Christian Carino — Direct/Cross
768 linesTHE COURT: All right. Your next witness.
MS. LECAROZ: Plaintiff calls Christian Carino, Your Honor.
THE COURT: Christian Carino.
MS. LECAROZ: And as with a number of IO the other depositions, this one will start with questions by Ms. Heard's counsel and at some point switch over to questioning by counsel for Mr. Depp.
THE COURT: All right. And how do you spell the last name just for me?
MS. LECAROZ: C-A-R-I-N-O.
THE COURT: Thank you.
MS. BREDEHOFT: Name and address for the record. Use your business address if you feel more comfortable.
CHRISTIAN CARINO: Sure. Christian Carino, and the work address is 2000 Avenue of Stars in Century City.
MS. BREDEHOFT: And that is in California?
CHRISTIAN CARINO: Correct.
MS. BREDEHOFT: And what is your current occupation?
CHRISTIAN CARINO: I'm a talent agent.
MS. BREDEHOFT: And could you give me just a very brief description of your educational background and IO work experience?
CHRISTIAN CARINO: Sure. I have a BA from the University of Massachusetts, and my work background is I've been a TA for approximately 16 years. And before that, I had a 12-year run with two different advertising agencies in New York.
MS. BREDEHOFT: And what are those advertising agencies in New York?
CHRISTIAN CARINO: Ogilvy & Mather and McCann Erickson.
MS. BREDEHOFT: Right. Now, you indicated that you were a talent agent.
MS. BREDEHOFT: Can you please describe what that means?
CHRISTIAN CARINO: I represent multiple clients and brands in transactions in the entertainment space.
MS. BREDEHOFT: And when you say "in the entertainment space," what are you including?
CHRISTIAN CARINO: Just the different genres of entertainment, everything from motion picture to television, to books to licensing to modeling, all of the different areas that the agency is - operates in.
MS. BREDEHOFT: As a talent agent representing multiple clients, what types of services do you perform for them? And what is the objective?
CHRISTIAN CARINO: Okay. Yep. I conduct business transactions on behalf of clients and brands in the entertainment space.
MS. BREDEHOFT: And what does that mean?
CHRISTIAN CARINO: It means - it means I organize, pitch, transact in contractual agreements between talent and studios, talent and brands, entertainment platforms and individuals, brands and individuals.
MS. BREDEHOFT: Do you represent any actors?
CHRISTIAN CARINO: I do work with every different group of talent within the agency, and for each person, it's different, the business that I personally oversee for them So in some cases I am negotiating contractual agreements for a music artist to go to Las Vegas. In some cases, I'm transacting an agreement for an artist to have a relationship with a brand. In some cases, it's • 18 a - an artist with a platform, like Netflix. It spans the general platform capabilities that the agency has overall.
MS. BREDEHOFT: Is one of the objectives of your representation to build the careers of the individuals you represent?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Did you have any conversations with Mr. Waldman in which you expressed any thoughts or opinions on how you believed any litigation was having an effect on Mr. Depp's reputation or career?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: How many times?
CHRISTIAN CARINO: One that I can recall.
MS. BREDEHOFT: And when was that?
CHRISTIAN CARINO: I have no idea. Years ago.
MS. BREDEHOFT: If you expressed to Mr. Waldman that the sooner the litigation was over, the better for Mr. Depp, what were you thinking when you said that? Why did you think that?
CHRISTIAN CARINO: I think anytime somebody is in litigation publicly, it is, at a minimum, a distraction to that person's career. And in a lot O of cases, it negatively impacts that person because there's attention drawn from that it is outside of what people want to know about that person.
MS. BREDEHOFT: And what do you mean by it distracts from the career?
CHRISTIAN CARINO: I mean that with somebody who is well known, people don't want to hear they're in a lawsuit with anybody about anything.
MS. BREDEHOFT: Why not?
CHRISTIAN CARINO: Because that's just not what they want to know or hear news about people.
MS. BREDEHOFT: And why do you believe that?
CHRISTIAN CARINO: Based on my experience in this world for the past 16 years.
MS. BREDEHOFT: And when you say "it negatively impacts," what do you mean by that?
CHRISTIAN CARINO: People don't want to hear that the people that they look up to are in litigation.
MS. BREDEHOFT: Do you also believe that that impacts career decisions by producers, directors, companies with brands, things of that nature?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And in what way?
CHRISTIAN CARINO: Because the general public doesn't want to hear that people that they look up to are in litigation. And when it - the more oxygen it takes up in the overall news or coverage of an individual and the less focused it is on that person's career, the less interested studios, brands, the general public, becomes in that person.
MS. BREDEHOFT: And, therefore, less opportunities?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: When you expressed to Adam Waldman I that -- your opinion that the sooner the litigation is over for Mr. Depp, the better, what did Mr. Waldman say?
CHRISTIAN CARINO: To be honest, I don't recall exactly what he said, but something to - something like .6 "We're gonna get this over with as fast as we can."
MS. BREDEHOFT: Mr. Carino, I'm going to ask you to take a look at what has been marked as Carino Exhibit Number -- exhibit labeled 4. Do you believe that the Mandel lawsuit posed a distraction to Mr. Depp's career?
CHRISTIAN CARINO: I don't know.
MS. BREDEHOFT: I'm going to show you what has been marked as Carino Deposition Exhibit Number 5. As you can see here, it's an article June 21st, 2017, by the Hollywood Gossip.
MS. BREDEHOFT: Do you recall that coming up during p9 that time frame, that issue?
MS. BREDEHOFT: Have you read or heard of the Rolling Stone?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Have you read or heard of GQ?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Mr. Carino, I'm going to ask you to take a look at what has been marked as Carino 1, Deposition Exhibit Number 2, and it's a Rolling Stone publication of June 21, 2018.
MS. BREDEHOFT: Do you see that?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Did you ever read this article?
CHRISTIAN CARINO: Parts of it.
MS. BREDEHOFT: Are you aware of whether this article in the Rolling Stone, June 2018, as reflected in Carino Exhibit Number 2, impacted in a negative way Mr. Depp's reputation or career?
CHRISTIAN CARINO: Elaine, I don't think it's possible to ask anybody that question without having done research among the people who read a specific article.
CHRISTIAN CARINO: If you're asking my opinion about whether an article like this, or this particular article, in my opinion, would have a positive or negative effect on somebody's, you know, career, I could potentially answer that.
CHRISTIAN CARINO: But as to definitively whether an article has or has not had an impact on somebody's career, nobody can answer that question without research specifically.
MS. BREDEHOFT: Mr. Carino, I think we were just going to start looking at the Carino exhibit Number 3. This is an article that was published in November of 2018.
MS. BREDEHOFT: Do you recall reading this at some point?
CHRISTIAN CARINO: What publication is that?
MS. BREDEHOFT: This is GQ.
CHRISTIAN CARINO: I probably read part of it, but I don't remember.
MS. BREDEHOFT: Have you had any direct contact with Ed White or his company?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And what is the nature of your contact with Ed White and his company?
CHRISTIAN CARINO: Payment on deals where Johnny was owed money, bill collecting.
MS. BREDEHOFT: When you say ''bill collecting,"was it collecting on your behalf? Or was it trying to collect from studios or companies?
CHRISTIAN CARINO: The latter.
MS. BREDEHOFT: And so what would your involvement be in those circumstances?
