Kate James — Direct/Cross/Redirect
923 linesCOURT BAILIFF: All rise.
THE COURT: Good morning.
THE COURT: All right. The first thing I want to say is I get a call from my mother last night, and my mother-in-law, saying, "Why did you have your phone on the bench?" So I want to clear everything up. That was not my phone. That was a call through the computer system because I guess we have an open line to remote witnesses, so it came through the computer system Jamie says it never happened before, came through the computer system and she hung up on it. So just for the record, that was not my phone.
THE COURT: So I don't need that kind of grief from my mother, all right?
THE COURT: Okay. All right. So I think before the jury comes out, we do have one issue with exhibits 2 -- Exhibit 548.
MS. BREDEHOFT: It was plaintiff's exhibit.
THE COURT: Plaintiff's Exhibit 548, okay.
THE COURT: So you had offered it to come into evidence.
MS. BREDEHOFT: Yeah.
THE COURT: And I know there was an objection there was a lot of hearsay on it. And so is there a redacted copy for me? Or is that something you haven't worked through?
THE COURT: That's fine, Mr. Chew. I think it was her witness, but that's fine.
MS. BREDEHOFT: It was plaintiff's exhibit, just so we're clear.
THE COURT: I know it was their exhibit, but you're offering it, and so if you're offering it, you have to redact it to basically -- I think it says two.
MS. BREDEHOFT: I wanted to make sure that in fact, I was going to bring that up right away this morning, I wasn't sure of the court's ruling, so I didn't know what --
THE COURT: Well, I just wanted to make sure. I know that.
MS. LECAROZ: I think we need to work out the details on that, Your Honor.
THE COURT: Okay. If you could work out the details so you owe me one exhibit, so we'll get that at some point today, right? Or even, I guess; tomorrow when I see you guys, that's fine.
MS. BREDEHOFT: I think we can do it today.
THE COURT: Okay. Perfect. All right. Anything else for me before the jury? Mr. Rottenborn?
MR. ROTTENBORN: Just one brief matter, Your Honor. May we approach?
THE COURT: Yes. That's fine.
MR. ROTTENBORN: I just want to kind of clarify the 48-hour rule that we had agreed to with respect to the witnesses.
THE COURT: Okay. For witnesses?
MR. ROTTENBORN: So 48 hours ago, they sent us an email saying that they anticipated Kate James, Gina Deuters, Laurel Anderson, and Sean Bett. Yesterday afternoon, or yesterday around lunch, they said, "Given how quickly we're working through the witnesses, we want to maybe add Kipper and Lloyd." No issue with that, since, obviously, we want to get through this trial.
THE COURT: We've already gone through those depositions, right?
MR. ROTTENBORN: So I emailed them and I asked for clarification, and I said, "Do you mean those two in addition? Or were you planning on -- to the four you were planning tomorrow?"
MR. ROTTENBORN: And yesterday at whenever, this afternoon these are in addition. Just this morning, they said, Oh, well, we're not going to do Sean Bett until Monday, and we're going to replace him with Dr. Kipper.
MR. ROTTENBORN: And I just want to get clarification. I mean, if they're going to say they have more time to prepare for Sean Bett. But it's more complex than that because there's a deposition designation. We have to have notice to fight over the exhibits that are going to come in.
THE COURT: Right.
MR. ROTTENBORN: There's some gamesmanship in them telling me yesterday afternoon at 5:00 p.m, "These are in addition," 12 and then today saying, "No. By the way, we're going to take out one of the people in the middle of the day, and it's going to be a live witness."
MR. ROTTENBORN: So I just wanted to raise that with Your Honor.
THE COURT: Well, I understand your concerns. But, you know, trials are very fluid. And I think 48 is helpful for everybody, I think, and I think as long as, as soon as you know -- and I think this will be for your side too --
THE COURT: Well, I understand that. That's a little bit beside the point. I get the feeling.
MR. ROTTENBORN: I think the problem was trying to confirm yesterday afternoon. And it's fine for today.
THE COURT: Okay.
MR. ROTTENBORN: I just wanted to make sure that we're all clear, that --
THE COURT: Right. You're going to do --
MS. VASQUEZ: We're going to do our very best.
THE COURT: Very best. Okay.
MS. VASQUEZ: It's hard, really.
THE COURT: Okay.
MR. ROTTENBORN: Thank you, Your Honor.
THE COURT: Thank you.
THE COURT: Okay. Are we ready for the jury?
THE COURT: Okay.
THE COURT: Good morning, ladies and gentlemen.
THE COURT: THE JURY: Good morning.
THE COURT: Your next witness.
THE COURT: Okay. By video. I wish I would have known that two seconds earlier. Can you get the screen up? I like to get the screen up before -- we usually try to get the screen up before, because of that, the sound, but we'll get it up for you.
MS. VASQUEZ: One moment, Your Honor, there's some issues.
THE COURT: All right.
MR. ROTTENBORN: Good morning, Ms. James. Can you please say your full name.
KATE JAMES: My name is Katherine Olwyn James.
MR. ROTTENBORN: What's your current address?
MR. ROTTENBORN: Have you ever spoken with Ms. Vasquez before today?
KATE JAMES: Yes.
MR. ROTTENBORN: When?
KATE JAMES: I don't recall.
MR. ROTTENBORN: What was the substance of that conversation?
KATE JAMES: I don't recall.
MR. ROTTENBORN: Is it in the past month?
KATE JAMES: No.
MR. ROTTENBORN: Is it in the past year?
KATE JAMES: Yes.
MR. ROTTENBORN: Did you talk about this case?
KATE JAMES: No.
MR. ROTTENBORN: What did you talk about?
KATE JAMES: I don't recall.
MR. ROTTENBORN: If you don't recall, how can you recall that you didn't discuss this case?
MR. ROTTENBORN: Have you discussed the case or the U.K. litigation with Mr. Waldman?
KATE JAMES: I just - yes, I discussed the U.K case with Mr. Waldman.
MR. ROTTENBORN: What did you discuss about the U.K. case with Mr. Waldman?
MR. NADELHAFT: Your Honor, can we stop IO this, please?
THE COURT: Okay. Can you pause, please. You can -- there you go. Do you want to approach?
MR. ROTTENBORN: Sure.
THE COURT: I'm not sure.
MR. ROTTENBORN: This doesn't have all the testimony that Your Honor let in. This is biased testimony that we --
THE COURT: Hold on. Hold on. Okay.
MR. ROTTENBORN: Sorry. Your Honor let in this testimony that goes to bias, and they didn't put it in the video.
MS. VASQUEZ: We sent it to , and we always -- the videos are sent to both sides.
THE COURT: Did you review this video ahead of time?
MR. ROTTENBORN: I didn't. I mean, they're the ones responsible for preparing it. I mean, I would ask that this be at least read for the jury by --
THE COURT: That's fine. Any objection to that?
MS. VASQUEZ: No, of course not.
THE COURT: But, I mean, both sides need to get the --
MR. ROTTENBORN: We will do our best to try to confirm, but, I mean --
MS. VASQUEZ: We didn't do anything. We sent you the transcripts. We sent both sides the transcript.
THE COURT: Okay. Okay.
THE COURT: Do you want to read that now? Or would you like to wait?
MR. ROTTENBORN: Yes.
THE COURT: Okay. All right. And if you see any other issues, let me know.
MR. ROTTENBORN: Okay. How would you like us to read it?
THE COURT: I will just tell the jury that there are additional parts of the deposition that you're going to read into the record.
THE COURT: Is that okay if you read it in?
MR. ROTTENBORN: Yeah. And do you want -- because this came in too. So you want me to read up to there? I think your counter.
MS. VASQUEZ: Okay. Sure. That's fine. Thank you.
THE COURT: Sure. Okay.
MR. ROTTENBORN: Thank you, Your Honor.
THE COURT: Ladies and gentlemen, in addition to the video deposition, there are some extra statements that this witness made that aren't part of the video but is part of her testimony. So Mr. Rottenborn is just going to read those into the record and for you as well, okay?
MR. ROTTENBORN: QUESTION: Have you IO spoken with Adam Waldman before?
MR. ROTTENBORN: ANSWER: Yes.
MR. ROTTENBORN: QUESTION: When was the last time you spoke with him?
MR. ROTTENBORN: ANSWER: I don't recall.
MR. ROTTENBORN: QUESTION: How many times have you spoken with him?
MR. ROTTENBORN: ANSWER: I would say somewhere around ten times total.
MR. ROTTENBORN: QUESTION: Have you spoken with him in 2022?
MR. ROTTENBORN: ANSWER: Yes.
MR. ROTTENBORN: QUESTION: What was the substance of that conversation? ANSWER: Friendly banter. QUESTION: About what?
MR. ROTTENBORN: ANSWER: Nothing to do with the case at all.
MR. ROTTENBORN: QUESTION: What was it about?
MR. ROTTENBORN: ANSWER: We had gotten to know each other, and, you know, I was on vacation, said "Happy new year." That's it.
MR. ROTTENBORN: QUESTION: Did you call him? Or did he call you?
MR. ROTTENBORN: ANSWER: I didn't call him.
MR. ROTTENBORN: QUESTION: Did you text him?
MR. ROTTENBORN: ANSWER: I sent a message saying, "Happy new year" to a lot of my :friends.
MR. ROTTENBORN: QUESTION: Over text?
MR. ROTTENBORN: ANSWER: Yes.
THE COURT: All right. Thank you, sir. All right. You can continue with the video.
