590 canonical items of evidence consolidated from 189 proceedings.
Each card deep-links to the testimony where the exhibit was introduced or discussed.
Type
Status
Location
Photographs (90)
Australia House — Bar Area Photos (Exs. 1816, 1817, 1820, 1821)
Photographs of the downstairs bar area in the Gold Coast, Australia rental house, showing blood, glass, tissue on the floor, and a possible wall-mounted telephone. Multiple witnesses across multiple trial days used these photos to illustrate the scene where Depp's fingertip injury occurred and where Heard alleged a bottle was used in a sexual assault.
Extensively cross-examined from both sides: Depp and his team used them to locate the blood from his severed fingertip and to identify a bottle used in the incident, while Heard's attorneys used them to challenge whether a wall-mounted phone was present during the incident and whether the glass visible in the photos constituted a full handle of vodka, contesting key details of Depp's testimony.
Photographs of bathroom mirrors in the Gold Coast, Australia rental house bearing messages written in black oil paint and red lipstick, including "Starring Billy Bob and Easy Amber" and the inscription "Call Carly Simon. She said it better, babe." Depp attributed the black oil-paint writing to himself and the red lipstick line to Heard; house manager Ben King confirmed he personally cleaned the mirrors that night and identified the materials, though he could not determine the layering order.
These photos were central to competing narratives about the Australia incident: Depp presented the mirror writings as evidence of his emotional state and jealousy, while Heard's attorneys questioned the authorship of the "Carly Simon" lipstick inscription as implausible self-directed writing by Depp, and used the photos to challenge his account of events during the multi-day altercation.
Photograph of Depp passed out with ice cream spilled on him, taken during the Black Mass filming period. Heard sent the photo to Raquel Pennington on August 7, 2014 with the message 'This is what I've been dealing with.'
Vasquez used the photo and accompanying message to Pennington to challenge Heard's claim that she documented Depp purely for his own benefit. Expert Spiegel testified that falling asleep with ice cream is inconsistent with normal Seroquel use, indicating a supra-therapeutic or misused dose; Dennison countered that the substance Spiegel characterized as vomitus could instead be ice cream.
Multiple photographs of Heard's face from May 21, 2016 showing facial redness, including two photos sharing an identical timestamp of 9:25:12 PM but differing in brightness and redness, and two photos described as having identical filenames but differing redness. Shown to witnesses Saenz and Hadden, who respectively attributed the redness to crying rather than injury and saw no injuries.
The identical-timestamp and identical-filename discrepancies, combined with Neumeister testimony regarding an editing application, formed a central pillar of the plaintiff's argument that the injury photographs had been digitally manipulated to exaggerate redness.
Graphic emergency room photograph of Johnny Depp's severed right middle finger sustained during the Australia incident. The photograph provides a clear profile of the injured fingertip, including detail of the fingernail and surrounding tissue, and was shown to multiple witnesses across several days of testimony.
Admitted as documentation of Depp's most severe physical injury, attributed by plaintiff to Heard throwing a vodka bottle. Used by Depp himself, Dawn Hughes, and Richard Moore — each drawing different conclusions about the injury's severity and mechanism. Dennison used it alongside PX 145 to challenge any characterization of Depp's injuries as less serious than Heard's.
Self-portrait photograph taken by Heard on March 23, 2013, depicting a bruise on her upper arm, which she sent to her mother. The photograph was introduced at trial to corroborate Heard's account of a March 2013 physical altercation with Depp, and was also shown to Bruce Witkin to compare to a bruise he testified observing.
Admitted without objection and published to the jury, providing documentary corroboration of Heard's claim that she sustained injuries in March 2013. On cross-examination, Vasquez highlighted that the photo showed a bruise on the arm but no visible facial injuries, despite Heard's testimony that Depp struck her in the face while wearing rings.
Defendant's Exhibits 710, 712, 713, and 714, consisting of May 21, 2016 face photographs of Heard. Exhibits 712 and 713 appear visually different but share identical timestamps (hour, minute, second) and identical filenames. Admitted in unredacted 712A/713A form, those versions contain metadata indicating a capture date of December 21, 2016.
The timestamp and filename discrepancies, which Ackert could not explain without software metadata analysis he had not performed, supported Depp's team's editing argument; the December 2016 capture date in the metadata further contradicted the claimed May 2016 origin of the photographs.
Photograph depicting a clump of hair on the floor, associated with the December 15–16, 2015 incident at Depp's penthouse. iO Tillett Wright identified this as the clump of hair he was shown at penthouse 3 on December 16, 2015; during cross-examination, Depp's counsel challenged the timing between the alleged incident and when Wright claims to have observed the hair.
Physical corroboration of hair loss during the December 2015 incident. Depp's team attempted to undermine the photograph's evidentiary weight by questioning the interval between the alleged incident and Wright's observation.
December 2015 Heard Injury Photos — Anderson Recollection
Unclear
Photographs of Heard's facial bruising, including bruising around the eyes, shown to couples therapist Laurel Anderson by Heard around the time of the December 15, 2015 incident. Anderson also personally observed small bruises approximately one inch in size in more than one location on Heard's face when Heard came to her office on December 17, 2015.
Anderson confirmed the in-person bruising she observed was consistent with the photographs, providing clinical corroboration of Heard's December 2015 injuries, though Anderson acknowledged she could not fully memorize the photograph details.
Photographs depicting Heard's scalp injuries and hair loss associated with the December 15–16, 2015 incident. iO Tillett Wright identified them as consistent with scalp injuries he personally observed at penthouse 3 on December 16, 2015; Raquel Pennington authenticated Pennington Exhibit 6 as depicting the scalp wound she observed on December 15, 2015.
Multiple witnesses authenticated photographs of Heard's scalp injuries, providing layered corroboration for testimony about hair being pulled during the December 2015 incident.
Depp Passed Out on Bahamian Island, July 2013 (Def. 1091)
Admitted
Defendant's Exhibit 1091DX-1091
Photograph taken by Heard showing Depp passed out on Depp's Bahamian island in July 2013, described by Heard as showing him 'on the nod.'
Heard testified this was among the first of a series of photos she took to document Depp's alleged substance abuse. Depp's team challenged whether the documentation reflected genuine concern or an effort to build leverage against him.
Depp Passed Out on Floor in Tokyo, July 2013 (Def. 1090)
Admitted
Defendant's Exhibit 1090Defendant's 1090
Photograph taken by Heard showing Depp passed out on the floor in Tokyo in July 2013.
Part of the incapacitated-Depp photo series; Vasquez challenged whether Heard documented Depp out of concern or to use the photos against him. Expert Spiegel testified the degree of incapacitation reflected is consistent only with pharmacological assistance.
The plaster splint applied to Johnny Depp's third and fourth fingers following surgery on March 20, 2015, described during David Kulber's testimony. On redirect, Kulber clarified that the splint was a partial plaster, non-circumferential, soft-sided construction.
Establishes the physical constraints on Depp's hand use during the disputed Australia timeline; the splint's specific design and limitations were clarified on redirect to address questions about what Depp's injured hand could or could not do.
A photograph of the carpeting or flooring in the hallway area near the penthouse elevator, showing a reddish stain or discoloration. The same image was introduced during the examinations of both Officer Saenz and Officer Hadden.
Defense used the photo to probe whether the officers had observed or documented signs of property damage during their protective sweep of the building; both officers testified they did not notice the stain during their respective visits.
Photographs depicting long, uniform cuts on Heard's arm and wrist area, documented after the Australia incident. Ben King identified the cuts as consistent with what he observed on Heard during the flight back to Los Angeles; iO Tillett Wright separately identified cuts consistent with injuries he saw after Heard returned from Australia.
Admitted despite Depp's foundation objection and offered to corroborate Heard's claim of physical injury during or after the Australia incident. King's in-person observation of the cuts during the LA flight, combined with Wright's separate identification, provided layered corroboration for Heard's injury account.
Heard Injury Photos — Admitted via Lay Witnesses (Metadata Excluded)
Admitted
Photographic evidence of Heard's purported injuries admitted as screenshots and screen grabs through lay witnesses during Heard's defense case, with EXIF metadata excluded by prior court ruling. These photographs were central to the dispute over the proper scope of Neumeister's testimony as a rebuttal expert.
Depp's team argued the admission of these photos through lay witnesses made Neumeister and his colleague Collins newly relevant as rebuttal experts, but the court rejected that position, constraining the metadata-based authenticity challenge.
Opening statement previews of Heard injury photographs, with the plaintiff's preview challenging forensic authenticity by noting non-original files in an editing program, and the defendant's preview citing the photos as corroboration of abuse allegations including bruises, cuts, black eyes, and hair loss with metadata.
Established competing narratives about the injury photo record at the outset of trial: authenticity and editing concerns raised by Depp's team versus evidentiary corroboration of abuse asserted by Heard's team.
March 2013 Breakfast Table Cocaine Lines (Def. 167A)
Admitted
Defendant's 167ADefendant's Exhibit 167A
Photograph taken by Heard at her Orange apartment circa March 22, 2013, showing four lines of cocaine arranged on a breakfast table alongside a drug box labeled 'Property of JD' and brown liquor, with a cigarette in an ashtray.
Heard offered this photo to document Depp's substance use during the March 2013 painting incident, identifying the items on the table in detail. Vasquez cross-examined whether the pristine, residue-free table actually depicted active cocaine use or a staged scene.
Photographs of Heard's injured face taken at the penthouse on the night of May 21, 2016, designated as Exhibit 42 and taken by Raquel Pennington. Pennington identified a swollen and red right cheek and eye in the images.
Marz's recollection that Pennington photographed Heard's face that night corroborated the documentary evidence of injury, reinforcing the contemporaneous nature of the photographic record.
A demonstrative exhibit, designated PX1303, showing three versions of the same injury photograph with mismatched file sizes that would not hash or digitally fingerprint consistently. Ackert later used the same demonstrative to explain why hash mismatches are expected and benign in Apple ecosystem photo handling, where emailing or resizing alters hash values without altering visual appearance.
The competing uses of PX1303 — by Neumeister to suggest tampering and by Ackert to explain normal Apple ecosystem behavior — made it a focal point in the jury's assessment of whether file-size and hash discrepancies indicated manipulation.
Emergency room photograph showing a cigarette burn wound on Johnny Depp's cheek, taken during the Australia incident. The photograph is among the images associated with Depp's hospital visit and documents an injury Depp attributed to Heard during the altercation.
Corroborates Depp's account of the cigarette-burn component of the Australia altercation. Hughes acknowledged the injury was severe; Dennison used it alongside PX 144 to challenge any framing of Depp's injuries as characteristically low-level.
A summary chart, designated Defendant's Exhibit 1675, listing IDS evidence numbers, source types distinguishing physical devices from iTunes or iCloud backups, and device details for all Heard evidence collected. Published as a demonstrative exhibit.
The chart established the provenance of the full evidence collection — covering an iPhone X, iPad Pro, three laptops, and cloud and iTunes backups — underpinning the chain-of-custody foundation for Ackert's conclusion that original photographs were available.
A chart, designated Defendant's Exhibit 1671, mapping each item in Neumeister's report to the corresponding original photograph found on Heard's devices, with columns for date captured and evidence ID. Published as a demonstrative exhibit.
The chart was the core visual aid for Ackert's rebuttal, demonstrating that original iOS-metadata photographs existed on Heard's physical devices for each item Neumeister had flagged, directly countering the claim that no unmodified originals were available.
Photograph of Depp in an incapacitated state presented during expert psychiatric testimony.
Presented to corroborate the substance use disorder evidence in Spiegel's testimony; Spiegel attributed the incapacitation depicted to legal or illegal pharmacological assistance.
A series of photographs of the Gold Coast, Australia rental house interior and grounds, spanning exhibit numbers DX-1804 through DX-1842, introduced by Heard's team.
Admitted to establish the physical layout of the Australia house for the jury's understanding of Heard's account of three days of alleged abuse during the March 2015 Australia trip.
Multi-page floor plan of the Gold Coast, Australia rental house introduced by Depp's team.
Used to geolocate property damage and the discovery of Depp's severed fingertip across the three floors of the Australia house, providing the jury with spatial context for witness testimony.
Photograph of a lampshade from the main-level art studio of the Gold Coast, Australia rental house, showing a painting applied to its surface.
Ben King identified the lampshade as missing from one of the lamps he found during the post-incident cleanup, corroborating his account of the extent of property damage throughout the Australia house.
Photograph taken at the Gold Coast, Australia rental house showing canvases of Heard that had been completely painted over.
Displayed to psychiatrist David Spiegel during examination to ask whether property destruction of this type correlates with intimate partner violence perpetrator risk factors; a sidebar limited his response to risk-factor framing rather than direct conclusions about abuse.
Photograph from the Gold Coast, Australia rental house depicting destruction of property.
Displayed to psychiatrist David Spiegel as visual evidence of behavior he characterized as intimidation and psychological abuse consistent with intimate partner violence risk factors; a subsequent sidebar reinforced the court's instruction that Spiegel must frame his answers in terms of risk factors.
An audio clip, approximately at the 33–34 minute mark, capturing Johnny Depp's voice at the Australia rental house on or around March 8, 2015.
Played during cross-examination of security guard Malcolm Connolly, who confirmed the recording reflected Depp's upset and angry state that day, corroborating the defense characterization of Depp's demeanor during the Australia incident.
An audio recording captured during the cleanup of the Gold Coast, Australia rental house, featuring the voice of Jerry Judge, Depp's former head of security, who has since died.
Excluded as hearsay because Judge was deceased and no foundation could be laid for his statements or knowledge; the exclusion blocked a potentially significant contemporaneous account of the cleanup scene from reaching the jury.
Photographs of Johnny Depp's facial injuries taken by security guard Sean Bett on multiple occasions, referenced as the basis for Bett's stated safety concern for Depp. The specific exhibits are authenticated in Bett's direct examination but are not individually identified in this reference.
Collectively form the documented injury record Bett maintained for Depp's protection; referenced as the evidentiary basis for Bett's testimony about his ongoing security concern.
Defendant's Exhibit 509, a photograph of a broken bed frame that Heard testified documented damage from the December 15, 2015 incident. Cross-examination noted an unidentified object visible on the bed and the absence of pillow-blood photographs.
Heard attributed the bed frame damage to Depp; Vasquez's cross-examination challenged the completeness of the photographic record by pointing to unexplained elements in the image.
December 2015 Heard Facial Injury Photos — Drew Exhibit 11
Unclear
Drew 11
A set of photographs depicting Heard's facial injuries from December 15, 2015, attached as exhibit 13 to Heard's deposition declaration. Josh Drew confirmed he was present during the photography and that the images were consistent with injuries he personally observed on Heard's face that day.
Drew's eyewitness authentication provided direct confirmation that the photographs accurately depicted Heard's facial injuries on December 15, 2015.
December 2015 Heard Injury Photos — Defendant's 516 and 517
Unclear
Defendant's Exhibit 516Defendant's Exhibit 517
Two photographs of Amber Heard introduced during her direct examination as depicting injuries sustained in the December 15, 2015 incident. The photographs were displayed again during cross-examination in connection with James Corden footage.
Part of Heard's primary injury documentation for the December 2015 incident on direct examination; Vasquez used the photos alongside the Corden footage during cross to challenge Heard's account.
December 2015 Heard Injury Photos — Inglessis Set (Exhibits 14–19)
Unclear
Exhibit 14Exhibit 16Exhibit 17Exhibit 19
Four photographs of Amber Heard depicting injuries on December 16, 2015, authenticated by makeup artist Melanie Inglessis, including one specifically depicting a lip injury. Inglessis noted that three of the photographs showed the injuries under varying lighting conditions but confirmed each accurately depicted Heard's condition on that date.
Inglessis's authentication from the perspective of someone who regularly observed Heard's face corroborated the injury documentation; her testimony about a split or gashed lip was supported by the lip photograph.
Photograph of Heard's swollen lip from around December 2015, authenticated by iO Tillett Wright as accurately depicting what he observed during his visit to penthouse 3 in December 2015.
Corroborates Wright's testimony about the specific nature of Heard's facial injuries following the December 15, 2015 incident.
A set of photographs authenticated by Raquel Pennington depicting Heard's bruising, scalp abrasions, hair loss, and property destruction in the penthouse following the December 2015 incident.
Pennington's broad authentication of this photo set provided documentary corroboration spanning both physical injuries and property damage from the December 2015 incident.
Photograph of the bar area at the Australia rental property where Ben King testified he discovered Depp's severed fingertip. The image shows a broken vodka bottle in the corner and blood drops on the floor.
Physical scene evidence of the Australia altercation's aftermath; introduced during Richard Moore's testimony, who noted he had not reviewed this image prior to testifying about the injury mechanism.
Red-carpet photographs of Amber Heard from April 2015 showing visible scars, introduced as evidence tied to the alleged March 2015 Australia countertop incident.
Visible-scar evidence offered to corroborate Heard's account of injuries sustained in Australia; the April 2015 date places the photographed scarring in close temporal proximity to the alleged March 2015 altercation.
A photograph of a penthouse floor that Heard, during her Day 16 testimony, attributed to the December 15, 2015 incident. The image was later placed side-by-side with Defendant's Exhibit 725 during impeachment.
Placed alongside Exhibit 725 to demonstrate that Heard had attributed what appeared to be the same or nearly identical photograph to two different incidents on different days of her testimony, calling her credibility into question.
A redacted photograph of a penthouse floor that Heard, during her Day 17 testimony, testified depicted spilled wine in Penthouse 5 on May 21, 2016. The image was displayed alongside Defendant's Exhibit 512 during cross-examination.
Displayed alongside Exhibit 512 to confront Heard with conflicting testimony attributing what appeared to be the same photograph to two separate incidents, undermining the reliability of her photographic evidence attributions.
A photograph of a damaged bed in the penthouse bedroom, introduced through Melanie Inglessis's deposition in connection with her account of damage observed during her December 2015 penthouse visit.
Corroborated Inglessis's account that she observed a broken bed upstairs during her visit, providing witness-authenticated photographic evidence of December 2015 penthouse damage.
Photographs of Johnny Depp showing alleged bruises, introduced by Depp's team and including at least one attributed to Sean Bett, referenced by Rottenborn in a procedural argument about prior admission practice.
Rottenborn cited these photos — shown by Depp's team without objection despite bearing timestamps — as precedent supporting a waiver argument regarding analogous timestamp-bearing evidence offered by Heard's team.
A photograph of the kitchen counter in Penthouse 3 showing handwriting attributed to Depp reading 'Why be a fraud. All is such bullshit.' Josh Drew identified the handwriting as Depp's and confirmed the photograph accurately reflected the scene.
The primary photographic exhibit for the December 15, 2015 kitchen scene; Drew's identification of the handwriting directly connected Depp to the physical marking left in the penthouse.
Photographs depicting damage inside Penthouse 5 from the May 21, 2016 incident, including Heard's closet area and a stairwell landing.
Drew identified the locations depicted but had no knowledge of who caused the closet damage; the images documented additional property damage extending into Penthouse 5.
DX360 pp.09-10 — X-rays, Comminuted Fracture of Distal Phalanx (Moore)
Unclear
DX360, pages 09–10
X-rays of Depp's injured right middle finger showing a comminuted fracture of the distal phalanx, introduced as a demonstrative during Richard Moore's testimony.
Moore identified a shattered tuft and transverse fracture as hallmarks of a crush injury, testifying these findings are inconsistent with the mechanism of a thrown-bottle impact.
DX369 p.26 — Clinical Photo, Palmar Tissue Loss and Intact Nail
Admitted
DX369, page 26
Clinical photograph of Depp's injured finger showing palmar tissue loss on the underside of the fingertip with an intact nail, introduced during Richard Moore's testimony.
Moore used this image to demonstrate that the injury pattern is an avulsion on the underside of the finger, which he testified is inconsistent with a top-down bottle strike.
Excluded — Heard Face Photo with Depp Handwritten Note
Excluded
Defendant's 1783
A photograph of Heard's face accompanied by a handwritten note from Depp, which Heard's team sought to introduce during her direct examination. The item was excluded after a sidebar on the grounds that it was produced after the discovery cutoff from devices in Heard's possession.
The exclusion, sustained on Vasquez's discovery-cutoff objection, prevented the jury from seeing both the photograph and the accompanying handwritten note, limiting evidence Heard's team sought to present.
A photograph or document shown to Officer Saenz during cross-examination in connection with questions about whether she observed any disarray during her protective sweep of the penthouses.
Saenz confirmed she saw nothing in disarray during either penthouse sweep, undermining the premise that visible damage would have been noticed and documented by responding officers.
