May 2005
Nov. 2008
Mar. 2013
March 2013
Amber Heard
incidents of violence in March 2013 and many fights over that month about the
8 March 2013
Amber Heard
sure that the painting incident took place on 8 March 2013. There were numerous
8 March 2013
Amber Heard
sure that the painting incident took place on 8 March 2013. There were numerous
March 8, 2013
Josh Drew
1 2013, Los Angeles, California." 02:58
2 Then on page 2, it says, "March 8, 2013,
3 Los Angeles, California."
4 Later on that same page, page 2, "May 24,
5 2014, flight from Boston, Massachusetts, to 02:58
6 Los Angeles, California."
7 Were you later, once you had started to
8 date Rocky, made aware of any of those incidents?
9 A The only one would be the -- the flight
10 from Boston. 02:58
11 Q Okay. And how did you become aware of
12 that?
13 A I honestly couldn't tell you the exact
14 circumstance that predicated it, and honestly, I
15 couldn't tell you whether it was early on in the 02:58
16 relationship or whether it came up following that
17 final May 21st incident.
18 I'm -- I'm trying to take myself out of
19 it, because, obviously, reading the context adds
20 information to it. The only thing that I really was 02:59
21 told at that time was that they had had an argument.
22 It was related to one of her projects and that at a
23 certain point, he kicked her.
24 And it was in -- one of the few incidents
25 that actually happened in front of people that 02:59
Page 157
9 March 2013
Amber Heard
The day after the painting incident (9 March 2013), I sent a text to Kate, telling her
10 March 2013
Amber Heard
41. On 10 March 2013 I told Kate about Johnny hitting me after being upset about Tasya.
22 March 2013
Amber Heard
March 2013 took place on 22 March 2013. There was a separate incident on 8 March
22 March 2013
Amber Heard
March 2013 took place on 22 March 2013. There was a separate incident on 8 March
Jun. 2013
June 2013
Amber Heard
21. In June 2013, in the early days of our relationship, Johnny and I were in Hicksville,
June 2013
Kristina Sexton
on a trip we took to Hicksville for his birthday in June 2013. We were all staying at this
Aug. 2013
August 2013
Amber Heard
42. There was at least one distinct conversation at my house. Around July or August 2013
Sep. 2013
September 2013
Whitney Henriquez
before they got engaged in September 2013, I saw that her face was swollen and she
September 2013
Whitney Henriquez
September 2013, I felt sick about it when she called to tell me. I told her it was a bad
September 2013
Whitney Henriquez
discuss the fact he was hitting her until sometime between March and September 2013.
September 2013
Whitney Henriquez
It was only sometime after this, but before we travelled to London in September 2013,
September 2013
Amber Heard
September 2013. I was impressed with Savannah�s work ethic and enthusiasm as an
Nov. 2013
November 2013
Amber Heard
to the US with me in November 2013 and then returned to the UK. Savannah then
17 November 2013
Amber Heard
a. Tab 65, I4-I5: The date range for this email exchange was 14-17 November 2013;
Dec. 2013
December 2013
iO Tillet-Wright
7. From October through December 2013, I spent a lot of time with Johnny while Amber
8 December 2013
Amber Heard
3.3 Tab 148(g): I took this picture of Johnny with Doug Stanhope on 8 December 2013;
Mar. 2014
March 2014
Amber Heard
came to the US in late March 2014 and stayed with me whilst I was working on a film
May 2014
24 May 2014
Amber Heard
44. On 24 May 2014, I texted Kate about the Boston plane incident. I wrote �I have to leave
May 25, 2014
Josh Drew
me on May 25, 2014 to pass along Johnny's apologies for his behavior during the flight. Stephen
May 25, 2014
Josh Drew
me on May 25, 2014 to pass along Johnny's apologies for his behavior during the flight. Stephen
Jun. 2014
Aug. 2014
August 2014
Amber Heard
island for him to detox in August 2014. I don�t believe she was around or nearby during
