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communications index
texts / texts (transcribed) / emails / emails (transcribed)
letters / letters (transcribed) / journal / recordings
nursing notes / nursing notes - JD / nursing notes - AH
all combined / unable to transcribe
2008-2012
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2008-05-20 time unknown | Tracey Jacobs | Jake Bloom Jake Bloom's assistant (Danny) & others | Joel has given me permission to ask for advance per tax situation. We'll see what happens. | email read out only --------------- BN TMG002722 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2008-08-21 time unknown | Patrick Knapp | Tracey Jacobs | Please see the attached perk list modified in accordance with our CC earlier today. (perk list for the movie Rango attached, only partially read out) page 1: personal hair dresser paragraph 3A on page 2: reference to business class round trip air travel from UK page 4: Doubling nudity. There shall be no nudity and/or sex scenes featuring JD and/or double. (hair, makeup and wardrobe are also mentioned) | TJ 2019 depo pg 50-53 | email partially read out only --------------- Patrick Knapp - presumably attorney Patrick Knapp Schwarzenegger |
| Date/Time | from | to | email / Subject: (no subject) | doc | notes |
|---|---|---|---|---|---|
2009-12-06 04:08 pm | Joel Mandel | Johnny Depp | johnny... I wanted to be sure to reach out to you, personally, before you left. Since my email to you in September, I have done what I was told you wanted done, meaning, "getting us through" financially until work could start again. The good news is that, so far, we have been able to do that. Notwithstanding, I need your help in a variety of ways. First, we ned to "take it easy" on holiday spending. Second, we need to discuss some dollar limit in the upcoming Dillinger auction. Third, I need to be able to sit with you on your return from this trip, and before you leave for France, so that we can talk about where we are financially, what we have borrowed in order to sustain ourselves, what we have had to do to obtain those borrowings, what is now necessary to pay those borrowings back and, finally, to look realistically at income and expenses and to work together on how to make sure that these are back in balance. I know that things are hectic for you at the moment, but know that I am available, day or night, if you want to discuss any of this now. My best, and please travel safely... joel.... | ||
2009-12-07 01:12 am | Johnny Depp | Joel Mandel | dear joel = first, thank you for dealing and getting me through. secondly, i am doing my very best on holiday spending, but there is only so much i can do, as i need to give my kiddies and famille as good a Christmas as possible, obviously within reason. but, regarding the plane situation... i don't have all that many options at the moment. a commercial flight with paparazzis in tow would be a fucking nightmare of monumental proportions. forget the dillinger auction. don't need it. know that i will be starting THE TOURIST, on or about the 15th of february, which will be 20 mil. i will then go, virtually, straight into PIRATES 4, for 35 mil and then in turn to DARK SHADOWS for another 20 mil. i hope that by the amount that will be coming in from work in the coming year and also from back end proceeds, etc., will put everything straight. what else can i do??? you want me to sell some art??? i will. you want me to sell something else??? sure... what??? boat is going to be chartered at new years and sony will then charter it for the TOURIST shoot in venice. other than that, i got bikes, cars, property, books, paintings and some semblance of a soul left. where would you like me to start??? i don't like being in this situation, but there wasn't a whole lot of choice, as THE RUM DIARY was a sacrifice we knew would be happening and the last proper paycheck was PUBLIC ENEMIES. i will do my best, joel. my love to you and yours= johnny |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2010-02-16 | Exh 48 "February 16, 2010 e-mail chain" re check UTA had received | TJ (2018) depo pg 82 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: VANREE,AMBER | doc | notes |
|---|---|---|---|---|---|
2011-11-30 10:36 am | JoAnn Carrasquillo | Brenda Neigel-Britt cc Jennifer Perry | Good morning Brenda, I received your voice mail this morning regarding the record for SID#WA2531100B, Name VANREE, AMBER, DOB 04/22/1986, contributing ORI WAKC50000, originating ORI WAO173200, charge of 0113400 ASSAULT-4-DV, Case#CPS013529. We have updated our database with no charges filed based on the letter received from the Prosecutors Office. Correction Notices are used to udate incorrect arrest information and the disposition shows the outcome of the case. Normally, a pink disposition would be sent in to reflect no charges filed, but we will accept the letter from the Prosecutor's Office as the source document. Please let me know if you have any more questions on this record. Thanks JoAnn Washington State Patrol Correctional Records Technician 1 | Plt112 pg 8 --------------- due to the quality of the document, I'm not 100% sure if I transcribed all the number/letter combinations correctly | |
2011-11-30 10:42 am | Brenda Neigel-Britt | JoAnn Carrasquillo | OK, thanks. I will send a correction letter to her attorney. I will try to remember this for the next one. Thanks for your help! Brenda | Plt112 pg 8 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2012-02-08 time unknown | Johnny Depp | Mathias Bocquillon | Not to use this as an excuse at all, because there is none, but my drinking was never for fun. I have been trying to numb and self-medicate my pain for years. My brain has not been right. After two separate lengthy stays in the hospital to get off alcohol and pills, I know now, after almost two months of sobriety that I was not happy and from the doctor's discoveries that had continued I was going to die, the liver has had enough. I have been living in a state of constant poison for years. This cannot continue. I need peace. Vanessa needs peace and she deserves to be happy. | email read out only |
| Date/Time | from | to | email / Subject: 100 days | doc | notes |
|---|---|---|---|---|---|
2012-03-22 time unknown | Johnny Depp | Elton John | Dearest Elton, A fucking 100 days of clarity for an old reprobate twat like me. No one would ever have believed it possible, but a very select few, most importantly you, so today I am fucking celebrating you. Your love, understanding and complete dedication to the curing of my poisoned et brain and liver resembling Mrs. Thatcher has been, alongside the birth of my children, the most lovely and most important thing that has ever happened to me in all of my 48 years. It is impossible for me to fathom how you are able to juggle your quite large life and work whilst keeping me afloat on a dreadful sea of confusion. Hellish personal life, fucked brain, hurt heart and internal savagery against myself. I would have been swallowed up by the monster were it not for you. That is a simple fact. One day at a time at the beginning felt far more like one step at a time, a foot forward. (rest was not read out) | email read out only |
| Date/Time | from | to | email / Subject: guten morgan | doc | notes |
|---|---|---|---|---|---|
2012-04-19 10:45 am | Stephen Deuters | Johnny Depp | we're all set to leave here approx 130P. hope you rested well, md. | ||
2012-04-19 11:59 am 10:59 am | Johnny Depp | Stephen Deuters | i got drunk and destroyed my room. there are hookers and animals in here... | must be 10:59 am when same UTC as above | |
2012-04-19 11:02 am | Stephen Deuters | Johnny Depp | watch out for Mike Tyson... have you num-numed? | ||
2012-04-19 12:11 pm 11:11 am | Johnny Depp | Stephen Deuters | don't want nummies, thank you. is it okay to put on a concom after the fact??? i mean, if i just wear it for the rest of the day, like??? that works, doesn't it??? i have had to kill a few of the animals for sustenance. i have made quite a mess... there is blood and animal tracks everywhere. | must be 11:11 am when same UTC as above | |
2012-04-19 11:17 am | Stephen Deuters | Johnny Depp | totally fine, stick them on. double up if you can. we'll get some virgins up there too. apparently they work wonders for this sort of thing. as for the beastly residue, i'll grab some kitchen roll and can of Febreeze. it'll be great. if all fails however, we'll point the finger at Nathan. he was so drunk last night, he'd probably just assume responsibility anyway. | ||
2012-04-19 11:20:47 am | Johnny Depp | Stephen Deuters | i am going to jump in the shower and have a good, solid weep. afterwards, can we locate charlie??? i'd love to hang with him before we split!!! i'm putting rubber bands around the condoms. very interesting color my penis has taken... i feel safe now. |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2012-12-14 time unknown | Tracey Jacobs | Christi Dembrowski | I told him not to blow up the movie. But still needs work. He seemed a bit too happy about P5, doing it later than sooner. OMG. | TJ 2018 depo pg 83/84 | email read out only |
2013
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2013-01-30 | Exh 242 "Email String, 1-30-13" re offer from Louis Vuitton | TJ (2019) depo pg 44/45 | if you're willing & able to transcribe this exhibit, please let me know |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2013-01-31 | Exh 244 "Email String, 1-31-13" re potential press release regarding Johnny Depp starring in Black Mass | TJ (2019) depo pg 48/49 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-02-27 time unknown | Tracey Jacobs | Christi Dembrowski | It must be his happy day. | TJ 2018 depo pg 85 | email read out only |
2013-02-27 time unknown | Christi Dembrowski | Tracey Jacobs | Hahaha. | TJ 2018 depo pg 85 | email read out only |
2013-02-27 time unknown | Tracey Jacobs | Christi Dembrowski | I mean it. | TJ 2018 depo pg 85 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-03-20 12:48 pm (UTC-7) | Johnny Depp | Jane Rose | Also, am with my girl, Amber... You will love her!!! Is it alright to bring her around with me? She's not a pain in the ass, like the French ex albatross... No comparison. | ||
2013-03-20 07:13 pm (UTC-7) | Johnny Depp | Jane Rose | Whatever's alright is fine... She's just on my arm and a killer broad... But, would never overstep any boundaries, as it is Maestro's sanctuary... |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-03-21 time unknown | Jason Zoragon | Tim Price cc Stephen Deuters | Tim and Mike. Per my conversation with Bruce ...(reads to the words)... He is departing Sunday and car services will be arranged. --------------- part of the email is unfortunately missing, but I assume "he" = Ian McLagan | email read out only --------------- sent "in the early hours of the morning, Greenwich Meantime" |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-05-23 time unknown | Christi Dembrowski | Tracey Jacobs | They aren't good guys. If we didn't need to keep on going, I'd tell them to take a hike. I would much prefer another option, as much as I wish it would work. | TJ 2018 depo pg 86/87 | email read out only |
2013-05-23 time unknown | Tracey Jacobs | Christi Dembrowski | Don't have one now. | TJ 2018 depo pg 86/87 | email read out only |
2013-05-23 time unknown | Tracey Jacobs | Christi Dembrowski | It's not good. Trying to get offer from Sony, ten to 15. | TJ 2018 depo pg 86/87 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-05-27 time unknown | Nathan Holmes | Amber Heard Kate James | summed up only: plans, info directions to Hicksville for Thursday --------------- Thursday = May 30, 2013 | email read out only | |
2013-05-27 time unknown | Amber Heard | Kate James | Can you please send this e-mail to the following people and ask that they RSVP: Rocky, Sis, Sean, Helen, Britney Eustace, Kristi. And please include in the e-mail to bring some food, booze and drug of choice. Yay! v02 of 2nd-to-last sentence: Please include in the e-mail to everyone to bring food, booze and drug of choice. | email read out only --------------- Sean = Whitney's boyfriend at the time, Kristi (in trial transcript mistranscribed as Christi) = Kristi Sexton |
| Date/Time | from | to | email / Subject: Can't shake it | doc | notes |
|---|---|---|---|---|---|
2013-06-05 12:42 pm | Bruce Witkin | Johnny Depp | Hey Hadn't Heard from you when you were here. I'm a puddle of shit. Can't shake this depression I'm in. Feel useless and unmotivated. Never been this bad. Maybe I'm burnt out or just sick if the path I choose. The only one that ever gave me a real shot in this fucked up music biz is you. I've questioned every decision I've made And don't know what I would have done different But here I am. Can't Fake smiles anymore or happiness. Hope you're are doing better. And hope you have a wonderful birthday. Me | ||
2013-06-05 02:13 pm | Johnny Depp | Bruce Witkin | dude... i am in exactly the same place... of course. i love you= me | ||
2013-06-05 03:34 pm | Bruce Witkin | Johnny Depp | What do we do? The thing that hurts the most is I feel like I've let you down. Nothing makes sense. High hopes for the new Buffalo record and once again I don't know who to trust can't tell what's good or bad. It sucks. | ||
2013-06-06 07:05 am | Johnny Depp | Bruce Witkin | seriously, bwoosie... how can you possibly think that you've let me down??? we have done some of our best work together in recent years!!! we've made incredible music together with some of the coolest and most unique artists EVER!!! and, of course, i COULD NOT, AND WOULD NOT, HAVE DONE SWEENEY WITHOUT YOU!!! i brag about you practically every single day!!! in fact, was playing the WHITE BUFFALO track, "THE AMERICAN DREAM" for Marcus the other day and bragged like a cocksucker!!! he went fucking crazy for the track and for the brilliant production and the sound of the recording!!! it is a proper anthem, in the tradition of woody guthrie and bob dylan. you made that fucking happen!!! the LONE RANGER record is brilliant!!! you are a genius, a wizard and also a lovely fucking man who happens to be my brother and i know you like i know me... it is a phase. simply. the fact the we're feeling the shit at EXACTLY at the same time doesn't surprise me in the slightest... brain is on full tilt. the circus never stops. feel physically fucked. constantly!!! i am wired up so tight that i am barely able to deal with people on any level that is remotely enjoyable. lexapro is fine, i think... seems to work, but, it does not erase and it doesn't supersede what and who we are and what we carry from birth. it's a very subtle band aide. the weed helps, but, it is really more a choice to alter reality to make it tolerable. it is not exactly the escape i yearn for... i wanna feel joy!!! when do we get that??? you and i are loaded down with responsibilities, expectations of others, expectations of ourselves(the worst!!!) and very, very high standards!!! we need to find the fun!!! wherever and whatever it is!!! chemically, our bodies expect reward for our daily offerings... it actually demands it!!! needs it!!! is it in the drugs that doc's give us??? to some degree, yes... because our bodies don't produce those natural fucking highs anymore!!! however, i think it would be fucking super wise of us to look into ourselves and locate what we can... and i know you'll laugh, but i think we should start exploring some form of meditation!!! it is the only reason that Damien was able to stay alive on death row... i've reached out to him to get some kinda starter advice... otherwise, i will just wallow in this muck and fucking rot. this we cannot do!!! life is fucking great!!! it is how we choose to spend our time during it that can be fucked. i know we are smarter and better than that. let us speak and take aggressive steps toward regaining what we need to feel good again and happy and fulfilled. we get one shot at this life, as you know... what Marlon referred to as, "... the length of a bird song..."... we MUST NOT FUCK IT UP!!! we have the goddam keys to the car!!! we're in charge of this ridiculous body and mind!!! forward is where we need to be. onward toward better. working today, but, will have moments, if you wanna talk, or text... we'll get through this bullshit. together!!! just as we always have... coming home saturday morning... HAPPY BIRTHDAY US!!!! let's hang, my brother... i love you dearly and more than you could ever know... johnny | ||
2013-06-07 07:21:43 pm | Bruce Witkin | Johnny Depp | Hey Brother. You have such a way of putting things. Brought me to tears what you said. I guess we both brag about each other. It's just been weird like I can't put my finger on it. Would love to see you for a minute when you come in. I've got my annual Birthday BBQUE on Saturday That Sheila fern started 20 years ago..... I think I keep it going for her more than me. Coz is in town. I'm sure we can snap out of it together. Love you very much. See you soon. Bwoosie. |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-06-10 time unknown | Tracey Jacobs | Christi Dembrowski | He's testing unknowns other than Colin. --------------- The transcript also says "it appears that you're discussing with Christi's traveling to Anaheim for something", not sure what that means, unless this was supposed to say "with Christi". | TJ 2018 depo pg 88/89 | email read out only |
2013-06-10 time unknown | Christi Dembrowski | Tracey Jacobs | (not read out) | TJ 2018 depo pg 88/89 | email not read out |
2013-06-10 time unknown | Tracey Jacobs | Christi Dembrowski | This is our last option other than shitty Mark Forster movie. | TJ 2018 depo pg 88/89 | email read out only |
| Date/Time | from | to | email / Subject: --- | doc | notes |
|---|---|---|---|---|---|
2013-06-11 06:06:38 pm | Amber Heard | herself | I just don't know if I can do this. anymore It's like dr jekyl and mr. hyde. half of you, I love. madly. the other half scares me. I can't take him. I wish I could, but I can't. the problem is, I never really know/ understand which one Im dealing with until it's too late. The drinking assures me that I am dealing with the monster. the abused scared insecure violent little boy. I just can't tell where the line starts. Also drugs seem to guarantee I will be forced to deal with the monster as well. once again, it's knowing what /how much/ and when --- which makes all the difference. sometimes the hangover , te morning after is just as bad as the full on disco blood bath I've come to expect. you live in a world full of enablers. you cut out and resent (whether you realize it or not) everyone who isn't an enabler. I can make a clear distinction as to who falls into which category with complete ease. Just how often you see them and what role they play in your day-to-day life distinguishes where they fall on the enabling scale. I watch yesterday as everyone around you picked you up off the floor, held you up. Got you on with your life. prevented you from really falling. with so much help, of course you can't know how much this hurts you and your life. because you pay people around you to prevent your feet from having to hit the rock bottom, as they say. yesterday, i saw you pass out, amongst vomiting, 3 times. all 3 times jerry had carry you from the floor. on the plane nathan mentioned how many times he's had to break into locked doors to wake you up , after passing out on the toilet. You would have embarrassed yourself countless times if someone would be honest enough with you to tell you. to show you. if someone filmed you while you were in this state you would be mortified. it's embarrassing just watching it happen. you can't know because people (friends?) keep smiling to your face and then turning their heads and rolling their eyes at how ridiculous they feel and look picking a grown man up from his own piss and vomit, knowing he'll never be able to realize how bad he looks. Hung over - post pills is not much better. you're mean and insensitive. i have no reason i have to stay with you. and i wont. you don't pay me. i don't have to lie to you for my job, livelihood or kids. i will never want to be locked into you. my freedom is now, i realize, the only thing i have to protect me. i will never ever trust you to trap me. I myself watched you pass out cold on the floor, after drinking yourself sick. one of these times you cut yourself so badly that you needed stitches. you say things you don't mean. you are impossible to reason with. so everyone placates you. lies to you. worse even, you lie to yourself. and you believe it. you have so many yes people around you constantly protecting you from yourself and the truth. they think looking at you in a disappointed way is truth? ah, no wonder it doesn't work. if they left you, on the floor in your own shit, locked in the bathroom while you missed work,-- then you might have to actually learn. learn to take care of yourself. you think you're so tough, big self-distruction- i-don't-give-a-fuck man?!? if you really didn't then you wouldn't have so many people there to take care of you. you just let them do all the hard work while you run away from your problems unable to carry and clean up after you. a real man doesn't need to be cared for like a baby.. what i saw last night was a child. you made me feel, at the beginning, safe. life you could care for me. like I could have a family with you. you made me feel like you were a real man -- that was only half of you. what i saw yesterday, and many times before, is a needy man-child. i watch as other grown men have to wipe you, basically. And you get the convenient benefit of never having to remember it. that's nice. for you. so you get away with so many lies that you tell yourself. you actually trick yourself into thinking the craziest lies when you're fucked up and because your so accustomed to people NOT calling you out on your bullshit (they work for you-- hello) that you Actually believe your shit. (Need a reference, how about when you actually though I hit you first. Or that i was hiding drugs-- the list goes on) Admit some of your own shit first. many times you have hurt me. physically and emotionally from the things you say and did while fucked up. the monster comes out and you become mean and horrible. the opposite of why i love you. and what i am to do? how would you be if you were in love with one person who was in fact, two? Both you, the love of my life, and the monster look the same. how fucking confused i feel. i am mad. so mad. how would you feel if you were sold false goods.?? i fell for you while you were sober. a whole year. how could i know this lay in store for me? how dare you make me fall in love with you , present this other self - your good half- only to rip the mask off once I was in?! I feel like the biggest idiot in the world. i have put up with so much. i have cleaned shit, vomit and piss up both literally and figuratively . i have been accused of crazy shit - none of which i deserved - only to never hear an apology for your booze-fueled zeal . you have hit me repeated. something you should Never have done. what a fucking man you are. And NONE of this would be possible without the booze and drugs. NONE. Sent from my spaceship |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-07-08 time unknown | Tracey Jacobs | Rob Friedman Eric Feig (both Lionsgate) | paraphrased/partially read only: telling them that Gwyneth Paltrow thinks the Mortdecai script is great and that she told Gwyneth that "Johnny took a financial haircut". | TJ 2019 depo pg 85/86 | email read out only --------------- "financial haircut" meaning instead of $20 million, he got $15 million with a back end |
| Date/Time | from | to | email / Subject: You | doc | notes |
|---|---|---|---|---|---|
2013-07-06 09:50 am | Elton John | Johnny Depp | (redacted) | ||
2013-07-13 05:05 pm | Johnny Depp | Elton John | Hello dear man... how are you??? how does the appendicitis fare??? if you need any assistance in removing stuff, i can help!!! thank fuck you're okay!!! it has been a bumpy, yet, beautiful ride... my mom, Betty Sue, as you know, has a relatively aggressive cancer and has had a malignant tumor removed from her brain and is now going to receive radiation on the lesion/spot/mass in her lung and we must now ride it out, to see if anything else pops up... she is doing great and is happy and comfortable. have been looking for big ass houses in beverly hills for her recuperation and comfort... the Doc's in Kentucky said we'd be lucky to get three months... the Cedars fucking super team have given her what they feel is a solid year, to a year and a half(which, of course, she is not aware of)... so, my brother and sisters and i feel very lucky to have the extra time!!! she will exit in great celebration, surrounded by her progeny... on the other side of the coin... my kids have fallen head over heels in deep love with Amber(my girl) and that pressure off my shoulders is fucking gone!!! that is, until the french extortionist (ex cunt) attempts to brain wash them against her... which, I'm sure is imminent. i thank you dearly for yours and your dear one's thoughts and prayers for Betty Sue... she's a tough ol' bird and a very unique species. she's as tennessee williams as it gets... he would break through the barriers of life and death to cop a gander at her for even an hour!!! she's very, very funny and does not edit... she's like a fucking cracker jack box... you never know exactly what the prize is inside, but, it is bound to be weird!!! let me know if you need me... I'm around and off "assisted living", as it were. i love you... becky | ||
2013-07-13 09:23:20 pm | Elton John | Johnny Depp | (redacted) |
| Date/Time | from | to | email / Subject: Pistol and boo | doc | notes |
|---|---|---|---|---|---|
2013-09-21 11:40 am | Amber Heard | Kate James | Can you maybe help Kevin procure a slightly altered health doc that has their shots recorded as two days before so they can all leave together on the 25th?? Do we have a vet we could grease ? Connection? | D197 via Kate James WS01 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-10-08 time unknown | Tracey Jacobs | Christi Dembrowski | Also, don't forget to call Jerry B re P5 and Jason Burns, re 22 Jump Street and J. | TJ 2018 depo pg 90/91 | email read out only |
2013-10-08 time unknown | Christi Dembrowski | Tracey Jacobs | On with Joel Mandel quickly. | TJ 2018 depo pg 90/91 | email read out only |
2013-10-08 time unknown | Tracey Jacobs | Christi Dembrowski | Be glad he got the checks. So at least we don't have to feel bad he turned the print ad down. | TJ 2018 depo pg 90/91 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-11-20 time unknown | Tracey Jacobs | Joel Mandel | I spoke to Christi yesterday, and we talked about March, April. Realistically, if he doesn't start until mid-April, we will get him an advance. | TJ 2018 depo pg 93/93 | email read out only |
2013-11-20 time unknown | Tracey Jacobs | Joel Mandel | Christi and I both get it, and we will figure it out. So far, I have two potential opportunities. One I'm pretty sure for 15 to 20 million. She is going to talk to J. in London. I understand and have accepted my marching orders, and we will deliver. | TJ 2018 depo pg 93/93 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-11-22 time unknown | Tracey Jacobs | Christi Dembrowski Joel Mandel Jake Bloom | Not to be a pain, but it is going to be important very soon to nail down very specific dates. April 1-ish for Houdini, then Lynch. We must confirm August-September for Alice 2, and November for either P5 or another picture. It really must run like clockwork to make all these movies work, and the financials work that we were all trying to solidify. --------------- when last sentence was read a 2nd time later, it was read out/transcribed as: "We really must run like clockwork to make all these movies work and the financials work that we are all trying to solidify." | TJ 2018 depo pg 95-98 | email read out only |
2013-11-22 time unknown | Christi Dembrowski | Tracey Jacobs Joel Mandel Jake Bloom | Fully aware. We've talked about the proposed year a bunch. I got it. --------------- when 2nd sentence was read a 2nd time later, it was read out/transcribed as: We talked about the proposed year a bunch. | TJ 2018 depo pg 95-98 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-11-23 time unknown | Tracey Jacobs | Christi Dembrowski | Internist and drug specialist. He has helped a lot of people get sober. | TJ 2018 depo pg 158/159 | email read out only --------------- discussions re Johnny Depp potentially hiring Dr. Kipper |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-12-06 time unknown | Tracey Jacobs | Joel Mandel | Have a good trip to London. My fingers are crossed that everything works out for April. If it does, I'm not worried about the rest of the year. Christi and I know what needs to be done. | TJ 2018 depo pg 99/100 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2013-12-29 time unknown | Christi Dembrowski | Tracey Jacobs | Spoke to Jake. He had me try Jeremy. Left word. Jeremy texted he will call Jake. | TJ 2018 depo pg 104/105 | email read out only --------------- Jeremy Zimmer = CEO of UTA (United Talent Agency) |
2013-12-29 time unknown | Tracey Jacobs | Christi Dembrowski | What did Jake say? | TJ 2018 depo pg 104/105 | email read out only |
2013-12-29 time unknown | Christi Dembrowski | Tracey Jacobs | He will say 15 plus perks and talk about Lionsgate. I can fill you in on producing idea; not a fan. And hoping there are more things that we end up hearing about, knowing you have looked at all. | TJ 2018 depo pg 104/105 | email read out only |
2013-12-29 time unknown | Tracey Jacobs | Christi Dembrowski | Anything is possible. I'm not willing to gamble on Johnny's financial future knowing what I currently know about April. | TJ 2018 depo pg 104/105 | email read out only |
2014
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2014-02-11 | Exh 243 "Email String, 2-11-14" re offer for Lionsgate movie "The Secret Life of Houdini" | TJ (2019) depo pg 45-47 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2014-03-24 time unknown | Nathan Holmes | Jerry Judge cc Bruce Witkin | On the way to the plane. ETA, 30 minutes. Bruce Witkin will meet us at the plane. Be there before us. 4 hours and 15 minute flight time on the plane. Estimated time of arrival 8:15 p.m. | BW depo pg 111, 113/114 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2014-05-08 08:26 pm | Kate James | Amber Heard | Hey there, hope you had a good flight and it's beautiful on the island. Savannah just asked me to write her a cheque for her pay, just checking if that's what you want me to do and, if so, how much. | email read out only | |
2014-05-08 time unknown | Amber Heard | Kate James | Yes, please, 1300. | email read out only |
| Date/Time | from | to | email / Subject: One-liner | doc | notes |
|---|---|---|---|---|---|
