May 2011
May 11
P.1387
10 You were asked questions about May
11 22nd.
12 A. Yes.
13 Q. Let me ask you this. You explained to Ms. Wass, when she
14 asked you whether you had ever seen Ms. Heard leave the
15 building without makeup, you thought for a little while and
16 you said, yes, you had seen her. Do you remember that?
17 A. Yes.
18 Q. On that day, on 22nd May, did you see Ms. Heard leave the
19 building as soon as you spoke to her?
20 A. Oh, no. She was, this was -- no, I left. I left the scene.
21 Q. Do you know whether Ms. Heard, if she put on makeup, put on
22 makeup in the car or anywhere else that day?
23 A. No, I would have no clue.
P.1388
4 Q. You say in your witness statement, just summarising, that you
5 saw her up close on May 22nd, you saw her up close again on
6 May 23rd, you saw her up close also on May 24th, and you saw
7 her up close again on either the 25th, you think, or even
8 maybe the 26th, but you are not entirely sure; is that
9 correct?
10 A. Sunday, Monday, Tuesday, Wednesday. Sunday, the first
11 interaction. Monday, her knocking on my door for me to take
12 the key, to see if I would take the key to let Hilda in to
13 clean the apartment. That is Monday. Tuesday, twice, her
Mar. 2013
March 2013
19 marks or swellings."
20 A. That is correct.
21 Q. How certain are you about that?
22 A. 100%.
23 Q. Now, you had known Ms. Heard for some time by May 2016, had
24 you not?
25 A. Since March 2016, I mean 2013.
P.1372
2 Q. 2013. They moved in in March 2013, so you had known her three
3 years and two months; yes?
4 A. Is that how long that is?
5 Q. 13 ----
6 A. From March 2013, from March 2013 is when I first met her, in
7 March 2013.
8 Q. I understand. Have you ever known her to go out to a party
9 without makeup on?
10 A. I would not know that.
20 MS. WASS: Yes. Mr. Baruch, I asked you, having known Ms. Heard
21 for three years and a bit, whether you had ever known her go
22 to a party or to an outside event without being made up;
23 I think you said you could not say that.
24 THE WITNESS: Yes, I would not know that. I do not know how many
25 parties she went to. I do not know, you know, if every time
P.1373
2 she went to a party. So, I could not tell you.
But when
12 you have known that she has been going to a party, have you
13 ever seen her without makeup?
14 A. Any time that I saw her go to an event, that she was decked
15 out in, she had makeup on.
16 MS. WASS: Had you ever known her leave the apartment block and go
17 to a public place without wearing makeup?
18 A. (Pause) I do not know. Yes. Yes.
March 2013
8 A. On my shoulder up here, yes.
9 Q. Visible or not visible?
10 A. Visible if I have no sleeves or if my shirt is off.
11 Q. When did you get the tattoo changed from "Winona" to "wino
12 forever", was it the beginning of 2013?
13 A. No, sir. The tattoo was altered in about 1993.
14 Q. 1993?
15 A. Yes.
16 Q. So, throughout your relationship in the 18 months or so before
17 2013, that is the incident we are talking about, the tattoo
18 had always read "wino forever"; yes or no?
19 A. Yes, that is correct.
20 Q. Was March 2013 the first time Ms. Heard had ever seen your
21 tattoo?
22 A. No, sir.
March 2013
8 A. On my shoulder up here, yes.
9 Q. Visible or not visible?
10 A. Visible if I have no sleeves or if my shirt is off.
11 Q. When did you get the tattoo changed from "Winona" to "wino
12 forever", was it the beginning of 2013?
13 A. No, sir. The tattoo was altered in about 1993.
14 Q. 1993?
15 A. Yes.
16 Q. So, throughout your relationship in the 18 months or so before
17 2013, that is the incident we are talking about, the tattoo
18 had always read "wino forever"; yes or no?
19 A. Yes, that is correct.
20 Q. Was March 2013 the first time Ms. Heard had ever seen your
21 tattoo?
22 A. No, sir.
March 2013
Incident 2: The Painting Incident/ Keith Richards Incident, March 2013
March 2013
18 Q. And there was a date in March 2013 when you were extremely
March 2013
P.1792
2 MS. LAWS: I think there is an e-mail exchange which I can go to
3 which indicates that Keith Richards was looking forward to
4 seeing you. That was on 20th March. Is this you in the
5 photograph with Mr. Richards?
6 A. Yes, it is.
7 MR. JUSTICE NICOL: Just a minute. (Pause) Which one are you,
8 please?
9 A. I am in between Johnny and Keith. That is my sister next to
10 Keith.
11 MR. JUSTICE NICOL: Yes.
12 MS. LAWS: Do you agree that there is absolutely no injury on your
13 face in this photograph?
14 A. I cannot tell in this photograph.
15 Q. When do you say the incident took place? Are you sticking
16 with 23rd March?
17 MR. JUSTICE NICOL: 22nd March.
18 MS. LAWS: 22nd March, sorry. Are you sticking with that date,
19 22nd March?
20 A. For the painting incident or the one that we called disco
21 bloodbath?
22 Q. The painting incident where you say you went to Keith
23 Richards' filming?
24 A. The painting incident took place on the 22nd.
25 MR. JUSTICE NICOL: 22nd March 2013?
P.1793
2 A. Yes, exactly.
3 MS. LAWS: Does this photograph show you before or after you were
4 hit by Mr. Depp?
March 2013
7 A. The 22nd.
8 Q. 22nd March, 2013?
9 A. Yes.
10 Q. Thank you very much indeed. As far as the painting incident
11 was concerned, what you said in your original statement was
12 that after the arguments, there was an episode of filming on
13 that date?
14 A. Yes, that is correct.
15 Q. With Keith Richards?
16 A. Yes.
17 Q. Was that the only date in March 2013 when there was filming
18 with Keith Richards?
P.2033
8 MS. WASS: How many incidents were there in March 2013 which
9 involved filming a documentary with Keith Richards?
10 A. At least three.
P.2052
6 Q. Mr. Depp accepts in his evidence that there was an occasion at
7 Orange Avenue when he politely, he says, asked you to remove a
8 painting done by Tasya van Ree which was on your bedroom wall.
9 Do you remember that part of the evidence?
10 A. I remember him saying that.
11 Q. Was it one of those two paintings that we see in those two
12 documents in the trial bundle?
13 A. Well, he defaced both and was upset about ----
14 MR. JUSTICE NICOL: No no. The question was whether you were able
15 to say whether the painting that Mr. Depp asked you to remove
16 was one of these two paintings.
17 A. Well, he did ask me to remove both of them, the one we have
18 been talking about the burning is the one that is part of the
19 text message screen grab between Mr. Hop, Johnny, and my
20 sister.
March 2013
7 A. The 22nd.
8 Q. 22nd March, 2013?
9 A. Yes.
10 Q. Thank you very much indeed. As far as the painting incident
11 was concerned, what you said in your original statement was
12 that after the arguments, there was an episode of filming on
13 that date?
14 A. Yes, that is correct.
15 Q. With Keith Richards?
16 A. Yes.
17 Q. Was that the only date in March 2013 when there was filming
18 with Keith Richards?
P.2033
8 MS. WASS: How many incidents were there in March 2013 which
9 involved filming a documentary with Keith Richards?
10 A. At least three.
P.2052
6 Q. Mr. Depp accepts in his evidence that there was an occasion at
7 Orange Avenue when he politely, he says, asked you to remove a
8 painting done by Tasya van Ree which was on your bedroom wall.
9 Do you remember that part of the evidence?
10 A. I remember him saying that.
11 Q. Was it one of those two paintings that we see in those two
12 documents in the trial bundle?
13 A. Well, he defaced both and was upset about ----
14 MR. JUSTICE NICOL: No no. The question was whether you were able
15 to say whether the painting that Mr. Depp asked you to remove
16 was one of these two paintings.
17 A. Well, he did ask me to remove both of them, the one we have
18 been talking about the burning is the one that is part of the
19 text message screen grab between Mr. Hop, Johnny, and my
20 sister.
March 2013
Ms Pennington�s vague account of what she allegedly saw in March 2013 was unconvincing.
March 2013
19 marks or swellings."
20 A. That is correct.
21 Q. How certain are you about that?
22 A. 100%.
23 Q. Now, you had known Ms. Heard for some time by May 2016, had
24 you not?
25 A. Since March 2016, I mean 2013.
P.1372
2 Q. 2013. They moved in in March 2013, so you had known her three
3 years and two months; yes?
4 A. Is that how long that is?
5 Q. 13 ----
6 A. From March 2013, from March 2013 is when I first met her, in
7 March 2013.
8 Q. I understand. Have you ever known her to go out to a party
9 without makeup on?
10 A. I would not know that.
20 MS. WASS: Yes. Mr. Baruch, I asked you, having known Ms. Heard
21 for three years and a bit, whether you had ever known her go
22 to a party or to an outside event without being made up;
23 I think you said you could not say that.
24 THE WITNESS: Yes, I would not know that. I do not know how many
25 parties she went to. I do not know, you know, if every time
P.1373
2 she went to a party. So, I could not tell you.
But when
12 you have known that she has been going to a party, have you
13 ever seen her without makeup?
14 A. Any time that I saw her go to an event, that she was decked
15 out in, she had makeup on.
16 MS. WASS: Had you ever known her leave the apartment block and go
17 to a public place without wearing makeup?
18 A. (Pause) I do not know. Yes. Yes.
March 2013
19 marks or swellings."
20 A. That is correct.
21 Q. How certain are you about that?
22 A. 100%.
23 Q. Now, you had known Ms. Heard for some time by May 2016, had
24 you not?
25 A. Since March 2016, I mean 2013.
P.1372
2 Q. 2013. They moved in in March 2013, so you had known her three
3 years and two months; yes?
4 A. Is that how long that is?
5 Q. 13 ----
6 A. From March 2013, from March 2013 is when I first met her, in
7 March 2013.
8 Q. I understand. Have you ever known her to go out to a party
9 without makeup on?
