SPECIALVERDICTFORM

SPECIAL VERDICT FORM

Mr. Depp's
Mr. Depp's Claim
Claim Against
Against Ms.
Ms. Heard
Heard
“This special
This special verdict
verdict form
form includes
includes each
eachofthe statements on
of the statements which John
on which John C.
C. Depp,
Depp, IIII bases
bases
his claim
his ofdefamation
claim of against Amber
defamation against Amber Heard.
Heard. Answer
Answer the
the questions
questions inin accordance
accordance withwith the
the
Court's instructions.
Court's instructions.

1.
1. Asto his statement
As to this statement appearing
appearing inin the
the online
online op-ed,
op-ed, entitled
entitled "Amber
“Amber Heard:
Heard: II spoke
spoke
up against sexual
up against sexual violence—and
violence—and faced
faced our
our culture's
culture's wrath.
wrath. That
That has
has toto change"
change” inin the
the Washington
Washington
Post's
Post's online edition:
online edition:

“I spoke up against sexualviolence—and faced our culture’s wrath. That has to change.”
"I spoke up against sexual violence—and faced our culture's wrath. That has to change."

1a). DoDo you

1(a). you find
find that
that Mr.
Mr. Depp
Depp has
has proven all the
proven all the elements
elementsofdefamation?
of defamation?

ANSWER YES
ANSWER YES OROR NO:NO:
If you
If you answer
answer question
question 1(a)
1(a) "NO,"
“NO,” please
please proceed
proceed to
to question
question 2.2.
If you
If you answered “YES.” please
answered "YES," answer YES
please answer YES oror NO
NO toto the
the following
following
questions: Has
questions: Has Mr.
Mr. Depp
Depp proven
proven byby aa greater
greater weightof the evidence
weight of the that:
evidence that:

‘The statement
The statement was
was made
made oror published
published by
by Ms. Heard?
Ms. Heard?

‘The statement
The statement was
was about
about Mr.
Mr. Depp?
Depp?
“The statement
The statement was
was false?
false?
“The statement
The statementhashas aa defamatory implication about
defamatory implication about Mr.
Mr. Depp?
Depp?
‘The defamatory
The defamatory implication
implication was was designed
designed andand intended
intended by
by Ms.
Ms. Heard?
Heard?

Due to circumstances surrounding the publication of the statement, it

Due to circumstances surrounding the publication of the statement, it
conveyed a defamatory implication to someone who saw it other than Mr.
conveyed a defamatory implication to someone who saw it other than Mr.
Depp?
Depp?

1b). If you answered “YES” to each subpart of question 1(a), answer the
1(b). If you answered "YES" to each subpart of question 1(a), answer the
following question: do you find that Mr. Depp has proven by clear and convincing evidence that
following question: do you find that Mr. Depp has proven by clear and convincing evidence that
Ms. Heard acted with actual malice?
Ms. Heard acted with actual malice?

ANSWER YES
ANSWER YES OROR NO:
NO:

(uss. sess voor on)

(2266786-1, 115653-00002-01/
 2.
2. Astothis statement appearing in the op-ed entitled “A Transformative Moment For
As to this statement appearing in the op-ed entitled "A Transformative Moment For
Women in the Washington Post's print edition and the online op-ed “Amber Heard: I-spoke up
Women" in the Washington Post's print edition and the online op-ed "Amber Heard: I. spoke up
against sexualviolence—and faced our culture’s wrath. That has to change” in the Washington
against sexual violence—and faced our culture's wrath. That has to change" in the Washington
Post's online edition:
Post's online edition:

“Then two years ago, I became a public figure representing domestic abuse, and I felt the
"Then two years ago, I became a public figure representing domestic abuse, and I felt the
full force of our cultures wrath for women who speak out.”
full force of our culture's wrath for women who speak out."

2a). Do you
2(a). Do you find
find that Mr. Depp
that Mr. Depp has
has proven
proven all
all the
the elements
elementsofdefamation?
of defamation?

ANSWER YES OR NO:

ANSWER YES OR NO:
If you answer question 2(x) “NO, please proceed to question 3.
If you answer question 2(a) "NO," please proceed to question 3.

If you
If answered "YES,"
you answered “YES,” please
please answer
answer YES
YES oror NO
NO toto the
the following
following
‘questions: Has Mr.
questions: Has Mr. Depp
Depp proven
proven by
by aa greater
greater weightofthe evidence that:
weight of the evidence that
The statement
The statement was made or
was made or published
published by Ms. Heard?
by Ms. Heard?
‘The statement
The statement was about Mr.
was about Mr. Depp?
Depp?
The statement
The statement was false?
was false?

