Malcolm Connolly — Direct/Cross/Redirect

THE COURT: Can you turn your camera on, sir?

MALCOLM CONNOLLY: Okay. There we go.

THE COURT: All right. Sir, if you could raise your right hand. MALCOLM CONNOLLY,

THE COURT: Being first duly sworn, was examined ,9 and testified as follows: EXAMINATION BY COUNSEL FOR THE PLAINTIFF AND

MR. MONIZ: Good afternoon, Mr. Connolly.

MALCOLM CONNOLLY: Good afternoon

MR. MONIZ: And would you please state your full name for the record.

MALCOLM CONNOLLY: Malcolm Connolly.

MR. MONIZ: And, Mr. Connolly, where are you testifying from at the moment?

MALCOLM CONNOLLY: From home, Essex, U.K.

MR. MONIZ: And where do you live?

MALCOLM CONNOLLY: I live Essex, U.K.

MR. MONIZ: Mr. Connolly, what is your occupation?

MALCOLM CONNOLLY: At present, close protection operative. I've had a couple professions. I'm a bricklayer trade. I was in the corrections facility in Chelmsford, HMS prison. Right now, yeah, I'm a protection officer.

MR. MONIZ: Okay. And can you tell us a little bit just generally what that means?

MALCOLM CONNOLLY: That means looking after the personal O well-being and physical well-being of any client for detail, sir.

MR. MONIZ: And how long have you been in the personal security business?

MALCOLM CONNOLLY: 25 years.

MR. MONIZ: Over the course of those 25 years, have you had any other kinds of jobs?

MALCOLM CONNOLLY: Yeah. As I said, I was a corrections officer for a magistrate prison.

MR. MONIZ: Okay. Are you familiar with the plaintiff in this case, Johnny Depp?

MALCOLM CONNOLLY: I am, yes.

MR. MONIZ: And how do you know Mr. Depp?

MALCOLM CONNOLLY: I met Mr. Depp long -- maybe about 23 years ago, 24 years ago, I worked for a company called Music and Arts. The guy who owned that company was Jerry Judge. Jerry started working with Johnny way back in the early days, and I was detailed looking after Johnny's ex, Vanessa Paradis, and Jack and Lily-Rose, Johnny's kids. My job is just to make sure they were safe when Johnny was at work.

MALCOLM CONNOLLY: So that job, after about a year and a half, two years, Johnny asked me to go with him directly and to find someone else to do the kids. And that's how I came across Johnny. That's how I personally met Johnny Depp.

MR. MONIZ: Can you ballpark for us about what year that was?

MALCOLM CONNOLLY: Oh,2006.

MR. MONIZ: Okay. And can you generally just tell us a little bit about what you do for Mr. Depp as his security guard?

MALCOLM CONNOLLY: I escort Johnny to everyday public places, make sure he's okay, make sure, you know, he's not in any danger. First of all, you do your recce, you know, you go along first. It was usually a two-man team It's a two-man detail. You go along, do your recce, make sure all the ins and outs are sorted, no compromises, any risks involved, risk assessment. Do the job. I look after him - basically I look after Johnny whenever they're in the public domain. Whenever we're going to be in the public domain, I will look after Johnny.

MR. MONIZ: Okay. And how about the defendant in this case, Amber Heard? Are you familiar with Ms. Heard?

MALCOLM CONNOLLY: I am familiar with Ms. Heard, yeah. I first met Ms. Heard in probably 2000 and - I don't recall the exactly date. Probably about 1172010, around there. She came into the U.K to do a promotional job for a movie called Drive Angry. My boss, Jerry Judge, asked me to take the detail. Went and met Amber, started the job. Amber was with her ex, Tasya, and I looked after Amber for a week, pleasant week.

MR. MONIZ: Did anything --

MALCOLM CONNOLLY: And then - sorry. Yeah. After that week, I never seen Amber again until we did Rum Diary, the premiere, lS after-show of Rum Diary.

MR. MONIZ: Okay. So let's move to the Rum Diary then.

MR. MONIZ: When did you see Ms. Heard -- well, how did you see Ms. Heard in connection with the Rum Diary?

MALCOLM CONNOLLY: We done the Rum Diary premiere. We went to the after-show party. I was busy working, doing my job, myself and Jerry Judge. Seen Amber across the floor, Amber seen me. Just basically come across the floor said, "Hello. How are you doing?" You know, the usual chitchat. We chitchatted for a minute or two. Johnny asked me how I knew Amber. Explained that's the last I saw Amber I was with Johnny doing my job, you know.

MR. MONIZ: Did you know at the time in -- well, let's back up for a second. Where was that premiere?

MALCOLM CONNOLLY: Do you know what? I don't recall. I think it was in LA.

MR. MONIZ: Okay.

MALCOLM CONNOLLY: I don't actually recall.

MR. MONIZ: Okay. Did you know at the time of that premiere in probably LA but possibly somewhere else, did you know at the time that Mr. Depp and Ms. Heard were seeing each other romantically?

MALCOLM CONNOLLY: No, I didn't. I actually didn't. I mean, I surmised there was a spark there, you know. It wasn't until maybe a few days later, a few nights later, we were at a dinner party somewhere, a promotional thing, Amber and Johnny were basically sparking up. Then again I assumed, you know, there was a romance out there, budding there, you know.

MR. MONIZ: Okay. Over the course of Mr. Depp and Ms. Heard's relationship with each other, about how often would you say you saw them together?

MALCOLM CONNOLLY: Oh, in the beginning, actually not a lot, you know. Not a lot. Maybe once a week, twice a week, average. But then it started maturing something in their relationship, so more often, more often entertainment line, you know.

MR. MONIZ: And as time went on, did you have an opportunity to observe how Mr. Depp and Ms. Heard interacted with each other?

MALCOLM CONNOLLY: At the beginning, oh, you know, lovey-dovey, everything was great, honeymoon period was on, and it was - yeah, it was good. I mean it was great, great to see Johnny happy again. Amber was, you know, lovely, charming, as she usually is, you know, good as gold. Then things, you know, things started to change. Amber started to change. Amber started getting a bit, I would say, a bit more feisty, demanding, you know. I could see that Amber wanted to wear the pants in this relationship. That was quite obvious.

MR. MONIZ: And what in particular made you think that, that you observed personally?

MALCOLM CONNOLLY: Just the way, you know, if something wasn't quite right, Amber could get a bit frosty if you talk about that. So it was, you know, I could see them change; I could see Amber change. I could see Johnny getting quieter. We'd get in the car, and 'nobody's speaking. And, you know, just things started changing, changing. Amber started to get a bit more grumpy, I shall say.

MR. MONIZ: How did she get along with you?

MALCOLM CONNOLLY: Actually very nice. Amber was fine with me. Amber was never anything but professional, polite, with me, you know, if she was there. No, Amber was fine by me.

MR. MONIZ: Did you ever see or hear any arguments between Mr. Depp and Ms. Heard?

MALCOLM CONNOLLY: When you say "see," I have. I mean, I could hear a change in setting accommodations, where we were staying at I could hear Amber, yeah, screaming, you know. I could hear shouting and bawling and, yeah, I could hear it going on, yes. I mean, I wasn't there every single night. When we were working in the U.K, there's nights maybe I go home because Jerry would be there. But, yeah, yeah, definitely. Definitely a fight, I could hear sometimes, the shouting and bawling, you know. Mostly I could hear Amber screaming, you know.

