Plaintiff's Team · Brown Rudnick

Wayne Dennison

Johnny Depp’s counsel who examined expert witnesses on damages, psychology, social media and digital photographs.

2022 Defamation Trial Apr 11 – Jun 1, 2022

2,018 lines 38 proceedings 5 highlights

About

Wayne Dennison, a Brown Rudnick attorney on Depp’s trial team, questioned witnesses about psychological evaluations and claimed lost earnings. He examined forensic accountant Michael Spindler about his estimate of Depp’s lost earnings and, after opposing counsel challenged the analysis, asked Spindler to explain his choice of 2017 as a baseline. He also questioned psychologist Shannon Curry and asked her to address challenges to her evaluation methods.

In cross-examining Heard’s psychologist Dawn Hughes, Dennison challenged the timing of her PTSD diagnosis, her use of test instructions and blank fields in her CAPS-5 assessment. Hughes defended her methods, citing supplemental notes and explaining on redirect why she considered some risk factors unaffected by the evaluation window. Dennison played a recording in which Heard spoke about hitting Depp and starting physical fights. Heard’s counsel later played additional excerpts in which Depp acknowledged mutual physicality. Dennison also challenged psychiatrist David Spiegel’s qualifications to address intimate partner violence and questioned his opinions under the Goldwater Rule. Spiegel said intimate partner violence could not be separated from trauma; on redirect, he addressed the rule by distinguishing the private records he reviewed.

Dennison questioned social-media analyst Ron Schnell about whether negative hashtags could be attributed to Adam Waldman’s statements. Schnell acknowledged that his analysis showed correlation, not causation, while maintaining that negative tweet volume increased and that more than a quarter of negative tweets referenced Waldman. Dennison pressed entertainment consultant Kathryn Arnold on other possible causes of Heard’s claimed career losses and the basis for her estimate. Arnold defended the timing as evidence of a link and said her estimate used Heard’s negotiated contract rates. In questioning computer-forensics witness Julian Ackert, Dennison tested the scope of his photograph analysis and compared visually different files with matching names and timestamps. Ackert limited his authentication opinion to photographs another expert had flagged and said he had not performed the software-metadata analysis needed to assess the pair.

Trial Record (38)

2022 Defamation Trial Apr 11, 2022 – Jun 1, 2022 38 proceedings

Day 9 April 26, 2022

Direct Direct Examination of Shannon Curry Shannon Curry Wayne Dennison 104

Summary

Forensic psychologist Shannon Curry testifies that Amber Heard has borderline and histrionic personality disorders, does not have PTSD, and showed gross exaggeration of PTSD symptoms during testing.

Cross Cross Examination of Shannon Curry Shannon Curry Elaine Bredehoft 20

Summary

Bredehoft challenges Curry's independence through her pre-retention dinner with Depp, an expert designation listing opinions Curry hadn't formed, and prior-statement impeachment on IPV expertise.

Redirect Redirect Examination of Shannon Curry Shannon Curry Wayne Dennison 14

Summary

On redirect, Curry addressed the CAPS-5 and trauma-test findings and explained how she distinguished treating and forensic roles.

Day 11 April 28, 2022

Direct Direct Examination of Edward White Edward White Wayne Dennison 77

Summary

Depp's accountant testified about the April 21, 2016 meeting, settlement negotiations totaling $14.25M, charity payments, and Heard's wine orders at the birthday party.

Cross Cross Examination of Edward White Edward White J. Benjamin Rottenborn 18

Summary

Rottenborn impeaches Depp's business manager on prior oath statements about financial catastrophe, Depp's work punctuality, and the nature of Heard's charitable pledge.

Redirect Redirect Examination of Edward White Edward White Wayne Dennison 8

Summary

Dennison elicits the pledge letter language confirming Heard's $3.5M gift as installment-based, then closes by confirming Depp is fully current on all taxes.

Day 13 May 3, 2022

Direct Direct Examination of Michael Spindler Michael Spindler Wayne Dennison 44

Summary

Forensic accountant Spindler testified to $40.3M in Depp lost earnings: $20.25M net from the lost Pirates 6 role and ~$20M net from reduced non-franchise bookings post-op-ed.

Redirect Redirect Examination of Michael Spindler Michael Spindler Wayne Dennison 4

Summary

Two-question redirect in which Spindler defends his 2017 base year choice and earnings-comparison methodology; witness excused subject to recall.

Colloquy Motion to Strike Argued; Plaintiff Rests, Defense Begins 3

Summary

Plaintiff rests; defense moves to strike all three defamatory statements; judge denies as to statements 2 and 3 and takes statement 1 under advisement.

Direct Direct Examination of Dawn Hughes Dawn Hughes Elaine Bredehoft 88

Summary

Defense expert Dr. Dawn Hughes testified that Heard's reported abuse is consistent with intimate partner violence and that she suffers from PTSD attributed to Depp's conduct.

Day 14 May 4, 2022

Cross Cross-Examination of Dawn Hughes Dawn Hughes Wayne Dennison 482

Summary

Dennison challenged Hughes on gender bias, financial stake, and flawed PTSD testing methodology, then played an audio recording of Heard admitting to hitting Depp and starting physical fights.

