Alan Blaustein — Direct
340 linesTHE COURT: All right. Ladies and gentlemen, let's go ahead and take our afternoon recess. Please do not discuss the case, and do not do any outside research, okay?
THE COURT: We'll see you back in 15 minutes.
THE COURT: All right. We'll come back at 3:45. Does that give you time to be ready?
MS. BREDEHOFT: Yes, Your Honor.
THE COURT: All right. 3:45.
COURT BAILIFF: All rise. seated and come to order.
THE COURT: Okay. Are we ready for the
COURT BAILIFF: All rise. Please be jury?
MR. NADELHAFT: Your Honor, we have a preliminary.
THE COURT: Okay. You want to approach with the exhibits?
MR. NADELHAFT: Yeah.
THE COURT: Okay.
MR. NADELHAFT: So I believe we're in agreement that 1049 is admitted.
THE COURT: Okay.
MR. CRAWFORD: No objection.
MR. NADELHAFT: And then 1050 is his notes that the doctor -- Dr. Blaustein is Mr. Depp's psychiatrist.
THE COURT: Okay.
MR. NADELHAFT: And these are his notes which he testifies these are all Depp's statements.
MR. CRAWFORD: Dr. Blaustein's interpretation of Depp's statements, and there are notes, which Dr. Blaustein has notes to himself.
MR. NADELHAFT: Which he testifies
THE COURT: Are you able to read these? ,3
MR. CRAWFORD: He could not, unfortunately. I 5
MR. NADELHAFT: So I know what we did with-- Your Honor, what we did with Erin Falati's notes, if I recall, was that we played them Remember there was an issue about what was redacted and what wasn't.
THE COURT: Right. Right.
MR. NADELHAFT: And we played it. We're comfortable playing these without showing them
THE COURT: All right.
MR. NADELHAFT: Maybe you can --
THE COURT: I can try to review this.
MR. NADELHAFT: No, no, no. As he's testifying to it, we're going to be seeing the portions of it, and I guess maybe afterwards, we can --
THE COURT: We can have a discussion about it?
MR. NADELHAFT: Yeah.
THE COURT: Okay.
MR. NADELHAFT: That's my suggestion.
MR. CRAWFORD: Some of the portions ! 5 that get read in would come in, but everything else is redacted.
THE COURT: Redacted out.
MR. NADELHAFT: Sure. We can do it that way.
THE COURT: We can look at that. Does anybody have a problem with that?
MS. VASQUEZ: No.
THE COURT: So there was an agreement that if it was read in during the deposition, that that can come in?
MS. VASQUEZ: That's fine.
MR. NADELHAFT: We're all on the same page. We won't show it.
THE COURT: Okay. That's fine. We won't show it.
MR. NADELHAFT: We won't show it, so that way there's no question about what's redacted and what's not.
THE COURT: So I'll admit as redacted. The only thing that's going to be admitted in evidence are these statements that will be read on in the deposition?
THE COURT: MR... NADELHAFT: Sure.
THE COURT: Everybody agree with that? No objection to 1049, right? 1049's in evidence.
MS. VASQUEZ: Thank you, Your Honor.
THE COURT: All right. Thank you.
THE COURT: All right. Thank you Your next witness.
MR. NADELHAFT: Your Honor, we call Dr. Alan Blaustein.
THE COURT: All right.
MR. NADELHAFT: B-L-A-U-S-T-E-1-N.
THE COURT: Thank you, sir.
MR. NADELHAFT: Oh, and I'm asking questions first. I believe I may be the only one asking questions.
THE COURT: All right. All right. Thank you. ALAN S. BLAUSTEIN, M.D.
THE COURT: Being first duly sworn, was examined and testified as follows:
MR. NADELHAFT: Can you provide your full name?
DR. BLAUSTEIN: Alan Scott Blaustein.
MR. NADELHAFT: You're a doctor, correct?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: And you're a psychiatrist?
DR. BLAUSTEIN: Yes.
