Tina Newman — Direct
114 linesTHE COURT: All right. Yes, ma'am. Your next witness.
MS. BREDEHOFT: Yes, Your Honor, we would like to call the Disney corporate representative.
THE COURT: All right.
THE COURT: TINA NEWMAN, Being first duly sworn, was examined and testified as follows:
MS. BREDEHOFT: Would you please state your name and your business address for the record?
TINA NEWMAN: Tina Newman, Walt Disney Studios Motion Picture Production, Live Action, 500 South Buena Vista Street, Burbank, California 91521.
MS. BREDEHOFT: And what is your current occupation?
TINA NEWMAN: Production executive.
MS. BREDEHOFT: And what is your job title?
TINA NEWMAN: That is my title: Production executive. I work in the live action features division for Disney.
MS. BREDEHOFT: Is it your understanding you're testifying on behalf of Walt Disney Motion Pictures Group?
TINA NEWMAN: Yes.
MS. BREDEHOFT: Were you involved in gathering of the documents responsive to the documents presented to Disney?
TINA NEWMAN: Yes. I did provide some documentation to Alex and his group from our production group.
MS. BREDEHOFT: I'm going to ask you to take a look at what I just highlighted under topic number subpoena duces tecum paragraph Number 2, and it asks for documents relating to this case, in fact, and then it also says specifically, "This specifically includes the op-ed by Ms. Heard and any impact it may have had on the above, and that includes, as is defined above, including the business relationship of Mr. Depp including considering Mr. Depp for any work with Disney or future Pirates of the Caribbean role or greater role, a different role, or a different production."
MS. BREDEHOFT: Do you recall seeing in any of the documents you reviewed, either being -- as being involved as the corporate designee, or in preparing as the corporate designee, do you recall seeing an op-ed written by Ms. Heard?
TINA NEWMAN: No.
MS. BREDEHOFT: Do you recall, in your preparation as the corporate designee of Disney and your review of the documents that were produced by Disney, any document that referred in any manner to the op-ed written by Ms. Heard?
TINA NEWMAN: I would say no.
MS. BREDEHOFT: Do you remember seeing, in any of the documents you reviewed that were produced by Disney in response to the subpoena duces tecum, the word "op-ed" in any of those documents?
TINA NEWMAN: I don't recall that, no.
MS. BREDEHOFT: Did you have any discussions with anyone at Disney about any future Pirates of the Caribbean deal, a lesser or greater role, a different role, or a different production?
TINA NEWMAN: No.
MS. BREDEHOFT: Did you have any discussions with anyone at Disney about the impact of the op-ed by Ms. Heard on the relationship between Disney and Mr. Depp, including considering Mr. Depp for any work with Disney, any future Pirates of the Caribbean role, a lesser or greater role, a different role, or a different production?
TINA NEWMAN: No.
MS. BREDEHOFT: Do you know whether Mr. Depp is being considered for a role in Pirates 6?
TINA NEWMAN: No.
MS. BREDEHOFT: And when you say no, I think I have to probably ask clarification. Does that mean you don't know one way or the other or he is not being considered?
TINA NEWMAN: I don't know one way or the other.
MS. BREDEHOFT: Do you know --
TINA NEWMAN: Well-
MS. BREDEHOFT: Oh, I'm sorry, go ahead.
TINA NEWMAN: I was just going to say that decision doesn't fall within my job responsibilities. It's above my head, best way to say it
MS. BREDEHOFT: So what is the knowledge you have about Pirates 6? ,21
TINA NEWMAN: Like I said, I just know that it's a project that's possibly in development at the studio. That's it.
MS. BREDEHOFT: Do you know whether anyone at Disney has ever even read the op-ed written by Ms. Heard?
TINA NEWMAN: No.
MS. BREDEHOFT: Are you aware of anyone else at Disney who has knowledge of the topic areas in the deposition notice, that's Deposition Exhibit No. 2, beyond what you know?
