Debbie Lloyd — Direct/Cross/Redirect/Recross
2,024 linesMR. NADELHAFT: And you do not work or live in Virginia, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Have you, at any time, spoken with-- can you please provide your full name?
DEBBIE LLOYD: Yes. Deborah Lynn Lloyd.
MR. NADELHAFT: And Ms. Lloyd, you live in California?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you work in California?
DEBBIE LLOYD: Yes. And you do not live or work in Virginia, correct.
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Have you, at any time, spoken with Mr. Depp or any of his counsel either in preparation for this deposition or for any other matter after you no longer worked with Mr. Depp?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Do you recall who you spoke to?
DEBBIE LLOYD: I believe her name was Camille.
MR. NADELHAFT: And do you recall when you spoke to Camille, approximately?
DEBBIE LLOYD: Two weeks ago.
MR. NADELHAFT: Okay. And what did Camille and you discuss?
DEBBIE LLOYD: She had asked me if Johnny had ever thrown anything at me.
MR. NADELHAFT: And what did you say?
DEBBIE LLOYD: No.
MR. NADELHAFT: Were there any other -- was that the total of your communications with Camille?
DEBBIE LLOYD: That was the only time that I remember speaking to her.
MR. NADELHAFT: Did you speak about anything else other than whether -- and when you say "Johnny," I assume you mean Mr. Depp, correct?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Did you have any other -- did you discuss anything else other than whether Mr. Depp had thrown something at you?
DEBBIE LLOYD: They had asked if I would be willing to go to Virginia to the trial.
MR. NADELHAFT: And are you willing to go to Virginia to be a trial witness?
DEBBIE LLOYD: No.
MR. NADELHAFT: Did you -- at any time, did you -- did you have any other -- do you recall anything else you and Camille spoke about?
DEBBIE LLOYD: Not in detail.
MR. NADELHAFT: Do you know how long the conversation was, approximately?
DEBBIE LLOYD: Approximately 15 minutes.
MR. NADELHAFT: Was it over the phone?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Do you recall at any other time having any other communications with any other counsel for Mr. Depp?
DEBBIE LLOYD: No. There was somebody else on that call, I believe, from his side, but I don't know who it was.
MR. NADELHAFT: Do you recall if it was a man or a woman?
DEBBIE LLOYD: A man.
MR. NADELHAFT: Did you ever speak to Adam Waldman?
DEBBIE LLOYD: I know an Adam reached out to me a long time ago. I don't remember a last name.
MR. NADELHAFT: You're a psychiatric mental health Is I nurse practitioner?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Can you briefly explain what that is?
DEBBIE LLOYD: I'm a nurse practitioner that I specializes in psychiatry.
MR. NADELHAFT: And did you go to -- where did you go to school for that?
DEBBIE LLOYD: I got my master's from Maryville University.
MR. NADELHAFT: Is that in California?
DEBBIE LLOYD: It's in Illinois.
MR. NADELHAFT: And --
DEBBIE LLOYD: No, it's not. It's in Missouri, St. Louis, Missouri, sorry.
MR. NADELHAFT: No problem. And I understand you're I also a certified addiction nurse.
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And can you briefly explain what that is?
DEBBIE LLOYD: I had to get a certification in addiction nursing.
MR. NADELHAFT: And what is addiction nursing? IS
DEBBIE LLOYD: Nursing that specializes in taking care of patients with chemical dependency issues.
MR. NADELHAFT: And chemical dependency, that's drugs and alcohol?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: How long have you worked in those fields, addiction nursing and mental health nursing?
DEBBIE LLOYD: Since 2004.
MR. NADELHAFT: And would you agree that one of your specialties is concierge addiction services?
DEBBIE LLOYD: It was, yes.
MR. NADELHAFT: What are concierge addiction services? I [21
DEBBIE LLOYD: We would - that's a good question. We mainly deal with higher-end clients and provide care go to their home rather than have them come into facilities.
MR. NADELHAFT: And would you, at times, provide 24/7 nursing care?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you'd also be a patient's travel companion for nursing care?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you own your own company?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And what was the company's name?
DEBBIE LLOYD: Turning Point.
MR. NADELHAFT: And do you still own Turning Point?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And what does Turning Point do?
DEBBIE LLOYD: Provides services. It's actually no longer - I still own it, but I don't work with it anymore. It provides services to either nursing or sober companion services to patients.
MR. NADELHAFT: And when did you start Turning Point?
DEBBIE LLOYD: I don't recall the exact year.
MR. NADELHAFT: Does anyone else own it?
DEBBIE LLOYD: No.
MR. NADELHAFT: How many people work at Turning Point?
DEBBIE LLOYD: I'm the only employee.
MR. NADELHAFT: And what do you have, contract nurses who worked for you?
DEBBIE LLOYD: I did, yes.
MR. NADELHAFT: And what does Turning Point do now, if anything?
DEBBIE LLOYD: Sits dormant.
MR. NADELHAFT: Okay. And when did it start to sit dormant?
DEBBIE LLOYD: About two years ago.
MR. NADELHAFT: Is there any particular reason why?
DEBBIE LLOYD: That's when I became a nurse practitioner and changed my career path.
MR. NADELHAFT: And where do you work now?
DEBBIE LLOYD: I work for Headlands Addiction Treatment Services.
MR. NADELHAFT: What do you do there?
DEBBIE LLOYD: Nurse practitioner.
MR. NADELHAFT: Okay. Is there a difference between a nurse practitioner and a nurse?
DEBBIE LLOYD: Nurse practitioner, I can diagnose and prescribe medications underneath a doctor's 1,2 supervision.
MR. NADELHAFT: So when you were working at Turning Is Point, or when you owned -- when you were working at Turning Point, were you a nurse practitioner?
DEBBIE LLOYD: No.
MR. NADELHAFT: What was your title then?
DEBBIE LLOYD: Registered nurse.
MR. NADELHAFT: And you performed work for Mr. Depp, correct?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Was that with Turning Point?
DEBBIE LLOYD: Turning Point was contracted through Dr. Kipper.
MR. NADELHAFT: Can you explain how that arose, how you I began to work for Mr. Depp through Dr. Kipper?
DEBBIE LLOYD: Dr. Kipper was his doctor, and he needed nursing services, so Dr. Kipper reached out to me.
MR. NADELHAFT: And it's Dr. David Kipper, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Had you worked with Dr. Kipper before working with Mr. Depp?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Do you know when you started working for Mr. Depp, approximately?
DEBBIE LLOYD: Approximately, I think it was 2015 or '16.
MR. NADELHAFT: And we can look at some documents, and that may help. I IO Do you recall how many patients you had I worked with Dr. Kipper before working with Mr. Depp?
DEBBIE LLOYD: That would be a guesstimate.
MR. NADELHAFT: Okay. Do you have any approximation?
MR. NADELHAFT: And when Dr. Kipper reached out to you I about Mr. Depp, did he reach out to you by phone ! 18 or by written communication?
DEBBIE LLOYD: By phone.
MR. NADELHAFT: Do you recall what Dr. Kipper told you he was looking for in regards to Mr. Depp's care?
DEBBIE LLOYD: Detox.
MR. NADELHAFT: And detox from what?
DEBBIE LLOYD: Originally, I don't think I knew any of the specifics.
MR. NADELHAFT: What did you come to understand Mr. Depp was looking to detox from?
DEBBIE LLOYD: Opiates.
MR. NADELHAFT: Any other medication or any other drugs that Mr. Depp was looking to detox from?
DEBBIE LLOYD: Not that I recall.
MR. NADELHAFT: Do you know if Mr. Depp ever took cocaine?
DEBBIE LLOYD: I never witnessed him use any cocaine.
MR. NADELHAFT: Okay. So did Dr. Kipper contract with your company for care for Mr. Depp?
DEBBIE LLOYD: I don't recall the specifics of how we were brought on.
MR. NADELHAFT: Well, okay. How were you -- how were you paid?
DEBBIE LLOYD: Through Dr. Kipper.
MR. NADELHAFT: Did you have to submit your time to Dr. Kipper --
DEBBIE LLOYD: Yes.
MR. NADELHAFT: For Mr. Depp's services?
MR. NADELHAFT: Did Mr. Depp ever pay you directly?
DEBBIE LLOYD: No.
MR. NADELHAFT: Did you ever get any gifts from Mr. Depp?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: What gifts did you receive from Mr. Depp?
DEBBIE LLOYD: I remember getting a jewelry box and a - I forget what it's called - like a notepad, a fancy notepad, I guess.
MR. NADELHAFT: Do you recall why he -- Mr. Depp gave you the jewelry box?
MR. NADELHAFT: You can answer that.
DEBBIE LLOYD: I don't know why. I believed it was a - for a thank-you.
MR. NADELHAFT: And the same, you believe it was a thank-you for the fancy notepad that you received?
DEBBIE LLOYD: It was at the same time.
MR. NADELHAFT: Okay. Did you receive anything else, ever, from Mr. Depp?
DEBBIE LLOYD: Not that I recall.
MR. NADELHAFT: Okay. Do you still do work for Dr. Kipper?
DEBBIE LLOYD: I have not recently. I 1
MR. NADELHAFT: Do you recall when you last worked with Dr. Kipper?
DEBBIE LLOYD: Not exactly.
MR. NADELHAFT: Do you remember the year you stopped working with Dr. Kipper?
DEBBIE LLOYD: No.
MR. NADELHAFT: Okay. Do you recall the last time you've spoken to Dr. Kipper?
DEBBIE LLOYD: This week, last week.
MR. NADELHAFT: What did you talk to Dr. Kipper about I this week?
DEBBIE LLOYD: He's my personal doctor.
MR. NADELHAFT: So did you speak to Dr. Kipper at all ! 17 about this case?
DEBBIE LLOYD: No.
MR. NADELHAFT: Have you ever spoken to Dr. Kipper about your deposition?
DEBBIE LLOYD: No.
MR. NADELHAFT: Have you ever spoken to Dr. Kipper about his deposition?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you know who Erin Boerum is, correct?
DEBBIE LLOYD: Yes. j 6
MR. NADELHAFT: And who is she?
DEBBIE LLOYD: She's a nurse that worked with us.
MR. NADELHAFT: And Ms. Boerum worked for Turning Point; is that right?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And she -- and did you hire Ms. Boerum?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Was Erin -- was Ms. Boerum a salaried employee of Turning Point?
DEBBIE LLOYD: No.
MR. NADELHAFT: So Ms. Boerum was a contract attorney -- a contract employee for Turning Point, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: So in kind of a general sense, how did that work with Ms. Boerum at Turning Point.
MS. MEYERS: Objection; vague.
MR. NADELHAFT: If you needed her for a particular case, you'd hire her for that case?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. Your testimony is that you had hired Ms. Boerum previously for other patients; is that right, before Mr. Depp and Ms. Heard?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. And do you recall how Ms. Boerum came to work for Mr. Depp and Ms. Heard?
COURT REPORTER: And do you recall how Ms. Boerum came to work for Mr. Depp and Ms. Heard?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: How did that happen? What happened?
DEBBIE LLOYD: I was taking care of Johnny, and Amber - it was decided that Amber needed some support, so I brought her in for Amber.
MR. NADELHAFT: So were you Mr. Depp's primary nurse?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And was Ms. Boerum Amber's primary nurse?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And would you ever share responsibilities where Ms. Boerum would perform nursing care for Mr. Depp and you would perform nursing care for Amber?
DEBBIE LLOYD: I know Erin covered for me a few times. I do not believe I ever cared for Amber.
MR. NADELHAFT: And you said that a decision was made that Amber needed nursing care?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Who made that decision?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Can we put up Attachment 2, and we'll call this Lloyd Exhibit 1.
MR. NADELHAFT: AV TECHNICIAN: Please stand by.
MR. NADELHAFT: Thanks.
MR. NADELHAFT: AV TECHNICIAN: Exhibit 1.
MR. NADELHAFT: Ms. Lloyd, I'm showing you what's been marked as Lloyd Exhibit 1. You'll see it's many pages, and we're going to go through some of these during the day. But just looking at it, do you recognize what this is?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And what is Lloyd Exhibit 1?
DEBBIE LLOYD: My nursing notes.
MR. NADELHAFT: Okay. And so these are the notes that you created?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And these are notes you created for your care of Mr. Depp; is that right?
DEBBIE LLOYD: Correct
MR. NADELHAFT: And if at the break, you want to go over and see the whole thing, you know, I'm happy ! to let you do that just to save time, rather than I having you read 123 pages. But did you create these notes in the ordinary course of business?
DEBBIE LLOYD: Can you clarify what that means?
MR. NADELHAFT: You created these notes as part of your job of being a nurse, correct?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. Did Dr. Kipper ask you to keep these notes?
DEBBIE LLOYD: We just keep notes as nurses. I don't recall. 'I !
MR. NADELHAFT: So this is your normal practice, keeping these notes; it's not particular to Mr. Depp, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Did you receive any training into how to keep these notes?
DEBBIE LLOYD: Nursing school.
MR. NADELHAFT: Okay. And the notes are typed, right?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. Did you bring a laptop with you l when you were working with Mr. Depp?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Let's just go to the first one. It says June 12th, 2014, 23:00. Do you see that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And 23:00, that's military time, is correct?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: So that's 11:00 p.m. at night?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. And it says, "RN and MD met with l patient to discuss plan and medication regime.
MR. NADELHAFT: Do you see that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: The "RN" is you, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: And the "MD" is Dr. Kipper?
DEBBIE LLOYD: Correct. 8.
MR. NADELHAFT: And "the patient" is Mr. Depp, right?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Okay. So where it says 6/12/14 at 23:00, is that when you met with Mr. Depp? Or that when you wrote up the note?
DEBBIE LLOYD: That's when I wrote up the note.
MR. NADELHAFT: Okay. So you may have met with Mr. Depp at some other time before this?
DEBBIE LLOYD: Sometime during that day.
MR. NADELHAFT: Okay. So the time you have here is when you wrote the note?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Okay. And would you typically type the notes as opposed to writing notes and handwriting and then typing the notes?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Okay. Did anyone review the notes?
DEBBIE LLOYD: Notes were sent to Dr. Kipper.
MR. NADELHAFT: How often would you send the notes to Dr. Kipper?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: And was there a system where you could see the notes, or did you email him, Dr. Kipper, the notes?
DEBBIE LLOYD: Email.
MR. NADELHAFT: Okay. So is it your understanding based on these notes that the first time you met Mr. Depp was on June 12th, 2014?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And if we scroll down to the 6/13/14, this says you met with patient in his apartment, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: So the next day you met with Mr. Depp in his apartment; is that right?
DEBBIE LLOYD: According to my notes. I don't recall.i
MR. NADELHAFT: Okay. And in the second line, you write, "He stated that he initially started taking opiates after some dental work and became Is dependent on them." !1176 you? Is that something that Mr. Depp told is
DEBBIE LLOYD: According to my notes.
MR. NADELHAFT: Would there be a reason you would write that if Mr. Depp did not tell you that?
DEBBIE LLOYD: No.
MR. NADELHAFT: Okay. And then you write, "Patient is fearful of coming off of opiates but knows it's what he needs to do."
MR. NADELHAFT: So, again, that's something, according to your notes, that Mr. Depp told you?
DEBBIE LLOYD: According to my note, yes.
MR. NADELHAFT: And then it says, "Patient also expressed some emotional trauma which causes him depression and anxiety."
MR. NADELHAFT: Again, according to your notes, that's what Mr. Depp told you?
DEBBIE LLOYD: According to my notes, yes.
MR. NADELHAFT: Do you recall at all what the emotional trauma was that was causing Mr. Depp depression and anxiety?
DEBBIE LLOYD: I do not recall.
MR. NADELHAFT: Let me ask this again. Do you recall what the plan was for Mr. Depp's detox as of the end of June 2014?
DEBBIE LLOYD: "Plan" in what regards?
MR. NADELHAFT: Where was Mr. Depp's detox going to I take place?
DEBBIE LLOYD: I don't remember when it was determined, but I remember that it was after filming, we would go to the island.
MR. NADELHAFT: And that's the island that Mr. Depp owns?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you went to the island, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Who else was on the island in this time when Mr. Depp was doing the detox?
DEBBIE LLOYD: I know I was there. I cannot remember if Amber was there the entire time. And some of Johnny's staff and Dr. Kipper came at some point.
MR. NADELHAFT: How did you get to Mr. Depp's island?
DEBBIE LLOYD: Flew.
MR. NADELHAFT: And then would you take a boat to his island?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. And if we go to, in the same document, Kipper 69, which I believe is page 17, there we go, we see where it says "8/8/14"?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And it says, "arrived on island today"?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Does that mean that you arrived on the island on August 8th, 2014?
