Shannon Curry — Direct/Cross/Redirect
371 linesTHE COURT: All right. Your next witness.
MS. MEYERS: Your Honor, we're calling Dr. Shannon Curry.
THE COURT: Just give us a moment to move the TV. All right. Dr. Curry, Good morning, Mr. Dennison.
MR. DENNISON: Good morning, Your Honor. Plaintiff calls Shannon Curry, Dr. Shannon Curry.
THE COURT: You're under oath, so, please, have a seat, Doctor.
KATE MOSS: Good morning. SHANNON J. CURRY, PSY.D., MLS.C.P., having been previously sworn, was examined and testified as follows:
MR. DENNISON: Good morning, Dr. Curry.
DR. CURRY: Good morning.
MR. DENNISON: Can you remind the jury who you are and what you do? Sure. I'm Dr. Shannon Curry, I'm a clinical and forensic psychologist, and I'm here today to rebut the testimony that was provided by Dr. Hughes.
MR. DENNISON: Which of the opinions rendered by Dr. Hughes do you intend to rebut?
DR. CURRY: So, generally speaking, there are three main categories that I would like to talk about today. So, the first is that Dr. Hughes misrepresented the tests and the results that she utilized in her evaluation. She misrepresented my testing and the results that I obtained in my evaluation. And she communicated in a manner, provided testimony in a manner, that presented, essentially, her own opinions and the self-report of Ms. Heard as facts.
MR. DENNISON: Okay. The first category you talked about was the misrepresentation of her own test methods and results. What do you mean by that? So, Dr. Hughes used — she stated that she administered 12 tests. In actuality, she used — eight checklists, about half of those were symptom checklists, the other half were checklists about experiences that people can have with domestic violence. And those are not appropriate for forensic settings. They're easily exploited.
MR. DENNISON: Other issues that you intend to address relative to misrepresentation of those results? Yes, so, in addition to using these checklist measures, which are easily exploited in forensic context, they're developed for research and treatment only. She also stated that these checklists revealed things that they simply cannot reveal, especially in this context. And, let's see, she also misrepresented information, clear indications on several of the objective measures that she offered. And there were indications visible that Ms. Heard had essentially engaged in what we call response distortion.
MR. DENNISON: So clear indications of exaggeration on one of the measures that's specific to PTSD, clear minimization of symptoms intentional, on another more broad personality and psychopathology-based measure that she gave to Ms. Heard, which she did not acknowledge.
MR. DENNISON: Did you intend to address anything relative to the CAPS-5? I did. So Dr. Hughes administered the CAPS-5 about ten days after I did, almost two years after she initially tested Ms. Heard, and she did not administer the test appropriately. So she left major components blank. She didn't apply the scoring rules that are clearly outlined with the test. And yet, she diagnosed Heard -- Ms. Heard with PTSD based on that assessment.
MR. DENNISON: What about Dr. Hughes's use of the Personality Assessment Inventory? q A So, of the tests that Dr. Hughes administered, two would be considered -- of those 12, two would be considered what we would call forensically relevant instruments, meaning that ‘ they're objective enough, and they provide us with some information about how the examinee approached the test, that would be appropriate for this setting, where the examinee is going to have the natural incentive to present themselves in a way that benefits the outcome of their case. Now, on the PAI, there were clear indications that Ms.
MR. DENNISON: Heard was responding and obtained scores that's consistent with individuals who have a personality disorder, and there was also an indication that several scales, we call this a configuration, so you might have one main scale that you notice is elevated, and then you look for additional subscale information and get additional information on what could be elevating that scale. And there was a configuration that showed that even though Ms. Heard had moderately elevated one of the scales that can be associated with trauma, that elevation is better explained by childhood, or distant traumatic experiences, like the complex trauma Ms. Heard reported experiencing growing up. Q Okay. You said that Dr. Hughes utilized checklists that are not appropriate for forensic analysis?
DR. CURRY: Yes.
MR. DENNISON: Can you explain that?
DR. CURRY: Yes. So, as I said, in any sort of forensic context, whether it's a civil or criminal matter, a person who's being evaluated is going to have major incentive to present in a way that benefits the outcome of their case. So you always approach the examination, and I believe Dr. Hughes said
MR. DENNISON: How many tests were administered by Dr. Hughes?
DR. CURRY: She said that she administered 12 tests.
MR. DENNISON: How many of them were appropriate for forensic physical [sic] examination?
MR. DENNISON: Y Trial - Day 23 79 °° May 25, 2022 scales, similar to the one test that I administered, the MMPI, that tells us a Jot of nuanced information about the way the person approached the test. She also administered a malingering screen that:can be very, very useful, but not in this context. So it's called the Miller Forensic Assessment Symptom Test. It's a brief set of questions that you ask the examinee, and it's been shown by research to be extremely effective at identifying an examinee's attempt to fake a severe mental illness or psychosis.
MR. DENNISON: And psychosis is when somebody loses complete connection with reality. It's excellent for that purpose. It's actually been shown in research to not be effective at all for identifying a respondent's attempts to fake PTSD, anxiety, or mood disorders. The questions are just too odd for somebody who has the wherewithal to be trying to have PTSD to endorse. They see through it. So, she used that. That's a fine test, but not appropriate for this context. Of the various tests that she administered, how many were these checklists?
DR. CURRY: Eight of them.
MR. DENNISON: What are you talking about, specifically?
DR. CURRY: Okay. So I had mentioned that there were two main categories of checklists she used. The first is the symptom checklists, those included the Beck Depression Inventory, it's a brief inventory of items that, essentially, show all of the systems of depression that a person might have and rate which level of severity you have for each question. She also gave the Beck Anxiety Inventory, very similar, but just with questions about anxiety. She gave the Mood Disorder Questionnaire, which is a very brief, again, checklist. It shows symptoms of bipolar disorder.
DR. CURRY: Bipolar disorder is a mood disorder where you might have an extended manic episode and then a very extended depressive episode. And then she gave the Post-traumatic Stress Disorder Checklist, and that is a screening instrument only. It contains every single symptom of PTSD. So there's a secondary danger here too, when you think about it, given that PTSD is the most frequently feigned and claimed diagnosis. In civil courts, if you are handing somebody a checklist that has every single symptom of PTSD, you're essentially teaching them all the little nuances that we're looking for to get that diagnosis, So she gave that to Ms. Heard. Ms. Heard endorsed most of the items, and Dr.
DR. CURRY: Hughes diagnosed her with PTSD and substantiated that opinion by Ms. Heard's checking those items on the PCL-5.
MR. DENNISON: Were there another group of checklists that Dr. Hughes used?