10 A. I would not know that.
20 MS. WASS: Yes. Mr. Baruch, I asked you, having known Ms. Heard
21 for three years and a bit, whether you had ever known her go
22 to a party or to an outside event without being made up;
23 I think you said you could not say that.
24 THE WITNESS: Yes, I would not know that. I do not know how many
25 parties she went to. I do not know, you know, if every time
P.1373
2 she went to a party. So, I could not tell you.
But when
12 you have known that she has been going to a party, have you
13 ever seen her without makeup?
14 A. Any time that I saw her go to an event, that she was decked
15 out in, she had makeup on.
16 MS. WASS: Had you ever known her leave the apartment block and go
17 to a public place without wearing makeup?
18 A. (Pause) I do not know. Yes. Yes.
7 March 2013
19 marks or swellings."
20 A. That is correct.
21 Q. How certain are you about that?
22 A. 100%.
23 Q. Now, you had known Ms. Heard for some time by May 2016, had
24 you not?
25 A. Since March 2016, I mean 2013.
P.1372
2 Q. 2013. They moved in in March 2013, so you had known her three
3 years and two months; yes?
4 A. Is that how long that is?
5 Q. 13 ----
6 A. From March 2013, from March 2013 is when I first met her, in
7 March 2013.
8 Q. I understand. Have you ever known her to go out to a party
9 without makeup on?
10 A. I would not know that.
20 MS. WASS: Yes. Mr. Baruch, I asked you, having known Ms. Heard
21 for three years and a bit, whether you had ever known her go
22 to a party or to an outside event without being made up;
23 I think you said you could not say that.
24 THE WITNESS: Yes, I would not know that. I do not know how many
25 parties she went to. I do not know, you know, if every time
P.1373
2 she went to a party. So, I could not tell you.
But when
12 you have known that she has been going to a party, have you
13 ever seen her without makeup?
14 A. Any time that I saw her go to an event, that she was decked
15 out in, she had makeup on.
16 MS. WASS: Had you ever known her leave the apartment block and go
17 to a public place without wearing makeup?
18 A. (Pause) I do not know. Yes. Yes.
23 March 2013
3 MS. LAWS: Yes, it is the angle I am interested in. Was the wall
4 to your right, literally facing your face there or was it
5 behind you?
6 THE WITNESS: I cannot quite recall exactly where the wall -- if
7 that was the doorway, I was closer to the doorway, or if I was
8 facing towards the wall, but I was facing towards the living
9 room.
10 Q. What did the blood spatter look like? You say you do not know
11 how it happened, but what did it look like? I am sure that
12 was memorable.
13 A. To be honest, we made light of it. It was remarkable because
14 of the, of what had happened, but I was quick to make light of
15 it. I know that sounds hard to imagine, but I was so ready to
16 believe that it would never happen again that we were quick to
17 make light of it.
18 Q. There was no blood on the wall, which is why you cannot
19 describe it in any way, is it not?
20 A. That is not true.
Ms Heard�s account evolved further when she was shown a photograph of herself with Ian
McLagan taken on 23 March 2013, but once again Ms Heard sought to cover herself by
giving evidence that she might be able to see an injury on a photograph where she clearly
had none.
P.1809
23 A. I do not know his name.
24 Q. You do not know his name. He is, and he is ----
25 MR. JUSTICE NICOL: Ian McLagan.
P.1810
2 MS. LAWS: He is the guitarist for Keith Richards.
3 THE WITNESS: Oh yes, I am vaguely familiar with this.
4 Q. You are familiar with this photograph. It shows you with a
5 clear face, does it not?
6 A. What do you mean?
7 Q. No injury?
8 A. No, I cannot see an injury to my face.
9 Q. No injury at all on that?
10 A. I cannot really tell if my lip is bruised.
Jun. 2013
June 2013
Incident 3: Hicksville, June 2013
May 2014
May 2014
DAY 7 (Cross-examination of Kate James)
Ms James saw Ms Heard in the immediate aftermath of the plane journey in May 2014
P.1224
23 Q. Do you remember contacting Ms. Heard after she had returned on
24 a plane journey from Boston, having travelled from New York,
25 where she was filming The Adderall Diaries with James Franco?
P.1225
2 A. I believe she contacted me first, ma'am.
3 Q. She contacted you. What she says here ----
4 A. Yes.
5 Q. ---- in the text, and I will read it, is: "I have to leave
6 JD. He's just freaked out on me. He is drinking again. It's
7 bad, worse than ever. I need out. ...(reads to the words)...
8 Please, Stephen will help arrange". Then, the next text
9 reads: "Also, can you please see if you can redirect all of
10 his texts to me to Whitney's phone, or just block him
11 entirely. I need to make this move". Having seen those
12 texts, are you reminded about -- (Pause) Are you reminded
13 about what the subject-matter was?
14 A. Yes, I remember the day very clearly, trust me.
15 Q. Ms. Heard went to stay in a hotel?
16 A. I do not know why because she had an apartment, but yes.
17 Q. She had an apartment that she was sharing with Mr. Depp in the
18 Eastern Columbia Building?
19 A. No, excuse me, ma'am, she had her own apartment that was still
20 being paid for and maintained by Mr. Depp, which was on Orange
21 Avenue. You may have heard of that apartment before.
22 Q. We have heard of that apartment. I suggest ----
23 A. That apartment was still fully functioning and liveable, so I
24 do not know why she went to The Chateau.
25 Q. She did go to The Chateau, as you call it, the hotel?
P.1226
2 A. Yes, she went to The Chateau with four of her friends and they
3 basically had a pool party all day.
4 Q. She had friends who were supporting her in a traumatic event?
May 2014
7 A. You know, of that ilk. It could cause quite unpleasant
8 feeling in that area. It could be that. I do not know
9 specifically. I could not say specifically.
10 Q. We are on our way to 80, that is 80 Sweetzer Avenue, is that
11 right, where he had a property in Hollywood?
12 A. Yes.
13 Q. Over the page, you carry on: "He has been sick. We are going
14 to get him straight to bed"?
15 A. Yes.
16 Q. Is that just tummy ache?
17 A. I mean, I cannot recall specifically.
18 Q. Or do you think, having seen what he said he had drunk and
19 imbibed by way of controlled drugs, he might have just
20 overdone it, and that is what made him ill?
21 A. It is possible, yes.
22 Q. That is possible as well?
23 MR. JUSTICE NICOL: Just a minute. (Pause) By "overdone it", do
24 you mean that he was drunk?
25 A. The behaviour was not the behaviour of a drunkard, but
P.778
2 nevertheless, the consumption, as you said, because of the
3 consumption, it could be, you know, quite impressive, if you
4 will, and it could be a cause of that, yes. So, not
5 necessarily behavioural but physical, yes.
Mr Deuters rejected the description set out in Ms Heard�s email to herself which he was taken
to
P.778
16 Q. This is another e-mail from Ms. Heard to herself, but dated
17 25th May 2014 at 11.32 p.m; all right?
18 A. Yes.
19 Q. That is what the date is recorded as?
20 A. Yes.
21 Q. It reads as follows, and I am going to ask you about whether
22 you recognise the events that she is describing in case
P.779
Aug. 2014
August 2014
5 A. And drinking and swimming and sunbathing and having fun.
Incident 5: Bahamas Detox, August 2014
August 2014
P.621
20 Q. Does your Lordship have that? If you look at the first text,
21 let us set in context what this is. You will see from Rocky
22 to you: "Steve, it's Rocky" -- Steve was the affectionate
23 name that Ms. Heard used for you and you used "Slim" for her;
24 that is right, is it not?
25 A. Yes.
P.622
2 Q. "Happy birthday dear sweet friend" -- this is from Rocky to
3 you -- "changed my life, I'm so grateful you're in the world.
4 Hope you have a wonderful day." It is quite clear from the
5 response: "I am happy you are happy, doll, that's all that
6 matters. Slim and I just fucking adore you." You are with
7 Ms. Heard?
8 A. Yes.
P.623
7 Q. If you look there, that is still 6th August 2014, and it is
Sep. 2014
September 2014
The following month, September 2014, Mr Depp and Ms Heard were clearly going through a
difficult time, but the documents show only Mr Depp hurting himself � and not attacking Ms
Heard.
Jan. 2015
January 2015
P.1928
18 MS. LAWS: My Lord, moving on to the Tokyo incident, incident 7,
19 please, this is an allegation you make dated January 2015,
20 where you say Mr. Depp slapped you, grabbed your hair, and
21 yesterday we had a reference in your evidence that Mr. Depp,
22 you say, knelt on your back and was hitting you. Is that all
23 true?
24 A. Yes.
25 Q. Did you attend a premier whilst in Tokyo?
P.1929
2 A. Yes.
3 Q. At what point did you attend that premier -- before or after
4 the assault?
5 A. Two days after. I remember being concerned about any visible
6 bruising on my back because my back was exposed.
7 MR. JUSTICE NICOL: Just a minute. (Pause)
8 MS. LAWS: So the premier was two days after this assault?
9 A. I believe somewhere around there.
10 Q. Do you remember wearing a backless dress to that premier?
11 A. Very well. Very well.
January 2015
DAY 4 (Re-examination of Mr Depp)
Page 681
17 Q. That is in January 2015. You explained that you were on a
18 trip to Tokyo and that you went not only with Ms. Heard, but
19 also with Lily-Rose, your daughter, and Jack?
20 A. That is correct.
21 Q. I think, to be fair, at that stage, I think Lily-Rose would
22 have been 15 or 16 and Jack 12 or 13?
23 A. Somewhere around that.
24 Q. Do not worry. You said they were sleeping in an adjoining
25 room to yours and Ms. Heard's?
Page 682
2 A. Yes.
3 Q. How do you remember the time in the hotel with the children
4 and Ms. Heard? Did you all interact together or were you very
5 separate?
6 A. I was doing -- mostly, I was doing press, but when we were all
7 together ----
8 Q. You were all together?
9 A. We were all together and it was fine.
10 Q. It was in that context that it was suggested to you -- and I
11 will not read out all the allegations again -- that you
12 shoved, wrestled her to the floor, grabbed her by the hair,
13 yelled at her, Ms. Heard said she was crying on the floor, and
14 this happened in hotel. Where would the children have been
15 when you were in the hotel bedroom?
