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                          posed the protective order. Their position was that the protec-
                          tive order pertaining to pretrial discovery implicated the First
                          Amendment and was disfavorable and, where issued, should
                          be drawn as narrow as possible. It stated that the invasion of
                          privacy theory presented by Mr. Cochran was hollow in this
                          case because public interest of the best known public figure in
                          the world is unavoidable.

                                The Outcome of the Motion for Protective Order
                                The hearing on the Motion for Protective order was heard
                          on December 17, 1993. The Court ruled as follows:
                               1.) The motion to prevent parties-in-action from disclosing
                          informal and formal discovery material to the District
                          Attorney's office was denied.
                               2.) The Stipulation of counsel ordered as follows:
                                  Neither side shall release to media or persons not a party
                          to the litigation a) videotapes; b) Discovery; c) information
                          regarding personal security of Michael Jackson; or medical or
                          psychiatric records.
                               3.) The motion to compel be filed under seal.
                               4.) The motion to compel further responses to written dis-
                          covery was denied.
                               In this decision, the Court did not completely rule against
                          Michael Jackson. It did take some of Mr. Cochran's points con-
                          cerning privacy in ordering that the motions to compel be filed
                          under seal and by denying the motion to compel further re-
                          sponses to discovery. However, Mr. Cochran's main interest
                          was the protective order and keeping the District Attorney's
                          office from accessing formal and informal discovery material
                          obtained in the civil lawsuit, which was denied. The Court's
                          decision, in essence, favored the District Attorney's office giv-
                          ing them free reign to access and obtain any and all informa-
                          tion that was produced in discovery in the civil lawsuit.
                                 Mr. Cochran's repeated reason for making this request was
                          not to impede the criminal investigation nor to prevent the
                          district attorney's office from accessing the information dis-



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