Alejandra Romero — Direct/Cross/Redirect
294 linesTHE COURT: Sorry, your next witness.
MS. LECAROZ: Alejandro Romero.
THE COURT: Alejandro Romero.
MS. LECAROZ: If I might, You Honor, this is another one that begins with questioning by counsel for Ms. Heard and later on switches to counsel for Mr. Depp.
THE COURT: Thank you.
MS. BREDEHOFT: Mr. Romero, will you, please, state your name and address for the record.
ALEJANDRA ROMERO: My name is Alejandro Romero, I go by Alex.
MS. BREDEHOFT: What is your current occupation?
ALEJANDRA ROMERO: I work at the front desk of the Eastern Columbia Building.
MS. BREDEHOFT: And is that for the Action Property Management Company?
ALEJANDRA ROMERO: That's correct.
MS. BREDEHOFT: How long have you been employed at the Eastern Columbia Building?
ALEJANDRA ROMERO: Approximately, 13 years.
MS. BREDEHOFT: And could you, please, describe what kind of work you do for the Eastern Columbia Building?
ALEJANDRA ROMERO: Most of all, it's just access control, and I deal with a lot of residents regarding their packages and food deliveries.
MS. BREDEHOFT: Okay. And have you done that pretty much the whole ten years?
ALEJANDRA ROMERO: That's correct
MS. BREDEHOFT: I'm going to take you back to 2015 and 2016 for a moment.
ALEJANDRA ROMERO: Okay.
MS. BREDEHOFT: How many people would you say would go through the building on any particular day in that time period? I'm talking tenants and visitors.
ALEJANDRA ROMERO: I cannot say a number because there's 15147 units in the building and there's - they have visitors, guests, friends. Actually, we used to send delivery people up. We don't send them anymore because of the COVID. But I cannot tell you a number. There's thousands of people, probably.
MS. BREDEHOFT: Have you ever met Johnny Depp?
ALEJANDRA ROMERO: I saw him a couple of times.
MS. BREDEHOFT: Do you remember what Mr. Depp was wearing on any of those occasions?
MS. BREDEHOFT: Do you remember what jewelry he had on?
MS. BREDEHOFT: Do you remember what headgear he was wearing, was he wearing a scarf or a hat?
MS. BREDEHOFT: Do you remember whether Mr. Depp was wearing any makeup or eyeliner?
ALEJANDRA ROMERO: No, I don't remember. Nope.
MS. BREDEHOFT: You can't remember whether he had any, right?
MS. BREDEHOFT: Do you know whether Mr. Depp had ever been physically violent with Amber Heard? And by this, I mean hitting, punching, throwing objects at her, kicking her, headbutting her. Do you know, one way or the other, whether Mr. Depp ever did that to Ms. Heard?
ALEJANDRA ROMERO: Nope.
MS. BREDEHOFT: Did you ever see Mr. Depp slam things p around or be angry?
ALEJANDRA ROMERO: No, I have never seen him like that.
MS. BREDEHOFT: I'm going to ask you some questions, now, about Amber Heard.
MS. BREDEHOFT: When did you first meet Amber Heard? ,6
ALEJANDRA ROMERO: I believe she was passing in the lobby, or maybe it was the front desk. Like, I interact more with her sister, Whitney, I believe that's her sister's name, and her good friend Raquel, Rocky. But Amber, I've only seen, like, once in a while when she was -- when she would get packages.
MS. BREDEHOFT: Do you recall whether Ms. Heard became a resident sometime around March 2016?
ALEJANDRA ROMERO: Don't remember.
MS. BREDEHOFT: Could you tell me one way or the other?
ALEJANDRA ROMERO: I just can't remember. Like I said, it's been so long. I just don't remember. And, it's like, I know you guys sent me those papers to review, and I've got to be honest, I didn't want to review them because it's been so long. It's like, I don't want to deal with this anymore.
ALEJANDRA ROMERO: Yes, I went through the witness I statement and it's everything that is written there that's what I said.
MS. BREDEHOFT: Okay.
ALEJANDRA ROMERO: That was correct. It was accurate.
MS. BREDEHOFT: Okay.
ALEJANDRA ROMERO: That's why I signed it.
