FEED I I I A rain 9351 IN THE CIRCUIT COURT OF FAIRFAX COUNTY 1? JOHN C. DEPP, II 1' 335 g'g? mum? rim. I?m-?u Plaintiff, v. Civil Action No.: CL-2019-0002911 AMBER LAURA HEARD Defendant. MOTION FOR LEAVE FOR BRIEFING SCHEDULE AND EVIDENTIARY HEARING ON MOTION TO DISMISS PURSUANT TO VA. CODE 8 COMES NOW, by special appearance, Defendant Amber Laura Heard Heard?), by her undersigned counsel, and, pursuant to Virginia Code section the Rules of the Supreme Court of Virginia, and sub-sections 1.04, 1.05, and 6.00 of Section of The Fairfax Circuit Court Practice Manual (2018 hereby ?les this Motion for Leave for Brie?ng Schedule and Evidentiary Hearing on Motion to Dismiss Pursuant to Va. Code and in support thereof states as follows: 1. Ms. Heard, by counsel, has ?led a Combined Motion to Dismiss Pursuant to Va. Code and Plea in Bar. 2. In accordance with Virginia Code section the Rules of the Supreme Court of Virginia, and sub?sections 1.04, 1.05, and 6.00 of Section of The Fairfax Circuit Court Practice Manual (2018 Ms. Heard respectfully requests that this Court apply a brie?ng schedule to her Motion to Dismiss with a Memorandum in Support of ?fteen (15) pages, The undersigned counsel will confer with counsel for Plaintiff to appear at calendar control for scheduling a brie?ng schedule and an evidentiary hearing and/or otherwise schedule this matter for an available Motion?s Docket if necessary. 1235730.1 a Memorandum in Opposition (if any) of twenty pages (20) and a Memorandum in Reply of ?ve (5) pages.2 3. Moreover, Ms. Heard has already prepared a Memorandum in Support consistent with the above which includes evidence necessitating an evidentiary hearing of more than thirty (30) minutes such that Ms. Heard also requests the scheduling of an evidentiary hearing at the Court?s earliest available date. 4. The Memorandum in Support is attached and incorporated herein by reference as Exhibit A with a request that the Court accept the Memorandum as ?led. WHEREF ORE, in consideration of the foregoing, Defendant Amber Laura Heard respectfully moves this Court to: grant the proposed brie?ng schedule contained herein, (ii) grant the request for an evidentiary hearing (and schedule such hearing) as to the Motion to Dismiss Pursuant to Va. Code 8.0] -265(i), accept the attached Exhibit A as the Defendants? Memorandum in Support of the Motion to Dismiss Pursuant to Va. Code 8.01- 265(i) with instructions that Defendant docket an identical copy with the Clerk of this Court for clear record purposes, and (iv) grant such other and further relief as deemed appropriate. IN 2 Defendant intends to schedule the Plea in Bar for a separate hearing subject to a separate brie?ng scheduling if the Motion to Dismiss is not granted. 12357304 2 12357301 Dated this 1 1?h day of April 2019. Respectfully submitted, By: 324?. Eric M. George, Esq. (pro hac vice application pending) Richard A. Schwartz, Esq. (pro hac vice application pending) BROWNE GEORGE ROSS LLP 2121 Avenue of the Stars, Suite 2800 Los Angeles, California 90067 Telephone: (310) 274-7100 Facsimile: (310) 275-5697 eaeorae?lbar? rm.com ar?rmeom Counsel for Defendant Amber Laura Heard q? Timothy .1. McEvoy, Esq. (VSB No. 33277) Sean Patrick Roche, Esq. (VSB No. 71412) PLLC 4100 Monument Corner Drive, Suite 420 Fairfax, Virginia 22030 Telephone: (703) 273-8898 Facsimile: (703)273-8897 srocher?EDeameronmcevovxorn Counsel for Defendant Amber Laura Heard CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 1 1?1 day of April 2019, 1 served the foregoing via First Class Mail (postage prepaid) and electronic mail upon the following: Benjamin G. Chew (VSB No. 291 13) Elliot]. Weingarten (pro hac vice application forthcoming) Andrew C. Crawford (VSB 89093) BROWN RUDNICK LLP 601 Thirteenth Street, N.W. Washington, DC. 20005 Telephone: (202) 536-1700 Facsimile: (202) 536-1701 Email: lichen ?rizbrownrudnickcom Adam R. Waldman THE ENDEAVOR LAW FIRM, RC. 1775 Avenue, N.W., Suite 350 Washington, DC 20006 Brittany Whitesell Biles (pro hac vice application forthcoming) STEIN MITCHELL BEATO MISSNER LLP 901 Fifteenth Street, N.W. Suite 700 Washington, DC. 20005 Telephone: (202) 601-1602 Facsimile: (202) 296-8312 Email: Counsel for Plainti? John C. Depp, II a? Timothy .1. McEvoy, Esq. (VSB No. 33277) 123573111 4 I I I A IN THE CIRCUIT COURT OF FAIRFAX COUNTY JOHN C. DEPP, 11 Plaintiff, v. Civil Action No.: CL-2019-0002911 AMBER LAURA HEARD Defendant. ORDER THIS CAUSE comes at the request of Defendant Amber Laura Heard, by counsel, for a brie?ng schedule and evidentiary hearing as to the Motion to Dismiss Pursuant to Va. Code 8.01- 26S(i), and IT APPEARING that the Motion for Leave for Brie?ng Schedule and Evidentiary Hearing on Motion to Dismiss Pursuant to Va. Code should be granted, it is hereby: ORDERED that in accordance with Virginia Code section the Rules of the Supreme Court of Virginia, and sub-sections 1.04, 1.05, and 6.00 of' Section of The Fairfax Circuit Court Practice Manual (2018 ed.) the following schedule and evidentiary hearing is hereby scheduled to govern the disposition of the Motion to Dismiss Pursuant to Va. Code 801-2650): Memorandum in Support Due: (15 pages). Memorandum in Opposition Due: (20 pages). Memorandum in Reply Due: (5 pages). Evidentiary Hearing - to commence at EDT. IT IS FURTHER ORDERED the Exhibit A attached to the Motion for Leave for Brie?ng Schedule and Evidentiary Hearing on Motion to Dismiss Pursuant to Va. Code is hereby accepted as ?led with Defendant instructed to docket an identical copy with the Clerk of this Court for clear record purposes. ENTERED this day of 2019. Judge, Circuit Court for the County of Fairfax WE ASK FOR THIS: Timothy .1. McEvoy, Esq. (VSB No. 33277) Sean Patrick Roche, Esq. (VSB No. 71412) PLLC 4100 Monument Comer Drive, Suite 420 Fairfax, Virginia 22030 Telephone: (703) 273-8898 Facsimile: (703)273-8897 imeex or sroche ti cameronmeevox'xmn Counsel for Defendant Eric M. George, Esq. (pro hac vice application pending) Richard A. Schwartz, Esq. (pro hac vice application pending) BROWNE GEORGE ROSS LLP 2121 Avenue of the Stars, Suite 2800 Los Angeles, California 90067 Telephone: (310) 274-7100 Facsimile: (310) 275-5697 barli rm.com Counsel for Defendant SEEN AND Benjamin G. Chew (VSB No. 29l 13) Elliot J. Weingarten (pro hac vice application forthcoming) Andrew C. Crawford (VSB 89093) BROWN RUDNICK LLP 601 Thirteenth Street, N.W. Washington, DC. 20005 Telephone: (202) 536-1700 Facsimile: (202) 536-1701 Email: Adam R. Waldman THE ENDEAVOR LAW FIRM, RC. 1775 Avenue, N.W., Suite 350 Washington, DC 20006 Brittany Whitesell Biles (pro hac vice application forthcoming) STEIN MITCHELL BEATO MISSNER LLP 90] Fifteenth Street, NW. Suite 700 Washington, DC. 20005 Telephone: (202) 601-1602 Facsimile: (202) 296-8312 Email: bbilesf?" Counsel for Plairiti?r John C. Depp, EXHIBIT A 09l756-vl I I I A IN THE CIRCUIT COURT OF FAIRFAX COUNTY JOHN C. DEPP, II Plaintiff, v. Civil Action No.: CL-2019-0002911 AMBER LAURA HEARD Defendant. MEMORANDUM IN SUPPORT OF MOTION TO DISMISS PURSUANT TO VA. CODE 8 8.01-2655i] COMES NOW, by special appearance, Defendant Amber Laura Heard (?Ms Heard?), by her undersigned counsel, and, pursuant to Virginia Code section hereby moves to dismiss the Complaint because the only issues to be resolved in this litigation center on events, witnesses, and premises, all of which are located in Los Angeles, California, making Virginia an inappropriate venue. In support of her Motion to Dismiss, Ms. Heard states as follows: I. INTRODUCTION Johnny Depp regularly abused Amber Heard?both physically and emotionally? throughout much of their relationship. The vast majority of these violent incidents occurred when Mr. Depp was drunk or high or both in their Los Angeles, California home or while the couple was traveling abroad. Ms. Heard eventually found herself forced to ?le for divorce, sought and obtained a domestic violence restraining order against Mr. Depp, and freed herself from the abusive relationship. After the ensuing media frenzy?in which Mr. Depp distorted the truth for public consumption?Ms. Heard resolved to fight for the victims of domestic violence, and to do everything in her power to ?ght back against the silencing of abuse victims. She became the 122l850.l I American Civil Liberties Union?s Ambassador for Women?s Rights, and now speaks at conferences worldwide about how to combat this pernicious and insidious issue affecting millions, if not billions of women and men worldwide. In December of 201 8, Ms. Heard authored an Op-Ed about domestic violenCe. Her article does not mention Mr. Depp. Moreover, as Mr. Depp concedes, every sentence in that Op- Ed is literally true. Notwithstanding, in an all-too-transparent ploy to stanch the ongoing damage to his reputation as a Hollywood star, Mr. Depp used the Op-Ed as a pretext to sue Ms. Heard. He now claims?as a means of alleging defamation against Ms. Heard?that he has dozens of witnesses (notably, all of whom are located in Los Angeles, California) who will testify that one particular incident of abuse is ?demonstrably untrue? and a ?hoax.? Of course, Mr. Depp?s claims are an attempt to mislead the trier of fact into thinking that one incident in 20 6?out of dozens of violent episodes throughout the couple?s relationship?is the only possible basis for Ms. Heard?s perspective as a domestic abuse victim. Ms. Heard?s primary defense?the truth?will be proven when this bad faith defamation action is adjudicated on its merits. For now, however, it simply need be noted that the issues, witnesses, and premises that will prove the truth of Ms. Heard?s defenses are all located in LosAngeles, California. Because an examination of such evidence could not be performed by this Court in Fairfax, Virginia, Ms. Heard respectfully requests that this Court dismiss this case on grounds of forum non conveniens, so that Mr. Depp?s meritless claims may be tried and disposed of, once and for all, in Los Angeles, California. 11. LEGAL STANDARD Pursuant to Virginia Code section 8.0] -265(i), a court may ?dismiss an action brought by a person who is not a resident of the Commonwealth without prejudice under such conditions as 122 850. I 2 the court deems appropriate if the cause of action arose outside of the Commonwealth and if the court determines that a more convenient forum which hasjurisdiction over all parties is available in ajurisdiction other than the Commonwealth.? The decision of whether or not to dismiss and transfer such a case is ?within the sound discretion of the trial judge.? Va. Code 8.01-267. ARGUMENT A. Plaintiff?s Complaint Allgges Only One Claim, Which Arose In California Despite Plaintiff?s attempt to disguise his Complaint as three separate causes of action, in reality, Plaintiff asserts only one defamation claim based on a single Op-Ed appearing in the Washington Post. That claim is subject to dismissal under Virginia Code because the claim arose in California and because California is the far more convenient forum for this litigation. 1. Plaintiff Asserts Only One Defamation Claim Depp seeks to prosecute three redundant defamation claims arising out of a single Op?Ed written by Ms. Heard and published in the same edition (though in different media) of the Washington Post. However, Virginia follows the ?single publication rule? in defamation cases. See v. Bank of Am., 61 Va. Cir. 13] (2003) (citing Myska v. RMS Technologies, Inc, 25 Va. Cir. 344 (Fairfax, Oct. 21, 1991) (?Under the single publication rule, ?[a]ny one edition of a book or newspaper, or any one radio or television broadcast, exhibition of a motion picture or similar aggregate communication is a single The single publication rule ?was adopted in recognition of the vast multiplicity of suits which could arise from mass publications which transcend a variety of medias and state lines, and the attendant problems of choice of law, inde?nite liability, and endless tolling of the statute of limitations.? Myska v. MS Techs, inc, 25 Va. Cir. 344 (I 991) (quoting Khaury v. Playboy Publications, 450 F. Supp. 1342, 1354 12mm: 3 (S.D.N.Y. Because each of Plaintiff?s claims is expressly premised on the publication of a single Op-Ed that appeared in a single edition of the Washington Post across different media, Plaintiff asserts only a single defamation claim. (See Compl.1]1] 75, 86, 97 (premising three separate claims on the same edition of the Washington Post).) 2. Plaintiff?s Defamation Claim Arese Outside Virgini_a Plaintiff?s single claim for defamation undoubtedly arose outside of Virginia. Regardless of whether Virginia or some other law applies to determine where a defamation claim ?arises,? the single, multistate mass media claim at issue here arises in California. Applying Virginia law, a federal district court squarely addressed where a multistate, mass media defamation claim arises: Virginia follows the ?traditional? choice-of-law approach: it applies the [ex loci delecti, or the law of the place of the tort, to issues of substantive law. See Jones v. RS. Jones Assoc?s, Inc(1993); McMillan v. McMillan, 219 Va. 1 127, 253 662, 663?64 (1979). According to the First Restatement of Con?ict of Laws, the place of the tort is the state ?where the last event necessary to make an actor liable for an alleged tort takes place, which in all but a few cases is the injury felt by the plaintiff. Restatement (First) of Con?ict of Laws 377 (1934). The traditional rule has been considered inexact in cases of libel arising from multi-state publications. Some courts have called the old rule ?cumbersome, if not impossible? to apply where the plaintiffs reputation is allegedly injured in several states by the same aggregate publication. Wells v. Liddy, 186 F.3d 505, 527 (4th Cir. 1 999). However, in practice, lex loci jurisdictions have shown remarkable consistency in Although the Virginia Supreme Court has not speci?cally considered whether the single publication rule applies in the context of an intemet publication, nearly every otherjurisdiction has held that an intemet publication of the same material is part of a single publication. See, Eramo v. Rolling Stone, LLC, 209 F. Supp. 3d 862, 879 (W.D. Va. 2016) (?Jurisdictions that have adopted the single publication rule are ?nearly unanimous? in applying it to intemet publications?); Canatella v. Van De Kemp, 486 F.3d 1 128, 134 (9th Cir. 2007) (holding that intemet publication quali?ed as single publication for purposes of the single publication rule, and that ?a single publication gives rise to only one cause of action?); Nationwide Bi? Weekly Admin, Inc. v. Bela Corp, 512 F.3d 137, 146 (5th Cir. 2007) (same). 12218501 4 how to resolve the question. The vast majority of such districts look to the law of the jurisdiction where the plaintiff suffered the greatest injury. Moreover, that district is usually the one in which the plaintiff was domiciled. See Wells v. Liddy, 186 F.3d 505, 528 (4th Cir. 1999) (interpreting Maryland law); Miller v. Lear Siegler, Inc. 525 F. Supp. 46, 56 (D. Kan. 1981); Lewis v. Reader's Digest Ass'n, Inc, 162 Mont. 401, 407, 512 P.2d 702 (Mont.1973). Virginia has not speci?cally addressed this question, but I ?nd that they would follow the lead of other lex loci jurisdictions and pinpoint the place of greatest harm in this multistate libel case in the district where the plaintiff was domiciled, absent strong countervailing circumstances. Hatfill v. Foster, 415 F. Supp. 2d 353, 364?65 (S.D.N.Y. 2006) (emphasis added); see also Gilmore v. Jones, N0. 3: 8-cv-00017, at *40-41 (W.D. Va. Mar. 29, 2019) (?the Court ?nds that the Supreme Court of Virginia, in extending lex loci delicti to multi-defendant, multi-state Internet tort cases, would de?ne the ?place of the wrong? as the state where the plaintiff is primarily injured as a result of the allegedly tortious online content,? and holding that a claim arose in the plaintiff?s domicile state). The Restatement (Second) of Conflicts is in accord. Section 150 recites that ?The rights and liabilities that arise from defamatory matter in any one edition of a . . . newspaper . . . or similar aggregate communication are determined by the local law of the state which . . . has the most signi?cant relationship to the occurrence and the parties.? Rest. (Second) Conflicts 150. Moreover, ?the state with the most signi?cant relationship ?will usually be the state where the plaintiff was domiciled at the time if the matter complained of was published in that state.? Sarver v. hartier, 813 F.3d 891, 898 (9th Cir. 2016); see also Hanley v. rib. Publ?g Co., 527 F.2d 68, 70 (9th Cir.1975) (?In cases of defamation, [the Second Restatement factors] normally would call for application of the law of the plaintiff?s Here, the alleged defamation plainly arose outside of Virginia. Plaintiff is domiciled in California. (Compl. ll 8.) He does not own property in Virginia. He does the vast majority of his work as a Hollywood actor in California. He seeks redress for injuries to his 1221350.: 5 professional and personal reputation?both of which are primarily based on the opinions of people he works and lives with in California. (Id. 111] 5, 8, 73, 82, 83, 93, 104.) Underscoring the conclusion that Virginia is not the place where any defamation arose, none of the relevant conduct took place in Virginia. To the best of her knowledge, Ms. Heard has never set foot in Virginia. (Heard Decl.1l 56.) Ms. Heard was never even in direct contact with any Washington Post employee, let alone one with an of?ce in Virginia. (1d. ?ll1l53-55.) Nor did she make any request that her Op-Ed be distributed in any print edition of the newspaper that might be circulated in Virginia. (Id. 11 55.) B. Vigginia Is A Cornnlettelvr Inconvenient Forum Virginia courts also look to whether another forum would be more convenient: The principle of forum non conveniens is simply that a court may resist imposition upon its jurisdiction even whenjurisdiction is authorized by the letter of a general venue statute. These statutes are drawn with a necessary generality and usually give a plaintiff a choice of courts, so that he may be quite sure of some place in which to pursue his remedy. But the open door may admit those who seek not simply justice but perhaps justice blended with some harassment. A plaintiff sometimes is under temptation to resort to a strategy of forcing the trial at a most inconvenient place for an adversary, even at some inconvenience to himself. Gulf Oil Corp. v. Gilbert, 330 US. 501, 507 (I 947) (emphasis added). ?The forum chosen as a result of [the forum non conveniens analysis] should be one which insures the ability of the plaintiff to prosecute his cause free from any suggestion of abuse of the venue provisions.? N0ifolk& W. Ry. Co. v. Williams. 239 Va. 990, 393 (1990). In Norfolk Western Railway Co. v. Williams, the Virginia Supreme Court articulated the circumstances that must be considered in a forum non conveniens analysis. Those factors include relative ease of access to sources of proof; availability of compulsory process for attendance of unwilling, and the cost of obtaining attendance of willing witnesses; possibility of view of premises, if view would be appropriate to the action; and all other practical l221850.l 6 problems that make trial of a case easy, expeditious and inexpensive.? Id. at 393 (citing Gulf, 330 US. at 508). Thus, critical to the forum non conveniens analysis is an understanding of what would be litigated on the merits of Plaintiff?s action. 1. 31:2 Primarv Issue In Dispute ls Whether Mr. Depp Abgsed Ms. Heard In California. Australia. Japan. Or The Bahamas For his Complaint, Mr. Depp contends that Ms. Heard defamed him by authoring an Op- Ed. Ostensibly vexed by the absence of any literal falsehoods in the Op?Ed (Compl. 1-2, 20- 23), Plaintiff takes issue with an implication he has imagined is contained within the Op-Ed, namely, that he had abused Ms. Heard during the course of their marriage. (Id. 3-4, 22-23.) Setting aside whether any such implication is reasonably inferable, the only factual questions that will require resolution in this action are whether, in fact, Mr. Depp actually abused Ms. Heard (rendering even the imagined inferences truthful) and whether Ms. Heard acted with malice. See Jordan v. Kollman, 269 Va. 569, 575, 612 203, 206 (2005) (?In Virginia, the elements of libel are (1) publication of (2) an actionable statement with (3) the requisite intent. True statements do not support a cause of action for defamation?) (internal citations omitted).2 Mr. Depp?s Complaint proclaims that he could not have abused Ms. Heard because several witnesses who saw Ms. Heard after one reported incident later claimed that they had not seen evidence of abuse on that occasion. (See Compl. 16, 17, 27, 30, 33-60.) This confusion suffers from two flaws of logic: First, notwithstanding the fact that there is ample evidence that Mr. Depp abused Ms. Heard on that occasion?including suf?cient evidence for a court to grant Ms. Heard a domestic violence restraining order?there were numerous other occasions where Mr. Depp abused Ms. Heard. (See Heard Decl. 1W 5-42.) Second, it does not follow that because 2 Of course, whether Ms. Heard?s statements constitute opinion is a separate question. l22l850.l 7 certain individuals may now claim not to have seen bruises on Ms. Heard, that she was not in fact abused. For purposes of adj udicating the Motion to Dismiss, the only state with a nexus to the truth of Mr. Depp?s abuse?which will prove the truth or falsity of the implication Mr. Depp alleges Ms. Heard made in her Op-Ed?is California (setting aside Australia, Japan, and the Bahamas). That is because California is where all of the witnesses are located. Indeed, that is true as to those ?witnesses? who Mr. Depp claims may somehow disprove his abuse, as Mr. Depp concedes that each of the 13+ ?witnesses? identi?ed in the Complaint (and therefore a central source of proof for his claim) is located in California. (See Comp]. l6, 17, 27, 30, 33- 60.) California is also the location of the other witnesses who directly observed Mr. Depp?s abuse of Ms. Heard. (Heard Decl. 111] 19-20, 23, 27-33, 36-40.) The vast majority of these occasions took place in Los Angeles, California, where Mr. Depp would alternate between sober and inebriated states, between lucid and delusional thinking, and between remorse and violence with Ms. Heard. (1.51.1111 5-42.) Mr. Depp and his assistants would apologize to Ms. Heard the next morning for Mr. Depp?s behavior, appalled at what had happened the night before. (1d.1]1] 8, 12.) Ms. Heard would frequently cover for Mr. Depp, brushing her hair to conceal bruises and lying to her parents to prevent them from intervening. (Id. 1H 45.) Ms. Heard had to frequently live apart from Mr. Depp?at one point in their marriage for a month straight?in order to hide from Mr. Depp when he was in one of his delusional or violent moods. (1d. 14, 35.) Friends, acquaintances, staff and doctors: all witness to Mr. Depp?s behavior, all located in California. (Id. 6?1 1, 19-20, 23, 27-33, 36-40.) If litigation is a vehicle for ascertaining the truth, it is necessary for this litigation to proceed in California where the witnesses can be heard in person. Those witnesses are outside of this Court?s subpoena power. 1221850.l 8 Similarly, evidence regarding the effects of Ms. Heard?s Op-Ed on Mr. Depp?s professional reputation?the primary source of his damages claim?will necessarily focus on Los Angeles, California, the place where Mr. Depp regularly conducts his business as an actor. (See Compl.1?l 5, 7l 73, 82, 83, 93, 104.) While a plaintiff?s choice of forum may have an initial presumption of correctness, ?the weight afforded that choice is diminished when, as here, the action has at best only a technical, formal connection with the original court chosen.? Williams, 239 Va. at 395-96. Here, none of Mr. Depp?s abuse of Ms. Heard even allegedly took place in Virginia. Based on the issues raised by Mr. Depp?s Complaint, the factual questions to be resolved at trial are: i) the credibility of the various parties and witnesses he has identi?ed in his Complaint (all of whom are located in California); ii) the veracity of Defendant?s account of Plaintiff?s abusive episodes given the layout and damage done to the physical premises where the abuse occurred (in Los Angeles, California); and damages, if any, to Plaintiff?s professional reputation amongst the entertainment industry (primarily located in Los Angeles, California). Therefore, as discussed below, every factor in the forum non conveniens analysis weighs in favor of ?nding that Virginia is an inconvenient forum. California has a far greater nexus to the issues for resolution in this action, and proceeding in Virginia would interpose all sorts of practical and substantive dif?culties on the parties, making it impossible to conclude that Plaintiff chose Virginia as a venue for any reason other than harassment. l22l850.l 9 2. Litigating In Virginia Would Make It Prohibitivelv Dif?cult For Th_c ?irties To Access The Relevant Sources Of Proof The ?rst factor in the forum non conveniens analysis is whether the forum provides ready and inexpensive access to the sources of proof in the litigation. Williams, 239 Va. at 395. ?Clearly an important indicator of good cause supporting transfer is substantial inconvenience to parties or witnesses.? Id; see also Hotung v. Hotung, No. 130264, 2014 WL 576178, at *3 (Va. Feb. 7, 2014) (reversing denial of motion to dismiss on forum non conveniens grounds because, inter alia, testify in person in this case, both the parties and the witnesses would have been required to engage in complicated international travel from Hong Kong to Fairfax, Virginia. The expense and inconvenience of appearing at trial would have increased proportionally with distance compared to Williams?). Here, as previously discussed, every party and relevant witness resides in LosAngeles, California: Mr. Depp (Compl. 11 Ms. Heard (id. 11 Ms. Heard?s friends and family Mr. Depp has accused of participating in a hoax (id. 11 54); the building residents and employees who claimed to have witnessed (or not witnessed) Ms. Heard?s physical conditions (id. 1111 36, 38, 40- 56); the security guards employed by Mr. Depp (id. 1111 30); the police officers who arrived in response to a 91 1 call by i0 Tillet Wright, who overheard Mr. Depp abusing Ms. Heard (id. 11 60; Heard Decl. 1111 36, 38); Mr. Depp?s assistant who witnessed and apologized for his abuse (Heard Decl.11 and Mr. Depp?s professional representatives who might testify as to how Mr. Depp?s career and reputation have changed following the publication of the Op-Ed (see, Comp]. 111 5,71, 73, 82, 83,93,104). Of course, Los Angeles, California is significantly farther ?'om Fairfax, Virginia than the distance that proved dispositively inconvenient in Williams, and the dozens of witnesses who would be needed at any fair trial would be substantially inconvenienced in any attempt to [2218501 10 provide live testimony, if not outright precluded from being compelled to testify. (See Compl. 1111 36, 38, 40-56; Heard Dec1.1]1i 1, 19-20, 23, 27-33, 36-40.) As the Virginia Supreme Court recently reaf?rrned, in Williams, it had ?reversed a circuit court?s denial of a motion to transfer under Code 8.01?265 largely because of the inconvenience to the witnesses in having to travel from Roanoke (where the plaintiff sustained personal injury) to Portsmouth (where he ?led his complaint)? See Hotung, 2014 WL 576178, at The Williams court had explained: By holding a trial in Portsmouth, the witnesses faced the inconvenience of being away from families, homes, and jobs while traveling to Portsmouth to testify, regardless of who made the arrangements or paid the expenses. Not one potential witness was from Portsmouth and would be spared this imposition. The alternative was the presentation of deposition testimony, a less desirable procedure which deprives the trial judge and jury of the ability to evaluate the witnesses in person. Williams, 239 Va. at 395 (emphasis added). The case at bar presents a stronger case for dismissal on forum non conveniens than even Williams, as the inconvenience to the potential witnesses in this action would be far greater given the larger distance between Los Angeles and Fairfax County. 3. Virginia Courts Cannot Comnel Cgliforr? Witnesses To Appear At Trial, Depriving The Parties The Ability; To Confront Accusers, Aecompliees Or Uncooperative Witnesses As discussed above, numerous witnesses would undoubtedly refuse to undertake such travel for purposes of hearings, depositions, or trial if this case was litigated in Fairfax County. Moreover, the neighbors, guards, friends, and other purported witnesses who are not parties to the case could choose not to cooperate and thereby frustrate efforts to obtain their attendance at trial as Virginia cannot compel it. See Yelp, Inc. v. Hadeed Carpet Cleaning, Inc, 289 Va. 426, 433, 770 440, 443 (2015) Rules do not recognize the existence of subpoena power over nonresident The ability to compel witness attendance at trial was a critical concern of the Williams court, and is all the more problematic here given the likelihood 12218501 11 that neutral, disinterested witnesses (including those Mr. Depp identi?es in his Complaint) will be unwilling to bear the inconvenience and expense to testify at trial unless compelled. Thus, far beyond being a matter of ?mere inconvenience,? litigating in Depp?s chosen forum of Virginia would actually deprive Defendant of the ability to confront witnesses at trial. That signi?cant prejudice weighs heavily in favor of dismissal under Williams. 4. ?ue Onlv Relevant Physical Premises Are In Los Angeles, California In addition to the inconvenience of procuring the witnesses Mr. Depp has identified in his Complaint, it would be impossible for a trier of fact located in Fairfax County, Virginia to view the physical premises that Mr. Depp has put at issue in his Complaint. For example, Mr. Depp alleges that he could not have injured Ms. Heard when he threw his cell phone and struck Ms. Heard in the face in light of the physical layout of the apartment and the view that his security guards had of Ms. Heard after the fact. (Compl.1l 33.) Mr. Depp also claims that security camera footage following one incident of abuse disproves Ms. Heard?s claim?either way, the proof will necessarily depend on the layout of the physical premises in Los Angeles, California. (1d. 51, Likewise, Mr. Depp le? ample evidence of his delusional and violent states in the broken objects and furniture he had shared with Ms. Heard in his Los Angeles apartments. (Heard Decl.1l1l 27, Ex. 12, 36-40, Ex. 29.) Such physical evidence would only be accessible to a trier of fact in California, not Virginia. Thus, if forced to litigate in Virginia, Defendant would suffer even more prejudice to her ability to fully present her defenses. Consequently, this factor also weighs in favor of dismissal on forum non conveniens grounds. 5. Litigating In California Would Allow For An Early Motion A_nd Disposition Of Mr. Dean?s Claims. Lastly, litigating in Virginia would preclude Ms. Heard from asserting her substantive right to require Mr. Depp to prove his likelihood of prevailing on the merits before litigating 221850l 12 further under California?s statute. See Maloney v. 3Media, Inc, 94 F. Supp. 3d 1128, 1132 (CD. Cal. 2015), 853 F.3d 1004 (9th Cir. 2017) (?Although framed as a rule of state procedure, California's statute protects substantive rights and thus applies in federal court.?) (citing Newsham v. Lockheed, 190 F.3d 963, 973 (9th Cir. 1999)). In California, Ms. Heard could require Mr. Depp to put forward evidence that would demonstrate, on pain of dismissal, that he is likely to prevail on his claim, to prove that he had never abused Ms. Heard. See Cal. Civ. Proc. Code 425.16; Stewart v. Rolling Stone LLC, 181 Cal. App. 4th 664, 675 (2010), as modi?ed on denial of reh?g (Feb. 24, 2010) (under California law, a special motion to strike may be ?led, and if defendant shows that the challenged conduct arises out of ?protected activity,? ?the burden shifts to the plaintiff to establish, with admissible evidence, a reasonable probability of prevailing on the While Virginia?s recently amended statute does provide for immunity from suit for certain kinds of statements, Virginia law does not place an early burden of af?n?natively proving a plaintiff?s likelihood of prevailing on their underlying claims at an earlyjuncture in litigation. Nor would Ms. Heard (for the reasons set forth above) be able to adduce in a Virginia- based motion the same quantum of evidence that she would be in a Califomia-based motion. Because there is overwhelming evidence of Mr. Depp?s abuse of Ms. Heard (and on multiple occasions, notjust the one instance Mr. Depp is attempting to call into question in his Complaint), Ms. Heard?s motion applying California law would undoubtedly preclude Mr. Depp?s claims from going any farther. 3 Ms. Heard has ?led a Combined Motion to Dismiss and Plea in Bar in which the laws of both California and Virginia are preserved out of an abundance of caution. This Motion to Dismiss is submitted to the Court ?rst because this question of venue should be resolved first. 1221850.: 13 IV. CONCLUSION For the foregoing reasons, Ms. Heard respectfully requests that this Court dismiss this case pursuant to Va. Code l22l8501 Dated this ll'h day of April 20l 9. Respectfullv submitted. By: By: C/w Eric M. George, Esq. (pro hae vice application pending) Richard A. Schwartz, Esq. (pro hae vice application pending) BROWNE GEORGE ROSS LLP 212] Avenue of the Stars, Suite 2800 Los Angeles, California 90067 Telephone: (310)274-7100 Facsimile: (310) 275-5697 eueorue? burlirnmom h2r?rm.com ounseL for endam Amber Laura Heard Tim?i?y J. McEvoy, Esq. (VSB No. 33277) Sean Patrick Roche, Esq. (VSB No. 7l412) PLLC 4100 Monument Corner Drive, Suite 420 Fairfax, Virginia 22030 Telephone: (703) 273-8898 Facsimile: (703) 273-8897 smclie?ti?cameronmcet as .com Counsel for Defendant Amber Laura Heard CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 111h day of April 2019, I served the foregoing via First Class Mail (postage prepaid) and electronic mail upon the following: Benjamin G. Chew (VSB No. 29113) Elliot]. Weingarten (pro hac vice application forthcoming) Andrew C. Crawford (VSB 89093) BROWN RUDNICK LLP 601 Thirteenth Street, NW. Washington, DC. 20005 Telephone: (202) 536-1700 Facsimile: (202)536-1701 Email: lichen -"u-hrou nrudn ickcom Adam R. Waldman THE ENDEAVOR LAW FIRM, PC. 1775 Avenue, N.W., Suite 350 Washington, DC 20006 Brittany Whitesell Biles (pro hac vice application forthcoming) STEIN MITCHELL BEATO MISSNER LLP 901 Fifteenth Street, NW. Suite 700 Washington, DC. 20005 Telephone: (202) 601-1602 Facsimile: (202) 296-8312 Email: Counsel for John C. Depp, 11 Timothy J. McEvoy, Esq. (VSB No. 33277) l221850.l 15 VIRGINIA: IN THE CIRCUIT COURT OF FAIRFAX COUNTY JOHN C. DEPP, 11 Plaintiff, v. Civil Action No.: 1 9-0002911 AMBER LAURA HEARD Defendant. DECLARATION OF AMBER LAURA HEARD Lit bx) DECLARATION OF AMBER LAURA HEARD 1, Amber Laura Heard, declare as follows: 1. I am a party in the above-entitled action. I have ?rsthand, personal knowledge of the facts set forth below and if called as a witness could competently testify thereto. 2. I ?rst met John C. Depp, 11 (?Johnny?) in 2009, and we started dating around the end of 201 1 or early 2012. For the ?rst year of our relationship, Johnny was sober and our relationship blossomed. We were in love. 3. About a year into our relationship, I began to witness Johnny abusing drugs and alcohol or would notice that he was drunk or high. He frequently went in and out of drug and alcohol dependency medical care, including 24-hour live-in medical aid for the last three years of our relationship. On some occasions, when Johnny simultaneously used both illegal narcotics and prescription medications I have had to get him medical attention. Whenever he was using, I worried for both of us. He would become a totally different person, often delusional and violent. We called that version of Johnny, ?the Monster.? 4. Johnny often would not remember his delusional and violent conduct after he came out of his drunk or medicated states. Eventually, as his abuse continued, I began to document the injuries and destruction with photographs or videos so that I could show Johnny what he had done while in his altered state. Because I loved Johnny, I had believed his multiple promises that he could and would get better. I was wrong. Late 2012/Early 2013, Los Angeles, California: 5. The ?rst time Johnny hit me was at the end of 2012 or in early 2013. We were in Los Angeles, California, talking about a tattoo, and I laughed at something Johnny had said. I thought he had made ajoke. He responded by slapping me across the face. Each hit was harder than the one before. The third hit knocked me to the ?oor. I did not respond physically or verbally; froze, whether out of fear or shock, and then I went home without saying a word. I thought about leaving Johnny then. I237778J 439-3li ONDOONJCBUI March 8, 2013, Los Angeles, California: 6. Johnny hit me again on March 8, 2013 in my Los Angeles home. This wasjust one unfortunate incident in a series around that time where Johnny would become volatile and violent when under the in?uence of drugs and alcohol, then contrite and apologetic when he would sober up. On this particular incident, Johnny was getting drunk and high alone, and was angry that I had hung up a painting given to me by someone I had formerly dated. He tried to set ?re to?the paining the following morning. Johnny?s team and asked my sister Whitney to come over to try to intervene with Johnny, which she did. At some point after she left, Johnny resumed his ?ght with me, and hit me so hard that blood from my lip ended up on the wall. Attached hereto as Exhibit 1 is a true and correct copy of a text message exchange Johnny and 1 had the following Tuesday. On my phone, I had labeled Johnny as ?Steve,? and on his phone, he labeled me ?Slim,? in part to protect our privacy if anyone else came into possession of our phones. May 24, 2014, Flight from Boston, Massachusetts to Los Angeles, California: 7. On or about May 24, 2014, I met Johnny in Boston, and we both ?ew from Boston to Los Angeles on a private plane. Johnny appeared to have been drinking heavily and was holding a bottle of champagne when 1 met him in the morning. On the ?ight, Johnny ordered the ?ight attendants to give him an oxygen tank, and drank heavily. Johnny?s handlers told me that he was upset that was ?lming a movie with a romantic scene with James Franco the day before. Soon, Johnny began to throw objects at me. Instead of reacting to his behavior, I simply moved seats. That didn?t stop him. He provocatively pushed a chair at me as I walked by, yelled at me, and taunted me by yelling out the name ?James Franco.? At some point, I stood up, and Johnny kicked me in the back, causing me to fall over. Johnny threw his boot at me while I was on the ground. Johnny continued to scream Obscenities until he went into the plane bathroom and passed out locked in the bathroom for the remainder of the ?ight. Attached hereto as Exhibit 2 is a true and correct copy of text messages exchanged between me and Johnny (labeled ?Steve?) dated May 25, 2014. in them, Johnny admitted, ?Once again, I ?nd myself in a place of shame and regret. Of course, I am sorry. I really don?t know why or what happened. But will never do it again.? 1237778.! -2- AWN Johnny?s assistant Stephen Deuters (labeled ?Stephen? on my phone) also texted me on May 25, 2014 to pass along Johnny?s apologies for his behavior during the flight. Stephen admitted that Johnny ?was appalled. When I told him he kicked you, he cried.? Attached hereto as Exhibit 3 is a true and correct copy of the text message exchange between me and Deuters dated May 25, 2014, in which Deuters con?rmed my memory of what took place and relayed messages from Johnny to me. Speci?cally, Exhibit 3 was generated by a forensics expert who extracted these text messages from my phone in 2016 to disprove allegations that 1 had somehow doctored or fabricated these messages. August 2014, Bahamas: 9. In August of 201 4, Johnny and I took a trip to the Bahamas to try to help Johnny detox under the supervision of his full?time, live-in nurse, Debbie Lloyd. While we were in the Bahamas, Johnny had a number of manic episodes requiring medical attention that Debbie was unable to manage on her own, so we flew in Dr. David Kipper, Johnny?s private doctor, to help manage his increasingly severe episodes. 10. On August 17, 2014, while in the Bahamas, Johnny and I got into a ?ght during which Johnny kicked and pushed me to the ground, slapped me with an open hand, and grabbed me by the hair. During his attack, Johnny kicked the door so hard that it splintered Attached hereto as Exhibit 4 are true and correct copies of photographs of the broken door. 1 l. I contacted Dr. Kipper and his assistant Debbie Lloyd for help with Johnny and managing his complex drug regimen. They both arrived on the night of August 17, 2014, and observed my injuries. We all continued to monitor Johnny for several days thereafter. Attached hereto as Exhibit 5 are true and correct copies of text messages I exchanged with Dr. David Kipper and his assistant Debbie Lloyd during that time frame. December 17, 2014, Los Angeles, California: 12. On December 17, 2014, after Johnny had a particularly violent episode, he apologized for his behavior, calling himself a ?fucking savage.? Attached hereto as Exhibit 6 are true and correct copies of screenshots of that text message exchange (again, Johnny is ?Steve?). 