Laura Wasser — Direct

MS. BREDEHOFT: Will you please state your name and address for the record.

MS. BREDEHOFT: Thank you. What is your occupation?

MS. BREDEHOFT: And how Jong have you been an attorney?

MS. BREDEHOFT: You represented Mr. Depp in the divorce against Amber Heard; is that correct?

MS. BREDEHOFT: And you are here under subpoena?

MS. BREDEHOFT: Your practice has primarily been focused on domestic relations in California; is ! 22 that correct?

MS. BREDEHOFT: Are you a member of any bar other than California?

MS. BREDEHOFT: During the period of 2012 through 2016, I was California a no-fault state with respect to divorce?

MS. BREDEHOFT: During the period of 2012 to 2016, was California a community property state, with respect to the division of assets in a divorce?

MS. BREDEHOFT: And what does that mean to you?

MS. BREDEHOFT: And what do you mean by "absent some other theory of law applied"?

MS. BREDEHOFT: Now, if someone alleges domestic violence or abuse against their spouse, would that change the amount they would otherwise be entitled to under community property laws?

MS. BREDEHOFT: In obtaining a temporary restraining order, what is your understanding of the process?

MS. BREDEHOFT: And the temporary restraining order, can it be continued?

MS. BREDEHOFT: Yes. When did you first begin representing Mr. Depp relating to his divorce with Amber Heard?

MS. BREDEHOFT: I'm going to ask you to pull up Document 1, Wasser Document 1. Let's go ahead and label that as Wasser Exhibit Number 1.

MS. BREDEHOFT: Ms. Wasser, I'm going to ask you to take a look at what has been marked as Wasser Deposition Exhibit Number 1. It is a letter dated May 24, 2016. It's addressed to Jake Bloom, and it says "Re: In the marriage of Depp."

MS. BREDEHOFT: Do you see that?

MS. BREDEHOFT: And it's from Samantha Spector, who indicates she's representing Amber Heard.

MS. BREDEHOFT: As of the time of this letter, had you made known to Amber Heard or Ms. Spector or anyone j! else related to them that you represented Mr. Depp?

MS. BREDEHOFT: Did you receive a copy of this letter from someone?

MS. BREDEHOFT: Did you receive this letter on or around May 24, 2016?

MS. BREDEHOFT: Around May 24, 2016?

MS. BREDEHOFT: Did you have any communications with I Samantha Spector in connection with this letter?

MS. BREDEHOFT: And when you say within days, could it have been the same day, the 24th, the next day, the 25th?

MS. BREDEHOFT: I'm going to direct your attention to the next paragraph. It says, "To this end, please have Johnny promptly sign and return, by Friday, May 27, 2016, the enclosed notice and acknowledgement of receipt form confirming service of the summons, petition, law case cover sheet and blank response."

MS. BREDEHOFT: Did you do that?

MS. BREDEHOFT: No, I understand that. But it was given to you, correct?

MS. BREDEHOFT: And you were representing Mr. Depp, correct?

MS. BREDEHOFT: And Mr. Bloom did not represent I Mr. Depp in connection with the divorce, correct?

MS. BREDEHOFT: So once Mr. Bloom gave this to you, then did you represent Mr. Depp going forward in communications with Samantha Spector?

MS. BREDEHOFT: Now, the next section, I think, is something you referred to earlier. It says, "In addition, we are requesting on Amber's behalf the following," and it says, "appropriate pendente lite support."

MS. BREDEHOFT: Would you have an understanding of what that amount might be at the time that you saw this letter?

MS. BREDEHOFT: Do you recall making any kind of y g y I counter to any of these items?

MS. BREDEHOFT: Had you had any communications with Samantha Spector prior to her going into court on that Friday, May 27th?

MS. BREDEHOFT: How many communications had you had with Ms. Spector prior -- prior to receiving this letter and prior to her going into court at 8:30 on May 27, 2016?

MS. BREDEHOFT: Do you have a recollection of whether any of the communications that you had with Ms. Spector between the receipt of this letter that's dated May 24, 2016, and going -- and Ms. Spector going into court on Friday, May 27th, 2016, related in any way to requests on your behalf -- on behalf of your client that you made?

