Closing Argument - Plaintiff

MS. VASQUEZ: Good morning. Good morning.

MS. VASQUEZ: Good morning.

MS. VASQUEZ: Good morning. Good morning. Thank you. Try that again. Good morning. On May 27th, 2016, - Ms. Heard walked into a courthouse in Los Angeles, California to get a no notice ex parte restraining order against Mr. Depp, and in doing so, ruined his life by falsely telling the world that she was a survivor of domestic abuse at the hands of Mr. Depp. Today, on May 27th, 2022, exactly six years later, we ask you to give Mr. Depp his life back by telling the world that Mr. Depp is not the abuser Ms. Heard said he is, and hold Ms. Heard accountable for her lies. Ladies and gentlemen of the jury, as you probably know by now, my name is Camille Vasquez. On behalf of Mr.

MS. VASQUEZ: Depp and all my colleagues at Brown Rudnick, I want to thank you deeply for your time and your service over these last seven weeks, We understand that it probably has not been convenient for you to be here every day, and we are so grateful for your time and careful consideration of the evidence as you deliberate. ' After weeks of sitting in this courtroom listening to testimony and looking at evidence, now it's time for you, the jury, to come to a decision. You have been entrusted with a serious task. What is at stake in this trial is a man's good name.

MS. VASQUEZ: Even more than that, what is at stake at this trial is a man's life, the life that he lost when he was accused of a heinous crime, and the life he can live when he is finally vindicated. Exactly six years ago today, on May 27th, 2016, Ms. Heard walked into court and filed a false report of domestic abuse against her husband of 15 months, Johnny Depp. The scene was a setup. She tipped off the paparazzi so they would be waiting. They knew exactly where she would pause, which side of her face to photograph, and the photos captured what she wanted them to see. The image of a battered woman. But what the paparazzi did not know is that the dark mark on her face mysteriously appeared six days after last seeing Mr. Depp. It was a lie.

MS. VASQUEZ: She knew it. Mr. Depp knew it. And the multiple witnesses you heard from who saw her that week of May 21st, 2016, also knew it. But the world only saw what she wanted them to see. Two years later, when promoting the biggest role of her career, until this trial, Ms. Heard presented herself to the world as a public figure representing domestic abuse. The headline of the op-ed featured the term "sexual violence." even though she had never before Heard presented to the world, the exact opposite, in fact. There is an abuser in this courtroom, but it is not Mr. Depp. And there is a victim of domestic abuse in this courtroom, but it is not Ms. Heard. The evidence presented at this trial has shown that Ms. Heard is, in fact, the abuser, and Mr. Depp the abused. As you heard from Mr. Depp and multiple other witnesses that testified under oath at this trial, Mr. Depp experienced persistent verbal, physical, and emotional abuse by Ms. Heard during their relationship. And when their relationship was over, Ms. Heard inflicted the greatest and cruelest injury of all, she publicly and falsely named Mr. Depp as the abuser. Ms. Heard never thought she would be held accountable. Never thought that she would have to face her abuser. She never thought she would never -- have her supposed mountain of evidence vetted. She never thought that Mr. Depp would tell you, the jury and the world, that he was the real victim of domestic abuse.

MS. VASQUEZ: She said it in her own words. Con Nth WN

MS. VASQUEZ: At the start of this case, Mr. Chew and I stood before you to give you our opening statements on behalf of Mr. Depp. During that statement, we made promises to you about what the evidence would ultimately show at the end of this trial. We've kept those promises. One of those promises we made was that you would come to understand who Ms. Heard is. That she is a deeply troubled person. Violently afraid of abandonment. Desperate for attention and approval. And in her relationship with Mr. Depp, she was violent, she was abusive, and she was cruel. You heard from Dr.

MS. VASQUEZ: Shannon Curry who explained that Ms. Heard suffers from borderline personality disorder and histrionic personality disorder. These are disorders that are characterized by anger, sometimes uncontrollable and explosive anger, and a powerful, sometimes desperate, need for attention, acceptance, and approval. Fear of abandonment is the deepest fear. A person with these disorders will suffer from dramatically fluctuating moods and can sometimes be violent and aggressive. They can also be charming and likeable, but they can be incredibly manipulative and wild. An emotional rollercoaster with wild swings, from idolizing their partner to devaluing him. In fact, you saw that when she completed testing with her own forensic psychology expert, Dr. Dawn Hughes. Ms.

MS. VASQUEZ: Heard self-reported that she felt like she had three or four different personalities and that sometimes her temper would explode and she would completely lose control. You heard from multiple witnesses that Ms. Heard can be very pleasant, even charming, but you also heard from multiple witnesses and in audio recordings of Ms. Heard that she can be incredibly aggressive, violent, and cruel. You heard that even from her former assistant. Kate James. Ms. James testified that Ms. Heard would scream, yell, and send her barrages of text messages. In fact, Ms. Heard testified that -- Ms. James testified that Ms. Heard literally spat in her face. You heard from Ms. Heard's former best - friend Rocky Pennington, that Ms. Heard once hit her when Ms. Pennington did not do her best to meet Ms. Heard's needs. You also heard from Beverly Leonard, that she once witnessed Ms. Heard assault her then partner in the Seattle airport in 2009. And you heard from Mr. Depp, that Ms.

MS. VASQUEZ: Heard used her sister, Whitney, as a.punching bag, literally and figuratively. You also heard overwhelming evidence 16-from Mr. Depp and the people that were around him and Ms. Heard during the relationship, that Mr. Depp suffered persistent verbal and physical abuse at the hands of Ms. Heard. You heard evidence from Dr. Curry and the fact witnesses at this trial, that Ms. Heard's deepest fear is one of abandonment, being left by Mr. Depp. On NMA BR WYN PLANE' May 27, 2022 Mr. Depp's greatest crime, in her mind, the fault he confronts him with time and time again is that he splits. He leaves the fight, especially when Ms. Heard gets physical, and she couldn't stand it when he did. You heard from Ms. Heard yourselves and audio recordings how upsetting it was to her when Mr. Depp would split.

