Shannon Curry — Direct/Cross/Redirect

DR. CURRY: Good morning.

DR. CURRY: Shannon Curry.

DR. CURRY: I am a clinical and forensic psychologist.

DR. CURRY: I received - well, I started college at Georgetown University. I then transferred to I I the University of California Irvine, where I received my bachelor's degree in psychology and social behavior. I completed my master's degree in psychology at the - at Pepperdine University.

DR. CURRY: IS I I went on to complete my doctoral degree in clinical psychology at Pepperdine University, which included several training rotations at different practicum sites; those are essentially clinical rotations we do to learn various types of psychology. You learn how to do psychological assessment, counseling, et cetera, and you do that in a variety of different settings. And then I completed a year-long doctoral internship at an American Psychological Association-accredited doctoral internship. You do this a year before you get your degree.

DR. CURRY: And that was at Tripler Army Medical Center. It's traditionally a military internship. They did admit two civilians; I was lucky enough to be one of them. I then completed two years of postdoctoral training at Hawaii State Hospital, a locked forensic psychology facility, and that's where you essentially have individuals with severe mental illness who have committed crimes.

DR. CURRY: I have. So after I completed my doctorate and my postdoctoral training, I obtained a -- it's called a postdoctoral master of science degree in clinical psychopharmacology. That is for partial fulfillment of prescription privileges, meaning that it's part of what we need to be able to prescribe medication as psychologists because psychologists don't traditionally prescribe, and we can do that with certain military jurisdictions in other states.

DR. CURRY: I also obtained advanced training in the Gottman method of couples therapy. I completed all three levels of training, and then I'm also a Gottman educator for several workshops involving helping,parents learn how to prepare to bring their baby home and helping couples without serious problems improve their relationships.

DR. CURRY: The Gottman method is a highly research-based method of couple's therapy. It's very structured, so different than what many people expect when they think about couples therapy. I always tell me clients I don't want them to come in, just tell each other all their problems, and then have an awkward, silent drive home. In this therapy, they come in, they complete a really structured assessment in the beginning, so they complete a bunch of questions.

DR. CURRY: It gives me a ton of information about their relationship before we even get started and really identifies the areas we're going to target with structured interventions during each session. I think of it almost like a class.

DR. CURRY: Any what?

DR. CURRY: I did So my internship specifically was dedicated to essentially working with I post-traumatic stress disorder, traumatic stress lot of my training has been with psychological assessment and testing, and then my training during practicum and then in my postdoctoral work was dedicated to working with trauma populations and also conducting forensic psychological assessments.

DR. CURRY: Oftentimes -- forensic psychological assessments actually refers to doing testing and an interview and a couple other things for purposes related to law. So it's the application of psychology to the courts, to legal issues. And sometimes that also involves doing assessments for the military to determine whether somebody has sustained a mental disability after combat.

DR. CURRY: So Tripler Army Medical Center is a I hospital in Honolulu, Hawaii, if anybody's ever gotten to have a vacation in Hawaii, it's in a giant pink building there And it's one of the g p g top training sites for military psychologists I was very, very lucky to be able to train there They have wonderful funding and a lot of new research going on, particularly for PTSD, but really for all areas of mental health.

DR. CURRY: While I was there, I did rotations in family psychology, so doing family therapy, I worked with children. But I also did a neuropsychology rotation learning really the ins and outs of advanced psychological assessment, identifying not just mental issues, mental - sort of mental illness, but also traumatic brain injuries after trauma and doing those PTSD evaluations and then also working with service members who were struggling with a whole host of issues, military stressors, normal life stressors, and then also those who sustained tremendous trauma from combat

DR. CURRY: I do Actually our practice - my practice is very focused on military service members, veterans, and their families

DR. CURRY: Well, most of my litigation -- if we're talking about civil work, that has mostly been reports, so this is my first time testifying in a civil matter. The majority of my forensic work has been in criminal law or providing O :::::,:,::: ::.::;, :;;,::t'" reviewed by a judge, and a determination is made or usually there's a settlement beforehand.

DR. CURRY: I do. So I'm actually not sure if I'm on the list anymore in Honolulu, but I'm a certified forensic evaluator for the State of Hawaii, which means that I have been appointed by the Court to conduct evaluations for matters that are presented, and then I'm also on the list of forensic evaluators in several courts in Southern California. And then I'm also -- I am contracted by the military, Department of Defense, now again for evaluations of PTSD of service members.

DR. CURRY: Yes.

DR. CURRY: So PTSD is a mental illness. It can develop after a person has been exposed to a traumatic event, and our Diagnostic Statistical Manual, the DSM, is sort of the authoritative manual of mental illnesses. It's considered our bible of mental illness. We go there for diagnoses.

DR. CURRY: And according to that, there's a specific type of trauma that a person must experience for them to be able to qualify for a diagnosis of PTSD. And that's an event that is life-threatening. It can also involve sexual assault, and you can experience that either directly, but you can also be traumatized if you've seen it happen to somebody else or if it's happened unexpectedly or violently to somebody close to you, a family member or a friend. And then there's also a provision for people who are first responders. If they're encountering really traumatic information regularly, that qualifies as a trauma. Now, there are a number of symptoms that can develop.

DR. CURRY: Okay.

DR. CURRY: Well, I am a licensed psychologist.

DR. CURRY: In California and Hawaii.

DR. CURRY: Not that I can think of off the top of my head other than the training with the Gottman method of couples therapy.

DR. CURRY: Yes, I have.

DR. CURRY: Well, I am -- so that, I guess, would be a credential. So I am a certified forensic evaluator for the State of Hawaii.

DR. CURRY: There was. So would you like me to tell you about it?

DR. CURRY: Okay. So I conducted a research study while I was at Pepperdine completing my doctorate. It's called a dissertation, so when you're obtaining your doctorate, you contribute something to the scientific field that you're in. And typically that involves doing what we call "novel science," so you're doing an experiment. You're finding out new information and helping the field progress.

DR. CURRY: So I did research in Peru, and I was essentially looking at the effectiveness of the therapy intervention there for kids who were growing up in this community called Ayacucho which was exposed to years of guerrilla warfare, the longest guerrilla war in the history of the world. And there were a lot of issues in that community, tremendous trauma, and my research was around finding interventions that were really effective for that community.

DR. CURRY: I work for the Curry Psychology Group.

DR. CURRY: We're a multispecialty mental health center, so we have neuropsychologists who do testing of kids. We have therapists, individual therapist, couples therapists, family therapists. We even have a meditation teacher. We basically try to meet the needs of our community, and we highly specialize in working with military personnel and their families.

DR. CURRY: I'm Dr. Curry.

DR. CURRY: As of right now, I believe it's 13.

DR. CURRY: For about 15 years.

