Shannon Curry

“The results of Ms. Heard's evaluation supported two diagnoses: Borderline personality disorder and histrionic personality disorder.”

The core conclusion of the examination, establishing the diagnostic finding Depp's team would build the remainder of Curry's testimony around.

“people with borderline personality disorder, it seems to be a predictive factor for women who implement violence against their partner, and one of the most common tactics that they'll use is actually physically assaulting and then getting harmed themselves”

Directly supported Depp's narrative that Heard was the physical aggressor by linking BPD to a pattern of initiating violence and then sustaining injury.

“Ms. Heard did not have PTSD. And there were also pretty significant indications that she was grossly exaggerating symptoms of PTSD when asked about them.”

The headline finding on PTSD: not only did Heard fail to meet criteria, but Curry affirmatively characterized her responses as gross exaggeration — directly attacking the credibility of Heard's abuse claims.

“she initially said, "Yes, I have that," to 19 of the 20 symptoms. That's not typical even of somebody with the most disabling form of PTSD.”

Specific quantitative basis for the exaggeration finding, giving the jury a concrete and memorable benchmark.

“I was interviewed at Mr. Depp's home by his legal team Dinner was served.”

Curry's own framing of the pre-retention meeting — correcting Bredehoft's characterization as a social dinner — while conceding the basic facts of the gathering.

“I can't speak to whether or not there's a coincidence. What I can tell you is, my opinions are based on the results of my evaluation.”

Curry deflects Bredehoft's suggestion that her BPD diagnosis aligned suspiciously with Depp's prior accusations about Heard, anchoring her defense to methodology.

“I did not disclose that. It's not significant to the report.”

Curry admits she never disclosed the pre-retention dinner with Depp in her expert report, while maintaining her view that the omission was immaterial.

“The MMPI-2 profile, it's specific to how she approached this test, and you're correct, for this test, it was a defensive profile, not an exaggerated profile.”

Curry concedes the MMPI-2 showed a minimizing rather than exaggerating response style, directly qualifying the symptom-exaggeration narrative from direct examination.

“I prefer feigning, which you brought up earlier, because it indicates someone is intentionally exaggerating but I don't know, necessarily, why.”

Curry reframes the cross-examination's malingering challenge by distinguishing intent-neutral feigning, preserving her exaggeration finding without overclaiming motive.

“Ms. Heard was in the 98th profile - 98th percentile, meaning that she is - she - she had engaged in extreme levels of exaggeration.”

Curry uses Hughes's own objective test against Heard's PTSD claim, noting the 98th-percentile result on the intentional exaggeration scale.

“you're going to have an automatic bias for your client. It's almost a sense of protection, advocacy, wanting their best”

Curry explains why treating providers' accounts carry less evidentiary weight than a forensic evaluation — the advocacy role is structural, not a character flaw.

“given that PTSD is the most frequently feigned and claimed diagnosis. In civil courts, if you are handing somebody a checklist that has every single symptom of PTSD, you're essentially teaching them all the little nuances that we're looking for to get that diagnosis”

Explains why the PCL-5 is inappropriate in forensic civil litigation — it functions as a symptom guide for examinees motivated to obtain a PTSD finding.

“our cookbook actually states that that 3-6 profile, specifically, tends to be associated with cruel and ruthless behavior, particularly to those who they perceive as less powerful to them and subordinates”

The MMPI-2 3-6 code type finding is Curry's primary personality-pathology conclusion about Heard and directly supports Depp's narrative of the relationship dynamic.

“Scored more of those unusual items that are not consistent with PTSD than 98 percent of people who had ever taken the test.”

Quantifies Heard's TSI-2 exaggeration finding, the same 98th-percentile figure Curry first raised in redirect on Day 9.

“There was no evidence of PTSD.”

Curry's dispositive conclusion, delivered as a standalone sentence after enumerating her multi-method evaluation — the central rebuttal to Hughes's diagnosis.

“J would say that it can't be triggered if PTSD isn't present.”

Closing answer that forecloses the counterclaim theory that Waldman's public statements caused Heard psychological harm, within the scope permitted by the court's sidebar ruling.

“I did not disclose that I was interviewed because that's standard procedure.”

Curry's justification for not disclosing the pre-retention meeting — her framing of the dinner as a routine interview — is the central defense against Bredehoft's conflict-of-interest attack.

“I never had a client that was essentially homebound because of their celebrity status.”

Curry explains why the interview took place at Depp's home rather than in her office — an explanation Bredehoft does not challenge, but which implicitly acknowledges the unusual circumstances of the engagement.

“Not for a forensic evaluation of this sophisticated examinee.”

Curry's rebuttal to Bredehoft's assertion that the SCID is the gold standard for personality disorder assessment — she draws a line between clinical and forensic contexts that runs through her entire methodology.

“the majority of those were checklists, which are inappropriate in the forensic setting”

Curry's consistent position on Hughes's 12 instruments — framing them as symptom checklists rather than validated forensic measures — is the methodological core of her rebuttal testimony.

“It's a structured clinical interview. It's for rendering a diagnosis. It's best for treatment because you're asking direct questions of the examinee and about symptoms. So if you have an examinee who has a tendency to minimize, you're not going to get much information.”

Curry signals the SCID's inherent limitation with uncooperative or minimizing examinees, implicitly framing the decision not to use it as methodologically sound.

“Because, well, first of all, I had a limited amount of time for my evaluation, and I already had to use — just to complete the interview was extremely time consuming, and I had to even restructure it into handouts so that I could keep Ms. Heard on track.”

Curry attributes the omission of the SCID to both time pressure and Heard's difficulty engaging with direct questioning, rehabilitating her methodology against cross-examination criticism.