A photograph of writing on the kitchen wall of Depp's penthouse, introduced through Melanie Inglessis in connection with her account of damage she observed during a December 2015 visit.
Corroborated Inglessis's testimony that she personally witnessed penthouse damage, including writing on surfaces, during her December 2015 visit.
A set of ten photographs documenting property damage across Penthouses 3, 4, and 5 following the May 21, 2016 incident, including broken glass on staircases, overturned furniture, and scattered jewelry materials.
Pennington identified damage spanning multiple penthouse units and attributed it to Depp, providing photographic corroboration of her eyewitness account of the extent and character of the destruction.
Heard Alleged Injury Photos Shown to Inglessis — Exs. 14–20
Unclear
Exhibits 14–20
Photographs of Amber Heard's alleged injuries, designated as Exhibits 14 through 20, shown to Inglessis during direct examination. Vasquez established on cross that Inglessis did not take any of these photographs and did not recall personally taking photos with Heard's or Pennington's phone.
The cross-examination concessions limited Inglessis's personal connection to the photographic record, reducing her ability to independently authenticate or corroborate the images beyond what she could observe in them.
Photographs apparently of Heard, designated as Defendant's Exhibits 7, 8, and 9, shown to witness Gatlin during a video review. Bredehoft asked Gatlin to connect the person depicted in the photos to the person visible on the sofa, but Gatlin was unable to make that connection.
Gatlin's inability to identify the person in the photographs limited the evidentiary weight of these images as corroboration of Heard's presence or condition at the relevant time.
A photograph of Heard's injuries authenticated by Raquel Pennington as a photograph she recognized. No specific date for this exhibit is identified in the available record.
Authenticated by Pennington as part of her testimony regarding Heard's injuries.
Photographs published in People magazine in June 2016 depicting Heard with injuries, designated as Plaintiff's Exhibit 409. Vasquez established these photos were given to People during the contentious divorce, while Heard testified she gave them only to lawyers and representatives.
The conflicting accounts of how the photos reached People magazine were relevant to the question of whether Heard orchestrated media coverage of her alleged injuries as part of a broader public relations strategy.
Heard Injury Photos with Metadata — Def. 700–726 Proffer
Unclear
Defendant's Exhibits 700-726
Defendant's Exhibits 700 through 726, photographs with associated metadata, subject to a Nadelhaft proffer in which the metadata was excluded as hearsay without foundation. The proffer was made to preserve the appellate record on the metadata ruling.
Although the metadata was excluded from the jury's consideration, the proffer ensured that the evidentiary and legal basis for admitting it remained part of the appellate record, preserving the issue for post-trial review.
A photograph of Amber Heard's scalp showing a missing chunk of hair, designated as Exhibit 11. The image constitutes physical evidence of a scalp injury.
Inglessis recognized the injury depicted as consistent with what she observed on December 16, 2015, though she could not recall associated bruising or pus along the scalp, partially limiting her corroboration of the full injury picture.
iTunes backup extractions of Heard's injury photographs, characterized by Neumeister as third-generation backups lacking system-level data. Neumeister relied on this characterization to conclude that no forensic validation of any analyzed photograph was possible.
The third-generation backup classification was foundational to Neumeister's forensic-inauthenticity argument, as the absence of system-level data meant he could not verify the origination or chain of custody of the images.
A set of photographs taken on the night of May 21, 2016, including images of marks on Heard's face, a broken bed frame, red wine staining in the hallway, and broken picture frames on a wall.
Provided photographic corroboration of Marz's eyewitness testimony, documenting both physical injury to Heard and structural damage to the penthouse consistent with her account of the incident.
Elizabeth Marz's eyewitness account of wine spilled in the hallway of the Eastern Columbia Building, observed during her visit on the night of May 21, 2016. No specific photographic exhibit was introduced for this observation.
Physical evidence of destruction consistent with Marz's account of Depp wielding a wine bottle; the hallway location placed evidence of the incident outside the penthouse units.
A list of items allegedly destroyed in Penthouse 3, including candelabra sticks, food, kitchen utensils, and a lamp, discussed during Elizabeth Marz's examination without a specific exhibit being admitted.
Vasquez used the list to test Marz's recollection; Marz could not confirm seeing the items, raising the inference that she entered the penthouse after cleanup had occurred.
Photographs of Heard's injuries from May 2016, shown to Alejandra Romero, a building front desk employee. Used to prompt Romero's concession that the swelling depicted was significant enough that she probably would have remembered it.
The concession undermined Romero's prior statement that she had noticed no injuries on Heard, weakening testimony offered to contradict the injury record.
May 21 Photos and Wine Bottle — Cross Exclusion Ruling
Excluded
May 21 photographs and a wine bottle photograph that were the subject of a ruling excluding them from cross-examination. Vasquez argued the photos showed a discrepancy between Heard's deposition testimony and her redirect testimony about which incident they depict.
The exclusion ruling limited the cross-examination's ability to exploit the claimed discrepancy between Heard's deposition and trial testimony regarding the incident depicted in these photographs.
May 21, 2016 Face Photos Sent to Falati at 12:36 a.m.
Unclear
Exhibit 11 (Falati 114–119)
Four photographs of Heard's face, designated as part of Exhibit 11 (Falati 114–119), sent to nurse Erin Falati at 12:36 a.m. around May 21, 2016. The photos show Heard's appearance in the hours immediately after the May 21 incident.
The absence of corresponding nursing notes from Falati was noted in connection with these photographs, raising questions about the clinical response to the depicted injuries.
May 21, 2016 Night Photos by Drew — Injuries and Apartment
Unclear
Drew 13
A series of photographs taken on the night of May 21, 2016, designated as Drew Exhibit 13, depicting Heard's facial injuries, apartment damage including broken glass and pictures off walls, spilled wine in the hallway, and a wine bottle in PH5. Drew confirmed the photos were taken by him or Pennington and were shown to the first responding police officers.
Drew's confirmation that the photos were shown to the responding officers and were neither staged nor manipulated lent contemporaneous law enforcement context to the documentary injury record from that night.
A set of twenty-one photographs (Defendant's Exhibits 706–726) documenting Heard's face and penthouse damage following the May 21, 2016 incident. These are the same exhibits previously shown to Officers Saenz and Hadden during their depositions.
Introduced during Heard's testimony to anchor her account of the May 21 incident for the jury, connecting the photographic record to the officers who had been shown the images in deposition.
Photographs of Heard's face taken on May 22, 2016, the day after the May 21 incident, designated as Drew Exhibit 14. Drew confirmed they were taken by him or Pennington and were consistent with his recollection of Heard's appearance that day.
Drew's denial of any staging or use of makeup to exaggerate injuries supported the authenticity of the photographic record and its consistency with his personal observation of Heard's condition the following day.
May 27, 2016 Courthouse Interior Photos — DX-800/801
Admitted
DX-800, 801
Defendant's Exhibits 800 and 801, photographs of Heard inside the courthouse on the day she obtained her domestic violence restraining order. Vasquez framed the images as a staged photo shoot.
The photographs were used to contradict Heard's stated desire for privacy on the day she filed the DVRO application, suggesting instead a deliberate media-facing presentation.
May 27, 2016 Courthouse Photo with Publicist — Def. 799
Admitted
Defendant's Exhibit 799
A photograph, designated Defendant's Exhibit 799, showing Heard with her publicist Jody Gottlieb at the courthouse on May 27, 2016, the day she obtained the domestic violence TRO against Depp.
The photograph was used to establish that Heard brought her publicist to the courthouse on TRO filing day, undermining her claim of surprise at the media presence and supporting the argument that the event was strategically managed for public relations purposes.
May 27, 2016 Courthouse Photos by Pennington — Exhibit 46
Admitted
CourtPennington 1292, 1295, Exhibit 46
Courthouse photographs of Heard taken on the day of her domestic violence restraining order application, designated as Exhibit 46 and identified by numbers CourtPennington 1292 and 1295. The images show bruising on Heard's right cheekbone days after May 21, and Pennington confirmed she took them and that Heard wore no makeup.
The bruising visible days after the May 21 incident, combined with Pennington's confirmation of no makeup, strengthened the evidentiary foundation for the injury claims underlying the DVRO application.
Two photographs of Amber Heard and Raquel Pennington, designated as Plaintiff's Exhibits 1316 and 1317, taken on a May 28, 2016 outing and published in a May 30, 2016 article; one photograph also includes Josh Drew. Admitted during cross-examination.
The photographs were used to argue that no visible bruise was present on Heard's face the day after the penthouse incident, contradicting the injury narrative and the contemporaneous photographic record from May 21 and May 27.
A demonstrative exhibit, designated PX1304, showing EXIF data excerpts from multiple injury photographs, each bearing the notation "Photos 3.0" in the software field. It served as the primary visual evidence of the editing-software marker across the photo set.
The consistent presence of the "Photos 3.0" software marker across multiple photographs was the central basis for Neumeister's opinion that the images had been processed through an editing application rather than being unaltered originals.
Neumeister Demonstrative PX1305 — Edited vs. Unedited Video
Excluded
PX1305
A video demonstrative exhibit, designated PX1305, showing a side-by-side comparison of a Photos 3.0 edited version and an iOS version of the same injury photograph. It illustrated the visible difference between edited and unedited versions for the jury.
The side-by-side visual comparison made the editing-software argument concrete and perceptible to jurors, translating technical EXIF metadata findings into an observable visual distinction.
Neumeister Demonstrative PX1306 — DX-712/713 Color Modification
Excluded
PX1306
A video demonstrative exhibit, designated PX1306, comparing Defendant's Exhibits 712 and 713, which Neumeister argued were the same photograph with colors modified in an editing program. It extended the editing-marker findings to a second photo pair on Heard's exhibit list.
By applying the editing-modification argument to a second photo pair already in evidence as defense exhibits, PX1306 broadened the scope of the authenticity challenge beyond the Photos 3.0 marker alone.
Photographs previously flagged by Bryan Neumeister for EXIF metadata concerns, revisited during Ackert's redirect examination. Ackert reaffirmed that he found no forensic inauthenticity in any of the photographs he analyzed.
The redirect reaffirmation reinforced Ackert's rebuttal of Neumeister's conclusions, presenting the jury with a direct expert-to-expert conflict on whether the flagged photographs showed evidence of manipulation.
A compilation of photographs from alleged abuse incidents including events in Russia, at the Met Gala, in Tokyo, in December 2015, and in May 2016, assembled by Depp's team to show no visible injuries on Heard.
Used by Depp's team to challenge Heard's testimony about serious injuries across multiple incidents, arguing the photographs undermine the credibility of her injury claims.
Photographs from Raquel Pennington's deposition, some of which had been previously admitted and others agreed upon during the designation process. The central question addressed in the ruling was whether iPhone timestamp display information would be shown to the jury alongside these photos.
The ruling on the iPhone timestamp display determined what contextual metadata the jury would see when evaluating the Pennington deposition photographs, directly affecting the weight those images could carry on timing and authenticity questions.
A photograph of a broken platform bed frame in the Penthouse 4 bedroom, authenticated by Raquel Pennington as depicting the broken bed she found on the evening of the incident.
Authenticated by Pennington as physical evidence of damage she personally observed, supporting her account of the state of the penthouse following the May 21, 2016 incident.
A photograph, designated Defendant's Exhibit 170A, discussed during Neumeister's direct examination and then introduced during cross-examination for his opinion on it. Murphy used it to establish that Neumeister offered specific testimony about a photograph he had not identified by exhibit number in his expert disclosure.
The exchange highlighted a potential scope-of-disclosure issue, suggesting Neumeister's trial opinions extended beyond what had been formally disclosed, which bore on the reliability and admissibility boundaries of his expert testimony.
Photo at Neumeister Cross — Defendant's 517 (No Opinion)
Unclear
Defendant's 517
A photograph, designated Defendant's Exhibit 517, shown to Neumeister during cross-examination. Neumeister conceded he was not offering any opinion about it.
The concession further narrowed the defined scope of Neumeister's expert opinions, excluding photographs not specifically addressed in his disclosure and limiting the reach of the authenticity challenge.
Plaintiff's Ex. 146 — Depp Swollen Cheekbone, circa March 2015
Admitted
Plaintiff's 146
Photograph of Johnny Depp's swollen upper left cheekbone, taken by security guard Sean Bett around March 2015. Bett authenticated the photograph and explained the protective purpose behind documenting Depp's injuries.
Physical documentation of a facial injury to Depp attributed to Heard; authenticated by Bett, who described his practice of photographing injuries as a safety record for Depp.
Two X-rays of Johnny Depp's right middle finger taken after the Australia injury, showing the comminuted fracture at the distal phalanx, published to the jury as a demonstrative during Richard Gilbert's testimony.
Gilbert used the X-rays to illustrate the comminuted fracture pattern and explain why the injury requires high-velocity force inconsistent with simple punching.
Series of photographs of Depp's healing right middle finger taken at a surgeon's office, showing the finger wrapped in kiddie bandages during recovery following the Australia injury.
Documents the ongoing nature of the finger injury through Depp's filming of Pirates of the Caribbean 5; Depp testified that CGI was required to remove the bandage in post-production.
Three-page set of photographs documenting Johnny Depp's facial scratch marks and bruising, taken by security guard Sean Bett in mid-December 2015. Bett authenticated each photograph and described each injury in detail for the jury.
Documents a second documented injury event distinct from the March 2015 Australia incidents; Bett's authentication provided the chain of custody and injury detail required for the exhibit's admission.
A video filmed by Heard on February 10, 2016, showing Johnny Depp slamming kitchen cabinets, pouring wine, and smashing glasses while yelling. The version TMZ received via a Dropbox link on August 12, 2016 — posted as a TMZ exclusive — was shorter than the trial version, missing opening setup footage and a closing segment in which Heard appeared to snicker at the camera. The footage was released online the night before Heard's August 2016 divorce deposition.
Heard's team introduced the video as proof of Depp's erratic behavior and impulse-control failures consistent with IPV perpetrator risk factors. Depp's team used TMZ employee Morgan Tremaine's observations about the discrepancy between the TMZ version and the trial version, the video's strategic timing of release before Heard's deposition, and TMZ's copyright ownership to argue Heard selectively edited and leaked the footage.
Eastern Columbia Building security footage showing Whitney Henriquez appearing to throw a fake punch toward Amber Heard in the elevator mezzanine area during the week of May 21, 2016; both women are visibly laughing in the clip.
Introduced by Depp's team to challenge the credibility of Heard's claimed visible injuries before her May 27, 2016 courthouse appearance. During Isaac Baruch's testimony, the court ruled he could describe what he personally observed but the footage was not formally moved into evidence through that examination.
Elevator surveillance footage and still photographs from the Eastern Columbia Building bearing timestamps 21:04:43 and 21:19:49 on May 21, 2016, showing Officers Saenz and Hadden on the penthouse floor.
Used to fix the duration of the police visit at approximately 15 minutes (9:04–9:19 p.m.), establishing how briefly the responding officers were present at the penthouse on the night of the incident.
Approximately 87 Eastern Columbia Building security camera clips from May 2016, authenticated by building general manager Brandon Patterson as true and accurate copies preserved since 2016, covering the mezzanine vestibule, lobby, elevator, call box, front desk, service corridor, penthouse elevator, and parking garage. Footage depicts Depp, Heard, Raquel Pennington, Whitney Henriquez, police officers, and building staff across May 21–25, 2016. One specific clip (Exhibit 3) shows Depp in the mezzanine vestibule; Patterson described him as 'animated' without audio and 'upset about something' once audio was available.
Depp's team used this corpus to document the movements of key individuals at the Eastern Columbia Building around the May 21, 2016 police-call incident. Patterson authenticated each clip as a business record, providing the primary contemporaneous visual record of activity in and around the penthouse during the relevant period.
Eastern Columbia Building elevator security video from the night of May 21, 2016, authenticated through front desk employee Alejandra Romero, showing Johnny Depp and his bodyguard in the elevator.
Played in court during Romero's testimony; Romero identified Depp and described him as visibly agitated and pacing, providing the only direct contemporaneous observation of Depp's demeanor from the incident night available through the building's camera system.
Surveillance video from the Eastern Columbia Building lobby showing Sean Bett, Johnny Depp, and a person identified as Judge entering the building at 19:02 (7:02 p.m.) on May 21, 2016.
Establishes an earlier-than-recalled arrival time and confirms the identities of the three men entering the building; combined with the departure footage, places the total stay at approximately 87 minutes — substantially longer than Bett's estimated 30–40 minutes.
Still frame from Eastern Columbia Building security footage dated May 21, 2016 at 22:28:15, showing both William Gatlin and Officer Diener together in the frame.
Corroborates the identities of both personnel present and the arrival time of law enforcement at the Eastern Columbia Building on the night of the incident.
Eastern Columbia Building surveillance video clips from May 24, 2016, shown to Alejandra Romero during cross-examination by Presiado.
Referenced by Heard's counsel to establish that Romero could not identify what makeup, if any, Heard was wearing in the footage, thereby limiting the weight of Romero's testimony that she observed no injuries on Heard.
Surveillance video from the Eastern Columbia Building showing Sean Bett, Johnny Depp, and a person identified as Judge departing the building at 20:29 (8:29 p.m.) on May 21, 2016.
Combined with the arrival footage, this clip places the total stay at approximately 87 minutes — substantially longer than Bett's estimated 30–40 minutes, undermining his characterization of the visit's duration.
TMZ Footage of Heard at Deposition Parking Lot, August 2016
Unclear
TMZ video footage of Amber Heard arriving at a parking lot adjacent to a law office for her deposition on August 6 and August 13, 2016. Tremaine confirmed that TMZ would not normally cover a law office parking lot and that the tips came through a news producer and were not independently verified by him.
The unusual nature of TMZ covering a private law office parking lot, combined with unverified tips routed through a news producer, was used to support arguments that Heard's team orchestrated coordinated media tip-offs surrounding her legal proceedings.
TMZ Footage of Heard Leaving Courthouse, May 27, 2016
Unclear
TMZ video footage of Amber Heard leaving the Los Angeles courthouse on May 27, 2016, captured by paparazzi dispatched after a tip.
Captured following a tip that Heard would pose to display her alleged bruise, supporting Depp's team's argument that the courthouse appearance was staged for media coverage.
The broader topic of Morgan Tremaine's testimony regarding TMZ tip-offs and publicist presence at the courthouse, raised as a rebuttal-case subject on cross-examination.
Permitted on cross-examination as a rebuttal-case topic bearing on Heard's claimed damages arising from Adam Waldman's public statements.
Extended audio recording played in multiple proceedings across several segments, covering discussions of the Australia fight, bathroom retreat disputes, and Heard's acknowledgments that she started physical fights. Additional segments included Depp's 'crime scene waiting to happen' statement and his acknowledgment of recent physical fights, as well as the 'five bathrooms and two bedrooms' exchange used to argue Heard was pursuing, not fleeing.
Central audio evidence used repeatedly by both sides throughout the trial. Depp's team played Heard's admissions to impeach expert testimony characterizing her violence as purely reactive; Heard's team played additional segments showing Depp's own acknowledgments of escalation dynamics. During the Hughes cross-examination, Heard's own words became the central impeachment of the direct testimony framework.
Audio recording (portion 18:43–21:46) in which Heard tells Depp to 'tell the world' he is also a domestic violence victim and Depp responds 'Yes'; also includes Depp referencing losing a finger and mineral spirits thrown at his nose. Played in multiple proceedings and referenced at closing.
Played by both sides for different purposes: Vasquez argued it showed Heard doubted Depp would claim victimhood publicly, suggesting she believed the allegation incredible; Heard reframed it as sarcasm directed at her abuser. At closing, used to argue Heard never credited Depp's victimhood as genuine.
Audio recording from the Boston-LA flight in which Depp is heard moaning and making indiscernible sounds, and Jerry Judge audibly calls Depp a 'fucking idiot.'
Used to corroborate Heard's account of Depp's inebriation on the May 24, 2014 flight, and to contradict Depp's claim that he had little to drink on that occasion.
'Punch vs. Hit' Admission Recording (Pl. 356A/356B)
Admitted
Pl. 356A, 356B
Audio recording from September 27, 2015 in which Heard admits to hitting Depp, using language distinguishing a 'punch' from a 'hit' and saying 'I can't promise' about future physical behavior; also includes statements attributed to Heard such as 'I meant to hit you' and 'you're not punched, you got hit.'
Heard's direct on-tape admissions to hitting Depp became core evidence of her physical aggression; Heard's team framed the admissions as context-dependent and grounded in a physical disparity argument.
Audio recording of a Depp-Heard argument in which Heard made derogatory remarks about Depp's son Jack and his parenting, and Depp used profane and demeaning language toward Heard including 'suck my dick' and 'washed-up piece of shit.'