CHRISTIAN CARINO: Ed, on occasion, reached out to me to ask about the timing of a payment that was owed to Johnny.
MS. BREDEHOFT: All right. And were you able to answer those questions?
CHRISTIAN CARINO: I think in all cases, I just referred him to somebody who worked for me to find out what the payment schedule was.
MS. BREDEHOFT: Other than these occasions where Ed White would reach out to you to ask the timing of payment, did you have any other connections or communication with Ed White or his company in connection with Johnny Depp?
MS. BREDEHOFT: Were you familiar with Jake Bloom?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Do you know whether Mr. Bloom ever represented Mr. Depp? s 4
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And what was your understanding of the nature of that representation?
CHRISTIAN CARINO: He was his lawyer.
MS. BREDEHOFT: Did you ever talk to Jake Bloom?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: On how many occasions did you speak with Jake Bloom relating to Mr. Depp?
CHRISTIAN CARINO: I have no idea.
MS. BREDEHOFT: Was it pretty frequently?
CHRISTIAN CARINO: What does that mean?
MS. BREDEHOFT: Well, is it more than ten?
CHRISTIAN CARINO: Are you asking me if I had approximately ten conversations with Jake over the duration of our relationship?
MS. BREDEHOFT: Yes. I actually asked if you had more than ten. I wasn't asking you if it was exactly ten.
CHRISTIAN CARINO: Okay. I mean, I'm guessing that it was probably less than ten in total.
MS. BREDEHOFT: Was Mr. Bloom still representing Mr. Depp when you started representing Mr. Depp?
CHRISTIAN CARINO: I believe so, but I'm not sure.
MS. BREDEHOFT: And when did you start representing Mr. Depp?
CHRISTIAN CARINO: I believe it was in 20 - late 2016.
MS. BREDEHOFT: Mr. Carino, are you looking at something to be able to refresh your recollection?
CHRISTIAN CARINO: I am.
MS. BREDEHOFT: What do you have in front of you?
CHRISTIAN CARINO: Note that I made to myself of the date of when Johnny was a client. And I think I wrote down "October 2016."
MS. BREDEHOFT: Do you have a recollection of the context of your discussions with Mr. Bloom?
CHRISTIAN CARINO: Yes. My recollection of the conversations I had with Jake were in regard to getting Johnny and Jake to meet and work out whatever the issues were around their disagreement.
MS. BREDEHOFT: So you were trying to broker, if you will, a discussion between them to try to resolve their issues?
CHRISTIAN CARINO: Correct.
MS. BREDEHOFT: Were you successful in that?
CHRISTIAN CARINO: I don't remember whether they ever got together and met about it, to be honest.
MS. BREDEHOFT: Now, I'm going to show you what has been marked as deposition -- Carino Deposition Number 7, and this is the lawsuit that was filed IO on October 17, 2017. Were you aware of this litigation being filed by Mr. Depp, on his behalf, against Bloom Hergott Diemer, et cetera?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And were you involved in any way in this litigation?
MS. BREDEHOFT: Do you know one way or the other whether the filing of and the ongoing litigation associated with this lawsuit had any negative impact on Mr. Depp's reputation and career?
CHRISTIAN CARINO: I said no, Elaine.
MS. BREDEHOFT: Do you recall whether there was any publicity surrounding this litigation that's reflected in the complaint that's Carino Number 7?
CHRISTIAN CARINO: Are you asking me if I'm aware if the Jake Bloom litigation was made public?
MS. BREDEHOFT: Yes.
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And in addition to being made public, do you recall whether there was publicity surrounding the Jake Bloom litigation?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And do you recall whether there was publicity surrounding the Mandel litigation?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Mr. Carino, I'm going to ask you what has been marked as Deposition Exhibit Number 10, and this particular one, we have -- this is the article that was written in The Sun Times that is the beginning, if you will, of the U.K. lawsuit.
MS. BREDEHOFT: Do you have a recollection of seeing that?
MS. BREDEHOFT: Did you ever read it?
CHRISTIAN CARINO: I don't know. I'd have to - I don't know. I'm sure I've read at least part of it, if it's the original document that caused The Sun 1! legal issues.
MS. BREDEHOFT: Now, the date on this one is April 27, 2018.
MS. BREDEHOFT: Do you see that on there?
CHRISTIAN CARINO: Yep.
MS. BREDEHOFT: Mr. Carino, I'm going to ask you what has been marked as deposition -- Carino Deposition Exhibit Number 11, and it's dated June 13, 2018. You can see that little stamp there, but it was filed on June 13, 2018, and it's Mr. Depp filing The Newsgroup -- The Newspaper Limited, The Sun, and Dan Wootton. Were you aware that Mr. Depp brought this lawsuit in the U.K. between The Sun and Mr. Wootton?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Mr. Carino, I'm going to ask you to take a look at what has been marked now as Carino Exhibit Number 12. This is a -- this was published in the Washington Post on December 18, 2018.
MS. BREDEHOFT: Are you aware of this article?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: This op-ed? /6
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Mr. Carino, when I asked you if you ! s were aware one way or the other whether this lawsuit that's reflected in Exhibit Number 1 I had ! a negative impact on Mr. Depp's reputation and career, you answered no. What did you mean by that?
CHRISTIAN CARINO: I meant that there isn't a way for any individual to know whether the filing of a ,15 document had an impact on somebody's career, l positive or negative, without specific research conducted in exactly that case.
MS. BREDEHOFT: The same as in the facts, because you haven't researched it, you don't know whether it impacted Mr. Depp's reputation and career, correct?
CHRISTIAN CARINO: I believe I stated that unless someone had done research specifically about the filing of this document and its impact one way or the other, it's impossible to answer the question.
MS. BREDEHOFT: Let me show you what has been marked as Carino Number 14. This is the lawsuit that Mr. Depp filed against Ms. Heard.
MS. BREDEHOFT: Do you believe that the filing of this lawsuit reflected in Carino Deposition exhibit Number 14 and the attendant publicity has O had a negative impact on the reputation and career of Mr. Depp?
MS. BREDEHOFT: And why not?
CHRISTIAN CARINO: Because I've stated previously it's not about the filing of a lawsuit; it's about the coverage.
CHRISTIAN CARINO: I mean, you're asking me what my opinion is of what Johnny's reputation is today. Is that what you're asking?
MS. BREDEHOFT: Yeah.
CHRISTIAN CARINO: My opinion of what Johnny's reputation today is one of the finest actors of his generation.
MS. BREDEHOFT: Has -- in your opinion, has Mr. Depp's reputation changed at any point from October 2016 to the present?
CHRISTIAN CARINO: If you're asking me if what I define as his reputation has changed in terms of his being viewed as one of the best actors of his generation, I would say no.
MS. BREDEHOFT: Just so I'm clear that I understand your answer, in your opinion, Mr. Depp's reputation is that he is one of the finest actors of his generation, and that has been his reputation since you started representing him in October 2016, it still is today, and it hasn't changed during that time frame; is that correct?
CHRISTIAN CARINO: The view on his acting ability has not changed.
MS. BREDEHOFT: Well, I'm taking your definition of reputation. You said, "What they are known for."
MS. BREDEHOFT: So I'm taking that specific definition, and I'm asking is there anything other than that Mr. Depp is one of the finest actors of his I generation, that he is known for, that has changed between October 2016 and the present?
