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Geraldine Hughes -

Los Angeles, the State of California, and in other locations both
within and without the State of California. The complaint also
alleged that Michael Jackson repeatedly committed sexual bat-
tery upon the minor. The alleged damage caused to the minor
was described as: injury to his health, strength and activity,
injury to his body and shock and injury to his nervous system;
all of which injuries have caused and continue to cause plain-
tiff great mental, physical and nervous pain and suffering and
emotional distress.
The complaint further alleged that the gifts, vacations and
trips that Michael Jackson lavished upon the minor was his
way of forcing the minor to comply with said sexual demands
and to seduce said minor. Although Michael Jackson had lav-
ished many minors and traveling buddies with gifts, trips and
toys, none of whom corroborated the 13-year old boy's claim
of sexual molestation.
The filing of the civil lawsuit was made while the criminal
investigation was still ongoing. Generally, the civil lawsuit is
not initiated until after the criminal case has been resolved.
The civil lawsuit allows hearsay and circumstantial evidence
to be admitted, while the criminal case does not. Therefore,
the premature filing of a civil lawsuit while the criminal in-
vestigation is ongoing can cause the defendant to be preju-
diced or suffer self-incrimination if they are indicted in a crimi-
nal case.

Answer to the Complaint
Mr. Fields' office filed the answer to the complaint on Oc-
tober 29, 1993. As soon as the complaint is filed and the defen-
dant answers the complaint, they are entitled to start the dis-
covery phase of the action. The discovery stage allows each
party to ask questions, called: Depositions, of the parties or
witnesses in a case, request documents (Request for Produc-
tion of Documents), admit to certain facts (Request for Admis-
sions) and request answers to standard questions called Form
Interrogatories. The courts have a limit on the number of in-
terrogatories or documents that can be requested, but through

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