Depp's team used Heard's remarks to show she verbally weaponized his children during arguments. Heard's team played the recording for character and temperament impeachment of Depp.
Post-Birthday / San Francisco Hotel Recording (PX 1229)
Admitted
Plaintiff's Exhibit 1229PX-1229
Audio recording from a July 2016 San Francisco hotel meeting between Depp and Heard in which Depp refuses Heard's request for a hug and tells her she will not see his eyes again; also includes Depp's recorded allegation that Heard physically attacked him ('you fuckin' haymakered me, man').
Vasquez used the recording to open cross-examination, establishing Depp's posture toward Heard. Depp's on-tape haymaker allegation against Heard went undenied on the recording.
Excerpted audio recording (seconds 1–20 and 1:30:02–1:31:45) in which Depp describes the couple's arguments as a 'bloodbath' and references violent escalation on 'the island.'
Depp's own words describing predictable violent escalation in the relationship were used to support Heard's account of a pattern of abuse.
'I Made a Huge Mistake' Argument Recording (Def. Ex. 581)
Admitted
Defendant's Exhibit 581
Audio recording of a Depp-Heard argument in which Heard references Depp beating her and Depp says 'I made a huge mistake.'
Placed Depp in a recorded confrontation in which Heard referenced physical violence; Depp's statement 'I made a huge mistake' was subject to competing interpretations at trial.
Second audio recording from the Australia cleanup period, featuring Jerry Judge, offered during Ben King's testimony.
Excluded on hearsay and foundation grounds, on the same basis as the first Australia cleanup recording; the court ruled consistently that Judge's death foreclosed admission.
Pre-trial or opening reference to audio recordings from the Australia incident, specifically the five-hour tape and associated recordings; Australia tape described as including handlers discussing cleanup after the incident.
Previewed by the defense to establish Depp's behavior during the Australia incident; the reference anticipated recordings that would be introduced to characterize how Depp's team managed the aftermath.
Car/'Let Me Go' Recording Outside Studio (Def. Ex. 598C)
Admitted
DX-598C
Defendant's Exhibit 598C, a recording made in a car outside a studio in which Heard says 'let me go' and requests space.
Vasquez contended the recording showed Depp was attempting to enter the studio to see Lily-Rose rather than to use drugs, countering an implication about his motives.
Audio recording, without a specified exhibit number, in which Depp uses the phrase 'borderline personality disorder' in reference to Heard; played during Shannon Curry's testimony.
Used to suggest that Curry's BPD finding echoed Depp's prior accusations during arguments; Curry declined to characterize the use of the phrase as taunting.
Audio recording with two played portions (31:14–33:04 and 56:xx–59:54) in which Depp explains his strategy of leaving arguments to de-escalate, and Heard calls him a 'bully' and says his leaving causes her immense stress.
Depp used the recording to support his narrative of retreating to avoid violence; Heard's team highlighted her description of his departure behavior as a control tactic.
February 10, 2016 Aggressive Confrontation Recording (Ex. 17)
Admitted
Exhibit 17
Audio/video recording capturing Depp speaking aggressively and Heard questioning whether he had been drinking; confirmed by iO Tillett Wright as the recording Heard sent him on February 10, 2016.
Played in court to corroborate Wright's testimony about the pattern of Depp's intoxicated confrontations with Heard.
Set of audio recordings from June 2016 (Plaintiff's Exhibits 357B through 357F), in which Heard articulates arguments about a smear campaign and cross-corroboration of her account.
Heard's team used Depp's own June 2016 recordings to support her narrative and cross-corroboration arguments regarding the alleged smear campaign against her.
Set of redacted audio clip exhibits (approximately Exhibits 700–717) with associated photo metadata, offered through Heard's testimony.
Bredehoft attempted to admit these through Heard's testimony; the court sustained objection on foundation and hearsay grounds, preventing their admission.
Ring-Throw and 'Borderline Personality Disorder' Recording (PX 342A)
Admitted
PX 342A
Audio recording (portion 19:40–25:25) of a heated Depp-Heard argument in which Depp throws his ring, Heard pleads for him to stay, and Depp says 'borderline personality disorder' in reference to Heard.
Captured the emotional intensity of the parties' conflicts and Depp's use of psychological labeling during arguments; admitted at trial.
Dembrowski–Heard Feb 3 2014 Text ('JD Is on a Bender')
Admitted
Defendant's Exhibit 210Exhibit 210214
A February 3, 2014 text exchange between Christi Dembrowski and Amber Heard in which Heard wrote 'JD is on a bender' and Dembrowski responded with messages including 'I worry about everything,' 'where are the kids,' and 'I don't love any of it.' The exhibit was produced in both unredacted and redacted forms across proceedings.
Introduced to challenge Dembrowski's on-stand minimization of her awareness of Depp's substance use. Partially admitted, with only Heard's 'JD is on a bender' phrase allowed for impeachment purposes; Dembrowski's responses were admitted with her phone number redacted. The redacted version was revisited to close cross-examination and frame the overall pattern of substance-abuse awareness predating Dembrowski's testimony.
Text message(s) from Depp to his physician Dr. David Kipper, sent around March 7–8, 2015, in which Depp states 'I cut the top of my middle finger off' and comments on Heard's ambition, contemporaneous with the Australia finger injury.
Key impeachment exhibit: Depp's own contemporaneous words described the finger injury as self-inflicted, directly undermining his trial testimony attributing the injury to Heard throwing a bottle.
Depp–Bettany Texts re Boston Flight (Def. Ex. 245)
Excluded
Defendant's 245DX 245
Text messages from Johnny Depp to actor Paul Bettany concerning drug and alcohol use in connection with the Boston plane flight incident, including language characterized as admitting to a blackout and aggression. The exhibit was offered by Heard's team through audio technician Keenan Wyatt on Day 5 and later addressed when Depp testified directly.
The court excluded the exhibit as hearsay when offered through Wyatt, blocking Heard's team from using Depp's own words to contextualize the Boston flight through that witness. Later in the trial the texts were characterized as contemporaneous admissions corroborating Heard's account of the Boston plane incident. Depp explained the language as hyperbolic expression of emotional overwhelm rather than literal intent.
Text message from August 15, 2016 in which Johnny Depp wrote to talent agent Christian Carino, 'She will hit the wall hard!!!!' and expressed a wish that 'Karma kicks in and takes the gift of breath from her,' along with other degrading and threatening language about Heard. The exhibit was admitted in redacted form.
Described as among the most damaging exhibits of the trial, the message showed Depp expressing a death wish directed at Heard months after their separation. Depp confirmed authorship but reframed the language as shock at what he characterized as false allegations rather than evidence of genuine hostility.
Text messages sent by Depp to Heard on May 22, 2016, expressing 'profound apologies' and stating 'I am clear, I am me,' introduced as Defendant's Exhibits 771, 772, and 773.
Heard's team argued the apologies sent the day after the May 21 incident proved Depp knew what he had done and were consistent with a pattern of apology following alleged abuse. Bredehoft framed them as establishing Depp's awareness of his conduct.
Depp to Dembrowski 'Replace Her on WB Film' Text, June 4, 2016 (DX821)
Admitted
DX821Defendant's Exhibit 821
A text message from June 4, 2016 in which Johnny Depp wrote to his sister Christi Dembrowski, 'I want her replaced on that WB film,' referring to Amber Heard and her Warner Brothers role, with additional references to Warner Brothers franchise concerns.
The message contradicted Depp's denial that he attempted to have Heard removed from the Aquaman film. Depp attempted to explain it as concern for Warner Brothers rather than hostility toward Heard; sustained objections limited his explanation.
Plaintiff's Exhibit 40 (admitted as 120B)PX120APX120B
Text message(s) from Depp to Heard's mother Paige, sent August 19, 2014, in which Depp calls himself 'this poor old junkie,' praises Heard's 'heroism,' and credits her caregiving during his Roxicodone detox.
Showed Depp privately crediting Heard as a devoted caregiver at the height of his addiction, used as contemporaneous evidence against his trial characterization of their relationship and his denials about his substance struggles.
A text exchange between Johnny Depp and Bruce Witkin dated February 4, 2014, in which Depp referenced his relationship with Heard.
Used to show Depp employed identical 'hit the wall hard' language with different claimed meanings across two separate years; also anchors Witkin's awareness of the February 2014 period of contact.
A social media post authored by Gina Deuters, described as a 'long letter' commenting on court proceedings and Depp's wins; a screenshot was passed to Heard's counsel by Eve Barlow from the front row during trial. The post was later identified as approximately two years old rather than from the current trial week.
Raised at sidebar as evidence that Deuters had been following the trial in potential violation of witness exclusion protocols, prompting the judge to excuse the jury and question the witness directly. Depp's team alleged the undated screenshot was presented in a way intended to mislead the court about Deuters' trial exposure.
An email chain dated December 20, 2018, with the subject 'Johnny Depp's Jack Sparrow Won't Return,' in which Depp's publicist Robin Braun forwarded a movieweb.com article about Depp's removal from the Pirates franchise; agent Jack Whigham replied that Disney had not officially notified them, and the chain also included a message from Christian Carino.
Placed Disney's Pirates 6 decision two days after Heard's op-ed was published, offered to corroborate the narrative that Heard's allegations caused Depp's removal from the franchise. Excluded as hearsay when offered to refresh Whigham's recollection at trial.
A redacted page from a text exchange between agent Tracey Jacobs and business manager Edward White, in which Jacobs reported Disney's complaint that Depp had arrived five hours late for Pirates 5 ADR in London.
Admitted for impeachment purposes; directly contradicted White's denial of knowledge about Depp's on-set lateness. Also submitted as a court exhibit by Rottenborn during preliminary matters on a separate day.
Jennifer Howell Email to Whitney Henriquez (July 2020)
Admitted
4Depp Exhibit 9
An email from Jennifer Howell to Whitney Henriquez dated July 28, 2020, forwarded to Marcel Pariseau, in which Howell expressed belief that Whitney was being dishonest about the abuse allegations and urged her to tell the truth.
Contemporaneous document showing Howell's belief that Whitney was not being truthful about the allegations. During redirect, Howell denied that Adam Waldman had influenced the email's drafting.
A text chain involving Stephen Deuters introduced as Defendant's Exhibit 229A-M, including a message reading 'When I told him he kicked you, he cried.' The court excluded the texts on the grounds that Deuters was not acting as Depp's speaking agent when he sent them.
Excluded in full after the court rejected the party-opponent speaking-agent theory; the objection was preserved on the record for appeal. The excluded texts could have corroborated Heard's account of a Boston flight incident.
Two text messages referencing 'Molly' sent from Depp's phone, introduced as Defendant's Exhibit DX883. Depp disavowed authorship during cross-examination.
The only cross-examination exhibit for which Depp denied authorship entirely rather than offering contextual explanation, making the texts a focal point for credibility assessment.
A text exchange between Sean Bett and Depp dated June 12, 2019, referencing 'not-drugs' in connection with visitors at Depp's house.
Excluded after sidebar; the judge found the 'not-drugs' reference too ambiguous to constitute proper impeachment of Bett's denial that he facilitated Depp's drug use.
A September 1, 2017 text exchange between Depp and his security guard Sean Bett in which Depp describes drinking wine and pounding an entire bottle of tequila, and Bett mentions preventing others from calling police.
Admitted for impeachment use only; full admission was denied as too remote given the 2017 date, after the relationship ended. Contradicts Bett's trial characterization of Depp's drinking as minimal.
A text exchange or package of exchanges between Christian Carino and Amber Heard, covering post-divorce communications including Heard's reconciliation requests and TRO-related discussions.
Anchored questioning about Heard's promise regarding the TRO and her request for a San Francisco meeting with Depp.
Text messages between Christian Carino and Amber Heard scheduling post-TRO meetings with Depp.
Admitted without redactions as non-hearsay statements by a party; supports Depp's team's narrative that Heard sought contact with Depp despite the restraining order being in effect.
A text exchange between Christian Carino and Amber Heard dated August 7–16, 2017, in which Carino wrote that Heard 'wasn't in love with' Elon Musk and had told him 'a thousand times you were just filling space.'
Supports the narrative that Heard's relationship with Musk was not serious and that she remained emotionally attached to Depp following the divorce.
Text messages sent by Depp's sister Christi Dembrowski to Depp on February 5, 2014, instructing him to 'Stop drinking,' 'Stop coke,' and 'Stop pills.'
Primary impeachment document establishing Dembrowski's direct, personal knowledge of and concern about Depp's substance use, contradicting her trial denials about the extent of her awareness.
An email from Christi Dembrowski to agent Tracey Jacobs dated February 27, 2015, referencing Depp arriving two and a half hours and seven hours late to set during Pirates 5 filming.
Established that Dembrowski had contemporaneous knowledge of Depp's on-set conduct during the Australia period, used to challenge her claim of limited awareness.
A March 22, 2013 text exchange between Christi Dembrowski and Amber Heard in which Dembrowski wrote 'I don't love what it is' and advised Heard against having confrontational conversations with Depp.
Showed Dembrowski was aware of concerns about Depp's behavior as early as 2013 and was counseling Heard to moderate her approach; published to the jury over objection.
A multi-page text chain between Christi Dembrowski and Amber Heard dated May 25, 2014, containing messages from Dembrowski including 'he needs help' and 'I don't have all the information to help alone.'
The court permitted Rottenborn to question Dembrowski about her own statements in the texts as potential prior inconsistent statements but declined to admit the exhibit itself.
Depp 'I'm Never Getting Clean and Sober' Audio Recording
Admitted
Defendant's Exhibit 587B
An excerpted audio recording (Defendant's Exhibit 587B, segments at 19:40–19:53 and 23:04–23:29) in which Depp states 'I'm never getting clean and sober' while Heard contemporaneously documents his cocaine and alcohol use that day.
Depp's own voice, on recording, declaring he would never achieve sobriety directly countered his trial framing of substance use as a past struggle he was managing.
A text exchange including a message from Depp reading 'I'm good. Just got a fucked finger,' with a follow-up from Stephen Deuters, contemporaneously documenting the Australia finger injury.
Introduced to show Witkin's awareness of and reaction to the Australia finger injury, providing contemporaneous documentation of the incident.
Depp January 2013 Insult Texts About Heard (D-153)
Admitted
D-153
Text messages from January 2013 in which Johnny Depp referred to Amber Heard as 'idiot cow,' 'ugly cunt,' and 'worthless hooker.'
These messages contradicted Depp's characterization of himself as a Southern gentleman and provided direct evidence of his denigrating language about Heard.
Depp Multi-Incident Apology Texts and Emails (DX-272/310/321/325)
Admitted
DX-272DX-310DX-321DX-325
A set of Depp text messages and emails introduced as Defendant's Exhibits 272, 310, 321, and 325, including phrases such as 'I'm a fucking savage' and 'I love you more than life.'
Depp's own-words apologies and admissions were used to corroborate an alleged pattern of apology-cycle behavior following incidents of alleged abuse.
Depp to Connolly 'Mangling' Text, c. February 10, 2016 (Ex. 620)
Admitted
Exhibit 620
A text message from around February 10, 2016 from Johnny Depp to security guard Malcolm Connolly containing graphic language about physically 'mangling' an abuser.
Introduced to show Depp's violent ideation toward Heard contemporaneously with the Sweetzer kitchen video incident in February 2016.
Depp to David Heard — December 2015 Incident Apology Text
Unclear
DX580
Text from Depp to Heard's father David Heard, sent approximately two weeks after a December 2015 incident, stating 'I fucked up and went too far in our fight,' introduced as Defendant's Exhibit DX580.
Used as contemporaneous evidence to corroborate Heard's account of a December 2015 incident, providing Depp's own words as an admission of excessive conduct.
A redacted text message from September 9, 2013 from Johnny Depp to Amber Heard containing the phrase 'don't test me, please' and characterized as containing 'aggravated ultimatum' language.
Heard characterized the message as a threat following a London Fields concert dispute; presented as evidence of threatening communication between the parties.
Depp to Kate James 'Flabby Ass' Text, August 13, 2016 (Def. Ex. 844)
Admitted
Defendant's Exhibit 844
A text message from August 13, 2016 in which Johnny Depp wrote to Kate James, 'Come over for a spot of purple and we'll fix her flabby ass nice and good,' referring disparagingly to Amber Heard.
Admitted over a character-evidence objection, the message was used to show Depp's disparaging language about Heard and to impeach James's claimed ignorance of the text's meaning.
Depp to Kevin Murphy — January 2014 Drinking Admission Text
Admitted
Exhibit 207
Text from Depp to his estate manager Kevin Murphy, dated January 21, 2014, in which Depp acknowledges his daughter Lily-Rose suspected he was drinking, writing 'she's right. But I can't admit it or I fucking die in her eyes.'
Directly contradicted Depp's trial testimony that no one other than himself was troubled by his drinking.
Email from Depp to Dr. David Kipper, dated March 19, 2015, in which Depp states 'I've chopped off my left middle finger,' introduced in redacted form as Defendant's Exhibit 398.
Depp's own written account of the Australia finger injury, presented to show that Depp's version of events — not only Heard's account — existed in the record.
Text from Depp to Nathan Holmes, sent after the Australia finger injury, requesting 'whitey stuff' and 'the E business,' introduced as Plaintiff's Exhibit PX393.
Impeaches Depp's denial that he requested drugs in the aftermath of the Australia finger injury.
On Day 5, Johnny Depp proactively addressed text messages he had sent containing dark or violent language, before being cross-examined about them.
By preemptively contextualizing the messages as hyperbolic, Hunter S. Thompson-influenced expression of emotional overwhelm rather than literal intent, Depp aimed to blunt anticipated impeachment by Heard's attorneys.
Depp–Baruch Texts Including 'Rotting Corpse' (Oct 2016)
Unclear
Plaintiff's Exhibit 548
Text messages between Johnny Depp and Isaac Baruch from October 2016, containing Depp's derogatory messages about Heard including the 'rotting corpse' text.
Court reserved ruling on admission pending a hearsay objection raised during testimony.
Text messages from June 11, 2013 in which Johnny Depp wrote to actor Paul Bettany, 'Let's burn Amber,' 'Let's drown her before we burn her,' and made an additional corpse threat directed at Heard.
Offered as character evidence of violent ideation toward Heard, these texts were among the most striking exhibits introduced by Heard's team to challenge Depp's self-presentation.
Depp–Bettany Boston–LA Flight Drug and Alcohol Text
Admitted
D-245
Text exchange from May 30, 2014 between Depp and Bettany describing drinking and drug use on a Boston-to-Los Angeles flight that ended in a blackout, introduced as Defendant's Exhibit D-245.
Directly contradicted the sobriety timeline Depp presented at trial.
Depp–Deuters 'I NEED, I WANT, I TAKE' Texts, Feb. 22, 2017 (DX883)
Admitted
DX883
Text messages from February 22, 2017 from Johnny Depp to Stephen Deuters, including the phrase 'I NEED, I WANT, I TAKE.'
Admitted over objection as impeachment evidence; Depp denied authorship of these messages, making them significant in assessing his credibility on the stand.
An email from Johnny Depp to agent Tracey Jacobs dated August 29, 2015, concerning the London Fields film and a nudity-related dispute involving producers Jacobs identified as Hanley (misspelled by Depp as 'Harley').
Introduced to illustrate Depp's communication style with Jacobs and to contextualize production difficulties on London Fields.
Heard to Carino Text, Letter for Depp (Aug 16 2017)
Unclear
A text dated August 16, 2017, in which Heard asked Carino to deliver a handwritten letter to Depp, stating she was 'finally single' and wanted Depp to know she loved him and was sorry.
Direct evidence of Heard's desire to reconcile with Depp more than a year after the divorce filing, relevant to the contested characterization of their post-divorce relationship.
An email exchange with Bates reference CC00070, dated January 11, 2018, subject 'WME,' in which Heard discussed with Carino her decision to leave CAA for William Morris Endeavor.
Establishes Heard's departure from CAA and confirms that Depp did not interfere with her professional representation during their relationship.
Text messages between Amber Heard and Dr. Cowan dated March 8, 2015.
Admitted in redacted form over a Rule 2:106 completeness objection; the phrase 'I don't know if I'll ever be able to change' was used as an admission against Heard.
A text exchange between Amber Heard and Kate James (Heard's former personal assistant) containing affectionate messages including 'I love you' and 'Love you too, hon.'
Used to probe whether James's affectionate communications with Heard were sincere or merely professional placation.
Heard–Kate James Email (c. Feb 12 2015, Depp Ex. 4)
Unclear
Depp Exhibit 4
An email purportedly from Amber Heard to Kate James dated on or about February 12, 2015.