MR. MONIZ: About how -- I recognize this is years ago but, can you estimate for us how regularly that happened?

MALCOLM CONNOLLY: I can't say regularly. I can't say it was like every day. But, you know, it got more regular. It got more often than not

MR. MONIZ: Did you ever witness any physical violence between the two of them?

MALCOLM CONNOLLY: No. No, I never seen any physical violence. That's not a thing people would do in front of security. It's not a thing that happened in front of myself or Jerry Judge or Sean Bett. It just wouldn't happen. It wouldn't happen. No, I never seen any physical security. I never seen any hands-on, no.

MR. MONIZ: Okay. What do you mean you never saw I any hands-on?

MALCOLM CONNOLLY: Well, I never seen any slapping or grabbing or punching or hitting. I never seen any of that physically. Well, I'll tell you what. There was an incident, maybe two incidents, that come in my mind. One incident was on a private plane. In fact, I can't recall if it was a domestic flight or an international flight. I'm sitting -- Johnny and Amber -- or Johnny and whoever he's flying with, was up at the fore-table, the fore-table, or aft, and then myself and my colleagues were sitting in the front end of the plane. So I usually wake up in the fuselage, that way, with my back to the noise.

MALCOLM CONNOLLY: Amber had her back to me, Johnny sitting across the table, and there's a bit of bickering, and I cannot hear because, you know, we're talking about jet craft, I can't actually hear, and it's more animated than verbal.

MALCOLM CONNOLLY: And I see a liter, a plastic liter bounce off his chest, boom, you know, bounce off his chest. So I think well, this is going to escalate, either going to go one way or the other. I don't think it came to much. I remember Johnny just smirking and looking away as if to say, you know, "Is that it?" kind of attitude, you know. Then Johnny tipped his hat up, put his head against the window, and whoa, you know.

MALCOLM CONNOLLY: Another time, it was at the loft apartment. I was in the security room in the loft apartments with security guard - do you know what, I can't recall if it was Sean Bett or a guy called Donovan. Anyway, I got the text, it was Johnny. I picked him up to go to the West Hollywood accommodation. And I got the text.

MR. NADELHAFT: Objection. To the extent he's going to talk about what the text says, that's hearsay.

MR. MONIZ: You can just tell us what you observed without recounting the contents of the text.

MALCOLM CONNOLLY: Okay. I'm instructed to go up and get Johnny, and, okay, we're leaving.

MR. NADELHAFT: Objection. He was just saying what he was instructed to do.

THE COURT: All right. I'll sustain the objection.

MR. MONIZ: What did you do after you received the text?

MALCOLM CONNOLLY: I go to the loft apartment, the door was ajar slightly, just slightly, just a crack in the door. Push the door open and I go in.

MALCOLM CONNOLLY: Shouting, there was shouting going on, and I can't really, I can't hear; I'm in the wrong area of the apartment But as I turn, as I turn to the left to more of the lounge area, there was a soda can. I don't know if it was a Coca-Cola or Sprite. I don't know what it was, but it's launched from the mezzanine. And Johnny's had this huge TV, the biggest TV I've ever seen. And it's on this mechanical arm which is an actual piece of art that Johnny had commissioned. Anyway, this big mechanical arm holds this TV. So this can of pop, if you want to call it pop, smashes on that by force.

MALCOLM CONNOLLY: I mean, a bang, boom. And all I can hear is it spraying all over the place. Johnny has already got his jacket on and a bag on his shoulder. That's why he's called me in, because we're leaving. I just pick up the other bags, two bags, pick up two bags, put my hands to Johnny's arm, and say, "Boss, we're leaving." We walk out the door. We walk out the door, and we go halfway to the West Hollywood, Johnny really calms down. He turns to me and is like, "Man" -

MR. NADELHAFT: Objection to the extent he's talking about what :Mr. Depp is saying. ,8

THE COURT: All right. I'll sustain that objection. Continue.

MR. MONIZ: If you have -- I

MR. MONIZ: I think we can move on.

THE COURT: Okay. All right.

THE COURT: Next question.

MR. MONIZ: Just to clarify, Mr. Connolly, when the soda can was launched from the mezzanine, where was Mr. Depp in relation to where the soda can landed?

MALCOLM CONNOLLY: Probably ten feet- probably ten feet back from that, ten feet back from that.

MR. MONIZ: Okay. And just to make sure we're on the same page, when you refer to the loft apartments, what are you referring to?

MALCOLM CONNOLLY: The downtown Columbia Eastern Building.

MR. MONIZ: Okay. What was your -- did you form any understanding as to who had thrown the soda can?

MR. NADELHAFT: Objection. Speculation.

THE COURT: Hold on, sir.

MR. NADELHAFT: Speculation, IO foundation.

MR. MONIZ: I'I'm just asking if he formed an understanding, and he can state the basis if he did.

THE COURT: Do you want to lay a foundation?

MR. MONIZ: To your knowledge, was Ms. Heard present in the apartment at that time?

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MR. NADELHAFT: Objection. Leading.

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THE COURT: I'll allow it.

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MALCOLM CONNOLLY: I never seen her physically, but I could hear her voice, yes.

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MR. MONIZ: And where does -- could you tell where her voice was coming from?

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MALCOLM CONNOLLY: Upstairs. Just upstairs.

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MR. MONIZ: Okay.

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MALCOLM CONNOLLY: She wasn't on the lower apartment that I saw; I can only imagine she was upstairs.

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MR. MONIZ: Other than the cigarette lighter and the soda can, anything else similar to that that you observed?

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MALCOLM CONNOLLY: No. No. I can't say, no.

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MR. MONIZ: Did you ever observe any physical injuries on Ms. Heard?

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MALCOLM CONNOLLY: Never, no.

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MR. MONIZ: How about on Mr. Depp?

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MALCOLM CONNOLLY: Yeah. Yes. Yes. Started off maybe a scratch once in a while or, you know, a swelling. But it got more. It got more, yeah. I'm not talking it was marks every week or every two weeks. But, yeah, he sustained marks, yeah, definitely. He was getting marks.

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MR. MONIZ: And can you describe for us what you can -- I . , 1 2

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MALCOLM CONNOLLY: Yeah.

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MR. NADELHAFT: Objection. Can we approach?

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THE COURT: All right. Hold on, Mr. Connolly, for a minute.

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[STAGE DIRECTION]: (Sidebar.)

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MR. NADELHAFT: I don't think it's Is relevant if he can't describe that it came from Amber Heard. He's just describing injuries -- O vague scratches. I mean, he had already said he's never seen Ms. Heard be physical, so now he's ! 12 going to describing just scratches?

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MR. MONIZ: Whether or not Mr. Depp has his injuries corroborates Mr. Depp's accounts of physical violence.

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MR. NADELHAFT: I think it outweighs -- if there's no relevance, you can't --

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MR. MONIZ: It goes to domestic violence. I mean, it's --

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THE COURT: I'm going to allow it, but you can cross-examine on it, okay?

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THE COURT: All right. Thank you.

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[STAGE DIRECTION]: (Open court.)

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[SECTION HEADER]: BY MR. MONIZ:

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MR. MONIZ: So, Mr. Connolly, you can continue responding. I think the question was just "Can you generally describe for us what you remember about the marks you saw on Mr. Depp?"