16 A. They were either in our room or their room at all times.
17 Q. If Lily-Rose or Jack had seen any marks or injuries on
18 Ms. Heard's face or body at the time, would they have asked
19 her about that, do you know?
20 A. Certainly they would have.
January 2015
Incident 7: Tokyo Hotel Room, January 2015
Ms Heard�s allegation that she was assaulted by Mr Depp in their hotel room in Tokyo when
they flew in for the premier of one of Mr Depp�s films lacks credibility. As Mr Depp explained
his two children had come on the trip with them. They had an adjourning room. That fact not
only undermines this specific allegation, but it also undermines the Defendants� more general
narrative that Mr Depp carried out his heinous assaults on Ms Heard when he so drunk or out
of control on drugs that he could not recall what he had done.
Mar. 2015
March 2015
Incident 9: Stairs at Eastern Columbia PH, March 2015
March 2015
3 mix-up" -- that is the phrase she used -- over the
4 photographs. I am not going to go back over how that
5 happened. You have explained the mistake. Can I ask you
6 about your evidence. Now, in terms of what you saw on 21st
7 April, you said to Ms. Wass that you saw injuries that were
8 very similar to the ones in the photograph we now know is the
9 March photograph?
10 A. Correct.
11 Q. And Ms. Wass accepted, she said, that Ms. Heard had hit ----
12 MR. JUSTICE NICOL: March 2015.
13 MR. SHERBORNE: My Lord, yes. Ms. Wass said it is accepted by
14 Ms. Heard that she did hit Mr. Depp in March 2015. We have
15 your account of 21st April and the injuries you saw. Are
16 those the only two incidents of injuries that Ms. Heard caused
17 to Mr. Depp that you know of?
18 A. There was another incident in December in which he sustained
19 injuries from Ms. Heard -- Mr. Depp.
20 MR. JUSTICE NICOL: Just a minute. (Pause) In December. Can you
21 help me with which year?
22 A. That would be 2015, sir.
23 MR. JUSTICE NICOL: Thank you.
24 MR. SHERBORNE: Can I ask you to take bundle 6. It is the red
25 bundle to your right.
P.1306
14 MR. SHERBORNE: There, we see there should be a photograph on
15 F894.092.
16 A. Correct.
17 Q. Do you see there a photograph of Mr. Depp?
18 A. I do.
19 Q. Can you just explain. It says "Sean". Can you just explain
20 what you know about this photo?
21 A. I took this photo on December 15th, 2015.
22 Q. Can I just pause for one second. Just looking at the top, is
23 that IMG 2015, 12.15, a reference to the date you just gave
24 us?
25 A. It is.
March 2015
Incident 8: Australia, March 2015
March 2015
3 mix-up" -- that is the phrase she used -- over the
4 photographs. I am not going to go back over how that
5 happened. You have explained the mistake. Can I ask you
6 about your evidence. Now, in terms of what you saw on 21st
7 April, you said to Ms. Wass that you saw injuries that were
8 very similar to the ones in the photograph we now know is the
9 March photograph?
10 A. Correct.
11 Q. And Ms. Wass accepted, she said, that Ms. Heard had hit ----
12 MR. JUSTICE NICOL: March 2015.
13 MR. SHERBORNE: My Lord, yes. Ms. Wass said it is accepted by
14 Ms. Heard that she did hit Mr. Depp in March 2015. We have
15 your account of 21st April and the injuries you saw. Are
16 those the only two incidents of injuries that Ms. Heard caused
17 to Mr. Depp that you know of?
18 A. There was another incident in December in which he sustained
19 injuries from Ms. Heard -- Mr. Depp.
20 MR. JUSTICE NICOL: Just a minute. (Pause) In December. Can you
21 help me with which year?
22 A. That would be 2015, sir.
23 MR. JUSTICE NICOL: Thank you.
24 MR. SHERBORNE: Can I ask you to take bundle 6. It is the red
25 bundle to your right.
P.1306
14 MR. SHERBORNE: There, we see there should be a photograph on
15 F894.092.
16 A. Correct.
17 Q. Do you see there a photograph of Mr. Depp?
18 A. I do.
19 Q. Can you just explain. It says "Sean". Can you just explain
20 what you know about this photo?
21 A. I took this photo on December 15th, 2015.
22 Q. Can I just pause for one second. Just looking at the top, is
23 that IMG 2015, 12.15, a reference to the date you just gave
24 us?
25 A. It is.
8 March 2015
The cross-examination of Mr Depp focused on drugs, but not violence. It also focused on
matters which are not probative of violence, for example Mr Depp�s disappointment with the
state of the film he was shooting and Mr Deuters� attempt to cheer him up. The dark language
used by Mr Depp in a text message to his friend, Paul Bettany, relied upon by the Defendants,
was nothing to the point.
The evidence of third parties, in particular Mr Ben King, is important. Mr King was frank about
the damage to the house, but his evidence also shows that Ms Heard�s more lurid account (in
her statement and then in cross-examination) cannot be believed. There was no urine from
Mr Depp �peeing on walls and carpet�, no dripping blood, raw meat, potatoes and gravy
smeared on a door. Further while he noticed diagonal cut marks on her arms, he saw no other
injuries.
He did not see or learn about a telephone smashed to the point of disappearing which featured
so graphically in Ms Heard�s account of how Mr Depp injured his finger.
Had Ms Heard wanted to leave the house, she could have done so, whether through
contacting security (who were hired by the production company), calling someone, or walking
out the glass doors of the bedroom.
Instead she was a very active participant in the argument on 8 March 2015. The evidence
supports the view that she was not just responsible for one broken bottle as she claimed, but
other damage too � including some of the writing on the bathroom mirror. While Mr Depp takes
responsibility for the damage which he caused, Ms Heard proved incapable of accepting that
she had done anything � on her account it was all one-way � but despite that she did not leave
at any point over the three days.
DAY 3 (Cross-examination of Mr Depp)
Jul. 2015
July 2015
2 not fall down a flight of stairs.
3 Q. This is your way of trying to minimise the fact that this
4 whole incident was Amber attacking Mr. Depp, are you not?
5 A. I disagree with that statement. I am telling the truth.
Incident 10: S.E. Asia Train Journey
The evidence about the nature of the train, its staffing and the presence of a security person,
Malcolm Connolly, for Mr Depp and Ms Heard during their honeymoon completely
undermine Ms Heard�s account of an unprovoked attack in their cabin where she screamed
and/or Mr Depp was screaming at her. There is no evidence of any injury and Mr Connolly
did not see any injuries.
Day 5 (Re-examination of Mr Depp)
Page 698
10 MR. SHERBORNE: Can I take you then to the next alleged incident,
11 Mr. Depp, incident 10 on the Southeast Asia train. This was
12 part of your honeymoon; is that right?
13 THE WITNESS: Yes.
14 Q. It is July 2015. Can I ask, was it just you and Ms. Heard who
15 were present on the train?
16 A. We travelled with security, Malcolm Connolly, he was with us
17 for the entire honeymoon, for the trip.
18 Q. You were not asked many questions about this by Ms. Wass, so
19 I am going to keep it very brief. We know that Ms. Heard's
20 evidence is that you were very violent, according to her, you
21 hit her, you pushed her against the wall, you grasped her by
22 the throat and you caused her to fear for her very life; you
23 have seen that is what she says?
24 A. Yes, I have seen it.
July 2015
8 Q. Mr. Depp mentioned this yesterday and he said that you were
9 present; is that correct?
10 A. Correct. Yes.
11 Q. It was Mr. Depp and Ms. Heard's honeymoon, part of their
12 honeymoon?
13 A. That is correct.
14 Q. In July 2015?
15 A. Correct.
16 Q. Did Mr. Depp take over the whole train?
17 A. No, not at all, no.
Nov. 2015
November 2015
13 and he is uninjured. He strangled me.
Incident 11: Thanksgiving, November 2015
November 2015
24 MS. LAWS: It is a summary at F2.1.
25 THE WITNESS: Which file bundle?
P.1937
25 Q. It is Ms. Pennington's account: "I attended Thanksgiving
P.1938
2 Dinner with Johnny and Amber and a number of others at their
3 apartment PH5 in November 2015. At one point, late in the
4 meal, Amber went upstairs to look for Johnny and stayed up
5 there for a long time. After a long time, they both came
6 downstairs. When I asked Amber what had happened, she told me
7 that Johnny had thrown a bottle of wine at her in the bedroom.
8 I went to look and found that a full bottle of wine had hit
9 and broken a piece of art that Amber really loves above the
10 bed and that broken glass was scatted all over the bed. I
11 went back downstairs and spoke to Amber. She was upset, but
12 just wanted to get through dinner without further problems."
13 Now, what she is saying is that this assault took place
14 while everyone was there, and that you had to go back
15 downstairs?
16 A. No, she is saying ----
17 Q. She is wrong?
18 A. Excuse me?
19 Q. Is she wrong?
20 A. No. She is saying this part of it took place while she was
21 there and others were downstairs. She was just describing the
22 first part of the fight.
23 Q. So the incident has two parts now, does it?
24 A. Our fights typically involved many parts.
25 Q. You are just making this all up as you go along to try and fit
P.1939
2 with evidence that comes out later, are you not?
3 A. No. I have had this information.
4 Q. You see, this is a lying account, we say, from Raquel
5 Pennington, but we can deal with that with her. She has got
6 one thing very wrong, has she not, in that, because what she
7 says is that in Penthouse 5, she has gone upstairs, asking you
8 what is happening, and you tell her that Johnny had thrown a
24 November 2015
23 Q. These are Erin Burin's notes. We can see that on 26th
24 November 2015 she has made an entry, making it clear that in
25 fact she joined in on Thanksgiving: "RN visited client and
P.1943
2 husband/client JD's home in Downtown Los Angeles ...(reads to
3 the words)... client AH notified RN that she will need refills
4 on her routine", and then it goes on about your medication.
