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28 CAMP8ELL I> WILLIAMS

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DONALD 1. CAMPBELL (Nevada State Bar No. 1216) J. COLBY WILLIAMS (Nevada State Bar No. 5549) CAMPBELL & WILLIAMS

700 South Seventh Street

Las Vegas, Nevada 89101

Telephone: (702) 382-5222

Facsimile: (702) 382-0540

KELLI L. SAGER (California State Bar No. 120162; Nevada Pro Hac Vice Pending)

ALONZO WICKERS IV (California State Bar No. 169454; Nevada Pro Hac Vice Pending)

DAVIS WRlGHT TREMAINE LLP

865 S. Figueroa Street, Suite 2400

Los Angeles, California 90017-2566

Telephone: (213) 633-6800

Facsimile: (213) 633-6899

FILED NOV 2 02009 ~-i.~

ctEFiK OF COURT

Attorneys for Non-Party Press Organizations

LOS ANGELES TIMES COlvIMUNICA TrONS LLC; THE ASSOCIATED PRESS; STEPHENS MEDIA LLC d/b/a LAS VEGAS REVIEW-JOURNAL; and TMZ PRODUCTIONS, INC.

DISTRICT COURT CLARK COUNTY, NEVADA

IN RE MATTER OF SEARCH WARRANTS ) Miscellaneous Action No. A-09-60 1140-C

ISSUED IN CONNECTION WITH ) Dept. No. XXI

INVESTIGATION OF DEATH OF MICHAEL)

JACKSON ) SUPPLEMENTAL ORDER

) REGARDING REQUEST TO

)) INTERVENE AND FOR ORDER

UNSEALING COURT RECORDS

j RELATED TO SEARCH WARRANTS

») Hearing Date: November 18-19,2009

) Hearing Time: 10:00 a.m.

)

)

------------------------------)

The Request to Intervene and for Order Unsealing Court Records Related to Search

Warrants came on for a status hearing in Department XXI before the Honorable Valerie Adair on

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28 CAMPBELL 6. WILLIAMS

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November 18, 2009.

J. Colby Williams, Esq. appeared on behalf of the Non-Party Press

Organizations; David Schubert, Chief Deputy District Attorney, appeared on behalf of the State of

Nevada. The Court, having previously reviewed the papers and pleadings on file in this matter,

considered the arguments of counsel at the time of status hearing, which included in camera

presentations from Detective Orlando Martinez from the Los Angeles Police Department (on

November 18) and Deputy Attorney David Walgren from the Los Angeles District Attorney's

Office (on November 19) who are involved in the Michael Jackson murder investigation, hereby

rules as follows:

Upon the Court's inquiry, Deputy Attorney Walgren was unable to articulate a specific

reason why the search warrant and affidavit filed on or about August 13, 2009 should be kept

sealed or explain how the subject investigation would be compromised by unsealing these

materials. Based upon Deputy Attorney Walgren's statements and the testimony of Detective

Orlando Martinez of the previous day, the Court FINDS there is not a sufficient basis to continue

to keep the materials sealed.

NOW, THEREFORE, the Court GRANTS the Motion of the Non-Party Press

Organizations and ORDERS the warrant and affidavit filed on or about August 13, 2009

UNSEALED.

~

DATED this~ day of November, 2009.

VALERIE ADAIR

DISTRiCT COURT JUDGE

2

CAMPS eLL s WILLIAMS

1 2

Submitted by:

CAMPBELL & WILLIAMS

3 DONALD J. CAlvIPBELL J. COLBY WILLIAMS

DAVIS WRIGHT TREMAINE LLP 5 KELLI L. SAGER

ALONZO WICKERS IV

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Attorneys for Non-Party Press Org izations

LOS ANGELES TIMES COMMUNICATIONS LLC; THE ASSOCIATED PRESS; STEPHENS MEDIA LLC d/b/a LAS VEGAS REVIEW-JOURNAL;

and TMZ PRODUCTIONS, INC.

3

IN RE: SEARCH WARRANT for )

) ) 6370 West Flamingo, Suite #1 LV. NV 89103 ) )

)

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I , .,

ORDER SEALING , . AFFIDAVIT

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Upon the ex parte application of Detective S. Armbruster P#7327 a commissioned officer

with the Las Vegas Metropolitan Police Department and Affiant, to seal the affidavit in support of the attached search warrant, and for good cause appearing therefore,

IT IS HEREBY ORDERED that the affidavit in support of the attached search warrant be

ordered sealed pending further order of this Court except that copies may be provided to the office of tile Clark County District Attorney, the Los Angeles Police Department and/or the Drug

Enforcement Administration. A prosecuting agency may provide copies to a Defendant in a

criminal proceeding as part of the criminal discovery process, and

IT IS FURTHER ORDERED a copy of this order sealing the affidavit be left at the premises along with the search warrant in lieu of the affidavit in support of the warrant.