TINA NEWMAN: I can't honestly say. I can't speak O for someone else. Like I explained earlier, my knowledge and what my job functionality is, at the studio plateaus, and there are people that I work under. And those particular persons may or may not have more knowledge. But I can't speak on behalf of them
MS. BREDEHOFT: Is Disney aware that Mr. Depp has testified under oath that he would not take other Pirates of the Caribbean :franchise roles for $300 million and a million alpacas?
TINA NEWMAN: No.
MS. BREDEHOFT: Would Disney entertain paying Mr. Depp more than $300 million and provide him with more than a million alpacas to be able to retain his services for any future Pirates of the Caribbean role?
TINA NEWMAN: No.
MS. BREDEHOFT: I'm going to show you what has been marked as Deposition Exhibit No. 52, to Alan Horn.
MS. BREDEHOFT: Who's that?
TINA NEWMAN: He was a co-chairman.
MS. BREDEHOFT: Of Disney?
TINA NEWMAN: Yes.
MS. BREDEHOFT: And Alan Bergman, who's he?
TINA NEWMAN: Same. He's the other co-chairman of Disney, or was at the time.
MS. BREDEHOFT: And then Sean Bailey you indicated was the president?
TINA NEWMAN: Our president of production, right.
MS. BREDEHOFT: Okay. And then Ricky Strauss, who's he?
TINA NEWMAN: I believe at the time, he was the head of our marketing group.
MS. BREDEHOFT: And Paul Roeder?
TINA NEWMAN: Paul Roeder is the head of communications.
MS. BREDEHOFT: All right. And this is from Angela Shaw, and it's dated 5/10/2017. Do you see that?
TINA NEWMAN: Yes.
MS. BREDEHOFT: And it says "Subject: HR. Johnny Depp: A star in crisis and insane story of his missing moments."
MS. BREDEHOFT: Do you see that?
TINA NEWMAN: Yes.
MS. BREDEHOFT: Do you have any understanding as to why Angela Shaw was sending this communication to this group, the two co-chairmen, the president, the vice president of production, head of communications, on this particular date?
TINA NEWMAN: I don't know what the intent of the email is, but obviously we had a relationship as a company with Johnny, so I assume that's why she may be bringing it to their attention.
MS. BREDEHOFT: All right. And just to take that a little bit further, given that Disney has a relationship with Johnny Depp, if there is I publicity relating to Johnny Depp, whether it be I, positive or negative, that would be relevant to Disney, would it not?
TINA NEWMAN: Yeah. I mean, I can't say how it's concerning the company. That's about as far as I can read into it.
MS. BREDEHOFT: Okay. And so that's your interpretation of why Angela Shaw sent this to that group of people was to keep them apprised of this particular article on Johnny Depp; would you agree?
TINA NEWMAN: Yeah, that would be my assumption.
MS. BREDEHOFT: I'm going to ask you to take a look at what has been labeled as Exhibit Number 53, and it is Disney 114 through 137. And I'm going to ask, "Do you recognize this document?"
TINA NEWMAN: Well, looks like an internal email that may be - it may have been part of the disclosure documents.
MS. BREDEHOFT: This one's from Alan Horn. And I think we've identified Alan Horn -- actually it starts with Mr. -- start down here. On June 21st, 2018, all right, and then it has a reply from Sean Bailey that says, "Sad."
MS. BREDEHOFT: Do you see that?
TINA NEWMAN: Yes.
MS. BREDEHOFT: What was Mr. Bailey's position with Disney on June 21st, 2018?
TINA NEWMAN: I believe he was the president then.
MS. BREDEHOFT: Okay.
TINA NEWMAN: He may have been the EVP. I don't know.
MS. BREDEHOFT: Okay. And then we have an email at the top. It's to Sean Bailey, CC Janelle Tipton, and then it has some copies to other people. It's from Alan Horn. I believe we said he was one of the co-directors; is that correct?
TINA NEWMAN: Co-chairman.
MS. BREDEHOFT: Co-chairman. Okay. All right. And Alan Bergman?
TINA NEWMAN: The other co-chairman.
