This thread will pertain to Mr. Depp's opposition to Ms. Heard's Motion to Compel Responses to 10th Requests for Production of Documents: fairfaxcounty.gov/circuit/sites/…
The hearing before Judge Azcarate on this was July 2, 2021; we haven't heard how she ruled.
🤣Once again, Mr. Chew..."Ms. Heard's conduct in filing the present Motion is both typical & troubling. Most of the RFPs at issue are patently overbroad, harassing & improper." He then notes Ms. Bredehoft's refusal to Meet & Confer noting Ms. Heard should be sanctioned.
Pages 2-6 are Mr. Depp's objections to each RFP Ms. Heard is attempting to compel.
RFP 5: "Ms. Heard was not a party to the 'Other Litigation,' was not deposed in the 'Other Litigation,' & was not mentioned in Mr. Depp's Complaints."
RFP 6: "Ms. Heard has no valid basis to demand every document relied upon to generate financial records of Mr. Depp's companies over the past 10 years...Furthermore, [it] is not directed to the correct party...."
🤣Ms. Bredehoft again being schooled in Law School 101!
RFP 7 & 9: "...seek premature & improper expert discovery."
RFP 10, 24 & 25: "These...are vague & open-ended to the point of meaninglessness...It's improper. Ms. Heard must serve more targeted requests for reasonably identifiable categories of documents."
🤣I love when Mr. Chew schools Ms. Bredehoft!
RFP 11: "...rather bizarrely seeks 'all publications' evidencing or 'reflecting negatively' Mr. Depp's reputation....publications are just that, publicly available....Mr. Depp has no obligation...."
🤣Ms. Heard can collect millions of pages of Tweets, b/ can't search for these?
RFP 12, 14, 15, 17, 21: Mr. Chew notes Mr. Depp has produced documents in response; has produced recordings in response. "These RFPs should never have been the subject of a motion & should be denied." He also mentions Ms. Bredehoft refusing to meet & confer.
RFP 13, 16, 18: Ms. Heard is looking for documents 'overbroad' & 'vague' regarding Mr. Depp's loss of any role or commercial opportunity w/out specifying who the persons communicating even are. This is the objection.
RFP 19, 20 (Payments to 3rd parties): "RFP 19, Ms. Heard already has this information...."RFP 20 seeks information regarding any payments...to a laundry list of 49 individuals w/in the past 5 years...payments made to lawyers...Mr. Depp would be willing [to Meet & Confer].
RFP 22 & 23: "...are truly astounding. 22 demands all agreements, payments, communications w/ anyone [providing services to Mr. Depp]....23 demands all communications...relating to [SM] or any ISP relating to all services & charges...." Mr. Chew notes it is irrelevant to the case
Pages 8-20 are emails. I'm going to address the emails, post then w/ a summation, b/ without the personal information of the sender or recipients.
From Mr. Moniz to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. He's responding to her continued unsubstantiated accusations & schooling her in VA law pertaining to Meet & Confer, which she's been unwilling to reasonable do per the law.
From Ms. Bredehoft to Mr. Moniz, CC'd to the legal counsel of Mr. Depp & Ms. Heard. She disagrees @ not complying w/ VA law on Meet & Confer; she addresses discovery issues; disagrees her client is Contempt for not producing via Court Order. Notice she copy/pastes; unprofessional
From Mr. Moniz to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. He again calls her out on her repeated accusations & insinuations in emails; explains Mr. Depp's opposition to Ms. Heard's RFPs, Tracey Jacobs; addresses anticipated Motions by Mr. Depp.
Cont...From Mr. Moniz to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. He again calls her out on her repeated accusations & insinuations in emails; explains Mr. Depp's opposition to Ms. Heard's RFPs, Tracey Jacobs; addresses anticipated Motions by Mr. Depp.
From Ms. Bredehoft to Mr. Moniz, CC'd to the legal counsel of Mr. Depp & Ms. Heard. She continues to make unsubstantiated accusations; addresses Mr. Depp's opposition to Ms. Heard's RFPs; cites an email she sent to Mr. Chew on this matter.
🙄She accuses, is combative, demands.
From Mr. Moniz to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. He addresses her accusation Meet & Confer requests are 'harassment;' says he will sent a more detailed summary of Mr. Depp's objections; asks for a Meet & Confer again.
From Ms. Bredehoft to Mr. Chew, CC'd to the legal counsel of Mr. Depp & Ms. Heard. She starts off insulting him; makes unsubstantiated accusations @ Mr. Moniz's emails; whines @ the Meet & Confer disagreement; suggest he looks at his records again.
From Mr. Chew to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. It's straight to the point, it's her refusing to Meet & Confer; Ms. Heard is in Contempt of Court, by not complying w/ Judge Azcarate's Court Order; @ her misleading the court in filings.
From Mr. Moniz to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. It simply is once again a polite request to Meet & Confer.
Pages 21-24 are an excerpt from a hearing before Judge White, November 20, 2020. I'm not going into too much detail b/c we've seen this previously, b/ I can't resist reposting Judge White's admonishment to Ms. Bredehoft.🤣
Pages 25-77 is the Complaint in Mr. Depp's lawsuit against Rob & Joel Mandel TMG.
I dealt with this extensively in this thread, so I'm just going to link that thread here. threadreaderapp.com/thread/1411362…
Pages 78-103 is the Complaint in Mr. Depp's lawsuit against Jacob Bloom & Bloom Hergott Diemer Rosenthal LaViolette Feldman Schenkman & Goodman LLP.
I dealt with this extensively in this thread, so I'm just going to link that thread here.
threadreaderapp.com/thread/1411362…
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