August 17, 2014
Josh Drew
On August 17, 2014, while in the Bahamas, Johnny and I got into a fight during
August 17, 2014
Josh Drew
On August 17, 2014, while in the Bahamas, Johnny and I got into a fight during
Nov. 2014
November 2014
Whitney Henriquez
15. One example of this that I remember was after a fight they had in November 2014.
Dec. 2014
December 2014
Amber Heard
around December 2014. She noticed a scratch above my eye, touched it gently and
8 December 2014
Amber Heard
Kate also texted me on 8 December 2014 asking me �Love you sweetie- are u ok? Is
Jan. 2015
January 2015
Amber Heard
his doctors Connell Cowan and David Kipper from January 2015 (AH5/1-3) where Dr
Feb. 2015
February 2015
Whitney Henriquez
But it was before their wedding in February 2015 � so this was sometime in 2014 after
February 2015
Amber Heard
97. Johnny and I got married in February 2015. We fought on our wedding night over his
February 2015
iO Tillet-Wright
I attended Amber and Johnny�s wedding in the Bahamas in February 2015 as Amber�s
Mar. 2015
March 2015
Josh Drew
10 A Okay. 03:16
11 Q The declaration.
12 The next incident that's described is on
13 page 6. It says, at the top, "March 2015,
14 Los Angeles."
15 And, again, keeping in mind the same 03:16
16 instruction I gave you earlier, Mr. Drew, separate
17 and apart from whatever you may have learned from
18 reading this document, did you know about this event
19 prior to the deposition?
20 A I don't have any recollection of this 03:16
21 event.
22 Q Okay. Same thing for the next one, which
23 is just a small paragraph where it says, "August
24 2015, Thailand and Malaysia."
25 A Only thing I know is that they did take 03:17
March 2015
Amber Heard
throw anything at him during the March 2015 staircase incident. I recall that Johnny
March 3, 2015
Josh Drew
On March 3, 2015, I arrived in Australia to meet Johnny after I had been filming a
Apr. 2015
21 April 2015
Amber Heard
56. On 21 April 2015 Johnny chartered a private plane to Australia where he was filming
May 2015
May 2015
Amber Heard
59. In about May 2015 the Australian authorities were made aware that we had imported
Jun. 2015
Jul. 2015
July 2015
Amber Heard
therefore must have taken place on 26/27 July 2015, not August 2015 as I say in my
Aug. 2015
August 2015
Amber Heard
therefore must have taken place on 26/27 July 2015, not August 2015 as I say in my
August
24 2015
Josh Drew
10 A Okay. 03:16
11 Q The declaration.
12 The next incident that's described is on
13 page 6. It says, at the top, "March 2015,
14 Los Angeles."
15 And, again, keeping in mind the same 03:16
16 instruction I gave you earlier, Mr. Drew, separate
17 and apart from whatever you may have learned from
18 reading this document, did you know about this event
19 prior to the deposition?
20 A I don't have any recollection of this 03:16
21 event.
22 Q Okay. Same thing for the next one, which
23 is just a small paragraph where it says, "August
24 2015, Thailand and Malaysia."
25 A Only thing I know is that they did take 03:17
Sep. 2015
September 2015
Whitney Henriquez
job she took. For example, I was with them in Brazil in September 2015 when they had
13 September 2015
Amber Heard
to me dated 13 September 2015 when we were talking about him being passed out
26 September 2015
Amber Heard
5. This recording is from 26 September 2015 (TB/File 4 Tab 154) and it was recorded
Oct. 2015
October 2015
Amber Heard
proceedings about the dogs in October 2015. This is not true and makes no sense,
11 October 2015
Amber Heard
his statement, Kevin refers to Marty�s email to me of 11 October 2015 at 07.29. I
Nov. 2015
Dec. 2015
December 2015
Amber Heard
in Dr Kipper�s office when I went there for a concussion check after the December 2015
December 2015
Amber Heard
evaluation that was carried out back in December 2015, and in which I explain that at
December 2015
Amber Heard
13. He says that, during the December 2015 incident, I violently attacked him and
December 2015
Josh Drew
10 BY MS. KAPLAN: 03:30
11 Q Did you personally observe that day this
12 injury on Ms. Heard's face --
13 A I did.
14 Q -- on December -- in December 2015?
15 A I did. 03:30
16 Q Thank you.
17 And you said before, you were there when
18 Ms. Pennington was taking the photos?
19 A Yes.
20 Q Was there any discussion -- well, 03:30
21 withdrawn.
22 There's a couple more photos in there. It
23 looks like there's a busted lip. Do you see those
24 photos?
25 A Yes. 03:31
15 December 2015
Amber Heard
137. This happened on the night of 15 December 2015. This was one of the worst and most
December 15, 2015
Josh Drew
cheek, chin and nose from an incident that took place on December 15, 2015.