MS. BREDEHOFT: So during the time between 2015 and 2016, how many times would you say, total, that ,9 you interacted with Amber Heard?
ALEJANDRA ROMERO: For a whole year, I don't think I can give you a number. Because it could be, like, probably I see - probably saw Amber three times in one day, probably I'd see her five times, and probably I would never see her for a whole week. So I don't have, like, there's never been a routine.
MS. BREDEHOFT: Okay. How would you describe Amber Heard's interactions with you? Were they friendly? Did she smile at you? Did she talk to you?
ALEJANDRA ROMERO: She was really friendly She always smiled But she we never had like an interaction of really close relationship like I do with some of the other residents She never told me any of her problems She never stopped by and talk about her personal life She never did that.
MS. BREDEHOFT: They're asking you about a date that you recall seeing Amber Heard on May 25th, 2016.
MS. BREDEHOFT: Do you see that?
ALEJANDRA ROMERO: Yes, I do.
MS. BREDEHOFT: And you said, "Probably. I just can't remember the days. I've got a really bad memory for dates."
MS. BREDEHOFT: Do you see that?
ALEJANDRA ROMERO: Yep.
MS. BREDEHOFT: So, Mr. Romero, would you, at any time, be able to remember what type of clothing Amber Heard was wearing from one of her events?
ALEJANDRA ROMERO: Nope. I don't remember.
MS. BREDEHOFT: Would you remember, on any daily basis, what type of hairstyle she was wearing?
ALEJANDRA ROMERO: Nope.
MS. BREDEHOFT: Would you remember, on any type of basis, what type of bag she was -- Amber Heard was carrying?
MS. BREDEHOFT: Would you be able to say whether she, Amber Heard, was dressed up or casual on any certain day?
MS. BREDEHOFT: Would you be able to say whether she was -- what type of makeup Amber Heard was wearing on any given day?
MS. BREDEHOFT: Would you be able to say, for example, whether Amber Heard had on concealer or foundation on any given day?
MS. BREDEHOFT: Would you be able to say whether Amber Heard had on blush or powder on any given day?
MS. BREDEHOFT: Would you be able to say whether Amber Heard had any mascara or eyeliner on, on any given day?
MS. BREDEHOFT: How about eyebrow pencil or lip pencil?
MS. BREDEHOFT: Do you have any memories of Amber Heard wearing a particular type of makeup with a type of outfit?
MS. BREDEHOFT: If you were asked to describe any characteristics of Amber Heard from two days earlier, without knowing you were going to be IO asked, would you be able to testify to any of those, what she was wearing, what her makeup was, what her hairstyle was?
ALEJANDRA ROMERO: No, I won't -- probably won't remember.
MS. BREDEHOFT: When was the first time that you recall anyone saying anything to you about the police being called at the EC Building because of a domestic dispute between Mr. Depp and Amber Heard?
ALEJANDRA ROMERO: Well, to answer your question, whatever happened, it happened on a Saturday. I don't work Saturdays. When I got there on Monday, they asked me, oh, you heard what happened? I said, no, what happened? So that's how I find out.
MS. BREDEHOFT: Okay.
ALEJANDRA ROMERO: Then I went to the cameras to see what was going on. Then as soon as I saw Johnny Depp on the camera and the elevator, just walking back Is and forth on the camera in the elevator, I said, okay, I know that was him, and that's all I knew. But I was never - I was never - I was not there on that Saturday when that happened. I believe that whenever that happened, they say it Ito happened, when they called the police, I believe 111 it was on a Saturday, and I was not there.
MS. BREDEHOFT: Okay. Do you recall who told you that on that Monday following Saturday?
ALEJANDRA ROMERO: Okay. As a matter of fact, I think it was one of the residents. They approached me and they said there was a lot of noise, and the person was working out on the gym that's next to the penthouse. They heard of bunch of noise and that's it. That's why I checked the cameras. When I looked at the cameras and I saw Johnny, like I said, just walking back and forth at the elevator, I said, okay, all right, okay. I'll try to figure it out. I didn't say anything more. I turned off the camera, and that's it.
MS. BREDEHOFT: So, the first part of that, who's -- somebody was working out and heard noises?
