Search Warrants: Re: Dr. Conrad Murray Manslaughter Charges
Search Warrants: Re: Dr. Conrad Murray Manslaughter Charges
Your Affiant, Daniel Myers, requests that the following portion of the Search Warrant Affidavit /
Statement of Probable Cause be ordered sealed by the Magistrate in order to implement the privilege
under Evidence Code Sections 1040 to 1042 and to protect the identity of any confidential
informant(s) and/or official information, pursuant to the Supreme Court decision in People v. Hobbs
(1994) 7 Cal. 4th 948, and California Rule of Court Rule 243.1, subd. (d).
If any of the information within the requested sealed portion of the Affidavit / Statement of Probable
Cause is made public, it will reveal or tend to reveal the identity of any confidential informant(s), impair
further related investigations and/or endanger the life of the confidential informant(s). ^
••.
of my
-n
ORDER
x -.
Based upon a review of the Search Warrant Affidavit this court finds that there exists an overriding
interest that overcomes the right of public access to the record; the overriding interest supports
sealing the record; a substantial probability exists that the overriding interest will be prejudiced if the
record is not sealed; the proposed sealing is narrowly tailored; an no less restrictive means exist to
achieve the overriding interest.
Therefore it is ordered that the following portion of the Search Warrant Affidavit / Statement of
Probable Cause identified as the "Confidential' Attachment" be sealed and kept in the custody of the
Affiant's law enforcement agency and not be made part of the public record until further order of this
court or any competent court.
Judge of the Superior Court of California, County of Los Angeles, Central District, Dept.
CHAFMLAfNE F. OLMEDO
( Printed Name of Magistrate)
I further swear that this is a true and detailed account of all the property taken by me pursuant to
the search warrant, and that pursuant to Penal Code Sections 1528 and 1536 this property will
be retained in my custody, subject to the order of this court or of any other court in which the
offensejn respect to which the seized property is triable.
(Signature of Affiant)
istrate).
(SEARCH WARRANT)
THE PEOPLE OF THE STATE OF CALIFORNIA TO ANY PEACE OFFICER IN THE COUNTYpF^)S ANGELES-
proof by affidavit, having been this day made before me by Peace Officer Daniel Myers that the«e^s pfSbable cause to
believe that the property or person described herein may be found at the location(s) set forth hereirK|ndifiat it is lawfully
seizable pursuant to Penal Code Section 1524 et seq., as indicated below by "[>3"(s), in that: '"', ^ c°
|~l property was stolen or embezzled; * .-*> —
[>3 property or things were used as the means of committing a. felony; ,.*&, '^t\3 property
or in the possession of another to whom he or she may have delivered them for the purpose of concealing-fhern'or preventing
their being discovered; &•' *~>
^ property or things to be seized consist of any item or constitute any evidence that tends to show a felony fils^been ppmmitted
or tends to show that a particular person has committed a felony; r;,S ^-)
[~~l property or things to be seized consist of evidence that tends to show that sexual exploitation of a child, in '^ptotion of Section
311.3, or possession of matter depicting sexual conduct of a person under the age of 18 years, in violation of "Section 311.11
has occurred or is occurring;
I | there is a warrant to arrest a person;
f~] a provider of electronic communication service or remote computing service has records or evidence, as specified in Section
1524.3, showing that property was stolen or embezzled constituting a misdemeanor, or that property or things are in the
possession of any person with the intent to use them as a means of committing a misdemeanor public offense, or in the
possession of another to whom he or she may have delivered them for the purpose of concealing them or preventing their
discovery;
Q property or things to be seized include an item or any evidence that tends to show a violation of Section 3700.5 of the Labor
Code, or tends to show that a particular person has violated Section 3700.5 of the Labor Code;
You are Therefore COMMANDED to SEARCH: (premises, vehicles, persons)
See page Two
AND TO SEIZE IT / THEM IF FOUND and bring it / them forthwith before me, or this court, aHhe-eourttiouse of this
court. This Search Warrant, apd. Affidavit andattachjecLand incorporated Affjdaiu^ were sworn to as true and
subscribed before me on this Joi±aay of NO^y^^^^n, at Y-2VA.M. / Wherefore, I find probable
cause for the issuance of this Search Warrant and do issue it.
SEARCH WARRANT for AFFIDAVIT doc - revised 04-22-2006 MLV Search Warrant CR/DR #
Page 1 of 1
.0
STATE OF CALIFORNIA - COUNTY OF LOS ANGELES page 2 of 7
Pursuant to Title 18 United States Code Section (USC §§) 2703(c) (1) (b), 2703(c), 2703(d), 3122, 3123
10 it is hereby granted that the Custodian of Records: Google (Gmail); located at, 1600 Amphitheatre
11 Parkway, Mountain View, California, 94043, furnish all information, records, and technical assistance
12 necessary to release any and all Gmail (Google ) accounts for the screen name,
13
14 whether the account is current or terminated, to include contents of all e-mails (sent or received), in
15 electronic storage, instant message conversations, histories, internet protocol addresses buddy lists,
16 profiles, subscriber information, method of payment and credit information, as well as detailed billing logs
17
(log on & log off times), as well as, but not limited to name(s) of the customer(s), any information used by
18
the customer to establish a Gmail (Google) account including customer name(s), address(es), telephone
19
number(s), credit information including any identifying numbers such as Driver's license number(s) and
20
Social Security number(s), for the time period of 05/01/2009 through 09/01/2009.
21
hi addition, provide certified copies of customer service records, on-line usage time and connection
22
information, also for the time period of 05/01/2009 through 09/01/2009. hi the event the subscriber has '
23
been terminated, provide the last known customer information. Provide any and all of the above requested
24
information for additional Gmail(Google) screen names belonging to the same account. It is hereby
25
26
SW&A1
STATE OF CALIFORNIA - COUNTY OF LOS ANGELES Pa9e 3 of 7
SEARCH WARRANT AND AFFIDAVIT
ordered that the Custodian of Records: Gmail (Google), be provided with a copy of this order ordering
and ratifying compliance with and, in accordance with, Title 18, United States Code(U.S.G), 2703(d.)
