Heard's witness statement

I, Amber Heard, will say as follows:

1. I am an actor, model and activist.
2. The facts and matters set out in this statement are within my own knowledge unless otherwise stated, and I believe them to be true. Where I refer to information supplied by others, a source of the information is identified. Facts and matters derived from these other sources are true to the best of my knowledge and belief. I make this witness statement in support of the Defendants’ defence of these proceedings.
3. From 2011 to 2016, I was in a relationship with Johnny Depp. We were married in 2015 and the divorce was finalised in 2017. Although I am not a party to this present claim, I should say that in 2019 Johnny sued me for defamation based on an article I wrote for an American newspaper. At the time of signing this statement that US case he brought against me is ongoing.
4. Johnny has said he was never violent or abusive towards me during our relationship. That is not true. He was both physically and verbally abusive. The physical abuse and the worst of the verbal abuse would usually happen when he was drunk or high on drugs, which was often. Much of the time he had difficultly recalling what he had done once he had slept it off.
5. The physical abuse included punching, slapping, kicking, head-butting and choking me, as well as throwing me into things, pulling me by my hair, and shoving me or pushing me to the ground. He threw things at me, especially glass bottles. He was always antagonised by shows of will, like me standing up after he had knocked me down. Often, especially earlier in the relationship, I wouldn’t even block the blows; I would just freeze and disassociate.
6. The verbal abuse included screaming, swearing and threatening me; but it also included what I would call extremely controlling and intimidating behaviour. Having had time to reflect on things, I recognise that this sort of intimidation, isolation, and control is also abusive.
7. All of the abuse contributed to a severe decline in my mental and physical health while I was with him.
8. As I talk about in this statement, some incidents were so severe that I was afraid he was going to kill me, either intentionally or just by losing control and going too far. He explicitly threatened to kill me many times, especially later in our relationship.
9. One thing that is important to know about Johnny at the outset is that he has a unique ability to use his charisma to convey a certain impression of reality. He is very good at manipulating people. With me, at least early in our relationship, he was able to express contrition after acts of violence. He would blame all his actions on a self-created third party instead of himself, which he often called “the monster”. He would speak about it as if it was another person or personality and not him doing all these things. I started to do so as well, referring to “the monster” to describe him during the worst periods of his violent and abusive behaviour, especially the violent incidents that took place while he was abusing drugs and alcohol.
10. Johnny attacked me a lot of times, on many different occasions. I will address the incidents that I understand are particularly at issue in these proceedings to the best that I can remember. Some of these events took place quite a few years ago and were extremely distressing, and recounting them is in itself very difficult and upsetting for me. There may be times where it is difficult to recall, these years later, the exact sequence within an incident of violence or abuse, some of which lasted for hours or even days. I will describe them as best I can and will try to be clear about what I can and can’t remember.

### Meeting Johnny and the early days of our relationship

2. Johnny and I met in 2009 on the set of a film, The Rum Diary. He pursued me romantically during filming, but I was in a relationship with someone else (Tasya van Ree) so nothing happened. But I liked him: I thought he was charismatic and interesting. We would hang out sometimes with the director, just drinking wine and talking. We had a lot of things in common, like blues music – I love blues. After that shoot, I didn’t hear from him directly, although he would send me gifts. One time, he tried to have a guitar delivered to my house. (I declined the delivery.)
3. The next time I saw Johnny was in 2011 on The Rum Diary press tour. Johnny’s publicist invited me to meet Johnny and the director in a hotel room for a drink. But when I turned up, this time it was just Johnny. By this time, I had broken up with Tasya. Johnny told me that his relationship with Vanessa Paradis was also over, but it wasn’t public yet. Our romantic relationship then began.
4. After the press tour and sometime late in 2011, Johnny invited me to spend a weekend at the Trump SoHo in New York. I booked a room and met him there. I remember I had to go out to run an errand, and when I came back, my bags were in his room. He said he had them moved and I would stay with him now. At the time, I thought it was kind of romantic.
5. The first night we drank red wine together late into the night. When Johnny and I were together, it was like we were the only people in the world. We loved the same music, and poetry, and art—we would just sit and talk for hours. He was engaging and intellectual and dark and funny. He knew so much about life, and he had lived longer and so much more than me. I was captivated. I had never been with someone like him.
6. In the mornings he would sleep late. He was always a night owl. But I remember waking up that next morning and he was drinking champagne, and a lot of it. I didn’t think so much of it at the time. It didn’t seem out of control, and back then he was always subdued, and sort of dark and intense when he was with me.
7. After that weekend I didn’t hear much from Johnny for a while. Then I got a message from him while I was on vacation in Spain and Morocco in early 2012. He said he wanted me to come meet him on his private island in the Bahamas. I cut my vacation short by a couple days and flew to Miami. I didn’t know what to expect, but it was exciting.
8. When I got to the island, it was beautiful. We would spend all day just reading and talking and sleeping— Johnny slept a lot in those days. He wasn’t drinking, and I remember he had gotten really into tea. In the evenings I drank red wine. I told him I was happy not to if that made things easier on him, but he said it was no problem. I remember he insisted on pouring my wine for me. That was where our relationship really began.
9. For a year or so after that, I didn’t see him drink, and as far as I could tell he was sober. These were the best times in our relationship. When we were together, it was magic. When Johnny wanted to be affectionate towards you, he was intensely affectionate, warm and charming. I called this “the warm glow”. When Johnny puts his attention on you, with all his intensity and darkness, it is unlike anything I’ve ever experienced. When I say he was dark, he had a violent and dark way of speaking: the way he talked about our relationship being “dead or alive” and telling me that death was the only way out of the relationship; the way he would describe what he wanted to do to me if I left him or hurt him (for example, carving my face up so no one else would want me); and in his language towards others who he didn’t like or was threatened by (detailing how he wanted to have someone tortured or how cheap and easy it would be to have someone knocked off). He could be very intense and dark. It was the polar opposite of “the warm glow”.
10. Johnny had told me he had split from his ex-wife Vanessa Paradis at that time, but that wasn’t public yet, and his kids didn’t know. I wanted to be respectful of that, particularly to protect the kids. He said we had to be careful about how the news got out because he was concerned that I would be blamed as the cause of the end of their relationship when, in fact, it was unrelated. He only allowed me to tell a few family members and close friends about our relationship, and in those days we could never be seen in public together. When I would go to his compound on Sweetzer Avenue in Los Angeles or meet him on set he would send a driver for me, and I would have to hide under a blanket in the car. When we were together it was always just the two of us. We would be at his compound, behind gates. It was like I was dating a king, with his level of fame and the way he lived. I learned then that I had to suspend all expectations of normalcy, but I later came to understand how this protected him, isolated me and facilitated unacceptable behaviour.
11. I remember visiting him in New Mexico when he was filming The Lone Ranger. That was the first time he told me that the reason he wasn’t drinking was that he had serious liver problems. It was at that point he told me that, just before our weekend in New York, he had been in a treatment facility. I started to think a little differently about those bottles of champagne.
12. When we were in New Mexico, I would mostly stay in his cabin. I couldn’t be photographed because Johnny said he didn’t want the world to blame me for his separation from Vanessa because it was not yet public that they had split up and his children didn’t yet know. He promised me that they had broken up, he just hadn’t made it public yet and I was trying to be respectful of how he wanted to handle it, especially for his children. This meant I was pretty much stuck in the house all day. I would read, and cook, and wait for him. I later came to see that this was how Johnny wanted things and he was incredibly benevolent when I was meeting those expectations.