ALEJANDRA ROMERO: Somebody was working out in the gym and heard the noise, they heard a lot of noise in the hallway. It's really rare to hear anything because, most of the time, the penthouse level is really quiet.
MS. BREDEHOFT: Okay. Do you remember who the person was in the gym, that heard a lot of noise in the penthouse that night?
ALEJANDRA ROMERO: That's correct. I do remember the person.
MS. BREDEHOFT: Who is it?
ALEJANDRA ROMERO: I remember the person has been a resident of the building for a long time, I just don't remember their -- I don't remember her name.
MS. BREDEHOFT: And where is the gym in comparison to the penthouse that's owned by Mr. Depp?
ALEJANDRA ROMERO: Like I said, Johnny Depp owns the penthouse below the clock, and the gym at the Eastern Columbia Building is just in front of one of the penthouses. You actually can see it through the window.
MS. BREDEHOFT: You can see the gym through a window of the penthouse or you can see the penthouse through a window of the gym?
ALEJANDRA ROMERO: You can see the gym through one of the windows of the penthouse, and they have a patio that leads to the gym. Penthouse has a patio that leads to the gym.
MS. BREDEHOFT: Okay. And this tenant, if you think of her name while, you know, even if we're asking another question, please, let me know. This tenant is a resident there, right, that saw this?
ALEJANDRA ROMERO: Yeah. I believe her name is Shauna (phonetic).
MS. BREDEHOFT: And, so, she told you she heard a lot of noise?
ALEJANDRA ROMERO: That's correct.
MS. BREDEHOFT: Did she describe anything, voices, any objects, anything like that?
ALEJANDRA ROMERO: No. She just said there was a noise. Just noise. And that she was just surprised because, like I said, it's always really quiet.
MS. BREDEHOFT: Okay. And so, she wanted to know what happened. And so, you went to the video cameras to look at a video.
MS. BREDEHOFT: How did you know when to look for them?
ALEJANDRA ROMERO: Because she had the time. She had the time that she was working out. That's why I figured out to track the time on the camera and looked. And then when I saw, as soon as I saw, like I said, Johnny Depp walking back and forth in the elevator, I turned off the camera, and I figured out, okay, this is what happened. I figured out, one and two together, okay.
MS. BREDEHOFT: When you said you figured out what happened after you saw Johnny Depp in the elevator, what did you figure out had happened?
ALEJANDRA ROMERO: I figured that's why they called the cops, the police.
MS. BREDEHOFT: Because why?
ALEJANDRA ROMERO: Approximate because of the noise that was on the penthouse level.
MS. BREDEHOFT: Mr. Romero, I'm going to ask you to look at this. This is a video clip marked as Romero Exhibit Number 8.
MS. BREDEHOFT: It shows the date and times tamp near the bottom. Is Do you recognize this as the elevator at ECB building?
ALEJANDRA ROMERO: That's correct.
MS. BREDEHOFT: Mr. Romero, you're nodding. Is this the video that you remember looking at after Shauna told you she heard the noise that night?
ALEJANDRA ROMERO: That's correct.
MS. BREDEHOFT: And that's Mr. Depp?
MS. BREDEHOFT: AQ Correct. Do you recognize the other two men in the elevator?
ALEJANDRA ROMERO: I recognize the guy in front of the elevator button. That's his personal bodyguard. The other guy, I've seen him before, but I never interact with him. If I did, I don't remember.
MS. BREDEHOFT: You said he looked --
ALEJANDRA ROMERO: Yeah, he looked agitated. Like, he was walking back and forth. He had his jacket His body language was different than before. Most of the time, he's really calm He's just, like, a really happy person. This is the first time I saw him like that.
MS. BREDEHOFT: And then you go to the next -- so then you say Wednesday, May 25th, at approximately 10:30, Ms. Heard walked into the lobby accompanied
ALEJANDRA ROMERO: Yes, that's correct.
MS. BREDEHOFT: And you said that Ms. Heard approached you to ask you for the key to her unit, which you gave her. And you said you did not discuss anything else at that time.
ALEJANDRA ROMERO: Correct.
MS. BREDEHOFT: Ms. Heard stood approximately three feet away from you. I did not notice any bruises, cuts, swelling, red marks or any other injuries of, g, any kind on Ms. Heard's face.