CHRISTIAN CARINO: The only way I can answer that is as it relates to his professional capabilities, that has not changed.
MS. BREDEHOFT: Is there something that has changed that doesn't relate to his professional capabilities?
CHRISTIAN CARINO: I don't know how to answer that, IO Elaine.
MS. BREDEHOFT: Q: Using your definition of reputation, which is "what a person is known for," is there any aspect of what Mr. Depp is known for that has changed between October 2016 and the present?
CHRISTIAN CARINO: It's - I've stated what I think his reputation is, and I've stated that in my opinion, his professional reputation as it relates to the quality of his acting abilities has remained unchanged.
MS. BREDEHOFT: Do you make any distinction between personal and professional reputation?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And what is that distinction?
CHRISTIAN CARINO: The difference between what somebody does on screen and off screen.
MS. BREDEHOFT: What is your opinion of what Mr. Depp was known for off screen when you started representing him in October of 2016?
CHRISTIAN CARINO: I think what he was known for off screen was a shroud of mystery of who he was because he was not visible to the public.
MS. BREDEHOFT: And that was back in October 2016?
CHRISTIAN CARINO: I don't have a specific date for that.
MS. BREDEHOFT: All right. But when you started representing him, that was your sense?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Okay. Did that change over time?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And in what way did it change?
CHRISTIAN CARINO: It changed with the exposure of - that came with the lawsuits.
MS. BREDEHOFT: And the lawsuits that we're talking about are the ones that we've ah"early taken a look at, Exhibit 4, 7, 8, 9, 11, and 15 -- no, I mean
CHRISTIAN CARINO: I'm not talking about any one or two specifically. In general.
MS. BREDEHOFT: Do you believe that Mr. Depp is still a shroud of mystery not visible to the public?
MS. BREDEHOFT: And when did that change?
CHRISTIAN CARINO: I don't know exactly when.
MS. BREDEHOFT: Would you say it was cumulative over the period of time as a result of all of the litigation and the publicity ensuing?
CHRISTIAN CARINO: Probably.
MS. BREDEHOFT: Is there any one specific litigation that you believe most significantly impacted on Mr. Depp's personal reputation no longer being a shroud of mystery, not visible to the public?
CHRISTIAN CARINO: My opinion is that Amber's accusations would have had the most dramatic impact on his off-screen reputation. I'm not talking about any one specific accusation.
MS. BREDEHOFT: When you say "Amber's accusations," what do you mean by that?
CHRISTIAN CARINO: I mean the things that she's accused Johnny of doing, both in - that have been made public.
MS. BREDEHOFT: Now, those accusations were made public in the divorce back in 2016, correct?
CHRISTIAN CARINO: I don't know exactly how or when they were made public.
MS. BREDEHOFT: Given that you believe Amber's accusations would have had the most dramatic impact on Mr. Depp's off-screen reputation, would Amber have been -- filing the divorce action and obtaining a domestic violence restraining order have had an impact on Mr. Depp's off-screen reputation?
CHRISTIAN CARINO: I think the only way I can answer that is by saying I don't think filing for divorce would have any impact whatsoever. And I'm actually not familiar with the lawsuit to get the restraining order, so I don't know exactly what's in there. But if that was based on claims of - or accusations of abuse, then that, in my opinion, would have a negative impact on Johnny's off-screen reputation.
MS. BREDEHOFT: Mr. Carino, we were talking about Amber's accusations and your view that those would have the most dramatic impact on Mr. Depp's off-screen reputation. And we were talking about her accusations of domestic abuse and violence, 1; correct?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Were you aware that the Dan Wootton article published in The Sun included specific ! 11 accusations by Amber Heard of domestic violence and abuse by Mr. Depp?
CHRISTIAN CARINO: The Sun case, is that what you're asking about?
MS. BREDEHOFT: Well, first, the article itself that was in the paper, the "Why is JK Rowling genuinely happy about employing Mr. Depp, the wife beater?"
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And you're aware that the litigation, the lawsuit including the particulars of the claim brought by Mr. Depp included the accusations by Amber Heard of domestic violence and abuse by Mr. Depp, correct?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Given that the Mandel lawsuit moved forward, accusations by Amber Heard of domestic Is violence by Mr. Depp against her, are you able to say how much of Mr. Depp's off-screen reputation was impacted by the Mandel lawsuit?
MS. BREDEHOFT: Now, you were aware that the op-ed by Dan Wootton in The Sun included accusations by Amber of domestic violence against Mr. Depp, correct?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Are you aware one way or the other how much Mr. Depp's off-screen reputation was impacted by the complaint that was filed in this case that contained Amber Heard's accusations of domestic violence and abuse by Mr. Depp?
MS. BREDEHOFT: Are you aware of how much Mr. Depp's off-screen reputation was impacted as a result of the op-ed in the Washington Post from Amber Heard?
MS. BREDEHOFT: Are you aware of how much Mr. Depp's off-screen reputation was impacted by the accusations included in the Waldman tweet on May 2020 of the op-ed?
MS. BREDEHOFT: Are you aware of any role or opportunity that Mr. Depp lost as a result of the op-ed by Dan Wootton in The Sun?
MS. BREDEHOFT: Are you aware of any role or -- and when I said "opportunity," I'm talking business opportunity -- that Mr. Depp lost as a result of the particulars claims that Mr. Depp filed?
MS. BREDEHOFT: Are you aware of any roles or business opportunities that Mr. Depp lost as a result of the op-ed by Amber Heard in the Washington Post?
MS. BREDEHOFT: Are you aware of any roles or business opportunities that Mr. Depp lost as a result of the Waldman tweet from late 2020 relating to Amber's op-ed?
MS. BREDEHOFT: Is there any other role or business opportunity that Mr. Depp has lost since you started representing him in October 2016? And I'm saying --
CHRISTIAN CARINO: I would say his - I would say yes.
MS. BREDEHOFT: And what?
CHRISTIAN CARINO: The Pirates, the next Pirates movie.
MS. BREDEHOFT: Do you remember which one that was?
CHRISTIAN CARINO: Six, seven, I'm not sure what the number is.
MS. BREDEHOFT: It's 6. I think Pirates 6 is the one that's yet to come out.
MS. BREDEHOFT: And why -- what is your understanding of why Mr. Depp lost Pirates 6?
CHRISTIAN CARINO: My opinion is that it was related to the accusations that Amber has made.
MS. BREDEHOFT: And what is your opinion based on?
CHRISTIAN CARINO: Excuse me?
MS. BREDEHOFT: What is your opinion based on?
CHRISTIAN CARINO: Conversations with colleagues and I studio execs.
MS. BREDEHOFT: I'm sorry. I didn't quite hear you.
CHRISTIAN CARINO: Conversations with studios and other executives, both internal and external. When you say "related to the accusations that were made by Amber Heard against Mr. Depp," are you talking about accusations of domestic violence and abuse by Mr. Depp?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: How many conversations have you had with studios and other executives?
CHRISTIAN CARINO: I have no idea.
MS. BREDEHOFT: More than five? More than ten?
CHRISTIAN CARINO: I don't know about more than ten. Probably between five and ten.
MS. BREDEHOFT: Who do you recall speaking with at studios or other executives?
CHRISTIAN CARINO: Jerry Bruckheimer. I think mostly Jerry and then colleagues at CAA.
MS. BREDEHOFT: When did you first have any conversations with Jerry Bruckheimer about Pirates 6 and Mr. Depp?
