Depp v. Heard Transcript Christi Dembrowski
Depp v. Heard / Day 2 / April 13, 2022
3 pages · 3 witnesses · 2,972 lines
Christi Dembrowski's cross concludes with her own texts and Dr. Kipper's email as impeachment; Baruch testifies to no visible injuries on Heard post-May 21; ECB manager Patterson authenticates 87 surveillance clips.
colloquy Preliminary Matters
1

COURT BAILIFF: All rise.

2

THE COURT: All right. Good morning.

3

THE COURT: Do we have any preliminary matters before the jury?

4

MS. BREDEHOFT: We do, Your Honor. May we approach?

5

THE COURT: Sure.

6

MS. BREDEHOFT: Your Honor, Mr. Depp was taking photographs and taking pictures outside the courthouse yesterday.

7

MS. BREDEHOFT: Courthouse.

8

THE COURT: Well, that's not the

9

MS. BREDEHOFT: Do you see the stone right behind it? Do you see the stone right behind it?

10

THE COURT: I don't know if that's the courthouse or not.

11

MS. BREDEHOFT: Do you see the stonework?

12

THE COURT: That's not a door at this courthouse. He comes out the judge's lot, and that's not where he comes out. I'm not sure where that is. That might be his hotel, possibly.

13

MR. CHEW: Actually, it looks more like his hotel.

14

THE COURT: That's not the courthouse. He comes out the judge's lot. We have a pool camera there when he leaves.

15

MS. BREDEHOFT: The other thing I wanted to bring up, with respect to that juror yesterday, I would rather the Court not reinstruct the jury.

16

THE COURT: Are you sure?

17

MS. BREDEHOFT: Yes. The Court already instructed the jury not to do that. I would rather that the Court watch that juror to see if anything like that happens again.

18

THE COURT: Sure.

19

MS. BREDEHOFT: And if there is some bias, then we'd ask for alternates.

20

THE COURT: Okay. All right. That's fine. I was going to read about -- not the same way, but just have no contact. But I won't do it.

21

MS. BREDEHOFT: Just keep an eye on it.

22

THE COURT: I will keep an eye on him You did tell Mr. Depp, though, not to wave back if anybody in the jury waves at him or smiles at him or anything?

23

MR. CHEW: Yeah, I will reiterate that right now.

24

THE COURT: I would appreciate that. Thank you.

25

THE COURT: Mr. Rottenborn, do you have the redactions for me?

26

MR. ROTTENBORN: We have one of the two. The other one, we had to make one tweak to it, and we're going to do that electronically during my cross-examination.

27

THE COURT: Which one do you have for

28

MR. ROTTENBORN: Exhibit 214.

29

MR. ROTTENBORN: That we provided.

30

THE COURT: So the redactions, reserving your other objections, the redactions are okay?

31

MR. CHEW: Yes, Your Honor.

32

THE COURT: Okay. So, 214 will be in evidence, then.

33

THE COURT: Do you want to get the witness back on the witness stand before we get the jury here?

34

MR. CHEW: Yes, Your Honor.

35

THE COURT: Ms. Dembrowski. All right. Let's put her up before we get the jury out. That would be helpful.

36

THE COURT: Mr. Rottenborn, you're going to get me 214 afterwards?

37

MR. ROTTENBORN: Yes, Your Honor.

38

THE COURT: No, 210.

39

MR. ROTTENBORN: 210. We'll put it up on the screen but without the presence of the jury. The judge will see it the same time you do.

40

MR. CHEW: Okay.

41

MR. ROTTENBORN: I just don't have it with me.

42

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

43

MR. CHEW: Yes, Your Honor.

44

THE COURT: Okay.

45

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

46 46:55

THE COURT: All right. Good morning, ladies and gentlemen. Thank you.

47 46:57

THE COURT: All right. You can have a seat, Ms. Dembrowski. Ms. Dembrowski, I want to remind you, you're still under oath at this time, okay?

48 47:03

THE COURT: You want to continue with your cross-examination, Mr. Rottenborn?

49

[SECTION HEADER]: BY MR. ROTTENBORN:

50 47:08

MR. ROTTENBORN: Good morning, Ms. Dembrowski.

51 47:12

CHRISTI DEMBROWSKI: Good morning.

52 47:13

MR. ROTTENBORN: So, I believe we talked a little bit about this yesterday, but you were, in addition to being Mr. Depp's brother, I believe you referred to it as his personal manager; is that right?

53 47:25

CHRISTI DEMBROWSKI: I have been referred as that, yes.

54 47:27

MR. ROTTENBORN: So you were responsible for, or had some responsibility for his business affairs, right?

55 47:35

CHRISTI DEMBROWSKI: I actually coordinated with other people, but I didn't have full responsibility.

56 47:40

MR. ROTTENBORN: Right. But in terms of the information that you would receive, you would receive IO information that was relevant to Mr. Depp's business affairs and personal affairs, right?

57 47:47

CHRISTI DEMBROWSKI: At times, yes.

58 47:48

MR. ROTTENBORN: And you care about Mr. Depp's well-being, right?

59 47:55
60 47:55

MR. ROTTENBORN: He's your brother --

61 47:56
62 47:57

MR. ROTTENBORN: You love him, right?

63 47:59

MR. ROTTENBORN: It was important to you that you, in your role as both his brother [sic] and as his manager, be kept informed of his well-being, right?

64 48:09
65 48:09

MR. ROTTENBORN: And if something was wrong, you'd want to know about that, right?

66 48:16
67 48:16

MR. ROTTENBORN: Did you ever have reason to believe, " from anyone other than Amber, that Mr. Depp had a problem with drugs or alcohol?

68 48:27
69 48:28

MR. ROTTENBORN: Did you ever have reason to believe, from someone other than Amber, that Mr. Depp romanticized drug culture?

70 48:39
71 48:40

MR. ROTTENBORN: Did you ever have reason to believe, from anyone other than Amber, that Mr. Depp didn't take accountability for his actions?

72 48:55

CHRISTI DEMBROWSKI: I didn't have reason to believe that., no.

73 48:58

MR. ROTTENBORN: Did you ever have reason to believe, from anyone other than Amber, that Mr. Depp lacked patience for getting his needs met?

74 49:07

CHRISTI DEMBROWSKI: I didn't have reason to believe that, no.

75 49:09

MR. ROTTENBORN: Did you ever have reason to believe, from someone other than Amber, that Mr. Depp could act like a child if he didn't get immediate satisfaction?

76 49:14

MR. CHEW: Objection, Your Honor. Lack of foundation.

77 49:19

MR. ROTTENBORN: I'm asking if she had --

78 49:20

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

79 49:23

MR. ROTTENBORN: Let me ask that again, Ms. Dembrowski. Did you ever have reason to believe, from anyone other than Amber, that Mr. Depp could act like a child if he didn't get immediate satisfaction?

80 49:31

MR. CHEW: Hearsay, Your Honor.

81 49:38

THE COURT: Overruled for this question. We'll see what the follow-up is.

