Thread by @roaringrapids22

This thread will pertain to Mr. Depp's opposition to Ms. Heard's Motion to Compel & seek Sanctions based on Ms. Heard's allegations Mr. Depp failed to timely produce discovery prior to Ms. Jacobs January 2021 deposition: fairfaxcounty.gov/circuit/sites/…
Judge Azcarate DENIED.

🤣Mr. Chew wastes no time & starts off with: "Defendant Amber Heard filed her motion to compel without any basis in fact or law, & for the improper process of smearing Mr. Depp's counsel. The court should deny the motion & impose sanctions against her."

Mr. Chew mentions Ms. Heard's "fishing expedition" into unrelated legal cases involving TMG, he won via settlement; that sparked a IRS/DOJ/SEC investigation into money laundering btw.; & his lawsuit against Bloom, which he won via settlement; she wasn't a party to either.

🤣Mr. Chew included Judge White's admonishment of Ms. Bredehoft denying her previous motion to compel Mr. Depp on similar matters. He then mentions in "defiance of the Court" she attempted in January 2021 to once again compel Mr. Depp similarly.

This is "key"...Ms. Jacobs has never claimed to be a witness to any alleged violence b/n Mr. Depp & Ms. Heard. Ms. Jacobs testified she didn't even know about any alleged violence until Ms. Heard publicized her claims in May 2016 & never discussed the allegations w/ Mr. Depp.

Another "key" point...Ms. Jacobs, in her January 2021 deposition, lasting 4 hours (we've not seen the full transcript), she was questioned extensively by Ms. Bredehoft, was shown photographs of Mr. Depp & Ms. Heard, which she testified she'd never seen previously.

🤣I love when Mr. Chew schools Ms. Bredehoft in his Court submissions in Law School 101, ending by saying Mr. Depp legally had the right to withhold the transcripts, b/ generously provided them to Ms. Bredehoft in good faith.

🤣Mr. Chew continues to school Ms. Bredehoft in basic Law School 101...I love his use of "hypothetical evidentiary objections," noting Mr. Depp's never waived his evidentiary objections; in fact he's objected & the Court's never overruled his objections.

Ms. Bredehoft mentions she cannot under CA law depose Ms. Jacobs again, however, according to Mr. Chew she's misinformed the court & can seek to depose her again, to authenticate documents/business records via United Talent Agency or those she was communicating with.

According to Mr. Chew, Ms. Bredehoft has threatened motions, refused multiple requests to meet & confer in Ms. Heard's threatened motions, claiming these requests are harassment & attempts to delay; he also mentions Ms. Heard's request to stay discovery was denied.

Judge White has 2X previously denied Ms. Heard's motions on the grounds that her counsel failed to meet/confer prior to filing; calling these motions a "pretextual vehicle" for her to "hurl unfounded accusations of bad faith against Mr. Depp" ahead of her third dismissal attempt.

Pages 8-11 are simply newspaper articles regarding his previous litigation w/ Rob & Joel Mandel (TMG) & Jacob Bloom, Alan Hergott & Bloom Hergott Diemer Rosenthal LaViolette Feldman Schenkman & Goodman LLP, so I'm not going to post those.

Pages 12-13 are Mr. Chew's Declaration pertaining to the exhibits attached, explaining each briefly. I'll deal with the exhibits directly, in a moment, so will just post the Declaration itself, so you can get a preview of the attachments I'll be covering.

Pages 15-67 is Mr. Depp's original complain against Rob & Joel Mandel, The Management Company. I'm just going to post anything from the Complaint that is of interest, rather than dissecting it, since the case is settled; the IRS/DOJ/SEC investigation followed.

Mr. Depp alleges "gross misconduct, mismanagement, & outright fraud" by his business managers Rob & Joel Mandel, TMG, who paid themselves 10s of millions of dollars of "contingent fees purportedly based on an oral contract, all at Mr. Depp's expense."

Rob & Joel Mandel, TMG paid themselves $28M in "contingency fees," over the course of their employ by Mr. Depp. They failed to pay his taxes on time costing Mr. Depp $8M in penalties & interest on his federal & state tax returns, "failing to keep proper books & records."

Rob & Joel Mandel, TMG "loaned nearly $10M to third parties w/out Mr. Depp's prior required proper authorization & w/out proper documentation or requiring repayment, using inflated & obviously incorrect figures as loan offsets, falsely ascribing 3rd parties' taxable income to ...

