Kirk Invokes Fifth Amendment

Other than 2 initial interviews with Carver County detectives who arrived at Paisley Park the morning of Prince’s death, Kirk Johnson has refused all subsequent questioning.  Kirk quickly retained legal counsel, criminal defense attorney Clayton Tyler.

Kirk Johnson is the last person to have seen Prince alive, and is also the person that located Prince’s body on April 21, 2016. After providing is his name, age, place of birth and city of residence, Kirk Johnson refused to answer any questions.  Kirk evoked the Fifth Amendment 200 times when he was questioned by the plainiff’s attorneys.  Depositions can be used at trial.  Below is transcript of Kirk Johnson’s February 2019 deposition.

 

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“Are you currently employed outside of the home?” Mr. Goetz asked, presumably having prior knowledge of Kirk’s ongoing consulting role with Paisley Park

“I plead the Fifth,” Kirk responded.

“Did you know Prince Rogers Nelson?”

“Fifth Amendment.”

“I will refer to him as ‘Prince’ if that’s alright. When did you first meet Prince?”

“Fifth.”

“How long did you know him?”

“Fifth.”

“Did you have a relationship with him from the time you met him until the time of his death?”

“Fifth Amendment.”

“Thank you. What was your relationship with Prince during the last years of his life?”

“Fifth.”

“Were you employed by Prince?”

“Fifth.”

“Could you please give me a complete history of your employment with Prince, starting from the time you might first have been employed by him until the time of his death, and the positions you held with him?”

“Fifth.”

“Did you know him as a friend before you were employed by him?”

“Fifth.”

“Were you a musician for Prince?”

“Fifth.”

“Were you a manager for Prince?”

“Fifth.”

“Either a musical manager or a stage manager, program manager, business manager, any kind of manager?”

“Fifth.”

“And if so, the details of such.”

“Fifth.”

“This is going very smoothly.”

“I would love that.”

“Were you a bodyguard for Prince?”

“Fifth.”

“Did you ever reside at Paisley Park?”

“Fifth.”

“If so, when?”

“Fifth.”

“In the last year of his life, how much contact did you have with Prince?”

“Fifth.”

“For what purposes?”

“Fifth.”

“Do you know the identity of any health care providers for Prince at any time or any place, for any reason?”

“Fifth.”

“And, in other words, do you know the identity of any doctors who might have seen or treated him at any time in his life that you might know of? Either through observation or talking to Prince?”

“Fifth.”

“The same with respect to medical doctors. You understand I’m asking that?”

“Fifth.”

“And with respect to any other kind of health care providers, such as a chiropractor or osteopath or other health care professionals, I’m asking if you would be kind enough to give us the identity of any such people who treated Prince at any time, at any place, for any reason.”

“Fifth.”

“Do you know of a Dr. Doug, last name not known to me, who saw Prince from time to time at Paisley Park and elsewhere?”

“Fifth.”

“Do you know or can you tell us the identity of persons other than yourself who might have information as to the identity of medical providers, health care providers of any type to provided any kind of care or treatment to Prince at any time, at any place, for any reason?”

“The Fifth.”

“Do you know any pharmacies where prescriptions were filled for Prince –”

“Fifth.”

“—at any time, at any place, for any reason?”

“Fifth.”

“Do you know other individuals who would be able to provide the identity of pharmacies or prescriptions of any kind that might have been filled for Prince at any time, at any place, for any reason?”

“Fifth.”

“And if you do know the identities of those pharmacies, can you please tell me when and at which pharmacies Prince obtained prescriptions, to the best of your recollection?”

“Fifth.”

“And then, going back to medical providers, if you do know the identity of any medical providers, can you please tell us the dates that you recall Prince seeing those medical providers?”

“Fifth.”

“And the purpose for which he saw them.”

“Fifth.”

“From time to time, Prince used aliases. Could you please give us a list of all aliases that you recall Prince using?”

“Fifth.”

“Were you with Prince at the time of the illness for which he was seen at Ridgeview Medical Center in October of 1913? I just recently saw a documentary on WWI, so I guess I’m still back about a hundred years. 2013.”

“Fifth.”

“It’s a really good documentary. And if you were with him, what do you recall about that incident?”

