Thread by @roaringrapids22

This thread will be the "key points" of Ms. Heard/Ms. Bredehoft's 200 page Memorandum in Support of her Motion to Compel Mr. Depp, in my opinion. Please feel free to discuss, add anything you believe I've missed.

Full Memorandum: fairfaxcounty.gov/circuit/sites/…

As evidenced by Ms. Heard's Motion to Compel & the attached emails it is apparent Ms. Bredehoft send attorney's to meet & confer discussions that have no authority & who & it is all or nothing...no compromising. This is not something that will evade Judge Azcarate imo.

The $50M in damages Mr. Depp is seeking in his lawsuit, are based on Disney firing him just days after the 12/18/18 defamatory Washington Post Op-Ed was published. He based this amount on his salary for POTC 5, which was $50,500,000.

Mr. Depp mentions in his claims, as a result of Ms. Heard's false allegations & the Washington Post Op-Ed, the negative publicity generated he's lost career opportunities thereby impacting his income. Ms. Heard is seeking publications reflecting this in her Motion to Compel.

Ms. Heard is also seeking communications & documents "reflecting Mr. Depp losing any film or commercial opportunities (studios, companies, producers, directors)" related to the divorce action, the DVRO, the publication of the UK Sun piece, the WAPO Op-Ed, UK Judgement.

The difference b/n the damages Mr. Depp is claiming, is he is citing his firing by Disney just says after Ms. Heard published her defamatory WAPO Op-Ed; she's claiming damages broadly. If she's proven to have lied, defamed him, abused him, her damages are irrelevant; vice versa.

What Ms. Heard is attempting is to claim Mr. Depp's alcohol/drug use, his being late to set, & overall behavior is the cause of his loss of professional opportunities/his firing by Disney & not as a result of her WAPO Op-Ed to reduce her culpability, blame him.

Ms. Heard will fail in her attempt to shift the professional loss of opportunities on Mr. Depp b/c it is well established by Mr. Depp himself he's self-medicate throughout his life, he's been professional, completed multiple films a year & one cannot do that drunk/strung out.

Ms. Heard's arguments that simply b/c she was compelled to produce items relating to her broad claims she lost professional opportunities, that he should when his claim is specific to being fired by Disney may have some merit, b/ their damages are markedly different.

Mr. Depp hired Edward L. White as his business manager, forensic accountant, financial adviser, & to manage his irrevocable trust. Mr. Depp is claiming some of the items are privileged. Ms. Heard is contesting this claim. I'll be curious to read Mr. Chew's response on this.

If Mr. White in his assessment of Mr. Depp's damages, the $50M, based on his POTC 5 salary are in relation to legal documents &/or communications w/ lawyers then it is possible some is privileged; some may be work protected. We will have to wait & see.

Ms. Heard is seeking access to documents, transcripts, communications from Mr. Depp's previous resolved lawsuits against Rob & Joel Mandel (TMG) & Jacob Bloom, Alan Hergott (Bloom Hergott Diemer Rosenthal LaViolette Feldman Schenkman & Goodman LLP).

Ms. Heard is seeking access to documents, transcripts, communications from Mr. Depp's previously resolved lawsuits in an attempt to connect his loss of professional/commercial opportunities to his own alcohol/drug use, lateness & behavior, to blame him.

Ms. Heard is also attempting to call Mr. Depp's mental health into question, seeking information via these previous lawsuits pertaining to his mental health issues. This is something touched upon briefly during the UK trial & in UK WSs; she seeking to blame him for his losses.

Ms. Heard is attempting to discover via these previous lawsuits to uncover any property damage he paid for or allegedly caused, not just during their relationship, but also the NYC incident in the 90s; anyone he may have abused; prenuptial agreements. It's a fishing expedition.

Ms. Heard ironically opposed Mr. Depp's request to have the depositions of Ms. Heard/Ms. Pennington used via the VA trial; she's seeking transcripts/videos of depositions from Mr. Depp & various witnesses in the TMG/Bloom cases, as she cannot subpoena some of them.

