WATCH LIVE: Johnny Depp v Amber Heard Def Trial Day 4 – Sean Bett – Private Security For Johnny Depp

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Watch at: 00:00 / 00:00:20Watch at: 00:20 / 00:40all right good morning are there any preliminary matters before the jury comes in if you could put your microphone on or go to the river oh you wanna approach with it okay that's fine all right anything else preliminary no thank you your honor okay we're good we're ready for the jury all right let's bring the jury out oh sorry i'm sorry so dr kipper is going to be oh yes dr kipper is the last hour we had some agreement we've had agreements on exhibits do you want to wait for the jury then you can uh enter those into evidence is that okay you enter those exhibits into evidence when the jury comes out does that sound all right that works okay that works okay uh um all right good morning ladies and gentlemen all right mr mr nadel hof did you have um ladies and gentlemen you might remember we're in the middle of dr kipper's testimony for per deposition but i think there's some exhibits that need to be moved in i thank your honor the parties discussed over the over the weekend and we have agreement as to plaintiffs exhibits um 41 42 47 48 and 49 of plaintiff's exhibits i do believe that there are some slight redactions that i think they have copies of that they can provide to you and then we also have defendants 10 1063 which is redacted and i can provide you a copy and they also have the redactions okay um same for defendants 283 defendants 405 defendants 455 defendants 304 defendants 307 and in addition um 395 and 414 would come in without any redactions but i can provide you copies of the ones that we all right and have you already done the redactions are you still working on redactions uh your honor we have agreed on the redactions except for one document which we will okay and now 42 i already have an evidence i was just waiting for redactions for that one so we're still waiting for redactions for that one correct or do you have that for me uh so 42 is i believe defending defendants 42. oh i think we decided we agreed that for that one that there would be no no reductions wait plane is 42. sorry plane is 42 we have no reaction after discussion that there would be no redaction okay gotcha that's correct okay all right so all those are entered into evidence is that correct with the redactions that you've agreed upon yes sir all right so there's no objection and there's yes there's no objection okay if i may did you address ours i think i addressed yours okay all right and we can provide you would you so they have the they have the electronic copies which can be are going to be shown while the definition is being played and we can provide these copies i can provide you copies now of the redacted right if they're redacted ones i need copies if they're not redacted i have them right so yes okay that'll be fine all right thank you all right all right i think we're ready thank you if i may just before we begin your honor okay um just as an explanation for the jury um what you have seen from dr kipper up until this point has been miss herds council examining him at some point it'll switch over and it'll be mr depp's council examining him all right thank you mr depp uh informing you that he was upset with dr cowan yeah yes i i remember clearly that he was upset with dr cowan at a certain point you know do you recall this text message from mr depp that i just read to you yes and reading it i do okay and then mr depp wrote you again on july 5th 2015 and said you're a great man and a great friend as much as i would love to see you dot dot dot be a waste of your time dot dot dot i've just got quite a lot going on with my with business stuff my keith film and some amber issues dot dot dot by the way i'll try not to be too subtle about this dot dot dot cowen should be stripped of his license to practice his supposed profession dot dot dot and then he should be stripped and spray painted whisked handcuffed to a stop sign three exclamation points he is at best a fraudulent irresponsible turd of monumental proportions three exclamation points i love you johnny you recall this text message for mr deb again i i do upon reading this i i don't remember all the specific messages i got from him but i certainly remember the gestalt of his feelings okay and and do you continue to work with dr cowan you continue to refer patients to dr cowan let me ask it differently yes i have great respect for dr gown and mr depp sent you another text message on july 24th 2015 that says hey dear pal amber is happy happy with calallen dot dot dot i just don't know what truth he gets and i don't know what his manners and strengths are dot dot dot i think she listens to him because when she we argue she slathers me up in those condescending psychiatric trophy lines like dot dot dot your fear is so visible dot dot what are you scared of dot dot dot three exclamation points why are you letting your fear and your ego control your life etcetera dot dot dot hippie shit that that that makes me wanna rampage against anyone all capitals wearing birkenstocks three exclamation points love you large jay i assume you recall this text message as well no but i i recall when when i'm looking at it yes okay um now i'm going to go to another text message on august 3rd 2015 mr depp texts to you can flog me soon for waiting until now for having not to properly given my kind apparatus the appropriate and adequate general cock love dot dot i've tried and mostly failed dot dot dot many many unpleasant things happening with my business world going on that are attempting to give me the funny pain face that could render me no more and send me head first straight into the bowl of minestrone or worse a green curry dot dot dot so most necessary prns are all headache meds xanax adderall and whatever this magical ointment for that traitorous redness in the much valued in region of significance dot dot dot thanks in love xjd um do you recall this text message no but i'm once again reminded by looking at it you recall not being paid for three months i recall not being paid i don't remember how long and um it always it always turned back around but specifically that issue no i can't give you specifics so there was a period of time where mr depp was not paying you for your services correct correct okay so as of february 10 2016 you were very concerned about mr doubts mr depp's health correct in the document i'm also serving as his internist managing some medical issues and that that's the nature of these concerns you weren't concerned at all about mr depp's uh continuing with his uh treatment plan for drug and alcohol use you can't separate those two issues they're not two distinct issues but in order for me to assess how he was doing in general with his general health these metrics that i identify in the second paragraph were things that i needed to have follow up on and i wasn't i wasn't getting that follow-up and i needed to know that we were on the right course medically and you recall being concerned about mr death in june 2018 yes what if any concerns did you have about mr depp taking drugs or alcohol that were not part of the protocol i was concerned that that could be potentially an issue dr kipper kipper 28 your honor at this point there's an exhibit at which the parties are still in dispute um i believe that's okay to continue playing at this point and we can resolve it after the fact is that yeah after the deficit okay all right that's fine thank you our invoices that you produced um from february 2015 through from february 20 february 6 2015 to february 1st 2021. you recall producing these documents no those would have come from my accountant's office okay are you are you still um working for mr dapp yes okay and so at the bottom here there's a lot that just say case management fee um do you know what that refers to as opposed to nursing services and doctor services that's a retainer fee that i have with him um on a monthly basis now dr kipper we received invoices for you from mr depp from fireman's insurance fund um for 2014. does this look like an invoice from from your office to mr depp dr kipper you would just you've already testified that these are invoices to mr deb correct i've testified that these are invoices this is something generated from my account yes have you um spoken to mr legal counsel since the beginning of this year um yes who have you spoken through now i spoke i've spoken to camille um on two occasions anybody else no what did you speak to camille about about the deposition mr dr kim bradzick you're incorrect i think also ms myers was in one of those telephone conversations that's right and um other than the scheduling of the deposition did what did they talk about the issues that you were going to be asked about yes of course okay how long were the conversations minutes each were they uh over phone or by zoom or in person the first conversation was in person and this the second was bison and you thought there were about two 45-minute calls about that are um are you paying for your council in this case yes i am first of all uh dr kipper do you remember seeing this document earlier yes and you recognize it as your initial consultation notes with mr deb yes i'd like to direct your attention to the third page excuse me okay um you see here where it says impressions yes now what could you describe what the items listed under this heading are so the first one primary dopamine imbalance [Music] this in general terms i don't know primary dopamine imbalance adhd which is attention deficit hyperactivity disorder bipolar one depression secondary to above insomnia chronic substance abuse disorder chronic reflux with respect to these items are these an official diagnosis of mr death these are my impressions yes um when you say impression is that considered a diamond would you consider that a diagnosis yes ms meyers that's my diagnostic impression i'd like to pull up what's already been marked as kipper exhibit 4 please and dr kipper um i believe we've already established but could you confirm that you recognize these documents this document yes and these are also notes of the consultation you had with mr deb correct um do you and it appears from these notes that miss uh debbie lloyd was at the meeting correct yes and she's a registered nurse yes and did mr duff's treatment plan uh contemplate miss floyd remaining with mr duck during his therapy and was it contemplated that miss floyd would personally distribute his medications to him did miss lloyd provide personally dispensed medications to mr doug yes she did and how and how regular was miss lloyd's contact with mr depp she had contact with him daily either physically or by phone how often would you estimate that she was physically in contact with him i would say 80 90 of the time somewhere in there and mr duff agreed to this supervision by miss lloyd yes um alex could we please pull up what's been marked as kipper exhibit six um dr kipper could you please confirm that these are your notes from a consultation you had with mr duff in boston in june of 2014. yes this is a summary from june 22nd to june 24th of that concept of that time with him and if we scroll down i guess the notes reflect here that you met with ms hurd at that time correct yes does her tell you that she was concerned about mr duff being violent with her at this point no if she had told you that is that something you would have documented in these notes yes um your note here states that amber has a strong family history of drug and alcohol abuse and is particularly sensitive to his behaviors and potential for abuse um the phrase potential for abuse is that referring to substance abuse yes it's not referring to physical abuse and what do you mean when you state that misheard is particularly sensitive to mr depp's behaviors having grown up in in that environment she's used to seeing the trauma that it inflicts and is not only able to um to recognize it but also it affects her um she has the ability to understand what that looks like and was this your observation of her or something she told you this is something she told me um alex could you please pull up what's been marked as uh kipper exhibit five please um dr kipper you recognize these as i believe you testified a combination of your own patient notes and miss lloyd's patient notes for mr deb correct yes and you and i believe you testified you compiled them together is that right yes did you add for the notes that were taken by miss lloyd did you specifically request that she maintain these notes yes that's part of her responsibility and did you advise her on what types of uh information she should include in those notes no is there anything in particular that you asked her to include in the notes no she was trained in this and she she knew what the what the important metrics were in in notation and i believe you testified that you have reviewed these notes in their entirety before correct yes how many times would you say you've reviewed these notes i reviewed them at the time they were written and i reviewed them probably a couple weeks ago so twice i'm going to turn to the last page now and do you see this note marked on june 30th yes and so do you understand that to be june 30th 2015 yes is did miss did miss lloyd stop attending to mr duck around this time i'm going to refer to my timetable just because i'll have a better sense where the treatment was all right i'd like to talk to you uh briefly about the detox process um on mr duff's island in august 2014. [Music] uh i believe you said that you you traveled down to attend to mr depp during this time correct yes and when you arrived on the island who was who was present mr depp miss heard miss lloyd and assistance for mr depp and i can't recall which assistance do you recall how many um no there were people that i think lived or serviced that island when he was there there were probably four of those people and i'm not sure if he had one or two of his own assistants um dr kipper um when you arrived on the island in august 2014 did you see where mr depp was was staying during that time yes and what did these accommodations look like he had a little home structure it was a small structure bedroom and a kitchen and a sitting area and was miss heard staying there with him yes and relative to where mr duff was staying where was miss boyd's thing she was staying on another part of the island in a structure called a yurt which is like a tent um and um how far away how long would it take miss lloyd to get to where mr duck was staying five minutes would that be walking no that would be on a motorized vehicle and uh relative to where mr duck was staying where did you say when you're on the island stayed on the other side of that word okay also in a year um have the deep had mr gut's detoxification process already started when you arrived on the island yes and had missed lloyd been overseeing that process did she report any issues to you upon your arrival she certainly updated i was updated he started on the 10th i arrived on the 12th so i was in full communication with her from the beginning after you arrived on the island did you personally oversee mr duck's detoxification process yes and how often would you check in on him um several times a day and was this physically going to see him no this would be seeing him physically once a day and then checking on his progress throughout the day so during the detoxification process you did see mr death at least once a day yes and was miss lloyd checking on mr beth daley yes and she was seeing him in person anyway as well yes you went and saw mr depp after receiving that message correct yes and did ms lloyd go with you yes and um where did you see mr jeff after receiving that message i believe i saw him outside of his little home uh it was either in the across from this little home was like a little cantina where one would eat and it was i think in the around the cantina and what was his physical condition at that he was frustrated he was uncomfortable how was his demeanor one of being frustrated and uncomfortable and was miss heard with him at that time when i saw mr depp at that point no she was not and at this time this was in the middle of his detoxification process correct yes did you seem as hard that evening i can't remember do you [Music] recall miss heard seeking medical treatment from you for any physical injuries while you were on the island in august 2014. go ahead if ms heard had thought treatment from you for injuries is that something you would have documented yes i would have is that something you would have remembered her telling you yes did you see this heard after this evening of august 8 17. on that particular evening that i can't remember but i did see mister pretty much daily during the time my time on the island so did you see her at some point perhaps did you see her the next day yes and did you observe any injuries to miss heard at that time no she didn't have any bruises that you occur no after you met with mr depp that evening of august 17th did you go back to his accommodations at some point no no i think we we resolved the issues where we were outside of his little um his home so you didn't go and attend to him again in his home after that time no alex could you please pull up what's been marked as kipper exhibit eight thank you uh dr kippah i think you look you do you remember this email from earlier in your deposition yes i do and i believe you testify that you recall sending this email to um mrs denbrough on august 18 2014 correct yes at the time you wrote this email how long have you known mr depp approximately four months and in those four months how much time have you spent with mr death in person i couldn't give you a cumulative number of hours but i would say i would estimate that including up until august 18. i would i would guesstimate 20 hours is it fair to say that when you wrote this email most of the time you had known mr deb or spent with mr depp was while he was in detox yes during the time that you were with mr depp on the island for his detox process did you ever witness him physically abused misheard no never did you ever see any physical evidence that mr deaf had abused misheard no same answer never and um at the during your time on the island did you witness miss heard abuse mr duck in any way no do you recall when mr first became your patient no i couldn't give you a definitive date it was it would have been before october 2014 though correct yes and it would have been after mr duttsy talks on the island in august 2014 is that right that's great um when you started treating miss her did you assign a nurse to her when when you started treating miss heard was there a nurse that you assigned to her i can't recall whether it's whether as far as it was when i started to treat her at some point i did assign a nurse to her but i can't tell you which came first i i believe i was treating her before um i had recommended a nurse for her so your recollection is that you started treating her and after that a nurse was assigned that's that's my memory yes do you have a sense of how close in time to you beginning your treatment the nurse was assigned to misheard it couldn't have been too too long um but i i honestly can't give you a specific reference of time do you remember that nurse's name aaron borham and is miss foreign a registered nurse yeah and i believe you covered this earlier miss borum is a contractor for you yes but she reports to you with respect to your patience that she covers correct during the time that myth heard was your patient and she had a nurse miss born was assigned to her how regular was miss borum checking in with this her very regular very regular she saw her yes would she have seen her on a daily basis i don't believe i i don't believe it was a daily basis but she i know had daily contact with her in some way would miss in foreign on a at least a weekly basis yes are there times that miss foreign yes and as a registered nurse does miss foreign have an obligation to report any suspected abuse of her patient to you alex could you please pull up document h yes 34 yes dr kipper do you recognize this document yes and what is it um it's it's an initial intake of that care i'm going to scroll down a bit and just show you that there are future entries on this document as well do you see these i do i'm i'm assuming i don't want to make an assumption that i i would believe these notes are from aaron forum but if you give me a second to look at this i can be more specific certainly let me know if you'd like me to scroll through the document a bit more i can do that for you yes these are notes from aaron does this document reflect any of your own notes on this heard this reflects my treatment recommendations but these are miss did you foreign this farm to maintain these notes yes and for what purpose because she was monitoring a patient and i needed to be informed of how the patient was doing and for any adjustments of treatment did you tell ms moore what type of information should be documented in the notes no and would there be anything that you expressly asked for not to document no do you understand that mr miss borem used her training and judgment in preparing these notes yes i do you weren't telling her what to including these notes she was drafting them on her own is that correct that's correct um have you reviewed these notes before i have reviewed these notes have you reviewed them in their entirety yes but not recently and how often would you review miss forum's notes on miss heard i i review my nurses notes as they come in so that would be on a real-time basis okay and going back to the first page do you see this entry is dated august 27 2014 yes does this uh reflect refresh your recollection as to when miss forum would have been assigned to miss heard yes and does this at all refresh your recollection as to when you started treating this herd yes this would this would be about the time during the time that you treated miss her did she ever seek treatment from you for injuries that appear to be the result of domestic abuse no she did not did she never seek treatment from you for any injuries that she told you were caused by mr death no she did not did miss herd ever tell