CHRISTIAN CARINO: I have no idea.
MS. BREDEHOFT: Do you recall whether it was in 2016, 2017, 2018, 2019?
CHRISTIAN CARINO: I don't.
MS. BREDEHOFT: When did you have any conversations with colleagues at CAA?
CHRISTIAN CARINO: It would have been whenever the decisions were being made about how to cast that movie. I don't - honestly, I don't know what year that was.
MS. BREDEHOFT: Do you recall who you spoke with at CAA?
CHRISTIAN CARINO: I spoke with Jack Whigham. I spoke with Brian Lourd.
MS. BREDEHOFT: What do you recall Jerry Bruckheimer telling you?
CHRISTIAN CARINO: I don't recall the specific conversations, but the nature of it was that the studio was having difficulty employing him.
MS. BREDEHOFT: And did Mr. Bruckheimer tell you why the studio was having difficulty employing Mr. Depp?
CHRISTIAN CARINO: No. Not specifically, but it was understood.
MS. BREDEHOFT: Did you ask?
CHRISTIAN CARINO: I didn't need to.
MS. BREDEHOFT: Why did you think you didn't need to?
CHRISTIAN CARINO: Because everyone was aware of what was garnering the attention of the studios in determining whether or not he could be employed.
MS. BREDEHOFT: When you say "everyone was aware," how IO do you know that?
CHRISTIAN CARINO: I don't know. I just knew.
MS. BREDEHOFT: Can you tell me who "everyone" is? Can you tell me who anyone is?
CHRISTIAN CARINO: The people who would have been involved in making that decision.
MS. BREDEHOFT: Well, if I'm understanding you correctly, and please correct me if I'm wrong, the only person at Disney that you spoke with about Pirates and employing Mr. Depp was Jerry Bruckheimer, correct?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And you spoke between five and ten And you spoke between five and ten times with Mr. Bruckheimer, and he did not say in any of those conversations, "The reason we're not employing Mr. Depp is because of Amber Heard's accusations of domestic violence and abuse by Mr. Depp," correct?
CHRISTIAN CARINO: That's correct.
MS. BREDEHOFT: Mr. Carino, when we went off for the break, we were talking about your discussions with Jerry Bruckheimer and other executives at CAA, IO respecting Mr. Depp not being employed further at Disney and likely not being in Pirates. And I think a question came up right before the break, so I just want to make sure that I have clear did you talk with anyone, other than Jerry Bruckheimer at Disney, about Mr. Depp not being employed again at Disney or Pirates?
MS. BREDEHOFT: Okay. And was I correct in understanding you had somewhere between five and ten conversations with Mr. Bruckheimer relating to this topic?
CHRISTIAN CARINO: Probably less than that. I talk to Jerry regularly, but probably not that many on this topic.
MS. BREDEHOFT: Okay. And was there anyone else at Disney that you spoke with at any point about Johnny Depp being considered for Pirates or not being employable by Disney?
MS. BREDEHOFT: And is that true to the present?
MS. BREDEHOFT: Okay. And whatever discussions that
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: You've had, those were all with executives at CAA?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: And that was Brian Lourd and Jack Whigham, correct?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Anyone else?
MS. BREDEHOFT: Not that I can recall, no. Okay. Do you -- you had indicated that you believe that everybody -- everyone was aware that the impact of Amber's allegations were at the heart of this. I just want to make sure that we're clear, since we were talking about this, we're clear, since we were talking about this, I before the break. Jerry Bruckheimer did not say specifically what it was that caused Disney to decide not to continue with Johnny Depp in Pirates 6 or in other matters, correct?
CHRISTIAN CARINO: Correct.
MS. BREDEHOFT: Well, and I'm trying to reach that it s was understood. I'm trying to discover any facts that would have led you to believe it was understood. And if I'm understanding, I'll use the same word, Mr. Bruckheimer didn't tell you that, correct?
CHRISTIAN CARINO: Again, it was understood. So I don't recall whether either of us ever said anything specific about why, but it is something within the industry that is understood.
MS. BREDEHOFT: Can you tell me whether any other actors did not receive roles or were unemployable because of the #MeToo movement allegations? Other than Mr. Depp, I'm asking.
CHRISTIAN CARINO: Not that I work with directly, no.
MS. BREDEHOFT: In any of your discussions with Mr. Bruckheimer, did you ask him what Mr. Depp could do to become employable by Disney again or to get any part of any Pirates franchise going forward?
MS. BREDEHOFT: Why not?
CHRISTIAN CARINO: Because there - in cases like this, there is nothing anybody can do. It is the directive of the studio, and they have the sole right to make the judgment whether they can continue to employ somebody or not.
MS. BREDEHOFT: And your understanding from your discussions with Mr. Bruckheimer is that Disney had made the judgment to decide that they could no longer employ Mr. Depp; is that correct?
CHRISTIAN CARINO: Yes. But not solely based on conversations with Mr. Bruckheimer. It was cumulative with the internal and external conversations.
MS. BREDEHOFT: What did Mr. Lourd say that led you to believe that, that Disney had made a decision, the judgment that they were not going to employ j g y g g p y Mr. Depp at Disney?
CHRISTIAN CARINO: Just that a decision had been made.
MS. BREDEHOFT: What did Mr. Whigham say about --
CHRISTIAN CARINO: The same.
MS. BREDEHOFT: Making the judgment of whether they would not be able to employ Mr. Depp further?
CHRISTIAN CARINO: Same thing.
MS. BREDEHOFT: Okay. Just that they had made the decision?
CHRISTIAN CARINO: Correct.
MS. BREDEHOFT: Were you aware of any problems on the set with Mr. Depp during the filming of Pirates 5?
MS. BREDEHOFT: Are you aware of Mr. Depp engaging in alcohol, drug use, being tardy, any of those issues during the filming of Pirates 5?
CHRISTIAN CARINO: I'm aware of him being tardy, but he's been tardy on everything his entire life.
MS. BREDEHOFT: Were you aware of whether that was troublesome to Disney during the filming of Pirates 5?
CHRISTIAN CARINO: I think it's troublesome to everybody, but everyone has learned how to produce a film to I deal with it.
MS. BREDEHOFT: Working around Mr. Depp?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Do you know whether there was anyone on the set of Pirates 5 who wasn't willing to deal with it and was quite irritated?
MS. BREDEHOFT: Were you aware that the filming had to be shut down for a period of time after Mr. Depp injured his finger?
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: Were you aware of any disagreements between Mr. Depp and Disney, including Mr. Bailey and others who were on the project, about artistic differences? In other words, when Mr. Depp thought something should be this way or something should be that way, and they didn't agree.
CHRISTIAN CARINO: Yes.
MS. BREDEHOFT: What is your understanding of that?
CHRISTIAN CARINO: There was a difference of opinion on how the film was edited.
MS. BREDEHOFT: And what is your understanding of what y g I Mr. Depp thought it should be edited to?
CHRISTIAN CARINO: I don't know how to describe the difference between the Disney edit and Johnny's preferred edit. I think Johnny told me about it, I talked about it a little bit.
MS. BREDEHOFT: Do you know how well Pirates 5 did at the box office?
CHRISTIAN CARINO: Not exactly.
MS. BREDEHOFT: Do you know whether it was more , successful or less successful than earlier Pirates franchise films?