123777111 -3- January 25, 2015, Tokyo, Japan: 13. On or around January 25, 2015, Johnny and I were in a hotel room in Tokyo, Japan. Johnny shoved me, slapped me, and grabbed me by my hair. When I tried to stand up, Johnny muscled me back to the floor. He stood over me and yelled as I cried on the floor. March 2015, Australia: 14. On March 3, 2015, I arrived in Australia to meet Johnny after I had been ?lming a movie. It was the ?rst time I had seen Johnny in about a month, and I noticed that Johnny had lost a lot of weight and was behaving erratically. At some point in the next few days, I watched Johnny pull out what I later found out was a bag of MDMA (ecstasy); even though Johnny was supposed to be clean at that time, Johnny told me that I had not explicitly forbidden him from taking ecstasy. The argument heated up, and Johnny pushed me, slapped me, and shoved me to the ground before I retreated to a locked bedroom and went to sleep, as I wasjet-lagged from the travel. 15. When I woke up the next morning, I went downstairs to ?nd that Johnny was still awake, and that he had stayed up all night, having taken about eight MDMA pills. He was also drinking again. We got into a fight that Johnny made physical, and I barricaded myself in one of the rooms. That didn?t stop Johnny from busting through the door of the room I was in. By nightfall, Johnny had hit me multiple times, shoved and pushed me to the ground, choked me, and spit in my face. Johnny then handed me a liquor bottle that he was drinking from, and asked me, ?What are you going to do?? I threw the bottle on the ?oor. Johnny responded by starting to throw cans and unopened glass bottles at me. I wanted Johnny to go to sleep, in hopes that he would sober up. Instead, he began to ?ght with me about our upcoming marriage. I observed as Johnny then called multiple lawyers and representatives, including Tracey Jacobs, then his agent at the United Talent Agency. 16. That night, Johnny shoved me into a ping pong table that collapsed underneath me. Johnny threw bottles through the window panels of a glass door, breaking two panes, and leaving glass everywhere. Johnny then grabbed me, gripping my body and nightgown. He tore the nightgown off, and at some point, I was naked and barefoot, covered in alcohol and glass. Johnny l237778 I -4- 43-grabbed me by my hair and choked me against the refrigerator in the kitchen. I tried to stand myself up but I was sliding around the glass-strewn ?oor and countertop. Johnny threw me away from him, and I tried to run away as Johnny continued to throw objects and alcohol at me. In one of the most horri?c and scariest moments of this three-day ordeal, Johnny grabbed me by the neck and collarbone and slammed me against the countertop. I struggled to stand up as he strangled me, but my arms and feet kept slipping and sliding on to the spilled alcohol and were dragged against the broken glass on the countertop and ?oor, which repeatedly slashed my feet and arms. Scared for my life, I told Johnny, ?You are hurting me and cutting me.? Johnny ignored me, continuing to hit me with the back of one closed hand, and slamming a hard plastic phone against a wall with his other until it was smashed into smithereens. While he was smashing the phone, Johnny severely injured his ?nger, cutting off the tip of it. I did not throw a vodka bottle?-?or any other kind of bottle?at Johnny, nor did I cause that injury to Johnny?s ?nger. Once I was able to get away, I barricaded myself in an upstairs bedroom, and tried to go to sleep. 17. On the third day of Johnny staying awake without sleeping, I came downstairs to ?nd numerous messages Johnny had written to me around the house, on the walls and on my clothes, written in a combination of oil paint and the blood from his broken and severed ?nger. Johnny also urinated all over the house in an attempt to write messages. I was only able to capture a few pictures of these messages because I had barricaded myself in my bedroom, even though they had been spread all over the house. Attached hereto as Exhibit 7 are true and correct pictures of messages Johnny had smeared in his blood and paint in the bathroom adjoining the bedroom I had barricaded myself in. 18. By the time I got the security guards to come upstairs, it had been almost 24 hours now since Johnny had cut off part of his ?nger. His team was worried about the blood he had lost, and so he was rushed to hospital. Afterwards, I ?ew back to Los Angeles, and Johnny returned to his separate house in West Hollywood. I had a busted lip, a swollen nose, and cuts all over my body, which friends, family, medical professionals, and co-workers all witnessed. To this day, I still have scars on my arms and feet from this incident. Attached hereto as Exhibit 8 is a true and correct copy of a picture of scars that are still on my left arm from this incident. 237778 I -5- March 2015, Los Angeles, California: 19. Later in March, 2015, Johnny and I were in Los Angeles, California. Johnny?s hand was still in a cast following the incident in Australia. After becoming enraged, he began to destroy personal preperty all over the house, including my belongings in my closet. My sister Whitney was there, so when Johnny lunged to hit me, Whitney placed herself between us. Johnny turned his attention to Whitney, who was standing on the top of a ?ight of stairs, and moved on her. Acting in defense of my sister, as I was scared for her physical safety, I punched Johnny in the face to draw his attention away from her. That was the only time I ever hit Johnny. At that point, house security intervened and separated us. Attached hereto as Exhibit 9 are true and correct copies of a text message exchange Whitney had with Kevin Murphy (the house manager) following that incident. Attached hereto as Exhibit 10 is a true and correct copy of excerpts of the transcript of my deposition dated August 13, 2016, in which I previously testified under oath about that incident. Attached hereto as Exhibit 1 is a true and correct copy of a video excerpt of that deposition testimony. 20. After he attacked me and my sister in March of 2015, Johnny seemed to get clean and quit using everything other than his prescription medications. For some months, things were peaceful. Then, in July of 20] 5, Johnny started to drink wine and smoke marijuana again. August 2015, Thailand and Malaysia: 21. In August of 20] 5, Johnny and I traveled to Southeast Asia. While on the Eastern Oriental train, Johnny picked a ?ght with me, and started hitting and pushing me against a wall by grasping my throat and holding me there. I remember being afraid that Johnny might not know when to stop, and that he might kill me. - November 26, 2015, Los Angeles, California: 22. On November 26, 2015, which was Thanksgiving, Johnny and were in Los Angeles, and got into another physical ?ght. Johnny ripped my shirt, and threw me around the room. He threw a wine glass and a heavy glass decanter at me, which luckily missed. At one point, Johnny pushed me, and I fell over the back of a lounge chair and hit my head against a brick 1237713.] -6- UI-PUJN wall. I later learned that I had gotten a sizeable lump on the back of my head, and that my lip had busted open. December 15, 2015, Los Angeles, California: 23. On the night of December 15, 2015, I had plans to meet with my friends Raquel ?Ro?cky? Pennington and Melanie at Johnny?s and my penthouse in Los Angeles. Before they arrived, Johnny picked another ?ght with me. He threw another decanter at me, knocked items around the room, and punched the wall. He slapped me hard, grabbed me by my hair, and dragged me from a stairwell to the of?ce to the living room to the kitchen to the bedroom and then to the guest room. In the process, he pulled large chunks of hair and scalp out of my head. 24. Hoping to avoid the violence, I tried to calm Johnny down, and then went upstairs to try to remove myself from the situation. Johnny followed me, hit me in the back of my head, grabbed me by my hair again, got in front of me on the steps, and then dragged me by my hair up the last few steps. At the top of stairs, Johnny shoved me twice, which made me fear I would fall. I told Johnny that he had broken my wrist in an attempt to get him to stop. 25. Johnny kept hitting me, and each time he knocked me down, I chose to react by simply standing up and looking him in the eye. Johnny responded by yelling, ?Oh, you think you?re a fucking tough guy?? He reeled back and head-butted me in my face, bashing my nose, which immediately began. bleeding, sending searing pain through my face. I instantly started tearing up, and I thought that I would have to go to the hospital. I told Johnny I wanted to leave him, and that I would call the police if he ever touched me again. When I began to walk away toward the guest apartment, he responded by pushing me, then grabbed me and pulled me from one room to the next, gripping me by my hair. 26. By the time Johnny had dragged me into the upstairs of?ce, I told Johnny that was leaving him, since I could not put up with his behavior any longer. Johnny reacted by grabbing me by my throat, pushing me down to the ground, and punching me in the back of my head. He grabbed me by my hair, slapping me in the face, and screaming at me something like, fucking will kill you l?ll fucking kill you, you hear me?? There were chunks of my hair everywhere and indentations in the carpet where I was dragged. 1237773.] ALAIN some point, the ?ght continued onto a bed. Johnny got on top of me with his knee on my back and the other foot on the bedframe, while repeatedly punching me in my head, and he screamed?as loudly as I?ve ever heard him scream??I fucking hate you? over and over again. The bedframe splintered under the weight of the pressure of his boot. Johnny hit me with his closed ?sts, and I remember being unable to hear myself screaming because he had pushed my face into the mattress. I screamed as loudly as I could, hoping Johnny would realize he was severely hurting me. For a while, I could not scream or breathe. I worried that Johnny was in a blacked-out state and unaware of the damage he was doing, and that he could actually kill me. To this day, I do not know how the ?ght ended. Attached hereto as Exhibit 12 are true and correct copies of photographs of the hair he pulled out of my head and the bedframe he splintered during the course of' this violent episode. 28. The ?rst thing I remember after the ?ght was Rocky coming into my room, and screaming ?Oh my god! Oh my god! Oh my god!? as she saw me. Together with Melanie, who had also arrived, we called Erin Boeurum, a nurse, who instructed us on how to conduct a concussion check over the phone. I had severe headaches and other pain for at least a week afterward. 29. I later learned, that when Rocky and Melanie arrived, broken glass and chunks of hair were strewn across the downstairs of the penthouse. True and correct copies of pictures of my injuries from that occasion are attached hereto as Exhibit 13. 30. Johnny also had written a message on the countertop in our kitchen in gold sharpie that said, ?Why be a fraud? All is such bullshit.? A true and correct copy of a picture of that message is attached hereto as Exhibit 14. 31. That night, I texted my publicist Jodi Gottlieb (who lives in Los Angeles) to let her know that I had been badly injured, and that I might not be able to make an appearance on the Late Show that was scheduled for the following day depending on the extent of my bruising. I told her, had an accident tonight Jodi. I?m really bruised and might have a black or two same with my nose. . . . But won?t know how bad the bruising is until the morning.? I told Jodi that I had had an accident because, like many who experience abuse, I was afraid of exposing this aspect 1237773 1 -8- relationship with Johnny to her or the world. A true and correct copy of the text message I sent Jodi is attached hereto as Exhibit 15 (my message in white, Jodi?s in blue). I asked Melanie and Rocky to help cover up the bruises, bleeding, and swelling so 1 could make it to the Late Show appearance without exposing Johnny. 32. A day or two later, I went to Dr. Kipper?s of?ce to get a concussion check follow- up examination. Lisa Beane, the nurse who saw me followed me out to the parking lot, and told me that she recognized that I ?was in trouble,? and advised me to call her if I was attacked again. 33. Attached hereto as Exhibit 16 are text messages I exchanged with Rocky a few days later, on December 20 and 21, 2015, in which we discussed the attack from the night of December 15, 2015 (my messages are in white, hers are in blue). April 21, 2016, Los Angeles, California: 34. On April 21, 2016, was hosting my own 30lh birthday party at our penthouse. Johnny arrived to the party late and inebriated, and, after our guests had left, we started to ?ght. During the course of that ?ght, Johnny threw a magnum-sized bottle of champagne against the wall, and shattered a glass against the floor. Johnny grabbed me by the shoulders, pushed me onto the bed, and blocked the bedroom door when I tried to leave. He grabbed me by my hair, and violently shoved me to the floor. I later applied for a domestic violence restraining order, and cited that incident as part of the reason I was afraid of Johnny. His lawyers later deposed me and asked about that incident. Attached hereto as Exhibits 17, 18, and 19 are true and correct copies of excerpts of the transcript of my deposition dated August 13, 2016, in which I previously testi?ed under oath about that incident. Attached hereto as Exhibits 20, 21, and 22 are true and correct copies of the video excerpts of that deposition testimony. 35. Johnny and I did not speak for a month after my birthday. Nonetheless, during that month, I found myself unable to sleep through the night because I was afraid that Johnny would come home and instigate a ?ght. I even inquired about the possibility of having my locks changed because Johnny and his team had keys to the house, and 1 never knew when?or in what state?he would come home. 1237773.: -9- AWN May 21, 2016, Los Angeles, California: 36. On May 21, 2016, Johnny and I met at our home in Downtown Los Angeles to discuss our relationship. His behavior was erratic, and as I felt increasingly unsafe, I texted Josh and Rocky?who lived next door?to have them come over. I also called our mutual friend i0 Tillet Wright to mollify Johnny. Johnny started to scream at i0 over the phone, left to go upstairs, then came back downstairs and grabbed my phone, threatening i0 and calling him names. At some point, i0 yelled at me to ?get out of the house.? When Johnny heard that, he wound up like a baseball pitcher and threw the phone in my face, as hard as he could. I yelled, ?You hit my face,? and started to cry. I had been sitting on the couch, cross-legged, and Johnny grabbed my hair and started to slap, shake and yank me around the room while I continued to scream. I was questioned about this t0pic during my August 13, 2016 deposition. Attached hereto as Exhibits 23 and 24 are true and correct copies of excerpts of the transcript of my deposition dated August 13, 2016, in which I previously testified under oath about that incident. Attached hereto as Exhibits 25 and 26 are true and correct copies of the video excerpts of that deposition testimony. 37. Rocky had a key to our penthouse, and let herself in. When she entered, Johnny noticed, turned, and let go of me, allowing me to retreat to the comer sofa. Both Johnny and Rocky ran toward me at the same time. Rocky threw herself in between Johnny and me, and raised her arms. Johnny ran into Rocky, and pushed her arms down. She calmly planted herself and said, ?Stop, Johnny.? Johnny grabbed Rocky?s arms again and threw them to her sides. I collapsed onto the couch, with Johnny standing over me. Johnny repeatedly screamed at me, ?Get the fuck up, Amber.? 1 did not move, and Johnny got closer screaming ?Get the fuck up, Amber? about 10 times. At some point, Rocky got between us, and placed her arms over me protectively. 38. The door opened and someone yelled, ?Boss! Boss!? Jerry Judge and Sean Bett, Johnny?s private security guards, came in. Johnny stood up and then I stood up. I ran to the corner of the room and said, ?Jerry, he hit me, if he hits me one more time I'm calling the police! I will call the police!? At the time, I did not realize that i0 had been on speakerphone since Johnny had thrown my phone at my face. I later learned that, at some point, i0 had hung up and called 911. 12317711.1 -10- Ul-bbJN 39. Johnny smashed various objects around the house with a wine bottle as he left. Josh?Rocky?s ?ance?entered and told Rocky and me to stay in PH 1 (the neighboring Penthouse Josh and Rocky lived in). Josh met Johnny in the hallway, where they squared off. Johnny did not touch Josh. Instead, Johnny smashed more items in the hallway, spilled wine everywhere, and kicked a hole in a solid door. Johnny then demanded to be let into PH 5, my apartment where all of my belongings were at the time. Either Jerry or Sean opened the door, despite my repeated requests not to let Johnny in due to his longstanding history of destroying my possessions when he would get angry. After entering, Johnny destroyed everything he could and chased Liz Marz out of the penthouse carrying a wine bottle. He also destroyed all of Rocky?s beads (which she used in her work) that were supposed to be used in her show the next day. Johnny?s security guards stood by the entire time. Attached hereto as Exhibit 27 is a true and correct copy of an excerpt of the transcript of my deposition dated August 13, 2016, in which I previously testi?ed under oath about Sean and Jerry?s inaction. Attached hereto as Exhibit 28 is a true and correct copy of the video excerpt of that deposition testimony. Attached hereto as Exhibit 29 are true and correct copies of photographs of the aftermath of Johnny?s destruction that night. 40. At some point during Johnny?s destruction, while I was hiding in PH 1, I called my attorney, Samantha Spector, with whom I had been consulting about my situation with Johnny, to ask for her advice. 1 was afraid to give the police a statement that would create an international media incident for either Johnny or me, and my instinct was still to protect Johnny and our privacy. When the police officers arrived, I told them decline to give any statement at this time as per the advice of my counsel.? The of?cers repeatedly requested that I cooperate by providing a statement so that they could take action, but 1 declined. They did, however, conduct a search of the apartments, which they insisted was necessary in order to ensure my safety. Attached hereto as Exhibit 30 is a true and correct copy of an excerpt of the transcript of my deposition dated August 13, 2016, in which I previously testi?ed under oath about that interaction. Attached hereto as Exhibits 31 is a true and correct copy of the video excerpt of that deposition testimony. 41. During this time, I also texted Melanie. Attached hereto as Exhibit 32 is a true and correct copy of the text exchange between us that night (my messages in white, hers in blue). 123777111 42. Attached hereto as Exhibit 33 are true and correct copies of photographs of the injuries I sustained on May 21, 2016, which were taken between May 21 and May 28, 2016. May 27, 2016, Los Angeles, California: 43. After the May 21, 2016 attack, I resolved to leave Johnny for good. I ?led a request for a domestic violence restraining order in Los Angeles Superior Court. Attached hereto as Exhibit 34 are true and Correct copies of the Application for Domestic Violence Restraining Order, the Declaration of Amber Laura Depp, the Declaration of Raquel Rose Pennington and the exhibits thereto, and the Declaration of Samantha F. Spector, Esq. Re Ex Parte Notice and In Support Of Petitioner Amber Laura Depp?s DVRO Request, all of which were ?led on May 27, 2016. 44. On May 27, 2016, I appeared in Court for a hearing on my request for a domestic violence restraining order. At that time, I was still bruised following Johnny?s violent attack six days prior. The Court granted the domestic violence restraining order against Johnny. Attached hereto as Exhibit 35 is a true and correct copy of the Court?s Notice of Hearing and Temporary Restraining Order ?led on May 27, 2016. June 2016, Los Angeles, California: 45. In June of 2016, the media began reporting that there were individuals who claimed to have witnessed me between May 21, 2016 and May 26, 2016, and claimed that I did not appear to have been injured. Others claimed that my injuries were faked based on photographs I had taken, in which my bruises had been deliberately covered using my hair. Of course, as I already mentioned, other photographs that were taken of me during that time period show my injuries. Likewise, multiple people 1 saw at personal and private events noticed my injuries and inquired whether they could help, but also told me they could not comment publicly because they had reason to fear that they would lose theirjob or livelihood if they cooperated with me. 46. As part of Johnny?s defense in my divorce lawsuit, his lawyers claimed that I was arrested for a domestic physical altercation with my former wife, Tasya van Ree. That account was deliberately misleading, since the police released me with no charges ever being brought. Ms. van Ree has publicly contradicted the media reports generated by Johnny?s team, and said, ?In 12377711 1 -1 2- Lo2009, Amber was wrongfully accused for an incident that was misinterpreted and over- sensationalized 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 notjust ?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 5 wonderful years together and remain close to this day.? A true and correct copy of a June 8, 2016 article that appeared on Online recounting Ms. van Ree?s statement is attached hereto as Exhibit 36. 47. On June 6, 2016, i0 Tillet Wright?who was on the phone with Johnny and me during the May 21, 2016 ?ght and called 91 l?reacted to one of these media accounts on Twitter. iO?s Twitter handle is ?iOlovesyou.? Attached hereto as Exhibit 37 are true and correct copies of the ?ve tweets i0 posted on June 6, 2016. 48. On June 13, 2016, i0 ?led a declaration with an accompanying exhibit. Attached hereto as Exhibit 38 is a true and correct copy of the Declaration of i0 Tillet Wright and the exhibit thereto. January 13, 2017, Los Angeles, California: 49. After I obtained the restraining order against Johnny, we proceeded to dissolve our marriage. A true and correct copy of the Stipulated Judgment of Dissolution of Marriage, entered on January 13, 2017, is attached hereto as Exhibit 39. December 2018, Los Angeles, California: 50. Following my highly?publicized separation from Johnny, I read accounts in the media referring to me as a victim of domestic violence. In response, many people called me a liar (without ever hearing my story). I was dropped from a global fashion brand?s upcoming campaign. I lost a part for a movie in which I had already been cast. People I have never met or spoken to threatened me with violence. I received so many death threats I had to change my phone number on a near-weekly basis. 1237778.] -1 J- 51. People accused me of having abused Johnny. That simply is not true. I never attacked Johnny other than in self-defense (and in defense of my little sister). I have never physically abused anyone. 1 know what that does to people. 52. Instead, I have attempted to promote good in the world and to advocate an end to domestic violence. I have sought to use my public persona to speak out on an issue that was extremely meaningful to me and millions of other women and men every year. I have spoken out about violence in public, but I have always avoided speci?cally referencing Johnny, or recounting his violence against me, not only because I wanted to move past that phase of my life but also because I was constrained by the terms of a strict con?dentiality agreement that Johnny had insisted upon as part of our divorce settlement. 53. In early December 2018, while working with the American Civil Liberties Union as the ACLU Ambassador for Women?s Rights, I learned of an opportunity to write an Op-Ed about women?s rights issues. I agreed to do so. 54. I wrote the Op-Ed in Los Angeles, California, and submitted it to the Washington Post through my contact at the ACLU, who was based in New York. The Op-Ed was published on December 18, 2018. 55. I do not believe I ever even spoke to an editor for the Washington Post, nor did 1 ever travel to Washington, D.C. or Virginia in connection with the Op-Ed. I never knowingly contacted any employee of the Washington Post who worked from the Washington Post?s Virginia of?ce. Nor did I discuss with any Washington Post employee whether or not the Op-Ed would be published in any particular metro edition of the newspaper. 56. To the best of my knowledge, 1 have never traveled to Virginia in my life. Executed this day of April 2019, at Los Angeles, California. I declare under penalty of perjury under the laws of the State of Virginia that the foregoing is true and correct. Amber Laura Heard 1237178.] ?l 4- EXHIBIT 1 4G 4:23 PM Mar 12, 2013, 2:37 PM Just thought you should know that there exists a book titled, "Disco Bloodbath". That's (We need that book! 1 Is it about last Friday night, by any chance? Delivered {How can you make me smile about such a hideous Yes, it Funny bitch. I fucking love youHeard - MTD Exhibits - 2 EXHIBIT 2 No Service 3:22 PM Messages (IOI) Steve Details 2?3. SCI-2, l; Once again, I find myseh? in a place of shame and regret. Of course, I am sorry. I really don't know why, or what happened. But I will never do it again. I want to get better for you. And for me. I must. My illness somehow crept up and grabbed me. I can't do it again. I can't live like that again. And I know you can't either. I must get better. And I will. For us both. Starting today. I love you. Again, I am so sorry. So I love you and feel so bad for letting you Yours Pill-1. I see that understanding and forgiveness ain't on the I'm disappointed to see that, but, not too surprised, I suppose?. II -LI--.- LI--1 I5) Send Heard - MTD Exhibits - 4 No Service 3:37 PM ID Messages [101) Steve Details nimum stress to my life, yes, it could!! And yes? I know you don't get it, but I need the money. Just cuz it's not a "money job" doesn't mean I don't need the money it will Don't worry baby. I won't do a anything that makes you feel pain or discomfort . You tell me when you want - and ill do it. But ultimately we'll have to talk about it sometime. Ok! I'm in a tough situation right now and need the work. Period. I know you forget how that feels but please try to understand. I feel you're trying to embarrass me. I love you . Don't know what else to We need to talk in person about all this stuff and it will work out I know - . - Send Heard - MTD Exhibits - 5 No Service 3:38 PM .3 Messages [101) Steve Details Because you want You?ve led them didn't let go of it very You said that last time. (In a more respectful way) and I didn't do it! Because I wanted to talk to you more about it. Involve you and your opinion in it more. But we haven't had time to talk in person (obviously) so none of that could be accomplished What I don't want to loose is a paycheck I need. my parents need. That?s it. work. This is myjob. And most the time wish I was better than this. But at the moment- I'm not. This was my job when you met me. And unfortunately, I need to work because I'm really in a tight spot. But I held off saying a Send Heard - MTD Exhibits - 6 No Service 3:38 PM ID Messages (101) Steve Details ecause rea yin a tug spot. But I held off saying a decision- in either direction- because of you. And your feelings and our conversations (which we have yet to be able to really have about it. Wouldn't you want just that from me? Would you do that exact thing for me? Were you hoping for my opinion on the James Franco I'd rather you didn't stoop to that level, you've already told me How much you like the material and that it's not a money lt's I'm not gonna tackle that greased up No You have to do that You really want it, I'm going to sleep. Hope tomorrow holds You're a funny Send Heard - MTD Exhibits - 7 EXHIBIT 3 From Stephen Dueters Stephen Dueters Stephen Dueters Stephen Dueters Stephen Dueters Amber H Stephen Dueters Stephen Dueters Body Date/Timestamp He's up. In the bathroom. Moving slowly. Will let you know when en route and how he is in the car. He's in some pain, as you might guess He's been sick. We're gonna get him straight to bed 5/25/2014 4:13:19 AM(UTC+0) We're on our way to 80. Hey. He's sound asleep. We're here looking out for him. Thanks. Please let me know when you speak to him. Or if there's any major change - or if anything goes wrong Hey. He's up. He's much better. Clearer. He doesn't remember much, but we took him thru all that happened. He's sorry. Very sorry. And just wants to get better. Which allows us to make him follow up on that promise. He's teary. He doesn't want to be a fuck-up anymore his words. He's got bad indigestion this morning but otherwise alright. He's gone back to sleep for a bit. 5/25/2014 4:22:24 AM(UTC+0) 5/25/2014 7:38:40 AM(UTC+0) 5/25/2014 4:13:50 AM(UTC+0) 5/25/2014 4:22:24 AM(UTC+0) 5/25/2014 12:16:43 PM(UTC+0) 5/25/2014 3:45:04 PM(UTC+0) 5/25/2014 4:06:24 PM(UTC+0) Spoken to C. We're going to set him up with Dr Kipper on weds hopefully. He won't be skipping it this time. Amber H If he was, he'd tell me himself I reckon 5/25/2014 4:42:03 PM(UTC+0) Will that dr be in Boston? Stephen Dueters Amber H Stephen Dueters Stephen Dueters Stephen Dueters Amber H Amber H Stephen Dueters Amber H {00067764;1} Have you told him about charlie?? That Doc will fly to Boston. He's a much bigger deal 5/25/2014 4:44:48 PM(UTC+0) than Charlie. I'm not worried about bringing Charlie up I'll do that later when he's awake again Ok. I've not heard from him. Which I expected. 5/25/2014 5:23:58 PM(UTC+0) I still want to fly back to NYC today on the red eye though. I can't keep doing this. His phone is fucking up. I'm restarting it. You will hear from him, I'm sure. There feels like a sea change in him this morning. He just spoke about how bad he feels and he wasn't talking physically Think he's just texted you. He's incredibly apologetic and knows that he has done wrong. He wants to get better now. He's been very explicit about that this morning. Feel like we're at a critical juncture. Yes but I don't know how to be around him after what he did to me yesterday. I don't know if I can stay with him. I need time He wants to see you so much. He's distraught. Don't worry about the flights. I'll be taking car of them myself. Thank you. 5/25/2014 5:25:20 PM(UTC+0) 5/25/2014 5:59:28 PM(UTC+0) 5/25/2014 6:00:25 PM(UTC+0) 5/25/2014 6:13:56 PM(UTC+0) 5/25/2014 6:14:19 PM(UTC+0) 5/25/2014 8:30:56 PM(UTC+0) 5/25/2014 8:33:14 PM(UTC+0) Heard - MTD Exhibits - 9 Amber H Look, He thinks 'he doesn't deserve this'. Obviously he 5/25/2014 8:47:17 PM(UTC+0) has no idea what he did or to the extent that he did it. If someone was truly honest with him about how bad it really was, he'd be appalled. The man johnny is would be humiliated. And definitely wouldn't say to me that he doesn't deserve it. I'm sad that he doesn't have a better way to really know the severity of his actions yesterday. Unfortunately for me, I remember in full detail everything that happened. Stephen Dueters Stephen Dueters It was disgusting. And he knows it. 5/25/2014 8:48:00 PM(UTC+0) He was appalled. When I told him he kicked you, he 5/25/2014 8:48:00 PM(UTC+0) cried. I wasn't with him when he sent u the 2nd txt. He read it 5/25/2014 8:50:08 PM(UTC+0) to me and I said it was the wrong text to send. He then sent the 3rd one and sat and cried again after on the bed. He's a little lost boy. And needs all the help he can get. He is so very sorry, as he should be. Stephen Dueters Amber H He's done this many times before. Tokyo, the island, 5/25/2014 9:19:58 PM(UTC+0) London (remember that!?), and I always stay. Always believe he's going to get better... And then every 3 or so month, I'm in the exact same position . Stephen Dueters I know. It's hideous. But that is one side of the man that 5/25/2014 10:15:28 PM(UTC+0) you fell in love with. And one side of the man that fell in love with you. I know you're hurting. And you've every right too. And he knows that. {00067764;1} Heard - MTD Exhibits - 10 EXHIBIT 4 . . vs EXHIBIT 5 No Service 5159 PM 3 Messages [96) Group MMS Details To: Debbie, Dr. David Aug 201a, mm Issue has arisen again. He took the meds about 30 mins ago (which seems to be the trend) as I reckon they haven?t kicked in yet all the sudden he's flipping again. Just starting screaming he was so mad he pushed me and asked him to get out Don't know what else to do. Sorry to keep at you guys Debbie Lloyd it Would like us to come over? Dabble Lloyd 0k. Heading over. At house or He's probablyr at cabrones - . - Send Heard - MTD Exhibits - 16 No Service 5:57 PM 3 .31- Messages (96) Debbie Details Aug18. 2014,6115 mm Just seeing your text Sorry? he tossed and turned all night Woke up at least once but then fell back He woke up about 30 ago No worries. It was before kipper went in and talked to you. Is he awake now? How are things? He?s awake He's not Super angry Bad mood Are you guys talking? Has he taken morning meds?? - Send Heard - MTD Exhibits - 17 No Service ?45? 5:57 PM 3 Messages [96) Debbie Details Are you guys talking? Has he taken morning meds? Yes- but it's rough. He always works himself into rage without any provocation. Making me not feel like I can even converse with him. His blood pressure was good - like 127 over 88 or something He just took am meds I know it is rough right now. He is angry with everyone but mostly himself and he doesn't know how to handle those emotions without his drugs. Stay as calm as you can. We will get through the day and get him home. Aug 1B, 2014Send Heard - MTD Exhibits - 18 EXHIBIT 6 a) 96% Steve Dec 17, 2014, 5:04 PM I love you I am truly sorry to have upset you to the degree that I And I couldn't be more sorry for, yet again, ruining your I do, of course, take your generosity, your selflessness, your affection and your sweet doting deeply into my And, I think, that I've been Agony is never the answer to any equation, or Nor is rage. We are, I believe, in concert about Please, know that my apology is sincere and And, as stupid as it I hope your meeting with Clive Barker is I love you so very fuckin' My Steve Dec17, 2014, 8:16 PM Thank you for your words ljust left betty sue's. Just going a couple blocks away for a quick dinner or drink with Megan. I hope we can see each other when I get I don't want this Nor can I bear putting it on you. Dec 17, 2014, PM On the way home It's I've let it Went too We/l tend to do always regret it when ljump, or When you I don't want to be conditioned to continue that Therefore, I'll put in heavy work with me) 9 Heard - MTD Exhibits - 20 8 Steve It's I've let it Went too tend to do always regret it when Ijump, or When you I don't want to be conditioned to continue that Therefore, I'll put in heavy work with I'm sorry for being For your disappointment in For my behavior. I'm a fucking savage Gotta lose Gonna lose The Devil is All Around, I wish I were able to bring even just a glimmer of a smile to the pretty face of my most gorgeous of dreams and darkest I love you far too much for you and to be these heinous slinging insults like we do/did.. It is not anything that I am particularly proud of to have participated And, I regret giving it How when we fight, little How do we end up on the very edge of the precipice..?? And, why?? Wish I knew. Know that YOU ARE I am, WELL AWARE that SHOULD have been bigger than the And, that it WILL NEVER again manifest in negative It can be What a killer concept to Wish you were in this Lunatic's Be careful out I adore $96%-l Heard - MTD Exhibits - 21 EXHIBIT 7 5 2 .m a Heard - MTD Exh' lv A,21..i .. . . .3 4 fur,.Iyn It. ,Ilr. EXHIBIT 8 EXHIBIT 9 . a: 18:42 '3 :f Messages (10) Kevin Details Mar 23, EDI-3. Good morning. Johnny destroyed Amber's doset. And there's some other damage to PH5 You're the lucky person I should talk to about that - correct? I suppose I'm up Insanity. Just, fucking insanity. Mar 2:15 2' Heard - MTD Exhibits - 30 Heard - MTD Exhibits - 31 Messages (10} Kevin Details 13:42 II it I-- 18:42 I: Messages {10} Kevin Details Heard - MTD Exhibits - 32 . #3 13:42 I it I: Messages {10} Kevin Details Heard - MTD Exhibits - 33 . *e 13:43 i3 it I: Messages {10} Kevin Details to give you an idea Be down later. I'll call you. 0 Heard - MTD Exhibits - 34 EXHIBIT 10 Amber Laura Depp Vol II August 13, 2016 · · · · · · SUPERIOR COURT OF THE STATE OF CALIFORNIA · · · · · · · · ·FOR THE COUNTY OF LOS ANGELES · · · ·In re the Marriage of · · ·Petitioner:· AMBER LAURA DEPP · · · · · · · · ·and· · · · · · · · · · · No. BD641052 · · ·Respondent:· JOHN CHRISTOPHER DEPP · · · · · · · · · II (AKA JOHNNY DEPP) · · ·________________________________ · · · · · · · · VIDEOTAPED DEPOSITION OF AMBER LAURA DEPP · · · · · · · · · · · · · VOLUME II · · · · · · · · · · · ·August 13, 2016 · · · · · · · · · · 10:00 a.m. - 7:04 p.m. · · · · · · · · ·2049 Century Park East, Suite 800 · · · · · · · · · ·Los Angeles, California · · · · · · ·Reported by: · · ·PAMELA J. FELTEN · · ·CSR No. 5189 U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 36 Amber Laura Depp Vol II August 13, 2016 378 ·1· · · · · · ·THE WITNESS:· -- them actually. ·2· · · · · · ·MR. HARDER:· I can't hear them.· I hear them. ·3· · · · · · ·MS. GARVIS WRIGHT:· I can't hear them. ·4· · · · · · ·MR. HARDER:· So please answer the question. ·5· ·BY MS. BERK: ·6· · · · ·Q· ·Yes or no -·7· · · · · · ·MR. HARDER:· No. ·8· ·BY MS. BERK: ·9· · · · ·Q· ·-- did you ever punch Johnny Depp with a closed 10· ·fist in the history of your relationship with Johnny? 11· · · · · · ·MR. HARDER:· Answer it however you feel you 12· ·wish to. 13· · · · · · ·THE WITNESS:· One time, um, Johnny was hitting 14· ·me and he was hitting me hard and repeatedly and I was 15· ·screaming.· Security walks in and they don't do anything 16· ·about it.· And there -- he -- he -- he -- he -- he makes 17· ·this motion when Jerry Judge yells "Boss."· Or Sean. I 18· ·can't remember who it was.· And -- and my -- all we had 19· ·was a little bit of separation.· And my sister runs down 20· ·the stairs.· It's a -- we're on a landing in between two 21· ·flights of stairs. 22· · · · · · ·MS. BERK:· Ms. Heard, I must interrupt you -23· · · · · · ·MR. HARDER:· You can't. 24· · · · · · ·MS. BERK:· -- because -25· · · · · · ·MR. HARDER:· You can't -- U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 37 YVer1f Amber Laura Depp Vol II August 13, 2016 379 ·1· · · · · · ·MS. BERK:· -- I've asked you a yes or a -·2· · · · · · ·MR. HARDER:· Then withdraw -·3· · · · · · ·MS. BERK:· -- no question. ·4· · · · · · ·MR. HARDER:· Withdraw your question, then, ·5· ·because she was answering. ·6· ·BY MS. BERK: ·7· · · · ·Q· ·Ms. Heard, prior to today's date, at any time, ·8· ·has Johnny -- have you ever hit Johnny Depp? ·9· · · · · · ·MR. KOENIG:· Objection.· 352. 10· · · · · · ·MR. HARDER:· You've already asked and she's 11· ·already answered and you interrupted her. 12· ·BY MS. BERK: 13· · · · ·Q· ·Ms. Heard, have you ever hit Johnny Depp prior 14· ·to today? 15· · · · · · ·MS. SPECTOR:· 352. 16· · · · · · ·MR. KOENIG:· Objection.· Vague as to time. 17· · · · · · ·MS. KLEIN:· Let her answer. 18· · · · · · ·MR. HARDER:· Everyone on this side of the room, 19· ·please. 20· · · · · · ·MR. KOENIG:· Objection.· 352.· It's not 21· ·relevant to the domestic violence proceeding. 22· · · · · · ·MR. O'DONNELL:· Overruled.· You may answer. 23· · · · · · ·MS. BERK:· Thank you, Your Honor. 24· · · · · · ·MR. HARDER:· Answer it however you want to 25· ·including the way you were just giving -- U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 38 YVer1f Amber Laura Depp Vol II August 13, 2016 380 ·1· · · · · · ·MS. BERK:· I'm asking for a yes or no answer. ·2· · · · · · ·THE WITNESS:· He -·3· · · · · · ·MR. HARDER:· You don't have to answer it the ·4· ·way she wants you to answer it. ·5· · · · · · ·THE WITNESS:· He was about to push my sister ·6· ·down the stairs.· She was attempting to break us up.· I'm ·7· ·protective over my baby sister.· When he laid hands on ·8· ·her, I don't know what I did, but I know I jumped in ·9· ·between the actions that I saw could lead to a fatal 10· ·injury to my sister.· She was standing at the top of a 11· ·flight of stairs, and she has never hurt anyone in her 12· ·life and she does not deserve to be pushed down a flight 13· ·of stairs, and it looked like she was about to be.· And I 14· ·would have done what anybody who has a child or a sister 15· ·would have done.