15 December 2015
Amber Heard
24. Things were bad between Johnny and me after the 15 December 2015 incident in our
15 December 2015
Whitney Henriquez
about the fight on 15 December 2015 at that point because Amber and I were not
15 December 2015
Amber Heard
24. Except for after the violence on 15 December 2015, I didn�t seek medical treatment for
Jan. 2016
January 2016
Whitney Henriquez
Wright was �banned� by Johnny too. At some point in January 2016, I sought
January 2016
iO Tillet-Wright
52. Sometime after this, in late January 2016, Amber and I took a trip together to Palm
January 2016
Whitney Henriquez
in early January 2016 (sometime before the Art of Elysium charity event I was working
Feb. 2016
Apr. 2016
April 2016
Amber Heard
22. Sometime before my birthday in April 2016, I remember that I had to postpone an
April 2016
Amber Heard
16. I did not punch Johnny after my birthday party in April 2016, as he alleges. I did not
April 21, 2016
Josh Drew
10 transpired. I know that after the fact, they had 04:09
11 made a call to one of the nurses. I don't remember
12 whether it was Aaron or whether it was the other
13 one, whose name escapes me, to do a concussion check
14 over the phone, and they talked about her going to
15 see Dr. Kipper, but I don't actually know what 04:09
16 happened after the fact.
17 MR. CHEW: Move to strike. Lack of
18 personal knowledge by the witness's own admission.
19 BY MS. KAPLAN:
20 Q I'm going to turn now to the incident on 04:10
21 April 21, 2016 in connection with Ms. Heard's
22 birthday party. I think it was a 30th birthday
23 party.
24 And there's been a lot of -- today a lot
25 of kind of disjointed -- and that -- that's -- no 04:10
April 21, 2016
Josh Drew
Our la s t inte ra ction ha d be e n a t my pe nthous e on April 21, 2016, a nd involve d a n
April 21, 2016
Josh Drew
Our la s t inte ra ction ha d be e n a t my pe nthous e on April 21, 2016, a nd involve d a n
21 April 2016
Raquel Pennington
24. 21 April 2016 was the day of Amber�s birthday party. We had a small gathering planned,
21 April 2016
Amber Heard
148. On 21 April 2016 I was having my 30th birthday party with friends at the penthouse.
21 April 2016
iO Tillet-Wright
I was not at Amber�s birthday party on 21 April 2016, but I was told about it the next day,
April 21, 2016
Josh Drew
1 vein. 11:43
2 There were other times when things were
3 not good, and there were arguments, or there were
4 fights, and things were not going well. And the
5 context varied based on circumstances. 11:43
6 Q Mr. Drew, moving to April 21, 2016, do you
7 recall that there was to have been a birthday
8 celebration that night?
9 A Yes.
April 22, 2016
Josh Drew
Heard punching me in the face on or about April 22, 2016. This photograph was taken by my
April 22, 2016
Josh Drew
Heard punching me in the face on or about April 22, 2016. This photograph was taken by my
April 22, 2016
Josh Drew
This photogra ph wa s ta ke n by S e a n Be tt on April 22, 2016 a fte r I re turne d to my We s t
22 April 2016
Amber Heard
April 2016/early morning of 22 April 2016. Johnny had thrown my phone out of the
May 2016
May 2016
Amber Heard
proceedings (TB/ File 4 Tab 155). I think the date of the call was around late May 2016.
May 2016
Kristina Sexton
May 2016, and the police had been called and she decided to leave, it was like there was
21 May 2016
Raquel Pennington
at that time, let alone in Amber�s bed. I understand that, during the 21 May 2016 incident
21 May 2016
Raquel Pennington
at that time, let alone in Amber�s bed. I understand that, during the 21 May 2016 incident
21 May 2016
Amber Heard
d. Tab 92, J6: This photograph is marked in the index as 21 May 2016, but is in fact a
21 May 2016
Amber Heard
d. Tab 92, J6: This photograph is marked in the index as 21 May 2016, but is in fact a
21 May 2016
Amber Heard
d. Tab 92, J6: This photograph is marked in the index as 21 May 2016, but is in fact a
21 May 2016
Amber Heard
155. The next time I saw Johnny was on 21 May 2016 when we met at the apartment to
May 21, 2016
Josh Drew
10 say it was between three and five months after that 11:24
11 May 21st incident.
12 Q Is it your understanding that Mr. Depp and
13 Ms. Heard separated on or after May 21, 2016?
14 A I'm aware of that, yes.
15 Q Did Mr. Depp ever come -- well, I'm 11:24
16 getting ahead of myself.
