Brandon Patterson — Direct/Cross
1,181 linesTHE COURT: Thank you.
THE COURT: All right. So ladies and gentlemen, we'll go ahead and take our afternoon lunch. We'll give you until 2:30 to take care of lunch. Again, no outside information, and please don't discuss this case, okay? All right. Thank you. Have a good lunch.
THE COURT: All right. So we'll come back at 2:30, then; is that correct?
MS. LECAROZ: Thank you.
COURT BAILIFF: All rise.
COURT BAILIFF: (Recess taken from 1:19 p.m to 2:30 p.m) All rise. Please be seated and come to order.
THE COURT: All right. Are we ready for the jury?
MS. VASQUEZ: Your Honor, if I may.
THE COURT: Sure.
MS. VASQUEZ: First, we are going to be calling Brandon Patterson by video deposition designations at this point.
THE COURT: Oh, okay.
MS. VASQUEZ: And I just wanted to alert the court how we've handled the exhibits amongst the parties; we've met and conferred. The parties have agreed that we have no objections to the Eastern Columbia Building surveillance videos that have been authenticated by Mr. Brandon Patterson in his deposition
THE COURT: Okay. What exhibit numbers are they? Or whose exhibit are they?
MS. VASQUEZ: Well, so we have no objection to all -- I think there's 87 currently. So for the interests of time for the jury and the Court and everyone here, because there are 87, we've agreed to show a selected smaller set which have been identified by both parties, and both parties are taking on the responsibility of introducing and playing each exhibit for the jury.
THE COURT: Okay.
MS. VASQUEZ: With Your Honor's permission.
MS. VASQUEZ: So since Mr. Depp is up now in his case-in-chief, we are going to be playing the video deposition of Mr. Patterson. We will pause the video, and then when one of Ms. Beard's exhibits comes up --
THE COURT: No, no. I'm sorry. The deposition, the person, just one time when that deposition, well, just testimony is once.
MS. BREDEHOFT: We understand that, Your Honor.
THE COURT: Then you're going to pause right now, and then you're going to do it? I'm just confused.
MS. VASQUEZ: I'm sorry, Your Honor. Let me be a little more clear. We're going to pause the video deposition of Mr. Patterson.
THE COURT: Okay.
MS. VASQUEZ: To allow Ms. Beard's counsel to publish the exhibit, which is also a video, surveillance video, I know.
THE COURT: Okay. It's going to be a little difficult, okay.
MS. VASQUEZ: Right. So we ask that the Court perhaps remove the publishing from Mr. Depp's counsel table and allow Ms. Beard's counsel to publish that exhibit, which is a surveillance video, and play that.
THE COURT: Okay. We can do that.
MS. VASQUEZ: Each side has taken responsibility of the clips that they would like to play.
THE COURT: How many times is this going to happen?
MS. VASQUEZ: How many do you have?
MR. NADELHAFT: We have six, Your Honor, and there's six clips which probably the longest is less than 2 minutes long.
THE COURT: Okay.
MR. NADELHAFT: And they have 10. And again they're all relatively short. What happened in the deposition was that the witness saw the video and then testified to it.
THE COURT: So you'll pause it. When the witness is watching the video, we're going to watch the video.
MR. NADELHAFT: Correct, Your Honor.
THE COURT: Okay. All right. And how long is this video?
MS. VASQUEZ: I believe the entire deposition is about an hour --
MR. NADELHAFT: An hour and 48 minutes.
MS. VASQUEZ: One hour and 48 minutes.
THE COURT: One hour 48 minutes, okay.
MS. VASQUEZ: And with the exhibits, I anticipate it might take us till the end of the day . No promises.
THE COURT: That's fine. I still need the exhibit numbers.
MR. NADELHAFT: I can give you, Your Honor.
MS. VASQUEZ: Would you like to read them?
MR. NADELHAFT: I can read them?
THE COURT: That's fine. If you would precursor with whose exhibit it is so -- I have two lists, so I just want to make sure I get it.
MR. NADELHAFT: Sure. All right. So I'll give you ours.
THE COURT: Okay.
MR. NADELHAFT: It would be 670.
MR. NADELHAFT: 671,672,673 -- I'm sorry, I'm going out of order here now -- 666.
THE COURT: That's okay. 666.
THE COURT: Okay.
MR. NADELHAFT: 685,686,687,688, 668,690,691,692,693,669,694,695,696, 729, 743, 745, 746, 744, 750, 751, 752, 753, 755, 780G, 780R, 780X, 789A, 789B, 789G, 789H, 789L, 789N, 789R, 974.
MR. NADELHAFT: And I believe we had 1041, which I think was what actually came in from your, today, the plans for the ECB. I think that's the same thing, but it was 1041. I'm not sure if you're objecting to that.
MS. VASQUEZ: No.
MR. NADELHAFT: No. So 1041.
THE COURT: Okay. All right. So you're entering all of those into evidence, there's no objection, correct?
MS. VASQUEZ: Your Honor, I want to confirm one thing with counsel.
MR. NADELHAFT: Sure.
MS. VASQUEZ: May I confer with him?
THE COURT: Go ahead.
MS. VASQUEZ: As long as they're all Eastern Columbia surveillance videos, Your Honor, we have no objections.
MR. NADELHAFT: Which they are.
THE COURT: Which they are? So they're all entered into evidence.
MR. NADELHAFT: Except for the plan, which was the one I just talked about, yes.
THE COURT: Okay. So those are all entered into evidence then.
THE COURT: All right. And yes, ma'am, yours.
MS. VASQUEZ: And, Your Honor, just to short-circuit this for the Court, our Eastern Columbia surveillance video are Exhibits Numbers 250 through 336.
THE COURT: All right. So Exhibits 250 through 336?
MS. VASQUEZ: That's correct.
THE COURT: No objection to those exhibits, correct?
MR. NADELHAFT: Assuming they are all the Eastern Columbia Building, no objection.
MS. VASQUEZ: Yes.
THE COURT: Okay. So Plaintiffs Exhibit 250 through 336 are entered into evidence.
MS. VASQUEZ: Thank you, Your Honor. Would Your Honor like to know the ten exhibits that we are going to be playing for the jury?
THE COURT: No, that's okay. They're all in evidence. That's all I needed to know. We don't need to pull them up. You're going to handle that.
MS. BREDEHOFT: Your Honor, the only thing about this is there's going to be duplicates. I don't know whether we want to try to sort that through.
THE COURT: They're in evidence. Not going to unring that bell.
THE COURT: Okay. Could you put the big TV up, though, before we get the jury back in, just because it's going to be a deposition with testimony, we're going to go ahead and put the big TV up, if it works.
MR. NADELHAFT: Your Honor. I thought the deposition --
THE COURT: Could you speak a little louder?
MR. NADELHAFT: I thought the deposition video came through the other screen.
THE COURT: Think it comes from here too.
MR. NADELHAFT: Oh, it does? Okay.
THE COURT: When you have a remote witness, the remote witness will stay up there. And then you can use those screens as well, but when you're using deposition, we can see it over O here. We'll just publish it to the big screen. If you want to set up just before the jury comes out, just to make sure you have the person, let's just make sure it's all working before we get the jury.
THE COURT: All right. Seems like it's all working. That's fine. Are we ready for the jury then?
MR. NADELHAFT: Yes, Your Honor.
MS. VASQUEZ: Yes, Your Honor.
THE COURT: Okay. All right. Thank you, ladies and gentlemen.
THE COURT: Your next witness.
MS. VASQUEZ: Thank you, Your Honor. Plaintiff calls Brandon Patterson. He is the corporate designee of the Eastern Columbia Building by deposition designations.
THE COURT: All right. Patterson.
THE COURT: Ladies and gentlemen, this is the first one that we have of a few where they already have been deposed, and so you're going to see them on a recording, okay.
THE COURT: No volume.
THE COURT: Do you have an audio connection attached? Try it one more time. Can you push play one more time.
MS. STEMLAND: If you could, please state your name and address for the record
BRANDON PATTERSON: Sure. Brandon Patterson, 849 South Broadway, Los Angeles, California 90014.
MS. STEMLAND: And if you could, please state your occupation.
BRANDON PATTERSON: General manager.
MS. STEMLAND: For what?
BRANDON PATTERSON: I'm the general manager for the Eastern Columbia HOA in Los Angeles.
MS. STEMLAND: And how long have you been in that position?
BRANDON PATTERSON: I've been here at the building six years.