DATED this ~ay of August, 2009

AFFIANT

CERTIFIED COpy DOCUMENT ATIACHED IS A TRUE AND CORRECT COpy OF THE ORIGINAL ON FILE

C[~F~T

AUG 1 3 2009

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SEARCH WARRANT

STATE OF NEVADA) L:;G \ 'j lb i"li 'u.

) 5S: 6370 West Flamingo, Suitr:.#1 LV, NV-891~

COUNTY OF CLARK) c. , ; .. JC'

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The State of Nevada, to any Peace Officer in the County of Clark, proof by Affidavit having been made before me by Detective S. Armbruster P#7327, said affidavit attached hereto and incorporated herein by reference, that there is probable cause to believe that certain property, hereinafter described will be found at the following described premises, to wit:

1) 6370 West Flamingo, Suite #1 Las Vegas) Clark County, Nevada further described as a single story office/business complex. The structure has a tan stucco exterior with a tan tile roof, Applied Pharmacy occupies Suite 1. The aforementioned suite is located on the west end of the building. ·Working from west to east, the first suite is identified by a clear glass door surrounded by a dark metal frame. This door faces south. The number "1 ", white in color, is located above the door. Located on the door is a sign with a yellow background, with black letters, reading "PATIENTS USE OTHER DOOR". Directly west of this door is a business sign placed on the top portion of a glass window. The sign has a white background with black letters and contains the words "Applied Pharmacy Services", East of door one is an additional entrance for Applied Pharmacy suite and is identified by a clear glass door surrounded by a dark metal frame. This door faces south. East of the second door, written on the glass window, is tile words "Applied Pharmacy". The address number "6370" are affixed to a business marquis directly southeast of the office/business complex, Further, the marquis proclaims the office/business complex to be Phoenix Plaza III. The Phoenix Plaza III logo is affixed to the roof overhang directly east of Applied Pharmacy. The Phoenix Plaza 111 is written in blue letters on a white background.

The property referred to and sought to be seized consists of:

A) Medications, correspondence, notations, logs, receipts, journals, books, records and documents noting price, quantity, and/or times when prescription medications, including but not limited to PROPOFOL (DIPRIVAN). were administered, prescribed, obtained, transferred, sold, distributed, and/or bought by DR. CONRAD MURRAY, GLOBAL CARDIOVASCULAR ASSOCIATES aka GLOBEL CARDIOVASCULAR ASSOCIATES or any

1

employee thereof including but not limited to STACEY HOWE, LEAH TANNER, SARAH O'LEARY, CAROL GREUEL and COI'JNIE NG.

8) Credit Card receipts, logs, transactions, history, for any medicines, supplies, drugs and/or items from Applied Pharmacy Services to DR. CONRAD MURRAY, Global Cardiovascular Associates and/or any employee thereof including but not limited to STACEY HOWE, LEAH TANNER, SARAH O'LEARY, CAROL GREUEL and CONNIE NG, including but "not limited to a VISA card ending in tile digits 4467 used in the May 12, 2009 purchase by MURRAY.

C) A sample of bottles/vials of PROPOFOL (DIPRIVAN) with the "lot numbers" of 313058858 and/or 76197DJ, including but not limited to bottles manufactured by Teva, Inc. and Hospira Inc.

D) Federal Express records, mail orders, shipping orders, distribution lists, use/receiving records relating to the purchase, transfer, receiving, ordering, delivery and storage of PROPOFOL (DIPRIVAN) to DR. CONRAD MURRAY, Global Cardiovascular Associates and/or any employee thereof including but not limited to STACEY HOWE, LEAH TANNER, SARAH O'LEARY, CAROL GREUEL and CONNIE NG from Applied Pharmacy Services and shipments/product received by Applied Pharmacy Services from any manufacturer and/or distributor.

E) This search is authorized for the described location including all rooms, locked or unlocked, within the location. The search shall extend into all containers, safes, desks, cabinets, drawers, closets, briefcases, trash receptacles, recording media, mailboxes, garages, outbulldings or other storage areas within or thereon the location. The search may include the inspection and mlrror-lmaqlnq of any computer-based storage media, whether locked or unlocked, contained within the area described in this paragraph.

And as I am satisfied that there is probable cause to believe that said property(s) is located as set forth above and that based upon the Affidavit attached hereto there are sufficient grounds for the issuance of the search warrant.