MS. BREDEHOFT: Do you see that? Correct. Okay. But you weren't looking for bruises, cuts, red marks or any other injuries on Ms. Heard's face that night, were you?
ALEJANDRA ROMERO: I was not looking for any marks or bruises or anything. But something like that, it would be really noticeable. But, I guess, you know, I was not looking. I was more focusing on what my job duties were, like getting the key and, also, I gave her the key and they were talking about -- I told her, you know what, your dog -- I was talking with Raquel because her dog got out of her unit. That was one of my concerns. I told her, you know what, I saw your dog was outside. You didn't want me to get too close to it, so it's still out there.
ALEJANDRA ROMERO: In the penthouse area, the dog will be fine because it's not -- like I said, it's always really quiet and Mr. Depp owns everything up there, so he'll be fine. So that was one of my concerns. That was my job, and I was just taking care of that. I was not trying to say, oh, let me see your face, no.
MS. BREDEHOFT: So -- and that's where I'm going to follow up.
MS. BREDEHOFT: Do you remember what Ms. Heard was wearing that night?
ALEJANDRA ROMERO: Nope.
MS. BREDEHOFT: Do you remember whether she was dressed up?
MS. BREDEHOFT: Do you remember where she was coming from that she was coming home at 10:30 at night with Ms. Pennington?
ALEJANDRA ROMERO: No, I don't remember. They didn't mention to me. Actually, she was on the phone. She was with Raquel, in front of me. We were talking about it, and then she left to the lobby, where she was still on the phone. I was focusing more on Raquel because I was telling her about her dog.
MS. BREDEHOFT: Okay. Do you remember what hairstyle Ms. Heard had that night?
ALEJANDRA ROMERO: Nope.
MS. BREDEHOFT: Do you know what type of makeup Amber Heard was wearing that night? 1
MS. BREDEHOFT: Can you tell me whether she was wearing l any concealer or foundation?
MS. BREDEHOFT: Can you tell me whether she was wearing blush?
MS. BREDEHOFT: Could you tell me whether she was wearing any type of -- any kind of eye makeup.
MS. BREDEHOFT: So, who wrote the sentence "I did not I notice any bruises, cuts, swelling, red marks, or 116 any other injuries of any kind on Ms. Heard's face"?
ALEJANDRA ROMERO: I'm pretty sure if I would have seen something like that, I would have said something.
MS. BREDEHOFT: Mr. Romero.
ALEJANDRA ROMERO: I didn't saw any marks or bruises on her face. I just don't recall. I don't saw anything. She was just standing in front of me.
MS. BREDEHOFT: I'm asking, specifically, "I did not notice any bruises, cuts, swelling, red marks or face," who wrote that? any other injuries of any kind to Ms. Heard's
ALEJANDRA ROMERO: That's what I said. I didn't saw any marks or bruises on her face. That's what I said.
MS. BREDEHOFT: But--
ALEJANDRA ROMERO: Because they asked me, they asked me if I remember seeing anything, and I just don't recall seeing any marks or bruises because she was just standing in front of me. I just don't remember anything, anything. I just don't remember. If it would have been so obvious, like, someone had, like, a black eye, I would have, like, whoa, you know. I would have seen that, and I would have remembered because it's something that you will see. You know, like, so none of them were like, oh, you will remember.
ALEJANDRA ROMERO: But when I was there talking to her, she was, like, three feet away from me, she was right in front of me. I just don't remember seeing any marks, bruises, j g y or anything.
MS. BREDEHOFT: But you don't know whether she was wearing makeup to cover it, do you?
ALEJANDRA ROMERO: No, I don't -- no. If she was wearing any makeup to cover it, probably, you know-- probably would you -- probably you would cover any bruise, but you cannot cover the swelling.
MS. BREDEHOFT: Were you looking for swelling?
ALEJANDRA ROMERO: No. Like I said, I was not looking for anything.
MS. BREDEHOFT: In fact, you were spending more time talking to Rocky about her dog; were you not?
ALEJANDRA ROMERO: That's correct. But I got a habit, when I'm talking to someone, I look into their eyes. And when I was talking to Amber and Rocky, I always look into their eyes.
MS. BREDEHOFT: Okay.
