe em cos ee te ip ee a ee eed eee has = eer ee ee ae AS ee ee WY ee the fee ee ab ea el prea ae en eet on mie tet meine obi bmeeeeh emacs teers Sa a [ete eee wi tee nee Se Seay ees 62 pa ol om fe ca eee Ce re wren Seer at ow bee eet Sat Se =o eee oe ee is tees So an See 6a Sere ee te Ee Big pee Roe a ee cea e Ge rat tee Oe or ae ee ee ies Stet care ee ree apa Re Tae ak ee ae ba Sone ee eee we enebenre tain meth ee ee hee ee al See heb ee Me eedee Soe est i ceed a eee ee Seg ae rR Seer nee Gee i ete ee ee FP Se st Bee ees beer tee at (eS Rg inks cate eeeSHERIFF'S DEPARTMENT Santa Barbara Count: CONTINUATION SHEET [a] UBTEEMTRWATION (8) DEGCAUG PHYBIEAL EVIDENCE, LOCATION FOUND A CISPOSITION. [6] NARRATIVE, {0} ISPOEITION. PAGE 10 03-5670 the magazine (unknown title). Also, in this front compartment were two loose pieces of paper. One of which wao blank and the othe= bad "Paria and me” w=itter on dt. Within a separate compartment vithir this front porcion of the briefcase, I located two envelopes and a Sec syringe (ne needle}. The first’ envelope was a security type envélope with "No" printed im purple ink on the front. Within the envelope, I found two news clippings. One of which pertained te the death of & composer by the name of Walter Sherif. And, the other pertained to a person writing in support of Michael Jackson with regard to the Bashir documentary. Tue second envelope had, what appeared to be 2 writing from Prince Jackson to Michael Jackgon and possible song lyrics on the reverse side. Within the business card holder of this section, I located a business card and various leose papors. The businces card was for a Henry Cornell of Goldman, Sachs, and Co., out of New York. The Jeose paperverk appoarcd to be letters to and from Michae) Jackson. The other party in the letters was auc identified. of note: The letters apeak of going to Florida and Jackson being a dad to the other person. The note on the lavender paper appeared to be fem an unknown person to Michael Jackson. The mete on the light blue psper appeared to be a note to Michael Jackson from an unknown person. I photographed the notes and made photocopies, which I provided to Sergeant Rebel for investigative / purposes. : On the reverse side of the briefcase was a compartment thet contained miscellaneous loose papers and envelopes. There was en empty envelope addreased to Mr. Michael Jackson, from the Motion Picture Association. | There were numerous loose papers and drawings, which appeared to be made by children and titled "Prince and Paris", There was a photo card (like a baseball card) for Corporal Gary Smith of , Indiana, Police Department. Thor was a postcard depicting young boys inal. There was a ripped ‘up, faxed transmission, which appeared to discuss concert a=rangements for xecording artists including Diane Ross, Gloria estefan, Stevie Wonder, and Michael Jackson. olewavanewns SHERIFF'S DEPARTMENT CONTINUATION SHEET 8) LST CONTIUATION, fa) DESCAIME: PHYSICAL EVDENCE LOCATION FOUND B DISPOSITION. {6] NARRATIVE. [01 OISPOSITIC, PAGE 11 There were two center compartments, one large and one small. The email one contained a package of triple “A” batteries, 2 telephone cord, business paperwork involving Michael Jackson and Goldman, Sachs, and co.. x also found a children’s book titled Spiel Mit ‘ix. ‘This appeared to be a baby book and had a handwritten note on the back that appeared to etate "Shay Eom Ieracl.” I also found a black jewelzy case, which indicated the content was a crown wich o price of twenty-four pounds (English). Inside che jewelry box was @ email metal crown. 3 Additionally, within thie compartment was a book titled How the Mind Works by author Christen D. iarson. 1 reviewed each ‘page of thie book and found pictures and writings inserted within the pages. I photographed the inserted materials. The name “Wolfgang” was written on the ineide cover of the hook with a possible telephone number: of 011-494-05523968. I found a piece of paper, Between page twenty and twenty-one ‘of the book. This paper had the name Gary Hearn written on it, with a telephone number of: Q@M@NEB There were Six photographs inserted between pages thirty-two and thirty-three. I took a digital photograph of these pictures. The photographs hed writings on the rear, which appeared to be from “Shay" from Jexusalem, Zsrael. The writinge of “shay” seemed to indicate he had personal contact with Michael Jackson. Onc of the weitings appears to have been dated September 24, 2002. ‘The main compartment contained miscellaneous paperwork, pornography periodicals, the manual for a Samsung DVD player, loose papers, and an audic-patch cord, and two DVD cases that appeared to contain pornographic material.. The fizst DVD titled Michael Ryan's Believe Tt or Not. The eecond DVD was titled i ‘i le, I'm a a Girl. There was no Dvp disk in this particular DVD case. As noted earlier, beth of these items were not reviewed. I ye-packaged the two OVD cases in a new evidence bag and given en Evidence Tag Numbex of 305A. I found a letter from the Gary Community School Corporation. The letter appeared te be writteA by a Brenda Carson, who was a student Councilor/ Teacher. Carson wrote of a desire fe. bring a group ‘of The letter indicated the purpe: the’ plan was to-bring the children to California between January and dune of 2004 cre was a contact telephone number for Brenda Carson, Q@UGMEMNMMMs Also, within the main compartment, T found a battery for a samaung portable DVD player. ‘There was a fan letter from a reaident of Tokyo, Japan, by the name of Romi Kaanno. atsSHERIFF'S DEPARTMENT PAGE 12 Santa Barbara Count: CONTINUATION SHEET Iai ST CONTINUATION. (0) DESCRIEE: PHYSICAL EVIDENCE, LSCATION FOUND DIPOAITION, (€] NAGRATIVE (B) LEPESITION. Prom reading the letter, it did nct appear this pezsog had pexsonal contact with Michael Jackson. There was a greeting card from rns o. Lardydell, QM telephone number The writer indicated she eang with Michael Jackson and provided the name of ker son, Prince Alba, who was thirteen years of age. There wes @ faxed letter from Mark Slotkin telephone’ number WMMREMMMEN Within this letter, Slotkin described that he and bis children went to the Neverland Ranch. The letter indicated Michael Jackson was not presect during their vieit. There was a letter from Kanoko Gotoh tron Japan. This appeared to be a fan letter and it did not seem ae if the writer hed personal contact with Michael Jackson. The final items within this compartment were the May 2002, issue of” Gallery and the September 2002 issue of Gallery. 1 reviewed each page of these pornography. periodicals. I did net locate any foreign writings and/ or pictures inserted within the pages. None of the material within the periodical appeared to be illegal in nature. Based on my training, thie type of m&terial (Gallery Magazines) can be used 2s part of a “grooming” process by which people (those seeking to molest children) axe able to lower the inhibitions of their intended victims and facilitate the molestation of sai¢ victims. The next item of evidence I reviewed was Item Number 313. This item was described as being, a book that contained nude photographs. * This item was located in the masters bathroom of the Neverland Ranch xepidence. This bock was titled Neked asa Jaybyrd, by author Dian Hanson. I reviewed’ each page of f thie book and dia ner find any foreign pictures and/ or writings inserted within the pages. The book appeared to be a compilation of photographs and/ or writing which discussed nudity. Some ef the pictures depicted sexually explicit activities. None of the material within the periodical appeared to be illegal in nature. Based on my training, this type of material can be used as part of a “grooming” process by which people (those seeking to molest childzen) are able to lower the inhibition; of their fntended virrima and facilitace the molestation of said victims. Due to time constreinte, 1 was unable to complete xeviewing the remaining, items T checked out of evidence. 1 retumed all items of evidence that I checked out to Sergeant Ruben Cintron on 12-2-03, oth21 22 23 24 25 26 27 28 THOMAS W. SNEDDON, JR., DISTRICT ATTORNEY County of Santa Barbara SUED Pune SARE REA By: RONALD J. ZONEN (State Bar No. 85094) Ver Senior Deputy District Attorney JAN 18 2005 GORDON AUCHINCLOSS (State Bar No, 150251) Senior Deputy District Attorney COLE Ftecuive Otcer GERALD. FRANKLIN (State Bar No. 40171) ee a Wha Senior Deputy District Attorney ‘CARRIE L- WAGNER, Oéuly Clark 1112 Santa Barbara Street Santa Barbara, CA 93101 hone: (805) 568-2300 Ve Unraalel Puruert FAS B05) 568. 2398 45 Ubu ca ord SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA — Sa SANTA MARIA DIVISION em ey “\ a THE PEOPLE OF THE STATE OF CALIFORNIA, No. 1133603 oe eal PLAINTIFF’S REQUES# TO. Plaintiff, ADMIT SEIZED EVIDENCE OF EROTIC MATERIALS TO DEMONSTRATE DEFENDANT'S v. INTENT, PLAN, SCHEME AND MOTIVE MICHAEL JOE JACKSON, DATE: January 28, 2005 Defendant. ) TIME: 9:30 a.m. DEPT: SM8& \eiep ONDER SEAL The People seek to introduce numerous homosexual and heterosexual picture books, videos, and magazines seized on November 13, 2003, from the defendant's master bedroom suite at Neverland Valley Ranch, the video arcade and from a room adjoining the defendant's private office in a security building. The People also seck to admit three hard-cover books and ‘two photographs seized from defendant’s bedroom at Neverland Ranch by the Los Angeles Police Department in August, 1993. 7 WL (FST FOR ANMISSION OF FVINENCE AF FROTIC ROOKS AND MaGATINFS10 u 2 4 15 16 0 18 19 20 a 2 2B 24 25 26 7 28 A. Items To Be Introduced Specifically, the People seek to introduce the following items: From the search of defendant’s bedroom in 1993, the following unnumbered items: -- Book: “Boys Will Be Boys,” containing photographs of boys under the age of 14; full frontal nudity. The book is personally inscribed by Michael Jackson; ~- Book: “In Search of Young Beauty,” containing photographs of children, both boys and girls; some nude; -- Book: “The Boy, A Photographie Essay”; containing black-and-white photos of boys, some nude; -- Photograph: A photograph of a boy, believed to be Jonathan Spence; fully nude. — Photograph: A photograph of a young boy holding an umbrella; wearing bikini bottoms, partially pulled down, From the search of Neverland Ranch on November 13, 2003: Item #303: Found in plastic bag, bookshelf in master bath, Homosexual erotica, consisting of: CAMP COVE, PHOTOS OF SYDNEY MEN Book of photographs of adult men, full frontal nudes; SCENES D’INTERIEUR Pictures of nude and semi-nude adult women, some sadomasochistic; DRESS UP Playacts and Fantasies of Childhood 1978 photo book. Contains 3 photos of teenage boys naked. Item #304: Found near bathtub in master bath; consisting of: The Art of Dave Nestler, Wicked Intentions Nude illustrations, female model, some sadomasochistic; 210 n 12 13 4 15 16 a7 18 19 20 ai 2 2B 24 25 26 2 28 The Gnoids, Genetically Manipulated Nude illustrations, mostly female, some male, extreme sadomasochism and body mutilation; BIDGOOD, James Bidgood Nude young teenage men, Erotica; 2 “Barely Legal” magazines Pornographic magazines Item #313: Master bathroom (den); consisting of: NAKED AS A JAYBIRD 1967. Nude adult male and female erotica; very graphic. Item #363: Found upstairs in box at base of Jackson’s bed in master bedroom; consisting of: 12 pomographic magazines; 23 nudist magazines, vintage 1930's. Item #364: Master bedroom upstairs; consisting of: THE CHOP SUEY CLUB Photo book; some nudes, all male, young adult models. Item #365: Master bedroom upstairs; consisting of: THE CHRISTY REPORT History of pomography, heterosexual photos from 1940’s on to recent, some graphic, some sadomasochism; ROBERT MAXWELL PHOTOGRAPHS Old photos, some nude, some of young children (nude and dressed). Item #366: Master bedroom den; consisting of: BIANCHI BOB AND ROD Nude photos of male couple; BEFORE THE HAND OF MAN ‘Nude photos of young men; TAORMINA WILHELM VON GLOEDEN Nude photos of teenage boys from late 1800°s; 3 REQIFST FOR ADMISSION OF EVIDENCE OF FROTIE ROAKS AND MAGATINESeae 10 u 2 B 4 15 16 7 18 19 20 21 2 2B 24 25 26 27 28 THE GOLDEN AGE OF NEGLECT Photos of teenagers, some nude; ROOM TO PLAY Photos of children that are altered, morphed head on older bodies, kids made to look sexualized. Some are nude photos of kids; MAN A SEXUAL STUDY OF MAN Graphic primer for homosexuals. Gay photos, all nude, featuring a study of ‘masturbation, oral and anal sex, each photo 2 men. All homosexual erotica; About two dozen nudist magazines. Item #301; Found in master bathroom near bathtub; consisting of: 4 “Barely Legal” DVDs; 1 “Pimps Up ~ Ho’s Down” DVD. Item #302: Found in master bathroom near bathtub; consisting of: 1 “The Best of Club” pomographic magazine. Item #306: Found in metal briefcase sitting on edge of master bathroom bathtubs; consisting of: 1 “Couples”, a pornographic magazine Item #309: Found in leather bag located in master bathroom with notes between Michael Jackson and Gavin; consisting of: 2 pornographic magazines. 