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- Geraldine Hughes -

sition, they are allowed to motion the Court for assistance in
getting an order for their attendance by way of a Motion to
Compel.
Mr. Feldman's office noticed the depositions of Michael
Jackson and 11 nonparty witnesses as follows: custodian of
records of Pellicano Investigations, custodian of records of
Anthony Pellicano, Phillip Le Marque, Stella Le Marque, Gary
Hearne, Janelle Wahl, Gayle Goforth, Evangilcan Aquilizor,
Anthony Pellicano, LaToya Jackson, Bianca Francia. Michael
Jackson's attorneys noticed the depositions of: Plaintiff, the little
boy, Barry Rothman, June Schwartz (Chandler) and David
Schwartz.
Mr. Feldman's office requested discovery from Michael
Jackson as follows: Form Interrogatories, First Set of Special
Interrogatories, First Set of Request for Production of Docu-
ments, Second Set of Request for Production of Documents
and Second Set of Special Interrogatories.
Michael Jackson's attorneys did not refuse to produce him
for his deposition, but kept putting the date off. They did fi-
nally pinpoint a date to produce Michael Jackson for his depo-
sition sometime in January, but stated that the January date
was the soonest he could be produced because of his being out
of the country on tour. Mr. Feldman's office was so anxious to
take Michael Jackson's deposition that they were even willing
to travel out of the country at a mutually agreeable location
just to take his deposition earlier than January.

Motion to Compel Michael Jackson's Deposition
While Mr. Fields office was trying to get a Stay of Discov-
ery and the trial date, Mr. Feldman's office, on the other hand,
filed a motion to compel Michael Jackson's deposition and to
produce documents for inspection. Mr. Feldman was having a
hard time deposing Michael Jackson. Michael Jackson and his
attorneys responded to all of the requests for inspection of
documents by asserting his Fifth Amendment rights.
Mr. Fields' stated his reason for objecting to Mr. Feldman's
motion to compel was based on the fact that it impaired Michael

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