82 49:43

CHRISTI DEMBROWSKI: I'm sorry?

83 49:45

MR. ROTTENBORN: Did you ever have reason to believe, from someone other than Amber, that Mr. Depp could act like a child if he didn't get immediate satisfaction?

84 49:54

CHRISTI DEMBROWSKI: I never had reason to believe that

85 49:56

MR. ROTTENBORN: Did you ever have reason to believe, from someone other than Amber, that Mr. Depp had fundamental issues with anger?

86 50:00

MR. CHEW: Your Honor, may we approach?

87 50:05

THE COURT: Okay.

88

[STAGE DIRECTION]: (Sidebar.)

89 50:09

MR. CHEW: He's reading from a document, a hearsay document, so ....

90 50:13

THE COURT: I don't know what he's reading from. He's just asking a question at this point. I assume if he tries to get something in, that's a different issue.

91 50:18

MR. CHEW: Okay.

92 50:22

THE COURT: Let's see where -- okay.

93 50:27

MR. CHEW: Okay.

94

[STAGE DIRECTION]: (Open court.)

95

[SECTION HEADER]: BY MR. ROTTENBORN:

96 50:31

MR. ROTTENBORN: Let me try that again, Ms. Dembrowski: Did you ever have reason to believe,. from someone other than Amber, that your brother had fundamental issues with anger?

97 50:41

CHRISTI DEMBROWSKI: I didn't have reason to believe.

98 50:44

MR. ROTTENBORN: And did you ever have reason to believe, from someone other than Amber, that your brother didn't grasp the responsibility that he had in his children's lives?

99 50:57

CHRISTI DEMBROWSKI: I did not have reason to believe.

100 50:59

MR. ROTTENBORN: Heather, can you pull up exhibit 268, please.

101 51:24

MR. ROTTENBORN: Ms. Dembrowski, is this an email from Dr. David Kipper to you on August 18th, 2014?

102 51:28

MR. CHEW: Objection. Hearsay.

103 51:33

THE COURT: It's not being offered yet, so I'll overrule the objection.

104 51:36

THE COURT: Go ahead.

105 51:38

CHRISTI DEMBROWSKI: I don't have it.

106 51:40

MR. ROTTENBORN: Can you see the documented on your screen?

107 51:42

THE COURT: You might need to make it bigger.

108 51:44

CHRISTI DEMBROWSKI: I don't have anything.

109 51:47

MR. ROTTENBORN: Can you see it there, ma'am?

110 51:51
111 51:52

THE COURT: It's not showing up on her screen.

112 51:57

MR. ROTTENBORN: Just bear with us one minute. Thank you.

113 52:03

CHRISTI DEMBROWSKI: Do I need to do something?

114 52:14

THE COURT: It's not coming up.

115 52:26

THE COURT: Do you have a physical copy that she could look at?

116 52:29

MR. ROTTENBORN: Not that's not marked up. Can you grab one?

117 52:33

THE COURT: Wait, she's got it. Tum it off and on, see?

118 52:37

MR. ROTTENBORN: That's the trick.

119 52:39

THE COURT: That's the trick.

120 52:44

MR. ROTTENBORN: Thank you.

121 52:49

MR. ROTTENBORN: Take as much time as you need to read it, Ms. Dembrowski, but my question is, is this an email from Dr. David Kipper to you, on August 18th, 2014?

122 53:04

CHRISTI DEMBROWSKI: Yes. It's got my name on there, yes. It's from him.

123 53:07

MR. ROTTENBORN: And this is an email that you would have received on or about that date, August 18th, 2014, to the best of your knowledge?

124 53:19

CHRISTI DEMBROWSKI: It was sent on that date, yes.

125 53:23

MR. ROTTENBORN: Okay. And it's about Dr. Kipper's treatment of your brother, correct?

126 53:27

CHRISTI DEMBROWSKI: I'm actually reading it.

127 53:29

MR. ROTTENBORN: Okay. Take your time. Thank you.

128 55:11

CHRISTI DEMBROWSKI: Sorry. Is there -- I'm sorry, is there more to the ...

129 55:15

MR. ROTTENBORN: There's another page, which we can go to, but my question is just this, and I think we established this, this is an email that you received from Dr. Kipper, correct?

130 55:24
131 55:25
132 55:27

MR. ROTTENBORN: Your Honor, permission to publish the second paragraph on page 1 into the -- and the remainder of that paragraph on page 2, with everything redacted -- else redacted.

133 55:40

THE COURT: You're asking to enter it into evidence?

134 55:42

MR. ROTTENBORN: Yes, we would like to enter it into the evidence with those redactions.

135

MR. CHEW: Your Honor. Two layers. Hearsay. May we approach?

136

[STAGE DIRECTION]: (Open court)

137

MR. CHEW: This is a double-hearsay issue.

138

THE COURT: Okay. Go ahead.

139

MR. CHEW: This is Dr. Kipper basically using Amber, a very dubious source, so there's two layers of hearsay here.

140

THE COURT: Right.

141

MR. CHEW: No exception.

142

THE COURT: What's the basis?

143

MR. ROTTENBORN: Not hearsay. She's testifying -- she testified that she never heard from anyone. I mean, her whole testimony, Your Honor, has been Amber exaggerates and no one else ever told me that he had any issues. I don't want to get the first paragraph in. That is hearsay. I agree. But the second paragraph, when he says all these things about Johnny, when she's testifying to the jury, she's making it sound like Amber is the only one.

144

MR. CHEW: Your Honor, it's still double hearsay. This is the very beginning of Dr. Kipper's treatment, where he had reason to think that Amber might have any credibility.

145

THE COURT: Don't talk over. Okay. Go ahead.

146

MR. ROTTENBORN: On the stand, she's putting her head in the sand. She's saying Amber was the only one that told me about Johnny.

147

THE COURT: Then you can ask her. So, Dr. Kipper did tell you about this? You can ask that, but I'm not going to allow this piece of evidence in this; okay?

148

MR. CHEW: Thanks, Your Honor.

149

MR. ROTTENBORN: Thank You.

150

[STAGE DIRECTION]: (Open court.)

151

MR. ROTTENBORN: BY MR. ROTTENBORN:

152 57:15

MR. ROTTENBORN: Ms. Dembrowski, if you take a look at the first page of this email, please. In the second paragraph-- well, first of all, who is Dr. Kipper?

153 57:26

CHRISTI DEMBROWSKI: Dr. Kipper was the doctor that was helping my brother, excuse me, helping my brother get help from the pain medication addiction that he had

154 57:41

MR. ROTTENBORN: He was helping him with his drug addiction?

155 57:43

CHRISTI DEMBROWSKI: The pain medication.

156 57:45

MR. ROTTENBORN: Okay. And your brother was addicted to pain pills?

157 57:48

CHRISTI DEMBROWSKI: He had been taking them for a long time, right.

158 57:51

MR. ROTTENBORN: And you were instrumental in hiring Dr. Kipper to help your brother try to deal with that, right?