You are hereby commanded to search forthwith said premises for said property, serving this warrant between 7:00 a.m. and 7:00 p.m., and if the property is there to seize it, prepare a written inventory of the property seized, and make a return for me within ten days, pursuant to NRS 179.075 and then, transfer said property to a sworn law enforcement officer employed by the Los Angeles Police Dept / Los Angeles Sheriff's Office of the State of California, for transfer to the State of California, where such property shall be held subject to further order of a Nevada court or a court in the

State of California, pursuant to NRS 179.105. During the execution of this search warrant I authorize California and federal law enforcement officers to be present and assist Nevada authorities.

Further, upon good cause shown in the affidavit and application for search warrant, the affidavit is ordered sealed and a copy of the affidavit need not be left with this search warrant.

-tt#'

DATED THIS -L- day of August, 2009.

REF: 1) 6370 West Flamingo, Suite #1 LV, NV 89103

J

APPLICATION AND AFFIDAVIT FOR SEARCH WARRANT

STATE OF NEVADA) i I:'

) 55: 6370 West Flamingo, Suite #1 LV, NV 89103 COUNTY OF CLARK)

lil:G i J

I, Detective S. Armbruster P#7327, being first duly sworn, depeses .and slateji that he is the affiant herein, and that he is a Police Officer with the l~:s.vegas rJi~tf.?pblitan Police Department for approximately seven years. I am currently assigned Ito the Narcotics Bureau, specifically to the Drug Enforcement Adrninlstratlcn's Tactical Diversion Squad.

That there is probable cause to believe that certain property hereinafter described will be found at tile following described premises, to-wit:

1) 6370 West Flamingo, Suite #1 Las Vegas, Clark County, Nevada further described as a single story office/business complex. The structure has a tan stucco exterior with a tan tile roof. Applied Pharmacy occupies Suite 1. The aforementioned suite is located on the west end of the building. Working from west to east, the first suite is identified by a clear glass door surrounded by a dark metal frame. This door faces south. The number 111 It, white in color, is located above the door. Located on tile door is a sign with a yellow background, with black letters, reading uPATIENTS USE OTHER DOOR", Directly west of this door is a business sign placed on the top portion of a glass window. The sign has a white background with black letters and contains the words "Applied Pharmacy Services", East of door one is an additional entrance for Applied Pharmacy suite and is identified by a clear glass door surrounded by a dark metal frame, This door faces south. East of the second door, written on the glass window, is the words "Applied Pharmacy". The address number "6370" are affixed to a business marquis directly southeast of the office/business complex. Further, the marquis proclaims the offlce/buslness complex to be Phoenix Plaza III. The Phoenix Plaza III logo is affixed to the roof overhang directly east of Applied Pharmacy. The Phoenix Plaza III is written in blue letters on a white backqround.

The property referred to and sought to be seized consists of the following:

A) Medications, correspondence, notations, logs, receipts, journals, books, records and documents noting price, quantity, and/or times when prescription medications, including but not limited to PROPOFOL (DIPRIVAN), were administered, prescribed, obtained, transferred, sold, distributed, and/or

1

bought by DR. CONRAD MURRAY, GLOBAL CARDIOVASCULAR ASSOCIATES aka GLOBEL CARDIOVASCULAR ASSOCIATES or any employee thereof including but not limited to STACEY HOWE, LEAH TANNER, SARAH O'LEARY, CAROL GREUEL and CONNIE NG.

B} Credit Card receipts, logs, transactions, history, for any medicines, supplies, drugs and/or items from Applied Pharmacy Services to DR. CONRAD MURRAY, Global Cardiovascular Associates and/or any employee thereof including but not limited to STACEY HOWE, LEAH TANNER, SARAH O'LEARY, CAROL GREUEL and CONNIE NG, including but not limited to a VISA card ending in the digits 4467 used in the May 12, 2009 purchase by MURRAY.

C) A sample of bottleslvials of PROPOFOL (DIPRIVAN) with the "lot numbers" of 313058858 and/or 76197DJ, including but not limited to bottles manufactured by Teva, Inc. and Hospira Inc.

D) Federal Express records, mail orders, shipping orders, distribution lists, use/receiving r-ecords relating to the purchase, transfer, receiving, ordering, delivery and storage of PROPOFOL (DIPRIVAN) to DR. CONRAD MURRAY, Global Cardiovascular Associates and/or any employee thereof including but not limited to STACEY HOWE, LEAH TANNER, SARAH O'LEARY, CAROL GREUEL and CONNIE NG from Applied Pharmacy Services and shipments/product received by Applied Pharmacy Services from any manufacturer and/or distributor.

