I, Amber Heard of---------, LA CA 90067 WILL SAY AS FOLLOWS
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I am an actor, model and activist.
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The facts and matters set out in this statement are within my own knowledge unless otherwise stated, and I believe them to be true. Where I refer to information supplied by others, a source of the information is identified. Facts and matters derived from these other sources are true to the best of my knowledge and belief.
Various documents and photographs: Core Trial Bundle
3. I have been shown the core trial bundle index and I have reviewed the following material in the trial bundle and confirm:
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Tab 121: These are text messages between Lily-Rose Depp and me;
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Tab 126(a): This is an email from me to Dr Kipper;
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Tab 142: These are emails between Marty Singer and me;
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Tab 143: This is an email from Josh Drew to me, with an account from Josh Drew
and Raquel (“Rocky”) Pennington attached;
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Tab 148: This tab is listed as including various photographs, which I have reviewed
and confirm:
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(i) F894.001: I took this photo of my injuries after a spate of attacks by Johnny in March 2013;
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(ii) F894.003: I took this photo of Johnny’s drugs in the bathroom at Disneyland for his film premiere; and
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(iii) F894.005 – F894.009: I took these pictures of Johnny passed out in our hotel room in Tokyo.
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Tab 148(a): This tab is listed as including various photographs, which I have reviewed and confirm:
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(i) F894.012: This is a picture I took of the weed at Johnny’s house;
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(ii) F894.014 – F894.018: These are pictures I took of Johnny with his weed;
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(iii) F894.020: I took this picture of Johnny smoking hash;
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(iv) F894.022: This is a picture I took of the injury to my face after an incident
after the Met Gala at our hotel in New York, in which Johnny punched me and caused damage to the hotel room;
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(v) F894.024 and F894.026: I took these pictures of Johnny passed out after taking opiates at our downtown apartment;
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(vi) F894.028 – F894.046: These are a series of photos that were taken of me by Johnny while on the island for his detox in 2014, where there is a visible scratch on my face, caused by Johnny during his detox; and
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(vii) F894.048: This is a screenshot of text messages between Debbie Lloyd and me about medicine dosage for Johnny.
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Tab 148(b): This tab is listed as including various photographs, which I have reviewed and confirm:
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(i) F894.049: This is a photo I took of the mirror in master bathroom in the house in Australia, showing where Johnny had written on the mirror with blood, paint and my lipstick;
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(ii) F894.050: This is another photo I took of another bathroom mirror in the house in Australia which he had painted on;
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(iii) F894.051: This is a photo that was taken of me by my lawyer showing the scars on my arm from the incident in Australia in March 2015;
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(iv) F894.053: This is a photo I took of the mirror in master bathroom in the house in Australia, showing where Johnny had written on the mirror with blood, paint and my lipstick;
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(v) F894.055 – F894.067: These are photos that I believe I took of Johnny with his injured finger at his doctor’s office in LA before he had surgery;
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(vi) F894.069: This is a photo I believe I took of Johnny at his doctor’s office;
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(vii) F894.071 – F894.075: These are screen grabs (i.e. photos) of the messages my sister, Whitney Henriquez, sent to Kevin Murphy after the stairs
incident in March 2015, which she took on her phone and sent to me.
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Tab 148(c): This tab is listed as including various photographs, which I have reviewed and confirm:
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(i) F894.095: This is a photo I took of the message Johnny wrote on the counter-top in our apartment after the 15 December 2015 incident;
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(ii) F894.097 – F894.101: These are photos taken on my phone by me or Rocky Pennington of the damage in my apartment after the 15 December 2015 incident;
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(iii) F894.103 – F894.120: This is a series of photos of the injuries to my face, my temple, my lip taken by Rocky Pennington after the 15 December 2015 incident;
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(iv) F894.122: This is a photo Rocky took of my hair on the floor after the 15 December 2015 incident;
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(v) F894.124: This is a picture of the injuries to my face taken by Rocky after the 15 December 2015 incident;
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(vi) F894.126 – F84.130: This is a series of pictures I took of myself after an incident in which Johnny hit me in January 2016; and
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(vii) F894.132 – F894.147: This is a series of pictures that Rocky Pennington took of my injuries from the 15 December 2015 incident.
i. Tab 148(e): This tab is listed as including various photographs, which I have reviewed and confirm:
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(i) F894.155 – F894.175: This is a series of photos that were taken of me by Rocky Pennington after the incident in May 2016;
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(ii) F894.177 – F894.201: This is a series of photos that I took after the incident in May 2016, which show the damage Johnny caused to our apartment;
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(iii) F894.202 – F894.222: This is a series of photos that were taken of me by Rocky Pennington after the incident in May 2016;
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(iv) F894.224 – F894.232: This is a series of photos taken of Rocky and I at her bead show after the May 2016 incident;
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(v) F894.234: This is the picture that was taken of me together with Amanda de Cadenet and Amber Valletta at Amanda de Cadenet’s birthday party after the May 2016 incident;
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(vi) F894.235 – F894.257: This is a series of pictures taken of me at the courthouse on the day that I obtained the restraining order against Johnny;
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(vii) F894.249 – F894.555: This is a series of pictures Rocky and I took together
at home; and
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(viii) F894.257 – F894.259: These are photos that I took of my injuries after the
May 2016 incident.