CHRISTIAN CARINO: I think it was slightly less than - it wasn't the most successful installment of that franchise.
MS. BREDEHOFT: Do you know whether Mr. Depp has a pay or play clause that would pay him even if he was not in the subsequent Pirates 6?
MS. BREDEHOFT: Yes.
CHRISTIAN CARINO: I don't think he does.
MS. BREDEHOFT: Have you or anyone at CAA on behalf of Mr. Depp made any efforts with Disney to find any roles for Mr. Depp since he filmed Pirates 5?
CHRISTIAN CARINO: My efforts were probably primarily around Houdini which, at one point, was a film, but other people at CAA for sure did, yes.
MS. BREDEHOFT: And who were they?
CHRISTIAN CARINO: I would start with Jack Whigham.
MS. LECAROZ: We'll now play volume 2 of Mr. Carina's deposition at which --
THE COURT: Okay. It may be time for our afternoon --
MS. LECAROZ: Sure.
THE COURT: At least close enough to it.
MS. LECAROZ: Absolutely, Your Honor.
THE COURT: All right. Before we get to volume 2, let's go ahead and take a 15-minute break. Please do not talk to anyone about the case, and don't do any outside research. Thank you.
THE COURT: All right. Then we'll come back at 3: 3 0 then, okay? Thank you.
MS. LECAROZ: Thank you, Your Honor.
COURT BAILIFF: All rise. Please be seated and come to order.
THE COURT: Ready for the jury?
MS. BREDEHOFT: One moment, please.
THE COURT: Okay. Sure.
MS. BREDEHOFT: I made a mistake in Dougherty. I did have one exhibit that I wanted to admit.
THE COURT: Okay. Which objection?
MS. LECAROZ: I'm not sure actually, Your Honor. She just handed this to us.
THE COURT: All right. You can look at it. It's Exhibit 1639 for defendant's.
MS. LECAROZ: I need the text. I don't know that we're going to get to Dougherty today.
THE COURT: But if you want to take a look at it though, that's fine.
MS. VASQUEZ: I think Mr. White's going to testify in person.
THE COURT: Okay.
MS. VASQUEZ: So I think that to the extent--
MS. BREDEHOFT: This is a business record.
MS. VASQUEZ: Of Mr. White.
MS. BREDEHOFT: And they did tell you -- he sent this to you and Mr. Dougherty testified to it as an exhibit in there, I just missed it when I was flipping through.
MS. VASQUEZ: No. We're going to maintain our objections: Unfair prejudice, hearsay, lack of authentication. This is a communication from Mr. White, who is Mr. Depp's business manager, to the ACLU.
THE COURT: Okay.
MS. VASQUEZ: And like I just said, Mr. White will be testifying in person.
THE COURT: Live.
MS. BREDEHOFT: Still a business records exception, Your Honor.
THE COURT: I'm going to sustain the objection.
MS. BREDEHOFT: So we should just do it tomorrow with Mr. White?
THE COURT: Yeah. I'll keep it open because that sounds like we're not to going have • 12 any problems getting to the witness.
MS. VASQUEZ: Thank you, Your Honor.
THE COURT: Okay. Let's get the jury. I 17
MS. LECAROZ: Yes, thank you, Your Honor. We'll now play volume 2 of Mr. Carino's deposition which is the questioning from counsel for Mr. Depp.
THE COURT: Okay. Thank you
MS. LECAROZ: CHRISTIAN CARINO, Being first duly sworn, was examined and testified as follows:
MR. PRESIADO: Dispute between Johnny Depp and Amber Heard, correct?
CHRISTIAN CARINO: Correct
MR. PRESIADO: And you know both of those individuals, correct?
CHRISTIAN CARINO: Correct
MR. PRESIADO: Who did you meet first?
CHRISTIAN CARINO: Amber.
MR. PRESIADO: When did you meet her?
CHRISTIAN CARINO: I don't know exactly when, but probably within those first few years of being at CAA.
MR. PRESIADO: Okay. So can we, as an estimate, say 2005, 2006 time frame?
CHRISTIAN CARINO: Sure. I don't exactly know, but sure.
MR. PRESIADO: But it was pretty early on in your career at CAA?
CHRISTIAN CARINO: Correct
MR. PRESIADO: And describe for me the events of your meeting her.
CHRISTIAN CARINO: She was represented theatrically at the time by an agent named Warren Zavala, who has since left CAA, and he brought her down to my office because he wanted me to represent her with him specifically in the commercial space.
MR. PRESIADO: And what do you mean by "represent her in the commercial space"?
CHRISTIAN CARINO: Help identify business opportunities for her with brands.
MR. PRESIADO: So not as an actor?
CHRISTIAN CARINO: Correct.
MR. PRESIADO: And did you take on that representation?
CHRISTIAN CARINO: I did.
MR. PRESIADO: And at some point in time, you did consider her a friend in addition to you two working together; is that right?
MR. PRESIADO: AQ Yes. And in that regard, did you and her do anything social?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And can you describe for me generally what types of activities you two would do together as friends?
CHRISTIAN CARINO: We will go to dinner, go to events together, hang out at each other's residences.
MR. PRESIADO: And at some point in time, did you consider Mr. Depp a friend?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And how did that relationship evolve? And I'm just talking about you and Mr. Depp becoming friends.
CHRISTIAN CARINO: I spent a fair amount of time with both of them together and at some point started to spend time with him on my own as well.
MR. PRESIADO: I see. And at some point in time, did I become as good a friend to you as
CHRISTIAN CARINO: Yeah.
MR. PRESIADO: Let me re-ask that also.
MR. PRESIADO: Did you consider -- at some point in time, did you consider Mr. Depp a friend to the , same degree that you considered Ms. Heard a ' Is friend?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And at some point -- Jet me ask you, at I some point in time, did you represent Mr. Depp professionally?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And can you explain to me how it came to you representing Mr. Depp professionally?
CHRISTIAN CARINO: Johnny asked me to represent him.
MR. PRESIADO: And when you began representing Mr. Depp, did you continue representing Ms. Heard?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And do you recall who Mr. Depp's agent was prior to you?
CHRISTIAN CARINO: He was represented at another talent agency, UTA.
MR. PRESIADO: Do you still work for Mr. Depp?
CHRISTIAN CARINO: I do not
MR. PRESIADO: Do you recall when you stopped working for Mr. Depp?
CHRISTIAN CARINO: Within the past two years.
MR. PRESIADO: And can you describe the circumstances of you no longer working for Mr. Depp?
CHRISTIAN CARINO: He left CAA to follow an agent who left CAA to become part of a founding group in a new management company.
MR. PRESIADO: And who is that person?
CHRISTIAN CARINO: Jack Whigham
MR. PRESIADO: Was Mr. Whigham ever affiliated with CAA?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And you say that when Jack Whigham departed CAA, Johnny went with him?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And when Mr. Depp left CAA, did you remain -- did you remain friends with him?
MR. PRESIADO: Okay. I should probably first ask, at some point in time, did your friendship with Mr. Depp end?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And when was that?
CHRISTIAN CARINO: I would say at the time that he left CAA.
MR. PRESIADO: And did him leaving CAA have something to do with the end of the friendship?
CHRISTIAN CARINO: I don't know.
MR. PRESIADO: Are you still friends with Ms. Heard?
MR. PRESIADO: And when did that friendship end?