you that mr duff abused her no she did not and you never witnessed any physical abuse by mr jeff against miss heard during the times he treated both of them no no never miss born deserved that misheard had any physical injuries is this something that would have been documented in her patient notes from his heart yes absolutely in march 2015 you traveled down to australia to attend for death was that right yes and at the time mr depp was already in australia correct correct and was miss lloyd with him yes and was misheard with him yes you arrived in australia when did you first see mr dab i believe it was the day after i arrived and where did you see him i saw him at his home in australia and how long did you meet with him during that time probably an hour when you first met with mr death in australia um did you see the home that he was staying in yes and was it a standalone house yes was there events around the house i'm sorry was there a fence around the house that i can't recall do you recall whether mr duff security security team was at the property yes they were where did you see them i saw them in and around the house do you recall how many security personnel there were two to three now after you arrived in australia at some point you were notified that mr depp had been injured correct yes and i believe we you this was covered earlier in your deposition you were actually you actually received a text message from mr depp correct yes and after you received that message did you go directly to mr depp yes and miss lloyd came with you yes and i believe you said that mr duff was outside the property in his in a car at that time right that's correct was mr depp's security team there with him yes and he examined mr depp in the car with his security team present yes i i saw him seated in the car when i arrived [Music] did mr duff tell you what had happened to his finger at that time yes how long did you attend to mr death outside of the house not long probably a half hour so i needed to get him to the emergency room so immediately after meeting him at the house you went with him to the emergency room yes i cleaned his wound to the best that i could with the supplies that we had and then took him so it was within a half hour that we left did you return to the house after bringing mr duck to the hospital no i was taken back to my hotel after you attended to mr depp and before you went to the hospital with him did you go inside the house no you did not go inside the property the day that mr duff contacted you about his injured finger no i did go into the house as i had stated that after i saw him initially i went into the home to see the home before you went to the hospital with him yes i i went in to instruct one of the people with him to look for the tip of the finger hoping that we would be able to put it back was the tip of the finger found it was found who found it i believe this man was their chef and do you know where he found it or where he told you he found it he said he found it in the kitchen area when you went over the house did you see miss heard yes and how did she appear she was certainly upset did miss hart seek any medical attention to from you for any injuries at that time no didn't miss her seek any medical attention from miss lloyd at that time no did you observe any physical injuries to miss her when you saw her that um no so this herd did not have any observable breezes that you saw that's correct and did miss hurt appear to have a broken nose was miss heard's face swollen at all when you saw her not that i was aware of him did miss hurt have any cuts on her arms when you saw not that i can recall did you recall seeing any cuts on her feet or any other part of her body i can't recall if miss heard had appeared to have been injured is this something that you would have documented yes [Music] did you observe any broken glass in the house yes could you tell what the glass was from no was there blood around the broken glass there was blood around the home as i had previously mentioned but i didn't specifically see blood on glass where did you see the broken glass in the kitchen area and that's where the finger the part of the finger was found as well yes um alex could you please bring up what i believe was marked as kipper exhibit 17. uh dr kipper you recognize this document from earlier in the deposition yes it's a letter dated march 15 2015. from you to mr deaf correct and you did send this letter to mr duff correct correct alex could you please pull up when i've marked as document k and i believe will be for exhibit 35. do you recognize this document yes and what is it if you could just for my verification can you scroll down to the bottom please sure it goes on to her two pages yes i'm familiar with this document yes did you prepare this document no is this a document that was prepared by someone who works for you this was prepared by monroe tinker who is a nurse practitioner who worked for me at that time um is this a record that's ordinarily prepared and maintained in the course of your business yes and have you reviewed this document before yes when would you have reviewed it i reviewed it immediately after the visit probably the next day and i also reviewed this um a couple weeks ago and i'd just like to direct your attention to the last page is this your signature here yes and when would you sign this that was confirming that i reviewed mr tinker's notes going back to the top um this is a patient record for misheard correct yes and this where it says date december 17 2015 um is that the date of this that's the date of this document yes and the document states a phone call consultation headache correct yes so does that mean that on december 17 2015 ms heard called the offices to report a headache yes and right below this there's a paragraph that starts out with hpi what does that stand for history of present illness and is the information in this paragraph what ms heard reported during her phone consultation i was not there but that's what's written it's today the patient reports a headache after she bumped her head while standing up two days ago correct yes and a couple sentences below that it says last seen in the office on 12 23 2015. is that an error or did she come back in later no i think that's got to be an error so based on this document it's your understanding that ms heard called the office on december 17. yes it's going down to the bottom here it says objective data data physical exam do you see that yes um does that mean that ms heard came into the offices for a physical examination that's what it signifies yes and would that have also been on december 17 2015 yes this note reflects that visit everything in this note reflects that vision and so um monroe would have also performed that physical examination monroe did perform that physical examination i did not see miss heard monroe saw this hurt and the information below this heading of physical exam which goes on to the next page are these the the findings from ms hearts physical exam on december 17th correct and um have you heard of any physical injuries with those have been noted in this portion of the document yes and there are some medical terms in here but so if you could let me know does any of this indicate that there were physical injuries that were documented no does this document indicate that a concussion check was performed yes and what were the results of that under the assessment and plan as written mr tinker did not indicate concussion under his assessment under assessment and plan item 4 says that dr kipper is aware of the medical plan and is in agreement that's consistent with your recollection yes and i believe you testified you didn't seem misheard on december 17th correct that's correct how were you informed of the medical plan i spoke to mr tinker by telephone and would that conversation have happened on the 17th as well yes um alex could you please pull up document l okay and i believe this is what will be marked as hippo exhibit 36 and dr kippur do you recognize this document uh yes i i recognize it upon looking at it yes what do you recognize this document as as an email from miss heard to me requesting medical records for that month of december december 2015. yes and you recall receiving this email um i don't recall receiving it but i'm sure i i did and i'm sure i reviewed it yes and you see that the email is dated august 8 2016 right yes and you have no reason to doubt that you received the email on or around that date right um on august 8 2016 was miss heard still your patient i believe so but i i can't be sure now i'm going to read from this email here ms heard writes to you as per our conversation earlier is it possible to get my medical records from the month of december please i know i saw monroe during one of my office visits if it makes it easier for you to find i'm not sure anyways anyway it was great talking to you earlier um [Music] ms heard references speaking to you earlier in this email correct yes um do you recall having spoken to ms heard before receiving this email i can't remember you do you don't remember anything about a conversation that you might have had with my party prior to receiving this email no i i can't recall that um and i believe you already stated this but you understand ms heard to be requesting medical records from december 2015 correct correct and [Music] miss heard mentions um monroe in this email as well correct correct and monroe is the nurse practitioner that was hurts on december 17 2015 right yes um did you provide ms heard with her medical records for december 2015 i believe so and [Music] do you recall what those records consisted of the one we just reviewed was that the only one for december 2015 again i would have to research your chart for that information but i know at least it was it was that night did ms herd ever ask you for any other medical records no in the over six years that you've known mr deb have you ever witnessed him be physically abusive to any person never and you've never witnessed him being physically abusive to his heart correct correct you've also known miss heard for over six years at this point correct yes although i have not seen this for for at least a couple years perhaps three years in the six years that you treated mister in the over six years you've treated mr deb has mr duff ever complained to you that miss heard has physically abused him no not that i can recall have you ever witnessed miss heard be physically abusive to mr death no how's anyone who works for you or reports to you ever reported to you that they witnessed miss deb or excuse me misheard be physically abusive to mr dunn no not that i can recall you testified we testified earlier uh from questions from miss myers that the tip of mr depp's finger was found in the kitchen found on the floor of the kitchen and in the home in in australia correct right where do you know where the kitchen was was it on what floor the kitchen was there was a downstairs below the kitchen area i think those i'm not really sure i think those were bedrooms but i'm not positive so this would be on the main floor the kitchen was on the main floor as you went into the home and that's where the tip of the finger was found in the kitchen on the main floor yes no there was a text message where you got a text message from yes and he said he said he cut his finger correct i think that's what it said yes okay and um the reference from the emergency room said that mr deputy sliced his finger with a knife correct yes that's what he told because i was present for that that's what he told the emergency room about okay so mr depp told the emergency room doctor that he had cut his finger with a knife correct yes and you didn't put that in any of your notes that a bottle was thrown at mr deb correct correct did mr depp have any cuts anywhere else on his face or anywhere else that would have come from glass now if um if miss heard told miss borum that mr death had hit her in the face several times and sent her pictures of bruises would you expect miss gorham to report that in her notes i would have expected this forum to send me those pictures um so you would have expected to see those pictures from his forum is that correct yes and you would have expected and you would have wanted miss forum to if she had been seen a text that said i was hit in the face by misheard and then received pictures of bruises that missed lauren would report that to you correct yes is that any is that an instruction that you gave to your nurses to to report to you any abuse that they saw or were reported to them yes if they saw that as valid um miss herb for example if somebody hurt miss heard while she was under the care of direct care of miss forum and miss forum documented that miss heard had been injured she certainly would have reported that to me that's that was that's what your expectation would be that you can report roger kipper did you keep any notes um of your treatment of mr deb while he was in australia other than the summary notes no and when was miss lloyd with you and mr deb told you what had happened to his finger before you brought him to the hospital i believe yes i'm not positive but i believe yes because she was helping me at the car to try to clean out that finger which is when he explained what happened so you believe that that miss lloyd would have heard mr jeff's explanation i believe so all right that completes the deposition and i and the next witness is also by deposition is that correct that's correct your honor debbie lloyd all right well why go ahead and go ahead and take our morning break it's a little early but since the next witness is also by deposition why don't we take our 15-minute break now so you can uh stretch for a little bit and we'll come back um in about 15 minutes okay so you can go ahead do not talk to anybody don't do the outside research right okay thank you 18 minutes okay all right i'm told this clock is right today so we'll come back at 11 25. okay all right thank you okay which one does you have a disagreement on we might as well do it now before we go on to the next deposition uh sure um so the exhibit is it's invoices from dr kipper what number is it um i'm sorry it is that's correct and and we have no objection to the document coming in it's just we have a disagreement about the redaction all right if you want to come forward then maybe we'll take a look at the you said 1067 correct okay okay sure so are you ready for the jury are you ready for the jury okay i just make sure that's right thank you um so all right thank you nice just for the record i assume juror number 10 that that's your address to your employer because you need a letter from your employer is that correct okay so the court's going to do a letter for his employer so he can be released from work for six weeks so that's what that information is just for the record is just his employer's address okay all right thank you all right are you ready for your next witness yes your honor mr depp calls debbie lloyd okay right by a video by by deposition okay do okay california yes and you do not live or work in virginia correct correct have you at any time spoken with can you please provide your full name debra lynn lloyd and uh miss lloyd you live in california yes and and you work in california yes and you do not live or work in virginia correct correct have you at any time spoken with uh mr depp or any of his counsel um either in preparation for this deposition or for any other matter after you no longer work with mr dab yes do you recall who you spoke to i believe her name was camille and do you recall when you spoke to camille approximately two weeks ago and um what did camille can you discuss um she had asked me if johnny had ever thrown anything at me and what did you say no were there any other without the total of their communications with camille that was the only time that i remember speaking to her did you speak about anything else other than whether um and when you say johnny i assume you miss her dad correct yes did you um have any other with did you discuss anything else other than whether um mr def had thrown something at you um they had asked if i would be willing to go to virginia to the trial and are you willing to go to virginia to be a trial witness no um did you at any time did you and did you have any other you recall anything else you and camille spoke about not in detail you know how long the conversation was approximately approximately 15 minutes was it over the phone yes you recall at any other time having any other um communications with any other counsel for mr dab no there was somebody else on that call i believe from his side but i don't know who it was your call was a man or a woman amen um do you do you ever speak to adam walton i know an adam reached out to me a long time ago i don't remember a last name you're a psychiatric mental health nurse practitioner yes can you briefly explain what that is i'm a nurse practitioner that specializes in psych uh psychiatry and did you go to um where'd you go to school for that i got my master's from maryville university is that in california it's in illinois and um in missouri st louis missouri sorry no problem no problem um and i understand you're also a certified addiction nurse yes and can you briefly explain what that is um it's i had to get a certification in addiction nursing and what is addiction nursing and nursing that specializes in taking care of patients with chemical dependency issues and chemical dependency that's drugs and alcohol yes how long have you worked in those fields addiction nursing and uh mental health nurse since 2004. and would you agree that one of your specialties is concierge addiction services it was yes what are concierge addiction services um we would that's a good question i mainly deal with higher um higher end clients and provide care go to their home rather than have them come into facilities and would you at times provide 24 7 nursing care yes um and you'd also be a patient's travel companion for nursing care yes and you own uh your own company yes and what was the company's name turning point do you still own turning point yes and what does turning point do provides services it's actually no longer i still own it but we do i don't work with it anymore um it provides services to either nursing or sober companion services to patients and when did you start a turning point you don't recall the exact year does anyone else own it no how many people work at turning point um i'm the the only employee and what do you have contract nurses who work for you i did yes and what does turning point do now if anything sits dormant okay and when did when did it start to sit dormant about two years ago is there any particular reason why that's when i became a nurse practitioner and changed my career path um and where do you work now i work for headlines addiction treatment services what do you do there nurse practitioner and what is there a difference between a nurse practitioner and a nurse nurse practitioner um i can diagnose and prescribe medications underneath a doctor's supervision so when you were working at turning point or when you owned when you were working at turning point were you a nurse practitioner yeah what what was your title then registered nurse and um you you performed work for mr debt correct yes was that with turning point turning point was contracted through dr kipper can you explain how that arose how you began to work for mr depp through dr kipper and dr kipper was his doctor and he needed nursing services so dr kipper reached out to me and it's dr david kipper correct um had you worked with uh dr kipper before working with mr dab yes um do you know when you started working for mr dab approximately approximately i think it was 2015 or 16. okay and we can we can look at some documents and that may help um do you know how many patients you would work with with dr kipper before working with mr depp that would be a guesstimate okay you have any approximation 20. um and what when dr kipper reached out to you about mr depp um did he reach out to you by phone or by written communication by phone you'll recall what dr kipper uh told you he was looking for in regards to mr depp's care detox and detox from what originally i don't think i knew any of the specifics what did you come to understand mr depp was looking to detox from opioids any other um medication there any other drugs that mr deb was looking to detox from not that i recall do you know if mr depp ever took cocaine i never witnessed him use any cooking so did dr kipper contract with your company for care for mr depp i don't recall the specifics of how we were brought on um [Music] well okay how were you how was how were you paid through dr kipper did you have to um submit your time to dr kipper for deaf services did mr depp ever pay you directly did you ever get any gifts from mr deb yes okay what gifts did you receive from mr dad i remember getting a jewelry box and a um i forget what it's called like a notepad a fancy notepad i guess um it was um do you recall why mr depp gave you the jewelry box you can answer that i don't know why i believed it was a or a thank you and the same uh you believe it was a thank you for the with the fancy notepad that you received it was at the same time did you receive anything else ever from mr dab not that i recall um do you uh do you still do work for dr kipper i have not recently you recall when you last uh worked with dr dipper not exactly do you remember the year he stopped working with dr kipper no you recall the last time you've spoken to dr kipper this week i think what did you talk to dr kipper about this week he's my personal doctor so did you speak to dr kipper at all about um this case no have you ever spoken to dr kipper about your deposition no have you ever spoken to dr kipper about his deposition yes and you know whoever gorham is correct yes and who is she and she's a nurse that worked with us and uh miss forum worked for turning point is that right yes um and she [Music] um and did you hire miss form yes was aaron was uh miss borum uh a salaried employee of turning point no so miss foreign was a contract attorney a contract uh employee for a turning point correct correct so how in in kind of general sense how did that how does