Clerk stamps date here when form is filed. Notice of Court Hearing 6) Name of Person Asking for Order: FELEU Superior (loud of California AMBER LAURA r)an Wm" Oil-C's Angeles Your lawyer in this case if you have one): i; Namezsamau?lHALSEEQEQE?State Bar No.: REHABL- MAY 27 2816 Firm Name: SPECTOR T-AW A LAW CORPORATTON 1 'eeuliue OilicerlClerlt Address (If you have a lawyer for this case, give your lawyer's Sherri epuw information. If you do not have a lawyer and want to keep your home Bil 69mm Ga mam address private, give a di?erenr mailing address instead. You do not Fill in court name and street address: have to give your telephone, fax, or Superior Court of California, County of LOS ANGELES Address: L925- EAST, BUTTE C. I . 111 NORTH HILL STREET 11y. LDS ANGELES State: CA ZIP. 341.051? 1 11 NORTH HILL STREET Telephone: _Lll qq? pp PT NL LOS ANGELES, CA 90012 - CENTRAL G) Name of Person to Be Restrained: Clerk fills in case number when form is filed. J_le_p 1 r1 "1 Ft - - 3mm: 12 BEE: Case Number: ED 641 052 The court will fill out the rest of this form. Notice of Court Hearing A court hearing is scheduled on the request for restraining orders against the person in . . - - Name and address of court if different from-above:- j, . Heurng Date: Time: '3 0 fi" Wk? Date Dept: Room: if (9 Temporary Restraining Orders (any orders granted are attached on Form DV-110) a. Temporary restraining orders for personal conduct, stay away, and protection of animals, as requested in Form Request for Domestic Violence Restraining Order, are: granted until the court hearing (2) All denied until the court hearing (specify reasonsfor tier-rial in (3) Partly granted and partly denied until the court hearing (specify reasons for denial in b. Requested temporary restraining orders for personal conduct, stay away, and protection of animals are denied because: (1) facts as stated in form DV-100 do not show reasonable proof of a past act or acts of abuse. (Family Code, 6320 and 6320.5) (2) DThe facts do not describe in sufficient detail the most recent incidents of abuse, such as what happened, the dates, who did what to whom, or any injuries or history of abuse. (3) MFurther explanation of reason for denial, or reason not listed above: rhaL/W?g. AHQ pin-r64)? pfl? Chg. This is a Court Order. Councll o! Caliiornia. mewxuu?smagov Notice 0f Court Hearing DV-109, Page(Domestic Violence Prevention) r. - turns" Case Number: ED 641 052 At least ?ve or Cl days before the hearing, someone age 18 or older?not you or anyone else to be protect nust personall ive (serve) a court?s file-stamped cepy of this form Notice of Court Hearing) to the person in @along with a copy of all the forms indicated below: 3. Porn Request?n' Domestic Violence Restraining (Jr-tier, (file-stamped) with applicable attachments d1. Service of Documents and Time for Service?tor Person in (D b. "orm l0, Restraining Order (file?stamped) with applicable. attachments if granted by the judge c. Form DV-120, Response to Request for Domestic Violence Restraining Order (blank form) d. Form Proof of Service by Mail (blank form) e. Other (specycy): a Date: i??l Judicial O?icer (mm 5.5, moan Iz?? rI - a 2.: . aster-we? .. . H.932 Intetmaiion for the Person - If item or G) is checked, the judge has denied some or all of the temporary orders you requested until the court hearing. The judge may make the orders you want after the court hearing. You can keep the hearing date, or you can cancel your request for orders so there is no court hearing. - If you want to cancel the hearing, use Form Waiver of Hearing on Denied Request for Temporary Restraining Order. Fill it out and file it with the court as soon as possible. You may file a new request for orders, on the same or different facts, at a later time. - If you cancel the hearing, do not serve the documents listed in item?on the other person. - - If you want to keep the hearing date, you must have all of the documents listed in item? servod on the other person within the time listed in item - At the hearing, the judge will consider whether denial of any requested orders will jeopardize your safety and the safety of children for whom you are requesting custody or visitation. - You must come to the hearing if you want the judge to make restraining orders or continue any orders already made. If you cancel the hearing or do not come to the hearing, any restraining orders made on Form 10 will end on the date of the hearing. To, the Person, in The court cannot make the restraining orders after the court hearing unless the person in @has been personally given (served) a c0py of your request and any temporary orders. To show that the person in has been served, the person who served the forms must fill out a proof of service form. Form DV-ZOO, Proof of Personal Service may be used. - For information about service, read Form What Is ?Proof of Personal Service? 7 - If you are unable to serve the person in in time, you may ask for more time to serve the documents. Read Form IS-INFO, How to Ask for a New Hearing Date. This is a Court Order. . Notice of Court Hearing ov-109, Page 2 of3 tsgr'??'n?ni?RMs'm (Domestic Violence Prevention) Fievisad January 1, 2012 Case Number: ED 641 052 regains.Rename. - If you want to respond in writing, mail a copy of your completed Form DV-IZO, Response to Request for Domestic Violence Restraining Order, to the person in? and file it with the court. You cannot mail Form yourself. Someone age 18 or older?not you?must do it. To show that the person in has been sewed by mail, the person who mailed the forms must fill out a proof of service form. Form DV-ZSO, ProofofService by Mail, may be used. File the completed form with the court before the hearing and bring it with you to the hearing. For information about responding to a restraining order and filing your answer, read Form How Can I Respond to a Request for Domestic Violence Restraining Order?. - Whether or not you respond in writing, go to the court hearing if you want the judge to hear from you before making orders. You may tell the judge why you agree or disagree with the orders requested. You may bring witnesses and other evidence. - At the hearing, the judge may make restraining orders against you that could last up to five years. - The judge may also make other orders about your children, child support, spousal support, money, and property and may order you to turn in or sell any firearms that you own or possess. Request for Accommodations Assistive listening systems, computer?assisted real?time captioning, or sign language interpreter services are available if you ask at least five days before the hearing. Contact the clerk?s office or go to courts. ca. gov/forms for Request for Accommodations by Persons With Disabilities and Response (Form (Civil Code, 54.8.) (Clerk will?ll out this part.) fig? ?Clerk?s Certificate? . I certify that this Notice of Court Hearing is a true and correct copy of the original on file roll, I in the court. Er I it?11; Date: Clerk, - Deputy 1.. man? 4..- unlhm?ww,? Gestelle Gammage This is a Court Order. ?maimfwl'zmz Notice of Court Hearing - - . BSENHM (Domestic Violence Prevention) DV-109, Page 3 of 3 Clerk stamps date here when form is filed. Temporary Restraining Order FELED 'or Good of California Person in @mnst complete items (D and only. Sugg?my of LOB Angeies Q) Name of Protected Person: AMBER LAURA DEPP MM 2 7 Z?l? Your lawyer in this case (if you have one): if- - egullue O?icerlCIEltk Sherri Name: SAMANTHA E. State Bar No; 33. Firm Name: WW Gestelie Ga mags Address If you here a lawyer for this case, give your lawyer?s information. If you do not have a lawyer and want to keep your home address private, give a di?cerent mailing address instead. You do not Fill in court name and street address: Superior Court of California, County of have to give your telephone, fax, or LES ANGELES . 