MS. STEMLAND: Were you there in 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And are you here under a subpoena as the corporate designee for Action Property Management?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Okay. And if you could please pull up Exhibit 1 and just scroll to page 15 of the PDF, please, does this look like a copy of the subpoena that you received?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Is it okay if I call your building "ECB"?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Is it your understanding that ECB has produced these three categories of documents and films?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Please go to Exhibit 2 and scroll to page 8. And does this look like the topics of the deposition of the subpoena for testimony?
BRANDON PATTERSON: Okay.
MS. STEMLAND: Is it your understanding that you're the most knowledgeable person on these topics?
BRANDON PATTERSON: I am the most knowledgeable within Action Property Management as it relates to these 16 items.
MS. STEMLAND: Are you responsible for managing any of the records or managing, preserving any of the records and videos at Action Property Management?
BRANDON PATTERSON: Specifically as it relates to Eastern Columbia, this is the only property and building for Action that I manage. So Action as a whole, I can't speak to that But as for ECB, yes.
MS. STEMLAND: Thanks. And this whole deposition, I'll be just referring to ECB related to Action Property Management.
MS. STEMLAND: What was your role in locating the videos responsive to the subpoena?
BRANDON PATTERSON: The videos had been saved from the original case. I don't recall the exact year that was. I think this is number 4 now. So I provided the video that was requested that had been saved as the only videos that were requested and saved.
MS. STEMLAND: And who saved them? Was that you or someone at Action Property Management?
BRANDON PATTERSON: I had initially worked on saving them when I received the first lists. I guess I'm - I don't know if you're referring to the first set of videos that was ever requested or subsequent subpoenas, I guess, since this refers to, that were already saved and I just transferred the already-saved documents.
MS. STEMLAND: So we'll get into more details.
MS. STEMLAND: But when was the first time you saved security footage relating to ECB in response to a subpoena?
BRANDON PATTERSON: Like I said, I don't recall the exact year. It was the first case between Depp and Heard, as a response to subpoenas that we had received from both parties.
MS. STEMLAND: And what was your role in preserving those videos from that first time until now?
BRANDON PATTERSON: Can you expand on what you mean by "preserving"?
MS. STEMLAND: Sure. Were these videos kept securely in the same format at --
BRANDON PATTERSON: Yes.
MS. STEMLAND: ECB.
MS. STEMLAND: And were you responsible for making sure they were kept securely in the same format at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: How many cameras are there at ECB in 2016?
BRANDON PATTERSON: I don't recall the exact number. We've since switched out the entire system and expanded on it. I believe we doubled the cameras, which we currently have 44. So I would be speculating, but I think it's probably around 20, 22 or so, originally.
MS. STEMLAND: Where in 2016 were the cameras positioned?
BRANDON PATTERSON: Throughout the common areas.
MS. STEMLAND: And did ECB tape them as a matter of course sort of all day, 24 hours a day?
BRANDON PATTERSON: The recordings were 24/7. The concierge staff periodically does review them, just as part of their daily duties. But the video footage is recorded onto a DVR in a - back then I believe it was like a 20-day period before it was written over.
MS. STEMLAND: Is it correct that you're not represented by an attorney?
BRANDON PATTERSON: I am not.
MS. STEMLAND: Did you review any documents or videos before the deposition?
BRANDON PATTERSON: I did not.
MS. STEMLAND: Have you ever communicated with Mr. Depp's former attorney, Mr. Waldman?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And did Mr. Waldman, do you know if he drafted the declaration for you in 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Is Action Property Management -- I believe you said this earlier. Is it the property management company for ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Is it your understanding that in 2016, Depp owned the top-floor penthouses in ECB, penthouses 1 through 5?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And are you aware of whether Amber Heard was a resident at ECB in 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: How many times have you seen Amber Heard, personally?
BRANDON PATTERSON: Maybe - I mean, I would be guessing. My best guess would be maybe half a dozen to a dozen times.
MS. STEMLAND: Do you remember when those time$ were, like what year?
BRANDON PATTERSON: I don't recall the exact year, but, likely, 2016.
MS. STEMLAND: So moving to May 21st of 2016, are you aware that officers were called to the penthouse of ECB on that day?
BRANDON PATTERSON: Yes, I am aware.
MS. STEMLAND: Were you there the day that the officers were called to ECB in May of 2016?
BRANDON PATTERSON: I was not at the building when officers were called.
MS. STEMLAND: Do you have any firsthand knowledge of why the officers were called on May 21st, 2016?
BRANDON PATTERSON: Firsthand, no, I do not.
MS. STEMLAND: Did you see Amber at all on May 21st?
BRANDON PATTERSON: Not that I recall.
MS. STEMLAND: Did you see Amber on May 22nd, 2016?
BRANDON PATTERSON: Not that I recall.
MS. STEMLAND: Did you see Amber on May 23rd, 2016?
BRANDON PATTERSON: The timeline is 2016. I don't recall the specifics of those dates specifically.
MS. STEMLAND: Can you say -- can you testify as to whether you talked to Amber Heard at all the week of May 21st, 2016, personally?
BRANDON PATTERSON: I don't recall the dates, no.
MS. STEMLAND: Did you personally interact with Mr. Depp at ECB in 2016?
BRANDON PATTERSON: No, I never did.
MS. STEMLAND: Have you seen Mr. Depp on video footage in 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Could you please bring up exhibit 3, please?
MS. STEMLAND: How would you describe Mr. Depp's behavior in that video?
BRANDON PATTERSON: I would describe it as animated.
MS. STEMLAND: And do you have any -- in the times that you've seen Mr. Depp at ECB, did you ever observe Mr. Depp in an animated manner like you saw in the video?
BRANDON PATTERSON: I do recall a video of Mr. Depp in the elevator, I guess, in an animated state.
MS. STEMLAND: And was that in 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you have any familiarity with -- have you seen Mr. Depp appear angry in the times you've seen him at ECB?
BRANDON PATTERSON: I wouldn't say I angry. I would use the term I animated.
MS. STEMLAND: And what does the tenn "animated" man to you?
BRANDON PATTERSON: What I saw on the video.
MS. STEMLAND: Mr. Patterson, when were you first contacted for video footage after the May 21st police call to the building?
BRANDON PATTERSON: I don't recall the exact time frame.
MS. STEMLAND: Do you remember who contacted you about the May 2016 video footage, who first contacted you?
BRANDON PATTERSON: I do not recall.
MS. STEMLAND: Do you know who selected what copy to preserve and what copies -- what to preserve?
BRANDON PATTERSON: The attorneys from both sides submitted a list of video times and dates to be preserved.
MS. STEMLAND: And do you remember what times and dates those were, roughly?
BRANDON PATTERSON: I don't have a time frame, no.
MS. STEMLAND: Do you have a rough time frame of what the videos that were preserved, what times those covered?
BRANDON PATTERSON: My rough recollection is that 1'fay 2016 time frame.
MS. STEMLAND: Was it after the May 21st incident, that time frame?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you know what role Mr. Depp's lawyers played in the selection process?
BRANDON PATTERSON: The attorneys came to the office here, set up a viewing area, reviewed video footage, took notes based on that review, and those dates and times were provided to retrieve the video saved.
MS. STEMLAND: Do you remember which attorneys came, either their names or who they were, that came to view the footage?
BRANDON PATTERSON: I don't recall. There's attorneys from both sides that came very close together, and I don't recall who or what side they were on.
MS. STEMLAND: And was all of the footage that they selected preserved?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And were all of those videos that were preserved and taken in the ordinary course of ECB's business operations?
BRANDON PATTERSON: Can you rephrase that?
MS. STEMLAND: Sure. It's ordinary, is it not, for ECB to have these cameras rolling and the videos that were preserved were from those cameras that were rolling in the ordinary course of business?
BRANDON PATTERSON: Yes, correct.
MS. STEMLAND: And do you know how many video clips ECB preserved pursuant to the requests from attorneys?
BRANDON PATTERSON: I don't recall the exact number. It was whatever was on the subpoena. We provided exactly what is on there.
MS. STEMLAND: Does the number 87 ring a bell?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you know where the videos were maintained from 2016 until today?
BRANDON PATTERSON: They were on a portable drive here in my office.
MS. STEMLAND: At ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And how are they maintained?
BRANDON PATTERSON: It was on a portable hard drive.
MS. STEMLAND: And as far as you know, is that in the same condition that it was in 2016?
BRANDON PATTERSON: To my knowledge, yes.
MS. STEMLAND: And were the 87 videos preserved on three DVD disks or in some other format?
