Depp v. Heard Transcript Tara Roberts
Depp v. Heard / Day 9 / April 26, 2022
4 pages · 3 witnesses · 2,825 lines
Day 9: island manager Tara Roberts corroborated a December 2015 Bahamas altercation, forensic psychologist Shannon Curry diagnosed Heard with BPD and found no PTSD, and LAPD Officer Saenz testified she observed no injuries on May 21, 2016.
Procedural Preliminary Matters
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COURT BAILIFF: All rise. Please be seated and come to order.

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THE COURT: All right. Good morning. Do we have any preliminary matters before we have the jury?

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MS. BREDEHOFT: Your Honor, may we approach, please?

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THE COURT: Yes, ma'am.

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MS. BREDEHOFT: Your Honor, we received .11 126 photos --

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THE COURT: Oh, goodness.

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MS. BREDEHOFT: Last night, almost -- shortly before midnight.

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THE COURT: Okay.

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MS. BREDEHOFT: We're still assessing I them.

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THE COURT: I understand.

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MS. BREDEHOFT: And so we'll determine, but I wanted the Court to know that we now have those.

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THE COURT: You have them? Good.

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MS. BREDEHOFT: And we're going to figure out --

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THE COURT: How you're going to use them? Good. That's fine.

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THE COURT: And he's still under --

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UNKNOWN: (Indiscernible), yeah. And we --

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THE COURT: You might do the same thing. Okay.

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MS. BREDEHOFT: And then Officer Saenz will be by video this afternoon. I'm trying to work with counsel to work off those exhibits because that was before we started --

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THE COURT: All right.

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MS. BREDEHOFT: Working those with Your Honor, so we're going to see if we can get those figured out if there's any we disagree on, we want to argue about those before we do the deposition.

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THE COURT: Okay.

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UNKNOWN: We should be able to work that out.

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THE COURT: Right. And it's a remote witness first, and then you're going to have a live witness before the deposition?

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UNKNOWN: Yes.

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MS. BREDEHOFT: Correct.

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THE COURT: Okay. So that'll work out.

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MS. BREDEHOFT: Thanks.

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UNKNOWN: Thank you, Your Honor.

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THE COURT: We can go ahead and bring the jury in.

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[STAGE DIRECTION]: (Whereupon, the jury entered the courtroom and the following proceedings took place.)

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THE COURT: All right. Thank you. Good morning, ladies and gentlemen.

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THE COURT: All right. Your next witness.

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MS. CALNAN: Good morning, Your Honor. Plaintiff calls Tara Roberts.

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THE COURT: All right. Let's see if we can get her on here.

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THE COURT: Ms. Roberts, can you hear me? Can you hear me, Ms. Roberts? Ms. Roberts? I can see her. Excuse me.

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THE COURT: See if she's on mute or not. Can you hear me, Ms. Roberts?

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TARA ROBERTS: Yes, I can

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THE COURT: Okay. Great Can you Raise your right hand for me. I, TARA ROBERTS, being first duly sworn, was examined and testified as follows:

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[SECTION HEADER]: EXAMINATION BY COUNSEL FOR THE PLAINTIFF AND

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MS. CALNAN: Okay.

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MS. CALNAN: Good morning. Would you please state hi your name for the record.

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TARA ROBERTS: Tara Lee Roberts.

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MS. CALNAN: Ms. Roberts, how do you know Johnny Depp?

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TARA ROBERTS: I manage his island in the Little Hall's Pond Cay in the Bahamas for the past 15 years.

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MS. CALNAN: Ms. Roberts, where do you live?

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TARA ROBERTS: I live on the island, and I have a home in Nassau and in Long Island, Bahamas, which I try to get to as frequently as possible.

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MS. CALNAN: Can you please describe Mr. Depp' s I private island, generally?

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TARA ROBERTS: My duties on the private island would be to maintain the island, the buildings, the housing, logistics, not included or limited to provisioning fuel, gas, groceries, just day-to-day operations, staff, and kind of like an estate just in the middle of nowhere.

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MS. CALNAN: Okay.

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MS. CALNAN: Your Honor, I would like to pull up Plaintiff's Exhibit 49 which has previously been submitted into evidence.

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THE COURT: Okay.

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MS. CALNAN: And, Mr. Gibson, if you could, play this.

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MS. CALNAN: And, Your Honor, if we could, publish this to the jury.

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[STAGE DIRECTION]: (Whereupon, a video was shown.)

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MS. CALNAN: Thank you. We can take that down.

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MS. CALNAN: Ms. Roberts, do you recognize what is shown in that video.

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TARA ROBERTS: Yeah. That's Johnny's house on the island

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MS. CALNAN: Okay. Thank you.

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MS. CALNAN: Mr. Gibson, can you please pull up Plaintiffs Exhibit 348. And this hasn't been submitted into evidence yet, so let's first just play it for Ms. Roberts.

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THE COURT: All right.

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[STAGE DIRECTION]: (Whereupon, a video was shown.)

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MS. CALNAN: Ms. Roberts, do you recognize what is shown in that video?

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TARA ROBERTS: That's his house and closet area.

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MS. CALNAN: Okay.

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MS. CALNAN: Your Honor, I would like to -- plaintiff moves to submit this into evidence.

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MS. CALNAN: UNKNOWN SPEAKER: No objection.

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THE COURT: All right. 348 in evidence. Do you wish to have it published?

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MS. CALNAN: Yes, please publish that to the jury.

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MS. CALNAN: And, Ms. Roberts, what is that doorway with the beads that was just shown in that video?

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TARA ROBERTS: That's the entrance to the closet

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MS. CALNAN: Okay. Thank you.

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MS. CALNAN: We can take that down.

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TARA ROBERTS: In his house.

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MS. CALNAN: Ms. Roberts, I believe you mentioned that you managed staff on the island. How many people work with you on the island?

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TARA ROBERTS: Myself and three others, Jason Majors goes by CJ, Stephen Farrow and Rico Major.

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MS. CALNAN: I believe the witness is not being shown to the jury right now on their screens. Thank you.

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THE COURT: No, the witness. There we go.

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[SECTION HEADER]: BY MS. CALNAN:

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MS. CALNAN: Thank you. Ms. Roberts, how are you compensated for your work on the island?

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TARA ROBERTS: I receive a monthly salary.

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MS. CALNAN: Other than this monthly salary, what other sources of income do you have?

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TARA ROBERTS: I get dividends of rental from family properties and businesses that we have.

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MS. CALNAN: Since you've been working for Mr. Depp, how often have you seen him?

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TARA ROBERTS: On average, two, three times a year. Sometimes it was longer, more visits; sometimes I didn't see him for a period of time, depending on what his schedule was or what was happening on the island.

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MS. CALNAN: And how would you describe your interactions with Mr. Depp?