Pursuant to 18 USC §§ 2703(c)(l)(B), 2703(c), and 2703(d), this court may order a provider of an
electronic communication service doing business in California to disclose the records listed above to an
officer who has established reasonable grounds to believe said records are relevant and material to an
ongoing criminal investigation. Affiant has filed with this court an affidavit containing specific and
articulable facts establishing probable cause to believe the listed records are relevant and material to an
1° Probable Cause having been shown, IT IS FURTHER ORDERED, pursuant to CA Penal Code 629.66,
that this Search Warrant be sealed until otherwise ordered by the court, that the identity of any target(s)
12
of the underlying criminal investigation may be redacted from any copy of this Search Warrant to be
13
served on any service provider or other person, and that the local, long distance and wireless carriers
14
and their representatives, agents and employees shall not disclose in any manner, directly or indirectly,
15
by any action or inaction, the existence of this Search Warrant or the existence of the above-described
16
investigation, to the subscriber, any account holder and/or account user, or to any other person, in full
17
or redacted form, unless or until otherwise ordered by the court. Affiant's declaration has established
18
grounds for a non-disclosure order pursuant to TitlelS USC § 2705(b).
STATE OF CALIFORNIA - COUNTY OF LOS ANGELES Page4of 7
SEARCH WARRANT AND AFFIDAVIT
1 II Statement of Expertise
2 || Your affiant is Detective Daniel Myers, Serial No. 25735. Your affiant is employed by the Los
3 || Angeles Police Department and has been so employed for the past twenty two years. Your affiant
has had cause to be involved in the criminal investigations of numerous crimes relating to
5 || homicides, assaults, robberies and other types of criminal activity. Your affiant has been a homicide
g || investigator for the past fifteen years. Your affiant has been the primary investigator in over 150
homicides. Your affiant is currently assigned to Robbery Homicide Division, Homicide Special
8 Section and is responsible for gathering and identifying information of criminal activity relating to
9 homicides and death investigations. This includes interviewing witnesses, identifying modus
10 operandi (M.O.) to one particular individual or group of individuals, compiling and showing
photographic line-ups, the interrogation of suspects and the collection of or directing of the
-J2 collection of various types of physical evidence.
15 II UCLA Medical Center. Los Angeles Police Department (LAPD) Robbery-Homicide Division (RHD)
16 II was assigned the investigation into Jackson's death. Pursuant to the investigation, RHD detectives
17 II conducted multiple interviews and collected numerous items of evidence which formulated probable
18 II cause to believe that Doctor Conrad Murray was responsible for the death of Michael Jackson.
19
Based upon this probable cause, on July 27, 2009, the Honorable Judge Timothy C. Williams, Clark
20 County Superior Court, Nevada, issued a search warrant for DR. MURRAY'S business address, "Global
21 Cardiovascular Associates" 2110 East Flamingo, unit number 301, Clark County, Las Vegas Nevada, and
23 Vegas Metro Police Department (LVMPD), Drug Enforcement Administration (DBA) and LAPD RHD
24 officers served the search warrant at the business and home addresses for items including ''Records,
25 shipping orders, distribution lists, and use records relating to the purchase, transfer, receiving, ordering,
26 delivery and storage ofPROPOFOL (DIPRWAN). " During the search, LAPD Detective Smith, Serial
SW&A1
STATE OF CALIFORNIA - COUNTY OF LOS ANGELES Pa9e 5 of 7
SEARCH WARRANT AND AFFIDAVIT
No. 25301, recovered a sales receipt from "Applied Pharmacy Services," located at 6370 W. Flamingo
Road, Suite number T, Las Vegas, NV, to "Conrad MURRAY, MD, Global Cardiovascular Assoc." at
2110 East Flamingo Road, suite number 201. The receipt detailed on May 12,2009, MURRAY
purchased four (4) 100ml vials of PROPOFOL 10ML/ML SDV lOxlOOML, one (1) 100ml vial of
PROPOFOL 10ML/ML VL 25x20ML, two (2) vials of MIDAZOLAM IMG/ML VIAL 10/2 ML, one (1)
vial FLUMAZENIL 0.1 MG/ML VL 10x5ML and one (1) LIDOCAINE 2% cream. There was a separate
$65 charge for overnight Federal Express (Fed Ex) of the purchased items to DR. MURRAY to an
8 unknown destination.
DBA Agents were tasked with attempting to track the origin, route and possessor of the PROPOFOL
10 (DIPRIVAN) bottles found at the JACKSON residence. On August 4, 2009, DEA agents notified your
11 affiant's partner, Detective O. Martinez, Serial No. 31124 that PROPOFOL (DIPRTVAN) bottles found
12 during the search of Jackson's residence and in DR. MURRAY'S personal medical bag showed Teva, Inc.
13 as the manufacturer for the 20ml bottles and Hospira, Inc. for the 100ml bottles. DEA sent requests for
14 shipment records for all bottles possessing the same lot numbers to both manufacturers: From the records
15 received from the manufacturers, additional record requests were made by DEA to each distributor Teva
16 and Hospira had sold to. DEA received records of sales from these distributors as well. A subsequent
17
review of records received by DEA from the distributors showed sales to Applied Pharmacy Services for
18 both 20ml and 100ml bottles with the corresponding lot numbers.
19
The searches at DR. MURRAY'S residence and business failed to yield any notes, patient profiles,
20
treatment history, records, and charts regarding the treatment for MICHAEL JOSEPH JACKSON at his
22
On August 7, 2009, the Honorable Judge Timothy C. Williams, Clark County Superior Court,
23
Nevada, issued a search warrant for APPLIED PHARMACY SERVICES, located at 6370 West Flamingo
24 Road, suite 1, Las Vegas Nevada. On August 11, 2009, Las Vegas Metro Police Department (LVMPD),
25 Drug Enforcement Administration (DEA) and LAPD RHD officers served the search warrant at the
26 business address. LAPD RHD and your affiant recovered several purchase invoices and receipts from the
SW&A1
STATE OF CALIFORNIA - COUNTY OF LOS ANGELES Page 6 of 7
3 from APPLIED PHARMACY SERVICES. A check of their Federal Express account showed the
4 delivery addresses for the purchases to be either to DR. MURRAY'S office in Las Vegas or to a NICOLE
5 ALVAREZ at
6 On September 24 & 25, 2009, NICOLE ALVAREZ appeared before the Los Angeles County Grand
8 She also advised the court she utilized the Gmail (Google) e-mail account with the screen name of
10 born March 2, 2009. During the course of the investigation your affiant also learned that DR.
11 MURRAY made numerous telephone calls to NICOLE ALVAREZ leading up to and including the day
12 JACKSON died. Your affiant believes that MURRAY may have communicated the aforementioned
13 shipments with ALVAREZ via her Gmail (Google) account under the screen name of
14 During the investigation your affiant discovered DR MURRAY owned
15 and utilized an Apple IPhone to send and receive real time e-mails and messages.
