Sean Bett — Cross/Redirect

MS. BREDEHOFT: No, Your Honor.

MR. ROTTENBORN: Thank you, Your Honor.

MR. ROTTENBORN: Good morning, Mr. Bett.

MR. ROTTENBORN: You're a full-time employee of I Mr. Depp, correct?

MR. ROTTENBORN: You've been working with Mr. Depp for about 15 years?

MR. ROTTENBORN: And you make a salary from Mr. Depp, right?

MR. ROTTENBORN: And in your role, one of your top priorities is to make sure Mr. Depp is safe and that if he's out, he gets home safely, correct?

MR. ROTTENBORN: And Mr. Depp's safety is a priority over others that may be out with Mr. Depp, correct?

MR. ROTTENBORN: But Mr. Depp's safety is the top priority, correct?

MR. ROTTENBORN: That just goes without saying, right, in your role as his chief of security, right?

MR. ROTTENBORN: And your job as security is to remain discreetly in the background, right?

MR. ROTTENBORN: You are not part of Mr. Depp's family, right?

MR. ROTTENBORN: You're not with him 24/7, right?

MR. ROTTENBORN: And you weren't with him 24/7 when he was in a relationship with Ms. Heard, correct?

MR. ROTTENBORN: And you obviously have no personal knowledge of what happens when you're not around, correct?

MR. ROTTENBORN: And you have no personal knowledge of what happens behind closed doors with Mr. Depp, correct?

MR. ROTTENBORN: When Mr. Depp was in a relationship with Ms. Heard, you weren't traveling out of Los Angeles as part of Mr. Depp's security, correct?

MR. ROTTENBORN: What occasion was that?

MR. ROTTENBORN: But other than that, you didn't travel outside of LA as part of your security when he was with Ms. Heard, correct?

MR. ROTTENBORN: So you weren't in Australia in March of 2015, right?

MR. ROTTENBORN: You weren't on a plane flight from Boston to Los Angeles in May of 2014, correct?

MR. ROTTENBORN: You didn't go to the Bahamas with him, I correct?

MR. ROTTENBORN: You didn't go to Tokyo with him and Ms. Heard, correct?

MR. ROTTENBORN: You're around him almost every day when he's in Los Angeles, right?

MR. ROTTENBORN: Picking up food for him?

MR. ROTTENBORN: Pick up medicine for him?

MR. ROTTENBORN: Help coordinate visitors to his house?

MR. ROTTENBORN: Or his houses.

MR. ROTTENBORN: Pick up groceries for him?

MR. ROTTENBORN: And you Jet him into places like his residences, right?

MR. ROTTENBORN: Because he doesn't carry keys for them, right?

MR. ROTTENBORN: You drive him places --

MR. ROTTENBORN: Correct? Almost every time he leaves his property, he's being driven rather than driving, correct?

MR. ROTTENBORN: And you help arrange that, right?

MR. ROTTENBORN: Your responsibility, one of them is to help get him where he needs to go, right?

MR. ROTTENBORN: You've woken him up in the mornings before?

MR. ROTTENBORN: And yesterday I believe you testified that sometimes Mr. Depp would have just a glass of wine or two, right?

MR. ROTTENBORN: And you testified that his demeanor when he was slightly intoxicated was the same as if he had had a glass of sparkling water.

MR. ROTTENBORN: Do you remember giving that testimony?

MR. ROTTENBORN: The fact is you've seen him much more impaired than that, right?

MR. ROTTENBORN: You've seen him impaired enough that you've had to help put him to bed before, right?

MR. ROTTENBORN: Well, there have been times when Mr. Depp was so impaired that you had to get up the stairs and open the bedroom doors for him, right?

MR. ROTTENBORN: Right. So you've gotten him into bed -- you've gotten him some water, you've asked him if he needs anything, right?

MR. ROTTENBORN: At times when he's been impaired, correct?

MR. ROTTENBORN: And you've stayed with him during difficult times when he's been impaired, there's times when you've stayed with him until he lays down and you tell him, "Good night," and you'll see him the next day, right?