MR. NADELHAFT: How long have you been a psychiatrist
DR. BLAUSTEIN: Since 1987.
MR. NADELHAFT: And you went to medical school?
DR. BLAUSTEIN: Yes.
MR. NADELHAFT: What medical school did you go to?
DR. BLAUSTEIN: Northwestern University.
MR. NADELHAFT: Now, Johnny Depp was a patient of yours, correct?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: You understood that Mr. Depp had substance dependence issues; is that correct?
DR. BLAUSTEIN: Yes.
MR. NADELHAFT: Do you recall what substance issues -- what substances he had -- Mr. Depp had issues with?
DR. BLAUSTEIN: Marijuana, alcohol, opiates, I believe.
MR. NADELHAFT: Did you ever have an understanding that Mr. Depp had an anxiety syndrome?
DR. BLAUSTEIN: I knew Mr. Depp had anxiety.
MR. NADELHAFT: And how did you become aware that Mr. Depp had anxiety?
DR. BLAUSTEIN: He told me that
MR. NADELHAFT: Do you recall having any conversation that Mr. Depp was bipolar?
DR. BLAUSTEIN: There was some question about a bipolar disorder diagnosis, but I cannot remember any specifics about the discussion.
MR. NADELHAFT: Do you recall having a conversation with Mr. Depp about a bipolar diagnosis?
DR. BLAUSTEIN: No.
MR. NADELHAFT: What behaviors did Mr. Depp acknowledge I that should be changed?
DR. BLAUSTEIN: Certainly, his drug use. And his turning to drugs for - to help relieve a lot of the psychic pain that he was experiencing.
MR. NADELHAFT: In working with Mr. Depp, would you I agree that he had fundamental -- that Mr. Depp had fundamental issues with anger?
DR. BLAUSTEIN: I - I would say that he expressed having issues with anger.
MR. NADELHAFT: Mr. Depp expressed having issues with anger?
DR. BLAUSTEIN: Yes.
MR. NADELHAFT: Did Mr. Depp express having issues with anger towards Amber?
DR. BLAUSTEIN: He expressed having anger towards her, yes.
MR. NADELHAFT: Do you recall what reasons Mr. Depp told you as to why he was expressing anger towards Amber?
DR. BLAUSTEIN: I had - no. I'll have to say no.
MR. NADELHAFT: In working with Mr. Depp, was he ever suspicious of Amber having affairs?
DR. BLAUSTEIN: I can recall how he expressed feelings of jealousy, but I don't remember if it was about affairs.
MR. NADELHAFT: Do you recall any more detail about what Mr. Depp was feeling jealousy toward Amber about?
DR. BLAUSTEIN: No.
MR. NADELHAFT: In working with Mr. Depp, did you see that he -- Mr. Depp had any issues with patience?
DR. BLAUSTEIN: Yes, he was impatient.
MR. NADELHAFT: What is your understanding about issues that Mr. Depp had with Amber?
DR. BLAUSTEIN: It was a very chaotic relationship with a lot of fluctuations, ups and downs, and lots of difficulty and emotional expressions and lots of anger in both places, and, you know, high intensity affect and emotional expression. A lot of love, a lot of disappointments, a lot of fears.
MR. NADELHAFT: Dr. Blaustein, I'm showing you what's been marked as Blaustein exhibit 3.
MR. NADELHAFT: Do you recognize this document?
DR. BLAUSTEIN: Yes.
MR. NADELHAFT: What is it?
DR. BLAUSTEIN: It's my invoice billing document.
MR. NADELHAFT: Okay. This is from your files?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: And you keep this document in the ordinary course of business?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: And this billing invoice is for Johnny Depp, correct?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: And so where it says I 0/2/14 from your billing records, would this be -- is this your understanding the first time you met with Mr. Depp?
DR. BLAUSTEIN: By phone, yes.
MR. NADELHAFT: And, in totaL if we look at the number of sessions you either met or spoke to Mr. Depp that weren't canceled or he didn't show up, my counting comes to 18 times you met with Mr. Depp.