DR. CURRY: I would say about half of it is individuals, half is couples.

DR. CURRY: I do.

DR. CURRY: So we have several unlicensed professionals at our office, and they're earning their additional hours so that they can get licensed. So they're able to see clients, and I meet with them regularly to supervise them; discuss their cases; provide them with information about different diagnoses, interventions, and treatment methods.

DR. CURRY: I was contacted by Ms. Camille Vasquez, one of the attorneys for Mr. Depp.

DR. CURRY: Ms. Vasquez called me and indicated I 8 that she might be interested in having me meet the legal team so that I could discuss my expertise and possibly provide my opinions related to the IO matter.

DR. CURRY: So initially, my role that I understood at the time was to review the case materials and provide my opinions regarding anything that I noticed that was consistent or even inconsistent with the psychological science that exists today on intimate partner violence in Mr. Depp's and Ms. Heard's relationship.

DR. CURRY: So there are a multitude of different definitions depending on the source or the state. But essentially intimate partner violence is abuse. It can be physical, psychological, and it's from one partner to another in an intimate relationship.

DR. CURRY: Yes. It shifted. So I was retained at the end of January 2021 and then had just barely .1 O begun to review the documents. The case was postponed, and then in October 2021, I was asked by counsel to provide a psychological evaluation of Ms. Heard.

DR. CURRY: No.

DR. CURRY: So I reviewed quite a few documents as part of my evaluation. That included all of the case documents: Ms. Heard's medical records by Dr. Kipper, her prior mental health treatment records, I believe I reviewed records from Dr. Amy Banks, Dr. Bonnie Jacobs, Dr. Connell Cowan. And also a significant portion of my review involved notes from nurse Erin Falati, at the time Erin Boerum, who spent a significant time with Ms. Heard in her direct company.

DR. CURRY: I also viewed exhibits, quite a few audio recordings, a video recording - several video recordings or possibly photographs; I might be getting them confused - and multiple witness statements, testimony, and declarations.

DR. CURRY: Yes, I did So in conducting my evaluation, I met with Ms. Heard on two separate dates: December 10th and December 17th, 2021.

DR. CURRY: So the evaluation - we spent 12 hours directly with one another; however, there were more - there were more hours involved in the evaluation with some breaks. So we spent seven hours together on the first day, December 10th. Not necessarily together because there was a one-hour lunch break and about a half hour with breaks split up through the day. And then on the 17th, we spent a little more than eight hours in the evaluation from start to finish with a one-hour break and another half hour of breaks distributed throughout the day.

DR. CURRY: I did.

DR. CURRY: The results of Ms. Heard's evaluation supported two diagnoses: Borderline personality disorder and histrionic personality disorder.

DR. CURRY: Diagnosis is a way that we essentially - that psychologists, psychiatrists, anybody in the mental health field thinks about a disorder. It helps us to communicate a set of symptoms that a person's experiencing, and along with that set of symptoms, it tells other professionals a lot about how those symptoms might have developed, how that person might behave, perceive the world. It also drives treatment. The real purpose is to determine what sort of interventions will be most effective for the person.

DR. CURRY: Yes.

DR. CURRY: So the DSM-5, that stands for the Diagnostic Statistical Manual, Version 5, and that contains every diagnosis we use in mental health, and we -- it's the authoritative manual of mental diagnoses.

DR. CURRY: Yes.

DR. CURRY: To understand a personality disorder, I think it could be helpful for us to kind of define personality. So personality, something we take for granted but these are the traits, the characteristics, the way we think, we feel, and we act, that make us who we are. And these traits are pretty stable over time and across situations. We might, you know, be sure to mind our Ps and Qs when we're meeting somebody new, but overall if somebody were to describe, or if we were to describe ourself, we have a pretty good sense of who we are. Sometimes an easy way to think of it is imagining how you might describe a brother or sister or a child if you have children; their personalities are pretty clear to you.

DR. CURRY: Personality disorder is some sort of dysfunction in those enduring traits, so as opposed to other types of mental illness, when you think about something like depression, that's episodic. It comes and it goes, and when it's treated with medication it can pretty much be completely mitigated or minimized in a person's life, and their personality is still there, separate from the depression.

DR. CURRY: When we have a personality disorder, there are going to be disturbances in several different areas that are visible in almost all different facets of their life.

DR. CURRY: Yes. So they can be diagnosed in a treating environment, a treating psychologist or a therapist or a psychiatrist simply does a diagnostic interview which involves assessing multiple areas of a person's history back down through childhood.

DR. CURRY: Yes.

DR. CURRY: Sometimes I'll slip into these words. I apologize. So a treating environment, in therapy, if somebody is going in for treatment, the mental health provider will ask them questions to find out what sort of symptoms they've experienced and what sort of things have occurred in their life that might be consistent with these disorders or rule out those disorders, prove that there's no reason for these disorders to be considered. They might also pay attention to their observations of the client over time and new information the client provides them.

DR. CURRY: The most reliable way, however, to ever come about a diagnosis really is through a comprehensive psychological assessment. And I might use the words "assessment," "examination,"

DR. CURRY: P , differently.

DR. CURRY: You integrate that with the same interview I was telling you that people would do for therapy. We do that as well. And then in a courtroom setting, you're going to look at all the legal records, all of those documents, corroborating information, to sort of check your hypotheses that may be developing and also check against the examinee's statements to confirm O whether you have enough evidence on of a certain diagnosis.

DR. CURRY: Clinical interview is a very comprehensive interview. It includes a person's entire life history as well as very specifically looks at any symptoms they might have. This can start as far back as birth. You might find out if there were any issues with their delivery, any genetic issues, any intellectual issues. How did they do - what was their home life like? How was discipline handled? What's their relationship with their primary caregivers? Were they raised by an aunt, an uncle, their parents? How many siblings do they have? How do they get along with their siblings? How many times did they have to move? Was there any abuse? Did they have any really significant life experiences that come to mind when they think about their childhood? How were they as a student? Did they need special services? Did they get in trouble in school?

DR. CURRY: And you do this. You continue on to high school. Were there hobbies? Did they play sports? How many friends did they have? Did they have any trouble keeping those friendships? Then you get into adulthood. Did they go to college? Did they not go to college? How come? What sorts of jobs have they held? How did those jobs go? How did they end? That's an important question. What sort of romantic relationships have they been involved in? How do they identify sexually? culturally? Let's see. What else? What sort of symptoms have they experienced?

DR. CURRY: You go through the entire gamut of some of the main symptoms. You might screen for depression, any disorganized thinking, that means thinking that isn't necessarily in touch with reality, and any current

DR. CURRY: So there was information that supported it from multiple sources. I conducted testing including - one of the main tests that I used, she obtained scores that were consistent with those diagnoses, and then I also - there was evidence of those diagnoses in her records and in her self-report.

