Laurel Anderson — Direct/Cross/Redirect/Recross
548 linesTHE COURT: All right, ladies and gentlemen, let's go ahead and take our morning recess for 15 minutes. No outside research. Do not talk about the case.
THE COURT: Okay. Thank you.
THE COURT: All right. Let's go ahead and take a break until noon. Is your next witness --
THE COURT: We're going to set it up so it's all ready to go.
THE COURT: Really appreciate that. Okay. Be in recess until 12.
COURT BAILIFF: All rise.
THE COURT: All right. Are we ready for the jury?
THE COURT: Everything's working, right?
THE COURT: All right, good. Thank you. Thank you.
THE COURT: All right. Thank you. Your next witness.
DR. ANDERSON: Laurel Avis Anderson.
MR. NADELHAFT: And what is your business address?
DR. ANDERSON: It's been a while. 10921 Wilshire Boulevard, Westwood Medical Plaza, Suite 1101, Los Angeles 90024.
MR. NADELHAFT: And you're a clinical psychologist; is that correct?
DR. ANDERSON: Correct.
MR. NADELHAFT: And you practice in Los Angeles?
DR. ANDERSON: Yes.
MR. NADELHAFT: For how long have you been practicing?
DR. ANDERSON: Almost 40 years.
MR. NADELHAFT: Have you been practicing in Los Angeles for that entire time?
DR. ANDERSON: Yes.
MR. NADELHAFT: And you provide counseling for couples?
DR. ANDERSON: Psychotherapy for individuals and couples.
MR. NADELHAFT: And what is psychotherapy, just a brief layman's description?
DR. ANDERSON: It's an evaluation of an individual or couple's problems, and then it's a conceptualization of what's actually going on in an effort to make interventions that lead to change.
MR. NADELHAFT: So you recognize what this document is?
DR. ANDERSON: Yes.
MR. NADELHAFT: What is it?
DR. ANDERSON: This is my ledger for tracking sessions that I use for invoice - billing.
MR. NADELHAFT: And did this ledger come out of your files?
DR. ANDERSON: Yes.
MR. NADELHAFT: And do you keep this document in the ordinary course of business?
DR. ANDERSON: Absolutely.
MR. NADELHAFT: Okay. And I just want to -- and this particular ledger, who is it for?
DR. ANDERSON: It's - well, despite the names that are camouflaged, it's for Ms. Heard and Mr. Depp.
MR. NADELHAFT: At the top, what are the two names that it says there?
DR. ANDERSON: Ann Henry and Joey Davis.
MR. NADELHAFT: And Ann Henry is Amber Heard?
DR. ANDERSON: Yes.
MR. NADELHAFT: And Joey Davis is Johnny Depp?
DR. ANDERSON: Yes.
MR. NADELHAFT: And then it says age 29 and 52; is that right?
DR. ANDERSON: Yes.
MR. NADELHAFT: And 29 was the age of Amber Heard at the time?
DR. ANDERSON: Yes.
MR. NADELHAFT: And 52 was the age of Johnny Depp?
DR. ANDERSON: Yes.
MR. NADELHAFT: So as I understand it, on October 1st, 2015, Mr. Depp and Amber Heard came in for couples counseling at-- for 3 1/2 hours?
DR. ANDERSON: Yes. Whether they were in for the full 3 1/2 or not, I don't know. But that was the amount - that was when the session started, and they came in when they came in, not together, and it took 3 1/2 hours to actually do that first session.
MR. NADELHAFT: So as I understand it, for that first session, Mr. Depp and Amber Heard did not come in together?
DR. ANDERSON: I don't believe that they did. The next session with Amber - with Ms. Heard alone, for background intake, and that was a 2 1/3-hour session.
MR. NADELHAFT: And that session was on October 6th, 2015?
DR. ANDERSON: Yes.
MR. NADELHAFT: And what's the next row indicate?
DR. ANDERSON: The next day -
MR. NADELHAFT: You saw Amber October 6th, 2015 for 2 1/3 hours, correct?
DR. ANDERSON: Yes.
MR. NADELHAFT: And what is the next row indicating?
DR. ANDERSON: The next day, October 7th, Mr. Depp, for 3 1/2. Again, it may not have been face-to-face for the full 3 1/2, but it was being at the beginning of the session waiting for him, his coming in with the entourage, and our getting to work.
MR. NADELHAFT: And for the three sessions we just discussed, the October 1st session, the October 6th session, and the October 7th session, those were all in person with you, correct?
DR. ANDERSON: So, yes. The first three sessions were all in person.
MR. NADELHAFT: And then what does it say under -- for the next row, for the 10/14 row?
DR. ANDERSON: Couple, three hours.
MR. NADELHAFT: So October 14th, 2015, Amber Heard and Mr. Depp saw you for couples session?
DR. ANDERSON: Yes.
MR. NADELHAFT: There's a couple session on October 14th for three hours; is that right?
DR. ANDERSON: 10/14, there's a couple session. On 10/21 there's a couple session where someone walked out, for two hours. On 10/24, Ms. Heard was there. We did a phone session for one and a half.
MR. NADELHAFT: And how did -- and on the 10/24 row, next to the two hours, it says "W out," correct?
DR. ANDERSON: It's 10/21.
MR. NADELHAFT: In the 10/21 row, what does it say in the fourth column?
DR. ANDERSON: Walk - for me, that's "walk out."
MR. NADELHAFT: And do you recall who walked out of that meeting?