DR. CURRY: Yes. So she also -- oh, and I forgot one in the last, because I don't think of it as one. But previously I've explained, and I do not expect you to remember, it's called the Life Events Checklist, which is just an inventory of experiences a person may have gone through that are traumatic. Dr. Hughes also used that, and that's appropriate to use before the clinician administered PTSD scale, the gold standard, CAPS-5; however, she administered this long ago, before she gave the CAPS-5. Now, going on to the second group, there were three checklists that she gave that are specific to abuse.
DR. CURRY: And the first she gave, Danger Assessment Scale, was actually developed for use by nursing staff in an emergency room setting, specifically for female victims of intimate partner violence. The purpose of this is important because our forensic ethics, our psychology ethics talk a lot about relevance. Is the test relevant to the purpose? And the Danger Assessment Scale, its original purpose is completely different.
DR. CURRY: This was developed to show high-risk factors for dangerousness and pretty much to help a female, who's in an extremely abusive partnership, who is in the emergency room with extreme injuries to stop rationalizing, PLANE' Trial - Day 23 32 43094 to May 25, 2022 because if she has to check off all the things that have happened that year that have been dangerous, does he own a gun? Has he -- you know, I won't go into all of them. But the more she checks off, the more likely it is that she is in imminent danger and then accept resources offered by the hospital and social work to protect her. That was the purpose of this scale.
DR. CURRY: It was never intended to be used as a retrospective measure to look back in time and find out whether abuse was occurring based on one person's report used later in a litigation. She also gave the Conflict Tactic Scale Revised, the second edition. Similarly, this scale was developed for research purposes, to research family violence. Again, there's no control for exaggeration or minimizing. It was just given to research participants, anonymously, so that we could get data on the prevalence of abuse and how the abusive dynamics work.
DR. CURRY: And on that, there's 39 questions where the respondent indicates, essentially, certain abusive behaviors they may have engaged in, and there are 39 where they indicate behaviors their partner might have engaged in. And obviously, you can understand in a forensic setting, the respondent is likely to put a very minimal amount of behaviors they engaged in and then extremely increase the number of behaviors their partner might have. And then lastly, the Abusive Behaviors Observation Checklist was the third checklist she gave. This one has not been - there's no known research, even on its effectiveness, for what it was developed.
DR. CURRY: It's a theoretical, very brief checklist that was meant to be used for therapy, where an individual who had experienced domestic violence could essentially read through some of the behaviors that constitute violence that they might not have been aware of. And if those behaviors apply to them or if some of those coping strategies were ones they utilized, they would check that off, and then they have a way to talk about it because now it's been put to words. Again, this is similarly problematic. If you're in a civil litigation, the person's motivated to have the results be consistent with a claim or an allegation of intimate partner violence, and an allegation that they've been severely harmed, then they could simply just check off more. And not only that, but checklists like this one, specifically, give a lot of nuanced information about what clinicians might be looking for when they're assessing whether violence was present, whether the person's self-report is consistent with a genuine self-report of having been victimized.
DR. CURRY: They're given all that information that we might be looking for.
MR. DENNISON: Can you talk, specifically, about Dr. Hughes's use of the, I think you called it the PCL-5?
DR. CURRY: Yes. So the PCL-5 is the Post-traumatic Stress Disorder Checklist. This is different, not to be confused with the CAPS-5, which I talked about previously as being the gold standard. The PCL-5 was developed by the National Center of PTSD. It's intended for treatment. So if I were, for instance, working with a service member who I know had been in combat, I would probably give this as a standard with my intake before we do the diagnostic interview. It kind of gives me a read on how somebody who's there for treatment who I assume can be taken at their word because if they give us correct information, they're going to get an appropriate treatment, and if they give us incorrect, they might not get the treatment they need.
DR. CURRY: So I would give this checklist to them, and then if they recognize some of those symptoms of PTSD, they can check it off. And that would probably indicate to me that I need to, then, do the next step, if they're checking off more items than not. I would probably decide to administer the Clinician Administered PTSD scale, that gold standard interview, to find out more about the diagnosis.
MR. DENNISON: The last thing is what everybody refers to as the CAPS-5? May 25, 2022 Allright. What about -- well, you talked about forensic use. What do you mean by that?
DR. CURRY: So, when I'm talking about forensic evaluation, that's an evaluation that doesn't -- isn't done for therapy or treatment. It's specifically to assist the fact finder, to assist the judge or the jury in the court by providing information about the psychological status about an individual. And that's an important delineation, too. We are not psychologists -- I wish we were mind readers, I wish we had a crystal ball and find out whether intimate partner violence occurred and looked back in the past. But it's nothing like that. Really, it's a lot less interesting.
DR. CURRY: We look at data, we have to control for those response biases, and then we also, looking at functioning, which is really the bottom line of the assessment. Did the person have a change in functioning from before the alleged trauma, or, in this case, the alleged IPV, to after? Is there a declining in the way they go about their life?
MS. BREDEHOFT: Objection, Your Honor. May we approach?
THE COURT: All right.
THE COURT: Yes, ma'am.
MS. BREDEHOFT: All right. She's testifying outside the scope of her designation, now, Your Honor. Dr. -- and I elicited this from her, and you may recall this before. The only 1] thing she's testifying to is whether Ms. Heard has PTSD or not. She is not -- she's explicitly testifying -- or she is explicitly not testifying about whether she suffered IPV or not, whether she was a perpetrator, whether she was a victim, whether she suffered any domestic abuse.
MS. BREDEHOFT: All those things, she's already testified and admitted those are not part of her opinion, and now she's clearly trying to tell the jury about IPV and assessing whether somebody has suffered from IPV, and that's completely outside the scope of her designation.
MR. DENNISON: Your Honor, I respectfully disagree with that analysis. This is the root of the report. There are multiple pages in this report, pages 18 through -- through 23.
THE COURT: Uh-huh.
MR. DENNISON: That reflect each of the tests I've been asking about and why they -- why Dr. Curry believes they were administered incorrectly.
MS. BREDEHOFT: And I didn't object on those. But she's now testifying about whether somebody suffered from IPV or not, and that is absolutely outside the scope.
MR. DENNISON: First of all, I don't think she --
THE COURT: I'm not sure that's where she was going,
MS. BREDEHOFT: She just says explicitly, she said when you're trying to figure 20.out whether somebody is suffering from IPV or not.
THE COURT: Not that she's going to give an opinion to that. I think she's just discussing,
MR. DENNISON: Well, she's certainly not giving an opinion to that.
MS. BREDEHOFT: That's outside the scope. She cannot address whether somebody suffers from IPV or not. She's already admitted that outside --
THE COURT: Well, I don't think she's | giving an opinion about whether somebody. I think — she's talking about IPV.
