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                          Jackson's constitutional rights until his treatment for drug de-
                          pendency was completed. He further objected on the grounds
                          that Michael Jackson's deposition should not be taken until
                          the threatened criminal prosecution is disposed of and until
                          his medical condition has been resolved.
                                 Mr. Feldman stated in his reply that Michael Jackson's con-
                          tinued strategy was delay, delay and more delays. He also stuck
                          to his assertion that the memory of a minor is crucial if the
                          victim is to successfully prosecute an action for child molesta-
                          tion. He further stated that Michael Jackson's drug addiction
                          did not prevent him from giving an 8-10 hour deposition in
                          Mexico City on November 8, 1993 in a copyright infringement
                          case while on tour.
                                  Michael Jackson's attorney, Eve H. Wagner, stated that he
                          could not be deposed because of his drug addiction. She de-
                          scribed him as being glassy eyed, that he could hardly stay
                          awake, he had difficulty holding physical objects, slurred
                          speech and was unable to focus on issues.
                                  Michael Jackson's doctor in London, Dr. Beauchamp
                          Colelough, issued a statement on November 20, 1993, validat-
                          ing Michael Jackson's condition. He stated that David Fore-
                          cast, Michael Jackson's physician in Mexico City, and Miss
                          Elizabeth Taylor brought Michael Jackson to him on Novem-
                          ber 12, 1993 to participate in a 6 to 8 week program for his
                          dependency to pain killers. It was Dr. Daniel Forecast who rec-
                          ommended that Michael Jackson cancel the remainder of his
                          tour. Mr. Fields spoke with Mr. Forecast over the phone where
                          he informed him that Michael Jackson would be canceling the
                          tour, which would cost him millions of dollars and be put into
                          professional care. He refused to disclose where Michael Jack-
                          son would be receiving his treatment because of the media
                          attention it would draw, which would destroy Michael
                          Jackson's possibility of receiving proper care.
                                    The law that Fields cited in his Reply was that there was no
                          constitutional right to a Stay. U.S. v. Kordel, 397 U.S. 1, 90 S.
                          Ct. 763 25 L.Ed.2d 1 (1970); People v. Coleman, 13 Cal.3d. 867
                          (1975).





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