What's of interest is Ms. Bredehoft's claim evidence was revealed in terms of the deposition transcripts & exhibits from the Mandel (TMG) case which allegedly reveal evidence supporting Ms. Heard's defense. Remember, however, Ms. Jacobs was fired by Mr. Depp Oct. 2016.

I will address excerpts from Ms. Jacobs' deposition further into this thread simply so people can follow along w/ the Memorandum. Mr. Depp won substantial settlements from both Bloom/TMG; the DOJ, IRS & SEC launched federal investigations into TMG: wsj.com/articles/johnn…

Jacob Bloom/Alan Hergott retired & the law firm was renamed. Mr. Depp didn't take either to trial but he did win in terms of a sealed substantial settlement: ftllp.com/johnny-depps-e… Tracey Jacobs was a witness in discovery. Again she was fired & there's much we don't know.

I wouldn't at this juncture be too concerned. This is all strategically placed in the Motion to Compel to smear Mr. Depp, as Ms. Heard's legal counsel has done many times before. Ms. Jacobs, as well as subpoenas to Mr. Depp's sister Christi Dembrowski & Elisa's Attic in VA...

seem to coincide with these 2 lawsuits. IDK how it all connects, this is something I trust will be dealt with by Mr. Depp's legal team & via evidence. Mr. Chew will address this to some degree in his response as well. So I wouldn't be concerned by excerpts/cherry-picked exhibits.

Ms. Heard is attempting to suggest via these claims, as she did in the UK, that simply b/c some of Mr. Depp's witnesses were under his employ past or present, their testimony was not credible; she seems to be taking the same route in the US. She also seeks payment ...

records to Dr. Kipper during their relationship & since 2016. Dr. Kipper is concierge physician, meaning his paid via a retainer for her services annually, to be there 24/7 for his clients; he wasn't just Mr. Depp's physician during the relationship, but hers as medical notes ...

indicate as well. I'm uncertain the concierge agreement, but it is legal & usually above & beyond the retainer you are billed additional costs. We all pay medical professionals, but it doesn't make their testimony less credible.

🤣I laugh at this next section. Mr. Depp's been candid throughout his career about not having social media accounts. His first foray on social media was in March 2020 & he stated it was b/c of the global pandemic that he decided to join Instagram/Facebook as a means to ...

connect with his fans & supporters. There's no evidence to support Mr. Depp communicating beyond his posts w/ his supporters. In his November 2020 deposition he mentions his ineptness in terms of social media & notes he's had help with his SM accounts. This part of ...

Ms. Heard's counterclaim was dismissed by Judge White. Most of her counterclaim was dismissed by Judge White. Her subpoena of Twitter went nowhere, where one of the two final SM posts she provides to the court she found issues w/ was a Depp supporter calling her "Ms. Nobody." ...

Despite her counterclaim on this being dismissed, she's seeking in this Motion to Compel all "agreements, payments, & communications w/ anyone providing any type of computer or social media services to Mr. Depp, related to services & charges from 1/1/16 to the present." ...

Again, Ms. Heard's allegations of "social media conduct, defamation, malice & punitive damages" are ridiculous imo. This part of her counterclaim was dismissed & all that remains are statements by Mr. Waldman, which are only defamation if she can prove her case.

Meanwhile back in reality, Ms. Heard is following her own supporters; supporters who allege she speaks to them via DM & some have claimed to have been paid by her, which may be true. She's defamed Mr. Depp via SM with malice, cyberbullied, et cetera, not Mr. Depp. TBC.