BRANDON PATTERSON: So through the subpoenas, the videos were provided to the different teams. I vaguely remember DVDs. They weren't stored on DVDs for purposes here. I just have them on a portable hard drive.
MS. STEMLAND: Is there any other video footage other than those 87 clips that has been preserved?
MS. STEMLAND: And what happened to any other video footage that was not preserved?
BRANDON PATTERSON: Like I mentioned earlier, the DVR has a capacity of so many days, and it rewrites over itself.
MS. STEMLAND: And just for clarity, I just want to make it clear, how did you decide what May 2016 videos to preserve?
BRANDON PATTERSON: The only videos that were preserved was the ones called out via the subpoena by the various law firms, or the two law firms.
MS. STEMLAND: And do you know why there's no footage from May 23rd, 2016?
BRANDON PATTERSON: I do not know.
MS. STEMLAND: And you mentioned that both sides requested preservation of the video footage; is that right?
BRANDON PATTERSON: Yes, correct.
MS. STEMLAND: Is it your understanding that the press, at some point, became interested in getting statements from ECB relating to the May 21st incident?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Did the press ask ECB or its employees for statements?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And what's the policy of APM or ECB with respect to press statements about residents?
BRANDON PATTERSON: The policy is that we do not give statements to press.
MS. STEMLAND: And did Amber ever ask you about that?
BRANDON PATTERSON: Yes, she did.
MS. STEMLAND: In 2016, do you know if Rocky Pennington and Josh Drew lived in one of the penthouses at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And did you ever see Rocky with Amber?
BRANDON PATTERSON: Yes.
MS. STEMLAND: If we could pull up Exhibit 4, please.
MS. STEMLAND: Mr. Patterson, does this refresh your recollection about which penthouse Rocky Pennington lived in?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Mr. Patterson, I'd like to go to the video footage now and go through some video footage.
MS. STEMLAND: And let's start with Exhibit 5, please, in particular, around time stamp 18:55:19.
MR. NADELHAFT: Now, Your Honor, I think we need to switch it so I can show ...
THE COURT: Okay. All right. We can do that.
MR. NADELHAFT: Now if you'll go back to the deposition.
THE COURT: Okay.
MS. STEMLAND: Mr. Patterson, do you recognize this area?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And where is it?
BRANDON PATTERSON: This is the mezzanine vestibule between the building and the garage.
MS. STEMLAND: Do you know if you or someone else at ECB was responsible for pulling this security footage and keeping it at ECB?
BRANDON PATTERSON: I did pull some video early on; however, the task was very overwhelming and took away from my daily duties, so the task was sent off to an outside party to pull all the videos based on the subpoena lists.
MS. STEMLAND: And what was that outside party's name?
BRANDON PATTERSON: I don't recall offhand.
MS. STEMLAND: But was it at the direction of you or ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: To assist you with time or -- is that why?
BRANDON PATTERSON: Yes. I did not have the time to go through all of the video footage to record it.
MS. STEMLAND: Sir, do the ECB video cameras have time and date stamps as a matter of course?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And in your experience. Are those time and date stamps relatively accurate?
BRANDON PATTERSON: Relatively accurate, yes.
MS. STEMLAND: And did you recognize the men in that exhibit?
BRANDON PATTERSON: Can you replay it, please?
MS. STEMLAND: Sure. And while we're waiting for the men to appear, how would you describe the quality of these videos?
BRANDON PATTERSON: Compared to our new, updated cameras, not as clear.
MS. STEMLAND: And can you be more specific about not clear?
MS. STEMLAND: Would you consider these to be grainy?
BRANDON PATTERSON: I would say this video here in the paused state does appear to be semi-grainy.
MS. STEMLAND: And does it appear to be just a little bit blurry?
BRANDON PATTERSON: Yes. This video, as I see it now, looks a little blurry.
MS. STEMLAND: And did you recognize the men in thus video clip?
BRANDON PATTERSON: Yes. I do recognize Mr. Depp. The first gentleman looks familiar; I can't place him at the moment.
MS. STEMLAND: And do you have any reason to believe that the date and time stamp are not accurate?
BRANDON PATTERSON: It does seem consistent with the time stamping of the video, so unless it was somehow altered, I would say it appears to be accurate.
MS. STEMLAND: And the video camera that you preserved in your office at EC1;3 since 2016 has not been altered; is that correct?
BRANDON PATTERSON: Correct.
MS. STEMLAND: Let's move to exhibit 6, please.
MS. STEMLAND: Do you recognize where this is?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And where is it?
BRANDON PATTERSON: This is the mezzanine level again, vestibule. The mail room is directly behind it leading to the elevator vestibule.
MS. STEMLAND: And does that look like it accurately portrays the scene?
BRANDON PATTERSON: A This shot accurately depicts the area, correct.
MS. STEMLAND: And do you recognize those men?
BRANDON PATTERSON: As I previously stated, I do recognize Mr. Depp. The other ones, I do not
MS. STEMLAND: And do the date and time stamp look accurate?
BRANDON PATTERSON: Yes.
MS. STEMLAND: If we could please go to exhibit 7.
MR. NADELHAFT: Okay. It's going to have to be switched on our side.
THE COURT: All right. Thank you.
MR. NADELHAFT: Thank you, Your Honor.
THE COURT: Yes, sir.
THE COURT: We have to switch back? Okay.
MR. NADELHAFT: Switch back.
THE COURT: Thank you, Your Honor.
MS. STEMLAND: And do you recognize where this is, Mr. Patterson?
BRANDON PATTERSON: Yes, I do.
MS. STEMLAND: Okay. And does that look like a clip from the surveillance video in the elevator at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does it accurately portray the scene?
BRANDON PATTERSON: I don't know what you mean by I scene.
MS. STEMLAND: Does it look like ECB, like the elevator at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And is the quality of this a little bit grainy as well?
BRANDON PATTERSON: As it's displayed right now, yes.
MS. STEMLAND: And do the date and time stamp look accurate like ECB keeps in the regular course of business?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And could we please play the video so we can see who's getting on?
MS. STEMLAND: And do you recognize those people getting on the elevator, Mr. Patterson?
BRANDON PATTERSON: Yes, I do recognize Mr. Depp.
MS. STEMLAND: And is smoking permitted on elevators at ECB?
BRANDON PATTERSON: No, it's not.
MS. STEMLAND: Let's move to exhibit 8, please.
MS. STEMLAND: Do you recognize this as ECB video I footage?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you recognize the men on the elevator?
BRANDON PATTERSON: As I previously mentioned, Mr. Depp only.
MS. STEMLAND: And do those date and time stamps look accurate?
BRANDON PATTERSON: Yes.
MS. STEMLAND: How would you describe Mr. Depp's movements on this elevator?
BRANDON PATTERSON: I'll use the description "animated" again.
MS. STEMLAND: Isn't he also swaying from side to side?
MS. STEMLAND: Does this footage generally look like the footage that you preserved from 2016?
BRANDON PATTERSON: Yes.
THE COURT: Okay. Switch it.
MR. NADELHAFT: Thank you.
THE COURT: Uh-huh.
MS. STEMLAND: And do you recognize this area?
BRANDON PATTERSON: Yes.
MS. STEMLAND: What is it?
BRANDON PATTERSON: This is the same shot that was previously shown, the mezzanine vestibule.
MS. STEMLAND: And is it shot from one of the ECB surveillance cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this look like one of the ones that was preserved since in 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do the date and time stamps look accurate, as far as you know?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And were you responsible for pulling this security footage, generally?
BRANDON PATTERSON: Generally, yes.
MS. STEMLAND: And do you recognize the people in that video?
BRANDON PATTERSON: Excuse me. I do recognize Mr. Depp.
MS. STEMLAND: And what's Mr. Depp holding?
BRANDON PATTERSON: Appears to be a jacket.
MS. STEMLAND: And how would you describe how he's holding it?
BRANDON PATTERSON: With his left hand.
MS. STEMLAND: And if we could please move to Exhibit 11.
MS. STEMLAND: And do you recognize this as ECB surveillance footage?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And where was that footage taken?
BRANDON PATTERSON: This is back in the mezzanine vestibule between the building and the garage.
BRANDON PATTERSON: MALE SPEAKER: That last part, vestibule what?
BRANDON PATTERSON: Between the building and the garage.
MS. STEMLAND: And is this one of the videos that was preserved back in 2016 by ECB?
BRANDON PATTERSON: I don't recall the specific clip, but, yes, this is video that was preserved.
MS. STEMLAND: And do the date and time stamp look accurate, like they would be on ECB footage?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Do you recognize those people?