that how did that work with miss forum in turning point objection if you needed her for a particular case you'd hire her for that case yes yeah and uh you're saying your testimony is that you had hired miss form previously for other patients is that right before mr depp and miss her yes um and do you recall how um miss borum came to work uh for mr depp and miss heard and do you recall how miss borum came to work for mr depp and miss heard yes how did that happen what happened i was taking care of johnny and amber it was decided that amber needed some support so i brought her in for it for amber so were you mr depp's primary nurse yes and was miss borum amber's primary nurse yes and would you ever share responsibilities where ms gorham would perform nursing care for mr depp and he would perform nursing care for amber i know aaron covered for me a few times i do not believe i ever cared for amber and you said that a decision was made that amber needed nursing care yes who made that decision i don't recall can we put up attachment two and we'll call this uh lloyd exhibit one incendiary thanks look at one and this lloyd i'm showing you what's been marked as lloyd exhibit one um you'll see it's it's it's many pages um and we're gonna go through some of these during the day but just looking at it do you recognize what what this is yes and what is lloyd exhibit one my nursing notes okay and so these are notes that you created yes and uh these are notes you created for your care of mr death is that right correct and if any if it'll break you just want to go over let's see the whole thing i'm um you know i'm happy to let you do that uh just this save time rather than having you read 123 pages um but uh did you did you create these notes in the ordinary course business can you clarify what that means you created these notes as part of your job of being a nervous correct yes um did dr kipper ask you to keep these notes we just keep notes as nurses i don't recall so this is this is your normal practice keeping these notes it's not particular to mr depp correct correct um did you receive any training into how to keep these notes nursing school and um the notes are typed right yes okay did you [Music] bring a laptop with you when you were um working with mr dap yes well let's just go to the first one it says june 12 uh 2014 2300 you see that yes and 2300 that's that's military time correct yes so that's 11 p.m at night yes okay and uh it says rn and md met with patient to discuss plan and medication regime you see that yes the rn is you correct correct and the md is dr kipper correct and the patient is mr deaf right correct okay um so where it says uh 6 12 14 at 2 300 is that when you met with mr depp or is that when you wrote up the note that's when i wrote up the note okay so you may have met with mr depp at some other time before this sometime during that day okay so the the time you have here is when you wrote the note correct okay and would you typically type the notes as opposed to writing notes and handwriting and then typing notes correct okay um did anyone review the notes notes were sent to dr kipper how often would you send the notes to dr dipper i don't recall and was there um a system where he could see the notes or did you email him dr kipper the notes email so um is it your understanding based on these notes that the first time you met mr depp was on june 12 2014 yes and if we scroll down to the 6 13 14 um this says you you met with patient in his apartment correct correct so the next day you met with mr kip mr def in his apartment is that right according to my notes i don't recall okay and um in the second line you write he stated that he initially started taking opiates after some dental work and became dependent on them that is is that something that mr depp told you according to my notes would there be a reason you would write that if mr depp did not tell you that no okay and then you write patient is fearful of coming off of opiates but knows it's what he needs to do um so again that's something according to your notes that mr depp told you according to my notes yes um and then it says patient also expressed some emotional trauma which causes him depression and anxiety again according to your notes that's what mr depp told you according to my notes yes do you recall at all what the emotional trauma was that was causing mr death depression and anxiety i did not recall let me ask this again do you recall what the plan was for mr depp's detox as of the end of june 2014. plan in what regards where was mr depp's detox going to take place i don't remember when it was determined but i remember that it was after filming we would go to the island and that's the island that mr depp owns yes and you you went to the uh you went to the island correctly correct who else was on the island in this time when mr depp was doing the detox i know i was there i cannot remember if amber was there the entire time and some of johnny's staff and dr kipper came at some point how did you how did you get to mr depp's island flew and then what do you take a boat to the up to his island yes um and if we go to in the same document kipper 69 which i believe is page 17. there we go um you see where it says 8 8 14. yes and it says arrived on island today yes does that mean that you arrived on the island at on august 8th 2014. uh according to my notes okay and on august 9th um 2014 it says patient express fears of never feeling normal without his drugs you wrote that yes and is that something that mr duff told you according to my notes yes and if we go uh two pages uh kipper71 oh you can yeah there we go um you see where it says uh at the top uh md's flight has been canceled yes arrangements arrangements are being made for him to arrive on the island 8 12 14. so according to your notes dr kipper after the flight was cancelled was set to arrive on the island on august 12th 2014. according to my notes miss lloyd i'm showing you what's been marked as exhibit lloyd exhibit 2 which is alh 16110 through 113. do you remember uh texting with amber at all while um you were on the island with mr depp that is some of how we communicated yes and does this refresher recollection that amber was at least at some point on the island with mr depp during the detox yes the gray uh part of the text is is your text correct yes and the blue is amber yes and is in the gray part of the text um where it shows a phone number there is that here is that your cell phone number yes it's lloyd i'm showing you what's been marked as exhibit three text message chain between you and amber heard on august 16 2014 um and again in the gray box where it shows your a phone number that's your phone number correct and this miss lloyd i'm showing you what's been marked as lloyd exhibit four um text message chain between you and amber on august 18th 2014. you see that yes okay do you recall one on the island amber would be telling you how mr depp was doing according to these texts that's what was happening yes um do you recall how long you were on the island i do not um in a day in a day do you recall how long you would see mr death it varied um would there be reasons why it varied as to how long you'd see mr def in a day i don't recall what how it was determined how far away were you from where mr depp was staying five to ten minutes by foot or by something some other transportation by a john deere tractor and where what type of place where you staying in on the island it was a yurt yeah and you were staying with anyone i was by myself some of the time and then dr kipper was also in the yurt for some of the time and did the yurt have separate rooms yes and would you would you typically uh eat with mr depp married um and what was your when you were on the island what was your role in terms of mr depp's detox medication management and what do you mean by medication management to administer medications and was dr kipper the person who was prescribing the medications yes did as part of the medication management did mr def get a a bag of meds you can answer to the extent you know did i give mr deaf a bag of medications either you or dr kipper not that i recall staying on this last page for a second of lloyd four um the picture of uh looks like a pillbox right correct did would you have provided um either mr depp or miss heard mr depp's medications in a in a box like this yes okay well why don't we actually just take a break um right for this moment it would been about an hour um take up i don't know how five-minute break is there any reason to believe where you wrote rn received text from fiance that that's not a text you received from amber heard yeah lloyd exhibit five is a chart of text messages we received from in a production from mr death um it is death 7819 um you see the second entry entry 131 um yes okay and where in the third uh row there's your name and above that name is the phone number is that your phone number yes and you you would you would sometimes text message with mr depp to correct correct um you see it says in the body on that one row 131 i will come by 80 within an hour to drop meds off just in case how are you feeling your your head back on straight how do you see that i see that and this was a text you wrote some uh mr depp according to this do you recall um as of around august 26 2014 um what you meant by your head back on straight i don't recall and then mr depp responded to you you see in the next row pretty much i don't have the ability to take anything more on my back right now i'm fucking strong if my arm is dangerous i would cut off i would cut the fucker off i'm threatened by the love i feel i need to stop simple matt did you recall receiving that text from mr deb i don't recall no i don't recall receiving that okay you have any reason to believe you did not receive this text from mr depp no if we go back to um exhibit one and if you can go to um kipper101 and you see where it says 0125 under september 22nd 2014 yes okay and you wrote uh rn received texts from patients stating that he'd been in an argument with fiance and she quote had a nasty freakout end quote and he would like rn to come give him some quote some fucking knockout yum yum are an instructed patient to take prn neurontin 300 milligrams prn and seroquel 50 milligrams and that rn was on her way over you wrote that yes do you recall anything about what um the nasty freak out that um mr depp was referring to about amber i do not recall and then you see the note for uh 3 30 or september 22nd 2014. yes okay and again that's 3 30 in the morning right correct and you wrote upon arriving at the home patient was sitting in kitchen with scraped and bloody knuckles on right hand patients stated he punched whiteboard in kitchen after fight patients stated he'd been texting his friend explaining why he didn't show up to play music and fiance got upset that he was not giving her enough support and the fight escalated from there um you wrote that you wrote that no according to this yes do you recall going to mr depp's home and seeing him with scraped and bloody knuckles on his right hand i do not recall did you ever recall any incident where mr depp had claimed he punched a white board in the kitchen i do not do you have any reason to believe where you wrote that you wrote upon arriving at the home patient was sitting in kitchen with scraped and bloody knuckles on right hand would you have written that based on your observation of mr depp yes um on cooper 111 there's a there's a highlighted note at 19 30 for october 14th you see that a patient finished filming and was extremely agitated leaving the set patient kicked in the door of his trailer and refused to speak to director patient was verbally aggressive to another person on the set so no apparent for no apparent reason her md patient is to take xanax two milligrams to reduce his agitation at this time you wrote that according to these notes yes and was were these notes based on your observation of mr depp i don't recall would you go to miss would you did you ever attend filming where miss where mr depp was filming yes um where you wrote patient kicked in the door of his trailer and refused to speak to director that's based on your observation of mr deb i don't recall where you were a patient was verbally aggressive to another person on the set so no apparent reason you recall what that's based on i do not would it have been based on anything other than your observation of mr deb i don't recall if you had been told that mr depp was verbally aggressive would you have written that in your note i don't recall and the note above it for 1630 you see that yes you wrote rn and md arrived on set to assess patient so that's you and dr kipper correct correct um and you wrote patient appeared agitated and was short towards rn you wrote that according to this yes and um where you wrote patient appeared agitated and was short towards rn meaning mr depp was short towards you correct i don't remember you could that's what th that's what you that's what the note means right is there a reason and this note would have been based on your observation of mr depp at the time correct i don't remember and then you see under october 15th there's another highlighted um entry correct yeah and you wrote patient awake and states he slept from 2200 to 430 you see that yes patient continues to be agitated about work and is verbalizing having desire to escape with drugs you wrote that it's in my notes and that would mean that you wrote that note correct correct and you would have written that note based off mr depp telling you if you had a desire to escape with trump that's correct i'm sorry did you answer yes i said i don't remember and this is exhibit aids um more text between you and mr death um feel free to look through it okay mr depp wrote i'm all i'm all right confused as fuck she said nothing of last night and most certainly not one thing about of the exist of the rap party's existence all the proof that i predicted last night how will i look at her when she gets back professing her undying love all a fucking lie i for sure unfortunately wouldn't mind some company but i have inundated you with too much already love love me um that's a text you received from mr dab i don't recall is it at nine um and this is um more text between you and mr depp and that you can take a look through on november 11 2014 um mr depp wrote all good haven't read her text yet i'm feeling so fucked why was she at the goddamn rap party until 5am did aaron say anything the lies are so clear now they're making me nuts wondering what was so interesting to keep her there that goddamn long please ask aaron i must have truth i need it it's not the easiest thing to do at this point though it's been a shitty and painful experience i cannot help but hear her voice begging and crying she wants to change and is going to change etc help i don't know what's real and what's paranoiac jealousy you receive that text from mr deb i don't recall and you don't recall did you recall ever mr depp not feeling trust for amber i don't recall while you were working with mr depp did he smoke marijuana i don't recall you recall if he took any if not smoke marijuana ingested marijuana in any sort of way i don't recall you live at 10. can you think of another instance where there was a patient without giving me the patient's name or information where they were allowed to continue to take marijuana while detoxing from other drugs i don't recall exhibit 11 is is lloyd two through five um do you recall producing documents in this matter yes you produced text messages with mr depp and with ms heard yes and this um and this is a text message between you and amber um starting on december 26 2014 you see that yes okay um and and you understand that you're in the the text from you or the blue correct okay all right yeah you wrote sorry to bother you is jd up he has an important appointment at 2pm and he isn't responding to me hope you guys had a beautiful christmas and amber wrote hey there yes he is he's opening presents with lily rose what appointment is he being picked up uh who's lily rose johnny's daughter did you ever see mr def super stone when you were working with him i don't recall does that mean that you never saw him stoned or you just don't recall one way or the other i don't recall one way or another do you know who the wit is is amber's sister okay do you recall any time where mr depp seemed confused about something that had occurred i know did you ever recall mr depp wondering if he and amber had a fight or if he was dreaming i don't recall do you recall mr depp ever not taking the medications he was prescribed yes did you recall mr depp sometimes potentially doubling the medications that he was prescribed i recall thinking that at times did you believe that mr depp wanted to detox off of drugs what was your answer yes and how did mr d how did mr depp show you that it was on his own free will that he hired us to be with him and then did mr def have any um relapses with drugs when you were working with him i don't recall you recall mr depp and working with him ever take cocaine not that you necessarily saw him but that you understood that he took cocaine i i never saw mr deputy's cocaine did you have any understanding that mr depp took cocaine whether you saw it or not i don't recall did you administer drug tests to mr dap in the beginning did you see the results of the drug tests yes did you see mr depp being positive for taking cocaine i don't recall do you recall accompanying mr depp to australia yes okay and you recall accompanying mr deaf to australia in around march of 2015. i don't remember dates do you recall accompanying mr depp to australia when he was filming pirates of the caribbean five i do um where were you staying in australia in relation to mr death distance wise yeah how far away were you from about 30 minutes okay when where was mr depp staying in a rental house and where were you staying in an apartment and what what city were you in i don't recall the name okay and was dr kipper there with you he came and went did you fly to australia with mr depp sometimes i did and other times i flew on a commercial do you recall talking to dr blaustein about mr depp in australia i do not do you recall mr death not doing very well while he was in australia as of march 1st 2015. i don't recall anything around that time do you have an understanding as to what mr depp was doing with marilyn manson did you ever tell dr kipper that mr depp was doing what he wants with with marilyn manson i don't recall do you recall marilyn manson being in australia with mr deaf i do not it says debbie is worried and somewhat exhausted um do you recall being exhausted while in australia and working with mr depp i do not if you have any reason to believe that what dr pipper wrote is not true i do not um we can take this down and um go back to uh exhibit one and if we could go to kippur 157 you see three seven fifteen i do okay before i ask do you recall how long you were in australia with mr deb no however long the filming of pirates was okay and at 3 7 15 at 11 30 you wrote md received a text message from client that he'd been arguing with white and that he had cut his finger according to patient his assistant and security were on their way to pick him up you wrote that according to my notes yes there any reason to believe you didn't write that note no okay do you recall dr kipper receiving a text message from mr depp about mr depp cutting his finger i don't i don't i'm just what this note says do you recall going to mr depp's house after learning that he had cut his finger yes what do you recall about that that we went to the house and he he i actually i don't even think i went in at first dr kipper went in and he had cut his finger and we took him to the emergency room or his finger had been cut you recall what the house looked like when you went in yes what did the house look like it was a mess hey can you describe how it was a mess i don't remember details but i remember there was some writing on the wall and i remember a smash tv do you remember what any of the writing said on the wall i did not did you um and you said you were called to smash tv yes okay do you recall um was amber in the house i don't recall you recall seeing amber that day no i don't recall do you recall what rooms you went through of the house mr duff's house i remember looking for his finger in the downstairs area and what was in the downstairs area but what rooms were in the downstairs area it was like a pool table entertainment room did you look anywhere else around the house i don't recall what was the um pool table entertainment room was that a mess i don't recall do you recall um going into the kitchen of the house i don't recall if you recall finding mr depp's finger i did not you know who found mr depp's finger yes ben ben who i don't remember his last name who was ben in relation to mr depp he's like our house manager he recall where the finger was found i did not do you recall if mr depp appeared to have uh dirt grime and paint on his hands yes he did um do you recall seeing any glass anywhere i do not do you recall smelling any alcohol i do not who else was with you when you went to the hospital uh malcolm and stephen and who were malcolm and steven uh stephen was his assistant and malcolm was one of his security guards do you recall who was holding the piece of finger that had been cut ben brought it to the er what did ben bring the finger in i don't recall was it on ice the finger i don't recall did you ask mr depp how he cut his finger i don't recall if i asked him did you ask anyone how mr deputy cut his finger i don't recall do you have any understanding as to how mr duff cut his finger i heard different stories from people what were the different stories you heard i had heard that amber threw a bottle of vodka at him i had heard that he slammed it um with a phone do you recall who you heard that amber had thrown a bottle at him i do not you recall who you heard that he slammed it on the phone i do not those the stories that you had heard did you hear it on that day of march 7th uh or march 8th 2015 or later i don't remember did you ever talk with mr depp about how he cut his finger i don't recall conversations okay did you ever talk with dr kipper about how mr depp cut his