Edward White — Direct/Cross/Redirect
587 linesMR. DENNISON: Good afternoon, Mr. White.
EDWARD WHITE: Good afternoon, Counselor.
MR. DENNISON: Will you state your full name for the record.
EDWARD WHITE: Yes. Edward White.
MR. DENNISON: Where do you reside?
EDWARD WHITE: Los Angeles, California.
MR. DENNISON: How are you employed?
EDWARD WHITE: Many years ago I founded Edward White and Company, Certified Public Accountants, and I am the managing and senior partner of the firm
MR. DENNISON: What is a certified public accounting firm?
EDWARD WHITE: A certified public accounting firm is authorized by a particular state, in my case, California to audit financial information and to certify the statements related thereto.
MR. DENNISON: What's the nature of the work that's p done at Edward White and Company?
EDWARD WHITE: It's diversified. It includes providing tax and related compliance services, that is to do the tax return for the clients. That's both fiduciary, corporate, individual, as well as partnership work. We also are involved in providing financial statements for financial institutions and for governmental agencies. We, in addition to that, have a business management department and provide a wide variety of services in that capacity.
MR. DENNISON: Are you the Edward White of Edward White and Company?
EDWARD WHITE: Yes, I am.
MR. DENNISON: Who do you employ?
EDWARD WHITE: We employ a very talented group of professionals that have really amazing credentials. They have graduate degrees from NYU and USC in business administration as well as taxation. Many of my colleagues have been with the firm for over 25 years, in one case for 35 years. I'm very proud to be associated with this group of people.
EDWARD WHITE: Who are your principal clients?
EDWARD WHITE: We represent approximately 100 high-net-worth individuals and the companies that they own and operate. In addition to that, we do work for governmental agencies such as the Department of Justice, the State of Alaska, the State of California, and the City of Long Beach.
MR. DENNISON: What's your educational background?
EDWARD WHITE: I started my college career utilizing the GI Bill. I served four years in the Air Force and was fortunate enough to have that opportunity. My undergraduate degree was in business administration, and I have a master's degree in business administration from the University of 116 Southern California. After completing my graduate degree at USC, I studied several -- I took several tax classes, corporate, fiduciary, estate and gift, and subject matters such as that.
MR. DENNISON: Do you have any other experience with education?
EDWARD WHITE: Yes. I was a former professor of accounting and taxation at California State University located in Los Angeles, California.
MR. DENNISON: What kind of work do you personally do?
EDWARD WHITE: The work I do is primarily transaction oriented, acquisition of companies, dispositions such as buying or selling a company, arranging financing with large financial institutions, consulting with clients where they feel it's appropriate for me to be involved, assisting my colleagues. As I mentioned to you we have approximately 100 high-net-worth individual clients, and there's always something I can contribute to.
MR. DENNISON: Do you hold any certifications?
EDWARD WHITE: Yes. I'm certified in financial forensics by the American Institute of Certified Public Accountants. I'm also a member of the American Institute of Certified Public Accountants and the California Society of Certified Public Accountants, and of course I'm a certified public accountant.
MR. DENNISON: What are financial forensics?
EDWARD WHITE: That's an attempt to ascertain not only the facts but what transpired as related to financial activity. So you do a study based upon financial records. You then look at contracts, look at other financial information, in an attempt to, once again, not only ascertain what the results were but what caused the results.
MR. DENNISON: Have you ever previously testified in court?
EDWARD WHITE: Yes. I've been accepted as an expert witness in both the California court and the federal courts, and I have testified in matters involving the Department of Justice and the FBI.
MR. DENNISON: Okay. Do you serve on any boards or have you served on any boards?
MR. ROTTENBORN: Objection. Relevance. Your Honor, this witness is not being proffered as an expert in this case.
THE COURT: All right. He's just a fact witness and not an expert witness?
MR. DENNISON: Fact witness, and that goes the credibility.
THE COURT: I'll sustain the objection. I think we can move on.
MR. DENNISON: Do you know Mr. Depp?
EDWARD WHITE: Yes, I do.
MR. DENNISON: How did you come to know Mr. Depp? 1
EDWARD WHITE: I met him because he was introduced to me by a senior executive at the Bank of California, Richard Smith.
MR. DENNISON: Do you work with Mr. Depp?
EDWARD WHITE: Yes, I do.
MR. DENNISON: In what capacity?
EDWARD WHITE: We are his business management firm
MR. DENNISON: How Jong have you served in that capacity?
EDWARD WHITE: Approximately six years.
MR. DENNISON: What does that role involve?
EDWARD WHITE: Processing, managing his financial affairs. As you know, Mr. Depp is an amazing talent, internationally acclaimed for his work, but he relegated his financial activities to me and my colleagues, so we provide a wide variety of services for him
MR. DENNISON: Do you do this kind of work for other people?
EDWARD WHITE: Yes. We do. Numerous other clients.
MR. DENNISON: When did you first become involved with Mr. Depp?
EDWARD WHITE: Approximately six years ago, after the 7: introduction from Mr. Smith.
MR. DENNISON: What was the nature of the work that you were to perform for him?
EDWARD WHITE: Initially, it was to perform a forensic study, evaluate his financial affairs, and to formulate recommendations on how he could manage his affairs in a more advantageous manner.
MR. DENNISON: After you conducted that analysis, what did you do?
EDWARD WHITE: I met with Mr. Depp, the purpose of which was to share with him the results of our findings and to make recommendations in how he could resolve the issues he was confronting.
MR. DENNISON: When was that meeting?
EDWARD WHITE: That meeting was on April 21st, 2016.
MR. DENNISON: Who called the meeting?
EDWARD WHITE: I did. I called the meeting because I felt it was appropriate to meet with Mr. Depp and to discuss his affairs and to provide him with opportunities and plans and strategies to resolve the issues he was confronting.
MR. DENNISON: Where was the meeting held?
EDWARD WHITE: It was held at his offices in Los Angeles, California.
MR. DENNISON: Do you know approximately what time it began?