BRANDON PATTERSON: I recognize Mr. Depp.
MS. STEMLAND: And does Mr. Depp appear to be leaving the building?
BRANDON PATTERSON: That would be the pathway from the building into the garage.
MS. STEMLAND: Does this look like true and accurate video surveillance preserved in 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Moving right along to exhibit 12, please.
MS. STEMLAND: And where is this video, Mr. Patterson?
BRANDON PATTERSON: This video is the call box at the lobby entrance on Broadway.
MS. STEMLAND: Do you recognize it as footage from one of the ECB surveillance cameras that's been preserved since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does the date and time stamp look accurate to you?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Move to exhibit 13, please.
MS. STEMLAND: BY MS. STEMLAND:
MS. STEMLAND: Where this is?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Where?
BRANDON PATTERSON: This is in the main lobby of the building.
MS. STEMLAND: And does that look like a surveillance clip from one of ECB's surveillance cameras that's been preserved since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And it says May 21st, 2016 at 20:53. Does that look like an accurate date and time stamp from the ECB footage?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And that looks like a true and accurate copy of the surveillance that's been preserved?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Moving to Exhibit 14, please.
MS. STEMLAND: Do you recognize this clip?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does it look like it's from one of ECB's security footage cameras that's been preserved since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And where was this footage taken?
BRANDON PATTERSON: This is the shot of the front desk.
MS. STEMLAND: And would you agree that the footage is also a little bit grainy?
BRANDON PATTERSON: As it is displayed now, yes.
MS. STEMLAND: And do the date and time stamps look accurate to you?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you recognize this as surveillance footage from one of the ECB cameras that's been preserved since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Do you recognize either of the officers?
BRANDON PATTERSON: I recognize them as officers.
MS. STEMLAND: And does the date and time stamp look I accurate, as far as you know?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Move to Exhibit 16, please.
MS. STEMLAND: Does this also appear to be an ECB surveillance camera footage?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you recognize that person who just left the elevator?
BRANDON PATTERSON: I do not.
MS. STEMLAND: And does this generally appear to be one of the ones that have been preserved since 2016 at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, does the date and time stamp look accurate?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And for all of these clips that you've seen, do they appear to you to be true and accurate copies of the footage that have been preserved?
BRANDON PATTERSON: These seem very grainy and slow to me from what I remember. But these are taken from Eastern Columbia video cameras during this time.
MS. STEMLAND: And preserved since that time at ECB?
BRANDON PATTERSON: Correct.
MS. STEMLAND: And they were preserved in the same condition?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Could we please pull up Exhibit 17.
MS. STEMLAND: And do you recognize this as a clip from one of the ECB surveillance cameras that's been preserved since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time, stamp accurate?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does that accurately portray the elevator scene at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Can we move to Exhibit 18, please.
MS. STEMLAND: Do you recognize this as ECB security footage that's been preserved at ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And it looks like an accurate copy of what was preserved as far as know?
BRANDON PATTERSON: As far as I know, yes.
MS. STEMLAND: And the date and time stamp, as far as you know, look accurate?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Please move to exhibit 19.
MS. STEMLAND: And, Mr. Patterson, do you know whether or not any of these time stamps are a few seconds off here or there or not?
BRANDON PATTERSON: I believe there is a few-second time discrepancy.
MS. STEMLAND: And do you know why there would be a few-second time discrepancy or ...
BRANDON PATTERSON: I don't know the reason behind it, no.
MS. STEMLAND: Okay. And do you recognize that video clip as one of the videos that have been preserved at ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does that appear to be an accurate copy of one of the surveillance copies that have been preserved?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, the date and time stamp is reasonably accurate, you know, with a couple-seconds margin?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Please move to Exhibit 20.
MS. STEMLAND: And you recognize this as one of the videos that have been taken at ECB, or by a surveillance camera at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And are these one of the videos that have been preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, within a few seconds, is the date and time stamp accurate?
BRANDON PATTERSON: As far as I know, yes.
MS. STEMLAND: And those appear to be two officers leaving the -- leaving ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And move to exhibit 21, please.
MS. STEMLAND: Do you recognize where this is?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And what does it look like to you?
BRANDON PATTERSON: This is the same shot from the kiosk camera also in the lobby on Broadway.
MS. STEMLAND: Is it shot from one of the surveillance cameras at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does that appear to be one of the clips that have been preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate as far as you know?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Exhibit 22, can we move to that, please.
MS. STEMLAND: And does this appear to be, this clip appear to be taken with one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And which camera?
BRANDON PATTERSON: This is the lobby - well, one of the lobby cameras.
MS. STEMLAND: And does this appear to be one of the clips that was preserved at ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate?
BRANDON PATTERSON: Yes, within a few seconds.
MS. STEMLAND: And were those two officers walking in, in this video?
BRANDON PATTERSON: Yes, those appear to be two officers.
MS. STEMLAND: Does this look like how the lobby -- does it look like how the lobby looks in the video surveillance preserved by ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Let's move to exhibit 23.
MS. STEMLAND: Do you recognize this as video footage taken from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this appear to be one of the clips that's been preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, are the date and time stamps accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do those appear to be officers talking to the concierge?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Move to Exhibit 24, please.
MS. STEMLAND: And do you recognize this as video footage taken by one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Was this one of the clips that were taken by ECB and preserved since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, within a few seconds, are the date and time stamps accurate?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Can we please go to Exhibit 27.
MS. STEMLAND: And do you recognize this?
MS. STEMLAND: It's one of the videos from the ECB security footage that have been preserved since 2016 by ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: As far as you know, is the date and time stamp accurate within a few seconds?
MS. STEMLAND: All right. Move to exhibit 28 please.
MS. STEMLAND: Do you,recognize this video as one of the ECB surveillance videos?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And which surveillance video? Which part of the building?
BRANDON PATTERSON: This is the lobby.
MS. STEMLAND: Does this appear to be one of the clips that has been taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, are the date and time stamps accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do those look like two officers in the lobby to you?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Move to 29.
MS. STEMLAND: Do you recognize this video as taken from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And was this one of the clips that have been taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And this appears to be an accurate copy of what was preserved?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And move to Exhibit 30, please.
MS. STEMLAND: And do you recognize this as footage taken from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this appear to be one of the clips that have been taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And that appears to be an accurate copy of what was preserved?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: May we please go to Exhibit 30 [sic].
MS. STEMLAND: And do you recognize this as one of the video clips from ECB video surveillance?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And is this the elevator camera?
BRANDON PATTERSON: One of, yes.
MS. STEMLAND: And do you recognize who's on the elevator?
BRANDON PATTERSON: It appears to be Amber.
MS. STEMLAND: And does this look like one of the video clips that have been taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, within a few seconds, is the date and time stamp accurate?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Can we please move to exhibit 30 -- 31.
MS. STEMLAND: And does this appear to be one of the video clips taken from the ECB security footage?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this appear to be one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, are the date and time stamps accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: While we're waiting for someone to appear, do you recognize the person at the front desk if you can see him? And do you recognize who's walking into the video now?
BRANDON PATTERSON: I do recognize that as Amber. I'm trying to get a facial recognition of the person at the desk.
MS. STEMLAND: Can you see him now?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And who is that?
BRANDON PATTERSON: His name's Cornelius.
MS. STEMLAND: Do you know why Mr. Harold and Amber would be going around that comer?
BRANDON PATTERSON: The package room is around the corner.
MS. STEMLAND: And does this look like one of the video clips that's been preserved and taken by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does the date and time stamp look accurate within a few seconds as far as you know?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this like look an accurate clip from the ECB footage?
BRANDON PATTERSON: Yes.
MS. STEMLAND: I'd like to move this in as exhibit 31 and move to Exhibit 32, please.
MS. STEMLAND: And do you recognize who's walking through the picture in this video?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Who is it?
BRANDON PATTERSON: Amber Heard
MS. STEMLAND: And does this look like a video clip taken from one of the ECB surveillance cameras?
MS. STEMLAND: A' Yes.
MS. STEMLAND: And does this look like one of the videos that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, are the date and time stamps accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: I would like to move to Exhibit 33, please.
MS. STEMLAND: And does this look like video footage taken from one of the ECB surveillance cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this look like one of the clips taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, are the date and time stamps accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: I would like to move to admit this as Exhibit 33.
MS. STEMLAND: And do you recognize who's in this video right now?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Who is it?
BRANDON PATTERSON: Amber Heard. --
MS. STEMLAND: And where is she?