finger i don't recall specific conversations did mr depp um how long was mr depp in the hospital for i don't remember did you have any concerns about the supervision of mr dapp i know at times we would go days without me seeing him but i don't know specifically what this is regarding were there issues with the nurse supervision while in australia i don't recall specifics you have no recollection of of dr kipper withdrawing his care of mr depp for any period of time no i know at times it was discussed when he would miss appointments but i don't recall him ever actually going through withdrawing his care do you recall there being concerns about mr depp taking substances that he shouldn't have been taking i don't recall what that was regarding do you recall having major concerns about leaving for australia with mr dapp and you're not while that's going up um miss lloyd the day that uh mr depp cut his finger you don't recall seeing amber one way or the other is that right i do not exhibit 16 um is uh lloyd 140-145 and mr depp responded it's sad i love you so much little debbie and of course kipper too he was right though i did feel a bit of a sting when his letter paper trail arrived on the off chance that i croak which i also understand just never heard of anyone being fired by their position before so i'm kind of proud of that little fact too i love you kid even attempting saying thank you to you would be like a monkey trying to fuck a football it's just simply impossible i wish things could have ended on a better note all my love nurse shark jd do you recall receiving this text from mr deb i don't this text was on your phone correct correct would mr def call you nurse shark yes would mr depp call you little debbie yes and okay and you don't recall mr depp saying never heard of anyone being fired by their physician before i do not um and then you respond on the next page i love you too and hope this is not the end be safe and be smart my son you sent that text to mr depp according to this yes and you know what you meant by be safe and be smart i don't know and then mr depp wrote i've i've been off of for three days the doc jumped the gun also please thank him for the motrin and the black baclofen they work a treat for amputated fingers god damn i love that weird fucker no matter what you receive that text from mr depp according to this do you understand what is meant by i've been off of for three days i do have no idea okay you respond so glad to hear you have been off no matter what i just want you to feel better yeah i don't know what we were referring to let me go down to the next page you're right i'd be more than happy to come back and help you with pain management and peridol injections i know kipper loves you and would always want to continue your care if you're no longer using you wrote that to mr deb according to this and this text was on your phone correct correct what did you mean by uh kipper loves you and would always want to continue your care if you're no longer using i don't know just what it says i don't know what that was regarding you don't know what no longer using is referring to i do not and then mr depp wrote i don't know i'm going to stop it all except whatever i was on before and just deal with it you received that text from mr depp yes do you know what he was referring to where he said i'm going to stop it all except whatever i was on before and just deal with it i do not know what that's regarding and then you wrote i respect whatever decisions you make i'll be sad to leave the crew as i love you all i hope to always be in touch even if you choose not to continue a working relationship miss you already i will get in touch with kevin and get my stuff out or 72 soon hugs you wrote that message to mr depp according to this okay and then mr depp wrote take care darling i cannot ever thank you enough all you've done for me on the junky side and the broken heart side you've been a lifesaver literally we'll be seeing each other again sweetheart love you so much little debbie and so does my entire crew x you received that text message from mr depp according to this yes i'm gonna cry miss lloyd i'm showing you what's been marked as uh exhibit lloyd 17 uh which is lloyd 158 through 160 um which is a text message between you and johnny depp uh from your phone you see that yes okay and um on march 27 2015 um you wrote uh good morning sleepyhead aaron came by to give you a shot you were still sleeping um take the pill form of tutorial to hold you over and i'll check in with you when i've done my appointment in beverly hills uh and then you wrote have you taken pill if not hold off and aaron is on her way to give you injection do you see that yes okay and you wrote that text message correct for those messages yes okay and then on the next page um mr depp wrote the fucking pain is as bad as when it was cut off horrific uh you received that message from mr depp yes and he's talking about his his finger there correct yes and you received that text message from amber correct correct right and then you wrote he's at the studio with marcus and is supposed to call me when he gets back to the lofts i will drive up there if you want me to always feel weird showing up unexpected do you want me to go you wrote a text message to amber i don't recall but according to this yes do you know who marcus is what was his relationship to mr deb okay and then you wrote i know stephen is there let me just check in and see what i can find out i'll get right back to you who's stephen his assistant do you ever remember checking if mr death had been taking cocaine i don't remember specifically asking any questions related to that is there any reason to believe that you didn't do what you said in your text message no do you recall what you were giving mr death valium for i do not is lloyd showing you again what's been marked as exhibit one and i'm gonna point you to um kipper 167. which is from april 13 2015 okay okay do you see it you see the the entry for 1500 yes all right um you wrote um bandage changed and hand exercises done at appointment with surgeon's office per rn at surgeon's office and occupational therapist hand is healing well and finger has good range of motion exercises to be done three to five times per day patient is in good spirits and said he's not smoked marijuana in three days states he feels majority of his issues with his wife have been from him using drugs and alcohol patients states he will no longer sneak use and wants to enjoy clarity you wrote you wrote that yes and these are part of your nurses notes yes and mr death told you that he felt the majority of his issues with his wife had been from him using drugs and alcohol according to the note yes and mr depp wrote he will no longer sneak use and wants to enjoy clarity according to the document yes um what is being referred to as no longer sneak use i only know what's stated in my notes okay would it be anything other than drugs or alcohol i don't recall was there anything that mr depp was sneaking other than drugs and alcohol that you were concerned about i don't recall if we go to uh 175 kipper 175 on this page on this document um it's notes for june 28 2015 um it talks it says at 1700 rn received initial results from brain mri no obvious abnormalities noted final report will be done tomorrow patient informed of results do you recall why mr depp received the brain mri he was having chronic headaches and then you see at six at 6 30 at 1300 yes okay um and that's and that's highlighted yeah okay um you wrote rn arrived on set to visit patient he was upset due to having an argument with his wife patients stated he had taken about four's annex one milligram over the past 24 hours to deal with the stress he was feeling the patient was able to express his emotions appropriately the patient stated that he had not slept the night before due to argument with his wife that's a note you wrote correct and that's based off of information provided to you by mr depp i i don't recall well we're according to my note yes so mr depp told you he'd taken about four xanax one milligram over the past 24 hours correct into my notes yes okay and then at um 1920 on june 30th it said patient had another argument with his wife patient was anxious and was asking for medication to help calm him down sarah call 50 milligrams administered you see that and that's a note you wrote yes do you know why your nursing notes ended on june july 1st 2015. i do not how could you continue to care for mr depp as his nurse after july 1st 2015 i do not recall my last date did you prepare nursing notes through the time that you were mr depp's nurse i did okay and did you provide those notes to dr kipper i did this lord i'm showing you what's been marked as exhibit floyd 19. this is an email from dr david culver on june 27 2015 that you were copied on do you see that yes and do you know who dr culver is i don't recall exactly who he was did you understand that mr depp went to a specialist first finger yes okay you're copied on this email i see my name copied on the email yes okay and you recall the doc that mr depp was treated for a bad crush injury for his finger i recall him being treated for a finger injury i didn't realize this is the first i remember hearing it was a crush injury and that's the email you received from dr caldwell correct i'm seeing this today i don't recall receiving this email is there any reason you believe you didn't receive this email no i just don't recall miss lloyd i'm showing you what's been marked as exhibit 20. which is a text message chain between you and mr depp from your phone you see that i see that um on july 5th 2015 mr depp wrote to you canceling the squeezing and need needles tonight need to get the recluse out of his cage and his brain you received that text message from mr depp yes and then you said how how come you're canceling you okay not sure what you mean by the rest of your text please let me know if you need anything i'm here if you want to chat or want me to go hang at the house with you you wrote that text to mr dap yes and then mr depp wrote to you i'm in a very anxious and painfully confused state rather not get into details but in a nutshell problems with family my company the ex business manager and my fucking jumbled brain will need refills of meds tomorrow thanks honey x you received that text from mr depp according to this yes okay and mr depp talked about how he was having problems with his family that's what this states and mr depp was having problems with his company that's what this states and mr depp was having problems with the ex that's what to say and mr depp was having problems with his business manager according to this text and mr deck was having trouble with his fucking jumbled brain correct according to this text i'm just going back to exhibit one for a moment if we can go back to kipper 167 miss lloyd um i'd ask you to look at the uh entries for april 14th the bot is at the bottom okay um you wrote at 1400 rn and md arrived patient's home to have meeting to set treatment plan and boundaries while traveling in australia you wrote that and the rn is you correct yes and the md is dr kipper correct and do you recall what the treatment plans and boundaries were while traveling in australia as of april uh 2015. i do not recall and then if we go to the next page um you see the april 15 entries uh yes okay and at 12 15 you write arrived at patient's home assistant was in hallway and informed rn the patient was in a bad mood and told the assistant he did not need anything from him today aaron was let in home by security and knocked on patient's door to let him know she was there patients screamed what are an informed patient she was letting him know she was there and would be downstairs about five minutes later security came into house and informed rn the patient has told security to get everyone out of his home and he did not want any more unexpected guests rn left property and informed md of the events per md drop tomorrow meds off with security and do not reach out the patient again wait for p patient to reach out to medical team you wrote that note correct and this document also this note also talks about you informing dr kipper about what happened that in this note correct yes this lloyd i'm showing what's been marked as lloyd 21 um you see at april 15th at the bottom there's a text from mr depp yes and he wrote hey sweetheart i'm so sorry about today i thought you were stephen whom i'm not particularly enthused about for his loss of loyalty and his loss of memory he has tried everything to fuck me over as far as traveling with my wife he also bursts into my fucking house like it's goddamn grand central station i'm truly sorry if i upset you if you like you can give me some morphine to see if my tongue and penis touch all my love jay did you receive this text from mr death ahmed appear so i don't yes okay um do you do you have any understanding as to what mr depp was referring to where he says um steven tried everything to fuck me over as far as traveling with my wife um first of all um going back to um your work for dr kipper um you said i think you testified earlier you cared for multiple patients that were of dr kipper is correct correct and um when you would care for dr tipper's patients how would you um report their status to dr kipper objection vague uh multiple different resources phones texts verbal tech verbal and written and how often would you report to dr kipper about his vision it responded i mean it depended on different patients varied and i believe you testified earlier that you maintain nursing notes for those patients correct correct what type of information did you maintain in these nodes mainly we provide a care given in patients responses to care given or any external factors that could affect the patient is there any information that you would not include in your note i'm not i'm sorry i didn't catch your answer i'm not specifically other than dr kipper does anyone else review your note if another nurse was to work on the case they could uh have access to the notes and um does dr kipper advise you on any information that should be maintained in your notes not directly has he ever told you that certain information should not be included in your notes no how long have when did you um become a registered nurse 2004 and have you been employed as a registered nurse um from that time up until you became a nurse practitioner yes um in your time as a registered nurse have you ever had a patient that you suspected was the victim of domestic abuse no do you have any professional responsibility to uh report domestic abuse yes and what is that responsibility i'm a mandated reporter for child elder abuse and any suspected injuries how would you define suspected injuries if i was to work in a facility and somebody came in and reported or i felt that it was a result from an injury caused by somebody else um who do you report the abuse to in that instance i've never had to report abuse okay do but um given your professional responsibility do you know who you would report that to in that event i do not um in your time as a registered nurse have you ever witnessed physical violence by one of your patients i do not recall ever witnessing any violence and when you say any violence does that mean perpetrated by your patient or against your patient or just just in general violence so you met mr deb either on june 11th or june 12th of 2014. according to him i know yes okay have you ever spoken with him before that date no uh when did you first meet miss heard i don't recall do you recall when you first met her not specifically when but do you recall the instance when you first met her i do not when you uh first met miss her did you have an understanding as to what her relationship to mr deaf was at that time yes and what was that understanding that they were in a relationship were they engaged when you first met them i don't i don't recall the dates they got engaged were they married when you first met them no did you attend their wedding yes and where was that on the island in the bahamas um can we take this down and please pull up um what i've marked as document be what 23 now just for the record um i believe these are the nursing notes you were looking at earlier um this is just has a different um production number and i just thought it might go more smoothly if i i'm calling out the correct page number so um just to establish this do you recognize this document here yes and these are your nursing notes that um i believe you looked at with this mr needlehop earlier correct okay um i'd like to direct your attention to the entry for june 17th of 2014 which is on age with perfect there it is um this is a note you prepared correct correct and at the time that you prepared this note were you in boston with mr deb according to the note yes now in the subsection that says 2 23 30 um do you see where it says accompany the patient fiance assistance and security to concert yes okay and in this note patient refers to mr depp is that right yes and beyonce is misheard yes please reflect refresh your recollection that uh mr deaf and ms heard were engaged in june of 2014 according to this yes um is this the first time you met miss heard i don't recall when i met her um further down in the note you see where it says assistant was also asked to pass on rn and md's numbers to fiance as we would both like to speak with her and to obtain her input towards you see patient i'm referring to yep okay um rn is referring to you in this instance correct and um md refers to dr kipper correct um do you recall why he wanted to speak with miss hurt at this time i do not um do you recall ms hart expressing interest in participating in mr duff treatment i don't remember the events other than what stated in my notes um your phone number was given to ms heard though correct correct so 24. um floyd do you recognize this document so i think that you did not prepare this document is that correct correct um ladies and gentlemen that's probably a good break to go ahead and have our lunch break so we'll go ahead and break until two o'clock to not discuss the case with anybody known to me outside research okay we'll come back and continue this deposition so all right so we're tuned at 2 p.m correct okay thank you can we get 25 do it's fine do we need the microphone for this yeah so you can have a seat that's fine microphone maybe you can just talk real loud for me hold on just a minute i really can't hear you that's why you start pain okay oh you have you have a problem with a hernia yes okay and it's it's really bothering you to the point where you can't concentrate yeah it's two days i don't know why he bothered me too much i know but what i want to make sure you understand if i excuse you today i'm excusing you from the jury i'm trying to do go today home and take medicine and rest get ready for tomorrow okay i can't do that i i can't i can't have that done we have to keep going so i mean has it been bothering you other days in the while you've been on the jury no today you start now never a bother more than one two week i'm here okay but it might bother you also tomorrow i'm not sure but i'm trying to do my best to i know you're trying to do your best but i want to make sure you're healthy too i don't want you to to ruin your health for this all right just sit there for a second if i can have the attorneys all right sir we just want to make sure you're healthy and everything so we're going to excuse you from this jury okay all right just take care of yourself okay all right thank you all right you can come back thank you all right yes ma'am do you have something before the jury comes in okay which one 548 perfect okay all right okay 548 is done all right i did have one question um there seems to be a few oh you can that's okay you can stay there we don't have the jury there seems to be a few exhibits i just want to make sure of you gave us we have everything that you just gave us earlier from dr kipper's deposition but i just want to make sure if there were redactions needed for 395 or 414 or am i using mine for that i just want to see i mean i can just give you the numbers the ones i'm not sure about and you can look at it and we can move on i just 405 455 304 307 395 and 414 i'm just not sure if those i'm waiting for redactions or if i'm using the ones i'm going to use and then you had one that uh i'm not sure if you said 1083 or 283. so if you could let me know i i heard 1083 as the exhibit number jamie heard 283 so i just want to make sure we get the right one that was with dr kippers you said 1063 then you said either 1083 or 283 and i'm not sure which you can get back to me on it mr nadelhoff i don't want to catch you off guard 405. oh there you go 283 jamie's always right that's good good to know okay all right if you want to hand those up that'd be fantastic all right is there anything else before the jury sure your honor just for the record um plaintiff's exhibit uh 47 plaintiffs exhibit 48 and plaintiff's exhibit 41 were also used and offered during kipper but i've got dr kipper's deposition i believe i passed the redacted versions of those up to you yes we have all of those okay thank you i think that should be everything if not we'll we'll get back with you thank you know where to find you all right okay are you ready for the jury then all right thank you um thank you ladies and gentlemen just to let you know juror 25 has experienced some health issues and obviously your health is a top priority for us so i went ahead and excused him for the jury and that's why we have alternates so okay all right all right thank you all right we can continue with ms lloyd's testimony where it says this protracted therapy will include 12 step private counseling and personal psychotherapy personal psychotherapy and couples therapy with his fiancee amber both are in agreement to this plan do you see where i'm referring yes do you recall that couples therapy was the component of mr depp's treatment i don't recall what was that between him and the doctor you recall mr depp and miss heart attending couples therapy together yes if we could turn to the next page here and then at the top it says i met with amber for 90 minutes and discussed the above and her concerns that he be strictly monitored