EDWARD WHITE: It began at approximately 7:30, and my recollection is there were seven people in attendance, including Mr. Depp and myself.
MR. DENNISON: Was alcohol served at the meeting?
EDWARD WHITE: Not to my recollection. I don't recall any alcohol being consumed.
MR. DENNISON: Did Mr. Depp stay for the entirety of the meeting?
EDWARD WHITE: Oh, yes. He was very interested in the contents. He asked very thoughtful questions. He was fully engaged and fully sensitive to the matters that we were discussing.
MR. DENNISON: Did there come a time when Mr. Depp didn't participate in the meeting?
EDWARD WHITE: No. He was very actively involved. He did excuse himself on two or three occasions. It's my understanding that he was going to contact Ms. Heard and attempt to respond to her concerns and also address the fact that this was an extremely important meeting and that involved his financial viability and that he felt it imperative to stay and address the issues I was discussing with him.
MR. DENNISON: When did the meeting conclude?
EDWARD WHITE: At approximately 9:30. So it went for approximately two hours.
MR. DENNISON: At the conclusion of the meeting, what did you deserve -- what did you observe as to Mr. Depp?
EDWARD WHITE: That he was fully engaged, once again. He thanked me profusely for not only addressing the problems, but he was excited about the fact there was a strategy and a plan to resolve the problems.
MR. DENNISON: Did he appear impaired to you in any way?
EDWARD WHITE: No. To the contrary -
MR. ROTTENBORN: Objection. Leading.
EDWARD WHITE: I found him to be -
THE COURT: I'm sorry, sorry. There's . an objection. What was the objection? Leading?
MR. DENNISON: I just asked him for his observation as to impairment.
THE COURT: I'll sustain that objection, but you can ask another question.
MR. DENNISON: Did you make any observations as to Mr. Depp's potential impairment?
EDWARD WHITE: It was readily apparent to me that he was actively involved in the conversation. He asked very thoughtful and prudent questions. He was genuinely interested, and once again, when he left, he thanked me profusely for not only addressing the issues but formulating a strategy and plan to resolve them in a successful manner.
MR. DENNISON: Did you have -- did you play any role on Mr. Depp's behalf with respect to dissolution of his marriage to Ms. Heard?
EDWARD WHITE: Yes. I was actively involved in the ,3 negotiations of the separation and the marriage dissolve.
MR. DENNISON: What role did you play in those negotiations?
EDWARD WHITE: Well, in my capacity as his business manager, I understood his financial capacity and the tax implications associated with it. So I was actively involved in addressing those issues as they were forthcoming from counsel.
MR. DENNISON: You mentioned tax implications. What are you talking about there?
EDWARD WHITE: Excuse me?
MR. DENNISON: I think you just mentioned tax implications. What are you talking about there?
EDWARD WHITE: Well, what I was talking about is that when Ms. Heard began the negotiations, she was asking for approximately $4 million. That amount then was increased -
MR. ROTTENBORN: Objection, Your Honor. Foundation, hearsay, lack of foundation, hearsay.
MR. DENNISON: These are requests made
THE COURT: You want to approach for a minute?
MR. ROTTENBORN: Foundation. He wasn't involved in these conversations. He hasn't established that he was.
MR. DENNISON: He just testified that --
MR. ROTTENBORN: He's actively involved, but he's not actively involved in talking to Ms. Heard.
THE COURT: Did Ms. Heard tell him that, I guess, is the question.
MR. DENNISON: No. Ms. Heard negotiated these things through agents, lawyers, and he dealt with their lawyers.
THE COURT: I understand. But I mean if he didn't get it directly from her, then I'll sustain the objection.
MR. DENNISON: I'm sorry, Your Honor. I didn't hear what you said.
THE COURT: I'm sorry. If he didn't get that directly from Ms. Heard, then I'll sustain.
MR. DENNISON: Even though the lawyers were involved?
THE COURT: Because he's not a lawyer. I mean, you can get into his understanding, but not quotes of what she said.
MR. DENNISON: Oh, okay. I understand.
THE COURT: Okay.
MR. DENNISON: As a result of your involvement on behalf of Mr. Depp in the negotiation, what was your understanding of what Ms. Heard was looking for?
EDWARD WHITE: She initially was looking for a consideration of $4 million. But that demand continually increased. It went from $4 million to $5 million. Then it went from $5 million to 5 and a half million dollars. Then it went to $7 million. And then it was $7 million, and she required demanded that Mr. Depp also pay $500,000 to her attorneys.
EDWARD WHITE: Then after that consideration, she also said that all the community liabilities that were accumulated during the course of the marriage, which approximated -
MR. ROTTENBORN: Objection, Your Honor.
THE COURT: There's an objection, sir. When there's an objection, I'm sorry, if you can't hear it, I'll let you know.
EDWARD WHITE: I'm sorry. Thank you.
THE COURT: Yeah. No problem, sir.
MR. ROTTENBORN: This goes into the allegations of what she said, which Your Honor just instructed -- sustained the objection on that. He has no foundation to suggest that, no knowledge of that.
MR. DENNISON: Your Honor. I understand that. I asked his understanding.
THE COURT: All right. I'll overrule the objection. Go ahead.
EDWARD WHITE: May I continue?
MR. DENNISON: She'll tell you yes.
THE COURT: Yes.
EDWARD WHITE: Thank you, Your Honor.
THE COURT: He learns very well.
EDWARD WHITE: So the next demand was that all the community liabilities that were unresolved, approximately $13.5 million, that Mr. Depp had to pay those liabilities in its entirety. So at that point, she was demanding $14,250,000 of consideration, and then it got worse. The next demand was that all this consideration be paid to her free of taxation. And, Counselor, for him to pay 1614 million, $14,250,000 to Ms. Heard, that would require him to earn approximately $30 million.
MR. ROTTENBORN: Objection. So far beyond the scope. So far beyond his foundation of what was discussed.
THE COURT: I'll sustain that last answer. All right. Next question.
MR. DENNISON: Did you make a proposal as to how payments would be made to Ms. Heard?
