Thread by @roaringrapids22

Thread covering the "key" points of interest imo/the legal points raised pertaining to Ms. Heard's Motion to Compel & for Relief. I welcome questions & discussion, if I cannot answer them I will @ Katherine & Ms. Burkhart.

Document:
fairfaxcounty.gov/circuit/sites/…

Ms. Heard is compelling the court in VA to order Mr. Depp to produce the 2 video depositions of third party witness Tracey Jacobs claiming she was provided w/ the transcripts too late to review them, b/ that Plaintiff used in her January 2021 deposition/sanctions as well.

I will continue this thread in the morning, covering the "key" points of the Memorandum in support of this Motion to Compel & Request for Sanctions against Ms. Heard. Please feel free to discuss it & ask any questions you may have.

Document: fairfaxcounty.gov/circuit/sites/…

Ms. Heard's thwarted discovery many times; she's filed endless court submissions to clog the courts, some frivolous; her lawyers have misled the court & are currently attempting her third "futile" dismissal attempt; they've used court submissions & media smears intentionally.

Ms. Bredehoft/Ms. Heard contend "discovery is not a game," yet have been playing games since the beginning of this litigation. They haven't sought "truth" or the "fair adjudication" of the issues in this case. They've used "surprises, trickery, bluffing, & legal gymnastics.

It's Ms. Bredehoft/Ms. Heard that have engaged in "abhorred tactics, significantly prejudicing" Mr. Depp in both the UK libel case & the US defamation case, so it is rich they are now accusing Mr. Depp & his legal counsel of engaging in this type of behavior now.

Important: Tracey Jacobs was fired by Mr. Depp 10/16, after forensic accountant Edward White audited Mr. Depp's accounts & she was tied to both the TMG/Bloom cases (we don't know the extent of what they uncovered in relation to Ms. Jacobs' or the specific reason she was fired).

Important: Mr. Depp's always been candidly honest @ his drug & alcohol use, his self-medication at times in his life. Ms. Bredehoft makes general statements, often misleads the court, so the "key" to remember here is like many victims of abuse, he self-medicated.

Ms. Bredehoft misleads the Court in submissions & this submission is aimed at further smearing Mr. Depp while attempting to win this motion. Mr. Depp's taken drugs, consumed alcohol throughout his many relationships & hasn't ever been abusive, nor has any woman accused him.

It's within the realm of abuse that victims often resort to self-medication via drugs/alcohol to escape the severe trauma they are experiencing at the hands of their abuser. Mr. Depp's human, he gets angry like the rest of us. It's possible all this led to moments where he ...

couldn't recall his lines. Imagine trying to prepare for the next day, while your abuser, Ms. Heard, is screaming at you, violently attacking you or you're recovering from multiple surgeries, bouts of MRSA b/c your wife severed your finger. He's human. His tardiness/absence ...

from filming, already via some of the evidence we've seen indicates it is Ms. Heard's abusive behavior that often led to this behavior. Don't fall into the trap of believing everything you read without pausing to hear Mr. Depp's side or look at the evidence.

Ms. Jacobs was fired for reasons we don't yet know, however, Mr. Depp's loyal so she must have done something egregious; it's also curious she was fired after Edward White's audit of Mr. Depp's accounts TMG/Bloom matter that led to lawsuits against them. TMG, Rob & Joel Mandel...

being investigated by the IRS, DOJ, & SEC, the status or outcome unknown. Ms. Jacobs' was involved in both these lawsuits & clearly after 30 years, being fired, disgruntled. Remember anyone can say anything, twist things, so we have to stay calm, wait for evidence.

Ms. Bredehoft/Ms. Heard are alleging Mr. Depp hid information from them intentionally to prejudice Ms. Heard, yet fail to mention it was Ms. Heard who subpoenaed Ms. Jacobs & it was her responsibility to make sure she had all the discovery materials needed to proceed w/ the ...

deposition in January. If she didn't have them, she had the right/opportunity to reschedule the deposition until she had those materials. Often she complains in the deposition transcripts & court submissions w/out conveying all the facts, so Mr. Chew's response will tell us more.

According to Ms. Jacob's excerpted January 2021 deposition enclosed in Court submissions, we know Mr. Chew stated he sent the transcript in question to Ms. Heard's counsel, that he alleges it was sent, that it was a mistake on Ms. Heard's end, not Mr. Depp's.

Again, Ms. Bredehoft/Ms. Heard subpoenaed Ms. Jacobs, set the time/date of the deposition. Mr. Chew says he sent the deposition transcripts from Ms. Jacobs' previous deposition. It's Ms. Bredehoft's responsibility to make sure she has what she needs/to prepare ahead of time.

According to this Motion, Ms. Heard started seeking Tracey Jacobs & Mr. Depp's deposition transcripts from his previous litigation 8/20/20. Mr. Depp refused to supply them, citing it was unrelated to the case at hand. Ms. Heard's Motion to Compel was considered at a hearing ...

by Judge White to be "overly broad." Ms. Bredehoft accuses Mr. Chew of misleading the court when he said, the issues in these cases didn't pertain to this case or to Ms. Heard or allegations of abuse. She says new less broad RFPs were requested of Mr. Depp, b/ he still refused.

It's important to remember Ms. Jacobs was fired. I've gone into this previously in the thread. Ms. Jacobs wasn't present as witness to any of the alleged incidents of violence Ms. Heard claims, so her opinion, belief Mr. Depp could have abused Ms. Heard holds little merit.

Again, it is Ms. Bredehoft/Ms. Heard that subpoenaed Ms. Jacobs, scheduled the deposition & had the responsibility to make sure they obtained the necessary discovery prior to the deposition. They could have chosen to reschedule if they didn't, they didn't do that.

There are other ways to authenticate texts an emails, it is not solely something that Ms. Jacobs would have to authenticate. Ms. Heard is seeking sanctions as well as the video depositions of Ms. Jacobs from previous litigation.

Ms. Jacobs via CA law cannot be deposed again in Mr. Depp's VA lawsuit. This is why Ms. Bredehoft/Ms. Heard is seeking the video depositions. It's clear, however, she possesses the full transcripts & imo is just seeking them for the emotional aspect of smearing Mr. Depp.

The next section (pp.10-14), are Mr. Depp's responses & objections to Ms. Heard's 8th request for production. This is just his objections to providing copies of depositions taken in other litigations, both transcripts & videos & copies of all pleadings in other litigation.

The next section (pp.16-19) is a transcript from the November 2020 hearing before Judge White. I'm just going to post anything of relevance that is important imo from transcript as it will all lead back to things Ms. Bredehoft mentions in her Motion/Memorandum.

Mr. Chew, responding to Ms. Heard's Motion to Compel, notes the requests are "hopelessly broad & unduly burdensome;" notes Ms. Heard is the only woman that's ever accused Mr. Depp of abuse & the previous litigation has nothing to do with the issue in VA.

RE: Mr. Chew says the Bloom case "involved Mr. Depp's former lawyer, who illegally took 5% of his income" from 1999-2017. Judge Green ruled in Mr. Depp's favor & as a result Jacob Bloom & Alan Hergott retired, the law firm was disbanded b/c they had perpetrated this illegal ...

scheme on other people including Sylvester Stallone. The case produced over 1M documents. The case was settled prior to trial in 2018, with Mr. Depp successful.

RE: "The TMG case involved Mr. Depp's former manager prior to Ed White." Mr. Depp was his manager from 1999-2016. "He breached fiduciary duties & misappropriated tens of millions of dollars. This case also produced about 1M documents, "most of which were designated ...

confidential by the defendant (TMG), "which is the same in the Bloom case." While these things were confidential in the TMG/Bloom case, they aren't considered confidential in the VA case.

RE: "The Rocky Brooks case is a comically frivolous case involving an incident more than a year after the divorce." This trial is scheduled for October 2021. This is a case where Mr. Brooks is suing Mr. Depp for $70,000 & all evidence refutes Mr. Brooks claims.

RE: "The bodyguard's case involved an esoteric dispute over whether the two gentlemen employees were either employees or independent contractors."

None of these cases has anything to do with Ms. Heard or the VA defamation lawsuit against her, or her allegations of abuse.

The next section (pp.21-27) are Mr. Depp's responses & objections to Ms. Heard's 10th request for production, where she is seeking "all contracts b/n Mr. Depp, or any agents or representatives thereof, and Eyes on U LLC. from January 1, 2019 to the present; As well as⬇️

The next section (p.29) simply shows the electronic One Drive link w/ password protection sent from Arnold G. Blair to Mr. Depp & Ms. Heard's legal counsel January 28, 2021 at 12:08 PM labeled Depp 0017 (Ms. Jacob's deposition transcript). For privacy I'm not attaching it.

The next section (pp.32-252) is a transcript from Ms. Jacobs' May 30, 2018 deposition. It was originally marked confidential in the TMG case, but isn't in VA. Out of respect for its original designation, I'm only going to post "key" points of relevance to the VA case.

Just for clarification in the TMG matter: Bruce Witkin Sal Jenco, Mr. Depp's friends since Miramar, Florida, his youth were both members of 'The Kids.' Mr. Witkin is also married to Mr. Depp's first ex-wife Lori-Anne Allison & ran the Music arm of Infinitum Nihil at one time....

Sal Jenco was in the band 'P' as well w/ Mr. Depp & was part owner of the 'Viper Room' when it was opened in 1993. Since both were involved in various business ventures w/ Mr. Depp, this is likely why they are listed as cross-defendants at Ms. Jacobs deposition & in the TMG case.

It's interesting to me that Mr. Depp in interviews has mentioned Ms. Jacobs' being his agent from the beginning of his career, 'Nightmare on Elm Street,' having said it was Nicolas Cage that introduced him to her, that she was integral in getting him a meeting with ...

Tim Burton for 'Edward Scissorhands,' but in this deposition she claims to have only met him via contact w/ his mother Betty-Sue after seeing him on '21 Jump Street @ 1996. It's just an interesting discrepancy. She contacted Betty-Sue, not an agent or representative, yet ...

there's never been mention of his mother as his manager, by Mr. Depp or anyone else. Ms. Jacobs claims she was his manager for 30 years. 1996-2016 mathematically is only 20 years. 1984-2016 (Mr. Depp's claims in interviews would be 32 years. The math doesn't equate.

It's common knowledge Mr. Depp formed the production company Infinitum Nihil in 2004, although Ms. Jacobs mentions it in her deposition. Also if she began in 1996, then why is she claiming she helped him transition from television to film, as he'd already done that by 1996.

Ms. Jacobs' contradicts herself. It's impossible she started in 1996 as she claims b/c she mentions in her deposition she introduced Mr. Depp to Mr. Burton with regard to 'Edward Scissorhands,' which is what Mr. Depp's always claimed in interviews.

Ms. Jacobs also notes she knew Tim Burton previously. Ms. Jacobs also notes she met Mr. Depp's sister Christi Dembrowski about 4 years after she began representing Mr. Depp. She notes Mr. Depp introduced his sister to her; told her she was his assistant. This is known.

Ms. Jacobs mentions Mr. Depp from the onset of her representing him was always difficult to get a hold of, she mentions he stood her up 3 times when she initially wanted to meet him, but he says he was introduced to her by Nicolas Cage, so there are glaring discrepancies.

Ms. Jacobs says she realized Ms. Dembrowski was going to be a "conduit" b/n herself & Mr. Depp b/c he wouldn't respond to calls, attempts to contact him, starting about 4 years into representing him. She also notes Stan Coleman & Peter Nichols were his 1st Ent. lawyers.

Again, here claim she began representing Mr. Depp in 1996 doesn't mesh b/c she mentions Mr. Depp retaining the legal services of Mr. Coleman & Mr. Nichols around the time of 'Edward Scissorhands.' She also mentions Mr. Nichols was his primary attorney.

Ms. Jacobs fails to recall who Mr. Depp's first manager was, but recalls the second was Alan Tivoli. She also notes Ms. Dembrowski went from being Mr. Depp's assistant to President of Infinitum Nihil in a short period of time. The math again doesn't matchup....

Ms. Dembrowski is listed as Mr. Depp's assistant as early as 1994, when he filmed 'Dead Man,' so mathematically Mr. Depp's account is more accurate than Ms. Jacobs who had to begin representing him earlier than 1996. She was also his assistant on 'Waiting for the Barbarians.'...

It is true via the official Infinitum Nihil, Ms. Dembrowski is listed as President; ran the company from its inception in 2004, b/ that's hardly soon after Ms. Jacobs claims to have met her, which is mathematically impossible in 1996. She also remained his assistant on projects.

Ms. Jacobs mentions she introduced Mr. Depp to Graham King, a producer "who was being financed by Warner Brothers & in time Mr. Depp was offered via Infinitum Nihil "an overhead deal for 3 years." She then mentions what a genuine president of a company & what ...

Ms. Dembrowski was doing in the position of president of Infinitum Nihil was markedly different; say all she did was the duties of an assistant & she continued to act as Mr. Depp's assistant as well. The latter is verified via her credits as his assistant on IMDB.

Ms. Jacobs testifies Mr. King stayed through his 3 year deal w/ Mr. Depp & Infinitum Nihil & then a deal was struck with Warner Brothers for 3-4 years. Ms. Jacobs notes after the founding on Infinitum Nihil she spoke more frequently w/ Ms. Dembrowski, even several times a day...

but says she knew very little about the inner workings of Infinitum Nihil over the next decade (2004-2014 approximately). Ms. Jacobs mentions talking to Mr. Depp when she could, but more w/ Ms. Dembrowski, as he was hard to reach; she then mentions Ms. Dembrowski was hard to ...

reach as well as time went on. Ms. Jacobs says when Mr. Depp started Infinitum Nihil in 2004, named Ms. Dembrowski president, it was her understanding she would be running "all aspects of his production company, that she would have access & the ability to get information ...

to pretty much everything he was doing." It also became her understanding that she could reach Mr. Depp through Ms. Dembrowski; that she was told by Mr. Depp she was permitted to share otherwise confidential information w/ Ms. Dembrowski. She says Ms. Dembrowski told her as well.

Ms. Jacobs says Ms. Dembrowski told her many times "the buck stopped" w/ her & that she was the only person that could have access to Mr. Depp. This is consistent w/ others testimony as well including the TMG whistleblower Ms. Rayburn. Ms. Jacobs says this is true except for ...

one period of time in September 2015, when Black Mass premiered, when Mr. Depp was angry with his sister Ms. Dembrowski & didn't speak to her for approximately 6-8 months. Ms. Jacobs said she spoke to Mr. Depp daily during this time. It's noted Mr. Tivoli his manager was ...

replaced by Joel Mandel & The Management Group (TMG), the subject of Mr. Depp's lawsuit & the subsequent IRS/DOJ/SEC investigation into money laundering & fraud (the status/outcome of these federal investigations is unknown.) She then mentions when Mr. Depp sought to ...

replace his then, Entertainment attorney Mr. Nichols, three attorneys were interviewed: Jacob Bloom, Alan Wertheimer & Jim Jackoway. Mr. Bloom was chosen to become Mr. Depp's attorney, the subject of the Bloom lawsuit. She also mentions an interim lawyer, Terri Gilliam's ...

lawyer Tom Hunter. Ms. Jacobs mentions Mr. Depp sought to replace Mr. Nichols b/c he no longer liked him; same w/ Hunter & wanted a new Entertainment lawyer. She also mentions she wasn't involved/didn't have input in Mr. Depp's choice to hire Joel Mandel (TMG). She admits to ...

interacting regularly w/ Mr. Bloom, Ms. Dembrowski, b/ only on occasion w/ Joel Mandel (TMG). Ms. Jacobs says she was fired before Jacob Bloom, in October 2016. Prior she says she negotiated all of Mr. Depp's deals w/ Jacob Bloom & Michael Schenkman of the Bloom law firm.

Ms. Jacobs notes Ms. Dembrowski was involved in every step of these negotiations, as well; that Mr. Depp made the final decisions, but often not directly to her, via the "conduit" Ms. Dembrowski was in the relationship. She notes Mr. Depp living in France for several years.

Ms. Jacobs says it was difficult to get a hold of Mr. Depp when he was living in France, so she had to rely on Ms. Dembrowski via "conduit" to communicate w/ him. She says Mr. Depp understood this, b/ there was never any legal authorization for Ms. Dembrowski to do so.

Ms. Jacobs says prior to September 2015, she was never told she wasn't authorized to discuss anything w/ Ms. Dembrowski. She says that Ms. Dembrowski acted as a manager to Mr. Depp in her opinion. She mentions she doesn't believe Mr. Depp ever had a written contract w/

UTA, the talent agency Ms. Jacobs works through, even though they were collecting 10% of his overall earnings, but says there was an oral contract b/n them & Mr. Depp, that he agreed to this amount. Ms. Jacobs also says she believes Ms. Dembrowski was communicating w/ studios.

Ms. Jacobs says Ms. Dembrowski communicated w/ Jerry Bruckheimer about any issues that may have arisen; likely didn't communicate w/ Dick Cook at Disney. According to her, she & Jim Berkus (Chairman UTA) took Mr. Depp set up a meeting w/ the then chairman of Disney Dick Cook....

Ms. Jacobs led to Mr. Depp's relationship w/ Disney & 'Pirates of the Caribbean: The Curse of the Black Pearl.' Ms. Jacobs says b/n 2004-2016 she had limited interactions w/ Joel Mandel (TMG) pertaining to foreign film shoots, how it might impact tax indemnification & ...

certain tax ramifications; keeping Mr. Mandel appraised of Mr. Depp's salary, where films were shooting, as this impacted his financial planning on behalf of him. It's interested she's asked, answers she's not aware of any time when Mr. Mandel (TMG) was acting as his attorney.

