Katherine Jackson V AEG Live August 5

th
2013
We cant find an image of Woolley
Timm Woolley(AEG Live Accountant)
(The following proceedings were held in open court, outside the presence of the jurors:)
Ms. Bina. The issue, your honor, there's a number of corrections to Mr. Woolley's deposition
transcript. They're not substantive changes. What happened was it was just a court reporter who
had been in a car accident that morning and was very shaky in her typing. So the oral testimony
is actually perfectly clear. We could pause and read each one as it comes up, but I think it would
just be easier to read them at the end and say there were typos in the transcript, read them into
the record. Any issue with that, your honor?
Judge. No. That's fine.
Mr. Boyle. your honor, the practice was before -- I suggested this before. They insisted that the
transcripts that we did be stopped and read and it goes on, and now they want to change the rules
for their witnesses. We would prefer that we go by the same practice, stop and read when the
error comes up.
Judge. But if there's multiple corrections --
Ms. Bina. There's eight of them, your honor; and the stop-and-read practice was when the
witnesses had actually corrected their testimony. Here, the testimony is perfectly clear. I'll give
you an example. Mr. Woolley testifies in clear language that he attended the university of
Greenwich, London. The court reporter typed university of north Umbria. He's going to say, "I
attended the university of Greenwich in London." to then stop and say, "correct university of
north Umbria to university of Greenwich, London," is sort of time consuming and confusing
since the audible testimony is clear.

Judge. You can do it at the end, since you have multiple corrections.
Ms. Bina. All right. Thank you, your honor. I notice plaintiffs just filed a brief relating to
tomorrow's witness. We'd, obviously, like to oppose that. We think it's a wrong approach.
Judge. Okay.
Mr. Putnam. And this one is 45 minutes, your honor; so it should take us right to the time to
leave.
Ms. Bina. I think that's it.
Mr. Boyle. Your honor, just for the record, too, we agreed on some exhibits for Mr. Woolley, that
they can be admitted; but the bates stamp, which is from another case, will be redacted because it
will be confusing for the jury to see that.
Ms. Bina. That's correct. And we've redacted it on the audio when we submitted exhibits.
Judge. Okay. Thank you.
(the following proceedings were held in open court, in the presence of the jurors:)
Judge.. I understand there's going to be a playing of a deposition.
Ms. Bina. Yes, your honor. At this time, defense calls Timm Woolley by video deposition.
Judge. Okay. Thank you.
(excerpts of the videotaped deposition of Timm Woolley were played.)

Q. Mr. Woolley, could you please state your name for the record?
A. My name is Timm Woolley, T-i-m-m, W-o-o-l-l-e-y.
Q. I'm not going to do a "this is your life". I'm going to try to simply get your background. Mr.
Woolley, how would you describe what you do for a living?
A. I'm a financial consultant.
Q. And what educational background do you have to become a financial consultant?
A. I was a graduate in business studies with a specialization in financial control. I'm a member of
the Institute of Chartered Accountants in England in Wales in 1976. I was admitted to fellowship
in 1981.
Q. And where did you go to university?
A. University of Northumbria.
Q. And how long have you been a financial consultant?
A. At least 20 years.
Q. And I see from your -- or a CV that has been marked as Exhibit 1 to the deposition, youve
done a lot of work as business manager, tour manager for various bands; is that correct?
A. Predominantly tour accountant.
Q. Did you believe that it was unusual for Mr. Jackson to have a personal physician on the This
Is It tour?
A. Okay. It's his choice. Whether its usual or not usual, it isn't up to me to judge.
Q. Sir, didn't you put in an e-mail that it was an unusual circumstance?
A. I think at the time I was trying to get Mr. Murray off my back.
Q. So are you saying what you said in the e-mail was not true?
A. I may have exaggerated but it was an unusual prospect and that he would understand that it
may take time for his matters to be sorted.
Q. So you -- are you saying you were stalling him?
THE WITNESS: Putting him off.

BY MR. BOYLE:
Q. You were putting him off. You were putting him off on getting his contract completed?
A. No. Expressing that some time they had before it would be complete.
Q. And, sir how was it that you came to work on the This Is It tour?
A. I must have had the right qualifications.
Q. Let me ask a another, more specific question. Who contacted you and asked you to work on
the tour?
A. Paul Gongaware.
Q. And when did Mr. Gongaware contact you?
A. I'm going to take back what I said because you need more explanation. I had forgotten that
Prince had done some shows at the O2 in 2007 in which I acted in the capacity of a financial
consultant. And I met Mr. Gongaware because the Rolling Stones also happened to be at the O2
at exactly the same time. And he then told me that there was the potential for the This Is It tour --
not so named at the time -- to happen, and we discussed it briefly. Then in 2008, I prepared some
pitch materials for him.
Q. For the This Is It tour?
A. Yes. Again, it wasn't named that at the time.
Q. What was it named?
A. Nothing. It wasn't named anything.
Q. Okay. And so you -- the first contact regarding the 2007 -- I'm sorry, the This Is It tour was in
2007. Then in 2008, you prepared some pitch materials. And then at some other time, were you
asked to come on a more formal role?
A. Yes.
Q. And when was that?
A. Early 2009.
Q. And is that when Mr. Gongaware contacted you?