2014-05-10 time unknown | Amber Heard | Kate James | v01: Hey there, can you do me a favour, please, can you please be sure you don't send Nathan or Christi or anyone on Johnny's team the one-liner of my schedule. I do not want them to see a one-line breakdown that mentions anything romantic or anything that could Johnny to lose it you know. Please be careful, we just sent the DOOD that does not explain what the scenes are in any way. v02: Hey there, can you do me a favour, can you please be sure you don't send Nathan or Christi or anyone on Johnny's team the one-liner of my schedule. I don't want them to see a one-liner breakdown that mentions anything romantic or anything that could Johnny to lose it, you know. Please be careful. We just send the DOOD that does not explain what the scenes are in any way. --------------- I assume this was meant to say something like "could cause Johnny to" and since Ms Wass points out that there's "probably a word missing there" and it's missing in both versions, it seems to be missing in the email or whatever doc she's reading from, not misread or mistranscribed. | email read out only --------------- DOOD = day out of days, according to KJ "a more broad and general description of the day's shooting schedule" |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2014-05-25 11:11 pm or 11:32 pm | Amber Heard | herself | v01 via The Mirror: I mean If he doesn't know how scared I am, must be, then I must have overestimated him. (Which I don't think I have, but maybe you're right). He should know because he should love me. And know if anyone did this to you or lily rose - he's fucking kill them. He needs to be accountable. And aware enough to know that. To know how much I've been put through. And how scared I must be. I've given him a thousand sorrys and a thousand chances and couldn't have been more supportive throughout. I am not going to live my future like this. I can't sit back and be there when he finally kills himself. Insanity is doing the sme thing over and over and expecting different results. That's what I'm doing by staying in his life. I have nothing left to say. He doesn't have the impetus to fix this - to fix us - then it wasn't important enough to him. Bottom line. I have done all the fixing - all the carrying - all the putting my faith into him and being disappointed and lied to over and over. Now it's time for HIM to do the caring. He needs to care for himself. He needs to fix us. Fix this. Not me. If I fix it again, it will all happen again. And I'm done. If he seems confused, feel free to explain to him. Or don't. Not sure it matters at this point. I need time and space to recover. The man I love and want to marry called me an embarrassment and a whore, among other things, in front of a plane full of people who did NOTHING before kicking me - kicking me in the back and then mocked me for crying about it immediately after. v02 via UK Trial transcript: If he doesn't know how scared I am, must be, then I have overestimated him, which I don't think I have, but maybe you are right. He should know because he should love me and know if anyone did this to you or Lily-Rose, he'd fucking kill them. He needs to be accountable and aware enough to know that, to know how much I've been put through and how scared I must be. I've given him a thousand sorrys and a thousand chances and couldn't have been more supportive throughout. I'm not going to live my future like this. I can sit back and be there when he finally kills himself. Insanity is doing the same thing over and over and expecting different results. That's what I'm doing by staying in his life. I have nothing left to say. He doesn't have the impetus to fix this, to fix us, then it wasn't important enough to him. Bottom line, I have done all the fixing, all the carrying, all the putting my faith into him being disappointed and lied to over and over. Now its time for him to do the caring. He needs to care for himself. He needs to fix us, fix this, not me. If I fix it again, it will happen again and I'm done. If he seems confused, feel free to explain to him or don't. I'm not sure it matters at this point. I need time and space to recover. The man I love and want to marry called me an embarrassment and a whore amongst other things in front of a plane full of people who did nothing before kicking me, kicking me in the back and then mocked me for crying about it immediately after. | According to the UK Trial, she wrote this email to herself at 11:32 pm, according to the NGN CS it was at 11:11 pm. --------------- I'd say there's a bit of a difference whether she "can" (v2) or "can't" (v1) "sit back and be there when he finally kills himself". |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2014-05-27 10:39 (am? pm?) | Stephen Deuters | Amber Heard | end of the first, start of the second line: He was very upset again last night. I stayed with him again. Important thing is that he behaved himself. These last few days have been trial by fire for him in that regard, okay. We're giving him all the support we can. As I mentioned, the Kipper meeting was very promising. Feeling like a strong bond will be made there. Saturday was a hideous blip. --------------- The transcript says "I stayed with him -- he was very upset again last night. I stayed with him again." Considering that the "--"s in these transcripts usually mean corrections, I'm assuming the first "I stayed with him" is the 2nd sentence that was read first, then Rottenborn stopped to go back and read the sentence before that, then read the 2nd one again in full. Also, the "okay" seems weird to me, so I'm not sure if this is actually part of the email (unless in the email he's asking "okay?") or, since in the transcript the "okay" is followed by "Do you see that?", if that was Rottenborn basically asking SD if he's with him ("Okay? Do you see that?"). | SD depo pg 148-151 | email read out only --------------- BN DEPP18764 |
| Date/Time | from | to | email / Subject: Update | doc | notes |
|---|---|---|---|---|---|
2014-08-18 07:54 am PDT (UTC-7) (10:54 am Bahamas time) | David Kipper | Christi Dembrowski | Christie, I am alerting you to some concerning issues that arose last night after we spoke. Amber called us at around midnight asking that we come over to their house. They evidently had a fight, she claims he pushed her, and she asked him to leave the house. We found him in the bar area, sitting quietly, and upset. We spent a long time with him discussing how he felt, what had happened, his thoughts on what sobriety actually meant for him, and how committed he truly was to the journey we were on. As we discussed in my home at our first meeting, and several times since, the "journey" was a series of transitions - first to stabilize him at an acceptable/comfortable medication dose until his filming was complete, then detoxifying him from all these substances (using other medications to insure comfort and safety), and finally re-balancing his brain chemistry with stabilizing medications - not addictive and safe. We have completed the first two phases and are now ready for round three. This was the discussion you and I had on the phone prior to Debbie and I going over there at midnight. Its difficult for me to read too much into the conversation that followed. He is uncomortable, is pessimisstic that he will ever be able to stop doing drugs, actually romanticizes the entire drug culture, and has no accountability for his behaviors. When reminded that he has had these feelings his entire life, he is able to have a glimmer of perspective, but this very history reinforces his feeling that past is prelude. He admitted to me and Debbie that he was willing to do this treatment for everyone else, but has never been clear as to how much he wanted this for himself. This conversation was unfortunately wrapped around a centerpiece of bad feelings with Amber. He has fundamental issues with anger, and when he gets mad at her for her bad behavior he has tremendous ambivalence and guilt about these feelings even being valid. When we discussed soliciting support from those in the sobriety community that he respected (Elton, Chuck) he gave what seemed to be lip service, referencing these folks more for their celebrity than their struggle with sobriety and what they could bring to his table. I also think that his need to be liked trumps his ability to actually reach out to these guys with the vulnerability that would ultimatley give him the support he needs from the community he respects. There is also an issue of patience. He is driven almost reflexibly by his id - he has no patience for not getting his needs met, has no understanding of delayed gratification, and is quite child-like in his reactions when he does not get immediate satisfaction. His motivation is also labile, and this speaks to the issue of his accountability. He has tremendous respect for you, which Debbie and I believe could be an essential positive in his ability to remain committed. Even when he speaks of his children, I don't believe he grasps the responsibility he must have in their lives. He describes the events surrounding Lily Rose's E.Coli near-death experience without much emotion, and the conversation becomes about him, not her. He admits to feeling close to suicidal at the moment when he thought she might die, but doesn't parlay this experience into anything close to a revelation about proper parenting. So, here we are. He agreed to sleeping on all this last night. He did not sound at all committed to continuing the care once we arrived in Los Angeles, but he did waiver a bit when we suggested that he and Amber take a few days apart once we landed. I think this would be critical if we are to continue his treatment. This is not so much a denouncement of Amber, but a recognition that the focus now needs to be exclusively on him. For my two cents I think he needs to remain committed, endure some discomfort (he has actually had very little), get neurochemically stable, seek an ongoing therapuetic relationship with a doctor I know that could help him, and get into the recovery community on whatever level he would accept. Short of this, his chances remain slim. He is discouraged and angry, but this is not unusual at this phasee of treatment. Our best course now is to get him back to Los Angeles, get his pharmacologic fine-tuning initiated, and add in the therapist while we have his attention. I think if you were to call him today and "take his pulse", encourage him to stay the course and trust us, it would go a long way toward keeping him on track. I am not willing to quit, since I know this is a predictable bump in anyone's treatment, and we can make a difference in his life. The problem is him - he needs to be on his own team. I am available to chat, at any time. One way or the other, we need to leave the island if there is any chance of him getting well. Another set back or failure for him would only reinforce his bad feelings about himself, his destiny to always fail, and the dark road his life has occasionally traveled. Much respect and still hope, David |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2014-08-25 time unknown | Amber Heard | Kate James | (possibly only partially read out) You can be honest with them. | KJ depo pg 96 | email read out only --------------- them = Dr. Kipper and/or Debbie Lloyd |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2014-08-27 | email exchange on August 27, 2014 between Amber Heard and Dr. David Kipper re having gotten "into an argument when Johnny didn't come home the night before or that night" & "just his basic changing of schedule request" | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: Check-in | doc | notes |
|---|---|---|---|---|---|
2014-08-28 10:01 am | Dr. Connell Cowan | Amber Heard | Hi Amber, Please give me a call today and let me know how you are. I spoke with Dr. Kipper yesterday after your meeting with him and understand things got heated. I'm sorry these times are so painful and difficult, but I do believe there can be smoother times ahead for you. You will get through this and come out the better for it. Believe in yourself. Come from strength even when you don't feel it. Hope I hear from you today Amber. By the way, are you now on Viber? I checked and didn't see your name in the directory. Connell | Def1057 pg 05 |
| Date/Time | from | to | email / Subject: --- | doc | notes |
|---|---|---|---|---|---|
2014-08-29 06:36:11 am PDT (UTC-7) | Amber Heard | Kate James | can you please discreetly trace this number for me: 512 (rest redacted) - all the info you could get would be great. thanks babe! | email via ThatBrianFella | |
2014-08-29 09:59 am | Kate James | Amber Heard | It appears that number belongs to (redacted) - I googled that name and there's a costume designer by that name - middle aged African American woman - she worked on (redacted) amongst other films | email via ThatBrianFella | |
2014-08-29 10:01 am | Amber Heard | Kate James | phew! ok - i know who that name is. a friend of J's . Saw a weird message pop up with that number - but that makes sense now all good. Xo thanks! | email via ThatBrianFella |
| Date/Time | from | to | email / Subject: New Patient JD | doc | notes |
|---|---|---|---|---|---|
2014-09-18 time unknown | David Kipper | Alan Blaustein | Alan, I am in London coming home today, after spending a week with a patient we discussed, JD. He's anxious to begin a relationship with you and I would love to "seize the moment". Obviously this would need to be a phone introduction, and perhaps just that. He's coming to Los Angeles mid-October and will be in Los Angeles until the early spring. He is doing remarkably well. I have him on a combination of Lamictal 50 milligrams, Lexapro 30 milligrams, melatonin at HS, Seroquel 25 BID, and 50 at HS, and an occasional Inderal LA 80 milligrams. He's with his girlfriend, Amber, and there are issues that we can discuss privately and not on the Internet. If you'd be able to make a phone introduction over the weekend, I can arrange for this. | AB depo pg 54-64 | email read out only --------------- BN DEPP1639-1640 (Def292) |
2014-09-18 time unknown | Alan Blaustein | David Kipper | Let's try on Sunday around 11 a.m. LA time. | AB depo pg 65 | email read out only --------------- BN DEPP1639-1640 (Def292) |
2014-09-21 time unknown | Alan Blaustein | David Kipper | Hi David. Just texted you. Never heard back from you on this, so I'm assuming there's no call scheduled. | AB depo pg 65 | email read out only --------------- BN DEPP1639-1640 (Def292) |
| Date/Time | from | to | email / Subject: JD medications | doc | notes |
|---|---|---|---|---|---|
2014-10-26 04:26 pm | Debbie Lloyd | Alan Blaustein cc David Kipper | Dr. Balustein - Per your request, here is a current list of JD's medications: QAM Adderall 15mg Inderal 80mg Lexapro 30mg Nexium 40mg Seroquel 50mg Lamictal 75mg Neurontin 300mg Cialis 10mg Valtrex 1G Noon Adderall 15mg Seroquel 25mg Neurontin 300mg 4-6pm Adderall 15 mg (this might change now that he is not working) Seroquel 25mg Neurontin 300mg HS Ambien 10mg Nexium 40mg Seroquel 50mg Neurontin 600mg Melatonin 20mg PRN Neurontin 300mg BID PRN anxiety Xanax 1-2mg BID PRN anxiety (on average he takes 1 mg QD) Seroquel 50 mg BID PRN anxiety He is looking forward to meetin you tomorrow. Things have continued to be chaotic with his relationship since he last spoke to you. Please email your availability for next week so we can schedule his appointments. Thank you, Debbie |
| Date/Time | from | to | email / Subject: Change of plans | doc | notes |
|---|---|---|---|---|---|
2014-11-03 time unknown | Kate James | Trudy Salven | I know I spoke to Erin about it. It's horrible. | KJ depo pg 77-79 | email read out only --------------- Trudy Salven = travel agent --------------- according to KJ, Amber and Erin Falati were in Myrtle Beach at the time, as Amber was filming Magic Mike XXL |
| Date/Time | from | to | email / Subject: (Fw:) Watch Johnny Depp's Bizarre Hollywood Film Awards Speech That Set Social Media Abuzz (Video) | doc | notes |
|---|---|---|---|---|---|
2014-11-15 12:20:08 pm | The Wrap | Tracey Jacobs | (sending article) | ||
2014-11-15 12:17 pm | Tracey Jacobs | Christi Dembrowski | (forwarding the article) |
| Date/Time | from | to | email / Subject: Meds | doc | notes |
|---|---|---|---|---|---|
2014-11-24 01:45 pm | Debbie Lloyd | Alan Blaustein | AM Neurontin 300 mg Seroquel 50 mg Lamictal 100 mg Cialis 10 mg Nexium 40 mg Valtrex 1 C Adderall 30 mg Afternoon Neurontin 300 mg Seroquel 50 mg Adderall 30 mg Evening Neurontin 300 mg Seroquel 50 mg HS Neurontin 600 mg Seroquel 150 mg Ambien 10 mg Melatonin 20 mg Nexium 40 mg His prn box Neurontin 300 mg #6 Seroquel 50 mg #6 Zanaflex 4mg #4 Baclofen #4 Xanax 1mg #6 The main changes were an increase in seroquel and adderall. Debbie |
| Date/Time | from | to | email / Subject: Fwd: National Enquirer Comment Request Re: Johnny Depp--Addition | doc | notes |
|---|---|---|---|---|---|
2014-12-18 12:17 pm | Patricia Gonzalez/National Enquirer | Robin Baum | Robin-- The National ENQUIRER is preparing to publish a story that Johnny Depp has turned his party palace into a rehab retreat. Sources tell The ENQUIRER the embattled actor - who embarrassed himself with a bizarre and seemingly intoxicated speech at the Hollywood Film Awards on November 14 - has entered an at-home treatment program. Rather than checking into a traditional clinic, Depp is getting help for his booze battle by participating in rehab from the comfort of his multi-million dollar Los Angeles home - a technique previously pioneered by Charlie Sheen. The treatment forced the 51-year-old to skp the premiere for his Christmas Day blockbuster "Into the Woods," which debuted at the Ziegfeld Theatre in New York City on December 8, according to a top Hollywood source. "It raised a lot of questions," said the source. "People were discreetly told that Johnny is relying on professionals to help him through this fight, in private." "The decision was motivated at least in part by concerns over Johnny's privacy -- having caregivers come to him eliminates the risk of fellow patients or clinic staff spilling the beans about his treatment." Please kindly attempt to provide any comment by 10 am ET tomorrow, Friday, December 19th to Lachlan Cartwright, Executive Editor, at (phone number and email-address). Thank you, Patricia Gonzales The National Enquirer | ||
2014-12-18 10:32:11 am PST (UTC-8) | Patricia Gonzalez/National Enquirer | Robin Baum | Robin-- An addition to the comment request sent earlier today... The source also tells us that: "Johnny's problem has always been his issue with moderation. Once he starts he can't stop, and it turns him into a pic. It's got so bad that she's locked herself in the bathroom for hours waiting for him to sober up because she just can't deal with his mood swings. She understands he's still reeling with shock over his string of movie flops and he's going through a real mid-life crisis, but Amber [Heard] can't live with it anymore. She feels like some surrogate mom, who has to cook, clean, organize his diary all the time. It's not what she signed up for." Please kindly attempt to provide any comment by 10 am ET tomorrow, Friday, December 19th to Lachlan Cartwright, Executive Editor, at (phone number and email-address). Thank you, Patricia Gonzales The National Enquirer | ||
2014-12-18 11:26 am | Robin Baum | Christi Dembrowski | (forwarding email from Patricia Gonzalez/National Enquirer) | ||
2014-12-18 10:09 pm | Robin Baum | Jodi Gottlieb | (forwarding email from Patricia Gonzalez/National Enquirer) |
2015
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2015-01-07 | Exh 241 "Email String, 1-7-15" re Tryon loan | TJ (2019) depo pg 35 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: Today's appointment | doc | notes |
|---|---|---|---|---|---|
2015-01-12 10:52 am | Alan Blaustein | Debbie Lloyd | Hi Debbie Just got your voice mail message. Fortunately, my appointment with him is for 2:45 today. Hopefully, he'll wake up in time for that. Also, please send me current meds list. Thanks again. Alan | ||
2015-01-12 11:10 am | Debbie Lloyd | Alan Blaustein | Current Meds: am Wellbutrin 300mg Lexapro 30mg Seroquel 50mg Neurontin 300mg Lamictal 100mg Cialis 10mg Valtrex 1G Inderal LA 80mg Adderall 30mg Nexium 40mg noon Adderall 30mg Neurontin 300mg Seroquel 50mg Evening Adderall 30mg Neurontin 300mg Seroquel 50mg HS Melatonin 20mg Ambien 10mg Neurontin 600mg Seroquel 150mg Another antacid (can't remember name and don't have Meds in front of me. Will get it to you later) Stephen is confirming 2:45. Will let u know. Debbie |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-01-27 06:11 pm | Dr. David Kipper | Dr. Connell Cowan | v01 (CC): Con, sorry for getting back to you late. I'm swamped. Amber and JD have been fighting non-stop since he confirmed his need for a prenup on their way to the airport (going to Japan to promote his movie). She tried to push up the date up of the wedding to avoid all this, but the reality is he will need a prenup. If she fails to sign, they won't get married. Both behaved like super triple DD types, complete with thrown coffee, attempts to storm the cockpit by him to turn the plane around, and attempts by her to leave the plane while they were over the fucking ocean, et cetera. They are due home in a day and or so, but, as I point out him, she is in control because she can either sign or not sign. I told him if she didn't sign, I would buy him another island. v02 (DK): Connell, sorry for getting back to you late. I'm swamped. Amber and JD have been fighting nonstop since he confirmed his need for a prenup on their way to the airport going to Japan to promote his movie. She tried to push up the date of the wedding to avoid all this, but the reality is he'll need a prenup. If she fails to sign, they won't get married. Both behaved like super triple DD types, complete with thrown coffee, attempts to storm the cockpit by him to turn the plane around, attempts by her to leave the plane while they were over the fucking ocean, etcetera. v03 (UK Trial): Con, sorry for getting back to you late. I am swamped, Amber and JD have been fighting non-stop since he confirmed his need for a pre-nup on their way to the airport going to Japan to promote his movie. She tried to push up the date of the wedding to avoid all this, but the reality is he'll need a pre-nup. If she fails to sign, they won't get married. Both behaved like super triple D types. v04 (UK J): Amber and JD have been fighting non-stop since he confirmed his need for a prenup on the way to the airport (going to Japan to promote his movie). She tried to push up the date of the wedding to avoid all this, but the reality is he will need a pre-nup. If she fails to sign, they won’t get married. Both behaved like super triple DD types, complete with thrown coffee, attempts by him to storm the cockpit, attempts by her to leave the plane while thy were over the fuckin ocean, etc. | parts of the email read out only --------------- BN DEPP1634-1635 (Plt44) |
| Date/Time | from | to | email / Subject: Rough idea | doc | notes |
|---|---|---|---|---|---|
2015-02-01 08:09:37 pm EST (UTC-5) | Amber Heard | James Merifield Little Halls Pond Cay cc Whitney Henriquez cc Raquel Pennington | SCHEDULE FOR WEEKEND: 2/3: Jerry, Stephen, Gina, iO and Morgann arrive . Time TBD 2/4: Crew 1 arrives -10am, Breakfast / lunch for everyone upon arrival -7pm, Dinner for seventeen guests 2/5: Crew 2 arrives (guests and staff) -Breakfast for seventeen -Lunch for aprox. twenty guest -Dinner for all guests, approximately thirty four 2/6: Rehearsal day -Breakfast for thirty four -Lunch for thirty four -4pm Rehearsal/Run-thru -7pm Rehearsal Dinner -After, dance party and drugs and music 2/7: Big day! -Breakfast for thirty four ROS: 11a - 2p: -Bridal party, hair and make up (place TBD) -Russel to provide snacks and beverages 2pm - 3:30pm: -Groomsmen and Bridal Party pictures (separate, of course!) 3:30pm: Cocktail Reception, in Large Tent -Tray passed h 'devours and champagne 4:30pm: Seating guests for ceremony on LR Beach 5pm - 6:30pm: -Groomsmen & Bridal Party get into place -Ceremony 6:30p: Cocktails/Dinner, in Large Tent -6:30 cocktails -7:15 sit for dinner -7:30 dinner is served 9:30/10 - Party time 2/8 - Crew 2 departs (evening, time TBD) -10am, Breakfast for thirty four -Lunch/Dinner for eleven | re Wedding weekend schedule |
| Date/Time | from | to | email / Subject: Nice to meet you over the phone | doc | notes |
|---|---|---|---|---|---|
2015-02-02 time unknown | Michele Mulrooney | Dana Lowy | I look forward to working with you. Please send me the bullet points for the economics of the deal when you are back in the office tomorrow. I will have Amber's business manager get her financial information to me asap. I also like to exchange two years of tax returns, but not attach them. Is this your general practice? Let me know. Thanks. | MM depo pg 14 | email read out only --------------- Def1604 |
| Date/Time | from | to | email / Subject: J/A Deal Points | doc | notes |
|---|---|---|---|---|---|
2015-02-03 10:13 (am?) | Dana Lowy | Michele Mulrooney | paraphased only: "it lists a number of proposed terms for this prenuptial agreement" | MM depo pg 19/20 | email paraphrased only --------------- Def340 |
2015-02-03 time unknown | Michele Mulrooney | Dana Lowy | I have emailed these points to Amber and her entertainment attorney. I don't know if she will get back to me today since the plan is for them to get married today. I assume that if they do actually get legally married, these points are for a post-nuptial agreement. I will get back to you as soon as I can. Best, Michele | MM depo pg 24 | email read out only --------------- Def340 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-02-04 time unknown | Amber Heard | Kate James | ARE THERE NO DIRECT FLIGHTS??! | KJ depo pg 160 | email read out only --------------- part of an email chain starting on Feb 03 with, based on Kate's testimony, previous emails (involving travel agent Trudy Salven) being about Amber "traveling straight to London after the wedding" |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2015-02-?? | Exh 11 "E-Mail Chain", e-mail exchange between Kate James & Amber Heard regarding the termination of Kate's employment | KJ depo pg 107-114 | if you're willing & able to transcribe this exhibit, please let me know |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2015-02-12 | Depp Exh 04 "E-Mail Chain", e-mail from Amber Heard to Kate James on or about February 12, 2015 | KJ depo pg 157/158 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-02-17 time unknown | Bruce Witkin | Joel Mandel | partial email only: I'm real worried about him and this Dr. Kipper. | BW depo pg 33 | partial email read out only |
| Date/Time | from | to | email / Subject: A/J | doc | notes |
|---|---|---|---|---|---|
2015-02-17 time unknown | Dana Lowy | Michele Mulrooney | Hi Michele, I hope all is well. I will have a draft Postnuptial Agreement to you in the next few days for you to review with A. In the meantime, prior to providing financial disclosures, I have attached a Confidentiality Agreement for you to sign and for A to sign and initial each page. As you can see, J has already signed and initialed. I look forward to working with you. Best regards, Dana (attached to the email: 12-page Confidentiality Agreement + attachments) | MM depo pg 25-27 | email read out only --------------- possibly Def343 |
2015-02-17 time unknown | Michele Mulrooney | Dana Lowy | Dana, I have forwarded to Amber. She is filming a movie, but hope to connect with her by the end of the week. I will keep trying to move forward. | MM depo pg 29 | email read out only --------------- possibly Def1605 |
2015-02-17 time unknown | Dana Lowy | Michele Mulrooney | Thanks Michele. | MM depo pg 30 | email read out only --------------- possibly Def1605 |
2015-02-18 time unknown | Michele Mulrooney | Dana Lowy | Amber is sending the signed confidentiality agreement to me. I assume I will receive all the underlying financials and a list of anticipated future revenue streams and documentation pertaining thereto after. I can't really comment on the document until I get this information. paraphrased only: "then you also asked for a copy of the marriage license" | MM depo pg 31-34 | email read out only --------------- possibly Def1606 |
| Date/Time | from | to | email / Subject: P 5 | doc | notes |
|---|---|---|---|---|---|
2015-02-26 03:57 pm | Tracey Jacobs | Christi Dembrowski | Sean bailey did call me. There were 300 extras yesterday. Disney is going to give him 2 days ish to correct the lateness and then there will be a problem. Was he with the foo fighters last night? Xxx | ||
2015-02-26 04:00 pm | Christi Dembrowski | Tracey Jacobs | Not that I know of. | ||
2015-02-26 04:01 pm | Tracey Jacobs | Christi Dembrowski | It will get ugly if the lateness doesn't change. Has anyone spoken to him? Xxx | ||
2015-02-26 04:03 pm | Christi Dembrowski | Tracey Jacobs | Anyone as in who? Jerry did last week when he was super late. He himself said he needs to get turned around. | ||
2015-02-26 04:07 pm | Tracey Jacobs | Christi Dembrowski | Stephen or nathan or you? Sam dickerman also just called me. He said he"hoped this was a wake-up call.". They say he's great but you know the problem. Xxx | ||
2015-02-26 04:08 pm | Tracey Jacobs | Christi Dembrowski | Sam is in australia and reporting all this. | ||
2015-02-26 04:18 pm | Christi Dembrowski | Tracey Jacobs | Sam was just in LA | ||
2015-02-26 04:21:04 pm | Tracey Jacobs | Christi Dembrowski | He just called me from australia. He's on set. Sean called me from la. X |
| Date/Time | from | to | email / Subject: Johnny/P5 | doc | notes |
|---|---|---|---|---|---|
2015-02-27 11:22 am | Sean Bailey | Tracey Jacobs | 8 hours late yesterday. We're a day behind on our schedule. I've lw for Christi. Thx | lw = left word --------------- TJ transcript says "John Bailey" instead of Sean Bailey | |
2015-02-27 11:41 am | Tracey Jacobs | Christi Dembrowski | (sending SB's email to Christi) | ||
2015-02-27 11:54 am | Christi Dembrowski | Tracey Jacobs | Yeah. I will call him. | ||
2015-02-27 12:31 pm | Tracey Jacobs | Christi Dembrowski | Bruckheimer just called me and said if hes not on time Monday, we have a real problem. I don't know what to do. Jerry isn't there on location, so I don't know who will be speaking to him. | ||
2015-02-27 12:34 pm | Christi Dembrowski | Tracey Jacobs | I will see what we can do to make sure he knows and understands. I know he felt bad about the other day so he was mindful of needing to get turned around. What kind of problems could it be? | ||
2015-02-27 12:40 pm | Tracey Jacobs | Christi Dembrowski | Jerry said hes been late evry day at least 2 hours. He also referenced his lateness on alice 2 and Mordechai, which clearly is out there. Is there anything I can do? Jerry is very positive about his work, as is the studio but the lateness is undermining all of this. jerry also referenced the weight which he said is noticeable. I also asked Jerry why he isn't there, but he isn't. so the next people who will be talking to him will be Disney and or he directors. Call me when you can speak. x | ||
2015-02-27 12:50 pm | Christi Dembrowski | Tracey Jacobs | The everyday time frame seems to grow. He told me 1 to 1-1/2 hrs, but not two. Yes he was 2-1/2 hours late one day and 7hrs recently. I know all of it and what he needs to do. I think he knows also. Working on how to get him there but I don't know what to tell you to do to help. I know you could call or email or go thru the guys but not sure how that would go over if it's just telling him what he needs to do to be better. That's not always helpful with all people to be honest. I can't talk right now nor do I want to rehash it all. Perhaps I will get thoughts together in a better way and call you later but I don't want to just talk about what we already know over and over. Sorry. I will find a way to call Sean a bit later for sure. i get it. Xoxoxo | ||
2015-02-27 12:56:56 pm | Tracey Jacobs | Christi Dembrowski | Ok xoxo |
| Date/Time | from | to | email / Subject: J is in some trouble | doc | notes |
|---|---|---|---|---|---|
2015-03-01 time unknown | Alan Blaustein | David Kipper | Hi David, sending you this e-mail to two addresses. Want to make sure you're receiving my e-mails since I haven't heard back from you. I've been in touch with Debbie in AUS about J and it doesn't sound like he's doing very well. Thought it might be a good idea to talk and see if there's anything we can do to help. I've offered to speak with him, but so far he hasn't set up anything with me. I last spoke to him in mid-January, so I'm way behind on what's going on with him. Let me know if you'd like to talk about him, and strategize if there's some role I can play in his care. Also, want to make sure you got my note updating you about Betty and thanking you for your care. | AB depo pg 108/109 | email read out only --------------- BN DEPP1636-37 (Def351) |