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MALCOLM CONNOLLY: Yes. As I was saying, independent service you're taught to pick up, log in your main mental -- logging in your main marks, bruises, belly patterns, stuff. What I knew as straightaway was most of these marks and most of these things in my training. I started the left-hand side of the face, and it would be scratches on his neck, maybe a fat lip you call, maybe a bruising on the eye socket. Dull impact, you know, except for obviously the scratches maybe on his left ear, sometimes mature marks, two lines, two charms, one yeah, you know, yeah.

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MALCOLM CONNOLLY: It was getting more regular. As I say, not every week, but it was definitely happening, yeah.

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MR. MONIZ: Can we see Plaintiffs Exhibit 162 please

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MR. MONIZ: And, Mr. Connolly, are you able to see the picture -- I assume you can see it on your screen?

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MALCOLM CONNOLLY: Yeah.

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MR. MONIZ: Yes. One second, please. Yeah, I, And do you --

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MALCOLM CONNOLLY: I understand -- yeah, I know that picture. I took that picture.

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MR. MONIZ: You took--

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MALCOLM CONNOLLY: That picture is actually on -- yeah, I took the picture.

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MR. MONIZ: Can you just quickly tell us what this picture is?

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MALCOLM CONNOLLY: This picture is a Ms. Heard and Johnny's honeymoon on the Orient Express on the east link from Bangkok to Singapore. You travel through Malaysia, stop in Calcutta, Kuala Lumpur, and a few other places, and that is in the dining coach, I think. Yeah, dining coach, that's what that is. The guy on the left there with a silver band around him is he's the waiter, he's the waiter of the details for the car for us. The guy in the tie, he's our relations manager.

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MR. MONIZ: Mr. Connolly, hold on. Before we continue describing the document.

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MR. MONIZ: I move for the admission of Plaintiffs Exhibit 162 and that it be published to the jury.

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THE COURT: Any objection?

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MR. NADELHAFT: I would like to approach.

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THE COURT: What's the objection?

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[STAGE DIRECTION]: (Sidebar.)

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MR. NADELHAFT: There's no foundation for the photo, just like yesterday's photos of the police officer.

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MR. MONIZ: He just said he took the picture.

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MR. NADELHAFT: Oh, he did? Okay. I missed that.

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THE COURT: So any objection to 162?

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MR. NADELHAFT: Then, no.

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THE COURT: All right. Thanks. 162 in evidence. You can publish it.

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[STAGE DIRECTION]: (Open court.)

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[SECTION HEADER]: BY MR. MONIZ:

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MR. MONIZ: All right. And, Mr. Connolly, I apologize for cutting you off. But could you just continue to describe for us what we're looking at in this picture.

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MALCOLM CONNOLLY: Yeah. As I said, the guy in the bow ! tie, he's a guest relations manager. He's detailed to, you know, fixes up anything we need, you know, the excursions and transports and stuff. Then Ms. Heard.

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MALCOLM CONNOLLY: The guy that's the chef, he looked after us, he cooked for us. He's a great chef, by the way. Yeah, he looked after us. And that's Johnny. And I also notice if you look at that picture, like I said, on the left-hand under his eye, there's a swelling. And you see swelling I just on the left-hand side of his nose and under his left eye.

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MR. MONIZ: And what do you interpret that swelling to be?

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MALCOLM CONNOLLY: What do I interpret that as? That he's walked into a door or a door's walked into him.

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MR. MONIZ: Okay. Can you tell us anything -- I 4

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MR. MONIZ: And we can take this down, I think. Thank you.

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MR. MONIZ: Mr. Connolly, can you tell us -- well, I 7 first of all, what -- do you recall what year Mr. Depp and Ms. Heard went on their honeymoon in the picture we were just looking at?

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MALCOLM CONNOLLY: That would -- I don't know, 2013. 2013.

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MR. MONIZ: Okay. And were you -- well, you testified that you took the picture, so you were there, I assume?

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MALCOLM CONNOLLY: Absolutely, yes.

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MR. MONIZ: What can you tell us about that trip generally, and particularly focused on how Mr. Depp and Ms. Heard were interacting with each other?

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MALCOLM CONNOLLY: Started off good. Started off good. Johnny's cabin was maybe 50 meters down the corridor from me. There was no cabins in between. There was, like, storerooms, like, you know, blankets and cutlery and stuff. So not a big massive distance, but, you know, it wasn't, like - the trip started to fain. Actually, it was fain. I think it was five, six days, five days, maybe two days, three days into the trip, I can see Johnny going down. I can see him coming down, you know. He's just not enjoying this. He's not enjoying this. But, you know, it's not my business to step in on that. I just did my job. But I can see he's not enjoying this. He's just not- he's not happy. He's not happy.

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MR. MONIZ: Did you ever observe any arguments between Mr. Depp and Ms. Heard in this time frame?

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MALCOLM CONNOLLY: Yes. They had no arguments. Ms. Heard started demanding, you know, to have her own dining car available. So me doing my job, I inquire to the guest relations guy that you see in the photograph, and he comes up and tells me that, you know, there's other VIPs on this train -

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MR. NADELHAFT: Objection, hearsay.

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THE COURT: All right. Objection to I hearsay? All right.

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MR. MONIZ: I think we can move on.

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THE COURT: Okay. I'll sustain the objection.

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THE COURT: Next question.

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MR. MONIZ: All right. So, Mr. Connolly -- well, taking a step back for a minute and changing topics slightly, have you ever seen Mr. Depp use any drugs?

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MR. NADELHAFT: Objection. Leading.

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THE COURT: I'll allow it. Go ahead.

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MALCOLM CONNOLLY: Yes. I seen him smoke marijuana. I had my suspicion, I had my suspicion that when he goes off to the bathroom, he probably does a line of cocaine. I've never seen him do it. Mr. Depp would never do a line of anything in front of me or Jerry Judge or Sean Bett or anybody. Mr. - Johnny would never compromise my license, my commission, and embarrass me like that. It wouldn't happen. So to answer your question, I've seen him smoke weed, yes.

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MR. MONIZ: Have you noticed any particular -- what changes, if any, have you noticed in his behavior when he's under the influence of marijuana?

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MALCOLM CONNOLLY: To be honest, a bit more relaxed, not so uptight. I mean, he's not a - he's not always had - he's totally functioning. I mean, he can talk about anything, any conversation you want to talk about. He's not without a (indiscernible) with that, you know; he really isn't. He has a very high tolerance for any substance, Johnny, you know, I would say so, you know. I think Jack Sparrow is more drunk than Johnny Depp.

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MR. MONIZ: So, okay, so that's marijuana.

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MR. MONIZ: What about alcohol same question?

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MALCOLM CONNOLLY: Well, he used to like the wine, and the last - I would say the last couple years, that's dropped drastically. I'd say my last year with Johnny, probably actually rare, no, not rare, but he's not a big boozer, now, he's not a boozer now. And he was never heavy in wine. I think I seen Johnny- in the 20-odd years I've been with Johnny, I think I've seen him drunk twice. And when I say drunk, I mean drunk. Other than that, there's not a lot of difference in Johnny's demeanor or behavior whether he's drinking alcohol or smoking weed, you know.

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MR. MONIZ: Okay. And finally, same question for the time periods when you formed the suspicion that he was under the influence of cocaine.

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MALCOLM CONNOLLY: Sorry. Could you ask me that again?