Mr. Depp, so that he, rather than they, paid the tax, failing to reduce expenditures TMG undertook on Mr. Depp's behalf, which caused profound financial waste."

This is "key"...The employ spoken of next, is Ms. Rayburn, she was a whistleblower in this case, who came forward to expose Rob & Joel Mandel, TMG, after Edward White's forensic audit; she was fired for being unwilling to be complicit in these activities.

Ms. Rayburn in her deposition testified she was fired b/c she was unwilling to "fix numbers in Mr. Depp's financial statements, to improperly notarize Mr. Depp's purported signatures when Mr. Depp wasn't present, & notarize blank signature pages...."

Rob & Joel Mandel, TMG, & other advisors "added language into a hard money loan agreement that provided them rights the didn't otherwise possess to multi-million dollar payouts on residuals of 6 of Mr. Depp's most successful films...." lying to a lawyer.

Rob & Joel Mandel, TMG "ensured that millions of dollars of payments...flowed to them & other advisors; they engaged in multiple self interested transactions by investing Mr. Depp's funds in business ventures in which they had direct ownership interests w/out documentation.

Why bring this up? This plays into Tracey Jacobs depositions TMG/Bloom, attached to Ms. Bredehoft's recent Court submission; to the Elisa's Attic, Mandel, TMG, Bloom, & Christi Dembrowski subpoenas in VA, as well, in Ms. Heard's attempt to mitigate damages, among other things.

"TMG's gross mismanagement & fraud remained undetected, as TMG borrowed millions of dollars to survive from movie-to-movie." It's noted this was detected by Edward White upon a forensic audit, it also is mentioned he is Mr. Depp's new business manager.

It's also noted that at the time of Mr. Depp's Complaint against TMG in 2017, they also presently were attempting to foreclose on his Sweetzer home, even though the loan was made through TMG's misconduct & self-interests illegally.

It's important to note that in addition to co-owning & operating The Management Group (TMG) both Rob Mandel & Joel Mandel are also licensed CA attorneys. Why? Because of the deposition testimony of Tracey Jacobs in 2018/2019.

Rob & Joel Mandel "rarely consulted w/ Mr. Depp regarding any financial transactions, legal or tax matters, or investments....often [only presenting Mr. Depp] w/ a signature page to sign, rather than a full document." They told him he was in excellent financial condition.

Rob & Joel Mandel, TMG "took out 10s of millions of dollars in loan after loan" & sold some of Mr. Depp's assets to hide their misconduct....concealing the true state of [his] finances while driving him deeper & deeper into financial distress."

Earlier in this thread, recall the mentioning of other "advisors" illegally benefitting from TMG's mismanagement of Mr. Depp's funds & "outright fraud; it's in this paragraph where you discover one of them is Jacob Bloom, Alan Hergott, the Bloom firm.

Edward White during his forensic audit of TMG's records, documented they failed to keep a complete set of electronic records, to keep a current accounting of Mr. Depp's finances, accounts & business transactions; then when caught they attempted to "simulate" an accounting system.

Insurance is something that is incredibly important to everyone, so the fact it is revealed Rob & Joel Mandel failed to purchase or maintain adequate insurance for Mr. Depp or his business entities, unbeknownst to Mr. Depp is quite disturbing.

Rob & Joel Mandel, TMG, despite the fact Robert Mandel is himself, a CA licensed tax attorney, "never once paid Mr. Depp's income tax....creating numerous estate tax, gift & income tax anomalies....costing Mr. Depp approximately $8M.

Since, this is public knowledge, I'm going to mention this: It's documented of the 3rd party loans totaling $10M dollars, made w/out Mr. Depp's knowledge/approval, his sister Christi Dembrowski was the recipient of $7M; his sister Debbie Rassel, was a recipient as well.

Example of financial waste: Mr. Depp rented a home for his mother, Betty-Sue, "to serve as a potential hospice for her at a cost of $35K per month; she recovered & TMG failed to terminate the lease costing Mr. Depp $350K

Example of financial waste: TMG retained Premiere Group International (PGI) to provide Mr. Depp security at various locations w/out telling Mr. Depp about the "Exorbitant" cost or ? if their services were even needed. B/n 2012-2015 this cost Mr. Depp $8M.