2015-03-01 02:10 pm | David Kipper | Alan Blaustein | (first talks about the previously mentioned Betty, unrelated to JD) J is in some trouble and I've been in touch with the camp in Australia and his sister at home. Debbie is worried and somewhat exhausted and he is doing what he wants since his friend Marilyn Manson is there visiting. The big problem has been his sleep issue. this part paraphrased only: Dr. Kipper informs Dr. Blaustein "that he's added metformin to the list of drugs that he's prescribing to Mr. Depp" and "that he'd asked Ms. Lloyd to increase the Neurontin that Mr. Depp was taking" (...?) If he doesn't come home, I am planning to go out there tomorrow night for a few days to get him back on track. (...?) then at the bottom of the email: When and where I see him I'm going to insist he reestablishes dialogue with you. | email read out only --------------- BN DEPP1636-37 (Def351) | |
2015-03-01 time unknown | Alan Blaustein | David Kipper | Thanks, David, for the update. Glad the e-mail stuff is working again. Sounds like a difficult time in Australia. I wonder if we shouldn't get Marc Schoen back in the loop. Perhaps he can have him start up the hypnotherapy audio once again. I haven't used metformin yet. Looking forward to hearing more about your experience. (in the deposition transcript "hypnotherapy" was transcribed as "hypotherapy", and based on the response in the deposition after this was read out, I assume it was misread and correctly spelled in the actual e-mail) | AB depo pg 115/116 | email read out only --------------- BN DEPP1636-37 (Def351) |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2015-03-02/03 | Exh 9 "3/2/15 and 3/3/15 e-mail string", Michele Mulrooney and Dany Lowy trying to schedule a meeting on March 02 and March 03, 2015 | MM depo pg 37/38 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: A/J | doc | notes |
|---|---|---|---|---|---|
2015-03-04 time unknown | Dana Lowy | Michele Mulrooney | Hi Michele, thank you for forwarding the Confidentiality Agreement. I have now signed. Please sign and also please date for Amber and forward a fully executed copy to me. We will be back in touch. Best, Dana (with confidentiality agreement attached) | MM depo pg 39/40 | email read out only --------------- possibly Def1658 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-03-04 time unknown | Dani Lespron | Dana Lowy | Hi Dana, Michele Mulrooney asked that I send you the attached signed/dated pages. Please let me know if I can be of further assistance. | MM depo pg 41-43 | email read out only --------------- date based on exhibit description "3/4/15 and 3/5/15 e-mail string" |
2015-03-04 or 05 time unknown | Dana Lowy | Dani Lespron | Thank you. | MM depo pg 41-43 | email read out only |
2015-03-05 10:08 am | Dani Lespron | Michele Mulrooney | FYI - Dana Lowy confirmed receipt of the signed/dated pages. with confidentiality agreement attached | MM depo pg 41-43 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
~2015-03-08 time unknown | Dr. David Kipper | Lisa Beane | (telling her to please print for Johnny Depp's chart) | DK depo pg 124 | email read out only --------------- presumably around March 08, 2015 |
2015-03-08 time unknown | Dr. Raja Sawhney | Dr. David Kipper | Thank you for your time, David. Attached is a copy of my notes for you to use as necessary, re Robert Wells. 51M, right ring finger injury and distal detipping. Right-hand dominant. Unclear history of traumatic event and no witnesses. Patient under the influence and not coherent. Not sure of mechanism. Accompanied by his physician, Dr. Kipper, who has given him Toradol and Augmentin, 870 milligrams orally. On examination, conversant and pleasant when awake, but not coherent. Heavily contaminated hand and fingers with dirt, grime, and paint. (according to the UK Judgment, the email says "not coherent nor sure of mechanism") | DK depo pg 125 UK Judgment pg 73 | email read out only --------------- Robert Wells = JD |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-03-09 time unknown | Dr. David Kipper | Erin Falati | Erin, love you too (much). (...?) I'm sure JD will let her know we are coming home. I want her to please not see him for a few days until we can get him organized with the hand surgeon and get his meds balanced. Please use the excuse that Dr. Kipper insists that JD stay quiet without any distraction for the rest of the week while we get his medication organized and balanced. None of this will be accepted by her but I will be very upset (you can tell her this) if there is any stress created by a visit that is premature. Please reiterate to her that I want her to see Cowan every day if he can this week to help her organize her thoughts and take accountability for her part in the fighting before she sees him. the transcript says "if she can go -- if he can" which usually indicates that something was misread & corrected, so I assume the email says "if he can" | EF depo pg 247-253 | email read out only --------------- BN Falati 0134-0135 (Plt474, Falati 0134 = Plt 53) |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-03-11 time unknown | Michael Singer | Robin Baum | The story below is on Daily Mail Australia's website, which means it will go out on the Mail's other international sites. It's more than likely that local and other media will contact me for comment or confirmation. I will make none unless advised otherwise by you. part of the story: "The actor is rumored to have broken his right wrist go-karting on a private track." | RB depo pg 152-154 | email read out only --------------- Michael Singer = POTC5's unit publicist |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-03-15 time unknown | David Kipper | Debbie Lloyd | Letter sent today. Love you, Deb. I hope he starts making good decisions. I am so sad about all this. (DK depo says "I'm so sad about this.") (...?) attachment: johnny depp termination letter.docx the attached letter (partially read out): paragraph 01: Johnny, I am so sorry for your struggle. The events over the past several days and our inability to properly monitor your safety are beyond concerning and I don't feel I am helping you. As we discussed earlier today, regarding your surgery Monday, it's my responsibility to the surgeon to clear you medically for this procedure, and I'm now uncomfortable doing so. v01 EF depo: Further, the nurse supervision has broken down and this places you at great risk of medication interactions that can prove harmful. OR v02 DL depo: Further, the nurse supervision has also broken down and this places you at a greater risk for medication interactions that can prove harmful. OR v03 DK depo: Further, the nurse supervision has also broken down, and this places you at great risk for medical interactions that could prove harmful. paragraph 02: It is with a very sad heart that I must withdraw my care. (...?) I also believe that re-engaging with Amber without a professional third party to help guide you both through your issues will not be productive. The last time you both addressed the issues ended in disaster (...?) What I believe you need is a clear system without any substances that could (DL depo: can) interfere with your medications and jeopardize your surgical procedure. Without this assurance, based on behaviors and not promises, I'm putting you at risk. I refuse to put you in this dangerous position. paragraph 03: I know you're suffering and it breaks my heart. I'll be there for you if you decide to let me back in with the boundaries I feel are necessary. I am asking our nurses to leave you a week's worth of medications to avoid any precipitous changes in your treatment. I am aware that you are now impaired, emotionally and physically, which is preventing us from being effective. last paragraph: I know you told the nurse tonight that you can find your own doctor and nurses, and I hope this will be a better path to your health and happiness. (...?) I encourage you to at least connect with Dr. Blaustein who knows you well to help you obtain another resource for your continued care. | email read out only --------------- BN DEPP1794 & DEPP1795 (Def614 & Def391) --------------- I would have assumed that the "I also believe" part came after the "What I believe" one, but it was read out in this order in the DK depo. |
| Date/Time | from | to | email / Subject: Letter Sent Today (?) | doc | notes |
|---|---|---|---|---|---|
2015-03-15 time unknown | Dr. David Kipper | Dr. Connell Cowan | Conn, I sent this letter out to him today after another night of broken promises to remain sober and compliant. Details are not important, or frankly, any different from the past few weeks. I received his immediate response via text, which acknowledged my position and without a plea for changing behavior. I am feeling sad, incredibly sad, since I did like him, feel like I failed him, and all the neurotic feelings an old Jew is entitled to have and exploit. I know I did the right thing. I know he was at risk for surgery tomorrow. I also know about my own abandonment feelings and the definition of projected identification (if I'm even close). I did receive your message and will do the comps. It's funny, or sad, depending on how you look at it - the last vacation I had was a year ago for my birthday in Utah, our annual trek with Chanel's cousins and their little kids - and at night I was doing comps on aging books (which I just pulled out of my ski boot bag). Let's make a promise I won't have to do this next year. Thanks for listening. You're an amazing friend. You don't have a private island, but I'm willing to overlook that. | CC depo pg 116-118 | email read out only |
2015-03-15 time unknown | Dr. Connell Cowan | Dr. David Kipper | David, my friend, you just did the hardest thing. It doesn't matter that it was the right thing, it still hurts. Somewhere along the line, J will have to face consequences. You may very well have provided him an invaluable learning experience. Irrespective, you did the only thing you could do, closed the door, but not the latch. I have asked Amber to lay low, stay away, and observe. Only J can decide if he is worth saving. You went a hundred miles beyond what anyone else would have done. Why don't you take a couple of pounds of your Jewish guilt and bury it in some Utah snow? | CC depo pg 118/119 | email read out only |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2015-03-17 | Exh 22 "Chain of e-mails dated 3/17/15 with Courier Mail article" re headline | RB depo pg 160 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: --- | doc | notes |
|---|---|---|---|---|---|
2015-03-18 09:32 pm | Christian Carino | Dr. Laurel Anderson cc Amber Heard | Laurel... my closest friend amber (on copy) wants to come see you. Alone first...and then with her husband, Johnny. Will leave it to you two to arrange a time. Love you both. | BN CC172 | |
2015-03-19 08:43 am | Dr. Laurel Anderson | Christian Carino | Hey Christian, OK, got your message. I have openings on a cancellation/travel basis right now--but they exist. Will be glad to talk to Amber and figure out a time to meet. Can sort out what else might be needed later. Please just ask her to leave me a message and a phone number. Hope your life is going well. Laurel | BN CC172 | |
2015-03-19 09:41:12 am (UTC-7) | Christian Carino | Dr. Laurel Anderson cc Amber Heard | To make it easy here are the phone numbers: Amber's cell: redacted Laurel's office: redacted Thanks Laurel. | BN CC172 | |
2015-03-19 time unknown | Amber Heard | Dr. Laurel Anderson cc Christian Carino? | So I was hoping that perhaps I could give you a call and maybe see if there is a way to commence some sort of process with you. | LA depo pg 88 | email read out only --------------- BN CC159 --------------- Based on exhibit description this email was sent on March 19 as a reply to CC's March 18 email. Since this is a different email chain and there was no time given, I'm not sure about the exact chronological order |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-03-28 05:16 pm | Kevin Murphy | Amber Heard | Hi.. Just making sure you know that the dogs will not be allowed to fly commercial in the passenger compartment to Aus. They would have to go cargo. They do not make exceptions for service dogs to Aus. Just want to make sure you understood. It has been a very complex process thus far. The all in cost will be around 10k (not including flight) Just wanted you to know. Per our last discussion re the dogs travel...... I should proceed... Right? They would be able to travel at the end of April with a 10 day quarantine upon arrival. Delivery to the house somewhere around may 7th (est). K |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-03-29 time unknown | Kevin Murphy | Amber Heard | Hi. Because of the paperwork process (combination of vet visits and permit application) for pet travel to Australia the time frame for the dogs to be able to travel there was always the end of April. We started the process quite some time ago. I think J is returning around the 10th/12th. I believe the dogs are not able to enter Australia til the 27th. Let me know if you have additional questions. | ||
2015-03-29 time unknown | Amber Heard | Kevin Murphy | Shit. Ok. Hum.... We're out of options then? Because I don't know what else to do. | ||
2015-03-29 time unknown | Kevin Murphy | Amber Heard | Morning.... Would you allow them to fly cargo? | ||
2015-03-29 time unknown | Amber Heard | Kevin Murphy | (message not shown) |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-03-30 time unknown | Kevin Murphy | Amber Heard | Hi I will have to continue the process for the dogs if they are going. There will be some non refundable charges. Can you advise please. Thanks | ||
2015-03-31 time unknown | Amber Heard | Kevin Murphy | I'm sorry but as I understood it, they were't able to travel with J. and since they couldn't travel with him, they won't be able to go at all. no? So what process needs to be continued exactly? | ||
2015-03-31 time unknown | Kevin Murphy | Amber Heard | We never concluded the original conversation other than you saying "no" to cargo. If that means that the dogs will not travel then I will discontinue the travel paper process. Thanks K | ||
2015-04-01 time unknown | Amber Heard | Kevin Murphy | Yeah- unless there's another way to get them there or get them on the plane with J. I can't send them in cargo. It's too dangerous. |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-04-09 time unknown | Debbie Lloyd | David Kipper | David, I couldn't sleep last night. I have major concerns about leaving for Australia with JD. I'm not saying I won't go, but every part of my body is telling me it's a poor decision. (differences between DL and DK transcripts are just "I am" vs. "I'm", "it is" vs. "it's" and a missing comma before "but") | email read out only --------------- BN DEPP1794 or DEPP1795 (Def614 or Def391) |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-04-10 time unknown | Tracey Jacobs | Jake Bloom Christi Dembrowski Joel Mandel Michael Schenkman | Crossed to 208 million! Japan was huge. We are owed some back end! | TJ 2019 depo pg 84/85 | email read out only --------------- re worldwide gross of Into the Woods |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-04-13 time unknown | Amber Heard | Amy Banks | partially read out: As with some of life's most rewarding gifts, I happened upon your book by accident... at just the right time. I picked it up in the airport (while in transit, fleeing the most traumatic and crushing situation I have ever faced) and spent the next few days in the precious comfort of your insight and advice. It with a plea of confidence that I can say after 3 and a half years of the most trying and compelling relationship I have ever known, I finally married the man with whom I am desperately in love. However I write to you today because those years, the relationship and my heart, has arrived at a breaking point. | AB depo pg 35/36 | email partially read out only (1st paragraph not read out) |
2015-04-13 time unknown | Amy Banks | Amber Heard | email paraphrased only: Q: "And you responded in this e-mail that you would -- you could help Amber, correct?" A: "I believe I said that I would try to help, yes." | AB depo pg 35/36 | email paraphrased only |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2015-04-14 | Exh 172 "Email String, 4-14-15" re January 2015 payments made to UTA, but not to Johnny Depp | TJ (2019) depo pg 36/37 40-42 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: Ummm | doc | notes |
|---|---|---|---|---|---|
2015-04-14 time unknown | John Lesher | Tracey Jacobs Scott Cooper | I called you. He didn't show up. Very upsetting. Hopefully he will be there tomorrow. We have to pay for the stage time even if he doesn't come. | CD depo pg 178 | email read out only --------------- BN DEPP19239 (Def415) |
2015-04-15 time unknown | Tracey Jacobs | Christi Dembrowski | (forwarding JL's email to Christi) | CD depo pg 178 | email read out only --------------- BN DEPP19239 (Def415) |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-04-20 time unknown | Chelsea Perrotty (Star Magazine) | Robin Baum | (asking about whether or not it's true that the marriage is strained due to alcohol and insecurity over Amber Heard's relationship with iO Tillett Wright) | RB depo pg 178-181 | email read out only --------------- BN BAUM364-365 (Def426) |
2015-04-20 time unknown | Robin Baum | Christie Dembrowski | I don't think we should buy into this. It will pass. | RB depo pg 178-181 | email read out only --------------- BN BAUM364-365 (Def426) --------------- based on exhibit description, this email was sent to Christi Dembrowski |
| Date/Time | from | to | email / Subject: JD Update | doc | notes |
|---|---|---|---|---|---|
2015-06-27 time unknown | Dr. Kulber | Dr. Kalamaras cc Debbie Lloyd | CT of finger looks quite good considering, aside from bone spikes which are related to this bad crush injury. I agree with the plan. Thank you for update and such great care. | DL depo pg 169 | email read out only --------------- BN DEPP5751-53 (Def443) |
| Date/Time | from | to | email / Subject: William Freidkin | doc | notes |
|---|---|---|---|---|---|
2015-08-29 time unknown | Tracey Jacobs | Johnny Depp | (redacted) | ||
2015-08-29 08:23 am | Johnny Depp | Tracey Jacobs | i NEED YOU to get on to the fucking harley's regarding LONDON FIELDS!!! they are going to be PREMIERING IT AT THE TORONTO FILM FESTIVAL!!! despite our LETTER OF LEGAL ACTION if they used their version and not the Matthew Cullen version!!! it is in Amber's contract that there will be NO NUDITY and her fucking agent's are weak and insipid!!! also, they were told that i would NOT ALLOW THEM TO USE ANY OF MY WORK IN THE FILM, as i had agreed to do the film based on Matthew..!!!! will you PLEASE CALL THESE MOTHERFUCKERS and you and Jake get on this IMMEDIATELY!!!??? | "harley's" was a typo and was supposed to say "Hanleys", the producers of the movie | |
2015-08-29 time unknown | Tracey Jacobs | Johnny Depp | I'm already on it with lawyers and Marty Singer, have spoken to Matthew Cullen twice this AM. He also wants it stopped. We are doing everything to shut this down. --------------- (transcript says "Stinger", but it was correctly read as "Singer" in the deposition video) | email read out only, redacted in exhibit | |
2015-08-29 08:37:37 am | Johnny Depp | Tracey Jacobs | IT MUST BE SHUT DOWN, OR I WILL SUE THEM EIGHTEEN WAYS FROM FUCKING SUNDAY!!! THEYSE PEOPLE ARE NOBODYS IN THIS BUSINESS AND THEY SHOULD BE MADE TO UNDERSTAND THAT WE WILL RUIN THEM INSTANTLY!!!!!!!!!!!!!!!!!!!!!!! |
| Date/Time | from | to | email / Subject: Did you tell Johnny | doc | notes |
|---|---|---|---|---|---|
2015-09-02 time unknown | Tracey Jacobs | Joel Mandel cc Christi Dembrowski | He needs to make 25 million by the end of the year? What are you doing????? I'm in Europe. --------------- based on the testimony, what's written in the email is a continuation of the subject, meaning it's supposed to be read as "Did you tell Johnny he needs to make 25 million by the end of the year?" Also, according to the transcript, the email starts with a "y", which the lawyer believes to mean "why", but Tracey clarifies that it's a typo, so to avoid confusion, I left it out. | email read out only --------------- Def469 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-09-04 time unknown | Tracey Jacobs | Robin Baum | If you have to break down the door, just get him there on time. X | RB depo pg 53-55 | email read out only --------------- BN BAUM000990 |
2015-09-04 time unknown | Robin Baum | Tracey Jacobs | Ha. He's in makeup now, that's good. | RB depo pg 53-55 | email read out only --------------- BN BAUM000990 |
2015-09-04 time unknown | Tracey Jacobs | Robin Baum | Are he and Amber fighting? | RB depo pg 53-55 | email read out only --------------- BN BAUM000990 |
2015-09-04 time unknown | Robin Baum | Tracey Jacobs | They are good, not fighting. And they had an early night. | RB depo pg 53-55 | email read out only --------------- BN BAUM000990 |
| Date/Time | from | to | email / Subject: jd/speech | doc | notes |
|---|---|---|---|---|---|
2015-09-04 time unknown | Stephen Deuters | Robin Baum cc Christi Dembrowski | (not read out, attaching document with JD's speech for an event that he ended up not using) part of the speech: "My wife has been called in the press by a so-called journalist everything from a 'gold-digger' to a 'home-wrecker'... How fucking dare anyone who calls themselves a journalist write something as cruel as this?" | RB depo pg 155/156 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-09-09 time unknown | Christian Carino | Dr. Laurel Anderson cc Amber Heard? | (trying to set up a meeting with Dr. Laurel Anderson, Amber Heard & Johnny Depp) | LA depo pg 37 | email summed up only |
2015-09-09 time unknown | Dr. Laurel Anderson | Christian Carino cc Amber Heard? | (email not read out) | LA depo pg 37 | email mentioned only |
2015-09-10 time unknown | Amber Heard | Dr. Laurel Anderson cc Christian Carino? | Hi Laurel. Thank you so much for responding. I really appreciate it. I have to speak to my husband when he's done working today and make sure he's good with that time. I think it sounds perfect. Thank you so much again. I'm really looking forward to meeting you. | LA depo pg 38 | email read out only --------------- date based on exhibit description --------------- Exhibit Anderson 4 = Def473 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-09-10 time unknown | Andrew Thau (UTA) | Tracey Jacobs | I have the person for Jake to speak with. | TJ 2019 depo pg 80-82 | email read out only --------------- according to TJ, this was regarding loan for JD |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-09-27 time unknown | Amber Heard | Dr. Laurel Anderson | Hi Laurel. Johnny and I are back in town and would love to know if you have any availability to see us this week. Please let me know. Thanks. | LA depo pg 39 | email read out only |
2015-09-30 time unknown | Dr. Laurel Anderson | Amber Heard | responded that she was "available on Thursday at 5:30 pm" | LA depo pg 39 | email paraphrased only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-09-30 time unknown | Tracey Jacobs | Christi Dembrowski | We're going to deal with Shep on money of the 'Vampires.' I talked to Jay (J?) about it. Shep is ripping him off. --------------- (transcript says "Jay", I assume the email actually says "J", as in Johnny, because the "him" in the sentence after refers to JD, but there's a possibility that the email said "Jake" (Bloom, who is mentioned below) and it was misheard as "Jay") | TJ 2019 depo pg 72-78 | email read out only --------------- BN UTA21493-21494 (Def489) --------------- I assume Shep is Shep Gordon |
2015-09-30 time unknown | Christi Dembrowski | Tracey Jacobs | (not read out) | TJ 2019 depo pg 72-78 | email read out only --------------- BN UTA21493-21494 (Def489) |
2015-09-30 time unknown | Tracey Jacobs | Christi Dembrowski | I feel really bad that you think I don't. Why don't you ask Jake? | TJ 2019 depo pg 72-78 | email read out only --------------- BN UTA21493-21494 (Def489) |
| Date/Time | from | to | email / Subject: Attorney Privilege - Heard Statement-Current draft | doc | notes |
|---|---|---|---|---|---|
2015-10-09 time unknown | Karl Austen | Marty Singer Amber Heard? | (email mentioned by MS in later email) | email mentioned only | |
2015-10-09 03:28 pm | Marty Singer | Karl Austen Amber Heard | That would be great. | ||
2015-10-09 time unknown | Amber Heard | Karl Austen Marty Singer | Great! I will procure that statement ASAP and send it to you guys. Anything in specific that would be extra important/helpful? Please let me know if there's anything that I should specifically asked for... Also, I spoke to Kevin and he said that he sent you guys all of the evidence of the dogs numerous international travels. The only thing that we are missing is evidence of the process being initiated however not completed and therefore the dogs weren't taking on the trip. That is harder to prove obviously since it involves documenting something that DIDNT happen. However, since I know we attempted to bring them at least once before the Australian trip, I can ask Kate to include that in her statement if that would be helpful? | ||
2015-10-11 08:58 am | Amber Heard | Marty Singer Karl Austen | Marty - I'm waiting to hear back from you before I reach out to Kevin to liaise with Kate. A H | ||
2015-10-11 07:29 am | Marty Singer | Amber Heard Karl Austen | Amber If you look at my email below on October 9, I responded to Karl's email when he said that he thought you could get Kate to sign a statement " That would be great. " Therefore if you could get Kate to sign a statement, it would be helpful. I don't know what your relationship with her is at this time since you fired her. You have to be careful that she will cooperate and will not go public, if you ask her not to be truthful | via Mythnmonsters v01 / v02 email via ThatBrianFella UK Judgment pg 33 UK07//1135 & 1136 AH WS05 pg 14 & 15 | |
2015-10-11 04:50:32 pm (GMT+1) (UTC+1) | Karl Austen | Marty Singer cc Amber Heard cc Jonathan Klein | Indeed. | ||
2015-10-11 04:02 pm | Amber Heard | Kevin Murphy cc Marty Singer | forwarding the email exchange between her, Karl Austen and Marty Singer, and writing: Kevin, What do you think???? Could you possibly reach out for us?? Do you think you could get her to do it? |
| Date/Time | from | to | email / Subject: Any update | doc | notes |
|---|---|---|---|---|---|
2015-10-23 time unknown | Tracey Jacobs | Joel Mandel | With B of A? What about selling the back-ends? | TJ 2018 depo pg 112, 115 | email read out only --------------- the beginning of the email seems to be a continuation of the subject, meaning "Any update with B of A?" --------------- B of A = Bank of America |
| Date/Time | from | to | email / Subject: Paul D. | doc | notes |
|---|---|---|---|---|---|
2015-11-14 time unknown | Raul Anaya (Bank of America) | Andrew Thau (UTA) | We spoke to Joel on Friday and we are moving it along. There may be a shortfall in value from his art collection, so we are getting an appraisal on it. We hope to have a better sense of what we can do once we get the appraisals back. As we discussed, issue is he is asset-rich, but CF-poor for now. We know it will change so we are trying to figure out the right structure for him. I will update you as we get more info. | TJ 2018 depo pg 117/118 | email read out only --------------- it's unclear whether "Paul D" (subject line) is another alias for JD, since TJ doesn't recognize the name |
2015-11-14 time unknown | Tracey Jacobs | Jake Bloom's assistant (Danny) Joel Mandel | From our contact at Bank of America. | TJ 2018 depo pg 117/118 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-11-16 time unknown | Tracey Jacobs | Joel Mandel | Johnny said he is seeing you at 1:00 p.m. today. Hope it goes well. I told him to listen, and we are all here to help him. | TJ 2018 depo pg 137 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-12-04 time unknown | Erin Falati | Dr. David Kipper | Hello good sir, just wanted to let you know I still have not heard from JD. I'll let you know as soon as I hear from him. I want to talk with you, though, when you have some time. I wanted to offer some thoughts I have on the discussion he and I had last Sunday and reassure you that I do not believe JD sees any of us as anything other than trustworthy and for making him our concern and priority. To be honest, I'd be surprised if he recalled much of what we discussed, and also have some concerns that he'll make the 11:00 a.m. meeting. I know you have a Bar Mitzvah on Saturday and don't want you to be late, so if I do not hear from JD soon I'll also call Amber to confirm as she was planning on joining. Please do not worry or feel concerned about anything we do or our level of care or our costs for services. If JD really were worried about any of the above, he wouldn't continue services, nor would he explicitly tell me over and over how much he loves and respects you. The transcript says "last Saturday -- Sunday", which usually means something was misread, then corrected, so I'm assuming the email said Sunday. The transcript also says "he would continue services", don't know if misread, mistranscribed or accidentally written in the email like this, but obviously it's supposed to say "wouldn't continue services" for it to make sense. | EF depo pg 133-135 | email read out only --------------- BN DEPP1638 (Def506) --------------- exhibit description says the email was sent on November 10, but according to Adam Nadelhaft it was sent on December 04, 2015, so either there are more emails on that one exhibit page (DEPP1638) or one of the dates is wrong |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2015-12-16 01:00 am | Amber Heard | Jodi Gottlieb | I had a bad accident tonight Jodi. I'm really bruised and might have a black eye or two tmrw - same with my nose. Nurse on the way to make sure I don't have a concussion. There's a chance I might not be fit for tomorrow. But won't know how bad the bruising is until the morning. Giving you a heads up. I'll call you tmrw to let you know- k? (not to be confused with the similar text Amber sent to Jodi on Dec 15 at 11:52 pm) | ||
2015-12-16 02:49 am | Amber Heard | Jessica Kovacevic Assistant | I had an accident tonight Jessica. I'm really bruised and might have a black eye or two tmrw - same with my nose. Nurse on the way to make sure I don't have a concussion. There's a chance I might not be fit for tomorrow. But won't know how bad the bruising is until the morning. Giving you a heads up. I'll call you tmrw to let you know-k? Can we push to my morning stunt appt to the next morning perhaps ?? |
| Date/Time | from | to | email / Subject: Call this weekend? | doc | notes |
|---|---|---|---|---|---|
2015-12-19 04:08:57 pm | Amber Heard | Dr. Laurel Anderson | Hey Laurel, i am sorry to report that unfortunately things don't seem to be progressing well. I wish I could tell you why... In part, I am sure from the time and type of messages I'm getting from him, that his use is continuing (and not helping). However, knowing this, I am still lost as to how to get through to him (via text message, as this is the form in which we have been communicating) and at least put off resolving this until after the holiday. Do you think that you would be able to speak by phone today or tomorrow? Or help me in any other way wrap my head around what to do? I do have my own therapist but unfortunately the nuances and complexity of our relationship - and subsequently my reaction- are a bit lost on him. So without putting much pressure on you and your otherwise peaceful holiday, can I ask for your help on the phone ? Maybe I could show you our communication and you could tell me your advice?? Any help would be appreciated. I feel so lost. AH | Plt237 (via the Daily Mail) |