CHRISTIAN CARINO: Probably when the legal disputes started.
MR. PRESIADO: And what legal dispute are you referring to? This one?
CHRISTIAN CARINO: I'm not sure which one was first, but one of the disputes between Johnny and Amber.
MR. PRESIADO: Okay. But your friendship with -- you're not referring to their divorce, correct?
CHRISTIAN CARINO: Correct.
MR. PRESIADO: Okay. So you remained friends with both of them through their divorce; is that accurate?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Although you're no longer friends with Mr. Depp, do you have any animosity towards him?
CHRISTIAN CARINO: I do not.
MR. PRESIADO: And same question with respect to Ms. Heard, although you're not friends with her , IO any longer, do you have any animosity towards her? /11
CHRISTIAN CARINO: I do not.
MR. PRESIADO: Do you recall when it is the last time you spoke with Ms. Heard?
CHRISTIAN CARINO: I do not.
MR. PRESIADO: Would it have been around the same time that your friendship ended with her?
CHRISTIAN CARINO: I would assume so.
CHRISTIAN CARINO: AV TECHNICIAN: Exhibit 16.
MR. PRESIADO: Mr. Carino, you'll see at the bottom here, I don't know if you can see it. Do you see at the bottom, it has a Bates stamp number under the yellow tag, CC00070?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Do you recognize this document? Take I your time if you need to review it.
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Okay. And do you understand this to be a true and authentic copy of an email exchange in which you were involved?
CHRISTIAN CARINO: I believe so.
MR. PRESIADO: Okay. And you'll see it's dated January 11th, 2018, and the subject is "WME."
MR. PRESIADO: Do you know what -- what is your understanding of what WME is?
CHRISTIAN CARINO: William Morris Endeavor.
MR. PRESIADO: And what is that?
CHRISTIAN CARINO: It's another talent agency.
MR. PRESIADO: Okay. And you've read this email from Ms. Heard to you, correct?
CHRISTIAN CARINO: Correct.
MR. PRESIADO: So at this point in time, was she a close friend of yours?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And ultimately, did she leave CAA?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And it was at this time?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: During the entire time you represented Ms. Heard, did Mr. Depp ever interfere with your representation of Ms. Heard?
MR. PRESIADO: Did he ever ask you to do anything with respect to her career?
CHRISTIAN CARINO: Not that I can recall.
CHRISTIAN CARINO: AV TECHNICIAN: exhibit 17.
MR. PRESIADO: Now, Mr. Carino, this particular document was not produced by you. You will see that at the bottom here, the Bates stamp indicates ALH; that means it was produced by Ms. Heard. And this appears to be a text exchange between you and her. It's about a page and a half.
MR. PRESIADO: If you could take the time to read it, and then I will ask you questions about it.
CHRISTIAN CARINO: I read it.
MR. PRESIADO: You'll see at the top, Mr. Carino, it's dated July 14th, 2016. Based on that date and based on reading this text exchange, at this point in time, were you close friends with both Mr. Depp and Ms. Heard?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And having read the text exchange, do you believe this to be a true and correct representation of the exchange?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And to be authentic in that regard?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Now, you started the text exchange by indicating "JD just surfaced." What does the "JD" reference?
CHRISTIAN CARINO: Johnny Depp.
MR. PRESIADO: And she said, "I saw Laurel yesterday." Who is Laurel?
CHRISTIAN CARINO: Laurel's a therapist.
MR. PRESIADO: Do you know her full name?
CHRISTIAN CARINO: Laurel Anderson.
MR. PRESIADO: Did you independently know Laurel?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Did you have anything to do with Laurel seeing either Ms. Heard or Mr. Depp?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And can you explain that to me, please?
CHRISTIAN CARINO: I introduced them all.
MR. PRESIADO: What was the purpose of you introducing her to them?
CHRISTIAN CARINO: They needed help.
MR. PRESIADO: And can you explain to me in more detail what you mean by that?
CHRISTIAN CARINO: I think it was at a time when they needed somebody to help mediate the difficulties they were having.
MR. PRESIADO: And what do you mean by "difficulties"?
CHRISTIAN CARINO: The strains on their relationship.
MR. PRESIADO: And in that regard, did you have conversations with Ms. Heard about the state of her relationship with Mr. Depp?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: I'm trying to determine for how long a period of time did Ms. Heard have conversations with you about the state of her relationship with J Mr. Depp. Can you give me a time frame?
CHRISTIAN CARINO: I would say she talked to me about the state of their relationship from the beginning until the end.
MR. PRESIADO: The entire time you knew her? I'm sorry. The entire time you considered her a friend?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And how about Mr. Depp? Would you -- how would you -- did you have conversations with him about the state of his relationship with Ms. Heard?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And were those ongoing during the entire time you were friends with him?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Would you say they both confided in you in that regard?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: So back to this text exchange, where my cursor is, Ms. Heard said to you, "Yeah. She said that Johnny and I need to talk directly." Do you know who she is -- do you know who Ms. Heard is referring to there?
CHRISTIAN CARINO: Laurel.
MR. PRESIADO: That is your understanding after reading this?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And then you asked her, "Do you want to do something tomorrow?"
MR. PRESIADO: And she says, "Yeah." She says, "IDP, I do. Please say, ah, okay."
MR. PRESIADO: And then you say, "What is safe to do? Do you want to come to my place for dinner?"
MR. PRESIADO: What did you mean by "What is safe to do?"
CHRISTIAN CARINO: It meant avoiding paparazzi.
MR. PRESIADO: Okay. And then she says, "It's so fucked up. I just want to tell him that what they are telling him isn't true."
MR. PRESIADO: What was your understanding what she meant by that sentence?
CHRISTIAN CARINO: I don't recall.
MR. PRESIADO: Mr. Carino, while she's doing that, at the outset of this deposition, I asked you if you recalled being deposed about a year ago in this case, and you said yes.
MR. PRESIADO: Is that accurate?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Okay. What I'm going to show you now is the transcript -- a portion of the transcript from that deposition.
MR. PRESIADO: And who is Mr. Bruckheimer?
CHRISTIAN CARINO: Jerry Bruckheimer is the producer of the Pirates franchise.
MR. PRESIADO: And who is Mr. Whigham?
CHRISTIAN CARINO: Jack Whigham was an agent at CAA who worked with Johnny.
MR. PRESIADO: Okay. And who is Mr. Lourd?
CHRISTIAN CARINO: Brian is one of the managing partners of CAA and also worked on Johnny Depp.
MR. PRESIADO: And what was your understanding of why the Pirates 6 job was not offered to Mr. Depp?
CHRISTIAN CARINO: You're asking my opinion?
MR. PRESIADO: Yes.
CHRISTIAN CARINO: Because of the accusations that Amber p made.
MR. PRESIADO: And what I'm about to show you, Mr. Carino, is an article in the Washington Post authored by Ms. Heard. You're going to notice that the article will be presented sideways, so you'll have to tilt your head a bit to review it.
MR. PRESIADO: AV TECHNICIAN: Exhibit 19. First, Mr. Carino, why don't you take control and just scroll through the document. It's just a couple pages.
CHRISTIAN CARINO: Is this the top of the next page?
MR. PRESIADO: Yeah. When there's a jump like that, it's just the top of the next page.
CHRISTIAN CARINO: Okay.
MR. PRESIADO: Mr. Carino, have you seen this document before?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Do you know who wrote this document?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Who wrote this document?