DR. CURRY: So the self-report would be things that Ms. Heard indicated to me specifically. So there were a couple of characteristics that she noted in her self-report that were consistent with these personality disorders. The first was actually my own behavioral observations of her based on her self-report. So one of the hallmark characteristics of histrionic borderline - sorry - histrionic personality disorder is sort of a overly dramatic presentation. It's called this impressionistic speech, so it tends to be very flowery. It uses a lot of descriptive words like "magical," "wonderful," and it can go on for quite some time. And yet it really lacks any substance. So at the end you're left wondering what was just said or what the answer is to the actual question.

DR. CURRY: So that occurred a number of times, and it also represented the quick shifts you'll see between emotions. So she would suddenly be one way, and then she would become very animated or very sad, and when people are displaying these emotions with this personality disorder, there's a sense of shallowness to it. People who are observing them will feel like it's always playacting, and they might not be able to put their finger on it, but part of it is because of the rapidness with which the person can switch emotions and also the lack of substance. They don't really refer to "I feel this way." They might describe emotions. They might describe events, but very rarely, and Ms. Heard did not say, "I feel vulnerable." She never really indicated a vulnerable feeling of her own.

DR. CURRY: Then the substance of her self-report, so when I was asking her information about her history --

DR. CURRY: Oh, okay.

DR. CURRY: Okay. So psychological tests, I -- I'll just go in order. So first of all, I asked her a couple questions from something called the Mini-Mental Status Exam [sic]. That's really just a fancy way of saying that I wanted to make sure that she was alert and oriented to we call it person, place, and time. That means she knew who she was. She knew who I was. She knew where we were, and she knew the date. That way I can ensure that she's able to participate in the evaluation and understand what's happening.

DR. CURRY: I then administered something called the Minnesota Multiphasic Personality Inventory-2. The 2 means that it's the second edition. And this is something we call an objective measure. So it asks 567 questions, or statements, and the person either agrees or disagrees with them how much this statement represents them. And this test has been around since 1943. There are more than 10,000 studies showing that it is appropriate for determining somebody's personality traits.

DR. CURRY: It measures all of those things I sort of mentioned: How a person thinks, feels, and behaves in multiple different aspects of their lives. It also measures very accurately any signs of mental illness or dysfunction.

DR. CURRY: And the reason I also really like this test, whenever you're using a test for an evaluation that's going to be used in a forensic setting, people have a lot of incentive to present themselves in a way that's going to benefit their case. And they may want to look like they're sicker than they really are. They may want to look much healthier than they really are, and some of those incentives, they may not even realize that they're intending to do that. So it can be conscious or unconscious, but you really need to have a test that can check for that.

DR. CURRY: And the MMPI-2 has a set of validity scales, we call them These are scales that measure, really, the truthfulness and accuracy with which a person is approaching the test. And these scales on this particular test have been so well researched over many decades that they've been nuanced, and they can tell us a lot about if somebody's, for instance, exaggerating. Are they elevating one of the scales that shows that they're exaggerating on purpose? Are they exaggerating in a manner that's more like a cry for help?

DR. CURRY: Are they exaggerating in a manner that's clever and sophisticated or more obvious? And then the same exact thing goes for trying to minimize symptoms. We have a number of scales that can show us all the different - if somebody's trying to say they're the most wonderful person on Earth or trying to deny problems and if they're doing that, again, in a very clever way or more of an obvious way.

DR. CURRY: So that test was my choice for this case. There's one other reason I'd like to add is that part of my evaluation was - one of the reasons was to assess whether Ms. Heard has post-traumatic stress disorder, which I told you about earlier, as a result of the incidents that these allegedly occurred by Mr. Depp. And that's a really tough disorder to find out if somebody's faking it or not. It's one of the most easily faked disorders.

DR. CURRY: Most of us know what it feels like to feel anxious, and a lot of people have seen war movies and movies that depict somebody having PTSD. In fact, some research has shown that if you give someone a diagnostic checklist of things that show that you have PTSD, they can do it 96 percent of the time, just someone on the street.

DR. CURRY: So you really need a test that's very sensitive to that, and MMPI-2 has been shown in multiple studies to be excellent at detecting those attempts.

DR. CURRY: The -- I'm sorry if I hadn't said that. That's the Minnesota Multiphasic Personality Inventory.

DR. CURRY: So I also performed the Clinician-Administered PTSD Scale dash 5, and that dash 5 makes it to the diagnosis for PTSD in our current diagnostic manual, the fifth version. To do that test, you first administer something called the life events checklist, and the life events checklist -- both of these tests, by the way, were developed by the National Center for PTSD with the Department of Veterans Affairs. But the life events checklist lists 16 different very stressful life events that people can go through that are often -- can be associated with developing PTSD. And then it also has a 17th item that you can fill in if you feel like you've been through something really difficult that wasn't included.

DR. CURRY: Now, I like to also add something called the life events checklist 5 interview which digs a little bit deeper into the person's childhood as well to find out if they -- what sort of -- there are so many different things that can be difficult growing up. And also it's very important that you have the person determine which of the events they've listed -- let's say they have a number of different types of traumas -- which one do they feel like was the most traumatic for them? Which one still causes them to feel distressed when they talk about it? And sometimes they can't just identify one.

DR. CURRY: And then that has -- that leads to your next decision. So if they have multiple different similar types of events, like seeing combat, then you might use that as the worst one, the multiple similar. So that looks like you describe an anchor, we call it, to do the testing, and we I! Is would maybe describe the anchor as "the worst of my combat experience," okay?

DR. CURRY: Now, if somebody had multiple different traumas from different times in their life, like childhood abuse, and then went to combat and had some horrible things happen there, you would do the Clinician-Administered PTSD Scale test, the one that comes after, you do one for the childhood event and a separate one for the adulthood event

DR. CURRY: It does. We'll call it the CAPS-5. That's actually what it goes by.

DR. CURRY: The MMPI-2 is actually the most commonly used assessment worldwide by mental health professionals and in forensic settings for g the Court. 1! excellent validity in those settings across

DR. CURRY: I use it for that purpose and for its genders, across ethnicities, for different reasons, and when I keep saying "validity," by the way, what I mean is accuracy or -- and I'll try to work that in, but then also for detecting the accuracy with which a person reports PTSD.

DR. CURRY: I'm sorry. What was that?

DR. CURRY: The MMPI-2? Do you mean specifically for PTSD?

DR. CURRY: There's actually a combination of scales you want to look for. You would never make the diagnosis just based on one scale alone or even on the test alone. You'd integrate other data.

DR. CURRY: I provided her the test on an iPad MMPI-2 to Ms. Heard? She essentially had her own little desk area and then an iPad. She hit start It provides her with the instructions, and then the - it gives her 567 statements in order. For each one she taps "true" or "false."