· I acted defensively in her life.· I saw 16· ·her standing on top of a flight of stairs and trying to 17· ·interrupt a fight between him and I.· I don't know what 18· ·part of my body I put in between me and him and her, but 19· ·I would have done anything, I would have done anything to 20· ·prevent her from being pushed down a flight of stairs. 21· ·BY MS. BERK: 22· · · · ·Q· ·Isn't it true, Ms. Heard, that prior to today 23· ·you've committed domestic violence against your sister, 24· ·Whitney Heard? 25· · · · · · ·MR. HARDER:· I'm going to object. U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 39 YVer1f Amber Laura Depp Vol II August 13, 2016 421 ·1· ·STATE OF CALIFORNIA· · ) · · · · · · · · · · · · · · ) ss ·2· ·COUNTY OF LOS ANGELES· ) ·3 ·4· · · · · · ·I, PAMELA J. FELTEN, a Certified Shorthand ·5· ·Reporter, do hereby certify: ·6· · · · · · ·That prior to being examined, the witness in ·7· ·the foregoing proceedings was by me duly sworn to ·8· ·testify to the truth, the whole truth, and nothing ·9· ·but the truth; 10· · · · · · ·That said proceedings were taken before me at 11· ·the time and place therein set forth and were taken 12· ·down by me in shorthand and thereafter transcribed 13· ·into typewriting under my direction and supervision; 14· · · · · · ·I further certify that I am neither counsel 15· ·for, nor related to, any party to said proceedings, 16· ·nor in anywise interested in the outcome thereof. 17· · · · · · ·In witness whereof, I have hereunto subscribed 18· ·my name. 19 20· ·Dated:· August 14, 2016 21 22 23· ·___________________________ · · ·PAMELA J. FELTEN 24· ·CSR No. 5189 25 U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 40 EXHIBIT 11 VIDEO See Attached CD/DVD Recommended Media Player - VLC Media Player Heard - MTD Exhibits - 41 EXHIBIT 12 EXHIBIT 13 Heard - MTD Exhibits - 46 . a -3. ?r Heard - MTD Exhibits - 49 Heard - MTD Exhibits - 50 Heard - MTD Exhibits - 51 eard - MTD Exhibits - 52 Heard - MTD Exhibits - 53 Heard - MTD Exhibits - 54 i Heard MTD Exhibits 55 6 5 .3 a . 4.311; Ar/ ll.11 1.4410111EXHIBIT 14 EXHIBIT 15 "no T-Mobile 46 4:52 PM SWIM Messages Details Thu. Nov 5. :1 if} Aim Hey there. I didn't Maybe old? Sorry for the delay. Wasn't on this phone. Xo Tueaccident tonight Jodi. I'm really bruised and might have a black or two - 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 to let you know- k? Wed. 0:21:16, I ?51 M4 Oh Are you ok?! That sounds terrible. Sending you love. Thu, Jan M3. 3 Send Heard - MTD Exhibits - 61 EXHIBIT 16 Messages (3) [4 Will get into Sara Stins Friday Just heard about amber. 0mg is everything 0k? Jessa I love you Friday Josh 8: +44 7480 Friday Are you potentially coming in July? Stacey Friday Ok. see the news now. l've been in abusive +1 (323) 683-8917 Thank you Jo Friday Josh, +1 (973) Friday He! Ryan Howard Friday Meow Amber Friday Document signed +1 (916) 599?3518 Thursday SinswansonB@omail.com :1 2:10 PM Amber I said "you head butted me" and his response? just gave you a little knock? "With my head" And then he left the room after saying what a "fuck up" he was and such Fucking feeling sorry for himself poor him Can't take any responsibility Just like josh said He doesn't know how 3 98%- Details Does that make it a little easier? Are you sure you guys are okay not going to the island I feel terrible for ruining cams *xmas Christmas is going to happen many more times. And home is where you and moms are Heard - MTD Exhibits - 63 9 'ad Edit Messages (3) Will get into 1 Sara Stins Friday Just heard about amber. 0mg is everything 0k? Jessa I love you Friday Josh +44 7430 Friday Are you potentially coming in July? Stacey Friday Ok. see the news now. I've been in abusive +1 (323) 683-8917 Thank you Jo Fnday Josh, +1 (973) Friday Ha! Ryan Howard Friday Meow Amber Friday Document signed +1 (916) 599-3518 Thursday Smswanson3?omail.com 1} 2:10 PM I'm ok Just been a hard night Crying And talking And crying more Amber Mon, Dec 21, 1231 MM )8 98%- Details Oh Amber, wish there was anything I could do to make this load not as heavy Thank you for responding, was dreaming about you. i was worried. He's fucked up asked him to leave ignore it He's gone I'm so sorry Mon, Dec 21.31%: AM Ho'e it not fps-lint: lilo: ho': fl Inland rm i think Johnny just came in and left a note on my floor Yes obviously Heard - MTD Exhibits - 64 9 'ad Edit Messages (3) Wili getinto I Sara Stins Friday Just heard about amber. 0mg is everything 0k? Jessa Friday I love you Josh 8: +44 7480 Friday Are you potentially coming in July? Stacey Friday Ok. see the news now. I've been in abusive +1 (323) 683-8917 Friday Thank you Jo Josh, +1 (973) Friday Ha! Ryan Howard Friday Meow Amber Friday Document signed +1 (916) 599-3518 Thursday SmswansonBt?iomail.com :l 2:10 PM Amber rvlonI Dec 21,3118 AM )3 98%- Details 1 think Johnny just came in and left a note on my floor He's fucked up I asked him to leave ignore it He's gone I'm so sorry He's just feeling like he's fucked up I've asked him to leave twice I don't know He's not with me He's drink *drunk Yes obviously No need no apologize it's not your fault I saw Steven in the hallway, can he help? Can we help? Heard - MTD Exhibits - 65 9 EXHIBIT 17 Amber Laura Depp Vol II August 13, 2016 · · · · · · SUPERIOR COURT OF THE STATE OF CALIFORNIA · · · · · · · · ·FOR THE COUNTY OF LOS ANGELES · · · ·In re the Marriage of · · ·Petitioner:· AMBER LAURA DEPP · · · · · · · · ·and· · · · · · · · · · · No. BD641052 · · ·Respondent:· JOHN CHRISTOPHER DEPP · · · · · · · · · II (AKA JOHNNY DEPP) · · ·________________________________ · · · · · · · · VIDEOTAPED DEPOSITION OF AMBER LAURA DEPP · · · · · · · · · · · · · VOLUME II · · · · · · · · · · · ·August 13, 2016 · · · · · · · · · · 10:00 a.m. - 7:04 p.m. · · · · · · · · ·2049 Century Park East, Suite 800 · · · · · · · · · ·Los Angeles, California · · · · · · ·Reported by: · · ·PAMELA J. FELTEN · · ·CSR No. 5189 U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 67 Amber Laura Depp Vol II August 13, 2016 245 ·1· ·before she came today. ·2· · · · · · ·MR. HARDER:· Well, she's doing it now. ·3· · · · · · ·MS. WASSER:· Well, it's okay. ·4· · · · · · ·Maybe it's privileged because it was sent to ·5· ·her attorneys. ·6· · · · · · ·MR. HARDER:· Take your time with this document. ·7· ·Make sure you're comfortable with what this document is. ·8· ·Okay? ·9· · · · · · ·MS. BERK:· Okay.· I'll move on. 10· · · · ·Q· ·Ms. Heard -11· · · · · · ·THE WITNESS:· I haven't seen this ever. 12· · · · · · ·MR. HARDER:· Don't -- don't say anything. 13· · · · · · ·THE WITNESS:· Okay. 14· · · · · · ·MR. HARDER:· Just let her ask a question. 15· · · · · · ·MS. BERK:· I need this. 16· · · · ·Q· ·Did -17· · · · · · ·MR. ALLHOFF:· What is that? 18· · · · · · ·MS. BERK:· That's her declaration in support of 19· ·her DVRO. 20· · · · ·Q· ·In your declaration that you filed in support 21· ·of your request for a restraining order, did you say -22· ·do you have it there so that you can refer to it? 23· · · · ·A· ·That's what this is, right?· It's Exhibit K? 24· · · · ·Q· ·Exhibit K. 25· · · · · · ·Did you say in -- did you claim in paragraph 7 U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 68 YVer1f Amber Laura Depp Vol II August 13, 2016 246 ·1· ·that: ·2· · · · · · ·"After my guests had left, Johnny ·3· · · · · · ·and I had a discussion about his ·4· · · · · · ·absence from my birthday celebration ·5· · · · · · ·which deteriorated into a bad ·6· · · · · · ·argument that started with Johnny ·7· · · · · · ·throwing a magnum size bottle of ·8· · · · · · ·champagne at the wall and a wine ·9· · · · · · ·glass on me and the floor -- both 10· · · · · · ·which shattered.· Johnny then 11· · · · · · ·grabbed me by the shoulders and 12· · · · · · ·pushed me onto the bed, blocking the 13· · · · · · ·bedroom door.· He then grabbed me by 14· · · · · · ·the hair and violently shoved me to 15· · · · · · ·the floor." 16· · · · · · ·Did you say that when you swore under penalty of 17· ·perjury and signed your name to this document? 18· · · · ·A· ·Yes. 19· · · · ·Q· ·Okay.· And did you say in this same document 20· ·that "Johnny was screaming and threatening me, taunting 21· ·me to stand up"? 22· · · · ·A· ·Yes.· He did that often in fights. 23· · · · ·Q· ·Did he do that -- are you saying he did that on 24· ·April 21, 2016? 25· · · · ·A· ·Yes.· It's something that had been happening a U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 69 YVer1f Amber Laura Depp Vol II August 13, 2016 247 ·1· ·lot lately. ·2· · · · ·Q· ·Did you say in your declaration that "After ·3· ·several minutes, Johnny stormed out of the condominium, ·4· ·but not before tossing aside and breaking nearly ·5· ·everything in his path"? ·6· · · · ·A· ·Yes.· Are you asking me if I said that? ·7· · · · ·Q· ·Yes. ·8· · · · ·A· ·Yes. ·9· · · · ·Q· ·And is that the truth? 10· · · · ·A· ·Yes. 11· · · · ·Q· ·Okay.· After you say he did this, did you call 12· ·the police? 13· · · · ·A· ·No, I did not. 14· · · · ·Q· ·Did you call the police regarding these things 15· ·you say happened at any time after you say they happened? 16· · · · · · ·MR. HARDER:· Vague and ambiguous, compound. 17· ·BY MS. BERK: 18· · · · ·Q· ·Do you understand my question? 19· · · · ·A· ·Yes. 20· · · · ·Q· ·Okay.· Did you call the police -- can you 21· ·answer my question? 22· · · · · · ·MR. HARDER:· Go ahead. 23· · · · · · ·THE WITNESS:· Oh, okay.· Did I call the police 24· ·on any of the other occasions or any occasion? 25· ·BY MS. BERK: U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 70 YVer1f EXHIBIT 18 Amber Laura Depp Vol II August 13, 2016 · · · · · · SUPERIOR COURT OF THE STATE OF CALIFORNIA · · · · · · · · ·FOR THE COUNTY OF LOS ANGELES · · · ·In re the Marriage of · · ·Petitioner:· AMBER LAURA DEPP · · · · · · · · ·and· · · · · · · · · · · No. BD641052 · · ·Respondent:· JOHN CHRISTOPHER DEPP · · · · · · · · · II (AKA JOHNNY DEPP) · · ·________________________________ · · · · · · · · VIDEOTAPED DEPOSITION OF AMBER LAURA DEPP · · · · · · · · · · · · · VOLUME II · · · · · · · · · · · ·August 13, 2016 · · · · · · · · · · 10:00 a.m. - 7:04 p.m. · · · · · · · · ·2049 Century Park East, Suite 800 · · · · · · · · · ·Los Angeles, California · · · · · · ·Reported by: · · ·PAMELA J. FELTEN · · ·CSR No. 5189 U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 72 Amber Laura Depp Vol II August 13, 2016 248 ·1· · · · ·Q· ·I'm speaking of April 21 when you make these ·2· ·claims. ·3· · · · ·A· ·No, I did not. ·4· · · · ·Q· ·When you say these things happened on April 21, ·5· ·at any time after April 21, did you call the police about ·6· ·these things you say happened on April 21? ·7· · · · ·A· ·No.· I never called the police on Johnny ·8· ·myself. ·9· · · · ·Q· ·Did you ever report to any law enforcement 10· ·authority other than the police your claims that he did 11· ·these things on April 21? 12· · · · ·A· ·No.· I attempted as best as I could to hide 13· ·this and keep our lives as private as -- as possible, and 14· ·I did what a lot of I guess women do, tried to protect 15· ·him. 16· · · · ·Q· ·Were you attempting to hide this when you filed 17· ·this declaration on May 27, 2016? 18· · · · ·A· ·It was unhideable because the cops had been 19· ·called. 20· · · · ·Q· ·Ms. Heard, when you claim in your declaration 21· ·that the argument started with Johnny throwing a magnum 22· ·size bottle of champagne at the wall, um, do you recall 23· ·that event? 24· · · · ·A· ·Yes. 25· · · · ·Q· ·Okay.· Did the bottle break? U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 73 YVer1f Amber Laura Depp Vol II August 13, 2016 249 ·1· · · · ·A· ·I don't know if it broke or if there was a ·2· ·bottle on the table next to it that broke and a wine ·3· ·glass next to it that broke, but there was both a wine ·4· ·glass and a bottle.· I'm not sure which of the two it was ·5· ·that broke when -- the one that was thrown at me but ·6· ·missed, or if it was the one perhaps sitting on the table ·7· ·nearby.· But our paint -- the painting behind it, behind ·8· ·it that rests on the wall behind where I was standing, ·9· ·still is missing a big chunk out of it.· So -10· · · · ·Q· ·Did the bot- -11· · · · ·A· ·-- it made quite an impact. 12· · · · ·Q· ·Are you finished?· I want to make sure if 13· ·you're finished or not. 14· · · · ·A· ·Yeah. 15· · · · ·Q· ·Okay.· Did the bottle you refer to, did it ever 16· ·touch your body? 17· · · · ·A· ·No. 18· · · · ·Q· ·Did the wine glass you refer to in reference to 19· ·the bottle ever touch your body? 20· · · · ·A· ·Uh, pieces of it did.· That's -- it shattered. 21· · · · ·Q· ·Okay.· Where did the pieces you say touched 22· ·your body touch your body?· What part of your body? 23· · · · ·A· ·I don't remember exactly what part of my body 24· ·was touched by the glass breaking upon impact.· I do know 25· ·that it touched my body, knees and hands -- no, not my U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 74 YVer1f Amber Laura Depp Vol II August 13, 2016 250 ·1· ·hands -- my knees anyway when I went down to the floor, ·2· ·or some version of my legs when I went down to the floor ·3· ·later in the fight, but nothing significant.· Not like ·4· ·Australia or anything. ·5· · · · ·Q· ·Were there any injuries to your body at the ·6· ·places you claim the wine glass touched your body? ·7· · · · ·A· ·No, I don't think so. ·8· · · · ·Q· ·Was there -·9· · · · ·A· ·Not that I saw. 10· · · · ·Q· ·-- any indication that you could see on your 11· ·body that the wine glass shards had touched your body? 12· · · · ·A· ·No.· Not that I could see. 13· · · · ·Q· ·Okay. 14· · · · ·A· ·Or nothing that I remember. 15· · · · ·Q· ·At the time the wine glass touched you, as you 16· ·claim it did, was it intact or was it already broken? 17· · · · ·A· ·I can't tell because it was -- I assume it was 18· ·shattered upon impacting -- impact with the magnum size 19· ·bottle of wine that was thrown.· Um, I'm assuming that's 20· ·what shattered it.· But at some point there was glass 21· ·everywhere and, um, I was standing right next to it. 22· · · · ·Q· ·When it -- when you claim it touched your body, 23· ·where specifically in the apartment were you standing? 24· · · · ·A· ·Uh, I was standing in our bedroom. 25· · · · ·Q· ·Okay.· And where did the bottle and glass end U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 75 YVer1f EXHIBIT 19 Amber Laura Depp Vol II August 13, 2016 · · · · · · SUPERIOR COURT OF THE STATE OF CALIFORNIA · · · · · · · · ·FOR THE COUNTY OF LOS ANGELES · · · ·In re the Marriage of · · ·Petitioner:· AMBER LAURA DEPP · · · · · · · · ·and· · · · · · · · · · · No. BD641052 · · ·Respondent:· JOHN CHRISTOPHER DEPP · · · · · · · · · II (AKA JOHNNY DEPP) · · ·________________________________ · · · · · · · · VIDEOTAPED DEPOSITION OF AMBER LAURA DEPP · · · · · · · · · · · · · VOLUME II · · · · · · · · · · · ·August 13, 2016 · · · · · · · · · · 10:00 a.m. - 7:04 p.m. · · · · · · · · ·2049 Century Park East, Suite 800 · · · · · · · · · ·Los Angeles, California · · · · · · ·Reported by: · · ·PAMELA J. FELTEN · · ·CSR No. 5189 U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 77 Amber Laura Depp Vol II August 13, 2016 253 ·1· ·what -- what -- what was on the floor of your bedroom as ·2· ·you described it and where it was -·3· · · · ·A· ·I -- I don't -·4· · · · ·Q· ·-- from this incident? ·5· · · · ·A· ·I don't remember. ·6· · · · ·Q· ·Was -·7· · · · ·A· ·I don't -·8· · · · ·Q· ·Was there anything in addition on the floor in ·9· ·addition to the broken wine bottle and a broken glass? 10· · · · ·A· ·Uh, broke -- wine.· Um, wine, as well, but it 11· ·might have been dried up by the time -- um, by the time I 12· ·left.· I don't really remember what else. 13· · · · ·Q· ·In terms of the broken glass you claim was on 14· ·your bedroom floor, could you describe specifically where 15· ·it was on your bedroom floor relative to your bed? 16· · · · ·A· ·Uh, it was around my bed because the paint -17· ·and probably by the entrance of the door, as well, but 18· ·I'm not exactly sure. 19· · · · ·Q· ·Okay. 20· · · · ·A· ·There was a lot of -- we were -- there was a 21· ·lot of fighting and a lot of movement in several 22· ·different parts of our room.· So when he was holding me 23· ·down on the bed and I was trying to stand up, that was by 24· ·the bath -- closer to the bathroom and I know there was 25· ·broken glass there.· When I was -- when I tried to get U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 78 YVer1f Amber Laura Depp Vol II August 13, 2016 254 ·1· ·out of the bedroom door and he blocked it and shoved me ·2· ·back down to the floor by the -- that was by the -- by ·3· ·the entrance to the door.· And I can't remember what else ·4· ·was breaking and what had been knocked over.· I know the ·5· ·lamp -- the lamp broke, as well.· I didn't mention that. ·6· ·It's still in -- in the storage closet.· I just saw it ·7· ·the other day.· And it has wine on it.· You know, I found ·8· ·it the other day.· But -·9· · · · ·Q· ·Did you take pictures of that at any time? 10· · · · ·A· ·No.· Not that I recall. 11· · · · ·Q· ·Did you bring that with you today? 12· · · · ·A· ·I did not bring that with me.· The lamp? 13· · · · ·Q· ·Yes. 14· · · · ·A· ·No, I did not bring the lamp with me today. 15· · · · ·Q· ·Okay.· Were you ever asked to locate any of the 16· ·items that were -- that you say were damaged or broken 17· ·from April 21? 18· · · · · · ·MR. HARDER:· Privilege.· Don't answer. 19· · · · · · ·(Instruction not to answer) 20· ·BY MS. BERK: 21· · · · ·Q· ·Did you ever make any attempts to locate any of 22· ·the items from 21 -- from April 21 that you say were 23· ·damaged or broken? 24· · · · ·A· ·No. 25· · · · ·Q· ·Okay.· And, in fact -- U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 79 YVer1f Amber Laura Depp Vol II August 13, 2016 255 ·1· · · · ·A· ·Oh, my -- yes, I'm sorry.· My phone.· I tried ·2· ·to find my phone, but I never recovered it. ·3· · · · ·Q· ·And in the DVRO that you filed with the Court, ·4· ·did you attach any photographs whatsoever from the events ·5· ·you claim on April 21, 2016? ·6· · · · · · ·MR. HARDER:· The Court filing would speak for ·7· ·itself. ·8· ·BY MS. BERK: ·9· · · · ·Q· ·To your knowledge. 10· · · · ·A· ·I don't know what we attached off the top of my 11· ·head. 12· · · · ·Q· ·Okay.· Do you know what you gave any other 13· ·person for the April 21 -- relating to the April 21 14· ·events? 15· · · · · · ·MR. HARDER:· If it has to do with lawyers, it's 16· ·privileged. 17· ·BY MS. BERK: 18· · · · ·Q· ·Ms. Heard, can you tell me exactly what you say 19· ·happened, uh, uh, on -- in the argument you had with -20· ·you say you had with Johnny on April 21? 21· · · · ·A· ·What was the question exactly if you don't mind 22· ·me asking? 23· · · · ·Q· ·What happened? 24· · · · · · ·MR. HARDER:· She wants to hear you tell what 25· ·happened. U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 80 YVer1f Amber Laura Depp Vol II August 13, 2016 256 ·1· · · · · · ·THE WITNESS:· I was -- Johnny and I, when we ·2· ·made it back to our apartment, I was being cold to him. ·3· ·I -- I wasn't being very -- I wasn't being as, you know, ·4· ·open or friendly as I normally am.· Um, it was -- I ·5· ·was -- I was crushed that he missed my birthday.· And ·6· ·this is after a month of him not coming home like five ·7· ·nights a -- on average five nights a week.· Just not ·8· ·showing up or showing up at like 2:00, 3:00, 4:00 o'clock ·9· ·in the morning or at like 8:00 o'clock in the morning, 10· ·I'd find out that he was passed out at one of the other 11· ·places in West Hollywood.· So it had been building up. 12· · · · · · ·And -- and so the birthday incident was 13· ·heartbreaking.· It was my 30th birthday.· And I was just 14· ·so sad about it. 15· · · · · · ·MR. HARDER:· She -16· · · · · · ·THE WITNESS:· So we -- he asked me -- he -- we 17· ·got in bed and I was just being quiet.· I think I picked 18· ·up my book and tried to read, and he said, um, "What's 19· ·your fucking problem?" 20· · · · · · ·And I said, "I'm just hurt."· And I had been 21· ·seeing this -- you know, I've been trying to get us to 22· ·see a marriage counselor -- who said that that's how I 23· ·should like word things, as opposed to it being 24· ·accusatory, and I said, "I'm just hurt.· Hurt that you 25· ·didn't make it to my birthday party."· And then it U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 81 YVer1f Amber Laura Depp Vol II August 13, 2016 257 ·1· ·quickly deteriorated into the normal, "It's my fault. ·2· ·Why do you always blame me for everything?· You always ·3· ·blame me for everything." ·4· ·BY MS. BERK: ·5· · · · ·Q· ·Okay. ·6· · · · ·A· ·And then it escalated and he -- I don't know ·7· ·what I said that immediately preceded it, but he -- the ·8· ·first big action was the wine bottle that I remember ·9· ·being thrown at me.· Or -- or maybe it was that I was 10· ·trying to leave.· I don't really remember which of the 11· ·first -12· · · · ·Q· ·Was that while you were in the bed that the 13· ·wine bottle was thrown at you? 14· · · · ·A· ·No.· It was in -- I was standing in the 15· ·bedroom. 16· · · · ·Q· ·Okay. 17· · · · ·A· ·In front of this painting, kind of closer to 18· ·the bathroom.· And when I moved to leave, um, he shoved 19· ·me at some point, shoved me down on the ground.· I stood 20· ·back up and, um, and then he did -- he did this taunting 21· ·thing where I guess it -- it was to challenge me to see 22· ·if I was really going to leave.· "You think you're really 23· ·going to be the little -- want to leave.· You really 24· ·think you're that tough, huh?· Tough guy.· Tough guy." 25· ·And then shoved me down again.· I stand back up.· Again, U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 82 YVer1f Amber Laura Depp Vol II August 13, 2016 258 ·1· ·"You think you're so tough." ·2· · · · · · ·And eventually I did make it out of the ·3· ·bedroom, um, and -- and, um, I don't -- I don't know if I ·4· ·was walking back from where my clothes are with an ·5· ·overnight bag and I have to pass through the office ·6· ·because of the adjoining apartments, but in my passing ·7· ·him, um, he grabs my hair at some point, um -- well, we ·8· ·were arguing kind of in passing as I'm walking through ·9· ·the office and as I make it around the edge of the desk, 10· ·it's either a shove to initiate or something with my 11· ·head, a push or something, and it turns into him grabbing 12· ·me by the back of my hair.· And -- and I -- and I -- and 13· ·I -- and I -- I -- I said some, you know, comment to him, 14· ·I don't remember what it was, and walked into the 15· ·bedroom, grabbed my -- to grab my toothbrush, things like 16· ·that that I don't keep in -- in my closet room, and in 17· ·doing that, um, we had more of a -- more of a fight.· It 18· ·was pushing, um, uh -- I -- I put my hands up like this 19· ·once. 20· · · · · · ·MS. BERK:· Let the record reflect the witness 21· ·is raising her hands above her head. 22· · · · · · ·MR. HARDER:· You're interrupting her.· She's 23· ·being videotaped.· Don't interrupt her, please.· She's -24· ·she's telling her story. 25· · · · · · ·Go ahead. U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 83 YVer1f Amber Laura Depp Vol II August 13, 2016 259 ·1· · · · · · ·THE WITNESS:· Um, yeah.· I put my hands up and ·2· ·he did this, he pushed them down, and squared off to me, ·3· ·bumped his chest into mine.· I kind of fell back a little ·4· ·bit onto the bed.· I stood back up and, um, tried to -·5· ·tried to get -- walk past him to the door.· At some point ·6· ·I end up on the floor.· Um, I don't -- um, he walks out. ·7· ·Um, I tried to actually even at that point say, "Don't ·8· ·walk out.· Like we just need to talk about it.· You know, ·9· ·can we just take a break and then just talk?· Because 10· ·it's my birthday.· And I don't want to wake up on my -11· ·you know, my birthday -- we have -- we've had a million 12· ·of these fights.· Just don't leave.· I just don't want to 13· ·wake up on my birthday by myself.· Don't go, please." 14· · · · · · ·Even though it had gotten violent, this is 15· ·nothing compared to so many of the other things.· I -- it 16· ·actually wouldn't even be a major thing if -- if it 17· ·weren't one of the just most recent -- this is not a bad 18· ·thing.· I mean it wasn't bad in my head in relation to 19· ·what I -- what we have lived through. 20· · · · · · ·MR. HARDER:· Say what happened. 21· · · · · · ·THE WITNESS:· Sorry.· Um, it -- it escalates. 22· ·I tried to get him to stop in that moment and he -- and 23· ·he -- and he broke a bunch of shit in the kitchen. I 24· ·think he wrote on the countertop -- I think that's one -25· ·one of the times he wrote on the countertop in Sharpie U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 84 YVer1f Amber Laura Depp Vol II August 13, 2016 260 ·1· ·some -- some crazy message to me.· And I -- I -- I went ·2· ·upstairs.· I heard him kind of coming in and out and -·3· ·and then when I walked downstairs -- it was quiet for a ·4· ·really long time.· When I walked back downstairs, there ·5· ·was just a note on the floor that said, you know, "Happy ·6· ·fucking birthday." ·7· ·BY MS. BERK: ·8· · · · ·Q· ·Was there -- was there any other debris on the ·9· ·floor downstairs other than on the countertops in the 10· ·kitchen? 11· · · · ·A· ·I don't remember.· I know he -- he smashed -12· ·he -- he was -- he knocked over lamps and a statue thing 13· ·and paintings.· And he's gotten really into -- he had 14· ·been punching photographs with me in them recently and 15· ·this was one of those times, but nothing that I -16· ·nothing downstairs specifically that I remember at this 17· ·moment. 18· · · · ·Q· ·Okay.· And did I hear you say you had tried to 19· ·convince Johnny to stay to talk about it? 20· · · · ·A· ·At some point in the argument, yeah. 21· · · · ·Q· ·Okay.· And were you successful in getting him 22· ·to stay? 23· · · · ·A· ·No.· No.· Just -- just long enough to have it 24· ·explode. 25· · · · ·Q· ·And at any -- U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 85 YVer1f EXHIBIT 20 VIDEO See Attached CD/DVD Recommended Media Player - VLC Media Player Heard - MTD Exhibits - 86 EXHIBIT 21 VIDEO See Attached CD/DVD Recommended Media Player - VLC Media Player Heard - MTD Exhibits - 87 EXHIBIT 22 VIDEO See Attached CD/DVD Recommended Media Player - VLC Media Player Heard - MTD Exhibits - 88 EXHIBIT 23 Amber Laura Depp Vol II August 13, 2016 · · · · · · SUPERIOR COURT OF THE STATE OF CALIFORNIA · · · · · · · · ·FOR THE COUNTY OF LOS ANGELES · · · ·In re the Marriage of · · ·Petitioner:· AMBER LAURA DEPP · · · · · · · · ·and· · · · · · · · · · · No. BD641052 · · ·Respondent:· JOHN CHRISTOPHER DEPP · · · · · · · · · II (AKA JOHNNY DEPP) · · ·________________________________ · · · · · · · · VIDEOTAPED DEPOSITION OF AMBER LAURA DEPP · · · · · · · · · · · · · VOLUME II · · · · · · · · · · · ·August 13, 2016 · · · · · · · · · · 10:00 a.m. - 7:04 p.m. · · · · · · · · ·2049 Century Park East, Suite 800 · · · · · · · · · ·Los Angeles, California · · · · · · ·Reported by: · · ·PAMELA J. FELTEN · · ·CSR No. 5189 U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 90 Amber Laura Depp Vol II August 13, 2016 302 ·1· ·BY MS. BERK: ·2· · · · ·Q· ·To your knowledge that you saw. ·3· · · · ·A· ·I can't remember. ·4· · · · ·Q· ·During the call with iO Wright, please tell us ·5· ·exactly what happened. ·6· · · · ·A· ·She picked up the phone and I said, "Hey, babe, ·7· ·um, just for clarity, I'm here with Johnny, he's upset ·8· ·about some things.· Can you just clarify and we can put ·9· ·some things to bed?" 10· · · · · · ·She said, "What?" 11· · · · · · ·And I said, "Were you over here on the morning 12· ·of my birthday?" 13· · · · · · ·And she said, "Why are you asking me that?" 14· ·And "Of course I wasn't.· I met you in Palm Springs." 15· · · · · · ·And I said, "I'm here with Johnny and he's 16· ·upset about something and I just want to put it to bed." 17· · · · · · ·And she said, "No.· I" -- you know, like I 18· ·don't know if she got much more out because he started 19· ·screaming, grabbed the phone out of my hand -- she was on 20· ·speakerphone -- and he started yelling at her. 21· · · · ·Q· ·Were you holding the phone prior to -- the 22· ·phone that you were speaking to iO Tillett on? 23· · · · ·A· ·Yeah. 24· · · · ·Q· ·Okay.· And you claim that he then grabbed the 25· ·phone for you -- from you? U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 91 YVer1f Amber Laura Depp Vol II August 13, 2016 303 ·1· · · · ·A· ·He grabbed the phone from me and then before he ·2· ·went upstairs, presumably to pack a bag or get some of ·3· ·his things as he indicated to me, he, you know, like ·4· ·tossed it on -- in -- tossed it in my direction or ·5· ·something on the table or on the couch, I can't remember ·6· ·which.· I picked it up and I said, "Oh, my God, iO" -- I ·7· ·can't remember if the call disconnected and it was two ·8· ·separate calls or if it was one call, but I remember ·9· ·saying to iO, "Oh, my God, I'm so sorry.· I did not call 10· ·you to get screamed at."· Because she answered the phone, 11· ·the poor thing, without any real expectation, just 12· ·started being screamed at by Johnny this way, and I 13· ·didn't want to make it seem like I called her for a setup 14· ·to just be yelled at.· And -- and -- and -- and he was 15· ·saying, "You know, you dike bitch, you -- you know, your 16· ·ten cent words and your fucking book deal and your 17· ·fucking sell out my family," you know, just the worst 18· ·things that you can -- expletives and -- and -- and very 19· ·personal things to her situation.· And he started to go 20· ·upstairs and I had the phone in my hand again and I'm on 21· ·speakerphone, and -- and he -- he makes it upstairs -22· ·makes it partway up the stairs and she says, "It is -- it 23· ·does not sound safe.· Get out before it gets worse this 24· ·time.· Get out of there.· Get out.· It's not safe." 25· · · · · · ·And all of my friends who are informed of our U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 92 YVer1f Amber Laura Depp Vol II August 13, 2016 304 ·1· ·history are very very very very scared of me being alone ·2· ·in a room with him when there are things wrong, when ·3· ·we're fighting, when we're working things out, and when ·4· ·he's using.· So she was very clear and on speakerphone ·5· ·saying, "Get out of the house.· It's not safe.· It ·6· ·doesn't sound safe.· Get out."· And he heard it and it ·7· ·was -- it -- it was like a -- um, like a -- he just -- he ·8· ·turned around, bolted back down the stairs, grabbed the ·9· ·phone, and -- and -- and started screaming at her even 10· ·louder this time and even worse this time.· And really 11· ·lit into her.· And I'm sitting on the couch.· I haven't 12· ·even gotten up off the couch.· My legs were cross-legged. 13· ·And -- and he -- and he -- he says, "You want her so 14· ·much, you -- you -- you dike bitch, you want to be her 15· ·man now, you want to be a man to her now, you can fucking 16· ·have her."· And he winds up his hand -- he winds his arm 17· ·back and he throws the phone at me.· And it -- it hits 18· ·me, bam, right in the -- what felt like the eye.· And it 19· ·just felt like this pop or what I thought was a pop and 20· ·it -- it just felt -- I -- it felt -- I -- and I put my 21· ·head in my hands and when I had my head covered, I didn't 22· ·know what he was doing or where he was going, but I had 23· ·my head down and I was saying -- I think I was crying and 24· ·I said, "You've hit me."· It -- it -- it -- it -- and 25· ·then I -- I could hear him yelling and knocking things U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 93 YVer1f Amber Laura Depp Vol II August 13, 2016 305 ·1· ·over.· And I wanted him to know that -- that he had hurt ·2· ·me because sometimes he wouldn't remember these ·3· ·incidences.· And so I remember I said, "Johnny, you -- it ·4· ·hit me in the eye."· And I don't know -- it felt like ·5· ·my -- it just felt like -- um, it felt like my eye or it ·6· ·could have been my eye and I didn't know, you know, um. ·7· · · · ·Q· ·Okay.· Before we get to the injuries, let me ·8· ·just ask you about what you say happened with Ms. Tillett ·9· ·Wright. 10· · · · ·A· ·Sure. 11· · · · ·Q· ·Was she on the phone during all of this? 12· · · · ·A· ·Yes.· But at the time, I wasn't sure.· Because 13· ·the phone, after it impacted my face, fell on the ground. 14· ·So . . . 15· · · · ·Q· ·Okay.· Isn't it true that, Ms. Heard, you 16· ·yelled to Tillett Wright to call 911? 17· · · · ·A· ·I -- I don't remember yelling that.· I'm sure 18· ·I -- I -19· · · · ·Q· ·Okay. 20· · · · · · ·MR. HARDER:· Well -21· · · · · · ·THE WITNESS:· I'm sure I -- I -- I yelled, 22· ·"Help.· Help."· I don't know what -- it was traumatic. 23· ·BY MS. BERK: 24· · · · ·Q· ·Isn't it the truth, Ms. Heard, that you swore 25· ·in your declaration at line 11, page 3, that I then U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 94 YVer1f Amber Laura Depp Vol II August 13, 2016 306 ·1· ·yelled out, quote, "Call 911," end quote? ·2· · · · ·A· ·Yeah.· Then I -- then I said that.· This was ·3· ·taken immediately after and it's been a while. ·4· · · · ·Q· ·Okay.· So you did yell to -- for Tillett Wright ·5· ·to call 911 -·6· · · · ·A· ·Yeah. ·7· · · · ·Q· ·-- correct? ·8· · · · ·A· ·Yeah. ·9· · · · ·Q· ·Okay.· But didn't you testify earlier that you 10· ·had kept these abuse allegations secret? 11· · · · ·A· ·Not from everybody. 12· · · · ·Q· ·Okay.· So -13· · · · ·A· ·There was -- like I said earlier to you, my 14· ·select -- my select group was starting to become more and 15· ·more informed of it as time went on.· So at the very 16· ·beginning, I would only tell my mom who -- somebody who 17· ·understands this sort of situation.· And then I -18· · · · ·Q· ·So your mom? 19· · · · ·A· ·And then I -20· · · · ·Q· ·You told her that you had been physically 21· ·abused by Johnny Depp? 22· · · · ·A· ·Yeah.· I would tell her from the -- almost -23· ·almost at the very beginning I confided in her.· That's 24· ·why I had pictures.· Yeah. 25· · · · ·Q· ·Okay.· So from the very beginning, to this U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 95 YVer1f Amber Laura Depp Vol II August 13, 2016 307 ·1· ·incident, May 21, you had confided in your mom? ·2· · · · ·A· ·Yeah.· I think I probably hid the first few ·3· ·incidences, but very very soon into it, I started to tell ·4· ·her. ·5· · · · ·Q· ·Okay.· And you confided in other people, ·6· ·including your friends, correct? ·7· · · · ·A· ·Therapists until -- until it became ·8· ·problematic.· Um -·9· · · · ·Q· ·Okay.· When you confided in your therapist -10· ·when did you confide in your therapist that you've been a 11· ·victim of domestic violence? 12· · · · · · ·MR. HARDER:· I'm -- I'm just going to object on 13· ·the grounds of the therapist privilege. 14· · · · · · ·THE WITNESS:· Okay. 15· · · · · · ·MS. BERK:· She's just told us what she told her 16· ·therapist, therefore, under the law, she's waived any 17· ·claim as to privilege for me asking her what she told her 18· ·therapist. 19· · · · · · ·MR. HARDER:· Well, that may have been 20· ·inadvertent.· I'm -- I'm asserting it right now.· If I -21· ·if I didn't catch it the first time, it was probably 22· ·quick and I apologize. 23· ·BY MS. BERK: 24· · · · ·Q· ·Ms. Heard, when did you have this conversation 25· ·with your therapist about these events?· We don't have to U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 96 YVer1f EXHIBIT 24 Amber Laura Depp Vol II August 13, 2016 · · · · · · SUPERIOR COURT OF THE STATE OF CALIFORNIA · · · · · · · · ·FOR THE COUNTY OF LOS ANGELES · · · ·In re the Marriage of · · ·Petitioner:· AMBER LAURA DEPP · · · · · · · · ·and· · · · · · · · · · · No. BD641052 · · ·Respondent:· JOHN CHRISTOPHER DEPP · · · · · · · · · II (AKA JOHNNY DEPP) · · ·________________________________ · · · · · · · · VIDEOTAPED DEPOSITION OF AMBER LAURA DEPP · · · · · · · · · · · · · VOLUME II · · · · · · · · · · · ·August 13, 2016 · · · · · · · · · · 10:00 a.m. - 7:04 p.m. · · · · · · · · ·2049 Century Park East, Suite 800 · · · · · · · · · ·Los Angeles, California · · · · · · ·Reported by: · · ·PAMELA J. FELTEN · · ·CSR No. 5189 U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 98 Amber Laura Depp Vol II August 13, 2016 312 ·1· · · · ·Q· ·Okay. ·2· · · · ·A· ·-- but it was -- it didn't hurt me. ·3· · · · ·Q· ·Okay.· And was there any other act of violence ·4· ·against you prior to when he went upstairs, came back ·5· ·downstairs and threw the phone? ·6· · · · ·A· ·I don't -- I don't know if you'd count ·7· ·screaming at me -·8· · · · ·Q· ·Okay. ·9· · · · ·A· ·-- or -- but no -10· · · · ·Q· ·Other than -11· · · · ·A· ·-- physical. 12· · · · ·Q· ·Okay.· Other than screaming, had he broken 13· ·anything in the apartment yet -14· · · · ·A· ·Um -15· · · · ·Q· ·-- on the floor? 16· · · · ·A· ·I'm not sure. 17· · · · ·Q· ·You're not sure? 18· · · · ·A· ·I'm not sure. 19· · · · ·Q· ·Okay.· Had he thrown any bottles prior to your 20· ·saying he threw this phone? 21· · · · ·A· ·I'm not sure.· I'm not -- I can't remember now. 22· ·I'm not sure what -- what he did prior to throwing the 23· ·phone at me. 24· · · · ·Q· ·Okay.· Was there any broken glass on the -- on 25· ·the floor where you were prior to his throwing the phone U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 99 YVer1f Amber Laura Depp Vol II August 13, 2016 313 ·1· ·at you? ·2· · · · ·A· ·Was there any broken glass on the floor around. ·3· · · · ·Q· ·Anywhere on the floor of the room you both were ·4· ·in prior to when he threw the phone at you that you were ·5· ·aware of. ·6· · · · ·A· ·At this moment, I don't remember there being ·7· ·any. ·8· · · · ·Q· ·Okay.· Okay.· And after you say he threw the ·9· ·phone at you, what happened next? 10· · · · · · ·(Sotto voce discussion among petitioner's 11· · · · · · · counsel off the record) 12· · · · · · ·THE WITNESS:· Um, all I remember is him 13· ·screaming these expletives at my friend iO and telling 14· ·her that he -- that she could have me now and then he 15· ·threw his arm back and he threw the phone -16· ·BY MS. BERK: 17· · · · ·Q· ·Okay. 18· · · · ·A· ·-- at what appeared to be very -- as hard as he 19· ·could at my face.· I put my head down.· I said, "You hit 20· ·me."· I was crying.· I said, "Johnny, you hit me," 21· ·because then I start hearing things being smashed.· And I 22· ·said to him, "Honey, you hit me.· You hit me in the eye. 23· ·My eye.· My eye."· And I start crying and I -- he 24· ·approaches me, and I don't know if he -- if I, in feeling 25· ·him approach, anticipate to try to get up or if I help U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 100 YVer1f Amber Laura Depp Vol II August 13, 2016 314 ·1· ·him help me up or if he just did it all by grabbing my ·2· ·hair, but for some reason, I mean, I had some aid in ·3· ·getting up off the couch by him -- him grabbing my head, ·4· ·mostly on my right side like a -- the impact of which was ·5· ·significant in and of itself.· He grabs my -- he grab -·6· ·grabs my head, takes a fist full of my hair and says, "I ·7· ·hit your eye?· I hit your eye, huh?· Let me see your eye. ·8· ·Let me see.· Let me see your eye.· What if I pull your ·9· ·hair back?"· And he yanks my head back and he's -- I 10· ·don't know, smacking my face or moving my face or -- and 11· ·he's got me by the hair and he's, um -- it's hard to 12· ·describe.· It's -- he was like yanking me from side to 13· ·side with my -- with my hair. 14· · · · ·Q· ·Are you standing up at this time? 15· · · · ·A· ·Yeah. 16· · · · ·Q· ·Okay.· And has he pulled out any hair from your 17· ·head? 18· · · · ·A· ·I -- he's still holding on to my head -19· · · · ·Q· ·Okay. 20· · · · ·A· ·-- at this time and he said -- um, I don't know 21· ·if he's trying to grab my face or he's hitting my face. 22· ·I don't know what's happening, but he's yelling at me, 23· ·he's screaming about -- about my -- about "Let's see how 24· ·hard I hit you."· And -- and I'm screaming at the top of 25· ·my lungs -- U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 101 YVer1f Amber Laura Depp Vol II August 13, 2016 315 ·1· · · · ·Q· ·Okay. ·2· · · · ·A· ·-- "Help, help.· Please help."· I guess I say ·3· ·call 911.· I'm screaming for help, not just in case iO is ·4· ·on the phone, which I don't know, because the phone is ·5· ·somewhere -- after hitting my face, I don't know where it ·6· ·ricocheted and bounced off to -- but it's on the floor. ·7· ·I can only hope she's on the line.· But I know and guess ·8· ·security is somewhere.· And even though they never ·9· ·respond when I'm screaming "Help" ever, I'm screaming 10· ·"Help" as loud as I can.· I also text Rocky previous, 11· ·"It's amping up.· It's getting crazy again.· Please just 12· ·I need you to come over."· Because I thought another 13· ·third party might be -- a third party being present helps 14· ·always to -15· · · · ·Q· ·Is it your testimony -16· · · · ·A· ·-- calm things.· Because I -17· · · · · · ·MR. HARDER:· Can we take a -18· ·BY MS. BERK: 19· · · · ·Q· ·Is it your testimony, Ms. Heard, that -20· · · · · · ·MR. HARDER:· Can we take a break, please. 21· · · · · · ·MS. BERK:· No. 22· · · · · · ·MR. HARDER:· She's upset.· She's upset. 