CHRISTIAN CARINO: Amber.
MR. PRESIADO: Amber Heard?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And do you see there on the first page of the document, it actually indicates that it's written by Amber Heard on December 18th, 2018?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And you understand that this document was authored by Ms. Heard and published on December 18th, 2018?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And do you recall reading it at the J 11 time it was published?
MR. PRESIADO: Mr. Carino, I'm showing you an email exchange in which you were involved. It's just this one page. I'll blow it up so you can review it.
MR. PRESIADO: Take a second to review it, please.
CHRISTIAN CARINO: Okay.
MR. PRESIADO: And let's start at the bottom of this -- well, do you see at the top that the email re line is entitled Johnny Depp's Jack Sparrow won't return in the new Pirates of the Caribbean movie?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And this email exchange was on December 20th, 2018, correct?
CHRISTIAN CARINO: Correct.
MR. PRESIADO: And do you recall that the article you just read published by Ms. Heard was published on December 18th, 2018, two days before this?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Now, if you go to the bottom of this email, do you see there's this link to an article?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And it says URL defense -- I'm sorry. It says movieweb.com.
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Mr. Carino, what I put up next to the email exchange that we've been discussing is an article that is dated December 20th, 2018.
CHRISTIAN CARINO: Okay.
MR. PRESIADO: So this article is dated December 20th, 2018, and the email sent to you by Robin Braun is that same day, December 20th, 2018, correct?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Who is Ms. Braun?
CHRISTIAN CARINO: Johnny's publicist.
MR. PRESIADO: And she's sending this article to you; is that right?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And then in response you say, "Were we told this officially from Disney?"
MR. PRESIADO: And she responds -- I'm sorry -- Jack Whigham responds, "No."
MR. PRESIADO: Is that accurate?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Sure. So you testified just a few minutes ago that it was your opinion that Mr. Depp lost the Pirates 6 movie because of Ms. Heard's allegations; is that accurate?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Allegations of abuse, correct?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And is this a demonstration of when Disney made that decision to not hire Mr. Depp for Pirates 6?
CHRISTIAN CARINO: Yes.
CHRISTIAN CARINO: AV TECHNICIAN: Exhibit 22.
MR. PRESIADO: Did you ever see Mr. Depp physically abuse Ms. Heard?
MR. PRESIADO: Did Ms. Heard ever tell you that she had been physically abused by Mr. Depp?
MR. PRESIADO: Did Mr. Depp ever tell you that he had physically abused Ms. Heard?
MR. PRESIADO: Did you ever witness any injuries on Ms. Heard that would indicate that she was physically abused?
MR. PRESIADO: Now, again, this is a few months after the filing of the divorce papers and the TRO. And Ms. Heard states to you, "I'll call you right back. Sorry."
MR. PRESIADO: And you say, "K."
MR. PRESIADO: She says, "Is it too late to call?"
MR. PRESIADO: And you say Just finishing dinner. Will call you as soon as we walk out, within 20.
MR. PRESIADO: And she says, "Please tell him I love him."
MR. PRESIADO: Is that an accurate reading of the text is exchange so far?
CHRISTIAN CARINO: Yes. I 1
MR. PRESIADO: Do you know if at this time, based on s your relationship with Ms. Heard and Mr. Depp, whether Ms. Heard wanted to reconcile with po Mr. Depp?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: It's your understanding that she did?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Did Ms. Heard, based on your personal friendship with Ms. Heard, close personal friendship with Ms. Heard, would you say that she confided in you?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And what about Mr. Depp?
MR. PRESIADO: Mr. Carino, at some point in time after
CHRISTIAN CARINO: Yes Ms Heard filed those divorce papers in May of 2016 did she make any request of you to intervene in the relationship between her and Mr Depp?
CHRISTIAN CARINO: What do you mean by "intervene"?
MR. PRESIADO: Let's start with assist in communications between the two of them.
MR. PRESIADO: Yes. Can you explain to me what transpired in that regard, walk me through?
CHRISTIAN CARINO: At some point around that time, she wanted me to arrange for them to get together in person.
MR. PRESIADO: And what did you do after that was requested of you by Ms. Heard?
CHRISTIAN CARINO: I talked to Johnny about it.
MR. PRESIADO: What happened after that?
CHRISTIAN CARINO: He was reluctant at first and then agreed.
MR. PRESIADO: And then what happened after that?
CHRISTIAN CARINO: I mean, this is a long time ago. But I remember there was a fair amount of discussion about the TRO and how we would deal with that because nobody wanted Johnny accused of violating TRO as an outcome of that meeting. And I don't remember exactly what we did, but Amber, at some point, warranted that she would never accuse him of violating the TRO to do the meeting. And I set the meeting up.
MR. PRESIADO: So just so I understand, you set the meeting up at the request of Ms. Heard?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And as part of you setting it up, she told you that it didn't matter? What I'm trying to understand is what was the issue with respect to the TRO?
CHRISTIAN CARINO: My understanding of a restraining order, at least at the time, was that he couldn't go within a certain distance of her.
MR. PRESIADO: Okay. And what was her suggestion with respect to that issue in connection with her wanting to meet with him?
CHRISTIAN CARINO: She promised me and told me to relay to him that she would never accuse him of violating the restraining order as a result of agreeing to meet her. And I believe, but I don't recall I exactly, there were conversations with both sides, legally, I believe at the time, that make it transparent to everybody that this was happening.
MR. PRESIADO: Okay. And then what happened next?
CHRISTIAN CARINO: I arranged the meeting. Johnny was in San Francisco on tour, and I arranged to borrow a friend's house. And Amber and I flew to San Francisco and drove to the house, and Johnny showed up a few hours later.
MR. PRESIADO: And did the two of them meet? /11
CHRISTIAN CARINO: Yes.
MR. PRESIADO: In the same room?
CHRISTIAN CARINO: They sat outside.
MR. PRESIADO: Okay. How close to each other were they?
CHRISTIAN CARINO: Inches away from each other.
MR. PRESIADO: And how long were they out there talking? For how long were they out there talking?
CHRISTIAN CARINO: Several hours.
MR. PRESIADO: Did you -- although you weren't out there, did you seat yourself in a position where you could see them through a window or otherwise?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: At some point in time, the conversation ended, correct?
CHRISTIAN CARINO: Correct
MR. PRESIADO: And what happened after that?
CHRISTIAN CARINO: I received a call or a text from Steve, ! whose house it was, and he notified me that he would be coming back to the house within the next hour or so. And I told Johnny and Amber, and we decided to rent the hotel room in San Francisco so that they could continue to talk.
MR. PRESIADO: And did that in fact happen?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And at some point in time, you left that house, correct, to go to San Francisco?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And was it the three of you?
CHRISTIAN CARINO: No. Johnny had security with him, and we talked about the fact that they - it wouldn't be a good idea for them to be seen together there. So Johnny left with his security in his car, and I believe Amber and I took an Uber.
MR. PRESIADO: And what happened after that?
CHRISTIAN CARINO: We all met at the hotel room.
MR. PRESIADO: And do you know what happened after that?
CHRISTIAN CARINO: They started arguing.
MR. PRESIADO: And do you recall any details of the argument?
MR. PRESIADO: And for how long were they -- was this argument had in a hotel room?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Did you witness the entire discussion? Or did you leave at some point?