ALEJANDRA ROMERO: And I probably would have noticed, like, any swelling or bruise, like I said. I probably would notice.
MS. BREDEHOFT: Fair to say, Mr. Romero, that you can't say that Amber Heard had injuries or did not have injuries that day, on the 25th?
ALEJANDRA ROMERO: I don't remember.
MS. BREDEHOFT: Okay.
ALEJANDRA ROMERO: Like I said, I would probably remember the swollen, but I never saw anything. I just don't remember.
MS. BREDEHOFT: And you don't remember seeing anything, I 8 right? But do you remember even looking?
ALEJANDRA ROMERO: I remember - I remember I was - okay, I'm really sorry, but I remember - I've got to tell the whole story, probably, to get there. Before the guy went and got the key, they come down. They said somebody tried to get into my unit There's scratches on my door. And, like, I'm really sorry, but who would think they get into the unit because there's some scratches on the door, like, what, four inches above the door? Because the dog was scratching the door, was trying to get in, and they thought that someone was trying to break into their unit. In my head, I was like, you really think somebody's trying to get into your unit? There's scratches, like, four inches above the floor on your door. That was your dog trying to get into the unit. They were so afraid. Oh, someone's trying to get into my unit. Oh, come on, really? And I actually went, they asked me to go inside the unit to check room by room, to make sure no one was there. So I did that, part of my job, make sure they're safe, but I was, like, really? I didn't understand why they want me to do that. Like, I don't know.
ALEJANDRA ROMERO: Just so stressed out because of this. I just don't want to deal with this anymore. I'm tired. I don't want to deal with this court case. Everybody's got problems and I don't want to deal with it no more. I don't want to put any more words.
MS. BREDEHOFT: The interaction you just testified about with Amber Heard and Rocky Pennington and talking about the dog and going up and checking about the penthouse, none of that was on video footage, correct?
ALEJANDRA ROMERO: That's correct. We don't have cameras in the video - sorry, we don't have cameras in the hallways.
MS. BREDEHOFT: I'm going to show you what has been marked as Romero exhibit Number I, the deposition that was taken of you on July 19, 2016. Now, that's, approximately, two months after the May 21, 2016 incident.
MS. BREDEHOFT: Do you recall giving that deposition?
ALEJANDRA ROMERO: '16? Probably. I don't remember.
MS. BREDEHOFT: I'm going to take you to page 35. And you were asked, this is the same incident that you're talking about now, okay? And it's talking about, okay, you spoke with Amber at the front desk, later saw her in the lobby, later went upstairs with her.
MS. BREDEHOFT: It says the question, at line 6, "I just want to go back for a second here. You said several times, in answer to my questions, that you didn't recall seeing any marks on Amber's face.
MS. BREDEHOFT: When you say you didn't recall seeing any of those marks, any marks, did you mean that you didn't see any marks on her face? And your answer, then, was, "I say that because when I saw Amber, I was not looking to see anything on her face. I was not looking to see anything.
MS. BREDEHOFT: Do you recall giving that testimony, under oath, back at that time, two months after the incident?
ALEJANDRA ROMERO: Yes. I remember. Because, like I said, I was - I always make eye contact with someone that I'm talking to, but I'm not looking to find something, like, oh, your makeup is wrong, you haven't change your eyebrows, or your eyelashes are not even. I'm not looking for anything. I'm just looking at their eyes. I'm not looking for anything else.
ALEJANDRA ROMERO: But, if I see something, I would- probably would remember.
MS. BREDEHOFT: If you saw something, right?
ALEJANDRA ROMERO: Yeah. I would have probably seen, like, if she had a swollen, like if she was wearing makeup, probably would still seen the swollen. I probably would remember that. But I have not looking for anything. I was like, oh, you know.
MS. BREDEHOFT: How swollen was Amber on the 25th of May? How swollen was her cheek?
ALEJANDRA ROMERO: According to the pictures I've been seeing right now, that you're showing me, it was pretty swollen. I probably would remember that.
MS. BREDEHOFT: How many days later did you see her from that swelling?
ALEJANDRA ROMERO: That was on a Wednesday. That was from Saturday to Wednesday.
MS. BREDEHOFT: Right.
