Depp v. Heard Transcript iO Tillett Wright
Depp v. Heard / Day 17 / May 17, 2022
3 pages · 3 witnesses · 4,190 lines
Vasquez concluded her cross of Heard attacking the Australia sequence, May 21 injury accounts, and op-ed "of and concerning" claims; iO Tillett Wright and Raquel Pennington testified for Heard, with Wright placing a 911 call during the May 2016 incident.
Procedural Procedural
1 6:29:28

THE COURT: All right. Ladies and gentlemen, Jet's go ahead and take our afternoon recess, then, for 15 minutes. Do not discuss the case with anybody, and don't do any outside research, okay?

2

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

3 6:29:54

THE COURT: All right. Is your next ! 12 witness a live witness, remote witness, or deposition?

4 6:29:57

MS. BREDEHOFT: It will be by deposition, Your Honor.

5 6:30:01

THE COURT: Deposition, all right. So we'll get the TV set up for that, and let's just come back, then, at 3:30, okay?

6 6:34:45

MS. VASQUEZ: Thank you, Your Honor.

7 6:39:29

THE COURT: All right. Thank you.

8 6:41:30

COURT BAILIFF: All rise.

9 6:43:30

COURT BAILIFF: All rise. Please be seated and come to order. ;4

10

[STAGE DIRECTION]: (Recess taken from 3:15 p.m. to 3:30 p.m.)

11 6:45:31

THE COURT: Thank you. All right. Just before the jury comes out, for the motion to strike, I had taken Count I under advisement. Now that we have Plaintiff's 3 in evidence and we've had the testimony from the defendant, at this point I do find that there's evidence in the tweet -- I know that the tweet, Plaintiff's 3, is a retweet or tweet that has a hyperlink of the online op-ed link, and I know that a mere hyperlink without more cannot constitute republication.

12 6:45:46

THE COURT: However, here, when there's additional content, that could constitute republication in this matter, so there is evidence of ownership and additional content that the jury could find constitute republication. That is a factual question that does survive a motion to strike; therefore, the motion to strike is denied as to Count I.

13 6:46:05

MR. CHEW: Thank you, Your Honor.

14 6:46:06

THE COURT: All right. Thank you.

15 6:46:08

THE COURT: Okay. Are we ready for the jury?

16 6:46:29

MS. BREDEHOFT: Yes, Your Honor.

17 6:46:50

THE COURT: All right.

18

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

19 6:47:11

THE COURT: All right. Thank you. You may be seated.

20 6:47:13

THE COURT: All right. Your next witness.

21 6:47:17

MS. BREDEHOFT: Your Honor, our next witness is Mr. iO Tillett Wright, and it starts with counsel for Mr. Depp asking questions and then will switch over to me.

22 6:47:27

THE COURT: All right. Thank you.

23 6:47:29

THE COURT: IO TILLETT WRIGHT, Being first duly sworn, was examined and testified as follows:

24

[SECTION HEADER]: EXAMINATION BY COUNSEL FOR THE PLAINTIFF AND

25 6:47:31

MR. PRESIADO: Good morning again. Have you had any communications with Ms. Heard at all, in text or emails or otherwise, in connection with your preparation for this deposition?

26 6:47:36
27 6:47:41

MR. PRESIADO: When's the last tin:e you spoke to her?

28 6:47:44

IO TILLETT WRIGHT: April of last year, April or May. Almost a year ago.

29 6:47:51

MR. PRESIADO: Mr. Wright, when did you first meet Ms. Heard?

30 6:48:01

IO TILLETT WRIGHT: I met Amber in the end of 2011.

31 6:48:06

MR. PRESIADO: And where did you meet her?

32 6:48:10

IO TILLETT WRIGHT: In Los Angeles.

33 6:48:12

MR. PRESIADO: What were the circumstances of the meeting?

34 6:48:18

IO TILLETT WRIGHT: A friend "as introducing us to each other so that I could photograph her for a large portrait series that I \as doing at the time.

35 6:48:26

MR. PRESIADO: What was your profession in 2011?

36 6:48:31

IO TILLETT WRIGHT: I was a photographer, and I worked for the New York Times, I think. I don't recall exactly everything.

37 6:48:41

MR. PRESIADO: In 2011 you were both a photographer and separately worked for the New York Times as a freelancer?

38 6:48:46

IO TILLETT WRIGHT: I worked for the New York Times as a journalist and photographer.

39 6:48:54

MR. PRESIADO: And what is your profession today?

40 6:49:03

IO TILLETT WRIGHT: I'm a writer and a producer.

41 6:49:12

MR. PRESIADO: And between 2011 and through the present, have you had any other professions other than photographer, writer, or producer?

42 6:49:21
43 6:49:22

MR. PRESIADO: And what are those?

44 6:49:26

IO TILLETT WRIGHT: I've hosted a television show or two.

45 6:49:31

IO TILLETT WRIGHT: I made some podcasts. I wrote two other books, or two books, three books. Three books, I've written three books. A number of things. I don't know.

46 6:49:56

IO TILLETT WRIGHT: 20 There are more things that I -- yeah, I've always been a multi-hyphenated person. To the best of my recollection, we initially met at a mutual friend's house, which I think I already stated. That friend is also an actor and had met Amber at the children's hospital while they were both volunteering and knew that Amber had done quite a bit of LGBT activism and mentioned my project to her and then invited her over to -- the other friend invited Amber to her house so that we could all meet. And Amber and I discovered that we liked the same books, and we liked psychology and just, you know, laughed and had fun that night. And then I asked her if she would participate in the photo project, I think, or somebody did, and she said yes.

47 6:51:03

IO TILLETT WRIGHT: A couple of days Its later, I went to the house that she was staying at, and I photographed her for the project. And then, thereafter, I went back to New York where I Its lived, and I remember her texting me and saying that she was shooting a movie in New York and did I want to get lunch. So we got lunch, and we became friends.

48 6:51:26

MR. PRESIADO: Okay. Please walk me through that.

49 6:51:29

IO TILLETT WRIGHT: We met in 2011. We started becoming friends soon thereafter. In 20 -- very early in 2013, I came to LA to spend a couple of months with my then -- I don't know if she was my girlfriend or my fiancee at that point, but the person I was in a relationship with, in a very serious relationship with -- and during the time that I was in LA, I spent more time with Amber. We both spent more time with Amber.

50 6:52:07

IO TILLETT WRIGHT: And I was introduced to Johnny. And the summer of 2013, I ended up moving to LA, during which Amber and Johnny and I got even closer, very, very close. And then, we remained close, the three of us, for twoish years, and then all of this happened, this nightmare, and Johnny and I stopped being friends and Amber and I stayed friends. And then Amber and I were friends up until the date that I told you that we last spoke.

51 6:52:51

MR. PRESIADO: And at some point in time, did you live on the same property as Johnny Depp and Amber Heard?

52 6:52:58
53 6:53:01

MR. PRESIADO: And when was that?

54 6:53:04

IO TILLETT WRIGHT: It was August 2013 until, I believe, June 1st of 2014, I moved into my own house, so nine months.

55 6:53:17

MR. PRESIADO: And why is it that you left that property, left living there?

