TRANSCRIPT OF THE POOL TV FEED FROM DEPP v HEARD

FAIRFAX COUNTY COURT Tuesday 12 April 2022

PROFESSIONALLY TRANSCRIBED. THIS IS NOT AN OFFICIAL
COURT TRANSCRIPT AND SHOULD ONLY BE USED FOR
GUIDANCE.

Bailiff: Court is now in session. The Honorable Penney Azcarate is

presiding. Please be seated, everyone.
Judge Azcarate: Good morning, Judy. Can you hear everything okay
today? Okay, good. All right, good morning. All right. Do we have any
preliminary matters before the jury comes out?
Mr. Chew: Yes, Your Honor. We would just ask Your Honor to please
publish our very demonstrative exhibit.
Judge Azcarate: All right. There's no objection to that? People have
changed places here, I just want to make sure I look at the right place.
Okay, we're good.
Mr. Chew: It's a blank screen right now, so we would ask to publish it
now.
Judge Azcarate: Okay. I'm assuming it's...
Mr. Chew: We tried it out beforehand, it seemed to work.
Judge Azcarate: If it's a blank screen, it's hard to see if it's working or
not.
Mr. Chew: Understood.
Judge Azcarate: It is published.
Mr. Chew: Thank you, Your Honor.
Judge Azcarate: But it's just a blank screen, I guess. Okay. We're going
to hope that's it, then. All right. Thank you. Anything other else we have?
All right, ready for the jury?
Mr. Chew: Yes, Your Honor.
Judge Azcarate: Okay, great. All right. Good morning, ladies and
gentlemen. If I can have you move your water down by your chair, just
not have anything there. If we get electronics and we mess up the

Transcription by www.speechpad.com Page 1 of 115

electronics, I get in trouble. So, thank you. I hope you like the seat that
you're in. I'd like you to stay in that seat for the duration. I'd appreciate it.
I hope you had a good evening. All right. Thank you, and thank you for
being punctual today. I appreciate it. You can have a seat.
All right. Are we ready with opening statements?
Mr. Chew: Yes, Your Honor.
Judge Azcarate: All right. Go ahead, sir.
Mr. Chew: Good morning. My name is Ben Chew. My colleagues and I
from Brown Rudnick are truly honored to represent the plaintiff in this
case, Johnny Depp.
Some of you may recognize Mr. Depp from seeing him portray
characters such as Edward Scissorhands or Captain Jack Sparrow from
the "Pirates of the Caribbean" movies. For nearly 30 years, Mr. Depp
built a reputation as one of the most talented actors in Hollywood, a
respected artist whose name was associated with success at the box
office. Today, his name is associated with a lie, a false statement uttered
by his former wife, the defendant, Amber Heard, that falsely cast Mr.
Depp, falsely and unfairly characterized, cast Mr. Depp as a villain, a
man who would violently abuse a woman.
This is a defamation case. It's a case about how devastating words can
be when they are false and uttered publicly. Under the law, a person
who makes a false statement about someone else can be held
responsible for the harm that results from that falsehood. That's because
words matter. They paint a picture in our mind based on what we have
experienced and what we know or what we think we know. And because
of that, words can evoke strong emotions in the listener and cause
irreparable harm to a person's reputation. And when, like Mr. Depp, your
career depends upon your image and your reputation or whether movie
producers want their films associated with you, that harm can be
particularly devastating.
This is a case about the impact of Amber Heard's words on Johnny
Depp, specifically, the words that she used in an op-ed published in "The
Washington Post" in December 2018, which is shown on the screens.
And the op-ed was published, and this is no accident, the evidence will
show, on the eve of her first major acting role in the movie "Aquaman."
The evidence will show, that's no coincidence. The evidence will show
the words that Ms. Heard used, which are the subject of Mr. Depp's
defamation suit against her. And there are three statements that we
respectfully ask each of you to focus on.

Transcription by www.speechpad.com Page 2 of 115

Statement number one, "I spoke up against sexual violence and faced
our culture's wrath." Statement number two, "Two years ago, I became a
public figure representing domestic abuse." And I want to repeat that
because you're going to hear that throughout the case, because the
timing here is critical. "Two years ago, I became a public figure
representing domestic abuse." Statement number three, "I had the rare
vantage point of seeing, in real time, how institutions protect men
accused of abuse."
Ms. Heard did not use Mr. Depp's name in the op-ed. She didn't have to.
She didn't have to because the evidence will show that everyone in
Hollywood, where Mr. Depp and Ms. Heard both have their careers, and
many others outside Hollywood knew exactly what she was talking
about when she used the word, "Two years ago, I became a public
figure representing domestic abuse." That's because, as the evidence
will show and you will hear, 2 years earlier, on May 27th, 2016, Ms.
Heard had publicly accused Johnny Depp, her husband at the time, of
domestic abuse.
You will learn during the trial that Ms. Heard's actions were prompted by
Mr. Depp's request for a divorce. He wanted out, which drove her to
concoct, to make up a story that was, at first, designed to keep him and
then, when he made it clear that, finally, after all he had endured, he was
done, was designed to recast herself as an abuse survivor, with Mr.
Depp as the alleged abuser. The evidence will show that six days after
Mr. Depp requested a divorce, and he did so politely, and three days
after Ms. Heard's lawyer threatened Mr. Depp with claims of abuse if he
did not agree to her financial demands, Ms. Heard arrived at the
courthouse in Los Angeles, California to file for a restraining order
alleging abuse.
Ms. Heard, the evidence will show that Ms. Heard showed up with a
mark on her face that mysteriously appeared six days after she last saw
Mr. Depp and six days before she publicly filed a request for domestic
violence restraining order alleging abuse. The evidence will show that
her publicist and the paparazzi were there at the courthouse to
document the event to make sure that Johnny Depp's name was forever
associated with the image of an innocent battered woman. It was a jolt.
It was a shocking story, splashed across front pages across the country.
No one had ever, in five decades, accused Johnny Depp of being violent
with a woman. No one had ever accused Mr. Depp of being violent with
a woman. He had been in other long-term relationships. He had
children.

Transcription by www.speechpad.com Page 3 of 115

Ms. Bredehoft: Objection, Your Honor. May we approach?
Mr. Chew: No one, as I stated before, no one had ever, in five decades,
no one had ever accused Johnny Depp of being abusive of any kind with
a woman. That's why it was such a jolt. He had been in other long-term
relationships, as I said. He had two children. And no one had even
suggested ever that he was capable of something like this.
By choosing to lie about her husband for her own personal benefit,
Amber Heard forever changed Mr. Depp's life and reputation, and you
will hear him tell you the dreadful impact that it has had on his life. The
evidence you will hear at this trial contradicts the story Ms. Heard
presented to the world in May 2016, and again in December 2018. The
evidence will show that the last time Mr. Depp and Ms. Heard saw each
other, before Ms. Heard showed up in court on May 27th, 2016, was
May 21st, and that's a very important date, and I will ask you, please, to
remember that through the trial. Mr. Depp's mother, Betty Sue, passed
away on May 20th, after a long illness, when Johnny and his sister,
Christi, had been taking care of his mother for a very long period of time.
And for reasons that Mr. Depp will personally explain to you throughout
the course of this trial, he had resolved to divorce Ms. Heard.
So, on May 21st, Mr. Depp came by the apartment that he shared with
Ms. Heard in the Eastern Columbia Building or the ECB, as some
people refer to it, to tell her that, to pick up his things, and to say
goodbye. There is no dispute that, soon after Mr. Depp ended things
with Ms. Heard and left the apartment on May 21st, he got on a plane to
head out on a European tour, a music tour, for months, with his band,
The Hollywood Vampires. And Ms. Heard knew that he was going off on
tour and out of state when she walked into court to get the restraining
order, which she obtained ex parte. It's a Latin word, fancy word, but all
it means is that Mr. Depp and his lawyer were not there and had no
opportunity to be heard. That's what an ex parte order is.
You will hear from the police officers who responded to a 911 call on
May 21st after Mr. Depp left. The police officers will testify that they saw
no injuries on Ms. Heard. Both police officers will testify that they saw no
injuries on Ms. Heard, nor did the police officers see any of the property
damages that you will hear Ms. Heard claims existed in the apartments
that evening. And you will hear those officers, under oath, testify that
there was no violence and that there was no crime. You will also hear
from multiple witnesses who, like the police officers, saw Ms. Heard
between May 21 and May 26. Those are the crucial days between the
alleged incident and the day she walked into court with her lawyer and

Transcription by www.speechpad.com Page 4 of 115

got an ex parte order. And those witnesses will testify that they saw her
without any marks, any signs of injuries on her face. And you will hear
from multiple witnesses, including Brandon Patterson, who is the
manager of the Eastern Columbia Building, where Mr. Depp and Ms.
Heard live together. You will hear Mr. Patterson say that he saw...and
others will say as well, that they saw a surveillance video from the week
of May 21st that showed Ms. Heard's sister, Whitney, throw a fake punch
at Ms. Heard's face.
Let's just stop there. This is the surveillance video you will hear about
where the sister of the alleged victim threw a fake punch at her sister,
allegedly, which allegedly occurred, this incident, only a couple of days
earlier, Ms. Heard acting out being punched, responding to the fake
punch, and the two laughing about it. So you have the alleged victim and
the sister laughing about a fake punch. And you will have to decide for
yourself, or we ask that you please decide for yourself, would anyone
ever joke about that if there had been actual abuse, much less, ask
yourself, would a sister ever joke with an alleged victim about being
punched by her husband?
Of course, none of this contradicting evidence was publicly available
when Ms. Heard walked into court on May 27th and got her restraining
order. Instead, as you can imagine, the media storm was instantaneous.
You will hear about and see some of that media coverage, which
published pictures of Ms. Heard walking into court, and other pictures
supposedly showing injuries supposedly caused by Mr. Depp, a man
who had never been accused of abuse of a woman. The evidence will
show that Mr. Depp and Ms. Heard eventually settled their divorce out of
court. Thereafter, Ms. Heard dismissed her restraining order against Mr.
Depp.
But Ms. Heard's false claim that Mr. Depp had abused her remained in
the public sphere. It didn't go away. The images were permanent. And
the evidence will show that, two years later, which is why we're pointing
to that, that reference in the op-ed, in the wake of the #MeToo
movement, and just before the release of Ms. Heard's role in the movie
"Aquaman," Ms. Heard chose to remind the world about the festering
allegations, this time under the banner of a national, international
newspaper, "The Washington Post." In the op-ed, in her op-ed, Ms.
Heard again painted herself as the innocent victim of abuse, but this
time, this time with a wider audience primed to take action against
industry powerhouses accused of abuse.

Transcription by www.speechpad.com Page 5 of 115

The evidence will show that the clear implication in Ms. Heard's op-ed
that you have in front of you was that she was the victim of domestic
abuse perpetrated by Mr. Depp. The evidence will show that that was a
lie, and it remains a lie, when it was repeated and republished two years
later. Hollywood studios don't want to deal with the public backlash from
hiring someone accused of abuse, even someone with the incredible
body of work and record that Mr. Depp can be proud of. A false
allegation can devastate a career. And it can devastate a family. And the
evidence will show that Ms. Heard's false allegations had a significant
impact on Mr. Depp's family and his ability to work in the profession he
loved and loved to bring joy to everyone.
Ultimately, this trial is about clearing Mr. Depp's name of a terrible and
false allegation. We ask you, in the next several weeks, to please,
please, carefully consider the evidence, assess the reliability and
credibility of that evidence, and to make your own determination about
what actually happened between Mr. Depp and Ms. Heard. And to tell
you more about that, I am going to turn it over to my colleague, Camille
Vasquez, who you had the pleasure of meeting yesterday. Thank you all
for your attention.
Judge Azcarate: Ms. Vasquez.
Ms. Vasquez: Your Honor, may I approach?
Judge Azcarate: Sure.
Ms. Vasquez: There we go. [inaudible 00:18:53]. Thank you. Thank you,
Ben. And good morning.
Over the course of this trial, you're going to have an opportunity to get to
know Johnny Depp, not the characters he's portrayed but the man
himself. You will hear from Mr. Depp directly, but you will also hear from
his friends, his family, and employees. You will hear from people who
have known him for decades. They have seen him at his best, and they
have seen him at his worst. And they will tell you, each of them, that he
is a kind soul who has never and would never raise a hand to a woman.
You will hear that Mr. Depp learned at a very young age how to coexist
with an abusive woman.
You will learn from Mr. Depp's sister, Christi, and from Mr. Depp that
their mother, Betty Sue, lived in a constant state of anger that would boil
over daily, in vicious words and violence, directed at her husband and
their children. And you will hear how Mr. Depp, who had the personality
of his father, coped with that abuse in the same way his father did. He
just took it. The evidence will show that Mr. Depp learned that the best

Transcription by www.speechpad.com Page 6 of 115

way to deal with violence was to leave, to get away from it, give her time
to cool down. But he never turned his back on his mother. Mr. Depp
loved his mother, and he cared for her until the day she died.
You will hear how Mr. Depp came to Los Angeles as a teenager. He first
planned to be a musician, then became an actor, and eventually, thanks
to his talent, his dedication, and a lot of hard work, grew into one of the
biggest movie stars in the world. He had relationships with major figures,
in Hollywood and elsewhere, like Winona Ryder, Kate Moss. And before
he met Amber Heard, he was with the same woman, Vanessa Paradis,
for 14 years. He had two children with her. And even though he was a
megastar, they had a quiet, domestic life. In fact, you'll hear, as Mr.
Chew already told you, that in Mr. Depp's 58 years, not a single woman
has ever accused him of violence, and nobody, in Hollywood or the
world, had any reason to believe he was an abuser, until Ms. Heard
publicly accused him in 2016. You're also going to hear evidence about
Ms. Heard. You're going to learn that she's a profoundly troubled person,
who manipulates the people around her just like she manipulated Mr.
Depp.
Ms. Heard came to Los Angeles and sought a career in acting after Mr.
Depp was well established as a movie star. Mr. Depp and Ms. Heard first
met in 2009 on the set of the film "The Rum Diary." There was a
significant age difference between them, and at first, he avoided her
advances. But she pursued him. She wooed him. The evidence will
show that Ms. Heard went to great lengths to win him over by playing
the doting girlfriend. And it worked. He fell head over heels in love with
her. Those who watched this relationship developed saw red flags all
over the place. You will hear from them in this trial. And over time, the
real Ms. Heard began to emerge. She would berate him, scream at him.
He would try to appease her and sometimes, just sometimes, things
would get better. But it would always happen again.
The evidence will show that Mr. Depp started coping with Ms. Heard in
the same way he did as a child. He would try to get away, avoid the
conflict. But his trying to leave enraged Ms. Heard. She would resort to
physical violence, throwing things at him, hitting him. She would tell him
he was a coward. She would tell him he wasn't man enough because he
wouldn't stay and fight with her. You will see that Ms. Heard equated
anger and violence with passion. She would apologize with poetic
excuses as if the violence just proved how fierce and overwhelming her
love for him was. And you're going to hear that, when Ms. Heard got
violent, Mr. Depp would just retreat, just as he did with his mother. He
would try to leave to get away from her. In her words, Ms. Heard's

Transcription by www.speechpad.com Page 7 of 115

words, he would split. Mr. Depp would often retreat into bathrooms, lock
the doors, wait out Ms. Heard's aggression. But his leaving just
provoked her more.
You will hear from Mr. Depp's security people, like Sean Bett, about how
they often had to remove Mr. Depp from scenes with Ms. Heard
screaming at him, chasing him, trying to keep him from leaving. You're
going to hear evidence that, when Mr. Depp and Ms. Heard traveled
together, his team routinely had to book an extra room for him so that he
had somewhere to go when Ms. Heard became enraged. You'll hear
from other witnesses, including Mr. Depp and Ms. Heard's marriage
counselor, her name is Dr. Laurel Anderson, who perceived Ms. Heard
as the aggressor in the relationship, Ms. Heard as the aggressor in the
relationship, the one who would strike Mr. Depp to try to keep him from
leaving. You'll hear from medical professionals who were with Mr. Depp
and Ms. Heard, often on a daily basis, for years, including their doctor,
David Kipper, and Ms. Heard's personal nurse, her personal assigned
nurse, Erin Boerum Falati, who did not see any signs of injuries that Ms.
Heard later testified to in graphic detail.
Ms. Heard wants you to ignore the testimony of these medical
professionals, who saw her in real-time, just as she wants you to ignore
the testimony of the police officers, who testified under oath, who saw
her on May 21st, 2016 without any injuries. But it is up to you, ladies and
gentlemen of this jury, to judge the credibility of these witnesses and that
of Ms. Heard.
In this trial, Ms. Heard will undoubtedly present photos that supposedly
show injuries she sustained as a result of the claimed abuse by Mr.
Depp. Here's what you should keep in mind when you see these
photographs. First, the evidence and expert testimony from forensic
pathologist, a doctor, will show that the injuries reflected in these
photographs are not consistent with the brutal allegations of abuse Ms.
Heard has alleged. Second, there are multiple, multiple witnesses,
including medical professionals and police officers, who will testify that
they did not observe the injuries supposedly reflected in these
photographs. And you may be wondering, "How can that be?" Well, you
will hear expert testimony that none of these photographs are the
originals, not one, and many are stored in an editing program. So they
could have been manipulated and cannot be confirmed as authentic.
Importantly, you will not see a single photograph of the vast majority of
the abuse alleged by Ms. Heard. Not one. And there is not a single
photograph or video showing Mr. Depp becoming physically violent
towards Ms. Heard.

Transcription by www.speechpad.com Page 8 of 115

The only medical report of an injury during their relationship was a
severe one, and it was sustained by Mr. Depp after an argument shortly
after their marriage while the couple was in Australia. You will hear
evidence that the people who cared about Mr. Depp were encouraging
him to have a prenuptial agreement with Ms. Heard, but she rushed the
wedding date, and he agreed to get married without one. After the
wedding, again, people close to Mr. Depp encouraged him to consider a
postnuptial agreement. When the topic came up, Ms. Heard became
outraged, as she always did, at the suggestion that Mr. Depp might
leave her. She berated him, and when he tried to leave, she became
violent. She became so violent, in fact, she threw a vodka bottle at him
that hit his hand and exploded. It severed the end of one of his fingers.
You'll see pictures of Mr. Depp's severed finger and learn about his
emergency medical treatment for that injury.
And then you'll learn, and this is important, years later, after the false
claims of abuse that caused Mr. Depp to file this very lawsuit, Ms. Heard
came up with an elaborate story about what actually happened,
according to her, in Australia. And what she said happened was that it
was a three-day hostage affair, an episode, where she was violently
attacked and then sexually assaulted by Mr. Depp. You will see for
yourself that the evidence does not support the story she told after she
was sued.
You will learn that there came a time when Mr. Depp was done, and
you'll learn from him, and he will tell you why, the evidence will show that
on May 20th, 2016, Mr. Depp's mother, Betty Sue, passed away. You will
hear from Mr. Depp that his mother's passing was a wake-up call that
helped confirm what he already knew, that the relationship with Ms.
Heard wasn't working and that Ms. Heard was not going to change. If
you've ever lost a parent, you understand how much this experience can
change your perspective on what is important for your own well-being.
So Mr. Depp resolved to finally divorce Ms. Heard and told her that very
day that he would do so respectfully and, most importantly, discreetly.
The evidence will show that, on May 21st, 2016, when Mr. Depp went
over to the Eastern Columbia Building to gather his things, Ms. Heard
caused a final dramatic scene. In the wreckage of their relationship, Ms.
Heard spun the final encounter between them into a tale of domestic
abuse.
Now, I understand that many of you may be asking yourselves why. Why
would Ms. Heard say that Mr. Depp abused her during their relationship
if it didn't actually happen? Why would she make up the detailed
dramatic tales of abuse that you will surely hear in this courtroom over

Transcription by www.speechpad.com Page 9 of 115

the coming weeks? By the end of this trial, you will have the answer to
that question. The evidence will show exactly who Ms. Heard is.
You will hear from Mr. Depp and other witnesses, including their
marriage counselor, Dr. Laurel Anderson, that Ms. Heard would go to
great lengths and even resort to physical violence to stop Mr. Depp from
leaving her. But once Mr. Depp did leave, Ms. Heard tried to avoid public
humiliation and present herself as a noble survivor and representative of
the #MeToo movement. You will hear evidence, including the testimony
of Ms. Heard's former personal assistant, Kate James, that Ms. Heard is
obsessed with her public image. It's her number one priority. And you will
see evidence that after she received a $7 million divorce settlement from
Mr. Depp, Ms. Heard released a public statement claiming she wanted
nothing from him and would donate the entire settlement to 2 charities,
the Children's Hospital of Los Angeles in California and the American
Civil Liberties Union, also known as the ACLU. But then, she did not
make the donations.
Quite simply, Ms. Heard had publicly cast herself in the role of a
domestic abuse survivor. There was no going back. When Mr. Depp
finally stood up and fought for his good name in court by filing this
lawsuit, Ms. Heard, because she couldn't back down, went all in. After
this lawsuit was filed, it's important, the timeline here, after this lawsuit
was filed, Ms. Heard started making up more and more alleged incidents
of abuse. And if you'll recall, ladies and gentlemen, the headline of the
op-ed references sexual violence. But Ms. Heard had never made that
accusation against Mr. Depp. It was never part of her allegations of
abuse. So what changed? What changed between 2016 and 2018?
We submit to you, and the evidence will show, when she realized the
seriousness of what she had alleged, she panicked, and she alleged
sexual assault. Ms. Heard and her lawyers are going to tell you some
truly horrific tales of abuse before this trial is over, but the horrific details
are designed. They're designed to shock you and to overwhelm you.
They are designed to be explosive, and they are designed to distract
you from the evidence and, most importantly, from common sense. That
tells you, the common sense and the evidence will tell you, that it is all a
lie, that none of this, not one single alleged incident of abuse, could
have happened as Ms. Heard claims.
Ms. Heard's pattern is consistent. She tells the lies, then covers up that
lie with still more lies, in a constantly changing, evolving, ever more
dramatic story. You're going to hear a lot about Mr. Depp during this trial.
Ms. Heard is going to tell you a lot of things about him, that he abused

Transcription by www.speechpad.com Page 10 of 115

drugs and alcohol, that he used bad and offensive language. And it's
true, that Mr. Depp has had real struggles with substance abuse in his
life. He's not denying that. You may know people close to you who have
struggled too. But struggling with drugs and alcohol doesn't make you
an abuser. He has also used some very colorful language. He uses
words that I don't use and you probably don't use, and he uses them
frequently. Mr. Depp, like all of us, is not perfect, but he did not abuse
Ms. Heard. All of this is just meant to distract you from what this case is
about.
This case is about what Ms. Heard said in her op-ed. The evidence will
show that Ms. Heard painted a picture of herself as a heroic, innocent
survivor of abuse by Mr. Depp, a beaten woman who finally stood up to
her tormentor. The evidence will show that Ms. Heard used her
allegations against Mr. Depp to raise her own profile and to advance her
own career the very same day that the op-ed was published under the
title, "I spoke up against sexual violence." She posted that article, that's
now displayed on your screens, and the title on her Twitter page, right
along with an announcement that she was becoming an ACLU
ambassador on women's rights to make sure that "women and girls can
live free from violence."
She presented herself as the face of the #MeToo movement, the
virtuous representative of innocent women across the country and the
world who have truly suffered abuse. The evidence will show that was a
lie, and the evidence will show that Ms. Heard portrayed Mr. Depp as the
representative of abusers everywhere, the agent of her suffering, the
villain in her heroic journey. That was a lie too. And more than just a lie,
it was an act of cruelty. Mr. Depp will go to his grave knowing that
whatever he does, there are people out there in this world who will
always believe that he abused a woman.
This is a case about what Ms. Heard said. It's also a case about what a
man named Adam Waldman said. Adam Waldman is a lawyer who has
worked for Mr. Depp. After...again, timeline, after Mr. Depp filed this case
against her, Ms. Heard filed her own claim against Mr. Depp, which is
also the subject of this trial. In her claim, Ms. Heard says that Mr. Depp
defamed her because Adam Waldman, his attorney, made some
statements to reporters denying the truth of her claims of abuse. Adam
Waldman is not in this courtroom. Ms. Heard chose not to name him in
her claim. And I won't take up too much of your time with a discussion of
her claim against Mr. Depp, except to say a few things.