MR. NADELHAFT: Does that sound about right?
DR. BLAUSTEIN: Looks like 18 times.
MR. NADELHAFT: Did you have any concerns about any of I the amounts of medications that Mr. Depp was taking?
DR. BLAUSTEIN: I had concerns about the Adderall that I would have expressed to him.
MR. NADELHAFT: And what were the concerns about the Adderall?
DR. BLAUSTEIN: Again, I don't recall the specific conversations, but I would have been asking about how he was diagnosed to have ADHD or under what circumstances he would take that, especially if he wasn't currently working.
MR. NADELHAFT: Did you ever talk to Mr. Depp about what he did when Marilyn Manson would visit? ,14
DR. BLAUSTEIN: No.
MR. NADELHAFT: When you were working with Mr. Depp, did you have any understanding whether Mr. Depp was still abusing drugs and alcohol or not?
DR. BLAUSTEIN: Yes.
MR. NADELHAFT: But you do recall that there were times in your working with Mr. Depp where he had breakthrough uses of drugs or alcohol?
DR. BLAUSTEIN: Yeah, that his relative sobriety was not complete, yes.
MR. NADELHAFT: And that's what you mean by I! "breakthrough usage," that his sobriety, Mr. Depp's sobriety, was not complete?
DR. BLAUSTEIN: Well, relative sobriety. Again, I said relative sobriety because he did continue to use marijuana throughout, almost entirely throughout the time that I - even with a short-time exception, I think. So I called it "relative sobriety," then there would be some breakthrough uses of other substances.
MR. NADELHAFT: Okay. When you say breakthrough usage, just so everyone understands, what do you mean by that?
DR. BLAUSTEIN: He was trying to be sober. He was working on sobriety. And by breakthrough uses, sobriety would be the abstinence of using a substance. And so the breakthrough would be on a particular time he would have used the substance that he was trying to be sober of, abstinent of.
MR. NADELHAFT: Okay. So in addition to marijuana, in the time that you saw Mr. Depp from October of 2014 through January of 2015, there were other times -- there were times where Mr. Depp broke his sobriety with drugs or alcohol in addition to marijuana, correct?
DR. BLAUSTEIN: I believe so, yes.
MR. NADELHAFT: How did you come to that understanding?
DR. BLAUSTEIN: He would have told me.
MR. NADELHAFT: Do you know why Mr. Depp stopped seeing you?
DR. BLAUSTEIN: I know he was preparing to leave to Australia to go to work and - I assumed that was the reason.
MR. NADELHAFT: But he hadn't returned to you since he went to Australia in 2015, correct?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: And did anyone inform you as to why he stopped seeing you?
DR. BLAUSTEIN: No.
MR. NADELHAFT: Blaustein exhibit 9 are notes reflecting your care of Mr. Depp, correct?
DR. BLAUSTEIN: Right.
MR. NADELHAFT: And you kept these notes in the ordinary course of business, correct?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: And you kept these notes in a file for Mr. Depp, correct?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: And this is page 1 of those notes from October 2nd, 2014, correct?
DR. BLAUSTEIN: Correct. There would be plenty of places where I don't remember - I can't read what they say. They are for my current retention purposes only in these particular notes.
MR. NADELHAFT: Okay.
DR. BLAUSTEIN: And that's what makes them process notes.
MR. NADELHAFT: In working with Mr. Depp, did he discuss any abuse he received as a child or an adolescent?
DR. BLAUSTEIN: Yes.
MR. NADELHAFT: And do you recall any difficulties that Mr. Depp was talking to you about in his relationship with his fiancee?
DR. BLAUSTEIN: No. Not from this.
MR. NADELHAFT: What does it say?
DR. BLAUSTEIN: "Such a pain in the ass."
MR. NADELHAFT: Do you recall why he was saying Amber was a pain in the ass?
DR. BLAUSTEIN: No.
MR. NADELHAFT: Okay. And what's the next thing say?
DR. BLAUSTEIN: Well, in boxes about his kids' mom
MR. NADELHAFT: Okay.
