FILED
1 D. CHRISTOPHER RUSSELL

201SJUN-3 m\\-h5

State Bar No.022674

2 THE RUSSELL'S LAW FIRM,PLC

c: -.rr? dukla?

741 East Fry Blvd, Suite 200
3 Sierra Vista, Arizona 85635
Toil Free: (855)707-7246
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Telephone:(520)458-7246
5 Facsimile: (855)778-5559

CLERK C; LUi' LKiCR COURT
DEPUTY
SV

courtdocs@russellsIawfirm.com

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CHARLES J. HARDER (California State Bar No. 184593)
(Pro Hac Vice application to be filed)
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HARDER MIRELL & ABRAMS LLP

9 132 S. Rodeo Drive, Suite 301

Beverly Hills, California 90067
10 Telephone: (424)203-1600

Facsimile: (424)203-1601
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CHarder@HMAfirm.com

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Attorneys for Plaintiff
13 AMBER HEARD

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15

SUPERIOR COURT OF THE STATE OF ARIZONA

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COUNTY OF COCHISE

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C V2016y0280

18 AMBER HEARD,an individual.
19

Case No^

Plaintiff,
COMPLAINT

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V.

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DOUG STANHOPE,an individual;
and DOES 1-20, inclusive.
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DEMAND FOR JURY TRIAL

Defendants.

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SUMMARY OF THE CASE

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1.

Defendants orchestrated a plot to write an article, which was published at

28 TheWrap.com, which falsely accuses plaintiff Amber Heard of"blackmail" and other criminal
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behavior towards her husband, Johnny Depp,from whom she is seeking a divorce. The

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allegations about Heard in the article are completely false and defamatory, and have caused and

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will continue to cause her tremendous harm. Defendants engaged in this scheme to try to divert

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public attention away from the true facts regarding Depp which caused their marriage to fail,

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namely,that Depp repeatedly abused Heard throughout their marriage, at times to the point of her

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fearing for her life. Heard was forced to seek a court protective order, to protect her from the

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ongoing physical abuse and violence by her husband, Depp. During their marriage, Heard gave

8 Depp numerous chances to get and stay sober and change his violent behavior towards her. When
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she finally realized that Depp was not changing his behavior, and to avoid further injury and risk

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to her life. Heard took the very difficult step offiling for divorce and seeking a protective order.

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2.

In response to Hoard's truthful and necessary court filings. Defendants took action

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to publicly defame Ms. Heard by falsely accusing her of"blackmail" and other criminal conduct,

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knowing that he had no factual basis to make the allegations. Defendants' statements are

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completely false and highly defamatory. Defendants are engaged in a classic case of"attacking

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the victim," in an effort to discredit Heard, destroy her good name and reputation, and severely

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harm her hard-earned entertainment career, on top ofthe campaign of violence that Depp has

17 inflicted upon her for years.
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3.

To counter the setback to the progress of women by the Defendants' actions.

19 Amber Heard pursues the maximum possible damages against the Defendants, and will donate all
20 ofthe proceeds of this lawsuit to a battered women's shelter in Arizona.
THE PARTIES

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4.

Plaintiff Amber Heard ("Heard")is an individual residing in Los Angeles County,

23 California.
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5.

Defendant Doug Stanhope("Stanhope")is an individual residing in Bisbee,

25 Arizona. Stanhope is one of Depp's closest personal fnends.

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6.

Heard is informed and believes, and based thereon alleges, that defendants, and

27 each ofthem, designated herein as DOES 1 through 20,inclusive, are responsible in some manner

28 for the occurrences and happenings herein alleged, and that Heard's damages as herein alleged
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were and are the direct and proximate result ofthe actions of said defendants, and each ofthem.

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Said defendants are sued as principals or agents, partners, servants and employees ofsaid

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principals, or any combination thereof, and all ofthe acts performed by them as agents, partners,

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servants and employees were performed within the course and scope oftheir employment,and

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with the knowledge, consent, approval and ratification ofsaid principals, and each of them.

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(Stanhope and DOES 1 through 20, inclusive, are collectively referred to herein as "Defendants.")

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7.