Transcription by www.speechpad.com Page 11 of 115

The evidence will show that those statements weren't even made by Mr.
Depp. They were made by Adam Waldman. And Mr. Waldman, the
evidence will show, is not under Mr. Depp's control. The statements
were merely Mr. Waldman's opinions, made in justified defense of his
client and friend, Mr. Depp. Mr. Waldman believed those statements.
And finally, at the end of the day, Mr. Waldman's statements merely
reflected the reality that we intend to prove in this trial, that Ms. Heard's
portrayal of herself as a victim of domestic violence at the hands of Mr.
Depp is a lie.
Ms. Heard, as you know, is an actress. When she accused Mr. Depp of
abuse and painted herself before the world as a representative of abuse
victims everywhere, Ms. Heard took on the role of a lifetime. She can't
back down. She has been living and breathing this lie for years now, and
she has been preparing to give the performance of her life in this trial.
But this trial is about the evidence. It's about a man's reputation, and it's
about his whole life, his ability to walk down the street, look people in the
eye, without having to think he's an abuser. It's about the truth, and the
truth will come out in this trial.
At the end of this trial, we will ask you to render a verdict for Mr. Depp.
We will ask you to tell the world that he is not the abuser she described
and that she is not the victim she portrayed. And we will ask you to tell
Ms. Heard that what she did was wrong. Thank you very much.
Judge Azcarate: Thank you, Ms. Vasquez. All right. Ladies and
gentlemen, it's a little early, but maybe we should go ahead and take our
morning break just since it's a natural point to have a break before we
have the second opening statement, okay? So why don't we go ahead
and take a 15-minute recess? Just remember, do not discuss the case
and don't do any outside research, okay? All right, you're free to go.
All right. Thank you. All right. Opening statements. Mr. Rottenborn.
Mr. Rottenborn: May I approach?
Judge Azcarate: Yes, sir.
Mr. Rottenborn: Good morning, everyone. My name is Ben Rottenborn,
and together with Elaine and Adam, I represent Amber Heard.
In a few minutes, Elaine will get up here, and she'll introduce you to
Amber. And she'll address the allegations that you just heard in Mr.
Chew and Ms. Vasquez's opening statement. And she'll explain to you
why all those inflammatory things are things that are designed to
mislead you, mislead you from the truth. She'll explain to you what the

Transcription by www.speechpad.com Page 12 of 115

evidence will show, and that's something that we're going to focus on in
this trial, not attempts to distract you. We're going to focus on the
evidence, not what we wish the evidence showed, not some crazy
conspiracy theories, but what the evidence and the facts actually show.
And as you assess the evidence in this trial, I would ask that you keep
one question in mind above all else, which is this, why are you here?
What are you being asked to decide?
You're being asked to decide a very simple question, and that question
is, were the words that Amber used in the December 18th, 2018 opinion
piece that was published in "The Washington Post" protected free
speech under the First Amendment or not? That is the question, and
that's what you're being asked to decide. At the end of the trial, the judge
will explain to you what the law is on defamation and what Mr. Depp's
burden is to prove in order to establish defamation. And she'll tell you a
lot of things about the law, but among them, she will tell you that Mr.
Depp will have to prove that the words Ms. Heard used were about him
and that they were false. If he can't do that and if he can't meet the other
elements of the claim, then he loses that claim.
And he can't do that. He can't come close to doing that, and for that
reason, you're going to hear, in this trial, Mr. Depp's team is going to
make it about trying to distract you from that very simple question. Mr.
Depp's team is going to try to turn this case into a soap opera. Why? I'm
not really sure, because the evidence isn't pretty for Mr. Depp. It's not.
You're going to see who the real Johnny Depp is, behind the red
carpets, behind the fame, behind the money, behind the pirate
costumes. You're going to see who that man really is.
Amber is going to tell you about it. You're going to hear who he really is
from other witnesses, and you're going to hear who he really is in his
own words, in the vile, graphic, terrible messages that he wrote about
Amber and ways he used to describe Amber and what he wanted to do
to Amber, from the earliest days that they were dating, through their
marriage, and after their marriage. You're going to hear about that.
But this case isn't about that. This case isn't about a day-to-day
chronicle of their marriage. It's not about who is the better spouse. It's
not about who you like more. It's not about which party can sling more
mud. But you're going to hear a lot of that in this trial. You're going to
hear that because that's what Mr. Depp wants to turn this case into. He
wants to turn this case into a six-week-long public spectacle of the most
intimate aspects of their relationship and their marriage. And you know
what, I'm sorry for that. I'm sorry. I'm sorry that we're going to have to do

Transcription by www.speechpad.com Page 13 of 115

that. I'm sorry that you're going to have to listen to all of it. And I'm sorry
that Amber's going to have to relive that. But that's the case that Johnny
Depp chose to bring. And we're not going to stand idly by and let him
sling mud at our client and make inflammatory and false statements, like
you just heard in opening, and not let those go unresponded to.
But ultimately, what this case is about, is about the First Amendment,
about that December 18th, 2018 op-ed piece, and whether Ms. Heard's
freedom of speech and the First Amendment give her the right to say the
words that she said. That right, that freedom of speech, is what Amber
Heard is asking you to uphold and protect in this lawsuit. And that's a
very simple question, a question you could decide this afternoon, and it
does not require you to stand and serve as the umpire of two movie
stars' imperfect marriage. It doesn't. And so we're going to focus on
those words. We're going to look at those words. And as we look at
those words, I'd ask you to keep this in mind.
Keep in mind what you just saw on the screen for Mr. Chew when he put
up those words. Keep in mind what you didn't see. You didn't see the
rest of the opinion piece. And what we'd ask is that, as you look at those
words, that you look at them in the context of the piece in which they
were written. Now, whether you look at them individually or in the
context of the piece, it doesn't really matter, because the words are true.
But context matters.
And so what I'm going to do is I'm going to ask Heather to put up the
article, put up the opinion piece, and I'm going to read that to you. And
we're going to look at those words in the context of what this piece was
about, because Mr. Depp's team wants to make you think that this
opinion piece was designed to destroy Johnny Depp, that this was
designed to maliciously talk about him and their life together. And it
wasn't. So let's take a moment to look at this, and I'm going to read it to
you, and I'd ask that you follow along if you can. But either way, let's
take a look at what the piece as a whole says.
This is the piece that Amber wrote. "I was exposed to abuse at a very
young age. I knew certain things early on without ever having to be told.
I knew that men have the power, physically, socially, and financially, and
that a lot of institutions support that arrangement. I knew this long before
I had the words to articulate it, and I bet you learned it young too. Like
many women, I had been harassed and sexually assaulted by the time I
was of college age, but I kept quiet. I did not expect filing complaints to
bring justice, and I didn't see myself as a victim.

Transcription by www.speechpad.com Page 14 of 115

Then, two years ago, I became a public figure representing domestic
abuse, and I felt the full force of our culture's wrath for women who
speak out. Friends and advisors told me I would never again work as an
actress, that I would be blacklisted. A movie I was attached to recast my
role. I had just shot a two-year campaign as the face of a global fashion
brand, and the company dropped me. Questions arose as to whether I
would be able to keep my role of Mira in the movies, 'Justice League'
and 'Aquaman.' I had the rare vantage point of seeing, in real time,
institutions protect men accused of abuse. Imagine a powerful man as a
ship, like the Titanic. That ship is a huge enterprise. When it strikes an
iceberg, there are a lot of people on board desperate to patch up holes,
not because they believe in or even care about the ship, but because
their own fates depend on the enterprise.
In recent years, the #MeToo movement has taught us about how power
like this works, not just in Hollywood but in all kinds of institutions,
workplaces, places of worship, or simply, in particular, communities. In
every walk of life, women are confronting these men who are bullied by
social, economic, and cultural power, and these institutions are
beginning to change. We are in a transformative political moment. The
president of our country has been accused by more than a dozen
women of sexual misconduct, including assault and harassment.
Outrage over his statements and behavior has energized a female-led
opposition. #MeToo started a conversation about just how profoundly
sexual violence affects women in every area of our lives. And last
month, more women were elected to Congress than ever in our history,
with a mandate to take women's issues seriously. Women's rage and
determination to end sexual violence are turning into a political force.
We have an opening now to bolster and build institutions protective of
women. For starters, Congress can reauthorize and strengthen the
Violence Against Women Act. First passed in 1994, the act is one of the
most effective pieces of legislation enacted to fight domestic violence
and sexual assault. It creates support systems for people who report
abuse and provides funding for rape crisis centers, legal assistance
programs, and other critical services. It improves responses by law
enforcement, and it prohibits discrimination against LGBTQ survivors.
Funding for the act expired in September and has only been temporarily
extended. We should continue to fight sexual assault on college
campuses while simultaneously insisting on fair processes for
adjudicating complaints.
Last month, Education Secretary Betsy DeVos proposed changes to
Title IX rules, governing the treatment of sexual harassment and assault

Transcription by www.speechpad.com Page 15 of 115

in schools. While some changes would make the process for handling
complaints more fair, others would weaken protections for sexual assault
survivors. For example, the new rules would require schools to
investigate only the most extreme complaints and then only when they
are made to designated officials. Women on campuses already have
trouble coming forward about sexual violence. Why would we allow
institutions to scale back support?
I write this as a woman who had to change my phone number weekly
because I was getting death threats. For months, I rarely left my
apartment, and when I did, I was pursued by camera drones and
photographers on foot, on motorcycles, and in cars. Tabloid outlets that
posted pictures of me spun them in a negative light. I felt as though I
was on trial in the court of public opinion, and my life and livelihood
depended on myriad judgments far beyond my control. I want to ensure
that women who come forward to talk about violence receive more
support. We are electing representatives who know how deeply we care
about these issues. We can work together to demand changes to laws
and rules and social norms and to write the imbalances that have
shaped our lives."
I know that was a lot, but that is the central issue in this case. Are those
words, that Amber wrote, are those protected by the First Amendment?
And the answer is, very clearly, yes. So let's talk about that article for a
minute. First of all, the article doesn't mention Depp by name. It never
once contains his name in that article. It is not about Amber's
relationship with Mr. Depp. There are no details of any abuse in that
article. The article is about proposed legislation and strengthening of
government laws and policies designed to protect abuse victims and
people who report abuse. That's what the article is about, and it was
written in the midst of a social movement in which the American Civil
Liberties Union, the ACLU, asked Amber to use her platform to speak on
these important issues. And that's what she did.
To do so, she drew on her experiences as someone who had reported
domestic abuse. And there's no question, there is no dispute, that she
did, in fact, report domestic abuse in 2016. Depp's side admits that. She
talked about her negative personal experiences and her reactions and
opinions after being someone in Hollywood who reported abuse and the
consequences that flowed from that. She talked about what she
experienced in the days and months following reporting that abuse.
That's what the article is about. The article isn't about Johnny Depp. The
article is about the social change for which she is advocating and that
the First Amendment protects. And so I hope you remember, as this

Transcription by www.speechpad.com Page 16 of 115

case goes on, that you saw from Mr. Chew only the three statements in
isolation, because they want you to forget that. They don't want you to
pay attention to what the article is about.
Now, if it had been Amber's intention to use this article to detail the
abuse that she suffered and that you'll hear about over the course of this
trial, believe me, the article would have looked very, very different. She
could fill a book with those details. She probably would have started out
by calling out Mr. Depp by name. She probably wouldn't have published
it in "The Washington Post." She would have described in great detail
the man who has described himself, the violent side of himself, as the
monster. That's what she would have done. The monster. She would
have told you about the monster. But she didn't. That wasn't the point of
this article. And she was careful to avoid that, even having her lawyer
review the article to make sure that it was okay, and she relied on that
lawyer's advice, and you'll hear testimony on that during the trial. But
because Johnny Depp brought this case and asked for it, all of that is
going to come out. Just know that Amber Heard never wanted to unearth
for the public who the real Johnny Depp is, but that's going to come out
over the course of this trial.
I'd like you to also take into consideration who isn't here today. You don't
see The Washington Post sitting here as a defendant in this courtroom.
Depp didn't sue The Washington Post. He had no interest in doing that.
He only sued Amber. He could have sued The Washington Post, they
published the article. But he didn't, and he chose to bring Amber to court
here in Virginia where she has no ties, has never lived, he's never lived,
where they never spent any time, because he wanted to make her life
hard. He wanted to ruin her life. He wanted to destroy her. That's what
he did. And I wish I could say that that's surprising. It's certainly
disturbing, but it's not surprising, because the evidence will show that,
for years, all Mr. Depp has wanted to do is humiliate Amber, to haunt
her, to wreck her career. That's what the evidence will show in his words.
That's what he wanted.
But he made a mistake, bringing this case in Virginia, because you're
the people who are going to hear this case, a qualified, prepared jury
who respects the First Amendment. And with that, even though we've
looked at the article as a whole, I'd like to spend a few minutes looking
at the individual statements that were made, just as Depp's side showed
you, because I think it's important to do that as well. Can we pull up slide
one, please?

Transcription by www.speechpad.com Page 17 of 115

"Then, two years ago, I became a public figure representing domestic
abuse, and I felt the full force of our culture's wrath for women who
speak out." There's absolutely nothing false about that statement. First
of all, the evidence will show that Amber did suffer domestic abuse at
the hands of Johnny Depp, and it took many forms, physical, sure, but
also emotional, verbal, and psychological abuse. It's all domestic abuse
that she suffered at his hands. So that's the truth.
But what else is the truth is that, on May 27th, 2016, 2 years before this
opinion piece was published, Amber walked into a courtroom in
California, with bruises on her face that were given to her by Johnny
Depp on that incident in May 21st, 2016, that Elaine is going to tell you
more about, that absolutely were given to her, and she took out a
domestic violence restraining order that she obtained from the court in
California to protect herself. And she was, of course, a public figure.
She's a movie star. She didn't want the paparazzi, the press photos. She
got those, of course. Who wants to be photographed with a bruised face
walking out of court? She didn't want that. And the evidence will show
that. But she was a public figure, and two years before she wrote this
article, she was a public figure representing domestic abuse. That is
100% true. And try as he might to take it away, Amber's freedom of
speech gives her the right to say that. Can we pull up slide two, please?
This is the second statement. "I had the rare vantage point of seeing, in
real time, how institutions protect men accused of abuse." Once again,
that statement is 100% true. Amber did accuse Johnny of abuse, and
she saw how he was protected at the same time that her career took a
downturn and that he did everything that he could to try to wreck her
career, as the evidence will see. But she accused him of abuse. That
statement is true. You don't need to relive every intimate detail of their
marriage. You don't need to decide what happened on any individual
day of their marriage to determine that the First Amendment protects
that statement because it is true. He wants you to forget that. Don't take
the bait. Let's pull up the third statement, please.
Now, this statement was in the headline of the online edition of the
article. "I spoke up against sexual violence and faced our culture's
wrath. That has to change." The undisputed evidence in this case will be
that Amber did not write these words, did not review these words, did not
approve these words. That's how op-eds work. She wrote the article.
She didn't write this headline. And for that reason and that reason alone,
it's not defamatory. But here's the thing, like the first two statements,
tragically, it's true. Amber did suffer sexual violence at the hands of

Transcription by www.speechpad.com Page 18 of 115

Depp. And Ms. Vasquez tried to minimize that and tried to make you
think that it's all made up, but it's not.
You will hear in the most graphic and horrifying terms about the violence
that she suffered. You'll hear that straight from her. She will get on the
stand, and she will tell you that. It happened, and by taking out that
domestic violence restraining order, by obtaining that from the court, she
did speak out against it and all the other abuse that she suffered, and
she said, "Enough is enough. I need to protect myself." She didn't want
to do that. She didn't want to be forced to get that restraining order, but
she did. She spoke out against the abuse by doing that. And the
evidence will show that she did face her culture's wrath, perhaps,
illustrated no more clearly by the fact that she's here today facing this
lawsuit brought by an obsessed ex-husband hell-bent on revenge. That's
why she's here. That's why she's facing our culture's wrath.
And as you consider whether these statements are true, I'd ask you to
keep this in mind as well, the evidence will show that, in May of 2016,
when she obtained the restraining order, Mr. Depp never denied the
allegations, and in fact, he signed a statement that Amber hadn't made
any false statements for financial gain. He signed a statement saying
she hadn't made any false statements. And you'll see that in evidence in
this trial. And it was only two years later, as his career was in free fall
and her career was taking off, that he pounced, that he chose to bring
this lawsuit, after saying that she hadn't made any false statements. And
one thing that you'll be instructed at the end of the trial, that the Mr.
Depp side will try to distract you from, is that any damages that he
suffered and any defamation has to flow from that 2018 opinion piece.
This case isn't about the statements made in 2016, even though they're
true. This case is about the December 2018 opinion piece. That's what
the case is about. And I have to say, it's pretty ironic. It's pretty ironic that
a piece that briefly discussed Amber moving on from Johnny Depp, that
briefly discussed her life experiences after Johnny Depp, is the very
vehicle that he uses to try to keep her from moving on, to try to keep her
from living that life, rather than give her her life back, rather than take
personal responsibility for his own actions. It's ironic that he uses that
piece to do that. But like I said, it's not surprising, because you will see
clear and graphic evidence of his intentions dating back years.
Now, in five or six weeks, Elaine or I will get up here at closing
argument, and we'll remind you. We'll remind you what this case is
about. We'll remind you that this case is about one piece of paper,
Amber's words in this article that wasn't about Depp, wasn't about her

Transcription by www.speechpad.com Page 19 of 115

marriage, wasn't about her relationship, that it was about life after that.
It's about the freedom of speech. It's not about the soap opera that Depp
will turn this case into. It's not about who you like better. It's not even
about whether you agree with the words that she wrote. It's about her
right to speak them.
Now, before I sit down, I'd like to briefly discuss some of the damages
that Depp alleges in this case, because he can't win the case if he can't
show damages, and the evidence will show that he has not suffered one
cent of damages from this op-ed, not one. Now, make no mistake,
Johnny Depp's reputation is in tatters. His career is in free fall. But it's
because of problems that he created, problems that he is responsible
for, and he's here in court asking you to blame Amber for them. But it's
not Amber's fault. They're from the choices that he made. You'll hear a
lot of evidence in this trial about those choices.
You'll hear evidence of crushing drug and alcohol abuse. You'll hear
evidence of Depp taking more drugs than you can count. You'll hear
evidence that before one of the instances of abuse, a cross-country
plane flight in May 2014 from Boston to Los Angeles, when he kicked
Amber in the back on a private jet. You'll hear evidence that he had had
no food for days, that he had used cocaine, that he had had half a bottle
of whiskey, that he had had countless Red Bulls and vodkas, that he had
taken pills and, on the plane, decided to top all that off with two bottles of
champagne, you'll hear evidence of that, and he blacked out on the
plane, and he abused Amber and didn't remember anything about it
when he woke up. You'll hear evidence of drug binges with his good
friend, Marilyn Manson.
You'll hear evidence of that three-day blackout in Australia that Ms.
Vasquez tried to minimize and tell you was false, a three-day blackout in
which he abused and sexually assaulted Amber all because she had the
courage to confront him about his drinking. Imagine that, a concerned
spouse confronts her husband about his drinking and gets rewarded
with that. That is what the evidence will show. That is what happened to
my client. That three-day blackout that led her to be so in fear for her life
that she barricaded herself in her room, that same three-day blackout
that kept him from being able to do what he was in Australia to do, which
was to film "Pirates of the Caribbean 5." His behavior on that trip, both
before the blackout and during it, kept him from being a reliable actor.
He showed up late to the set, and after that blackout, he was gone from
the set for a long time.

Transcription by www.speechpad.com Page 20 of 115

Now, he did cut off his finger, but the evidence will show, my client did
not do it. And just imagine this, what Ms. Vasquez is trying to get you to
buy, is that Heard somehow developed a Major League-level fastball
and cut off his finger with a bottle. You'll see the evidence. You'll see that
that doesn't make any sense, and you'll hear from Ms. Heard's experts
who'd testify, including orthopedic hand specialists who'd testify, there
was no way that that happened. You'll also see pictures of what Mr.
Depp did after he cut off his finger, when he dipped it in blood and paint
and wrote graffiti all around the house. That's what you're going to see
he did. And you're going to ask yourself, "How can someone that is
blacked out, how can they deny that they abuse someone? How can
they deny what they were told that they did?" He has no credibility when
he gets up here now in this court and tells you he didn't do this or do that
when he was blacked out. So just remember that. Those were problems
that he created.
You'll hear evidence that the same addictions that led him to abuse
Amber also led to the demise of his career as an actor. Like I said, as
you saw with Disney, as the evidence will show with Disney, he was
unreliable as an actor. And those same self-destructive tendencies led to
financial distress. Quite simply, he was running out of money, and that
distress fueled his abusive tendencies toward Amber. And it led the
public to think less and less of him.
And you will see a parade of witnesses who testify in Johnny's case that
all have one thing in common, they all rely on him, they're all on his
payroll, for the most part, or they rely on him for some sort of luxury in
their life. And you'll see that of these witnesses. So in a lot of ways,
Amber previewed the parade of witnesses when she said in her op-ed,
and I'm going to read from it and quote it here, she said, you remember
when I said this, "Imagine a powerful man as a ship, like the Titanic.
That ship is a huge enterprise. When it strikes an iceberg, there are a lot
of people on board desperate to patch up holes, not because they
believe in or even care about the ship, but because their own fates
depend on the enterprise."
Remember that as Depp's witnesses take the stand, none of whom
know what happened behind closed doors between him and Amber,
none of whom can testify to that. But remember that these are people
who care about their own financial well-being, just as they were
previewed in that article. And they know what happens to people who
stand up to Depp. They know what happens, because they've seen it.
They've seen it with Amber, and they've seen it with other people in his
life who had the courage to ask him to change and who he lashed out

Transcription by www.speechpad.com Page 21 of 115

against. These are people who helped enable the man who describes
himself as the monster. Make no mistake, this man's poor choices have
brought him to this courtroom, his own bad behavior, his own refusal to
commit to sobriety, his own violence, his poor choices. And the people
who have spoken up against it, they're the ones that have suffered the
consequences.
You'll hear evidence that he fired his long-time agent, that he got rid of
his business managers and his law firms that had represented him for
years. And no one has suffered from his refusal to take accountability
more than Amber Heard. You'll hear evidence that, two years before the
op-ed, two years before that, Mr. Depp brought someone else into his
life who helped convince him to blame other people. That man, Adam
Waldman, who Ms. Vasquez introduced you to, had never met Mr. Depp
while he was in a relationship with Ms. Heard or while he was
represented by his agents or his former business managers. But he
convinced him that all these bad things that are happening in his life, he
helped convince him of this, were other people's fault. And you'll hear
evidence of that. Rather than take responsibility for cleaning himself up,
Depp chose to blame other people.
That's why we're here, and the evidence will show you, crystal clearly,
that the op-ed had nothing to do with damages that he's suffered. He's
going to try to make it sound like this caused him to lose Pirates of the
Caribbean 6, which is a movie that hasn't been made but that Disney
wasn't going to cast him in because of Amber's article. But there's no
evidence of that. The evidence will actually show that months before the
op-ed, it was reported that Disney was considering dropping him from
Pirates 6. The evidence will show that Disney had a dossier on him that
had articles from the press, had other information about Mr. Depp, and
they didn't have this article at all in their files, didn't register with them,
just as it didn't register with the public. The public had known since 2016
what Amber had to say about Johnny Depp. This didn't change any of
that. The evidence will also show that he said he would not make Pirates
6 even if Disney paid him far more money than he'd ever made on a
film. That's what the evidence will show.
So any damages that he's suffered in his career are not because of this
op-ed, and it's time to make Johnny take responsibility, to tell him, "Mr.
Depp, stop blaming other people for your self-created problems, to take
responsibility for your own life." And it's up to you, ladies and gentlemen,
to make him do that. It's up to you because you are uniquely qualified to
do that. No one else has the power to do that, only you, to tell him,

Transcription by www.speechpad.com Page 22 of 115

"Enough is enough," to stand up for the First Amendment, to stand up
for the truth and Amber's right to speak it. Thank you.
Judge Azcarate: Thank you, Mr. Rottenborn. Ms. Bredehoft. Okay.
[01:16:39]
[silence]
[01:17:07]
Ms. Bredehoft: Good morning, still. It's good to see you all again, and
thank you, again, very much. Ben told you we will be relying on the
evidence rather than the hyperbole and the personal attacks, and he
was right. The evidence in this case, simply put, is overwhelming and
compelling. In six weeks, we're going to try to show you as much as we
possibly can. There are many, many, many photographs. Now, you
heard Ms. Vasquez try to say, "Uh-oh, you can't trust those. It's not the
originals." She's got that wrong. It's not from the original devices. Ms.
Heard took all kinds of photographs, and her friends took photographs,
and all of those remained on the cloud. And all of them have been
imaged, and all of them have been examined by their IT experts, and
they cannot discredit one photograph. Then, she says, "Oh, and it's got
a photo editing thing." Well, all iPhones have the photo editing. It's
where you can make it a little lighter or darker, you can move it to the
center or not. That doesn't discredit the photographs, and we will have
an IT expert who will testify that all of these are legitimate, authentic
photographs.
Not only that, but Ms. Heard produced all of her different devices over
the years, including her most recent laptop, and they were pulled from
many, many sources, and all of them are identical. So if she was going
to go in and try to manipulate, she would have had to do it everywhere.
And Ms. Heard will tell you, she doesn't have that level of talent. There
may be a couple of you on the jury who have that talent. She does not
have that talent. They're all very legitimate photographs. And listen
carefully to the evidence from the experts, and you will find every single
piece is authenticated and is true, and they show bruises, and they show
cut lips. They show hair pulled out of her hair. They show all kinds
of...they show two black eyes when he head-butted her. Those are all
going to be there.
We also are going to show you a video, and I'll talk about the time frame
of it. Ms. Heard took that on her iPad, and it was one day when she was
in the kitchen with Mr. Depp, and it was February 10th, 2016. And he's
on a tear, and he's going around, he's yelling at her and being abusive to

Transcription by www.speechpad.com Page 23 of 115

her, and he's slamming the kitchen cupboards and their glass. And you
can hear them rattling, and you can hear them breaking. Then, he goes
over with a big glass of wine, and he has a huge bottle of wine, and he
pours more in there. And then she says, "Did you drink all of that?" And
then he sees that she's videotaping him, and bam. That's going to be a
pretty graphic one for you to see.
Then you're going to hear audio tapes, which are pretty significant too.
Ben told you about the May 2014 plane, Boston plane incident we call it,
where he kicked her, where he was so drunk and he blacked out. Well,
Amber audio taped him when he went to the back of the plane and
passed out and was moaning loudly. You will hear that. You will also
hear some other audio tapes that are very significant, one of them in
Australia. At the end of the three-day hostage situation, you will hear,
apparently, Mr. Depp turned on Ms. Heard's iPhone. She was never
allowed to have a password, by the way. He would never let her do that
during their relationship. But he must have inadvertently turned it on.
There's five hours of audio tape. It's during the cleanup of all the broken
glass and the liquor, and the urine, and the bloodstains, and everything
else in that house. And you can hear his handlers talking about it. You
can hear them talking about trying to find his finger, and you can hear
them say, "She's stone-cold sober." You will hear all of that. It's very,
very significant evidence.
What this is going to tell you is the story of a very different Johnny Depp.
It's one who is always, always...well, I can't say always, because he has
the charismatic side that Amber fell in love with, but he has an enormous
amount of rage. You will see the medical records and hear from the
psychiatrist that talked to him for a while in 2014 where he admits that
he has rage, that he's like a demon, that he views his wife, Amber, like
his mother and his sister that he hates. That's what you will see. You will
see that. And it'll be fueled by the alcohol and the drugs. Ben told you a
little bit about that. You're going to see a list of his prescription drugs that
his concierge doctor and team who charge him $100,000 a month and
have since 2014. And they are still his concierge doctors. That's the list
of the medications he takes in one day that they prescribe. That doesn't
include the cocaine. It doesn't include the Ecstasy, the MDMA, the
mushrooms, and all of the others. Now, it's during these rages that Mr.
Depp engaged in verbal, emotional, physical, and sexual abuse of
Amber.
Let me introduce you to Amber, the lesser-known person here, and I
know, when we were doing the voir dire, none of you had even watched
as much as three of her movies. So I'm going to tell you a little bit about