DR. BLAUSTEIN: And, again, looks like I have the word "destructive."
MR. NADELHAFT: What was destructive referring to? Do you know?
DR. BLAUSTEIN: I don't know. No, I don't Something, relationship 14 to 15 years, mother of my kids. I, Out of that officially. He didn't want to be his dad, thinking I'm not- abandon them like his dad. Then below kids, it says "Clear, better." She needed me to be all this - needed me to be all this week or all this work." I don't know.
MR. NADELHAFT: If you turn to the next page, it says page 2.
DR. BLAUSTEIN: Got it.
MR. NADELHAFT: And then what's the next line say?
DR. BLAUSTEIN: "There was violence/rage that we had over a couple years."
MR. NADELHAFT: Okay. And so what is Mr. Depp referring to there? Do you recall? So, do you recall that in working with Mr. Depp, that he spoke about violence and rage in other relationships in addition to his relationship with Amber?
DR. BLAUSTEIN: Well, rage and chaos. I don't remember violence, but I do remember rage and chaos. And, again, in the context of this is, is I had met him at this point. This is an initial telephone consultation to see whether or not he was going to start therapy with me.
MR. NADELHAFT: But in your working with Mr. Depp, was he talking about rage and chaos with relationships in addition to his relationship about Amber, correct?
DR. BLAUSTEIN: Yes. Yes.
MR. NADELHAFT: What other relationships was he talking ! about rage and chaos?
DR. BLAUSTEIN: Again, I don't have the specific recollection, but I think it included his -- the mother of his children and arguments about -- not child custody, child care, or visitation or access to the children.
DR. BLAUSTEIN: On the left it says "Raised two kids, 15 and 12." And then below that, "She tried to protect me. She tried to protect me too."
MR. NADELHAFT: Do you know what that's referring to?
DR. BLAUSTEIN: My association now is his sister, but I don't -- I don't think that's true. I don't have a specific recollection no.
DR. BLAUSTEIN: "Wouldn't take fear. Wake up to fight devil. Wait up to fight devil."
MR. NADELHAFT: Do you know what that's referring to, "wait up to fight devil"?
DR. BLAUSTEIN: I think he referred to a devil as some version of internal depression and chaos that he felt that he made an everyday phenomenon because he was struggling. And I think he maybe labeled that as the devil.
MR. NADELHAFT: So Mr. Depp labeled something internal to him as the devil?
DR. BLAUSTEIN: As a representation of something horrible inside of himself, is what I would say.
MR. NADELHAFT: So the devil was something horrible inside of himself, correct? That's what --
DR. BLAUSTEIN: Again, I don't think he ever said that, so I'm going to be careful here.
DR. BLAUSTEIN: The devil was the representation of the battle that he had many days when he woke up with depression and the anxiety and fears that he had.
MR. NADELHAFT: Did Mr. Depp ever refer to himself as a monster?
DR. BLAUSTEIN: I remember the word "monster" in my office, but I don't know if he was referring to himself or not. Maybe that will be more revealed as we go forward.
MR. NADELHAFT: Now, turning to Blaustein 12, which is page 4 of this exhibit, there's a 3 at the top, correct?
DR. BLAUSTEIN: Yes.
MR. NADELHAFT: And then to the right, that says "Amber, fiancee," correct?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: And then there's --
DR. BLAUSTEIN: "Work through anger," just below that?
MR. NADELHAFT: And when you're saying "work through anger," is that referring to his anger towards !
MR. NADELHAFT: Amber?
DR. BLAUSTEIN: I think what he was saying then was that part of his goal of therapy was to work through anger that he and his fiancee had towards each other. Then going back to the left, "Better with girl about it. Self-destructive. Hard to not put in front of me."
MR. NADELHAFT: Do you know what "self-destructive, hard not to put in front of me" means -- is it referring to?
DR. BLAUSTEIN: I think the self-destructive was his drug use. I think that's what he's referring to at this time.
MR. NADELHAFT: I'm now looking at Blaustein 13, which has a page 4. I Are you there?