56 6:53:24

IO TILLETT WRIGHT: Because I didn't want to live for free in someone's property, and I wanted to have my own house and support myself.

57 6:53:32

MR. PRESIADO: And for how long after that did you stay close with both Johnny and Amber?

58 6:53:41

IO TILLETT WRIGHT: I stayed close with both of them -- I don't remember. It was a -- hmm. Sometime in 2015, I think, late 2015, maybe, Johnny and I were no longer -- I think the period when I really stopped considering Johnny a friend of mine was December of 2015.

59 6:54:20

MR. PRESIADO: Okay. Let me ask you this way: You never saw Mr. Depp assault or beat Ms. Heard on any occasion, correct?

60 6:54:27

IO TILLETT WRIGHT: That's correct. I'd just like to clarify, Mr. Presiado. That's a question you already asked me. Are you asking me the same question again about whether or not I witnessed Mr. Depp assault Ms. Heard?

61 6:54:33

MR. PRESIADO: Yes, sir.

62 6:54:40

IO TILLETT WRIGHT: No, I have not witnessed that.

63 6:54:41

MR. PRESIADO: Let me ask it this way, then: Had you ever personally seen Mr. Depp assault or beat Ms. Heard on any occasion?

64 6:54:50
65 6:54:51

MR. PRESIADO: Now, back to this same paragraph, where it says, "My experience of Johnny during the time that we were close, from 2013 through 2015, was that he could be incredibly kind, generous, and loyal." Can you give me examples of his kindness, generosity, and loyalty during that period of time?

66 6:55:17

IO TILLETT WRIGHT: Johnny, when sober, was lovely and magical and very funny. Johnny, when sober, was incredibly lucid and imaginative, and I felt a kindred connection with him and a shared perspective on the world that I've shared with very few people in my life. Johnny, when sober, understood how much influence he had over people, and he was very kind to them about it and generous with talking to them about whatever came up. And he was also, when sober, very -- you know, he made time for people's nervousness around him, which I witnessed on a number of occasions.

67 6:56:29

IO TILLETT WRIGHT: He also -- he had his number of houses on that street, and there was a constant rotation of different people coming to town who could all afford to live somewhere else or stay somewhere else who he would let and enjoyed living in those houses, which I find to be generous.

68 6:56:58

MR. PRESIADO: In the next paragraph, paragraph 6, you refer to Mr. Depp's struggles with respect to OxyContin. You say that in late 2013, after a dental surgery, he became hooked on OxyContin.

69 6:57:11

MR. PRESIADO: Did you ever experience him while he was on OxyContin?

70 6:57:15
71 6:57:16

MR. PRESIADO: And while he was on OxyContin, did you ever experience him to be mean or vicious?

72 6:57:25

IO TILLETT WRIGHT: I can't answer that with any accuracy because I don't know whether or not the times that I did see him be mean and vicious he was also on OxyContin.

73 6:57:35

MR. PRESIADO: In paragraph 5 where you say that he could be incredibly mean and vicious, especially when he was drunk or high, when you refer to "drunk or high," what substances are you referring to?

74 6:57:47

IO TILLETT WRIGHT: The substances that I saw him ingest with my own eyes were cocaine and hard liquor, marijuana, ecstasy, mushrooms, wine, probably some other things. Those are the immediate ones that jump to mind. Cocaine and any kind of alcohol would bring out a very, very ugly side of him, very misogynistic and cruel and other things. And when he would take any kind of psychedelic, like ecstasy or MDMA, he would become paranoid, and when he would drink alcohol, he would become paranoid.

75 6:58:17

IO TILLETT WRIGHT: Yeah. I think I've answered your question.

76 6:58:24

MR. PRESIADO: You mentioned that you witnessed him having had cocaine. Did you ever have cocaine with him?

77 6:58:33
78 6:58:33

MR. PRESIADO: Were there any drugs or substances that you took with him?

79 6:58:40

IO TILLETT WRIGHT: I don't smoke marijuana. I don't do cocaine. For the entire period that I knew Johnny and thereafter, I did not drink alcohol. It was a, I think, one-week period during the peak of my breakup, during which Johnny offered me some pain pills to get through the intensity of that situation, and that was the only time that I took any substances for three and a half years -- no, that's not true. That was the only time that I took any substances with Johnny and -- yeah. Yeah. All the other things that I had stated previously about what I do and don't do are also accurate.

80 6:59:35

MR. PRESIADO: I'm son-y. Just to summarize that, is your testimony that when you witnessed Mr. Depp drunk and high, you were not also either drunk or I high? Is that your testimony?

81 6:59:50

IO TILLETT WRIGHT: My testimony is that during the entire period that I knew Mr. Depp, I was never drunk or drinking or consuming alcohol at all. My , testimony is that for a one-, maybe two-week, possibly two-and-a-half-week - I don't remember - period, on a sporadic occasion, I took some pain pills that Mr. Depp offered me for- to get through an extreme emotional pain situation.

82 7:00:22

IO TILLETT WRIGHT: When I witnessed Johnny doing cocaine, I was not drunk or high. Other occasions that I witnessed Johnny drinking, I was not drunk or high. It was a very narrow window during which I was taking some non-mind-altering pain pills for a very brief period, during which I witnessed Johnny drunk and high.

83 7:00:48

MR. PRESIADO: Did you ever witness Ms. Amber Heard drunk or high?

84 7:00:51
85 7:00:52

MR. PRESIADO: And did you ever witness her drink I alcohol?

86 7:00:54
87 7:00:56

MR. PRESIADO: Did you ever witness her ingesting cocaine?

88 7:01:01

IO TILLETT WRIGHT: Are you asking, like, ever in the history of time, have I ever witnessed Amber Is ingest cocaine?

89 7:01:06

MR. PRESIADO: That's the first question, yes.

90 7:01:10

IO TILLETT WRIGHT: The answer's no. Amber was vehemently against cocaine.

91 7:01:16

MR. PRESIADO: Did you ever witness her smoke l marijuana?

92 7:01:23

IO TILLETT WRIGHT: No. Marijuana is not her drug.

93 7:01:25

MR. PRESIADO: What is her drug?

94 7:01:27

IO TILLETT WRIGHT: I haven't spoken to Amber in a year, but as far as I know, and I have known her for the I last 11 or 12 years, Amber doesn't have a narcotic of choice.

95 7:01:36

MR. PRESIADO: Have you seen her ingest ecstasy?

96 7:01:39

IO TILLETT WRIGHT: Yes, I believe so. Yes.

97 7:01:41

MR. PRESIADO: How many times have you seen her ingest ecstasy?

98 7:01:45

IO TILLETT WRIGHT: I can think of one instance in particular when she took it for her birthday, like in a celebration.

99 7:01:50

MR. PRESIADO: Do you recall what year that was?

100 7:01:55

IO TILLETT WRIGHT: I don't recall when that would have been.

101 7:02:00

MR. PRESIADO: Other than the narcotics and alcohol that I mentioned, did you ever witness Ms. Heard ingest any other drugs?

102 7:02:12

IO TILLETT WRIGHT: Are you asking me if other than -- what did you ask me about? -- cocaine, ecstasy, and mushrooms, I've witnessed Amber taking any other illegal narcotics? Or are you asking me about prescription medications? Can you clarify?