DEBBIE LLOYD: According to my notes.
MR. NADELHAFT: Okay. And on August 9th, 2014, it says, "Patient expressed fears of never feeling normal without his drugs."
MR. NADELHAFT: You wrote that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And is that something that Mr. Depp told you?
DEBBIE LLOYD: According to my notes, yes.
MR. NADELHAFT: Okay. And if we go two pages to Kipper 71 -- oh, you could, yeah, there we go -- do you see where it says at the top, "MD's flight has been canceled" --
DEBBIE LLOYD: Yes.
MR. NADELHAFT: "Arrangements are being made for him to arrive on the island 8/12/14"?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: So according to your notes, Dr. Kipper, after the flight was canceled, was set to arrive on the island on August 12th, 2014?
DEBBIE LLOYD: According to my notes.
MR. NADELHAFT: Ms. Lloyd, I'm showing you what's been marked as exhibit -- Lloyd Exhibit 2, which is ALH 16110 through -113.
MR. NADELHAFT: Do you remember texting with Amber at all while you were on the island with Mr. Depp?
DEBBIE LLOYD: That is some of how we communicated, yes.
MR. NADELHAFT: And does this refresh your recollection that Amber was, at least at some point, on the island with Mr. Depp during the detox?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: The gray part of the text is your text, correct?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And the blue is Amber?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And in the gray part of the text where I it shows the phone number there, is that your cell phone number?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Ms. Lloyd, I'm showing you what's been marked as Exhibit 3, a text message chain between you and Amber Heard on August 16th, 2014. And, again, in the gray box where it shows a phone number, that's your phone number, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Okay. And, Ms. Lloyd, I'm showing you what's been marked as Lloyd Exhibit 4, a text message chain between you and Amber on August 18th, 2014.
MR. NADELHAFT: Do you see that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. Do you recall, when on the island, Amber would be telling you how Mr. Depp was doing?
DEBBIE LLOYD: According to these texts, that's what was happening, yes.
MR. NADELHAFT: Do you recall how long you were on the island?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: In a day, do you recall how long you ! 14 would see Mr. Depp?
DEBBIE LLOYD: It varied.
MR. NADELHAFT: Okay. Would there be reasons why it ! 17 varied as to how long you'd see Mr. Depp in a day?
DEBBIE LLOYD: I don't recall what - how it was determined.
MR. NADELHAFT: How far away were you from where Mr. Depp was staying?
DEBBIE LLOYD: Five to ten minutes.
MR. NADELHAFT: By foot or by something, some other transportation?
DEBBIE LLOYD: By a John Deere tractor.
MR. NADELHAFT: And where -- what type of place were you staying in on the island?
DEBBIE LLOYD: It was a yurt.
MR. NADELHAFT: Okay. And were you staying with anyone?
DEBBIE LLOYD: I was by myself some of the time, and then Dr. Kipper was also in the yurt for some of the time.
MR. NADELHAFT: And did the yurt have separate rooms?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And would you typically eat with Mr. Depp?
DEBBIE LLOYD: Varied
MR. NADELHAFT: And what was your -- when you were on the island, what was your role in terms of Mr. Depp's detox?
DEBBIE LLOYD: Medication management.
MR. NADELHAFT: And what do you mean by "medication management"?
DEBBIE LLOYD: To administer medications.
MR. NADELHAFT: And was Dr. Kipper the person who was prescribing the medications?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: As part of the medication management, did Mr. Depp get a bag of meds? You can answer to the extent you know.
DEBBIE LLOYD: Did I give Mr. Depp a bag of medication?
MR. NADELHAFT: Either you or Dr. Kipper.
DEBBIE LLOYD: Not that I recall.
MR. NADELHAFT: Staying on this last page for a second, of Lloyd 4, the picture of, looks like a pill box, right?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Would you have provided either Mr. Depp or Ms. Heard Mr. Depp's medications in a box like this?
MR. NADELHAFT: Yes.
MR. NADELHAFT: Okay.
MR. NADELHAFT: Well, why don't we actually just take a break for this moment. We've I been about an hour. Take a, I don't know, how long, five-minute break?
MR. NADELHAFT: Is there any reason for you to believe where you wrote, "RN received text from fiance," that that's not a text from Amber Heard"?
DEBBIE LLOYD: No.
MR. NADELHAFT: Lloyd exhibit 5 is a chart of text messages we received from -- in a production from Mr. Depp. It is DEPP 7819. Do you see the second entry, entry 131?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And where in the third row there's your name, and above that name is a phone number. Is that your phone number?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you would sometimes text message I with Mr. Depp too, correct? I 1 s
DEBBIE LLOYD: Correct.
MR. NADELHAFT: You see it says in the body on that row 131, "I'll come by within an hour to drop meds off just in case. How are you feeling? Your head back on straight?"
MR. NADELHAFT: Do you see that?
DEBBIE LLOYD: I see that.
MR. NADELHAFT: And this was a text you wrote to Mr. Depp?
DEBBIE LLOYD: According to this.
MR. NADELHAFT: All right. Do you recall, as of around August 26th, 2014, what you meant by "your head is back on straight?"
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: And then Mr. Depp responded to you, do you see in the next row, "Pretty much. I don't have the ability to take anything more on my back right now ... I'm fucking strong ... if my arm is gangrenous, I would cut off -- I would cut the fucker off. If I am threatened by the love I feel... I need to stop. Simple math."
MR. NADELHAFT: Do you recall receiving that text from Mr. Depp?
DEBBIE LLOYD: I don't recall. No, I don't recall receiving that.
MR. NADELHAFT: Okay. Do you have any reason to believe you did not receive this text from I Mr. Depp?
DEBBIE LLOYD: No.
MR. NADELHAFT: If we go back to Exhibit 1, and if you can go to Kipper 101.
MR. NADELHAFT: And you see where it says "0125" under September 22nd, 2014?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you wrote, "RN received text from patient stating that he had been in an argument IO with fiance and she 'had a nasty freakout' and he would like RN to come give him some 'some fucking knockout yum yum.' RN instructed patient to take PRN Neurontin 300 milligrams pm and Seroquel 50 milligrams and that RN was on her way over."
MR. NADELHAFT: You wrote that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Do you recall anything about what the "nasty freakout" that Mr. Depp was referring to about Amber?
DEBBIE LLOYD: I do not recall.
MR. NADELHAFT: And then you see the note for 3:30 for September 22nd, 2014?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And, again, that's 3:30 in the morning, right?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: And you wrote, "Upon arriving at the home, patient was sitting in kitchen with scraped and bloody knuckles on right hand. Patient stated he punched white board in kitchen after fight. Patient stated he had been texting his friend explaining why he didn't show up to play music and fiance got upset that he was not giving her enough support and the fight escalated from there."
MR. NADELHAFT: You wrote that note?
DEBBIE LLOYD: According to this, yes.
MR. NADELHAFT: Do you recall going to Mr. Depp's home and seeing him with scraped and bloody knuckles on his right hand?
DEBBIE LLOYD: I do not recall.
MR. NADELHAFT: Do you ever recall any incident where Mr. Depp had claimed he punched a whiteboard in the kitchen?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Do you have any reason to believe where you wrote that -- you wrote, "Upon arriving at the home, patient was sitting in the kitchen with scraped and bloody knuckles on right hand." Would you have written that based on your observation of Mr. Depp?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: On Kipper 111, there's a highlighted note at 19:30 for October 14th. Do you see that?
DEBBIE LLOYD: Oh, wait. One minute. Yes.
MR. NADELHAFT: And you wrote, "Patient finished filming and was extremely agitated leaving the set. Patient kicked in the door of his trailer and refused to speak to director. Patient was verbally aggressive to another person on the set so no apparent -- for no apparent reason. Per MD patient is to take Xanax 2-milligrams to reduce his agitation at this time." You wrote that?
DEBBIE LLOYD: According to these notes, yes.
MR. NADELHAFT: And was -- were these notes based on I your observation of Mr. Depp?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Would you go to -- would you have -- did you ever attend filming where Mr. Depp was filming?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Where you wrote, "Patient kicked in the door of his trailer and refused to speak to director," that's based on your observation of ! Mr. Depp?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Where you wrote, "Patient was verbally I! ::::::::e::.t!: ::e:: !ea:;1::ts Based on?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Would it have been based on anything I other than your observation of Mr. Depp?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: If you had been told that Mr. Depp was verbally aggressive, would you have written that in your note?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: And the note above it for 16:30, do you see that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: You wrote, "RN and MD arrived on set to assess patient."
MR. NADELHAFT: So that's you and Dr. Kipper, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: And you wrote, "Patient appeared agitated and was short towards RN."
MR. NADELHAFT: You wrote that?
DEBBIE LLOYD: According to this, yes.
MR. NADELHAFT: And where you wrote, "Patient appeared agitated and was short towards RN," meaning Mr. Depp was short towards you, correct?
DEBBIE LLOYD: I don't remember.
MR. NADELHAFT: That's what you -- that's what the note means, right? ls there a reason for it?
DEBBIE LLOYD: That's what the note means, yes.
MR. NADELHAFT: All right. And this note would have been based on your observation of Mr. Depp at the time, correct?
DEBBIE LLOYD: I don't remember.
MR. NADELHAFT: And then you see under October 15th, there's another highlighted entry, correct?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you wrote, "Patient awake and states he slept from 22:00 to 4:30."
MR. NADELHAFT: Do you see that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: "Patient continues to be agitated about work and is verbalizing having desire to escape with drugs," you wrote that?
DEBBIE LLOYD: It's in my notes.
MR. NADELHAFT: And that would mean that you wrote that note, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: And you would have written that note based off Mr. Depp telling you he had a desire to escape with drugs, correct? I'm sorry, did you answer?
DEBBIE LLOYD: Yes. I said I don't remember.
MR. NADELHAFT: Okay. And this is exhibit 8, more texts between you and Mr. Depp. Feel free to look through it.
DEBBIE LLOYD: Okay.
MR. NADELHAFT: Mr. Depp wrote, "I'm all right. Confused as fuck. She said nothing of last night and, most certainly, not one thing about -- of the wrap party's existence. All the proof that I predicted last night... How will I look at her when she gets back professing her undying love ... All a fucking lie ... I for sure, unfortunately, wouldn't mind some company, but... I've inundated you with too much already. Love love ... Me." That's a text that you received from Mr. Depp?
DEBBIE LLOYD: I don't recall.
AV TECHNICIAN: Exhibit 9.
MR. NADELHAFT: And this is more texts between you and Mr. Depp that you can take a look at through.
MR. NADELHAFT: On November 11th, 2014, Mr. Depp wrote, All good. Haven't read her text yet... Am feeling so fucked ... Why is she at the goddamn wrap party until 5:00 a.m.? Did Erin say anything? The lies are so clear, now. They are making me nuts, wondering what was so interesting to keep her there that goddamn long. Please ask Erin. I must have truth. I need it... It's not the easiest thing to do, at this point... Though, it has been a shitty and painful experience ... I cannot help but hear her voice begging and crying. She wants to change and is going to change, et cetera. Help ... I don't know what's real and what's paranoiac jealousy.
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: And you don't recall -- do you recall, ever, Mr. Depp not feeling trust for Amber?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: While you were working with Mr. Depp, ! did he smoke marijuana?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Do you recall if he took any -- if not smoked marijuana, ingested marijuana in any sort of way?
DEBBIE LLOYD: I don't recall. AV TECHNICIAN: Exhibit 10.
MR. NADELHAFT: Can you think of another instance where there was a patient -- without giving me the patient's name or information -- where they were allowed to continue to take marijuana while detoxing from other drugs?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Exhibit 11 is LLOYD 2 through 5. Do you recall producing documents in this matter?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you produced text messages with :Mr. Depp and with Ms. Heard.
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And this is a text message between you and Amber starting on December 26th, 2014.
MR. NADELHAFT: Do you see that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. And you understand that you're in the -- the texts from you are the blue, correct?
DEBBIE LLOYD: Okay.
MR. NADELHAFT: All right. You wrote, Sorry to bother you. Is JD up? He has an important appointment at 2:00 p.m. and he isn't responding to me. Hope you guys had a beautiful Christmas.
MR. NADELHAFT: And Amber wrote, "Hey there. Yes he is. He's opening presents with Lily-Rose. What appointment? Is he being picked up?"
MR. NADELHAFT: Who's Lily-Rose?
DEBBIE LLOYD: Johnny's daughter.
MR. NADELHAFT: Did you ever see :Mr. Depp super stoned when you were working with him?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Does that mean that you never saw him stoned? Or you just don't recall one way or the other?
DEBBIE LLOYD: I don't recall one way or another.
MR. NADELHAFT: Do you know who the Whitney is?
DEBBIE LLOYD: Amber's sister.
MR. NADELHAFT: Okay. Do you recall any time when :Mr. Depp seemed confused about something that had occurred?
DEBBIE LLOYD: I don't.
MR. NADELHAFT: Did you ever recall :Mr. Depp wondering if he and Amber had a fight or if he was dreaming?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Do you recall :Mr. Depp ever not taking the medications he was prescribed?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. Do you recall :Mr. Depp sometimes potentially doubling the medications that he was prescribed?
DEBBIE LLOYD: I recall thinking that at times.
MR. NADELHAFT: Do you recall that :Mr. Depp wanted to ! 10 detox off of drugs? What was your answer? i 111
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And how did :Mr. Depp show you that?
DEBBIE LLOYD: It was on his own free will that he hired us to be with him
MR. NADELHAFT: And then did :Mr. Depp have any relapses with drugs when you were working with him?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Do you recall :Mr. Depp in working with him, ever take cocaine? Not that you necessarily saw him, but that you understood that he took cocaine?
DEBBIE LLOYD: I never saw Mr. Depp use cocaine.
MR. NADELHAFT: Did you have any understanding that :Mr. Depp took cocaine whether you saw it or not?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Did you administer drug tests to :Mr. Depp?
DEBBIE LLOYD: In the beginning.
MR. NADELHAFT: Did you see the results of the drug l.s tests?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Did you see :Mr. Depp being positive for taking cocaine?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Do you recall accompanying :Mr. Depp to Australia?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: In -- okay. And do you recall accompanying Mr. Depp to Australia in around March of 2015?
DEBBIE LLOYD: I don't remember dates.
MR. NADELHAFT: Do you recall accompanying Mr. Depp to Australia when he was filming Pirates of the Caribbean 5?
DEBBIE LLOYD: I do.
MR. NADELHAFT: Okay. Where were you staying in Australia in relation to Mr. Depp?
DEBBIE LLOYD: Distance-wise?
MR. NADELHAFT: Yeah. How far away were you from him?
DEBBIE LLOYD: About 30 minutes.
MR. NADELHAFT: Okay. Where was Mr. Depp staying?
DEBBIE LLOYD: In a rental house.
MR. NADELHAFT: And where were you staying?
DEBBIE LLOYD: In an apartment.
MR. NADELHAFT: And what city were you in?
DEBBIE LLOYD: I don't recall the name.
MR. NADELHAFT: Okay. And was Dr. Kipper there with you?
DEBBIE LLOYD: He came and went
MR. NADELHAFT: Did you fly to Australia with Mr. Depp?
DEBBIE LLOYD: Sometimes I did, and other times I flew on a - commercial.
MR. NADELHAFT: Do you recall talking to Dr. Blaustein about Mr. Depp in Australia?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Do you recall Mr. Depp not doing very well while he was in Australia as of March 1st, 2015?
DEBBIE LLOYD: I don't recall anything around that time.
MR. NADELHAFT: Do you have an understanding as to what Mr. Depp was doing with Marilyn Manson?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Did you ever tell Dr. Kipper that Mr. Depp was doing what he wants with Marilyn Manson?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Do you recall Marilyn Manson being in Australia with Mr. Depp?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: It says, "Debbie is worried and somewhat exhausted."
MR. NADELHAFT: Do you recall being exhausted while in Australia and working with Mr. Depp?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Do you have any reason to believe that what Dr. Kipper wrote is not true?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Okay.
MR. NADELHAFT: We can take this down.
MR. NADELHAFT: And go back to Exhibit 1. And if we could, go to Kipper 157.
MR. NADELHAFT: Do you see 3/7/15?
DEBBIE LLOYD: I do.
MR. NADELHAFT: Before I ask, do you recall how long you were in Australia with Mr. Depp?
DEBBIE LLOYD: No. However long the filming of Pirates was.
MR. NADELHAFT: Okay. And at 3/7/15 at 11:30, you wrote, "MD received a text message from client that he had been arguing with wife and that he had cut his finger. According to patient, his assistant and security were on their way to pick him up." You wrote that?