MR. ROTTENBORN: Did Mr. Waldman assist you in preparing your witness statements for the U.K. litigation?
KATE JAMES: No.
MR. ROTTENBORN: Did you exchange drafts of those statements with Mr. Waldman?
KATE JAMES: No.
MR. ROTTENBORN: Who did you send those drafts to?
KATE JAMES: Schillings.
MR. ROTTENBORN: Is every word in those witness statements words that you drafted?
KATE JAMES: Yes.
MR. ROTTENBORN: Did anyone provide edits to those witness statements for your consideration?
KATE JAMES: I'm very good at my own editing, I can assure you.
MR. ROTTENBORN: That didn't answer my question. Did anyone else provide edits to those witness statements for you?
KATE JAMES: No.
MR. ROTTENBORN: Now, you've spoken with Mr. Depp since he and Amber have gotten divorced, correct?
KATE JAMES: Correct.
MR. ROTTENBORN: When was the last time you spoke with him? You can answer.
KATE JAMES: I don't recall.
MR. ROTTENBORN: Was it within the past year?
KATE JAMES: No.
MR. ROTTENBORN: In any day prior to today, have you exchanged text messages with Mr. Depp?
KATE JAMES: Yes.
MR. ROTTENBORN: When was the last time, approximately, that you exchanged text messages with Mr. Depp?
KATE JAMES: I would say 2016. Yeah, I think 2016. But it's just a long time ago.
MR. ROTTENBORN: When was the last time you spoke with Amber Heard?
KATE JAMES: I don't recall when.
MR. ROTTENBORN: Was it shortly after your employment with her ended in 2015?
KATE JAMES: No.
MR. ROTTENBORN: Was it after that?
KATE JAMES: No.
MR. ROTTENBORN: Have you spoken with her, to the best. of your recollection, or communicated with her in any way in the past, say, five years?
KATE JAMES: No.
MR. ROTTENBORN: When were you hired by Ms. Heard?
KATE JAMES: In 2012.
MR. ROTTENBORN: How did you meet her?
KATE JAMES: Her sister put an ad through, you know, a recruitment system I use in my field.
MR. ROTTENBORN: Take me through your, the chronology of -- well, let me ask it this way: When did you -- would you describe your work for Ms. Heard as a personal assistant? Is that what you call your job title?
KATE JAMES: Yes.
MR. ROTTENBORN: When did you first start working as a personal assistant?
KATE JAMES: In 1999.
MR. ROTTENBORN: For how many people have you served as personal assistant?
KATE JAMES: Maybe six.
MR. ROTTENBORN: Since you left Ms. Heard's employment in 2015, for how many people have you served as a personal assistant?
KATE JAMES: One That's the same person I work for to this day I've been with him for six and a half years.
MR. ROTTENBORN: Ms. James, have you had any other jobs since -- other than this personal assistant job, since you left Ms. Heard's employment?
KATE JAMES: No.
MR. ROTTENBORN: And your work for Ms. Heard, was it part-time or full-time?
KATE JAMES: It started as part-time and became full-time.
MR. ROTTENBORN: When did you change from prut-time to full-time?
KATE JAMES: I don't recall.
MR. ROTTENBORN: What were your job duties?
KATE JAMES: Too many to mention.
MR. ROTTENBORN: Give me your best summary of what your job duties were, please.
KATE JAMES: Is this relevant? Okay. So, let's see, I mean if you're ready for a really, really long time of me explaining the details, that's fine.
KATE JAMES: It's everything you could possibly do to run someone's life okay So it is grocery shopping It is taking care of admin It is running errands It is getting the car fixed It is getting the dogs groomed It is picking up flowers It is dealing with the decorator It is dealing with the housekeeper It is going on and on and on and on and it goes on every single day.
KATE JAMES: Arranging travel, dealing with all of the surplus stuff around the travel, booking all the places, the changing of travel, okay? Liaising with people that she's working with on films, updating her calendar accordingly, liaising with the people on set every single day to update her calendar to make sure that she knows what scene she's doing each day, what her call time is. Every day it's something different. But it's a long - a myriad, a myriad of things that go across the board daily.
MR. ROTTENBORN: You were paid for that work, correct?
KATE JAMES: Very poorly.
MR. ROTTENBORN: What were you paid? Was it $1,500 a week to start?
KATE JAMES: Are you kidding Oh I wish My God No it was not She paid me $25 an hour to start off with and she finally agreed after screaming at me that she would pay me $50000 a year once I went to full-time And this was after me working for well over ten years as a personal assistant So it was very insulting to me but I did it anyway because I had grandfathered in the ability to pick up my son from school and bring him to work with me at 3:00.
MR. ROTTENBORN: And you could have left Ms. Beard's employment at any time, correct?
KATE JAMES: Yes.
MR. ROTTENBORN: You were based in Los Angeles when you were providing personal assistant services to Ms. Heard, right?
KATE JAMES: I have always lived in Los Angeles since 1999.
MR. ROTTENBORN: So you didn't travel with Ms. Heard when she was out of town, correct?
KATE JAMES: That was another part of our agreement, that I wouldn't travel with her because of my child.
MR. ROTTENBORN: And she was out of town quite a bit, right?
KATE JAMES: Not really.
MR. ROTTENBORN: Not really? How many weeks a year would you estimate Ms. Heard was out of town while you worked for her?
KATE JAMES: Well, you're talking almost ten years ago, so I can't tell you, quite honestly.
MR. ROTTENBORN: When she was out of town, you wouldn't see -- you never traveled with her, right?
KATE JAMES: No.
MR. ROTTENBORN: How much did you see Mr. Depp over the course of your employment with Ms. Heard?
KATE JAMES: Regularly.
MR. ROTTENBORN: How many times -- obvious you didn't see him when he was out of town, right?
KATE JAMES: No.
MR. ROTTENBORN: When he was in town, was it -- would you see him daily, weekly, monthly? What would you estimate?
KATE JAMES: There's no rhyme or reason to answer that question.
MR. ROTTENBORN: Now, you never witnessed any violence between Ms. Heard or Mr. Depp, right?
KATE JAMES: No.
MR. ROTTENBORN: And Ms. Heard never told you that she had been violent to Mr. Depp, correct?
KATE JAMES: No.
MR. ROTTENBORN: You had knowledge that Ms. Heard and Mr. Depp had arguments, correct?
KATE JAMES: No.
MR. ROTTENBORN: Ms. Heard never told you that she had -- and Mr. Depp had had arguments?
KATE JAMES: Occasionally she'd send a text message complaining about her mental state. It was never clear exactly what was going on. It was mostly -
MR. ROTTENBORN: So you never -- I'm sorry.
KATE JAMES: I remember she would text me complaining about her mental state, and that was about it. I don't have any of the text messages, so it's hard to remember.
MR. ROTTENBORN: Do you recall hearing anything about an alleged incident between Amber and Johnny on a flight from Boston to LA around this time frame?
KATE JAMES: Like I said, I remember that day very well.
MR. ROTTENBORN: And to follow up on that, I'm not asking just about what Amber may have told you. I'm just trying to drill down, generally, to what you may have heard, whether from Amber or Johnny or anyone about that flight.
MR. ROTTENBORN: Does that make sense?
MR. ROTTENBORN: So can you tell us what do you remember hearing about that flight or what happened or didn't happen on that flight from Boston to LA?
KATE JAMES: Don't know.
MR. ROTTENBORN: Q Sitting here today, you don't remember anything that you've heard about that?
KATE JAMES: I don't know. I wasn't on the plane. I just know what happened afterwards, okay, when she asked me to meet her at the shuttle.
MR. ROTTENBORN: Did you think to ask her if she was okay?
KATE JAMES: You know, I probably did because that's my role, to play a caregiver. That's all I can imagine.
MR. ROTTENBORN: So what do you remember about this day that you alluded to earlier?
KATE JAMES: Mostly my surprise that they went to the Chateau Marmont because Amber had an apartment of her own in West Hollywood that was very completely set up and available to her. So that was my biggest confusion, that why did she go to the Chateau. And then she asked me to get her bathing suit. I remember that. So I had to go to her apartment to get her bathing suit, which, again, seemed strange to me. And then, what also seemed strange is when I got there, she had a bunch of friends with her and originally I thought she was alone.
MR. ROTTENBORN: When you were referred to Amber's I 6 apartment, are you referring to the apartment on Orange Avenue?
KATE JAMES: Yes, yes.
MR. ROTTENBORN: And isn't it true that Mr. Depp would spend time in that apartment with Amber from time to time, correct?
KATE JAMES: Well, I don't really know what the question is in relation to, but he wasn't there at that time, if that's what you're referring to.
MR. ROTTENBORN: Yeah, no, that's not my question. My question was just over the course of your employment, you have knowledge of Mr. Depp spending time at that Orange Avenue apartment, right?
KATE JAMES: They spent time there and at each residence. They would go around, yeah.
MR. ROTTENBORN: Were you concerned about Ms. Heard and her well-being on that day?
KATE JAMES: No. Because it had become a pattern with her, and so I was merely placating her, I would say, and especially when I saw she was there with about four or five girlfriends and basically having fun, enjoying each other down by the pool. That's why she needed her swimsuit, and then they proceeded to hang out drinking while I sat around waiting and -- with my son, actually, I think it was a Sunday that day, I remember.
KATE JAMES: We had to wait all day while they were just home. around -- drinking around the pool. Finally, I went home, and finally, she went back to her apartment and then she wanted me to go back and pack her bags with her about 10:00 at night on Sunday. I said I couldn't go with her. By that time, I'd spent the whole day sitting there, so I said I couldn't go to pack her bags because I had already put my son to bed, and she was very angry about that. I remember that.