159 57:56
160 57:57

MR. ROTTENBORN: And so, Dr. Kipper, in his role as someone treating your brother, tried to keep you informed of what was going on with that treatment, right?

161 58:06
162 58:06

MR. ROTTENBORN: And it was important to you, as both his brother -- sorry, his sister and his manager that you be kept informed of that, right?

163 58:15

CHRISTI DEMBROWSKI: It was important as his sister.

164 58:20

MR. ROTTENBORN: Well, and his issues with drugs were having an impact on his career as well, too, tight?

165 58:26
166 58:26

MR. ROTTENBORN: And you knew that they were having an impact on his relationship with Amber, right?

167 58:30

MR. CHEW: Objection. Lack of foundation.

168 58:34

MR. ROTTENBORN: She's given plenty of testimony about that.

169 58:36

THE COURT: Overruled. I'll allow it.

170 58:37

MR. ROTTENBORN: You knew that the drugs were having an impact on his relationship with Amber.

171 58:41

CHRISTI DEMBROWSKI: I knew that Amber claimed certain things.

172 58:45

MR. ROTTENBORN: But you didn't believe that they were?

173 58:48

CHRISTI DEMBROWSKI: I didn't necessarily believe it, no.

174 58:51

MR. ROTTENBORN: We'll get to that in a few minutes. Isn't it true that on the bottom paragraph on page 1, that Dr. Kipper informed you that your I brother was uncomfortable and pessimistic that h:1 will ever be able to stop doing drugs?

175 59:00

MR. CHEW: Objection. Double hearsay.

176 59:08

MR. ROTTENBORN: I'm not asking for --

177 59:09

THE COURT: I'll allow this question, but that's the only question on that point, okay? Thank you.

178 59:17

CHRISTI DEMBROWSKI: I'm sorry?

179 59:18

MR. ROTTENBORN: Isn't it true that Dr. Kipper informed you, in August of 2014, that your brother was uncomfortable and is pessimistic that he will ever be able to stop doing drugs?

180 59:30

CHRISTI DEMBROWSKI: He does write this in this email, but this email's an update, if I'm looking at the dates, and I don't remember all the dates, but I know that period, what's in the email, I think this was during the time they were - where he was getting help from Dr. Kipper.

181 59:50

MR. ROTTENBORN: Right. But that's what he informed you of, in your role as his manager and his sister, about the status of Mr. Depp's belief that he would be able to stop doing drugs, right?

182 59:57

MR. CHEW: Objection. Hearsay.

183 1:00:03

THE COURT: I'll allow that question.

184 1:00:06

CHRISTI DEMBROWSKI: I think he was informing me of the conversations, yes.

185 1:00:10

MR. ROTTENBORN: And he also informed you that your brother didn't take accountability for his behaviors, correct?

186 1:00:33

CHRISTI DEMBROWSKI: He does say in here, yes, he wrote that he has no accountability for his behaviors in this time.

187 1:00:41

MR. ROTTENBORN: Heather, if you go to the top of page 2, please.

188 1:00:48

MR. ROTTENBORN: In that first and second line, he also told you that your brother has fundamental issues with anger, right?

189 1:00:53

MR. CHEW: Your Honor, objection. Hearsay. No exception applies.

190 1:00:59

MR. ROTTENBORN: Same exception that applied to the other ones, this is what he informed her.

191 1:01:02

THE COURT: We need to move on, though.

192 1:01:07

MR. ROTTENBORN: Okay. Heather, you can take that down.

193 1:01:10

MR. ROTTENBORN: So you just testified, Ms. Dembrowski, that you understood, from Amber, that drugs and alcohol were impacting the relationship but that you didn't necessarily believe that, right?

194 1:01:25
195 1:01:25

MR. ROTTENBORN: You didn't necessarily share those concerns, right?

196 1:01:30
197 1:01:30

MR. ROTTENBORN: Did you have an occasion to speak with Amber after a plane flight from Boston to Los Angeles in May of 2014?

198 1:01:39

MR. CHEW: Objection. Hearsay.

199 1:01:48

MR. ROTTENBORN: I just asked if she spoke with her. I'm not asking what the content is.

200 1:01:51

THE COURT: Spoke. I'll overrule the objection at this time.

201 1:01:54

CHRISTI DEMBROWSKI: I don't recall a specific time speaking with Amber like that.

202 1:02:02

MR. ROTTENBORN: Did you become aware of an incident on a plane flight from Boston to Los Angeles in May of 2014?

203 1:02:06

MR. CHEW: Objection. Lack of foundation.

204 1:02:09

THE COURT: Foundation objection.

205 1:02:13

MR. ROTTENBORN: She's testified--

206 1:02:17

THE COURT: I'll sustain the objection as to foundation. If you can lay a foundation.

207 1:02:22

MR. ROTTENBORN: If something happened in your brother's life that was notable, you wanted to know about it, you testified to that, right?

208 1:02:29

MR. CHEW: Objection. Calls for speculation. No exception.

209 1:02:36

MR. ROTTENBORN: It's a foundation question. She's testified that she had insight into his daily life.

210 1:02:41

THE COURT: I don't see it as a foundation question, so I'm going to sustain the objection.

211 1:02:46

MR. ROTTENBORN: You were kept apprised of the goings on in Johnny's life, correct?

212 1:02:51

CHRISTI DEMBROWSKI: For the most part, yes.

213 1:02:52

MR. ROTTENBORN: And you testified yesterday you saw him just about every day, correct?

214 1:02:59

CHRISTI DEMBROWSKI: When -- what I testified to yesterday, when I saw him every day, was when he was with the family, Vanessa.

215 1:03:05

MR. ROTTENBORN: You still saw him-or were in touch with him fairly frequently, as his business manager and as his sister, when he was with Amber, correct?

216 1:03:13

CHRISTI DEMBROWSKI: Less frequent.

217 1:03:15

MR. ROTTENBORN: But still with some frequency, right?

218 1:03:17
219 1:03:17

MR. ROTTENBORN: And if an event had happened that was potentially harmful to your brother, you would want to know about that, right?

220 1:03:27
221 1:03:28
222 1:03:29

MR. CHEW: Objection. Asked and answered several times.

223 1:03:29

THE COURT: Okay. I'll sustain asked and answered.

224 1:03:31

THE COURT: Next question.

225 1:03:32

MR. ROTTENBORN: You made an effort to make yourself available to Ms. Heard to talk to you about issues she was having with your brother, correct?

226 1:03:51

CHRISTI DEMBROWSKI: Excuse me. I made an effort to talk to her anytime I felt she needed to speak.

227 1:04:01

THE COURT: Somebody's trying to call us.

228 1:04:05

MR. ROTTENBORN: Kind of a pleasant ring tone.

229 1:04:06

THE COURT: I didn't answer it, so, I don't know.

230 1:04:17

MR. ROTTENBORN: Ms. Dembrowski, in addition to just Amber believing it, you believed that your brother needed help, didn't you?

231 1:04:21

MR. CHEW: Objection. Vague.

232 1:04:24

THE COURT: Vague.