MS. BREDEHOFT: You recall having communications with Samantha Spector between May 24 and May 27, you can't recall how many, and you can't recall the specifics of those communications; is that accurate?

MS. BREDEHOFT: It's not accurate. And in what way is it not accurate?

MS. BREDEHOFT: Now, on the next paragraph, it has a proposal for private retired judicial officers. Ultimately, did you and Ms. Spector talk about using a private retired judicial officer whether it was the list she provided or any others?

MS. BREDEHOFT: And what do you recall?

MS. BREDEHOFT: What do you recall Ms. Spector saying to indicate that she did not want to take it out of the system?

MS. BREDEHOFT: Okay. Now, after -- your understanding was that a CLETS DVTRO was, in fact, obtained on Friday, May 27th, 2016, by Ms. Heard against Mr. Depp, correct?

MS. BREDEHOFT: Okay. After that, did there come a time that you or anyone on -- at your law finn 1116 communicated with the Eastern Columbia Building concierge staff or management? .18

MS. BREDEHOFT: The Penthouse Lofts, yes. And if it's easier for you, everyone has been referring to the Eastern Columbia Building as ECB. Would that be helpful at all?

MS. BREDEHOFT: If you prefer to call them the penthouse Lofts building, that's fine too.

MS. BREDEHOFT: And who from your from spoke with someone at the building and when?

MS. BREDEHOFT: Now, you indicated either you or Samantha Klein, Lisa Sutton, and you also had co-counsel. Do you have a specific recollection of speaking with anyone at the ECB building?

MS. BREDEHOFT: What were Samantha Klein's communications with the ECB building?

MS. BREDEHOFT: What were Lisa Sutton's communications with the ECB building?

MS. BREDEHOFT: What were your co-counsel's communications with the ECB building? When I say "ECB building," I'm not talking about the structure; I'm talking about the individuals who worked there.

MS. BREDEHOFT: And just so we're clear here, you don't recall any communications with the ECB building staff as well, correct?

MS. BREDEHOFT: Do you have a general recollection?

MS. BREDEHOFT: Are you able to testify to any conversation you or anyone at your from or your co-counsel had with the ECB building staff?

MS. BREDEHOFT: Are you able to speak to whether there I 1 s were any conversations between you, anyone at your I law from, or your co-counsel and ECB building personnel prior to your issuing the subpoena?

MS. BREDEHOFT: So you don't have a recollection of a subpoena being issued on Mr. Depp's behalf for the ECB building surveillance tapes?

MS. BREDEHOFT: Let's talk about the videos that you just referred to from the ECB building staff.

MS. BREDEHOFT: How did you and your finn or your co-counsel receive these videos?

MS. BREDEHOFT: Now, is it your recollection that there was just one e-file that contained all of the surveillance tapes?

MS. BREDEHOFT: When you were talking about receiving

MS. BREDEHOFT: The video surveillance footage, whether it was one file or seven files or eight files or whatever, did you have an understanding that you were not provided the full amount that was requested, whatever the amount was?

MS. BREDEHOFT: So you thought you received whatever you were supposed to receive; is that fair?

MS. BREDEHOFT: What did you do with the actual surveillance footage that you received?

MS. BREDEHOFT: That's my next question.

MS. BREDEHOFT: Is there a time that you no longer possessed the video surveillance footage that was sent to you by the ECB building?

MS. BREDEHOFT: Ms. Wasser, I'm going to ask you to take a look at what has been marked as Wasser Deposition exhibit Number 2, and it's a multipage document, and so I'm going to scroll down a little bit, but you let me know if I'm going too fast here. It's dated June 3rd, and it's to Samantha Klein. She's with your -- she was working with y g you on the Depp case, correct?

MS. BREDEHOFT: And it's from Samantha Spector, which you can see there, and I'll show you the signature later. And it's a litigation called preservation of information, and it's not limited to electronically stored information.

MS. BREDEHOFT: Do you see that?

MS. BREDEHOFT: Do you recall receiving this letter? If you want me to scroll down and let you read each page, I'm happy to do that first.

MS. BREDEHOFT: And did you receive this letter before you received the surveillance footage from the ECB building?

MS. BREDEHOFT: Well, I think you had indicated that you thought that it was in June or July that you received the surveillance footage.

MS. BREDEHOFT: Is that still your best recollection?