DR. CURRY: Quite a bit. I wrote up a 25-page interpretation outline. It has numerous, numerous scales. So one of the reasons I like this measure so much is that it can tell you so much about multiple different traits and tendencies and mental issues.

DR. CURRY: One of the primary things I learned was that she had a very sophisticated way of minimizing any personal problems. I also learned that she tends to - well, there were a number of characteristics that were consistent with the eventual diagnoses, but some of the primary characteristics - I'm going to try to condense 25 pages here -- were essentially externalization of blame, tending to have a lot of inner hostility that is attempted to be controlled, a tendency to be very self-righteous but to also deny that self-righteousness and to judge others critically against these sort of high standards for moral value, but also to deny doing that. Essentially to claim that one is very nonjudgmental and accepting and yet very full of rage, really.

DR. CURRY: And these aren't facts, but her scores essentially correlated, so they were consistent with other people who obtained these scores who have been shown through many, many, many studies to have these very specific traits.

DR. CURRY: So externalization of blame, a lot of inner anger and hostility. Sometimes that anger, among these groups with similar scores, these people might have that anger kind of explode out at times. They tend to be very passive-aggressive. They may be self-indulgent, very self-centered. They could use manipulation tactics to try to get their needs met, very needy of attention, acceptance, approval. They tend to distance people who are close to them. Initially they may seem very charming; they're very socially sophisticated actually; that was a major component on there. They have a capacity to kind of offer some of their faults, but in a way -- but only the ones that people think of lightly and can all relate to. And so they can present as very fair and balanced, but in actuality, they really might be very judgmental of others and unaware of problems in their behavior and their thinking. So after you provide the examination So once they've completed the test, you can have it scored by the computer immediately. It's a very, very complex test to interpret, but right away, you'll get a list of what's called "critical items," and these are just some -- a couple of the items, the statements that are presented that were more clearly symptom based, and I always follow up with the examinee. Some of these might have to do with suicide. Some of them have to do with other symptoms that you'd just like to get a little bit more information on because sometimes an examinee might tell you they're fine when you're doing your interview with them and they have no symptoms, and then when they take the test, it says that they're having trouble sleeping or they struggle with nausea all the time or they feel very anxious, so you want to follow up on that.

DR. CURRY: A code type, let me think of how to explain this very, very simply. So the main scales, I keep referring to "scales." These are just the main scores that come up on this test, we can refer to them as codes. And when I was saying that Ms. Heard's scores could be compared to certain groups of people that had been researched before and obtained similar scores, the research has shown that certain people will have certain scores that kind of spike on us, okay?

DR. CURRY: And so all of those traits that I was describing, those are traits found in these code types. So it means that Number 2, score number 2 was high, and score Number 6 was high. And so if we have those two scores were both high, then that's a 2-6 code type, and the code type -- s

DR. CURRY: Ms. Heard had -- the clearest code type was 3-6, but then she also had some other code types that were less significant.

DR. CURRY: So a 3-6 code type, a lot of that anger is expressed in this code type. There can be actually a lot of cruelty. Usually with people who are less powerful, actually, when you see this code type, you want to, if you can, to follow up with subordinates, co-workers, people who may have observed their behavior more closely.

DR. CURRY: The 3-6 code type is very concerned with their image, very attention seeking, very prone to externalizing blame to a point where it's unclear whether they can even admit to themselves that they do have responsibility in certain areas.

DR. CURRY: Lot of suppressed and denied anger, but the anger is very present, will explode out, and a lot of issues in their close relationships.

DR. CURRY: Well, this might be an appropriate time to describe a little bit about these personality disorders because I think what you'll hear is that there's a lot of consistency there.

DR. CURRY: So borderline personality disorder is a disorder of stability. It's instability. And it's instability in personal relationships. It's instability in their emotions. It's instability in their behavior, and it's instability in their sense of self and their identity. And that instability is really driven by this underlying terror of abandonment.

DR. CURRY: So one of the key features also of this disorder, all of it is like pistons of an engine kind of firing off and igniting one another. But when somebody is afraid of being abandoned by their partner or anybody else in their environment and they have this disorder, they'll make

DR. CURRY: Desperate attempts to prevent that from happening. And those desperate attempts could be physical aggression. It could be threatening. It could be harming themselves. But these are behaviors that are usually very extreme and very concerning to the people around them The anger is typically what - sadly, it's counteractive, right? So the thing these people fear most is being abandoned, but over time, the anger, that explosive anger that they've shown when somebody is needing space or when somebody is really not doing anything wrong - because a lot of times they read into things that they perceive as being a slight to them or somebody intending to harm them that actually isn't happening - they'll exaggerate it, and they'll explode, react in this heightened manner that is just exhausting for their partners.

DR. CURRY: Oftentimes their partners will try to make them happy at first and really allow themselves to be a punching bag, thinking that they can somehow solve this problem, that somehow they can make this better. And eventually it just overwhelms them.

DR. CURRY: Okay.

DR. CURRY: I am.

DR. CURRY: So emotional reactivity is very common in the diagnosis. So essentially, like I said, there's instability in emotions. People with borderline personality disorder are often misdiagnosed as having bipolar disorder because they can be up and down. They can look very depressed, and they can look very elated. But these changes are happening within a matter of hours. Somebody with bipolar disorder, this is a clinical depression lasting days, weeks, a clinical mania where sometimes they even need to be hospitalized because they're so grandiose, they clear out their bank account and go to Vegas and spend it all, they're acting in some very bizarre ways.

DR. CURRY: With borderline personality disorder, you're having these fluctuating moods constantly, and again, this hypersensitivity to being slighted or feeling offended really driven by the fear that if you're offended or slighted, if the therapist comes in two minutes late, or if somebody shows up to dinner two minutes late, that they might be abandoning you. And it's not as if the borderline is considering themselves abandoned in that moment, but they just know that they have this overwhelming emotion, and there are no attempts to control that emotion.

DR. CURRY: There's no -- there are no attempts to regulate it. So if they're in the middle of the restaurant and they feel offended, they're going to start the fight. People are going to see it, or they might just start crying or break down. But they'll make a lot of accusations, and that reactivity is when you're going to just -- you're y y g g j y going to see a lot of this escalation of bizarre behavior. They can react violently. They can react aggressively. They will often physically prevent their partner from trying to leave if their partner want to get space from all of this intense emotions, and oftentimes they will be abusive to their partners in these situations.

DR. CURRY: Sometimes they'll physically restrain them from leaving and become injured that way, but also people with borderline personality disorder, it seems to be a predictive factor for women who implement violence against their partner, and one of the most common tactics that they'll use is actually physically assaulting and then getting harmed themselves. But mostly we call this "administrative violence," the -- essentially this is saying that they'll make threats using the legal system.