MS. VASQUEZ: You saw the barrage of text messages she would send when he would leave, calling him a monster for doing so. You heard from witnesses like Travis McGivern, Tara Roberts, and Debbie Lloyd, that Ms. Heard would claw Mr. Depp, block the elevator, throw a punch when Mr. Depp tried to separate himself from the fight. And you heard from Mr. Depp and Ms. Heard's couple therapist, Dr. Anderson, that Ms. Heard reported that when Mr. Depp would leave to deescalate a fight, she would strike him to keep him there. She would rather be in a fight than have him leave. You heard from Mr. Depp about how often Ms. Heard would berate him, insult him and physically attack him, including one of the most serious occasions when Ms.

MS. VASQUEZ: Heard threw a vodka bottle at Mr. Depp severely injuring his finger and then to put a cigarette-out on his face. You heard from Mr. Depp that this whole incident in Australia started because Ms. Heard was enraged that Mr. Depp wanted a postnuptial agreement and she wasn't in his will. Just a month after getting married. When her husband was seriously injured and bleeding from a partially amputated finger, what did Ms. Heard do? She pursued him. She kept coming after him because that's what she does. She wouldn't stop.

MS. VASQUEZ: You heard Mr. Depp testify he went through something like a nervous breakdown that day, and he wrote a lot of things on mirrors and other places. Again, what did Ms. Heard do as her husband was bleeding from serious injury? She wrote snarky messages right back to him. She denied it under oath to you, but the evidence that you saw speaks for itself. You heard from Mr. Depp's security, Sean Bett, who was aware of constant arguing and bickering. He witnessed Ms. Heard calling Mr. Depp names, fat ass, fuck you, Johnny. Mr. Bett testified that he saw and documented injuries on Mr. Depp, a swollen eyelid in March of 2015, cuts on his nose, scratch marks on his chin in December of 2015.

MS. VASQUEZ: And you heard from Travis McGivern, who testified that Ms. Heard called Mr. Depp names like washed-up, fucking cunt, and worst of all, a fucking deadbeat dad. Ms. Heard would take the low blows and hit him where it hurts, his children. Mr. McGivern told you that on March 23rd, 2015, Ms. Heard threw things at Mr. Depp, spat at him, and ultimately punched him in the face, leaving him with a shiner. You heard testimony from Malcolm Connolly, another security member, who testified he saw Ms. Heard throw things at Mr. Depp, a cigarette lighter on a plane, a soda can from upstairs at the Eastern Columbia Building. He never saw marks on Ms. Heard. But he saw marks on Mr. Depp, scratches, bruises on his left eye, scratches on his left ear. And he took pictures documenting injuries, like this one. You also heard from Tara Roberts, a manager at Mr. Depp's island who witnessed Ms. Heard tell Mr. Depp that he was washed-up and would die fat and lonely. You also heard from Ms.

MS. VASQUEZ: Roberts that she witnessed Ms. Heard clawing and grabbing at Mr. Depp, grabbing his hair, trying to pull him back to her, and Mr. Depp had a visible injury to his nose on that occasion. Most importantly, you heard from Ms. Heard yourselves, on multiple audio recordings, admitting to being physically violent with Mr. Depp. You heard Ms. Heard admit to hitting Mr. Depp.

MS. VASQUEZ: You heard her admit it again and claim Mr. Depp was a baby for complaining about the abuse.

MS. VASQUEZ: Take a minute to really think about what you just heard there. "I'm sorry that I didn’t -hit you across the face in a proper slap, but I was hitting you. I was not punching. Babe, you're not punched." Imagine that was Mr. Depp saying that to Ms. Heard on that recording. Let's play one more.

MS. VASQUEZ: This is the real Ms. Heard. The one in the audio recording, not the one you saw in this courtroom. What you didn't hear on a single recording you heard in this case, and there were many played by both parties, is Mr. Depp ever admitting to hitting, punching, or kicking Ms. Heard. You didn't hear it. It doesn't exist. It didn't happen. And despite the fact that It didn't happen. And despite the fact that Mr. Depp and Ms. Heard are heard discussing many of the alleged incidents you've heard about at this trial, like Australia and the Bahamas, you never heard Ms. Heard accuse Mr. Depp of sexual assault. Unlike Mr. Depp, who you heard admit to and own up to his past mistakes and his struggles, particularly with drugs and alcohol. Ms. Heard will not admit that she has ever done anything wrong. But she cannot deny what you heard on those recordings. As much as Ms. Heard and her lawyers have tried to make this case about Mr. Depp's language, it is Ms.

MS. VASQUEZ: Heard that repeatedly admits to violence. By April and May of 2016, Mr. Depp had reached his limit. His mother was dying. His finances were a mess. And when he showed up late to Ms. Heard's 30th birthday party because a meeting with his new business manager, Edward White, had gone late, Ms. Heard, of course, was not understanding. She was furious. You heard from Mr. Depp, both in this courtroom and on audio recordings, that Ms. Heard punched him that May 27, 2022 evening. He left with Travis McGivern, and the next morning, he learned that someone had left feces on his bed. Ms. Heard denies responsibility but she admitted to the prank to Starling Jenkins. You heard him testify to that effect. For almost a month after that, they didn't see each other. And you heard from Mr. Depp that when his mother died on May 20th, 2016, he was all set to leave Ms. Heard. He was done. And when Ms. Heard learned that Mr. Depp was done, that she was really losing him, she went on the attack. She filed for divorce before Mr.

MS. VASQUEZ: Depp could. Then, as you heard from Mr. Depp's divorce lawyer, Laura Wasser, Ms. Heard sent a letter demanding financial support. And when her demands weren't met, Ms. Heard struck a blow against Mr. Depp that was more damaging than any physical blow she had ever landed. When she walked into court, six years ago today, on May 27th, 2016, to get a domestic violence restraining order against Mr. Depp, she did so in front of paparazzi with a mark on her face. The evidence presented at this trial demonstrates that Ms. Heard didn't just want a divorce, she wanted to ruin him. Ms. Heard denied alerting TMZ to the TRO filing in this courtroom, but you heard testimony from Morgan Tremaine, that TMZ knew to go to the courthouse, knew which side of her face - the alleged bruise was on, and that Ms. Heard would pause, she would pause for paparazzi who got the photos that ended up splashed across newspapers and magazines - Ms.