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TARA ROBERTS: The island is a very friendly atmosphere, dinners together; he's very social, funny, humorous, very kind with all of us, and, y, very outgoing. I've enjoyed working with him and for him.

87

MS. CALNAN: When you first started working on Mr. Depp's island, who would come down to the island?

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TARA ROBERTS: At the beginning, it was Vanessa and the children. When he started dating Amber- ls

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MS. BREDEHOFT: Objection. Relevance.

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THE COURT: Hold on a minute, ma'am. Objection.

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MS. BREDEHOFT: Relevance.

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FEMALE SPEAKER: It goes to just Ms. Roberts's knowledge of who came down to the island.

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THE COURT: We can move forward. Next question.

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MS. CALNAN: Okay.

95

MS. CALNAN: Ms. Roberts, when -- well, Ms. Roberts, are you aware if Mr. Depp brought -- or how often did Mr. Depp bring guests with him to the island?

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TARA ROBERTS: He had guests, he would bring Amber and Amber with friends, and also I had on one of the occasions, I had Paul Bettany and his wife and his children here on one of the trips.

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MS. CALNAN: And when did the Bettanys come down to the island?

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TARA ROBERTS: Sometime in the summer of July 2013.

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MS. CALNAN: What happened when the Bettanys came down?

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TARA ROBERTS: It was a normal trip. I -- we had an incident where I was asked to have Amber leave the island. I scheduled a flight for her to leave to go to Florida that morning. And then that afternoon, I was told to bring her back, and then I arranged for a flight for her to come back that afternoon to the island.

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MS. CALNAN: When did you first meet Ms. Heard?

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TARA ROBERTS: I believe it was shortly after they started dating.

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MS. CALNAN: What was your impression of Ms. Heard when you first met her?

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MS. BREDEHOFT: Objection.

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TARA ROBERTS: I very much loved her.

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MS. BREDEHOFT: Relevance.

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MS. BREDEHOFT: I'll withdraw it. I'll withdraw.

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THE COURT: Okay. Go ahead. Next question.

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MS. CALNAN: I think Ms. Bredehoft has withdrawn her objection.

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THE COURT: Yes. Go ahead.

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[SECTION HEADER]: BY MS. CALNAN:

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MS. CALNAN: Okay. So, Ms. Roberts, you can answer. What was your first -- what was your impression of Ms. Heard when you first met her?

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TARA ROBERTS: I think they were a very nice couple in love. They - she cooked for him, cleaned up. They took care of each other. They were a very happy couple.

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MS. CALNAN: When, if at all, did that change?

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TARA ROBERTS: With each visit, it changed. More of - we were more not like an island life anymore; it was more of wines and more requests, simple things, toiletries, to have things here in place before they came or she came as well. So it, you know, luggage changed, more and more p luggage, just things evolved and kind of mushroomed a bit. 1:

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MS. CALNAN: How often would you see Ms. Heard on the island when she was in a relationship with Mr. Depp?

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TARA ROBERTS: On average, every day, taking meals, cleaning houses, sometimes more.

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MS. CALNAN: And how often would Ms. Heard come down to the island?

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TARA ROBERTS: At the beginning, probably the same, two or three times a year, sometimes three times with her friends and family and Johnny.

120

MS. CALNAN: During your interactions with Ms. Heard, what, if any, changes did you observe of Ms. Heard?

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TARA ROBERTS: The taking care of - the cooking . meals, we had a chef come to cook. It was more of a - it was more of a formal island with chefs and housekeepers and things like that change, and yeah, pretty much that.

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MS. CALNAN: Ms. Roberts, were you on the island on August 2014 for Mr. Depp's detox?

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TARA ROBERTS: I I es, was.

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MS. CALNAN: Who else was on the island?

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TARA ROBERTS: I believe I saw and met Johnny, Amber, and Deb. I brought them - flew them back to the island, and then a couple of -

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MS. CALNAN: Ms. Roberts, I believe you froze there for a second. I heard you say Johnny, Amber, and . Deb, and then you were cut off for a second.

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TARA ROBERTS: Couple days into - a couple days later, Dr. Kipper arrived.

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MS. CALNAN: Okay. What do you recall about that time that Mr. Depp came down to the island in -13 August 2014?

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TARA ROBERTS: That he was going to be here - they were going to be here for an extended period of time, at least a month or longer, and so we I provisioned for a month for the trip, and after about a week or two, they left.

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MS. CALNAN: Where was Mr. Depp staying for the ?O detox?

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TARA ROBERTS: In his house.

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MS. CALNAN: Is that the same house that was just 'shown in those videos earlier?

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TARA ROBERTS: Yes, it was.

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MS. CALNAN: How often would you see Mr. Depp when he was on the island for the detox?

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TARA ROBERTS: Every day, but not face-to-face, just from delivering some - replenishing the house, delivering supplies, water, things like that, linens and changing things out. So glimpses of him, not a conversation as it used to be.

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MS. CALNAN: How was Mr. Depp when you saw him?

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TARA ROBERTS: He was always asleep on the couch.

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MS. CALNAN: While Ms. Heard was on the island for the detox, what, if any, injuries did you observe on Ms. Heard?

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TARA ROBERTS: I didn't see anything.

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MS. CALNAN: After Mr. Depp and Ms. Heard left the island, what happened next?

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TARA ROBERTS: We would go into the house and break it down, empty out refrigerators, change the linens, collect the laundry, straighten the house back up again.

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MS. CALNAN: After they left, what, if any, property damage did you observe?

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TARA ROBERTS: There wasn't any.

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MS. CALNAN: Ms. Roberts, to what extent were you involved in Mr. Depp and Ms. Heard's wedding in February 2015 on the island?

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TARA ROBERTS: Pretty much all aspects of it, logistics, work permits, getting things set up onto the island, to the island staff, provisions, building of the tents, and organizing transportation of guests to and from the island.

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MS. CALNAN: When did you first hear that Mr. Depp and Ms. Heard were getting married on the island?

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MS. BREDEHOFT: Objection. Calls for hearsay and relevance.

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THE COURT: What's the relevance of when she heard?

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MS. CALNAN: I can move on.

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THE COURT: Okay.

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THE COURT: Next question.

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MS. CALNAN: What communications, if any, did you have with Ms. Heard about the wedding?

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TARA ROBERTS: We were given information on a schedule to better help me with the scheduling and provisioning of what would be on the island, beverages and food and things like that. We were given the schedule for daily -- things were going to happen each day, what time foods were, when people were coming in, how many people would be at meals just so I had a better idea of planning what was happening. It was detailed. It was what was happening each day on -- and then it was the rehearsal night and there would be, you know, we had scheduled there would be dinner, dancing, drugs, music.