Transcription by www.speechpad.com Page 24 of 115

Amber. She's 35 years old. She's from Austin, Texas. She grew up
outside of Austin, Texas. She has a daughter, Oonagh, who turned one
last week. Amber grew up in an area...her father was a construction
worker, primarily, a painter, but he would break horses as part-time.
They lived out on a ranch area. Her mother, Paige, who died 2 years
ago at age 63, dropped out of medical school to marry Amber's father.
She worked for the state of Texas in internet communications. They
grew up very poor. Amber has a sister, Whitney, who's 16 months
younger than her, and you will see and hear from Whitney later, because
unfortunately, she also witnessed some of the abuse.
Amber rode horses with her father. She tried to work with him to help
him break the horses. She remembers having a broken arm at least four
times, being in casts during that time. But there were some things she
learned from breaking those horses that was very significant. Her father
taught her she couldn't show fear, she couldn't show pain, and she
couldn't show emotion. That's how she could break those horses. It's
significant for you to know that so you can understand how Amber could
have remained in this relationship with Mr. Depp for as long as she could
and the dynamics of some of the abuse you're going to hear about,
because that's what would be her instinct, is to stand up and not let him
show that he's caused the pain, that he's caused the fear, that he's
caused the humiliation.
You'll hear about a long line of jobs that Amber started from back, you
know, age 12, as soon as she could, working in a soup kitchen...well,
that was volunteer, but then she took all kinds of miscellaneous jobs,
lifeguards, everything else, trying to improve herself. She's not
somebody who had a great break. What happened was she got
recognized by a Hollywood agent who expressed some interest in her.
She took her $180 that she'd saved up, and she went to L.A. That's all
she had to her name. The testimony would be she worked all kinds of
different jobs when she was in L.A., anything that she could get. And she
would go on...but she didn't have a vehicle, so she would go on buses,
and she'd go up to six different auditions in one day.
She'd have a map, and she'd have the bus, and then she would just go
around. She had a big sweater so she could change underneath it to
whatever the role was so that she could get things. And she wasn't
going for, you know, famous actor roles. She was taking one-liners. She
was taking extras. She was doing anything she could to make money to
survive. And then you know what she did with it, she gave a bunch of it
back to her parents. She started helping support them. Then, when
Whitney graduated from high school, she brought her out to L.A., and

Transcription by www.speechpad.com Page 25 of 115

put a roof over her house, and put her through community college. She
took care of her family with what she made.
When she met Johnny Depp in 2009, when he hired her for Rum Diaries
to star across from him, she felt like she was pretty successful. She'd
starred in some roles. She had an apartment. She had a vehicle, a
Mustang. She could go to Starbucks. She could afford Starbucks. She
viewed herself as doing pretty well at that point. Now, during "The Rum
Diary," she got to know Mr. Depp. Not true that she was pursuing him or
anything else. She was in a long-term relationship with Tasya van Ree,
and he was in a long-term relationship with Vanessa Paradis. Neither of
them had any kind of romantic relationship at that time. When she
departed from "The Rum Diary" in 2009, Johnny started pursuing her. In
fact, he sent her a number of gifts, one of them was a guitar, and she
returned them.
Now, two years later, fast forward, that's when the press junket started,
and that's when she had to come back and meet with him, and they ran
on the press tours. At that point, she had ended the relationship with
Tasya van Ree, and he said he had ended his relationship with Vanessa
Paradis. So during the press trips, that's when they started dating and,
by both accounts, fell madly in love. She loved the side of Johnny that
we see in the movies, the charismatic one, the charming one, the
generous one. That's the man she fell in love with. But sadly, the
monster came in the way, and that monster would come out when he
was drinking and when he would take the drugs.
Amber will never forget the first event of abuse. She was sitting in his
house in Sweetzer, on the sofa, and he was across from her. And they
were talking about a tattoo that he had that had had Winona, Winona
Ryder, forever. He had altered that to "Wino forever" after he broke up
with Winona Ryder. Just an aside, he had "SLIM," which was his
nickname for Amber. When they broke up, he turned it to "SCUM." But in
any event, he had that on there, and Amber thought he was making a
joke when he was talking about it. And she laughed. And he slapped her.
Now, you see the rings that Mr. Depp has on, and it hurts when he slaps.
And she was stunned. She had no idea what to think. And she kind of
laughed thinking, "Well, maybe that was a joke. What just happened?"
And he slapped her again.
And then she just froze and just looked. And then he hit her again, and
this time, it knocked her right off the sofa, onto the ground. And she
remembers, her face was in this dirty, filthy carpet. That's what she
remembers and fixated on, the dirty carpet. And she's thinking, "Oh my

Transcription by www.speechpad.com Page 26 of 115

god, I have to leave. I have to leave. But I love him. I have to leave, but I
love him." And she sat there for the longest time. She laid there for the
longest time. Then, Johnny came off the sofa, got on his knees, started
crying, told her he was very, very sorry that he had done this, it would
never happen again, and he said some very significant words, "I thought
I had put the monster away for good." That's what he said to her that
day.
Well, Amber ended up leaving that day, and she went out to her car, her
Mustang. And she remembers that it was cold, and she sat in the car for
the longest time. And she remembers watching her breath, because it
was cold, and she was thinking, "I have to leave him. But I love him."
She just kept thinking that. She finally drove away. But Amber made the
mistake that millions before her and millions after her have who are
victims of domestic abuse, she chose to stay and try to fix the problem
and thinking that she could do that. So she stayed.
Now, Amber was also...she grew up in an abusive family. Her father
abused her mother, and sometimes she and Whitney. So she had that
cycle in there, just as you've heard that Johnny had that cycle in his
house. And so what's normal to them is a little bit more difficult than
some of us can understand. You will hear expert witness testimony
about the cycles of violence and what happens with these people, and
how they react, and all the dynamics of thinking they can fix them. She
thought, all the way through, she could fix them. If she can just get him
sober and clean, then everything was going to be that wonderful side
that she fell madly in love with. And she kept trying, and she kept trying.
She went to Al-Anon meetings. She went to therapists. She tried to do
couples therapy. You'll hear about their tape recording sessions to try to
resolve fights or de-escalate them so he wouldn't get mad at her for
anything. But you'll hear that he gets mad at her for all kinds of things.
He didn't want her to work. She's a budding actor who wants to be out
there and succeed, and he doesn't want her to take roles. He starts
controlling what she wears. He starts looking at her lines when she tries
out for places. He nixes any romance scenes, sex scenes. He gets mad
and accuses her of sleeping with every single one of her co-stars. It
became a cycle of that, a control, as well, emotional abuse, as you go.
But what's also significant in that is the property damage, and that's a
hard one for Mr. Depp to be able to escape when he's claiming that he's
such a docile thing and that it's all Ms. Heard. You're going to see
pictures. He writes on mirrors horrible things to her, writes on lamp
shades, you know, on clothing, on countertops. In Australia, when you

Transcription by www.speechpad.com Page 27 of 115

heard Ben talk about Australia, he wrote...the third day, as Amber comes
out after she's barricaded herself and gone through a lot, and I'll back up
on that in a minute, she comes out, he's got mashed potatoes spread
across the top. He's written along the wall of the staircase going down
all kinds of nasty things about her, and Billy Bob Thornton, the last one
she was in a co-star with, and you know, fucking ambition, and all kinds
of things like that. Then, he's written on the lampshades downstairs, and
then he's got more on the mirrors. And then, on top of it, you've got all
the broken glass everywhere, and you've got the liquor everywhere. And
it's just...and then he's urinated...tried to urinate messages to her.
That's the Johnny Depp that's the other side. Now, you're going to hear
that Amber tried to protect him, all the way through. She didn't want the
public to know this. She didn't want his kids to know this. And so she
didn't tell people about it.
So let's go back. The first event that I told you about was 2011. And how
do we know that it was in 2011? Because Amber was going through her
therapist, Bonnie Jacobs, and Bonnie Jacobs has therapy notes of her
sessions with Amber. And in those therapy notes, she chronicles the first
time that Amber tells her that Johnny hit her, and it goes through into
2012, 2013, 2014. And you will see, and you will hear from Bonnie
Jacobs, her saying, "You know, this is a cycle of violence. This is a cycle
of abuse. You can't enable him. You need to stand up for yourself."
Amber will testify about how Johnny would get so drunk and so drugged
out that he would vomit all over himself and, worse, lose control of his
bowels. She would clean him up. And you'll see Bonnie Jacobs, in these
notes, saying, "Don't do that. You're enabling him. Don't do it. Leave him
there." But what would happen was his handlers would then take care of
him if she left him.
So that's the story you're going to hear on that. Let me just tell you about
a few of the events, and I'm going to start in Australia. That's the three-
day hostage. She gets there. Now, you will hear Mr. Depp would testify,
under oath, that for 15 to 18 months before the March 2015 Australia
event, when he's there filming, that he's been sober. Clean and sober.
Then, you'll see all the text messages for the last 18 months in which
he's scoring drugs, in which...you'll hear testimony from people in which
he's gotten drunk and, you know, taken all kinds of different drugs, the
whole time. He doesn't get clean and sober, but he claims that he was
clean and sober. That she came there...this is a month after they just got
married.

Transcription by www.speechpad.com Page 28 of 115

She flew in from filming "The Danish Girl." She's there, and he claims
that he was just sitting there calmly, and she was haranguing him. So he
took a shot glass of vodka, and when he did that, she got mad, took the
bottle of vodka, it was 8 to 10 feet, about where I am from you, and
hurled it at him, and it happened to just take off the bottom part of his
finger. And then he says she came and burned a hole in his cheek. The
testimony is going to be that he self-mutilated on a number of occasions
and burned himself in the cheek and also cut himself. But Amber never
did that. And you're going to hear from the experts testifying about this
finger injury and how fantastic this version is.
But the other part of it was he was with Marilyn Manson for the week
before scoring on cocaine. You'll see text messages of him getting it
from his handlers, the cocaine and the liquor. And you'll hear so much
before that. But Amber gets there, and instead, what he does is he takes
8 to 10 tablets of Ecstasy, almost immediately. And the next three days
are just a cycle of a very, very, very violent activity by him. Amber keeps
trying to calm him down. She tries to get him to eat. She tries to get him
to sleep. She tries to do these things. And he would just, at different...he
was, you know, at times, delusional, paranoid. He would be, you know,
mad at somebody else. Then, he'd be mad at her.
And by the way, we'll talk about the prenup, but he called her lawyer,
who she had because she wanted to give him a prenup, and then they
got married too quickly, so she was going to give him a postnup. He
called the lawyer from Australia, called her a bitch, and fired her. You'll
hear the testimony from the lawyer on that. That's the type of Johnny
Depp that was there. He didn't want the postnup, he didn't want the
prenup, but now they're going to tell you that it was her that was mad.
You're going to hear...she had a lawyer, and she was cooperating
completely on that.
So, as you go through those three days of Australia, some pretty
horrendous things happened to her. He rips off her nightgown. He has
her jammed up against a bar. He has hurled bottles and bottles at her.
He has dragged her across the floor on the broken bottles and the liquor.
He has punched her. He has kicked her. He tells her he's going to
fucking kill her. He fucking hates her. He's pounding at her, pounding
her. And then he penetrates her with a liquor bottle. That's the Johnny
Depp that you're going to hear about in this case.
Now, after that, Amber goes to the airport. What does she do? She buys
a book by a psychiatrist who's talking about couples therapy. She's
already trying to figure out a way to fix it again, fix this marriage that's

Transcription by www.speechpad.com Page 29 of 115

only a month old, and her husband has just done these horrible things to
her. Now, they go back to L.A. He's got to get his finger fixed. So he has
to stop filming Pirates 5. They get there, and there's another fight in just
two weeks from there. He's still using, at this point. He's still drunk. But
Amber finds on a TV screen, his monitor, she finds pictures of another
woman, naked pictures of a woman, and text messages, which show
that he's clearly having an affair. She gets extremely mad. Amber can be
jealous too. She can get angry. She's half his age, and she's defiant,
and we're not going to say she's perfect, she was mad as can be when
she saw that. And she confronted him, and the two of them were
screaming at each other.
Now, her sister, Whitney, happened to be in the house. She was
summoned. She literally was awakened to come and try to resolve this
fight between the two of them. While she's there, Johnny starts hitting
Amber. And Whitney ends up getting in between them, and Amber thinks
that Johnny's going to throw her down, push her down the stairs,
because he's in that position. So Amber actually gets up and punches
Johnny in the face. She'll tell you that's the only time she has ever laid
one on him, you know, in an aggressive manner, but it's after he's
already been hitting her, and it's in defense of her sister. And she'll
admit, she got him that time, and she actually did have an impact on
him. She'll testify about how many times they were in their fights, and
she said...you know, she's almost half his size, so you know, she said, "If
I pushed him, he doesn't move. He pushes me, I go flying across the
room."
There isn't any, you know, ability on her part to be the abuser. What
she'll also tell you is it took her a while to ever fight back, that many
times before, that she would do what she did when she was breaking
the horses. She wouldn't show fear, she wouldn't show pain, she would
look at him, she would just be defiant, and all it would do is piss him off
more. She'll tell you that she tried everything. She tried everything, you
know, from trying to be nice, trying to get away from him. You know, she
would throw things in his way to get him from running after her. She
would try to, you know, flail back. She would use her hands and legs,
and she would go and try to fight him. She'd run into a room and try to
barricade and push his hands and everything out of there. She'd try all
those things, but she couldn't figure out what could get him to calm
down.
I'm going to fast forward now to the next one, and that is...I'm going to
jump you up to after the stair incident and Johnny had to get surgery on
his finger. That's the longest period of time he stayed sober. It was

Transcription by www.speechpad.com Page 30 of 115

almost three months. You're going to hear that he has never been
through rehab, even though he has been a lifelong drug addict and an
alcoholic, never has he gone through a rehab plan. Instead, there's
twice that he went to some New York hospital and did a cleansing. One
time, it was for three days, and one time, it was for five days, and that's
it. He's never made any effort, whatsoever, to get sober or stop the
drugs. But this particular time, he did, for almost three months, and you'll
see the text messages. We're going to take you through this whole story
and all the text messages and all the emails and all the testimony that
you're going to get.
So fast forward to December 2015, that was one of the worst. Australia
was pretty bad, but this one was even worse. In this particular occasion,
he gets angry for some reason, and he starts dragging her by her hair
through the apartment, kicking her, punching her, tearing her hair out. At
one point, she gets up and looks at him, and he head-butts her. And she
gets two black eyes from it. Then, he goes and grabs and drags her up
the stairs, puts her on the bed, puts his foot and knee in the back of her,
and he continues to punch her, telling her he's fucking hating her, and
he's fucking going to kill her. And he's got his boot stuck in the bed frame
as he's doing it, and the force of what he's doing to her causes the bed
frame to splinter. That's how much force. She is suffocating in the pillow,
and she believes, truly, she's going to die on this one.
She wakes up to her friend being there. She doesn't know how long that
she was unconscious or subconscious. She doesn't know. But Johnny
was gone at that point, and her friend is saying, "Are you okay? Are you
okay?" You'll see the pictures of all of this. You'll see the pictures of the
hair. Imagine how much that must hurt, the hair that's out on the ground.
And you'll see the pictures of Amber.
Now, here's the ironic thing. The next day, she's got to be on the James
Corden show. And you can see the text messages, she's not sure if she
can go, she's worried, she's got two black eyes, she's got a split lip,
she's got bruising, she's got hair missing. But her friends rally with her.
She's got a makeup artist. You're going to hear from Melanie Inglessis,
who does the best job of makeup you could imagine to get her through
the James Corden show. And she does it, but you'll see the pictures, the
before, and you'll see them then. And that's the resilient Amber who
says, "I'm going to go do this anyway."
Now, her friends, she tells...you're going to hear about iO Tillett Wright.
He was in New York. She texted him and said, "Johnny beat me up
really good this time. Can you help?" And he says, "I was filming

Transcription by www.speechpad.com Page 31 of 115

something. I stopped. I got the first flight out of there. I'm flying from New
York back to L.A. I see her on the James Corden show. I can see the
swelling, because I know her well. I can see the swelling." And then he
said, "Somebody touched her, and she flinched on the show." He said,
"That's not like Amber." He got there. They hadn't cleaned up all the
mess. He sees the hair, he sees the splinter, and he sees all of the other
things. And he is so upset. He was a good friend of Johnny's as well.
He'll testify about all of his friendship with Johnny. But he put his foot
down on that one and said, "You need to have consequences. You
cannot do this to Amber anymore. I am not your friend anymore."
Now, there were several people that were supposed to go to Johnny's
island, the Bahamas island, in December, for Christmas. He was going
to bring his two kids. He'd invited Amber's parents, who loved Johnny.
And unfortunately, her father used to drink and do drugs with Johnny a
lot. And he was also going to take Rocky, her friend who lived next door
in a penthouse, and her fiancé, and Rocky's parents. Imagine being able
to go to a Bahamas island for Christmas. What a cool thing to do? But
they all were so upset, what he did to Amber on December 15, they said,
"No, we're not going. We're not going to condone this. We're not going."
But he talked Amber into going. He guilted her into going, "I'm going to
be with my kids. Please come. I'll be better. I'm going to get better."
Amber went. And then he ends up assaulting her even there and
sexually assaults her even there.
Now, you'll see a video from them of the Bahamas place that they
stayed in on his island, and the video just conveniently leaves out the
wardrobe in the bathroom where he committed the assault. It just goes
around and makes it look like it's one room, and his kids were there, and
there's no way they could have done that. But you'll hear the testimony,
and you'll see the pictures.
Then, from then on, things really were bad for Amber, and she was really
considering leaving him at this point, and she was talking to her friends
and confiding. You'll see, you know, the medical records. And in
February 2016, I told you, you'll see that video, that same night before
the video, he called iO Tillett Wright and left him a voicemail message
that he said was just absolutely delusional. It was crazy. He was
pretending like he was the property management. It was just an insane
call. And then, the next day, we have the picture of the video.
Then, we get to April 30th, or April 21st, 2016, Amber's 30th birthday
party. She was going to turn 30 the next day. Pretty big event. Her
friends had a tape that they put together of everybody giving her

Transcription by www.speechpad.com Page 32 of 115

tributes. Johnny doesn't participate. They have a dinner and a party for
her that night. Johnny says, "I have a business meeting at 7 p.m. I'll be
there after that." What kind of business meeting do you need to have at
7 p.m. when your wife turns 30? But that's Johnny, right? And he can't
say that it was an important financial one because he'd fired his financial
manager the month before when, as you heard from Ben, he was
blaming him for all his financial problems. So he is the problem.
So he shows up late, drunk, drugs. And after everybody...and he's even
drinking while he's there, and he's telling the other friends, and you'll
hear from one of them, that he's saying, "Here, hide the bottle from
Amber. Hide the bottle from Amber." When they all leave, she expresses
her disappointment. He gets mad and assaults her again, including
sexually, assaults her. Then, he goes away, and he doesn't come back
for a month.
Now, this is an important event, May 21, 2016. This is the last one, and
this is the final straw that leads out to the DVTRO, the domestic violence
temporary restraining order. So he says he's coming over to get some
clothes. He's going to go out on tour. She says, "Okay." He comes over,
and his mother died the day before, and he's already in the state. He's
been drinking, he's clearly high, and he comes in, and he's got on his
mind this obsession that when she, on her birthday...go back to her
birthday, the next day, she and her friends went to Coachella, but his
housekeeper had come in to clean after that. Always did. And the
housekeeper found some, you know, feces on the bed and had been
upset about it and taken a picture and sent it to him.
So all of a sudden, a month later, he's got it in his head that Amber has
conspired with her friends to defecate on the bed. It's human, not dog,
even though they got two dogs, and one of them has major problems.
You'll hear about Boo and Pistol. And somehow, Amber was doing this
so he would get back there and find it, even though he had no intention
of coming back and even though the housekeeper was there. And he
won't lose it. He won't get rid of it. He's just obsessed with it. Then, he
decides that it's iO Tillett Wright who did it, even though iO wasn't at the
birthday party and wasn't even in town. So Amber gets iO on the phone,
iO is in New York, and she says, "This is what Johnny says. Can you
please just calm him down? Tell him this isn't true. Tell him we didn't do
it." I don't know the conspiracy here.
And iO was thinking, "What?" And you'll hear from iO, he'll say, "Amber's
fecal-phobia. I mean, she can't even, you know." She's so embarrassed
about that stuff. She would never conspire, never do anything like that to

Transcription by www.speechpad.com Page 33 of 115

him. So they're kind of laughing at the absurdity of it, and that was the
biggest mistake, because that triggered his anger. And then he started
after...started hitting Amber. He took...grabbed the cellphone from her,
wound it up, and bashed it into her face. And you will see the pictures,
you will see the bruise there, and you'll see the form of it there.
Now, iO was very, very upset. He's worried, because he knows about
the December 15, 2015, and he says, "Amber, get out of there. Get out
of there. Are you safe? Get out of there," as Johnny's storming around.
And he calls Rocky who lives next door, and then he calls 911. And it's
not clear, you know, whether Amber said, "Call 911," or he said, "Call
911," but he calls 911. But he's in New York, and he's genuinely
concerned for her safety. So he calls 911 there, and he calls a friend in
L.A. and says, "Please, call 911 and just tell them this so they get
somebody there, so we can get somebody fast. I don't know what's
going on."
So the police are called twice, essentially. And now, here's what
happens next. Johnny goes around, and he trashes the apartment
before he leaves. He loves to do that. You're going to hear about his
penchant for that. He does it a lot. And you'll see a picture of him in the
elevator afterwards, leaving with his bodyguards, and he's a little
agitated there. And the police are called. You will see pictures of Amber,
with metadata on them, both before, during, and after the police officers
are there. But what happens is Amber calls her attorney, the one that
she had consulted after the December 15 event, and the attorney says,
"If you press charges, they'll arrest him." And Amber says, "I can't have
that happen. I don't want his kids to know about this. I don't want the
public to know. I can't have that happen."
So when the police show up, she refuses to cooperate. She says, "On
the advice of my attorney, I'm not going to cooperate." But her friend,
Rocky, whose fiancé was there, Josh, at this point, he takes them
around and shows one of the police officers all the property damage
around the house as well. And the police officers say to him, "Look,
she's got the red mark on there, you know. If you just give us the name,
we'll go get him." And he says, "I can't. She won't let me." So they leave.
Now, here's what happens and creates all of the, you know, noise here
that you're going to have to deal with. So the police officers don't make
an incident report. They don't take a report. They don't document the
property damage. They don't document the facial damage. Instead, they
go out, and they write on their CAD. That's their little system in there.
They write, "Verbal dispute only. Victim uncooperative." That's their

Transcription by www.speechpad.com Page 34 of 115

language for, "We don't have to write a report." You'll see that the police
officers have another one later that night, another, and they put, "Verbal
dispute only." That's their magic language.
Now, that's notwithstanding that you will see these pictures, but Amber
wasn't cooperating with them, and they were quite convinced she wasn't
going to. So, as many domestic violence, you know, calls that they take,
they're not going to....this is one that they figure, "It's gone." Now, the
other police officers come two hours later. They've cleaned up the place,
at this point. They don't know that these police officers are arriving, but
when they do arrive there, they tried to discourage them even from
coming in. Josh answers the door and says, "No, the other police
officers were already here." And they say, "No, but we just have to see
her." And they have body cams, by the way, so you'll see the body cam
footage of this. So they go through, and they do that. And one of the
significant things is you'll see on the CAD that the two police officer sets
are communicating with each other, and that first set says, "I don't think
she's going to change her mind." And they know who the officers were
the first time. Because they say Officer Saenz. You'll hear this, and you'll
see it in the body cam footage. Amber says, "No, everything's fine. You
can see on there." And they leave.
Now, the reason this is so significant is what they have done with this in
creating...and that's part of the counter claim. And their version of the
reality is that Amber calls the cops, then they don't see any injury, so
they mess up the place, splash a little wine, and then call another set of
cops. Does that sound like the situation here? No. No. And it's really
important to look at the evidence and think about this. You'll hear from
many...actually, I don't know how many of the police officers we'll put on,
but we have, you know, between four and six LAPD police officers and
experts who will say those police officers, even when she declined to
cooperate, should have taken a report. They should have documented it.
That was police policy.
So when faced with this big public DVRO and all of the publicity later,
now they go back to the police officers and say, "Hey, wait a second, you
didn't take a report. You said it was a verbal dispute only." They're stuck,
you know. If all of that was true, and they admitted it was true, then they
violated policy by not doing the report, because they were supposed to
take a report. So the police officers chose the other and said, "No, there
was no evidence." But you're going to watch it. You're going to see it in
real-time. You're going to see it on metadata.