MR. ROTTENBORN: Yesterday -- you've actually prevented people from calling the police when Mr. Depp's behavior after drinking was bothering them, haven't you?

MR. ROTTENBORN: Uh-huh.

MR. ROTTENBORN: Yeah. And in that occasion, Mr. Depp and some other people had had a couple perfect bottles of wine and pounded an entire bottle of tequila, right?

MR. ROTTENBORN: Mr. Depp told you that they had had a couple bottles of perfect wine and pounded an entire bottle of tequila, right?

MR. ROTTENBORN: Heather, can you pull up Exhibit 892, please.

MR. ROTTENBORN: Mr. Bert, is this a text exchange that Is you had with Mr. Depp on September 1st, 2017, 2:34 to 2:36 in the afternoon?

MR. ROTTENBORN: Sure. Take your time.

MR. ROTTENBORN: Sure, sure. My question was just is this a text exchange that you and Mr. Depp had on September 1st, 2017, from 2:34 to 2:36 in the afternoon?

MR. ROTTENBORN: The relevance is that Mr. Bett testified yesterday that he'd seen Mr. Depp have a glass or two of wine, and this is direct evidence to contradict that.

MR. ROTTENBORN: Thank you, Your Honor.

MR. ROTTENBORN: And at 2:34 p.m., Mr. Depp texts you, "Steaks were excellent and pondering, though we will likely have dinner here. Steaks were excellent. A couple of bottles of perfect wine. We then pounded an entire bottle of tequila!!! Then the savagery commenced!! Good morning!!!"

MR. ROTTENBORN: Did I read that right?

MR. ROTTENBORN: Then you told Mr. Depp that you prevented them from calling police.

MR. ROTTENBORN: That's for the context of the text when he testified that he prevented him.

MR. ROTTENBORN: Thank you, Your Honor.

MR. ROTTENBORN: So then, Mr. Bett, you texted Mr. Depp back two minutes later, and you said, "I prevented them from calling po-po. Glad you had fun. You mean dinner in room or restaurant?"

MR. ROTTENBORN: Do you see that?

MR. ROTTENBORN: And you sent that text to Mr. Depp, correct?

MR. ROTTENBORN: By "po-po," you mean police, correct?

MR. ROTTENBORN: You told them that you were glad he had fun, right?

MR. ROTTENBORN: Your Honor, permission b to move for admission of Exhibit 892 and permission to publish.

MR. ROTTENBORN: Well, it's Mr. Depp's statements about what he did when he pounded an entire bottle of tequila and the savagery that commenced. Therefore, it is his use of alcohol that's --

MR. ROTTENBORN: Uh-huh.

MR. ROTTENBORN: You're aware that Mr. Depp has used l drugs, right?

MR. ROTTENBORN: And you've helped facilitate Mr. Depp's drug use on occasion, correct?

MR. ROTTENBORN: I'm sorry. I IS

MR. ROTTENBORN: You have not?

MR. ROTTENBORN: Heather, can you pull up Exhibit 967, please.

MR. ROTTENBORN: Mr. Bett, feel free to take the time that you need to to review this document, familiarize yourself with it. But my first question for you is just is this a text exchange that you had with Mr. Depp on June 12th, 2019?

MR. ROTTENBORN: Right. And it starts at the bottom and goes up, correct?

MR. ROTTENBORN: That's okay.

MR. ROTTENBORN: Hard to orient yourself with these sometimes.

MR. ROTTENBORN: And then the more recent texts are as you go up the page, right?

MR. ROTTENBORN: So in the bottom text, you're telling Mr. Depp that some people are at his house visiting and you say, "They'll be at the pool" --

MR. ROTTENBORN: He just testified that he hadn't helped facilitate Mr. Depp's drug use, so this is for impeachment, and you've got to read the text in context to see how it impeaches him.

MR. ROTTENBORN: Sure.

MR. ROTTENBORN: Yes, Your Honor.