1 NORTH HILL STREET Address. 9 2 '3 CENTURY PARK EAST. 111 NORTH HILL STREET City: LOS State: CA Zip: 9.0.0.63? LOS ANGELES CA 9 0 0 12 Telephone: (310)282-9478 CENTRAL E?mail Address: COM Court fills in case number when form is tiled. . Case Number: Name of Restrained Person. ED 641 052 JOHNNY DFIPP) Description of restrained person: Sex: CI Weight: 111? Hair Race: Age: 52?? Date of Birth: -6 Address (if known): City: State: Zip: Relationship to protected person: HUSBAND Additional Protected Persons In addition to the person named in CD, the following persons are protected by temporary orders as indicated in items and G) family or household members): Full name Relationship to person in Sex Age CI Check here if there are additional protected persons. List them on an attached sheet of paper and write 10, Additional Protected Persons? as a title. The court will complete the rest of this form. Court Hearing This order expires at the end of the hearing stated below: Hearing Date: $0 i 6 Time: 8: 30 dam. CI pm. This is a Court Order. dialing??'tihi'h'ishlm?sm?9'? Temporary Restraining Order DV-110, Pagel ofB Family Code. 6201] Eileen. 9 Approuadby OJ c. - . ?ft [55mm ?mm-u (Domestic Violence Preventlon) Case Number: ED 641 052 (5) fl Criminal Protecflve Order a. DA criminal older on Form CRVIGO, Criminal PmIeclive Ol'drsr--Domenir ls ln effecL Case Nurnlrer, Ceunry: Explr-arlon Dale: 1). lnformalinn Ius been plowde the Judge about a ploIECfiVc nrder To eperson In 0 Tha court has granted the temporary orders checked below. yIJu do not obey these urders, you can be arrested and charged a crime. You may be sent to jail rur up to one year. pay a fine of up to $1,000, or both. 63) Personal Conduct Orders requested DDenicd until the hearing (jut-aura as follows: a. You musr up: do rlre following things tn the person in(R)and Clpersons ln El Harass, altack. rlu-eslen, assaulr (sexually or Ufllel'wise), hit, tolluw, sralk, rnolesr, desuuy personal plupeny' dislutb the peace, keep under surveillance, impersonate {an rhe lnrmer, electronically or when wire), or block movements Bf Contact, cirhcr direerly or indirectly, rn any way, illcludlng bu| not lirnned re, by telephone, marl, er other electronic means I: Take any action, drreerly at through others, to oblain the addresses or uf rhe persons ln (C) and (C) . rhr's "am i: nel checked, the noun rim/014m! good came not {a mllke this finial b. written eenteer rhrough a lawyer nr process server or anorher persnn f0l service of Farm DVVIZO (Response to Requeslfor Danreslzc Violence Order) or nrher legal papers relered |o a court case ls allowcd and dues nor vlolare rlus order. e. Exceptions: Eliefand peaceful contact with rhe person rn (R) and peaceful Contact in @e as required for courtrol'deltd visitation nf ls allowed unless a prnreeuve erder says erherwrse. (R) Stay-Away Order C]an requested a Denied until the nearlng El/Granred as follows: a, Yuu musl slay at least (specify); 7% yards away from (check all apply)' The pelsoll in (D School orpersou ln(R) CI The persons in CI The school or eare Home of pcrson in (R) Other {:petify): Elere or workplace of person in (R) [2(Venlcle of person ln(R) b. El Exceprlens: Brlef and peaceful conracr with rhe person in Q, and peaceful conraet children ln@. as required for counrordexcd visitaliuu e! children. is allowed unless a criminal protecrive urdcr says otherwise Move-Out Order requested DDenled until the hearlng El/Granled as follows: You must la drately fml-n (nddresr): Th 5 a Court Order. Order "410. Pam (C - Vlolence Prevention) Case Number ED 541 2 G) No Guns or Other Firearms or Ammunition a, You cannot own. possess, have, buy or try to buy, receive or try to receive, or in any ether way get guns. ether firearms. or ammunition, b. You must . Sell to, at store With, a licensed gull denier, or turn in tn .1 law enhneement agency, any guns or other within your immedlal: possession 01 control, Du so wllhin 24 hours of being served this order, . within 43 hours this order, file With the court is receipt that proves gum have heen turned in, stored, or sold. (You mxy use Form DV-800,Pn7t1fofFirenvm: Turned 171, Sold, or Sic/rad, tor the receipt) Bring a eeuri tiled ehpy to the heating. e. L3 The court has received information that you own nr iirearm Record Unlawful Communications Cl Not requested Cl Denied until the hearing dammed as follows: The person in @eun record eurnmunieatiens made by you that Violate the judge's ol'dcls (R) Care at Animals requested m'Denicd until the hearing Cl Granted us follaws: The person in(R)is given the sole possession, care, and control of the animals listed below The person in (R) must stay at least 7 yards away train and not lake, sell, transfer, eneumher, concealv molest, attack. strike, threaten, harm. m' uihclwisc dispuse of the following animals: Custody and EfNol requested CIDenied until the hearing \j Granted as Child custody and visilutiun are ordered on the attached Form Child Custody and Visitation Order or (specify otherform) The parent with lampomry cuslody of the child must not remuve the child from California unless the court allows il after a noticed heanng (Fzml Code, 3053). Child support Nat oxdel'ed now but may b: mdered after a noticed hearing Property Control :1 Nut requested Denied until the hearing EfGranlcd as intinws: Until heann 0711 [he i: on in can us central. and assess the following perly Debi Payment R1 Not requested Cl Denied until the hearing El Granted as follows: The person in (R) must make these until this order ends: Pay te: Fm Amount: 3 Due date: Pay to: For: Amount- 3 Due date: Order. "1w Tamporar Restraining Order Irv-nu, Faun l. imitate. 7 El Tao) (Domestic Vlulence Prevention) Case NumberProperty Restraint CI Not requested CI Denied until the hearing [ZfGranted as follows: If the people in and 2 are married to each other or are registered domestic partners, EE/lhe person in G) the person in must not transfer, borrow against, sell, hide, or get rid of or destroy any property, including animals, except in the usual course of business or for necessities of life. In addition, each person must notify the other of any new or big expenses and explain them to the court. (The person in cannot contact the person in G) if the court has made a ?no Contact? order.) Peaceful written contact through a lawyer or a process server or other person for service of legal papers related to a court case is allowed and does not violate this order. Spousal Support Not ordered now but may be ordered after a noticed hearing. 9 Insurance person in Eithe person in is ordered NOT to cash, borrow against, cancel, transfer, dispose of, or change the beneficiaries of any insurance or covorage held for the benefit of the parties, or their child(ren), if any, for whom support may be ordered, or both. Lawyer?s Fees and Costs Not ordered now but may be ordered after a noticed hearing. Payments for Costs and Services Not ordered now but may be ordered after a noticed hearing. Batterer Intervention Program Not ordered now but may be ordered after a noticed hearing. Other Orders DNot requested EfDenied until the hearing CI Granted as follows: iq?j't' Mirror?an l? Check here if there are additional orders. List them on an attached sheet of paper and write 10, Other Orders" as a title. No Fee to Serve (Notify) Restrained Person If the sheriff serves this order, he or she will do so for free. mot/rm ac MAY 7 7 Judge (or Judicial Ojjicer) (EARL H. M003 Warnings, and Notices to the Restrained Person in 9 If you do not obey this order, you can be arrested and charged with a crime. - If you do not obey this order, you can go to jail or prison and/or pay a fine. - It is a felony to take or hide a child in violation of this order. - If you travel to another state or to tribal lands or make the protected person do so, with the intention of disobeying this order, you can be charged with a federal crime. This is a Court Order. Temporary- Restraining Order DV-110, Page4o ?in (Domestic Violence Prevention) Revised July 1. 