MS. VASQUEZ: Heard testified that she did not personally give photographs of her apparent injuries to People magazine, but somehow these pictures that she took and maintained on her devices ended up on the cover of People magazine one month later. In the end, she walked away with $7 million without any tax liabilities, which she said she was donating to two charities, the ACLU and the Children's Hospital of Los Angeles. ACLU, they got less than a million dollars from her, and the Children's Hospital, they got $250,000, But that didn't stop Ms. Heard from telling the world that she donated everything because, remember, she wanted nothing. And she had donated everything. The word "donated." And that didn't stop her from testifying, under the penalty of perjury, that she had donated it. Ms. Heard tried to tell you that pledge and donate mean the same thing. She claims she hasn't given the money because she was sued.

MS. VASQUEZ: But you've heard uncontested evidence that she had the money for 13 months prior to this lawsuit being commenced by Mr. Depp. She had all the money and had month after month after month to fulfill her pledge and actually donate the money. But she didn't. She also told you that she never fulfilled the pledge because Mr. Depp sued her for defamation. That's a blatant lie. It was Ms. Heard who fired the first shot after the divorce was finalized, after she sought to initiate an arbitration against Mr. Depp for defamation, three months before the op-ed was even published, and six months before Mr. Depp filed this lawsuit. Not only does this contradict Ms. Heard's excuse for not making donations, it contradicts her narrative that she just wants to move on with her life. That she just wants Mr. Depp to leave her alone. Lies. That is Ms. Heard's narrative, lies upon lies.

MS. VASQUEZ: (Whereupon, the following video was played.) ' MALE SPEAKER: There were actually all kinds of accusations flying your way when you said all this, and then there was a divorce settlement, you got $7 million. People were saying this is all about the money, but then you did something that twisted that whole argument. What did you do with that:money?

MS. VASQUEZ: When you catch Ms. Heard in a lie, she tries to cover it up with more lies. So let's talk about the giant lie at the heart of this case, Ms. Heard's claim that Mr. Depp has been an abusive monster and that she is a public figure representing domestic abuse. At the start of this case. Mr. Chew and At the start of this case, Mr. Chew and I told you that you were going to hear some disturbing and graphic tales of abuse from Ms. Heard and they were designed to shock you and overwhelm you, which you have. We told you that this would be a performance, the role of her lifetime, as a heroic survivor of brutal abuse. When Mr. Depp brought this case for defamation, Ms. Heard went all in. She spun a story of shocking, overwhelming brutal abuse. She came into this courtroom prepared to give the performance of her life, and she gave it. Ms.

MS. VASQUEZ: Heard's acting coach, Kristina Sexton, testified that. Ms. Heard has difficulty crying when she is acting. You saw it, Ms. Heard sobbing without tears, while spinning elaborate, exaggerated, fantastical accounts of abuse and everything going on in her mind almost a decade prior while enduring that abuse. It is a performance. She told you what she thinks about -- excuse me -- she told you what she thinks you need to hear to convict this man as a domestic abuser and a rapist. She wants you to believe that she was abused countless times, countless times, over the entire course of their relationship. But as Mr. Chew and I promised you, the evidence just does not bear that out. Ms. Heard has told you that she has mountains of evidence of abuse, but there are no medical records reflecting she sustained any injuries from this abuse she claims. Ms. Heard had medical professionals at her disposal: Dr. Kipper; Debbie Lloyd; her own nurse, Erin Falati, and yet there's nothing, Ms.

MS. VASQUEZ: Heard took pictures all the time: Pictures of Mr. Depp sleeping, pictures of cocaine, pictures of property damage, pictures of herself. And as an-actress, she was photographed all the time. Where are the pictures of the horrific injuries Ms, Heard describes? Ms. Heard also took audio recordings 19.and videos frequently. Where are the videos of Mr. Depp attacking her? Where are the audio recording of Mr. Depp admitting to or apologizing for physical abuse? There are none. What Ms. Heard has and what you've seen multiple times is. video of Mr. Depp banging some cabinets around in a kitchen, a video that based on the testimony you heard from Morgan Tremaine, the former TMZ employee, Ms. Heard seems to have sold to TMZ right before she was deposed in connection with her divorce from Mr. Depp. Sure, Ms. Heard can point to text messages where Mr. Depp is apologizing to her, but never for violence. Ms. Heard's counsel showed you Defendant's Exhibit 325, where Mr. Depp says sorry for "my behavior."

MS. VASQUEZ: I'ma fucking savage." But this is not an apology for physical violence. It's an apology for "these heinous slinging - insults." Mr. Depp is apologizing for the words he used. Unlike Ms. Heard, who you heard apologizing for physical violence in multiple audio recordings, you have never heard that from Mr. Depp because he never used physical violence against Ms. Heard. Ms. Heard told you that Mr. Depp started abusing her right from the very beginning to May 27, 2022 of their relationship, starting at the beginning of 2012. But she has repeatedly testified under oath differently, to having spent a year of bliss with Mr. Depp before he ever laid a hand on her, and now, now, in this courtroom, she has suddenly erased an entire year of magic. She wants you to believe that instead of hitting after a year of magic, Mr. Depp was hitting her immediately. The good times she has testified to about repeatedly in the past apparently never happened.

MS. VASQUEZ: And with the good times erased, Ms.Heard wants you to believe that she gave Mr. Depp a big knife that said, "Hasta la muerte," "until death," to the man who supposedly would get drunk and high and beat her. Ms. Heard admitted to you during this trial that Mr. Depp always wears big, chunky rings on-every finger. According to her, he was wearing these rings when he'd slap her, hit her, punch her in the face. But you have not seen a single photograph that reflects the serious injuries Ms. Heard would have sustained if this was true, not one. Ms. Heard testified to an incident in March 2013 when Mr. Depp supposedly hit her multiple times in the face while wearing rings. And this is what her face looked like afterwards.

MS. VASQUEZ: Ms. Heard testified to an incident in Russia where she claims Mr. Depp whacked her in the face and gave her a bloody nose. She didn't take pictures of her bloody nose. But her photograph was taken on that trip, and this is what she looked like.

MS. VASQUEZ: ‘Ms. Heard told you that there was an incident the night of the Met Gala in May 2014 when Mr. Depp supposedly whacked Ms. Heard in the face, leaving her with a red, discolored, and swollen nose that she felt was broken. Ms. Heard - didn't show you any photographs of these alleged injuries, But photographs were taken of her the following night, and there were no visible injuries to Ms. Heard's face. [ DEPOS,

MS. VASQUEZ: Ms. Heard testified that in January 2015, while she and Mr. Depp were in Tokyo, Mr. Depp knelt on her back so aggressively that she was concerned that bruises would be: visible in her backless dress. Here's Ms. Heard in that backless dress.

