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Because Mr. Rothman was not a litigation attorney, he sim-
ply responded to the Ex Parte Motion by filing a declaration
on behalf of Dr. Chandler. There were no points and authori-
ties in the declaration giving the Judge legal grounds for their
position, nor did it include anything to defend their position.
More importantly, there was no mention whatsoever about
any suspicion on Dr. Chandler's part in regards to his 13-year
old son having been sexually molested by Michael Jackson.
(There was absolutely no mention of child sexual abuse in the
response to the motion.)
A real case of child molestation would have caused any
normal parent to simply pick up the telephone and call the
police or the child abuse hotline. Giving Dr. Chandler the ben-
efit of the doubt in not doing what a normal parent would
have done, the second course of action would have been to
seek an order from the Court for custody that would guaran-
tee the safety of his son. I know of no Judge anywhere who
would not have granted Dr. Chandler an order for custody
had he made any mention of sexual molestation in his response
to June Schwartz's Ex Parte Motion.
When Mr. Rothman filed the declaration in response to June
Schwartz's Ex Parte Motion on August 16, 1993, Dr. Chandler
had already been negotiating with Michael Jackson since Au-
gust 4, 1993, for money in exchange for not going public with
his suspicion of child molestation.
This point, however, speaks for itself. Let me break it down
and make it more easily understood. The Ex Parte Motion filed
by June Schwartz caught Dr. Chandler and Mr. Rothman by
surprise because they had not anticipated for it in their plan.
(She had thrown them a curve ball.... as Dr. Chandler had ad-
mitted "we were moving according to a plan.") Because it re-
quired immediate response and attention, they were not pre-
pared to adequately deal with such a crucial issue on the spur
of the moment.
The fact that the declaration filed by Mr. Rothman in re-
sponse to June Schwartz's Ex Parte Motion did not mention
anything about Dr. Chandler's suspicion of child molestation

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