A. Yes.
Q. Okay. And did he do it by phone or e-mail?
A. I can't remember.
Q. Okay. And what did he ask you to do?
A. The simplest way to put it is that I was his deputy in matters of projections, payables, payroll,
and petty cash; in an accounting capacity, I should say, broadly.
Q. Were you asked to take on a title?
A. No.
Q. So you -- in certain aspects that you just listed, you acted as Mr. Gongaware's agent?
A. No.
Q. His deputy?
A. Deputed for him in matters financial, when delegated to me.
Q. Did you have any role in negotiating with a man named Dr. Conrad Murray?
A. I didn't do negotiations. That's a broad, general statement. From time to time, I might have a
hand in refining negotiations in order to have material to insert in a contract, but that's the extent
of it.
Q. What is your understanding of what your role for AEG was with respect to Dr. Conrad
Murray?
A. I gathered information from him and passed it to the people to prepare a contract and
agreement.
Q. So you were contacting him on behalf of AEG?
A. I contacted him once, that I can remember. I can't remember how many times after that, on
behalf of Michael Jackson, whose doctor he was.
Q. And what is the basis of your opinion on that?
BY MR. BOYLE:
Q. What is your basis of your belief that Conrad Murray was among Michael Jackson's personal
physician?

A. Because -- well, I wasn't present in any conversation between Michael Jackson and Paul
Gongaware. But Paul told me that Michael had told him to hire Conrad Murray, whom I later
understood was his primary care physician.
Q. So you had a conversation with Mr. Gongaware where Mr. Gongaware told you that Michael
told him to hire Conrad Murray?
A. Yes.
Q. What else did he tell you in that conversation?
A. Phone him.
Q. Did you discuss why it is that Michael Jackson needed a personal physician?
A. Not mine to ask.
Q. I noticed in a lot of the emails, you run a pretty tight ship, budget-wise, and you tend to shut
people down if you think an expense is not warranted. Were there any conversations like that
with Mr. Gongaware about Dr. Murray?
A. Not that I can remember in any detail.
Q. Do you know when it was when Mr. Gongaware asked you to -- or told you to call Dr.
Murray?
A. Early May.
Q. So Mr. Woolley, I'm going to hand you Exhibit 2.
Q. So is that an e-mail you wrote to Dr. Conrad Murray on May 8th, 2009?
A. As I say, I believe that, as I said, it looks like the general tone is that, but I don't know
precisely that it's word-for-word because I haven't got the original.
Q. Sir, the first line of the e-mail: It was a pleasure meeting you on the phone. Do you see that?
A. Yes.
Q. So -- and the e-mail's dated May 8th; correct?
A. Yes.
Q. 2009? And you testified earlier, earlier, you believe you called Dr. Murray in for the first
time in May of 2009?

A. Early May.
Q. Okay. So do you know how many days it was that you called him before you wrote the e-
mail?
A. I would have written it the same day.
Q. The same day, you think? Okay.
A. Yes.
Q. Sir, is one of the purposes of this e-mail to list things that you spoke to Dr. Murray about?
A. There are certain things that I told him and certain information that I had gathered from him.
Q. And were you gathering information for things that Dr. Murray might need so you could
convey that on to someone at AEG?
A. I don't know if there's anything that he told me he needed. I gathered information to pass to
the appropriate person at AEG.
Q. Well, let me point one line out in particular.
A. Yes, sir.
Q. Need -- it's right in the middle. Need for one venue-based, comma, one home-based, extra
corporeal, C-o-r-p-o-r-e-a-l, CPR units, capital C, capital P, capital R, units. Do you see that,
sir?
A. I do.
Q. Now, was that something you told Dr. Murray he would need or something that Dr. Murray
told you he would need?
A. Neither. We were talking about his needs and I generated that suggestion because he wasn't
forthcoming with any others. It was a "for instance".
Q. And so is it your testimony here today that you suggested to Dr. Murray that he might need
CPR units?
A. Yes.
THE WITNESS: Yes, I did.
BY MR. BOYLE:

Q. Yes. And you made this call to Dr. Murray on behalf of AEG; correct?
A. No. I think I said that I made the call on behalf of Michael Jackson who wanted to hire
Conrad Murray.
Q. Well, that's not -- well, were you working for Michael Jackson or for AEG?
A. I was working for the tour.
Q. And who was -- who was the producer of the tour?
A. I am employed -- self employed, but my payor was AEG.
Q. All right. And you took -- you took commands from Paul Gongaware; correct?
A. I did.
Q. And Paul Gongaware is post-CEO of AEG; correct?
A. I'm not sure of his title, but if you say he is, I'm prepared to believe you.
Q. Did you take orders from Michael Jackson?
A. Never.
Q. So you took orders from Paul Gongaware?
A. Correct.
Q. And you -- based on your order from Paul Gongaware, you called Dr. Murray?
A. I did.
Q. And you suggested to Dr. Murray that he's going to need CPR units for Mr. Jackson?
THE WITNESS: I enumerated that item as a potential item that he might want to have in
those two locations.
BY MR. BOYLE:
Q. And why did you think he might need a CPR unit?
A. There has been recent installations of CPR units. By the way, by which we mean, defibrillator
units. On aircraft, and recently in my own hometown, some had been installed in various
neighbors' houses for potential against people having heart attacks and there not being an

adequate provision for a jump start for their heart if they suffered one. So it was in the forefront
of my mind and it occurred to me to ask him, just to find out what sorts of things he'd need.
Q. And what -- your neighborhood, you -- your neighborhood here in Florida?
A. It's about 20 miles north.
Q. The Villages?
A. Yes.
Q. Is that a retirement community?
A. I'm not retired, but lots of people are.
Q. Generally a community of people in more advanced age. Is that a fair statement?
A. Some are, certainly.
Q. And so some of those people have CPR units in their house?
A. No. Some people who are trained in the application of those units have them in their houses
should an event fall on a neighbor.
Q. Did you have a reason to believe that Michael Jackson, specifically, might need a CPR unit?
A. No.
Q. Before we talked about having one in the venue. But why did you suggest a CPR unit for
Michael Jackson's home?
A. Because nobody wanted to be in the position of carrying it around.
Q. But did you have a reason to believe that Michael Jackson might suffer a heart attack?
THE WITNESS: No, none.
BY MR. BOYLE:
Q. Do you -- is it a common thing when you're being -- your job as a tour accountant that you
suggest to a physician -- a personal physician for an artist that he put a CPR unit in the artist's
home?
A. I was gathering information for use in my projection and budgets and I needed to know what
he wanted to spend on equipment. So I asked him what he wanted -- and I might have said