MS. VASQUEZ: Ms. Heard testified that after an incident in December of 2015, she had two black eyes, a broken nose, and chunks of hair missing. The assault was allegedly so violent that there was blood left all over the pillows and Mr. Depp had broken the bed frame. Pictures were taken of that bed frame.

MS. VASQUEZ: Indeed, you heard from Ms. Heard's own nurse, Erin Falati, that she saw her a day or two afterwards and could not visualize the i injuries Ms. Heard described. Ms. Heard did take picture of herself after this alleged incident, but are the injuries in these photographs consistent? That's the question: Are they consistent with the brutal assault and serious injuries Ms. Heard has 10-testified to? Or are these injuries more consistent with Mr. Depp's testimony, that he and Ms. Heard bumped heads while he was trying to restrain Ms. Heard to keep her from attacking him.

MS. VASQUEZ: I have Australia, where Mr. Depp sustained the.most serious. injury from his relationship with Ms. Heard. Ms. Heard's spun story of horror, a three-day ordeal with a drug-fueled Mr. Depp violently assaulting her, cutting his own finger off, dragging her through glass, and then bending her back over a counter and raping her with a whiskey bottle. She:claimed to May 27, 2022 that she had bruises on her face, cuts all over her arms and feet, and was bleeding from her vagina from the sexual assault. And what did Ms. Heard say she did? She. went upstairs, took some sleeping pills, and went to sleep. The next morning, she took pictures of the mirrors her husband had written on in paint, using his amputated finger. She took no picture of herself, her alleged injuries, or the property 1] damage she; testified to in this courtroom. When Malcolm Connolly, Jerry Judge, 13.Dr. Kipper, and Nurse Debbie Lloyd arrived to extract Mr.

MS. VASQUEZ: Depp and get him medical treatment for his finger injury, you heard from Mr. Connolly, Dr. Kipper, and Ms. Lloyd, all of them testified they did not observe any injuries to Ms. Heard, and no one, including Ms. Heard, testified that she sought medical treatment. You also heard from Ben King, who also saw Ms. Heard right after this alleged incident. He flew home with her to Los Angeles. He testified that Ms. Heard didn't want to leave, that she said, "I can't leave. I can't leave. It will be the end if I leave." He also testified that once they did leave for Los Angeles, Ms. Heard asked him if he ever got so mad he just lost it. When Ms. Heard arrived in Los Angeles, she saw Travis McGivern, who also testified he observed no injuries, and her personal nurse, Erin Falati, who documented no requests for medical treatment and no injuries in her nursing notes for Ms. Heard. You heard from Mr.

MS. VASQUEZ: Depp's sister Christi that she.also saw Ms. Heard when she arrived back to Los Angeles and observed no injuries on Ms. Heard. Christi testified that when she told Ms. Heard her fighting with Mr. Depp was unsustainable, Ms. Heard responded that Christi should get off her cross, that Mr. Depp liked her feisty. Ms. Heard's testimony about what occurred in Australia just. doesn't add up. That's T DEPOS DAA AREY NK: because there was a monster in that house in Australia, but it wasn't Mr. Depp; it was Ms. Heard. Other than Ms. Heard's testimony, all: the evidence you've seen in this trial shows that it was Ms. Heard who attacked and grievously wounded Mr. Depp' when she threw a vodka bottle at him, severing his finger. Mr. Depp told Dr. Kipper that when Dr. Kipper arrived to treat Mr. Depp's finger. You've seen the pictures of the bar area in the Australia with the broken vodka bottles on the ground and trails of blood drops on the floor and the bloody tissue on the floor.

MS. VASQUEZ: You've heard from Ben King that the tip of Mr. Depp's finger was found in the same bar area. And you heard from Dr. Gilbert that the injury to Mr. Depp's finger could have been caused exactly as he described. And interestingly, you heard from Kristina Sexton that Ms. Heard told her that Mr. Depp injured his finger while swinging a bottle around, not smashing a phone, as Ms. Heard surmised in this courtroom, but swinging a bottle around. You also heard from Ms. Sexton that Ms. Heard first told her about the bottle rape in Australia while Ms. Sexton was at Ms. Heard's home meeting with her lawyers the day before Ms. Sexton was scheduled to be deposed in this case. The evidence presented at this trial shows that this is not the only time that Ms. Heard disclosed a sexual assault at a convenient time for purposes of litigation that she's involved in. The first time Ms. Heard claimed that Mr.

MS. VASQUEZ: Surmised in this courtroom, but swinging a bottle around. You also heard from Ms. Sexton that Ms. Heard first told her about the bottle rape in Australia while Ms. Sexton was at Ms. Heard's home meeting with her lawyers the day before Ms. Sexton was scheduled to be deposed in this case. The evidence presented at this trial shows that this is not the only time that Ms. Heard disclosed a sexual assault at a convenient time for purposes of litigation that she's involved in. The first time Ms. Heard claimed that Mr. Depp sexually assaulted her in the Bahamas in December 2015 was after Tara Roberts, the manager of Mr. Depp's island, submitted a sworn statement in the U.K. action describing the incident she testified to in this courtroom where Ms. Heard chased Mr. Depp out of the house, was yelling and then pleading with Mr. Depp to stay while clawing at his hair and clothes, and left Mr. Depp with an injury to his face. That's the first time she disclosed it, 22. after there was contrary evidence. C774 to | May 27, 2022 c | ] Ms. Heard testified about another incident just two weeks after the events in Australia where Mr. Depp supposedly attacked Ms. Heard and almost pushed her sister, Whitney, down the stairs, Whitney is the only witness that you heard from that backs up Ms. Heard's version of events. She's it. And the only witness other than Ms. Heard who claims to have seen Mr. Depp physically attack Ms. Heard. But just like Ms.