EDWARD WHITE: Yes, I did. And they were initially contemplated to be paid directly to the charities, the Children Hospital of Los Angeles for the benefit of the children who required severe medical service, and to the ACLU.
EDWARD WHITE: During the course of the negotiations, one of the demands as the contract changed, was that the payments be made directly to Ms. Heard
MR. DENNISON: Did you have any personal involvement with either the ACLU or the Children's Hospital?
EDWARD WHITE: Yes, I did
MR. DENNISON: What was that?
EDWARD WHITE: Mr. Depp directed me to issue two $100,000 checks directly to the Children's Hospital Los Angeles. I knew that he was involved and supported their efforts and appreciated his service. In addition to that, he directed me to contribute $100,000 to ACLU. In accordance with his instructions, my colleagues drafted the checks, I executed them, and they were delivered to the two charities.
MR. DENNISON: Did you continue making payments to either of those charities on Ms. Heard's behalf?
EDWARD WHITE: No. In fact, I was chastised for making the payments by Ms. Heard's counsel and told the payments in the future would go directly to her.
MR. ROTTENBORN: Objection, Your Honor. IO This is clearly hearsay. He's not answering the question. I would ask for you to instruct him to answer the question and not expound upon his --
THE COURT: I'll sustain as to hearsay.
THE COURT: Next question.
MR. DENNISON: What role did you play with respect to the payments ultimately made to Ms. Heard?
EDWARD WHITE: We supplied the payments to Ms. Heard in accordance with the agreement either on or before the date in which they were required to be paid. The first payment made to Ms. Heard was $2 million in 2017.
EDWARD WHITE: Then in April of 2017, another payment p of $1 million, made payable directly to Ms. Heard, was made.
EDWARD WHITE: Then in August of 2017, another million dollars was paid directly to Ms. Heard.
EDWARD WHITE: Then in November, $500,000 was paid directly to Ms. Heard.
EDWARD WHITE: My colleagues drafted those checks. I executed them. Were delivered on a time basis.
EDWARD WHITE: Therefore, in 2017, she was paid $4.5 million directly paid to her. Then on February 1 of 2018, she was paid the final installment of $2.3 million, for total payments that went directly to Ms. Heard of $6.8 million.
MR. DENNISON: ,Do you know when this lawsuit was filed?
EDWARD WHITE: Yes. It was filed on March 1, 2019.
MR. DENNISON: Okay. Were the payments that were made on Mr. Depp's behalf directly to Ms. Heard the only economic benefit she received?
MR. ROTTENBORN: Objection. Leading.
THE COURT: I haven't heard the -- I'll overrule the objection for now. Go ahead.
MR. DENNISON: Were the payments made to Ms. Heard the only economic benefits that she received from the settlement agreement?
EDWARD WHITE: No. As I shared with you earlier, Mr. Depp was required to pay $500,000 to Ms. Heard's counsel, which he did in a timely, respectful manner. He was also required to pay all the community liabilities which cumulated during their 15 months of marriage which was approximately $13,500,000. So he paid all the community liabilities; she paid none of them.
EDWARD WHITE: That's why you'd have to aggregate the money that was paid directly to her, the money that was paid to her -- to the charities on her behalf, the money that was paid to her attorneys, and the relief of all these liabilities that she had -- that he had to satisfy. That's why I said to you, Counselor, that the total consideration paid to her was $14,250,000, and she demanded that that payment be made free of taxation, that Mr. Depp would have to satisfy all the tax liabilities.
MR. DENNISON: How long were they married for?
EDWARD WHITE: They were married for 15 months.
MR. DENNISON: Okay. Were the payments that went to Ms. Heard the only payments that you've made on Mr. Depp's behalf?
EDWARD WHITE: No. We satisfied all of his obligations. So it was very customary for us to pay everything that Mr. Depp was obligated to pay.
MR. DENNISON: Are you familiar with an entity known as Twenty Twenty Wine Merchants?
EDWARD WHITE: Yes, I am.
MR. DENNISON: Why are you familiar with it?
EDWARD WHITE: It's a prominent purveyor of wine in Los Angeles, California.
MR. ROTTENBORN: Objection, Your Honor. Foundation. Hearsay.
THE COURT: I don't see the hearsay, but I don't know.
MR. ROTTENBORN: Foundation at this point.
MR. DENNISON: Can we approach?
THE COURT: Sure.
THE COURT: All right.
MR. ROTTENBORN: What's the relevance?
THE COURT: Relevance not the objection, it's foundation. I assume that's what you're laying, right?
MR. DENNISON: I'm laying a foundation. He's going to tell you he paid the wine person.
THE COURT: What's the relevance?
MR. DENNISON: There's some evidence in this case -- a suggestion in this case that Mr. Depp was going through $30,000 a month in wine. And --
THE COURT: Okay.
MR. DENNISON: And direct evidence of that's on --
MR. ROTTENBORN: That's evidence from--
THE COURT: That's all right. I'll overrule the objection.
MR. DENNISON: Thank you.
THE COURT: That's fine.
MR. DENNISON: I think where we left off is I asked you how were you familiar with Twenty Twenty Wine Merchants. And if that's not what I asked you, that's what I'm asking you now.
EDWARD WHITE: Twenty Twenty is a highly recognized purveyor of wine in Los Angeles along with other companies.
MR. DENNISON: What involvement, if any, did you have with Twenty Twenty?
EDWARD WHITE: I satisfied the liabilities that Mr. Depp incurred, which at the dissolve of the marriage, was approximately $160,000.
MR. DENNISON: Do you continue to pay Mr. Depp's wine bill?
EDWARD WHITE: Yes I do We pay all of his obligations But his wine bill has shrunk to virtually zero because he does not consume that much in way of wine He's made a few gifts around Christmastime but his wine bill has gone to virtually zero
MR. DENNISON: Are you familiar with a Spanish wine b known as Vega Sicilia?
EDWARD WHITE: Yes.
MR. DENNISON: How are you familiar with that?
EDWARD WHITE: I know that it is a very expensive wine, and then I know that Ms. Heard enjoyed drinking the wine.