2016
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-01-19 time unknown | Andrew Thau | Tracey Jacobs | (explains status of things) | email not read out --------------- BN UTA 24 | |
2016-01-19 time unknown | Tracey Jacobs | Joel Mandel | (referring to Andrew's email) This is good news. Also, I may have two other offers in the next week. | email read out only --------------- BN UTA 24 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-01-21 time unknown | Tracey Jacobs | unknown (several people) | My office is going to be setting a meeting for next Thursday, January 28th, with Johnny at his office. Please allocate two hours' time for the meeting so we have enough time. Thank you. | TJ 2018 depo pg 139 | email read out only --------------- presumably referring to the meeting where according to Tracey JD asked for 15/20 million dollars |
| Date/Time | from | to | email / Subject: Johnny | doc | notes |
|---|---|---|---|---|---|
2016-01-26 time unknown | Tracey Jacobs | Joel Mandel Jim Berkus Jeremy Zimmer Jacob Bloom | On Thursday, Joel will walk him through the math of what he has to do to be financially okay. He needs to do two big movies this year, plus commercials, and selling the French house. (v02 via Jacob Bloom depo: "(...) what he needs to do (...) and sell the French house.") | email read out only --------------- BN DEPP19215 // UTA 017 (Def604) |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2016-02-05 | Exh 68 "February 5, 2016 e-mail chain" re Agreement in Consideration of Guaranty between Johnny Depp & UTA re planned Bank of America loan | TJ (2018) depo pg 155/156 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-02-12 time unknown | Tracey Jacobs | Joel Mandel cc Christi Dembrowski people from Bloom Hergott (cc?) | Joel, you really need to speak to him Tuesday to explain the need for him to do a film, even if not this one. I just spoke to the music manager, who told me Johnny may gross 100 grand a week for a couple weeks, max. v02 of 2nd sentence: I spoke to the music manager who told me Johnny may gross 100 grand a week for a couple of weeks max. | email read out only | |
2016-02-12 a couple of minutes later | Tracey Jacobs | Joel Mandel Christi Dembrowski (cc?) people from Bloom Hergott (cc?) | Also, she wants to know next week that she can book more July dates, and into August. This will render him unavailable for potentially any movies this year. | TJ 2018 depo pg 144-146 | email read out only |
| Date/Time | from | to | email / Subject: The tour | doc | notes |
|---|---|---|---|---|---|
2016-03-07 time unknown | Tracey Jacobs | Joel Mandel | Christi just told me J is doing the tour until August. Did you ever e-mail or text him? This flies in the face of what we discussed last week. | email read out only --------------- Def641 |
| Date/Time | from | to | email / Subject: a & jd | doc | notes |
|---|---|---|---|---|---|
2016-03-08 06:23 am | Christian Carino | Dr. Laurel Anderson | Would you be willing to make a house call to Johnny's apartment downtown? | LA depo pg 50/51, 146 | email read out only |
2016-03-08 07:27 am | Dr. Laurel Anderson | Christian Carino | Hey Christian, Have, of course, avoided this my whole career, unless someone was in rehab. Would be willing to try it once in that there's something I'd like Johnny to understand that I don't think he does. | LA depo pg 50/51, 147 | email read out only |
| Date/Time | from | to | email / Subject: Turkish air | doc | notes |
|---|---|---|---|---|---|
2016-03-09 time unknown | Tracey Jacobs | Gueran Ducoty (UTA) cc Christi Dembrowski & cc others | We must get redline contract so Christi can get Johnny and we can have to get signed ASAP. We need to get the 4 million immediately. Please!!!! (transcript says "with a number of exclamation marks behind it", don't know how many) v02: We must get red line contract so Christi can get Johnny. And we have to get signed ASAP. We need to get the four million immediately. Please. | email read out only --------------- regarding a $15 million offer for a Turkish Air commercial |
| Date/Time | from | to | email / Subject: The Ginger Man | doc | notes |
|---|---|---|---|---|---|
~2016-03-24 time unknown | ? (Fahar?) | Tracey Jacobs | Bank of California were talking about a loan against personal security from Johnny, which obviously we can't allow. | email read out only --------------- regarding loan to fund the filming of The Ginger Man | |
2016-03-24 time unknown | Tracey Jacobs | Christi Dembrowski | (forwarding the above email to Christi) How do you want to deal with this? I don't want to get involved with the bank. | email read out only --------------- regarding loan to fund the filming of The Ginger Man |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2016-04-28/29 | Exh 28 "Chain of e-mails dated 4/28/16 and 4/29/16" re Met Ball attendance in 2016 | RB depo pg 182/183 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: What happened | doc | notes |
|---|---|---|---|---|---|
2016-05-22 07:44 or 55 am | iO Tillett Wright | Amber Heard | At 8pm PST Amber texted me and asked me to call her. When I called her she explained that Johnny was convinced that we had defecated in his bed as some kind of prank. I started laughing at the absurdity of the situation, which he heard because Amber had put the phone on speaker phone. Johnny then walked away, which she told me, and went upstairs. I asked her why she was in a house with someone who had previously attacked her. She explained that his mother had died and she was worried about him and he needed some items from the house before going on tour with his band. I then heard Johnny come back downstairs and he picked up the phone and started yelling expletives at me. Still on speakerphone, I told Amber that she should get out of the house because I could tell that he was potentially going to get violent. At that point, I heard the phone be thrown. Shortly thereafter Amber pick the phone back up and explained that he had thrown it directly at her face and hit her with it. At that point I heard Johnny say "oh you think I hit you? What about if I pull your hair back?" The phone then dropped, I heard Amber shriek, and she yelled at me to please call 911. At that point I hung up texted Raquel that she needed to immediately go to penthouse 3 to intervene, and called the police. | NGN CS page 114 says iO's email was sent at 7:55, page 135 says it was sent at 7:44. |
| Date/Time | from | to | email / Subject: Statement from JD & RP | doc | notes |
|---|---|---|---|---|---|
2016-05-22 09:43:38 pm | Josh Drew | Amber Heard | (2 docs with statements attached) -------------------------- Josh Drew statement: The purpose of this document is to describe, in the best possible manner, my description of events I was directly witness to on the evening of Saturday, May 21. At 8:06PM, Amber sent a text to Raquel asking her to come over to PH3, where she was engaged in conversation with her husband, Johnny. I was in PH5 with Liz, waiting for them to complete the conversation. Approximately 15 minutes later, we heard Johnny shouting, and saw (through the peephole) both of his security team rush over in the direction of PH3. We heard him continue to shout, as well as what sounded like banging on the walls (which was confirmed with the dents and scratches on the doors, as well as the wine spilled all over the hallway). During this, I locked the door to PH5 (we left the doors unlocked to let the girls freely travel from apartment to apartment throughout the day). I heard Johnny come up to the door and shout at his security to "open this fucking door, let me in this fucking place." Which they did without hesitation. He walked in and immediately started screaming at me. I can't remember exactly what he was saying, but it was a reputation something along the lines of: "Get the fuck out of my house," "You motherfuckers fucking sold me out," so on and so forth. The whole time, no more than 6" from my face, spitting in my face the whole time. I didn't respond in any way, rather, calmly made my way to the door. I had forgotten my keys, so I turned around to grab them. He followed me every step of the way throughout, screaming and spitting in my face. I did not see where Liz went to, as I thought she was right behind me. He made a beeline to go right at her, and she ran away. After I had left, I heard him screaming and smashing things inside the apartment as I made my way over to PH3 to check on Raquel & Amber, during which they relayed what had occurred. I moved them over to our apartment PH1, and dead-bolted the door until we were certain he had left. I kept them inside PH1, and went down to the garage to confirm their departure. At 8:46PM, I started getting calls from his head of security, Jerry, as Johnny had left his phone there, and Jerry wanted me to bring it down for him to pick up. I told him not to pull into the complex, and that I would meet him at the front door. We had a verbal confrontation in the process of handing off the phone, which I can provide further detail should the need arise. I declare under penalty of perjury that the foregoing is true and correct. Executed on Sunday, May 22. -------------------------- Raquel Pennington statement: The purpose of this document is to describe, in the best possible manner, my description of events I was directly witness to on the evening of Saturday, May 21. At approximately 7:15, Amber informed me that her husband Johnny would be coming over shortly to pick up a few of his personal effects & discuss their current situation. At 8:06PM I received a text from Amber asking me to come over to PH3 right away. At 8:09PM I texted back to confirm she needed me immediately. At 8:11PM I knocked on the door. The door was locked so I went back, grabbed my keys, knocked again, heard Johnny yelling. I immediately unlocked the door and came in to see him standing in the kitchen area. I asked if everything was ok, to which Amber replied "No. Help me." Johnny had a magnum of wine in his hand, and told me to leave. I looked at Amber holding her face & her head, and she then told me that he threw her phone at her and hit her, and to please help her. He proceeded to argue, deny any and all wrongdoing, all while continuing to move closer to Amber. I stepped in front of him to shield her from him and put my hands on his chest, telling him to "stay away from her." To this, he replied "get your fucking hands off me." He then proceeded shoved my hands out of the way, which I then put back on his chest. He shouted "Oh you want to be fucking tough now, where's your fucking bearded boyfriend, you've got what you want, you've got her to yourself." He then backed away, saying "the DNA test will prove it, We Will Find Out who did this." He walked over to the kitchen area to grab his bag I then went over to the couch to console Amber, who curled up in my arms, saying "I didn't do anything, I just called Io to confirm the story, I didn't do anything." While holding her on the couch, he starts yelling unintelligibly, ranting obscenities & random accusations specifically at Amber throughout. He grabs his bag & the wine, makes to leave, then turns around and comes back towards us, walks right up in front of us (still on the couch), states "Amber, get up," repeatedly, at least 10 times. All the while, no more than a foot away from us, with me still cradling her. At this point his security, Jerry & Sean came in. As soon as they come in, he retreated away, about 15 feet. Amber got up to head towards the bathroom, telling Jerry that if he "hits me one more time I'm calling the cops." Johnny denied that he had struck her. He said that he had "thrown her phone at her, and that's what she's accusing me of." Amber then repeated what she had said before "I didn't do anything, if he hits me one more time I'm calling the cops." He then went into the kitchen area and started smashing things at random. His security did nothing but stand behind him. No effort was made to restrain him, no acknowledgment was made of the abuse, nor did they make any verbal effort to try and diffuse the situation or get him to walk away. He then stormed out of the apartment, screaming unintelligibly. That was the last I saw of him that evening. I heard him yelling and breaking things for the next 15-30 minutes in the hallway and other apartments. When I went to find Amber's phone and purse in PH3 and PHS, still not knowing if he was on the premises, I discovered broken belongings. This included my art that had been thrown against the wall, Amber's office that had been ransacked, framed photos that had been smashed and glass broken, and art that had been taken from the wall and left on the bed in Amber's room. In the public hallway there were puddles of spilled wine on the floor and splashed on the walls, and dents in the doors. Amber was in my apartment (PH1) when the police arrived. To my knowledge he had already vacated the premises. I declare under penalty of perjury that the foregoing is true and correct. Executed on Sunday, May 22. |
| Date/Time | from | to | email / Subject: Marriage of Depp - EX PARTE NOTICE 5/27/2016 8:30 am Dept 6 LASC | doc | notes |
|---|---|---|---|---|---|
2016-05-26 09:52 am | Samantha F. Spector | Laura Wasser cc Samantha Klein cc Linda Bigbee | Hi Laura, I called your office and requested to speak to you as well as to Samantha Klein. I was directed to each of your respective voicemails. I then asked to speak to your assistant Linda Bigbee and, in turn, received her voicemail as well. Thus, as a follow up to my voicemail message left for you this morning at 9:45 am, I am confirming I have provided you with ex parte notice that we will be appearing on behalf of Amber Depp tomorrow, May 27, 2016 at 8:30 am in Dept. 6 of the Los Angeles Superior Court located at 111 North Hill Street, Los Angeles, CA 90012, before the Honorable Carl H. Moor, on an ex parte application to seeks a DV CLETS TRO order against Johnny Depp which will include requests for (1) pendente lite spousal support payable by Johnny to Amber; (2) Amber's exclusive use and possession of the 849 S. Broadway residence; (3) exclusive use and possession of the black Range Rover vehicle which Amber is currently driving; (4) Amber's exclusive possession of the dogs, Pistol and Boo; and (5) a contributive payment by Johnny for Amber's attorney fees and accounting costs. Best, Samantha |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2016-05-26/27 | Exh 12 "Chain of e-mails dated 5/26/16 and 5/27/16" re E!News/NBCUniversal running a story on Johnny and Amber split | RB depo pg 117-119 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-05-27 time unknown | Stephanie Marcus (Huffington Post) | Robin Baum | (reaching out regarding the restraining order Amber Heard is seeking against Johnny Depp) | RB depo pg 163/164 | email paraphrased or summed up only |
2016-05-29? time unknown | Robin Baum | Stephanie Marcus (Huffington Post) | Are you around for a quick off the record conversation? | RB depo pg 163/164 | email read out only |
| Date/Time | from | to | email / Subject: thinking of you | doc | notes |
|---|---|---|---|---|---|
2016-05-28 10:01:33 pm (UTC-4) 07:01:33 pm (UTC-7) 2016-05-29 02:01:33 am (UTC+0) | Amy Banks | Amber Heard | Hi Amber - just caught something in the times about you and Johnny divorcing and a restraining order. I am hoping that you are safe and with friends... just wanted you to know I am thinking of you, knowing some of what you have gone through. Be well, Amy | Lexington, Massachusetts = UTC-4 |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2016-05-29 | Exh 29 "Chain of e-mails dated 5/29/16" re THR article & Alice Through The Looking Glass box office | RB depo pg 184 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-05-30 time unknown | JD Heyman (People) | Robin Baum | People has just obtained these images of Amber Heard, showing injuries she says Johnny Depp gave her in December, as referenced in court filing. | RB depo 121-123 | email read out only --------------- BN BAUM1474-75 (Def813) |
2016-05-30 time unknown | Robin Baum | JD Heyman (People) | Will you be posting these photos online or will they be part of a cover story? | RB depo 121-123 | email read out only --------------- BN BAUM1474-75 (Def813) |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-06-02 time unknown | Christi Dembrowski | Robin Baum | She is so gross. More so because we know she has said that. She's awful. I can't wait till we kill her in court. | RB depo pg 166 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-06-07 time unknown | Tasya van Ree | Amber Heard | sending Amber her statement: "In 2009, Amber was wrongfully accused for an incident that was misinterpreted and over-sensationalised by two individuals in a power position. I recount hints of misogynistic attitudes toward us which later appeared to be homophobic when they found out we were domestic partners and not just 'friends'. Charges were quickly dropped and she was released moments later. It's disheartening that Amber's integrity and story are being questioned yet again. Amber is a brilliant, honest and beautiful woman and I have the utmost respect for her. We shared five wonderful years together and remain close to this day." | ||
2016-06-08 time unknown | Amber Heard | Jodi Gottlieb | AH forwarding TvR email to Jodi Gottlieb | email summed up only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-06-27 time unknown | Kevin Murphy | Laura Wasser | Remembering something. This is a pic of the remote control at 1480 house that's cracked because Amber through it at JD and hit him in the forehead. About a year ago or so. K (photo attached) | ||
2016-06-28 time unknown | Laura Wasser | Kevin Murphy | Nice. Thank you. |
| Date/Time | from | to | email / Subject: re Hi | doc | notes |
|---|---|---|---|---|---|
2016-07-31 time unknown | Melanie Inglessis | Amber Heard | I understand you are torn as you still love your husband and you miss him, but I really don't think it's a good idea, you even considering going back. First and foremost, how can you go back? What is there to go back to? What future do you see? It's doomed. There's nothing good or happy or healthy that is going to come out of you going back. Nothing at all. You are just delaying the inevitable. He is a mad man. Always has been. Always will be. He is a delusional addict, with a violent behavior when intoxicated and he beats on you. He has demons and will suck the life and the youth out of you and spit you out in a couple of years, if it even lasts that long or doesn't end more tragically. You go back, you will fight again and he will beat on you again except the next time the public won't believe you and your friends and your sister won't be next door. You will be surrounded by his people only. Who knows what kind of fuckin' crazy shit could happen. Every move that you will make will most likely be documented and recorded just in case. Your life will be hell. Please make the right choices towards healing and rebuilding versus self-destruction. | MI depo pg 84/85 | email read out only --------------- Def852 |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2016-08?-?? | Exh 9 "e-mail" e-mail chain between Laura Wasser and Samantha Spector regarding Amber Heard's deposition day | LW depo pg 210-216 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: DEPP - Client Acknowledgment and Consent re Waiver of 1/2 Interest in Community Back-End Deals | doc | notes |
|---|---|---|---|---|---|
2016-08-06 12:41:39 am PDT (UTC-7) | Samantha Spector | Amber Heard cc herself cc Joseph Koenig | Amber, As a follow up to our call tonight, the attached letter which was sent to Laura tonight (dated August 8, 2016) is worded specifically so that you are not making any specific demands, but it clearly extends your willingness to be extremely generous by waiving your 1/2 interest in the back-end of Pirates 5, etc. Joe Sweeney, your forensic accountant, has reviewed the financial documentation provided to him thus far from Ed White. From Sweeney's analysis, he determined that Pirates 1, which was released in 2003, has resulted in profit-participation payments made to Johnny from his back-end deal for the 12 months ended March 31, 2016 of approximately $700,000 or more. Johnny's profit-participation (back-end deal) for Pirates 4, to date, has earned Johnny over $33,000,000. Based on that fact that Johnny made Pirates 5 during marriage, Pirates 5 is a community property asset and, therefore, you are entitled to 1/2 of the income from this asset. Although one cannot predict with accuracy the amount of profit-participation that will be earned by Johnny from Pirates 5, it is important for you to note and understand that from back-end deals, Johnny has made over $21,000,000 from Pirates 1, and he has made over $33,000,000 from Pirates 4. Accordingly, by waiving your 1/2 interest in the back-end deal of Pirates 5 (i.e., the profit-participation), not to mention any other projects such as Boswell in which Johnny made during marriage, you would potentially be foregoing tens of millions of dollars in income to you in the future. Simply put, given Sweeney's analysis, you are potentially leaving a lot of money (to wit, tens of millions of dollars payable to you) on the table by waiving your interest in Johnny's back-end deals for projects he worked on during marriage. Therefore, you will need to print out, and date and sign this email below, and thereafter return the executed document to me, to signify your express confirmation that you understand what you are choosing to do. Candidly, you are being amazingly true to your word, that this is not about the money. With tremendous respect, you are walking away from a lot of money. Yet, as your attorneys we cannot be held responsible for making that decision and we cannot recommend to you that you walk away and waive your rights to this community asset/money. We ask that you proceed with great caution and prudence as this is a decision only you can make. Please take the time to think carefully about this decision to waive your 1/2 interest in all of the back-end deals of Johnny for all projects which he worked on during marriage, and should we reach a settlement today or in the near future, you will need to first sign-off on this email before doing so. All my best, Samantha I, AMBER LAURA HEARD, HAVE READ, AND HEREBY ACKNOWLEDGE AND UNDERSTAND THE CONTENTS OF THIS EMAIL. I HAVE NO FURTHER QUESTIONS OF MY ATTORNEYS, I HEREBY ACKNOWELDGE I HAVE BEEN FULLY INFORMED OF MY COMMUNITY PROPERTY RIGHTS IN MY DISSOLUTION OF MARRIAGE PROCEEDING WITH JOHNNY DEPP, AND AGAINST THE EXPRESS RECOMMENDATION OF MY ATTORNEYS, I HAVE INDEPENDENTLY CHOSEN, ON MY OWN FREE WILL AND VOLITION, TO WAIVE MY ONE-HALF (1/2) INTEREST AND CLAIM IN THE COMMUNITY'S ESTATE/ASSET WITH REGARD TO JOHNNY'S PROFIT-PARTICIPATION (I.E., BACK-END DEALS) FOR ANY AND ALL PROJECTS JOHNNY COMPLETED DURING MARRIAGE (SUCH AS, PIRATES 5 AND BOSWELL, AS WELL AS ANY OTHER PROJECTS HE WORKED ON DURING MARRIAGE). I VOLUNTARILY MAKE THIS DECISION TO WAIVE MY RIGHTS AS NOTED HEREIN AND DO SO UNDER NO COERICION, UNDUE INFLUENCE OR DURESS. ______________________________________________ AMBER LAURA HEARD Dated: _______________________ | ||
2016-08-06 time unknown | Amber Heard | Christian Carino | (redacted) | based on exhibit description ("Email - Amber Heard to Carino, 8/6/16, Fw Spector email with waiver") and Laura Wasser depo transcript page 189, the redacted email in the doc is from AH to CC |
| Date/Time | from | to | email / Subject: Dec medical records | doc | notes |
|---|---|---|---|---|---|
2016-08-08 02:03:37 pm | Amber Heard | David Kipper | Hey there, as per our conversation earlier is it possible to get my medical records from the month of December, please? I know I saw Monroe during one of my office visits, if it makes it easier for you to find... I'm not sure. Anyway, it was great talking to you earlier XO Thanks! |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2016-08-16 | Exh 16 "Chain of e-mails dated 8/16/16" re divorce settlement statement | RB depo pg 126/127 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: Connecting You Guys | doc | notes |
|---|---|---|---|---|---|
2016-08-18 01:14 pm | Elon Musk | Amber Heard Anthony Romero (ACLU) | Amber, I described your plan to donate $3.5 million to the ACLU over the next 10 years, as you very much believe in what they are doing. | TD depo pg 227, 229, 403/404 | email read out only --------------- Def1637 |
2016-08-19 time unknown | Anthony Romero (ACLU) | Amber Heard cc Elon Musk | Dear Amber, I've just learned that the first portion of your gift has arrived. | TD depo pg 227, 229, 403/404 | email read out only --------------- Def1637 |
| Date/Time | from | to | email / Subject: Potential Amber Heard Donation | doc | notes |
|---|---|---|---|---|---|
2016-08-18 time unknown | Stephen Smith (ACLU) | Stacy Sullivan? / ACLU communications department | Anthony has heard that Johnny Depp's soon-to-be ex, Amber Heard, is considering donating a portion of her divorce settlement to the ACLU. She may go public with that decision as soon as today. | TD depo pg 91-94 | email read out only --------------- Plt4 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-08-18 06:30 pm | Andrea Mandell (USA Today) | Stephen Smith (ACLU) | Can you confirm the amount donated? | TD depo pg 96-98 | email read out only |
2016-08-18 time unknown | Stephen Smith (ACLU) | Andrea Mandell (USA Today) | Hi Andrea: I don't have the exact number yet - I will let you know when I do. | TD depo pg 96-98 | email read out only |
| Date/Time | from | to | email / Subject: Lots Of Twitter Chatter About This (Johnny Depp's Ex) | doc | notes |
|---|---|---|---|---|---|
2016-08-18 time unknown | Diana Scholl (ACLU) | ACLU colleagues | Executive decision, tweeted. (incl. link to a twitter statement regarding Amber Heard's donations) | TD depo pg 114/115 | email read out only |
2016-08-18 08:32 pm | Stephen Smith (ACLU) | Diana Scholl (ACLU) & colleagues | Okay. Let's just hope that the donation comes through! | TD depo pg 114/115 | email read out only |
| Date/Time | from | to | email / Subject: unknown / NonProfit Times/Amber Heard | doc | notes |
|---|---|---|---|---|---|
~2016-08-18 time unknown | NonProfit Times | ACLU | Good morning, I'm reaching out regarding the $3.5 million gift Ms. Heard has reportedly gifted to the ACLU. | TD depo pg 122-127 | email read out only |
2016-08-18 time unknown | Stephen Smith (ACLU) | Thomas Dresslar (ACLU) | I just spoke with Anthony about this. Can you have Sandra Park handle? Make sure she's armed with Anthony's quote and the attached final fact sheet. Anthony's quote: "We are incredibly grateful that Ms. Heard has so generously shown her support for the important and necessary advocacy for victims of domestic violence." attaching the fact sheet "The ACLU's Work to Defend Victims of Domestic Violence" | TD depo pg 122-127 | email read out only |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2016-08-19 | Exh 3 "8/19/16 E-Mail, 'Re: Entertainment Tonight / Amber Heard'" | TD depo pg 101-106 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
~2016-08-19 time unknown | Holly (NBC Universal/E! News) | ACLU media | (not read out) | TD depo pg 109-112 | email not read out |
~2016-08-19 time unknown | Thomas Dresslar (ACLU) | Holly (NBC Universal/E! News) | (responding to Holly's email with a "prepared statement that was put together in order to respond to media inquiries" incl. a link to the ACLU website) | TD depo pg 109-112 | email not read out |
~2016-08-19 time unknown | Holly (NBC Universal/E! News) | ACLU media | Can you clarify if you've already received the donation or not? | TD depo pg 109-112 | email read out only |
2016-08-19 time unknown | Thomas Dresslar (ACLU) | Stephen Smith (ACLU) | Can you answer this question? | TD depo pg 109-112 | email read out only |
| Date/Time | from | to | email / Subject: Fusion/Amber Heard Donation | doc | notes |
|---|---|---|---|---|---|
2016-08-19 time unknown | reporter (Fusion) | ACLU media | (reaching out about the planned donation to the ACLU) | TD depo pg 119/120, 151 | email summed up only |
2016-08-19 11:59 am | Thomas Dresslar (ACLU) | Stephen Smith (ACLU) | Here's another one. By the way, Sandra has not gotten back to me. | TD depo pg 119/120, 151 | email read out only |
2016-08-19 time unknown | Stephen Smith (ACLU) | Thomas Dresslar (ACLU) | What about Cristel? | TD depo pg 119/120, 151 | email read out only |
| Date/Time | from | to | email / Subject: Mailing Address For Amber Heard's PR Rep? | doc | notes |
|---|---|---|---|---|---|
2016-08-19 time unknown | Mimi Clara (ACLU) | Stephen Smith (ACLU) | Hi, Steve, Congrats on the Amber Heard publicity. I'm drafting her acknowledgment letter. By chance have her publicist's mailing address? (don't know if there was a "do you" that wasn't read out or if that's actually how the question was phrased) | TD depo pg 128-130 | email read out only --------------- Plt5 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-08-23 time unknown | Amber Heard | Amy Banks | Hope you're well. I can't remember if I responded at the time or not, but in case I didn't, I want you to know how much I appreciate it that you checked on me... This may or may not surprise you, but I'm still very much "in it" and dealing with a lot. | AB depo pg 62-64 | email read out only |
2016-08-23 time unknown | Amy Banks | Amber Heard | Hi Amber - glad to hear from you. Have been very concerned, and you are right, not surprised you are still very much in it as you would say. Would be happy to help in any way that I can. | AB depo pg 62-64 | email read out only |
| Date/Time | from | to | email / Subject: Heard donation | doc | notes |
|---|---|---|---|---|---|
2016-08-25 12:44 pm | Hector Villagra (ACLU) | Anthony Romero (ACLU) | Anthony, I hope you are doing well. I keep hearing about all the money you are raising for the centennial campaign and can only imagine how worn out you must be. I hope you are finding time for yourself. Coincidentally, I am writing with good news regarding your fundraising efforts. Late last night we received a couriered package at the office here in LA with a check and commitment letter regarding the Amber Heard pledge. Thank you for working your magic! I've attached the full letter, but the heart of the message that accompanied the $100k check read that this gift made "in the name of Amber Heard ... represents the first of multiple scheduled installments to honor the full amount of Ms. Heard's $3,500,000 pledged gift." The actual check is from Mr. Depp (c/o his CPA) and handwritten on the check, it says "Donation being made in the name of Amber Heard." My staff let me know that you have been the point person, so I wanted to check in with you directly with this update. Thanks, Hector | ||
2016-08-25 09:53 am | Anthony Romero (ACLU) | Hector Villagra (ACLU) cc Mark Wier (ACLU) cc Terence Dougherty (ACLU) | Hi hector Can you coordinate with Mark Wier? I thought we had received a $350k wire from amber already. So am a bit confused. We need to make sure we aren't being paid by multiple sources. Anthony | ||
2016-08-25 12:56 pm | Hector Villagra (ACLU) | Anthony Romero (ACLU) cc Mark Wier (ACLU) cc Terence Dougherty (ACLU) | Will do. | ||
2016-08-25 10:38 am | Mark Wier (ACLU) | Hector Villagra (ACLU) Anthony Romero (ACLU) cc Terence Dougherty (ACLU) | Hi Hector, we already received Amber's payment of $350,000, so it's possible the $100,000 is a mistake, especially since the check is from Mr. Depp. We'll do some sleuthing on our end. In the meantime, you may want to hold off on processing the check until we get clarity. | ||