MS. BREDEHOFT: She can't talk about IPV. She's confined to PTSD, and she cannot -- and she has said she did not try to evaluate for IPV. I even elicited it from her testimony earlier, nothing about IPV or domestic abuse.
MR. DENNISON: Your Honor, she specifically identified that nothing about IPV, other than the test given by Dr. Hughes, were done inappropriately.
MS. BREDEHOFT: And I did not object when she was testifying to those, Your Honor. But now she went into - she's talking about whether you have a crystal ball, whether you can determine whether somebody suffered from IPV or not, and that's outside the scope. It's not anywhere in any of her testimony.
MR. DENNISON: I believe the answer was in relation to the use of the checklist.
THE COURT: Overrule the objection. Make sure it's within the tests, okay?
MR. DENNISON: Thank you.
MS. BREDEHOFT: Okay.
MR. DENNISON: Dr. Curry, let's look back at some of those domestic violence checklists that you were talking about.
DR. CURRY: Okay. 17. Q. And did you see any problem with the use of those?
DR. CURRY: Yes.
MR. DENNISON: What problems did you see?
DR. CURRY: Well, first of all, they shouldn't be used. so we do have professional standards that used, so we do have professional standards that require that we utilize instruments that are relevant and appropriate for the particular setting, and that we substantiate our opinions based `on data that is reliable from tested, accurate, reliable tests for the purpose. So there's that. It's inconsistent with the ethics. And, essentially, they just shouldn't be used. They don't provide us with the robust information that would be expected in such a high-stake setting. 12. Q. Allright. Would you have expected Dr. Hughes to comment on the limitations of the checklists she was using?
DR. CURRY: Yes. So, first of all, Dr. Hughes provided opinions based on these checklists, so she referenced, especially, the Danger Assessment Scale several times throughout her testimony, stating that Ms. Heard was in a very dangerous situation. We also have an ethical guideline in the professional standard, as well, that indicate that whenever there is a question about the reliability and validity, and in psychology, we use the term "validity" to talk about accuracy. Any of the methods that we're using to collect data, we clearly communicate not only that there are limitations to our opinions, but we also need to provide the fact finder with information about - what the potential implications or impact could actually be.
DR. CURRY: So, for instance, if we use a scale that's idiosyncratic for the purpose, but we would first need to explain why we made that decision, not follow standard procedures, and then we would need to explain the use of this scale might introduce some potential exaggeration of this symptom and, so, I'm trying to control for that, that way, but that was one of the limitations of my opinion. You have to make it very clear. Transparency is really at the center of good science, in general.
MR. DENNISON: = You talked a little bit about ignoring response distortion. What is response distortion?
DR. CURRY: Response distortion is a term that sneaks generally, about examining, approaching a OT test, and providing answers that are either exaggerated or minimized, but in some way, an inaccurate representation of the current mental status or their experience.
MR. DENNISON: What tests do you believe that Dr. Hughes failed to acknowledge response distortion on?
DR. CURRY: So, she administered the Personality Assessment Inventory, which is similar to the test that I gave, the MMPI-2, it's that general broadband measure of psychopathology symptoms and personality traits. It includes several scales that are very good at detecting either exaggeration, minimization, or even trying to claim that you have unusually good qualities. On that test, there were clear indicators that Ms. Heard, very similar to the way she approached my MMPI, engaged in defensiveness.
DR. CURRY: And, in fact, there's a function that you can look at, so you have that main scale elevation, call it positive impression, which was elevated, and then because we want to make sure that somebody isn't elevating PLANE' to May 25, 2022 that scale just because they have such well-being, there are additional configurations of scales that you can look at to find out what's going on. And so, the catchall discriminate function is the name of one of these configurations, these equations that are done, and she was highly elevated on that. In fact, that elevation tells me that, no, this isn't accidental. This isn't because she's just doing so well in life that she has an extremely, extremely low amount of problems.
DR. CURRY: No, this is an intentional over reporting — I'm sorry, an intentional effort to minimize any appearance of having problems.
MR. DENNISON: Now, you may have addressed this, but there was a reference to malingering?
DR. CURRY: Yes, so what's interesting about Ms. Heard's approach to different tests is that it seems to be influenced by what we call the face validity of questions on the test. So if a test looks like it's measuring PTSD, you see exaggeration on her validity scales. If the test has less face value questions, for instance, the Personality Assessment, which Dr. Hughes administered, the MMPI-2, which I administered, where she can't quite figure out what the questions are asking, they seem really benign in general, on those, you see extreme defensiveness, minimization of any potential pathology, essentially presenting herself as perfect and free of any mental illness or personality disorder. But on the Trauma Symptom Inventory, which Dr.
DR. CURRY: Hughes administered, that was the one that I previously indicated, for ease of explanation, when the test results come out for how the person approaches the test, that test itself prints it as a percentage. And there's a really excellent scale for finding out if a person is exaggerating their symptoms of PTSD. It's called the Atypical Response Scale, and the TSI-2 is the revised version of this test, and that scale was improved this time around to really try to be a clean indication of is this person exaggerating.
DR. CURRY: And it puts - has questions in the test that are so unusual; they might seem like PTSD, but even the most severe cases of PTSD don't have these symptoms. And so, somebody who's intentionally trying to exaggerate PTSD, or possibly unintentionally, but nonetheless, who is exaggerating it, is likely to endorse these items, even though they're not real PTSD symptoms. Ms. Heard worked so hard on this that even if there is -- although, Dr.
DR. CURRY: Hughes directly said there tends to be a negative skew when people have the high levels of distress that's associated with PTSD, so sometimes people score high levels even when they do have PTSD, she scored so high that that is effectively ruled out as a possibility.
MR. DENNISON: Okay. What about Dr. Hughes's administration and use of the CAPS-5?
DR. CURRY: Okay. So Dr. Hughes had diagnosed Ms. Heard with PTSD back in 2019, when she began testing her. It wasn't until two years later, more than two years later, ten days after I administered the CAPS-5 in Ms. Heard that Dr. Hughes had an impromptu evaluation session remotely with Ms. Heard and administered the CAPS-5. She had previously diagnosed PTSD without using what we consider to be the gold standard PTSD diagnostic interview. And, again, when we're doing a forensic evaluation, it is an important responsibility, and part of our ethics and professional standards are that we document everything to allow for transparency and full judicial scrutiny. And Dr. Hughes administered it incorrectly. She left huge sections, very relevant sections, blank.