E) This application is for authorization to search the described location including all rooms, locked or unlocked, within the location. The search shall extend into all containers, safes, desks, cabinets, drawers, closets, briefcases. trash receptacles, recording media, mailboxes, garages, outbuildings or other storage areas within or thereon the location. The search may include the inspection and mirror-imaging of any computer-based storage media, whether locked or unlocked, contained within the area described in this paragraph.

Las Vegas Metropolitan Police Department has no intention of retaining or copying any aforementioned property to be seized. All property of evidentiary value will be turned over to the Los Angeles Police Department.

Your Affiant is currently assisting the Los Angeles Police Department, specifically the Robbery-Homicide Division, with an ongoing criminal investigation. Your Affiant received information from Los Angeles Police Department. Co-Case Agent, Detective

Scott Smith, Serial NO. 25301, that they are investigating the following crimes that were comrnitted in the state of California:

California Penal Code section 192(b) Manslaughter.

In support of your affiant's assertion to constitute the existence of probable cause, the following facts are offered:

STATEMENT OF PROBABLE CAUSE

Affiant declares under penalty of perjury that the following facts are true and that there is probable cause to believe, and Affiant does believe, that the designated articles, property, and persons are now in the described locations, including all rooms, buildings, and structures used in connection with the premises and buildings adjoining them, the vehicles and the persons:

On August 5, 2009, Detective Steve Armbruster who is employed by the Las Vegas Metropolitan Police Department and is assigned to the Drug Enforcement Administration's Tactical DIversion Squad, Las Vegas office was presented with an affidavit outlining an ongoing investigation in the state of California. It is your affiant's assertion that LAPD Peace Officer Orlando Martinez Serial Number #31124 demonstrated probable cause for the crime of California Penal Code section '192(b) Manslaughter.

On June 25, 2009, at approximately 1222 hours, Los Angeles Fire Department (LAFO) Rescue Ambulance (RA) 71 responded to an emergency call at 100 North Carolwood Drive, in the city of Los Angeles. The comments of the call stated a 50 year old male was not breathing, and cardiopulmonary resuscitation (CPR) was in progress. Upon their arrival, they were met by Dr. CONRAD MURRAY, who identified himself as the patient's personal physician. MURRAY informed the paramedics that the patient, later identified as MICHAEL JOSEPH JACKSON, had stopped breathing and MURRAY had continuously administered CPR until the RA's arrival.

Murray told the PAFD paramedics he had given JACKSON LORAZEPAM (ATIVAN) before he stopped breathing. The paramedics began caring for JACKSON and transported both MURRAY and JACKSON to UCLA Medical Center. Upon arrival, MURRAY met with Dr. R. COOPER, the physician in charge of the emergency department. MURRAY told COOPER he had given JACKSON two separate 2mg doses of LORAZEPAM (ATIVAN), during the course of the night. COOPER and her team attempted to revive JACKSON with negative results, COOPER pronounced JACKSON's death at 1426 hours. MURRAY refused to sign the death certificate, and the Los Angeles Coroner's Office was summoned to the hospital. Los Angeles Police Department (LAPD) Robbery Homicide Division (RHO) Detectives Smith, Serial No.

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25301, and Officer Martinez were assigned to assist the Coroner's office conduct a death investigation. Upon arrival at UCLA Medical Center, neither the coroner's investigators nor detectives could locate MURRAY to re-interview him, Repeated attempts at contacting and locating MURRAY were unsuccessful.

Coroner's investigators and RHO Detectives responded to 100 North Carolwood Drive to further their investigation, A search of the residence, specifically JACKSON's bedside, revealed numerous bottles of medications prescribed by DR. MURRAY to JACKSON, including DIAZEPAM (VALIUM), TAMSULOSrN (FLOMAX), LORAZEPAM (ATIVAN) and TEMAZEPAM (RESTORIL). Prescription pill bottles of CLONAZEPAM (KLONOPIN) and TRAZODONE (DESYRL), prescribed to JACKSON by DR. METZGER and a prescription pill bottle of TIZANIDINE (ZANAFLEX), prescribed to JACKSON by DR. KLEIN were also found at JACKSON's bedside. According to the Physician's Desk Reference (PDR), most of these drugs have an indicated or off label use in the treatment of insomnia.

On June 27, 2009, Detective Smith and Officer Martinez met with MURRAY and his attorneys for an interview. MURRAY stated that he was JACKSON's personal physician. MURRAY had been treating JACKSON for insomnia for approximately the past six weeks. He had been giving JACKSON 50 mg of PROPOFOL (DIPRIVAN), diluted with LIDOCAINE (XYLOCAINE), every night via intravenous drip (IV) to assist JACKSON In sleeping.