ALEJANDRA ROMERO: Correct.
MS. BREDEHOFT: Would it be fair to say that you cannot testify, one way or the other, whether Amber Heard was domestically abused by Johnny Depp on May 21, 2016?
ALEJANDRA ROMERO: I cannot say that. I would not agree to testify against anyone of domestic violence because I was not there. I didn't see anything.
ALEJANDRA ROMERO: I didn't hear anything. I was not there. I was never there. I was probably hundreds of miles pictures of wine, a glass of wine and a bottle of wine, wine stains on the floor outside of the -- in the hallway of the penthouse from May 21st, 2016? I remember seeing a mark. I'm not going to say it was mine.
MS. BREDEHOFT: Allright. Well--
ALEJANDRA ROMERO: I'm not an expert.
MS. LECAROZ: Ladies and gentlemen, the next portion of this deposition contains questions asked by counsel for Mr. Depp.
MR. PRESIADO: Sitting here today, when you saw her at the front desk on March 25th, you didn't see any bruising, correct?
ALEJANDRA ROMERO: Correct
MR. PRESIADO: And you didn't see any marks, correct?
ALEJANDRA ROMERO: That's correct I didn't see any marks or bruises.
MR. PRESIADO: You didn't see any swelling, did you, Mr. Romero?
ALEJANDRA ROMERO: That's correct. No swelling.
MR. PRESIADO: And she was only three or four feet away from you, correct?
ALEJANDRA ROMERO: Correct.
MR. PRESIADO: And you were looking right into her face, squarely, correct?
ALEJANDRA ROMERO: Correct.
MR. PRESIADO: And the lighting was good at the front desk, correct?
ALEJANDRA ROMERO: Correct.
MR. PRESIADO: It was so good that had she had any bruises, swelling, or marks on her face, you would have noticed that, correct?
ALEJANDRA ROMERO: Correct.
MR. PRESIADO: And then later that -- later that same day, and you testified to this already today, later that same day, you went up the elevator with Ms. Heard and Ms. Pennington in connection with their request for you to check the penthouse correct
ALEJANDRA ROMERO: That's correct.
MR. PRESIADO: And during that entire period of time, taking them up to the penthouse, walking through the penthouse, and then finally you leaving and going back to your desk, you did not -- you looked at Ms. Heard during that time period, correct?
ALEJANDRA ROMERO: That's correct.
MR. PRESIADO: And you looked her in the face, squarely in the face, correct?
ALEJANDRA ROMERO: Correct.
MR. PRESIADO: And you didn't notice any swelling, correct?
ALEJANDRA ROMERO: Correct.
MR. PRESIADO: I'm sorry?
ALEJANDRA ROMERO: Correct. I never saw anything.
MR. PRESIADO: Did you see any swelling?
MR. PRESIADO: Did you see any bruises?
ALEJANDRA ROMERO: Nope.
MR. PRESIADO: Did you see any evidence on her face of any kind?
ALEJANDRA ROMERO: No marks at all.
MR. PRESIADO: And, again, just to repeat, when you were at the front desk looking at her face, did you see any swelling on her face?
MR. PRESIADO: Did you see any bruises on her face?
MR. PRESIADO: Did you see any marks, of any kind, on Is (9 her face?
ALEJANDRA ROMERO: No marks at all.
MR. PRESIADO: And how was the lights down when you were at the reception and you were looking at her and you didn't see any of this? How was the lighting?
ALEJANDRA ROMERO: The lighting was pretty good. It was not dark at all.
ALEJANDRA ROMERO: AQ How far away was she? I Three to four feet apart.
MR. PRESIADO: Were you looking her square in the 120 face?
ALEJANDRA ROMERO: Correct.
MR. PRESIADO: Okay. And when you were up in the penthouse and you were looking her square in the face, how far apart were you from her then?
ALEJANDRA ROMERO: We actually were pretty close to each other. She was probably just next to me. She was telling me, like, go into this room. So I need to pack right in front of her.
MR. PRESIADO: And do you recall seeing any bruises, swelling, redness, or any marks on Ms. Heard's face on May 24th, 2016?
ALEJANDRA ROMERO: I don't recall seeing anything.