2014 CaseNumber: ED 641 052 You cannot have guns, firearms, and/or ammunition. You cannot own, have, possess, buy or try to buy, receive or try to receive, or otherwise get guns, other firearms, and/or ammunition while the order is in effectjail and pay a $1,000 fine. You must sell to or store with a licensed gun dealer or turn in to a law enforcement agency any guns or other firearms that you have or control. The judge will ask you for proof that you did so. If you do not obey this order, you can be charged with a crime. Federal law says you cannot have guns or ammunition while the order is in effect. Service of Order by Mail If the judge makes a restraining order at the hearing, which has the same orders as in this form, you will get a copy of that order by mail at your last known address, which is written in If this address is incorrect, or to find out if the orders were made permanent, contact the court. Child Custody, Visitation, and Support 0 Child custody and visitationthe hearing, the judge can make custody and visitation orders for your children without hearing from you. in Child support: The judge can order child support based on the income of both parents. The judge can also have that support taken directly from a parent's paycheck. Child support can be a lot of money, and usually you have to pay until the child is age 18. File and serve a Financial Statement (Simpli?ed) (Form or an Income and Expense Declaration (Form if you want the judge to have information about your finances. Otherwise, the court may make support orders without hearing from you. Spousal support: File and serve an Income and Expense Declaration (Form so the judge will have information about your finances. Otherwise, the court may make support orders without hearing from you. "instructions for Law Enforcement This order is effective when made. It is enforceable by any law enforcement agency that has received the order, is shown a copy of the order, or has verified its existence on the California Law Enforcement Telecommunications System (CLETS). If the law enforcement agency has not received proof of service on the restrained person, and the restrained person was not present at the court hearing, the agency shall advise the restrained person of the terms of the order and then shall enforce it. Violations of this order are subject to criminal penalties. Arrest Required if Order ls Violated If an officer has probable cause to believe that the restrained person had notice of the order and has disobeyed the order, the officer must arrest the restrained person. (Penal Code, 836(c)(1), 1370103).) A violation of the order may be a violation of Penal Code section 166 or 273.6. lithe Protected Person Contacts the Restrained Person Even if the protected person invites or consents to contact with the restrained person, the orders remain in effect and must be enforced. The protected person cannot be arrested for inviting or consenting to contact with the restrained person. The orders can be changed only by another court order. (Pen. Code, This is a Court Order. Temporary Restraining Order DV-110, Page5 Drive. 7? ESSENTIAL illFiMS (Domestic Violence Prevention) Revised July 1. 2014 Case Number: ED 641 052 Conflicting Orders?Priorities for Enforcement If more than one restraining order has been issued protecting the protected person from the restrained person, the orders must be enforced according to the following priorities (see Pen. Code, 136.2, and Fam. Code, 6383(h), 6405(b)): 1. EPO: If one of the orders is an Emergency Protective Order (Form and it is more restrictive than other restraining or protective orders. it has precedence in enforcement over all other orders. 2. No-Contact Order: If there is no EPO. a no-contact order that is included in a restraining or protective order has precedence in enforcement over any other restraining or protective order. 3. Criminal Order: If none of the orders includes a no-contact order, a domestic violence protective order issued in a criminal case takes precedence in enforcement over any conflicting civil court order. Any nonconllicting terms of the civil restraining order remain in effect and enforceable. 4. Family, Juvenile, or Civil Order: If more than one family, juvenile, or other civil restraining or protective order has been issued, the one that was issued last must be enforced. Child Custody and Visitation 0 The custody and visitation orders are on Form items@ and They are sometimes also written on additional pages or referenced in DV-14O or other orders that are not part of the restraining order. 0 Forms and are not orders. Do not enforce them. Certificate of Compliance With VAWA This temporary protective order meets all ?full faith and credit? requirements of the Violence Against Women Act, 18 U.S.C. 2265 (1994) (VAWA) upon notice of the restrained person. This court has jurisdiction over the parties and the subject matter; the restrained person has been or will be afforded notice and a timely opportunity to be heard as provided by the laws of this jurisdiction. This order is valid and entitled to enforcement in each jurisdiction throughout the 50 states of the United States, the District of Columbia, all tribal lands, and all US. territories, commonwealths, and possessions and shall be enforced as if it were an order of that jurisdiction. (Clerk willfill out this part.) 1.. -C erk's Certificate- 1- all," i, I certify that this Temporary Restraining Order is a true and correct copy of the loci original on file in the court. 6:5" is Date: br Gestelie Gammage This is a Court Order. Hevisechl'?liig?rti Tempora?KETassg?ggling Order DV-110, Page 6 of 6 2? armature" (Domestic Violence Prevention) Laura A. Wasser, Esq. (SBN 173740) Samantha Klein, Esq. (SBN 222414) Lisa P. Sutton, Esq. (SBN 276183) WASSER, COOPERMAN MANDLES, RC. 2049 Century Park East, Suite 800 Los Angeles, California 90067-3110 Telephone No.: (310) 277-7117 Facsimile No.: (310) 553-1793 Attorneys for Respondent $515.: Superior Court of C?llf?mla Cnumy of Los Angeles NM 2 Ema mm: inn. unal'y?g??Cl?'k SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES In re the Marriage of Petitioner: AMBER LAURA DEPP and JOHN CHRISTOPHER DEPP II (AKA JOHNNY DEPP) Respondent: IN CASE NO. BD641052 [Assigned to Dept. 6, Hon. Carl H. Moor] OPPOSITION TO PETITIONER, AMBER LAURA EX PARTE AND DECLARATION OF LAURA A. WASSER, ESQ. Date: May 27, 2016 Dept: 6 Time: 8:30 A.M. -1- .nn. . run urn-'1 nun? Tn DY A A DDI Ir? ATION MEMORANDUM OF POINTS AND AUTHORITIES Respondent, John Christopher Depp II (hereinafter ohnny?) submits the within Memorandum of Points and Authorities in opposition to the ex parte application noticed by Petitioner, Amber Laura Depp (hereinafter ?Amber?) for hearing on May 27, 2016. I. INTRODUCTION Ex parte applications are restricted for emergency situations where substantial injury, harm, or, at the very least, prejudice, would result if the matter were not either resolved immediately or on shortened time. Amber is nonetheless seeking ex parte relief for several matters which do not constitute an emergency, including the payment of spousal support and attorneys? fees. Not only are such matters devoid of any exigency, but they are also wildly premature. This case commenced this week. Amber ?led her Petition for Dissolution of Marriage this Monday, May 23, 2016. Johnny ?led his Response and Request for Dissolution of Marriage two days later, on May 25, 2016. No discovery has been conducted. The parties have not yet had an opportunity to even informally exchange information. The Court therefore has no ?nancial information upon which to make the ?nancial orders requested at this time. Moreover, Amber is a successful model and actress who earns her own income and is capable of supporting herself. Although Amber is entitled to seek support, fees, and property orders, Johnny is likewise entitled to reasonable time to prepare his response. Amber is attempting to secure a premature ?nancial resolution by alleging abuse. Her current application for a temporary restraining order along with her ?nancial requests appears to be in response to the negative media attention she received earlier this week after ?ling for divorce. Both Amber and Johnny are successful actors. Amber ?led her Petition three days after the death of Johnny?s mother. There has been signi?cant commentary in the media as to this timing given that Johnny was very close to his mother. Yet Johnny cannot protect himself or Amber from media scrutiny, and Amber?s anger certainly cannot drive this dissolution proceeding. The actual issues in this case should be handled through properly noticed Requests for Orders and settlement efforts. The issues are limited as the parties were married for little more than one -2- run WV a. year and have no children together. These issues can and will be resolved. Further, Johnny is willing to stipulate to mutual stay-away and personal conduct orders even though he and Amber are currently on different continents, as Amber is aware. There is therefore no basis, in law or in fact, upon which to issue the orders Amber seeks at this time. II. AS A MATTER OF LAW, THE MAJORITY OF THE RELIEF REQUESTED CANNOT BE ORDERED ON AN EX PARTE BASIS Due process requires reasonable notice and an opportunity to be heard. Accordingly, ex parte orders are issued with extreme caution and only under extraordinary circumstances. California Rules of Court, Rule 3.1202(0) requires that an ex parte applicant ?make an af?rmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief exparte.? Amber cannot make such an af?rmative showing because there is no risk of irreparable harm or immediate danger upon which to grant the majority of the relief she requests. The majority of the relief she requests is purely ?nancial in nature. Amber is seeking payments for spousal support, attorneys? fees, and accounting fees as well as the exclusive use and possession of particular real and personal property owned by the parties. Neither the parties nor this Court has ?nancial information upon which to grant such relief as this case commenced only four days ago. Moreover, as a successful actress with signi?cant income of her own, there is no question that Amber can support herself until the parties have had a reasonable amount of time to assess their ?nances with the assistance of counsel and then negotiate a mutually agreeable resolution or seek regularly-noticed court orders. ANY ISSUES FOR WHICH EX PARTE RELIEF MAY BE AVAILABLE HAVE ALREADY BEEN RESOLVED In addition to her numerous ?nancial requests, Amber has also requested a temporary restraining order against Johnny. Johnny is currently out of the country for work. He is unable to attend the hearing on this matter and has not heard Amber?s speci?c allegations against him. He - . n-nvhn-n A ?min I run? in nonetheless has every intention of staying away from Amber and will stipulate to mutual stay-away and personal conduct orders. IV. CONCLUSION For all of the foregoing reasons, Johnny respectfully requests that Amber?s ex parte application be denied in its entirety. DATED: May 26, 2016 By: Respectfully submitted, WASSER, COOPERMAN MANDLES A Professional Corporation LMJRA A. WASSER, ESQ. Attorneys for Respondent -4. Tn APPI ?DECLARATION OF LAURA A. WASSER. ESQ. 1, Laura A. Wasser, hereby declare as follows: 1. I am an attorney at law duly licensed to practice before all courts of the State of California, and am a partner in the ?rm of Wasser, Cooperman Mandles, P.C., attorneys of record for Respondent, John Christopher Depp II (hereinafter ohnny?) herein. I have personal knowledge of the following facts, and if called as a witness, I could and would competently testify thereto. 2. My of?ce was retained by Johnny this month. On Monday, May 23, 2016, Petitioner, Amber Laura Depp (hereinafter ?Amber?) ?led a Petition for Dissolution of Marriage. A copy of the Petition was provided to Jake Bloom, Johnny?s entertainment lawyer, on Tuesday, May 24, 2016. 3. My of?ce ?led a Response and Request for Dissolution of Marriage on Johnny?s behalf on Wednesday, May 25, 2016, after advising Amber?s counsel that we would be doing so. Later that same day, I became aware of several reports in the media questioning the timing of Amber?s ?ling for divorce given the death of Johnny?s mother only three days earlier. 4. On Thursday, May 26, 2016, I received ex parte notice from Amber?s counsel for a hearing the following day. The notice indicated that Amber would seek a temporary restraining order and property control orders as well as payments for spousal support, attorneys? fees, and accounting fees. 5. It is my understanding that Johnny is currently out of the country working in Spain for the next several weeks and will not return before June 7, 2016, at the earliest. My of?ce informed Amber?s counsel, prior to the ex parte notice, that Johnny was out of the country. My of?ce communicated with Amber?s counsel by telephone and email throughout the day on May 26 in an effort to resolve these matters. 6. My of?ce has not yet had an opportunity to assess the parties? ?nances. Neither party has served a Preliminary Declaration of Disclosure and no discovery has been conducted. My of?ce has already begun working with Johnny?s business managers and accountants in order to obtain the necessary ?nancial information. We informed Amber?s counsel on several occasions this week that we would share ?nancial information with them and seek to answer any questions they might have. -1- ?writ our A WARRFI addition, my of?ce offered Amber?s counsel the Opportunity to Speak with Johnny?s business managers on May 26 or thereafter at her convenience, so that she might begin to understand the ?nancial circumstances of this matter. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 26?1? day of May, 2016, at Los Angeles, Cali nia. LAURA A. WASSER ?rant Ln sminnr n?ni 111111 A EAST, SUITE 200 LOS ANGELES, CA SAMANTHA F. SPECTOR, ESQ. (State Bar 204482) SPECTOR LAW, A Professional Law Corporation 1925 Century Park East, Suite 200 Los Angeles, California 90067 Telephone: 310.282.9478 Facsimile: 310.220.3889 EILED Superior Court at Califnmla Cnunry oi Lag Anselm MAY 2? H3153 Sherri R, I I Ian-r" Ia. Attorneys for Petitioner, 3, lerk AMBER LAURA DEPP SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES In re the Marriage of: CASE NO. BD 641 052 Petitioner: AMBER LAURA DEPP, Judge: Hon. Carl H. Moor Department: 6 and DECLARATION OF SAMANTHA F. SPECTOR, ESQ. RE EX PARTE NOTICE AND IN SUPPORT OF PETITIONER AMBER LAURA DVRO REQUEST- Respondent: JOHN CHRISTOPHER DEPP II (AKA JOHNNY DEPP) Date: May 27, 2016 Time: 8:30 am. Dept: 6 I, SAMANTHA F. SPECTOR, declare as follows: 1. I am an attorney at law duly licensed to practice before all court of the State of California and I am the managing attorney at Specter Law, APLC, attorneys of record for Petitioner, Amber Laura Depp, herein. have firsthand personal knowledge of the facts stated herein and if called as a witness, I could and would competently testify thereto. EX PARTE NOTICE GIVEN 2. On May 26, 2016, at approximately 9:45 am, I telephoned Respondent John Christopher Depp Il's (?Johnny?) counsel, Laura Wasser, Esq. asked to speak to Ms. Wasser and was told she was not available. I then requested to speak to Samantha Klein, Esq., and was also told she was unavailable. I was then directed to voicemails for both; instead I asked to speak Pace 1 EAST, suns zoo LOS ANGELES, CA 90067 to Ms. Wasser's assistant, Linda Bigbee, and was told she too was unavailable and directed to her voicemail. 