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MR. MONIZ: What changes in his behavior, if any, did you observe on those occasions when you suspected but didn't know for sure that he was under the influence of cocaine?

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MALCOLM CONNOLLY: Well, again, training I had in the, you know, the HMP prison service, he just seemed a bit more, I don't know, happier, not so down, you know. But I wouldn't say he's not leaping around kicking his heels or anything. You know, he'd pick his guitar up, and he gets really into his guitar. There's no major changes, really. You know, just he's fine, you know.

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MR. MONIZ: Now, you mentioned you traveled with Mr. Depp and Ms. Heard on their honeymoon in -- on the Orient Express. Where else have you traveled with them?

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MALCOLM CONNOLLY: All over the world. Japan, China, Germany, I've been all over the States. I went to, Atlanta, it's not very safe. Hicksville, that's an interesting story. Yeah, all over the world. Australia, went to Australia, as far as away as that.

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MR. MONIZ: And let's take that one at a time. Hicksville, you said.

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MALCOLM CONNOLLY: Yeah, Hicksville, yeah. It's a funky -- I remember it, Hicksville, because it was a funky -- it's a real funky place, you know, with Amber and Johnny did say they were going to go to Hicksville for, you know, a day, a day and a night, I think it was. So we get off the truck, and Amber and her friends all head off, and they're -- well, Amber traveled with Johnny. her friends all head off.

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MALCOLM CONNOLLY: I followed -- Johnny wanted to drive But his own beautiful customized Plymouth, I think it's a or -- I'm not an expert. But had it customized. They gave us this car. Myself and, he was an assistant, at the time, Nathan Holmes, we used another one of Johnny's car, and we follow behind. We get to Joshua Tree, Hicksville. Very stunning, as you can imagine. It's done in a very funky theme. All the caravans are different themes.

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MALCOLM CONNOLLY: Mine was an old rail that kept its -- the old, you know, the old famous fortune teller head that comes around and stuff like that.

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MALCOLM CONNOLLY: Johnny's and Amber's caravan were maybe about 50 meters from mine, maybe 20 meters, and it was -- that was done in 1850s theme. It was an 1850s theme.

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MALCOLM CONNOLLY: And the rest of the caravans were all zombies coming out the ground and caves.

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MALCOLM CONNOLLY: Anyway, we go there. There's a lot of booze, lot of booze comes out. Party starts. Sitting around in the sun, messing around, party starts. There was lots of booze and weed, and I think there's mushrooms there, some psychedelic mushrooms, that went around. But I've been watching exactly what I saw. Everyone was happy, p ! you know, Johnny and Amber was happy. It was much happening. I could see Johnny and Amber getting a bit animated, and I recall they were about, maybe, 25 feet from me. So I approached, and I've been working with Johnny that long, I don't have to say anything. I just have to look at his face. And Johnny can talk to me through his face, doesn't Is need to say a word. So I know what's happening.

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MALCOLM CONNOLLY: And I say in a low voice, "Let's keep it private. Let's start working towards the caravan. Let's get you away from here." As we were walking ahead, you know, just, you know, going ahead, I could hear some, you know, bickering behind me. Johnny's talking, you know, low tone, you know, he's keeping it quiet, but Amber is getting a bit more loud, a bit more nasty, you know. So, anyway, I get into the caravan, I put them inside, and I go to my caravan. That's it. I don't hear anything, don't see anything until the next morning.

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MALCOLM CONNOLLY: We sat around the pool a couple hours and we head back to LA.

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MR. MONIZ: What prompted you to --

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THE COURT: Mr. Moniz before you -- do you have a lot of direct still left in this matter?

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MR. MONIZ: Not terribly much longer, maybe 10 or 15 minutes.

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THE COURT: We're going to take our afternoon break, then.

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THE COURT: Ladies and gentlemen, let's go ahead and take your 15-minute afternoon break, and then we'll come back and continue with the testimony, okay? Don't do any outside research and don't talk to anybody.

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THE COURT: All right. Mr. Connolly, I'm going to put you in the lobby for a break, okay? I'm going to come back and put you back in about 4:20 our time, okay, in about 17 minutes, okay?

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[STAGE DIRECTION]: (Whereupon, the jury exited the , courtroom and the following proceedings took place.)

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MALCOLM CONNOLLY: Okay. Thank you.

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THE COURT: All right. Thank you. Okay.

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THE COURT: And so we'll come back then at 4:20, okay? All right. Thank you.

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COURT BAILIFF: All rise.

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[STAGE DIRECTION]: (Recess taken from 4:03 p.m. to 4:20 p.m.)

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COURT BAILIFF: All rise. Please be seated and come to order.

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THE COURT: All right. Are we ready for the jury?

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MS. VASQUEZ: Yes.

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THE COURT: Okay.

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[STAGE DIRECTION]: (Whereupon, the jury entered the courtroom and the following proceedings took place.)

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THE COURT: All right. Mr. Connolly, can you hear me okay?

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MALCOLM CONNOLLY: I can, yes.

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THE COURT: All right. Can you just count to five for me, please?

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MALCOLM CONNOLLY: One, two, three, four, five.

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THE COURT: Perfect. Thank you. All right.

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THE COURT: Next question.

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[SECTION HEADER]: BY MR. MONIZ:

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MR. MONIZ: All right. Mr. Connolly, we were talking about Hicksville there, and you made a IO comment that you had suggested to Mr. Depp and Ms. Heard that they keep it private or something along those lines.

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MALCOLM CONNOLLY: I did, yes.

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MR. MONIZ: My question is just what prompted you to make that suggestion?

224

MALCOLM CONNOLLY: Well, it was getting kind of animated You know, it was getting animated, and no one wants to see them air their dirty laundry in public.

225

MR. MONIZ: Were they both animated?

226

MALCOLM CONNOLLY: More so Amber. Johnny, yes, but more so Amber.

227

MR. MONIZ: Do you remember anything in particular that Ms. Heard was saying at the time?

228

MALCOLM CONNOLLY: I don't recall, no. See, it wasn't really coherent. It was more of the animation, you know, the head movements and the staring looks and stuff, that prompted me to do what I have to do, you know.

229

MR. MONIZ: Okay. Shifting gears a little bit, you listed out various places that you've traveled with Mr. Depp and Ms. Heard, and I think you listed Japan, Germany, Hicksville, and Australia. Do I have that right?

230

MALCOLM CONNOLLY: Correct, yes.

231

MR. MONIZ: When were you in Australia?

232

MALCOLM CONNOLLY: Probably '15, 2015, private flight.

233

MR. MONIZ: And what were you doing in Australia?

234

MALCOLM CONNOLLY: My job. On that occasion, I flew in first. I usually fly in first to do an advance. Advance includes the check-in accommodation. Not much accommodation because Nathan Holmes, Ben King, and the sheriff called Russell, they had already been at the home -- excuse me -- been at the home and got that started. My main concern was their locations, transport, local security, drivers, you know, making sure all that's in line before Johnny gets there. Jerry Judge traveled with Johnny and Ms. Heard.

235

MALCOLM CONNOLLY: On arrival, I would pick them up at the airport, as we do, take them to the house, whatever accommodation they're staying in, and I would have peeled off at the left of that, went back to my apartment. Johnny would have been maybe there actually a week for, you know, makeup, costume before any shooting stuff. It was time to get him on some locations, studio locations as well as be around for if Johnny want to be to dinner at night anywhere, I would check out those place to go.