MR. ROTTENBORN: So "There's some visitors to the house," if you start at the bottom and read up, and Mr. Depp makes clear he doesn't want them to go down and see them, and he says, "the 'not-drugs' are down there" on, I think it's Entry 73. And then right above that, he says -- so the visitors are coming. He says -- on 74, he says something about "can't go downstairs until they split." And then he says "the 'not-drugs' is down there. What's a boy to do?" And he says, "Trying to help Daddy."

MR. ROTTENBORN: The impeachment is he i ! 1 says he hasn't helped facilitate Mr. Depp's drug /2 use. Mr. Depp is saying the "not-drugs" -- he doesn't want to go downstairs because the "not-drugs" is down there, meaning -- Is

MR. ROTTENBORN: I don't know what it means either, but it's --

MR. ROTTENBORN: Well, I'm going to ask him, "Well he says he doesn't want to go downstairs because 'the not-drugs,' meaning, like, the drugs are upstairs. I don't want to go downstairs."

MR. ROTTENBORN: Do you know what I'm saying?

MR. ROTTENBORN: Okay. All right.

MR. ROTTENBORN: BY MR. ROTTENBORN:

MR. ROTTENBORN: Mr. Bett, you communicate with Mr. Depp through texts, correct?

MR. ROTTENBORN: That's your primary way of communicating with him?

MR. ROTTENBORN: Sure. But in terms of written communications, texting is the way that you guys primarily communicate, right?

MR. ROTTENBORN: And that's the same thing that you -- the same way that you communicate primarily with his other employees or with his family as well, right?

MR. ROTTENBORN: You have a practice of deleting all your texts with him at the end of the day or week, correct?

MR. ROTTENBORN: So there wouldn't be texts from his time when he was in a relationship with Amber Heard that you have possession of, correct?

MR. ROTTENBORN: You've never seen Amber do something that you would call physically violent or an assault of Mr. Depp, correct?

MR. ROTTENBORN: But you wouldn't consider that physically violent or an assault of him, correct?

MR. ROTTENBORN: May I approach, Your Honor?

MR. ROTTENBORN: I'm just handing.

MR. ROTTENBORN: I'm sorry.

MR. ROTTENBORN: Mr. Bett, do you remember giving a deposition in this case?

MR. ROTTENBORN: And you were under oath for that IO deposition, correct?

MR. ROTTENBORN: And I asked you a number of questions, right?

MR. ROTTENBORN: I did. And if you can turn to page 111 of this transcript, please.

MR. ROTTENBORN: It's on page 28 of the document.

MR. ROTTENBORN: If you look at line 22, the last line, and then heading over to page 112, do you see that?

MR. ROTTENBORN: And in your deposition, I asked you b this question, and you gave this answer: "QUESTION: So is it fair to say that while you've seen Ms. Heard yell and get emotional toward Johnny, you've never seen her do something that you would call physically violent or assault of Johnny?

MR. ROTTENBORN: "ANSWER: correct." Did I read that right?

MR. ROTTENBORN: I'd like to turn to May 21st, 2016. That was the incident that we talked about last night, right before you -- we adjourned for the day, correct?

MR. ROTTENBORN: You and Mr. Judge, Jerry Judge, brought Mr. Depp over to the penthouses at the Eastern Columbia Building that night, right?

MR. ROTTENBORN: And you knew that he was going there to speak with Amber, correct?

MR. ROTTENBORN: Your understanding was that Mr. Depp was going over there because they both wanted to talk and calm everything down, right?s

MR. ROTTENBORN: Mr. Depp told you that he and Amber I were going to talk it out and talk about what's I going on, correct?

MR. ROTTENBORN: And he had wine in the car on the way over, I believe you testified yesterday, right?

MR. ROTTENBORN: And I think you testified it's possible he had been drinking during the day before you brought him over there, correct?

MR. ROTTENBORN: And when you no I'm sorry during the day before you picked him up to go over to the Eastern Columbia Building it's possible he had been drinking collect?

MR. ROTTENBORN: Okay. And when you arrived at the Eastern Columbia Building, you can't say one way or the other whether Mr. Depp was carrying wine O with him into the building, right?

MR. ROTTENBORN: You and Mr. Judge let him into penthouse 3 and were in there for just a minute or two before you exited penthouse 3, correct?