233 1:04:27

MR. ROTTENBORN: You believed that your brother needed help with drugs and alcohol didn't you?

234 1:04:30

THE COURT: Overrule the objection.

235 1:04:32

THE COURT: Go ahead.

236 1:04:35
237 1:04:35

CHRISTI DEMBROWSKI: I believed on the one medication I was concerned about.

238 1:04:39

MR. ROTTENBORN: And you wanted your brother to get I better from his addictions, right?

239 1:04:44

CHRISTI DEMBROWSKI: I wanted to address the medication that he was on.

240 1:04:49

MR. ROTTENBORN: And you understood that Amber wanted t'le same thing, wanted him to get better for both him and for her, correct?

241 1:04:58

MR. CHEW: Objection. Calls for speculation as to what Amber wanted.

242 1:04:59

THE COURT: I'll sustain s to what IO Amber wanted.

243 1:05:01

MR. ROTTENBORN: Now, do you recall meeting with Ms. Heard on May 25th, 2014?

244 1:05:07

CHRISTI DEMBROWSKI: I don't recall.

245 1:05:10

MR. ROTTENBORN: Let's pull up exhibit 234, please.

246 1:05:17

THE COURT: You said that was 234?

247 1:05:21

MR. ROTTENBORN: 2-3-4, yes.

248 1:05:25

THE COURT: Okay. Thank you.

249 1:05:28

MR. ROTTENBORN: The non-redacted version.

250 1:05:41

MR. ROTTENBORN: Ms. Dembrowski, this is a multipage exhibit. We're not going to ask you about all the pages, but is this a text message chain between Amber and you on May 25th, 2014?

251 1:06:03
252 1:06:05

MR. ROTTENBORN: And those are your texts in gray on the left, right?

253 1:06:09
254 1:06:09

MR. ROTTENBORN: And Ms. Beard's texts in blue on the right?

255 1:06:14
256 1:06:15

MR. ROTTENBORN: Your Honor, we have a version of this exhibit with Ms. Beard's texts redacted and the personal identifiers redacted that I'd like to ask the witness about and publish to the jury.

257 1:06:23

MR. CHEW: Objection. Hearsay, Your Honor.

258 1:06:31

THE COURT: First, you want to admit it into evidence before you publish it to the jury?

259 1:06:34

MR. ROTTENBORN: Right. I'm just previewing that would you like me to go through the unredacted version with the witness first?

260 1:06:40

THE COURT: Well, if it's just her I texts, how is that probative if it's just her texts?

261 1:06:51

MR. ROTTENBORN: Two things. One is her texts about what she wanted for her brother, we will get to those on page 2.

262 1:06:55

MR. CHEW: Your Honor, it's still-- still has the same hearsay problem.

263 1:07:00

MR. ROTTENBORN: I'm allowed to ask her about her own words and what her feelings were.

264 1:07:04

THE COURT: You can ask her about it, but it's not coming into evidence.

265 1:07:07
266 1:07:09

THE COURT: Okay?

267 1:07:11

MR. ROTTENBORN: Ms. Dembrowski, did you reach out to Ms. Heard on May 25th, 2014?

268 1:07:18
269 1:07:18

MR. ROTTENBORN: Asking her if she wanted to talk?

270 1:07:20
271 1:07:21

MR. ROTTENBORN: Why did you do that? Did you do that because you had been made aware of an issue about your brother's behavior on a flight earlier that day?

272 1:07:25
273 1:07:29

MR. ROTTENBORN: The day before?

274 1:07:30

CHRISTI DEMBROWSKI: I don't recall why I did that

275 1:07:33

MR. ROTTENBORN: You don't recall why you did that?

276 1:07:34
277 1:07:36

MR. ROTTENBORN: You have no awareness or memory of a flight earlier that day or the day before? .s

278 1:07:42

CHRISTI DEMBROWSKI: I don't recall all flights at all times. I don't have any specific memory of anything.

279 1:07:47
280 1:07:50

MR. ROTTENBORN: If you can turn to page 2, Heather.

281 1:07:59

MR. ROTTENBORN: If you can look at your third text down, Your Honor -- or Ms. Dembrowski, you say to him -- to Ms. Heard, you say to Ms. Heard, "I love him so much, but he needs help, and I don't have all the information to help alone."

282 1:08:15

MR. ROTTENBORN: Do you see that?

283 1:08:17

MR. CHEW: Objection, Your Honor. This is all hearsay.

284 1:08:18

THE COURT: I'll allow that question. That's fine.

285 1:08:21

CHRISTI DEMBROWSKI: I do see that.

286 1:08:22

MR. ROTTENBORN: And what did you mean when you said "he needs help"?

287 1:08:31

CHRISTI DEMBROWSKI: I don't recall the actual timing of it, but I wanted to help him with the - that medication that he was on. That, I know. And I know that I wanted to be able to be helpful to him and his wife because they were arguing all the time.

288 1:08:52

MR. ROTTENBORN: And I believe you testified earlier that you didn't actually have concerns about your brother's dependence on drugs, right?

289 1:08:57

CHRISTI DEMBROWSKI: No, I said I did have about the medication.

290 1:09:01

MR. ROTTENBORN: Just the pain pills?

291 1:09:02

CHRISTI DEMBROWSKI: It was the pain pills.

292 1:09:03

MR. ROTTENBORN: Nothing else?

293 1:09:04

CHRISTI DEMBROWSKI: I didn't have concerns.

294 1:09:06

MR. ROTTENBORN: So when you said, "He needs help," that's what you were referring to, that you believed that your brother needed help with pills? Objection, Your Honor. This has been asked and answered several times.

295 1:09:35

MR. ROTTENBORN: May I approach, Your Honor?

296 1:09:43

THE COURT: All right.

297

[STAGE DIRECTION]: (Sidebar.)

298 1:09:45

MR. ROTTENBORN: It's not hearsay.

299 1:09:48

THE COURT: He said asked and answered. Which it has been. She's not giving you the O answer that you want, I understand that. He objected asked and answered.

300 1:09:51

MR. ROTTENBORN: It's also --

301 1:09:54

THE COURT: It's a prior inconsistent statement, I understand that. That's why I'm letting her testify to it, but it doesn't come into evidence. Make sense?

302 1:09:57

MR. ROTTENBORN: Makes sense.

303 1:10:00

MR. CHEW: He has a tendency just to beat the horse.

304 1:10:03

THE COURT: If you object to asked and answered, then I will either sustain or overrule.

305 1:10:06

THE COURT: Okay. Thank you, Your Honor.

306 1:10:09

MR. ROTTENBORN: Thank you.

307

[STAGE DIRECTION]: (Open court.)

308 1:10:12

MR. ROTTENBORN: Heather, can you, please, pull up the pages ending in 934. Start with that, please.

309 1:10:22

THE COURT: Actually, let's not. Let's go to 936.

310 1:10:30

THE COURT: Just for the record, this. is still in Exhibit 234, it's just Bates-stamped IO page 936; is that correct?

311 1:10:41

MR. ROTTENBORN: Yes, Your Honor.