103 7:02:29

MR. PRESIADO: Narcotics other than prescription narcotics.

104 7:02:32

IO TILLETT WRIGHT: I don't know, but I don't actually think so, no.

105 7:02:36
106 7:02:37

IO TILLETT WRIGHT: Amber drinks red wine when she's not training -- or let me rephrase that. Amber, when I knew her, drank red wine in the evenings fairly regularly, with the exception of when she was training for an acting role.

107 7:03:02

MR. PRESIADO: Have you ever witnessed Mr. -- excuse me -- Ms. Heard intoxicated?

108 7:03:09
109 7:03:11

MR. PRESIADO: And how often would you estimate that you witnessed Ms. Heard intoxicated?

110 7:03:17

IO TILLETT WRIGHT: I don't know how to quantify intoxicated. If you're asking me how often I witnessed her drunk - is that your question?

111 7:03:25
112 7:03:25

IO TILLETT WRIGHT: Amber's strangely immune to getting drunk unless she's really drunk a lot. So I didn't see her drunk very often. I saw her drinking often, but I didn't see her out of her faculties very often. Like, you know, I saw that a handful of times in the 11 years that I knew her.

113 7:03:54

MR. PRESIADO: And how would you describe how alcohol affects Ms. Beard's personality based on your experience?

114 7:04:03

IO TILLETT WRIGHT: You know, it depends on the circumstance. If it was during a moment when she was celebrating, it would make her loose, like if I were salsa dancing, then, you know, she would have fun and be fun and at a party and, you know, inebriated and dancing and having fun. If she was in a stressful situation, I think it would just kind of exacerbate whatever the feeling of the moment was.

115

[SECTION HEADER]: EXAMINATION BY COUNSEL FOR THE DEFENDANT AND BY MS. BREDEHOFT:

116 7:04:41

MS. BREDEHOFT: I'm going to ask you to state your name I I for the record. Nobody has yet.

117 7:04:50

MS. BREDEHOFT: This is me, in case you haven't recognized the voice.

118 7:04:54

THE COURT: All right. Go ahead.

119 7:04:56

IO TILLETT WRIGHT: My name is iO Tillett Wright.

120 7:04:57

MS. BREDEHOFT: Let's bring up Depp Exhibit Number I again, please.

121 7:05:03

MS. BREDEHOFT: Mr. Tillett Wright, you were asked some questions by Mr. Presiado, and I'm going to take you back up to the first page where you were asked some questions. And he started out with-- I'm just going to draw your attention to paragraph 4. And you indicated you met Johnny Depp through Amber. And you hit it off immediately.

122 7:05:31

MS. BREDEHOFT: Do you see that?

123 7:05:33

IO TILLETT WRIGHT: Yes, I do.

124 7:05:35

MS. BREDEHOFT: Okay. And then you explained to Mr. Presiado that you considered Johnny to be a close friend and you cared very much about Mr. Depp; is that correct?

125 7:05:46

IO TILLETT WRIGHT: He became a close friend, and I did care very much about him. I still care very much about him.

126 7:05:51

MS. BREDEHOFT: All right. Could you please describe that relationship that you had with Mr. Depp up until, I think you said, December of 2015?

127 7:06:04

IO TILLETT WRIGHT: Sure. Okay. Mr. Depp and I first met. Amber invited me over to his house with my then-partner, girlfriend - I don't know if she was my fiancee yet or not- in, I think, February of 2013, right at the beginning of 2013. And we all hung out, the four of us hung out in his house, in his living room, and just kind of talked and got to know each other, and it was sweet. I was mostly hanging out with Amber and kind of meeting this person, who was a trip to meet someone like that, you know, in his house, very friendly, very welcoming, very kind And then the next time we saw each other was at - Amber and I both like to do what we call "family dinners," so we invite people over and cook for them and have a dinner party, and Amber did an elaborate family dinner at her house. O And Johnny and I and my ex and Amber and, I believe, Whitney were there. I don't know if anyone else was there. I'm sure so many other people were there, I don't remember.

128 7:07:26

IO TILLETT WRIGHT: And Johnny and I really connected at that dinner. We were sitting either opposite each other or just catty-cornered from each other, and I left feeling a really intense connection to him. And I was like, "Well, yeah, sure. Everybody probably feels an intense connection with him because of who he is. I forget. It's ridiculous."

129 7:07:49

IO TILLETT WRIGHT: And then a couple of days later, Amber had another dinner, some -- such a dinner at her house. And Johnny and I had another really good time and felt very connected and really laughed a lot, whatever, and at the end of the dinner, as I was standing to leave with my ex, Johnny came up to me and said, "I don't really know how to say this because it doesn't happen to me very often, but I think I love you.

130 7:08:27

IO TILLETT WRIGHT: And I felt strange because I felt the same way. And I said, "That's funny because I had that same experience after the last dinner party too." And then we joked about how crazy and ridiculous that felt. And we exchanged phone numbers, and then he -- he texted me wanting to talk about Amber a couple of times, and I felt that it was, like, kind of violating her privacy.

131 7:08:57

IO TILLETT WRIGHT: So I said that I was happy to be friendly with him and happy to, I don't remember exactly what I said, but something to the effect of, like, you know, "I'm happy to be -- to give advice or to help you guys stay in concert with each other, but I don't want to violate anybody's privacy with the other one."

132 7:09:22

IO TILLETT WRIGHT: And he -- I think he really respected that and really liked that because he also values his privacy greatly. And then, yeah, I was in LA for a couple more months, and I don't know, I think maybe we hung out more during that period. I'm not sure. I don't remember if they came to New York during the next stretch of time or what happened, but basically by the summer, I came back to LA to write and had a very bad breakup with that fiancee and was going through some things personally that Johnny, you know, he was like, "I recognize what's happening for you."

133 7:10:05

IO TILLETT WRIGHT: It was like particularly bad anxiety-related, trauma-related things. And he -- I didn't expect him to offer me any support around that stuff, but he was just like, "Wait. I see what you're going through. You know, this is my experience. I have the same thing, and let's talk about it and, like, if you need anything, I'm here."

134 7:10:32

IO TILLETT WRIGHT: And I was like, "Thank you so much." You know, I didn't really expect that.

135 7:10:37

IO TILLETT WRIGHT: I went back to New York for -- to be with my family for a couple days or maybe a week or something, and it was very painful to be there. And he had said if it's painful to be there, just Let me know and come back and stay here. And so I did. And I came back, and I originally was going to stay at Amber's house because she kept her apartment for a number of years while they were together, even though she stayed at his house a lot, that she paid for, et cetera. And she was, you know, the person that I'd known longer, so I felt more comfortable being at her house. And then the consensus was that I should be closer to them. And so they said, "Oh, there's this house that's sitting empty at the end of the street."