MR. DENNISON: How much does it cost?
EDWARD WHITE: The cost of the wine is approximately $500 a bottle.
MR. DENNISON: Were you ultimately charged with paying for the wine that was served on -- at the birthday party on April 21, 2016?
EDWARD WHITE: Yes,I was.
MR. ROTTENBORN: Objection. Foundation.
THE COURT: I'll overrule the objection. That's fine.
MR. DENNISON: How many bottles of Vega Sicilia was served?
EDWARD WHITE: At Ms Heard's request she ordered five bottles of the wine and eight bottles of other wine, so a total of 13 bottles of wine.
MR. DENNISON: Thank you, Mr. White. I have no other questions at this time.
THE COURT: All right.
MR. ROTTENBORN: Good afternoon, Mr. White.
EDWARD WHITE: Good afternoon, Counselor.
MR. ROTTENBORN: Your firm has been paid millions of dollars by Mr. Depp and his companies since you were first retained in 2016, correct?
EDWARD WHITE: Correct.
MR. ROTTENBORN: And, in fact, you're being paid for the time that you're sitting on that witness stand today, aren't you?
EDWARD WHITE: No.
MR. ROTTENBORN: Well you charged the time that you spent in connection with legal proceedings in this case correct
EDWARD WHITE: That's correct But I charge for my time.
MR. ROTTENBORN: Yeah.
EDWARD WHITE: And it's the same time as -
MR. ROTTENBORN: You answered the question. In fact, you charge $710 an hour, don't you?
EDWARD WHITE: Counselor, if you'll let me complete my answer, I'll be happy to respond.
MR. ROTTENBORN: Sir, please try to stick to the question I'm asking you. You've had your chance to go well beyond the question being asked, but if you could just please stick to the question I'm asking you, it will go faster?
MR. DENNISON: Objection, Your Honor. Badgering.
THE COURT: That's not really-- badgering is not an objection, but that's all right.
THE COURT: Sir, if you could, answer the question that's asked, okay? Thank you.
MR. DENNISON: Thank you, Your Honor.
MR. ROTTENBORN: Let me start over, sir. You charge Mr. Depp $710 an hour for the work that you do for him, don't you?
EDWARD WHITE: That is my standard rate for all clients, and, yes, I do charge that rate to Mr. Depp.
MR. ROTTENBORN: And you gave a deposition in this case, do you remember that, on or around February 2nd, 2022?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And that day, you charged $710 an hour for the time you spent giving testimony that day, didn't you?
EDWARD WHITE: Yes, I did.
MR. ROTTENBORN: And you charge Mr. Depp $710 an hour for anything that you do in connection with his account, don't you?
EDWARD WHITE: Yes, I do.
MR. ROTTENBORN: You have about six people working on Mr. Depp's account, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And whether through you or one of your colleagues, your main contact with Mr. Depp and his companies is his sister, Christi Dembrowski, correct?
EDWARD WHITE: No.
MR. ROTTENBORN: Who is your main contact?
EDWARD WHITE: Mr. Depp.
MR. ROTTENBORN: One of your colleagues maintains active communication with Christi Dembrowski, correct?
EDWARD WHITE: Could you ask the question again, Counselor?
MR. ROTTENBORN: One of your colleagues maintains active communication with Christi Dembrowski, correct?
EDWARD WHITE: No.
MR. ROTTENBORN: May I approach, Your Honor?
THE COURT: All right. Yes, sir.
THE COURT: Thank you.
MR. ROTTENBORN: Mr. White, I've handed you the transcript from your deposition that you gave in this case on February 2nd, 2022.
MR. ROTTENBORN: Do you remember that? We did it over Zoom.
EDWARD WHITE: Yes, I do.
MR. ROTTENBORN: Okay. And you swore to tell the truth in that deposition as best you can, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: Okay. Can you turn to page 116 of your deposition transcript.
EDWARD WHITE: Certainly. Did you say 16, Counselor?
MR. ROTTENBORN: 1-1-6.
EDWARD WHITE: Okay. I have it.
MR. ROTTENBORN: And now, you just answered "no" to my question about your colleagues maintaining communication with Christi Dembrowski. But at your deposition just two months ago, at line 11 of page 116, the question is "What about Christi Dembrowski?"
MR. ROTTENBORN: The answer that you gave is "I do not. I haven't spoken to Christi in some time. One of my colleagues probably maintains an active basis of communications between her and our firm."
MR. ROTTENBORN: Did I read that right SIL
EDWARD WHITE: Yes. But define your term.
MR. ROTTENBORN: I'm just asking if I read that right, Now, part of the service that you provide -- that your firm provides to Mr. Depp is to pay the bills to his doctors, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And you make payments relating to maintenance or damages to his properties, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: Now, you were contacted in early 2016, right? You testified to that, to do work on behalf of Mr. Depp?
EDWARD WHITE: We were engaged -
MR. ROTTENBORN: Engaged?
EDWARD WHITE: In 2016, if that's your question.
MR. ROTTENBORN: Right. Right. Around February 10th, is that when you were first contacted?
EDWARD WHITE: I do not recall the date.
MR. ROTTENBORN: And you said you were introduced by executives, a guy named Richard Smith at the Bank of California?
EDWARD WHITE: Yes.
MR. ROTTENBORN: Mr. Depp owed a significant amount of money to the Bank of California at that time, I! correct?
EDWARD WHITE: No.
MR. ROTTENBORN: He owed money to the Bank of California, correct?
EDWARD WHITE: I do not recall that he had an active indebtedness with the Bank of California. He had O had other commercial loans, but not with the Bank of California.
MR. ROTTENBORN: And after you were brought on, you developed an understanding that Mr. Depp's financial status was very challenging, correct?
EDWARD WHITE: It was challenging, but we had an ability to resolve the problems if they were ! 17 properly addressed.
MR. ROTTENBORN: He had liquidity problems, right?
EDWARD WHITE: He had substantial assets in excess of his liabilities, but he had short-term obligations that needed to be satisfied.