BRANDON PATTERSON: This is the service corridor outside of the package room.
MS. STEMLAND: Okay. And if we could, please rewind the tape a little bit and see who Amber was with.
MS. STEMLAND: Do you recognize that person?
BRANDON PATTERSON: Yes. That's Cornelius.
MS. STEMLAND: And what's his last name?
BRANDON PATTERSON: Howell? Harrell?
MS. STEMLAND: And was he walking out -- where was he walking out from?
BRANDON PATTERSON: The package room.
MS. STEMLAND: Where is this in ECB?
BRANDON PATTERSON: This is on the main level service corridor.
MS. STEMLAND: And would you agree with me that this footage is also a little bit grainy?
BRANDON PATTERSON: Yes.
MS. STEMLAND: If we could, please, I would like to move to admit Exhibit 33. If we could, please move to Exhibit 34.
MS. STEMLAND: And do you recognize this as one of the ECB security camera footage clips?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this appear to be one of the video footage clips taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: As far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you recognize who's in this video?
BRANDON PATTERSON: It appears to be Amber Heard.
MS. STEMLAND: And do you know where this video is?
BRANDON PATTERSON: Can you expand on that?
MS. STEMLAND: Sure. Is it in an elevator at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And can we go back to that exhibit, please, just for a minute. And could we go to roughly time stamp 18:22:26.
MS. STEMLAND: Would you agree with me that the video footage here is a little bit grainy?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does it look a little bit fuzzy to you?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And can we please move to Exhibit 35.
MS. STEMLAND: And does this like video footage from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does it appear to be one of the clips that was taken and preserved by ECB in 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, are the time stamps accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: If we could please move the time stamp to 18:41:29.
MS. STEMLAND: And do you recognize who just walked in the elevator?
BRANDON PATTERSON: It appears to be Amber. I'm not sure who the gentleman is.
MS. STEMLAND: Does that video appear a little bit grainy to you?
BRANDON PATTERSON: As its displayed now.
MS. STEMLAND: And if we could, please move to Exhibit -- I think we're on 36.
MS. STEMLAND: And does this appear to be footage from one of the security cameras at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And who just walked through the footage?
BRANDON PATTERSON: Amber Heard and a gentleman.
MS. STEMLAND: And does this appear to be one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: As far as you know, is the date stamp and time reasonably accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And would you agree with me that also is a little bit grainy in that footage?
BRANDON PATTERSON: Yes, as it is displayed now.
MS. STEMLAND: And if we could, please move to Exhibit 37.
MS. STEMLAND: And does this appear to be a video camera from one of the ECB's video cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this appear to be one of the clips that was taken: and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you recognize who walked through the video?
BRANDON PATTERSON: Amber Heard and a unknown gentleman.
MS. STEMLAND: And is this video also a little bit grainy as it appears?
BRANDON PATTERSON: As it appears now, yes.
MS. STEMLAND: I would like to move in exhibit 37. And please move to Exhibit 38.
MS. STEMLAND: And does this appear to be video taken from one of the security cameras at ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this appear to be one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And if we could, let's see, go to 22:56, please, the time stamp-wise.
MS. STEMLAND: And do you recognize who's getting on the elevator?
BRANDON PATTERSON: I cannot see her face, but it appears to be Amber Heard.
MS. STEMLAND: I move to admit this as 38. And then we can move to 39, please.
MS. STEMLAND: Does this look like a true and accurate copy of -- or surveillance footage from one of the ECB cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this look like one of the clips that was taken and preserved in 2016 by ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And when I say "by ECB," I mean either you or someone under your direction, like the contractor you spoke 0£ Is that your understanding?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And I would like to move this in as Exhibit 38 -- I'm sorry, 39, please.
MS. STEMLAND: Do you know who was working behind the desk in this video?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And who's that?
BRANDON PATTERSON: Alex Romero.
MS. STEMLAND: Okay.
MS. STEMLAND: Can we move to Exhibit 40, please.
MS. STEMLAND: Q' And does this appear to be a clip -- a video from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does thus appear to be one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: I would like to move this in as Exhibit 40, please. And if we could, go to time stamp 21:17:33, please. And if we could move -- oh, yeah, thanks.
MS. STEMLAND: And do yoµ recognize who's getting on the elevator?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And who is it?
BRANDON PATTERSON: Amber, Rocky, and her sister, Whitney.
MS. STEMLAND: And would you agree with me that the video footage is a little bit grainy in this clip?
BRANDON PATTERSON: Yes, as it is displayed at the moment.
MS. STEMLAND: And does the date and time stamp look accurate within a few moments as far as you know?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does that appear to be one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: I would like to move to admit that as Exhibit 40, please. And move to 41, please.
THE COURT: Counsel could you pause it for a moment? Let's just go ahead and ...
THE COURT: All right. Ladies and gentlemen, let's go ahead and take a 15-minute break till 4:00, okay? Great.
THE COURT: All right. We'll come back at 4:00 then, okay?
COURT BAILIFF: All rise.
COURT BAILIFF: All rise. Be seated and come to order.
THE COURT: Ready for the jury then? Okay. We're ready for the jury.
THE COURT: All right. You may continue. Thank you.
MS. STEMLAND: And does this also look like one of the clips taken from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this appear to be one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And would you agree with me that the quality is also grainy as it appears in this video?
BRANDON PATTERSON: Yes.
MS. STEMLAND: As far as you know, does the date and time stamp look accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you recognize the people in this video?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And who are they?
BRANDON PATTERSON: Amber, Rocky, Whitney.
MS. STEMLAND: Move to 42.
MS. STEMLAND: And does this appear to be one of the video cameras from ECB's security footage?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Does this appear to be one of the videos taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And if we could, please, let's see, go to 11 :32 and 11 :35.
MS. STEMLAND: Do you recognize this as a clip from 2016, one of the ones that was taken and preserved by ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, the date and time stamp is accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Move to admit this as Exhibit 43 -- I'm sorry, 42 and let's move to Exhibit 43, please.
MS. STEMLAND: Does this look like footage from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this appear to be one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And can you tell me where this is? Or do you remember where that was in the building?
BRANDON PATTERSON: That is the mezzanine vestibule between the building and the garage.
MS. STEMLAND: Okay.
MS. STEMLAND: If we could, move to exhibit 44, please.
MS. STEMLAND: And does this look like one of the videos taken from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Does this look like one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you recognize who's in this photo -- I mean, who's in the video?
BRANDON PATTERSON: It appears to be Amber and Trinity Esparza.
BRANDON PATTERSON: MALE SPEAKER: Trinity what?
BRANDON PATTERSON: Trinity Esparza.
MS. STEMLAND: Can you rewind that footage, please.
MS. STEMLAND: And does Amber Heard have a sister?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Do you know if that's Amber Heard's sister versus Amber Heard? Could you tell?
BRANDON PATTERSON: In this video? Not a hundred percent, no.
MS. STEMLAND: And would you agree that the video is O also a little bit fuzzy in this clip?
BRANDON PATTERSON: As it appears now, yeah, it's grainy.
MS. STEMLAND: And does this look like an accurate clip taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And if we could, please move to Exhibit 46.
MS. STEMLAND: As far as you know, did ECB preserve all the footage that Mr. Depp's attorneys or/and Amber's attorneys asked you to preserve?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And did you -- from your understanding, did you understand that the attorneys, some attorneys came and actually were involved in the selection process of videos, ECB in May of 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And moving to this exhibit, 45, does this appear to be a video clip from one of the elevator surveillance cameras in ECB?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this appear to be one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and the time stamps accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And I'd like to move to admit this as Exhibit 45. And 46.
MS. STEMLAND: And do you recognize the people in this?
BRANDON PATTERSON: It appears to be Amber and Rocky.
MS. STEMLAND: And would you agree that the footage is a little bit fuzzy?
BRANDON PATTERSON: Yes, as it's displayed now.
MS. STEMLAND: I would like to move to admit that as Exhibit 46 and move on to Exhibit 47, please.
MS. STEMLAND: And does this appear to be a video clip from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this appear to be one of the. clips taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the time and date stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Will you agree that video footage is a little bit fuzzy in this clip as well?
BRANDON PATTERSON: Yes, as it is displayed.
MS. STEMLAND: And does this look like one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, the date and time stamp looks accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: I believe we're on Exhibit 48.
MS. STEMLAND: Does this appear to be a clip from one of the ECB video cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does it appear to be one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, are the date and time stamps accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And do you recognize the woman about to get on the elevator, getting on?
