WATCH LIVE: Johnny Depp v Amber Heard Defamation Trial Day 2 – Video Deposition of Brandon Patterson

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Watch at: 00:00 / 00:00:20do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do do i've gone three times now and that my ekgs foreign is [Music] i could go good morning good morning okay just let us sure mr rottenberg do you have the reactions for me we have one of the two the other one we had to make one tweak two and we're going to do that electronically during my cross-examination okay all right so which one do you have one uh 214 all right so the redactions uh reserving your other objections the redactions are okay yes okay all right so 214 will be in evidence then all right all right thank you all right do you want to get the witness back on the witness stand before we get the jury here yes mr broski all right let's put her on before we get the jury out that would be mr rottenborn you're going to get me 214 after yes okay no there's 2 10 this is 2 14. yes 2 10. okay we'll put it up on the screen but without the presence of the jury so the judge will see it at the same time okay all right are you ready for the jury you ready for the jury yes okay uh one please all right good morning ladies and gentlemen thank you all right you can have a seat miss dombroski mr broska i just want to remind you that you're still under oath at this time okay all right you want to continue with your cross-examination your honor good morning ms dabrowski good morning so i believe we we talked a little bit about this yesterday but you were in addition to being mr depp's brother you were his i believe you referred to it as his personal manager is that right i have been referred to yes okay and so you were responsible for or had some responsibility for his business affairs right i actually coordinated with other people but i didn't have full responsibility right but in terms of the information that you would receive you you would receive information that was relevant to mr depp's business affairs and personal affairs right at times yes and you you care about mr depp's well-being right yes he's your brother you love him right it was important to you that you in your role as both his brother and as his manager be kept informed of his well-being right yes and if something was wrong you'd want to know about that right yes did you ever have reason to believe from anyone other than amber that mr depp had a problem with drugs or alcohol no did you ever have reason to believe from someone other than amber that mr depp romanticized drug culture no did you ever have reason to believe from anyone other than amber that mr deb didn't take accountability for his actions i didn't have reason to believe that no did you ever have reason to believe from anyone other than amber that mr depp lacked patience for getting his needs met i didn't have reason to believe that now did you ever have reason to believe from someone other than amber that mr depp could act like a child if he didn't get immediate satisfaction i'm asking if she had uh overruled i'll allow it that's fine let me ask that again um miss nabrowski did you ever have reason to believe from anyone other than amber that mr depp could act like a child if he didn't get immediate satisfaction overrule for this question we'll see if the follow-up okay i'm sorry did you ever have reason to believe from someone other than amber that mr depp could act like a child if he didn't get immediate satisfaction i never had reason to believe that did you ever have reason to believe from someone other than amber that mr depp had fundamental issues with anger reason to believe from someone other than amber that your brother had fundamental issues with anger i i didn't have reason to believe and did you ever have reason to believe from someone other than amber that your brother didn't grasp the responsibility that he had in his children's lives i did not have reason to believe heather can you pull up exhibit 268 please okay miss dombrowski is this an email from dr david kipper to you on august 18th 2014. it's not being offered yet so i'll open the objection good i don't i don't have it can can you see the document on your screen you might have to make it bigger it's much smaller i don't i don't have anything can you see it there ma'am no it's not showing up on your screen just bear with us one minute thank do i need to do you [Music] do you have a physical copy that she could look at not that's not marked up let me um can you see if i can grab one wait she's got it oh okay turn it off and on see that's that's the trick that's the judge thank you to take as much time as you need to read it ms dombrowski but my my question is is this a an email from dr david kipper to you on august 18 2014. yes it's got my name on there yes from him and this is an email that you um that you would have received on or about that date august 18 2014 to the best of your knowledge it was it was sent on that date yes and it's about dr kipper's treatment of your brother correct i'm actually reading it okay take your time thank you he's fine uh is there i'm sorry is there more to the there's a there's another page which we can go to but my question is just this i think we establish this this is an email that you received from dr kipper correct yes okay um you're on a permission to publish the um the second paragraph on page one into the and then the the remainder of that paragraph on page two with everything redacted else redacted you're asking to enter into evidence yes we'd like to enter it into evidence with those redactions miss dambrowski if you can take a look at the first page of that email please um in the second paragraph well first of all who is dr kipper uh dr kipper was the doctor that was helping my brother um excuse me um helping my brother get help from the pain medication addiction that he had he was helping him with his drug addiction the pain medication and he your brother was addicted to pain pills he had been taking them for a long time yes right and and you were instrumental in hiring dr kipper to help your brother try to deal with that right yes okay and so dr kipper in his role as someone treating your brother tried to to keep you informed of what was going on with that treatment right yes and it was important to you as both his brother and his sorry his sister and his manager that you be kept informed of that right it was important as his sister and well and and his his issues with drugs were having an impact on his career as well too right no and you knew that they were having an impact on his relationship with amber right she's given plenty of testimony about ruled out you knew that the drugs were having an impact on his relationship with amber right i knew that amber claimed certain things but you didn't believe that they were i didn't necessarily believe it now okay um we'll get to that in a few minutes it isn't it true that on the bottom paragraph on page one that dr kipper informed you that your brother was uncomfortable and pessimistic that he will ever be able to stop doing drugs i'm not not asking for this i'll allow this question that's the only question on that point okay thank you i'm sorry isn't it true that dr kipper informed you in august of 2014 that your brother was uncomfortable and is pessimistic that he will ever be able to stop doing drugs he does write this in this email but this email is an update if i'm looking at the dates and i don't remember all dates but i know that period and what's written in the email i think this was during the time they were where he was getting help from dr kipper right but that's what he informed you of in your role as his manager and his sister about the status of mr depp's belief that he would be able to stop doing drugs right objections i'll allow that question i think he was informing me of the conversations yes and he also informed you that your your brother didn't take accountability for his behaviors correct he does say in here the yes he he wrote that he has no accountability for his behaviors in this time and heather can go to the top of page two please in that first and second line he also told you that your brother has fundamental issues with anger right same exception that applied to the other ones this is what he informed her we need to move on though okay heather you can take that down so you just testified um miss dembrowski that you understood from amber that drugs and alcohol were impacting their relationship but you didn't necessarily believe that right right and you didn't necessarily share those concerns right right did you have um an occasion to speak with amber um after a plane flight from boston to los angeles in may of 2014. i just asked if she spoke with her i'm not asking about the content spoke objection at this time i i don't recall specific times speaking with amber like that okay did you become um did you become aware of an incident on a plane flight from boston to los angeles in may of 2014. foundation objection if you you should testify that she i'll sustain the objection of the foundation if you can lay a foundation you you if something if something happened in your brother's life that was notable you you wanted to know about it you testified to that right sir it's it's a foundation question she's testified that she had insight into his daily life i don't see it as a foundation question so i'm sustaining the objection if you want to okay you you were kept surprised of the goings-on in johnny's life correct for the most part yes yeah and you testified yesterday you saw him just about every day correct when what i testified to yesterday saw him every day was when he was with the family in vanessa and you still saw him you or were in touch with him fairly frequently as his business manager and as a sister when he was with amber correct less frequent okay but still with with some frequency right yes and if if an event had happened that was potentially harmful to your brother you would you would want to know about that right yes okay and all right i'll sustain asked and answered next question you want you you made an effort to make yourself available to miss heard to talk to you about issues she was having with your brother correct i'm i'm excuse me i made an effort to talk to her anytime i felt she needed to speak somebody's trying to call us kind of a pleasant ringtone i didn't answer it so i don't know miss dembrowski in addition to just amber believing it you believed that your brother needed help didn't you fake you believed that your brother needed help with drugs and alcohol did a rule of ejection go ahead i'm sorry i believed on the one medication i was concerned about and you wanted your brother to get better from his addictions right i wanted to address the medication that he was on and you understood that amber wanted the same thing wanted him to get better for both him and for her correct sustain as to what amber wanted um now uh do you recall meeting with miss herd on may 25th 2014 i don't recall okay um let's pull up exhibit 234 please you said that was 234 234 yes thank you the non-redacted version mrs dombrowski this is a multi-page exhibit that we can um we're not going to ask you about all the pages but um is this a text message chain between amber and you on may 25th 2014 yes and that those are your texts in gray on the left right yes and miss herd's texts in blue on the right yes your honor we have a a version of this exhibit with miss hurt's text redacted and the personal identifiers redacted that i'd like to ask the witness about and publish to the jury i'm happy of course you want to admit into evidence before you publish correct right so i'm just previewing that would you like me to go through the unredacted version with the witness first or well if it's just her text how does that how is that probative if it's just her text because it's her texts about what she two thinks one it's her texts about what she wanted for her brother we'll get to those on page two um it's it's i'm allowed to ask her about her her own words and what her feelings sort of you can ask her about it but it's not coming into evidence okay well okay okay miss dombrowski did you reach out to miss heard on may 25th 2014. yes asking her if she wanted to talk yes why did you do that i did you do that because you had been made aware of an issue about your brother's behavior on a flight earlier that day the day before i don't recall why i did that you don't recall why you did that yeah or you have no no awareness or memory of a flight earlier that day or the day before i don't recall all flights at all times i don't have any specific memory of anything okay um if you can turn to page two heather if you can look at your third text down your honor or miss dombrowski you say to him or to misheard you say to miss heard i love him so much but he needs help and i don't have all the information to help alone do you see that objection i'll allow that question that's fine i do see that and what did you mean when you said he needs help i don't recall the actual timing of it but i wanted to help him with the that medication that he was on that i know um and i know that um i wanted to be able to be helpful in life because they were arguing all the time and i believe you testified earlier that you didn't actually have concerns about your brother's dependence on drugs right no i said that i i did have about the the medication just just the pain pills it was the pain pills nothing else i didn't have concern and so when you said he needs help that's what you were referring to is that you you believe that your brother needed help with pills man approach honor all right so heather can you please pull up the the page is ending in 934 start with that please actually let's let's not let's let's go to um 936. just for the record this is still in exhibit 234 it's just fade stamp page 936 is that correct yes your honor okay miss dembrowski do you see that the message that you sent to amber three down where you said he is going to see the doctor in the morning with three exclamation points yes tell us tell me what you remember about that you were referring to when you said he you were referring to your brother right yes and by doctor you meant an addiction doctor is that right i believe i would have meant dr kipper okay and what was it's it's it's you'd agree that it's fairly rare to get an appointment for a doctor the next day right i'll allow it that's fine i don't know that it's rare to get an appointment the next day dr kipper wasn't an emergency room doctor right no so what was so urgent about your brother's need to see a doctor that he was going to see dr kipper the next morning when you texted this at 7 35 pm i don't know that it was urgent i think i was happy that he was going to see the doctor and you're happy he was going to see the doctor because you thought he had finally realized the problem that his drug addiction was having on himself and others correct that's why you were happy right i was happy he was going to see the doctor because i was concerned about the pain medication he was on and you were concerned about what that pain medication did to your brother right yes you were concerned about the effect that had on his life right i was concerned about him and you were concerned about the effect that that drug addiction had on other relationships in his life as well correct i'm going through that's fine a lot you can answer i didn't see anything that that was happening necessarily in life to be concerned about others me um it was him i was concerned about so you didn't see your your testimony today is that you didn't see any effect that your brother's drug problem was having on anyone else other than him my concern was him i wasn't focused on anything beyond that right you weren't you weren't concerned about the effect that it could be having on anyone else is that your testimony again my concern was him can you pull up page 937 please and when you sent misheard the text at the top of the page at 9 20 pm on may 25th 2014 and you said i just meant i will help in getting him help what did that mean it's help with dr kipper i believe you you were referring to getting your brother help for his drug addictions correct i was referring to getting him help with the medication that he was on and if you go to page 938 please when you told amber at the bottom of that page at 10 30 10 26 p.m i think you need to tell him you were scared and you can't deal what did you mean by that i think you need to tell him you are scared and you can't deal what did you mean by that asking her what she meant with one of her statements it's no different from the statement i just asked her about it i'm just not sure what the prior inconsistent statement would be for this which was well that she's testified that all of amber's concerns were overblown okay uh drug abuse you were concerned for your brother and your brother only is that right i was concerned for my brother yes and only your brother is that right that my brother was my focus now you as in your capacity as his personal manager you were often apprised of your brother's performance on movie sets right did you did you have occasion to communicate with studios for example about movies that your brother was shooting yes and studio executives would could feel free to contact you about your brother's work yes they mostly contacted the agent okay and you were who was the agent at the time is that tracy jacobs and that's the your brother mr deb fired miss jacobs in in around 2017 is that right i don't recall when how long was miss jacobs his agent 20 something years and he fired miss jacobs at some point right yes after his divorce from amber i i don't recall exactly when he fired her do you recall whether it was before or after he divorced amber i don't recall but in any event you had frequent communications with miss jacobs about your brother's work correct excuse me um yeah and you um in the course in in your capacity as his manager it came to your attention that he was late to movie sets correct you testified that you had contact with frequent contact with ms jacobs his agent right yes and that contact included when he was shooting movies yes and that contact included um communications relating to his conduct on set well it sounds like your foundation is going to be based on hearsay which is what we're going to be getting too well if you can lay a foundation without it being based on hearsay did you have personal knowledge of your brother being late to a set movie shoots would i would that be if i was physically there is that what you're asking or your honor no first i'd instruct i'd ask you to interrupt mr chu not to shake his head and nod his head to the witness that's inappropriate okay well he was all right well i'll keep a lookout thank you all right thank you miss dombrowski your brother told you himself that he was late to movie shoots didn't he party i'll allow them i don't i don't think he came to me and said i'm late to movie shoots no you learned from your brother that he was late to movie shoots correct i i don't think he would have come to me to talk about it allow it you learned so so you never had any communications with your brother about issues that he had being on time to movie sets is that your testimony no what i'm saying is is i worked with him for years you know there was never a really a continuous topic of whether he was late to a movie set him and i having a conversation he told you he had been late to movie sets correct i'll sustain the objection next question can you pull us 348 please 348. um if you can can you blow it up so you just see the second email down heather and that second email down is an email from you to tracy jacobs on february 27 2015 right objections i allowed that question we'll see where we go the second all the way down in here the second one down from the top sent at 12 50. oh sorry yes that's from me to tracy okay now in the second sentence of that email you write he told me one to one and a half hours but not two yes he was two and a half hours late one day and seven hours recently do you see that i do see that and when you said he told me you're referring to your brother johnny depp admitting to you that he was late to movie sets right i don't know that i'm referring to him now okay uh in any event it was a problem is his personal manager you knew that it was a problem for the studios if he showed up late to set right i knew that on this particular film there were times when he was late to that you did know on this particular film and this was this particular film is pirates five correct yes pirates of the caribbean five and he was filming that in australia right yes and this email was sent on february 27 2015 right yes so you knew that as he was filming pirates of the caribbean five on in 2015 early 2015 that he had problems being late to the set right i i wouldn't call it problems being late to set but he was occasionally late to set okay enough that disney executives called you to discuss that right all right i'll sustain the objection next question and you knew that this wasn't the only movie that he had been late to set for correct she's testified about her close involvement in his personal affairs when he was shooting movies maybe if you lay a foundation not based on hearsay have you you talked to your brother when he was filming each of the movies that he filmed right yes okay and with respect to pirates five he told you that he'd been late to the set right no i don't recall him telling me he was late to set okay so despite the fact he said he told me you don't recall whether that was him or not i don't know that that i don't know that the he in that refers to him okay you you were also i believe you testified yesterday that you were closely involved in um in the financial aspects of your brother's life right i was i was closely involved in speaking with the representatives but i wasn't really closely involved in you know his financial world i had that wasn't my thing and your brothers the income that he made from movies or other commercial opportunities that he had that funded with him and