MS. BREDEHOFT: Okay. And do you have any recollection of ever reading the Rolling Stone's article about Johnny Depp back in this time frame?
TINA NEWMAN: I honestly don't remember if I ever read this document. I may have.
MS. BREDEHOFT: Do you have any understanding of why this would be sent from Alan Horn to these other individuals on the top?
TINA NEWMAN: Again, same as before, just because of the fact that we have a relationship with Johnny, so they may have determined it was important to bring it to their attention.
MS. BREDEHOFT: All right. Now, Ms. Newman, I'm going to show you what's been marked as deposition exhibit 54. And do you recognize this document?
TINA NEWMAN: Yes. It looks like an email.
MS. BREDEHOFT: Please describe it for me.
TINA NEWMAN: It's an email - well, it started from Scott to myself. Scott Sellers is in postfinance. And then I replied to Scott. So it looks like an email exchange between to two of us.
MS. BREDEHOFT: All right. And you said Scott Sellers is in postfinance?
TINA NEWMAN: He handles all finances once a film Correct
MS. BREDEHOFT: What is that? goes into postproduction, on any given picture. Also reporting to the studio internal finances.
MS. BREDEHOFT: All right. And this is July 14, 2018, Is that he's sending this to you, correct?
TINA NEWMAN: Yes.
MS. BREDEHOFT: Do you recall reading this, the story that was in the Rolling Stone, "Trouble with Johnny Depp"?
TINA NEWMAN: To be honest, I don't remember much about the story, but obviously I must have looked at it and commented.
MS. BREDEHOFT: And, in fact, you commented, "Depressing." Do you see that?
TINA NEWMAN: Yes, yes.
MS. BREDEHOFT: And just to go back to refreshing your recollection on the template, did you see that it has "Important and Received" on this when you sent it back?
TINA NEWMAN: Uh-huh.
MS. BREDEHOFT: Ms. Newman, I'm going ask you to take a look at what has been marked as Deposition Exhibit Number 56, and it is a document also produced by Is Disney and bears the Bates stamp Disney 167 through 177. I'm going to ask you to take a look at the top here. This is to Alan Bergman from -- it has THR, Today, and Entertainment. Do you understand what that is?
TINA NEWMAN: Yes.
MS. BREDEHOFT: Okay. I'm going to ask you to turn down to 169. It says, "Johnny Depp's legal team prepares for court hearing about Amber Heard abuse claims. The actor's chance of previewing the evidence that it will present in the upcoming court hearings in the U.K. this fall tied to a defamation lawsuit against the Sun for an article that labeled the actor as a 'wife beater,' Katie Couric reports." Do you see that?
TINA NEWMAN: Yes.
MS. BREDEHOFT: Do you have a recollection of learning about this and reading about the U.K. case in this time frame we're talking of, October 2018?
TINA NEWMAN: I may have seen the headline come across my desk in the same manner as Alan received it but that's probably as far as it went.
MS. BREDEHOFT: Ms. Newman, I'm going to show you what has been marked as Deposition Exhibit Number 60. And it's dated November 5, 2020. And it says, "Disney reportedly scratch plans for Depp's IO 'POTC6"' -- I'm assuming that's Pirates of the Caribbean 6 -- "return," do you see that? Did you see it?
MS. BREDEHOFT: Yes, I see it. As you sit here today, are you aware of any document in Disney's emails or in their IT system or anywhere that contains Amber Heard's op-ed from December of 2018?
TINA NEWMAN: I mean, no, not that I'm aware of.
MS. BREDEHOFT: Are you aware of any decision-maker within Disney who has ever said they are not casting Johnny Depp in Pirates 6 or any other role because of Amber Heard's op-ed?
TINA NEWMAN: No.
MS. BREDEHOFT: Are you aware of any decision-maker outside of Disney, and by this I'm including producers, directors, people of that ilk, who has ever said they were not considering Mr. Depp for Pirates 6 or any other movie because of Amber Heard's op-ed from December 2018?
MS. BREDEHOFT: I one.
TINA NEWMAN: No.