MURRAY felt that JACKSON may have been forming an addiction to PROPOFOL (DIPRIVAN), and tried to wean JACKSON off of the drug. On June 22, 2009, two clays prior to his death, 11e gave JACKSON 25 mg PROPOFOL (DIPRIVAN), along with LORAZEPAM (ATIVAN), and MIDAZOLAM (VERSED). JACKSON was able to sleep with this mixture of medications, On June 23, 2009, he gave JACKSON LORAZEPAM (ATIVAN) and MIDAZOLAM (VERSED) only, withholding any PROPOFOL (DIPRIVAN), and JACKSON was able to sleep. On June 25, 2009, at approximately 0130 hours, he again tried to induce sleep without the PROPOFOL (DIPRIVAN) and gave JACKSON a 10mg tab of VALIUM, JACKSON was unable to sleep and at approximately 0200 hours, MURRAY injected JACKSON with 2mg LORAZEPAM (ATIVAN) after dilution, pushed slowly Into his IV. JACKSON was still unable to sleep. At approximately 0300 hours, MURRAY then administered 2mg MIDAZOLAM (VERSED) to JACKSON after dilution, also pushed slowly into his IV, JACKSON remained awake and at approximately 0500 hours, MURRAY administered another 2mg LORAZEPAM (ATIVAN). after dilution, pushed slowly into his IV. JACKSON remained awake and at approximately 0730 hours, MURRAY administered another 2mg of MIDAZOLAM (VERSED), after dilution, into his IV. MURRAY stated 11e was continuously at JACKSON's bedside and was monitoring him with a pulse oximeter. According to DR. MURRAY, tile pulse oximeter was connected to JACKSON's finger and measured his pulse and oxygen statistics.

JACKSON remained awake and at approximately 1040 hours, MURRAY finally

administered 251119 of PROPOFOL (DIPRIVAN), diluted with LIDOCAINE (XYLOCAINE), via IV drip to keep JACKSON sedated, after repeated demands/requests from JACKSON. JACKSON finally went to sleep and MURRAY stated that he remained monitoring hlm. After approximately 10 minutes, MURRAY stated he left JACKSON's side to go to the restroom and relieve himself. MURRAY stated he was out of the room for about 2 minutes maximum. Upon his return, MURRAY noticed that JACKSON was no longer breathing. MURRAY began single man cardiopulmonary resuscitation (CPR) at once. MURRAY also administered .2mg of FLUMANEZIL (ANEXATE) to JACKSON and called JACKSON's personal assistant, MICHAEL AMIR WILLIAMS, with his cellular telephone for help. MURRAY reached WILLIAMS and requested that he send security upstairs for an emergency. MURRAY continued CPR and after a few minutes without the security detail's response, he left JACKSON and ran out to the hall and downstairs to the kitchen. MURRAY asked the chef to send up PRINCE JACKSON, the eldest son, and returned to continue CPR. P. JACKSON responded upstairs and summoned the security detail. ALBERTO ALVAREZ went to the aid of MURRAY and called 911 via his cellular telephone. MURRAY waited for the ambulance's arrival while conducting CPR, assumed care from the paramedics and accompanied them to the hospital. MURRAY observed the treatment to JACKSON at UCLA Medical Center and assisted in notifying the family after JACKSON's death was pronounced. MURRAY left the hospital after a while because he did not know that he was needed. MURRAY added that his doctor'S bag was still at the residence and directed Officer Martinez to its exact location inside of JACKSON's residence.

MURRAY told Officer Martinez that he was not the first doctor to introduce JACKSON to PROPOFOL (DIPRIVAN). MURRAY stated that JACKSON was very familiar with the drug and referred to it as his "milk." PROPOFOL (DIPRIVAN) has a milk appearance. JACKSON would also refer to the LIDOCAINE (XYLOCAINE) as "anti-burn." According to the Physician's Desk Reference (PDR), PROPROFOL (DIPRIVAN) creates a burning sensation at the injection site and LIDOCAINE (XYLOCAINE) can be used to relieve the dlscorntort. MURRAY stated that he had repeatedly asked JACKSON what other physicians were treating him and what was