BRANDON PATTERSON: Which? It looks like Amber's waiting to get on. Rocky just came in. Whitney is over in the corner. I don't know the other two.
MS. STEMLAND: Okay. And can you -- would you agree that this footage is also a little bit fuzzy?
BRANDON PATTERSON: Yes, as it's displayed now.
MS. STEMLAND: And that looks like an accurate clip from one of the ones that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: If we could, please pull up Exhibit 49.
MS. STEMLAND: Mr. Patterson, are you familiar with the layout at the penthouse level of the Eastern Columbia Building?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And this is Exhibit 49 that I'm showing to you. And does this look like what you understand the layout to be of the penthouse 3, first level? Does this look, to you, like what your understanding is of the layout of penthouse 3, the first level?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And if we could scroll down, please.
MS. STEMLAND: Does that look like the layout of the second level of penthouse 3?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Move to admit exhibit 49, please. And can we please move to 846. Exhibit 50.
MS. STEMLAND: And can we zoom in a little bit, please.
MS. STEMLAND: Mr. Patterson, do you recognize this as the layout of the penthouse level?
BRANDON PATTERSON: Nothing's labeled. Generally, I guess.
MS. STEMLAND: Does that look like the pool is in the right spot on that exhibit?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does -- from what you can tell, does everything else look as you would expect the layout to be in your familiarity with the layout in your experience?
BRANDON PATTERSON: Yes, generally.
MS. STEMLAND: Going back to the video clips, and we can watch, there's a couple I'm saving till the end to see if there's time, but for the ones that I've showed you, is your understanding that those are all accurate copies of ECB footage that were taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And, again, by taken by ECB, I mean by you or someone under your direction in the regular course of business.
MS. STEMLAND: Is that your understanding?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And is it correct that ECB has produced all the video footage that had been subpoenaed by attorneys?
BRANDON PATTERSON: Yes, that's correct
MS. STEMLAND: So to the extent that that footage has not been produced, is it fair to say that that footage no longer exists? Or do you have another explanation?
BRANDON PATTERSON: Can you expand on that, please?
MS. STEMLAND: Sure. So there's -- my understanding is that you testified that there's 87 clips that have been preserved; is that right?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And that the date and time stamps are reasonably accurate, to your knowledge, on those?
BRANDON PATTERSON: Yes, to my knowledge.
MS. STEMLAND: To the.extent there are any missing days or times, is it fair to say that that footage no longer exists? Or is there any other footage that could be produced?
BRANDON PATTERSON: Outside of the videos that were requested, that's correct; no, everything else would have been written over at this point.
MS. STEMLAND: Okay. So there's no other videos, other than those that have been produced, to your knowledge?
BRANDON PATTERSON: Yes, correct.
MS. STEMLAND: Okay. And I believe you testified that ECB currently has a new and improved video system; is that right? Am I remembering that correctly?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And back in 2016, would you agree with me that the video quality was somewhat grainy, as I believe that we've talked about in some of the clips?
BRANDON PATTERSON: Yes. Compared to today's, yes.
MS. STEMLAND: And was it also a little bit fuzzy in the clips that we reviewed today?
BRANDON PATTERSON: Yes, as they were displayed on the screen.
MS. STEMLAND: And is it correct that you did not see Amber in person yourself on May 21st or the several days after?
BRANDON PATTERSON: I don't recall which day or days she came into the office, but I did see her on those two occasions. Outside of that, no, I did not see her in person.
MS. STEMLAND: Okay. With that last answer, you don't recall which days you saw her; is that correct?
BRANDON PATTERSON: I don't remember the specific date of those interactions.
MS. STEMLAND: So would you be able to testify, based on your knowledge, whether Amber is wearing makeup the week of the 21st of 2016?
BRANDON PATTERSON: Not that I recall.
MS. STEMLAND: And if we could please go back, since we have a little bit of extra time, and watch the video that we couldn't hear the audio on, there's something wrong with it, but I believe the audio's fixed, so can we please go back to exhibit 3.
MS. STEMLAND: Mr. Patterson, I believe you testified when we first saw this video without audio, that you described Mr. Depp's behavior as animated; is that right?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Now that the audio is back, would you still describe Mr. Depp's behavior as animated?
BRANDON PATTERSON: Yeah. I think he's still animated, but with the audio, I would say upset about something.
MS. STEMLAND: And based on your -- the times you've seen Mr. Depp at ECB, have you seen him upset about -- similarly upset in the building?
BRANDON PATTERSON: There was one video of Mr. Depp in the elevator seems, like I said earlier, animated.
MS. STEMLAND: The one you're referring to, is that the one where you said Mr. Depp was swaying side to side? Or are you thinking .of a different one?
BRANDON PATTERSON: Yes, when he was swaying side to side
MS. STEMLAND: Do you know who Mr. Waldman is?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And who is he?
BRANDON PATTERSON: Johnny Depp's attorney.
MS. STEMLAND: Did Mr. Waldman contact you about this case?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And what did Mr. Waldman want when he called you?
BRANDON PATTERSON: Can you clarify? Just because there's been several cases. I don't recall which case Mr. Waldman was involved in,. so I don't believe he's reached out regarding this particular one, to my knowledge.
MS. STEMLAND: Which are the other cases that you've been contacted by Mr. Waldman about?
BRANDON PATTERSON: I don't recall the specific one, but he did reach out to whichever one he was representing at that time, and I believe there's a subpoena that had followed.
MS. STEMLAND: And did you say that Mr. Waldman contacted you in two prior cases?
BRANDON PATTERSON: I don't recall which case it was in regard to,
MS. STEMLAND: And did you talk to Mr. Waldman on the phone?
BRANDON PATTERSON: I don't recall.
MS. STEMLAND: And did you communicate with Mr. Waldman by email?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Did Mr. Waldman prepare a draft declaration for you?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Is it fair to say that you cannot testify one way or another about whether Mr. Depp committed domestic violence against Amber?
BRANDON PATTERSON: I cannot
MS. STEMLAND: If we could, please turn to Exhibit 9.
MS. STEMLAND: And does this look like a video camera from the ECB video footage?
THE COURT: Is this where you want to stop?
MR. NADELHAFT: Yeah. We're just going to play one before showing ...
THE COURT: Okay.
MR. NADELHAFT: Yeah. Thank you.
THE COURT: Uh-huh.
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this look like one taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Can we please take that down and bring up 10.
MS. STEMLAND: And does this look like a video from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this look like one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does the date and time, within a few seconds, look accurate as far as you know?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Can we please take that down and bring up 16.
MS. STEMLAND: And does this look like a video clip from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this look like one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: We can take this down and bring up 17, please.
MS. STEMLAND: Does this look like one of the video clips from the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this look like one of the clips that was taken and preserved by ECB from 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Could we please take it down and bring up 18.
MS. STEMLAND: Does this look like a video clip from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this look like one of the clips that was taken and preserved by ECB from 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time stamp accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: Could you please take it down and bring up 25.
MS. STEMLAND: And does this look like a security camera -- footage from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this look like one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, are the date and time stamps accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. STEMLAND: If we could, pull up 26.
MS. STEMLAND: And does this look like a video from one of the ECB security cameras?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And does this look like one of the clips that was taken and preserved by ECB since 2016?
BRANDON PATTERSON: Yes.
MS. STEMLAND: And as far as you know, is the date and time accurate within a few seconds?
BRANDON PATTERSON: Yes.
MS. VASQUEZ: And just to confirm, that is your signature at the end of this document; is that correct?
BRANDON PATTERSON: Yes, that's correct.
MS. VASQUEZ: Did anyone assist you in drafting this I declaration?
BRANDON PATTERSON: Yes.
MS. VASQUEZ: And who was that person?
BRANDON PATTERSON: Mr. Waldman.
MS. VASQUEZ: And did Mr. Waldman, with his assistance in drafting your declaration, have any influence on the truthfulness of your :Statements in your declaration?
MS. VASQUEZ: Is this a true and accurate copy of your first witness statement submitted in the U.K. action?
BRANDON PATTERSON: Yes, it appears to be.
MS. VASQUEZ: Mr. Patterson, the statements contained in this first witness statement, are they truthful?
BRANDON PATTERSON: Yes. Anything that I would have put on here and signed would have been truthful.
MS. VASQUEZ: Did Mr. Depp ever offer you any money?
BRANDON PATTERSON: No, he did not
MS. VASQUEZ: Between May 21st, 2016, which I'll represent to you was a Saturday, and May 27th, 2016, which I will represent to you was a Friday, did you work on site at the Eastern Columbia Building?