23· · · · · · ·MS. BERK:· She has not -24· · · · · · ·MR. HARDER:· It's clear that she -- yeah. 25· ·She's crying and she's upset. U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 102 YVer1f Amber Laura Depp Vol II August 13, 2016 316 ·1· · · · · · ·THE WITNESS:· It's okay. ·2· · · · · · ·MR. HARDER:· Blair, how can you possibly force ·3· ·her to answer questions -·4· · · · · · ·MS. BERK:· Because I see -·5· · · · · · ·MR. HARDER:· -- when she's crying -·6· · · · · · ·MS. BERK:· -- the witness is not -·7· · · · · · ·MR. HARDER:· -- and upset? ·8· · · · · · ·MS. BERK:· -- upset and hasn't requested. ·9· · · · ·Q· ·Do you need to take a -10· · · · · · ·MR. HARDER:· I'm requesting -11· ·BY MS. BERK: 12· · · · ·Q· ·-- a break -13· · · · · · ·MR. HARDER:· -- on her behalf. 14· ·BY MS. BERK: 15· · · · ·Q· ·-- Ms. Heard? 16· · · · · · ·MR. HARDER:· Yes. 17· · · · · · ·THE WITNESS:· Yes. 18· · · · · · ·MS. BERK:· Let the record reflect Mr. Harder is 19· ·answering for Ms. Heard yes -20· · · · · · ·THE WITNESS:· I answered as well. 21· · · · · · ·MS. BERK:· -- and Ms. Heard -22· · · · · · ·MR. HARDER:· She -23· · · · · · ·MS. BERK:· -- responded yes. 24· · · · · · ·We'll take a break and go off record at this 25· ·time. U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 103 YVer1f EXHIBIT 25 VIDEO See Attached CD/DVD Recommended Media Player - VLC Media Player Heard - MTD Exhibits - 104 EXHIBIT 26 VIDEO See Attached CD/DVD Recommended Media Player - VLC Media Player Heard - MTD Exhibits - 105 EXHIBIT 27 Amber Laura Depp Vol II August 13, 2016 · · · · · · SUPERIOR COURT OF THE STATE OF CALIFORNIA · · · · · · · · ·FOR THE COUNTY OF LOS ANGELES · · · ·In re the Marriage of · · ·Petitioner:· AMBER LAURA DEPP · · · · · · · · ·and· · · · · · · · · · · No. BD641052 · · ·Respondent:· JOHN CHRISTOPHER DEPP · · · · · · · · · II (AKA JOHNNY DEPP) · · ·________________________________ · · · · · · · · VIDEOTAPED DEPOSITION OF AMBER LAURA DEPP · · · · · · · · · · · · · VOLUME II · · · · · · · · · · · ·August 13, 2016 · · · · · · · · · · 10:00 a.m. - 7:04 p.m. · · · · · · · · ·2049 Century Park East, Suite 800 · · · · · · · · · ·Los Angeles, California · · · · · · ·Reported by: · · ·PAMELA J. FELTEN · · ·CSR No. 5189 U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 107 Amber Laura Depp Vol II August 13, 2016 342 ·1· · · · ·Q· ·And he broke wine bottles? ·2· · · · ·A· ·I don't know to what ex- -- what -- I don't ·3· ·know what things he broke in front of them or what ·4· ·happened -- I am on the couch crying, being covered by my ·5· ·best friend after having this happen to me, so I have ·6· ·limited ability to tell you what exactly was broken ·7· ·when -- when Jerry or Sean's eyes are pointed in any ·8· ·specific direction. ·9· · · · ·Q· ·And you're claiming that Sean Bett and Jerry 10· ·Judge stood there and did nothing, though, while this was 11· ·happening, correct? 12· · · · ·A· ·They weren't there the whole time. 13· · · · ·Q· ·During the period they were there, your claim 14· ·is that they did nothing, correct? 15· · · · ·A· ·They walked in and most of it had been done. 16· ·Um, he had already, um, charged at me till Raquel threw 17· ·herself in between us, put her arms up to protect us.· He 18· ·had already pushed Raquel's arms away, intimidated her. 19· ·We're both back down on the couch.· She's protecting me 20· ·and he's screaming at me at the top of his lungs, which I 21· ·can only guess served as the impetus to get Jerry Judge 22· ·and Sean into the room.· While he's screaming at -- at me 23· ·and I'm looking down and he's screaming at me and taking 24· ·a step closer and screaming louder each time, "Get the 25· ·fuck up, Amber.· Get the fuck up.· Get the fuck up. U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 108 YVer1f Amber Laura Depp Vol II August 13, 2016 343 ·1· ·Amber, you hear me?· Get the fuck up." ·2· · · · · · ·And I can only imagine, because it was so loud ·3· ·toward the end, that they came in.· I -- so I can't tell ·4· ·you the exact moment, was it at the third threat or the ·5· ·tenth threat when they walked in, but at some point they ·6· ·walked in -·7· · · · ·Q· ·Was -·8· · · · ·A· ·-- and -·9· · · · ·Q· ·Was -10· · · · ·A· ·-- he turned his head and I hopped up off the 11· ·couch, ran to the side corner of the room and said, 12· ·"Jerry, help me.· If he hits -- if he hits me one more 13· ·time, I will call the -- I will call the police." 14· · · · ·Q· ·But you'd already asked to call 911 by that 15· ·point, correct? 16· · · · ·A· ·I didn't know if iO was even on the phone when 17· ·I was screaming. 18· · · · · · ·MS. BERK:· Objection.· Nonresponsive.· Move to 19· ·strike. 20· · · · ·Q· ·You had already asked to call 911 by the time 21· ·you say Jerry Judge was there, correct? 22· · · · ·A· ·That's incorrect, because that's to assume that 23· ·I knew somebody -- I had somebody to whom I could ask to 24· ·call. 25· · · · ·Q· ·Did you ask to call 911 prior to when Jerry U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 109 YVer1f EXHIBIT 28 VIDEO See Attached CD/DVD Recommended Media Player - VLC Media Player Heard - MTD Exhibits - 110 EXHIBIT 29 Heard - MTD Exhibits - 112 . .. . urns/1i .. 3. 1f}, "at! Heard - MTD Exhibits - 119 EXHIBIT 3O Heard - MTD Exhib Amber Laura Depp Vol II August 13, 2016 · · · · · · SUPERIOR COURT OF THE STATE OF CALIFORNIA · · · · · · · · ·FOR THE COUNTY OF LOS ANGELES · · · ·In re the Marriage of · · ·Petitioner:· AMBER LAURA DEPP · · · · · · · · ·and· · · · · · · · · · · No. BD641052 · · ·Respondent:· JOHN CHRISTOPHER DEPP · · · · · · · · · II (AKA JOHNNY DEPP) · · ·________________________________ · · · · · · · · VIDEOTAPED DEPOSITION OF AMBER LAURA DEPP · · · · · · · · · · · · · VOLUME II · · · · · · · · · · · ·August 13, 2016 · · · · · · · · · · 10:00 a.m. - 7:04 p.m. · · · · · · · · ·2049 Century Park East, Suite 800 · · · · · · · · · ·Los Angeles, California · · · · · · ·Reported by: · · ·PAMELA J. FELTEN · · ·CSR No. 5189 U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 121 Amber Laura Depp Vol II August 13, 2016 356 ·1· · · · ·Q· ·Did you ever tell any officers at your house on ·2· ·May 21, 2016 that the -- that Johnny Depp had ever done ·3· ·anything wrong to you that night or before? ·4· · · · ·A· ·You're asking me if I've told them -·5· · · · ·Q· ·If you -·6· · · · ·A· ·-- that he -·7· · · · ·Q· ·-- told them on May 21, yes. ·8· · · · ·A· ·Again, I said to them, "I decline to give any ·9· ·statement at this time as per the advice of my counsel." 10· · · · ·Q· ·Did the police -11· · · · ·A· ·They did make a comment to me about it seeming 12· ·unsafe, that's why they needed to check the apartment. 13· ·They made a gesture to my face.· They said I looked hurt. 14· ·They also pulled me aside and said, "Look, just say -15· ·just say a statement.· We can make sure you're safe, just 16· ·say statement or give us a statement and we'll go get the 17· ·guy."· And they said the exact same thing to Josh. 18· · · · ·Q· ·Is it your testimony that a police officer on 19· ·May 21 -20· · · · ·A· ·Yes. 21· · · · ·Q· ·-- told you that it appeared you looked hurt? 22· · · · ·A· ·He gestured -- he or she gestured, I can't 23· ·remember which one, to my face and said, "It's -- we can 24· ·tell you've been hurt" or "You don't look good" or 25· ·something to that effect, but I don't remember the exact U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 122 YVer1f Amber Laura Depp Vol II August 13, 2016 357 ·1· ·words they used. ·2· · · · ·Q· ·But something to that effect? ·3· · · · ·A· ·Yes. ·4· · · · ·Q· ·Is it your testimony -- well, let me ask you. ·5· ·Did the officers ever say they saw enough to arrest ·6· ·Johnny when they were with you on May 21, 2016? ·7· · · · ·A· ·Well, they said to both myself and Josh that ·8· ·all I needed to do was give a statement in order for them ·9· ·to go get the guy or go make an arrest.· Maybe they 10· ·didn't use the word arrest to me, but . . . 11· · · · ·Q· ·And your testimony is here today that one of 12· ·the officers told you that? 13· · · · ·A· ·Yes. 14· · · · ·Q· ·And was it a male officer or female officer? 15· · · · ·A· ·Like I said, I -- I -- I -- really I can't 16· ·remember which one it was. 17· · · · ·Q· ·During -18· · · · ·A· ·They asked -19· · · · ·Q· ·-- the time the police arrived -- from the time 20· ·the police arrived till they left, did you ever at any 21· ·time call any other human being on a telephone? 22· · · · · · ·MR. HARDER:· What? 23· ·BY MS. BERK: 24· · · · ·Q· ·While the police were at your property on 25· ·Broadway, did you ever call on the telephone any other U.S. LEGAL SUPPORT (800) 993-4464 Heard - MTD Exhibits - 123 YVer1f EXHIBIT 31 VIDEO See Attached CD/DVD Recommended Media Player - VLC Media Player Heard - MTD Exhibits - 124 EXHIBIT 32 Heard - MTD Exhib Sat, May 21,1024 PM No. Johnny came over" to talk" . His mom just died. Then he went sideways. Convinced of some CRAZY shit. Beat on me. Cops were called. They just left. Filing a restraining order. Divorce goes through on Monday. My face looks stupid and swollen. Bad night. need us to come over now?! Heard - MTD Exhibits - 126 need us to come over now?! And get you Cops came back. It's okay. Rock and josh are helping me. All okay Sorry I couldn't communicate earlier. text you tomorrow if that's okay. Sun, May 22, 3:31 PM Thinking of you Heard - MTD Exhibits - 127 EXHIBIT 33 Heard - MTD Exhib MTD Exhibits- 129 Heard - MT - MTD Exhibits - 132 EXHIBIT 34 Clerk stamps date here when form is filed. Request for Domestic HI Violence Restraining Order You must also complete Form CLETS-001, Confidential CLETS Information, and give it to the clerk when you file this Recpiest. fioN£&^°L%°rv (^T) Name of Person Asking for Protection: AMRF.R Age: 3-0. DF.PP LAURA Your lawyer in this case (ifyou have one): Name: Firm Name: spectcr taw, 3V G^'e information. Ifyou do not have a lawyer andwant to keep your home address private, give a different mailing address instead. You do not City: T,ns anodes, orltfor Telephone: (310) PARK SUTTF. FAST, 200 LOS Zip: State: Fax: 282-9478 (310) 220-3889 (T) Name of Person You Want Protection From: DEPP, TT (AKA JOHNNY ddrels: ANGELES , OA 90012 CENTRAL Court fills in case number when form is filed. E-Mail Address: F.Ffa.FPFCTORT.AWFTRM . COM JOHN CHRISTOPHER Fill in court name and street a Superior Court of California, County of LOS ANGELES 111 NORTH HILL STREET 111 NORTH HILL STREET have to give your telephone, fax, or e-mail): CENTURY Shem R- Carter, Executi ve Officer/Clerk a proffer t on at. t.aw corporation Address (Ifyou have a lawyerfor this case, give your lawyer's Address: 1Q?S MAY 2 7 201 o State Bar No.: sprctor. f.so rrmrntpr f Case Number: BD 641 052 nFPP) Description of person you want protection from: Sex: [&J M XI F Height: 3 1 1 0 " Eye Color: Brom Hair Color: R1 ark Weight: 1 7 5 Age: 52. Race: Whi t.o Date of Birth: 6/0/1 063 Address (ifknown): Zip: State: City: (jT) Do you want an order to protect family or household members? XI Yes Ifyes, list them: Sex Full Name Age Relationship to you Lives with you? ? Yes I (XI No I No ? Yes ? No ? Yes ? No I Check here ifyou need more space. Attach a sheet ofpaper and write "DV-100, Protected People "for a title. 1 What is your relationship to the person in © ? (Check all that apply): a. 1X1 We are now married or registered domestic partners. b. ? We used to be married or registered domestic partners. c. 1X1 We live together. Ifyou do not have one of these relationships, the court may not be able to consider your request. Read D V-500-INFQ for help. d. 1X1 We used to live together. e. XI We are related by blood, marriage, or adoption (specify relationship): f. XI We are dating or used to date, or we are or used to be engaged to be married. g. XI We are the parents together of a child or children under 1 8: Child's Name Date of Birth: Child's Name Date of Birth: Child's Name Date of Birth: XI Check here ifyou need more space. Attach a sheet ofpaper and write "DV-100, Protected People "for a title. h. XI We have signed a Voluntary C)eclaratioi^^ateniitWb^u^hild or children. (Attach a copy ifyou have one). This is not a Court Order. Reused ^^ 120HM^dat^ry FoTrn^5 — Family code, § 6200 et seq. P Domestic Violence Restraining Order Request for (Domestic Violence Prevention) DV-100, Page 1 of 5 Martin Dean's Essential Forms'" AMBER LAURA DEPP Heard - MTD Exhibits - 137 ,mber: Case BD 641 052 (T) Other Court Cases a. Have you or any other person named in © been involved in another court case with the person in ©? Ifyes, check each kind ofcase and indicate where and when each was filed: Year Filed Case Number (if known) County or Tribe Where Filed Kind of Case (XI Yes ? No XI Divorce, Nullity, Legal Separation 201 6 LASH BP 641 052 ? Civil Harassment XI Domestic Violence XI Criminal XI Juvenile, Dependency, Guardianship ? Child Support XI Parentage, Paternity XI Other (specify): 1 I Check here ifyou need more space. Attach a sheet ofpaper and write "DV-100, Other Court Cases "for a title. b. Are there any domestic violence restraining/protective orders now (criminal, juvenile, family)? XI Yes Ifyes, attach a copy ifyou have one. IXl No Check the orders you want. 0 (T) XI Personal Conduct Orders 1 ask the court to order the person in © not to do the following things to me or anyone listed in a. XI Harass, attack, strike, threaten, assault (sexually or otherwise), hit, follow, stalk, molest, destroy personal property, disturb the peace, keep under surveillance, impersonate (on the Internet, electronically or otherwise), or block movements b. XI Contact, either directly or indirectly, in any way, including but not limited to, by telephone, mail or e-mail or other electronic means The person in © will be ordered not to take any action to get the addresses or locations ofany protected _ person unless the court finds good cause not to make the order. (T) XI Stay-Away Order yards away from (check all that apply): a. I ask the court to order the person in ©to stay at least 1 00 XI Me fXl My vehicle XI My home l XI My job or workplace XI Each person listed in © XI My school XI Other (specify): I The child(ren)'s school or child care b. If the person listed in © is ordered to stay away from all the places listed above, will he or she still be able to get to his or her home, school, job, workplace, or vehicle? XI Yes XI No (Ifno, explain): (T) XI Move-Out Order (If the person in © lives with you and you want that person to stay awayfrom your home, you must askfor this move-out. order.) I ask the court to order the person in ©to move out from and not return to (address): ft 4 9 S . Rrnarlway Avpnnpf T,os An gel en , OA 9001 4 I have the right to live at the above address because (explain): ma r i f,a 1 res i Hence This is not a Court Order. Revised July 1, 2014 7. rtl '-'¦'5 Request for Domestic Violence Restraining Order DV-100, Page 2 of 5 (Domestic Violence Prevention) SSENTIAL FORMS"" DEPP - 138 LAURA AMBER Heard - MTD Exhibits -> Case Number: BD 641 052 (V) Guns or Other Firearms and Ammunition I believe the person in © owns or possesses guns, firearms, or ammunition. ? Yes ? No El I don't know Ifthe judge approves the order, the person in (2) will be ordered not to own, possess, purchase or receive a firearm 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 firearms that he or she owns or possesses. (To) El Recorc* Unlawful Communications 1 ask for the right to record communications made to me by the person in © that violate the judge's orders. (iT) El Care of Animals I ask for the sole possession, care, and control of the animals listed below. I ask the court to order the person in yards away from and not take, sell, transfer, encumber, conceal, molest, attack, @ to stay at least 1 00 strike, threaten, harm, or otherwise dispose of the following animals: Pi s.f. o 1 Yorkshire Terrier I ask for the animals to be with me because: XI i s my pet (12) ? Child Custody and Visitation a. ? I do not have a child custody or visitation order and 1 want one. b. ? 1 have a child custody or visitation order and I want it changed. Ifyou askfor orders, you must fill 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). (T3) ? Child Support (Check all that apply): a. ? I do not have a child support order and 1 want one. b. ? I have a child support order and I want it changed. c. ? I now receive or have applied for TANF, Welfare, CalWORKS, or Medi-Cal. Ifyou askfor child support orders, you must fill out and attach Form FL-I50, Income and Expense Declaration or Form FL-155, Financial Statement (Simplified). (^4) E Property Control 1 ask the court to give only me temporary use, possession, and control of the property listed here: Real property "locotod at 849 ¦ Broadway Avenue, Tina Angelfts,—CA 9001 4 (js) ? Debt Payment I ask the court to order the person in © to make these payments while the order is in effect: El Check here ifyou need more space. Attach a sheet ofpaper and write "DV-100, Debt Payment "for a title. For: Pay to: Amount: $ Due date: (^6) El Property Restraint I am married to or have a registered domestic partnership with the person in ©. 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. Revised July 1, 2014 7~a Martin Dean's Essential Forms " Request for Domestic Violence Restraining Order DV-100, Page 3 of 5 (Domestic Violence Prevention) DEPP- 139 LAURA AMBERHeard - MTD Exhibits Case Number: BD 641 052 (7?) ? Spousal Support I am married to or have a registered domestic partnership witli the person in © and no spousal support order exists. I ask the court to order the person in © to pay spousal support. (You must complete, file, and serve Form FL-150, Income and Expense Declaration, before your hearing). (J) IX] Insurance I ask the court to order the person in© NOT to cash, borrow against, cancel, transfer, dispose of, or change the beneficiaries of any insurance or coverage held for the benefit of me or the person in ©, or our child(ren), for whom support may be ordered, or both. (77) (2J 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, file, and serve Form FL-150, Income and Expense Declaration, before your hearing. (20) ? Payments for Costs and Services I ask the court to order the person in © to pay the following: You can askfor lost earnings or your costsfor services caused directly by the person in © (damaged properly, medical care, counseling, temporary housing, etc.). You must bring proof of these expenses to your hearing. Pay to: For: Amount: $ Pay to: For: Amount: $ (77) IX] 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. (22) X] Other Orders What other orders are you asking for? 52-week,s of anger management, courses. I Check here ifyou need more space. Attach a sheet ofpaper and write "DV-100, Other Orders "for a title. I (23) 1X1 Time for Service (Notice) The papers must be personally served on the person in © at least five days before the hearing, unless the court orders a shorter time for service. Ifyou want there to be fewer than five days between service and the hearing, explain why below. For help, read Form DV-200-INFO, "What Is Proof of Personal Service?" (24) No Fee to Serve (Notify) Restrained Person Ifyou want the sheriff or marshal to serve (notify) the restrained person about the orders for free, ask the court clerk what you need to do. (25) 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-1 12, Waiver of Hearing on Denied Request for Temporary Restraining Order, for more information. This is not a Court Order. Revised July 1,2014 0 V) Mariln Deans ential Forms " Request for Domestic Violence Restraining Order DV-100, Page 4 of 5 -> (Domestic Violence Prevention) LAURA AMBERHeard - MTD DEPP- 140 Exhibits Case Number: BD 641 052 26J Describe Abuse Describe how the person in (2) 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. Dale of most recent abuse: b. Who was there? c. Describe how the person in (2) abused you or your child(ren): Bp 1 f 5/21 / 2 0 1 6 7--fa.qponrlpnf. npnlflr^f inn of Ppt.itinnpr Ambor T.aura Depp fXl Check here ifyou need more space. Attach a sheet ofpaper and write " DV-100, Recent Abuse "for a title. d. Did the person in (2) use or threaten to use a gun or any other weapon? ?No e. Describe any injuries: Spp f. Did the police come? ? No attached ? Yes (Ifyes, describe): Peel a rat i on—and—Fxh i hi t. a ?Yes If yes, did they give you or the person in (2) an Emergency Protective Order? !? Yes 1x1 No (? I don't know Attach a copy ifyou have one. The order protects g. ? you or ? the person in (2) Has the person in (2) abused you (or your children) other times? Ifyes, ? check here and use Form DV-101. Description of Abuse or describe any previous abuse on an attached sheet ofpaper and write ""DV-100, Previous Abuse"/or a title. (27) Other Persons to Be Protected The persons listed in item (3) need an order for protection because (describe): (J) 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 above is true and correct. \ Date: May 2 6, 201 6 2 AMRF.R LAURA DEPP Type or print your name Date: May ¦SAMANTHA 26, F . ( SPFCTOR, - Sign your name / 201 6 Lawyer 's name, ifyou have one Jy?- / ESQ Lawyer's signature This is not a Court Order. Revised July 1, 2014 & Martin Dean's " . Essential forms'" Request for Domestic Violence Restraining Order (Domestic Violence Prevention) DV-100, Page 5 of 5 - MTD Exhibits AMBERHeard LAURA DEPP- 141 DECLARATION OF PETITIONER AMBER LAURA DEPP Heard - MTD Exhibits - 142 1 In re Marriage of DEPP 2 ATTACHMENT TO FORM DV-100 L.A.S.C. Case No. BD 641 052 3 DECLARATION OF AMBER LAURA DEPP 4 I, AMBER LAURA DEPP, declare as follows: 5 1. 6 I am the Petitioner herein. I have firsthand personal knowledge of the facts stated herein and if called as a witness, I could and would competently testify thereto. 2. 7 I submit this declaration in support of my Request for CLETS Domestic Violence 8 Restraining Orders against Respondent John Christopher Depp II aka Johnny Depp ("Johnny"). 9 I am also requesting pendente lite spousal support, exclusive possession of the residence located 10 at 849 S. Broadway in downtown Los Angeles ("Broadway residence"), exclusive possession of 11 the 2015 Range Rover vehicle, and attorneys' fees. 3. 12 13 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. 14 4. During the entirety of our relationship, Johnny has been verbally and physically 15 abusive to me. 16 has included angry, hostile, humiliating and threatening assaults to me whenever I questioned 17 his authority or disagreed with him. 18 5. I endured excessive emotional, verbal and physical abuse from Johnny, which Johnny has a long-held and widely-acknowledged public and private history of 19 drug and alcohol abuse. 20 exceptionally scary for me as it has proven many times to be physically dangerous and/or life- 21 threatening to me. Johnny relationship with reality oscillates, depending upon his interaction with 22 alcohol and drugs. As Johnny's paranoia, delusions and aggression increased throughout our 23 relationship so has my awareness of his continued substance abuse. 24 extremely afraid of Johnny and for my safety. 25 Broadway residence, to which he has full access to despite my repeated pleas to his security 26 team to prevent otherwise and to protect me, if restraining orders are not immediately issued. 27 I 28 management courses and a Batterer's intervention program. strongly believe that in He has a short fuse. addition to He is often paranoid and his temper is Because of this, I am I am petrified he will return at any moment to the DVROs, Johnny also requires enrollment in anger SPECTOR LAW 1925 CENTURY PARK Page 1 EAST, SUITE 200 LOS ANGELES, CA 90067 310.282.9478 DECLARATION OF AMBER LAURA DEPP Heard - MTD Exhibits - 143 1 In re Marriage of DEPP Recent Events Supporting the Basis of the Instant DVRO Request 2 3 L.A.S.C. Case No. BD 641 052 6. Since early 2013 and throughout the entirety of our marriage, Johnny and I have 4 resided at the Broadway residence. 5 requesting exclusive possession and use of the 3 unit condominium (i.e., Units 3, 4 and 5). 6 7. The residence is compromised of connected units. I am On April 21, 2016, I celebrated my birthday with my friends at the Broadway 7 residence. As everyone was preparing to leave my birthday party, Johnny showed up, inebriated 8 and high. After my guests had left, Johnny and I had a discussion about his absence from my 9 birthday celebration which deteriorated into a bad argument that started with Johnny throwing a 10 magnum size bottle of champagne at the wall and a wine glass on me and the floor -both which 11 shattered. Johnny then grabbed me by the shoulders and pushed me onto the bed, blocking the 12 bedroom door. He then grabbed me by the hair and violently shoved me to the floor. Johnny was 13 also screaming and threatening me, taunting me to stand up. After several minutes, Johnny 14 stormed out of the condominium, but not before tossing aside and breaking nearly everything in 15 his path. 16 8. I did not see Johnny again for another month. 17 9. The next time I saw him was on May 21 , 201 6. He arrived at the Broadway 18 residence at approximately 7:1 5 p.m. He was inebriated and high. At the time of Johnny's arrival, 19 my friend Elizabeth Marz was present, along with my friend Raquel Rose Pennington and her 20 fiance Joshua Drew who live in the adjacent apartment at the Broadway residence. 21 10. When Johnny arrived, at first, we were having a peaceful conversation in our living 22 room talking about his mother's passing as I tried to comfort him while we sat on the couch. 23 Suddenly, he began obsessing about something that was untrue and his demeanor changed 24 dramatically. 25 trusted employees to alleviate his misplaced concerns, but it did not work. 26 11. He became extremely angry. I tried to calm Johnny down by calling one of his Johnny was becoming increasingly enraged. I began to have concerns for my 27 safety and sent a text to my friend Raquel who was in the condominium next door. I texted her 28 to ask her to come over. As Johnny continued to rant in an aggressive and incoherent manner, SPECTOR LAW 1925 CENTURY PARK Page 2 EAST, SUITE 200 LOS ANGELES, CA 90067 310.282.9478 DECLARATION OF AMBER LAURA DEPP Heard - MTD Exhibits - 144 L.A.S.C. Case No. BD 641 052 1 In re Marriage of DEPP 2 he then demanded we call our friend iO Tillet Wright ("iO") to prove his paranoid and irrational 3 accusations about some delusional idea he was having. 4 12. As my call to iO went through on speaker phone, Johnny ripped the cell phone 5 from my hand and began screaming profanities and insults at iO. I heard iO yell at me to get out 6 of the house. Johnny then grabbed the cell phone, wound up him arm like a baseball pitcher and 7 threw the cell phone at me striking my cheek and eye with great force. 8 9 1 3. 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, 10 challenged whether or not the cell phone actually hit me. He then forceably pulled back my hair 11 as I attempted to stand up from the sofa. I then yelled out "Call 911"- hoping it would be heard 12 by iO who was still on the phone. Johnny continued screaming at me, pulling my hair, striking me 13 and violently grabbing my face. 14 15 16 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. 17 Raquel ran in between us and begged Johnny to stop. He then slapped away her arms that she 18 had extended in a defensive manner and continued to yell obscenities at her. 19 16. I retreated to the couch. Raquel then came over to covered me in a protectively 20 posture, while Johnny then picked up the magnum size bottle of wine he had been drinking out 21 of, and he started swinging it around, smashing everything he could. 22 17. Johnny then stormed at me once again, demanding that I get up and stand. He 23 did this - about ten times - getting closer to me, louder and more threatening each time. 24 Johnny's security team, that included, Judge Jerry, entered the condominium atthistime, butthey 25 stood back without saying or doing anything. I yelled to Jerry to please help me and told him that 26 if Johnny hit me one more time I was going to call the police. I heard Jerry say, "Boss, Please." 27 28 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 SPECTOR LAW 1925 CENTURY PARK EAST, SUITE 200 LOS ANGELES, CA 90067 310.282.9478 Page 3 DECLARATION OF AMBER LAURA DEPP Heard - MTD Exhibits - 145 L.A.S.C. Case No. BD 641 052 1 In re Marriage of DEPP 2 went into the adjoining condominium unit I use as my office, painting studio and closet. I could 3 hear him destroying items of my personal property as he continued screaming. 4 5 6 7 8 9 1 9. Joshua and Raquel took me into their condominium for safety. Eventually I did not hear Johnny any more. 20. Collectively attached hereto as Exhibit "A" 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 10 of Domestic Violence restraining orders. 11 domestic violence with Johnny, in particular there was one severe incident in December 2015 12 when I truly feared that my life was in danger. 13 22. There also have been several prior incidents of In addition to the DVROs I am seeking, as I have no place to live other than the 14 Broadway residence (my home for the past two years), I am requesting exclusive use and 15 possession of said property. I also require exclusive use and possession of the Range Rover 16 vehicle, which I am currently using. 17 23. Further, I am requesting possession of my dog Pistol. Although Johnny is extremely wealthy, he refuses to provide me with any direct 18 financial support. Concurrent with this filing I am providing an Income and Expense Declaration. 19 I am requesting $50,000 a month as and for pendente lite spousal support based on our marital 20 lifestyle. 21 24. Except as to that which is based on information and belief, I have personal 22 knowledge of the matters set forth herein and, and if sworn as a witness, I could and would 23 competently testify thereto. 24 pursuant to Code of Civil Procedure §§ 2009 and 2015.5, California Rules of Court, Rule 5.1 18(f), 25 and Reiflerv. Superior Court (1974) 39 Cal.App.3d 479. 26 27 This declaration is being submitted in lieu of personal testimony 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 signature on DV-1QQ form 28 AMBER LAURA DEPP SPECTOR LAW 1925 CENTURY PARK Page 4 EAST, SUITE 200 LOS ANGELES, CA 90067 310.282.9478 DECLARATION OF AMBER LAURA DEPP Heard - MTD Exhibits - 146 DECLARATION OF RAQUEL ROSE PENNINGTON Heard - MTD Exhibits - 147 1 In re Marriage of DEPP 2 ATTACHMENT TO FORM DV-100 L.A.S.C. Case No. BD 641 052 DECLARATION OF RAQUEL ROSE PENNINGTON 3 4 I, RAQUEL ROSE PENNINGTON, declare as follows: 5 1. 6 I have firsthand personal knowledge of the facts stated herein and if called as a witness, I could and would competently testify thereto. 2. 7 I submit this declaration in support of Petitioner AMBER LAURA DEPP's ("Amber") 8 RequestforCLETS Domestic Violence Restraining Orders against Respondent John Christopher 9 Depp II aka Johnny Depp ("Johnny"). 3. 10 I have been friends with Amber since 2003. My fiance Joshua Drew and I live in 11 one of the condominiums located at 849 South Broadway in Los Angeles. 12 condominium units which Amber shares with Johnny. 4. 13 I have a key to the On May 21, 2016, I was in my condominium with Joshua when I received a text 14 message from Amber at approximately 8:06 p.m., asking me to come over to her condominium 15 unit. 16 5. I immediately went over to Amber's place. When I got to the door, I could hear 17 Amber and Johnny arguing inside. 18 I quickly ran back to my apartment to get my key to open Amber's door. 6. 19 I knocked on the locked door, but there was no answer, so I returned to Amber's condominium less than a minute later. When I opened the 20 door, I saw Amber by the couch in the living room covering her head with her arms and hands, 21 as Johnny was loudly screaming at her. 7. 22 I ran over and stood in between Johnny and Amber, begging Johnny to stop yelling 23 at her. 24 hands away and screamed foul obscenities at me. I then tried to covered Amber up with my body 25 to protect her from him. 26 I put my hands out in a defensive manner motioning him to stop. 8. Johnny slapped my Johnny picked up a magnum size bottle of wine and began swinging it like a 27 baseball bat. Wine was flying all over the walls, floors and furniture, and he began using the 28 bottle to smash everything he could. SPECTOR LAW 1925 CENTURY PARK EAST, SUITE 200 LOS ANGELES, CA 90067 Page 1 DECLARATION OF RAQUEL ROSE PENNINGTON 310,282.9478 Heard - MTD Exhibits - 148 1 In re Marriage of DEPP 9. 2 L.A.S.C. Case No. BD 641 052 He then charged at Amber, screaming at her to stand up. He repeatedly yelled 3 at Amber to stand up -- about ten times - and each time, he got closer, louder and more 4 threatening. 10. 5 6 stood back and did not say or do anything. 1 1. 7 8 Johnny's security team then arrived, which included Jerry Judge, but they each Amber pleaded with Jerry to help and said that if Johnny hit her one more time she was going to call the police. 9 12. Jerry said "Boss. Please." 10 1 3. Johnny continued screaming and breaking things, before finally walking out of the 11 apartment and into the hallway where he continued screaming and breaking things. 14. 12 13 personal belongings and artwork, and continue to scream and break things. 15. 14 15 I could hear Johnny go into Amber's private condominium, where she keeps her Joshua came into the condominium unit and together we took Amber into our condominium unit for safety. 16. 16 I observed that Amber sustained a significant injury to her right eye as a result of 17 the incident with Johnny, as there was redness and swelling. Amber was crying, shaking and very 18 afraid of Johnny. 17. 19 20 Finally, I heard Johnny leave the premises. I then took pictures of Amber's face which are attached as Exhibit "A" to the Declaration of Amber. 18. 21 Many times over the past few years, Amber has confided and complained to me 22 about Johnny's abusing her, both physically and verbally. 23 III 24 III 25 III 26 27 28 SPECTOR LAW 1925 CENTURY PARK EAST, SUITE 200 LOS ANGELES, CA 90067 Page 2 DECLARATION OF RAQUEL ROSE PENNINGTON 310.282.9478 Heard - MTD Exhibits - 149 1 2 In re Marriage of DEPP 19. L.A.S.C. Case No. BD 641 052 Except as to that which is based on information and belief, I have personal 3 knowledge of the matters set forth herein and, and if sworn as a witness, I could and would 4 competently testify thereto. 5 pursuant to Code of Civil Procedure §§ 2009 and 2015.5, California Rules of Court, Rule 5.1 18(f), 6 and Reifler v. Superior Court (1974) 39 Cal.App.3d 479. 7 8 This declaration is being submitted in lieu of personal testimony I declare, under penalty of perjury pursuant to the laws of the State of California, that the foregoing is true and correct. Executed this 27th day of May, 2016 at Los Angeles, California. 9 10 see facsimile signature on next page RAQUEL ROSE PENNINGTON 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SPECTOR LAW 1925 CENTURY PARK EAST, SUITE 200 LOS ANGELES, CA 90067 310.282.9478 Page 3 DECLARATION OF RAQUEL ROSE PENNINGTON Heard - MTD Exhibits - 150 1 2 L.A.S.C. Case No. BD 641 052 In re Marriage of DEPP 19. Except as to that which is based on information and belief, I have personal 3 knowledge of the matters set forth herein and, and if sworn as a witness, I could and would 4 competently testify thereto. This declaration is being submitted in lieu of personal testimony 5 pursuant to Code of Civil Procedure §§ 2009 and 20 15. 5, California Rules of Court, Rule 5.1 18(f), 6 and Reifler v. Superior Court (1974) 39 Cal.App.3d 479. 7 8 I declare, under penalty of perjury pursuant to the laws of the State of California, that the foregoing is true and correct. Executed this 27th day of May, 2016 at Los Angeles, California. 9 10 RAQUEL ROSE PENNINGTON 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SPECTOR LAW 1925 CENTURY PARK EAST, SUITE 200 LOS ANGELES, CA 90067 Page 3 DECLARATION OF RAQUEL ROSE PENNINGTON 310.282.9478 Heard - MTD Exhibits - 151 EXHIBIT A ¦ ; / - m A 3p? I * iP 1 \ / fi n /£ f f' X IM'i j ' f/ /« 7 : % ; Vi* fP ij & IIIV *"• f p ,r. 1 r ¦' ib? V feft, - H ¦. Km r ¦ -- W \ $ i a I ya K w \ / B f •a ? t s SP rn S i I Heard - MTD Exhibits - 153 V m ft; ; f vVf.' r' w mrggap* rM ¦ Kf. ' i< il ^ I, w. m /i i' i ¦ 1 '¦ A i * 'i F.v \ [, ffl f 30 Heard - MTD Exhibits - 154 ft # / ~r&er- /J/ i / // J 'li '/ 5 £ /IF/ 58? 'if 5^ r - ' JT^' •r-V . - ' * F P; 7? V 5 Vi VJ IjJ I ¦Y ; ' /, ff, i 'i?; ;'i /. I H V. ,ii / I * \ !J / f > i 5 J Heard - MTD Exhibits - 155 1 2 SAMANTHA F. SPECTOR, ESQ. (State Bar 204482) SPECTOR LAW, A Professional Law Corporation CONFORMED COPY 1925 Century Park East, Suite 200 Superior Court of California County of Los Angeles ORIGINAL FILED Los Angeles, California 90067 3 Telephone: 310.282.9478 Facsimile: 310.220.3889 MAY 2 7 2016 4 5 Sherri R. Carter, Executive Officer/Clerk Attorneys for Petitioner, AMBER LAURA DEPP By Gestelle Gammage, Deputy 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 11 12 13 14 In re the Marriage of: CASE NO. BD 641 052 Petitioner: Judge: Hon. Carl H. Moor Department: 6 AMBER LAURA DEPP and Respondent: JOHN CHRISTOPHER DEPP II (AKA JOHNNY DEPP) 15 DECLARATION OF SAMANTHA F. SPECTOR, ESQ. RE EX PARTE NOTICE AND IN SUPPORT OF PETITIONER AMBER LAURA DEPP'S DVRO REQUEST Date: Time: Dept.: 16 17 May 27, 2016 8:30 a.m. 6 18 19 I, SAMANTHA F. SPECTOR, declare as follows: 20 1. I am an attorney at law duly licensed to practice before all court of the State of 21 California and I am the managing attorney at Spector Law, APLC, attorneys of record for 22 Petitioner, Amber Laura Depp, herein. 23 herein and if called as a witness, I could and would competently testify thereto. EX PARTE NOTICE GIVEN 24 25 I have firsthand personal knowledge of the facts stated 2. On May 26, 2016, at approximately 9:45 a.m., I telephoned Respondent John 26 Christopher Depp ll's ("Johnny") counsel, Laura Wasser, Esq. I asked to speak to Ms. Wasser 27 and was told she was not available. I then requested to speak to Samantha Klein, Esq., and was 28 also told she was unavailable. I was then directed to voicemails for both; instead I asked to speak SPECTOR LAW 1925 CENTURY PARK EAST, SUITE 200 LOS ANGELES, CA 90067 310282,9478 Page 1 DECLARATION OF SAMANTHA F. SPECTOR, ESQ. Heard - MTD Exhibits - 156 1 to Ms. Wasser's assistant, Linda Bigbee, and was told she too was unavailable and directed to 2 her voicemail. 3 3. I left a voicemail for Ms. Wasser at 9:45 a.m. and advised her that Petitioner, 4 Amber Laura Depp ("Amber"), would be appearing ex parte at 8:30 a.m. on Friday, May 27, 2016, 5 in Department 6 of the Los Angeles Superior Court located at 1 1 1 North Hill Street, Los Angeles, 6 California 9001 2 on the instant matter. Specifically, I stated that Amber would be requesting a DV 7 CLETSTRO against Respondent John Christopher Depp II ("Johnny"), including requests for: (1) 8 pendente lite spousal support payable by Johnny to Amber; (2) Amber's exclusive use and 9 possession of the 849 S. Broadway residence; (3) exclusive use and possession of the black 10 Range Rover vehicle which Amber is currently driving; (4) Amber's exclusive possession of the 11 dogs, Pistol and Boo; and (5) a contributive payment by Johnny for Amber's attorney fees and 12 accounting costs. 13 4. I then sent a follow-up email to Ms. Wasser stating all of the above in writing, and 14 copying Ms. Klein and Ms. Bigbee. 15 May 26, 2016 at 9:52 a.m., confirming my ex parte notice, is attached hereto as Exhibit "A." 16 5. A true and correct copy of my email to Ms. Wasser dated Thereafter, at approximately 9:59 a.m. I was able to speak directly to Mrs. Klein 17 and I advised her of all of the above via telephone. 18 ATTEMPTS TO RESOLVE ISSUES PRIOR TO INSTANT EX PARTE AND DVRO REQUEST 19 20 21 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. 22 I stated that, although Amber had been attacked and remained in fear for her safety, given the 23 notoriety of both parties and the high likelihood of press harassment, Amber would prefer to settle 24 the matter amicably out of Court. A true and correct copy of my letter to Mr. Bloom dated May 25 24, 2016, is attached hereto as Exhibit "B." 26 27 I declare, under penalty of perjury pursuant to the laws of the State of California, that the foregoing is true and correct. Executed this 27th day of May 2016, at Los Angeles, California. W-- 28 SPECTOR LAW 1925 CENTURY PARK EAST, SUITE 200 LOS ANGELES, CA 90067 310.282.9478 I ' SAMANTHA F. SPECTOR Page 2 DECLARATION OF SAMANTHA F. SPECTOR, ESQ. Heard - MTD Exhibits - 157 EXHIBIT A Heard - MTD Exhib Samantha F. Spector From: Samantha F. Spector Sent: Thursday, May 26, 2016 9:52 AM To: Laura Wasser Cc: 'Samantha Klein'; 'Linda Bigbee' Marriage of Depp - EX PARTE NOTICE 5/27/201 6 8:30 am Dept 6 LASC Subject: 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 assista nt 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 applica tion to seeks a DV CLETS TRO order against Johnny Depp which will include requests for (1) pendente lite spousa l support payable by Johnny to Amber; (2) Amber's exclusive use and possession of the 849 S. Broadway residen ce; (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 90067 310.282.9478 Office 310.220.3889 Fax lit! I j ^ NOT ICE: 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, confidenti al 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 e-mail. If you have received this e-mail in error, please immediately contact the sender by reply e mail, telephone, or facsimile. 