3. I left a voicemail for Ms. Wasser at 9:45 am. and advised her that Petitioner, Amber Laura Depp ("Amber"), would be appearing ex parte at 8:30 am. on Friday, May 27,2016, in Department 6 ofthe Los Angeles Superior Court located at 111 North Hill Street, Los Angeles, California 90012 on the instant matter. Specifically, I stated that Amber would be requesting a DV CLETS TRO against Respondent John Christopher Depp ll ("Johnny"), including 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. 4. I then sent a follow-up email to Ms. Wasser stating all of the above in writing, and copying Ms. Klein and Ms. Bigbee. A true and correct copy of my email to Ms. Wasser dated May 26, 2016 at 9:52 am, confirming my ex parte notice, is attached hereto as Exhibit 5. Thereafter, at approximately 9:59 am. was able to speak directly to Mrs. Klein and I advised her of all of the above via telephone. ATTEMPTS TO RESOLVE ISSUES PRIOR TO INSTANT EX PARTE AND DVRO REQUEST 6. I attempted to resolve this matter with Johnny?s counsel prior to giving notice for the instant Request for Order re: Domestic Violence Restraining Orders. 7. On May 24, 2016, I sent a letter to Johnny's business attorney, Jacob A. Bloom. I stated that, although Amber had been attacked and remained in fear for her safety, given the notoriety of both parties and the high likelihood of press harassment, Amber would preferto settle the matter amicably out of Court. A true and correct copy of my letter to Mr. Bloom dated May 24, 2016, is attached hereto as Exhibit declare, under penalty of perjury pursuant to the laws of the State of California, that the foregoing is true and correct. Executed this 27'"1 day of May 2016, at L'os Angeles, California. SAMANTHA F. SPECTOR Page 2 Samantha F. Spector From: Samantha F. Spector Sent: Thursday, May 26, 2016 9:52 AM To: Laura Wasser Cc: 'Samantha Klein'; 'Linda Bigbee' Subject: Marriage of Depp EX PARTE NOTICE 5/27/2016 8:30 am Dept 6 LASC 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. lthen 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 Samantha F. Spector, Esq. Partner SPECTOR LAW, A Professional Law Corporation 1925 Century Park East, Suite 200 Los Angeles, California 9006? 310.282.9478 I Office 310.220.3889 I Fax 53'11171? NOTICE: This e?mail (including any files transmitted with it) is being sent by a law firm. It is intended only for the individual or entity to which it is addressed and may contain information that is proprietary, privileged, confidential or otherwise exempt from disclosure under applicable Federal or State Law. If you are not the named addressee or the employee or agent responsible for delivering this e-mail to the named addressee, be advised that you have received this e-mail in error and you are prohibited from any dissemination, distribution or copying of this email. If you have received this e-mail in error, please immediately contact the sender by reply e- mail, telephone, or facsimile. hl'lxs OR l'llil 4 i till ris >l'l,l wl'll May 24, 2015 VIA AND u.s. MAIL Jacob A, aloom, Eso. Bloom hergott Diemer Rosenthal LaVioIette Feldman Schenkman Goodman, LLP 150 South Rodeo Drive, Third Floor Re: In re Marriage 0! D292 Dear Mr. Bloom: Please be advised that our firm has tiled a Petition lor Dissoiution oi Marriage on behait oi Amber Depp, As you may be aware, your them and Amber's husband, Johnny Depo, violently attacked and threatened Amber on Saturday night, May 21", in their penthouse apartment located at 849 5. Broadway, There are several witnesses to this particular incident, and there are photographs depicting the property damage Johnny caused, as well as the physical injuries he inflicted on Amber. Unfortunately, this is not the first incident of domestic violence perpetrated by Johnny against Amber. In fact, there have been two other incidents in the past Although Amber is afraid of Johnny, she strongly insists that we do everything possible to keep this personal matter out ofthe media spotlight, which is why she has not yet sought a CLETS DV TRO and why we did not arrange for Johnny to have been personally served at last night's premiere, Amber wishes to work quickly towards a private and amicable resolution of all matters, but she will need Johnny's immediate cooperation to do so, To this end, please have Johnny sign and return by Friday, May 27,2015, the enclosed Notlce and Acknowledgment or Receipt form (FL-117 lorm) confirming service of the Summons, Petition, Family Law Case Cover Sheet and blank Response (FL-120 form). ll the requested Notice is not signed and the original executed form is not returned to me by May we will have no alternative but to arrange for Johnny to be personally served ln addition, we are requesting on Amber's behalrthe iollowmg: ll) appropriate pendehie lite support; (il) exclusive use and possession oftne black Range Rover, the vehicle she is currently driving, with Johnny to continue to make all payments for any encumbrances thereon; exclusive use and possession of 849 S. Broadway, Penthouse Nos. 1, 3 and 5 with Johnny to continue to pay mortgage, utilities, etc. associated therewith; and (iv) a contribution towards her reasonable and necessary attorney's fees in the amount of $100,000 and $25,000 for forensic accounting costs, to be paid to my firm by close of business (5:00 pm) on May 27, 2016. Further, I believe it would be beneficial for all if this case was assigned to a private retired judicial officer for all purposes. My proposed list of private retired judicial officers is as follows: Hon. Gretchen Taylor, Hon. Robert Schneider or Hon. Melinda Johnson. The fees of the judicial officer can be paid with funds from the parties? community estate. Kindly let me know at your earliest convenience if you and your client are agreeable to doing so as well as which judicial officers are acceptable. Upon hearing from you, I will have my assistant obtain rates and availabilities. We are indeed hopeful that we can swiftly work out mutually acceptable short and long term solutions outside of the public eye. Thank you. I look forward to your prompt follow up and reply. VERY TRULY YOURS, SPECTOR LAW, APLC F. SPECTOR Enclosures cc: Client Violence Restraining Order i . Clerk stamps data here when form is filed. Request for Domestic You must also com lete Form 151001, Con?dential CLETS Information, and give it to the erlc when you?le this Request. . 6) Name of Person Asking for Protection: AMBER LAURA DEPP Your lawyer in this case (if you have one): Name: Firm Name: WW Address (Hyatt ho vs a lawyer for this case. rive yo or lawyer 's inforttraiion. you do not have a lawyer one want to tree your home address private. give a different mailing address instea . You do not have to give your telephone, for, or email): Address: 1925 CENTURY PARK EAST, City: State: Telephone: Fax: 31 0) E?Mail Address: SS [3 RM Name of Person You Want Protection From: DEPP, Description of person you want protection from: EILEQ Superior Court of California County of Les Angeles MAY 2% E?l? Sherri R. "soul. but; 1m. dinner/Clerk B), . Fill in court name and street address: Agez30 SAMANTHA Spartan, aso State Bar No.2 Superior Court of California, County of 111 NORTH HILL STREET 111 NORTH HILL STREET LOS ANGELES, CA 90012 CENTRAL SUEDE 900 Zip: 770?3889 Court fills in case number when form is filed. Case Number: ED 641 052 TT [Filth JOHNNY have} Sex: [8 Height: Weight: Hair Color: Color: Eman_ Race: Wh it Age: 52? Date of Birth: Address (if known): City: State: Zip: Do you want an order to protect family or household members? El Yes ENC If yes, list them: Full Name SEQ Age Lives with you? Relationship Check here if you need more