2 pornographic DVDs. Item #321: Found in nightstand next to Jackson's bed in master bedroom; consisting of: 7 ponographic magazines. Item #1001; Found in bathroom cabinet (right side) in Jackson’s private office; consisting of: 1 Hustler Barely Legal ~ 2002 Anniversary Edition magazine. Item #1002: Found in bathroom cabinet (left side) in Jackson’s private office; consisting of: 1 Naughty Neighbors - December 2002 magazine. ‘ RFOIIEST FOR ADMISSION OF FVINENCE OF FROTICROOKS AND MIATATINS19 20 21 n 2B 24 25 26 7 2B Item #346; MacIntosh Power Book G3 laptop computer found in Jackson’s master bedroom; which contained: 21 graphic nude femal ages from “Teen Sex” internet site. Item #347a: Power Mac G4 located in Jackson's master bedroom; which contained: 19 graphic nude female images; Records of multiple visits to the following websites: www.varsityteens.com www.adoptablekids.com www.adoption.com Item #347b: Power Mac G4 located in Jackson’s master bedroom; which contained: 10 teenage sex imaging; documentation of user ID as “King 777 tut / privacy 969.” Item #344 Sony, Vaio model PCV ~ W20 laptop computer, located adjacent to the master bedroom; which contained: - Adult erotica: user ID: “Marcel Jackson / Dr. Black.” scus: The Materials There are principally two orientations to the sexually explicit materials found in defendant's possession: ~- Many items described above are all-male erotica. Some depict both naked male adults and children while others principally focus on adult males only. Taken together they reveal a predominantly male orientation. ~ The remaining magazines and videos are pornographic materials graphically depicting every imaginable combination of explicit heterosexual, and sometimes homosexual, sexual activities, oftentimes with more than two people participating.' "Item No. 317, a black briefcase found in a closet in Jackson’s bedroom, also contained approximately 19 nude female “centerfolds” and 18 pornographic magazines, several with teenage themes, matching this description. The magazine and photographic contents of this briefcase are independently admissible as being identified by both the victim and his brother as materials shown them by the defendant Jackson. The fingerprints of both brothers and Jackson hhave been found on several of the magazines. 5 RFOIFET FOR ADMISSION OF FVINENCF OF FRATIC RODKS AND MAGAZINES10 12 13 4 15 16 a 18 19 20 21 2 23 24 25 a 28 2. The Relevance Of The Materials A e 1, section 18 of the California Constitution declares that all relevant evidence is admissible in criminal prosecutions unless its admission is specifically precluded by overriding statutory or constitutional provisions. In assessing the relevancy of a particular item of evidence, a trier of fact must start with the premise that the evidence must have a“... tendency in reason to prove or disprove any disputed fact that is of consequence to the determination of the action, (Evid.Code, § 210.) The listed materials are admissible and relevant as circumstantial evidence on the issues of defendant's intent, motive and method. They are adjuncts to his plan to seduce young, boys, and demonstrative evidence of his preparation for their seductions. They are evidence of his method. 3. Defendant's Specific Intent Is In Issue “A ‘plea of not guilty puts in issue every material allegation of the accusatory pleading’ (Pen. Code, § 1019), and when a spe ic kind or particular type of mental state or intent is a part of the corpus delicti of the crime charged, the not guilty plea puts in issue the existence of that state of mind. [Citation.]” (People v. Gentry (1968) 257 Cal.App.2d 607, 610.) In the prosecution of an alleged violation of Penal Code section 288, one of the elements that must be proved is that “The touching was done with the specific intent to arouse, appeal to, or gratify the lust, pas: ns, Or sexual desires of [the accused] or the child.” (CALJIC 10.42, in pertinent part; see People v. Maquez (1994) 28 Cal.App.4th 1315, 1322.) When defendant pled not guilty to the offenses alleged in Counts Two through Six of the pending indictment, he placed “in issue” whether he acted with the lewd and lascivious intent which must be shown to demonstrate a violation of Penal Code section 288. (See People v. Memro (1995) 11 Cal.4th 786, 864: “Defendant’s intent to violate section 288 was put at issue when he pleaded not guilty to the crimes charged. [Citations.]”) 4. Evidence Of Defendant's Intent And Method The intention with which an act n of fact for the committed is ordinarily a que: trier of fact and may be inferred from the surrounding circumstances. (People v. Darling ‘eae 10 u 12 4 15 16 7 19 20 21 2 2B 24 25 26 a 2B (1989) 210 Cal.App.3d 910, 913.) It may be inferred from the accused’s prior conduct demonstrating a particular state of mind (Evid. Code, § 1101, subd. (b).) That prior conduct need not be a crime to be admissible under Evidence Code section 1101. (People v. Willis- Watkins (1979) 99 Cal. App.3d 451, 456 and fn. 1.) “[E]vidence Code section 1101's recognition of the admissibility of certain evidence to prove such things as ‘preparation,’ ‘plan,’ and ‘identity’ not limited . . . to ‘uncharged offenses,’ but embraces also ‘other acts.” (People v. Harris (1978) 85 Cal. App.3d 954, 958.) The materials described above are relevant to the issues of the defendant's intent and his method of “grooming” young boys to satisfy his lewd desires. Indeed, they are the very instruments of the seduction process itself and so are demonstrative evidence. From his possession of that material, the trier of fact may infer defendant’s intent, purpose, motive and method of molestation. The sexually explicit materials found on the premises are specifically calculated to appeal to a young boy’s sexual appetite and create the opportunity for the defendant’s molestation of him, 5. The Homoerotic Materials Are Circumstantial Evidence Of Defendant's Sexual Preoccupation With Young Boys And His Intent To Involve Himself Sexually With Them Defendant's possession of the all-male erotic books and magazines found throughout his house is circumstantial evidence of his interest in male-male sexual relationships. There is no more reasonable explanation for his possession of that material. That evidence would be irrelevant without other evidence that he acted upon that attraction in this case.” In People v. Memro, supra, 11 Cal.4th 786, the court reviewed the conviction and death sentence in a capital homicide prosecution in which the defendant was charged with felony murder based upon a killing during the commission of a lewd act with a 7-year-old boy. ? See People v. Giani (1956) 145 Cal.App.2d 539, which addressed and correctly rejected the false “concept that if a man belongs to the larger group (homosexual) he is predisposed to ‘commit the particular offense [of molestation of a boy]. (/d., at pp. 545-546.) BPOIIERT FOR AAMISRION OF EVIDENCE OF FROTIC ROAKS AND MIATATINES10 u 12 13 Is 16 7 18 19 20 21 2 2B 4 25 26 2 28 “Over an objection made on grounds of irrelevance and undue prejudice and also implicitly made under Evidence Code section 2201, the [trial] court ordered certain magazines and photographs depicting clothed and unclothed youths admitted under Evidence Code section 1101, subdivision (b), as evidence of motive and intent to perform a lewd or lascivious act on {the victim] in violation of section 288. The court admonished the jury not to consider the items as evidence that defendant was evil or was disposed to commit ce Cal.4th 786, at p. 864.) types of crimes.” (11 The Supreme Court approved the admission of that sexually explicit material on the issue of the defendant's intent: We have examined the magazines and photographs in question. They contain sexually explicit stories, photographs and drawings of males ranging in age from pre-pubescent to young adult. Some of the photographs are of similar character. Others depict youths in a manner that is not sexually suggestive. [f] (9) ... Although not all were sexually explicit in the abstract, the photographs, presented in the context of the defendant's possession of them, yield evidence from which the jury could infer that he had a sexual attraction to young boys and intended to act on that attraction.” (Ud., pp. 864-865.) In the case at bar, the evidence listed above is admissible pursuant to Evidence Code section 1101, subdivision (b) for precisely the same reason similar evidence was admitted in Memro’s prosecution. It is plaintiff's belief that defendant possessed the heterosexual materials for the purpose of “grooming” young boys. “Grooming” is the process of deliberately exposing young boys to graphic sexual materials to awaken or heighten their interest in matters of sex and reduce their sexual inhibitions. Defendant's personal display of these materials to pubescent boys was calculated. So was defendant’s decision to make them accessible and readily ble to the “special friends” he allowed to go into his private bedroom even in his absence. A significant number of the materials are “young”-themed. Many of the materials RFOIFET FAR ADMISSION OF FVINENCF OF PROVFIE ROOKS AND ATAGATINES10 u 2 14 15 16 7 19 21 2 2B 24 28 26 2 28 depict teenage or teenage-looking young girls, generally naked and often engaged in sexually explicit activities with males. The publications featuring young nude females were acquired because their appearance would generally appeal to teenage heterosexual boys. Many even carry the additionally suggestive and provocative label “Barely Legal.” These materials were used in conjunction with the defendant's often-stated references to the value and pleasures of self or mutual masturbation to satisfy one’s sexual desires and needs. The defendant spoke more than once to the victim and the vietim’s brother about masturbation, He encouraged the boys to masturbate. He sang the praises of ‘masturbation, In fact, one of the books found in the master bedroom’s den (Item No. 366: “A Sexual Study of Man”) contain all male nude photographs and photographs of men engaged in homosexual acts. It features a study of masturbation and oral and anal sex. Taken together, these materials are the instruments of seduction and are circumstantial evidence of defendant’s systematic approach to that seduction and of his intent to engage in sexual acts with young boys as the fruit of that seduction, 6. Evidence of “Preparation” and “Plan” The relevance of the listed materials in this prosecution extends beyond the issue of the defendant's intent. As noted, the materials also corroborate other evidence of the defendant’s attraction to young boys, all of which suggests the motive for his relationship with Gavin Arvizo was sexual, His method was to use graphic and sexually explicit heterosexual pornographic materials as his instruments in the grooming and seduction processes. The materials, considered with other evidence of his preoccupation with young boys, reflect a plan and a scheme to use them with the boys with whom he cultivated a close relationship to achieve his goal of seeking their acquiescence and active participation in lewd acts with him, As such, their admis &). ty falls squarely within the dictates of Evidence Code section 1101, subdivision A plan or scheme need not be pa ularly distinetive to warrant admissibility of ‘evidence of that scheme to show that the defendant acted pursuant to that plan in committing the charged offenses. (People v. Kraft (2000) 23 Cal.4th 978, 1031-1032.) Here, one must not 910 u 12 14 1 16 7 18 19 20 2 2 2B 2s 26 2 28 overlook the fact that the molestations were “acquaintance molestations.” This is not a “stranger” molestation, nor is it a case where a child’s will was overcome by force. These sexually arousing materials, considered in conjunction with limitless amounts of alcohol, were calculated to create an intimate relationship with Gavin in an atmosphere conducive to behavior without restrictions. In analogous situations, courts have routinely admitted evidence of the possession of burglary instruments as circumstantial evidence of an in jual’s intent to commit the crime of burglary. (People v. Darling, supra, 210 Cal.App.3d 910, at page 913 [possession of screwdriver]; People v. Wilson (1965) 238 Cal. App.2d 447, 463 (plastic strips found in defendant’s pocket could be used to slip locks on doors and were “reasonably adapted to the performance of the entry which is in fact effected”}; People v. Gibson (1949) 94 Cal.App.2d 468, 471 (defendant found in alley with ladder, a bag of tools and a rope; that evidence admissible to establish his burglarious intent even if he was interrupted before achieving his objective}.) In Darling, supra, 210 Cal.App.34 910, appellant argued that his possession of a screwdriver was evidence of a “character trait” and so should have been excluded pursuant to Evidence Code section 1101. In response, the court noted “that even character evidence may be admissible on the issues of intent, preparation and plan.” (210 Cal.App.3d at p. 914, n. 2, citing People v. Rodriguez (1986) 212 Cal.3d 730, 757.) Nor, as Darling also points out, is it necessary to show that the tools or instruments found in the defendant’s possession actually were used in the commission of the charged crime itself to be admissible. (People v. Darling, supra, 210 Cal.App.3d at 914.) nce of Motive Juries considering the guilt or innocence of a defendant charged with a criminal offense are routinely instructed in the words of CALJIC 2.51: Motive is not an element of the crime charged and need not be shown. However, you may consider motive or lack of motive as a circumstance in this case. Presence of motive may tend to establish the defendant is guilty. Absence of motive may tend to show the defendant is not guilty. 