154 32:54

TARA ROBERTS: And then the wedding, they were very conscious about doing the -- the next day we were doing the wedding, the ceremony, and we were specific on time, privacy was very important. We were very careful of people taking pictures. I think everybody was given disposable cameras and asked not to take pictures.

155 33:18

TARA ROBERTS: I was concerned about that also, but we were doing the ceremony at sunset, so there really wouldn't be an issue with paparazzi people and things like that. And shortly when the ceremony was about to happen, it actually happened earlier. When it was scheduled, the bridal party and Amber showed up early, and we were still scrambling for flowers and setting up and getting beverages and snacks down there, and there was a plane circling overhead and it just kept on circling and circling and taking pictures, and the ceremony proceeded earlier than was scheduled.

156 34:08

MS. CALNAN: Did you observe Mr. Depp drinking O alcohol at the wedding?

157 34:12

MS. BREDEHOFT: Objection. Leading.

158 34:12

THE COURT: All right. I'll sustain l the objection.

159 34:14

MS. CALNAN: Okay.

160 34:21

MS. CALNAN: Ms. Roberts, as part of the provisioning for the wedding, did you order alcohol for the wedding?

161 34:27

MS. BREDEHOFT: Objection. Leading.19

162 34:29

THE COURT: Sustained.

163 34:30

MS. CALNAN: Okay.

164 34:31

MS. CALNAN: Ms. Roberts, what did you order for the wedding in February 2015?

165 34:38

TARA ROBERTS: I was given a list of food. I was given a list of beverages for wine, champagne. I was asked to have Dr. Pepper and sugar-free Red Bull here because at that time, that was what Mr. Depp, or Johnny, was drinking was Dr. Pepper and sugar-free Red Bull.

166 35:01

MS. CALNAN: Okay. Did you observe Ms. Heard drinking alcohol at the wedding?

167 35:06

MS. BREDEHOFT: Objection. Leading.

168 35:08

THE COURT: Sustained.

169 35:09

MS. CALNAN: Who did you observe drinking alcohol at the wedding?

170 35:15

TARA ROBERTS: Pretty much everybody was drinking and doing shots and celebrating. It was a party.

171 35:25

MS. CALNAN: Ms. Roberts, I'd like to discuss with you when Mr. Depp and Ms. Heard were on the island in December of 2015, who came down to the island with them?

172 35:37

TARA ROBERTS: I flew to Nassau to meet them, which is what I normally do, I meet himself, Johnny, and whoever comes to the island, I fly to Nassau to meet them just to make sure that the transition is smooth with customs and immigration. So I flew to Nassau, and I met Johnny, Amber, his children, and a friend of theirs -- of the children -- and loaded the luggage onto the caravan plane, and we loaded the plane and came to the island. And a couple days into the trip, Alice and Greg and Alice's three children and a nanny came to the island as well.

173 36:21

MS. CALNAN: Who are Alice and Greg?

174 36:24

TARA ROBERTS: Alice is a clothes designer, and Greg was her partner. I believe he's a photographer.

175 36:33

MS. CALNAN: When did you first interact with Ms. Heard when she came to the island in 2015?

176 36:41

TARA ROBERTS: At the airport when I flew to Nassau to meet everybody, just when they come off the plane, you know, there's hugging and kissing and chatting for a couple minutes while the luggage is transferred.

177 36:51

MS. CALNAN: How close are you to Ms. Heard?

178 36:57

TARA ROBERTS: Close. Hug, kiss, you know, "How are you?" Talk, same with everybody. So face-to-face, cheek to cheek.

179 37:05

MS. CALNAN: What, if any, makeup did you observe Ms. Heard wearing when you first interacted with her?

180 37:11

TARA ROBERTS: I don't recall if she was or was not wearing makeup. She -- if she wore makeup, it was very natural. I don't think often she wore makeup on the island. I don't recall her wearing makeup.

181 37:29

MS. CALNAN: What, if any, injuries did you notice on Ms. Heard?

182 37:34

TARA ROBERTS: I didn't notice any.

183 37:37

MS. CALNAN: Ms. Roberts, you mentioned that Gregory, a photographer, came to the island during that time. How often did you observe Gregory on the island?

184 37:47

TARA ROBERTS: I interacted every day as meals went °16 down and changing the sheets and cleaning the ,17 rooms. So I see everybody every day there.

185 38:00

MS. CALNAN: And when you saw him, what was he •19 doing?

186 38:05

TARA ROBERTS: They were doing -- there was a photo shoot on the island. Amber was wearing the clothes -- Amber was wearing Alice's clothes, and, they were doing a photo shoot on the beach and Greg was taking pictures.

187 38:21

MS. CALNAN: What, if anything, do you remember about that particular time that Mr. Depp and Ms. Heard came down to the island?

188 38:29

TARA ROBERTS: We had a - there was an incident between Johnny and Amber here during that trip.

189 38:38

MS. CALNAN: Okay. Can you please describe that incident?

190 38:45

TARA ROBERTS: One evening, we've kind of called it a night Dinner was finished, we wrapped everything up down here at the staff area in the kitchen. Myself and CJ came to the office later on that evening, and Johnny was in the office up here and he was agitated, kind of walking back and forth. I'd asked him if he needed anything, because I figured - I wasn't sure if he was up here to get something or was looking for something, which wouldn't be unusual for people to come up here. So he was here.

191 39:17

TARA ROBERTS: We talked for a couple minutes, the three of us, and a couple minutes later, Amber came into the office with - into the office, and we were - the three of us were in the office and Amber came in and she was asking him to - telling him to come back to the house. "Please come back. I'm sorry. Come back.

192 39:41

TARA ROBERTS: And he stood here, reluctant to go. Didn't want to go. And a little exchange back and forth. He left the office and got into his vehicle and started it up, and Amber went outside and stood in front of the vehicle so that - didn't drive away. She was standing - Amber was standing in front of it and, again, it was - she was asking him to "Don't leave. I'm sorry. Come back to the house."

193 40:16

TARA ROBERTS: After a couple minutes, she got in the vehicle, and they left to go back up to the house.

194 40:24

MS. CALNAN: What happened after they went back up to the house?

195 40:29

TARA ROBERTS: CJ and I were still in the office and weren't really sure - decided that maybe it would be best if we just drove up there just to make sure that everything was okay, and so we got in the golf cart and we drove up to the house, got to the parking lot, and his vehicle was in the parking lot. And you could hear them -- you could hear them inside the house -- you could hear inside the house yelling, her yelling, Amber yelling and Johnny answering back, but you couldn't really hear what was being said.

196 41:09

TARA ROBERTS: We stood there for a couple minutes, CJ and myself, and then you started to hear, it became audible. Amber was telling him that he was a washed-up actor, he was going to die a fat, lonely old man. Then you heard, "You hit me with a can." You heard Johnny say, "You hit me with a can," and then he came down the steps, and Amber was behind him and she had a bottle in her hand, was removed, and it was a brief pause the moment, I think, of initial shock or uncertainty of why -- we were there. Neither Johnny nor Amber knew that we were there.