DR. ANDERSON: I have tried to, and I don't. Because each threatened and stood up, and I'm not positive who finally did the walkout.
MR. NADELHAFT: And then what does it say -- what is it indicating on the row for 11/12/2015?
DR. ANDERSON: Couples session showed, one and a half hours.
MR. NADELHAFT: And then on 12/17, what does that show?
DR. ANDERSON: Amber alone show two and a quarter hours.
MR. NADELHAFT: Based on this, you saw Amber and Mr. Depp for four couples sessions?
DR. ANDERSON: That's right.
MR. NADELHAFT: Dr. Anderson, I'm showing you what's been marked as Anderson 3.
MR. NADELHAFT: And, your Honor, at this time, we're looking to move Defendant's Exhibit 397. I understand there's no objections.
THE COURT: All right. 397, no objection; is that correct?
MR. NADELHAFT: They didn't list objections in their exhibit list, and then we actually communicated this morning and they said they weren't objecting.
THE COURT: Do you know who on the team you talked with? I'm sorry.
MR. NADELHAFT: Do you want me to ...
THE COURT: No, that's all right, who?
MR. NADELHAFT: I believe it was Jessica Meyers.
THE COURT: All right. So no objections. All right.
MS. MEYERS: Sorry, Your Honor.
THE COURT: 397 in evidence, then, Defense 397.
MR. NADELHAFT: And I will let you -- which is CCOOOL 72, I'll let you take a look at it. It's a one-page email. Just let me know when you're finished.
MR. NADELHAFT: Do you recognize this email chain?
DR. ANDERSON: Yes.
MR. NADELHAFT: Do you know who Christian Carino is?
DR. ANDERSON: Yes.
MR. NADELHAFT: On the page where it says laurel.anderson28@gmail.com, that's your email address?
DR. ANDERSON: Yes.
MR. NADELHAFT: The email March 28th, 2015, from Mr. Carino, he wrote, "Laurel...my closest friend Amber (on copy) wants to come see you ... alone first and then with her husband Johnny. Will leave it to you two to arrange a time. Love you both."
MR. NADELHAFT: Do you see that email? Did you receive that email from March 18th, 2015?
DR. ANDERSON: I did.
MR. NADELHAFT: Okay. And you responded to Mr. Carino's email, correct?
DR. ANDERSON: As you can see, yes.
MR. NADELHAFT: What was your understanding as to why Amber Heard wanted to meet with you?
DR. ANDERSON: I took it at face value that Ms. Heard wanted to have a consultation, and if - this is not infrequent, that I might get an email like this -- so and when I hear that someone may then later want to come in with husband or spouse, yes, I think it has to do with relationship issues.
MR. NADELHAFT: On September 9th, 2015, you received an email from Mr. Carino; is that right?
DR. ANDERSON: Yes, apparently. He was trying to set it up.
MR. NADELHAFT: And Mr. Carino was trying to set up a meeting with you and Amber and Mr. Depp; is that right?
DR. ANDERSON: Yes. That's what I assumed.
MR. NADELHAFT: And you responded to Mr. Carino's email, correct?
DR. ANDERSON: I did.
MR. NADELHAFT: And then at the top, you received an email from Amber Heard?
DR. ANDERSON: Yes.
MR. NADELHAFT: And she wrote, "Hi Laurel. Thank you I so much for responding. I really appreciate it.
MR. NADELHAFT: "I have to speak to my husband when he's done working today and make sure he's good with that time. I think it sounds perfect. Thank you so much again. I'm really looking forward to meeting you."
MR. NADELHAFT: Did I read that correctly?
DR. ANDERSON: Yes.
MR. NADELHAFT: And you received that email from Amber Heard?
DR. ANDERSON: I did.
MR. NADELHAFT: On September 27th, 2015, you received an email from Amber Heard, correct?
DR. ANDERSON: Yes.
MR. NADELHAFT: And Amber wrote, "Hi Laurel. Johnny and I are back in town and would love to know if you have any availability to see us this week. Please let me know. Thanks."
MR. NADELHAFT: You received that email from Amber Heard?
DR. ANDERSON: Yes.
MR. NADELHAFT: And you responded that you were available on Thursday at 5:30 p.m., correct?
DR. ANDERSON: Yes.
MR. NADELHAFT: And looking at the top of the email where it says Wednesday, September 30th, would you agree that the next day is Thursday, October 1st, 2015?
DR. ANDERSON: Yes.
MR. NADELHAFT: Okay. And if we need to, we can go back to your billing ledger, but the first time IO you saw Amber Heard and Mr. Depp was on October 1st, 2015; is that right?
DR. ANDERSON: Yes.
MR. NADELHAFT: Did you see Amber Heard on December 17th, 2015?
DR. ANDERSON: Yes. We had established that. Yes.
MR. NADELHAFT: Dr. Anderson, I'm showing you what's been marked as Anderson Exhibit 7, which is Depp -3202. Take a chance to read it, and let me know when you're finished.
DR. ANDERSON: Yes.
MR. NADELHAFT: Attachment 7 is an -- at the bottom it is a -- you see a March 8th, 2015 email from Christian Carino to you, correct?
DR. ANDERSON: Yes.
MR. NADELHAFT: And Christian Carino was asking if you'd be willing to make a house call to Johnny Depp's apartment downtown; is that right?
DR. ANDERSON: I did not know where he lived.
MR. NADELHAFT: But in his email it says "Would you be willing to make a house call to Johnny's apartment downtown," correct?
DR. ANDERSON: Did it say "downtown"? Yes, it did. Okay.