MS. VASQUEZ: Heard's version of the events in Australia, her testimony about the staircase incident and that of her sister, Whitney's, just doesn't square up with the other evidence in this trial. Their testimony is contradicted by testimony of Travis McGivern and Debbie Lloyd, who were there that night. Ms. Heard and Whitney testified that Mr. Depp threw a Red Bull can that hit or almost hit Ms. Lloyd. Ms. Lloyd testified that never happened. Mr. McGivern testified that it was Ms. Heard that threw a can at Mr. Depp. Ms. Heard testified that Whitney was between her and Mr. Depp when she punched him. Mr. McGivern testified that he was the one between Ms. Heard and Mr. Depp when Ms. Heard punched Mr. Depp. Ms. Heard testified that Mr. Depp was able to get his hands in her hair, yank her, and then hit her in the face with the cast he had on. But you heard from Ms. Lloyd and Dr. Kulber, Mr. Depp's medical doctor who treated Mr. Depp's finger injury, that Mr. Depp's finger was in a delicate state.

MS. VASQUEZ: He had a pin in his finger, a skin graft, and soft cast that immobilized Mr. Depp's two middle fingers. And tellingly, the only picture of an injury from this incident is of Mr. Depp with a shiner. And then we have May 21st, 2016. Ms. Heard testified that Mr. Depp threw a phone at her face, causing a visible injury. Ms. Heard is shown in pictures she claims to show this injury. But these photographs are not to be trusted. You heard from Mr. Neumeister, but like many of the photographs Ms. Heard has presented in this case, these photos were stored in a photo editing application. And these photos show signs of manipulation.

MS. VASQUEZ: These two photographs were taken at the exact same time and have the exact same file name, but they are visually different. One shows significantly more redness on Ms. Heard's face than the other, which doesn't show any injury at all. Ms. Heard testified the difference is explained by turning on a light. But there is no way Ms. Heard could have taken a picture, turned on a light, and then taken another picture with every hair in the exact same place within the same second. It's impossible.

MS. VASQUEZ: Moreover, you heard from multiple witnesses -- including Officer Melissa Saenz, Officer Tyler Hadden, and Officer William Gatlin, Isaac Baruch, Alejandro Romero -- who saw Ms. Heard on or after May 21st and saw no injuries to her face before she showed up to that courthouse with a mark on May 27th. And the very next day, after Ms. Heard walked into court with a bruise on her face to obtain a domestic violence restraining order against Mr. Depp, Ms. Heard was photographed laughing with her best friend, fresh-faced, with no bruise on her face.

MS. VASQUEZ: The mountain of evidence that Mr. Depp abused Ms. Heard is simply not there. What we have is a mountain-of unproven allegations that are wild, over the top; and implausible. And you can't pick and choose which of these wild allegations to believe and which ones to disregard; you either believe all of it or none of it. Either Mr. Depp sexually assaulted Ms. Heard with a bottle in Australia, or Ms. Heard got up on that stand, in front of all of you, and made up that horrific tale of abuse.

MS. VASQUEZ: Either she's a victim of truly horrific abuse, or she is a woman who is willing to say absolutely anything. It is disturbing to think that on May 27, 2022 Ms. Heard would make up the horrific tales of abuse that she testified to in this courtroom. But this case doesn't come down to whether you believe Ms. Heard or you believe Mr. Depp. This case comes down to whether you believe Ms. Heard or you believe Mr. Depp, Christi Dembrowski, Sean Bett, Malcolm Connolly, Travis McGivern, Starling Jenkins, Keenan Wyatt, Dr. Kipper, Nurses Debbie Lloyd and Erin Falati, Tara Roberts, Ben King, Kate James, Kate Moss, Dr.

MS. VASQUEZ: Kulber, Morgan Night, Morgan Tremaine, Officer Melissa Saenz, Officer Tyler Hadden, Officer William Gatlin, and Beverly 13.Leonard. 14. What Ms. Heard testified to in this courtroom is a story of far.too many women. But the overwhelming evidence, weight of that evidence, shows that it is not her story. It's not Ms. Heard's story. It was an act of profound cruelty, not just to Mr. Depp, but to true survivors of domestic abuse, for Ms. Heard to hold herself out as a public figure representing domestic abuse. It was. false, it was defamatory, and it caused irrepairable harm. And to tell more. about that, I'm going to turn it over to my colleague and my friend, Mr. Chew.

MR. CHEW: Thank you, Camille. Logistics are.not our strong suit. And thanks to all of you, truly, for taking so much time over these last several weeks to listen to Mr. Depp, to his friends, to his family, and to so many others who have come forward, physically, in this courtroom, some from 1].a very long distance, to tell you the truth and to finally, after so many years, to correct the record. As Ms. Vasquez said, you have now come to know the real Amber Heard. Scary.

MR. CHEW: We also told you at the start of this trial that you were going to come to know the real Johnny Depp, not the many characters you've seen him play so wonderfully in the movies, but the man himself. We kept that promise. You've met the real Johnny Depp. You have heard that Mr. Depp came from humble, very difficult beginnings. You have heard from Mr. Depp's big sister, who's here in the courtroom today, Christi Dembrowski, who told you how Mr. Depp grew up in a deeply troubled household with a mother, Betty Sue, who was physically abusive and mentally cruel. As Ms. Dembrowski testified, one of the names that Betty Sue called Mr. Depp when he was a'boy was "One Eye" because he had to wear an eye patch for some time. His mother used to hit his father and the kids, including young Mr. Depp. And when his mother got violent, Mr.

MR. CHEW: Depp would retreat and find a place to hide. Sometimes, he and his sister Christi would find a place to hide together. Mr. Depp never hit back. And like his father, he either stood up and took the violence, or he retreated from it. Those were habits he'd return to later when he found himself in a relationship with another person who returned his love with abuse, with physical abuse. And despite this long, unhappy history with his mother, Johnny never turned his back on her. In her elder years, Mr. Depp moved his mother to California, and he moved her to Los Angeles right across the street from his house so his two children could get to know her. He hired nurses for his mother. He made sure to take care of her and to make her comfortable. She never went to hospice. She had the nurses make her comfortable until the day she died. And from those humble and difficult beginnings, Mr.