Heard is informed and believes, and based thereon alleges, that at all times

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mentioned herein, each ofthe defendants was the agent, employee and partner ofeach ofthe

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remaining defendants, and was acting within the scope and authority ofsuch agency, employment

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and partnership and with the knowledge,consent, approval and ratification ofthe remaining

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defendants, and each ofthem.

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8.

Whenever in this complaint reference is made to any act ofa defendant, such

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allegation shall be deemed to mean the acts ofthe defendants named in the particular cause of

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action, and each ofthem, acting individually,jointly and severally.
FACTS COMMON TO ALL CAUSES OF ACTION

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9.

Amber Heard is an award-wiiming actress who has credits in more than 40 movies

17 and television shows.
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10.

Heard has been in a relationship with Depp for five years, and married to Depp

19 since February 3,2015.
20

11.

During the course of his relationship with Heard, Depp has repeatedly been

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physically and verbally abusive towards her. Depp has hit and kicked Heard on numerous

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occasions, has thrown objects at her, at one point nearly suffocated her to the point where she

23 feared for her life. Depp is an alcoholic and drug addict, and these violent episodes occurred
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mostly after Depp had relapsed into a cycle ofsubstance abuse. His drug and alcohol abuse has

25 increased dramatically in recent years, as has his violent behavior.
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12.

Heard repeatedly retumed to Depp,despite his verbal and physical mistreatment of

her, hoping optimistically that the man she married would change his behavior. Each time Heard

28 retumed, however, within months,the cycle of substance abuse and violence repeated.
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13.

Throughout the years, Heard has documented the effects ofthe abuse that she

suffered at the hands of Depp,including numerous photographs of bruises and injuries caused by

3 Depp's abuse, among other forms of evidence.
4

14.

In May 2016, after 15 months of marriage and numerous instances of abuse,

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matters came to a head when Heard was consoling Depp after his mother died. In his altered state,

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Depp was incensed by a delusion, blew up at Heard and flew into a rage, threw her phone at her,

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then violently grabbed Heard by the hair while assaulting her, and verbally and physically

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threatened neighbors and witnesses who came into the house to help.

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15.

Heard reached a breaking point, and filed for divorce promptly thereafter.

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16.

As part ofthe divorce filing. Heard sought a domestic violence restraining order

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against Depp which included a photograph (one of many)showing the bruises and injuries caused

12 by Depp's abuse.
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17.

Heard's divorce filing received substantial publicity because Depp is a noted

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HoiI)^ood celebrity whose personal life is routinely covered by the entertainment industry press.

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Depp and his representatives have numerous connections in the entertainment industry and the

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entertainment industry press who will do his bidding and serve his interests, to obtain from him,in

17 turn, favors, access and other benefits.
18

18.

After the May 2016 domestic violence incident, Depp commenced a publicity tour

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for his new film, and his representatives contacted numerous members ofthe press to discredit

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Heard and subvert her truthful allegations. Depp and his representatives further'Svent on the

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offensive" during the publicity tour by repeatedly making false public allegations about Heard to

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the press, accusing her of being manipulative, a blackmailer, and blaming her for the breakup of

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the marriage—^as if Depp's alcoholism, drug addiction and campaign of violence against his wife

24 played no part.
25

19.

Depp's publicity tour was coordinated by Depp and his powerful representatives,

26 who surreptitiously disseminated numerous false statements about Heard. As a result ofthis
27 coordinated, malicious campaign, a number of news organizations have repeated these false

28 statements, disparaging Heard and harming her reputation and career. Defendants were well4

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aware that their defamatory statements to press organizations would have this affect on Heard, and

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Defendants had the specific intent to cause harm to Heard, when they made these false statements

3 to the press.

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20.

On May 29,2015, an article written by Stanhope entitled

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"Johnny Depp Is Being Blackmailed by Amber Heard - Here's How I Know(Guest Column)"

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(the "Defamatory Article") was posted on the website TheWrap.com. On information and belief.

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Stanhope wrote the Defamatory Article at the request of, and with active input from others, whose

8 identities are currently unknown and,therefore, have been named in this action as"Doe"

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defendants. When their identities have been revealed, through further investigation and discovery,

10 their names will be identified herein and included as named defendants.
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21.

The Defamatory Article contains the following false and defamatory statements:

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a.