DR. CURRY: There's no way to understand why she scored it as high as she did, based on the information that's provided. You're essentially supposed to notate the examinee's responses as verbatim as possible to explain your reasoning in applying their scoring procedure. It's a standardized test, and if you don't follow those standard procedures, it's completely invalid. Not only that, but after -- it looks as though Dr. Hughes further invalidated it by trying to show that she had assessed for the childhood trauma impact, and she had said that she went back PLANE] G10 to May 25, 2022 712 and asked the childhood question. But you can't do.that. If you're assessing for two separate periods of one's life to find out relatedness to PTSD, you do two separate CAPS interviews, period. You don't create your own question system. That is non-standard administration. of the test, and it invalidates it.
MR. DENNISON: Allright. You also mentioned, with respect to the PAI or the Personality Assessment Inventory, that Dr. Hughes failed to mention some element. What did she fail to mention?
DR. CURRY: Oh, okay. So on the Personality Assessment Inventory, so first she failed to mention that there were clear indications of response distortion. She also failed to mention that Ms. Heard's score, her score profile against their main scores, she did elevate a score for the borderline personality disorder sort of section, but that, in and of itself, would not indicate a diagnosis. However, the configuration of the scores overall is consistent with that, and in fact, it's one of the diagnostic suggestions given by the test itself. And then, also, there's a configuration around Ms. Heard's trauma responses around that particular test, which demonstrates that it is more likely that those symptoms were reported in relation to something in the distant childhood. It's more consistent with childhood chronic abuse than present circumstances or recent circumstances.
MR. DENNISON: Okay. I think you said, in addition to the issues with her own testing, Dr. Hughes misrepresented your results? 13. A_ She did.
MR. DENNISON: Can you tell us how? 15. A_ So, I would say the main issue is that she said that Ms. Heard obtained a norma! profile on my MMPI-2.
MR. DENNISON: Allright. How do you disagree with Dr. Hughes relative to the profile? Okay. So the profile was not normal. So Ms. Heard already had subtle elevations, just by the - the test by itself, as it came out, there were several elevations, but they were elevation that if the validity scales hadn't been as elevated as they were, you might have said this person has some traits, but this isn't necessarily at the level of a true pathology. However, Ms. Heard elevated a scale that essentially is a defensiveness scale on this test. And when you're giving this test, you always are mindful of different norms or groups who may have similar profiles, and there are certain groups of litigants who tend to elevate this scale as well. So, I had that in mind. However, Ms.
MR. DENNISON: Heard elevated this so much that it was far beyond the mean for the litigants that are known to have the highest level of this scale, this defensiveness scale. And when this scale is elevated to the level that is, you automatically understand that it is very likely that those clinical scales be — I Keep doing this because I'm seeing it in my head, it looks like sort of an ECT, sort of these peaks you see on a graph. And when you see these peaks, and you have this huge peak over here for the defensiveness scale, what you know is that these peaks are artificially lowered or suppressed based on respondent being so defensive. They still detected what's likely there for her, but it's not as high as it should be. So you make an adjustment. And the recommendation is that anything at 60 or above, we call it a T score of or above, is considered significant. Ms. Heard's were already over 60, some were quite higher than that. And then you see a very clear profile. And that was how I got that. I mentioned a 3-6 code type.
MR. DENNISON: Now, the test does some of its own correction, also, for some of the scores, but not the ones that are the main code type. With the test correction, she had a 1-3-6 code type, which is very similar.
MR. DENNISON: What is a 3-6 code type?
DR. CURRY: A 3-6 code type is something that has been researched and found to be highly correlated or problematic of certain behavioral tendencies and personality traits. And the traits with the 3-6 code type tend to be marked by a lot of externalization blame, a lot of denial about one's own personal faults, intentional or not intentional. Just extreme denial. Hostility that is strongly controlled and suppressed. The person may not even realize how hostile they are, but family members, those closest to them are very likely to report that they lose their temper and when they lose their temper, explodes.
DR. CURRY: We have sort of what we call a cookbook for these code types, which will provide you with all the information that's been researched to be associated with them. And our cookbook actually states that that 3-6 profile, specifically, tends to be associated with cruel and ruthless behavior, particularly to those who they perceive as less powerful to them and subordinates,
MR. DENNISON: Describe for the jury the review process that you went through relative to the MMPI.
DR. CURRY: So, I conducted a very methodical analysis of the scores; I do this for every test. I also did it when I was reviewing Dr. Hughes's scores. So what you haven't seen, it's in discovery, is that I created a 25-page outline just of her scores, with -- and it's sort of a table. So I'll put the score, I'll do it in sections so that I can understand different groupings, different research studies, and I start with looking at all the validity scales.
DR. CURRY: So I put in the score, I — and I'll even color the table to show me if it's kind of in the high zone, moderate zone, or low, and then if it's low, is it a significant low score or is it just low, so it doesn't mean anything. And then, on the right side, I put all the research data that I found on this particular scale score. And so, I start with the validity scales, the way the person approached the test, and then I go down to, essentially, we call these the first factors. So their overall sense of well-being and how well they cope. On this, actually, Ms.
DR. CURRY: Heard's, she endorsed scores were -- endorsed items that were opposite of PTSD. So, really, saying that she feels free of distress and that she views herself very well. So then I go down to control, self-control, loss of control, coping abilities, and I put in the scores that are associated with that, the research and the test development. Then I go down to clinical and personality pathology, and I look at all the scores that are significant there, first with the top level main scores, then with all the different subscores. Again, citing the research, the meaning, the level of elevation and what that means. And then, I do comparison with different research groups. So for Ms.
DR. CURRY: Heard, I did a section that looked at all sorts of different scores that have been implicated with the PTSD presentation to see if any of those were consistent. I can't remember how many there were. I think I put 13 on there, but I could be wrong. But I believe that there was only one that could even be -- in some research, sometimes associated with it, but it was general anxiety, which turned out to be more trait specific. I looked at the scores that are typical of women with IPV. Those were not consistent, at all, with those. I looked at the scores that are consistent with people who are frequently in litigation. Hers actually were very highly correlated with those. That tends to be also consistent with a 3-6 code type. The reason for that is believed to be that they tend to perceive themselves often as victims who need to avenge wrongs.
MR. DENNISON: Were there other results you believed Dr. Hughes to have misrepresented, the TSI-2?
DR. CURRY: Unusual items that are not consistent with PTSD. And even though, when some people are experiencing PTSD, their distress level is so high that they'll engage in what we call a cry for help, and they may sometimes exaggerate distress. Again, when you're looking at scores as high as Ms.
DR. CURRY: Heard's and then you're not seeing indications of PTSD in the more subtle tests, where she doesn't know what she's endorsing, it's good evidence that her over-endorsement on that one test is because of the reason the scale was made, to detect exaggeration and feigning of symptoms.