Ms. Jacobs confirms she never spoke w/ Rob Mandel, is unaware if he via TMG provided any services to Mr. Depp. Again, she's asked if at anytime from 2004-2015, if she is aware whether or not Rob or Joel Mandel acted as his lawyers & she responds "No," to her knowledge they ...

were his business managers. Ms. Jacobs also says she's never shared any other clients to whom Mr. Mandel was also the business manager. She says it is typical for business managers to look at real estate contracts, but not film contracts & was never involved in film contracts.

Ms. Jacobs testifies she & Mr. Bloom spoke more often to Ms. Dembrowski when negotiating deals, then they did w/ Mr. Depp, but Mr. Depp would weigh in on the final deal. She also says she wasn't involved in anything related to how Mr. Depp spent his money, nor was she ...

aware of how Mr. Depp spent his money. B/n 2004-2016, Ms. Jacobs says sometimes she spoke to Mr. Depp more often than others, sometimes not for long periods of time, but did reiterate she spoke regularly w/ Ms. Dembrowski. She also says she is unaware of any "activities ...

that Joel Mandel or [TMG] did for Mr. Depp" that was atypical of something business managers would engage in. Ms. Jacobs says she is aware of periods of time Mr. Depp wasn't working in 2015 (March 2015, his finger was severed by Ms. Heard). She says she became aware of ...

Mr. Depp's financial issues @ 2005 b/c she was always under pressure to find him films that would pay the most amount of money, by Mr. Depp, Ms. Dembrowski & indirectly from Joel Mandel; says she was concerned this would impact his artistic choices. She also mentions ...

Joel Mandel occasionally told her that there were financial matters that had to be dealt with, asking her what films were in the "pipeline." She also says Mr. Depp complained @ Joel Mandel wanting to sell his yacht; that he was angry. She says Mr. Depp was aware of his ...

problems in her opinion @ 2005. While she testifies he never blamed this on Mr. Bloom, Mr. Mandel or herself b/n 2005-2015, it's important to remember it is Edward White who found the illegal discrepancies when he was hired in early 2016; this is consistent w/ Mr. Depp's claims.

Ms. Jacobs says it became more difficult to get Mr. Depp jobs @ 2010/2011. She claims when she would call to speak w/ a studio head, director, producer she'd be asked about his lateness, reports he was complicated, unavailable; this is juxtaposed by what many have said @ ...

working w/ Mr. Depp. I'm not suggesting Ms. Jacobs is lying, I'm just saying her statements, the statements others have made contradict one another. She says she spoke to Mr. Depp @ this, b/ doesn't recall his response; she says she can't recall b/ "possibly" lost roles b/c of it

Ms. Jacobs says she spoke @ his lateness etc. w/ Ms. Dembrowski as well, but she always defended her brother, made excuses for his behavior, & blamed others for these issues. She also says his issues with substance abuse also were an issue, becoming more noticeable in 2010/2011.

Ms. Jacobs says potential buyers were concerned about his substance abuse issues & would speak to her about it. She says she again spoke to Mr. Depp about these concerns, in addition to showing up late, the "craziness" w/ Ms. Heard. Mr. Depp, Rick Wood & others have all stated...

he was late oftentimes b/c of Ms. Heard's "bizarre behavior" & the abuse she was inflicting on Mr. Depp. Abuse victims often self-medicate & it is clear Ms. Heard was encouraging his drinking/illegal drug use; she gave him a Xanax in of the recordings. She says nothing ...

changed. Ms. Jacobs is then asked @ an email from her to a number of people dated May 20, 2008, in relation to 'Sweeney Todd,' the email was sent to Danny, Mr. Bloom's assistant b/c he didn't have an email at the time. The emails says Joel Mandel has given Ms. Jacobs ...

permission to "ask for advance per tax situation We'll see what happens." She says she asked for an advance on the front or back end of Mr. Depp's when he needed money. 'Pirates' she says she took a backend advance on, this is something that's been mentioned previously.

Ms. Jacobs mentions on advance she can recall, just prior to being fired by Mr. Depp. It was for 'Fantastic Beasts.' She says she asked Warner Brothers for a $5M advance against his $13M salary, & they granted it. She says Mr. Depp still owes money as of the time of this ...

May 30, 2018 deposition to UTA, possibly from backend deals for 'Fantastic Beasts,' 'Murder on the Orient Express,' 'LAbyrinth' aka 'City of Lies, & the remaining three 'Fantastic Beasts' films he will start in 2019. B/n these & frontend deals she says she & UTA are owed M's.

Ms. Jacobs says when money came in she would typically send it to Mr. Mandel's office. She says Mr. Depp received a frontend salary of $15M for Mortdecai, which is a film he starred in, produced along w/ his sister Ms. Dembrowski; it bombed so the backend deal was useless....

They discuss unspecified projects, Houdini as far as she knows which is still development, ad campaigns he was offered from Japan for jeans or glasses Ms. Jacobs can't recall. Nothing of importance at this juncture. The Dior campaign is mentioned. It was a 4 year deal; the ...

Japanese beer commercial Mr. Depp did. Ms. Jacobs then is asked @ November 2013, getting "marching orders" from Joel Mandel, a need for money & Ms. Jacobs assuring him she had films in the pipeline for March/April 2014 ($10-15M) & would get it done w/ the help of Ms. Dembrowski.

Next an email, just 2 days later, November 2013, is discussed. It's b/n Ms. Jacobs & other people including Ms. Dembrowski, Mr. Mandel, & Mr. Bloom. Ms. Jacobs is seeking to pin down specific dates for 2014, April 1-ish for 'Houdini,' confirmation for August/September for ...

'Alice 2' & November for 'Pirates of the Caribbean 5,' mentioning these need to be "pinned down" for the schedule & financials to work. She mentions working w/ Ms. Dembrowski & Mr. Bloom to line up films for Mr. Depp over the next few months. She mentions Mr. Depp needed ...

these money to meet financial needs. She says she had discussions w/ Ms. Dembrowski & Mr. Depp as well. She says she is unsure if Mr. Depp was aware of the series of movies, b/ he was aware he needed & wanted to work. She claims Mr. Depp spoke directly to David Lynch, b/ ...

the project they spoke about never came to fruition. The other movies, 'Alice 2' & 'Pirates of the Caribbean 5' did come to fruition. Ms. Jacobs verifies 'Pirates of the Caribbean 5' was made in 2015. She says along w/ Ms. Dembrowski, Mr. Mandel, & Mr. Bloom were trying to ...

layout the financials, the potential financials. Several weeks later via email, it is clear Mr. Mandel was planning a trip to London, where Mr. Depp was filming, to discuss his financial issues. Ms. Jacobs tells him to have a good trip; if it works out the rest of the year ...

should fall into place. Ms. Jacobs says Mr. Mandel told her Mr. Depp was spending too much money. Ms. Jacobs says she spoke to Mr. Mandel after he returned from London a few weeks later, b/ to her recollection nothing had changed after the meeting. It didn't sound to her ...

as if Mr. Depp planned to change his spending. She verifies Joel Mandel says he spoke to Mr. Depp, b/ she didn't have firsthand knowledge. She says she spoke again to Mr. Depp she was concerned about the pressure he was under financially, the need to make more money....

Next is an email Ms. Dembrowski sent to Ms. Jacobs saying she spoke to Mr. Bloom & he advised her to speak to Jeremy Zimmer the CEO of United Talent Agency. The email exchange continues w/ Ms. Dembrowski mentioning a potential deal to Ms. Jacobs. Ms. Jacobs replies saying she ...

won't gamble w/ Mr. Depp's financial future knowing what "she currently knows about April." Ms. Jacobs cannot recall if this is in relation to 'Mortdecai' or 'Houdini' as both are w/ Lionsgate; but says it was likely 'Mortdecai' b/c Mr. Depp & Ms. Dembrowski produced it....

Ms. Dembrowski ends the email, once again suggesting Ms. Jacobs keep looking for more projects. She says Mr. Depp was asking her to do the same. She says it was often about finding the highest paying film project. Next they move to an email from September 2, 2015. It's from ...

Ms. Jacobs to Mr. Mandel & copied to Ms. Dembrowski. She writes, "Did you tell Johnny? He needs to make $25M by the end of the year? What are you doing? I'm in Europe." It's important to note it is mentioned that Mr. Depp via his complaint accuses Ms. Jacobs from she was ...

hiding from him; the fact that he was in a difficult financial situation; that Mr. Mandel was hiding from Ms. Jacobs, Mr. Depp & everyone else...that this email proves this. I'm including this comment so you can read it in full. Mr. Chew objects to this, b/ just for the record.

Ms. Jacobs disagrees the email being b/n her & Mr. Mandel, claims it is likely from Ms. Dembrowski, b/ admits she was told Mr. Depp needed a job right away b/c he wasn't working earlier in 2015 (Ms. Heard severed his finger, requiring multiple surgeries, bouts w/ MRSA)....

Ms. Jacobs says she was questioning why she was being put in a position to find Mr. Depp any job for $25M. The last few tweet are clarified more w/ this Question & subsequent answer by Ms. Jacobs⬇️

Ms. Jacobs says she believes it was Ms. Dembrowski, not Mr. Mandel that told her this. That she believes she was told this by Ms. Dembrowski, & she was talking the w/ Mr. Mandel, that she had no time to find Mr. Depp a $25M job; that this is next to impossible to do.

Ms. Jacobs is in Venice at this time w/ Mr. Depp who is promoting 'Black Mass.' She says it was at this time or shortly after that Mr. Depp told her he was angry w/ Ms. Dembrowski. She recalls he told her he wasn't speaking w/ Ms. Dembrowski at the time & that she should ...

speak to him directly & not to Ms. Dembrowski. She cannot recall why he was angry w/ his sister; that she spoke to him directly after this point. Another email is mentioned from Ms. Jacobs to Mr. Mandel: "With B & A. What about selling backends?" Ms. Jacobs says this is ...

about a loan. She mentions at one point Mr. Depp spoke to UTA about the possibility of getting a loan or some type of money from UTA in 2016. She says B & A is Bank of America in this email. Ms. Jacobs mentions a discussion she had w/ Mr. Mandel & Mr. Bloom @ a ...

loan they had arranged based on some of his backends, specifically w/ 'Alice' & 'Pirates,' all movies that essentially, performed approximately a billion dollars or more were pledged against some cash. She says she doesn't know specifics @ the loans, as she wasn't involved.

After lunch they reexamined. Raul Anaya is mentioned at the bottom of one of the emails. Mr. Anaya works for Bank of America on loans for wealthy/famous people like Mr. Depp & works w/ UTA. It's an email from Ms. Jacobs to Mr. Bloom's assistant & Mr. Mandel. The subject is ...

Paul D. Ms. Jacobs is asked if this is one of Mr. Depp's aliases b/ she can recall, saying it might be. Raul Anaya writes to Andrew Thau, UTAs COO. The email says they spoke to Mr. Mandel on Friday & we are moving it along, noting there may be a shortfall in value from his ...

art collection; they are getting an appraisal on it. It notes they hope to have a better sense of what they can do after the appraisals are back. It also mentions Mr. Depp is asset-rich, b/ CF-poor for now; they say they know this can change & they are working our a structure ...

for it; they will update soon. Ms. Jacobs the self-corrects & says this was 2015, not 2016. She says this was about UTA loaning Mr. Depp money, something she says he proposed. She says Mr. Depp spoke to her, Jim Berkus, Jeremy Zimmer, Mr. Bloom, Mr. Schenkman & Mr. Mandel, ...

she thinks. Ms. Jacobs says Mr. Depp was seeking $20M & claims he said they should loan it to him b/c they'd made so much money together over the years. She says those form UTA at this meeting were shocked; that Mr. Berkus told Mr. Depp UTA wasn't in a position to ...

provide him w/ a loan. Ms. Jacobs said Mr. Depp became angry, saying he'd made them a lot of money & thusly they should reciprocate w/ a loan. UTA then she says informed him they would see what they could do. Mr. Depp then asked for only $15M. This was November 2015....

Ms. Jacobs calls her relationship in November 2015 as "complicated & difficult;" that he was more difficult to work w/ at this time. She mentions, however, w/ Ms. Dembrowski out of the picture September 2015 to this meeting, her relationship w/ Mr. Depp was "good, ...

accessible, responsive, either to emails or phone calls." Ms. Jacobs says the meeting ended w/ Mr. Depp furious. She says subsequent discussion @ this potential loan was w/ Andrew Thau & Mr. Depp. During all this she says she wasn't speaking w/ Mr. Depp as often as she thought.

After the meeting w/ UTA, Ms. Jacobs says Mr. Depp was "just very angry, & he was just going through the divorce things, so he was very angry." Let's keep in mind in March 2016, Mr. Depp was informed by Edward White hundreds of millions of dollars was unaccounted for & ...

financially he was in trouble. This resulted in the TMG/Bloom lawsuits in the next year, both of which he was successfully won via sealed settlements. There must have been merits to his accusations, as TMG following the settlement became the subject of a IRS/DOJ ...

investigation, as well as a SEC investigation & Jacob Bloom, Alan Hergott were forced to retire & the law firm was restructured & renamed. May 20, 2016 Mr. Depp's mother, Betty-Sue after falling into a coma, passed away from terminal cancer. May 21, 2016 Mr. Depp went to ...

the ECB Penthouse to pick up some of his belongings & to inform Ms. Heard their marriage was over, he wanted a divorce, after which she via proxy called 911 twice. Bodycam footage, 4 LAPD officers all refute her claims of abuse. May 27, 2016 Ms. Heard went to LA Court ...

to file a fraudulent TRO claiming abuse, when in fact credible evidence & witnesses of merit prove she was never abused by Mr. Depp, but in fact had severely abused him, even severing his finger, which resulted in multiple surgeries, MRSA. He's human, his anger was justified.

Ms. Jacobs says she spoke to Mr. Depp @ the divorce. She says he told her he never hit Ms. Heard. She then says she "believes" Mr. Depp lied to her @ drugs. She says she had conversations w/ him @ his drug use b/c she was concerned @ the impact it would have on his life & ...

children primarily, b/ also his career. She said the first time she ever spoke to him about his drug use was approximately 25 years ago. She says it was a problem at times, not a problem at other times. Let's take a moment to put this into perspective. Mr. Depp's been ...

candidly honest @ his drug use over his lifetime. He spoken of it in interviews over the course of his entire career, noting he started young self-medicating. He's been w/ many women in that time & none of them have accused him of abuse. Many abuse victims resort to ...

alcohol &/or drug use to cope w/ the abuse, to numb the pain. Mr. Depp was until June 2013 sober, it isn't until after his relationship w/ Ms. Heard that he starts to self-medicate again; in fact she poured him drinks, encouraged his drinking, his drug use, even giving him ...

a Xanax in one recording. Ms. Heard via medical documentation is an alcoholic/illegal drug user that required Seroquel an antipsychotic & attempted to leave a plane midflight over the ocean. Ms. Jacobs says she attempted to get Mr. Depp into rehab, b/ doesn't know if he ...

ever went to rehab. Ms. Jacobs says Mr. Depp's drug use altered his moods & his personality in a negative way, at least from her experience w/ him; she says he became angry, hostile, unwilling to communicate. She says his drug use affected his professional career, his ...

performance, his reliability, his showing up on time. She says she spoke to people directly involved w/ trying to get him to perform & appear on set on time. Ms. Jacobs says this made it more difficult to find Mr. Depp work. She says she discussed this w/ both ...

Ms. Dembrowski & Mr. Depp. Ms. Jacobs says she didn't feel like any of her discussions w/ Mr. Depp about these issues, ever truly resonated w/ him, then clarifies sometimes she felt it did, others she didn't. She also says his alcohol abuse was part of the problem.

Ms. Jacobs says she believed Mr. Depp when he told her he never hit Ms. Heard, but after learning some things she now (May 30, 2018) believes he did hit Ms. Heard. Let's put this into perspective. This deposition is from May 30, 2018. At this juncture, Ms. Jacobs wouldn't ...

have seen the credible evidence, heard the audio recordings. She may have a different opinion, as of her January 2021 deposition in VA. Ms. Jacobs isn't an eyewitness to the abuse. I'm not defending her, just noting this as clearly this is a smear attempt orchestrated ...

by Ms. Bredehoft/Ms. Heard submitted in a public court Motion. It's intentional. Reading this, noting Ms. Jacobs disdain for Mr. White & knowing his role as a forensic accountant in all this, we don't know why Mr. Depp fired Ms. Jacobs & it is possible she is a disgruntled ...

ex-employee. Much of Ms. Jacobs deposition testimony suggests there is more to the reason she was fired. My point is this is not anything of concern at this juncture. Ms. Jacobs continues saying the reason she believes Ms. Heard's claims of abuse "possibly" are valid is b/c ...

of his behavior & "violent outbursts" directed at her; she says he was never physically abusive to her. She clarifies saying he was verbally angry, raised his voice toward her; that over 30 years he was angry a couple of times. She says in 2015/2016 his anger increased....

Let's put this into perspective...Mr. Depp was being severely abused, had his finger severed, discovered 100s of millions of his own money was unaccounted for, lost his mother to terminal cancer, & was falsely accused by his abuser. He's human, he was angry. It's understandable.

Ms. Jacobs says Mr. Depp was angry w/ everybody & impacted his career. She says he's done a number of films since firing her in October 2016. She says she negotiated b/n 30-50 movies for Mr. Depp generating an income for Mr. Depp of $650M.