16
On August 27, 2009, the Los Angeles County Coroner's Office determined the cause of death to be
17
Acute Propofol Intoxication, with a benzodiazepine effect. The manner of death was ruled a homicide.
18
Based on the aforementioned information, your affiant believes reviewing NICOLE ALVAREZ'S e-
19
mails may reveal additional shipments of Propofol and other medications not already known.
20
Furthermore the e-mails may establish chain of custody of the shipments. The e-mails may also
21
identify and or establish any aiders or abettors in the death of Michael Jackson. Because there are
22
reasonable grounds to believe that such information is relevant and material to the ongoing
23
investigation, I request the Search Warrant authorizing the release of all e-mails (sent or received),
24
instant message conversations, histories, internet protocol addresses buddy lists, profiles, subscriber
25
information, method of payment and credit information, as well as detailed billing logs (log on & log off
26
SW&A1
STATE OF CALIFORNIA - COUNTY OF LOS ANGELES Pa9e 7 °f 7
establish a Gmail (GOOGLE) account including customer name(s), address(es), telephone number(s),
credit information including any identifying numbers such as Driver's license number(s) and Social
Based on the information provided in this affidavit, I believe that the disclosure of the requested Search
Warrant may result in the flight from potential prosecution or the destruction of or tampering with
evidence, or may otherwise seriously jeopardize the investigation. Therefore, pursuant to California
Penal Code Section 629.66,1 further request that the court Seal this record and direct the Custodian of
Records: Gmail (Google) Legal Compliance Manager, filed concurrently herewith, and their
representatives, agents and employees, not to disclose in any manner, to the listed subscribers, or to any
other person, the existence of this Order, in full or redacted form, or of this investigation unless
12
otherwise ordered by this court.
13
Pursuant to California Evidence Code Sections 1040 to 1042, and to protect the identity of any official
14
information, pursuant to the Supreme Court decision in People v. Hobbs, (1994) 7 Cal. 4 948, your
affiant also respectfully requests that this search warrant, affidavit and all documents relating to this
search warrant be sealed to maintain the integrity of the investigation. Your affiant also requests that they
remain sealed and in the custody of the clerk of the court until order of this court or other competent court
18
having jurisdiction over this matter. Disclosure of these documents would compromise the ongoing
19
investigation into the death of JACKSON and would jeopardize the integrity of the investigation and give
20
the targets opportunity to hide, destroy and/or alter other material evidence.
21 "
22
23
24
25
26
SW&A1
STATE of CALIFORNIA, COUNTY of LOS ANGELES,
Your Affiant, Peace Officer Orlando Martinez, relates that this Search Warrant sought pursuant to
this Search Warrant / Affidavit, Statement of Probable Cause and the Return to Search Warrant and
all documents relevant to this Search Warrant relate to an on-going Death Investigation. It is
expected that additional Search Warrants will be sought relating to this matter. If information
contained in the above listed documents is made public, it would compromise this investigation and
make it impossible to continue.
.Your Affiant requests that the Search Warrant / Affidavit, Statement of Probable Cause and the
Return to Search Warrant and all documents relating to this Search Warrant be ordered to be sealed.
And that the Search Warrant / Affidavit, Statement of Probable Cause and the Return to Search
Warrant and all documents relating to this Search Warrant remain sealed and in the custody of the
clerk of the court until order of this court or other competent court having jurisdiction over this matter.
I declare under penalty of perjury that the related foregoing is true and correct to the best of my
knowledge.
(Signature of Affiant)
ORDER
Based upon the foregoing Declaration and Request and a reading of the original Affidavit, Search
Warrant, Statement of Probable Cause, and the Return to Search Warrant thereof referred to above, it
is hereby ordered that the Affidavit, Search Warrant, Statement of Probable Cause and the Return to
Search Warrant thereof, be sealed and maintained in a secure location in the custody of the clerk of
the court until further order of this court or other competent court having jurisdiction over this matter.
1u5**HSKf~~ *•*
SWNo.
STATE OF CALIFORNIA - COUNTY OF LOS ANGELES
55
The above listed items were retained by the Los Angeles County Coroner's office.
7V*r-
70
I further swear that this is a true and detailed account of all the property taken by me pursuant to
the search warrant, and that pursu^pnb^na^Code Sections 1528 and 1536 this property will
be retained in my custody, subje^t^tjg^j&i^V this court or of any .other court in which the
offense^'n res&ect to which the s/i^djjffifiDMmte&teble.
(SEARCH WARRANT)
THE PEOPLE OF THE STATE OF CALIFORNIA TO ANY PEACE OFFICER IN THE£COUN?Y OF LOS ANGELES:
proof by affidavit, having been this day made before me by Peace Officer Orlando Martinez thatgfeere is probable cause to
believe that the property or person described herein may be found at the location(s) set ftrth herein and that it is lawfully
seizable pursuant to Penal Code Section 1524 et seq., as indicated below by "E3" (s) in that:
|~l property was stolen or embezzled; ; j—» j
property or things were used as the means of committing a felony;
D property or things are in the possession of any person with the intent to use them as means of committing gpublic Mense, or in the
possession of another to whom he or she may have delivered them for the purpose of concealing them or pfgi/enting their being
discovered;
property or things to be seized consist of any item or constitute any evidence that tends to show a felony hiPbeen committed, or tends
to show that a particular person has committed a felony; £ _r~_
property or things to be seized consist of evidence that tends to show that sexual exploitation of a child, inffltolation of Section 311.3, or
possession of matter depicting sexual conduct of a person under the age of 18 years, in violation ofSection 311.11, has occurred or is
occurring;
there is a warrant to arrest a person;
D a provider of electronic communication service or remote computing service has records or evidence, as specified in Section 1524.3,
showing that property was stolen or embezzled constituting a misdemeanor, or that property or things are in the possession of any
person with the intent to use them as a means of committing a misdemeanor public offense, or in the possession of another to whom
he or she may have delivered them for the purpose of concealing them or preventing their discovery;
D property or things to be seized include an item or any evidence that tends to show a violation of Section 3700.5 of the Labor Code, or
tends to show that a particular person has violated Section 3700.5 of the Labor Code;
YOU are Therefore COMMANDED to SEARCH: (premises, vehicles, persons)
The residence, curtilage and appurtenant structures located at 100 N. Carolwood Drive, in the city of Los Angeles. The
location is described as a multi-level single family dwelling on the east side of Carolwood Drive. The location is surrounded
by a high wall, accessible via an electronic wrought iron gale. The numerals 100 are affixed to the mailbox and are painted on
the curb in front of the location.