10 REOIIFST FOR ANMISSION OF FVIRFNCE OF FROTIC ROOK AND MAGATINES10 u 12 3 4 15 16 a 18 19 20 a1 2 2B 24 25 26 27 28 Defendant Jackson’s possession of both all-male erotica and heterosexual materials, like the evidence of the defendant's gang membership considered in People v. Williams (1997) 16 Cal.4th 153, is relevant and material to prove the defendant’s motive. (See also People v. Conrad (1973) 31 Cal-App.3d, 308 — portions of a tape recording of one of the defendant's ‘statements in which he stated that he was a narcotic addict and was getting money to support his habit by stealing, hustling and dealing dope was admissible on the issue of motive.) CONCLUSION ‘The People respectfully request that the items set forth above be deemed admissible as demonstrative evidence of the materials defendant used in acquainting his young “special friends” with the pleasures of sexual arousal and masturbation, and as circumstantial evidence of the defendant's motive and method and plan to seduce young boys and his intent to molest them. DATED: January 18, 2005 Respectfully submitted, District Attorney RFOUFST FOR ADMISSION OF VIRENCF OF PROTIC ROOKS AND MAGAZINESa 2 2 24 25 26 n 28 PROOF OF SERVICE, STATE OF CALIFORNIA COUNTY OF SANTA BARBARA. ss 1am a citizen of the United States and a resident of the County aforesaid; I am over the age of eighteen years and I am not a party to the within-entitled action. My business address is: District Attorney's Office; Courthouse; 1112 Santa Barbara Street, Santa Barbara, California 93101. On January 18, 2005, I served the within PLAINTIFF’S REQUEST TO ADMIT SEIZED EVIDENCE OF EROTIC MATERIALS TO DEMONSTRATE DEFENDANT’S. INTENT, PLAN, SCHEME AND MOTIVE on Defendant, by THOMAS A. MESEREAU, JR., ROBERT SANGER, and BRIAN OXMAN by personally delivering a true copy thereof to Mr. Sanger’s office in Santa Barbara, by transmit 1g a facsimile copy thereof to Attorney ‘Mesereau, and by causing a true copy thereof to be mailed to Mr. Mesereau, first class postage prepaid, at the addresses shown on the attached Service List. I declare under penalty of perjury that the foregoing is true and correct. Executed at Santa Barbara, California on this 18 day of January , 2005. 2 RPOIIFST FOR ADMISGION AF FVINFNCF OF FROTICRAOKS AND MAGAZINEST SY: $860 DA; 8055801077; JAN-48-05 9:89PU; Pag 18 19 20 21 2 23 24 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA. |COUNTY OF SANTA BARBARA ss Jam a citizen of the United States and a resident of the County aforesaid; 1 am over the age of eighteen years and I am not « party to the within-entitled action. My business address is: District Attomey's Office; Courthouse; 1112 Santa Barbara Street, Santa Barbara, California 93101, On January 18, 2005, I served the within PLAINTIFF’S REQUEST TO ADMIT ‘SEIZED EVIDENCE OF EROTIC MATERIALS TO DEMONSTRATE DEFENDANT'S INTENT, PLAN, SCHEME AND MOTIVE on Defendant, by THOMAS A. MESEREAU, JR, ROBERT SANGER, and BRIAN OXMAN by personally delivering a true copy thereof to Mr. Sanger’s office in Santa Barbara, by transmitting a facsimile copy thereof to Attomey /Mesereau, and by causing a true copy thereof to be mailed to Mr. Mesereau, first class postage prepaid, at the addresses shown on the attached Service List. 1 declare under penalty of perjury that the foregoing is true and correct. Executed at Santa Barbara, California on this 18 day of January , 2005. 2 LocAT 10N:8085601077 RX TIME 01718 "05 14:3810 ul 12 13 1s 16 v7 18 19 20 21 2B 24 28 26 2 28 SERVICE LIST THOMAS A. MESEREAU, JR, Collins, Mesereau, Reddock & Yu, LLP 1875 Century Park East, No. 700 Los Angeles. CA 90067 FAX: [CONFIDENTIAL] Attomey for Defendant Michael Jackson ROBERT SANGER, ESQ. Sanger & Swysen, Lawyers 233 E, Carrillo Street, Suite C Santa Barbara, CA 93001 FAX: (805) 963-7311 Co-counsel for Defendant BRIAN OXMAN, ESQ. Oxman & Jaroscak, Lawyers 14126 E. Rosecrans Blvd, Santa Fe Springs, CA 90670 Co-counsel for Defendant 8JSATBARGNIS0ervausuna 2 22 23 24 25 26 2 28 23 30 31 32 33 3¢ 35 36 37 38 33 40 ay SHERIFF'S DEPARTMENT PAGE 2 Santa Barbara County 03-5670 CONTINUATION SHEET (8) USTCOTINUATICN [8] BESERINE: PHYSICAL CPCHEE, LOCATION FOUND & DISPOSITION, (6) NARRATIVE (0) HIRPOSITION (4) LIST CONTINUATIONS: FelK! warts Hy tae Lorin 1a Rated ener tw!” Relationships of named individuals: A feoidden, Hu AnudAmélocr, 1. Gerald Franklin and Ren) Zonen are? Deputy /Districc Attorney's, employed by the Santa Barbara County District Attorney'o Office. Attachments te report: 1, Photocopy of BFS-1 CA DOT evidence svbmiscion form (1 page) 2. Photecepies of court ordexs (2 pages) (8) PHYSICAL EVIDENCE: None (C) NARRATIVE: On Tuesday, 01-13-2004, Detoctive Zelis and > pet with Deputy District Pecorneys Gerald Franklin und Ron Zonen at the Sante Barbara Sheriff's Department Headquerters. The purpose of the meeting was to allow DDA Franklin and DDA Zonen to review itens of evidence. DDA Zonén provided me with a list of items they wished to review, I contacted SBSO Propesty Officer Chuck Villazeel and checked out the following items of property. 301-307, 305-313, 318-318, 320-324, 326-328, 320, 331, 349-353, 359 and 361. 1 then opened one bag at a time and allowed ODA Zonen and DDA Pranklin to review the evidence. After each item was reviewed, Detective zZelie replaced the icem in its original peckaging and resealed the bag. After all of the above noted fcems were reviewed, T returned the evidence to SBSO Property Officer chuck vilareal. During the afterncet of 01-13-200¢, I checked out additional irems of evidence. Agein, these items were reviewed by DDA Franklin and DDA Zonen. Specifically, the items reviewed were numbers 362-356, §01-S03, 505-508, S14, Sis, 601, 602, s04-s06, 620-623, 1001-1008 tnd 1020, I opened one bag of evidence et 2 time and allowed DDA Zonsn and DDA Franklin to teview the evidence. Aftcr each icem was revicwed, / P boroow PoemohypoS Sle ~2 522 040!SBUAHRGNASworMMAUD SHERIFF'S DEPARTMENT CONTINUATION SHEET PAGE 3 03-5670 Tay UT EONTAUATION (6) BESCRIEG_PIFSIEAL EVDENCE, LOEANON FOUND & CISPORTION, (] HaffeTWvE (01 OSPOATION Detective Zelia replaced the item in ite original packaging and zesealed the bag. After all of the obeve noted items were reviewed, I returned the evidence to SBSO Property officer Chuck Villareal. puring the review of evidence on 01-23-2003, we noticed the glass vial (item number 524) seemed te contain zemnants of a substance. 1 was directed to submit this item of evidence to che Californie Depactment of Justice Crime Laboratory for the purpose of determining what substance was contained within the viel. = filled oue a BF6-1 Evidence Submission form and a controlled substance submission envelope. 1 provided the BFS-2 form to S8SO Property officer Chuck Villareal. 1 obtained item number $14 from Villareal. I placed item number $14 into the controlled subscance submission envelope and xeturned the item to Villereal. I requested Villareal transport the item to the CA DOJ office and gabmit the item for analysis. S250 Propercy Officer Villareal submitted the item to CA DOJ on Tuesday, 2-20-2004. on Friday, 1-16-2004, I contacted SBSO property Officer Chuck viliareal and checked out item numbers 301 and 309%. Both of these items weze described aa being pornographic DVD media. I opened item number 309A and found ir to contain two DVD media covers. The first cover was titled Sloppy Dog presents, Fuck Me i'ma Sad Girl." Upon opening the cover, I found that it did not contain any DVD, or CD media within. The cover contained pornographic images, which were likely still photogzephe c= she movie it contained in the past. The cover indicated the film was Preduced on 7-27-02 and release on 6-22-02. There was 4 price tag en the cover, indicating the item sold for $14.15. The sccoad DVD cover was titled “Michael Ryan's Believe I= Oz Not.” The cover further stated the film was “The new series, #2". The cover further stated the £ilm contained, “Unbelievable anal,” ve * iggest black." The film was produced on 1-22-03, by Leisure Time Sntextainment, out of Gary, Indiene. 1 wacened (#ast foxward) the film and found it to be approximately three hours end “Buman herse cocka,” “Brown qbET I Mi i SM /wovanewns SHERIFF'S DEPARTMENT PAGE 4 Santa Barbara County 03-5670 CONTINUATION SHEET (AI UST CONTAUBTION (B) OESCRIE: PHYSICAL EVICENEE LOCATION FOUND A DISPOSITION fC] NARRATIVE. {O] DISPOSTION thirty minutes in length. The film was a compilation of scenes and Bhone sex ads. The scenes involvad heterosexuz] acts, lesbian acts, insertion of objecks into the anus and sex acts between women and transsexuals. The film appeared to be commercially manufactured pornography. The persons copicted within the £4tm and the DVD covers did not appear to ba under eighteen ycars of age. Although this material is not illegal, it could be used as “grooming” materia) with regard te lowering the inhibiticns of children with regard to engaging in acxual acts. I repackaged the evidence within the original bag. i then openad item number 301. I found this item to contain five DVD media covers. Four of the covers cated the sentents were filme from che Huscler Srreryorese ee The fifth cover indicated the content was a film tiried "Pimps Up, Ho's Down.* The first DVD/ cover 1 reviewed was titled “Barely Legal #26, Fuck Me I'm Legal". ‘the cover indicateé the film was produced on 2/5/02, by Fuvtlex Video. There was a price tag on she frost indicating the meterial sold fer $19.35. There wae a stick-on tag on the back of the cover, indicating the item was sold at piamond Adult World, #2. I viewed (fast forward) the DvD contained within. The £{lm was 2 compilation of five scenes wherein 2 woman and a man engaged in sexual acts. The second DVD cover I reviewsd was titled "Rarely Legal #26, Preah Figked-Pink". The cover indicateé the film was produced on S-21- 02, by Huotler Video. There was a price tag on the front indicating the material sold for $¢8.95. There was a otick-on tap ez the back of the cover, indicating the item wac cold at Diamond Adult World, #2. The cover ad@ not conzain any DVD, oc CD media within, The pictuxes on the cover were pernogzaphic in nature and ccemed co be still pictures obtained from the film, The third DVD cover I reviewed was titled “Barely Legale34, Dirty Teens Come-Clean". The cover indicated the film was produced cn B- 18-02, by Hustler Video. There was a price tes on the front indicating the material sold for 549.98. There was a stick-on cag on the Buck ef the cover, indicating the item was scld at Diamond Adult World, #2. The cover did not contain any DVD, or CD media within, The pictures on the cover were pornographic in nature and secmed to be still pictures obtained from the film. 0403woeranrsans SHERIFF'S DEPARTMENT Santa Barbara Count CONTINUATION SHEET 03-8670 TA) UST CONTWUATON, (8) DFRCRIRE PHYSICAL BVDENCE LOCATION FOUND ACISPOSTION [e] NAARATWE (0) DISPOSITION The fourth DVD/ cover I reviewed was citled “barely Legal 436, Hot! Wot! Tight! Pinki". The cover indicated the film was produced en 2/3/02, by Hustler Video, ‘There was a price tag on the front indicating the material sold for 545.95. There was a stick-on tag on the back of the cover, indicating the item was sold at Diamond Adult World, #2. I viewed (fast forwerd) the DVD: contained within. The film was 2 compilation of five scenes vherein a woman and a men engaged in sexual acts. With regard to the four Hustler “Sarely Legal" DVD's end/ or DVD covers, the films/ and covers appeared to be conmercially manufactured pornography. The persons depicted within the films and the DVD covers (particularly the females) project a young appearance, but do not specifically appear to be under eighteen yeare of ege. The promise of this ~Sarely Legal" video series is documentation of sexual acts involving persens who present a ceenage appearance, but are of lege’ age. Although this material is not illegal, it could be used as “grosming* material with regard to Inwering the inhibinions of childre: with regard to engaging in sexual acts. The fifth video was titled ‘Pimps Up Ho's Down" ‘The modia indicated this film was produced in 1999, by Out of Pocket Productions Inc. I watched (fast forward) che film and found it to be a documentary of pimps, prostitutes and strippers. The film contained nudity and depicted individuals engaged in eexual actr {although these waza somewhat hidden). Thic material dié not appear to ba pornegrophic ia nature. Because of the nudity and sexual acts, thie material could be used as “grooming” materiel with regerd to lowering the inhibitions ef children with regard to engaging in sexual acts. On Wednesday, 1-21-2004, I was directed to take specific itoms of evidence and transfex custedy of said items te Santa Maria Superior Court. I was provided with the attached copy of the Court Order signed by Judge Rodney'Melville, I was also rrovided with the acteched decument, which way to be used to document the transfer of the evidence. 