12h 30min, jun 12, 2020 y - Depp v Heard EMAIL The Walt Disney Company to Amber Heard

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Disney to Amber Heard’s California lawyer, Davida Brook. There is no sign that this email was sent to any member of Johnny Depp’s legal team although at this point Team Depp were not making enquiries of Disney - that was all Team Heard on a fishing trip searching for reports of any medical issues or bad behaviour by Johnny Depp

From: Alec Myers, Disney
Date: June 12, 2020 at 3:59:21 PM PDT
To: Davida Brook, Susman Godfrey
Cc: Jennifer Coleman, Disney; Audra MacConnell, Disney; Sylvia Mares, Disney

Subject: Amber Heard v Johnny Depp II-Subpoena

Davida, following up our conversation yesterday, we can produce documents responsive to the following categories. Unless otherwise stated, the date limitation of these categories will be January 1, 2010 to present, consistent with the original subpoena:

1. Communications, by or to individuals with input into casting of the sixth Pirates of the Caribbean movie, referencing Amber Heard and Johnny Depp.

2. Communications, by or to individuals with input into casting of the sixth Pirates of the Caribbean movie, referring or relating to the Op Ed first published in the Washington Post on December 18, 2018 (online), titled, "Amber Heard: I spoke up against sexual violence - and faced our culture's wrath. This has to change," or issues discussed therein, during the period of time after it was published and before Disney first made publicly known - in a December 20, 2018 news article - that it would not be recasting Mr. Depp for a future Pirates of the Caribbean movie.

3. Contracts with or relating to Mr. Depp and the Pirates of the Caribbean franchise, dated January 1, 2015 to present.

4. Non-privileged documents or communications concerning any insurance policy or claims relating to any performance by Mr. Depp from January 1, 2015 to present.

If this is not consistent with your understanding of our conversation, please let me know and we can have another conversation. Otherwise, we should be in a position to produce responsive documents shortly.

We do not require another subpoena if we are in agreement on this refinement of the original subpoena. We agree that any deadline to move to compel will run from two business days after we produce responsive documents. Finally, we may need to withhold some documents until we receive a HIPPA waiver from you.

Alec Myers
Principal Counsel
The Walt Disney Company

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