something to the effect of, what else do you need, do you need a CPR unit. And he said, well,
we might need more than one. And I don't know how the rest of the conversation went.
Q. Did you have any discussion with Dr. Murray about that he was going to be injecting
Michael Jackson with Propofol?
A. No.
Q. Did you have any discussion with Dr. Murray about whether he needed IV drip and needles?
A. None.
Q. Did you have any discussion with Dr. Murray about whether he needed a full-time nurse?
A. He told me that there might be occasion where he'd need an assistant. He did not describe a
nurse or doctor.
Q. Did you have an understanding that Dr. Murray was going to be acting as Mr. Jackson's full-
time physician?
A. No.
Q. You didn't have that understanding?
A. No.
Q. Did Dr. --
A. We didn't talk about his services.
MR. BOYLE: Here's another one. This will be 3.
Q. Have you had time to peruse that e-mail, sir?
A. Yes.
Q. And do you recognize this e-mail as one that you sent to Dr. Murray?
A. Again, it looks like something that I sent. And I don't know if it's, word-for-word, the same
as I sent.
Q. Sir, this appears to be an e-mail that was sent from Timm Woolley on May 14th, 2009. Do
you see that?
A. Yes, I do.

Q. And it looks to me like this e-mail says that you were -- you were basically following up with
Dr. Murray and asking him if he had looked at the last e-mail that you sent him.
A. Yes.
Q. Was what I said a fair characterization of this e-mail?
A. I tried to chivvy him up.
Q. And what do you mean by that?
A. Get him working on giving me responses to any question I proposed in the earlier e-mail.
Q. Very good. Okay. We can move on. This one will be 4.
THE WITNESS: Am I going to have to read that?
BY MR. BOYLE:
Q. Yeah. This one's a tough one. I'll represent to you, the bottom is the same one as -- is the
same text as on Exhibit 3, when you were chivvying him up. And I can read this to you. Can
you see it, sir? I can read it to you.
A. No, sir. I'm making this out.
Q. Okay. Have you had a chance to read that, sir?
A. I'm still working on the first paragraph. I'm having difficulty with the second sentence.
Could you help me out, for -- as for good faith --
Q. As for good -- and this is the one I was going to ask you about, so this is good.
A. Please.
Q. As for good faith with my client, I am sure that you are aware that my services are already
fully engaged with Mr. Jackson, period. I wish you and yours all the best, and I look forward to
a quick response so we can close this matter.
MR. PUTNAM: And just for the sake of the record, I believe it says I look forward for a quick
response so we can close this matter.
MR. BOYLE: I agree with that.
BY MR. BOYLE:
Q. And this e-mail appears to be dated May 15th, from Dr. Murray to you; correct?

THE WITNESS: I don't know and I can't read it.

BY MR. BOYLE:
Q. Do you recall getting this e-mail?
A. No.
Q. Do you know what Dr. Murray meant when he said, in the second line, I am sure that you are
aware that my services are already fully engaged with Mr. Jackson?
A. No, I don't know what he meant.
Q. Okay. So this next one, I think, is going to be a two-pager. This will be Exhibit 5.
Q. Okay. Sir, do you recognize the content of the messages in this e-mail?
A. I think it's something that I sent. Obviously, I don't know if it's word-for-word what I did.
Q. Assuming no one altered it, does it refresh your memory that you think you sent something
like this?
A. I do. It does.
Q. Okay. And did you read the message below yours that says, Dear Timm?
A. It appears to be the same as the previous e-mail that you gave to me that I was unable to
read.
Q. I think that's correct. And you were referring to --
A. The previous exhibit.
Q. Exhibit 4. Well, actually I don't think they're the same one. Yes, you're correct. Okay. Sir, are
you able to read it now in this one?
A. Oh, yes, I can see it.
Q. Okay. And then on page two of Exhibit 5, there's an e-mail that we've already discussed
which, Which was when you were chivvying up Dr. Murray?
A. Yes.
Q. Okay.

MR. PUTNAM: For the sake of the record, I think he means Exhibit 5.
MR. BOYLE: Thank you. What, that we're on right now? You're correct. Thank you.
BY MR. BOYLE:
Q. So here, sir, it appears that you wrote, Dear Conrad, sorry to be silent this week. Went on
urgent errand to Florida for two days, and has deranged my schedule, but I'm getting back on
track. I would like to send a contract to you in the next day or two, but I am looking for help in
the legal department because the forms within which I work don't apply to your specialized
position so it has to be custom-generated. This won't take long and I hope to get it to you before
close of business tomorrow.
Q. Did I read that largely correctly, sir?
A. I see I misspelled position.
Q. Okay. No harm -- no penalty for misspelling. But did my reading of that comport with your
reading of it?
A. It wasn't complete. It says that I'm copying Brigitte Segal, whose talent, as well as being the
tour manager, include being a licensed U.S. attorney.
Q. Okay.
A. Look forward to getting back to you, best regards.
Q. So were you really trying to get it to Dr. Murray before the close of business?
THE WITNESS: I would have liked to get to that timetable.
BY MR. BOYLE:
Q. Did you think that was a realistic possibility when you wrote this?
A. Well, let me say, I would have to speculate as to Brigitte Segal's workload at the time.
Q. But before you testified to the effect that you had said something to Dr. Murray that was
meant to sort of stall him, were you doing that again here?
A. I was attempting to be helpful.
Q. And did you have an awareness at this time that my -- that Dr. Murray was already under the
belief that he was treating Michael Jackson on behalf of AEG?
A. None.