2016-08-25 01:53 pm | Hector Villagra (ACLU) | Mark Wier (ACLU) | Was the payment directly from Amber? Is the concern that she thought the money was coming to her and she would be donating to the ACLU and is perhaps unaware that he is sending the money to the ACLU directly? | ||
2016-08-25 10:56 am (GMT-8) (UTC-8) | Mark Wier (ACLU) | Hector Villagra (ACLU) cc Mimi Clara (ACLU) | Yes, the $350,000 was from her. That's exactly the concern. | ||
2016-08-25 02:02 pm | Hector Villagra (ACLU) | Mark Wier (ACLU) cc Mimi Clara (ACLU) | Got it. We will hold the check. We will let you know if we receive anything else. | ||
2016-08-25 11:12 am | Mark Wier (ACLU) | Hector Villagra (ACLU) Mimi Clara (ACLU) | Just spoke with Anthony, who just got off the phone with Elon Musk. We're going to draft an email from Anthony to Amber explaining the situation and asking for her advice. I'll keep you in the loop, but definitely hold the check until we get clearance from Amber. Thanks! | ||
2016-08-25 02:36 pm | Hector Villagra (ACLU) | Mark Wier (ACLU) | We have more folks than I knew who follow TMZ. Here's their latest report: Amber Heard Calls BS on Johnny's Charity Donation, Now You Owe Double (with link to article) | ||
2016-08-25 04:31:59 pm | Mark Wier (ACLU) | Anthony Romero (ACLU) | She's calling Johnny out on the $14M in the press... |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-08-25 time unknown | Dina Sansing (NBCUniversal/E! News) | Robin Baum | Would you be able to send me the statement regarding Johnny donating money to the ACLU and Children's Hospital? | RB depo pg 195-197 | email read out only |
2016-08-25 time unknown | Robin Baum | Dina Sansing (NBCUniversal/E! News) | Johnny Depp has sent the first of multiple installments of monies to each charity in the name of Amber Heard which when completed will honor the full amount of Ms. Heard's pledge. | RB depo pg 195-197 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2016-09-03 time unknown | Johnny Depp | unknown | If she releases anything, she will not get the dough as she will be in breach of her agreement. | email read out only |
| Date/Time | from | to | email / Subject: Check time | doc | notes |
|---|---|---|---|---|---|
2016-10-17 02:13:29 pm | Amber Heard | Anthony Romero (ACLU) | Hi there, I hope you're doing well... I am so sorry for the delay in this matter. They were highly unusual circumstances and I sincerely appreciate all of your patience and grace in helping facilitate through them... Anyway, just emailing to let you know that it is indeed all right to cash Mr. Depp's check. Thank you so much for your patience! And thank you for keeping me updated as to the ACLU's progress with things! All my best, Amber Heard | ||
2016-10-17 time unknown | Anthony Romero (ACLU) | Amber Heard | Thank you for the response. We will cash the check, but that means you have "overpaid" for this year. As you wired $350,000, and then the (?) $100,000 from Mr. Depp. So you can keep track that where you are on the overall amounts. --------------- (Transcribed from deposition video, although I'm not sure if it was read out as "and the hundred thousand" or "and a hundred thousand". The transcript says "the", but it's also missing the very first sentence, says "mean" instead of "means" and has a lot of other mistakes, so I don't know. Also, the "keep track that where" (instead of presumably "keep track of where") was either misread or actually written like this in the email.) | TD depo pg 413 | BN ACLU_2808 (Def1642) |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2016-11-01 | Exh 246 "Email To J. Bloom From M. Sinclair, 11-1-16" re conditions & commitments Johnny Depp still owed his representatives after terminating them | TJ (2019) depo pg 63 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: Vanity Fair / Amber Heard And Johnny Depp | doc | notes |
|---|---|---|---|---|---|
2016-12-15 time unknown | Hilary Weaver (Vanity Fair) | ACLU/Thomas Dresslar | (asks for information about donations Heard promised to make to the ACLU using her divorce settlement amount) | TD depo pg 155-157 | email summed up only --------------- Hilary Weaver was misspelled in the transcript as "Hillary" --------------- Plt8 |
2016-12-15 time unknown | Thomas Dresslar (ACLU) | Stephen Smith (ACLU) | What did you tell E! News yesterday about this? | TD depo pg 155-157 | email read out only --------------- Plt8 |
2016-12-15 time unknown | Stephen Smith (ACLU) | Thomas Dresslar (ACLU) | So we need to leave these pending. | TD depo pg 155-157 | email read out only --------------- Plt8 |
2017
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2017-05-24 | Exh 32 "Chain of e-mails dated 5/24/17" re London Fields lawsuits | RB depo pg 193/194 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: Saw Elon yesterday | doc | notes |
|---|---|---|---|---|---|
2017-06-20 10:59 am | Anthony Romero (ACLU) | Amber Heard | Had a lovely time. Missed you. He mentioned that you may have sent an additional $500 k gift. I checked with the office today and we did get an anonymous $500K check from Vanguard Charitable on 6/9. If this is your gift, I'm guessing you want me to apply that amount to the overall pledge. If so, we have received the $350k from you and this $500k gift. Also, I think we discussed that we should count the $100k payment we received from Depp toward your pledge amount. That would bring you up to $950k. Let me know if I got this right. Hope you are well. Sending my best. Anthony | ||
2017-06-20 02:05 pm | Amber Heard | Anthony Romero (ACLU) | Yes! sorry! Was not meant to go through vanguard. I'm so sorry that I missed you guys too! I'm back in LA to see E and he said he had a great talk with you. Sorry I missed it! I back off to Australia in a couple of days. Hope our paths cross soon! I'm really looking forward to finally meeting you. | ||
2017-06-20 03:16:11 pm PDT (UTC-7) | Anthony Romero (ACLU) | Amber Heard | Great. So the $500k is yours, right? And I will count the Depp gift toward your pledge, right? Want to make sure I code them right in the database. Had a great meeting with Elon. Love that guy. Love you too. |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2017-06-22 | email exchanges on June 22, 2017 in Def890 & Def891, which seem to "overlap": JW - Exh 4 - Def890 ("Email - Baum and Dembrowski re Johnny Depp slams Donald Trump at Glastonbury and re assassination question, 6/22/17") RB - Exh 9 - Def891 ("Email - Baum to Carino re did you see this - New documents allege Depp's management knew about his abuse of Amber Heard, 6/22/17") | if you're willing & able to transcribe these exhibits, please let me know |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2017-07-06 time unknown | Stephen Smith (ACLU) | Jon Maresco (ACLU) | Hey Jon, Have a look. I tried to mostly keep it to the facts. attaching draft statement for a potential press release which says: Actress Amber Heard has donated $500,000 to the American Civil Liberties Union, part of her pledge to support the organization and its work to protect victims of domestic violence. | TD depo pg 168/169, 171 | email read out only --------------- Plt9 |
| Date/Time | from | to | email / Subject: Amber Heard Donation Statement | doc | notes |
|---|---|---|---|---|---|
2017-07-06 time unknown | Stephen Smith (ACLU) | Mark Wier (ACLU) Michele Moore (ACLU) Anthony Romero (ACLU) Jon Maresco (ACLU) | (sending draft press release incl. headline saying "Amber Heard donates $500,000 to the ACLU") | TD depo pg 178, 180/181 | email read out only --------------- Plt10 |
2017-07-06 02:37 am | Anthony Romero (ACLU) | Amber Heard | (is sending the draft press release to Amber and according to TD's testimony is saying "that his comms folks are going to be reaching out to Tony and Jodi about recognizing the recent gift") | TD depo pg 178, 180/181 | email read out only --------------- Plt10 |
2017-07-06 time unknown | Amber Heard | Anthony Romero (ACLU) cc Tony Freinberg cc Jodi Gottlieb | I'm sending this off to them. Thank you Anthony. | TD depo pg 178, 180/181 | email read out only --------------- Plt10 |
| Date/Time | from | to | email / Subject: Pierce- statement from ACLU re: Amber Heard donation | doc | notes |
|---|---|---|---|---|---|
2017-07-07 03:28 am | Pierce O'Donnell | Amber Heard & others? | (redacted, presumably forwarding an email sent by Stephen Smith) | ||
2017-07-06 07:59:19 pm | Amber Heard | Jodi Gottlieb Tony Freinberg Stephen Smith cc John Blakeman cc Eric George & others (redacted) | Stephen, thank you for reaching out. I am no longer working with Pierce but instead now working with my new lawyer, Eric George (cc'd here). We have a call set for an hour from now to talk about this with my PR team. Their concern is that the press could potentially spin the fact that this is an installment (and not the entire lump sum, as you well know isn't possible due to the structure of the settlement agreement) against me in some way. Also, we are tracking down a confirmation/ statement from Children's as well, although I don't necessarily think we should wait on that. Stephen, I'll have my team reach out after we've spoken, if that's alright? Thanks again. |
| Date/Time | from | to | email / Subject: Amber Heard Update | doc | notes |
|---|---|---|---|---|---|
2017-07-11 time unknown | Stephen Smith (ACLU) | Michele Moore (ACLU) Mark Wier (ACLU) | (indicating that he spoke with Amber Heard's representatives and that they are not interested in them doing a statement right now.) They are, however, interested in a more comprehensive push in the near future about how her donation is being used. | TD depo pg 190, 196/197 | email paraphrased/partially read out only |
2017-07-11 time unknown | Mark Wier (ACLU) | Stephen Smith (ACLU) | Thanks, Steve, her gift is technically unrestricted, but it is weighted towards women's rights issues. transcript says "it was", but in the deposition video I hear "it is" | TD depo pg 190, 196/197 | email read out only |
| Date/Time | from | to | email / Subject: Amber Heard | doc | notes |
|---|---|---|---|---|---|
2017-07-12 time unknown | Stephen Smith (ACLU) | Jonathan Maresco (ACLU) | (indicating that he spoke to Amber Heard's representatives who wanted them to do something that would show her support for the ACLU, and therefore asking to have a conversation with JM about this) | TD depo pg 240/241 | email summed up only |
2017-07-12 time unknown | Jonathan Maresco (ACLU) | Stephen Smith (ACLU) | (saying that he's willing to have that meeting with SS and mentioning a conversation that was had about "doing a blog posting or a video") | TD depo pg 240/241 | email summed up only |
2017-07-12 time unknown | Stephen Smith (ACLU) | Jonathan Maresco (ACLU) | I think a video blog is exactly the sort of thing they're looking for. | TD depo pg 240/241 | email read out only |
| Date/Time | from | to | email / Subject: Amber Heard | doc | notes |
|---|---|---|---|---|---|
2017-07-26 time unknown | Stephen Smith (ACLU) | Terry Tang (ACLU) Matthew Harwood (ACLU) | (indicating that they were interested in discussing ways to do PR around their relationship with Amber Heard) As you know, actress Amber Heard is in the process of handing us half of her Johnny Depp divorce settlement, the other half going to the LA Children's Hospital. Instead of doing a series of statements each time a payment installment is made (as Johnny's PR team continually pushes out stories that she's not actually making the donations while they hold up their payments. Fun.) Anyway, she's keen to show her support and talk about her ongoing support for us in a few ways. I'm going to pitch to her PR team that she pen a blog about why she's supporting us, blah, blah, blah. (part of what's in brackets was then read out slightly differently: "Johnny's PR team continually pushes out stories saying she is not actually making the donations." Also, the sentence before that seems to be incomplete in the actual email.) | TD depo pg 242-245, 248 | email read out only |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2017-12-04 | Exh 27 "12/4/2017 E-Mail" email from Johnny Depp to Jann Wenner, the owner of Rolling Stone magazine | SD depo pg 222 | if you're willing & able to transcribe this exhibit, please let me know |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2017-12-07 | Exh 6 "12/7/17 Emails", December 07, 2017 email chain re JK Rowling statement and "JK Rowling and Warner Brothers putting out some positive press" | JW depo pg 83/84 | if you're willing & able to transcribe this exhibit, please let me know |
2018
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2018-01-11 time unknown | Amber Heard | Christian Carino | Hey, my love. I called you to talk about this. I would love to meet up and talk with you over a drink when you're available. I've been trying to see you to talk in person, but but actually sometimes it's easier to write these things. Anyways, either way, I want to see you soon. As you know, you're one of my dearest friends. I love you so much and treasure our friendship more than you know and hope with every ounce of my soul that this does not affect it at all. I really need to get back to work and simplify my career by moving everything to WME. --------------- (don't know if the "but but" is from the actual email or if it was only read out like this or mistranscribed) | CC Depo vol02 pg 219-224 | email read out only --------------- Plt569 - 1/12/18 Email from Amber Heard to Christian Carino / Def1024 - Emails - Amber Heard and Carino re Wme, 1/12/18 |
2018-01-11/12? time unknown | Christian Carino | Amber Heard | I want whatever you feel is best for you. | CC Depo vol02 pg 219-224 | email read out only --------------- Plt569 - 1/12/18 Email from Amber Heard to Christian Carino / Def1024 - Emails - Amber Heard and Carino re Wme, 1/12/18 |
2018-01-12 time unknown | Amber Heard | Christian Carino | That means the world to me. | CC Depo vol02 pg 219-224 | email read out only --------------- Plt569 - 1/12/18 Email from Amber Heard to Christian Carino / Def1024 - Emails - Amber Heard and Carino re Wme, 1/12/18 |
| Date/Time | from | to | email / Subject: Fantastic Beasts and Johnny | doc | notes |
|---|---|---|---|---|---|
2018-01-12 time unknown | Bryan Lourd (CAA) | Jack Whigham Christian Carino | I wanted you to be aware of the article that hit today. (copy/pasting this Entertainment Weekly article which has Daniel Radcliffe "weighing in on the controversy surrounding the casting of Johnny Depp in the spin-off film Fantastic Beasts: The Crimes of Grindelwald" as well as JK Rowling's defense of "keeping Depp on the film") --------------- the transcript says "Daniel Radcliffe, Johnny Depp, Fantastic Beasts is the title within it.", which is not the headline of the article, but part of the URL "daniel-radcliffe-johnny-depp-fantastic-beasts" | JW depo 85/86, 88/89 | email read out only --------------- Def902 |
| Date/Time | from | to | email / Subject: The Sun-JKR/JD Article | doc | notes |
|---|---|---|---|---|---|
~2018-04-28 time unknown | Susanna Scott (WB) | Blair Rich (WB) | copy/pasting Dan Wootton article: "So let me be clear for the benefit of an apparently unaware Ms. Rowling: Overwhelming evidence was filed to show Johnny Depp engaged in domestic violence against his wife Amber Heard. She was granted a restraining order after alleging Depp assaulted her following a drunken argument and submitted photographs to the court showing her bruised face. Heard - backed up by numerous friends on the record - recounted a detailed history of domestic abuse incidents, some of which had led to her fearing for her life. According to the court documents, there were kicks, punches, shoves and 'all-out assault.'" (the full Dan Wootton/Sun article was copy/pasted into the email, only part read out) | JW depo 91-94, 97 | email read out only |
~2018-04-28 time unknown | Blair Rich | Bryan Lourd (CAA) | (forwarding SS's email) Unfortunately, it's an inflammatory article from The Sun below that I wanted to make you aware of. | JW depo 91-94, 97 | email read out only |
~2018-04-28 time unknown | Blair Rich | Bryan Lourd (CAA) | Understand you're traveling, but let me know when you can touch base at some point over the weekend. transcript says "but we'll -- let me know", which usually indicates that something was misread and corrected, so I assume the email says "but let me know" | JW depo 91-94, 97 | email read out only |
~2018-04-28 time unknown | Bryan Lourd (CAA) | Jack Whigham | FYI. | JW depo 91-94, 97 | email read out only |
2018-04-28 time unknown | Jack Whigham | Bryan Lourd | I will ring her. | JW depo 91-94, 97 | email read out only |
| Date/Time | from | to | email / Subject: The Sun-JKR/JD Article | doc | notes |
|---|---|---|---|---|---|
2018-04-28 time unknown | Robin Baum | Bryan Lourd (CAA) cc Jack Whigham | I will forward to you a copy of the email Adam sent us this morning. (Adam's email was not produced, so we don't know what it said.) | JW depo pg 102/103 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2018-06-22 time unknown | Dr. David Kipper | Christi Dembrowski | I hope you and your family are well and happy. I'm writing to get your pulse on how your brother is doing. I was scheduled to see him prior to his departure to Europe, but his depositions ran late and I was unable to see him. I've been receiving several images of him that look worrisome and I need to know he is doing well. I have reached out to Nathan in order to connect with your brother. I wanted to get your input in case there was a problem. | DK depo pg 160 | email read out only |
| Date/Time | from | to | email / Subject: City of Lies Pulled from Release Schedule | doc | notes |
|---|---|---|---|---|---|
2018-08-06 time unknown | Jack Whigham | Christi Dembrowski | I need to call her in the morning. forwarding/copy/pasting this Variety article // screenshot: "Johnny Depp film City of Lies pulled from release schedule" | JW depo pg 111-113 | email read out only --------------- the transcript doesn't mention who this email was sent to (presumably at least Christi Dembrowski, since she responded), and depending on whether it was sent to Robin Baum or not, she might be the "her" he needs to call |
2018-08-06 time unknown | Christi Dembrowski | Jack Whigham Robin Baum | When did they decide this and does he know? | JW depo pg 111-113 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2018-08-15 time unknown | Robin Baum | Jack Whigham | And this one. (presumably copy/pasting or linking an article about "Johnny Depp accusing Amber Heard of defecating in their marital bed") | JW depo pg 119 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2018-09-11 time unknown | Rob Cowan | Amber Heard | (not read out) | WH depo pg 62 | email only mentioned --------------- BN ALH_18110 (Def1267) |
2018-09-11 time unknown | Amber Heard | Rob Cowan | OMG. I loved. Heard it tested super well. How did I do? | WH depo pg 62 | email read out only --------------- BN ALH_18110 (Def1267) |
2018-09-11 time unknown | Rob Cowan | Amber Heard | You did amazing. People really loved the film and loved your character. We're cutting Jason out of the movie. | WH depo pg 62 | email read out only --------------- BN ALH_18110 (Def1267) |
| Date/Time | from | to | email / Subject: Amber's Pledge | doc | notes |
|---|---|---|---|---|---|
2018-09-28 time unknown | Anthony Romero (ACLU) | Jonathan Maresco (ACLU) | (not read out) | TD depo pg 414 | email only mentioned --------------- Def1645 |
2018-09-28 time unknown | Jonathan Maresco (ACLU) | Anthony Romero (ACLU) cc Mark Wier (ACLU) | Hi, Anthony, if you get a chance on Sunday, can you please check in with Amber on her next pledge payment? She has a balance of $2.55 million on her $350,000 10-year pledge. Below is a summary of her other payments. | TD depo pg 414 | email read out only --------------- Info based on depo video. Depo transcript is missing the "to Mr. Romero" as well as "other", Elaine Bredehoft says "Mike", but it should be "Mark". --------------- Def1645 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2018-09-30 time unknown | Stephen Deuters | Jack Whigham | Hey, Jack, don't know if you've seen this or not, waiting for J's response. Adam isn't happy with some obvious elements. Thus far GQ are agreeing to delete parts online and offer a full retraction for the print copy, namely the nonsense regarding City of Lies, which I believe the author acknowledges he misquoted, plus various errors in regards to that trial. | JW depo pg 124 | email read out only --------------- BN JW50 (part of Def913) --------------- it's not mentioned in the deposition, but I would assume that Stephen linked or copy/pasted the GQ article in question) |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2018-10-01 time unknown | Jack Whigham | Christian Carino | (forwarding GQ article) | JW depo pg 122 | email read out only --------------- BN JW50 (part of Def913) |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2018-10-11 time unknown | Jodi Gottlieb | Jessica Weitz | We are so thrilled to hear that Amber will be an official ambassador for the ACLU. | TD depo pg 250/251, 255-260 | email read out only --------------- Def917 (ACLU_045-51) --------------- very first email in the chain, so presumably at the bottom of ACLU 51 |
2018-10-12? time unknown | Jessica Weitz | Jodi Gottlieb cc others (ACLU) | I think it makes most sense to call her a Women's Rights Ambassador, as we have with others who are working with the Women's Rights Project, but with an area of specificity around gender-based violence. | TD depo pg 250/251, 255-260 | email read out only --------------- Def917 (ACLU_045-51) --------------- top of ACLU 49, so there might be multiple unread emails in between this one and the above one |
| Date/Time | from | to | email / Subject: Disney talking Pirates of the Caribbean reboot with Deadpool Scribes Rhett Reese and Paul Wernick, Deadline | doc | notes |
|---|---|---|---|---|---|
~2018-10-26 time unknown | Robin Baum | Jack Whigham | (asks if this is for real, presumably with this Deadline article linked or copy/pasted) | JW depo pg 125-127 | email paraphrased only |
2018-10-26 time unknown | Jack Whigham | Robin Baum | I think they are loosely discussing how to move forward. I'll call Jerry. I spoke with Jerry B. who said there's no script or idea for the film, they, Disney, are just wanting to do a deal with Jerry to start developing a script for a reboot. Jerry would like Johnny in the film in some capacity but he asked me to call Disney to gauge where their head is at. I've LW for Sean Bailey. The transcript says "are just wanting to -- something -- I think it's supposed to be to do a deal with Jerry" . I assume in the actual email there was a word or more missing which Elaine Bredehoft then "filled in", so I'm just transcribing it how it was presumably meant to be ("are just wanting to do a deal with Jerry"), I'm also not sure if it actually said "they, Disney, are" or if Elaine Bredehoft just clarified that "they" means Disney. | JW depo pg 125-127 | email read out only --------------- LW = left word |
| Date/Time | from | to | email / Subject: unknown (possibly "Aquagirl") | doc | notes |
|---|---|---|---|---|---|
2018-10-30 time unknown | Rob Cowan | Amber Heard | We are on our last few days of finishing this baby. It's really great. You are terrific in this!! | WH depo pg 55/59 | email read out only --------------- BN ALH_18108 (Def1601) |
| Date/Time | from | to | email / Subject: AMBER HEARD/ACLU | doc | notes |
|---|---|---|---|---|---|
2018-11-06 02:22 pm | Gerry Johnson (ACLU) | Jodi Gottlieb Jessica Weitz (ACLU) cc Ana Blinder (ACLU) cc various Independent Public Relations people | Hi Jodi, I'd like your and Amber's thoughts on doing an op-ed in which she discusses the ways in which survivors of gender-based violence have been made less safe under the Trump administration, and how people can take action. It can be timed for sometime after 11/14, when it's time to remind the newly elected Congress of their priorities. Her ambassador title could appear in her byline and announced in the social media promotion of the piece. In the op-ed, she can argue that it's time to make sure that our leaders take GBV seriously, by highlighting the following: • Congress' delay in re-authorizing VAWA, which expires 12/7. • The ACLU's lawsuit against Sessions over a new asylum rule he implemented against asylum-seekers fleeing domestic violence • A new Title IX rule we're expecting Betsy DeVos to issue this month, which would roll back protections for sexual assault survivors on college campuses. • She can also, of course, mention Trump's irresponsible attacks on Christine Blasey Ford and survivors who don't report right away. If she feels comfortable, she can interweave her personal story, saying how painful it is as a GBV survivor to witness these setbacks. Target publications could include digital outlets like Teen Vogue, Marie Claire, and Vice/Broadly, or a paper like the L.A Times. Would this be of interest? And if so, would you like for us to do the first draft (might include a quick phone interview to get her thoughts) or would Amber prefer to start it off? Thanks, let me know what you think. Also happy to jump on the phone to discuss if it's helpful. All the best, Gerry | Def917 (ACLU_045-51) --------------- bottom of ACLU 47 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2018-11-08 time unknown | Robin Baum | Jack Whigham Christian Carino Christi Dembrowski | Current reviews below there are a few good ones for JD and some not so nice. (attaching film reviews for Fantastic Beasts: The Crimes of Grindelwald) | JW depo pg 130 | email read out only |
| Date/Time | from | to | email / Subject: Amber Heard / ACLU | doc | notes |
|---|---|---|---|---|---|
2018-11-?? time unknown | Jodi Gottlieb | Jessica Weitz (ACLU) | We are so thrilled to hear that Amber will be an official ambassador for the ACLU. | EG depo pg 37 | email read out only --------------- BN ALH_16814-16821 (Def918) |
2018-11-?? time unknown | Jessica Weitz (ACLU) | Jodi Gottlieb & others | partially read out: I would like to also introduce you to my colleagues Ana and Gerry in media and editorial who will be part of Amber's team here and be the bridge between her and our women's rights project. | EG depo pg 38 | email partially read out only --------------- BN ALH_16820 (ALH_16814-16821 = Def918) |
2018-11-?? time unknown | Gerry Johnson (ACLU) | ? | In the op-ed, she can argue that it's time to make sure that our leaders take GBV seriously by highlighting the following: Congress' delay in re-authorizing VAWA, which expires 12/7; the ACLU's lawsuit against Sessions over a new asylum rule he implemented against asylum seekers fleeing domestic violence; a new Title VII rule we're expecting Betsy DeVos to issue this month, which would roll back protections for sexual assault survivors on college campuses. She can also, of course, mention Trump's irresponsible attacks on Christine Blasey Ford and survivors who don't report right away. If she feels comfortable, she can interweave her personal story, saying how painful it is, as a GBV survivor, to witness these setbacks. | EG depo pg 39 | email read out only --------------- BN ALH_16814-16821 (Def918) |
2018-11-?? time unknown | Gerry Johnson (ACLU) | ? | Checking in to see whether Amber would like to move forward with this plan. If it would be most convenient for us to start the draft, we're more than happy to. We just need to know Amber's availability to jump on the phone so we can quickly get her thoughts on a few of the discussion topics in the op-ed. | EG depo pg 40 | email read out only --------------- BN ALH_16815 (ALH_16814-16821 = Def918) |
2018-11-?? time unknown | Gerry Johnson (ACLU) | ? | partially read out: ...and how people can take action. It can be timed for sometime after 11/14, when it's time to remind the newly elected Congress of their priorities. Her ambassador title could appear in her byline and announced in the social media promotion of the piece. | EG depo pg 304/305 | email partially read out only --------------- this may be part of one of the previous emails by Gerry Johnson or from a separate email --------------- BN ALH 16817 (ALH_16814-16821 = Def918) |
2018-11-08 time unknown | Jodi Gottlieb | Gerry Johnson (ACLU) | We will get back to you soonest with feedback. Amber is currently doing charity work in Mexico, but will be back soon. | EG depo pg 41 | email read out only --------------- BN ALH_16814-16821 (Def918) |
2018-11-?? time unknown | Jessica Weitz (ACLU) | ? (multiple people) | I will be speaking with Amber tomorrow afternoon with our op-ed writer, and get back to you-all with the first draft for Amber's edits soon after. | EG depo pg 41/42 | email read out only --------------- BN ALH_16814-16821 (Def918) |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2018-11-15 | Exh 33 "11/15/18 E-Mails, 'Re: Call w Amber Heard For Title IX'" | TD depo pg 263-270 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject:Thank you - and checking in | doc | notes |
|---|---|---|---|---|---|
2018-11-27 time unknown | Anthony Romero (ACLU) | Amber Heard | Is there anything I can do to help facilitate your next pledge payment of $350,000? | TD depo pg 415 | email read out only --------------- BN ACLU_2595 (Def1646) |
2018-11-29 time unknown | Amber Heard | Anthony Romero (ACLU) | Hang on, I'll be right with you. | TD depo pg 415 | email read out only --------------- BN ACLU_2595 (Def1646) |
| Date/Time | from | to | email / Subject: For Amber and Sara | doc | notes |
|---|---|---|---|---|---|
2018-11-29 03:20 pm | Robin Shulman (ACLU) | Jessica Weitz (ACLU) | Hi Amber, Hope your travel's been going great. It was such a total pleasure to talk with you. I tried to gather your fire and rage and really interesting analysis and shape that into op-ed form--with mentions of a few policies and a growing movement. I hope it sounds true to you. It's attached. I'm sorry for the delay in getting it to you. Many lawyers have reviewed it here and tweaked the policy bits. Your lawyers should review this for the way I skirted around talking about your marriage. And there are a few places where I wasn't sure if something was right or needed a few words to end the sentence--I put those in bold and noted them with TK. If you could fill those in, that would be a big help. Thank you again for sharing your passion and perspective. You have such a powerful voice on this issue and I'm so, so glad the world is hearing more of you. Happy to talk about anything and everything here. Take good care, Robin | the email incl. attached doc was then forwarded by JW to AH | |
2018-11-29 09:12:23 pm | Jessica Weitz (ACLU) | Amber Heard cc AH assistant | Hi Amber, Apologies for the delay, but we have needed this to pass through quite a few lawyer's first. Please read Robin's notes below, and let me know your edits. Also - you should show this to your attorney (one from the long list). I want to make sure nothing was said in here that puts you in jeopardy with your NDA. Jessica |
| Date/Time | from | to | email / Subject: Amber op-ed new | doc | notes |
|---|---|---|---|---|---|
~2018-12-06 time unknown | Amber Heard | Robin Shulman (ACLU) | Everyone was very impressed. Thank you for finding my voice. | according to the DM, this email was sent a week after Robin's Nov 29 email |
| Date/Time | from | to | email / Subject: Amber op-ed new | doc | notes |
|---|---|---|---|---|---|