Example of financial waste: @ July 2007 "an issue arose regarding a set of drain lines/retaining wing wall" at the Sweetzer estate; a neighbor arguing @ it crossing the property line. TMG didn't conduct a formal survey of the land or seek to move the retaining wall, instead ...

they entered into a release agreement w/out Mr. Depp's knowledge or consent w/ the neighbor, whereby the neighbor was paid $3K per month. As of the Claim being filed in 2017, Mr. Depp's paid the neighbor thus far, $320K.

Rob & Joel Mandel, TMG, w/out Mr. Depp's knowledge or consent, b/n 2006-2012 borrowed more than $22M from City National Bank, securing the loans w/ property owned by Mr. Depp, including his Sweetzer properties.

Rob & Joel Mandel, TMG, w/out Mr. Depp's knowledge or consent, @ August 2014, obtained "a large loan on behalf of Mr. Depp from a hard money lender, Tryon Management Services," orchestrated by Grosvenor Park Media & a collection agent Fintage Collection Account Management.

Rob & Joel Mandel (TMG), @ 10/2014 via Tryon made a loan of $12.5M to one of Mr. Depp's business entities "at an above market initial interest rate of 10%, which later increased to 10.25%;" was subject to high fees; accrued interest capitalized monthly; contained a buyout clause.

Rob & Joel Mandel, TMG @ August 2015 "caused Mr. Depp's entities to take out a further advance from Tryon...in the amount of $6.5M," bringing the total borrows from Tryon to $19M.

In the two years since the August 2015 loan was initiated, Mr. Depp "should have received a total of $25,722,467 in residuals," yet neither he or his business entities have $0, while TMG received $917,564 in fees & his other advisors $4M.

Ron & Joel Mandel, TMG, from 2006-2016 "caused Mr. Depp to incur $40M in debt & millions of dollars in unnecessary interest & fees to cover up it's mismanagement & fraud."

Rob & Joel Mandel, TMG "submitted incorrect financial information to City National Bank," regarding Mr. Depp's loans, mischaracterizing his "current tax liabilities as deferred," when in fact they were not & underestimated Mr. Depp's current liabilities by millions of dollars.

An example of the mismanagement & incorrect financial documents is provided here.⬇️

Based on information provided by the Internal Revenue Service & the CA Franchise Tax Board, TMG knew or should have known the correct, current tax liabilities. R. Mandel is a tax attorney.

@ March/April 2012 TMG caused Mr. Depp to obtain a $5M "unsecured line of credit from City National Bank." @ late 2012 TMG, on behalf of Mr. Depp, failed to make the payment obligations of this line of credit b/c of TMG's unauthorized expenditure of millions of dollars.

In order to hide the aforementioned $5M "unsecured line of credit," TMG took out a $5 M loan in their own name from City National Bank, & LENT the money to Mr. Depp to pay the original loan they fraudulently took out in the first place.

Even though the City National Bank promissory note was unsecured, TMG required Mr. Depp to execute a Lending Agreement/a promissory note to TMG; his 5 Sweetzer properties, causing him to exchange an "uncollateralized debt" for one secured by his own properties.

The Lending Agreement b/c Mr. Depp/TMG "sought to disclaim TMG's fiduciary duties...for purposes of the transaction...&gave Mr. Depp the opportunity to seek independent counsel. In reality, they didn't inform Mr. Depp of his right to seek independent counsel or many other things.

This section of the Claim, clearly shows TMG's conflict of interest, in the Loan Agreement making themselves independent from Mr. Depp, while still controlling his financial business/management to pay or not pay themselves back as his manager.

TMG intentionally caused the loan they made with Mr. Depp to go into default, by not paying themselves back, when they controlled his finances, hence the reason for the 2017 foreclosure attempt on his 5 Sweetzer homes.
Here's how they did attempted to do this⬇️

As early as 2004, Joel Mandel "used his position as trustee...to invest millions of dollars in various entities in which either Joel Mandel, TMG, or Joel Mandel's immediate family members also had a direct ownership interest," w/out Mr. Depp's knowledge or consent.

"TMG's gross mismanagement of almost every aspect of Mr. Depp's affairs caused [him] to lose 10s of millions of dollars. TMG then sought to hide its losses...by creating the illusion of wealth & financial stability, making improper disbursements to Mr. Depp's friends & family..."