MR. ROTTENBORN: Okay. So, let's -- so when you asked O her if she was okay, you didn't actually care if she was okay; you said you were just placating her, right?
KATE JAMES: It was a standard procedure at this point. She was a very dramatic person.
MR. ROTTENBORN: So you didn't actually think that there was anything that -- that Amber was actually upset, correct?
KATE JAMES: As I said, it just didn't make sense that she went to the Chateau instead of going home. That was the first red flag to me right there, you know.
MR. ROTTENBORN: So you came to the conclusion that day I that any -- she actually wasn't upset; is that what you're saying?
KATE JAMES: It's too much. I mean, it really was.
MR. ROTTENBORN: What I'm asking is did you come to the conclusion that there was nothing wrong with Ms. Heard that day and that she wasn't actually upset?
KATE JAMES: I don't know how to answer such a strange question. Like I said, you already asked me and I already answered.
MR. ROTTENBORN: I'm asking you to answer it again. I don't think I asked the exact same question, but do your best, please.
KATE JAMES: Could you ask me the question in a different way or a clearer way that is not exactly the same as the last question you asked me?
MR. ROTTENBORN: Did you reach the conclusion that day that Ms. Heard hadn't experienced anything traumatic?
KATE JAMES: Over the course of the day, I observed Ms. Heard enjoying the company of her friends for several hours. That's all I have to say on that
MR. ROTTENBORN: And would it be odd for someone who's experienced trauma to want to be around friends to you?
KATE JAMES: I don't know.
MR. ROTTENBORN: So in any event, you said you sat around the Chateau Marmont; is that right?
KATE JAMES: Yes. While she was deciding what to do.
MR. ROTTENBORN: Now, you were being paid for that time, correct?
KATE JAMES: Not overtime. It was a Sunday. I was not being paid, no.
MR. ROTTENBORN: Did you avail yourself of anything at the hotel like did you order any food?
KATE JAMES: No.
MR. ROTTENBORN: Did you --
KATE JAMES: I might have ordered some food for my son, actually, to be honest now that I think about it because he was little at the time, I think he was, you know, five or something. So I might have ordered food for my son. I'm not a big eater. Food is not a priority for me.
MR. ROTTENBORN: Did you -- would you have put that on Ms. Heard's tab that day?
KATE JAMES: Everything was on Depp's tab that day, so, no.
MR. ROTTENBORN: On Johnny's tab?
KATE JAMES: Yes.
MR. ROTTENBORN: Let's bring up the document entitled -- or that ends in -6151 please.
MR. ROTTENBORN: When she wrote "I love you," and you wrote, "Love you too, hon. Won't be long, X," was that just placating Ms. Heard?
KATE JAMES: That is a friendly text exchange in my role of work
MR. ROTTENBORN: Were you trying to be supportive at all or just placating her?
KATE JAMES: It would be to both, I guess.
MR. ROTTENBORN: Did you have any concern whatsoever about Ms. Heard's well-being that day?
KATE JAMES: No.
MR. ROTTENBORN: When was the first time you remember ,22 Ms. Heard telling you that all wasn't right in the relationship between her and Mr. Depp?
KATE JAMES: I don't recall exactly when it started, but it was usually her complaining and crying due to, I would say, insecurities within the relationship more than anything else. She would be very, very insecure, most of the time, and she would call me up crying.
KATE JAMES: I remember one time she called me when she was alone in New York City, and she was crying, lurking on the streets crying, and he wasn't there. She was alone. I told her that she needed to go inside because I was worried that the paparazzi might take a photo of her. And she was in a very disregulated state. And so just out of kindness, I told her to go inside rather than walking around crying in public. I remember that, but I don't remember exactly when that it was. It might have been 2012 or 2013.
KATE JAMES: As the job went on, we called each other less and less and did mostly text messaging. It was all text messaging we did.
MR. ROTTENBORN: Did you ever believe that Mr. Depp mistreated her?
KATE JAMES: No.
MR. ROTTENBORN: So -- and why not?
KATE JAMES: Just never had any evidence of it at all. I was there almost daily, in both her place and then eventually at his place, and ultimately at the Lofts downtown. It was a daily basis experience, morning, noon, night, all days of the week. So, you know, I mean, I never once saw any evidence of anything.
MR. ROTTENBORN: Did :Ms. Heard ever tell you that Johnny had hit her?
KATE JAMES: No.
MR. ROTTENBORN: Did she ever tell you that Johnny had pulled her hair or pushed her?
KATE JAMES: No.
MR. ROTTENBORN: Let me ask it a little bit differently.
KATE JAMES: Okay.
MR. ROTTENBORN: You never believed Ms. Heard that Mr. Depp had mistreated her; is that correct?
KATE JAMES: At the time or after? I never believed it in what context are you talking about? During my employ or afterward?
MR. ROTTENBORN: During your employ.
KATE JAMES: No. Never. And there was never any damage to the apartment that I witnessed. There . was never any aftermath of anything, ever, that I ever saw.
MR. ROTTENBORN: Now you, of course, have no personal knowledge one way or the other whether Johnny ever was abusive to her, correct?
KATE JAMES: Well, I don't know if that's necessarily true because if it was true, I would have seen the damage, even if I wasn't physically present in the moment of these alleged arguments.
MR. ROTTENBORN: And what's your basis for that statement?
KATE JAMES: Well, if someone's being beaten, there's generally physical evidence.
MR. ROTTENBORN: So it's your testimony if there was no physical evidence that you observed, then it couldn't have happened, the domestic violence by Johnny toward Amber; is that your testimony?
KATE JAMES: No.
MR. ROTTENBORN: Well, I'm trying to understand what your testimony is. Maybe you could clarify for me, Ms. James.
MR. ROTTENBORN: Is your testimony that if you never saw firsthand evidence of Johnny being violent to Amber, that it couldn't have happened?
KATE JAMES: That's not what I said. You're trying to put words into my mouth. I don't appreciate that.
MR. ROTTENBORN: Can you pull up the document that is, well, let me see what it ends with here. Depp -11432, please.
KATE JAMES: Your Honor, can we --
THE COURT: Can we pause for a moment. Okay.
MR. ROTTENBORN: This is a document that we're just waiting for the corresponding trial exhibit, so if you could just bear with us for one minute, and then we'd like to move for admission of it.
THE COURT: All right What's the number on it?
MR. ROTTENBORN: That's what we're trying to figure out, son-y for the delay.
MR. ROTTENBORN: Your Honor, it's Trial Exhibit 844.
THE COURT: All right. And that's Defendant's 844?
MR. ROTTENBORN: Yes, ma'am
THE COURT: Okay. 844. Any objection to 844? .19
MS. VASQUEZ: Yes, Your Honor, many objections.
THE COURT: All right. You want to approach, then, if somebody has a copy of 844 for me. We'll get it.
MR. ROTTENBORN: We can pull it up electronically.
THE COURT: That's all right. We'll get it.
MR. ROTTENBORN: It's just a lot of text that we're looking to admit. So, obviously, we could redact all of it.
MR. ROTTENBORN: Sure. Son-y.
THE COURT: All right. 844. Okay. I have 844. All right. So are you asking to move this into evidence?
MR. ROTTENBORN: With just the bottom text with everything else redacted.
THE COURT: Just this one text?
MR. ROTTENBORN: Yes, Your Honor.
THE COURT: Who is this with?
MR. ROTTENBORN: It's Mr. Depp's writing. Ms. James. If you want to do it in a couple minutes when she testifies that it's a text from Mr. Depp to her, we can do that.
THE COURT: Is it the second page? Because this one says Ms. Dembrowski.
MR. ROTTENBORN: He texted -- Cln is Dembrowski is Mr. Depp.
THE COURT: Okay. I did not know that. Sorry.
THE COURT: Okay. So you want this one text. She's about to say that she got this text from Mr. Depp?
MR. ROTTENBORN: Yes, Your Honor.
MS. VASQUEZ: May we -- sorry, Your Honor. Do you have a copy of it? I'm SOITY, Your Honor.
THE COURT: Looks like it's the very bottom.
MR. ROTTENBORN: I'm so sorry. I'll try to be better.
THE COURT: It's Judy's microphone. If you break it, you've got to deal with Judy.
MS. VASQUEZ: Yeah. I mean, our objections to this is that it's improper character evidence, Your Honor. They're trying to get in evidence of Mr. Depp's bad behavior via text messages, and yet we can't bring in any evidence of his good behavior.
THE COURT: Well, that's kind of how party admissions go, party opponents go. I mean, it's hearsay, but it's a party opponent.
MS. VASQUEZ: Well, I understand. It still goes to character. We're still saying it's improper character, Your Honor. And, you know, to the extent that Your Honor would allow us to bring in a bit more background on Mr. Depp and his good behavior, with some of our witnesses, you know, to be able to offer this ...
MR. ROTTENBORN: We'll take that as a --
MS. VASQUEZ: It's a proper --
MR. ROTTENBORN: But if he's reaching out to one of the witnesses and saying, "Come over and we'll," you know, do that, that's party admission, and relevance and bias, prejudice. All I sorts of things, for this extent. I mean, we can take whatever they want to try to get in later, but I don't think --
MS. VASQUEZ: We just think it's unfairly prejudicial and improper character evidence.
THE COURT: I understand your objections. I'm going to overrule the objections. You owe me a redaction for this, though, before we can show it to the jury.