197 41:52

TARA ROBERTS: He proceeded to walk back to the John Deere, and she, again, walked -- he was just sitting in the seat. Amber came up to him and was asking him to come back to the house, and she was sorry, please come back in the house. And he didn't come out of his seat, and she was hugging and kissing him and "I love you. I love you." She was telling him, "I loved you." He didn't react. Johnny sat there, eventually got out of the John Deere, and proceeded to start to walk away. At that time, Amber started to grab at him and his shirt and trying to call him back to the house, just basically viciously trying to pull him back and get him back to the house and yelling at him.

198 42:42

TARA ROBERTS: And at that point, I was between them and felt it was best and -- I was getting worried about what was going to happen, and it was best that I remove him from the situation. And so CJ took Amber back to the house, and I walked Johnny over to the cafe, which was basically 30 seconds away from the house because it was the only place I could take him to at the time.

199 43:12

MS. CALNAN: And you mentioned that Ms. Heard was viciously trying to pull Mr. Depp back. Can you explain what you mean by that? clothes, grabbing his hair, trying to pull him

200 43:27

TARA ROBERTS: It was like clawing, grabbing his back like an angry- he was leaving. And "Come back." He couldn't leave in the vehicle because I the keys had been taken out. So there was no way for Johnny to drive away. The only way was for him to - for him to walk away. And it wasn't a pleasant situation of wanting him to not leave. And Amber just yelling, you know, "Come back. Come back. Don't leave," and things like that.

201 44:01

MS. CALNAN: At any point, did Mr. Depp hit or touch Ms. Heard?

202 44:05

MS. BREDEHOFT: Objection. Leading.

203 44:06

THE COURT: All right. Sustain the objection.

204 44:13

MS. CALNAN: Ms. Roberts, how did Depp react to Ms. Heard viciously grabbing him?

205 44:16

TARA ROBERTS: He didn't. He stood there with his arms by his side, and he - he didn't do anything.

206 44:26

MS. CALNAN: Okay. Ms. Roberts, when you were back in the cafe with Mr. Depp, what happened next?

207 44:34

TARA ROBERTS: I was concerned because he I had heard him say -

208 44:39

MS. BREDEHOFT: Objection. Objection to her being concerned because that's not responsive to the question.

209 44:42

THE COURT: I'll sustain as to concerned.

210 44:45

MS. CALNAN: Ms. Roberts, without testifying how you felt, what did you observe when you went back to the cafe with Mr. Depp?

211 44:53

TARA ROBERTS: We went back to the cafe. He had a mark across the bridge of his nose. I got a bag of ice to put on his - on it so that it wouldn't swell, just to make sure that it wasn't bleeding, and I- he walked over to the love seat of the cafe, and he laid down and went to sleep. And CJ came back over, and I asked CJ to stay there for the remainder of the evening, for the remainder of the morning. And I left CJ inside the cafe, and I left Johnny on the couch.

212 45:31

MS. CALNAN: When did you next see Ms. Heard?

213 45:37

TARA ROBERTS: That morning. I saw her that morning.

214 45:39

MS. CALNAN: How close were you to Ms. Heard when you interacted with her the next morning?

215 45:50

TARA ROBERTS: Conversation in a couple feet away.

216 45:51

MS. CALNAN: When you saw her, how did she appear?

217 45:59

TARA ROBERTS: They had guests leaving, and it was kind of a normal morning, going down to the beach to see the guests leave.

218 46:11

MS. CALNAN: What, if any, makeup was Ms. Heard wearing?

219 46:16

TARA ROBERTS: Again, I'm not sure if she wore makeup on the island. If it was, it was very natural looking.

220 46:25

MS. CALNAN: What, if any, injuries did you observe on Ms. Heard?

221 46:30

TARA ROBERTS: I didn't observe any.

222 46:33

MS. CALNAN: What, if any, injuries did you observe on Mr. Depp?

223 46:38

TARA ROBERTS: The marking across the bridge of his nose.

224 46:45

MS. CALNAN: After -- and when did Ms. Heard and Mr. Depp leave the island?

225 46:51

TARA ROBERTS: I believe they left that afternoon The guests left in the morning and I believe they left that afternoon.

226 46:58

MS. CALNAN: After Ms. Heard and Mr. Depp left the I! island, what did you do next?

227 47:04

TARA ROBERTS: Our usual. We go into the buildings, and we break them down. We empty out the refrigerators, garbage, take all of the perishables out of the house, straighten things up, take linens away, things like that.

228 47:21

MS. CALNAN: What did you observe when you went I through that process?

229 47:26

TARA ROBERTS: I mean, the island was - the island was as it was when they arrived. The only thing that was different was the - there was a liquid on the deck with a can, I believe, of mineral spirits or something there next to it which had leaked out onto the deck, and over the railing were paintbrushes and art supplies, paintbrushes, paint tubes, jars that the paints are in, and those were all scattered in the bush.

230 47:58

MS. CALNAN: Ms. Roberts, when is the first time you provided testimony about this incident in December 2015?

231 48:05

TARA ROBERTS: I believe it was for another case in May 2020.

232 48:12

MS. CALNAN: Ms. Roberts, how often have you seen Mr. Depp drink alcohol on the island? h 15

233 48:19

TARA ROBERTS: I mean, there's some periods of time when he's here and he doesn't drink. It's non-alcoholic, Beck's or something like that. It varies. Sometimes he drinks when he's here; ,9 sometimes he doesn't.

234 48:31

MS. CALNAN: How often have you seen Ms. Heard drink alcohol on the island?

235 48:37

TARA ROBERTS: She drank wine. She drank wine with - her drink was wine with dinner, maybe in the afternoon, but I know definitely with dinner.

236 48:47

MS. CALNAN: Did you observe Ms. Heard drinking p6 alcohol when Mr. Depp was not drinking alcohol?

237 48:51

MS. BREDEHOFT: Objection. Leading.

238 48:53

THE COURT: Sustain as to leading.

239 48:55

MS. CALNAN: Okay.

240 48:58

MS. CALNAN: How often have you seen Mr. Depp drunk?

241 49:07

TARA ROBERTS: I wouldn't know his tolerance for alcohol. I haven't seen him passed-out drunk or anything like that. So he drinks, but I haven't seen him passed-out drunk.

242 49:22

MS. CALNAN: Thank you, Ms. Roberts. Nothing further.

243 49:22

THE COURT: Allright.

244

THE COURT: Cross-examination.

245 49:23

MS. BREDEHOFT: Thank you, Your Honor.