136 7:11:20

IO TILLETT WRIGHT: Just stay there. I was very hesitant because I didn't want to take advantage of him. And he was insistent, and he was very kind about it. And he said that he understood fully what having PTSD and anxiety can do and that he wanted to help. So I went and I stayed there. And then that was, I'm guessing, in August of 2013. And then in September, I think, Amber went to England to shoot a movie, so I was there, and Johnny and I would hang out on our own. And Johnny doesn't have a ton of friends because he can't, and I would go up and hang out with him. You know, we really enjoyed each other. We really liked each other, and so we would hang out, you know, on a daily basis, eat dinner or watch movies, and I'd hang out with his kids and got, you know, very like into a very sweet uncle-niece-nephew relationship with his kids, and they called me "Uncle iO.

137 7:12:30

MS. BREDEHOFT: Mr. Tillett Wright, did you ever call Mr. Depp "brother," or refer to him as your brother?

138 7:12:35

IO TILLETT WRIGHT: Yes, I did.

139 7:12:37

MS. BREDEHOFT: Now, I'm going to take you to paragraph 5 of Depp Exhibit Number I, and Mr. Presiado asked you about this paragraph as well. And at the end of it, you had said that he could be incredibly mean and vicious, especially when he was drunk or high.

140 7:12:54

MS. BREDEHOFT: What did you mean by that?

141 7:12:55

IO TILLETT WRIGHT: What I meant by that was on a number of occasions, I saw, you know, Amber or he, I think, also, would ask me to come and help. He and I had more of a, like, mano a mano kind of relationship, and she and I had a -- I was kind of like the only person that would check either of them for a while. And so they would both ask me to do that with each other. So I saw him -- for example, I remember there was a time when it was very late at night. I was down the hill, and so I went up the hill and he was outside by the pool with a glass of what I understood to be whiskey.

142 7:13:55

IO TILLETT WRIGHT: And she was inside, crying and very upset in the kitchen, I think. And then I went outside and talked to him for a long time. Situations like that.

143 7:14:14

IO TILLETT WRIGHT: Or -- and he would say things. He said something to me that night that I thought, Jesus Christ, you know, things like, "She's gonna -- all she's got is her looks, and, you know, she has no talent" I and when her tits start to sag and her face gets wrinkly, nobody's going to be interested in her for anything. So she, you know, better, like, figure out another way to survive, and shit like that - sorry; pardon me - things like that.

144 7:15:01

IO TILLETT WRIGHT: And I also witnessed him, when Amber was in England, Marilyn Manson and Paul Bettany came over at one point, and there was a great deal of cocaine and alcohol involved that I witnessed them doing together. I don't specifically recall if Mr. Bettany did or did not partake in the cocaine or really much of anything except things that he said and his personality. But Mr. Manson and Mr. Depp partook in a lot of cocaine.

145 7:15:39

MS. BREDEHOFT: What, if anything, did Mr. Depp tell you about these struggles with drugs and alcohol?

146 7:15:49

IO TILLETT WRIGHT: We sat on the couch, and he told me a number of things. He told me about his childhood. He told me about growing up in Kentucky. He told me about growing up being very poor and how his mom was verbally and physically abusive. He told me that when he was very, very young, like 13 or something, he started drinking and taking drugs, I think, or at least drinking quite heavily. He was even kind of like, "Yeah. It's crazy; I know. But I've been doing it my whole life. I'm built like a tank." So that was kind of the nature of the conversation. And he told me that he had struggled with ever not drinking or ever not doing drugs, and he also told me he didn't particularly enjoy being sober but that, you know, people around him were very, very concerned. He was very, very concerned with his children.

147 7:16:39

IO TILLETT WRIGHT: And he would express shame or regret about times that he had been inebriated to the point of falling down or embarrassing himself, you know, urinating on himself, things like that, when his children were around and that he was very grateful to the people that had kind of shielded them and whisked them away. And he told me that in his relationships with previous women, his drug and alcohol use had been an issue but that he just didn't really like life sober and that it was too painful to be alive without imbibing or getting high.

148 7:17:05

IO TILLETT WRIGHT: And he also told me that he had experienced great bouts of jealousy in relationships that had also led to a lot of drinking and a lot of rage activities. He told me that that happened with Winona. He told me that that happened with Kate. And - sorry, Winona Ryder and Kate Moss. He told me that that had happened with Vanessa Paradis.

149 7:17:34

MS. BREDEHOFT: Mr. Tillett Wright, what, if any, observation did you make about Mr. Depp abusing OxyContin?

150 7:17:45

IO TILLETT WRIGHT: Over the course of those two years, Mr. Depp told me verbatim that he was addicted to Oxycontin, and I have a text message from him where he expresses that it's extraordinarily hard to kick and that it - I don't remember exactly the words that he uses, but he referred to it to me verbally many times as, like, the hardest thing that he's ever tried to kick, which he's tried to kick most things. He said it was harder than So he was very open and verbose about Oxycontin, having got addicted to Oxycontin.

151 7:18:39

MS. BREDEHOFT: So what, if any, observations did you make with Mr. Depp smoking cigarettes and joints, marijuana?

152 7:18:51

IO TILLETT WRIGHT: Mr. Depp, as far as I can see, always had a cigarette or joint in his mouth at all times, to the point where I was confused about how he could function. He also showed me his marijuana closet that had, I don't know, tens and tens of pounds of weed in it.

153 7:19:21

MS. BREDEHOFT: What, if any, observations did you make while you were staying at Sweetzer -- I think you said that was August 2013 through May of 2014 -- with respect to the type of alcohol and the amount of alcohol that Mr. Depp was consuming?

154 7:19:37

IO TILLETT WRIGHT: When I saw Mr. Depp drink, it was often hard liquor. I believe it was whiskey and gin and tequila, maybe. Could also be vodka. I don't know. He had a full bar in his -in 80, the house that they - with his recording studio in it I that they mostly stayed in. So I know whiskey for sure, and there was also red wine, a lot of red wine.

155 7:20:10

MS. BREDEHOFT: And when you talk about the whiskey and the red wine, how much did you observe Mr. Depp consume on any given occasion of those?

156 7:20:22

IO TILLETT WRIGHT: I don't know. The one occasion I know specifically was the one that I mentioned before, during the argument where he would suddenly have a glass of whiskey. And I remember it being, like, I remember clock -- because I grew up counting people's drinks, I remember clocking that it was a very large pour in the glass of whiskey.

157 7:20:49

MS. BREDEHOFT: If you recall those, I think my o question was, you know, what, if any, observations did you make or did Mr. Depp ever tell you about him blacking out?

158 7:20:59

IO TILLETT WRIGHT: Mr. Depp was very open with everyone that he was a heavy user. And he told me about -- I know there was one instance where he had this very large house, property, so if Sweetzer Avenue goes like this, the house that I was staying at, the 76, was down here. Then there's 78, which is right here, and then up here is 80. And then across the street, I guess, is 82. And 82 is a very large compound. So he and I were staying - I was at 76 or up at 80. And then 82, they lived in for a brief period of time.

159 7:21:45

IO TILLETT WRIGHT: And he told me about, like, vanishing into 82, into the, like, the property, because it was very lush and they had a lot of trees and went up quite far up the hill, and he told me about kind of like blacking out and going in there. On one instance, he told me - I know that he told me that in Australia he had blacked out, but he also told me that he fucked up. I don't - in terms of specific blackouts, there were a number - I think he said they were on the plane. He said that he didn't remember what had happened.