DEBBIE LLOYD: According to my notes, yes.
MR. NADELHAFT: Is there any reason to believe that you '! didn't write that note?
DEBBIE LLOYD: No.
MR. NADELHAFT: Okay. Do you recall Dr. Kipper I I receiving a text message from Mr. Depp about Mr. Depp cutting his finger?
DEBBIE LLOYD: I don't. I don't. Just what this note says.
MR. NADELHAFT: Okay. Do you recall going to Mr. Depp's house after learning that he had cut I his finger? I (8
DEBBIE LLOYD: Yes.
MR. NADELHAFT: What do you recall about that?
DEBBIE LLOYD: That we went to the house and he -- actually, I don't even think I went in at first. Dr. Kipper went in, and he had cut his finger and we took him to the emergency room. Or his finger had been cut.
MR. NADELHAFT: Do you recall what the house looked like when you went in?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: What did the house look like?
DEBBIE LLOYD: It was a mess.
MR. NADELHAFT: Can you describe how it was a mess?
DEBBIE LLOYD: I don't remember details, but I
MR. NADELHAFT: Remember there was some writing on the wall, and I 'remember a smashed TV.'
MR. NADELHAFT: Do you remember what any of the writing said on the wall?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: And you said you recalled a smashed TV.
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Do you recall was Amber in the house?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Do you recall seeing Amber that day?
DEBBIE LLOYD: No, I don't recall.
MR. NADELHAFT: Do you recall what rooms you went through of the house, Mr. Depp's house?
DEBBIE LLOYD: I remember looking for his finger in the downstairs area.
MR. NADELHAFT: And what was in the downstairs area? Or what rooms were in the downstairs area?
DEBBIE LLOYD: It was, like, a pool table/entertainment room
MR. NADELHAFT: Did you look anywhere else around the house?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: What was the pool table/entertainment room, was that a mess?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Do you recall going into the kitchen of the house?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Do you recall finding Mr. Depp's finger?
DEBBIE LLOYD: I did not.
MR. NADELHAFT: Do you know who found Mr. Depp's finger?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Who?
DEBBIE LLOYD: Ben.
MR. NADELHAFT: Ben who?
DEBBIE LLOYD: I don't remember his last name.
MR. NADELHAFT: And who was Ben in relation to Mr. Depp?
DEBBIE LLOYD: He was, like, our house manager.
MR. NADELHAFT: Do you recall where the finger was found?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Do you recall if Mr. Depp appeared to I have dirt, grime, and paint on his hands?
DEBBIE LLOYD: Yes, he did.
MR. NADELHAFT: Do you recall seeing any glass anywhere?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Do you recall smelling any alcohol?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: And who else was with you when you went to the hospital?
DEBBIE LLOYD: Malcolm and Stephen.
MR. NADELHAFT: And who are Malcohn and Stephen?
DEBBIE LLOYD: Stephen was his assistant, and Malcolm was one of his security guards...
MR. NADELHAFT: Do you recall who was holding the piece of finger that had been cut?
DEBBIE LLOYD: Ben brought it to the ER.
MR. NADELHAFT: What did Ben bring the finger in?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Was it on ice, the finger?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Did you ask Mr. Depp how he cut his I finger?
DEBBIE LLOYD: I don't recall if I asked him
MR. NADELHAFT: Did you ask anyone bow Mr. Depp had cut his finger?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Do you have any understanding as to how I Mr. Depp cut his finger?
DEBBIE LLOYD: I heard different stories from people.
MR. NADELHAFT: What were the different stories you heard?
DEBBIE LLOYD: I had heard that Amber threw a bottle of vodka at him I had heard that he slammed it with a phone.
MR. NADELHAFT: Do you recall who you heard that Amber had thrown a bottle at him?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Do you recall who you heard that he slammed it on a phone?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Those -- the stones that you had heard, did you hear it on that day of March 7th, or March 8th, 2015, or later?
DEBBIE LLOYD: I don't remember.
MR. NADELHAFT: Did you ever talk with Mr. Depp about how he cut his finger?
DEBBIE LLOYD: I don't recall conversations.
MR. NADELHAFT: Did you ever talk with Dr. Kipper about how Mr. Depp cut his finger?
DEBBIE LLOYD: I don't recall specific conversations.
MR. NADELHAFT: Did Mr. Depp -- how long was Mr. Depp in the hospital for?
DEBBIE LLOYD: I don't remember.
MR. NADELHAFT: Did you have any concerns about the nurse supervision of Mr. Depp?
DEBBIE LLOYD: I know at times we would go days without me seeing him, but I don't know specifically what this is regarding.
MR. NADELHAFT: Were there issues with the nurse supervision while in Australia?
DEBBIE LLOYD: I don't recall specifics.
MR. NADELHAFT: You have no recollection of Dr. Kipper withdrawing his care of Mr. Depp for any period of time?
DEBBIE LLOYD: No. I know at times it was discussed when he would miss appointments, but I don't recall him ever actually going through with withdrawing his care.
MR. NADELHAFT: Okay. Do you recall there being concerns about Mr. Depp taking substances that he shouldn't have been taking?
DEBBIE LLOYD: I don't recall what that was regarding.
MR. NADELHAFT: Do you recall having major concerns about leaving for Australia with Mr. Depp?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: While that's going up, Ms. Lloyd, the day that Mr. Depp cut his finger, you don't recall seeing Amber one way or the other; is that right?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Exhibit 16 is LLOYD 140 through 145. And Mr. Depp responded, "It's sad. I love you so much, Little Debbie. And, of course, Kipper too. He was right... Though, I did feel a bit of a sting when his letter (paper trail) arrived, on the off chance that I croak. Which, I also understand. Just never heard of anyone being fired by their physician before ... So, I'm kinda proud of that little fact, too. I love you," I kid... Even attempting saying thank you to you, b would be like a monkey trying to fuck a football ... It's just simply impossible. I wish things could have ended on a better note ... All my love, Nurse Shark... JD.
MR. NADELHAFT: Do you recall receiving this text from Mr. Depp?
DEBBIE LLOYD: I don't.
MR. NADELHAFT: But this text was on your phone, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Would Mr. Depp call you "Nurse Shark"?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Would Mr. Depp call you "Little Debbie"?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you don't recall Mr. Depp saying I 18 "Never heard of anyone being fired by their I physician before"?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: And then you respond on the next page, "I love you too and hope this is not the end. Be safe and be smart my son.
MR. NADELHAFT: You sent that text to Mr. Depp?
DEBBIE LLOYD: According to this, yes.
MR. NADELHAFT: And do you know what you meant by "Be safe and be smart"?
DEBBIE LLOYD: I don't know.
MR. NADELHAFT: And then Mr. Depp wrote, "I've been off of for 3 days. The Doc jumped the gun ... Also ... Please thank him for Motrin and the baclofen. They work a treat for amputated fingers [sic] ... Goddamn... I love that weird fucker, no matter what." Did you receive that text from Mr. Depp?
DEBBIE LLOYD: According to this.
MR. NADELHAFT: Do you understand what is meant by "I have been off of for 3 days"?
DEBBIE LLOYD: I have no idea.
MR. NADELHAFT: You respond, "So glad to hear you have been off. No matter what, I just want you to feel better"?
DEBBIE LLOYD: Yeah. I don't know what we were referring to.
MR. NADELHAFT: If you go down to the next page, you write "I'd be more than happy to come back and help you with pain management and Toradol injections. I know Kipper loves you and would always want to continue your care if you're no longer using."
MR. NADELHAFT: You wrote that to Mr. Depp?
DEBBIE LLOYD: According to this.
MR. NADELHAFT: And this text was on your phone, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: What did you mean by "Kipper loves you and would always want to continue your care if you're no longer using"?
DEBBIE LLOYD: I don't know. Just what it says.
MR. NADELHAFT: No longer using --
DEBBIE LLOYD: I don't know what that was regarding.
MR. NADELHAFT: You don't know what "no longer using" is referring to?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: And then Mr. Depp wrote I don't I know I'm going the stop it all except whatever I was on before and just deal with it You received that text from Mr. Depp?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Do you know what he was referring to where he said "I'm going to stop it all, except, whatever I was on before and just deal with it"?
DEBBIE LLOYD: I do not know what's that regarding.
MR. NADELHAFT: Okay. And then you wrote, "I respect IO whatever decisions you make. I'll be sad to leave the crew as I love you all. I hope to always be in touch even if you choose not to continue a working relationship. Miss you already. I will get in touch with Kevin and get my stuff out or [sic] 72 soon. Hugs."
MR. NADELHAFT: You wrote that message to Mr. Depp?
DEBBIE LLOYD: According to this.
MR. NADELHAFT: And Mr. Depp wrote Take care Darlin I cannot ever thank you enough all you done for me On the junky side and broken heart side You've been a lifesaver Literally We'll see each other again sweetheart Love you I so much Little Debbie And so does my entire crew X You received that text message from Mr. Depp
DEBBIE LLOYD: According to this, yes. I'm going to cry.
MR. NADELHAFT: Ms. Lloyd, I'm showing you what's been !s marked as exhibit Lloyd 17, which is LLOYD 158 through 160, which is a text message between you I and Johnny Depp from your phone. Do you see that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. And on March 27th, 2015, you wrote, "Good morning sleepy head. Erin came by to give you a shot but you were still sleeping. Take the pill form of Toradol to hold over and I will check in with you when I've done my appointment at Beverly Hills." And then you wrote, "Have you taken pill? If not, hold off and Erin is on her way to give you injection."
MR. NADELHAFT: Do you see that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. And you wrote that text message, I I correct, or those messages?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And then on the next page, Mr. Depp wrote, "The fucking pain is as bad as when it was I cut off. Horrific."
MR. NADELHAFT: You received that message from Mr. Depp?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And he's talking about his finger I there, correct?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And you received that text message from Amber, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Right. And then you wrote, "He's at the studio with Marcus and is supposed to call me when he gets back to the lofts. I will drive up there if you want me to. Always feel weird showing up unexpected. Do you want me to go?" You wrote that text message to Amber?
DEBBIE LLOYD: I don't recall, but according to this,
MR. NADELHAFT: And do you know who Marcus is?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Who is Marcus?
DEBBIE LLOYD: A Marcus Mumford.
MR. NADELHAFT: And what was his relationship to Mr. Depp?
DEBBIE LLOYD: Friend.
MR. NADELHAFT: And then you wrote, "I know Stephen is there. Let me just check in and see what I can find out. I'll get right back to you."
MR. NADELHAFT: Who is Stephen?
DEBBIE LLOYD: His assistant.
MR. NADELHAFT: All right. Do you ever remember checking if Mr. Depp had been taking cocaine?
DEBBIE LLOYD: I don't remember specifically asking any questions related to that.
MR. NADELHAFT: Is there any reason to believe that you didn't do what you said in your text message?
DEBBIE LLOYD: No.
MR. NADELHAFT: Do you recall what you were giving Mr. Depp Valium for?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Ms. Lloyd, showing you again what's been marked as Exhibit 1, and I'm going to point you to Kipper 167, which is from April 13th, 2015.
DEBBIE LLOYD: Okay.
MR. NADELHAFT: Okay. Do you see the entry for 15:00?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: All right. You wrote, "Bandage changed and hand exercises done at appointment with surgeon's office. Per RN at surgeon's office and occupational therapist, hand his healing well and finger has good range of motion. Exercises to be done 3-5 times per day. Patient is in good spirits and says he's not smoked marijuana in 3 days. States he feels majority of his issues with his wife have been from him using drugs and alcohol. Patient states he will no longer sneak/use and wants to enjoy clarity."
MR. NADELHAFT: You wrote that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And these are part of your nurse's notes?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And Mr. Depp told you that he felt the majority of his issues with his wife had been from I I him using drugs and alcohol?
DEBBIE LLOYD: According to the note, yes.
MR. NADELHAFT: And Mr. Depp wrote, "he will no longer sneak/use, and wants to enjoy clarity"?
DEBBIE LLOYD: According to the document, yes.
MR. NADELHAFT: What is being referred to as "no longer sneak/use"?
DEBBIE LLOYD: I only know what's stated in my notes.
MR. NADELHAFT: Okay. Would it be anything other than I drugs or alcohol? i 114
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Was there anything that Mr. Depp was I sneaking other than drugs and alcohol that you I! 17 were concerned about?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: If we go to 175, Kipper 175 on this page -- on this document, it's notes for June 28th, 2015.
DEBBIE LLOYD: June ... Okay. I b
MR. NADELHAFT: It talks -- it says 17:00, "RN received initial results from brain MRI. No obvious abnormalities noted. Final report will be done tomorrow. Patient informed of results." Do you recall why Mr. Depp received the brain MRI?
DEBBIE LLOYD: He was having chronic headaches. ;s
MR. NADELHAFT: And then you see at 6/30 at 13:00?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And that's highlighted? In
DEBBIE LLOYD: Yeah.
MR. NADELHAFT: Okay. You wrote, "RN arrived on set to visit patient. He was upset due to having an argument with his wife. Patient stated he had taken 'about 4' Xanax 1 milligram over the past 24 hours to deal with with the stress he was feeling. Patient was able to express his emotions appropriately. Patient stated that he had not slept the night before due to argument with his wife." That's a note you wrote?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: That's based off of information provided to you by Mr. Depp?
DEBBIE LLOYD: I don't recall.
MR. NADELHAFT: Well, we're --
DEBBIE LLOYD: According to my note, yes.
MR. NADELHAFT: So Mr. Depp told you he had taken about four Xanax 1 milligram over the past 24 hours, correct?
DEBBIE LLOYD: It's in my notes, yes.
MR. NADELHAFT: And at 19:20 on June 30th, it says, "Patient had another argument with his wife. Patient was anxious and asking for medication to help calm him down. Seroquel 50 milligrams administered."
MR. NADELHAFT: Do you see that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And that's a note you wrote?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Do you know why your nursing notes ended on June 1st -- July 1st, 2015?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: How did you continue to care for Mr. Depp as his nurse after July 1st, 2015?
DEBBIE LLOYD: I do not recall my last date.
MR. NADELHAFT: Okay. Did you prepare nursing notes through the time that you were Mr. Depp's nurse?
DEBBIE LLOYD: I did.
MR. NADELHAFT: Okay. And did you provide those notes to Dr. Kipper?
DEBBIE LLOYD: I did.
MR. NADELHAFT: Ms. Lloyd, I'm showing you what's been marked as Exhibit Lloyd 19. This is an email from Dr. David Kulber on June 27th, 2015, that you were copied on.
MR. NADELHAFT: Do you see that?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And do you know who Dr. Kulber is.
DEBBIE LLOYD: I don't recall exactly who he was.
MR. NADELHAFT: Did you understand that Mr. Depp went to a specialist for his finger?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. And you're copied on this email?
DEBBIE LLOYD: I see my name copied on the email, yes.
MR. NADELHAFT: Okay. And you recall that Mr. Depp was treated for a bad crush injury for his finger?
DEBBIE LLOYD: I recall him being treated for a finger injury. I didn't realize - this is the first I remember hearing it was a crush injury.
MR. NADELHAFT: And that's the email you received from Dr. Kulber, correct?
DEBBIE LLOYD: I'm seeing this today. I don't recall receiving this email.
MR. NADELHAFT: Is there any reason you believe you I didn't receive this email?
DEBBIE LLOYD: No. I just don't recall.
MR. NADELHAFT: Okay. Ms. Lloyd, I'm showing you 1113 what's been marked as Exhibit 20, which is a text message chain between you and Mr. Depp from your I phone.
MR. NADELHAFT: Do you see that?
DEBBIE LLOYD: I see that.
MR. NADELHAFT: On July 5th, 2015, Mr. Depp wrote to you, Canceling the squeezing and needles tonight Need to get the recluse out of his cage and his brain. Mr. Depp?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. And then you said, "How come you're canceling? You okay? Not sure what you mean by the rest of your text. Please let me know if you need anything. I'm here if you want to chat or want me to go hang at the house with you." You wrote that text to Mr. Depp?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And then Mr. Depp wrote to you, "I'm in a very anxious and painfully confused state ... Rather not get into details ... But, in a nutshell ... Problems with family, my company, the Ex, business manager and my fuckin' jumbled brain ... Will need refills of meds tomorrow ... Thanks, honey. X." You received that text from Mr. Depp?
DEBBIE LLOYD: According to this, yes.
MR. NADELHAFT: And Mr. Depp talked about how he was having problems with his family?
DEBBIE LLOYD: That's what this states.
MR. NADELHAFT: And Mr. Depp was having problems with his company?
DEBBIE LLOYD: That's what this states.
MR. NADELHAFT: And Mr. Depp was having problems with the ex?