Edward White did a extensive financial audit of Mr. Depp's finances, that is noted as still ongoing at the time this Claim was filed in 2017. TMG's mismanagement/fraud has caused Mr. Depp to sell his investments "in real & personal" property. Other things Mr. White's done/doing⬇️

The final sections list the many causes of action; essentially a summary of the key points I've already pointed out. Lastly, is what Mr. Depp was seeking in terms of Relief via his lawsuit. I'll go over these as they are important imo, to understanding Ms. Jacobs testimony.

Mr. Depp was seeking Relief for "compensatory damages...in excess of $25M;" "restitution & disgorgement of all gains & profits" by TMG/Rob & Joel Mandel as a result of their "wrongful & unlawful conduct."

Mr. Depp was seeking Relief for "rescission of the Lending Agreement & Promissory note lending $5M directly to Mr. Depp by TMG, & of the corresponding Deeds of Trust, through which TMG currently seeks to foreclose on the Sweetzer properties."

Mr. Depp was seeking Relief for "setoff of any amounts allegedly owed to the Defendants against amounts Defendant's owe Plaintiffs;" "for punitive & exemplary damages in an amount subject to proof;" "& for interest & prejudgment interest."

Mr. Depp was seeking Relief for a "TRO, & preliminary & permanent injunction enjoining Defendant's from proceeding w/ the foreclosure of the Sweetzer properties."

Mr. Depp was seeking Relief for "An award of attorneys' fees & costs, except as to Defendant First American; & for such other & further relief as deemed just & proper."

Pages 68-92 is the Complaint (lawsuit) Mr. Depp filed against Jacob Bloom & Bloom Hergott Diemer Rosenthal LaViolette Feldman Schenkman & Goodman LLP in 2017. I will do the same as I did w/ the TMG Complaint in the Tweets to follow.

Bloom engaged in "misconduct for their own financial benefit & violated some of the most basic tenets of the attorney-client relationship, all to Mr. Depp's serious financial detriment, causing [him] substantial economic harm."

Bloom "engaged in self-dealing & pursued & undertook transactions in the face of undisclosed conflicts of interest for their own financial benefit over that of their clients."

Bloom "knowingly, recklessly, or negligently failed to disclose to Mr. Depp the years of misconduct engaged in by Defendants & Mr. Depp's then-attorneys & business managers who were providing both legal & business management services, TMG, despite a clear duty to disclose...."

Bloom, like TMG, "each collected over $30M in contingent fees based on Mr. Depp's variable income, paid out by TMG, without, among other things, the statutory prescribed written contract, in clear violation of California law."

"Defendants' breaches of fiduciary duties, unauthorized taking of Mr. Depp's film residual & other economic rights for themselves, conflicts of interest, self-dealing, legal malpractice, & clear violations of CA law, cost Mr. Depp 10s of millions of dollars...."

Example of a conflict of interest, self-dealing & breaches of fiduciary duty: "is the sourcing of an improper & predatory hard money loan, purportedly on behalf of Mr. Depp through...Grosvenor Park Media...." Notice this is the same loan as the one from the TMG lawsuit.

@ May/June 2014, TMG consulted w/ Bloom regarding Mr. Depp's financial affairs, but didn't disclose to him "the true state of his financial affairs & their own wrongdoing. Instead, TMG/Bloom "secured for themselves a stream of lucrative contingent fee payments...."

"Upon information & belief, TMG sought & received Bloom's assistance in effecting this effort....never ?'d TMG's financial management...or investigated TMG's explanation...as any reasonable competent lawyer would." They also didn't inform Mr. Depp of their own conduct/activities.

"On information & belief, in furtherance of the scheme, Bloom introduced TMG to Grosvenor Park in order to obtain a hard money loan, purportedly on Mr. Depp's behalf, b/ in reality to this detriment, & to Bloom, TMG, & Grosvenor Park's benefit."

"On information & belief, Bloom [had] professional relationships, which they failed to communicate to Mr. Depp,...w/ Grosvenor Park &/or its founder & CEO, Donald Starr." Bloom was given a position on the advisory board of Grosvenor Park, nor did Bloom inform Mr. Depp.

"Together w/ TMG & Grosvenor Park, Bloom orchestrated an initial $12.5M hard money loan...from a lender...an affiliate of Grosvenor Park, Tryon Management Services. This loan was later increased to $19M."