. being prescribed to him, but JACKSON would not tell him. JACKSON did mention that Doctor ARNOLD KLEIN and Doctor ALAN METZGER had given him medicine and that it was not working. JACKSON told MURRAY about two unknown doctors in Germany whom gave him the PROPOFOL (DIPRIVAN). At one time MURRAY noticed and inquired about injection marks on JACKSON's hands and feet. JACKSON stated that Doctor CHERIL YN LEE had been giving him a "cocktail" to help him. MURRAY believed the cocktail to be a PROPOFOL (DIPRIVAN) mix. MURRAY also recounted how sometime between March and April of this year, JACKSON called him in las Vegas and asked l1im to call Doctor DAVID ADAMS and arrange for Doctor ADAMS to give JACKSON PROPOFOL (DIPRIVAN). MURRAY did as JACKSON asked and arranged for Doctor ADAMS to treat JACKSON. MURRAY was present at a third party cosmetologist's office where Doctor ADAMS sedated JACKSON with PROPOFOL (DIPRIVAN). MURRAY stated this was around the time that JACI<SON requested him

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to be his personal physician on tile European tour .

. Officer Martinez obtained MURRAY's cellular telephone records for the early morning hours of June 25, 2009. In his statement, MURRAY estimated the time that he noticed JACKSON was not breath ing to be at approximately 1100 hours. MURRAY's cellular telephone records show MURRAY on the telephone, with three separate callers for approximately 47 minutes starting at 1118 hours, until 1205 hours. MURRAY did not mention this to tile interviewing detectives.

Officer Martinez authored a search warrant for the doctor's bag and supplies and on June 29, 2009, the honorable Judge C. OLMEDO issued the search warrant for JACKSON's residence at 100 N. Carolwood Drive. Investigators served the warrant and recovered multiple bottles/vials of LIDOCAINE (XYLOCAINE), several bottles/vials of PROPOFOL (DIPRIVAN), bottles/vials of LORAZEPAM (ATIVAN), bottles/vials of MIDAZOLAM (VERSED), and bottles/vials of FLUMAZENIL (ANEXATE). None of these items were labeled as prescribed to any patient.

The PROPOFOL (DIPRIVAN) that was recovered from 100 N. Carolwood Drive in Dr. Murray's doctor's bag and on the bedside table was in 20 ml and 100 ml bottles with the "lot numbers" of 313058858 and 76197DJ.

Detectives contacted the Drug Enforcement Administration (DEA) to assist in tracking the medications found at JACKSON's residence. DEA agents informed Officer Martinez PROPOFOL is difficult to track because the lot numbers are created in large amounts and shipped from manufacturer to distributor, distributor to surgery center, hospital, etc. The hospital or surgery center records would be needed to examine how many units were received and how they are accounted for. DEA advised that all doctors or nurse practitioners who prescribe medicines in California are required to obtain a "DEA" number under which they are identified during their drug orders. DEA also checked all available computer systems to determine whether DR. MURRAY had prescribed PROPOFOL (DIPRIVAN) to JACKSON and how much of the drug he had purchased and/or ordered. DEA was unable to find a record of DR. MURRAY purchasing, ordered or obtaining any PROPOFOL (DIPRIVAN) under his medical license or DEA number.

The attorney for the JACKSON family members, Blair Berk, contacted Officer Martinez and gave him the name of Dr. RANDY ROSEN. JACKSON's relatives stated that JACKSON had told them ROSEN had been treating him. JACKSON's family and news reports have documented that JACKSON has used the aliases of JACK LONDON, MIKE JACKSON, MICK JACKSON, FRANK TYSON, and MIC JACKSON. Tiley also mention that JACKSON would have prescriptions written in the name of members of his entourage. Through interviews of JACKSON's staff, employees and family, investigators determined that at the time of his death, JACKSON's closest circle of associates included MICHAEL AMIR WILLIAMS MUHAMMAD, JIMMY NICHOLAS, BLANCA NICHOLAS, ROSELYN MUHAMMAD, PRINCE JACKSON, FAHEEM

G

MUHAMMAD, AND KAI CHASE. On July 17, 2009, detectives received a call from an unknown female caller who stated that she had information on tile aliases used by JACKSON when he would visit DR. KLEIN. She provided the names, OMAR ARNOLD, FERNAND DIAZ, PETER MADONIE, and JOSEPHINE BAKER as names JACKSON would use when seeing DR. KLEIN. Detectives recovered a prescription at JACKSON's residence in the name of OMAR ARNOLD prescribed by DR. KLEIN.

Los Angeles County Coroner's Investigator Fleak subpoenaed medical records from DR. CONRAD MURRAY, DR. ARNOLD KLEIN, DR. ALLAN METZGER, DR. DAVID ADAMS, DR. MARK TADRISSI, whom DR. ADAMS stated stored his medical records, DR. DAVID SLAVIT, who completed an independent medical examination of JACKSON for Anschuntz Entertainment Group (AEG), DR. RANDY ROSEN and nurse practitioner CHERILYN LEE.