1 contacted S850 Property Officer Chuck Villaree] and checked cut che following items of evidence; 611. 812, 813, £1s, 815, €16, 817, 815 and 820. These items of evidence were oqedwaraueuns SHERIFF'S DEPARTMENT Santa Barbara County CONTINUATION SHEET TAI UIST COMTMATION, (6) DESCRIBE: PHYSICAL EVIOEIEGS LECATIEN POUND & DISPOSTRON, (6) NARRATIVE [5] OGPOSITION 03-5670 seized from Brad Millec's office and aze being challenged with regard to attorney/ client privilege. 1 transported the above noted items of evidence to the Santa Maria Superier Court compound. Once at this location, I contacted Patty Blayleck, who ia a Deputy Clerk of the Court. I previded Alaylock with cach of the above noted items and a copy of the attached court order. Blaylock and I then signed the attached court document, which Blayleck then filed wich the court, Blaylock provided ac with a phetocopy of the signed and Ziled court document (attached te this report). (0) aprepron RECORDS Investigation continuing. 0405"» COUNTY OF SANTA BARBARA - SHERIFF'S DEPARTMENT BUREAU OF CRIMINALISTICS Lab T exsENo: 03-5670 Tix 1-5-2004 1330hrs | Ta Evidence Tag Ne'er Ahyateal Rvidense Examines DD caning. 122980 ‘Latest Seurch . ‘Latent Compestton ! D thowsraphs D cater OD saw Wo. © otter spect je Liat al pests, DOR: CID, RACE; SEX: OrherD aumbeny Further Wenfcaden (ceibe) Bb, For lab wie vay. 8. ficen numbers: 302,303,304,306,507,309,513,316 317.321,363,364,(365,366,1002,2002|, All of the islet tems are magazines and! or books. Please examine the items forthe presence of latent fingerprint evidence, 1F jr -aruble latent fiogerpdats are developed, please compare against known fingerprints of the suspect. 8a JACKSON, Michos!, DOB: QUIN CID: 259814 Bb, Ox 01-16-08 at N830 hours J received items # 365 fora the propersy room and scturmed with the item ro the, Forcasics Lub. J opened the sealed evideace bag und observed two hardbsiuad books, 1 photographed the cover of the first bool: (Robert Muxwell PHOTOGELAPHS) and labcled as item #565A. I photozmphed the cover af the secanc book (THE CHRISTY REPORT Exploring The Outer Ldees of The Sexual Experience) aad labeled as item # 365B, I proceeded to examine cach book for tracc hair ond fbers as well as Quids, utilizing thes wteraule light souree at white lighl, UV 300-400 snd CSS settings. The scurch of both books met with negative results. Both fbouks were repackaged and sceled inside the oriyinal evidenec beg and retumed to the property room on O1-16- [04 at 1100 hours. 5. avaignedine 1 Assn OMe 7 T. Sutcliffe 1007 i x 1 Tow Time 8 Heirs 10, Received bye = Due Tie | M1. Dale and Ti Report Wines, ‘Superior Appreving/Body Nez Set Suatona 2661 1/12/04 0925hs | O122-04 1500 Sgt Santana! 2661 12, Evidenez Pispestna: a = u te: 5 Lanebrin [enrwe: #365 to Propeny O16 #1003 to property ey Suelitfe o12205 e242 Snsmpnsos 26M Mer mee wrsNT TSO VAR Ye SIG BOE LATENT SEVACH AOA wal RA ASCH RP 0941‘The Christy Report ~ Exploring the outer edges ofthe sexual experience ~ Kim Christy, John Guinn = Merial 1/9146 6:23 Pa IEE ros eos se ray oti by eau By angen pape ou alow cr pare reso lacs Secu tes rams God weak spa hyena ego Zap seh Ce zalogs) rarest merlin. pl SOA TENTG tr reer sews) nae \yruka x pol mils produ ‘Strona gidwna > Ksigtkt | Opis produktu L a The Christy Report - Exploring the outer edges of the sexual experience kim Christy, John Quinn "Numer ataogowy: 0427640 kts mia oer 2005- Eventing you ever wares to know abou see? Peneate the wot of 2th eran at ureorgroun wth pusher tm producer. ard archivist Kin Chisly. Compiled irom extensive prvate ‘aecons. The Croat Repo ings you a plethora of mages acing ihe fvouionofpem a5 we. ies Pelny opis produktu: The Christy Report - Exploring the outer edges of the sexual experience ‘Autoe: Kim Chvaty Jt Quin Wydawnictwo: Taschen, 2005 ISBN: 2-9228-2165-4 Liczba stron: 608 iymlary: 196 «249 mm ‘Sprawa inne tytuly: Kim Christy , John Quinn Ketegore: sige obeojayezne > Angie » Atoumy Everthing you ever wari fe know about sex? Penelate te wort ct 20h cemury aut underground iB pulser tm producer ana arcs Ken Chal Compted tom extensive ‘ale clecons, The Chsly Repo bigs you a pltorsclimages racing revlon of pan 3s we Rag Hom BaQnnngs a featy phlogaphy, Rusa, and fm, though te glory days ofthe 705 pom expioKn and up to edaye emanded dia. 2 iar. A Pisin book ne any you ever had in school The Chisty Reports more ran eye cay. sateo edie (Ws wns! re aster rm cri spent several years dancing and proringin ight cle beir rcs, Node Avangorde, Hooker and Expose Kim has since prodend "Wagan, Squser Moe and Corupt Doses. 2k ew ine forthe Eros Pubsting Company on such es ‘recied cove! featue fine, tng uke nxp//mesn py The-Chrsty-Repor-Explaring-ihe-ovter-edges-of-the-sexual-experence john-Quinn-Kim/browse/ product 1427640.himl age 1of 2SHERIFF'S DEPARTMENT Bureau of Criminallstics Santa Barbara Count CONTINUATION SHEET Case Number 03-5670 At 1115 hous on 01-16-04, I received evidence item # 366 from the property room and renumed with the item to the Forensics lab. L opened the sealed evidence beg and noticed several asegezines and some hardcover books. Ipraceeded to photograph the fron! cover of each individual magazine and book, identifying each itera by eter, originally with a “post-it” note, and then permanently marking the bortam right comer on the back cover of coch magazine end book, stating vith item # 366A through item # 366] Following the taking of phetogmphs I proceeded to examine euch book for truce hair and Gbers as Well us fluids, utilizing the alternate light soue at while light, UV 300-400 ond CSS settings. While examining mazuzines # 366D, 3G0E, 366N, 366Q, 3665, * 366V, 366W, und 366Z, several areas of fluorcycing siains were noted. On 01-22-04 the above evidence items, # 36SD, 368E, 366, 386Q, 3665, 366V, 566W. and 3662, were scaled in a new labeled evidence bag and ‘transported to the Santa Burbura DOJ lab on 1-22-2006 for further examination and nuslysis of the Muorescins mains, E On 01-21-04 | received evidence lem # 1001 ant evidence item # 1002 from the property room and retuned, with them to the Forensics lah. Topened the scaled cvidenee bug of item # 100] aud observed a Hustler “Barely Legal” magazine. | photographed the front cover of the meyizine and then proceeded to cxantine tbe muxwine for wace evidence and fluids using the ALS (eltemute light soutec) at whitc light, 300-300 and at CSS sertings. This scarch met with accative results. I repackaged und sealed jtem: # 1001 into its original evidence bag. the scaled cvidence hag for item # 1002 and observed a December 2002 issur of “Naughty magizins, I photographed the front of the muguzine end then proceeded to cxamniae the mayuzinc \ ace evideure und fluids using the ALS (alremate light source) at white light, 300-400 aad at CSS senings. A Dioreseing stain was noted on the front page of the mayezine. On 1-22-04 I repackaged aad sealed item al evidence bag anid transported the item (along with evidence item # 366D. 36GE, 3 366Q. 3665, 366V, S65W and 3662) to the Santa Barbura DO! lab for further exemipaticn and analysis of the stain, Refer to the attached SH-451 form and copy of the DOJ leb BFS1 form. [tem #366A through 3561) (except the above listed magazines) and ifem # 1001 were renamed to the property room on, 01-22-04, oaga~N ® PROOF OF SERVICE S'TA'TE OF CALUFORNLS, Ass COUNTY OF SANTA BARBARA, ) Jana citizen of the United States and a resident af the County aforesuid: | am over the age of clghtcen years and | am not a party to the within-cntivled action, My business auldeess is: District Antorncy's Office: Courthouse: 1105 Sante Barbara Street, Senta Rarharn. Calitimmis 95101, ‘On August 9. 2004. ] served the within PLAINTIFF'S OPPOSITION TO. DEFENDANT'S MOTION 10 TRAVERSE AFFIDAVITS, TO QUASH WARRANTS AND TO SUPPRESS EVIDENCE on Defendant, by [THOMAS A. MESEREAU. JR.. STEVIE ‘COCHRAN. ROBERT SANGER. and BRIAN OXMAN by personally delivering » true copy thereof Mr. Sanget’s office in Sunt Burbuna by transi} junile copy thereof to Auomeys Mesereau und Cochran, und by’ cuusing u true cupy' thereof te bc mailed te cach of them (Mr. Sanger excepted). first class postage prepaid, at the addresses shown on the atached Service List, Tdeclure under penully of perjury that the foregoing is true and vorreet, Executed at Sunt Barbary, Colifernin on this 9th day af August, 2008, VLAINTIFE'S OPPOSITION TO DEFENDANT'S MOTION TO TKAVEMSR. & QUASH SHAICH WAURANTS:* Lonnie era SS oe) (SS ————— = ow A | ovsza | HI 2E6t 1685 9 BUINIOA LSIONN SHL | | aupetew | zagr | cou ones : E61 YOIIW Z OWNIOA .ISIGAN SHL aurebew | MODE | Oaszz4 “OU SEGL “G24 Z OWNIOA ISIGNN an aurebew | Avot | | ooszzi “bu £6) aun 9 awMEN «ASIONN aH aurebew | s99E uM | onszzt “OU 2E6} "AON 9 SUINIOA ISIOAN SHI. aupebew | O99 onezz! ~~ EGE “AON § awUNIDA .LSINN 3H Le auzebew | NQQE opaeat ic uoypa Powe} OHNO. y auredew | 3996 oge2zt a “UoH|pa BA\SNI9x3 J4.NIOS. : surebew | aoe suscaLI IEEE BH semen torre we sur | aut vanz22-10 200) SUNPINS “L Jenuapyuod Yrvo4 4.20 30ANOR NOTE osu soawuiw's | _sAuoo yesoUHD ONO'S nvunnieoayntta'? ad JO done 30a Wuod ALUSdOud 0l9s-c0 ALNNOO WHVEHYE VLNVS ‘oa (edanz te sama tt ANAWLYVY FO S.4sIHFTHS woUNaUss) 48220" magsSFhitice SET roo stonee PHYSICAL EVIDENCE SUP-"ISSION FORM. GR ed 11520) FORMATION AND ROUTE AEERCY ONLY ACERT ORTY : REPORT SECURITY a. o o SUINITTING AGENCY: canta Rage Suey! CE ACINCYEASENO! O2- SEND * COUNTY OF PROSECUTION, RELATED ACENCIFS/CASE NUMBER(S 5 CONEY Dee Bat PATEGFINCIBENT! Qaga ATE NEEDED Rint _reAtom SASS [RECAPS DETTE BowweR ovens) eye urea mite _ a SUBIECS: | eareer | ate erricee, LAST NAME rast Hae, ut | nurtn | werems ano ora re—cvv alee al: —— Fe ‘DESCHITIONOPEVIOENCR | (ONE ITEM PER LINE WHEN POSSIBLE) ‘GonimEnTS OF UMOER eva DETAPEORMEAT-SCIUED. INITIALMARTUE SEAL, REQUESTS FOR SERVICE, Phonan sat [Bole @ ies DELIERES Fo [ere | ae | or a Rane ceca FOR GRIMINALISTICS AKO QUESTIONED DOCIIMENT CASES PLEASE SUBMIT A POLICE REPORT OM ATTACH A SEPARATE SWEET WITIL A SUMMARY OF THE CASE INSTRUCTIONS Fok SturadTTING EVIDENCE ARE ON TE REVERSE SIUE, 0944:BORER EE RE lr = SAsoa2EPYe FETVSECAL EVIDENCE, pre Care Hoe hecneeee SUBMASGIOT FORM EFORRLATHM CATE MO: Pet Revers 1S) “a 7 TREOURAIGN TAS RSGTHE TERE” SGRESIT | RECDICT BOSURITY CG “D at © AARNGV CASEND: CSS TS [counry er PAOSEOMUNC, won Crcgags, PSATEO ACBICIESEXSE NUMBER, | soup o PROD MUNS aase aeuape,_ ATE = orresem 2g3ca) (a DATE OFINEMDENT: 1. ¢,07 CATE NEEDED: re rncoencee er Segre HHH S! SL 4IS' SUBIESTS. ust mais aTmee sect EVIDENCE SURATTED DESCRIOTIONOF FVIDERCE (ONE IfbM PER LINE WHEN FaSSInILAy ToMMENTE OR EVIDENCE MULT EE TAPEOR BEAT.SEALED, WiCVTAI JMABSSTBE SEAL _pequests Font Bass Via iG COMMENTS | Ge Te numcen POP. CRINNALISTICS AND QUESTIONED OCUMENT CAIES PLEGHT SURMET 5 VOLICE REPORT OF ATTACH A SEPARGTE SREE! “NETH A SUMMA OF THE CSE INSTRUCTIONE FOR SUBMITTING RMINEHCE n 25:Jackson files/Research Notes: Case No: SB-03-2824 Re, PHYSICAL EVIDENCE SUBMISSION FORM ID PAGE NO: 0906 Investigating Officer: Detective ROBERT BONNER Penal Code 288 PC is a crime committed by touching a child somewhere on his/her body for sexual purposes. Justice officials sometimes refer to this offense as "lewd acts on a minor under 14" or "acts of lewd and lascivious conduct." ‘These cases typically involve accusations that the child was touched or fondled on a sexual organ, or that some overt act of child molestation took place. However, one can be charged with lewd acts even if the touching was not ona sexual organ, and even if the touching was done over the child's clothes (rather than on the bare skin).* SANTA MARIA, CA Santa Barbara County Sheriff Detective Robert Bonner at the Santa Barbara County Courthouse May 2, 2005 in Santa Maria, California. Michael Jackson is charged in a 10-count indictment with molesting a boy, plying him with liquor and conspiring to commit child abduction, false imprisonment and extortion. Comments on Page 0906 reads in re, to unk vial seized as follows: Determine effects of substance with/in human beings PAGE 0906Eyre ear)1 23 24 28 26 2 28 23 30 3 32 33 34 36 7 33 40 41 SHERIFF'S DEPARTMENT. Santa Barbara Count: Case Number CONTINUATION SHEET 03-5670 (a) UST coHTRWAION_10| DESCRIBE: PHVEICALEVDOICE \GEATON FOUND A DPOSITION (] MAARATIVE, 6] CHPORTION. PAGES |~2(TEIWG J open at tke bottom. The greeting caxd is a commercially produced card. The handwritten information on the greeting card appeared to be written by (Vi). Within the grecting card the (Vi) referred te Michael JACKSON as “Dear Daddy Michael~ and the (Vi) indicated the card was from, “Your doo-doo head’. PAGE 3 Zeem 342 \ Thio item appeared to be a faxed copy of a letter sent to ‘Michael. Prince and Paris" from “Your doo-doo head". The letter indicated the author missed the recipient and loved the recipient. rem 316: did not open this item. which wac ceseribed as two VHS cassette tapes, Based on my observations of the packasing cf thie item of evidence, 4£ appeared Detective Al Lafferty had epened this item previously. SBSO Forensic personnel were initially tasked with waking working copies of video cassette tapes, which were to be viewed at @ later time. I later conversed with Detective Lefferty and ascertained that he opened the package with the iatent to make the weching copies, but was unable to do so becauss of time sestraints. I will not review thin item of evidence until ouch time as a working copios of the tepes axe produced. Item 315: This item was described as being several letters and cards from the victim, which were contained within a manila envelepe. The envelope was further described as a legal-sized envelope with “Mz. Potter” written on the exterior in purple ink. Contained within the envelope was, an additional letter sized manila envelope with “Daddy michael" written in black ick within a lazge heart. The reverse side of the letter sized menilu envelope stated it is from *(vi), (va) (names omitted due te confidentiality], and Davellin Axvizo.” There vere also mumerous pieces of plastic happy face confetti within the envelope. 