James stated she did not remember the email and believed she was no longer employed by Heard at that date, undermining the document's authentication through this witness.
Heard–Kate James Email Chain (Early Feb 2015, Depp Ex. 5)
Unclear
Depp Exhibit 5
An email chain between Amber Heard and Kate James from early February 2015, including a message in which Heard wrote in all caps.
Used to illustrate Heard's communication style and confirm the employment timeline; James described Heard as appearing 'very confused' throughout the chain.
An email exchange between Amber Heard and Kate James regarding James's termination of employment, referencing six weeks' severance, financial difficulties, and James's request for alternative accommodation.
Used to establish James's financial distress at termination and to impeach her denial that she had missed mortgage payments, supporting the argument that James was biased against Heard.
A text message from Amber Heard to Raquel Pennington containing the message 'I'm not good,' partially admitted; the broader message that also referenced Depp's drinking was excluded.
Only the 'I'm not good' portion was admitted as a state-of-mind statement; the remainder of the message, 'JD is drinking again,' was excluded.
Heard–Pennington 'This Is What I've Been Dealing With' Text
Admitted
Defendant's Exhibit 252A
A redacted text message exchange between Amber Heard and Raquel Pennington dated August 7, 2014, including Heard's message 'This is what I've been dealing with' attached to the ice cream photograph.
Admitted over a completeness objection; used by Depp's counsel to suggest Heard shared embarrassing photographs of Depp with friends rather than keeping them solely as private documentation.
Heard–Pennington Email with Cocaine Photo (Mar 22 2013)
Admitted
Defendant's 167
An email from Amber Heard to Raquel Pennington dated March 22, 2013, enclosing the cocaine breakfast table photograph, admitted with redactions of the message text.
Establishes that Heard contemporaneously shared the cocaine photograph with her close friend, providing context for how and when the image was distributed.
A text message from Amber Heard to Raquel Pennington timestamped 8:06 p.m. on May 21, 2016.
Drew's confirmation that Pennington received the text while still in Penthouse 5 rather than Penthouse 3 establishes a timeline anchor for the sequence of events on the night of May 21, 2016.
James Wan to Heard Text, Aquaman Test Screening (Aug 2018)
Unclear
ALH18247 (Exhibit 5)
A text message from Aquaman director James Wan to Amber Heard dated August 25, 2018, stating she 'rated really high with the audience' at a test screening.
Introduced to show that audience data supported Heard's performance at the time Warner Bros.' alleged chemistry concerns were supposedly forming.
Whitney to Depp Texts re 'Point of No Return' (Oct 2 2015)
Excluded
Plaintiff's Exhibit 1283
Text messages sent by Whitney Henriquez to Johnny Depp dated October 2, 2015, in which she wrote that she would stay out of their relationship if she thought it was past the point of no return.
Used to impeach Whitney's trial testimony that she did not understand the 'point of no return' framing; established at sidebar that the texts could be read to the witness but not admitted into evidence for impeachment of a third-party witness.
A text message exchange between Whitney Henriquez and Kevin Murphy (Depp's estate manager) dated March 23, 2015, containing Whitney's photographs of the destroyed closet and kitchen.
Contemporaneous photographic record of destruction to Heard's closet taken the morning after the staircase incident, corroborating Whitney's testimony about the scale of damage.
A text exchange between Bruce Witkin and Amber Heard dated February 3, 2014, in which Heard reached out to Witkin with concern about Depp during a bender with Marilyn Manson; a continuation shows Witkin attempting to locate Depp at Manson's at Heard's urging.
Shows Heard's contemporaneous concern about Depp during the February 2014 bender and documents the coordinated effort by Witkin to locate Depp.
Amber Heard's opinion piece titled 'I spoke up against sexual violence and faced our culture's wrath. This has to change.' published in the Washington Post on December 18, 2018, describing herself as a public figure representing domestic abuse. The article did not name Depp by name; three specific statements within it were identified by Depp as defamatory. It was displayed in full on courtroom screens and introduced in both print and online forms.
The foundational document of Depp's three defamation claims, admitted into evidence and displayed to the jury throughout trial. Depp's team argued its statements were 'of and concerning' him and drove career harm; the defense read the full 349 words to argue it addressed policy rather than any named individual. Depp's experts analyzed its reputational and market impact; defense experts challenged the causal chain.
Bonnie Jacobs Therapy Notes (Heard, from October 2011)
Excluded
Defendant's 1059Y
Treatment notes of psychologist Dr. Bonnie Jacobs documenting Heard's sessions over approximately five years beginning October 2011, including Heard's reports of physical and sexual violence by Depp across multiple sessions and notes predating the Depp relationship. Characterized by Hughes and Spiegel as documenting physical and sexual abuse from 2012.
Contemporaneous records predating the restraining order establish a timeline of alleged abuse; used by Hughes and Spiegel to support trauma and IPV expert findings. Curry examined pre-relationship entries to challenge the claim that reported symptoms were caused by Depp. Jacobs never diagnosed Heard with BPD or HPD across five years of treatment, contrasting with Curry's forensic conclusions. Hearsay objections were sustained, excluding the notes from evidence.
The Computer-Aided Dispatch (CAD) summary and incident recall for the May 21, 2016 call to 849 S. Broadway, coded 242D (battery/DV), recording the call timeline (initiation 8:35 p.m., arrival 8:57 p.m., close 9:22 p.m.) and the notation that the victim advised a verbal dispute and refused to provide further information. Introduced through the Saenz, Hadden, and Sadanaga depositions as the only documentation Saenz and Hadden created from their visit.
The primary documentary record of the police response to the May 21 incident; used to establish the timeline and to demonstrate that no supplemental report, officer notes, or other records existed beyond the dispatch entries. The 'verbal dispute' notation and the 'victim' label were each examined to argue that the response and its documentation were inadequate.
The CAPS-5 structured clinical interview was administered by Hughes to Heard on December 27, 2021, producing an approximately 59-page handwritten scoring form. The plaintiff introduced the form as Plaintiff's 1247; the defense sought to admit the same materials as Defendant's 1435, which was excluded on hearsay grounds.
Central methodological battleground between the two forensic psychologists. Dennison used the form page by page to identify blank frequency fields, a sparse three-word anchoring event description, and margin-note childhood trauma testing, challenging whether Hughes's administration met standardization requirements. Hughes responded in rebuttal that Heard's scores were mild to moderate and that blank fields reflected a deliberate clinical choice documented in supplemental notes. Curry testified that the non-standard administration invalidated Hughes's PTSD diagnosis resting on it.
Amber Heard's test option agreement with Warner Brothers for the role of Mera in the Aquaman franchise, establishing a tiered salary structure across multiple pictures, identified by Hamada as a standard actor-studio agreement.
Arnold used the contract figures as the baseline for her damages projection, arguing Heard lost renegotiation leverage due to the Waldman statements; Marks argued renegotiation is not customary given the large multiples already baked into the option terms; Nadelhaft used the contract to pin down figures consistent with Arnold's projection.
The TSI-2, a clinical instrument assessing trauma-related symptoms including an Atypical Response Scale measuring exaggeration, was administered by Hughes to Heard. The plaintiff introduced a critical items list as Plaintiff's 1248; the defense's motion to admit the full test as Defendant's 1859 was denied on hearsay grounds.
Curry testified the Atypical Response Scale showed Heard at the 98th percentile for intentional exaggeration of PTSD symptoms, beyond levels expected in severe genuine cases. Dennison highlighted a zero score on violent behavior despite Heard's admitted hitting conduct. Hughes disputed Curry's methodology, stating the TSI-2 manual prohibits using percentile ranks and that Heard's raw score of 10 was below the 15-point clinical cutoff.
Text messages from March and October 2015 in which Depp wrote to Dr. Kipper and others that he had cut or chopped off his own finger. Depp later characterized the 'I cut my finger off' language as dark humor, referring to the injured finger as 'Little Richard.'
Used by defense to contradict Depp's narrative that Heard caused the Australia finger injury, by showing his own contemporaneous language attributing the injury to himself. Depp's rebuttal framed the phrasing as gallows humor rather than a factual admission.
Erin Falati (née Boerum), Heard's personal nurse, maintained clinical notes documenting Heard's physical condition, emotional state, and medication regimen from August 2014 through May 2016. The notes recorded observations across key incident dates—including a restaurant incident reflecting emotional reactivity and Heard's report that only Provigil was effective—and were admitted under multiple exhibit labels during different witness examinations. Heard testified and denied multiple entries during her own examination.
Served as the primary contemporaneous documentary record of Heard's condition across the relationship; corroborated forensic psychological findings about emotional reactivity and medication responses. Because the notes did not document physical injuries across several alleged abuse incidents, they were used by Depp's team to undercut injury claims, and by Heard's team as a baseline record of her care.
Amber Heard's December 19, 2018 tweet sharing a link to the Washington Post op-ed with the statement 'Today I published this op-ed in The Washington Post,' simultaneously announcing her ACLU ambassadorship. The tweet repeated the op-ed title, including the phrase 'sexual violence.'
Admitted as Plaintiff's Exhibit 3; Depp's team argued it constituted republication of the op-ed and Heard's adoption of its headline as her own statement, extending defamation liability. The timing — two days before Aquaman's December 21, 2018 release — was cited as significant. The defense argued a hyperlink does not constitute republication under the jury instructions.
LAPD Domestic Violence Supplemental Report Form (Form 15.40.02)
Unclear
Exhibit 9Exhibit Number 9Deposition Exhibit 9
The LAPD Domestic Violence Supplemental Report form containing victim observation checklists, victim emotional state assessments, crime scene indicators, and approximately 70 yes-or-no risk assessment questions. Introduced as Exhibit 9 across the Saenz, Hadden, and Sadanaga depositions.
The operative form officers were required to complete at domestic violence calls; its non-completion by Saenz and Hadden on May 21, 2016 was central to the defense's argument that the officers failed to follow required DV documentation protocol.
The PAI, a broadband personality inventory with built-in validity scales, was administered by Hughes to Heard. The plaintiff introduced critical item endorsements as Plaintiff's 1244; the defense sought to admit the full scoring profile as Defendant's 1858, which was excluded on hearsay grounds.
Plaintiff used Heard's endorsement of 'sometimes true' on items flagged for potential aggression and potential malingering to challenge Hughes's malingering rebuttal and Heard's self-reported violence. Curry additionally testified that the PAI showed an elevated catchall discriminant function indicating intentional minimization and a borderline personality disorder configuration that Hughes had not disclosed. Hughes responded in rebuttal that the elevation did not reach the threshold for meaningful response distortion.
Rolling Stone Depp Exposé — Stephen Rodrick (June 21, 2018)
Unclear
Exhibit 3Carino Exhibit 2
A June 21, 2018 Rolling Stone article by Stephen Rodrick offering an in-depth account of Depp's behavior, spending, and personal issues. Disney executives including Alan Horn forwarded it internally. Waldman described contacting the magazine regarding Depp's situation, while the article states Waldman initiated that contact.
Used by Heard's team to show pre-op-ed industry awareness of Depp's troubles, supporting the argument that his reputation had declined before the Washington Post op-ed. Tracey Jacobs confirmed it damaged Depp's reputation; Carino could not assess its net career impact. Arnold cited the article as evidence that Disney was internally tracking Depp's problems months before the op-ed.
Ron Schnell's social media analysis and underlying Twitter API dataset tracking negative hashtag tweets against Heard from April 2020 through January 2021 and into 2022, tracking approximately 1.2 million negative tracers, challenged under voir dire as the underlying work product.
Arnold relied on Schnell's finding that Waldman-linked words appeared in approximately 25% of analyzed posts; Dennison challenged whether the dominant hashtags contained Waldman's language and whether the analysis tied the data to Waldman's specific statements.
A joint statement signed by both parties in connection with their 2016 divorce settlement, affirming that their relationship was at times volatile but always bound by love, and that neither party made false accusations for financial gain. Depp signed on August 15, 2016, and the statement was released publicly.
Central to the defamation claims at trial: Heard's assent that no false accusations were made was presented by Depp's team as contradicting her subsequent public accounts of abuse. Conversely, Heard's team used Depp's signature on the statement to undermine his characterization of her allegations as fabricated.
Dr. Alan Blaustein's handwritten session notes for Johnny Depp, beginning with an initial telephone consultation on October 2, 2014, and spanning through January 8, 2015. Notes include entries on Depp's anger toward Heard, self-destructive behavior, sobriety goals, substance history including MDMA and cocaine, mental status observations linking THC to cognitive impairment, absence of observed mania or hypomania, self-described paranoia, jealousy triggers, and the Mini-Mental Status Examination result showing Depp unable to recall any of three test words.
Primary evidentiary vehicle for Blaustein's examination; notes read aloud to surface Depp's own disclosures about anger, substance use, and the relationship with Heard. Cited by defense experts for evidence of cognitive impairment and the absence of bipolar indicators observed by the treating psychiatrist.
Connell Cowan Treatment Records (Defendant's Ex. 1057)
Excluded
Defendant's 1057
Clinical treatment notes and deposition of Dr. Connell Cowan, who treated Heard for approximately two years; reviewed by both Shannon Curry and Dawn Hughes as part of their expert record reviews.
Cowan stated in deposition he did not diagnose Heard with BPD or HPD and does not use diagnoses; Curry acknowledged this while arguing the underlying symptoms were present in his notes. Notes were excluded on hearsay grounds when Hughes sought to testify to their contents.
The stipulated final judgment for the dissolution of marriage between Amber Heard and Johnny Depp, approximately fifty pages in length, including a provision dismissing the restraining order allegations.
Confirmed the dissolution of the marriage and the terms under which the restraining order allegations were dismissed. Eric George reviewed the document when advising Heard on whether the op-ed would constitute a breach of the dissolution judgment. Excluded as cumulative in at least one instance because Wasser's testimony covered the same ground.
An August 18, 2014 email from Dr. Kipper to Christi Dembrowski (Depp's sister and manager) summarizing Depp's post-Bahamas condition, including pessimism about stopping drugs, lack of accountability, and anger issues. Kipper had known Depp approximately four months and spent roughly 20 hours with him before writing the email.
Excluded on double-hearsay grounds; would have provided a contemporaneous physician assessment of Depp's psychological state following the Bahamas detox. Allowed questioning about whether Kipper communicated its contents to Christi Dembrowski.
Dr. David Kipper's deposition transcript and associated email describing Depp's 'fundamental issues with anger' and romanticization of drug culture, as well as Kipper's clinical notes and urine drug screen records reviewed by defense experts. The deposition also contained Kipper's account that Depp told him at the scene that Heard threw a vodka bottle during the Australia incident.
Proffered excluded physician testimony and email were excluded as hearsay; would have documented Kipper's characterizations of Depp's anger and drug attitudes. Moore's cross-examination surfaced Kipper's vodka-bottle account from the deposition, which Moore stated he did not recall reviewing, raising questions about the completeness of his expert review.
LAPD Chief of Police Memo — DV Supplemental Report Form Revision (Nov. 24, 2014)
Unclear
Exhibit 8Hadden Exhibit Number 8Deposition Exhibit 8
A November 24, 2014 memo from the Office of the Chief of Police announcing the revision of the LAPD Domestic Violence Supplemental Report Form to provide a more concise picture of victim history and needs for DV investigations. Introduced as Exhibit 8 across the Saenz, Hadden, and Sadanaga depositions.
Established the formal LAPD policy basis for enhanced DV documentation requirements that were in effect well before the May 2016 incident, providing a benchmark against which the officers' conduct on May 21 was measured.
Debbie Lloyd's contemporaneous nursing notes for Johnny Depp's care spanning June 2014 through July 2015, covering the detox period, Australia, post-Australia recovery, and behavioral incidents including polysubstance abuse references and March 2015 entries on finger assessment, anger, and alcohol cravings.
Primary contemporaneous record of Depp's medical treatment, substance use, and behavioral incidents throughout the care period; used as the documentary spine of the cross-examination to refresh recollection on substantive topics from the detox period through post-Australia recovery.
The Sun 'Wife Beater' Article — Dan Wootton (April 2018)
Excluded
Defendant's Exhibit 99Carino Exhibit 10
An April 27, 2018 article by Dan Wootton in The Sun, headlined 'How can JK Rowling be genuinely happy casting wife beater Johnny Depp in the new Fantastic Beasts film?' Introduced at trial as Defendant's Exhibit 99 and also as Carino Deposition Exhibit 10.
Origin of the UK libel lawsuit; used to show Depp was publicly labeled a 'wife beater' eight months before the op-ed, supporting Heard's argument that pre-existing coverage had already damaged Depp's career. The court allowed the headline for impeachment purposes but sustained a hearsay objection to full admission and barred reading the body.
A cover letter from Edward White to the ACLU, dated August 24, 2016, enclosing Depp's $100,000 check and characterizing the payment as the first of multiple scheduled installments on Heard's $3.5 million pledged gift.
White's contemporaneous language describing the payment as an installment on a pledge — drafted in the ordinary course of business — directly supports the pledge framing and the argument that Heard's commitment was ongoing rather than a completed donation.
ACLU Acknowledgment Letter to Heard with Unsigned Pledge Form
Admitted
P-23Exhibit 11
Romero's September 9, 2016 ACLU acknowledgment letter to Amber Heard, enclosing an unsigned pledge form and payment schedule. The document was admitted subject to redaction of a phone number.
Establishes the $350,000 as the first installment of a $3.5 million pledge and confirms that Heard never signed the payment schedule, placing this document at the center of the donation-vs.-pledge dispute.
Anderson Couples Therapy Session Notes (Plaintiff's Ex. 2)
Admitted
Plaintiff's Exhibit 2
Seventeen-page redacted session notes (Bates 1–17) prepared contemporaneously by couples therapist Laurel Anderson during sessions with Depp and Heard, color-coded and authenticated as business records. Page 13 includes a notation attributed to Depp describing the relationship as 'chaotic, violent.'
Primary documentary record examined during Anderson's cross-examination; authenticated notes document Heard's in-session admissions regarding initiation of violence and her strategic thinking about police reports. Anderson contextualizes Depp's own retrospective language describing the relationship as chaotic and violent.
Kathryn Arnold's expert damages testimony and report, including her $45 million projection, comparable actors analysis, and renegotiation opinions, as well as actor salary and budget figures cited during examination.
The central subject of Marks's entire rebuttal testimony, who disputed Arnold's methodology, comparables, and bottom-line figures point by point; Nadelhaft used Marks's concessions on cross to rehabilitate Arnold's methodology.
Records from the hospital that treated Depp's finger injury in Australia, including documentation that Depp told the treating ER doctor he had sliced his finger with a knife, with no documentation of glass retrieved from the wound or elsewhere on the patient.
Undermined the exploding-bottle theory for the finger injury; Dr. Kipper, who was present, confirmed Depp's knife account. The absence of glass evidence in the records was cited by defense expert Moore.
Bania deposition transcript, including March 21, 2022 pages 74, 83, and 113, and page 177 lines 6–10 on Momoa Q score timing.
Used on multiple impeachment sequences: inability to separate the op-ed from 2016 impact, scope of public-image opinion, Q score significance, and prior agreement that Momoa's winter 2020 Q score gave more time to account for Aquaman's rise in popularity.
The CAPS-5, a structured clinical interview for PTSD developed by the National Center for PTSD and the VA, was administered by Curry to Heard.
Gold-standard PTSD diagnostic instrument used by Curry; she testified the administration showed signs of gross exaggeration of PTSD symptoms and formed the basis for her conclusion that Heard did not meet PTSD diagnostic criteria.
A Daily Mail Online article dated July 3, 2020, quoting Waldman's statement characterizing the May 2016 penthouse incident as an 'ambush' and a 'hoax,' and alleging Heard staged the incident and placed a second 911 call. Read during Kovacevic's testimony to confirm WME's awareness of the statements.
The second of three Waldman press statements underlying Heard's counterclaim. Its characterization of the penthouse incident as staged and fraudulent directly supported Heard's defamation theory; reading it through Heard's own talent agent confirmed industry-wide awareness.
Daily Mail 'Depp Out as Jack Sparrow' Article (Oct. 2018)
Unclear
Defendant's Exhibit 115Defendant's 115
A Daily Mail article dated October 25, 2018, headlined 'Hide the Rum: Johnny Depp is Out as Jack Sparrow in Disney's Pirates of the Caribbean,' reporting that Disney executive Sean Bailey announced Depp's departure from the franchise. Introduced as Defendant's Exhibit 115.
Introduced to show Disney had publicly cut ties with Depp two months before the Washington Post op-ed, directly challenging Depp's causation argument that the op-ed caused his loss of the Pirates role.