Transcription by www.speechpad.com Page 35 of 115

So Amber goes to get the DV, the domestic violence, TRO. You're going
to see the letter that her lawyer wrote to Johnny Depp's lawyer that
week, telling them that that's what she would have to...she was going to
do if...but giving them opportunity here to be able to resolve it, to get a
mediator, you know, just make sure that she's safe, that she can stay in
that residence until they figure things out, that she can drive her vehicle
until they figure it out, you know, some attorney's fees, whatever. You're
going to see the letter. So they knew, and it says right in there, she's
going to go in on Friday. They chose not to go. They keep saying ex
parte, but they chose not to appear, and they knew she was going to
appear.
Well, Amber didn't call TMZ, but somebody called TMZ to take all those
photos that day. Now, you also heard them say that all kinds of people
saw Amber that week, and she didn't have any bruises on her face. Well,
let me show you this. This is what Amber carried in her purse for the
entire relationship with Johnny Depp. She's an actor. Do you honestly
think she would have left her apartment ever without makeup? Do you
think that she ever would have wanted other people to see her bruises
and her cuts?
This was what she used. She became very adept at it, and you're going
to hear the testimony from Amber about how she had to mix the different
colors for the different days of the bruises, as they developed in the
different coloring, and how she would use these to touch those up to be
able to cover those. She also used concealer, foundation. You'll hear it
from a makeup person that Amber didn't even leave her bedroom
without having foundation on. And one of the people that was at the
building testified, he said, "She had makeup on," and it would have
covered that bruise. So that's the testimony on that.
Now, let me talk about the divorce just for a moment. So they go
through. They have the two months of trying to resolve the divorce. Ben
already told you that they signed a joint statement in which Mr. Depp
admits that she did not make any of these allegations, falsely, and not
for financial gain. But they brought up the donation, so I want to talk to
you about the donations for a moment. Now, here's the story. Amber
didn't have a prenup. She didn't have a postnup. She was more than
willing to do that, but as I told you, Mr. Depp fired her lawyers and said,
"Only till death, that's the only way we're going to part is through death.
We don't need a postnup. We don't need a prenup." That's Johnny. And
it's true, his advisors were all telling him, "Get one." And she said, "I'll get
one," and she hired a lawyer.

Transcription by www.speechpad.com Page 36 of 115

But anyway, she didn't have a prenup. So what you're going to hear is
that meant, no matter what, whether it was abuse, adultery,
irreconcilable differences, abandonment, doesn't matter, she is entitled
to 50% of everything during that marriage. Well, he did Pirates 5, and he
did 2 other movies during that time, and you'll see that he made $65
million during those 2 years. Half of that is 32.5. Amber didn't want that.
You'll see a letter...you'll see an email from her lawyer that she
forwarded on to her agent, who became Johnny's agent later, saying, "I
want you to sign this because you're entitled to a whole lot more than 7
million. And I don't want you to come...basically, I don't want you to
come back and sue me for malpractice." That's what her lawyer tells her.
And then, her lawyer says, "I offered them even less than they...I
demanded less than they offered," in other words, the 7 million was less
than Mr. Depp's team was even offering to her. And she said, "I just want
to be left alone. I just want to get out of this marriage. I don't want it. I'm
not doing this for financial gain." So she didn't take the money. So she
said, "I'm going to donate all 7 million of this to charity, half to ACLU, half
to Children's Hospital."
And then, what happened was...and by the way, the 7 million was paid
out over time. It's installments. It was over, you know...you'll see the
documents, but it's over a couple of years, right? So his business
manager, Ed White, you'll see the letters, he sends the first 100,000 out
of the 7 million to each of them and says, "This is a pledge towards the
3.5 million that Amber's donating, and she'll be paying that in
installments." So everybody knows she's paying it in installments. You're
going to hear differently from them now, but you're going to see that was
the admission at the beginning. You're going to hear from Children's
Hospital and the ACLU that they assumed this was a pledge paid over a
period of time, because that's what they do because of tax deductions
and things of that nature.
So Amber does make...she makes a $250,000 payment to Children's
Hospital, then she also makes a $250,000 payment to Art of Elysium,
which is another charity that she worked for and used to feed and used
to do a lot of artwork with the Children's Hospital. She pays $350,000 to
the ACLU. Now, in addition to that, she also was dating Elon Musk by
this time. You'll find out that Mr. Depp is obsessed with Elon Musk. But
she's dating him, so he gives $500,000 to both of those charities in her
honor. Now, she doesn't claim that's part of the 7 million, but what
happens is that she makes her payments up through 2018, Mr. Depp
sues her March 1, 2019, in this litigation. She can't afford, right now, to

Transcription by www.speechpad.com Page 37 of 115

be making those pledges. She's got to defend herself. But she has every
intention of continuing to make those payments.
She has been a lifelong person who has served charities. She used to
volunteer at Children's Hospital three times a week when she could.
She's very much that kind of a person, and she intends to. And both
ACLU and Children's Hospital will tell you they have no reason to
believe she won't be good on her pledges. There's nothing that required
her to do a certain amount at a certain time, and she will give it to them
once she's able to afford it again.
Now, let me talk about the counterclaim for a minute, and then I'm going
to...I have to promise to let you go at some point, don't I? So Mr. Depp
has decided...you heard from Ben, you're going to see some really,
really terrible text messages from Johnny Depp on how he viewed
Amber Heard. He calls her some horrific names. But in the summer of
2016, he vows. He vows he's going to haunt her. He vows she's going to
suffer global humiliation. He says he's going to live in her, and she will
never forget him. And he meant it.
So in the summer of 2018, you heard Ms. Vasquez say that he wants to
clear his name, he can't be called a wife-beater, etc. But an article, an
op-ed, appeared on the Sun Times in London that called him a wife-
beater. It was written by Dan Wootton, the CEO, or yeah, the chief editor
of "The Sun" at the time, and he is writing because Johnny Depp is
being cast in Fantastic Beasts 3. And so the article is, "Why is JK
Rowling genuinely..."
So you will hear testimony...let me back up a little bit. So you have heard
from Mr. Depp's team that they are going to claim that Amber Heard
abused Johnny Depp. You also are hearing from them that he says that
she cut off his finger. When you look at the text messages and you look
at the emails, you will see that, in every one of those, Mr. Depp said to
Dr. Kipper, to David Heard, Amber's father, and to others, "I cut off my
finger." You will see that. He never, throughout the entire time he was
married to Amber, ever claimed that she hit him. He never ever,
throughout the time he was married to Amber Heard, claimed that she
cut off the finger. Only two years later does he, for the very first time,
start claiming she abused him and start claiming that she cut off the
finger. I'm going to ask you to look hard at the evidence, in this case,
because the evidence is going to show that it never ever came up
before,
Now, let's talk about the counterclaim for a few minutes. There's a few
statements here. Now, they've said, "Why are you suing Adam

Transcription by www.speechpad.com Page 38 of 115

Waldman?" You heard from Ben that Adam Waldman didn't come into
Johnny Depp's life until October 2016. He wasn't there for any of their
marriage. He doesn't have any personal knowledge of their marriage.
Everything he does is based on Johnny Depp. Johnny Depp used Adam
Waldman as his agent, and you will see a bunch of texts where he's
saying, "Yeah, man. He's going after these people. He's doing all this
stuff for me. He's suing my business manager. He's suing the lawyer.
He's going at...you know, he's doing all this." He's also going to the
press and making all kinds of statements about Amber Heard, and those
statements are as follows. And, Heather, if you can pull up the first.
The first one is Adam Waldman, Depp's lawyer, said afterwards, "Amber
Heard and her friends in the media use fake sexual violence allegations
as both a sword and a shield, depending on their needs. They have
selected some of her sexual violence hoax 'facts' as the sword, inflicting
them on the public and Mr. Depp." Now, there isn't any sexual violence
hoax. There isn't any hoax at all. But he's out there affirmatively stating
that she's got this conspiracy with her friends, and she's making these
things up. And it's very, very damaging and harmful to her. The
testimony will be that these Depp fans take and run with these things,
and you're going to hear from an expert who talks about, computer-wise,
when you search the hoax, and you see that it just spreads out into the
internet and to social media and generates a lot of negative publicity for
Amber.
Statement two, please. This was made in April of 2020. Depp's lawyer,
Adam Waldman, said the various discrepancies prove that nothing
Heard and her friends said about the events of May 21, 2016, could be
considered credible. "Quite simply, this was an ambush, a hoax. They
set Mr. Depp up by calling the cops but the first attempt didn't do the
trick," he told dailymail.com. "The officers came to the penthouses,
thoroughly searched and interviewed, and left after seeing no damage to
face or property. So Amber and her friends spilled a little wine, roughed
the place up, and got their stories straight under the direction of a lawyer
and publicist, and then placed a second call to 911."
Now, I've already told you all about the events of May 21, but you're also
going to hear from the second set of officers, there's no way that Amber
was trying, with her friends, to now get charges pressed against Johnny.
They cleaned everything up. They didn't want him in there. The absolute
opposite of what he says there.
The third statement, if you may. Depp's attorney, Adam Waldman, said,
"When Amanda de Cadenet," that's a friend of Amber's, "Amber Heard's

Transcription by www.speechpad.com Page 39 of 115

best friend and #MeToo activist recants her support for Ms. Heard and
testifies against her, you know we have reached the beginning of the
end of Ms. Heard's abuse hoax against Johnny Depp." Amanda de
Cadenet never testified against her, but that's not the part that we're
claiming is the defamation. It's abuse hoax against Johnny Depp. In
other words, in all of these articles, he's saying that she created an
abuse hoax, and you're going to make those determinations of whether
that's true or not.
But what we're going to show you is that that not only was tremendously
damaging to Amber, emotionally, and you're going to hear from an
expert on domestic violence and intimate partner violence, IPV, about
how those triggers happen when you have somebody who's gone
through all of this, and she's trying to heal, and she's trying to get past
this, and then, bam, you come in there, and you inflict this and put this
out in the public, and everybody runs. There's over a million...we're
going to tell you about a million different searches on the Twitter from
these different hits, how that impacts her emotionally every time
somebody calls her a liar for what she went through and how hard she
tried to protect Johnny Depp so that his children and the public never
found out about that Johnny Depp and how much that has harmed her
and how much emotionally that's impacted her and re-triggered and re-
triggered. But we're also going to talk to you about the reputational
damages for that.
Amber made it through the divorce. Then, she got cast in "Aquaman." A
few of you saw that. That was a blockbuster. It was the highest-grossing
movie in DC films history ever, up to this point. It hit over $1 billion in a
very short period of time. It was a mega, mega hit. She was moving
forward. Then, she gets hit with these defamatory statements and all of
the Depp followings and the computer and Twitter, and everything else.
Nobody wants to touch her. And you're going to hear from an expert
who's going to say, "Look at Jason Momoa. Look at Gal Gadot. Look at
other people who started coming up in those tracks from..." She was in
"Justice League" and then "Aquaman." Look what they're getting.
They're getting commercials. They're getting all kinds of different film
opportunities. These are the things that she would have gotten. Nobody
would touch her. She's a pariah. And we're going to ask you, as Ben
said, to hold Mr. Depp responsible. Enough is enough. But we're also
going to ask you to hold him responsible and try to fully and fairly
compensate Amber for what he has done to her. Thank you very much.
Judge Azcarate: Thank you, Ms. Bredehoft. Based on the time, ladies
and gentlemen, I think I'm going to release you for lunch a little early so

Transcription by www.speechpad.com Page 40 of 115

we can just start with the first witness when we get back from lunch. I
think it's just a natural break. So if you want to, go ahead and go with the
deputy. Just remember, don't talk to anybody about the case, and don't
do any outside research, okay? We'll be back here...let's get back at...I'll
give you a little extra time to 1:45, okay? Just to give you some extra
time downstairs, okay? All right. Thank you. If you'd go with Deputy Lucy
[SP]. All right. Does somebody have the motion in limines for me? I don't
think I've received those signed orders.
[inaudible 02:07:58]
Judge Azcarate: Okay, first thing after lunch, I get them?
Mr. Murphy: Yes, Your Honor.
Judge Azcarate: Okay. All right, that's perfect. Anything else? All right,
we'll be back at 1:45, then.
All right, are we ready for the jury, or do we have the motion in limines?
[inaudible 02:08:16]
Judge Azcarate: Okay, if I could just get those, I'd appreciate it.
Mr. Murphy: So we do have the order for Ms. Heard's motion in limine,
Your Honor.
Judge Azcarate: Okay.
Mr. Murphy: Mr. Depp's Mr. Moniz and I just agreed to it.
Judge Azcarate: Okay.
Mr. Murphy: I don't have it printed, but I can tell you, Your Honor, based
on the representation you gave me, it is agreed.
Judge Azcarate: Okay.
Mr. Murphy: And we will have it printed as soon as I can, but we're not
going to, obviously, hold the court.
Judge Azcarate: That's fine. Thank you very much.
Mr. Murphy: Thank you, Your Honor.
Judge Azcarate: Thank you, Mr. Murphy. All right, are we ready for the
jury, then? Okay.
[02:08:48]

Transcription by www.speechpad.com Page 41 of 115

[silence]
[02:10:02]
Thank you, ladies and gentlemen. All right. Your first witness.
Bailiff: Can we call in Christi Dembrowski?
Judge Azcarate: Christine Dembrowski? All right, Christine Dembrowski.
Is she outside?
Mr. Chew: She is.
Judge Azcarate: Okay. Christine Dembrowski.
[02:10:18]
[silence]
[02:10:42]
Female: Do you solemnly swear or affirm to testify truthfully in this case
under penalty of law?
Judge Azcarate: You have to verbally answer, ma'am.
Christi: Yes.
Judge Azcarate: Okay, thank you.
[02:10:53]
[silence]
[02:11:10]
Thank you.
Christi: Hi.
Judge Azcarate: Yes, sir.
Mr. Chew: Good afternoon, Ms. Dembrowski. Would you please state
your full name for the record?
Christi: Elisa Christine Dembrowski.
Mr. Chew: Ms. Dembrowski, what relationship, if any, do you have with
Johnny Depp?
Christi: He's my younger brother.

Transcription by www.speechpad.com Page 42 of 115

Mr. Chew: How much older are you than Johnny?
Christi: Two and a half years.
Mr. Chew: Ms. Dembrowski, I'd like to ask you a few questions about
your and Johnny's childhood. Where did you all grow up?
Christi: We were born in Kentucky, and we moved to Florida when we
were kids.
Mr. Chew: Who lived in your household with you and Johnny?
Christi: Our mom, our dad. We have an older brother, an older sister,
and Johnny and I.
Mr. Chew: Who was the youngest child in your family?
Christi: Johnny.
Mr. Chew: Would you please tell the jurors what your relationship with
Johnny was like when you were growing up?
Christi: Johnny and I were very close. With having the older brother and
older sister, we were the two younger ones, so we were really close, and
we, basically, were together all the time. We played together. We played
Hot Wheels. We, you know, played Batman and Robin, where we each
had a role in that. And he's probably going to be embarrassed that I say
any of this, but you know, we practiced, you know, karate kicks with
each other and chopping. We were just friends. We were like best
friends.
Mr. Chew: What was Johnny like as a young boy?
Mr. Rottenborn: Objection, Your Honor, 404.
Judge Azcarate: If you want to approach.
Mr. Chew: As I was saying, Ms. Dembrowski, what was Johnny like as a
little boy?
Christi: He was a shy, sweet little boy. He had a very caring personality,
but also, he was a little bit of a clown. He loved to, you know, play tricks
on us or try to scare us. He was a very typical, happy, little boy.
Mr. Rottenborn: Objection, Your Honor, move to strike, 404.
Mr. Chew: Your Honor, I'm going exactly where I said I was going.

Transcription by www.speechpad.com Page 43 of 115

Judge Azcarate: All right, I'll stay in the last part of her answer, and we'll
go forward from that.
Mr. Chew: Thank you very much, Your Honor. Ms. Dembrowski, how
would you describe your parent's relationship?
Christi: That was complicated.
Mr. Chew: Would you please explain to the jury what you mean when
you say your parent's relationship was complicated?
Christi: Our parents were...they had two completely different
personalities, where our father was also very kind, patient, loving, gentle
man, and our mom was the opposite. She was very high-strung, very
nervous, anxiety, angry. So they were completely opposite people.
Mr. Chew: What was your mother's first name?
Christi: Betty.
Mr. Chew: Did your mother, Betty, ever get angry with your father?
Christi: Yes.
Mr. Chew: How would your mother express her anger toward your
father?
Christi: Mom would...she would scream. She would yell at him. She
would hit him, call him names, that kind of thing.
Mr. Chew: Did your father ever hit your mother back?
Christi: No. Dad never reacted when mom would hit him or scream at
him.
Mr. Chew: If he didn't hit her back, how, if at all, did he react?
Christi: Basically, he would let her scream and get it out or hit and be
done. And the way that you dealt with my mom...the way that he dealt
with my mom was he always tried to keep the peace. So he never
wanted to...you know, he didn't want to engage in anything. So he was
very, you know, sort of...he would step back. And whatever it was that
she was angry about, he would try to go ahead and make sure that he
took care of whatever she was insisting that he did.
Mr. Chew: Is it fair to say he did what she wanted?
Christi: Yes, it's very fair to say he did.

Transcription by www.speechpad.com Page 44 of 115

Mr. Chew: What, if anything, did you and Johnny do while your mother
was hitting or attacking your father?
Christi: We would leave the area. We would run and hide. We would go
to our room, you know. Either we'd go to our room together or, you
know, depending on where we lived, you know, if our room was close,
we would sort of run off and get away from it.
Mr. Chew: How did your mother treat you and your brothers and sisters?
Christi: Well, there's a similarity, I'm sorry, in how she treated dad. Again,
she was very anxious, high-strung. She screamed, she yelled, she hit,
she threw things, she called us names. You know, we each had our own
little special set of names, some we wouldn't repeat, but... So she gave
each one of us a name. My name, for example, was Violet, which, to
some people, it wouldn't seem like it's anything, but Violet was my
father's mother, and my mom hated my father's mother. So that was my
special name, one of them.
Mr. Chew: Did your mother have any special names for Johnny?
Christi: Yes, she did. She had a few, again, some, to not repeat. Her
favorite, I think, was she called him One Eye, and she called in that
because, when he was young, the doctors thought he had a lazy eye, so
they would put a patch on his good eye so that they would strengthen
the other eye. So she used that as, you know, a way to find a new fun
name for him.
Mr. Chew: How did Johnny respond when your mother would call him
One Eye? He didn't respond in any negative way. Those names
were...they were just a way of life. We got used to them. We accepted
all of it.
Mr. Chew: Putting aside the names, did your mother ever get angry with
you?
Christi: Yes.
Mr. Chew: Did your mother ever get physical with you?
Christi: Yes, she did, but I was also very quiet, very shy, and I learned
early on to stay back. So I was more in the background because I would
constantly sort of stay in the background to stay away from trouble.
Mr. Chew: Ms. Dembrowski, when she, your mother, did get physical
with you, what forms did that take?

Transcription by www.speechpad.com Page 45 of 115

Christi: Well, she would hit us. She would throw things. She would have
us go pick a switch, you know, off of a tree, you know, so that that would
be what she could hit us with and make sure that we got one that was
nice and green.
Mr. Chew: I'm sorry, I don't mean to interrupt. Why did it have to be nice
and green?
Christi: Well, if it wasn't a nice green switch, twig, it would snap. Those
didn't break. If you got a dry one, they'd snap. They don't work the same.
Mr. Chew: Did your mother ever get angry at Johnny?
Christi: Yes.
Mr. Chew: Did you ever observe your mother hitting Johnny?
Christi: Yes.
Mr. Chew: How, if at all, did Johnny react when his mother would hit
him?
Christi: He was a typical little boy where, if it hurt, he would cry. That was
it. I mean, for the most part, he just wanted to get away from it.
Mr. Chew: Did Johnny ever hit his mother back?
Christi: No.
Mr. Chew: What about when he got to be an older boy, did he ever resist
or hit her back?
Christi: No. No. No. When he was older, even if she hit or threw things,
he never went to that place. He always...he would get away. He would,
you know, leave the area, go to his room.
Mr. Chew: Ms. Dembrowski, did there come a time when you left the
family household?
Christi: Yes.
Mr. Chew: When did you leave the household?
Christi: I left when I was 17. I was pregnant and got married and moved
out into my own place.
Mr. Chew: How did it feel when you left the family to go out and go to
your own place?

Transcription by www.speechpad.com Page 46 of 115

Christi: I think there's a bittersweetness to it. I was really young. I had
just turned 17. But I was so looking forward to this new life that I could
create that was different from what we had at home. And so there was a
part of me that was really happy to be able to do this, really excited, and
there was another part that was sad because I left behind my little
brother and my dad.
Mr. Chew: If you could explain that a bit, how, if at all, did your
experience with your mother affect your ideas about what you intended
to do with your own family?
Christi: Really early on, as a young child, none of what was happening in
our home felt good. And so, as I got older, you know, both Johnny and I,
actually, we decided that, once we left, once we would have our own
home, that we were never going to repeat ever anything similar, in any
way, to our childhood. We were going to do it different.
Mr. Chew: So Johnny felt the same way?
Christi: Absolutely.
Mr. Chew: When you left the home to start your own family, who among
the original four children were left at home with your mother?
Christi: Johnny.
Mr. Chew: Did there come a time when your parents separated?
Christi: Yes.
Mr. Chew: Would you please tell the jury what happened?
Christi: There was...our father, one morning, decided to pack up
everything and leave early in the morning. We didn't know it at the time. I
don't think. But I didn't. I didn't live there. I was at work. And then I got a
call from my mom in the afternoon right after she got off work. She
called me, and I could...it was hard to understand her voice. She
sounded faint and kind of groggy, but she kept saying, "He's gone. He's
gone. He's gone." And I was trying to get out of her, "Was it dad?" And
she said, "Yes, your daddy." And I said, "Mom, are you okay? What did
you...what's going on, you know? Did you take your pills?" Because she
took what she called nerve pills, and she said she had. I asked how
many. She couldn't tell me how many she took, but I knew she was
getting fainter on the phone. And it was more clear to me that she was
not in a good way. So I called our friend, our parent's friend, actually,
who was a police officer, and told him that he needed to get to mom and
what was going on. And so he got an ambulance to get over there to her.

Transcription by www.speechpad.com Page 47 of 115

Mr. Chew: And this was after your father left?
Christi: Yes, this is the day.
Mr. Chew: Ms. Dembrowski, do you know why your father left?
Christi: I know, at the time, because I did try to speak to him after,
because mom continued to not do well. At the time, he said that they
had had the last argument that he felt that they could ever have. He felt
he needed to leave home this time. And to be honest, I didn't really
understand. It had been so many years that he had been taking all of
the, you know, all of her personality. And I didn't really understand
exactly, fully, what that last argument was, why it was so intense. We did
learn, many years later, in our adult life, that what he was referring to
when he said...
Mr. Rottenborn: Objection, move to strike all of that as hearsay.
Judge Azcarate: I guess the objection is hearsay.
Mr. Chew: Your Honor, again, I think it's not offered for the proof. It's
offered for the abuse and the culture in which...
Judge Azcarate: I'll sustain the objection.
Mr. Chew: Thank you, Your Honor. Did your mother recover after she
took the pills?
Christi: Yes. She continued to not be well, but she recovered.
Mr. Chew: And after that time, did she ever take more pills than she
should have?
Christi: She did, but she didn't do it to the degree that she had at that
point.
Mr. Chew: And going back to the incident that you described, do you
know where Johnny was at the time your mother took those pills?
Christi: Johnny was home.
Mr. Chew: Did there come a time...oh, excuse me. I'm sorry.
Christi: I'm sorry. I think he was sleeping at the time. I think he woke up
when mom came out and the ambulance came.
Mr. Chew: So he saw all of that?
Christi: Yes.

Transcription by www.speechpad.com Page 48 of 115

Mr. Rottenborn: Objection, foundation.
Mr. Chew: Did he see that? She testified he was in the home.
Judge Azcarate: He was in the home, but was she in the home? I guess,
how did she know? So I'll sustain to foundation.
Mr. Chew: Thank you. Did there come a time when Johnny left his
mother's house?
Christi: Yes.
Mr. Chew: And after Johnny...what did Johnny do when he left the
house?
Mr. Rottenborn: Objection, foundation.
Judge Azcarate: All right, I'll sustain his foundation. If you want to lay a
foundation.
Mr. Chew: Were you in communication with your brother at the time?
Christi: Yes, he came and lived with me for part of the time.
Mr. Chew: So I think that...so, what did your brother do after he left your
mother's house?
Christi: He, you know, lived in different places. He lived with me, and he
lived with another family.
Mr. Chew: Did you and Johnny continue to communicate with your
mother, Betty, after you both left the home?
Christi: Yes. Yes, we did.
Mr. Chew: And after what you have described, why did you and Johnny
continue to communicate with your mother?
Mr. Rottenborn: Objection, foundation is to Johnny.
Mr. Chew: I think she's already laid the foundation, they're very close.
She was in communication.
Judge Azcarate: I'll sustain the objection, if you want, for this particular
question.
Mr. Chew: Why did you continue to communicate with your mother?
Christi: Because she was our mom, and we loved her. I mean, we knew,
you know, even when we were younger, that things weren't...they didn't

Transcription by www.speechpad.com Page 49 of 115

feel right, you know. But what we understood was that, you know, mom
had her own upbringing, you know. So she had her own past, and the
way she was raised would affect the way she lived. And so, in our mind,
she was doing the best she could do, you know. We sort of treated it like
she did the best that she could do with the tools that she was given, you
know, from her life in the past. And what we decided to do was we just
decided to get new tools. We chose different tools from that.
Mr. Chew: And when you say "we," to whom are you referring?
Christi: I'm referring to Johnny and I.
Mr. Rottenborn: Objection, foundation is to whom.
Judge Azcarate: I'll overrule that objection. Next question.
Mr. Chew: Thank you, Your Honor. Did you ever live with your mother
again after you and Johnny had left the house?
Christi: I did. I did live with her briefly. She had gotten diagnosed with
asthma when we lived in Florida, and she needed to move to a drier
climate. So Johnny moved her to California, to Palm Springs, for the
drier weather, and I moved also so that she wouldn't be alone. So I lived
with her for a period then.
Mr. Chew: And if you could just please elaborate on what role, if any,
Johnny played in your mother's move to Palm Springs.
Christi: He was the only reason the move could happen. He purchased
her a home and paid to have everything moved out there.
Mr. Chew: Did there come a time when your mother ever left Palm
Springs?
Christi: She moved from Palm Springs to be a bit closer to where
Johnny and I lived in the L.A. area. She lived there for a bit, and then,
ultimately, she went back to Kentucky. She had...her siblings were still
there, and a couple of them weren't doing well. So she wanted to be
closer to them while she could.
Mr. Chew: And after she moved back to Kentucky from Palm Springs,
did there come a time when your mother became chronically ill?
Christi: Yes.
Mr. Chew: When was that?
Christi: 2011.