This section is confusing in a sense. On the one hand, the audio released in early 2020 to the DM, noted several dozen audio recordings. When asked @ the release Mr. Waldman mentioned Mr. Depp just received them via discovery & they hadn't listened to them all yet. It's clear ...

via the audio recordings Mr. Depp mentions Ms. Heard has the Toronto recording for example, encourages her to send it to him & the conversation suggests she was the one recording these discussion & in possession of them; now Ms. Bredehoft is suggesting Mr. Depp is ...

possession of these 50+ recordings & refuses to turn them over via discovery. It's possible he is in possession of some of these, but they would be duplicates of her original recordings. There's no evidence if we trust Waldman's 2020 statement he submitted them to the DM, ...

although it is possible Ms. Heard sent some to Mr. Depp per his request in these audio recordings, but if she recorded them, then why doesn't she have them. Is it the infamous computer guy, who may or may not have scrubbed Ms. Heard's computers that deleted them & now she ...

is claiming she no longer has the original copy? It's just intriguing imo. Ms. Bredehoft mentions Ms. Heard's 2016 deposition & Mr. Depp using audio recordings in her divorce deposition claims she has no copy of it, despite it is revealed in audio she recorded them, would ...

likely have to send it to him. Ms. Heard didn't give a deposition in the UK, so Ms. Bredehoft must mean via her WSs, but clearly if it is presented as evidence in court, since the defense had the burden of proof, it would seem she would have a copy of these.

Ms. Bredehoft/Ms. Heard has been whining about his 60+ potential witnesses including expert witness for some time. As Mr. Chew has said repeatedly in court submissions he's not decided on his final witness list, yet you want discovery? Perhaps this is merited, b/ may be ...

just positioning, a PR smear via a court submission, motion to compel. Given Ms. Heard has no credible evidence, no witnesses of merit & I would imagine it may be expensive, b/ near impossible to find professional experts willing to put themselves, their credibility, on the ...

line for people like Ms. Heard, simply for money. Ms. Heard seems terrified by his expert witnesses.

The last part of her Motion to Compel amuses me.😂

🤣Ms. Heard's $100M counterclaim is defunct except for a few statements by Mr. Waldman, and she keeps whining.

I will continue with the exhibits tomorrow, using evidence available to all in his various cases, via links ...

to negate them, via my research, anyone can access via links or the SSs of court submissions. It's nearly 1 AM for me so I will continue in the morning. TBC.

Attachment 1: fairfaxcounty.gov/circuit/sites/…
This is simply a copy of Mr. Depp's responses & objections to Ms. Heard's corrected 10th Request for Production & pages 9-45. If you have any questions about this document, legal terms, etc. please don't hesitate to ask.

Attachment 2 (45-52): fairfaxcounty.gov/circuit/sites/…
This is simply a copy of Mr. Depp's memorandum in support of his Motion to Compel Ms. Heard (4/21). Judge Azcarate's Court Order: fairfaxcounty.gov/circuit/sites/…
If you have any ?s @ this document/legal terms/etc. please ask.

Correction: This is the correct 5/12/21 Court Order by Judge Azcarate ordering Ms. Heard to compel: fairfaxcounty.gov/circuit/sites/…

Attachment 3 (53-61): fairfaxcounty.gov/circuit/sites/…
This is a hearing transcript from 4/30/21, which led to Judge Azcarate ordering Ms. Heard to produce evidence on 5/12/21: fairfaxcounty.gov/circuit/sites/…
Reminder, emails from, Mr. Chew/Mr. Moniz indicate Ms. Heard is in Contempt.

About Mr. Depp's UK GQ article, published November 2018 in both print & online...Mr. Depp & Ms. Heard have a confidentiality agreement b/n one another as part of their 2016 divorce settlement, which was finalized in 2017. Ms. Heard contended in 2018 Mr. Depp violated the ...

confidentiality agreement in this interview. Ms. Heard sought legal recourse through arbitration, but was denied in CA. Ms. Heard then tried to list this same article in her now mostly defunct counterclaim, ruled on by Judge White.

At the 4/30/21 hearing, Attachment 3, included in Ms. Heard's Motion to Compel Mr. Depp. Mr. Chew pointed out the absurdity of her objections & pointed out Judge White ruled that to get an accurate snap shot of each parties careers/potential damages it needed to be over 10 years.