1 Heard - MTD Exhibits - 159 EXHIBIT Heard - MTD Exhib EXHIBIT Heard - MTD Exhibits - 161 >r i i I 0 RV LAW 1V25 < x'litun l'ark I >.ist. Sum- 200, 1..* \iu.;dt>. < ..tlilomu Onoo" 3 !0.2S2.9-l~S icl 31t).22u.3X,S'i fax S.WI WTI I \ I- SI'l :< . i < )K •>ybhdrl.com Re: In re Marriage of Depp Dear Mr. Bloom: Please be advised that our firm has filed a Petition for Dissolution of Marriage on behalf of Amber Depp. As you may be aware, your client and Amber's husband, Johnny Depp, violently attacked and threatened Amber on Saturday night, May 215t, in their penthouse apartment located at 849 S. 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 In fact, there have been two other incidents in the past six months. Although against Amber. Amber is afraid of Johnny, she strongly insists that we do everything possible to keep this personal matter out of the 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 movie 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 promptly sign and return by Friday, May 27, 2016, the enclosed Notice and Acknowledgment of Receipt form (FL-117 form) confirming service of the Summons, Petition, Family Law Case Cover Sheet and blank Response (FL-120 form). If the requested Notice is not signed and the original executed form is not returned to me by May 27th, we will have no alternative but to arrange for Johnny to be personally served. In addition, we are requesting on Amber's behalf the following: (i) appropriate pendente lite support; (ii) exclusive use and possession of the black Range Rover, the vehicle she is currently Heard - MTD Exhibits - 162 driving, with Johnny to continue to make all payments for any encumbrances thereon; (iii) 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 SAMANTHA F. SPECTOR SFS:ks Enclosures cc: Client 2 Heard - MTD Exhibits - 163 EXHIBIT 35 ( ( Clerk stamps date here when form is filed. Notice of Court Hearing 0 Name of Person Asking for Order: AMRRR T.AURA Su DEPP Your lawyer in this case (if you have one): State Bar No.: ,204482 Name: samantha f. spec/tor Firm Name: qprerTOP t.aw, a proff.ppt htm at . t.aw cor por att dtj Address (If you have a lawyer for this case, give your lawyer's information. If you do not have a lawyer and want to keep your home City: t.os Pax: (71 0 ) 220 -7889 Telephone: J, 71 0) 2 8 2 -9478 . COM FTRM SS^SPECTORTiAW Address: E-Mail TT DEPP CHRISTOPHER LOS ANGELES 111 111 NORTH HILL NORTH HILL LOS ANGELES, STREET STREET CA 90012 CENTRAL (0) Name of Person to Be Restrained: ¦TORN .GestpHfi Gaiwnafle Superior Court of California, County of Zip: 90007 .State: CA amcf.t.f.c; —Deputy Fill in court name and street address: STTTTE 2HCL CENTURY PARK EAST. Executive Oiticer/Clerk Sherri By. address private, give a different mailing address instead. You do not have to give your telephone, fax, or e-mail.): Address: 1Q2S MAY 2 7 2016 Clerk fills in case number when form is filed. lAKA Case Number: DEPP) .TOHMNV The court will fill out the rest of this form. BD 641 052 0) 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: Sa Hearing ^ Date: Dept.: Date 4 Time: Room: - S V J - (0) 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 DV-100, Request for Domestic Violence Restraining Order, are: (1) QA11 granted until the court hearing (2) I I All denied until the court hearing (specify reasons for denial in (b)): (3) F/fPartly granted and partly denied until the court hearing (specify reasons for denial in (b)): b. Requested temporary restraining orders for personal conduct, stay away, and protection of animals are denied because: (1) ?The 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) ? The 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) G4 Further explanation of reason for denial, or reason not listed above: ST a r* F l-c . psv Ye* r ft r This is a Court Order. Judicial Council of California, www.courts.ca.gov Revised January 1, 2012, Mandatory Form Family Code, § 242, Approved by DOJ Notice of Court Hearing DV-109, Page 1 of 3 (Domestic Violence Prevention) JV _-)l Mnrilii CiJ Essential Fo mr Heard - MTD Exhibits - 165 ( Case Number: BD 641 052 (jT) Service ofJPocuments and Time for Service—for Person in (T) At least five or Qj days before the hearing, someone age 1 8 or older—not you or anyone else to he protecteaE^must personallvg ive (serve) a court's file-stamped copy of this form (DV-109, Notice of Court Hearing) to the person in (2J along with a copy of all the forms indicated below: a. Form DV-100, Request for Domestic Violence Restraining Order, (file-stamped) with applicable attachments b. Ly Form DV-1 10, Temporary 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 DV-250, Proof of Service by Mail (blank form) e. dl Other (specify): (fx -ti- Date: Judicial Officer carl h. moon Right to Cancel Hearing: Information for the Person in< 3 « If item (4) (a)(2) or (4) (a)(3) 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 DV-1 1 2, 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 (5) on the other p erson. If you want to keep the hearing date, you must have all of the documents listed in item (5) served on the other person • 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 DV-1 10 will end on the within the time listed in item (jf). • date of the hearing. To the Person in • Hi The court cannot make the restraining orders after the court hearing unless the person in (zf has been personally given (served) a copy of your request and any temporary orders. To show that the person in (2) has been served, the person who served the forms must fill out a proof of service form. Form DV-200, Proof of Personal Service may be used. • • For information about service, read Form DV-210-INFO, What Is "Proof of Personal Service"? If you are unable to serve the person in (2) in time, you may ask for more time to serve the documents. Read Form DV-1 15-INFO, How to Ask for a New Hearing Date. This is a Court Order. Revised January 1, 2012 Mni'lin Dam's I_J Essential Forms" Notice of Court Hearing (Domestic Violence Prevention) DV-109, Page 2 of 3 4 Heard - MTD Exhibits - 166 ( Case Number: BD 641 052 To the Person in • If you want to respond in writing, mail a copy of your completed Form DV-120, Response to Request for Domestic Violence Restraining Order, to the person in(T) and file it with the court. You cannot mail Form DV-120 yourself. Someone age 18 or older—not you—must do it. • To show that the person in (T) has been served by mail, the person who mailed the forms must fill out a proof of service form. Form DV-250, Proof of Service 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 DV-120-INFO, 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 www.courls.ca.gov/forms for Request for Accommodations by Persons With Disabilities and Response (Form MC-410), (Civil Code, § 54.8.) (Clerk will fill out this part.) —Clerk's Certificate— / im !'2f I I certify that this Notice of Court Hearing is a true and correct copy of the original on file ft i&l. wM? \ \9!Si w in the court. Date: HAY 2 *1 2016 Clerk- , Deputy Gestelle Garnmage This is a Court Order. Revised January 1. 2012 Notice of Court Hearing U _~V Miirliu Dm u'i • V. Ml FORMS" DV-109, Page 3 of 3 (Domestic Violence Prevention) Heard - MTD Exhibits - 167 ( ( DV-110 i ••• Clerk stamps date here when form is filed. Temporary Restraining Order Person in (?) must complete items (T) , (2) , and (3) only. Superior Court of California County of Los Angeles (T) Name of Protected Person: AMRFR T.ATTPA MAY 2 7 2016 DEPP Your lawyer in this case (ifyou have one): Name: samantha f. rprctdk Firm Name: sprc.tor law, Executive Oilicer/Clei k Sherri State Bar No.: 2 04 4 8?, ——Deputy By. Gestelle Garrfmags a professional taw corporation Address {If you have a lawyer for this case, give your lawyer's information. If you do not have a lawyer and want to keep your home Fill in court name and street address: address private, give a different mailing address instead. You do not Superior Court of California, County of have to give your telephone, fax, or e-mail): Address: City: T ,OS 192,5 CENTURY ANGELES PARK FAST, State: OA Telephone: (21 0)282-9478 LOS RUTTE 200 Zip: 9 0057 Fax: .(21 0) 220-2889 DEPP HILL STREET NORTH HILL STREET CA 90012 CENTRAL Court fills in case number when form is filed. (T) Name of Restrained Person: CHRISTOPHER NORTH 111 LOS ANGELES, E-mail Address: SSOSPECTORLAWFTRFi . COM JOHN ANGELES 111 Case Number: BD TT (AKA .TOHNMY 641 052 DEPP! Description of restrained person: Sex: (XI M ? F Height: 5 ¦ 1 0 " Weight: 125. Race: WHTTF, Hair Color: BLACK Eye Color: BROWN Date of Birth: 6/9/1 962 Age: 52 Address (if known): City: State: Zip: Relationship to protected person: HURRAND ®a In addition to the person named in (?) , the following persons are protected by temporary orders as indicated in items Additional Protected Persons (tf) and (7) (family or household, members): Relationship to person in G? Full name ? Sex Age Check here if there are additional protected persons. List them on an attached sheet of paper and write "DV-110, Additional Protected Persons" as a title. The court will complete the rest of this form. (T) Court Hearing This order expires at the end of the hearing stated below: Hearing Date: * IT fPO 1 6 Time: & ¦ 30 a.m. I I p.m. This is a Court Order. Judicial Council of California, www.courls.ca.gov Revised July 1, 2014, Mandatory Form Family Code, J 6200 et seq. Approved by DOJ MmfmD.'aii's J EssENfiAi Forms" Temporary Restraining Order DV-110, Page 1 of 6 (CLETS-TRO) (Domestic Violence Prevention) Heard - MTD Exhibits - 168 ( ( Case Number: BD 5 641 052 Criminal Protective Order a. QA criminal protective order on Form CR-160, Criminal Protective Order-Domestic Violence, is in etfect. Expiration Date: County: Case Number: b. G^No information has been provided to the judge about a criminal protective order. To the person in Q The court has granted the temporary orders checked below. If you do not obey these orders, you can be arrested and charged with a crime. You may be sent to jail for up to one year, pay a fine of up to $1,000, or both. (jp) Personal Conduct Orders ?Not requested ? Denied until the hearing a. You must not do the following things to the person in© and Granted as follows: ? persons in ® : VA Harass, attack, strike, threaten, assault (sexually or otherwise), hit, follow, stalk, molest, destroy personal property, disturb the peace, keep under surveillance, impersonate (on the Internet., electronically or other wise), or block movements wi Contact, either directly or indirectly, in any way, including but not limited to, by telephone, mail, e-mail or other electronic means I I Take any action, directly or through others, to obtain the addresses or locations of the persons in © and © . (If this item is not checked, the court has found good cause not to make this order.) b. Peaceful written contact through a lawyer or process server or another person for service of Form DV-120 (Response to Request for Domestic Violence Restraining Order) or other legal papers related to a court case is allowed and does not violate this order. c. ? Exceptions: Brief and peaceful contact with the person in © , and peaceful contact with children in @ , as required for court-ordered visitation of children, is allowed unless a criminal protective order says otherwise. (©) Stay-Away Order !? Not requested (? Denied until the hearing a. You must stay at least (specify): i Granted as follows: yards away from (check all that apply): fvK The person in © I I School of person in ©) ? The persons in @ I I The children's school or child care Home of person in © ? Other (specify): Sf The job or workplace of person in © Vehicle of person in© b. ? Exceptions: Brief and peaceful contact with the person in©, and peaceful contact with children in®, as required for court-ordered visitation of children, is allowed unless a criminal protective order says otherwise. ( 8 j Move-Out Order I - I Not requested I I Denied until the hearing CA G ( ranted as follows: You must take only personal clothing and belongings needed until the hearing and move out immediately from (address): -ST. 13rcoi<*u'6^ fcfi • t if?, f 4- This is a Court Order. Revised July 1, 2014 O) © Essential Forms'" Temporary Restraining Ord er DV-110, Page 2o^ (CLETS-TRO) (Domestic Violence Prevention) Heard - MTD Exhibits - 169 ( ( Case Number: BD 641 052 (T) 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 other way get guns, other firearms, or ammunition. b. You must: • Sell to, or store with, a licensed gun dealer, or turn in to a law enforcement agency, any guns or other firearms within your immediate possession or control. Do so within 24 hours of being served with this order. • Within 48 hours of receiving this order, file with the court a receipt that proves guns have been turned in, stored, or sold. (You may use Form DV-800, Proof of Firearms Turned In, Sold, or Stored, for the receipt.) Bring a court filed copy to the hearing. c. ? The court has received information that you own or possess a firearm. (To) Record Unlawful Communications ~~ ? Not requested !? Denied until the hearing ivfGranted as follows: The person in (7) can record communications made by you that violate the judge's orders. (jT) Care Of Animals ? Not requested 1 Denied until the hearing ? Granted as follows: The person in (T) is given the sole possession, care, and control of the animals listed below. The person in @ must stay at least yards away from and not take, sell, transfer, encumber, conceal, molest, attack, strike, threaten, harm, or otherwise dispose of the following animals: 12 \ Child Custody and Visitation fairs'ot requested ?Denied until the hearing (? Granted as follows: Child custody and visitation are ordered on the attached Form DV-140, Child Custody and Visitation Order or (specify other form): . The parent with temporary custody of the child must not remove the child from California unless the court allows it after a noticed hearing (Fam. Code, § 3063). (T3) Child Support Not ordered now but may be ordered after a noticed hearing. 14J Property Control (? Not requested ? Denied until the hearing [^Granted as follows: Until the hearing, only the person in(T)can use, control, and possess the following property: ioro } t ^ (T5) Debt Payment y- Mi Not requested ? Denied until the hearing ? A^-; PtAy)r<, C'(\ciOd Granted as follows: The person in @ must make these payments until this order ends: Pay to: For: Amount: $ Due date: Pay to: For: Amount: $ Due date: This is a Court Order. Revised July 1, 2014 It Martin Dam's ential Forms- Temporary Restraining Order (CLETS-TRO) DV-110, Page 3 of6 (Domestic Violence Prevention) Heard - MTD Exhibits - 170 ( > Case Number: BD (TeT) Property Restraint ? Not requested 641 052 ? Denied until the hearing ZfGranted as follows: If the people in © and ® are married to each other or are registered domestic partners, rWthe person in © CA 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 (2) cannot contact the person in © 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. (17) Spousal Support Not ordered now but may be ordered after a noticed hearing. (^18) Insurance VTA The person in © ZJ the person in (2) is ordered NOT to cash, borrow against, cancel, transfer, dispose of, or change the beneficiaries of any insurance or coverage held for the benefit of the parties, or their child(ren), if any, for whom support may be ordered, or both. (7?) Lawyer's Fees and Costs Not ordered now but may be ordered after a noticed hearing. (20) Payments for Costs and Services Not ordered now but may be ordered after a noticed hearing. (21s) Batterer Intervention Program Not ordered now but may be ordered after a noticed hearing. (j©) Other Orders ?Not requested zfDenied until the hearing ? Granted as follows: ~~ I I Check here if there are additional orders. List them on an attached sheet ofpaper and write "DV-110, Other Orders" as a title. (23) No Fee to Serve (Notify) Restrained Person If the sheriff serves this order, he or she will do so for free. HAY 2 7 2616 Ca Date: MAY ? 7 MfP ^-0 Judge (or Judicial Officer) Warnings and Notices to the Restrained Person in CARL H. StfOOR 3 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. Revised July 1. 2014 fcC)] Mmtiii Dean's I2SI Essential Forms " Temporary Restraining Order (CLETS-TRO) DV-1 1 0, Page 4 0(6 (Domestic Violence Prevention) Heard - MTD Exhibits - 171 ( Case Number: BD 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 effect. If you do, you can go to \ jail and pay a $1,000 fine. You must sell to or store with a licensed gun dealer or turn in to a f .".-i J 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 (2). If this address is incorrect, or to find out if the orders were made permanent, contact the court. Child Custody, Visitation, and Support Child custody and visitation: If you do not go to the hearing, the judge can make custody and visitation orders for • your children without hearing from you. • 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 (Simplified) (Form FL-155) or an Income and Expense Declaration (Form FL-150) 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 FL-150) 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 Is 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), 13701(b).) A violation of the order may be a violation of Penal Code section 166 or 273.6. If the 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, §137 10(b).) This is a Court Order. Revised July 1, 2014 ( Min i in Dean's ENTIAl FORMS'" Temporary Restraining Order (CLETS-TRO) DV-110, Page 5 (Domestic Violence Prevention) Heard - MTD Exhibits - 172 ( Case Number: BD 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 Fain. Code, §§ 6383(h), 6405(b)): 1. EPO: If one of the orders is an Emergency Protective Order { Form EPO-001), 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 nonconflicting 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 © » The custody and visitation orders are on Form DV-140, items® and @ . They are sometimes also written on additional pages or referenced in DV-140 or other orders that are not part of the restraining order. Forms DV-100 and DV-105 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 parlies 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 U.S. territories, commonwealths, and possessions and shall be enforced as if it were an order of that jurisdiction. ( Clerk will fill out this part.) mm , ft -Clerk's Certificate- * IB m I certify that this Temporary Restraining Order is a true and correct copy of the original on file in the court. HAY 2 7 2818 Date: \ Clerk, b '¦'s^Tornu Deputy Gesteiie Gammage This is a Court Order. Revised July 1,2014 (7 V] Mnrffri Ocmi'i J [ami fmr Temporary Restraining Order (CLETS-TRO) DV-110, Page 6 of 6 (Domestic Violence Prevention) Heard - MTD Exhibits - 173 EXHIBIT 36 4/5/2019 Amber Heard's Ex-Girlfriend Tasya van Ree Speaks Out Following Domestic Abuse Allegations E! News LATEST NEWS WATCH FULL EPISODES KARDASHIANS PHOTOS TV VERY CAVALLARI MEGHAN MARKLE Amber Heard's Ex-Girlfriend Tasya van Ree Speaks Out Following Domestic Abuse Allegations by LILY HARRISON Wed., Jun. 8, 2016 12:57 PM Trending Stories GET POP CULTURED! Enter Your Email SIGN ME UP! By subscribing to our newsletter you agree to the Privacy Policy and Terms of Use Dario Cantatore/Getty Images 1 Inside the Undying Fascination With Sharon Tate 2 Kylie Daily Jenner Straddles Travis Scott Weeklyin Sexy Vacation Photos HeardTeases - MTD Exhibits 175 of The ABC a New- Side https://www.eonline.com/news/771257/amber-heard-s-ex-girlfriend-tasya-van-ree-speaks-out-following-domestic-abuse-allegations 1/6 3 4/5/2019 Amber Heard's Ex-Girlfriend Tasya van Ree Speaks Out Following Domestic Abuse Allegations E! News Earlier this week, it was revealed that Amber Heard was arrested LATEST NEWS WATCH FULL EPISODES KARDASHIANS PHOTOS TV in 2009 after she and her then-girlfriend, Tasya van Ree, got into an 3 ABC Teases a New Side of The Bachelorette 's Hannah Brown MEGHAN MARKLE 4 Elisabeth Hasselbeck Tries to Quit The View in Resurfaced Audio 5 Mindy Kaling and BJ Novak Go on a Basketball Outing VERY CAVALLARI argument at an airport. The 30-year-old actress was taken into custody and booked for misdemeanor domestic violence after she allegedly struck Ree at the Seattle-Tacoma International airport. And while the two split years ago, Ree is speaking out in support of her ex-girlfriend. LATEST NEWS "In 2009, Amber was wrongfully accused for an incident that was misinterpreted and over-sensationalized by two individuals in a powerful position," her statement, which was obtained by E! News, began. "I recount hints of misogynistic attitudes toward us which alter 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." The Big Picture: Today's Hot Photos Photos Court Appearances Ree continued, "It's disheartening that Amber's integrity and story are being questioned yet again. Amber is a brilliant, honest and Trending Stories beautiful woman and I have the utmost respect for her. We shared 5 wonderful years together and remain close to this day." Channing Tatum and Jessie J's Night Out Will Details of the former couple's past incident went public in the wake Have You Stepping Up Your Next Date of Amber's divorce proceedings with Johnny Depp. Days after initially ling, she asked the court for a domestic violence restraining order against the actor, which was subsequently granted. Johnny's rep told E! News at the time, "Given the brevity of this marriage and the most recent and tragic loss of his mother, Johnny will not respond to any of the salacious false stories, gossip, misinformation and lies about his personal life. Hopefully, the Was Game of Thrones Just an Elaborate Way to Inside the Undying MakeFascination Maisie Williams and SophieSharon Turner Best With Friends? Tate 1 dissolution of this short marriage will be resolved quickly." For more information on domestic abuse or to get help for yourself/someone you love, visit the website for The National GET POP CULTURED! Enter Your Email Domestic Violence Hotline or call 1-800-799-7233. SIGN ME UP! 2 Kylie Daily Jenner Straddles Travis Scott Weeklyin Sexy Vacation Photos By subscribing to our newsletter you agree to the Privacy Policy and Terms of Use HeardTeases - MTD Exhibits 176 of The ABC a New- Side https://www.eonline.com/news/771257/amber-heard-s-ex-girlfriend-tasya-van-ree-speaks-out-following-domestic-abuse-allegations 2/6 3 4/5/2019 Amber Heard's Ex-Girlfriend Tasya van Ree Speaks Out Following Domestic Abuse Allegations E! 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Tate Sophia Hutchins Praises ''Amazing Loving Partner'' Caitlyn Jenner After… GET POP CULTURED! 1 Enter Your Email SIGN ME UP! 2 Kylie Daily Jenner Straddles Travis Scott Weeklyin Sexy Vacation Photos By subscribing to our newsletter you agree to the Privacy Policy and Terms of Use HeardTeases - MTD Exhibits 177 of The ABC a New- Side https://www.eonline.com/news/771257/amber-heard-s-ex-girlfriend-tasya-van-ree-speaks-out-following-domestic-abuse-allegations 3/6 3 4/5/2019 Amber Heard's Ex-Girlfriend Tasya van Ree Speaks Out Following Domestic Abuse Allegations E! News Nipsey Hussle’s of EPISODES LATEST NEWS Cause WATCH FULL KARDASHIANS PHOTOS TV 3 ABC Teases a New Side of The Bachelorette 's Hannah Brown MEGHAN MARKLE 4 Elisabeth Hasselbeck Tries to Quit The View in Resurfaced Audio VERY CAVALLARI Death Revealed Kourtney Kardashian and Scott Disick's Family Mindy Kaling and BJ Novak Pics Kim Kardashian Reveals Possible Family Name for 5 Go on a Basketball Outing Baby No. 4 J.Lo's a Hustler, Baby! LATEST NEWS Featured See Andy Cohen's Cutest Photos of Baby Benjamin Hilaria Baldwin Reveals She Is Most Likely Experiencing a Miscarriage If Your Cat Vomits (Do This Every Day) The Big Picture: Today's Hot Photos Ultimate Pet Nutrition Sponsored Fantastic Apartments in Los Angeles have Seniors Packing Their Bags Killing Eve Season 2 Finds Eve and Villanelle's Relationship "Bad in a Bad Way" Trending Stories The Most Successful Lawyers In Los Angeles. See The List Channing Tatum and Jessie J's Night Out Will Have You Stepping Up Your Next Date Latest News Bill Cosby's Attorney Fires Back After Settling of Defamation Case Was Game of Thrones Just an Elaborate Way to Inside the Undying MakeFascination Maisie Williams and SophieSharon Turner Best With Friends? Tate 1 GET POP CULTURED! Enter Your Email SIGN ME UP! 2 Kylie Daily Jenner Straddles Travis Scott Weeklyin Sexy Vacation Photos By subscribing to our newsletter you agree to the Privacy Policy and Terms of Use HeardTeases - MTD Exhibits 178 of The ABC a New- Side https://www.eonline.com/news/771257/amber-heard-s-ex-girlfriend-tasya-van-ree-speaks-out-following-domestic-abuse-allegations 4/6 3 4/5/2019 Amber Heard's Ex-Girlfriend Tasya van Ree Speaks Out Following Domestic Abuse Allegations E! 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Enter Your Email SIGN ME UP! 2 Kylie Daily Jenner Straddles Travis Scott Weeklyin Sexy Vacation Photos By subscribing to our newsletter you agree to the Privacy Policy and Terms of Use HeardTeases - MTD Exhibits 180 of The ABC a New- Side https://www.eonline.com/news/771257/amber-heard-s-ex-girlfriend-tasya-van-ree-speaks-out-following-domestic-abuse-allegations 6/6 3 EXHIBIT 37 4/1/2019  iO Tillett Wright on Twitter: "BULLSHIT. I've had enough. I saw the bruises. Many times. And the fat lip. And the cut head. 😡😡😡 https://…  Home  Moments  Notifications iO Tillett Wright @iOlovesyou Messages Search Twitter     Follow Tweet  BULLSHIT. I've had enough. I saw the bruises. Many times. And the fat lip. And the cut head. m.tmz.com/#article/2016/ … 4:55 PM - 6 Jun 2016 124 Retweets 174 Likes   33 124 174    Tweet your reply    iO Tillett Wright @iOlovesyou  © 2019 Twitter About Help Center Terms Privacy policy  ♕ JOHNNY DEPP ♕ @fuckingjd · 6 Jun 2016 Cookies Ads info artist. author. agitator. host of TV things. @iolovesyou Replying on insta. to He.@iOlovesyou #ImWithJohnny nomad     bit.ly/balladofbillyb…  11  Joined November 2010 This Tweet is unavailable  Jamie @Harley_Smash · 7 Jun 2016 Replying to @iOlovesyou If you saw the evidence, why didn't you call him out? Call the police that you friend was in an domestic violence situation?   3   Karen Olsen @Virgofolkie · 7 Jun 2016 Replying to @iOlovesyou I'm not an attorney; but this seems weird to me from a legal standpoint. Such material is usually only shared between attorneys.   4  wyntersolstice @SkChavonneWitch · 7 Jun 2016 https://twitter.com/iOlovesyou/status/739969048104960000  Heard - MTD Exhibits - 182 1/1 iO Tillett Wright on Twitter: "How much evidence does a woman need to present?! She has photos, texts, witnesses, and filed a restraining… 4/1/2019   Home  Moments  Notifications iO Tillett Wright @iOlovesyou Messages Search Twitter     Follow Tweet  How much evidence does a woman need to present?! She has photos, texts, witnesses, and filed a restraining order. 4:56 PM - 6 Jun 2016 201 Retweets 283 Likes  iO Tillett @iOlovesyou  28 201 283   Tweet your reply   Wright   © 2019 Twitter About Help Center Terms Privacy policy  Mila @iAirborne · 7 Jun 2016 Ads info Cookies artist. author. agitator. host of TV things. @iolovesyou Replying on insta. to He.@iOlovesyou A lot more than that & rightfully so - otherwise anyone can send another to jail nomad with a bit of work on a computer.     bit.ly/balladofbillyb…  5  Joined November 2010 ♕ JOHNNY DEPP ♕ @fuckingjd · 6 Jun 2016 Replying to @iOlovesyou #ImWithJohnny   5   This Tweet is unavailable This Tweet is unavailable  Lili @Liaa09Lil · 7 Jun 2016 Replying to @iOlovesyou why does she needs spousal support then ?   https://twitter.com/iOlovesyou/status/739969182356275200 7  Heard - MTD Exhibits - 183 1/1 iO Tillett Wright on Twitter: "But no...a neighbor asked a doorman and talked to TMZ and THAT is headline news and serves as "evidence"… 4/1/2019   Home  Moments  Notifications iO Tillett Wright @iOlovesyou Messages Search Twitter     Follow Tweet  But no...a neighbor asked a doorman and talked to TMZ and THAT is headline news and serves as "evidence"?! Dear neighbor SHAME ON YOU. 4:57 PM - 6 Jun 2016 119 Retweets 188 Likes    iO Tillett Wright  @iOlovesyou 9 119   188 Tweet your reply  © 2019 Twitter About Help Center Terms Privacy policy Cookies Ads info artist. author. agitator. host of TV things. @iolovesyou Hazel on insta. He. Moon-#JohnnyDeppIsSilentNoMore #IBELIEVEHIM … · 7 Jun 2016    nomad Replying to @iOlovesyou  TRIAL BY MEDIA with Johnny automatically GUILTY because you HEARD bit.ly/balladofbillyb… something or Raquel saw him yelling is also WITCH HUNT. Joined November 2010   ♕ 9   ♕ @fuckingjd · 6 Jun 2016 Replying to @iOlovesyou #ImWithJohnny   9   Mila @iAirborne · 7 Jun 2016 Replying to @iOlovesyou The neighbor is as much a valid witness as you are. How is it that you're not ashamed to be a witness but they should be?   1 14  1 more reply Vegeta Solo @VegetaSolo1 · 21 Jun 2016 R l i t @iOl https://twitter.com/iOlovesyou/status/739969427534290944  Heard - MTD Exhibits - 184 1/1 iO Tillett Wright on Twitter: "This culture of victim blaming makes me sick. I'm a witness. I'm here. I'm standing up. I can't take any more of … 4/1/2019   Home  Moments  Notifications iO Tillett Wright @iOlovesyou Messages Search Twitter     Follow Tweet  This culture of victim blaming makes me sick. I'm a witness. I'm here. I'm standing up. I can't take any more of this witch hunt. 4:58 PM - 6 Jun 2016 219 Retweets 339 Likes  iO Tillett @iOlovesyou  27 219 339   Tweet your reply   Wright  © 2019 Twitter About Help Center Terms Privacy policy Cookies Ads info artist. author. agitator. host of TV This Tweet is unavailable things. @iolovesyou on insta. He.     nomad  ♕ ♕ @fuckingjd · 6 Jun 2016 bit.ly/balladofbillyb… Replying to @iOlovesyou Joined November#ImWithJohnny 2010   2 14   Bonnie Conway @BamaFantastique · 7 Jun 2016 Replying to @iOlovesyou You're a witness to WHAT? Her screaming? Heck, I can scream. Were you THERE? No! How much has she offered you? #initforthemoney  2  6  Jl0u @mummydiariesblg · 15 Jun 2016 depp let her & the other "witness" racquel live there for free and they got the hump when they had to move out.   3  Nicole Walker @WraithLette · 7 Jun 2016 Replying to @iOlovesyou #AmberHeardIsALiar #ImWithJohnn Depp https://twitter.com/iOlovesyou/status/739969865675476992   Heard - MTD Exhibits - 185 1/1 iO Tillett Wright on Twitter: "I was on the fucking phone when he hit her. I HEARD HER SCREAM. I will testify. Here and in court. Under oa… 4/1/2019   Home  Moments  Notifications iO Tillett Wright @iOlovesyou Messages Search Twitter     Follow Tweet  I was on the fucking phone when he hit her. I HEARD HER SCREAM. I will testify. Here and in court. Under oath. WHAT ELSE DOES A WOMAN NEED? 5:11 PM - 6 Jun 2016 230 Retweets 351 Likes    iO Tillett Wright  @iOlovesyou 77 230   351 Tweet your reply  © 2019 Twitter About Help Center Terms Privacy policy Cookies Ads info artist. author. agitator. host of TV things. @iolovesyou Its_Me_Kate @_LOVEINVAIN on insta. He. · 6 Jun 2016    nomad Replying to @iOlovesyou  Her problem is 1. her courting the media w/ these claims and 2. Asking for $50k bit.ly/balladofbillyb… monthly even as her lawyer says it's not abt $ Joined November 2010   5  lilojuicy @lilojuicy · 6 Jun 2016 Replying to @iOlovesyou  A witch hunt??!! Ok Johnny has been QUIET while she continues to lie repeatedly daily same as Australia. Rhianna was a victim   21  lilojuicy @lilojuicy · 6 Jun 2016 Replying to @iOlovesyou  Amber is looking for $$ and fucked up his mom just died she is evil/greedy. Look at Rhianna thats a real victim not cold sores.  2  29   lilojuicy @lilojuicy · 6 Jun 2016 her wolf cries make real abused women look bad. I hope Johnny gives her Heard - MTD Exhibits - 186 nothing and donates everything 2 real abuse victims https://twitter.com/iOlovesyou/status/739972938267385856 1/1 EXHIBIT 38 1 2 4 5 •ssk SPECTOR LA W, A Professional Law Corporation Samantha F. Spector (204482) 1 925 Century Park. East, Suite 200 Los Angeles, California 90067 m 1 3 m fetssser Telephone: 310.282.9478 Facsimile: 3 1 0.220.3889 Attorneys for Petitioner AMBER LAURA DEPP 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF LOS ANGELES 9 10 In Re Marriage of CASE NO. BD 641 1)52 11 Petitioner: Judge: Hon. Carl H. Moor Department: 6 12 and 13 Respondent: AMBER LAURA DEPP DECLARATION OF iO LILLET WRIGHT JOHN CHRISTOPHER DEPP 11 (AKA JOHNNY DEPP) Date: 6/17/2016 Time: 8:30 a.m. 14 15 16 17 18 .fv 19 IQi TO RESPONDENT JOHN CHRISTOPHER DEPP II (AKA JOHNNY DEPP) AND HIS ATTORNEYS OF RECORD: Petitioner AMBER LAURA DEPP hereby submits the declaration of iO TILLET WRIGHT 20 in further support of her request for a Domestic Violence CULTS Restraining Order against 21 Respondent JOHN CHRISTOPHER DEPP 11 aka JOHNN Y DEPP. <\ 22 23 SPECTOR LAW, A Professional Law Corporation DATED: June 13. 2016 24 vAJ 25 By: 26 SAMANTHA F. SPECTOR Attorney for Petitioner 27 AMBER LAURA DEPP 28 DECLARATION OF iO TILLET WRIGHT 1 Heard - MTD Exhibits - 188 erk L.A.S.C. BD 641 052 "n re Marriage of DEPP DECLARATION OF iO TILLET WRIGHT 1 2 I, iO TILLET WRIGHT, declare as follows: 3 1. I have firsthand personal knowledge of the facts stated herein and if called as a 4 witness, I could and would competently testify thereto. 5 2. I submit this declaration in support of Petitioner AMBER LAURA DEPP'S Request 6 for a CLETS Domestic Violence Restraining Order against Respondent JOHN CHRISTOPHER 7 8 9 DEPP II aka JOHNNY DEPP. 3. On the evening of May 21, 2016, 1 received a telephone call from Amber asking me 10 to talk to Johnny on the speakerphone, because he was very upset over something he thought ** someone had done to him. Amber said she wanted me to assist her in hopefully calming Johnny 12 down, by assuring him that what he believed had happened was not true. 13 4. Immediately thereafter, I heard Johnny launch into a cruel and vicious rage, 14 screaming "What if I pulled your hair back?" 15 16 17 18 19 5. I then heard Amber crying in fear and begging Johnny to stop his attack, thereafter I heard Amber scream out "Call 911" before the call discomiected. 6. I called 91 1 to save Amber's life. 7. Attached hereto as Exhibit "A" is a true and correct copy of the article I wrote about 20 the frequently abusive and tormenting relationship that I observed Amber having endured with 21 Johnny, before she finally found the strength and courage to stand up to his abusive behavior. 22 Signed under penalty ofpeijury, this date of June 13, 2016 at New York, New York. 23 See Attached Facsimile Signature 24 iO TILLET WRIGHT 25 26 27 28 Page 1 DECLARATION OF iO TILLET WRIGHT Heard - MTD Exhibits - 189 ¦Jun. 13. 20 6 No. 9469 3:95PM In re Marriage of DEPP 1 P. L.A.S-C. BP 641 052 DECLARATION OF iO TILLET WRIGHT 2 I, iO TILLET WRIGHT, declare as follows: 3 1. I have firsthand personal knowledge of the facts stated herein and if called as a 4 witness, I could and would competently testify thereto. 5 2, I submit this declaration in support of Petitioner AMBER LAURA DEPP'S Request 6 ^ 8 for a CLETS Domestic Violence Restraining Order against Respondent JOHN CHRISTOPHER DEPP n aka JOHNNY DEPP. •S 9 On the evening of May 21. 2016, 1 received a telephone call from Amber asking me 10 to talk to Johnny on the speakerphone, because he was very upset over something he thought 11 someone had done to him. Amber said she wanted tne to assist her in hopefully calming Johnny 12 down, by assuring hitn that what he believed had happened was not true. 13 4. Immediately thereafter, I heard Johnny launch into a cruel and vicious rage, 14 screaming "What if I pulled your hair back?" 15 16 17 18 19 5. I then heard Amber crying in fear and begging Johnny to stop his attack, thereafter I heard Amber scream out "Call 9 1 1" before the call disconnected. 6. I called 9 1 1 to save Amber' s life. 7. Attached hereto as Exhibit "A" is a true and correct copy of the article I mote about 20 the frequently abusive and tormenting relationship that I observed Amber having endured with 21 Johnny, before she finally found the strength and courage to stand up to his abusive behavior. 22 23 S igned under penalty of perjury, this date of June Npw ybrk^iw York. 24 25 iO TILLET ig; 26 27 28 Page I DECLARATION OF iO TD-LET WRIGHT Heard - MTD Exhibits - 190 EXHIBIT A Heard - MTD Exhibits - 191 NOW READING etry.1 Called 911 f