246

[SECTION HEADER]: EXAMINATION BY COUNSEL FOR THE DEFENDANT AND BY MS. BREDEHOFT:

247 49:29

MS. BREDEHOFT: Ms. Roberts, the salary you receive for managing the Bahama island is approximately $10,000 a month, correct?

248 49:40

TARA ROBERTS: Correct.

249 49:40

MS. BREDEHOFT: Okay. And so that comes out to 120,000 a year?

250 49:47

TARA ROBERTS: Correct.

251 49:48

MS. BREDEHOFT: Okay. And you --

252 49:48
253 49:49

MS. BREDEHOFT: And you've been receiving that salary for many years, correct?

254 49:55

TARA ROBERTS: Correct.

255 49:55

MS. BREDEHOFT: Correct. In fact I think you got a raise to $10,010 in 2018.

256 50:03

MS. BREDEHOFT: Do you remember that?

257 50:07

TARA ROBERTS: No. I don't know the exact number, but I know I get that a month.

258 50:11

MS. BREDEHOFT: Okay. And that's in addition to all of the expenses, correct, for running the island?

259 50:19

TARA ROBERTS: The expenses?

260 50:20

MS. BREDEHOFT: Of running the island.

261 50:25

TARA ROBERTS: I get a salary every month. I'm not sure what you're asking me.

262 50:30

MS. BREDEHOFT: So the other people that are on the island, to the extent they work, they get a different salary, right?

263 50:37
264 50:37

MS. BREDEHOFT: Okay. And all of the expenses you have -- you talked about what you have to do to provision the island and everything else and run it -- all of those expenses are paid separately, correct?

265 50:50

TARA ROBERTS: Correct.

266 50:50

MS. BREDEHOFT: Okay. And you said you've been managing this island for 15 years for Mr. Depp; is that correct?

267 50:58

TARA ROBERTS: Approximately, yes.

268 50:59

MS. BREDEHOFT: All right. Now, let's talk for a moment about those two videos that you testified to were part of the house.

269 51:08

MS. BREDEHOFT: The first video was missing both the closet and the bathroom, correct?

270 51:20

TARA ROBERTS: I don't remember. I would have to look at it again.

271 51:23

MS. BREDEHOFT: All right. And the second --

272 51:25

TARA ROBERTS: Sorry. Go ahead.

273 51:27

MS. BREDEHOFT: Go ahead. I'm sorry. You didn't come ! 14 through. Go ahead.

274 51:30

TARA ROBERTS: No, I'm sorry. I think in the first video, the beads were the closet, and then there was the bathroom next to the closet.

275 51:36

MS. BREDEHOFT: Okay. That was the --

276 51:37

TARA ROBERTS: Is that what you asked me?

277 51:38

MS. BREDEHOFT: That was the second video.

278 51:41

TARA ROBERTS: Oh, sorry.

279 51:41

MS. BREDEHOFT: Do you know who took those videos?

280 51:46

TARA ROBERTS: Oh, I did.

281 51:47

MS. BREDEHOFT: Okay. When did you take those videos?

282 51:55

TARA ROBERTS: Oh, it would have to be - I'm not sure, a couple years ago, maybe longer. I'm not Is sure.

283 52:03

MS. BREDEHOFT: Okay. Did you take those videos for the U.K. trial?

284 52:12

TARA ROBERTS: I don't recall if it was for that.

285 52:14

MS. BREDEHOFT: All right. Is there a reason that the closet and the bathroom were left out of the first video?

286 52:26

TARA ROBERTS: No. I- no. I stood in the house and did a circle-around of the house.

287 52:33

MS. BREDEHOFT: Okay. Who asked you to make that ! I video?

288 52:40

MS. BREDEHOFT: I'm not sure. I'm not sure. Was it Mr. Waldman, Adam Waldman?

289 52:48

TARA ROBERTS: I - I don't - I'm not sure. I don't know.

290 52:51

TARA ROBERTS: I can't. Can't recall? I'm not sure who asked me. No, I

291 52:55

MS. BREDEHOFT: Now, the second video, that shows the closet and then there's a door there.

292 53:00

MS. BREDEHOFT: Would you agree that door opens up into a bathroom?

293 53:07

TARA ROBERTS: Next to the closet, yes.

294 53:09

MS. BREDEHOFT: Okay. And we don't have a video of the bathroom, correct?

295 53:17

TARA ROBERTS: I don't believe there was a video for the bathroom IO

296 53:19

MS. BREDEHOFT: And no one asked you to make a video of the bathroom, correct?

297 53:24

MS. CALNAN: Objection, relevance.

298 53:26

THE COURT: I'll overrule it.

299 53:29

THE COURT: Go ahead.

300 53:32

MS. BREDEHOFT: Correct?

301 53:35

TARA ROBERTS: I'm sorry. I'm not sure if anybody asked me - I don't believe I videotaped the bathroom

302 53:40

MS. BREDEHOFT: And my question was "And no one asked you to videotape the bathroom, correct?"

303 53:47

TARA ROBERTS: Correct.

304 53:48

MS. BREDEHOFT: Okay. Now, let's talk for a moment I about the logistics of the island.

305 53:54

MS. BREDEHOFT: So, Mr. Depp's house, we've seen the inside of, and you said that the cafe was a 30-second walk, I think you said. How many yards?

306 54:07

TARA ROBERTS: Yeah. I don't know. I walk it. It's just outside his house, through the parking lot, and a walkway to the cafe.

307 54:16
308 54:17

TARA ROBERTS: I don't know.

309 54:17

MS. BREDEHOFT: Okay. And the cafe is where Mr. Depp would regularly have his meals, correct?

310 54:26

TARA ROBERTS: Right. All the guests would have their meals there.

311 54:28

MS. BREDEHOFT: Okay. Including Mr. Depp and Ms. Heard if she was there, and their children, correct?

312 54:34

TARA ROBERTS: Correct.

313 54:34
314 54:36
315 54:36

MS. BREDEHOFT: And then you were located on the other side of the island, correct? That's where you stayed?

316 54:45

TARA ROBERTS: Or I stay in the middle of the island,

317 54:47

MS. BREDEHOFT: Okay. How far away is that from the cafe and the house?

318 54:52

MS. CALNAN: Objection. Compound.

319 54:54

THE COURT: I'll sustain the objection.

320 54:56

MS. BREDEHOFT: How far away is it from the house?

321 55:01

TARA ROBERTS: Where I stay?

322 55:04
323 55:06

TARA ROBERTS: Probably a three-minute golf cart ride, five-minute walk.

324 55:11

MS. BREDEHOFT: Okay. And then when other guests come, I think you were talking about tents. Do they stay in tents?

325 55:21

TARA ROBERTS: No. The tents were - the tents were erected for the wedding, and then they were dismantled. And sometimes we would erect them if we were asked to just in case somebody wanted to stay there. But people didn't stay in the tents; they stayed in the buildings here.

