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Testemunho de Kris Kallman


9 Call Kris Kallman, Your Honor.

 

10 THE COURT: Come forward to the witness

 

11 stand, please. When you get to the witness stand,

 

12 remain standing.

 

13 Face the clerk and raise your right hand.

 

14

 

15 KRIS KALLMAN

 

16 Having been sworn, testified as follows:

 

17

 

18 THE WITNESS: Yes.

 

19 THE CLERK: Please be seated. State and

 

20 spell your name for the record.

 

21 THE WITNESS: My name is Kris, K-r-i-s,

 

22 Kallman, K-a-l-l-m-a-n.

 

23 THE CLERK: Thank you.

 

24

 

25 DIRECT EXAMINATION

 

26 BY MR. SNEDDON:

 

27 Q. Good morning, Mr. Kallman.

 

28 A. Good morning, Mr. Sneddon. 4949

 

 

 

1 Q. You’re an attorney?

 

2 A. Yes.

 

3 Q. Licensed to practice in the State of

 

4 California?

 

5 A. Yes, sir.

 

6 Q. And what is your brief educational

 

7 background to prepare you for the practice of law in

 

8 the State of California?

 

9 A. Well, I graduated from Santa Barbara High

 

10 School. Went to Santa Barbara City College.

 

11 Graduated from Cal Poly San Luis Obispo. Went to

 

12 Pepperdine University Law School.

 

13 Q. Do you have a certain area of law that you

 

14 specialize in?

 

15 A. Yes. I am a civil trial lawyer, and for the

 

16 most part, I represent people that get injured due

 

17 to the fault of another person or company.

 

18 Q. How long have you been practicing law in the

 

19 State of California?

 

20 A. 29 years.

 

21 Q. And how long have you lived in Santa Barbara

 

22 County?

 

23 A. My whole life, except when I was away at

 

24 college.

 

25 Q. And where do you live in Santa Barbara

 

26 County?

 

27 A. I live in Santa Barbara, on the mesa, in the

 

28 city. 4950

 

 

 

1 Q. Now, during the time that you’ve practiced

 

2 law in Santa Barbara County, have you had associates

 

3 that have practiced with you in your firm?

 

4 A. Yes.

 

5 Q. Are you a sole practitioner?

 

6 A. Essentially. Although I currently have two

 

7 lawyers that office with me and they act as “of

 

8 counsel.” They’re not employees, but they help me

 

9 out on cases.

 

10 Q. Are you familiar with an attorney by the

 

11 name of Terry Cannon?

 

12 A. I sure am.

 

13 Q. And how long have you known Mr. Cannon?

 

14 A. Oh, I’ve known Mr. Cannon for at least 20

 

15 years.

 

16 Q. And at some point in time prior to today,

 

17 was Mr. Cannon one of the people who was associated

 

18 with you in the practice of -- your civil practice?

 

19 A. Yes.

 

20 Q. And during what period of time was that; do

 

21 you recall?

 

22 A. Well, the relevant period here would have

 

23 been in the early to mid ‘90s.

 

24 Q. And at that time Mr. Cannon was practicing

 

25 with you?

 

26 A. He was associating with me on certain cases.

 

27 Q. And do you recall where Mr. Cannon was

 

28 residing at that particular point in time? 4951

 

 

 

1 A. I believe he was living in Santa Barbara.

 

2 Q. Now, at some later time, did Mr. Cannon

 

3 leave your association and take up the practice of

 

4 law somewhere else?

 

5 A. Yes.

 

6 Q. To your knowledge, where was that?

 

7 A. In Oregon.

 

8 Q. And then after that, did Mr. Cannon come

 

9 back?

 

10 A. He came back to San Luis Obispo County, and

 

11 then moved to San Diego County.

 

12 Q. And at this particular point in time, do you

 

13 know where Mr. Cannon is?

 

14 A. Not exactly this moment. But I happen to

 

15 know that he bought a condominium here in Orcutt.

 

16 Q. And is he, once again, associated with you

 

17 in the practice of law?

