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                          of the sexual abuse and did not witness such events, the plain-
                          tiff lacked standing to pursue his cause of action, and that the
                          injuries were the proximate cause of plaintiff's own negligence,
                          carelessness and/or other legal fault. The Complaint is based
                          on allegations that the defendant improperly cared for and/or
                          failed to protect the plaintiff's minor child from sexual abuse
                          and that the defendant was unaware of the abuse, and as the
                          child's custodial parent, her conduct was privileged. The plain-
                          tiff owed her back child support payments in the sum of sev-
                          enty thousand dollars.
                                David Schwartz cross complained against Dr. Chandler for
                          invasion of privacy, violation of Penal Code 632, and inten-
                          tional infliction of emotional distress. In his statement of facts
                          Mr. Schwartz contended that in the summer of 1993, the
                          Schwartz family was torn apart by Michael Jackson's interfer-
                          ence in the family. Schwartz further stated that he did not think
                          Michael Jackson had molested his stepson.
                                 Mr. Schwartz stated that on July 7, 1993, he received a call
                          from Dr. Chandler wherein he was abusive, belligerent and
                          violent. He stated that it was not uncommon for Dr. Chandler
                          to become violent. Mr. Schwartz said the reason he recorded
                          his conversation with Dr. Chandler was because Dr. Chandler
                          told him he had thoughts of killing the entire family, includ-
                          ing the children, and that Mr. Schwartz recorded the conver-
                          sation out of fear concerning Dr. Chandler's threats to kill the
                          family, including Mr. Schwartz.
                                  Mr. Schwartz further stated that the reason he presented
                          the recordings to Mr. Pellicano and Mr. Fields was to enlist
                          their aide in protecting his family and that it would prove that
                          Dr. Chandler had threatened violence. He said Mr. Fields and
                          Mr. Pellicano did not return the recordings, nor were they able
                          to assist him. Mr. Schwartz alleged that Mr. Pellicano gave the
                          recordings to Mary Fisher, without his permission, who used
                          some of the contents of the tape for the article she wrote en-
                          titled, Was Michael Jackson Framed?, which was published by
                          Gentleman's Quarterly in 1994.





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