2018-12-06 time unknown | Robin Shulman (ACLU) | Jessica Weitz (ACLU) Amber Heard & others See the attached and let me know if there is anything else you'd like to change before sharing with your lawyers. Otherwise, feel free to go ahead and pass it to them. There are two versions here -- one showing the changes I made and one clean. Read whichever is easier for you. Good luck on Jimmy Fallon, and hope you're staying warm. EG depo pg 24 email read out only --------------- BN ALH_16659-16662 (Def923) | |||
2018-12-06 time unknown | AH assistant | Jodi Gottlieb cc Amber Heard | (not read out, possibly email from RS being forwarded to JG) | EG depo pg 24 | email mentioned only --------------- BN ALH_16659-16662 (Def923) |
2018-12-06 time unknown | Amber Heard | Eric George Jennifer Robinson Jeffrey Berman | Please see the proposed op-ed that would run in conjunction with my official announcement as the new Women's Rights Ambassador for the ACLU. Please let me know what you think. (forwarding email/attachment) | EG depo pg 24/25 | email read out only --------------- BN ALH_16659-16662 (Def923) |
2018-12-06 time unknown | Eric George | Amber Heard Sean Walsh? | Reads very well. Forwarding to Sean. | EG depo pg 28 | email read out only --------------- BN ALH_16423-16428 (Def925) --------------- unclear if this means he's forwarding AH's email by sending this email to Sean Walsh or forwarding Amber's email to him afterwards |
2018-12-06 or 07 time unknown | Amber Heard | Eric George Sean Walsh? | Thanks. Let me know if I am putting myself in any compromising positions. Thanks. | EG depo pg 55/56 | email read out only --------------- BN ALH_16663-16664 (Def927) --------------- based on the depo transcript ("hopping back (...) to December 6th and December 7th, but there's different e-mail chains") I assume this was in response to EG's email |
| Date/Time | from | to | email / Subject: Amber op-ed new | doc | notes |
|---|---|---|---|---|---|
2018-12-07 10:00 am | Amber Heard | Eric George | Just checking in to see where we are. I need to get back to the ACLU with my edits/thoughts. Please let me know. | EG depo pg 28/29 | email read out only --------------- BN ALH_16423-16428 (Def925) |
2018-12-07 time unknown | Sean Walsh | Amber Heard cc Eric George cc Jen Robinson | I just reread through the whole draft and content wise and grammar wise, I think it's good. The only other thing I might add/be aware of is that while Me Too picked up steam in 2017/fully came to life then, the phrase and its association with combating sexual assault has been around since 2006. That kind of bolsters the point that it took a long time and a turning point for it to catch on with the broader public. You do us proud Amber. I'll grab Eric and make sure we are in on the legal part. | EG depo pg 30 | email read out only --------------- BN ALH_16423-16428 (Def925) |
2018-12-07 time unknown | Jennifer Robinson | Sean Walsh Amber Heard cc Eric George | I defer to Eric on the interpretation of your agreement as a matter of U.S. law. As we discussed in London, you have a really powerful story to tell about what happened to you as a result of speaking out. This is an important story which is not about him; it's about societal and industry responses. And that is a story that is empowering for so many women: I can tell you that I get contacted by women a lot wanting to speak out about the abuse they have suffered, but they face so many obstacles: wanting to be known for what they do and not what was done to them; the legal costs of defending themselves against legal action; the publicity; what it means for their careers, et cetera. It is also why it is so important that we ensure that you are protected and survive this, as an example of what's possible, even in such a powerful industry. That's why the Weinstein story was so big globally - for what it said to women everywhere. | EG depo pg 31/32 | email read out only --------------- BN ALH_16423-16428 (Def925) |
2018-12-07 time unknown | Amber Heard | Jennifer Robinson Sean Walsh | Great. I'm happy with this. Do I have everyone's approval to give back to the ACLU? | EG depo pg 34 | email read out only --------------- BN ALH_16786-16787 (Def926) |
2018-12-07 time unknown | Sean Walsh | Amber Heard Jennifer Robinson? | Give me five minutes to call Eric on one item. | EG depo pg 34 | email read out only --------------- BN ALH_16786-16787 (Def926) |
2018-12-07 time unknown | Amber Heard | Robin Shulman | Hey, I just wanted to check in with you and touch base. It's being run by the lawyers and should be done within the hour. There's a big team, so it took longer than I would have liked. | EG depo pg 35 | email read out only --------------- BN ALH_16786-16787 (Def926) |
| Date/Time | from | to | email / Subject: Aquaman, China Opening Day Flash Estimates | doc | notes |
|---|---|---|---|---|---|
2018-12-07 time unknown | Peter Safran | Amber Heard | I thought you might enjoy this! Congrats on the beginning of our worldwide roll-out. What a great way to start. See you in L.A. next week. | WH depo pg 67 | email read out only --------------- BN ALH_18252 (Def1269) |
| Date/Time | from | to | email / Subject: Language - TIME SENSITIVE | doc | notes |
|---|---|---|---|---|---|
2018-12-08 time unknown | Eric George | Robin Shulman (ACLU)? & others? | (...) By Amber Heard I was exposed to abuse at a very early age. I knew certain things young, without ever having to be told. I knew that men have the power, physically, socially and financially, and that a lot of institutions support that arrangement. I knew this long before I had the words to articulate it, and I bet you learned it young, too. Like many women, by the time I was college age, I had been harassed and sexually assaulted. But I kept quiet - I did not expect filing complaints to bring justice. And I didn't see myself as a victim. I signed an agreement not to talk about my marriage, and I will not do that here. IN ANY EVENT, FAR MORE REVEALING IS what happened to me publicly. Everyone on my team said I would never work as an actress again. My own lawyer told me I would be blacklisted. Sure enough, a movie I was attached to recast my role. I had just shot a two-year campaign as the face of Tod's fashion, but the company dropped me. And I had just been offered the role of Mera in the movies Justice League and Aquaman, and there were questions as to whether I would be able to keep the role. I was afraid I would lose my livelihood and my ability to provide for my family. There was no studio fighting behind me trying to make a multimillion-dollar franchise work. Imagine a powerful man as a ship, like the Titanic. That ship is a huge enterprise. When it strikes an iceberg, there are a lot of people onboard desperate to patch up holes - not because they believe in or even care about this enterprise, but because their own fates depend on it. In recent years, because of the #MeToo movement, we have learned about how power like this works, not just in the Hollywood machine, but in all kinds of institutions - workplaces, places of worship, or simply in particular communities. In every walk of life women are confronting these ships that are buoyed by social, economic and cultural power. And these institutions are beginning to change. We are in a transformative political moment. The president of our country has been accused by more than a dozen women of sexual misconduct, including assault, groping and harassment. Outrage over his statements and behavior has energized a female-led opposition. #MeToo started a conversation about just how profoundly sexual violence affects women in every area of our lives. And last month, more women were elected to Congress than ever in our history, with a mandate to take women's issues seriously. Women's rage and determination to end sexual violence is turning into a political force. We have an opening now to bolster and build institutions protective of women. For starters, Congress can re-authorize and strengthen the Violence Against Women Act. First passed in 1994, VAWA is one of the most effective pieces of legislation enacted to fight domestic violence and sexual assault. It creates support systems for people who report abuse, providing funding for rape crisis centers, legal assistance programs, and other critical services. It improves responses by law enforcement. And it prohibits discrimination against LGBT survivors. Funding for VAWA expired in September, and has only been temporarily extended. We should continue to fight sexual assault on college campuses, while simultaneously insisting on fair processes for adjudicating complaints. Last month, Education Secretary Betsy DeVos proposed changes to rules known as Title IX governing the treatment of sexual harassment and assault in schools. While some changes would make the process for handling complaints more fair, others would weaken protections for sexual assault survivors. For example, the new rules would require schools to investigate only the most extreme complaints, and then only when they are made to designated high-level officials. Women on college campuses already have trouble coming forward about sexual violence - why would we allow institutions to scale back supports? And we must protest recent changes that have stopped officials from granting asylum to immigrant women who are fleeing domestic and sexual violence. I grew up in south Texas on my dad's construction sites, and I have met many women who came here seeking refuge from sexual and domestic violence. In denying them asylum, the Trump administration is reverting to the old attitude that this is a private matter, ignoring governments' inability or unwillingness to protect women. For many, the United States is their only hope to escape. If we do not offer these vulnerable people refuge, do our ideals mean anything? I know social norms are hard to change, and the backlash is powerful. I WRITE THIS ARTICLE AS A WOMAN WHO I felt like I was on trial in the court of public opinion - and my life and livelihood depended on myriad judgments far beyond my control. I want to ensure that Amber Heard is an actress whose new movie Aquaman is coming to theaters this month, and she is an ACLU ambassador on women's rights. | The last sentence ("Amber Heard is an actress (...)" was written in italics. I didn't put it in italics to prevent confusion with my comments. |
| Date/Time | from | to | email / Subject: Legal Edits For ACLU Op-Ed | doc | notes |
|---|---|---|---|---|---|
2018-12-08 time unknown | Sean Walsh | Amber Heard AH Assist Eric George Jennifer Robinson cc himself | ACLU revised draft of EG and JR edits. (sending draft with, according to the deposition transcript, crossed out and capitalized parts, presumably the above Dec 08 email) | EG depo pg 58 | email read out only --------------- BN ALH_16285-16287 (Def928) --------------- EG = Eric George, JR = Jen Robinson |
| Date/Time | from | to | email / Subject: One thought - ACLU statement | doc | notes |
|---|---|---|---|---|---|
2018-12-08 time unknown | Amber Heard | Eric George Sean Walsh Jennifer Robinson | I received your redline version. I think the edits make perfect sense. I had one thought, however, in the attached statement I highlighted the one part that I'm curious to see if there's perhaps another version of it we could keep in there. Maybe instead of, "two years ago I sought a temporary restraining order from my then-husband," we could do something like, "two years ago after successfully acquiring a temporary restraining order," would it be okay then? Or some version of that? I just like the acknowledgement that follows after, "...only to feel the full force of the culture's wrath for women who speak out." I'd had to lose that. (with attachment) --------------- the transcript says "I'd had to lose that", but I assume she either meant or actually wrote (and it was either misread or mistranscribed) "I'd hate to lose that.". | EG depo pg 60 | email read out only --------------- BN ALH_16561-16562 (Def1549) |
2018-12-08 to 11 time unknown | Sean Walsh | Amber Heard Eric George Jennifer Robinson | Seems reasonable to me, but defer to Eric. | EG depo pg 62 | email read out only --------------- BN ALH_16795-16796 (Def1551) --------------- date in exhibit description says "12/11/18", but might be the date of only the last email in the exchange |
2018-12-08 to 11 time unknown | Amber Heard | Eric George Sean Walsh Jennifer Robinson | email summed up only: "Amber asks your thoughts" | EG depo pg 62 | email summed up only --------------- BN ALH_16795-16796 (Def1551) --------------- date in exhibit description says "12/11/18", but might be the date of only the last email in the exchange |
2018-12-08 to 11 time unknown | Eric George | Amber Heard Sean Walsh Jennifer Robinson | You did a great job on this. I see no reason why we can't leave in your elegant language while still eliminating reference to court proceedings. What's your ETA? Can I tinker with it and get back to you tomorrow evening? | EG depo pg 62 | email read out only --------------- BN ALH_16795-16796 (Def1551) --------------- date in exhibit description says "12/11/18", but might be the date of only the last email in the exchange |
2018-12-08 to 11 time unknown | Amber Heard | Eric George Sean Walsh Jennifer Robinson | We would need to submit it on Monday. | EG depo pg 63 | email read out only --------------- BN ALH_16795-16796 (Def1551) --------------- Date in exhibit description says "12/11/18", but might be the date of only the last email in the exchange. I assume the "Monday" in the email refers to Dec 17, in which case it's likely this one was sent on Tuesday, Dec 11. |
| Date/Time | from | to | email / Subject: Placing Amber Heard op-ed | doc | notes |
|---|---|---|---|---|---|
2018-12-10 08:00:00 pm | Gerry Johnson (ACLU) | Stacy Sullivan (ACLU) Terry Tang (ACLU) | Hi Stacy (or Terry, in case you're sick and offline), Amber Heard checked in about where we want to pitch her op-ed and we'd like to give her an answer today. She asked if we could place it where it'll have the biggest impact possible. Since the draft turned out pretty strong and Aquaman is slated to do huge numbers, I'm wondering what you think about pitching in this oder: NYT, WaPo, Teen Vogue, USA Today. Stacy, you liked the idea of the L.A. Times when we talked last month, but let me know if you think Teen Vogue would be more impactful. And for the division of labor, are you ok with our team pitching to the hard news outlets and Amber's team to Teen Vogue + any entertainment site? Finally, let me know if you think we should cross-post to the blog if the outlet allows it. (I imagine that would only be Teen Vogue.) Thanks, let me know what you think! Best, Gerry |
| Date/Time | from | to | email / Subject: ASAP | doc | notes |
|---|---|---|---|---|---|
2018-12-10 time unknown | Eric George | Amber Heard | I think this reads well, and completely avoids any areas that could come into conflict with the judgment. Let me know your thoughts. Proud of you for writing this. | EG depo pg 64 | email read out only --------------- BN ALH_16289 (Def930) |
2018-12-11 time unknown | Eric George | Martin Zuniga Lydia Tavera & others? | Team, we are on an urgent deadline and something I sent Amber at 5:20 p.m. now cannot be retrieved. Sean was able to access when sent. Now, it's totally corrupted. A special prize to anyone who can retrieve an intelligible version of what I originally sent Amber and promptly resend to Amber. --------------- based on EG on pg 66 of the transcript, this was written in all caps ("after my all caps request") | EG depo pg 65 | email read out only --------------- BN ALH_16289 (Def930) --------------- based on exhibit description, this email was also sent to Sean Walsh |
| Date/Time | from | to | email / Subject: amber op-ed w Eric's changes | doc | notes |
|---|---|---|---|---|---|
2018-12-11 time unknown | Lydia Tavera | Eric George Martin Zuniga? | not read out / sending attachment of op-ed with EG's edits | EG depo pg 66 | email only mentioned --------------- BN ALH_16281-16284 (Def931) --------------- according to Eric George this was sent 33 minutes after his "all caps request" from Dec 11 |
2018-12-11 time unknown | Eric George | Amber Heard & others? | Lydia found it. Here it is. | EG depo pg 66 | email read out only --------------- BN ALH_16281-16284 (Def931) |
2018-12-11 time unknown | Eric George | Amber Heard | A, I think this reads well and completely avoids any areas that could come into conflict with the judgment. | EG depo pg 68 | email read out only --------------- BN ALH_16288 (Def929) |
| Date/Time | from | to | email / Subject: Re: Final Amber Heard Op Ed | doc | notes |
|---|---|---|---|---|---|
2018-12-11 11:05 am | Jessica Weitz (ACLU) | Robin Shulman (ACLU) & others | Team: Amber sent back the Op Ed with final edits from her legal team, which specifically neutered much of the copy regarding her marriage, and the domestic violence. Ana, Gerry and I discussed placement of this, and we would like to see it pitched to a NYT or WaPo, ideally by our team, before sending it to a more traditional entertainment outlet. The goal is to get this out this week to capitalize on the tremendous PR campaign for Aquaman. Can you let us know if our plan is doable, and if we will do the initial press outreach? I will still need to let Amber and her publicist aware of the plan, and would like to get this moving today. Thank you! FINAL W EDITS ...By Amber Heard I was exposed to abuse at a very early age. I knew certain things young, without ever having to be told. I knew that men have the power, physically, socially and financially, and that a lot of institutions support that arrangement. I knew this long before I had the words to articulate it, and I bet you learned it young, too. Like many women, by the time I was college age, I had been harassed and sexually assaulted. But I kept quiet - I did not expect filing complaints to bring justice. And I didn't see myself as a victim. When I began to give voice to the observations and opinions I had for too long kept locked within, the reaction was instantaneous. Friends and advisors told me I would never again work as an actress. My own lawyer told me I would be blacklisted. Sure enough, a movie I was attached to recast my role. And, having just shot a two-year campaign as the face of a global fashion brand, the company dropped me. Later, after I was offered the role of Mera in the movies Justice League and Aquaman, questions arose whether I would be able to keep the role. Was I afraid? Terrified would be a better word. I believed I might lose my livelihood and my ability to provide for my family. No studio stood behind me, fighting to make a multimillion-dollar franchise work. Imagine a powerful man as a ship, like the Titanic. That ship is a huge enterprise. When it strikes an iceberg, there are a lot of people onboard desperate to patch up holes - not because they believe in or even care about this enterprise, but because their own fates depend on it. In recent years, the #MeToo movement has taught us about how power like this works, not just in the Hollywood machine, but in all kinds of institutions - workplaces, places of worship, or simply in particular communities. In every walk of life women are confronting these ships that are buoyed by social, economic and cultural power. And these institutions are beginning to change. We are in a transformative political moment. The president of our country has been accused by more than a dozen women of sexual misconduct, including assault, groping and harassment. Outrage over his statements and behavior has energized a female-led opposition. #MeToo started a conversation about just how profoundly sexual violence affects women in every area of our lives. And last month, more women were elected to Congress than ever in our history, with a mandate to take women's issues seriously. Women's rage and determination to end sexual violence is turning into a political force. We have an opening now to bolster and build institutions protective of women. For starters, Congress can re-authorize and strengthen the Violence Against Women Act. First passed in 1994, VAWA is one of the most effective pieces of legislation enacted to fight domestic violence and sexual assault. It creates support systems for people who report abuse, providing funding for rape crisis centers, legal assistance programs, and other critical services. It improves responses by law enforcement. And it prohibits discrimination against LGBT survivors. Funding for VAWA expired in September, and has only been temporarily extended. We should continue to fight sexual assault on college campuses, while simultaneously insisting on fair processes for adjucating complaints. Last month, Education Secretary Betsy DeVos proposed changes to rules known as Title IX governing the treatment of sexual harassment and assault in schools. While some changes would make the process for handling complaints more fair, others would weaken protections for sexual assault survivors. For example, the new rules would require schools to investigate only the most extreme complaints, and then only when they are made to designated high-level officials. Women on college campuses already have trouble coming forward about sexual violence - why would we allow institutions to scale back supports? And we must protect recent changes that have stopped officials from granting asylum to immigrant women who are fleeing domestic and sexual violence. I grew up in south Texas on my dad's construction sites, and I have met many women who came here seeking refuge from sexual and domestic violence. In denying them asylum, the Trump administration is reverting to the old attitude that this is a private matter, ignoring governments' inability or unwillingness to protect women. For many, the United States is their only hope to escape. If we do not offer these vulnerable people refuge, do our ideals mean anything? I know social norms are hard to change, and the backlash is powerful. I write this as a woman who had to change my phone number once a week because I was getting death threats. For months, I rarely left my apartment, and when I did, I was pursued by camera drones and photographers on foot, on motorcycles, and in cars. Tabloid news outlets that posted pictures of me spun them in a negative light. I felt like I was on trial in the court of public opinion - and my life and livelihood depended on myriad judgments far beyond my control. I want to ensure that women who come forward to talk about violence receive more support. We are electing representatives who know how deeply we care about these issues. We can work together to demand changes to laws and rules and social norms - and to right the imbalances that have shaped our lives. Amber Heard is an actress whose new movie Aquaman is coming to theaters this month, and she is an ACLU ambassador on women's rights. Jessica Herman Weitz | ||
2018-12-11 11:07 am | Robin Shulman (ACLU) | Jessica Weitz (ACLU) cc: Ana Blinder, Gerry Johnson, Stacy Sullivan, Terry Tang, Stephen Smith (all ACLU) | Hey everyone, I have not yet reviewed this or discussed with amber so hold please on any action till afternoon! Thank you. Robin | ||
2018-12-11 11:09 am | Jessica Weitz (ACLU) | Robin Shulman (ACLU) & presumably the others | Robin - her lawyers omitted the below, but Amber would love to see a way to have the part in bold somehow put back in. Is there an artful way to do that? Otherwise she is ok with the final: "two years ago I sought a temporary restraining order from my then husband...." was changed to "two years ago after successfully acquiring a temporary restraining order" but still not cleared by her lawyers. But how can we add back in "......only to feel the full force of the culture's wrath for women who speak out". | ||
2018-12-11 11:16 am | Robin Shulman (ACLU) | Jessica Weitz (ACLU) & presumably the others | No problem. Jess I'm planning to work on this in the afternoon. Please hold till then. Thanks! | ||
2018-12-11 02:41 pm | Jessica Weitz (ACLU) | Robin Shulman (ACLU) & presumably the others | Of course! Since I still need to clear the pitch plan, Terry can you let us know (in Stacey's absence) if we will handle the inital pitch of NYT or WaPo? Best, Jessica | ||
2018-12-11 03:54:02 pm | Robin Shulman (ACLU) | Jessica Weitz (ACLU) cc: Ana Blinder, Gerry Johnson, Stacy Sullivan, Terry Tang, Stephen Smith (all ACLU) | Thanks Jess. I emailed Amber about several things and will let all know when I hear back and we have a final version. Thanks, Robin |
| Date/Time | from | to | email / Subject: Approved letter | doc | notes |
|---|---|---|---|---|---|
2018-12-11 time unknown | Amber Heard | Jessica Weitz (ACLU) Robin Shulman (ACLU) | Please let me know if you have any thoughts or anything that you want to tweak or add. | EG depo pg 69 | email read out only --------------- BN ALH_10724-10727 (Def934) |
2018-12-12 time unknown | Robin Shulman (ACLU) | Amber Heard & Jessica Weitz? | Hi Amber, is there any room at all to rejigger the sentence we had before? "I signed an agreement not to talk about my marriage, and I will not do that here. What happened to me publicly is more interesting and revealing than what happened within my marriage anyway - because it shows how institutions protect men accused of abuse." It now reads: "When I began to give voice to the observations and opinions I had for too long kept locked within, the reaction was instantaneous." I see what the lawyers are trying to do, but don't think it quite makes sense with what comes after that. None of the fallout happened because you gave voice to observations and opinions, and making it so oblique kind of detracts from the incredibly powerful point that you are in the rare position of witnessing, from the eye of the storm, exactly how institutions cover up for perpetrators (or we could even hedge more and cast it as people accused of perpetrating abuse). Is there room to maneuver a bit? I miss this paragraph below too, which I think we could rejigger slightly along these lines (changes the bold), if there's a possibility of that: "Then two years ago, after I got a temporary restraining order against my then-husband, I felt the full force of the culture's wrath for women who speak out. I remember the day I left the courtroom and walked into a pack of hundreds of photographers. I didn't have a team of bodyguards. My lawyers used their own bodies to block out space for me to walk to my car. The whole way there, I heard the press yelling the same question in one form or another, 'Is it true you're making all this up.'" --------------- (I assume "changes the bold" was meant to be "changes in bold") | EG depo pg 69/70, 76/77, 264/265 | email read out only --------------- BN ALH_10724-10727 (Def934) & ALH_16399-16403 (Def933) & ACLU_6479 (Plt18) --------------- I added the quotation marks to prevent confusion. The original email may or may not have them, but the depo transcript doesn't. |
2018-12-12 12:17 am | Amber Heard | Eric George Sean Walsh Jennifer Robinson | Please see below from editorial team with ACLU. I agree completely and feel it's missing without having the below originally included in the initial draft, but let me know if I can go ahead and give her the go ahead to try to rework it a tiny bit. I don't anticipate it being a problem considering she is working from the elegant and fine-tuned draft you guys approved yesterday. (& sending email from RS to EG) v02: Please see below from editorial team at ACLU. I agree completely and feel it's missing without having the below originally included in the initial draft. Please let me know if I can go ahead and try and rework it a tiny bit. | EG depo pg 70/71, 77, 266 | email read out only --------------- BN ALH_10724-10727 (Def934) |
2018-12-12 ~01:28 am | Eric George | Amber Heard Sean Walsh | Hi A, just tried to call you. I'm e-mailing only you and Sean at this time. Here's the challenge: The confidentiality agreement in the divorce judgment is as broad as it gets. We have to live with it. The ACLU folks are surely well-intentioned, but they don't understand how broad it is. It, literally, prevents you from writing or discussing any information about your marriage or divorce. That's why I wrote the edits the way I did. There is no way that I am letting you expose yourself to the inevitable claim of breach the other side's lawyers would make were the article to state, "I signed an agreement not to talk about my marriage and I will not do that here. What happened to me publicly is more interesting and revealing than what happened within my marriage anyway - because it shows how institutions protect men accused of abuse." | EG depo pg 72-74, 269 | email read out only --------------- BN ALH_16391-16394 (Def935) |
2018-12-12 09:32 am | Sean Walsh | Amber Heard Eric George | I think Eric's edits still get us 95 percent of what you want.., I say send it off and dam the torpedos ahead! | time based on screenshot, order based on depo, so time may have been 02:32 am or 03:32 am in same time zone as above and below emails --------------- BN ALH_16399-16403 (Def933) | |
2018-12-12 time unknown | Amber Heard | Eric George Sean Walsh | Thank you for explaining it so clearly. | EG depo pg 77 | email read out only --------------- BN ALH_16399-16403 (Def933) |
2018-12-12 03:59 am | Eric George | Amber Heard Sean Walsh | Thanks, A. Here's the thing - any reference at all to marriage or divorce, even to say the word marriage or divorce and then elaborate that you're not, in fact, talking about it, is a technical violation. Would a reasonable ex or his lawyer object? Of course not. Will the opposing side that we're dealing with? Likely yes. So I propose we be artful in the words we use, so we can convey the same message without exposing you to the claim that you violated the agreement. (then making a proposal) Thoughts??? | EG depo pg 78/81, 276 | email read out only --------------- BN ALH_16399-16403 (Def933) |
| Date/Time | from | to | email / Subject: Language - TIME SENSITIVE | doc | notes |
|---|---|---|---|---|---|
2018-12-12 10:07 am | Amber Heard | Eric George Sean Walsh | Hey there, thank you both so much for all the help you've given me and making sure that this article conveys it's message and my voice...... and also doesn't for the complicate are already complicated legal situation(s). However there's one part of the final draft that was originally nixed by your team and I've pushed back on getting some of that language reincorporated back into it so that my voice is still present and it's relevant to my experience. However there's one piece still missing from the draft as it stands now, that is kinda needed. And after speaking to my team of the ACLU, I think it be best if we all hopped on a call for five minutes. Eric or Sean, would you be able to speak soon with my team at the ACLU, Robin Shulman and Jessica Weitz and myself? | BN ALH_16444 --------------- sent after Amber's Dec 12 email re "language that was nixed" | |
2018-12-12 01:09:07 pm | Sean Walsh | Amber Heard Eric George cc Robin Shulman (ACLU) cc Jessica Weitz (ACLU) | Let me know what works for you and I will adjust accordingly. Sean | BN ALH_16444 | |