Bloom was "actively involved in negotiating the Tryon loan on behalf of Mr. Depp....Bloom negotiated directly w/ film studios to secure Mr. Depp's residuals from the Films as collateral....Bloom [was] updated on the status of the loan paperwork by TMG...." & consulted w/ them.

Bloom/TMG structured the loan "w/out the legally required disclosures to Mr. Depp as a vehicle to provide themselves w/ immediate priority to millions of dollars of voidable contingency fees tied to the success of Mr. Depp's Film residuals, all before Mr. Depp received a cent."

"The Terms of the Tryon loan required that repayment would be made from, & secured, by Mr. Depp's residuals from 6 films....Bloom w/ TMG, inserted different numbers for different Film residuals, including a 22.22% fee for advisors for 1 movie."

Bloom/TMG "changing of the numbers in this contract illustrates Bloom/TMG's unfettered control to establish contractual entitlement that was in [their] best interest at the expense of [Mr. Depp]...."

"Further, the loan prioritized payment of Blooms' & TMG's fees ahead of the loan payments owed to Tryon, & regardless whether Mr. Depp actually retained any of the loan proceeds...w/ the rights to fees superior to Mr. Depp's own...."

Blooms' & TMG's "legally voidable contingent fees...& preferred payment position were inserted at the very beginning of the negotiations on the Tryon loan...assuring [they] received an improper stream of payments, which were not legally owed...."

Bloom "benefited immediately from the Tryon loan, through the insertion of this improper contingent fee arrangement in the loan...on or @ the date the [loan proceeds' were received Bloom/TMG & a 3rd party took $1.2M...[Bloom] was paid $300K at that time...."

"Despite the fact the initial was $12.5M, the Film rights pledged to secure the loan yielded Mr. Depp approx. $13M per year, more annually than the initial loan amount....during the 1st 12 mos....Mr. Depp would have received $15.2M in Film residuals...."

"Further, only 8 days after the loan agreements were signed, the studio paying Mr. Depp's residual rights paid $5.58M that would have gone to Mr. Depp, but for the Tryon loan...." The hard money loan wasn't "economically rational, at least not for Mr. Depp."

Bloom, "in their capacity as Mr. Depp's attorneys who negotiated film deals & the party whom the studio provided notice of such payments, knew that Mr. Depp soon would have received these significant residual earnings on these 6 films."

"The predatory hard money loan was further subject to high fees, double-digit interest rates, & repayment terms that provided that accrued interest would be capitalized monthly & added to the principal....contained substantial repayment penalties...of $1.5M" in fees.

"Although accrued interest was capitalized monthly...Mr. Depp's business entities received Film residuals less frequently than monthly, resulting in significant additions to the outstanding principal in b/n each repayment...by 6/30/17 over $2M if capitalized interest...."

"As a result of their actions Bloom/TMG caused Mr. Depp to forego 10s of millions of dollars of annual earnings from residuals from the Films that had provided Mr. Depp w/ regular & substantial income...."

"Bloom did not disclose to Mr. Depp the conflicts of interest caused by Bloom's professional relationships w/ Grosvenor Park....that the Tryon loan was a hard money loan...."

"In the end, Mr. Depp was presented w/ only the signature pages of the loan documents,..."

"[By 2017] Mr. Depp should have received a total of approx. $32M in residuals from the Films. Instead he received nothing....$9M...[was] directed to the payment of [his] tax liabilities...w/ the balance being paid to Bloom, TMG, Tracey Jacobs, & to the lender.

Bloom "received advanced notice from TMG's Joel Mandel (many months after Mr. Depp had terminated Mr. Mandel) that Mandel imminently intended to launch a nonjudicial foreclosure action on Mr. Depp's home...."

"...Bloom would submit to TMG requests for reimbursement of alleged expenses. A former TMG employee (Ms. Rayburn)...testified that Bloom submitted requests...w/ no supporting documentation, which TMG would then pay...she confronted Mr. Mandel & was ordered to just pay it...."

"...Bloom regularly failed to provide any documentation substantiating the claimed expenses; nor were they ever disclosed to Mr. Depp....Bloom submitted 100s of thousands of dollars of such unsubstantiated expenses...." TMG paid them.