“Fifth.”

“Do you recall other individuals who were with him at that time?”

“Fifth.”

“Did you contact Dr. Schulenberg about Prince in the fall of 2015?”

“Fifth.”

“How did you know Dr. Schulenberg?

“Fifth.”

“What came of the contact that you made, if any, with Dr. Schulenberg in the fall of 2015?”

“Fifth.”

“Did you arrange for Prince to see Dr. Schulenberg on April 7, 2016?”

“Fifth.”

“Did Dr. Schulenberg ever prescribe any kind of medication for Prince in your name?”

“Fifth.”

“Did Dr. Schulenberg ever prescribe any kind of medication for Prince to your knowledge in anybody else’s name?”

“The Fifth.”

“Did other doctors besides Dr. Schulenberg ever prescribe any medication for Prince in your name?”

“Fifth.”

“To your knowledge, did any other associates of Prince ever obtain prescriptions from Dr. Schulenberg in their names? Prescriptions for Prince?”

“Fifth.”

“To your knowledge, did any other associates of Prince ever obtain prescriptions from doctors other than Schulenberg for medication for Prince, but in their names?”

“The Fifth.”

 

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“What was the purpose for arranging for Dr. Prince to see – for Prince to see – Dr. Schulenberg on April 7, 2016?”

“The Fifth.”

“Thank you. Did you make any contact with Recovery Without Walls and Dr. Kornfeld and/or his son on behalf of Prince?”

“Fifth.”

“Do you know of anybody else who made contact on Prince’s behalf with Dr. Kornfeld and his son?”

“The Fifth.”

“If you or anyone else did make a contact with Dr. Kornfeld, can you please tell us when the first contact was made?”

“The Fifth.”

“And how was it made? By phone or otherwise?”

“Fifth.”

“And the purpose of the contact?”

“Fifth.”

“And how did you or anyone else in Prince’s circles came to know of Dr. Kornfeld and Recovery Without Walls?”

“Fifth.”

“What discussions with Recovery Without Walls were you involved in, if any?”

“Fifth.”

“Do you know what other people were involved in any discussions with Recovery Without Walls on behalf of Prince?”

“Fifth.”

“Do you know of any email communications between yourself and other, and/or other associates of Prince in Recovery Without Walls?”

“Fifth.”

“And the same with respect to oral communications by telephone.”

“Fifth.”

“Turning your attention to April 16 of 2016, were you with Prince at a concert in Atlanta on the night of the 15thor 16th of April?”

“The Fifth.”

“Were you on Prince’s private plane, or the private plane hired for Prince, that made an emergency landing in Moline, Illinois, on April 16th?”

“The Fifth.”

“If you were, who else was on that plane?”

“Fifth.”

“For the record – well, this is for Mr. Johnson – there is some confusion in the records as to whether Prince saw Dr. Schulenberg on April 7 or 8, and I think my questions all asked for the 7th. Would your answer be the same if the visit was on the 8th?

“Fifth.”

“Did you notice anything unusual about Prince’s behavior on the flight to Atlanta?”

“Fifth.”

“Did you notice anything unusual about Prince’s behavior during the show?”

“Fifth.”

“Do you know what time the show ended?”

“Fifth.”

“Do you know what time you left with Prince on the plane?”

“Fifth.”

“Did Prince appear to be alert and orientated when the plane left Atlanta?”

“Fifth.”

“Did anything seem unusual about him at all?”

“Fifth.”

“At what point in the flight did you become aware that Prince was no longer alert an orientated?”

“Fifth.”

“How did you become aware of that?”

“Fifth.”

“Are you able to tell approximately how long into the flight or how long after departure Prince’s condition began to change?”

“Fifth.”

“Did you see Prince take any pills, medications of any kind that night either in Atlanta or on the plane?”

“Fifth.”

“Do you know if Judith Hill saw Prince take any medications or pills of any kind in Atlanta or on the plane that night?”

“Fifth.”

“When you noted that Prince was no longer alert and orientated, now did he in fact appear to you?”

“Fifth.”

“In other words, did he go from alert and orientated to passing out, or was it a slow process, like blurring words, dozing and then passing out?”

“Fifth.”