DR. BLAUSTEIN: Yes, I am.
MR. NADELHAFT: Okay. And at the top it says Johnny/Debbie, correct?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: All right. And then the date, it says 10/ what?
DR. BLAUSTEIN: I think that's 10/7.
MR. NADELHAFT: So it says JD 10/21/14, correct?
DR. BLAUSTEIN: Correct. A lot of things, work, intense work, fatigue, need a minute, here I can say with certainty his words, "shit with my girl."
MR. NADELHAFT: And what's that referring to?
DR. BLAUSTEIN: Difficulties he was having with Amber.
MR. NADELHAFT: And do you recall what he was talking about? What difficulty he was having with -- Mr. Depp was having with Amber?
DR. BLAUSTEIN: No.
MR. NADELHAFT: The next line looks like it says, "She refuses to accept."
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: Do you know what Amber refuses to except? What Mr. Depp was referring to?
DR. BLAUSTEIN: No. And to the right, it says, Amber -- I
MR. NADELHAFT: What?
DR. BLAUSTEIN: "Amber wedding."
MR. NADELHAFT: Were you talking at this point about potentially Mr. Depp and Amber marrying?
DR. BLAUSTEIN: Yes. He was talking about that, yes.
MR. NADELHAFT: Okay. And then what does it say under "She refuses to accept"?
DR. BLAUSTEIN: "Wedding February."
MR. NADELHAFT: And then what's next?
DR. BLAUSTEIN: "Not want to go to marriage, 51 years old."
MR. NADELHAFT: Were there any discussions that you had with Mr. Depp where he had concerns about the age difference between him and Amber?
DR. BLAUSTEIN: I don't think so.
MR. NADELHAFT: Okay.
DR. BLAUSTEIN: No.
MR. NADELHAFT: What does it say under "51 years old"?
DR. BLAUSTEIN: "A lot of life experiences. You're being my mother and psychotic sister."
MR. NADELHAFT: What did you understand Mr. Depp referring to where you wrote You're being my mother and my psychotic sister?
DR. BLAUSTEIN: I think that's something that he said - he told me he said to her.
MR. NADELHAFT: That Mr. Depp said to Amber? "You're being my mother and psychotic sister"?
DR. BLAUSTEIN: That's what I would think, yes.
MR. NADELHAFT: Okay. Then the next line?
DR. BLAUSTEIN: "High tolerance for marijuana."
MR. NADELHAFT: Who has a high tolerance for marijuana?
DR. BLAUSTEIN: He did.
MR. NADELHAFT: All right. Turning to the next page, which is Blaustein 15, and where -- I have a number 5 on the top there. What does it -- "self-something"?
DR. BLAUSTEIN: "Self-destructive very early."
MR. NADELHAFT: And was Mr. Depp talking about himself being self-destructive very early?
DR. BLAUSTEIN: Yes.
MR. NADELHAFT: Okay. How was he being -- how was Mr. Depp describing that he was self-destructive?
DR. BLAUSTEIN: I think again I don't recall but y let's continue and maybe something's there.
MR. NADELHAFT: So he was trying to be sober from booze and pills, correct?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: Okay. And then was it you who said "reward"?
DR. BLAUSTEIN: Yeah. Asking about where could he get Is rewards elsewhere. Where did he get reward - I mean, I asked him where did he get rewards elsewhere. And there he said in the past MDMA, I ll ecstasy, cocaine.
MR. NADELHAFT: So what do you understand where you write "MDMA, ecstasy, cocaine"?
DR. BLAUSTEIN: I am not quite sure, but those are Its things that he had used in the past. There is I another possibility that I had asked him I specifically about that, but I don't think so. Its It's more likely that those were things he had I used in the past.
MR. NADELHAFT: Do you know what pills Mr. Depp was referring to, to be sober from?
DR. BLAUSTEIN: I know oxycodone was a main thrust of I that type.