MR. ROTTENBORN: Let me just ask that question.
MR. ROTTENBORN: At the time that you were brought on, he had liquidity problems, correct?
EDWARD WHITE: Can you define "liquidity" for me?
MR. ROTTENBORN: I'm asking you. At the time he was brought on, he had liquidity problems, correct?
EDWARD WHITE: I would define the term "liquidity" as where the short-term assets are less than the Is short-term - excuse me - are less than the short-term liabilities. If that's how you're O defining "liquidity," I would agree.
MR. ROTTENBORN: In layman terms, in terms that I could understand because I don't speak all the kind of business school terms that you speak, he didn't have enough money at the time, correct? He was spending more than he was bringing in, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And you gave him advice about how he could honestly get out of that problem, correct?
MR. ROTTENBORN: Okay. And just to be clear, Mr. White, because you've testified to some degree of knowledge about wine that you allege that I Ms. Heard requested. So you seem to have some knowledge of Mr. Depp's spending.
MR. ROTTENBORN: Ms. Heard didn't -- she didn't buy any of the dozens of properties that Mr. Depp owned, correct?
EDWARD WHITE: Correct. He owned the assets prior to their marriage.
MR. ROTTENBORN: She didn't pay $5 million to blast Hunter Thompson's ashes out of a cannon, did she?
EDWARD WHITE: Not to my knowledge.
MR. ROTTENBORN: She didn't buy a yacht that she couldn't afford and then have to sell it to JK Rowling, did she?
EDWARD WHITE: Not to my knowledge.
MR. ROTTENBORN: Now, let's talk about that meeting on April 21st, 2016. You said the meeting started at about 7:30 p.m.
EDWARD WHITE: Yes.
MR. ROTTENBORN: And lasted till maybe 9:30; is that Yes. right?
MR. ROTTENBORN: And you have no idea, no personal 3 29 5 knowledge, where Mr. Depp went after he left that meeting, do you?
EDWARD WHITE: That is correct. I did not go with him. I went home.
MR. ROTTENBORN: And at that meeting, Mr. Depp was given some catastrophic news about his business, correct?
EDWARD WHITE: He was given news that he needed to address a number of financial issues. But I had a strategy and plan to fully resolve them.
MR. ROTTENBORN: That news that he was given that night was catastrophic, wasn't it?
EDWARD WHITE: No.
MR. ROTTENBORN: May I approach, Your Honor?
THE COURT: An right. Yes, sir.
THE COURT: Thank you.
MR. ROTTENBORN: Mr. White, let's do this again with another under-oath series of statements. You gave testimony in the U.K. trial, did you not?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And that testimony was under oath, I correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: All right. And in front of you, I have your testimony from the U.K. trial and you gave that testimony on behalf of Mr. Depp, correct?
EDWARD WHITE: I gave it honestly.
MR. ROTTENBORN: Okay. You gave it on behalf of Mr. Depp, correct? You were one of his witnesses ! called?
EDWARD WHITE: That is correct.
MR. ROTTENBORN: Okay. Can you please turn to page 865. And it's just the second page of the document, upper left. Before that the questions are talking about this meeting on April 21st, 2016. And you were asked the question: "QUESTION: Now, Mr. Depp was given some catastrophic news about his business? "ANSWER: That is correct." Did I read that right?
EDWARD WHITE: You did. But remember -
MR. ROTTENBORN: No. You answered my question.
EDWARD WHITE: I did not define that term.
THE COURT: Sir, you'll have a chance to -- the attorney will get back up and redirect you, okay? So if you would just answer his question, that's fine.
MR. ROTTENBORN: And the reason I'm asking, sir, is because you just gave the exact opposite testimony here. So that's why we pointed that out.
MR. ROTTENBORN: Now you, at this meeting, you had a discussion about his financial affairs and the necessity to formulate a revised business strategy and plan, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And you talked about the following financial information: You talked about bank obligations and tax liabilities, right?
EDWARD WHITE: Yes.
MR. ROTTENBORN: Which means money you owe to either the government or banks, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: You talked about assets that he needed to sell, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: Properties and things like that that he needed to sell to generate money?
EDWARD WHITE: Correct.
MR. ROTTENBORN: You talked about ways to reduce spending, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And you talked about how to get new engagements, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: How to get new gigs, right?
EDWARD WHITE: Not how to get them, but I encouraged him to get them
MR. ROTTENBORN: The need to get them.
EDWARD WHITE: I'm not an agent. I'm not that familiar with his engagements.
MR. ROTTENBORN: Understood. I appreciate that. You talked about the need to get new gigs to generate additional money to help address these financial woes that he was experiencing, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: You also told him at that meeting that his taxes, he hadn't paid taxes in years, correct?
EDWARD WHITE: No, that's not correct. That he had not paid any taxes in years is not correct.
MR. ROTTENBORN: That he was significantly delinquent in federal obligations dating back years, correct?
EDWARD WHITE: I don't know how you're defining years. If there were delinquent liabilities, I addressed them and formulated a plan.
MR. ROTTENBORN: And you talked about the significant O delinquent tax liabilities that would run into the millions of dollars for taxes unpaid, correct?
EDWARD WHITE: That is correct.
MR. ROTTENBORN: And so after receiving these -- this catastrophic news, as we discussed, you have no idea where Mr. Depp went when he walked out the doors of his office, correct?
EDWARD WHITE: I do not know where he went.
MR. ROTTENBORN: Okay.
MR. ROTTENBORN: Can you pull up Plaintiff's Exhibit 936, please.
MR. ROTTENBORN: And, Mr. White, I'm not going to -- this is a long document that we can scroll I through, but what I'll represent to you, and ! Michelle can sort of scroll down, is that these ,3 appear to be Mr. Depp's tax returns for Mr. Depp and his companies from 2009 to 2019.
MR. ROTTENBORN: Do you see that?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And these are returns as part of your role as his CPA firm now, his business manager firm now, your firm prepares these tax returns, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And you maintain these tax returns in the ordinary course of your business, correct?
EDWARD WHITE: That is correct.