5 So she was there on that day, was she not?
6 A. Yes. This reminds me.
7 Q. She was there, was she, at the time before or after you had
8 been hit?
9 A. The first interaction I had with Johnny, he just threw a
10 bottle at me, and ----
11 Q. Sorry, I was asking about whether she was there or not?
12 A. She was downstairs.
13 MR. JUSTICE NICOL: I think you have established that Ms. Heard
14 agreed she was there. But then you asked whether she was
15 there before or after the altercation. Ms. Heard is giving
16 her answer.
17 THE WITNESS: So, the violence, what I would call violence, at the
18 time, no. She was there downstairs in penthouse 5 for the
19 bottle-throwing, the decanter breaking, the painting breaking.
20 I remember there was a slight altercation on the top of the
21 stairs involving wine and Johnny grabbing me by the short
22 collar ----
23 MS. LAWS: Can I ask you, was she there ----
24 A. ---- that was -- that is an altercation, so I was trying to
25 answer your question in full so you had the most information
P.1944
2 and I can answer you the best way possible. There was a
3 slight altercation, but it was not what it later became after
4 everyone left; which she was not there for.
5 MS. LAWS: Right. I was not asking for another description ----
6 MR. JUSTICE NICOL: Ms. Laws, you asked the question, Ms. Heard
7 has given her answer. As I have understood the answer, is
8 that she was there for the interaction that you have described
9 involving a painting, but when you were asked whether
10 Ms. Burin was there when you were assaulted, I think you said
11 she was not.
Dec. 2015
December 2015
10 Moving on then to
11 15th December 2015, again, this was an incident where you did
12 not witness anything happening, but you claim to have seen
13 injuries afterwards; is that correct?
14 A. That is correct, and may I ask, is there a paragraph or file
15 that I should be looking at?
16 Q. I will take you to it in a moment. I am just establishing
17 your recollection of that. What do you recollect as being the
18 injuries that you saw on Ms. Heard?
19 A. On December 15th?
20 Q. Yes. What do you recollect? I will take you to your
21 statement in a moment, but what do you recollect?
22 A. The one that stands out the most in my memory is the injury to
23 the back of her head, the scalp, that was bloody, where hair
24 had been ripped out.
25 MR. JUSTICE NICOL: Just a minute.
December 2015
Incident 10: December 2015
The Court heard Mr Depp explain that generally he tried to avoid arguments with Ms Heard,
he would �run away from fights�. Ms Heard�s allegation that she was injured, escalated in her
evidence to asserting that Mr Depp had inflicted a broken nose on her. Having maintained,
falsely, that Mr Depp �head butted� her, she then made up an injury which would � had it
happened � have been consistent with a headbutt. But there was no broken nose. None of
the photographs support that (as Mr Depp noted one seemed to show a chapped lip) nor
does any third-party testimony support that or Ms Heard�s evidence (given on DAY 12) that
she �had two black eyes, a broken nose and a broken lip, bruised ribs, bruises all over my
body.� Ms Pennington�s description differed and no photographs show what she said she
saw, namely a swollen nose.
Ms Heard account of her injuries is contradicted by what Tara Roberts saw, or in fact did not
see, when Ms Heard went with Mr Depp to the Bahamas for Christmas and what Samantha
McMillen saw, in terms of lack of any injuries on 16 December 2015. There was no reason for
Ms McMillen to attend court in order to lie for Mr Depp. She was present when Ms Heard was
being made up and would have seen if she was sporting two black eyes (and a broken/ swollen
nose). Similarly Kevin Murphy left Mr Depp�s employment some time ago. He has no vested
interest in lying for Mr Depp. He saw Ms Heard in her bedroom and took photos of a clump of
her hair on the carpet. But he was firm that the did not see any injuries to her face, although
she was upset.
Further, Ms Heard could not explain what her own nurse, Erin Boerum, noted as to the
absence of any visible injury beyond a bleeding lip.
DAY 3 (Cross-examination of Mr Depp)
Page 491
14 Q. Can I move forward, then, to December 2015. Now, Mr. Depp, by
15 December 2015, you were routinely using violence against
16 Ms. Heard when you were intoxicated and when you were angry.
17 What do you say about that?
18 A. I say that is incorrect, most of the time I tried to get away
19 from her.
20 Q. During episodes when you would start by punching walls or
21 destroying property or shattering glass objects, that very
22 quickly escalated into a slap or pushing her over, or worse on
23 some occasions?
24 A. No, that is incorrect. Most of the time, Amber's, Ms. Heard's
25 problem was that I would run away from fights and I was then
December 2015
Incident 10: December 2015
The Court heard Mr Depp explain that generally he tried to avoid arguments with Ms Heard,
he would �run away from fights�. Ms Heard�s allegation that she was injured, escalated in her
evidence to asserting that Mr Depp had inflicted a broken nose on her. Having maintained,
falsely, that Mr Depp �head butted� her, she then made up an injury which would � had it
happened � have been consistent with a headbutt. But there was no broken nose. None of
the photographs support that (as Mr Depp noted one seemed to show a chapped lip) nor
does any third-party testimony support that or Ms Heard�s evidence (given on DAY 12) that
she �had two black eyes, a broken nose and a broken lip, bruised ribs, bruises all over my
body.� Ms Pennington�s description differed and no photographs show what she said she
saw, namely a swollen nose.
Ms Heard account of her injuries is contradicted by what Tara Roberts saw, or in fact did not
see, when Ms Heard went with Mr Depp to the Bahamas for Christmas and what Samantha
McMillen saw, in terms of lack of any injuries on 16 December 2015. There was no reason for
Ms McMillen to attend court in order to lie for Mr Depp. She was present when Ms Heard was
being made up and would have seen if she was sporting two black eyes (and a broken/ swollen
nose). Similarly Kevin Murphy left Mr Depp�s employment some time ago. He has no vested
interest in lying for Mr Depp. He saw Ms Heard in her bedroom and took photos of a clump of
her hair on the carpet. But he was firm that the did not see any injuries to her face, although
she was upset.
Further, Ms Heard could not explain what her own nurse, Erin Boerum, noted as to the
absence of any visible injury beyond a bleeding lip.
DAY 3 (Cross-examination of Mr Depp)
Page 491
14 Q. Can I move forward, then, to December 2015. Now, Mr. Depp, by
15 December 2015, you were routinely using violence against
16 Ms. Heard when you were intoxicated and when you were angry.
17 What do you say about that?
18 A. I say that is incorrect, most of the time I tried to get away
19 from her.
20 Q. During episodes when you would start by punching walls or
21 destroying property or shattering glass objects, that very
22 quickly escalated into a slap or pushing her over, or worse on
23 some occasions?
24 A. No, that is incorrect. Most of the time, Amber's, Ms. Heard's
25 problem was that I would run away from fights and I was then
December 2015
P.1176
11 MS. WASS: What it says, it gives the date of 15th December 2015,
12 but what you say in your witness statement is this: "I have
13 been told by Mr. Depp's solicitors that it is alleged that on
14 December 15th, 2015, Mr. Depp beat Ms. Heard so hard in the
December 2015
P.1998
2 Q. Can you take file 2 out, please. I am not going to take you
3 to a document just yet, but you have given an account in
4 evidence of an incident whereby Tara Roberts' partner had to,
5 in effect, take Mr. Depp away from you; is that what you were
6 saying?
7 A. I believe my recollection is that towards the end of that
8 attack, Johnny only had me by the hair, and I was, there was a
9 bit of a scuffle trying to free myself from his grasp, and
10 they both approached us. I think at the same time, and it is
11 my recollection that Tara leaned towards me and CJ, her
12 partner, leaned more towards Johnny and put his hands on
13 Johnny's chest or upper shoulders, and that, we had about two
14 feet of separation for a moment.
24 Q. Can I ask you to go to page D229, please. I am going to ask
25 you about what her account is.
P.1999
2 A. All right.
3 Q. Which she gave a statement to, and which was not challenged.
4 So let us have a look at paragraph 10: "During the evening of
5 29th December 2015, Johnny drove to the office alone in his
6 John Deer Gator. He had said he just needed to get away from
7 Amber. Shortly afterwards, Amber showed up to the office.
8 Amber started pleading with him to come back to the house, and
9 at that point I walked out of the office. A few minutes later
10 I heard his vehicle start and I stepped outside. Amber was
11 standing in front of the vehicle, screaming at him and
12 apparently not letting him get away by blocking his path.
13 Then she climbed into the vehicle. He drove her back to their
14 house. I got in my golf cart and went to the caf�, which is a
15 short distance from the house. I called Christi Dembrowski,
16 Johnny's sister, as I was unsure how far this would go. While
17 I could not hear what caused the fight, Amber repeatedly
18 berated him with increasing ferocity. She was insulting him,
19 calling him names, and in the middle of this onslaught I heard
20 her specifically say 'Your career is over, no one is going to
15 December 2015
Incident 10: December 2015
The Court heard Mr Depp explain that generally he tried to avoid arguments with Ms Heard,
he would �run away from fights�. Ms Heard�s allegation that she was injured, escalated in her
evidence to asserting that Mr Depp had inflicted a broken nose on her. Having maintained,
falsely, that Mr Depp �head butted� her, she then made up an injury which would � had it
happened � have been consistent with a headbutt. But there was no broken nose. None of
the photographs support that (as Mr Depp noted one seemed to show a chapped lip) nor
does any third-party testimony support that or Ms Heard�s evidence (given on DAY 12) that
she �had two black eyes, a broken nose and a broken lip, bruised ribs, bruises all over my
body.� Ms Pennington�s description differed and no photographs show what she said she
saw, namely a swollen nose.