it flowed or it came in through his companies right and then the money that your brother made came in through his companies correct um i don't really understand your question well you're the president of one of those companies infinitive nile right yes so if your brother signs a movie contract the money is it paid directly to him or does it come in through through a company that he's owns infinite is completely a separate entity so how he gets paid is that's the business managers okay you you were involved with um discussions of opportunities that he had to shoot movies correct sometimes yes and you were um in close contact with others on mr depp's team about opportunities that arose right yes okay including tracy jacobs yes his agent yes including um you in fact you would be in contact with studios directly as well it's from time to time right yes and mr jacobs um well strike that in your capacity as his personal manager you became aware of financial distress that your brother was in correct because you you were familiar with his financial affairs right i was somewhat familiar that was that was the other representatives area okay did you have occasion to become familiar with whether he was undergoing financial distress such that he needed to get movies a certain number of movies a year i tracy had a certain number excuse me a certain number of movies per year that she wanted him to do and the certain number of movies a year to your understanding the certain number of movies a year that your brother had to do was necessary to stave off financial distress correct the certain number of movies per year would tracy would push for a certain number of movies per year because it was a it was beneficial to her that that's the only reason she pushed for a certain number of movies a year that's the main reason tracy would push for a certain number of movies per year yes not not because it was beneficial to mr deb if it was beneficial to mr death then it was going to be beneficial to tracy okay but just because it was beneficial to tracy doesn't mean it wasn't beneficial to mr depp or his companies correct i'll sustain the objection next question now at some point you became aware when he was filming pirates 5 in australia you became aware of an injury that he suffered to his finger right yes and you were involved in trying to cover up how it happened correct i'll allow the question i'm not sure i understand the question you were involved in helping to cover up how the finger injury happened right i i i don't understand cover-up you you were you were involved in making sure that people on mr depp's team didn't say how he hurt his hand correct i'll allow it if she can answer it you can answer um we certainly didn't want um any press to know about it so that's you know to keep it from that um and and because you didn't want any press to know about his finger injury you told mr depp's personal assistant to make sure that he wasn't to say that he wasn't sure how mr depp hurt his hand correct you instructed him to say that if it was someone that i would be concerned that the word would get out to the press i would have done that so it was it was okay to you to tell people to lie to protect your brother right it wasn't necessarily a lie i didn't know how he hurt his finger myself at the time because i i'm pretty sure i know the time frame you're talking about is when it first happened and you have no personal knowledge to this day of how he hurt his finger correct because you weren't there i wasn't there heather can you pull up exhibit 210 redacted please your honor this is um the exhibit we discussed yesterday um if the court and mr two agrees with the redactions i'd just like to publish it to the jury uh and admit it into evidence well if it's two tenets already in in evidence that that's when he gave me this morning correct no that's a different one yeah i think that was 2 14. that was 2 14. i'm sorry i got it backwards this is 2 10. and i believe that this is this is just one page or it's two it's two pages i'm sorry yeah it's these two pages that we talked about yesterday right reserving your objections are the redactions correct okay that's fine i will enter a 214 into evidence over over objections permission to publish yes sir thank you can you blow that up please so miss dombrowski we discussed this a little bit yesterday um this is the text exchange between you and ms heard on february 3rd 2014 where miss heard says jd is on a bender and your your response is where are the kids correct yes and just scroll down please let's go to the next page please scroll down to the bottom please and then you text amber worry about everything is that right i i wrote the words worry about everything was myself i was speaking about myself and you tell her i don't love any of it correct right and sustained we we did go through this yesterday but go ahead and and two days later is when you sent your brother the text messages that said stop booze stop coke stop pills correct i'm not looking at it i don't recall the timing of it nothing further thank you all right redirect yes thank you good morning ms timbreski good morning during mr rottenborn's examination yesterday and again this morning he spent a lot of time talking to you about your brother's alleged drug and alcohol abuse do you remember that yes you're not denying that mr depp ever used alcohol or drugs are you objection leading let's redirect your honor that's still leading um i'll sustain his leading if you want to rephrase your question you also testified uh several times in response to mr rottenborn's questions that miss heard tends to say things in a more dramatic manner do you recall that testimony yes why did you say that i've had my own interaction one-on-one with miss heard so i know i know a bit about her personality um she would you know she would present information to me um that was not necessarily information that was supported by everybody else that was around and and i've spent a lot of years working with my brother we have a close team we've you know it's it's a many years of trusted people helping you know make sure that everything in life it works out and goes smoothly um but all those people where i would have a daily contact you know whether it's about scheduling or just how the day is going for all the years those people never said the same thing objection here say your honor i think it was responsive to the question well i'll sustain the last the last sentence yeah because there's the last sentence of it that's all i understood i think it does well i think it goes to state of mind rather than the the truth i just think the last sentence i'll sustain just last sentence okay and do you recall your testimony yesterday when you stated that after the phenomenal success of pirates one one of the changes to mr dapster brother's personal life was that there were a lot more people around him after that do you recall that yes when johnny and miss heard became involved in a relationship several years later were there still several people were there still a lot of people around them your brother on a regular basis yes who were those people he had he had assistance he had security he had you know property managers people that helped at the house he had quite a few people that were around all the time how often did you communicate with those people um i communicated daily not necessarily with each one of those people but i communicated pretty much daily with people within the the world the circle did any of those people ever raise the same concerns that ms heard did objection hearsay all right again it goes to state of mind i'll sustain the objection as to here's the next question what if any concerns were expressed about johnny's behavior when using alcohol objection hearsay again it goes to state of mind i'll sustain the objection next question thank you honor that's all i have all right is this witness subject to recall i do not believe so john she's subject to recall yeah there you go all right mr broska you're free to go or you can stay in the courtroom it's up to you okay thank you all right thank you ma'am thank you very much mr broski [Music] all right your next witness good morning ma'am isaac all right we'll get him okay that's right thank you while we're waiting for him can you spell his last name for the court reporter for me uh b a r u c h thank you okay um truthfully in this case on the penalty of law [Music] hey there's a thing here transcription you can just keep it there so have a seat put the microphone close to you please thank you good morning would you state your name for the record please uh my name is isaac barooch i-s-a-a-c-b-a-r-u-c-h mr brooch where do you currently live i live in los angeles do you know the plaintiff in this case johnny depp yes how do you know mr depp i know i'm from since teenagers we met in florida and could you tell the jury a little bit about your experience meeting mr depp when you were teenagers in florida yeah uh we were both playing in bands we had mutual friends and uh that we met in probably 1980. uh yeah we hit it off we got along with each other and uh yeah how often did you see mr depp when you were teenagers together in florida a few times uh a few times uh a month i'd say it could be more a little more or whatever because you know we see each other at parties and clubs nightclubs with the bands played yeah like that and for how long were you both um living in florida and seeing each other somewhat regularly well we we met in like 1980 so and then we both moved away he moved to california i moved to new york was that 80 from 1883 that was that like four years what were your impressions of mr depp while you were both living in florida at the same time oh he's he's a sweet kid a sweet guy sir wait there's objection oh thank you what his impressions were back then what's the relevance just establishing the background in the relationship your honor i'll sustain the objection next question please all right um mr brooch did there come a time when mr depp uh moved away from florida yeah yeah and where did he move to if you know like i said before you moved to california at some point in time did you also move to california yeah and did you um reconnect with mr depp when you got there yeah around what time was that sometime during the first year and uh then afterwards after the first year of more and stuff yeah about what year would you say that was oh i moved to california in uh september of uh 85. and did you know um if mr deck was working when you arrived in california in 1985 well i know i know he was pursuing acting at that time yeah he's looking for work because he's pursuing acting how often did you see uh mr depp when you first moved to california well like i said the first year a few times afterwards i had a friend who uh whose girlfriend uh lived in the same building as johnny and that so then hanging out over there i ended up seeing johnny more often and plus my friend who i who i'm talking about who whose girlfriend lived in the same building he was playing in a band and they needed another guitar player and johnny ended up joining the band so we were hanging out a lot more often um what were you doing when you moved out to california i was pursuing music also working retail jobs and trying to [Music] get a ban make a band you know did there come a time when you begin working for mr depp oh yeah yeah yeah when was that oh that's later on that's like in 1993. what were you doing for mr depp when you started working for him in 1993 well he owned a place called the viper room and uh which is a music venue uh nightclub bar and bands play and uh it was already open for six months and uh the girl who was working the person who was working the as office manager didn't want to work there anymore so the guy who was running the place for johnny who's a friend named saljenko another florida friend from back in 1980 when we all first meet he calls me up and he says hey isaac do you want to work this job i don't think it's offered for the truth of the matter that's fine i'll overrule the objection go ahead at some point in time did you stop working at the viper room for mr depp oh yeah when was that well i worked from 93 to 98 in 98 i moved away did you return to la again at some point yes i did when was that i moved back uh december of 2002. what did you do um for work when you returned to l.a well for two weeks i worked at an art gallery and then i went back to the viper room on new year's eve how long were you working at the viper room at that point in time it was another year and then the place changed hands were you working um on anything else while you were working at the viper room in that time frame yeah i was work sidewise i was teaching myself art and what steps were you taking to teach yourself art at that time books learning how to draw and uh paint and uh taking community uh college classes at some point in time did you uh begin pursuing art at a on a full-time scale yeah yeah yeah how did that come about well i was working at working at the viper room taking classes and then at uh at one point the club changed hands completely after a year 2004 and i was given a choice of either keep working for these new owners or uh johnny out of his pocket was going to give a severance pay to whoever didn't want to work there anymore so i took this evidence pay and then it helped me continue on to to finish community classes private classes and then be able to transfer to uh cal state university and did you get a degree from cal state university yes i did what degree was that bfa what year 2010 um after you received your bfa did you continue to pursue art full-time yeah did mr depp ever express an interest in your art yeah when was the first time that happened well first time you saw a painting in 2008 and then the next time was 20 uh 2012 uh i had uh made a painting and sent it to my best friend uh uh email uh in an email and uh he forwarded it to johnny and johnny emailed back saying hey when isaac wants to sell that whenever he wants to sell that to go ahead and get in touch with me because i want to buy it did mr depp ever buy that painting no why not because when i brought over paintings i i had moved back to california and i brought over a bunch of paintings for him to look at and see if he wants any to buy by onions he looked at me and says i got an idea how about i be a patron and we put together an art show make some make make a body of work and then we'll i'll throw a party and invite people and i'll sell the stuff for you and you could keep all the money so he didn't he didn't buy any paintings there instead he offered me a complete patron ship so what did you understand he meant by um becoming your patron what was going to financially make it possible for me to just paint every day and put together a body of work so that way then it could be sold how did he plan to do that objection to what he planned on doing what did you understand he planned to do to make that possible for you i could tell you i could tell you that uh it inc and what it included was that the next day i ended up moving into he he i moved into a uh art studio penthouse at the eastern columbia building it was listen i got a place for you to go ahead and uh live and work and put this body of of art together and uh i'll take care of you you don't have to worry about anything and what was the place where you were going to live that mr depp offered you the eastern columbia building did you um did you take him up on that offer to live at the eastern columbia building yeah of course and uh how did that make you feel i started crying is you know one day you one day you're in your mother's garage selling paintings for a hundred dollars two hundred dollars three hundred dollars on ebay next thing you know you get your it's an art show and like you don't have to worry about deadly squad of course of course i was i was flipping out when did you move into the eastern columbia building the next day after we met and we talked the next day the next day i guess i get a phone call from a guy named kevin murphy who is working for johnny and i go to and he says hey meet me at this address and i go to and i meet him and here i am in front of this building this is a beautiful building this is like you know it's whatever 13 floors but it's like from the 1930s some art deco beautiful building and i'm looking i'll go all right this is unreal what there's going to be you know all right it's going to be one of these apartments or whatever one of these places here i go in with uh kevin murphy he takes me all the way up to the roof we go we go into penthouse two and this i walk in and i like crying and going this is a it's beautiful this is like a a mansion uh situation to me mr brooch how long did you end up living at the eastern columbia building three years and seven months um your honor i'd like to show the witness plaintiff's exhibit 116. all right 116. am i looking at something you will in a second sir it's not ice cream okay lunchtime paper copy i'm just going to pull up a paper copy for a moment we can see it but he can't all right thank you we'll just use the paper copy we'll get this resolved at lunchtime okay thank you mr brooch do you recognize the document um that you're looking at that's been marked as plaintiff's exhibit 116. yeah what and what is it this is uh the floor plan of the roof uh all the penthouses up on uh on the roof at uh the eastern columbia and that's the building where you lived starting in march 2013 is that right i moved in the first week of march uh 2013. yeah your honor at this time i'd like to move into evidence plaintiff's exhibit 116 please no objection all right 116 evidence you can publish to the jury is it i'm sorry i just want to be sure that yeah they can see it in the gallery we'll just have to work on that screen thank you uh mr bridge can you um describe for the jury what um is depicted here in exhibit 116 uh yeah that uh so the right side of this uh graph is uh there's a pool there there's a there's a another uh top of another apartment that actually starts on the floor below it's a two-story apartment um but there's a pool there and there's a gem workout room and the left side there's a at the bottom there's an x and that's uh the elevator and so you walk out of the elevator you make a little uh left and there's part of penthouse five right there straight ahead and then you keep walking straight and then you make a left a sharp left and the actual penthouse five is straight ahead and then you hang a right and you start walking up that way on your right is going to be penthouse one on your left is gonna be penthouse four when you get to the end of that corridor this is the door for penthouse three and if you hang a right oh look there it is it came up on the screen and if you hang a right and you go down to the end is the door to penthouse two that's the apartment that i lived in and who did you understand owned these penthouses oh johnny owned them all which one did you live in tenth house too was anyone else living um in the penthouses at the time that you moved in in march 2013 no i was the first one to move in i moved in the first week of march and then a couple of weeks later two three weeks later then johnny and amber moved in and then after that the next one to move in is rocky raquel pennington and his friend and then at some point her sister moved in whitney and uh also uh at some point rocky's uh boyfriend moved in with her in penthouse one so i believe you just testified that uh mr depp and ms heard moved in uh shortly after you moved in is that right yes and which penthouse did they move into penthouse 3. and then you testified i believe that um someone named rocky pennington moved in yes who was rocky pennington amber heard's friend from texas and i i think they made them i don't know i'm not sure if they told me that they moved out there together or something like that but um yeah her friend and later you said that um her boyfriend moved in with her what was his name josh josh drew and which unit did they live in penthouse one and i believe you also testified that whitney moved in who was whitney whitney heard uh she's married so she's got a different last name i'm not sure what it is but uh amber's sister whitney and which of the units did um miss her sister live in four um can you tell the jury a little bit about your relationships with ms heard ms pennington mr drew and miss herd sister oh yeah i just i was friends with all of them i loved them all they all treated me with respect this we had it was great uh you know i'm an all-time friend of johnny's living living there and we all looking out for each other we became great friends i fell in love with all of them when you moved in um to penthouse two you were working on an art show with mr depp right yeah that that's the entire reason that i'm there is to the to work and put together this art show did you have a time frame that you expected to be able to put on that art show at first when we first power out this idea when you know uh it's we talked about all right what do we do you know what's what's this show gonna be what how many paintings is is it gonna be and we came up with a number okay there's going to be a certain body of work i'm not i'm not a known person i'm just some schnook painter it's so there's and if i was a famous painter i could make five paintings and and the room will fill up but so we decided okay like 25 pieces of work large scale and i would and johnny says hey what how long do you think this will take i said i've never done it before i don't know maybe a few months and were you able to compete complete the paintings in the in a few months no it's it's after it took me to in order to make two large-scale paintings it took me like uh to almost two months and i'm i'm start freaking out going i'm only got two paintings and all right i got to do 25 i said a few months so i ended up going to johnny's place and saying hey look dude this is going to take a lot longer than of a a few months i don't i could only make two paintings and how did mr depp react he looks at me and he starts laughing and he says ike don't