MS. BREDEHOFT: Ms. Wasser, what steps did you and your firm and co-counsel take to preserve the surveillance video footage of ECB from the time you received it going forward?

MS. BREDEHOFT: Are you aware of any destruction of the video footage, surveillance video footage, of ECB up to the present?

MS. BREDEHOFT: Have you looked for it?

MS. BREDEHOFT: Have you been asked to look for it?

MS. BREDEHOFT: I'm going to ask you to take a look at what has now been marked as Wasser Deposition Exhibit Number 3, and it's dated June 6th, 2013, addressed to you, and it's from Charles Carter.

MS. BREDEHOFT: Did you have an understanding that Mr. Carter also represented Amber Heard?

MS. BREDEHOFT: And did you have an understanding that Mr. Carter was also asking you to preserve any evidence?

MS. BREDEHOFT: Ms. Wasser, I'm going to ask you to take a look at what has been marked as Wasser Deposition Exhibit Number 4, dated June 6th as well, and it's to Charles Carter from your firm. And you are acknowledging receipt of the preservation letter from Ms. Heard as well as his. And you indicated, "We are fully aware of our obligations with respect to preservation of evidence. Please rest assured that we intend to comply with the preservation demand and expect that Ms. Heard will do so as well."

MS. BREDEHOFT: Do you recall saying that in this letter?

MS. BREDEHOFT: And was this letter, in fact, only to Ms. Heard?

MS. BREDEHOFT: Ms. Wasser, I'm going to ask you to take a look at what's been marked as Wasser Deposition number 5. It's a letter dated June 21, 2016, to Samantha Spector, Charles Carter, and Leonard Levine, I think it's pronounced, Re: Marriage of Depp, and it's from Samantha Klein.

MS. BREDEHOFT: Do you see that?

MS. BREDEHOFT: And you are copied on it. Do you see that?

MS. BREDEHOFT: Okay. And Ms. Klein worked with your Jaw finn?

MS. BREDEHOFT: And represented Mr. Depp as well; is that correct?

MS. BREDEHOFT: Okay. I'm going to go back up to the beginning to call your attention to a particular section. It says, "This letter shall confirm the agreements we reached yesterday with respect to the pending domestic violence proceeding."

MS. BREDEHOFT: Do you see that?

MS. BREDEHOFT: Then you're going to go down to the media press, and it says, "Neither party nor his or her respective counsel representatives, or agents shall make any comments to media or press pertaining to this dissolution action, the civil action pending against Constanope [sic], and/or any pending or future litigation between and/or involving the parties."

MS. BREDEHOFT: Do you see that?

MS. BREDEHOFT: Does that accurately reflect the agreement that was made between the parties with respect to Amber Heard and Mr. Depp and communication to the press?

MS. BREDEHOFT: Did you know Ms. Walters?

MS. BREDEHOFT: Ms. Walters?

MS. BREDEHOFT: And who is she?

MS. BREDEHOFT: For?

MS. BREDEHOFT: Did you have any communication with Liz Walters during the Depp/Heard divorce?

MS. BREDEHOFT: Did you have any communications with TMZ relating to the Depp/Heard divorce?

MS. BREDEHOFT: Now, do you recall what the date was for the permanent TRO, temporary restraining order? Do you recall the date that -- you said that early on, 21 days after the temporary restraining order is typically the date that set the hearing for the defendant if they want to come in and oppose it or if the petitioner wants to extend it.

MS. BREDEHOFT: Do you recall what the first date was?

MS. BREDEHOFT: All right. And then do you recall that date being continued?

MS. BREDEHOFT: How many times?

MS. BREDEHOFT: All right. Alan, can l we bring up number -- document number 7. Thank you.

MS. BREDEHOFT: Ms. Wasser, I'm going to ask you to take a look at what's been marked as Wasser Exhibit Number 7. It is dated August 5, 2016. It is to you from Samantha Spector. Do you see that?

MS. BREDEHOFT: Do you recall -- did you receive this document?

MS. BREDEHOFT: It sure does. All I'm asking is whether you received it or not. I'm not asking you about the substance.

MS. BREDEHOFT: Do you have any reason to believe that you did not receive it?