236

MR. MONIZ: Mr. Connolly, I'm sorry. I had a little trouble hearing there. It might be the connection, but could you speak maybe just a little bit slower? I'm sorry.

237

MALCOLM CONNOLLY: Okay. As I say, my job in Australia is just to secure all the advance. So I would check out, make sure the local drivers are there, all the cars are in order, the accommodations in order, the locations for shooting are all safe, liaison with production, what's expected of him. I would pick them up at the airport when he arrives, take them to the accommodation, peel off, go and check out a few restaurants in case he wants to go, and if nothing's happening, stand down for that evening.

238

MR. MONIZ: Does anything stand out to you about your time in Australia in 2015?

239

MALCOLM CONNOLLY: Yeah. Johnny lost a finger.

240

MALCOLM CONNOLLY: Yeah. One afternoon, I was instructed to go to Johnny's accommodation -

241

MR. NADELHAFT: Objection. Can we just approach for a minute?

242

THE COURT: All right. Hold on just minute, Mr. Connolly.

243

[STAGE DIRECTION]: (Sidebar.)

244

MR. NADELHAFT: My concern here is he's going to give a long dialogue, and he's going to -- from previous testimony, he may say that Mr. Depp told him how his finger --

245

THE COURT: Okay.

246

MR. NADELHAFT: And that would be hearsay--

247

THE COURT: Right.

248

MR. NADELHAFT: Clearly, that his finger got cut off by a thrown bottle.

249

THE COURT: Okay.

250

MR. MONIZ: Well, I think there is actually a basis to rule that in; that's the same as any existing mental.

251

THE COURT: Sustained.

252

MR. MONIZ: Understood, Your Honor. I'll make clear on the questioning --

253

THE COURT: Can you make sure in the question that he can't talk about anything anybody told him, to including Mr. Depp?

254

MR. MONIZ: Excepting Ms. Heard, of course.

255

THE COURT: Except Ms. Heard.

256

MR. NADELHAFT: Yeah, of course.

257

THE COURT: Yeah, okay. All right. That's fine. All right. Thank you.

258

[STAGE DIRECTION]: (Open court.)

259

[SECTION HEADER]: BY MR. MONIZ:

260

MR. MONIZ: All right, Mr. Connolly, please continue, but as you go, please avoid discussing the substance of any communications that you had with Mr. Depp or his security and just focus on what you observed.

261

MALCOLM CONNOLLY: Okay. I arrived at Johnny's accommodation with my driver, Andrew, I noticed that there was a SUV, one of the security, the RST, resident security team, one of their vehicles sitting outside the door, no driver. So I just assumed, well, something was a security car there but no driver. As I approached the door, I hear a muffled, like a muffled shouting and screaming and - I think muffled, because the entrance to this house there's a massive oak door, I mean, it's huge, and it's got to be about 25 mil thick.

262

MALCOLM CONNOLLY: I open it and it's chaos. It's screaming and shouting, and all I can see with my eyes is Johnny. He's wearing a jacket, a hat, and a bag with notebooks. I always know that bag because it's gray canvass bag, and he's nursing one hand. So I'm saying, "Hey, what's going on I S with all the screaming and shouting, this madness?" Amber's irate, I mean, tenacious, it's crazy stuff.

263

MALCOLM CONNOLLY: Johnny's shouting back. So I said, "Johnny, let's go. Let's go." That's my job, to remove him from the situation. I did a couple stairs with him, Johnny, "Give me five minutes in-house, five minutes." Well, he's the boss, you know. There's no bullets flying, so okay. Give him two minutes. Then I said, "Let's go. Let's go." Eventually I manage to get him to the door. We go downstairs. Amber appears from somewhere.

264

MALCOLM CONNOLLY: I don't know whether Amber is upstairs or in the room to the left or whenever, but she appears and she's screaming, you know, screaming, berating him. She's basically berating him. Yes, "Fuck off." She says, "Johnny, that's what you --" fuck off, that's what you do all the time. That's all you ever do is fuck off. You fuck off with your guys. You're a fucking coward. That's what you fucking do, you fucking coward. You fuck off with your guys, you big man, all that shit.

265

MALCOLM CONNOLLY: I get him down the stairs, this time Amber's at the threshold of the accommodation, and she's screaming, you know, "Fuck off, you are a fucking coward," these kinds of words, you know.

266

MALCOLM CONNOLLY: I get him in the car, and I usually sit in the front seat, shotgun. But I went and sat in the same seat in the back. I said, "What's going on here? Want to chat? Want to talk?" When I got in the car, the driver opened up the door. So he's out the door again, and he's making his way back up the stairs. I get back around again. By the time I get to the top, two complete stairs to the front door, he's just crossing the threshold, and the screaming started again, Amber's screaming.

267

MALCOLM CONNOLLY: Again, "Johnny, let's go. Let's go," this time with a wee bit more force, and I managed to actually basically pull him out the place. I get him into the car, pull the locks this time, into the car, we take off.

268

MALCOLM CONNOLLY: I got him back to my apartment using, you know, a secret way through the underground car park and driver's list. I get him up to my apartment and I get him into my apartment, once I start washing his hand, basic triage on his hand, washing it first aid. It's a mess. His hand -- his finger is just a mess. It's like one of them cartoon exploding cigars. I always think in my mind one of them cigars that blow up, you know, the caption's "boom." And then I say, "Stop fucking around." And I could see bone. There's bone there. It's smashed a bit.

269

MALCOLM CONNOLLY: And he's -- you know his bone is seen, can't wash his hand.

270

MALCOLM CONNOLLY: Anyway, I sat him down, and I phoned Debbie, the nurse who was living in the same apartment block with me. So that's my first thing, phone Debbie. Phone Debbie. About 20 minutes later after I made the phone call, maybe 25, maybe half an hour, but she comes up with Dr. Kipper. So Dr. Kipper does these things, Nurse Debbie address, oh, and Kipper says, "We've got to go to the hospital." He says, "No, there's no other way. We have to go to the hospital. This has to be seriously looked at.

271

MALCOLM CONNOLLY: We get to the hospital, and that's when his treatment started, you know.

272

MR. MONIZ: Okay. When you were in the presence of Mr. Depp and Ms. Heard in the house in Australia, O how far away were you from Ms. Heard? )1

273

MALCOLM CONNOLLY: When I first entered the house, Ms. Heard wasn't visible to me, only Johnny. It's only when we started to leave, Ms. Heard appeared, and she probably was two feet, three feet.

274

MR. MONIZ: Did you observe any injuries on Ms. Heard?

275

276

MR. NADELHAFT: Objection. Leading.

277

THE COURT: I'll allow it.

278

MR. MONIZ: I'm sorry. What was your answer?

279

MR. MONIZ: No injuries, none. Other than the injury to his finger, I did you observe any injuries on Mr. Depp?

280

MALCOLM CONNOLLY: No. No. No. Well, I say no. You know, there was a mark on his face, and I didn't know what that was so I never really put it down to much. But in the house I take a photograph, and when I look at that photograph, I can see two injuries.

281

MR. NADELHAFT: Objection.

282

MALCOLM CONNOLLY: When we were sitting in the car, I think I-

283

THE COURT: Hold on, Mr. Connolly.

