A SPECIAL VERDICT FILLING FORMAT
His Claim against Ms. Heard
Each statement on this special verdict form is included in the Special Verdict Form John C. Depp IIHis claim for defamation is based against Amber Heard. Follow the instructions of the Court to answer the questions.
1. Concerning the statement in “Amber Heard”, an online op–ed:
Our culture was furious at our resistance to sexual violence. This must change in Washington
Online edition of Post:
“I stood up against the sexual violence in my life and was subject to our culture’s fury.” This must change.”
1(a). Are you sure that Depp has proved all elements of defamation in his case?
ANSWER NO OR YES
Answering question 1(a), “NO” will not allow you to proceed to question 2.
Answer “YES” to this question if your answer is yes.
Questions: Does Mr. Depp have more evidence to support his claims?
Did Ms. Heard make or publish the statement?
It was about Mr. Depp.
This statement is false.
Is the statement defamatory about Mr. Depp?
Did Ms. Heard intend the defamatory implication?
Aufgrund of certain circumstances, Mr. Depp was not able to see the statement.
1(b). Answer the next question if you have answered yes to all of subparts 1(a). Clear, convincing evidenceThat Ms. Heard was involved in an act of kindness actual malice?
ANSWER NO OR YES
2. This statement was published in an op ed in “A Transformative moment for Women” (Washington Post, print edition) and in “Amber Heard,” the Washington Post online. My actions against sexual violence were met with the ire of our culture. The Washington Post online edition must make this a reality.
“Then, two years later, I was made a public advocate for domestic abuse and felt the full force our culture’s hatred towards women who stand up.”
2(a). Are you sure that Depp has proved all elements of defamation in his case?
ANSWER YES OR NO: If you answer question 2(a) “NO,” please proceed to question 3.
Answer “YES” if you have answered yes to any of these questions.
Did Ms. Heard make or publish the statement?
It was about Mr. Depp.
This statement is false.
This statement includes a defamatory reference to Mr. Depp.
Did Ms. Heard intend the defamatory implication?
Aufgrund of certain circumstances, Mr. Depp was not able to see the statement.
2(b). 2.b).
ANSWER NO OR YES
3. Concerning the statement in “A Transformative moment for Women” published in both the Washington Post’s online and print editions, I said so. It must be changed in the Washington Post online edition.
“I had the unique opportunity to observe, in realtime, how institutions protect victims of abuse.”
3(a). Are you sure that Depp has proved all elements of defamation in his case?
ANSWER NO OR YES: Please answer question 3.a “NO” if you answered that question.
If “YES”, please reply YES/NO to these questions: Is Mr. Depp able to prove that:
Did Ms. Heard make or publish the statement?
It was about Mr. Depp.
This statement is false.
This statement has defamatory implications about Mr. Depp.
Did Ms. Heard intend the defamatory implication?
Aufgrund of certain circumstances, Mr. Depp was not able to see the statement.
3(b). 3.b).
ANSWER NO OR YES
Answer Questions 1 through 4 ONLY if all questions are answered “YES” to either question 2 or 3.
4. In the case of Amber Heard, indicate the compensation damages that John C. Depp, II believes he has been entitled to.
The Jury awards compensatory damages of $_______
As against Amber Heard state the amount of punitive damages, if any, to which you find John C. Depp, II is entitled to recover:
We the Jury award punitive damage in the amount $________
A SPECIAL VERDICT FILLING FORMAT
Ms. Heard’s Claims Against Mr. Depp
The special verdict form contains all the statements that Amber Heard used to base her defamation claim against John C. Depp II. Follow the Court’s directions and answer the questions.
1. Referring to the statement in The Daily Mail, April 8, 2020 online edition:
Amber Heard and her associates in media use fake allegations of sexual violence as both a shield and a sword, depending upon their needs. Some of the sexual violence hoaxes she has made have been used as the blade, and they are being inflicted on Mr. Depp.”
1(a). Are you convinced that Ms. Heard has proved all elements of defamation ANSWER YES OR NO: If you answer question 1(a) “NO,” please proceed to question 2.
Answer “YES” if you have answered this question. If so, please reply YES/NO to the following questions. Has Ms. Heard been proven guilty by more evidence than:
The statement was made by or published by Mr. Waldman while acting as agent for Mr. Depp?
Was it about Ms. Heard
Was the statement seen by anyone other than Ms. Heard
This statement is false.
1(b). 1.b).
ANSWER NO OR YES
2. This statement appeared in The Daily Mail’s April 27, 2020 online edition.
“Quite simply this was an ambush, a hoax. After setting up Mr. Depp by calling police, the second attempt failed to succeed. Officers arrived at the penthouses and searched them thoroughly. After interviewing Mr. Depp, they left without causing any damage to property or faces. Amber and her friend drank some wine while they rummaged through the area, trying to get their stories straight. Then, they called 911 once more.
2(a). Are you convinced that Ms. Heard is guilty of all elements defamation
ANSWER YES or NO: Answer question 2(a), “NO”, and then proceed to question 2.
Answer “YES” if you have answered this question. If so, please reply YES/NO to the following questions. Has Ms. Heard been proven guilty by more evidence than:
The statement was made by or published by Mr. Waldman while acting as agent for Mr. Depp?
Was it about Ms. Heard
Was the statement seen by anyone other than Ms. Heard
This statement is false.
2(b). 2.b
ANSWER NO OR YES
3. This statement appeared in The Daily Mail’s April 27, 2020 online edition.
“We are at the end of Johnny Depp’s abuse hoax by Ms. Heard.”
3(a). 3(a). Do you believe that Ms. Heard has proved all of the elements necessary for defamation to be true?
ANSWER YES OR NO: If you answer question 3(a) “NO,” please proceed to question 4.
Answer “YES” if you have answered this question. If so, please reply YES/NO to the following questions. Has Ms. Heard been proven guilty by more evidence than:
The statement was made by or published by Mr. Waldman while acting as agent for Mr. Depp?
Was it about Ms. Heard
Was the statement seen by anyone other than Ms. Heard
This statement is false.
3(b). 3(b).
ANSWER NO OR YES
Answer Questions 1 through 4 ONLY if all questions are answered “YES” to either question 2 or 3.
As opposed John C. Depp IIIndicate the total amount. Compensatory DamagesIf you have any doubts, tell us. Amber Heard A greater amount of evidence has shown that she is entitled.
The Jury awards compensatory damages of $_______
As opposedJohn C. Depp IIIndicate the punitive damages you are seeking, if applicable. Amber Heard Is entitled to receive:
The Jury awards punitive damages of $___________
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DATE SIGNATURE OF FOREPERSON
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PRINTED NAME FOREPERSON