MS. BREDEHOFT: Ms. Wasser, I'm going to ask you to take a look at what's been marked as Wasser Deposition exhibit Number 8. And it starts out with an email from Samantha Spector to Amber on August 6th, 2016.

MS. BREDEHOFT: Do you recall what was going on, on or around August of with the divorce, in connection with the divorce?

MS. BREDEHOFT: Do you know who Christian Carino is?

MS. BREDEHOFT: Okay. Who is he?

MS. BREDEHOFT: How long have you known Christian Carino?

MS. BREDEHOFT: Were you aware that Mr. Carino was involved in organizing, if you will, or assisting Mr. Depp and Ms. Heard with their own meeting to try to resolve their case up in San Francisco?

MS. BREDEHOFT: Were you on the telephone at any point while Amber Heard and Johnny Depp were meeting to discuss attempted resolution of the issues during summer of 2016?

MS. BREDEHOFT: Yes.

MS. BREDEHOFT: Were you on the telephone where Mr. Depp and Ms. Heard were in the hotel and were talking?

MS. BREDEHOFT: Were you ever on the telephone when Ms. Heard and Mr. Depp were together talking during the Summer of 2016, no matter where they were?

MS. BREDEHOFT: Yes.

MS. BREDEHOFT: While he was with Ms. Heard and I Ms. Heard was on speaker -- and you were on ! 10 speakerphone with the two of them?

MS. BREDEHOFT: You recognize the name -- let me get this here.

MS. BREDEHOFT: COURT REPORTER: Do you recognize the name on what?

MS. BREDEHOFT: Joe Sweeney.

MS. BREDEHOFT: And who was he?

MS. BREDEHOFT: And was Edward White acting as forensic accountant for Mr. Depp?

MS. BREDEHOFT: Did Mr. White provide the documentation Is that was then submitted to Samantha Spector as counsel for Ms. Heard?

MS. BREDEHOFT: I'm going to show you what has been marked as Wasser Deposition Exhibit Number 10, and I'm not going to ask you any specific questions so I don't need you to have to review it in detail unless you'd like to. You're certainly welcome to spend as much time as you'd like on it. But I'm just going to go down to the end of it, and I'm going to ask if this is the memorandum that you referred to that was finalized on August 16, 2016.

MS. BREDEHOFT: Okay. Is there any reason to believe that it is not the final deal point memorandum?

MS. BREDEHOFT: Ms. Wasser, I'm going to ask you to take a look at what has been marked as Wasser Deposition exhibit Number 11, and it's a series of documents, an FL-150, for example, and then -- that's page 4 of 4, and then it goes into the next part, 1 of 1. Try to page through it for you just so you can see generally.

MS. BREDEHOFT: Do you recognize this document?

MS. BREDEHOFT: Could you tell me what it is, please?

MS. BREDEHOFT: Ms. Wasser, I'm going to ask you if you can take a look at what has been marked as Wasser Exhibit Number 12. And it's a -- many pages. I think it's 50 total.

MS. BREDEHOFT: Do you recognize this document?

MS. BREDEHOFT: And can you tell me what it is?

MS. BREDEHOFT: Is there a specific amount that was paid to Amber Heard as part of this divorce settlement and judgment for --

MS. BREDEHOFT: For her claims of domestic violence including any claims of assault, battery, intentional or negligent infliction of emotional distress, libel, slander, and/or defamation?

MS. BREDEHOFT: Did you make any effort to seal, S-E-A-L, the records in this case? And I'm referring to the case in front of us, the marriage or partnership of Amber Laura Depp and John C. Depp I, filed in Superior Court of California out in Los Angeles.

MS. BREDEHOFT: Yes.

MS. BREDEHOFT: Why not?

MS. BREDEHOFT: We would ask you to take a look at what O has been marked as Deposition Exhibit Number 13. And this is a subpoena of you for this deposition. Did you receive that? Do you want me to scroll through it?

MS. BREDEHOFT: And you are testifying pursuant to this subpoena, correct?

MS. BREDEHOFT: I'm going to ask you to look at what has been marked as Deposition Exhibit Number 14. And this is for the corporate designee of Wasser, Cooperman & handles; do you see that --

MS. BREDEHOFT: For today's deposition?

MS. BREDEHOFT: Is it your understanding that you're the corporate designee on behalf of Wasser, Cooperman & handles speaking today?