284

MR. NADELHAFT: Objection to the extent he's going to go talking about what the mark is. Since he didn't see what happened and he's not a s doctor, he can't describe what... p6

285

THE COURT: All right.

286

MR. MONIZ: That's fine, Your Honor.

287

THE COURT: You're going to move on?

288

MR. MONIZ: Yeah.

289

THE COURT: Okay. Next question.

290

MR. MONIZ: Think you've generally described for us the kinds of things Ms. Heard was saying. How would you describe her overall demeanor when she and Mr. Depp were in each other's presence in the house in Australia?

291

MALCOLM CONNOLLY: Good days and bad days.

292

MR. MONIZ: I'm sorry. I mean on that particular day.

293

MALCOLM CONNOLLY: On that particular day? I had never seen them in the house on that particular day. Only time I seen Ms. Heard and Johnny in that house is when I arrived there to extract him.

294

MR. MONIZ: And how did Ms. Heard seem to you when you saw her on that day when you arrived to extract him?

295

MALCOLM CONNOLLY: Crazy. Crazy. Crazy. Fierce. You know, fierce.

296

MR. MONIZ: Okay. What was the last thing Ms. Heard said as you were taking Mr. Depp out of the house to go to your apartment and then the hospital?

297

MALCOLM CONNOLLY: The last words I recall hearing as I'm getting Johnny out is, "Yeah. Just fuck off with your guys, you're a fucking coward, like you always do.

298

MR. MONIZ: I have no further questions.

Cross

299

[SECTION HEADER]: EXAMINATION BY COUNSEL FOR THE DEFENDANT AND BY MR. NADELHAFT:

300

MR. NADELHAFT: Mr. Connolly, do you still work for I Mr. Depp?

301

MALCOLM CONNOLLY: I do, yeah.

302

MR. NADELHAFT: And you've worked for him now for about 18 years?

303

304

MR. NADELHAFT: Well, two years ago, you said you worked for him for 16 years. So two more years would be 18.

305

MALCOLM CONNOLLY: No, I work with him. I didn't work for him. I worked for a guy called Jerry Judge and Music and Arts. Johnny Depp never paid me. Johnny Depp started paying me two years ago.

306

THE COURT: Okay. Cross-examination, So that's --

307

MR. NADELHAFT: Okay. Jerry Judge was your boss until he passed away; is that right?

308

MALCOLM CONNOLLY: Correct

309

MR. NADELHAFT: And now you get paid directly by Mr. Depp, correct?

310

MALCOLM CONNOLLY: Right.

311

MR. NADELHAFT: And you're paid a salary by Mr. Depp?

312

313

MR. NADELHAFT: Okay. And Mr. Depp's also provided you gifts, correct?

314

MALCOLM CONNOLLY: Gifts?

315

MR. NADELHAFT: Gifts. Money, gifts?

316

MALCOLM CONNOLLY: Yes. Yes, Johnny gave me gifts. Yes, I gave Johnny gift.

317

MR. NADELHAFT: And he's given you gifts over $8,500, correct?

318

MALCOLM CONNOLLY: $8,500?

319

MR. NADELHAFT: Yeah.

320

MALCOLM CONNOLLY: He gave me a lot more than that.

321

MR. NADELHAFT: Okay. And you're loyal to Mr. Depp, right?

322

MALCOLM CONNOLLY: Yes, of course I'm loyal to Mr. Depp. I?- I'd be loyal to you if I was working for you.

323

MR. NADELHAFT: Okay. Now, going to Australia, you said you went to Australia in 2015 with Mr. Depp, correct? Or you went before Mr. Depp, but you I 5 were there to work for Mr. Depp, correct? 1,6

324

MALCOLM CONNOLLY: Correct.

325

MR. NADELHAFT: And Jerry Judge was also there? But he eventually -- Jerry Judge was eventually in Australia, correct?

326

MALCOLM CONNOLLY: Right.

327

MR. NADELHAFT: And Nathan Holmes was in Australia as well, right?

328

MALCOLM CONNOLLY: Right.

329

MR. NADELHAFT: And Mr. Depp came to Australia in February of 2015, correct?

330

MALCOLM CONNOLLY: Correct.

331

MR. NADELHAFT: And when Mr. Depp first came to

332

MALCOLM CONNOLLY: Not when I arrived, no. Australia, Amber was not with Mr. Depp, right?

333

MALCOLM CONNOLLY: I don't recall. I don't recall if Amber arrived with Johnny or Amber arrived later.

334

MR. NADELHAFT: You don't know one way or the other?

335

336

MR. NADELHAFT: And Mr. Depp stayed in a house in Australia, correct?

337

MALCOLM CONNOLLY: Correct.

338

MR. NADELHAFT: And you and the security team were about 40 minutes away from the house Mr. Depp was renting, correct?

339

MALCOLM CONNOLLY: 25, 30. 30, 40. Yeah, you're correct if it's a traffic day, yeah, probably a few minutes more.

340

MR. NADELHAFT: And alcohol was in the house in Australia, correct?

341

MALCOLM CONNOLLY: Correct.

342

MR. NADELHAFT: And Mr. Depp consumed alcohol before Amber arrived in Australia; is that right?

343

MALCOLM CONNOLLY: Yeah, he would have done, yes.

344

MR. NADELHAFT: Do you know if Mr. Depp consumed illegal drugs before Amber arrived in Australia?

345

MR. MONIZ: I'm going to object to speculation.

346

MALCOLM CONNOLLY: I wouldn't know.

347

THE COURT: I'll overrule it. I'll I allow it.

348

THE COURT: Go ahead.

349

MR. NADELHAFT: Do you know if Mr. Depp spent any time with Marilyn Manson in Australia before Amber arrived?

350

MALCOLM CONNOLLY: I don't recall. I don't recall Marilyn Manson being there.

351

MR. NADELHAFT: So as Mr. Depp's security, you don't know if Mr. Depp was with Marilyn Manson at any time?

352

MALCOLM CONNOLLY: I left Australia to smuggle two dogs back out of Australia, back to -

353

MR. NADELHAFT: No, no. I'm talking about in the beginning of March 2015, you were --

354

MALCOLM CONNOLLY: I don't recall Marilyn Manson.

355

MR. NADELHAFT: You don't know one way or the other?

356

357

MR. NADELHAFT: Were you seeing Mr. Depp every day in --

358

MALCOLM CONNOLLY: No, not in the beginning. I had other duties.

359

MR. NADELHAFT: So you don't know what Mr. Depp was I doing at that time, correct?

360

MALCOLM CONNOLLY: No. I wasn't with him

361

MR. NADELHAFT: Okay. And you don't know when Amber arrived in Australia, correct?

362

363

MR. NADELHAFT: But you do know that Amber stayed with Mr. Depp, right?

364

365

MR. NADELHAFT: Okay. And you talked about a resident ! IO security team that was at the Australia house; is ! 11 that right?

366

MALCOLM CONNOLLY: That's correct.

367

MR. NADELHAFT: And were there about four -- is it -- I was there anyone from the resident security team I in the house when you arrived on March 8th, 2015?

368

369

MR. NADELHAFT: Okay. And the resident security team, is it your understanding that they were there? That they were kind of guarding the house?

370

MALCOLM CONNOLLY: They would have been on the grounds but it was substantial grounds, real substantial grounds. They would have been on the grounds somewhere.

