The document is a prerequisite to filing a wrongful death lawsuit, in which Joe claims Dr Murray had been drinking at a strip club hours before he allegedly administered a fatal dose of propofol to his son Michael.
According to the document, "On June 25, 2009, prior to treating Michael Jackson, defendant was at a 'strip club' called 'Sam's Hofbrau' in Los Angeles where he had been drinking." The document goes on: "It was reckless for him to 'drink' prior to administering anaesthesia to Michael Jackson. He concealed his conduct from Michael Jackson."
The document, written by attorney Brian Oxman, outlines Murray's treatment and the medical emergency that ended in Michael Jackson's death.
According to the document, Michael had "neurological, pulmonary, and anaemia signs over several weeks prior to his death. In May and June, 2009, Michael Jackson was confused, easily frightened, unable to remember, obsessive, and disoriented." Oxman goes on: "He had impaired memory, loss of appetite, and absence of energy. He was cold and shivering during the summer rehearsals for his show ..."
Oxman claims these problems were caused by Dr Murray administering a "polypharmacy" of drugs (multiple medicines) to Michael. And Oxman claims, Dr Murray "ignored the signs of Michael Jackson's pulmonary inflammation, brain swelling, and anaemia."
Oxman alleges Murray repeatedly lied about the drugs he administered to Jackson and withheld vital information from EMTs and doctors who were trying to save Jackson's life. He repeated all of the alleged inconsistencies that have been previously reported.
Oxman says of Dr Murray, "His conduct was inhuman. It was an extreme violation of the standard of care."
TMZ we're told Dr Murray received a copy of the document on March 27 this year. Dr Murray's legal team told TMZ:"The allegations are absolute, utter nonsense."
And people close to Dr Murray insist he does not drink ... ever.
According to California law, Joe Jackson must wait 90 days from the date the document is delivered before filing an actual wrongful death lawsuit. The 90-day period is up this Friday, the anniversary of Michael's death.