MR. NADELHAFT: And then, you responded on March 8th, 2016, correct?
DR. ANDERSON: Yes.
MR. NADELHAFT: And you wrote "Hey Christian, Have, of course, avoided this my whole career, unless someone was in rehab. Would be willing to try it once in that there's something I'd like Johnny to understand that I don't think he does."
MR. NADELHAFT: Where you wrote: "I'd like Johnny to understand," were -- where you wrote "Would be willing to try it once in that there's something I'd like Johnny to understand that I don't think he does," what did you mean by that?
DR. ANDERSON: I can't say exactly what it was I wanted to impart, but I know that I thought that he was having difficulty in the sessions, and I think there was something about the process between the two of them that I was trying to clue him into.
MR. NADELHAFT: What difficulty was Mr. Depp having in the sessions?
DR. ANDERSON: Having a voice.
MR. NADELHAFT: What do you mean by that?
DR. ANDERSON: Ms. Heard had a jackhammer style of talking. She was very amped up. He had trouble talking at a similar pace. Their dialogue, he was cut off a lot. So I'm guessing this is what I was - I'm not sure what it is, but it was something - anyhow, this is how he didn't have a voice. He couldn't keep up with her rapid-fire way of conversation. And so he was really overwhelmed.
MR. NADELHAFT: In working with Amber and Mr. Depp, did Amber ever report to you any physical violence on behalf of Mr. Depp toward Amber?
DR. ANDERSON: Yes.
MR. NADELHAFT: What type of physical violence did she report to you? Do you recall seeing photos from Amber Heard?
DR. ANDERSON: I have, but I don't remember when I saw them
MR. NADELHAFT: What do you recall about the photos?
DR. ANDERSON: Her face was bruised.
MR. NADELHAFT: Do you recall where on her face you saw -- on Amber's face you saw bruises?
DR. ANDERSON: I think they were around her eyes, but I couldn't be positive.
MR. NADELHAFT: Did you witness abuse by either?
DR. ANDERSON: I didn't witness.
MR. NADELHAFT: Had you worked with Mr. Depp before working with Amber and Mr. Depp?
DR. ANDERSON: No.
MR. NADELHAFT: Is it your testimony that while Mr. Depp may have said he wasn't violent with any of his other partners, there was violence between -- from Mr. Depp toward Amber, correct?
DR. ANDERSON: Yes. You're right. He had been well controlled, I think, for almost, I don't know, 20, 30 years. And both were victims of abuse in their homes. But I thought he had been well controlled for decades. And then with Ms. Heard, he was triggered, and they engaged in what I saw as mutual abuse. Sometimes -- I'm not -- I know she led, on maybe one occasion, and started it to keep him with her because abandonment and having him leave was her worst nightmare. And I think he may have initiated it on occasions too, and that I'm less sure of.
MR. NADELHAFT: And how did you come to the understanding that on some occasions, Ms. Heard physically abused Mr. Depp?
DR. ANDERSON: Ms. Heard reported that.
MR. NADELHAFT: What did Ms. Heard report to you?
DR. ANDERSON: That it was a point of pride -- two things. It was a point of pride to her, if she felt disrespected, to initiate a fight. Her father had beaten her. She was not going to -- And the second one is that she reported to me, which is if he was going to leave her to deescalate from the fight, she would strike him to keep him there. She would rather be in a fight than have him leave.
MR. NADELHAFT: Did you speak to any other doctors or psychologists that worked with either Amber or Mr. Depp?
DR. ANDERSON: No.
MR. NADELHAFT: Did you review any medical documents of Mr. Depp or Amber?
DR. ANDERSON: I reviewed a pharmacokinetic that Ms. Heard showed me which has to do with neurotransmitter function, genetics, and medications.
DR. ANDERSON: I have a couple of master's, a Ph.D., and a certified clinical nutrition certification.
DR. ANDERSON: Yes. I have a master's from Young in my early life in teaching curriculum. I have a master's in psych. I have a Ph.D. in clinical psychology. I have a CCN, which is a certified clinical nutrition certification.
DR. ANDERSON: Yes. I got it in '82.
MR. CHEW: And very briefly, if you could just please, in summary fashion, just describe your employment history from 1982 forward after earning your Ph.D.
DR. ANDERSON: I collected clinical hours in hospitals and in psychiatric medical groups. I was employed to do some nutrition evaluation and intervention as well, but there were MDs behind me. We worked in concert.
DR. ANDERSON: Then worked in a hospital which I think --
DR. ANDERSON: Was workers' comp. And then when I was, you know, I have it out of order. Then I was on my own, but I was employed by - this is when I was employed by a psychiatric medical group to do kind of a combination of psychotherapy and some nutrition. And then, since then, I have been a solo practitioner, out of network, word of mouth only, very small footprint, purposely, all of these years.
DR. ANDERSON: Very soon. Probably in - probably in - probably in '86.
MR. CHEW: So is it fair to say that as of 2015, you were already quite established as a solo practitioner?
DR. ANDERSON: Yes.
DR. ANDERSON: Adult-only, individual or couples work, and with a limited number of people, there would have been neurotransmitter testing and some attention to lifestyle and how nutritional elements affect the brain.
MR. CHEW: And if you would, just please describe for us laypeople what a clinical psychologist does.
DR. ANDERSON: The first thing is evaluation, intake, gather material.