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Tab 196: This is described in the index as journal entries and transcript, but I do not have the original journal entry, only a word document providing what appears to be a transcript, so cannot say if this is an accurate reflection of what Johnny and I wrote in his journal;
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Tab 197: This is the original and transcript version of journal entries made by me and Johnny in his journal;
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Tab 198(a): This is my tweet, where I share our joint divorce statement;
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Tab 198(b): This is my tweet about becoming an ambassador for ACLU; and
Text Messages: Section H, Supplemental Trial Bundle
4. I have been shown the supplemental trial bundle index and I have reviewed the following material in section H of the supplemental trial bundle (H1-H82; H102- H134.1; H136-192; H194; H198-206; H680-H697) and confirm that I have looked at these messages and they are all messages from me to the individuals specified in the index on the time and date specified, except that I cannot be sure that these are the only text messages between myself and each person on the specified dates. To clarify a few points on the index for section H where some information was missing:
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Tab 14, H82: This is a text messages between iO Tillet Wright and me (iO calls me “Slim Slam”;
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Tab 36, H161: These are text messages between Tasya van Ree and me;
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Tab 37, H162: These are text messages between Elon Musk and me;
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Tab 62, H687-697: These appear to be screenshots of my messages with Christian
Carino, who is an agent at Creative Artists Agency (CAA), and used to represent me on commercial endorsements. I also considered Christian to be a friend and he arranged the mediation attempt between Johnny and me in San Francisco on 21- 22 July 2016. I later learned that, after this mediation attempt, Christian became Johnny’s agent (Johnny moved from United Talent Agency (UTA) to CAA).
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I would like to note that, in respect of Tab 53, H197, I do not recognize this document, though it appears to be a draft email from my inbox with no marked sender. I do not recognize the language as being mine or remember the context in which I would have written this.
Emails: Section I, Supplemental Trial Bundle
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I have been shown the supplemental trial bundle index and I have reviewed the following material in section I of the supplemental trial bundle (I1-I16; I19-I47) and confirm that I have looked at these emails and they are all emails from me to the individuals specified in the index on the time and date specified, except that I cannot be sure that these are the only emails between myself and each person on the specified dates. To clarify a few points on the index for section I:
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Tab 65, I4-I5: The date range for this email exchange was 14-17 November 2013;
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Tab 79, I29: This was a draft statement that Amanda de Cadenet was considering in relation to the photograph she had posted of me on her social media at her
birthday party;
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Tab 80, I30-31: This was a letter I had written to Johnny about what had happened
on 20 February 2016 but did not feel able to send;
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Tab 81, I32: This was another letter that I had written to Johnny about what was
happening at that time, but did not feel able to send; and
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Tab 85, I44: This is incorrectly described in the index. It is in fact an email from me
to my publicist, Jodi Gottlieb, forwarding an email from Tasya van Ree in which she provides a statement about the 2009 incident.
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Photographs: Section J, Supplemental Trial Bundle
7. I have been shown the supplemental trial bundle index and I have reviewed the following material in section J of the supplemental trial bundle (J1-J8; J10-J47) and confirm that I have looked at these photographs and confirm they are photographs of me or photographs I recognize on the time and date specified that were either taken by me or others. To clarify a few points on the index for section J:
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Tab 87, J1.1-J1.3: These photographs were taken by me in a hotel room in New York of the property damage caused by Johnny on 5 May 2014;
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Tabs 88-90, J2-J4.5: These are photographs taken of me by Rocky Pennington after the incident on 15 December 2015;
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Tab 91, J5: This is a photograph I took of my injury after Johnny hit me in January 2016;
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Tab 92, J6: This photograph is marked in the index as 21 May 2016, but is in fact a photograph which was taken of me by Rocky on the night of 16 December 2016 after the 15 December incident (J7-J8 appear in the same tab, which are the same pictures taken on the night of 21 May 2016);
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Tab 94, J10: This is the same photograph taken on the evening of 21 May 2016, though this version is a screengrab of that photo;
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Tab 95, J11-J42: This tab includes numerous photographs from various events over the course of our relationship, which are marked in the index as undated, which I am able to identify:
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(i) J11: This is a photograph I took of my injuries after a spate of attacks in March 2013;
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(ii) J12-J26: These are photographs that were taken after the 15 December incident;
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(iii) J 27: I took this of my injuries on 6 January 2016;
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(iv) J28: I took this picture on 28 May 2016 of the bruises on my legs
from the incident on the evening of 21 May 2016;
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(v) J30-31: I took this, a closer up picture, of my face on 22 May 2016;
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(vi) J32: This is the picture at J11 again, from March 2013;
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(vii) J 33-34: This photograph was taken on 22 May 2016, after the 21
May 2016 incident, of the injury to my face;
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(viii) J35: This is a picture of my hair on the floor after the 15 December
2015 incident, which was taken by Rocky;
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(ix) J36: This picture was taken of me by Rocky on 16 December 2015;
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(x) J37: This picture was taken of me by Rocky on 21 May 2016;
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(xi) J38: This is a picture of my hair on the floor after the 15 December
2015 incident taken by Rocky;
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(xii) J39: This is a picture I took of a note Johnny wrote me on a coaster
(“I love you Slim, dead or alive”) during our attempt to privately
mediate on 22 July 2016;
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(xiii) J40-J42: These are pictures of the bruising to my legs from the
incident that began with the capturing of Johnny in the kitchen (the video that ended up being leaked and published by TMZ) which was, to the best of my recollection, sometime in February 2016.
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I understand there are more documents to go into the trial bundle and I will review them as soon as I am told there is an agreed index.
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During the course of reading through these materials, I have now realized I cannot be sure that the painting incident took place on 8 March 2013. There were numerous incidents of violence in March 2013 and many fights over that month about the painting. While the incident is as I have described it in my statement and was around that time, I cannot say for certain it was on 8 March 2013. Similarly, the incident at Hicksville took place as I described in my statement, but it may have been at the very end of May or early June.
STATEMENT OF TRUTH
I believe that the facts stated in this witness statement are true I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
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Amber Heard
4 July 2020
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