worry i do not care i just want you to paint however long it takes just i want you to paint every day during the course of time that you were living at the eastern columbia building um did mr depp ever give you any money yeah how much did he give you over a period of four years of the patron ship i ca ballpark calculated probably around 100 000. and how did you come up with that amount well from the first from the first get-go when i say hey look i need doubt you know to buy stuff and and and to you know do this he i ended up getting an envelope the next day with five thousand dollars in it and then i budgeted it and and stretched it out and you know and so every few months i'd i'd get an envelope it could have that i didn't know if it was going to be the same amount but it ended up being the same amount which was wow uh so basically around five grand every few months so in the year it's 20 grand but then also there was a per uh maybe a year or two might have been that it was five times i had to ask for for dough or it was four and then on top of it so so right there that's could be 80 grand or 90 grand and then on top of that i ended up uh uh getting a herniated disc he sent me to the doctors to get an mri and and see the doctor get an mri and there was 10 weeks of of uh therapy that he covered so i throw that in there too and i ended up coming up with the figure 100 100 grand could be a little less could be a little more what was your understanding of whether mr depp intended to be paid back for the money that he provided to you there's no it's he that's not even the thought of being paid back this is something that he wanted to see happen this is something he he invested in to to he knew he had to he was going to spend money to make it happen for me to survive and paint and create this thing that he wanted to see because he liked the art and so there was and there was no payback and then the whole thing was about him selling the art so that way i could put so that way i keep all the money he didn't expect anything it was he was doing this as a friend as he's done with many other friends i'll sustain the last sentence of his his statement we've done that but that's fine thank you thank you your honor uh mr bruce did there come a time when you um decided that you planned to pay mr debt back oh yeah that for me when uh when he he's told me he had a money situation going on for me it was like this guy just changed he's been he's been making it possible for me to live and work and and and make product and that and and i'm by that expense i'm part of the problem it's like how do i help him how can i help him i mean he's sharing his sandwich with me you know it's like if i how do i how do i share that my hat my sandwich with him give him that half to make something up that's it's you you don't you don't not do anything and said the only thing i got is paintings so i i stood up when he's telling me what he's telling me about his money situation and for me i said hey it's this is if these things ever sell we got to split this 50 50 and i ain't taking no for an answer something i got to add i got to put something into this so as for me i looked at it like he's got it he has to get something back mr brooch during your time living at the eastern columbia building did you develop a relationship uh with the defendant in this case miss heard yeah and did you get along with miss hurd i loved her i fell in love with her just like johnny fell in love with her i fell in love with her she's uh totally respectful gracious to me uh that she's got great teeth uh that she treated me with complete respect anytime i walk into the sheets it's the humor wise totaled uh locker the locker room humor demented humor totally laughed at you know the jokes uh made the jokes totally got along with her every time i walked into their place isaac you want something to eat isaac you want something to drink every time there's only one time i remember that she didn't offer because i walked in and she's in the kitchen at the counter and she's doing a beauty facial mask and uh so she can't offer me and i'm going hey is that something that can help me and she looked at me and she goes no and that and i'm laughing and then she left after because she didn't realize she was making a joke so um yeah i loved him mr brooch did miss herd ever visit you in your penthouse yeah do you recall the first time that she visited you there yes when was that the first time is that uh it's in march when they moved in and they were there for a couple of days and i didn't even know and johnny had called me says hey come over meet my girl and that and then and so i did and then the next day they came over to my place uh for the first time to see how i had set up the art studio the lights and you know just what's my painting set up and stuff and to look at other paintings and they walked in and i remember the first thing she said was i hope we didn't keep you up last night because of all the yelling and i looked her and says no these walls are like three feet thick i don't hear deadly squad how did she seem when she said that to you well she's is it semi-joking and inquisitive you know like they did you know to find out um in your three and a half years living at the eastern columbia building did you have opportunities to observe mr depp's and miss uh relationship yeah can you describe uh what you observed about their relationship they were always loving with each other they treated each other like gold you know kissing and and you know can what can i get you type of thing you know being kind with each other always loving always a loving situation how often would you say you interacted with mr depp and miss heard if they were there because they're traveling they're doing they're working and doing stuff if they were there i saw them maybe two three times a week could maybe the other uh there might be one time one time a week that i see them that i go over to hang out or you know see them or they might come or johnny might come over to visit or you know like that since you've known them um did you ever see them get physically violent with each other no did you ever see them argue yes how many times probably like twice okay um can you describe the arguments that you witnessed the first argument that i remember was our walking in uh there was a it was a telephone argument johnny's at the kitchen table and he's argued he's he's he's screaming about something and on the other line because it's on speaker and he's talking with the phone at the phone uh the other person is is amber and that she's in new york and he's uh at the kitchen table and uh they're arguing and he's going who is it who is it and she's saying oh baby come on please don't what are you doing baby why are you being like this baby and this went on for a little while and i'm listening and then he hangs up she calls back again and it's the same thing who is it what's going on who is it and she's she's saying oh come on baby don't be woody what are you doing baby and and then hang up the phone again the third time it happens i'm saying this there's no solution in this conversation i grabbed the phone from him and i says hey amber this is isaac listen this conversation is now over and i hung up the phone and she didn't call back again and he went to the couch and went to bed i believe you said you saw them argued twice was there another time that you saw them argue uh i ended up going over and there's at the kitchen table is johnny is amber is uh rocky and josh and they're pat and i'm going what are you guys doing and they're hanging out and their power to try and plot to figure out a way how to get rid of whitney to not live there anymore and i felt bad i like whitney says you know oh well you know that's that's going to be a drag and uh i just i you know what are you plotting you know how do you figure out hey lend your sister some dough and let her move out but you know they're trying to figure something out something differently or whatever at one point so there was a point johnny got completely you know flustered and and frustrated and he got up and he walks away and as he's walking away he says figure it out and that was it that was the whole thing i don't know if you want to call it i don't think you uh might call that an argument but uh your honor i'm about to um switch gears a little bit it might be a good time for a mid morning perfect thank you all right ladies and gentlemen go ahead and have you take your morning recess for 15 minutes okay just remember to not talk to anybody and do not do any outside research okay and we'll see you back here in 15 minutes you stay right here that's fine you don't understand thank you all right so i just want to remind you since you're still on the stand on earth you can't talk to any of the attorneys or mr hurt at this time until your testimony is done okay okay all right and we'll be back and we'll be back at 11 45 okay i gotta stay here though yeah you have to say the whole time oh okay oh okay so you can stay you can stay inside all right okay yes ma'am your next question mr baruch were you stuck thank you for coming back yes um were you still living in penthouse 2 of the eastern columbia building on may 21st 2016 yes do you recall what you were doing that evening yes what were you doing i was out it was evening time i'm out in the neighborhood and i'm on my way home i get a phone call from my friend who wants to know if i want to go out and eat i said i just ate but i'm five minutes away from from the eastern columbia building home and that go across the street get something to eat and bring it up for takeout and we'll go upstairs to my joint and we'll eat and yeah did you meet your friend back at the eastern columbia building yeah around what time was that 9 30. what happened after you met your friend we went upstairs can we pull up um planets exhibit 116 again please in your honor given that this has already been admitted i ask that it be published all right that's fine you can publish it you just can't see it okay you still have it mr burch is it on the screen in front of you yeah okay great yes mr brooch i'm going to ask you a couple of questions about what happened after you went upstairs that evening and it may be helpful for you there are controls on that screen that you can use to sort of mark the exhibit to show the jury the the spots that you're talking about and identifying so if you just touch it it'll make a mark so you don't have to touch the top that's fine do i touch something on manual here nope you don't know just wait and you can touch it whenever she needs you to mark it just wherever i touch it it's going to make them all it will okay thank you mr burj when you uh got upstairs that evening with your friend around 9 30 what did you see we got out of the elevator and you know just like in the graph you you make a left and then you turn the corner when we walked out i noticed on the floor there's uh charge of glass there's pieces of glass and so you know it's just looking going oh something busted could be one of the sconces or something like that and kept walking can you mark on the exhibit where you saw the broken glass that evening yeah right there right where you could go left or you could go right and if you wanted to go to the pool area that's you could there's a exit that way so you could either go right through you go left you go left you're in the apartments going in the hallway through the apartments or you go right right there in that spot and did you continue on to your penthouse after you saw the broken glass oh yeah so we walk walk around and then we make the turn we hang the right pass the penthouse five and we stop right in front of right here what and why did you stop right there oh stop the front of here penthouse one which is much more right there because there's this puddle of wine huge puddle of wine on the floor that's in front of the door and there's a wine uh the splashed wine that's dripping down the wall and so we stopped and i'm looking and going look at this this is someone must have got hammered these guys probably had a party and and at that point right then as soon as i said that the door opens up and it's josh drew who pokes his head out the door only enough for his head to come out and he's pretty bug-eyed and looks distraught and i look at him and i go what's up with the spilled wine and i figured i'd get an explanation or whatever and uh he says he looked at me and just said rough day had a rough day and at that point i got concerned and said to him because i'm friends with with him you know i got concerned say hey you okay you want me to help you with something do you need help he said no it's okay we got it and i said okay and i me and my buddy took off and went into my place and what did you do after that keep my buddy eight uh i believe he had pizza from across the street and uh we talked we yapped for a while and you know it could be i could yap so it could you know it could take we were there probably hour and change or something like that and then uh he's you know we're done so it's i walked i walked him out and walked down i went to the elevator walked out went to the elevator we went downstairs i walked them out the door finished to finish the conversation that we were having and i said all right see you and then i went back in i went upstairs and i went to bed around what time was that that you went back into the eastern columbia building you know something is is if we got there at like around 9 30 and we we're talking i don't know an hour to an hour and a half two hours you know somewhere around 11 o'clock i would think we can go ahead and take exhibit 116 down mr baruch can you um describe for the jury the events of the next day may 22nd 2016 yes it's my birthday may 22nd is my birthday i wake up i end up uh texting johnny and saying hey i'm gonna be in town because he's not staying at the at the eastern columbia building he's staying in a house in in town okay and uh so i texted him it's my birthday i said listen i'm gonna be in town uh i'm gonna come by and uh to have a birthday drink okay i didn't hear from him you know i didn't get an answer back but i said that's what i'm doing if that happens that happens but so it was around uh noon noon time uh that so i left i walked out of my apartment and i go through the hallway as you see the graph i go through the hallway and i turn the corner from penthouse street and uh as i'm walking down who do i see it's a group of people it's a guy in black clothes uh a black shirt black pants amber heard and i see josh drew who's leaning up against the door and the door is open this door is open something's going on and as i'm walking up i'm saying hey what's up what are you guys doing and then amber turns to me as i'm walking up amber turns to me and she says uh johnny came by last night he got violent so i'm changing the locks on one three and five and i'm look at her and and she goes oh and don't worry about two you're okay and at this point i'm now walking past so now we're all in front of this of the open door of the apartment and i see there's two guys two locksmiths working on the door so now i'm standing on one side and yeah you have josh drew on one side of the door you got the two locksmiths with the door open working on it some lights the sun's coming through the door some light from windows and then amber is in is in front of me and there's the security guy and and that we're two feet away from each other talking and she introduces me as she as she's finishing saying uh oh don't worry about your uh your apartment she says oh and this is a security guard that i got that was going to be hanging around and she i got introduced she introduced me to him and i shook his hand he gave me a card which i lost and uh and that and i'm kind of taking this in and going and i said wait what what happened what's what's going on and uh at that point josh drew looks at me and gives me the high sign so like hey i'll you know follow me i'll uh i'll tell you in private and when you were speaking with miss heard how close were you standing to her like i said two i'm two feet a foot and a half two feet away were all two feet and how was the lighting in that area there's lights in the hallway but we're standing and we're standing in an open doorway that the wall this uh is all windows sunlight's coming through and you can operate in this light there's that much light did you notice any marks on her face when you were speaking with her no did you see any bruises no did you see any redness no did you notice any swelling no did it look like miss heard was wearing any makeup no had you seen her wearing makeup before yeah and you had seen her not wearing makeup before yeah i seen like i said with fate doing with the face mask doing a face mask no makeup hanging around the uh waking up in the morning uh no uh with makeup glammed out to go out in three and a half years just seeing her in different different forms did you speak with mr drew about anything at that point well yeah after i said that uh uh hey what's going on and he gave me the high sign to like hey follow him we went into my apartment and had a conversation and what happened um after you had that conversation with mr drew we left the apartment and we'd we go walking back uh towards uh penthouse one and as i'm walking back i say to amber as i'm walking up he hit you and she goes yeah he threw a phone at me and hit me and i'm looking because i had just seen her two feet away and i'm going where and she puts her head out she puts a face out like that for me to look at the right side of her face and i'm looking but at that point also i'm looking and i turn i turn around get on the other side we're in the doorway so i'm on this side with the light shining this way from the doorway with the lights above and but the sunshine and she's got a face out like this looking you know to show me and i'm looking and i just go i inspect the face i'm looking at a forehead i'm looking at the side of a side of her eye i'm looking at a cheek i'm looking at her chin i'm looking at the other side of the face i'm looking at the whole thing and i don't see anything i don't see anything to i don't see a cut a bruise swelling redness it's just amber's face that she's going like this and show me so i'm not seeing anything i back up and i'm making a joke i make a joke going well i don't see anything but maybe all the beauty from one side of your face to the other side of the face is outshining everything so i can't see anything and she's laughed and she's you know smiled and i just looked at everybody and said hey this it sounds nuts and i went and i gave i said i gotta go and i gave her a hug and kissed her on that side of the face kissed her on that side of the face and then i left said goodbye what was her reaction when you kissed her on that side of the face nothing did she flinch no did you see ms hurd again the next day yeah yeah yeah when was that so that's monday that was may 22nd my birthday then the next day is uh monday the 23rd i had woken up uh with a chest cold and i heard a knock on the door and it's amber so i opened up the door around what time was that that's i want to say maybe around maybe around noon time maybe a little bit before maybe it could have been a little bit i think around noon time again and uh i went downstairs and i opened up the door and when you opened the door did you have a good view of miss heard absolutely yeah how was the lighting lighting's fine lighting from the from outside and there's light from my place yeah so this is the lighting was great did you see any marks on miss hurt's face at that time no same thing like the the the day before there's no redness there's no swelling there's no bruises there's no cuts there's no nothing this is the animal looking like amber did you notice if she was wearing any makeup at that point she didn't look like she was wearing makeup then either what did miss hurt say to you during that encounter she was knocking on my door to see if uh i would take uh the house key her house cake to let the cleaning lady in because she had to go somewhere and said i woke up that day and i had some kind of chest cold thing i was upstairs laying down and so i was i looked at her and i said hey listen i'm i i'm feeling sick i'm going to be upstairs laying down this entire time for the day or whatever and that uh so i can i'm not i can't do it and then uh she stood there and and uh is like well i gotta figure out what to do like maybe if she was only dependent upon me to to give the housekeeper the key it's the same the housekeepers it cleans both of our places and uh so i said hey listen won't you go ahead and take the key and put it in an envelope and bring it downstairs to the concierge you know one of the and that's where the key would be and tell hilda who is the housekeeper that uh that's where the key is and uh that's it and here's your set and she was like yeah okay i guess i could do that and i'm looking i'm three feet away from her two and a half three feet away from my talking with and how long did that conversation last three minutes did you see miss hurt again the next day yes i did where did you see her all right it does i go down i'm leaving the my apartment on tuesday to go downstairs to the cafe to go get something hot to drink i still haven't shopped or did anything for what's a chest cold and uh so i wanted something hot to drink i go downstairs and uh as i'm locking my door that uh all of a sudden a group of women will come up to penthouse three because in the corridor on the graph you could see we share the same corridor so i closed i'm locking my door and a group of women show up did you recognize who the women were three of them yeah it was you know something i'm not sure if it was four or five women but it's uh amber it's her sister whitney and it's uh uh melanie iglesias who's a makeup artist for johnny and amber and then there's two other women i'm that i didn't i didn't recognize but not sure did you interact with the women at all well i did after closing the door whitney who calls me her spirit animal came running came running down the you know