Detectives Smith and Myers interviewed CHERIL YN LEE. LEE first met JACKSON ill January 2009 when she was asked to come and look at JACKSON's three children, Prince, Paris and Blanket, who were suffering from colds. She conducted a routine examination on all 3 children.

LEE stated that JACKSON was complaining of a low energy level. She returned the next day and completed a full blood screening. Two days later the blood came back normal-low blood sugar. LEE stated that she put JACKSON on a good food diet with a protein drink.

On Easter Sunday, JACKSON complained to LEE that he had problems sleeping.

JACKSON mentioned the drug PROPOFOL (DIPRIVAN). LEE stated that she was not familiar with the drug. JACKSON told her that his Doctor told him that it was safe. He did not mention what Doctor told him this. LEE researched the drug and learned that PROPOFOL (DIPRIVAN) was commonly used by anesthesiologists during surgery. She stated that the drug was not good for him and that he should not take it. LEE stated that JACKSON asked her if she could get PROPOFOL (DIPRIVAN) or if she knew someone that could. He stated he would pay her or another Doctor whatever they wanted for it. LEE stated that 511e could not and would not get it for him. LEE stated that this was the last time she ever saw JACKSON.

On Father's Day of this year, LEE stated that she received a call from FAHEEM MUHAMMAD, JACKSON's personal body guard, stating that JACKSON was sick. LEE stated that she heard JACKSON in the background saying, "one side of my body is hot and the other side is cold." When asked what this meant to her, she stated that something had been introduced into his Central Nervous System. LEE stated she told Faheem to take JACKSON to the hospital.

Detectives interviewed GRACE OWANDA, JACKSON's children's nanny. OWANDA stated that JACKSON was currently being treated by DR. KLEIN and tile last physician to treat JACKSON was DR. LARRY KOPLIN.

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The Los Angeles Chief Medical Examiner-Coroner, Dr. SATHYAVAGISWARAN, indicated that he had reviewed the preliminary toxicology results and his preliminary assessment of JACKSON's cause of death was due to lethal levels of PROPOFOL (DIPRIVAN).

Investigators interviewed the responding paramedics and UCLA Medical staff regarding the statements made by DR. MURRAY on the 251h of June at the residence and hospital. UCLA doctors and the LAFD paramedics stated that DR. MURRAY had only disclosed that he had given the medication LORAZEPAM (ATIVAN) to JACKSON prior to his medica! emergency. DR. MURRAY also admitted to giving JACKSON the medication FLUMAZENIL (ANEXATE), to counteract the LORAZEPAM (ATIVAN), to UCLA doctors.

On July 24, 2009, the Honorable Judge Timothy C. Williams, Clark County District Court issued a search warrant for DR. MURRAY's business address, "Global Cardiovascular Associates" 21 -10 East Flamingo, unit number 301, Clarl< County, Las Vegas Nevada, and his home address, 2426 Grassy Spring, Clarl< County, Las Vegas Nevada. On July 28, 2009, Las Vegas Metro Police Department (LVMPD), Drug Enforcement Administration (DEA) and Los Angeles Police Department (LAPD) .Robbery-Hornlclde Division (RHO) officers served the search warrant at the business and home addresses for items including "Records, shipping orders, distribution lists, and Lise records re/Elting to the purchase, transfer. receiving, ordering, delivery and storage ot PROPOFOL (0 IPRI VA N). " LAPD detectives identified the employees of Global Cardiovascular Associates as STACEY HOWE, LEAH TANNER, SARAH O'LEARY, CAROL GREUEL and CONNIE NG through business records and employee interviews.

During the search, LAPD Detective Smith, Serial No. 25301, recovered a sales receipt from "Applied Pharmacy Services," located at 6370 W. Flamingo Road, Suite number 1, Las Vegas, NV, to "Conrad MURRAY, MD, Global Cardiovascular Assoc." at 2110 East Flamingo Road, suite number 201, for a purchase of PROPOFOL (DIPRIVAN) and other drugs. The receipt detailed on May 12, 2009, MURRAY purchased four (4) 100ml vials of PROPOFOL 10MLlML SDV 10x100ML, one (1) 100ml vial of PROPOFOL 10MLlML VL 25x20ML, two (2) vials of MIDAZOLAM 1MG/ML VIAL 1012 ML, one (1) vial FLUMAZENIL 0.1 MG/ML VL 10x5ML and one ('I) LIDOCAINE 2% cream. The receipt was dated 05/12/2009, and marked with sale number 25234. Attached to the receipt were 2 separate copies of credit card transactions, detailing the business "Applied Pharmacy Services" at 6370 W Flamingo Rd Ste 1, Las Vegas, NV 89103-2274, (702) 304-0770, Merchant 10: 8013131753, Term 10: 0017340008013131753002, Invoice Number 025234, Approval Code: 902570, credit card number xxxxxxxxxxxx4467, in the amounts of $853.00 at 16:25:02 and $65 at 16:29:06. The separate $65 charge was for overnight Federal Express (Fed Ex) of the purchased items to DR. MURRAY at an unknown destination.