space. Attach a sheet of paper and write V-J 00, Protected People ?for a title. Judiclal Council at California, Flavlseo July 1 2014, Mandatory Fortr- Famin Coda oi seq What is your relationship to the person in (Check all that apply): El We are now married or registered domestic partners. We used to be married or registered domestic partners. El We live together. CI We used to live together. CI We are related by blood, marriage, or adoption (specify relationship): CI We are dating or used to date, or we are or used to be engaged to be married. CI We are the parents together of a child or children under 18: [f you do not have one of these relationships, the court may not be able to consider your request. Read 0 for help. Child?s Name: Date of Birth: Child?s Name: Date of Birth: Child?s Name: Date of Birth: CI Check here if you need more space. Attach a sheet of paper and Write Protected People for a tit e. We have signed a Voluntary Declaration oi?iJaterni for our child or children. (Attach a capy if you have one). This is not a Court Order. Request for Domestic Violence Restraining Order DV-100, Page 1 of5 (Domestic Violence Prevention) '9 l'mlu'i [mums [shim- DRDD i, ease mbar: ED 61:1 052 (R) other Court Cases 2. Have you or any other person named in (3 been involved in another court case with the person in No in Yes l/yes, check each kind o/coso and indicate where and when each wosfilcd: Killd olese chuuty or Trihemere Filed Year Filed gnse Number Divorce, Nulhty. Legal separation use 7 2L m--Ln :1 civil Harassment a Domestic Violence Criminal a Juvenile, Dependency, Guardianship Child Support Parentage, Potemity Other wreck here lfyou need mare spore. Allach sneer o/poper and wrl'le ether Court Cases "for til 2. Are there any domestic violence restraininyprolective orders now (criminal, juvenile, family)? ix: No Yes Ifyes. otloch acopy lfyalt have one. Check the orders you want. (6) Persanal Conduct Orders I ask the coun to order the person in (9 not to do the following lhings to me or anyone listed in u, ix] Hornss, attack, strike. threaten, assault (sexually or otherwise), hit, follow, stalk, molest, destroy personal properly, disturb the peace, keep under surveillance, impersonate (on the Internet, electronically or otherwise), or block movements b. Contact, either directly or indirectly, in any way, including hut not limited to, by telephone, mail or e-mail or other electronic means The person (9 will be mdered not to lake any notion to gel the addresses or locations o/onyprotoctcd person unless the courlfirlds gaad cause not to make the order. Stay-Away Order u, [ask the court to order the person in @to stay nt lesst yards away from (checkall that apply). in Me My vehicle My home :1 The school or child care My job or workplace :1 Each person listed in (R) a My school Other (specifll) W77, ,7 7 b. lithe person listed in (R) is ordered to slay away from all the places listed above, will he or she still he ahle to get to his or her home, school, job, workplace, or vehtoiel Ewes No (Ifno, explain)- Move-Out Order medlulyl 20" Wl [llmul [Mur- (lflhe person in (R) lives with you and you wont [hat person to slay owny/rorn your horns, yuu must halt/or lhis moverour order. I have the right to live at the shove address hecnuse (explai nota Court Orde Request for Dames Violence Restraining Order (Domestic iolenoa Preventionl marlra] r? idpn DV-1DD, P39: 2 or 5 'i x. Case Number: ED 641 052 Guns or Other Firearms and Ammunition I believe the person in owns or possesses guns, ?rearms, or ammunition. LII Yes DNO KI I don?t know If the judge approves the order, the person in will be ordered not to own, possess, purchase or receive a ?rearm or ammunition. The person will be ordered to sell to, or store with, a licensed gun dealer, or turn in to law enforcement, any guns or ?rearms that he or she owns or possesses. 0 Record Unlawful Communications I ask for the right to record communications made to me by the person in that violate the judge?s orders. El Care of Animals 1 ask for the sole possession, care, and control of the animals listed below. I ask the court to order the person in Q) to stay at least LIL yards away from and not take, sell, transfer, encumber, conceal, molest, attack, strike, threaten, harm, or otherwise dispose of the following animals: Pistoi, Yorkshire Terrier I ask for the animals to be with me because: Tr i 8 my pet Child Custody and Visitation a. I do not have a child custody or visitation order and I want one. b. CI I have a child custody or visitation order and I want it changed. If you ask for orders, you must ?ll out and attach Form DV-105, Request for Child Custody and Visitation Orders. You and the other parent may tell the court that you want to be legal parents of the children (use Form DV-180, Agreement and Judgment of Parentage). CI Child Support (Check all that apply): a. I do not have a child support order and I want one. b. I have a child support order and I want it changed. 0. I: I now receive or have applied for TANF, Welfare, or Medi-Cal. If you ask for child support orders, you must ?ll out and attach Form FL-150, Income and Expense Declaration or Form FL-J 5 5, Financial Statement (Simpli?ed). El Property Control I ask the court to give only me temporary use, possession, and control of the property listed here: Real 3; located Fli' Fit! Li Ernst?twig ?irt-inns, Lois tinge] as, (?It Cifl?l 11 Debt Payment I ask the court to order the person in to make these payments while the order is in effect: Check here if you need more space. Attach a sheet of paper and write Debt Payment? for a title. Pay to: __For: Amount: 55 __?Due date: a El Property Restraint I am married to or have a registered domestic partnership with the person in C2) . I ask the judge to order that the person in not borrow against, sell, hide, or get rid of or destroy any possessions or property, except in the usual course of business or for necessities of life. I also ask the judge to order the person in?to notify me of any new or big expenses and to explain them to the court. This is not a Court Order. Request for Domestic Violence Restraining Order ov-1oo, Page 3 of5 (Domestic Violence Prevention) AMBER LAURA DE PP Case Number: ED 641 052 Spousal Support I am married to or have a registered domestic partnership with the person in and no spousal support order exists. I ask the court to order the person in Q) to pay spousal support. (You must complete, ?le, and serve Form FL-150, Income and Expense Declaration, before your hearing). [El Insurance I ask the court to order the person to cash, borrow against, cancel, transfer, dispose of, or change the bene?ciaries of any insurance or coverage held for the bene?t of me or the person in or our child(ren), for whom support may be ordered, or both. Lawyer?s Fees and Costs I ask that the person in pay some or all of my lawyer?s fees and costs. You must complete, ?le, and serve Form FL-150, Income and Expense Declaration, before your hearing. Cl Payments for Costs and Services I ask the court to order the person in C2) to pay the following: You can ask for lost earnings or your costs for services caused directly by the person in (damaged property, medical care, counseling, temporary housing, etc. You must bring proof of these expenses to your hearing. Pay to: For: Amount: Pay to: For: Amount: Batterer Intervention Program I ask the court to order the person listed in to go to a 52-week batterer intervention program and show proof of completion to the court. 