Q. You were not aware of that?

A. No.
Q. Okay. Let's go to the next one.
COURT REPORTER: Six.
MR. BOYLE: This is going to be hard to read, but I think we can look at it with the next one.
You know what? Let me do this. Before we go to 6, I want to mark 7. And I won't remark it. Just
here's 7.
(Plaintiff's Exhibit 6 and Exhibit 7 were marked.)
Q. Okay. So let's look at Exhibit 7 first, sir.
A. Yes, sir.
Q. Are you able to read the text of that e-mail?
A. Just.
Q. Okay. And I'll read -- I'll read it and correct me if I'm wrong. Dear Timm, I gathered from
your last e-mail that my contract is taking a little more time to develop than the usual. In the
meanwhile, I have performed and continued to fulfill my services to the client in good faith.
Period. Therefore, I am asking you to deposit my fee for May in reciprocity of good faith on
your part as per our agreement. Period. Did I read that correct?
A. Yes, sir.
Q. Sir, do you recall having an agreement with Dr. Murray that you were going to pay him for
May?
A. I didn't have any agreement with Dr. Murray.
Q. Did AEG have an agreement with Dr. Murray?
A. Never.
Q. That they were going to pay him for May, never?
A. No, I don't remember that there was ever a completed agreement between AEG and Dr.
Murray.

Q. I know about the completed contract argument. My question is: Was there ever an
understanding that at some point in time, were the relationship come to fruition, Dr. Murray was
going to be paid for May?
THE WITNESS: I have no idea if AEG would have paid him for May.
BY MR. BOYLE:
Q. Do you recall seeing the final contract between AEG and Dr. Murray that you sent to him?
A. No, I didn't.
Q. Do you know if the final contract draft called for payment beginning May 1?
THE WITNESS: I never read it.
Q. No? So, basically -- so, when you got this e-mail from Dr. Murray, did you have an
understanding that Dr. Murray was under the idea that he was going to be paid for May?
THE WITNESS: I don't know. I would have responded to them and I don't know what my
response says.
BY MR. BOYLE:
Q. Okay. And would you have told them, hey, you're not going to be paid for May?
THE WITNESS: I would have told him he wasn't going to get paid unless there was an
agreement.
BY MR. BOYLE:
Q. All right. Let's move on to exhibit now six. Dear Timm, I would like to forward -- no. Let
me start above. This e-mail is dated May -- Friday, May 22nd, at 134750, 2009. The e-mail that
we just looked at, Exhibit 7, was dated Thursday, May 28th, 2009 at 11:51. And then the text of
Exhibit 6 says: Dear Timm, I would like to forward, fax, or deliver to you as soon as possible a
copy of the voided check so that you may have the routing and account number for my bank in
order for you to successfully transfer the monthly fee of $150,000 -- 150K, it says. Period.
Preemptively, I am also including the name of the bank, the account and routing number as
well as the name on the account. Please see the following. And then there's bank information I
won't read. With kind regards, Conrad. Sir, do you recall getting this e-mail from Dr. Murray?
A. No, not specifically.
Q. You don't recall getting this e-mail?
A. Not specifically.

Q. Okay. Based on your listening to my reading of it, do you have an understanding what Dr.
Murray was asking here?
A. Yes. I don't know what I replied, though.
BY MR. BOYLE:
Q. What was your understanding, based on what I read, that this e-mail says that Dr. Murray
was asking you?
THE WITNESS: He's dunning for money.
BY MR. BOYLE:
Q. And he's giving you his bank account information; right?
A. Yes.
Q. And he wants you --
A. I don't know if that's accurate, but let's assume that it is.
Q. Okay. And he's giving you that because he wants you to wire him some money; right?
A. I don't know if he says that or if he wants a check. He looks like he's wire -- wants it wired.
Do you have my response to him?
Q. Yes. Right here. Of course. And Mr. Woolley -- am I pronouncing your last name correctly?
A. Yes.
Q. Mr. Woolley, had you asked Dr. Murray for his bank account information?
A. I can't remember.
Q. Isn't that something you normally ask vendors on tours?
THE WITNESS: It depends on what mode of payment is requested in the contract or
agreement. If it requires wire, I'd have asked for it. If it requires check, I wouldn't.
BY MR. BOYLE:
Q. Okay. So you don't remember in this particular instance?
A. I don't know why he's giving it to me, and I don't know if I asked for it.

Q. Sir, in all of your experience working on tours, how many times have you been in a position
where you were talking with, by either phone or e-mail, a potential personal physician for an
artist?
A. Potential? Never.
Q. So this is the first time?
A. Actual, yes. Potential, never.
Q. Okay. Okay. So these communications with Dr. Murray, right, you contacted him because
Paul Gongaware told you to; right?
A. Yes.
Q. And you were in the process of being involved at some level in getting to an agreement
between AEG and Dr. Murray?
THE WITNESS: No.
BY MR. BOYLE:
Q. No, you were not?
A. No. Getting to an agreement implies that I was negotiating. I wasn't. I gathered information.
I passed it on. And thereafter, I was absent from that process.
Q. Okay. In your information-gathering capacity that you just testified about, right, you were
gathering information that could then be used, be placed in a contract between AEG and Dr.
Murray; correct?
Q. Okay. Exhibit 6. Now, let's look at Exhibit 8. And this is a two-pager.
THE WITNESS: Yes, sir.
BY MR. BOYLE:
Q. Sir, do you recall writing an e-mail on May 28th that says, Dear Conrad, the legal
department has not yet completed the agreement, which is rather specialized since it is a rare
event that a physician is engaged to accompany a touring artist? Period. And I'll stop there. Do
you recall writing that?
A. I remember that you made reference to it earlier on. And I think I remember maybe having
written it.