MR. ROTTENBORN: Would it be okay if, for now, we do like we did -- we'll prepare a redacted exhibit but we do like we did with Ms. Dembrowski's texts the other day, where we showed this part right here?
THE COURT: Okay. Any objection just to that?
MS. VASQUEZ: Just making sure --
THE COURT: Just make sure that they show it to you.
MS. VASQUEZ: Yes, Your Honor.
MR. CHEW: And if you could have somebody else -- this is not an insult at all, but, I mean, if you could have somebody else also look at it and give us a chance look at it, because last time you and I both missed a personal identifier.
THE COURT: Okay. Yeah. That's fine. The problem you'll have to switch it like we did with the security tapes with the other depositions. They can't see her at the same time that they see this. You understand?
MR. ROTTENBORN: Okay. Why don't we -- there's probably a few more questions that will key it up so that they'll know what they're looking at, and then I'll stand up and ask --
MR. NADELHAFT: Pause the video? noted.
THE COURT: And your objections are
MR. ROTTENBORN: Thank you, Your Honor.
MR. ROTTENBORN: Can you just wait one minute before you start, please.
MR. ROTTENBORN: Box at the bottom --
KATE JAMES: Uh-huh.
MR. ROTTENBORN: Do you see your name, Kate, in that column labeled "participants"?
KATE JAMES: Yes, uh-huh.
MR. ROTTENBORN: Is this a text message that you received from Mr. Depp on or around August 13th, 2016?
KATE JAMES: Yes.
MR. ROTTENBORN: And it appears that he's responding to something that you had sent him, correct?
KATE JAMES: I don't know.
MR. ROTTENBORN: You see where he says "Thank you, sweetheart"?
KATE JAMES: Yes.
MR. ROTTENBORN: He's directing that to you, right?
KATE JAMES: It looks like there's someone else cc'd on this text, so it could be to that person. I honestly don't know. I cannot answer your question.
MR. ROTTENBORN: Can we please pause the video.
THE COURT: All right. Can you pause for a second, please. Thank you. He already did. That was good. Thank you.
MR. ROTTENBORN: Your Honor, I would like to switch to our --
THE COURT: Well, switch to -- okay. That's fine.
MR. ROTTENBORN: Thank you.
THE COURT: Make sure it's set right before you publish it. All right.
MR. ROTTENBORN: Your Honor, with the stipulation that we'll prepare a redacted version to be entered into evidence that has other personal identifiers redacted, we'd ask for permission to admit this into evidence and publish it to the jury.
THE COURT: The objections are noted, and we'll get the redacted copy. All right.
MR. ROTTENBORN: Thank you, Your Honor. Can you blow it up, Heather.
THE COURT: All right, sir. Are we ready to continue?
MR. ROTTENBORN: Ready to resume with the video. Thank you, Your Honor.
THE COURT: All right.
MR. ROTTENBORN: Do you see where he says Will hit you when I get back doll Come over for a spot of purple and we'll fix her flabby ass nice and good
KATE JAMES: Yep.
MR. ROTTENBORN: "Come over for a spot of purple" means come over for a drink of wine, right?
KATE JAMES: I don't know.
MR. ROTTENBORN: That's what you understood it to mean, correct?
KATE JAMES: I don't know.
MR. ROTTENBORN: That's what you understood it to mean, correct?
KATE JAMES: I don't know.
MR. ROTTENBORN: Lucien, can you pull up the document labeled "U.K. trial, day seven, James testimony," please.
MR. ROTTENBORN: Ms. James, you remember giving testimony in the trial in the U.K., right?
KATE JAMES: Well, there'd be something wrong with me if I didn't.
THE COURT: I need order in the court.
MR. ROTTENBORN: When you gave that testimony you gave it under oath correct
KATE JAMES: Yes. Yes.
MR. ROTTENBORN: Lucien, can you please go to page 39 of the PDF. And can you please blow up the page that is labeled 1221.
MR. ROTTENBORN: On line 7, Ms. James, am I reading this right that you were asked a question and he is inviting you over for a spot of purple? What is that?
MR. ROTTENBORN: "Yes" is your answer.
MR. ROTTENBORN: Question: What did you understand?
MR. ROTTENBORN: And your answer, "Red wine, I imagine."
MR. ROTTENBORN: Do you see that?
MR. ROTTENBORN: Yeah, I do remember that.
MR. ROTTENBORN: Do you remember giving that testimony?
KATE JAMES: Uh-huh, yeah.
MR. ROTTENBORN: So is it your understanding that Mr. Depp was inviting you over for wine at some point after he split up from Ms. Heard?
KATE JAMES: And just speculation.
MR. ROTTENBORN: Did you meet up with Mr Depp for red wine around the time period of this text on August 13th 2016
KATE JAMES: I did meet up with him, but we did not drink red wine, no.
MR. ROTTENBORN: Was anyone else present for that meeting?
KATE JAMES: No.
MR. ROTTENBORN: When he said "Come over for a spot of purple, and we'll fix her flabby ass," you understand him to be referring to Ms. Heard when he said "we'll fix her flabby ass," correct?
KATE JAMES: Yeah. It wasn't for me to speculate what he was referring to.
MR. ROTTENBORN: And I'm not asking for you to speculate what he was referring to; I'm asking for your understanding was that he was talking about Ms. Heard, correct?
MR. ROTTENBORN: You can answer.
KATE JAMES: There isn't an answer. I mean, this is the way he writes. It's very random and you don't sit and question it, okay? It's the way he writes. He writes in a very abstract way.
MR. ROTTENBORN: Okay.
MR. ROTTENBORN: Lucien, if you can just pull up the prior testimony that we just looked at.
MR. ROTTENBORN: Ms. James, isn't it true that on line 12 of page 1221, you were asked the question, "Red wine, and not only to come over for a spot of purple but to fix her flabby ass, that was about Ms. Heard, was it not?"
MR. ROTTENBORN: And on line 14, you answered "Yes, yes."
MR. ROTTENBORN: Do you see that?
KATE JAMES: Yes. Uh-huh.
MR. ROTTENBORN: So you did understand this to be referring to Ms. Heard, correct?
KATE JAMES: No.
MR. ROTTENBORN: I'm sorry. You said no?
KATE JAMES: Just trying to be agreeable in the court, having no clue what on Earth is going on. So there you go. I have no clue.
MR. ROTTENBORN: Was that answer in the court truthful or just agreeable?
KATE JAMES: Just being agreeable.
MR. ROTTENBORN: So it wasn't truthful? You can answer.
KATE JAMES: I don't have an answer for you, Mr. Rottenborn.
MR. ROTTENBORN: What did you and Mr. Depp talk about at that meeting that you recall?
KATE JAMES: I don't recall details.
MR. ROTTENBORN: Just tell me generally everything you recall.
KATE JAMES: It's too long ago, Mr. Rottenborn. I don't recall.
MR. ROTTENBORN: Do you recall anything?
KATE JAMES: No.
MR. ROTTENBORN: Where was the meeting?
KATE JAMES: At his residence in West Hollywood.
KATE JAMES: COURT REPORTER: Is that his residence? I What? I'm sorry.
KATE JAMES: In West Hollywood.
MR. ROTTENBORN: What time of day?
KATE JAMES: About 3:00 p.m.
MR. ROTTENBORN: So you recall the time of day, but you don't recall anything you discussed?
KATE JAMES: No. I'm just saying I know it was in the afternoon because it was after I picked my son up from school because my son went to swim in the pool with the security guard watching him while I went and had a brief conversation with Mr. Depp. That's the only reason I remember the time.
MR. ROTTENBORN: Did you talk about Ms. Heard?
KATE JAMES: Yes.
MR. ROTTENBORN: What did you discuss about Ms. Heard?
KATE JAMES: Well, like I said, I don't recall the details.
MR. ROTTENBORN: Well, I'm just a little confused because you just testified you didn't remember anything, but now you remember that you did talk about Ms. Heard. So what I'm trying to get is everything you remember about the conversation.
KATE JAMES: Well, you've got to understand, Mr. Rottenborn, the mutual connection between Mr. Depp and myself is, in fact, Ms. Heard. So inevitably that is going to be part of the conversation. That's all I remember. Okay?
MR. ROTTENBORN: Do you remember anything else about that conversation with Mr. Depp?
KATE JAMES: No.
MR. ROTTENBORN: Have you seen Mr. Depp since that conversation?
KATE JAMES: No.
MR. ROTTENBORN: Now, what's your -- just describe generally your educational background, please.
KATE JAMES: I completed high school, and then I went straight into becoming a veterinary nurse when I left the school, left school, which I did for approximately three to four years before I left Australia.
MR. ROTTENBORN: Did you have any sort of specialized training in veterinary medicine or nursing?
KATE JAMES: Only on-the-ground experience. I was four years in a clinic.
MR. ROTTENBORN: So you don't have any experience with medical training for humans, right?
KATE JAMES: No.
MR. ROTTENBORN: And you don't have any training in health care, correct?
KATE JAMES: Could you be more specific?
MR. ROTTENBORN: You don't have any training in health care for people, correct? e 2
KATE JAMES: I'm not a human nurse, if that's your question. I don't really understand your question.
MR. ROTTENBORN: Sorry. You don't have any training related to prescription drugs, do you?
KATE JAMES: No.
MR. ROTTENBORN: And you have no basis --
KATE JAMES: Excuse me. Only pertaining to animals, yes. I would like to add that.