17 Have you ever lived at a building located
18 at 849 South Broadway in Los Angeles, known as the
19 Eastern Columbia Building?
20 A Correct. 11:24
21 Q Did you live in the condo known as
22 Penthouse 1?
23 A Correct.
24 Q With whom did you live in the Penthouse 1?
25 A Raquel Pennington. 11:24
May 21, 2016
Josh Drew
10 Q Okay. Okay. Sit -- sitting here today, 01:55
11 do you have any reason to believe that this is not
12 her signature?
13 MS. VIGLIETTA: Objection. Foundation;
14 speculation.
15 BY MR. CHEW: 01:56
16 Q All right. Well, let's -- let's go to the
17 one question I -- I really have about this document,
18 which is paragraph 4. She testifies --
19 A On which page?
20 Q On page 1. 01:56
21 Ms. Pennington testifies:
22 "On May 21, 2016, I was in my condominium
23 with Joshua when I received a text message
24 from Amber at approximately 8:06 p.m.,
25 asking me to come over to her condominium 01:56
21 May 2016
Amber Heard
d. Tab 92, J6: This photograph is marked in the index as 21 May 2016, but is in fact a
May 21, 2016
Josh Drew
1 Q What -- what, again, was his role? 11:58
2 A I believe he was Johnny's house manager.
3 Q Did you have good interactions with him?
4 A Always.
5 Q Was he a pleasant person? 11:59
6 A Yes.
7 Q To your knowledge, was he an honest
8 person?
9 A To me, yes. I know there had been some
10 friction with -- with a variety of people in 11:59
11 Johnny's life, but I was never present or privy to
12 it. I always had pleasant interactions with him.
13 Q Understanding that you weren't with him
14 all the time, did you ever know Mr. Murphy to lie to
15 anyone? 11:59
16 A I don't want to answer that. That's going
17 to force me to speculate.
18 Q Okay. Well, your -- your lawyer is not
19 going to allow you to speculate.
20 Without speculating, can you cite any 11:59
21 example of him lying to someone?
22 A No.
23 Q Mr. Drew, let's please change subjects and
24 move to the evening of May 21, 2016, which you had
25 referenced previously. 11:59
23 May 2016
Amber Heard
marriage on 23 May 2016, and on 27 May 2016 I filed an application for a domestic
27 May 2016
Amber Heard
marriage on 23 May 2016, and on 27 May 2016 I filed an application for a domestic
27 May 2016
Amber Heard
restraining order (TRO) against Johnny (I was granted the TRO on 27 May 2016). In
27 May 2016
Raquel Pennington
3. On 27 May 2016 I gave evidence in a declaration in support of Amber Heard�s request for
30 May 2016
Amber Heard
message I sent to Lisa Beane on 30 May 2016 in which I asked for the medical
Jun. 2016
June 2016
Amber Heard
78. This June 2016 publication of the 2009 event started a harassment campaign of people
June 2016
Amber Heard
circulating in the media in June 2016, about a week after I filed for the temporary
16 June 2016
Raquel Pennington
4. On 16 June 2016 and 14 July 2016 I testified in a deposition in the divorce case between
Jul. 2016
14 July 2016
Raquel Pennington
4. On 16 June 2016 and 14 July 2016 I testified in a deposition in the divorce case between
22 July 2016
Amber Heard
22 July 2016. I later learned that, after this mediation attempt, Christian became
Aug. 2016
August 13, 2016
Josh Drew
deposed on or about August 13, 2016. Ms. Heard admitted to some of these acts of violence
Dec. 2016
16 December 2016
Amber Heard
photograph which was taken of me by Rocky on the night of 16 December 2016
Dec. 2017
Dec. 2018
28 December 2018
Amber Heard
28 December 2018. I had emailed her a link to the article in the Washington Post that
Apr. 2019
Jul. 2019
July 2019
Amber Heard
media in July 2019 (see for example the article in The Blast dated 15 July (TB/File 5
Nov. 2019
November 19, 2019
Josh Drew
1 Irvine, California
2 Tuesday, November 19, 2019; 11:08 a.m.
3
4 THE VIDEOGRAPHER: Good morning. We are
5 on the record. This is the recorded videotaped
6 deposition of Joshua Drew in the matter of John C.
