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Wade Jeremy William Robson - 12/12/2016

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Wade Jeremy William Robson - 12/12/2016 Wade Jeremy William Robson - 12/12/2016 1 DECEMBER 12, 2016, SANTA MONICA, CALIFORNIA 2 THE VIDEOGRAPHER: Good morning. We are on the 3 record at 10:03 a.m., on December 12th, 2016, for the 4 videotaped deposition of Mr. Wade Robson. We're taping 5 this deposition at 808 Wilshire Boulevard, Third Floor, 6 in the City of Santa Monica, California, 90401, in the 7 action entitled Wade Robson v. MJJ Productions, Inc., et B al. The case number is BC508502, in the Superior Court 9 of the State of California, County of Los Angeles. 10 My name is Michael Currie. I'm the video 11 production specialist with Ben Hyatt Certified 12 Deposition Reporters in Encino, California. This is 13 tape one of Volume I. 14 Would counsel and all present please identify 15 yourselves for the record. 16 MS. KLEINDIENST: Katherine Kleindienst for 17 defendants. 18 MR. FINALDI: Vince Finaldi, Manly·stewart 19 Finaldi, for the plaintiff. 20 MR. STEWART: Morgan Stewart, Manly Stewart & 21 Finaldi, for plaintiff. 22 THE VIDEOGRAPHER: Okay, the court reporter 23 today is Sue Lansing, also with Ben Hyatt. 24 Ms. Lansing, will you please swear in the 25 witness. ... • ·•·••-·-·-·--- ••••·•s·r•• ·, ••a.·.·- c·, ·•·•·•·•·•·•· .•a·.•-• Page 3 Ben Hyatt Certified Deposition Reporters 888.272.0022 818.343.7040 Fax 818.343.7119 www.benhyatt.com AA - 3037 Wade Jeremy William Robson - 12/12/2016 1 WADE JEREMY WILLIAM ROBSON, 2 having been duly administered an oath in accordance 3 with CCP 2094, was examined and testified as 4 follows: 5 EXAMINATION 6 BY MS. KLEINDIENST: 7 Q. All right, good morning. 8 A. Good morning. 9 Q. Could you please state and spell your name for 10 the record. 11 A. Yeah. Wade, W-a-d-e, William, sorry, Jeremy, 12 J-e-r-e-m-y, and William, W-i-1-1-a, i-a-m. It's like I 13 never go through telling my middle names; right? And 14 Robson; R-o-b-s-o-n. 15 Q. Great. And have you ever gone by any other 16 names? 17 A. No. 18 Q. I want to talk for a minute, I know that you've 19 testified before, but I want to talk about, well, first 20 of all, the two times that I know of and whether you've 21 testified any other times. The first time I'm aware 22 that you've testified under oath was during the Jordy 23 Chandler allegations. Do you remember that? 24 A. Yes. 25 Q. And it's my understanding -- well, let me ask Page 4 Ben Hyatt Certified Deposition Reporters 888.272.0022 818.343.7040 Fax 818.343.7119 www.benhyatt.com AA - 3038 Wade Jeremy William Robson - 12/12/2016 1 you, do you know whether that was a deposition or what 2 type of testimony you were giving? 3 MR. FINALDI: Calls for legal conclusion. 4 THE WITNESS: Yeah, I'm not positive. I think, 5 I think it was a deposition. 6 Q. BY MS. KLEINDIENST: But it was in an informal 7 conference room type setting? 8 A. Yeah, like this type setting, yeah. 9 Q. And it was in lieu of testifying before the 10 grand jury? 11 MR. FINALDI: Same objection. 12 THE WITNESS: Yes. 13 Q. BY MS. KLEINDIENST: And that was when you were 14 11? 15 A. I believe so, yeah. 16 Q. And then, the second instance that I know of is 17 when you testified at the criminal trial in Santa 18 Barbara in 2005. Do you recall that? 19 A. Yes. 20 Q. And that was when you were how old? 21 A. I believe I was 22. 22 Q. And that was actually in a courtroom setting; 23 is that correct? 24 A. Yes. 25 Q. Other than those two instances, have you ever Page 5 Ben Hyatt Certified Deposition Reporters 888.272.0022 818.343.7040 Fax 818.343.7119 www.benhyatt.com AA - 3039 Wade Jeremy William Robson - 12/12/2016 1 provided testimony under oath before? 2 MR. FINALDI: Calls for legal conclusion. 3 THE WITNESS: The only other one I remember was 4 as a part of this case, or, the estate case, which I 5 believe was in 2014. 6 Q. BY MS. KLEINDIENST: Right. So that was a 7 deposition? 8 A. Yes. 9 Q. And that was given in connection with the 10 probate case against the estate? 