and supervised um do you recall dr kipper meeting with with amber early on in mr duff's treatment i do not if we could bring back up um document b which is now marked as me too is that correct 23 23. um can we please go to the entry for june 24th 2014 which is on depth one six six one okay okay now um with respect to the entry for june 24th 2014. this is a note this is an entry you prepared correct correct and the first line says rna met with patient's fiance to inform her a treatment plan for patient do you see that i do um does this refresh your recollection that you attended a meeting with dr kipper and ms heard concerning mr depp's treatment i don't recall the meeting do you have any reason to doubt that this meeting occurred yes do you have any um other than what's reflected in this note do you have any other independent recollection of any such meeting with dr kipper and i do not okay um if i could direct your attention just to the last line of the note it says here um she was encouraged to call rn or md with any questions or concerns that might arise do you see that i do um throughout your treatment of mr depp did ms herd reach out to you with questions and concerns yes you have your phone number correct yes and i think we saw some text messages that mr nadelhof was asking a question where she misheard was reaching out to you correct correct um when mr depp became your patient did miss heard ever show you any pictures of mr death i don't recall do you recall miss heard showing you any pictures of cocaine i don't recall did do you recall mr ever showing you any audio recordings of mr deb i don't recall um okay i'd like to move on to the um mr beth's detox and that was on his private island correct correct um and you travel you travel down to the island with mr deb is that right i don't recall i'd have to it should be in my notes um we can look at those in a moment um but you you were on the island with mr depp for the majority of his detox correct yes and when you um were on the island did you see where mr depp was staying yes and um was miss heard staying with him in that location as well yes and what did their accommodations look like can you be more specific what type of structure were they staying in it was a house um we pull up um document e which is a short video here's somebody and for the record this was produced as depth 9811. burying exhibit 25. let me know whenever you need me to play council uh please please play thank you uh miss lloyd do you recognize the location reflected in that video yes and uh what is it it's the johnny's home on this island and is that where he was staying during the detox process yes is is that video consistent with how the house looked in august of 2014 yes okay um is there any part of the house that's not reflected in that video the bathroom wasn't in the video when you were on the island where you were personally overseeing mr dev's detox process correct correct and how often would you um see him in person during that as an answer it married did you see him in person at least once a day i cannot recall when dr kipper arrived you recall how often he would see mr duff i do not what substances was mr doc excuse me what what substances was mr death detoxing from opiate if you detoxing from any other substances not on the i don't recall um have you overseen other patients detox detoxing from opiate before you were caring for mr death yes how many would you ask me hundreds hundreds what what is that process what does that process do to the person physically they go through withdrawal symptoms and we medicate them and what type of withdrawal symptoms have you observed nausea vomiting body aches um hylo erection restlessness anxiety is there a time during the detox process when those symptoms are typically the most acute what what stage in the process is that typically day three through five or six how would you describe mr depp's physical state throughout the detox process i don't recall specifics i'd have to refer to my notes how would you describe mr adept's psychological faith throughout the detox process i don't recall i have to review my notes um all right let's go back to your notes then which i believe is exhibit 23. okay great could we first go to the entry dated august 8 2014. okay um ms lloyd does this refresh your recollection as to when you arrived on the island to assist mr depp in his detox process according to my notes it was august 8th okay and so as i think we established earlier you met mr death in in june um fair to say that you had known him for about two months at this time correct okay um can we please go to the entry for august 11 2014. okay um and this is a note you prepared yes okay um if you need to take a minute and read it over um just let me know when you're done go right into it okay okay um uh fair to say that this note reflects that mr depp was experiencing discomfort on this date according to my notes yes it says he was experiencing muscle spasms chills and pains right correct did you personally observe mr depp in this state according to this note it does not appear i did okay um are these symptoms typical during the detox process yes yeah okay um can we please go to the entry for august 12 2014. okay um and i believe we look you looked at this earlier but i'd just like to direct direct your attention to the last line in this first paragraph and be arriving this morning and we'll assess the patient do you see that where are we on what so directing your attention to the um august 12 2014 entry and yes yeah sorry um and so based on your note it appears that dr kipper arrived on the island on august 12th is that correct correct okay um was the plan always for dr kipper to come down to the island to attend to mr depp i don't recall um do you recall any issues in your caring for mr debt prior to dr kipper's arrival do you recall any medical issues arising with mr depp before dr kipper arrived that caused you concern i don't recall um if there had been a serious medical issue with mr death prior to dr kipper's arrival would that have been reflected in your notes yes if mr depp's behavior had been unmanageable prior to dr clifford's arrival would that have been supplied yes um can we please go to the next entry for august 13th um and miss lloyd this is also a note that you prepared yes now i'd like to direct your attention to the portion of the note that starts with 13 40. um again this is military time is that right correct and i think you testified earlier this is the time that you prepared the note not the time of the events reflected in the note is that right yes sometimes i mean i i don't recall specifics but sometimes they were at times and sometimes they were done later so generally speaking when you prepare these nursing notes um how long after the events reflected in the note was the note actually prepared by you very okay okay so directing your attention back to the portion that starts with 1348 um do you see where it says patience fiance to say he's it wasn't feeling well md orders phenos 64.8 milligrams narotten 600 milligrams stat patient and fiance informed that today and tomorrow will be the most difficult days and to keep in close contact with us do you see that yes um do you recall informing mr depp and miss heard that the following days would be the most difficult just what was stated in my notes can we please go to the entry for august 17th 2014. do you see that i do and this is a note you prepared correct um do you recall um this specific event i do not have any reason to doubt that what is reflected in your note is accurate no okay so when you wrote um rn and md foundation sitting quietly on his board you believe that's an accurate um recitation of how you found mr depp on this date correct when you wrote that he was calm and stated he was frustrated um you have no reason to doubt the accuracy of that statement correct um could we bring back up um exhibit 23 and specifically go to um the august 18th 2014 entry which is on deb one six seven seven um miss lloyd i'd like to direct your attention to um well first of all this is a note that you prepared correct correct okay and i'd like to direct your attention to the end of the note which is actually on the second page or the next page um you see at the end here where it says patient was escorted back or escorted to bed do you see that yes um would that have been you who escorted mr dub to bed i don't recall um you testified earlier though that you did um see mr death in his the home that he was staying in on the island correct correct um and it says plan is to leave the island tomorrow see that i do and directing your attention to the next note august 19th do you see that it says um next to two three three five arrive back in l.a yes okay so um does this accurate really excuse me does this accurately reflect that um you left the island on august 19th 2014. according to these notes yes um i'd like to direct your attention to um the august 20th 2014 entry which starts on the next page and then um if you go to the next page as well you can see that there's another entry for august 20th 2014. do you see that oh yeah yeah okay um on on this page here i'd like to direct your attention to the portion that starts with 12 30. do you see that yes um now it says here rn and mv spent time talking with patients you see that i do um this would have been you and dr kipper correct correct and does this reflect that you spoke with mr depp in person i don't recall i would yes and um the rest the note goes on to say patient expressed frustration with the detox process and was not liking how the phenobarb was making him feel initially he stated he was done with the process and no longer wanted md and rn services after processing his feelings and realizing how far he had come and that part of his wanting to give up was due to tensions between him and his fiancee patient fiance rn md came up with a plan for fiance to take a few days for herself and patient was willing to continue treatment but was going to refuse phenobarbital from this point forward do you see that i do okay did i read that correctly yes um do you recall [Music] tensions between mr deaf and miss heard at this stage in his detox process yes and what do you recall about that i recall johnny feeling that she was trying to interfere um in what way did he feel she was trying to interfere by reporting to us things that he didn't feel were true can you think of a specific instance where ms heard reported something to you that was you found out later was not true i can't i cannot remember specifics um do you recall the plan for miss her to take a few days for herself i don't recall specifics but you do recall that there being tension between mr deb and miss heard around this time yes and do you recall that having an impact on mr depp's treatment i don't recall specifics let's go on to the entry for august 21st um first of all is this a number you've prepared it is um directing your attention to the portion that starts with 1900 um first line says meeting at md's house was quite stressful for patient do you see that i do do you recall attending a meeting with mr deaf at dr kipper's house i don't recall uh the next line says him and his fiancee are having a hard time communicating and understanding each other's point of view and feelings do you see that thank you um do you recall any specifics about this situation i do not um a couple sentences down it says plan is for fiance to start therapy tomorrow do you see that yes um do you recall that miss heard um started therapy shortly after mr depp's detox process i don't recall do you have any understanding as to why misheard was starting therapy i do not uh directing your attention to the entry for august 27 2014 which starts on depth one six eight seven or eight six excuse me one six eight six yep um again this is an entry you prepared it is um okay do you see where it says receive text from patient's sister that patient had been recording music with his friend until five and did not go to sleep until seven and is currently sleeping yes and who is um mr depp's sister that's referred to here christy and at this time have you met christy before i don't recall have you met christy before yes how many times i don't know more than once more than once yes um at this time have you communicated with christy about mr depp's treatment before i don't recall um okay the entry goes on to say sister stated that patient and his fiance had had a disagreement last night and that patient was able to remain calm and handle the situation appropriately do you see that um do you recall miss uh do you recall christy telling you that did you know see the portion of the note that starts with 13 30. i do the second line reads patient expressing feeling about argument with fiance and feels relationship is putting unwanted stress on him right now do you see that did you um do you recall this exchange with mr depp sorry i didn't catch it like i'm sorry i do not okay um based on this node you can you tell whether this was a conversation you had in person with mr depp based on this note yes um do you recall on other occasions mr depp expressing to you that his relationship was putting unwanted stress on him i'd have to review my notes um okay directing your attention down to the portion of the note that says that starts with 2130 um it says patient back home her patient he has a long he had a long conversation with fiance and they both understand that right now is a time to work on themselves as individuals patients fiance now has an rn to help her anxiety and to monitor her while she's starting a new mood stabilizer medication do you see that you do um who was i believe you testified to this earlier miss heard's um nurse was was aaron forum is that right and miss borum um was an employee of yours that correct she was an independent contractor okay um but you you placed her dr kipper is that right correct okay um do you recall when this um forum was assigned misheard i do not recall do you have any understanding as to why um ms heard needed a nurse other than what my notes state i do not do you recall witnessing um misheard being anxious or having anxiety i do not recall um now the last line here says patient feels this will take some of the stress off their relationship and in return if you go to the next page take some stress off of him did i read that correctly um do you recall why mr duck death felt that ms hurt having a nurse would reduce the stress on their relationship i do not recall [Music] from your perspective was it important to mr deaf treatment that his stress be reduced best and why is that any patient going through detox or changes always important to relieve as much stress as you can from them um let's go to the entry for september 10th please which is on depth 1694 and continues on to 1695. september 10 2014 entry this is your entry grad you prepared this right all right sorry and um if i could direct your attention to the portion that starts with two three three zero which is actually on the next page um the first line says met with patient he complained of body aches and nausea do you see that and does this reflect that you were physically with mr death at this time it would yes okay um a couple sentences down it says and this portion is highlighted here while rn was visiting patient beyonce came in and tried to start argument with him patient was able to stay calm and talk his fiance down you see that i do do you recall the incident reflected in this note i do not do you recall any instances where you witness misheard um try to start a fight with mr depp how many instances do you remember i don't recall specific numbers do you remember at least one yes do you remember more than one yes more than two i don't recall specific numbers what do you remember about that first instance that you can remember i remember one night trying to leave the penthouse and amber standing in the elevator and not letting us leave uh why wasn't she letting you leave i she didn't want him to leave had they been fighting previous to that point i wasn't there previously and what's the other instance you remember i can't remember specifics um you have any reason to doubt the accuracy of what's reflected in your note here no do you have any understanding as to what you meant when you said patient was able to remain calm was able to stay calm excuse me and talk his fiance down i don't recall the events of that note have you seen mr deaf and miss her get in a fight before this date i don't know let's go to the entry for september 12th please um and this is a note that you prepared as well miss boyd is correct okay um the first line here says rn md visited patient at work do you see that you do um and so this reflects that both you and dr kipper went and saw mr death is that right correct um and the entry states here patient expressed some concerns with beyonce's behavior and how it is adding stress to his life do you see that um do you recall this mr dub saying this to you in this instance i do not um do you have any reason to doubt the accuracy of what's reflected in your note i do not um could we please go to the entry for october 22nd 2014 which starts on uh one seven one seven and continues on to dep one seven one eight my notes are different what's the top of the i see the top of that just so i know what i'm looking okay okay so um first of all this is also a note that you prepared correct correct um and if you want to take a minute and read through the note i know it it goes on first two pages okay just let me know when you read through it okay um fair to say that this note reflects that you and mister are in georgia this when this the events in this note occurred i think we were at the end it says now in georgia i would i i don't recall but it the travel day well you see above that where it says 10 22 and then below it it says now in georgia yeah okay um so based on your notes you were in georgia on october 22nd 2015. do you recall being in georgia with mr depp yes um do you recall who else was with you in georgia i don't recall who was with us but i the the purpose of the trip was to visit amber on location okay so so amber was in georgia as well yes okay um now dressing your attention to the portion of the entry which is on the next page and begins with 15 30. it um here um he requested an emergency session with the psychiatrist to discuss feeling about arguments with fiance and would like some tools to help him feel to help him feel with his emotions do you see that did you um do you recall mr death of his heart having a fight on this trip in georgia i do not do you recall who mr deb's psychiatrist was at this time i do not do you recall why mr duff started seeing the psychiatrist i do not um driving your attention down to the portion of the note that starts with 2010 it says here patients spoke to a psychiatrist for 50 minutes and was open and honest with his feelings he feels better after conversation but also feels he is in a no-win situation with fiance do you see that i i'm kind of lost where we're at right now oh sorry oh 15 30. okay yes yeah i see it sorry okay um does this reflect that you were present with mr depp when he spoke to his psychiatrist i don't remember it was based on him telling me or if i was present do you recall mr duff ever expressing to you that he felt he was in a no-win situation with richard i i don't recall those specific words um but you you wrote them in your nursing house correct um you see at the bot so the still in this portion that starts with 2010. do you see where it says uh plan is for patient and fiance to go to dinner this evening the patient is feeling exhausted and wants to stay home but does not want to upset fiance do you see that we're on the same page yes we're still in the portion of the note that starts with 2010. 