down the the hallway going isaac spirit animal and i'm i'm going hey listen i'm not feeling so hot i'm not feeling so good and i get duck under arms you know stop and i love you but stop and i duck on the rums and and and i go past and i'm now passing the other ladies uh amber and uh who she's with and uh i'm i'm looking at them they're laughing of this whole scene and then that was it and then i walked went past and went down and got some hot tea did you see ms hurt's face during that encounter it was a quick glance but nothing's you know nothing's just shot out to me to like notice anything um did you see ms hurt again the day after that well i saw again that day oh can you describe that please yeah that on the way back from me being outside the cafe getting dr uh having a tea i come walking back in and now all her and her the women that she was with are coming back out and we're in the lobby and so and the doors of the lobby it's all windows there's great light shining through the entire lobby and the women are there's a table in the middle of the lobby and her uh her friends or i don't know if they're friends or not i know three you know one's a sister and the other one's a friend they're coming they're walking on one side of the table and then she's on the other side of the table where i'm walking and now we're walking past each other and she's you know of course we're gonna acknowledge each other in looking at each other and now she's the sun shining right in our face it's to my back because i'm walking in and so that's like this and saying all right hey all right enjoy yourself have a good time or whatever whatever you're doing you know and go by and i went up and that was it that was the second time that i saw her and that's on tuesday and did you get a good look at her face during that second encounter absolutely the sun's shining right on her face did you notice anything unusual about her face nothing no no no cuts no bruises no swelling no red redness no it's amber it's amber's face and then did you see miss hurt again the day after that yes i did and that's wednesday may 25th that's right where did you see her at that point i was like okay i gotta shop for something to because otherwise i'm not going to get rid of this chest cold i i would go to the store and on the way back in between the garage and the building there's this room with like vestibule you know that's uh that's you have to walk through and i'm coming in to go into the building and amber and whitney her sister are coming out of the building to go into the garage and we met there how long did you speak with them if at all yeah we spoke that's sold we're facing each other i'm bit them amber and whitney uh across from me we're two and a half feet two feet away from each other talking of course and so we stop of course to say hey what's up what are you doing where you going where you going where you're coming from i have bags of food in my hand of stuff that i went and i bought and so i said hey i'm coming from shopping i finally bought myself some stuff to get rid of this chess call thing and uh they go and there's they're going to the uh cvs and they look at me and they s and so what happened everything everyone's smiling and stuff and and she says you sure we can't get you anything did how about we get you some aspirin or some you know some cold stuff i said no i think i got everything and uh that and they said you sure and i said yeah yeah of course i got it done don't sweat it and uh uh you know a kiss or whatever i got my hands i can't hug or whatever so and then uh uh i was said to see you and i went on went up and they went through the garage that was the that was that was it that day did you have a good look at her face during that conversation yes this room yes yeah this room it's comp it's it's completely lit that it's a spot and there's a camera taking uh uh you know cameras always on the security camera and all always and so it's got good lighting and stuff because this is a spot where if you use your fob key to to go into this into the building well the door takes a long time to you know it's one of those things with the uh pressure thing that the door just doesn't close shut it takes a while to for it to close someone could be in the garage is not supposed to be in the garage run and hold the door open and that they then they get into the apartment building and then who knows so maybe somebody gets ripped off but so it's well lit for security reasons and that there's a there's a camera there it's taking pictures you know doing what the camera does was miss hard wearing makeup during that um discussion neither of them looked like they were wearing makeup at all whitney had this hat on that uh it was a fun hat or whatever uh and that no it's no no makeup i don't i don't even know whitney to to be a a makeup person and that uh amber no she looked like she was you know just natural amber it's it's all you know just as always no makeup did you notice any marks on miss heart's face no no did you notice any swelling no no swelling no there's no nothing there's no swelling no bruising no redness no cuts no i don't even you know nothing back to uh may 21st for a second when you first heard that ms heard told you mr devitt hit her do you recall that say that again we when ms heard told you that mr depp had hit her on may 22nd yeah my birthday how did you feel hearing her say that all right what's the relevance to how he feels i mean it's a present sense impression of how he perceived that in that moment i'll sustain the objection mr brooch did you see miss heard at all the rest of that week of may 23rd no did you learn at some point in time that ms heard had filed for divorce from mr deb say that again did you learn at some point in time that ms heard had filed for divorce from mr depp yeah how did you learn that i learned it from the internet after the weekend around that's probably monday sun either sunday or monday i'm on the internet and i end up seeing a picture of it was the friday of that that week the past week and there's a picture of amber wearing a black morning dress and with this brown mark on her cheek and that she's out she's been to a divorce you know she went to go file for divorce that's how i found out were you surprised when you saw that surprise is not the word it's like what the hell is this what's going on at any point when you had seen her um during that prior week had she told you that she intended to file for divorce i'll i'll allow it go ahead you can answer the question sir what's the question again at any point when you had seen her during that week had miss heard told you that she intended to file for divorce no no she never once sunday monday tuesday wednesday and thursday or friday not even see it no there's no i'm clueless she does not she did not say anything about divorce so what did you think when you saw those pictures um and read the articles and learned that she was filing for divorce all right i'm sorry objection relevance to what he thought i mean it builds on all the testimony he's given previously i'll sustain the objection when did you see ms heard next after that she knocks on my door june 3rd friday friday a friday night june 3rd she knocks at she knocks on my door around 11 o'clock is and is the next time that i see her and what happened when she knocked on your door on june 3rd i opened the door i opened up the door and naturally you know something i'll say is hey how you doing you know to say hello so i open up the door and say hey how you doing and she looks at me and she says not feeling so hot that uh i made some food would you like to come over and eat with me and at that point after you know everything i've seen i looked at it i said listen me and you we're not going to talk anymore after everything that i've just seen all week long from from the past the past week and change you uh listen i'm confused i'm angry and i'm frustrated by everything that i've seen and that i think the best thing is for me and you that we don't talk anymore did she say anything in response yes she in response to that she looks at me and she says i told johnny i don't want anything the lawyers are making me do all of this and i you know that's what she said did you respond to miss her no what i was thinking was that to me when after saying that after she said that to me i'm thinking to myself hey how did you know all right i'll just take that objection next question did you see any injuries on ms heard's face on june 3rd when you spoke with her no did you ever speak with miss hurt again after that well she said to me uh after uh that the lawyers are making me do all of this uh then she's uh i was just looking at her and then she ended what she was saying by saying uh well i'm sorry you feel that way and i closed the door and would never talk to her ever again did you have any interactions with the staff of the eastern columbia building um about miss herd's allegations uh against mr deb objection okay mr brooch did you have any interactions with the staff of the eastern columbia building about miss herd's allegations against mr depp yes and at some point uh did you see a security video taken in the eastern columbia building yes when was that at some time in june maybe two weeks in or something like that it's two three weeks in can you describe um what you saw in that video yes i can it was a video of uh amber and whitney waiting at the elevator a mezzanine level coming from the garage obviously and uh waiting for the elevator and whitney does this to anvil and hits her like fake and hitting her in the face and then they start laughing did ms heard react at all in that video to the fake punch that you observed whitney throw yeah she's laughing after doing it they both uh you know laughing at each other with each other mr brooch do you know who elon musk is sure have you ever seen mr musk in person yeah where did you see him in person first time was uh i'm getting into the elevator on the rooftop penthouse level i'm get going into the elevator and he's coming out of the elevator going past me and when did that take place this is after may this is sometimes june it could be july but after may in that same year 2016. yeah and when was the second time that you saw mr musk uh uh one morning waking up and going and opening up the shades to uh the bedroom and it's on the second floor and it overlooks the balconies our joining balconies because my balcony joins with uh john and amber's of balcony and that i opening up the shades i see uh elon musk going through the balcony door on their side uh to then walk down a common corridor to that then at the end leads to a door that you then you walk out to the rest of of the rooftop and it could you go to the pool you go to the gym and stuff so i'm looking out and at the view the the view out the window is of the both of our balconies so that's where i saw him and when was that oh i sometimes is either june july some but it's after may mister bruce how long have you known mr deb met him i believe in 1980 and was 42 years well it's going to be 42 years have you ever seen uh mr depp be violent when angry with miss hurt objection leading i love the question okay i'm allowed to answer yes yes what's the question again have you ever seen mr depp be be violent when angry with misheard no well the from what i said uh from before there was an argument that i walked in so there's obviously there's that that but have i ever seen him be violent to her uh with uh physicality no did you ever see him hit her never in your three and a half years living at the eastern columbia building next to mr depam has heard did you ever observe any injuries or marks on misheard objection leading your honor all right a sustain is deleted did you ever notice anything unusual about misheard when you were living at the eastern columbia building objection leading your honor i allow it i can answer yes sir what's the question again did you ever notice anything unusual about miss heard during the time that you were living next door to her at the eastern columbia building besides having great teeth no mr burj are you appreciative of everything that mr depp has done for you objection your honor leading end relevant all right i'll sustain it's deleting all right mr brooch how do you feel about what mr depp has done for you objection well you know what no i'll go ahead okay go ahead i think that's what i think that's withdrawn go ahead i can answer the question oh okay just answer the question sir and the question is how do you feel about everything that mr depp has done for you oh come on this is it's unreal yeah it's you know you think too much about it you're gonna cry that uh i appreciate everything that he's done for me um you know i i it's like stuff you can't pay back would you lie for him under oath no no no no no all right i'll sustain the objection next question have you given truthful testimony today sir objection your honor leading it's still leading i'll sustain the objection that's all you have okay thank you all right cross-examination let's start with the makeup now you know that ms heard was excuse me i didn't hear the beginning of what you started saying i said let's start with the makeup okay okay you're aware that miss heart misheard has both modeled and been an actor and had been for many years before you met her correct i knew she acted i didn't know she was a model okay were you aware that she had a commercial agreement with l'oreal for example when now or back then what's your knowledge i don't know any of that okay have you ever been with ms heard when she has put makeup on i've been in the room yeah when she's putting when makeup was getting put on her yeah when makeup was being put on or was this for some acting role or something like that it was an event that they were going to so that was somebody else applying makeup to ms heard who was going to have some gala event that she was going to yeah okay have you ever been with miss heard in her bathroom or anything when she's applying her makeup in the morning no okay do you are you familiar with amica cream what is [Music] yes no okay do you know what type of foundation ms heard uses no do you know what type of concealer ms heard uses no do you know what type of tint ms heard uses i have no clue do you know what types of powders ms heard uses oh okay so when you're saying that you didn't notice any makeup would it be fair to say that you yourself are not familiar with what type of makeup amber heard uses on a daily basis i don't know what she uses on a daily basis that's my point now the first time that you saw her which was may 22nd yeah miss heard was there were you aware she was on her way to somebody else's birthday party not yours but somebody else's that day no okay can you tell me what her hair style was that day it's just down down as in just regular house she has it up now she's got some kind of hair style but no she's she was no hair down regular no makeup just hanging well when you say no makeup you don't know she was not wearing makeup correct for a fact correct no and you don't know whether she had applied amica cream correct no and i didn't even know what amica cream is and you don't know whether she had had applied concealer or foundation or powder or tent correct that's correct okay now if she's going out to a party yeah do you think she would want to have her bruise exposed objection your honor what's the objection calls for speculation all right i'll sustain the objection next question so um do you recall what ms heard was wearing that day you know something i could have sworn she had on a schmatta dress uh hippie dress at that particular time but i could be confusing it with june 3rd she's got this victorian type of uh [Music] long hippie dress that has embroidery and i she definitely was wearing that bet that night all right but but let's go back to may 22nd did you recall what she was wearing i could have swore she was worn uh wearing a another schmatta dress that i've seen hanging around uh uh the apartment with and do you recall what color no okay do you recall what jewelry ms heard was wearing that day no okay now you indicated that there was a security guard there and there was josh drew correct and was there anyone else there yeah the two locksmiths okay and also in the apartment for a fleeting second person went walking by and who seemed to me look like it was raquel pennington but it could be it could have been uh another friend that was supposedly staying with them okay so you saw somebody come by so so no go go through the living room and then they're out of the picture because they went upstairs so they're at this that's somebody that else was in that room and but walking by okay yeah so and you talked to josh what did josh tell you it was true he took you to the side what did he tell you objection your honor hearsay all right i'll sustain the objection to hearsay all right before you spoke with josh drew in the other room what if anything had been said about what mr depp did the night before objection to the extended calls for here say your honor all right be a hearsay objection i'll sustain that objection i'm not i'm asking what if anything that was still solicit hearsay but he already testified about what amber said i'll go back to that okay so what exactly did amber heard tell you happened the night before as i was walking up the first time she turned to me and said johnny came by last night and got violent so i'm changing the locks on one penthouse one three and five don't worry about your place okay did you ask her for any more specifics on what she meant by getting violent huh did you ask her for any specifics about what she meant by he came by and got violent no okay okay well i'm going to jump you to the next day for a few and then i'm going to come back but let's go to the next day so the next day you testified that you saw her twice correct from sunday no monday i saw it once in the morning that's when she came by to ask if you could have the key or that you could leave the key for the house right for helder and you weren't feeling well right that's right okay so you wouldn't have been standing very close to amber right because you were sick well i opened up the door and i'm holding the door we're like three feet away from each other yeah okay and you told her you were sick right yeah okay do you know where she was going out someplace correct she had she was going somewhere right she wasn't going to be there all right do you know whether she had applied any amica cream that morning to her face no do you know whether she had applied any concealer to her face that morning no do you know whether she had applied any foundation that morning no do you know whether she had applied any tint that morning no do you know whether she had applied any powder that morning no okay now the next day i can't tell you she looked like she wasn't wearing any makeup right and would you agree that people who are models and actors can be pretty darn good with putting makeup on so that you can't tell they're wearing makeup objection your honor foundation calls for speculation i think that's a fair question to ask him i'll sustain as a speculation next next question do you have any knowledge of the skills of amber heard with respect to putting on makeup well it can't be that good because she's got a friend who's is a makeup artist who came over to do makeup but i don't really know right and and that makeup artist that comes over does it when she's going to be on some show or in some big public event or gala right yeah yeah that makeup person and you're talking about melanie iglesias right uh yeah exactly and that makeup person doesn't put amber's makeup on every day for her does she i wouldn't know how many times have you did you see melania glacis put makeup on amber one time okay it's just one time okay so she wasn't living at amber's house right no no no i had we i i hung out with her and uh husband and johnny and uh and amber and you know over there one time eating uh and then another time i was when i met her that uh seeing her do makeup for these guys okay so so you don't you're not saying that that amber doesn't know how to put makeup on herself correct oh no i'm sure she does okay but again i would think she does you know but for the most i'll tell you what over three and a half years living around around each other for the most for the most part she's not a makeup wearing person completely natural ha rocky totaled great complexion texas natural neck girl next door no makeup wearing hanging out did amber ever tell you she was not wearing makeup did she ever tell me in any of those three and a half years that you're saying she wasn't wearing it around the house did she ever say i don't have a stitch of makeup on as many times as she's told me i am wearing makeup which is i can't remember so i don't know yeah no i there's not one time i remember that of saying that okay so now let's go to the next day i think that's the day you've got the two times uh that you saw her she's with other people yeah and she's either going out or coming in correct well first time they're coming in and the second time they're going out so they've been out someplace before they're coming in correct objection your honor foundation i'll allow it you can answer the question sir oh i have no clue okay okay but they're they're physically entering the house in other words they haven't been in the house they're coming to the house from some place right oh i would have no idea when i walked out who knows they might have been out and and twice before that but i i don't know they could be coming from another apartment you know coming you know to go there and i'm seeing them it could be the second time that they're entering this apartment or the first time or the third time yeah i don't know okay i have no idea and and do you know so you don't know where they were no idea whether they were out in public someplace correct no of course not i won't know that all right um and then the later time that you saw them that day they were going out is that correct yeah okay okay and do you know whether amber had any amica cream on