DEBBIE LLOYD: That's what this states.
MR. NADELHAFT: And Mr. Depp was having problems with his business manager?
DEBBIE LLOYD: According to this text.
MR. NADELHAFT: And Mr. Depp was having trouble with his "fuckin' jumbled brain," correct?
DEBBIE LLOYD: According to this text.
MR. NADELHAFT: Just going back to Exhibit 1 for a moment, if we go to back to Kipper 167, and, Ms. Lloyd, I'd ask you to look at the entries for April 14th. It's at the bottom.
DEBBIE LLOYD: Okay.
MR. NADELHAFT: You wrote at 14:00, "RN and MD arrive at patient's home to have meeting to set treatment plan and boundaries while traveling in Australia."
MR. NADELHAFT: You wrote that?
DEBBIE LLOYD: Correct. Yes.
MR. NADELHAFT: And the "MD" is Dr. Kipper, correct?
MR. NADELHAFT: Correct. And do you recall what the treatment plans and boundaries were while traveling in Australia as of April 2015?
DEBBIE LLOYD: I do not recall.
MR. NADELHAFT: And then if we go to the next page, do you see the April 15th entries?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Okay. And at 12:15 you write, "Arrived at patient's home. Assistant was in hallway and informed RN that patient was in a bad mood and told assistant he did not need anything from him today. RN was let in home by security and knocked on patient's door to let him know she was there. Patient screamed 'what.' RN informed patient she was letting him know she was there and would be downstairs. About 5 minutes later security came in the house and informed RN that patient has told security to get everyone out of his home and he did not want any more unexpected guests. RN left property and informed MD of the events. Per MD drop tomorrow's meds off with security and do not reach out to the patient again - wait for patient to reach out to medical team.
DEBBIE LLOYD: Correct.
MR. NADELHAFT: This document and this note also talks I 8 about you informing Dr. Kipper about what happened that -- in this note, correct?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Ms. Lloyd, I'm showing you what's been marked as Lloyd 21. Do you see on April 15th at the bottom, there's a text from Mr. Depp?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: And he wrote, "Hey, sweetheart ... I'm so sorry about today... I thought you were Stephen, whom I'm not particularly enthused about for his loss of loyalty and his loss of memory ... He has tried everything to fuck me over, as far as traveling with my wife. He also bursts into my fucking house like it's goddamn Grand Central I'm truly sorry if I upset you. If you like, you can give me some morphine to see if my tongue and penis touch. All my Jove. J."
MR. NADELHAFT: Did you receive this text from Mr. Depp? I IS
DEBBIE LLOYD: It appears so. I don't - yes.
MR. NADELHAFT: Okay. Did you have any understanding as to what Mr. Depp was referring to where he says "Stephen tried everything to fuck me over, as far as traveling with my wife"?
DEBBIE LLOYD: I do not.
MS. MEYERS: First of all, going back to your work for Dr. Kipper, I think you said earlier you cared for multiple patients that were of Dr. Kipper's, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And when you would care for Dr. Kipper's patients, how would you report their status to Dr. Kipper?
MR. NADELHAFT: Objection. Vague.
DEBBIE LLOYD: Multiple different resources: Phones, texts, verbal - verbal and written.
MS. MEYERS: And how often would you report to Dr. Kipper about his patients?
DEBBIE LLOYD: Responded - I mean, it depended on different patients. It varied.
MS. MEYERS: And I believe you testified earlier that you maintained nursing notes for those patients, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: What type of information did you maintain in these notes?
DEBBIE LLOYD: Mainly we provide care given and patient's responses to care given or any external factors that could affect the patient.
MS. MEYERS: Is there any information that you would not include in your notes?
DEBBIE LLOYD: Not-
MS. MEYERS: I'm sorry; I didn't catch your answer.
DEBBIE LLOYD: Not specifically.
MS. MEYERS: Other than Dr. Kipper, does anyone else review your notes?
DEBBIE LLOYD: If another nurse was to work on the case, they could have access to the notes.
MS. MEYERS: And does Dr. Kipper advise you on any information that should be maintained in your notes?
DEBBIE LLOYD: Not directly.
MS. MEYERS: Has he ever told you that certain information should not be included in your notes?
DEBBIE LLOYD: No.
MS. MEYERS: How long have -- when did you become a registered nurse?
MS. MEYERS: And have you been employed as a registered nurse from that time up until you became a nurse practitioner?
DEBBIE LLOYD: Yes.
MS. MEYERS: In your time as a registered nurse, have you ever had a patient that you suspected was the victim of domestic abuse?
DEBBIE LLOYD: No.
MS. MEYERS: Do you have any professional responsibility to report domestic abuse?
DEBBIE LLOYD: Yes.
MS. MEYERS: And what is that responsibility?
DEBBIE LLOYD: I'm a mandated reporter for child/elder abuse and any suspected injuries.
MS. MEYERS: How would you define "suspected Is injuries"?
DEBBIE LLOYD: If I was to work in a facility and somebody came in and reported or if I felt it was ,9 an injury caused by somebody else.
MS. MEYERS: Who do you report abuse to in that I instance?
DEBBIE LLOYD: I've never had to report abuse.
MS. MEYERS: Okay. But given your professional I responsibility, do you know who you would report I s that to in that event?
DEBBIE LLOYD: I do not.
MS. MEYERS: In your time as a registered nurse, have you ever witnessed physical violence by one of your patients?
DEBBIE LLOYD: I do not recall ever witnessing any violence.
MS. MEYERS: And when you say "any violence," does I that mean perpetrated by your patient or against your patient or just --
DEBBIE LLOYD: Just in general, violence.
MS. MEYERS: So you met Mr. Depp either on June 11th or June 12th of 2014?
DEBBIE LLOYD: According to my notes, yes.
MS. MEYERS: Okay. Had you ever spoken with him ! 8 before that date?
DEBBIE LLOYD: No.
MS. MEYERS: When did you first meet Ms. Heard?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Do you recall when you first met -- not specifically written, but do you recall the instance when you first met her?
DEBBIE LLOYD: I do not.
MS. MEYERS: When you first met Ms. Heard, did you I have an understanding as to what her relationship I to Mr. Depp was at that time?
DEBBIE LLOYD: Yes.
MS. MEYERS: And what was that understanding?
DEBBIE LLOYD: That they were in a relationship.
MS. MEYERS: Were they engaged when you first met them?
DEBBIE LLOYD: I don't recall the date they got engaged.
MS. MEYERS: Were they married when you first met them?
DEBBIE LLOYD: No.
MS. MEYERS: Did you attend their wedding?
DEBBIE LLOYD: Yes.
MS. MEYERS: And where was that?
DEBBIE LLOYD: On the island in the Bahamas.
MS. MEYERS: Can we take this down and please pull up what I've marked as document B.
AV TECHNICIAN: Exhibit 23.
MS. MEYERS: Now, just for the record, I believe these are the nursing notes you were looking at earlier. This just has a different production number, and I just thought it might go more smoothly if I am calling out the correct page numbers.
MS. MEYERS: So just to establish this, do you recognize this document here?
DEBBIE LLOYD: Yes. And these are your nursing notes that I
MS. MEYERS: Believe you looked at with Mr. Nadelhaft earlier, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: Okay. I'd like to direct your attention to the entry for June 17th of 2014, which is on the page with -- perfect. There it is. This is a note you prepared, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And at the time that you prepared this note, were you in Boston with Mr. Depp?
DEBBIE LLOYD: According to the note, yes.
MS. MEYERS: Now, in the section that says 2 -- "23:30," do you see where it says, "Accompanied patient, fiance, assistants and security to conceit"?
DEBBIE LLOYD: Yes. J 8
MS. MEYERS: And in this note, "patient" refers to Mr. Depp; is that light?
DEBBIE LLOYD: Yes.
MS. MEYERS: And "fiance" is Ms. Heard?
DEBBIE LLOYD: Yes.
MS. MEYERS: Does this refresh your recollection that Mr. Depp and Ms. Heard were engaged in June of 2014?
DEBBIE LLOYD: According to this, yes.
MS. MEYERS: Okay. Is this the first time you met Ms. Heard?
DEBBIE LLOYD: I don't recall when I met her.
MS. MEYERS: Further down in the note, do you see where it says, "Assistant was also asked to pass RN and MD's numbers to fiance as we would both like to speak with her and to obtain her input toward patient treatment needs"? Do you see where I'm referring to?
DEBBIE LLOYD: Yep.
MS. MEYERS: Okay. "RN" is referring to you in this instance?
DEBBIE LLOYD: Correct. I 1 s
MS. MEYERS: And "MD" refers to Dr. Kipper?
DEBBIE LLOYD: Correct.
MS. MEYERS: Do you recall why you wanted to speak with Ms. Heard at this time?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you recall Ms. Heard expressing interest in participating in Mr. Depp's treatment?
DEBBIE LLOYD: I don't remember the events other than I ,4 what's stated in my notes. i 5
MS. MEYERS: Your phone number was given to Ms. Heard, though, correct?
DEBBIE LLOYD: Correct. AV TECHNICIAN: exhibit 24.
MS. MEYERS: Ms. Lloyd, do you recognize this document?
DEBBIE LLOYD: No.
MS. MEYERS: So I take it you did not prepare this document; is that correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: Directing your attention to the bottom of the page --
THE COURT: Ladies and gentlemen, that's probably a good break to have a lunch break, so we'll go ahead and break until 2:00. Do not discuss the case with anybody, and don't do any outside research, okay? We'll come back and continue this deposition.
THE COURT: All right. So we'll return at 2:00 p.rn., correct?
THE COURT: Okay. Thank you.
COURT BAILIFF: All rise.
COURT BAILIFF: (Recess taken from 1:00 p.m. to 2:01 p.m.) All rise. Please be seated.
THE COURT: Before we bring the jury in, if I could have counsel approach for a moment.
THE COURT: Juror 25, who happens to be the one waving, the deputies, at lunchtime, said he had hernia surgery about two months ago and he's in a lot of pain. He doesn't feel comfortable sitting here. I'm not sure if that's just today or if that's in general. But I was --
MS. BREDEHOFT: I'm happy to excuse him
THE COURT: I know you are. I think I can bring him out here so we can talk with him and see. If I excuse him today, he's excused for the jury. He has to know that. But would you want me to bring him out so you could talk to him?
MR. CHEW: So we wouldn't want to dismiss him immediately. I mean, I just had hernia surgery myself, several months ago. I O don't have any problems at all, but I know everybody's different.
THE COURT: I can bring him out individually. I'll have 25 come out so we can talk to him for a minute.
THE COURT: Is that okay?
MS. BREDEHOFT: Yes. Thank you, Your Honor.
THE COURT: We'll just bring him in.
THE COURT: Can we get 25.
THE COURT: Sir, you can have a seat. That's fine. Maybe if you can just talk real loud for me. Sir, I know you let the deputy know you're not feeling well from a surgery that you had.
THE COURT: Hold on just a minute. I really can't is hear you.
THE COURT: I had hernia problem.
THE COURT: That's why it start being --
THE COURT: You have a problem with a hernia?
JUROR NUMBER 25: Yeah. I:; to the p= :i; ::,e:'.;c::,:;g you Yeah. Today, I don't know why it's bothering me too much.
THE COURT: I want to make sure you understand, if I excuse you today, I'm excusing you from the jury.
JUROR NUMBER 25: I try to go home, get medicine, get rested, be ready for tomorrow.
THE COURT: I can't do that. I can't have that done. We have to keep going. Has it been bothering you other days while you've been on the jury?
JUROR NUMBER 25: No, today, start now. Never bother me for the one to weeks I'm here.
THE COURT: But it might bother you, also, tomorrow?
THE COURT: I'm not sure. I'm trying to do my best.
THE COURT: I know you're trying to do your best. I want to make sure you're healthy too. I don't want you to ruin your health for this. Just sit there for a second. If I could have the attorneys. Do you have any follow-up questions?
THE COURT: Sounds like he just has hernia problems that bother him one to two weeks a year. That's what I got from that.
THE COURT: I'm just afraid tomorrow he's going to call in or something or he's not focusing on the testimony today.
MS. BREDEHOFT: Today. He's already saying that today. So, I move to excuse him
THE COURT: There's not much you can -- I know.
THE COURT: FEMALE SPEAKER: It's early on. There's not much we can do.
THE COURT: Would you like us to ask him if he's able to concentrate?
THE COURT: He says that he's pretty pained. I think we just have to cut our losses here on this.
THE COURT: He needs to go to the doctor, get it checked out. I think it might be worse than he thinks it is. He's not one of our alternates but what we can do is, at some point, we'll take one of the names out of the alternate bag and I'll tell you what the name is and that person will be back on the jury.
MS. BREDEHOFT: Okay. So the alternates are not in the order we picked them?
THE COURT: They're in an envelope together.
MS. BREDEHOFT: Oh, okay. I thought the order in which --
THE COURT: We could do it that way, if you want to. Rather do it that way? You can decide tonight. I'll keep them all in the envelope.
THE COURT: All right.
THE COURT: Sir, we want to make sure you're healthy. We're going to excuse you from this jury, okay? Just take care of yourself, okay?
THE COURT: Okay.
THE COURT: Okay. Thank you. You can go back. Thank you.
THE COURT: Yes, ma'am, do you have something before the jury comes in?
MS. LECAROZ: Exhibit 548, Your Honor.
THE COURT: Which one?
THE COURT: Okay. 548 is done.
THE COURT: I did have one question, you can stay there, we don't have the jury. There seems to be a few exhibits I just wanted to make sure of You gave us, we have everything that you just gave us earlier from Dr. Kipper's deposition, but I just want to make sure if there are redactions needed for 3 9 5 or 414 or am I using mine for that?
MR. NADELHAFT: Bear with me, Your Honor.
THE COURT: I just want to see. I can if I just give you the numbers of the ones I'm not sure about. You can look at it so we can move on. 405,455,304,307,395, and 414. Just not sure if those -- I'm waiting for redactions or if I'm using the ones I'm going to use. Then you had one that I'm not sure if you said 1083 or 283. So if you could let me know. I heard 1083 as the exhibit number. Jamie heard 283. So I just want to make sure we get the right one. That was with Dr. Kipper's. You said 1063 then you said either 1083 or 283. I'm not Is You can get back to me on it, Mr. Nadelhaft. I don't want to catch you off guard.
MR. NADELHAFT: I do have the redacted versions of 304,455,405 --
THE COURT: There you go.
MR. NADELHAFT: I think probably 283. I have 283.
THE COURT: 283. Jamie's always right. That's good. Good to know. If you want to hand those up, that would be fantastic. I Is there anything else before the jury I comes?
MS. MEYERS: Your Honor, just for the record, Plaintiff's Exhibit 47, Plaintiff's Exhibit 48, and Plaintiff's Exhibit 41 were also used and offered during Kipper, but -- Dr. Kipper's deposition, I believe, I passed the redacted versions of those up to you.
THE COURT: Yes, we have all of those.
MS. MEYERS: Okay.
THE COURT: Thank you. I think that should be everything. If not, we'll get back with you. Thank you. I know where to find you.
THE COURT: All right. Are we ready for the jury then?
THE COURT: All right. Thank you.
THE COURT: Thank you, ladies and gentlemen. Just to let you know, Juror 25 was experiencing some health issues and, obviously, your health is a top priority for us, so I went ahead and excused him from the jury. That's why we have alternates, okay?
THE COURT: All right. Thank you.
THE COURT: All right. We can continue with Ms. Lloyd's testimony.
MS. MEYERS: Where it says this protracted therapy will include 12-step private counseling, personal psychotherapy and couples therapy with his 36- fiancee, Amber. Both are in agreement to this plan.
MS. MEYERS: Do you see where I'm referring?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you recall that couples therapy was a component of Mr. Depp's treatment?
DEBBIE LLOYD: I don't recall what was set between him and the doctor.
MS. MEYERS: Do you recall Mr. Depp and Ms. Heard attending couples therapy together?
DEBBIE LLOYD: Yes.
MS. MEYERS: If we can tum to the next page here. And then at the top, it says "I met with Amber for 90 minutes and discussed the above and her concerns that he be strictly monitored and supervised."
MS. MEYERS: Do you recall Dr. Kipper meeting with Amber early on in Mr. Depp's treatment?
DEBBIE LLOYD: I do not.
MS. MEYERS: If we could bring back up document B, which is now marked as Exhibit 22; is that correct?
MS. MEYERS: Okay. Can you please go to the entry for June 24th, 2014, which is on DEPP 1661.
MS. MEYERS: Okay. Now, with respect to the entry for June 24th, 2014, this is a note -- this is an entry you prepared, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And the first line says "RN and MD met ! 10 with patient's fiancee to inform her of treatment plan for patient."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Does this refresh your recollection that you attended a meeting with Dr. Kipper and Ms. Heard concerning Mr. Depp's treatment?