DR. ANDERSON: The second thing in the way I work is during the intake process, could be one session, could be four sessions, depends on if it's an individual or a couple, I'm conceptualizing. I'm looking for the process. The content is something I make notes on, I care about, it leads me from session to session. But I'm really looking at process, what's going on between two people or what's actually going on inside of someone.
DR. ANDERSON: The third step is I'm -- I show my hand. I talk about it. I try to get either three people in the room all on the same page with me, or one other person. This is what I see. And then the onus is on me to not just be a good friend and hold someone's hand and talk about Mom, but to actually make change. And so I lay out Here are the things I think we need to work on. And then there are action steps for all of them so that someone has a more directed sense of what they're doing in psychotherapy, as opposed to just coming in am;l.talking about how they feel.
MR. CHEW: Is it your practice, when you have a session with a couple, that you take notes from the session?
DR. ANDERSON: I absolutely take notes from any session.
DR. ANDERSON: I'm taking them during the session, and they know it Because I don't want hours and hours and hours of homework at the end of a clinical day. So the notes are often, you know, a lot of typos, wrong pronouns here and there. But essentially I'm just trying to gather facts as I go.
DR. ANDERSON: Sure.
DR. ANDERSON: Absolutely.
MR. CHEW: Do you maintain or do you keep those notes as part of your treatment and regular course -- ordinary course of business?
DR. ANDERSON: I do.
MR. CHEW: And what type of information, generally, do you keep in your notes, other than what you've already testified about?
DR. ANDERSON: Whatever I want to. Anything that - it could be content that I'm tracking, just so I know in the next session what kind of content we were talking about, and it could be process, too.
DR. ANDERSON: TECHNICIAN: Stand by and I'll mark notices as Plaintiffs Exhibit Number 1. Showing you 1 on screen.
DR. ANDERSON: Yes.
DR. ANDERSON: It's Christian Carino during the first contact, and the second one is from Ms. Heard wanting to know how to get in touch with me.
MR. CHEW: But accepting what's been thrust upon us, when was your first couples therapy involving Ms. Heard?
DR. ANDERSON: October 1st, 2015.
DR. ANDERSON: Yes.
DR. ANDERSON: In my office.
DR. ANDERSON: Yes.
DR. ANDERSON: Three and a half hours.
DR. ANDERSON: I think so.
DR. ANDERSON: Yes.
MR. CHEW: Okay. Now, if you could please turn -- and this is a multi page exhibit, Mr. Nadelhaft did not show you. This is going to be Plaintiffs Exhibit 2.
FEMALE SPEAKER: Adam, can you turn up your microphone because everyone's a lot louder than you, and when you object, I struggle to hear you.
MR. NADELHAFT: Can you hear me? FEMALE SPEAKER: Michelle is a lot louder than you, so if you talk at the same time, I can't hear you.
MR. NADELHAFT: All right. I'll see what I can do.
MR. NADELHAFT: FEMALE SPEAKER: Thank you
MR. CHEW: And, Dr. Anderson, if you could just take as long as you would like to familiarize yourself with this document, I'll just state for the record these are documents that you produced that have a Bates designation 1 through 17.
DR. ANDERSON: Yes, I'm familiar.
MR. CHEW: What are these -- well -- strike that. Have you ever seen Plaintiff's Exhibit 2 before?
DR. ANDERSON: Yes.
DR. ANDERSON: It's a redacted copy of my personal notes that I provided to you guys.
MR. CHEW: And are these -- I think you testified in response to Mr. Nadelhaft's questioning that the names Ann Henry and Joey Davis are pseudonyms.
DR. ANDERSON: Yes.
DR. ANDERSON: Ann Henry and is Amber Heard Joey Davis is Johnny Depp.
MR. CHEW: And are these your notes that you took contemporaneously of the for-couples -- strike that.
DR. ANDERSON: Yes.
MR. CHEW: Would these notes include any session that you had for Ms. Heard that was not part of the couples therapy?
DR. ANDERSON: No.
MR. CHEW: Did you have any sessions with Mr. Depp individually that weren't part of the couples therapy?
DR. ANDERSON: No. During this period of time, it's color coded Black is couples, red is Ms. Heard, and blue is Mr. Depp. Whether I talked to them or saw them individually or as a couple, it was all in service of couples therapy.
MR. CHEW: Understood. And so these notes in Plaintiff's exhibit 2 .encompass all of the couples therapy sessions that you had with Mr. Depp and Ms. Heard, either when they appeared together or when they appeared separately, in the context of your couples therapy; is that correct?
DR. ANDERSON: I'm looking at one page. You're talking about the entire redacted document, yes.
MR. CHEW: And I've asked you the question generally, but I want to ask you in the context of these 17 pages.
MR. CHEW: Did you prepare these 17 pages of couples therapy notes in the ordinary course of your treatment of Mr. Depp and Ms. Heard?
DR. ANDERSON: Yes.
DR. ANDERSON: I did.
DR. ANDERSON: I'm going to look at what I'm reading so that this makes sense to you. This can't possibly make sense, but it makes sense to me.
DR. ANDERSON: They reported what they said to one another. So the first line is Ms. Heard talking, saying that Mr. Depp says to her "No one likes you. You're getting fame from me. I'm falling out of love with you. You're a whore."
DR. ANDERSON: She's reporting, just in the first session, just how bad the relationship is, just how mean they are to one another.
DR. ANDERSON: And at that point, because I'm typing quickly as they go along, I'm switching into a different voice more about the process between them where she has, I believe, interrupted him. He says no more about what she says about him, and it's just that they're fighting and she has a hard time -- she bites the bait. She can't let him talk is my recollection and from this -- that's kind of what that is.
