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Jackson should not be required to respond to discovery until
the conclusion of the pending criminal investigation and that
plaintiff should not be permitted to use civil discovery to ha-
rass and intimidate third parties.

Motion for Trial Preference
Mr. Feldman hit them with another blow by filing a Mo-
tion for Trial Preference. This is a special request to have the
trial heard within 120 days after the motion is granted. This
request is generally given to children under the age of 14 years
old and seniors due to their inability to remember details after
a prolonged period of time. The Motion for Preference was set
to be heard on November 16, 1993, and a trial date of March
16, 1994 was requested.
Mr. Feldman stated in the Trial Preference Motion that the
system designed to protect a child from the embarrassment
and ridicule of being a victim in this type of crime has totally
failed this minor due to the worldwide publicity of the leaked
Department of Children's Services report. Mr. Feldman, obvi-
ously good at painting pictures of despair, further alleged that
a delay in this case would send a message to the world that no
child would be safe from someone with a superstar status such
as Michael Jackson. He concluded that his client, the 13-year
old boy, was entitled to live the remainder of his childhood
without a cloud over his head that he was an extortionist and
liar. (He was referring to statements Mr. Pellicano made to the
press which was televised stating that Dr. Chandler and Mr.
Rothman were extortionists and liars). Mr. Pellicano submit-
ted a Declaration to the Court refuting Mr. Feldman's claim
and stated that his comments were directed to Dr. Chandler
and Mr. Rothman and were never directed at the 13-year old
boy.
The law that Mr. Feldman used to base his request for trial
preference was Civil Code of Procedure section 36, which re-
quires that a party to a civil action for personal injuries who is
under the age of 14 be provided with a speedy trial date within
120 days. Mr. Feldman further stated that his request would

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