MR. DENNISON: Is this the test that resulted in the 98 percentile score?
DR. CURRY: Yes. Yes, on that atypical response scale.
MR. DENNISON: And what is the 98 percentile score represent?
DR. CURRY: Scored more of those unusual items that are not consistent with PTSD than 98 percent of people who had ever taken the test.
MR. DENNISON: Does that relate to this concept you talked about before called feigning?
DR. CURRY: Yes.
MR. DENNISON: What is feigning again?
DR. CURRY: Feigning is essentially exaggerating symptoms of a disorder.
MR. DENNISON: I think the third thing you indicated you were going to talk about is self-reports and personal opinion as facts. What are you talking about there?
DR. CURRY: Ethics talk about, especially with the specialty guidelines of forensic. psychology, the responsibility we have to distinguish between data then inferences we're making from that data, what the data can mean, sort of like those tables I do. I put the data, the inferences based on the research, and then what my ultimate opinion is integrating all of that data. And it's very important that we clarify that to the fact finders, to the judge, the jury.
DR. CURRY: That's our responsibility, that we do not cloak personal: opinions or the self-report of an examinee as an expert fact or somehow scientifically based when it is just a personal opinion or a self-report of an examinee. examinee tells you during the interview. most? instances of alleged IPV. and there's also an
MR. DENNISON: What do you mean-by self-report?
DR. CURRY: The self-report is essentially what the
MR. DENNISON: Okay. When did Dr. Hughes do this
DR. CURRY: She did this most when describing instances of alleged IPV, and there's also an issue there because one of our ethics also discusses the importance of relevance and withholding, essentially constraining our testimony to the data and not including private information, personal information that unnecessarily compromises the dignity of any of the litigants. She provided a lot of what was Ms. Heard's report to her, the allegations of abuse, when describing Mr. Depp, who she had not examined, when describing Mr. Depp's behavior, his motivations.
DR. CURRY: I believe she used the word "obsessive jealousy" quite a few times, talked about Ms. Heard being in a highly dangerous situation. These are simply things that we cannot detect based on testing and a psychological evaluation. We have to evaluate the person, we have to get consent, and we can only describe an individual, not whether or not IPV has occurred. And we certainly shouldn't go into explicit details about sexual encounters or other things that are highly prejudicial, shocking, and hard to forget.
MR. DENNISON: Dr. Hughes says that Ms. Heard has PTSD. Do you agree?
DR. CURRY: I do not.
MR. DENNISON: Why not?
DR. CURRY: The results of my multi-method comprehensive evaluation, based on carefully selected researched relevant test instruments, based on comparing those instruments to Ms. Heard's self-report, observing Ms. Heard's behavior over 12 direct hours of assessment, reviewing copious notes from prior therapists who indicated symptoms in their notes, reviewing the notes of Nurse Falati, previously Nurse Boerum, who spent, I believe, at one point, almost 152 months with Ms. Heard, daily. Reviewing the notes of her treating providers. Let's see. All of the legal documents and discovery.
DR. CURRY: There was no evidence of PTSD.
MR. DENNISON: How is evidence of PTSD generally exhibited? So, really, the bottom line in a forensic psychological evaluation is a change in functioning. That's what we're looking for. Again, I said we don't have a crystal ball. We're not wizards, we can't get into somebody's head. What we're looking for, were there identifiable changes in the way the person engaged in their world, were they able to keep their job? PTSD is an extremely disabling diagnosis. When a person has true PTSD, it is difficult for them to work. You'll see unemployment, job loss. It causes extreme levels of distress and impairment.
MR. DENNISON: There's divorce, there's isolation and estrangement from children, from family members. Extreme alcohol abuse, often a string of sudden DUIs, when the person never had any before. They become homebound, they can't go to the store. They're certainly not going to events. They're not having success in their film career, usually. They're not exercising every day, pursuing their hobbies, being avid readers, obtaining level 3 Sommelier training, having dinner parties with friends, speaking to public groups. Those are just indications of very high functioning, and when you're looking for a decrease in functioning over time, that is inconsistent with that decrease.
MR. DENNISON: What about Dr. Hughes's suggestion that Mr. Waldman's statements served as a trigger for Ms. Heard's PTSD?
MS. BREDEHOFT: Objection. Your Honor, may we approach?
THE COURT: All right.
MS. BREDEHOFT: Very explicitly, she is not testifying about -- and I elicited it in trial testimony early, she is not testifying about : whether Ms. Heard suffered any PTSD as a result of defamatory statements. Explicitly testified she is not. She's not -- it's not anywhere in her report. It's not in her rebuttal report, and she admitted that on the stand, that she is not addressing that, was not asked to address that.
MR. DENNISON: Her answer, and it's the last answer of this inquiry, is there is no PTSD to be triggered.
MS. BREDEHOFT: Still, he's asking -- he's trying to connect it to the defamation. You know, she can say that there's no PTSD, but she cannot connect it to the defamation. She did not disclose that opinion.
THE COURT: She's going to bring up the a defamation ts the issue.
MR. DENNISON: All it literally says is it brings it into the current time frame. There's no effort to connect it other than saying there was no PTSD to be triggered.
THE COURT: I think you can state there is no PTSD to be triggered. I get that.
MS. BREDEHOFT: I disagree, Your Honor. He's bringing up the defamation and letting her give an opinion about whether she has PTSD as a result of the defamation, and she explicitly said she's not speaking to that.
THE COURT: Okay. You cannot ask the defamation, but he can say no PTSD has been triggered.
MR. DENNISON: I can do it and not talk PLANE! to ‘May 25, 2022 about it.
THE COURT: Ai right.
MS. BREDEHOFT: Thank you, Your Honor.
MR. DENNISON: Dr. Hughes suggested that perhaps Ms. Heard's PTSD was somehow triggered. What's your view on that?
DR. CURRY: J would say that it can't be triggered if PTSD isn't present.
MR. DENNISON: Thank you very much, Doctor,
THE COURT: All right. Cross-examination.
MS. BREDEHOFT: Thank you, Your Honor.
MS. BREDEHOFT: Dr. Cuny, I just want to make sure that we all remember, you're not board certified, correct?
DR. CURRY: No, I'I'm not.
MS. BREDEHOFT: Okay, And you've been licensed for how long?
DR. CURRY: I've been licensed for ten years.
MS. BREDEHOFT: Okay. And you are being paid by Mr. Depp's legal team to be here, correct? Yes. How much have you charged so far? IT actually don't know. Over a hundred thousand? I truly don't know. I don't do my own Over 200,000? I don't know. Over 300,000? That would be way too much, but I do not know.