Any vehicle, which can be reasonably associated with any resident or occupant of the location, via registration documents,
certificates of ownership, keys, bills of sale, motor vehicle repair or fuel receipts, insurance documents, moving or parking
citations, DMV or other government maintained computer records and similar notices.
AND TO SEIZE IT / THEM IF FOUND and bring it / pr tr)js court at the courthouse of this court. This
Search Warrant and .Affidavit and qrn to as true and subscribed before me on this
^ day of ff.t"$/fierefbre, I find probable cause for the issuance of
this Search Warranted do issue it. r '•'
U.KlG; APPROVED:
Cft APPROVED:
Judge of the , Dept.
6 for the Los Angeles Police Department for over fifteen years and is currently assigned to Robbery-
Homicide Division. Your affiant has worked in Homicide for eight years investigating murders
8 committed during the commission of robberies, gang related murders, narcotic related murders,
domestic dispute murders, murders for hire and other types of felony murders. Your affiant has
10 been assigned and investigated homicides in the Devonshire and Mission Areas of the Los Angeles
12
investigative responsibilities. In addition, your affiant has served in a Detective capacity since 1998
and became a Detective in March of 2001. Your affiant's investigative assignments have included
14 violent crimes against persons including assault with a deadly weapon and attempted murder, auto
15 theft and domestic violence. Prior to that, your affiant worked uniformed field investigation as well
. . , , . , . .
H'}., NMTvoiurs Division K'f^'ri r.ni<m:o!ni:»if Section i'FKSi. Oncrations Vaiicv jjureau auto
18
theft task force (CECAT), Devonshire area bicycle detail and the Devonshire Area Special Problems
19
Unit. Your affiant is a member in good standing of the California Homicide Investigator's
20 Association, has attended training seminars and has received training materials offered by this and
21 other professional organizations. Your affiant currently holds Basic and Intermediate certificates
22
awarded by the California Commission of Police Officers Standards and Training (POST). Your
23 affiant is fluent and can read and write in Spanish. Your affiant has personally prepared in excess of
SW&AI
STATE of CALIFORNIA, COUNTY of LOS ANGELES, Pa" 3 °'3
the medicines given to Jackson, was located in Jackson's residence, in the bedroom foyer, above the
3 closets closest to the bedroom where he was treating Jackson. Dr. Murray consistently left the bag at the
Your affiant respectfully requests that a search warrant be issued for the decedent's residence for the
purpose of locating the doctor's equipment and furthering the investigation into the cause of his death.
Your affiant believes there will be prescription medicines, controlled substances, notes, diagrams, logs,
8 journals, electronic memo devices, and computer storage devices, to include written and oral materials
9 inside the doctor's bag that would assist the investigators and coroner's office in the death investigation.
10 Your affiant also respectfully requests that this search warrant be sealed to maintain the integrity of the
12
14
15
ie|
17 I
18
19
20
21
22
23
SW & A1 I ^-
STATE of CALIFORNIA, COUNTY of LOS ANGELES,
Your Affiant, Peace Officer Orlando Martinez, relates that this Search Warrant sought pursuant to
this Search Warrant / Affidavit, Statement of Probable Cause and the Return to Search Warrant and
all documents relevant to this Search Warrant relateJo an on-going investigation of a Homicide. It is
expected that additional Search Warrants will be sought relating to this matter. If information
contained in the above listed documents is made public, it would compromise this investigation and
make it impossible to continue.
Your Affiant requests that the Search Warrant / Affidavit, Statement of Probable Cause and the
Return to Search Warrant and all documents relating to this Search Warrant be ordered to be sealed.
And that the Search Warrant / Affidavit, Statement of Probable Cause and the Return to Search
Warrant and all documents relating to this Search Warrant remain sealed and in the custody of the
clerk of the court until order of this court or other competent court having jurisdiction over this matter.
I declare under penalty of perjury that the related foregoing is true and correct to ,the be^Jof my
knowledc
ORDER
Based upon the foregoing Declaration and Request and a reading of the original Affidavit, Search
Warrant, Statement of Probable Cause, and the Return to Search Warrant thereof referred to above, it
is hereby ordered that the Affidavit, Search Warrant, Statement of Probable Cause and the Return to
Search Warrant thereof, be sealed and maintained in a secur£ location in the custody of the clerk of
the court until further order of this court or other competent court having jurisdiction over this matter.
Judge of the Superior Court of California, County of Los Angeles, r^/rTv^L-District. Dept.
SWNo.
STATE OF CALIFORNIA - COUNTY OF LOS ANGELES
Location2:
A champagne 2005 BMW 645CI, TX license numbe VIN:i
and seized the items*
^ described in the attached and incorporated inventory
-""D
r~| described below:
Co -1
further swear that this is a true and detailed account of all the property taken by me pursuant to
the search warrant, and that pursuant to Penal Code Sections 1528 and 1536 this proper
be retained m my custody subject to,the order of this court or of any other court in which
offenseyrn cespectlo whic/i the/eizeXproperty is triable.
Sworn toMagistrate)
s\e of and subscribed before me this [& day of
R-1
Las Angeles Police Department IF EVIDENCE CONT.. COMPLETE SHADED AREAS ONLY. IF NOT EVID. CONT., COMPLETE ENTIRE FORM.
PROPERTY REPORT TOTAL us. EVID NON-EVID IF RELATED TO PREV BKD EVID, USE THAT OR
CttKR. BKD.