7 Depp v. Amber Laura Heard.
8 This deposition is taking place at 2211
9 Michelson Drive, 7th floor, Irvine, California,
10 92612 on November 19th, 2019, at 11:08 a.m.
11 My name is Joshua Yasko. I'm the legal
12 videographer with Veritext. Video and audio
13 recording will be taking place unless all counsel
14 have agreed to go off the record.
15 Would everyone please introduce themselves
16 beginning with the witness.
17 THE WITNESS: Joshua Drew.
18 MS. VIGLIETTA: Emily Viglietta, attorney
19 for nonparty Joshua Drew.
20 MS. BROOK: Davida Brook of Susman Godfrey
21 on behalf of the Defendant Amber Heard.
22 MS. GOODARZI: Mona Goodarzi, associate at
23 Brown Rudnick.
24 MR. RAWLINSON: Tom Rawlinson, associate
25 at Kaplan Hecker & Fink.
November 19, 2019
Josh Drew
1
2
3 Confidential Video Deposition of JOSHUA
4 DREW, taken on behalf of Plaintiff, at 2211
5 Michelson Drive, 7th Floor, Irvine, California,
6 beginning at 11:08 a.m. and ending at 6:22 p.m. on
7 Tuesday, November 19, 2019, before Michelle Bulkley,
8 Certified Shorthand Reporter Number 13658.
9 * * *
19 November 2019
Josh Drew
4. I was deposed on 19 November 2019 in John C. Depp v Amber Laura Heard Civil Action
November 19, 2019
Josh Drew
1 DECLARATION OF PENALTY OF PERJURY
2
3
4
5 I, JOSHUA DREW, do hereby certify under penalty
6 of perjury that I have read the foregoing transcript
7 of my deposition taken on November 19, 2019; that I
8 have made such corrections as appear noted herein;
9 that my testimony as contained herein, as corrected,
10 is true and correct.
11
12
13 DATED this _____ day of _____________, 20_____,
14 at __________________________________, California.
15
16
17
18 _______________________
19 JOSHUA DREW
20
21
22
23
24
25
November 25, 2019
Josh Drew
1 I, the undersigned, a Certified Shorthand
2 Reporter of the State of California, do hereby
3 certify:
4 That the foregoing proceedings were taken
5 before me at the time and place herein set forth;
6 that any witnesses in the foregoing proceedings,
7 prior to testifying, were administered an oath; that
8 a record of the proceedings was made by me using
9 machine shorthand which was thereafter transcribed
10 under my direction; that the foregoing transcript is
11 a true record of the testimony given.
12 I further certify that I am neither
13 financially interested in the action nor a relative
14 or employee of any attorney or any party to this
15 action.
16 IN WITNESS WHEREOF, I have this date
17 subscribed my name.
18 Dated: November 25, 2019
19
20
21
22 <%1482,Signature%>
23 MICHELLE BULKLEY
24 CSR No. 13658
Dec. 2019
4 December 2019
Amber Heard
Defendants in this action, has provided a witness statement dated 4 December 2019
15 December 2019
Amber Heard
70. I refer to paragraph 135 of my statement dated 15 December 2019. At (AH/32-36) is a
15 December 2019
Amber Heard
2. In this claim I have approved and signed a witness statement dated 15 December 2019
Feb. 2020
12 February 2020
Josh Drew
Name: Joshua Drew
Party: Defe ndants
Exhi bit JD 1
Date: 12 February 2020
25 February 2020
Amber Heard
16. At paragraph 21 of his third witness statement dated 25 February 2020, Johnny lays
26 February 2020
Amber Heard
Name: Amber Heard
Statement: Third
Party: Defendants
Exhibit AH 3
Dated 26 February 2020
26 February 2020
Amber Heard
Name: Amber Heard
Statement: Third
Party: Defendants
Exhibit AH 3
Dated 26 February 2020
26 February 2020
Amber Heard
Name: Amber Heard
Statement: Third
Party: Defendants
Exhibit AH 3
Dated 26 February 2020
26 February 2020
Amber Heard
Name: Amber Heard
Statement: Third
Party: Defendants
Exhibit AH 3
Dated 26 February 2020
26 February 2020
Amber Heard
Name: Amber Heard
Statement: Third
Party: Defendants
Exhibit AH 3
Dated 26 February 2020
26 February 2020
Amber Heard
Name: Amber Heard
Statement: Third
Party: Defendants
Exhibit AH 3
Dated 26 February 2020