326 55:38

MS. BREDEHOFT: Okay. So how much accommodation can you handle in the buildings for other guests? I'm not talking about the house, Mr. Depp's house; I've seen that. But how many people can actually be accommodated in the buildings?

327 55:58

TARA ROBERTS: We have a two-bedroom yurt on Brando Beach, we have a beach house which has a bed in it, and then we have what we call a round house which has a bed in it as well.

328 56:17

MS. BREDEHOFT: Okay. Now, when Mr. Depp and Ms. Heard were visiting, whether they had the children there or not, typically, would you bring the meals to the cafe for each of the meals?

329 56:37

TARA ROBERTS: Sometimes I would take them to the house depending on where they wanted to eat.

330 56:42

MS. BREDEHOFT: All right. And then, typically, would you join them for the meal? Or would you leave the meal and then come back and clean up afterwards?

331 56:49

MS. CALNAN: Objection. Compound.

332 56:51

THE COURT: All right. I'll sustain the objection.

333 56:53

MS. BREDEHOFT: All right. We'll take that one at a time.

334 56:56

MS. BREDEHOFT: Typically would you bring the meals to them?

335 57:00

TARA ROBERTS: Myself or one of the other workers here would take the meals.

336 57:05

MS. BREDEHOFT: Okay. How often was it you that would take them?

337 57:18

TARA ROBERTS: How often? Maybe every other day, every day. It depended on how -- if people were eating in their buildings or eating together.

338 57:24

MS. BREDEHOFT: All right. And would you stay and eat IO the meal with them? Or would you leave?

339 57:30

TARA ROBERTS: If we were invited for dinner, we would all eat together. Usually we would take the food to the places and leave.

340 57:38

MS. BREDEHOFT: Okay. And then would you be called to come pick them up? the evenings on our own and clean up and tum some of the lights off, and sometimes we would do it in

341 57:55

TARA ROBERTS: No. No. We would sometimes go back in the morning. It depended on what was happening.

342 57:56

MS. BREDEHOFT: Okay. So other than bringing the meals, and it could be you or somebody else, how often did you interact with Mr. Depp and Ms. Heard during the day when they were on the island?

343 58:12

TARA ROBERTS: On average, every day?

344 58:16

MS. BREDEHOFT: In what context other than delivering the meals and picking them up?

345 58:21

TARA ROBERTS: Oh. Just see if anything was needed, if they were all right, things like that, generally passing them if they were in the office or on the beach.

346 58:32

MS. BREDEHOFT: Now, would it be fair to say that you weren't spending 24/7 with them?

347 58:40

TARA ROBERTS: No. I didn't live with them, no.

348 58:42

MS. BREDEHOFT: Okay. And would it be fair to say that you don't know what they were doing during the times that you weren't passing them by or bringing meals?

349 58:55

TARA ROBERTS: Yes. Unless they were on the beach, then I would know.

350 58:59

MS. BREDEHOFT: Okay. So you wouldn't know what happened, what would be taking place within the house, for example, when you weren't there, correct?

351 59:07

TARA ROBERTS: Correct.

352 59:07

MS. BREDEHOFT: You wouldn't know whether Mr. Depp was taking drugs, correct?

353 59:12

TARA ROBERTS: Correct.

354 59:13

MS. BREDEHOFT: And you wouldn't know whether Mr. Depp was drinking, correct?

355 59:20

TARA ROBERTS: I would only know by cleaning up.

356 59:22

MS. BREDEHOFT: And you wouldn't know -- well, you wouldn't know from cleaning up necessarily whether it was Mr. Depp, Ms. Heard, or somebody else, would you?

357 59:26

MS. CALNAN: Objection, compound.

358 59:31

THE COURT: Overruled. I'll allow it. Go ahead.

359 59:35

MS. BREDEHOFT: Please continue.

360 59:40

TARA ROBERTS: Unless I would know what it was by what was in the garbage or left out. Who consumed or what was consumed, I would be able to know.

361 59:49

MS. BREDEHOFT: Okay. And you wouldn't know what arguments, if there were any, were taking place in that house behind closed doors, right?

362 59:58

TARA ROBERTS: Correct.

363 59:59

MS. BREDEHOFT: And you wouldn't know whether there was I I any kind of physical abuse that was taking place behind those closed doors, correct?

364 1:00:09

TARA ROBERTS: I wouldn't know, correct.

365 1:00:12

MS. BREDEHOFT: Okay. Now, let me just take you for a moment to the December 2015 time frame.

366 1:00:20

MS. BREDEHOFT: How much advance notice are you typically given for when Mr. Depp and his entourage are going to arrive and for how long they're going to stay?

367 1:00:33

MS. CALNAN: Objection. Compound.

368 1:00:35

THE COURT: All right. I'll sustain the objection.

369 1:00:38

MS. BREDEHOFT: All right. Let's break it down.

370 1:00:40

MS. BREDEHOFT: How much notice are you given when Mr. Depp and his entourage are coming?

371 1:00:48

TARA ROBERTS: It varies. Sometimes it's a couple It 7 days; sometimes it's a couple weeks.

372 1:00:53

MS. BREDEHOFT: So how much notice were you given in December of 2015 to who would be coming for Christmas on the Bahama island?

373 1:01:04

TARA ROBERTS: I believe sometime in November -

374 1:01:08
375 1:01:08

TARA ROBERTS: For that trip.

376 1:01:11

MS. BREDEHOFT: All right. And in November, how many people were you told were coming for Christmas on the island?

377 1:01:24

TARA ROBERTS: I don't recall how many. I don't recall how many people.

378 1:01:26

MS. BREDEHOFT: It was a lot more than Amber, Johnny, Lily-Rose, Jack, and Lily-Rose's boyfriend, wasn't it?

379 1:01:35

TARA ROBERTS: Yes, it was.

380 1:01:36

MS. BREDEHOFT: In fact, it was Amber's parents, correct?

381 1:01:41

TARA ROBERTS: I believe so.

382 1:01:42

MS. BREDEHOFT: And it was Rocky Pennington and Josh Drew, correct?

383 1:01:49

TARA ROBERTS: I believe they were on the list

384 1:01:51

MS. BREDEHOFT: And Rocky Pennington's parents?

385 1:01:59

TARA ROBERTS: Yes. I believe they were on the list

386 1:02:01

MS. BREDEHOFT: Do you recall them canceling?

387 1:02:04

MS. CALNAN: Objection, hearsay.

388 1:02:07

TARA ROBERTS: I recall -

389 1:02:10

MS. BREDEHOFT: How is that hearsay?

390 1:02:13

THE COURT: I'll overrule the objection. Go ahead.

391 1:02:17

TARA ROBERTS: I recall there was a change, to the guests.

392 1:02:26

MS. BREDEHOFT: When did you learn of that?