Pausing for a moment to mention something, while it is difficult to interpret via a transcript, it seems to me Ms. Jacobs in this section in particular is disgruntled b/c Mr. Depp fired her...she seems in answers to credit herself w/ his film career & success.

Ms. Jacobs says the last time she spoke to Mr. Depp was October 27, 2016. She says he called her while she was in London to inform her she was being fired & he had found new representation via CAA; that he felt they would do a better job representing him & Infinitum Nihil....

Ms. Jacobs says Mr. Depp "slammed the phone down." She says one of Mr. Depp's complaints @ her handling of Infinitum Nihil was he didn't believe she was doing enough to set up "esoteric projects that he either cowrote or scripts he'd optioned of films no one wanted to make....

Ms. Jacobs says these projects were "unmarketable" & she told this to Mr. Depp. She says he blamed her over the last few years of their working relationship. She says she had some idea she would be fired; says Ms. Dembrowski was saying how much she liked CAA for some time b/c ...

of the way they handled production companies like Infinitum Nihil. On the phone call Mr. Depp made to Ms. Jacobs, May 27, 2016 to fire her, she says she told him she found this disrespectful after 30 years toward her & toward their relationship; that she found it insulting....

Ms. Jacobs says this is when he began screaming at her, b/ she cannot recall what he said, then he "slammed the phone down." She confirms this is the last time she spoke to Mr. Depp, b/ says he texted her saying he knew this was difficult, that he wished it hadn't been quite ...

like that; that in case he didn't mention it on the phone, he would be taking his daughter, Lily-Rose w/ him to CAA. There are a bunch of nonconsequential emails about the UTA loan, nothing of substance. Then via an email January 2016, after getting the information from ...

Joel Mandel, Ms. Jacobs writes "On Thursday, Joel will walk him through the math of what he has to do to be financially okay. He needs to do two big movies this year, plus commercials, & selling the French house." The meeting she says took place January 28, 2016.

Ms. Jacobs says Ms. Dembrowski told her in 2015 Mr. Mandel had loaned Mr. Depp $8M in the past prior to the January 28, 2016 meeting. She says this discussion was @ Mr. Depp's financial situation; she says she was shocked. She says she asked Ms. Dembrowski if the loan ...

came from Rob & Joel Mandel personally. She says Ms. Dembrowski said yes, that she'd never heard of a business manager doing that. She says she then asked Ms. Dembrowski if Jacob Bloom had ever loaned Mr. Depp money & was told no. Sometime later she says she & ...

Ms Dembrowski spoke @ the Mandel's loaning money to Mr. Depp again around the time of the January 28, 2016 meeting. Ms. Dembrowski she says told her that UTA would be expected to provide a loan to Mr. Depp as well, b/ an amount was never discussed. Next is an email from ...

February 12, 2016 from Ms. Jacobs to Mr. Mandel & several people, including Ms. Dembrowski: "Joel, you really need to speak to him Tuesday to explain the need for him to do a film, even if not this one. I just spoke to the business manager, who told me Johnny may gross ...

100 grand a week, for a couple weeks maximum." Then a correction is made, it is music manager, not business manager; the email was misread. The email concludes w/ the music manager wanting to confirm July dates into August for the Hollywood Vampires tour....

The music manager is confirmed to be Trudy Green, Joe Perry's manager. Ms. Jacobs says she was concerned @ Mr. Depp playing w/ the Hollywood Vampires b/c he was just booking dates w/ no concern @ the money he needed to earn from film projects & he seemed not to care.

Ms. Jacobs says he was blocking out huge money earning months in terms of when films are greenlit. She says she spoke to Ms. Dembrowski @ this; then Mr. Depp's sister she says "threw her under the bus," telling him she was attempting to interfere w/ his music career.

Ms. Jacobs says Mr. Depp was angry b/c he thought she was trying to sabotage or interfere w/ his music career. March 7, 2016, Ms. Jacobs emails Mr. Mandel informing him Mr. Depp will be performing w/ the Hollywood Vampire's until August, despite having discussed this ...

further w/ Ms. Dembrowski, making it clear financially he needed to book a film b/c of his finances. Next it is mentioned Mr. Depp fired Mr. Mandel (TMG) March 14, 2016. Ms. Jacobs says she didn't know Mr. Depp intended to fire Mr. Mandel (TMG). She says she was told by either...

Ms. Dembrowski or Mr. Depp @ Mr. Mandel's (TMG) termination, b/ wasn't told why. Ms. Jacobs says shortly after Mr. Depp hired Edward White, she had communications w/ him; met him several times face to face. She says she had "regular" communications w/ him until she was fired.

Ms. Jacobs says she spoke to Mr. White @ money, films, Mr. Depp's financial issues & a loan he was procuring for Mr. Depp via Bank of California. She says she doesn't think Mr. Depp got the loan from the Bank of California, b/ doesn't know who he got the loan from.

Ms. Jacobs says Sheikh Fahad was someone Mr. Depp met in London several years ago who introduced him to Eric Princes, who he spent time with as friends. A Yacht trip is then mentioned. She believes it was Eric Princes that talked Mr. Depp into firing Mr. Mandel, as well as ...

herself. Ms. Jacobs says he acted as if he was the go between w/ the Bank of California. Sheikh Fahad she says is Pakistani. She says she met him for lunch, along w/ Jim Berkus at the Polo Lounge at Mr. Depp's request. The meeting was to discuss raising money for Mr. Depp.

Ms. Jacobs says, Sheikh Fahad was going to produce all of Mr. Depp's films & had access to a lot of foreign money & investments. She says he was going to be involved in Mr. Depp's professional life. She says she thought Sheikh Fahad was "full of sh*t." She says he ...

never raised any money for Mr. Depp or put him in any films. Ms. Jacobs says she spoke w/ him again to ask him for a progress report on the money he was raising for a script Mr. Depp had, that he said he had all the money for. She reiterates he never raised any money.

Ms. Jacobs says Sheikh Fahad was a "conman." She says she researched his producing credits & found just one of a film she'd didn't recognize. She says she told Mr. Depp she didn't trust him; that Mr. Depp ignored her concerns. She says Mr. Depp was relying on his counsel ...

at the time Mr. Depp terminated her & she believes Sheikh Fahad had something to do w/ the reason she was fired. Next an email from March 9, 2016 from Ms. Jacobs to Gueran Ducoty, a commercial agent at UTA is discussed. It's regarding a commercial or endorsement of some ...

type w/ Turkish Air. It's mentioned it is vital to get this offer to Ms. Dembrowski & Mr. Depp immediately as he needs $4M. The full offer is $15M for a Turkish Air commercial, some personal appearances, & a print ad. She says Mr. Depp turned it down.

Ms. Jacobs is shown a series of emails she wasn't a party to saying, "This agreement in consideration of guaranty is entered into as of February 5, 2016 among John C. Depp borrower & United Talent Agency, LLC." The agreement is signed by Jeremy Zimmer on behalf of UTA & Mr. Depp.

Ms. Jacobs says she's never seen this previously & cannot verify it. She says she does know at some point there was an agreement b/n the parties, however. UTA was guaranteeing a loan at Bank of America, loaning Mr. Depp $5M dollars, secured by his art collection.

Ms. Jacobs says this angered both Ms. Dembrowski & Mr. Depp both of whom called her "yelling" UTA was screwing him over by using his art collection as collateral for the loan. She says she told them both to speak to Mr. White, have him explain it to them. She says she ...

called Mr. White to inform him she didn't think his client understood the terms of the loan. Ms. Jacobs is show a series of emails b/n herself & Ms. Dembrowski @ Dr. Kipper, an internist who also assists people detox from substance abuse issues. She says there were discussions...

in November 2013 @ Mr. Depp potentially hiring Dr. Kipper, also the subject of these emails b/n Ms. Jacobs & Ms. Dembrowski. She says Mr. Depp did in fact hire Dr. Kipper. She doesn't know if he helped Mr. Depp w/ his sobriety, b/ she says 2013-2016 Mr. Depp had issues ...

w/ substance abuse. Just to put this into perspective 2013-2016 is when he was w/ Ms. Heard who was severely abusing him, encouraging his drug & alcohol use & it isn't uncommon for abuse victims to self-medicate. Mr. Depp's been candidly honest @ his issues.

An email from The Wrap to Ms. Jacobs brings up his speech at The Hollywood Film Awards & his "bizarre behavior." Ms. Jacobs says she forwarded the email to Ms. Dembrowski. The video she says shows him stammering, looking completely out of it. She says he looked under the ...

influence of something. Ms. Jacobs said she forwarded the email to Ms. Dembrowski b/c Mr. Depp is her brother & she wanted her to see what people were talking about, especially since she was receiving calls about it, others were commenting to her @ it; that it wasn't good ...

for Mr. Depp's career. Ms. Jacobs says she also spoke to Mr. Depp @ it, b/ cannot recall his response. She mentions she also spoke to his publicist & she said he'd smoked some pot & had taken a Xanax prior to walking on stage. Let's put this into perspective....

Mr. Depp's spoken candidly about his issues w/ anxiety over the course of his career. It's possible the Xanax was prescribed to him by a medical professional. At this time, he's suffering silently through severe abuse, self-medicating, which isn't uncommon for abuse victims....

Perhaps, he smoked some pot, via the abuse & his normal anxiety issues, he took more than his normal dosage of Xanax or Ms. Heard who gave him a Xanax in an audio recording gave him the Xanax. We don't know, but it isn't uncommon for this to happen to people taking medication.

Ms. Jacobs then is given emails from February 26, 2015, just days before Ms. Heard severed Mr. Depp's finger in Australia. The email says she spoke w/ Sean Bailey, the President of Disney. Mr. Bailey mentions Mr. Depp was late to set, tells Ms. Jacobs he needs to self-correct ...

within 2 days or there will be issues. Mr. Bailey also asks if he attended a Foo Fighter's concert the night prior. Ms. Jacobs says Mr. Bailey was upset & concerned; that this wasn't the first time he'd been late to set. Let's put this in perspective. Via evidence & ...

testimony we know Ms. Heard during this time, was violently abusive to Mr. Depp; he was fleeing into bathrooms in the rental home to escape the abuse; she was angry, screaming, calling cabs w/ empty suitcases repeatedly, among other things; we also know this is why he was late.

Ms. Jacobs says Sam Dickerman, the Vice-President of Disney also called her, as he was overseeing the film (POTC 5). She says Mr. Dickerman also made it clear Mr. Depp's lateness to set would not be tolerated & they would impose financial penalties if Mr. Depp didn't self-correct

Ms. Jacobs says she attempted to contact Mr. Depp & speak directly to him, b/ was unable. Instead she spoke w/ Ms. Dembrowski, b/ doesn't recall her response; says she assumes she defended her brother. In an email February 7, 2015, Mr. Bailey tells Ms. Jacobs, Mr. Depp was ...

8 hours late to set yesterday & the film is behind schedule. He tells Ms. Jacobs he's left word w/ Ms. Dembrowski. Ms. Jacobs responds saying Ms. Dembrowski will call Mr. Bailey. She also tells him Jerry Bruckheimer called to inform her that if he's not on time Monday, ...

"we have a real problem." Ms. Jacobs tells Mr. Bailey she doesn't know what to do b/c Jerry isn't there, isn't on location & she doesn't know who will speak to Mr. Depp. Ms. Dembrowski writes saying she will attempt to speak to Mr. Depp, make sure he understands. Ms. Jacobs...

responds saying Jerry has informed her Mr. Depp has been late every day at least 2 hours; his lateness on 'Alice 2' & 'Mortdecai; & asks Ms. Dembrowski if there is anything she can do to help. Ms. Dembrowski responds saying Mr. Depp admits the lateness & knows he ...

needs to self-correct; they are working on getting him there on time. Let's put this into perspective. Mr. Depp lateness on POTC 5 is attributed to Ms. Heard's abuse via evidence & testimony; he was w/ Ms. Heard in 2014 when he filmed 'Alice 2' & in 2013 when he filmed Mortdecai

Ms. Jacobs mentions Mr. Depp's severed finger, how it shut down production for over a week on POTC 5, costing Disney millions. She says Disney was frustrated about the delay due to his severed finger. Ms. Jacobs says she flew to Australia twice w/in 3 weeks to see Mr. Depp.

Ms. Jacobs says she missed him the first trip to Australia b/c Mr. Depp had already left for Los Angeles for surgery on his severed finger. Three weeks later she was able on the second trip to see Mr. Depp in person. She says Mr. Depp was on set w/ Ms. Heard & everything was okay

Ms. Jacobs said POTC 5 finished production, however, Mr. Depp was late to set on several more occasions. She says she continued to have discussions w/ Mr. Depp about these issues as they arose when she was occasionally able to speak to him directly. She says issues like these...

didn't help his career progress & made it more difficult for her to procure him employment, to keep his price up & for her to give him opportunities she wanted him to have. Ms. Jacobs says when she was fired it was a crisis point. Next is a new set of emails....

Ms. Jacobs identifies John Lesher as the "Pressure of 'Black Mass' & Scott Cooper, as the director of 'Black Mass.' Mr. Lesher writes Ms. Jacobs b/c Mr. Depp didn't show up when he was scheduled to work today; expressing he hopes he will show up tomorrow. Ms. Jacobs says ...

there were issues during the filming of 'Black Mass,' regarding Mr. Depp's lateness to set. She says she attempted to address the issue. Ms. Jacobs is then asked if she knows if Mr. Depp ever made any false statements or untruths to studios; her response is she doesn't know.

Ms. Jacobs is asked if she knows of any false statements or untruths Mr. Depp's made in connection w/ the press; her response is she "imagines" he has, b/ notes most actors do. Ms. Jacobs is then asked if she knows of any false statements or untruths Mr. Depp's made to ...

Ms. Jacobs is asked if she knows of any false statements or untruths Mr. Depp's made to authorities who were investigating anything either his conduct or anything involving his family; her response is yes. She says it relates to his daughter, Lily-Rose. She says Mr. Depp was ...

being investigated by the Department of Family Services & the LAPD. She says she doesn't know what the particular "charges" were, b/ says Lily-Rose was 15, her boyfriend was 23 & they were living next door to Mr. Depp in the ECB Penthouses. Ms. Jacobs says the reason she ...

believes Mr. Depp made false statements to the authorities is he met w/ both the LAPD & the Department of Family Services & no charges were filed. When she asked him about it he said things went well. She says she accused him of lying to the authorities & his response was smile.

Let's put this into perspective. First, a smile is not an indication someone lied to the authorities. Second, charges not being filed in an investigation doesn't warrant the accusation Ms. Jacobs made that he lied to authorities. Third, Lily-Rose is both a citizen of the ...

US & France. She was 15 at the time. In California the age of consent is 18, however, in Paris the age of consent is 15. It's also important to note Ms. Paradis at the age of 15, was living w/ her boyfriend, French singer Florent Pagny who was 26 at the time....

Lily-Rose wasn't hiding this relationship from her parents, in fact, she was living next door to her father. Fifth, who called the Department of Family Services in LA? Was this part of Ms. Heard's malicious criminal hoax scheme? Was this part of other parties nefarious acts?

Ms. Jacobs is asked if she knows if Mr. Depp pressured anyone working for him to lie to the authorities; her response is she doesn't know. Next we move on to emails from September-October 2016. Ms. Jacobs is asked if she still had issues contacting/speaking to Mr. Depp ...

after the Mandel's (TMG) were fired & Mr. White came into the picture; her response is yes. They discuss emails b/n Ms. Jacobs & Mr. White @ when he will return to Los Angeles, a film role he's accepted his mentioned by Mr. White & he says all that's left to work out are the ...

financials. Ms. Jacobs says this is in reference to LAbyrinth (City of Lies). Ms. Jacobs said she negotiated a salary of $8M w/ 6 weeks of backends for Mr. Depp, b/ the estimates they had made to sell it were too high, so they could only afford to pay him $6M w/ 6 weeks backends.

Ms. Jacobs says this is why she was trying to contact Mr. Depp. She says Mr. Depp contacted her, didn't want to reduce his fee, so the film was going away. A text from September 3rd from Mr. White to Ms. Jacobs says he says he received the attached text from Fahar & he met ...

w/ the uncles of the prince. He mentions contacting her later as the price arranged for a private jet so Mr. Depp could go finish 'Sherlock.' Ms. Jacobs says the prince refers to the prince of Saudi Arabia. She says the 'Sherlock' role was a voiceover for Elton John & ...

David Furnish for which Mr. Depp got paid $250,000; basically a gratuity she says. Ms. Jacobs sends Mr. White @ an invoice sent to him when he first started working w/ Mr. Depp; she asks him what Fahar is giving Mr. Depp besides planes & a trip to Spain w/ the Saudi Prince....

Mr. White responds to Ms. Jacobs informing her Mr. Depp has received nothing from Fahar to date. Ms. Jacobs saya Mr. Depp didn't receive anything from Fahar. Mr. White sends Ms. Jacobs pictures of Mr. Depp that Mr. Fahar took, telling her he looks healthy & rested, saying ...

maybe Spain was the perfect hiatus. Ms. Jacobs says she was constantly texting/calling Mr. Depp, b/ never received a response; she left word for him twice; she called Ms. Dembrowski & Mr. White, b/ neither assisted her in contacting Mr. Depp. She says she's unsure if ...

either Ms. Dembrowski or Mr. White at the time was able to contact Mr. Depp. On September 19th Ms. Jacobs informs them she need to close the deal at FOX for 'Murder on the Orient Express.' She's says she emailed Mr. Depp the specifics of backend & needs him to get back to her ...

today. Mr. Depp then texts Ms. Jacobs accepting the backends; she says she was going to go back to FOX to see if she could get him a better backend deal. October 7th Ms. Jacobs texts Mr. White saying there is an issue w/ Mr. Depp; that she received an angry text from him @ money.

