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1.) Michael Jackson's right to privacy and undue embar-
rassment and annoyance; 2.) his right to receive a fair trial;
and 3.) the rights of witnesses from undue embarrassment and
annoyance.
In Mr. Cochran's motion he further stated that if the pro-
tective order was not granted, Michael Jackson would require
a Stay of the Civil action because of the law enforcement's ex-
pressed intent to use the Civil Discovery as part of it's investi-
gation. Mr. Cochran asserted that the law enforcement agency
was delaying their investigation in order to gain information
elicited through their discovery efforts. This is precisely the
reason why Mr. Feldman tried to obtain a Stay of Discovery
and Trial to prevent information obtained in the civil lawsuit
from being used in the criminal investigation.
The introduction of Mr. Cochran's motion for a protective
order pleaded that the release of information by plaintiff's at-
torney would undermine Michael Jackson's right and deprive
him of a fair trial. Mr. Cochran eloquently pointed out that the
protective order was not only needed for Michael Jackson's
best interest, but was also necessary to protect the lives of wit-
nesses. He wanted no party to disclose any information re-
vealed through discovery to media or law enforcement.
Mr. Cochran also stated that the protective order was nec-
essary to not only protect the privacy of the 13-year old minor,
but the privacy of other children involved in the case. Origi-
nally, the attorneys came to a mutual agreement not to reveal
anything to the media concerning the case. Mr. Feldman repu-
diated the agreement stating that he could no longer honor
any agreement regarding publicity because of Michael
Jackson's family declaring his innocence.
The Code that Mr. Cochran used to base his legal position
was Code of Civil Procedure section 2025(i) which states that:
the Court, for good cause, may invoke any order that justice
requires to protect any party, deponent, or other from annoy-
ance, embarrassment, or oppression. Also, section 2017(c) ap-
plies to general discovery; section 2031(e) applies to document

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