MR. NADELHAFT: And then it says -- back to the left, ; it says, "left of£"
DR. BLAUSTEIN: Yeah. And that's probably a note to myself to try to get back to. Left off a reward loop mechanism. And it's parallel to a relationship. What kinds of rewards could come back to him that could be healthy. What kinds of rewards that could come from a relationship that could be healthy? And then, talking about biology changes. So I made a note to myself there to talk about how the brain changes in the face of many of these drugs over time.
MR. NADELHAFT: Did you talk with Mr. Depp at all that his brain can change as he continues to take these medications -- these drugs?
DR. BLAUSTEIN: Yes, I did.
MR. NADELHAFT: And then it says 10/27/14.
DR. BLAUSTEIN: More on relationship issues being accused in his word of being manic Grounded from seeing children Son is one of the positive aspects of the relationship I'm assuming he's talking about his past relationship there.
MR. NADELHAFT: Mr. Depp was saying that Amber reminded him of his mom and his psychotic sister.
DR. BLAUSTEIN: That the relationship reminded him of his relationship with his psychotic sister and his mother, yes.
MR. NADELHAFT: And Mr. Depp talked about that he was being accused of being manic?
DR. BLAUSTEIN: Yes.
MR. NADELHAFT: Did he say who accused him of being manic?
DR. BLAUSTEIN: I assume from this, it was Amber.
MR. NADELHAFT: Turn to the next page, Blaustein 16. And this is 10/29/14 at the top?
DR. BLAUSTEIN: "Mood euthymic."
MR. NADELHAFT: What does that mean?
DR. BLAUSTEIN: Attention - "normal mood. Attention decreased."
MR. NADELHAFT: What do you mean by, "attention decreased"?
DR. BLAUSTEIN: Attention, needing attention. "Memory transitional difficulties."
MR. NADELHAFT: What do you mean by having transitional difficulties with his memory?
DR. BLAUSTEIN: It would have been part of a Mini-Mental status test that I would have done in our first session, where he would have trouble holding on to memory of things from five minutes ago. If I asked him to remember three words, he may have had difficulty - he would have had difficulty remembering those three words five minutes later after distracting him with other conversation.
MR. NADELHAFT: Okay. And then what does it say after that?
DR. BLAUSTEIN: "THC, marijuana, is part of issue," tetrahydrocannabinol, that's what THC stands for.
MR. NADELHAFT: So you saw THC as an issue with Mr. Depp's memory and attention; is that right?
DR. BLAUSTEIN: Well, with the transitional memory at least, yes, and perhaps the attention. MSE, mental status examination. "More was, perhaps that's what that's referring to.
MR. NADELHAFT: So Mr. Depp was off on --
DR. BLAUSTEIN: Whatever date it was.
MR. NADELHAFT: The date. 145 I And to the next page, Blaustein 17. Says, "JD" at the top, and then 11/10/14.
MR. NADELHAFT: Do you see that?
DR. BLAUSTEIN: Yep. I have that.
MR. NADELHAFT: Okay. And Mr. Depp came in to see you on 11/10/14?
DR. BLAUSTEIN: Correct
MR. NADELHAFT: Okay. And what's the first line say.
DR. BLAUSTEIN: "Some clouding, probably secondary to THC."
MR. NADELHAFT: What do you mean by "clouding"?
DR. BLAUSTEIN: Well, it would have been something in confusion or something about his mental state or less sharp, less alert, perhaps.
MR. NADELHAFT: What's the next line say?
DR. BLAUSTEIN: It says "No evidence of mania/hypomania."
MR. NADELHAFT: What do you mean by that?
DR. BLAUSTEIN: I didn't see in his presentation any evidence of mania or hypomania.
MR. NADELHAFT: Okay. Next line.
DR. BLAUSTEIN: "Discussion about relationships, core issues of trust. Amber says context" - contact. I don't know.
MR. NADELHAFT: Okay.
DR. BLAUSTEIN: "Fruitless meeting with her therapist."
MR. NADELHAFT: Did you ever observe Mr. Depp with mania or hypomania in any of your other sessions?