2018 okay yes yep um do you recall this specific um incident i do not do you have any understanding as to why mr depp would be concerned about upsetting his fiance i do not uh if we could go on to the next entry which is on the same page 1023 and this is also a note you prepared miss lloyd it is okay it says here you text patient to see if rn could come by and check it do you see that i did i do um why did you want to check in on mr grant i don't recall were you ever concerned about mr duff when he and miss heart were in arguments yes why were you concerned their arguments were a trigger for him emotionally any other reasons no what do you mean by a trigger for him emotionally it would cause him to be upset add stress um the next portion of this note says when rn arrived in the room patient was agitated and felt beyonce was using the term mania to express explain his behavior and excuse herself from any fault during argument did you see that um do you have any did you ever hear miss heard use the term media to describe mr depp i don't recall if that was i heard it from her or heard it that she was saying it to others but you do have some recollection of hearing that misheard was using that word whether it was directly from her or from others yes um the note goes on to say a patient was upset by this label rn processes feelings with patient and he was able to see fiance's negative behavior did i read that correctly yes um do you have any uh recollection of what you meant when you wrote that i do not you don't have any understanding of what um fiance's negative behaviors refers to i don't recall specifics do you recall generally yes and what do you recall at times she would almost try to instigate him and when you say she you're referring to miss her yes um did you ever witness that personally yes on more than one occasion yes ballpark how many times did you witness that during their ordering during the time you cared for mr death i don't recall number more than five i don't recall um when you say miss heard would try to instigate him what do you mean i remember an argument or being in there when he was going from room to room trying to remove himself from a situation and she would just follow him from room to room and not give him his space and that's one specific incident instance that you remember yes do you remember seeing that type of behavior on other occasions yes um are you aware of any of the fights that we just went through are you aware that any of them became physical no um from what you observed um what was the cause of the friction between mr deaf and mr during this time i don't know uh could we please go to the entry for november 3rd 2014 which is on that one seven one seven two sorry council uh yes one seven two one all right um miss lloyd this is also note you prepared correct um and it says here you arrived at mr depp's home and he was quote focused on relationship with fiance and is struggling with conflicted emotions did i read that right yes um based on this note is that something mr duff would have told you based on this note it appears so um looks like there's another note for november 3rd below this one do you see that yes and it continues on to the next page which is one step one seven two two if we could go there please i'm very good thank you and miss lloyd directing your attention to the portion that starts with one seven zero zero um do you see where it says rn went back to patient's house he was chatting with a friend and just feeling stressed about his relationship do you see that i do um and it goes on to say he feels she is not being truthful with him and he is not sure how to comfort her about this when you may confront her about this when she arrives home do you see do you see that yes um and the she here refers to miss heard is that right correct um do you remember this exchange with mr depp johnson um do you have any reason to doubt the accuracy of your notes i do not uh if we could turn to the entry for november 17 2014 which begins on depth 1723 um just like you see at the very bottom uh it says 11 17 yes okay um and then i think the entry itself is on the next page thank you um this is also a note you prepared correct um and this says rn and md went to patient's house to assess him do you see that i do um and so again this reflects uh that you and dr kipper wants to see mr depp correct um do you have any uh reflection of why mr excuse me why dr kipper was visiting with mr death at this time i do not um the next line says patient appeared anxious and depressed over relationship issues do you see that do um and then it says uh patient continues to be ambivalent about relationship status do you see that thank you um do you recall mr depp expressing these sentiments to you objection hearsay i don't recall specific conversations um but you also have but this is what you wrote in your notes correct i'm sorry i didn't catch that correct sorry i'm sorry um do you recall when mr death and mr got married i don't recall the date okay um but you said you testified earlier that you did attend the wedding correct um were you there to provide nursing services i don't really recall if i was a guest or i i don't think they made that clear to me uh did dr kipper attend the wedding he did and did aaron gorham attend the wedding he did do you recall any discussions of a prenuptial agreement um between mr deaf and ms heard before they got married yes and what do you recall i don't recall specifics what do you recall generally i only recall what johnny told me about the conversation and and what was that that she didn't take it well it didn't take what well the idea sorry i didn't hear the end of that the idea of having to sign a prenup did johnny tell you that he asked ms ford to sign a prenup i don't recall specifics but you recalled johnny telling you that miss heard yes and when you say it didn't take that well what are you referring to from what johnny said her reaction was when he asked when they spoke about the prenup do you recall that in january of 2015 um mr depp and ms heard traveled to japan together i don't recall do you recall traveling to japan with mr depp i recall being in japan yes um do you remember anything specific about that trip i do not do you recall mr death in this bird having a fight on a plane i recall a fight on a plane but i don't know the time it was around what do you remember about that fight it was another instance where he was sitting at a table and not wanting to talk and she wouldn't leave the table what was she doing she wouldn't leave the table and he was saying you know please just let's just just go away and what was she saying i don't remember i don't remember her words um how was her tone i i don't recall okay um you spoke with uh mr natal hawk about this earlier but um at some point you traveled to australia with mr depp right right can we pull up on what has been previously marked as exhibit 14. i'd like to direct your attention to the march 1 2015 email from dr kipper at 2 10 p.m do you see that i do do you recall mr death having issues with his sleep while when he was in australia not specifically in australia do you recall mr depp having issues with his sleep generally yes and what issues were those a hard time sleeping staying on a sleep schedule miss lloyd when you were in australia with mr depp um did you see where he was staying yes and how many times did you go to that property i don't recall specific numbers um fair to say you went there multiple times though yes you talked about this with mr nadelhof earlier um at some point in australia you learned that mr depp had injured his finger correct right and dr kipper was already in australia at that time correct and you testified earlier that you and dr kipper went to see mr depp after he injured his finger correct correct um do you recall anything about miss what do you recall about mr depp's physical appearance when you first saw him don't recall specifics what do you remember about his demeanor if anything i don't remember the events of when i first arrived but you did see mr depp at that time correct i can't recall when i initially saw him after the finger event and i believe you testified you don't recall whether miss heard was at the house when you went to attend mr death correct right okay do you remember seeing miss heard in australia yes did you ever see any injuries on miss heard when she was in australia yes what did you see a bruise on her arm anything else no did you have any injuries to her face that you can recall not that i recall any cuts or abrasions that you can recall not that i recall um do you recall miss heard ever seeking medical treatment from you while you while she was in australia i do not recall her ever seeking a medical treatment from me all right at the time that mr def injured his finger misheard was a patient of dr kipper correct i'm not sure do you recall whether miss gorham was already assigned to miss heard i don't recall if she was working with her at that time um can we turn back to the nursing notes which is exhibit 23 and specifically entry for um march 7th which is on 1732. is this march 7th of 2014 or uh this it says 3 7 15. do you see that so 15. hold on no i wasn't there yes you said you saw a bruise on miss heard's arm at some point when you were in australia correct correct do you have any understanding of how she got that i do not um okay directing your attention to um the entry for march 7 2015. um you see here it says md received text message from client that he had been arguing with his wife and that he cut his finger yes i see that okay so so this is the date that um [Music] you went and saw mr depp after his injury correct correct um now if i could direct your attention down to the portion that starts with 15 30 okay um it says md cleaned and dressed wound to our middle finger do you see that um what does our middle finger reflect right and so mr depp's had cut his middle right finger is that correct according to this yes now if i could direct your attention down to the bottom part of this entry that starts with 11 30. do you see that i do now this starts with patient and staff returned from er at 21 30. do you see that so um am i am i is it correct that the 11 30 at the beginning of this is referring to 11 30 pm um yeah that would make sense so this is the same day that you um were notified that mr depp had injured his finger correct um according to this yes okay and this was also the same day that mr depp was was seen in the eer for his finger correct okay um in the middle of the page here you see or in the middle of this entry you see where it says upon arrival back to apartment patient discuss feelings of anger and sadness about his relationship patient was encouraged to stay away from life as the relationship is toxic patient expressed verbal understanding and why they needed to separate do you see that yes um do you have any recollection of this conversation beyond what's reflected in the notes i do not do you have any reason to doubt the accuracy of what you documented in your notes i do not um do you recall advising mr depp to stay away from this herd i don't recall anything other than what's stated in my notes do you recall ever having the view that mr depp and mrs heard's relationship with toxic yes and what's the basis for that view conversations that he would share with me um what did mr duck share with you i don't remember specifics just like things we've reviewed in my notes that he would be emotional and that the relationship was causing him stress um after mr death injured his finger in australia do you recall him coming back to l.a yeah i don't recall specifics but i know we did return to l.a at some point was mr jeff's hand bandaged at all yes and why was that at one i mean beforehand we kept it bandaged to keep it clean and then he had surgery and it was bandaged after the surgery do you recall that mr depp had pins in his finger yes um do you recall mr depp reporting that his finger was in pain yes how would he report his pain to you i have to review my notes for specifics um well let's take a look at the entry in your notes for march 23rd 2015 which is on hey it starts on page one seven three five and goes on to 736. um actually before we turn to that one do you see in the entry above for 322.15 do you see that entry yep okay and do you see um next to 20 the portion of the entry that starts with 2015. you see in the middle it says currently 5 10 yes do you know what that refers to it's a pain scale okay and is that um how mr duff would report his pain to you according to my notes okay okay so now going to um the entry for march 23rd um first of all do you see the portion of the entry that starts with 120 yes is this uh 1 20 in the morning i am according to this yes okay um do you see it says um patient states his wife is trying to argue with him i see i see that and again you have no reason to doubt the accuracy of your note correct turning to the next page do you see the portion of the note that starts with 5 45 yes and it's a call to loft correct what does that refer to i don't know specifically loft is where they were living is that the eastern columbia building correct and then the next two sections of this note says 820 torrid val and then at 14 45 the same thing do you see that what is that referring to incomplete notes it would have been toward all and valium administered and uh do you have any recollection as to why those medications would have been administered they were for his pain okay and then you see below that it says fu thursday afternoon and tuesday afternoon skin graft bandage off week from tuesday pin off to in pin off in two weeks yes um what does this reflect i don't recall did mr duff have a spin graft on his finger he did and i think you testified you just testified um he had pins in his fingers as well right sorry i didn't hear that correct okay um so at this time on march 23rd he had bandages and a skin graft and pins in his finger according to this yes and then do you see in the section that starts with 20 200 um patient informed wife is coming to talk to him and he became extremely anxious do you see that i do do you have any recollection of why mr depp was anxious i do not um you remember being present for a fight with mr depp between mr depp and miss heard um shortly after mr duff returned from australia i don't remember specifics do you recall um a fight when um amber's sister whitney was present i don't recall um can we please pull up um document h please so um now just for the record um this is a document that has the base number wh106 through 109. and miss lloyd you're not included on this um but i just want to direct your attention to the first text message here um it this is i can represent you these are text messages between erin borham and whitney heard um and before i proceed do you know who whitney hurd is have you met her before on how many occasions have you been i don't recall and um what is whitney's relation to miss heard sister um so this first text message appears to be from aaron forum and it says debbie just and it's on um 14 it's at 14 32 in military time at on the date march 23rd 2015. do you see that yes okay and it says debbie just told me what is going on and to check with you is amber awake or fall asleep do you see that yeah do you recall reaching out to aaron borum um i do not um directing your attention down to whitney's uh to three messages down from whitney um or excuse me let's go up um do you see that whitney responds to erin she finally fell asleep and then aaron says thank goodness she must be exhausted do you want me to come to the loft or is she safe and sound asleep do you see that okay and then whitney responds safe no she's not she keeps saying she wants to kill herself do you see that thank you did you ever hear miss heard um say that she wanted to kill herself no okay do these text messages combined with your notes refresh your recollection about an incident that occurred on march 23 2015 i remember an incident but i don't remember the dates of it uh what incident are you remembering um there is an incident where johnny and amber got into a fight at the lofts and what do you remember about that i was staying next door at a hotel in security um had come to get me saying that they had had an argument and johnny wanted to go back to 86. so is that sorry is 86 um the sweets are property yes okay sorry continue um and so i went i went to the lofts and i remember that night amber was already leaving she was in the um lobby when we walked through and when she saw that i was coming she came back up to the apartment and what happened when was her came back up to the apartment i don't remember specifically what happened i remember johnny was sitting outside and we went to leave and somehow we didn't end up leaving and why didn't you end up leaving i don't remember um do you remember who else was in the apartment um i remember travis one of the security guards was there anyone else that you can remember i don't remember exactly who else was there is travis travis mcgivern correct um do you recall seeing miss heard throw anything at mr depp i do not do you remember mr depp throwing anything and misheard i don't recall do you remember witnessing any physical violence on that occasion i saw johnny push over one of amber's clothing racks okay no physical violence directed at correct okay um okay and then you you said you didn't end up leaving the apartment after that correct at some point that night we left and when you say we who does that include myself johnny and travis and where did you go don't remember okay do you know where amber went that night i don't know okay but she didn't come with you ladies and gentlemen let's go ahead and take our afternoon recess for 15 minutes okay again don't talk to anybody and don't uh don't do any outside research okay all right we'll see in 15 minutes so all right we'll come back at 3 45 then okay all right thank you all right are we ready for the jury yes okay are we ready we're ready for the jury there thank you um so so all right thank you all right you want to continue with the testimony thank you um please go back to the nursing notes which are exhibit 23 and specifically um could we go to the entry for march 25th that starts on depth one seven three six and goes on to one seven three seven uh miss lloyd do you see at the bottom here where it says uh 325 yes okay and um if we could just go to the next page um you'd agree that this is a continuation of that note correct yes okay and you've seen under uh 1330 it says patient states pain is four out of ten do you see that you do okay and what does that reflect um pain was being rated at a four out of ten out of 10 out of 10. um and then directing your attention down to the entry for march 26th this is a note that you prepared yes yes okay and just to make sure i'm not sure but um the the prior two notes we looked at those are also notes you prepared right um now if you why don't you take a moment and read through this note and just let me know when you're done um okay um now the beginning of the note starts at 1 45 do you see that and so again is that 1 45 in the morning correct okay and it says here rn called the patient's home upon arrival patient and wife were fighting in the garage do you see that do you remember this incident i do not um it says when arguments became heated patient removed himself from situation and had security drive him to another home you see that um i think you just testify you don't remember witnessing that's correct i do not um but you don't have any reason to doubt the accuracy of what you wrote down in your note correct i do not um have you seen mr deb remove himself from fights before in this manner yes um could we please turn to the entry for march 31st which is on page uh dep1740 um miss lloyd this is also a note you prepared yes um do you see um the portion that starts 130 patient continues to co pain 10 10 which is causing anxiety and insomnia do you see that and what what does this mean plaintiff continues to co pain 10 slash 10. and the 10 out of 10 is the the pain on the scale that you referenced previously correct correct um directing your attention down to the portion that starts with 1615 um it says at follow up with surgeon bandage was removed from skin graft graft took 100 there but there was an infection under bolster finger was drained pin was removed and rose fin 1g was administered during appointment so i read that correctly even if my pronunciation is incorrect um uh what does this reflect that mr depp had the bandage from his skin graft on his right middle finger removed on this date meaning removed at that time or removed for good uh removed at that time at that time that's what that would mean and the pin from his finger was also removed according to this um and when you say the bandage was removed at that time um are you clarifying that because another bandage was put on i don't remember that's why i was clarifying okay um do you remember what type of bandages mr duff had on his hand at the time i didn't hear you what type of bandage yes um i i don't remember specifics was it a hard cast or a soft cast soft okay was mr duff's hand mo i'm sorry i don't recall if it was a cast but i know the bandage was soft okay do you recall whether mr depp could move the hand that was bandaged hand yes for a while he was his finger was i like splinted okay did he grab anything with that hand i remember him pretending he had a claw he could do this were were certain fingers bound together in the cast i don't remember specifics um mr depp eventually uh returned to australia after the time period we were just discussing correct correct and you returned with him correct and um how long did you stay in australia on that trip i don't recall um i'd like to direct your attention to the last page of this document which was um for july 1st do you see that yes um please take a moment and read through this and just let me know when you're done i'm done okay great um this is a note you prepared yes correct um and do you remember the events reflected in this i do not um directing your attention to the portion that starts with 1235 do you see where it says rn received text from patient's assistants that the arguments between patient and wife are continuing and rn should come to the set to see patient did i read that correctly sorry i didn't hear your response yes okay um who is the assistant referred to here if you can recall i don't recall he had two main assistants and who were they stephen and nathan do you recall both of them being in australia i don't recall if they were both there um why did why did you understand right job um why did you understand that you were being called to set jackson hearsay i don't recall at the time um all right now directing your attention to the last part of this note that says 2100 says here between shooting patient was able to express his feeling to our end he explained that his wife makes him feel that he can never do anything right and that they cannot have a conversation without her blowing up do you see that um and i think you testified you don't recall having this experience with mr deb correct um it goes on to say patient was given positive reinforcement for expressing his feelings patient verbalized he knows it's best for them to take a break from each other when the fights start to escalate but how she will follow him from room to room when he tries to get away do you see that have you ever personally observed mr depp try to get away from this hurt and her then following him yes but you don't recall him telling you in this specific instance i do not um and again you don't um have any reason to doubt the accuracy of this no i do not this appears to be the last note reflected in this document do you see that um and i think you said you don't recall specifically when you stopped caring for mr correct um i'm sorry what was the answer sorry correct sorry thank you um do you recall why you stopped providing nervous nursing services to mr duff i do not um did you continue to work for dr kipper after you stop uh providing nursing services to mr jeff yes now i think you testified earlier you don't recall the last time you saw mr depp not for sure no what's the last time that you remember seeing him i went to his um one of his hollywood vampire show out here in the desert was mr duff and this herd still in a relationship when you saw mr jeff the last time no not that i was aware of um when was the last time you saw miss heard i had no idea what's the last time you remember seeing her i i honestly don't know during the time you were you were mr depp's nurse did you ever see mr death physically abused miss hard no you had witnessed this would you have documented and documented it in your nursing notes yes did you ever see mr duff throw