312 1:10:45

THE COURT: Okay.

313 1:10:46

MR. ROTTENBORN: Ms. Dembrowski, do you see the message that you sent to Amber, three down, where you say "He's going to see the doctor in the morning," with three exclamation points?

314 1:10:56
315 1:10:58

MR. ROTTENBORN: Tell me what you remember about that. When you said "he," you're referring to your brother, right?

316 1:11:06

MR. ROTTENBORN: A. Yes.

317 1:11:07

MR. ROTTENBORN: And by "doctor," you meant an addiction y y doctor; is that right?

318 1:11:15

CHRISTI DEMBROWSKI: I believe I would have meant Dr. Kipper.

319 1:11:19

MR. ROTTENBORN: Okay. And what was -- you'd agree that it's fairly rare to get an appointment for a doctor the next day, right?

320 1:11:25

MR. CHEW: Objection. Calls for speculation.

321 1:11:31

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

322 1:11:34

CHRISTI DEMBROWSKI: I don't know that it's rare to get an appointment the next day.

323 1:11:37

MR. ROTTENBORN: Well, Dr. Kipper wasn't an emergency room doctor, right?

324 1:11:41
325 1:11:42

MR. ROTTENBORN: So what was so urgent about your brother's need to see a doctor that he was going to see Dr. Kipper the next morning, when you texted this at 7:35 p.m.?

326 1:11:52

CHRISTI DEMBROWSKI: I don't know that it was urgent. I think I was happy that he was going to see the doctor.

327 1:11:56

MR. ROTTENBORN: And you're happy he was going to see the doctor because you thought he'd finally realized the problem that his drug addiction was having on himself and others, correct? That's why you were happy, right?

328 1:12:08

CHRISTI DEMBROWSKI: I was happy he was going to see the doctor because I was concerned about the pain medication he was on.

329 1:12:13

MR. ROTTENBORN: And you were concerned about what that pain medication did to your brother, right?

330 1:12:17
331 1:12:17

MR. ROTTENBORN: You were concerned about the effect that had on his life, right?

332 1:12:21

CHRISTI DEMBROWSKI: I was concerned about him.

333 1:12:22

MR. ROTTENBORN: And you were concerned about the effect that that drug addiction had on other relationships in his life as well, correct?

334 1:12:26

MR. CHEW: Your Honor. Asked and answered.

335 1:12:30

MR. ROTTENBORN: I'm going through.

336 1:12:33

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

337 1:12:34

MR. CHEW: It has been consistent statements.

338 1:12:36

MR. ROTTENBORN: You can answer.

339 1:12:37

CHRISTI DEMBROWSKI: I didn't see anything that was happening, necessarily, in life to be concerned about others' needs. It was him I was concerned about.

340 1:12:45

MR. ROTTENBORN: So your testimony today is that you didn't see any effect that your brother's drug problem was having on anyone else other than him?

341 1:12:54

CHRISTI DEMBROWSKI: My concern was him. I wasn't focused on anything beyond that.

342 1:12:58

MR. ROTTENBORN: Right. You weren't concerned about the effect that it could be having on anyone else? Is that your testimony?

343 1:13:06

CHRISTI DEMBROWSKI: Again, my concern was him.

344 1:13:14

MR. ROTTENBORN: Can you pull up page 937, please.

345 1:13:27

MR. ROTTENBORN: And when you sent Ms. Heard the text at the top of the page at 9:20 p.m. on May 25th, 2014, and you said "I just meant I will help in getting him help," what did that mean?

346 1:13:50

CHRISTI DEMBROWSKI: It's help from Dr. Kipper, I believe.

347 1:13:54

MR. ROTTENBORN: You were referring to getting your brother help for his drug addictions, correct?

348 1:13:59

CHRISTI DEMBROWSKI: I was referring to getting him help with the medication that he was on.

349 1:14:04

MR. ROTTENBORN: And if you go to page 938, please.

350 1:14:13

MR. ROTTENBORN: When you told Amber, at the bottom of that page, at 10:26 p.m., "I think you need to tell him you are scared and you can't deal'" what did you mean by that? "I think you need to tell him you are scared and you can't deal'" what did you mean by that?

351 1:14:22

MR. CHEW: Objection. Hearsay.

352 1:14:30

MR. ROTTENBORN: I'm asking her what she meant with one of her statements. It's no different from the statement I just asked her about.

353 1:14:34

MR. CHEW: Your Honor, it's hearsay--

354 1:14:37

THE COURT: I'm just not sure what the prior inconsistent statement would be for this.

355 1:14:41

MR. ROTTENBORN: Well, that she's testified that all of Amber's concerns were overblown.

356 1:14:46

MR. CHEW: Your Honor, may we approach?

357 1:14:50

THE COURT: Okay.

358

[STAGE DIRECTION]: (Sidebar.)

359 1:14:55

MR. CHEW: Your Honor, this is not a prior inconsistent statement.

360 1:14:59

MR. ROTTENBORN: She testified that all of Amber's concerns were overblown, and here she is telling her, I think you need to tell him you're scared. This is the last question I'm going to ask her and then I will move on from the document.

361 1:15:04

MR. CHEW: Just because it's the last question doesn't make it appropriate.

362 1:15:08

THE COURT: I'm going to sustain the objection.

363 1:15:13
364

[STAGE DIRECTION]: (Open court.)

365

[SECTION HEADER]: BY MR. ROTTENBORN:

366 1:15:17

MR. ROTTENBORN: So, Ms. Dembrowski, concerning your concerns regarding your brother's drug abuse, you were concerned for your brother and your brother only?

367 1:15:21

CHRISTI DEMBROWSKI: I was concerned for my brother, yes.

368 1:15:23

MR. ROTTENBORN: And only your brother; is that right?

369 1:15:27

CHRISTI DEMBROWSKI: My brother was my focus.

370 1:15:32

MR. ROTTENBORN: Now, you -- in your capacity as his personal manager, you were often apprised of your brother's performance on movie sets, right?

371 1:15:40

MR. CHEW: Objection. Hearsay.9

372 1:15:48

MR. ROTTENBORN: Did you have occasion to communicate with studios, for example, about movies that your brother was shooting?

373 1:15:56
374 1:15:56

MR. ROTTENBORN: And studio executives could feel free to contact you about your brother's work?

375 1:16:03

CHRISTI DEMBROWSKI: Yes, they mostly contacted the agents.

376 1:16:06

MR. ROTTENBORN: And who was the agent at the time?

377 1:16:07
378 1:16:09

MR. ROTTENBORN: Is that Tracey Jacobs?

379 1:16:10

MR. ROTTENBORN: And your brother, Mr. Depp, fired Ms. Jacobs in or around 2017; is that right?

380 1:16:15

CHRISTI DEMBROWSKI: I don't recall when.

381 1:16:17

MR. ROTTENBORN: How long was Ms. Jacobs his agent?

382 1:16:22

CHRISTI DEMBROWSKI: 20-something years.