### Johnny’s controlling and isolating behaviour

2. As our relationship progressed, I began to notice aspects of Johnny’s increasingly controlling behaviour. For example, I noticed he didn’t like me leaving for work. In part I think this had to do with the fact that it meant I had to travel and was away from him, which he didn’t like. But I also noticed that he never really acknowledged my work as an actress and made demeaning comments about actresses generally. From the beginning, it was clear he didn’t want me to take any job – or be an actress at all.
3. As time went on, it took a lot for me to be able to justify working at all. He didn’t like me doing anything that was not under his control. When I was away, I had to check in with him all the time. He would insist on me calling him as soon as I landed and he wanted to know my schedule, what hotel room I was in, who I was with. He would do things like get his staff to move my hotel room (organised by the production team of whichever film I was working on at the time) without asking me, telling me it was an upgrade as if it were a gift or a romantic gesture, but then would call the hotel room phone to monitor when I came and went. It is a little embarrassing for me to say, but in some ways, at first, I found this sort of thing romantic. But Johnny would get mad at me if I didn’t answer my phone or if I didn’t return his calls immediately. If he didn’t like the amount of time it took to respond, he would interrogate me furiously and obsessively and would not let it go, finding a reason to punish me. I would often be late for filming or press calls and events because I was on the phone trying to placate him. It was exhausting.
4. Johnny would create fights or problems before I was going to an audition or an acting class. Me being “ambitious” became a bad thing, as if it was synonymous with fame- seekers and women he considered to be distasteful, which made me feel like my profession was somehow embarrassing or shameful. Over time, I stopped taking so many jobs because it was just not worth the fight. He made all kinds of demeaning and derogatory comments about actresses (“two-bit whores”) and about me wanting to work as an actress.
5. I had to justify to him why I was doing any movie, and it was much worse if there was any kissing or a sex scene in it. He would insist every male actor was trying to sleep with me and/or that I had had an affair with them, that he’d spoken to people and knew all about it. He would try and catch me out by taking my phone or telling me someone had told him I was having an affair and act as if he had information proving it – when I really hadn’t. He accused me of having affairs with each of my co-stars, movie after movie: Eddie Redmayne, James Franco, Jim Sturgess, Kevin Costner, Liam Hemsworth, Billy-Bob Thornton, Channing Tatum; even women co-stars like Kelli Garner. He also accused me of having affairs with stars I auditioned with, like Leonardo DiCaprio. He would taunt me about it – especially when he was drunk or high – and had derogatory nicknames for every one of my male co-stars he considered a sexual threat. For example, Leonardo DiCaprio was “pumpkin-head”, Channing Tatum was “potato-head” and “Jim Turd Sturgess”.
6. He demanded to know about any romantic scene in a film and complained about how people can watch me “get fucked on camera”. He would even get himself copies of the scripts I was looking at, without asking me, to review them for himself. His rules got tighter every year we were together about what nudity or scenes were acceptable, wanting descriptions of every detail, every aspect of scenes and how they were covered, placing increasing restrictions on what I could and couldn’t do. I found myself making concessions and turning down work. My salary went down every year I was with him because of all the work I was missing. Meanwhile, he would insist I went on set with him when I wasn’t working. It was such a hassle to fight so I often went along.
7. If I had a scene that was even questionably romantic, I would always tell him in advance because I didn’t want information getting back to him and then him complaining that I didn’t tell him or I was hiding it. Because of the nature of the industry and Johnny’s stature, everyone wanted to be the one to tell Johnny a new piece of information. You never know how things will go with the particular scene, maybe not until you rehearse it on set, but I knew well enough at that point that what people would tell him would usually be the worst possible version of the truth. So, to get ahead of that, I would tell him the worst possible version of what would happen in the scene. But even that was never enough. It would never satiate his paranoia. Whatever I said, he’d accuse me of having this affair on screen with this sexy person who was younger than him. He would also call directors I was working with on set or after he saw the film cut to complain about nudity or how I was portrayed.
8. Johnny also frequently made reference to my ex-es. He was very jealous and would obsess about who I had slept with and been out with before him. He spoke possessively of me as “my woman” and made comments that he wished he had found me before I had slept with anyone else, joking he would have locked me away at 14.
9. He would obsess about how I dressed. If I wore a low-cut dress, then he would say things like “my girl is not gonna dress like a whore”. Over time, I stopped wearing revealing dresses for red carpet events: it just wasn’t worth the verbal and psychological abuse. He demeaned me anytime I tried to wear anything that could be seen as sexy, calling me a “whore”, “slut”, “fame-hungry” and “an attention whore”, but it got worse over time. He started saying things like “well I’m going to have to watch you get raped” and “I hope you get railed by a bunch of fucking fellas.” Sometimes he used racial epithets about the men I would be – or deserved to be – assaulted by, saying things like “a slimy Mexican” or “a fucking gang of big black mother fuckers are going to fuck you and get their big cock in you”. His verbal abuse was often sexualised, but it was also about my looks and related to my work, saying things like “no one will hire you when your tits and ass sag” or calling me “fat ass”. Sometimes I would react and give it back to him, calling him “old man” or “limp dick”. He would often refer to my verbal insults as “right hooks” or “sucker-punches”. For the most part, it wasn’t worth responding because it only antagonised him.
10. I was financially independent from Johnny and I didn’t want to concede to his – spoken or unspoken - terms of not working. My escape was my independence. He was always trying to give me a bank card, and he got mad at me because I didn’t want to take it. For him it was about “looking after my woman”. It seemed to me to be about him trying to make me dependent on him.
11. He once took my car without asking me – my Mustang – explaining that he was going to get it fixed for me as a gift. Once it was gone, he insisted that his drivers and handlers take me everywhere. He had tried to insist on this before, but after he took my car, it was harder to resist. I didn’t have a car for the next three and a half years. Over time it became obvious that this was one of the ways in which he would know about and control where I was. The same happened with security guards. He insisted on me having personal security, over my protests, and sent his own security guards with me, who would report back to him about where I was at all times.
12. Johnny didn’t like that I wanted to maintain my independence. I think he saw some of this as normal behaviour because he considers himself as an old-fashioned guy, a gentleman he would say; he takes a lot of pride in that and in wanting to “look after” his woman. This was part of that. I don’t think that he really respects women, he likes ones that validate his ego, sexy ones. He doesn’t like powerful women, and he saw me as one of those, especially towards the end. I remember describing it to a friend at the time as feeling like a wild horse in a cage; it was as if he wanted to break me.
13. If I was ever critical of him or did something that he perceived as a critical reaction then he would get very upset and find ways to punish me – he would stop speaking to me, or sometimes he would disappear and there would be periods of absence, or he would see other women. It was really intense behaviour and was so different from what I’d experienced in a relationship before. A common early example is where he said he couldn’t meet me one night but then would just turn up, much later, at my house anyway. I might say something like “Oh, I thought you weren’t coming”, and he would get hostile and angry and say, “so you don’t want me here, then fine – I’ll go...”. It was passive aggressive and I had to constantly reassure him.
14. I couldn’t set any boundaries – he would turn up at my house at any time of the day or night – both at the beginning of the relationship and then later when we lived together. He would tell me he was coming over and then not show up for two days. Other times he would text me and say he was on his way over or coming home and I would either have to wait for him or race home to be there, and then he might not show up for hours or sometimes days. But if I wasn’t there when he finally showed up, he would find ways to punish me. For example, once he said he was coming over at 2pm and then didn’t show up, so I texted him at 3am saying I was going to bed so had to lock my door. He didn’t reply but turned up after 3am when I was asleep and then later accused me of going out partying because I didn’t answer the door. It was impossible – I was always in trouble for something, which justified his ability to punish me somehow. And, I began to learn, he also used it as justification for a rage and needing to “twist off”, that is, going on a drug and alcohol binge.
15. Things got worse, although right up to the end I always thought – or hoped – that it would get better. I stayed as long as I did because I really wanted to help him get better and, perhaps naively, I thought that if I could help him overcome his addiction and substance abuse issues, then “the monster” would go away and the abuse and controlling behaviour would stop.

### Johnny’s drinking and drug use

2. The first time I really saw Johnny drink since we had started dating officially was in March 2013.
3. We had been in sporadic and irregular communication from around the summer of 2012, which is when I think he started using again. He would disappear for periods with explanation, long enough for me to think we had broken up. I didn’t get to see him for long periods, which was agonising for me because I was so in love, but he was so unreliable. We didn’t have Thanksgiving or Christmas together at the end of 2012, which also made me really sad. But I went to join him on the island in early 2013. After I left him on the island, he went out of contact again. I tried to get information from his assistants. I deduced that his friend Keith Richards of The Rolling Stones had flown out to the island and I pieced things together. Then he came back to LA, and things started to get bad. It was the beginning of the next three or so years.
4. He first started taking cocaine in front of me soon afterwards. I remember the first time I saw this too, because he took it from a small vintage bottle where he kept cocaine and he made a ceremony out of it. I thought it was a bit of a joke, which I think is how he meant it, but it soon became clear that it was turning into a habit, which, combined with drinking and use of other drugs, many of them on prescription, became a problem. He had a huge list of prescribed medications, and later had a specialised substance abuse doctor and full-time nurses around him. He was taking massive doses of the prescription drugs.
5. Johnny would almost always split or run out on things after he got drunk or high, smashed things up or hit me. He would leave me alone to deal with the consequences and by the time he returned, it had all been cleaned up by me or his staff. Because Johnny often didn’t remember what he had done, it was as if it hadn’t happened for him. I was sad that he would hurt me and leave me alone and I was frustrated that he wouldn’t stick around to face the reality of what he had done. At first, I would help clean up, but after a while I stopped doing that, and I asked his assistants and handlers to stop clearing up the mess so he could see it and face the consequences of what he was doing. Maybe then he would have seen things how they were. This is part of the reason I started taking photographs of the damage he did, because I wanted to show him what he had done.
6. Johnny lives in a state of weaponised victimhood. To hear him talk about his childhood or past relationships, he is always the victim. He functions off zero accountability to anyone and thrives off others who provide him with that. No one really gives him direct or honest feedback. It is very rare to see anyone — professionals, doctors, lawyers, film executives — say no to him. I tried to, but it didn’t go down well.
7. After his violent episodes, he would often come back with a sobriety coin from an alcoholics’ support group, a seven day or a month chip; or he would have a new sober coach, and he would say that this time it was the end of his drinking, and the end of the monster. But with it came complete denial. I couldn’t confront him about his alcohol and drug abuse because it was very triggering for him. He would get angry and call me “the moral police” and things like that. There was no actual accountability for his actions; the closest he got was that it was sometimes implied, in the form of a period of sobriety, or a new doctor or abstinence method.
8. Even though my dad — who is an alcoholic — could never get clean and sober (despite our family efforts to help him to do so), I thought I could fix Johnny. I thought he could get better and that he would, and I wanted that so badly right to the end. After violent episodes, his team would try to convince me to stay with him or to come back, often telling me he was sorry and would get clean for me. I think I stayed not only because I had hope of him getting clean and things changing, but also because of the responsibility I felt, being told I was the one to motivate him and help him to get clean.
9. Especially in the later part of our relationship I would speak to his doctors about his drinking and drug use and they said some of the behaviour was like drug induced psychosis: he couldn’t distinguish what was real. This was another reason I would take photos. I never imagined I would be sharing these as part of a court case; I really hoped he could get better and I thought I could help him get better.

