Michael Spindler

“I concluded that Mr. Depp suffered lost earnings of about $30 million.”

“the loss related to the loss of that role and that franchise picture was $22.5 million, based on testimony provided by Mr. Jack Whigham”

“Mr. Whigham testified that that was a typical year for Mr. Depp, and it's also the most recent, clean year”

“Well, that's grand total. That's the sum of those two components for total lost earnings of $40.3 million.”

“Correct. And I'm not acknowledging any of this being accurate. I'm just saying that that wasn't part of my calculations.”

“That sounds like hyperbole to me. I didn't take that very seriously.”

“2017 was a year in which Mr. Whigham indicated that that was a typical year for Mr. Depp. He had a studio. He had an independent. He had an endorsement deal.”

“You're taking a look at what Mr. Depp would have been expected to earn in a typical year, and then you're comparing that to the period of time where you're analyzing following the op-ed from December of 2018 through October 2020.”

“It is not adequately supported, and it is unreasonable.”

“you also don't have the - any potential impact from the alleged defamatory Waldman statements that occurred in April of 2020. So 2019 is clean of all that.”

“That methodology was unsound. It's just unsupported. There are no numbers. There's no data that she provided in support for that.”

“There was a slight increase during that period of time in her earnings from 2013 through 2019.”

“That's correct. I'm not testifying on causation issues.”

“I've been involved in defamation cases, but I've not done the calculations as an expert.”