that day i don't know i don't know and i'll try to make this faster do you know whether amber was wearing concealer foundation powder or tint that day i don't know okay now the next day i think you said it was she and whitney is that correct on wednesday yeah okay yeah yeah okay um and again do you know whether she was wearing any amica cream sir if you could just answer this question i'm totally sorry i'm sorry that uh no and do you know whether she was wearing concealer foundation powder or tent no okay can you tell me what amber's hairstyle was on the 23rd that's monday like i said when she knocks on my door hands down okay can you tell me what she was wearing that day not exactly but if i if best of my recollection pair of dungarees and a t-shirt okay at the time when she knocked on my door to give me the key if she went home to go change or something like that i got no clue okay do you remember what color the t-shirt was i think it might have been white best of my recollection do you remember what jewelry amber had on okay let's go to the next day the wednesday and you've got all these people here next day is tuesday okay next day tuesday is when you had the bunch of people coming together to her house the first time right right what was she wearing then you want to know something i do remember uh of a women's beige uh long coat kind of like a a woman's uh not a raincoat but it could be similar to that it was a beige long kind of looking like a business coat type of thing loved a female version of a colombo jacket okay and what was she wearing under it oh i have no i i have no cloak okay and do you remember what jewelry she was wearing no okay now you said that on the 22nd that you kissed her on the cheek what day the 22nd your birthday 22nd sunday yes okay so when you showed it the first time you went like this right and then the next time when you said you did the kisses you went like this what's your typical way of kissing women when you greet them i think i'm not understanding any of what you just did okay so when you well i'll just leave it at amber when you i take it that you would regularly kiss amber on the cheek when you used to say hello and to say oh yeah yeah absolutely and tell us how you did that objective can you just show us how you did that which time regularly did you have a different way of kissing her on the cheek different times or did you have a general way that you would greet or say goodbye to amber with kisses regular it's a regular you know you give her you give it back on the cheek goes you know like you just touch cheeks and okay that's that so it's it's a pretty soft it's kind of like a almost a superficial one or is it a really hard one on the cheek no it's uh you know just uh yeah you kiss someone on the side of the cheek i don't know pressure wise what kind of torque is there uh i mean is it just one of these little pecks or is it is it much harder well it's a regular use you you touch you know you touch and point and that's that okay so so you think it was pretty hard you you peck her on the cheek pretty hard every time objection your honor no i'll sustain objections you want next question okay you also showed that you did one like this did you ever do it a two kiss when you greeted amber two general i'm not european i'm from brooklyn no that no you give you know europeans do you know both sides and sometimes you even three bam bam all right let's go to the fake punch i want to make sure that i understand exactly what you remember seeing yeah you said that it was two to three weeks into june is that correct that you sign it's got to be somewhere in that period okay to some somewhere in the the first three if the i would say the first three weeks of june all right yeah somewhere like that can you recall which week no okay so you saw whitney and amber was there anyone with them no okay do you recall what either of them was wearing long jackets yes actually i do long jackets you know overcoats and how was amber's hair styled that day down that pull back pulled back well when i say pull you know it's like hairs down you know maybe because of something around the neck or whatever the pears you know flip back or whatever not tied back i don't remember if it was tie back but just where it's full that i remember okay so now where were they standing when you watched this this is uh the where would they stand yes they're standing waiting for one of the elevators on the mezzanine floor where there's i guess you could see there's cameras that you know has that view of the the the of the elevators on the mezzanine floor so they're on the mezzanine level yeah this is the same level this is the same level there's apartments on that level and that that's how the exit how you get out to go to the garage and so were they coming back from the garage well if they're standing at the elevator outside that it's could be and waiting to get into the elevator on that floor so it could be that maybe they came from outside maybe they know somebody who lives on that floor because there's apartments there i got no clue where they're coming from it's that's not even in in the thought process when i see that when i see this it's not like wow i wonder where they're coming from oh no it's okay so now what i saw tell me where they were each standing as i'm watching the video this tape uh amber's on the left and whitney's on the right okay and then tell me just take us through tell me what you saw amber's on the amazon the left whitney's on the right they're hanging out can i stand up yes sir and so here's amber here's whitney and they're hanging waiting for the elevator and whitney does it either looking at each other yapping or whatever whatever they're doing and whitney goes like this just a fake pow and then they both start laughing and then they're just standing there doing yapping doing what they're doing and how close does whitney's fist get to amber oh i'm watching this it's a fake thing it's not it's not like she went and she hit her own sister no but i mean she just you know go in power if here's my face if he's if if here's my face you know it's just coming by you know fake punch going by just you know that fuck okay making believe just make him believe it's a belief punch okay and and then they both laugh you say yeah they both you know they just thought you know did you watch them get on the elevator no okay so the part that you saw they the elevator never opened during that time that's that's right okay that is correct and how many seconds would you say or minutes would you say this little clip was oh what i saw was 10 seconds uh 15 seconds okay and do you recall what day that was that i saw this no no no was there a date on this the video oh i don't i don't i if there was it wasn't something that i acknowledged okay great good thank you all right now let's go back to the argument that you witnessed between mr uh depp and actually ms hurd who was on the phone or the speaker phone do you recall testifying say this again start against yes let's go back to you testified that you observed an argument between mr depp and ms heard do you recall that you came into the room mr dev had amber on speaker phone do you recall that yeah okay mr mr def was drunk would you agree yeah okay and do you recall that amber was actually in london not new york no you don't recall that no i thought it's it's i think i thought it was she was in new york okay and you recall that mr depp was accusing amber of sleeping with somebody right there was somebody else in the room with her and that's that's and that's what they were arguing about are you sure that mr depp wasn't thinking there was someone in the room and she was trying to tell him there wasn't somebody in the room he uh say that again are you sure he wasn't saying someone was in the room and she was trying to convince him there wasn't anybody in the room well he said that that he heard of the other voice okay and were did you hear the voice oh no i walked in there already it's this is already in motion right and amber's saying why are you saying that right amber was amber was saying come on baby why are you being like this what do you do what are you doing come on johnny well this this donate why are you being like this right and it was taunting how is it taunting to say why are why are you accusing me of having somebody in my room because they were in the midst of no solution at that point it's it would be if instead of taunting saying listen john let's talk tomorrow and let's end this conversation right now and every and and we'll talk tomorrow and we'll get to an understanding because there's not going to be any solution right now but there was none of that it was just continuous oh baby oh baby so and that kept it going if if mr depp in his drunken state was suffering from delusions and thought he heard a voice and wasn't do you think it would have been reasonable for amber to be saying what's going on why are you saying this what's going on objection your honor speculation i'll allow the question if we can answer it you can answer the question sir if you would i think it would be what if if mr dev was suffering from delusions and there wasn't anybody in the room and he hadn't heard a voice but thinks he's hearing a voice would it be reasonable for amber to be trying to figure out what's going on objection your honor hypothetical speculation i'll sustain a speculation to that question okay and and the bottom line is you came in on the call so you don't know what he said first or whether there was any voices correct whether he heard voices yes besides hers yes no i didn't hear the beginning of the conversation and then after the hang up he went straight to bed right no after the first hang up she calls back again which i was was was it necessary i don't know and then the third time she knew do you know whether she knew whether he accidentally hung hung up or not that he accidentally hung up right do you know whether she knew whether whether he hung up intentionally or no i didn't say the same way that i wouldn't know if like you know yeah she didn't know that the telephone line got cut right okay so so after the three calls that you testified about he went straight to bed right went to the couch and laid down right and he was drunk yeah and went and he went and went to sleep yeah he went out do you know whether he'd taken any drugs that night no okay now you have known you've already testified you've known him for 42 years he you didn't pay rent at the penthouse correct no no one did right right okay and then after you finished at the penthouse you went over and lived with him in sweet sir correct i live in one of his house uh house that he owns on suites and you still live there yes and rent free correct yes okay and uh is it has other than the hundred thousand you never paid that back right the hundred thousand that he's given you no that's not that's a thing that that's a thing for me when i if the how i look at it and stuff at some point i would love to pay it back pay back uh some that money but that's not something that is expected that he's expecting would you say you're kind of beholden to mr deb not beholden at all he's giving you a hundred thousand dollars he's put you in that race i'm sorry i started i didn't hear the whole question can you say it again you were rent free in in penthouses for a number of years and now you've been rent free ever since in sweet sir that's that's a nice friend yeah okay and you i think you testified already you're pretty angry with ms heard right about the phony pictures that would that were taken and put in uh tabloids and about the fake narrative and about uh and the way she's uh trying uh at trying to get a a a a fraudulent dv claim to extort and blackmail uh a man yeah that kind of got me uh uh pretty frustrated confused angry upset yes which is why i said the best thing for us to do is not to talk to each other okay yes was it fair to say you're still angry with her oh you know something it's six years but we just heard you give you years am i angry anymore i'm not you know what i am is tired and i want this all to end how to go heal him to go heal you know so many people are have been affected by this malicious lie that she started and she created and it's gone out the door and around the world and so i'd only i can't even paint anymore i've stopped painting for the last who knows how many years and that's affected by stuff it's it's it i don't i i'm not angry at anybody i want the best for her for her to take her responsibility heal and and and and and and move on move on and and for johnny john you know his family has been completely wrecked by all of this stuff and it's not it's it's it's not it's not fair it's not right what what she did and what happened for so many people to get affected from this it's i it's insane and mister that's how this happened and mr burroughs if in fact she's telling the truth and if in fact mr depp who has engaged in enormous rage and domestic abuse and violence of amber over a period of time that you wouldn't know about then maybe it's time for him to take responsibility don't you think objection your honor speculation lack of foundation relevance speculations he just went off on this rant and rave about assuming that she's you asked questions i didn't ask a question that launched that i'm going to sustain the objection okay i'll i'll ask this mr brooch you don't know whether mr depp has committed domestic violence of amber heard do you i never i've never witnessed i never saw or witnessed whatever type of claim that is that is being said ever i've never seen him be violent since kit since teenagers from first person i didn't ask you that i said you don't know whether he has committed domestic violence or abuse on amber isn't that correct that's correct i did not witness any physical violence but you have seen mr depp use drugs as well as drink and be drunk correct oh yeah okay now i've partaken i'm going to ask you to take a look let's let's pick up dep exhibit number 116 again it's already in if we can have that published to the jury mr how much more do you think you have i i think i can finish it up if you give me five or three more minutes maybe maybe less okay all right i'll hold you to this okay okay so mr bruce i just want to make sure that i understand this is the penthouse thing and you spread off if um so on this diagram when you got out of the l was you said 9 30 today but in fact it was between 9 30 and 10 that you came back with your friend correct no it was around 9 30. it could be five minutes one way five minutes the other way could have been just do you recall saying it was between nine and nine or between 9 30 and 10 earlier today no i said that do you recall do you recall are you sure it was 9 30 give or take five minutes or could it have been between 9 30 and 10 it was 9 30 give or take five minutes five to ten minutes either way and you saw a broken sconce no i did not see a broken sconce what did you see i saw a broken glass on the floor shards of glass pieces of glass which i figured could have been a broken sconce or possibly maybe uh the something from uh the fire department stuff that's around the walls so it could be something broken from that but i real you know maybe one of the sconces broke i didn't see your broken scots i just saw the glass okay was was there typically a sconce right there did you come off the elevator yeah from my memory there was sconces on on the walls certain places do you remember looking that night and saying where did this glass come from there's there's a broken one did you tie it tie it together no it wasn't it wasn't uh it was in a it was a assumption it had to come from some of those places because what the what the glass looked like to me looked like it might have come from one of those places it could have been you know maybe the stunts okay when you said from the fire thing were you talking about the fire extinguisher no no no not the fire extinguisher uh there's there was a uh in the hallway that first hallway that you go through the doors that you walked through after you get out of the elevator those doors the fire doors that you close all right hopefully no one gets burned to death that would be you know crazy um but then along the wall i believe before by the staircase because there's a door that's when uh next to penthouse five then there's the doorway the stairwell uh door and i believe there's a thing that's by the floor there that's uh that's got a glass plastic thing around it so it could have been something from that coach all right yes ma'am council do you have another copy of the deposition is this something for me to look at just wait for a question sir i asked you a few minutes ago whether you you were sure that it was 9 30 give or take five minutes or if it could have been somewhere between 9 30 and 10 do you recall me asking that question yeah okay and i'm going to ask you to take a look um at page 39 do you recall giving your deposition on november 20 2019 oh from down in anaheim yes yeah i remember that and were you understood at that time well that's yeah i think that's i believe so yeah it was about two and a half years ago wasn't it two three yeah it's yeah like between two and three years yeah sure all right so if you can take a look starting on page 39 hang on a second and if you go to the line 21 where were you on the evening of may 21 2016 and your answer was all right so i was out in the street i met i was with a buddy of mine calls me he asked if i wanted to go out and eat and i says i just ate just meet me let's meet at the apartment let's go hang out so i met him at my apartment probably i want to say around 9 30 or a little bit later i don't know yeah between 9 30 and 10 do you see that so i met him at my apartment probably i want to say around 9 30 or a little bit later i don't know yeah between 9 30 and 10 and that ends up so does that refresh your recollection that it could have been a little bit is somewhere between 9 30 and 10 i go more with 9 30 give or take five minutes because it could have been 9 20. okay it could have been 9 25 it could have been 9 35 but i go with 9 30. but okay and did you see any police officers no okay did you ever hear any police officers no okay so let's go back to this 116 for a second and you said that you saw a lot of wine at right outside wait a second line 115 sorry uh the exhibit that's in front of you on the screen oh oh oh so you go by penthouse now i have to hurry up to make my promise to your honor um so you see penthouse one there and you said that the wine was in that area right it's in front of the door okay it's a little uh it's it's it's it's gonna be a foot and a half two feet up further north north closer on the way to ph3 no it's right in front of the doorway you have it past the doorway the blue dot [Music] it's just in front of that doorway okay can you put the dot exactly where it was okay and how how much how much wine was there it was a puddle a puddle of wine could could you walk past it without seeing it no it was and could you tell a little bit about how much how much probably had been spilled of the wine i mean were we talking like a half a bottle a bottle uh looked like you know a couple of glasses of uh of wine uh making a puddle okay it wasn't like a full bottle that's it's okay that's a bit more okay thank you your honor i do have another exhibit i need to put in and i think that might take a little bit longer than a couple of minutes how much time are you talking about well i mean i can do it as fast as i can you can try okay then let's can we pick heather can you pick up well it's going to be plaintiff's exhibit 548. now do you have a recollection of mr depp uh having a volatile relationship with his earlier uh partner vanessa parody no but then again i wasn't uh i met her a couple of times i have no i wasn't we weren't our paths weren't crossing at that particular time when they were together all right do you recall mr depp ever referring to a circumstance with her as carnage what's the relevance uh we're talking he's trying to give character testimony here and i'm um i'll tell you what i'll move to a different one all right now you said that mr depp and ms heard were um you said that they were always nice to each other yeah do you ever remember mr depp referring to amber with the term cunt like to a face no no to you calling calling her a cunt to you maybe in a maybe in a text uh all right did he do it more than once i would have i would have no recollection of that i mean he's called me a cunt in uh in in in a text so i mean it could be i don't know how many uh uh texts if there's something specific if you could show me a text that would be a different story i don't but i don't you know we've had many texts together many kind you know okay let's go to line 57 then it would be section 57 of the exhibit that i have in front of me now this is a text message between you and mr deb do you see that well this is 80 million taxes on you good under 50 go to the one that's number 57. 