This thread will pertain to Mr. Depp's opposition to Ms. Heard's Motion to Compel Responses to 10th Requests for Production of Documents: fairfaxcounty.gov/circuit/sites/…
The hearing before Judge Azcarate on this was July 2, 2021; we haven't heard how she ruled.
🤣Once again, Mr. Chew..."Ms. Heard's conduct in filing the present Motion is both typical & troubling. Most of the RFPs at issue are patently overbroad, harassing & improper." He then notes Ms. Bredehoft's refusal to Meet & Confer noting Ms. Heard should be sanctioned.
Pages 2-6 are Mr. Depp's objections to each RFP Ms. Heard is attempting to compel.
RFP 5: "Ms. Heard was not a party to the 'Other Litigation,' was not deposed in the 'Other Litigation,' & was not mentioned in Mr. Depp's Complaints."
RFP 6: "Ms. Heard has no valid basis to demand every document relied upon to generate financial records of Mr. Depp's companies over the past 10 years...Furthermore, [it] is not directed to the correct party...."
🤣Ms. Bredehoft again being schooled in Law School 101!
RFP 10, 24 & 25: "These...are vague & open-ended to the point of meaninglessness...It's improper. Ms. Heard must serve more targeted requests for reasonably identifiable categories of documents."
🤣I love when Mr. Chew schools Ms. Bredehoft!
RFP 11: "...rather bizarrely seeks 'all publications' evidencing or 'reflecting negatively' Mr. Depp's reputation....publications are just that, publicly available....Mr. Depp has no obligation...."
🤣Ms. Heard can collect millions of pages of Tweets, b/ can't search for these?
RFP 12, 14, 15, 17, 21: Mr. Chew notes Mr. Depp has produced documents in response; has produced recordings in response. "These RFPs should never have been the subject of a motion & should be denied." He also mentions Ms. Bredehoft refusing to meet & confer.
RFP 13, 16, 18: Ms. Heard is looking for documents 'overbroad' & 'vague' regarding Mr. Depp's loss of any role or commercial opportunity w/out specifying who the persons communicating even are. This is the objection.
RFP 19, 20 (Payments to 3rd parties): "RFP 19, Ms. Heard already has this information...."RFP 20 seeks information regarding any payments...to a laundry list of 49 individuals w/in the past 5 years...payments made to lawyers...Mr. Depp would be willing [to Meet & Confer].
RFP 22 & 23: "...are truly astounding. 22 demands all agreements, payments, communications w/ anyone [providing services to Mr. Depp]....23 demands all communications...relating to [SM] or any ISP relating to all services & charges...." Mr. Chew notes it is irrelevant to the case
Pages 8-20 are emails. I'm going to address the emails, post then w/ a summation, b/ without the personal information of the sender or recipients.
From Mr. Moniz to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. He's responding to her continued unsubstantiated accusations & schooling her in VA law pertaining to Meet & Confer, which she's been unwilling to reasonable do per the law.
From Ms. Bredehoft to Mr. Moniz, CC'd to the legal counsel of Mr. Depp & Ms. Heard. She disagrees @ not complying w/ VA law on Meet & Confer; she addresses discovery issues; disagrees her client is Contempt for not producing via Court Order. Notice she copy/pastes; unprofessional
From Mr. Moniz to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. He again calls her out on her repeated accusations & insinuations in emails; explains Mr. Depp's opposition to Ms. Heard's RFPs, Tracey Jacobs; addresses anticipated Motions by Mr. Depp.
Cont...From Mr. Moniz to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. He again calls her out on her repeated accusations & insinuations in emails; explains Mr. Depp's opposition to Ms. Heard's RFPs, Tracey Jacobs; addresses anticipated Motions by Mr. Depp.
From Ms. Bredehoft to Mr. Moniz, CC'd to the legal counsel of Mr. Depp & Ms. Heard. She continues to make unsubstantiated accusations; addresses Mr. Depp's opposition to Ms. Heard's RFPs; cites an email she sent to Mr. Chew on this matter.
🙄She accuses, is combative, demands.
From Mr. Moniz to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. He addresses her accusation Meet & Confer requests are 'harassment;' says he will sent a more detailed summary of Mr. Depp's objections; asks for a Meet & Confer again.
From Ms. Bredehoft to Mr. Chew, CC'd to the legal counsel of Mr. Depp & Ms. Heard. She starts off insulting him; makes unsubstantiated accusations @ Mr. Moniz's emails; whines @ the Meet & Confer disagreement; suggest he looks at his records again.
From Mr. Chew to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. It's straight to the point, it's her refusing to Meet & Confer; Ms. Heard is in Contempt of Court, by not complying w/ Judge Azcarate's Court Order; @ her misleading the court in filings.