Ms. Jacobs says this was in reference to his advance for "Fantastic Beasts.' She says he got him the advance, b/ Mr. Depp didn't want to pay UTA the commissions on it or "pay them period." UTA wanted a meeting w/ Mr. Depp when he returned to LA, b/ the meeting never happened.

Ms. Jacobs says the meeting never happened according to Mr. White b/c Mr. Depp didn't want the meeting to happen. She says, Mr. Depp knew the meeting didn't need to happen b/c two weeks later he fired her (10/27/16). Ms. Jacobs says she corresponded w/ Mr. White complaining ...

No one was updating her. Reminding him Mr. Depp was supposed to go to work in 3 weeks & needed to do some work before filming commenced. Mr. White responds to Ms. Jacobs saying, "If I receive additional information, I'll share w/ you." Ms. Jacobs believes Mr. Depp made the ...

decision to fire her several weeks prior to her termination 10/27/16. Ms. Jacobs corresponds w/ Mr. White saying she received a call from Disney last week saying Mr. Depp showed up 5 hours late for his ADR work in London for POTC 5, to inform him he needed to speak to Mr. Depp...

in LA before he started his next project. Mr. White responded saying: "All you can do is continue to reach out in a thoughtful & professional manner. When feasible, I will attempt to assist you." Ms. Jacobs says she thought this response was "bullsh*t." She says she wrote ...

back via correspondence saying: "I'm always thoughtful & professional. You're the only one I get information from. There are 3 international commercial campaigns we have real potential for on Johnny." Ms. Jacobs says Mr. White never responded. October 19th, Ms. Jacobs ...

corresponds w/ Mr. White again, telling him: "Just to let you know I texted Johnny all the details & told him we made a decision...we need a decision immediately or the film goes...November goes away. They are 3 weeks away from starting...it would have...it would be helpful ...

if you reached out to Johnny too. We're in a time crunch." Mr. White responds saying: "Please continue to pursue JD & request a response by a specific date & time." Ms. Jacobs says she found this response to be "bullsh*t" too. October 20th Ms. Jacobs writes to Mr. White again...

to tell him the November film is about to fall apart b/c no one can reach Mr. Depp; that if he doesn't close today the financing falls apart. Mr. White responds tell her he's sent a text to Mr. Depp & requested he contact Ms. Jacobs. Ms. Jacobs was in a meeting when this ...

text arrive so wrote back to Mr. White informing him she was "out now" & he could contact Ms. Dembrowski for the details. Mr. Whites replies by informing her Mr. Depp asked for the producer's number. Asks Ms. Jacobs if she sent Mr. Depp the number. Ms. Jacobs replies she ...

sent Mr. Depp the number 3 times, & he just kept asking for it. Mr. White responds requesting the number, so he can send it to Mr. Depp. There's a back and forth 3 times b/c Ms. Jacobs & Mr. White, she says he has the number, he says he does not. She says he was ...

"screaming at her in texts." Mr. White once more says Mr. Depp doesn't have the number & if she sends it to him he will forward it to Mr. Depp. Ms. Jacobs responds saying she doesn't understand what is going on. October 21st Ms. Jacobs corresponds again w/ Mr. White to ...

inform him Mr. Depp never called her & she doesn't know what he wants to do; that if he doesn't contact her by end of day, the film is over, unless he wants to make the $6M deal today. She also requests to speak to Mr. White soon. Ms. Jacobs writes again to Mr. White saying ...

she just wants the best for Mr. Depp; she's always fought for him & been honest & direct. Invites Mr. Depp to speak w/ Jim Berkus. A few days later Ms. Jacobs writes to Mr. White to inquire how the meeting went. She asks if Mr. Berkus & herself can set up a meeting w/ Mr. Depp.

Mr. White responds saying: "The meeting was financially oriented, & Mr. Depp did not commit to any additional meetings. Please converse w/ JD." The following day Ms. Jacobs emails Mr. White saying: "I called you. Johnny fired me. It was very unpleasant & angry from him....

We will be speaking very soon." Mr. White responds writing: "Tracey, Johnny informed me on Monday during our meeting. You are welcome to call me tomorrow, respectfully." Ms. Jacobs says she spoke to Mr. White after this; she saw Mr. White was being honest w/ her via an ...

article she read in Vanity Fair where it described the meeting Mr. White & a group of people were having where it mentioned he was terminating her & UTA. Ms. Jacobs is asked if she was ever involved in an attempted intervention w/ Mr. Depp b/c of his substance abuse; she ...

responds yes. Ms. Jacobs is asked what her role was in this attempted intervention; she responds she was 1 of 4 people that were going to do it & met w/ a doctor/interventionist at St. John's Hospital to learn what was required in an intervention. She says this happened ...

25 years ago. Ms. Jacobs says she was at this attempted intervention w/ Ms. Dembrowski, Mr. Palmer (JD's stepfather), Betty-Sue Wells Depp Palmer, & some of his friends, @ 10 people total. She says it took place at her house & the outcome is he left yelling he wasn't ...

going to rehab.

I'd like to take a moment & interject something her I discovered in my research into this case since 2016. I don't know if this comment is related to this attempted intervention, b/ Mr. Depp is speaking @ an intervention. The time period he says this fits.

Ms. Jacobs is presented a series of texts w/ someone named Jacques Hughes & she confirms this is one Mr. Depp's aliases. Ms. Jacobs is attempting to send the LAbyrinth (City of lies) script to him, saying she set a meeting b/c she's told him "we need more money." ...

Mr. Depp responds saying there is no point to a meeting if there isn't any money. Ms. Jacobs writes back she is working on getting him money, b/ he needs to help her by taking this meeting. She tells him he won't know if he even wants the role unless he meets w/ the director....

Mr. Depp responds asking her for the numbers & saying he will call her "in a second." Ms. Jacobs write back, "Johnny, I felt so bad after our conversation & I love you so very much. I want you to know I will never stop fighting for you. It will all be good again. I promise."

Mr. Depp responds saying, "It ain't looking good." Ms. Jacobs believes he was talking @ his career & Ms. Heard; indirectly he was talking about his financial situation she believes. In b/n there are some nonconsequential texts @ Labyrinth (City of Lies) the ignorance of the ...

murders of Tupac Shakur & The Notorious B.I.G. & his desire to make a film exposing the truth. July 2016, Ms. Jacobs texts Mr. Depp saying she needs to speak w/ him @ the schedule for the movie, mentions Brad wants to hiatus for a few weeks, so Mr. Depp can ...

gain weight for the role. She tells Mr. Depp she made a deal for 6 consecutive weeks, b/ notes he may need time to prepare for the role & needs his thoughts. Mr. Depp responds in the SS attached. I felt it best not to sum up his words pertaining to this text⬇️

There are 2 more texts, essentially Mr. Depp is irritated b/c he told Brad he would bulk up on muscle & do some MU tests. Ms. Jacobs says the Scott Cooper reference was @ "Black Mass.' Mr. Cooper wanted him to look closer to Whitey Bulger & Mr. Depp wanted to use less ...

prosthetics; that Mr. Depp won the argument. August 16. 2016 Ms. Jacobs texts Mr. Depp: "I'm really happy for you this is settled so things will be better. I know its been awful, & now you can move on. We are focused on work." She says this is in reference to Mr. Depp's ...

divorce settlement w/ Ms. Heard. Ms. Jacobs says Brett Ratner had some scripts Mr. Depp was interested in. She says before Brett was Brett, there was one film he gave Mr. Depp, 'The Libertine.' The movie Mr. Ratner offered was one now was @ a diplomat in NY that r*pes his maid...

which was based on the story of Dominique Strauss, b/ after what happened w/ Ms. Heard, Mr. Depp couldn't do the film; she clarifies saying he shouldn't do the film. There's a text exchange b/n Ms. Jacobs & Mr. Depp, noting Warner Brother's had a great test of 'Fantastic ...

Beasts' & Sue Krill, President of Distribution & Marketing likes the character & Mr. Depp's performance & is requesting to talk to Mr. Depp directly. Mentioning also Brett Ratner wanted an answer in the aforementioned film @ a diplomat in NY. Ms. Jacobs says neither she nor ...

UTA ever negotiated a book deal for Mr. Depp. Ms. Jacobs in response to Mr. Depp's request for money via text, tells him she will find him the right job; that she's negotiated a $5M advance in October from Warner Brothers/Fantastic Beasts; that she & Mr. Berkus got his Disney ...

overhead extended an additional 6 months, while they see if China happens. She explains the Disney overhead as the overhead that supports the company b/c his overhead was almost $3M a year that paid all the employees, including Ms. Dembrowski at Infinitum Nihil....

Ms. Jacobs said UTA went to Disney Alan Horn, the Chairman of Disney, & Sean Bailey, the President of Disney to "grovel" for an additional year. She says, "There was no love b/n Johnny & Disney, given the 'Pirates 5' situation. But for UTA they agreed to extend it. This = $1M.

Ms. Jacobs is asked if Mr. Depp ever told her he was diagnosed w/ Bipolar; she responds saying no. Let me interject a moment, this is not news, as Mr. Depp was asked @ being diagnosed by Ms. Wass during the UK trial & honestly answered. October 2016, Ms. Jacobs texts Mr. Depp ...

to tell him how great the POTC 5 teaser trailer looks & the great reception it is receiving. Mr. Depp responds w/ the attached text. I've left this in full b/c earlier Ms. Jacobs says he texted this screaming at her...the text isn't screaming imo. This is important⬇️

Ms. Jacobs asks if she thinks Mr. Depp wrote this text; she responds no & says she believes Mr. White wrote the text. Ms. Jacobs texts Mr. Depp saying: "I don't want there to be any misunderstanding. Can we talk not over text?" Mr. Depp writes back: "I don't know how my ...

message gave you the idea that I misunderstand. Seemed pretty straightforward from my end." Ms. Jacobs responds saying: "I don't know what was conveyed to you. I'd rather talk on the phone when you can." Mr. Depp writes back saying: "I'll speak to you when I can."

Ms. Jacobs says the next time she spoke to Mr. Depp on the phone was when he fired her 10/27/16. Next the move onto a series of texts b/n Ms. Jacobs & Mr. Depp @ the film LAbyrinth (City of Lies). Ms. Jacobs texts Mr. Depp @ a money issue that's arisen w/ the financing of the ...

film. Mr. Depp responds asking how much financing has been lost; he asks who he needs to speak to, as he's certain locate the money in a "very short period of time." Ms. Jacobs texts him, tells him he needs to speak w/ the producer Miriam Segal & requests to speak to ...

him directly as she doesn't want to cut his fee, has said no, & wants to give him the details; wants to see him person on Friday afternoon, early evening; also she wants to personally give him a Frances Bean Cobain painting. Mr. Depp texts back in all capital letters ...

October 20th: "GIVE ME MIRIAM SEGAL'S NUMBER. I NEED IT NOW." Ms. Jacobs then sends him the number 3 times. Mr. Depp replies saying: "Give me Miriam Segal's number !!!" Ms. Jacobs writes back saying: "I just sent you both numbers." She then sends the numbers again & an ...

additional text to Mr. Depp saying: "Got it. Do you have them?" Mr. Depp responds saying: "I need it now!" Ms. Jacobs write back: "I sent it...look at your texts..." Eventually she sends the numbers to Mr. White who forwards them to Mr. Depp. October 21st Ms. Jacobs texts ...

Mr. Depp to inquire if he received Donna Langley's text b/c she reached out & mentioned she'd not received any response @ 'Invisible Man' or 'Phantom.' She also mentions Doug Brinkley called to see how Mr. Depp was doing. October 25th Ms. Jacobs sends this text to Mr. Depp.⬇️

October 25th Mr. Depp responds saying, "Need to speak w/ you. I know you're in London. Let me know when it is a good time to call you." Ms. Jacobs replies, "Call me now if you'd like." She also send him her number. Mr. Depp responds, "Gimme 20 minutes." Ms. Jacobs writes, ...

"Isn't it early there?" Mr. Depp responds, "Yeah, 4AM call you in a bit." Mr. Jacobs replies, "Okay, I'm going to lunch soon. I'll have my phone out ready to speak w/ you. Whenever you're ready I'll be there." Mr. Depp responds, "Just hit me up when your lunch is over...."

Ms. Jacobs writes, "Are we okay? I can speak whenever." Mr. Depp replies, "Just don't want to interrupt a lunch." The exchange continues w/ Mr. Depp saying his in the studio. Several hours later Mr. Depp writes, "Are you in your room? Hit me when you can talk." Ms. Jacobs ...

texts Mr. Depp saying, "I'm up." She then sends him a number of additional emails, b/ there's no response.

Now onto the GOOD part...Mr. Chew cross-examining Ms. Jacobs.

Mr. Chews asks Ms. Jacobs if she is an attorney; she responds by saying no. Mr. Chew asks Ms. Jacobs ...

if legal services were part of "the engagement for which UTA received 10% of $650M;" she responds no. Mr. Chew asks Ms. Jacobs if she is a CPA; she responds no. Mr. Chew asks Ms. Jacobs if she or UTA provided any accounting services to Mr. Depp; she responds no.

Mr. Chew asks Ms. Jacobs if she or UTA prepared any tax returns for Mr. Depp or his company; she responds no. Mr. Chew asks Ms. Jacobs if she or UTA were responsible for filing any of his tax returns; she responds no. Mr. Chews asks Ms. Jacobs if she was present when ...

Depp's finger was severed in Australia; she responds she wasn't present. Mr. Chews asks Ms. Jacobs if Mr. Depp ever hit her or was physically violent in her presence; she responds acknowledging Mr. Depp never hit her or was physically violent in her presence. Mr. Chew asks ...

Ms. Jacobs if she ever witnessed Mr. Depp hit anyone else in her presence: she responds saying Mr. Depp never hit anyone else in her presence. Mr. Chew asks Ms. Jacobs what was the total amount UTA received for its work over the years for Mr. Depp; she responds "10% of ...

whatever he made." She then verifies it was approximately $65M. Mr. Chew asks Ms. Jacobs if Mr. Depp would buy her gifts at holiday time; she responds "Some holidays, yes." Mr. Chew asks Ms. Jacobs if she would often request a particular gift that she wanted; she responds yes....

Mr. Chew asks Ms. Jacobs if Mr. Depp would accede to her gift requests; she responds "Sometimes." Mr. Chew asks Ms. Jacobs what were some of the things he bought her for the holidays; she responds "Pens, a bracelet." Mr. Chew asks Ms. Jacobs if these were expensive gifts; ...

she responds, "I don't know. It depends what you call expensive." Mr. Chew asks Ms. Jacobs if some of the gifts were over $5,000; she responds yes. Mr. Chew asks Ms. Jacobs if some of the gifts were over $10,000; she responds yes. Mr. Chew asks Ms. Jacobs if Mr. Depp was ...

generous to her; she responds yes. Mr. Chew asks Ms. Jacobs if she didn't like the manner in which Mr. Depp fired her; she responds she didn't like it. Mr. Chew asks Ms. Jacobs if she thought she deserved more after all those years of service; she responds yes. Mr. Chew ...

asks Ms. Jacobs if she was angry with Mr. Depp at the time she was fired; she responds no. Mr. Chew asks Ms. Jacobs if she was angry when he dismissed her; she responds no. Mr. Chew asks Ms. Jacobs if she was present during the interview w/ Child Protective Services; she ...

responds no. Mr. Chew asks Ms. Jacobs @ the texts from Jacques Hughes who she identified as Mr. Depp. He asks her if she believes these came from Mr. White; she says no, she believes they came from Mr. Depp. The next set of questions is asked by Ms. Sookasian representing ...

cross-defendants Bruce Witkin, Sal Jenco, William Rassel, James Russo & Unison Music. Ms. Jacobs is asked if she is familiar w/ the cross-defendants; she responds yes to the 4 individuals, b/ says she knows little @ Unison Music. Ms. Sooskian says she will ask @ the 4 then.

Ms. Sooskian asks Ms. Jacobs was it her understanding that Mr. Depp was friends w/ these 4 individuals; she responds yes. Ms. Sooskian asks Ms. Jacobs whether she knows Mr. Rassel is Mr. Depp's nephew; she responds yes. Ms. Sooskian asks Ms. Jacobs how long these 4 ...

individuals have been friends w/ or known Mr. Depp; she responds, "A long time, b/ not exactly." Ms. Sooskian asks Ms. Jacobs whether or not they have known Mr. Depp for at least 5 years; she responds yes. Ms. Sooskian asks Ms. Jacobs whether or not they have known Mr. Depp ...

for at least 10 years; she responds yes. Ms. Sooskian asks Ms. Jacobs whether or not they have known Mr. Depp for at least 15 years; she responds "I believe so." Ms. Sooskian asks Ms. Jacobs if 15 years is her best estimate; she responds "Maybe more." Ms. Sooskian asks ...

Ms. Jacobs based on her interaction w/ Mr. Depp, her conversations w/ him over the period of time that she worked w/ him if it was her understanding that Mr. Depp had had a close relationship w/ these 4 people; she responds yes. Ms. Sooskian asks Ms. Jacobs to tell her ...

more about Mr. Depp's relationship w/ these 4 men; she responds "Well they're each different. Sal Jenco was his best friend who ran the Viper; Bruce Witkin was his friend who he did music with; I don't know what he did w/ his nephew. I believe that's Debbie's son. And ...