2018-12-12 06:25:30 pm | Robin Shulman (ACLU) | Sean Walsh Amber Heard cc Eric George cc Jessica Weitz (ACLU) | Thanks so much Amber and Sean. I so appreciate your work to protect Amber and also make this piece true to her experience. I'd love to hop on a phone call if you're available. I'm free now for the next 5 minutes, or again from 2-3 EST (40 minutes from now). You had a brilliant solution for the paragraph about not talking about the marriage. My concern is this paragraph: "Then two years ago, after I got a temporary restraining order against my then-husband, I felt the full force of our culture's wrath for women who speak out. The day I left the courtroom and walked into a pack of hundreds of photographers. I didn't have a team of bodyguards - my lawyers used their own bodies to block out space for me to talk to my car. The whole way there, I heard press yelling the same question in one form or another: 'Is it true you're making all this up?'" Could we cut the words "marriage," "divorce," and "restraining order" and say this, below? (If we don't say something like "I became a public figure representing domestic abuse," the rest of the piece doesn't really make sense--it's not clear whether Amber is talking about the abuse she witnessed as a child, what was the pivotal moment that changed things for her, or why she knows about institutions protecting accused perpetrators.) "Then two years ago, after I became a public figure representing domestic abuse, I felt the full force of our culture's wrath for women who speak out. Once, I had to walk into a pack of hundreds ofphotographers, many of them yelling the same question in one form or another: 'Is it true you're making all this up?'" Here's the whole piece in latest form. The only big changes are third and fourth paragraphs. Thanks so much, Robin By Amber Heard I was exposed to abuse at a very early age. I knew certain things young, without ever having to be told. I knew that men have the power, physically, socially and financially, and that a lot of institutions support that arrangement. I knew this long before I had the words to articulate it, and I bet you learned it young, too. Like many women, by the time I was college age, I had been harassed and sexually assaulted. But I kept quiet - I did not expect filing complaints to bring justice. And I didn't see myself as a victim. Then two years ago, after I became a public figure representing domestic abuse, I felt the full force of our culture's wrath for women who speak out. Once, I had to walk into a pack of hundreds of photographers, many of them yelling the same question in one form or another: "Is it true you're making all this up?" I am not going to talk here about any specific relationship in my life. What happened to me publicly is more interesting and revealing than anything that transpired within any relationship, anyway - because it shows how institutions protect men accused of abuse. Friends and advisors told me I would never again work as an actress. My own lawyer told me I would be blacklisted. Sure enough, a movie I was attached to recast my role. I had just shot a two-year campaign as the face of a global fashion brand, and the company dropped me. Questions arose as to whether I would be able to keep my role of Mera in the movies Justice League and Aquaman. Was I afraid? Terrified would be a better word. I believed I might lose my livelihood and my ability to provide for my family. No studio stood behind me, fighting to make a multimillion-dollar franchise work. Imagine a powerful man as a ship, like the Titanic. That ship is a huge enterprise. When it strikes an iceberg, there are a lot of people onboard desperate to patch up holes - not because they believe in or even care about this enterprise, but because their own fates depend on it. In recent years, the #MeToo movement has taught us about how power like this works, not just in the Hollywood machine, but in all kinds of institutions - workplaces, places of worship, or simply in particular communities. In every walk of life women are confronting these ships that are buoyed by social, economic and cultural power. And these institutions are beginning to change. We are in a transformative political moment. The president of our country has been accused by more than a dozen women of sexual misconduct, including assault, groping and harassment. Outrage over his statements and behavior has energized a female-led opposition. #MeToo started a conversation about just how profoundly sexual violence affects women in every area of our lives. And last month, more women were elected to Congreess than ever in our history, with a mandate to take women's issues seriously. Women's rage and determination to end sexual violence is turning into a political force. We have an opening now to bolster and build institutions protective of women. For starters, Congress can re-authorize and strengthen the Violence Against Women Act. First passed in 1994, VAWA is one of the most effective pieces of legislation enacted to fight domestic violence and sexual assault. It creates support systems for people who report abuse, providing funding for rape crisis centers, legal assistance programs, and other critical services. It improves responses by law enforcement. And it prohibits discrimination against LGBT survivors. Funding for VAWA expired in September, and has only been temporarily extended. We should continue to fight sexual assault on college campuses, while simultaneously insisting on fair processes for adjudicating complaints. Last month, Education Secretary Betsy DeVos proposed changes to rules known as Title IX governing the treatment of sexual harassment and assault in schools. While some changes would make the process for handling complaints more fair, others would weaken protections for sexual assault survivors. For example, the new rules would require schools to investigate only the most extreme complaints, and then only when they are made to designated high-level officials. Women on college campuses already have trouble coming forward about sexual violence - why would we allow institutions to scale back supports? And we must protest recent changes that have stopped officials from granting asylum to immigrant women who are fleeing domestic and sexual violence. I grew up in south Texas on my dad's construction sites, and I have met many women who came here seeking refuge from sexual and domestic violence. In denying them asylum, the Trump administration is reverting to the old attitude that this is a private matter, ignoring governments' inability or unwillingness to protect women. For many, the United States is their only hope to escape. If we do not offer these vulnerable people refuge, do our ideals mean anything? I know social norms are hard to change, and the backlash is powerful. I write this as a woman who had to change my phone number once a week because I was getting death threats. For months, I rarely left my apartment, and when I did, I was pursued by camera drones and photographers on foot, on motorcycles, and in cars. Tabloid news outlets that posted pictures of me spun them in a negative light. I felt like I was on trial in the court of public opinion - and my life and livelihood depended on myriad judgments far beyond my control. I want to ensure that women who come forward to talk about violence receive more support. We are electing representatives who know how deeply we care about these issues. We can work together to demand changes to laws and rules and social norms - and to right the imbalances that have shaped our lives. Amber Heard is an actress whose new movie Aquaman is coming to theaters this month, and she is an ACLU ambassador on women's rights. --------------- The two paragraphs in Robin's email starting with "Then two years ago" were written in italics, I didn't put them in italics to prevent confusion with my comments, but I added quotation marks instead. The last sentence ("Amber Heard is an actress (...)" was written in italics as well. | BN ALH_16445-16448 | |
2018-12-12 time unknown | Robin Shulman (ACLU) | Eric George & others? | presumably incomplete, only Robin's suggestion re op-ed edit was read out: "Then two years ago, after I became a public figure representing domestic abuse, I felt the full force of our culture's wrath for women who speak out. Once, I had to walk into a pack of hundreds of photographers, many of them yelling the same question in one form or another: 'Is it true you're making all this up?'" --------------- transcript says "for women to speak out" instead of "for women who speak out", either misread or mistranscribed, since in the drafts we have it's always "who" | EG depo pg 86/87 | email read out only --------------- BN ALH_16461-16464 (Def937) |
2018-12-12 time unknown | Eric George | Robin Shulman (ACLU) & others? | Robin, good edits re the paragraph you forwarded. Can you please circulate a new version with the same, and I'll give a final review? | EG depo pg 87 | email read out only --------------- BN ALH_16461-16464 (Def937) |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2018-12-12 | Exh 20 "12/12/18 E-Mail, 'Last Revised Edit ACLU Piece'", according to Eric George this is "an e-mail from AH, to myself, dated 12/12/2018, at 3:10:00 a.m.", only 3 words were read out ("my time constraints") | EG depo pg 74, 270 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: Language - TIME SENSITIVE | doc | notes |
|---|---|---|---|---|---|
2018-12-13 time unknown | Eric George | Sean Walsh cc Amber Heard cc Jessica Weitz (ACLU) cc Robin Shulman (ACLU) | Go with this. Identical to your version minus one sentence. (Once I had to go into a pack of yelling journalists asking if I was lying), which too directly raises the issue of the allegations about what you're lying about. | EG depo pg 88 | email read out only --------------- BN ALH_16484-16489 (Def936) |
2018-12-13 time unknown | Robin Shulman (ACLU) | Sean Walsh Eric George cc Amber Heard cc Jessica Weitz (ACLU)? | Hi Eric, Amber, I'm so sorry to revisit this when we thought it was in the bag, but a colleague just read the piece and noted that because of the text we removed it still felt confusing on top about what actually happened -- why Amber started losing roles and why her career was in jeopardy. We have a solution here, below -- we cut a few lines and slightly changed some wording. There's one new clause I've highlighted. Eric, does that work for you? highlighted part (non-highlighted part was not read out): "I had the rare vantage point of seeing in realtime how institutions protect men accused of abuse." | EG depo pg 90/91 | email read out only --------------- BN ALH_16297-16305 (Def940) |
2018-12-13 time unknown | Eric George | Robin Shulman (ACLU) cc Amber Heard cc Sean Walsh? cc Jessica Weitz (ACLU)? | All good to go. | EG depo pg 92 | email read out only --------------- BN ALH_16306-16312 (ALH_16306 = Def939) |
2018-12-13? time unknown | Amber Heard | Robin Shulman (ACLU) Eric George? Sean Walsh? cc Jessica Weitz (ACLU)? | Robin, when it's all ready to go and finalized, would you mind sending me the draft, so I have it in one place? | EG depo pg 93 | email read out only --------------- BN ALH_16502-16510 (ALH_16502 = Def942) |
2018-12-13 time unknown | Jessica Weitz (ACLU) | Amber Heard Robin Shulman (ACLU) Eric George? Sean Walsh? | This was worth all the orchestrations. Robin - Thank you for birthing this, and, Amber, thank you for letting the world in. | EG depo pg 274/275 | email read out only --------------- this email was sent at some point after the "Go with this" one |
| Date/Time | from | to | email / Subject: Re: Final Amber Heard Op Ed | doc | notes |
|---|---|---|---|---|---|
2018-12-13 10:45 am (UTC-5?) | Robin Shulman (ACLU) | Jessica Weitz (ACLU) cc: Ana Blinder, Gerry Johnson, Stacy Sullivan, Terry Tang, Stephen Smith (all ACLU) | Hi all, We have a final version. Stacy is taking a look now. Best, Robin | ||
2018-12-13 10:54 am (UTC-5?) | Jessica Weitz (ACLU) | Robin Shulman (ACLU) cc: Ana Blinder, Gerry Johnson, Stacy Sullivan, Terry Tang, Stephen Smith (all ACLU) | YAY!!!!!! Stacy - Amber might want her publicist to pitch after all. I know, I know... she was out late last night for her LA premiere, so before you go to the mat for this, let me just confirm with her that we are confident in handling. Give me till afternoon our time/morning her time. | ||
2018-12-13 03:58:04 pm (UTC-5?) | Stacy Sullivan (ACLU) | Jessica Weitz (ACLU) Robin Shulman (ACLU) cc: Ana Blinder, Gerry Johnson, Terry Tang, Stephen Smith (all ACLU) | Yes - and I need to read the latest version. Robin told me Amber's lawyers took out some of the stuff that made it really powerful, so let me look to see if I think it's strong enough for top-tier. I won't get to it for a bit. |
| Date/Time | from | to | email / Subject: Language - TIME SENSITIVE | doc | notes |
|---|---|---|---|---|---|
2018-12-14 time unknown | Robin Shulman (ACLU) | Amber Heard Eric George? Sean Walsh? cc Jessica Weitz (ACLU)? | (not read out / sending draft of the final version) | EG depo pg 93 | email read out only --------------- BN ALH_16502-16510 (ALH_16502 = Def942) |
| Date/Time | from | to | email / Subject: Piece by Amber Heard - // Fwd: Piece by Amber Heard - domestic abuse | doc | notes |
|---|---|---|---|---|---|
2018-12-14 11:01:38 am EST (UTC-5) | Stacy Sullivan (ACLU) | Michael Larabee (WaPo) | Hey Michael, Wondering if we might interest you in a piece by Amber Heard (who, as you may recall, was beaten up during her brief marriage to Johnny Depp) on what the incoming Congress can do to help protect women in similar situations. Many thanks! Stacy The Incoming Congress Has an Opportunity to Change how Institutions Protect Men Accused of Abuse By Amber Heard I was exposed to abuse at a very early age. I knew certain things young, without ever having to be told. I knew that men have the power, physically, socially and financially, and that a lot of institutions support that arrangement. I knew this long before I had the words to articulate it, and I bet you learned it young, too. Like many women, by the time I was college age, I had been harassed and sexually assaulted. But I kept quiet - I did not expect filing complaints to bring justice. And I didn't see myself as a victim. Then two years ago, I became a public figure representing domestic abuse, and I felt the full force of our culture's wrath for women who speak out. Friends and advisors told me I would never again work as an actress. My own lawyer told me I would be blacklisted. Sure enough, a movie I was attached to recast my role. I had just shot a two-year campaign as the face of a global fashion brand, and the company dropped me. Questions arose as to whether I would be able to keep my role of Mera in the movies Justice League and Aquaman. I had the rare vantage point of seeing in real time how institutions protect men accused of abuse. Was I afraid? Terrified would be a better word. I believed I might lose my livelihood and my ability to provide for my family. No studio stood behind me, fighting to make a multimillion-dollar franchise work. Imagine a powerful man as a ship, like the Titanic. That ship is a huge enterprise. When it strikes an iceberg, there are a lot of people onboard desperate to patch up holes - not because they believe in or even care about this enterprise, but because their own fates depend on it. In recent years, the #MeToo movement has taught us about how power like this works, not just in the Hollywood machine, but in all kinds of institutions - workplaces, places of worship, or simply in particular communities. In every walk of life women are confronting these ships that are buoyed by social, economic and cultural power. And these institutions are beginning to change. We are in a transformative political moment. The president of our country has been accused by more than a dozen women of sexual misconduct, including assault, groping and harassment. Outrage over his statements and behavior has energized a female-led opposition. #MeToo started a conversation about just how profoundly sexual violence affects women in every area of our lives. And last month, more women were elected to Congress than ever in our history, with a mandate to take women's issues seriously. Women's rage and determination to end sexual violence is turning into a political force. We have an opening now to bolster and build institutions protective of women. For starters, Congress can re-authorize and strengthen the Violence Against Women Act. First passed in 1994, VAWA is one of the most effective pieces of legislation enacted to fight domestic violence and sexual assault. It creates support systems for people who report abuse, providing funding for rape crisis centers, legal assistance programs, and other critical services. It improves responses by law enforcement. And it prohibits discrimination against LGBT survivors. Funding for VAWA expired in September, and has only been temporarily extended. We should continue to fight sexual assault on college campuses, while simultaneously insisting on fair processes for adjucating complaints. Last month, Education Secretary Betsy DeVos proposed changes to rules known as Title IX governing the treatment of sexual harassment and assault in schools. While some changes would make the process for handling complaints more fair, others would weaken protections for sexual assault survivors. For example, the new rules would require schools to investigate only the most extreme complaints, and then only when they are made to designated high-level officials. Women on college campuses already have trouble coming forward about sexual violence - why would we allow institutions to scale back supports? And we must protect recent changes that have stopped officials from granting asylum to immigrant women who are fleeing domestic and sexual violence. I grew up in south Texas on my dad's construction sites, and I have met many women who came here seeking refuge from sexual and domestic violence. In denying them asylum, the Trump administration is reverting to the old attitude that this is a private matter, ignoring governments' inability or unwillingness to protect women. For many, the United States is their only hope to escape. If we do not offer these vulnerable people refuge, do our ideals mean anything? I know social norms are hard to change, and the backlash is powerful. I write this as a woman who had to change my phone number once a week because I was getting death threats. For months, I rarely left my apartment, and when I did, I was pursued by camera drones and photographers on foot, on motorcycles, and in cars. Tabloid news outlets that posted pictures of me spun them in a negative light. I felt like I was on trial in the court of public opinion - and my life and livelihood depended on myriad judgments far beyond my control. I want to ensure that women who come forward to talk about violence receive more support. We are electing representatives who know how deeply we care about these issues. We can work together to demand changes to laws and rules and social norms - and to right the imbalances that have shaped our lives. Amber Heard, an actor in the new movie Aquaman, is an ambassador on women's rights at the American Civil Liberties Untion. | The last sentence ("Amber Heard, an actor in the new movie Aquaman (...)") was written in italics. I didn't put it in italics to prevent confusion with my comments. | |
2018-12-14 12:04 pm (UTC-5) | Stacy Sullivan (ACLU) | Michael Duffy (WaPo) Mark Lasswell (WaPo) | Hello Michael and Mark: Per Mike Larabee's out of office, I'm sending this your way. It's a piece by Amber Heard on what the new Congress can do re domestic abuse. If you're wondering why I'm pitching, she is an ACLU ambassador for women's rights and her publicist is tied up with all things aqua man. Many thanks, Stacy Sullivan (forwarding the email she previously sent to Michael Larabee) | ||
2018-12-14 02:37 pm (UTC-5) | Michael Duffy (WaPo) | Stacy Sullivan (ACLU) | Stacy, is this piece still available? Or has it been offered and accepted elsewhere? Thanks Michael Duffy | ||
2018-12-14 03:18 pm (UTC-5) | Stacy Sullivan (ACLU) | Michael Duffy (WaPo) | And btw, my husband is Karl Vick.... So your name looms large in the household. He speaks of you in adoringly. :) | there seems to be an email missing from Stacy S. in response to Michael D. | |
2018-12-14 04:33 pm (UTC-5) | Michael Duffy (WaPo) | Stacy Sullivan (ACLU) | Amazing. Lovely to meet you. So we will take this, in a shorter form, sometime next week, likely for the web only. More to come early next week. Hope KV gets a break after POY. md | ||
2018-12-14 04:37 pm (UTC-5) | Stacy Sullivan (ACLU) | Michael Duffy (WaPo) | Poor guy was so wiped out. But I'm the only one that needs a break! Single-parenting for 3 weeks. :) Ok, great. Totally fine to shorten. Just bear in mind that the piece was heavily lawyered by her people bc she signed a non-disclosure agreement and Depp is litigious, so there may be some phrasing that can't be changed. |
| Date/Time | from | to | email / Subject: Language - TIME SENSITIVE | doc | notes |
|---|---|---|---|---|---|
2018-12-14 time unknown | Jessica Weitz (ACLU) | Sean Walsh cc Robin Shulman (ACLU) cc Eric George cc Amber Heard | It's going to the Washington Post!!! It will run next week and we are awaiting final details. Stay tuned for more. | email read out only --------------- BN ALH_16510-16528 (ALH_16520-16528 = Def943) BN ACLU_324-332 (Plt19) |
| Date/Time | from | to | email / Subject: Piece by Amber Heard - // Fwd: Piece by Amber Heard - domestic abuse | doc | notes |
|---|---|---|---|---|---|
2018-12-17 04:04 pm (UTC-5?) | Michael Duffy (WaPo) | Stacy Sullivan (ACLU) | Ok, take a look. I cut it just below 800 (it came in above 1000) and so it had to come down. Don't think its lost a bit of its power. We will run it this week, sometime. Let me know what you think? | ||
2018-12-17 09:09:01 pm (UTC-5?) | Stacy Sullivan (ACLU) | Robin Shulman (ACLU) | --- (forwarding MD's email incl. attached doc to RS) |
| Date/Time | from | to | email / Subject: Language - TIME SENSITIVE | doc | notes |
|---|---|---|---|---|---|
2018-12-17 03:02 pm | Robin Shulman (ACLU) | Eric George Amber Heard cc Sean Walsh? cc Jessica Weitz (ACLU)? | Hi everyone, Hope you're all doing well. Here's the edit back from the WashPost. The only real change I noticed was in the very first line, when they cut the first mention of being an early witness to abuse. I added the bit about "one of my own lawyers".. in bold. Amber, could you take a look by tomorrow morning 9am so we can get back to them? And Jess will get back to you about talking points. Thank you again! Robin --------------- presumably with op-ed draft attached | BN ALH_16328-16338 (Def1552) | |
2018-12-17 11:02:13 pm | Eric George | Robin Shulman (ACLU) cc Amber Heard cc Sean Walsh cc Jessica Weitz (ACLU) | Robin - All good EXCEPT that edit is a NO GO. Pls explain to the Post that one cannot reveal discussions w a lawyer without waiving the attorney-client privilege. Can't let that happen here, esp since the edit adds nothing. Amber can simply say that an 'advisor' made that stmt to her. OK? Thanks, E | BN ALH_16328-16338 (Def1552) |
| Date/Time | from | to | email / Subject: Language - TIME SENSITIVE | doc | notes |
|---|---|---|---|---|---|
2018-12-18 time unknown | Robin Shulman (ACLU) | Eric George Amber Heard cc Sean Walsh? cc Jessica Weitz (ACLU)? | I think what you're referring to is just that slight change to wording of our previous language that has been in the piece all along - from "my own lawyer" to "one of my own lawyers," but if you feel it's problematic, we can reword. We'd have to change those sentences to, "My own friends and advisors told me I would never work again as an actress, I'd be blacklisted." Sound good to you, Amber? Is that what you want, Eric? | EG depo pg 98/99 | email read out only --------------- BN ALH_16350-16362 (Def945) |
2018-12-18 time unknown | Eric George | Robin Shulman (ACLU) cc Amber Heard? cc Sean Walsh? cc Jessica Weitz (ACLU)? | Yes, since the word "lawyer" can't be included without possibly waiving privilege. | EG depo pg 99 | email read out only --------------- BN ALH_16350-16362 (Def945) |
2018-12-18 05:05 pm (UTC-5?) | Jessica Weitz (ACLU) | Robin Shulman (ACLU) Sean Walsh cc Eric George cc Amber Heard? | Fantastic! Robin or I will get you the cleanest copy of this. We just heard from the Washington Post that this will be in the paper tomorrow. I will send through suggested share language under separate cover with Amber, Sara, and Jodi. | EG depo pg 100 | email read out only --------------- BN ALH_16363-16373 (Def948) --------------- transcript says "from Jessica Weitz, Robin Shulman, and Sean Walsh, and you are copied", I assume it meant from JW "to" RS/SW/EG, I would also assume this was sent to Amber as well |
2018-12-18 time unknown | Robin Shulman (ACLU) | Amber Heard | Here it is final. (with final draft of op-ed attached) --------------- (going by the exhibit description, the email may have actually said "Here's the final.") | EG depo pg 101 | email read out only --------------- BN ALH_16374-16386 (Def946) |
| Date/Time | from | to | email / Subject: Edited version of Ms. Heard's Washington Post op-ed | doc | notes |
|---|---|---|---|---|---|
2018-12-18 04:23 pm (UTC-5?) | Chris Hanna (WaPo) | Stacy Sullivan (ACLU) cc Trey Johnson (WaPo) | Good afternoon. Below is an edited version of Amber Heard's Washington Post op-ed on women and abuse. Please review the text carefully, as it is our last chance to make changes before publication. If you have any questions or concerns, please hit reply-all to this email so our copy chief will see the message as well. I do have a quick question highlighted in the text below. Thanks so much, and have a great evening. Chris -- I was exposed to abuse at a very early age. I knew certain things early on, without ever having to be told. I knew that men have the power - physically, socially and financially - and that a lot of institutions support that arrangement. I knew this long before I had the words to articulate it, and I bet you learned it young, too. Like many women, I had been harassed and sexually assaulted by the time I was college age. But I kept quiet - I did not expect filing complaints to bring justice. And I didn't see myself as a victim. Then two years ago, I became a public figure representing domestic abuse, and I felt the full force of our culture's wrath for women who speak out. Friends and advisors told me I would never again work as an actress - that I would be blacklisted. A movie I was attached to recast my role. I had just shot a two-year campaign as the face of a global fashion brand, and the company dropped me. Questions arose as to whether I would be able to keep my role of Mera in the movies "Justice League" and "Aquaman." I had the rare vantage point of seeing, in real time, how institutions protect men accused of abuse. Was I afraid? Terrified would be a better word. I believed I might lose my livelihood and my ability to provide for my family. No studio stood behind me, fighting to make a multimillion-dollar franchise work. Imagine a powerful man as a ship, like the Titanic. That ship is a huge enterprise. When it strikes an iceberg, there are a lot of people on board desperate to patch up holes - not because they believe in or even care about this man, but because their own fates depend on the enterprise. QUESTION: I would suggest changing "this man" to "the ship," to maintain the analogy formed at the beginning of the paragraph. Conversely, in the following paragraph, I would change the word "ships" to "men." However, I did not want to do so without running it past you first. Thoughts? In recent years, the #MeToo movement has taught us about how power like this works, not just in Hollywood, but in all kinds of institutions - workplaces, places of worship, or simply in particular communities. In every walk of life, women are confronting these ships that are buoyed by social, economic and cultural power. And these institutions are beginning to change. We are in a transformative political moment. The president of our country has been accused by more than a dozen women of sexual misconduct, including assault and harassment. Outrage over his statements and behavior has energized a female-led opposition. #MeToo started a conversation about just how profoundly sexual violence affects women in every area of our lives. And last month, more women were elected to Congress than ever in our history, with a mandate to take women's issues seriously. Women's rage and determination to end sexual violence is turning into a political force. We have an opening now to bolster and build institutions protective of women. For starters, Congress can re-authorize and strengthen the Violence Against Women Act. First passed in 1994, the act is one of the most effective pieces of legislation enacted to fight domestic violence and sexual assault. It creates support systems for people who report abuse, and provides funding for rape crisis centers, legal assistance programs, and other critical services. It improves responses by law enforcement, and it prohibits discrimination against LGBTQ survivors. Funding for the act expired in September, and has only been temporarily extended. We should continue to fight sexual assault on college campuses, while simultaneously insisting on fair processes for adjucating complaints. Last month, Education Secretary Betsy DeVos proposed changes to Title IX rules governing the treatment of sexual harassment and assault in schools. While some changes would make the process for handling complaints more fair, others would weaken protections for sexual assault survivors. For example, the new rules would require schools to investigate only the most extreme complaints, and then only when they are made to designated officials. Women on campuses already have trouble coming forward about sexual violence - why would we allow institutions to scale back supports? I write this as a woman who had to change my phone number weekly because I was getting death threats. For months, I rarely left my apartment, and when I did, I was pursued by camera drones and photographers on foot, on motorcycles, and in cars. Tabloid outlets that posted pictures of me spun them in a negative light. I felt as though I was on trial in the court of public opinion - and my life and livelihood depended on myriad judgments far beyond my control. I want to ensure that women who come forward to talk about violence receive more support. We are electing representatives who know how deeply we care about these issues. We can work together to demand changes to laws and rules and social norms - and to right the imbalances that have shaped our lives. The writer is an actress and ambassador on women's rights at the American Civil Liberties Union. | ||
2018-12-18 04:30 pm (UTC-5?) | Stacy Sullivan (ACLU) | Jessica Weitz (ACLU) cc Robin Shulman (ACLU) | final (forwarding CH's email to JW & RS) | ||
2018-12-18 04:37 pm (UTC-5?) | Jessica Weitz (ACLU) | Stacy Sullivan (ACLU) cc Robin Shulman (ACLU) | I can't go back to them with this question right now and Amber is at the hospital with her sister. | ||
2018-12-18 04:40:20 pm (UTC-5?) | Stacy Sullivan (ACLU) | Jessica Weitz (ACLU) cc Robin Shulman (ACLU) | Ok. so shall we just say don't change it and run as is? | ||
2018-12-18 05:54:22 pm (UTC-5?) | Robin Shulman (ACLU) | Stacy Sullivan (ACLU) Jessica Weitz (ACLU) | I agree with their change. Go for it! |
| Date/Time | from | to | email / Subject: USA: Amber Heard speaks out again about domestic abuse, despite consequences she says she paid | doc | notes |
|---|---|---|---|---|---|
2018-12-19 02:24:37 am (UTC-5?) | Jessica Herman Weitz (ACLU) | Gerry Johnson (ACLU) | So much for not mentioning JD... (with link to USA Today article) |
| Date/Time | from | to | email / Subject: USA Today on Amber's op-ed | doc | notes |
|---|---|---|---|---|---|
2018-12-19 02:47 pm (UTC-5?) | Stacy Sullivan (ACLU) | Jessica Herman Weitz (ACLU) (Robin Shulman (ACLU) ?) | link to USA Today article | ||
2018-12-19 03:30 pm (UTC-5?) | Jessica Herman Weitz (ACLU) | Stacy Sullivan (ACLU) Robin Shulman (ACLU) | Yeah. Pretty deplorable. | ||
2018-12-19 08:50:54 pm (UTC-5?) | Robin Shulman (ACLU) | Jessica Herman Weitz (ACLU) cc Stacy Sullivan (ACLU) | It's kind of amazing that they just grabbed the entire op ed and rewrote it using johnny depp's name. |
| Date/Time | from | to | email / Subject: FW: Johnny Depp's Jack Sparrow Won't Return in New Pirates of the Caribbean Movie | doc | notes |
|---|---|---|---|---|---|
2018-12-20 01:28 pm (UTC-8?) | Robin Baum | Christian Carino | FYI (with link to movieweb article) | ||