The Danger Assessment Scale, a validated instrument identifying risk factors for serious or lethal domestic violence, was administered by Hughes to Heard.
Curry testified the instrument was developed for emergency-room nursing staff assessing female IPV victims and was never intended as a retrospective forensic measure, lacking controls for exaggeration in litigation contexts. Hughes defended her retrospective application, noting the scale is used in Domestic Fatality Review Boards examining completed homicides, which she argued supports backward-looking use.
Text messages from April through June 2015 in which Depp used the word 'monster' to describe himself in communications to Jerry Judge, Elton John, Dr. Kipper, and Stephen Deuters, with Heard absent from the threads.
Used to contradict Depp's trial testimony that 'the monster' was a term invented by Heard, by demonstrating he applied the label to himself in contemporaneous messages to multiple people before any dispute about the term arose.
Text messages between Johnny Depp and Erin Falati dated October 31, 2015, produced from Depp's own records, in which Depp references the Australia finger injury with the phrase 'The first time I had just chopped my finger off.'
The messages provided a second self-documentation by Depp of the finger injury, corroborating the Kipper email, and also established a direct communication channel between Depp and Falati independent of Heard's care.
Text messages from Depp to Dr. Kipper in July–August 2015 showing Depp's hostility toward Heard's psychiatrist Dr. Cowan and requests for Xanax and Adderall as PRNs.
Cited by defense experts as evidence of erratic behavior and Depp's pattern of actively undermining Heard's therapeutic support while simultaneously seeking controlled substances from his own physician.
Text messages exchanged between Erin Falati (then Boerum) and Whitney Heard on March 23, 2015, following the loft incident during the Australia aftermath. The exchange was introduced under multiple exhibit labels across different witness examinations, with Falati identifying the messages on screen during her testimony.
Whitney Heard's statements in the exchange—including that Amber was expressing suicidal ideation that night—provided contemporaneous third-party corroboration of Heard's emotional state following the March 2015 incident and were relevant to the characterization of the Australia aftermath.
February 2021 Expert Witness Designation for Shannon Curry
Unclear
Plaintiff's Exhibit 884
A February 2021 expert witness designation signed by Depp's counsel listing three opinions attributed to Curry before she had evaluated Heard or formed any views, introduced as Plaintiff's Exhibit 884.
Central to the attack on Curry's independence: opinions were pre-attributed to her before her evaluation, including one she stated she never held. Bredehoft used the document to argue Curry's conclusions may have been pre-determined by the retaining team; Curry denied authorship and could not identify who wrote the designation.
ACLU and Fidelity Charitable records documenting a $350,000 donation received on December 11, 2018, designated as anonymous but recorded as a donation from Amber Heard, sourced from a donor-advised fund with no independent ACLU verification of the underlying source.
Documents the final payment credited to Heard's pledge before Depp filed suit, and highlights that the ACLU could not independently verify who funded the anonymous donor-advised contribution.
Hughes Expert Witness Training Presentation — National Clearinghouse
Admitted
Plaintiff's 1241
A PowerPoint presentation titled 'Expert Witness Testimony in Cases Involving Domestic Violence,' given by Hughes and Mary Ann Dutton to the National Clearinghouse for the Defense of Battered Women, introduced as Plaintiff's 1241.
Established Hughes's role as a trainer of advocates in expert witness testimony, supporting Dennison's professional-witness bias challenge. Hughes's redirect used the same presentation to provide professional context for her expertise in court-facing IPV work, rebutting the bias framing.
Hughes IPV Expert Witness Presentation — Kings County Bar Assoc.
Admitted
Plaintiff's 1242
A PowerPoint presentation titled 'The Use of Psychological Experts in Cases of Domestic Violence,' given by Hughes to the Kings County Bar Association, covering myths and misconceptions about IPV, introduced as Plaintiff's 1242.
Further supported Dennison's contention that Hughes functions as an expert advocate in domestic violence cases who shapes how attorneys use psychological testimony, while also providing additional professional context for her expertise in court-facing IPV work.
Kipper consultation notes from June 2014 documenting treatment encounters around the Bahamas detox arrangement, including Amber Heard's presence and her family history of drug and alcohol abuse, and no documented concern about Depp being violent.
Documented Heard's role administering medications during the Bahamas detox and established the isolated detox arrangement; also showed no contemporaneous documentation of Depp's violence toward Heard at that time.
A March 2015 email from Dr. Kipper, referenced in connection with Depp's sleep issues in Australia and directing Erin Falati to give Heard an excuse to keep her separated from Depp after the Australia incident; Bates No. Falati 0134.
Showed the treatment team's deliberate decision to separate Depp and Heard post-Australia and Dr. Kipper's acknowledgment that Heard would not accept the separation, offering context for the severity of the Australia argument.
A combined set of Kipper and nurse Lloyd patient progress notes for Depp spanning June 2014 through April 2015, including Bahamas detox notes, the bloody knuckles episode, Australia observations, and treatment noncompliance entries.
Primary source for documenting Depp's Bahamas detox incidents, the Australia period, and his pattern of treatment noncompliance; Kipper confirmed Lloyd's responsibility for maintaining contemporaneous notes.
The front and back of the LAPD business card left for Amber Heard on the night of May 21, 2016, bearing handwritten notes including 'refused report' and 'advised can call at later time if changes mind,' dated 9:16 p.m. Introduced through both Saenz (Exhibits 19–20) and Hadden (Hadden Exhibit 19).
Described as the sole contemporaneous documentation produced by the responding officers recording Heard's refusal of a report; used to establish what the officers communicated to Heard and what they observed at the time of their departure.
LAPD DV Field Notebook Divider — Case Preparation Guidelines (LAPD 18.30.02)
Unclear
Exhibit 10Deposition Exhibit Number 10
An LAPD field notebook divider (LAPD 18.30.02, dated January 31, 2010) setting out domestic violence laws and case preparation guidelines, including obligations to note complainant condition, preserve evidence, and photograph injuries. Introduced as Exhibit 10 in both the Saenz and Hadden depositions.
Established officers' affirmative obligations at DV scenes; defense used it to demonstrate that Saenz and Hadden did not photograph Heard, note her condition, or preserve other evidence as the guidelines required.
The MMPI-2, a 567-item objective personality and psychopathology inventory, was administered by Curry to Heard on an iPad. Curry produced a 25-page scoring outline summarizing the results in discovery.
Primary instrument underlying Curry's diagnoses of borderline personality disorder and histrionic personality disorder; results yielded a 3-6 code type with elevated defensiveness that Curry argued demonstrated sophisticated minimization of psychological dysfunction. In rebuttal testimony, Curry disputed Hughes's characterization of the profile as normal.
A news item dated November 5, 2020, headlined 'Disney reportedly scratch plans for Depp's POTC6 return,' introduced as Deposition Exhibit 60 during Tina Newman's testimony and separately referenced during Michael Spindler's cross-examination.
Offered to suggest Disney had decided against rehiring Depp before or independent of the Washington Post op-ed, challenging Depp's causation argument; Spindler confirmed he had not reviewed the article in preparing his damages analysis.
The PCL-5, a face-value self-report checklist of DSM-5 PTSD symptoms, was administered by Hughes to Heard as part of her evaluation protocol.
Curry testified the PCL-5 is inappropriate for forensic use and functions as a symptom guide that coaching-prone examinees can exploit, as it was designed as a screening tool rather than a diagnostic instrument. Hughes explained she used it as one data point within a multi-method protocol and conducted a clinical interview follow-up rather than relying on it in isolation.
Plaintiff's Trial Exhibit 1296 — a demonstrative Q score comparison chart using winter 2019 data, showing Amber Heard alongside Jason Momoa, Gal Gadot, Zendaya, Ana de Armas, and Chris Pine, comparing Q score timing across the group.
Showed Heard's positive Q score (9) was the lowest in the group and her negative score (28) the highest, contradicting Arnold's use of these actors as comparable benchmarks; also used to establish that Heard's scores were measured in winter 2019 while comparables were measured in different periods.
Plaintiff's Exhibit 936 — Depp's tax returns for Depp and his companies for 2009–2019, prepared by Ed White's firm, including page 69 showing 2015 earnings of $43 million.
Admitted subject to redaction and not to be published to the jury; the 2015 figure was used with Spindler's $22 million 2016 figure to calculate Heard's alleged community property entitlement of approximately $31.5 million.
A March 8, 2015 email from Raja Sawhney to Dr. Kipper containing notes on Depp's condition (under alias Robert Wells), including hand contamination observations and information about Depp's coherence at the Australia hospital.
Excluded on hearsay grounds; would have documented another physician's contemporaneous observations of Depp's hand after the finger injury and his level of coherence. An objection was sustained when defense attempted to use it to refresh a witness's recollection.
The pre-trial deposition of Shannon Curry taken March 21, 2022, including pages 199, 200, 207–208, 240, 254–255, 270, 305–306, and 337.
Primary impeachment tool throughout cross-examination; used to lock Curry into prior admissions on her IPV experience, her characterization of the pre-retention meeting, and her MMPI findings. Pages 207–208 were specifically used to confront Curry with prior statements about her experience testifying about bipolar disorder and her qualifications as an IPV expert, to which Curry conceded she had forgotten one case.
One of the three Waldman defamatory statements admitted and shown to the jury, entered as Defendant's Exhibit 1245. Introduced during both Kathryn Arnold's testimony and Johnny Depp's testimony; Depp testified he first encountered this statement in August 2020 when it appeared in Heard's counterclaim filing.
A formal basis for Heard's counterclaim; Arnold's entire Heard-damages analysis depends on the publication of this and the other two Waldman statements. Depp's testimony about when he first saw it was relevant to the timeline and causation questions before the jury.
One of the three Waldman defamatory statements admitted and shown to the jury, entered as Defendant's Exhibit 1246 / 1246A. Introduced during both Kathryn Arnold's testimony and Johnny Depp's testimony; Depp testified he first saw it with the counterclaim filing in August 2020.
A formal basis for Heard's counterclaim; Arnold's entire Heard-damages analysis depends on the publication of the three Waldman statements. Depp's first awareness in August 2020 was relevant to causation and timeline issues the jury had to resolve.
The third of three Waldman defamatory statements admitted and shown to the jury, entered as Defendant's Exhibit 1247. Introduced during both Kathryn Arnold's testimony and Johnny Depp's testimony; Depp testified he first saw it with the counterclaim filing in August 2020.
A formal basis for Heard's counterclaim; Arnold's entire Heard-damages analysis depends on the publication of the three Waldman statements. Depp's testimony completing the chronological picture—first awareness in August 2020—informed the jury's assessment of the counterclaim timeline.
Photographs described as 'PLANE pictures,' shown to Dr. Kulber during cross-examination.
Used as visual evidence of alleged damage to frame the closing cross-examination question about whether Depp's cast would have prevented him from causing it.
911 Call Summary Report — May 21, 2016 (Two Calls)
Admitted
A 911 call summary report documenting two separate calls placed approximately eight minutes apart on the night of May 21, 2016.
Used to refute Adam Waldman's claim that a second call was placed after staging; the calls were nearly simultaneous and independent, undermining the narrative that the second call was coordinated.
The Abusive Behaviors Observation Checklist, a brief therapeutic checklist with no published validation research, was administered by Hughes to Heard.
Curry testified it was designed for therapy rather than forensic evaluation and provides examinees a roadmap of what clinicians look for when assessing victimization claims, challenging its appropriateness as a forensic instrument.
ACLU Business Record — Heard Donation Status (P-27)
Admitted
P-27
An ACLU business record pulled from their internal system reflecting Heard's donation status, admitted as a business record with the relevant portion already redacted.
Admitted as a business record, this document provided authoritative documentary evidence of Heard's donation status within the ACLU's own records.
A bundle of ACLU donation records including a JPMorgan wire record, a Vanguard grant letter, Fidelity records, and Salesforce screenshots, providing a comprehensive accounting of payments received against the pledge.
Establishes total payments of $1.3 million received against the $3.5 million pledge, with a breakdown of direct versus soft-credited amounts, offering the most complete documentary accounting of the shortfall.
ACLU Email — Heard's Plan to Donate $3.5M Over Ten Years (Def. Ex. 1)
Admitted
Defendant's Exhibit 1 (Bates 2866)
An email describing Heard's plan to donate $3.5 million to the ACLU over the next ten years.
Forms the foundation for the donate-vs.-pledge semantic dispute at trial; its use of the phrase 'plan to donate' rather than 'pledge' was a distinction central to the parties' competing characterizations of Heard's commitment.
An email chain among ACLU personnel Romero, Villagra, and Wier regarding Depp's $100,000 check and Elon Musk's role in first introducing Heard as a prospective donor to Romero.
Shows the ACLU held Depp's check pending Heard's confirmation, and documents that Musk introduced Heard to the ACLU as a prospective donor — establishing the chain of events behind the initial $100K payment.
An email chain between ACLU personnel Romero and Maresco requesting Heard's next pledge payment, referencing a remaining balance of $2.55 million on a ten-year pledge.
The ACLU's own internal records use the word 'pledge,' supporting a more binding interpretation of Heard's financial commitment and corroborating that a substantial balance remained unpaid.
ACLU Internal Emails on Op-Ed Placement (Exhibit 42)
Admitted
Exhibit 42
ACLU internal email chain concerning placement of Heard's op-ed, including a pitch from ACLU staffer Stacy Sullivan to Washington Post editors describing Heard as having been 'beaten up' by Depp.
Admitted during Terence Dougherty's testimony; showed ACLU staff explicitly linked the op-ed to Heard's allegations against Depp in outreach to media, contradicting the op-ed's avoidance of naming him and supporting the 'of and concerning' element of Depp's claim.
ACLU Internal Emails re: Reuters Fact-Check, July 2020 (Ex. 61)
Admitted
Exhibit 61
Internal ACLU emails from July 2020 responding to a Reuters fact-check inquiry, including a statement by Weitz that Heard had donated her full settlement to charity.
Shows that the ACLU publicly affirmed an inaccurate claim about Heard's charitable giving well after she had stopped making payments, supporting the argument that the donation was never fully completed.
An email from ACLU's Romero to Amber Heard dated November 27, 2018, asking her to facilitate a $350,000 pledge payment.
Shows the ACLU actively soliciting payment from Heard; the $350,000 donation credited to her account in December 2018 followed directly from this solicitation.
American Academy of Psychiatry and the Law (AAPL) forensic psychiatry practice g
Unclear
American Academy of Psychiatry and the Law (AAPL) forensic psychiatry practice guidelines (2015)
Secondary professional standard Shaw cited to reinforce that even permissible without-examination opinions require acknowledged limitations and no claim of medical certainty.
American Medical Association Council on Ethical and Judicial Affairs 2017 Honolu
Unclear
American Medical Association Council on Ethical and Judicial Affairs 2017 Honolulu resolution
Corroborating authority from a non-psychiatric medical body that physicians should not render psychiatric diagnoses about public figures without direct evaluation.
Laurel Anderson's billing ledger tracking therapy sessions under the pseudonyms Ann Henry (Heard) and Joey Davis (Depp).
Establishes the treatment relationship, session dates, and duration of the couples therapy, including four couples sessions from October through December 2015.
Anderson Proffer Bundle — Deposition, Records & Summary (Exs. A–C)
Excluded
ABC
Proffer of Dr. Laurel Anderson's deposition transcript, therapy session records, and treatment summary, collectively submitted as Exhibits A, B, and C.
Proffered excluded evidence containing Heard's in-session reports of physical abuse by Depp; excluded as hearsay.
Treatment summary that Laurel Anderson prepared when first subpoenaed, synthesizing her clinical notes and conceptual impressions of the Depp–Heard relationship.
Contains Anderson's written characterizations that Heard 'admitted she eventually initiated the hitting herself' and that the physical violence 'appeared to me to be mutual' — key findings confirmed under cross-examination.
Anderson–Carino–Heard Email Chain (March & September 2015)
Admitted
Anderson Exhibit 3Defendant's Exhibit 397CCOOOL 72
Email chain among therapist Laurel Anderson, Christian Carino, and Amber Heard arranging the initial and subsequent couples therapy consultations in March and September 2015.
Documents how couples therapy was initiated through Carino and confirms session scheduling leading to the October 1, 2015 first meeting; establishes Carino's role in introducing both parties to Anderson.
APA Goldwater Rule text — the 2017 amendment stating it is unethical to offer a
Unclear
APA Goldwater Rule text — the 2017 amendment stating it is unethical to offer a professional opinion about an individual without conducting an examination — read aloud by Dennison.
Central to the ethics challenge: Dennison uses the rule's text to argue Spiegel's professional opinions were rendered in violation of his own organization's ethical guidelines.
April 2018 Dan Wootton / The Sun 'Wife Beater' Article
Unclear
April 2018 article by Dan Wootton in The Sun calling Depp a 'wife beater,' published approximately eight months before the Washington Post op-ed.
Raised by Rottenborn to argue that reputational damage in 2018 had causes independent of the op-ed, undermining damages expert Michael Spindler's rationale for using 2017 as a base year.
Aquaman 2 Script Received by Heard (Pre-April 2020)
Unclear
The Aquaman 2 script received by Amber Heard prior to April 8, 2020, the date of the first Waldman statement.
Arnold used this as industry-practice evidence that Warner Bros. intended to cast Heard in the sequel before Waldman's statements were published, establishing a pre-statement baseline for Heard's career prospects to support the damages analysis in the counterclaim.
Articles on Heard–Van Ree 2009 Assault (Day 16, Exs. 5–6)
Unclear
56
Two articles about Heard's alleged 2009 assault of Tasya van Ree, marked as Exhibits 5 and 6 during Day 16 proceedings.
The disputed evidence at the center of a motion in limine; the judge ruled the articles may be referenced regarding the assault itself but not regarding the arrest, limiting how the prior incident could be used before the jury.
A deal point memorandum signed on August 16, 2016, bearing signatures of both parties and both lead counsel, identified by Wasser as the controlling memorandum for the final divorce settlement.
Confirms the final divorce settlement terms as agreed by the parties and their counsel; Wasser identified it as the operative document governing the settlement, and testified that the payment was not allocated by claim type.
Bania Google Trends Chart 2004–2020 (Demonstrative A)
Excluded
Plaintiff's 1236 (Demonstrative A)
Google Trends chart spanning 2004 to 2020, with seventeen labeled spikes of public interest in Johnny Depp and redlines marking May 2016 and December 18, 2018.
Not admitted; served as the visual foundation for expert Doug Bania's methodology identifying when the public searched for Depp and what content they encountered, underpinning his intellectual property and brand damages opinion.
A demonstrative chart derived from Schnell's own demonstrative, showing the six largest negative hashtag volume spikes with Waldman statement dates marked alongside them.
Showed that the largest spike predated the Waldman statements and that no spikes—in fact a downward trend—coincided with the Waldman statement period, directly rebutting Schnell's causal inference. Not admitted.
Bania Monthly Hashtag Distribution Chart (Plaintiff's 1293)
Excluded
Plaintiff's 1293
A demonstrative summary chart prepared by Doug Bania showing Schnell's Twitter hashtag data by month from January 2018 to June 2021, displaying percentage distribution across pre-Waldman, Waldman-period, and post-Waldman timeframes.
Sought to establish that 35% of hashtag activity predated the Waldman statement period and only 2% coincided with it, forming the foundation of Bania's rebuttal of Schnell's attribution analysis. Not admitted.
Bania Q Score Overlay on Google Trends (Demonstrative C)
Excluded
Plaintiff's 1236 (Demonstrative C)
Q score data overlaid on the Google Trends chart, showing positive and negative Q scores at three time points: pre-2016, post-2016, and post-op-ed.
Not admitted; quantified the shift in Depp's public sentiment using bi-annual survey data at key dates, providing numerical support for the reputational damage claim.
Bania Social Media Follower Comparison Chart (Plaintiff's 1297)
Excluded
Plaintiff's 1297
A demonstrative social media follower comparison chart using pre-Waldman data retrieved via the Wayback Machine, covering Instagram, Twitter, and Facebook counts for Heard and Arnold's five alleged comparable actresses.
Illustrated that Heard's follower counts were orders of magnitude below those of alleged comparables such as Gal Gadot and Zendaya, reinforcing the argument that Arnold's damages comparables were inappropriate. Not admitted.
A demonstrative showing Bania's content analysis of 1.2 million post-April-2020 tweets searched for key Waldman statement phrases, yielding 95 unique tweets and ultimately five tweets directly referencing the statements.
Quantified the near-total absence of Waldman statement language in Schnell's dataset, reducing 2.7 million tweets to five relevant ones and severely undermining Schnell's attribution of the online campaign to Waldman. Not admitted.