James Russo was an actor who he had known for a long time." Ms. Sooskian asks Ms. Jacobs asks what band or what kind of music did Mr. Depp & Mr. Witkin engaged in; she responds "I don't know. He was always at the house & they were always recording music w/ different ...

musicians." Let me pause a moment to interject...Ms. Jacobs isn't being forthright in my opinion. Mr. Witkin was a member of The Kids, was his vocal coach for 'Sweeny Todd,' & at one point ran the musical branch of Infinitum Nihil; since UTA represented Infinitum Nihil ...

Ms. Jacobs would know these things. Ms. Sooskian asks Ms. Jacobs if Mr. Depp had any conversations w/ her @ the financial struggles these 4 individuals were having at any time; she responds yes. Ms. Sooskian asks Ms. Jacobs to elaborate on these conversations; she responds ...

"Sal Jenco, who I think he knew the longest. We haven't spoken @ it in years, b/ when he spoke to me, he was always broke." Ms. Sooskian asks Ms. Jacobs if Mr. Depp said anything else @ Sal Jenco, other than he was always broke; she responds yes. Ms. Sooskian asks Ms. Jacobs ...

to elaborate on the other things Mr. Depp said about Mr. Jenco; she responds "That he thought that he had stolen from him at the Viper Room....He was in his life for years, & then he was gone, so we haven't spoken about it in years." Ms. Sooskian asks Ms. Jacobs if Mr. Depp ...

at any point in time ask her for advice about helping Mr. Jenco & the financial situation he was in; she responds no. Ms. Sooskian asks Ms. Jacobs if she ever gave Mr. Depp advice about whether or not he should help Mr. Jenco & the financial situation he was in; she responds ...

no. Ms. Sooskian asks Ms. Jacobs if she is aware of any payments Mr. Depp may have given to Mr. Jenco at the time; she responds yes. Ms. Sooskian asks Ms. Jacobs what Mr. Depp told her about James Russo; she responds "That he was an actor. I knew that already....

And I would be constantly asked to get him jobs in movies Johnny was in." Ms. Sooskian asks Ms. Jacobs if it was her understanding at the time that she needed to get Mr. Russo jobs b/c he wasn't financially stable; she responds "And b/c he was Johnny's friend." ...

Ms. Sooskian asks Ms. Jacobs if Mr. Depp ever went into details about Mr. Russo's financial condition at the time; she responds no. Ms. Sooskian asks Ms. Jacobs if Mr. Depp ever asked her to give him advice about whether or not he should help Mr. Russo financially; she ...

responds no. Ms. Sooskian asks Ms. Jacobs if she ever gave Mr. Depp advice about helping Mr. Russo financially; she responds no. Ms. Sooskian asks Ms. Jacobs if she ever became aware of the fact that Mr. Depp did provide financial assistance to Mr. Russo; she responds "Nope."

Ms. Sooskian asks Ms. Jacobs if she would characterize Mr. Depp as generous to others; she responds "Extremely." Ms. Sooskian asks Ms. Jacobs to elaborate on Mr. Depp's generosity to others; she responds⬇️

In the next section (pp.254-387) is Tracey Jacobs deposition from May 13, 2019 in Mr. Depp's lawsuit against Bloom Hergott Diemer Rosenthal LaViolette Feldman Schenkman & Goodman LLP, Jacob Bloom, & Does 1-30. Feel free to discuss, ask questions if you have any.

Mr. Chews asks Ms. Jacobs when she started working as Mr. Depp's agent; she responds "32.5 years...." Mr. Chews asks Ms. Jacobs at the time she started working w/ Mr. Depp, what, if any movies had he appeared in; she responds "He had appeared in 'Platoon' in a small role....

And I was at ICM then." Mr. Chews asks Ms. Jacobs if at the time she started working w/ Mr. Depp, if he'd already appeared on '21 Jump Street;' she responds "He was when I signed him, he was in his second year of 'Jump Street." Mr. Chews asks Ms. Jacobs if it would be fair to ...

say Mr. Depp was already a star at this point, or if he a star somewhat on the rise; she responds "He was on the rise. He was not a star." Mr. Chews asks Ms. Jacobs if she thought she could help Mr. Depp get to the next step of his career; she responds yes. Mr. Chews asks ...

Ms. Jacobs if this is why she sought out Mr. Depp; she responds yes. Mr. Chews asks Ms. Jacobs if she had a written contract when she signed Mr. Depp; she responds no. Mr. Chews asks Ms. Jacobs if it was an oral contract when she signed Mr. Depp; she responds yes.

Mr. Chews asks Ms. Jacobs if the oral agreement when she signed Mr. Depp was for 10%; she responds yes. Mr. Chews asks Ms. Jacobs to be more specific about what the 10% was; she responds "front end, back end." Mr. Chews asks Ms. Jacobs if she recalls testifying Mr. Depp ...

had a breakout hit w/ "Edward Scissorhands;' she responds yes. Mr. Chews asks Ms. Jacobs if 'Edward Scissorhands' was Mr. Depp's first big movie hit; she responds yes. Mr. Chews asks Ms. Jacobs how the film 'Edward Scissorhands' came about; she responds⬇️

Mr. Chews asks Ms. Jacobs if it is fair to say that she basically pushed both sides to make that happen; she responds yes. Mr. Chews asks Ms. Jacobs what, if any, impact did that have on Mr. Depp's career going forward; she responds "It made him a serious actor...

in a movie that was a hit." Mr. Chews asks Ms. Jacobs if at the time she was acting as his talent agent & making this happen, who, if anyone, was his Entertainment lawyer; she responds "I believe at that time it was Peter Nichols & Stan Coleman." Mr. Chews asks Ms. Jacobs ...

what, if any, role did Mr. Coleman or Mr. Nichols have in getting Mr. Depp the part; she responds "Lawyers don't generally involve themselves in getting the part. They are involved, at least w/ me, in getting on the phone in the very beginning when the deal starts getting ...

made. So they're involved from the moment the offer comes in & then to help me make the best deal I can." Mr. Chews asks Ms. Jacobs w/ respect to the deal on 'Edward Scissorhands,' who negotiated the deal points...the front end salary & the back end; she responds "The lawyers ...

& myself." Mr. Chew asks Ms. Jacobs if the studio came forward w/ a proposal or if the proposal originated on the Depp side; she responds "The studio or the financier comes forward w/ the proposal first & then we respond."Mr. Chew asks Ms. Jacobs who was Mr. Depp's manager, ...

if any, at the time; she responds "He didn't have one." Mr. Chew asks Ms. Jacobs if Mr. Depp had a business manager at the time; she responds "He was w/ someone named Alan Tivoli." Mr. Chew asks Ms. Jacobs if there came a time when Mr. Tivoli ceased to be Mr. Depp's ...

business manager; she responds yes. Mr. Chew asks Ms. Jacobs if the next business manager was TMG or Joel Mandel; she responds yes. Mr. Chew asks Ms. Jacobs if this was approximately 1999; she responds "That sounds about right." Mr. Chew asks Ms. Jacobs what, if any, role ...

she played in hiring Mr. Mandel/TMG; she responds "Absolutely none. Christi Dembrowski set Johnny up w/ Joel. That totally was done through her & I was told." Mr. Chew asks Ms. Jacobs if the engagement of TMG & Mr. Mandel preceded the engagement of Jacob Bloom as ...

Mr. Depp's Entertainment lawyer; she responds "Jake I believe was w/ him 17 years. I don't recall how long Joel was." Mr. Chew asks Ms. Jacobs how long Mr. Coleman & Mr. Nichols served as Mr. Depp's Entertainment lawyers; she responds "Several years...."

Mr. Chew asks Ms. Jacobs if she knows why Mr. Depp fired Mr. Coleman & Mr. Nichols; she responds "Johnny didn't like Peter Nichols." Mr. Chew asks Ms. Jacobs who Mr. Nichol's successor was; she responds "Jake Bloom." Mr. Chew asks Ms. Jacobs what, if anything, she ...

knows about the process by which Mr. Depp engaged Mr. Bloom & Bloom, Hergott; she responds "I introduced him to Jake. I had him meet two different law firms. Jake was one of them." Mr. Chew asks Ms. Jacobs who the other law firm was; she responds: "He met Jim Jackoway & ...

Alan Wertheimer." Mr. Chew asks Ms. Jacobs if she was present at the meeting w/ Christi Dembrowski & Johnny where Mr. Depp engaged Mr. Bloom; she responds "Johnny was there. I don't recall if Christi was." Mr. Chew asks Ms. Jacobs if there was any discussions at this meeting ...

regarding financial arrangements; she responds no. Mr. Chew asks Ms. Jacobs what, if any, she's aware of the financial arrangements b/n Mr. Depp & Bloom Hergott w/ respect to their serving as Mr. Depp's Entertainment counsel; she responds "I'm aware of the same thing ...

that I experience w/ every Entertainment lawyer, which is unless otherwise negotiated, it is understood that it is 5%, front & back." Mr. Chew asks Ms. Jacobs if she is an attorney; she responds no. Mr. Chew asks Ms. Jacobs if she is aware if there was ever a written ...

agreement b/n Mr. Depp & Bloom Hergott; she responds "No, I'm not." Mr. Chew asks Ms. Jacobs what, her understanding, if any, is of the scope of Bloom Hergott's duties as Mr. Depp's Entertainment lawyers; she responds ⬇️

Mr. Chew asks Ms. Jacobs how much time did Mr. Bloom spend for Mr. Depp; she responds "I can't say. I just know a lot. And it wasn't just during working hours. On weekends, vacations, & anything else, b/c he always needed & wanted something." Mr. Chew asks Ms. Jacobs if ...

Mr. Bloom was responsible for Mr. Depp's litigation; she responds "Not that I am aware of." Mr. Chew asks Ms. Jacobs if Bloom Hergott was involved in any family law matters; she responds "Not that I am aware of." Mr. Chew asks Ms. Jacobs what, if any role, did Mr. Bloom or ...

Bloom Hergott play in Mr. Depp's divorce from Ms. Heard; she responds "I have no idea." Mr. Chew asks Ms. Jacobs to explain how Mr. Depp's role in 'Pirates of the Caribbean ' came about; she responds⬇️

Mr. Chew asks Ms. Jacobs if Mr. Bloom was at that meeting; she responds no. Mr. Chew asks Ms. Jacobs if Mr. Bloom did anything to make that meeting happen; she responds no. Mr. Chew asks Ms. Jacobs if this meeting was her initiative; she responds "No. It was Jim Berkus." ...

Mr. Chew asks Ms. Jacobs if she was the one who suggested this meeting; she responds "Yes, But Jim actually set it up." Mr. Chew asks Ms. Jacobs if it is fair to say that Mr. Berkus & herself set up the meeting w/ Dick Cook that led to the first POTC film; she responds⬇️

Mr. Chew asks Ms. Jacobs if the meeting she & Mr. Berkus setup led to the first POTC film; she responds "The meeting definitely led to it, b/ it was a very complicated long transaction that was not just involving 'Pirates." Mr. Chew asks Ms. Jacobs what else it involved; she ...

responds "They wanted to make a two-picture deal w/ another movie. He & I did not want him to do, b/ we ended up making the deal b/c it was the only way to get 'Pirates.' They reduced his salary & he almost didn't do it, & I talked him into doing it b/c I said ...

what's the difference if you get $500,000 less than you think you should if you believe that this movie is such a hit, it's not going to matter." Mr. Chew asks Ms. Jacobs what the other movie was that was paired w/ 'Pirates;' she responds "I can't remember the name of it, ...

honestly. I would have to check. It was a movie that Jerry Bruckheimer was going to produce as well that they tacked on the 'Pirates' deal." Mr. Chew asks Ms. Jacobs if she was the one that convinced Mr. Depp to take this deal; she responds⬇️

Mr. Chew asks Ms. Jacobs if she talked Mr. Depp back into it; she responds yes. Mr. Chew asks Ms. Jacobs if she played a role in getting it financed; she responds "Yes. For 10 years." Mr. Chew asks Ms. Jacobs if Infinitum Nihil was created in 2004; she responds⬇️

Mr. Chew asks Ms. Jacobs how she reacted to that; she responds "I didn't think it was a good idea." Mr. Chew asks Ms. Jacobs what, if any, role did Mr. Bloom play in setting it up; she responds "We made the deal together. The moment they had agreed that Johnny wanted to do ...

this & Graham agreed to finance it, then Jake & I structured a deal." Mr. Chew asks Ms. Jacobs what, if any, opinion did Mr. Bloom express as to the wisdom of having Johnny's sister serve as President of Infinitum Nihil; she responds "I don't recall." Mr. Chew asks Ms. Jacobs ...

if she ever talked to Mr. Bloom @ it; she responds "Probably." Mr. Chew asks Ms. Jacobs how much Mr. king put up for overhead during those 3-4 years; she responds "I believe it was 3 years. I think roughly $2.5M guaranteed a year for overhead. That includes salaries, ...

offices & everything else." Mr. Chew asks Ms. Jacobs what Mr. King got out of it; she responds "'Rum Diary,' which lost $50M.

I'm taking a break for the night, b/ will continue tomorrow. Thank you for bearing w/ me as the document is 438 pages long.

Mr. Chew asks Ms. Jacobs what happened once the 3 year deal w/ Mr. King expires; she responds "He let the deal lapse." Mr. Chew asks Ms. Jacobs if she found a new funder for Infinitum Nihil; she responds yes. Mr. Chew asks Ms. Jacobs who the new funder was; she responds ...

"Warner Brothers." Mr. Chew asks Ms. Jacobs who made this new deal happen; she responds "Jake & I." Mr. Chew asks Ms. Jacobs who found Warner Brothers; she responds "Jake & I together." Mr. Chew asks Ms. Jacobs how this came about; she responds⬇️

Mr. Chew asks Ms. Jacobs if she recalls specifically what Mr. Bloom did to make it happen; she responds "Yeah. He was on the calls I was w/ whomever we dealt w/ at the time. I don't recall exactly who that was, that was some time ago, & we made a deal together, every step of ...

the way." Mr. Chew asks Ms. Jacobs if she recalls specifically what Mr. Bloom did to make 'Pirates' happen; she responds "He helped me at Warner Brothers. It involved Alan Horn, who works at Disney, & he had a great relationship w/ him. He went to Alan. And I was speaking to ...

I believe again, I could be wrong, Steve Spira, who runs business affairs for many, many, many years & together we were able to get a pretty terrific deal for three more years." Mr. Chew asks Ms. Jacobs if she is speaking about 'Pirates' now; she responds "No, I'm speaking of ...

well before 'Pirates.' Because then the deal moved to Disney." Mr. Chew asks Ms. Jacobs when she became aware of Mr. Depp's financial problems; she responds "Years ago." Mr. Chew asks Ms. Jacobs if she knew about Mr. Depp's financial problems in 2005; she responds "It ...

sounds like something I might have said in my last deposition." Mr. Chew asks Ms. Jacobs how she became aware of Mr. Depp's financial problems; she responds⬇️

Mr. Chew asks Ms. Jacobs if there came a time when she became aware of Mr. Depp's tax issues; she responds "I had heard generally about it, but no specifics." Mr. Chew asks Ms. Jacobs who apprised her about Mr. Depp's tax problems; she responds "I can't recall."

Mr. Chew asks Ms. Jacobs if it was Mr. Bloom who apprised her about Mr. Depp's tax problems; she responds "I can't recall." Mr. Chew asks Ms. Jacobs if Mr. Bloom was aware of Mr. Depp's tax problems; she responds "I don't know." Mr. Chew asks Ms. Jacobs if she knows what ...

involvement Mr. Bloom had w/ respect to Mr. Depp's taxes; she responds "I don't know." Mr. Chew asks Ms. Jacobs to explain what she did as Mr. Depp's talent agent; she responds⬇️

Mr. Chew asks Ms. Jacobs if it is fair to say she was proactive on Mr. Depp's behalf; she responds "I am on everyone's behalf." Mr. Chew asks Ms. Jacobs if she was on the lookout for scripts she thought might be good for Mr. Depp; she responds "Always."

Mr. Chew asks Ms. Jacobs what role, if any, did Mr. Bloom play in looking for scripts; she responds That's not a lawyers job." Mr. Chew asks Ms. Jacobs if a lawyers job is to negotiate & paper the deal; she responds⬇️

Mr. Chew asks Ms. Jacobs if in terms of structuring a deal, if that includes tax; she responds "I don't know. I can only say that on occasion I remember the phrase 'indemnification' being used. I can't recall which ones, b/ I had nothing to do w/ that,"

Mr. Chew asks Ms. Jacobs if she has any idea whether tax implications are ever considered in a deal; she responds " I only know from Christi who told me that he could only be...I'm trying to recall where he was living at the time...that there were tax implications for how ...

much time he spent in different countries. I have no idea how it was applied to contracts." Mr. Chew asks Ms. Jacobs if she knew whether Mr. Bloom or his law firm dealt w/ the tax implications; she responds "I don't know." Mr. Chew asks Ms. Jacobs if this would be part of ...

any financial strategy; she responds "I would assume yes, along w/ the business manager." Mr. Chew asks Ms. Jacobs what role did the business manager Joel Mandel (TMG) play w/ respect to the taxes; she responds "I don't know." Mr. Chew asks Ms. Jacobs if she knew whether ...

Mr. Depp's taxes were being paid on time; she responds "I don't know." Mr. Chew asks Ms. Jacobs if she ever became aware that Mr. Depp's taxes were paid late for 16 years in a row; she responds "I only knew he needed cash. I don't know anything about the specifics."