2018-12-20 03:26 pm (UTC-8?) | Christian Carino | Jack Whigham | Were we told this officially from Disney | ||
2018-12-20 03:30 pm (UTC-8?) | Jack Whigham | Christian Carino | no | ||
2018-12-20 03:31:42 pm (UTC-8) | Christian Carino | Jack Whigham | what do we do |
| Date/Time | from | to | email / Subject: congrats and studio thrilled | doc | notes |
|---|---|---|---|---|---|
2018-12-31 time unknown | Rob Cowan | Amber Heard | I'm sure you've been seeing the numbers. Studio is thrilled. Have a happy and healthy New Year. Big hug, Rob. | WH depo pg 76/77 | email read out only --------------- BN ALH_18268 (Def1278) |
2019
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2019-01-03 | Exh 24 "Rouse Email" re Alisha Rouse inquiring about THR article from January 03, 2019 | JW depo pg 137/138 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: The Independent Inquiry | doc | notes |
|---|---|---|---|---|---|
~2019-01-04 time unknown | reporter (The Independent) | ? | Per Adam, we are not comm | JW depo pg 138 | email mentioned only |
~2019-01-04 time unknown | Robin Baum | multiple people incl. Jack Whigham's assistant | Per Adam, we are not commenting. | JW depo pg 138 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2019-01-13 time unknown | Amber Heard | Rob Cowan | Rob, congratulations. OMG, 1 billion. Can I put in my request for, say, Hawaii or Bali sequel, titled Mera, I'm assuming? LOL. | WH depo pg 76/77 | email read out only --------------- BN ALH_18268 (Def1278) |
2019-01-13 time unknown | Rob Cowan | Amber Heard | Love you, too, and congrats to you. Yes. Mera -- the Further Adventures of Mera and Sidekick what's his name. | WH depo pg 76/77 | email read out only --------------- BN ALH_18268 (Def1278) |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2019-03-01 time unknown | Jack Whigham | Joel Lubin (CAA) Michael Cooper (CAA) | (sending link to article about Johnny Depp filing defamation lawsuit) | JW depo pg 140 | email read out only --------------- Def1610 |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2019-03-08 time unknown | Jack Whigham | Johnny Depp | I'm loving these headlines and good momentum. Talking to Adam every day and feeling good. I hope you're getting some rest while working. Need you healthy. Big hug bruthaman and much love. It's always painful to see your slang. | JW depo 143-147 | email read out only --------------- BN DEPP8124 (Def983) |
2019-03-08 time unknown | Johnny Depp | Jack Whigham | I am so fucking proud of what Adam has been doing. The motherfucker hasn't even thought of stopping since day fucking one. We are getting there. | JW depo 143-147 | email read out only --------------- BN DEPP8124 (Def983) |
2019-03-08 time unknown | Jack Whigham | Johnny Depp | Shea is always sending you much love and asking me, who do we need to knock off for J? | JW depo 143-147 | email read out only --------------- BN DEPP8124 (Def983) |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2019-04-11 time unknown | Dr. David Kipper | Stephen Deuters | I'm writing after receiving some concerning news about our mutual friend and my patient. I'm concerned that my prescribing will only create problems with his health and be dangerous given this information. I've asked that after his scan today he make an appointment to see me in the office tomorrow or Friday to review the situation and his general health and scans. I'll also need to get a laboratory panel to assess his wellness. | DK depo pg 161/162 | email read out only |
| Date/Time | from | to | email / Subject: Johnny Depp Accused of Trying to Get Amber Heard Fired from Aquaman | doc | notes |
|---|---|---|---|---|---|
2019-04-19 12:48 pm PDT (UTC-7) | Robin Baum | Yohana Desta (Vanity Fair/Conde Nast) | Please update your story with the below quote from Johnny Depp's lawyer Adam Waldman. Thank you. "Jake Bloom and Bloom Hergottt, being sued for over $60 million for gross breaches of their fiduciary duties including improperly swiping Johnny Depp's back end film rights, desperately tried yesterday to join hands with others being sued for abusing Mr. Depp, with media clickbait allegations of "blacklisting" efforts. Grotesquely, it is the opposite of their assertion that is objectively true: according to the New York Post, "senior executives at Warner Bros.," who are the company's #Metoo leadership and personally close with Amber Heard, claimed a week ago Warner Bros. will throw Johnny Depp off the Fantastic Beasts franchise in which he stars because of Ms. Heard's unambiguously disproven abuse hoax. One week later, Warner Bros has notably failed to make any statement correcting this news report. Ms. Heard continues to enjoy the public support of powerful institutions like L'Oréal, ACLU, the UN and the media despite the unambiguous evidence of her hoax and her documented history of violence. Will Warner Bros stand with real abuse victims or with hoaxsters who are chummy with their executives?" https://www.vanityfair.com/hollywood/2019/04/johnny-depp-legal-battle-amber-heard-aquaman | BN BAUM1764 (Def958) |
| Date/Time | from | to | email / Subject: ACLU Ambassador Amber Heard And Defamation Suits Against Women Alleging Abuse | doc | notes |
|---|---|---|---|---|---|
2019-05-06 time unknown | Jennifer Robinson | Anthony Romero (ACLU) | I was hoping to speak with you about how ACLU might be able to engage with and support her, and what creative ideas you might have about how to combat this. | TD depo pg 321-323 | email read out only |
~2019-05-06 time unknown | Anthony Romero (ACLU) | Ben Wizner (ACLU) & others | (forwarding JR's email) | TD depo pg 321-323 | email read out only |
| Date/Time | from | to | email / Subject: Amicus Brief In Depp V Heard | doc | notes |
|---|---|---|---|---|---|
~2019-05-09 time unknown | Vera Eidelman (ACLU) | Eden Heilman (ACLU) cc Ben Wizner (ACLU) cc Brian Hauss (ACLU) cc Arianna Demas (ACLU) | Her legal team has asked us to file an amicus brief in support of her demurrer, with a likely deadline of late next week or the following. | TD depo pg 338-341 | email read out only |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2019-05-19 | Exh 49 "5/19/19 E-Mails, 'Re: ACLU Comms Team Connect'" | TD depo pg 333/334 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: ACLU Support For Amber | doc | notes |
|---|---|---|---|---|---|
~2019-05-30 time unknown | Jessica Weitz (ACLU) | Jodi Gottlieb & others | We're working on a blog post about First Amendment rights as it pertains to Amber's case. | TD depo pg 335/336 | email read out only |
2019-05-30 time unknown | Richard Schwartz | Jessica Weitz (ACLU) & others | You are correct that at this time the legal team is not looking for an amicus brief filing, but we would most certainly welcome a blog post or social media outreach supporting Amber and identifying Johnny's tactics as typical of how abusers deny reality and attempt to gaslight those they abuse. | TD depo pg 335/336 | email read out only --------------- Richard Schwartz = lawyer who was working with Eric George |
| Date/Time | from | to | email / Subject: DRAFT declaration | doc | notes |
|---|---|---|---|---|---|
2019-06-25 time unknown | Adam Waldman | Laura Divenere | Dear Laura Thank you again for speaking today as a witness of some simple matters which are nevertheless at the heart of the case. I took good notes of our conversation. I wrote a up a nearly 1 pager that is attached for your review, edit and comment and blank filling in. I used the words you did in your testimony, and hope that you agree that I did so faithfully. I did not include the topics that I promised I would not. If you would, as discussed, carefully review the attached, and let me know if you have comment or elaboration, Johnny and I would be grateful. We would then put it into proper final form for signature and later will file it along with the chorus of testifying witnesses. Thank you again for spending the time. Kind regards, Adam (draft declaration attached) |
| Date/Time | from | to | email / Subject: Re: Final Declaration with your last revisions | doc | notes |
|---|---|---|---|---|---|
2019-06-28 time unknown | Laura Divenere | Adam Waldman | Correct - I did not speak with Amber's friends about it - that would have been out of character and something I would have recall on. The only thing that would have been said was something like asking how she was doing. That said? I have been racking my brain this past week trying to recall what were the times like when I saw her immediately after the breakup, and in all honesty I can't say 100% for certain that it wasn't brought up. I'm inclined to think she had mentioned it because given the circumstances it would have (I think) been normal to do so it also just wouldn't have been that memorable to me at the time as it was common knowledge their relationship was difficult, and because I hadn't noticed any signs of physical abuse. (rest of email missing) |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2019-07-11 time unknown | Richard Schwartz | Elizabeth Marz | After meeting with us, here is a summary, a draft declaration for you to review. (draft declaration attached) | EM depo pg 190-192, 203 | email read out only --------------- Richard Schwartz = lawyer who was working with Eric George |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2019-10-07 | Exh 05 "10/7/19 E-Mail, 'Re: Request'" re Amber Heard's billing records & chart with sessions | CC depo pg 61-63 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: Re: URGENT! | doc | notes |
|---|---|---|---|---|---|
2019-11-11 11:42:27 am EST (UTC-5) | Adam Waldman | Christian Seitz Benjamin Chew Camille Vasquez | I have interviewed Drew. Here are the key points from that call: 1. Rocky and Amber's sworn stories that she was summoned by an 8:07 pm text to come help her with a berserk johnny was "a lie." Rocky was hiding in penthouse 5 all along, almost certainly in the coat closet by the front door, which explains both the security guards testimony that she never came past them and was already in the apartment when they entered and Johnny's that Rocky just came out of nowhere past his right shoulder to go stand with Amber. Super important fact, and I hope he will repeat it. This makes the whole thing a set up, and discredits both their testimony. 2. Amber was sleeping with Musk all the week after the 21st (obviously not on Franco's night, the 22nd). 3. Amber and Musk were into some kinky things together. He didn't elaborate. 4. She did have "marks" on her at times. He even seemed to suggest she had marks on her the night of the 21st, although of course we know this is not true. Do we know if he ever gave a declaration to Amber? I bet he did, back then. 5. There was a long gap between Johnny's departure and calling the cops. Perhaps an hour or more, he couldn't be precise. During that time, they all sat together in PH3 on the phone with Samantha Spector her divorce lawyer who was guiding them to "writing it all down" to get their stories straight, before calling the cops. |
2020
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2020-01-22 | Exh D-21 "1/22/20 E-Mail, 'Re: Thank You'" | TD depo pg 420/421 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: Johnny Depp | doc | notes |
|---|---|---|---|---|---|
2020-02-26 05:57 pm (UTC-8) | Robin Baum | Kenzie Bryant (Vanity Fair) | Below is from Adam Waldman, Johnny Depp's lawyer. We ask for fair comment in regard to the below story. Thank you. "What does the Sun do to keep Amber Heard's hoax alive? Today in court we learned the answer - cherry picking a fragment of a single frustrated text message to a friend sent out of 500 gigabytes of text and email messages provided. Inconveniently for the Sun, here is what Mr Depp atually said next in his text - that he could never harm Amber: 'I am admittedly too f***** in the head to spray my rage at the one I love.'" (with link to Vanity Fair article) | ||
2020-02-27 07:31 am | Kenzie Bryant (Vanity Fair) | Robin Baum | Thanks Robin, running an update that should appear soon. Are you the best contact for comment on both cases, in the UK and US moving forward? Kenzie | ||
2020-02-27 11:42 am PST (UTC-8) | Robin Baum | Kenzie Bryant (Vanity Fair) | I haven't seen an updated story. Please use the below comment from Adam Waldman. "This is why Johnny Depp seeks justice in court and not the media. The media will not report that at the end of a demonstrated abuse victim's single frustrated text to a friendd, Johnny confides to Paul Bettany that he could in fact never "spray my rage at the one I love" and says he will use pills instead to numb the pain. This is the best text of 70,000 the desperate Sun tabloid could muster to save their skin." |
| Date/Time | from | to | email / Subject: RE: 1782 Application | doc | notes |
|---|---|---|---|---|---|
2020-03-10 06:36 am | Laura Divenere | Lee A. Sherman | partially read out only: Highly apologise for the delay. paragraph 3: I want it to be clear to everyone, I gave a declaration in this case. My declaration is 100% truthful and that will not change. In retrospect, where I may have thought I was unduly pressured to write and sign my declaration, I now believe that was not the case. My declaration went through three iterations with my complete involvement and understanding. Again, I signed knowing that my declaration was truthful best to my recollection. I did the best I could do. Again, I signed my declaration knowing that my declaration was truthful to the best of my recollection. I did the best I could. I find the communications from the The Sun's lawyers extremely burdensome and threatening. I told the truth and continued to tell the truth here in my letter. I want to be left alone. (a paragraph was skipped) Please forward this letter to all counsel involved for Depp, Heard and the Sun newspaper (UK). --------------- presumably one of the skipped paragraphs: I've had nothing but a positive relationship with both Johnny and Amber. Since the time I was first approached to submit a declaration I have come to understand that all attorney's seek information similarly. I signed the declaration knowing that it was 100% truthful to the best of my knowledge. Pertaining to the Hollywood Reporter article: This episode mentioned happened no more than a week after the signing. I was an emotional wreck when asked by Amber to stop by to discuss the declaration. During this meeting I expressed honestly how apologetic my declaration hurt her. I do not ever recall seeing her with a black eye, and do remember telling her so. I was never aware of a recording taking place. This situation has really taken a toll on me emotionally, physically and financially. I have given all the information I have to give. If compelled to give testimony I will do so truthfully and will acknowledge that I was not coerced into signing the declaration. | email partially read out only --------------- Plt249 | |
2020-03-10 time unknown | Lee A. Sherman | Laura Divenere | Good morning, Laura. Here is the draft response. beginning of draft response: "Good morning, Alexander. I have now had the opportunity to discuss these matters with my client." | email partially read out only | |
2020-03-10 01:16 pm | Laura Divenere | Kevin Murphy | forwarding the above exchange incl. Lee Sherman's draft response, part of which said: "My client's position is that she voluntarily gave a truthful and accurate declaration in the other case based on her best recollection of the events and if compelled by the US District Court to testify; her testimony will be completely consistent with that position." | email mentioned only | |
2020-03-10 02:07 pm | Lee A. Sherman | Alexander Rufus-Isaacs | Good afternoon Alexander: I have now had the opportunity to discuss these matters with my client. My client's position is that she voluntarily gave a truthful and accurate declaration in the other case based on her best recollection of the events described and if compelled by the US District Court to testify; her testimony will be completely consistent with that position. As I mentioned to you the other day, the declaration in question went through 3 versions with my client requesting changes to ensure accuracy before she signed it. If she is forced to testify, I believe that will come out as well. As you are well aware, my client did not provide any declaration to anyone involved in the UK matter and has no involvement in that case whatsoever. Moreover, she is quite upset with the Sun's continued threats and attempts to force her involvement in its case. With that in mind, please be further advised that my client has also provided our office with authority to oppose the petition to compel her testimony if filed and we will do so. However, we certainly hope it does not come to that. Thank you, |
| Date/Time | from | to | email / Subject: Re: Johnny Depp vs Amber Heard | doc | notes |
|---|---|---|---|---|---|
2020-03-17 07:42:28 pm EDT (UTC-4) | Lee A. Sherman | Adam Waldman | Mr. Waldman: I've received your message. First, my client is unaware of any recording and to my knowledge never consented to being recorded. So, as far as I'm concerned, any such recording, if indeed there is one of my client, would be in violation of Ca Penal Code 632. Second, I have previously advised counsel for The Sun that she had the opportunity to make changes to her declaration and that the matters stated in her declaration were true and correct to the best of her knowledge. |
| Date/Time | from | to | email / Subject: AH issues | doc | notes |
|---|---|---|---|---|---|
2020-05-27 09:30:37 am PDT (UTC-7) | Kimberly Kress (NYC-MEW) (McCann) | Katie Slater (WME Agency) cc Katie Slater Assistant | Hi Katie, There has been another wave of negative IG comments on L'Oreal's IG after two posts featuring Amber (her Preference commercial and her Cannes women/cinema image/quote). Someone also found an article saying she is about to be dropped by Aquaman 2 due to the change.org petition to remove her from the film and all the bad press she gets. Is this article true? I can't imagine that it is but there is real concern. I know this is not new news and that we have weathered this in the past but there is a new high level person across all L'Oreal business in the Americas and he's throwing up the warning signs again... Please let me know ASAP about Aquaman 2 and if you have any info on the latest spate of negative IG comments. Also, it's been awhile since we heard from her attorneys but assuming there is no update on the UK and US trials due to Covid, right? Best, KK | ||
2020-05-27 05:32 pm | Katie Slater (WME Agency) | Warren Zavala (WME Agency) Jessica Kovacevic (WME Agency) Jodi Gottlieb | See below re L'Oréal and Amber. There's no truth to the Aquaman 2 rumors, right? If there is anything else helpful and reassuring to share with L'Oréal please let me know. (forwarding KK's email) | ||
2020-05-27 05:37 pm | Jodi Gottlieb | Katie Slater (WME Agency) Warren Zavala (WME Agency) Jessica Kovacevic (WME Agency) | I believe they are just rumors from crazy Johnny supporters, but WZ/JK to advise. And to be honest, our company with 3,000 followers gets killed consistently on Instagram when we post about Amber. There has to be a algorithm that they follow as there is no way they would know what @independentpublicrelations is doing and posting unless they have a way of tracking us in other ways. Additionally, I have clicked on many of those making obscene comments and they all seem like bots. | ||
2020-05-27? time unknown | Jessica Kovacevic (WME Agency) | ? (presumably everyone previously involved) | Can I get on the phone w them to nip it in the bud? There is zero truth Warner doesn't even acknowledge these statements exist, and ive had zero calls of concern from anyone at the studio | ||
2020-05-28 02:15:57 am | Katie Slater (WME Agency) | Jessica Kovacevic (WME Agency) cc Jodi Gottlieb cc Warren Zavala (WME Agency) | (redacted?!) |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2020-06-17 | Exh 58 "6/17/20 E-Mails, 'Re: ACLU Subpoena'" | TD depo pg 354/355 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: A quick question | doc | notes | ||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
~2020-07-02 time unknown | Elaine Bredehoft? | ACLU | (request regarding the amounts contributed to the ACLU that were connected to the ACLU's relationship with Amber Heard) | TD depo pg 359-363 | email mentioned/paraphrased only --------------- the transcript says "a request from Ms. Bredehoft", so I'm assuming she sent the email, but could have been someone emailing on her behalf or maybe Michelle Bredehoft (paralegal at EB's firm) | ||||||||||||||||||||
2020-07-02 04:51 pm | Jonathan Maresco (ACLU) | Mark Wier (ACLU) | Hi Mark, according to her record in Salesforce, she's made the gifts below. Hide Adjustments ☑
| ||||||||||||||||||||||
~2020-07-02 time unknown | Anthony Romero | (ACLU colleague(s)) | What about the $100,000? | TD depo pg 359-363 | email read out only | ||||||||||||||||||||
~2020-07-02 time unknown | Anthony Romero | Jonathan Maresco (ACLU) | Did Elon's other gifts come from Vanguard? | TD depo pg 359-363 | email read out only | ||||||||||||||||||||
~2020-07-02 time unknown | Jonathan Maresco | Anthony Romero (ACLU) | One of them yes. His $5 million gift in February 2017 was from Vanguard. In any case, my understanding was that the $500,000 from Vanguard was recommended by EM. | TD depo pg 359-363 | email read out only | ||||||||||||||||||||
~2020-07-02 time unknown | Jonathan Maresco | (ACLU colleague(s)) | (Elon Musk's) $1 million gift in May 2018 was from Fidelity. (transcribed as "May of 2018", read out in deposition video as "May 2018") | TD depo pg 359-363 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2020-07-28 11:02 am | Jennifer Howell | Whitney Henriquez | (sending email with letter, presumably the one from July 25, 2020, attached) | JH WS 01 pg 09 (BN DEPP20942) | time based on JH deposition (US21//7022 or JH depo vol. 02 pg 325). |
2020-07-28 08:01 am | Jennifer Howell | Whitney Henriquez | I was just given the statement you made about me to go to press. Wow, Whitney! If you want to call me a liar while you are lying under oath then I promise you that I will prove in every way that I am not lying. You questioning my integrity, my honesty, the sincerity that I take with my word is desperate at best. Again, there are 20 plus people that heard everything that you said. I have opened my home, heart, life to you and have never been anything but honest and loving with you. I let you in when you told me you needed to be protected from your sister. I love you and am doing everything in my power to do what is right for you and you call me a liar. Wow! |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2020-07-28 | Exh 4 "Email chain", email from Jennifer Howell to Whitney Henriquez on or about Tuesday, July 28, 2020, at 11:02 am, then forwarding the email exchange and the attachments to Marcel Pariseau | JH depo vol. 02 pg 325/326 | if you're willing & able to transcribe this exhibit, please let me know |
| Date/Time | from | to | email / Subject: Amber Heard Reuters | doc | notes |
|---|---|---|---|---|---|
~2020-07-29 time unknown | Jill Serjeant (Reuters) | Inga Sarda-Sorensen (ACLU) Tyler Richard (ACLU) | I'm preparing some material while awaiting a verdict in the Johnny Depp libel trial in London, and wanted to fact check Amber Heard's current/previous links with the ACLU. | TD depo pg 364-370 | email read out only |
~2020-07-29 time unknown | Jessica Weitz (ACLU) | Tyler Richard (ACLU) Inga Sarda-Sorensen (ACLU) ACLU media | ... the answer is yes, she's still an ambassador. She donated her full settlement to charity, 50% to the ACLU, and 50% to another organization. | TD depo pg 364-370 | email read out only |
2020-07-29 05:48 pm | Jessica Weitz (ACLU) | presumably same as above | We have no reason not to believe Amber's claims. | TD depo pg 364-370 | email read out only |
| Date/Time | from | to | email / Subject: Quick check with you on a press question - time sensitive | doc | notes |
|---|---|---|---|---|---|
2020-07-30 01:06 pm | Jessica Herman Weitz (ACLU) | Jonathan Maresco (ACLU) | Hi Jon, I hope you're doing ok. We have been approached by Reuters to comment on the libel trial in the UK between J. Depp and Amber Heard. Based on their questions, we are planning to respond with the below, but can you let me know if you're ok with it from a development perspective, for accuracy: "Amber Heard is an ACLU Ambassador for Women's Rights since 2018. While we typically do not share information about our donors, because Amber shared the information publicly we can confirm that she donated her full settlement to charity - 50% to the ACLU and 50% to another organization." Thank you! Jessica | the 2nd paragraph was written in italics, I didn't put it in italics to prevent confusion with my comments, but I added quotation marks instead | |
2020-07-30 01:10 pm | Jonathan Maresco (ACLU) | Jessica Herman Weitz (ACLU) cc Mark Wier (ACLU) | Hi Jessica, I hope you're well, too. I defer to Mark on how we want to answer this question. I cannot confirm the accuracy of the statement. Thanks. -Jon | ||
2020-07-30 03:42 pm | Jessica Herman Weitz (ACLU) | Jonathan Maresco (ACLU) cc Mark Wier (ACLU) | Mark - is the donation language accurate? | ||
2020-07-30 06:19 pm | Mark Wier (ACLU) | Jessica Herman Weitz (ACLU) cc Jonathan Maresco (ACLU)? | It's not quite accurate. You could say that she "pledged" the full settlement to charity, but we've only received a portion of the pledge to date... | ||
2020-07-30 06:56 pm | Jessica Herman Weitz (ACLU) | Mark Wier (ACLU) cc Jonathan Maresco (ACLU)? | Oh really? I didn't know that. How much? | ||
2020-07-30 07:25 pm | Mark Wier (ACLU) | Jessica Herman Weitz (ACLU) cc Jonathan Maresco (ACLU) | I don't have the exact numbers at hand but I think she's contributed less than half of the pledge to date. Jon, does that sound right? | ||
2020-07-30 07:28:27 pm | Jonathan Maresco (ACLU) | Mark Wier (ACLU) Jessica Herman Weitz (ACLU) | Yes that's right, Mark. |
| Date/Time | from | to | email / Subject: Amber Heard Reuters | doc | notes |
|---|---|---|---|---|---|
~2020-07-31 time unknown | Tyler Richard (ACLU) | Jessica Weitz (ACLU) | Amber Heard is an ACLU ambassador for women's rights since 2018. She also pledged her full settlement to charity. | TD depo pg 375-379 | email read out only --------------- regarding how they should respond to Reuters asking about Amber and her contributions to the ACLU --------------- Plt26 |
~2020-07-31 time unknown | Jessica Weitz (ACLU) | Tyler Richard (ACLU) | Yeah, I think that's safer. I had nightmares about this last night. I'm very upset. Do you think this is okay? | TD depo pg 375-379 | email read out only --------------- Plt26 |
2020-07-31 time unknown | Jessica Weitz (ACLU) | Tyler Richard (ACLU) | I'm just stressed about her and the difficulties with all this. | TD depo pg 375-379 | email read out only --------------- Plt26 |
| Date/Time | from | to | email / Subject: Anthony | doc | notes |
|---|---|---|---|---|---|
2020-08-02 time unknown | Jennifer Howell | James Franco | (beginning not read out) Well, I got two subpoenas from Johnny Depp's attorney and had to give a sworn statement to the truth after Whitney Heard brought me up on stand. (possibly part skipped) I am attaching the letter that I personally wrote to Whitney after speaking to the attorney. I am sharing this with you because if you feel compelled to share only what you did or did not see on the elevator that day, you could put an end to all of this. (partially read out only) and paying attention to the witness statements and trial transcripts. I am deeply ashamed that it took two subpoenas to speak the truth. | JH depo vol. 01 pg 125/126, 129, 137, 147/148 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2020-08-02 time unknown | Jennifer Howell | Vince Jolivette | I sent an e-mail because I had to do the right thing. The decision is in both of your hands and I have done everything in my power to bring the truth to light. Whatever the consequences with any of this, I know I have done all in my power to be on the right side of justice, honesty and truth. I love you. | JH depo vol. 01 pg 123/124 | email read out only --------------- "both" = VJ & James Franco |
| Date/Time | from | to | email / Subject: Depp V. Heard - More Recent ACLU Subpoena | doc | notes |
|---|---|---|---|---|---|
2020-11-02 time unknown | Craig Mariam | Elaine Bredehoft Ben Wizner (ACLU) & others | I'm sure you saw the reference to charity and the gold digger issue. | TD depo pg 382/383 | email read out only --------------- Craig Mariam = one of Amber Heard's attorneys |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2020-12-07 time unknown | Tatiana Siegel (THR) | Robin Baum Simon Halls? | I am writing a cover story on Johnny Depp for this week's magazine and I include part of the text exchange between Depp and Bethany about burning Amber Heard. ("Bettany" was misspelled as "Bethany" in the email) | RB depo pg 186-188 | email read out only |
2020-12-07 time unknown | Robin Baum | Simon Halls | Are you ignoring? | RB depo pg 186-188 | email read out only |
2020-12-07 time unknown | Simon Halls | Robin Baum | Yes. | RB depo pg 186-188 | email read out only |
2020-12-07 time unknown | Robin Baum | Simon Halls | (says that she didn't engage) The lawyers asked me not to. | RB depo pg 186-188 | email read out only |
2021
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2021-01-07 time unknown | Leanne Gutierrez (E! News) | Robin Baum | I wanted to reach out as we saw the Daily Mail is reporting that Johnny Depp has accused Amber Heard of pocketing the 7 million settlement from their divorce and repeatedly lying about giving it all to charity. | RB depo pg 191/192 | email read out only |
| Date/Time | from | to | email / Subject: unknown | doc | notes |
|---|---|---|---|---|---|
2021-01-08 01:07 pm | Jennifer Howell | Anthony Romero | partially read out only (second-to-last paragraph): No matter what our needs are, our moral obligation is to tell the truth at all costs, especially when subpoenaed by a court of law to do so. | JH depo vol. 02 pg 332, 334 | email read out only |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2021-01-14 | Exh 67 "Vanguard Anonymous Donor $500,000 Grant Notification" re privileged email sent by Elizabeth Bradford to Elaine Bredehoft on January 14, 2021 with various non-privileged documents attached | TD depo pg 218/219, 226/227, 229, 234 | partially transcribed |
| Date/Time | from | to | email / Subject: ACLU Document Production | doc | notes |
|---|---|---|---|---|---|
2021-02-25 time unknown | Michelle Bredehoft | Elizabeth Bradford (ACLU) Stephanie Teplin (Patterson Belknap) Ben Wizner (ACLU) | (sending a share file link containing the document production about communications between Amber Heard and the ACLU) | TD depo pg 387-391 | email read out only --------------- Michelle Bredehoft = paralegal at Elaine Bredehoft's firm |
2021-02-25 time unknown | Michelle Bredehoft | Elizabeth Bradford (ACLU) Stephanie Teplin (Patterson Belknap) Ben Wizner (ACLU) | I'm attaching the interrogatory responses we discussed. | TD depo pg 387-391 | email read out only |
| Date/Time | from | to | email / Subject: Mera | doc | notes |
|---|---|---|---|---|---|
2021-02-25/26 time unknown | Warren Zavala | Amber Heard | I spoke with Toby Emmerich and Walter Hamada today. They are saying if Aquaman happens with Jason Momoa and James Wan, they guarantee that you will be playing Mera. | WH depo pg 89 | email read out only --------------- BN WME_740 (Def1302) |
| Date | unable to properly transcribe / info | doc | notes |
|---|---|---|---|
2021-05-20 | Exh 71 "5/20/21 E-Mail, 'Re: Confidential: Heard V Depp'" | TD depo pg 392-398 | if you're willing & able to transcribe this exhibit, please let me know |