10 h 27 mai 2021 ans - Depp v Heard Email ACLU to Jessica Meyers

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Michael Schwartz to

Counsel,

We have reviewed your Petition and the supporting memorandum of law and exhibits. While we disagree with many of your arguments, we believe there is no serious dispute on what donations were made to the ACLU by Ms. Heard or others on her behalf, and when those donations were made. We reiterate our position that Ms. Heard's donations are irrelevant to the issues in the Virginia litigation, but are willing to stipulate to the facts of the donations to avoid unnecessary burdens on our clients and the Court.

Attached is a draft stipulation that describes the dates and amounts of donations to the ACLU by Ms. Heard or others on her behalf, based on the ACLU's review of relevant books and records. Please let us know if you are willing to stipulate to these facts. As you know, our opposition is due on June 4, so please provide your position by close of business on Tuesday, June 1. We're available to discuss if it would be helpful.

Mike

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