Page , 1 of P
NARC
P
ONLY i CATeBORY PER REPORT
OR 09-0812997
DATE AND TIME OF THIS REPORT DATE PROPERTY BKD. IF RELATED TO PREVIOUSLY BOOKED EVIDENCE. ORIQ. EVID. BKD. TO DATE ORI6. EVID. TAKEN WTO CUSTODY
(IN THIS CASE COMPLETE ENTIRE REPORT) . . ... . , ,
08/13/2009 1245 08/13/2009 ' Jackson, Michael Joseph 06/25/2009
RESIDENCE ADDRESS AfiKESTEE; DOS CHARGE
BKD. DR
BKG. #
. ENSORE>iN-EXTRACOPriS
Wiasp3smoN.'.eipbTO™»To^^
ITIJ&WEJP^G^N*^^ '.'"..*%,•:':',, ,,. y;^',. :' . ' '
\"MM^Ua5v.S)2E,;lNSCljJp1iON; CALIBER, •ETC.'IFISlULT.-
Si -•••=•-
On August 13, 2009, LAPD RHD detectives served a search warrant al I in the city of The below listed items
were recovered pursuant to that warrant
INC #0906250051 10
10.01.00 (01/96)
PAGE LOS ANGELES POLICE DEPARTMENT
ADDRESS STREET
CHARGE
BOOKING NUMBER
tmt
(UfO
SERIAL NUMBER
THIS RECEIPT DOES NOT CONSTITUTE RECOGNITION OF LEGAL TITLE TO ABOVE PROPERTY
SIG6 FJ'ERSOC 3OSSESSION OF PROPERTY (OPTIONAL)
\
AN EWPtOYEE SEIZING OR TAKING CyrpSbY OF PROPERTY SHALL ISSUE A RECEIPT FOR PROPPRTV
INTO CUSTODY, FORM 10.10 (DUPLICforfcOPY), TO THE PERSON RELIEVED OF THE PROPERTYSol K««^'
THE ORIGINAL OF THE FORM 10.10 SHALL BE INCLUDED AS A PAGE! OF THE ORIGINAL OFTHE^nPPD^c^
FORM 10.1; NOTICE TO APPEAR / RELEASE FROM CUSTODY REPORT FORM 52ft-OPi ISUS?EfS^EPOR7:
5.2, WHEN EVIDENCE IS LISTED THEREON. ncru« i,. ^UHM 5.2.8, OR ARREST REPORT, FORM
70-10.10.0 (R.1/90)
PROPERTY RELEASE (OVER!
SWNO
STATE of CALIFORNIA, COUNTY of LOS ANGELES,
SEARCH WARRANT and AFFIDAVIT
(AFFIDAVIT)
Peace Officer Orlando Martinez, swears under oath that the facts expressed by him/her in the attached and incorporated Affidavit
are true and that based thereon he/she has probable cause to believe and does believe that the articles, property, and persons
described below are lawfully seizable pursuant to Penal Code Section 1524 et seq., as indicated below, and are now located at the
locations set forth below. V\0ierefore, Affiantjpquests that this Search Warrant be issued.
(SEARCH WARRANT)
THE PEOPLE OF THE STATE OF CALIFORNIA TO ANY PEACE OFFICER IN THE COUNTY OF LOS ANGELES:
proof by affidavit, having been this day made before me by Peace Officer Orlando Martinez that there is probable cause to
believe that the property or person described herein may be found at the location(s) set forth herein and that it is lawfully
seizable pursuant to Penal Code Section 1524 et seq., as indicated below by "E3" (s) in that:
property was stolen or embezzled;
LJ property or things were used as the means of committing a feiony;
D property or things are in the possession of any person with the intent to use them as means of committing a public offense, or in the
possession of another to whom he or she may have delivered them for the purpose of concealing them or preventing their being
discovered;
property or things to be seized consist of any item or constitute any evidence that tends to show a felony has been committed, or tends
to show that a particular person has committed a felony;
D property or things to be seized consist of evidence that tends to show that sexual exploitation of a child, in violation of Section 311.3, or
possession of matter depicting sexual conduct of a person under the age of 18 years, in violation of Section 311.11, has occurred or is
occurring;
D there is a warrant to arrest a person;
D a provider of electronic communication service or remote computing service has records or evidence, as specified in Section 1524.3,
showing that property was stolen or embezzled constituting a misdemeanor, or that property or things are in the possession of any
person with the intent to use them as a means of committing a misdemeanor public offense, or in the possession of another to whom
he or she may have delivered them for the purpose of concealing them or preventing their discovery;
D property or things to be seized include an item or any evidence that tends to show a violation of Section 3700.5 of the Labor Code, or
tends to show that a particular person has violated Section 3700.5 of the Labor Code;
YOU are Therefore COMMANDED to SEARCH: (premises, vehicles, persons)
See Page 2.
K*
CO
AND TO SEIZE IT / THEM IF FOUND and bring it / them forthwith before me, or this court, at the courthouse of this court. This
Search. Warrant and Affidavit and attached and incorporated Affidavit weresMnorn to as true and subscribed before me on this
(-5**- j-» ~f A* >/?- r -so- ft~^)Ci *t 2 - :lfcsrr2f*.v / D/I& \AVh,erefore, I find probable cause for the issuance of
this Search Warrant and d
ING APPROVED: YES PINO
APPROVED: DYES
, Dept..
paragraph. The officers are authorized, if necessary to remove the electronic storage devices from the
14 premises and conduct an off-site evidentiary search of the electronic storage devices.
15
16 LOCATION 2:
17 A champagne 2005 BMW 645CI, Texas license number! VIN:
18 currently registered to
19
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21
22
23
24
SW&A1 1 .*
STATE of CALIFORNIA, COUNTY of LOS ANGELES, PageSof
medicines, packages and letters including but not limited to received from APPLIED PHARMACY
4 SERVICES, were received, delivered, attempted delivery to NICOLE ALVAREZ, DR. CONRAD
6 CARDIOVASCULAR ASSOCIATES.
2) Packaging, invoices, mail orders, confirmation notices received from FEDERAL EXPRESS aka FED
8 EX, UNITED STATES POSTAL SERVICE, any other shipping/ delivery company regarding the
9
delivery of any prescription medications, medicines, packages and letters to NICOLE ALVAREZ,
I1 CARDIOVASCULAR ASSOCIATES.
12 3) Any bottles/vials of PROPOFOL (DIPRIVAN) including but not limited to the "lot numbers" of
313058858 and/or 76197DJ, including but not limited to bottles manufactured by Teva, Inc. aiid
Hospira Inc.
4) Any other medicines, including but not limited to BENOQUIN, MIDAZOLAM, FLUMAZENIL,
location.
5) Any electronic notices of delivery, attempted delivery, delivery dates, delivery confirmation,
invoices, purchase receipts, and credit card authorizations whether sent to personal or business email
other prescription or non prescription medicine from APPLIED PHARMACY SERVICES, or any
other pharmacy.