Q. Okay. And so now, when you wrote here, It is a rare event that a physician is engaged to
accompany a touring artist, were you telling the truth?
A. Yes. As far as I know, I was telling the truth, as my experience dictated. There may be
instances of physicians going on tours with an artist of which I'm not aware.
Q. Because before when I brought it up, you said you were just saying that to chivvy the doctor.
A. No, I didn't. I said that I was putting him off.
Q. Okay.
A. And indeed, that was the intention.
Q. Okay. But you were putting him off, but you were also telling him the truth, that based on
your experience it was a rare event that a physician is engaged to accompany a touring artist?
A. I could count on the fingers of less than one hand, fewer than the fingers of one hand, the
numbers of times that I've experienced it.
Q. So it's a rare event, in your experience?
A. In my experience.
Q. And given that it was a rare event, did you ask anybody like Mr. Gongaware, for example,
why are we doing this?
A. Nope.
Q. You were just following orders?
A. Did I not say earlier that it was Mr. Jackson's request to have him there? Why would I
question that?
Q. Well, that's -- I appreciate you offering information, but that wasn't my question. Were you
following Mr. Jackson's orders?
A. No.
Q. Because you answered to Mr. Gongaware; correct?
A. Correct.
Q. And Mr. Gongaware told you to contact Dr. Murray; correct?
A. He did.

Q. And he told you to take part in this process that ultimately was going to lead to a draft
contract between AEG and Dr. Murray; correct?
THE WITNESS: To the extent of my ability. And my abilities were short.
BY MR. BOYLE:
Q. You don't think Mr. Gongaware was telling you to call Dr. Murray for no reason, do you?
THE WITNESS: He asked me to get information for Dr. Murray that would be useful in the
contract.
BY MR. BOYLE:
Q. Thank you. And now that we've gotten that out of the way, you didn't say to Mr. Gongaware
anything like, why are we getting Michael Jackson a personal physician?
A. No.
Q. Okay. And sir, below this e-mail, below your e-mail to Mr. Murray, there is, I think, a reprint
of the prior exhibit.
MR. PUTNAM: Title?
BY MR. BOYLE:
Q. You're right.
A. reprint of Exhibit 7 where Dr. Murray wrote, It's taking longer. And he specifically wrote, In
the meanwhile, I have performed and continued to fulfill my services to the client in good faith.
Do you -- do you see that?
A. Yes, I do.
Q. Now, when you responded to that e-mail on May 28th, did you say anything to Dr. Murray to
the effect that, what are you talking about, you're not supposed to be performing services yet?
THE WITNESS: Not my place to ask.
BY MR. BOYLE:
Q. Okay. Did you -- did you inform Dr. Murray that he was not supposed to be performing
services yet?
A. I think I said earlier on that I understood he was his primary care physician.

Q. Where did you get the understanding that Dr. -- that Dr. Murray was Michael Jackson's
personal physician?
A. Because Mr. Jackson asked for him to be hired on the tour.
Q. And that was told to you by?
A. Mr. Gongaware told me that Mr. Jackson asked for him to be hired on the tour. And my
supposition was that he must have been engaged prior to the request. He came from Vegas. And
I believe Mr. Jackson was living in Vegas for a period of time.
Q. And then here, sir, back to your e-mail, is something that you've alluded to before today. You
state, In any other circumstance, I would agree that payment should be made as close as
practicable to the due date, but AEG policies dictate that payments can only be made under a
fully executed agreement. Do you see that?
A. Yes.
Q. And is that where -- where did you get the understanding -- strike that. Were you telling Dr.
Murray the truth in that line?
A. Yes.
Q. Where did you get the understanding that AEG policies dictate the payments can only be
made under a fully executed agreement?
A. Practice.
Q. Do you know if it's written down in a manual somewhere?
A. I've never seen it written.
Q. Do you know if AEG has a policies and procedures manual?
A. I'm absolutely certain that they do, but I wouldnt have known where to find it in it.
Q. Because you've never seen it?
A. Exactly.
Q. Okay. So, where did you get the -- practice is where you got the understanding -- strike that.
A. But experience. Call it that.
Q. Experience with AEG?

A. Yes.
Q. Which at that -- at this time would have been the Prince tour?
A. Yes.
Q. And has it been your experience with your work with AEG that they never pay anybody until
a fully executed contract has been made?
A. I can't remember any exception. I'm sure there must be one.
Q. All right. Sir, do you -- do you recall ever sending Dr. Murray -- forwarding to Dr. Murray an
e-mail that has an attachment, the first contract draft between AEG and Dr. Murray?
THE WITNESS: I don't know if I sent him the first draft. I sent him what I was sent by Kathy
Jorrie.
BY MR. BOYLE:
Q. Okay. So you recall, at some time, Kathy Jorrie sent you a draft of an agreement and you
forwarded it to Dr. Murray?
A. I don't know if it was a draft or an agreement because I never read it. But I forwarded what
she sent me.
Q. And do you know when that was?
A. No.
Q. Okay. Mr. Woolley, as you know, weve been going through a series of documents that
purport to be e-mails between you and Conrad Murray. I'm going to -- I'm going to now -- I have
only one copy of this, so I've showed it to defense counsel and I apologize and I'm going to
have that one marked as the next in line, which I think is --
COURT REPORTER: Nine.
MR. BOYLE: Nine. Thank you.
(Plaintiff's Exhibit 9 was marked.)
BY MR. BOYLE:
Q. There you go, Mr. Woolley. I'll let you take a look at that.
A. Thank you. Yes.