CHRISTIAN CARINO: I left the next morning at 5:00 in the morning or 6:00 in the morning.
MR. PRESIADO: And, Mr. Carino, I'm showing you emails that were produced by you. First, the bottom of the first page, it starts at the bottom of the first page, the string of emails was redacted. You'll see it started on August 7th, 2017?
CHRISTIAN CARINO: August 7th, 2017, yes.
MR. PRESIADO: Having read it, can you determine who you're speaking with in this text exchange?
CHRISTIAN CARINO: Amber.
MR. PRESIADO: Let me ask you this: Do you know whether or not Ms. Heard ever had a relationship with Mr. Elon Musk?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: She did?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Again, it's dated August of 2017. And she says, "Dealing with breakup. I hate when things go public. See, I'm so sad."
MR. PRESIADO: Having reviewed the document again, do you have an understanding of what she's referencing there?
CHRISTIAN CARINO: I believe she's referring to breaking up with Elon.
MR. PRESIADO: You say, "Seems like a press release. You weren't in love with him, and you told me a thousand times you were just filling space."
MR. PRESIADO: What are you saying there?
CHRISTIAN CARINO: I'm saying, "Why would you be sad if you weren't in love with him to begin with?"
MR. PRESIADO: And by "him," you're referring to who?
CHRISTIAN CARINO: Elon.
MR. PRESIADO: And at this point in time, were you still close friends with Ms. Heard?
CHRISTIAN CARINO: Looks like that's the case at that time, yes.
MR. PRESIADO: And was -- did she still -- at this point in time, did she still confide in you about her relationships?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Okay. And you respond -- I'm sorry, she responds "I know, but I wanted time to grieve and recover in my own time." Is she still referring to Mr. Musk there, do you know, your understanding?
CHRISTIAN CARINO: I don't know whether she's referring to Johnny or to Elon in that line.
MR. PRESIADO: Okay. At this point in time, do you know what her feelings were, or what was your understanding -- at this point in time what was your understanding, based on your experience with her, what was your understanding of her relationship with Mr. Depp?
CHRISTIAN CARINO: I don't believe there was a relationship at that point.
MR. PRESIADO: And you say, "And you got that, no?" She says, "No. I hate that, yet again, a man lets me fall on the spikes by myself."
MR. PRESIADO: You ask, "How so?"
MR. PRESIADO: She says, "Meaning they are mad at me for leaving them and put things like this out there." You say like -- sorry. She says, "Like that you say you could avoid all of this if you stop dating uber-famous people. You can be with a big man who isn't famous." What were you relating to her there?
CHRISTIAN CARINO: I believe what I was saying was if you don't like being in the press about your personal life, then don't date people that are famous.
MR. PRESIADO: Sure. You indicated that she moved on,22 immediately after JD -- after, I'm sorry, after Johnny Depp to date Elon Musk.
MR. PRESIADO: Is that accurate?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Okay. Sure. Do you have an understanding one way or the other whether Ms. Heard and Mr. Musk were, in fact, dating at the time of the San Francisco reconciliation that she asked you to set up?
CHRISTIAN CARINO: I don't know whether they were dating, O but they had definitely spent time together.
MR. PRESIADO: And do you know how long after the San Francisco attempted reconciliation you came to the understanding that Elon Musk and Ms. Heard were, in fact, dating?
CHRISTIAN CARINO: I don't know exactly how long, but not long after.
MR. PRESIADO: Do you know who she's -- what was your understanding of who she was referring to when she said here, "I love him"?
CHRISTIAN CARINO: Johnny.
MR. PRESIADO: Based on this exchange, did you have an understanding at this time whether Ms. Heard g wanted to reconcile with Mr. Depp?
CHRISTIAN CARINO: I believe she did.
MR. PRESIADO: And at this point in time, she was still a close, personal friend of yours, correct?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And at this point in time, was she -- did she consider you a confidant, in your understanding?
CHRISTIAN CARINO: I think, yes.
MR. PRESIADO: Okay. Just to authenticate this document, again, Mr. Carino, do you see that it's referenced at the bottom Bates stamp CC indicating that you produced this document?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And after having read this, do you perceive this as a true and correct copy of a text exchange between you and Ms. Heard?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Okay. And I will -- you see at the very top here, it's dated August 16th, 2017?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And Ms. Heard states to you, "I've written so many notes. Can you give him one. I don't know how or where to start. There's no way to begin/end all I have to say, but I have so many. Finally I am single, clear in my heart and my mind. I just want him to know that I loved him and that I am sorry."
MR. PRESIADO: Do you have an understanding of who Ms. Heard is referring to here? ,o
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And who is Ms. Heard referring to in this text?
CHRISTIAN CARINO: Johnny.
MR. PRESIADO: And what is she asking you to do here?
CHRISTIAN CARINO: She was asking me to deliver a letter that she was writing to him.
MR. PRESIADO: Okay. And did she also want you to -- and it says "and that I am sorry." What was your understanding that she was asking you to do there, if anything?
CHRISTIAN CARINO: I believe that was all in reference to getting him a handwritten letter that she was writing or trying to write.
MR. PRESIADO: It was your understanding at the time of this text exchange, August 24, 2017, that Ms. Amber was attempting to reconcile with Mr. Depp?
CHRISTIAN CARINO: I believe so.
MR. PRESIADO: Okay. And I know this may sound repetitive, but on August 20 -- at the time of this text on August 24, 2017, you and her were still close, personal friends, correct?
CHRISTIAN CARINO: I believe so.
MR. PRESIADO: But to be sure, Mr. Carino, I want to confirm that this was the document produced by you, correct, based on the Bates stamp at the bottom?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And do you see it's dated September 27th, 2017?
CHRISTIAN CARINO: September 23rd.
MR. PRESIADO: Oh, you're right. My apologies. It's dated September 23rd, 2017. It's a text to you that says "God, I miss him." Do you have an understanding of what -- who Ms. Heard is referring to there?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And who is that?
CHRISTIAN CARINO: Johnny.
MR. PRESIADO: And do you see at the bottom, the date of the text is June 9th, 2018?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: Okay. And it says, "I text him happy birthday.
MR. PRESIADO: Do you know who sent that and who the "him" is?
CHRISTIAN CARINO: I assume this is from Amber, and she's talking about Johnny.
MR. PRESIADO: Have you had a chance to review the whole document, Mr. Carino?
MR. PRESIADO: What does this appear to be?
CHRISTIAN CARINO: It appears to be the communications around the time that we set up a meeting in San Francisco.
MR. PRESIADO: And who are these meetings between?
CHRISTIAN CARINO: Me and Johnny.
MR. PRESIADO: And this first bubble, can you tell if y the blue is you or Mr. Depp?
CHRISTIAN CARINO: I think the blue is me.
MR. PRESIADO: Sure. Earlier in your deposition, at the very outset, I was asking you about your representation of individuals at CAA. You indicated that you represent individuals that are both actors and musicians. Would you consider Mr. Depp in that pool?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And you represented -- or CAA represented him both in connection with his acting endeavors and his involvement with the Vampires?
CHRISTIAN CARINO: Yes.
MR. PRESIADO: And was Mr. Depp's participation in Hollywood Vampires lucrative?
MR. PRESIADO: Do you know whether or not it was something Mr. Jeff -- Mr. Depp enjoyed?
CHRISTIAN CARINO: Yes.