Ms Heard account of her injuries is contradicted by what Tara Roberts saw, or in fact did not
see, when Ms Heard went with Mr Depp to the Bahamas for Christmas and what Samantha
McMillen saw, in terms of lack of any injuries on 16 December 2015. There was no reason for
Ms McMillen to attend court in order to lie for Mr Depp. She was present when Ms Heard was
being made up and would have seen if she was sporting two black eyes (and a broken/ swollen
nose). Similarly Kevin Murphy left Mr Depp�s employment some time ago. He has no vested
interest in lying for Mr Depp. He saw Ms Heard in her bedroom and took photos of a clump of
her hair on the carpet. But he was firm that the did not see any injuries to her face, although
she was upset.
Further, Ms Heard could not explain what her own nurse, Erin Boerum, noted as to the
absence of any visible injury beyond a bleeding lip.
DAY 3 (Cross-examination of Mr Depp)
Page 491
14 Q. Can I move forward, then, to December 2015. Now, Mr. Depp, by
15 December 2015, you were routinely using violence against
16 Ms. Heard when you were intoxicated and when you were angry.
17 What do you say about that?
18 A. I say that is incorrect, most of the time I tried to get away
19 from her.
20 Q. During episodes when you would start by punching walls or
21 destroying property or shattering glass objects, that very
22 quickly escalated into a slap or pushing her over, or worse on
23 some occasions?
24 A. No, that is incorrect. Most of the time, Amber's, Ms. Heard's
25 problem was that I would run away from fights and I was then
16 December 2015
Incident 10: December 2015
The Court heard Mr Depp explain that generally he tried to avoid arguments with Ms Heard,
he would �run away from fights�. Ms Heard�s allegation that she was injured, escalated in her
evidence to asserting that Mr Depp had inflicted a broken nose on her. Having maintained,
falsely, that Mr Depp �head butted� her, she then made up an injury which would � had it
happened � have been consistent with a headbutt. But there was no broken nose. None of
the photographs support that (as Mr Depp noted one seemed to show a chapped lip) nor
does any third-party testimony support that or Ms Heard�s evidence (given on DAY 12) that
she �had two black eyes, a broken nose and a broken lip, bruised ribs, bruises all over my
body.� Ms Pennington�s description differed and no photographs show what she said she
saw, namely a swollen nose.
Ms Heard account of her injuries is contradicted by what Tara Roberts saw, or in fact did not
see, when Ms Heard went with Mr Depp to the Bahamas for Christmas and what Samantha
McMillen saw, in terms of lack of any injuries on 16 December 2015. There was no reason for
Ms McMillen to attend court in order to lie for Mr Depp. She was present when Ms Heard was
being made up and would have seen if she was sporting two black eyes (and a broken/ swollen
nose). Similarly Kevin Murphy left Mr Depp�s employment some time ago. He has no vested
interest in lying for Mr Depp. He saw Ms Heard in her bedroom and took photos of a clump of
her hair on the carpet. But he was firm that the did not see any injuries to her face, although
she was upset.
Further, Ms Heard could not explain what her own nurse, Erin Boerum, noted as to the
absence of any visible injury beyond a bleeding lip.
DAY 3 (Cross-examination of Mr Depp)
Page 491
14 Q. Can I move forward, then, to December 2015. Now, Mr. Depp, by
15 December 2015, you were routinely using violence against
16 Ms. Heard when you were intoxicated and when you were angry.
17 What do you say about that?
18 A. I say that is incorrect, most of the time I tried to get away
19 from her.
20 Q. During episodes when you would start by punching walls or
21 destroying property or shattering glass objects, that very
22 quickly escalated into a slap or pushing her over, or worse on
23 some occasions?
24 A. No, that is incorrect. Most of the time, Amber's, Ms. Heard's
25 problem was that I would run away from fights and I was then
17 Dec 15
P.1911 (Having taken to notes of Nurse Erin Boerum following a visit to Ms Heard on 17 Dec
15)
7 Now, that was over the phone, that conversation, but the
8 very next day, so on 17th December, Erin Burin is in contact
9 with you to notify you that she will be able to deliver your
10 medications to your home. So she turned up -- this is quite
11 late -- at 11 o'clock at night, and waited at the door for
12 several minutes after knocking. You greeted her at the door
13 looking dishevelled, with your hair unbrushed, weepy and sad,
14 slouched posture, and you told Ms. Burin about an argument
15 with Mr. Depp. Then there is a discussion about her offering
16 emotional support and that she could not stay. It is this bit
17 I am asking you about, the last sentence: "The client had
18 visible bright red blood appearing at centre of lower lip.
19 When RN made client aware that she was actively bleeding on
20 her lip, client stated it was from the injuries sustained in
21 the argument between her and her husband, and that it
22 continued to bleed actively. Client also states that her head
23 is bruised and she lost clumps of hair in altercation. RN
24 briefly looked at client's scalp, but was unable to visualise
25 the haematomas the client had described. RN encouraged the
P.1912
2 client to be seen by physician, Dr. Kipper, or go to an
3 emergency." You did not have any bruising at all when you saw
4 Erin Burin, did you?
5 A. I had two black eyes, a broken nose and a broken lip, bruised
6 ribs, bruises all over my body.
7 MR. JUSTICE NICOL: Just a minute. (Pause) You were being
8 particularly asked about bruises and you said you had bruised
9 ribs ----
10 A. I had bruised ribs, bruises all over my body, bruises on my
11 forearms from trying to defend the blows. I had two black
12 eyes. I had a broken nose. I had a broken lip. I had
13 bruises primarily. The really bad ones were in my hairline,
14 in my scalp, my chin ----
15 Q. Just a minute. (Pause)
16 A. There were chunks of hair missing, there was pus in those
17 wounds, in my hairline, dark red bruises specifically, like,
Mar. 2016
March 2016
19 marks or swellings."
20 A. That is correct.
21 Q. How certain are you about that?
22 A. 100%.
23 Q. Now, you had known Ms. Heard for some time by May 2016, had
24 you not?
25 A. Since March 2016, I mean 2013.
P.1372
2 Q. 2013. They moved in in March 2013, so you had known her three
3 years and two months; yes?
4 A. Is that how long that is?
5 Q. 13 ----
6 A. From March 2013, from March 2013 is when I first met her, in
7 March 2013.
8 Q. I understand. Have you ever known her to go out to a party
9 without makeup on?
10 A. I would not know that.
20 MS. WASS: Yes. Mr. Baruch, I asked you, having known Ms. Heard
21 for three years and a bit, whether you had ever known her go
22 to a party or to an outside event without being made up;
23 I think you said you could not say that.
24 THE WITNESS: Yes, I would not know that. I do not know how many
25 parties she went to. I do not know, you know, if every time
P.1373
2 she went to a party. So, I could not tell you.
But when
12 you have known that she has been going to a party, have you
13 ever seen her without makeup?
14 A. Any time that I saw her go to an event, that she was decked
15 out in, she had makeup on.
16 MS. WASS: Had you ever known her leave the apartment block and go
17 to a public place without wearing makeup?
18 A. (Pause) I do not know. Yes. Yes.
Apr. 2016
April 2016
21 have to state and it is quite embarrassing -- apparently I had
22 made $650 million, and when I fired them for the right
23 reasons, I had not only lost the $650 million, but I was
24 $100 million in the hole because they had not paid the
25 government my taxes for 17 years.
Page 716
2 Q. So, as you say, a bad meeting?
3 A. Very unpleasant and ugly, yes.
4 Q. You were asked by Ms. Wass, after the meeting, given how you
5 said you were upset, if you had taken cannabis, and you said,
6 quite fairly, that you are not sure, but you may have taken
7 cannabis, I think you said?
8 A. It is possible that from the meeting which was held at my
9 office in the conference room, that on my way down to
10 Ms. Heard's dinner, it is possible that I would have smoked
11 some cannabis in the car on the way.
12 Q. If you had smoked some cannabis, what effect would it have had
13 on you? Would it have made you angry or in a rage?
14 A. No, it is a calming agent.
Page 717
2 Q. You will see the second entry on that page of Nurse Burin's
3 notes. She explains that on 21st April, "Client invited ----
4 MR. JUSTICE NICOL: Sorry, this is dated 27th August, is it?
5 MR. SHERBORNE: No, my Lord, it should be ----
6 MR. JUSTICE NICOL: I beg your pardon. I have the wrong page.
7 Which page?
8 MR. SHERBORNE: K210, my Lord.
9 MR. JUSTICE NICOL: Just a moment. (Pause) Yes, and the entry for
10 21st April 2016?
11 MR. SHERBORNE: My Lord, yes. Do you have that? (Pause)
12 MR. JUSTICE NICOL: Mr. Depp, do you have that?
13 A. K210 at the bottom.
14 MR. SHERBORNE: Yes.
15 A. Yes, I do, thank you.
16 Q. So, as you said, Nurse Burin was a friend of Ms. Heard's as
17 well as a nurse?
April 2016
Mr. Jenkins,
11 have you got file 9 to your left?
12 A. Yes, sir.
13 Q. I am grateful. Behind tab 91A, if your bundle has been
14 updated, do you have there a document entitled "J5.1"?
15 A. Yes.
16 MR. JUSTICE NICOL: Just a minute.
17 MR. SHERBORNE: I am just waiting for his Lordship to find it.
18 MR. JUSTICE NICOL: Sorry, 91A?
19 MR. SHERBORNE: 91A.
20 MR. JUSTICE NICOL: Just a moment. (Pause) Yes, J5.1.
21 THE WITNESS: Yes, I have it. That is my photo.
22 MR. SHERBORNE: Mr. Jenkins, I was going to ask you if you can
23 identify it. That is your photo, you said?
24 A. That is my photo.
25 Q. We can see at the top that it says 23rd April 2016?
P.1338
2 A. Yes.
3 Q. That is the day of Coachella. Can you identify
4 Miss Amber Heard in that photo?
5 A. Right in the middle, wearing the white dress.
6 MR. JUSTICE NICOL: Just a minute. The dresses are all rather
7 coloured, but which is Ms. Heard?
8 A. She is the third one right on the left.
9 MR. SHERBORNE: Right in the middle.
10 A. (Unclear) next to her, the one in the striped shirt, (unclear)
11 in the striped shirt, then Ms. Heard, then Rocky, then her
12 male friend, then I believe this is her stylist, and her
13 sister, Whitney, is at the end.