### First violent incident, early 2013

2. I remember the first time he hit me so clearly. It changes your life forever.
3. It was a little over a year into the relationship. It was cold, so it might have been winter. We were at Johnny’s place in LA and we were sitting on the sofa. My understanding at that time was that he was sober and I didn’t see him do cocaine that evening, but looking back now I think he was starting to break from his sobriety around this time.
4. We were talking about one of his tattoos, which he had had altered from Winona (his ex-partner) to say “Wino”. I laughed at something he said but he must not have meant it as a joke and he hit me with an open hand across my cheek.
5. I was stunned. I had never had a man other than my dad hit me. I was staring at him in shock, finishing the laughter that had caused him to hit me, looking at him and trying to decipher what was going on. I didn’t know if it was some kind of joke. The way I was looking at him seemed to antagonise. Then he hit me a second time, harder.
6. I thought to myself, “I can’t believe this is happening to me, did he just hit me again?” I was still sitting next to him, looking at him. He was asking me, “are you fucking laughing, you think it’s so funny bitch?”. I didn’t know what to say. He tried to provoke an answer from me, saying “Eh?” I didn’t know what to say and it was if my silence provoked him further because he hit me again even harder. It felt like my eye popped out. Johnny wears a lot of rings, one on every finger. This third hit knocked me off balance and I fell to the floor.
7. I remember thinking “what am I going to do?”. I was in a frozen quiet space; just to get back up and look at him was so hard; I remember looking at the carpet and thinking it was dirty. I focussed on the carpet and I didn’t give him a reaction. I told myself that I had to get in the car and leave; I couldn’t validate it or make it real. I knew that I needed to get up, but I felt that then I would have to leave the house, which would mean leaving the relationship, and I wasn’t ready to do that. In so many ways, I was so in love. I wanted this to work and be okay.
8. I slowly got up and sat down on the sofa. I think by then he was apologising. I remember him being on his knees crying, because I remember thinking that it was unusual to see a man cry in front of me. He said he was sorry and that he would not do it again. He indicated to me that this sudden shift in temper used to happen but that it wouldn’t happen again. He pitched it to me that it was as if it is was another personality having done it and that he thought he had killed that other person, and that he had not come back before. This was the first time I heard him talk about this other person, “the monster”, as he called it. He said it was a sickness.
9. I left without saying a word. It was cold outside. I remember sitting in my Mustang and seeing my breath, but I remember that I didn’t feel cold at all.

### Painting incident, March 2013

2. In March 2013, I was living in my old house in LA. Johnny took issue with a painting that my ex-partner Tasya had painted, which I had hanging up. I know that Johnny has said in this claim that he politely asked me to remove the picture “as a courtesy”. That is not what happened. The picture had been up on the wall for a long time: Johnny had seen it many times and he had never said anything, but one day after he had been doing a lot of drugs it was suddenly a big problem for him.
3. As best as I can describe it, the painting was hanging in a vestibule or walkway area between my bedroom and the hallway. It was in a place on the wall that meant it would be behind the bedroom door, which was naturally almost always open.
4. Johnny was sparked off that day by cocaine, pills, weed, and booze; he was snorting lines of cocaine and drinking alone in my kitchen. He started arguing with me about the painting – I think it was in the evening – and it carried on over into the next day. I don’t know why he got so mad about the painting. It was really out of the blue; I didn’t have much familiarity with this kind of crazy behaviour at the time.
5. This was a whole ordeal of screaming and fighting that went on overnight and into the next day. At one point he tried to set the painting on fire with his lighter. I had to physically stop him from trying to light it up. He hit me in the face with the back of his hand and drew blood, some of which ended up on the wall. He had silver rings on – he always wore rings – and I think those might have been what drew the blood. I walked straight out of the room. I wanted him to be sorry and to snap out of it.
6. At another point during the ordeal he also verbally attacked me and accused me of having an affair with my ex-wife Tasya. I remember trying to walk away from him, just because I wanted to diffuse the situation, but this antagonised him. At various points he grabbed me hard, shook me and shoved me into a wall. I couldn’t calm him down – he was so angry and just wouldn’t let it go. He was drinking and doing cocaine. We barely slept.
7. He was supposed to have been on set to film a Keith Richards documentary, but he wouldn’t leave my house. Everyone was coming up with strategies to calm him down and get him to the set. At various points, I spoke with his handlers who were sitting in a car outside waiting for him. Everyone was trying various strategies to get him to where he needed to be. I remember speaking to his sister Christi on the phone, trying to get her to reason with him. I indicated to her that he was doing cocaine but she wasn’t very helpful, and seemed to suggest that I had been doing it with him, when I hadn’t been. I remember thinking that I just didn’t understand this dynamic. I was aware that people were really upset that he was delayed getting to the set and I was anxious to try to get him there.
8. Sometime in the afternoon Johnny said something about my sister Whitney, so she came over to try to help; she was a bit of a buddy to him at the time. Johnny could have a lot of animosity towards me whenever I questioned him about his drug and alcohol use: he would call me things like “nun” or “lesbian camp counsellor”. He did a lot of name calling, but he didn’t have those sorts of interactions with Whitney. I thought he might listen to her. He was in some kind of drug-fuelled mania and whatever I was doing or saying had not worked. He was getting progressively worse, more disconnected. He’d just held onto the feeling of whatever he was mad about.
9. I was learning enough at this time to realise that Johnny can get a narrative in his brain that he convinces himself is true or accepts is true regardless of whether it is or not. It’s important to try to keep him away from that state of mind, because he will latch onto the thing that he feels justifies his rage, whatever it is. It was important to try and stop the path from growing until it became a cemented street. Along the way I would have to try and figure out what he was really mad about, what exactly he was referencing. The painting is a good example of that. I told him, “you were fine with it here yesterday and the day before, so why are you upset this random day?” He didn’t have any answer; it was just one of those things that he would latch onto to justify being angry.
10. While Whitney was talking to him, everyone was still at the studio waiting for him for the documentary. He’d missed a whole day of working and left the entire crew – and Keith Richards – waiting for him all day. Eventually we got him to calm down enough to leave the house. We got in the car – myself, Whitney and Johnny.
11. We shared two small dogs at the time, Pistol and Boo. He took Boo and held her out of the window of the moving car, as some sort of joke or prank, while he himself was howling like a dog. It was so fucked up. I was scared that he could have dropped her, and I managed to lean across him and get her back in the car. I will never forget the way that everyone else in the car reacted – no one reacted. There was like a quiet alarm because no one wanted him to drop the dog, but no one reacted so as not to antagonise him which might make him do something even crazier. That was a really scary situation, everyone was trying to keep the energy down, without confronting him, to make sure he didn’t drop the dog.
12. When we got to the set, he walked in as if he had not kept anyone waiting. Everyone welcomed him as if nothing had happened – even though I knew people were really frustrated and pissed off that he hadn’t showed up all day. I remember being alarmed at the apparent lack of accountability: it was clear that no one was going to show him they were frustrated, let alone to call him out for what was clearly unacceptable behaviour. It scared me. I felt like I was all alone.
13. We had a lot of fights and arguments and he was high a lot. Johnny and I exchanged text messages after this incident where he mentioned a book called “Disco Bloodbath” and joked that it could have been about what had happened, calling it a “hideous moment” (Johnny and I called each other “Steve” and “Slim” respectively in each other’s phones). I exhibit a copy of this exchange at exhibit AH1 page 1.
14. This incident was unlike anything I had experienced with him up until that point. I didn’t realise that it was a sign of what was to come.