DR. ANDERSON: So it gives me a sense of what they're doing at home. They're each reporting, "This is what we say to each other."
MR. CHEW: Okay. I appreciate that, Dr. Anderson. I'm just going to try to break it down into little bits. So October 1, 2015 is the date of the first couples session, correct?
DR. ANDERSON: Yes.
DR. ANDERSON: I am guessing they were in -- they were present for 2 1/2 hours, but that I waited whatever the first - the ledger says, but I waited an hour for them to show up.
MR. CHEW: And Dr. Anderson, in that first bullet point that we can see, you write, "J says no one likes you. Getting fame from me. Falling out of love with you whore," J is Johnny Depp?
DR. ANDERSON: Yes. But that was said by Ms. Heard.
MR. CHEW: So is it fair to say that Ms. Heard was saying that Johnny said to her, "No one likes you're. You're getting fame from me. I'm falling out of love with you, whore," that would have come from Mr. Depp; is that correct?
DR. ANDERSON: Ms. Heard reported that that's what Mr. Depp said to her at her worst, yes.
MR. CHEW: Did Amber -- when Mr. Depp told you that Amber had hit him in the jaw, did Amber respond in any way? Did she deny it? Did she admit it?
DR. ANDERSON: I don't think she denied it, but what I believe, from my notes, was that they galloped - she galloped off in a new direction and they continued to talk and there was no more that Johnny Depp was going to say about what he was reporting. It was more that they started into a fight.
DR. ANDERSON: And I wrote that their process is a back-and-forth firing at each other. At that low point, he had some energy. And they don't communicate. They had terrible skills.
MR. CHEW: At any point during the first session, did Ms. Heard interrupt Mr. Depp when he was trying to talk?
DR. ANDERSON: Yes. She talked over him. She had rapid-fire talking.
MR. CHEW: Did she interrupt him during your other sessions that are reflected in Plaintiffs Exhibit 2?
DR. ANDERSON: Yes. And I pointed out the process to her at some point, and she got it, that no one could actually have a decent dialogue with her if she was rapid firing and talking over and just barraging. It was a process issue.
MR. CHEW: You write, "Doesn't answer directly when he asks her a question." To what were you referring there?
DR. ANDERSON: Don't have a clue.
MR. CHEW: If I could direct your attention further down the page from plan, you see the notation to October 6th, 2015?
DR. ANDERSON: Yes.
DR. ANDERSON: No. It's red. It's Amber alone.
MR. CHEW: So is it fair to say that you met alone IO with Amber for 2 1/3 hours in the context of the couples therapy; is that'correct?
DR. ANDERSON: A Yes. This was to get her background material.
MR. CHEW: So tell us what you mean in that one section, "He hits her, no closed fist. She hits back d now starts it for pride because" --
DR. ANDERSON: Father.
DR. ANDERSON: This is her reporting to me. It's the only thing in this clinical session that apparently was about physical abuse, or else it would not have been redacted out. It's so when she said in terms of physical abuse, that he hits her, no closed fist means a open-hand slap to me, and she says that she hits back and now she starts it and sometimes hits him first because her history is having been violated by her father physically. And just out of pride, she - if she's - a lot of things trigger her, and if she's triggered, she would hit him first.
DR. ANDERSON: Yes.
MR. CHEW: When you said that she sometimes hits Johnny first because of pride, what did you mean?
DR. ANDERSON: She was sensitive to feeling disrespected and a number of other things, but - and, so, and if she felt disrespected, she had come out of her background history feeling that her pride needed to be - needed to dominate and she needed to stand up for herself.
MR. CHEW: When Ms. Heard told you that Johnny Depp hits her or slaps her, Johnny Depp was not present, correct?
DR. ANDERSON: Correct. And it wasn't plural. It was she referred to - well, I wrote he hits her, yes. So maybe it was plural.
DR. ANDERSON: He was not.
DR. ANDERSON: Yes. She was describing kind of the progression of the physical violence.
MR. CHEW: Did you have any understanding of what she meant when she admitted that she socks Mr. Depp?
DR. ANDERSON: Yes, because there were three lines above this that explained the progression a bit, and I've already said what it was. She felt she had to hit him back if he hit her, and so she always did, and -
MR. CHEW: And, again, that entry is from a session where Mr. Depp was not physically present, correct?
DR. ANDERSON: That's right.
MR. CHEW: Okay. Let's move to the next session, October 7, 2015, and this is a 3 1/2-hour session; is that correct?
DR. ANDERSON: Yes.
DR. ANDERSON: Yes.
DR. ANDERSON: No. This is blue. This is John's - Mr. Depp's intake.
MR. CHEW: Understood. And let's move, now, to the -- toward the bottom of the page, and I think I'm finally getting the code, right? So the next session occurred on October 14th, 2015, and it was the two of them for three hours; is that correct?
DR. ANDERSON: A Yes.
DR. ANDERSON: Yes.
MR. CHEW: And am I right to say that every single piece of your notes as to the October 14th, 2015 session has been redacted; is that true?
DR. ANDERSON: Yes. But to clarify something earlier on the ledger.
DR. ANDERSON: I wrote two hours couple then Amber. It means he is the one who walked out of that session.
MR. CHEW: My question was am I correct that all of your notes for the October 14th, 2015 couples session for three hours are completely redacted; is that true?
DR. ANDERSON: A Yes.
DR. ANDERSON: True.