At the 4/30/21 hearing, Attachment 3, Mr. Chew in answering one of Judge Azcarate's questions mentions the absurdity of Ms. Heard's $100M counterclaim, it being twice the amount of Mr. Depp's claims of damages, despite the clear career differences.

At the 4/30/21 hearing, Attachment 3, Mr. Chew also notes Ms. Heard lied/perjured herself in the UK & her continued attempts to thwart discovery in the VA defamation case.

Attachment 4 (62-114): fairfaxcounty.gov/circuit/sites/…
Despite these financial documents being de-designated as confidential by Judge White's Order, I'm going to refrain from posting them out of respect for Mr. Depp: fairfaxcounty.gov/circuit/sites/…

Included in Attachment 4 (62-114) are Infinitum Nihil's income statements from 2009-2020; LRD Productions Inc. income statements from 2009-2020; Scaramanga Bros. Inc. income statements from 2009-2020; Scaramanga Bros. Inc., LRD Productions Inc., & Infinitum Nihil Projects ...

Gross Receipts Summary from 2009-2020. You can look at these yourself. If you have questions about any of Attachment 4, please don't hesitate to ask. Again I won't post these out of respect for Mr. Depp, but am happy to discuss them.

Attachment 5 (115-157): fairfaxcounty.gov/circuit/sites/…
This is a deposition, Tracey Jacobs gave 5/30/2018 in Mr. Depp's lawsuit against Rob & Joel Mandel, The Management Company (TMG). Ms. Jacobs was Mr. Depp's agent from 1983/1984 until he fired her in October 2016.

Please note, Attachment 5 is an excerpt of Ms. Jacobs' 5/30/2018 deposition in Mr. Depp's lawsuit against Rob & Joel Mandel, The Management Company (TMG). Again Mr. Depp fired her, so I wouldn't give too much credence at this juncture to this cherry-picked excerpt.

Also, while Ms. Jacobs' mentions being aware of Mr. Depp's financial issues since @ 2005, it is important to remember Mr. Depp won in the settlement, being granted a sealed amount & Mr. Depp's claims must have had some merit as following this The Internal Revenue Service ...

& Justice Department began jointly looking into possible fraud & money laundering by the Management Group, brothers Joel & Rob Mandel. The Securities & Exchange Commission separately began investigating how the Management Group handled Mr. Depp’s funds. Mr. Depp’s lawyers also...

met with government officials. It's unclear what resulted from these investigations, however, Mr. Depp's claims must have had merit if these investigations were opened in the first place.
archive.ph/seVTb#selectio…

Ms. Heard makes claims Mr. Depp was drinking/drunk early on in their relationship, yet through June 2013, Mr. Depp who has been candidly honest @ his issues with alcohol, spoke of his sobriety (18 months). So this refutes her claims to this date.
archive.ph/glwqu

Ms. Jacobs' notes studios, directors & producers were concerned by his lateness during the years he dated/was married to Ms. Heard. In the UK it was revealed that Ms. Heard's anger, violence, & behavior was often the reason for his lateness; this will be gone into in the US imo.

Ms. Jacobs' in this cherry-picked excerpt claims she believes Mr. Depp lied to her about drugs; makes assertions his alcohol/drug use negatively caused him to be angry, hostile & unwilling to communicate; impacted his performances, his professionalism....

No woman, from Mr. Depp's first wife to the present, outside Ms. Heard has ever claimed he was abusive; Paul Barresi, the Private Investigator Ms. Heard hired interviewed over 100 people & couldn't find one to say a single negative thing about Mr. Depp. This is important.

It's also important to note, outside these claims by Ms. Jacob, which may or may not have merit (he fired Ms. Jacobs' Oct. 2016), no one that's worked with Mr. Depp has ever said he was anything less than professional. Mr. Depp's been honest in court/ in interviews @ his ...

lateness. Over 35+ years he's been candidly honest about his self-medication w/ drugs & alcohol. If anyone is concerned about this I can post some of these comments to illustrate why it is unlikely he lied to Ms. Jacobs as she claims. This an excerpt, deliberately cherry-picked.