DEBBIE LLOYD: I don't recall the meeting.
MS. MEYERS: Do you have any reason to doubt that this meeting occurred?
DEBBIE LLOYD: No.
MS. MEYERS: Do you have any -- other than what's reflected in this -- do you have any other I independent recollection of any such meeting with Dr. Kipper and Ms. Heard?
DEBBIE LLOYD: I do not.
MS. MEYERS: Okay. If I could direct your attention ;5 just to the last line of the note, it says here I "She was encouraged to call RN or MD with any I questions or concerns that might arise." Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Throughout your treatment of Mr. Depp, did Ms. Heard reach out to you with questions and concerns?
DEBBIE LLOYD: Yes.
MS. MEYERS: She had your phone number, correct?
DEBBIE LLOYD: Yes.
MS. MEYERS: And I think we saw some text messages, I that Mr. Nadelhaft was asking you questions, where I Ms. Heard was reaching out to you, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: When Mr. Depp became your patient, did Ms. Heard ever show you any pictures of Mr. Depp?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Do you recall Ms. Heard showing you any pictures of cocaine?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Do you recall Ms. Heard ever showing you any audio recordings of Mr. Depp?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Okay. I'd like to move on to the -- Mr. Depp's detox.
MS. MEYERS: And that was on his private island, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And you traveled down to the island with Mr. Depp; is that right?
DEBBIE LLOYD: I don't recall. I'd have to - it should be in my notes.
MS. MEYERS: We can look at those in a moment.
MS. MEYERS: But you were on the island with Mr. Depp for the majority --
DEBBIE LLOYD: Correct.
MS. MEYERS: Of his detox, correct?
DEBBIE LLOYD: Yes.
MS. MEYERS: And when you were on the island, did you see where Mr. Depp was staying?
DEBBIE LLOYD: Yes.
MS. MEYERS: And was Ms. Heard staying with him in that location as well?
DEBBIE LLOYD: Yes.
MS. MEYERS: And what did their accommodations look like?
DEBBIE LLOYD: Can you be more specific?
MS. MEYERS: What type of structure were they staying in?
DEBBIE LLOYD: It was a house.
MS. MEYERS: Can we pull up document E, which was a video.
MS. MEYERS: AV TECHNICIAN: Please stand by.
MS. MEYERS: And for the record, this was produced as DEPP 9811.
AV TECHNICIAN: Showing Exhibit 25. Let me know when you need me to play, Counsel.
MS. MEYERS: Please play. Thank you.
MS. MEYERS: Ms. Lloyd, do you recognize the location reflected in that video?
DEBBIE LLOYD: Yes. I 3
MS. MEYERS: What was it?
DEBBIE LLOYD: It's Johnny's home on his island.
MS. MEYERS: Is that where he was staying during the detox process?
DEBBIE LLOYD: Yes.
MS. MEYERS: Is that video consistent with how the house looked in August of 2014?
DEBBIE LLOYD: Yes.
MS. MEYERS: Is there any part of the house that's not reflected in that video?
DEBBIE LLOYD: The bathroom wasn't in the video.
MS. MEYERS: When you were on the island, you were I personally overseeing Mr. Depp's detox process, I correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And how often would you see him in person during that time?
MR. NADELHAFT: Objection. Asked and ! answered.
DEBBIE LLOYD: It varied.
MS. MEYERS: A day?
DEBBIE LLOYD: Did you see him in person at least once I cannot recall. When Dr. Kipper arrived, do you recall how often he would see Mr. Depp?
DEBBIE LLOYD: I do not.
MS. MEYERS: What substances was Mr. Depp -- excuse me. What substances was Mr. Depp detoxing from?
DEBBIE LLOYD: Opiates.
MS. MEYERS: Was he detoxing from any other I substances?
DEBBIE LLOYD: Not on the - I don't recall.
MS. MEYERS: Have you overseen other patients detoxing from opiates, before you were caring for Mr. Depp?
DEBBIE LLOYD: Yes.
MS. MEYERS: How many, would you estimate? I Its
DEBBIE LLOYD: Hundreds.
MS. MEYERS: What does that process do to the person, physically?
DEBBIE LLOYD: They go through withdrawal symptoms and we medicate them.
MS. MEYERS: And what type of withdrawal symptoms have you observed?
DEBBIE LLOYD: Nausea, vomiting, body aches, piloerection, rhinorrhea, restlessness, anxiety.
MS. MEYERS: Is there a time during the detox process when those symptoms are typically the most acute?
MR. NADELHAFT: Objection. six.
DEBBIE LLOYD: Yeah.
MS. MEYERS: What stage in the process is that?
DEBBIE LLOYD: Typically day three through five or
MS. MEYERS: How could you describe Mr. Depp's physical state throughout the detox process?
DEBBIE LLOYD: I don't recall specifics. I'd have to refer to my notes.
MS. MEYERS: How would you describe Mr. Depp's psychological state throughout the detox process?
DEBBIE LLOYD: I don't recall. I'd have to review my notes.
MS. MEYERS: All right. Let's go back to your notes, then, which I believe is Exhibit 23.
MS. MEYERS: Could we first go to the entry dated August 8th, 2014.
MS. MEYERS: Ms. Lloyd, does this refresh your recollection as to when you arrived on the island to assist Mr. Depp in his detox process?
DEBBIE LLOYD: According to my notes, it was August 8th.
MS. MEYERS: Okay. And, so, as I think we established earlier, you met Mr. Depp in June. Fair to say that you had known him for about two months at this time?
DEBBIE LLOYD: Correct.
MS. MEYERS: Okay.
MS. MEYERS: Can we please go to the entry for August 11th, 2014.
MS. MEYERS: And this is a note you prepared?
DEBBIE LLOYD: Yes.
MS. MEYERS: Okay. If you need to take a minute and read it over, just let me know when you're done or I can go right into it.
DEBBIE LLOYD: Okay.
MS. MEYERS: Okay. Fair to say that this note reflects that Mr. Depp was experiencing discomfort on this date?
DEBBIE LLOYD: According to my notes, yes.
MS. MEYERS: It says he was experiencing muscle spasm, chills, and pains, right?
DEBBIE LLOYD: Correct.
MS. MEYERS: Did you personally observe Mr. Depp in this state?
DEBBIE LLOYD: According to this note, it does not I appear I did.
MS. MEYERS: Okay. Are these symptoms typical during a detox process?
DEBBIE LLOYD: Yes, they are.
MS. MEYERS: Okay.
MS. MEYERS: Can we, please, go to the entry for August 12th, 2014.
MS. MEYERS: And I believe you looked at this earlier, but I'd just like to direct your attention to the last line in this first paragraph, "MD arriving this morning and will assess patient."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: Where are we on?
MS. MEYERS: So directing your attention to the August 12th, 2014 entry.
DEBBIE LLOYD: Yes, I see it. Sorry.
MS. MEYERS: Oh, okay.
MS. MEYERS: And so, based on your note, it appears that Dr. Kipper arrived on the island on August 12th; is that correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: Okay. Was the plan always for Dr. Kipper to come down to the island to attend to Mr. Depp?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Do you recall any issues in your caring for Mr. Depp prior to Dr. Kipper's arrival?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Do you recall any medical issues I Is arising with Mr. Depp before Dr. Kipper arrived I that caused you concern?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: If there had been a serious medical issue with Mr. Depp prior to Dr. Kipper's arrival would that have been reflected in your notes?
DEBBIE LLOYD: Yes.
MS. MEYERS: If Mr. Depp's behavior had been unmanageable prior to Dr. Kipper's arrival would that have been reflected in your notes?
DEBBIE LLOYD: Yes.
MS. MEYERS: Can we, please, go to the next entry for August 13th.
MS. MEYERS: And, Ms. Lloyd, this is also a note IO that you prepared?
DEBBIE LLOYD: Yes.
MS. MEYERS: Now, I'd like to direct your attention to the portion of the note that starts with I 1340. I right?
MS. MEYERS: Again, this is military time; is that Correct. And I think you testified earlier this is the time that you prepared the note, not the time of the events reflected in the note; is that right?
DEBBIE LLOYD: Yes. Sometimes - I mean, I don't recall specifics, but sometimes they were at times, and sometimes they were done later.
MS. MEYERS: So, generally speaking, when you prepared these nursing notes, how long after the events reflected in the note was the note actually prepared by you?
DEBBIE LLOYD: It varied.
MS. MEYERS: Okay. So directing your attention back to the portion that starts with" 1340." IO Do you see where it says "Patient's fiancee texted to say he wasn't feeling well. MD orders Pheno 64.8 milligrams, Neurontin 600 milligrams stat. Patient and fiancee informed that today and tomorrow will be the most difficult days and to keep in close contact with us."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you recall informing Mr. Depp and Ms. Heard that the following days would be the most difficult?
DEBBIE LLOYD: Just what was stated in my notes.
MS. MEYERS: Can we, please, go to the entry for August 17th, 2014.
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: And this is a note you prepared?
DEBBIE LLOYD: Correct
MS. MEYERS: Do you recall this specific event?
DEBBIE LLOYD: I do not. I j 8
MS. MEYERS: Do you have any reason to doubt that what is reflected in your note is accurate?
DEBBIE LLOYD: No.
MS. MEYERS: Okay. So when you wrote "RN and MD found patient sitting quietly on his porch," you believe that's an accurate recitation of how you found Mr. Depp on this date?
DEBBIE LLOYD: Correct.
MS. MEYERS: When you wrote that he was calm and stated he was frustrated, you have no reason to doubt the accuracy of that statement?
DEBBIE LLOYD: Correct.
MS. MEYERS: Could we, please, bring back up Exhibit 23 and, specifically, go to the August 18th, 2014 entry, which is on DEPP 1677.
MS. MEYERS: Ms. Lloyd, I'd like to direct your attention to -- well, first of all, this is a note that you prepared, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And I'd like to direct. your attention to the end of the note, which is actually on the b second page -- or the next page. Is Do you see at the end here, where it says "Patient was escorted" back -- or "escorted to bed"?
MS. MEYERS: Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: Would that have been you who escorted Mr. Depp to bed?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: You testified earlier, though, that you I did see Mr. Depp in the home that he was staying I 1 s in on the island, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And it says "Plans to leave the island tomorrow." Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: And directing your attention to the next note, August 19th.
MS. MEYERS: Do you see that it says, next to 2335, "arrived back in LA"?
DEBBIE LLOYD: Yes.
MS. MEYERS: Okay. So does this accurately reflect that you left the island on August 19th, 2014?
DEBBIE LLOYD: According to these notes, yes.
MS. MEYERS: I'd like to direct your attention to the August 20th, 2014 entry, which starts on the next page. And then, if you go to the next page, as well, you can see that there's another entry for August 20th, 2014.
MS. MEYERS: Do you see that?
DEBBIE LLOYD: Oh, yeah. Yep.
MS. MEYERS: Okay. On this page here, I'd like to direct your attention to the portion that starts with "1250."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: Now, it says here "RN and MD spent time
MS. MEYERS: Talking with patient."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: This would have been you and Dr. Kipper, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And does this reflect that you spoke with Mr. Depp in person?
DEBBIE LLOYD: I don't recall. I would -- yes.
MS. MEYERS: Okay. And the note goes on to say "Patient expressed frustration with the detox process and was not liking how the phenobarb was making him feel. Initially, he stated he was done with the process and no longer wanted MD and RN services. After processing his feelings and realizing how far he had come, and that part of his wanting to give up was due to tension between him and his fiancee, patient, fiancee, RN, and MD came up with a plan for fiancee to take a few days for herself and patient was willing to continue treatment but was going to refuse phenobarbital from this point forward."
MS. MEYERS: I Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Did I read that correctly?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you recall tensions between Mr. Depp I and Ms. Heard at this stage in his detox process?
DEBBIE LLOYD: Yes.
MS. MEYERS: And what do you recall about that?
DEBBIE LLOYD: I recall Johnny feeling that she was trying to interfere.
MS. MEYERS: In what way did he feel she was trying I to interfere?
DEBBIE LLOYD: By reporting to us things that he didn't feel were true.
MS. MEYERS: Can you think of a specific instance where Ms. Heard reported something to you that you found out later was not true?
DEBBIE LLOYD: I can't - I cannot remember specifics.
MS. MEYERS: Do you recall the plan for Ms. Heard to take a few days for herself?
DEBBIE LLOYD: I don't recall specifics.
MS. MEYERS: But you do recall there being tension between Mr. Depp and Ms. Heard around this time?
DEBBIE LLOYD: Yes.
MS. MEYERS: And you recall that having an impact on Mr. Depp's treatment?
DEBBIE LLOYD: I don't recall specifics.
MS. MEYERS: Let's go on to the entry for August 25th, please.
MS. MEYERS: First of all, is this a note that you prepared?
DEBBIE LLOYD: It is.
MS. MEYERS: Directing your attention to the portion that starts with "1900." First line says "Meeting at MD's house was quite stressful for patient." Do you see tl_mt?
DEBBIE LLOYD: I do.
MS. MEYERS: Do you recall attending a meeting with Mr. Depp at Dr. Kipper's house?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: The next line says "Him and his fiancee are having a hard time communicating and understanding each other's point of view and feelings.
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Do you recall any specifics about this situation?
DEBBIE LLOYD: I do not.
DEBBIE LLOYD: Couple sentences down, it says "Plan is for fiancee to start therapy tomorrow."
DEBBIE LLOYD: Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you recall that Ms. Heard started therapy shortly after Mr. Depp's detox process?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Do you have any understanding as to why Ms. Heard was starting therapy?
DEBBIE LLOYD: I do not.
MS. MEYERS: Directing your attention to the entry for August 27th, 2014, which starts on DEPP 1687 -- or 86, excuse me. 1686, yep.
MS. MEYERS: Again, this is an entry you prepared?
DEBBIE LLOYD: It is.
MS. MEYERS: Okay. Do you see where it says Received text from patient's sister that patient had been recording music with his friend until 5 and did not go to sleep until 7 and is currently sleeping
DEBBIE LLOYD: Yes.
MS. MEYERS: And who is Mr. Depp's sister that's referred to here?
DEBBIE LLOYD: Christi.
MS. MEYERS: And at this time, had you met Christi before?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Have you met Christi before?
DEBBIE LLOYD: Yes.
MS. MEYERS: How many times?
DEBBIE LLOYD: I don't know.
MS. MEYERS: More than once?
DEBBIE LLOYD: More than once, yes.
MS. MEYERS: At this time, had you communicated with Christi about Mr. Depp's treatment before?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: The entry goes on to say "Sister stated that patient and his fiancee had had a disagreement last night and that patient was able to remain calm and handle the situation appropriately." Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you recall Christi telling you that?
DEBBIE LLOYD: I do not.
MS. MEYERS: Now, do you see the portion of the note that starts with "1330"?
DEBBIE LLOYD: I do.
MS. MEYERS: The second line reads "Patient expressing feelings about argument with fiancee and feels relationship is putting unwanted stress on him right now." Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Do you recall this exchange with Mr. Depp? Sorry, I didn't catch that.
DEBBIE LLOYD: I'm sorry. I do not.
MS. MEYERS: Based on this note, can you tell whether this was a conversation you had in person with Mr. Depp?
DEBBIE LLOYD: Based on this note, yes.
MS. MEYERS: Do you recall, on other occasions, Mr. Depp expressing to you that his relationship was putting unwanted stress on him?
DEBBIE LLOYD: I'd have to review my notes.
MS. MEYERS: Okay. Directing your attention down to the portion of the notes that starts with "2130."
MS. MEYERS: It says "Patient back home. Per patient, he has a long -- he had a long conversation with fiancee and they both understand that right now is a time to work on themselves as individuals. Patient's fiancee now has an RN to help her anxiety and to monitor her while she is starting a new mood stabilizer medication." Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Who was -- I believe you testified to this earlier -- Ms. Heard's nurse was Erin Boerum; is that right?
DEBBIE LLOYD: Correct.
MS. MEYERS: And Ms. Boerum was an employee of yours; is that correct?
DEBBIE LLOYD: She was an independent contractor.
MS. MEYERS: Okay. But you placed her with Dr. Kipper; is that right?
DEBBIE LLOYD: Correct.
MS. MEYERS: Do you recall when Ms. Boerum was assigned to Ms. Heard?
DEBBIE LLOYD: I do not recall.
MS. MEYERS: Do you have any understanding as to why Ms. Heard needed a nurse?
DEBBIE LLOYD: Other than what my notes state, I do not.
MS. MEYERS: Do you recall witnessing Ms. Heard being anxious, or having anxiety?