14 MR. JUSTICE NICOL: So, Ms. Heard is the one in the dress that
15 looks slightly green; is that right?
April 2016
Incident 13: Ms Heard�s Birthday Dinner, April 2016
April 2016
18 Q. Were you taking drugs that weekend?
19 A. I was not.
20 Q. You see, Starling Jenkins was there with an eye on you and
21 Amber and the others for the whole time, was he not?
22 A. I do not recall him being around. I recall him driving us to
23 and from.
P.2181
19 MS. LAWS: So, Starling Jenkins has got it wrong, he has mistaken
20 your sister for you, and he did not buy anything and hand it
21 over to you, you got it from room service?
22 A. He is mistaken about who was sick. I do not recall if he
23 actually went to go get those things. I am not saying that is
24 incorrect. I just do not recall actually receiving those
25 things from Starling.
P.2182
19 Q. It is a message between your sister and iO Tillet Wright. Can
20 you see that there on the left, AH, then iO, then AH?
21 A. Yes. The lines are separated by ----
22 Q. We have the date of 26th April 2016, so just at the end, so
23 Coachella would have ended by then, five days ----
24 A. I do not remember the dates of Coachella, I apologise.
P.2183
7 MS. LAWS: Ms. Heard, Amber Heard, to iO Tillet Wright: "Please
8 sit down, will you. The worse experience of my life...(reads
9 to the words)... in Palm Springs for mine." There are just a
10 few questions. The first question: what your sister is
11 talking about is Coachella, is it not, and the fact that
12 iO Tillet Wright left early?
13 A. I am assuming so, yes.
19 Q. But is what your sister said about the weekend true?
20 A. What about it?
21 Q. From what you witnessed, the bit I read out?
22 A. There is a bunch of information here. Which are you asking me
23 to confirm?
24 Q. I think you know that what I am talking about is that she said
21 April 2016
The events of Coachella, including Ms Heard partying hard with her friends, strongly support
Mr Depp�s account of the night of 21 April 2016. Ms Heard partied so hard, she was sick. Mr
Starling Jenkins was in attendance as security for Ms Heard. That was his job. He was not
going to confuse the subject of his security assignment with someone else.
P.1329
3 Q. Were you ever invited to be part of that group that was
4 enjoying the music festival, or were you simply a part as a
5 driver who was not engaged in the music festival but simply
6 there on duty?
21 April 2016
Ms Heard punched (haymakered) Mr Depp on the night of 21 April 2016.
P.1761
17 So what happened after the guests left is that
18 you started on Mr. Depp, started complaining about the fact
19 that he was late, and you were going on and on at him. Do you
20 agree or not?
21 A. No. I was sad he missed my birthday.
22 Q. He started to read, you became really annoyed, because one
23 thing you get annoyed about is if he does not pay you
24 attention or if he leaves?
25 A. No, ma'am. He was not reading and I was upset because he had
P.1762
2 missed my birthday. He also had scheduled his business
3 meeting, even though he was having, you know, he had all day
4 and the days before, and he was taking these kinds of meetings
5 at this point in our lives quite a bit. He scheduled this
6 meeting, I believe, right before. I think he scheduled it for
7 30 minutes before my thirtieth birthday party began and he was
8 still late on top of that, to the point of missing the ----
9 Q. During the row about this, it was you who punched him, was it
10 not, twice in the face; yes or no?
11 A. Absolutely not. He has no evidence to speak towards that and
12 honestly, I could not ----
13 MR. JUSTICE NICOL: You just need to answer whether you punched
14 him in the face or not.
15 A. No, absolutely not.
May 2016
May 2016
Importantly, he was able to testify to seeing Ms Heard on a number of occasions in the week
following 21 May 2016. With Mr Baruch, Ms Heard does not, cannot, say that she did not see
him up close. Her attempts to say that she was wearing makeup clash with the evidence of a
number of others, including Kristina Sexton. Mr Baruch was clearly deeply unsettled by Ms
Heard�s allegations against Mr Depp in late May 2016.
May 2016
Ms McMillen, who was fond of Ms Heard, also did not see any injuries when she bumped
into her at the Sweetzer house on 24th May 2016
P.1029
22 Q. You have said in your witness statements that as far as the
23 picture, the image of the 27th -- that is the one we last
24 looked at where you agreed there were prominent injuries
25 visible on Ms. Heard's face -- "I knew she did not have those
May 2016
19 marks or swellings."
20 A. That is correct.
21 Q. How certain are you about that?
22 A. 100%.
23 Q. Now, you had known Ms. Heard for some time by May 2016, had
24 you not?
25 A. Since March 2016, I mean 2013.
P.1372
2 Q. 2013. They moved in in March 2013, so you had known her three
3 years and two months; yes?
4 A. Is that how long that is?
5 Q. 13 ----
6 A. From March 2013, from March 2013 is when I first met her, in
7 March 2013.
8 Q. I understand. Have you ever known her to go out to a party
9 without makeup on?
10 A. I would not know that.
20 MS. WASS: Yes. Mr. Baruch, I asked you, having known Ms. Heard
21 for three years and a bit, whether you had ever known her go
22 to a party or to an outside event without being made up;
23 I think you said you could not say that.
24 THE WITNESS: Yes, I would not know that. I do not know how many
25 parties she went to. I do not know, you know, if every time
P.1373
2 she went to a party. So, I could not tell you.
But when
12 you have known that she has been going to a party, have you
13 ever seen her without makeup?
14 A. Any time that I saw her go to an event, that she was decked
15 out in, she had makeup on.
16 MS. WASS: Had you ever known her leave the apartment block and go
17 to a public place without wearing makeup?
18 A. (Pause) I do not know. Yes. Yes.
May 2016
Incident 14 � 21st May 2016 in PH3 at Eastern Columbia
May 2016
Officer Saenz gave a straightforward account that she spoke to Ms Heard, had the opportunity
to look at Ms Heard and she is sure that she showed no injuries
Page 650
16 Q. Is this incident recall, which in fact we have got, and I am
17 sorry you do not have a copy of it, is that incident recall
18 the only document that was generated by you as far as your
19 activities on 21st May 2016?
20 A. Yes, it is.
21 Q. All right. Now, you gave a deposition in the United States
22 about this on 18th July 2016.
Page 653
19 MS. WASS: (To the witness) Her face was red from crying; yes?
20 THE WITNESS: Her face appeared red from crying, but it did not
21 appear that she was injured or (unclear).
22 MR. JUSTICE NICOL: Sorry, officer, can you repeat your last
23 answer, please?
24 THE WITNESS: Yes. Her face was red, it was clear that she was
25 crying, but it did not appear redness as if it would have been
Page 654
2 from an injury, from my training and experience.
3 MR. JUSTICE NICOL: Sorry, it did not appear that there was injury
4 on her face, is that what you are saying?
5 THE WITNESS: Correct, no injuries.
6 MS. WASS: Let me ask you a little bit about that. She was not
7 making eye contact with you.
8 MR. JUSTICE NICOL: I think you have established that, Ms. Wass.
9 MS. WASS: You did not see her full face on at any time, did you,
10 she had her face down and she was upset?
11 THE WITNESS: There were times when she made eye contact. She was
12 visibly upset, so she would look down, and sometimes she would
13 look up when she spoke to me. It was back and forth. So,
14 I did get a look at her entire face.
15 Q. What was the lighting like in this apartment?
16 A. It was very well lit.
17 Q. Did you ask her to go towards a light so you could examine her
18 face?
21 May 2016
DAY 5 (Cross Examination of Trinity Esparza)
Ms Esparza was clear that she had not confused Ms Heard with her sister, Whitney Henriques
in the week after 21 May 2016. The fact that she had spoken to Ms Heard at close range was
confirmed by the CCTV footage subsequently shown to Ms Heard in cross-examination. She
had no animosity towards Ms Heard, she liked her; she has no reason to come to court and
be untruthful. She was also clear that she knew makeup and Ms Heard well enough to know
whether Ms Heard was, or was not, wearing any.
Page 876
6 Q. Ms. Heard had a sister called Whitney; do you know that?
7 A. Yes.
8 Q. And Whitney (Hernandez her name is now) actually lived in the
9 Eastern Columbia Building earlier in 2015; do you agree?
10 A. Yes.
11 Q. She was a regular visitor even after she moved out of that
12 building?
13 A. Yes.
14 Q. And again, you know her by sight?
15 A. Yes.
16 Q. Similar in appearance to Ms. Amber Heard, tall, blonde, slim,
17 very attractive?
18 A. Yes.
19 MR. JUSTICE NICOL: Sorry, Ms. Esparza, do you agree that she is
20 similar in appearance to Ms. Amber Heard?
21 THE WITNESS: They are tall and blonde, they are sisters, they
22 look like ----
23 MS. WASS: They look like sisters, and the description ----
24 A. I suppose so.
25 Q. And the description I have given to you applies to each of
Page 877
2 them, they are tall, slim, blonde and attractive?
3 A. Yes; but they are quite different people.
Page 879
4 Q. Now, on 27th May, you saw Ms. Heard at your desk, you were
5 working at the desk at the Eastern Columbia Building?
21 May 2016
21 MR. SHERBORNE: It was put to you by Ms. Wass that you did not
22 really get a proper view of Ms. Heard. Do you agree that you
23 did not get a proper view of Ms. Heard or not, Mr. Bett?
24 A. No, I had a great view of Ms. Heard.
25 Q. How many years did you work in the Sheriff's Department?
P.1309
2 A. Approximately 14.
3 Q. During the course of your time at the Sheriff's Department,
4 did you have experience of allegations of violence or not?
5 A. Specifically related to calls for service?
6 Q. Yes.
7 A. Oh, indeed I did.
8 Q. You say in your witness statement that Ms. Heard had no red
9 marks or evidence of any bruises, abrasions to her face, or
10 body. Having heard Ms. Wass's questions, do you want to
11 change that evidence at all?
12 A. Not at all.
13 Q. It was put to you, Mr. Bett -- and I should give you the
14 opportunity to comment on it -- that you are lying for
15 Mr. Depp. That is what you have come here to do. What do you
16 have to say about that?