The headline:"Johnny Depp Is Being Blackmailed by Amber Heard."

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b.

"Heard was 'threatening to lie about[Depp] publicly in any and every

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possible duplicitous way if he didn't agree to her terms'."
c.

"Today,a friend of mine was pilloried in the press for domestic violence.

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Coupled with a picture of his wife with a bruise, he was murdered on social media. I

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watched it happen and I didn't say a f—^ing word. Even though I knew it was bulls—."

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d.

"We'd watched it build like this since before they were married. We'd

watched her manipulate and f— with him for years."

e.

"When your friend is in an awful, abusive relationship — man or woman —

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and you risk weighing in that their counterpart [referring to Heard] is a demon, you know

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the odds are they willjump right back into the fire and then dump you from their life for

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being honest."

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f.

"My girlfiiend. Bingo, and I have known Johnny Depp for a few years now.

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We have watched Amber Heard f— with him at his weakest — or watched him at his

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weakest from being f—ed with — for the entire time we've known him."

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g.

"Bingo and I were at Johnny's house for most ofthat Saturday until just

before the alleged assault. We assumed initially that his dour mood was because of his
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mother's death the day before. But he opened up in the most vulnerable of ways that it

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was not only his mother, but that Amber was now going to leave him,threatening to lie

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about him publicly in any and every possible duplicitous way if he didn't agree to her

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terms. Blackmail is what I would imagine other people might put it, including the manner

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in which he is now being vilified."

h.

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"Bingo and I together, and then separately, told him how much we were

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aware ofthis manipulative a-hole, how his closest circle had all agreed on this since the

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day we met and that we all feared that telling him outright might alienate us all."

i.

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"He still pronounced his love for Amber but was presciently aware that she

was going to pull offsome kind ofruse to f— him over."

j.

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"From what we now read in the news, later that night the police were called

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to his house for a domestic dispute. Finding no criminal act had occurred and no signs of

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physical abuse, the police left. Everything Johnny had told us that she'd been threatening

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had actually come to be. It blew up in the news,raced through the Internet like a plague

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and blew up on Twitter like it was the McMartin child abuse scandal. People are swarming

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with torches on social media."

k.

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"Johnny doesn't abuse anyone. And he told me that day ahead oftime that

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she'd pull some kind ofs— like this. Johnny Depp got used, manipulated, set up and

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made to look like an a-hole."

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22.

Each ofthese statements is feilse and defamatory. Heard never undertook any

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action that could even remotely be described as "blackmail." Quite to the contrary, Heard told

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Depp that if he did not change his alcohol and drug-fueled abusive behavior towards her, that she

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would have no alternative but to leave him,even though she loved him and wanted their marriage

24 to work.
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23.

Heard has never threatened to lie about Depp in public. To the contrary, all ofthe

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allegations Heard has made in her marital dissolution proceeding and request for a restraining

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order, including her accounts ofphysical and verbal abuse by Depp against her, are true. Heard

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has never attempted to improperly manipulate Depp or"f— with him." Rather,she loved him and
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gave him numerous chances to change his behavior, and end the cycle of alcoholism, drug abuse,

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and physical and verbal abuse of her. Yet Depp Avould not and has not changed his behavior,

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precipitating Heard to file for divorce and seek a restraining order.

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24.

On information and belief. Defendants' many defamatory statements in the

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Defamatory Article were made as part ofa calculated publicity campaign to smear Heard for

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having the temerity to file for divorce and seek a court order to protect her physical safety.

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Defendants knew the statements about Heard in the Defamatory Article were completely untrue

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and fabricated, and they did not care, because their only concern was helping Depp by trashing the

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reputation of his wife, who loved Depp,even though she had been repeatedly physically and

10 verbally abused by him.
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12

25.

Heard,through her attorney, demanded that TheWrap.com to take down the

Defamatory Article and issue a retraction. TheWrap.com refused to do so.

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FIRST CAUSE OF ACTION

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(Defamation - Against Ail Defendants)

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26.

Heard incorporates by this reference Paragraphs 1 through 25 ofthis Complaint as

16 though fully set forth herein.

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27.

The statements in the Defamatory Article were and are false.

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28.

The statements in the Defamatory Article were ofand concerning Heard.

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29.