Mr. Chew asks Ms. Jacobs if that is something his lawyer should know; she responds "I have no idea." Mr. Chew asks Ms. Jacobs who is Don Starr; she responds "I have no idea. I've never heard that name." Mr. Chew asks Ms. Jacobs if she's aware of something that's called the ...

'Tryon loan;' she responds "I have heard of it." Mr. Chew asks Ms. Jacobs what her understanding is of a 'Tryon loan;' she responds "I don't know the specifics." Mr. Chew asks Ms. Jacobs what she knows in general terms about a 'Tryon loan;' she responds "I don't know."

Mr. Chew asks Ms. Jacobs who is Danny Watts; she responds "He's Jake's assistant." Mr. Chew asks Ms. Jacobs if she knows how the 'Tryon loan' came about; she responds no. Mr. Chew asks Ms. Jacobs if she ever spoke to Mr. Bloom about it; she responds "Only in the vagaries ...

of knowing he needed cash, b/ never insofar as Tyron who I had never heard of." Mr. Chew asks Ms. Jacobs if Mr. Depp got cash out of this deal; she responds "I have no idea." Mr. Chew asks Ms. Jacobs if she ever at any time had a discussion w/ Mr. Depp in which he said in ...

words or substance that the back end, his residuals were for his children; she responds "He talked about how he made movies for his children so he could leave them something. We never talked about it in that way." At this juncture Mr. Chew shows Ms. Jacobs Exhibit 172....

Mr. Chew says this is a document that wasn't copied to Ms. Jacobs & has her look at the 2nd page. It is an executive summary Tyron Scaramanga. Mr. Chew directs Ms. Jacobs to where it says "to the advisers." Mr. Chew asks Ms. Jacobs if she sees where it lists the loan proceeds ...

to The Management Group; she responds yes. Mr. Chew then verifies w/ Ms. Jacobs The Management Group (TMG) is Mr. Depp's business manager & that Bloom Hergott is Mr. Bloom's firm. Mr. Chew asks Ms. Jacobs based on Exhibit 172 showing a payout to Mr. Bloom w/ a 5%, if she ...

knows what the 5% represents; she responds no. Mr. Chew asks Ms. Jacobs if she sees the entry for United Talent Agency (UTA); she responds "Yes, I see that." Mr. Chew asks Ms. Jacobs if that's her; she responds "Yes, I guess." Mr. Chew asks Ms. Jacobs if 10% was the amount ...

of commission that she took; she responds "Yes. But I have never seen these documents before." Mr. Chew asks Ms. Jacobs if she has any understanding that UTA was getting 10% of the proceeds; she responds "Not from this." Mr. Chew asks Ms. Jacobs if she has any understanding ...

that UTA was getting 10% from any source; she responds "I understood that...as, one,...I understood, however, some of the back ends were pledged, that we would be receiving commission owed on them for the money, I guess, he took." Mr. Chew asks Ms. Jacobs if she knows if he ...

got any money out of this; she responds "I assume. I don't know." Mr. Chew asks Ms. Jacobs if she knows UTA got its money; she responds yes. Mr. Chew asks Ms. Jacobs if she knows Bloom got its money; she responds "You're asking me something I really don't know about. I can ...

only speak for myself. Mr. Chew asks Ms. Jacobs if she believes Mr. Bloom didn't take his 5%; she responds "I have no idea." Mr. Chew then directs Ms. Jacob to the next page of Exhibit 172. Mr. Chew says it purports to show certain payments being made to the advisors on or @ ...

January 15, 2015; that The Management group received a payment on February 1, 2015. Mr. Chew asks Ms. Jacobs if she has any reason to believe that didn't take place; she responds no. Mr. Chew asks Ms. Jacobs if she has any reason to believe Bloom Hergott didn't receive a ...

payment; she responds "I don't know. I have no idea." Mr. Chew asks Ms. Jacobs if she sees the entry for January 15th, January 21st 2015 $108,000; she responds yes. Mr. Chew asks Ms. Jacobs if she has any reason to believe UTA didn't receive payment; she responds "I can't ...

recall. I don't disbelieve it, b/ I don't know." Mr. Chew asks Ms. Jacobs if she sees anything that shows any money whatsoever going to Mr. Depp; she responds "Not according to this document." Mr. Chew asks Ms. Jacobs if she has any other reason, independent of that ...

document, to think that Mr. Depp got anything out of this loan; she responds "I don't know." Mr. Chew asks Ms. Jacobs which of Mr. Depp's films were pledged; she responds "I believe it was mostly...and I don't know exactly...that it was several of the 'Pirates' movies, ...

'Alice in Wonderland' & 'Into the Woods.' Mr. Chew asks Ms. Jacobs what the basis is for her understanding; she responds "I can't recall who told me. It could have been Jake." Mr. Chew asks Ms. Jacobs what she was told about it; she responds⬇️

Mr. Chew asks Ms. Jacobs if she spoke to Mr. Depp about this; she responds no. Mr. Chew asks Ms. Jacobs why she didn't speak to Mr. Depp about this; she responds "No reason to." Mr. Chew asks Ms. Jacobs if it wasn't her job to speak to Mr. Depp about this; she responds ...

"Well, it's a money matter. I would have assumed it would be his business manager." Mr. Chew asks Ms. Jacobs if Mr. Bloom had any obligation to counsel his client, Mr. Depp, about this; she responds "I have no idea." Mr. Chew asks Ms. Jacobs if she knows who set up this deal; ...

she responds no. Mr. Chew then shows Ms. Jacobs Exhibit 212 which he says is the execution version of the Tyron Management Services Limited agreement. Mr. Chew asks Ms. Jacobs if she's ever seen this documents; she responds no. Mr. Chew then shows her Exhibit 242, an email ...

from Ms. Jacobs to Ms. Dembrowski dated January 30, 2013. Mr. Chew asks Ms. Jacobs if she's ever seen this before; she responds "I seem to have responded to it. I can't recall it now, b/ yeah, it sounds familiar. Mr. Chew asks Ms. Jacobs what the email pertains to; she ...

responds "Well, if you notice, it wasn't me who wrote it. It was Lisa Jacobson who at the time ran our endorsement department...and this was an offer she was trying to secure from Louis Vuitton for his commercial services." Mr. Chew asks Ms. Jacobs if it was Ms. Jacobson ...

who initiated this potential deal; she responds "This particular deal, yes, b/ I had been asking her to please find something." Mr. Chew asks Ms. Jacobs what role, if any, did Mr. Bloom play in obtaining this opportunity; she responds⬇️

Mr. Chew asks Ms. Jacobs if she knows why it didn't come to fruition; she responds "Because Louis Vuitton didn't want to pay us." Mr. Chew then shows Ms. Jacobs Exhibit 243, an email from Ms. Jacobs to a group of people, including Mr. Bloom, dated February 11, 2014.

Mr. Chew asks Ms. Jacobs what this exchange is @; she responds "About a movie that was at Lionsgate called 'The Secret Life of Houdini." Mr. Chew asks Ms. Jacobs who originated this opportunity; she responds "I did." Mr. Chew asks Ms. Jacobs how this came about; she responds⬇️

Mr. Chew asks Ms. Jacobs what the offer was & what the upfront payment & back end payment was; she responds (look at how she answers the Mr. Chew right after)⬇️

Mr. Chew asks Ms. Jacobs why this deal did not come to fruition; she responds "Because Johnny hemmed & hawed about doing it b/c they could never get the script right & ultimately Lionsgate never made the movie." Mr. Chew asks Ms. Jacobs if she pushed Mr. Depp to make the ...

deal; she responds "Yes. Because it was a development deal. It was for a lot of money & I just felt we could use that as an opportunity w/ other people. Was I crazy about it? No. But I thought that it was a good thing to have on our plate."

Mr. Chew asks Ms. Jacobs if Mr. Bloom expressed the same opinion, that it was something Mr. Depp should do; she responds⬇️

Mr. Chew asks Ms. Jacobs what did Michael Schenkman & Mr. Bloom do, since you were handing it over to them; she responds⬇️

Mr. Chew asks Ms. Jacobs if she knows what, if anything, Mr. Schenkman & Mr. Bloom did after that; she responds "I don't remember exactly, b/ they were in the process of dealing w/ Patricia." Mr. Chew shows Ms. Jacobs Exhibit 244, an email from Ms. Jacobs to a number of people.

Mr. Chew asks Ms. Jacobs if she's ever heard of Cross Creek Pictures; she responds "Yes. They were involved in the financing of this movie before it was set up at Warner Brothers. And actually...oh Adam Kassan. I don't remember him. Mr. Chew says "So, it appears in the email ...

at the bottom of this page, that Mr. Kassan is stating Johnny Depp is committed to acting in the film 'Black Mass,' playing the role of Whitey Bulger." Mr. Chew asks Ms. Jacobs if she disagrees w/ this; she responds⬇️

Mr. Chew then shows Ms. Jacobs Exhibit 245. Mr. Chew asks Ms. Jacobs who is Patrick Knapp; she responds "I don't remember. I'm looking at this & I cannot remember." Mr. Chew asks Ms. Jacobs is that Schwarzenegger; she responds "What." Mr. Chew asks Ms. Jacobs if Mr. Knapp ...

was a partner of Mr. Bloom; she responds "I don't know. I literally have no recollection about who that is." Mr. Chew asks Ms. Jacobs what is a perk list; she responds⬇️

Mr. Chew asks Ms. Jacobs if the perk list changes materially from film to film; she responds "Yes, depending on the budget." Mr. Chew asks Ms. Jacobs if there are common elements of the perk list; she responds yes.

Mr. Chew asks Ms. Jacobs if each perk list had to be drafted from scratch or were prior perk lists used as templates; she responds⬇️

Mr. Chew says, Mr. Knapp in writing you Ms. Jacobs says "Please see attached perk list modified in accordance w/ our CC earlier today." Mr. Chew asks Ms. Jacobs what role, if any, did she play in preparing the perk list; she responds "None." Mr. Chew asks Ms. Jacobs if she ...

has any idea why Mr. Knapp sent this to her; she responds "No. Because I was his agent." Mr. Chew directs Ms. Jacobs to the next page, which is the first page of the perk list, noting it says "personal hairdresser." Mr. Chew asks Ms. Jacobs why Mr. Depp would need a ...

'personal hairdresser' for an animated film; she responds "I can't see why, b/ they asked, so I guess more power to them." Mr. Chew asks Ms. Jacobs where 'Rango' was filmed; she responds "I believe in Los Angeles. That sounds right. I'm not 100% sure." Mr. Chew directs ...

Ms. Jacobs to a reference to business class round trip air travel from the UK. Mr. Chew asks Ms. Jacobs why would this be necessary on a perk list for a film that was filmed in Los Angeles; she responds⬇️

Mr. Chew directs Ms. Jacobs to page 4, where it says "doubling nudity," where it reads "There shall be no nudity or sex scenes featuring JD and/or double." Mr. Chew asks Ms. Jacobs if this would be applicable to an animated film; she responds "Doesn't seem so."

Mr. Chew asks Ms. Jacobs if it would be applicable w/ respect to hair, makeup & wardrobe; she responds⬇️

Mr. Chew asks Ms. Jacobs from what undergraduate institution did she graduate; she responds "Austin University." Mr. Chew asks Ms. Jacobs if she has any graduate degrees; she responds no. Mr. Chew asks Ms. Jacobs her major; she responds "Medieval history & art history."

Mr. Chew asks Ms. Jacobs what she did before joining ICM professionally; she responds "I worked for a company called Triad, which no longer exists." Mr. Chew asks Ms. Jacobs what her position was at Triad; she responds "I was an agent." Mr. Chew asks Ms. Jacobs how many years ...

she worked at Triad; she responds "3 or 4." Mr. Chew asks Ms. Jacobs if this was her first job out of college; she responds no. Mr. Chew asks Ms. Jacobs what was her first job after graduating college; she responds "First job out of college, I was a writer at Leo Burnett in ...

Chicago. It's an ad agency. The first agency was an agency that no longer exists named Jack Rose Dorothy Deotis. It no longer exists." Mr. Chew verifies w/ Ms. Jacobs that Christi Dembrowski is Mr. Depp's sister & that she became President of Infinitum Nihil.

Mr. Chew asks Ms. Jacobs how she met Ms. Dembrowski; she responds "I can't recall. Probably a couple of years...she was his assistant when I first came in. I don't even think...she was working for Sony in some capacity & then w/in a couple of years she became his assistant."

Mr. Chew asks Ms. Jacobs what was Ms. Dembrowski's role was when she first starting interacting w/ her; she responds "To be his assistant taking care of travel & things that he needed, like most assistants." Mr. Chew asks Ms. Jacobs if Ms. Dembrowski's role as assistant ...

changed over time; she responds yes. Mr. Chew asks Ms. Jacobs how Ms. Dembrowski's role changed; she responds "She became more managerial." Mr. Chew asks Ms. Jacobs approximately when this happened; she responds "A couple of years of her being an assistant."

Mr. Chew asks Ms. Jacobs what she specifically means when she says Ms. Dembrowski became more managerial; she responds "She wanted to control every aspect of everything." Mr. Chew asks Ms. Jacobs on what basis did she form this opinion; she responds⬇️

Mr. Chew asks Ms. Jacobs if Ms. Dembrowski was her client; she responds no. Mr. Chew asks Ms. Jacobs if she would rely on Ms. Dembrowski's decisions or the decisions of her client Mr. Depp; she responds⬇️

Mr. Chew asks Ms. Jacobs if she ever discussed this w/ Mr. Bloom; she responds yes. Mr. Chew asks Ms. Jacobs if she ever had discussions about her inability to get a hold of Mr. Depp; she responds "I expressed my frustration." Mr. Chew asks Ms. Jacobs if Mr. Bloom expressed a ...

similar frustration; she responds "No. He didn't have that issue w/ Christi." Mr. Chew asks Ms. Jacobs why she says that; she responds⬇️

Mr. Chew asks Ms. Jacobs how she knows Ms. Dembrowski was different w/ Mr. Bloom; she responds⬇️

Mr. Chew asks Ms. Jacobs if Ms. Dembrowski was a client of Mr. Bloom; she responds no. Mr. Chew reminds Ms. Jacobs of their earlier discussion @ when Mr. Depp hired Mr. Bloom to be his Entertainment counsel, that the competition was w/ Alan Wertheimer & Jim Jackoway.

Mr. Chew asks Ms. Jacobs why she thought Mr. Bloom was a better fit for Mr. Depp; she responds "And I think he was the better fit personality wise and talent wise for who Johnny Depp is as a particular individual." Mr. Chew asks Ms. Jacobs to please elaborate; she responds⬇️

Mr. Chew asks Ms. Jacobs if she & Mr. Bloom have any clients in common; she responds "Not at that time." Mr. Chew asks Ms. Jacobs did there come a time she & Mr. Bloom had client's in common; she responds yes. Mr. Chew asks Ms. Jacobs how she would describe Bloom Hergotts role...

in Mr. Depp's career; she responds "I think I've said that several times in several different ways, b/ I'll just say again. Jake was involved from the inception of every deal making process. All deals, every deal." Mr. Chew asks Ms. Jacobs if Mr. Bloom originated any deal ...

for Mr. Depp w/ respect to work; she responds "I can't recall. That's not his job." Mr. Chew asks Ms. Jacobs if it wasn't Mr. Bloom's job to get the 'Tryon loan;' she responds "I have no idea." Mr. Chew asks Ms. Jacobs if she & Mr. Bloom ever discussed the subject of conflicts...

of interest where Mr. Depp was concerned; she responds no. Mr. Chew asks Ms. Jacobs if Bloom Hergott was to be Mr. Depp's lawyers on everything; she responds "Again, I keep feeling like I repeat this, I'll say it in different words. They were involved in step one of every ...

deal making process through the end." Mr. Chew asks Ms. Jacobs if they were a full service law firm; she responds "Well, full service to the extent of, again, I'll say it, structure & strategy of all of the deal making." Mr. Chew asks Ms. Jacobs if they handled all of the ...

deals; she responds yes. Mr. Chew asks Ms. Jacobs if Bloom Hergott represented Infinitum Nihil; she responds ⬇️

Mr. Chew asks Ms. Jacobs when she attended the original meeting to hire Mr. Bloom, if there was any discussion of a limitation on the representation; she responds "No. Not that I can recall." Mr. Chew shows Ms. Jacobs Exhibit 246. Mr. Chew asks Ms. Jacobs what this ...

document is; she responds⬇️

Mr. Chew asks Ms. Jacobs if she knows, what is stated by Mr. Sinclair is true & accurate; she responds yes. Mr. Chew reiterates her earlier in the prior case (TMG) testimony confirming UTA received $65M; 10% of the $650M. Mr. Chew asks Ms. Jacobs if UTA retained certain ...

future rights; she responds yes. Mr. Chew asks Ms. Jacobs to explain those future rights; she responds "All the movies I had negotiated w/ Jake, prior to his terminating me, which were many he had finalized deals on." Mr. Chew asks Ms. Jacobs if in addition to the $650M ...

received would there be many millions more in the future; she responds yes. Mr. Chew clarifies it's not $650M, b/ $65M & Ms. Jacobs again answers "Yes. For several years to come." Mr. Chew asks Ms. Jacobs if this includes series like 'Fantastic Beasts;' she responds yes.

Mr. Chew asks Ms. Jacobs to look at the attachment to Mr. Sinclair's letter, which is Exhibit A to that letter, a complete list of the projects Ms. Jacobs & UTA brought to Mr. Depp, then asks Ms. Jacobs if she & UTA are entitled to 10% commission; she responds "I believe so."