1 took photographs of the individual cards. The cards were addressed to both Michael Jackson and Evie Tovashi. Item 329 This item was a letter addressed to “Deer Applehead’. The letter was sent from 2 subject who identified himself ag "Big Booty". OboeSHERIFF'S DEPARTMENT Santa Barbara Count Case Number CONTINUATION SHEET 03-5670 1) LET CONTeTUNioN,_(@) GESERDG: PHYSICAL EMDENEE ATION FOUND DIGPOSIIO, [] NAARATWE. (8 OBPCATION. PAGE 4 Item 322% 4 This item wag described as a letter addressed to Ronald Kenitzer. In reviewing this item I found it to be a faxed copy of a letter sent to Ronald Konitzex from Donald C, Hamnah. The letter discussed attempting to ect up a meating between Michael and Mark Advent.’ The addreas fer Ronald Konitzer is ckson Item 323: This item wos described as being a photograph of (V1), found by Detective Zelia within the nightstand in Michael Jackson's bedroom. In reviewing thie them, I found it to be a picture of {(V2!, (Va), and bavellin Arvizo. The photograph appeared as if it were staged, with a shooting star background. There is no writing ow the front, or back of the picture. . Item 32. E This item was described as 2 drawing with.the victim's name on it. In reviewing ‘this item, = foand it to be a picture, which appeared ze if it were drawn by a child. The @raving had both (Vi) and (v2) 's names written on dt. Item 325: This item was described as miscellaneous paperwork, which was located within Paris, Jackson's bedroom. In reviewing this item, 2 found it to be miscellaneous paperwork pertaining te individuals etaying at several hctels, at various locations within the United States, The hotels included the Hotel Bel Air, located at 791 Stone Canyon Road, in Los Angeles. The Turnberry Isle Resort and Club, located ar 19998 West Country Club Drive, Aventura, Florida. Phone number (305) 932-6200. The enzry key (magnetic strip card) helder indicated the people stayed in room 658 at the Turnberry Isle Resort. There vas alse paperwork from Omni Hotels in Montreal, Canada. There was also paperwork from the Regent, Beverly Wilehixe Four Seasone Rotel, located at 9500 Wilehire Blvd, Beverly Hills. California. Phone (310) 275-5200. The entzy key elder (magnetic strip card) from the Four Seasons Hotel in Las Vegas indicated a Chang P. stayed at in room 207 at the hotel Also within th ‘A., Jone: Horace Mann School. There was a list titlea “Sterling Room” which was handwritten on a paper associated with the Garden City Hotel. 0604SSwevousuns Betanasn SHERIFF'S DEPARTMENT Santa Barbara Count ‘Case Number CONTINUATION SHEET 03-5670 THU CONTAWATION (0) DESAI PHYSIC EMDENGE, LOCATION FOUND EDIPOSTHON, (6) NARRATOR 0] BSPOSTTION. There is also a list citled “Simpson Room’. There was also 8 list whieh contained the name Mx. Richard Parker and several others individuals with the lase name Parker. Item 326: : This item vas described as being commercially produced photographs. In reviewing this item, I found ic to be numerous pictures of juvenile childxen, which appear to be of commercial manufacture. There are few pictures within the many packaged pictures with depict semi-unclothed children. There were also two Polaroid photographs of what appeared to be & 10-13 year old boy. one of which had Michael Jackson in the background. Also included was a folder fron Irene Maria Management Group, out of miami Beach Hlorida, telephone number (305) 672-2929. ‘This appeared to be a “child management group". Aloo included in this item of evidence was o letter fzom [Management Compeny”, addressed to Frank Tyson, ac California. tem 327: . Described as being a paix of Zanes underwsex. This was further found te be bne pair of eize 30 Eanes cocten bricfs. The underwear does net zppear to have been worn. Icem 332: Thic, item vas a white envelope, vhich had haridwritten information pertaining te contact numbers ‘fer Dieter Wiesnez and Udo Schocz. The first number for Dieter Wiesner w2 sq (coll phenc) and the second number was QUEEN (‘private’). The telephone mmbexe for Udo Schaar vert QS (cell phene), and QM (-privete") . tem 330: This item vas described as being numerous photographs depicting children, which were located within a safe located inside the omplayee break room at Michael Jackson's house. I found these photographs to.be contained within a red colored fabric bandanna. ‘ One set of photographs, depicting two boys, was contained withia » Plastic picture protector. These photographs have inddcstiens they were made in 1998, and 1999. The two juveniles within these photographs are of different ages. One of the juveniles appears to be a young teenager and the other approximately 8-10 years of age. There were also numerous loose photographs which appear to be of ollwovanaen+ SHERIFF'S DEPARTMENT Santa Barbara Count) Case Number CONTINUATION SHEET 03-5670 TnI UST CONTROATION [BDESCRGE PHYSICAL EVIOENCE LOCATON FOUND kISPESTION (6) NARRATE (2 XsPoarIN_| PAGE & Prince and 2 children. Jackson, along with other young adolescent This concluded the review of items of evidence on Monday, 11-24-03. Agter Detective Alvarez and I finished reviewing the listed items of evidence Detective Alvarez replaced each icem of evidence in original packaging and resesled the criginel packaged. T occured the items of evidence inte locker number 27 at SBSO Haadquacters. I checked with SBSO Property Officer Villerenl on 11-25-03 end confirmed he retrieved all of the listed items of evidence from within evidence locker number 27. aAfcex I secured the evidence in the lockex, Lieuteaant Klapakis provided me with two VES caasette topes, which he indicated wexe working copies of evidence item number 368. Lieutenant Klapakis indicated SBSO Forensics Detective Al Lafferty retrieved item number 362 from evidence and made the working copies. I noted the Property forms indicated item 368 was supposed to ccnsist of three Vis tapse. Lieutenant Klapakie believed Detective Laffexty was unable te make a working copy of the third tape due to time gonakrainte. I later spoke with Detective Lafferty and learned che third tape was either blank, or recorded in a format (digital) we weze unable to view. I reviewed the working copies of the VES tapes from beginning to end. one of the tapes contained what appeared to be behind tha scenes video footage of a Michael JACKSON music video (possibly titled “Too Bad“). The second VHS tape contained what appeared to be surveillence footage of a kitchen food preparation/ dishwashing area. The only human achivicy I observed was of two individuals (adults) waghing the floor. i did not find any inserted video footage on the tapes. 7 also did not locate any video footage which seemed to pertain te this investigation. (2) CASEDISPOSTTION: Attention records, investigation continuing. O6llRBSIS eo ervonAon SHERIFF‘S DEPARTMENT Santa Barbara Count Case Number CONTINUATION SHEET 03-5670 [A] USTCONTWUATION, (8) DESCRIBE: PHYSICAL EVDENCE LOCATION FOUND & DISPOSITION, (C) NARAATWE.(D} GSPBITICN, The second bottle indicated the contents were described to Peter Midani. According to the label there waa an address of 3255 Sunset Blvd, Suite 2100, West Hollywood, california, which was aseociated with Peter Midani. Tt should be noted this address was’ also associated with a Grace Awarambu (the nanny), who was alse associated with the investigation. The Suite 1100 location is actually 3 televigion production company named Endemol Entertainment. The prescribing physician was a Dr. Klein, A.W.. The Mickey Fine Pharmacy in Beverly Hills filled thie prescription. This “bottle indicated it contained Prednisone. ‘ Both of the bottles, which were filled by the Micksy Pine Phermacy, did not have tops and were empty. ‘q P The third prescription bottle indicated the contents were prescribed to “M/M". The prescribing physician was a Doctor Caxey Logan, 300 East ‘Fremont, Las Vegas, telephone number 259-1616. Tne battle lateling indicated: the contents were thirty-count of “ERY- TaB 330 ng tablet BC.” The contents.of this bottle were white oval shaped tablete with “EH” stamped on one side and “e” stamped cn the opposite le. The fourth prescription bottle cated the inlendad recipient of the preecciption was Frank ‘ The labeling provided an associated address of QMS Severly =illc, California. The labeling further indicated a Dr. Arnold Klein, with -an address’ of 435 North Roxbury Drive, Beverly Hills, California, prescribed the medication. the, preeeription was for one-milligrom tablets of Aiprazolan. This prescription bottle was ematy. The leope pills within the evidence bag were small circular, pills; white in color. The numbers *5052" were stamped on one side and “DAN” was stamped two times on the opposing side. 7 The next item of evidence, I reviewed was Item number S18. This item was described ag being prescription paperwork.: This item was- found in the upstairs. library ithin the video arcade exea of Michael Jackson's Neverland Rench property. I found this item te consist of two preseription medication information sheets. The fixet sheet was from the Stax Drug Co.; located at 3576 Madera Street, Santa Ynez, California, telephone munbex 805-688-6096. This information sheet pertained to a prescription for Frank Tyson.” The prescription waa for Alprazolam, The papexwork indicated the ootwWornnaens SHERIFF'S DEPARTMENT. Case Number CONTINUATION SHEET 03-5670 (21 LIST CONTIUATION. [B] OESEHDE, PYSIEAL EVOENGE, LSCATan FOUND ISPOETTON, [6] NARRATE. [b) OPSSTION PAGE 2 (A) LIST CONTINUATIONS: None (B) PHYSICAL EVIDENCE: I tock numerous photographic images of the items of evidence I reviewed on Friday, 12-12-03. I teck the photographs with a Canon Powershot G2 digital camera, which was owned and maintained by the Santa Barbara Sherifi’s Department. After I finiohed photographically documenting che evidence, T provided the camera's digital media card te S8S0 Forensics personnel. The SBSO Forensics perconnel, downloaded end stored the digital images. The S3S0 Forensics Bureau will maintain the digital image files for future retrieval. (6) NARRATIVE: on Friday, 12-12-03, at 6845 hours, I contacted SBS Property Officer Chuck Villareal and checked out several items of evidence. The purpose of checking out the items of evidence was to conduct an in-depth review of each item and detexmine its evidentiary value. Specifically, I checked out Evidence Item Number 515,, $28, 1002, uon2, 1903, 1008, 2005, 1006, 1007, 1008, 1009, and’ 2010. The firat item of evidence I xeviewod was item number 515. This item was deseribed as being medicine bottles, which were found in the upstairs librazy room of the video arcade area of the Neverland Ranch property. Upon opening this item, I found it to contain four prescriptien medication bettles, two of which were not capped. There were numerous loose pills within the bag, as well as, a cotton ball. The first bostle indicated the prescription was presexibed to 2 subject named Michael Armstrong. There was ar addrese of GD California $0211, which was associated with Armstrong. Thc Isheling indicated the medication was prescribed by Dr. Gerald abiner .and was filled by the Mickey Fine Pharmacy, out of Beverly Hille, California. The prescription was for Percocet. 