MS. BREDEHOFT: Okay. Now, just so that we all remember, you had dinner at Mr. Depp's house for three to four hours with Mr. Depp, Mr. Waldman, Mr. Chew, and Ms. Vasquez, correct?
DR. CURRY: I was interviewed. I asked if there was anything I could eat because at about three hours, I started to get hungry. Mr. Depp, then, offered to order takeout for the entire team.
MS. BREDEHOFT: So you had dinner at Mr. Depp's home with Mr. Waldman, Mr. Chew, Ms. Vasquez, and Mr. Depp, correct?
DR. CURRY: Yes,
MS. BREDEHOFT: And you had drinks as well, correct? AT actually don't know. I do remember that there were drinks.
MS. BREDEHOFT: Do you recall testifying earlier that you did have a drink, a mule something?
DR. CURRY: No,I remember testifying that there might have been a mule, a Moscow mule.
MS. BREDEHOFT: Thank you. We didn't have animals there as well, right?
DR. CURRY: No animals.
MS. BREDEHOFT: That's good to know. You talked about transparency. I want to make sure. You had several designations, expert designations and reports in this case, correct? correct?
DR. CURRY: Yes.
MS. BREDEHOFT: And in not one of them did you disclose that you had dinner and drinks at Mr. Depp's house for three to four hours with Mr. Waldman, Mr. Chew, and Ms. Vasquez; is that correct?
DR. CURRY: Ms. Bredehoft, you're mischaracterizing what occurred.
MS. BREDEHOFT: Dr. Curry, please answer the question. Not once did you disclose this in any of your reports?
DR. CURRY: I did not disclose that I was interviewed because that's standard procedure.
MS. BREDEHOFT: But it's true that you have never gone to a client's house to be interviewed for an expert witness position, correct?
DR. CURRY: Yes. Because I never had a client that was essentially homebound because of their celebrity status.
MS. BREDEHOFT: Allright. And you talked to Mr. Depp for three to four hours before taking on the role of assessing Ms. Heard and deciding whether she was suffering from any distress, correct?
DR. CURRY: I did not talk to Mr. Depp. I was talking to his legal team. He was there to observe.
MS. BREDEHOFT: He was present for the three or four hours?
DR. CURRY: Yes.
MS. BREDEHOFT: And are you saying now he just stayed silent and said nothing all day?
DR. CURRY: I don't recall what he did or didn't do. I was answering questions.
MS. BREDEHOFT: Okay. Now, your expertise here is limited to whether Amber Heard suffers from PTSD currently; is that correct?
DR. CURRY: Yes. I was tasked with conducting evaluation to determine.
MS. BREDEHOFT: Dr. Curry, you know, we're on very, very strict time limitations because we promised to get this case to the jury, so I'd really appreciate it if you just answer my question rather than trying to go further. Okay. Thank you very much. Now, after you did have the dinner, you, then, provided the designation in February of 2021, in which you said, and this is long before you ever saw Amber Heard, correct, you said that Amber "exhibits patterns of behavior that are consistent with co-occurring Cluster B personality disorder traits, especially borderline personality disorder." Correct? No. No? We went through this before. We did. And that was on the designation; was it I told you last time that I did not write that.
MS. BREDEHOFT: Okay. And you don't know who did, on the.legal team, correct?
DR. CURRY: No. QQ. Okay. And then I also asked you, as you might recall, whether you listened to the audio recording in which Mr. Depp taunted Amber Heard that she had a borderline personality disorder. Do you recall that?
DR. CURRY: Recall you asking me that, yes.
MS. BREDEHOFT: Did you recall listening to that audiotape?
DR. CURRY: I don't recall Mr. Depp taunting Ms. Heard. I do recall that he, at some point, suggested she might have that diagnosis. 12. Q Okay. And that was back in these audiotapes, back when they were together, correct?
DR. CURRY: Yes.
MS. BREDEHOFT: Okay. Now, you've never before been asked to testify or’serve as an expert witness with respect to someone who has bipolar disorder, correct?
DR. CURRY: No, as I previously stated, that's not true.
MS. BREDEHOFT: All right. Let's get your deposition.
MS. BREDEHOFT: Your Honor, my extra --
MS. BREDEHOFT: Your Honor, my extra copies were all distributed before. Does everybody have those?
THE COURT: Not up here anymore.
MS. BREDEHOFT: Okay. Then my apologies, but I'm going to go --
MR. DENNISON: Your Honor, may we approach?
THE COURT: Okay.
THE COURT: I think we've cleaned up since then,
MS. BREDEHOFT: My apologies on that one. I thought they were still here.
MR. DENNISON: I get it. Are we going to rehash the entire previous cross-examination?
MS. BREDEHOFT: She'just testified to © bipolar.
MR. DENNISON: It's her time.
THE COURT: It's her cross-examination.
MR. DENNISON: Right.
THE COURT: I don't have mine.
MS. BREDEHOFT: Should I just show it PLANE oN AAS to May 25, 2022 to her Would that be the best way to do it
MR. DENNISON: I'm perfectly fine if she approaches the witness and shows her the deposition.
THE COURT: Right. Just remember you need a microphone, so don't start talking.
MS. BREDEHOFT: Okay. Thank you for the reminder.
MR. DENNISON: Thank you.
MS. BREDEHOFT: Thank you.
DR. CURRY: Yes.
MS. BREDEHOFT: And you were under oath at that time, correct?
DR. CURRY: Yes.
MS. BREDEHOFT: And the question I just showed on page 207 line 5 Have you ever been asked to testify or serve as an expert with respect to whether someone has bipolar disorder And your answer at that time was no correct
DR. CURRY: Yes. [had forgotten a case.
MS. BREDEHOFT: Okay. And have you ever been asked to testify whether anyone has behavioral or characterological conduct that suggests they may — be an IPV perpetrator?
DR. CURRY: I can't — I may have. It's difficult, after about 250 cases, it's difficult to remember specifically.
MS. BREDEHOFT: Allright. And have you ever been qualified as an expert in the area of IPV?
DR. CURRY: No. ; 13. Q Have you ever been.qualified to testify as an expert in domestic abuse or violence?
DR. CURRY: Violence —
MS. BREDEHOFT: Domestic abuse or violence? 17. A Yes. That's been a.component of testimony.
MS. BREDEHOFT: May I approach, Your Honor?
THE COURT: All right.
MS. BREDEHOFT: We're still on the same.