160 7:22:35

MS. BREDEHOFT: What, if anything, did Mr. Depp say to you about whether he wanted to become sober and clean?

161 7:22:47

IO TILLETT WRIGHT: Mr. Depp expressed to me that he wanted to get sober for Amber, that he didn't enjoy being sober, that it wasn't fun and that it was distressing and exhausting and very hard to do. He really, really, resented having to be sober. Yeah. He didn't want to be.

162 7:23:19

MS. BREDEHOFT: And what, if anything, did Mr. Depp say to you about his perception of Amber's role in him becoming sober and clean?

163 7:23:31

IO TILLETT WRIGHT: He expressed a number of times that he felt like she was his leash and she was holding him back from doing what he wanted to do in terms of substances and alcohol. Oh, I just wanted to go back to another incident that I remember. He told me he blacked out and was on the island; he went to the Bahamas. There were two different instances. One was, I guess, like they had only recently met, and he told me that he passed out face-down in the sand while his kids were there and that the staff had, like, whisked his kids away so that they didn't see it.

164 7:24:13

MS. BREDEHOFT: Mr. Tillett Wright, when you said that Mr. Depp used the term "monster," what do you recall him saying about that?

165 7:24:22

IO TILLETT WRIGHT: And the language that ended up being kind of settled on was that there was a side of him that was the monster and that it was not who he was, but it was something that lived within him that he had to battle. And the language that he used was of battle, battling - battling the demon, battling the monster so that the monster - you know, he would say things like, "The monster will not win. I will not be that type of man," you know. "I don't want to - I don't want to be that type of man or husband.

166 7:25:08

IO TILLETT WRIGHT: I don't want to hurt" - he would call her Slim, "our Slim, our girl," referring to all of her friends and him and her and I, yeah.

167 7:25:22

MS. BREDEHOFT: What, if any, observations did you make of Mr. Depp, both in terms of physical as well as temperament, when you perceived him as having too much to drink?

168 7:25:35

IO TILLETT WRIGHT: Mr. Depp would drink and/or take drugs. He would get very mean, very surly, very paranoid, extremely paranoid. He would weave these elaborate situations in which Amber was having affairs with every man she ever worked with and every woman she ever came in contact with. He became very demeaning. Johnny is incredibly intelligent, incredibly smart and witty, and he would point his jokes at people -- Amber's appearance, her talent, her lack of talent as he perceived it, why he thought that she was actually famous which he always implied was just because of her looks and because he thought that everyone wanted to have sex with her. And he would insult his fans.

169 7:26:48

IO TILLETT WRIGHT: He called them -- I remember he called them remoras which is a type of sucker fish that attaches itself to the hull of the ship, puts a hole in it, and then sinks it.

170 7:27:03

IO TILLETT WRIGHT: He would rail against his mother and his sister -- sisters. Pretty much, you know, anyone that he felt had crossed him or could cross him, he became very nasty about.

171 7:27:23

MS. BREDEHOFT: What, if anything, do you recall Mr. Depp saying about his mother and comparing his mother to Amber?

172 7:27:35

IO TILLETT WRIGHT: Mr. Depp told me that his mom was viciously cruel to him during his upbringing and that she was also viciously, like, violent with him and with his siblings and with his father. He referred to her -- pardon my language -- as a bitch and a cunt a lot. And he seemed to kind of compare them in the sense that he was -- he said at one point, something to the effect of -- it's right here, actually. Yeah. I already had a mum who was a bitch to me. I don't need another one in my life. There was a fair bit of that kind of like "My mom's been awful enough to me already.

173 7:28:34

IO TILLETT WRIGHT: I don't need another woman who's going to also be awful to me.

174 7:28:41

MS. BREDEHOFT: What, if any, discussions did you have I with Johnny about the fights he had with Amber?

175 7:28:51

IO TILLETT WRIGHT: We had a lot of discussions about his fights with Amber.

176 7:29:00

MS. BREDEHOFT: What do you recall?

177 7:29:02

IO TILLETT WRIGHT: In the very beginning, he expressed that she made him feel crazy, that he was so in love that it made him feel crazy. The very first time that I mentioned, September of 2013, when he and I were alone together a lot, he expressed that he thought she was cheating on him and sleeping with her costars in England on the films. And I said to him - or on the film And I said to him, "Listen, you know, I know her, I think, pretty well, and I talk to her a lot and I think - I think if she was having an affair, I would be one of the very few people that she would tell about it. And I don't hold secrets or lies for anybody, and I would tell you if that was happening so you could make your own decisions.

178 7:29:59

IO TILLETT WRIGHT: "But as far as I know, that's really not the case, and I think that she's really in love with you. And I think that she also is worried that you are having affairs because both of you are used to being sex symbols on Earth, and both of you need to just accept the fact that you're really in love with each other, lean in and be together and love each other."

179 7:30:23

IO TILLETT WRIGHT: And he told me that sometimes his jealousy would make him feel crazy and outside himself and that he had to get it under control and that it would cause them to fight, to be specific in regard to your question.

180 7:30:45

IO TILLETT WRIGHT: He told me about the fight that they had the time that I went up there - are you asking for specifics instances? Or are you asking about the nature of their fights?

181 7:30:53

MS. BREDEHOFT: Yeah. I am asking what he told you about their fights and specific instances, yes.

182 7:30:59

IO TILLETT WRIGHT: So to continue with what I was saying before, he told me about the fight in the middle of the night when I was living on the hill on Sweetzer is what - I mentioned that I saw him with the heavy pour of the whiskey. I went outside to the pool and spoke to him, and he told me about the argument that they had had and that she gets mean during fights and that it really hurts his feelings and that he, then, lashes out at her. And then, you know, she called him old, and he, then, calls her soon-to-be ugly and talentless, and then they get really ugly with each other. He told me about a fight that they had - we went to England that September. It was Whitney's birthday, I think, Amber's sister, Whitney, and Amber was stuck working. My birthday, Raquel's birthday, and Whitney's birthday, the three people that she's closest to, all have our birthdays in September. And Raquel's is just before the end of August. Whatever. We're all Virgos.

183 7:32:27

IO TILLETT WRIGHT: And she couldn't be with any of us on our birthday, so we all went to England to surprise her. And during that trip, Johnny proposed to her, and they, then, I'm pretty sure, that night after the proposal, got in a huge fight which they both told me about separately. And he said, "I'm pretty sure that she trashed the hotel room"

184 7:32:57

IO TILLETT WRIGHT: Let's see. I spoke to him after - I went and talked to him after their fight on the plane.

185 7:33:12

MS. BREDEHOFT: So that's the Boston/LA plane incident; is that right?

186 7:33:15

IO TILLETT WRIGHT: That's correct.

187 7:33:16

MS. BREDEHOFT: So, Mr. Tillett Wright, I'm going to ask you about the Boston/LA flight incident. You had talked about it a little bit earlier, and you just said now that you spoke with Mr. Depp about it. Is that correct?

188 7:33:31

IO TILLETT WRIGHT: That's correct.

189 7:33:32

MS. BREDEHOFT: Okay. What do you recall of your discussion with Mr. Depp about the Boston plane incident that happened in May of 2014?