57 from this is from me to him i'm sorry may i approach okay sure are you 157 yet 57 right and and this is to you correct from mr depp is that how it's uh this says from three two three four four five twenty four hundred that used to be my telephone number so that's two correct oh okay i see i understand i understand yes yes yes right and and that's to me all right and and the message he's sending to you and this is october 18 2016 is hopefully that objection your honor exhibits not in evidence and she's reading directly from it into the record all right uh all right does this refresh your recollection that mr depp referred to uh amber heard as a content in fact rodney cunt's writing corpse is decomposing objection your honor sustain the objection if you rephrase i'll ask it i'll ask it differently um do you recall mr depp ever telling you that he in base terms uh hoped that amber's rotting corpse is decomposing objection in the trunk of a honda civic a lot i'm not understanding the question say it again do you recall mr deb ever telling you that he hoped that amber heard's rotting corpse is decomposing in the fucking trunk of a honda civic objection i'll allow it yeah you can answer the question sir yeah that well i say yeah i'm seeing it here so obviously yeah it was said okay it was written and then go to 59 please and when you had to move out of out of the penthouse to go to sweet sir do you recall mr depp telling you that this was amber's fault and referring to her as a cunt can i read this thing first so that way what's going on so so now the what's i've just read this and i unders i remember i remember this exactly because this is the period of time you know i'm uh i'm moving uh and that this he he's selling the apartments and there's people who are coming over i'm still living there and it would have been better off if uh if uh i moved out so that way then the real estate people can look at it and not come in and look at the kind of paintings that i make and all that kind of scrap but my question to you is do you recall mr depp calling amber heard a cunt and saying that it was her fault well it's written there so yeah i could see that okay so if well i don't that's not what he says he says that cunt ruined such a fucking cool life we had for a while i don't know it's that's how he says i can't even look at the building anymore correct right can't even look at the buildings right exactly okay thank you i'd like to move the admission of those two limited excuse me objection your honor there are some uh i mean it's a significant exhibit there's definitely some hearsay in there i think i'll reserve on that on the entry of that okay we can discuss it later time okay are you done or i'm not going to publish i'm not i'm reserving on whether so are we done with cross yes okay and redirect briefly um we're going to be done with this witness before lunch okay there we go your honor okay mr brooch do you recall um that miss brettahop was just asking you some questions about some text messages you received from mr deb yeah uh do you recall when those text messages were sent no i'd have to look at them again and look at the date could you display it to the witness again and i believe we looked at lines 59 excuse me 57. do you see the date of when you receive that text message all right hang on october november just a month before it was the month before i moved out okay when was that text message sent it says uh 10 18 2016. that's october that's i moved out the next month so in november so this is from october so was that message sent several months after ms heard made claims against mr depp of domestic violence oh yeah yeah i'll allow it yes of course this is after this this whole fiasco that she started and if we look at line 61 what am i looking at what's the date on that message it's 10 28 october we can take that down mr brooch uh ms brettahoff asked you a series of questions about the security video from the eastern columbia building that you um observed do you recall that yeah the pal uh when did you understand that footage was from did you have an understanding at the time that you saw that video of when it was from i'll sustain the objection ms brethoff also asked you um a series of questions about um the argument that you overheard between ms hurd and mr depp on the phone do you recall that yes and you could hear um ms heard's voice on that phone right yeah do you recall if that was a facetime call or if it was just regular speakerphone just this speaker speakerphone and what did you understand her tone to be on that call that you overheard i'll allow if you can answer that's fine taunting egging on almost demean demeanoring uh the baby talk yeah i'll sustain the objection as to his answer and i'll strike it the whole answer you're not that the answer yes i believe you testified that mr depp um hung up the phone during that conversation do you recall that yes did you understand that mr depp was trying to end the argument by hanging up the phone his understanding of what mr depp was trying to do all right i'll sustain he has to pass speculation you're right he he he heard the phone call and he was there to directly what johnny depp intention was i'll sustain his reaction i know what my interest certainly i'm sorry okay thank you wait for the question thank you sir what was your understanding of um your intent with respect to uh hanging up the phone on that conversation he already asked and answered when he said he hung it up and so it was asked and answered also stay in the objection next question nothing further all right is this witness subject to recall possibly there's a silence okay so yes or no or not for you not from you yes all right all right sir since you're subject to recall that means that you may be called again to testify at some point so that means until that time the rule and witnesses still still is in place for you so you cannot have any outside information or talk to anybody about your testimony here today and uh don't look at any information about this on the news okay okay all right thank you so you're free to go at this time thank you thank you all right so all right ladies and gentlemen we'll go ahead and take our afternoon lunch we'll we'll give you until 2 30 to to take care of lunch again no outside information and please don't discuss this case okay all right thank you have a good lunch all right so we'll come back at 2 30 then secret all right thank you the parties we are going to be calling brandon patterson by video deposition designations at this point okay um and i just wanted to alert the court how we've handled the exhibits amongst the parties we've met and conferred um the parties have agreed that we have no objections to the eastern columbia building surveillance videos that have been authenticated by mr brandon patterson okay um in this deposition okay do you what exhibit numbers are they or whose exhibits are they and what well so we have no objection to all i think there's 87 currently so in the interest of time for the jury and the court and everyone here um because there are 87 we've agreed to show a selected smaller set which had been identified by both parties and both parties are taking on the responsibility of introducing and playing each exhibit for the jury okay with your honors permission so since mr depp is up now in his case in chief we are going to be playing the video deposition of mr patterson we will pause the video um and then when one of ms heard's exhibits comes up no no i'm sorry the deposition the person at just one time when that deposition were just testimonies once then you're going to pause right now and then you're going to do it i'm just confused i'm sorry your honor let me be a little bit more clear we're going to pause the video deposition of of mr patterson to allow miss herd's counsel to publish okay the exhibit which is also a video all right surveillance video i know it's gonna be a little difficult okay right so we ask that the court perhaps um remove the publishing from mr depp's council's table and allow ms heard's counsel to publish that exhibit which is a surveillance video and play that okay each side has taken responsibility of the clips that they would like to play yeah if that would happen how many times is this going to happen how many do you have which probably the longest is less than two minutes long and what happened in the deposition was that the witness saw the video and then testified so you'll pause it when he when the witness is watching the video we're going to watch the video okay all right and how long is this video i believe the entire deposition is about an 1 hour and 48 minutes 1 hour and 48 minutes and um with the exhibits i anticipate it might take us till the end of the day okay um but i nope no promises that's fine um i still need the exhibit numbers okay if we whose exhibit it is so i have two lists so i just want to make sure okay sure go ahead all right so i'll give you i'll give you ours okay um it would be 670 670 671 671 672 672 673. that's right i'm sorry i'm going out of order here that 666. that's okay six six six six eighty six eighty six eighty one six eighty one six eighty two six eighty two six eighty three eighty three six eighty four okay six eighty five 686 687 688 668 690 691 692 693 669 694 695 696 729 743 745 746 744 750 751 752 753 755 780 g 780r 780 x 789 a 789 b 789 g 789 h 789 l 789 n 789 r 974 and i believe we had 1041 which i think was the what actually came in from your uh today the the um the plans for the ecb i think that's the same thing but it was 10 41 and i'm not sure if you're objecting to that no so 10 41. okay just one question so you're entering all those into evidence and there's no objection correct well your honor i just want to confirm one thing with council sure may i come for sure as long as they're all eastern columbia surveillance videos your honor we have no objections which they are which they are so they're all interested except for the plan which was that one i just talked about okay so there those are all entered into evidence then all right and yes ma'am yours and your honor just short circuit this for the court um our eastern columbia building surveillance videos are um exhibit numbers 250 through 336. all right so exhibits 250 through 336. that's no objection to those exhibits correct yes okay so uh plaintiff's exhibits 250 through 336 are entered into evidence thank you your honor um would would your honor like to know the 10 exhibits that we were going to be playing for the jury no that's okay they're all in evidence that's all i need to know we don't need to pull them up so you're going to handle that yes all right the only thing about this is there's going to be duplicates i don't know whether we want to try to sort that they're in evidence so okay that's that's not going to okay could you put the big tv up though before we get the jury back in just since it's going to be a deposition with testimony we're going to go ahead and put the big tv up so if it works [Music] could you speak a little louder i'm sorry i thought the deposition video came through the other screen i was just i think it comes through here too yeah oh it does okay great yeah we will when you have a remote witness the remote witness will stay up there right then you can use those screens as well but when you're using deposition we can still see it over here fantastic just publish it to the big screen if you want to set up before the jury comes out just to make sure you have the person let's just make sure it's all working before we get the jury oh you didn't put it on there all right seems like it's all working okay no though that's fine all right are we ready for the jury then okay so all right thank you ladies and gentlemen all right your next witness thank you your honor plaintiffs call brandon patterson he is the corporate designee of the eastern columbia building by deposition designations all right patterson all right ladies and gentlemen this is the first one that we have of of a few where they already have been deposed and so you're gonna see them on a recording okay no volume do you have an audio connection attached to try it one more time could you push play one more time general manager for what uh if you could please state your name and address for the record sure brandon patterson 849 south broadway los angeles california 90014 and if you could please state your occupation general manager for what i am the general manager for the eastern columbia hoa in los angeles and how long have you been in that position uh i've been here at the building six years okay were you there in 2016 yes um and are you here under a subpoena as the corporate designated for action property management yes okay and if you could please pull up exhibit one and just scroll to page 15 of the pdf please does this look like a copy of the of the subpoena that you received um yes is it okay if i call your building ecb yes uh is it your understanding that ecb has produced these three categories of documents and films yes please go to exhibit two and scroll to page eight and does this look like the topics of the of the deposition of a subpoena for testimony okay um is it your understanding that uh you're the most knowledgeable person on these topics i am the most knowledgeable within action property management as it relates to these items are you responsible for for managing any of the records or managing preserving any of the records and videos at actual property management uh specifically as it relates to eastern columbia um this is the only property and building four action that i manage so action as a whole i i can't speak for that but as as for ecb yes thanks and this whole this whole deposition i'll be just referring to uh ecb related to action property management um what was your role in locating the videos responsive to this to the subpoena uh the videos had been saved um from the original case i don't recall the exact year that was so i think this is number four now so i provided the video that was requested that had been saved as the only videos that were that were requested and saved and um who saved them was that you or someone at action property management um i had initially worked on saving them when i received the first list and i guess i'm i'm i don't know if you're referring to the first set of videos that was ever requested or subsequent subpoenas i guess as this refers to that were already saved and i just transferred the already saved documents so we'll get into into more details um but when was the first time you saved respon um security footage relating to ecb in response to subpoena like i said i don't recall the exact year it was the first case between deaf and heard um as a response to subpoenas that we had received from both parties uh and what what was your role in preserving those videos from from that first time until now can you spend on what you mean by preserving sure did uh were were these videos kept securely in the same format that and were you responsible for making sure that they were kept securely and in the same format at ecb yes [Music] how many cameras are there in 2016. um i don't recall the exact number we've since switched out the entire system um and expanded on it um i believe we doubled the cameras um which we currently have 40 44 so i would be speculating but i think it's probably around 2022 or so originally where in 2016 were the cameras positioned uh throughout the common areas and did did ecb take them as a matter of course sort of all day 24 hours a day the recordings were 24 7. the concierge staff periodically does review them just as part of their daily duties but the video footage is recorded onto a dvr um in a back then i believe it was like a 20 day period before it was written over is it correct that you're not represented by an attorney i am not uh did you review any documents or videos before the deposition i did not have you ever communicated mr depp's former attorney mr waldman uh yes and did mr weldman do you know if he drafted a decoration for you 2016 yes is action property management i believe you said this earlier is it the property management company for ecb yes is he understanding that in 2016 deaf owned the top floor penthouses in ecb penthouses one through five yes and are you aware of whether amber kurd was a resident in ecb in 2016. yes how many times have you seen amber heard personally um maybe i mean i would be guessing my best guess would be maybe half a dozen to a dozen times do you remember when those times were like what year um i don't recall the exact year but likely 2016. um so moving to may 21st of 2016 are you aware that officers were called to the penthouse of ecb on that day yes i am aware were you there the day that the officers were called to ecb in may of 2016. i was not at the building when officers were called do you have any firsthand knowledge of of uh why the officers were called on may 21st 2016. firsthand no i do not you see amber at all on may 21st uh not that i recall did you see amber on may 22nd 2016 uh not that i recall did you see amber on may 23rd 2016. um the timeline is 2016. i i don't recall the specifics of those dates specifically can you say can you testify to whether you you saw amber heard it all the week of may 21st 2016 personally uh not i i don't recall the dates now did you personally interact with mr depp at ecb in 2016 no i never did have you seen mr depp on video footage in 2016 yes could please bring up um exhibit three please how would you describe mr jeff's behavior in that video i would describe it as animated and do you have any in the times that you've seen mr depp at ecb did you ever observe mr depp in an animated manner like you saw in the video uh i do recall a video of mr depp in the elevator um i guess in an animated state and was that in 2016 yes and do you have any familiarity with um have you ever seen mr depp appear angry in the times you've seen him at ecb i wouldn't say angry i use the term animated and what does it turn animated mean to you what i saw on the video when were you first mr patterson when were you first contacted for video footage after the may 21st police call to the building i don't recall the exact time frame do you remember who contacted you about the may 2016 video footage who first contacted you uh i do not recall know who selected what copy to preserve and what copies what to preserve uh the attorneys from both sides uh submitted a list of video times and dates to be preserved and do you remember uh what times and dates those were roughly uh i i don't have a time frame now do you have a rough time frame of what what the videos that were preserved what times those covered my reflect recollection is that may 2016 time frame was it after the may 21st incident that time frame yes um and do you know what role mr depp's lawyers played in the selection process the attorneys came to the office here set up a viewing area reviewed video footage took notes based on that review and those dates and times were provided to retrieve the video and save do you remember which attorneys came either their names or who they were that came to review the footage uh i don't recall there's attorneys from both sides that came very close together and i don't recall who who or what side they were on and was all of the footage that they selected preserved yes and were all of those videos that were preserved taken in the ordinary course of ecb's business operations can you rephrase that sure it's it's ordinary is it not for ecb to have these cameras rolling and the videos that were preserved were from those cameras that were rolling in the ordinary course of business yes correct and do you know how many video clips um ecb preserved pursuant to the the requests of from attorneys uh i don't recall the exact number it was whatever was on the subpoena we provided exactly what is on there does the number 87 ring a bill for how many yes uh and do you know where the videos were maintained from 2016 until today they were on a portable drive here in my office at ecb yes and uh how are they maintained it was on a portable hard drive and as far as you know are that is or is that in the same condition that it was in 2016 do my knowledge yes and uh where were the 87 videos preserved on three dvd discs or in some other format so through the subpoenas there the videos were provided to the different teams i vaguely remember cds they weren't stored on cds for purposes here i just have the portable hard drive any more video footage other than those 87 clips that has been preserved no and what happened to any other video footage that was not preserved like i had mentioned earlier the ddr has a capacity of so many days and it rewrites over itself and um just for clarity how did i just want to make it clear how did you decide what may 2016 video to preserve the only videos that were preserved were the ones called out via the subpoena by the various uh law firms or the two law firms and do you know why there's no footage from may 23 2016. i do not and you mentioned that both sides requested preservation of the video footage is that is that right yes correct um is he understanding that the press at some point became interested in getting statements from ecb relating to the may 21st incident yes uh did the press ask ecb or its employees turn for statements yes and uh what's the policy of apm or ecb with respect to press statements about residents the policy is that we do not give statements to press and did amber ever ask you about that yes she did in 2016 uh do you know if rocky pennington and josh drew lived in one of the penthouses at ecb yes and did he ever see rocky with amber yes if we could pull up exhibit four please uh mr patterson does this refresh your recollection about which penthouse uh rocky pennington lived in yes mr mr uh patterson i'd like to go to the video footage now and go through some video footage um let's start with exhibit five please uh in particular around time stamp 18 55 19. okay all right we'll do that so okay okay mr patterson do you recognize this this area yes um and where is it this is the mezzanine vestibule between the building and the garage and do you know if you or someone else at ecb was responsible for pulling this security footage and keeping it at ecb i did pull some video early on however the task was very overwhelming and took away from my daily duties so the task was sent off to an outside party to pull all the videos based on the subpoena list and what was the outside party's name i i don't recall off hand but it was it at was it at the direction of you or acv yes to assist you with time or is that why yes i did not have the time to go through all of the video footage to record it do the ecb video cameras have time and date stamps as a matter of course yes and in your experience are those time and date stamps relatively accurate relatively accurate yes and did you recognize the men in that exhibit can you replay it please sure and while we're waiting for the men um to appear uh how would you describe the the quality of the these videos compared to our new updated cameras um not as clear and can can you be more specific about not clear would you consider these to be grainy i would say this video here in the paused state does appear to be somewhat grainy and