0613Jackson files/Research Notes (2): Case No: SB-03-5670 Re, PHYSICAL EVIDENCE SUBMISSION FORM Research info: See Attached: Comments on Page 0906 reads in re, to unk vial seized as follows: Determine effects of substance with/in human beings Re, medication PERCOCET: The Connection Between Sex Addiction and Percocet Addiction One wouldn't think that a New York City mayoral candidate and a prison inmate would have much in common, However this week, Anthony Weiner and Ariel Castro both made headlines for their admitted sex addiction. It started first with Anthony Weiner, who since his 2011 sex scandal involving lewd photos, resigned from congress only to reenter into the race for New York City Mayor earlier this year. Deemed as The Comeback Kid, Weiner was expected to do well for himself, considering his checkered history. However, an additional sex scandal of Weiner's leaked to the public earlier this month, making his hopes of becoming mayor more dismal. Hundreds of miles away in Ohio, Ariel Castro plead guilty to over 900 counts of tape, murder and kidnapping of three young girls, all of whom he held for aver a decade. As he spoke in court, Castro used his sex addiction as an excuse for his monstrous actions. The judge did not acknowledge his claims, and instead sentenced him to life in prison with no chance of parole.These two men, both from different walks of life, have witnessed the many dangers that their untreated sex addiction can produce. Whether it is a lifetime sentence to prison or being distracted on the path to success, both men have been stopped in their tracks by their addiction. For many people, this type of addiction can serve as a catalyst for the development of another addiction, such as Percocet addiction. How Sex Addiction Causes Percocet Addiction Percocet, a combination of both acetaminophen and oxycodone, is one of the most commonly abused prescription drugs in the world. For many individuals who struggle with sex addiction, Percocet can seemingly serve one of the best ways to self-medicate the many symptoms of their condition, Percocet can cause effects such as sleepiness, slowed breathing and hallucinations ~all of which contribute to helping take a sex addict's mind off of their problem. One of the most common reasons why sex addicts abuse Percocet includes experiencing anxiety related to their sexual urges. This anxiety can become so invasive, that it causes an individual to be unable to stop thinking about their urges and how their sexual desires are controlling their life. To release this pent up anxiety, many sex addicts will turn to Percocet to help slow down the central nervous system in ways that promote relaxation as opposed to constant anxiety. As this becomes a habit, an addiction can develop. In addition to using Percocet to relieve anxiety, many sex addicts begin experimenting with drugs such as these because they have developed extreme impulsivity as a result of their sex addiction. Their impulsiveness leaves them prone to engaging in more risky behaviors outside of those sexual ones, which can cause increased interest in abusing Percocet and additional painkillers.Treatment Options for Sexual Addiction and Percocet Abuse While neither Anthony Weiner nor Ariel Castro have any known addictions to painkillers such as Percocet, it does not mean that other sex addicts are not struggling with this combined issue. Despite the complexity of these problems, there is treatment available at dual diagnosis facilities. Dual diagnosis facilities work to treat both issues simultaneously, all while providing individuals with the tools needed to prevent relapse and build a sober, healthy life for themselves. PAGE 0613waxonsuns 23 24 25 26 27 28 28 30 31 32 33 34 35 38 38 39 40 41 SHERIFF'S DEPARTMENT Santa Barbara Count Case Number 03-5670 14) USTEONTWUATION, DESCRIBE: PHYSICAL EVBENCE, LOCATION FOUNO K DISPOSITION (C] NERAATWE. fo] DISPOSITIGN prescribing phyeician was Dr. William VenValin. The prescription was filled on 3-26-02. The information sheet provided an address for Frank Tyson as beins@ MEP Los Olivos, California. The second information shect partained te a prescription that was obtained through Zong’s Drugs, located at 218 East Highway 246, Building 3, Buellton, California, telephone number 805-693-1132. The prescription information sheet pertained to a prescription for a Manuel Rivera. The prescription sheet provided an address of in Santa Marla, California, for Manuel Rivera. The information sheet indicated the prescription was for _fanax. The prescribing physician wae a Dr. William VanValin. The next item of evidence I reviewed was Item Number 1001, which was described as a Hustler, Barely Legal Magazine. This item of evidence was found in the museum/ office area of the Neverland Ranch property This iesue was further deseribed as being the AREOERE OST Tage SEWEPLIPRIGEE.” I evicved each page of this periodical. I not locate any pictures and/ or writings inserte? within the pages ef this periodical, which did not spocar to be an oxiginsl pert thereof. This item appeured to be commercially manufactuxed pornography and its contents die not appear to depict illegal activitias. Based on my training, this type of material can be used ao part of a ‘grooming’ process by which people (these seeking to | “ children) are able to lover the inhibitions of their intended victims and facilivate ‘the molestation of said victims. The, next item of evicence I reviewed, was Item Wumber 1002. This was described as being a magazine. This item was found in the Mucoun/ cffice area of the Neverland Ranch property. This item was the December 2002 Iesue of “Naughty Neighbors”. ZI reviewed each page cf this pericdical and did not lecate any writinga and/ or pictures iaserted within the magazine which did noc appear te be an oxiginal part of the magazine. This item appeared to be commercially masufactured pornography and its contents did not appear to depict illegal activities. Based om my training, this type of material can be used as part ‘sreeming” process by Which people (those seeking to molest children) are able ze lower the inhibitions of their intended victims and facilitate the molestation of said victims.SHERIFF'S DEPARTMENT. Santa Barbara Count Case Number CONTINUATION SHEET 03-5670 PAGE 5 TA LSTCORTNUATION._(@) GESCAING: PHVGICAL EVBUCE LOCATION FOUND 6 OISPOSIION, [¢] NARRATIVE. [2] SISPOEITION The next item of evidence I reviewed wao Item Number 1003. This was described as being a photograph of a nud= male, which was found within the museum/ office area of the Neverland Ranch property. This item was an eight-inch by ten-inch (8*x10") photesraph, which eppeared to be professionally produced. The oubject within the photograph appeared to be a ldight-skinned, African-American male who was either in his late teens, or early twenties. The pictured subject was wearing no clothing. The subject was covering his genitals wich 2 red, flannel clota materiel. The next item of evidence I reviewed was Item Number 1004. Thio item was deseribed as being photographs of unidentified males. This item was found in the museun/ office area of the Neverland Ranch property. This item consisted of eleven 8-xl0- photographs. which appeared to be of professional origin, These phosographs depicted two sopaxate males, that appeared co be in their late teens. Both of the pictured individuals appeased to be light skinned African Americans. These individuals were posed in @ provocative manner and were wearing little, or no clothing Ths zvihjecte’ private areas were covered by what little clothing they were wearing, or by cloth material purposely placed to cover the genitalia. One of tha pictured subjects was the same subject pictured in item number 1003. Each of the eleven pictures was individually numbered on theiz back. teenage yeare. This subject appeared to be woazing o white terry cleth robe. The name “Kendall- was printed over the adolescent aged individual. The adolescent individual was beze-chested. The picture dees not depict the lower half of the children so it cannot be ascertained, as to what they were wearing with zegerd to lower clothing. The background within tha Pelareid photogzaph was the game background seen through out other pictures booked into evidence during this ,irivestigation. It isa Hollywood themed background, with movi cameras, seafchlights.\snd stars in the night sky. The phrase, "ATE “yetz” bed cal Hal" were printed on the lever portfon af/the picture, pe: BOE gga ren’ fn ELL the next ike of evidence 1 chiMila AP WEE MUSE? ania was described az being photographs of three wnideatifiod males, Oblewarnvonaens SHERIFF'S DEPARTMENT Santa Barbara Count: Case Number CONTINUATION SHEET 03-5670 PAGE 6 Ta] USTECNTINUATION, [0] OECERIBE: PHYSICAL EVIDENCE LOCATION FOUND & DGPOBITION. FE} KARAATIVE. (| DEPOSITION, which were conteined within a Kodak box, which was found in the office/msseum area of the Neverland Ranch property. This item was a yellow, red, and black Kodak professional paper bex, which contained numerous 8"x10" photographs. The following phrase was written in black marker on the top of the box: “Why Photo shoot". The box contained numerous §x10 photographs, which depicted the same individuals as pictured in Iteme Number 2003 and 1004. In addition, Michael Jackson was also phetegraphed in the company cf these individuals. again, these individuals were posed in provocative manners with bare chests. - The next item of evidence I reviewed was Item Number 1006, which wae described as being photographs contained within a bex. This item was @ yellow, red, end black Kodak professional paper box. which contained numerous @x10 photographs. The words “Why Photo Shost" were printed in black marker on the top of the box. There waz also a yellow sticky note, which stated ~ownez’s office” on tos of the tox. The photographs within this box were of che same individusis depicted within Tcem Number 1003, 1004, and 1005. “The next item of evidence I reviewed was Item Number 1007, which was described as being photographs of sem!-aude males, which were within a box. This item was a yollow, red, snd black Kedex professienal paper box, which contained numerous 6xl0 inch photographs. “Why Photo Shoot” was printed in black marke: cn the top of ehe box and the same three individuals were pictured in the photographs. ‘Theze did not appear to be any photographs depicting Michael Jackson within this box. The next item of evidence I reviewed was Item Number 1008, which was described as being photographs of semi-nude males. This item of evidence was a yellow, xed, and black Kedak professional paper bex, which contained 6x10 and lixid-ineh phetegraphs. "ST" wes printed in black marker on the top of the box. This box also Contained picturee of Michael Jucksen along with members of the “31 pop group. They were of the same type of poses cescribed ia the previous items. It showld be noted, I recognized the photographs desczibed in icem numbers 1003 through 1008 [except the Polarnid photograph) as being associated with the pop croup, “3T." 1 recalled reading a magazine article, which discuseed thie pop group and their association with Michael JACKSON. The article had some of these photographs OGI7WOVAAPOW SHERIFF'S DEPARTMENT PAGE 7 Santa Barbara County Case Number CONTINUATION SHEET 03-5670 [A] Uy CONTINUATION, (8) DESCAIBE: PHYSICAL EMDENCE, LOCATION FOUND A DISPOSITION, (Gi NARRATIVE. 10} DISPOSITION, associated in it and.associated the photographs’ with a photo shoot fer a Compact Disc cover for 3T%s single titled “Why.” I further Teamed the pictured individuals were Michael JACKSON’s nephaws (Tito Jackson's sons). Although the phstes contained in Item(s) 1003 through 1008 appear to be commercially produced, they do depict young males in limited clothing and various provocative poses. Based on my training, this type of material can be used as part of a “grooming” process by which people (those seeking to molest children) are able to lower the inhibitions of their intended victims and facilitate the molestation of said victims. The next items of evidence I reviewed was Item Number 1008, which was described as being a black plastic case, which contained telephone recording equipment. I found this item to be a black plastic case made by “Aerospace by Andiamo”. The top of the case was sealed by two pieces of unbroken SBSO evidence tape. 1 broke the seal on the evidence tape in order to view the contents of this box, Witkin this box, I located a number of surveillance type equipment items. The first item was a black and white box, which indicered the content was a “Supex-Mini Camera w/ Lighter.” The camera within the box appeared so be approximately four-and-a-half inches. by one inch, by two-thirds inch in size. The item was a camera, which could be used as a cigarette lighter. There were two unopened containers of “Spy Tech" film within the box. I else found photocopies of price sheets and/ or purchase oxdere for Pertable electronic surveillance/ counter meagurcs. There wao oloo & phetecepy of a video surveillance system with audjo capabilities schematic, There was also a schematic for remote rcom audio monitoring. I also located numerous items, which would allow someone to record both telephono conversations, as well as, conversations made in person. Also within this case, was 6 surveillanse type extended time recorder. There was an audiccassetre -tape in the recorder. The audiocessette tape had ‘tape for long-play recordere” typed on the front of the tape. 1 made a working copy of the cassette tape and returned the original inte the recorde>. I also feund a business card for a James AL Iupoci, who 45 2 private investigator with an addreas o: SENN 22 fornia 90231, telephone ounbor a The final item of evidence was Item Number 1010, This icem was deseribed as being an envelope with telephone messages and numbers oul”1 2 3 4 5 6 7 8 8 10 nv 12 13 14 18 16 7 1B 19 SHERIFF'S DEPARTMENT PAGE 8 Santa Barbara County Case Number CONTINUATION SHEET 03-5670 TH UETEONTRUATION (1 BESCTIGE: PrTSIEA EVOEAZE LOCATION FOUND & DISPOSITION, [2 WARRATHE, [o] OSPOSTION, from “Dedder."