### Boston – LA flight, 24 May 2014

2. At this time, I was working on a film project called The Adderall Diaries in New York, where I played the love interest of James Franco’s character.
3. I told Johnny over the phone that I was about to film a romantic scene with James Franco. We had already discussed it in detail, as always, and he knew all about it anyway because I always had to tell him everything. I nervously told him because I was anticipating his reaction – he had a way of making me feel like I was doing something wrong, even when I wasn’t. He interrogated me and got angry, asking why I didn’t tell him earlier, that he couldn’t believe I told him on a day when he was working and upset his day. I knew why he was upset, and I was trying to prove to him that the scene wasn’t that bad or anything he was imagining. In fact, he had already known about the scene because we had talked about it before, but he was upset about it anyway and was upset that I hadn’t told him earlier about exactly when it was happening, and was upset that I told him as he was going on set to film himself – and hung up on me.
4. After he hung up, I think I ended up speaking to one of his assistants. He was filming in Boston at the time and when our breaks aligned we were supposed to be flying to LA together. Johnny was chartering a plane to pick me up in New York and I was to fly to meet him in Boston so we could fly home to LA together. After our fight on the phone, I asked his handlers if I should still come. I was scared of his reaction. But he still sent the plane, so I thought maybe he had calmed down or wanted to talk.
5. I took the plane from New York to Boston where it stopped to pick him up. I was waiting on the plane on the tarmac in Boston when I saw his car pull up. He didn’t come out for a long time, which is a sign he was using drugs. It’s one of the patterns. The car was on tarmac, I was on the plane, and all the handlers were milling round: Jerry Judge, Malcolm, and Nathan Holmes (who I was a bit more friendly with at the time). The car was blaring music. A long time went by – maybe an hour or more – and eventually Johnny got out. I saw immediately from his body language that he was stoned. I had been with him long enough to know what this was. He got on the plane and his eyes were black, he had clicked into another space. This was the monster.
6. I have seen that in this claim Johnny has presented a version of things that he was sitting there quietly sketching and I was the one upsetting him. That is not what happened on the plane.
7. Johnny sat in front of me on one of the seats opposite. I was in freeze mode. I could see he was mad and drunk and high on drugs. I started by trying not to provoke him – I knew there was nothing I could do to placate him. He was saying things like “get fucked on set, get fucked with fucking James Fucking Franco”; “at least you fucking liked it”; “I bet you slipped a tongue in there and you liked it”. He kept referring to my “pussy”, asking me if I was wet. I was so embarrassed that he would speak to me like this in front of other people (who included Keenan Wyatt (one of his oldest friends and his sister Christi’s partner), Stephen Deuters and Nathan Holmes (his assistants), Jerry Judge, Savannah McMillan, and a flight attendant), but I was just trying to keep things calm because there was no point in trying to placate him, and I just didn’t make eye contact and tried to ignore it.
8. I didn’t say anything, as I knew nothing would placate him. I was moving between seats and he was getting up and following me around; it was like a dance. When I moved seats, it provoked him. He started throwing ice cubes at me; throwing all kinds of things at me. When I got up from a chair, I got up slowly and calmly, I did not look away when he spoke. I just wanted to move to a safer seat, away from him, and do so without provoking him.
9. One time when I moved between seats he kicked one of the chairs so it would swivel round and hit me. It was the first time he had made contact with me in front of other people. He was taunting me and demanding I answer a question about how much I like getting off with James Franco on set. It was gross and I didn’t answer. I was looking at him and he was teasing and challenging me to answer, saying, “What you liked it?” and when I didn’t answer saying, “See, she liked it”. I just couldn’t believe he would treat me like this in front of other people – and I felt shame because I realised it was only unacceptable to me because other people were around. I tried to look out the window and I didn’t want to look at him.
10. He kept challenging me to answer, and at one point, when I didn’t, he gave me a slap in the face. I had been so careful to manage around him in the hope he wouldn’t hit me in front of others, but that was just broken. I couldn’t look at anyone, but I could feel them looking at me. I was mortified that people were seeing this. I remember being so ashamed. I was so mad at him. I went to sit by myself. He continued saying demeaning and degrading things like, “go-getter slut”; “whore”.
11. The atmosphere on the plane was tense throughout and he was verbally and physically abusive towards me, while drinking heavily until he crashed out in the bathroom. He demanded more alcohol and an oxygen tank from the flight attendants, which they gave him. He was sharing the oxygen tank with Keenan Wyatt, his sound assistant and a long-time friend. Johnny kept taunting me and trying to get my attention.
12. At one point, I got up to move elsewhere on the plane and he said, “are you fucking walking away from me?” and he kicked me hard in the back. I fell to my hands and knees, mortified. I wouldn’t look at him. He was screaming at me, taunting me, saying something like “James Franco fucker, fucking look at me”. He was still drinking heavily and kept on verbally insulting me, trying to get my attention.
13. He kept verbally abusing me, saying things like “when we land, I can call some black brothers who can fuck you if you’re so desperate for it”. I didn’t react, so he took off his boot and threw it at me. At some point he also threw a fork at me. He eventually went to the bathroom and passed out. No one said anything or reacted.
14. We landed and we called our own car so I didn’t have to get in his car. I was also concerned he would come to my place, so I stayed in a hotel, which had become a habit to avoid him when he was in this space. I was scared to go home and of what would happen if he showed up.
15. Soon after the incident, on 25 May, Johnny texted me to say: “Once again I find myself in a place of shame and regret. Of course, I am sorry. I really don’t know why, or what happened. But I will never do it again. I want to get better for you. And for me. I must. My illness somehow crept up and grabbed me. I can’t do it again. I can’t live like that again. And I know you can’t either. I must get better. And I will. For us both. Starting today. I love you. Again, I am so sorry. So sorry... I love you and feel so bad for letting you down...Yours”. I did not reply, and he texted me again later to say: “I see that understanding and forgiveness ain’t on the menu...”. I exhibit this at AH1 page 4.
16. The same day, Johnny’s assistant Stephen Deuters and I exchanged some text messages, which I exhibit at AH1 pages 2 to 3. I was worried about Johnny and wanted to check up on him. He referred to Johnny as being “sick” and “in some pain”, that “[h]e doesn’t remember much but we took him thru all that happened. He’s sorry. Very sorry”’; “He’s teary. He doesn’t want to be a fuck-up anymore - his words”; “He’s incredibly apologetic and knows that he has done wrong”. I was worried about Johnny but also angry about how he had treated me, and so I said to Stephen that Johnny obviously did not remember what he had done but, unfortunately, I did and that if someone was honest with Johnny then he would be appalled. Stephen replied: “It was disgusting. And he knows it. He was appalled. When I told him he kicked you, he cried.” I said that Johnny had done this sort of thing many times before, but I had always stayed, believing he would get better. Stephen replied, “I know. It’s hideous. But that is one side of the man that you fell in love with."
17. Around this time there were some messages between us which illustrate what I mentioned earlier about him trying to control my work. I talked about needing the money from this film part: I had adopted the practice of saying this because I had to justify doing the work because I needed the money. I had to give him a reason why I had to work because I knew it hurt him and I had to excuse to him why I was going to work. I said “I won’t do a anything that makes you feel pain or discomfort. You tell me what you want - and I’ll do it”, and that I had held off making a decision about it to take account of his feelings. He replied saying “[Y]ou want it! You’ve led them on!” and ”Were you hoping for my opinion on the James Franco piece??? I was hoping you didn’t stoop to that level [...]”. I exhibit these at AH1 pages 4 to 7. This is the sort of conversation we had regularly about my work.
18. After the incident on the plane, I remember thinking that was it; it was all too much and I had to leave. His team were reaching out to me apologising, saying he was sorry and that it had been a wake-up call so he was ready to get help, saying it was a critical juncture and that, if I left him, he would never get help. We had been talking for some time about him detoxing and getting medical assistance, and I was assured he was finally going to do it.
19. I had to go back to New York for work, but I was going to Al-Anon meetings twice a day when I could (a support group for friends and families of addicts). I read Dr Kipper’s book. I spoke with my friend iO Tillet Wright’s father, Seth Tillet, who had been an addict and who had recovered with his wife’s support. This all gave me hope. I thought I could help him get better.
20. In the interim, Johnny came to New York to win me back. I relented and began spending time with him in Boston where he was on set filming because I thought this might be the rock bottom he had to hit to get better. He had agreed to have treatment with Dr Kipper. I was told he was bipolar and manic depressive and that they needed to first stabilise his mental health issues to prepare him for treatment and detox. We had some quiet time in Boston together as he prepared to go to the island for this detox process.