Transcription by www.speechpad.com Page 50 of 115

Mr. Chew: Would you please describe briefly what her health condition
was as of 2011?
Christi: Well, in 2011, she was living in Kentucky, and we received a call
that she had been diagnosed with the final stages of Parkinson's. But
then, when another doctor looked at her scans, they felt it was
something different. So we had the scans brought to a doctor in
California, and they suggested that she come out and see a neurologist
right away. So Johnny got a plane, a private plane, and he and I, we flew
to go pick her up and bring her back to California to start seeing the
doctors.
Mr. Chew: And when she moved back in 2011 to California, was that a
permanent move?
Christi: It became, basically, a permanent move. She still had her house
in Kentucky, in the hopes of, you know, her being able to go back and
forth, but her health, basically, kept her in California. So she lived here,
or there.
Mr. Chew: And by that time, 2011, when she's moved out to Los
Angeles, had her treatment of you and Johnny changed in any way?
Christi: Yes, mom softened as she aged. She totally softened. And once
your mother moved to Los Angeles permanently in 2011, what role, if
any, did your brother, Johnny, play in her caretaking?
Mr. Rottenborn: Objection, foundation.
Judge Azcarate: All right, I'll sustain as a foundation.
Mr. Chew: To what extent, if any, did your brother play any role in her
caretaking?
Judge Azcarate: I think that's still a foundation objection.
Mr. Chew: Do you have knowledge of whether your brother had any role
in her caretaking?
Christi: Yes.
Mr. Chew: Would you please explain to the jury? Because I think Her
Honor needs to hear whether there's a foundation.
Christi: Okay. I'm sorry. Yes, when we brought mom out, you know, over
time, she had multiple other illnesses that came up. And Johnny
was...he dealt directly with the doctors, like we did, hired private nurses
so that we could make sure that, you know, mom was taken care of, you

Transcription by www.speechpad.com Page 51 of 115

know. Basically, Johnny was...he took all financial responsibility for
anything and everything mom could need or want during this time, all
medical care, doctors, hospitals, nurses.
Mr. Chew: How do you know that?
Christi: I was directly involved.
Mr. Chew: Is it fair to say you saw Johnny do those things and have
those interactions?
Christi: Yes. Yes, I was there. I was directly involved in all of that.
Mr. Chew: Did you witness your brother having any interactions with the
doctors relating to your mother's care?
Christi: Yes.
Mr. Chew: How often, if at all, did your brother visit your mother, Betty,
after she came to live in Los Angeles in 2011?
Mr. Rottenborn: Objection, foundation.
Mr. Chew: Were you ever present with your brother and your mother
when you all were visiting?
Christi: Yes. Mom lived in a house that was, basically, across the street
from Johnny. It was a house that he has on his street. And I was there,
you know, quite a bit. Johnny was pretty much down there every day, a
couple of times a day. You know, mom, like, she would see them all the
time, you know. One of her favorite things was watching Johnny take the
kids to school and waving at them, because she never got to do that
before, so.
Mr. Chew: Who were your brother's kids?
Christi: Oh, Lily-Rose and Jack.
Mr. Chew: We'll get to that in a little bit. Did there come a time when the
family was considering putting your mother in a hospice?
Christi: There were conversations with the doctors that we should start
to consider that since we weren't 100% sure with the variety of
conditions that she had what we needed to do. The idea of hospice was
something that felt like, since we didn't know a time frame, the idea of
introducing new nurses or something at a certain point in someone's life,
where they recognize there's a difference, and that could be frightening
for them. So we didn't want to instill any fear. You know, Johnny's big on

Transcription by www.speechpad.com Page 52 of 115

mom not having fear. So instead, that's when we hired nurses so that
the nurses could be there 24/7, you know. And she would have people
continuously throughout her life that she knew, that they were friendly,
and you know, cared for.
Mr. Chew: Did you actually have a conversation with your brother about
the possibility of your mother going into hospice?
Christi: Yes.
Mr. Chew: Did he express an opinion about it?
Christi: Yes. Well, this is where it all comes from, because the
idea...again, the idea of hospice, which is an amazing thing, but for
someone who...when you don't know, with the variety of illnesses, you
don't know what the timing is, the idea of introducing it, new people, is
something that becomes almost a signal, you know. And this was a very
big discussion. This is why the nurses were hired.
Mr. Chew: Was this just one discussion, or was it a series of
discussions?
Mr. Rottenborn: Objection, calls for hearsay.
Mr. Chew: I'm not asking for hearsay, I'm just asking about whether it
was discussed once or a number of times.
Judge Azcarate: I'll overrule the objection. Go ahead.
Mr. Chew: Was this just one discussion, or were there more discussions
among you and your brother about how to care, how to best care for
your mother?
Christi: We had continuous discussions. As a matter of fact, I mean,
there were daily updates. He knew every day everything that was
happening with mom, whether he was in town, out of town, because he
was working or traveling. He had...I made sure, because it's hard when
you know that someone wants to be there, and they can't. So I made
sure to fill him in on everything.
Mr. Rottenborn: Objection, hearsay.
Mr. Chew: It's not offered for the truth of it.
Judge Azcarate: I'll overrule the objection. Go ahead.
Mr. Chew: Did you ever see Johnny's children, Jack and Lily-Rose, over
at your mother's house across the street from Mr. Depp?

Transcription by www.speechpad.com Page 53 of 115

Christi: Yes.
Mr. Chew: Ms. Dembrowski, I'd like to change subjects right now, if that's
all right, and ask you to please tell us a little bit about your work life. Did
there come a time when you worked in the entertainment industry?
Christi: Yes. I started working when we moved from Florida to Palm
Springs. This is why I lived for a short period with my mom. I ended
up...I got a job at one of the studios in Los Angeles.
Mr. Chew: Which studio was that?
Christi: It was Columbia Pictures. I was...my title was I was an executive
assistant to the executive vice president of comedy development.
Mr. Chew: And what were your job responsibilities when you started
there?
Christi: I handled my executive's daily schedule, meetings, budgets,
scripts, phone calls, and then, in addition to that, we had...there were
four other executives, and they had assistants. So my desk was also to
oversee those assistants. And when we had writers come in, I oversaw
those assistants as well.
Mr. Chew: It sounds like a big job.
Christi: It was a good job.
Mr. Chew: How long did you work at Columbia Pictures Television in that
role?
Christi: I think it was about a year and a half.
Mr. Chew: Why did you leave after a year and a half?
Christi: Columbia itself started folding different departments, and ours,
our comedy development being one of them. And so some of the
employees that worked there went to work for Sony or TriStar, other sort
of arms of the corporation. And I was the last one there, sort of wrapping
up the department to go on to my next job.
Mr. Chew: So after you wrapped up the transition, the closing up of the
department, what did you do in terms of your work life?
Christi: I went to work with my brother.
Mr. Chew: In what capacity? When you say your brother, to whom are
you referring?

Transcription by www.speechpad.com Page 54 of 115

Christi: I'm sorry. I'm sorry?
Mr. Chew: I'm sorry. When you say your brother, to whom are you
specifically referring?
Christi: I went to work with my brother, Johnny.
Mr. Chew: What type of things did you do for your brother, Johnny?
Christi: Similar things to what I was doing with the other boss that I
worked for before, but with Johnny, he was...I was helping him anyway
as a sister, bits and pieces, before I started working with him. So there
were things like travel and meetings, setting meetings, making sure he
had his scripts that were coming in, and he knew all the information
about them, and any kind of publicity stuff that he had to do. Because I
really started to do this job with him because there was one time that I
had gone to his house, and I was helping him get ready to go on a trip,
and his ticket, I read it out loud, and it said standby, and I said, "Why are
you on standby?" He had no one looking out for that kind of stuff, you
know, so I did all of that.
Mr. Chew: How, if at all, did your work for your brother change over
time?
Christi: Well, over time, it sort of grew. Well, not sort of, it did grow. His
agent...I worked sort of hand-in-hand with his agent, and you know, as
she got to know me more and I got to know her more, there were other
parts of her job, actually, that she would give to me. So instead of just
doing scheduling meetings and calendars and travel, now I become a
person who's talking to producers or, as it expands, all the executives at
the studios and studio heads and become a part of contract negotiation,
etc. It just grew.
Mr. Chew: What role, if any, did you play in dealing with Johnny's movie
contracts?
Christi: Movie contracts, because I know the history and because there's
a certain amount of parts of life that are important, you know, to a human
being, not just to an actor but to a human being, and I know the human
being, I was part of mostly negotiating parts. Like, there's an area called
perks, and perks means anything and everything that an actor would
need in order to perform his duties and in order, you know, to also move,
right, to the location to do the duty. So I was part of all important dates
that, you know, needed to be considered in a calendar, making sure the
house was what he needed to have for the family, the travel to get there,

Transcription by www.speechpad.com Page 55 of 115

making sure he had his staff, drivers, security. Pretty much anything
necessary was in that.
Mr. Chew: Ms. Dembrowski, can you give the jury some examples of
some of the things you put on the perks list?
Christi: Sure. It was really important, as Johnny had a family, it was
really important to be able to make sure that we were given the
opportunity to find the right accommodations and accommodations for
the children, a house that could give them a home away from home, with
a garden, all the travel to make sure that they all get there. There were
really important dates that we carved out in every contract for Johnny's
kids, for their birthday. He never wanted to miss their birthdays. So if he
wasn't able to be with them because of filming, it was built into the
contract that he had their birthday off, and he would have the day before
and the day after so that he'd be able to travel to get to them and then
get back to working. So in addition to that, I mean, there's quite a bit. We
also had it built in that if he was to be away from his kids filming, if the
kids couldn't travel and family couldn't travel to be there, we had in his
contract that he would be able to fly back to them from wherever he is
every two weeks. So he didn't go beyond every two weeks not seeing
his children, you know. It's that kind of stuff that, you know, was
important.
Mr. Chew: Ms. Dembrowski, do you know what a personal manager is in
the context of the entertainment world?
Christi: I do.
Mr. Chew: What is it, if you could explain it to the jury? Because I just
learned it myself.
Christi: Well, I believe it's basically a lot of what I was doing. They work
with their client on maintaining different items in their personal life, as
well as, you know, projects coming in, production, all of the
representatives. It's sort of a big scope of duties.
Mr. Chew: Has anyone ever referred to you as Johnny's personal
manager?
Christi: I have been called that before, yes.
Mr. Chew: Do you perform the responsibilities of being Johnny's
personal manager?
Christi: I did. I did.

Transcription by www.speechpad.com Page 56 of 115

Mr. Chew: Do you still work with Johnny?
Christi: Yes.
Mr. Chew: Do you also work with any of Johnny's companies? Or strike
that. Does your brother have any companies associated with him?
Christi: He has a production company called Infinitum Nihil.
Mr. Chew: What type of company is Infinitum Nihil?
Christi: It's a production company. We develop, you know, projects for
films or television, or you know, different things.
Mr. Chew: And putting aside your responsibilities as your brother's
personal manager, what role, if any, do you play in Infinitum Nihil?
Christi: I'm president of Infinitum Nihil.
Mr. Chew: When did you start working at an Infinitum Nihil?
Christi: From the beginning, in 2004. I think we started in July 2004.
Mr. Chew: And would you please explain to the jury some of your
responsibilities as president of Infinitum Nihil?
Christi: My duties as president were to...I oversaw everything within the
company, the staff, where we were developing projects, where, you
know, maybe there's a book that people want to develop into a film or a
TV show or different ideas. So I oversaw that, oversaw all of the
development, their schedules of meetings with different people to take
those projects out to pitch. There's so many tasks in that job, I don't
know how to really lay them out.
Mr. Chew: Ms. Dembrowski, when did the first "Pirates of the Caribbean"
movie come out?
Christi: I think it was 2003, I think.
Mr. Chew: What was your brother's role in Pirates?
Christi: He was Captain Jack Sparrow.
Mr. Chew: Fair to say that was the lead?
Christi: That was the lead.
Mr. Chew: How did the first "Pirates of the Caribbean" movie fair at the
box office?

Transcription by www.speechpad.com Page 57 of 115

Christi: It did very well. I think it surprised people and did very well.
People really...they loved, you know, the...they love the entertainment of
it, you know, the total ride.
Mr. Chew: Did the success of Pirates 1 change Johnny's career in any
way?
Christi: I would have to say yes. The success of Pirates 1, it
became...Johnny, with that role, and other studios and everybody seeing
the success of that film and how the audiences reacted to that character,
there was a whole lot more people wanting to be in business with him.
Mr. Chew: And did the success of Pirates 1 change his personal life in
any way, or his day-to-day life?
Christi: It did. It did. Because where, prior to that, you know, he was able
to go out somewhat, you know. He could, you know, go to different
stores, go to bookstores, go to restaurants. When Pirates 1 came out,
after that, he was much more recognizable now, you know. So many
people loved that character, and so he was much more recognizable. So
it became harder for him to go out in public without having a lot of
people come around that, you know, rightfully so, wanted to meet him.
But then, it also became really big, and so we had even people that
were chasing in cars. So we had, at that point, we had to get security
team to kind of come in and help us manage how this all works, you
know.
Mr. Chew: Who is Jerry Judge?
Christi: Jerry Judge was...he was basically Johnny's head security.
Mr. Chew: When did Jerry Judge start coming to work with your brother?
Christi: Well, we started working with Jerry Judge back in the '90s,
because Jerry had his own security company in London. And when we
would go over there for press or premieres, or whatever, Jerry was the
one, you know, that set everything up. And we became really close with
him back then. And as things grew with Pirates, we brought him over
more and more, you know, for some of the items that we had, some of
the work that he had, if it was a show or whatever, and brought him on.
And then he started just working, basically, on every film with us after
Pirates, probably, right around that time.
Mr. Chew: How long did Jerry Judge work with you and Johnny?
Christi: Well, again, we met him in the '90s, so, and around...Pirates is
what, 2003? And Jerry was with us up until we lost him.

Transcription by www.speechpad.com Page 58 of 115

Mr. Chew: When did you lose him?
Christi: We lost him a couple of years ago to cancer.
Mr. Chew: What was Jerry's relationship like with Johnny?
Mr. Rottenborn: Objection, foundation.
Judge Azcarate: All right.
Mr. Chew: Did you ever see Jerry Judge interact with your brother?
Judge Azcarate: Sustain the objection. That's the leading. The next
question, that's fine.
Mr. Chew: Thank you, Your Honor. What, if any, observations did...were
there any times when you saw your brother interact with Jerry Judge?
Christi: I saw the two of them interact quite a lot, and they loved each
other. They were like, you know...Jerry thought of him as his, like, son
and sometimes as a brother. They really did love each other and so
much respect both ways.
Mr. Rottenborn: Move to strike all of that.
Mr. Chew: I don't think there's any basis to strike that. I think it was most
responsive.
Judge Azcarate: I'll overrule the objection, go ahead.
Mr. Chew: Thank you, Your Honor. And I wanted to touch on something
you mentioned a few moments ago when you were referring to Mr.
Depp's children. I believe you said it was daughter, Lily-Rose, and son,
Jack. Who was the mother of Johnny's children?
Christi: Vanessa Paradis.
Mr. Chew: Did Johnny and Vanessa Paradis ever live together as a
couple?
Christi: Yes.
Mr. Chew: How long did Johnny and Vanessa Paradis live together as a
couple?
Christi: I think they were together 14 years, I think.
Mr. Chew: And did their children live with them during the 14 years?
Christi: Yes.

Transcription by www.speechpad.com Page 59 of 115

Mr. Chew: How much time would you say you spent with Johnny,
Vanessa, Lily-Rose, and Jack?
Christi: When they were in Los Angeles, I would say I saw them all daily.
Our office, where we work, our office is only...it was only 10 minutes
from their house. So I would make trips back and forth, or every day,
after work, I would go straight to the house. So I saw them daily.
Mr. Chew: Would you please explain to the jury what it was like
spending time with Johnny and his family?
Christi: It was great. It was great. It was a normal, happy family, you
know. You go there, and the kids are playing, and you know, making
dinner, everybody having dinner, cleaning up together, sitting around,
laughing. It was great.
Mr. Chew: Did you have occasion to see your brother interact with his
children?
Christi: Yes. Yes, I did.
Mr. Chew: What did you observe? What can you tell the jury about what
you observed?
Christi: I'm proud to say, he's one of the most devoted fathers, I think,
that I've ever seen. Like, everything in life was about the children. But
when he was with the kids, like, the attention that he would give them,
you know, it was just constant, playing with them, listening to them, you
know, laughing with them, reading to them, Arby's, I mean, you name it,
and he was there.
Mr. Chew: Did you ever observe Johnny treating his children the way
you saw his mother treat him when he was young?
Christi: No. No.
Mr. Chew: Have you ever seen Johnny hit either of his children?
Christi: No.
Mr. Chew: Have you ever heard your brother raise his voice at his
children?
Christi: No.
Mr. Chew: You may have touched on it earlier, and if so, I apologize.
How, if at all, did Johnny communicate with his children when he was
shooting a film?

Transcription by www.speechpad.com Page 60 of 115

Mr. Rottenborn: Objection, foundation.
Mr. Chew: Were you...?
Judge Azcarate: All right, I'll sustain the objection if you want to lay the
foundation.
Mr. Chew: Understood. Did you have occasion to observe...were you
ever with your brother when he was shooting a film?
Christi: Yes.
Mr. Chew: Did you have occasion to observe your brother
communicating with his children while you both were there on set?
Christi: Yes. Yes.
Mr. Chew: No, please, go ahead.
Christi: Excuse me. When Johnny was filming, most of the time, the
family was with him. The family would travel and go. You know, just like I
said earlier, we would get a house and garden, and all of that, to make
sure that there was a home. So his family was with him most of the time.
Mr. Chew: What about when the children got older and they started
going to school, did that change in any way?
Christi: It changed in that, you know, they didn't want to disrupt the
children's lives when they were going to school. So if dad had to go off
and go work, and the children stayed home, this is where we get
into...we still maintained a home for the family wherever he was filming,
you know, because they have the opportunity to come back and forth.
But at the same time, Johnny would...he would travel back every two
weeks, you know, to see his kids.
Mr. Chew: And when you say he would travel back, who was it who
made those travel arrangements?
Christi: I made the travel arrangements.
Mr. Chew: Did you have occasion to observe Johnny interact with the
mother of his children, Vanessa Paradis, over the 14 years they were
together?
Christi: Yes, I did.
Mr. Chew: Would you please tell the jury what you observed about the
interactions between Mr. Depp and Vanessa?

Transcription by www.speechpad.com Page 61 of 115

Mr. Rottenborn: 404, Your Honor.
Mr. Chew: This is not...this is directly...
Judge Azcarate: I'll allow observations. [inaudible 02:58:19].
Mr. Chew: Thank you very much, Your Honor. What did you observe
about Mr. Depp's interactions with the mother of his children?
Christi: They were a great couple. I mean, first, you could see that they
were friends. They just...they were happy together. You know, they got
along great. It was a happy, normal...
Mr. Rottenborn: Move to strike, Your Honor.
Judge Azcarate: I'll sustain the objection at this point, then.
Mr. Rottenborn: Thank you.
Judge Azcarate: All right.
Mr. Chew: Did you ever hear your brother yell at Vanessa?
Christi: No.
Mr. Rottenborn: Objection.
Mr. Chew: It's not leading.
Mr. Rottenborn: 404.
Mr. Chew: To what extent, if any, have...
Judge Azcarate: That wasn't the question, Mr. Chew.
Mr. Rottenborn: 404 is the main objection, Your Honor.
Judge Azcarate: Okay. I'll sustain on that objection. Next question.
Mr. Chew: What, if any, violence did you observe between...
Judge Azcarate: Go ahead, finish your question first.
Mr. Chew: Well, if I think you're going to sustain the objection, perhaps, I
should...
Judge Azcarate: Maybe we should move on, yes. Okay.
Mr. Chew: Okay. All right. Did Vanessa ever claim that Johnny ever
physically abused her?
Christi: No.

Transcription by www.speechpad.com Page 62 of 115

Mr. Rottenborn: Objection, foundation, calls for hearsay.
Judge Azcarate: All right, hearsay objection.
Mr. Rottenborn: And 404.
Mr. Chew: It's not offered for the proof of the...it's what she observed,
what she heard. She was the personal manager, Your Honor.
Judge Azcarate: That would be hearsay, I'll sustain the objection. Thank
you.
Mr. Chew: Did there come a time when Johnny and Vanessa separated
after 14 years?
Christi: Yes.
Mr. Chew: How would you describe their relationship today?
Mr. Rottenborn: Same objection, 404.
Judge Azcarate: All right.
Mr. Rottenborn: And calls for hearsay, as well, and foundation.
Mr. Chew: I don't think it calls for hearsay, Your Honor. She's his sister.
Judge Azcarate: I understand, but it's a character evidence issue, so I'll
sustain the objection.
Mr. Chew: Who is Amber Heard?
Christi: My brother's ex-wife.
Mr. Chew: When did you first meet Amber Heard?
Christi: I first met her when she came to the office for casting on Rum
Diary, probably late 2008, I think, somewhere in there.
Mr. Chew: Did you see Ms. Heard on set?
Christi: Yes.
Mr. Chew: What, if anything, did you observe?
Christi: When she was working on set, I mostly observed, you know,
some of the...you know, I was there for some of the scenes and in
between, you know. She was a bit sort of, like, standoffish, had all
people coming around her, but I don't really have that much time with
her on set.

Transcription by www.speechpad.com Page 63 of 115

Mr. Chew: When was Rum Diary actually released?
Christi: 2011.
Mr. Chew: Was Johnny in that movie?
Christi: Yes.
Mr. Chew: What role, if any, did you have with respect to Rum Diary?
Christi: I was one of the producers.
Mr. Chew: And after seeing Ms. Heard on the set in 2009, 2010, when
was the next time you saw Ms. Heard?
Christi: I think the next time I saw her was we were promoting Rum
Diary towards the end of 2011, I think. I was not able to go on the full
promotional tour where we do screenings for people around the country,
because my mom was sick, but I was able to attend the one in Los
Angeles. So I saw her at that event.
Mr. Chew: What did you observe? So you attended the premiere?
Christi: I attended the premiere and the dinner afterward, yes.
Mr. Chew: Would you please describe for us what you observed at the
premiere?
Christi: At the dinner.
Mr. Chew: At the dinner.
Christi: Because I sat outside at the premiere. I didn't actually watch the
movie. I'd already seen it. I sat at the same table with some of the other
people involved and the cast. So I saw Johnny and Amber. You know,
they were seated together. I saw them talking quite a bit, and she
seemed very friendly that night, yes.
Mr. Chew: Did there come a time when you learned that Johnny and
Amber were romantically involved?
Christi: Yes.
Mr. Chew: When was that?
Christi: I don't recall exactly. I know it was some time after the Rum
Diary premiere.
Mr. Chew: To what extent did you have occasion to observe Johnny and
Ms. Heard together early in their relationship?

Transcription by www.speechpad.com Page 64 of 115

Christi: I would see them...there were times when she would come and,
you know, visit our mom, you know. I would see her then. I would see
the two of them then. I didn't really spend a tremendous amount of time
with her.
Mr. Chew: Had you formed any impression of Ms. Heard at that time
based on your observations?
Christi: I did. I did. Look, I didn't know her very well, and I would spend
time...like I said, she would, you know, she would come to my mom's
house. I sat with her and my mom.
Mr. Rottenborn: Objection, 404, what was her impression of Amber.
Mr. Chew: Based on her observation. She's describing what she
observed, Your Honor.
Mr. Rottenborn: It doesn't matter. It's 404.
Mr. Chew: I don't think that's right, Your Honor. I think she's describing
what she observed.
Judge Azcarate: Right. You want to approach for a moment.
Mr. Chew: Did there come a time when your brother and Ms. Heard
started to live together?
Christi: Yes.
Mr. Chew: And when did that occur, approximately, if you recall?
Christi: I don't recall the timing. I don't recall the time frame. I believe
they had moved downtown to the Eastern Columbia Building, but I don't
remember exactly when that was.
Mr. Chew: What type of structure was the Eastern Columbia Building?
Was that a freestanding house, or was it apartments?
Christi: It's apartments, and he had the penthouses on the top floor.
Mr. Chew: How many penthouses did your brother own on the top floor
of the Eastern Columbia Building?
Christi: I think it was five apartments.
Mr. Chew: Do you know who lived in those five apartments when your
brother and Ms. Heard went to live there?

Transcription by www.speechpad.com Page 65 of 115

Christi: I know who lived down there. I know Isaac, a friend of Johnny's
named Isaac, lived down there. I know Amber's friend, Rocky, and her
boyfriend lived in one of the penthouses. Amber's sister, Whitney, lived
in one of the penthouses.
Mr. Chew: When you say Rocky, are you referring to Rocky Pennington?
Christi: Yes.
Mr. Chew: And was her boyfriend Josh Drew?
Christi: Josh Drew.
Mr. Chew: Did Rocky Pennington and Josh Drew pay any rent to your
brother?
Christi: No.
Mr. Chew: What about Ms. Heard's sister, Whitney, did she pay any rent
to your brother?
Christi: No.
Mr. Chew: Do you know why your brother allowed them to live rent free
at the ECB?
Christi: Because they were...
Mr. Rottenborn: Objection, foundation.
Judge Azcarate: Hold on. I'm sorry, ma'am.
Christi: I'm sorry.
Judge Azcarate: Foundation, we asked, "Do you know why?" So if she
knows, she can answer. I'll allow it. I'll overrule.
Mr. Chew: She was his personal manager.
Judge Azcarate: That's fine. Go ahead.
Mr. Chew: Did you arrange for handling a lot of your brother's bills?
Christi: I would give them to the business manager, but I believe they
were Amber's family and friends, that's why he let them live there.
Mr. Chew: How often did you see your brother when he was living with
Ms. Heard at the ECB penthouses?