MR. ROTTENBORN: Your Honor, I know there's going to be plenty of redaction to do, but I just would like to move these into evidence. I don't plan to publish them or anything at this point.
MR. DENNISON: Objection, Your Honor.
THE COURT: Do you want to approach? Sure.
THE COURT: What's the objection?
MR. DENNISON: I don't have any issue with them coming in. But I want to make sure they're appropriately redacted.
THE COURT: Well, that's what he just said.
MR. ROTTENBORN: I wasn't even going to publish them.
THE COURT: He said he wasn't going to publish them. You guys work out the redactions.
MR. DENNISON: We'll work it out, but I we're talking about extraordinarily sensitive I material.
MR. ROTTENBORN: Understood.
THE COURT: Understood. All right. So 936 will come into 118 evidence, but I'll wait for redactions and they will not be published, okay?
MR. ROTTENBORN: Thank you, Your Honor.
MR. ROTTENBORN: BY MR. ROTTENBORN:
MR. ROTTENBORN: Now, Mr. White, you understood that Mr. Depp showed up hours late for work on Pirates 5, correct?
EDWARD WHITE: That is not correct.
MR. ROTTENBORN: Are you familiar with Tracey Jacobs?
EDWARD WHITE: Yes.
MR. ROTTENBORN: That's Mr. Depp's former agent, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And at the time that she was serving as his agent, part of her job responsibilities, to the best of your understanding, was to communicate with you about Mr. Depp's financial affairs, correct?
EDWARD WHITE: To the extent she had knowledge.
MR. ROTTENBORN: Right.
EDWARD WHITE: Yes, she would communicate.
MR. ROTTENBORN: And you and she did communicate about Mr. Depp, correct?
EDWARD WHITE: During the period of her engagement?
MR. ROTTENBORN: Yes.
EDWARD WHITE: Yes, we did communicate.
MR. ROTTENBORN: Can you pull up Defendant's exhibit 874, please, Michelle.
MR. ROTTENBORN: Mr. White, do you see here this text exchange between you and Tracey Jacobs.
EDWARD WHITE: Yes.
MR. ROTTENBORN: And your texts are in white, and Ms. Jacobs's are in blue, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: Michelle, could you please scroll to the document that is Bates-stamped Depp 19246. It's about the fifth or sixth one down, please.
MR. ROTTENBORN: Mr. White, do you see here the third text down from Tracey Jacobs to you saying, "Thanks. I got a call from Disney last week saying he showed up five hours late"?
MR. DENNISON: Objection, Your Honor. Hearsay.
MR. ROTTENBORN: It's not hearsay. It's party opponent. She's his agent. I'm happy to approach if you'd like to discuss. PIANE
THE COURT: Approach. •2
MR. ROTTENBORN: One, it's impeachment. Because he just said he didn't know about it.
THE COURT: That's fine. He said he ! 6 didn't -- you're just using it for impeachment purposes?
MR. ROTTENBORN: Yeah. But I also want to get Tracey Jacobs into evidence because under Rule 803(0), she was his agent at the time, and she was authorized to make statements on his behalf, and that falls squarely into party opponent admission.
THE COURT: Do we have testimony of that?
MR. ROTTENBORN: He just testified she was his agent at the time.
THE COURT: He just testified --
MR. ROTTENBORN: I know, but...
THE COURT: Right.
MR. ROTTENBORN: She was his talent agent.
THE COURT: Okay.
MR. DENNISON: Your Honor, we wouldn't admit communications directly from Ms. Beard's lawyers, and now we have a talent agent in an email that is somehow a party admission when she's, in fact, talking to a financial advisor?
MR. ROTTENBORN: I think in her capacity as his agent, and they're talking about commercial opportunities.
THE COURT: I'm not sure. She said she can't get ahold of him in all these statements, ! 12 correct?
MR. ROTTENBORN: I'm sorry?
THE COURT: She said she can't get ahold of him in all these statements.
MR. ROTTENBORN: There's many more.
THE COURT: Well, which one do you want I to get into evidence? Just the one about Disney? I don't have a problem with the impeachment one.
MR. ROTTENBORN: Yeah. But I want to be able to read the impeachment text, the one about Disney, and then there's a few more basically on the first page where she says, "We haven't been able to ...
THE COURT: What's the context? What's the relevance of that?
MR. ROTTENBORN: Because he's saying, "I didn't have the opportunities after Amber wrote this article." And now he's turning down a movie where he's offered $8 million, or $6 million, because he wants 8. And then some of the ones about her just not being able to get ahold of him, which includes screenshots of his texts to Tracey Jacobs. I just think under 803(0), her statements as an agent are party admission by him
THE COURT: Kind of a far stretch, Mr. Rottenborn.
THE COURT: So you will think under 803.
MR. ROTTENBORN: 803(0).
THE COURT: Does it have to do with availability level?
MR. ROTTENBORN: No, just a party opponent admission.
THE COURT: I'm getting it.
MR. ROTTENBORN: I always wonder why they put the zero.
THE COURT: I know. Making life hard for everybody. All right. 803, I don't have the most recent one. Yeah. I got it. Admission by party opponent.
THE COURT: "Statement by a person authorized by the party to make a statement concerning the subject."
MR. DENNISON: That's clearly not the case here, Your Honor.
MR. ROTTENBORN: She's his talent agent. She's authorized by Depp to make statements about what he wants and what his...
MR. DENNISON: She's authorized to make statements, but she can't reach Mr. Depp? That's certainly not true.
THE COURT: All right. "Statement by a party or agent made during the term of agency concerning a matter within the scope of such agency."
THE COURT: So which ones did you want to get in?
MR. ROTTENBORN: Well --
THE COURT: I just want to make sure I get them right.
MR. ROTTENBORN: So the first page she says, "We haven't been able to reach him regarding Labyrinth. They wanted to reduce his fee from 8 million to 6 million," and then she says later, "He texted me back, Johnny, he doesn't want to reduce his fee, which means the film goes away." So those two texts are ones I want to get in. And then later, she's exchanging texts with Mr. White about how she can't -- he won't respond. She says, "Just to let you know, his November movie is about to fall apart.