6) Prescriptions, patient profiles, medications, and correspondence, notations, logs, receipts, journals,
books, records and documents noting price, quantity, and/or times when prescription medications
were administered, prescribed, obtained, transferred, sold, distributed, and/or concealed to MICHAE^
SW&A1
STATE of CALIFORNIA, COUNTY Of LOS ANGELES, Pa" 4 »'
2 BRYAN SINGLETON, aka MIKE JACKSON, aka MICK JACKSON, aka MIC JACKSON, aka
3 JACK LONDON, aka MICHAEL AMIR WILLIAMS MUHAMMAD, aka JIMMY NICHOLAS, aka
4 BLANCA NICHOLAS, aka ROSELYN MUHAMMAD, aka PRINCE JACKSON, aka FAHEEM
5 MUHAMMAD, aka FRANK TYSON, aka FERNAND DIAZ, aka PETER MADONIE, aka
6 JOSEPHINE BAKER and aka KAI CHASE;
7) Notes, personnel records, telephone records, lists of names and records, telephone message pads,
g
appointment books, rolodexes, contracts, agreements, bills, invoices, receipts, photographs, calendars,
Q
diaries, cash receipts journals, cash disbursements journals, payroll journals, ledgers, reports,
writings, day planners and correspondence, telephone logs, doctor's notes, nurse's notes, payment
schedules, and personal notes and items regarding patient of MICHAEL JOSEPH JACKSON aka
12 OMAR ARNOLD, aka PAUL FARANCE, aka PAUL FARNCE, aka BRYAN SINGLETON, aka
MIKE JACKSON, aka MICK JACKSON, aka MIC JACKSON, aka JACK LONDON, aka
16 MUHAMMAD, aka FRANK TYSON, aka FERNAND DIAZ, aka PETER MADONIE, aka
17 JOSEPHINE BAKER and aka KAI CHASE;
1 ft
8) Word processors, electronic data processing and storage devices, computers and computer systems,
consisting of but not limited to; central processing units, internal and external peripheral storage
nr\s such as fixed disks, external hard disks, floppy disk drives and diskettes, tape drivesand
?1
tapes, optical storage devices, personal data assistants (PDA's), or other memory storage devices;
such as pagers, MP3 devices, compact flash and smart media cards, cellular telephones, and any and
all peripheral input/output devices such as keyboards, printers, video display monitors, optical readers
and related communication devices such as modems, acoustic couplers, telephone answering
machines, cameras, microphones, or any other capture device, printers, facsimile machine, together
along with system documentation, operating logs, documentation, software and instruction manuals
SW & A1
STATE of CALIFORNIA, COUNTY of LOS ANGELES, Page 5 of
3 JACKSON aka OMAR ARNOLD, aka PAUL FARANCE, aka PAUL FARNCE, aka BRYAN
4 SINGLETON, aka MIKE JACKSON, aka MICK JACKSON, aka MIC JACKSON, aka JACK
5 LONDON, aka MICHAEL AMIR WILLIAMS MUHAMMAD, aka JIMMY NICHOLAS, aka
6 BLANCA NICHOLAS, aka ROSELYN MUHAMMAD, aka PRINCE JACKSON, aka FAHEEM
7 MUHAMMAD, aka FRANK TYSON, aka FERNAND DIAZ, aka PETER MADONIE, aka
8 JOSEPHINE BAKER and aka KAI CHASE;
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9) Indicia of occupancy, residency or ownership of the premises, namely, utility bills, telephone bills,
loan payment receipts, mail, keys, rent receipts, trust deeds, lease or rental agreements, and escrow
documents;
1O
10) Any passwords, password files, test keys, encryption codes or other information necessary to access
the computer equipment, storage devices or data needed to garner access to computers or electronic
equipment at the locations;
11) Charts, associated laboratory workups and x-rays, payment records, and identification documents
16 related to patient MICHAEL JOSEPH JACKSON aka OMAR ARNOLD, aka PAUL FARANCE,
17 aka PAUL FARNCE, aka BRYAN SINGLETON, aka MIKE JACKSON, aka MICK JACKSON, aka
18 MIC JACKSON, aka JACK LONDON, aka MICHAEL AMIR WILLIAMS MUHAMMAD, aka
19 JIMMY NICHOLAS, aka BLANCA NICHOLAS, aka ROSELYN MUHAMMAD, aka PRINCE
!0 JACKSON, aka FAHEEM MUHAMMAD, aka FRANK TYSON, aka FERNAND DIAZ, aka
1 PETER MADONIE, aka JOSEPHINE BAKER and aka KAI CHASE;
12) Any correspondence, notes, writings, emails, letters, mail between the following persons and/or
3 entities; MICHAEL JOSEPH JACKSON aka OMAR ARNOLD, aka PAUL FARANCE, aka PAUL
* FARNCE, aka BRYAN SINGLETON, aka MIKE JACKSON, aka MICK JACKSON, aka MIC
JACKSON, aka JACK LONDON, aka MICHAEL AMIR WILLIAMS MUHAMMAD, aka JIMMY
NICHOLAS, aka BLANCA NICHOLAS, aka ROSELYN MUHAMMAD, aka PRINCE JACKSO:
SW&A1
STATE of CALIFORNIA, COUNTY of LOS ANGELES, fas>°6<*
device or media capable of digitally or magnetically storing data, found together or separately from one
another. Such systems also commonly include electronic cables linking computer systems to other systems
17 or telephone/coaxial lines and off site data storage locations.
SW&A1
STATE of CALIFORNIA, COUNTY of LOS ANGELES, Pase 7 °f
I 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:
fi I
I Your affiant, Detective Orlando Martinez, Serial No. 31124, has been a sworn police officer for the
Los Angeles Police Department for fifteen years and is currently assigned to Robbery-Homicide Division.
81 I
I Your affiant has worked in Homicide for eight years investigating murders committed during the
9 I
commission of robberies, gang related murders, narcotic related murders, domestic dispute murders,
I murders for hire and other types of felony murders. Your affiant has been assigned and investigated
I homicides in the Devonshire and Mission Areas of the Los Angeles Police Department. At Robbery-
12
Homicide Division, your affiant has city-wide homicide investigative responsibilities. In addition, your
affiant has served in a Detective capacity since 1998 and attained the rank of Detective in March of 2001.