(sp) The envelope was off-white in color and ‘mr. Michael Jackson” was printed in black ink on the front. There was a printed picture of a boy sitting within a circle on the front of the envelopo, It should be noted this sama picture was found in stationezy contained in other items of evidence seized during this investigation. There wee a telephone message of unknown date fron “Deider."(sp) The xecurn telephone number was The second piece of paper appeared to be torn out of a telephone list. The only person related to this investigation wes Evie (Tavashi) with a celephone number cf Qi I returned the above listed itens of evidence to S3SO Property Officer Chuck Villareal. I attempted to review the working copy of tha audiocassette tape T found in the surveillance recorder (Item 1009}. Due to an iesue with the high speed duplicater, che working copy was not useable. I centacted Sergeant Ruben Cintron, who supe=vised che sBs2 property room. I rechecked out item number 1003, 1 attempted to check the original audiocassette tape fox content. There was a recording at the beginning of the tepe, but duc to the extrenely slow recording speed, I could not understand what was said. I heard @ dialing sequence, followed by what sounded like a short, recorded message. We did not have any equipment to play the audiccassette at a speed, which would onable us to understand whee wae said. To aspist in any future atcenpts to review the content of the audiocassette tase. I repackaged the audiocassetce tape inte a separate evidence bag and assigned it an evidence number of 100s. I returned izem number 1009 and 10098 to SBSO Property Officer Chuck Villareal. On 12-12-03, at 1428 hours, I contected Santa Barbara Sheriff’s Office Property Officer, Chuck Villareal. and checked out numezous items of evidence. ‘The purpose for checking out the treme of evidence wes to conduct a detailed review of each item and ascertain its evidentiary velue. Specifically, I checked out icem 0614SHERIFF'S DEPARTMENT. Sante Barbara Count Case Number CONTINUATION SHEET 03-5670 PAGE 9 Tal UN GSNTDVUATION, (a) DESCRIBE PHYSICAL EVDENCE LOCATION FOUND ABRIPGSTIGN, (C1 NARRATWE. (0) DIPOSRON, numbers 326, 328, 341, 349, 353, 354, 359, 366, 369, 902, 906, and 907. The firet dtems ef evidence I zeviewed was item number 328. This iten vas described as being 4 book, which contained photogrsghs of children. Thio item wae lecated within the master m Michael JACKSON’S bedroom, This book was titled, Tetras Beach Portraits, and appeared te have boen compiled by Carol Shlera and James Rondeau. The book appeared to be a compilation of photograshs, which depicted children with a beach kackground. The children were clothed in swimvear and/ or undergarments. The children appeared to be of various ages from adolescent ago. to late teen aged years: I reviowed gack page of this book and did not locate any writings and /or’phetegraphs inserted within the pages, which did not appear to be an original part of the book. Nothing within thie book appeared te be pornosraphic, or illegal in nature. Based on my training. this type of matexial can be used ac part of a "grooming" process by which people (those seeking to mo: dren) are able co lover the inhibitions of their intended -ricy‘zs and facilitate the molestation of said victims. The next item of evidence I reviewed was Ttem numbes 328, which was described as being paperwork aseociated with Prank Tycon. This item was found within -the main closet staixcase, near ‘the front deor' of Michael JACKSON'S, residence. The first item I reviewed - within this package was’a four page fax trancmigsion, addressed to Mr. Michael Jackson and Mr. Frank Tyson from a Court Courecy and Derek’. Rundell. The fax transmiseien appeared te diecuss a business veature, which was, code named “Project 31". Specifically, . dt saemed to address actions necessary in order to set up a corporation. Also within this item was an unscaled anvelope addressed to Mr. Jackson. Upon opening this envelope, I feund it te contain a multi-page billing statement from South Beach Doctors, located at 9873 Harding Avenue in Surfside, Florida 33154. A. Farshchian, M.D. was associated with South Beach Doctors, along with an apparent telephone number of 305-866-8384. The bill was addressed to Frank Tyscr, QR Ch. 21423. The bill seemed to concern numerous in house physicals, which occurred during April and May of 2001. On the back of one of the bills, theze was hand written notes in black ink. The notes appeared to OvdtBSSVIASGNS Saor]9HEUVNH 22 23 24 25 2 28 2 30 31 32 33 35 36 37 3B 33 41 a SHERIFF'S DEPARTMENT Santa Barbara Count! Case Number CONTINUATION SHEET 03-5670 1H] GT GoeteWATiON,_ 6] OBSCRWE_PRYSICHL EMIDGNGE,WSEATION FOUNG & DPORTICN. (] KARAATIVE. )OIAPOSTION PAGE 10 be monetary figucca associated wich the bills. Also the name Alex Fazshchian, M.D. was writven in black in. Also contained within this icem, was a legal sized manila envelope. The envelope appeared ta be addrecoed to Frank Tyson from @ Danny O'Donovan, and pertained to an event in Dubai with 8111 Clinton and Neleon Mandela. Michael JACKSON'S name wes weitten in blue ink on the front of the envelope. The contents of the envelope portainod to a Sefence Technolosy and Arts Royal Summit (STARS) in the year 2001. There was an article within the magazine about a scheduled release of a Michael JACKSON album. No other material within the magazine eppeered to be pertinent with regard to this investigation. I did not find any writings and/ or picture ingezted within the magazine. which did not eppear to be an original parc of the magazine. Also within thie manila envelope, waa 3 faxed copy of 4 Universal information Research document, which appeared to be a part of someane's exedit histezy. The eredic history printout did not identify whe the sexsen was that was documented on the paperwork and there was no information on the printout, which could ed to identify the person it addveseed. The next item of evidence I reviewed was Item number 342. This irem was deserited as being paperwork associated with Frank Tyson, which was located in the upstairs storage/ pantry area on the west end of the staircase within che main residence. It should be noted thee someone opened this item of evidence on 11-21-03. The initials of the person re-sealing the item, appeared to be sz (possibly Sorgoant Steve Robel). within the item I found, T lecated a receipt for admittance into the Hollywocd Wax Museum cn 07-18-2000. The xeceipt indicated 2 adults and a “child combo" edmission were purchased. There was also a letter sized manilu envelope with “Frank Cascio" “confidential” wricten on the top. Within thie envelope, I locared 3 receipts. One receipt was from the Riverboat Princees at Universa, Studios, the second from Amazing Pictures Outtakes and the thiré from the UCLA store-Spiric. There was an opened envelope, which had the Sea Clifi Apsrtments, lccated at 40 Oceano Avenue #10, Senta Bezbaza, CA. Within this envelope, T found an application te vent, wherein ic appeared Frank “Cascic" Tyson was applying to ent a domicile. Of note, Tyson listed his employment 2s being MJ Productions, with a telephone O62!SHERIFF'S DEPARTMENT PAGE 11 Santa Barbara County Case Number CONTINUATION SHEET 03-5670 {4) METCONTINUATION, (G] DESERIE: PHYSICAL EVIENEE,LOTAINON FOUND & DIBPGLTTION, 1G) NARPATWE 0] BEPESTION. number of 310-278-1811 and claimed he had worked for 3 years at this lecation. The application did not have a date. I else located chree strips of 35m negatives. I provided the negative strips to Detective Paul Zelis and asked him to take the negatives to the SBS9 Forensics Bureau. 1 further asked to heave Perensica personnel ecan the aegative scrips and print uscable images of the pictures. Detective Zelis did this and returned the original negative strips to me. Detective Zelis retained the image prints. The SBSO forensics Bureau will maintala the digital image file for these negatives. Also within this item was an cavelope addressed to Frank Tyson fron Pitts and Bachmann Realtors out of Santa Barbara. The content was a hand-weitten letter from a subject, who identified herself as Mary, The letter was dated 10-30-00 and pertained to names and telephone numbers of cleaning ladies. There was also a bank atatement addressed co Francesco Cascio, with an address of CA. The bank statement was fron Los Padizzs Bank. The bank statement was date? Cctober 21, 2000. There was also a Cox Communicatione work order for customer named Bxank Tyson Casio, which listed an address of S—: GA. The work order was dated 11-02-00, The sustemer signature did not appear te be that of Frank Tyson, There was elso a lined sheet of paper, that had the name of Sennic Massien, cf Universal studios, 100 Universal Center Drive, Universal city. CA. 1606, with a phone number of T aise iecated 4 Verizon shipping label, waich was addressed se Frank Tys0: © with an addresa of There was also a bill from Rock-it Cargo USA, Inc., ——— wherein it appeared furniture was shipped from MJJ Productions ro “Frank” at! There were also miscellaneous receipts from various locations including Universal Studios Hollywood, the Hellywood Guiness Museum, Ripley's Believe Tt Or Net, Long's Drug Store in Buellton, and a Rite-Aid Drug Score in Hollywoed, CA, The next item of evidence I reviewed was Item mumber 349, which wes described as being paperwork found within the master, bathroom. This item was a letter from the Center for Regenecative Medicine, located at 9573 Harding Avenue, Miemi Beach, Florida 33154, telephone number 305-866-8384. The letter ie addresced to “Dearest DbaetBoevansuns RL Leesnaran | SPERMS RAEI SBRVRRAE SHERIFF'S DEPARTMENT PAGE 12 Santa Barbara County Case Number CONTINUATION SHEET 03-5670 TA LNT CONTIMUATION, 18) RESCHIBE, PHYSICAL EVIDENCE, LOCATION FOUND & BIEPOEITION. [6] NANGATIVE. 1D} OIEPOEITION may and is daced July 21, 2002. The letter indicated it was from De. Farshchian. The letcer pertains to ® “program” for ourpaticat detoxification. The next item of evidence I reviewed was Item number 253. This ikem was described as being a Christmas invitation, which was found in the master bedroom area. This item consisted of an opened letter, which was postmarkad November 2002, out of New York. The letter was addreesed to Evie Tavescie, with an address cut of Sherman Oaks, California. Contained within the letter was information about purchasing access to the Lita Minelli Christmas Spectacular and Opening Night VIF Dinner Party, which was to occur on Thursday, Decerber 5, 2002. The next item of evidence reviewed was Item number 354. This was desoribed as being a November 2003 calendar. Of nate, this calender appeared co contain information about Michael JACKSON going te Capetown, Africa, to meet with Nelson Mandela. The everse side of the paper had writing on it. Big Boy number 20 was wziccen in silver marker. : The next item of evidence reviewed w22 Item number 359, which wes descrited as being a beck found in the master bedroom den. This item was a hard covered book titied “Peo-chi". The author wae MayumivLake. I reviewed each page of this book and did not lecate any writings end/ oz pictures inserted'within che pages, which did “net appear to be an original part of the beck. This beok was 2 compilation of photographa in which axmpits were photographed in such a manner as to make the picture seem like {¢ depicte the female vaginal area. None of the material within this book eppearea to be porncgraphie in nature. aascd on my training, chis type of material can be used as part of a “groeming” sroccas by which people (these seeking to molecs children) are able co lower the dnhibicions of their intended victims end facilitate the molestation of said victims. The next item of evidence i reviewed was Item aumber 369, which was Gescribed as beins two keys, which could be used to open the master bathroom. These keys were of Schlage manufacture and appearad zo have the same cut. The next item of evidence I reviewed was item number 902, which wee described as being 2n address book. ‘This item was seized from 0633SHERIFF'S DEPARTMENT Santa Barbara Count: Case Number CONTINUATION SHEET 03-5670 [Cais eormenron i ceseRRe PHBA eveENcE eeATen OUND LDETOSTION 1 ARATHE © OBPcETION_| PAGE 13 Hamid Moslehi’s residence. It should be noted, this item was opened on two prior occasiens, 11-20-03 and 12-08-03 by a subject with initials of “cw” and a body number of 2334, This item appeared to be both a day planner. as well as an address book. Within the front cover of this item was a compartment which contained’ numerous, business cards and pictures. The pictures were of the same individual. The business cards were for 3 attorneys. 