Transcription by www.speechpad.com Page 66 of 115

Christi: We didn't see him as often. I didn't see him as often. He pretty
much stayed down there. He didn't come back, you know, towards
where we were in West Hollywood very often unless he had a reason to.
Mr. Chew: And on those occasions when you did see your brother, what
observations did you make?
Christi: He was always in a hurry when he was able to come back. You
know, he could never sit and spend the time, you know. It felt like he was
always trying to, you know, get back downtown. He just seemed so
much sadder. He did not seem himself. He was always...his person was
much just sadder.
Mr. Chew: In that time period, when your brother and Ms. Heard were
living at the ECB, did you have occasion to observe them together?
Christi: On occasion.
Mr. Chew: Would you please describe for the jury what you observed on
those occasions when you saw your brother and Ms. Heard together?
Christi: I mean, there's different occasions of...I've seen them together
when they come into the office. I mean...
Mr. Chew: When you saw them together, did they appear to get along?
Mr. Rottenborn: Objection, Your Honor, very leading.
Judge Azcarate: All right, I'll sustain this to leading. All right, next
question.
Mr. Chew: Did you ever witness them arguing?
Mr. Rottenborn: Objection, leading.
Judge Azcarate: All right, I'll sustain this, sustain this to leading.
Mr. Chew: In your capacity as Johnny's personal manager, do you know
whether your brother and Amber ever travel together?
Christi: Yes, they did travel together. I mean, there were times, you
know, when Johnny had to go do press or film, they travel together.
Mr. Chew: What type of travel arrangements did you make for the two of
them when they traveled together?
Christi: We would get a private plane that took them to whatever the
destination was and make sure that we had, you know, the hotel
accommodations taken care of. Part of what we did was to always make

Transcription by www.speechpad.com Page 67 of 115

sure that we anticipated, you know, everything. So we would do the
travel, the hotels, cars, drivers. I would make sure that there was an
extra hotel room, you know, for trips when they would go...
Mr. Chew: Why did you make sure there was an extra hotel room when
Johnny and Ms. Heard went on trips together?
Christi: Because their...
Mr. Rottenborn: Objection, the extent of the answer calls for hearsay.
Judge Azcarate: All right.
Mr. Chew: I don't believe it does, Your Honor.
Judge Azcarate: Okay, that's fine. You can answer, ma'am.
Christi: Oh, thank you. I booked the extra hotel rooms because, if
Johnny was at home or, you know, anywhere like that, he was able to...if
they argued, he was able to leave the room, leave the argument, and
go, like he's always done, and hide in a different room to get away from
it. When they were traveling for, you know, the different reasons, for
press, or whatever, and we'd book the hotel rooms, I wanted to make
sure that there was an extra room, you know, because it wasn't unusual,
I mean, for them to have an argument. So I wanted to make sure that
there was an extra room.
Mr. Chew: Did your brother ever have occasion to use that extra room
that you booked for him?
Christi: Yes.
Mr. Rottenborn: Objection, foundation. This calls for hearsay.
Judge Azcarate: All right, I'll sustain this foundation, if you want to lay a
foundation.
Mr. Chew: I think the foundation was she made all of the travel...well, I
can actually lay it through some other questions as well. She was a
personal manager. Whose idea was it to book an extra room for your
brother when he traveled?
Christi: It was my idea.
Mr. Chew: And why did you do that?
Christi: It was my idea because, you know, I saw a repeat happening in
life. When we were and arguments and fighting would start to happen,
our first thing was to go and hide and, you know, get away from it. And

Transcription by www.speechpad.com Page 68 of 115

since I recognized what felt to be a pattern, that was a repeat pattern
from his childhood, I wanted to make sure that there was a place that he
could do just that.
Judge Azcarate: Mr. Chew, the question was, "Did Mr. Depp ever use
the extra room?" and the objection was foundation. So if you want to lay
a foundation of how she would have known that he used that extra room
and it's not based on hearsay, that's the issue.
Mr. Rottenborn: And I move to strike that [inaudible 03:14:51].
Judge Azcarate: All right, I'll strike that. Okay, go ahead.
Mr. Chew: Thank you, Your Honor. Did you ever book an extra...did you
book your brother's hotel accommodations during the 14 years when he
was with Vanessa Paradis?
Christi: Yes.
Mr. Chew: Did you ever book an extra room when he was with her?
Mr. Rottenborn: Objection, leading.
Christi: No.
Judge Azcarate: Overrule. I'll allow that one. Go ahead.
Mr. Chew: If you could repeat it, I don't think the jury heard that.
Christi: I'm sorry. No, I did not.
Mr. Chew: Did you ever hear your brother and Ms. Heard argue?
Christi: No.
Mr. Rottenborn: Objection, calls for hearsay. Also, leading.
Judge Azcarate: I'll overrule that. Go ahead.
Mr. Chew: So you may answer that.
Christi: No.
Mr. Chew: Did you ever see or hear any physical altercation between
your brother and Ms. Heard?
Christi: No.
Mr. Chew: What can you tell us about what you did observe of your
brother and Ms. Heard together?

Transcription by www.speechpad.com Page 69 of 115

Christi: To me, when I saw them, to me, he was always trying to make
sure...he was always trying to make her happy. He always made effort to
sort of make her happy. I think she had a very...she has a very strong
personality, and my brother's personality came off much more soft, at
that point, to me.
Mr. Chew: Did you observe any occasions in which Ms. Heard was nice
to your brother?
Christi: Yes, I've seen her be nice to him.
Mr. Chew: Would you please explain that?
Christi: I've seen her be nice and offering to bring him a drink or get him
whatever. I mean, just typical, like, a typical nice, I've seen that.
Mr. Chew: Have you witnessed any occasions on which Ms. Heard
wasn't nice to your brother?
Christi: I have, actually.
Mr. Chew: Would you please describe those to the jury?
Christi: Yeah. On one occasion, because this one really staked with me,
on one occasion, I was at the office, and I had a meeting with Dior, who
had wanted to sit with Johnny and talk about, you know, working
together, and Amber had come in and asked if she was interrupting us,
and we said no. We weren't supposed to really talk about the meeting
with anyone, but Johnny told Amber that I had just had a meeting with
Dior and that, you know, they were interested in him. Her reaction to that
was she was in disbelief and sort of disgust, because she said, "Dior,
why would Dior want to do business with you? They're about class, and
they're about style. And you don't have style," you know. So it was the
insulting kind of taking away that one moment, you know. That insult is
there. You know, I've seen the insults, multiple times, actually.
Mr. Chew: What, if anything, did you hear Ms. Heard say about Mr.
Depp's physical appearance?
Christi: She called him an old, fat man.
Mr. Chew: How did he respond?
Christi: I believe he's heard her call him that himself.
Mr. Chew: Now, Ms. Dembrowski, I'd like to ask you about a specific
event that is relevant to this case, and just for the background, I'll say,

Transcription by www.speechpad.com Page 70 of 115

did there come a time in 2013 when your brother was working with Keith
Richards of the Rolling Stones on a documentary?
Christi: Yes.
Mr. Chew: Were you present?
Christi: Yes, I was present at the...
Mr. Chew: Was Ms. Heard there as well?
Christi: Yes.
Mr. Chew: If you could please tell the jury how physically close you were
or how far you were from Ms. Heard while the three of you were on the
set.
Christi: I was right next to her. They had gotten there, and I was close
enough that I hugged her and was standing next to her. It was a small
set.
Mr. Chew: And when you were standing next to her and when you were
hugging her, what, if any, marks or physical injuries did you see?
Christi: I didn't see anything.
Mr. Chew: Did you observe your brother's interactions with Ms. Heard
while the three of you were on the set?
Christi: Yes.
Mr. Chew: What, if anything, did you observe her doing?
Christi: They were fine. She was laughing and happy, and holding his
hand, and you know, leaning on him, hugging him.
Mr. Chew: Did your brother hug him back or hug her back?
Christi: Yes, but it was mostly her hugging.
Mr. Chew: And switching subjects from that time on the set, did there
come a time when you learned that Johnny was going to marry Ms.
Heard?
Christi: Yes.
Mr. Chew: And this is a little complicated so I'm just going to ask you in a
narrative form. I understand there was a wedding and that there were a
couple of ceremonies. If you could just please describe that to the jury.

Transcription by www.speechpad.com Page 71 of 115

Christi: There was a wedding celebration that was put together on the
island. So they had, like, a wedding ceremony on the island. But prior to
going to the island to do that, they actually got married in Los Angeles,
because they had to get married in Los Angeles because they couldn't
get married, you know, paperwork, etc., on the island. So they got
married in L.A.
Mr. Chew: How did you learn that they were going to get married?
Christi: We were already working on the celebration part, and I knew
that the date was...at some point, they were going to pick a date to try to
get married in Los Angeles, but I didn't know the actual date that had
been decided until he called me, which was pretty much right before the
date.
Mr. Chew: What was your reaction upon hearing from your brother that
he was going to marry Ms. Heard?
Christi: I was scared. I was devastated, actually, that it was going to
happen as quickly as it was being pushed for. I actually tried to talk him
into just waiting a little bit longer, just a little bit, and not rushing.
Mr. Chew: Why did you want him to wait a little bit longer?
Christi: There had been conversations about a prenuptial agreement
that had been going on for a while. And as the date was approaching,
you know, for the island ceremony, there was no success in the
prenuptial conversations. And I knew it was important. His
representatives had explained the importance, and I knew it was
important to him for his children. And we were rushing to do something
without his children being protected.
Mr. Chew: Specifically, if you could explain to the jury what involvement
you had in those discussions about a prenuptial agreement.
Mr. Rottenborn: Objection, there's foundations to discussion with them.
Mr. Chew: She's testified about her...
Judge Azcarate: I'll allow it, go ahead.
Mr. Chew: Thank you, Your Honor. What was your involvement in the
discussions involving a prenuptial agreement?
Christi: Mostly, it was...I spoke with the attorneys and the
representatives so that they explained the importance of it and they
explained the reasons behind it.

Transcription by www.speechpad.com Page 72 of 115

Mr. Rottenborn: Move to strike, hearsay.
Judge Azcarate: I'll allow it that.
Mr. Chew: That means you can keep going.
Christi: Okay. So, I'm sorry. I'm sorry. So that we could have further
conversation with Johnny, and there was an attorney that they
coordinated with for Amber. So that was where I was involved, in
coordinating that part.
Mr. Chew: Which side wanted a prenup?
Christi: Johnny's side wanted a prenup.
Mr. Chew: And I believe what you said may have gotten lost. Why did
Johnny's side want a prenup?
Christi: Well, the prenup was to make sure that his children were
protected.
Mr. Chew: That's Jack and Lily-Rose?
Christi: Jack and Lily-Rose, yes.
Mr. Chew: Did your brother and Ms. Heard ever sign a prenup?
Christi: No.
Mr. Chew: Why not?
Christi: Amber didn't sign it.
Mr. Chew: Did you end up, despite your misgivings, did you end up
attending the wedding between or the ceremony between your brother
and Ms. Heard on the island in the Bahamas?
Christi: Yes, I did, but I also attended the actual wedding in Los Angeles.
Mr. Chew: And that preceded the celebration in the Bahamas, is that
correct?
Christi: Yes. Yes.
Mr. Chew: Did you have occasion to speak with Ms. Heard either at the
ceremony, the formal ceremony in Los Angeles, or the celebration in the
Bahamas?
Christi: I did. At the actual ceremony in Los Angeles, they had the
ceremony at our mom's house, and at that ceremony, I didn't have

Transcription by www.speechpad.com Page 73 of 115

occasion to really speak with Amber. She, Rocky, and Whitney, I don't
believe, wanted necessarily to speak with me on that day. I did...after the
ceremony was done, I was standing not far from them, and they were
having a conversation. They were having a conversation, actually,
excuse me, about, should they leak the information that they had
already gotten married at the house to the press so that they
could...maybe they didn't have to worry about the island when they did
the celebration. And Amber actually reached out to me and said,
because I was standing seven, eight feet away from her, asked my
opinion, you know, what I thought about that, which I basically said I
didn't know why they would do it since all the information for the island
was already out, and then it wasn't going to help them. I didn't know why
they wouldn't want to leak it at all, but it was up to them.
I saw her on the island as well, but on the island, she was actually
extremely friendly when I got there. Because, if I'm honest, I debated
going. I didn't really want to. I almost didn't. But I took my dad. Dad
wanted to go, and I wanted to make sure that I showed up anyway,
because I wanted to make sure that, honestly, that my little brother
would know that I was going to be...I was always going to be around no
matter what. But Amber was extremely friendly and thanked me for
coming to her special day, you know. It was a very big day for her.
Mr. Chew: Can you remember any other interactions you had with Ms.
Heard or your brother on the island of the celebration?
Christi: Interactions on the island? Not really.
Mr. Chew: And when was the next time you saw Amber Heard after the
celebration on the island?
Christi: It would have been when she came back from Australia.
Mr. Chew: And I will get to that, Your Honor. Is it possible for us to take a
very quick break?
Judge Azcarate: Sure. Are you going to...you still have quite a bit of
direct left, I assume?
Mr. Chew: I do have a fair amount, Your Honor.
Judge Azcarate: Okay. All right. Ladies and gentlemen, why don't we go
ahead and have you take your afternoon break of 15 minutes, okay?
Again, don't do any outside research and not talk to anybody about the
case. I know you're going to hear me say it so much. Thank you.
Mr. Chew: Thank you, Your Honor.

Transcription by www.speechpad.com Page 74 of 115

Judge Azcarate: All right. I haven't said yet. So let's see. I want to make
sure...I haven't said yet. No, that's okay. I usually wait till the jury goes
out, so we can make sure. All right. So why don't we just go ahead and
make it at 3:30 then, so it's close enough? Take 15 minutes [inaudible
03:31:51]? Okay, we'll take it.
Mr. Rottenborn: Your Honor, may I just wait for one request?
Judge Azcarate: Sure.
Mr. Rottenborn: Would you mind instructing the witness, and I think this
will go for all the witnesses, that on the breaks, they're not to discuss
their testimony with anybody?
Judge Azcarate: All right. You understand that, ma'am, since you are,
right now, on the stand, you can't discuss this case, not even with the
attorneys, okay? So don't discuss it with anybody till we get you back
here in 15 minutes, okay?
Christi: Okay.
Judge Azcarate: All right. Thank you. Thank you. All right.
Are we ready for the jury? Okay. Are you ready?
Mr. Murphy: Just before he takes the witness back, Your Honor, you'll be
pleased, we have that second order fully endorsed, so.
Judge Azcarate: I am very pleased.
Mr. Murphy: Yes, both of them are completed.
Judge Azcarate: That's great. I'll have an entry for my diary. Why don't
you...Mr. Murphy? Thank you, Thank you so much.
Mr. Chew: Thank you, Your Honor.
Judge Azcarate: All right. Yes, sir. Yes, we're ready.
[03:32:44]
[silence]
[03:33:46]
All right. If we can just be seated and we're ready to start again. Okay.
Yes, Mr. Chew.

Transcription by www.speechpad.com Page 75 of 115

Mr. Chew: Thank you, Your Honor. Good afternoon, again, Ms.
Dembrowski. I'm told that both you and I need to speak a little closer to
our microphones.
Christi: I'm sorry. Okay.
Mr. Chew: Thank you. And when we took the break, I think you had just
testified that the next time you had seen Ms. Heard was when she had
just returned from Australia.
Christi: Yes.
Mr. Chew: What, if anything, did you discuss with Ms. Heard when she
returned from Australia?
Christi: Excuse me. We met for a late dinner, and she was telling me
that she and Johnny had had a fight in Australia. And I was trying to talk
to her about the idea that that kind of fighting is not normal. It's too
much, you know. It's not okay. But she told me that I needed to,
basically, get down off my cross and my mom business. She said that
Johnny liked that she was feisty, you know. She was feisty, and then he
loved it. And that Jerry Judge and I needed to stay out of her marriage.
So that was the basic conversation.
Mr. Chew: Did you respond at all when Ms. Heard told you to get off
your cross?
Christi: I just kept saying that fighting is not normal. This kind of fighting
is not normal.
Mr. Chew: How close were you to Ms. Heard when you were having this
conversation?
Christi: We were right next to each other, right? Like, right here.
Mr. Chew: Did you see any marks or any discoloration on her face?
Christi: No.
Mr. Chew: Now, Ms. Dembrowski, I'd like to shift gears again and ask
you about the period in April and May of 2016. If you could please let us
know, as of April 2016, what was the state of your mother's health?
Christi: Excuse me. Mom had been...she had been in the hospital for
quite some time, and...like, a long steady pace from November. So by
April, she was...we knew that she was towards the end of her life. So
that's what April basically was. And it went into May. In May, we gathered
everybody to come say goodbye to her.

Transcription by www.speechpad.com Page 76 of 115

Mr. Chew: How often, if at all, did you visit your mother in April 2016?
Christi: She was in the hospital. So I was with her pretty much every
day. I was a 24/7 when I wasn't, you know, at the office or something,
you know.
Mr. Chew: Did you ever see Johnny at the hospital?
Christi: Yes.
Mr. Chew: How often did you see Johnny at the hospital in April 2016?
Christi: I don't know how often I saw him. I mean, he would come and
see her regularly, even before that, when there was a period we were
trying to help her communicate, and he brought in different type/tools of
pens, pencils, drawing crayons, just to try to help her communicate. He
came as often as he could. He was there quite a bit.
Mr. Chew: And when you said you called the family together in May,
would you please explain what you meant?
Christi: We were told by the doctors that mom was at a point where
there was nothing else that we could do for her, and so that we should
start calling anybody that wanted to, you know, come and spend a little
bit of time and say their goodbyes. So we did that. We did that in May.
Mr. Chew: And moving ahead to May 19, 2016, what was your mother's
condition that day?
Christi: She was basically in a coma. She was medicated and just on
machines, life support, where it was, you know, slowly going away, on
May 19th.
Mr. Chew: How do you know that?
Christi: I was with her.
Mr. Chew: Did you see your brother in the hospital that day?
Christi: Yes.
Mr. Chew: What happened the next day, May 20th, 2016?
Christi: Well, mom passed away that morning. We had...all the family
was there. Johnny was there with his kids until the wee morning hours of
May, you know, May 20th. My kids, my sister, we were all there,
spending our last bits of time, and everybody else had gone home. And
mom passed away probably a few hours after that, maybe five, six hours
after that.

Transcription by www.speechpad.com Page 77 of 115

Mr. Chew: Who was with your mother when she passed?
Christi: I was.
Mr. Chew: Who, if anyone, told Johnny that your mother had passed?
Christi: Sorry.
Mr. Chew: Take your time.
Christi: I did. I called him, and I called our other siblings to tell them.
Mr. Chew: And I'm sorry, I know this is painful. How did Johnny react
when you told him that your mother had passed?
Christi: Well, he was sad, but also, there's a relief that, you know,
suffering is done, so. He was mostly trying to make sure that I was okay
and I was going to leave and not stay there and, you know, sort of take
on everything about myself.
Mr. Chew: So he asked about how you were doing.
Christi: Oh, yes, that became quite a big topic. Yes.
Mr. Chew: Ms. Dembrowski, did you see Johnny the next day, Saturday,
May 21, 2016?
Christi: I did. I had gone to his house the night we lost mom. I think we
all kind of gathered our children, right? And I had my sister with me. So I
had driven her back on Saturday, and we were going to go to the funeral
home. So while I was waiting for her, I went to go check on Johnny and
see if he was okay and wanted to go.
Mr. Chew: And did you check on Johnny Saturday morning, the 21st?
Christi: Yes. Yes, I went to see him, because he was...we had talked
about maybe he would also go to the funeral home. But when I got
there, he seemed upset because he and Amber had been fighting.
Mr. Chew: What else happened when you first met with your brother on
the morning of the 21st when you were talking about going to the funeral
home?
Christi: I just went to go see if he was going to go with us. I got there. He
was upset, excuse me, because they were fighting. I got upset because
of the day that was chosen to fight. But I went ahead and left and went
to the funeral home with my sister and then came back that evening.

Transcription by www.speechpad.com Page 78 of 115

Mr. Chew: Why were you upset about their fighting on that day, in
particular?
Christi: We had just lost our mom the day before. So I feel like, you
know, there might be the need for a little compassion, no fighting, on that
day.
Mr. Chew: Did Johnny end up going with you to the funeral home that
day?
Christi: No, I went ahead and went, and he was gathering his stuff,
because he had to go pick up some items because he was going to go
on tour.
Mr. Chew: Did you see Johnny again that day once you left him to go to
the funeral home?
Christi: Yeah, I came back. That evening, I came back. I was taking care
of my sister for a bit, and then, before I left to go home, I stopped at his
house to make sure that he was okay, you know. And I saw him then.
Mr. Chew: And what happened when you went over to see that he was
okay?
Christi: He was talking to a couple of people. You know, I saw him
briefly. He seemed to be all right. And I spoke to Jerry Judge, and they
had just come back from him picking up items down at the downtown at
the loft.
Mr. Chew: So when you met him the second day that time...strike that.
When you met him the second time that day on May 21, did you meet
with him at his Sweetzer house or at the ECB?
Christi: No, I went to the Sweetzer house. He had gone down to the
penthouse to pick up some of his stuff, because he was going to be
leaving, you know, to go on tour. And I just stopped by after they had just
gotten back.
Mr. Chew: And as of that time, the evening of May 21, your mother had
just passed, what plans, if any, had been made for a funeral service for
your mother?
Christi: We hadn't made any plans for a funeral service. We wanted to
wait until we could get, you know, all the friends and family, because we
weren't expecting the date, necessarily, but we wanted to wait till we can
get all friends and family to come together to have more of, like, a
dinner, like a celebration like mom would want at her favorite place. So

Transcription by www.speechpad.com Page 79 of 115

we waited. We decided to schedule it, like, a month or so out instead of
immediate.
Mr. Chew: So you had referred to your brothers having plans to go on
tour that next week, obviously, not knowing that his mother was going to
pass.
Christi: Right.
Mr. Chew: What, if any, other formal events had been planned for that
next week before he was going on tour?
Christi: Well, he had the premiere for Alice that was on the Monday
night. Mom passed on Friday. And the premiere was Monday night. And
then he was going to take a flight after that. Immediately after the
premiere, he had to get on a plane to go to New York to meet the band
and go on to Europe.
Mr. Chew: And when you say Alice, just so the jury may understand, if
you could please explain to them what Alice is.
Christi: Oh, I'm sorry. Alice and...I'm so sorry. Right now, I don't know if
it's "Alice Through the Looking Glass," maybe was that one's name or
the "Alice in Wonderland" Disney series, where he played Hatter.
Mr. Chew: And so that premiere for "Alice in Wonderland" was going to
be on Monday. And what day was Mr. Depp planning to go on tour with
his music band?
Christi: He had to be there Tuesday morning. So we had to schedule it.
It was very tight. We scheduled a plane for him immediately after the
premiere. He would get on the plane.
Mr. Chew: So he was expected to leave on Tuesday. So, how long was
he supposed to be on tour?
Christi: I believe it was a couple of months, something like that.
Mr. Chew: Going back to the premiere, how, if at all, did your mother's
passing affect the premiere of "Alice in Wonderland?"
Christi: We didn't anybody know that mom had passed away. We kept
that really close to just our, you know, just family and friends, because
he had to go to the premiere. And with the premiere, he's on the carpet,
and on the carpet, he does a lot. He does interviews, and it didn't feel
right on many levels to have him where people knew that mom had
passed away while he's trying to do interviews to sort of, you know, give

Transcription by www.speechpad.com Page 80 of 115

their condolences and their sympathies, and all of that. So we kind of
kept it just with us so that it wouldn't become, you know, a worldwide
thing, and he could just do what he was supposed to do and do his job.
Mr. Chew: Did you think he could handle hearing all that sympathy at the
premiere?
Christi: I didn't think he should handle, I didn't think. I thought it would be
very hard on him, you know. It would be very hard question after
question and condolences.
Mr. Chew: Did there come a time when Ms. Heard filed for divorce from
your brother?
Christi: Yes.
Mr. Chew: When was that?
Christi: I learned that she had filed on Tuesday morning after that
premiere. Tuesday morning, I was at the funeral home, and I got a call
from the attorney to let me know that she had filed.
Mr. Chew: Where was Johnny when you learned that Ms. Heard had
filed for divorce?
Christi: He was already in New York and getting ready to travel to
Europe for the tour.
Mr. Chew: How did you react, initially, when you heard from Mr. Depp's
attorney that Ms. Heard had filed for divorce?
Christi: I mean, I think, understandably, you know, the timing of this, it
made me sick, actually. It really made me feel ill. It made me sad,
frustrated. I can't even find the word to describe how I felt when I heard
that the divorce was filed the day after, you know...while I'm at the
funeral home.
Mr. Chew: You didn't think the timing of Ms. Heard's filing was
appropriate.
Christi: I did not. I thought something like that might have been able to
wait.
Mr. Chew: Did there come a time when you learned that Ms. Heard had
also filed for a restraining order against Johnny?
Christi: Yes. Yes. I think I heard that also from the attorney, I believe, the
day before she was...I think it was a Thursday, I think, I learned that one.