Banks and Anderson Clinical Notes — Curry Record Review
Unclear
Dr. Amy Banks's notes and transcript together with Dr. Laurel Anderson's clinical notes as couples therapist, reviewed by Shannon Curry.
Neither Banks nor Anderson diagnosed Heard with BPD or HPD; Curry confirmed this pattern, completing the finding that no treating provider reached her forensic diagnostic conclusions.
A medical record within Bates range Depp 1628–1927 that identifies Dr. David Kulber, produced early in litigation.
Depp's team argued this document gave constructive notice of Kulber's identity as a treating source even without naming him in interrogatory responses, central to the admissibility dispute over his testimony.
Bercovici Expert Disclosure with LAPD Officer Conduct Reference
Unclear
Bercovici's initial expert disclosure and a subsequent supplemental disclosure referencing LAPD officer conduct in connection with the May 2016 incident.
At issue on a scope objection from Heard's team, who argued the supplemental language improperly expanded Bercovici's designation beyond rebuttal; the court disagreed, treating the opening rebuttal designation as controlling.
A billing invoice from Dr. Alan Blaustein's files documenting 18 sessions with Johnny Depp from October 2014 through January 2015.
Authenticated the treatment relationship between Blaustein and Depp and established the number and date range of sessions, anchoring the scope of Blaustein's knowledge of Depp's mental state.
Blaustein Deposition Transcript (Reviewed by Shaw)
Unclear
The deposition transcript of Dr. Alan Blaustein, Depp's psychiatrist, reviewed by plaintiff's expert Dr. Richard Shaw in forming his opinion.
Referenced as part of Shaw's preparation for trial; however, the court's Motion in Limine barred Shaw from offering substantive opinions based on Blaustein's records.
A text exchange in which Bruce Witkin wrote that he was 'really worried about him and this Dr. Kipper,' expressing skepticism toward Kipper's treatment of Depp.
Provided contemporaneous corroboration of concern among Depp's close associates about the nature and adequacy of Kipper's treatment during the period in question.
Carino's March 2016 request for a house call from Dr. Anderson, along with Anderson's reply noting she wanted Depp to understand something she believed he did not.
Anderson's reply supports her testimony that Depp had difficulty in sessions and that she was attempting to communicate something important about the relationship dynamic to him.
Carino–Heard Text Exchange re: Anderson (July 14, 2016)
Unclear
Exhibit 17
Text exchange dated July 14, 2016, between Christian Carino and Amber Heard discussing couples therapist Laurel Anderson and paparazzi avoidance, produced by Heard (Bates ALH).
Establishes Carino introduced both parties to Anderson and demonstrates the closeness of his friendship with Heard shortly after the May 2016 divorce filing.
CHLA Letter to Amber Heard — Pledge Payment Inquiry
Unclear
A letter from Candie Davidson-Goldbronn of Children's Hospital Los Angeles sent directly to Amber Heard, care of Jody Gottlieb, inquiring about additional gift installments.
The hospital wrote directly to Heard seeking a pledge payment and received no response, further documenting the unfulfilled nature of Heard's charitable commitment.
CHLA Letter to Edward White — Pledge Installment Inquiry, June 2019
Unclear
A June 14, 2019 letter from Candie Davidson-Goldbronn of Children's Hospital Los Angeles to Edward White inquiring about further installments on Heard's pledge.
Documents the hospital's proactive attempt to collect on the pledge from Heard's accountant, which produced no result, supporting the argument that Heard's pledge remained unfulfilled.
A corporate designee subpoena directed to Wasser, Cooperman & Handles compelling the firm's testimony through its designated representative.
Confirms that Wasser spoke on behalf of her firm as a whole rather than in her personal capacity, broadening the scope of her testimony to the firm's institutional knowledge and actions.
The Conflict Tactic Scale 2 (Revised, 2nd edition), a research instrument developed for studying family violence prevalence in anonymous survey populations, was administered by Hughes to Heard.
Curry testified it has no response-distortion controls and is easily manipulated by a litigant motivated to inflate partner behavior scores, as it was designed for anonymous research contexts rather than forensic evaluation.
CTS-2 Instructions with Dennison Annotations (Demonstrative)
Unclear
Plaintiff's 1309
The published CTS-2 instructions bearing Dennison's redline annotations, introduced as Plaintiff's 1309 as a demonstrative exhibit.
The instructions specify the test asks respondents about the past year; used to challenge Hughes's deviation from the specified timeframe when administering the test to Heard.
Daily Mail — Waldman 'Abuse Hoax' Statement (July 2020)
Unclear
Exhibit 6
A Daily Mail Online article dated July 3, 2020, quoting Waldman's statement that labeled Heard's allegations 'the end of Ms. Beard's abuse hoax against Johnny Depp.' Waldman confirmed making the statement during his trial testimony.
The third of three Waldman press statements at the core of Heard's counterclaim; its explicit labeling of Heard's allegations as a hoax was cited as directly defamatory.
Daily Mail — Waldman 'Sword and Shield' Statement (July 2020)
Unclear
Exhibit 4
A Daily Mail Online article dated July 3, 2020, quoting Waldman's statement characterizing Heard's allegations as a 'sword and shield' tactic and labeling them fake sexual violence allegations. Waldman confirmed making the statement during his trial testimony.
One of the three Waldman press statements at the core of Heard's counterclaim; its public dissemination formed part of the basis for Heard's defamation claim against Waldman.
Daily Mail Campaign — Waldman's 20 Planted Statements (2020)
Unclear
Evidence or argument describing a coordinated effort involving approximately 20 statements planted in the Daily Mail in spring 2020, before the UK trial.
Cited as evidence of a deliberate campaign by Depp and Waldman to destroy Heard's reputation, supporting the counterclaim theory that the press statements were part of an organized effort rather than isolated or spontaneous public comments.
Danger Assessment Scale — Blank Test Form (Demonstrative)
Unclear
Plaintiff's 1310
A blank Danger Assessment Scale test form, published as a demonstrative exhibit and introduced as Plaintiff's 1310.
The printed instructions specify a one-year timeframe for respondents; used to challenge Hughes's retrospective administration of the test when Depp had been out of the relationship far longer than one year.
David Spiegel's deposition transcript — specifically the line 'So, I mean, he's
Unclear
David Spiegel's deposition transcript — specifically the line 'So, I mean, he's an idiot' and earlier statements about comparing Depp's Pirates performances to deposition testimony.
Used to impeach Spiegel on two fronts: the 'idiot' characterization of Depp, and a methodological admission about using movie roles as a cognitive baseline that Spiegel later called a misstatement.
Hughes's 88-page supplemental clinical notes prepared in connection with her evaluation of Heard.
Their contents were blocked by a sustained objection at sidebar; their existence was cited by Hughes to explain blank frequency fields in the CAPS-5 scoring form as a deliberate clinical documentation choice rather than an oversight.
The pre-trial deposition of Dawn Hughes taken March 28, 2022.
Used by Dennison to impeach Hughes with prior statements about her inability to recall testifying for a male in an IPV matter and an erroneous $100-per-hour compensation figure she had stated at deposition.
December 17, 2015 Kipper Office Medical Record (Heard Visit)
Unclear
Plaintiff's Exhibit 47
A medical record from Amber Heard's December 17, 2015 visit to Dr. Kipper's office, two days after the alleged December 15 incident, documenting no physical injuries and containing a reference to a 'malnourished male' suggesting possible composite or misfiling.
Plaintiff argued the absence of documented injuries showed there were no injuries to document; the 'malnourished male' notation raised questions about the accuracy or integrity of the record.
Twitter exchange between That Umbrella Guy and Morgan Night on April 21, 2022, in which Night replied that the Hicksville incident 'never happened' and characterized Heard as 'acting all jealous and crazy'
Ties Night to pro-Depp social media activity on the same day Depp testified about Hicksville, supporting a bias argument.
Defendant's Exhibit 1077 — ENT (ears, nose, and throat) medical records from Heard's sp
Unclear
Defendant's Exhibit 1077
ENT (ears, nose, and throat) medical records from Heard's specialist consultation in 2016 or 2017.
Shown to Heard to establish nose injuries; record contents excluded as hearsay, though Heard was permitted to testify directly to her physical symptoms.
Defendant's Exhibit 1581L — Color version of Depp's handwritten note or coaster, produce
Unclear
Defendant's Exhibit 1581L
Color version of Depp's handwritten note or coaster, produced in color through Mr. Young's review; previously produced by Depp in black-and-white in this case.
Bredehoft sought to introduce it to corroborate Heard's account of the post-mediation love note; excluded at sidebar as a late discovery production past the cutoff.
Defendant's Exhibit 1904 — Defendant's Exhibit 1904 — APA ethics committee opinions on
Unclear
Defendant's Exhibit 1904
Defendant's Exhibit 1904 — APA ethics committee opinions on principles of medical ethics, containing language that psychiatrists have argued the Goldwater Rule is unsound for expert witnesses who render opinions without examination
Provides published authority that the Goldwater Rule has recognized exceptions for courtroom expert testimony, undermining Shaw's ethical violation claim against Spiegel.
Demonstrative 1900 — Monthly Negative Hashtag Bar Chart
Admitted
Demonstrative 1900
Demonstrative 1900 — a monthly bar chart of negative hashtag volume against Heard and Depp from April 2020 through January 2021, derived from Twitter search API data.
Visually established spikes in negative Heard hashtags correlating with Waldman statement dates and other case events.
Demonstrative 1901 — a line graph of the same hashtag data extended through January 2022, with the dominant 'Justice for Johnny Depp' hashtag removed for scaling clarity.
Shows mathematical correlation across all negative hashtags, supporting the argument that a single driving force caused simultaneous volume changes.
Deposition Exhibit 52 — an internal Disney email from Angela Shaw to co-chairmen Horn and Bergman, president Bailey, and head of communications Roeder, dated May 10, 2017, subject: 'HR. Johnny Depp: A star in crisis and insane story of his missing moments.'
Shows Disney leadership was being kept informed of negative press about Depp as early as 2017, predating the op-ed.
Depo Ex. 53 — Horn/Bailey Disney Email Chain (Jun 2018)
Unclear
Deposition Exhibit 53
Deposition Exhibit 53 — an internal Disney email chain (Disney 114–137) involving Alan Horn and Sean Bailey, dated June 21, 2018, with Bailey's reply reading 'Sad.'
Further evidence Disney executives were tracking Depp's public image deterioration; Bailey's 'Sad' reply suggests concern at the executive level.
Depo Ex. 54 — Newman Rolling Stone Email (Jul 2018)
Unclear
Deposition Exhibit 54
Deposition Exhibit 54 — an email exchange between Newman and Scott Sellers dated July 14, 2018, concerning the Rolling Stone article 'Trouble with Johnny Depp,' with Newman's reply 'Depressing.'
Newman's own reaction to negative Depp coverage demonstrates awareness at the production level.
Depo Ex. 56 — Disney Doc re UK Proceedings (Oct 2018)
Unclear
Deposition Exhibit 56
Deposition Exhibit 56 — a Disney document (Disney 167–177) forwarded to Alan Bergman, containing a THR item about Depp's legal team preparing for the UK court hearing on Amber Heard's abuse claims, dated October 2018.
Shows Disney leadership was aware of the UK defamation proceedings before Heard's op-ed was published.
Deposition transcript of Richard Moore taken March 22, 2022, specifically pages
Unclear
Deposition transcript of Richard Moore taken March 22, 2022, specifically pages 163–164.
Used to impeach Moore's trial testimony: his deposition answer stated he 'can't rule anything out completely,' including a door, knife, or car door — broader than the confident exclusion implied at trial.
Depp Exhibit 5 — a financial document containing Jacobs's notation 'this is good news,' relating to a Bank of America loan secured for Depp.
Establishes that Depp's own agent viewed emergency financing as a positive development, contextualizing his financial state while also showing her continued effort on his behalf.
Depp Medical Records — Redacted Comprehensive File
Admitted
Plaintiff's Exhibit 40
A 123-page redacted compilation of Johnny Depp's medical records, admitted with redactions pending during Dr. Kipper's testimony.
Served as the comprehensive treatment record underlying Kipper's testimony and the evidentiary foundation for the medical evidence presented during his examination.
Depp video depositions taken November 10–12, 2020 and December 14, 2021.
Unclear
Depp video depositions taken November 10–12, 2020 and December 14, 2021.
Spiegel draws on these depositions to describe Depp's slowed processing speed, disjointed speech, and cognitive impairment attributed to substance use disorder.
Depp–Deuters Text — September 3, 2015 Drug Request
Admitted
Exhibit 470
A September 3, 2015 text message from Depp to personal assistant Stephen Deuters requesting Xanax and Adderall and complaining about the cost of Dr. Kipper and Debbie Lloyd.
Documented Depp's active drug requests and his critical attitude toward his own sobriety team during the period covered by the relationship, relevant to the credibility of his recovery narrative.
Depp–Heard Divorce Settlement Deal Point Memorandum (Def. Ex. 1458)
Unclear
Defendant's Exhibit 1458
A deal point memorandum from the Depp-Heard divorce settlement documenting the payment schedule, including a final installment of $2.3 million due on February 1, 2018.
Establishes that all settlement payments were made directly to Heard personally rather than to charities, and that the full settlement amount was in Heard's possession by February 2018 — thirteen months before Depp filed suit.
A single text message from Depp to Dr. Kipper sent shortly after the finger injury on March 7, 2015, admitted as a prior consistent statement.
Admitted to rebut cross-examination impeachment suggesting Depp cut his own finger; plaintiff introduced it as a prior consistent statement corroborating Depp's account of events immediately following the injury.
Disney Subpoena Duces Tecum (Deposition Exhibit 2)
Unclear
Deposition Exhibit 2
Subpoena duces tecum served on Disney, with paragraph 2 specifying document categories Disney was required to produce, explicitly including Heard's op-ed and any impact on Depp's business relationship with the studio.
Defined the scope of Disney's disclosure obligation and framed Tina Newman's entire deposition testimony, establishing what Disney was required to search for and produce regarding the op-ed's alleged career impact on Depp.
Records documenting the full financial scope of Depp's payments under the divorce agreement, including amounts paid directly to Heard, to her attorneys, and toward community liabilities.
Documents the financial terms executed under the divorce settlement, providing context for the overall scope of what Depp paid and the allocation of those payments.
Document re Heard's Separate Therapist (Plaintiff's Ex. 3)
Unclear
Plaintiff's Exhibit 3
Document, previously marked as Anderson Exhibit 6, relating to Heard's reference during couples therapy to her own separate therapist.
Anderson confirmed she never spoke with Heard's other therapists and did not know the therapist's name, establishing the limited scope of her clinical knowledge of Heard.
Document Referenced re Hadden's Verbal-Dispute Classification (Exhibit 11, Hadden Deposition)
Unclear
Exhibit Number 11
A document introduced by defense counsel during Hadden's deposition testimony when asking what Hadden determined the call to be. The specific content of the document was not described in the available transcript.
Introduced in the context of Hadden's verbal-dispute classification of the May 21 call; the specific content was not established from the available transcript.
Dr. David Kulber's Cedars-Sinai medical notes produced by Depp's team (Bates pages Depp 18263–18299), transmitted to the defense during a morning recess. The court ruled the records were a discovery matter and would not be admitted as exhibits, requiring Kulber to testify from memory.
Central to an admissibility dispute over whether Kulber was properly disclosed as a treating source; the court's ruling that the records would not be admitted forced his testimony to proceed from recollection alone.
Dr. Moore's deposition, page 164 — answer regarding ruling out alternative injur
Unclear
Dr. Moore's deposition, page 164 — answer regarding ruling out alternative injury causes
Rottenborn reads the full answer to counter Vasquez's selective reading on cross, restoring Moore's opinion that the vodka-bottle mechanism is inconsistent with the injury pattern.
DSM-5 diagnostic criteria for narcissistic personality disorder (9 criteria, 5 r
Unclear
DSM-5 diagnostic criteria for narcissistic personality disorder (9 criteria, 5 required for diagnosis)
Shaw used the DSM-5 criteria to demonstrate the evidentiary gap in Spiegel's NPD opinion — proper diagnosis requires structured interviews, inventories, and collateral data that Spiegel lacked.
Photographs of Amber Heard taken at the courthouse on the day she filed the domestic violence temporary restraining order, depicting her face without makeup.
Presented as visual documentation of Heard's appearance at the time of the TRO filing, relevant to the question of whether she had visible injuries on that day.
Email shown to Jack Whigham on cross-examination, dated two days after the December 2018 op-ed, and referenced again on redirect.
Whigham used it to show Disney had not yet formally excluded Depp from Pirates 6 as of that date, suggesting the op-ed's immediate career impact was not as direct as claimed.
Erin Falati's nursing notes spanning 2014 through 2016, covering both Amber Heard's and Johnny Depp's care under Dr. Kipper, including Heard's self-reported substance abuse, mental health history, absence of documented injuries after Australia, and admitted illicit drug use in 2016.
The primary document examined during Falati's cross-examination; used chronologically to establish Heard's self-reported history and to show the absence of documented physical injuries in the clinical record following key incidents.
Exhibit 1 — Romero's deposition from July 19, 2016 — page 17 read aloud,
Unclear
Exhibit 1
Romero's deposition from July 19, 2016 — page 17 read aloud, covering her recollection of whether she saw Heard on May 22, 23, and 24, 2016.
Used to establish that Romero had no memory of seeing Heard on May 23rd or 24th, undermining the cross-examination's reliance on video footage from those dates.
Exhibit 163 — Text messages offered by the defense for admission into evid
Unclear
Exhibit 163
Text messages offered by the defense for admission into evidence.
Excluded on hearsay grounds; Judge found no impeachment basis and noted the jury could not have adequate context for the texts without surrounding messages.
Exhibit 3 — an email from Michele Mulrooney to Dana Lowy dated February 2, 2015, requesting deal-point bullet points and Heard's financial information.
Anchors the start of active postnuptial negotiations and identifies Dana Lowy as Depp's counsel in the matter.
Exhibit 30 — L'Oreal Document (Women's Day Campaign)
Unclear
Exhibit 30
Exhibit 30 — a document related to L'Oreal, referenced briefly during questioning about the Women's Day campaign renewal; specific content was not described in the transcript.
Used to frame testimony about the L'Oreal flat-renewal; specific content was not described in the transcript.
Exhibit 7 — an email chain from February 17–18, 2015, covering the confidentiality agreement and Mulrooney's request for Depp's financial disclosures and future revenue streams.
Shows the postnuptial negotiation was progressing and Heard responded promptly, establishing that Depp's phone call — not Heard — ended the process.
Erin Falati's nursing note dated December 16, 2015, recording Heard's report of a December 15 attack that caused a closed eye and headache, and Falati's recommendation that Heard seek emergency room care. The note was read into the sidebar record by Bredehoft and excluded as double hearsay.
The defense sought the note to corroborate Heard's account of a December 15 incident; exclusion under the double hearsay rule, over medical-records and prior-consistent-statement arguments, prevented the jury from considering this contemporaneous clinical record.
Falati Nursing Notes for Johnny Depp, Apr–Jun 2016
Unclear
Exhibit 12 (Falati 114–119)
Erin Falati's nursing notes documenting care provided to Johnny Depp from April through June 2016, covering Falati pages 114–119. The notes recorded Depp's emotional state, medication regimen, alcohol consumption, and statements about the divorce during the post-separation period.
The notes provided a contemporaneous third-party clinical record of Depp's condition and behavior during the post-separation period, relevant to assessing his mental state at the time of the restraining order and divorce proceedings.
Text messages between Erin Falati and Amber Heard on December 16, 2015, regarding injuries Heard reported from a December 15 attack. The defense offered the documents as prior consistent statements rebutting cross-examination; the court excluded them but permitted open-ended oral questioning about the underlying communications.
Bredehoft argued the texts were admissible prior consistent statements; their exclusion limited the defense's ability to corroborate Heard's account of a December 15 incident with contemporaneous documentary evidence, though the underlying communications could still be addressed orally.
Fidelity Charitable Check to CHLA — $250K, January 9, 2018
Unclear
A Fidelity Charitable check in the amount of $250,000 to Children's Hospital Los Angeles dated January 9, 2018, recorded in hospital records as Heard's donation.
Identified by hospital records as the only direct payment from Heard toward the $3.5 million pledge, providing a concrete accounting of the gap between the pledge amount and payments actually made.
Fidelity Donation to Art of Elysium in Heard's Name
Unclear
A Fidelity Charitable donation received by Art of Elysium, attributed to Amber Heard via an anonymous donor-advised fund and accompanied by a letter attributing it to Heard.