371

MR. NADELHAFT: But they didn't go into the house on March 8th, correct?

372

MALCOLM CONNOLLY: I don't know. I never seen them in the house.

373

MR. NADELHAFT: Okay. So when you arrived at the house and went in, was it just Mr. Depp and Amber Heard?

374

MALCOLM CONNOLLY: Just Mr. Depp and Amber Heard.

375

376

MALCOLM CONNOLLY: And maybe someone else there. I never visibly seen anyone else. I wasn't there long enough to chat with anybody.

377

MR. NADELHAFT: When you arrived at the house, you could hear a ruckus, correct?

378

MALCOLM CONNOLLY: Yeah, yeah, I could hear, definitely 116 hear something through the door, yeah.

379

MR. NADELHAFT: But you said the door was so thick you j I 8 couldn't hear the actual words that were being ! 19 said; is that right?

380

MALCOLM CONNOLLY: No. Just a shouting.

381

MR. NADELHAFT: And then you saw -- then you went in the house and saw Mr. Depp in the foyer, correct?

382

MALCOLM CONNOLLY: Yes, correct.

383

MR. NADELHAFT: And Mr. Depp was trying to urinate in the foyer, wasn't he?

384

385

MR. NADELHAFT: Mr. Depp had his penis out of his pants, didn't he?

386

MR. MONIZ: Objection. Relevance.

387

MALCOLM CONNOLLY: I think I'd remember if I'd seen Mr. Depp's penis.

388

THE COURT: I'll allow it.

389

THE COURT: Next question.

390

MR. NADELHAFT: And you were trying to get Mr. Depp out of the house, correct?

391

MALCOLM CONNOLLY: Correct. I was trying to get Mr. Depp out of the house, yes.

392

MR. NADELHAFT: And Mr. Depp was refusing to leave the house, was he not?

393

MALCOLM CONNOLLY: Not refuse. He just wanted two minutes to say his piece.

394

MR. NADELHAFT: You took Mr. Depp by the arm to move him out, but he broke away; isn't that right?

395

396

MR. NADELHAFT: So he was strong enough to break away from your grip, correct?

397

398

MR. NADELHAFT: So you had his ann and he broke away, though, correct?

399

400

MR. NADELHAFT: Isn't that what you just said?

401

MALCOLM CONNOLLY: No. I let him go.

402

MR. NADELHAFT: You let go.

403

MR. NADELHAFT: But it wasn't easy --

404

MALCOLM CONNOLLY: Yeah. That's my boss. I'm not going to drag him by...

405

MR. NADELHAFT: So Mr. Depp's your boss. You'll do what Mr. Depp wants, correct?

406

407

MR. NADELHAFT: It's not easy to get Mr. Depp out of the house, correct?

408

MALCOLM CONNOLLY: Not easy.

409

410

MR. NADELHAFT: Can we play Exhibit 380A which is already in evidence?

411

THE COURT: Plaintiff's or defendant's? I'm sorry.

412

MR. NADELHAFT: It's Defendant's Exhibit 380A.

413

MR. MONIZ: What is this? What is this?

414

MR. NADELHAFT: This is a recording from Australia, and it's just of Mr. Depp.

415

MR. MONIZ: I don't think that's in evidence.

416

THE COURT: It's not in evidence.

417

MR. NADELHAFT: Or Plaintiff's Exhibit 380A? .13

418

MR. MONIZ: I don't believe there are any recordings from Australia in evidence, Your Honor.

419

THE COURT: I don't have anything in evidence.

420

MR. NADELHAFT: There definitely is. It's just of Mr. Depp.

421

THE COURT: I don't have 380 in evidence.

422

MR. NADELHAFT: It's 380A.

423

THE COURT: I have Jamie said it was IDed but never admitted.

424

MR. MONIZ: Your Honor, the recordings from Australia have other voices on them

425

MR. NADELHAFT: It's only the clip of Mr. Depp.

426

THE COURT: Okay. I have it. It's actually Plaintiff's 380A, minute 33 to 34.

427

MR. MONIZ: What's the foundation for using it with this witness?

428

MR. NADELHAFT: He was at the house.

429

THE COURT: It's in evidence. It's fine. So you're playing that clip, correct?

430

MR. NADELHAFT: Correct.

431

THE COURT: That is on plaintiff's.

432

[STAGE DIRECTION]: (Whereupon, the following audio was played.)

433

MR. DEPP: What you are and who you are and how you fucked me over and make me feel sick of myself There's still a lot left in the day. Maybe you should dye your hair. I see roots.

434

[SECTION HEADER]: BY MR. NADELHAFT:

435

MR. NADELHAFT: Did you hear that, Mr. Connolly?

436

MALCOLM CONNOLLY: I did, yes.

437

MR. NADELHAFT: And that was the sort of condition Mr. Depp was in when you saw him at the house, correct?

438

MALCOLM CONNOLLY: Yes. Yes.

439

MR. NADELHAFT: Mr. Depp was upset and angry when you saw him at the house, correct?

440

MALCOLM CONNOLLY: Absolutely, yes.

441

MR. NADELHAFT: Okay. Now, did you take -- did you take Mr. Depp to the hospital?

442

MALCOLM CONNOLLY: Along with others, yes.

443

MR. NADELHAFT: Is it your testimony that Mr. Depp was coherent at the hospital?

444

445

MR. NADELHAFT: Can you -- let's show Defendant's Exhibit 370. I would just like for you to look at something for a moment.

446

MR. NADELHAFT: I'm not publishing it. I just want to show him a document, Defendant's Exhibit 370. IR. MONIZ: Your Honor, I'm going to object on foundation grounds. The witness is not even copied on this document.

447

MR. NADELHAFT: I'm going to ask him a question and ask him if it refreshes his recollection. That's all I'm going to ask him about it. I can use any document to refresh --

448

THE COURT: Do you want to approach for a second? Let's see what we're refreshing.

449

[STAGE DIRECTION]: (Sidebar.)

450

THE COURT: So what are we refreshing his recollection on?

451

MR. NADELHAFT: He said he wasn't coherent at the hospital. If he doesn't know, he doesn't know.

452

MR. MONIZ: It's not proper -- I mean, it's not his words.

453

MR. NADELHAFT: I'm asking if he's -- I'm not trying to submit it into evidence.

454

THE COURT: I understand that.

455

MR. MONIZ: But reading it into the record --

456

MR. NADELHAFT: I wasn't going to read it into the record. I was going to ask him if seeing this document reminded him that Mr. Depp was not coherent. It's either a yes or it's a no.

457

THE COURT: But he didn't write this, right? I just want to make sure.

458

MR. NADELHAFT: No, he didn't write it. And I'm not trying to get it into the evidence. I'm not trying --

459

THE COURT: I understand. I'm going to sustain the objection. That's somebody else's words. He said he was coherent.

460

MR. NADELHAFT: I'm sorry?

461

THE COURT: He said he was coherent, but that's just somebody else's words. It's not his words.

462

MR. NADELHAFT: But you can use anything to refresh recollection. That's all I ! 19 was going to do.

463

THE COURT: No. I'm not going to allow it.

464

MR. NADELHAFT: Thank you, Your Honor.

465

THE COURT: Okay.

466

[STAGE DIRECTION]: (Open court.)

467

THE COURT: You can take the document down.

468

MR. NADELHAFT: You can take it down.