“Did you notice any signs or indications that Prince was under the effect of a medication on the plane?”

“Fifth.”

“Did you suspect that he had taken too much of a medication?”

“Fifth.”

“If you did, how much did you suspect he had taken?”

“Fifth.”

“What did you believe he had taken?”

“Fifth.”

“Please tell us what your observations of Prince’s condition were that caused the decision to make an emergency landing.”

“The Fifth.”

“Was it your decision to request an emergency landing?”

“Fifth.”

“If not, whose was it?”

“Fifth.”

“Did it seem to you the transition from Price being alert and orientated or in a normal condition to his being unconscious occurred quickly?”

“Fifth.”

“Did it seem t you that it – sorry – by ‘quickly’ I mean within an hour.”

“Fifth.”

“Would you agree that Prince did become unconscious on the plane?”

“Fifth.”

“At the airport in Quad Cities, did you know the pilots of the jet from previous flights?”

“Fifth.”

“Did you know the company that provided the jet?”

“Fifth.”

“If you knew them, how did you know them?”

“Fifth.”

“Do you know whether Prince saw a medical care provider while in Atlanta?”

“Fifth.”

“Did Prince get any of the Watson 853 tablets that were in the Bayer aspirin bottle while on the ground in Atlanta?”

“Fifth.”

“Did he receive any drugs while in Atlanta?”

“Fifth.”

“If so, how and from whom?”

“Fifth.”

“When the plane landed and you carried Prince to the ambulance, were you concerned that he was dead?”

“Fifth.”

“Did the ER doctor at Trinity Medical Center ever express aloud, telling Prince or you or Judith that the pills in the Bayer aspirin bottle could be fake?”

“Fifth.”

“Did the ER doctor ever tell Prince, you or Judith Hill that pills from the Bayer aspirin bottle might contain fentanyl?”

“Fifth.”

“At some point the emergency room doctor had one of the pills from the Bayer aspirin bottle; is that true?”

“Fifth.”

“Do you recall whether the doctor, she, examined the pill to identify it on her own?”

“Fifth.”

“Did she say anything out loud as to what the pill might be?”

“Fifth.”

“Did anyone tell her what the pill might be?”

“Fifth.”

“Do you know if Prince know what the pill was?”

“Fifth.”

“Do you recall whether the emergency room doctor sent the pill to another department for identification?”

“Fifth.”

“If it was sent somewhere, do you know if it was sent to a pharmacy?”

“Fifth.”

“Do you recall whether the doctor provided anyone in another department with information about the clinical status of Prince when she sent the pill for identification?”

“Fifth.”

“Do you know whether the doctor consulted with anybody on the phone or in person, any other medical doctor, during your – Prince’s – time at the hospital?”

“Fifth.”

“If so, details of that.”

“Fifth.”

“Did the emergency room doctor at any time tell you or Judith Hill that she suspected fentanyl was in the drug?”

“Fifth.”

“Did the doctors say at any time that testing of the pill could be done there, at the hospital, or sent away to somewhere in the area to see what indeed the pill contained?”

“Fifth.”

“Did the emergency room doctor give any impression to Prince, based on your observation, that the pills Prince was taking were in fact not oxycodone or hydrocodone?”

“Fifth.”

“Did she insinuate or say to Prince or Judith Hill that whatever Prince took could in fact be something for a more dangerous, like heroin, fentanyl or something much stronger?”

“Fifth.”

“Did the emergency room doctor ever leave you with the impression that whatever was in the white Watson 853 pill might be bootleg or fake, and therefore life-threatening?”

“The Fifth.”

“Did the emergency room doctor give Prince or you the impression that if Prince did not seek emergent intervention, he could die?

“Fifth.”

“If so, from what cause of death?”

“Fifth.”

 

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“Did the emergency room doctor want to contact Prince’s immediate family?

“Fifth.”

“Did the emergency room doctor tell Prince that a blood draw would tell him exactly what kind of opiate he was taking and how much?”

“Fifth.”

“Or did the emergency room doctor seem more concerned that Prince was at risk for overdose from acetaminophen, that is, Tylenol, that would also be in the pills from the prescription?”

“Fifth.”

