If called as a witness in any action, I could and would testify competently, under oath, from my own personal knowledge, to each and all of the following facts, except for those facts that I have stated under information and belief and those that I believe to be true.
- I use the name "Caroline Pierce" as my entertainment name.
- I first met Zak Smith aka Zak Sabbath ("Zak") on the set of a movie in 2006 and first met his then girlfriend (Mandy's real name redacted) aka Mandy Morbid ("Mandy") on the set of a movie in 2007.
- We have been friends since they got married here in Las Vegas.
- I have observed Zak and Mandy as a couple at work, at leisure, in private and in public. Being from out of town, I didn't see them often but we'd see each other when I was in LA or they were in Vegas.
- I used to drive Mandy around on errands and to doctor appointments when I was in Los Angeles when I had a free day to do so. I have spent time alone with her, in which she never spoke of anything negative happening in her relationship with Zak.
- I have spent time alone with Zak. I stayed over at their apartment on a Los Angeles work trip, during a time when Mandy was in Canada visiting her family. I have never once even remotely felt uncomfortable being alone around Zak. I have never witness Zak mistreating or being abusive towards a woman.
- I did not witness any signs of abuse or manipulation between them. What I saw were two people incredibly well matched for each other. The Mandy I knew was in control of her own thought and own actions. She has a very strong personality.
- From my observation of their relationship, I am of the opinion that Mandy's needs were the priority in the relationship, be it medical/health needs or sexual, and that Zak wasn't begrudging about that in any way. I saw respect and love. The relationship I saw between them was very much about compatibility and their personalities fitting so well together.
- I did not see Zak treat Mandy like a trophy wife as she claims, and I did not see Zak treat her as an owned object as she claims.
- Mandy and I have had talks about not wanting children and how it was unfair that young women aren't usually able to make that medical choice and have tubal ligation. Her accusation about pregnancy/abortion makes no sense in the context of the Mandy I knew because she would never have wanted to, or been able to, carry a baby anyway