393 1:02:34

TARA ROBERTS: I don't recall. Maybe a couple weeks after, maybe beginning of December, maybe, middle of December, I'm not sure.

394 1:02:40

MS. BREDEHOFT: Do you recall if it was after December 15?

395 1:02:48

TARA ROBERTS: I don't recall.

396 1:02:49

MS. BREDEHOFT: Did you think that was a little strange? That here these people were going to be there at Christmas --

397 1:02:52

MS. CALNAN: Objection.

398 1:02:54

MS. BREDEHOFT: On the island, and suddenly they cancel?

399 1:02:58

MS. CALNAN: Objection. Relevance.

400 1:02:59

MS. BREDEHOFT: I think it's highly relevant.

401 1:03:00

THE COURT: I'll sustain the objection.

402 1:03:02

THE COURT: Next question.

403 1:03:03

MS. BREDEHOFT: What, if anything, were you told about why they canceled? I;

404 1:03:08

MS. CALNAN: Objection. Hearsay.

405 1:03:10

MS. BREDEHOFT: Party opponent admission.

406 1:03:12

THE COURT: Lay the foundation.

407 1:03:14
408 1:03:14

MS. BREDEHOFT: Who told you that Amber's parents, her best friend and fiance, and her best friend's parents were suddenly canceling coming for Christmas on the island?

409 1:03:25

MS. CALNAN: Objection. Compound.

410 1:03:28

THE COURT: I'll allow that. Go ahead.

411 1:03:32

TARA ROBERTS: I don't know who told me, but I did receive information that they weren't coming and there were other - somebody else was coming instead.

412 1:03:46

MS. BREDEHOFT: And who was that "somebody else coming I instead"?

413 1:03:51

TARA ROBERTS: It would be Alice and Greg and the I children and the nanny.

414 1:03:55

MS. BREDEHOFT: And they were coming later, right?

415 1:03:59

TARA ROBERTS: They would be joining, I think were the words.

416 1:04:03

MS. BREDEHOFT: Okay. So on the December trip, you testified about a few arguments between Amber and Johnny, right?

417 1:04:14

MS. BREDEHOFT: Do you recall that testimony?

418 1:04:17

TARA ROBERTS: Yes, I do.

419 1:04:19

MS. BREDEHOFT: Okay. You weren't present when Johnny sustained the gash on bis nose, correct?

420 1:04:27

TARA ROBERTS: I wasn't there, no.

421 1:04:29

MS. BREDEHOFT: Okay. And you weren't present when the 112 mess was made through the paints that you've described, correct?

422 1:04:39
423 1:04:39

MS. BREDEHOFT: And so you don't know whether there had been a physical altercation and -- that led to throwing a paint can to try to slow down Johnny, right?

424 1:04:58

TARA ROBERTS: No. I just heard yelling in the house.

425 1:05:01

MS. BREDEHOFT: Okay. But that yelling in the house wasn't necessarily the same time, was it? You don't know, do you?

426 1:05:10

TARA ROBERTS: No. It was all in the same time. Okay, no.

427 1:05:15

MS. BREDEHOFT: Okay. Now, let's talk about the summer of 2013.

428 1:05:23

MS. BREDEHOFT: Are you aware of that Paul Bettany claims he's never met Amber?

429 1:05:28

MS. CALNAN: Objection. Relevance.

430 1:05:29

THE COURT: What's the relevance?

431 1:05:29

MS. CALNAN: And calls for hearsay.

432 1:05:31

MS. BREDEHOFT: She testified that he was there on the island with her.

433 1:05:32

MS. CALNAN: And calls for hearsay.

434 1:05:34

MS. BREDEHOFT: I can ask the question, see what she says.

435 1:05:36

THE COURT: All right. I'll allow the question. Go ahead.

436 1:05:41

TARA ROBERTS: Can you repeat it?

437 1:05:42

MS. BREDEHOFT: Are you aware of that Paul Bettany has said that he never met Amber Heard?

438 1:05:48

TARA ROBERTS: No, I'm unaware.

439 1:05:48

MS. BREDEHOFT: All right.

440 1:05:49

TARA ROBERTS: I didn't know that.

441 1:05:50

MS. BREDEHOFT: Well, let's stay on the summer of 2013, if we can. Do you have a recollection of Amber and Johnny, Lily-Rose, and Jack taking one final trip on the yacht that Johnny was going to be selling to JK Rowling?

442 1:06:13

TARA ROBERTS: I don't know what year that was. I don't know what year that was, but I do remember the yacht being sold.

443 1:06:18

MS. BREDEHOFT: If I tell you it was July of 2013, does that help refresh your recollection, July 9?

444 1:06:29

TARA ROBERTS: Yeah, I -

445 1:06:31

MS. BREDEHOFT: All right. Now --

446 1:06:33

TARA ROBERTS: I just know the yacht was sold.

447 1:06:35

MS. BREDEHOFT: And you made arrangements, did you not, for a captain to captain the yacht and for them to go out on the yacht?

448 1:06:46

TARA ROBERTS: No. I didn't have any responsibility for the yacht and the crew on the yacht.

449 1:06:51

MS. BREDEHOFT: Okay. Do you have a recollection of being called because Lily-Rose and Jack were upset, and they wanted to leave the yacht and have a helicopter take them away?

450 1:07:04

MS. CALNAN: Objection. Hearsay and compound.

451 1:07:05

MS. BREDEHOFT: I'm asking if she has a recollection of this.

452 1:07:08

THE COURT: I'll allow the question.

453 1:07:11

TARA ROBERTS: Can you ask me it again?

454 1:07:12

MS. BREDEHOFT: Do you have a recollection of Lily-Rose and Jack being upset on the yacht and wanting to leave it immediately so you managed for a IO helicopter to come in to fly them away with Amber?

455 1:07:26

MS. CALNAN: Objection. Compound.

456 1:07:29

THE COURT: I'll allow it. Please answer.

457 1:07:35

TARA ROBERTS: I don't know if Lily-Rose and Jack were upset. I do know that I did arrange for transportation off the island at the time.

458 1:07:49

MS. BREDEHOFT: And, in fact, Amber went with Lily-Rose, correct?

459 1:07:55

TARA ROBERTS: It was Amber and her friend and Lily-Rose.

460 1:07:58

MS. BREDEHOFT: Okay. And Jack decided at the last minute to stay back, correct?

461 1:08:04

TARA ROBERTS: I don't know if he decided last minute. He stayed.

462 1:08:06

MS. BREDEHOFT: Okay. Do you recall Lily-Rose telling you that she was upset because her father was drinking and trying to hide it from him -- from her?

463 1:08:15

MS. CALNAN: Objection. Hearsay.

464 1:08:16

MS. BREDEHOFT: I'm asking whether she has -- ...