469

[SECTION HEADER]: BY MR. NADELHAFT:

470

MR. NADELHAFT: Mr. Depp' s finger was filled with dirt, is grime, and paint when you saw it?

471

472

MR. NADELHAFT: And now, you say you saw no bruises or . cuts on Amber on March 8th, 2015, correct?

473

MALCOLM CONNOLLY: Correct.

474

MR. NADELHAFT: Isn't it true that your main concern was Mr. Depp and getting him out of the house, correct?

475

MALCOLM CONNOLLY: Yeah.

476

MR. NADELHAFT: So you weren't concentrating on Amber, correct?

477

MALCOLM CONNOLLY: I was close enough if there's any marks on Amber's face, I would have picked that up in a few minutes. Amber came in the home office -

478

MR. NADELHAFT: As you're trying to pull Mr. Depp out of the house, you're scanning Amber for bruises and cuts?

479

MALCOLM CONNOLLY: Not scanning. I'm looking at her.

480

MR. NADELHAFT: As you're moving -- as you're moving Mr. Depp out of the house, correct?

481

MALCOLM CONNOLLY: Yes, yes. Maybe I know what she's got on her left. I'm watching her. But I'm getting a client from a bad situation, a whole situation. I watch what's happening around me.

482

MR. NADELHAFT: But you're not --

483

MALCOLM CONNOLLY: I know where the client is. The client's with me.

484

MR. NADELHAFT: Right. The client was with you, and you're not scanning -- you didn't scan Ms. Beard's body for --

485

MALCOLM CONNOLLY: I scan everything. I look at everything.

486

[STAGE DIRECTION]: (indiscernible due to cross talking.)

487

MR. NADELHAFT: You scanned everything on her body?

488

MALCOLM CONNOLLY: No. Not her body. She's wearing long sleeves from what I recall.

489

MR. NADELHAFT: And at the hospital the doctor was told that Mr. Depp cut his finger with a knife, correct?

490

MALCOLM CONNOLLY: Correct. Yeah.

491

MR. NADELHAFT: Okay. And you understand that the damage at the house, at Mr. Depp's rented house, amounted to about a hundred thousand dollars, correct?

492

MR. MONIZ: Objection. Calls for speculation.

493

[STAGE DIRECTION]: (Indiscernible due to cross talking.)

494

THE COURT: I'll allow it. That's fine.

495

THE COURT: Next question.

496

MR. NADELHAFT: In Hicksville, other than when you first arrived, you didn't go to the trailer that Mr. Depp and Amber were staying in; is that right?

497

MALCOLM CONNOLLY: Only when I delivered them to it.

498

MR. NADELHAFT: Right. And then after you delivered them to it --

499

MALCOLM CONNOLLY: When I delivered them to it, when we first got there?

500

MR. NADELHAFT: Right.

501

MALCOLM CONNOLLY: Went inside and had a look around,

502

MR. NADELHAFT: But after that you never went inside the trailer after that, correct?

503

MALCOLM CONNOLLY: Correct.

504

MR. NADELHAFT: So you have no idea what went on in the trailer between Mr. Depp and Amber; isn't that right?

505

MALCOLM CONNOLLY: I was told. ,9

506

MR. NADELHAFT: But you don't have any personal knowledge as to --

507

MALCOLM CONNOLLY: I never seen it, no. I never seen it.

508

MR. NADELHAFT: You have no idea how much damage was done to the trailer, correct? Personal knowledge.

509

MALCOLM CONNOLLY: I do have an idea.

510

MR. NADELHAFT: You have no idea what happened to Amber in the trailer; isn't that right?

511

MALCOLM CONNOLLY: That's correct.

512

MR. NADELHAFT: And you talked about that there was tension between Amber and Mr. Depp. You don't know what started the fight, correct?

513

MALCOLM CONNOLLY: Correct.

514

MR. NADELHAFT: Did you see Mr. Depp grab another woman's ann before they moved off to the truck -- before the fight started?

515

516

MR. NADELHAFT: Okay. Were you with the company when you were -- were you with the group?

517

518

519

MALCOLM CONNOLLY: I was maybe 20 feet away, observing. That's my job, not to get involved. I don't sit with my clients in a personal situation. I just observe.

520

MR. NADELHAFT: Now, you testified that at times you saw marks and bruises on Mr. Depp, a fat lip, I ! 14 think you said. You don't have dates for those times that you saw that, right?

521

MALCOLM CONNOLLY: I don't recall. No, you're talking - that's a long time ago, you know.

522

MR. NADELHAFT: Right. You testified in the U.K. in -- you testified in the U.K., correct?

523

MALCOLM CONNOLLY: Correct.

524

MR. NADELHAFT: And you gave a witness statement too, in the U.K., correct?

525

MALCOLM CONNOLLY: Correct.

526

MR. NADELHAFT: And you never testified to seeing any marks, bruises, or injuries on Mr. Depp; isn't that right, in the U.K.?

527

MALCOLM CONNOLLY: I wasn't asked in the U.K

528

MR. NADELHAFT: But you never testified to that, right?

529

MALCOLM CONNOLLY: I wasn't asked.

530

MR. NADELHAFT: Okay. Now, in the private -- you talked about a private plane that you saw a plastic liter bounce off of Mr. Depp's chest, correct?

531

MALCOLM CONNOLLY: Correct.

532

MR. NADELHAFT: And you said you saw Mr. Depp smirking and said -- and then he said, "Was that it?" Is that right?

533

534

MR. NADELHAFT: Okay. You didn't -- you don't know what started the fight there, correct?

535

MALCOLM CONNOLLY: Correct.

536

MR. NADELHAFT: Okay. And you talked about at the EB -- at the lofts, I think you called it in Los Angeles you saw a Coke can get thrown somewhere in the vicinity of Mr. Depp, correct?

537

MALCOLM CONNOLLY: I seen a can.

538

MR. NADELHAFT: Right.

539

MALCOLM CONNOLLY: Not a Coke can. I couldn't tell you what can it was.

540

MR. NADELHAFT: Okay. And you don't know what happened before you saw the Coke can get thrown, correct?

541

MALCOLM CONNOLLY: Correct.

542

MR. NADELHAFT: And you talked about this picture of -- O that you took in Southeast Asia, correct?

543

MALCOLM CONNOLLY: Correct.

544

MR. NADELHAFT: And you never mentioned in the U.K. matter or in your witness statement Mr. Depp having scratches and bruises on the train, correct?

545

MALCOLM CONNOLLY: I was never prompted to. I was never asked.

546

MR. NADELHAFT: You gave a witness statement that gave the -- what you saw in the relationship between Amber and Mr. Depp, and you never talked about bruises or cuts on Mr. Depp in Southeast Asia, correct?

547

MALCOLM CONNOLLY: No. I wasn't asked that.

548

MR. NADELHAFT: Okay. Now, you said only Johnny could make a request for a private dining car; isn't that right?

549

MALCOLM CONNOLLY: I said that?

550

MR. NADELHAFT: Only Johnny needed a private dining car. Ms. Heard didn't need a private dining car, correct?

551

MALCOLM CONNOLLY: That would be correct. Oh, yeah, that would definitely be correct. Only Johnny Depp needed a private dining car. But Johnny doesn't want a private dining car.

552

MR. NADELHAFT: Okay. Now, you were not present in Ms. Heard and Mr. Depp's cabin on the train, right?

553