“Did the emergency room doctor seem concerned at all that Prince was at risk of overdose from the acetaminophen?”

“Fifth.”

“Did she seem concerned at all that Prince would be at risk from overdose of acetaminophen from the pills in the Bayer aspirin bottle?”

“Fifth.”

“When you left the emergency room, did the emergency room doctor or any other member of the hospital warn Prince, or you on his behalf, that if he took even one more pill from the Bayer aspirin bottle, he could die?”

“Fifth.”

“Did the emergency room doctor try to have Prince admitted for detox and/or rehab, as a follow-up, in Minnesota?”

“Fifth.”

“Did the emergency room doctor attempt to call Dr. Schulenberg?”

“Fifth.”

“Did the emergency room doctor recommend that a social worker or other specialist in addictionology come and talk with Prince?”

“Fifth.”

“Did the emergency room doctor want Prince to be admitted to the hospital for detox and/or drug rehabilitation?”

“Fifth.”

“Did the emergency room doctor ask to keep a pill or all of the pills from the Bayer aspirin bottle?”

“Fifth.”

“Did the emergency room doctor suggest that the pills were illegal, the pills in the Bayer aspirin bottle?”

“Fifth.”

“Did the emergency room doctor suggest to Prince that he should not be taking Percocet because it was in the name of someone else?”

“Fifth.”

“Did the emergency room doctor threaten to confiscate any of the pills?”

“Fifth.”

“Did she threaten to call the police?”

“Fifth.”

“Did she offer to give the pills from the Bayer aspirin bottle to the police for testing?”

“Fifth.”

“Or to sent them out for testing?”

“Fifth.”

“Did the emergency room doctor share with Prince, or you on his behalf, whether a pharmacist or a pharmacy technician or some other specialist identified the Watson 853 tablets?”

“Fifth.”

“If so, did she happen to mention how it was identified, whether visually or by other means?”

“Fifth.”

“When did you find out that the Watson 853 pills in the Bayer aspirin bottle were laced with fentanyl?”

“Fifth.”

“When did you find out they were counterfeit?”

“Fifth.”

“When did you find out they were laced with anything other than legitimate prescription contents?”

“Fifth.”

“Do you know how Prince got those pills from the Bayer aspirin bottle?”

“Fifth.”

“Do you know whether he had obtained a separate batch in the past?”

“Fifth.”

“Had you seen him take pills similar to those, having the same effect; in other words, inducing almost complete overdose or almost immediate overdose?”

“Fifth.”

“What instructions for returning home did Prince, or you or Judith Hill on his behalf, receive before Prince left the emergency room?”

“Fifth.”

“Did the emergency room doctor tell Prince that he overdosed from opiates?”

“Fifth.”

“Or did she tell you or Judith Hill that on his behalf?”

“Fifth.”

“Did you have any understanding, knowledge or belief as a result of the medical care and treatment Prince received in the ER that the Watson 853 pills were suspect, and that Prince could die if he ingested even one more pill?”

“Fifth.”

“Turning to the 20th of April, did Dr. Schulenberg, you and/or Prince discuss the opiate overdose that had caused the landing in Moline, Illinois?”

“Fifth.”

“What history was given to Dr. Schulenberg on April 20 about the emergency room visit in Moline, Illinois?”

“The Fifth.”

“Did you or Prince discuss with Dr. Schulenberg opiate withdrawal?”

“Fifth.”

“Dr. Schulenberg prescribed on that occasion, April 20, 2016, clonidine, or Catapres. Do you know the purpose of that prescription?”

“Fifth.”

“Dr. Schulenberg also prescribed diazepam, also known as Valium. Do you know what that was for?”

“Fifth.”

“Dr. Schulenberg prescribed hydroxyzine. Vistaril is another name. Do you know what that was for?”

“Fifth.”

“Do you know whether or not those three drugs, that is, Valium, clonidine and hydroxyzine, were being used to treat Prince for opiate withdrawal?”

“Fifth.”

“Did either you or Prince share with Dr. Schulenberg the number and type of pills that Prince took that caused his overdose in Illinois?”

“The Fifth.”

“Was there any discussion with Dr. Schulenberg about those pills that he had taken in Illinois containing something more dangerous than oxycodone or hydrocodone?”