465 1:08:18

THE COURT: I'll sustain the objection.

466 1:08:20

MS. BREDEHOFT: Okay. Then I'll ask I the next one.

467 1:08:23

MS. BREDEHOFT: Do you recall Mr. Depp passing out in I the sand face first?

468 1:08:32

TARA ROBERTS: I recall that he was passed out on the beach. He was - yeah, he was out on the beach, yes.

469 1:08:38

MS. BREDEHOFT: Okay. And do you recall Jack calling you because he was concerned?

470 1:08:43

MS. CALNAN: Objection. Hearsay.

471 1:08:44

MS. BREDEHOFT: That's just asking if he called. I haven't asked what he said.

472 1:08:47

THE COURT: You did. I'll sustain the objection.

473 1:08:51

MS. BREDEHOFT: Do you have a recollection of Jack being present when Mr. Depp was passed out face first in the sand?

474 1:09:02
475 1:09:03

MS. BREDEHOFT: And do you have a recollection of Jack being upset?

476 1:09:11

TARA ROBERTS: I don't have a recollection of him being upset

477 1:09:15

MS. BREDEHOFT: Do you have a recollection of him being happy about it?

478 1:09:20

TARA ROBERTS: I - no. I didn't speak with Jack about it.

479 1:09:27

MS. BREDEHOFT: Okay. But you recall that Mr. Depp was passed out face first in the sand, correct?

480 1:09:31

MS. CALNAN: Objection. Asked and answered.

481 1:09:32

THE COURT: I'll sustain the objection.

482 1:09:34

THE COURT: Next question.

483 1:09:35

MS. BREDEHOFT: All right. Thank you.

484 1:09:37

MS. BREDEHOFT: Let's talk about makeup for a moment. So you don't know what type of makeup regimen Amber uses every day, correct?

485 1:09:51

TARA ROBERTS: Correct.

486 1:09:51

MS. BREDEHOFT: Okay. And, in fact, you don't know, you said at one point you're not sure, but it's a natural look.

487 1:09:57

MS. BREDEHOFT: Do you recall that?

488 1:10:00

TARA ROBERTS: Yes, I do.

489 1:10:01

MS. BREDEHOFT: Okay. And would you agree that there O are a number of different types of makeup you can use that would still give you a natural look?

490 1:10:12

MS. CALNAN: Objection. Calls for speculation.

491 1:10:14

THE COURT: I'll allow it.

492 1:10:17

TARA ROBERTS: I'm guessing there is, yes.

493 1:10:20

MS. BREDEHOFT: Okay. And there's sun in the Bahamas, right?

494 1:10:27

TARA ROBERTS: Most of the time.

495 1:10:28

MS. BREDEHOFT: Do you know what Amber wears for sunscreen?

496 1:10:35

TARA ROBERTS: I think it was - at one point I had a brand, Shiseido, or something like that that was I on the island, that we provided.

497 1:10:44

MS. BREDEHOFT: And do you know whether Amber brought her own as well?

498 1:10:50

TARA ROBERTS: I don't know.

499 1:10:51

MS. BREDEHOFT: Do you know whether Amber had a skin condition?

500 1:10:57

TARA ROBERTS: I wasn't told.

501 1:11:00

MS. BREDEHOFT: Okay. But I take it you didn't ask.

502 1:11:05

TARA ROBERTS: No. I wouldn't have asked if somebody O had a skin condition.

503 1:11:09

MS. BREDEHOFT: Okay. The wedding, the wedding was planned at sunset, correct?

504 1:11:21

TARA ROBERTS: Correct.

505 1:11:21

MS. BREDEHOFT: And, in fact, it went forward at sunset, correct?

506 1:11:27

TARA ROBERTS: It went earlier. It was earlier than the sunset.

507 1:11:32

MS. BREDEHOFT: So your recollection is that there's no sunset pictures at the wedding?

508 1:11:47

TARA ROBERTS: I mean, there was - yeah, there was sunset pictures.

509 1:11:51

MS. BREDEHOFT: Okay. So last couple questions. The makeup or not makeup, you were asked whether you observed any injuries on Amber in the December 2015 time frame. Do you believe Amber would cover up bruises to hide them from the kids?

510 1:12:14

MS. CALNAN: Objection. Calls for speculation.

511 1:12:16

THE COURT: I'll sustain it.

512 1:12:18

MS. BREDEHOFT: Do you have any understanding, based on l l O your know ledge of Amber, whether she would try to cover up any bruises or cuts --

513 1:12:26

MS. CALNAN: Same objection.

514 1:12:27

THE COURT: I'll sustain the objection.

515 1:12:31

MS. BREDEHOFT: To keep them from the kids? You said that you believed that Amber wasn't wearing much makeup, but you said she participated in a photo shoot in December 2015. Do you recall that?

516 1:12:44

TARA ROBERTS: Yes, I do.

517 1:12:45

MS. BREDEHOFT: Do you know whether Amber was wearing any makeup for a photo shoot?

518 1:12:51

TARA ROBERTS: I'm not sure. The part that I saw, she as in and out of the water.

519 1:12:56

MS. BREDEHOFT: Do you know whether Amber would want to show bruises or cuts in a photo shoot?

520 1:13:01

MS. CALNAN: Objection Calls fur speculation

521 1:13:03

THE COURT: I'll sustain the objection

522 1:13:04

MS. BREDEHOFT: I have no further questions. Thank you

523 1:13:06

THE COURT: All right Redirect

524

[SECTION HEADER]: EXAMINATION BY COUNSEL FOR THE PLAINTIFF AND BY MS. CALNAN:

525 1:13:18

MS. CALNAN: Ms. Roberts, how many times have you seen Mr. Depp consume drugs?

526 1:13:21

MS. BREDEHOFT: Objection Leading.

527 1:13:22

THE COURT: All right Sustained.

528 1:13:29

MS. CALNAN: Ms. Bredehoft asked you about Mr. Depp passed out on the beach. How would you describe Mr. Depp when you saw him on the beach?

529 1:13:39

TARA ROBERTS: He was passed out I picked him up and brushed him off, and he sat- I left him underneath, I believe in a hammock. And I believe he had fallen asleep or he was asleep, and the hammock had overturned. And I know I picked him up and brushed him off and left him on the beach with Jack.

530 1:14:07

MS. CALNAN: Okay. No further questions.

531 1:14:08

MS. CALNAN: Thank you, Ms. Roberts.

532 1:14:10

THE COURT: Okay. Subject to recall? Ms. Roberts.

533 1:14:12

MS. CALNAN: Yes, potentially.

534 1:14:15

THE COURT: All right. Ms. Roberts, since you're subject to recall, do not discuss your testimony with anybody and do not watch anything about this case, okay, ma'am?

535 1:14:23

TARA ROBERTS: Okay. Thank you very much.