MR. CHEW: Depp grew into one of the greatest actors and movie star in his generation. Now, he came to Los Angeles with his first love as a young man, planning to be a musician. Music had been a part of his life ever since he found peace himself in his room as a young boy when he was escaping and he would learn -- he learned to play the guitar and would use it as solace. But it was as an actor as his star began its rise as he appeared in films too many to mention, including, of course, his iconic role as Captain Jack Sparrow in the Pirates of the Caribbean franchise. Fame came with challenges to Mr. Depp and his family. It was a strange experience for a shy young man from Kentucky to be thrust into the limelight, pursued by paparazzi, and to have even his very name become a brand. But he did his best to live a private, quiet life, and despite it all, and over the years built a reputation as a respected artist and as a decent, very well-liked man, which you've heard from many people: Mr.

MR. CHEW: Depp dated major figures like Winona Ryder, Kate Moss, and Vanessa Paradis, with whom he spent 14 years together and with whom they had their children. Before Amber Heard, ladies and gentlemen, no woman ever, no woman ever before Amber Heard ever claimed that Mr. Depp raised a hand to her in his 58 years. And no other woman since Ms. Heard made that false claim back on May 17th -- May 27th, 2016, has -- and repeated it in her December 2018 op-ed, has any woman come forward since. This is #MeToo without any #MeToo. To the contrary, ladies and gentlemen, you heard Kate Moss two days ago testify -- this is a woman who has never testified in any proceeding, ever, a very private person -- testified that Mr. Depp never abused her and that Ms. Heard lied to you, and she lied to you twice when.

MR. CHEW: When she said she suggested twice that she --

MR. CHEW: Correct. That's what I'm wan —

MR. CHEW: Ladies and gentlemen, as:I was saying, Ms. Heard lied to you twice when she suggested to you that Mr. Depp pushed Kate Moss down the stairs. You told her -- you heard her * say just two days ago that Mr. Depp never did that and he never hit her and he never kicked her. That was one of --

MR. CHEW: That's exactly what. she testified to.

MR. CHEW: Thank you Your Honor They're still at it Ms Heard and her lawyers have spent much of this trial talking about drugs and alcohol Mr Denn is no saint and he has never On AA HW NH claimed to be one He has made mistakes in his life as we all have Yes he has struggled with drugs and alcohol but you never heard him deny that We told you that in the opening statement He owns his flaws He admits to them He told you all about them But he is not a violent abuser He's not an abuser as Ms Heard claims and he did not and does not deserve to have his life his legacy destroyed by a vicious lie And this is as Ms Vasquez said this is the sixth anniversary of that There is a world of difference between having substance abuse problems and being a physical abuser Ms Heard falsely accused Mr Depp of beating her That was her first allegation And you know why and you know that wasn't true Then years years after the fact for the first time she accused him of raping her The lies have grown and metastasized over time and they need to be stopped And those false accusations have caused more harm to Mr Depp than 24 455/86 May 27 2022 her fists ever did And make no mistake Ms Heard has admitted unlike Mr Depp Ms Heard has admitted on the audio tapes you've heard at this trial and Ms Vasquez just played you a few of them she has admitted repeatedly to physically abusing Mr Depp And I would just like to take a minute to talk about the harm to Mr Depp and his family You have heard from several of the people in Mr Depp's life about the damage Ms Heard's lies have done to him You heard from his sister Christi who told you how hard it has been on his family and on her little brother personally You heard Mr Depp's friend of four decades and that speaks volumes about Mr Depp He has lifetime friends who appear for him Mr Baruch told you how Mr Depp and his family had been completely wrecked by Ms Heard's lies You heard Mr Depp testify that he has lost nothing less than everything because of Ms Heard's lies nothing less than everything You heard about Mr Depp's children Jack and Lily-Rose His children have had to hear these allegations since 2016 And then when that started to die down they had to hear them again this time in December 2018 this time in The Washington Post which is a national and international publication and Mr Depp has had to live with the knowledge that his children will keep hearing those false rumors and statements against him Mr Depp has millions of fans, people who grew up watching him on 21 Jump Street, which is something you heard Ms. Heard mock on one of the tapes that was played to you. Or they grew up watching him play the (Indiscernible) pirate Captain Jack Sparrow in the Pirates of the Caribbean movies, or Willy Wonka. Mr. Depp means something to those people, and those people mean a lot to Mr. Depp. He's a fond memory from childhood or adolescence or adulthood. And to tarnish him as an abuser is to destroy him in the eyes of many of these people, who will never look at him the same way again. And because of what Ms. Heard did, and because of what she said, Mr. Depp will go to his grave knowing no matter what he does, no matter the outcome of this trial, there are people who used to look up to him who now believe that he beat a woman, which is the worst thing that you can say about a man. Beyond the personal emotional effects of Ms. Heard's lies, their impact on Mr.

MR. CHEW: Depp and his family, the damage she inflicted on his reputation and career is undeniable. There's an old saying that a good reputation takes a lifetime to build but only a second to destroy. Mr. Depp spent, in fact, a lifetime building his reputation as one of the greatest actors and movie stars of his generation, an iconic figure respected and loved throughout Hollywood and recognized and admired. You heard evidence from Jack Whigham, who is here today, Mr. Depp's agent, who explained that Mr. Depp was very well-regarded and respected by peers in the artistic community. And you've heard further testimony from Mr. Whigham that Mr. Depp had a deal with Disney to play Captain Jack Sparrow in the sixth movie sequel of the Pirates of the Caribbean franchise, for 22.5 million. But, as Mr. Whigham explained, all of that changed when Ms. Heard published her op-ed in December of 2018, in The Washington Post. Quoting from the testimony you heard by Mr. Whigham, After the op-ed, it was impossible to get him a studio film, which is what we normally would have focused on in that time period. Another quote, it was on the damage, the impact of this op-ed as opposed to the other stories that you saw, the other publications. Mr. Whigham explained why this one was so damaging. It was a first-person account, I mean, from the victim. It's extremely impactful, you know, with respect to Johnny, it was catastrophic because it was coming from a first-person account. It was not from a journalist, it was coming from someone observing, it was from someone saying this happened to me.

MR. CHEW: Depp will agree with this, rightfully so, MeToo is an important movement. A movement that Mr. Depp supports and believes in. It's for true survivors of abuse, not Ms. Heard. True victims need protection and true perpetrators need to face the repercussions. But as you heard in this case, Amber Heard is not a true victim. And Mr. Depp certainly is not an abuser. Again, nobody has come out of the woodwork to say MeToo. This is the unique and singular MeToo case where there's not a single MeToo. In fact, to the contrary. Kate Moss, who was in a romantic relationship with Mr. Depp for three years, which he broke off, came forward to say, no, he never pushed her down any Stairs. And you heard Doug Bania, an expert in Internet and social media analytics, testify to the impact that Ms. Heard's allegations had on Mr. Depp's popularity. Ms. Heard's lawyers tried to tell you that all of the damage done to Mr.