Testified to by Jennifer Howell, this donation documented a charitable payment made in Heard's name through an anonymous Fidelity fund, relevant to the broader charitable donation dispute.
Fireman's Insurance Fund Invoices for Kipper Services (2014)
Unclear
Insurance invoices from Fireman's Insurance Fund for Dr. Kipper's services in 2014, confirming the scope of Kipper's treatment relationship with Depp.
Additional billing records corroborating the scope and financial structure of Kipper's treatment engagement with Depp during the early phase of their relationship.
Gerry Johnson Email on Op-Ed Topic Ideas (Exhibit 31)
Unclear
Exhibit 31 (introduced by Chew)
Email from Gerry Johnson listing potential topic ideas for the op-ed, subject to Heard's approval.
Established that ACLU staff originated subject-matter ideas for the op-ed rather than Heard conceiving it independently, supporting Depp's team's argument about the ACLU's role in the article's creation.
A GQ article dated November 2018 about Johnny Depp, introduced as Carino Deposition Exhibit 3.
Carino, who represented both Depp and Heard, had likely read part of it but could not clearly recall its contents, preventing him from assessing whether it had a positive or negative impact on Depp's career.
Walter Hamada's prior trial testimony regarding Jason Momoa's Aquaman salary renegotiation from $3–4 million to $15 million.
Referenced by Marks to distinguish Momoa's renegotiation context from Heard's option structure; Marks noted no sworn testimony confirmed the salary figures Nadelhaft cited.
Walter Hamada's in-court testimony about Warner Brothers' option exercise practices and the chemistry discussion regarding Heard.
Marks cited Hamada's sworn statement that studios do not typically renegotiate option contracts, and noted Hamada's candor about chemistry discussions as unusual but credible.
A sworn declaration made by Amber Heard on April 10, 2019.
Used for impeachment regarding the sequence of the phone-smash incident and Depp's finger injury, highlighting inconsistencies between Heard's prior sworn statements and her trial testimony.
An email from Amber Heard to Romero authorizing the ACLU to cash Depp's $100,000 check and credit it toward her pledge.
Confirms that Heard directed the ACLU to apply Depp's payment toward her own commitment, establishing that Depp's donation was credited to Heard's account rather than made independently.
An email from Amber Heard expressing concerns about publicity related to ACLU donations. The top portion was admitted with redactions; the bottom email was excluded.
Heard's own statements were not hearsay, making the admitted portions directly relevant to her intent and concerns about public perception of the donation.
Photographs that Amber Heard texted to nurse Erin Falati on May 21, 2016, contemporaneous with the penthouse phone-throwing incident on that date.
These photographs constituted a contemporaneous photographic record transmitted to Heard's nurse on the day of the penthouse incident, relevant to documenting the nature and timing of alleged injuries.
Heard–Kipper August 8, 2016 Email Requesting December 2015 Records
Unclear
Kipper Exhibit 36
An August 8, 2016 email from Amber Heard to Dr. Kipper requesting her December 2015 medical records; Kipper believed he provided them, which consisted of the Tinker note.
Relevant to what medical documentation existed from the December 2015 incident period and what records Heard sought to obtain, and to the disputed content of those records.
Hollywood Reporter 'Diminishing Return' Article (Spring 2017)
Unclear
A Hollywood Reporter article from spring 2017 titled 'Pirates of the Caribbean, the Diminishing Return of Johnny Depp,' referenced during Kathryn Arnold's testimony.
Arnold cited it as evidence of Depp's pre-op-ed career decline and diminished franchise value, supporting Heard's argument that Depp's career trajectory had already deteriorated before the Washington Post op-ed was published.
Hollywood Reporter Article on Disney and Depp (Dec 18, 2018)
Unclear
Hollywood Reporter article published in print on December 18, 2018 (appearing online December 20), discussing Disney's view of Depp, on the same morning as Heard's Washington Post op-ed.
Defense expert Kathryn Arnold argued this article — which Depp expert Richard Marks attributed to op-ed fallout — could not have been caused by the op-ed because the two were published simultaneously, undermining the causal chain in Marks's testimony.
Hollywood Reporter Pirates Reboot Article (Oct. 28, 2018)
Unclear
A Hollywood Reporter article dated October 28, 2018, reporting on whether the Pirates of the Caribbean franchise would be rebooted without Depp.
Arnold cited it to demonstrate that the franchise was already publicly moving away from Depp two months before the op-ed, further undermining causation between Heard's Washington Post piece and Depp's loss of the role.
Hughes administered a battery of 12 psychological instruments to Heard: the PAI, TSI-2, M-FAST, PCL-5, CAPS-5, Beck Depression Inventory, Beck Anxiety Inventory, Mood Disorders Questionnaire, Conflict Tactic Scales, Abusive Behavior Observation Checklist, Danger Assessment Scale, and Life Events Checklist.
Formed the foundation for Hughes's PTSD diagnosis and her conclusion that Heard was not malingering; Hughes also relied on the battery results to critique the validity of Curry's CAPS-5 and MMPI-2 administrations.
Set of therapy records reviewed by Dr. Dawn Hughes encompassing records of Dr. Bonnie Jacobs (2011–2014), Dr. Connell Cowan (2014–2015), Dr. Laurel Anderson, and Dr. Amy Banks, plus collateral interviews Hughes conducted with Jacobs and Cowan.
Contemporaneous documentation of Heard's reported abuse and deteriorating psychological status; the absence of personality disorder diagnoses from all treating clinicians supported Hughes's expert conclusions regarding trauma and intimate partner violence.
Hughes Forensic Evaluation Report and Interview Notes (Heard)
Unclear
Dr. Dawn Hughes's forensic psychological evaluation report and interview notes of Amber Heard, including a recorded disclosure of Heard's self-reported arm-cutting at intake.
Curry drew on Hughes's own evaluation records to identify a self-harm symptom consistent with borderline personality disorder that Hughes had documented, and also used Hughes's test data to assess the type of anxiety Heard reported.
The background information questionnaire completed by Hughes during her initial intake evaluation of Amber Heard, including sections on intimate relationships noting James Franco and Elon Musk, and legal history, introduced as Plaintiff's 1246.
Used to challenge Hughes's characterization of Franco as merely a friend and to explore Heard's timeline with Elon Musk relative to the TRO. A domestic violence arrest entry in the questionnaire was the subject of a sidebar that resulted in the court ordering that entry redacted.
Injury and Damage Photographs Offered via Officer Saenz
Excluded
Photographs of alleged injuries to Heard and property damage that the defense sought to introduce through Officer Saenz's testimony. The court sustained a foundation objection.
Excluded through Saenz for lack of foundation; the court ruled they should instead be admitted through Heard's own testimony, shaping the defense's evidentiary sequencing.
Internal ACLU Communications re: Musk and Defense Counsel (P-24)
Admitted
P-24
Internal ACLU donation communications referencing Elon Musk and defense counsel. Only the middle section of page 2, reflecting donation records, was admitted; the remainder was excluded on hearsay and relevance grounds.
The admitted portion provided documentary evidence of ACLU donation records; the remainder was excluded as hearsay or irrelevant.
Depp's interrogatory responses identifying his treating physicians and health care providers, used to assess whether Dr. Kulber was properly disclosed in discovery.
Central to the dispute over whether Dr. Kulber could testify at trial; the judge conditioned his testimony on confirmation that his medical records had been produced.
Designated portions of Jennifer Howell's deposition covering her meeting with Heard at a 2008 premiere, Heard's lack of abuse disclosures to Howell, a $250,000 Fidelity Charitable donation, and Whitney Henriquez's residence.
The court allowed the designations over defense objection, finding sufficient rebuttal nexus to Whitney Henriquez's testimony and Heard's claims about the staircase incident.
Johnny Depp's November 2020 deposition testimony, read into the record, in which
Unclear
Johnny Depp's November 2020 deposition testimony, read into the record, in which Depp described his reasons for terminating Jacobs and alleged conflicts of interest with Mandel and Bloom.
Used to confront Jacobs with Depp's characterization of her representation; Jacobs denied all allegations as untrue.
A June 21, 2016 letter from Samantha Klein to Spector, Carter, and Levine confirming agreements reached in the divorce proceedings, including a mutual media blackout clause prohibiting either party from making press comments about the dissolution.
Memorializes the mutual media blackout agreement, relevant to assessing the propriety of subsequent public statements made by either side about the marriage and its dissolution.
A June 3, 2016 litigation hold and preservation of information letter from Samantha Spector to Samantha Klein.
Establishes that Wasser's firm received formal preservation demands before obtaining the Eastern Columbia Building surveillance footage, relevant to the chain of custody for that evidence.
June 6, 2016 Preservation Acknowledgment Letter (Wasser to Carter)
Unclear
Wasser Deposition Exhibit 4
A June 6, 2016 response letter from Wasser's firm to Charles Carter acknowledging preservation obligations and committing to comply.
Documents Wasser's firm's formal acceptance of evidence preservation duties during the divorce proceeding, establishing the legal framework governing their handling of related evidence.
June 6, 2016 Preservation Request Letter (Carter to Wasser)
Unclear
Wasser Deposition Exhibit 3
A June 6, 2016 letter from Charles Carter to Laura Wasser requesting evidence preservation on behalf of Heard.
A second preservation demand, from additional Heard counsel, received by Wasser's firm, further establishing the formal evidence-preservation framework during the divorce proceedings.
Kipper and Banks Medical Records — Curry Record Review
Unclear
Dr. David Kipper's medical records for Amber Heard, together with records from Dr. Amy Banks, reviewed by Dr. Shannon Curry as part of her comprehensive pre-evaluation case record review.
Part of the broad record review Curry conducted prior to and in conjunction with her in-person evaluation of Heard.
Dr. Kipper's summary-level notes from the Australia treatment period, with Kipper confirming that only summary-level documentation exists and no detailed contemporaneous notes were created.
Established the limited documentary record of the Australia incident from Kipper's perspective, relevant to the completeness of the medical evidence about the finger injury.
Billing records from Dr. Kipper's files covering February 2015 through February 2021, establishing the ongoing financial relationship between Kipper and Depp including a monthly retainer.
Used to establish witness bias by demonstrating the long-term financial relationship between Kipper and Depp throughout the litigation period.
Kipper Consultation Notes — Lloyd Presence and Medications
Unclear
Kipper Exhibit 4
Consultation notes from Kipper's office used to establish Debbie Lloyd's presence at meetings and her role providing personally dispensed medications to Depp.
Used to document the scope of Lloyd's direct involvement in Depp's day-to-day medical care and the manner in which medications were administered.
A Kipper progress note dated June 11, 2014, recording a 'polysubstance abuse' clinical impression and a planned medication and detox protocol for Depp.
Documented the polysubstance abuse impression and the specific medications planned for Depp early in the treatment relationship.
A letter from Dr. Kipper to Johnny Depp dated March 15, 2015, following the Australia finger injury, referenced to establish Kipper's documentation practices around the incident.
Post-Australia correspondence used to contextualize the timing and nature of Kipper's documentation following the finger injury incident.
Dr. David Kipper's intake evaluation of Johnny Depp dated May 22, 2014, documenting Depp's polysubstance abuse history at the start of the treatment relationship.
Served as the primary documentary foundation for Depp's substance abuse history and established the basis for Kipper's initial treatment plan.
Kipper–Depp Text Messages — Treatment Period Compilation
Unclear
Defendant's Exhibit 1063
A compiled set of text messages exchanged between Dr. Kipper and Johnny Depp across the treatment period, containing Depp's use of 'monster' language, complaints about Heard, and expressions of emotional distress.
Provided a broad documentary foundation for Depp's state of mind and communications with his physician during the relationship, including language and emotional content later disputed at trial.
A June 27, 2015 email from Dr. David Kulber to Debbie Lloyd describing Depp's finger injury as a 'bad crush injury.'
Provided the treating surgeon's contemporaneous characterization of the Australia finger wound; Lloyd stated she did not recall receiving or reviewing this email.
X-rays from Dr. Kulber admitted as Australia medical records and shown to defense expert Dr. Moore during his testimony.
Plaintiff argued these records established Kulber as a disclosed treating source; defense disputed whether the Bates-numbered documents constituted proper identification of him in discovery.
L'Oreal communications regarding Amber Heard's marketability, referenced at trial.
Referenced as evidence that negative social media activity — not specifically Waldman's statements — caused L'Oreal to pause use of Heard in campaigns.
LAPD body camera footage from the officers' May 21, 2016 response to the penthouse was previewed at trial without specification of which officer's camera was shown.
Previewed to dispute Depp's claim that responding police found no injury or damage at the scene.
An April 9, 2020 memo from the Office of the Chief of Police addressing the VINE pamphlet and legislatively mandated requirements to provide domestic violence victim information to victims.
Establishes the department's formal mandate to provide DV resources to victims, used to highlight Saenz's failure to offer the pamphlet to Heard on May 21, 2016.
LAPD Incident Recall — Gatlin/Diener Unit and TOMSG Log, May 21, 2016
Unclear
Defendant's Exhibit 6
The LAPD incident recall for Officers Gatlin and Diener's May 21, 2016 response to 849 S. Broadway, including the TOMSG administrative data log (LAPD 11) showing the inter-unit message and Gatlin's 'rog' acknowledgment.
Establishes the timeline and prior knowledge for Gatlin's unit; used to refresh Gatlin's recollection about the administrative message received before arriving at the scene.
The official LAPD incident report for the May 2016 penthouse call, admitted as DX 730 through the Saenz deposition. Provides the responding officers' formal written observations of the scene.
The only documentary exhibit admitted through the Saenz deposition; serves as the official police record of what responding officers observed and documented, providing a baseline for evaluating competing accounts of the incident.
LAPD Policy/Procedural Forms Package — Excluded via Saenz Deposition
Excluded
DX 756DX 757DX 758DX 759
A package of LAPD policy and procedural forms (DX 756–759) referenced during the Saenz deposition that the court declined to admit formally. Oral reference in the deposition was permitted but formal admission was denied.
Excluded as not relevant to the fact witness testimony; their exclusion required the defense to introduce LAPD policy standards through other exhibits and witnesses.
Debbie Lloyd's deposition transcript and nursing notes on Depp's detox-related rage incidents, proffered by the defense to corroborate Heard's accounts during the Bahamas detox.
Excluded as hearsay; would have provided nurse testimony contemporaneously corroborating Heard's descriptions of Depp's behavior during the Bahamas detox period.
Lloyd–Blaustein October 2014 Medication List Email
Excluded
Defendant's Exhibit 301
An October 26, 2014 email from Debbie Lloyd to Dr. Alan Blaustein listing Depp's prescription medications, including Seroquel, Adderall, and Neurontin.
Not admitted due to hearsay; used as the basis for Dr. Spiegel's opinion on the pharmacological significance of Depp's combined medication regimen. The court directed counsel to ask hypothetically instead.
Text messages between Debbie Lloyd and Johnny Depp, Bates pages DEPP 7804–7848, including a May 27, 2015 message from Depp claiming his medications were stolen and pointing to 'the sister.'
Documented Depp's claims about stolen medications and his accusations directed at a family member of Heard, relevant to the dynamics around medication management and the parties' relationship.
The M-FAST, a forensic assessment instrument designed to detect feigned psychiatric symptoms, was administered by Hughes to Heard as the sole malingering measure in her evaluation.
Hughes defended the M-FAST's applicability to this case and noted that Curry administered no independent malingering instrument, a point used to differentiate their respective methodological choices.
Text messages exchanged between Depp and Heard on May 23–24, 2016, showing that Heard was aware Depp was out of town and referencing the TRO and domestic violence filing.
Presented by Depp's team to show Heard's awareness of his whereabouts at the time she filed the TRO and her expressed uncertainty about the filing, bearing on the credibility of the domestic violence allegations.
May 24, 2016 Divorce Initiation Letter (Spector to Bloom)
Unclear
Wasser Deposition Exhibit 1
A May 24, 2016 letter from Samantha Spector to Jake Bloom initiating divorce proceedings on Heard's behalf and requesting pendente lite support and acknowledgment of service.
Establishes the timeline of Heard's legal team's engagement and communications with Depp's counsel before the May 27 TRO application.
Melissa Saenz Deposition Transcript — July 18, 2016
Unclear
Exhibit 57
The transcript of Melissa Saenz's deposition taken approximately two months after the May 21, 2016 incident, introduced as Exhibit 57.
Used to refresh Saenz's trial recollection of her specific questions to Heard; her 2016 answers confirmed Heard said 'nothing,' shook her head, and denied needing an ambulance.
Monroe Tinker Patient Record for Heard, Dec 17, 2015
Unclear
Kipper Exhibit 35
A patient record from Monroe Tinker documenting a physical examination of Amber Heard on December 17, 2015, initiated following a call about headaches. The examination found no physical injuries and returned no concussion diagnosis.
The negative clinical findings on December 17, 2015—no documented injuries, no concussion—were used by Depp's team to undercut claims that Heard sustained physical harm in an incident around that date.
NBC Interview — Heard Claims $7M Donated to ACLU and CHLA
Unclear
A video of Amber Heard in an NBC interview claiming she donated the full seven million dollars in divorce settlement proceeds to the ACLU and Children's Hospital of Los Angeles.
Contrasted at trial with evidence of only partial payments, this interview was used to argue that Heard made false public statements about the donation.
News Article — 'Amber Heard Donates Settlement to Charity' (Pl. Ex. 1259)
Admitted
Plaintiff's Exhibit 1259
A news article titled 'Amber Heard Donates Johnny Depp Divorce Settlement to Charity,' including Heard's public statement pledging the seven million dollar settlement to charity.
Establishes the public pledge that Vasquez then contrasted with Heard's admission at trial that no full payment had been made, underpinning the impeachment on the donation claims.
News Article — 'Depp–Heard Row Over Divorce Donations' (Pl. Ex. 1260)
Admitted
Plaintiff's Exhibit 1260
A news article titled 'Amber Heard and Johnny Depp row over divorce donations,' containing a statement from Heard's spokeswoman demanding Depp pay fourteen million dollars if donating directly to the charities.
Shows Heard's position demanding adjusted payment after Depp donated $100,000 to each charity directly, framing the evolving dispute over the manner in which the divorce settlement would be directed.
October 2018 Daily Mail Headline on Depp / Pirates 6
Unclear
Defendant's Exhibit 115
October 2018 Daily Mail headline speculating that Depp would not appear in Pirates of the Caribbean 6, published approximately two months before the Washington Post op-ed.
Introduced by defense expert Richard Marks to support the argument that doubts about Depp's Pirates 6 casting predated and were independent of the op-ed, undermining Depp's expert's causal theory.
October 2018 Press Reports on Depp's Pirates 6 Exclusion
Unclear
October 2018 press articles reporting that Disney had decided not to cast Depp in Pirates of the Caribbean 6, published approximately two months before the op-ed.
Cited to establish that Depp's loss of the Pirates 6 role may have predated and been independent of the op-ed, which would reduce that component of Depp's damages claim to zero.
Body camera footage from Officer Diener's camera recording the arrival at penthouse 3 and the encounter with occupants on May 21, 2016. Shows dim lighting, distance from Heard, and the behavior of the three women present.
Provides direct visual record of the penthouse encounter; used to establish what officers could and could not have observed about Heard's appearance and demeanor given lighting and distance.
Body camera footage from Officer Gatlin's own camera recording the same May 21, 2016 penthouse encounter from a second angle. Gatlin confirmed on the stand that this footage was his.
Second-angle visual record of the encounter; used to assess visibility of Heard's face and the positioning of the three women present.
A handwritten comment by Eastern Columbia Building general manager Brandon Patterson on a draft of the Waldman declaration, noting the mezzanine fake-punch footage.
Used to establish Patterson's own contemporaneous uncertainty about dates, participants, and whether Heard showed injury signs, testing the credibility of the Waldman declaration and Patterson's reliability as a witness.
PCL-5 Instruction Manual (National Center for PTSD)
Admitted
Plaintiff's 1312
The official PCL-5 instruction manual published by the National Center for PTSD, introduced as Plaintiff's 1312.
Contains the provision that the PCL-5 should not be used as a standalone diagnostic tool; admitted and used to challenge Hughes's pre-CAPS-5 PTSD diagnosis.
Raquel Pennington's deposition taken on July 14, 2016 in connection with the Depp-Heard divorce proceedings, Volume 2, pages 238–240.
Used by Vasquez to refresh Pennington's recollection of the Thanksgiving incident, establishing that Depp returned to dinner and acted as though nothing had happened.
People Magazine — Heard Abuse Allegations Article (PX 409)
Admitted
PX 409
A People magazine article on Heard's abuse allegations against Depp, admitted as Plaintiff's Exhibit 409.