does it appear to be just a little bit blurry yes this video as i see it now looks a little blurry did you recognize the men in this video clip yes i do recognize mr depp the first gentleman looks familiar i can't place him at the moment and do you have any reason to believe that that that the date and time stamp are not accurate it does seem consistent with the time stamping of the video so unless it was somehow altered i would say it appears to be accurate and the video camera that you preserved in your office at ecb since 2016 has not been altered is that correct correct let's go to exhibit six please you recognize where this is yes and where is it this is the mezzanine level again vestibule the nail room is directly behind it leading to the elevator vestibule and does that look like it accurately portrays the scene this shot accurately depicts the area correct and do you recognize those men as i previously stated i do recognize uh mr death the other ones i do not and did the date and time stamp look uh accurate yes um if we could please go to exhibit seven okay all right thank you so do hmm rip switch back okay um and do you recognize uh where this is mr patterson uh yes i do okay and does that look like a clip from the surveillance video in the elevator at ecb yes and does it accurately portray the scene when i i don't know what you mean by scene does it look like ecb like the elevator at ecb yes and is this is the quality of this a little bit grainy as well as it's displayed right now yes um and do the time the date and time stamps look accurate like ecb keeps in the regular course of business yes and um could we please play the video so we can see who's getting on and you recognize those people getting on the elevator mr patterson yes i do recognize mr deb and uh is smoking permitted on elevators at ecb no it's not let's move to exhibit eight please do you recognize this this uh as ecb video footage yes and you recognize the minute on the elevator as i previously mentioned uh mr dad told me and um do those dayton time stamps look accurate yes how would you describe mr depp's movements on this elevator i'll use the description animated again is he also swaying from side to side does this footage generally look like the footage that that you preserved from 2016 yes let's move okay okay and you recognize this area yes what is what what is it uh this is the same shot that was previously shown the mezzanine vestibule and is it shot from one of the ecb surveillance cameras yes and does this look like one of the ones that was preserved since 2016 yes um and did the dayton time stamps look accurate as far as you know yes um and were you responsible for pulling this security footage generally generally yes and do you recognize the people in that video excuse me i do recognize mr deb and what's mr depp holding appears to be a jacket and how would you describe how he's holding it with his left hand and if we could please move to exhibit 11. and do you recognize this is ecb surveillance footage yes and where was that put it taken uh this is back in the mezzanine vestibule between the building and the garage say the last part just to be aware between the building and the garage and was just one of the videos that was preserved since 2016 by ecb i don't recall this specific clip but yes this this is video that was preserved and did the date and time stamps look accurate like they would be on ecb footage actually do you recognize those people uh i reckon i recognize mr dab and does mr depp appear to be leaving the building that would be the pathway from the building into the garage and does this look like true and accurate footage from the ecb video surveillance preserve since 2016 yes moving right along to exhibit 12 please and where is this video mr patterson uh this video is the call box at the lobby entrance on broadway and do you recognize that as security footage from one of the ecb uh surveillance cameras that's been preserved since 2016. yes and the date and time stamp looks accurate to you yes and move to exhibit 13 please and you reckon so uh where this is yes where uh this is in the main lobby of the building and does that look like a surveillance clip from one of the ecb surveillance cameras that's been preserved since 2016 yes and uh it says may 21st 2016 at 20 53 does that look like an accurate date and time stamp from the ecb footage yes and that looks like a true and accurate copy of the surveillance has been preserved yes moving to exhibit 14 please um you recognize this clip yes and does it look like it's from one of ecb security footage cameras that's been preserved since 2016. yes and where was this footage taken this is the shot of the front desk and would you agree that the footage is also a little bit grainy as it is displayed now yes um and do the date and time stamps look accurate um to you yes and do you recognize this as uh surveillance footage from one of the ecb cameras that's been preserved since 2016. yes do you recognize either of the officers i recognize them as officers and does the date and time stamp look accurate as far as you know yes move to exhibit 16 please does this also appear to be a um ecb surveillance camera footage yes and you recognize the per that person who just left the elevator i do not um and does this generally appear to be one of the ones that have been preserved since 2016 at ecb yes and as far as you know does the date and time stamp book accurate yes and for all of these clips that you've seen they look like do they appear to you to be true and accurate copies of the footage that have been preserved these seem very grainy and slow to me from what i remember but this these are taken from eastern columbia video cameras during this time and preserved since that time at ecb correct and they were preserved in the same condition yes can we please pull up at 17. and you recognize this as a clip from one of the ecb surveillance cameras that's been preserved since 2016. yes and as far as you know as the date and time stand accurate yes and does that accurately portray the the elevator scenes at ecb yes um and can we move to exhibit 18 please but do you recognize this is ecb security footage that's been preserved at east b since 2016. yes and it looks like an accurate copy of what was preserved as far as you know as far as i know yes and the dayton timestamp as far as you know look accurate yes please move to exhibit 19. and mr patterson do you know whether or not any of these uh time stamps are a few seconds off here or there or not i believe there is a few second time discrepancy and you know what do you know why there would be a few second time discrepancy or i don't know the reason behind it now okay um and um did you recognize that video clip as one of the videos that has been preserved at ecb since 2016 yes and and does that appear to be an accurate copy of one of the surveillance copies that have been preserved yes and as far as you know that the date and time stamp is is reasonably accurate you know with a couple seconds uh margin yes when please move to exhibit 20. and you recognize this as one of the videos that have been uh taken at ecb one to buy a surveillance camera and ecb yes and is the are these one of the videos that have been preserved by ecb since 2016 yes and as far as you know within a few seconds is the date and time stamp accurate as far as i know yes and does appear to be two officers leaving the leaving ecb yes and move to exhibit 21 please do you recognize where this is yes and what does it look like to you uh this is the same shot from the kiosk camera outside of the lobby on broadway is it shot from one of the surveillance cameras at ecb yes and does that appear to be one of the clips that's that uh has been preserved by ecb since 2016 yes and as far as you know is the date and time stamp accurate as far as you know yes exhibit 22. can we move to that please and does this appear to be uh this clip appear to be taken to one of the ecb security cameras yes and which camera uh this is the lobby look one of the lobby cameras and does this appear to be one of the clips that was preserved at ecb since 2016. yes and as far as you know is the date and time stamp accurate yes within a few seconds and were those two officers walking in in this video yes those appear to be two officers or does this look like how the lobby does it's a look like um how the lobby looks in the videos surveillance preserved by acv yes let's move to exhibit 23 do you recognize this uh as video footage taken from one of the ecb security cameras yes and does this appear to be one of the clips that's been preserved by ecb uh since 2016 yes uh and as far as you know are the date and time stamps accurate within a few seconds yes and do those appear to be officers talking to the concierge yes and move to exhibit 24 please and you recognize this as video footage taken by one of the ecb security cameras yes and was this one of the clips that were taken taken by ecb and preserved since 2016 yes um and uh as far as you know within a few seconds or the date and time stamped accurate yes can we please go to exhibit 27 and do you recognize this um was one of the videos from the ecb security footage that have been preserved since 2016 by ecb yes as far as you know as the date and time stamp accurate within a few seconds false for experts uh and move to 28 exhibit 28 please do you recognize this video as one of the ecb surveillance videos yes uh and which which which surveillance video which which part of the building uh this is the lobby okay does this appear to be one of the clips that has been taken and preserved by ecb since 2016. yes as far as you know are the date and time stamps accurate within a few seconds yes and do those look like two officers in the lobby to you yes move to 29. and you recognize this video is taken from one of the ecb security cameras yes and was this one of the clips uh that have been taken and preserved by ecb since 2016 yes um and as far as you know is the date and time stamp accurate within a few seconds yes i mean this appears to be an accurate copy of what was preserved yes and move to exhibit 30 please and you recognize this as footage taken from one of the ecb security cameras yes and it does appear to be one of the clips that has been taken and preserved by ecb since 2016. yes um and that appears to be an accurate copy of what was preserved yes and as far as you know is the date and time stamp accurate within a few seconds yes may we please go to exhibit 30. and do you recognize this as one of the video clips from ecb video surveillance uh yes and is this the elevator camera one up yes and do you recognize who's on the elevator uh it appears to be amber and does this look like one of the video uh clips that have been taken and preserved by ecb since 2016. yes and as far as you know within a few seconds is the date and time stamp accurate yes can we please move to exhibit 30. thirty-one and does this appear to be one of the video clips taken from the ecb security footage yes um and does this appear to be one of the clips that was taken and preserved by ecb since 2016 yes and as far as you know are the date and time stamps accurate within a few seconds yes and while we're waiting for someone to appear do you recognize the person at the front desk if you can see him and do you recognize who's walking into the video now i do recognize that as amber right trying to get a face a facial uh recognition of the person of the desk can you see him now yes and who's that his name is cornelius do you know why mr harold and amber would be going around that corner uh the package room is around the corner um and does this look like one of the video clips that's been preserved and taken by ecb since 2016 yes and does the date and time stamp uh look accurate as within a few seconds as far as you know yes and does this look an accurate clip um from the ecb footage yes um i'd like to move this uh in as exhibit 31 and move to exhibit 32 please and do you recognize uh who's walking through the picture in this video yes who is it amber heard and does this look like a video clip taken from one of the ecb surveillance cameras yes and does this look like one of the videos that was taken and preserved by ecb since 2016 yes and as far as you know are the date and time stamps accurate within a few seconds yes um i'd like to move to exhibit 33 please and does this look like uh video footage taken from one of the ecb surveillance cameras yes and does this look does this look like one of the clips taken and preserved by ecb since 2016 yes and as far as you know are the date and time stamps accurate within a few seconds yes i'd like to move to admit this as exhibit 33 and do you recognize who's in this video right now yes who is it amber heard and where is she this is the service corridor outside of the packaging okay and if we could please rewind the tape a little bit and see who amber was with do you recognize that person yes that's cornelius and what's his last name howard and was he walking out where was he where was he walking out from the package room where is this an ecb this is on the main level service corridor and would you agree with me that this footage is also a little bit grainy yes if you could please i'd like to move to admit exhibit 33. and if we could please move to exhibit 34. and you recognize this as one of the ecb security camera footage clips yes and this appear to be one of the video footage clips taken and preserved by ecb since 2016. yes as far as you know is the date and time stamp accurate within a few seconds yes and you recognize who's in this video it appears to be amber heard uh and do you know where this video is can you expand on that sure is it an elevator an ecb um and can we go back to that exhibit please just for a minute and can we go to roughly time stamp 18 22 22-26 would you agree with me that the video footage here is a little bit grainy yes and does it look a little bit fuzzy to you yes and can we please move to exhibit 35 and does this look like uh video footage from one of the ecb security cameras yes and does this appear to be one of the clips that was taken to preserve by ecb since 2016 yes and as far as you know did the time stamps look accurate within a few seconds yes if we could please move to timestamp see 1841 29 and do you recognize who just walked in the elevator uh it appears to be amber i'm not sure who the gentleman is does that video appear a little bit grainy to you as it's displayed now um and if we could please move to exhibit i think we're on 36 and is it does this appear to be footage from one of the security cameras at ecb yes and who who just walked through the footage uh amber herb and a gentleman and does this appear to be one of the clips that was taken and preserved by ecb since 2016. yes as far as you know uh is the date stamp and time reasonably accurate within a few seconds yes and would you agree with me that also is a little bit grainy in that footage yes as it's displayed now um and if we could please move to exhibit 37 and does this appear to be a video camera from one of ecb's video cameras yes and does this appear to be one of the clips that was taken observed by ecb since uh 2016 yes and as far as you know is the date and time stamp accurate within a few seconds yes and did you recognize who walked through that video amber hurt and uh unknown gentleman and is this video also a little bit grainy as it appears as it appears now yes i'd like to move in exhibit 37 and please move to exhibit 38 and this this appear to be video taken from one of security cameras at ecb yes and does this appear to be one of the clips that was taken and preserved by ecb since 2016 yes and as far as you know is a date and time stamp accurate within a reason within a few seconds yes uh and if we could let's see go to 2256 please a time stamp wise and you recognize who who's getting on the elevator i cannot see her face but it appears to be amber heard um now move to admit this is 38 and then we can move to uh 39 fees does this look like a true and accurate copy of or surveillance footage from one of the ecb cameras yes and does this look like one of the clips that was taken and preserved in 2016 by ecb yes and when i say by ecb i i mean either you or someone under your direction like the contractor you spoke of is that your understanding yes um and i'd like to move this in as exhibit 38 i'm sorry 39 please um and if and do you know who is working behind the desk in this video yes and who's that uh alex romero okay can we move to exhibit 40 please and does this appear to be a video from one of the ecb security cameras yes and does this appear to be one of the clips that was taken and preserved by ecb since 2016. yes and as far as you know is the date and time stamp accurate within a few seconds yes i'd like to move this in as exhibit 40 please um and if we could go to timestamp 21 1733 please and if we could move oh yeah thanks and you recognize who's getting on the elevator yes and who is it uh amber rocky and her sister whitney and um would you agree with me that the video footage is a little bit grainy in this that yeah it says this displayed at the moment um and does that date and time stamp look accurate within a few seconds as far as you know yes and does that appear to be one of the clips that was taken and preserved by acb since 2016 yes i'd like to move to admit that it's exhibit 40 please uh and move to uh 41 please all right council could you pause it for a moment let's just go ahead and all right ladies and gentlemen let's go ahead and take a 15-minute break till 4 o'clock okay all right thank you great all right we'll come back at four o'clock then okay all right ready for the jury then okay we're ready so so uh do so all right wow all right you may continue thank you and it does also look like one of the clips taken from one of the ecb security cam cameras yes and does this appear to be one of the clips that was taken and preserved by ecb since 2016. yes and would you agree with me that the quality is also grainy as it appears in this video actually as far as you know is the date and time stamp look accurate uh within a few seconds yes and you recognize the people in this video yes and who are they amber rocky and whitney and move to 42. and does this appear to be one of the video cameras from ecb security footage yes uh does this appear to be one of the videos taken and preserved by ecb since 2016 yes and as far as you know is the date and time stamp uh accurate within a few seconds yes and if we could please see go to 11 32 and 11 35. uh do you recognize this as a clip from 2016 uh one of the ones that was taken and preserved by by ecb yes and as far as you know the date and time stamp is it accurate within a few seconds yes uh move to admit this is exhibit 42 please and move to and let's move to exhibit sorry 42 and move to exhibit 43 please does this look like footage from one of the ecb security cameras yes and does this appear to be one of the clips that was taken and preserved by ecb from uh to since 2016 yes as far as you know is the date and time stamp accurate within a few seconds yes and can you tell me where this is or do you remember where that was in the building that is the mezzanine vestibule between the building and the garage i mean if we could move to exhibit 44 please um and does this look like one of the videos taken from one of the ecb security cameras yes um does this look like one of the clips that was taken and preserved by ecb since 2016 yes uh and as far as you know is the date and time stand back within a few seconds and do you recognize who's in the photo i mean who's in the video uh it appears to be amber and trinity esparza trinity what trinity esparza can you rewind that footage please um and this mis does does uh amber heard have a sister yes do you know if that's amber heard sister versus amber heard could you tell uh in this video uh not 100 now um and would you agree that the videos is also a little bit fuzzy in this clip as it appears now yeah it's uh grainy um does this look like an accurate tip um taken and preserved by ecb since 2016. yes and if we could please move to exhibit 46 as far as you know did uh ecb preserve all the footage that mr depp's attorneys or and ambassador attorneys asked you to preserve yes and did you from your understanding do you understand that the attorneys uh some attorneys came and actually were involved in the selection process of videos ecb in may of 2016 yes um and moving to this exhibit uh 45 does this appear to be a video clip from a from one of the elevator surveillance cameras to be yes and does this appear to be one of the clips that was taken and preserved by acb since 2016 yes and as far as you know is the date and time stamps accurate within a few seconds yes um and i'd like to move to admit this is exhibit uh 45 and or 46 um and do you recognize the people in this appears to be amber and rocky and would you agree that the footage is a little bit fuzzy yes as it's displayed now um i'd like to move to admit that it's exhibit 46 and move on to exhibit 47 please and does this appear to be a video clip from one of the ecb security cameras yes and is this appear to be one of the clips taken and preserved by acb since 2016 yes and as far as you know is the time and date stamp accurate within a few seconds yes would you agree that the video footage is a little bit fuzzy in this clip as well yeah it says and this looks like one of the clips that was taken to preserve by ecb since 2016 yes um and as far as you know the date and time stamp look accurate within a few seconds yes i believe we're on exhibit 48 um does this appear to be a clip from one of the ecb video cameras yes and this is appear to be one of exceptions taken and preserved by acv since 2016. yes and as far as you know are the date and time stamps accurate within a few seconds yes and do you recognize the woman who's about to get on the elevator getting on uh which it looks like amber's waiting to get on rocky just came in and whitney's over the corner i don't i don't know the other two um and can you is would you agree that this footage is also a little bit fuzzy