anything in this hurt i do not recall ever seeing him through anything do you did you during the time you cared for mr deb did you ever see miss heard physically abuse mr death no did you ever see miss heard throw anything at mr jeff i don't recall in the time that you cared for mr depp did he ever tell you that this bird was physically abusive towards him i don't recall any conversations like that were you ever concerned for mr depp's safety around this herd yeah were you ever called over by mr depp when he was in a fight with mister i can't remember if it was when a fight i remember being called over after fights and why to the extent you know why were you being called over my role with johnny was medication or emotional support um how many times did you travel with mr deb while he was under your chair multiple but i wouldn't i don't know a specific number um did you ever witness mr deaf and miss her get in arguments while you were traveling yes and what would mr depp do in those circumstances i don't remember specifics other than the one time i mentioned on the airplane would mr depp ever book a separate room to separate himself from this herd i don't recall have you ever witnessed miss heard lose her temper i don't recall specifics what do you recall generally i can't recall um in the time you treated mr depp did you ever suspect he was under the influence of um alcohol i don't recall specific times being of concern do you recall any specific instances when you were concerned he was under the influence of drugs that had not been prescribed by one of his physicians um did mr depp ever tell you that someone had taken his prescription drugs i don't recall a conversation uh could we pull up exhibit i please for standby and just for the record this is a document varying the base numbers debt 7804 through uh seven eight forty for the twenty eight um um miss floyd this these are i'll represent that these are text messages between you and mr deaf i think you've seen some of uh some portions of this document when you're answering mr natalhop's questions um but i'd like to just direct your attention specifically to messages between you and mr deaf on may 27 2015 which appears on page 7841 and goes through to 7843 hmm sorry council was there an instruction oh yes i'm sorry um can you please go to um the page 7841 and we're going to be scrolling through uh the pages after that um it's up in two pages yep great to see the text message that starts in row that 320. yes okay so i would like you to please read through the text messages in row 320 through 337 which are um from may 27 2015 and before you begin um i just want to confirm this number under participants next to your name that's your phone number oh yeah but i was looking below i was like no above yes okay um okay so if you could read through the end the text messages reflected in rose 320 through 337 and then just let you know when you're done okay i'm done food 322. oh okay i'm done through 3 30. so so are you done through 337 oh yeah yeah all right um do you recall this exchange with mr dub i do not uh do you have an understanding of what you and mr depp are discussing i mean just from what the text messages says i can see what he was saying and what was mr duff saying that his um as needed medications were missing um anything else about how they came to be missing i don't i already don't remember what the above text stated okay let's go to the text that's in row 33 please oh three three three please um it says here saw them she wiped me out of everything need adderall in the pr ends i don't like to be out of stuff on the just in case kind of deal i can't believe she's got the balls to flat out steal my meds for her fucking debaucheries hard game after all she is the sister x me did i read that right here do you have any understanding as to what mr duff is referring to there i do not do you know who he's referring to when he says she is the sister i do not sure how how did miss heard treat you when you first um started caring for mr beth she was accepting did that ever change in the time you treated mr depp i felt it did you felt that at some time miss heard's um demeanor towards you changed in the correct yes okay when when did you recall her demeanor changing i recall specifically how did her how did her treatment of you change it wasn't so much her treatment of me of me hearing that she didn't want me around from other members who did you hear that from i i don't recall specific it was from other staff people that we worked with did you understand do you have any understanding as to why she didn't want to be around i do not was miss heard unfriendly towards you no did miss herd ever get angry at you in your presence not that i recall so just to be clear your understanding that miss heard um feelings towards you changed is based off of what you heard from other people correct yes and your your understanding was that you as you said she didn't want you around correct yes mr depp was your mr jeff was your patient correct right and then amber heard was not your patient is that right correct you would you had satisfied before i believe that you said one of your roles for mr def was providing him emotional support did i recall that correctly correct that you didn't have that role for amber heard correct right um one of the exhibits i saw it was exhibited i believe lloyd 22 there was a reference to poly substance abuse what is that poly substance abuse is used to determine the use of different drugs and or alcohol so it's abusing more than one drug or alcohol is that right that's what it's the term means yes okay um could we go to y23 so this lawyer would be the march 7 2015 entries okay and you see the entry for 1300 yes you wrote um a patient was having a hard time leaving the house so security suggested the md and rn go to house to see patient upon arrival the house patient was sitting in car ready to leave mdss patient's finger and we'll spend more time with patient at the location and he's being moved to you wrote that i did and that was based and you wrote that based off of information you were provided i i don't recall what that first sentence is regarding right you don't have any reason to question the accuracy of the statement i do not okay um and then at 11 30 the the bottom entry uh you had testified a bit to that um after the uh highlighted portion it says md offered patient valium 10 milligrams i am to help with this anxiety and anger but patient refused you wrote that i did okay and you have no reason to question the accuracy of that i do not was mr depp expressing any do you recall mr death expressing any anger um only what i see i referred to earlier in that note the portion that was highlighted okay um then you were then at the highlighting goes um going to the next page patient was talking about wanting to drink alcohol but did not obtain any you wrote that i did and that was based off of what you saw with mr depp um according to this yes okay and there's no reason to question the accuracy of that note correct and then 3 8 15 145 you write a patient has been on phone with his security guard that is staying with his wife at their rented house patient is discussing wanting to go home to la tomorrow and rehashing night haitians personal security guard came to stay with patient rn will be next door and instructed security to call during the night if needed you wrote that correct um do you know what you meant by patient is discussing wanting to go home to la tomorrow and rehashing night i don't i do not recall what that's referring to i believe you testified way in the beginning that um you are you go to dr kipper as a patient is that right okay not going into detail but how long have you been his patient since before i went to nursing the early 2000s and you consider dr kipper to be a friend yes when you were with mr depp in australia was he drinking at that time i don't recall him drinking do you recall that he was specifically abstaining from drinking during that time i don't recall did you ever see miss heard drink in front of mr depp while he was abstaining from alcohol yes did you ever um did he ever ask her not to do that to your knowledge not to my knowledge all right your next witness your honor uh mr duff calls sean bett sean and hey how do you spell the last name i'm sorry b-e-t-t b-e-t-t thank you thank you oh television so [Music] is thank you ma'am thank you good afternoon mr bets good afternoon will you please state your name for the record joshua sean bett um mr bet what is your occupation i'm currently security with johnny depp and your current employer is mr depp that's correct and how long have you been in private security uh approximately just over 20 years prior to working in private security what were you doing professionally i was with the los angeles county sheriff's department and how long were you with the la county sheriff's department just over 14 years over those 14 years would you please describe for the jury your responsibilities in each position you held with the l.a county sheriff's department yes i was assigned a custody division where we handled the intake and outtake of inmates then i was assigned to a patrol division where i was assigned to crime units where we did calls for service proactive reactive arrest after that i was assigned to gang details where we focus and saturated in certain areas within our district on gang shootings and things of that nature then after that i was assigned to gain units were i performed search warrants and things of that nature worked with homicide worked with special enforcement bureaus to combat a lot of the crime that was taken place in our area did it come to a point where your employment with the los angeles sheriff's department came to an end it did and how did that come about i was in a couple of uh really bad traffic collisions and during the course of duties the county of los angeles issued a what they call a medical retirement or discharge and so i was kind of forced out based on my injuries and after you left the los angeles sheriff's department what did you do next i was doing some private investigations and i also was doing security estate security at various uh residents and offices and working with different executives on certain details and when you when you were doing uh estate security did you work with a certain clientele i did what type of clientele it ranged from um ceos vps of fortune 500 companies to certain uh types of celebrities as well how did you come to be employed by mr depp during the course of work in estate security and the type of private security you come in contact with a lot of other individuals and security companies what we like to call networking so when you network with a lot of individuals they call you from time to time to ask you if you're available to work certain days weeks events and things of that nature so i was asked by an individual if i wanted to work the estate of mr depp and i of course said yes on a part-time basis at the time and where is mr dave mr death's estate it's in uh west hollywood or it borders west hollywood in the city of italy and approximately what year was that that was at the end of either 2006 into the beginning of 2007 around that time and since 2006 2007 have you been employed exclusively by mr depp i have i have done other work uh over the years on a part-time basis with other firms but primarily uh within the last i'd say six to eight years it's been with mr depp and his family and would you please describe for the jury your general job responsibilities when you first started working for mr depp it was mostly uh state security so we um controlled the you know people that arrived at the estate we were there to monitor the streets to make sure there were no overzealous fans or paparazzi that would hop fences or would try to sneak in bushes and take pictures of the family it also entailed taking the kids or the kid's mother to school or shopping or out to dinner and things of that nature and when you say the kids do you mean mr death's children i do uh who was their mother vanessa paradis based on your observations mr bette would you please describe what it was like working for mr depp in the beginning when i first met him excuse me objection what sorry at the foundation i guess what are we talking about that would you ask could you put your microphone on and just vague foundation also just relevance all right what was it like working for him what's the relevance the relevance is your honor just background just to understand i'll sustain the objection we can move on okay over the years mr bett has your responsibilities evolved over time as you've provided protection for mr depp and his family it has and how so um i started to travel a little bit more with them out of state and then eventually out of the country and worldwide did your interactions with mr depp also evolve from the beginning to now they did i was around him uh quite a bit when he was in town in the very beginning of my employment with him he was doing a lot of movies he was out of the state he was out of the country a lot so once he was back in town if i wasn't with his children taking him around to school and so forth um i would be around mr depp and provide you know security for him when he went out and about in public and so forth would you please describe for the jury your general access to mr depp while providing security for him i had access to him at any given time he had an open door policy i had access to his residence the inside all the rooms at any given time in the event there was an emergency or anything like that and when traveling with mr depp was the access the same it was um i have access to his hotel room again if there's an emergency i have you know wherever he's at i make sure and it's mandatory that i and other security personnel have access to them and would you please describe for the jury your current job responsibilities basically to provide security for him and his well-being albeit if he's in a hotel a residence or when he's out and about in public has your job title changed from the beginning to now yes i primarily now just um work with mr depp uh not so much with his children anymore so i guess you could say for a lack for a term you know when we're in the united states you know i'm kind of his lead security guy are there other members of mr depp's security team there are and would you please name some of the security members uh that would be malcolm conley who primarily does his european um security although he does come from the states from time to time leonard damien mark gibbs travis mcgivern starling jenkins who is jerry judge jerry judge used to be his chief security individual he was with him well over 20 years i believe and we lost him a few years ago to cancer over the course of your employment with mr depp um have you seen him consume alcohol i have how frequently it rains sometimes uh i wouldn't see him drink at all and there'd be other times he you know would have a glass of wine or two and based on your observations um how would you describe mr depp's demeanor after drinking alcohol his demeanor is the same as if you were talking to him um i would joke around with some of the other uh security personnel he's you know my terminology would be he's kind of too cool for school he goes into that kind of jack sparrow mode and he just you know he's very likable you know whether he drinks or he doesn't drink based on your observations have you ever seen mr depp appear intoxicated objection leading over will allow it i've seen him slightly intoxicated and again based on your observations what is mr depp's demeanor like when he appears slightly intoxicated it's the same as if he you know had a glass of sparkling water i mean he's just very low key he's easy to get along with and you know he just seems to me i mean he handles alcohol a lot better than i would and over the course of your employment with mr deb have you ever seen him consume drugs i haven't are you generally aware that mr depp has used drugs over the years i am and how are you aware of that from him do you know who miss hurt is i do who is miss heard she is mr depp's ex-spouse when did you first meet miss heard i probably would have been around 2011 12 maybe maybe around 2010 it was some time ago and how did you first meet her she came over to his hollywood estate and would you please describe for the jury some of your early interactions with miss heard um she was very pleasant very easy along with i mean she was almost as if she was a next door neighbor just always had a smile to her face and um just you know just you know no issues at the time and you know i liked her liked her a lot in the early days of mr depp and miss herd's relationship did you have an opportunity to observe them together i did how frequently in the early stages it was kind of on a part-time basis because a lot of times you know he was traveling or he was out of town working on films and so forth but when they were in la i saw them quite frequently which could have been the days that i worked which varied anywhere between four five six days a week and based on what you observed of them together how would you describe miss heard's relationship with mr depp when they first started seeing each other yes objection foundation all right foundation your honor i believe i've laid the foundation that he saw them frequently together when they first started dating how he would describe their relationship is not the foundation i'll sustain the objection next question after mr depp and ms hurd started a romantic relationship did you become familiar with any of miss herd's family or friends i did which ones her sister whitney heard her good friend raquel or rocky pennington another friend io tell it right miss pennington's uh boyfriend at the time josh drew and did you have an opportunity to observe mr dap's interactions with uh miss heard's family and friends i did and how would you generally describe their interactions um he was very open and warm to them he you know offered them you know whatever they needed they were constantly coming around the estate um you know eventually he let a couple of them live in his penthouses downtown for free you would let them a few of them drive his nice um dodge challenger in and around town and take on trips did you have an opportunity to observe how miss hurd's friends and families treated mr dupp i did they were obviously very pleasant to him because you know i from observing they were taking advantage of them so they were being obviously extra nice to the hand that feeds them and that's just progressed over a period of time how did miss hurt interact with you yes all right what's the relevance it's just background your honor i'll sustain the objection move on were you ever present mr bet for any conversations amongst miss heard and her friends i was can you describe any particular one that stands out to you objection your honor leading calls for hearsay all right well to the extent your honor we're offering misheard statements it's not hearsay all right um if you can lay a foundation to that do you recall any specific instances mr batt where um you heard ms heard say something to her friends i do okay can you describe one of those situations yes um the first one i was taking her from um mr depp's property to her apartment in the south end of the city that i believe mr depp was paying for she was sitting next to me in the vehicle she was talking to a girlfriend or a friend where they were talking about another male and she says to the friend girlfriend whoever she was talking to you know all men are idiots you know you shouldn't trust that guy and then she turned to me and she said you know sorry sean not you i didn't mean that and i just shrugged it off like it's not a big deal do you remember approximately when that that conversation took place i would say probably maybe 2012 or 13 perhaps perhaps even um a little bit sooner than that it was a long time ago and over the years of miss herds and mr dabb's relationships um did you have an opportunity to observe how the relationship evolved i did and well i'll just see what the next question is that's right um did you notice any changes in the relationship between mr depp and miss herd objection vague foundation relevance and leading all right well i'll allow if you could get a timeline set in there okay thank you thank you your honor did you notice any changes in the relationship between mr depp and miss heard after the initial stages of them beginning to engage in a romantic relationship i did and would you please describe those changes that you observed well i noticed they went from being that loving almost like high school couple where they were very giddy towards each other he was very happy she was very happy to they started to argue um they started to argue periodically and then the arguing uh started to progress more and more and more and uh it was always taking place because you know ms hurd would start this argument did you ever observe miss her drink alcohol i did how often it just varied uh there would be you know some days when i was working that i would see her there would be other days i didn't see her she was out of town working so it just really depended on when she was around and when she was around for the most part you know she was drinking you know sometimes i'd see a glass in her hand and sometimes i'd see her you know have two glasses if i was in the presence of her and mr depp obviously based on your observations did it ever appear that miss heard was intoxicated there were times when i went into the penthouse or we were at the hollywood estate and you know based on my training experience in law enforcement i could tell she's slightly intoxicated excuse me that's kind of getting uh getting into the realm of expert testimony he's not a designated expert perhaps we can have him answer the question without any exciting to any experience in in law enforcement mr bett i'll just say the objection let's go the next question okay interested do you recall observing any arguments between mr depp and miss herd several can you tell the jury about one that comes to mind there is an incident uh for example um i just happened to be on the floor of their penthouse which is on the top floor of this building i was outside