DR. CURRY: So they might say that they are going to file a restraining order or claim abuse, or they might do these things to essentially try to keep their partner from leaving in the moment.

DR. CURRY: Again, they're not consciously thinking, "I'm going to keep my partner from leaving right now." They're just thinking, "I can't stand this. I , hate my partner." They went from idealizing to suddenly devaluing because of the hurt, and they'll do anything to express that big emotion of anger.

DR. CURRY: Okay. So there were a couple indications to me. First, I can sort of think about it with the treatment record. So particularly, Dr. Cowan Connell - am I getting it right? I feel like for some reason in my mind, I might have just reversed it - but Dr. Cowan's records - I did reverse it - he actually refers to this reactivity quite a bit and to Ms. Heard's temper, and that temper is often branded, or being hotheaded, is really characteristic of borderline personality disorder, as is their very charming, personable nature. This is a disorder of contradictions.

DR. CURRY: In Nurse Falati's notes, she had -- I thought there was something interesting. She references a night when they're out to dinner, I believe in London, and she provided positive reinforcement to Ms. Heard because Ms. Heard had been disappointed by a mistake made by the server, and it sort of references how previously she might have criticized the server, become upset by that and that she didn't this time and so that that had been some sort of a step forward.

DR. CURRY: And there was also an indication, actually, in Dr. Hughes's -- Dr. Hughes is a forensic psychologist who had been appointed by Ms. Heard to conduct an evaluation as well. In Ms. Hughes's [sic] interview of Ms. Heard, Ms. Heard disclosed that she had cut her arm in the past, which is a typical reactive-type thing somebody with this diagnosis can do. It's one of the symptoms.

DR. CURRY: And that's sort of all I can think of top of my mind from the treatment records.

DR. CURRY: Moving into some of the declarations, or deposition testimony, what struck me was Ms. Raquel Pennington's testimony. She's a former friend of Ms. Heard's, and she indicated -- she told a story about I suppose that they were shopping for Thanksgiving accoutrements, something to prepare for Thanksgiving, and Ms.

DR. CURRY: Heard struck her in the face sort of out of the blue, which is -- I thought was interesting because that is one of those signs of borderline personality disorder where if a friend or loved one isn't meeting your needs in that moment, borderline -- people with borderline personality disorder can be really caring in their relationships as long as their needs are being met. They feel that their needs to be met when they want them met at a specific level, and if they're not, then that anger, that sense of harm causes them to react.

DR. CURRY: So the striking Ms. Pennington, per Ms. Pennington's report in the declaration -- or the testimony, I thought, was pretty consistent. And then Ms. Heard's own self-description -

DR. CURRY: Sure.

DR. CURRY: Yes.

DR. CURRY: Yes. So the instability definitely translates to their relationships. You'll see relationships start very intensely. People will - somebody with borderline personality disorder sees the relationship as extremely close. This pattern of idealizing and devaluing is definitely displayed. They do this with their lovers and also with their friends, and so this might be the perfect person, their perfect soul mate friend, perfect soul mate partner, and their engagement in the relationship is very alluring, I very charming to the other person, and so initially everything seems great But what occurs is that reality sets in. People are not perfect, even when we have a lot in common with them. Whereas most of us can accept somebody as a whole, somebody who has a little bit of flaws and still thinks, "This is my great friend who always is constantly running late for dinner," the person with borderline personality disorder, things are in these extremes, this black-and-white call it splitting. And so that person goes from being idealized, the perfect person, to dumpster. They are totally devalued. "They are the worst friend. They don't care anything about me.

DR. CURRY: I have better people around. And then there will be a repair because the person with this disorder does feel remorseful after they have these reactions, angry, tell their friend off. But over time, it wears away at these relationships, and so what you'll usually see is many, many transitions in their friendships over the years, people who have sort of fallen by the wayside who were really very close-knit at one time, and then -- but there's not a lot of consistency in the long-term. You'll also see that intimate relationships, many, many relationships, but none that are particularly long-term.

DR. CURRY: So, again, that instability also travels toward identity. When I was describing personality earlier, I was talking a little bit about those traits we have that help us know who we are. When you have borderline personality disorder, that actually is not something you understand.

DR. CURRY: So people with this disorder actually take on the identity of the people they're spending time with because it's comforting. It's very uncomfortable to not know who you are. Some people with this disorder describe a feeling of emptiness when they feel like they've been p y y abandoned because now they don't know who they are in the world. And so when somebody with this disorder is going through that initial enmeshment phase with new people and they're idealizing them, they often will take on the identities of those people, so they may mimic them in a lot of ways. They might mimic them in the way they dress, their interests, the way they talk. And for this reason, the people around somebody with this disorder kind of from the outside may feel like, "Wait, I thought you were this way.

DR. CURRY: Now you're advocating for this, and this is your new main interest in life or the thing you're throwing yourself into all completely." Music tastes might change. Hobbies will change, the way they dress.

DR. CURRY: So histrionic personality disorder -- and these are really two sides of the same coin. They belong to the same cluster, we call these clusters. It's a way to organize personality disorders in that DSM, and this cluster is described as the personality disorders that are dramatic, they're erratic, and emotional, okay? So unpredictable but really having to do with emotions and relationships. They're very similar.

DR. CURRY: Whereas I was saying that borderline personality disorder, a lot of the key features that you're going to notice are instability, when it comes to histrionic, a lot of the key features are going to be drama and shallowness. Similarly, with borderline personality disorder, there's this under - this underlying drive of avoiding abandonment. With histrionic personality disorder, that underlying drive is to always be the center of attention.

DR. CURRY: Because if you don't have that attention on you, it feels similarly to borderline personality disorder; you feel pretty I empty, like you don't have that sense of being or of value, okay?

DR. CURRY: So whereas borderline personality disorder might have more the visible reactivity if I Is somebody seems to be leaving, with histrionic personality disorder, what you're going to see is extreme discomfort with not being the center of attention, extreme efforts to be the center of attention, and when they feel they're not the center of attention, you will see some strange things, making up stories to try to get attention, often taking on a victim or a princess role, those two roles in_particular are pretty consistent, seeking caretaking.

DR. CURRY: Borderline personality disorder is similar because with borderline personality disorder, the shifts of identity and the splitting, you might see somebody go from being - in the DSM it describes it as "a needy supplicant of help," seeking the perfect caretaker, to suddenly being the avenger against injustice or thinking that their partner is a terrible person. With histrionic, what you'll see is somebody who wants to be the center of attention, has sort of that impressionist speech, very flowery, very enthusiastic, but nothing's really being said. The moment your attention wears away, because they're so demanding for attention, that's when they might take the victim role or the princess role and even make up stories. Sometimes those stories are to bolster the victim role. Sometimes those stories are just to make them look more interesting or accomplished in their mind so that they can get respect and attention that way.