DR. BLAUSTEIN: Not that I recall.
MR. NADELHAFT: At 10/24/14, Mr. Depp came in for another individual session, correct?
DR. BLAUSTEIN: 11/24/14.
MR. NADELHAFT: The first line said "15 minutes late."
DR. BLAUSTEIN: 15 minutes late. Clear, relationship it stabilizing. Looking at jealous parts of him
MR. NADELHAFT: What do you mean by that, "looking at jealous parts of him"?
DR. BLAUSTEIN: Things that make him jealous or what his role might be in jealousy.
MR. NADELHAFT: And what made Mr. Depp jealous?
DR. BLAUSTEIN: Well, about what was happening there, but with Amber I don't know. I can't recall.
DR. BLAUSTEIN: Let's see my next notes, there was a triggering point. In my next note there's a triggering point, early breakup at 22, where an actress cheated with a leading man.
MR. NADELHAFT: So was Mr. Depp jealous of Amber being with other men?
DR. BLAUSTEIN: I don't remember that specifically.
MR. NADELHAFT: And turning to Blaustein 18, which looks like it starts at 12/7/14--
DR. BLAUSTEIN: Yeah.
MR. NADELHAFT: Mr. Depp came in for an individual session?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: And now it looks like you have "paranoia" in quotes.
DR. BLAUSTEIN: Would have been his word. What he meant by that, the elements were fear, envy, and vigilance.
MR. NADELHAFT: So Mr. Depp told you something about paranoia?
DR. BLAUSTEIN: Uh-huh. As he defined it.
MR. NADELHAFT: And his elements of paranoia were fear, envy, and vigilance, as he told you?
DR. BLAUSTEIN: Yeah.
MR. NADELHAFT: Then what's the next day, 12/18/14?
DR. BLAUSTEIN: Well, let's see. 12/18/14, yes.
MR. NADELHAFT: And Mr. Depp came in for a session?
DR. BLAUSTEIN: Uh-huh - yes. "Patient working so psychotherapy on the phone." It's possible it was a phone session that I didn't mark as a phone session.
DR. BLAUSTEIN: "Big fight with girlfriend yesterday. Struggling with how to separate. Let her tell you her feelings. Relationship needs to take care of you. Her to go to a safe zone, withdraw. Different than childhood experiences."
MR. NADELHAFT: Then it says 1/6/15, correct?
DR. BLAUSTEIN: Correct.
MR. NADELHAFT: And what do these notes say?
DR. BLAUSTEIN: "Patient late 20 minutes. Positive hypnotherapy session. The goal is to make a beeline to bed. Using a relationship to take care of the individuals." Let's see. "Not logical approach to Amber's work. Take care of emotions. Sobriety continuing."
MR. NADELHAFT: And then Blaustein 20. Move down to the last page.
MR. NADELHAFT: This is for 1/8/15, just to be clear.
DR. BLAUSTEIN: 1/8/15, correct. Is "22 minutes late. Vulnerability. Woman in studio who admired Amber. Threat."
MR. NADELHAFT: What's that mean? What do you I understand that to mean?
DR. BLAUSTEIN: That probably related to the prior question. There's a woman who admired her that he felt jealous of. Let's see. The next thing is something of vulnerability. "Instance of the vulnerability. And internal feel, parallel to vulnerability and then childhood inability. Free or fight only way."
MR. NADELHAFT: What's that mean? "Free or fight only way"?
DR. BLAUSTEIN: Free or fight -- or free and fight the only way. And my understanding of that is be free of the relationship or fight for it. And positive relatedness with Amber through dash vulnerability.
MR. NADELHAFT: Did -- and 1/8/15 was the last time you saw or spoke to Mr. Depp as a patient, correct?
DR. BLAUSTEIN: I believe that's true.
MR. NADELHAFT: Did Mr. Depp describe to you at all how his jealousy would present itself, whether he was jealous of a man or a woman, in relation to Amber?
DR. BLAUSTEIN: It could make him angry or make him feel insecure.