MS. BREDEHOFT: Line 16 on page 207, "Have you ever been qualified as an expert in the area of IPV?" Your answer, on line 20, was no, under oath, correct? Then the next question, "Have you ever been qualified to testify as an expert in domestic abuse or violence?" And it goes into page 208, line 4, the answer, then, under oath, was no. Now, you would agree that the literature is quite clear that trauma-based symptoms, such as PTSD, are complex; PTSD has symptoms that overlap with borderline personality disorder and histrionic personality disorder, correct?
DR. CURRY: Yes. 17. Q And you would agree that it's important to use valid and reliable measures for an accurate diagnosis, correct?
DR. CURRY: Absolutely.
MS. BREDEHOFT: Okay. You chose, however, not to 949 administer the structured clinical interview to administer the structured clinical interview to DSM Personality Disorders, the SCID; is that correct?
DR. CURRY: That's correct.
MS. BREDEHOFT: Would you agree that that is a state-of-the-art structured clinical interview?
DR. CURRY: Not for a forensic evaluation of this sophisticated examinee.
MS. BREDEHOFT: But to determine if a personality disorder is present?
DR. CURRY: No, not in this setting.
MS. BREDEHOFT: You don't agree with that?
DR. CURRY: I do not.
MS. BREDEHOFT: You don't agree that that is the gold standard assessment for reliable, accurate psychiatric diagnosis?
DR. CURRY: It's a good one but, for treatments that are (indiscernible).
MS. BREDEHOFT: Now, did Ms. Heard -- you said you talked about you read all of the treatment records, right?
DR. CURRY: Yes.
MS. BREDEHOFT: Okay. Do you recall reading the May 25, 2022 treatment records for the psychologist Bonnie Jacobs, who saw Amber Heard over five years?
DR. CURRY: I do.
MS. BREDEHOFT: And did you see anything in Bonnie Jacobs' notes over five years in which she ‘diagnosed Ms. Heard with borderline personality or histrionic personality disorder?
DR. CURRY: No.
MS. BREDEHOFT: Now, you also saw the notes of Dr. Connell Cowan, right, you even attended his deposition, correct?
DR. CURRY: Yes.
MS. BREDEHOFT: He saw Amber for, roughly, two years, he was part of Dr. Kipper connection, right?
DR. CURRY: Ut-huh.
MS. BREDEHOFT: Correct?
DR. CURRY: Yes.
MS. BREDEHOFT: Okay. Did you see anything in Dr. Cowan's notes and did he say, in his deposition, that he diagnosed Amber Heard with borderline personality disorder or histrionic personality disorder?
DR. CURRY: Saw the symptoms clearly delineated throughout his notes and his deposition. He does not use diagnoses, so he would not have diagnosed her.
MS. BREDEHOFT: He said specifically, in his deposition, he did not diagnose her with that, correct?
DR. CURRY: Yes. And he also specifically stated that he does not use diagnoses.
MS. BREDEHOFT: Allright. And you also have seen Dr. Banks, Dr. Amy Banks, the psychiatrist, her deposition, correct? 13. A Yes —not her deposition, I reviewed her notes and the transcript.
MS. BREDEHOFT: Did Dr. Anderson diagnoses Ms. Heard with borderline personality disorder or histrionic personality disorder?
DR. CURRY: I don't believe she provided any diagnosis, and she was a couples therapist.
MS. BREDEHOFT: Now, you said quite a bit about Dawn Hughes. Do you remember how many years of experience Dawn Hughes has in IPV and domestic IT abuse and violence?
DR. CURRY: I know it's quite a bit.
MS. BREDEHOFT: Extensive. And she is board certified, correct?
DR. CURRY: Yes, she is. Q_ And she spent 29 hours of examination Yes.
MS. BREDEHOFT: And she admitted -- and she interviewed her therapists, Bonnie Jacobs and Connell Cowan, correct? A Yes. Q And she also interviewed Amber's late mother? A Yes. And she administered 12 different tests over the period of that time, correct?
DR. CURRY: Well, as I said, the majority of those were checklists, which are inappropriate in the forensic setting. But she administered 12 different tests, correct?
DR. CURRY: If you want to qualify them as tests, sure.
MS. BREDEHOFT: And so, you disregard -- no, I'm not even going to say that. Okay. Let's go to the CAPS-5 and PTSD. Now, you assessed Ms. Heard's traumas in her life, correct?
DR. CURRY: Yes. I did give her an instrument to assess for any trauma exposure throughout the entire life-span.
MS. BREDEHOFT: Yes, that's fine. And you wrote that Ms. Heard's exposure to a traumatic event, namely one of the sexual assaults by Mr. Depp, more than satisfied this requirement; did you not write that in your notes? A That is not what I wrote in my notes. Do you have my notes, so I can look at them?
MS. BREDEHOFT: You administered a structured clinical interview based on that trauma, correct? A Not exactly. It's not quite right.
MS. BREDEHOFT: Now, Dr. Hughes administered a full intimate partner violence assessment, correct?
DR. CURRY: That's not a psychological assessment. We can't assess for intimate partner violence. That's an event.
MS. BREDEHOFT: Dr. Hughes administered a full intimate partner violence assessment, right?
DR. CURRY: She stated that, and that's actually something I'm rebutting today.
MS. BREDEHOFT: And you reviewed her psychological testing?
DR. CURRY: I sure did, yes. Q And are you aware that in September 2019, Ms. Heard had a trauma-based symptom on many of those valid tests?
DR. CURRY: Can you be a little bit more specific? _ Those valid tests? Which tests are you talking about?
MS. BREDEHOFT: Do you have a recollection of that, September 2019?
DR. CURRY: She administered-all her testing on September 2019, so I'm not sure — except for the CAPS-5, which was ten days after mine, 2021.
MS. BREDEHOFT: Now, Dr. Hughes clinically evaluated those symptoms and established that Ms. Heard does have PTSD from the totality of the intimate partner violence by Mr. Depp, correct?
DR. CURRY: That's what she stated, yes.
MS. BREDEHOFT: Okay. Now, Dr. Anderson's clinical notes that said Amber --
MR. DENNISON: Objection. Hearsay.
MS. BREDEHOFT: I haven't even asked the question yet, Your Honor.
THE COURT: Are you going to read her notes?
MS. BREDEHOFT: No, no. Actually, I wasn't going to read her notes. I was going to ask a particular question.
THE COURT: Okay.
MS. BREDEHOFT: You talked about danger. Do you recall that in your testimony?
DR. CURRY: Yes.
MS. BREDEHOFT: Allright. Now, if a patient comes to you, as a couples therapist, with two black eyes, would you assess that there may be a potential danger there? Sure. Did you read Dr. Anderson's notes? - I believe I did. Now, you administered the Minnesota Multiphasic Personality Inventory 2, the MMPI-2. Do you recall that?