190 7:33:44

IO TILLETT WRIGHT: And I went upstairs to his bedroom, which was, like, blacked out, and I woke him up. I remember shaking his shoulder and saying to him, "Hey, buddy, wake up," which was not something that a lot of people did to Johnny, wake him from his slumber. And he woke up and we had a conversation about what happened on the plane, and he didn't remember being on the plane. He didn't really remember getting off the plane. He didn't really remember much detail of anything. And he swore up and down that he was going to stop and he was going to stop drinking and taking drugs, and he was going to never do it again. That was that incident.

191 7:34:30

MS. BREDEHOFT: What, if any, meetings related to alcohol did you and Amber attend in this time frame?

192 7:34:39

IO TILLETT WRIGHT: I understand because we didn't go to many meetings. We -- I took Amber with me to Al-Anon, which is like a sister program to AA for the family and friends and loved ones of addicts and alcoholics, which I regularly attended. So she came with me to a number of Al-Anon meetings. She also had, I think, one or two phone calls with my dad's wife about how she dealt with helping him get off of his drugs and drink less. And she read a number of books about it. She was watching documentaries about it.

193 7:35:20

IO TILLETT WRIGHT: She was listening to any radio shows she could get on, like, anything, anything she could get her hands on that would give her some tools for how to deal with this, she consumed in that period.

194 7:35:30

MS. BREDEHOFT: What, if any, communication did Johnny have with you in this time frame about wanting to get back with Amber after the Boston plane incident?

195 7:35:43

IO TILLETT WRIGHT: We went to New York, and I remember we were staying at the Ace hotel in Midtown and Johnny started reaching out to me. He went, and when she went back to Boston to start filming again, would have been in like the next day or two because we weren't there for that long. And he reached out to me and basically said something to the effect of like, you know, "I have to fix this. I will do anything that I can."

196 7:36:23

IO TILLETT WRIGHT: And then, while he was in Boston, he let me know, and I think he was trying to reach Amber too but she wasn't ready to talk to him. He let me know that he had engaged Dr. Kipper and that he intended with every fiber in his being to get sober and that- the nature of the conversation, at that point, was that he was going to beat this thing, you know.

197 7:36:48

MS. BREDEHOFT: Please describe to me what transpired, what you discussed with Johnny and Amber related I to Australia in 2015.

198 7:36:58

IO TILLETT WRIGHT: After they were -- because they were married in February, and they were in Australia in the spring.

199 7:37:09

MS. BREDEHOFT: I'm going to interrupt you just for a moment, and forgive me. I just want to keep it chronologically there.

200 7:37:16

MS. BREDEHOFT: You had described earlier that you were present for the wedding, correct, in February of 2015?

201 7:37:22
202 7:37:23

MS. BREDEHOFT: Okay. And you also had discussed about Amber wanting Johnny to be sober for the wedding.

203 7:37:32

MS. BREDEHOFT: What, if any, observations did you make about Johnny at the ceremony and with respect to whether he was sober and clean?

204 7:37:41

IO TILLETT WRIGHT: You know, I don't actually know whether Johnny was -- I don't think Johnny was drinking on the day of their wedding. I really don't, actually, think he was. Let me rephrase that. Before the ceremony on the day of their wedding. Because I was going back and forth between their respective, like, private preparation quarters where they were getting ready because I was technically her best man, and his son, Jack, was his best man, but I wasn't one of the girls and felt more comfortable over there with them. But I was helping all the girls, so I was running back and forth on the golf carts.

205 7:38:28

IO TILLETT WRIGHT: Between, I was also taking pictures. I was one or two people who was friends with them that had worked as a photographer, so I volunteered to take pictures. So I was very intimate with Johnny and Jack leading up to the wedding, and he wasn't drinking, I don't think. I don't remember seeing him drink at all.

206 7:38:50

MS. BREDEHOFT: And then let me ask you this: After ! I the ceremony, as you were walking to the ! 17 reception, what, if anything, did Johnny Depp say ! 18 to you about Amber?

207 7:39:02

IO TILLETT WRIGHT: As we were walking back from the ceremony, we were coming into cafe Los Capones, which is where the party was happening, and I was walking with Johnny and congratulating him that they pulled it off and that they did it, you know, and he said, "We're married now. I can punch her in the face, and nobody can do anything about it.

208 7:39:30

MS. BREDEHOFT: So I'm going to, now, turn your attention to Australia, roughly a month later, after the wedding. You weren't present in Australia with Amber and Johnny, correct?

209 7:39:42

IO TILLETT WRIGHT: That's correct.

210 7:39:43

MS. BREDEHOFT: I'm showing you what has been marked as Exhibit Number 3.

211 7:39:46

MS. BREDEHOFT: Do you recognize anybody in this picture?

212 7:39:50

IO TILLETT WRIGHT: I do, yeah. Myself and Ms. Heard. I do, yeah.

213 7:39:54

MS. BREDEHOFT: Please describe what you see.

214 7:39:56

IO TILLETT WRIGHT: I see a number of long, thin, cuts.

215 7:40:01

MS. BREDEHOFT: And what, if any, similarity are those to ones you just described having seen after Amber returned from Australia?

216 7:40:13

IO TILLETT WRIGHT: Very similar.

217 7:40:14

MS. BREDEHOFT: All right. And are they the same? Or are they different ones?

218 7:40:17

IO TILLETT WRIGHT: I would have no way of knowing if they're the same or different ones, but they're similarly long, skinny cuts, like the ones that I saw after she was back from Australia.

219 7:40:28

MS. BREDEHOFT: Mr. Tillett Wright, I'm going to show you what's been marketed as Exhibit Number 5, and it's a text message exchange.

220 7:40:36

MS. BREDEHOFT: Do you recognize this text message number here below arrows?

221 7:40:42

IO TILLETT WRIGHT: That's my old phone number, yes.

222 7:40:44

MS. BREDEHOFT: Okay. So does this represent the text message exchange between you and Amber Heard on 12/16/2015?

223 7:40:53

IO TILLETT WRIGHT: Yes, it does.

224 7:40:54

MS. BREDEHOFT: Okay. And I'm going to start you at the top with the blue. It says "I need you." Do you recognize who is sending that message?

225 7:41:07
226 7:41:07

MS. BREDEHOFT: Mr. Tillett Wright, I'm going to ask you to take a look at what has been marked as Exhibit Number 6. Do you recognize the person in this photo?

227 7:41:15

IO TILLETT WRIGHT: Yes, I do.

228 7:41:17

MS. BREDEHOFT: Please describe what you see in this picture.

229 7:41:21

IO TILLETT WRIGHT: I see Amber Heard, and I see an injury to Amber's scalp.

230 7:41:30

MS. BREDEHOFT: Okay. And what, if anything, do you recall about seeing anything similar to that when you arrived in December 2015 at Amber's penthouse?

231 7:41:46

IO TILLETT WRIGHT: I remember this being one of the injuries that I was shown when I arrived at penthouse 3 at the eastern building on December 16th, 2015.

232 7:41:56

MS. BREDEHOFT: And does this picture that's marked as Exhibit Number 6 accurately depict the -- what you recall seeing?