Your affiant's investigative assignments have included violent crimes against persons, including assault
I with a deadly weapon and attempted murder, auto theft and domestic violence. Prior to that, your affiant
16 I
worked uniformed field investigation as well as specialized units. These specialized units included the
I Foothill Area gang suppression unit (CRASH), Narcotics Division Field Enforcement Section (FES),
*1 ft I
I Operations Valley Bureau auto theft task force (CECAT), Devonshire Area bicycle detail and the
Devonshire Area Special Problems Unit. Your affiant is a member in good standing of the California
Homicide Investigator's Association, and the International Homicide Investigator's Association. He has
attended training seminars and has received training materials offered by this and other professional
!2 organizations relating to homicide investigations, basic detectives skills, telephone technology, wiretaps,
!3 computer crimes, interviewing techniques and other types of criminal investigations. Your affiant
currently holds Basic and Intermediate certificates awarded by the California Commission of Police
Officers Standards and Training (POST). Your affiant has personally prepared in excess of 55 search
warrants and/or court orders. He has assisted in the execution of over 60 search warrants. Your affiant
SW & A1
STATE of CALIFORNIA, COUNTY of LOS ANGELES, Pa»e 8 °'
Narcotics Enforcement and the Los Angeles County Medical Examiner's Offices.
5 On June 25, 2009, at approximately 1426 hours, MICHAEL JOSEPH JACKSON was pronounced
e
dead at UCLA Medical Center. Los Angeles Police Department (LAPD) Robbery-Homicide Division
(RHD) was assigned to conduct the investigation into JACKSON's death. Several bottles of PROPOFOL
(DIPRIVAN) were recovered from JACKSON's residence with the same "lot" numbers. The lot numbers
Q
correspond to the manufacturers' date of production and shipping information. The bottles were
recovered from JACKSON's bedside and from DR. MURRAY'S personal medical bags.
Further investigation revealed that JACKSON was treated by at least 7 other doctors under the aliases
12 of OMAR ARNOLD, aka PAUL FARANCE, aka PAUL FARNCE, aka BRYAN SINGLETON, aka
MIKE JACKSON, aka MICK JACKSON, aka MIC JACKSON, aka JACK LONDON, aka MICHAEL
14 AMIR WILLIAMS MUHAMMAD, aka JIMMY NICHOLAS, aka BLANCA NICHOLAS, aka
15 ROSELYN MUHAMMAD, aka PRINCE JACKSON, aka FAHEEM MUHAMMAD, aka FRANK
16 TYSON, aka FERNAND DIAZ, aka PETER MADONIE, aka JOSEPHINE BAKER and aka KAI
17 CHASE. During the course of the investigation, RHD detectives conducted multiple interviews and
18 recovered numerous items of evidence which formulated probable cause to believe that DR. CONRAD
19 MURRAY was responsible for JACKSON's death under California Penal Code Section 192,
20
Manslaughter.
21 Based upon this probable cause, on July 27,2009, the Honorable Judge Timothy C. Williams, Clark
22 County Superior Court, Nevada, issued a search warrant for DR. MURRAY'S business address, "Global
23 Cardiovascular Associates" 2110 East Flamingo, unit number 301, Clark County, Las Vegas Nevada, and
24
25
Vegas Metro Police Department (LVMPD), Drug Enforcement Administration (DBA) and LAPD RHD
officers served the search warrant at the business and home addresses for items including "Records,
SW&A1
STATE of CALIFORNIA, COUNTY of LOS ANGELES, Pa^ 9 of
2 delivery and storage of PROPOFOL (DIPRIVAN). " During the search, LAPD Detective Smith, Serial
2
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. The receipt detailed on May 12, 2009, MURRAY
6 purchased four (4) 100ml vials of PROPOFOL 1OML/ML SDV 1 Ox 1OOML, one (1) 100ml vial of
7 PROPOFOL 1 OML/ML VL 25x20ML, two (2) vials of MIDAZOLAM 1MG/ML VIAL 10/2 ML, one (1)
8 vial FLUMAZENIL 0.1 MG/ML VL 10x5ML and one (1) LIDOCAINE 2% cream. There was a separate
Q
$65 charge for overnight Federal Express (Fed Ex) of the purchased items to DR. MURRAY to an
unknown destination.
DBA Agents were tasked with attempting to track the origin, route and possessor of the PROPOFOL
12 (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 and in DR.
MURRAY'S personal medical bag showed Teva, Inc. as the manufacturer for the 20ml bottles and
*••
5 Hospira, Inc. for the 100ml bottles. DEA sent requests for shipment records for all bottles possessing the
1 ft
same lot numbers 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 with the
The searches at DR. MURRAY'S residence and business failed to yield any notes, patient profiles,
!2 treatment history, records, and charts regarding the treatment for MICHAEL JOSEPH JACKSON at his
On August 7,2009, the Honorable Judge Timothy C. Williams, Clark County Superior Court,
Nevada, issued a search warrant for APPLIED PHARMACY SERVICES, located at 6370 West Flamingo
c
Road, suite 1, Las Vegas Nevada. On August 11, 2009, Las Vegas Metro Police Department (LVMPD),
SW& A1
STATE of CALIFORNIA, COUNTY of LOS ANGELES, Page 10 of
12
8
Your affiant respectfully requests that a search warrant be issued for the residence of NICOLE
g
10 the location will house information on any other/further transactions, deliveries or orders between DR.
11 MURRAY and APPLIED PHARMACY SERVICES or any other pharmacy for PROPOFOL
12 (DIPRIVAN) and the other listed drugs. The location may also contain DR. MURRAY'S missing medical
records regarding his treatment of JACKSON at the residence.
14 Based on the aforementioned information and investigation, your affiant believes ground for issuance
15 of a search warrant exists as set forth in Penal Code section 1524 because the items sought constitute
16
evidence which tend to show that a felony has been committed, and that a particular person has committed
17 a felony, that felony being PC 192, Manslaughter. Your affiant hereby prays that a search warrant be
18 issued for the seizure of said property or any part thereof, from said locations at any time of the day, good
19 „„„„*. u~;nrr oii«vum thfrofnrr: n«H thp. same be brnueht before this magistrate or retained subject to the
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STATE of CALIFORNIA, COUNTY of LOS ANGELES, Page 11 of
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SW&A1
STATE of CALIFORNIA, COUNTY of LOS ANGELES, Page 12 of
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SW& A1
SEARCH WARRANT
STATE OF NEVADA)
) ss: 6370 West Flamingo, Suite #1 LV, NV 89103
COUNTY OF CLARK)
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 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 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 III is written in blue letters on a white background.
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 STAGEY 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.
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, 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.
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
Sheriffs 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.
JO0GE
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,
\T IS HEREBY O
ordered sealed pending further order of this Court except that copies may be provided to the
office of the Clark County District Attorney, the Los Angeles Police Department and/or the Drug
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.