### Bahamas, August 2014

2. In August of 2014, Johnny attempted to kick his addiction to prescription painkillers and other drugs. We were advised about and expected a rough withdrawal process and he wanted to at least do it in a beautiful place. Johnny insisted that I go with him and I was happy to go to help him recover once and for all. So we went to the Bahamas along with a nurse named Debbie Lloyd who was working with Johnny on his substance abuse issues in LA.
3. I had been aware of my dad’s attempts to detox and had observed him sweating and being uncomfortable, but I had never experienced anything like this.
4. I was scared. As his behaviour became crazier, I was told that these things are symptomatic of the detox and his existing mental health issues would be exacerbated. There were so many layers of justification for his behaviour. I was there wanting to help him get better, being told by people around him that I was the only one who could help him, I was isolated and alone with him.
5. The nurse, Debbie Lloyd, was staying on the other side of the island where the other houses were, but we were in constant walkie talkie contact (mobile coverage is terrible on the island). I was trapped with Johnny on my own. It was hell: Johnny was in a state of absolute mania at times, he went through intense periods of auditory and visual hallucinations. For example, at times he became convinced I had said or done something when I hadn’t. He was repeatedly verbally abusive to me and was sometimes physically violent. When I could, I would try to focus on my homework for a history course I was taking at the time. He was erratic and all over the place: in one moment he would ask for hugs, the next he would yell at me. It was really hard to manage, and I would report it all to Debbie.
6. At one point during the detox, I think it was on 17 August, he kicked and pushed me so that I fell on the ground and grabbed my hair and slapped me. He was in such a rage that he smashed a door so hard that it splintered.
7. It got so bad around this time that his substance abuse doctor, Dr David Kipper, had to be called to fly to the island and help. I exhibit this at AH1 pages 8 to 10 a text message exchange I had with Debbie which includes me saying: “...he’s flipping again. Just started screaming – he was so mad he pushed me and I asked him to get out. Don’t know what else to do..”; “He always works himself into rage without any provocation”. She said “I know it is rough right now. He is angry with everyone but mostly himself and he doesn’t know how to handle those emotions without his drugs. Stay as calm as you can.”
8. I understand that Johnny has said in this claim that I was keeping his medicine away from him while we were in the Bahamas, and so he was getting worse. This is simply not true. The whole reason I agreed to go there was to try to help him.
9. The trip was ultimately a failure. Sometime after Dr Kipper was flown in, I returned to LA on my own earlier than planned. It didn’t feel safe to go back to our place because I was concerned Johnny might just have shown up and I was afraid of that because it had been so crazy on the island, so I went to stay in a hotel for a few days. I was in open communication with Debbie.
10. Johnny wasn’t around much for the next couple of months, but towards the end of the year he was back – and things were bad. He was constantly starting arguments and he regularly turned violent.

### 17 December 2014

2. At AH1 pages 11 to 12, I exhibit a copy of a text message exchange that I had with Johnny sent me on 17 December 2014, where he was apologising to me after an incident of violence. I can’t remember what the incident involved. He said that he “couldn’t be more sorry”, that “rage” was “never the answer to any equation or occasion”; “I’m a fucking savage... Gotta lose that.... Gonna lose that!! The Devil is All Around, right...??”; “I am WELL AWARE that I SHOULD have been bigger than the moment...And, that it WILL NEVER again manifest in negative experiences”. This is an example of his effusive promises that it wouldn’t ever happen again.

### Tokyo, January 2015

2. Johnny had a premiere in Tokyo for a film he had done called Mortdecai. He was using drugs at the time, a lot of pills and probably other things in retrospect. But I couldn’t ask him about it as that was a trigger.
3. We were in a hotel room and I can’t remember what he was upset about, but it ended up with him in a rage about something, and he slapped me. It was really upsetting because it wasn’t even clear exactly what he was upset about. There was a tussle and he wrestled me to the floor. I was on the ground and I started weeping. He was screaming at me. I was sitting on the floor crying and I put my head in my hands. I don’t remember how it ended.
4. For a while after that things got a bit better. It was so up and down that it became just how things were – fights and a violent incident, followed by a period where he was better. I was almost relieved after a big fight because I knew there would be a period of calm. After these incidents of violence, he would say the monster was gone, but it always happened again. He would write notes declaring his love and making all of these effusive promises that it would never happen again, that he had killed the monster.

### Wedding, February 2015

2. Johnny and I got married in February 2015. We fought on our wedding night over his drug use. He had lost weight and he would disappear into the bathroom for long periods during the wedding. He was even more possessive than usual and he was just not making sense a lot of the time.
3. I tried to smile through it and entertain our guests. But I had never felt more lonely in my life.

### Australia, March 2015

2. I have seen Johnny’s comments in this claim that the incident in Australia was supposedly all about me losing my temper over him wanting a postnuptial agreement. This is not true. Johnny’s sister Christi had raised the idea of a prenup before our marriage, and I had repeatedly said I would sign whatever. I even hired a lawyer to draft one. But Johnny told me multiple times that he did not want a prenup, he said that if he ever saw a prenup he would “rip it up” and asked me repeatedly if I was sure that it was “[him] or the end”.
3. We did argue about the prenup in Australia, but it was not about having a prenup or postnup in principle; it was about Christi’s influence and the way the whole thing had been done. Christi had tried to convince Johnny not to marry me without a prenup and I had said this was fine and even had one prepared myself and sent it to them to consider, but no response came back and in the end we had got married without one. He was on a lot of drugs throughout the whole three-day incident, he was very paranoid and was not making sense, raising not just this issue – but a range of other issues in a completely incoherent manner. I said that we could call the lawyer and arrange a postnup if he wanted, and again I said that I would sign whatever. At one point later during this three-day ordeal he called his people. I heard him call his manager, his agent; he even called my lawyer, and shouted at her too. She later texted me because she was concerned that I was not safe.
4. He was making all kinds of nonsensical accusations about me. He did his usual thing of accusing me of having affairs with various co-stars like Eddie Redmayne and Billy-Bob Thornton. Then out of nowhere he would have these strange, paranoid hallucinations. I don’t know how else to describe it. For example, there would be a pause in the conversation, he would have some sort of hallucination and suddenly say “what about that guy you are fucking in New York you just told me about?”. I had no idea what he was talking about.
5. The best way I can describe what happened in Australia is that it was like a three-day hostage situation. We were due to be there for three days on our own, but it was only when I arrived that I realised I was trapped in this remote place without any means to leave and that Johnny had already been using and had a bag of drugs. I was in a remote house, at least twenty minutes from help; where I could not leave; was trapped and isolated with a violent person suffering from manic depression, bipolar disorder and a pattern of repeated, drug induced psychosis and violence, who was on a multiple day drug and alcohol binge. Over the course of those three days, there were extreme acts of psychological, physical, emotional and other forms of violence. It is the worst thing I have ever been through. I was left with an injured lip and nose and cuts on my arms.

#### Day one

2. I went to visit Johnny when him while he was filming Pirates. He was very thin, which is typically a sign that he has been using. I hadn’t seen him for some time because we had both been filming. When I got there, I wanted to connect with him but he just seemed to want to drink. At some point he took out a bag of MDMA (ecstasy), and I guess I had some sort of negative reaction to that. He said I was being “the moral police” and it was “not on the list” (of drugs we had agreed he was not supposed to take). I said something to him about losing weight. He said something to me about being “mouthy”. He pushed me into the fridge and slapped me. He grabbed a bottle of wine or booze and took a swig from it in front of me and, at some point, he took a handful of ecstasy.
3. I stomped off to go to the upstairs bedroom. He got in front of me and wouldn’t let me pass him. I tried to push past him, but he pushed me to the ground. I fell like a rag doll. I got back up and he said something like “You want to go? You want to fight, tough guy?” and he slapped me in the face. Eventually, I got away from him. I went upstairs to the bedroom, locked the door and barricaded myself in with furniture so I would be alerted if he tried to get in and tried to sleep.