Mr. Chew asks Ms. Jacobs if to her knowledge, did anyone respond to Mr. Sinclair's letter disputing any of the projects; she responds "As Far as I know, there was not a response. I'd have to look at Michael Sinclair for that." Mr. Chew asks Ms. Jacobs if it has been discussed...

that there will be or might be 'Fantastic Beasts' films beyond part 3, b/c this list goes to 4 & 5; she responds yes. Mr. Chew asks Ms. Jacobs on what basis is she saying there will be a 'Fantastic Beasts' 3, 4, & 5; she responds "They've been discussed w/ Johnny, his ...

representatives and Warner Brothers. Does that guarantee them? No. If they get made, yes." Mr. Chew asks Ms. Jacobs when the last time is she spoke w/ Mr. Depp; she responds "2 years & 7 months ago." Mr. Chew asks Ms. Jacobs was the last time she spoke to him, the ...

10/27/16, when he fired her; she responds "That's when he slammed the phone down on me & woke me up in the middle of the night." Mr. Chew asks Ms. Jacobs, since she said in her previous deposition (TMG) Mr. Depp was generous where she was concerned & asks if this correct; ...

she responds "Some. Sometimes." Mr. Chew asks Ms. Jacobs if it is true that she asked Mr. Depp to buy her gifts that were worth more than $10,000; she responds "Sometimes." Mr. Chew asks Ms. Jacobs why she would do that; she responds⬇️

Mr. Chew asks Ms. Jacobs she's saying it was reciprocal; she responds yes. Mr. Chew asks Ms. Jacobs if there were occasions on which she asked Mr. Depp to buy her particular gifts; she responds "In a joking manner, yes." Mr. Chew asks Ms. Jacobs notwithstanding the joking ...

aspect of it, did Mr. Depp comply; she responds "Occasionally." Mr. Chew shows Ms. Jacobs Exhibit 247, an email from Ms. Jacobs to Mr. Bloom & his assistant & some other people. Mr. Chew then reads "Joel has given me permission to ask for advance per tax situation."

Mr. Chew asks Ms. Jacobs if she recalls what this is about; she responds "No. Probably just needed some money, for whatever it was, taxes or anything else. And in every deal, I was virtually asking for advances, including the last 'Fantastic Beast."

Mr. Chew asks Ms. Jacobs if this refreshes her recollection about what role, if any, Mr. Bloom had w/ respect to Mr. Depp's tax situation; she responds "No. Frankly, it seems like a Joel Mandel issue." Mr. Chew asks Ms. Jacobs why she was sending this email to Mr. Bloom; she ...

doesn't respond due to an objection from her lawyer. Mr. Chew then shows Ms. Jacobs Exhibit 248, an email exchange b/n Ms. Jacobs & Ms. Dembrowski. Mr. Chew reads a portion of the email: "We're going to deal w/ Shep on money of the 'Vampires.' I talked to Jay @ it. Shep is ...

ripping him off." Mr. Chew asks Ms. Jacobs who Shep is; she responds "Shep Gordon manages Alice Cooper." Mr. Chew asks Ms. Jacobs what she was conveying when she said Shep is ripping him off; she responds⬇️

Mr. Chew asks Ms. Jacobs if she discussed these concerns w/ Mr. Bloom; she responds yes. Mr. Chew asks Ms. Jacobs when she spoke to Mr. Bloom about these concerns; she responds "At the time I'm sure very close to this memo." Mr. Chew asks Ms. Jacobs what was the substance of ...

her conversation w/ Bloom about her concerns; she responds "Exactly what I just said to you." Mr. Chew asks Ms. Jacobs how Mr. Bloom responded to her concerns; she responds⬇️

Mr. Chew asks Ms. Jacobs if she has any idea if Mr. Bloom agree w/ her concerns; she responds "He understood what I was saying, b/ he wasn't controlling it. It was all Christi." Mr. Chew asks Ms. Jacobs if Mr. Bloom is an Entertainment lawyer; she responds "This is a music issue"

Mr. Chew asks Ms. Jacobs is music entertainment; she responds "Right. They have an Entertainment lawyer named Candace." Mr. Chew asks Ms. Jacobs if this is Candace Hanson; she responds "I think she was involved in this w/ Jake." Mr. Chew asks Ms. Jacobs what steps ...

Ms Hanson & Mr. Bloom took to rein this in; she responds "I have no idea." Mr. Chew asks Ms. Jacobs what steps, if any, Ms. Hanson, Mr. Bloom, Bloom Hergotts took w/ respect to her concern Shep was ripping him off; she responds⬇️

Things get heated b/n Mr. Chew & Mr. Freedman.

Mr. Chew reads another portion of Ms. Jacobs email to Ms. Dembrowski: "I feel really bad that you think I don't. Mr. Chew asks Ms. Jacobs what she is telling Ms. Dembrowski here; she responds⬇️

Mr. Chew asks Ms. Jacobs if she thought she was doing right by her client Mr. Depp; she responds "Correct." Mr. Chew asks Ms. Jacobs if she was doing it even though it was making her unpopular; she responds "Correct." Mr. Chew asks Ms. Jacobs if she did it b/c she cared @ ...

Mr. Depp & it is something she would do for her client; she responds "Correct." Mr. Chew reads another part of the email from Ms. Jacobs to Ms. Dembrowski: "Why don't you ask Jake." Mr. Chew asks Ms. Jacobs why she said this to Ms. Dembrowski; she responds "I must have said ...

to Jake what I just said to you, which is that I was concerned @ this." Mr. Chew asks Ms. Jacobs shouldn't Mr. Bloom have been doing the same thing; she responds "I don't know." Mr. Chew asks Ms. Jacobs if she knows what specifically Candace Hanson did w/ respect to Johnny's ...

music activities; she responds "No, I don't." Mr. Chew asks Ms. Jacobs if she knows how much time Ms. Hanson spent; she responds "No, I don't." Mr. Chew asks Ms. Jacobs if she's ever spoken to Ms. Hanson; she responds 'Maybe once or twice over the years."

Mr. Chew asks Ms. Jacobs if she ever spoke to Mr. Bloom about Ms. Hanson; she responds yes. Mr. Chew asks Ms. Jacobs what the nature of these discussions w/ Mr. Bloom; she responds⬇️

Mr. Chew says, And you're saying "What are you doing," w/ 5 question marks; she responds "I'm saying that's never going to happen." Mr. Chew asks Ms. Jacobs if she discussed this w/ Mr. Bloom; she responds "I'm sure I did." Mr. Chew asks Ms. Jacobs if she recalls how ...

Mr. Bloom responded; she responds "No, I don't remember." Mr. Chew asks Ms. Jacobs how many 'Tryon loans;' she responds "I have no idea." Mr. Chew asks Ms. Jacobs if this was before or after the first 'Tryon loan;' she responds "I have no idea." Mr. Chew shows Ms Jacobs ...

Exhibit 250. Mr. Chew asks Ms. Jacobs who if Andre Thau; she responds "He is our COO of UTA." Mr. Chew asks Ms. Jacobs when Mr. Thau is telling you in Thursday, September 10, 2015: "I have the person for Jake to speak with," if she has any idea what he is referring to here; ...

she responds "I have an idea, although, I might be wrong that it had to do ...⬇️

Mr. Chew asks Ms. Jacobs who is Fahar; she responds⬇️

Mr. Chew asks Ms. Jacobs on what basis are you asserting he is a fraud; she responds "Everything he said & none of it came to pass." Mr. Chew asks Ms. Jacobs what did he say that didn't come to pass; she responds⬇️

Mr. Chew shows Ms. Jacobs Exhibit 251, an email from Ms. Jacobs to Ms. Dembrowski RE: 'The Ginger Man.' Mr. Chew asks Ms. Jacobs what 'The Ginger Man' refers to; she responds⬇️

Mr. Chew says "And you're telling Christi on March 24: 'How do you want to deal w/ this? I don't want to get involved w/ the bank.'" Mr. Chew asks Ms. Jacobs what she is referring to; she responds⬇️

Mr. Chew asks Ms. Jacobs if Ms. Dembrowski replied to her question: " How do you want to deal with this?;" she responds "According to this, no." Mr. Chew asks Ms. Jacobs when she wrote this to Ms. Dembrowski, "I don't want to get involved w/ the bank," what she was ...

intending to convey; she responds "What I was conveying is that I don't trust Fahar. This is a terrible way of doing business & he's a liar." Mr. Chew shows Ms. Jacobs Exhibit 252, an email from Ms. Jacobs to Mr. Bloom, Ms. Dembrowski, Mr. Mandel & Michael Schenkman.

Mr. Chew asks Ms. Jacobs you say "Crossed to $208M!" what does this refer to; she responds "The worldwide gross of the movie." Mr. Chew asks Ms. Jacobs if this is in reference to 'Into the Woods;' she responds yes. Mr. Chew asks Ms. Jacobs you say "Japan was huge;" she ...

responds "It was a huge territory that did well for the movie." Mr. Chew asks Ms. Jacobs you say "We are owed some back end!" what were you referring to there; she responds "We were owed some back end & we were paid some back, which continues to pay." Mr. Chew shows ...

Ms. Jacobs Exhibit 253, an email from Ms. Jacobs to people at Lionsgate. Mr. Chew asks Ms. Jacobs who are Mr. Friedman & Mr. Feig; she responds "Rob Friedman at the time was the Chairman of Lionsgate. He no longer is. And Eric Feig, I believe, was the President & he no longer is"

Mr. Chew asks Ms. Jacobs if she is telling them Mr. Depp thinks the script is great; she responds "No. I'm telling them that Gwyneth Paltrow thinks it is. That says 'GP Mortdecai,' who starred in the movie w/ Johnny." Mr. Chew asks Ms. Jacobs you said that Johnny took a ...

financial haircut. What are you referring to here; she responds "That Johnny didn't get paid $20M; he got $15M w/ a back end instead." Mr. Chew asks Ms. Jacobs what was the purpose of sending this email; she responds⬇️

Mr. Chew asks Ms. Jacobs what Mr. Bloom did; she responds "Jake was very close to Robby Friedman & was very helpful & we set it up together very quickly." Mr. Chew asks Ms. Jacobs if the deal did get done; she responds "Yes. The movie got made." Mr. Chew asks Ms. Jacobs ...

when she first met Mr. Bloom; she responds "I don't recall exactly." Mr. Chew asks Ms. Jacobs what do you recall about first meeting Mr. Bloom; she responds "Must have been 20 or so years ago." Mr. Chew asks Ms. Jacobs if she remembers the occasion on which you met Mr. Bloom;...

she responds no. Mr. Chew asks Ms. Jacobs what matters, if any, have you worked on w/ Mr. Bloom at Bloom Hergott besides those involving Mr. Depp; she responds "I worked on another client w/ him, b/ many, many years after he signed Johnny Depp." Mr. Chew asks Ms. Jacobs ...

if it was just one; she responds "Uh-huh." Mr. Chew asks Ms. Jacobs how many client's she's had in common w/ Mr. Bloom; she responds "I just have one." Mr. Chew asks Ms. Jacobs When you were working w/ Mr. Depp, how often would you meet w/ Mr. Bloom over the years; she ...

responds "Not often." Mr. Chew asks Ms. Jacobs if it was just when they had a deal; she responds "Yes. Or we had an occasional lunch. Most of it was done on the phone." Mr. Chew asks Ms. Jacobs if she emailed w/ Mr. Bloom; she responds yes. Mr. Chew asks Ms. Jacobs how often; ...

she responds "Depending on what we were doing, could have been every day." Mr. Chew asks Ms. Jacobs if she ever texted w/ Mr. Bloom; she responds no. Mr. Chew asks Ms. Jacobs if Mr. Bloom did not text; she responds⬇️

Mr. Chew asks Ms. Jacobs how often, if at all, did she see Mr. Bloom socially; she responds "Occasionally." Mr. Chew asks Ms. Jacobs how many times a year she socialized w/ Mr. Bloom; she responds "2 or 3." Mr. Chew asks Ms. Jacobs when she last saw or spoke w/ Mr. Bloom; she ...

responds "It might have been an art opening in the last 6 months. I don't remember exactly." Mr. Chew asks Ms. Jacobs what, if anything, did she discuss w/ Mr. Bloom; she responds "Nothing." Mr. Chew asks Ms. Jacobs if she just said hello; she responds "Yeah. How are you?"

Mr. Chew asks Ms. Jacobs if she's ever discussed this litigation w/ Mr. Bloom; she responds no. Mr. Chew asks Ms. Jacobs if she's ever discussed the TMG litigation w/ Mr. Bloom; she responds no. Mr. Chew asks Ms. Jacobs since being dismissed by Mr. Depp, what conversations ...

she's had w/ Mr. Bloom @ Mr. Depp; she responds "I try not to. I don't think I have, other than when he first dismissed me. He had not fired Jake; he fired me." Mr. Chew asks Ms. Jacobs what conversations she had w/ Mr. Bloom after Mr. Depp fired her; she responds⬇️

Mr. Chew asks Ms. Jacobs how Mr. Bloom responded; she responds "He hadn't been fired, so I didn't get into it w/ him. Mr. Chew asks Ms. Jacobs what did Mr. Bloom say @ whether he knew whether she had been dismissed; she responds "He said he felt terrible."

Mr. Chew asks Ms. Jacobs if Mr. Bloom said her knew she had been dismissed; she responds "It sounded like he did." Mr. Chew asks Ms. Jacobs why Mr. Bloom hadn't given her a heads up about the dismissal; she responds "I don't think he knew." Mr. Chew says to Ms. Jacobs I ...

I thought you said you thought he did know about it; she responds "No. I think he knew after the fact. I think the person that knew was Ed White who did not give me the heads-up." Mr. Chew asks Ms. Jacobs when she first met Joel Mandell she responds "When Christi hired him....

I don't know how long he was w/ Johnny. That's the one I know least about." Mr. Chew asks Ms. Jacobs if she's worked on any matters w/ Mr. Mandel besides Mr. Depp; she responds no. Mr. Chew asks Ms. Jacobs how often she would meet w/ Mr. Mandel; she responds "Rarely."

Mr. Chew asks Ms. Jacobs how often she would speak to Mr. Mandel; she responds "Not very often. Everything was in email. You see where he's copied." Mr. Chew asks Ms. Jacobs if she ever had any meetings where Mr. Mandel & Mr. Bloom, as well as herself were all present; she ...

responds "Not that I can recall." Mr. Chew asks Ms. Jacobs if when she was representing Mr. Depp, if she ever worked w/ any attorneys other than Bloom Hergott; she responds yes. Mr. Chew asks Ms. Jacobs what other attorneys she's worked w/ while representing Mr. Depp; she ...

responds "Blair Burke & Laura Wasser." Mr. Chew asks Ms. Jacobs what Mr. Burke & Ms. Wasser were doing for Mr. Depp; she responds "During his divorce action, Blair Burke was his criminal lawyer & Laura Wasser was his divorce lawyer." Mr. Chew asks Ms. Jacobs if other than ...

Ms. Blair & Ms. Wasser if she'd ever worked w/ any other lawyers for Mr. Depp other than Bloom Hergott; she responds "No. Not that I can recall." Mr. Chew asks Ms. Jacobs if she ever spoke to Marty Singer in connection w/ Mr. Depp; she responds "I did speak to him very ...

occasionally, yes." Mr. Chew asks Ms. Jacobs what services Mr. Singer provided for Mr. Depp; she responds "I don't know. I didn't hire him, but I presume it was to defend Johnny in some litigation." Mr. Chew asks Ms. Jacobs if she knows the particulars of the litigation; she ...

responds no. Mr. Chew asks Ms. Jacobs if she has any dealings w/ any other lawyers for Mr. Depp other than Ms. Burke, Ms. Wasser, Mr. Singer & Bloom Hergott; she responds "Not that I remember, b/ maybe there is someone. I literally have no recollection."

Mr. Chew asks Ms. Jacobs what, if anything, did Mr. Bloom or Bloom Hergott do in connection w/ Mr. Depp's divorce; she responds "I have no idea. I never spoke to Jake about the divorce." Mr. Chew clarifies w/ Jacobs that she didn't know what Mr. Bloom did or did not do in ...

connection w/ Mr. Depp's divorce; she responds "No. I only spoke to Laura Wasser, Blair Burke & Christi Dembrowski." Mr. Chew shows Ms. Jacobs Exhibit 206. Mr. Chew asks Ms. Jacobs who prepared this first draft of the executed deal for the first 'Pirates' film; she responds ...

"Disney." Mr. Chew asks Ms. Jacobs to whom did Disney present this draft; she responds "To Jake." Mr. Chew asks Ms. Jacobs if to her knowledge if it was Disney which came up w/ the front end & back end; she responds "Correct. But this isn't the deal that ended up being agreed ...

to. That's why Johnny was so upset." Mr. Chew asks Ms. Jacobs if the financial terms stayed the same from the beginning to the end; she responds no. Mr. Chew asks Ms. Jacobs how the financial terms changed; she responds⬇️

Mr. Chew asks Ms. Jacobs if the clause in the draft is a standard clause; she responds "Seems to be." Mr. Chew asks Ms. Jacobs if the clause changed going forward; she responds "I'm not a lawyer. I have no idea." Mr. Chew shows Ms. Jacobs Exhibit CB. Mr. Chew asks Ms. Jacobs ...

if she knows what this is about; she responds "This is not something ordinarily that I would be dealing with." Mr. Chew asks Ms. Jacobs what she would be dealing with; she responds⬇️

Mr. Chew asks Ms. Jacobs if there were calls on which these terms were discussed; she responds "Endless." Mr. Chew asks Ms. Jacobs if she was party to these calls; she responds yes. Mr. Chews says "But sitting her today, you don't recall." Ms. Jacobs responds "Oh I don't ...

recall this particular exhibit, no." Mr. Chew asks Ms. Jacobs which lawyers from Bloom Hergott were involved in the negotiation of this deal as it went forward; she responds "Jake, Michael Schenkman" Mr. Chew shows Ms. Jacobs Exhibit 207 & asks if she's ever seen this ...

document before; she responds "I'm sure I have." Mr. Chew asks Ms. Jacobs what the document pertains to; she responds "It's an acting agreement b/n the Walt Disney Corporation & Johnny for his services on 'Alice in Wonderland.' Mr. Chew asks Ms. Jacobs if the first draft came ...

from Disney; she responds "Yep." Mr. Chew asks Ms. Jacobs what she remembers about the negotiations going forward for this film; she responds "The deal here is what we made. There might be changes that I can't define by looking at all of this." Mr. Chew asks Ms. Jacobs ...

