8h 10min, aug 11, 2020 y - Adam Waldman Twitter "You know I hate, detest, and can't bear a lie" Jen Robinson

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From: Jennifer Robinson
Sent: Monday, March 2, 2020 12:37 PM
To: Lee A. Sherman <La
Subject: Depp v NGN - Laura Divenere

Dear Lee

Thank you for making the time to speak today - and my sincere condolences again.

As discussed, having Laura deposed in the US proceedings does not remedy the issue with respect to the UK proceedings. As I understand it, our US team has no plans to depose her at present and, in any event, her deposition transcript would not serve as evidence in the UK proceedings so doesn't answer the problem we have in the UK (with trial due to commence on 23 March, so a very tight timeframe to remedy the issue). Depp's team is seeking to have Laura's earlier declaration (attached) admitted as hearsay evidence, giving no indication to the court that Laura herself disputes it. Do you know if they are aware of or on notice of the issue?

This means that it will be used to undermine NGN's case —and Amber's own evidence. It will also be public, used in open court, and reported around the world. I know from my discussion with Laura that she doesn't want that to happen and was very upset about what happened before. The declaration they are seeking to admit has Laura saying that Amber had not ever mentioned to her any abuse or violence (see [6]).

You have a copy of the amended draft declaration we had prepared with her after she reached out to Amber with concern when her declaration went public. I understood from you on our first call that it had accurately reflected what Laura would say, if deposed - making clear that the original declaration does not properly reflect her evidence (including that Amber did, in fact, tell her about the abuse in 2016 and that she believed her) and that she felt pressured to sign it.

The easiest and most direct way forward would be to submit that or some version of it you are comfortable with (which can of course be reviewed and agreed by you), in the format of a witness statement for UK proceedings, which Laura could sign and submit. In our system, it serves as evidence in chief. If Laura was not willing to give evidence by video-link (witnesses are typically expected to give evidence live - and be cross examined), then the effect of the statement would be to at least remedy/head off the evidential damage done by Depp's attempt to admit her earlier declaration. Of course, NGN would ideally like her to give evidence and that would be best, but that is a matter for you as to whether she would be willing to do so (I understand that they have instructed US counsel and may be in touch). If she doesn't give live evidence, her statement will still have the effect of nullifying Depp's effort to rely on the attached declaration.

I would be happy to speak on the phone anytime to answer your queries - please pass Laura my best.

Jen

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