#### Day two

2. The next day I came downstairs and he was still up and had music blaring. He was on the lower level, where there is a kitchen, a bar and a ping pong table – like a games room. I said to him I wanted to make us some food, to try and make peace with him. I thought I would feed him and hoped that he might then sleep. He had been up all night on ecstasy. I had got steaks out and turned the oven on. I was wearing a burgundy nightgown that Dr Kipper had given me as a wedding gift.
3. There was cocaine on the bar, so I knew he had been using. He was drinking Jack Daniels from the bottle and I saw the bag of pills. At this point there were only a few left. There had been ten or so in there, so I could tell he had taken a lot. He took some more in front of me and chased them down with red wine, which he was drinking straight out of a large bottle. I said something like “Johnny, did you really take all of those?”. I think I also said to him that he should not take it with all the medication he was on. He was reaching for a bottle and I tried to take it from him. He was verbally abusing me, saying “everything that my friends said about you is right”; “everyone hates you on set” and “you’ve changed, I don’t love you anymore”. It was really upsetting and hurtful – and I didn’t understand what I had done.
4. He grabbed me by the neck and shoved me against the fridge. I could smell the whisky on his breath. He said he could crush my neck and told me how easy it would be. It was chaotic. I remember glass breaking, he had me by the hair and hit and slapped me in the face. Johnny screamed at me and grabbed me by the wrist as I tried to leave the room, then violently dropped my arm and said something like “well, leave anyway”. I somehow managed to leave the room. I started packing a bag. He barged in and he kept screaming at me. Over the course of the day, he kept attacking me – he hit me, pushed me, choked me and spat in my face.
5. At some point I went back to the lower level because I wanted to try again to cook a meal and get things back to normal. He was still drinking booze from the bottle. He was so mad at me and I didn’t know why. His eyes were black. I told him to put it down and to stop. He became extremely mad, screaming at me “fuck you, I fucking hate you”. He offered me the bottle, “you want it?” and “what are you going to do?”. He was threatening me with the bottle of liquor. He provoked me to take it. I said “yeah”, and I took it and smashed it on the ground. This set him off. He picked up another bottle and threw it at the wall right next to me. I retreated into the bar area. He started throwing bottles that had liquid in them, full enough to break a window behind me. I felt the glass shatter behind me, but I was too scared to look. He was throwing full bottles hard at me, with real velocity and intent to hurt me. He was screaming at me “I fucking hate you”. There was broken glass around me and all around the room and I was really scared. I was screaming at him, pleading for him to stop. He put the broken bottle against me, screaming at me. I remember thinking I don’t want him to headbutt me. I was thinking that I needed to get out of striking distance because I worried he would break my nose – he clearly wasn’t in control of himself and I knew he could really hurt me in this state. I tried to run past him to get away and he grabbed me by the hair, hurled me around. I fell onto the ping pong table and it collapsed under me. He ended up on top of me.
6. Next I remember running toward the kitchen; I was trying to run or get out but there was no exit. I was cornered, trapped. He grabbed me by the neck and kept smashing my head against the fridge, saying “You fucking do this to me every time; you fucking did this; you fucking make me do this”. There was broken glass everywhere and my feet were getting cut. He had me up against the fridge and he grabbed the front of my gown and ripped it open, so at some point I was bare chested. I don’t remember what he was saying, but he was mocking me, touching my breasts. He ripped off the rest of the gown so I was naked. He grabbed me by my breasts and kept shoving me up against the fridge.
7. There was an old-fashioned, mint green and cream house phone mounted on the wall next to the fridge. At some point, he picked it up, smashing it against the wall next to me, right next to my face. He was smashing it so hard and so many times, that it was smashed to pieces.
8. I remember that the floor was wet, and my nightgown it was on the floor and it had got soaking wet. I did notice that. I also noticed blood on the floor.
9. Glass was broken everywhere – on the floor and the counter-top. At some point he pulled me around by my neck and pushed me down against the bar, I was against the bar, naked, bent over backwards, my back against the marble. He was pressing so hard on my neck I couldn’t breathe. I was trying to tell him that I couldn’t breathe. I remember thinking he was going to kill me in that moment. The floor was wet and I was slipping; I couldn’t get a purchase and I was kicking my feet trying to stand up, but nothing was catching. I was using my forearms to try to raise myself up and cutting myself on the broken glass on the counter. I remember pleading with Johnny saying he was hurting and cutting me and asked him to let me up. He ignored me, continuing to hit me with the back of one closed hand. He was screaming at me, over and over again, “you ruined my life, I hate you, I’m going to fucking kill you and I’ll fuck your corpse”. He said it so loud and over and over: “I am going to fucking kill you”. I really thought I might die.
10. I talk about the end of this incident in the confidential schedule annexed to my statement.
11. At some point I got out/ I had cut myself all over and I still have scars on the bottom of feet and on my arms from slipping on the glass. I took a picture of my arm which I exhibit at AH1 page 13.
12. I made it upstairs. At some point I was in the bathroom, throwing up repeatedly. I was retching; it was uncontrollable. I took sleeping pills that Dr Kipper had provided to put myself to sleep. I locked myself in my bedroom and managed to somehow sleep, it could have been for a long time. I slept very late.
13. Johnny’s account of his severed finger is also untrue. I would be very surprised if he remembers anything about the whole event, he was in such a state. I gather he has explained some of his actions as being in shock. I am not a doctor and I don’t know if he was in shock or not, but I was there and know he had drunk a huge amount and taken a lot of drugs, and he was completely out of his mind and out of control.

#### Day three

2. I came back downstairs and it was daytime. I had slept for a long time. Music was blaring but I didn’t see Johnny. Everything was broken and shattered. I noticed he had painted on a lampshade and on a sofa and on the wall and mirrors, all in red and dark colours. I saw something painted on the wall at the bottom of the stairs; it looked like a word but I didn’t understand it, at least at first. I later realised that the red was blood. At some point later I took some photographs which I exhibit at AH1 pages 14 to 17.
3. I was looking around for Johnny. I remember walking through the art space setup where I had been painting him a portrait for his birthday, but he wasn’t there. I found him in the office downstairs: he was there holding a Jack Daniels bottle with very little in it. I asked where he got it. His hand was covered in red, and there was black and blue paint everywhere – he had been writing on the walls and furniture. There was so much red on him; at first I thought it was my blood and I thought, had I bled that much? My feet and arms were very bloody. He held up his finger and said, “look what you made me do!”. It was covered in blood and paint, but I could see the bone. I was really worried about how much blood he could have lost from his finger. He had been alone and bleeding for so long while I was asleep, and I was worried about losing him. I convinced him to call his security team.
4. I asked what he had been doing while I had been upstairs. He said he had written me a goodbye note for my “other boyfriends” to see, listing names of all these men I had worked with, so that “they can frame them”, and something about my ambition, that maybe the messages will help them somehow. He was taunting me about his finger, “This isn’t good enough for you?”
5. We started to walk out. He kept taunting me, “Is this good enough for you? This is how much I fucking love you. This is what a fucking idiot I am for loving you”. I kept asking if he was okay and telling him to stop. He got more paint.
6. At some point we got into the in kitchen. We were surrounded by broken glass. He said he wanted a Red Bull and I said I would make him a coffee. There was more argument but he calmed down a bit after I made the coffee while we waited for security to arrive.
7. At some point as we sat down with the coffee in the living area. I thought he was calming down, but he threw his coffee cup at the TV and so hard that it went straight through the TV. Somehow the glass table got broken as well, though that could have been before we sat down. He got nasty again and he wasn’t making any sense. He thought I had had a guy over the night before, it was so crazy, I was crying. At one point he took my phone and pressed record.
8. I remember seeing security finally rush in. This was the first time I had seen other people for three days. They asked me what had happened and I told them about Johnny’s finger. I had only seen that his finger had been cut off that morning when he held it up in my face. I didn’t actually see the finger being cut off, but I was worried that it had happened the night before. I figured it might have happened when he was smashing the phone on the wall by the fridge.
9. Security asked him where his finger was, asking him where he had been walking. I stood behind them. Somehow, I just wanted it to be ok. I didn’t want this to be the end and I didn’t want to leave him if he needed help. I didn’t know what he would remember and, despite everything, I didn’t want him to be alone at the hospital.
10. He went out the front door, though security tried to stop him. He took out his penis and they asked him what he’s doing. He answered as if he was asleep: “I need to take a fucking piss, it’s my house”. He peed just outside the front door; he then he went back in and did it right in front of them, to nervous laughter. He said he was trying to write my name, peeing on the walls and carpet, walking through the house.
11. They then ushered me back into the little theatre room in the house. One of the guards went and talked to Debbie Lloyd, who was there now there with Dr Kipper. Someone tried to get me to take medication. Jerry Judge came in, saying they needed to get Johnny out of there. They took him to the hospital. I wanted to get out of there too, but I didn’t want to abandon him; I wanted to make sure that he was ok. But all of them were telling me it was best I go.
12. I remember that I found the nightgown some time that day. There were pieces of it wrapped round something and I realised it was the steak I had planned to cook. He had ripped the gown into pieces and put raw meat in it. He had also gone around and painted on all my clothes in the closet. He had taken a lot out of them and put them in the tub and smeared paint on them. And he had hidden more bits of raw meat in places, like in the bedroom closet. It was really messed up.
13. I am aware that Johnny has said that during this whole ordeal I was throwing bottles at him and that one of these bottles severed his finger. That is not true: he was the one throwing bottles, not me. He has also said that I put a cigarette out on his cheek. That is also untrue.
14. That night, I managed to sleep. I think I was given something, but I was still waking up constantly in a panic. I got through the night and packed the next day. Johnny’s driver took me to the airport. I went home to LA. I was in touch with Johnny’s team to ask how he was, but I wasn’t really being told what was happening.
15. Johnny didn’t stay in the hospital in Australia long. He came back to the LA house after just one night. He was having ongoing medical treatment and required a couple of surgeries for which he had to be somewhat sober. He was supposed to be filming the latest Pirates of the Caribbean movie, but the production got put on hold for at least a month. I asked him what he was doing about work and he told me that his team had given some excuse to the producers. He made some effort to apologise and try and fix things between us, but it did not last long.