26 February 2020
Amber Heard
Name: Amber Heard
Statement: Third
Party: Defendants
Exhibit AH 3
Dated 26 February 2020
26 February 2020
Amber Heard
Name: Amber Heard
Statement: Third
Party: Defendants
Exhibit AH 3
Dated 26 February 2020
26 February 2020
Amber Heard
Name: Amber Heard
Statement: Third
Party: Defendants
Exhibit AH 3
Dated 26 February 2020
26 February 2020
Amber Heard
Name: Amber Heard
Statement: Third
Party: Defendants
Exhibit AH 3
Dated 26 February 2020
Mar. 2020
Apr. 2020
3 April 2020
Amber Heard
5. The trial of this claim is taking place between 23 March � 3 April 2020 and I understand
May 2020
21 May 20
Josh Drew
21 May 20 16. Rocky told me that Johnny had ki cked Amber on a plane after a fight about
Jun. 2020
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
June 20
Josh Drew
I first met Amber in June 20 14. I met Johnny sometime soon after that. Rocky was living
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
June 2020
Raquel Pennington
Name: Raquel Rose Pennington
Party: Defendants
Exhibit RRP2
Date: June 2020
Jul. 2020
Apr. 2021
April 21
Josh Drew
Afte r I re move d mys e lf from Ms . He a rd's pre s e nce in the pe nthous e on April 21,
May 2021
May 21
Josh Drew
1 Q Yes. 06:18
2 A Not to my knowledge.
3 Q Oh, strike that. I may have misspoken.
4 Did Ms. Pennington tell you that Ms. Heard
5 had spent the night with Mr. Depp -- try again. 06:18
6 That Ms. -- did Ms. Pennington tell you
7 that Ms. Heard spent the night with Mr. Musk during
8 the week after the May 21 incident?
9 A I don't recall exactly, but it would have
May 21
Josh Drew
The purpose of this document is to describe, in the best possible manner, my description of events I
was directly witness to on the evening of Saturday, May 21.
May 21
Josh Drew
10 MR. CHEW: Move to -- 02:59
11 THE WITNESS: And I'm trying not to parse
12 it into what's written.
13 MR. CHEW: Move to strike. Multiple
14 hearsay; lacks personal knowledge.
15 BY MS. KAPLAN: 03:00
16 Q Who told you that?
17 A If memory serves, it was Raquel.
18 Q And --
19 MR. CHEW: Move to strike. Hearsay.
20 BY MS. KAPLAN: 03:00
21 Q And you say you don't recall exactly when
22 you became aware of -- let's call it the -- the
23 plane incident. Are you -- and then you said it
24 could even have been as late as May 21.
25 A Somewhere afterwards, yes. 03:00
May 21
Josh Drew
The purpose of this document is to describe, in the best possible manner, my description of events
was directly witness to on the evening of Saturday, May 21.
2 May 21
Josh Drew
1 Q And is this image of Ms. Heard's face on 04:53
2 May 21 consistent with your recollection of what her
3 face looked like?
4 A Yes.
5 Q And am I correct that unlike -- it's a 04:53
6 little hard to see because there's shadow on the
7 right, but unlike the prior incident that we looked
8 at where there were photos here, the injury looks
9 like it's mostly on one side.
20 May 21
Josh Drew
1 wall? 04:55
2 A It's going to be objected, but my
3 understanding was that it was Johnny.
4 MR. CHEW: Move to strike. Lack of
5 foundation; hearsay. 04:55
6 BY MS. KAPLAN:
7 Q We're trying to get you ready for law
8 school.
9 MR. CHEW: It's kind of first-year -- it's
10 first-year law school. It's not even third-year law 04:55
11 school.
12 BY MS. KAPLAN:
13 Q It's hard to see in the -- in the
14 pictures, but was -- were some of the glass frames
15 broken when you took the photos? 04:55
16 A I honestly don't recall.
17 Q Okay. Let's go to the next photo where
18 it's clearer.
19 Do you recall seeing this on the night of
20 May 21? 04:55
21 A Yes. This is on the column in PH 5 going
22 up the stairs.
23 Q And there, there -- the glass on the
24 pictures were shattered?
25 A Yes. 04:56
May 2022
May 22
Josh Drew
I declare under penalty of perjury that the foregoing is true and correct. Executed on Sunday, May 22.