Mr. Depp's first wife Lori-Anne Allison, her sister Suzanne Witkin, Sherilynn Fenn, Winona Ryder, & Vanessa Paradis have all come forward to say Mr. Depp is not abusive; Mr. Depp's colleagues & friends have come forward to say he isn't abusive. This is important.

While Kate Moss to the best of our knowledge hasn't given a Declaration in VA, it's important she's never claimed Mr. Depp was abusive & every interview she's given has been nothing but endearing of her time with Mr. Depp. It's unclear if she will prior to trial say more.

Mr. Depp dated & was engaged to Jennifer Grey briefly. Ms. Grey has never said anything negative or made any claims of abuse against Mr. Depp. Ms. Glen who Mr. mentioned in his interrogatories has made no negative comments or claims of abuse either. This too is important.

Ms. Jacobs' deposition excerpt is from May 2018, prior to Ms. Heard's Washington Post Op-Ed & just one month after Dan Wootton's defamatory piece in the UK Sun. It's also prior to Mr. Depp's lawsuits/evidence being made public via the UK/US lawsuits. This is important also.

In the May 2018, Attachment 5, excerpt of her deposition Ms. Jacobs says she believed Mr. Depp when he told her he hadn't "hit" Ms. Heard. When asked why now she believes he "hit" Ms. Heard she vaguely says it was his violent outbursts, behavior, but cites no credible evidence.

Ms. Jacobs says Mr. Depp over the span of representing from 1983/1984 until he fired her October 2016, was angry at times, raised his voice at times with her; he's human this is no more evidence than his anger in the Cabinet video; shocker he's human he has moments of anger.

Ms. Jacobs' says in this 2018 deposition, he was never physically abusive towards Ms. Jacobs. This is important b/c the defamation lawsuit is about Ms. Heard's false allegation of abuse. Anger, moments of, are all human. Mr. Depp's admitted he's angry at times, b/ not abusive.

Ms. Jacobs' says Mr. Depp was angry indiscriminately in 2016. He endured 4 years of physical abuse, emotional/psychological abuse at the hands of his wife, while his mother was terminally ill, died 5/20/16 & was falsely accused of abuse, by his abuser; anger is understandable.

Ms. Jacobs' mentions an awards show in which Mr. Depp appeared inebriated in 2015, via her testimony she says she spoken to Robin Baum, Mr. Depp's publicist & was informed he smoked pot, took a Xanax prior....recall when Ms. Heard gave him Xanax in audio/staged photos?

Let's just remove the possibility for one moment that Ms. Heard may have insisted he take a Xanax prior to the 2015 event in which he appeared inebriated...Mr. Depp's long spoken of his anxiety issues, his taking a drink, smoking pot prior to an event to calm his nerves.

Regardless of the scenario/cause of Mr. Depp appearing inebriated b/c of smoking pot/Xanax at this 2015 event, it isn't proof of anything other than the medication made him appear inebriated. This happens to normal people all the time w/ sleep medication/Xanax etc.

Ms. Jacobs' is also shown emails from February 26, 2015, where Mr. Depp was six hours late to set while filming POTC5, as noted by President of Disney Sean Bailey. This is just days prior to Ms. Heard severing his finger March 8, 2015. We know via the UK trial, Ms. Heard's ...

anger, physical violence, emotional/psychological abuse, where he says at one point or another he escaped to every bathroom in the rental home, her bizarre behavior as noted by Security Guard Rick Wood was the cause of his lateness, not his unprofessionalism; same as in the ...