From Mr. Moniz to Ms. Bredehoft, CC'd to the legal counsel of Mr. Depp & Ms. Heard. It simply is once again a polite request to Meet & Confer.
Pages 21-24 are an excerpt from a hearing before Judge White, November 20, 2020. I'm not going into too much detail b/c we've seen this previously, b/ I can't resist reposting Judge White's admonishment to Ms. Bredehoft.🤣
Pages 25-77 is the Complaint in Mr. Depp's lawsuit against Rob & Joel Mandel TMG.
A motion in limine is a motion filed by a party to a lawsuit which asks the court for an order or ruling limiting or preventing certain evidence from being presented by the other side during trial of the case. Generally, this motion is filed in advance of the trial, but a...
motion may be entertained by the court during a trial, before the evidence in question is offered. The purpose of this motion is to prevent the interjection of matters which are irrelevant, inadmissible or prejudicial.
Below I'll post key points I think merit mentioning.
Let me correct @cocainecross's malicious, pathetic & desperate thread by a supporter of Ms. Heard's that blocked me prior to posting, knowing full well, I was a threat because I rely on facts, evidence, not Ms. Heard's word as a pathological liar & Ms. Bredehoft's misinformation.
I find it offensive Depp supporters are relegated to "fans," when the reality is we are men/women of all ages, from all across the world, some fans, some not, many abuse survivors, survivors of false allegations. A lawyer, @aburkhartlaw paid $3K+ in the interest of transparency.
I am a man. Men of a certain age face erectile dysfunction. Ms. Heard, a violent narcissistic sociopath, could cause erectile dysfunction, psychologically. It's irrelevant, doesn't prove sexual violence, which a unanimous jury via evidence found to have never happened.
In the unsealed Fairfax Court documents, 'Second Notification of Judicial Notice of Adjudicated Facts & Law Impacting this Matter,' from July 2021, that @aburkhartlaw has provided is with there are a few interesting things to note: img1.wsimg.com/blobby/go/a5c6…
Mr. Justice Nicol's ruling from 11/2/20, notes regarding the alleged 'Hicksville' sexual violence claims, now proven false, he found it suspect that Amber Heard never mentioned these allegations until 2020. Ms. Heard didn't allege sexual violence until 2019, that's suspect too.
In the Confidential Annex to her 1st statement, Ms. Heard who via evidence, CCTV footage, witness testimony was having a sexual affair w/ Elon Musk starting in March 2015, claims she couldn't even think of having sex again, after the falsely alleged Australia 2015 sexual assault.
Judge Azcarate granted Johnny Depp's Motion for an Independent Mental Examination (IME) of Amber Heard. Dr. Curry performed that mental health examination & diagnosed Ms. Heard with a combination of borderline personality disorder & histrionic personality disorder.
Let's take a look at the newly unsealed Memorandum of Law in support of Johnny Depp's Motion to Compel an IME of Amber Heard, that @aburkhartlaw has provided: img1.wsimg.com/blobby/go/a5c6…
Once again, Amber Heard opened Pandora's Box, it's apparent in the opening of the Memorandum, Johnny Depp had no intention of seeking an IME, until Amber Heard gave notice of Dr. Hughes examination of her & intention to testify as a clinical & forensic psychologist, to IPV, PTSD.
Steven Robertson: "Our concept was that Johnny [Depp] was to play the role of a retired adventurer, & his shop is this wonderful world of curiosities & trinkets, each representing a story from his colorful past." lbbonline.com/news/johnny-de…
Steven Robertson: "By condensing the action into this complex set piece, we were able to really focus on the character that [Johnny Depp] created and let his performance serve as the gateway into what 'Sea of Dawn' is really all about."
Scott Carson: "Phillip knows that Anselm is a bill collector, so he’s going to dazzle him with all of his quirky tales & fanciful objects, & maybe he’ll forget he's collecting a debt & be inspired. The portrayal & the characterization – the speech, the delivery, the...
"If someone is familiar with the name George Jung, it is most likely due to the film Blow, starring Johnny Depp. Now, thanks to Clint Choate’s docuseries Boston George: Famous Without The Fortune,...[George Jung can tell his story in his words...." filmthreat.com/reviews/boston…
"...There is much to love about what Choate accomplishes with Boston George: Famous Without The Fortune. Jung is still as sharp-tongued as ever, pitching out sarcastic comments to his friends with the greatest of ease. The man’s meeting with a friend he hasn’t seen since...
1974 is filled w/ caustic barbs, yet it is evident that he means them from a place of love; it is sort of like how you can make fun of your siblings, b/ God help anyone else who does. Furthermore, his sense of humor makes it relatively easy to empathize & even root for the man."