“The Fifth.”

“Was Prince made aware by Dr. Mancha in Illinois or by Dr. Schulenberg that two Percocet and two Watson 852 would not require the amount of Narcan that he received to reverse the overdose?”

“Fifth.”

“If so, please relate that whole conversation.”

“The Fifth.”

“Was there any discussion with Dr. Schulenberg about emergency admission to the Betty Ford Clinic, Hazelden or other type of supervised detox and/or rehab?”

“Fifth.”

“Was Prince made aware that he was suffering from opiate addiction withdrawal by any medical professional, whether in Illinois or Dr. Schulenberg or otherwise?”

“The Fifth.”

“If so, by whom and when?”

”The Fifth.”

“Do you think Prince knew he was going through opiate withdrawal?”

“Fifth.”

“Did you know he was going through opiate withdrawal?”

“Fifth.”

“Do you know why Dr. Schulenberg ordered a laboratory test to identify drugs that Prince might be abusing?”

“Fifth.”

“Did Dr. Schulenberg have a confirmation of opiate – strike that. Did – before Prince left Dr. Schulenberg on April 20th, did Dr. Schulenberg have confirmation that Prince was taking opiates?”

“Fifth.”

“How did you come to choose the Walgreens at 4950 County Road – I forgot the name of the county road – in Minnetonka to fill his prescription?”

“The Fifth.”

“Did you know anybody at that pharmacy?”

“Fifth.”

“Did anybody question you why you were filling the prescriptions which were in fact for Prince?”

“Fifth.”

“In whose name were the prescriptions written?”

“Fifth.”

“Were they written in Prince’s name?”

“Fifth.”

“Did you know anybody at the Walgreens pharmacy on a first-name basis or otherwise?”

“Fifth.”

“That’s any Walgreens in the Twin Cities area.”

“The Fifth.”

“Was there any one Walgreens store that Prince went to regularly for prescriptions?”

“Fifth.”

“Have you seen the picture on the internet of Prince riding a bicycle outside of a Walgreens pharmacy?”

“Fifth.”

“If so, can you tell us anything about it?”

“Fifth.”

“Whether he did that for a particular reason, or did it frequently, or in general?”

“Fifth.”

“Do you recall Prince personally getting a prescription filled or dropped off or picked up at any pharmacy, including Walgreens?”

“Fifth.”

“Do you know if anybody at Walgreens would have known Prince as a result of Prince frequently doing business at a Walgreens?”

“Fifth.”

“Do you know whether Phaedra Ellis or Meron Bekure obtained pain killers for Prince?”

“Fifth.”

 

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“Do you know whether Phaedra and/or Meron Bekure shredded any documents or erased any computer records after Prince’s death?”

“Fifth.”

“There is a statement by you that you sent your aunt to get the aspirin bottle with medication in it. Why did you do that?”

“Fifth.”

“There is a statement by you in the criminal investigation file that you meant to remove the medication from Paisley Park. Why did you mean to do so?”

“Fifth.”

“Meron Bekure had over $3,000 in her purse on the morning Prince died. Do you know why?”

“Fifth.”

“Did you help with an intervention?”

“Fifth.”

“Did anyone discuss, either Dr. Schulenberg or any of his associates or you, admitting Prince to a rehabilitation facility against his will?”

“Fifth.”

“If so, describe those discussions.”

“Fifth.”

“Did anyone indicate to Prince or to you that Prince was in a life-or-death situation, each day after his episode in Illinois, without medical intervention?”

“Fifth.” “Fifth.”

“The DEA said that no one, including Prince, knew the Watson tablets were laced with fentanyl.”

“Fifth.”

“Do you agree with that?”

“Fifth.”

“Was Prince willing to get help for his addiction?”

“Did Prince admit privately to you or to other associates that you know that he was sick and tired of painkillers and wanted to be free of them?”

“Fifth.”

“Did Prince have a moment of clarity where he felt it was necessary to get help?”

“Fifth.”

“Had Prince decided to get help before he died?”

“Fifth.”

“Was it because Prince had decided to get help that someone from Recovery Without Walls flew to Minnesota?”

“Fifth.”