Q. And do you recall that e-mail or the content of that e-mail?

A. I don't remember writing it. It appears to be something I've written.
Q. What about the e-mail below from Ms. Jorrie to you?
A. I don't remember this specifically, but I do remember that everything she sent me that she
asked me to forward to Dr. Murray, I did.
Q. And what was your understanding about that e-mail that Ms. Jorrie sent to you was asking
you to do?
A. If I approved the attached, please submit a copy to Dr. Murray.
Q. And what was the attached?
THE WITNESS: There's a notation that says Murray agreement, 6/15.
BY MR. BOYLE:
Q. So is it your understanding that that was the Murray/AEG draft agreement dated 6/15?
A. I don't know. I didn't read it.
Q. Didn't Ms. Jorrie ask you to read it?
A. She said, Please review and comment. I know better, I think, than to try and gain say with
Ms. Jorrie.
Q. So in other words, you did not review and comment?
A. I did not.
Q. You just forwarded it on to Dr. Murray?
A. She asked me to.
Q. And what did you say to Dr. Murray in your e-mail?
A. Would you like me to read it?
Q. Sure.
A. Okay. I am sorry for the long delay in getting this to you, but I hope that with input and
comments we can dispose of the agreement quickly and arrange for payment of the May and

June fee installments. I hope that the accommodation options are producing some to your
liking, with kind regards.
Q. And sir, you see here, you wrote, We can dispose of the agreement quickly and arrange for a
payment of the May and June fee installments.
A. Yes.
Q. Does that refresh your recollection as to whether there was an agreement between AEG and
Murray that at some point they would pay him for his services in May and June?
A. There wouldn't have been any payment if there was no agreement.
Q. Okay. But if there were to be an agreement, was it your understanding that there would have
been payment for May and June?
A. I'm sorry, I can't speculate as to whether an agreement came into being because it is my
understanding there was none.
Q. And where did you get that understanding?
A. Because it never existed.
BY MR. BOYLE:
Q. Okay, Mr. Woolley. I want to hand you -- I'll hand you a document. I do not know if this has
been produced in another format to us, and I'll explain why. And this is a -- at the top of this is a
Friday, June 19th, 2009 -- I'm sorry, 2000, yes, 9 e-mail from Tim Woolley to Conrad Murray
and Paul Gongaware at his Mac address. Mark that as Exhibit 29.
Q. I ask that you take a look at that e-mail.
A. I read it, but it's missing a reference to a previous e-mail.
Q. What do you mean?
A. Well, Deniz Dervish here is talking about, could you please advise the situation regarding
obtaining previous medical records, and when these may be available. So there's no reference to
the e-mail that Deniz Dervish sent previously to, probably among others, Paul, the first of the
medical records she's trying to find, that related, I believe, to Dr. Murray's care of Mr. Jackson
from 2006 to 2009.
Q. Well, I will -- I actually think this was an original e-mail because it's not a re or a forward,
so...

A. No. It references Deniz previously having asked or perhaps Paul originally having asked, I
don't know, who, of some medical records of Dr. Murray and we're being asked to reiterate that
request because he was in possession from 2006 to 2009. And maybe earlier, I don't know.
Q. How do you know he was in possession of medical records from 2006 to nine?
A. I'm remembering that that information came to light after the tragic death.
Q. And do you know if those records were ever given to --
A. Haven't the faintest.
Q. Now, it looks to me that on June 19th, you forwarded this e-mail to Conrad Murray. Do you
see that?
A. Yes.
Q. And why was it that you were taking a role in attempting to get medical records from Dr.
Murray for purposes of securing insurance?
A. The second medical was due and the insurance people would have -- the underwriters would
have asked for both the outcome of that medical and for the previous medical records. Dr.
Murray was seemingly the only person that had them.
Q. And but did someone at AEG ask you to follow up on that and --
A. I can't remember who.
Q. Who do you think it would have been?
THE WITNESS: It might not have been.
BY MR. BOYLE:
Q. Would you have taken it upon yourself to follow up with Dr. Murray about getting medical
records?
THE WITNESS: I don't remember who asked me. It could have been Bob Taylor as much as
it could have been somebody within AEG.
Q. Do you recall ever being copied on any e-mails regarding those doctors' exams that were
scheduled for July 6th?
A. I might have been, but I had no action to take in respect to it.

Q. So specifically with regard to CPR equipment that we've talked about earlier, did you contact
any providers of CPR equipment to try to price out CPR equipment?
A. We wouldn't have done that until the UK.
Q. But, so the answer's no?
A. No.
Q. Did you have -- in your discussion with Dr. Murray, did you discuss how Dr. Murray was
going to obtain any medication?
A. No.
Q. Did you discuss in any way the type of treatment Dr. Murray had intended on providing to
Mr. Jackson?
A. Never.
Q. Had you ever -- have you heard from any source, other than lawyers, that one of Dr. Murray's
roles was to make sure Michael Jackson made it to rehearsals?
A. No.
Q. Okay. All right. Okay. Here's another one of these. Produced in another case, 1326, the e-
mail from Timm Woolley to Conrad Murray dated June 23rd, 2009.
BY MR. BOYLE:
Q. And what is that e-mail about?
A. Two things. It records that his experience with Kathy Jorrie should be coming to a close.
Q. And how did you know that?
A. I didn't. Now, I don't know how I knew that, other than I forwarded multiple copies and
multiple drafts of agreements to Murray from Kathy. And then contingent upon his having an
agreement, we would have offered him travel sickness, and accident for his family, and placed
that, assuming that he was going to end up on the tour, and assuming his family came out to
join him.
Q. So you were in the process of gathering information from Dr. Murray to get travel insurance
for him?
A. I would get that information. I wouldn't bind it until it would be certain he was on the tour.

Q. Mr. Woolley, did you ever see the agreement, the AEG/Conrad Murray agreement as signed
by Dr. Murray?
A. I never saw any of them.
Q. You never saw any of the drafts?
A. No.
Q. You just forwarded them along?
A. Exactly.
Q. Okay. Did you -- other than the initial conversation that you had with Dr. Murray about
items that may be needed, did you have any follow-up conversations with Dr. Murray about
changes that may need to be made to the agreement?
A. No.
Q. And your understanding, that was all done between Dr. Murray and Kathy Jorrie?
THE WITNESS: If not between those two, then him and Brigitte, if Brigitte was involved.
BY MR. BOYLE:
Q. And who was Brigitte? Brigitte Segal; correct?
A. Yes. Segal, S-e-g-a-l. Michael Jackson's personal tour manager.
Q. And was she part of the payroll of AEG?
A. Yes.
Q. Sir, were you ever instructed by anyone from any AEG entity to conduct a background check
on Dr. Murray?
A. No.
Q. Do you know if a background check was conducted on Dr. Murray by AEG?
A. I wouldn't know.
Q. Who would know that, if you know?
A. I don't know. The person who instigated it or carried it out would know.