DR. CURRY: There is, strangely. And this is always one of the trickiest things to talk about because how do you -- I mean, how is that a symptom? But characteristically people with this disorder are very, very interested in looks, but more importantly, they utilize their looks to get that attention, to get that respect that they're seeking. And so this type of a personality might be flirtatious with everybody. Characteristically they actually could even be subtly -- and when I say flirtatious, I'm not talking overtly sexy, but kind of inappropriately flattering. Sometimes they act in kind of a girlish way to be cute and to engender attention.

DR. CURRY: And this will even occur in their therapy relationships as a way to sort of avoid getting negative feedback or criticism. Other times, they'll bring the therapist gifts or be distracting if they engage in therapy because they just don't want any criticism. They want the therapist to like them.

DR. CURRY: Excuse me. I choked a little bit on my water.

DR. CURRY: Yes. And I think one way to think about it that's probably a little more accurate than just intelligence is in psychology, we would describe this more as sophistication, so street smarts, so to speak. The way - for instance, I've had many clients who have borderline personality disorder who are messy and really clearly suffering, and they might be difficult and I all over the place and yell at you in the middle of a session. But it's so -- it's not tailored. It's so much easier to work with because of that just openness and rawness of it, genuineness.

DR. CURRY: Sometimes you'll have a more sophisticated presentation. There are nine symptoms, and only five have to be met. There are a lot of different combinations and different ways that it can present. And sometimes you'll have more of a petulant version of this where it really shows when you push the button and you're kind of, "Woah, what was that?" So somebody who's really productive, high functioning, successful, and you get to know them and you think they're fantastic because they're so interested in you too, and you might not realize this, but they're mimicking you perfectly.

DR. CURRY: So you're really just kind of falling in love with this new friend who is being you. But then all of a sudden, you know, you say something that they think is offensive, and you can't, even in your wildest thoughts, understand how that could have offended somebody," but their reaction is so strong that you kind of buy into it. "Gosh, maybe I did say something offensive," and you feel bad about it So that sophisticated version, they can be a little bit more calculated in the way they present. They tend to kind of hit you where it hurts a little bit more, and they can be actually very, very destructive.

DR. CURRY: Well, from her testing and from her presentation, she was very likeable, but her testing, in particular, showed that she approached it in a manner that - remember I told you about those scales that are pretty neat- she approached it in a manner that very clearly minimized any psychological dysfunction, not just that, but really presented herself free of any problems. And she did so in a way that was very, very sophisticated, not obvious, by responding to questions that most people might not notice were trying to detect that.

DR. CURRY: So that's based on a particular scale on the MMPI-2 that is designed specifically to detect a type of responding that's a little bit more clever, a little bit more sophisticated, minimizing problems in a way that most laypeople probably wouldn't understand - and even providers, very difficult to detect.

DR. CURRY: So I think it probably presents mostly - or you'd see the bulk of it in intimate relationships because of that regular interaction and the desire for your partner to meet all of your needs, to be the perfect caretaker. Also that the hallmark of the disorder with the splitting, so idealizing, devaluing, and the perceiving of all sorts of neutral events as somehow demeaning or disrespectful.

DR. CURRY: It's regular escalations of anger, g g , frustrated, complaints, criticisms of your partner. But because the person with borderline personality disorder, first of all, they're more sensitive to things. They feel distress more strongly, and then that distress lasts longer. So these types of blowups go on forever, and they're very cyclic. It feels like you can't just get a resolution, and eventually, the partner will try to leave, will want to leave to get a break. It wears them down, and that's when the borderline might explode and act very aggressively or violently to try to prevent them from leaving.

DR. CURRY: Yes. So there were - go ahead.

DR. CURRY: Okay. Yes, I did.

DR. CURRY: So in addition to looking for Ms. Heard's general mental status, any psychological issues that were present, I very specifically was assessing to determine whether post-traumatic stress disorder was present, and it was not.

DR. CURRY: So first of all, from multiple Is information sources, right? So I was integrating the interview, my review of the data, the case records, other people's testimony, her treatment • 11 records.

DR. CURRY: And then I also conducted - in addition to the MMPI-2 and looking at that data, I also conducted the Clinician-Administered PTSD Scale, the CAPS-5, which is the gold standard PTSD assessment developed by the National Center for PTSD, shown to be valid, accurate for use not just with service members, but also with civilians, men, women, all genders, and also all ethnicities and then also specifically for use in a courtroom setting.

DR. CURRY: So the CAPS-5 is a standard interview. What that means is that it's an interview with very clear questions that are scripted. And you ask those same questions every time you test a person. So because you're doing that, you're actually taking something that would typically be kind of subjective, an interview with somebody, and you're making it more objective. When you ask those same questions in the same way every time somebody's assessed with this, now you can apply a scoring protocol and actually score their responses.

DR. CURRY: Ms. Heard did not have PTSD. And there were also pretty significant indications that she was grossly exaggerating symptoms of PTSD when asked about them.

DR. CURRY: So one of the strengths of this test, as I mentioned, the important thing about any test used when you're doing an evaluation in forensics is to make sure that the person is responding accurately. And this test does that by not just asking people whether they have a symptom, but asking follow-up questions that draw out very detailed accounts of every single symptom of PTSD.

DR. CURRY: And when you're really familiar with this disorder, which you need to be to administer this test, there are nuances in the way a person will describe their symptoms that have been shown. repeatedly to indicate exaggeration or faking. There are also indications when somebody is clearly giving you a genuine response.

DR. CURRY: So there are 20 kind of core symptoms that somebody might -- can manifest with PTSD; you don't have to have all of them. Ms. Heard initially said that she had, in the first question, you say, "Do you ever have this?" before you get to the more nuanced follow-up questions. When I asked that question on each item, she initially said, "Yes, I have that," to 19 of the 20 symptoms. That's not typical even of somebody with the most disabling form of PTSD.

DR. CURRY: When we eventually sort of dialed it down, she had three remaining symptoms, and having symptoms of any disorder is common for all of us. Some of us struggle with sleep. Some of us get anxious. It could be several different disorders. It could just be that you have this struggle in your life.

DR. CURRY: But she had three specific symptoms that I scored as present. Off the top of my head-- I might miss one, but one was sleep disturbance. So she reported that she had frequent nightmares. Another one that she says she tends to have is a startle response, so if she gets startled or surprised, she tends to stay in sort of a hyper-startled mode for quite a while, and that's consistent with a couple of things. It can be consistent with PISD if other criteria are met. It's also consistent with childhood complex trauma, which is something that can occur -- when I your brain is forming, if you constantly feel unsafe, if your parents are abusive, or if they're not present, if you're neglected, you can develop certain physiological responses that can stay for a long time in your life. So I noted that. That seems like a very genuine, accurate account where she stays in this state of kind of hyperarousal, has a hard time calming down if she gets surprised.