Redirect Redirect Examination of Dawn Hughes Dawn Hughes Elaine Bredehoft 43

Summary

Bredehoft rehabilitates Hughes via additional audio clips showing Depp acknowledging mutual violence, while hearsay objections block full test document admission.

Day 19 May 19, 2022

Colloquy Preliminary Matters — Alpaca Photo, TikTok Incident, Rebuttal Ruling 4

Summary

Judge reprimands Chew for violating her photography order near the courthouse, discloses a TikTok balcony incident involving courthouse staff's children, and limits Bercovici to rebuttal.

Colloquy Sidebar: Bercovici Rebuttal-Expert Designation 3

Summary

Post-lunch sidebar in which Heard's team argued Bercovici should testify beyond rebutting Frost; Judge Azcarate upheld her prior ruling that he is a rebuttal expert only.

Direct Direct Examination of Ron Schnell Ron Schnell Adam Nadelhaft 3

Summary

Heard's counsel walks Ron Schnell through his computer science credentials and social media forensic expertise before tendering him as an expert; Depp's team requests voir dire.

Voir Dire Voir Dire Examination of Ron Schnell Ron Schnell Wayne Dennison 1 5

Summary

Dennison's opening voir dire question about Schnell's tweet analysis is cut off when the court sustains an objection limiting voir dire to qualifications only.

Highlights (1)

Quote

“you made no effort to connect those tweets and hashtags to the statements made by Adam Waldman?”

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Colloquy Expert Qualification — Social Media Forensic Analysis 6

Summary

At sidebar, Judge Azcarate clarified that voir dire is for expert qualification only; Dennison conceded no objection, and the court admitted Heard's social media expert in open court.

Direct Direct Examination of Ron Schnell Ron Schnell Adam Nadelhaft 7

Summary

Heard's expert Ron Schnell presents Twitter API analysis showing 2.38 million negative hashtag uses against Heard, with spikes correlating to Waldman's alleged defamatory statements.

Recross Recross Examination of Ron Schnell Ron Schnell Wayne Dennison 1 77

Summary

Dennison questioned Schnell about hashtags that predated Waldman's statements and whether the Twitter data showed causation rather than correlation.

Highlights (1)

Quote

“Wait a minute. Is the new standard "It's not that big of a stretch''?”

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Redirect Redirect Examination of Ron Schnell Ron Schnell Adam Nadelhaft 3

Summary

Nadelhaft's redirect reaffirms Schnell's core findings: all sampled "justice for Johnny Depp" tweets were negative toward Heard, 25%+ cited Waldman, and negative volume doubled after April 2020.

Day 20 May 23, 2022

Direct Direct Examination of David Spiegel David Spiegel Elaine Bredehoft 4

Summary

Bredehoft qualifies psychiatrist Dr. David Spiegel as Heard's expert in psychiatry, substance abuse, and IPV; Dennison objects and requests voir dire of his qualifications.

Voir Dire Voir Dire Examination of David Spiegel David Spiegel Wayne Dennison 28

Summary

Dennison challenges Spiegel's IPV credentials during voir dire, establishing no IPV-titled publications or CV entries; court admits him as expert over objection.

Direct Direct Examination of David Spiegel (Continued) David Spiegel Elaine Bredehoft 59

Summary

Bredehoft elicits Dr. Spiegel's opinions linking Depp's polysubstance abuse and narcissistic traits to intimate partner violence risk factors, over repeated Dennison objections.

Cross Cross Examination of David Spiegel David Spiegel Wayne Dennison 1 209

Summary

Dennison cross-examines Dr. Spiegel, attacking Goldwater Rule compliance, NPD traits-vs-diagnosis, MMSE methodology, and a deposition "idiot" comment about Depp.

Highlights (1)

Quote

“we have no idea, clinically, if they are high, wasted, stoned, stroke. We have no idea.”

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Redirect Redirect Examination of David Spiegel David Spiegel Elaine Bredehoft 36

Summary

Bredehoft rehabilitates Spiegel by distinguishing private records from the Goldwater Rule, walking through narcissistic-trait evidence, rebutting BPD diagnoses across multiple treating clinicians, and displaying Australia destruction and passed-out photos as IPV risk-factor evidence.

Direct Direct Examination of Kathryn Arnold Kathryn Arnold Elaine Bredehoft 34

Summary

Defense entertainment expert Kathryn Arnold testifies that Depp's career decline predated the op-ed and that the Waldman defamatory statements caused $45–50M in losses to Heard.

Cross Cross Examination of Kathryn Arnold Kathryn Arnold Wayne Dennison 1 325

Summary

Dennison questioned Arnold about the claimed link between Waldman's statements and Heard's career losses, her comparable actors, and the basis for her earnings estimate.

Highlights (1)

Quote

“correlation does not imply causation, does it, ma'am?”

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Redirect Redirect Examination of Kathryn Arnold Kathryn Arnold Elaine Bredehoft 18

Summary

Bredehoft rehabilitates Arnold's damages methodology, re-establishes the Waldman causal chain, and uses the Aquaman 2 script to show Heard's pre-statement film prospects.