17 A. That is incorrect, sir.
18 Q. Then, finally, you say in your statement, "I could see
19 Mr. Depp was visibly upset at having been accused of hitting
20 Ms. Heard".
21 A. Correct.
22 Q. Had you seen Mr. Depp be in this state before?
23 A. No.
The days following 21 May 2016 are summarised in an Annex to the Claimant�s Closing
Document. Below is some of the key testimony which the Court heard.
21 May 2016
Mr Baruch did see some of the wine split in the hallway when he returned home on 21 May
2016, after the police officers had left. Notably he thought it looked like the detritus of a party,
not the result of quasi-criminal damage.
21 May 2016
17 A. No, it is when she sees me. She has seen me when I am in my
18 makeup chair. The wardrobe is set up often in a different
19 site, if she came at all. It is a different part of the
20 wardrobe/makeup process in photo shoots. It is just not how
21 they work.
22 Q. She is someone who did what for you? What exactly was her
23 ----
24 A. Stylist. She worked with me briefly as a stylist. She is
25 Johnny's lifelong stylist, I believe.
P.1731
2 MR. JUSTICE NICOL: Just a moment. Yes.
3 MS. LAWS: It is inconceivable to suggest that she would not have
4 seen you without makeup, but you disagree?
5 A. I disagree.
Ms Heard�s conduct after 21 May 2016 when she was seeking to get hold of Mr Depp were
inconsistent with the notion that she was �petrified� of him as she declared in order to obtain
a Temporary Restraining Order against him.
It was also notable in her evidence that she refused to accept what was written in black and
white by the attorneys who she had engaged to represent her, whether it was what they said
about the alleged abuse or what their demands of Mr Depp entailed in order, they said on her
behalf, to resolve the divorce amicably.
Further Ms Heard�s account of obtaining the TRO is at odds with reality � as set out in an
Annex to the Claimant�s Closing Document
DAY 10 (Amber Heard, cross-examination)
P.1725
5 MS. LAWS: That would mean that if you had told your lawyer, as
6 I suggest you would have done if you are telling the truth,
7 what she would have put in this letter is, "He was violent on
8 the 21st and he has been violent on so many incidents, a
9 number of incidents in the last six months."
10 A. Are you asking me how my lawyer should have written it?
11 Q. If what you are saying is the truth.
12 MR. JUSTICE NICOL: I think what is being put to you, Ms. Heard,
13 is that had Mr. Depp been violent to you on more than the
14 three occasions that are mentioned in this letter, your lawyer
15 would have referred to those.
21 May 2016
Mr Depp rejected the rather crass suggestion put to him that he numbed the pain of losing
his mother, and of his financial difficulties by taking drugs on 21 May 2016
Page 547
13 Q. Did you deal with the stress and the sadness of losing your
14 mother by numbing the pain with the usual methods?
15 A. No, ma'am.
16 Q. No?
17 A. No, ma'am. There was quite a lot going on, aside from the
18 fact that I had, I was in very bad financial straits as my
19 business managers and lawyers had conspired to steal a lot of
20 money. My mum was in a coma, she then passed away. Amber and
21 I were on the outs and it was looking like forever on the
22 outs, but I tried to maintain a good relationship with
23 Ms. Heard, a friendly relationship.
24 Q. My question was, you have answered it partially, there was an
25 awful lot of stress going on in your life, business-wise, your
Page 548
21 May 2016
Events immediately prior to 21 May 2016
21 May 2016
Importantly, he was able to testify to seeing Ms Heard on a number of occasions in the week
following 21 May 2016. With Mr Baruch, Ms Heard does not, cannot, say that she did not see
him up close. Her attempts to say that she was wearing makeup clash with the evidence of a
number of others, including Kristina Sexton. Mr Baruch was clearly deeply unsettled by Ms
Heard�s allegations against Mr Depp in late May 2016.
22 May 2016
13 A. Absolutely.
14 Q. You said: "I said to my friend something like, 'It looks like
15 somebody got hammered, probably these guys had a party'", and
16 you were referring to Ms. Heard's friends, Ms. Pennington and
17 Mr. Drew; yes?
18 A. Yes.
P.1367
2 Q. Now, then your statement carries on: "At that very moment the
3 door to penthouse 1 opened and Mr. Drew stepped out far enough
4 through the doorway to address me, but also to block my view
5 of the apartment inside"; correct?
6 A. He just poked his head out.
7 Q. Okay.
8 A. He opened the door just enough to get his head out.
9 Q. "I asked Mr. Drew what had happened with the spilt wine, and
10 he very seriously replied with words to the effect of, 'We
11 kind of had a rough day'". That is correct, is it not?
12 A. Yes.
13 Q. Your statement goes on: "He looked and sounded stressed, and a
14 bit worried. So I asked if he was okay and if he needed help,
15 to which he replied, 'No, it's okay, thanks', or words to that
16 effect. I said it was okay, said goodbye, and my friend and
17 I went into my apartment." That is all correct, is it?
18 A. Yes. Yes.
P.1369 (on 22 May 2016)
"We" -- that
24 is you and Mr. Drew -- "then left my apartment and walked back
25 to penthouse 1, where I asked Ms. Heard about Mr. Depp's
P.1370
2 actions the night before. She told me that he hit her in the
3 face and threw a phone at her. I then asked her where he had
4 hit her. She stretched her neck and pushed out the right side
5 of her head for me to look at her right eye"; yes?
6 A. Yes. That is correct. Just like this.
7 (Witness demonstrates)
8 Q. Pointing the right cheek to you; yes?
24 May 2016
Ms Vargas saw Ms Heard on the same day, 24 May 2016, at Sweetzer
27 May 2016
Ms Heard�s attendance at the Courthouse on 27 May 2016 was for publicity so that she could
control the agenda
27 May 2016
In respect of the immediate aftermath, that is the days 22 to 27 May 2016, what emerged from
the testimony of a large number of witnesses � police officers, residents in the Eastern
Columbia Building, those who worked in the Eastern Columbia and others who bumped into
Ms Heard over the subsequent days, such as Samantha McMillen, that the weight of evidence
is overwhelming that Ms Heard was not sporting injuries.
Jun. 2016
June 2016
17 Q. Your interpretation which you put in your statement is that
18 you were just saying what Ms. Heard wanted to hear?
19 A. Yes, and in my conversation with Mr. Depp at the time, he said
20 placate her, you know, say what you want to say, calm her
21 down. As I have said, often I find myself in this unfortunate
22 position and "kicked" was the adjective she was using on the
23 plane so "kicked" was the word I use here
The cross-examination of Stephen Deuters on a newspaper article of 2 June 2016 did not give
any support to the Claimant�s case.
P.792
11 MS. WASS: That is an article in a newspaper, do you agree, dated
12 2nd June 2016?
13 A. Yes.
14 Q. So, after the instigation of divorce proceedings; do you
15 agree?
16 A. Right, yes.
17 Q. This is an article about you, really, is it not, Mr. Deuters:
18 "Johnny Depp assistant says texts were doctored", and then
19 turn over to the other page, which is F1131?
20 A. Yes.
21 Q. "Johnny Depp's assistant, Stephen Deuters, tells TMZ that the
22 texts that were posted in which he allegedly apologised to
23 Amber Heard for Johnny's violent behaviour are heavily
24 doctored and he never said Johnny attacked her. Deuters said
25 he knows of no acts of abuse towards Amber at the hands of
P.793
2 Johnny and has never made such a claim to anyone. He added
3 Johnny has never been violent towards anyone he knows.
4 Deuters said the texts themselves are suspicious because they
5 don't even show a date. Bottom line, he says he will testify
6 under oath he never had a conversation about alleged violence
7 with Amber." That is what you were saying, Mr. Deuters,
8 publicly, about these texts?
9 MR. JUSTICE NICOL: Well, do you agree, Mr. Deuters, that the
10 article reflects what you were saying at the time?
11 A. No, your Honour. I never spoke to TMZ. I never had a
12 conversation with anyone about these texts outside of Johnny's
13 then counsel. I do not recall exactly who it was. They asked
14 me about the texts and I said to them that they were taken out
15 of context. I never used the word "doctored". I never said
16 that to a solitary soul.
2 June 2016
17 Q. Your interpretation which you put in your statement is that
18 you were just saying what Ms. Heard wanted to hear?
19 A. Yes, and in my conversation with Mr. Depp at the time, he said
20 placate her, you know, say what you want to say, calm her
21 down. As I have said, often I find myself in this unfortunate
22 position and "kicked" was the adjective she was using on the
23 plane so "kicked" was the word I use here
The cross-examination of Stephen Deuters on a newspaper article of 2 June 2016 did not give
any support to the Claimant�s case.
P.792
11 MS. WASS: That is an article in a newspaper, do you agree, dated
12 2nd June 2016?
13 A. Yes.
14 Q. So, after the instigation of divorce proceedings; do you
15 agree?
16 A. Right, yes.
17 Q. This is an article about you, really, is it not, Mr. Deuters:
18 "Johnny Depp assistant says texts were doctored", and then
19 turn over to the other page, which is F1131?
20 A. Yes.
21 Q. "Johnny Depp's assistant, Stephen Deuters, tells TMZ that the
22 texts that were posted in which he allegedly apologised to
23 Amber Heard for Johnny's violent behaviour are heavily
24 doctored and he never said Johnny attacked her. Deuters said
25 he knows of no acts of abuse towards Amber at the hands of
P.793
2 Johnny and has never made such a claim to anyone. He added
3 Johnny has never been violent towards anyone he knows.
4 Deuters said the texts themselves are suspicious because they
5 don't even show a date. Bottom line, he says he will testify
6 under oath he never had a conversation about alleged violence
7 with Amber." That is what you were saying, Mr. Deuters,
8 publicly, about these texts?
9 MR. JUSTICE NICOL: Well, do you agree, Mr. Deuters, that the
10 article reflects what you were saying at the time?