yeah it says it's displayed now and that looks like an accurate clip uh from one of the ones that was taken and preserved by ecb since 2016 yes if we could please pull up exhibit 49 mr patterson are you familiar with the layout at the uh penthouse level of eastern columbia building yes and uh this is exhibit 49 that i'm showing you and uh does this look like what you uh understand the layout to be of the penthouse 3 first level does this look to you like what your understanding is of the layout of penthouse 3 the first level yes and if we could scroll down please does that look like the layout of the second level of penthouse 3. yes move to admit exhibit 49 please and click please move to exhibit 50. uh and could we zoom in a little bit please mr patterson do you recognize this as uh the layout of penthouse level uh nothing's labeled um generally i guess does it that look like the pool's in the right spot on that exhibit uh yes and does does from what you can tell does everything else look as you would expect the layout to be in your familiarity with the layout in your experience uh yes generally going back to the video clips and we can walk there's a couple i'm saving to the to the end to see if there's time um uh but for the ones that i've show for the ones that i've showed you um is your understanding that those are all accurate copies of ecb footage that were taken and preserved by ecb since 2015 uh yes um and again by by taken by ecb i mean by you or someone under your direction and the regular course of business is that your understanding yes um and is it correct that that ecb has produced all of video footage that uh had been subpoenaed by attorneys yes that's correct um so to the extent that that footage has not been produced is it fair to say that that footage no longer exists or do you have another explanation can you expand on that please sure um so there's my understanding is that you testify that there's 87 clips that have been preserved is that right yes um and that the date and time stamps are are reasonably accurate to your knowledge on those yes then that there are any missing days or times is it fair to say that that footage no longer exists or is there any other footage that could be produced outside of the videos that were requested um that's correct no everything else would have been written over at this point okay so there's no other videos other than those that have been produced to your knowledge yes correct okay um and i believe you testify that ecb has currently has a new and improved video system is that right am i remembering that correctly yes and back in 2016 uh would you agree with me that the video quality was uh somewhat grainy as i believe that we've talked about in some of the clips yes compared to today's yes um and was was uh was it also a little bit fuzzy in the clips that we've reviewed today yes as they were displayed on the screen um and is it correct that you did not um see amber in person yourself uh may 21st or the several days after i don't recall which day for days she came into the office um but i did see her on those two occasions um outside of that no i didn't see her in person okay um with that last answer you don't recall which days you saw her is that correct i don't remember the specific date of those interactions so would you be able to testify based on your knowledge whether amber is wearing makeup uh the week of the 21st of 2016 not that i recall and if we could please go back um since we have a little bit of extra time and watch the video that we couldn't hear the audio on there's something wrong with it but i believe the audio is fixed so if we could please go back to exhibit three mr patterson i believe you testified when we first saw this video without audio uh that you described mr behave mr jeff's behavior is animated is that right yes after now that the audio is back would you still describe uh mr depp's behavior as animated yeah i think he's still animated but with the audio um i would say upset about something and based on your um the times we've seen mr depp at ecb have you seen him upset about similarly upset uh in the building there was one video of mr depp in the elevator seemed like i said earlier animated with the one you were referring to is that the one where you said mr depp was swaying side to side are you thinking of a different one yes when he was playing side to side you know who mr waldman is yes who is he uh johnny depp's attorney did mr waldman contact you about this case yes what did mr waltman want when he called you um can you click clarify just because um there's been several cases i don't recall which case mr waldman was involved um so i don't believe he's reached out regarding this particular one to my knowledge which are the other cases that you've been contacted by mr weldman about um i don't recall this specific one um but he did reach out to whichever one he was representing at that time um and i believe there's a subpoena that had followed and did you say that mr weldman contacted you in two prior cases i don't recall which case it was in regards to and did you talk to mr waldman on the phone i i don't recall and did you communicate with mr waldman by email yes did mr waldman uh prepare a draft declaration for you yes is it fair to say that you cannot testify one way or another about whether mr depp committed domestic violence against amber i cannot if we could please turn to exhibit nine and does this look like a um video camera from the ecb video footage this is where you want to stop yeah we're just gonna play okay um uh um so yes and does this look like one uh taken and preserved by ecb since 2016 yes and as far as you know is the date and time snake accurate within a few seconds yes could we please take that down and bring up ten and does this look like a video from one of the ecb security cameras yes and does this look like one of the clips that was taken and preserved by acb uh since 2016. yes uh and is the date and time uh within a few seconds look accurate as far as you know yes and then quickly take that down and bring up 16. and does this look like a video clip from one of the ecb security cameras yes and does this look like one of the clips that was taken and preserved by ecb since 2016 yes and as far as you know is the date and time stamp accurate within a few seconds yes and we could take this down and bring up 17 please uh does this look like one of the video clips from the ecb security cameras yes and does this look like look one of the clips that was taken and preserved uh by ecb from 2016 yes and as far as you know is the date and time stamp accurate within a few seconds yes could please take it down and bring up 18. [Music] does this look like a video clip from one of the ecb security cameras yes and does this look like one of the clips that was taken and preserved by acv from 2016. yes uh and as far as you know is the date and time stamp accurate within a few seconds yes could please take it down and bring up 25. and does this look like a security uh camera footage from one of the ecb security cameras yes and does this look like one of the clips that was taken and preserved by ecb since 2016 yes and as far as you know are the date and time stamps accurate within a few seconds yes if we could pull up 26. shhh and does this look like a video from one of the ecb security cameras yes and does this look like one of the clips that was taken observed by ecb since 2016 yes and as far as you know uh is the date and time accurate within a few seconds yes and just to confirm that is your signature at the end of this document is that correct yes that's correct did anyone assist you in drafting this declaration uh yes and who was that person uh mr waldman and did mr waldman's assistance in drafting your declaration have any influence or effect on the truthfulness of your statements in your declaration is this a true and accurate copy of your first witness statement submitted in the uk action yes it appears to be mr patterson the statements contained in this first witness statement are they truthful yes anything that i would have put on here and signed would have been truthful did mr depp ever offer you any money no he did not between may 21st 2016 which i'll represent to you was a saturday and may 27 2016 which i will represent to you was a friday did you work on site at the eastern columbia building i don't recall if i was there those days i'm typically there monday through friday but i do not recall if i was there those days sitting here today do you have any recollection of interacting in person with miss heard at any point between may 21 2016 and may 27 2016. as i had previously mentioned i i don't recall specific dates of when this heard stopped by the office um i i don't know how this specific debates alejandra romero was another person that spoke to you about his interactions with miss heard that i don't i'm not a hundred percent i i don't recall exactly was cornelius harold one of the people that spoke to you about his interactions with miss heard i also don't recall a specific interaction for me list do you recall when mrs sparza first came to you about her observations of ms heard i don't recall a specific interaction i have a recollection of uh i guess trying to be stopping by um but i don't i don't remember the exact uh interaction are the statements contained in paragraphs 15 through 18. truthful as i review it yes that is my recollection of the occurrences what footage do you recall miss esparza showing you i recall this esparza showing me video of the mezzanine level uh where the multi-colored area rug is of amber with her sister and rocky and one of them what i remember fake punched amber in the face in which they all started laughing and then they walked off screen you recall the date of that surveillance footage video that you just described i do not do you recall whether it occurred after may 21 2016 i don't recall patterson does this after reviewing paragraph seven of your declaration that you signed under the penalty of perjury does this refresh your recollection as to whether or not you observe the surveillance footage sometime around may 24th 2016. yes okay let's let's go through the first interaction that you remember with miss heard can you tell me what you remember about that interaction so i amra came in shook her hand um and she told me the situation where she needed to have me make a statement to her sources at people magazine did ms hurt explain to you why she wanted you to speak to her source at people magazine i don't remember the exact i don't recall the exact uh ask it was something to do with her getting ridiculed in the eye of the public opinion or something like that please have exhibit three pulled up and for the record it's bait stamped depth 3628 so mr patterson does this video clip represent a accurate copy of one of the original clips that was produced in response to a subpoena in this in 2016. yes and was this clip recorded and kept in the regular course of business for eastern columbia management i misspoke let me rephrase was this clip recorded and kept in the regular course of business for eastern columbia building um can you expand on that yeah let me rephrase it um this is surveillance footage this is a clip of surveillance footage that was recorded for business purposes at ecb yes yes that is correct okay and it was kept or preserved by ecb right yes that is correct do you know the which camera uh this particular clip was showing footage from we can perhaps replay it because i believe it might indicate that uh yeah we can pull it up again do you know which camera this is showing uh footage from uh so this would have been the penthouse elevator and if we could please pull up exhibit four so do so does this video clip represent a true and accurate copy of one of the original clips that was produced in in response to subpoena in 2016 it appears to be there's nothing going on right now but yes and which camera is this showing footage from uh this is also the penthouse elevator if i could please have exhibit five pulled up so uh and for the record that's bait stamped depth 3641 so so and does this video clip represent a true and accurate copy of one of the original clips that was produced in just in 2016 uh yes it appears to be do you know which camera this is showing footage from this would also be the penthouse elevator and what is the date of this footage may 21st 2016. okay if you could please pull up exhibit six bait stamped depth 3648 does this video clip represent a true and accurate copy of one of the original clips that you produced in 2016 uh it appears to appear so i don't recall this exact time of the split but yes it it does appear stuff and is it uh what is the date on this video clip may 21st 2016. and which camera is this showing footage from um if they can wait for the doors to open so uh so this is also the penthouse elevator mr patterson i will show you next a video clip that's been bait stamped depp 3610 patterson exhibit 7. does this video clip present a true inaccurate copy of one of the original clips that was produced in 2016. uh yes it appears to be so do you know which camera this is showing footage from this is the front desk camera in the lobby next can we please have exhibit eight pulled up which for the record is dep3620 mr patterson does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016 yes it appears to be some do you recognize who the person is that entered the elevator at 22.56 it appears to be amber heard i please have exhibit nine pulled up so uh does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016 yes it appears to be so do you know which camera this is showing footage from uh this is also the penthouse salary can i please have exhibit 10 hold up uh and for the record this is bait stamped depth 3607. does this appear to be video clip of a true and accurate copy of one of the original clips that was produced in 2016. uh yes it appears to be son and do you know which camera this is showing footage from this is also the penthouse elevator and what date is depicted may 25th 2016. next can i have please exhibit 12 which for the record is fade stamp depth 3572 does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016. hmm uh yes it appears to be some and do you know which camera this is showing footage from this is the front desk lobby camera and what is the date of this video clip may 25th 2016. and if we could please go to really if i could ask for your help 13.45 i'm going to mark this exhibit as patterson exhibit 12. do you recognize the woman at the desk walking to the desk yes it looks like amber heard is approaching trinity as far as i'm working at the desk can i have exhibit 13 pulled up please and for the record it's bait stamped depth three five eight three so up does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016 yes it appears to be so and do you know which camera this is showing footage from this would also be the penthouse elevator and what is the date of this video clip may 25th 2016. do you recognize the woman in the black shirt just outside the elevator uh yes amber hurt so is this one of the video clips that represents true and accurate copy of the original clips that was produced in 2016 uh yes it appears to be so and what is the date of this video clip may 25th 2016. what camera angle or excuse me what camera is this showing footage footage from uh this is the mezzanine camera between the building and the parking garage is that camera four according to the stamp yes thank you if you could please mark that as exhibit 14 turning to patterson exhibit 15 bait stamped depth 3569 does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016. uh yes it appears to be that and uh what is the date of this video may 25th 2016. and which cameras is showing footage from uh this is camera seven lobby camera and does this video clip represent through an accurate copy of one of the original clips that was produced in 2016 uh yes it appears to be some and what is the date of this video may 24 2016. and uh what camera is this showing footage from this is camera number six which is the kiosk camera outside on broadway thank you can we please mark this security clip as patterson exhibit 16. next can i please have patterson exhibit 17 depp 3594 does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016 uh yes it appears to be some and what cameras is showing footage from uh this is camera number eight um broadway outside of the permanent building what is the date of this video may 24 2016. thank you we could please mark this security clip that's patterson exhibit 17 almost done turning to video clip that has been bait stamp depth 3609 patterson exhibit 18. does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016. uh yes it appears to lisa and do you know which camera this is showing footage from this is camera 4 which is the service hallway and what date is depicted in the security clip may 22nd 2016. thank you can we please mark this video clip as patterson exhibit 18. next patterson exhibit 19 depth 3611. does this video clip represent a true accurate copy of one of the original clips that was produced in 2016. yes it appears to be so and uh what camera is this showing footage from this is camera 13 mezzanine level and what is the date on this video clip uh may 22nd 2016. thank you can we please mark the security clip as patterson exhibit 19. turning to patterson exhibit 20 which for the record is vape stamped depth three six one two this is one of the video clips that represents a true and correct copy of one of the original clips that was produced in 2016. uh yes it appears to be son and what camera is this showing footage from uh this is the garage camera number two and what is the date of this video clip may 22nd 2016. thank you can we please mark the security clip as patterson exhibit 20. and do you know what camera this is showing footage from this is parking garage camera number 14. and what is the date on this video clip may 22nd 2016. thank you can we please mark the security clip as patterson exhibit 21. mitch patterson i believe you previously testified for council informed you that there were 87 video clips that were produced in response to a subpoena in 2016. do you recall that testimony yes and all 87 video clips the best of your recollection as the person most knowledgeable for um property excuse me action property management were those 87 video clips recorded and kept or preserved in the regular course of business for eastern columbia building yes and were those clips collected preserved and produced near the time of the actual events recorded in the clips uh yes it would have been within that 20 to 30 day timeline right and it was the regular practice of the eastern columbia building to record security footage similar to what is reflected in these clips that you've been shown today correct yes that's correct mr patterson i believe uh you testified earlier that you commented on revisions to mr weldman's draft declaration is that right yes that's correct and i would like you to read please the comment uh the third comment down which says was this footage found i'm i'm not certain of the date or time i also do not recall who she was with but it was two females i do not recall who threw the pretend punch i also do not recall if if she had any signs of injury during this time however i do recall one of the females pretending to punch amber in the face now did you write this comment uh do you remember it i do recall vaguely and this this this footage never was found is that correct the footage was never requested by whom any of the attorneys so the footage if it was is it your testimony that that this exists this footage exists or not it would no longer exist and it would no longer exist and it was never produced as one of the 87 clips is that right that is correct and i believe you testified earlier that attorneys for both sides selected times and looked through video and made selections of what to preserve is that is that was that your testimony yes that's correct but nobody selected that footage to your knowledge not to my knowledge now and it was never produced that's my knowledge now um and is it correct that uh that you do not recall at that time whether amber had any signs of injury at this moment no i do not recall and according to that comment you did not recall at that time is that your understanding i don't recall and you don't know the date or the time of that footage don't recall and obviously i could read this but i don't recall offhand and you didn't recall at the time either is that right that's correct all right that completes testimony correct all right ladies and gentlemen thank you for your extra time tonight i just wanted to get through that witness tonight so we can start with a new witness tomorrow okay so have a good evening again don't do any outside research don't talk to anybody about the case probably stay off social media i would appreciate it okay and we'll see in the morning at 10 am okay all right okay well i know six weeks sounds like a lot of time but um it's only 24 days and we've already done three days so you have 21 days left you know stipulations is one of my favorite words so you might want to consider looking back through all the evidence that you have and stipulate on a lot of information because i promised the story would be done by memorial day weekend and we will be done by memorial day weekend so when your time is up your time is up my law clerk sammy is tracking everybody's time who's how much time has been used by each side so you'll keep doing that throughout the trial and we'll let you know on a weekly basis how it's going but if things don't speed up in the deposition you're just not going to get through this so i want you to keep that in mind okay all right um any remote witnesses tomorrow do if we need to set that up no more okay all right great thank you have a good evening we'll see you at 10 o'clock okay [Music] do do do do do do do do do do youWatch at: 00:20 / 00:40Watch at: 00:40 / 01:00Watch at: 01:00 / 01:20Watch at: 01:20 / 01:40Watch at: 01:40 / 02:00Watch at: 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