383 1:16:24

MR. ROTTENBORN: And he fired Ms. Jacobs at some point, right?

384 1:16:28
385 1:16:29

MR. ROTTENBORN: After his divorce from Amber?

386 1:16:32

CHRISTI DEMBROWSKI: I don't recall exactly when he fired her.

387 1:16:33

MR. ROTTENBORN: Do you recall whether it was before or after he divorced Amber?

388 1:16:39

CHRISTI DEMBROWSKI: I don't recall. Sorry.

389 1:16:40

MR. ROTTENBORN: But in any event, you had frequent communications with Ms. Jacobs about your brother's work, correct?

390 1:16:47

CHRISTI DEMBROWSKI: Excuse me. Yeah.

391 1:16:50

MR. ROTTENBORN: And you, in your capacity as his manager, it came to your attention that he was late to movie sets, correct?

392 1:16:56

MR. CHEW: Objection. Lack of foundation. Hearsay.

393 1:17:02

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

394 1:17:08

MR. ROTTENBORN: You testified that you had contact, p frequent contact with Ms. Jacobs, his agent, right?

395 1:17:14
396 1:17:15

MR. ROTTENBORN: And that contact included when he was shooting movies?

397 1:17:21
398 1:17:22

MR. ROTTENBORN: And that contact included communications relating to his conduct on set?

399 1:17:25

MR. CHEW: Objection. Lack of foundation.

400 1:17:29

MR. ROTTENBORN: I'm laying foundation.

401 1:17:32

THE COURT: Sounds like your foundation is going to be based on hearsay. Which is what we're getting to. If you can lay a foundation without being based on hearsay.

402 1:17:40

MR. ROTTENBORN: Did you have information about your brother being late to sets of movie shoots?

403 1:17:49

CHRISTI DEMBROWSKI: Would that be if I was physically there, is that what you're asking?

404 1:17:56

MR. ROTTENBORN: Your Honor, first, I'd ask you to instruct Mr. Chew not to shake his head, nod his head to the witness. That's inappropriate.

405 1:17:58

THE COURT: All right.

406 1:18:00

MR. CHEW: I'm not shaking or nodding to the witness.

407 1:18:02

THE COURT: All right.

408 1:18:04

MR. ROTTENBORN: Well, he was.

409 1:18:06

THE COURT: Well, I'll keep a lookout for that.

410 1:18:07

MR. CHEW: And I resent the implications.

411 1:18:09

THE COURT: Thank you.

412 1:18:11

MR. ROTTENBORN: Ms. Dembrowski, your brother told you himself that he was late to movie shoots, didn't he?

413 1:18:13

MR. CHEW: Objection. Hearsay.

414 1:18:16

MR. ROTTENBORN: Party admission.

415 1:18:18

THE COURT: I'll allow that.

416 1:18:22

CHRISTI DEMBROWSKI: I don't think he came to me and said "I'm late to movie shoots," no.

417 1:18:26

MR. ROTTENBORN: You learned, from your brother, that he was late to movie shoots, correct?

418 1:18:30

MR. CHEW: Objection. Asked and answered.

419 1:18:34

CHRISTI DEMBROWSKI: I don't think he would have come to me and talk about it, no.

420 1:18:37

THE COURT: I'll allow it.

421 1:18:40

MR. ROTTENBORN: So you never had any communications with your brother about issues that he had being on time to movie sets? Is that your testimony?

422 1:18:52

CHRISTI DEMBROWSKI: A No. What I'm saying is, I worked with him for years, you know. There was never, really, a continuous topic of whether he was late to a movie set, him and I having a conversation.

423 1:19:06

MR. ROTTENBORN: He told you he bad been late to movie sets, correct?

424 1:19:08

MR. CHEW: Objection. Asked and answered.

425 1:19:10

THE COURT: I'll sustain the objection.

426 1:19:11

THE COURT: Next question, please.

427 1:19:12

MR. ROTTENBORN: Can you pull up 348, please.

428 1:19:36

MR. ROTTENBORN: If you can, can you blow it up so you can see the second email down, Heather.

429 1:19:45

MR. ROTTENBORN: And that second email down is an email from you to Tracey Jacobs on February 27th, 2015, right?

430 1:19:51

MR. CHEW: Objection. Hearsay.

431 1:19:58

THE COURT: I'll allow that question. Let's see where we go.

432 1:20:02

CHRISTI DEMBROWSKI: The second - all the way down in here.

433 1:20:05

MR. ROTTENBORN: The second one down from the top. Sent at 12:50.

434 1:20:11

CHRISTI DEMBROWSKI: Oh, sorry. Yes, that's from me to Tracey.

435 1:20:27

MR. ROTTENBORN: Okay. Now, in the second sentence of that email, you write "He told me one to one and a half hours, but not two. Yes, he was two and a half hours late one day and seven hours recently."

436 1:20:47

MR. ROTTENBORN: Do you see that?

437 1:20:49

CHRISTI DEMBROWSKI: I do see that.

438 1:20:51

MR. ROTTENBORN: And when you said "he told me," you're referring to your brother, Johnny Depp, admitting to you that he was late to movie sets, right?

439 1:20:58

CHRISTI DEMBROWSKI: I don't know that I'm referring to him,

440 1:21:01

MR. ROTTENBORN: In any event, it was a problem -- as his personal manager, you knew that it was a problem for the studios if he showed up late to set, right?

441 1:21:12

CHRISTI DEMBROWSKI: I knew that on this particular film, there were times when he was late to set.

442 1:21:19

MR. ROTTENBORN: You did know on this particular film?

443 1:21:20

CHRISTI DEMBROWSKI: On this particular film.

444 1:21:22

MR. ROTTENBORN: And this particular film is Pirates 5, correct?

445 1:21:25
446 1:21:26

MR. ROTTENBORN: Pirates of the Caribbean 5. And he was filming that in Australia, right?

447 1:21:31
448 1:21:31

MR. ROTTENBORN: And this email was sent on February 27th, 2015, right?

449 1:21:38
450 1:21:38

MR. ROTTENBORN: So, you knew that as he was filming Pirates of the Caribbean 5 in 2015, early 2015, that he had problems being late to the set, right?

451 1:21:51

CHRISTI DEMBROWSKI: I wouldn't call it problems being late to set, but he was occasionally late to set.

452 1:21:56

MR. ROTTENBORN: Late enough that Disney executives called you to discuss that, right?

453 1:21:59

MR. CHEW: Objection. Hearsay.

454 1:22:02

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

455 1:22:06

THE COURT: Next question.

456 1:22:07

MR. ROTTENBORN: And you knew that this wasn't the only movie that he had been late to set for, correct?

457 1:22:11

MR. CHEW: Objection. Lack of foundation.

458 1:22:15

MR. ROTTENBORN: She's testified about her close involvement in his personal affairs when he was shooting movies.

459 1:22:18

MR. CHEW: Still lack of foundation.

460 1:22:21

THE COURT: If you lay a foundation not based on hearsay. i 8

461 1:22:23

MR. ROTTENBORN: All right.