a A s NEWS sm Khloe Kardashian Tried i IVF to Save Her Marriage Kliloe Kardashian opened up in a big and bold way on this week's episode of Kocktails With Khloe. The talk show host # and reality star shared that she ... J ¦ ' - :1 CAROLYN L. TODD MAR 24, 2C16 Heard - MTD Exhibits - 195 : ! @ Wh\M ' B i uoV,»' ' L bfj r . fi 9 • ; .. L L I 1, i . , is ill , m NEWS NEWS MUSIC TRACKER Gordon Ramsay Celebs React To Christina Grimmie Shares Miscarriage Christina Grimmie's Of 'The Voice Killed News Death JUN 11, 2016 EVETTE DIONNE JUN 15, 2016 ERIN DONNELLY I iWt 4 . i ' SARA MURPHY JUN 11, 2016 i «?! !¦ Jtsf : i &=¦ L \ w . C ** NEWS NEWS NEWS Benicio Del Toro Bieber Brawls Over Actor Says Cousin Calls Amber Heard Autograph Stuck At Anti-Gay School "Manipulative" MICHAEL HAFFORD JUN 9, 2016 MICHAEL HAFFORD JUN 9, 2016 CAROLYN L. TODD JUN 9, 2016 Heard - MTD Exhibits - 196 J{ illiil il 11 NEWS jjjj ¦ ¦ iiws; nn Obama Talks Trump On ¦ Fallon Wm mm President Barack Obama is endorsing a candidate for president, but it's probably not who you imagined it would ¦ be. According to Variety, Obama joked on The Tonight Show ¦ that he and the Democrats are very happy with the GOP's ¦ presumptive nominee. But Obama, making his first appearance on Jimmy Fallon's Tonight Show, ... am *.... i.r' f, 1 ¦ f ; ¦ . "9* : i k ^ * 9 * . »l m p. I k NEWS NEWS NEWS Harry Styles' Home Conrad Hilton Dash Store Struck By Vandalized, Fans Call Heading To Jail After Attempted Arsonist For Respect Violating Plane Threats Probation MICHAEL HAFFORD © 2016 RSFINERY29 JUN 8, 20(6 TERMS PRIVACY J UN 7, 2016 MICHAEL HAFFORD ABOUT CONTACT PRESS ADVERTISING JOBS JUN 7, 2016 SABRINA ROJAS WEISS FEEDBACK R29 NEWS SITE MAP RSS Heard - MTD Exhibits - 197 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA. COUNTY OF LOS ANGELES 3 4 I am employed in the County of Los Angeles, State of Cal ifornia. I am over the age of 1 8 and not a party to the within action. My business address is 10866 Wilshire Boulevard, Suite 900, Los Angeles, 5 California 90024. 6 On June 13, 2016, 1 served the foregoing document described as 7 DECLARATION OF iO TILLET WRIGHT on the interested party(ies) in this action by placing 8 the original x a true copy thereof addresses as follows: 9 Laura Wasser 10 Law Offices Wasser, Cooperman & Mandles 2049 Century Park East, Suite 800 Los Angeles, CA 90067 11 12 BY MAIL: I am readily familiar with the firm's practice of collection and processing correspondence 13 for mailing. Under that practice, it would be deposited with the United States Postal Service on that 14 same 15 day with postage thereon fully prepaid at Los Angeles, California in the ordinary course of 16 business. 17 cancellation date or postage meter date is more than one day after date of deposit for mailing affidavit. 18 I am aware that on motion of the party served, service is presumed invalid if postal BY PERSONAL DELIVERY: 1 will hand the above document(s) to the above named person. x _ 19 _ BY FEDERAL EXPRESS (OVERNIGHT) MAIL. 20 FACSIMILE: I caused the above-named document to be transmitted via FACSIMILE as follows: 21 I declare under penalty of perjury that the above is true and correct. 22 Executed on June 13, 2016, at Los Angeles, California. 23 24 Samantha F. Spector 25 26 27 28 Page 1 Heard - MTD Exhibits - 198 EXHIBIT 39 Heard - MTD Exhib 9999999 ~r _y un ~~ ATTQRNEV OR PARTY VYfiH~JT' ATTOHMlEY(lyema. S~c~o Hal Wombat, dr+d edQr~;91: fOR t0flRT t1SE ONLY ' Laura A.Walser, Esq.('[73740)lSamantha Klein, Esq.(2224'{4) WASSER,COOPERMAAI & MANRLES, p.C. 2Q49 Cenfury Park East, Suite 840 Las Angelesn,CA 970067-3110 TELEPHONE NO.: tJ~ O~ ?f 7.71'i7 F~ Ho.r~~~a~~: ~3'f0)553-1793 •vV ~~~~~ E-MAtlA00RES3{OpdonafJ: 5VpQTIOt ~jV~ ~~ n,~o~~Foa~+~x~ John Christopher Depp II (~B~I~Ot!'fla County of ~QS Anc~~los SUPERIdR CdUAT OF CALIFORNIA]COUN7Y OF SrAE~A~aFss;{ ~'f9 North Hillt Sfreet MAILING AOURESS: 1~~ IVOI lI1 HI~! St(@fit ~~na~o z~P ~oo~:Los Angeles,ca 9ao12 awwcH N~~:CENTRAL dISTRICT ~ JAS I ~ 2017 sne~~~.~ ~~,~,v~ orr~cerrcisr~c ~v'~ ~h~ rPsiariP C~ ,n~~, MARRIAGE 0R PARTNERSHIP OF PETITIaNEFi;AMBER LAURA DERP RESPONOENr:JdHN CHRISi'd~HER QEPP f~ aka JOHN~lY DEPR JUDGMENT Q DISSOLUTION Q LEGAL SEPARATION Q NULl.1TY Q Status only Q Reserving jurisdiction over termination of marital or domestic partnership status 0Judgment an reserved issues — 3 pate marital or domestic partnership status ends: ~ A~ ~. ~~j7 cAse riuMeeR: BDC4'I052 [Assigned to Dept. 6, Roil. Car. H. Moor] i. Q This judgment Q contains personal conduct restraining orders Q modifies existing restraining ciders. The restraining orders are contained on pages) of the attachment. They expire on (date),2, This proceeding was heard as follows: Q De[aull or uncontested 0Sy declaration under Fatuity Coda section 2336 Q Contested ~gr~enl in court a. Date; Room. ~R ~~} Depf.:CC. b b..ludicial oFiice~ ~'a'me): ~,~~~ H, ~~,0~ Q Temporary judge c. Q Petitioner present in court ~ Attorney present in cauR {name). d. Q Respondent present in coon Q Attorney present in court (name): e. Q Claimant present in court (name):• Q Attorney present in court (trams). f. Q Other {specify name): ~~~~r ;'y3 3. The court acquired jurisdiclian of the respondent an (dale): May 25, 2D'E6 a. Q The respondent was served with process. b. ~]The respondent appeared. 7HE COURT ORDERS,GDOD CAUSE APPEARING 4. a. Q Judgment of dissolution is entered. Marital or domestic partnership status is terminated and the parties are restored to the status of single persons (iy Q on {specify date): ~~~~ 1 ~ Z~~1 (2)Q on a date to be determined on noticed motion o~ eitfler party or on stipulat7on. b. Q Judgment of legal separation is entered. c. Q Judgrnertt of nullity is entered. The parties are dedared to be single persons on the ground of {speafy): d. Q This judgment wi[I be entered nunc pro lunc as of (date}: e. Q Judgment on reserved issues. f. The(i~ petitioners ❑respondents tarmer name is restated to (spectfy}: AMBER LAURA FfEARD g. Q Jurisdiction is reserved over all other Issues, and all present orders remain In etfeal except as provided below. h, Q This judgment conlai~s provisions for child support or family support. Each party must complete and file with the court a Chrld Support Case Registry Form (form FL-19~) within 10 days of the date of this judgment. The parents must notify the court of anal change in the information subrrtitted within 1 Q days of the change, by filing an updated form, The Notice of Rights and Responsibrfitres--Nealth-Care Costs 8rrd Rerrribu~semenf Procedures and Informa(ion Sheet on ChaRgrng a Child Suppor[ Order(corm FL•1 S2)is attached. r~s.i or z Famiy Cade. yy zoz<,x~a. Form AdoDlod for Mandarory Uso JUDGMENT 2365,2546 JuQdal Council o(COfifOmld F1.180[Rav, Judy 1,2o12J {F8R1jIy L8W} www.c+ourtseayav r -, l~aaln Ormi1 rd ESSfNiIAI Fb9~" Heard - MTD Exhibits - 200 ~--. C r' CASE NAME{Las! name, /irsf name of each party): FL-180 cn5e Nurae~a: Marriage of Depp BD641052 4. J. Q The children of this marriage or domestic partrters~tip are: (1}0 Name B9rthdate (2) Q Parentage is establ"shed for children of this relat~anship bom prior to the marriage or domestic partnership I• Q Child custody and visilalion (parenting time} are ordered asset forth in the attached t1) Q Settlement agreement, stipulation for judgment, or other written agreement which tonlains the information required by Fatuity Code section 3Q48(a). (2} Q Child Custody and Vrsifatior~ OrderAliachmenf(form FL•341), (3)Q Stipulation and Order(or Custody and/or Visitation of Children {lorm FL-355). (4) Q Pre~ious{y established in another case. Case number: Court: k. Q Child support is ordered as set forth in the attached {ij Q Settlement agreement, stipulation for judgment, or other written agreement which contains the declarations required by Family Code section 40fi5{a). (2? Q ChJJd Support ~nlormaffon and OrderAtfachmend (form FL-342). (3)Q SIlpulaGon to Establish or MOdily Ch11d Serpporl and Order(form ~L-350), (4)Q Previously established in another case. Case number: Caurt: L Q Spousal, domestic partner, or family support is afdered: (i) ❑ Reserved for future determination as relates l0 0petitioner Q respondent (2)~ Jurisdiction terminated to order spousal or partner support to ~ petitioner Q respondent (3) Q As set[oMh in the attached Spousal, Par►ner, or Fam!!y Support Order A[tachment(form FL-3433. (4)Q As set forth in the attached settlement agreement, stipulation for judgment, or other writlen agreement. i5)O Other 1S1~~Yk m.0 Property division is ordered asset Forih in the attached (1) Q Settlement agreement, slipulatiorl for judgment, or other written agreement. {2} Q property QrderAttachmerrf bJudgment(form FL-345}. {3) Q Other (specify): n. Q Attorney lees and costs are ordered as set forth in the attached (1) ~] Settlement agreement, stipulalian for jadgment,orother written agreement. {2) Q Attorney Fees and Costs Order(form FL-346y, (3)[,Other (specify): o. Q Other (specr'fy): Each atlachmen~ to this judgment is incorporated Into th9s judgment, and the parties are ordered [o comply wish each atlachmenPs pro~isiens. Jurisdiction is reserved to make other orders necessary to carry out this judgment JUDICULL OFF10Efl 5. Number of pages attached: Q SIGNATUAEF4LLOWSLA$7ATfACHM~lT NOTICE pissofulion or legal separation may automatically cancel the rights of a spouse or domestic partner under the other spouse's ar domestic partners will, Dust, retirement plan, power of attorney, pay-on-death bank account, transfer-on-death vehicle registrafron, survivorship rights to any property owned in joint tenancy, and any other similar property interest, LI daes not sutornalically cancel the rights of a spouse or domestic partner as beoeficaary of the otter spouse's or domestic partners life insurance policy. You should review these matters, as weft as any credit cards, other credit accounts, insurance policies, retirement plans, and credit reports, to determine whether they should be changed or whether you should take any other aotions. A debt or obligation mey tae assigned to one party as part of t3~e dissolution of properly and debts, but if that parry does not pay the debt or obligation, the creditor may be able to collect from the other party. An earnings assignment maybe issued wilf~out addtional proof if child, family, partner, or spousal support is ordered. Any part}r required to pay suppor! must pay interest on overdue amounts at the'legaf rate,' which is currently 10 percent. FL•iaotae .~~~y,,zo+z1 ~,~ ~+.~,~a~ont fS~FNil81 FOGMS'" I~ .JUDGMENT (Family Law) aoQezorx Heard - MTD Exhibits - 201 ~.:1 i In re the Marriage of 2 Petitioner: 3 4 5 CASE NO. BDG41052 ANI$ER LAURA DEPP and )[Assigned to Dept. b, Hon. Cazl H. Moor) ~ } Respondent: JOI~1 CHRISTOPHER DEFF)STIPULATED JiTDGMENT OF II(AKA JOY~NNY DEPP) DISSOLYJTI~N OF 11~#ARRIAGE d } 7 8i Petitioner AIVBEA LAURA DEPP {`Petitioner") and Respondent JOHN CHRISTOPHER 9' DEPP II {"Respondent"}(collectively, "the parties"} have resa~ved au issues in their pending I0 dissolution of marriage action by stipulation and ask that the Court make tie following ard~rs 11 pursuant to their stipuIatioa, TY' IS ORDERED,ADNDGED,AND DECREED AS FOLLOWS: 12 1. 13 STA'iISTTCAL INFORMATION 1.1 The parties stipulate and the Court orders as follows: 14 1.1.1 1S I _ I.2 The parties separated on May 21,2016 ("Date of Separation"). 16 1.1.3 17 1.1,4 Irreconcilable differences have arisen between the parties which have led to tine The parties were married on February 3, 2015("Date ofMarriage"), There are ~o minor children ofthe marriage. 18 irremediable breakdown of the marriage, making it irnpossibie for the patties to live together as 19 husband and wife. Petitioner and Respondent acknowledge that their marital relationship cannot be 20 ~ restored or reestablished at this time, 21 I.1.5 On May 23, 2416, Petitioner filed a Petition for Dissolurion of Marriage in tine 22 Superior Court of California, County ofLos Angeles, Case Number BD641052. On May 25,2016, 23 Respondent filed a Response and Request for Dissolution of Marriage. On NFay 27, 2Q I G, Petitioner 24 filed a Request fox Domestic Violence Restraining Orders against Respondent, and on May 27, 2016, 25 tine Court granted 3'emporary Restrauung Orders against Respondent. 2b !!/ 27 1/! 28 -1MARRIAGE OF DEPP STIPULATED JWGMENT OF DISSOLUTIQN OF MARRIAGE L.A.S.C.CASENO.BD64]052 ~~~cx~ ALD ~ICD ~~ jdg,091~16-A,vS.wpd Heard - MTD Exhibits - 202 x.1.6 Petitioaer aaa RespQnaent were residents ofthe County ofLos Angeles, State t 2 of CaliforriEa at the time this action was filed, and each resided continuously in this state and county 3 for a period in excess ofsix months prior ~o the filing ofthe dissolution action. 4 1.2 On August 15 and I6, 2016, the parties executed a Deal Point Memorandum pursuant 5 to Code of Civil Procedure Section 664.b ("DPM'~ which reflected their resolution of aI[ issues m b this dissolution action. 7 8 1.3 Each of the parties has represented and warranted that prior to theff executing this Judgment, they exchanged Preliminary Declarations of Disclosure as required by Family Code Section 9 21Q4 and Final Declarations ofDisclosure as required by Family Cede Section 2145. Pursuant to 10 Fami[y Code Sections 210h and Z1Q5,Petitiflner served on Respondent aPreliminary/Final 11 Declaration of Disclosure on October 21,2016, and Respondent served on Petitioner a . 12 PreliminarylFinal Declaration ofDisclosure on September 15, 2016. 1.4 13 , For the purposes ofthis Judgment, the "E$'ective Date" is the last date t~f execution of ]4 this Judgment by the parties and their counsel. l5 t6 2. SETTLEMENT OF ALL CLAIMS 2.1 Tt is the mutual wish and desire ofthe parties to effect a fu!!, complete, and final 17 settlement of all their respective property interests, future, and present by this Judgment, and, except I8 as otherwise set forth herein, to irrevocably adjust and deternine forever a~ legal obligations ofany 19 nature which may exist with respect to one another and by reason of their marriage, and to fully and 20 completely resolve any and all issues relating to division ofproperty, reimbursement claims and/or 21 cxedits, spousal support, and attorneys' fees and costs. It is the further mutual wish and desire ofthe 22 parties to completely resolve any and all issues regarding Petitioner's claims ofdomestic violence, 23 including any and all related claims of assault, battery, intentional or negligent infliction ofemotional 24 distress, libel, slander, andlor defamatipn. 25 2.2 The parties have resolved all property issues between them and iaave agreed that their 2S `~ property(regardless ofhow chazacterized} shall be divided between them as set forth below. 27 Petitioner and Respondent acknowledge and agree that the division ofproperty hereinafter provided 28 -ZMARRIAGE OF DEPP ST~ULATED NDGIVIENT OF DISSQLUTION OF I4~RRrAGE L.A,S.C. CASE NO.BDb4105Z ALD ;;, ~~ y JCD jdg.091416-A.vS.wpd Heard - MTD Exhibits - 203 1 is not intended to be a sale or exchange ofproperty, that Petitioner and Respondent have settled and 2 adjusted their respective property, including community property, separate property, and 3 quasi-community property rights and claims, including the assumption of certain obligations, to effect 4 a division thereofin a manner by which they intend to aceompGs~ an equitable division of their 5 property. Nothing in this Judgment sl~all constitute an admission by either party that any ofthe b property divided is ofa particular character, whether community, quasi-community, or separate 7 property. 8 2:3 Petitioner and Respondent acknowledge and agree that they desire to settle and adjust 9 ana hereby waive their zespective rights, tat~es, interests, and duties arising out of or based in any j4 manner upon their premarital cohabitation by any statute, law,judicial decision, common law, customs, 11 practice, contract(whether express or implied-in-fact or in-Iaw), or undertaking of any nature or kind 12 whatsoever, including, without limitation, any right, title, interest, and duty arising unfler or based in 13 any manner upon the decision rendered by the Califamia Supreme Court in Marvin v. Marvin {1975) 14 18 Cal. App. 3d 660, or any legal theory.or doctrine #herein mentioned or thereafter approved. 15 3. E6 DIVISION OF ASSETS AND DEBTS 3,I Proaerty Awarded andlar Cdr~&rmed to Petitioner: The faIIowing itetn~ of property, 17 including any assets held in Petirioner's name, in the name of any entities owned by Petitioner, and/or 18 in any trusts controlled by Petitioner, whether Petitioner's separate property, ca~nmunity property, or ~ 19 mixed in c5aract$r are awarded and/or confirmed to Petitioner as her sale and separate property as of 20 August 16, 2016, Respondent hereby waives, reliaqu~shes, releases, and quitclaims to Petitioner any 2~ and aIl afhis rigbt, title, and interest in and to those items set forth below in this Section 3.1 22 iacludmg,but not limited to, any and all tax benefits and obligations regarding or associated with 23 same. Respondent is ordered to forthwith transfer, convey, and assign said items, ifin ResFoRdent's 24 possession or as otherwise necessary, to Petitioner, as bet sole and separate property. Petitioner shall 25 pay for, indemnify, defend, and hold Respondent harmless from and against any and all liabilities, 26 encumbrances, liens, debts,judgments, suits and/or clauns including attorneys' fees, interest, and 27 penalties ofany soft, associated with the assets and debts awarded and confirmed to Petitioner herein: 28 -3MARRIAG OF DEP STIPULATED JUDGIVIENT OF DISSOL[iT[ON OF iVIARRIAGE G.A.S.C. CASE NO.BD541052 ALD ~~ JCIJ jdg091476 -A.v3.+vpd Heard - MTD Exhibits - 204 ~~ ~i 1 3.1.I 2 3.1.2 The horse known as Arrow. 3 3.1.3 2015 Range Raver, VIN: SALWR2TF3FASIU02. Respondent shall transfer The dogs known as Pistol and Boo. 4 said vefucle to Petitioner free and clear of any and all encumbrances thereon, Respondent represents 5 that the vehicle is currently being transferred to Petitioner and that the transfer should be completed in 6 the next thirty(30) to sixty(b0) days. As of August 16, 2416, Petitioner spa!! be solely responsble 7 for any aid ali expenses associated with said vehicle, including, but not limited ta, maintenance/repair 8 costs, storage fees, gas, insurance, registration, and any encurQbxances Petitioner may cause to be 9 incurred thereon. Also as ofAugust I6, 20I6, Petitioner shaIl inderi~ify, defend, and hotc~ 10 1I Respondent harmless from any liability associate with said vehicle. 3.1.4 1468 Ford Mustang. Petitioner shall be solely responsible for any and all 12 expenses associated with said veiucle, including, but not limited to, maintenance/repait costs,~storage I3 fees, gas, insurance, registration, and any encumbrances thereon. Petitioner shall indemnify, defend, 14 and hold Respondent harmless therefirom. i 15 3,1.5 1G 3.1.6 Screen Actors Guild -American Federation of Television and Radio Artists City National Bank checking account ending 90. 17 pension plan in name ofPetitioner. 18 3.1,7 Wells Fargo SEP IR.A account ending 59. 19 3.1.8 AU of the parties' right, title, and interest in Under the Black Sky,Inc., 20 including, but not limited to, all assets, bank accounts, liabilities, capital calls, accounts receivable, 21 accounts payable, security deposits, option contracts, and goodwill ofPetitioner end Respondent, if 22 any, in connection with said interest. 23 3.1.9 Certain furniture and furnishings in penthouse units 3 and 5 ofthe 849 S. 24 Broadway condominiums and in the Sweetzer properties awarded to Respondent herein and as agreed ZS 2b 27 28 upon by Petitioner and Respondent in the meet and confer process set Earth in Section 3.3. 3.l.la Any and all memorabilia, collectibles, watches, and jewelry in PeEitioner's possession, custody, and control. -4MARRIAGE OF DEPP ST~'UGA1'~D JUDGMENT O~ DISSOLUTION OF MARRIAGE L.A.S.C. CASE NO.BD6410S2 C ,.._ ALD JCD j4g.091816-A.vS,wpd Heard - MTD Exhibits - 205 ~J 3.1.11 All ofPetitioner's gremarital, marital, and Bast-separation earnings, 2 compensation, and accumulations, except as otherwise set forth herein. 3.1.12 All premarital, marital, and post-sepazation debts incurred by Petitioner, except 4 as otherwise specifrally set forth herein. 3.1.13 All assets and investments acquired by Petitioner at any time, including any D rents, issues, profits, and income fram same,except as otherwise set forth herein. 3.1.14 Any and a[1 clothing, including but not limited to, bathing suits and cosmetics 8 9 in Respondent's properties. 3.2 Property Awarded and/or Confirmed to Respondent: The following items of property, ra including any assets held in Respondent's name,in the ~a~ne of any entities owned by Respondent, 11 andlor in any trusts controlled by Resgondent~ whether Respondent's sepazate property, community 12 property, or mixed in character are awarded andlor confirmed to Respondent as leis sale and separate 13 property as of August 1 b, 20Ib. Petytioner hereby waives, relinquishes, releases, and quitclaims to 14 Respondent any and all ofher right, title, and interest in and to those items set forth below in this i5 Section 3.2, including, but not limited to, any and aIl tax benefits. and obligations regarding or 1G associated with same. Petitioner is ordered to forthwith transfer, convey, and assign said items, if ~n 17 Petitioner's possession or as otherwise necessary, to Respondent, as his sole and separate property. 18 Respondent shall pay for, indemnify, defend, and hold Petitioner harnifess from and against airy and ~9 all liabilities, encumbrances,[lens, debts,judgmenEs, suits andlor claims including attorney's fees, 20 interest, and penalties ofany sort, associated with the assets and debts awarded and confirmed to 21 Respondent herein. 22 3.2.1 All right, title, and interest in and to, and any loans and liabilities thereon, the 23 real property located at 1486 North 5weetzer Avenue, Las Angeles, California 40069 and fegaIIy 24 described as follows: 25 2d 27 2$ THAT PORTION OF LOT 3 IN BLOCK "H" OF HACIENDA PA1tK.,IN THE CITY OF LOS ANGELES,COUNTY OF LOS ANGELES,STATE OF CALIFORNIA, AS PER MAP RECORDED IN BOOK 10 PAGE 106 Off' MAPS,IN THE OFFICE OF THE COUNTY RECORDER OF SAID COUNTY,L`YIl~G NORTHWESTERLY QF THE SOUTHEASTERLY BOUNDARY -5-' MARRIAGE OF DEPP STLPIJ~ATED JUDGMENT OF DISSOL[iTI01~ OF MARRIAGE L.A.S.C~ CASE NO.BD64105z rw r ~ ALD JCD jd;.091416 - A,vS.wpd Heard - MTD Exhibits - 206 ~J l 2 LINE OF THE CITY OF LOS ANGELES, AS SAID BOUNDARY LINE EXISTED NOVEMBER 7, 1441. APN: 5555-022-412 3 3.2.2 All right, title, and interest in and to, and any loans and liabilities thereon, the 4 real property located at 1466 North Sweetzer Avenue, Los Angeles, California 90064 and legally S described as follows: b 7 8 ~ LOT 13 OF TRACT N0.879b,IN THE CITY OF LOS ANGELES, COYJNTY OF LOS ANGELES,STATE OF CALIFORNIA, AS PEK MAP RECORDED IN BOOK I24,PAGES 73 AND 74 OF MAPS, IN THE OFFICE OF THE CQUNTY REORDER OF SAID COUNTY. APN: 5555-023-003 9 10 3.2.3 All right, title, and interest in and to, and any loans and liabilities thereon, the 11 real property located at 1472 North Sweetzer Avenue, Los Angeles, California 90069 and Legally 12 described as follows: 13 ]4 15 1 fi THE SOUTHEASTERLY 15 FEET MEASURED AT RIGHT . ANGLES TO THE SOUTHEASTERLY LINE OF THAT PORTION OF LOT 1 I OF TRACT NO. 8796, IN THE CITY O~ LOS ANGELES, COUNTY OF LOS ANGELES,STATE OF CALIFORNIA, AS PER MAP RECORDED IN BOOK 124,PAGES) 73 AND 74 ~F MAPS,IN THE OFFICE OF THE COUNTY RECORDER OF SAID COUNTY,DESCRIBED AS FOLLOWS: i 17 !8 19 2D 21 22 23 BEGINNING AT THE MOST WESTERLY CQRNER OF SAID LC}T; THENCE ALONG THE NORTHWESTERLY LINE OF SAID LOT,NORTH 41° 45' 35" EAST b0.18 FEET TO THE SOUTHWESTERLY CORNER OF THE LAND DESCRIBED IN THE DEED TO A1~TI~A B, ASKAM,RECORDED IN BOOK 228b1 PAGE 132.OFFICIAL RECORDS OF SAID COUNTY;THENCE ALONG THE SOUTHERLY LINE OF SAIY7 LAND AS ASKAM, SOUTH ?4° 1 S'47" EAST 69.73 FEET TO THE SOUTHEASTERLY LINE OF SAID LOT 11: THENCE ALOI~FG SAID SOI3TIIIFASTERLY LIE SOUTH 47° 28' 21" WEST 7724 FEET TO TIC MOST SOUTI~RLY CORNER OF SAID LOT; THENCE WESTERLY AT.aNG SAID SOUTHERLY LINE, 57,09 FEET Ta THE POnvT OF BEGII~INn3G. 24 25 26 27 2S THAT P~RTIDN OF LOT 12 OF TRACT NO.8796,IN THE CITY OF LOS ANGELES,COUNTY OF LOS ANGELES,STATE OF CALiFORN~A, AS PER MAP RECORDED TN Bp~K l 24 PAGfi{S} 73 A1~ID 74 OF MAPS,IN THE OFFICE OF THE COUNTY RECORDER OF SAID COUNTY,DESCRIED AS FOLLOWS; _6_ MARRIAGE OF DEPP STIPULATED NDGIV~NT OF DI&50LUTION OF MARRIAGE L.A.S.C. CASL Na.BDb4105Z ALD `~ JCD jdgA9141b - A.vS.wya Heard - MTD Exhibits - 207 2 4 t4 11 BEGINNING AT THE'SOUT~-IWESTERY,Y CORNER OF SAID LOT 22; THENCE ALONG THE SOUTHERLY LINE OF SAID LOT,SOUTH 89° 59' 00", EAST 63.23 FEET TO THE SOUTHEASTERLY CORNER OF SAID LOT I2; THENCE ALONG THE EASTERLY LINE OF SAID LOT,NORTH 00° 1Q'00" EAST 87 FEET TO THE SOUTHEASTERLY CORNER OF THE LAND DESCRIBED IN THE DEED TO AN~1A B. ASKAM,RECORDED IN BOOK 22861,PAGE 132, QFF'ICIAL RECORDS OF SAID COUNTY;THENCE ALONG THE SOUTHERLY LINE OF SAID LAND OF ASKAM,NORTH 74° 18'47" WEST 17.33 FEET TO THE NORTHWESTERLY LINE OF SAID LOT ]2; THENCE ALOAI'G SAID NORT~-iWESTERx.Y LINE SOUTH 47° 23'2l" WEST 77.24 FEET TO THE MOST WESTERLY CQRNER dF SAID LQT;THENCE SOUTHEASTERLY ALONG THE SOUTHWESTEiLLY LINE t7F SAID LQT,X2.45 FEET TO THE POINT OF BEGINNING. APN: 5555-024-020 3.2.4 Alt tight, title, and interest in anc! to, anti any loans and ~ab~l~ties thereon, the real property iocated at 1498 North Sweetzer Avenue,Los Angeles, CaIiforrva 90069 and legaIIy 22 i described as foIlov,~s: 13 14 15 LOT 3 OF TRACT NO.8796,IN THE C~'I'Y OF LOS ANGELES, COUNTY OF LOS ANGELES,STATE OF CALIFORNIA, AS PER MAP RECORDED IN BOOK 124 PAGES 73 AND 74 OF MAPS IN THE OFFICE OF THE COUNTY ORI3ER ~F SATU COUNTY. API1: 5555-024-002 16 17 3.2.5 All right, title, and interest in and to, and any loans and liabilities t~ierean, the 18 real grogerty located at 14$0 North Sweetzer Avenue, Los Angeles, California 90069 and legally 19 described as fotlows: 20 ZI 22 LOT IO OF TRACT 8796,IN THE CITY OF LUS ANGELES, COUNTY OF LOS ANGELES,STATE OF CALIFORI~TIA, AS PER IviAP RECORDED IN BOOK 124 PAGE{S)73 AND 74 OF MAPS, IN THE OFFICE O~ THE COUNTY RECORDER OF SAID . COUNTY. 23 24 25 26 27 28 EXCEPT FROM SAiD LOT THAT PORTION DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON TEIE NORTHERLY OF SAID LOT, WHICH TS DISTANT NORTHWESTERLY 13 FEET FROM THE MOST EASTERLY CORNER OF SAID LOT,THENCE SOUTHEASTERLY ALONG SAID NORTHERLY LINE 13 FEET TO TIC MOST EASTERLY CORNER OF SAID LOT'; TI~NCE SOUTHVYESTERLY ALONG THE SOUTHEASTERLY LINE OF -7STIPULATED JUDGMENT OF DISSOLUTION OF MARRIAGE L.A.S.C.CASE 1V0.BDb47052 ALD y'dg.09 Td 16•It.vS.wpd Heard - MTD Exhibits - 208 SAID I.OT, 22 FEET; THENCE WESTERLY PARALLEL WITH THE NORTHERLY LINE OF SAID LOT,3 FEET,THENCE NORTHERLY TO THE PO1NT OF BEGINNING. 3 4 THAT PORTION OF LOT 11 OF TRACT 8796,IN THE CITY OF LOS ANGELES,IN THE CITY OF LOS ANGELES,COUNTY OF LOS ANGELS,STATE OF CALIFORNIA, AS PER 1VlAF RECORDED IN BOOK 124 PAGES)73 AND 74 OF MAPS,IN THE OFFICE OF THE COUNTY RECORDER SAID CQUNTY, DESCRIBED AS FOLLOWS: 6 7 $I 9~ ta. 11 12 BEGINNING AT TIC MOST WESTERLY CORNER OF SAID LOT,THENCE ALONG THE NORTHWESTERLY LINE OF SAID LOT,NORTH 4I° 45' 35'EAST 60.18 FEET TO TIC SOUTHWESTERLY COR~FER OF THE LAI~FD DESC~tIBED IN THE DEED TO ANNA B. ASKAM,RECORDED IN BOOK 22861 PAGE 132, OFFICIAL REC4~tI7S, OF SAID COUNTY,THENCE ALONG THE SOUTHERLY LINE OF SAID LAND OF ASKAM, SOUTH 74° 2S'45''EAST b9.73 FEET TO THE SOUTHEASTERLY LLNE OF SAID LQT 11,THENCE ALONG SAID SOUTHEASTERLY LINE,SOUTH 47° 28'21" WEST 77.24 FEET TO THE MOST SOUTHERLY CORNER OF SAID LOT, THENCE WESTERLY ALONG SAID SOUTHERY,Y LINE, 57.d4 FEET TO T IE POINT OF BEGINNING. 13 1a EXCEPT THE SOUTHERLY FiF'TEEN FEET OF LOT ]l MEASURED AT RIGHT ANGLES TO THE SOUTHEASTERLY Lnv~ ofs~ LOT i i. 15 lb 17 THE ABOVE LEGAL DESCRIPTION TS PURSUANT TO THAT NOTICE OF LOT MERGER RECORDED NNE 12, 1975 AS INSTRUMENT NO.75-386I OF OFFICIAL RECORI}S. APN: 5555-024-019 18 3,2.5.1 Petitioner or her designated agent bas been permitted to 19 ga to the Sweetzer properties and the storage facility to retrieve mutually agreed upon items which 20 wiU be awarded to ber as her separate property. 21 3.2.6 All right, title, and interest in and to, and any loans and liabilities thereon, the 22 real property located. at 7700 VLroodrow Vt~ilson Drive, Les Angeles, California 9 046 and legally 23 24 25 26 27 2$ descn~bed as follows: PARCEL A OF PARCEL MAP LA NO.6157, IN THE CITY ~F LOS ANGELES,COUNTY OF LOS ANGELES,STATE ~~ CALIFORI~IIA, AS PER MAP RECORDED IN BOCK 216 PAGES) $7 AND 88 OF MAPS,IN THE OFFICE OF THE COUNTY RECORDER OF SAID COUNTY. APN: 5570-026-a14 -8NIARR[AGE O DEPP STYPULATED NDGIVIENT OF DISSOLUTION OF MARRIAGE LA.S.C. CASE NO.BD641052 ALD `: .. __ '~~ • dCD jdg.W14l6 -av5.wad Heard - MTD Exhibits - 209 3.2.7 All right, title, and interest in and t~, and any loans and liabilities thereon, the 2 real property located at 470 NE Daisy Court, Cedaredge, Colorado 81413 and legally described as 3 follows: 4 Lot 19 in Block 2 ofCedaredge Estates Subdivision, as amended, County of Delta, State ofColorado. 5 6 3.2.8 All'right, title, and interest in and to, and any loans and liabilities thereon, the 7 real property located at 5443 Versailles Road, Lexington, Kentucky 40501 and legally described as fouows: 9 10 ]1 12 13 14 15 16 17 I8 19 20 21 22 23 24 25 26 27 28 Being all that tract or parcel ofland situated on the nortf~erly side ofthe Versai[Ies Pike {U.S. Highway No.60)about five miles west of Lexington in Fayette County, Kentucky, being known and designated as 54J3 Versaiues Road, and more ~fu~y described and bounded as follows,to-wit: Beginning at a point in the northerly right-of-way ofthe Versailles Pike {U.S. Highway No. 60)corner to Westmorland Subdivision thence with Westmorland for five calls N 1G deg. 19' S0" feet E b87.93 N lb deg. 12'00" E 482.22 feet, N fi7 deg. 08' 41" W 408.8 feet, N 19 deg. 10' Sp" feet, and N 19 deg. 24' E 00" 265.13 feet to an iron pin in the center ofthe west extremity ofCazleton Drive; thence for a new line along the center line extended of Carleton Drive N 72 deg. 27'00" W 645.15 feet to an iron pin in fence line ofFirst Security National Bann and Trust Ca.(Tn~stee); thence with said (Trustee)for three calls(as fenced} S i4 deg. 22' 36" W 981.08 feet S 13 deg. 23'36" W 981.08 feet, S 13 deg. 23'02" W SI3.18 feet and S 14 deg. 07'S8" W IQ38.0 feet to a point in the northerlyright-of-way ofthe Versailles Pike(U.S. Highway bQj for two calls S 8U deg. 26'00" E 800.0 feet with a cwve to the left (counter clockwise} a chord ofS 81 deg. 47'S2" E 98.94 feet to the beginning and containing 42.966 acres. Being excepted out ofthe above described pxoperiy is a certaut tract that was conveyed to the Commonwealth ofKentucky by deed dated the 15th day ofJuly,1976 and recorded in Deed Book i 152,Pago 388 Fayette County Court CIerk's Office, and beung more particularly described as follows, tv-wit: BEGINNfNG O.aO feet !eft of Versailles Road Station 239+63.00, tk~ence I~ort~ 12 degrees 34 minutes 59 seconds East, SQ.08 feet to a point 50.00 feet left of Versailles Road Station 239-~b5.91, thence North 12 degrees 35 minutes 3 seconds East, 35Ab feet to a point 85.00 feet left of Versailles Road Station 239+67.95,thence South 80 degrees 45 minutes d secouas East. 32.05 feet to a point 85.00 feet ]e& of Versailles Road Station 240+OO,QO, thence South 80 degrees, 45 minutes,0 seconds East, 350.0 feet to a point SS.00 feet Ieft of Versailles Road Station 243+50.00, thence South 78 degrees 55 minutes 2seconds East,469.00 feet to a point 70.40 feet !e$ of -9MARRIAGE OF DEPP STIPULATED JUDGII~NT OF bISSOLUTION U~ i~1ARRIAGE L.A.S.C. CASE 1Y0. Bb64105Z ALD JLD jdyo9l4f6-A.,rS.wyd Heard - MTD Exhibits - 210 i 2 3 4 5 6 7 9 Versailles Road Station 248+18.76, hence South 68 degrees 43 minutes 4 seconds East, 46.22 feet to a point 60.00 feet left of Versailles Read Station 248+64.93, thence South 16 degrees 19 minutes 37 seconds West, 8.59 feet to a point S 1.SD feet left of Versailles Road Station 248+63.72, thence South 16 degrees 19 minutes 52 seconds West, 54.63 feet to a point 1.34 feet left of Versailles Read Station 248+56.68 thence along an arc 95.64 feet to the right having a radius of2864.79 feet, the chord ofwhich is North 81 degrees 42 minutes 22 seconds West,9S.63b feet to a paint 0.00 feet right of Versailles Road Station 247+61.04,thence Notch 80 degrees 45 minutes 0 seconds West, 263.04 feet to a point O.UE} feet 1efr of Versailles Road Station 244- 9$.00, thence North 80 degrees 45 minutes 0 seconds West, 535.00 feet to paint of beginning. The above described parcel cr~ntains x.646 acres of which 1.028 acres is existing Right-of-Way. 10 Berg the same property conveyed to john C. Depp,a/k/a John C. Depp,II, a s~gle persfln, by deed dated November Ib, I995, ofrecord it1 Deed Book 18I9,Page 477,in the Fayette County Clerk's Office. I1 3.2.9 Aii right, title, and interest ~n and to, and anp loans and. liahilit~~s thet~on, tic 12 real property located at Little Hall Ponds Key #10, Bahamas and legally described as follows: 13 21 ALL THAT islet or Cay called or known as "Little Hall's Pond Cay" and situate in the vicinity ofHall's Pond Cay and being a part ofthe Exuma range ofIslands Islets and Cays in the saki Commonwealth of The Bahamas being designated as Cay Number Ten(IO)in Volume Two(2)of Arant~a's Report on the Exuma Cays 1929 in the Department ofLands and Surveys ofthe said Commonwealth ofThe Bahamas berg designated in a Crown Grant to Island Home Estates Limited dated the 15th Mazch, 1944 and recorded in the Registry of Records of the said Canunonwealth ofThe Bahamas in Baok V.13 at page 137 ~d which said Tslet or Cay is bounded by the Sea at High Water Mark and is delineated on that part of the Plan attached to an Indentwre of Conveyance dated the 5th day ofMay, A.D. 1992 made between AkroycE Limited ofthe one part ail d Avocado Holdings Limited ofthe other part and recorded in the Registry ofRecords in tl~e City ofNassau one ofthe Islands ofthe Commonwealth ofThe Bahamas in Volume 5835 at pages 455 to 461 and thereon coloured Pink. 22 3.2.1(1 All right, title, and interest in and to, and any loam and liabilities thereon, the I4 15 16 17 18 19 za 23 24 25 26 real property located at Ridgeback Cay &Snake Cays, Bahamas and legally described as fvl~ows; ALL THOSE Islands or Cays situate in the Exuma Chain of Cays and comprising all that Coy known as Ridgeback Cay and all those Three (3)Cays known as Snake Cays which said Cays axe shown for the purposes of identification on[y on the diagram or p~ attached hereto and thereon coloured Blue. 27 RIGHTS OF WAY AND EASEMENTS(ifany}: 28 NONE -10MARRIAGE OF DEPP STIPULATED 3UDGIVIENT OF DiSSOLUTIpN OF MARRIAGE L.A.S.C. CASE NO.BD64t052 _ ALD JCD jdg091416 - A,vS.wpd Heard - MTD Exhibits - 211 ~~ 1 ~J EXCEPTIONS AND RESERVATIONS (if any): AS 5BT FORTH IN CROWN GRANTS OF LAND IN THE COMMONWEALTH OF THE BAHAMAS 2 3 41 RESTRICTIONS AND CONDITIONS (if any}: SUB7ECT T4 THOSE IMPOSED ON ISLANDS 4R CAY SITUATE WITHIN THE EXUMA CAYS LAND AND SEA PARK 5 3.2.I 1 AtI right, title, and interest in and to, and any loans and tiabiGties thereon, the 6 real pzoperty located at Le Hautes Gassines, 83i20,Plan de la Tour, France and IegaIly described as 7 faIlows: 8 9 Residential property located at Hameau de Gassine - 83120 - Le Plan de la Tour -France, on a site of 104.378 m2 heid under freehold ownership by"SCI La Pierre". 10 3.2.12 Except as otheawise noted herein, all furniture, furnishings, appliances, and 11 household equipment in any and all of the real properties awazded to Respondent herein andJvr in 12 ResQondent's possession, custody, or control. 13 3.2.13 All right, title, and interest in and to the following ~e6icles and vessels: 14 3.2.13.1 195 i Mercury coupe; IS 3.2.13.2 1958 Chevy Apache truck; 16 3.2.13.3 1495 Porsche 9I 1 convertible; 17 3.2.13.4 1935 Packard coupe; 18 3.2.13.5 2006 Electric Fairplay golfcarts (two); I9 3.2.13.b 208 Dodge Challenger; 20 3.2.13,7 1934 Buick; 21! 3.2.13,8 1958 Corvette; 22 3.2.13.4 1430 Ford Model A coupe; 23 3.2.13.IQ Scooter Piaggo; 24 3.2.13,11 2011 EZCr~ 4-passenger electric carts(two); 25 3.2.13.12 1972 Buick Riviera(cuskom); 26 3.2.13.I3 194U Harley Davidson motorcycle; 27 3.2.13.14 1970 Triumph T1201 motorcycle; 2$ Z1 MARRIAGE O~ DPP 511PULATED NDGMENT OF DISS~LUTIQI~I OF MARRIAGE L.A.S.C. CASE NO.BD641051 ALD ~~J JCD jdg.041416 - A.vS.~vpd Heard - MTD Exhibits - 212 3,2.I3.I$ I973 Yau►~aha 175 motorcycle; 3.2.13.1b 1969 BSA A75R motorcycle; 3.2.I3.I 7 19b4 BSA B40 rnotorcycie; 3.2.13.18 1975 Norton S50 Commando motorcycle; 3.2.13,19 1989 Honda GB SQ motorcycle; 3.2.13.20 1972 Ducati 450P motorcycle; 7 3.2.13.21 1968 Triumph Banne~ille ?50 motorcycle; 8 3.2.13.72 1944 Triumph motorcycle; 9 3.2.13.23 1955 Triumph motorcycle; 10 3.2.13.24 1982 45-foot bucket truck; ~l 3.2.23,25 2007 Gus Silver golf cart; 12 3.2.13.2b PaLner; 13 3.2.13.27 Caterpillar TH360B Telescopic Han; 14 3.2.13.28 18" backhoe bucket model L45TLB; 15 3.2.13.29 2011 EZGO golf carts; jb 3.2.13.30 ZOIO EZGO shuttle; 17 3.2.13.31 2012 EZGO golf cart; 18 3.2.13.32 Jo}~n Deere Gatar XUV $50; Z4 3.2.13.33 Jo~rt Deere Gator XUVb20!cart; 20 3.2.13.3G 1964 American Rambler; 2] 3.2.I3.35 Gemini boat; 22 3.2.13.36 2409 24$0 DLX Carolina skiff; 23 3.2.13.37 17-foot Boston whaler; 24 3.2.13.38 Concept Twin Mercury HP haat; 25 3.2.13.39 1952 Airstream Trailer; 26 3.2.13.0 2Q07 Chrysler 300C; 27 3.2.t 3_~1 2007 Cadillac Escalade; and 28 -12MARRIAGE OF DEPP STIPULATED JUD{;METtT QF DISSOLUTION OF MARRIAGE L.A.S.C.CASENO.~D64105Z ~ 1 ~~= AI.D ,TCD jd&09Lg16-A.vS.wpd Heard - MTD Exhibits - 213 ~:J 1 3.2,13.2 2005 Airstream Trailer. 2 Respondent shall be solely respansibEe for any and all expenses associated with said vehicles and 3 vessels, iMcludi~g, but nat limited to, IIraintenance/repair costs, storage fees, gas, insurance, 4 registration, and any encnmbrancss thereon. Respondent shall indemnify, defend, and hold Petitioner 5 harmless therefrom. 6 3.2.I4 Banc of California c$ecking accounts ending 4$, S0, S5, 41, 75, $3, and 40. 7 3.2.15 City National Banfc checking accounts ending 98, 6b,68,686, 057, 557, 84, 8 8$~,26, Q7,73,75, 55,42,74,90, 20,4?,43,9294,2294, 1 X, 33, and 10. 9 3.2.]5 Merril]Lynch brokerage account ending 28. 10 3.2.17 National Lzfe life insurance policies ending 51 and 81. 11 3.2.18 Lincoln Benefit life insurance policies ending 3I and 46. 12 3.2.19 Protective Life insurance policies ending 67 and 68. 13 3.2.20 Bel Air Securities money-purchase pension plans ending O1 and 25. ]4 3.2.21 Screen Actors Guild Producers pension plan in name ofRespondent. 15 3,2.22 Any and all loans receivable payable to Respondent, Infinitum Niiul, Inc., ]6 Unison Music Group, LLC,or any other entity owned by Respondent. 17 3,2.23 Respondent shall be solely responsible for the Bank of America loan ending 76 18 and secured by United Talent Agency, and the loans owed to Premier Grflup International and Tryon 19 Management Services, Ltd. 20 21 3.2.24 All of the parties' right, title, and interest in the fallowing partnarsiaips, limited liability companies, and S-corporations, including, but not limited tQ, all assets, bank accounts, 22 liabilities, capital calls, accounts receivable, accounts payable, secuzity deposits, option contracts, and 23 goodwill ofPetitioner and Respondent, if any, in connection with said interests: 24 3.2.24.1 6949 Ventures, LLC; 25 3.2.24.2 A Contraria; 26 3.2.24.3 Brave Pictures, Ira; 27 3.2.24.E Contre Courant; 28 -13MARRIAGE OF DEPP STIPULATED JUDGMENT OF DISSOLUTION OF MARRIAGE L.A.S.C. CASE NQ.$D641052 AI.D C ~L JCD ,. ~a~.o9iaie -a~s.wpa Heard - MTD Exhibits - 214 ~~ ~~ I 3.2.24.5 Gelt Valleyview Holdings, LLC; 2 3.2.2.6 Infinitum Nihit Media, LLC; 3 3.2.24.7 Infinitum Nihil Music, LLC; 4 3.2.24.8 Ynfiniturn Nihil Publishing, LLC; 5 3.2.24.9 Infinitum ~IiYW Records,LLC; b 3.2.24.10 Tnfiriitum Nihil, Inc.; 7 3,2.24.11 Junior Varsity Productions, LLC; 8 I. 3.2.24.12 L.RD. Productions, Inc,; 9 3.2.24.13 Liontteart, L.P.; 10 i 3.2.24.14 Mataz, LLC; 11 3.2.24,lS F Music Group, LLC; 12 3,2.24.16 Plus Capital Partnership; 13 3.2.24.17 Scazamanga Bros., Inc,; 14 3.2.24.18 Stratton Films,Inc.; 15 3.2.24.19 Swag,LLC;and 16 3.2.24,20 Vajojiraja, LLC. ' 3.2.25 AlI right, title, and interesE in and to the option contract associated with The 17 18 Evidence Never Lies. 19 3.2.26 A~ right, title, and interest in and to tie fo~ewing trusts: 2fl 3.2.26.1 Mooh Investment Trust; 21 3.2.26.2 The Sweetzer Trust; 22 3.2.26.3 Versailles Road Trust; 23 3.2.26.4 SCI La Pierre Investment Trust; 2~ 3.2.26,5 john C. Depp II Insurance Trust; 25 3.2,26.b Depp Irrevocable Trust; and 2b 3.2.26.7 John C. Degp II Living Trust. 27 111 28 -1.4 MARRIAGE O DEPP STIPULATED JUDGMENT Off'DISSOY~UTIOiV OF MARRIAGE L.A.S,C. CASE HO.BD641~52 ~ ALD JCD jd;09141b -IivS.wpd Heard - MTD Exhibits - 215 3.2.27 Any and aIl memorabilia, collectibles, an#iques, art, books, musical instruments 2 and equipment, tivatches, and jewelry jn Respondent's possession, custody, or control. 3 3,2.28 Alt ofRespondent's premarital, in~rital, and post-segara#ion earnings, 4 compensation, and accumulations. 5 3.2.29 All premarital, marital, and post-separation debts incurred by Respondent, 6 ~xcepr as ot~etwise spe.~ifically set forth herein. 7 3.2.30 A!1 assets and investments acquired by Respondent at any tune, including any rents, issues, profits, and income from same, except as otheruvise set forth herein. 9 10 I1 3.3 $49 S. Broadway, Los Angeles, CA. 3.3.1 Responderrt shall ~ awarded all right, title, and interest in and to, and any taans and Liabilities thereon, the real properties located at 849 S. Broadway, Los Angeles, Caiifomia 12 90014, penthouse units 1, 2, 3, 4,and 5. and leg~lfy described as foIIows: 13 849 S. Broadway Unit PH-1, Los Angeles, CA 90014. l4 A CONDONIlNTUM COMPRISED 4F: IS PARCEL NO. 1 16 UI~1IT NO.PHI AS SHOWN AND DESCRIBED IN THE CONDOMINIUM PLAN FOR EASTERN COLUMBIA LOFTS, RECORDED ON NOVEMBER 3, 2006, AS INSTRUMENT NO. Q6-2447336E Il~I THE OFFICE OF TIC LbS ANGELES COUNTY RECORDER{THE "PLA1~I"), ENCUMBERING LOT 1 OF TRACT NO.61499,AS SHAWN ON T~iAT CERTAIN SUBDNISION MAP RECORDED IN BORIC 1322 AT PAGES 43 TO 42, INCLUSIVE, OF MAPS,IN THE OFFICIAL GORDS OF LQ5 ANGELES COUNTY, CALIFORNIA. 17 18 19 20 21 22 23 24 25 26 27 Z8 EXCEPTING AND RESERV~iG FROM FARCELS NO. 1, 2, 3 AND 4, ALL PREVIOUSLY UNRESERVED MINERALS,OIL, GAS,PETROLEUM,OTHER HXDROCARBON SUBSTANCES AND ALL UNDERGROUND WATER IN OR UNDER OR W~iT~H MAY BE PRODUCED FROM THE ABOVE- DESCRIBED LAND WHICH UNDERLIES A PLANE PAR.AL~,EL TO AND 500 FEET BELOW THE PRESENT SURFACE OF SUCH LAND FOR THE PURPOSE OF PROSPECTING FOR.,THE EXPLORATION, DEVELOPMErIT,PRODUCTION,EXTRACTION AND TAKING OF SUCH M3~fERALS,OIL, GAS,PETROLEUM,OTHER HYDROCARBON SUBSTANCES AND WATER FROM SUCH LAND BY MEANS OF MINES, WELY,S, DERRICKS OR OTHER EQUIPMENT FROM SURFACE LOCATIONS ON AD70INING OR NEIGHBORING LAND OR LYING OUTSIDE OF THE -15MARRIAGE O DEPP S'I7PUY.ATED r(JDGMENT OF DISSOLUTION OF MARRIAGE L.A.S.C.CASE NO.BD641052 __ ALD `' ' JCD jd~041476 • ArS.wpi Heard - MTD Exhibits - 216 ~; ~j ABOVE-DESCRIBED LAND,IT BEING LTi~IDERSTOQD THAT THE pWNER OF SUCH MINERALS,OIL, GAS,PETROLEUM, OTHER HYDROCARBON SUBSTANCES AND WATER,AS SET FORTH ABOVE,SHALL HAVE NO RIGHT TO ENTER UPON THE SURFACE OR ANY PORTION TI~REOF ABOVE SUCH PLANE PARALLEL TO AND 500 FEET BELOW THE PRESENT SURFACE OF SUCH LAND FOR ANY PURPOSE WHATSOEVER. PARCEL NO.2 AN UNDMDED ONE-ONE HUNDRED FORTY-SEVENTH {1114' FEE SIlvIPLE INTEREST AS A TENANT IN COMMON IN AND TO ALL OF THE REAL PROPERTY COMPRISING THE COMMON AREA(AS DEFINED IN SECTION 1.19 OF THE DECLARATYON DESCRIBED BELOV~. PARCEL N0.3 IQ 12 AN EXCLUSIVE EASEMENT APPURTENANT TO THE UNIT FOR STORAGB PURPOSES OVER THAT CERTAIN EXCLUSIVE USE COMMON AREA FOR STOYtAGE SPACE SHOWN AND DESIGNATED IN THE ABOVE-REFEREi~CED PLAN AS "S-5". 13 PARCEL N0.4 1~ NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS, EGRESS,ENCROACHMENT, SUPPORT, MAINTENANCE, DRAINAGE,USE,EN70YMENT,REPAIR, AND FOR OTHER PURPOSES,ALL AS DESCRIBED IN'THE DECLARATION OF COVENANTS,CONDITIONS AND RESTRICTIONS AND RESERVATION OF EASEMENTS FOR EASTEYtN COLUMBIA LOFTS RECQRDED ON NOVEMBER 3,20D6, AS INSTRUMENT NO.06-2447337,IN THE OFFICE OF THE LOS ANGELES COUNTY RECORDER ("DECLAMATION"). APN:5144-017-185 al ]5 16 ]7 l8 19 20 849 $. Broadway Unit PH-2,Los Angeles, CA 90014: 21 A CONDOMINIUIVI COMPRISED OF: 22 PARCEL NO. 1 23 U1VIT NO.PH2 AS SHOWN AND DESCRIBED IN THE CONDOMINIUM PLAN FOR EASTERN COLUMBIA LOFTS, RECORDED ON NQVEMBER 3, 2006, A5 R~iSTRUMENT Nd. 06-2447336,1N TIC OFFICE OF THE LQS ANGELES COUNTY RECORDER(THE"PLAN"),ENCUMBERING LOT I OF TRACT NO.61494, AS SHOWN ON THAT CERTAIN SUBbIVISTQN MAP RECQRDED IN BOOK 1322 AT SAGES 41 TO 42,INCLUSIVE, 24 25 26 27 28 OF MAPS 1N THE OFFICIAL RECORDS OF LOS ANGELES COUNTY,CALIFORNIA. -16 MARRIAG OF DEP STTPYJLATED JUDG14~1~iT OFDiSSULUTION OF MARRIAGE L.A.S.C.CASE NO.BDb41051 ~.. "' ALD JG'D jdg.09l~36-A.vS.wpi Heard - MTD Exhibits - 217 ~J 1 PARCEL NO.Z 2 AN UNDNIDBD ONE-ONE HUNDRED FORTY-SEVENTH {I/147)FEE SIMPLE INTEREST AS A TENANT IN COMMON IN AND TO ALL OF THE REAL PROPERTY COMPRISING THE COMMON AREA(AS DEFINED IN SEC'TTON I,19 OF THE DECLARATION DESCRIBED BELOV~. 3 4 5 PARCEL NO.3 6 8 AN $XCLUSNE EASEMENT APPURTENANT TO THE UNIT FOR STORAGE PURPOSES OVER THAT CERTAIN EXCLUSIVE USE COMMON AREA FOR STOI~AGE SPACE SHOWN AND DESYGNATED TN THE ABOVE-REFERENCED PLAN AS "S-S" 9 PARCEL N0.4 7 NON-EXCLUSIVE EASEMENTS FOR ACCESS,INGR$SS, EG~tESS,ENCROACHMENT,SUPPORT, MAINTENANCE, DRAINAGE,USE,ENJOYMENT,REPAIR, AND FOR OTHER PURPOSES, ALL AS llESCRIBED 1N THE DECLAItATYON OF COVENANTS,CONDITIONS AND RESTRICTIONS AND RESERVtLTIQN OF EASEMENTS FOR EASTERN COLUMBIA LOFTS RECORDED ON NOVEMBER 3,200b, AS INSTRUMENT NO.06-2447337,IN THE OFFICE OF THE LOS ANGELES COUNTY RECORDER ("DECLARATION"). 10 11 12 13 14 EXCEPTING FROM PARCELS 1~I0. 