"...Unbeknownst to Mr. Depp TMG & Joel Mandel unilaterally funneled millions of dollars of Mr. Depp's money from Mr. Depp's Sweetzer Trust account into 'investments' in which the Mandel's were secretly involved as members & directors, including Lionheart, LP (owned by a ...

mysterious entity called 'Benari' Capital Management, LLC,' both operating out of Wilmette Illinois), & the equally mysterious Matar I, Matar II & 6909 Ventures, LLC....Mr. Mandel wrote checks in his own hand & using his own signature to move Mr. Depp's money from his ...

Sweetzer Trust account to Mr. Mandel's 6909 Ventures, LLC, which Mr. Mandel manages...."

I'm going to interject something b/c it belongs here. This is from a Chicago Tribune article, regarding Mr. Depp's lawsuits w/ TMG/Bloom: archive.ph/SEbp9.

This connects to Ari & Rahm Emanuel, the former Mayor of Chicago, both bros have personal/business ties to Mr. Musk.

Keep in mind, it is potentially Jacob Bloom that was also the attorney of Elon Musk at the time Mr. Depp was also their client, although this is still unsubstantiated; all we know is Mr. Depp's unnamed legal counsel was also Mr. Musk's legal counsel.

"In court papers filed in Cook County Circuit Court this week, Depp’s lawyers subpoenaed records from Lionheart L.P., a Wilmette-based hedge fund. U.S. Securities and Exchange Commission filings list the Mandel brothers as directors of the company."

"Lionheart allegedly received more than $2M from a trust held by the actor 'despite the fact that (the Mandels) possessed direct ownership interests' in the company,...TMG had Depp invest hundreds of thousands of dollars in at least three other companies owned by TMG employees."

"The subpoenas from Depp’s attorneys, filed Wednesday, also seek any communications the hedge fund, its directors or TMG had that “relate to” Ari Emanuel, the Hollywood mogul who runs the talent agency WME-IMG." This is Amber Heard's agent/representative.

Btw. Mr. Musk in recent months is now on the Board of Directors of WME-IMG, now known as the Endeavor Group: businessinsider.com/elon-musk-ende…

"Court filings here do not explain why Depp’s attorneys want those records, but last summer Vanity Fair quoted Ari Emanuel as saying the Mandels are 'true, honest, loyal brokers' whom he’d trusted with his own finances."

"The Los Angeles Times reported in August that several federal agencies, including the Securities and Exchange Commission, had launched probes of TMG."

WSJ article: wsj.com/articles/johnn…

In his lawsuit w/ Mr. Bloom, Mr. Depp sought Relief for "compensatory damages in an amount subject to proof at trial; for a judgment declaring that any purported fee arrangement b/n Plaintiff's & Defendants is invalid, void & unenforceable."

In his lawsuit w/ Mr. Bloom, Mr. Depp sought Relief for "a judgment returning to Plaintiffs' all funds collected by Defendants pursuant to any purported fee arrangement w/ Plaintiffs in an amount subject to proof at trial."

In his lawsuit w/ Mr. Bloom, Mr. Depp sought Relief for "restitution & disgorgement of all gains & profits by Defendants as a result of their wrongful & unlawful conduct, in an amount subject to proof at trial."

In his lawsuit w/ Mr. Bloom, Mr. Depp sought Relief for "setoff of any allegedly owed to Defendants against amounts Defendants owe Plaintiffs; for punitive & exemplary damages in an amount subject to proof at trial."

In his lawsuit w/ Mr. Bloom, Mr. Depp sought Relief for "interest & prejudgment interest; an award of attorneys fees & costs; & for other & further relief as deemed just & proper."

Mr. Depp settled w/ Bloom in 2019, just prior to trial; it was a win for him.

Pages 93-95 are a transcript of November 20, 2020's hearing before Judge White in VA. Judge White sustains Mr. Depp's objects to 1-5 b/c they are "overly broad & burdensome;" 6-7 are sustained on the same grounds; part of 8 is granted to Ms. Heard, the request to paragraph 9 ...

is denied; "the request w/ regard to the personal income tax returns is granted [to Ms. Heard] as to the return pages, not all of the supplementary documents that are attached to them."

Judge White's rebuke of Ms. Bredehoft are in these 2 paragraphs⬇️

Pages 96-97 are an excerpt from May 28, 2021 before Judge Azcarate.

🤣Here's Ms. Bredehoft's migraine inducing BS attempt to stay discovery, which Judge Azcarate denied.⬇️

Pages 98-109 are a series of emails. I'm just going to post the highlights of importance from each, redacting any personal information out of respect for privacy.