BRANDON PATTERSON: I don't recall if I was there those days. I'm typically there Monday through Friday, but I do not recall if_l was there those days.
MS. VASQUEZ: Sitting here today, do you have any recollection of interacting in person with Ms. Heard at any point between May 21st, 2016, and May 27th, 2016?
BRANDON PATTERSON: As I have previously mentioned, I don't recall the specific dates of when Ms. Heard stopped by the office. I don't recall the specific dates.
MS. VASQUEZ: Alejandro Romero was another person that spoke to-you about his interactions with Ms. Heard?
BRANDON PATTERSON: That I don't - I'm not a hundred percent I don't recall exactly.
MS. VASQUEZ: Was Cornelius Hill one of the people that spoke to you about his interactions with Ms. Heard?
BRANDON PATTERSON: I also don't recall any specific interaction with Cornelius.
MS. VASQUEZ: Do you recall when Ms. Esparza first came to you about her observations of Ms. Heard?
BRANDON PATTERSON: I don't recall a specific interaction. I have a recollection of, I guess, Trinity stopping by, but I don't remember the exact interaction.
MS. VASQUEZ: Are the statements contained in paragraphs 15 through 18 truthful?
BRANDON PATTERSON: As I review i yes, that is my recollection of the occurrences.
MS. VASQUEZ: What footage do you recall Ms. Esparza showing you?
BRANDON PATTERSON: I recall Ms. Esparza showing me video of the mezzanine level where the multicolored area rug is, Amber with her sister, and Rocky; and one of them, what I remember, fake punched Amber in the face, in which they all started laughing and then they walked off screen.
MS. VASQUEZ: Do you recall the date of that surveillance footage video that you just described?
BRANDON PATTERSON: I do not.
MS. VASQUEZ: Do you recall whether it occurred after May 21, 2016?
BRANDON PATTERSON: I don't recall
MS. VASQUEZ: Mr. Patterson, does this, after reviewing paragraph 7 of your declaration that you signed under the penalties of perjury, does this refresh your recollection as to whether or not you observed the surveillance footage sometime around May 24th, 2016?
BRANDON PATTERSON: Yes.
MS. VASQUEZ: Okay. Let's go through the first interaction that you remember with Ms. Heard. Can you tell me what you remember about that interaction?
BRANDON PATTERSON: So Amber came in, shook her hand, and she told me the situation where she needed to have me make a statement to her sources at People magazine.
MS. VASQUEZ: Did Ms. Heard explain to you why she wanted you to speak to her source at People magazine?
BRANDON PATTERSON: I don't remember the exact - I don't recall the exact ask. It was something to do with her getting ridiculed in the eye of the public opinion or something like that.
MS. VASQUEZ: Can I please have Exhibit 3 pulled up. And for the record, it's Bates-stamped Depp 3628.
MS. VASQUEZ: Mr. Patterson, does this video clip represent a true and accurate copy of one of the original clips that was produced in response to a subpoena in 2016?
BRANDON PATTERSON: Yes.
MS. VASQUEZ: And was this clip recorded and kept in the regular course of business for Eastern Columbia management? I misspoke. Let me rephrase.
MS. VASQUEZ: Was this clip recorded and kept in the regular course of business for Eastern Columbia Building?
BRANDON PATTERSON: Can you expand on that?
MS. VASQUEZ: Yeah. Let me rephrase it.
MS. VASQUEZ: This is surveillance footage -- this is a clip of surveillance footage that was recorded for business purposes at ECB, yes?
BRANDON PATTERSON: Yes, that is correct.
MS. VASQUEZ: Okay. And it was kept or preserved by ECB, right?
BRANDON PATTERSON: Yes, that is correct.
MS. VASQUEZ: Do you know which camera this particular clip was showing footage from? We can perhaps replay it because I believe it might indicate that.
BRANDON PATTERSON: Yeah, if we could pull it up again.
MS. VASQUEZ: Do you know which camera this is showing footage froth?
BRANDON PATTERSON: A So this would have been the penthouse elevator.
MS. VASQUEZ: And if we could, please pull up Exhibit 4
MS. VASQUEZ: Does this video clip represent a true and accurate copy of one of the original clips that was produced in response to a subpoena in 2016?
BRANDON PATTERSON: It appears to be. I mean, there's nothing going on right now, but yes.
MS. VASQUEZ: And which camera is this showing footage from?
BRANDON PATTERSON: This is also the penthouse elevator.
MS. VASQUEZ: If I could please have Exhibit 5 pulled up.
MS. VASQUEZ: And for the record, that's Bates-stamped Depp 3641.
MS. VASQUEZ: And does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be.
MS. VASQUEZ: Do you know which camera this is showing footage from?
BRANDON PATTERSON: This would also be the penthouse elevator.
MS. VASQUEZ: And what is the date of this footage?
BRANDON PATTERSON: May 21st, 2016.
MS. VASQUEZ: Okay.
MS. VASQUEZ: If we could, please pull I up Exhibit 6, Bates-stamped Depp 3648.
MS. VASQUEZ: Does this video clip represent a true and accurate copy of one of the original clips that you produced in 2016?
BRANDON PATTERSON: It appears to - it appears so. I don't recall this exact time of this clip, but, yes, it does appear so.
MS. VASQUEZ: And what is the date on this video clip?
BRANDON PATTERSON: May 21st, 2016.
MS. VASQUEZ: And which camera is this showing footage from?
BRANDON PATTERSON: If I can wait for the doors to open, so this is also the penthouse elevator.
MS. VASQUEZ: Mr. Patterson, I will show you next a video clip that's been Bates-stamped Depp 3610, Patterson exhibit 7.
MS. VASQUEZ: Is it a true and accurate copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: Do you know which camera this is showing footage from?
BRANDON PATTERSON: This is the front desk camera in the lobby.
MS. VASQUEZ: Next, can we please have Exhibit 8 pulled up which, for the record, is Depp 3620.
MS. VASQUEZ: Mr. Patterson, does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: Do you recognize who the person is that entered the elevator at 22:56?
BRANDON PATTERSON: It appears to be Amber Heard.
MS. VASQUEZ: Can I please have Exhibit 9 pulled up.
MS. VASQUEZ: Does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: Do you know which camera this is I showing footage from?
BRANDON PATTERSON: This is also the penthouse elevator.
MS. VASQUEZ: Could I please have Exhibit 10 pulled up. And for the record, this is Bates-stamped Depp 3607.
MS. VASQUEZ: Is this video clip of a true and accurate copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: Do you know which camera this is showing footage from?
BRANDON PATTERSON: This is also the penthouse elevator.
MS. VASQUEZ: And what date is depicted?
BRANDON PATTERSON: May 25th, 2016.
MS. VASQUEZ: Next, can I have, please, Exhibit 12, which for the record is Bates-stamped Depp 3572.
MS. VASQUEZ: Does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: And do you know which camera this is showing footage from?
BRANDON PATTERSON: This is the front desk lobby camera.
MS. VASQUEZ: And what is the date of this video clip?
BRANDON PATTERSON: May 25th, 2016.
MS. VASQUEZ: And if we could, please go to, really, if I could ask for your help, 13:45, I'm going to mark this exhibit as Patterson Exhibit 12.
MS. VASQUEZ: Do you recognize the woman at the desk, walking to the desk?
BRANDON PATTERSON: Yes. That looks like Amber Heard is approaching Trinity Esparza working at the desk.
MS. VASQUEZ: Can I have Exhibit 15 pulled up, please. And for the record, it's Bates-stamped Depp 3583.
MS. VASQUEZ: Does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: And do you know which camera this is showing footage from?
BRANDON PATTERSON: This would also be the penthouse elevator.
MS. VASQUEZ: And what is the date of this video clip?
BRANDON PATTERSON: May 25th, 2016.
MS. VASQUEZ: Do you recognize the woman in the black IO shirt just outside the elevator?
BRANDON PATTERSON: Yes. Amber Heard.
MS. VASQUEZ: So is this one of the video clips that represents a true and accurate copy of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: And what is the date of this video clip?
BRANDON PATTERSON: May 25th, 2016.
MS. VASQUEZ: And what camera angle -- or excuse me. What camera is this showing footage from?
BRANDON PATTERSON: This is the mezzanine camera between the building and the parking garage.
MS. VASQUEZ: Is that camera 4?
BRANDON PATTERSON: According to the stamp, yes.
MS. VASQUEZ: Thank you. If you could, please mark that as Exhibit 14.