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DEA Agents were tasked with attempting to track the origin. route and possessor of the PROPOFOL (DIPRIVAN) bottles found at the JACKSON residence. On August 4, 2009, DEA agents notified your affiant that PROPOFOL (DIPRIVAN) bottles found during the search of Jackson's residence showed Teva, Inc. as the manufacturer for the 20ml bottles and Hospira, Inc. for the 100ml bottles. DEA sent requests for shipment records for all bottles possessed with the lot numbers of 313058858 and/or 76197DJ to both manufacturers. From the records received from the manufacturers, additional record requests were made by DEA to each distributor Teva and Hospira had sold to. DEA received records of sales from these distributors as well. A subsequent review of records received by DEA from the distributors showed sales to Applied Pharmacy Services for both 20ml and 100ml bottles.

Your affiant respectfully requests that a search warrant be issued for the business "Applied Pharmacy Services" at 6370 W. Flamingo Road, Suite No.1 Clark County, Las Vegas Nevada. Your affiant believes that the location will house information on any other/further transactions between DR. MURRAY and the pharmacy for PROPOFOL (DIPRIVAN). This information may also uncover the VISA credit card number DR. MURRAY used in the transaction and may lead to any further purchases of PROPOFOL (DIPRIVAN).

Based on the aforementioned information and investigation, your affiant believes grounds for issuance of a search warrant exists as set forth in Nevada Revised Statutes 179.035 and 179.045 because the items sought constitute evidence which tend to show that a crime has been committed, and that a particular person has committed a crime. Given that the State of California has no authority to issue a search warrant for property within the State of Nevada, I respectfully request this Court to issue a search warrant for the described property, located in Nevada; said property being evidence of crimes committed In the State of California. It is the intent of tile affiant and peace officers executing the warrant to turn over all the evidence seized hereunder to a designated sworn law enforcement officer from the Los Angeles Police Department I Sheriffs Office of the State of California for use in its prosecutionlinvestigation. I have been assured by the designated sworn law enforcement officer from the Los Angeles Police Department/Sheriff's Office of the State of California that the property turned over will be protected and subject to the jurisdiction of the courts of California and will not be disposed of except as pursuant to law of the State of California. The suspect herein will be accorded due process in such disposition. I have also been assured by the designated sworn law enforcement officer that jf a final judgment/order is entered by a Nevada court declaring the warrant is invalid pursuant to NRS 179.085, the property will be returned to the aggrieved party as Indicated in the judgment/order. Thus, in signing this affidavit and warrant I respectfully request the permission of the Magistrate to authorize such removalof the seized property to the State of California authorities in accordance with the terms herein.

Your affiant requests the items seized pursuant to this search warrant be permitted for use by the Medical Board of California, Drug Enforcement Administration

9

and the California Department of Justice, Bureau of Narcotics Enforcement in any possible administrative action taken to modify Ute subjects' license status.

It is further requested that this affidavit be sealed by the Order of the Court because of the following reasons. There is currently an ongoing criminal investigation involving multiple doctors, residences and businesses in several jurisdictions, and premature disclosure of the contents of this affidavit could jeopardize the success of the investigation.

WHEREFORE, Affiant requests that a Search Warrant be issued directing a search for and seizure of the aforementioned items at the locations set forth herein.

AFFIANT

SUBSCRIBED and SWORN to before me this 7 tf,;: day of August, 2009.

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PRoPfRT,v ,K,:itEA.5fL) 17 t1_?1P,D S ms: 'I}( #-.;i. s .3 0/ .•

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I Musl b ... made within 10 days cf lssuance of Warrant) :: ~ ,; I J

RETURN

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The Search and Seizure Warrant authorizing a search and aelzure at the rfo;i,,,~ing descrl~er.:I]~·cation(s):

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was executed on $?........,_· _- ..... /c....:! - c?.2 _

ImanU1. day. yoor.

A copy of this Inventory was left with

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In.,,,,, ul """on or·'" 100 pi,,,,, 01 teO't!"!"'

The following Is an inventory of property taken pursuant to the warrant:

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