MR. ROTTENBORN: Okay. And that was the training that you received on the job in Australia before you came to the US?
KATE JAMES: Amongst other things, yes.
MR. ROTTENBORN: You are familiar with Ms. Heard taking prescriptions for acne and Provigil, among other things, correct?
KATE JAMES: Yes.
MR. ROTTENBORN: You were not -- you never served as a nurse or doctor to Ms. Heard, right?
KATE JAMES: No.
MR. ROTTENBORN: And you have no medical knowledge to testify whether Ms. Heard used Provigil or Accutane in the way her doctors instructed, correct?
KATE JAMES: No.
MR. ROTTENBORN: And you're not an expert on the interaction of prescription drugs and alcohol or other drugs, correct?
KATE JAMES: No.
MR. ROTTENBORN: Did you, during the course of your employment, develop any personal knowledge of Mr. Depp's use of alcohol or drugs?
KATE JAMES: Not firsthand.
MR. ROTTENBORN: And what do you mean by "not firsthand"?
KATE JAMES: Veil, I worked for Amber; I didn't work for him.
MR. ROTTENBORN: Did you ever see Mr. Depp using illegal drugs?
KATE JAMES: No.
MR. ROTTENBORN: Did you ever see Mr. Depp abuse alcohol? ,22
KATE JAMES: No.
MR. ROTTENBORN: Did you ever speak with Dr. Kipper?
KATE JAMES: No.
MR. ROTTENBORN: Did you ever speak with Erin Boerum?
KATE JAMES: Yes.
MR. ROTTENBORN: And Erin Boerum was a nurse who worked for Dr. Kipper, right?
KATE JAMES: She was assigned to Amber.
KATE JAMES: COURT REPORTER: I'm sorry? I'm sorry.
KATE JAMES: She was assigned to Amber; that's how I came to be speaking to her.
MR. ROTTENBORN: And she also provided medical services to Johnny, right?
KATE JAMES: I don't remember.
MR. ROTTENBORN: What do you recall speaking to Erin Boerum about?
KATE JAMES: Just random chitchat in the course of the day, nothing specific.
MR. ROTTENBORN: Do you recall ever fanning any concern in your own mind about any of Mr. Depp's behavior in his relationship with Amber?
KATE JAMES: Never.
MR. ROTTENBORN: Nothing you heard, nothing you witnessed, nothing you saw during your time with Ms. Heard ever gave you an inkling of concern about Mr. Depp's behavior toward Amber?
KATE JAMES: Never.
MR. ROTTENBORN: Now, you left your employment -- or your employment with Amber ended in early 2015, correct?
KATE JAMES: Just after they came back from the wedding on the island.
MR. ROTTENBORN: Did Ms. Heard terminate your employment?
KATE JAMES: When Ms. Heard came back from the island, she informed me that she now needed to support her mother because her mother could no longer work after her diagnosis, her medical diagnosis, and she told me she could no longer afford to pay me since she had to support her mother, and, therefore, she would have to terminate my employment to support her family.
MR. ROTTENBORN: And did you resent Ms. Heard for that, for terminating your employment?
KATE JAMES: It would have been nice to have been given some notice so I had some time to look around, so I was a little upset for the lack of notice, but apart from that, no, I was not upset.
MR. ROTTENBORN: Ms. Heard gave you six weeks of severance pay, correct?
KATE JAMES: I don't recall.
MR. ROTTENBORN: Did you want to stay in the job for Ms. Heard?
KATE JAMES: Well, I did ask if I could have a few months' heads-up so I could seek another job that would suit the terms of my employment, but she did not allow that.
MR. ROTTENBORN: And that made you angry, correct?
KATE JAMES: No.
MR. ROTTENBORN: Did you ask to be put on Mr. Depp's payroll so that you could remain being paid by Ms. Heard or Mr. Depp?
KATE JAMES: Well, when she said she couldn't afford it, I said, "Now you're married, couldn't I go onto Depp's payroll?"
KATE JAMES: And she said no. It was part of a legal agreement they had that she was not allowed I to do that. I don't know whether that was true or not.
MR. ROTTENBORN: Did you ever ask Mr. Depp whether you could go on his payroll?
KATE JAMES: No.
MR. ROTTENBORN: Isn't it true that you asked to live in one of Mr. Depp's houses rent-free for a period of time after your employment?
KATE JAMES: Well, you see, I'm a homeowner. I want to be clear I didn't want to miss a mortgage payment due to unemployment, so my idea was if perhaps I can find an alternate accommodation in order to rent out my house so I don't lose my entire property. I'm a homeowner. Keeping my home and my payments up to date is of paramount importance to me.
MR. ROTTENBORN: Isn't it hue that you had ah early skipped about a year and a half of mortgage payments on your home during the time you were employed by Ms. Heard?
KATE JAMES: No.
MR. ROTTENBORN: Let's pull out the document ending in ALH -5858, please.
TECHNICIAN: Exhibit 11 on the screen.
MR. ROTTENBORN: Yeah, I think you read everything so if you're ready for me to ask the questions my first question is just is this an email exchange between you and Amber relating to the termination of your employment.
KATE JAMES: Yes, this is the email I received when she terminated me.
MR. ROTTENBORN: And then the emails above in this document are -- some of which have duplicated -- are an email change that you had with Amber after you received the termination email?
KATE JAMES: Yeah, when I woke up that morning, yep.
MR. ROTTENBORN: Can you go to the first page, please, top of the document.
KATE JAMES: Uh-huh.
MR. ROTTENBORN: Isn't it true that Ms. Heard did pay you six extra weeks of pay after your termination?
KATE JAMES: She's stating that but I don't recall if it actually happened or not.
MR. ROTTENBORN: You don't have personal knowledge one way or the other or recollection of whether she did?
KATE JAMES: No.
MR. ROTTENBORN: And isn't it hue that you do tell her in this email that you didn't pay your mortgage for the first year and a half that you were working for her?
KATE JAMES: Yes.
MR. ROTTENBORN: Right?
KATE JAMES: I had one of those balloon mortgages, so I had to go to loan modification, and I recall now that's why I was able to agree to work for her for such a small amount of money from what I normally made; it was sort of as a favor, almost.
MR. ROTTENBORN: What was the favor?
KATE JAMES: To work for her for, like, half my usual paycheck basically.
MR. ROTTENBORN: So you were doing Amber a favor?
KATE JAMES: Yes. Because initially it was described as part-time, 20-hour-a-week thing with flexibility and blah, blah, blah. So, you know, I thought it's not really in my caliber, but my son was only four at the time so seemed like a good idea especially because I wasn't paying my mortgage so I could take the hit by getting less pay than I would normally make. And that way I could also have the time with my son that I wanted.
MR. ROTTENBORN: And I think the answer to this is no, but I wanted to be clear. You're not blaming Amber for your not paying your mortgage, right?
KATE JAMES: No. That was my choice. It was the only way I could get a loan modification is the way it worked then. But, you know, the 2008 crash that's how it worked back then. If you wanted to save property.
MR. ROTTENBORN: You started working for Amber in 2012, right?
KATE JAMES: Yes. It took a long time, the loan modification process.
MR. ROTTENBORN: And you're not blaming Amber for getting a credit card with 29 percent interest, are you?
KATE JAMES: What?
MR. ROTTENBORN: You see in your email in that first page about two-thirds of the way down, you say, "I have borrowed from my mom my tenant's security deposit, and now I have used up a credit card I shouldn't have used as it has 29 percent interest"?
KATE JAMES: No. That's my choice.
MR. ROTTENBORN: Did you have tenants in your property at that time?
KATE JAMES: I have a duplex. I'm just trying - at that time, yes, I had tenants in one house and I was living in the other.
MR. ROTTENBORN: Did you use the tenant's security deposit for personal expenses?
KATE JAMES: I don't remember.
MR. ROTTENBORN: Do you see where you say, "I have borrowed from my mom my tenant's security deposit"?
KATE JAMES: Uh-huh.
MR. ROTTENBORN: Do you recall using your tenant's security deposit orb. arrowing from that?
KATE JAMES: It's too long ago for me to recall if it actually happened.
MR. ROTTENBORN: Would there be a reason that you would have said that if it wasn't true?
KATE JAMES: No.
MR. ROTTENBORN: And isn't it true that you did ask to live rent-free in one of the Johnny's houses after you were terminated, right?
KATE JAMES: Loads of people did.
MR. ROTTENBORN: Isn't it true that you did?
KATE JAMES: Yes.
MR. ROTTENBORN: And did that ever come to pass?
KATE JAMES: No.
MR. ROTTENBORN: Did it make you angry that that didn't happen?
KATE JAMES: No.
MR. ROTTENBORN: It's fair to say at the time that your employment was terminated, you were in fairly significant financial trouble, correct?
KATE JAMES: Yes.
MR. ROTTENBORN: And you were angry with Amber for terminating you at this time when you were in financial trouble, correct?
KATE JAMES: No.
MR. ROTTENBORN: See at the bottom of your email on page 2, you say, "Max and I love you very much" as a sign-off to your email?
KATE JAMES: Yes.
MR. ROTTENBORN: Max is your son, right?
KATE JAMES: Yes.
MR. ROTTENBORN: That wasn't true, correct? In fact, you didn't love Amber, didn't like her, did you?
KATE JAMES: Any close relationship has ebbs and flows and feelings that you have for one another; it's pretty standard.
MR. ROTTENBORN: And at that point in time you -- well, since your termination, you've had nothing but animosity towards Ms. Heard, correct?