MS. LECAROZ: Ladies and gentlemen, at this point, the remainder of this deposition of this witness contains questions by counsel for Ms. Heard.
MS. BREDEHOFT: I'm going to talk a little bit about the video clips that Mr. Depp's attorney showed you I'm going to ask you, first of all, Mr. Presiado showed you a number of video clips from May 24th. Do you recall that?
ALEJANDRA ROMERO: May 24th?
MS. BREDEHOFT: Yes.
ALEJANDRA ROMERO: That's Tuesday.
MS. BREDEHOFT: But, in fact, you don't recall seeing Amber Heard on May 24th, correct?
ALEJANDRA ROMERO: I don't remember. I don't even remember what I got for breakfast.
MS. BREDEHOFT: Okay. Well, let's pull up exhibit Number 1. Let's stay on page 17, that's a good place. This is your deposition from July 19, 2016.
MS. BREDEHOFT: Do you recall that?
ALEJANDRA ROMERO: 19th? Yeah.
MS. BREDEHOFT: Okay. And that's --
ALEJANDRA ROMERO: That was 3 :00 in the morning.
MS. BREDEHOFT: Okay. And it says here, "So Saturday was the 21st. Did you work that day?"
MS. BREDEHOFT: "No."
MS. BREDEHOFT: Did you work Sunday, May 22nd? No. Did you work May 23rd? Yes.
MS. BREDEHOFT: "On May 23rd, when you were working, did you see Amber at any time?"
MS. BREDEHOFT: "I don't recall seeing her."
MS. BREDEHOFT: "Question: Did you work on Tuesday, May 24th?"
MS. BREDEHOFT: "Yes,I did."
MS. BREDEHOFT: "On Tuesday, May 24th, at any time, did you see Amber?" "I don't recall seeing her."
MS. BREDEHOFT: Do you recall that being your testimony two months after the events?
ALEJANDRA ROMERO: Yeah. I just don't recall. I don't remember.
MS. BREDEHOFT: Okay. Then while we're here -- now, Mr. Presiado had you go through a number of video clips and asked you a bunch of questions about whether you saw swelling, whether you saw red marks, whether you saw all other kinds of things. But, in fact, I'm going to ask you, and tell me if you need me to bring up the videos and replay them, can you tell me what type of makeup Amber Heard was wearing in any of those videos?
ALEJANDRA ROMERO: No. I can't - I can't tell.
MS. BREDEHOFT: You can't tell me?
ALEJANDRA ROMERO: I don't even know if she was wearing any lipstick.
MS. BREDEHOFT: Can you tell --
ALEJANDRA ROMERO: I don't know.
MS. BREDEHOFT: Can you tell me whether Amber Heard was wearing concealer in any of those videos?
MS. BREDEHOFT: Can you tell me whether Amber Heard was wearing any foundation in any of those videos?
ALEJANDRA ROMERO: No. I can't tell you.
MS. BREDEHOFT: Can you tell me whether Amber Heard was wearing any blush in any of those videos?
MS. BREDEHOFT: Can you tell me whether Amber Heard was wearing any powder in any of those videos?
ALEJANDRA ROMERO: No. But she looked pretty pale.
MS. BREDEHOFT: Well, do you know what shade of 1 21 concealer or foundation or powder Ms. Heard uses "22 or used at that time?
MS. BREDEHOFT: Okay. So you don't know whether Ms. Heard was wearing makeup in every one of those video clips, correct?
ALEJANDRA ROMERO: Correct.
MS. BREDEHOFT: I'm trying to move along. So, the incident was May 21st, 2016. You saw her the night of May 25th, correct?
ALEJANDRA ROMERO: Correct.
MS. BREDEHOFT: So you saw Amber Heard hundreds of , 11 times while she was -- did she treat you well and was she friendly to you these hundreds of times?
ALEJANDRA ROMERO: Yes, yes. I'm not going to say no, because she was really always nice. She would be nice.
MS. BREDEHOFT: All right. This is my last question. You testified, in response to Mr. Presiado's questions, that you testified truthfully in all of these occasions. Did you testify truthfully to everything that you testified in response to my questions today?
ALEJANDRA ROMERO: That's correct.
MS. BREDEHOFT: All right.
ALEJANDRA ROMERO: I did