DEBBIE LLOYD: I do not recall.
MS. MEYERS: Now, the last line here says "Patient feels this will take some of the stress off their relationship and in return," then we go to the next page, "take some stress off of him."
MS. MEYERS: Did I read that correctly?
DEBBIE LLOYD: You did.
MS. MEYERS: Do you recall why Mr. Depp felt that Ms. Heard having a nurse would reduce the stress on their relationship?
DEBBIE LLOYD: I do not recall.
MS. MEYERS: From your perspective, was it important for Mr. Depp's treatment that his stress be reduced?
DEBBIE LLOYD: Yes.
MS. MEYERS: And why is that?
DEBBIE LLOYD: Any patient going through detox or changes, it's always important to relieve as much stress as you can from them.
MS. MEYERS: Let's go to the entry for September 10th, please, which is on DEPP 1694 and continues on to 1695.
MS. MEYERS: September 10, 2014 entry, this is your entry, correct, you prepared this?
DEBBIE LLOYD: Correct. Sorry.
MS. MEYERS: And if I could direct your attention to the portion that starts with "2330," which is actually on the next page.
MS. MEYERS: The first line says "Met with patient. He complained of body aches and nausea.
DEBBIE LLOYD: I do.
MS. MEYERS: And does this reflect that you were physically with Mr. Depp at this time?s
DEBBIE LLOYD: It would, yes.
MS. MEYERS: Okay. A couple sentences down it says, and this portion is highlighted here, "While RN s was visiting patient, fiancee came in and tried to start argument with him. Patient was able to stay ! 10 calm and talk his fiancee down." Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Do you recall the incident reflected in I this note?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you recall any instances where you witnessed Ms. Heard try and start a fight with Mr. Depp?
DEBBIE LLOYD: Yeah.
MR. NADELHAFT: Objection.
MS. MEYERS: How many instances do you remember?
DEBBIE LLOYD: I don't recall specific numbers.
MS. MEYERS: Do you remember at least one?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you remember more than one?
DEBBIE LLOYD: Yes.
MS. MEYERS: More than two?
DEBBIE LLOYD: I don't recall specific numbers.
MS. MEYERS: What do you remember about that first incident, that you can remember?
DEBBIE LLOYD: I remember, one night, trying to leave the penthouse and Amber standing in the elevator and not letting us leave.
MS. MEYERS: Why wasn't she letting you leave?
DEBBIE LLOYD: She didn't want him to leave.
MS. MEYERS: Had they been fighting previous to that point?
DEBBIE LLOYD: I wasn't there previously.
MS. MEYERS: And what's the other instance you remember?
DEBBIE LLOYD: I can't remember specifics.
MS. MEYERS: Do you have any reason to doubt the accuracy of what's reflected in your note here?
DEBBIE LLOYD: No.
MS. MEYERS: Do you have any understanding as to what you meant when you said "patient was able to" remain calm -- "was able to stay calm," excuse me, "and talk his fiancee down"?
DEBBIE LLOYD: I don't recall the events of that note.
MS. MEYERS: Had you seen Mr. Depp and Ms. Heard get in a fight before this date?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Let's go to the entry of September 12th, please.
MS. MEYERS: And this is a note that you prepared as well, Ms. Lloyd?
DEBBIE LLOYD: That is correct.
MS. MEYERS: Okay. The first line here says "RN and MD visited patient at work."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: And so, this reflects that both you and Dr. Kipper went and saw Mr. Depp; is that right?
DEBBIE LLOYD: Correct.
MS. MEYERS: And the entry states here, patient expressed some concerns with fiancee's behavior and how it is adding stress to his life.
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Do you recall Mr. Depp saying this to you in this instance?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you have any reason to doubt the accuracy of what's reflected in your note?
DEBBIE LLOYD: I do not.
MS. MEYERS: Could we please go to the entry for October 22nd, 2014, which starts on 1717 and continues on to Depp 1718.
DEBBIE LLOYD: My notes are different. What's the top of the - can I see the top of that, just so I know what I'm looking for? Okay.
MS. MEYERS: First of all, this is also a note that you prepared, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And if you want to take a minute and read through the note, I know it goes on for two pages.
DEBBIE LLOYD: Okay.
MS. MEYERS: Just Jet me know when you've read through this.
DEBBIE LLOYD: Okay.
MS. MEYERS: Fair to say that this note reflects that you and Mr. Depp are in Georgia when the events in this note occurred?
DEBBIE LLOYD: I think we were. At the end, it says "now in Georgia." I don't recall that it was a travel day.
MS. MEYERS: Well, you see above that, where it says I "I 0/22," and then below it, it says "now in Georgia"?
DEBBIE LLOYD: Yes.
MS. MEYERS: So based on your notes, you were in Georgia on October 22nd, 2014?
DEBBIE LLOYD: All right.
MS. MEYERS: Do you recall being in Georgia with l P8 Mr. Depp?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you recall who else was with you in Georgia?
DEBBIE LLOYD: I don't recall who was with us, but the Is purpose of the trip was to visit Amber on location.
MS. MEYERS: Okay. So Amber was in Georgia as well?
DEBBIE LLOYD: Yes.
MS. MEYERS: Okay. Now, directing your attention to the entry that's on the next page and begins with "1530." It states here, "He requested an emergency session with the psychiatrist to discuss feeling about arguments with fiancee and would like some tools to help him" feel -- "help him feel with his emotions." Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Do you recall Mr. Depp and Ms. Heard l ! 15 having a fight on this trip in Georgia?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you recall who Mr. Depp's I psychiatrist was at this time?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you recall why Mr. Depp started seeing a psychiatrist?
DEBBIE LLOYD: I do not.
MS. MEYERS: Directing your attention down to the portion of the note that starts with "2010." It says here "Patient spoke to a psychiatrist for 50 minutes and was open and honest with his feelings. He feels better after conversation but also feels he is in a no-win situation with fiancee." Do you see that?
DEBBIE LLOYD: I'm kind of lost where we're at right now.
MS. MEYERS: Oh, sorry.
MS. MEYERS: FEMALE SPEAKER: Yes, yes, sorry.
MS. MEYERS: Does this reflect that you were present with Mr. Depp when he spoke with his psychiatrist?
DEBBIE LLOYD: I don't remember if it was based on him telling me or if I was present.
MS. MEYERS: Do you recall Mr. Depp ever expressing to you that he felt he was in a 110-win situation with Ms. Heard?
DEBBIE LLOYD: I don't recall the specific words.
MS. MEYERS: But you wrote them in your nursing note correct Do you see the box still in this portion that starts with 2010 Do you see where it says Plan is for patient and fiancee to go to dinner this evening Patient is feeling exhausted and wants to stay home but does not want to upset fiancee Do you see that?
DEBBIE LLOYD: Are we on the same page?
MS. MEYERS: Yes. We're still in the portion of the note that starts with 2010.
DEBBIE LLOYD: 2010. Okay. Yes. Yep.
MS. MEYERS: Do you recall this specific incident?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you have any understanding as to why Mr. Depp would be concerned about upsetting his fiancee?
DEBBIE LLOYD: I do not.
MS. MEYERS: All right.
MS. MEYERS: If we can go on to the next entry, which is on the same page, 1023.
MS. MEYERS: And this is also a note you prepared, Ms. Lloyd?
DEBBIE LLOYD: It is.
MS. MEYERS: Okay. It says here you text patient to see if RN could come by and check in.
MS. MEYERS: Is Do you see that?
DEBBIE LLOYD: I did-I do.
MS. MEYERS: Why did you want to check in on Mr. Depp?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Were you ever concerned about Mr. Depp I when he and Ms. Heard were in arguments?
DEBBIE LLOYD: Yes.
MS. MEYERS: Why were you concerned?
DEBBIE LLOYD: Their arguments were a trigger for him emotionally.
MS. MEYERS: Any other reason?
DEBBIE LLOYD: No.
MS. MEYERS: What do you mean by "a trigger for him emotionally"?
DEBBIE LLOYD: It would cause him to be upset, add stress.
MS. MEYERS: The next portion of this note says "When RN arrived in the room, patient was agitated and felt fiancee was using the term mania to express -- "to explain his behavior and excuse herself from any fault during argument." Do you see that?
DEBBIE LLOYD: Yeah.
MS. MEYERS: Do you have any -- did you ever hear Ms. Heard use the term "mania" to describe Mr. Depp?
DEBBIE LLOYD: I don't recall if that was - I heard it from her or heard that she was saying it to others.
MS. MEYERS: But you do have some recollection of hearing that Ms. Heard was using that word, whether it was directly from her or from others?
DEBBIE LLOYD: Yes.
MS. MEYERS: The note goes on to say "Patient was upset by this label. RN processes feelings with patient and he was able to see fiancee's negative behaviors." Did I read that correctly?
DEBBIE LLOYD: Yes.
MS. MEYERS: Did you have any recollection of what you meant when you wrote that?
DEBBIE LLOYD: I do not.
MS. MEYERS: You don't have any understanding of what "fiancee's negative behaviors" refers to?
DEBBIE LLOYD: I don't recall specifics.
MS. MEYERS: Do you recall generally?
DEBBIE LLOYD: Yes.
MS. MEYERS: And what do you recall?
DEBBIE LLOYD: At times - what's the word - she would almost try to instigate him.
MS. MEYERS: And when you say "she," you're referring to Ms. Heard?
DEBBIE LLOYD: Yes.
MS. MEYERS: Did you ever witness that personally?
DEBBIE LLOYD: Yes.
MS. MEYERS: On more than one occasion?
DEBBIE LLOYD: Yes.
MS. MEYERS: Ballpark, how many times did you witness that during their -- during the time you cared for Mr. Depp?
DEBBIE LLOYD: I don't recall a number.
MS. MEYERS: More than five?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: When you say Ms. Heard would try to "instigate him," what do you mean?
DEBBIE LLOYD: I remember an argument -- or being in there when he was going from room to room trying to remove himself from a situation, and she would just follow him from room to room and not give him his space.
MS. MEYERS: And that's one specific instance that O you remember?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you remember seeing that type of behavior on other occasions?
DEBBIE LLOYD: Yes.
MS. MEYERS: Are you aware of any of the fights that we just went through, are you aware that any of them became physical?
DEBBIE LLOYD: No.
MS. MEYERS: From what you observed, what was the cause of the friction between Mr. Depp and Ms. Heard during this time?
DEBBIE LLOYD: I don't know.
MS. MEYERS: Could we, please, go to the entry for November 3rd, 2014, which is on DEPP 172?
MS. MEYERS: AV TECHNICIAN: 172? Sorry, Counsel.
MS. MEYERS: Yeah, 1721.
MS. MEYERS: Ms. Lloyd, this is also a note you prepared?
DEBBIE LLOYD: Correct.
MS. MEYERS: And it says here you arrived at Mr. Depp's home and he was "focused on relationship with fiancee and is struggling with conflicted emotions."
MS. MEYERS: Did I read that right?
DEBBIE LLOYD: Yes.
MS. MEYERS: Based on this note, is that something Mr. Depp would have told you?
DEBBIE LLOYD: Based on this note, it appears so.
MS. MEYERS: Looks like there's another note for November 3rd below this one. Do you see that? And it continues on to the next page, which is DEPP 1722.
MS. MEYERS: If we could go there, please.
MS. MEYERS: And, Ms. Lloyd, directing your attention to the portion that struts with "1700," do you see where it says "RN went back to patient's house. He was chatting with a friend and was feeling stressed about his relationship"?
MS. MEYERS: Do you see that? IS
DEBBIE LLOYD: I do.
MS. MEYERS: And it goes on to say "He feels she is not being truthful with him and he is not sure how to" comfort her about this when -- excuse me, "confront her about this when she arrives home." Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: And the "she" here refers to Ms. Heard; is that right?
DEBBIE LLOYD: Correct.
MS. MEYERS: Do you remember this exchange with Mr. Depp?
MS. MEYERS: MR. N.ADELH.AFT: Objection.
MS. MEYERS: Do you have any reason to doubt the accuracy of your note?
DEBBIE LLOYD: I do not.
MS. MEYERS: If we could turn to the entry for November 17th, 2014, which begins on DEPP 1723.
MS. MEYERS: Ms. Lloyd, do you see, at the very bottom, it says 11/17?
DEBBIE LLOYD: Yes.
MS. MEYERS: Okay. And then I think the entry itself is on the next page.
MS. MEYERS: Yes. Thank you.
MS. MEYERS: This is also a note you prepared?
DEBBIE LLOYD: Correct.
MS. MEYERS: And this says "RN and MD went to patient's house to assess him."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Again, does this reflects that you and Dr. Kipper went to see Mr. Depp?
DEBBIE LLOYD: Correct.
MS. MEYERS: Do you have any recollection of why Mr. -- excuse me, why Dr. Kipper was visiting with Mr. Depp at this time?
DEBBIE LLOYD: I do not.
MS. MEYERS: The next line says "Patient appears anxious and depressed over relationship issues."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: And then it says "Patient continues to be ambivalent about relationship status."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Do you recall Mr. Depp expressing these sentiments to you?
MR. NADELHAFT: Objection. Hearsay.
DEBBIE LLOYD: I don't recall specific conversations.
MS. MEYERS: But you also have -- but this is what you wrote in your notes, correct?
MS. MEYERS: I'm son-y, I didn't catch that.
DEBBIE LLOYD: Correct. Sorry.
MS. MEYERS: Thank you.
DEBBIE LLOYD: Sorry.
MS. MEYERS: Do you recall when Mr. Depp and Ms. Heard got married?
DEBBIE LLOYD: I don't recall the date.
MS. MEYERS: But you said -- you testified earlier that you did attend the wedding?
DEBBIE LLOYD: Correct.
MS. MEYERS: Were you there to provide nursing Is services?
DEBBIE LLOYD: I don't really recall if I was a guest or - I don't think they made that clear to me. I 8
MS. MEYERS: Did Dr. Kipper attend the wedding?
DEBBIE LLOYD: He did.
MS. MEYERS: And did Erin Boerum attend the wedding?
DEBBIE LLOYD: She did.
MS. MEYERS: Do you recall any discussions of a prenuptial agreement between Mr. Depp and Ms. Heard before they got married?
DEBBIE LLOYD: Yes.
MS. MEYERS: And what do you recall? -
DEBBIE LLOYD: I _don't recall specifics.
MS. MEYERS: What do you recall, generally?
DEBBIE LLOYD: I only recall what Johnny told me about the conversation.
MS. MEYERS: And what was that?
DEBBIE LLOYD: That she didn't take it well.
MS. MEYERS: Didn't take what well?
DEBBIE LLOYD: The idea.
MS. MEYERS: Sorry. I didn't hear the end of that.
DEBBIE LLOYD: The idea of having to sign a prenup.
MS. MEYERS: Did Johnny tell you that he asked Ms. Heard to sign a prenup?
DEBBIE LLOYD: I don't recall specifics.
MS. MEYERS: But you recall Johnny telling you that Ms. Heard didn't want to sign a prenup?
DEBBIE LLOYD: Yes.
MS. MEYERS: And when you say "didn't take that well," what are you referring to?
DEBBIE LLOYD: From what Johnny said, her reaction was when he asked -- when they spoke about the prenup.
MS. MEYERS: Do you recall that in January of 2015, Mr. Depp and Ms. Heard traveled to Japan together?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Do you recall traveling to Japan with Mr. Depp?
DEBBIE LLOYD: I recall being in Japan, yes.
MS. MEYERS: Do you remember anything specific about I that trip?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you recall Mr. Depp and Ms. Heard having a fight on a plane?
DEBBIE LLOYD: I recall a fight on a plane, but I don't know the time it was around.
MS. MEYERS: What do you remember about that fight?
DEBBIE LLOYD: It was another instance where he was sitting at a table and not wanting to talk and she wouldn't leave the table.
MS. MEYERS: What was she doing?
DEBBIE LLOYD: She wouldn't leave the table and he was saying, you know, "please, just go away."
MS. MEYERS: And what was she saying?
DEBBIE LLOYD: I don't remember her words.
MS. MEYERS: How was her tone?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: You spoke with Mr. Nadelhaft about this earlier, but at some point, you traveled to Australia with Mr. Depp, right?
DEBBIE LLOYD: Correct.
MS. MEYERS: Can we pull up what has been previously marked as Exhibit 14.
MS. MEYERS: I would like to direct your attention to the March 1st, 2015 email from Dr. Kipper at 2:10 p.m. Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Do you recall Mr. Depp having issues with his sleep when he was in Australia?
DEBBIE LLOYD: Not specifically in Australia.
MS. MEYERS: Do you recall Mr. Depp having issues with his sleep, generally?