“Was Dr. Kornfeld just going to talk to Prince, or have his son talk to Prince, or had it been decided that Prince would take medication that had been sent with the son to start detoxification?”

“Fifth.”

“Was Prince even aware someone from Recovery Without Walls was coming to talk to him?”

“Fifth.”

“Was Dr. Schulenberg aware that Prince was taking hydrocodone – let me start that over. Because of the ER landing in Illinois, was Dr. Schulenberg aware that Prince was taking hydrocodone?”

“Fifth.”

“How long had Dr. Schulenberg known that Prince was likely suffering from withdrawal symptoms, based on your conversation and meetings with Dr. Schulenberg?”

“Fifth.”

“Either done or close to done. If we could take a five-minute break, I’m going to make a call to my co-counsel and go over things.”

A brief recess was taken.

“We are back. No more questions.”

Examination by Mr. Steinhoff:

“Good morning, Mr. Johnson. My name is Eric Steinhoff. Again, I represent Dr. Schulenberg. I’m going to ask you a few questions. I’m going to kind of put things into categories. I don’t want to repeat everything Mr. Goetz just asked you to get the same answer, but if – generally, if I asked you about your interaction with Dr. Schulenberg on the phone or in person in any way about Prince, would you be taking the Fifth Amendment on those questions?”

“Yes.”

“If I asked you about your interaction with Dr. Schulenberg and Prince at an appointment, or overhearing discussions between Prince and Dr. Schulenberg, or any other questions about what happened at various medical appointments and medical treatment Dr. Schulenberg provided, would you be taking the Fifth Amendment to those questions?”

“Yes.”

“If I asked you generally about any discussions you had with Dr. Schulenberg, outside of the presence of Prince, related to chemical dependency, or resources available to him, or resources that Dr. Schulenberg provided, anything related to that, would you be taking the Fifth Amendment as well?”

“Fifth.”

“If I asked you about any interaction you had related to obtaining help with Recovery Without Walls, or any other discussions you had with Prince on obtaining help for opioid addiction, would you take the Fifth Amendment for those as well?”

“Fifth.”

“I think that’s all I have. Thank you.”

Examination by Ms. Hoffman:

“Good morning Mr. Johnson. Again, my name is Sarah Hoffman, and I represent North Memorial. I’m going to ask you a series of questions in a similar fashion to what Mr. Steinhoff has done. Mr. Johnson, if I were to ask you a series of questions about any conversations that you may have had with any employees or health care providers at North Memorial related to Prince Rogers Nelson at any point in time, would you plead the Fifth to those questions?”

“Yes.”

“And if I were to ask you a series of questions about your general knowledge and observation of Mr. Nelson’s physical and mental health at any point in time, would you also plead the Fifth to those questions?”

“Fifth.”

“If I were to ask you a series of questions as to your knowledge based either on your own personal observation or your communications with others about Mr. Nelson’s drug use, would you plead the Fifth to that series of questions?”

“Fifth.”

“And if I were to ask you a series of questions about materials that were found at Paisley Park after Mr. Nelson’s death, including but not limited to controlled substances, would you also plead the Fifth as to that series of questions?”

“The Fifth, yeah.”

“I think that’s all I have at this time.”

Examination by Mr. Hagen:

“Mr. Johnson, I’m Roger Hagen. I represent Trinity Medical Center – Rock Island, Illinois. If I were to ask you questions today about any conversations you had with individuals who were health care providers at Trinity Medical Center in Rock Island, Illinois, would it be your intention to invoke your Fifth Amendment right?”

“The Fifth.”

“If I were to ask you questions about observations – strike that. If I were to ask you questions about observations you made while Prince was at Trinity Medical Center in Rock Island, Illinois, would it be your intention to plead the Fifth?”

“Fifth.”

“If I were to ask you questions about conversations that you may have overheard between Prince and medical providers at Trinity Medical Center – Rock Island, Illinois, would it be your intention to invoke your Fifth Amendment right?”

“The Fifth.”

“And if I were to ask you questions about information that was communicated to Prince either in writing or orally by health care providers at Trinity Medical Center – Rock Island, would it be your intention to invoke your Fifth Amendment right?”

“Fifth.”

“I have no further questions. Thank you.”