by the pool area reading a book and when i was walking back past their door i could hear shouting i could hear her voice shouting um you know at a very high pitch so i didn't rush in right away or anything i just kind of stood by the door he was you know speaking with her and then the voices you know the shouting act dissipated and then you know there was music playing and then they started talking so i kind of just stood by the door briefly and then i went into another section of the penthouse floor do you recall approximately the time frame of that argument as far as the year or how long it lasted i'm sorry thank you mr bet the year um that could have been perhaps 2012 2013 maybe a little thereafter did mr ever confide in you about her relationship with mr depp briefly do you recall her saying anything particular about her relationship with mr duff there was a couple occasions there was one occasion in which they had an argument um at his west hollywood address um johnny told me you know just take her down downtown to the penthouse so she can relax and cool off as we were driving downtown you know she was crying this was at the point when uh the the arguing was taking place quite frequently and i was telling her you know i said amber you know this can't continue you guys are either going to kill each other you're going to be in jail and you know with tears and everything she says but i love him and i'm not going to lose him and i says but you guys can't keep doing this so we eventually got to the downtown apartments you know she said thank you i dropped her off and then i went back to the west hollywood address what did you mean by you know this can't continue when you told ms heard that the constant arguing and pickering and so forth because as i said it was slowly progressing and you know it was just going to turn out bad eventually i believe you testified earlier that you observed many arguments between mr dev and miss heard do you recall anything that ms heard said to mr depp while they were arguing there is an incident because as i said the arguing progressed over and over as the years continued um he would text me when i was working saying you know objection your honor calls for hearsay all right i'll sustain that objection if you want to mr bett if you could just focus on what miss heard you overheard miss heard say while observing arguments between mr depp and miss heard i overheard her saying to him he's a fat ass fuck you johnny and you too sean uh at one time when you know she went to throw a water bottle or a plastic cup down the stairs and it bounced kind of in johnny's direction but i ended up getting him and we you know got out of there as soon as possible did you ever see ms heard throw anything other than a water bottle it was a water bottle or a coffee cup it was something plastic other than a water bottle or a plastic cup did you ever see miss her throw anything else um no other than what he told me when she threw a broken bottle and sliced his finger sir i'll sustain the objection the jury will strike that that testimony please just answer the question asked and when there's objection do not speak okay i'm sorry thank you after observing several arguments between mr depp and miss heard what happened next uh as far as a time frame um well as i said the arguing when it would continue we would always you know i'd put him in the car and we'd drive back to his west hollywood address at which point it just depended on the week or the day or the month you know they would reconcile within hours or it might take a day where he would stay overnight at his west hollywood address and then you know i would take him back the next day and you know they would reconcile by you know talking and she would have you know candles lit or you know a bottle wine open with glasses and you know with within you know certain evenings you know i'd get a text message from her you know asking me to go pick up uh dinner at local restaurants stay frequented [Music] did you ever see any violence between miss hurd and mr dub no other than the occasion when you saw miss heard throw something plastic in mr duff's direction did you ever see miss heard hit mr depp no did you ever see any physical injuries on misheard i didn't did you ever see any physical injuries on misheard on occasions after mr depp and misford argued objection your honor foundation all right you only a time frame to that absolutely sure on the occasions that you witnessed miss heard and mr deaf argue after that did you ever see any physical injuries on misheard the same question all right move on okay at any point during during miss herds and mr depp's relationship did you ever see any injuries on misheard no how about on mr depp yes when did you observe injuries on mr depp the first time would have been around 2014 i guess in which he had a his finger was damaged from an incident in australia do you know how mr death's finger was damaged injection foundation foundation it's just background if he knows i won't ask i'll sustain the objection he unless he was an australian thought himself okay okay when else did you see injuries on mr depp i saw another injury around would have been march of 2015. he had a swollen kind of cheekbone eyelid your honor if i may please pull up a photograph exhibit number 146. just to the witness just for the witness that's correct i'm sorry 146. yes thank you thank you and that's plaintiffs obviously 146. mr bett do you recognize this photograph i do and how do you recognize it because i took that picture [Music] why did you take this photograph well we needed it as evidence and case miss her tried to make allegations towards mr depp i was emphatic with him telling him that's serious mark and we need to photograph it i just moved a strike for foundation i'll allow that answer but that's thank you and when did you take this photograph it would have been around march of 2015. your honor we ask that this photograph please be published to the jury and admit it into evidence any objection to 146 no your honor all right 146 in the evidence can be published to the jury thank you mr bett what does this photograph show it depicts a swollen upper left cheekbone with redness to it thank you did you notice any other injuries on mr dub on that specific day no later in time did you ever notice any other injuries on mr depp i did can you please describe what you recall it was around uh december of that same year 2015 um he uh got into an argument with miss hurt and she scratched him and he had injuries objection sustain the objection only your observations are what you saw all right thank you mr bett can you please describe the injury that you saw on on mr dap uh yes he had scratch marks um around his nose area i believe on one of the sides of his face in the cheek area and then on his forehead and if we could just have just published to the witness uh plaintiff's exhibit number 65 65 [Music] and mr beth this is a three-page document so if i can have mr arnold blair please scroll down okay okay thank you do you recognize these photographs i do and how do you recognize them because i took them when did you take them uh december mid-december 15th and why did you take these photographs i took him to show proof that uh he once again had injuries sustained and an altercation your honor we'll move to publish these photographs to the jury and um for admittance all right any objection to 65 no you're on all right 65 in evidence it can be published mr bett would you please describe what we're looking at here the first picture there's a laceration on the left side of his nose it looks like the left upper cheek has slight a slight bruise to it and then on his forehead right above the ridge line just um almost to the center it looks like there's a red scratch mark above his left eye and to the right do you see that in the same subsequent pictures in page two okay page two i see a scratch mark a vertical scratch mark adjacent to his right ear um [Music] on the right side of his face same question for page three [Music] page three uh there's a scratch mark on the lower right portion of his chin there's that same scratch mark on uh the center left side of his nose and you could see the frontal portion of that bruise it's on the left side under his eye were you surprised to see mr duff with these injuries objection leading did you ever see any similar injuries on this heard none did you see ever ever see any injuries on misheard i didn't didn't ever tell you she was being abused by mr depp she didn't did she ever ask you for help no you ever see any evidence that ms heard was being abused by mr depp i did [Music] turning to april 21 2016 mr bats do you remember anything about that day uh yes that was the day or evening that miss heard was celebrating her birthday with some friends do you recall what birthday ms heard was celebrating i'm sorry do you recall what birthday ms heard was celebrating i believe it was their 30th 29th or 30th your honor if we may can we can we just remove the exhibit sorry thank you other than miss heard's birthday celebration that evening do you recall anything else about april 21st 2016 he had a meeting that afternoon and which extended into the evening and that was the as i said the night of her birthday party uh where they got into another argument and she had uh struck him in the face objection moved to strike your honor sir if you didn't see it you can't testify to it correct correct all right thank you thank you in your honor jerry will strike that answer thank you were you with mr depp when he attended uh the meeting that that you mentioned earlier i was okay and uh if you know who was that meeting with it was with his uh accountant and who was mr duff's accountant ed white and where did that meeting take place it took place at his production his old production office um in the los angeles area what happened after the meeting ended uh when the meeting ended we drove to his um west hollywood address which might have been maybe five ten minutes away he had to go inside the house and retrieve something um i don't know what it was we were only there a short period of time and we were kind of rushing because you know we had been running late because it was a birthday dinner and then we eventually left thereafter and headed back down to the penthouses downtown los angeles and how would you describe mr dub's demeanor after the meeting ended with mr white um to me he looked fine he just you could tell he was in a hurry and he was you know telling me okay we gotta hurry up and go to the house real quick before we go downtown uh but other than that he appeared fine to me and uh based on your observations mr bett did mr depp appear to you to be intoxicated he didn't i believe you testified that after you left the meeting you went to mr depp's home his residence in west hollywood and then on to the eastern columbia building is that correct that's correct what happened after you arrived at the penthouses for miss herd's birthday dinner we went upstairs and she was having a dinner with her friends and one of the penthouses i believe it was penthouse number five um we entered uh the front door to that penthouse amber stood up she walked towards mr deb she had a look of you know you could tell she was upset the fact that he was late you know mr depp apologized to everybody apologized to amber and you know told her you know sorry baby or words that effect for being late she gave him a hug and a kiss and said you know come sit down suga was that a nickname a common nickname has heard used for mr dupp yes she used to call that quite frequently in front of me approximately what time did you arrive to the eastern columbia building it would have been somewhere between maybe nine and ten o'clock in the evening do you know what time the birthday dinner for miss herd was scheduled to start i can't remember the exact time do you recall how late you and mr depp were to the birthday dinner i knew we were running behind but as i said i didn't know actually what time the dinner was starting and once you arrived at the penthouses at the eastern columbia building did you go inside briefly i had a couple of mr depp's um computer bags and bags with me and i just set him down in the corner and then i exited thereafter how long did you stay at the eastern columbia building after exiting the penthouse i was probably there perhaps maybe another hour or two and then i would have been relieved by the night shift security personnel travis mcgivern did you happen to work the next day on april 22nd 2016 i did where did you start working on that day on that day i started uh i drove to his west hollywood address um because mr mcgivern had sent me a text message uh stating they had an argument hearsay why did you start your shift at uh the sweetster property or mr duff's west hollywood property as opposed to the eastern columbia building because that's where mr deb was at the time do you recall anything specific about that day april 22nd 2016. um just he had told me they had a sustained objection you cannot say what he told you sir i'm sure you've testified before correct yes thank you did you see mr depp when you arrived to the his west hollywood home on april 22nd 2016. i did did you observe any injuries on mr depp i didn't in this time frame of april 2016 do you recall mr duff's mother having any health problems yes what do you recall about her health problems at that time she was very critical she had been suffering from cancer for some time a few years i believe and at that stage um she was slowly deteriorating so it was approximately um a month before she passed do you recall when she passed away i believe it was around may 20th 19th and how did you learn that she had passed away mr deb told me and again based on your observations how would you describe mr depp's demeanor when he informed you that his mother had passed away well he just lost his mother so he was you know you could tell he was you know very sad and he was mourning and so i just left him alone until he needed me for whatever i had to do for him that day and to your knowledge mr butt uh when was the next time mr duff saw misheard um maybe a month later sometime in may i'm sorry was that a month after the birthday dinner on april 21st 2016. objection leading uh sustainability to your knowledge after april 21st 2016 when did mr depp next scene is heard in my presence he would have seen her may 21st and was that after mr duff's mother passed away correct that would have been a day after she passed i have approximately 10 15 minutes left i'll let you finish if that's okay with the jury we'll finish lisa direct okay okay thank you yes turning to may 21st 2016 um please tell us what you remember about that day um that day we were at his um west hollywood address um jerry judge his chief security guard was with me and with us at the estate at the time later on in that evening mr depp told us that he wanted to go down and retrieve some items from the penthouse and he also wanted to talk uh briefly with miss herbert all right it's just to establish all right do you want to talk to ms heard that's fine we'll leave it that next question thank you so you were working on may 21st is that right i was did you end up taking mr depp to the penthouses at eastern columbia building i did and mr judge uh was along with me as well and do you remember approximately what time you arrived at the penthouses it would have been some time after 7 30 maybe 7 45 7 15 around that time frame and was that in the evening it was did you enter the penthouses with uh mr depp i did myself in uh jerry judge and mr deb and what did you see when you first entered the penthouse uh when we first walked in um on the center island in the kitchen there were candles lit on the table there was a couple glas wine glasses that were empty and there was a bottle of wine that was open um there was also music playing in the background through the speakers that were in the wall did you see miss heard when you first entered the penthouse i didn't what happened after you entered the penthouses uh after we entered the penthouses um jerry judge um told johnny that myself and yes objection here's all right i'll sustain the objection all right next question okay did you stay inside the penthouse with mr judge and mr depp no shortly thereafter mr judge and i exited the penthouse and stood outside the door briefly how long would you estimate that you stood outside the door of the penthouse it would have been approximately maybe 10 minutes maybe a little bit more a little bit less and after standing outside the penthouse for 10 minutes give or take where did you go next we walked down the hallway to uh penthouse number five penthouse number five has two doors there's a main entrance that takes you into the living room next to it around the corner it's a continuation of the penthouse which is like a storage area it also has it had a couch at the time and a tv for uh the security personnel so once we were at the penthouses we could go in there have lunch or dinner or watch a little bit of tv and then um you know whatever mr deb or miss heard would leave and i'd have to drive or the other security personnel we would get a text or they would come knock on the door and we would leave and when you first arrived to the penthouses with mr depp based on your observations did was he drinking he had had some glasses of wine at the meeting he was at with his accountant apologies mr bed i meant on may 21 2016. oh i'm sorry i'm sorry did you observe mr depp drinking any alcohol that day uh he might have had a glass of wine in the car uh but as far as the entire day i would have known how much he drank did he appear intoxicated to you when he arrived to the eastern columbia building no so you went to the storage area of the of the penthouse area how long were you there we might have been there maybe ten minutes five minutes um we got uh something to drink and then we exited that you know penthouse i described or that penthouse storage area and where did you go next we walked down the hall towards um mr depp's penthouse which would have been penthouse number three and did you stand outside the door or did you go in we as we approached the door we could hear the screaming and shouting from his herd so i immediately opened up the door and mr judge and i ran in there what do you remember miss heard screaming or shouting it appeared she was shouting profanities so once mr judge and i went through the front door mr depp would have been standing directly in front of us maybe about 20 feet because parallel to us walking in or running in there was a wall it was the the way that the kitchen was set up it was almost like an l shape so you walk in and then you'd have to make a left so mr depp would have been standing in front of us and he glanced at us as soon as mr judge and i rounded the corner i saw miss heard standing next to her good friend raquel pennington and um how was miss heard standing where were her hands her hands would have been in this motion once mr judge and i rounded that corner and she saw both jerry and i she had this look a surprise on her face and then she looked at mr deb and us and she shouted out loud this is the last time you do this to me at which point mr deb looked at her and said what the hell are you talking about at that point mr judge tapped mr depp on the arm and told him boss let's leave so we gathered uh there was a couple of computer bags that was right on a table and we exited the front door to penthouse number three based on your observations did you see did you have a clear view of miss heard i did did you have a clear view of her face i did did you observe any injuries on miss hurt's face i didn't did you see any redness i didn't swelling none was misheard holding her face she wasn't so what happened next um we exited penthouse number three and we walked down the hallway right when we were getting close to penthouse number five door mr deb says i need to get in here and look for something so i opened up the door for him we went inside and that's when i saw miss hurt's friend raquel pennington's boyfriend josh drew and another unknown female that i'd never seen before and there was a small dog kind of walking around mr depp uh i believe he said get the fuck out of my apartment so mr drew nodded his head and basically said okay the female picked up the dog and they exited the front door to that penthouse what did mr dab do next he was working around the kitchen area living room area he might have gone upstairs briefly i can't remember i don't know what he was looking for i didn't ask him mr judge didn't ask him eventually um he didn't find whatever he was looking for and we exited penthouse number three and while mr depp was in penthouse number three did you observe him cause any damage no did you observe him cause any damage to any of the penthouses on may 21 2016 no did you see mr depp become violent with anyone while at the penthouse is on may 21 2016. objectional leading i'll allow it that's fine i didn't mr but have you ever seen mr depp become violent with miss heard i haven't thank you i have nothing further all right you can stay right there sir all right ladies and gentlemen that concludes the testimony for today so i'll release you we'll be back here at 10 a.m tomorrow please have a safe quiet night please take care of yourself take your vitamins we need you um and we will see you uh in the morning don't talk to anybody don't do the outside research okay all right thank you all right and mr betsin you're still in the middle of your testimony you cannot talk to the attorneys or mr depp about your testimony or about this case okay i understand all right we'll see you tomorrow tonight okay so thank you thank you you're released all right anything else for this evening yes your honor wanted a point of clarification okay okay sure go ahead um perhaps we would you approach okay sure so so much so so so so so youWatch at: 00:40 / 01:00Watch at: 01:00 / 01:20Watch at: 01:20 / 01:40Watch at: 01:40 / 02:00Watch at: 02:00 / 02:20Watch at: 02:20 / 02:40Watch at: 02:40 / 03:00Watch at: 03:00 / 03:20Watch at: 03:20 / 03:40Watch at: 03:40 / 04:00Watch at: 04:00 / 04:20Watch at: 04:20 / 04:40Watch at: 04:40 / 05:00Watch at: 05:00 / 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