MR. CHEW: And lasted two hours; It started as a couple, then Mr. Depp left, and then you spoke only with Amber but in the context of couples therapy; is that right?
DR. ANDERSON: Yes.
MR. CHEW: Okay. Let's go to the next session on page 10. The next session was on October 24th, 2015, and I can't see from the code. Was that a couples therapy or was it just one or the other of them attending?
DR. ANDERSON: No, no, no. This is a red phone session with Ms. Heard.
DR. ANDERSON: Yes.
DR. ANDERSON: Yes.
DR. ANDERSON: That one? No. That one was canceled.
MR. CHEW: Oh, it was canceled. That's why it's so short. Okay. And then the one after that, still on page 10, was on November 12th, 2015?
DR. ANDERSON: There's an appointment on 11/4 that was canceled that I didn't put an entry on.
DR. ANDERSON: Yes.
DR. ANDERSON: Yes, it was.
DR. ANDERSON: Yes.
MR. CHEW: Okay. And then the next session on page 11 is -- that, even I can understand. So there was a no-show on December 4th, 2015; is that right?
DR. ANDERSON: Yes. I'd like to clarify the no-shows.
DR. ANDERSON: I think they both told me, but I think Mr. Depp told me at one point but I already knew because this happens with couples. When a couple is having a lot of trouble in sessions but they're doing well at home and they're in a little bit of a honeymoon, you know, period, they cancel instead of coming in because they know coming in will get them into conflict.
DR. ANDERSON: I can't tell which sessions they were .sick or which sessions they were canceling because of this dynamic. But it was admitted and explained to me, and I understood it fully.
MR. CHEW: Okay. And still on page 11, the next session was on December 15th, 2015, and it was a telephonic session; is that right?
DR. ANDERSON: With -- yes, with Ms. Heard.
MR. CHEW: You write then "Last night, Monday, she slapped him as he sat there talking incoherently."
DR. ANDERSON: I actually -- I actually know what happened.
DR. ANDERSON: This was, as I said, Ms. Heard talking on the phone to me. Mr. Depp's mother was in ICU. He had been doing a lot of -- he was fucked up, as she would say, on a lot of drugs, and she slapped him because he was being incoherent and talking about another -- being with another woman.
MR. CHEW: Did she tell you that he had hit her first? Or was she the one who initiated the slap?
DR. ANDERSON: She initiated that one because I think she felt demeaned and threatened.
DR. ANDERSON: Yes.
DR. ANDERSON: No.
DR. ANDERSON: No.
DR. ANDERSON: No.
DR. ANDERSON: Where is that?
MR. CHEW: That's right below what we were just talking about. In red it says, "Should she call police?"
DR. ANDERSON: That was her asking me.
DR. ANDERSON: I believe I did.
DR. ANDERSON: Yes.
DR. ANDERSON: She loved him. He loved her. She believed that - she wasn't stupid. She knew that what they were doing wasn't healthy, and so she wanted to want to divorce him, but she didn't. And yet it had escalated to this point, so she was trying to figure out what to do. And she had an entourage around her telling her what to do.
DR. ANDERSON: She had a routine group of friends that stayed with her, lived in her home, probably as well as paid people that I don't know.
DR. ANDERSON: One was Rocky.
MR. CHEW: Directing your attention to the last snippet from that session, "Will she have advantage if she leaves him but files with police for abuse first?" Was that a question that she asked you?
DR. ANDERSON: Yes. This was her talking out loud, trying to strategize for herself.
TECHNICIAN: Showing Plaintiff's Exhibit 3 on the screen.
MR. CHEW: And, Dr. Anderson, I think this is the same document that Mr. Nadelhaft showed you as Anderson exhibit 6. So I'm not going to ask you to identify it again, but I do have a couple of questions about it that Mr. Nadelhaft did not ask.
MR. CHEW: I believe you testified, and correct me if I'm wrong, that you have never spoken to any of Ms. Heard's other psychologists or therapists; is that true?
DR. ANDERSON: That's true.
MR. CHEW: And putting that aside, when she refers to her own therapists in this exhibit, 3, do you know the name of that person, putting aside whether you had ever spoken to him or her?
DR. ANDERSON: I do not.
MR. CHEW: Okay. Did Ms. Heard ever explain to you why the nuances and complexity of her relationship with Mr. Depp would be lost on her own therapist?
DR. ANDERSON: I believe that she felt known in a more thorough way in terms of her behavior inside of the relationship.
MR. CHEW: And let's pick up where we left off on the bottom of page 11 of Plaintiff's Exhibit 2.
DR. ANDERSON: Okay.
MR. CHEW: And specifically, the entry that begins on January 13, it's at the very bottom of page 11, literally the last line. Oh, that's it.
MR. CHEW: On January 13, 2016, was this a joint session with Mr. Depp and Ms. Heard? Or was this just with one of them?
DR. ANDERSON: It was only Ms. Heard And let me go back and see if it - it was phone. No, no, no. I'm sorry. It was in person. No, no, no. That's wrong. 1/13/16 was Ms. Heard in person.
MR. CHEW: And do you know how long this in-person session was with Ms. Heard on January 13, 2016?
DR. ANDERSON: I think it was probably just one hour.
MR. CHEW: Okay. You write, "Didn't fight on" island till last day. On island started to get into something.
DR. ANDERSON: Well, Christmas had occurred, and the goal was - they had a lot of people going to his island, and they were going to be together. And the goal was to try and get through the Christmas holiday without fighting. And so she was reporting on that.