462 1:22:26

MR. ROTTENBORN: You talked to your brother when he was :filming each of the movies that he filmed, right?

463 1:22:31
464 1:22:32

MR. ROTTENBORN: Okay. And with respect to Pirates 5, he told you that he had been late to the set, right?

465 1:22:37

CHRISTI DEMBROWSKI: No, I don't recall him telling me he was late to set

466 1:22:40

MR. ROTTENBORN: Okay. So despite the fact when you say "he told me," you don't recall whether that was him or not?

467 1:22:45

CHRISTI DEMBROWSKI: I don't that - I don't know that the "he" in that refers to him IO

468 1:22:53

MR. ROTTENBORN: You were also, I believe, you testified yesterday, that you were closely involved in the financial aspects of your brother's life, right?

469 1:23:07

CHRISTI DEMBROWSKI: I was closely involved in speaking with the representatives, but I wasn't really closely involved in, you know, his financial world. That wasn't my thing.

470 1:23:17

MR. ROTTENBORN: And your brother, the income that he made from movies or other commercial opportunities that he had, that funded both him and it flowed -- and it came in through his companies, right? And then -- the money that your brother made came in through his companies, correct?

471 1:23:42

CHRISTI DEMBROWSKI: I don't really understand your question.

472 1:23:44

MR. ROTTENBORN: Well, you're the president of one of those companies, Infinitum Nihil, right?

473 1:23:47
474 1:23:47

MR. ROTTENBORN: So if your brother signs a movie contract, the money, is it paid directly to him or does it come in through a company that he owns?

475 1:23:57

CHRISTI DEMBROWSKI: Infinitum Nihil is completely a separate entity, so how he gets paid is - that's the business managers.

476 1:24:04

MR. ROTTENBORN: Okay. You were involved with discussions of opportunities that he had to shoot movies, correct?

477 1:24:13

CHRISTI DEMBROWSKI: Sometimes, yes.

478 1:24:14

MR. ROTTENBORN: Okay. And you were in close contact with others on Mr. Depp's team about opportunities that arose, right?

479 1:24:22
480 1:24:22

MR. ROTTENBORN: Okay. Including Tracey Jacobs?

481 1:24:24
482 1:24:24

MR. ROTTENBORN: His agent?

483 1:24:26
484 1:24:27

MR. ROTTENBORN: Including -- in fact, you would be in contact with studios directly as well, from time to time, right?

485 1:24:37
486 1:24:40

MR. ROTTENBORN: And Mr. Jacobs [sic] -- well, strike that.

487 1:24:46

MR. ROTTENBORN: In your capacity as his personal manager, you became aware of financial distress that your brother was in, correct, because you were familiar with his financial affairs, right?

488 1:25:01

CHRISTI DEMBROWSKI: I was somewhat familiar. That was - that was the other representatives' area.

489 1:25:07

MR. ROTTENBORN: Did you have occasion to become familiar with whether he was undergoing financial distress such that he needed to get movies, a certain number of movies a year?

490 1:25:21

CHRISTI DEMBROWSKI: Tracey had a certain number of - excuse me, a certain number of movies per year that she wanted him to do.

491 1:25:33

MR. ROTTENBORN: And the certain number of movies a year, to your understanding, the certain number of movies a year that your brother had to do was necessary to stave off financial distress, correct?

492 1:25:46

CHRISTI DEMBROWSKI: The certain number of movies per year, Tracey would push for a certain number of movies per year because it was beneficial to her.

493 1:25:57

MR. ROTTENBORN: That's the only reason she pushed for a certain number of movies a year?

494 1:25:59

CHRISTI DEMBROWSKI: That's the main reason Tracey would push for a certain number of movies per year, yes.

495 1:26:04

MR. ROTTENBORN: Not because it was beneficial to Mr. Depp?

496 1:26:06

CHRISTI DEMBROWSKI: If it was beneficial to Mr. Depp, then it was going to be beneficial to Tracey.

497 1:26:11

MR. ROTTENBORN: Just because it was beneficial to Tracey doesn't mean it wasn't beneficial to Mr. Depp or his companies, correct?

498 1:26:14

MR. CHEW: Objection. Asked and answered, Your Honor.

499 1:26:17

THE COURT: I'll sustain the objection.

500 1:26:21

THE COURT: Next question.

501 1:26:22

MR. ROTTENBORN: Now, at some point, you became aware when he was filming Pirates 5 in Australia, you became aware of an injury that he suffered to his finger, right?

502 1:26:33
503 1:26:35

MR. ROTTENBORN: And you were involved in trying to cover up how it happened, correct?

504 1:26:42

MR. CHEW: Objection. Lack of foundation.

505 1:26:48

THE COURT: I'll allow the question.

506 1:26:51

CHRISTI DEMBROWSKI: I'm not sure I understand the question.

507 1:26:53

MR. ROTTENBORN: You were involved in helping to cover up how the finger injury happened, right?

508 1:26:58

CHRISTI DEMBROWSKI: I don't understand "cover up."

509 1:27:04

MR. ROTTENBORN: You were involved in making sure that people on Mr. Depp's team didn't say how he hurt his hand, correct?

510 1:27:09

MR. CHEW: Objection. Lack of foundation.

511 1:27:15

THE COURT: I'll allow it, if she can answer it.

512 1:27:19

MR. ROTTENBORN: You can answer.

513 1:27:26

CHRISTI DEMBROWSKI: We certainly didn't want any press to know about it. So that's - you know, to keep it from that.

514 1:27:39

MR. ROTTENBORN: And because you didn't want any press to know about his finger injury, you told Mr. Depp's personal assistant to make sure that he wasn't -- to say that he wasn't sure how Mr. Depp hurt his hand, correct? You instructed him to say that?

515 1:27:59

CHRISTI DEMBROWSKI: If it was someone that I would be concerned that the word would get out to the press, I would have done that.

516 1:28:06

MR. ROTTENBORN: So, it was okay, to you, to tell people to lie to protect your brother, right?

517 1:28:16

CHRISTI DEMBROWSKI: It wasn't necessarily a lie. I didn't know how he hurt his finger, myself, at the time, because I'm pretty sure I know the time frame you're talking about, is when it first happened.

518 1:28:29

MR. ROTTENBORN: And you have no personal knowledge, to this day, of how he hurt his finger, correct, because you weren't there?

519 1:28:37

CHRISTI DEMBROWSKI: I wasn't there.

520 1:28:42

MR. ROTTENBORN: Heather, can you pull up Exhibit 210 redacted, please.

521 1:28:46

MR. ROTTENBORN: Your Honor, this is the exhibit we discussed yesterday. If the Court and Mr. Chew agree with the redactions, I would just like to publish it to the jury and admit it into evidence.

522 1:28:58

THE COURT: Well, if it's 210, it's already in evidence. That's the one you gave me this morning, correct? No, that's a different one.

523 1:29:05

MR. ROTTENBORN: Yeah, I think this was 11214.

524 1:29:07

THE COURT: I'm sorry, I got them backwards. This is 210?