MS. VASQUEZ: Turning to Patterson Exhibit 15, Bates-stamped Depp 3569, does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: And what is the date of this video?
BRANDON PATTERSON: May 25th, 2016.
MS. VASQUEZ: And which camera is this showing footage from?
BRANDON PATTERSON: This is camera 7, lobby camera.
MS. VASQUEZ: And does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: And what is the date of this video?
BRANDON PATTERSON: May 24th, 2016.
MS. VASQUEZ: And what camera is this showing footage from?
BRANDON PATTERSON: This is camera number 6, which is the kiosk camera outside on Broadway.
MS. VASQUEZ: Thank you.
MS. VASQUEZ: Can we please mark the security clip as Patterson Exhibit 16.
MS. VASQUEZ: Next, could I please have Patterson Exhibit 17, Depp 3594.
MS. VASQUEZ: Does this video clip represent a true and accurate copy of one of the original clips IO that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: And what camera is this showing footage from?
BRANDON PATTERSON: This is camera number 8, Broadway, outside of the apartment building.
MS. VASQUEZ: What is the date of this video?
BRANDON PATTERSON: May 24th, 2016.
MS. VASQUEZ: Thank you.
MS. VASQUEZ: If we could, please mark this security clip as Patterson Exhibit 17.
MS. VASQUEZ: Almost done.
MS. VASQUEZ: Turning to video clip that is been Bates-stamped Depp 3609, Patterson Exhibit 18.
MS. VASQUEZ: Does this video clip represent a true and accurate copy of one of the original clips . that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: And do you know which camera this is showing footage from?
BRANDON PATTERSON: This is camera 4, which is the service to hallway.
MS. VASQUEZ: And what date is depicted in the security clip?
BRANDON PATTERSON: May 22nd, 2016.
MS. VASQUEZ: Thank you.
MS. VASQUEZ: Can we please mark this video clip as Patterson Exhibit 18.
MS. VASQUEZ: Next, Patterson Exhibit 19, Depp 3611.
MS. VASQUEZ: Does this video clip represent a true and accurate copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: And what camera is this showing footage from?
BRANDON PATTERSON: This is camera 13, mezzanine level.
MS. VASQUEZ: And what is the date on this video clip?
BRANDON PATTERSON: May 22nd, 2016.
MS. VASQUEZ: Thank you.
MS. VASQUEZ: Can we please mark the security clip as Patterson exhibit 19.
MS. VASQUEZ: Turning to Patterson Exhibit 20 which, for the record, is Bates-stamped Depp 3612.
MS. VASQUEZ: Is this one of the video clips that represents a true and correct copy of one of the original clips that was produced in 2016?
BRANDON PATTERSON: Yes, it appears to be so.
MS. VASQUEZ: And what camera is this showing footage from?
BRANDON PATTERSON: This is the garage, camera number 2.
MS. VASQUEZ: And what is the date of this video clip?
BRANDON PATTERSON: May 22nd, 2016.
MS. VASQUEZ: Thank you.
MS. VASQUEZ: Can we please mark this security clip as Patterson exhibit 20.
MS. VASQUEZ: And do you know what camera this is showing footage from?
BRANDON PATTERSON: This is parking garage camera Number 14.
MS. VASQUEZ: And what is the date on this video clip?
BRANDON PATTERSON: May 22nd, 2016.
MS. VASQUEZ: Thank you.
MS. VASQUEZ: Can we please mark this security clip as Patterson Exhibit 21.
MS. VASQUEZ: Mr. Patterson, I believe you previously testified, or counsel informed you that there were 87 video clips that were produced in response to subpoena in 2016.
MS. VASQUEZ: Do you recall that testimony?
BRANDON PATTERSON: Yes.
MS. VASQUEZ: And all 87 video clips, to the best of your recollection as the person most knowledgeable for property -- excuse me -- Action Property Management, were those 87 video clips recorded and kept, or preserved, in the regular course of business for Eastern Columbia Building?
BRANDON PATTERSON: Yes.
MS. VASQUEZ: And were those clips collected, preserved, and produced near the time of the actual events recorded in the clips?
BRANDON PATTERSON: Yes. It would have been within that 20- to 30-day timeline.
MS. VASQUEZ: Right. And was the regular practice of the Eastern Columbia Building to record security footage similar to what is reflected in these clips that you've been shown today, correct?
BRANDON PATTERSON: Yes, that's correct.
MS. VASQUEZ: Mr. Patterson, I believe you testified earlier that you commented on the revisions to Mr. Waldman's draft declaration; is that right?
BRANDON PATTERSON: Yes, that's correct.
MS. VASQUEZ: And I would like you to read, please, the comment -- the third comment down where it says "Was this footage found?"
MS. VASQUEZ: I'm not certain of the date or time. I also do not recall who she was with, but it was I two females. I do not recall who threw the pretend punch. I also do not recall if she had any kind of injury during this time; however, I do recall one of the females pretending to punch Amber in the face.
MS. VASQUEZ: Now, did you write this comment? Do you remember it?
BRANDON PATTERSON: I do recall vaguely.
MS. VASQUEZ: And this footage, it never was found; O is that correct to your knowledge?
BRANDON PATTERSON: The footage was never requested.
MS. VASQUEZ: By whom?
BRANDON PATTERSON: Any of the attorneys.
MS. VASQUEZ: Is it your testimony that this footage exists or not?
BRANDON PATTERSON: It would no longer exist.
MS. VASQUEZ: And it would no longer exist -- and it was never produced as one of the 87 clips; is that right?
BRANDON PATTERSON: That is correct.
MS. VASQUEZ: And I believe you testified earlier that attorneys for both sides selected times and looked through video and made selections of what was preserved. Was that your testimony?
BRANDON PATTERSON: Yes, that's correct
MS. VASQUEZ: But nobody selected that footage to your knowledge?
BRANDON PATTERSON: Not to my knowledge, no.
MS. VASQUEZ: And it was never produced?
BRANDON PATTERSON: Not to my knowledge, no.
MS. VASQUEZ: And is it correct that you did not IO recall at that time whether Amber had any signs of injury?
BRANDON PATTERSON: At this moment, no, I do not recall.
MS. VASQUEZ: And according to that comment, you did not recall at that time; is that your understanding?
BRANDON PATTERSON: I don't recall.
MS. VASQUEZ: And you don't know the date or the time of that footage?
BRANDON PATTERSON: Don't recall and obviously I could read this, but I don't recall offhand.
MS. VASQUEZ: And you didn't recall at the time either; is that right?
BRANDON PATTERSON: That's correct.
THE COURT: All right. That completes testimony, correct? All right. Ladies and gentlemen, thank you for your extra time tonight. I just wanted to get through that witness tonight so we could start with a new witness tomorrow, okay? So have a good evening. Again, don't do any outside research. Don't talk to anybody about the case. Probably stay off social media. I'd appreciate it, okay, and we'll see you in the morning at 10:00 a.m., okay? Thank you.
THE COURT: All right. Well, I know six weeks sounds like a lot of time; but it's only 24 days, and we've already done three days. So you have 21 days left. You know, "stipulations" is one of my favorite words, so you might want to consider looking back through all the evidence that you have and stipulate on a lot of information because I promised this jury we'd be done by Memorial Day weekend, and we will be done by Memorial Day weekend. So when your time is up, your time is up.
THE COURT: My law clerk, Stanley, is tracking everyone's time, who's -- how much time has been used by each side. So he'll keep doing that throughout the trial; and we'll let you know on a weekly basis how it's going. But if things don't speed up in deposition, you're just not going to IO get through this, so I want you to keep that in mind, okay?
THE COURT: Any remote witnesses tomorrow? Do we need someone to set that up?
UNKNOWN SPEAKER: No, Your Honor.
THE COURT: No? Great. Thank you. Have a good evening. I'll see you at 10:00, okay?
UNKNOWN SPEAKER: Thank you, Your Honor.
COURT BAILIFF: All rise.
[STAGE DIRECTION]: T I, JUDITH E. BELLINGER, RPR, CRR, the court reporter before whom the foregoing hearing was taken, do hereby certify that the foregoing excerpt transcript is a true and correct record of the proceedings; that said proceedings were taken by me stenographically and thereafter reduced to typewriting under my direction; and that I am neither counsel for, related to, nor employed by any of the parties to this case and have no interest, financial or otherwise, in its outcome.
[STAGE DIRECTION]: IN WITNESS WHEREOF, I have hereunto set my hand and affixed my notarial seal this 14th day of April, 2022. My Commission Expires: September 30, 2024 PLANET p