233 7:42:05

IO TILLETT WRIGHT: I remember this being one of, I think, maybe two scalp injuries that I remember. I remember there was another one as well, but I could be mistaken. I believe there was another one on a different part of her head as well.

234 7:42:18

MS. BREDEHOFT: Do you recognize the picture that is set forth as Exhibit Number 7?

235 7:42:26

IO TILLETT WRIGHT: Yes, I do

236 7:42:28

MS. BREDEHOFT: Please describe for me what is depicted in this picture that you recognize.

237 7:42:34

IO TILLETT WRIGHT: This was a picture of Amber's scalp.

238 7:42:38

MS. BREDEHOFT: And does it accurately -- does this accurately depict what you saw when you were shown it, as you testified earlier, in December 2015?

239 7:42:50

IO TILLETT WRIGHT: Yes, it does.

240 7:42:50

MS. BREDEHOFT: Mr. Tillett Wright, I'm going to show you what has been marked as Deposition Exhibit Number 8. Do you recognize this picture?

241 7:43:00

IO TILLETT WRIGHT: Yes, I do.

242 7:43:01

MS. BREDEHOFT: Please describe what is depicted there.

243 7:43:03

IO TILLETT WRIGHT: This is Amber Heard's face with a very swollen lip.

244 7:43:10

MS. BREDEHOFT: And does this accurately depict what you observed when you arrived at Amber Heard's penthouse in December of 2015?

245 7:43:23
246 7:43:24

MS. BREDEHOFT: I'm going to show you what has been marked as Deposition Exhibit Number 9. Do you recognize this picture?

247 7:43:29

IO TILLETT WRIGHT: Yes,! do.

248 7:43:31

MS. BREDEHOFT: Please describe.

249 7:43:32

IO TILLETT WRIGHT: This is the clump of hair that I was shown, I believe, when I arrived at penthouse 3 on the night of December 16th, 2015.

250 7:43:41

MS. BREDEHOFT: And does this accurately and genuinely depict the scene that you recall seeing?

251 7:43:47

IO TILLETT WRIGHT: Yes, it does.

252 7:43:50

MS. BREDEHOFT: Thank you. Now, did -- what, if any, O plans was there, as of December 16, 1 7, of 2015, for Amber to be spending Christmas with Mr. Depp and his kids? Do you recall?

253 7:44:16

IO TILLETT WRIGHT: Can we take those pictures down while we talk?

254 7:44:18

IO TILLETT WRIGHT: Yes, I do recall. There was a plan for Johnny and Amber and Lily-Rose and Jack and Raquel and her boyfriend, I think, at the time, Josh, to go to the Bahamas -- oh, and Raquel's mom and Amber's parents to go to the Bahamas and spend Christmas on the island together, yeah.

255 7:44:49

MS. BREDEHOFT: Mr. Tillett Wright, I'm going to ask you what, if any, conversations did you have with Johnny Depp about the December 15 incident?

256 7:44:54

IO TILLETT WRIGHT: I don't think that he and I -- I don't know that he and I had a direct conversation about it. I'm not sure if he and I had a direct conversation.

257 7:45:05

MS. BREDEHOFT: So what, if any -- I'm going to show you, Mr. Tillett Wright, what has been marked as Deposition Exhibit Number 16. It's a text message exchange dated 2/10/2016. Do you recognize this O document?

258 7:45:10

IO TILLETT WRIGHT: Yes, I do. It's a text exchange between me and Amber Heard about a video that she sent me.

259 7:45:13

MS. BREDEHOFT: Okay. Now, it starts out, "Hi, Steve left me a voicemail at 5:00 a.m." And that's from you, correct?

260 7:45:24

IO TILLETT WRIGHT: That's correct.

261 7:45:25

MS. BREDEHOFT: Do you remember what the voicemail message was?

262 7:45:31

IO TILLETT WRIGHT: Yeah. Yeah. Johnny called me at 5 in the morning and left me a voicemail in the character of some kind of management, of, like, a property manager, and he said something about "Yes, hello. This is management," and I don't remember what he said, but it was something to do with, like, "We have a situation that we need to change out of something," and it was just a lengthy, just, off-the-wall, nut-bag ramble in the character of management

263 7:46:09

MS. BREDEHOFT: Mr. Tillett Wright, I'm going to show you what has been marked as Exhibit Number 17.

264 7:46:13

MS. BREDEHOFT: And then, Alex, I'm going to ask you to play this.

265 7:46:30

MR. DEPP: Motherfucker. Motherfucker.

266

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

267 7:46:47

MS. HEARD: What happened? What happened?

268 7:47:05

MR. DEPP: Nothing. I'

269 7:47:22

MS. HEARD: Nothing happened this morning. You know that?

270 7:47:27

MR. DEPP: Were you in here?

271 7:47:28
272 7:47:29

MR. DEPP: So then nothing happened to I you this morning?

273 7:47:31

MS. HEARD: Yes. You're right. I just woke up and you were so sweet and nice. We were not even fighting this morning. All I did was say I 5 sorry.

274 7:47:41

MR. DEPP: Did something happen to you this morning? I don't think so.

275 7:47:52

MS. HEARD: Hell, that's the thing.

276 7:47:53

MR. DEPP: You want to see crazy? I'll giving you fucking crazy. Bitch. All your crazy, all the crazy.

277 7:48:01

MS. HEARD: Have you drunk this whole thing this morning?

278

MR. DEPP: Oh, you got this going. You got this thing going.

279

MS. HEARD: You just started it.

280

MR. DEPP: Oh, really?

281 7:48:11

MS. HEARD: Yeah.

282

MR. DEPP: Really. You saved that shit on me motherfucker.

283 7:48:21

MS. HEARD: No, I didn't. You were smashing shit.

284 7:48:30

MR. DEPP: Bye. Ass. (Indiscernible.)

285 7:48:40

MS. BREDEHOFT: Thank you, Alex. You can take this down now.

286

[SECTION HEADER]: BY MS. BREDEHOFT:

287 7:48:45

MS. BREDEHOFT: Mr. Tillett Wright, do you recognize that video?

288 7:48:49

MS. BREDEHOFT: Yes, I do. Was that the video that Amber sent to you on the text message exchange on February I 0th, 2016?

289 7:48:57
290 7:48:58

MS. BREDEHOFT: Do you recall watching that video on February 10, 2016?

291 7:49:05

IO TILLETT WRIGHT: Yes, I do. I recall watching that video at the time that I received those text messages.

292 7:49:10

MS. BREDEHOFT: So I'm going to take you to 21 May 2016. What do you recall with respect to a telephone call you received from Amber?

293 7:49:24

IO TILLETT WRIGHT: Sure I was in New York I was there visiting family I was in Greenpoint Brooklyn I was walking down Manhattan Avenue and I got believe a text message from Amber that said something to the effect of like Can you talk And so I called and I was walking down the street as this happened.

294 7:49:55

IO TILLETT WRIGHT: She put me on speakerphone, so I was talking to both of them. He had just stopped by to pick up some of his stuff, and he has a theory that he - either he wants to ask you about or I said, "Okay. Sure. Hello, Johnny," like, all right.