"But, unlike "Alice' where you recalled the deal changed over time...Ms. Jacobs interrupts saying "Because he was an enormous star by the time 'Alice'...the deal was made. It was much easier to make the deal. Mr. Chew asks Ms. Jacobs how much time it took to finalize the ...

deal from the time it was first sent to the time it was finalized; she responds "I have no idea." Mr. Chew asks Ms. Jacobs if Mr. Bloom & Mr. Schenkman were the lawyers at Bloom Hergott involved in the deal; she responds "Correct." Mr. Chew asks Ms. Jacobs w/ respect to the ...

back end, how UTA calculates its 10% interest; she responds "We collect 10% of all his receivables." Mr. Chew asks Ms. Jacobs if this is the audit process; she responds⬇️

Mr. Chew asks Ms. Jacobs if UTA does any of its own independent auditing; she responds "I have nothing to do w/ an auditing process as far as checks being sent to UTA. They didn't come from us." Mr. Chew asks Ms. Jacobs if she's on the Board of Directors of the UTA; she ...

responds "Yes. But I don't think if you asked any Board Member, they could explain to you the audit process b/n the business manager & the agent." Mr. Chew asks Ms. Jacobs if UTA independently verifies the back end compensation; she responds⬇️

Mr. Chew asks Ms. Jacobs who, if anyone, at Bloom Hergott performed that function w/ respect to Johnny's film; she responds "Jake's not an auditor." Mr. Chew asks Ms. Jacobs what about Michael Schenkman; she responds⬇️

Mr. Chew asks Ms. Jacobs who makes the decision to engage an auditor; she responds "In this case I really don't know, b/ I know they audited as a group several time & I'm sure still are." Mr. Chew asks Ms. Jacobs if she is not familiar that Mr. Schenkman played that role ...

at Bloom Hergott for Mr. Depp; she responds "I have no idea. I don't know." Mr. Chew asks Ms. Jacobs if Mr. Schenkman ever sent her any reminder notices concerning deadlines @ the audit process; she responds "Never. Neither has any lawyer." Mr. Chew asks Ms. Jacobs if she ...

has any idea of how many hours Mr. Bloom or Bloom Hergott would spend on a particular deal; she responds "No. But I can only imagine Johnny Depp took more hours than all of his clients combined." Mr. Chew asks Ms. Jacobs what the basis is for her opinion; she responds ...

"Because I know how much time & life force he drained from all of us." Mr. Chew asks Ms. Jacobs if she knows all of Bloom Hergott's clients; she responds no. Mr. Chews says "So you don't know how much life force that any one of them may have drained; she responds "I guess you ...

could say speculation."

😂This is priceless Benjamin Chew, who clearly doesn't get along w/ Mr. Freedman. Who could have guessed Mr. Depp's litigation would have taken a Star Wars turn. May the Force be w/ Mr. Chew & Mr. Depp!

Mr. Chew asks Ms. Jacobs if she has any idea of how long it would take to modify a perk list for a particular film; she responds "No idea." Mr. Chew asks Ms. Jacobs in regards to the payouts to the advisors made pursuant to the Tryon loan, does she know whether Mr. Bloom ever ...

discussed that w/ Mr. Depp; she responds "I have no idea." Mr. Chew asks Ms. Jacobs if she has any idea what, if any, disclosures Mr. Bloom may have made to Mr. Depp about the Tryon loan; she responds⬇️

Mr. Chew asks Ms. Jacobs if she knows what role, if any, the law firm of Gibson Dunn played w/ regards to the Tryon loan; she responds "Nope." Mr. Chew asks Ms. Jacobs generally when she involved Mr. Bloom at the inception of the negotiations, who did what; she responds⬇️

Mr. Chew asks Ms. Jacobs if the studio would then send the draft deal; she responds "No. The studio would not immediately send the draft. That's the last thing you get." Mr. Chew says "Okay" & she elaborates⬇️

Mr. Chew asks Ms. Jacobs if after the negotiation, a draft contract comes from the studio; she responds "No. You keep saying the draft comes in, like it's magic." Mr. Chew asks Ms. Jacobs to walk through the steps; she responds⬇️

Mr. Chew asks Ms. Jacobs what the next step is after that; she responds⬇️

Mr. Chew asks Ms. Jacobs what the term "fiduciary responsibility" refers to; she responds⬇️

Mr. Chew asks Ms. Jacobs who had the fiduciary responsibility, herself or Mr. Bloom; she responds⬇️

🤣Mr. Chew is the man! This is another priceless small exchange b/n he & Mr. Freedman.⬇️

Mr. Chew asks Ms. Jacobs if there came a time when Mr. Depp asked UTA to give him $20M; she responds yes. Mr. Chew asks Ms. Jacobs to explain; she responds⬇️

Mr. Chew asks Ms. Jacobs who, if anyone, responded to Mr. Depp's request for $20M; she responds "I believe Jim Berkus did." Mr. Chew asks Ms. Jacobs what Mr. Berkus said to Mr. Depp; she responds⬇️

Mr. Chew asks Ms. Jacobs what happened after that; she responds "Johnny got very angry & then said 'Okay give me $15M'" Mr. Chew asks Ms. Jacobs what Mr. Berkus said in response to Mr. Depp; she responds⬇️

Mr. Chew asks Ms. Jacobs how the meeting ended; she responds "Not well, b/c we said no to his demands." Mr. Chew asks Ms. Jacobs how did the meeting end; she responds⬇️

Mr. Chew asks Ms. Jacobs if UTA gave a guarantee of a particular amount; she responds yes. Mr. Chew asks Ms. Jacobs how much; she responds "$5M...." Mr. Chew asks Ms. Jacobs if she was aware TMG made a loan to Mr. Depp; she responds yes. Mr. Chew asks Ms. Jacobs when was ...

that; she responds "I don't know when they did, b/ I'm aware they did." Mr. Chew asks Ms. Jacobs what she knows about the loan TMG made to Mr. Depp; she responds⬇️

Mr. Chew asks Ms. Jacobs when Ms. Dembrowski told her this; she responds "Not far along...It wasn't a long time before he insisted we give him money." Mr. Chew asks Ms. Jacobs if she ever had a conversation w/ Mr. Depp @ the alleged DV allegations by Ms. Heard; she responds no.

Mr. Chew asks Ms. Jacobs if Mr. Depp denied Ms. Heard's alleged abuse allegations; she responds "Yes. We never spoke @ it specifically. He wasn't really speaking to me at the time." Mr. Chew's examination is complete & now Mr. Peterson questions Ms. Jacobs.

Mr. Peterson is a bit wordy, so I'm going to SS this part of Ms. Jacobs 2019 deposition for convenience. I'll comment to anything I feel is worth pointing out.

This question pertains to Mr. Blooms reputation at the time Mr. Depp hired him & Ms. Jacobs's thoughts.

Mr. Peterson inquires of Ms. Jacobs what she believes Mr. Bloom brought specifically that would be beneficial to somebody w/ a career where Mr. Depp was at, at that juncture of his career. Ms. Jacobs response⬇️

Mr. Peterson asks Ms. Jacobs to give examples of the things Mr. Bloom was able to do w/ & for Mr. Depp; she responds⬇️

This answer is intriguing, when you consider all Mr. Depp's career has accomplished in terms of the film industry either by him directly or by proxy.

Mr. Peterson asks Ms. Jacobs when she says "that came directly from Jake," what she means. She responds⬇️

It seems this benefits not just Mr. Depp, b/ also many in the film industry.

Mr. Peterson asks Ms. Jacobs to describe Mr. Bloom's role, if any, in keeping 'Pirates' together & moving forward; she responds⬇️

Mr. Peterson asks Ms. Jacobs how much the initial deal structure that she credits to Mr. Bloom sets in stone the financial success that inert to Mr. Depp's benefit; she responds "I would like to say 80%." Mr. Peterson asks Ms. Jacobs are there other examples; she responds⬇️

Mr. Peterson asks Ms. Jacobs if it would be fair to say in terms of her knowledge of the industry at the time, Mr. Bloom's resume was as strong as any Entertainment lawyer; she responds "As strong, if not stronger."

Mr. Peterson asks Ms. Jacobs how much time she devoted to Mr. Depp; she responds "I think like for many years I would say 60-75%." Mr. Peterson asks Ms. Jacobs in terms of working w/ Mr. Bloom & his team what observations would you make @ their time commitment; she responds⬇️

Mr. Peterson asks Ms. Jacobs if based on conversations she had that Mr. Bloom spent even more time than she did, speaking w/ Ms. Dembrowski for example; she responds⬇️

Mr. Peterson verifies w/ Ms. Jacobs that the main person she worked w/ besides Mr. Bloom was Michael Schenkman. Mr. Peterson asks Ms. Jacobs if she has an opinion to Mr. Schenkman's competence, responsiveness, things like that; she responds⬇️

Mr. Peterson asks Ms. Jacobs if she knows of any lawyers she would view in Mr. Bloom's league as an Entertainment lawyer that charged anything other than a 5% fee; she responds "No." Mr. Peterson verifies w/ Ms. Jacobs she was aware Mr. Depp's money issues going back years.

Mr. Peterson asks Ms. Jacobs w/ respect to the issue of Mr. Depp's taxes, what she understood the issue to be, if she had any understanding at all; she responds⬇️

Mr. Peterson asks Ms. Jacobs if it ever came to her attention that tax returns were not properly being filed for Mr. Depp; she responds "No. Ed White told me that whenever Johnny left, but I had never heard that before."

Mr. Peterson asks Ms. Jacobs if she had a sense while representing Mr. Depp if there was an issue w/ respect to actually filing the tax return; she responds "No. None. No. No knowledge."

Mr. Peterson asks Ms. Jacobs if during the years she represented Mr. Depp, if she heard criticisms from him of the service provided by anybody at the Bloom Hergott firm; she responds "No."

Mr. Peterson asks Ms. Jacobs if during the years she represented Mr. Depp, if she heard criticisms from him of the service provided by Mr. Mandel & his colleagues; she responds "Only at the very end." Mr. Peterson asks her to elaborate; she responds⬇️

Mr. Peterson asks Ms. Jacobs if over the years, she was ever at meetings where Mr. Mandel tried to explain to Mr. Depp where he was financially; she responds "No."

Mr. Peterson asks Ms. Jacobs if she received any documents from Mr. Mandel over the years that would have demonstrated where Mr. Depp was in terms of net worth, cash, anything like that; she responds "No."

Mr. Peterson asks Ms. Jacobs if she can expand on Mr. Bloom's relationships w/ Steve Spira & Alan Horn. How those studio relationships were used by Mr. Bloom to Mr. Depp's benefit; she responds⬇️

Mr. Peterson asks Ms. Jacobs if it would be fair to say that her main communication linked to Mr. Depp was Ms. Dembrowski; she responds "Yes." Mr. Peterson asks Ms. Jacobs how that came to be; she responds⬇️

Mr. Peterson asks Ms. Jacobs what happened when you needed Mr. Depp's direct approval; she responds "She would get it." Mr. Peterson asks Ms. Jacobs if she relied on Ms. Dembrowski; she responds "I had no choice."

Mr. Peterson asks Ms. Jacobs if she ever had a situation after the fact where Ms. Dembrowski indicated that she had Mr. Depp's answer on something & it turned out that she had not given her an accurate recital of what Mr. Depp had decided; she responds "I don't think so, b/ IDK."

Mr. Peterson asks Ms. Jacobs if she relied on Ms. Dembrowski on a regular basis; she responds "Yes." Mr. Peterson asks Ms. Jacobs if she thought she could rely on Ms. Dembrowski; she responds "I didn't want to, b/ I had no choice."

Mr. Peterson asks Ms. Jacobs why she had no choice, b/ to rely on Ms. Dembrowski; she responds "Because he wouldn't return emails, texts, phone calls & I had no other choice. She was his sister."

Mr. Peterson asks Ms. Jacobs why she thought it was unrealistic to try to secure $25M in deals by the end of the year; she responds⬇️

Mr. Peterson asks Ms. Jacobs if by that point in time Mr. Depp's value in the marketplace had changed; she responds "Yes." Once again Mr. Chew chimes in w/ an objection & Ms. Jacobs gets snarky when she elaborates on the previous question.⬇️

I would like to take a moment to interject something regarding these comments by Ms. Jacobs. All these incidents she lists her are all incidents that occurred while Mr. Depp was being severely abused by Ms. Heard; this is important & will be mentioned at the US trial.

Mr. Peterson asks Ms. Jacobs if she's speaking of a history of this behavior beyond the award show incident; she responds "Yes" Mr. Peterson asks Ms. Jacobs to elaborate; she responds.⬇️

I would like to take a moment to interject something regarding these comments by Ms. Jacobs. All these incidents she lists her are all incidents that occurred while Mr. Depp was being severely abused by Ms. Heard; this is important & will be mentioned at the US trial.

Mr. Peterson concludes his questions & Mr. Chew is once again question Ms. Jacobs.

Mr. Chew asks Ms. Jacobs if working for Mr. Depp was so horrible, why didn't you just quit; she responds "A lot of money. And the truth is I loved him like a brother. And it was very ...

disappointing to have him treat me the way he did." Mr. Chew asks Ms. Jacobs when she speaks of Mr. Bloom's contribution, if it is true 'Edward Scissorhands' was a huge success a decade before Mr. Bloom came on; she responds⬇️

Mr. Chew asks Ms. Jacobs if Mr. Depp was a TV star before she became his agent; she responds "Right. And I made him into a movie star." Mr. Chew asks Ms. Jacobs if she sought Mr. Depp out; she responds "Correct. And he stood me up 5 times, b/ I didn't care."

Mr. Chew says to Ms. Jacobs: "And you didn't have a problem collecting $65M for your company? Ms. Jacobs responds.⬇️

Mr. Chew asks Ms. Jacobs if Mr. Bloom spoke to Ms. Dembrowski once or twice a day; she responds "That's what I think." Mr. Chew asks Ms. Jacobs if she has any idea what Mr. Bloom & Ms. Dembrowski spoke @; she responds "No. Could have been the weather."

Mr. Chew asks Ms. Jacobs if lawyers get compensated for nonlegal communications; she responds "Maybe you should ask Christi. All I know is it is a fact they spoke several times a day, according to her. So maybe she lied to me."

Mr. Chew asks Ms. Jacobs if it is true she doesn't know what Mr. Bloom & Ms. Dembrowski spoke @; she responds "No, I don't." Mr. Chew asks Ms. Jacobs if it is accurate that she doesn't know how long they talked; she responds "No, I don't."

Mr. Chew asks Ms. Jacobs if it is accurate Mr. Depp would not communicate w/ her & was unresponsive to her; she responds "Correct." Mr. Chew asks Ms. Jacobs if it is true Mr. Bloom did not have an issue communicating w/ Mr. Depp; she responds⬇️

Mr. Chew asks Ms. Jacobs w/ respect to Mr. Bloom's reputation he's been fired by certain clients, correct; she responds "So have I." Mr. Chew asks Ms. Jacobs if Mr. Bloom was fired by Sylvester Stallone; she responds "I don't know. I have heard that." This concludes the 2019 depo

The next section (pp.389-393) is an excerpt of Ms. Jacobs January 28, 2021 deposition in Mr. Depp's defamation lawsuit against Ms. Heard. Ms. Bredehoft appears to be questioning Ms. Jacobs at the onset of this excerpt.

I'm going to take a small break before tackling this part.

Ms. Jacobs is asked if she's had any communications w/ Debbie Lloyd or Aaron Burham during the time she represented Mr. Depp; she responds "No." Ms. Jacobs is asked how frequently she communicated w/ Christi Dembrowski during the time she represented Mr. Depp; she responds⬇️

This exchange is the basis for Ms. Bredehoft/Ms. Heard's Motion to Compel the video of both Ms. Jacobs deposition in the TMG/Bloom matter & her request Mr. Depp be sanctioned⬇️

Ms. Jacobs is asked if she was involved at all in the negotiation of the Christian Dior contract w/ Mr. Depp; she responds "Yes. But it was another woman that ran the department named Lisa Jacobson, who's no longer at UTA."

This exchange also is the basis for Ms. Bredehoft/Ms. Heard's Motion to Compel the video of both Ms. Jacobs deposition in the TMG/Bloom matter & her request Mr. Depp be sanctioned⬇️

This also concludes this excerpt of Ms. Jacobs 2021 deposition.

The next section (pp.395-438) is Mr. Depp's responses & objections Ms. Heard's 4th request for admission.

This concludes this thread. I hope you've found it helpful. Please feel free to discuss anything & if you have questions to feel free to ask myself or @ the lawyers.

@threadreaderapp unroll.