OPENING STATEMENT

I would first like to thank the mediators for briefing us about the process of mediation in
great length. Also, I would like to thank the opposing party for agreeing to partake and being
present at this mediation. I am here to represent my client Mr. RHONNY JEPP. I would also
like to mention that I am here only in an advisory capacity and will only be carrying forward
my clients interest in any communication thereof. And additionally I have advised my client
to have a very open mind in today’s discussion.

Mediators we are all well aware of the situation at hand and the fact that it has affected
both the parties financially, emotionally and physically. The issue has been heightened to
the level it should never have had in the first place.

Despite the complex dispute, my client R demonstrates a willingness to pursue this

mediation, to amicably resolve the issues at hand. This indicates his desire to reach a fair
and confidential resolution, prioritizing the well-being of all involved parties, including their
daughter Lana.

I believe that today after this discussion both the parties can reach a fruitful settlement that
is beneficial to everyone involved.

Now mr.rhonny would take forward the discussion.

Adding on to what my client said,in todays sessions we would possibly like to partake in a
discussion relating to a few fronts ie

(i) Defamation caused to my client due to the fabricated domestic abuse accusations
against him

(ii) The trademark infringement of my client’s brand by ms. Lamber Sherd

(iii) The custody of their daughter lana

ARGUMENTS

1. FABRICATED DOMESTIC ABUSE ALLEGATIONS (settle: Mutual Public Statement)

The Op-ed written by LAMBER SHERD was a direct attack over mr.Rhonny and the domestic abuse
allegations were falsely fabricated

Called WIFE BEATER and CRAZY FREAK on public front.

Tarnished Rohnny Jepp's public image and professional opportunities.

Has lost a lucrative movie role worth $22.5 million due to the resulting bad publicity, indicating
tangible harm inflicted upon his career and financial interests.

Lamber Sheard's allegations of domestic abuse are part of an elaborate hoax designed to garner
sympathy and financial gain.

exploiting fame for personal motives, including launching a footwear brand allegedly infringing on
his trademark, further questioning her credibility and intentions.

Though op-ed did not mention Depp, it was clear by implication that it referred to him

Lamber Sherd struggling actress, is trying to find her place in the industry, trying to gain fame and
financial benefits

• MORI CALLISON –While allegations of substance abuse have been made against Rohnny
Jepp by his ex-wife, Mori Callison, it's important to note that these are unproven claims and
remain disputed.

It was done out of personal vengeance and misunderstanding. Young boy full of rath when
got married, she has taken back her words and apoligized

• WOMAN: Highlight relation with mother , and counsel having worked closely with him for
many years

PERPETRATOR: They also discussed several instances in which Depp alleges Heard instigated
physical violence against him

2. DIVORCE/ ALIMONY (settle: provide for daughter only)

Not ready to pay any alimony, because divorce only for financial gains

She is an independent woman who has various ventures, can do well for herself

Rhonny jepp faced financial setback because of defamation- no movies,no roles, no

one ready to work with him

Ready to provide for the daughter financially at every front

3. CUSTODY OF LANA ( settle : joint custody)

Lamber lacks suitable financial means or patience to take care of their daughter.

Lana would lack resources if solely raised by Lamber Sheard

Rhonny understands the relationship between a child and a mother, he is very close to his
mother himself

Broken home, saw drug abuse in childhood, going to rehab to solve drinking problem,

initiate contract if his drinking issue hampers Lana’s life, Lamber can have full custody
immediately.

Joint custody over Lana to ensure she gets love of both the parents equally, Rhonny will fully
take care of all the financial aspects of daughter.

4. TRADEMARK INFRINGEMENT( settle : change logo completely & brand partnership)

Ms. Lamber Sheard Exploited his fame for personal motives, including launching a
footwear brand allegedly infringing on his trademark, further questioning her
intentions.

Launched brand LASH with similar logo of that Rhonny’s brand: JODE

Trademark infringement because creates a confusion in the mind of the condsumer

because of copied logo and nature of business

Want to promote her business for the ultimate betterment of their daughters future.

BRAND COLLABORATION : Instead of viewing Lamber Sheard's footwear brand

"Lash" as competition, Rohnny Jepp could propose a brand partnership that
leverages their combined influence and expertise in the fashion industry

DEALS

1.Mutual Public Statements: Both parties could agree to issue mutually agreed-
upon public statements aimed at reducing the negative impact on their reputations
and addressing any misconceptions or misunderstandings that may have arisen from
the dispute.

2. JOINT CUSTODY of LANA: this arrangement would involve shared responsibilities for
parenting decisions and visitation schedules, ensuring that Lana's best interests

3. Take care of all finances of daughter

4. Change logo Lash completely and introduce brand collaboration to cover los