11 A. No, your Honour. I never spoke to TMZ. I never had a
12 conversation with anyone about these texts outside of Johnny's
13 then counsel. I do not recall exactly who it was. They asked
14 me about the texts and I said to them that they were taken out
15 of context. I never used the word "doctored". I never said
16 that to a solitary soul.
Jul. 2016
July 2016
P.1763
11 Q. When you met Mr. Depp in July 2016, so after the restraining
12 order, when it was still in place in fact but before the
13 divorce was finalised, do you remember that recording that we
14 have heard a lot about that was made of the meeting?
15 A. Yes.
16 Q. And do you remember there is a part of it in which he makes it
17 quite clear that he said, "I did not want you to go to
18 Coachella, I left you because you haymakered me, you came
19 around the bed to start fucking punching on me" and you did
20 not deny it, did you?
21 A. No, that is not what I was having a conversation with him
22 about.
P.1764
4 MS. LAWS: After the 21st, we are on the 22nd, so the morning you
5 saw Rocky, she came into the penthouse; that is right, is it
6 not?
7 THE WITNESS: Yes.
8 Q. You, in fact, did not mention or say at all that Mr. Depp had
9 hit you or assaulted you in any way, did you?
10 A. That is not true. I did.
11 MR. JUSTICE NICOL: Just a minute. (Pause)
12 MS. LAWS: I suggest that is absolutely untrue?
13 THE WITNESS: I texted her that night and said, we had another
14 real bad one, which at that point was a well-recognised,
15 almost euphemism for a physical altercation. Rocky knew very
16 well I meant that Johnny had hit me. And I asked her to wake
17 me up specifically once she was ready -- well, ready to go in
18 the morning, and I managed to get a few hours of sleep.
P.1765
8 MS. LAWS: What you said to Rocky is that you had a row. I will
9 repeat the question again. You at no stage informed Rocky
10 that Mr. Depp had hit you or assaulted you?
11 A. Again, I was ----
12 MR. JUSTICE NICOL: Just a minute.
13 THE WITNESS: Sure. (Pause)
July 2016
Page 717
25 Q. And the nurse says this: "I arrived with client's UK
Page 718
2 assistant", if your Lordship notes that, ".... arrived with
3 the client's UK assistant, Savannah, at nine o'clock. The
4 client was socialising with friends" upon Ms. Burin's arrival.
5 "She appeared irritable and upset." She reports being angry
6 with husband because he is late and then Nurse Burin provided
7 reassurance that he would arrive and encouraged her to
8 distract herself by socialising with friends. Then you will
9 see she appears to laugh, but her mood turns to depressed and
10 flat when she is alone. Then she says she cannot believe that
11 you are not there yet and so on.
12 Then you arrive. Can you see, "Client's husband, JD,
13 arrives at 10.15." Then it says this. You appear in good
14 spirits, you greet her guests, and during dinner you and
15 Ms. Heard sit next to each another. You appear affectionate
16 towards one another and then you socialise with Ms. Burin for
17 about 45 minutes. She says you appear coherent, oriented and
18 sociable. Does that reflect your recollection of how you
19 were?
20 A. Yes.
Page 719
17 Q. Can I take you back to that transcript, which should be in
18 file 5, and it is 161N. It is the secret recording Ms. Heard
19 did of your meeting on the second day in July 2016 in the
20 hotel room in San Francisco.
Page 720
4 MR. SHERBORNE: We are. It is internal page 14 for me, but I will
5 give you the reference. (Pause) I do not know if you have got
6 references at the bottom. Yes, it is F1009 -- do you have
7 internal pages at the bottom?
�
12 quite sensitive on the electronic bundle. There we go, it is
13 on page F1009.23. Do you have that?
14 A. I do.
15 Q. And do you see, round about the first hole punch, I hope it
16 is, that you are saying, "I don't want a divorce"?
17 A. Yes.
18 Q. "I don't want a divorce. I never wanted a fucking divorce. I
19 never wanted a divorce. I didn't want you to fucking go to
20 Coachella without fucking talking to me because I left you
21 because you fucking haymakered me, man. You came around the
22 bed to fucking start punching on me." Can you explained what
23 "haymakered" means, Mr. Depp?
July 2016
The evidence was that Mr Depp had come from a meeting, he may have smoked cannabis to
calm himself but Nurse Erin�s notes made clear he was coherent, sociable on arrival. The
recording which Ms Heard made of her meeting with Mr Depp in July 2016 contains Mr Depp�s
impromptu account of what transpired that night as Ms Heard was furious that he was late for
her birthday dinner, she �haymakered� him. The violence was all one way and Ms Heard is
attempting to deflect from her conduct by accusing Mr Depp of what she is guilty of.
July 2016
Officer Saenz gave a straightforward account that she spoke to Ms Heard, had the opportunity
to look at Ms Heard and she is sure that she showed no injuries
Page 650
16 Q. Is this incident recall, which in fact we have got, and I am
17 sorry you do not have a copy of it, is that incident recall
18 the only document that was generated by you as far as your
19 activities on 21st May 2016?
20 A. Yes, it is.
21 Q. All right. Now, you gave a deposition in the United States
22 about this on 18th July 2016.
Page 653
19 MS. WASS: (To the witness) Her face was red from crying; yes?
20 THE WITNESS: Her face appeared red from crying, but it did not
21 appear that she was injured or (unclear).
22 MR. JUSTICE NICOL: Sorry, officer, can you repeat your last
23 answer, please?
24 THE WITNESS: Yes. Her face was red, it was clear that she was
25 crying, but it did not appear redness as if it would have been
Page 654
2 from an injury, from my training and experience.
3 MR. JUSTICE NICOL: Sorry, it did not appear that there was injury
4 on her face, is that what you are saying?
5 THE WITNESS: Correct, no injuries.
6 MS. WASS: Let me ask you a little bit about that. She was not
7 making eye contact with you.
8 MR. JUSTICE NICOL: I think you have established that, Ms. Wass.
9 MS. WASS: You did not see her full face on at any time, did you,
10 she had her face down and she was upset?
11 THE WITNESS: There were times when she made eye contact. She was
12 visibly upset, so she would look down, and sometimes she would
13 look up when she spoke to me. It was back and forth. So,
14 I did get a look at her entire face.
15 Q. What was the lighting like in this apartment?
16 A. It was very well lit.
17 Q. Did you ask her to go towards a light so you could examine her
18 face?
Aug. 2016
August 2016
Mr Muphy has no reason to lie for Mr Depp
P.1206
7 It is suggested by
8 Ms. Wass on a number of occasions that you have lied in your
9 witness statement. In December 2019, which is the date of
10 your first witness statement, were you working for Mr. Depp
11 still or not?
12 A. What was the year, sorry?
13 Q. December 2019.
14 A. I was not.
15 Q. To be fair to you, I think in your witness statement you say
16 you stopped, you parted company with Mr. Depp in August 2016;
17 is that correct or not?
18 A. That is correct.
19 Q. In relation to your second witness statement, on 23rd June
20 2020, were you working for Mr. Depp, or doing anything for
21 Mr. Depp at that time?
22 A. I was not.
23 Q. Mr. Murphy, the final question: did you have to come here to
24 give evidence for Mr. Depp and be accused of lying on oath by
25 Ms. Wass?
P.1207
2 A. I definitely did not have to come here.
Dec. 2019
December 2019
Mr Muphy has no reason to lie for Mr Depp
P.1206
7 It is suggested by
8 Ms. Wass on a number of occasions that you have lied in your
9 witness statement. In December 2019, which is the date of
10 your first witness statement, were you working for Mr. Depp
11 still or not?
12 A. What was the year, sorry?
13 Q. December 2019.
14 A. I was not.
15 Q. To be fair to you, I think in your witness statement you say
16 you stopped, you parted company with Mr. Depp in August 2016;
17 is that correct or not?
18 A. That is correct.
19 Q. In relation to your second witness statement, on 23rd June
20 2020, were you working for Mr. Depp, or doing anything for
21 Mr. Depp at that time?
22 A. I was not.
23 Q. Mr. Murphy, the final question: did you have to come here to
24 give evidence for Mr. Depp and be accused of lying on oath by
25 Ms. Wass?
P.1207
2 A. I definitely did not have to come here.
December 2019
Mr Muphy has no reason to lie for Mr Depp
P.1206
7 It is suggested by
8 Ms. Wass on a number of occasions that you have lied in your
9 witness statement. In December 2019, which is the date of
10 your first witness statement, were you working for Mr. Depp
11 still or not?
12 A. What was the year, sorry?
13 Q. December 2019.
14 A. I was not.
15 Q. To be fair to you, I think in your witness statement you say
16 you stopped, you parted company with Mr. Depp in August 2016;
17 is that correct or not?
18 A. That is correct.
19 Q. In relation to your second witness statement, on 23rd June
20 2020, were you working for Mr. Depp, or doing anything for
21 Mr. Depp at that time?
22 A. I was not.
23 Q. Mr. Murphy, the final question: did you have to come here to
24 give evidence for Mr. Depp and be accused of lying on oath by
25 Ms. Wass?
P.1207
2 A. I definitely did not have to come here.
Jun. 2020
June 20
Mr Muphy has no reason to lie for Mr Depp
P.1206
7 It is suggested by
8 Ms. Wass on a number of occasions that you have lied in your
9 witness statement. In December 2019, which is the date of
10 your first witness statement, were you working for Mr. Depp
11 still or not?
12 A. What was the year, sorry?
13 Q. December 2019.
14 A. I was not.
15 Q. To be fair to you, I think in your witness statement you say
16 you stopped, you parted company with Mr. Depp in August 2016;
17 is that correct or not?
18 A. That is correct.
19 Q. In relation to your second witness statement, on 23rd June
20 2020, were you working for Mr. Depp, or doing anything for
21 Mr. Depp at that time?
22 A. I was not.
23 Q. Mr. Murphy, the final question: did you have to come here to
24 give evidence for Mr. Depp and be accused of lying on oath by
25 Ms. Wass?
P.1207
2 A. I definitely did not have to come here.
Mar. 2025
March 25
nan