8] Other Orders What other orders are you asking for? 5W- CI Check here if you need more space. Attach a sheet of paper and write 00, Other Orders for a title. El Time for Service (Notice) The papers must be personally served on the person in (D at least ?ve days before the hearing, unless the court orders a shorter time for service. If you want there to be fewer than ?ve days between service and the hearing, explain why below. For help, read Form DV-200-INFO, "What Is Proof of Personal Service?" No Fee to Serve (Notify) Restrained Person If you want the sheri?' or marshal to serve (noti?i) the restrained person about the orders for free, ask the court clerk what you need to do. Court Hearing The court will schedule a hearing on your request. If the judge does not make the orders effective right away ("temporary restraining orders"), the judge may still make the orders after the hearing. If the judge does not make the orders effective right away, you can ask the court to cancel the hearing. Read Form DV-112, Waiver of Hearing on Denied Request for Temporary Restraining Order, for more information. This is not a Court Order. . Request for Domestic Violence Restraining Order DV-100, Page 4 of5 (Domestic Violence Prevention) Revised July 1, 2014 AMBER LAURA DEPP Case Number: ED 641 052 Describe Abuse Describe how the person in abused you. Abuse means to intentionally or recklessly cause or attempt to cause bodily injury to you; or to place you or another person in reasonable fear of imminent serious bodily injury; or to harass, attack, strike, threaten, assault (sexually or otherwise), hit, follow, stalk, molest, keep you under surveillance, impersonate (on the Internet, electronically or otherwise), batter, telephone, or contact you; or to disturb your peace; or to destroy your personal property. (For a complete definition, see Fam. Code, 6203, 6320.) a. Date of most recent abuseWho was there? Self . respondent Raquel Penningt on 0. Describe how the person in abused you or your child(ren): See attached Declaration nF~Petiriener Amber Laura of Raquel Penninqton El Check here if you need more space. Attach a sheet of paper and write Recent Abuse for a title. d. Did the person in C2) use or threaten to use a gun or any other weapon? EINO DYes (If yes, describe): e. Describe anyinjuries: See attached Declarationsmd Exhibits f. Did the police come? CI No a Yes If yes, did they give you or the person in? an Emergency Protective Order? CI Yes [2 No I don?t know Attach a copy if you have one. The order protects CI you or Cl the person in g. Has the person in abused you (or your children) other times? If yes, check here and use Form DV-IOI Description of Abuse or describe any previous abuse on an attached sheet of paper and write Previous Abuse? for a title. Other Persons to Be Protected The persons listed in item@ need an order for protection because (describe): Number of pages attached to this form, if any: I declare under penalty of perjury under the laws of the State of California that the information aims? is true and correct. Date: May 26, 2016 I AMBER LAURA DEPP 3 Type or print your name Sign your Heidi I. .av-P (I Date: May 26, 2015 1 RAMANTHA seamen Ran . gig-JG} Lawyer?s name, if you have one Lawyer?s signature This is not a Court Order. RevisedJuivm?? Request for Domestic Violence Restraining Order Dv-1oo, Page5 of 5 (Domestic Violence Prevention) AMBER LAURA DEPP DECLARATION OF PETITIONER AMBER LAURA DEPP 1925 CENTURY PARK EAST. SUITE 200 Los ANGELES, CA 90067 310.282.9476 f. In re Marriage of DEPP L.A.S.C. Case No. ED 641 052 ATTACHMENT TO FORM DV-100 DECLARATION OF AMBER LAURA DEPP I, AMBER LAURA DEPP, declare as follows: 1. i am the Petitioner herein. have firsthand personal knowledge of the facts stated herein and if called as a witness, I could and would competently testify thereto. 2. I submit this declaration in support of my Request for CLETS Domestic Violence Restraining Orders against Respondent John Christopher Depp ll aka Johnny Depp (?Johnny?). lam also requesting pendente lite spousal support, exclusive possession of the residence located at 849 S. Broadway in downtown Los Angeles ("Broadway residence"), exclusive possession of the 2015 Range Rover vehicle, and attorneys' fees. 3. Johnny and I began living together in or about 2012, and we were married on February 3, 2015. We do not have any children together. 4. During the entirety of our relationship, Johnny has been verbally and physically abusive to me. endured excessive emotional, verbal and physical abuse from Johnny, which has included angry, hostile, humiliating and threatening assaults to me whenever I questioned his authority or disagreed with him. 5. Johnny has a long-held and widely-acknowledged public and private history of drug and alcohol abuse. He has a short fuse. He is often paranoid and his temper is exceptionally scary for me as it has proven many times to be physically dangerous and/or life- threatening to me. Johnny relationship with reality oscillates, depending upon his interaction with alcohol and drugs. As Johnny?s paranoia, delusions and aggression increased throughout our relationship so has my awareness of his continued substance abuse. Because of this, I am extremely afraid of Johnny and for my safety. I am petrified he will return at any moment to the Broadway residence, to which he has full access to despite my repeated pleas to his security team to prevent otherwise and to protect me, if restraining orders are not immediately issued. I strongly believe that in addition to DVROs, Johnny also requires enrollment in anger management courses and a Batterer's intervention program. Page 1 DECLARATION OF AMBER LAURA DEPP LAN am, Sun: and ms Aussies, loos] am an we in re Marriage of DEPP L.A.S.C. Case No. ED 641 052 Recent Events Supporting the Basis of the instant DVRO Rgguest 6. Since early 2013 and throughout the entirety oi our marriage, Johnny and have resided at the Broadway residence. The residence is compromised of connected units. I am requesting exclusive possession and use of the 3 unit condominium -- 7, On April 21. 2016, celebrated my birthday with my friends at the Broadway residence, As everyone was preparing to leave my birthday party, Johnny showed up. ihebrialed and high After my guests had leil, Johnny and I had a discussion about his absence from my birthday celebration which deteriorated into a bad argument that started With Johnny throwing a magnum size bottle at champagne at the wall and a wine glass on me and the "GOP-both which shattered. Johnny then grabbed me by the shoulders and pushed me ontothe bed, blocking the bedroom door. Hethen grabbed me by the hair and violently shoved metothe floor. Johnny was also screaming and threatening me. taunting me to stand up, After several minutes, Johnny stormed out oi the condominium, but not before tossing aside and breaking nearly everything in his path 8 I did not see Johnny again {or another month. 9' The next lime saw him was on May 21.2016. He arrived at the Broadway residence at approximately 7:15 pm. He was inebriated and high. Althe time of Johnny's arrival, my Vriend Elizabeth Marz was present, along with my friend Raquel Rose Pennington and her liance Joshua Drew who live in the adjacent apartment at the Broadway residence 10. When Johnny arrived, at first, we were having a peaceful conversation in our living room talking about his mother's passing as tried to comfort him while we sat on the couch. Suddenly, he began obsessing about something that was untrue and his demeanor changed dramatically, He became extremely angry. I tried to calm Johnny down by calling one of his trusted employees to alleviate his misplaced concerns, but it did not work 11. Johnny was becoming increasingly enraged. I began to have concerns for my salety and sent a text to my friend Raquel who was in the condominium next door. I texted her to ask her to come over. As Johnny continued to rent in an aggressive and incoherent manner, Page 2 DECLARATION OF AMBER LAURA DEPP 1925 CENTURY PARK EAST, SUITE 200 LOS ANGELES. CA 90067 310.252.9473 In re Marriage of DEPP L.A.S.C. Case No. BD 641 052 he then demanded we call our friend iO Tillet Wright to prove his paranoid and irrational accusations about some delusional idea he was having. 