MR. ROTTENBORN: And then you stayed outside in the hallway of penthouse 3 for a bit, right?

MR. ROTTENBORN: I think you testified yesterday like ten minutes; is that right?

MR. ROTTENBORN: And then you, from there, you went from the hallway outside of penthouse 3 to penthouse 5, the storage area where you had a couch and a TV and that sort of thing that you testified about, right?

MR. ROTTENBORN: Ls that also known as the "guard shack"?

MR. ROTTENBORN: Sometimes called the "cubbyhole"; is that right?

MR. ROTTENBORN: Okay. Just to orient us.

MR. ROTTENBORN: Heather, can you please pull up Plaintiffs Exhibit 116.

MR. ROTTENBORN: And, Your Honor, I believe this has already been entered into evidence.

MR. ROTTENBORN: Can you rotate that, please. Counterclockwise. And then maybe just li, blow it up, please. And, Your Honor, permission to publish if it is not ah-early.

MR. ROTTENBORN: Thank you. Oh, thank you.

MR. ROTTENBORN: So, Mr. Bett, if you -- just to orient us, am I correct in saying that the -- well, could you put your finger just on the guard shack area of penthouse 5, please?

MR. ROTTENBORN: Yeah. I think the screen will make a ! 19 mark if you show on it.

MR. ROTTENBORN: Okay.

MR. ROTTENBORN: Okay.

MR. ROTTENBORN: It is.

MR. ROTTENBORN: Yeah, yeah, that's showing up.

MR. ROTTENBORN: So that's down the hall from outside of penthouse 3, right?

MR. ROTTENBORN: And you stayed in that guard shack for, I believe you said, five to ten minutes; is that right?

MR. ROTTENBORN: So if you spent about ten minutes outside penthouse 3 and then five to ten minutes inside the guard shack, you say you were at the building for, what, a total of 30 minutes or so?

MR. ROTTENBORN: But you're fairly confident it was 40 minutes to an hour?

MR. ROTTENBORN: And you said that you arrived at the building sometime between 7:15 and 7:45; is that what you said yesterday?

MR. ROTTENBORN: What's your best guess?

MR. ROTTENBORN: Okay. More towards eightish? All right. And so you stayed in the guard shack for five to ten minutes, and then you left the guard shack and headed back up the hall toward the door of penthouse 3, right?

MR. ROTTENBORN: And at some point, you heard Amber shouting, and you let yourself into penthouse 3, 2_2_n_ g_h_t?

MR. ROTTENBORN: The closest you got to Amber when you went into penthouse 3 was 15 to 20 feet, right?

MR. ROTTENBORN: And you were in penthouse 3 for just about 30 seconds to a minute before you left again with Mr. Depp, right?

MR. ROTTENBORN: You don't remember what Ms. Heard was O wearing, do you?

MR. ROTTENBORN: And you can't remember if she was crying when you saw her, right?

MR. ROTTENBORN: You can't remember if she was crying, right?

MR. ROTTENBORN: I just said I didn't see her crying.

MR. ROTTENBORN: She could have been crying, right?

MR. ROTTENBORN: It's a different question.

MR. ROTTENBORN: And you can't remember if she had any makeup on or not, right?

MR. ROTTENBORN: You just can't remember if she did, right?

MR. ROTTENBORN: Turn to page 160, please, in your I deposition.

MR. ROTTENBORN: Page 40, yeah. Yes, sir.

MR. ROTTENBORN: And on line 1, I asked you the question, "Did Ms. Heard have any -- you couldn't tell if she was wearing any makeup, right?" Your answer was "I can't remember if she had any makeup on or not." Did I read that right?

MR. ROTTENBORN: And you don't know what -- you have no personal knowledge of what transpired in penthouse 3 while you were outside of it that evening, correct?

MR. ROTTENBORN: And you have no personal knowledge of whether Amber had a phone thrown at her face by Johnny Depp that evening, correct?

MR. ROTTENBORN: Because you weren't there, right?

MR. ROTTENBORN: So you left penthouse 3, and then you I went into penthouse 5 at Mr. Depp's insistence that he get into penthouse 5, right?