The statements in the Defamatory Article brought Heard into disrepute, contempt,

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or ridicule, and purported to impeach Heard's honesty,integrity, virtue and/or reputation.

30.

Defendants published the Defamatory Article knowing or recklessly disregarding

22 that the statements therein were false.
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31.

The statements in the Defamatory Article were defamatory per se.

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32.

Heard has suffered actual damages to her personal and professional reputation and

25 career in an amount to be proven at trial.
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33.

Defendants intended to injure Heard, were motivated by spite or ill will, acted to

serve their ovm interests, having reason to know and consciously disregarding a substantial risk

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that his conduct might significantly injure Heard, and consciously pursued a course ofconduct

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knowing that it created a substantial risk of significant harm to Heard.

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SECOND CAUSE OF ACTION

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(Intentional Infliction of Emotional Distress- Against All Defendants)

34.

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Heard incorporates by this reference Paragraphs 1 through 33 ofthis Complaint as

6 though fully set forth herein.
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35.

Defendants' conduct was extreme and outrageous.

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36.

Defendants intended to cause Heard emotional distress and/or recklessly

9 disregarded that their conduct would do so.
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37.

Defendants' conduct has resulted in Heard suffering severe emotional distress.

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38.

Defendants knew that their false statements offact in the Defamatory Article were

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false at the time the statements were made and/or with reckless disregard to the truth.

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39.

Heard has suffered actual damages in an amount to be proven at trial.

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40.

Defendants intended to injure Heard, were motivated by spite or ill will, acted to

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serve their own interests, having reason to know and consciously disregarding a substantial risk

16 that their conduct might significantly injure Heard, and consciously pursued a course ofconduct
17 knowing that it created a substantial risk of significant harm to Heard.
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THIRD CAUSE OF ACTION

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(Tortious Interference with Existing and Prospective Economic Relationships-

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Against All Defendants)

41.

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Heard incorporates by this reference Paragraphs 1 through 40 ofthis Complaint as

22 though fully set forth herein.

42.

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Heard, as a working actress, has prospective economic relationships with a number

ofindividuals and entities in the entertainment industry, the fashion industries, and many other

25 industries who may seek to use her services.

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43.

Defendants, at all relevant times, were aware of Heard's status as an actress and her

27 prospective economic relationships within the industry.

28 ///

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44.

Defendants published the Defamatory Article with the intent to interfeie with

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Heard's actual and prospective economic relationships and to cost her valuable work in the

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industry, to add pressure to Heard to resolve the pending divorce case on favorable terms, and also

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in retaliation for Hoard's decision to end her marriage with Depp and protect her safety by seeking

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a restraining order against Depp. In the alternative. Defendants' actions were negligent in that

6 they disregarded the risk that by publishing the Defamatory Article, they would harm Hoard's
7 prospective economic relationships.

8

45.

As a result of Defendants' actions. Heard has suffered actual damages in an amount

9 to be proven at trial.
10

46.

Defendants intended to injure Heard, were motivated by spite or ill will, acted to

11

serve their own interests, having reason to know and consciously disregarding a substantial risk

12

that their conduct might significantly injure Heard, and consciously pursued a course ofconduct

13 knowing that it created a substantial risk ofsignificant harm to Heard.
PRAYER FOR RELIEF

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WHEREFORE,Plaintiff prays for relief as follows:

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a.

For actual damages according to proof;

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b.

For punitive damages;

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c.

For costs ofsuit; and

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d.

For such other and further relief as may be just and proper.

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All proceeds from this lawsuit will be donated to a battered women's shelter in Arizona.

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DEMAND FOR JURY TRIAL

Plaintiff hereby demands a trial by jury.

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Dated: June 3, 2016

THE RUSSELL'S LAW FIRM,PLC

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gy.

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D. CHRISTOPlfER RUSSELL
741 East Fry Blvd, Suite 200
Sierra Vista, Arizona 85635

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-and-

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CHARLES J. HARDER

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HARDER MIRELL & ABRAMS LLP

132 S Rodeo Drive, Suite 301

Beverly Hills, California 90067
(a pro hac vice application pursuant to Rule 39( c),
Ariz. R.S. Ct. shall be filed forthwith)

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Attorneys for Plaintiff AMBER HEARD
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