KATE JAMES: No. Actually bumped into her at the PO box about three months after, and she was in her Range Rover. And I saw her sister, and she said, Come say hi to Amber, and I went back there and I was going to say hi, but she was on the phone and she was saying, Wait, wait. But then I had to go. That's the only time I've ever seen her, but I wanted to go and say hi. I wasn't feeling like I wanted to avoid her or anything. You know, things happen and life goes on, you know.
MS. VASQUEZ: I understand you're a personal assistant, Ms. James. What type of people do you work for?
KATE JAMES: High-profile celebrities.
MS. VASQUEZ: Are they celebrities in the entertainment industry?
KATE JAMES: Yes.
MS. VASQUEZ: You previously testified that in March of 2012, you worked as a personal assistant for Ms. Heard, yes?
KATE JAMES: Yes.
MS. VASQUEZ: In total how long did you work for Ms. Heard as her personal assistant?
KATE JAMES: Almost three years.
MS. VASQUEZ: And at the time you were hired in March of 2012, had you ever heard of Ms. Heard?
KATE JAMES: No.
MS. VASQUEZ: You previously testified today that at some point while working for Ms. Heard, you transitioned from working part-time to full-time; ,4 is that right?
KATE JAMES: Yes, uh-huh.
MS. VASQUEZ: When did that transition happen?
KATE JAMES: I don't recall specifically.
MS. VASQUEZ: Do you think it happened within the first year of your employment?
KATE JAMES: I believe it happened within - around six months into the employment.
MS. VASQUEZ: So most definitely it happened in the first year of your employment; is that correct?
KATE JAMES: Yes.
MS. VASQUEZ: You previously testified that you stopped working for Ms. Heard as her personal assistant in February of 2015 is that right?
KATE JAMES: Yes.
MS. VASQUEZ: And you also testified that Ms. Heard let you go upon her return from the Bahamas in February of 2015, yes?
KATE JAMES: Yes.
MS. VASQUEZ: Did Ms. Heard ever give you any indication or warning that your employment might end upon her marriage to Mr. Depp?
KATE JAMES: No.
MS. VASQUEZ: How did it make you feel when Ms. Heard terminated your employment without warning?
KATE JAMES: Bit of a shock. Bit of a feeling of being blindsided.
MS. VASQUEZ: When you first began working for Ms. Heard, and when Ms. Heard was in town, in other words, not traveling, how many times per week would you see her?
KATE JAMES: Almost daily.
MS. VASQUEZ: And did that change when you became a full-time personal assistant for Ms. Heard?
KATE JAMES: No.
MS. VASQUEZ: Would you see Ms. Heard on the weekends as well?
KATE JAMES: Yes.
MS. VASQUEZ: And when you would see Ms. Heard in person, did you coordinate with her when you would be seeing her?
KATE JAMES: No. I would arrive whenever it was necessary to bring stuff that I picked up on errands or whatnot. There was no given set schedule.
MS. VASQUEZ: And when you say you would arrive, where would you arrive to?
KATE JAMES: It depended where she was at the time. Sometimes she was at Orange, sometimes she was at one of Johnny's houses on Sweetzer, and then eventually, they all moved down to the Lofts downtown.
MS. VASQUEZ: You previously testified that your work as Ms. Beard's -- as being Ms. Beard's private assistant was extensive. Would you please tell us everything that was -- you were responsible for?
KATE JAMES: Everything from handling all of her dry cleaning, packages, mail, liaising with agents, other people in the industry, coordinating travel, making restaurant reservations, you know, dealing with the staff, the vendors on the property, that sort of thing.
MS. VASQUEZ: Did Ms. Heard ever ask you to monitor I press for her?
KATE JAMES: Yes.
MS. VASQUEZ: What specifically did she ask you to do?
KATE JAMES: I had a newsstand guy that was instructed to hold two copies of every magazine she appeared in. It was newsstand on Schoenborn Avenue, just off La Cienega, and he would hold them for me, and I would go there once a week to pick up the magazines.
KATE JAMES: COURT REPORTER: I'm sorry. You got muffled out. You said, "and he would hold those for me and ... "
KATE JAMES: Hold them for me, and I would go approximately once a week to pick up whatever magazines Amber was featured in, two copies each, which I would then store in her garage.
MS. VASQUEZ: Why would you store them in Ms. Beard's garage?
KATE JAMES: Because she didn't want Mr. Depp to see them.
MS. VASQUEZ: Did she tell you why she didn't want Mr. Depp to see them?
KATE JAMES: No. She just got very angry with me one day because I hadn't quite made it downtown to put them in the garage when she came home, and she went absolutely ballistic over that.
MS. VASQUEZ: When you say "she went absolutely ballistic over that," can you please describe what you mean?
KATE JAMES: Screaming, yelling, abuse.
MS. VASQUEZ: Do you remember what she said to you?
KATE JAMES: No.
MS. VASQUEZ: But it was abusive, in your opinion?
KATE JAMES: Blind rage.
MS. VASQUEZ: Over the three-year period in which you worked for Ms. Heard, were you ever with Ms. Heard when she was getting dressed or undressing?
KATE JAMES: All the time.
MS. VASQUEZ: How often were you present when Ms. Heard was getting dressed?
KATE JAMES: Every time she was getting dressed for a fitting, I would say 90 percent of the time, I was there.
MS. VASQUEZ: And just to clarify, was it just when Ms. Heard was in fittings that you would see her in states of undress?
KATE JAMES: No. It was also in her apartment. She had no issue with walking around naked quite often.
MS. VASQUEZ: Did you ever observe Ms. Heard putting on makeup?
KATE JAMES: Yes.
MS. VASQUEZ: How often did you see Ms. Heard doing her makeup?
KATE JAMES: Just when she was getting ready to go out somewhere for a party or something.
MS. VASQUEZ: And when you interacted with Ms. Heard, and I understand it was quite frequent and regular, did it appear to you that she was wearing makeup?
KATE JAMES: She usually never wore makeup unless she was going to a special event.
MS. VASQUEZ: And when she did go to special events, would you describe her makeup as heavy?
KATE JAMES: Either a makeup artist would do it, or she would do it herself. If she did it herself, it would be light and usually adding lashes, and that's about it.
MS. VASQUEZ: And I believe you previously testified to this, so I'm sorry for asking you again, but while you worked for Ms. Heard, did you ever see any type of injuries on her?
KATE JAMES: No.
MS. VASQUEZ: Did you ever see any cuts?
KATE JAMES: No.
MS. VASQUEZ: Did you see bruises?
KATE JAMES: No.
MS. VASQUEZ: Did you see swelling?
KATE JAMES: No.
MS. VASQUEZ: Redness in her face?
KATE JAMES: No.
MS. VASQUEZ: How about Ms. Heard having black eyes?
KATE JAMES: Never.
KATE JAMES: A broken nose?
KATE JAMES: Never.
MS. VASQUEZ: Missing hair clumps? Sorry, I didn't catch that.
KATE JAMES: Never.
MS. VASQUEZ: Did you ever see Ms. Heard cry?
KATE JAMES: Yes.
MS. VASQUEZ: How often did you see her cry?
KATE JAMES: Hard to put a number on it. Sometimes she would cry on the phone. I think at least once or twice, she might have cried on the phone, you know, and then as far as seeing her personally crying, you know, she was a pretty dramatic person. It's hard to really put a number on it.
MS. VASQUEZ: And focusing on when you saw her in person crying, how many times do you believe that you saw her in person crying?
KATE JAMES: I would say twice, maybe. Twice.
MS. VASQUEZ: Let's take that in bite sizes.
MS. VASQUEZ: The first time you saw Ms. Heard cry in person, do you recall what she was crying about?
MS. VASQUEZ: Go ahead, Ms. James.
KATE JAMES: Insecure emotions.
MS. VASQUEZ: So the two times that you recall Ms. Heard crying in front of you, you remember her crying about being insecure is that correct?
KATE JAMES: Yes.
MS. VASQUEZ: You testified that she felt insecure about her relationship; is that correct?
KATE JAMES: Yes.
MS. VASQUEZ: Can you expand on that? What do you mean by that?
KATE JAMES: She didn't like being away from his physical presence.
MS. VASQUEZ: Did Ms. Heard tell you that she felt insecure when Mr. Depp wouldn't be present with her?
MS. VASQUEZ: Other than telling you she felt insecure about her relationship with Mr. Depp, what else did Ms. Heard say about feeling insecure?
KATE JAMES: She told me she didn't like hanging out in his house with his friends because it was boring, and those were old men playing guitars and it wasn't interesting to her.
MS. VASQUEZ: Was Ms. Heard dating Mr. Depp when you first started working for her
KATE JAMES: Yes.
MS. VASQUEZ: When did you first learn that Ms. Heard was dating Mr. Depp?
KATE JAMES: After about a month, I think.
MS. VASQUEZ: How did you learn that she was dating Mr. Depp?
KATE JAMES: She told me.
MS. VASQUEZ: What did she tell you?
KATE JAMES: She told me she is dating Johnny Depp.
MS. VASQUEZ: Do you recall the first time you met Mr. Depp?
KATE JAMES: Yes.
MS. VASQUEZ: When was that?
KATE JAMES: It was in her apartment on Orange, probably shortly after she told me she was dating him and standing in the dining room
MS. VASQUEZ: And approximately when was that?
KATE JAMES: I don't remember. I would say April or May of 2020.
MS. VASQUEZ: What was your impression of Mr. Depp?