Depp testified he recalled seeing this specific article and felt compelled to warn his children about its content, making it a particularly significant data point in his account of the personal and reputational impact of the public allegations.
Plaintiff's 120D — Plaintiff's Exhibits 120A–120D — documents including a June
Unclear
Plaintiff's 120D
Plaintiff's Exhibits 120A–120D — documents including a June 16, 2015 communication referenced in sidebar
Nadelhaft sought to use Connolly's prior characterization of Heard as professional; objection sustained as hearsay after sidebar, though Connolly had already testified to the same effect on direct.
Plaintiff's Trial Exhibit 1294 — a hashtag spike timeline chart numbered 1 through 6.
Displayed to establish that five of six negative hashtag spikes occurred after the Waldman statements and to discuss the February 2020 pre-Waldman spike.
Plaintiff's Trial Exhibit 1297 — a demonstrative showing Instagram follower counts for Heard and comparables including Ana de Armas.
Nadelhaft used it to show that de Armas had fewer followers and lower familiarity yet Bania still excluded her as a comparable, probing the consistency of his methodology.
Plaintiff's Exhibit 888, page 76 — Bania's expert designation document listing search result headlines 6A through 6N.
Nadelhaft sought to admit this page to show the articles Bania used to contextualize hashtag spikes; the objection was sustained because the document contained a reference to the UK ruling.
Floor plan of the rooftop penthouse level of the Eastern Columbia Building, showing the layout of penthouses 1–5, elevator, pool, and gym.
Used to orient the jury to the physical geography of the building — establishing spatial relationships between Baruch's unit and Depp/Heard's, and to anchor the corridor observations from May 21 and May 22.
Plaintiff's Exhibit 1248 — Photograph of Heard and Depp at a Russia dinner event in con
Unclear
Plaintiff's Exhibit 1248
Photograph of Heard and Depp at a Russia dinner event in connection with The Lone Ranger.
Taken after the alleged June 2013 Russia incident in which Heard testified Depp whacked her in the face causing a nosebleed; photo shows no visible facial injuries.
Plaintiff's Exhibit 162 — Photograph taken by Connolly of Depp, Heard, and train staff
Unclear
Plaintiff's Exhibit 162
Photograph taken by Connolly of Depp, Heard, and train staff in the dining car of the Orient Express during their honeymoon journey from Bangkok to Singapore.
Connolly identifies swelling under Depp's left eye and on the left side of his nose, presented as consistent with the pattern of marks he observed on Depp over the course of the relationship.
Plaintiff's Exhibit 9 — Still photograph or video frame from Amber Heard's appearanc
Unclear
Plaintiff's Exhibit 9
Still photograph or video frame from Amber Heard's appearance on The Late Late Show with James Corden, December 16, 2015.
Vasquez displayed the image to have Inglessis identify on-screen what she described as visible swelling on the right side of Heard's lip and discoloration under the right eye, testing the credibility and precision of her injury observations.
A collection of approximately twelve articles from the Guardian, Hollywood Reporter, Vanity Fair, Rolling Stone, and the Daily Mail, published between 2014 and 2018, with headlines referencing alleged intoxication, financial collapse, and career decline.
Not admitted; used by Rottenborn to establish that Depp's public reputation was substantially damaged before the op-ed was published, challenging the defamatory sting element of Depp's damages claim.
Prior deposition transcript excerpt: Carino's deposition testimony (approximately one year prior to trial) about Pirates 6 loss, Jerry Bruckheimer, Jack Whigham, and Brian Lourd — read back to him during examination.
Used to establish consistency of Carino's opinion that Heard's accusations caused Depp's removal from Pirates 6.
Proffered Falati Records Bundle (Dec 2015 & May 2016)
Excluded
HIJKLMNO
A set of proffered exhibits (H through O) comprising Erin Falati's nursing notes, associated text messages, and a deposition transcript covering the December 2015 headbutt incident and the May 21, 2016 phone incident. The entire bundle was excluded as hearsay.
The excluded bundle represented the defense's attempt to place contemporaneous documentary evidence of two alleged abuse incidents before the jury; exclusion meant the jury could not consider these records when evaluating Heard's injury claims for those incidents.
A set of Plaintiff's Exhibits 1267–1278 comprising negative publicity articles about Heard from February through June 2020, presented through Amber Heard's testimony. Headlines were read into the record but the exhibits were not admitted; exhibits 1273 and 1274 were additionally excluded on objection.
Offered to contest the causation argument between Waldman's three statements and Heard's alleged damages by showing that substantial negative coverage of Heard predated or was independent of the Waldman statements.
A May 30, 2016 news article headlined 'Amber Heard smiles as she puts arm around friend one day after getting restraining order against Johnny Depp,' presented as Plaintiff's Exhibit 1315 during Amber Heard's testimony. Vasquez moved to admit it in partially redacted form showing only the headline and date.
Rottenborn objected that the proposed admission was inconsistent with prior practice; Judge Azcarate sustained the objection and excluded the exhibit.
A media article covering Heard's temporary restraining order allegations against Depp, admitted as Plaintiff's Exhibit 411.
Establishes the publication and reach of Heard's abuse allegations in support of Depp's reputational harm claim, forming part of his evidence of the media metastasis of the domestic violence allegations.
PX 414 — News Article on Heard's Domestic Violence Allegations
Admitted
PX 414
A media article covering Heard's domestic violence allegations and TRO against Depp, admitted as Plaintiff's Exhibit 414.
Part of Depp's evidence establishing the media metastasis of abuse allegations that damaged his career, supporting the causal chain between Heard's public statements and Depp's reputational harm.
Plaintiff's Exhibit 1236, a Google Trends demonstrative published to the jury during direct examination.
Nadelhaft used this exhibit against Bania, pointing to declining searches immediately after the op-ed and showing that the 2004 search peak dwarfed all post-2016 activity.
Plaintiff's Exhibit 804 — Depp's Disney contract for Pirates of the Caribbean 4 and 5, including compensation terms and merchandise provisions, admitted minus cover letter after sidebar.
Establishes Depp's franchise investment and career stake prior to being dropped from the franchise.
Plaintiff's Exhibit 889 at page 117 — a Q score chart compiled from Dr. Allen Jacobs's data covering winter 2012 through summer 2021, admitted as a demonstrative over a foundation objection.
Showed a seven-point positive Q score drop predating Heard's involvement and a partial post-op-ed recovery omitted from Bania's analysis.
Pennington described Heard striking her in the face while shopping for Thanksgiving items; Curry cited this as behavioral evidence consistent with BPD's explosive anger pattern.
Richard Gilbert's sworn deposition taken March 17, 2022, referenced at pages 61
Unclear
Richard Gilbert's sworn deposition taken March 17, 2022, referenced at pages 61 (document page 16) and pages 25–26 (document page 7).
Used to impeach Gilbert on two points: his characterization of Heard's account and his assertion that Depp's hand 'likely' moved during impact, eliciting that he had read no evidence supporting the latter.
Romero Exhibit 1 — Romero Exhibit 1 — Deposition of Alejandra Romero, July 19,
Unclear
Romero Exhibit 1
Romero Exhibit 1 — Deposition of Alejandra Romero, July 19, 2016
Read back at p. 35 to confirm Romero's prior sworn testimony that she was not looking for marks on Heard's face — used to lock in the impeachment of her witness statement.
RTL Late Night Clip — Heard States '$7M Was Donated' (Pl. Ex. 346)
Admitted
Plaintiff's Exhibit 346
A video clip of Amber Heard appearing on the RTL Late Night television program, in which she states that seven million dollars in total was donated, split between the ACLU and Children's Hospital of Los Angeles.
Made in October 2018 after Heard had received the full settlement, Heard's use of past tense 'was donated' — when full payment had not been completed — formed the core of Vasquez's perjury-adjacent impeachment of Heard's donation claims.
A demonstrative chart of negative hashtag usage over time from 2020 to 2022, showing volume spikes intended to be correlated with Waldman statement dates, presented during Schnell's testimony.
Dennison used the chart against Schnell during cross-examination to show the dominant negative hashtag predated Waldman's statements, the largest spike preceded his statements, and Waldman's statement dates were not actually marked on the chart, undermining Schnell's causal narrative.
An admitted demonstrative chart prepared by social media analyst Ron Schnell showing term-frequency searches for 'hoax,' 'fake,' 'fraud,' 'Waldman,' and 'Wald-Mignon' within the corpus of negative hashtag tweets.
Quantified that 25% of tweets in the negative hashtag universe directly attributed language to Waldman and that his 'hoax' framing appeared 81,121 times, supporting the theory that Waldman's statements drove the online campaign against Heard.
Shannon Curry Day 10 Trial Testimony (Page 2710, Line 13)
Unclear
A specific passage from Shannon Curry's Day 10 trial testimony at page 2710, line 13, containing a prior sworn statement confirming she had not been asked to testify about Heard's behavior in the context of her relationship with Depp.
Used to define the scope of Curry's mandate; Curry confirmed she still agreed with the statement, which Bredehoft used to close out cross-examination on whether Curry had been asked to opine on abuse.
Shannon Curry's Expert Materials — Reviewed by Spiegel
Unclear
The collective body of Shannon Curry's expert reports, deposition, and trial testimony, reviewed by Dr. David Spiegel in preparation for his own expert testimony.
Spiegel reviewed Curry's materials, but the court sustained an objection barring him from opining on Curry's MMPI results or Heard's credibility on those tests, significantly limiting the use he could make of Curry's materials at trial.
Demonstrative earnings chart from Spindler's expert report showing Depp's annual income from 2009 to 2020, drawn from records provided by Ed White's office.
Published to the jury by Rottenborn to illustrate that 2017 was an atypical high outlier and that Depp's post-op-ed 2020 earnings exceeded several pre-op-ed years.
Spindler deposition transcript, Volume 2, March 25, referenced by Rottenborn at the first sidebar.
Used to establish that Spindler's designation scope was limited to addressing Arnold's analysis and did not extend to rendering independent causation opinions.
Lost earnings demonstrative chart prepared by Spindler's firm showing a two-component breakdown and a $40,318,237 total, used as a demonstrative and not moved into evidence.
Used to walk the jury through the damages calculation visually, illustrating the component breakdown of Spindler's expert opinion.
Deposition and trial testimony of Heard and Depp from both U.S. and UK proceedings, plus depositions of therapists Bonnie Jacobs, Connell Cowan, and Amy Banks, reviewed by Dr. Dawn Hughes as part of her expert analysis.
Cross-referenced for consistency with Heard's reported account and with medical records; formed part of Hughes's evidentiary basis for her expert findings on trauma and IPV.
Three Waldman Statements April–June 2020 (Hughes Basis)
Unclear
The three public statements issued by Adam Waldman on April 8, April 27, and June 24, 2020, considered together as a set during Dawn Hughes's expert testimony.
Hughes offered a second main opinion that Heard suffered exacerbated PTSD symptoms as a direct result of Waldman's three counterclaim statements, using this group as the factual predicate for her psychological findings.
TV Guide Interview — Depp Drug Use Disclosure (1989)
Unclear
A 1989 TV Guide interview in which Depp publicly acknowledged early drug use.
Depp used this prior public disclosure to frame his substance history as longstanding and openly acknowledged, arguing that it was not something Heard uniquely exposed during their relationship and therefore could not form the basis of fresh reputational harm attributable to her.
Twenty Twenty Wine Merchants invoices showing a balance of approximately $160,000 at the time of the Depp-Heard divorce and a near-zero current balance.
Offered as rebuttal evidence to counter claims of ongoing excessive wine spending by Depp, demonstrating the balance had been substantially reduced.
Twitter posts found by Night via a keyword search for 'Hicksville trailer,' including one claiming Depp yelled at and grabbed Heard by the fire pit, and Night's reply denying the account.
Night's reply constitutes a prior statement made before attorney contact in which he denied the fire pit allegation and characterized Heard as the jealous party — the core factual dispute his voir dire testimony addresses.
Two house videos filmed by Roberts showing the interior of Depp's island house
Unclear
Two house videos filmed by Roberts showing the interior of Depp's island house
Bredehoft challenges completeness — no bathroom footage exists and Roberts cannot recall who requested the videos or whether they were made for the U.K. trial.
USA TODAY articles interpreting Heard's Washington Post op-ed as referring to Johnny Depp.
Introduced to demonstrate third-party public understanding that the op-ed's statements were 'of and concerning' Depp, supporting the defamation claim's identification element.
A VINE pamphlet listing domestic violence victim resources, shelters, and phone numbers, introduced as Exhibit 11 during Officer Saenz's deposition.
Saenz confirmed she did not provide this pamphlet to Heard because she did not identify Heard as a domestic violence victim during the May 21 response, supporting the defense's argument that the investigation fell short of required protocol.
Waldman On-Record Statement to RTL — LAPD Perjury Investigation Claim
Unclear
ARW 660
Adam Waldman's on-record statement to German media outlet RTL claiming that LAPD had opened a criminal perjury investigation into Amber Heard, introduced as ARW 660.
Anchored cross-examination challenging Waldman's claimed basis for the perjury investigation narrative and forced Waldman to explain the factual predicate for his public claim.
A text message thread comprising six messages among three parties over 209 minutes, involving publicist Keith Bishop arranging a Mail Online meeting for Waldman on February 17. Waldman recalled that Depp was present at the meeting and that he provided two audiotapes.
Establishes that Waldman used a London publicist to coordinate press meetings with the Daily Mail Online, supporting Heard's argument that the defamatory statements were part of a deliberate media campaign rather than spontaneous remarks.
Deposition of Disney's corporate designee, in which Disney represented that it produced no internal documents referencing Heard's op-ed and the designee did not recall seeing it.
Central to the defense challenge to Depp expert Richard Marks's causal theory; used to argue Disney's internal record did not support the claim that the op-ed drove the Pirates 6 casting decision.
Hamada stated WB holds actors to contracted deals and that nothing Depp said affected Heard's compensation—testimony Arnold acknowledged but did not incorporate into her renegotiation assumptions.
Used to impeach Whigham's direct testimony by showing his prior sworn statement that by fall 2018 he had already inferred Pirates 6 was unlikely for Depp.
Checks issued by Edward White to Children's Hospital Los Angeles ($100,000 ×2) and the ACLU ($100,000), reflecting Depp's direct charitable contributions prior to or alongside the divorce settlement.
Establishes Depp's direct charitable contributions, relevant to the broader context of the donation-pledge dispute and the question of how the divorce settlement was to be directed to charity.
White Cover Letter to CHLA — First Pledge Installment (Def. Ex. 1596)
Admitted
Defendant's Exhibit 1596
A cover letter from Edward White to Children's Hospital of Los Angeles enclosing a check, using identical 'first of multiple scheduled installments' language to describe Heard's $3.5 million pledged gift, mirroring the contemporaneous ACLU correspondence.
Corroborates the pledge framing applied to both charitable recipients; having been drafted in the ordinary course of White's business, the consistent language across both letters reinforces that the payments were always understood as installments on a pledge.
Transcripts of Johnny Depp's sworn testimony in Depp v. News Group Newspapers, including Day 3, page 421, where Depp addressed the Australia bar phone, and additional pages used throughout his Virginia cross-examination.
Served as the primary impeachment vehicle during Depp's Virginia cross-examination; specific pages — including his prior testimony about ripping a phone off the wall in Australia — were used to establish prior inconsistent statements on multiple topics.
Depp's UK High Court Complaint Against The Sun (June 13, 2018)
Unclear
Carino Exhibit 11Defendant's Exhibit 1599
Depp's June 13, 2018 complaint filed in the UK High Court against The Sun newspaper and journalist Dan Wootton, alleging the article caused serious harm to his personal and professional reputation.
Established that Depp had sued The Sun in 2018, before Heard's Washington Post op-ed, and that associates including Carino and Whigham were aware of the UK litigation and Depp's own allegation of reputational harm.
Starling Jenkins III UK Witness Statement, Paragraph 13
Unclear
The written witness statement of Depp's security guard Starling Jenkins III submitted in the UK Sun trial, specifically paragraph 13, which states that Find My iPhone located Depp's phone 'on the streets below the balcony of the residence.'
Used to impeach Jenkins's Virginia testimony that Depp's phone was found six miles away in Skid Row; the two sworn accounts are irreconcilable. The full paragraph confirms Jenkins recovered the phone via a homeless man on the street near the building.
The November 2, 2020 judgment in Depp v. News Group Newspapers (the UK Sun libel case). The Virginia court excluded it from evidence, denying two attempts by Heard's counsel to introduce it.
Heard's counsel argued Depp had opened the door to admission by seeking post-judgment damages; Judge Azcarate rejected that argument both times and excluded the judgment.
Amber Heard Third UK Witness Statement (Feb. 26, 2020)
Unclear
Amber Heard's third witness statement submitted in the UK Sun libel action, signed February 26, 2020, which states that 'the entire amount of my divorce settlement was donated to charity.'
Vasquez read paragraph 4 to the jury to impeach Heard's Virginia trial testimony, showing that Heard made the same unqualified donation claim under oath in the UK proceedings.
Edward White UK Trial Testimony (p. 865 — 'Catastrophic News')
Unclear
Edward White's sworn testimony from the UK libel trial, page 865, containing a question and answer in which White characterizes an April 21 briefing as 'catastrophic news.'
Used to impeach White when he denied in Virginia having described the April 21 briefing as catastrophic; his UK sworn answer directly contradicted his Virginia testimony.
InsidetheMagic.com Article on Pirates of the Caribbean (Nov. 5, 2020)
Unclear
Defendant's Exhibit 134
A November 5, 2020 article on Insidethemagic.com reporting that Disney had scrapped plans for Depp's return to the Pirates of the Caribbean franchise, published three days after the UK trial judgment.
Used to argue that the cancellation of Depp's Pirates involvement was connected to the UK trial fallout rather than solely to Heard's op-ed, complicating Depp's damages theory.
Travis McGivern's observation of Depp's heavily bandaged right hand on March 23, 2015, which McGivern noted was the same wrapping Depp had when he returned from Australia.
Corroborates that Depp's finger injury sustained in Australia was a pre-existing condition at the time of the March 23 penthouse incident, bearing on the injury timeline disputed at trial.
Raquel Pennington UK Witness Statement (June 16, 2020)
Unclear
Pennington Exhibit 1
Raquel Pennington's sworn witness statement submitted in the UK Sun trial proceedings, dated June 16, 2020.
Introduced to authenticate Pennington's prior sworn account and establish its provenance; Pennington confirmed she wrote it independently, without assistance from Heard or Heard's counsel, and that its contents are true.
The written witness statement of Travis McGivern prepared for the UK Sun trial, paragraph 5, stating that when McGivern and Lloyd entered the penthouse, Heard and Depp were already engaged in a verbal argument.
Used to impeach McGivern's Virginia direct testimony about the sequence of events on March 23, 2015, specifically his claim that he first encountered Heard in the lobby before going upstairs.
A large bowie knife inscribed "Hasta la muerte / XX Slim" (until death), given by Amber Heard to Johnny Depp as a gift, variously dated to circa 2012 (during The Lone Ranger filming) or circa 2015. Two photographic exhibits were introduced — one showing the blade (PX 92) and one showing the full knife (PX 93) — as well as the physical knife itself.
Introduced by Depp's team to challenge Heard's claims of abuse-driven fear of Depp: Depp's attorney argued the inscription and the act of gifting a knife were incongruous with a victim afraid for her life. Hughes, testifying for Heard, offered a counter-contextualization, linking the inscription to Depp's own documented statement that 'the only way out of this relationship is death.'
A color-correction makeup palette and kit belonging to Amber Heard, introduced as a demonstrative exhibit. Entered as Defendant's Exhibit 1/155 during Heard's testimony and again as DX-155 later in the proceedings.
Supports Heard's account that she concealed bruises on a daily basis using professional-grade color-correction products; directly contradicts testimony from Eastern Columbia Building witnesses who stated they did not observe bruises or heavy makeup on Heard during the relevant period.
A broken vintage light sconce discovered in Depp and Heard's trailer at the Joshua Tree property the morning after their stay. A matching replacement pair was subsequently sourced for $62 and charged to Depp's assistant. No formal exhibit was introduced.
Offered as physical evidence of damage at the Joshua Tree property; property owner Morgan Night characterized the damage as minor and did not assess a cleaning fee, contextualizing the scale of the alleged altercation at that location.
A necklace allegedly pulled from a traveling companion's neck by Amber Heard during the 2009 altercation at Seattle-Tacoma International Airport. Referenced in witness testimony but not formally introduced as an exhibit.
Cited to establish the nature and degree of force in Heard's alleged aggression during the 2009 Sea-Tac incident, the earliest physical altercation alleged at trial.