1, 2,3 ANI7 4,FOR THE BENEFIT OF GRANTOR,XTS SUCCESSORS IN INTEREST,THE ASSQCIATXON, AND OV~NERS O~ CONDOMINIUMS IN THE PROJECT,NON-EXCLUSIVE EASEMENTS FOR ACCESS, INGRESS,EGRESS,ENCROACHMENT,SLFPpORT, MAINTENANCE,DRAINAGE,USE,REPAIR, AND FOR OTHER PURPOSES,ALL AS DESCRIBEI'~ IId ~'HE DECLAR.ATI4N. 15 16 I7 18 l9 20 21 22 23 24 25 2b 27 28 ~ EXCEPTING FROM PARCELS NO. 1, 2,3 AND 4, ALL PREVIOi(.JSLY UNRESERVED MINERALS,OIL, GAS, PETROLEUM,OTHER HYDROCARBON SUBSTANCES AND ALL UNDERGROUND WATER IN OR UNDER OR WHICH MAY BE PRODUCED FROM THE ABOVE-DESCRIBED LAND WHICH UI~DERI,IES A PLANE PARALLEL TO AND S00 FEET BELOW THE PRESENT SURFACE OF SUCH LAND FOR THE PURPOSE OF PROSPECTING FOR,THE EXPLORATION,DEVELOPMENT, PRODUCTI(3N,EXTRACTION AND TAKING OF SUCH MINERALS, QIL, GtiS, PE'~R~LEUM,OTHER HYDROCARBON SUBSTANCES AND WATER FROM SUCH LAND BY MEANS OF MmiES,WELLS,DERRICKS OR OTHER EQUIPMENT FROM SURFACE LOCATIONS ON AD30II~IIl~IG OR NEIGHBORING LAND OR LYING OUTSIDE OF THE ABOVE DESCRIBED LAND,IT BEING UNDERSTOOD THAT THE OWNER OF SUCH MINERALS, pIL, GAS,PETROLEUM,QTHER HYDROCARBON SUBSTANCES AND WATER, AS SET FORTT~ ABOVE,SHALL HAVE NO RIGHT TO ENTER UPON THE SURFACE OR ANY -17- MARRIAGE OF DEPP STIPULATED JUDGIV~NT OF DYSSOLUI'IQN OF MARRIAGE L.AS.C.CA5EN0.SD641052 ~ ALD _. _ JCD ~a~.o9ia~b-n.~s.W Heard - MTD Exhibits - 218 Z PORTIQN THEREOF ABOVE SUCH PLANE PAI2ALLEI,TO ANA 500 BEET BELOW'£HE PRESENT SURFACE QF SUC~I LAND FOR ANY PURPOSE WHATSQEVER_ APN; 5144-Q17-187 3 4 849 S. Broadway Unit PH-3, Los Angeles, CA 40014: S A CdND~MINFUM COMPRISED 4F: PARCEL I; 8 9 AN UNDIVIDED 1/147TH INTEREST rN AND TO `2VIODU~E A" OF LOT 1 OF TRACT NO.Ob1499,IN THE CITY OF LOS ANGELES,COUNTY OF LOS AriGELES,STATE OF CALIFORNIA, AS PEA MAP RECORDED IN BOOK 1322 AT PACrES 41 AND 42 OF MAPS,IN THE QFFICE OF THE.COUNTY RECORDER OF SAID COUNTY. 10 lI 12 I3 14 15 16 17 I8 19 EXCEPT THEREFROM[JNITS 101 AND 142, N14L THROUGH MU INCLUSNE,201 THROUGH 211 INCLUSIVE,301 THROUGH 312 INCLUSIVE,4Q1 THROUGH 412 FNCLUSIVE, 501 THROUGH S I2 INCLUSIVE,60I THROUGH 612 INCLUSIVE,7~1 THROUGH 712 INCLUSIVE,801 THROUGI~ 8I2 INCLUSIVE 901 THROUGH 9l2 INCLUSIVE, 10U 1 THROUGH IO111NCLUSIVE, 1101 THROUGH 1111 INCLUSIVE, 1201 THROUGH 1212 INCLUSIVE, p~Il THROUGH PH 5 INCLUSIVE, AS DEFINED AND DELINEATED Obi THE CONDONIINIUM PLAN RECORDED NOVEMBER 3,200b, AS INSTRUN~NT NO. Q&-244733b OF OFFIGIA~ REC~R.D~. RESERVING THEREFRQM EXCLUSIVE EASEMENTS FQR STORAGE SPACES,TOGETHER WITH THE RIGHT TO GRAN' THE SAME TO O'Ff~RS,OVER THOSE PORTIONS OF 5AID LAND DEFINED AND DELINEATED AS STaRAGE SPACES 51 THROUGH 525,INCLUSFVE ON THE ABOVE REFERENCED CONDOMINNM PLAN. 20 PARCEL 2. 2I 22 UMT PH-3 OF SAID AS DEFINED AND DELINEATED ON THE ABOVE REFERENCED CONllOMINIUM PLAN. APN: 5144-017-18$ 23 24 844 S. Broadway Unit PH-4, Los Angeles, CA 90014; 25 A CONDOMINIUM COMPRISED OF: 26 PARCEL NQ. 1 27 LIIVIT NO.PH 4 AS SHOWN AND DESCRIBED IN THE C~NDONIlNIUM PLAN FOR EASTERN COLUMBIA LOFTS, 28 -18MARRIAGE OF DEPP ~ ST~ULATED JUDGMENT OF DISSOLLiT1UN OF MARRIAGE L.A.S.C. CASE NO.BD641052 .. ALD dCD jdg0914Z6 - A.vS.wp Heard - MTD Exhibits - 219 RECORDED ON NOVEMBER 3, 20Q6, AS INSTR~JMENT N0 06-24~F7336,IN THE OFFICE OF THE LOS ANGELES COUNTY RECORDER THE "PLf1N"}, ENCUMBERING LOT 1 OF TRACT NO.61499, AS SHOWN ON TT~AT CERTAIN SUHDNISI~N MAI' RECORI?ET~ IN BOOK 1322 AT PAGES 41 TO 42,INCLUSIVE, ~F MAPS,IN THE OFFICIAL RECORDS ~~ LOS ANGELES courrrY,c;~r~~oRrrrA. EXCEPTING THEREFROM,NON-EXCLUSIVE EASEMENTS FOR AeCESS,INGRESS,EGRESS,ENCROACHMENT, SUPPO1tT, MAINTEAIANCE,DRAINAGE,USE,REPAIR, ANF7 FAR OTHER PURPOSES, AFL AS DESCRIBED IN THE DECLARATION. 14 ~~ I2 13 14 IS 16 17 ~8 I EXCEPTING FROM PARCELS NC). 1, 2, 3 AND 4, ALL PREVIOUSLY UNRESERVED MINERALS,OIL, GAS, PETROLEUM,~~HER HYDROCARBON SUBSTANCES AND ALL UNDERGROUND WATER IN OR UNDER Old WHICH MAY HE PRODUCED FRC)M THE ABOVE-DESCRIBED LAND WHICH UNDERLIES A PLA1~E PARALLEL TO AND 500 FEE BELOW THE PRESENT SURFACE OF SUCH LAND FOR THE PURPOSE O~ PROSPECTING FOR,THE EXPLORATION,DEVELOPMENT, PRODUCTI~i~i,EXTRACTIaN AND TAKING OF SUCH 1VITNERALS, OIL, GAS,PETROLEUM,OTHER HYDROCARBON SUBSTANCES AND WATER FROM SUCH LAND BY MEANS OF MINES,WELLS,DERRICKS OR OTHER EQ[3IPMENT FRaM SURFACE LOCATIONS ON AD30Il~ING DR I~IEIGHBORING LAND OR LYING OUTSIDE OF THE ABOVE-nBSCRIBED LAND,IT BEING UNDERST04D THAT TIDE OWNER OF SUCH MINERALS, DII., GAS,~ETROLEUI~,OTHER HYDROCARBON SUBSTANCES E1N71 WATER,AS SET FORTH ABOVE,SHALL HAVE NO RIGHT TO ENTER UPON THE SURFACE ~R AMY PORTION THEREOF ABOVE SUCH PLANE PARALLEL TO AND 500 FEET BELOW THE PRESENT SLFRFACE OF SUCH LAAID FOR ANY PURPOSE WHATSOEVER. 19 PARCEL NQ.2 2fl 22 22 AN UNDNIDED ONE-ONE HUNDRED FORTY-SEVENTH (1J147} FEE SIMPLE INTEREST AS A TENANT IN COMMON TN AND TO ALL OF THE REAL PROPERTY'COMPRISING THE COMMON AREA(AS DEFINED IN SECTION 1.I9 OF THE DECLARATION DESCRIBED BEL~VI~. 23 PARCEL NO. 3 24 25 26 A?v EXCLUSIVE EASE~NT APPURTENANT TO THE UNIT FOR STORAGE PURPOSES OVER THAT CERTAIN EXCLUSIVE USE COMMON AREA FAR STQR.AGE SPACE SHOWN AND DESIGNATED IN THE ABOVE-REFERENCED PLAN AS "S-4" 27 28 -19S'TIPUI,ATED J'[TDGIVIENT OF DISSOLUTION OF MARRIAGE L.A.S.C. CASE ND.BD641052 ~D jd~091426 - A.VSO wp~ Heard - MTD Exhibits - 220 ~~ PARCEL NO.4 NON-EXCLUSIVE EASEMENTS FOR ACCESS,INGRESS, EGRESS,ENCROACHMENT,S[IPPORT,MAIN'T'ENANCE, DRAINAGE,USE,ENJO'YMEN~,REPAIR,AND FOR OTHER PURPOSES, ALL AS DESCRIBED IN THE DECLARATION OF COVENANTS,CONDITIONS AI~ID RESTRICTIONS AND RESERVATION QF EASEMENTS FOR EASTERN COLUMBIA LOFTS RECORDED ON NOVEMBER 3, 2006, AS INSTRUMENT NO. Ob-2447337 IN THE OFFICE OF THE LOS ANGELES COUNTY RE RDER("DECLARATION"). APN:5144-Q 17-189 849 S.$roadway Unit pH-5, Los Angeles, CA 9404: A CQNDOMINIUM COMPRISED QF: 10 PARCEL NO. 1 11 UNIT N0.PH 5 AS SHAWN AND DESCRIBED IN THE CONDpMINTU1V~ PLAN ~rOR EASTERN COLUMBIA LOFTS, RECORDED ON NOVEMBER 3, 2006, AS INSTRUN~I~IT N4. ~6-2447336,IN THE OFFICE OF THE LOS ANGELES COUN"1'Y REORDER(THE"PLAN"), ENCUMI3ERING LOT I OF TRACT NO.61499, AS SHAWN ON THAT CERTAIN SUBDIVISION MAP RECORDED IN BOOK 1322 AT PAGES 41 TQ 42,1TICLUSNE, OF MAPS,IN THE OFFICIAL RECORDS OF LOS ANGELES COUNTY, CAX.IFORNIA. 12 13 14 15 16 17 18 19 20 21 2~ 2? 24 2R Zf 2'. EXCEPTING THEREFROM PARCELS NO. 1,2,3 AND 4, NON-EXCLUSNE EASEMENTS FOR ACCESS,INGRESS, ENCROACHMENT,SUPPORT,MAINTEI~iANCE, DRAINAGE, USE,REPAIR, AND FOR OTHER PURPOSES,ALL AS DESCRIBED DV THE DECLARATION. EXCEPTING FROM PARCELS I~IO. 1, 2, 3.AND 4, ALL PREVIOUSLY UNRESERVED MINERALS,OIL,GAS, pETROLEUII~, Q'T~1~ HYD1t~CARHON SUBSTANCES AND ALL UNDERGROUND WATER IN OR UNDER OR WHICH MAY BE PROD[3CED FROM THE ABOVE-DESCRIBED LAND W~-IiC~I UNDERLIES A PLANE PARALLEL TO AND 500 FEET BELOW THE PRESENF SURFACE OF SUCH LAND FOR THE PURPOSE OF PROSPECTING FOR,THE EXPLORATION,DEVELOPMENT, PRODUCTION,EXTR.A.CTION AND TAKIl~TG OF SUCH MINERALS,OIL,GAS,PETROLEUM,OTHER HYDROCARBOAi SUBSTANCES ACID WATER FROI1h SUC~I LAND BY MEANS OF MINES,WELLS,DERRICKS OR OTHER EQUIPMENT FROM SURFACE LOCATFONS ON AD30INiNG OR NEIGHBORING LAND OR LYING OUTSIDE OF THE ABOVE DESCRIBED LAND,IT BEING UNDERSTOOD THAT THE OWNER OF S~3CH MENERALS, OIL, GAS,PETROLEUM,OTHER HYDROCARBON SUBSTANCES AND WATER,AS SET FORTH ABOVE,SHALL NO RCGHT TO ENTER UPON TAE SURFACE OR ANY PORTION 2! -20._ MARRIAGE OF DEPP STIPULATED JUDGMENT OF DISSOLUTION OF MARRIAGE L.A.S.C.CASE NO.BDb41052 ALD JCD jdg.p9l416• A.vS,w Heard - MTD Exhibits - 221 ~~ I ~~ 2 THEREOF ABOVE SUCH PLANE PARALLEL TO AND SOQ FEET BELOW PRESENT SURFACE OF SUCH LAND FOR ARTY PURPOSE WHATSOEVER. 3 PARCEL N0.2 4 6 AN UNDNIDED ONE-ENE HUNDRED FORTY-SEVENTH (1/1~7)FEE SIMPLE INTEREST AS A TENANT 1N COMMON IN ~1ND TO ALL OF THE REAI.PROPERTY COMPRISING THE COMMON AREA(AS DEFINED IN SECTION 1.19 O~ THE DECLAR.ATYQN DESCRIBED BELOW}. 7 PARCEL NO.3 5 8 ' 9 AN EXCLUSIVE EASEMENT APPURTENANT T4 THE UNIT FOR STORAGE PURPOSES OVER THAT CERTAIN EXCLUSIVE USE COMMON A~tEA FOR STORAGE SHOWN AND DESIGNATEA IN THE ABOVE~REFERENCED PT,AN AS "S-19". 10 PARCEL N0.4 ll ld NON-EXCLUSIVE EASE~NT FOR ACCESS,INGRESS, EGRESS,ENCROACHIviENT,SUPPORT,MAII~ITENANCE, DRAINAGE,USE,ENJOYMENT,REPAIR,AND FOR OTHER PURPOSES,ALL AS DESCRIBED IN THE DECLARATION OF COVENANTS,CONDITIONS AND RESTItYCTIONS AMID RESERVATION OF EASEMENTS FOR EASTERN COL[3MBIA LQFTS RECORDED ON 1~FOVEMBER 3,2006, AS INSTRUMENT I~IO, 46-2447337,IN THE OFFICE OF THE LOS ANGELES COUNTY RECORDER("DECLARATION"). APN:5144-0~ 7-290 17 3.3.2 On or before September 1, 2016,Petitioner shall vacate and/or cause any thud 12 13 14 15 IS parties to vacate penthouse units I,4, and 5. Any and all of p'etitioner's andlor third parties' personal 19 property shall be rerr►oved therefrom by that date. Respondent or his representatives shall be 20 permitted to list for sale, mazket and sell penthouse units I and 2 immediately, and penthouse units 4 21 and 5 e$'ective September 1, 2016. It is acknowledged and confirmed that Petitioner has fully 22 complied with this provision. 3.3.3 Petitioner shall leave penthouse units 1,4 and 5 in good condition, and it is 23 24 acknowledged and confirmed that Petitioner has met all obligations of this instant provision. Except 25 as otherwise set forth herein and for aII those awarded to Petitioner, a!l household items therein (not 26 including clotkung and other personal effects) shall remain in the units when the units are vacated. 27 111 2$ -21MARRIAG~ OF DEPP ST[PULATEll.~UDGN~IVT OF DYSSULLJTYON OF MARRIAGE L.A.S.C. CASE NO.BD64145Z ~, ~ ._-Ai~b JCD jdg.091416 - A,vS.wp Heard - MTD Exhibits - 222 ~~ 1 3.3.4 On or before December 31, 2U16,Petitioner shall vacate and/or cause any ttrird 2 parties to vacate penthouse unit 3. Commencing September 1, 2016, Petitioner shall make penthouse 3 unit 3 available tq be shown to prospective buyers ofthe property upon 48 hours written notice, 4 Petitioner shall easure that penthouse unit 3 is clean and in goad condition for any and ai! properly 5 noticed sbowrngs. A representative ofPetitioner shall he present to ensure that no pictures or 6 personal belongings are taken dwring showings. 3.3.5 Petitioner and Respondent shat! meet and cont'er to divide the furniture and 7 8 furnishings contained in penthouse units 3 and 5. Furniture and furnishings shall specifically exclude 9 any and all items in penthouse unit 2 a.nd any and all artwork located in any ofR.espondent's 10 residences or office, which shall be awarded to Respondent as his separate property. Petitioner shall 11 be awarded as her separate property any and all ofher personal possessions, clothing,jewelry, books, 12 etc. kespondent's representatives shaII retrieve any and atl ofhis persoIIal possessions, ctothiag, I3 instruments, books,jewelry and artwork from penthouse units 1, 2, and 4 an or before August 15, 24 20th, A$er the parties have met and conferred, and agreed upon the division of the furniture and 15 furnishings in penthouse units 3 and 5, Respondent's represeatatives shall retrieve items awarded to 16 Respondent from said units, I7 4. EQUALIZATION PAYMENT 18 4.1 19 Ta effectuate an equal division of the community estate and to resolve all other issues between the parties, Respondent shall pay to Petitioner Che sum of$7,000,000, as follows: 4.1.1 $200,000 on ar before August 31,2016. Petitioner and Respondent Za 21 aclmow(edge and agree that said payment was made by Respondent as follows: $100,OQ~ to the 22 American Civil Liberties Union and $100,000 to Children's Hospital of LQs Angeles. Petitioner and 23 Respondent further acknovsrledge and agree that Respondent sha11 be entitled to claim this eharitabfe 24 contribution on his federal aid state income tax returns. 4.1.2 $1,000,000 within three {3} days of entry of this Judgment; 25 26 II 111 27 1/1 28 -22MARRtAGE OF DEPP STIP[3LATED NDGMENT OF DISSOLUCION OF MARRIAGE L.A.S.C. CASE NO.BDG41052 -•~~ ALD ~JCD jdg.091416 .A.v3,~+pi Heard - MTD Exhibits - 223 ~J ~~ 4.1.3 Respondent sha[1 make additional payments to Petitioner on or before the dates i~~~ listed below, unless this .Tudgment has not yec been executed by Petitioner atld her counsel, in wtuch 3 event the paymeat shall be delayed until the execution ofthe Judgment: 4 4.1.3.1 $1,000,000 an ar before February 2, 2017; 5 4.I.3.2 ~ 1,Q40,U00 on or before May 1,2017; 6 4.1.3.3 $Z,OQ0,040 on or before Aug~t:st I, 24]7; 7 4.1.3.4 $500,000 on or before November 1, 2017; and 4.1.3.5 $2,300,OOt? an or before February 1, 2018. 9 4.2 Thy payments set forth in pazagraph 4.1 above shall accelerate upon the sale of the 20 real property owaec! by Respondent in France (referenced in paragraph 32 above}. Within ten(10) 11 business days of the close of escrow on the real property in France, f~espondent shall pay Petitioner 12 25°lo ofthe nit proceeds from the sale up to the fu!! amount ofthe equalization payment then due and 13 j owing to Petitioner pursuant to paragraph 4.1 above. This payment shall be made directly through 14 escrow. Under no circumstances shall Petitioner be entitled to more.than We $7,OOd,000 equalization 15 payment set forth in paragraph 4.1 above. Further, under no circumstances shall Respondent's 16 obligation to pay the full amount ofthe equal~ation payment of ~7~000,000 to Petitioner as set forth 1? in paragraph 4.1 above be extinguished or discharged by any type of bankruptcy proceedings, 18 bankruptcy procedure, the filing of a petition {voluntary or involuntary) declaring Respondent 19 personaIly or any of his related corporations bankrupt and thereafter unablc to meet Respondent's 20 payment obligations due to Yetitianer. 21 4.3 The et~ualization payments set faith in paragraph 4.1 above shall be secured by 22 Respondent's back-end compensation from Pirates of khe Caribbean S and the Sweetzer real 23 properties (referenced in paragraph 3.2 above} confirmed to Respondent. 24 4.4 The equalization payments provided above are nontaxable, non-modifiable, and 25 `~ non-Eennina6le upon Respondent's death, Petitioner's death, or PetiEioner's remarriage and shall not 26 be subject to further order of Court. In the evert of Respondent's deati~ prior to satisfaction of the 27 obligations set forth herein, Respondent's estate shall remain liable for the obligations set forth in this 28 -23MARRIAGE OF DEPP STIPT.fI,ATEDJUDGMENT OF DISSOLU7'FON QF MARRIAGE L.A.S.C.CASE LVO.BD641052 ~ -•ALD JCD jdg0914{6-A.vS.wpd Heard - MTD Exhibits - 224 CG 1 C section regazdless of whether Respondent's estate is probated. The equalization payments are 2 intended to be tax-free payments to Petitioner under ~nt~rcial Revenue Code Section 1 U41 as a 3 transfer incideat to divorce and shall not be deducted by eittcer party or taxable to either party. 4 5 4.5 be dischargeable in any bankruptcy proceeding filed by Respondent. 4.b 6 7 The equalization payments are considered a domestic support obligation and shall not The equali~atioa payments are not considered a debt but rather an order, and therefore, in the event that Respondent fails to make the payments,Petitioner shall be entitled to . 8 enfvrc~ the payments is an enforcement action. The Court shall have jurisdiction to issue appropriate 9 enforcement orders against Respondent if he fails to make the equalization payments. ]0 5. MUT~IAL WAIVER OF SPOUSAL SUPPORT I1 S.l Petitioner and Respondent have each forever absolutely waived and released any and 12 all rights which be or s~~ may have to seek spousal support, maintenance, or alimony from the other 13 party at any time. Each party has released and discharged the other from any and all obligations, 14 statutory or otherwise, to provide spousal support, maintenance, or aiisnony to the other. The parties i5 ~ acknowledge and agree that no spousal support arrearages are owed by either party tv the other l6 party, 5.2 17 No Court sha[I ever obtain or retain ~risdiction to order or award any spousal s~spport 18 payable b~ either party to the other party at any time, regardless of any circumstances that may arise. 19 This jurisdictional iunitation is absolutely non-modifiable and no Court shall ever have the power to 20 set any support payable by Petitioner to Respondent, or by Respondent to Petitioner. Having made 21 this waiver, Petitioner and Respondent acicriowledge and agree that each is precluded from malting 22 any subsequent claim for spousal support. Petitioner and ResgandenE acknowledge and agree that 23 ttus waiver may result in hardship to either one ofthem at some point in the future, and t3~at each has 24 considered this in electing to fix £or all time the rights ofPetitioner and Respondent to receive spousal 25 support from the other. 26 ll! 27 111 28 -24MARRIAGE OF DEPP STIPULATED J'C]'DGMENT OF DISSOLUTION OF MARRIAGE I.,A,S.C. CASE NO.BD641052 ~~J •. ALD JCD is&o9~ais.,~,.,,s.wy Heard - MTD Exhibits - 225 5.3 With the advice ofexperienced, competent counsel, and with frill knowledge of her 2 rights and the effect of the waiver, Petitioner has waived her right to seek any spousal support from 3 Respondent. With the advice of experienced, competent counsel, and with full knowledge of his 4 rights and the effect ofthe waiver, Respondent has waived his right to seek any spousal support from Petitioner. The Court approves said waiver and based thereon terminates forever its jurisdiction to 6 7 order spousal sapport from Petitioner to Respondent or from Respondent to Petitioner. 5.4 Each party has represented and acknowledged,for the other to re!y upon in entering 8 into this Judgment and for the Court to re[y upon in signing this Judgment, that he or she bas fully 9 discussed the spousal support provisions of this Judgment with his or her lawyer, that he or she 10 understands that except for theix agreement, the Court would have to take into cpnsideratioa their 11 marital lifestyle, their respective income and needs, the duration of their marriage, and many other l2 factors. The waivers contained in this Judgment are absolute and irrevocable. Once the Court 13 relinquishes jurisdiction over spouss~ support, the Court can never agaun, far any reason, consider the 14 subject of, ar make an award o~ spousal support, 15 5.5 The parties have acknowledged and agreed that they have carefully bargained in this ~b Judgment far tie mutual waiver ofspousal support, and that said waNer ~s an integral pazt of their 17 negotiations, and an integral part of the terms and conditions ofthis Judgment. The parties have !8 acta~ow2edged, each to the other, that they understand that such relinquishment ofthe right to spousal I9 support and maintenance is permanent and may not be resurrected for any purpose whatsoever, 20 notwithstanding what their economic or physical condition is now or may be in the future. The 21 parties have knowingly and wiEh the advice ofcourse! permanently waived any right they may have 22 from the other for support or maintenance or the equivalent thereto. The parties further acknowledge 23 that they are familiar with and have been advised as to the legal mlport ofthe case ofIn re Mamage 24 of vomacka(1984} 36 CaI.3d 459 and those cases that fouow its principle. The provisions herein are 25 intended to comply with the requirements ofin re Marriage ofBrown (1995)3S Ca1.App,4th. 785 2b and In re t~farriage ofIberli(1997} 55 Cal.App.4th I~34, to rnalce clear that no Court shall have the 27 authority to awazd spousaUQartner support to Petitioner or Respondent at any time. Thus, the parties 28 -ZSMARRIAGE OF DEPP STIPULATED JUDGII~NT OF DIS50LUT10N OF MARRYAGE L.A.S.C. CASE IYO. BD64Ia5Z ~~~, ..._ ALD JCD jAg0914J6 -A.viwp Heard - MTD Exhibits - 226 l._~ 2 acknowledge they each have intended to memorialize the absolute and unequivocal intention of the 2 parties to mutually waive forever their right to receive or claim spousal support or its equivalent fzom 3 the other for all time. 4 6. ATTORNEYS ACCOUNTANTS,ANll EXPERTS FEES AND COSTS 5 6.1 6 The parties acknowledge that they agree t~ cooperate fully with each other iri this dissolution proceeding until the entry ofthe Judgment in this matter in order to min~m»e the amount 7 of attorneys' fees and costs each party will incur. 6.2 8 Petitioner and Respondent sha!!each remain responsible for ~iis ar her respective 9 attorneys', accountants', and/or other experts' fees and cos4s incurred through the entry of Judgment, 10 with the exception of a $500,000 contribution by Respondent toward Petitioner's attorneys' fees and 11 costs. Said X500,000 contribution shall be paid directly to Petitioner's attorney Samantha Spector as I2 follows: 6.2.i ~ 100,000 on or before August 31,2016. Petitioner and Respondent 13 14 ~ acknowledge that this provision was satisfied and said payment was timely made to Samantha 15 Spector. b.2.2 Respondent shall snake additional payments to SamaQtha Spector an or before l5 17 the dates listed below, unless the ]udgment has not yet been executed by Petitioner and her counsel, 18 in which event the payment shall be delayed until the execution of the Judgment: 14 5.2.3 $150,OQ0 on or before December 1, 2016; and 20 5.2.4 $2SO,a00 an or before Februazy 1,2017. 2I 6.3 The Court re#ains jurisdiction aver the issue of attorneys' fees and casts incurred by 22 either party after the Effective Date. 23 24 25 7. TAXES 7.1 Petitioner and Respondent acknowledge and agree that each bas filed or intends to fale se~rarate federal and state income tax returns for calendar year 2fl15 and throughout tie marriage. 26 Each party shall be solely Gable far all taxes arising from his or her respective income tax returns 27 28 including, but not limited to, any taxes, assessments, interest, and penalties due, -26MARRIAGE OF DEPP ~ S'~IPULATED JUDGMENT +OF DISSOLUTION OF MARR]AGE L.A.S.C. CASE N0.BD64105Z ALD t '-~J JCD jdg.091416 • A.vi.wpl Heard - MTD Exhibits - 227 7.2 Petitioner and Respondent shaII continue to file separate federal and state income tax 2 returns (single ar mazried with a new spouse or head ofhousehold} each year from and including 3 calendar year 2416. Petitioner and Respondent shall each be responsible for his or her respective 4 income tax liability attributable to calendar year 2016 and each caiendaz year thereafter(based upon 5 her or hss income and deductions shown on his order separate returns)and eacl~ shall be entitled to s his or her respective tax refund and credits for 201b and thereafter. 7 7.3 The parties aclaiowiedge and agree that no Less than $10, 00,000 in income tax debt accrued during the parties' marriage. Respondent shall assume all such community property and 9 separate property income tax debt, with tie exception of any community property income tax debt 10' incurred as a consequence of Petitioner's work efforts during the maRiage. I1 7.4 Each party shall pay, indemnify, defend, and hold the other party free and harmless 12 dam any and all tax liabilities, penalties and interest attributable to each of the party's respective 13 incomes (defined as community property income earfled by each pazty based on Eheir work efforts 14 during the marriage and their separate property income)far the years prior to the marriage, the 15 calendar year 2015,and all calendar years thereafter. Each party sl~all pay, indemnify, defend, and 16 hold the other party free and harmless from acid against a~ lia~ri~ty arising from the fling of their 17 respective separate state and federal income tax returns pursuant to this paragraph. 18 7.S Except as otberwise set forth herein, Petitioner shat!assume ail income and liabilities 19 cif any)for those assets awazded and confirmed to hec in Section 3.1 above and gay any and all taxes Za far said income and claim any deductions con~nencing with her 2016 federal and state income tax 21 returns and shall indemnify and hold Respondent hazmless therefrom. Except as otherwise set forth 22 herein, Respondent shall assume all income and liabilities (if any) for those assets awarded and 23 confirmed to hun in Section 3.1 above and pay any and a!! taxes for said income and claim any 24 ded~ariQns commencing with lus 2016 federal and state income tax returns and shall indemnify and 25 26 27 28 hold Petitioner harmless therefrom 7.6 All allocations of property hereunder are transfers of property incident to divorce, within the meaning ofInternet Revenue Code Section 1041. -27MARRtAGE OF DEPP ST{PLR,ATED JUDGMENT OF DISSOLUTION OF MARRIAGE L.A.S.C.CASE NO.~3Db41051 ~ ALD JCD ,_ jdg69i41b-A.vS.wF Heard - MTD Exhibits - 228 ~ rj 1 7,7 V Except as otherwise expressiy provided herein, each party sna~t be responsible for, and 2 indemnify and hold the other harmless from, any taxes due as a result ofpostjudgment 3 ownerstup, sale, transfer, or other transaction involving righEs or assets Ehat each party obtains or 4 retains under this Judgment. 5 ~.8 As used in this section, the wards "assessment","t3X," "t87tfS," "deficiency," ~►[ld 6 ``refund" shall include interest and penairies, if any. 7 8 7.4 Each party has been further ad~+ised by his or her counsel that such counsel are not tax experts, that there are certain tax consequences that may fallow from this Judgment, and that each 9 party has been advised to seek independent tax counsel to advise them ofthe tax consequences, and is such caunse~ cannot make representations orrender advice with respect to the tax cflnsequences to iI F Judgment. either party as a result ofthe ternis of this 7.10 i2 13 Neither party shall file any tax returns that aze inconsistent with the tax consequences contemplated by the parties in this ]udgment. 14 7.lI In tYse event of a dispute, tine Court shall retain jurisdiction to make further Orders that 15 are necessary to enforce the provisions of this Eax section andlor any other portion of this Judgment. Y6 S. OT~R PROCEF~DIlVGS 8.1 !7 Petitioner represents, and Respondent acknowledges and agrees, that on August 1 b, 1$ 2016 Petitioner dismissed her Request for Domestic Violeece Restraining Orders against Respondent, 19 with prejudice, in this dissolution action. The parties agree that neither Petitioner nor Respondent 20 was the prevailing party for purposes of Code of Civil Procedure Section 1Q32,Family Code Section 21 4344, or any other statute. 22 8.2 0n September 2, 20Ib, Petitioner dismissed, without prejudice, the action she initiated 23 against Doug Stanhope in Arizona: Arnbcr Heard v. Doug Stanhope, Arizona Superior Court, 24 Cochise County Case No. CV201G04280, and such dismissal has been confrmed. petitioner shall not 25 initiate any ether proceeding agauLst Doug Stanhope relating to his conduct prior to Augast 16, 2016. 26 Petitioner may, however, fie a future claim against Doug Stanhope in Ehe event that Doug 27 ll! 28 - 28 MARRIAGE OF DEPP STII'ULATED JUDGMENT'OF DIS50LUT10N DF NJARRIAGE L.A.S.C. CASE NO.BD441452 AI.D ' ~~~~ JC?) -• Jdg~9lVl6 - A.vS.wpi Heard - MTD Exhibits - 229 ~~ Stanhope engages in actionable conduct after August 16, 2016. Respondent represents that he tunely 2 made f~is best efforts to request that Doug Stanhope make a positive statement about Peritioner. 3 8.3 Neikher Petitioner nor Respondent shall pursue any civil action(including, but not 4 lunited toy actions for assault or battery, negligent or intentional infliction ofemotional distress, I~bel, S slander, or defamation, and/or any "Marvin" clams arising before the parties' marriages against the other for any reason in anyjurisdiction for anything that occurred for the time period through and including the execution ofthe DPM on August 15!16, 2016. 8.4 Petitioner represents that she has not filed a police report claiming there was any 9 criminal wrongdoing by Respondent. Petitioner shall not be limited in any way with fully complying 10 with any valid legal process ~r cooperating with any law enforcement investigation. In the event that 11 Petitioner is served with any valid legal process relating in any way to Respondent and/or this 12 dissolution action, Petitioner shall notify Respondent in writing within 48 fours ofreceipt ofthat legal 13 process so that Respondent may make any and all appropriate and legal objections to such process as 14 he deems necess2uy. 15 9. TRANSFER OF PROPERTY 16 9.1 All property divided pursuant to this Judgment shall become the separate property l7 and/or obligation of the party so designated to receive such property as ofAugust lb, 2416. The 18 party receiving such divided property shall indemnify and hold the other party harmless from any and 19 all debts, liabilities, or obligations in connection with such property. 9.2 20 Each party shall promptly, upon request ofthe other party or counset of the other 21 party, execute, ackno~rledge, and deliver to the other party, his or her heirs, executors, 22 administrators, or other representatives, all deeds, tax retains, amendments to tax retains, amended 23 returns, leases, contracts, releases, certificates of partnerships, escrow agreements, partnership 24 agreements, loan agreements, refinancing agreements, loan applications, bi11s ofsale, insurance 25 documents, designations of beneficiaries, andlor other instruments and documents w~tich may 26 hereafter be necessary or desirable to enable either ofthe parties to seil, transfer, redesignate 27 1l1 28 -Z9MARRIAGE OF DEPP 5TiPULATED JUDGl1~NT OF DISSOLUTION QF MARRIAGE GA.S,C.CASE Ka.BD641052 ~~ _ ALD JCD jdg091416 - A,vS.wp Heard - MTD Exhibits - 230 .} ~} beneficiaries, or own any real or personal property acquired under, before or after the execution of this Judgment, or to carry out the terms ofthis 3udgment. 4.3 Should a party required to execute and deliver such documents fail to do so within 4 seven(7} days after demand bas been made by the party entitled thereto, then the other party may make an emergency application to the cotut, accompanied by the minimum of forty-eight(48) hours (excluding Saturdays,Sundays and legal holidays) telephonic ex-parte notice ofsuch application to 7 the other party, in order to carry out such orders as may be necessary to obtain the execution ofsaid documents and to obtain delivery ofsame to the party entitled thereto; and, the Clerk ofthe Court oz 9 the Assistant Clerk of the Court may sign in place of the other party pursuant to t}ae request ofthe 10 party making khe applicarion. ii 9.4 The Court retains jurisdiction to make such other and fiuther orders as may be 12 necessary, convenient, or required with respect to the form of any documents which are or maybe 13 necessary to effectuate the purpose ofthis Judgment, and any aggrieved party may make application 14 to tie Court for such purposes npfln ex pane application onforty-eight(4$)hours advance notice as 15 defined above. 4.5 ld Not~vithstanding the fai~ur'e or refusal of either party to execute any such document or 17 instrument, the parties' execution ofthis Judgment shall consritute a fu11 and complete transfer 18 conveyance, ar assignment ofthe prapert~ herein designated as being transferred, conveyed, or j9 assigned by each party. ZO 14. ASSIGNII~ENT f~F DEBTS/OBLIGATIONS 10.1 21 Petitioner and Respondent aclrnowledge and agree that there are no community debts 22 or obligations due and owing by the parties or either ofthem nat otherwise speci6cal~y set forth in 23 this Judgment. In the event there are community obligations or other obligations not otherwise 24 provided for in this Judgment, khe party who incanted such obiigation(sj s~a~ assume fu~~ 25 responsbility to discharge said obligations}, and shall indemnify and hold the other party free and 26 harmless therefrom 27 111 28 -30AGE OFD P STIPULATED JUDGMENT OF DISSOLUTIgN OF MARRIAGE L.A.S.C. CASE NO.BD641USZ ALD +` ~ ~`=~ JCD ~a~.osrate • ~Ys..~ Heard - MTD Exhibits - 231 r.t CJ 14.2 Except as otherwise set forth herein, Petitioner hereby assumes and agrees to pay any 2 and afl unpaid debts and obligations incurred by Petitioner prior to the Date ofMarriage, during the mamage,and subsequent to the Date ofSeparaEian, and to indemnify Respondent and hold him 4N ham~,tess therefrom. 10.3 Except as otherwise set forth herein, Respondent hereby assumes and agrees to pay any and atf unpaid debts and obligations incurred by Respondent prior to the Date ofMarriage, During the Marriage, and subsequent to the Date of Separation, and to indemnify Petitioner and hold 8 9 her harmless therefrom. 1 D.4 Each party is ordered to indemnify and bald the other harmless from any and all debts IO and objigations retating to or arising out ofthe assets confirmed to each respective party 11 under this 3udgment, and from all costs and expenses,including, but not limited to, attorneys' fees, in 12 connection therewith. 13 I~.S Except as otherwise set forth herein, Petitioner warrants to Respondent that 24 Petitioner has not,incurred {except as othervs►ise provided in this Judgment}, nor will Petitioner incur, 15 any liability, or obligation for which Respondent is or may be liable, If any claim, action or 16 proceedings arising out Qf the representation set forth in this paragraph shall herea$er be brought 17 seeking to hold Respondent Liable on account of any liability or obligation for which Petitioner is ar 18 may be liable, Petitioner shall, at Petitioner's sole expense, defend Respondent against all such claims 19 or demands and Petitioner shall hold Respondent free anal ~arniless therefrom. Respondent shall be 20 entitled to recover from Petitioner in such action, by cross-complaint, the amount of any Judgment 21 rendered against Respondent and Respondent shah be entitled to recover for all reasonable costs and 22 attorneys', accountants', and other expert fees incurred by Respondent. If Respondent is served with 23 legal process, Respondent may appear through counsel, defend the action, and also cross-complain 24 against Petitioner. Alternatively, at Respondent's option, be may seek redress for any}udgraent 25 suffered by him, including the aforementioned costs and fees via a Request for Order proceeding. 2b 27 28 14.6 Except as otherwise set forth herein, Respondent warrants to Petitioner that Respondent bas not incurred (except as otherwise provided in this 3udgment), nor will Respondent -31MARRiA E O AEPP STIPULATED JUDGMENT OF DISSOLUTION OF MARRIAGE L.A.S.C.CASE NO.BD641052 ALD ~~"~ JCD jdg.091416 - A.v3.wp Heard - MTD Exhibits - 232 incur, any liability or ob~igatian for wlueh Petitioner Ys or may be liable. If any claim action or 2 proceedings azising out of the representation set forth in this paragraph shall hereafter he brought seeking to bald Petitioner Liable on account ofany liability or obligation fir whick Respondent is Qr 4 maybe liable, Respondent sha[I, at Respondent's soEe expense, defend Petitioner against all such 5 claims or dcmands and Respondent shall hold Petitioner free and harmless therefroas. Petitioner sfiat~ be entitled to recover from Respondent in such action, bycross-complaint, the amount of any 7 ]udgment rendered against Petitioner and Petitioner shall be entitled to recover for atf reasonable costs and attorneys', accountants', and other expert fees incurred toy Petitioner. IfPetitioner is served 9 with legal process, Petitioner may appear through counsel, defend the action, and also cross-comglain 10 against Respondent. Alternatively, at Petitioner's option, she may seek redress for any,~udgment I1 su$'ered by her, including the aforementioned costs and fees via a Request for Order proceed+ng. 10.7 12 13 Except as otherwise set forth herein, each party has warranted to the other that be or she shall not hereaftcr incur any indebtedness chazgeable against the other or his or her estate, nor }4 contract any debt or obligation in the name ofthe other, and each party is ordered to indemnify and ~5 hold the other harmless from and against any such indebtedness hereafter incurred or created by such 16 indecrinifying party. Except as otherwise spec~ca~ly set forth in this Judgment, each of the parties 17 hereto warrants to the other that he or she has not incurred any liability or obligation on which the 18 other is or may be I~abie. Petitioner and Respondent each shall indemnify and hold harmless the otter I9 party from and against any such liability or obligations heretofore incurred. 1 Q.8 20 Both parties shaIl forthwith surrender and cancei aI~ credit cards and charge accounts 21 presently outstanding upon which the other is, would, or may become liable. Each party 22 acknowledges and agrees that each shall be saleiy responsible for payment of any outstanding credit 23 card or cbarge account obligations held in his or her respective name. 24 11. DISCLOSURE 4F CUMMUNITY AND SEPAXt,ATE PROPERTY /OMITTED '25 ~~ ASSETS 26 27 28 Y 1.1 Petitioner and Respondent wazrant and represent to the othey that they have disclosed in writing in rhea respective Declarations of Disclosure and in this judgment all community, - 32 MARRIAGE OF DEPT' ST~ULATED JUDGMENT OF bI550Y.T1TION O~ MARRIAGE ~,,A.S.C.CASENO.SD641052 ALD ~ ~L~J JCD _ jdg,09f416-A.~S,wS Heard - MTD Exhibits - 233 l~ l quasi-community, and separate property assets and liabilities, and that neither ofthem knows ofany 2 real or personal community or segacate property except that which is set forth in their Declarations of 3 Disclosure and in this. Judgment. 4 5 11.2 Ifit shall berea~Yer be determined by a Court of competentjurisdiction that either Petitioner or Respondent is now possessed of any community and/or quasi-community property not 6 set forth herein or that Petitioner or Respondent has not disclosed herei~~ or that either oftherq since 7 the Date of Sepazation has made, without the consent of the other, any gift, transfer, conveyance, or 8 assignment ofany community property, in the amount of~10,000 or more, not disclosed to the other, 9 the Court shall divide the community and/or quasi-community property pursuant to Family Code 10 Section 2556. ll 11.3 Should either party subsequently team ofany e~nd~scIosed community gifts or any 12 ' after-discovered and/or omitked property, or should any Court so detercx~ine that either party failed to 13 disclose gifts ofcommunity property or failed to disclose the existence of any community, 14 quasi-community, or separate property. the parties agree that said events and/or determination shall 15 not maid or invalidate this Judgment. 11.4 16 None ofthe parties' rights set forFh in this Section I l shah be limited by the azutual i7 release ofclaims set forth in Section 12 herein. The Court reserves jurisdiction to make disposition of 18 all a#ter-discovered andior undistributed community andlor c}uasi-community property not otherwise 19 disposed ofby this rudgment. 2U ~ 12. 21 RIGHTS 12.1 22 23 WAIVER OF RIGHTS TO REYMBURSE1VfENT Il~~ERITANCE, AND AUDITING $xcept as otherwise expressly set forth in this Judgment, each party has waived all rights to reimbursement including, but not limited to, the foIlowing: ]2.1.1 Epstein credits jIn re Marriage ofEpstein (1979)24 Cal.App.3d 76~ and all 24 25 rights of reimbursement to which a party maybe entitled as a result ofthe payment ofcommunity 2b obligations since the Date ofSeparation. 27 IIJ 28 -33MARRIAGE O DEPP STIPULATED NDGMENT OF DTSSQLU'j'ION OF MARRIAGE L.A.S.C. CASE NQ.SD64I052 ALD r ~ ~'. .ICD ._ jdg.091416 • A.vS.wp Heard - MTD Exhibits - 234 L 1 12.1.2 Watts charges[In re Marriage of Walts(1485} l71 Cal.App.3d 3G6] and a!1 2 rights to reimbursement to which a party ar the community may be entitted as a result ofone party's 3 use of community assets since the Date of Separation, 4 12.1.3 All rights to reimbursement under Family Code Section 2b40 or otherwise,for 5 separate property contributed to the acquisition or maintenance ofcommunity property, including b without limitation all Section 2640 clauns which the parties may otherwise have. 7 1Z.I.4 Claims against either party to account for community property received, possessed or expanded by either party after tfie Date of Separation other than as stated in this 9 Judgment. 12,1.5 Claims pursuant to Je,fJries (credit and reimbursements} Marriage ofJeffries 10 I1 (1991)228 Ca1.App.3d 54$]for the allocation ar offset ofEpstein credits and Warts charges. 12.1.b Afl claims to reunbursements from the other party and/or community estate 12 13 zegarding loans oz payments made to or an behalf oftie parties and/or the commuciity estate ~4 subsequent to ihs Data ofSeparation through the Effective Date by the parties and their attorneys. ]2.I.1 Any other claims by or against either party, by or against the community estate 15 16 for any credit, reim~arsement, or surcharge, except as otherwise provided far herein. 12.1.8 Claims or reunbursements for liability, property, automobile, or other insurance 17 18 I9 premiums paid in advance ofthe Effective Date. 12.2 The waivers set forth herein supersede all exisEing cfl~rt orders, stipulations and 20 agreements betwten the parties. The parties each have warranted and represented that said waivers 21 22 23 24 are rnadc as part ofand iri cons~~eration for the division of assets as provided for in this Judgment. 12.3 Each party specifically waives any further auditing or accounting rights through the Effective Date with respect to the assets and debts awarded and confirmed to tie atner party hereon. 