KATE JAMES: He was very peaceful, very calm, almost shy, and very quiet. And I remember he was y q wearing red suede shoes. Because I didn't know where else to look, I looked at his shoes. It's a weird recollection, I know, but I'm just being honest.
MS. VASQUEZ: Did you ever witness Mr. Depp be rude to anyone?
KATE JAMES: He's such a gentleman, so he's like a total Southern gentleman. So, no, no.
MS. VASQUEZ: Did you ever see Mr. Depp lose his IO cool?
KATE JAMES: No.
MS. VASQUEZ: Did you ever see him scream at anyone?
KATE JAMES: No.
MS. VASQUEZ: Did you ever see him break something?
KATE JAMES: Only in a video.
MS. VASQUEZ: In your presence did you ever see Mr. Depp break something intentionally?
KATE JAMES: Never broke anything, never throw anything, always completely passive.
MS. VASQUEZ: I believe you've testified previously that you have a son, correct?
KATE JAMES: Yes.
MS. VASQUEZ: How old was your son when you first started working for Ms. Heard?
KATE JAMES: Four. Four years old.
MS. VASQUEZ: And did you ever bring your son to work with you?
KATE JAMES: Yes.
MS. VASQUEZ: How often?
KATE JAMES: Quite often if I had to keep working; I would bring him back there after school. And if I had to work on the weekend, he would come with me then.
MS. VASQUEZ: Did Mr. Depp ever interact with your son?
MS. VASQUEZ: Yes. He was very kind. How often did you -- did Mr. Depp interact with your son?
KATE JAMES: Whenever they were in each other's presence.
MS. VASQUEZ: Can you give me an estimate of how often that happened?
KATE JAMES: Oh, countless times. You know, he would even teach him how to play guitar. He would even teach him how to play guitar. He 960 brought him back things from vacations. He showed him his amazing makeup makeover when he was doing Black Mass. He tricked him and went over saying, "Do you know who I am?" With a full makeup. My son's jaw almost hit the ground. It was really cute, actually. He gave my son a little pick as well, guitar pick, which he cherishes to this day as well.
MS. VASQUEZ: Fair to say you were around Mr. Depp O and Ms. Heard together quite a lot?
KATE JAMES: Yeah. It became increasingly more as the time went on, yes.
MS. VASQUEZ: What was your impression of Ms. Heard and Mr. Depp's relationship?
KATE JAMES: You know, it did not seem like a perfect relationship to me, based on a lot of insecurity on her behalf, which seemed to cause confusion in the relationship. Maybe the age gap was an issue because of interests. I know that much. Apart from that, who am I to know their relationship, you know?
MS. VASQUEZ: Do you think that Mr. Depp was smothering of Ms. Heard?
KATE JAMES: Oh,no.
MS. VASQUEZ: Did it appear to you that Mr. Depp was jealous of Ms. Heard?
KATE JAMES: No.
MS. VASQUEZ: Did you ever have interactions with Mr. Depp by yourself?
KATE JAMES: Sometimes, yes.
MS. VASQUEZ: And what were those interactions like?
KATE JAMES: Just friendly chitchat, which would stop immediately when Amber saw me speaking to him. She'd give me the evil eye, and I'd always just quickly walk away.
MS. VASQUEZ: Did Amber ever talk to you about your interactions with Mr. Depp?
KATE JAMES: No.
MS. VASQUEZ: In the three years that you worked for Ms. Heard, did you ever see Ms. Heard and Mr. Depp argue?
KATE JAMES: No.
MS. VASQUEZ: In the three years that you worked for Ms. Heard, did you ever see any physical violence between Ms. Heard and Mr. Depp?
KATE JAMES: Never.
MS. VASQUEZ: Did you ever see either of them being physically aggressive with one another?
KATE JAMES: No.
MS. VASQUEZ: Did you ever see any property damage at Ms. Beard's home?
KATE JAMES: Never.
MS. VASQUEZ: Did you ever see any property damage at Mr. Depp's primary residence on Sweetzer?
KATE JAMES: Never.
MS. VASQUEZ: Did you ever see any property damage at the Lofts or the penthouses at the Eastern Columbia Building?
KATE JAMES: No, never.
MS. VASQUEZ: Over the three-year period in which you worked for Ms. Heard, did you ever hear from anyone that Mr. Depp or Ms. Heard had been in a physical altercation?
KATE JAMES: No.
MS. VASQUEZ: Over the three-year period in which you worked for Ms. Heard, did you ever see Ms. Heard be physically aggressive with anyone?
KATE JAMES: No.
MS. VASQUEZ: Let's break that down a bit. When you say she was verbally abusive to you regularly, can you explain to me how she was verbally abusive to you?
KATE JAMES: Screaming, screaming over the phone. She screamed at me once in person, multiple times screaming at me over the phone, barrages of abusive text messages. In the middle of the night, I think you're aware. I think between 2 and 4 a.m., the barrages would start; that's what I'd wake up to. All incoherent, not really making sense, just basically someone to lash out at, you know, no apparent reason to it.
MS. VASQUEZ: You testified previously that you observed Ms. Heard being verbally abusive to her sister?
KATE JAMES: Yes.
MS. VASQUEZ: What do you recall about that verbal abuse?
KATE JAMES: It was an ongoing "kick the door" kind of relationship with her sister, so it's really hard to pinpoint any specifics, but, yeah, her poor sister was treated like the dog that you kick basically.
MS. VASQUEZ: You've previously testified that Ms. Heard -- you observed Ms. Heard be verbally abusive to her mother.
KATE JAMES: Uh-huh.
MS. VASQUEZ: What specifically did you observe?
KATE JAMES: Well, there is a video line where you can see her being abusive, first and foremost, so it's not even based on what I'm telling you. It's I what I've seen the interactions between the two of them when her mother was still alive and the fact that her mother was terrified of her.
MS. VASQUEZ: Did her mother tell her she was terrified of her?
KATE JAMES: She personally told me she was terrified of her.
MS. VASQUEZ: Did you ever witness Ms. Heard tongue lash her mother?
KATE JAMES: Here and there, yes. Especially when it was built up to a stressful event or something like that, yeah.
MS. VASQUEZ: You said you felt that Ms. Heard was verbally abusive to you. Can you provide me with any specific examples of this behavior?
KATE JAMES: I thought I did earlier that, yeah, so random and ongoing, you would never know when it was going to come left of center. I do remember on one occasion when we were going from part-time to full-time, and the salary negotiations became a real bone of contention. And I specifically remember standing in her office where she leapt up out of her chair, put her face approximately four inches from my face. So she was spitting in my face and telling me how dare I ask for the salary I was asking for, which was, in fact, approximately half of my regular annual salary.
KATE JAMES: I was offering her that as a favor. And she felt -- she felt that gave her the right to spit in my face, and there was a witness in the apartment at that time by the way.
MS. VASQUEZ: Who was at the apartment at the time?
KATE JAMES: The handyman, Hector Galindo.
KATE JAMES: COURT REPORTER: I'm sorry.
KATE JAMES: The handyman, Hector Galindo.
KATE JAMES: He was so mortified. He was so embarrassed to hear her speaking to me like that.
MS. VASQUEZ: Ms. James, while you worked for Ms. Heard, did you ever observe her drinking alcohol?
KATE JAMES: Yes, I did.
MS. VASQUEZ: How often did you observe Ms. Heard drink alcohol?
KATE JAMES: Don't recall.
MS. VASQUEZ: What alcohol did you observe Ms. Heard drink in your presence?
KATE JAMES: Red wine.
MS. VASQUEZ: Did Ms. Heard ever appear intoxicated to you?
KATE JAMES: Yes. She often did.
MS. VASQUEZ: While you worked for Ms. Heard, were you aware of what, if any, prescription drugs she was taking?
KATE JAMES: Yes. Because I had to pick it up, and I often had to deliver it to her.
MS. VASQUEZ: You anticipated -- I'm sorry, Ms. James. I interrupted your question -- or your answer, excuse me. The last part of your answer was to?
KATE JAMES: I would - that was my job, to pick it up and deliver it to her, also bring it to her if she was doing a photo shoot or, you know, on set or something, if she had forgotten it.
MS. VASQUEZ: What prescription drugs do you remember picking up for Ms. Heard?
KATE JAMES: Provigil.
MS. VASQUEZ: Any other prescription drugs that you remember picking up for Ms. Heard?
KATE JAMES: Accutane.
MS. VASQUEZ: Any others?
KATE JAMES: Not specifically.
MS. VASQUEZ: To your knowledge, did Ms. Heard ever stop taking Provigil or Accutane while you were working for her?
KATE JAMES: No.
MS. VASQUEZ: Did Ms. Heard ever tell you that she was experiencing any side effects from Provigil?
KATE JAMES: She dido 't say it, but I observed it.
MS. VASQUEZ: We'll go back to that in a minute.
MS. VASQUEZ: But did Ms. Heard ever tell you that she was experiencing any side effects from Accutane?
KATE JAMES: No.
MS. VASQUEZ: You previously testified that you observed Ms. Heard having certain side effects from Provigil, yes?
KATE JAMES: Yes.
MS. VASQUEZ: What side effects did you observe Ms. Heard exhibiting?
KATE JAMES: Manic episodes.
MS. VASQUEZ: Can you tell me what you mean by "manic episodes"?
KATE JAMES: Similar to if someone was on some sort of amphetamine drug, moving very fast, not making a lot of sense, hyperorganizing, hypertasking, just very, very hyper.
MS. VASQUEZ: Besides prescribed medication, did you ever observe Ms. Heard ingest any illicit drugs while you worked for her?