2013 incident where he was late to meet with Keith Richards on the documentary they were working on. While, unknown to Mr. Bailey at the time, most likely, it was these extenuating circumstances created by Ms. Heard, not unprofessionalism that is the cause.9news.com.au/national/johnn…

Ms. Jacobs then says Disney had to shut down production on POTC 5 b/c Mr. Depp's finger was severed, costing the millions & millions of dollars. Remember this May 2018 deposition is prior to the public evidence in his UK/US lawsuits, proving Ms. Heard severed his ...

finger; all she knows is what Mr. Depp told Disney to protect his wife, that he severed it. It's common for abuse victims to protect their abusers. This is again, Ms. Bredehoft cherry-picking talking points simply to attempt to support her clients refutable claims.

Ms. Jacobs' says Mr. Depp was late at times on 'Black Mass, as well. Notice this lateness is on projects during his relationship/marriage to Ms. Heard/is consistent w/ his testimony/evidence that he was often late b/c of her anger/abuse; also his finger was severed 1 month prior.

Mr. Depp's been candidly honest in interviews over 35+ years about his flaws, his self-medicating at time w/ alcohol & drugs, he was honest @ it in his litigation w/ TMG, Bloom, & in the UK. If you need examples of his honesty I can post them.

Ms. Jacobs' is asked if Mr. Depp ever made "an false statements or untruths to any studios;" her response is she doesn't know. We know via Rick Wood, Mr. Depp, Mr. Judge, Mr. Bette that he did lie to Disney & hospital personnel to protect Ms. Heard when his finger was severed....

It's common for abuse victims to lie to protect their abusers; to lie to avoid further abuse. It's no different when the victim is a male. We know via audio & evidence, the velocity of the wound to his finger, he did not sever it, Ms. Heard did.

Ms. Jacobs is asked if Mr. Depp in "his dealing w/ the press...whether he made false or untrue statements;" her reply is she imagine so, most actors do. Again, Mr. Depp's been candidly honest over 35+ years. We know he lied to protect his wife, made jokes to deflect some ...

questions, but there is no evidence beyond this that he's ever been less than candid or that he intentionally lied to the media. I suppose over the years its possible, but there is no evidence that he's done so beyond these things I mentioned.

We don't know, given this isn't public, we don't have all the information, clearly the investigation by LA Family services didn't result in any charges, Ms. Jacobs was fired by Mr. Depp in 2016, is tied to the TMG/Bloom litigation, both of which Mr. Depp won via settlement, ...

Ms. Paradis has never stated Mr. Depp was an unfit father, & neither of his children have ever made that claim either. This is all important. All we have is Ms. Jacobs' assertion he lied to authorities in that investigation. Ms. Bredehoft cherry-picked this to smear him.

It's important to note Lily-Rose Depp was 15 in 2014, in the mist of his relationship w/ Ms. Heard. Ms. Depp, was living in one of the ECB penthouses next door to Mr. Depp, likely w/ Ms. Paradis knowing she was living w/ a 23 year old male. Who called & reported this to ...

Family Services in LA? Reporting to Family Services can be done anonymously. Was it Ms. Heard, Ms. Henriquez, Mr. Wright or one of her other coconspirators? Was it all for Ms. Heard's malicious hoax scheme? The age of consent in CA is 18, b/ Ms. Depp is also French, where ...

the age of consent is 15, so this wouldn't have been something of issue in Paris, where Ms. Paradis lives; At 15, Ms. Paradis started dating French singer Florent Pagny, who was 26 at the time. My point is this all irrelevant, much ado @ nothing, just one more instance...

of Ms. Bredehoft cherry-picking in an attempt to smear Mr. Depp in the court, in the media who is watching public filings via Fairfax Court's website.

Ms. Jacobs is asked @ the alleged false statements he made to authorities pertaining to this investigation. She takes Mr. Depp smiling when she asks him about the investigation, the fact no charges were filed & her asserting then he couldn't have told the truth as an admission.

Smiling is neither evidence he told or lie. There's no evidence Mr. Depp lied in his statement to authorities during this investigation & no charges were filed. Ms. Jacobs is then asked if he asked any of his employees to lie during this investigation & she says she doesn't know.