11 A. Yes. 12 Q. And that's the only other time that you are 13 aware of that you've testified under oath? 14 A. That is all I recall, yeah. 15 Q. I'll go over some ground rules because I think 16 it's always good to anyway. If you don't understand my 17 question or you need me to clarify my question, please 18 let me know. Do you understand? 19 A. Yes. 20 Q. We can take a break at any time. So, just let 21 me know. The only thing I would ask is if there's a 22 question pending, that you would go ahead and answer the 23 question before we take the break. Do you understand? 24 A. Yes. 25 Q. As you know and as you can see, we have a court Page 6 Ben Hyatt Certified Deposition Reporters 888.272.0022 818.343.7040 Fax 818.343.7119 www.benhyatt.com AA - 3040 Wade Jeremy William Robson - 12/12/2016 1 reporter who is recording everything we're saying, so 2 for her sake we need to not talk over each other. So, 3 if you could wait for me to ask my question before you 4 start to answer, and I'll try to let you finish your 5 answer before I ask the next question. Okay? 6 A. Yes. 7 Q. Also for the court reporter's sake you need to B answer audibly rather than give, shake your head or give 9 a more vague answer like "uh-huh" or "huh-uh." Just a 10 simple "yes" or "no" will reflect better on the 11 transcript. Do you understand? 12 A. Yes. 13 Q. Are you represented by counsel here today? 14 A. Yes. 15 Q. Your counsel may make objections for the 16 record. Go ahead and let them finish their objection, 17 again, for the court reporter's sake, and then you can 18 go ahead and answer the question unless they instruct 19 you not to. Do you understand? 20 A. Yes. 21 Q. After the deposition you'll be given a chance 22 to read the transcript and make any corrections that you 23 deem necessary. But if you change the substance of your 24 testimony as it appears in the transcript, those changes 25 could be used to question your credibility as a witness, Page 7 Ben Hyatt Certified Deposition Reporters 888.272.0022 818.343.7040 Fax 818.343.7119 www.benhyatt.com AA - 3041 Wade Jeremy Wi11iam Robson - 12/12/2016 1 so it's important you give your best testimony here 2 today. Do you understand? 3 A. Yes. 4 Q. And you understand that even this is, even 5 though this is an informal conference room setting, that 6 you're under oath and under penalty of perjury just as 7 if you were testifying in a court of law? 8 A. Yes. 9 Q. And is there any reason that you cannot testify 10 truthfully and to the best of your recollection here 11 today? 12 A. No. 13 Q. What did you do to prepare for this deposition? 14 MR. FINALDI: Objection; calls for 15 attorney/client privileged communications. Instruct not 16 to answer. 17 Q. BY MS. KLEINDIENST: Did you meet with counsel? 18 MR. FINALDI: You can answer that yes or no. 19 THE WITNESS: Yes. 20 Q. BY MS. KLEINDIENST: When did you meet with 21 counsel? 22 A. This morning. 23 Q. Where did you meet? 24 A. Coffee Bean across the street. 25 Q. And how long did you meet before you came over? Page 8 Ben Hyatt Certified Deposition Reporters 888.272.0022 818.343.7040 Fax 818.343.7119 www.benhyatt.com AA - 3042 Wade Jeremy William Robson - 12/12/2016 1 A. About 30 minutes. 2 Q. Did you meet with counsel any other time to 3 prepare for this deposition? 4 A. Yes. 5 Q. When was that? 6 A. Last Friday. 7 Q. And how long did you meet? 8 A. Couple of hours. 9 Q. And who was, who was there? 10 A. Mr. Vince Finaldi. 11 Q. Anyone else? 12 A. At some point John Manly was there. 13 Q. And when you say a couple hours, you mean, 14 like, two or three? 15 A. Yeah, around that range. 16 Q. Did you meet with counsel any other days apart 17 from today and last Friday to prepare for this 18 deposition? 19 A. No. 20 Q. Did you review any documents to prepare for 21 this deposition? 22 A. Yes. 23 Q. Did any of those documents help you refresh 24 your recollection of facts or information about your 25 past? Page 9 Ben Hyatt Certified Deposition Reporters 888.272.0022 818.343.7040 Fax 818.343.7119 www.benhyatt.com AA - 3043 Wade Jeremy William Robson - 12/12/2016 1 A. I didn't need them to. 2 Q. Have you spoken to anyone else besides your 3 counsel about your deposition today? 4 A.
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