2 ~ dentists, and 2 photographer. ‘There were also 2 business cards for amid Moslehi. of note, the-day planner shows Mcslehi going to Flexida on January 22™ ang returning to Los Angeles on January 15. There azo also notes to contact Evie (Tavaschi). There were also entries showing Moslehi going to Florida on February 6, 2003, follewed by going to Neverland Ranch on February 8, 2003. There was also “60 min interview" written under Neverland. There wae also an entry on February 15“ stating interview with “Jacksons” and “Fox Aired® and ‘MJ on February 20, 2003. On April 11, 2003, Shannon “Mi0" de written on the “Fox special with mJ- is written.on April 2%, cn Meteber 2, 2003, sm Court is written nthe log. Bvie Tavaschi’e addreon and telephone number were’ written in the addreap portion of the ledser. There was aleo an entry titled’ Provident MJ (account). I photographed this entry. This entry had numerous names and telephone nunbers aeseciated with it including CER None of the nancs appeared. to be associated with our investigation. On a notepad, there was a hand-written note that appeared to address photo assistants. There were three names and telephone numbers after this entry. Tha firec is Janie, phe second is Alex, (QE The third fo Troy. oN: The next item of evidence I reviewed was‘item number 906. ' Thi: item was described as baing miscellaneove contracts and invoices between Michael JACKSON and Hania Mosleni. Within this item, I found a manila folder containing a receipt for Shurgerd Storage out of Weedland Hills, Unit number 2110. This item was dated 09-23-03. ‘The next item was a manila folder containing releases from Ja Productions, which allow the images of childzer to be used by Mao Production: The following is a list of the chiidren‘s names on the various releases; Chare'la Torres, Donald Coukrite, Christopher Jerdan, Marissa Morris, Aarin Ables, Nexissa Scott, Nicoiya Scott, Angel Crockett, Lauren Garner, Cameron Paysinger. Justin Paysinger, Spencer Paysinger, Cana Cherrington, Drew 0624waryaurans SHERIFF'S DEPARTMENT | . Case Rusioar, CONTINUATION SHEET 03-5670 TPL LSTEOMTATON. 6] OBSER@E PYTSICAL EVBEAEE LOCATION FOUNO A OISFORTION. (C] NARRATWE. 9} OMPORTION Littlecon, Cory Martin. Mitchell Rowle: Jorder-Ann Jacobson, Ashley Knorc, Kassie Welbaum, Lindsey Welbaum, Sydney Welbaum, Miyah Velszquez, Jose R. Velazquez. J=., Curtis Boneck. .and lastly a Danny Maxdoy. Some off the releases had photographs attached to them. All of the releases.were dated 10-15-00. There were no addresses and/ or‘telephone nunbera associated with the releases. There-was an additional manila folder, which contained information portainifig to che Michael JACKSON 30 Anniversary celebration. There was an additional manila folder which contained information pertaining to Michael JACKSON. There was ane cheet, which hed humerous telephone numbers pertaining to subjecte associated with this investigation. of note, the following names and telephone pumbers were written. . 2. Ronald Gs . 2. Grace ellie, 3. Dieter 4. Neverland . 5. Frank eS : I aleo found three pages of hand-written not which appeared to be issues somsone wanted te discuss with Michael JACKSON. The main Adasue discussed within the notes appeared tobe receiving payment of some sozt. There were’ hand-written notes pertzining to the interview cf (Vi) and (V2) in October 2000 and September 2000. The bandweitcen notes did not appear to be dialogs. There were also €ax tranamissiona, which appeared to pertain to the Martin Bashir documentary. The fax trensmissions were from Brad Lachman . Productions and were dated February 14, 2003. This manila folder was titled Fox Special. The next manila folder was titled Script and Shot List. This folder contained hand-written ootes pertaining to video shoots at Neverland Ranch. The next folder was titled Lendon and conteined Papexwork dated in 2002. and seemed to be with vegard to Michaol, JACKSON'S visit to Oxford Union. The next manila folder was titled New York Rock ‘N Roll Hall of Fane. This contained paperwork dated im 2001, I did not locate ay information which seemed partinent to this investigation. Also within thia item was a manila folder titled “legal papoxe". Within this, I located an independent contracter confidentiality agreenent from Md Preductions. The agreement was unsigned. The folder also contained other paperwork pectaining to MIT Productions. = also found paperwork kitled “Outstanding invoices without interest and late payment”. Of note, there were entries pertaining to Neverland, Michael JACKSON and 062s: SHERIFF'S DEPARTMENT PAGE 15 Santa Barbara County _ Case Number CONTINUATION SHEET 03-5670 [al USTCONTIRUATION. [8] DESCRIBE: PHYSICAL EVDENCE, LOCATION FOUND & BISPORTION.[C] HARRATIVE.[D} DISPOSITION 4 (v2). The entxy with regard te (V2) was on 02-20-03. Of note. the 2 entzy on 02-08-02 (should probably be 03), indicated it- pertained 3 te activities in Florida and Neverland (Fox Special). Also within 4 this item was a large green folder. which contained numerous items 5 of paperwork pertaining te Hamid Moslehi filming and/ or producing 6 vddeo footage for Michael JACKSON and/ or Md Productions. 7 Fs a The next item of evidence I reviewed was item aumber 307, which was 9 described ac being a boarding pasa obtained during the search of 10 Mamia Meslehive residence. This item consisted of a boarding pues” 11 and an excess baggage ticket for Hamid Moslehi. The boarding pasa 12 and baggage claim tickct pertained to American Airlines flight 245 13 fxom Los Angeles to Miam{ International Airport. Tne boarding pase {4 and baggage ticker wexe dated Pebruazy 7, 2003. 4 i 16 The last item of evidence I reviewed on this date wes item numbe= 17 366. This item vas described as several books and magazines 18 containing nude photographs, which wera located within the master 19 bedrcon/ den arwa. Thie item consisted of numerous hard cover 1 books, sft cover books, and periodicels. 22 Wichin this item, chore were 5 copies of a periodical titled “Thr 23 onudist. Included within this was the February 1935, March 1933, 24 May 1935, the June/July 1935 and the August 1835 issues. This item 25 was described as being the official publication, International 25 Nudist Conference. These periodicals contained nude photographs of 27 «men, women and children, as well as writings pertaining to nudisn. 28 The photographs and writings did not appear to ba pornographic in 290 nature. : 30 31 Also within thia item was a plostic sleeve, which contained 32 numerous additicnal nudist related periodicals. There were 73 33 copies of “The Nudist, Sunshine and Health". These were aluo 34 periodicals, wkich contained photographs ef nude men, women and 35 children, and writings which digcussed nudity. Nene of the 36 materiale contained within these items appeared bo be pornographic 37 in nocure 38 39 There was one‘ magazine titled, “Solaire Universelle Day Sudisme", 40 May 1961 issue. This magazine described as being the 41 International Jouxnal of sudism. This item contujned photographs 42 of nude men, women and children, es well as writings and articles deaeSHERIFF'S DEPARTMENT Case Number CONTINUATION SHEET 03-5670 TH WET EOWTNUNTION, (0) DESEROE: PYG. BNOENCE, LOCATION FOUND & DISPOSITION, (6 NARAATIVE 2) DISROSTION PAGE 16 pertaining to nudisin. None of the material within thic item appeared ta be pornographic in nature. There was aiso a magazine titled "American Sunbather". Thie was the May 1961 issue, and it contained photographs of nude men, women and children. It also contained writings pertaining co nudicm. Nene of the material «ithin chic magazine appeared to be pornographic in nature. There were also 3 issues of “Eden. This item contained nude photographs of men, women and childzen. Two of these magazines wore copywritten in 1961, and cne in 1963. These magazines contained photographs of naked men, women and children, and writings which discussed nedity. None of the material within theac items were pornographic in nature. 1 did not find any writings and/ or pictures inverted within acy of the above noted nudism relaced poriedicals, which did not appear to be an original part of the periodicals. whe fizst soft cover book I reviewad was titled Man, a Sexual Study pfoMan, with text material by tevens. This item was compilation of photographs and writings, which pertained to homosexual activity ketwaen men. The phocographe depicted naked males engaged in sexually explicit activities including oral sepulacion and anal sex. I did not locate any writings and/ or pictures inserted within the pages. which did not apnear to be an original part of the book. The next seft cover hock I reviewed was titled, Taormina Wilbelm Vex den. This item was a compilation of photographs, which depicted both Witwer tes, who were posed in the nude. the groin area cf the sales wae disployed in most of the photographs. None of the photographs depicted the individuals in sexually explicit activities. I did not locate any writings anc/ or pictures insexted within the pages, vhich did not appear to be an original part of the boct. The next soft cover book I reviewad wes titled, The Golden Age of Neglect, authored by Ed Templeton. This book appeared ts be sicned by Ed Templeton in 2003. The signature was on the inside fronc cover. This bock appeared to be a compilation of photographs which pertained to problem issues with adolescents end teenagers. These 6.27yee Golder AS OF ffEGtE ¢ (SHERIFF'S DEPARTMENT Case Number CONTINUATION SHEET 03-5670 Te st GOMTeTON (0) BESCABE PrVslenCVDENCE,LOEATEN FOLND A OBPOETION (El HAMMATWE, Bi] DEPOSITION PAGE 17 issues seemed to focus on antisocial behavior on the part of adolescents including alcohol consumption and sexual behavior. Specifically, the sexual behavior depicted in thie book contained photograshs which depicted male and female eubjects, in various ‘stages of undress, including full sudity. Some of the phetographo depicted semvally explicit activity, including oral sex. masturbation and digital penetration, With the exception of the auther'c oignature, I did not locate any writings and/ or photegraphs inserted within the pages, which did noz appear to be an original part thereof. It should be noted the subjects who appear in the photographs vhich depicted the sexually explici: poses, appuared te be within the age range of late adolescence to young adults. However, I-was unable te accurately determine x the 31 jects wey i Se 18. Therefore, T was unable co determine with any accuracy if material within this book could be considared child pornography. The firct hard cover book I reviewed was titled, Befo: Man, by author Rey Dean. The book was a compilation of photographs Which depicts: aude males in nature scenes. The raterdal within the bock did net appear to be pornographic in nature. I did not locate any writinge and/ or pictures insezted within the Book, which did net appear te be an original part of the book. The next hard cover book I reviewed was titled, Gebvand Rod, by author Tom Bianchi. This book was a compilation ef photogzephs of tuo adult males, who for the most part, were pictured in full and/ or partial audicy. The malec Were not depicted in cemually explicit poses. The cover of the book indicated the bock was 2 photo-decumentstion of the romance between the two pictured subjecte. I did not locate any writings and/or pictures located within the pages that d4d net appear to be an original part of the book. The next hard back book I reviewed was titled, Reom to Play, by authorSimen Johan. It should be noted thac this item was previously reviewed during the examination of another item of evidence. This book is a compilation of photosraphs of chiléren, which appear to nave been altered ("morphing"). [ did not lecace any writings and/ or pictures inserted within che pages of chis book that did not eppser to be an original purt of the book, T dtd lecete a blank piece of crumpled pape=, which was between the front sever and the first page of the book. deadSHERIFF'S DEPARTMENT PAGE 18 Santa Barbara County Case Number | CONTINUATION SHEET 03-5670 a] UST COMTWWATION. 18) OESCROE. MrYBICAL EVIDENCE, LOCKTION FOUND & DISPOSITION, [6] RARAATIVE, (0) DISPOSITION, The last hard back book within this item was titled, Naked asa Jay by auther Dian-Hanson. This book waa 2 compilation of hotogréphs and/ or writings. The photographs depicted both men and women in various stages of nudity, including full nudity. Some ef the photographs depicted the individuals engaged in sexually explicit activities. This bock was also reviewed es pert of another item reviewed at an earlier date. I did tocate a blank picce of crumpled paper, which was between the frent cover and the firet page of the book. Based on my training, the macerial depicted in tke above noted Periodicals and books contained in Item #366, can be used as part ef a “grooming” process by which people (those seeking to molest children) are able to lower the inhibitions of ehildren ard facilitate the molectation. After completing the review cf che abevea noted items of evidence, 7 secured the items of evidence into locker numbers eleven and thirteen at the Sheriff/a Department Main Station. 1 notified Santa Barbara Sheriff's Office Property Officer Chuck Villerreel, that the items of evidence were secured in lockers cleven and thirteen. (D) CASE DISPOSITION: Actentior =ecords, investigation continuing. 0624