### Staircase incident, March 2015

2. Soon after Johnny’s return to LA, we got into a big argument one night because I found messages that showed he was cheating on me. I knew that he had cheated on me before, but I did not think he would have carried on after we were married. I confronted him about it – and he reacted badly. He started smashing things up all round the apartment, including possessions of mine in my closet.
3. I went to the penthouse next door, where my sister Whitney was staying, and told her what had happened and she came into the apartment where Johnny and his team were. I remember being very upset and crying. I also remember Johnny and I were shouting at each other and at some point he started hitting me. Everything happened very quickly. I recall Whitney standing between Johnny and I when he was trying to attack me on the mezzanine level. He pushed Whitney out of the way so he could reach me. She had her back to the stairs and I remember being really scared that she was going to fall down the stairs. I lunged at Johnny to stop him from hurting my sister and struck him to protect her. It was an instinctive reaction to protect my sister. Johnny grabbed me by the hair with one hand and hit me repeatedly in the head with the other. His security stepped in and separated us. Whitney stayed with me the night after that incident.
4. Despite what Johnny has alleged, I did not throw anything at him. As for “berating him in a rage”, I would not put it like that, but it is true I was very angry and upset about him having an affair. I did strike him on the stairs. I can’t remember exactly how I struck him – all I really know was that I wanted to protect Whitney.
5. I would say that I held my own this time. I remember connecting with him physically, even if it was not much of a blow. It was a point of pride. It sounds sick but I had accepted by then it was a physical relationship; I had to know what my place in it was, and I didn’t sign myself up to be a victim. I was almost bragging about it, that I got a lick in, as messed up as that is, at least I got a lick in.

### Malaysia train, August 2015

2. Johnny and I were travelled on the Eastern Oriental train in Malaysia. We got into an argument, though I don’t remember what it was about. He had me up against the wall in our little private cabin and he tore my shirt, exposing one breast. He was screaming at me, hitting me around the face and choking me. I remember having my hands up trying to block the blows. He was holding me against the wall by the neck. Again, I thought he might actually kill me. I thought I might die. It was pure adrenaline; I didn’t have time to think about the pain. Eventually he let me go.

### Los Angeles, November 2015

2. We were in our place in LA. Johnny was using a lot of drugs at the time, especially cocaine and weed, which he was pretty much constantly smoking. We got into a fight on Thanksgiving, where Johnny ripped my shirt and threw me across the room. He threw a wine glass and a heavy glass decanter at me, which thankfully both missed me. Once when he pushed me, I fell over the back of a lounge chair and hit my head against the apartment’s exposed brick wall. I noticed later that I had got a lump on the back of my head and a busted lip from this.

### Los Angeles, December 2015

2. This happened on the night of 15 December 2015. This was one of the worst and most violent nights of our relationship.
3. Again, we were at the penthouse in LA. Johnny got mad at me and threw another glass decanter at me; he also knocked things around the room and punched the wall. He slapped me and grabbed me by my hair, dragging me by my hair through the apartment, all around between different rooms. I was trying to get out of his grasp and, in the process, he pulled clumps of my hair out.
4. I got free from him and ran upstairs to try and escape, but he followed me and caught up with me on the stairs; he grabbed me by the hair again, and he also hit me in the back of my head. He dragged me by my hair up the last few steps and, when he had pulled me to the top, he shoved me a couple of times, making me afraid I would lose my balance and fall down the stairs. I had to get him to stop, so I said that I thought he had broken my wrist, hoping that he would calm down. Unfortunately, that didn’t work and he kept on hitting me and shouting. He was extremely angry, getting out of control, and would not stop. He knocked me to the floor, but each time he did that I stood back up. I made a point of looking him straight in the eye. He did not like that, and he yelled at me, something like, “you think you’re a fucking tough guy?”. He was trying to square off with me, provoking me and berating me saying things like “you want to prove how tough you are?” and “she thinks she is so fucking tough”. The last time I got up, he took a step back from me and then headbutted me, hitting me right in the nose with his forehead. I staggered back, completely stunned and instantly felt a searing pain, my eyes teared up and my nose started bleeding. I was in shock. He left me holding my face, bleeding and crying. I thought I would have to go to hospital.
5. I resolved to leave Johnny in that moment. I told him that I wanted to leave him and that I would call the police if he ever touched me again. I turned to walk away from him but he came up to me and pushed me and again grabbed me by my hair. Just like earlier, he pulled me by my hair from one room to the next. He dragged me into the upstairs office and I managed to get free from him. I told him again that this was it, I had enough and I was leaving him. Johnny grabbed me by my throat, pushed me to the floor, and hit me in the back of the head. He grabbed my hair, slapped me in the face, and screamed and swore at me, saying that he was going to kill me. He was dragging me all over the carpet; I was trying to dig in with my nails to stop him and get free but I couldn’t.
6. He pushed me onto the bed in PH4 and got on top of me, pushing me face down into the mattress, smothering me and pulling out more hair. I was suffocating. I was trying to scream, hoping he would get off me, but I couldn’t even get any sound out. It was like a nightmare. I was panicking, as it felt like Johnny had completely blacked out: it was as if he had completely lost control of himself and nothing would make him stop hurting me. His whole weight was on me, and he put his knee on my back and his other foot on the bedframe. At the same time, he was punching me in the head, screaming over and over – so loudly, right in my ear – how much he hated me. The bedframe splintered and that’s all I remember. I have no idea how it ended. I don’t remember anything after that until my friend Rocky Pennington came into the room, saying “oh my god, oh my god”. I wasn’t in the bed– but on the floor – and Johnny had left.
7. My friends Rocky Pennington and Melanie Inglessis had been due to come over earlier that night. I can’t remember if Melanie came into the apartment because I was in a daze, but I remember Rocky coming in and we called the nurse to do a concussion check over the phone. I had horrible headaches and pain in my face for at least a week after this incident.
8. We took photos of the splintered bed and of the injuries Johnny caused to my face, plus a clump of hair on the carpet, which I exhibit at AH1 pages 18 to 31. As I explained, I wanted pictures to be able to show Johnny what he was doing. At some point that night Johnny also had written “Why be a fraud? All is such bullshit” on the kitchen counter in gold marker pen. I exhibit a picture of that at AH1 page 32.
9. I was supposed to be appearing as a guest on “The Late Late Show” hosted by James Corden, the next day. My face was all bruised and I was very shaken up and upset, so I texted my publicist Jodi Gottlieb just before midnight that night saying I might not be able to make it, that I was bruised and might have one or two black eyes, and I would have to see how things were looking in the morning. I pretended that I had had an accident. I didn’t want to tell her what had happened to me. I exhibit a copy of our text exchange at AH1 page 33.
10. That night and the next day were really hard. I ended up deciding to do the show because I didn’t think I could cancel at the last minute. I remember being in pain and had some difficulty getting ready. I remember they put a lot of makeup on me to cover the bruises and I wore red lipstick to properly cover up my bleeding lip. I remember it hurt when they did my hair. I was really upset all day. But I just got on with it and did my job.
11. A day or so later I wanted to follow up the telephone concussion check, so I went to Dr Kipper’s office to get an examination. I saw a nurse named Lisa Beane, who followed me out to my car, saying that she could see that I was “in trouble”, or something similar, and that I should call her if anything like this happened again.
12. A few days later, on 20 December, Johnny and I spoke about what he had done. I said to him “you head-butted me”. I think I was still in disbelief. This caused him to pause and he said, “I just gave you a little knock with my head”. He then said he was a “fuck up” and left. I had a text message exchange with Rocky about that conversation (I had texted her to say that Johnny was coming over to talk), the same night, 20 December, and into the early hours of 21 December, exhibited at AH1 pages 34 to 36.