Q. Do you know if one happened?

A. No.
Q. Given a date, June 24th, and that you would -- on June 23rd, I believe, sent an e-mail to Dr.
Murray saying I believe your time with Kathy Jorrie has gone well. Do you recall that?
A. I do remember the text of that, but I don't remember the date.
Q. Okay. Given that timing, did you, at this time, have a belief that the AEG/Murray agreement
was essentially complete?
A. No.
Q. No? Yet, you still put it in the budget?
A. As I would have done a lot of things that related to that and similar items.
Q. And you did not mark that it was a contingent item?
A. Well, no.
Q. And did the budgets show that the payment would have to go back to begin in May?
A. Well, this is a cumulative budget. It's expenses that were being incurred throughout the
whole run. So it would have been every month times 150,000, but -- whether or not it was
actually going to be incurred or not.
Q. Were you told by Mr. Gongaware at some point that the amount for Murray was going to be
150,000 a month?
A. That's when he asked me to phone Murray.
Q. And so at that point in time, he knew the number, presumably?
A. He must have done.
Q. Because he told you? Okay. And that was approximately early May?
A. Early May.
Q. Okay. But he -- but Mr. Gongaware did not tell you about any of his communications with
Murray; is that true?
A. None.

Q. Okay. We touched on this before and I can't remember how far we went, but there was --
when you spoke to Dr. Murray first, somebody mentioned a need for a nurse or a medical
assistant?
A. No. He talked about a locum to stand in for him from time to time when he needed rest.
Q. Okay.
A. He didn't mention a nurse, unless it was to Kathy Jorrie.
Q. Okay. And you used the word locum.
A. British medical speak for a man that stands in place of the general practitioner.
Q. Got it. And to your recollection, was it Dr. Murray who mentioned that or did you suggest
that?
A. No, I did not. He did.
END
Ms. Bina. Your honor, this concludes Mr. Woolley's testimony. As I noted before, there were
some corrections to the deposition transcript. Not corrections that Mr. Woolley made to his
deposition, but errors in the court reporter's transcription. I'd like to read those into the record
now that Mr. Woolley had highlighted --
Mr. Boyle. for the record, these are changes that Mr. Woolley made?
Ms. Bina. Yes, these are changes that Mr. Woolley made. On page 6, line 22, "university of
north Umbria" was changed to, "university of Greenwich, London." on page 13, line 6, "an
unusual prospect" was changed to "and unusual project." on page 13, line 16, "some time they
had" was changed to "some time would be needed." on page 29, line 3, "post CEO." was
changed to "co-CEO." on page 29, line 24, "there has been" without a capital t -- with a capital t
has been changed to "there has been" with a lower case t. On page 41, line 13, "like to get to"
was changed to "like to stick to." on page 46, line 24, "responded to them" was changed to
"responded to him." and on page 66, line 18, "gainsay with Ms. Jorrie" was changed to "gainsay
Ms. Jorrie." that's it.
Judge. Thank you.

Mr. Boyle. your honor, there are, I believe, exhibits that are going to need to be admitted that
were referenced. I'm happy to do that outside the presence of the jury so they don't need to listen
to that being read in.
Judge. Okay. We can do that right after. Tomorrow, I believe I can probably start at 9:30, but I'm
going to have a discussion with the lawyers at 9:30, so I'm going to ask you to come at 9:45.
Okay? So 9:45 tomorrow, but they'll be here at 9:30. Thank you. Have a good evening.
(the following proceedings were held in open court, outside the presence of the jurors:)
Ms. Bina. Just to close out the record on this, your honor, I'll quickly read these exhibits into the
record.
Judge. Okay. You've already agreed to them?
Ms. Bina. Yes. Exhibit 2 to Mr. Woolley's deposition is trial exhibit 686.0002.
Mr. Boyle. we have it as a dash.
Ms. Bina. Dash, 02. 686, dash, 2. You're absolutely right. Exhibit 3 to Mr. Woolley's deposition
is trial exhibit 686, dash, 3. Exhibit 4 to Mr. Woolley's deposition is exhibit 686, dash, 4. Exhibit
5 to Mr. Woolley's deposition is 686, dash, 5. Exhibit -- yeah, there are multiple pages. It goes
through dash, 6. You're absolutely right. Thank you, Mr. Boyle. Exhibit 6 to Mr. Woolley's
deposition is trial exhibit 686, dash, 7. Exhibit 7 to Mr. Woolley's deposition is trial exhibit 686,
dash, 8. Exhibit 8 to Woolleys deposition is trial exhibit 686, dash, 9 through 10. Exhibit 9 to
Mr. Woolley's deposition is trial exhibit 686, dash, 11 through 12. Exhibit 29 to Mr. Woolley's
deposition is trial exhibit 686, dash, 46 through 47; and exhibit 34 to Mr. Woolley's deposition is
trial exhibit 686, dash, 55. I'm happy to provide Mr. Boyle with any of these if he wants them.
Mr. Boyle. agreed.