DR. CURRY: Yes.

DR. CURRY: So they were vague. She indicated that she has recurrent nightmares and that she feels as though she's being held down. And there were some conflict in that account because even though that could be a PTSD symptom, it is fairly vague, but I still scored it as present. And in her initial treatment with Ms. -- I'm sorry, with Dr. Bonnie Jacobs, which I believe started before she began dating Mr. Depp, she had indicated to Dr. Jacobs, according to Dr. Jacobs's notes, that she was having repetitive nightmares back then and that they were related to her childhood trauma. And so that came up several times in the notes. Dr. Jacobs kept mentioning that.

DR. CURRY: Feigning is essentially faking or exaggerating symptoms that aren't present.

DR. CURRY: It doesn't necessarily control for it. It can expose it by --

DR. CURRY: Because you're not just simply handing the person a checklist that says, "Here are all the symptoms of PTSD. Just check off the ones you have," which clearly if you're trying to look like you had PTSD, you would just check them all. The CAPS-5, because it requires them to describe in detail how they experience the symptom, where it shows up, what it looks like, what sort of examples they can give you, how many times it's happened in the last couple weeks, how many times it's happened in the last month, by the end of each symptom, you've gotten a very good picture of a couple things: One, does it meet the definition of the symptom? Are they getting it right? Right. Is this actually the symptom? Or are they kind of confusing this with something else?

DR. CURRY: Number two, are they giving you very vague accounts? Are they giving you kind of a stereotyped idea of what the symptom is based on media or movies or something that actually is completely different from genuine experiences of this symptom? Or are they giving you a very genuine, heartfelt -- sometimes minimizing, but it's ticking all the boxes, their mannerisms while they're describing it, the actual very specific, very nuanced, symbolic ways they're describing it, a lot of times it's smells; it's sounds.

DR. CURRY: That all appears in genuine accounts, and it's something that people really get wrong when they're feigning.

DR. CURRY: Yes, actually, I did. So, you know, just because somebody doesn't have PTSD doesn't mean that they weren't harmed psychologically by whatever is being alleged. In this case, Ms. Heard is alleging that she was psychologically harmed and that she had suffered PTSD because of abuse that she alleges occurred by Mr. Depp.

DR. CURRY: So I also -- the MMPI-2 is helpful because it shows you kind of everything, any other symptoms, and then in Ms. Heard's own self-report and her prior treatment record, I knew that she had reported to me that she had had some other symptoms.

DR. CURRY: So now what becomes really important is determining -- and let me clarify one thing here, not so much a diagnosis, but did she start to experience symptoms during the relationship and after? Did they worsen after? Or could these types of symptoms or reports be explained by other factors? A, by feigning; B, by preexisting I conditions; or, C, by other stressful life events that might have occurred?

DR. CURRY: So the main symptoms that I was looking at didn't meet criteria for PTSD, right? There was also, you know, substantial evidence of this sort of emotional dysregulation, emotional disorganization, the shallowness, the dramatic affect. Now, when you have a lot of childhood trauma, you can actually have some similar-type presentation in adulthood There are some differences, though.

DR. CURRY: But also that's not something that would have occurred after this relationship. So now I was looking at are there indications that these types of things that she's described, this transient anxiety, the issues with sleep, were these there prior? And sure enough, Ms. Heard, in her own self-report, stated to me that when she first got to LA, she was seeking treatment for, in her words, "blanket anxiety and depression." She also reported that she was taking medications in general. None of them were helpful.

DR. CURRY: That's actually very typical of borderline personality disorder. Medications typically aren't very helpful for somebody with a disorder. They really need an intensive, lifelong type of therapy which is not necessarily as relevant to this.

DR. CURRY: But interestingly also, people with I.

DR. CURRY: Borderline personality disorder often respond really positively to stimulant medications that are given for ADD or ADHD. And in one of Nurse Falati's notes, she reported that Ms. Heard told her that none of the medications were working for her except for one, Provigil, which is often prescribed as stimulant medication, and I had just thought that was interesting and sort of consistent with more of these lifelong personality disorders that aren't necessarily caused by a harm, by any allegations but have been there and will remain there, typically.

DR. CURRY: The other issue, you know, so the anxiety, she's had already indicated that that had been there prior, but the form of the anxiety, so looking at Dr. Hughes's testing and then also looking at the scores on the MMPI, when you look at all these little combination of the scores, you can actually learn a lot about is the anxiety related to an event? Or is this more a person who tends to be an anxious person regardless of what's going on in their life and somebody might describe them as a worry wart?

DR. CURRY: And the scores, the little combination of scores that she obtained actually indicated that it was the latter, that her anxiety tends to be separate from events and more just kind of a constant, and it comes and goes but its more of a trait.

DR. CURRY: Okay.

DR. CURRY: Thank you, Your Honor.

TARA ROBERTS: Yes, Your Honor.

DR. CURRY: No, I'm not.

DR. CURRY: No. I'm a licensed clinical psychologist.

DR. CURRY: No.

DR. CURRY: That's not correct.

DR. CURRY: I've been licensed for ten years.

DR. CURRY: And I've been practicing for about 15 years.

DR. CURRY: Yes.

DR. CURRY: That's not quite right. I was interviewed at Mr. Depp's home by his legal team Dinner was served.

DR. CURRY: Yes.

DR. CURRY: Yes.

DR. CURRY: Yes.

DR. CURRY: Yes, the interview.

DR. CURRY: Yes. Dinner and, I believe, drinks were served.

DR. CURRY: Yes, this was an interview so that they could make an informed decision as to whether or not to retain me.

DR. CURRY: I was interviewed by the legal team.

DR. CURRY: Yes.

DR. CURRY: He was not serving dinner and drinks.

DR. CURRY: Yes, it was at his house.

DR. CURRY: I knew of Ms. Vasquez professionally. We live in the same city, and I work with many attorneys.

DR. CURRY: Not correct. I did not know Johnny Depp.

DR. CURRY: AQ You knew of him? I had seen several of his movies.

DR. CURRY: Yes.

DR. CURRY: Yes.

DR. CURRY: I did not provide an expert designation. That's an attorney thing. My opinions are contained in my report.

DR. CURRY: Yes.

DR. CURRY: I'm reading that here. That's not my opinion. It's a current opinion, but this was not an opinion of mine then. I did not have any opinions at that time.

DR. CURRY: That's what it says, yes.

DR. CURRY: I'm not sure I understand what that means.