### Birthday party, April 2016

2. On 21 April 2016 I was having my 30th birthday party with friends at the penthouse. Johnny was a couple of hours late and when he arrived, he was drunk and high on drugs. After everyone else had left, Johnny and I went to bed and we spoke about him missing the party. I was upset that he had missed my birthday, I was really sad about it and I told him so. He soon got angry: he said I was always blaming him for everything.
3. At this point we were up out of the bed, but still in the bedroom. Johnny picked up and threw a magnum sized bottle of champagne at me, which missed and hit the wall. I can’t remember if it smashed but something definitely did, it could have been another bottle or a glass which was sitting near to where the magnum hit the wall, or he could also have thrown a glass at me, I am not completely sure. But I remember that bits of flying shattered glass hit me.
4. Johnny then grabbed me by the shoulders, pushed me onto the bed, and blocked the bedroom door when I tried to leave. He grabbed me by the hair and pushed me to the ground. I scraped my knees on bits of broken glass. He was screaming at me and taunting me, asking if I thought I was a “tough guy” or something like that, and he said that he wouldn’t let me leave. At some point in the tussle a lamp got broken. When I stood up, Johnny shoved me down again, but I eventually escaped from the bedroom and walked through the office. I think I was trying to put together a bag of overnight things. As I was walking round the desk, Johnny shoved me and grabbed me by the back of my hair. I got away from him and back into the bedroom and Johnny pushed me again. I put up my arms to try and defend myself and Johnny pushed them down. Then he squared up to me and bumped his chest into mine, making me stumble backwards onto the bed. I tried to plead with him not to be like this on my birthday, then I tried to walk past him to leave the bedroom, but he pushed me to the floor again. Then he walked out of the apartment, smashing things – pictures and photographs – as he went. He’d left me a note: ‘Happy Fucking Birthday’.
5. After this incident I went to the annual Coachella music festival in California with my friends as we had planned. I understand that Johnny is claiming, as ridiculous as this sounds, that I pooped in our bed after this incident. This is just not true. One of the dogs may have done it; they had accidents in the house a lot, including having pooped in our bed before, so it was a well-known pattern of the dogs’ behaviour. Johnny knew this, which is why I find his accusation was so ridiculous. My friends and I call this “Poopgate”.
6. I didn’t see Johnny for a month after that, but I was constantly worried that he would show up, probably drunk or high, and act violently again. I even asked Kevin Murphy about getting the locks changed; he said that Johnny would need to agree to it.
7. In the weeks after this incident my friends and family were increasingly worried for my safety and told me I should leave, including my sister, iO Tillet Wright, Rocky Pennington and Amanda de Cadenet.
8. I was so worried and anxious about him coming home and hurting me, that at some point I gave my friend, Amanda de Cadenet, keys to my apartment and garage downstairs so she could access the building if anything happened to me. She would come over to visit me a lot, just to check in and see that I was ok. I was struggling with the decision to leave Johnny. By then, I knew I had to, but I was devastated about it. I also talked to Amanda about trying to get the locks changed.

### Los Angeles, 21 May 2016

2. The next time I saw Johnny was on 21 May 2016 when we met at the apartment to discuss our relationship. He had been in touch and upset about his mother dying. I had told Rocky he was coming. She was worried and told me to contact her if I needed help. He arrived at the apartment at around 7.15 pm. I was alone in our apartment when Johnny walked in. I could tell that he was drunk and high. Rocky and Josh lived in a neighbouring apartment, and Rocky kept a key to our penthouse.
3. Johnny was becoming very angry with me, making accusations over “Poopgate”. I couldn’t believe he was getting so worked up about this ridiculous story when we hadn’t seen each other for a month and his mother had just died. We called Kevin Murphy and I challenged him over his account that I had said to him that it was a prank.
4. I was getting worried for my safety, as Johnny was getting more and more aggressive towards me about “Poopgate”. I texted Rocky asking her to come back over. I also spoke to our mutual friend iO Tillett Wright on the phone because Johnny was saying crazy things about iO being the one who pooped in the bed. I put iO on speakerphone and told iO what Johnny was saying and asked him to explain the truth. iO laughed at how ridiculous the accusation was and Johnny became enraged, ripping the phone from my hand and began screaming insults at iO. He then tossed the phone away and stormed upstairs. I retrieved the phone and iO shouted over the line that I had to get out of the house. Johnny rushed back down the stairs and grabbed the phone and started screaming into the phone at iO. That was the moment he wound up his arm back like he was a baseball pitcher and threw the phone at my face as hard as he could. The phone hit me in the right cheek and eye.
5. I covered my face and was crying with pain. I told Johnny that he had hit me in the face. He started yelling at me, saying he wanted to see my eye and how hard he had hit me. He said, “what if I pulled your hair back?” and charged at me, grabbing my hair and started yanking and jerking my head around. As I tried to get up from the sofa he was slapping and shaking me. I called out “Call 911”, hoping that iO might still be on the speakerphone and would hear me.
6. I was screaming. At this point Rocky came into the apartment and I managed to get loose from Johnny’s grasp. I went over to the other side of the room. Johnny ran at me again but Rocky got in his way, getting between us. She put out her arms to separate us and pleaded with Johnny to stop. This made him grab Rocky’s arms, pushing them down to her sides, and shouted and swore at her.
7. I ran away back over to the sofa and collapsed down into it, afraid of what might come next. Johnny came over towards me, standing over me, but Rocky got between us again, taking on a protective posture. Johnny was screaming at me repeatedly to get up, saying “get the fuck up!” over and over again. He picked up a magnum bottle of wine and began swigging out of it, swinging it around, smashing things as he went.
8. By this time Johnny’s security, Jerry Judge and Sean Bett had come inside. I yelled at Jerry to help me, saying I would call the police. Jerry said, “boss, please”, and he took Johnny away, though he continued to scream and smash things as he went out. There was a lot of wine spilled in the hallway and he damaged one of the doors. He went into another apartment, which I used to store my things, and I heard him destroying items in there.
9. Josh was inside by now, and he and Rocky took me out to their apartment in an effort to keep me safe. Rocky took some pictures of the damage that Johnny had caused: see AH1 pages 37 to 44. (the stripy carpet with the split wine is the hallway). In hindsight we could have taken more pictures of the damage but didn’t expect we would need them for legal proceedings. Rocky also took pictures of the injuries caused to my face: see AH1 pages 45 to 51.
10. At some point I called my new attorney Samantha Spector to get her advice.
11. I was afraid to speak to the police at this point. I knew it would cause an international media incident for us both and I wasn’t ready to be in the middle of a media storm, on top of everything else.
12. Josh was standing outside the door of their penthouse, watching out in case Johnny suddenly came back. I was on the couch with Rocky, who was looking after me.
13. Two police officers showed up, a man and a woman. They came up to me and spoke to me. They said something about my face and that it looked like something was wrong. I don’t know if there were marks on my face at this point because I hadn’t spent time looking in the mirror. They encouraged me to make a statement and that, if I did, they could make sure I was safe. But they told me they couldn’t do anything if I didn’t make a complaint. I declined.
14. Then they demanded to do a walk through the apartments. There was wine all over the floor and Johnny had smashed things. After the walk through, one of the police officers have me a business card and encouraged to call if I changed my mind and was ready to talk.
15. Later that night, I was sitting on the couch when two different police officers arrived. Rocky was there with me. They also demanded to do a walk through; but by then we had cleaned up.
16. I also texted Melanie after the police had left, see exhibit AH1 pages 52 to 53.
17. Over the next few days I left the apartment a few times, including to see my lawyer and to go to my friend Amanda’s party.
18. I attended my friend Amanda de Cadenet’s birthday party the next day. I had promised her I would bring the birthday cakes, so I didn’t want to let her down. My face was bruised, so I covered it up with make-up as best I could and wore sunglasses. At the party, Amanda saw my face and was obviously really concerned, confronting me about it and asking me if I was ok. I was just doing the best I could to get through the day. Others at the party noticed my face and commented on it.
19. The woman who hosted the party for Amanda pulled me aside at one point. As I remember it, she told me she could tell that I was in trouble. She told me that I could come and stay at any time if I needed to. She explained to me where I could find a key and that I could come any time of the day or night. I remember being struck by that. She was right. I was anxious, my weight had gone down to 45.3 kilos (I am 58.9 now), I was scared all the time – it was over.
20. After this I resolved to leave Johnny and I filed a petition for the dissolution of our marriage on 23 May 2016, and on 27 May 2016 I filed an application for a domestic violence restraining order against him. I needed to be able to change the locks and have a safe place to be.
21. I was really scared to leave Johnny and I had talked to my friends about this in the months leading up to the incident in May and my decision to seek a restraining order. Over the years, Johnny threatened me a lot about me leaving him – even when things were good between us. He would often hold me by the neck up against the wall, without hitting me, but he would talk about what he would do to me if I left him, such as “I will cut up your face so no one will want you ever again” and about how he knew people who could “break a leg, real cheap”. He told me repeatedly that “if you ever fuck this up or leave me, I will make sure you live to regret it every single day”. He told me he would ruin me and enjoy watching me be ruined and that I would never work again, saying things like, “if you leave me, you will end up sucking cock under the freeway”. I was scared about what he would do if I left him and I remember talking to my friends, including Amanda de Cadenet and Kristy Sexton about the fact he was vindictive and I was scared about what he would do when I left.
22. But after the incident in May I felt that I had no choice and I had to do what I needed to do to be safe. Johnny wasn’t wrong about what he said: he has found ways to remind me every day about the fact I have left him, but I do not regret leaving him.
23. On 15 August Johnny and I executed a Deal Point Memorandum resolving the issues around the dissolution of our marriage, and I discontinued my claim for a restraining order.

### Conclusion

2. I know that Johnny has denied the incidents of abuse I have spoken about. He has even sued me over it in the United States. I believe he doesn’t remember the things he has done. I have I think he has somehow been convinced by others that I am making things up for attention, money or fame. I am not.

I believe that the facts set out in this statement are true.