KATE JAMES: No.
MS. VASQUEZ: Did Ms. Heard ever tell you that she had ingested illegal drugs?
KATE JAMES: Yes.
MS. VASQUEZ: When did Ms. Heard tell you that she had ingested illegal drugs?
KATE JAMES: Sporadically here and there.
MS. VASQUEZ: What drugs did Ms. Heard tell you she had ingested?
KATE JAMES: Mushrooms, ecstasy, and cocaine.
MS. VASQUEZ: If you remember, how many times did Ms. Heard tell you that she had ingested illegal drugs?
KATE JAMES: I can't remember.
MS. VASQUEZ: Based on your personal observations, did it ever appear to you that Ms. Heard was under the influence of illegal drugs?
KATE JAMES: Yes.
MS. VASQUEZ: How many times?
KATE JAMES: I don't know.
MS. VASQUEZ: Less than five?
KATE JAMES: So long ago, it's hard for me to remember.
MS. VASQUEZ: Why did you -- why did it appear to you that Ms. Heard was under the influence of illegal drugs?
KATE JAMES: Disoriented, partying with friends, lots of heavy drinking, laughing, dancing, playing, all the sorts of things that go hand-in-hand with the imbibing in drugs.
MS. VASQUEZ: Would Ms. Beard's treatment of you change when she was intoxicated?
KATE JAMES: Yes.
MS. VASQUEZ: How so?
KATE JAMES: She became more and more belligerent and abusive.
MS. VASQUEZ: Ms. James, you previously testified that you provided testimony in a matter involving Mr. Depp in the United Kingdom. Do you remember that testimony?
KATE JAMES: Uh-huh, yep.
MS. VASQUEZ: And how did you provide testimony in the United Kingdom?
KATE JAMES: Well, I wrote a witness statement, and then I had to do a live video feed.
MS. VASQUEZ: And did you understand that your witness statement was made under oath?
KATE JAMES: Yes.
MS. VASQUEZ: And did you understand that your testimony during the trial live, was also under oath?
KATE JAMES: Yes.
MS. VASQUEZ: Did anyone help you write your witness statement?
KATE JAMES: Schillings, over in the U.K, helped me with the first draft, and then I took over and completely edited it to be my own words. That was after a phone conversation we had; I jotted down notes, sent me some basic notes to work with and then I worked on it from there.
MS. VASQUEZ: How long did it take you to write your witness statement?
KATE JAMES: About three or four days.
MS. VASQUEZ: Did you feel you had an adequate amount of time to prepare and write your witness statement?
KATE JAMES: Yes. I was very proud with the outcome, how I wrote it, because it was all my words and it was the absolute truth.
MS. VASQUEZ: And did you have enough time to review your witness statement for accuracy before you signed it?
KATE JAMES: Yes.
MS. VASQUEZ: Was everything that was in your witness statement true and accurate to the best of your knowledge?
KATE JAMES: Yes.
MS. VASQUEZ: And is that still true today?
KATE JAMES: Yes.
MS. VASQUEZ: Lucien, may I please have you pull up Depp Exhibit 4, please.
MS. VASQUEZ: TECHNICIAN: Depp Exhibit 4 on the screen.
MS. VASQUEZ: Thank you.
MS. VASQUEZ: Ms. James, do you remember receiving an email from Ms. Heard on or about February 12th,
KATE JAMES: I don't even believe I was still working that date.
MS. VASQUEZ: Do you remember receiving this email in particular from February 12th, 2015?
KATE JAMES: Again, I don't - as far as I know, I wasn't even working for her at that time, so I wouldn't even know why she wrote this letter to me, quite honestly.
MS. VASQUEZ: Do you remember receiving this email then?
KATE JAMES: No.
MS. VASQUEZ: Okay.
MS. VASQUEZ: Can we please pull up Exhibit Number 5.
MS. VASQUEZ: TECHNICIAN: Stand by.
MS. VASQUEZ: Depp Exhibit Number 5 on the screen.
MS. VASQUEZ: Lucien, may I ask you to -- there you go. You read my mind.
MS. VASQUEZ: Lucien, may I either take control or have you scroll down to the bottom. Thank you.
MS. VASQUEZ: Ms. James, the way these emails tend to work is they start at the bottom --
KATE JAMES: Yep.
MS. VASQUEZ: And then go up, and this one is no exception. So I'm going to, for your ease, I'm going to have you read the bottom email first, since it's the first one in the chain, dated February 3rd, 2015.
KATE JAMES: Uh-huh. Looks like she was traveling straight to London after the wedding. That's what I'm reading.
MS. VASQUEZ: Actually, you know what? Why don't you read this entire email chain, and then I'm going to ask you some questions about it.
KATE JAMES: Uh-huh. Can you help me? It says - I don't know. It's being finicky.
KATE JAMES: TECHNICIAN: Do you have control of it?
MS. VASQUEZ: I do have control.
MS. VASQUEZ: Sorry, Ms. James.
KATE JAMES: Thank you. I can go up a bit more now. Uh-huh.
MS. VASQUEZ: Do you remember receiving these emails from Ms. Heard?
KATE JAMES: Not really, no. No.
MS. VASQUEZ: Do you see where Ms. Heard on February 4th, 2015, writes in all caps "Are there no direct flights??!"
KATE JAMES: Uh-huh.
MS. VASQUEZ: I'm just pointing her to the top email, Mr. Rottenborn.
MS. VASQUEZ: Do you see where Ms. Heard writes to you "Are there no direct flights?" in all caps?
KATE JAMES: Yep.
MS. VASQUEZ: You would agree with me that nowhere else in this email chain Ms. Heard uses all caps to write to you, correct?
KATE JAMES: No, there's not. She seems very confused; that's all I can say. When I'm reading through this, that's all I can say; she just seems very confused. Everything is its own, like if that question were to be directed to anyone, it should have been to the travel agent, not me. I mean, I'm not the travel agent. The travel agent was down there in the beginning, Trudy Salven.
MS. VASQUEZ: Direct your attention, Ms. James, to May of 2014 when you met Ms. Heard at the Chateau Marmont in Los Angeles California. 1! Do you remember your testimony about that incident? You testified previously that she -- that Ms. Heard asked you to bring a bathing suit to the hotel; is that correct? 1;
KATE JAMES: Yes.
MS. VASQUEZ: Did you see Ms. Heard wearing a bathing suit in May of 2014 at the Chateau Marmont?
KATE JAMES: Yes.
MS. VASQUEZ: Based on your recollection, did you see any bruises on Ms. Heard's body?
KATE JAMES: No.
MS. VASQUEZ: Did you see any red marks on Ms. Heard's body?
KATE JAMES: No.
MS. VASQUEZ: How would )'OU describe the general atmosphere or mood of Ms. Heard and her friends at the Chateau Marmont?
KATE JAMES: To be honest, it seemed a little conspiratorial to me.
MS. VASQUEZ: How so?
KATE JAMES: Like a strategy meeting or something and combined with a pool party. Hard to describe. It was very confusing. Originally I thought I was going over for some major emergency, but then something else completely different was going on that day.
MS. VASQUEZ: What made you think something completely different was going on that day?
KATE JAMES: Well, because originally it made it seem like she was having this major emergency, and she was completely alone and she needed me very badly to come as quickly as possible. But when I got there she was surrounded by people, Savannah, iO Tillett Wright, and Rocky specifically, Raquel Pennington.
KATE JAMES: COURT REPORTER: What was the second name you said? I got Rocky and who?
KATE JAMES: IO Tillett Wright, it's the letter I, the letter O, Tillett Wright.
MS. VASQUEZ: Did you observe Ms. Heard showing what appeared to be injuries to any of her friends at the Chateau that day?
KATE JAMES: No.
MS. VASQUEZ: Did it appear to you that Ms. Heard's friends were comforting her? How would you describe Ms. Heard's friends' behavior?
KATE JAMES: Friends hanging out together by the pool, having cocktails, and spending the entire afternoon hanging around together.
MR. ROTTENBORN: Did you ever learn information that made you believe that one of the reasons that the relationship between Johnny and Amber wasn't, as you described, perfect was because of Johnny's substance abuse?
KATE JAMES: I couldn't speculate on the details of their personal relationship.
MR. ROTTENBORN: You did testify earlier that one of the reasons you thought their relationship wasn't perfect was insecurity on Amber's part, though, right?
KATE JAMES: Yes.
MR. ROTTENBORN: So you developed an opinion that insecurity on Amber's part affected their relationship, but you did not develop an opinion that substance abuse or any actions by Johnny affected their relationship; is that right?
KATE JAMES: That statement was based on communications directed to me from Amber, basically.
MR. ROTTENBORN: What communications specifically?
KATE JAMES: Expressing, you know, exactly what I just stated. That she was sad. She didn't want to be away from him, blah, blah, blah. That sort of thing. It would happen all the time.
MR. ROTTENBORN: And you believed that those statements were the reason that their relationship wasn't perfect?
KATE JAMES: It's not for me to speculate.
MR. ROTTENBORN: You would agree that just because someone is insecure in a relationship, does not mean that she deserves to be abused, correct?
KATE JAMES: I have no answer for you to that.
MR. ROTTENBORN: You would agree that even if someone acts "smothering" in a relationship, doesn't mean she deserves to be abused, correct?
KATE JAMES: I don't have an answer for you for that.
MR. ROTTENBORN: I don't have any further questions. Thank you for your time today.
THE COURT: All right. Thank you.