This email is from Samuel Moniz, to Ms. Bredehoft, b. CC'd to relevant parties of Mr. Depp & Ms. Heard's legal counsel.

Mr. Moniz's has clearly had enough of Ms. Bredehoft's unfounded accusations, disagreement @ RFP objections by Ms. Heard & meet & confers, Mr. Depp's motions.

Mr. Moniz's has clearly had enough of Ms. Bredehoft's unfounded accusations, disagreement @ RFP objections by Ms. Heard & meet & confers, Mr. Depp's motions continued via this email.

This email is from Ms. Bredehoft to Mr. Moniz, CC'd to members of both Mr. Depp & Ms. Heard's legal counsel.

Ms. Bredehoft makes unsubstantiated accusations & complaints.

This email is from Mr. Moniz to Ms. Bredehoft, CC'd to members of both Mr. Depp & Ms. Heard's legal counsel. He mentions how he finds it baffling she sees a request to meet & confer as "harassment," then address her previous email more specifically.

This email is from Ms. Bredehoft to Mr. Chew, CC'd to members of both Mr. Depp & Ms. Heard's legal counsel. In it she complains @ Mr. Moniz's emails, is insulting toward Mr. Chew, as well as it makes a threat @ motions she's filing, & makes unfounded accusations.

This email is from Mr. Chew to Ms. Bredehoft, CC'd to members of both Mr. Depp & Ms. Heard's legal counsel. It's in regards to Ms. Bredehoft failing to respond to meet & confer requests & Ms. Heard's contempt of court of not adhering to a Court Order to compel.

This email is from Mr. Moniz to Ms. Bredehoft, CC'd to members of both Mr. Depp & Ms. Heard's legal counsel. It's a request for a meet & confer over multiple issues, including Ms. Heard's contempt of Court.

I'm going to get a few hours sleep, b/ will continue/finish this thread in the morning before moving on to the last 3 of Fridays VA uploads in individual threads.

Pages 110-128 is an excerpt of Tracey Jacobs, 1/28/21 deposition. I will deal with this deposition the same, as I have, in the past. We've seen the transcripts of Ms. Jacobs' 2018/2019 depositions in the TMG/Bloom legal cases. Those are in this thread: threadreaderapp.com/thread/1405728…

Ms. Bredehoft asks Ms. Jacobs (pertaining to exhibit 12) "Have you seen this picture before; response "Not this exact picture." Ms. Bredehoft notes the metadata on the photo is 5/21/16 at 9:24 PM EST. She asks Ms. Jacobs "Do you recognize this as Amber Heard; response "Yes."

Ms. Bredehoft asks Ms. Jacobs (pertaining to exhibit 13, metadata 5/21/16 at 9:25 PM EST) "Have you seen this picture before?"; response "Not that I can recall." "Do you recognize the person in this picture?; response "Yes." She asks "And who is it?"; response "Amber Heard."

Ms. Bredehoft asks Ms. Jacobs (pertaining to exhibit 14, also date 5/21/16) "Have you seen this picture before?;" response "Not that I can recall." She asks "Do you recognize the person in this photo?;" response "Yes." She asks "Who is it?;" response "Amber Heard."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 15) "Have you seen this photo before?; response "No." She asks "So you recognize the person in this photo?;" response "Yes." She asks "And who is that?;" response "Amber Heard."

Ms. Bredehoft asks Ms. Jacobs (pertaining to exhibit 16) "Ms. Jacobs, have you ever seen this photo before?; response "Not that I can recall." She asks "Do your recognize the person in this photo?;" response "Yes." She asks "Who is it?; response "Amber Heard."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 17) "Have you seen this photo before?;" response "Not that I can recall." She asks "Do you recognize the person in this photo?;" response "Yes." She asks "And that is?;" response "Amber Heard."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 18) Have you seen this photo before?; response "Not that I can recall." She asks "Do you recognize the person in this photo?;" response "Yes." She asks "And that is?;" response "Amber Heard."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 19) "Have you seen this photo before?;" response "No." She asks "Do you recognize the person in this photo?;" response "Yes." She asks "And that is?;" response "Amber Heard."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 20) Have you seen this photo before?; response "No." She asks "Do you recognize the person in this photo?;" response "It's Amber Heard."