May 22
Josh Drew
I declare under penalty of perjury that the foregoing is true and correct. Executed on Sunday, May 22.
May 22
Josh Drew
10 A Okay. 02:04
11 MS. KAPLAN: Are we marking -- Counsel,
12 are we marking this as Drew 6?
13 MR. CHEW: 6, Drew 6.
14 BY MR. CHEW:
15 Q Was that from Amber to you? 02:04
16 MS. VIGLIETTA: Objection. Foundation.
17 MR. CHEW: I'm asking him.
18 BY MR. CHEW:
19 Q Was that -- did you receive this from
20 Amber on or about May 22, at 10:58? 02:05
21 A I don't specifically recall, but that is
22 my number, and it rings a bell.
23 Q She says:
24 "I don't want to bother her on her big
25 day." 02:05
May 22
Raquel Pennington
48. The next day May 22 I wrote a statement saying what had happened during the incident
16/05/22
Josh Drew
05/21/16 22:09 TELETYPE FROM NYPD ICAD #D16052125292, FEMALE STATED SHE WAS ON PHONE
05/21/16 22:09 WITH HER FRIEND AND SHE BEGAN SCREAMING AT HER HUSBAND, SUB) ^AMBER
17
P
05/21/16 22:09 HEARD ^, HUSBAND "JOHNNY HEARD" M/W 53 YRS, 511, NFD /NFI
05/21/16 22:09 Units Recomrrended:BPD /1A85 -W3 PD /1A85 -W3 BPD/1A85-W3 BPD /1A85-W3 BPD /1A85 -W3 37
05/21/16 22:09 LOC INFO REVIEWED: S
05/21/16 22:09 IN PENTHOUSE #3
05/21/16 22:09 Apartment Number CHANGED To: 3
05/21/16 22:16 Stacked Incident LPDLPD160521005437 To:PD /1A61 -W3
05/21/16 22:16 Stacked IncAck'd LPDLPD160521005437 By: PD /1A61 -W3
05 /21/16 22:17 Stat: DS PD /1A61 W3 Loc: 840 S BROADWAY
05/21/16 22:17 Stat: ER PD /1A61 -W3 Lac: 849 S BROADWAY
05/21/16 22:17 Primary Unit Changed PD1A61 -W3
05/21/16 22:17 ,Unit CHANGED To: PD1A61 -W3
05/21/16 22:24/Stat: AS PD /1A61 -W3 Loc: 849 S BROADWAY
05/21/16 23:021
05/21/16 23:021Stacked IncAck'd LPDLPD160521005437 By:PD /1A61 -W3
05/22/16
03:00 Stat: DS PD /1A61 -W3 Loc: 849 S BROADWAY
05/22/16
03:01 Stat: AS PD /1A61 -W3 Loc: 849 S BROADWAY
05/22/16 03:01 RELATED TO PREY INC. VERBAL ARGUMENT ONLY. CHECKED RES.
05/22/16 03:01 Stat: CL PD /1A61 -W3
05/22/16 03:01 Incident Closed: 16/05/22 03:01
05/22/16 03:01 Disposition #1 CHANGED To: GOASN:GONE ON ARRIVAL SUPV NO
05/22/16 03:01 GOASN:GONE ON ARRIVAL SUPV NO
May 2024
May 24
Josh Drew
1 2013, Los Angeles, California." 02:58
2 Then on page 2, it says, "March 8, 2013,
3 Los Angeles, California."
4 Later on that same page, page 2, "May 24,
5 2014, flight from Boston, Massachusetts, to 02:58
6 Los Angeles, California."
7 Were you later, once you had started to
8 date Rocky, made aware of any of those incidents?
9 A The only one would be the -- the flight
10 from Boston. 02:58
11 Q Okay. And how did you become aware of
12 that?
13 A I honestly couldn't tell you the exact
14 circumstance that predicated it, and honestly, I
15 couldn't tell you whether it was early on in the 02:58
16 relationship or whether it came up following that
17 final May 21st incident.
18 I'm -- I'm trying to take myself out of
19 it, because, obviously, reading the context adds
20 information to it. The only thing that I really was 02:59
21 told at that time was that they had had an argument.
22 It was related to one of her projects and that at a
23 certain point, he kicked her.
24 And it was in -- one of the few incidents
25 that actually happened in front of people that 02:59
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Jul. 2027