 

18 A. Yes, sir.

 

19 Q. Now, did you have occasion to represent

 

20 Jason Francia in some litigation?

 

21 A. He and his mother, yes.

 

22 Q. And can you tell us, did you ever prepare a

 

23 lawsuit on behalf of Jason Francia?

 

24 A. We prepared a Complaint, which is a document

 

25 that’s the beginning of a lawsuit, yes.

 

26 Q. And when you say “we,” who’s “we”?

 

27 A. Mr. Cannon and myself.

 

28 Q. So Mr. Cannon was working with you on that 4952

 

 

 

1 particular case?

 

2 A. Yes, sir.

 

3 Q. And after the preparation of that

 

4 document -- well, with regard to that document, what

 

5 were the allegations set forth in the proposed

 

6 Complaint to be filed?

 

7 A. Well, it’s been --

 

8 MR. MESEREAU: Objection. Hearsay;

 

9 relevance.

 

10 THE COURT: Sustained.

 

11 Q. BY MR. SNEDDON: Who was the individual that

 

12 the Complaint was directed towards?

 

13 A. Mr. Jackson.

 

14 Q. At some point in time, did you have contact

 

15 with individuals who were representing Mr. Jackson

 

16 over the proposed filing of the criminal -- of the

 

17 civil complaint?

 

18 A. Yes.

 

19 Q. And who did you make contact with?

 

20 A. Initially our contacts were with Johnnie

 

21 Cochran and his associate, Carl Douglas.

 

22 Q. Do you recall approximately when it was when

 

23 you first made contact with Mr. -- or when contact

 

24 was made between you and Mr. Cochran and Mr.

 

25 Douglas?

 

26 A. It was either late ‘94 or early ‘95.

 

27 Q. Did you, after your conversations with those

 

28 individuals, file the civil lawsuit? 4953

 

 

 

1 A. No.

 

2 Q. At some point in time later, were you then

 

3 dealing with other lawyers with regard to the

 

4 proposed filing of that civil lawsuit?

 

5 A. Yes. At some point, Mr. Jackson’s

 

6 representation was assumed by a lawyer named Zia

 

7 Modabber, and a lawyer named Howard Weitzman.

 

8 Q. And do you recall approximately when it was

 

9 that you then began contact with those particular

 

10 individuals?

 

11 A. I believe it was in mid 1995.

 

12 Q. And the purpose of those contacts?

 

13 A. Well, the --

 

14 MR. MESEREAU: Objection. Vague;

 

15 foundation.

 

16 THE COURT: Overruled.

 

17 You may answer.

 

18 THE WITNESS: The purpose of the contacts

 

19 was that they knew that we had a Complaint that we

 

20 were about to file in Santa Barbara County Superior

 

21 Court, and they didn’t want us to do that.

 

22 MR. MESEREAU: Objection. Hearsay;

 

23 foundation.

 

24 THE COURT: The answer is stricken.

 

25 Sustained.

 

26 Q. BY MR. SNEDDON: As a result of the

 

27 conversations between these individuals, did you

 

28 pursue your lawsuit? 4954

 

 

 

1 A. Well, we never filed the lawsuit.

 

2 Q. Did you reach an agreement, a settlement

 

3 agreement?

 

4 A. Yes, we did.

 

5 Q. Did you reach a settlement agreement in

 

6 which Jason Francia received monetary compensation

 

7 from Mr. Jackson?

 

8 A. Yes, sir.

 

9 Q. Did you receive -- did you reach an

 

10 agreement in which Blanca Francia received monetary

 

11 compensation from Mr. Jackson?

 

12 A. Yes, we did.

 

13 Q. During the time that you were

 

14 representing -- during the time that you had

 

15 prepared a Complaint ready to be filed and you were

 

16 in contact with attorneys representing Mr. Jackson,

 

17 can you give the ladies and gentlemen of the jury an

 

18 idea of how old Jason Francia was at that particular

 

19 point in time?

 

20 A. Well, he was about 14 years old. He’s 24

 

21 now, as I understand it, and we’re talking about

 

22 things that happened just about exactly ten years

 

23 ago.