MR. ROTTENBORN: And he was agitated at this time, l I right?

MR. ROTTENBORN: I'm sorry. You left penthouse 3 after 30 to 60 seconds with Mr. Depp and Mr. Judge, and you went to penthouse 5, right?

MR. ROTTENBORN: And that's because Mr. Depp was demanding to get into penthouse 5, right?

MR. ROTTENBORN: And Mr. Depp was agitated at this time, right?

MR. ROTTENBORN: And one of the reasons that you could tell that he was agitated was because this wasn't the first time you had seen him agitated, right?

MR. ROTTENBORN: Mr. Depp told you to let him into penthouse 5 and you did that, right?

MR. ROTTENBORN: And when he left penthouse 3 to go to penthouse 5, you can't remember if he had wine in his hand or not, correct?

MR. ROTTENBORN: I'm sorry?

MR. ROTTENBORN: Cannot?

MR. ROTTENBORN: And when you walked into penthouse 5 inside were Rocky Pennington; her fiance, Josh Drew; and another woman and a dog, right?

MR. ROTTENBORN: Mr. Depp told them to get out of his penthouse, right?

MR. ROTTENBORN: And they exited, right?

MR. ROTTENBORN: And you can't remember one way or the O other whether Mr. Depp knocked anything off the table in any of the penthouses, right?

MR. ROTTENBORN: Did you or Mr. Judge, just to be clear, did you or Mr. Judge destroy any property or knock anything off tables in any of the penthouses that evening?

MR. ROTTENBORN: You have no personal knowledge of whether or not Mr. Depp was violent to Ms. Heard at times when you weren't around them, correct?

MR. ROTTENBORN: And Ms. Heard may have suffered injuries at the hands of Mr. Depp over the years that you didn't witness or you didn't see, correct?

MR. ROTTENBORN: I'd like to end by just taking a look at the videos of you entering and exiting the Is building, I believe.

MR. ROTTENBORN: Heather, could you pull up Exhibit 672.

MR. ROTTENBORN: Your Honor, I believe that these were part of Mr. Patterson's deposition and that they've been admitted.

MR. ROTTENBORN: And the next one will ! be 666, just to confirm.

MR. ROTTENBORN: Thank you, Your Honor. Heather, could you play this starting at 1. Actually, before we start --

MR. ROTTENBORN: Do you see this on your screen, Mr. Bett?

MR. ROTTENBORN: And you see the time stamp at the bottom? That shows what time the camera -- the video was taken, correct?

MR. ROTTENBORN: Okay.

MR. ROTTENBORN: Let's go ahead and ! 12 play this, Heather. Start at 1 :55.

MR. ROTTENBORN: That's you in that black-and-white shirt, right?

MR. ROTTENBORN: That's Mr. Depp in the hat?

MR. ROTTENBORN: And that's Mr. Judge to his left?io

MR. ROTTENBORN: And this video is when you're entering the Eastern Columbia Building to take him to 'penthouse 3, correct?'

MR. ROTTENBORN: So it's actually a good bit earlier than you testified to, right, it's at 7:02, if I'm converting military time to --

MR. ROTTENBORN: 7:02 p.m., right?

MR. ROTTENBORN: On May 21st, 2016?

MR. ROTTENBORN: Heather, you can take that down. And please pull up Exhibit 666.

MR. ROTTENBORN: And you see that the time stamp on this video is -- well, let's go ahead and play the video first.

MR. ROTTENBORN: And that's you on the right again, right?

MR. ROTTENBORN: And that's Mr. Judge in the middle, right?

MR. ROTTENBORN: And that's Mr. Depp on the left, correct?

MR. ROTTENBORN: And the time stamp on this video is 20:29, or 8:29 p.m, right?

MR. ROTTENBORN: So you were actually in the Eastern Columbia Building for about an hour and a half that evening, right?

MR. ROTTENBORN: I have nothing further, thank you

MR. ROTTENBORN: Objection just to Ms. Vasquez testifying.

MR. ROTTENBORN: Objection. Foundation. And leading.

MR. ROTTENBORN: No, Your Honor.