MR. ROTTENBORN: No one can reach him, and if it doesn't go today, the financing falls apart. Just giving you a heads-up."
THE COURT: I understand.
MR. ROTTENBORN: And then she, like, screenshots texts to him where Johnny's demanding the producers --
THE COURT: As I read the part C, "By a" personal representative or designated speaking agent, although an agent employed for the purposes of making a statement may qualify, very few employees are hired to be speaking agents. Is She is the agent.
MR. ROTTENBORN: I mean, she's like the agent.
MR. DENNISON: How do you get a speaking on his behalf to Mr. White?
THE COURT: Your response?
MR. ROTTENBORN: She's just like Christian Carino yesterday, she was predecessor to Carino who obviously spoke a lot about things. I don't see any difference.
THE COURT: We didn't get any texts in his, though. I think I sustained those objections too. In the view of being consistent, I think I'm going to sustain. But I do think you get that one in for impeachment purposes, if you can redact for just that one.
MR. ROTTENBORN: Okay. Thank you. Can we admit that?
THE COURT: With redactions and published that one. You redact it just that one.
MR. ROTTENBORN: Thank you.
THE COURT: Uh-huh.
MR. ROTTENBORN: Mr. White, we just saw the text I started reading.
MR. ROTTENBORN: Do you remember that text?
EDWARD WHITE: Yes.
MR. ROTTENBORN: Okay. We're going to just show you and move for admission of that page of the document with that text, so I just wanted, since you won't see anything else, I just wanted you to orient yourself that that is the text that we were just reading, okay?
EDWARD WHITE: Fine.
MR. DENNISON: Your Honor, that page or that text?
THE COURT: They're going to redact it to just that one text.
MR. DENNISON: Thank you.
THE COURT: Uh-huh.
MR. ROTTENBORN: Your Honor, I would move for admission of this document. I guess we could call it Defendant's 874A
THE COURT: Okay. 874A with the redactions.
MR. ROTTENBORN: Thank you, Your Honor.
MR. ROTTENBORN: Mr. White, you just testified a few minutes ago that you didn't have any understanding of Mr. Depp showing up late for work on Pirates 5. But, in fact, you received this text from Tracey Jacobs that says, "Thanks. I got a call from Disney last week saying he showed up five hours late for ADR work in London for Pirates 5. I really need to speak to him before he starts work on his next project in LA"
MR. ROTTENBORN: Did I read that right?
MR. ROTTENBORN: Permission to publish this, Your Honor?
THE COURT: Oh, yes. I'm sorry.
MR. ROTTENBORN: Thank you.
EDWARD WHITE: Do you want me to respond?
MR. ROTTENBORN: I just wanted to ask you if I read that right, that you received this text message saying b in part, "I got a call from Disney last week I 4 saying he showed up five hours late for ADR work in London for Pirates 5. I really need to speak to him before he starts work on his next project in LA."
MR. ROTTENBORN: Did I read that right?
EDWARD WHITE: I believe you read it right
MR. ROTTENBORN: Thank you. Now, at some point you became I familiar --
MR. ROTTENBORN: You can go ahead and take that down.
MR. ROTTENBORN: At some point you became familiar, as I you testified, with what Amber planned to do with money that she got from Mr. Depp in the divorce, correct?
EDWARD WHITE: It was the understanding from the beginning the money would be contributed to charities.
MR. ROTTENBORN: The two charities, the Children Hospital of LA and the ACLU, correct?
EDWARD WHITE: That is correct
MR. ROTTENBORN: And as we discussed, you wrote checks to those two organizations that were part of Mr. Depp's divorce payment, but they were just sent directly to those organizations, correct? I .17
EDWARD WHITE: Yes.
MR. ROTTENBORN: Can you please pull up Defendant's Exhibit 1639. Actually, let's go to Defendant's Exhibit-- yeah, we'll do 1639. Thanks.
MR. ROTTENBORN: Mr. White, this is a letter from you to the ACLU Foundation dated August 24th, 2016, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And as part of your work for your I hundred or so high-profile, high-net-worth clients, you've helped clients set up pledge contributions to charities before, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And sometimes those payments are made over a period of time, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: Charitable donations aren't always paid at once, correct?
EDWARD WHITE: That is correct.
MR. ROTTENBORN: And when you make payments on behalf of your clients to charities, is it customary for you to send a cover letter like this?
EDWARD WHITE: In some instances, yes. In some instances, no.
MR. ROTTENBORN: Okay.
EDWARD WHITE: But in all instances, that there is a signed agreement and an understanding that when the -
MR. ROTTENBORN: Yeah. Sir, that wasn't my question. My question is just is it customary for you to send a letter like this? And I think you've answered that.
MR. ROTTENBORN: And so when you send letters like this on behalf of your clients, do you prepare such letters in the ordinary course of your business?
EDWARD WHITE: In some instances, yes.
MR. ROTTENBORN: In the instances in which you prepare those letters, did you then maintain those letters in the ordinary course of your business?
EDWARD WHITE: Yes.
MR. ROTTENBORN: Your Honor, I move for admission of Defendant's exhibit 1639.
THE COURT: Any objection?
MR. DENNISON: No objection.
THE COURT: All right. 1639 in evidence, and you can publish it to the jury.
MR. ROTTENBORN: Michelle, if you could, please just scroll through.
MR. ROTTENBORN: Mr. White, I just want you to see the letter here. We'll come back to the letter, and then there's the check that you're making out to the ACLU. And then there's, I guess, the envelope or something, right?
EDWARD WHITE: Correct.
MR. ROTTENBORN: Okay.
MR. ROTTENBORN: You can go back to the letter, please.
MR. ROTTENBORN: So in this cover letter, you tell the ACLU that you're enclosing a check for a hundred thousand dollars and that the donation is being made in accordance with Ms. Heard's pledged gift of three and a half million to the ACLU Foundation, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And you also write that the check represents just -- go ahead -- that the check represents the first of multiple scheduled installments, correct?