Attachment 5 ends with Ms. Jacobs mentioning her version of deals she procured weeks prior to being terminated by Mr. Depp in October 2016, claims there was "no love" b/n Disney & Mr. Depp in 2016; this is her version, we don't know if it is accurate or not, but we do know ...

Disney didn't fire him, he promoted POTC 5 in 2017 & Mr. Depp was ONLY fired days after Ms. Heard's December 2018 Washington Post Op-Ed. So again, there's no evidence to substantiate her version, no evidence of Mr. Depp beings asked for his version.

Attachment 6 (158-162): fairfaxcounty.gov/circuit/sites/…
These are communications b/n Ms. Jacobs & others pertaining to her excerpt deposition in Attachment 5 relating primarily to February 2015, his lateness, an article in The Wrap @ the 2015 inebriated appearance. I've covered this.

Attachment 7 (163-175): fairfaxcounty.gov/circuit/sites/…
I will not post this in SSs, just give a summation out of respect for the privacy & safety of all those exposed by this attachment & b/c of Twitter's TOS. If you have questions, please don't hesitate to ask.

Attachment 7 (163-175): fairfaxcounty.gov/circuit/sites/…
This document contains Mr. Depp's interrogatory response to one of Ms. Heard's RFPs. If you have questions, please don't hesitate to ask.

Attachment 8 (176-183): fairfaxcounty.gov/circuit/sites/…
This is an excerpt of Dr. Kipper's deposition 2/21/21.

We learn that as of this deposition date Dr. Kipper is still Mr. Depp's Concierge physician; Mr. Depp pays a retainer fee monthly for his services.

Dr. Kipper, not shockingly, admits he's been in contact w/ Mr. Depp's legal counsel over the last year; w/ Camille Vasquez specifically @ his deposition, again not uncommon. It seems Ms. Heard intends to suggest that b/c he's paid by Mr. Depp, he would lie for him. Ridiculous imo

Attachment 9 (184-187): fairfaxcounty.gov/circuit/sites/…
This is an excerpt from a hearing before Judge White 7/24/20. Judge White says, Mr. Depp's "outflow, what his expenses are & whether he spends more money than he makes, isn't relevant; limits interrogatory 1 to 2012 to the present.

Judge White says: "Communications to & from Mr. Depp regarding violence against women" he doesn't find discoverable or appropriate for a discovery order; "transactions w/ people he finds are "overly broad;" & finds "transactions where they might be receiving money appropriate."

Attachment 10 (188-197): fairfaxcounty.gov/circuit/sites/…
This is an excerpt from Mr. Depp's deposition 11/12/2020. I'm just going to comment & post on "key" points from this deposition.

Mr. Depp says he doesn't have a SM team; he didn't join SM until the Pandemic (March 2020); ...

he also notes his purpose was to to connect with people isolated due to the Pandemic, to thank people for various things, & that a female friend runs his SM accounts for him (Gina Deuters); he doesn't even know how to log in; he's not tech savvy.

Mr. Depp testifies Mrs. Deuters (Gina) is a friend, she maintains his SM accounts & confirms she offered to do this, has never asked for money & he's not paying her to maintain/run his SM accounts; explains he creates the content & she uploads it for him; the purpose of them.

Attachment 11 (198-200): fairfaxcounty.gov/circuit/sites/…
This is SSs of the Fairfax Bar Association/Fairfax Circuit Court Practice Manual 2018 Edition. Judge Azcarate is listed as 1 of the Editors, as is Judge White. The page referenced is on expert designation/testimony/discovery cutoff

End of thread. Please feel free to discuss anything in the thread or ask any questions you may have. If I cannot answer them or feel a lawyer should respond I'll @ Katherine & Ms. Burkhart.

Sean Bailey, Jerry Bruckheimer from Attachments 5/6 regarding Tracey Jacobs's statements/emails via her 5/18 deposition, this tells a much different tale & shows Disney wasn't in a strained relationship w/ Mr. Depp, as Ms. Bredehoft is hoping to suggest.
sports.yahoo.com/news/jerry-bru…