Thestatementhas
The statement has aadefamatory
defamatory implication about Mr.
implication about Mr. Depp?
Depp?
‘The defamatory implication
The defamatory implication waswas designed and intended
designed and intended by Ms. Heard?
by Ms. Heard?

Due to circumstances surrounding the publication of the statement, it

Due to circumstances surrounding the publication of the statement, it
conveyed a defamatory implication to someone who saw it other than Mr.
conveyed a defamatory implication to someone who saw it other than Mr.
Depp?
POP? ccc:

2(b). If you answered “YES” to each subpart of question 2(a), answer the
2(b). If you answered "YES" to each subpart of question 2(a), answer the
following question: do you find that Mr. Depp has proven by clear and convincing evidence that
following question: do you find that Mr. Depp has proven by clear and convincing evidence that
Ms. Heard acted with actual malice?
Ms. Heard acted with actual malice?

ANSWER YES OR
ANSWER YES OR NO:
NO:
 3.
3. Asto this statement appearing in the op-ed entitled “A Transformative Moment For
As to this statement appearing in the op-ed entitled "A Transformative Moment For
Women in the Washington Post's print edition and the online op-ed “Amber Heard: I spoke up
Women" in the Washington Post's print edition and the online op-ed "Amber Heard: I spoke up
against sexual violence—and faced our culture's wrath. That has to change” in the Washington
against sexual violence--and faced our culture's wrath. That has to change" in the Washington
Post's online edition:
Post's online edition:

“I had
"I the rare
had the rare vantage
vantage pointof seeing, inin real
point of seeing, time, how
real time, institutions protect
how institutions men accused
protect men accused
ofabuse.”
of abuse."

3@). Do
3(a).Do you
you find
find that
that Mr.
Mr. Depp
Depp has
has proven
proven all
all the
the elements
elementsof defamation?
of defamation?

ANSWER YES OR NO:

ANSWER YES OR NO:
If you answer question 3(a) “NO,” please proceed to question 4.
If you answer question 3(a) "NO," please proceed to question 4.

If you
If you answered
answered "YES,"
“YES.” please
please answer
answer YES
YES or NO toto the
or NO the following
following
questions: Has Mr.
questions: Has Mr. Depp
Depp proven
proven by
by aa greater
greater weightofthe
weight of the evidence
evidence that:
that:

‘The statement
The statement was
was made
made or or published
published by Ms. Heard?
by Ms. Heard?
‘The statement
The statement was
was about
about Mr.
Mr. Depp?
Depp?
‘The statement
The statement was
was false?
false?
“The statement
The statement has
has aa defamatory implication about
defamatory implication about Mr.
Mr. Depp?
Depp?
‘The defamatory
The implication was
defamatory implication was designed
designed and
and intended
intended by Ms. Heard?
by Ms. Heard?

Due toto circumstances

Due circumstances surrounding
surrounding thethe publication
publication of
of the
the statement,
statement, itit
conveyed
conveyed aa defamatory
defamatory implication
implication toto someone
someone who
who saw
saw itit other
other than
than Mr.
Mr.
Depp?

3(b). If you answered “YES” to each subpart of question 3(a), answer the
3(b). If you answered "YES" to each subpart of question 3(a), answer the
following question: do you find that Mr. Depp has proven by clear and convincing evidence that
following question: do you find that Mr. Depp has proven by clear and convincing evidence that
Ms. Heard acted with actual malice?
Ms. Heard acted with actual malice?

ANSWER YES OR NO:

ANSWER YES OR NO:
Complete Questions 4-5 ONLY if you answered YES to allof questions 1,2, or 3:
Complete Questions 4-5 ONLY if you answered YES to all of questions 1, 2, or 3:

4.4. As against Amber Heard, state the amountofcompensatory damages,if any, you
As against Amber Heard, state the amount of compensatory damages, if any, you
believe John C. Depp, I has proven, by a greater weightofthe evidence, that he is
believe John C. Depp, II has proven, by a greater weight of the evidence, that he is
entitled to recover:
entitled to recover:

We, the Jury, award compensatory damages in the amount of§

We, the Jury, award compensatory damages in the amount of $ g

5.
5. Asagainst Amber Heard state the amountof punitive damages, ifany, to which you find
As against Amber Heard state the amount of punitive damages, if any, to which you find
John C. Depp, I is entitled to recover:
John C. Depp, II is entitled to recover:

We, the Jury,

We, the Jury, award
award punitive
punitive damages
damages inin the amountof§.
the amount of $ ’

DATE
DATE SIGNATURE OF FOREPERSON
SIGNATURE OF FOREPERSON

PRINTED NAME OF FOREPERSON

PRINTED NAME OF FOREPERSON
 SPECIAL VERDICT FORM
SPECIAL VERDICT FORM

Ms. Heard's
Ms. Heard’s Claim
Claim Against
Against Mr.
Mr. Depp
Depp

“This special verdict form includes each of the statements on which Amber Heard bases
This special verdict form includes each of the statements on which Amber Heard bases
her claimofdefamation against John C. Depp, IL. Answer the questions in accordance with the
her claim of defamation against John C. Depp, II. Answer the questions in accordance with the
Court's instructions.
Court's instructions.

1.
1. Astothis statement appearing in the April 8, 2020 online editionofThe Daily Mail:
As to this statement appearing in the April 8, 2020 online edition of The Daily Mail:

“Amber Heard and her friends in the media use fake sexual violence allegations as both a sword
"Amber Heard and her friends in the media use fake sexual violence allegations as both a sword
and shield, depending on their needs. They have selected some of her sexual violence hoax ‘facts’
and shield, depending on their needs. They have selected some of her sexual violence hoax 'facts'
as the sword, inflicting them on the public and Mr. Depp.”
as the sword, inflicting them on the public and Mr. Depp."

1a). Do
1(a). Do you find that
you find that Ms.
Ms. Heard
Heard has
has proven all the
proven all the elements
elements of
ofdefamation?
defamation?

ANSWER YES OR NO:

ANSWER YES OR NO:
Ifyou answer question 1(a) “NO,” please proceed to question 2.
If you answer question 1(a) "NO," please proceed to question 2.

If you
If answered "YES,-
you answered “YES.” please
please answer
answer YESYES oror NO
NO toto the
the following
following
questions: Has Ms. Heard provenby a greater weightof the evidence that:
questions: Has Ms. Heard proven by a greater weight of the evidence that:

Mr. Waldman,
Mr. Waldman, while
while acting
acting asas an agent for
an agent for Mr.
Mr. Depp,
Depp, made
made or or published
published
the statement?
the statement?
The statement
The statement was about Ms.
was about Ms. Heard?
Heard?
‘The statement
The statement was seen by
was seen by someone
someoneother
otherthan Ms. Heard?
than Ms. Heard?
‘The statement
The statement was false?
was false?

1b). If you answered “YES” to ach subpart of question 1(a), answer the
1(b). If you answered "YES" to each subpart of question 1(a), answer the
following question: do you find that Ms. Heard has proven by clear and convincing evidence that
following question: do you find that Ms. Heard has proven by clear and convincing evidence that
the statement by Mr. Waldman was made with actual malice?
the statement by Mr. Waldman was made with actual malice?

ANSWER YES OR
ANSWER YES OR NO:
NO:
 2.
2. Asto his statement appearing in the April 27, 2020 online edition of The Daily
As to this statement appearing in the April 27, 2020 online edition of The Daily
Mail:
Mail:

“Quite simply this was an ambush, a hoax. They set Mr. Depp up by calling the cops but the first
"Quite simply this was an ambush, a hoax. They set Mr. Depp up by calling the cops but the first
attempt didn’t do the trick. The officers came to the penthouses, thoroughly searched and
attempt didn't do the trick. The officers came to the penthouses, thoroughly searched and
interviewed, and left after seeing no damage to face or property. So Amber and her friends spilled
interviewed, and left after seeing no damage to face or property. So Amber and her friends spilled
alitile wine and roughed the place up, got their stories straight under the direction ofa lawyer and
a little wine and roughed the place up, got their stories straight under the direction of a lawyer and
publicist, and then placed a second call to 911.”
publicist, and then placed a second call to 911."

2(@). Do
2(a). you find
Do you find that Ms. Heard
that Ms. Heard has
has proven all the
proven all the elementsof defamation?
elements of defamation?

ANSWERYESORNO:
ANSWER YES OR NO:
Ifyou answer question 2(a) “NO,” please proceed to question 2.
If you answer question 2(a) "NO," please proceed to question 2.