295 7:50:19

IO TILLETT WRIGHT: And he - I think it was he said or she said, "Johnny thinks that you and I together defecated on his pillow." I think the words were - used were - "shit on his pillow."

296 7:50:44

IO TILLETT WRIGHT: So I started laughing. And I just, I - I was laughing. She was laughing, and when I realized that he was serious, I was like, "Okay. Look, you know, first of all, I wasn't there that day." And so he got very agitated by the fact that she and I thought it was funny. And he started to get more and more agitated, and I could hear him walk away from the phone.

297 7:51:15

IO TILLETT WRIGHT: He came clomping back down the stairs.

298 7:51:17

IO TILLETT WRIGHT: I heard, like, a noise, and then the phone dropped, and he said to her, "Oh, you think I hit you? You think I fucking hit you? What if I peel your fucking hair back?" And then I heard the phone drop again, and then I heard her scream. I remember her screaming. And I hung up the phone, and I called Raquel immediately because I know that she lives one door away and her and her boyfriend, Josh, who is a big dude, would be able to get there the fastest. And I called or texted her right away, and I hung up with her and immediately called 911 in New York.

299 7:52:15

IO TILLETT WRIGHT: And then I called a friend of mine in LA who I knew had met Amber a number of times, and I think I may have placed a second call to NYPD. Now I'm frazzled and I don't remember, but I think I called NYPD.

300 7:52:34

MS. BREDEHOFT: Mr. Waldman made statements in April and June of 2020 that both Amber Heard and her friends in the media use fake sexual violence allegations as both a sword and shield depending on their needs. They have selected some sexual violence hoax facts as the sword, inflicting them on the public and Mr. Depp. That was made on April 8, 2020. What, if any, impact did that have on Amber based on your observations?

301 7:53:13

IO TILLETT WRIGHT: Amber retreated Amber became Is isolated, embattled, extraordinarily distressed

302 7:53:27

MS. BREDEHOFT: And then on June 24, 2020, Waldman I accused Amber Heard of committing a "abuse hoax" ! 11 against Depp. IP What were your observations of how this impacted Amber?

303 7:53:41

IO TILLETT WRIGHT: I think that my previous statement 1:: ! encompassed that.

304 7:53:48

MS. BREDEHOFT: During the time that you were friends with Johnny and you were speaking with him up until, you testified, December of 2015, what, if anything, did Johnny Depp ever tell you about Amber Heard being physically violent to him?

305 7:54:06

IO TILLETT WRIGHT: Nothing ever at any point.

306

[SECTION HEADER]: EXAMINATION BY COUNSEL FOR THE PLAINTIFF AND BY MR. PRESIADO:

307 7:54:07

MR. PRESIADO: Do you agree with me that Mr. Depp and Ms. Heard had many verbal arguments?

308 7:54:18

IO TILLETT WRIGHT: Yes, I do.

309 7:54:19

MR. PRESIADO: And you were a witness to a lot of those verbal arguments, correct?

310 7:54:22

IO TILLETT WRIGHT: I was a witness to some verbal arguments.

311 7:54:25

MR. PRESIADO: Okay. And did you ever hear Ms. Heard say anything mean to Mr. Depp in those arguments?

312 7:54:37
313 7:54:37

MR. PRESIADO: And did you ever hear Ms. Heard say anything vicious to Mr. Depp in those arguments?

314 7:54:45
315 7:54:45

MR. PRESIADO: So would you agree with me that when they argued, they were mean and vicious to one another in what they said?

316 7:54:53

IO TILLETT WRIGHT: I would categorize it very differently, sir.

317 7:54:57

MR. PRESIADO: Well, you testified that you heard Ms. Heard say mean and vicious things to Mr. Depp when they argued and vice versa is that accurate

318 7:55:13
319 7:55:16

MR. PRESIADO: And although you witnessed arguments, verbal arguments between the two of them where they exchanged mean and vicious statements, you never saw Mr. Depp assault or beat Ms. Heard on any occasion, correct?

320 7:55:32

IO TILLETT WRIGHT: No, I never saw either of them physically assault the other one.

321 7:55:35

MR. PRESIADO: Did you ever experience him become violent as a result of or because of smoking cigarettes or joints?

322 7:55:43

IO TILLETT WRIGHT: As I've already explained to you probably eight times, I've never seen Mr. Depp become physically violent with Ms. Heard. So if that's what you're asking me, if he smoked a cigarette and that made him violent, I think you know that that's ridiculous and the answer is, again, no.

323 7:56:02

MR. PRESIADO: Did you ever witness Mr. Depp become violent in any manner on account of him smoking cigarettes or joints?

324 7:56:09

IO TILLETT WRIGHT: If you want my honest answer, my honest answer is that Mr. Depp mixed substances constantly, and I keep trying to tell you that. He mixed all kind of things together when he got crazy and violent. So - and upset and paranoid. So - and I never knew what he had taken.

325 7:56:29

MR. PRESIADO: When you say "when he got violent," when did you see him get violent?

326 7:56:33

IO TILLETT WRIGHT: I saw Mr. Depp throw glasses and I O dishware on at least two occasions, which I would characterize as physically violent And do I know if he smoked marijuana or cigarettes before that? I don't know.

327 7:56:45

MR. PRESIADO: When were those two occasions?

328 7:56:47

IO TILLETT WRIGHT: Sometime during the time that I was living in Sweetzer.

329 7:56:50

MR. PRESIADO: And --

330 7:56:53

IO TILLETT WRIGHT: And once at the eastern building.

331 7:56:55

MR. PRESIADO: And prior to throwing those dishes, did you witness him imbibing any drugs or alcohol?

332 7:57:08

IO TILLETT WRIGHT: I couldn't tell you but seeing as Mr. Depp always was smoking cigarettes and marijuana my assumption would be yes

333 7:57:24

MR. PRESIADO: Okay. Do you recall when Ms. Bredehoft showed you a picture of a clump of hair on the floor?

334 7:57:44
335 7:57:46

MR. PRESIADO: When you saw that, that was more than a day after it was allegedly pulled from her head by is Mr. Depp; is that right?

336 7:57:57

IO TILLETT WRIGHT: Well, if you want to get technical, my understanding was that their fight happened very late at night, which was technically the morning of the 16th. And I arrived at her house around midnight, the night of the 16th. So, technically, it's not more than a day after; it's in the same 24-hour period. So technically, the answer to your question is no.

337 7:58:23

MR. PRESIADO: Okay. So I'm just talking about the hair on the ground that you saw. When you saw it, was it your understanding that it had been there for more than 20 hours?

338 7:58:33

IO TILLETT WRIGHT: I have no idea what time their fight started or ended, so I don't know if it was 20 hours or 16 hours or 13 hours. But my understanding, again, is that they had gotten into a fight sometime in the morning of the 16th/late at night on the 15th. I don't know at what point during which - during that fight in which the clump of hair was ripped out of her head, but it happened sometime then and there. So, yeah, sure my understanding was that that clump of hair had not been moved since it was ripped out of her head.

339 7:59:18

THE COURT: All right. Completes --

340 7:59:21

MS. BREDEHOFT: That completes that one, Your Honor.