DR. CURRY: Yes.
MS. BREDEHOFT: And you used that to determine whether Amber had PTSD, right?
DR. CURRY: Not by itself. But it was a part of the data. Q Okay. And in the 60 to 70 T-score range for that test, which "deliberate attempts to mislead are uncommon"; isn't that correct?
DR. CURRY: Sorry, could you repeat that?
MS. BREDEHOFT: In the T score section of that, which assesses deliberate attempts to mislead, do you recall -- she scored a 60 on that test, correct?
DR. CURRY: So there are multiple T scores for each scale, so I'm not sure which scale you're talking about. Q Okay. Well, we can deal with that
MS. BREDEHOFT: = Okay. Well, we can deal with that later. So you would agree that you need to follow ethics and best practices in forensic psychology, correct?
DR. CURRY: Yes.
MS. BREDEHOFT: Okay. And the two primary sources are the American Psychological Association Ethical Principles and Professional Code of Conduct, right? <A Uh-huh. Q_ And the American Psychological Association's Specialty -Guidelines for Forensic Psychology, correct?
DR. CURRY: Yes. Q_. And special guidelines 1.02 states that forensic practitioners "strive for accuracy, impartiality, fairness, and independence," correct? <A Yes.
MS. BREDEHOFT: And specialty guidelines 1.03 states that you have to avoid a conflict of interest? Correct? Now, in addition to not listing the four hours you spent with Mr. Depp, Mr. Waldman, Mr. Chew, and Ms. Vasquez, you also did not list that you spent an hour with Dr. Shaw, correct?
DR. CURRY: That's incorrect.
MS. BREDEHOFT: Are you saying that the designation said that you --
DR. CURRY: During my deposition, I also clarified this. I didn't spend an hour with Dr. Shaw. There was an introduction with the attorneys present on Zoom. My time on that call was less than 30 minutes.
MS. BREDEHOFT: But you still didn't disclose it, did you, in your report?
DR. CURRY: No.
MS. BREDEHOFT: Okay. Now, you are not -- you have not been asked to testify about Ms. Heard's behavior in the context of her relationship with Mr. Depp; is that correct?
DR. CURRY: I was asked to testify about somebody's behavioral mental status, in general co that can behavioral mental status, in general, so that can include behavior involved in the relationship with Mr. Depp, but not specifically.
MS. BREDEHOFT: Can you pull up day 10 of the trial testimony, at page 2710. 2710, lines 12 through 13.
MR. DENNISON: May we approach?
THE COURT: All right.
THE COURT: Okay.
MR. DENNISON: I think the request I heard, may we pull up some trial testimony and I'm--
MS. BREDEHOFT: I'I'm not going to show it to the jury.
MR. DENNISON: Okay. That's the issue.
THE COURT: This is to refresh?
MS. BREDEHOFT: This is what I should have done in deposition. It would have made it go a lot faster.
MR. DENNISON: That was why I asked.
THE COURT: Okay.
MS. BREDEHOFT: So, Dr. Curry, this is your testimony from day ten in this case, and if you can look at page 2710, line 13. Now is it -- my question was, "Now is it your testimony, under oath, today that you have not been asked to testify concerning Ms. Heard's behavior in the context of her relationship with Mr. Depp, including any abuse?" And your answer, under oath, to this jury that day was that's correct. -
DR. CURRY: Yes.
MS. BREDEHOFT: Is that correct? 13. A_ I still agree with that question.
MS. BREDEHOFT: Allright. And you have not made any determinations, including any opinions, that Ms. Heard abused Mr. Depp or Mr. Depp abused Ms. Heard, correct?
DR. CURRY: Correct.
MS. BREDEHOFT: Okay. And in fact, you've said that's outside the scope, correct? <A Yes, of psychology. And you cannot testify whether Ms. Heard suffered any emotional distress as a result of any of the defamatory comments that she has alleged Mr. Waldman made through Mr. Depp or Mr. Depp made through Mr. Waldman, correct?
MR. DENNISON: Objection, Your Honor.
DR. CURRY: Do you want me to read my response?
MS. BREDEHOFT: Sure.
THE COURT: ‘Objection.
DR. CURRY: I'm sorry, Your Honor.
THE COURT: That's okay. What was the objection?
MR. DENNISON: That's the question she wouldn't let me ask.
THE COURT: Well, it opens it up for redirect.
MR. DENNISON: Yeah.
MS. BREDEHOFT: Well, she's going to say what I can testify is there's no indication of a decline in psychological functioning since she's been with Mr. Depp. I'll withdraw that. May 25, 2022
THE COURT: Withdrawn.
MS. BREDEHOFT: Now, you have not rendered any opinion as to whether Amber Heard exhibits patterns of behavior that would suggest her allegations of abuse against Mr. Depp are false; would you agree?
DR. CURRY: No-—TI:mean, yes, I would agree with that. = Q > Thank you. And you have not -- no, that's all right.
MS. BREDEHOFT: That's all I've got. No further questions.
THE COURT: Allright. Redirect.
MR. DENNISON: You were asked about the SCID.
DR. CURRY: Yes.
MR. DENNISON: > Whats that? 399 A It's a structured clinical interview.
DR. CURRY: It's a structured clinical interview. It's for rendering a diagnosis. It's best for treatment because you're asking direct questions of the examinee and about symptoms. So if you have an examinee who has a tendency to minimize, you're not going to get much information.
MR. DENNISON: Why didn't you use it?
DR. CURRY: Because, well, first of all, I had a limited amount of time for my evaluation, and I already had to use — just to complete the interview was extremely time consuming, and I had to even restructure it into handouts so that I could keep Ms. Heard on track. I determined, based on that -- so this is where you would make an interference. Because J was having difficulty getting direct answers to my questions from Ms.
DR. CURRY: Heard, I had determined that creating forms of those questions would be a better use of the time, which it was, and then J further deduced that adding on the structured clinical interview would probably be unproductive, given that J had limited time to use the best, most reliable methods for getting information at that time.
MR. DENNISON: You were asked about the APA Specialty Guidelines.
DR. CURRY: Yes.
MR. DENNISON: Specifically, 1.02 --
DR. CURRY: Yes.
MR. DENNISON: And 1.03?
DR. CURRY: Yes.
MR. DENNISON: Have you complied with it?
DR. CURRY: I have.
MR. DENNISON: No further questions.
DR. CURRY: Thank you.
THE COURT: Thank you, Dr. Curry. You're free to go. Thank you, ma'am. Allright. Ladies and gentlemen, let's go ahead and take our morning recess for 15 minutes. Do not discuss the case, and do not do any outside research, okay?
DR. CURRY: That's fine.