Order for Release of Redacted Docs – Declaration of Brian Oxman (11-24-04) Excerpts: 4. In direct violation of this Court’s July 9 2004 order __________________ have informed the prosecution of the existence of a subpoena. Their disregard for this Court’s orders after being served with a copy of the July 9 2004 Order, demonstrates an overriding bias that is the product of their vested financial interest in this case that is so strong that it compels them to violate court orders. These individuals have no excuse for their inexcusable flaunting of the July 9 2004 Order. (pg 3) ———————————————————– 6. Plaintiff produced a medical report dated August 12 2004, from ____________ claiming the complaining mother was physically incapacitated and unable to attend court. (Exhibit “A”). Plaintiff then asks this Court to block Mr. Jackson’s subpoena that seeks to verify the medical representations that the prosecution and the complaining witness made to this Court. There was no limitation on the August 12 2004, _____________, and not only did plaintiff open the door to permit Mr. Jackson’s inquiry into the medical representations made in that letter, but also under Evidence Code section 998, there is no physician-patient privilege in criminal proceedings. Evidence Code section 998. (pg 4) —————————————————– 14. Laboratory tests for the complaining witnesses are critical in this case because the prosecution has claimed that Mr. Jackson was part of a vast conspiracy to dump a urine sample jar so that alcohol would not be detected in the older son’s urine. {Redacted information}. There was sufficient urine to test on the occasion in question, and the laboratory reports will demonstrate that fact. 15. The defense believes additional and other urine samples from both the mother and her children will demonstrate _________ is the complaining witnesses who has raised these issues and opened the door to the examination of their medical records. Mr. Jackson is entitled to subpoena those records 17. Mr Jackson’s subpoena seeks the complaining mother’s most recent medical treatments at UCLA and seeks gynecological records only to the extent they reflect her treatment, prescription of drugs, and her use or non-use of drugs. The subpoena seeks all of her medical records, and the mother’s gynecological records are relevant to this proceeding because the mother became pregnant at the same time she has given testimony in this case. Her medical records contain a history of the use of {Redacted Information} drugs, and {Redacted Information}. The records are relevant because they disclose other medical information dealing with the truth of her claims and not for the sake of the gynecological portion of the records. 18. {4 lines of redacted information}. The complaining mother’s gynecological records will demonstrate the fact she failed to take her medication. 20. {3 lines of redacted information}. The medical bills from heath care provides (sic) will demonstrate the mother defrauded Michael Jackson. (5-7) ————————————————————— 23. While the prosecution claims her medical records are irrelevant to this proceeding, the mother is the one who claims physical injuries to her and her children because of Michael Jackson. It is improper for anyone to offer a doctor’s report to a court of law {redacted info} and then to attempt to hide the medical records. Mr. Jackson has a right to determine the veracity of not only the complaining mother, but also the physicians involved, and the court should compel production of the medical reports 24. Mr. Jackson seeks records of the complaining witnesses American Express credit card. {5 lines of redacted info} 25. Attached as Exhibit “C” and “D” are copies of two (2) checks from the County of Los Angeles made out to _______________. The first check (Exhibit “C”) is dated January 2 2003, in the amount of $769.00, and was cashed ________________ on January 2 2003, the same day the check was issued. {redacted info} 26. {5 lines of redacted info}. That American Express card is also the means by which the funds collected by Fritz Coleman and others are expended. 27. But the second check (Exhibit “D”) is ___________________ a check dated February 19 2003, in the amount of $769.00 from the County of Los Angeles ______________. It was ____________ cashed through _______________ bank account on February 24 2003, right in the middle of the alleged child abduction, false imprisonment, and extortion. {3 lines of redacted info} (pg 8-9) :nav Declaration of Brian Oxman in Opposition to Modify Teal Order

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