12.4 Neither party hereto shall in any manner, directly or indirectly, con#esE or appose the 25 probate of the other's will whether heretofore or hereafter made. Each ofthe parties hereby waives 26 and releases in favor ofthe other party all ofhis or her right to act as administrator or executor or 27 otherwise to administer the other party's estate. Each of the parties hereby waives, relinquishes, 28 -34MARRIAGE F b PP STIPULATED JUDGMENT OF DISSOLUTION OF MARRIAGE L.A.S.C.CASENO.BD641flS2 _. AI.D `'-'tJ JCD jd&09!416-A,vS.api Heard - MTD Exhibits - 235 ~1 releases and forever surrenders in favor of the other party, and to his or her heirs, assigns, and legal 2 representatives, any and a~ ofhis or her rights to claims or rights of election to take or acquire under 3 the laws ofthe State of California, or any other jurisdiction, any property, benefit ar interest o#'any 4 kind, nature or description, under any wig or testament ofthe other, and any and aiI right ra inherit, 5 one from the other, and any and all rights to receive any real or personal property(no matter how or 6 when said property was acquired) ofthe other upon the death flf the other, either under the laws of 7 succession or under community prpperty laws, or by way of dower, curtsy, or otherwise. Petitioner and Respondent waive,.release, relinquish, and surrender all such clairns and rights, if any, in favor of 9 the heirs ofthe other party—it ~euig understood that neither of the parties hereto shall have any right 10 to inheritance, descent, or distribution of anry kind in or to the estate of the other. Notwithstanding 11 anything to the contrary stated herein, either party hereto may, by will executed subsequent to the 12 date ofthe signing of this Judgment, make provisions contrary to those herein stated. 12.5 13 Except as set forth in Section 4.4, each party has relinquished the right to act as 14 executor or administrator ofthe estate of the other, a!i right to inherit from the other and all rights to 15 receive in any manner any property of the other upon the death ofthe other, either under the laws of 16 succession or under community property taws, or by dower, curtsey, family s!lourance, probatE 17 homestead, ur any statutory substitute therefore, or otherwise, except as devisee, legatee, or 18 bene5c~ary under any Last Wil!and Testament or other instrument executed after the Effective Date 19 by either Qarty herein or when the other party maybe named in such capacity. as 13. 2l MUTUAL RELEASE OF CLAIMS 13.Z Except as otherwise expressly set forth in this Judgment, and except for the claims, 22 obligations, and rights in this Judgment created against or in favor of either ofthe parties hereto, 23 which elairns, obligations, and rights are expressly reserved from the operation ofttus Section 13, 24 Petitioner and Respondent have released the other and all of his or her respective agents, 25 representatives, attorneys, heirs, insurers, assigns and successors-in-interest, from any and all claims, 2b demands, damages, debts, liabilities, obligations, accounts, reckonings, allegations, costs, expenses, 27 liens, actions, causes, and causes ofaction, ofany kind and notate whatsoever through and including 28 - 35 MAf~RiACCE OF DEPP ST~ULATED JUbGMEl\"f OF DISSOLUTION OF MARRIAGE L.A.S.C. CASE NO.BD64105Z `~ ALD JCD ••-• ~a$o9laia-e.+~.+~a Heard - MTD Exhibits - 236 LJ 1 ~~ the date ofentry of tivs Judgment. Each of the parties agrees and understands that there is a risk that 2 subsequent to the execution or entry ofthis Judgment, either of them may incur or suffer lass, 3 damage, or injuries which az~ in some way caused by, or related to, the matters released herein, which 4 are unknown or unanticipated at the time tk~ts Judg~ne~t is executed or entered. Each party hereto 5 assumes said risk and agrees to hold the other party harmless therefrom. 13.2 6 Notwitbstandi~g the terms flf this Section 13, nothing contained in this Judgment shall 7 be ~terpreted or construed as a waiver ofthe parties' rights of full disclosure ofcommunity and 8 quasi-community property under California Fatuity Code Section 2120-2128, The Court retains 9 jurisdiction over sue~z non-disclostue claims pursuant to California Family Code Section 255b with 10 respect to enforcement ofsaid Family Code Sections as set forth above. 11 I33 Except far the benefits, rights, and obligations created by this Judgment or reserved 12 herein and except as to any action to enfozce this 3udgcnent, it is the intention ofthe parties that this 13 Judgment shaII be a full and final accord and satisfacrion ofall claims, known and unknown, which 14 each may have against the other. The parties hereby waive Civil Code Section 1542, which provides 15 that"A general release does not extend to claims which the creditor does not know or suspect to 16 exist in his or her favor at the time of executing the release, which ifknown by him or her must 17 have materially affected leis or her settlement with the debtor." 18 14. 19 ADVICE OF COUNSEL, 14.1 Petitioner has acknowledged and represented that she has been represented by 20 Samantha Spector ofSpector Law and Pierce O'Donnell of Cneenberg, Gluslcer, Fields, Claman & 21 Machtitiger LLP in tie negotiations for and vn tie preparation oft$is Judgment aad ira connection 22 with the action for the dissolution of the marriage ofthe parties. 23 14.2 Respondent bas acknowledged and represented that be has been represented by Laura 24 A. Wasser and Samantha.Klein of Wasser, Cooperman & Mandles,P.C., Patricia Glaser and Kerry 25 Garvin Wright of Glaser, Glaser, Weil, Fink, Howard, Avchen &Shapiro, LLP,in the negotiations 26 for and in the preparation ofttus Judgment and i~ connection with tie action for the dissolution ofthe 27 marriage of the parties. 28 -36MARRIAGE OF DEPP 5'I~ULA?ED NDG~~'T OF DISSOL VTIQIIT OF MARRIAGE L.~l.$.C. CASE' N~.8~1~~~~2 ~'-" ~.~ .T~ id~~91416-A.rS.wp Heard - MTD Exhibits - 237 ~J 14.3 The parties acknowledge and agree that they have not been told that any provision of F~ this Judgment is "standard" The parties have reviewed each and every one of the provisiflns of this 3 Judgment and have negotiated those provisions as necessary to reflect their agreement and to meet 4 II their needs. 15. 6 WAVER OF FURTHER FORMAL DISCOVERY PROCEEDINGS 15.1 In negotiating the economic terms ofthis Judgment, each of the parties acknowledges 7 that he or she has had the opportunity to determine, both on a voluntary basis and through forma[ 8 discovery pzocedures, atl ofthe financial circumstances ofthe other party, and the income which each 9 is likely to derive from the property acquired by each hereunder. Concerning the nature, extent, and 10 value ofcommunity property(assets and liabilities}, and the parties' interest therein, the parties state 11 that each has relied upon his or her own respective knowledge opinion, and evaluations ofsuch 12 matters based an the other party's Disclosure Statements signed under penalty of perjury, that each 13 has read and understood his or her respective rights under this Judgment, and that each has sought 14 and obtained separate counseling from other persons that each selected concerning said matters. 15 15.2 Each ofthe parEies has warranted and represented that each party desired a settlement !6 ofsll of r}~e matters set forth in this Judgment and that.each party has chosen not to exercise all of the 17 formal and informal discovery rights available to him or her beyond what he or she has already 18 pursued, including without limitation, serving special interrogatories, form interrogat~ri~.s, requests 19 far production of documents, requests for admissions, issuing subpoenas, taking depositions of one za another and ofHurd parties, and/or obtaining further expert appraisals ofreal, personal, andlor 21 business properties and assets. 22 15.3 Each party has knowingly and expressly waived and released his or her respective 23 rights to complete full discovery, bath fvrnsal and informal, relating to any issues and procedures and 24 to investigate beyond what he or she has already pursued, the nature, extent, and value ofcommunity 25 property {assets and liabilities) and the parties' interest therein, and the financial circumstances ofthe 26 other party. Bach party has accepted the economic terms ofthis Judgment with full knowledge ofhis 27 or her respective rights ~n light of the foregoing waiver. 2$ -37MARRIAGE OF DEP STIPULATED JUDGME~N'T OF DISSOLU'C10N OF MARRIAGE L,A.S.C. CASE NO.BD641452 ALD ( ~. JCA ...._ jdg.U91416- A.vS.wp Heard - MTD Exhibits - 238 ~~ I S.~ ~/ Tlie parties acknowledge that by entering into a negotiated settlement of ali financial 2 issues between them, each bas knowingly waived his or her right to a full evidentiary hearing on the 3 merits with respect to those issues. Each party has acknowledged that each has been advised by his 4 or her respective counsel that the economic benefits conferred on each by this Judgment maybe 5 better or worse than the econonuc benefits that would be conferred on each after such a full 6 evidentiary hearing or trial and that the full impact ofthis Judgment may not be known for many 7 years. 8 15.5 Each party entered into this Judgment freely and voluntarily, and bad sufficient time 9 to consider the terms of the Judgment, and to consult with farens~c accountants, other experts, and 10 his ar her counsel about this judgment. Prior to executing ti~is Judgment, each party expressly 11 waived aad released his or her right to cflnduct any fiuther formal or informal discovery as set forth 12 herein. Each part}+ elected Eo proceed with the negotiations and settlement contained. in this Judgment 13 without resort to any fiu-ther formal or informal procedures prior to executing this ]udgment. 15.6 14 Each party has acknowledged that Califoznia law imposes a fiduciary duty an married 15 persons regarding the accurate and complete disclosure of all assets, liabilities, and investment 16 opportunities. I7 I6. VOLi]rITARY AGREEMENT 16.Z I8~ Each ofthe parties has acknowledged that ~c or sbe is fury aware of the content and 19 legal effect of this Judgment and that each party has acknowledged for himself or herself, and for the 20 other and t[ie Court to rely upoq that be or she has entered into the settlement oft~s action 21 voluntan~y and free of any duress, undue influence, or presently known fraud, and that both parties 22 are competent to enter into their agreement that formed tie basis ofthis Judgment, 16.2 23 Petitioner actcnowledges (a)that Respondent has obtained no advantage over her as a 24 result ofthis Iudgment,(b)that there is sufficient cansiderarion far Petitioner's entry into the 25 settlement agreement that is set forth in this Judgment, and (c)that Petitioner was not under any 26 undue influence in entering into this Judgment. 27 I11 28 38 MARRIAG OF DEPP STIPULA3'ED NDGIVIENC OF DISSOLUTION OF MARRIAGE L.A.S.C. CASE NO.BD641052 ALD C_ .: .-JCT1 jdg.091416 - A.r3,.~y~ Heard - MTD Exhibits - 239 ~'} 16.3 (_} Respondent acknowledges ~a) that Petitioner has obtained no advantage over him as a 2 result of this Judgrttent,(b) khat there is sufficient consideration for Respondent's entry into the 3 settlement agreement that forn~s the basis fflr this 3udgment, and (c) that Respondent was not under 4 any undue influence in entering into this Judgment. 1b.4 5 The parties fiurther acknowledge (a) that alE negotiations leading to this Judgment were 6 carried out at arm's length, tb) that each recognizes that his or her interests were adverse during such 7 negotiations and (c) that the confidential relationship arising aut of the marriage ofthe parties did exist during such negotiations. 9' 17. AGREEMENT TO LIVE SEPARATE 1~ID APART 10 I7.1 Except as otherwise provided in this 7udgcnent,the parties shall be free from 11 interference, authority, or control by the other and each may conducE, carryon, and engage in any iz employment, business, or trade which to him ar her shaII seem advisable for his or her sole and 13 separate use and benefit without and free from any direct or indirect control, restraint, or interference 14 by the other party. 15 18. 16 CREDITOR CLAIMS 1 S.1 Exce{~t as otherwisE provided in this Judgment, each party shall be solely liable for and 17 shall indemnify, render a defense, and. hold the other party harmless from all clauns, demands, deb#s, 18 ot~ligatrons, liabilities, income and capital gain taxes, rEal property taxes, casts, expenses, c[amages, 19 and liens arising heretofoze or hereafter from the businesses, real properties, and all other assets being 20 awazded and/or cvt~frnned to that party as his or her sole aria separate property_ Each party vs+arrants 21 and represents to the other that he or sloe is not awaze of any claim, debt, or liability not mentioned in 22 tfiis Judgment to wIueh the other party may have liability. 23 1$.2 Petitioner and Respondent aclrnowledge that each has been advised by his or her 24 respective counsel as foIIows: Although an obligation based upon a contract is assigned to one party 25 as part 4fthe division of the conunwuty, in the event that the party to whom the obligation was 26 assigned defaults on the contract, the creditor may have a cause ofaction not anIy aga~st the 27 assigned party, but against the other party as weU. 28 ,39MARRIAG O DPP STIPULATED JUDGMENT OF DISSULUTIQN OF MA~tRIAGE G,A.S.C.CASE NO.BD6410SZ .._ e~D ~~~-JCD ~ag,ov~a,s-ti~s.~ Heard - MTD Exhibits - 240 V 18.3 l~ 1 Petitioner and Respondent accordingly recognize that this Judgment between therr~ is 2 not binding upon thsd parties. In the event that any third party seetcs to hold one party liable for the debts or obligat9ons that the other has assumed by this Judgment, the indebted party herein steal! 4 defend and/or compromise and settle any lawsuits, claims, demands, or actions brought at his or her sole expense, and further, pay, indemnify, render a defense, and hold the non-indebted party harmless from any and all such clauns,demands, debts, obligations, liabilities, costs, expenses,.causes of action, 7 and judgments ofevery kind, nature, and description that the non-indebted party may be caused to 8 incur to defend hymselfor herself including payments for all reasonable attorneys', accountants', and 9 other experts' fees, costs, and expenses incurred by the non-indebted Qarty. Except for the IO signatories hereto, no third parties are intended to be benefitted by this Judgment and no such third 11 parties shall have any standing to enforce this Judgment, nor shall they be able to assert any right, 12 title, or in#erest ~ the assets herein ~@eati~ed. 13 19. l4 STIPULATION RE: APPUINTMEN'~'OF JUDICIAL OFFICERIJiTDGE PRO TEM 19.1 The parties acknowledge their intent to cooperate with one another and to resolve all 15 issues, if possible, without further litigation. Other than entry ofthe instant Judgment, the parties 16 stipulate that Judge Louis M. Meisinger, Retired, shall be appointed as a judge pro tem for all 17 purposes in this case. Accordingly, in the event that the parties encounter disputes as to any 18 provision herein, the parties agree that they will submit any and all disputes for mediation and 14 resolution to 3udge Louis M. Messinger, Retired as a judge pro tem, or ifJudge Messinger is za unavailable for any reason to another mutually agreed upon retired judicial officer. 21 19.2 After the entry ofthis Judgment, the parties shall immediately file a stipulation for an 22 order appointing Retued Judge Louis Messinger as the judicial officer to resolve all disputes between 23 24 25 26 the parties arising aut of or relating to the 3udgment. 19.3 The parties agree that Judge Messinger shall adjudicate any claims that the parties may have relating to alleged breaches ofthe DPM_ 19.4 To the extent possible, the parties shall seek to keep confidential all proceedings, 27 pleadings orders, and the like relat~g tv aay adjudication by Judge Messinger. 28 44 MARRIAG OF DEPP I..A.S.C. CASE NO. BD641d52 .._ C ST7pULATED JUDG1►~NC OF DISSQLUI'ION O~ MARRIAGE ~~-ALD JC[3 ja&oq~atb-a..s..wd Heard - MTD Exhibits - 241 ~~ 20. 3 CONFIDENTIALITY . 2U.1 2 ~J Except for dflcurnents previously filed with the Court, neither Petitioner nor Respondent shall discuss, publish or past or cause to be discussed, published or posted, duectly or 4 indirectly, any information pertaining to the parties' premarital relationship, marriage or this 5 dissolution action on the Internet {including, but not limited to, social media applications, websites, 6 blags, news periodicals, etc.) or in the media ~n any manner. Petitioner and Respondent shall also insixuct their respective agents,friends, family members,and representatives not to communicate and/or act in any uray contrary to this provision. 20.2 9~ The confidentiality provisions set forth herein shall be fully enforceable by each party. lU Tl~~ parties each expressly acltnotivledge and agree that the confidentiality provis~Ans in this judgment I1 are of a special, unique, unusual, and extraordinary character and that a breach ofany confidentiality 12 provision of this Judgment shall necessarily result in irreparable in3ury to the other party for which na 13 adequate remedy is available at law and which is not fully compensab~e in money damages alone. The 14 parties further acl~owledge and agree that in the event of any such breach or threat thereof, the 15 non-breaching party may be entitled t4 injunctive and any other ec}uitable relief as may be necessary to lb prevent, remedy, and/or mitigate the adverse effects flf such actual or threatened breach; in addition l7 ko any legal remedies, such as disgorgement of profits received or damages to which said party may 18 lie entitled. The parties acknowledge and agree that the non-breaching party also shall be entitled to 19 setk recovery of any and all reasonable attorneys' fees and costs incurred to pursue such remedies. 20.3 20 Each ofthe parties hereto acknowledges, agrees, warrants, represents and covenants 21 that, except as wap be required by law, each said party shall refrain from making or causing to be 22 made, and agrees not to make or cause to be made, any derogatory, disparaging,.eritical or 23 accusatory statements;either directly or indirectly, express flr implied, oral or written, concerning fhe 24 other party, whether said statements are believed to be true or not. 20.4 25 The foregoing shall not be construed or enforced in a manner that wautd restrict the 26 ~tsclosing party from responding trut~'ully in response to any inquiry required by legal process. 27 /!! 28 -41MARRIAGE QF DEPP STIPULATEDJUDGMENT 4F DISSOLUTION OF r1~ARRIAGE L.A.S.C. CASE NO.BD641052 _..ALD ,~z- ~~ JCD jdg.091416 - n.v5.~ Heard - MTD Exhibits - 242 1 2 2X. MTSCELLAI~IEOUS 21.1 Each party has been advised by his or her counsel that such counsel are not tax 3 experts, that there are certain tax consequences that may follovs~~from this Judgment, and that each 4 party has been advised to seek independent tax counsel Eo advise them oftie tax consequences, and 5 such counsel cannot, make representations or render advise with respect to the tax consequences to 6 either party as a result of the terms ofthis Judgment. 7 8 21.1.1 In negotiating the economic terms of this Judgment, each ofthe parties aclaiowledges he or she has been advised by his or her counsel that he or she has had the opportunity 9 to determine, both an a voluntary basis and through formal and/or informal discovery procedures, alI 10 ofthe financial circumstances ofthe other party, and the income which each is likely to derive from I1 the groperty acquired by each hereunder. Each of the parties bas warranted and represented that each 12 party desired a settlement of all oftlae matters set forth in this Judgment and that each party has 13 chosen not to exercise any formal or informal discovery rights available to him or her prior to l4 executing this Judgment. Each party knowingly waives his or her rights to discovery, bath formal and 15 informal, and to investigate fully the financial circumstances ofthe other party prior to executiong this 16 Judgment. The parties also acknowledge that by entering into a settlement ofall financial issues 17 between them, each has knowingly waived her or his right to a full evidentiary hearing on the merits I$ vs~ith respect to those issues. Each party acknowledges that each has been advised by his or her 19 counsel that the economic benefits conferred on each by t}us Judgment maybe better ar worse than 20 the economic benefits that would be conferred after such a full evidentiary hearing. Nevertheless, 21 both parties have considered the ristc of litigation and the costs thereof, and have decided that it is 22 preferable to settle all the issues rather than to be subjected to the uncertainties associated with the 23 24 litigation process. 21.1.2 The parties acknowledge that they have been advised that prior to entering info 25 an agreement, including, wikhout (imitation, prior to signing this Judgment, they had and have the 2b right to value any and all assets owned by either ofthem, in whole ur in part. Such assets include, 2~ WS~]OU~ ~1IIllkBtlOri, companies(whether sole 28 proprietorship,"C" corporation,"S" corporation, -42MARRIAGE OF DEPP STIPCJY.ATED NDG1ViENT OF D15SOLUTiO~t OF MARRIAGE L.A.S~C.CASE NO.BDb4i05Z ALD ~ `:. JCD is&osia i6 - ~.~s.Wv Heard - MTD Exhibits - 243 ~~ "LLC," partnerships, DBA,or otherwise); professional practices; real property; intellechial property 2 (including catalogs ofsuch property};investments(of any kind); and defined benefit pension plans and other deferred compensation. To the extent that the parties chose not to value an asset or assets, the parties acknowledge that each party made such decision fi-ee~y, voluntarily, without any gressur~ or duress from anyone, and with the ~owledge that they could, in fact, value any and all assets prior to 6 entez-ing into an agreement and prior to signing this Judgment. pursuant to the parties' agreement, 7 neither party shall have the right to set aside or obviate any ofthe financial temss or conditions of this 8 Judgment by reason oftheff voluntary decisions not to value an asset or assets. 21.1.3 Based upon each party having been advised of the above descnbed rights to 9 10 fiuther formal discovery proceedings, upon execution of this judgment, neither party's counsel shall 11~ be respansble in any manner whatsoever with regard to the nature, extent, condition or value of any 12 ofthe asseEs and obligations, be they community,separate, confirmed by,or disposed of6y way of 13 this Judgment. 14 21.1.4 Each party acknolvledged far hixnseif ar herself, and for the other and the IS Court to rely upon, that be or sloe has relied solely on his or her own personaljudgment as to all 16 matters pertaining to the matters encompassed by tinis Judgment and that he ar she did not rely on any 17 statement, warranty or representation of any other party, except as expressly set forth in this 18 Judgment. 21.1.5 Neither party shall have the right to set aside or obviate any of the financial 19 20 terms or conditions of this judgment by reason ofthe foregoing waivers and decisions not to conduct 22 22 further discovery, appraisals and investigations. 21.2 The parties expressly intend and agree that this Judgment is a written settlement 23 agreement within the meaning ofEvidence Code Section 1123 and agree that it is not made 24 inadmissible, or protected from disclosure, by provisions of Evidence Code Section 1115 et. seq. 25 because it is signed by the settling parties and (a) it provides that it is admissible or subject to 26 disclosure, or words to that effect;(b)it provides that it is enforceable or binding or words to that 27 effect, and;(c) all parties to this Judgment expressly agree to its disclosure, The parties further agree 28 -43MAIiRIAGE OF DEPP STTPULATED JUDGMENT OF DISSOLUTION OF MARWAGE L.A.S.C. CASE NO.BD641052 ALb ~-JCD jdg091416-A.vS.wp Heard - MTD Exhibits - 244 C' 1 that communications between each party and his or her counsel are not made inadmissible by 2 Evidence Code Section 1115 et. seq.; provided, that such cammunica#ions are and remain privileged 3 under the attorney-client privilege. Nothing contained in this section shall be deemed to waive or 4 limit the attorney-client privilege or the attorney ~vark-product doctrine. 5 2L3 Eacb party waxrants and represents to the oeber party that he or sf~e has not since the G Date ofSeparation transferred any interest in any graperty nor encumbered any property awarded to ~ ~~ the other party pursuant to this Judgment. 8 9 2I.4 The parties understand and acIaiowledge that there rs a possibility tkat an asset awarded and/or confirmed to either of them hereunder may be sold a$er the Effective Date by the ]0 parties far an amount either substantially greater or substantiaIIy less than the value now believed or 1~ perc~eivea by either party to be tt~e fair market value ofsuch asses. Each party expressly waives and 12 releases any claun against the other arising out ofsuch sale. Each party further acknowledges that, l3 except as set forth in this Judgment and the parties' respective Disclosure Statements, neither has 34 warranted to the other fhe valve ofany asset awazded and/or confirmed by this Judgment. Y5 21.5 The party receiving specific property under this Judgment shall be entitled ta, and the 16 other party shall transfer and assign to him oz her, atl right, title, and interest in the property together 17 with any existing insurance iu the property, and the benefits, if any, ofpremiums previously paid on I8 that insurance, and shag be solely responsble for the payment of aII premiums due thereafter under 19 the insurance policy terms if the party decides, in his order sole discretion, to maintain said policy in 20 force. zl 21.6 This Judgment has been prepared and reviewed by the joint efforts ofthe respective 22. I~ attorneys far Petitioner and Respondent. This 3udgment shall be interpreted fairly and simply, and 23 24 not sErictly far or againsE either party. 21.7 The parties hive had an opportemity to review and revise this 3udgment and aze ZS satisfied with its temps; the normal rules of construction to the effect that any ambiguities-tin this 26 Judgment are to be resolved agairLst the drafting party shaII not be employed in the interpretation of 27 this Judgment, 28 -44MARRIAGE OF DEPP S'Y'IPULATED JUDGMENT OF DISSOLUTION OF MARRIAGE t.A.S.C. CASE r10. BD641052 ALD <, `~. JCD jdg.6914t6 • w.vS.wp~ Heard - MTD Exhibits - 245 ~' 21.$ ~y Each party is aware ofCalifornia Family Code Section 2424 which states as foIIows: Dissolution or annulment ofyour marriage may automatically cancel your spouse's rights under your will, trust, retirement benefit plan, power of attorney, pay on Heath bank account, transfer on death vehicle registration, swvivnrslup rights to any property owaed in joint tenancy, and anyother sunilar thing.It does not autamaticaflycancelyour spouse's rights as beneficiary of your Iife insurance policy. If these are not the results that you want, you must change your will, trust, account agreement, or other similar document to reflect your actual wishes, 3 4 6 8 Dissolotion or annulment ofyour marriage may also automaticaIIy cancel your rights under your spouse's will, trust, retirement benefit plan,power of attarrtey, pay on death bank account, transfer an death ve~cte registration, survivorship rights to any property owned in joint tenancy, 9 and any other similaz thing. It does not automatically cancel your rights as beneficiary of your spouse's life insurance policy, 7 10 You shfluEd review these matters, as well as any credit cards, other credit accounts, insurance policies, retirement benefit plans, and credit reports to determine whether they should be changed or whether you should tafce any other actiox~ in view of the ckissolution or annulment of your . marriage, or youx Iegal separation. li 12 13~ 21.9 Zn the event that either party has executed a Durable Pewer of Attorney far Health 14 Care pursuant to California Probate Code Section 4570 et seq., and has specified his or her spouse as 15 the designated agent, upon dissolution of marriage, the designated spouse will become ineligible, as a 16 matter oflaw, to act as the designated agent. For such purposes, it may be necessary for either or I7 both of the parties to appoint a new designated agent for purposes of a Durable Power ofAttorney l8 for Health Care. 21.10 In the event that any portion or provision or clause ar term of this Judgment shall be 19 20 held illegal, unenforceable, void, or voidable by any court, each of the remaining provssions/terms 21 hereof shall nevertheless remain in full force and effect. 21.11 No waiver ofthe breach of any ofthe terms or provisions of t3~is Judgment shah be 22 23 construed to be a waiver of any preceding ar succeed~g breach of the same or nay other provision 24 hereof. 21.12 Petitioner and Respondent each warrant and represent that neither has relied on any 25 26 oral or written representations made by anyone not contained in the Judgment. 27 !ll 28 -45MARRIAGE OF DEPP STiPLTI.ATED JUDGII~NT OF DISSOLUTION OF MARRIAGE L.A.S.C.CASE NO.BD641fl52 ALD ~ z_ JCD jdgWJ1/16 - A.rS.wp Heard - MTD Exhibits - 246 ~`} CJ 21.13 Petitioner and Respondent each acknowledge, for hanself or herself, that he flr sbe has 2 been advised that California Family Code Sections 721 and 1100 provide t4~at a fiduciary and 3 confidential relaEionship exists between spouses which "imposes a duty of the highest good faith and 4 fair dealing on each spouse and neither shall take any unfair advanEage ofthe other," that this 5 obligation shall continue `until such time as the assets and liabilities have been divided by the parties 6 or by a court," that said "duty incindes the obligation to make full disclosure to the other spouse ofall 7 material facts and infarmativn regarding the existence, characterization and valuation of all assets in 8 which the community leas or may have an interest and debts far which the community is or may be liabEe, and to provide equal access to all information, records and books that pertain to the value and 10 character ofthose assets and debts, upon request," that Family Code Section 2140{c} imposes upon 11 each party a "continuing duty to imine~iately, fully ar~d accurately update and augment" facts anti 12 information regarding the ex~stcnce, chazacterization, and valuation ofassets and liabilities in which 13 the community has or may have an interest to the extent there have been material changes relative to I4 such assets and liabilities, and that pursuant to Family Code Section 21.02, such updates must be 15 "immediate, fu11 and accurate" to the extent there have been any material changes. 21;14 Petitioner and Respondent agree that this 3udgment constitutes the entire agreement 16 17 and understanding between Petitioner and Respondent with respect to the subject matter hereof, and 18 supersedes and replaces all prior agreements and understandings whether oral or written. There are l9 no other agreements,understandings, statements, representations, or warranties of the parties, oral ar 20 written, except as expressly set Earth herein. 21.15 This Judgment, and each of the provisions herein, may not be altered, amended, 21 22 kerminated, modified, or waived, in whole or in part, except by an instrument in writing executed by 23 both ofthe parties hereto with the sane formality as this Judgment, or by fiuther order of the Court. 22.26 Petitioner and Respondent agree that tt~s 3u@gment is executed aa~ intended to be 2~3 25 Qerformed in tie State of California, and the Iaws ofthe State of California shall govern its 2b interpretation and effect. 27 111 28 -46MARRIAGE OF DEPP 5TIPULATED JUDGMENT OF DISSOi,UTIO~I OF MARRIAGE L.A.S.C. CASE NO.$D541052 ALD ~~~ JCD ~agosia~s. w.~s.+~ Heard - MTD Exhibits - 247 1 21.17 In each instance in ttus ]udgment where one patty indemnifies, renders a defense, and 2 holds the other party harmless, such indemnification and agreement to hold hamiless includes, but is 3 not expressly limited to, the obligation to pay or reimburse the other party far all reasonable 4 attorneys', accountants', and other experts' and consultants' fees, costs, and expenses which the 5 other party may incur in defending herself or himself against a breach ofsuch indemnity. 21.18 Each party warrants that he or she has read this Judgment and has had it fully 7 explained to hym or her by bis or her own counsel. The parties acknowledge that the provisions of S this Judgment aze fair and reasonable. The parties acknowledge that the provisions of this l'udgment 9 have been negotiated with their participation and understanding. 10 21.19 Notices: Any notice under this Judgment must be in writing and shall be effective II upon hand delivery or free (5) business days after deposit in tie United States mail, postage prepaid, 12 certified or registered, and addressed to Petitioner or to Respondent as follows: 13 To Petitioner: Amber Laura l7epp c/o john ]3lakeman, CPA MGtJ 2029 Century Park East, Suite 1500 Los Angeles, CA 90067 To Respondent: John Christopher Depp c/o Edward White, C.P.A EDWARD WHITE & CO.,LLP 21700 Oxnard Street, Ste. 400 Woodland Hills, CA 91367 14 15 16 17 18 19 2Z. FINALITY OF.~Ur1CMENT 20 22.I This Judgment is final and binding. z~ 22.2 Both parties understand and acknowledge that this Judgment is final and binding. 22 22.3 The provisions of this 3udgment constitute the ga~ties' marital settlement agreement. 23 22.4 The provisions of the marital settlement agreement shall inure to the benefit of, and be 24 (binding upon, the parties and their respective ~Zeirs, executors, administrators, successors, assigns, and f 25 legal representatives. 26 111 27 rtrrr 28 47. MARRIAGE O DEPP ''~~~ . STiPULA'fED JUDG1vIENT OF DISSOLUTION OF MARRIAGE L.A.S.C. CA$E l~'O. BD64i052 ALD JCD jdg09I6l6 - A.vS.wpd Heard - MTD Exhibits - 248 1 22.5 The parties waive their right to appeal, their right to request a StaEement ofDecision, 2 their right to move far a new triad, aad their right to file a motion pursuant to California Code of Civil 3 Procedure Sectifln 473. 4 22.6 Each party has had an opportunity to consult with attorneys, accountants, and other 5 advisors of his order own selection with respect to all matters within the scope ofthis action for 6 dissolution of rriarriage, and each party has specifically obtained such advice as be or she has 7 determined he or she desired from such attorneys, accountants, and other advisors. Ether party's 8 failare to investigate or con$rm any matter pertaining to the parties' assets, liabilities, obligations, 9 income or expenses, the facts upon which this Judgment is based, either party's failure to consult with 10 an attorney, accountant, or other advisor, or either party's failure to follow the advice of any such li attorney, accountant, or other advisor, shau not constitute grounds for setting aside this Judgment. 12 23. REVOCATION OF PEI~TDENTE LITE ORDERS 23.1 13 Except insofar as such orders are set forth in this ]udgment, all Qriar pendente Iite 14 orders, inc~vding the automatic temporary restraining orders applicable to the parties upon the filing 15 and service ofthe Petition far Dissolution of Marriage, are hereby revoked as ofthe Effective Date, lb and shall hereafter be of no further force ar effect. 23.2 ]7 18 This Judgment maybe executed in signed counterparEs, each of which shad be deemed to be an original. A facsimile andlor electronic copy of the signature pages of this Judgment 19 ll( 2a 11/ a~ ~~i as ~~i 23 err 24 111 25 //I 26 111 27 111 zs -asAGE OF DEPP STIPULATED JUDGMENT OF DCSSULUTION OF MAARIAG~ L.A.S.C. CASE NO.BD64105I :~;~ • •ALD BCD jdg.041416•~v5.wpd Heard - MTD Exhibits - 249 shall be deemed an original pursuant to California Rule of Courc, Rule 2.305(d} and California Civi! 2 Code, Section 1633.7, respectively. 3 PETYTIONER AND RESPONDENT SAVE READ THIS 3UDGMENT AND EACH HAS BAD QT'S TERMS EXPLAINED TO HIlI~I OIt HER BY ffiS OR HER COUNSEL. EACH 4 REPRESEN3'S THAT ~3E OR SHE UNDERSTANDS THE TERMS OF 'I'AXS JUDGMENT. THEFOREGOING STA'1`EMENTIS NOTINTENDED TOIN ANY R'AY ~~OPEN THE DQQR" S TO A'WANER OF T'HE ATTORNEY-CLIENT PRIVII,EGE BETWEEN EACH PARTY A►ND HYS 012HER RESPECTIVE ATTORNEY;PROVIDED,THAT T`HE PRNILEGE SAALLBE 6 DEEMED WAIVED TO THE EXTENT OF TAE FACTUAL REPRESENTATIONS CONTAINED IN SUCH STr~iT~MENT. EACHPARTY ACKNOR'LEDGE3THAT A COURT' 7 MAY RULE OTHERWISE AND HOLD THAT NOATTORNEY-CLIENTPRIVILEGE EXISTS BECAUSE OF THE STATEMENTS MADE IN THIS JUDCrMENT. EACH PARTY AGREES THAT HE OR SHE I~ AWARE OF ANA ACCEPTS TY~AT RISK. 9 THE FUREGOII~TG IS AGREED TO BY: 10 11 12 ,20I6 DATED: DAT SIGiVATURE F~LE.OWS AMBER LAURA DEPP,Petitioner ecember 13 2016 ._ _ ~--- JOHN CHRISTOPHER DEP II(AK.A JQHNNY DEPP}, Respondeat 13 APPROVED AS C~NFORM]NG TO TIDE STIPULATIOI~T OF THE PARTT.ES: l4 15 DATED. ,2016 SPECTER L.4W, A PROFESSIONAL LAW CORPORATION 16 DATED: ~1'Nv WASSER,COPE SIGNATURE FOLLOWS By: By. A_ WASSER,ESQ. LA SAMANTHA KLEIN,ESQ. Attorneys for Respondent SAMANTHA F. SPECTOR~ ESQ. Attorney for Petitioner 17 18 ,2016 DATED: GREENBERG,GLUSKER,FIELDS, 20 CLAMAN & MACHTINGER LLP 19 21 22 3 201 LES,P.C. & SIGNATURE FELLOWS By; .. .2016 DATED. GLASER, WEIL,FINK,HO~AR.D, AVCHEN & SHAPIRO,LLP Hy. SIGNATURE ~OI.~OWS PATRI IA GLASER,ESQ. KERRY GARVIS WRIGHT,ESQ. Attorneys for Respondent ONNELL,ESQ. PIE E Attorneys for Petitioner 23 24 IT IS SO ORDERED. 25 26 II DATED: 27 28 HONORABLE CARL H,MOOR NDGE OF THE SUPBRIOR COURT -49- MARRIAGE OF DEPP STIPULATED JUDGMENT OF DISSOLUTION OF MARRIAGE L.A.S.C. CASE 1~i0. BDb41052 ALD _.~ ~"-~ SCD ~a&a9iai6 -~+rs,wF Heard - MTD Exhibits - 250 ~~ shall he decnied an original purs~~nt to California Rirlc of Courr, Rule 2.305(d) and Ccrlrfornia Civil Code, Section Ib33.7, respecrrrely. PETTTTb1~ER AND RESPONDENT HAVE REND THIS JUDGMENT A1~D EACH HA5 HAb ITS TERMS EXPLAINED TO HTiVI OR AER BY 1~IIS OR I~ER COUNSEL. EACH REPRESENTS TEAT HE OR SFTE UI~D~RSTr1ND5 T$E TERMS OF THIS JUDGMENT, THE ROREGOING S'FATEh~LENT IS~OT II~ITENDED TO1N ANY V4'AY"OPEN THE DO OR" TO A V4'AIVER OF TAE ATTORNEY-CL~NT PRN~F,GE BETWEEN[EAC~CPARTY AND F3IS OR HER RESPECTIVE ATTORNEY;PROVIDED,THAT THE PRNILEGE SHALL BE DEE1bIED 1Vr~VE.0 TO THE EXTENT aF THE FACTUAL REPRESENTATIQNS CO~TAIlYED IN SUCH STATENIEI~T. EACFIPARTY ACKriOti~'LEDGES THAT ACOURT MAY RU LL OTH~RWISE ANDI30LD THAT NO ATTORNEY-CLIENTPRF~'ILEGEEXISTS BECAUSE OF THE 5TATEIVIENT5 NIAAE IN THIS JUDGMFI~TT. EACH PARTY AGRER.S TI3AT HE OR SHE LS A~VA~.E OT 4ND ACCEPTS TF3AT RYSK. T~I~ rOREGOING IS AGREED TO BY: 10 DATED: ^,2016 DAT ~~cernber 13 2016 ---•J. 11 12 AI`'Li3ER LAURA DEPP,Pctiltoner }~EiN CHRISTOPHER DEPP {AKA 30HNNY DEPP}, Respondent 13 APPROVED AS CONFORh~G TO THE STIPULATiUN O~ THE PARTIES: I4 15 DATED; ,2016 SPLCTOR LAW,A PROFESSIONAL LA~V CORPORATION 3 ~O1 DATED: y~1''Nv ~i'ASSER, CO PERMAN & V LES, P.C. By. By- {6 17 is !9 20 LAU A. WASS~R,ESQ. SAMANTHA KI.,~TI~1, ESQ. Attorneys far Respondent SAMANTHA F. SPCCTpR,ESQ. Attorney for Petitioner DATED: ,2~ib GREEI~lBERG, GLUSKER,FIELDS, CLANiAN & MACHTINGER LLP DATED: ~-~~•L. r "'.-r 201t~ ~GLASBR, IL, F ~ 'K;~OWARD, AVCHEN.~c SHAFI ~,~~F"'~ `~ i 21 22 ,-,. ~Yt ey: ;4~ER,.$SQ. PAT~ti A KERR~~G~ WRIGHT,ESQ. Attorneys or Respondent P]ERCL O'DONNEI.I., ESQ. Attorneys for Petitioner 23 24 IT IS 30 ORDERED. 25 26 II DATED: 27 28 HO~I4RABLE ARL H.1Vi00R NDGE OF THE SUPERIOR CQURT -491~EARRIACE OF DEPP STiPULA'f'ED JUDG'~TE,~"i' OF DJ550LUTiOti OF hLLRRIAGE L,A.S.C. CASE ~'O. BD6S1052 ALD JCTI~ jdz091<36 - A ~S,.p Heard - MTD Exhibits - 251 ~i i shall E~: d~cmccl un uriginal p►sno:S01 IP Cf1ll/1~1771d f!!Ic UI C~O[r1'L Rule'•.?0~(d1 cud Cer!!!iu•~,iu C'iril L'nrle•. Sc4tiop 1633,i_ re~prcti'.'eh•, 3 PCTl7'IO\ER AtD R~SPO.~'pE\T 11: 1\'L 12dC;tU 7'Hlti JL'DC:11E\T A.~'U E:r~CH HrtS R:tll 17'S T~12~I5 C\P1al`CD TO 1~11~I Oft l~1l:R Bl" H1S OK HER COU,~SEL. G~tCH itCPRES~N'fS THAT HE UR 5HE l.•VD~R5T:~tiDS i'flk: "FI:R\35 (ll~ 'fIEIS .11inG~iL!~T. 'FIE L'QRFCOI\C S7':tl'i~:~f i~:\7'15 y O'i'1~T~~DED"1'O 1~ a?~i~'~1':~1~••QPE1'TEiE DOOR" Z'C1.~ tti'AIIrEROTl'11Erb'I"roR~EY-C:i.IF.1'1'PRl1'ILF.G~BET~I'EC\ GICN PAIiTI'A~iD N1S OR HLR lt~SPEC'i'ri'E _17T0[2V U.l'; PR~I'!UL•'U,7'11.x1' TNL•' PRI\`ILEGE SHALI.IZI: h DEC~t~:D ~1'AI~'FD 1'O 7'!lE f\~'F~lT Ol~ 'flll: fACTC~AI. R~PRESENTATIO\S C.t)1T:11\'ED 1\ SI~CFI $TA7'~~1I[:~1'. I:~kCll R~~t'1'1' AGt~\U«'LIiUG~S 7'H,+~'1' A CUG fi'[' 71 1I:~1'ROLE OTti~R~1~lSF A`D HULD TH:iT V~ ATl'0~1E~'-Ci.tT~l'Pit1V11.F,G~ ~XIS'l'S l3EC:1US~ Ul'THE ST~TEAII•:\TS llrtinl: f~ T1ilS JUDG1•iT~'F'. EACH YAR'll~ :1GRrL•'S ti TH:~"~' FIH: Clit S13F. 1S ~13Y:11tL• nr:~\I) AC'CEY'['S "1'll:t7 RfSi~. ~riic :tnurrrzr~•r ~c ir•ulrr~ •rri a~•. 9 l {1 Dr1T£D:! __~'.1tlG d:11'F:1): ~~201(1 ]l Ail t? A. W iti<~ner r ~? JUt~lti t'liRlti`T(1P11L12 DCPI' 11 fr\K:1 ~c~ritv~' ~~r:i~~~. its-r~,rni,-n~ ;lni'R01'I:D :t5 COti'}UI21~1tiC: 'I'U 7'lll: S'!'1PUL~'1'lU\ 0[~ 7'H!:['.AFLT1rS: !~ ~; SPL'C?0[t La11'.,~Plt~~l~fSSIU\:t[. L:~~l' co~~oR~rici~ ~ c~ n.•: t7 ~1'~SSEft. C'OQf'1:R~1AN lc hI.+1VDLHS. f~.C'. r~~ Lr'l[`'et:1 .~.~l`~SSER. ESQ. ti:~t•1:\E~il-1.~ KLF:I\. 1:5U_ :\~~nrut~x ii•~r Rcsr~n~rm S:1~1:13~~i~r~:1 I~. SPI:CTUEZ. LSQ :1t~ariie~• liar P~iitiLm~r IS ~ ~~ 3U - .?Ol6 ll:~~k'F:D: u,a t ~u: ecem er 9 _.3U I c~ CiRl:1::' T:RC,r. GLl'S'!i. FI1:L1)5, CL:~: A\' ~ 1.1.10 1 ~'t;l:lt LLP c~~s~it:~~-i:~.. Fi~~:. ~~u~i~,~ttt~. S`. B~•: =l1'L'HF~ ce S~d:~P1RU. I.I,P 21 f'~1TR]C'1~1~ LAS~R_tSQ~:1:RRl' Ci~1R1~'i5 ~~'Tt1GH7'.(:SQ. r\t~c~rne.~. Iar Ftc~pundam C'li t 'Ui~\VI~I.L_ F:SQ. P Auurnc~~. liar ~'eiiti~s~t~•r ~3 ~~ 17' 15 50 URtl~:ltED. ~S ~~, ~,~-~r-.~~. ,q JUUGE t)1~ Tlli: 51~1'LRIOR C(}URT ' ti i -~49~~:►Knrit~e ur ur.rr 5E'iPL~LATEE~JI'UG}I~\TUF 1?Iti5U1.1'TIU\pI~ t~.~I~RI:~[;F. 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