MR. CHEW: Okay. Then you write, "He got aggressive, threatening. Didn't touch him. Hid in bathroom."
DR. ANDERSON: What she reported to me, which was an improvement, that she didn't participate.
DR. ANDERSON: Yes. That's what I believe my notes say, yes.
MR. CHEW: Then you write, "She threw can at him since home fighting, then she better." Who is the "she" who threw a can at him?
DR. ANDERSON: Ms. Heard.
DR. ANDERSON: Yes.
DR. ANDERSON: Well, apparently, because I responded in the morning.
MR. CHEW: So the response at the top of the page, the second entry, I suppose, did you write that email to Mr. Carino on March 8th, 2016 at 7:27 a.m.?
DR. ANDERSON: I did.
DR. ANDERSON: I was not.
MR. CHEW: And Mr. Nadelhaft asked you about what it was you wanted Johnny to understand about the process.
DR. ANDERSON: And I was wrong. Because I can see now the date of it, looking at it more carefully, this is after their relationship has devolved considerably. So what I think, just guessing, was earlier in the relationship. I don't know what it was I wanted him to understand.
MR. CHEW: Let's go back to Exhibit 2, then, please, and we're not going to repeat. We're just picking up where we left off. And now we've gotten up to page 13 of the 17 pages of your notes.
MR. CHEW: So if we can start -- exactly. Do you see where the notes of your session on June 18th, 2016 begin?
DR. ANDERSON: Yes.
DR. ANDERSON: This is with Mr. Depp. It's blue; it's just the two of us.
DR. ANDERSON: Yes.
MR. CHEW: You write, "Fight on her April 22nd birthday. He late, huge fight. His mother died on the 20th."
MR. CHEW: I think I !mow what you're referring to, but if you could, please describe that for the record.
DR. ANDERSON: One second. This is when I got the Scaramanga productions on my phone, so he found me at home, which was new. Domestic violence charges had already been made. His mother had just died on the 20th.
MR. CHEW: Well, when he told you that there was a fight on April 22 birthday, was that Ms. Heard's 30th birthday?
DR. ANDERSON: I think it was.
MR. CHEW: And is he telling you that he arrived late for the birthday dinner party and there was a huge fight?
DR. ANDERSON: Yes.
DR. ANDERSON: Well, I know her name. I know she was someone that Ms. Heard was in a relationship with.
MR. CHEW: Then you write, "Was chaotic, violent, but gave as good as she got." What does that mean?
DR. ANDERSON: I believe I'm quoting -- I think I'm quoting what -- some of this is just my typing of the words he's using while he's talking. He's also very verbal when no one's interrupting him. And I think he talked about how chaotic it was, how violent it was, and she gave as good as she got. That's kind of a direct quote; those are not my language.
MR. CHEW: Directing your attention further down the page to the entry for July 13th, 2016, three hours, Amber, in person.
DR. ANDERSON: No. This is not couples therapy; this is Ms. Heard by herself. I wrote "in person."
MR. CHEW: Okay. So just to be clear, what follows, these are your notes for your individual treatment of Ms. Heard having nothing to do with g g couples therapy?
DR. ANDERSON: Not true. In my mind, the dust had not settled on the couple yet, and this was just kind of aftermath of the kind of falling-apart of the marriage.
DR. ANDERSON: No. This is not therapy for her; this is about the marriage.
MR. CHEW: If we could please go to Exhibit 6, Lucian, which is a new document -- when I say "new," it was produced by Dr. Anderson's office but new in the sense that Mr. Nadelhaft didn't ask her about it.
DR. ANDERSON: Of course. I created it.
DR. ANDERSON: It's a treatment summary when I was first subpoenaed or my notes were required years ago. My notes are jumbly. They don't say a lot. They're confusing, as you've seen - or you haven't seen, actually
DR. ANDERSON: So I did what psychologists do. You take - you go through all of those notes and your brain, because it's not- if you're not left with a very, you know, I hope, a very clear sense of what went on. So I took everything I thought and believed conceptually about them. I went through all of my notes, and I wrote this treatment summary.
DR. ANDERSON: The first paragraph is still there.
MR. CHEW: And I think you described this in the course of your testimony; but I did want to ask you about your sentence "She reported always hitting him back as a point of pride but admitted that she eventually initiated the hitting herself"
DR. ANDERSON: It is.
DR. ANDERSON: It is.
MR. CHEW: Okay. Let's move to the next page, please. And I just want to focus on the one snippet on Bates page 3. All right. You write, "She reported trying to initiate a fight with him one night by slapping him when she was offended by O what he said."
DR. ANDERSON: Yes, it is.
DR. ANDERSON: Yes, it is.
MR. CHEW: Then in the last sentence, "It was also at this time that she showed me photos of her injuries."
DR. ANDERSON: Well, to the best my pulling together the information I wrote down, I'm saying it was right after that fight. And she - my recollection is she came in - she talked to me by phone and then came in the next day, or at least I thought that. Somewhere around the time she had the injuries, I know she came in in person to show me.
DR. ANDERSON: Both.
MR. CHEW: You said she showed you photos. And so, is it your testimony that she showed you photos of her injuries shortly after the alleged event?
DR. ANDERSON: Somewhere in the period while she still had injuries, she showed me photos, but she also came in and showed me in person.
DR. ANDERSON: Bruising on her face.
MR. CHEW: Other than the bruising on her face, what else -- what other injuries did she show you?
DR. ANDERSON: I don't remember. There may have been y more, but I don't remember.
