Cross of Ralph Chacon begins on p 5202 (A) Cross of Adrian McManus begins on p 5355 (B) (sidenote: McManus cross-examination continued into April 8 2005) Excepts: [b]Ralph Chacon[/b]

5202 14 Q. You sued Mr. Jackson and you wanted $16 15 million, right? 16 A. Well, I don’t know about the 16 million. 17 Q. You wanted millions, true? 18 A. No, sir. 19 Q. Really? 20 A. Well, I don’t know, sir. Whatever our 21 attorney was — he’s the one who was speaking for 22 us. 23 Q. Okay. We’ll get into that. 24 You sued Mr. Jackson claiming you were 25 wrongfully terminated, right? 26 A. That’s correct, sir. 27 Q. He sued you claiming you had stolen property 28 from him, true? 5203 1 A. That’s correct, sir. 2 Q. The jury found you were not wrongfully 3 terminated by Mr. Jackson, correct? 4 A. But we were, sir. 5 Q. Answer my question, please. Did the Santa 6 Maria jury find you were not wrongfully terminated 7 by Mr. Jackson? 8 A. Yes, sir. 9 Q. And they also found you had stolen property 10 from Mr. Jackson, correct? 11 A. But I didn’t, sir. 12 Q. Did the Santa Maria jury find you had stolen 13 property from Mr. Jackson? 14 A. Yes, sir. 15 Q. A judgment was entered against you, Mr. 16 Chacon, for $25,000, the value of what you had 17 stolen, correct? 18 A. For candy bars, sir? 19 Q. A judgment was entered against you for 20 $25,000, the value of what the Court found you had 21 stolen, correct? 22 A. Well, if a candy bar is worth that much, 23 yes, sir. 24 Q. That’s not all you owe Mr. Jackson 25 currently, is it? 26 A. No, sir. I don’t owe him. 27 Q. In fact, Judge Zel Canter of this court, 28 entered a judgment against you and your 5204 1 co-defendants for $1,473,117.61, correct? 2 A. Yes, sir. 3 Q. He ordered you pay all of Mr. Jackson’s 4 legal fees and costs, correct? 5 A. Yes, sir. 6 Q. Have you ever paid any of that judgment, Mr. 7 Chacon? 8 A. No, sir. I filed bankruptcy. 9 Q. Now, the jury found you not only stole from 10 Mr. Jackson, but you acted maliciously, correct? 11 A. No, sir. 12 Q. Did a judge find you had acted with malice? 13 A. No, sir. 14 Q. Is there a judgment against you for acting 15 with fraud against Mr. Jackson? 16 A. That I know of, no, sir. 17 Q. Would it refresh your recollection to look 18 at the judgment?


[b]Adrian McManus[/b]

5355 27 Q. The prosecutor for the government mentioned 28 a case you were involved in where you were sued by 5356 1 Rosalie Hill, correct? 2 A. Correct. 3 Q. You were sued by Rosalie Hill as the 4 guardian ad litem for two children, correct? 5 A. Correct. 6 Q. The children were Shane McManus and Megan 7 McManus, correct? 8 A. Correct. … 5356 19 Q. That was Judge Richard A. St. John, Judge of 20 the Santa Barbara Superior Court, true? … 5356 28 Q. And after you told Judge St. John your 5357 1 position under oath, he found that you and your 2 husband willfully and maliciously defrauded these 3 children out of the money in the estate, true? 4 A. I believe so. 5 Q. Judge St. John found that that money was to 6 be held in trust for the benefit of those two 7 children, right? 8 A. Yes. 9 Q. He found that you and your husband 10 dissipated those funds, right? 11 A. I believe so. 12 Q. He found that you and your husband violated 13 that trust, right? 14 A. I believe so. 15 Q. He entered a judgment against you and your 16 husband for $30,000 — excuse me, 30,584.89, 17 correct? 18 A. I believe so, but I believe it was — I 19 thought it was like separate, like — I thought it 20 was maybe 17 for me and 17 for my husband. Maybe — 21 I don’t know. Maybe that’s right, what you have 22 there.

:nav Cross-examination of Chacon and McManus April 7

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