DEBBIE LLOYD: Yes.
MS. MEYERS: And what issues were those?
DEBBIE LLOYD: Hard time sleeping and staying on a sleep schedule.
MS. MEYERS: Ms. Lloyd, when you were in Australia with Mr. Depp, did you see where he was staying?
DEBBIE LLOYD: Yes.
MS. MEYERS: And how many times did you go to that property?
DEBBIE LLOYD: I don't recall specific numbers.
MS. MEYERS: Fair to say you went there multiple times, though?
DEBBIE LLOYD: Yes.
MS. MEYERS: You've talked about this with Mr. Nadelhaft earlier. At some point, in Australia, you learned that Mr. Depp had injured his finger, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And Dr. Kipper was already in Australia at that time?
DEBBIE LLOYD: Correct.
MS. MEYERS: And you testified earlier that you and Dr. Kipper went to see Mr. Depp after he injured his finger, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: Do you recall anything about -- what do you recall about Mr. Depp's physical appearance when you first saw him?
DEBBIE LLOYD: I don't recall specifics.
MS. MEYERS: What do you remember about his demeanor, if anything?
DEBBIE LLOYD: I don't remember the events of when I i first arrived.
MS. MEYERS: But you did see Mr. Depp at that time, I! I correct?
DEBBIE LLOYD: I can't recall when I initially saw him after the finger event.
MS. MEYERS: And I believe you testified you don't recall whether Ms. Heard was at the house when you went to attend to Mr. Depp, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: Do you remember seeing Ms. Heard in Australia?
DEBBIE LLOYD: Yes.
MS. MEYERS: Did you ever see any injuries on Ms. Heard when she was in Australia?
DEBBIE LLOYD: Yes.
MS. MEYERS: What did you see?
DEBBIE LLOYD: Bruise on her arm.
MS. MEYERS: Anything else?
DEBBIE LLOYD: No.
MS. MEYERS: Did she have any injuries to her face, 1! that you can recall? ,20
DEBBIE LLOYD: Not that I recall.
MS. MEYERS: Any cuts or abrasions, that you can recall?
DEBBIE LLOYD: Not that I recall.
MS. MEYERS: Do you recall Ms. Heard ever seeking medical treatment from you while she was in Australia?
DEBBIE LLOYD: I do not recall her ever seeking medical treatment from me.
MS. MEYERS: At the time that Mr. Depp injured his finger, Ms. Heard was a patient of Dr. Kipper, correct?
DEBBIE LLOYD: I'm not sure.
MS. MEYERS: Do you recall whether Ms. Boerum was already assigned to Ms. Heard?
DEBBIE LLOYD: I don't recall if she was working with her at that time.
MS. MEYERS: Can we turn back to the nursing notes, which is Exhibit 23. And, specifically, the entry for March 7th, which is on 1732.
DEBBIE LLOYD: Is this March 7th of 2014 or -
MS. MEYERS: Yes. It says "3/7/15."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: 3/7/15, no. Yes.
MS. MEYERS: You said you saw a bruise on Ms. Hem d's mm at some point when you were in Australia, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: Do you have any understanding of how she got that bruise?
DEBBIE LLOYD: I do not.
MS. MEYERS: Okay. Directing your attention to the entry for March 7th, 2015.
MS. MEYERS: Do you see here it says "MD received text message from client that he had been arguing with his wife and that he cut his finger"?
DEBBIE LLOYD: Yes, I see that.
MS. MEYERS: Okay. So this is the day that you went and saw Mr. Depp after his injury, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: Now, if I could direct your attention down to the portion that starts with "1530."
DEBBIE LLOYD: Okay.
MS. MEYERS: It says "MD cleaned and dressed wound to R middle finger."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: What does "R middle finger" reflect?
DEBBIE LLOYD: Right.
MS. MEYERS: And so, Mr. Depp had cut his middle right finger; is that correct?
DEBBIE LLOYD: According to this, yes.
MS. MEYERS: Now, if I could direct your attention down to the bottom part of this entry that starts with "1130." Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Now, this starts with "Patient and staff returned from ER at 2130." Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: So, am I -- is it correct that the 1130, at the beginning of this, is referring to 11:30 p.m.?
DEBBIE LLOYD: Yeah. That would make sense.
MS. MEYERS: So, this is the same day that you were notified that Mr. Depp had injured his finger, correct?
DEBBIE LLOYD: According to this, yes.
MS. MEYERS: Okay. And this was also the same day that Mr. Depp was seen in the ER for his finger, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: In the middle of the page here, do you see -- in the middle of this entry, do you see where it says "Upon arrival back to the apartment, patient expressed feelings of anger and sadness about his relationship. Patient was encouraged to stay away from wife, as the relationship is toxic. Patient expressed verbal understanding and why they needed to separate." Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you have any recollection of this ! 17 conversation, beyond what's reflected in the ; notes?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you have any reason to doubt the accuracy of what you documented in your notes?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you recall advising Mr. Depp to stay away from Ms. Heard?
DEBBIE LLOYD: I don't recall anything other than what's stated in my notes.
MS. MEYERS: Do you recall ever having the view that Mr. Depp and Ms. Beard's relationship was toxic?
DEBBIE LLOYD: Yes.
MS. MEYERS: And what's the basis for that view?
DEBBIE LLOYD: Conversations that he would share with tome.
MS. MEYERS: What did Mr. Depp share with you?
DEBBIE LLOYD: I don't remember specifics, just, like, things we reviewed in my notes, that he would be emotional and that the relationship was causing him stress.
MS. MEYERS: After Mr. Depp injured his finger in Australia, do you recall him coming back to LA?
DEBBIE LLOYD: I don't recall specifics, but I know we did return to LA at some point.
MS. MEYERS: Was Mr. Depp's hand bandaged at all?
DEBBIE LLOYD: Yes.
MS. MEYERS: And why was that?
DEBBIE LLOYD: At one - I mean, beforehand, we kept it bandaged to keep it clean, and then he had surgery, and it was bandaged after the surgery.
MS. MEYERS: Do you recall that Mr. Depp had pins in his finger?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you recall Mr. Depp reporting that his finger was in pain?
DEBBIE LLOYD: Yes.
MS. MEYERS: How would he report his pain to you?
DEBBIE LLOYD: I'd have to review my notes for specifics.
MS. MEYERS: Let's take a look at the entry in your notes for March 23rd, 2015, which is on page -- it starts on page 1735 and goes on to 736.
DEBBIE LLOYD: I see it.
MS. MEYERS: Actually, before we turn to that one, do you see, in the entry above for 3/22/15? Do you see that entry?
DEBBIE LLOYD: Yes.
MS. MEYERS: Okay. And do you see next to 20 -- the portion of the entry that starts with 2015, do you see in the middle it says "currently 5/10"?
DEBBIE LLOYD: Yes.
MS. MEYERS: Do you know what that refers to?
DEBBIE LLOYD: It's a pain scale.
MS. MEYERS: And is that how Mr. Depp would report his pain to you?
DEBBIE LLOYD: According to my notes.
MS. MEYERS: Okay. So, now going to the entry for March 23rd. First of all, do you see the portion of the entry that starts with "120"?
DEBBIE LLOYD: Yes.
MS. MEYERS: Is this 1 :20 in the morning, a.m.?
DEBBIE LLOYD: According to this, yes.
MS. MEYERS: Do you see it says "patient states his I wife is trying to argue with him"?
DEBBIE LLOYD: I see that.
MS. MEYERS: And, again, you have no reason to doubt I the accuracy of your note?
DEBBIE LLOYD: Correct.
MS. MEYERS: Turning to the next page. Do you see the portion of the note that starts with "545"?
DEBBIE LLOYD: Yes.
MS. MEYERS: And it says "called to loft," correct?
DEBBIE LLOYD: Yes.
MS. MEYERS: What does that refer to?
DEBBIE LLOYD: I don't know specifically. Loft is s where they were living.
MS. MEYERS: Is that the Eastern Columbia Building?
DEBBIE LLOYD: Correct.
MS. MEYERS: And then, the next two sections of this note says "0820 torod, va" and then at 1445, the same thing. Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: What is that referring to?
DEBBIE LLOYD: Incomplete note. It would have been Toradol and Valium administered.
MS. MEYERS: Do you have any recollection as to why I those medications would have been administered? Its
DEBBIE LLOYD: They were for his pain.
MS. MEYERS: And then do you see below that it says "Flu Thursday afternoon and Tuesday afternoon. Skin graft bandage off week from Tuesday. Pin off in two weeks"?
DEBBIE LLOYD: Yes.
MS. MEYERS: What does this reflect?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Did Mr. Depp have a skin graft on his finger?
DEBBIE LLOYD: He did.
MS. MEYERS: And I think you testified that -- you just testified that he had pins in his finger as well, right? IO Sorry, I didn't hear that.
DEBBIE LLOYD: Correct.
MS. MEYERS: Okay. So, at this time, on March 23rd, he had bandages and a skin graft and pins in his finger?
DEBBIE LLOYD: According to this, yes.
MS. MEYERS: And then, do you see, in the section that starts with 2000, "Patient informed wife is coming to talk to him and he became extremely anxious."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Do you have any recollection of why Mr. Depp was anxious?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you remember being present for a fight with Mr. Depp -- between Mr. Depp and Ms. Heard shortly after Mr. Depp returned from Australia?
DEBBIE LLOYD: I don't remember specifics.
MS. MEYERS: Do you recall a fight when Amber's sister, Whitney, was present?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Can we please pull up document H, please.
MS. MEYERS: AV TECHNICIAN: exhibit 27.
MS. MEYERS: Now, just for the record, this is a document that has a Bates number WHI06 through 109. And, Ms. Lloyd, you're not included on this, but I just want to direct your attention to the first text message here. This is -- I can represent to you these are text messages between Erin Boerum and Whitney Heard.
DEBBIE LLOYD: Okay.
MS. MEYERS: Before I proceed, do you know who Whitney Heard is?
DEBBIE LLOYD: Yes.
MS. MEYERS: Have you met her before?
DEBBIE LLOYD: Yes.
MS. MEYERS: On how many occasions have you met Whitney?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: And what is Whitney's relation to Ms. Heard?
DEBBIE LLOYD: Sister.
MS. MEYERS: So the first text message appears to be from Erin, says Debbie just -- and it's on 14 -- is that 1432, military time, on the date March 23rd, 2015.
MS. MEYERS: Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: Okay. And it says "Debbie just told me ! what is going on and to check with you. Is Amber I awake or falling asleep?" Do you see that?
DEBBIE LLOYD: Yes. l _E
MS. MEYERS: Do you recall reaching out to Earn on this date?
DEBBIE LLOYD: I do not.
MS. MEYERS: Directing your attention down to Whitney -- to three messages down from Whitney -- or, excuse me, let's go up. Do you see that Whitney responds to Erin, "she finally fell asleep."
MS. MEYERS: And then Erin says, "Thank goodness. She must be exhausted. Do you want me to come to the loft or is she safe and sound asleep?" Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: And then Whitney says "Safe? No. She's not. She keeps saying she wants to kill !is herself." Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Did you ever hear Ms. Heard say that she wanted to kill herself?
DEBBIE LLOYD: No.
MS. MEYERS: Do these text messages, combined with your notes, refresh your recollection about an incident that occurred on March 23rd, 2016?
DEBBIE LLOYD: I remember an incident, but I don't remember the date of it.
MS. MEYERS: What incident are you remembering?
DEBBIE LLOYD: There is an incident where Johnny and Amber got into a fight at the loft.
MS. MEYERS: And what do you remember about that?
DEBBIE LLOYD: I was staying next door at a hotel and security had come to get me saying that they had had an argument and Johnny wanted to go back to 1186.
MS. MEYERS: Sorry. Is 86 the Sweetzer property?
DEBBIE LLOYD: Yes.
MS. MEYERS: Sorry. Continue.
DEBBIE LLOYD: So I went to the lofts, and I remember that night, Amber was already leaving. She was in the lobby when we walked through. And when she saw that I was coming, she came back up to the apartment.
MS. MEYERS: And what happened when Ms. Heard came back up to the apartment?
DEBBIE LLOYD: I don't remember specifically what happened. I remember Johnny was sitting outside and we went to leave and somehow we didn't end up leaving.
MS. MEYERS: And why didn't you end up leaving?
DEBBIE LLOYD: I don't remember.
MS. MEYERS: Do you remember who else was in the apartment?
DEBBIE LLOYD: I remember Travis, one of the security guards, was there.
MS. MEYERS: Anyone else that you can remember?
DEBBIE LLOYD: I don't remember exactly who else was there.
MS. MEYERS: Is Travis, Travis McGivern?
DEBBIE LLOYD: Correct.
MS. MEYERS: Do you recall seeing Ms. Heard throw anything at Mr. Depp?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you remember Mr. Depp throwing anything at Ms. Heard?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Do you remember witnessing any physical violence on that occasion?
DEBBIE LLOYD: I saw Johnny push over one of Amber's clothing racks.
MS. MEYERS: Okay. No physical violence directed at any human, correct?
DEBBIE LLOYD: No.
MS. MEYERS: Okay. You said you didn't end up leaving the apartment after that, correct?
DEBBIE LLOYD: At some point that night, we left.
MS. MEYERS: When you say "we," who does that o ! 10 include?
DEBBIE LLOYD: Myself, Johnny, and Travis.
MS. MEYERS: And where did you go?
DEBBIE LLOYD: I don't remember.
MS. MEYERS: Do you know where Amber was that night?
DEBBIE LLOYD: I don't know.
MS. MEYERS: But she didn't come with you?
DEBBIE LLOYD: No.
THE COURT: Ladies and gentlemen, let's go ahead and take our afternoon recess for 15 minutes, okay? Again, don't talk to anybody and don't do any outside research, okay? All right. We'll see you in 15 minutes.
COURT BAILIFF: All rise.
COURT BAILIFF: All rise. Be seated and I l O come to order.
THE COURT: All right. Are we ready for the jury?
THE COURT: Okay. We're ready for the jury? Thank you.
THE COURT: All right. Thank you. All right. Do you want to continue with the testimony? Thank you.
MS. MEYERS: Can you please go back to the nursing notes, which are Exhibit 23. And, specifically, could we go to the entry for March 25th, that starts on DEPP 1736 and goes on to 1737.
MS. MEYERS: Ms. Lloyd, do you see at the bottom here where it says "325"?
DEBBIE LLOYD: Yes.
MS. MEYERS: If we can just go to the next page.
MS. MEYERS: You agree this is a continuation of that note, correct?
DEBBIE LLOYD: Yes.
MS. MEYERS: Okay. And do you see, under 1330, it says "Patient states pain is 4 out of 10."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: And what does that reflect?
DEBBIE LLOYD: Pain was being rated at a 4 out of 10.
MS. MEYERS: And then directing your attention down to the entry for March 26th.
MS. MEYERS: This is a note that you prepared, yes?
DEBBIE LLOYD: Yes.
MS. MEYERS: Okay. And just to make sure, I'm not sure I asked, but the prior two notes, those are also notes that you prepared, right?
DEBBIE LLOYD: Correct.
MS. MEYERS: Now, why don't you take a moment and read through this note, and just let me know when you're done.
DEBBIE LLOYD: Okay.
MS. MEYERS: Now, the beginning of the notes starts at 0145.
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: And so, again, is that I :45 in the morning?
DEBBIE LLOYD: Correct.
MS. MEYERS: It says here "RN called to patient's home. Upon arrival, patient and wife were fighting in the garage."
MS. MEYERS: !s Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Do you remember this incident?
DEBBIE LLOYD: I do not.
MS. MEYERS: It says when argument became heated, patient removed himself from situation and had security drive him to another home.
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: I think you just testified you don't ! remember witnessing this, correct?
DEBBIE LLOYD: I do not.
MS. MEYERS: But you don't have any reason to doubt the accuracy of what you wrote down in your note, I is correct?
DEBBIE LLOYD: I do not.
MS. MEYERS: Had you seen Mr. Depp remove himself I from fights before, in this manner?
DEBBIE LLOYD: Yes.
MS. MEYERS: Could we please turn to the entry for March 31st, which is on page DEPP 1740.
MS. MEYERS: Ms. Lloyd, this is also a note you prepared?
DEBBIE LLOYD: It is.
MS. MEYERS: Do you see the portion that starts Is "0130, patient continues to c/o pain 10/10, which is causing anxiety and insomnia."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: And what does this mean, "plaintiff po continues to c/o pain 10/10"?
DEBBIE LLOYD: Complain of.
MS. MEYERS: And the 10 out of 10 is the pain on the scale that you referenced previously, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: Directing your attention down to the portion that starts 1516. It says "At follow-up with surgeon, bandage was removed from skin graft. Graft took a hundred percent but there was an infection under bolster. Finger was drained, pin was removed, and Rocephin IG was administered during appointment." Did I read that correctly?
