Motion in Limine to Exclude Reference to Books, Magazines, Photographs (pg 2-3) Mr Jackson’s Motion is based on the following grounds: … (2) The introduction of evidence of photographs or physical depictions seized from outside of Neverland Ranch has no connection to any issue in this proceeding and are irrelevant; … (4) The introduction of evidence of books, magazines, photographs, and computer images belonging to third parties lack probative value and any probative value is outweighed by their prejudicial effect because they have no connection to Michael Jackson or any nexus to this case (pg 3) B. Items showing ______________ in the Private Quarters of Michael Jackson’s Business Associates have No Connection to any Issue of this Case. Plaintiff has executed more than 110 search warrants and dozens of subpoenas directed to numerous Michael Jackson business associates (hereafter “outside” seized materials). The police seized numerous items, papers, computers, and files from the homes and businesses of these individuals, including books, magazines, and images ___________________. All of these seizures had nothing to do with Michael Jackson, and the fact that business associates has _______________, yet perfectly legal materials, in their possession is not a basis of make any claims or inferences regarding the character of these individuals, nor any of these issues involved in this case. When the police searched Neverland Ranch on November 18 2003, they seized numerous books, magazines, photographs, and computer images which also showed _____________ (hereafter “inside” seized materials). However, these items also had no connection to Michael Jackson, and plaintiff will not be able to establish any foundation for their presentation in evidence in this case. These photographs and images do not depict any crime, let alone the alleged crime in this case, nor do they establish the participation of any person in any of the acts alleged to be part of this proceeding. (pg 3) The materials from both “inside” and “outside” Neverland Ranch are ________ with no probative value, and there is no legitimate purpose for their introduction into evidence. Plaintiff cannot establish that Mr. Jackson had any connection to any of the “outside” materials, and he had little relevant connection to the “inside” items. None of the physical depictions show Michael Jackson, nor have any nexus to the crimes alleged in this proceeding. And suggested connection between the photographs, magazines, books, and computer images and the crimes alleged in this case is speculation lacking foundation. (pg 4) Mr. Jackson moves in limine that the “outside” books, magazines, photographs, and computer generated images _____________ seized at the homes and living quarters of business associates be excluded from evidence because they are irrelevant and lack foundation. As to “inside” items seized on Neverland Ranch premises, no foundation can be laid establishing a nexus between them and Michael Jackson, let alone the crimes alleged to have occurred in this case, and the court should hold a preliminary fact hearing regarding them before plaintiff is permitted to make reference to them. (pg 4) This motion will primarily address items seized “outside” of Neverland Ranch because the individuals whose homes were raided are Mr. Jackson’s business contacts whose private books and magazines have no relevance to this case. What they do in the privacy of their homes or living quarters is their individual responsibility. Plaintiff has not and cannot establish a nexus between these seized items showing ___________________ and Michael Jackson, and all of these books, magazines, photographs, and computer images are irrelevant to any issue in this case. (pg 5) The preliminary facts necessary to the admissibility of the photographs and physical depictions of ______________ found at locations “outside” of Neverland Ranch do not exist, and these items have no connection to the alleged crimes or issues of this case. Plaintiff cannot present any evidence that the computer depictions or photographs were part of any conspiracy, used in any crime, or have any connection to any of the complaining witnesses. They are not relevant to any issue before the court and have no probative value. (pg 7) There is no showing that Michael Jackson knew of any of these items, nor can there be any such showing because the undeniable fact is he had never seen these things. More important, Mr. Jackson’s knowledge of the existence of these items is not an issue in this proceeding. These items are not connected to this case and should be excluded from evidence. (pg 8) There is no relevant purpose for which these books, magazines, photographs, and physical depictions of ___________ can or should be offered in this case. The fact that people with whom Michael Jackson does business have these items in their possession, at their homes, has no probative value in this proceeding, and any probative value is far outweighed by the prejudicial and __________ impact they would have on the jury. The court should [exclude] them as remote, irrelevant, and unduly prejudicial. :nav Motion in Limine to Exclude Reference to Books, Magazines, Photographs

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