525 1:29:10

MR. ROTTENBORN: And I believe that this is --

526 1:29:13

THE COURT: Follows.

527 1:29:15

MR. ROTTENBORN: It's just one page? Or it's two pages, I'm sorry. It's these two pages that we talked about yesterday.

528 1:29:22

THE COURT: All right.

529 1:29:22

THE COURT: Reserving your objections, are the redactions correct?

530 1:29:26

MR. CHEW: The redactions are correct. We'll reserve our objections.

531 1:29:31

THE COURT: All right. I will enter 214 into evidence over objections.

532 1:29:35

MR. ROTTENBORN: Permission to publish, Your Honor.

533 1:29:38

THE COURT: Yes, sir.

534 1:29:42

MR. ROTTENBORN: Thank you.

535 1:29:46

MR. ROTTENBORN: Can you blow that up, please.

536 1:29:56

MR. ROTTENBORN: So, Ms. Dembrowski, we discussed this a little bit yesterday. This is the text exchange between you and Ms. Heard on February 3rd, 2014, where Ms. Heard says "JD is on a bender."

537 1:30:09

MR. ROTTENBORN: And your response is "where are the kids," correct?

538 1:30:13
539 1:30:16

MR. ROTTENBORN: Scroll down, please. Let's go to the next page, please. Scroll down to the bottom, please.

540 1:30:33

MR. ROTTENBORN: And then you text Amber "worry about everything."

541 1:30:37

MR. ROTTENBORN: Is that right?

542 1:30:39

CHRISTI DEMBROWSKI: I wrote the words "worry about everything," it was myself. I was speaking about myself.

543 1:30:44

MR. ROTTENBORN: And you tell her "I don't love any of it," correct?

544 1:30:48
545 1:30:50

MR. CHEW: Your Honor, objection. Asked and answered.

546 1:30:51

THE COURT: Sustained. We did go through this yesterday.

547 1:30:52

THE COURT: Go ahead.

548 1:30:53

MR. ROTTENBORN: And two days later is when you sent your brother the text messages that said "stop booze, stop coke, stop pills," correct?

549 1:31:03

CHRISTI DEMBROWSKI: I'm not looking at it. I don't recall the timing of it.

550 1:31:10

MR. ROTTENBORN: Nothing further. Thank you.

551 1:31:11

THE COURT: All right. Redirect.

552 1:31:14

MR. CHEW: Yes. Yes, Your Honor. Bear with me.

553 1:31:17

THE COURT: Okay. Thank you.

554

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

555 1:31:23

MR. CHEW: Good morning, Ms. Dembrowski

556 1:31:32

CHRISTI DEMBROWSKI: Good morning.

557

MR. CHEW: During Mr. Rottenborn's examination,

559 1:31:41

MR. CHEW: You're not denying that Mr. Depp ever used alcohol or drugs, are you?

560 1:31:49

MR. CHEW: Objection Leading.

561 1:31:51

MR. CHEW: It's redirect, Your Honor.

562 1:31:52

THE COURT: That's still leading. I'll sustain as to leading. If you want to rephrase yarn- question

563 1:32:01

MR. CHEW: You also testified several times, in response to Mr. Rottenborn's questions, that Ms. Heard tends to say thing, in a more dramatic manner. Do you recall that testimony?

564 1:32:16
565 1:32:17

MR. CHEW: Why did you say that?

566 1:32:22

CHRISTI DEMBROWSKI: I've had my own interaction, one-on-one, with Ms. Heard, so I know - I know a bit about her personality. She would - you know, she would present information to me that was not necessarily information that was supported by everybody else that was around. And I've spent a lot of years working with my brother. We have a close team, we, you know, many years of trusted people helping, you know, make sure that everything in life, it works out and goes smoothly.

567 1:33:04

CHRISTI DEMBROWSKI: But all those people, where I would have a daily contact, whether it's about scheduling or just how the day's going, for all the years, those people never said the same thing.

568 1:33:16

MR. ROTTENBORN: Objection. Hearsay, Your Honor.

569 1:33:18

MR. CHEW: I think it was responsive to the question.

570 1:33:20

THE COURT: Well, I'll sustain the last sentence. Just the last sentence of it, that's all.

571 1:33:24

MR. CHEW: Understood, Your Honor.

572 1:33:28

MR. ROTTENBORN: The others as well.

573 1:33:28

MR. CHEW: I think it goes to state of mind rather than the truth.

574 1:33:31

THE COURT: I'll sustain the last sentence. I'm going to strike the last sentence, okay?

575 1:33:33

MR. CHEW: Thank you, Your Honor.

576 1:33:35

MR. CHEW: And do you recall your testimony yesterday, when you stated that after the phenomenal success of Pirates 1, one of the changes to Mr. Depp's, your brother's, personal life was there were a lot more people around him after that.

577 1:33:44
578 1:33:53

MR. CHEW: Do you recall that?

579 1:33:56
580 1:33:57

MR. CHEW: When Johnny and Ms. Heard became involved in a relationship, several years later, were there still several people -- were there still a lot of people around them --your brother, on a regular basis?

581 1:34:12
582 1:34:13

MR. CHEW: Who were those people?

583 1:34:14

CHRISTI DEMBROWSKI: He had assistants, he had security, he had, you know, property managers, people that helped at the house. He had quite a few people that were around all the time.

584 1:34:28

MR. CHEW: How often did you communicate with those people?

585 1:34:33

CHRISTI DEMBROWSKI: I communicated daily, not necessarily with each one of those people, but I communicated, pretty much, daily with people within the world, the circle.

586 1:34:44

MR. CHEW: Did any of those people ever raise the same concerns that Ms, Heard did?

587 1:34:50

MR. ROTTENBORN: Objection. Hearsay.

588 1:34:51

THE COURT: All right.

589 1:34:52

MR. CHEW: Again, it goes to state of mind.

590 1:34:54

THE COURT: I'll sustain the objection as to hearsay. Next question.

591 1:35:01

MR. CHEW: What, if any, concerns were expressed about Johnny's behavior when using alcohol?

592 1:35:11

MR. ROTTENBORN: Objection. Hearsay.

593 1:35:11

THE COURT: All right.

594 1:35:12

MR. CHEW: Again, it goes to state of mind.

595 1:35:13

THE COURT: I'll sustain the objection.

596 1:35:16

THE COURT: Next question.

597 1:35:17

MR. CHEW: Thank you, Your Honor, that's all I have.

598 1:35:18

THE COURT: All right. Is this witness subject to recall?

599 1:35:21

MR. CHEW: I do not believe so, Your Honor.

600 1:35:23

THE COURT: Is she subject to recall?

601 1:35:24

MR. ROTTENBORN: No, Your Honor.

602 1:35:25

THE COURT: All right. Ms. Dembrowski, you're free to go or you can stay in the courtroom, it's up to you, okay?

603 1:35:27

CHRISTI DEMBROWSKI: Thank you.

604 1:35:28

THE COURT: Thank you, ma'am.

605

MR. CHEW: Thank you very much.