Examination by Mr. Johnson:

“Good morning, sir. My name is Stuart Johnson, and I represent Walgreens in this matter. Sir, if I were to ask you a series of questions about any of your experiences in Walgreens, or interactions with any Walgreens staff, would it be your intent to invoke your Fifth Amendment rights?”

“The Fifth.”

“If I were to ask you a series of questions on whether you recognized by name or face or appearance any employee at any Walgreens, would it be your intent to invoke your Fifth Amendment rights?”

“Fifth.”

“If I were to ask you a series of questions about whether Mr. Nelson had been in any Walgreens pharmacies, would it be your intent to invoke your Fifth Amendment rights?

“The Fifth.”

“If I were to ask you a series of questions on whether Mr. Nelson recognized any employees or representatives of Walgreens by face or appearance or name, would it be your intent to invoke your Fifth Amendment rights?”

“The Fifth.”

“If I were to ask you a series of questions of whether you’ve ever been at any Walgreens at any time with Mr. Nelson, and any conversations that you’ve had with any staff of Walgreens, would it be your intent to invoke your Fifth Amendment rights?”

“Fifth.”

“If I were to ask you a series of questions about any pharmacies that you had ever been with Mr. – been in with – Mr. Nelson, would it be your intent to invoke your Fifth Amendment rights?”

“Fifth.”

“If I were to ask you a series of questions about any knowledge you have about Mr. Nelson going to any pharmacy at any time, would it be your intent to invoke your Fifth Amendment rights?”

“Fifth.”

“If I were to ask you a series of questions about any interactions you had with Walgreens regarding your prescriptions, or prescriptions in your name, would it be your intent to invoke your Fifth Amendment rights?”

“Fifth.”

“If I were you ask you a series of questions about any interaction you had with Walgreens staff on April 20th, 2016, in Minnetonka, would it be your intent to invoke your Fifth Amendment rights?”

“Fifth.”

“If I were to ask you a series of questions about Mr. Nelson’s shopping habits, meaning whether he would personally go to a convenience store or a grocery store to get things, or sent others on his staff, or associates, would you invoke your Fifth Amendment rights?”

“Fifth.”

“If I were to ask you a series of questions about other persons who may have any knowledge about Prince’s purchases, would it be your intent to invoke your Fifth Amendment rights?”

“Fifth.”

“If I were to ask you a series of questions about any other pharmacies that Prince may have attended or had associates attend to attempt to fill prescriptions, including, but not limited to, CVS pharmacies, would it be your intent to invoke your Fifth Amendment rights?”

“Fifth.”

“If I were to ask you a series of questions if you’ve spoken with anyone at Walgreens or Walgreens employees at any time, would it be your intent to invoke your Fifth Amendment rights?”

“Fifth.”

“If I were to ask you a series of questions about your various roles and positions with Mr. Nelson, would it be your intent to invoke your Fifth Amendment rights?”

“Fifth.”

“Same question regarding any employment positions you’ve held.”

“Fifth.”

“If I were to ask you a series of questions that – at any time that you filled a prescription about requests or conversations with pharmacies or employees, would it be your intent to invoke your Fifth Amendment rights?”

“The Fifth.”

“Sir, I don’t know if anyone has asked you this, but what is your date of birth?”

“Fifth.”

“Thank you. I don’t have any further questions at this time.”

Examination by Mr. Goetz:

“I’ll ask one or two more. Did Prince carry a credit card?”

“Fifth.”

“Did he use a checkbook, personal checkbook?”

“Fifth.”

“Did he carry cash with him?”

“Fifth.”

“Thank you.”

Mr. Tyler: “Any other questions?”

Ms. Hoffman: “No.”

Mr. Steinhoff: “None.”

Mr. Hagen: “None.”

Mr. Tyler: “You have a right to read and review your answers to this deposition, and I always – even though you’ve pled the Fifth all the time, I always tell my clients to read it and sign it. So, I’m going to have him read it before we send it out. So, we do want a copy, and we’ll do that. Okay? Is that what you want to do?”

Kirk Johnson: “Yes.”

Mr. Goetz: “Thank you.”

Mr. Tyler: “Thank you.”

Mr. Steinhoff: “Thank you.”

 

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