DR. CURRY: No.

DR. CURRY: I'm not an attorney. I don't understand, necessarily, all of these procedures.

DR. CURRY: I was made aware of that in this case, yes. Actually, not necessarily taunting, but I do recall hearing that Mr. Depp had used that phrase.

DR. CURRY: My opinion -

DR. CURRY: I can't speak to whether or not there's a coincidence. What I can tell you is, my opinions are based on the results of my evaluation.

DR. CURRY: I'm not sure.

DR. CURRY: No. That's not quite right.

DR. CURRY: The way you phrased it is not quite right.

DR. CURRY: Okay. So there are more women who have been diagnosed with bipolar disorder than men, it's more prevalent in women.

DR. CURRY: No.

DR. CURRY: Right now, we know that there are people who have borderline personality disorder who have sustained childhood trauma. There are also people who have borderline personality disorder who have had no childhood trauma.

DR. CURRY: So, like most personality disorders, and really like most mental health issues in general, there seems to be both a biological component, in this case, with borderline personality disorder, the research tends to support a genetic component and possibly a neurological component, and then there's also, possibly, an environmental component triggering those genetic marks.

DR. CURRY: I can't tell you the percentage off the top of my head, but I do know that there is a larger - women with borderline personality disorder tend to have a higher prevalence of being involved in intimate partner violence relationships, being the receiver of violence and being the perpetuator of violence.

DR. CURRY: Bipolar disorder?

DR. CURRY: That's not correct. •18

DR. CURRY: Thank you.

DR. CURRY: Yes.

DR. CURRY: I believe that was the date, yes.

DR. CURRY: Yes.

DR. CURRY: I'm sorry. Page 207?

DR. CURRY: Ah. "No."

DR. CURRY: I'm sorry, I missed the first part. What was that?

DR. CURRY: Oh, okay.

DR. CURRY: No, I didn't render any opinions. My opinions weren't finalized until after my evaluation.

DR. CURRY: I had not rendered that opinion.

DR. CURRY: It says perpetrated, but other than that, yes.

DR. CURRY: This document, yes.

DR. CURRY: It says that.

DR. CURRY: Thank you.

DR. CURRY: Thank you.

DR. CURRY: No, I've never been asked to testify to that.

DR. CURRY: No.

DR. CURRY: No. That is correct, yes.

DR. CURRY: No. That is correct, yes.

DR. CURRY: I see that. You said it's my third opinion. That is not my opinion.

DR. CURRY: Yes, that's what this says.

DR. CURRY: No. As I said, I had not formed any opinions at that time. I had just been retained.

DR. CURRY: In terms - no, the opinions that I've rendered are provided in my report.

DR. CURRY: They're what I'm testifying to today.

DR. CURRY: That's correct.

DR. CURRY: What I'm saying is that this, the opinions in here, these are not my opinions. My opinions are provided in my report.

DR. CURRY: I don't have that page, I'm sorry.

DR. CURRY: Oh, okay.

DR. CURRY: That is correct. I 4

DR. CURRY: Yes. "So, no, it's not the task" - I was cut off - essentially, what I wrote - what I said then was -

DR. CURRY: No. That's not the task of - that was never my task to determine.

DR. CURRY: Well, there was an objection.

DR. CURRY: No, no.

DR. CURRY: Correct.

DR. CURRY: I said, "No."

DR. CURRY: I believe I had just started to review materials. I believe that I indicated that in my deposition. I had not, yet, rendered any opinions. I hadn't completed my review, and I hadn't conducted an evaluation.

DR. CURRY: I believe that is correct. But I may not be remembering all of my cases.

DR. CURRY: Okay.

DR. CURRY: Gosh, let me catch up. Line 22.

DR. CURRY: "No."

DR. CURRY: That's correct.

DR. CURRY: Again, that -- I'm reluctant to say that's correct because with 15 years of experiences -- experience, a lot of my cases have been complex, and that may have been a component. But I don't remember, explicitly, a case being just about that.

DR. CURRY: No.

DR. CURRY: I hadn't gone to the page in time.

DR. CURRY: But I have not.

DR. CURRY: That's correct.

DR. CURRY: That's outside the task of a psychologist, to determine whether an event , occurred. We assess behavior, we assess mental status, we don't detect crimes.

DR. CURRY: It's not something that occurs, so, no, I have not

DR. CURRY: No, I was not.

DR. CURRY: I'm sorry. Can you repeat that one more time?

DR. CURRY: Excuse me.

DR. CURRY: I did not disclose that I was interviewed by the legal team, no.

DR. CURRY: I'm not trying to resist that, but it's I not quite right.

DR. CURRY: I did. With his legal team

DR. CURRY: And what?

DR. CURRY: Drinks were served. This was over two years ago. I may have had a drink with dinner, yes.

DR. CURRY: Possibly.

DR. CURRY: I did not disclose that. It's not significant to the report.

DR. CURRY: I don't.

DR. CURRY: No.

DR. CURRY: That's not quite right. I justified it, in this case, actually, I sought consultation about it. First of all, the person who had about it. First of all, the person who had retained his attorneys was unable to come to my office with his attorneys, and, yes, this is a very visible case, it's been going on a very long time, and I understood that there would be a need to interview me and determine - make an informed decision about my qualifications.

DR. CURRY: Yes.

DR. CURRY: Yes.

DR. CURRY: Correct.

DR. CURRY: Correct.

DR. CURRY: That's not true.

DR. CURRY: So, as a forensic psychologist, my obligation is to the Court, is to the fact finder. I present science, regardless of what that science may be. Now, when I take a case, my retainer may be. Now, when I take a case, my retainer I agreement is explicit about that and - d I'S

DR. CURRY: Okay.

DR. CURRY: No, I would - sorry.

DR. CURRY: That is not accurate.

DR. CURRY: Ms. Bredehoft, that is not accurate.

DR. CURRY: You're incorrect. That is not correct.

DR. CURRY: That is my testimony.

DR. CURRY: May I clarify what occurred so we can stop talking about muffins? What happened was that I was getting ready that morning, I frequently bring muffins to the office, my husband did happen to know that there was going to be a celebrity client coming in because on the morning that that occurs, which often occurs, we have to actually clear the office and move the staff to the other office. So, yes, on the one hand, he was aware of that. I was getting ready. I asked him to go to the bakery near our house and pick up the muffins for me because I was running late. He often has to do that because I often do run late.

DR. CURRY: He brought the muffins back to the house, I brought them into the office, Ms. Heard and I enjoyed the muffins together. I think I made the comment to her along the lines, like, we can thank my husband - or my husband got these for us today, meaning he purchased the muffins, we are now enjoying them because of him

DR. CURRY: 305 and 306?

DR. CURRY: Is there a line you want me to look at?