If you
If you answered
answered "YES,"
“YES,” please
please answer
answer YES
YES oror NO
NO toto the
the following
following
questions: Has
questions: Has Ms.
Ms. Heard
Heard proven
proven by
by aa greater
greater weight
weightofthe evidence that:
of the evidence that:
Mr. Waldman,
Mr. Waldman, while acting as
while acting as an
an agent
agent for
for Mr.
Mr. Depp,
Depp, made
made or or published
published
the statement?
the statement?
‘The statement was
The statement was about
about Ms.
Ms. Heard?
Heard?
‘The statement was
The statement was seen
seen by
by someone
someone other
other than
than Ms.
Ms. Heard?
Heard?
The statement
The statement was
was false?
false?

2(b). If you answered “YES” to each subpart of question 2(a), answer the
2(b). If you answered "YES" to each subpart of question 2(a), answer the
following question: do you find that Ms. Heard has proven by clear and convincing evidence that
following question: do you find that Ms. Heard has proven by clear and convincing evidence that
the statement by Mr. Waldman was made with actual malice?
the statement by Mr. Waldman was made with actual malice?

ANSWER YES OR
ANSWER YES OR NO:
NO:
 3.
3. Asto this statement
As to this statement appearing
appearing inin the
the April 27, 2020
April 27, 2020 online
online edition
edition ofof The
The Daily
Daily
Mail:
Alail:

“[WJe have reached the beginning of the endofMs. Heard abuse hoax against Johnny Depp.”
"[W]e have reached the beginning of the end of Ms. Heard's abuse hoax against Johnny Depp."

3(a). Do
3(a). Do you
you find
find that
that Ms.
Ms. Heard
Heard has
has proven
proven all
all the
the elements
elements of
ofdefamation?
defamation?

ANSWER YES OR NO:

ANSWER YES OR NO:
If you answer question 3(a) “NO,” please proceed to question 4.
If you answer question 3(a) "NO," please proceed to question 4.

If you
If you answered “YES.” please
answered "YES," answer YES
please answer YES or or NO
NO toto the
the following
following
questions: Has
questions: Has Ms.
Ms. Heard
Heard proven
proven by
by aa greater
greater weight
weightof
of the evidence that:
the evidence that:
Mr. Waldman,
Mr. Waldman, while
while acting
acting as
as an agent for
an agent for Mr. Depp, made
Mr. Depp, made or or published
published
the statement?
the statement?
‘The statement
The statement was
was about
about Ms.
Ms. Heard?
Heard?
‘The statement
The statement was
was seen
seen by someone other
by someone other than
than Ms.
Ms. Heard?
Heard?
The statement
The statement was
was false?
false?

3(b). If you answered “YES” to each subpart of question 3(a), answer the
3(b). If you answered "YES" to each subpart of question 3(a), answer the
following question: do you find that Ms. Heard has proven by clear and convincing evidence that
following question: do you find that Ms. Heard has proven by clear and convincing evidence that
the statement by Mr. Waldman was made with actual malice?
the statement by Mr. Waldman was made with actual malice?

ANSWER YES OR NO:

ANSWER YES OR NO:
 Complete Questions 4-5 ONLYif you answered YES to all of questions 1,2, or 3.
Complete Questions 4-6 ONLY if you answered YES to all of questions 1,2, or 3.

4.
4. As against John C. Depp, II, state the amount of compensatory damages, ifany, you
As against John C. Depp, II, state the amount of compensatory damages, if any, you
believe Amber Heard has proven, by a greater weight of the evidence, that she is entitled
believe Amber Heard has proven, by a greater weight of the evidence, that she is entitled
to recover:
to recover:

We, the Jury,

We, the Jury, award
award compensatory
compensatory damages
damages inin the
the amount
amount of
of§$

5.
5. Asagainst John C. Depp, IL state the amountof punitive damages, ifany, you to which
As against John C. Depp, II, state the amount of punitive damages, if any, you to which
you find Amber Heard is entitled to recover:
you find Amber Heard is entitled to recover:

We,the Jury, award punitive damages in the amount of§

We, the Jury, award punitive damages in the amount of $

DATE
DATE SIGNATURE OF FOREPERSON
SIGNATURE OF FOREPERSON

PRINTED NAME OF FOREPERSON

PRINTED NAME OF FOREPERSON