Judge. Thank you. Is there anything else we can do? Anything you want me to prioritize in terms
of getting to -- it was nice not to have to do Woolleys over the weekend.
Ms. Bina. We were able to work it out.
Judge. But I realize there's other things.
Ms. Bina. Mr. Marcus's would still be the priority, your honor; and, obviously, we'll be filing an
opposition to the brief they just filed regarding Ms. Jorrie.
Judge. And is she the next witness?
Ms. Bina. She's testifying tomorrow, your honor. We just were served with this at 3:15, so --
Mr. Panish. Well, we were just told on Sunday.
Ms. Bina. The 48 hours.
Mr. Panish. We couldn't really file anything on Sunday. Ms. Jorrie, the attorney -- and there's
many issues, I believe, regarding privilege and waiver of privilege and et cetera.
Ms. Bina. And just for the record --
Mr. Panish. And expert testimony they're going to try to get out of her.
Ms. Bina. Your honor, we have no intention of offering expert testimony with Ms. Jorrie; so I
don't think that will be an issue. We're actually planning a fairly narrow examination of her. I
think the privilege issues, plaintiffs are wrong, there's been no waiver and there will be no
waiver. Our brief will lay that out.
Mr. Panish. It's absolutely a waiver.

Judge. What I hope you'll do is lay out what it is she's going to say so I can evaluate what the
narrow testimony will be.
Ms. Bina. Yes, it will be quite narrow, your honor.
Mr. Panish. Some of the e-mails have blacked out specific -- you know. They're going to try to
say there's no -- we'll talk about it in the morning.
Judge. I read -- I'm on my way to reading the brief, I understand there's blacked out --
Mr. Panish. Just because their exam is short doesn't mean there's not a waiver.
Judge. I'm not suggesting that. I want them to tell me what it is she's going to say so that I can
evaluate.
Ms. Bina. As I'm sure your honor is aware, just because someone is testifying about
communications they made to a third party, that doesn't waive communications they had with
their client. But we'll put all that in writing tomorrow, as well as an idea of what she'll be
testifying to.
Mr. Panish. Fine.
Judge. So Marcus, and then Jorrie tomorrow morning.
Ms. Bina. Yes, your honor.
Judge. And then what are the designations you filed?
Ms. Bina. We submitted a couple.

Ms. Cahan. I believe you have designations for dr. Adams, dr. Gordon and dr. Slavit as of now.
Slavit's was one of the two that we filed today. That was probably the highest priority one at this
point. And, your honor, there was also a brief submitted today by plaintiffs who are seeking to
exclude the designated 18 minutes of dr. Shimelman's testimony. They want to exclude it as
cumulative, although it's one of plaintiffs' experts; and we'll be opposing that.
Mr. Panish. It's the same thing as us trying to play Ms. --
Mr. Boyle. Roma Young.
Mr. Panish. -- this cumulative issue. But we can deal with that when they file the motion.
Judge. Okay. I just want to know what I have.
Mr. Panish. Thank you, your honor.
Ms. Cahan. Your honor, as well, there was a brief submitted today on the presentation of
medical evidence at trial that should hopefully -- it's intended to streamline the hearsay issues
that we've dealt with with medical witnesses to date, and will be addressing going forward, so
your honor might --
Judge. I don't know why we have to address that. I mean, is there a reason why I needed a brief
on that?
Mr. Boyle. I haven't seen this brief yet.
Ms. Cahan. Your honor had asked us to explain why the situation with Dr. Finkelstein and Dr.
Forecast was distinguishable from the situation of contemporaneous treating physicians on a
going-forward basis, so we put that in a brief for your honor. And it also addresses the separate
issue of the admissibility of medical records because although we had a stipulation to that, we're
having some trouble with plaintiffs.
Mr. Putnam. We understood you wanted them, your honor, so we put it on paper.

Mr. Panish. We'll respond. There hasn't been any issue on the depositions, it was whatever
record they referred to could be admitted into evidence. So -- but we'll look at it.
Judge. But medical records in general --
Mr. Panish. We just can't put in all medical records. There has to be some relevance.
Judge. What I said was there wouldn't be any need to call custodians; but if there was some
relevance or something like that, if there's that type of objection, then, you know --
Mr. Panish. We're not --
Mr. Boyle. that's where we are.
Mr. Panish. We're not complaining about the custodian. There hasn't been any record that we
see an issue with yet on foundation. There are other legal objections, potentially; but we haven't
said they have to call in a custodian. We worked that out weeks ago.
Judge. Okay. We did talk about that, anything with relevance would be preserved, but that
having to call custodians is not going to happen.
Mr. Panish. Right.
Mr. Boyle. I think the issue, without reading their brief -- for some of the witnesses, they'll have
marked in the deposition a stack -- literally a 3-inch stack of medical records, but then refer to
five or six pages. We're fine with the five to six pages, but that doesn't mean the other 3 inches
should be admitted into evidence.
Ms. Bina. The issue is there are many medical records that were not discussed specifically at
deposition that have been relied on by experts and are relevant to the overall view of Mr.
Jackson's health; and plaintiffs didn't make specific objections, but seemed to say only the ones
that were referred to should be admitted. That's the issue outlined in the brief, in part.

Mr. Panish. Just because an expert relied on something doesn't make it admissible. We had that
issue today. You allowed, over my objection, them to get in specific hearsay of what their experts
testified to, which I objected to you overruling. But 721 allows cross-examination of it, but it
doesn't allow an expert to get in hearsay that they're trying to rely on. And you said, "are they
calling him?" and they represented they're calling Earley and Levounis live, and with that
representation, you said they could get it in, assuming that it was coming in with those experts.
Ms. Bina. Again, your honor, I think the issue is how the objection should be made. Plaintiffs'
counsel is not necessarily making any objections to the testimony, so it's a bit confusing, and
that's something that's in the brief.
Mr. Putnam. That's in the brief, your honor.
Mr. Panish. I don't know what they're talking about. We'll see you tomorrow.
Judge. Thank you.
Ms. Bina. Thank you, your honor.
Mr. Boyle. thank you, your honor. Have a nice night.
(proceedings adjourned to Tuesday, august 6, 2013, at 9:30 a.m.)