JUDGE
AFFIANT
STATE OF NEVADA)
) ss: 6370 West Flamingo, Suite #1 LV, NV 89103
COUNTY OF CLARK)
I, Detective S. Armbruster P#7327, being first duly sworn, deposes and states that he
is the affiant herein, and that he is a Police Officer with the Las Vegas Metropolitan
Police Department for approximately seven years. I am currently assigned to the
Narcotics Bureau, specifically to the Drug Enforcement Administration's Tactical
Diversion Squad.
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 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 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 III is written in blue letters on a white background.
*
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
employee thereof including but not limited to STAGEY 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 STAGEY 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.
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 ail
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.
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
committed in the state of California:
In support of your affiant's assertion to constitute the existence of probable cause, the
following facts are offered:
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 ail 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
(LAFD) 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 (RHD) Detectives Smith, Serial No.
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.
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 days
prior to his death, he 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 he was continuously at
JACKSON's bedside and was monitoring him with a pulse oximeter. According to DR.
MURRAY, the pulse oximeter was connected to JACKSON's finger and measured his
pulse and oxygen statistics.
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 discomfort. 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 CHERILYN 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 him 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 JACKSON requested him
to be his personal physician on the 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 breathing 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 the 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. Carplwood 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.
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.
They 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
MUHAMMAD, AND KAI CHASE On July 17 200Q H t *•
unknown fema/e caller who stated that shl hf H Vdete° Ives rec^ed a callfroman
JACKSON when he would vIsftDR KLEIN Sh<?n °^°n °n the allases «ed by
FERNAND DIAZ, PETER MADONI ^ JOSEPH^E BAKFTeS' OMAR ARNOL?
would use when seeing DR. KLEIN Detective Trtrn! JP R 3S names JACKSON
residence in the name of OMAR ARNotC/S ^" ^ JACKS°N>S
On July 24, 2009, the Honorable Judge Timothy C. Williams, Clark County District
Court issued s search warrant for DR. MURRAY'S business address, ;:Globai
Cardiovascular Associates" 2110 East Flamingo, unit number 301,_ CjarkjCpunty, Las
•Hft- On July 28, 2009, Las Vegas Metro Police Department. (LVMPD), Drug
Enforcement Administration (DEA) and Los Angeles Police Department (LAPD)
.Robbery-Homicide Division (RHD) officers served the search warrant at the business
and home addresses for items including "Records, shipping orders, distribution lists,
and use records relating to the purchase, transfer, receiving, ordering, delivery and
storage of PROPOFOL (DIPRIVAN)." LAPD detectives identified the employees of
Global Cardiovascular Associates as STAGEY 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 10ML/ML SDV 10x100ML, one (1)
100ml vial of PROPOFOL 10ML/ML VL 25x20ML, two (2) vials of MIDAZOLAM
1MG/ML VIAL 10/2 ML, one (1) vial FLUMAZENIL 0.1 MG/ML VL 10x5ML and one (1)
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 ID:JHMNM»,
Term ID: 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.
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 (DfPRJVAN) bottles found
during the search of Jackson's residence showed leva, 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 leva 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 PROPCFOL
(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).
Your affiant requests the items seized pursuant to this search warrant be
permitted for use by the Medical Board of California, Drug Enforcement Administration
and the California Department of Justice, Bureau of Narcotics Enforcement in any
possible administrative action taken to modify the 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.
AFFIANT
SUBSCRIBED and SWORN to before me this
day of August, 2009.
10
DE-1?fl
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name. State Bar number, and address): FOR COURT USE ONLY
Eric R. Adler, State Bar Number 194393
Magee & Adier
400 Oceangate
Suite 1030
Long Beach, CA 9 0 8 0 2
TELEPHONE NO.: 562.432.1001 FAX NO. (Optional): 562.432.1060
E-MAIL ADDRESS (Optional): e r i c @ma geeadler.com
ATTORNEY FOR (Name): Brian Nese, Petitioner
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles
STREET ADDRESS: 111 N. Hill St.
MAILING ADDRESS: 111 N. Hill St.
CITY AND ZIP CODE: Los Angeles, CA 90012
BRANCH- NAME: Central Disrict
i . >C ESTATE OF (Name): ! j IN THE MATTER OF (Name): IN RE NESE FAMILY TRUST
DATED AUGUST 2, 1 985 AS AMENDED BY THE FIRST AMENDMENT AND COMPLETE
RESTATEMENT ON APRIL 27, 2009 JLj DECEDENT I1V TRUST ;"._.. ".'... OTHER
CASE NUMBER:
NOTICE OF HEARING— DECEDENT'S ESTATE OR TRUST BP121589
2. You may refer to the filed documents for more information. (Some documents filed with the court are confidential.)
Assistive listening systems, computer-assisted real-time captioning, or sign language interpreter services are
available upon request if at least 5 days notice is provided. Contact the clerk's office for Request for
Accommodations by Persons With Disabilities and Order (form MC-410). (Civil Code section 54.8.)
* Do not use this form to give notice of a petition to administer estate (see Prob. Code, § 8100 and form DE-121) oT
notice of a hearing in a guardianship or conservatorship (see Prob. Code, §§1511 and 1822 and form GC-020)
Page 1 of 2
Form Adopted for Mandatory Use
Judicial Council of California
NOTiCE OF HEARING—DECEDENT'S ESTATE OR TRUST o Legal P-o&aie Code S§ 851 1211
DE-120(Rev. July 1. 2005) (Probate—Decedents' Estates) Solutions 1215, 12l6i230'l
1 SERVICE LIST
2
3 Robert Nese
1422 Glengarry Road
4 Pasadena, CA91105
5Samuel Nese
304 Cahuenga Drive
6 Channel Island Beach, CA 93035
7 Michael Nese
3345 W. Corning Street
8 Newbury Park, CA 91320
9 Robin Thieltges
2214 Panorama Terrace
10 Los Angeles, CA 90039
11 David L. Pacheco
10648 Whipple Street
12 North Hollywood, CA 91602
13 Carly Nese
8355 Manchester Ave. #1
14 Playa del Rey, CA 90293
15 Stephanie Nese
1210 Venice Blvd., Apt 206
16 Venice, CA 90291
17 Jonathan Nese
11951 Mayfield Ave., #303
18 Los Angeles Ca 90049
19 Sean Eckhardt
345 S. Gabriel Blvd.
20 Pasadena, CA91107
21 John Nese
502 Lakewview Rd
22 Pasadena, CA92118
23
24
25
26
27
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