 

24 Q. And in your position as a civil litigator,

 

25 at the time that an individual is of minority, at

 

26 the age of 14, how do you deal with representing a

 

27 person like that?

 

28 A. Well, a child -- 4955

 

 

 

1 MR. MESEREAU: Objection. Vague;

 

2 foundation; relevance.

 

3 THE COURT: Overruled.

 

4 You may complete your answer.

 

5 THE WITNESS: A child, under California law,

 

6 under the age of 18, is not permitted to enter into

 

7 a contract. I suppose he or she could, but it

 

8 wouldn’t be enforceable. So the only way a child

 

9 can act legally is through a guardian ad litem. And

 

10 it’s normally the parent and normally the mother.

 

11 Q. BY MR. SNEDDON: Was that the case in this

 

12 particular instance?

 

13 A. Yes.

 

14 Q. Now, during the course of the time that you

 

15 were involved in obtaining a settlement from Mr.

 

16 Jackson on behalf of the Francias, did you deal

 

17 personally with Jason at any time?

 

18 A. Yeah. Sure.

 

19 Q. In what respect?

 

20 A. Well, I knew who he was, I met with him. I

 

21 met with he and his mom. He was a teenaged boy, and

 

22 a nice young man.

 

23 Q. Now, at some point in time was Jason

 

24 required to sign some kind of documents in

 

25 conjunction with the settlement?

 

26 A. Yes. When he turned 18, part of the

 

27 condition was that he sign a confidentiality

 

28 agreement. 4956

 

 

 

1 Q. Now, with regard to the confidentiality --

 

2 and to your knowledge, did he sign that?

 

3 A. Yes.

 

4 Q. And with regard to the confidentiality

 

5 agreement, did it have a provision that required

 

6 notice to Mr. Jackson in the event that Jason

 

7 Francia talked to anybody?

 

8 MR. MESEREAU: Objection. Leading; move to

 

9 strike.

 

10 THE COURT: Overruled.

 

11 You may answer.

 

12 THE WITNESS: I believe so, yes.

 

13 Q. BY MR. SNEDDON: And what was the

 

14 requirement notice in the confidentiality agreement

 

15 with regard to notice to the defense?

 

16 A. I believe it’s five days.

 

17 Q. And were you at some point contacted by Mr.

 

18 Zonen of our department with regard to interviewing

 

19 your -- Jason Francia?

 

20 A. Yes.

 

21 Q. And in that particular case, did you

 

22 indicate to Mr. Zonen that you would have to do

 

23 something before you could agree with that?

 

24 A. Yes.

 

25 Q. And what was that?

 

26 A. Well, I’d have to notify somebody on Mr.

 

27 Jackson’s legal staff that they wanted to talk to

 

28 him. 4957

 

 

 

1 Q. And did you do that?

 

2 A. Yeah. Yes. Excuse me.

 

3 Q. And did you then grant permission for Mr.

 

4 Zonen to have a conversation with your -- with Jason

 

5 Francia?

 

6 A. Yes.

 

7 Q. Now, were you present during the

 

8 conversations between Jason Francia and Mr. Zonen?

 

9 A. I don’t think so. I think I was there, and

 

10 then I think I had to go to another court or

 

11 something like that. I don’t remember being an

 

12 integral part of any of those -- if there was more

 

13 than one, I don’t even know.

 

14 Q. And I’m talking about the conversations that

 

15 occurred after you gave notice to the defense in

 

16 this case, or gave notice to Mr. Jackson. To your

 

17 knowledge, was Mr. Cannon present?

 

18 A. I believe so. At least for part of it.

 

19 Again, I’m not certain.

 

20 Q. Do you remember when it was that you

 

21 finally -- the year that you finally reached a

 

22 settlement agreement with Mr. Jackson?

 

23 A. Yes. It’s been a long time. But it was a

 

24 big deal. And I do remember --

 

25 MR. MESEREAU: Objection. Nonresponsive;

 

26 move to strike.