Transcription by www.speechpad.com Page 81 of 115

Mr. Chew: So this was two days after your brother had left for New York?
Christi: Yes. Yes. Because I was shocked at that. I was shocked at that
and concerned that he was out of town and didn't know if he needed to
be there. He was gone, you know. And I was asking the attorney, and
they said, "No, he doesn't have to be there. No one has to be there.
Amber won't be there. No one will be there, just attorneys. It's a very
simple process."
Mr. Chew: Did Johnny attend the restraining order hearing?
Christi: No, he was not in town. He wasn't in the country.
Mr. Chew: Did you see any press coverage of the restraining order
hearing?
Christi: Yes, I did.
Mr. Chew: Would you please tell the jury what you saw or read?
Mr. Rottenborn: Objection, calls for hearsay.
Mr. Chew: I'm not asking for the proof of what was in the articles. To
present sense, impression.
Mr. Rottenborn: Relevance. Why is it relevant?
Judge Azcarate: All right, I'll sustain it to hearsay and relevance.
Mr. Chew: Okay. Did you see press...was there press coverage of the
hearing?
Christi: There was a tremendous amount of press coverage.
Mr. Chew: Did you read any of it?
Christi: I did. I did. I did read some of it. You know, I saw some of it.
Mr. Chew: Putting aside the truth or falsity of what you saw, what did you
see?
Mr. Rottenborn: Relevance.
Judge Azcarate: And why is that?
Mr. Rottenborn: And hearsay.
Mr. Chew: Was the...?
Judge Azcarate: All right, I'll sustain the objection. Next question.

Transcription by www.speechpad.com Page 82 of 115

Mr. Chew: How did you feel when you read the press?
Mr. Rottenborn: Relevance, how the witness felt is irrelevant.
Judge Azcarate: What's the relevance, Mr. Chew?
Mr. Chew: I think it's relevant to her testimony, Your Honor, but I can
move on.
Judge Azcarate: Okay, I'll sustain the objection. Next question.
Mr. Chew: Moving ahead two years in time, did you see Ms. Heard's
Washington Post op-ed when it was published in December 18, 2018?
Christi: Yes.
Mr. Chew: What did you think Ms. Heard's op-ed was about?
Mr. Rottenborn: Relevance.
Mr. Chew: It's entirely relevant. They're trying to argue, somehow, that
people didn't understand what the op-ed meant. We heard in opening
where there was...
Judge Azcarate: Why don't you approach, please?
Mr. Chew: Yes, Your Honor.
[03:54:28]
[silence]
[03:54:49]
Ms. Dembrowski, have you had any discussions with your brother about
the op-ed?
Christi: Yes.
Mr. Rottenborn: Object to anything after the yes is hearsay.
Judge Azcarate: I'm not sure if it is or not.
Mr. Chew: It's a yes or no question.
Judge Azcarate: Okay. All right, next question.
Mr. Chew: As Mr. Depp's brother and as his personal manager, do you
have any understanding how the publication of the op-ed has affected
your brother's career?

Transcription by www.speechpad.com Page 83 of 115

Mr. Rottenborn: Objection, foundation, Your Honor, and hearsay.
Judge Azcarate: I don't know if it's hearsay.
Mr. Chew: Oh, I apologize, Your Honor.
Judge Azcarate: That's fine.
Mr. Chew: But she's worked with her brother for...
Judge Azcarate: I'll allow that. Let's see where the answer goes.
Mr. Chew: You may answer.
Christi: I'm sorry, would you mind asking it again?
Mr. Chew: Do you have an understanding of how the publication of the
op-ed has affected your brother's career?
Christi: Yes. The op-ed, as written, with the way it was written, the
wordings within the op-ed make it very clear of a time frame.
Mr. Rottenborn: Objection, Your Honor.
Judge Azcarate: Give direction to answer that question. Maybe you
should ask it again.
Mr. Chew: How has the publication of Ms. Heard's op-ed, putting aside
for a moment its relationship to your brother, its references to your
brother, how has it affected his career?
Christi: I believe there's a negative effect on anyone's career when
there's accusations, you know, as there have been.
Mr. Chew: How has it affected him personally?
Mr. Rottenborn: Objection, foundation.
Mr. Chew: She's his sister, Your Honor.
Judge Azcarate: I'll allow it, go ahead.
Christi: Personally, I know he doesn't want people to feel that he could
ever be that type of person, which he isn't, and to know that, actually,
that is something that is attached to him now, which trickles down to his
children, where I think that part, more than anything, is the part that has
bothered him, the fact that his children have to have this in their life.
Mr. Chew: Ms. Dembrowski, do you believe that your brother physically
abused Ms. Heard?

Transcription by www.speechpad.com Page 84 of 115

Mr. Rottenborn: Objection, Your Honor, relevance and foundation.
Judge Azcarate: I'll sustain the objection.
Mr. Chew: Do you believe that Ms. Heard is a public figure representing
domestic violence?
Christi: No, I don't. I believe the opposite.
Judge Azcarate: Excuse me, I'll sustain the objection.
Mr. Chew: Thank you, Your Honor.
Judge Azcarate: Thank you. You can strike that answer, please. Thank
you.
Mr. Chew: As his sister and as his personal manager for decades, are
you aware of any occasion on which any woman other than Ms. Heard
has ever accused your brother of any type of physical abuse?
Mr. Rottenborn: Objection, foundation, hearsay.
Judge Azcarate: I'll allow the answer.
Christi: No.
Mr. Chew: How has Ms. Heard's op-ed impacted your life?
Mr. Rottenborn: Objection, relevance.
Judge Azcarate: What's the relevance?
Mr. Chew: Thank you, Your Honor. That's all I have right now.
Judge Azcarate: Okay. All right, all drawn question, okay? All right. Cross
examination.
Mr. Rottenborn: Thank you, Your Honor.
Judge Azcarate: Yes, sir.
[03:59:50]
[silence]
[04:00:13]
Mr. Rottenborn: Good afternoon, Ms. Dembrowski.
Christi: Good afternoon.

Transcription by www.speechpad.com Page 85 of 115

Mr. Rottenborn: So I believe we covered some of this, but just want to
make sure. So you're employed at a company your brother owns, right?
Christi: Yes.
Mr. Rottenborn: It's called Infinitum Nihil?
Christi: Yes.
Mr. Rottenborn: Is that right? And it's Mr. Depp's production company?
Christi: Yes.
Mr. Rottenborn: And you're the president of that company, right?
Christi: Yes.
Mr. Rottenborn: And that is your only source of income, correct?
Christi: I have other projects that I work on on the side.
Mr. Rottenborn: It's your only job, right?
Christi: It's my full-time job, yes.
Mr. Rottenborn: Right. And job-wise, you don't have any other sources of
income other than Infinitum Nihil, right?
Christi: Other projects. I have the opportunity with other projects to make
more money.
Mr. Rottenborn: Okay. All right. Your Honor, may I approach?
Judge Azcarate: All right, if you could just show counsel what you're
approaching with.
Mr. Rottenborn: It's just a copy of her deposition.
Judge Azcarate: All right. I think he's just giving copies, Mr. Chew. Oh, I
assume it wouldn't be. Okay. Thank you. Yes, please.
[04:01:35]
[silence]
[04:01:51]
Mr. Rottenborn: Ms. Dembrowski, do you remember giving a deposition
in this case?
Christi: Yes.

Transcription by www.speechpad.com Page 86 of 115

Mr. Rottenborn: And just a couple of months ago, right?
Christi: I believe so, yeah.
Mr. Rottenborn: And you remember, before you started that deposition,
being under oath, right?
Christi: Yeah.
Mr. Rottenborn: Okay. And you swore to tell the truth.
Christi: Yeah.
Mr. Rottenborn: Okay. And you were asked questions by counsel for Ms.
Heard, and you gave answers, right?
Christi: Yes.
Mr. Rottenborn: Okay. Could you please take a look at page 19 of that
deposition transcript in front of you?
Christi: I'm sorry.
Mr. Rottenborn: And do you see, on page 19, line 8 through 10, you
were asked the question, "Do you have any other sources of income
other than from Infinitum Nihil?" and you answered no, job-wise, no.
Christi: Right.
Mr. Rottenborn: Do you see that?
Christi: I do.
Mr. Rottenborn: And was that testimony correct?
Christi: Yes.
Mr. Rottenborn: Okay.
Christi: But it's the same as what I said today.
Mr. Rottenborn: Now, you have a huge financial interest in your brother's
career, right? The money that Infinitum Nihil makes comes from money
that Mr. Depp makes, correct?
Christi: It hasn't always, historically, no.
Mr. Rottenborn: What else does it come from?
Christi: We've had deals with other entities, companies.

Transcription by www.speechpad.com Page 87 of 115

Mr. Rottenborn: And for the most part, the better your brother does in his
career, the more money Infinitum Nihil makes, though, correct?
Christi: I don't think it's exactly like that, no.
Mr. Rottenborn: And you have...your brother has done projects that
Infinitum Nihil has been the production company for, correct?
Christi: Yes.
Mr. Rottenborn: Okay. And you have a financial interest in that company,
correct?
Christi: I'm an employee.
Mr. Rottenborn: Okay. Are you employed by his other companies as
well?
Christi: I'm employed by Infinitum Nihil.
Mr. Rottenborn: Are you employed by the other companies that your
brother has?
Christi: No.
Mr. Rottenborn: Where do you receive your paycheck from? Infinitum
Nihil?
Christi: Infinitum Nihil.
Mr. Rottenborn: Okay. And you have a financial interest in how Infinitum
Nihil performs financially, correct?
Christi: I have a salary that I get. So that's not a financial interest, if
you're asking if I get a piece of the pie. No.
Mr. Rottenborn: You wouldn't consider salary financial interest, is that
your concern?
Christi: I consider it a salary, yes, but it sounds like you're asking
something different. I'm sorry. Maybe I misunderstood.
Mr. Rottenborn: Yeah. So the bottom line is you draw a salary from
Infinitum Nihil.
Christi: Yes.
Mr. Rottenborn: And that's your brother's production company, correct?
Christi: Yes.

Transcription by www.speechpad.com Page 88 of 115

Mr. Rottenborn: Now, you feel protective of your younger brother, always
have, right?
Christi: Yes.
Mr. Rottenborn: And you testified earlier today about Mr. Depp's
reactions to some of your mother's anger growing up.
Christi: Mm-hmm.
Mr. Rottenborn: How old was Mr. Depp during the periods you were
talking about? Like, when he was a kid, is that basically what you were
talking about?
Christi: The reactions to mom's anger began when we were children,
and we've had the same reaction always, was to leave.
Mr. Rottenborn: Right. And when you were testifying earlier about Mr.
Depp's reaction being to leave, you were referring to when he
was...before you left the house, when he was a kid, right?
Christi: Yes, but we left the house not too far apart from each other, but
yes.
Mr. Rottenborn: Okay. When Mr. Depp would leave, as a child, during
the times when your mother was angry at him, was he addicted to drugs
back then?
Christi: No.
Mr. Rottenborn: Was he addicted to alcohol?
Christi: No.
Mr. Rottenborn: You testified a little bit about Mr. Depp's former partner,
Vanessa Paradis. You were friends with Vanessa, right?
Christi: We were. It was a family, so.
Mr. Rottenborn: Right. You considered her family, Right?
Christi: Yeah. She was part of the family, yes.
Mr. Rottenborn: Right. And you were friendly with her?
Christi: Yes.
Mr. Rottenborn: You liked her?
Christi: Yes.

Transcription by www.speechpad.com Page 89 of 115

Mr. Rottenborn: You were happy that your brother was with her?
Christi: I was happy that my brother was happy.
Mr. Rottenborn: Yeah. And you didn't want to see him split up from
Vanessa, did you?
Christi: You know what, I wanted both of them to be happy. It didn't
matter to me if they split up or not.
Mr. Rottenborn: You were devastated when they split up, weren't you?
Christi: I don't think I was devastated.
Mr. Rottenborn: Were you happy about it?
Christi: No, I wanted my family to be okay.
Mr. Rottenborn: What were your emotions when you learned that your
brother was splitting from Vanessa?
Christi: If I had to say, I was probably, you know, a little sad for both of
them, but I mean, beyond that, I don't really recall big emotions.
Mr. Rottenborn: And you were sad because you were losing her as part
of what you just testified was your family, right?
Christi: No.
Mr. Rottenborn: You weren't sad about that?
Christi: No.
Mr. Rottenborn: Now, on May 21st, 2016, you were asked some
questions about that, and I know your mother's passing must have been
very tough. So I'm not going to ask specific questions about that. I'm
going to ask questions about the next day, just to make sure that I had
your testimony right. Can you remind me? You said you saw your
brother the morning of May 21st?
Christi: I stopped by there, at some point, yeah, in the daytime, in the
early part of the day.
Mr. Rottenborn: Approximately, what time?
Christi: I honestly don't remember.
Mr. Rottenborn: Was it before lunch?
Christi: I don't remember the timing. It was just daytime.

Transcription by www.speechpad.com Page 90 of 115

Mr. Rottenborn: It was daytime. And you testified that when you stopped
by there for the first time that day that you were upset because it
seemed like he and Amber had been fighting. Is that what you said?
Christi: I said that they had been arguing. They had been arguing. And
I've said that I didn't love that they were arguing on. It was a horrible day
to argue on.
Mr. Rottenborn: And that was...your testimony was that you were upset
that they had been arguing when you stopped by during the daytime,
right? Okay. Now, you have no understanding of any of Amber or Mr.
Depp's communications leading up to May 21st, correct?
Christi: I don't know that I have a lot of that, no.
Mr. Rottenborn: Okay. But your testimony is that when you stopped by
during the daytime on May 21st that they had been fighting and that
made you upset, is that right? I'm just trying to understand what you
testified to.
Christi: It's not that it made me upset. I found it upsetting.
Mr. Rottenborn: Did you ever become aware that they hadn't actually
seen each other or communicated at all before he came over at 8 p.m.
on May 21st?
Mr. Chew: Objection, Your Honor, foundation.
Judge Azcarate: All right, foundation.
Mr. Rottenborn: She's testified that she said that they were fighting
earlier in the day. I'm asking her if she ever became aware that they
hadn't actually seen each other or talked that day.
Mr. Chew: Strike, foundation.
Judge Azcarate: I'll allow the question, just go ahead.
Mr. Rottenborn: I'll ask it again. Did you ever become aware that Amber
and Mr. Depp hadn't seen each other or talked that day before he came
to the Eastern Columbia Building, the evening of May 21st?
Christi: No. I just know that when...what I understood was that they had
had a fight, whether it was over the phone or I don't know. They were
arguing.
Mr. Rottenborn: Now, when your mother was in the last days of her life,
in the hospital, Amber visited her, right?

Transcription by www.speechpad.com Page 91 of 115

Christi: Amber did come one time by herself, if that's what you're
referring to. She did come one time, shortly before Johnny was also
coming.
Mr. Rottenborn: And she visited her actually more than one time,
correct?
Christi: I don't recall her visiting on her own more than one time, no. I
remember her coming one time because I didn't know she was coming,
and Johnny was actually also coming.
Mr. Rottenborn: Right.
Christi: So they ended up there together.
Mr. Rottenborn: I guess I'm a little confused, because you just testified
that she only visited one time.
Christi: Alone. This is what I'm saying. I only remember the one time,
alone, where she showed up alone. I only remember one time. And
Johnny came shortly after she was there.
Mr. Rottenborn: And other times, she visited with Johnny or other
people, is that right?
Christi: She visited with Johnny sometimes.
Mr. Rottenborn: During the time that Amber and Johnny were together,
you became aware that he was using drugs and alcohol excessively,
correct?
Mr. Chew: Objection, beyond the scope [inaudible 04:11:44].
Judge Azcarate: All right.
Mr. Rottenborn: Your Honor, she's testified to what she observed during
their relationship. I think it's within the scope.
Mr. Chew: [inaudible 04:11:51] I think is beyond the scope.
Judge Azcarate: No, I'll rule the objection. You can ask the question. Go
ahead. Did you want to ask the question again?
Mr. Rottenborn: I do, yeah.
Judge Azcarate: Okay.
Mr. Rottenborn: During the time that Amber and Johnny were dating, did
you become aware that he was using drugs or alcohol excessively?

Transcription by www.speechpad.com Page 92 of 115

Christi: I became aware that he had been drinking. And during the time
they were dating, I became aware of, at one point, you know, a certain
medication, yes.
Mr. Rottenborn: And you form the opinion that, not only had he been
drinking, but he was drinking excessively, correct?
Christi: I don't know that I formed excessively, but he was drinking.
Mr. Rottenborn: You became aware that he was using booze, right?
Christi: I knew he was drinking, yes.
Mr. Rottenborn: And you knew he was using cocaine, right?
Christi: I never saw him do that, so.
Mr. Rottenborn: You became aware that he was using cocaine, correct?
Christi: I never saw him use anything like that. I became aware of people
saying that.
Mr. Rottenborn: Right. And you became so concerned about that that
you told your brother to stop using cocaine, correct?
Christi: I don't know that I remember telling him to stop using cocaine. I
think I might have told him anything that he was doing he should stop
doing.
Mr. Rottenborn: Heather can you pull up Exhibit 214, please? Your
Honor, I'll obviously move for admission before it's published to the jury.
Judge Azcarate: That's fine.
Mr. Rottenborn: I just wanted to make sure it wasn't going to be on their
screen.
[04:14:04]
[silence]
[04:14:31]
Can you flip it?
[04:14:32]
[silence]
[04:14:55]

Transcription by www.speechpad.com Page 93 of 115

Just trying to figure out how to rotate this, Your Honor.
Judge Azcarate: If it's coming from her computer screen, you have to
rotate it on there.
Mr. Rottenborn: I figured.
Judge Azcarate: All this is doing is mirroring whatever was on the
computer screen. There's nothing we can do.
[inaudible 04:15:05]
Mr. Rottenborn: Sorry for the delay, Your Honor. Appreciate your
patience.
Judge Azcarate: Yes, sir.
[04:15:13]
[silence]
[04:15:39]
Mr. Murphy: If I may, Your Honor, the issue is what's on the screens, not
on the laptops.
Judge Azcarate: Okay. I don't know. Do you want to unplug it and plug it
back in just to see, to the system?
[04:15:57]
[silence]
[04:16:24]
Mr. Rottenborn: All right, I think we have it.
Judge Azcarate: When you turn it off and on, it works at everything.
Mr. Rottenborn: That's right. That's the secret.
Okay. All right. That looks better. Ms. Dembrowski, I'd like to direct your
attention to the four texts in the middle of the page. If you look in the
From column, there's a name that says Christi Dembrowski, and it has a
number. Is that your number?
Christi: Yes.
Mr. Rottenborn: Okay. And are those texts from you to your brother,
Johnny Depp?

Transcription by www.speechpad.com Page 94 of 115

Christi: Yes.
Mr. Rottenborn: And those texts were sent on or about February 5th,
2014?
Christi: Yes.
Mr. Rottenborn: Okay. Your Honor, I'd move for the admission of
Defendant's Exhibit 214.
Judge Azcarate: Any objection to 214?
Christi: Can I just say something?
Judge Azcarate: No, just wait, ma'am. Just wait for a question.
Christi: I'm sorry.
Judge Azcarate: Yes, sir. All right, so you're moving in 214. We'll receive
it redacted, correct?
Mr. Rottenborn: Yes, Your Honor.
Judge Azcarate: Okay. Over objection? That's fine. And you wanted to
publish just the redacted parts, correct?
Mr. Rottenborn: Yes, Your Honor.
Judge Azcarate: Okay. That's fine. Right now, you just have the dates
up. Is that what you want to start with?
Mr. Rottenborn: Yes, Your Honor.
Judge Azcarate: Okay.
Mr. Rottenborn: Thank you.
Judge Azcarate: You can publish that to the jury. Okay.
Mr. Rottenborn: Ms. Dembrowski, just because we can only show part of
this page, do you see that these...you just testified these were text
messages between you and Mr. Depp, right? And do you see that these
text messages were sent on February 5th, 2014?
Christi: Yes.
Mr. Rottenborn: The bottom three? Okay. And those bottom three, you
just looked at when we saw the whole page, and I know it's a little
cumbersome for the jury not seeing that, but you testified that the bottom
three were text messages from you to your brother, right?

Transcription by www.speechpad.com Page 95 of 115

Christi: Yes.
Mr. Rottenborn: Okay. Heather, could you just scroll to the right, please?
That's good, thank you. So, on February 5th, 2014, you sent three texts
to your brother. You sent one that said, "Stop drinking," right?
Christi: Mm-hmm.
Mr. Rottenborn: You sent one that said, "Stop coke," right?
Christi: Yes.
Mr. Rottenborn: I assume you weren't talking about the soft drink, right?
Christi: It doesn't appear to be.
Mr. Rottenborn: You were talking about cocaine, correct?
Christi: I don't know what these are in reference to, so. I remember they
brought this up at my deposition, and these are something that...I don't
know. I don't know if there's more context to them. I don't know what
they're in reference to. I know what they say, but I don't know what
they're in reference to.
Mr. Rottenborn: And what they say is that, on February 5th, 2014, you
were telling your brother, Johnny Depp, to stop using cocaine, correct?
Christi: No. I wrote those words, but that's what I'm saying, I don't know
that I was telling him to stop doing that. You know, in context, it would be
different. It could be a different scenario.
Mr. Rottenborn: Well, let's take it word by word. Coke, when you wrote
coke, you meant cocaine, not the soft drink, right?
Christi: Yeah.
Mr. Rottenborn: Okay. And when you wrote pills, you meant prescription
pills, right?
Christi: Yeah.
Mr. Rottenborn: Okay. So you were telling him on February 5th, 2014 to
stop drinking, stop coke, and stop pills, right?
Christi: I wrote the words.
Mr. Rottenborn: And did you have any reason to believe, when you
wrote that, that Mr. Depp had been on a bender recently?

Transcription by www.speechpad.com Page 96 of 115

Christi: I don't recall writing this, so I don't recall the context of it. I
understand that the words are there, but I don't recall the timing or the
writing of it. I don't recall anything about it, necessarily.
Mr. Rottenborn: You weren't joking when you wrote that, right? It wasn't
a joke, right?
Christi: I probably was not joking, but you know, maybe I was repeating
something that someone else told me to write.
Mr. Rottenborn: You were telling your brother to stop drinking, stop
cocaine, and stop pills because you believed that he had a problem with
drinking, cocaine, and pills, correct?
Christi: I didn't believe he had the problem as much as someone else
was trying to make me believe that he had the problem.
Mr. Rottenborn: Did you have any reason to believe that Mr. Depp had
been on a recent bender?
Christi: I didn't witness benders. I don't...you know what I mean? So I'm
not involved in the benders.
Mr. Rottenborn: Understood. I'm asking, at the time when you sent these
three text messages, on February 5th, 2014, did you have any reason to
believe that Mr. Depp had been on a recent bender?
Christi: I couldn't tell you about February, whatever date that is, back
then, and what I would know at this moment.
Mr. Rottenborn: Did you have any reason to be worried about Mr. Depp
when you sent these texts?
Christi: Again, I don't know what was happening in life at that time. I
don't recall that period, the dates. I don't recall where we...I don't recall
anything about that time. These texts, I know what the words are, but I
don't know what the context is of them.
Mr. Rottenborn: Right. And so I'm asking you a question as best I can,
which was, when you sent these texts, did you have any reason to be
worried about Mr. Depp's use of alcohol, cocaine, or pills?
Christi: Again, I don't recall the time period of sending these texts, so I
don't know that I would have any reason at that time. I don't know.
Mr. Rottenborn: Would you have sent the text if you didn't have a reason
to be worried about his use of alcohol, cocaine, or pills?

Transcription by www.speechpad.com Page 97 of 115

Christi: I could send those three separate lines like that, three separate
texts, I could do that if it was...you know, there's different reasons that
maybe I could do that. It doesn't mean that was me giving him a
message.
Mr. Rottenborn: Have you ever sent texts to anyone else to tell them to
stop drinking, stop coke, or stop pills before?
Christi: Again, I don't know that I'm telling him to stop drinking, stop
coke, and stop pills. That's what I'm saying. It's the context of this.
Mr. Rottenborn: And I appreciate that, but that wasn't my question. My
question was, have you ever sent texts to anyone else in your life telling
them to stop drinking, stop coke, or stop pills?
Christi: I don't believe I've ever told anybody to stop doing any of those
things in a text message, but I also don't know that that's what I was
doing here, is what I'm trying to say.
Mr. Rottenborn: But you wrote those words to Mr. Depp, right?
Christi: I wrote those words.
Mr. Rottenborn: And you didn't love the behavior that Mr. Depp was
engaging in around this time frame, did you?
Christi: I don't know the time frame. I don't know what time frame you're
actually referring to.
Mr. Rottenborn: Well, in the days leading up on or around February 5th,
2014, you didn't love the behavior that Johnny Depp was engaging in,
did you?
Christi: I don't recall anyone's behavior from February 2014. I don't recall
February 2014.
Mr. Rottenborn: Would it refresh your recollection, perhaps, to see other
text messages that you sent on around this time to determine whether or
not you were worried about Mr. Depp?
Christi: If there's other context, I guess. I don't know.
Mr. Rottenborn: Why don't we do this? Heather, can you please pull up
Exhibit 210?
[04:24:52]
[silence]

Transcription by www.speechpad.com Page 98 of 115

[04:25:14]
Your Honor, may I approach?
Judge Azcarate: All right.
Mr. Rottenborn: Thank you.
[04:25:17]
[silence]
[04:25:32]
Ms. Dembrowski, do you recognize this document as a text message
chain between you and Amber Heard on February 3rd, 2014?
Christi: Yes.
Mr. Rottenborn: And you see the chain starts at about 5:20 p.m., right?
Christi: Yes.
Mr. Rottenborn: And there's messages from Amber to you are the ones
on the right, correct, in blue?
Christi: Yes.
Mr. Rottenborn: And messages from you to Amber are the ones in gray
on the left, right?
Christi: Yes.
Mr. Rottenborn: Okay. And if you go...well, take a minute and just read
that first page, please.
[04:26:12]
[silence]
[04:26:44]
Does this refresh your recollection about a text conversation you had
with Amber on or about February 3rd, 2014?
Christi: Well, I can see this is our text exchange.
Mr. Rottenborn: Okay. And does this refresh your recollection about
concern that you may have had about the behavior that Mr. Depp was
engaged in on or around that time?