DR. ANDERSON: Correct.
MR. CHEW: So the only basis you had with respect to the cause of the injuries was what Ms. Heard told you, correct?
DR. ANDERSON: Yes.
MR. CHEW: And you write, "The physical violence that occurred between them appeared to me to be mutual."
MR. CHEW: You never actually witnessed any physical violence by Mr. Depp or by Ms. Heard, correct?
DR. ANDERSON: Never.
MR. CHEW: And you said that they were each victims of domestic violence, both in their family -- they were each victims of domestic violence in their families.
DR. ANDERSON: They were each beaten by parents.
MR. CHEW: Page 11. And after the part where -- this refers to a session that was just you and Ms. Heard, correct?
DR. ANDERSON: Yes.
MR. CHEW: And this call, which was just between you and Ms. Heard and not Mr. Depp involved, that occurred on or about December 15th, 2015?
DR. ANDERSON: Yes.
MR. CHEW: And was it just shortly after that call when Ms. Heard showed you pictures and actually came into your office; is that right?
DR. ANDERSON: Sh came in on 12/17, so yes.
MR. CHEW: So Ms. Heard came in on December 17th, and you saw bruises on her face; is that correct?
DR. ANDERSON: I believe that's when.
MR. CHEW: Was that bruising that you observed similar to the bruising that appeared on the photographs that she showed you?
DR. ANDERSON: Yes.
MR. CHEW: You testified that what you saw in person was similar to what you saw in the photographs Amber gave you, correct?
DR. ANDERSON: Yes.
DR. ANDERSON: What I recall is not purple, green, and blue, but just a darkening, so kind of a dark -- a darker gray/blue sort of thing.
DR. ANDERSON: But I don't have a photo of it. I don't remember that well.
MR. CHEW: Is that, Dr. Anderson, consistent with your understanding that there were no other entries on December 15, or December 17th, relating to physical abuse?
DR. ANDERSON: You know, there was nothing about physical abuse, nothing in that next session. It was all about Christmas and getting her therapist telling her one thing -
DR. ANDERSON: Maybe like this (indicating) in more than one place, about an inch.
MR. CHEW: You said it was -- so is it fair to say those are small bruises in more than one place? So there was -- how many one-inch-size bruises on her face that you observed?
DR. ANDERSON: I'm not a good person to ask this question to. I don't really remember. I wasn't looking to memorize it I think there's other data that will support this not from me.
DR. ANDERSON: A few minutes ago, you briefly spoke about seeing bruises, about an inch, on Amber Heard's face.
MR. NADELHAFT: Do you recall that testimony?
DR. ANDERSON: Yes.
MR. NADELHAFT: And you were making motions with your fingers.
DR. ANDERSON: But I'm saying multiple. I'm not saying one.
MR. NADELHAFT: Right You were seeing multiple bruises on Amber's face.
DR. ANDERSON: Yes.
MR. NADELHAFT: When you were talking about how the size of it, your fingers were under your eyes. Did you -- do you remember seeing the bruises under Amber's eyes?
DR. ANDERSON: That's what I recall. They may have been in other places throughout her body; I don't remember. But I do remember her face.
MR. NADELHAFT: Can you tum to page 13.
MR. NADELHAFT: In the blue, where it says, "Was chaotic, violent," do you know what Mr. Depp was referring to there?
DR. ANDERSON: What I said previously, and I'll say it again: He's kind of doing a retrospective of trying to understand the relationship and is characterizing it as chaotic and violent, that she gave as good as she got and she started it. You know, he's complaining, but he's also just kind of describing what the relationship was.
DR. ANDERSON: His mother is dead at this point. The relationship is not - it is not good. It's over, pretty much. And he's trying to come to terms with it. And he still loves her and is mourning. So he's just- he's a very articulate man, and when left alone to speak, he can describe intelligently what's going on.
DR. ANDERSON: I think I'm kind of - I think while he's talking and I'm not trying to be intrusive with my taking notes, l'in listening, I'm talking, but I'm also copying down a word here and there. So my belief is that those are his words.
MR. NADELHAFT: And Mr. Depp, I think you testified IO about this, but I just want to make sure, clear, Mr. Depp told you Amber gave as good as she got, correct?
DR. ANDERSON: Correct.
MR. NADELHAFT: Did you ask what Mr. Depp meant by "gave as good as she got"?
DR. ANDERSON: I was pretty aware of what he meant I agreed.
MR. NADELHAFT: What did you understand Mr. Depp to mean?
DR. ANDERSON: I have - she.initiated fights. She started violence. She rose to the challenge if he started first, which I - and so she - in my opinion, that had been established throughout the relationship, that she fought as hard as he did, and he tried to deescalate far more than I think she did
MR. NADELHAFT: Do you know did Mr. Depp talk about his fingertip with you before June 18th, 2016?
DR. ANDERSON: No. Because I would have written it when he first mentioned it to me.
MR. NADELHAFT: Did you ever see Mr. Depp with an injury to his finger during any of your sessions with Mr. Depp or counseling or, you know, sessions together with Amber Heard?
DR. ANDERSON: During that session, yes.
MR. NADELHAFT: On June 18th, 2016, but before June 18th, 2016, did you ever see an injury to Mr. Depp's finger?
DR. ANDERSON: No. But -- yes. No, I didn't.
MR. CHEW: When we were going through Amber's -- the incidents where Amber described Mr. Depp being violent, Mr. Depp was not present, correct?
DR. ANDERSON: That's true.