🤣You have to love Mr. Chew, clearly glad this set of pictures is nearly finished.

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 21) Have you seen this photo before?; response "Not that I can recall." She asks "Do you recognize the person in this photo?;" response "Yes." She asks "Who is it?;" response "Amber Heard."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 21) Have you seen this photo before?; response "Not that I can recall." She asks "Do you recognize the person in this photo?;" response "Amber Heard."

Ms. Bredehoft asks Ms. Jacobs "Were you involved in any manner in the mediation & settlement efforts b/n Mr. Depp & Ms. Heard following Ms. Heard filing for divorce in May 2016?;" response "No."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 24) "Have you seen this photo before?;" response "No." She asks "Do you recognize the people in that photo?;" response "No." An argument ensues b/n Ms. Bredehoft & Mr. Marmorstein over the next question...she's combative.

Ms. Bredehoft asks Ms. Jacobs "Have you ever seen Mr. Depp snort cocaine?;" response "No." She asks "Are you able to say one way or the other whether Mr. Depp snorted cocaine while you were representing him?;" response "No."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 25) "Do you recognize the people in this photo?;" response "Yes." She asks "Have you ever seen this photo before?;" response "No." She asks "Who are the people in this photo?;" response "Amber Heard and Johnny Depp."

Ms. Bredehoft asks Ms. Jacobs "During the time you represented Johnny Depp, did he smoke?;" response "Yes." She asks "For the entire 30 years or was there periods where he was on or off or took it up later?;" response "The entire 30 years."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 26) "Have you seen this photo before?;" response "No." She asks "Do you recognize the person in this photo?;" response "No."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 27) "Have you seen this photo before?;" response "No." She asks "It's a little bit closer up. Do you recognize the person in this photo?;" response "It looks like Johnny."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 27) "Have you ever seen Mr. Depp in this state before? Passed out on the floor?;" response "I don't recall." She asks "Were there occasions...that you would see him passed out?;" response "I don't recall."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 28) "Do you recognize the person in this photo?;" response "It looks like Johnny, but I don't know." She asks "Have you ever seen Mr. Depp in the state he's depicted in this photo before?;" response "I don't recall."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 28) "Do you recall ever seeing this photo before?;" response "Never saw it." She asks (pertaining to Exhibit 29) "Do you recognize this bag, the things in this bag?;" response "No."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 30) "Have you ever seen this photo before?;" response "No." She asks (pertaining to Exhibit 31) "Have you seen this photo before?;" response "No."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 31) "I'm going to direct your attention to this box that says 'Property of JD' w/ a skull & crossbones. Have you ever seen Johnny Depp w/ this box before?;" response "No."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 32) "Have you ever seen this picture before?;" response "No." She asks "Do you recognize the person in this photo?;" response "Yes." She asks "Who is it?;" response "Johnny Depp."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 33) "Have you seen this picture before?;" response "No." She asks "Do you recognize the person in this picture?;" response "Yes." She asks "Who is the person in this photo?;" response "Johnny Depp."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 33) "Can you tell what Mr. Depp is doing in the picture?;" response "I'm not sure." She asks (pertaining to Exhibit 34) "Have you seen this picture before?;" response "No."

Ms. Bredehoft asks Ms. Jacobs (pertaining to Exhibit 34) "I'm pretty sure if I ask you if you recognize the person's hand in there, you're going to say you don't. Would you agree w/ that?;" response "Correct." She asks "Do you recognize what's in that hand?;" response "No."

Mr. Marmmorstein asks Ms. Jacobs (pertaining to Exhibit 34) "Do you recognize what's in that? What is that?;" response "It looks like a cigar. I have no idea." Ms. Bredehoft asks "Were you aware that Mr. Depp filed a lawsuit in the UK against Sun Newspapers, and ...

Dan Wootton, b/c they called him a wife b*ater?;" response "Yes." She asks "Did you follow any of the press, publicity associated w/ that litigation & the trial?;" response "Sometimes." She asks "Do you know if any of the pictures & video that I just showed you from ...

Exhibit 12-34 were Exhibits in that trial?;" response "No."

This concludes the excerpt of Tracey Jacobs' 1/28/21 deposition.

Pages 129-131 is the Declaration of Camille Vasquez. I'm just attaching it, as it is not revelatory, just from Ms. Heard's Motion, SOP.

@threadreaderapp please unroll.