12. As my call to i0 went through on speaker phone, Johnny ripped the cell phone from my hand and began screaming profanities and insults at lo. I heard iO yell at me to get out of the house. Johnny then grabbed the cell phone. wound up him arm like a baseball pitcher and threw the cell phone at me striking my cheek and with great force. 13. I immediately covered my face and was crying because of the pain resulting from the phone hitting me. Johnny charged at me, insisting on seeing my face. He taunted me, challenged whether or not the cell phone actually hit me. He then forceably pulled back my hair as I attempted to stand up from the sofa. I then yelled out "Call 911" hoping it would be heard by i0 who was still on the phone. Johnny continued screaming at me, pulling my hair, striking me and violently grabbing my face. 14. Raquel entered the condominium using the key I had previously provided to her. I then escaped Johnny's grasp as he momentarily seemed distracted by Raquel?s entrance. 15. Johnny then charged me again after I had moved to the other side of the room. Raquel ran in between us and begged Johnny to stop. He then slapped away her arms that she had extended in a defensive manner and continued to yell Obscenities at her. 16. retreated to the couch. Raquel then came over to covered me in a protectively posture, while Johnny then picked up the magnum size bottle of wine he had been drinking out of. and he started swinging it around, smashing everything he could. 17. Johnny then stormed at me once again, demanding that I get up and stand. He did this - about ten times getting closer to me, louder and more threatening each time. Johnny's security team, that included, Judge Jerry, entered the condominium at this time, but they stood back without saying or doing anything. I yelled to Jerry to please help me and told him that if Johnny hit me one more time I was going to call the police. I heard Jerry say, "Boss, Please." But Johnny continued screaming and breaking things, finally leaving the condominium. 18. As Johnny went down the hallway, he smashed another bottle of wine and then Page 3 DECLARATION OF AMBER LAURA DEPP 1925 CENTURY PARK EAST, SUITE 200 LOS ANGELES, CA 90067 310.282.9478 In re Marriage of DEPP L.A.S.C. Case No. ED 641 052 went into the adjoining condominium unit I use as my office, painting studio and closet. I could hear him destroying items of my personal property as he continued screaming. 19. Joshua and Raquel took me into theircondominium for safety. Eventually I did not hear Johnny any more. 20. Collectively attached hereto as Exhibit are photographs depicting the injuries to my face and the property damage caused by Johnny. 21. I live in fear that Johnny will return to the Broadway residence unannounced to terrorize me, physically and emotionally. I require the protection of this Court via the issuance of Domestic Violence restraining orders. There also have been several prior incidents of domestic violence with Johnny, in particular there was one severe incident in December 2015 when I truly feared that my life was in danger. 22. In addition to the DVROs I am seeking, as have no place to live other than the Broadway residence (my home for the past two years), I am requesting exclusive use and possession of said property. i also require exclusive use and possession of the Range Rover vehicle, which I am currently using. Further, i am requesting possession of my dog Pistol. 23. Although Johnny is extremely wealthy, he refuses to provide me with any direct financial support. Concurrent with this filing I am providing an Income and Expense Declaration. I am requesting $50,000 a month as and for pendants lite spousal support based on our marital lifestyle. 24. Except as to that which is based on information and belief, I have personal knowledge of the matters set forth herein and, and if sworn as a witness, I could and would competently testify thereto. This declaration is being submitted in lieu of personal testimony pursuant to Code of Civil Procedure 2009 and 2015.5, California Rules of Court, Rule and Reifler v. Superior Court (1974) 39 Cal.App.3d 479. I declare, under penalty of perjury pursuant to the laws of the State of California, that the foregoing is true and correct. Executed this 26th day of May, 2016 at Los Angeles, California see siqnature on form AMBER LAURA DEPP Page 4 DECLARATION OF AMBER LAURA DEPP seamen 0.51. SWYE toe moms, CA in re Marriage oi DEPP L.A.S.C, Case No. ED 641 052 ATTACHMENT TO FORM DV-10Q DECLARATION OF RAQUEL ROSE l, RAQUEL ROSE PENNINGTON, declare as lollows: 1. I have firsthand personal knowledge at the facts stated herein and it called as a witness. i could and would competently testiiy thereto. 2. declaration in support oi PetilionerAMEER LAURA ("Amber") RequesitorCLETS Restraining Orders against Respondent John Christopher Depp ll aka Johnny Depp ("Johnny"). 3 have been friends wilh Amber since 2003. My fiance Joshua Drew and i live in one at the condominiums located ai--Los Angeles. I have a key to the condominium unils which Amber shares with Johnny. 4 On May 21, 2016, I was in my condominium with Joshua when I received a text message lrom Amber at approximately 8:05 pm" asking me to come over to her condominium unit. 5. I immediately went over to Amber's place. When i got to the door, I could hear Amber and Johnny arguing inside. I knocked on the locked door, but there was no answer, so I quickly ran back Io my apanment to get my key to open Amber's door. 6. I returned to Amber's condominium less than a minute later. When I opened the door, I saw Amber by the couch in the ihling room covering her head with her arms and hands. as Johnny was loudly screaming at her. 7. I ran over and stood in between Johnny andAmber, begging stop yelling at her. i put my hands out in a defensive manner motioning him to stop. Johnny slapped my hands away and screamed toul Obscenities at me. Ithen tried to covered Amber up with my body to protect her lrorn him a. Johnny picked up a magnum slze bottle of wine and began swinging it like a baseball bat, Wine was all over the walls. floors and furniture, and he began using the bottle to smash everything he could. Page 1 DECLARATION OF RAQUEL ROSE PENNINGTON L05 90067 am 9R9 DATA In re Marriage of DEPP L.A.S.C. Case No. ED 641 052 9. He then charged at Amber, screaming at her to stand up. He repeatedly yelled at Amber to stand up -- about ten times and each time, he got closer, louder and more threatening. 10. Johnny's security team then arrived, which included Jerry Judge, but they each stood back and did not say or do anything. 11. Amber pleaded with Jerry to help and said that if Johnny hit her one more time she was going to call the police. 12. Jerry said "Boss. Please." 13. Johnny continued screaming and breaking things, before finally walking out of the apartment and into the hallway where he continued screaming and breaking things. 14. I could hear Johnny go into Amber's private condominium, where she keeps her personal belongings and artwork, and continue to scream and break things. 15. Joshua came into the condominium unit and together we took Amber into our condominium unit for safety. 16. I observed that Amber sustained a significant injury to her right as a result of the incident with Johnny, as there was redness and swelling. Amber was crying, shaking and very afraid of Johnny. 17. Finally, I heard Johnny leave the premises. I then took pictures of Amber's face which are attached as Exhibit to the Declaration of Amber. 18. Many times over the past few years, Amber has confided and complained to me about Johnny's abusing her, both physically and verbally. Page 2 DECLARATION OF RAQUEL ROSE PENNINGTON