 

27 THE COURT: The answer is stricken.

 

28 Nonresponsive. 4958

 

 

 

1 Q. BY MR. SNEDDON: Just --

 

2 A. Yes.

 

3 Q. And what year was that, approximately?

 

4 A. It was either ‘95 or ‘96, I believe.

 

5 THE COURT: Counsel, we’ll take our break.

 

6 (Recess taken.)

1 THE COURT: Counsel?

 

2 MR. SNEDDON: Your Honor, I’ve just about

 

3 completed my examination. But I would request if we

 

4 could approach the bench for just one second. I

 

5 don’t want to run afoul of the Court.

 

6 THE COURT: All right.

 

7 (Discussion held off the record at sidebar.)

 

8 THE COURT: (To the jury) All right. Knock

 

9 it off.

 

10 (Laughter.)

 

11 THE COURT: Okay. Counsel, you may proceed.

 

12 MR. SNEDDON: All right.

 

13 Q. Mr. Kallman, I think I just have a couple

 

14 questions left.

 

15 I think where we were headed before the

 

16 break was you told us the approximate year in which

 

17 the case actually reached a settlement.

 

18 And what I wanted to know was, after the

 

19 settlement of the case, have you kept in contact

 

20 with Jason over the years?

 

21 A. Yes.

 

22 Q. And to your knowledge, has Mr. Cannon kept

 

23 in contact with Jason over the years?

 

24 A. I believe so.

 

25 Q. Now, with regard to the lawsuit that was

 

26 contemplated against Mr. Jackson at the time, the

 

27 basis of the -- of the nature of the representation

 

28 of Jason Francia involved inappropriate sexual 4965

 

 

 

1 conduct against Jason by the defendant, Mr. Jackson?

 

2 A. Yes.

 

3 MR. SNEDDON: Nothing further, Your Honor.

 

4 THE COURT: Cross-examine?

 

5 MR. MESEREAU: Yes, please. Your Honor.

 

6

 

7 CROSS-EXAMINATION

 

8 BY MR. MESEREAU:

 

9 Q. Good morning, Mr. Kallman.

 

10 A. Good morning.

 

11 Q. My name is Thomas Mesereau and I speak for

 

12 Mr. Jackson.

 

13 A. Pleasure to meet you.

 

14 Q. I want to ask you some questions about the

 

15 settlement agreement you referred to in response to

 

16 the prosecutor’s questions, okay?

 

17 First of all, you had separate settlement

 

18 agreements for the mother, Blanca Francia, and the

 

19 son, Jason Francia, correct?

 

20 A. I believe so. I can tell you, I have not

 

21 reviewed this material and it’s been ten years, but

 

22 I believe that was the case. Some of this I’m going

 

23 to have to take your word for it.

 

24 Q. Well, I can show you a copy if you need it.

 

25 A. I don’t disbelieve that.

 

26 Q. Okay. The settlement agreement with Blanca

 

27 Francia was entered into approximately April 1st,

 

28 1996, right? 4966

 

 

 

1 A. I don’t know.

 

2 Q. Would it refresh your recollection if I show

 

3 you a copy of the agreement?

 

4 A. Sure.

 

5 MR. MESEREAU: May I approach, Your Honor?

 

6 THE COURT: Yes.

 

7 THE WITNESS: That’s what it says.

 

8 Q. BY MR. MESEREAU: The settlement agreement

 

9 with Jason Francia was entered into approximately

 

10 June 1st, 1998, right?

 

11 A. Don’t know.

 

12 Q. Would it refresh your recollection if I just

 

13 show you a copy of it?

 

14 A. Sure.

 

15 MR. MESEREAU: May I approach, Your Honor?

 

16 THE COURT: Yes.

 

17 THE WITNESS: That’s what it says.

 

18 Q. BY MR. MESEREAU: Okay. Now, that would

 

19 suggest, wouldn’t it, that the mother had agreed to

 

20 get money for herself before there was any agreement

 

21 for Jason to get money in a settlement, right?

 

22 A. No, it was all part of one global

 

23 settlement.

 

24 Q. Then why would there be a two-year

 

25 difference between the execution of those settlement

 

26 agreements?

 

27 A. Remember when I told the jury that a minor

 

28 can’t enter into a contract? 4967


 

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