EDWARD WHITE: It was my understanding that -
MR. ROTTENBORN: I'm just asking if that's what you ! 12 wrote.
EDWARD WHITE: That 3 million.
MR. ROTTENBORN: I'm asking if that's what you wrote. Its
EDWARD WHITE: You've asked me a question. I'm trying to respond.
MR. ROTTENBORN: No. I was actually just asking if that's what you wrote.
EDWARD WHITE: Would you ask the question again, please?
MR. ROTTENBORN: Yeah. You write, "This check represents the first of multiple scheduled installments to honor the full amount of Ms. Beard's three and a half million dollar pledged gift," correct?
EDWARD WHITE: It was my understanding she was going S to contribute the money, and that -
MR. ROTTENBORN: Okay. Sir, I just asked if that's what you wrote. I think you've answered that.
MR. ROTTENBORN: Can we please pull up exhibit 1596.
MR. DENNISON: Your Honor, before we go ! 11 to the next exhibit, can I raise an issue at the ! bar?
THE COURT: Okay. Sure.
MR. DENNISON: Thank you.
MR. DENNISON: That check needs to be redacted too.
THE COURT: Yeah. I saw that.
MR. ROTTENBORN: Oh. Yeah. Okay.
MR. DENNISON: I didn't want it to come in.
THE COURT: Yeah, I hope you didn't take pictures of it.
MR. ROTTENBORN: I understand. Okay.
THE COURT: I didn't know a check was coming.
MR. ROTTENBORN: I'm sorry. We'll redact that.
THE COURT: Just redact that.
MR. ROTTENBORN: And then the next exhibit is just a cover letter. It doesn't have a check on it.
THE COURT: There's no check, no routing numbers?
MR. ROTTENBORN: No. I promise you on this one.
THE COURT: Okay. Thank you. All right. Thank you.
MR. ROTTENBORN: Mr. White, is this a letter similar to what we just looked at for the ACLU, a letter that you wrote that accompanied the check that you sent to the Children's Hospital of Los Angeles foundation?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And this letter and whatever payment -- sorry -- this letter is one that you would have prepared in the ordinary course of business, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: And you would have maintained this letter in the ordinary course of business, correct?
EDWARD WHITE: Yes.
MR. ROTTENBORN: Your Honor, I move for admission of Exhibit 1596.
MR. DENNISON: No objection.
THE COURT: All right. 1596 in evidence. You can publish it to the jury.
MR. ROTTENBORN: And, Mr. White, this letter also says at the bottom that it represents -- the check that accompanies this letter represents the first of multiple scheduled installments to honor the full amount of Ms. Heard's $3.5 million pledged gift, correct?
EDWARD WHITE: When I composed the letter, that was my understanding, that she was going to give -
MR. ROTTENBORN: Sir, sir, I -- you're really not answering my question. My question was simply-- I understand that you want to -- you want to speak your own narrative here, but my question was simply that this letter says that this check represents the first of multiple scheduled installments to honor the full amount of Ms. Heard's three and a half million dollars pledged gift, correct?
EDWARD WHITE: We can both read the letter. The n answer's yes.
MR. ROTTENBORN: Thank you, sir. Now, you hosted a dinner with Mr. Depp and Adam Waldman in 2016, correct?
EDWARD WHITE: I do recall that.
MR. ROTTENBORN: And that was the first time that Mr. Depp had been introduced to Mr. Waldman, correct?
EDWARD WHITE: I do not know that to be factual.
MR. ROTTENBORN: Now, you are not an expert on California divorce law, right?
EDWARD WHITE: Correct.
MR. ROTTENBORN: And you're not an expert on the division of marital property in California, correct?
EDWARD WHITE: I'm not an expert, but I've been actively involved in numerous cases involving the dissolution of marriage and the related proceeds distributed to each respective party.
MR. ROTTENBORN: Now, you can't give any sort of legal opinion or testimony as to whether or not Ms. Heard would have been entitled to more in the divorce settlement with Mr. Depp than she received, correct?
EDWARD WHITE: I'm not an attorney at law.
MR. ROTTENBORN: Okay.
EDWARD WHITE: I don't render legal opinions.
MR. ROTTENBORN: So, you've never met Amber Heard, correct?
EDWARD WHITE: That is correct.
MR. ROTTENBORN: The first time you've ever seen her in person is here in this courtroom this afternoon, correct?
EDWARD WHITE: That's my recollection.
MR. ROTTENBORN: And you have no personal knowledge of whether Mr. Depp engaged in domestic abuse against my client, correct?
EDWARD WHITE: I've never witnessed him involved in any abuse, and obviously I've never met her. I could not respond to that inquiry.
MR. ROTTENBORN: So the answer to my question is that it's correct that you have no personal knowledge of whether Mr. Depp engaged in domestic abuse against Amber Heard?
EDWARD WHITE: That is correct I have no knowledge.
MR. ROTTENBORN: Nothing further.
THE COURT: All right Redirect, Mr. Dennison.
MR. DENNISON: Sir, can you read the last line of your letter.
EDWARD WHITE: "This check represents the first of multiple scheduled installments to honor the full amount of Ms. Heard's $3.5 million pledged gift"
MR. DENNISON: What was the schedule for those payments?
EDWARD WHITE: They were scheduled - I don't know the schedule because I don't have a copy of any pledge that she made, if that's your question.
MR. DENNISON: Okay. Thank you very much.
MR. DENNISON: One more question. Has Mr. Depp paid all his taxes?
EDWARD WHITE: Yes, he has. He's fully current with all of his federal, foreign, and state tax obligations.
MR. DENNISON: Thank you.
THE COURT: Allright. No further questions, Mr. Dennison?
MR. DENNISON: No further questions.
THE COURT: Is this witness subject to recall?
MR. DENNISON: No.
THE COURT: No.
MR. DENNISON: No, Your Honor.
THE COURT: All right. Mr. White, you're free to go. Just be careful stepping down there, okay.
EDWARD WHITE: Thank you, Your Honor.