MR. CHEW: DEPP's career was because of his own behavior, because he was sometimes unprofessional or sometimes late to sets. But that doesn't hold up. Mr. Depp has been a major figure in Hollywood for decades. Yes, Mr. Depp was late to sets sometimes. But as Mr. -- as Richard Marks testified "when you hire Johnny Depp, you get all of Johnny Depp, which includes being late." Keenan Wyatt, who has worked for decades as a sound engineer on some of Mr. Depp's films, said much the same thing. And by the way, Mr. Wyatt is not and never has been an employee of Mr. Depp. He's just worked with him on movies. Mr. Depp wasn't canceled by Hollywood because he was sometimes late to set. He was canceled because Ms. Heard falsely accused him of domestic violence and sexual violence on the pages of The Washington Post on December 18, 2018, repeating the prior lies of May 17th [sic], 2016. And as you saw at trial, Ms.

MR. CHEW: Heard published the op-ed on December 18, 2018, two years after her public allegations of domestic abuse. Ms. Heard's publication of the op-ed coincided with the release of her major movie Aquaman that December, and it coincided, as well, with her announcement on Twitter that she was becoming an ACLU ambassador for women's rights. And in that op-ed, Ms. Heard repeated her false allegations against Mr. Depp. Now, she didn't mention his name. She didn't have to. Everyone knew exactly who and what Ms. Heard was talking about. Ms. Heard got on the stand and tried to tell you that the op-ed was not about Mr. Depp. She then said, well, it wasn't just about Mr. Depp, but she couldn't deny, and this was yesterday, that this was at least partly about Mr. Depp. The op-ed obviously is about Mr. Depp, and the testimony at trial proves that. You will recall testimony from the ACLU's representative, an attorney, stating that Mr.

MR. CHEW: Depp's name was included in drafts of the op-ed and that they and others understood that the op-ed was about Mr. Depp. Specifically, the ACLU representative testified, among other things, "based on my review of prior drafts of the op-ed, I knew that they were -- that she was referring to Johnny Depp and the marriage." Ms. Heard's claim that the op-ed is not about Mr. Depp is just another one of her many, many lies. In fact, what you have seen time and time again, through the course of this trial, is that Ms. Heard lies. She lies all the time about things that are important and things that aren't important. She just can't seem to stop. And as Ms. Vasquez said, what she routinely does is she doesn't take ownership or responsibility for anything, and she has an excuse for everything. But in this courtroom, confronted with the evidence, she can't run away from her own words. As my colleague said, words matter, and Ms. Heard is condemned by her own words. So, Tom, let's please take a look at the words she used in her op-ed, which is Plaintiff's Exhibit 1, and which Ms.

MR. CHEW: Heard published in December 2018, two years after she first publicly accused Mr. Depp of being an abuser on May 27th, 2016. The title of the op-ed reads, as you can see, "Amber Heard: I spoke up against sexual violence and faced our culture's wrath. That has to change." Below that, Ms. Heard states "then two years ago, I became a public figure representing domestic abuse, and I felt the full force of our culture's wrath for women who speak out." And below that, Ms. Heard states "I have the rare vantage point of seeing, in real time, how institutions protect men accused of abuse." Each of those statements clearly refers to Ms. Heard's allegations against Mr. Depp. And taken collectively, their message and their implication about Mr. Depp is clear, i.e., that Ms. Heard is a survivor of domestic abuse and that Mr. Depp is a perpetrator. The context in the rest of the op-ed makes that clear as well.

MR. CHEW: Consider, for instance, this line: "Imagine a powerful man as a ship, like the Titanic. That ship is a huge enterprise. When it strikes an iceberg there are a lot of people on board desperate to patch up holes, not because they believe in or even care about the ship, but because their own fates depend upon the enterprise." Everyone in Hollywood knew, and everyone in this courtroom now knows exactly what Ms. Heard intended those words to mean. The ship, the Titanic, is Mr. Depp, and Ms. Heard was the iceberg that sank him. That's precisely what Ms. Heard was saying in the op-ed. And in just the same way, everyone in Hollywood knew -- Hollywood and elsewhere knew exactly what Ms. Heard meant by the words "two years ago, I became a public figure representing domestic abuse." two years earlier, on May 27th, 2016, as Ms. Vasquez said, that was six years to the day. That's when his life ended.

MR. CHEW: That was six years ago to this day, when Ms. Heard, on May 27th, 2016, walked into court with her public -- with her publicist, Jody Gottlieb, having tipped off TMZ, with an alleged mark on her face to accuse Mr. Depp of abuse. quite mindful of her image. She was careful to portray herself as the innocent representative of abuse survivors, and by implication, Mr. Depp as the perpetrator of domestic abuse. She was the woman who, in the words of her title, supposedly "spoke up against sexual violence." Now, Ms. Heard has done a lot to try to walk away from the title, in particular. That's true to form. She has testified that she didn't write it, and she will argue later that she shouldn't be held liable because she didn't write it. But as the Court's instructions, which you heard this morning, made clear, Ms.

MR. CHEW: Heard didn't have to personally write any part of the op-ed for her to defame Mr. Depp through implication in The Washington Post. And let's, please, Tom, turn to Plaintiff's Exhibit 3. Ms. Heard, as you all can see on the screen, retweeted the article, including the title, on her Twitter page. Ms. Heard put her name on it, and she proudly declared "Today, I published this op-ed in The Washington Post..." Her tweet included the title with the words "I spoke up against sexual violence," prominently featured. Nowhere in this tweet or anywhere else does Ms. Heard disavow the title. To the contrary. She's proclaiming it. At the same time Ms. Heard posted this tweet, she posted another, which you can see right beneath it. "I'm honored to announce my role as an ACLU ambassador on women's rights." Aggrandizing herself at the expense of Mr. Depp. So make no mistake, this was about Mr. Depp.