Transcription by www.speechpad.com Page 99 of 115

Christi: Again...
Judge Azcarate: I'll allow it. I'll allow that question. Go ahead.
Mr. Rottenborn: I'll ask it again. Does this refresh your recollection about
behavior that Mr. Depp may have been engaging in around that time?
Christi: I remember this period and what Amber was believing that he
was doing, yes, at this period.
Mr. Rottenborn: Okay. And does this refresh your recollection about your
worry and concern for your brother, Johnny Depp, around this time?
Christi: I still don't recall having a severe worry around this time.
Mr. Rottenborn: Okay. Well, before you didn't recall having any worry, so
does this at least refresh your recollection that you had some worry?
Christi: Honestly, I don't recall having to worry, you know. I've had
worries in the years, but I don't recall having to worry at this time. I don't
recall it.
Mr. Rottenborn: Okay. So, did you have any reason to doubt what you
were reading from Ms. Heard in these texts?
Christi: To be honest, she would write things quite often or explain things
quite often, and it's a bit more dramatic, maybe, than what we
understood it to be or maybe even, sometimes, the instances were
different than what she was describing, so.
Mr. Rottenborn: But in any event, this conversation that you had with Ms.
Heard gave you concern enough to tell your brother stop coke, stop pills,
stop booze, right?
Christi: No, I don't think it did.
Mr. Rottenborn: It didn't. And I've asked this before, but we'll take a look
at this. Is it true, you didn't love the behavior he was engaging in around
this time, right?
Christi: Again, I didn't witness a lot of the behavior that people are...you
know, that you guys are referencing. I didn't witness a lot of it.
Mr. Rottenborn: Okay. All right. Take a look at page 2, please.
Christi: Okay.
Mr. Rottenborn: And just take a minute to read that, and then I'll have
some questions about both of the pages.

Transcription by www.speechpad.com Page 100 of 115

Christi: Mm-hmm.
[04:29:42]
[silence]
[04:30:01]
Mr. Rottenborn: Okay. What you had been told by Ms. Heard on the first
two pages of these texts gave you concern about Mr. Depp's behavior
and made you not love anything that he was engaging in, behavior-wise,
around this time, right?
Christi: What I had heard from her in these texts, I didn't really love
where life was at the time.
Mr. Rottenborn: Your Honor, I'd move for the admission of these two
pages, in their entirety, for the reasons that we discussed both as
impeachment of the witness.
Judge Azcarate: All right. There are other statements in here that I do
find as hearsay, so we can work with it. I'll reserve on that for this time
maybe, and we'll have other issues with it outside the presence of the
jury, and we'll work on redactions, okay?
Mr. Rottenborn: Okay, that sounds good. Can I ask her questions just
about her language?
Judge Azcarate: Okay.
Mr. Rottenborn: And then we can work on redactions.
Judge Azcarate: Yes, sir.
Mr. Rottenborn: Okay.
Mr. Chew: [inaudible 04:31:08].
Judge Azcarate: Okay. Yes, sir.
Mr. Rottenborn: On the first page, Your Honor...or I'm sorry. On the first
page, Ms. Dembrowski, you write, "Where are the kids?" Why did you
write that to Ms. Heard?
Christi: I don't know. I mean, I remember, they asked me that at the
deposition. I'm not sure.
Mr. Rottenborn: You wrote that because you had concerns about where
Mr. Depp's kids were at this time, right?

Transcription by www.speechpad.com Page 101 of 115

Christi: Well, if she was saying, "He wasn't home," I was asking where
the kids were.
Mr. Rottenborn: Right. Because you were concerned for the kids' well-
being, particularly, when Mr. Depp was in this sort of state, correct?
Christi: No, I was curious about where the kids were if he wasn't home.
Mr. Rottenborn: Were you ever concerned about the impact on the kids
of Mr. Depp's drug use and alcohol use?
Christi: No.
Mr. Rottenborn: Okay. So, when you wrote, "Where are the kids?" you
had no concern for their actual well-being, is that right?
Christi: The concern...it's not that kind of concern. She's saying, "He's
not home." I was wondering where the kids were so that they weren't
alone.
Mr. Rottenborn: When you wrote her, on page 2, "Do you want to come
to office to talk?" you wrote that because you were concerned about
what was going on with Mr. Depp at that point, right?
Christi: No, actually. I wrote that so that she could come to the office so
that we could talk about all of it.
Mr. Rottenborn: All of what?
Christi: Of her text.
Mr. Rottenborn: Your Honor, I'd ask for permission to publish the bottom
text on page 2 that I think...
Judge Azcarate: It's not up here. You just need her text.
Mr. Rottenborn: Sorry. And I guess, while she's pulling that up, I'd move
for partial admission of Exhibit 210 with redactions to be...
Judge Azcarate: Again, I'm going to reserve on that, okay?
Mr. Rottenborn: Okay.
Judge Azcarate: All right, that's... All right. I'm still going to reserve on the
admission of it, so I'm not going to show it to the jury at this time, okay?
Mr. Rottenborn: Okay. Okay.
Judge Azcarate: But you can ask your questions about it.

Transcription by www.speechpad.com Page 102 of 115

Mr. Rottenborn: Okay, thank you, Your Honor. When you wrote Ms.
Heard on February 3rd, 2014 at 5:42 p.m., Ms. Dembrowski, "Worry
about everything," you were telling her to worry about everything and all
the types of behavior that Mr. Depp was engaging in at that time, right?
Christi: I was not telling her to worry about anything. That's the way I
wrote. That sounds like I say, you know, "I worry about everything."
Mr. Rottenborn: You're saying that you're worrying about everything, is
that right?
Christi: Yes, as a whole.
Mr. Rottenborn: Okay. So, in contrast to what you testified a few minutes
ago, you actually were very worried around this time frame, correct?
Christi: I was worried about what life was, that's what I said.
Mr. Rottenborn: And the life that you were referring to here, what was
going on in life was Mr. Depp's drug and alcohol abuse, correct?
Christi: What was going on in life was someone who constantly wanted
to point out some sort of drug and alcohol abuse.
Mr. Rottenborn: Is that unfair for a spouse not to want their husband to
abuse drugs and alcohol?
Christi: It's not unfair at all.
Mr. Rottenborn: Yeah. So, was that a negative to you that Ms. Heard
didn't love that?
Christi: I'm sorry?
Mr. Rottenborn: Was that a negative to you that Ms. Heard didn't love
Mr. Depp's drug and alcohol abuse? Was that unreasonable of her?
Christi: To me, it was exaggerated, is the problem, so.
Mr. Rottenborn: It was exaggerated. But you testified that you personally
have no personal knowledge of your brother doing cocaine.
Christi: I never saw him do it, no.
Mr. Rottenborn: Okay. But you had enough concern to text him stop
doing coke, stop the pills, and stop the drinking, correct?
Christi: No, I really don't think that's what I was doing with him.

Transcription by www.speechpad.com Page 103 of 115

Mr. Rottenborn: What were you...you weren't talking about the Super
Bowl, right? You were talking about drinking, coke, and pills.
Christi: I understand. But the way it's written, and I know my writing, the
way it's written, I don't feel like what I was doing was me giving him an
order to do that. I wouldn't typically do that. So there's other context
somewhere, you know, for that.
Mr. Rottenborn: Right. And that's what we're trying to explore, is, what is
that context? Because you're very direct in those texts that the jury just
looked at, stop the booze, stop the pills, stop the coke. So if you weren't
telling him to stop the booze, stop the pills, and stop the coke, what were
you telling him?
Christi: I could have been telling him that, because I've had this
conversation before, I could have been telling him that in order to make
her not constantly accusing, this is what she would need.
Mr. Rottenborn: Right. You didn't write those words in your text, though,
right?
Christi: No, I didn't.
Mr. Rottenborn: Okay. And when you said in the February 3rd text
message exchange with Ms. Heard, "I don't love any of it. I really want to
be able to talk with him," that was you expressing concern about Mr.
Depp's drinking and drug use, correct?
Christi: That was me expressing concern about what life was, and there
was arguments all the time, and it felt like there was just constant
unpleasantness.
Mr. Rottenborn: Right. And would it be unfair...well, let me ask it this way.
That unpleasantness, to your knowledge, was caused, in part, at least,
by your brother's drug and alcohol abuse, right?
Christi: I don't know that.
Mr. Rottenborn: Did you ever reach your own conclusion that your
brother had a problem with drugs and alcohol?
Christi: I knew my brother was drinking.
Mr. Rottenborn: I'm sorry.
Christi: I knew my brother was drinking. But in terms of, like, drugs, you
know, honestly, there was...I had only one medication that I really knew
of that, you know, was an issue for him.

Transcription by www.speechpad.com Page 104 of 115

Mr. Rottenborn: And what was that?
Christi: I don't remember the name of the medication. It was a
prescription medication.
Mr. Rottenborn: What was it?
Christi: It was, like, a pain medication that he had been taking for a long
time.
Mr. Rottenborn: Okay. And that was what you were referring to when you
said, "Stop pills," was prescription pain medication, correct?
Christi: Again, I wasn't necessarily referring to anything in particular. I
know I wrote those words. I don't know the context of the words.
Mr. Rottenborn: Okay. But in any event, you don't dispute that, on
February 5th, 20...whatever date that was, on February 5th, 2014, you
wrote your brother, "Stop drinking," "Stop coke," "Stop pills," right?
Christi: I wrote those words, but I don't know the context of the words.
Mr. Rottenborn: Now, February 2014 wasn't the first time that you had
communications with Ms. Heard relating to concerns about drug and
alcohol abuse, right, by Mr. Depp, correct?
Christi: I don't know.
Mr. Rottenborn: Heather, if you could pull up Exhibit 163, please.
Judge Azcarate: What's the exhibit number? I'm sorry.
Mr. Rottenborn: Oh, I'm sorry, Your Honor, 163.
[04:39:17]
[silence]
[04:39:42]
While she's pulling that up, Ms. Dembrowski, let me ask you this. You
knew that Mr. Depp's drug and alcohol problem was affecting his
relationship with Ms. Heard, right?
Christi: I knew that she would say that. I mean, I knew that she would
say that she had issues with, you know, him with drugs and alcohol.
Mr. Rottenborn: Okay. And you knew from those communications that it
was negatively impacting their relationship, right?

Transcription by www.speechpad.com Page 105 of 115

[04:40:16]
[silence]
[04:40:33]
Christi: I knew that she would write me about them, and I know that she
would try to talk about them, but... And I know that she would say that
they were negatively impacting. I don't know that that was the whole
situation that they had going on, to be honest, though.
Mr. Rottenborn: Well, you didn't disbelieve her when she told you that,
right?
Christi: When she told me?
Mr. Rottenborn: What you just testified to, that drinking and drugs were
negatively impacting their relationship, you didn't disbelieve her, right?
Christi: Oh, I didn't necessarily think it was true, no.
Mr. Rottenborn: You didn't think it was true?
Christi: That it was negatively impacting their relationship, I didn't
necessarily think it was 100% true, no.
Mr. Rottenborn: Well, you just said true and then 100% true. So I'm
trying to figure out. I'm trying to figure out where you're going with this. Is
it your testimony today that you never believed Ms. Heard when she
would talk to you about Johnny's drugs and drinking?
Christi: No, I think you're taking it to an extreme.
Mr. Rottenborn: Well, that's what I'm trying to get at. I'm sorry if I am. So
just explain to me what...that's not your testimony, so...
Christi: I think she exaggerated things quite a bit.
Mr. Rottenborn: But you tried to help Amber deal with Mr. Depp's drugs
and drinking, correct?
Christi: I tried to make sure that I was helpful to Amber as best as I
could, yes.
Mr. Rottenborn: Okay. If you can look at the document in front of you,
Exhibit 163, please. This is a text exchange between you and Ms. Heard
on March 22nd, 2013, correct?
Christi: Yes.

Transcription by www.speechpad.com Page 106 of 115

Mr. Rottenborn: And do you remember, earlier, you testified about being
present during the filming of a documentary about Keith Richards?
Christi: Yes.
Mr. Rottenborn: This was right around that time frame, correct?
Christi: I don't know.
Mr. Rottenborn: Do you recall when that was?
Christi: I don't recall the dates.
Mr. Rottenborn: And actually, one thing I wanted to ask you about that
while we're at it is, you testified earlier about not seeing cuts or bruises
on her face, do you remember that? You have no knowledge whether
she was wearing makeup or not that night, right?
Christi: I don't recall if she was wearing makeup or not. She typically did
not.
Mr. Rottenborn: Okay. And you weren't specifically looking for cuts or
bruises because you suspected that Mr. Depp had abused her, right?
Christi: I would have no reason to look for cuts or bruises, but I would
think if they were there, I would see them.
Mr. Rottenborn: Okay. So if you look at page 1, Exhibit 163, and, Your
Honor, I'd move for permission to publish.
Mr. Chew: Your Honor, we object.
Judge Azcarate: I'm going to sustain that objection.
Mr. Rottenborn: I figured you would.
Judge Azcarate: Okay.
Mr. Rottenborn: But can I do the same thing and ask her about her
words to Ms. Heard? And then we can...reserving the right to publish it
to the jury, depending on Your Honor's ruling.
Judge Azcarate: You can ask her if it refreshes her memory about the
conversations you're trying to discuss, yes.
Mr. Rottenborn: Sure. Thank you. So, Ms. Dembrowski, do you recall
having a conversation with Ms. Heard on or about March 22nd, 2013, in
which Ms. Heard was expressing concerns to you about Mr. Depp's
behavior?

Transcription by www.speechpad.com Page 107 of 115

Christi: No. I don't recall dates, so no.
Mr. Rottenborn: Okay. Why don't you go ahead and take a look at this
document, please? And let's just...let's start with...just tell me when
you're done with page 1, please. Oh, Ms. Dembrowski, I think that's you
on the screen, which is okay if you want to mark it up.
Judge Azcarate: We can clear it up. We got it.
Christi: I didn't...
Mr. Rottenborn: Oh, I'm sorry. Oh, okay. Doing their own redactions.
Judge Azcarate: Okay.
Christi: Okay, I've read it.
Mr. Rottenborn: Okay. So when you texted Ms. Heard...well, first of all,
does this refresh your recollection about a conversation that you and
Ms. Heard had on March 22nd, 2013 relating to Ms. Heard's concerns
about Mr. Depp's behavior?
Christi: It really doesn't, but I see it here.
Mr. Rottenborn: But you don't dispute that it is a conversation that the
two of you had.
Christi: This is a text exchange between the two of us, yes.
Mr. Rottenborn: Okay. When you wrote, "Don't be sorry! I am not
completely sure if what is going on or why, but I don't love what it is,"
what did you mean by that?
Christi: I'm not 100% sure. I believe I probably meant, once again, you
know, how life was.
Mr. Rottenborn: Right. Life including Mr. Depp's conduct toward my
client, Amber Heard, right?
Christi: Yeah.
Mr. Rottenborn: Okay. And when you wrote, "It is sad and I'm sorry you
guys are going through this. I'm here if there's anything I can do," you
were talking about the chat, you were sad that they were going through
the challenges that drugs and alcohol, on behalf of Mr. Depp, were
posing to their relationship, correct?
Mr. Chew: Objection, Your Honor.

Transcription by www.speechpad.com Page 108 of 115

Judge Azcarate: I'll allow it. She can answer it.
Christi: I don't think that I'm saying that I'm sad about that. I'm saying
that I'm sad, you know, about whatever it is that, you know, that they're
going through. But I don't know exactly what it is that they're going
through.
Mr. Rottenborn: Right. And right two texts underneath that, Ms. Heard
tells you what they're going through, right?
Christi: She does go into about, yeah, what they have going on.
Mr. Rottenborn: And then, below that, you say, "I think, with anyone in
that place, confrontation, unfortunately, doesn't help and sometimes
conversations can seem like confrontations," do you see that?
Christi: Mm-hmm.
Mr. Rottenborn: Were you suggesting to Ms. Heard that she shouldn't
have a conversation with Mr. Depp about what drugs and alcohol did to
him because it could seem like a confrontation?
Christi: No. No, I was not suggesting that at all.
Mr. Rottenborn: What did you mean by it?
Christi: Honestly, what I was trying to do is trying to...Amber, Ms. Heard,
she could be very, very vocal, and so what I was trying to do was, if they
were having a conversation, if it wasn't going well, I was trying to tell her
that, you know, maybe, you know, sometimes conversations, if you're
vocal, really loud, they're more confrontational. Like, just whatever it is,
just have a nice, easy conversation.
Mr. Rottenborn: Okay. Well, let's just go to the...I just want to look at one
more text on the top of the next page. Heather, please. When you write
Ms. Heard on March 22nd, 2013, you say, "Disagreeing, reasoning,
nudging, all can seem like confrontations. I am not sure of the volume or
when some is likely to wear off?" First of all, when you were talking
about "volume or when some is likely to wear off," you're talking about
drugs or alcohol, correct?
Christi: She said in the text prior, right?
Mr. Chew: Your Honor, direction of hearsay.
Mr. Rottenborn: I'm asking...
Mr. Chew: That's the problem.

Transcription by www.speechpad.com Page 109 of 115

Judge Azcarate: No, I understand. I'll sustain the objection.
Mr. Rottenborn: And I'm asking what you're referring to, without referring
to Ms. Heard's text prior, when you say, "I'm not sure of the volume or
when some is likely to wear off," what are you referring to?
Christi: I don't know. I mean, that's what I'm trying to say, is she had all
kinds of things that she said in the text prior. I'm referring to, like, volume
of even just voices. Even you can see where I say, like, you know, the
nudging and all of that. You know, there was a certain way that you
learned to try to talk with Amber to keep things calm.
Mr. Rottenborn: Okay. And when you said...
Mr. Chew: [inaudible 04:48:57].
Mr. Rottenborn: I thought she was.
Judge Azcarate: All right, [inaudible 04:49:00].
Mr. Chew: [inaudible 04:49:01]
Judge Azcarate: Mr. Chew, that's fine. Thank you. I appreciate it. I
understand. I'll let her finish, first, her answer. That's fine, Mr. Chew.
Christi: Thank you. Thank you. There was a certain way that, you know,
ultimately, you learn to talk to Amber, you know, to sort of keep things
calm. So you would pacify her. You would sort of, you know, just go
along with all of her conversations, whatever, so that you could...we
would placate her all the time to keep things calm. That's what we did.
Mr. Rottenborn: And so, when you said, "Disagreeing, reasoning,
nudging, all can seem like confrontations," were you telling Ms. Heard
that she shouldn't voice any concerns about her significant other's drug
or alcohol abuse?
Christi: Voice any concerns to who?
Mr. Rottenborn: To him, that she shouldn't nudge him about it or try to
reason with him about drug and alcohol abuse or his behavior. Is that
what you were saying that she shouldn't do that because it might seem
like a confrontation?
Christi: No, she was more confrontational. She was much more
confrontational, always confrontational. And I was trying to say that all of
these things can be confrontational and maybe take it down a notch.

Transcription by www.speechpad.com Page 110 of 115

Mr. Rottenborn: Okay. So you shouldn't disagree or reason or nudge, is
that what you were saying?
Christi: No. In the way that I know that it would be done, she was much
more...she wasn't...you know, there wasn't a comforting conversation.
Mr. Rottenborn: I'm sorry. I'm sorry for interrupting. Were you done with
your answer?
Christi: I think so.
Mr. Rottenborn: Okay. Do you believe that disagreeing with someone or
trying to reason with them or nudging them justifies them getting
abused?
Mr. Chew: Your Honor, lack of foundation.
Judge Azcarate: As to foundation, I'll sustain as to foundation.
Mr. Rottenborn: Okay. Do you have any...have you ever disagreed with
or reasoned with or nudged anyone in anything in your life?
Mr. Chew: Your Honor, [inaudible 04:51:10] hypothetical.
Judge Azcarate: All right.
Mr. Chew: The exact words.
Mr. Rottenborn: I mean, these are the words that she wrote.
Mr. Chew: Explained today.
Judge Azcarate: I know...
Mr. Rottenborn: These are the words that you wrote to my client,
"Disagreeing, reasoning, nudging, all can seem like confrontations."
Judge Azcarate: I'll allow the question.
Mr. Rottenborn: Thank you.
Christi: I'm sorry?
Mr. Rottenborn: Have you ever disagreed or reasoned or nudged with
someone in your life?
Christi: Yes.
Mr. Rottenborn: Okay. Do you believe that doing any of those three
things would justify you're being abused?

Transcription by www.speechpad.com Page 111 of 115

Mr. Chew: Your Honor, this is...
Judge Azcarate: I'll sustain the question.
Mr. Rottenborn: Withdrawn.
Judge Azcarate: Sustain. Okay. Thank you. All right. How much more do
you have probably?
Mr. Rottenborn: A little bit.
Judge Azcarate: A little bit, okay, since it's 5:00.
Mr. Rottenborn: About an hour.
Judge Azcarate: All right, about an hour, okay. All right. Ladies and
gentlemen, since it's 5:00, we're going to go ahead and release you for
the day, okay? Just a reminder, as always, please don't do any outside
research, don't talk to anybody about this case, don't look at the news,
don't watch anything on TV, don't read the papers, and just have a good,
calm, peaceful night, okay? And we'll see you tomorrow, bright and early,
okay? Thank you.
Well, a hard copy of 210.
[04:52:23]
[silence]
[04:52:41]
Thank you. All right. Ms. Dembrowski, just a reminder that you are still
under oath and you're still testifying. So since you're still testifying, you
can't have any discussions with anybody, to include Mr. Depp's
attorneys or his legal team, okay?
Christi: Okay.
Judge Azcarate: All right. And we'll see you tomorrow morning, all right?
If you could leave the courtroom, I just have a few housekeeping matters
I need to take care of.
Mr. Rottenborn: And that includes Mr. Depp as well, correct?
Judge Azcarate: Correct, and Mr. Depp, yes, anybody, okay?
Mr. Rottenborn: Thank you.
Judge Azcarate: Just don't talk about your testimony to anybody, okay?

Transcription by www.speechpad.com Page 112 of 115

Christi: Yeah, okay.
Judge Azcarate: All right, that's fine. If you can have a seat outside the
courtroom, I just have a few housekeeping matters I want to take care
of.
[04:53:11]
[silence]
[04:53:40]
You can sit down, it's okay. If you want to stand up, that's fine. I just want
to... Let me finish this one issue first, okay? I'd appreciate it. All right,
going back to the text. So, on 163, are you still trying to admit that into
evidence? That was the last one.
Mr. Rottenborn: Yes, Your Honor.
Judge Azcarate: All right. And there's an objection to that. Okay. Okay,
good.
Mr. Chew: [inaudible 04:54:03].
Judge Azcarate: All right. Yes, sir. Anything further to say on 163?
Mr. Rottenborn: Well, I think, yes, two things. At a minimum, Ms.
Dembrowski's texts should be [inaudible 04:54:14] because those aren't
hearsay, even if we have to redact out all of Ms. Heard's texts, which if
that's what [inaudible 04:54:21] we can. The problem is and the reason I
think it's not hearsay is that it's impeachment under 607 A7...
Judge Azcarate: I understand your impeachment issue, and I
understand that. We'll go back to 210, and I think there's an issue with
impeachment there. But here, I don't see any impeachment basis to
have the extrinsic evidence in. You got the testimony in, but I don't see a
basis to have the extrinsic evidence.
Mr. Rottenborn: And I would still ask that her text, I mean, not through
impeachment, they're not hearsay but probative to this case that she's
expressing concern, and even the jury can't see context because she
can't see [inaudible 04:54:55].
Judge Azcarate: Since they couldn't have the context, I'm not going to
allow them in. So I'm going to deny...I'm going to sustain the objection to
163. As far as 210, the only impeachment basis was when she testified
that she didn't recall anything about a bender or him being on a bender.
So I think, for impeachment purposes, just the only part that comes in as

Transcription by www.speechpad.com Page 113 of 115

far as Ms. Heard's text, is the "JD is on a bender," and not even the last
part of the...that's it, okay? Everything else would have to be redacted.
Mr. Chew: [inaudible 04:55:29] 607 A7.
Judge Azcarate: I'm going to allow that, just that one part. That one part
of...everything else gets redacted as far as her text, Ms. Dembrowski's
text can come in, except you have to get rid of her identifying information
as far as her phone number, okay?
Mr. Rottenborn: And just to be clear, so [inaudible 04:55:50]
Judge Azcarate: That's it.
Mr. Chew: Your Honor, for the record, [inaudible 04:55:52].
Judge Azcarate: Okay, I understand.
Mr. Chew: ...also speculation.
Judge Azcarate: Okay. All right. That's fine. Noted. Thank you.
Mr. Rottenborn: If you want to redact [inaudible 04:56:00] bender, not the
last two words.
Judge Azcarate: That's exactly right, not the last two words, and not the
sentence above it, and not any of the sentences below it or any of the
other texts, but Ms. Dembrowski's texts come in, but you got to just take
out her phone number for me. Okay? So if you can give me...you owe
me that, and I'll allow the redacted one into evidence. And you can owe
that to me tomorrow, okay? And you also owe me 214 tomorrow too,
correct?
Mr. Rottenborn: Yes, Your Honor. On that one, can we redact the...if we
only show the last two columns and we redact the personal identifiers,
can we then show the other columns that correspond to the text?
Judge Azcarate: As long as the personal identifiers...was what the
objection was. So if you could do that for just the four...
Mr. Rottenborn: Yes. Yes, Your Honor.
Judge Azcarate: ...and get rid of the others, okay? All right. All right.
That's all I had. Yes, ma'am, you had something?
Ms. Bredehoft: May we approach?
Judge Azcarate: Okay.

Transcription by www.speechpad.com Page 114 of 115

Transcription by www.speechpad.com Page 115 of 115