DEBBIE LLOYD: Yes.
MS. MEYERS: Excuse me if I my pronunciation is incorrect.
MS. MEYERS: Does this reflect that 1\,1:r. Depp had the bandage from his skin graft on his right middle finger removed on this date?
DEBBIE LLOYD: Meaning removed at that time or removed for good?
MS. MEYERS: Removed at that tune.
DEBBIE LLOYD: At that time, that's what that would mean.
MS. MEYERS: And the pm from his finger was also removed?
DEBBIE LLOYD: According to this.
MS. MEYERS: Okay. And when you say "the bandage was removed at that time," are you clarifying that because another bandage was put on?
DEBBIE LLOYD: I don't remember. That's why I was clarifying.
MS. MEYERS: Okay. Do you remember what type of bandages Mr. Depp had on his hand at the tune?
DEBBIE LLOYD: I didn't hear you. What type of bandage?
MS. MEYERS: Yes.
DEBBIE LLOYD: I don't remember specifics.
MS. MEYERS: Was it a hard cast or a soft cast?
DEBBIE LLOYD: Soft.
MS. MEYERS: Was Mr. Depp's hand -- I'm sorry --
DEBBIE LLOYD: I don't recall if it was a cast, but I know the bandage was soft.
MS. MEYERS: Do you recall whether Mr. Depp could move the hand that was bandaged?
DEBBIE LLOYD: Can, yes. For a while, his finger was, like, splinted.
MS. MEYERS: Could he grab anything with that hand?
DEBBIE LLOYD: I remember him pretending he had a claw. He could do this.
MS. MEYERS: Were certain fingers bound together in the cast?
DEBBIE LLOYD: I don't remember specifics.
MS. MEYERS: Mr. Depp eventually returned to Australia after the time period we were just discussing, correct?
DEBBIE LLOYD: Correct.
MS. MEYERS: And you returned with him?
DEBBIE LLOYD: Correct.
MS. MEYERS: And how long did you stay m Australia on that trip?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: I'd like to direct your attention to the last page of this document that's marked -- Is it's for July 1st.
MS. MEYERS: Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: Please take a moment and read through this, and just let me know when you're done.
DEBBIE LLOYD: I'm done.
MS. MEYERS: Okay. This is a note you prepared, yes?
DEBBIE LLOYD: Correct.
MS. MEYERS: And do you remember the events reflected m this note?
DEBBIE LLOYD: I do not.
MS. MEYERS: Directing your attention to the portion that starts with 1235. Do you see where it says "RN received text from patient's assistant that I the arguments between patient and wife are continuing and RN should come to the set to see patient"? Did I read that correctly? I'm sorry, I didn't hear your response.
DEBBIE LLOYD: Yes.
MS. MEYERS: Okay. Who was the assistant referred to there, if you can recall?
DEBBIE LLOYD: I don't recall. He had two assistants.
MS. MEYERS: And who were they?
DEBBIE LLOYD: Stephen and Nathan.
MS. MEYERS: Do you recall both of them being in Australia?
DEBBIE LLOYD: I don't recall if they were both there.
MS. MEYERS: Why did they -- why did you understand -- strike that. Why did you understand that you were being called to set?
MR. NADELHAFT: Objection to hearsay.
DEBBIE LLOYD: I don't recall at the time.
MS. MEYERS: All right. Directing your attention to the last part of this note that says "2100." Says here Between shooting, patient was able to express his feelings to RN. He explained that his wife makes him feel that he could never do anything right and that they cannot have a conversation without her blowing up.
MS. MEYERS: Do you see that?
DEBBIE LLOYD: Yes.
MS. MEYERS: And I think you testified you don't recall having th.is exchange with Mr. Depp?
DEBBIE LLOYD: Correct.
MS. MEYERS: It goes on to say, "Patient was given positive reinforcement for expressing his feelings. Patient verbalized he knows it's best for them to take a break from each other when the fights start to escalate, but how she will follow him from room to room when he tries to get away."
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: Have you ever personally observed Mr. Depp try to get away from Ms. Heard and her, then, following him?
DEBBIE LLOYD: Yes.
MS. MEYERS: But you don't recall him telling you in this specific instance?
DEBBIE LLOYD: I do not.
MS. MEYERS: And, again, you don't have any reason to doubt the accuracy of th.is note?
DEBBIE LLOYD: I do not.
MS. MEYERS: This appears to be the last note reflected in this document.
MS. MEYERS: Do you see that?
DEBBIE LLOYD: I do.
MS. MEYERS: And I think you said you don't recall, specifically, when you stopped caring for Mr. Depp, correct?
MS. MEYERS: COURT REPORTER: I'm sorry, what was the answer?
DEBBIE LLOYD: Correct.
DEBBIE LLOYD: COURT REPORTER: Sorry. Thank you.
MS. MEYERS: Do you recall why you stopped providing nursing services to Mr. Depp?
DEBBIE LLOYD: I do not.
MS. MEYERS: Did you continue to work for Dr. Kipper after you stopped providing nursing services to Mr. Depp?
DEBBIE LLOYD: Yes.
MS. MEYERS: Now, I think you testified earlier you don't recall the last time you saw Mr. Depp.
DEBBIE LLOYD: Not for sure, no.
MS. MEYERS: When's the last time that you remember seeing him?
DEBBIE LLOYD: I went to his - one of his Hollywood I Vampire shows out here in the desert.
MS. MEYERS: Were Mr. Depp and Ms. Heard still in a relationship when you saw Mr. Depp the last time?
DEBBIE LLOYD: No. Not that I was aware of.
MS. MEYERS: When was the last time you saw Ms. Heard?
DEBBIE LLOYD: I have no idea.
MS. MEYERS: When's the last time you remember seeing her?
DEBBIE LLOYD: I honestly don't know.
MS. MEYERS: During the time you were Mr. Depp's nurse, did you ever see Mr. Depp physically abuse Ms. Heard?
DEBBIE LLOYD: No.
MS. MEYERS: If you would have witnessed this, would I you have documented it in your nursing notes?
DEBBIE LLOYD: Yes.
MS. MEYERS: Did you ever see Mr. Depp throw Is anything at Ms. Heard?
DEBBIE LLOYD: I do not recall ever seeing him throw b anything.
MS. MEYERS: During the time you cared for Mr. Depp, did you ever see Ms. Heard physically abuse I Mr. Depp?
DEBBIE LLOYD: No.
MS. MEYERS: Did you ever see Ms. Heard throw anything at Mr. Depp?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: In the time that you cared for Mr. Depp, did he ever tell you that Ms. Heard was physically abusive towards him?
DEBBIE LLOYD: I don't recall any conversations like that.
MS. MEYERS: Were you ever concerned for Mr. Depp's safety around Ms. Heard?
DEBBIE LLOYD: No.
MS. MEYERS: Were you ever called over by Mr. Depp when he was in a fight with Ms. Heard?
DEBBIE LLOYD: I can't remember if it was when in a fight. I remember being called over after fights.
MS. MEYERS: And to the extent you know, why were you being called over?
DEBBIE LLOYD: My role with Johnny was medication or emotional support.
MS. MEYERS: How many times did you travel with Mr. Depp while he was under your care?
DEBBIE LLOYD: Multiple, but I wouldn't - I don't know a specific number.
MS. MEYERS: Did you ever witness Mr. Depp and Ms. Heard get in arguments while you were traveling?
DEBBIE LLOYD: Yes.
MS. MEYERS: And what would Mr. Depp do in those circumstances?
DEBBIE LLOYD: I don't remember specifics, other than the one time I mentioned on the airplane.
MS. MEYERS: Did Mr. Depp ever book a separate room to separate himself from Ms. Heard?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Have you ever witnessed Ms. Heard lose her temper?
DEBBIE LLOYD: I don't recall specifics.
MS. MEYERS: What do you recall, generally?
DEBBIE LLOYD: I can't recall.
MS. MEYERS: In the time you treated Mr. Depp, did you ever suspect he was under the influence of alcohol?
DEBBIE LLOYD: I don't recall specific times being of concern.
MS. MEYERS: Do you recall any specific instances when you were concerned he was under the influence of drugs that had not been prescribed by one of his physicians?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Did Mr. Depp ever tell you that someone had taken his prescription drugs?
DEBBIE LLOYD: I don't recall a conversation.
MS. MEYERS: Could we pull up Exhibit I, please.
MS. MEYERS: AV TECHNICIAN: Please stand by.
MS. MEYERS: And just for the record, this is a document bearing the Bates number DEPP 7804 through 7848. AV TECHNICIAN: exhibit 28.
MS. MEYERS: Ms. Lloyd, these are -- I'll represent that these are text messages between you and Mr. Depp. I think you've seen some of -- some portions of this document when you were answering Mr. Nadelhaft's questions. But I'd like to just direct your attention specifically to messages between you and Mr. Depp on May 27th, 2015, which appear on page 7841 and go through to 7843.
AV TECHNICIAN: Sorry, Counsel, was there an instruction?
MS. MEYERS: Yeah. I'm sorry. Can you please go to the page 7841, and we're going to be I scrolling through the pages after that. Go up two pages. Yeah.
MS. MEYERS: Do you see the text message that starts in row 320?
DEBBIE LLOYD: Yes.
MS. MEYERS: Okay. So I would like you to, please, !
MS. MEYERS: I read through the text messages in row 320 through 337, which are from May 27th, 2015. And before you begin, I just want to confirm this number under participants, next to your name.
MS. MEYERS: I That's your phone number?
DEBBIE LLOYD: Yeah. But I'm looking below, I was like, no. But above, yes.
MS. MEYERS: All right. So if you could read through the text messages reflected in rows 320 through 337 and then just let me know when you're done.
DEBBIE LLOYD: Okay. I'm done to 322. Okay. I'm done through 330.
MS. MEYERS: Are you done through 337? Its
DEBBIE LLOYD: Yeah. I've read everything.
MS. MEYERS: Okay. Do you recall this exchange with Mr. Depp?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you have an understanding of what you and Mr. Depp were discussing?
DEBBIE LLOYD: I mean, just from what the text messages says. I can see what he was saying.
MS. MEYERS: And what was Mr. Depp saying?
DEBBIE LLOYD: That his as-needed medications were missing.
MS. MEYERS: Anything else about how they came to be missing?
DEBBIE LLOYD: I really don't remember what the above text stated.
MS. MEYERS: Okay. Let's go to the text that's in row 33 please -- or 333, please. And it says here "Saw them. She wiped me out of everything. Need Adderall in the PRNs. I don't like to be out of stuff on the just-in-case kind of deal. I can't believe she's got the balls to flat out steal my meds for her fucking debaucheries. Hard game. After all, she is the sister. X. Me."
MS. MEYERS: Do you see that?
MR. NADELHAFT: Objection.
MS. MEYERS: Do you have any understanding as to what Mr. Depp was referring to there?
DEBBIE LLOYD: I do not.
MS. MEYERS: Do you know who he's referring to when he says "She is the sister"?
DEBBIE LLOYD: I do not.
MS. MEYERS: How did Ms. Heard treat you when you first started coming for Mr. Depp?
DEBBIE LLOYD: She was accepting.
MS. MEYERS: Did that ever change in the time you Ms. Heard's demeanor towards you changed, correct?
DEBBIE LLOYD: Yes. treated Mr. Depp?
DEBBIE LLOYD: I felt it did.
MS. MEYERS: You felt that, at some time, Okay. When do you recall her demeanor changing?
DEBBIE LLOYD: I don't recall specifically.
MS. MEYERS: How did her treatment of you change?
DEBBIE LLOYD: It wasn't so much her treatment of me, of me hearing that she didn't want me around from other members.
MS. MEYERS: Who did you hear that from?
DEBBIE LLOYD: I don't recall specifics. It was from other staff people that we worked with.
MS. MEYERS: Did you understand -- do you have any understanding as to why she didn't want you" "I around? 2
DEBBIE LLOYD: I do not.
MS. MEYERS: Was Ms. Heard unfriendly toward you?
DEBBIE LLOYD: No.
MS. MEYERS: Did Ms. Heard ever get angry at you in your presence?
DEBBIE LLOYD: Not that I recall.
MS. MEYERS: So, just to be clear. Your understanding that Ms. Heard's feelings towards you changed is based off of what you heard from other people, correct?
DEBBIE LLOYD: Yes.
MS. MEYERS: And your understanding was that you ! 14 said she didn't want you around, correct? Its
DEBBIE LLOYD: Yes.
MR. NADELHAFT: Mr. Depp is your patient, correct?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: And Amber Heard was not your patient; was that right?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: You talked about before, I believe, I that one of your roles for Mr. Depp was providing him emotional support. Did I recall that correctly?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: You didn't have that role for Amber Heard, correct?
DEBBIE LLOYD: Correct. Is Exhibit, I believe, Lloyd 22. There was a po reference to polysubstance abuse.
MR. NADELHAFT: Okay. One of the exhibits I saw was What is that?
DEBBIE LLOYD: Polysubstance abuse is used to determine the use of different drugs and/or alcohol.
MR. NADELHAFT: So it's abusing more than one drug or alcohol; is that right?
DEBBIE LLOYD: That's what the term means, yes.
MR. NADELHAFT: Okay. So, Ms. Lloyd, it would be the I : March 27, 2015 entries.
DEBBIE LLOYD: Okay.
MR. NADELHAFT: Can you see the entry for 1300?
DEBBIE LLOYD: Yes.
MR. NADELHAFT: You wrote "Patient was having a hard MD and RN go to the house to see patient. Upon time leaving the house, so security suggested the arrival at the house, patient was sitting in the car ready to leave. MD assessed patient's finger and will spend more time with the patient at the location he's being moved to."
MR. NADELHAFT: You wrote that?
DEBBIE LLOYD: I did.
MR. NADELHAFT: And you wrote that based off of information you were provided?
DEBBIE LLOYD: I don't recall what that first sentence is regarding.
MR. NADELHAFT: You don't have any reason to question the accuracy of the statement?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Okay. Even then, at 11:30, the bottom entry, you had testified a bit to that. After the highlighted portion, it says "MD offered patient Valium 10 milligrams IM to help with his anxiety and anger, but patient refused." You wrote that?
DEBBIE LLOYD: I did.
MR. NADELHAFT: Okay. And you have no reason to question the accuracy of that?
DEBBIE LLOYD: I do not.
MR. NADELHAFT: Okay. Was Mr. Depp expressing any -- do you recall Mr. Depp expressing any anger?
DEBBIE LLOYD: Only what I see I referred to earlier in that note, the portion that was highlighted.
MR. NADELHAFT: Okay. Then you -- then it's highlighting those -- going to the next page, "Patient was talking about wanting to drink alcohol but did not obtain any."
MR. NADELHAFT: You wrote that?
DEBBIE LLOYD: I did.
MR. NADELHAFT: And that was based off of what you saw with Mr. Depp?
DEBBIE LLOYD: According to this, yes.
MR. NADELHAFT: Okay. And there's no reason to question the accuracy of that note?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Okay. And then 3/8/15, 1:45, you write "Patient has been on phone with his security guard that is staying with his wife at their rented to LA tomorrow and rehashing night. Patient's house. Patient is discussing wanting to go home personal security guard came to stay with patient. RN will be next door and instructed security to call during the night if needed. You wrote that?
DEBBIE LLOYD: Correct.
MR. NADELHAFT: Do you know what you meant by "patient I O is discussing wanting to go home to LA tomorrow I and rehashing night"?
DEBBIE LLOYD: I do not recall what that's referring to.
MR. NADELHAFT: I believe you testified, way in the beginning, that you are -- you go to Dr. Kipper as a patient; is that right?
DEBBIE LLOYD: Correct. J 18
MR. NADELHAFT: Not going into details, but how long have you been his patient?
DEBBIE LLOYD: Since before I went to nursing - early 2000s.
MR. NADELHAFT: Okay. And do you consider Dr. Kipper to be a friend?
DEBBIE LLOYD: Yes.
MS. MEYERS: When you were with Mr. Depp in Australia, was he drinking at that time?
DEBBIE LLOYD: I don't recall him drinking.
MS. MEYERS: Do you recall that he was specifically I 1 O abstaining from drinking during that time?
DEBBIE LLOYD: I don't recall.
MS. MEYERS: Did you ever see Ms. Heard drink in front of Mr. Depp while he was abstaining from alcohol?
DEBBIE LLOYD: Yes.
MS. MEYERS: Did you ever -- did he ever ask her not to do that, to your knowledge?
DEBBIE LLOYD: Not to my knowledge.