Day 21 May 24, 2022

Direct Direct Examination of Michael Spindler Michael Spindler Wayne Dennison 41

Summary

Forensic accountant Spindler testifies Arnold's damages analysis for Heard is methodologically unsupported, and presents Heard's historical earnings as a factual baseline.

Cross Cross Examination of Michael Spindler Michael Spindler J. Benjamin Rottenborn 8

Summary

Rottenborn's brief cross confirms Spindler's opinion is limited to rebutting Arnold's calculations and elicits that he has no experience calculating actress defamation damages.

Day 22 May 25, 2022

Direct Direct Examination of Shannon Curry Shannon Curry Wayne Dennison 58

Summary

Dr. Curry rebuts Dr. Hughes's expert testimony, challenging her test battery as forensically inappropriate, identifying response distortion Hughes ignored, and concluding Heard has no PTSD.

Cross Cross-Examination of Shannon Curry Shannon Curry Elaine Bredehoft 14

Summary

Bredehoft attacks Curry's independence and credentials via deposition impeachment, establishing that none of Heard's treating providers ever diagnosed her with BPD or HPD.

Redirect Shannon Curry — Redirect Examination Shannon Curry Wayne Dennison 8

Summary

Dennison briefly redirects Curry on two cross topics: her rationale for not using the SCID, and her confirmation of compliance with APA Specialty Guidelines 1.02 and 1.03.

Day 23 May 26, 2022

Direct Direct Examination of Julian Ackert Julian Ackert Aidan Murphy 3

Summary

Heard's computer forensics expert rebutted Neumeister's EXIF metadata concerns, finding original iOS-metadata versions of flagged photos on Heard's actual devices.

Cross Cross Examination of Julian Ackert Julian Ackert Wayne Dennison 1 26

Summary

Dennison limits Ackert's authentication scope to Neumeister-flagged photos and presents two admitted exhibits with identical metadata but different visual appearance.

Highlights (1)

Quote

“They have the exact same file name, don't they, sir?”

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Direct Direct Examination of Dawn Hughes — Rebuttal Dawn Hughes Elaine Bredehoft 15

Summary

Dr. Dawn Hughes rebuts Shannon Curry's Day 22 criticisms, defending her multi-method forensic methodology, test interpretations, and PTSD conclusions regarding Amber Heard.

Cross Cross Examination of Dawn Hughes Dawn Hughes Wayne Dennison 75

Summary

Dennison cross-examines Hughes using test manuals to show she diagnosed PTSD before the CAPS-5 and deviated from PCL-5, CTS-2, and Danger Assessment instructions.

Redirect Redirect Examination of Dawn Hughes Dawn Hughes Elaine Bredehoft 7

Summary

Brief redirect rehabilitates Hughes on static risk factors, the 88-page notes, and clinical versus research scoring of the CAPS-5.

Evidence From Their Proceedings (47)

Documents Excluded

Bonnie Jacobs Therapy Notes (Heard, from October 2011)

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…

Wayne Dennison

About

Trial Record (38)

2022 Defamation Trial Apr 11, 2022 – Jun 1, 2022 38 proceedings

Day 9 April 26, 2022

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Day 11 April 28, 2022

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Day 13 May 3, 2022

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Day 14 May 4, 2022

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Day 19 May 19, 2022

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Day 20 May 23, 2022

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Day 21 May 24, 2022

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Day 22 May 25, 2022

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Day 23 May 26, 2022

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Evidence From Their Proceedings (47)

Bonnie Jacobs Therapy Notes (Heard, from October 2011)

CAPS-5 — Hughes Administration (Heard, Dec. 27, 2021)

Depp–Heard Multi-Segment Argument Recording (PX 343)

Heard's Aquaman Option Contract with Warner Bros.

TSI-2 — Hughes Administration (Heard)

Depp Ice Cream / Passed-Out Photo (Def. 1094)

Falati Nursing Notes for Amber Heard (Aug 2014–May 2016)

Hasta la muerte bowie knife gifted by Amber Heard

PAI — Hughes Administration (Heard)

Plaintiff's Ex. 144 — ER Photo, Depp's Severed Fingertip (Australia)

Schnell Social Media Hashtag Analysis / Dataset

Blaustein Session Notes — October 2014 through January 2015

Connell Cowan Treatment Records (Defendant's Ex. 1057)

May 21, 2016 Face Photos — DX-710/712/713/714 + Metadata

White Cover Letter to ACLU — $100K Pledge Installment

CAPS-5 — Curry Administration (Heard)

Danger Assessment Scale — Hughes Administration (Heard)

Hughes Expert Witness Training Presentation — National Clearinghouse

Hughes IPV Expert Witness Presentation — Kings County Bar Assoc.

MMPI-2 — Curry Administration (Heard)

PCL-5 — Hughes Administration (Heard)

Plaintiff's Ex. 145 — ER Photo, Cigarette Burn on Depp's Cheek (Australia)

Abusive Behaviors Observation Checklist — Hughes Administration (Heard)