MR. CHEW: In the wake of the #MeToo movement, with her ACLU ambassadorship and a major movie coming out, Ms. Heard was trading on her accusations of abuse against Mr. Depp. She was reminding everyone of those allegations. She was, once again, taking on the role of her lifetime, the heroic survivor of domestic abuse, or to use her phrase, "a public figure representing abuse." And she was, once again, casting Mr. Depp as the villain in her drama, the supposed perpetrator of that abuse. When you meet to deliberate this case, you're going to be tasked with several questions. Those questions appear on a form that you will use to reach your verdict in this case. So I would just like to ask you, please, to spend a few minutes with me going through that. Tom, would you please put up the special verdict form so the jury can see it. It's a little bit hard to read, so, maybe, Tom, might, please, blow it up. Thank you very much. You will see here, the first page of the verdict form relating to Mr. Depp's claim for defamation against Ms. Heard. There are three pages relating to Mr.

MR. CHEW: Depp's claim, one for each of the three defamatory statements in the op-ed that form the basis of Mr. Depp's claim against Ms. Heard. You've heard those three statements many times, but they bear repeating, I promise, just once more, here. One, "I spoke up against sexual violence and faced our culture's wrath. That has to change." Two, "Then two years ago, I became a public figure representing domestic abuse, and I felt the full force of our culture's wrath for women who speak out." Three, "I had the rare vantage point of seeing, in real time, how institutions protect men accused of abuse." Now, there are seven questions that you will need to, please, answer with respect to each of those statements. So that's 21 questions, I think. That's 7 as to each statement. One, was the statement made or published by Ms. Heard? Two, was the statement about Mr. Depp?

MR. CHEW: Three, was the statement false? Four, did the statement have a defamatory implication about Mr. Depp? Five, was the defamatory implication designed and intended by Ms. Heard? Six, was the defamatory implication conveyed to someone other than Mr. Denn? Conveyed to someone other than Mr, Depp? Seven, did Ms. Heard make the statement with actual malice, which as Her Honor explained, means, did Ms. Heard make the statement knowing it was false or with reckless disregard as to the truth. Ladies and gentlemen, the evidence clearly shows that the answers to those seven questions are all yes. And if you answer yes to all of those questions, which you should, we respectfully submit, you will be asked to state the amount of damages to which Mr. Depp is entitled.

MR. CHEW: In the wake of the #MeToo movement, movie producers know better than to cast a movie star who has been accused of domestic and sexual violence. And it is entirely within your discretion, as jurors, to quantify the amount of money that constitutes fair compensation for Mr. Depp's pain and humiliation inflicted by Ms. Heard's defamation. But while Mr. Depp certainly is entitled to monetary compensation, this case, at least for Mr. Depp, has never been about money. This case, for Mr. Depp, has never been about money. Nor is it about punishing Ms. Heard. It is about Mr. Depp's reputation. And freeing him from the prison in which he has lived for the last six years, and it's six years to the day. The most important questions for Mr. Depp, the ones truly at the heart of this case are questions two, three, and four on the verdict form. And while Tom is pulling that up, let's take question 2. Were the statements about Mr. Depp? Yes. Two points here.

MR. CHEW: One, when the ACLU pitched the op-ed to The Washington Post, I think you'll remember this, they pitched it as "a piece by Amber Heard, who, as you know, was beaten up during her brief marriage to Johnny Depp." That's how they pitched it. Two, after the op-ed was published, news outlets, including USA TODAY, and you've seen that, that was the exhibit, characterized the op-ed as referring to Ms. Heard's allegations of abuse against Mr. Depp. So the USA TODAY interpreted it that way, and so did many other publications. They got exactly the implication that Ms. Heard and the ACLU intended them to have. Tom, if you would, please, pull up Plaintiffs Exhibit 409 and 411, if you could put them side by side.

MR. CHEW: And this was expected, this is what they wanted. There have been a lot of press, two years prior to the publication of the op-ed, about Ms. Heard's claims of abuse against Mr. Depp when she walked into court with her publicist to obtain the domestic violence -- the no notice ex parte, meaning Mr. Depp's lawyer was not informed and he was already in New York, which he testified Ms. Heard was well aware of. You don't need a domestic violence restraining order when your husband is halfway across the continent and is heading for a European tour.

MR. CHEW: On May 27th, 2016, with a purported mark on her face, everyone knew exactly who and what Ms. Heard was referring to in the op-ed. She was referring to Mr. Depp. Let's take questions two and three next, if we can. Were each of the statements false? And did the statements have a defamatory implication on Mr. Depp? Again, the clear answer is yes. The statements, understood in the context of the op-ed itself, and in the broader context of the press coverage of Ms. Heard walking into the court with a mark on her face to obtain a domestic violence restraining order against Mr. Depp in May of 2016, imply, clearly imply that Mr. Depp physically and sexually abused Ms. Heard.

MR. CHEW: The overwhelming evidence that you all have heard and has come forward in this case shows that those allegations are false, indisputably false. Mr. Depp did not physically abuse Ms. Heard. He did not sexually abuse Ms. Heard. You've heard audio after audio where Ms. Heard admits that she was physically abusing him. While Mr. Depp's name will be forever tarnished by these horrendous and false allegations, this case is about telling you his story and the truth about what really happened, which you've now heard. It is about restoring his lost reputation. It's about showing Mr. Depp's children, Lily-Rose and Jack, that the truth is worth fighting for. It is. And it's about restoring Mr. Depp's name and standing in the community to the fullest extent that he can. And you can do something. And only you, ladies and gentlemen, can do that for him. You heard from Mr.

MR. CHEW: Depp yesterday that he has been carrying these outlandish, outrageous stories on his back pretty stoically, and living with them for six years and waiting to be able to bring the truth back. And he has told you the truth, the unvarnished truth, even truth that could embarrass him. He knew that was going to happen when he brought this case. You've seen the evidence in this case over six long weeks, which we, again, thank you for. That evidence shows overwhelmingly that Ms. Heard's attempt to paint herself as a heroic survivor, an innocent survivor, and Mr. Depp as a terrifying abuser are utterly false. We ask you to, please, return your verdict for Mr. Depp. We ask you, we implore you to give him his name, his reputation and his career back. Thank you very much, ladies and gentlemen.

MS. VASQUEZ: I don't think so. It's still on, so that's a good thing.

MR. CHEW: Keep laughing. It's my fault

MS. VASQUEZ: Thank you, Your Honor.