Lady Gaga's Deposition in Dr. Luke's Defamation Lawsuit

FILED: NEW YORK COUNTY CLERK 01/29/2019 06:39 PM INDEX NO.
653118/2014
NYSCEF DOC. NO. 2097 RECEIVED NYSCEF: 01/29/2019
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1
2 SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
3 -------------------------------------------X
LUKASZ GOTTWALD p/k/a DR. LUKE, KASZ MONEY,
4 INC., and PRESCRIPTION SONGS, LLC,
5 PLAINTIFF,
6 v.
7 KESHA ROSE SEBERT p/k/a KESHA, PEBE SEBERT,
VECTOR MANAGEMENT, LLC, and JACK ROVNER,
8 `
9 DEFENDANTS.
10 Index No. 653118/2014
-------------------------------------------X
11 ***CONFIDENTIAL***
12
13 DEPOSITION OF STEFANI GERMANOTTA

14 Philadelphia, Pennsylvania
15 Tuesday, September 12, 2017
16
17
18
19
20
21
22 Reported by:
23 Rebecca Schaumloffel, RPR, CLR
24 Job No: 130239
25
TSG Reporting - Worldwide (877) 702-9580

FILED: NEW YORK COUNTY CLERK 01/29/2019 06:39 PM INDEX NO. 653118/2014
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1 1
2 A P P E A R A N C E S:
2 3
3 September 12, 2017 4 MITCHELL SILBERBERG & KNUPP
4 Attorneys for the Plaintiff
2:10 p.m. 5 12 East 49th Street
5 New York, New York 10017
6 6 BY: CHRISTINE LEPERA, ESQ.
DAVID STEINBERG, ESQ.
7 7 BRADLEY MULLINS, ESQ.
8 Deposition of STEFANI GERMANOTTA, 8
9
9 held at the offices of COZEN O'CONNOR, One O'MELVENY & MYERS
10 Liberty Street, Philadelphia, Pennsylvania 10 Attorneys for the Defendant
11 1999 Avenue of the Stars
19103, before Rebecca Schaumloffel, a 11 Los Angeles, California 90067
12 Certified Livenote Reporter and Notary Public BY: JAMES PEARL, ESQ.
13 12 STEPHEN VOLPE, ESQ.
of the States of New York, New Jersey, and 13
14 Pennsylvania. 14
15 GIBSON, DUNN & CRUTCHER
15 Attorneys for the witness
16
200 Park Avenue
17 16 New York, New York 10166
18 BY: ORIN SNYDER, ESQ.
17 JEFFERSON BELL, ESQ.
19 18
20 19 ALSO PRESENT:
20
21
Lukasz Gottwald, telephonically
22 21
22
23
* * *
24 23
24
25
25
Page 4 Page 5
1 S. GERMANOTTA 1 S. GERMANOTTA
2 S T E F A N I G E R M A N O T T A, called 2 want you to understand that. I appreciate
3 as a witness, having been first duly sworn by 3 that, and this is not something that we are
4 a Notary Public of the State of New York, was 4 doing as other than just gathering evidence
5 examined and testified as follows: 5 that, unfortunately, we need because of Ms.
6 EXAMINATION BY 6 Sebert's situation.
7 MS. LEPERA: 7 A. I understand.
8 Q. Good morning. Good morning, Ms. 8 MS. LEPERA: I appreciate that.
9 Germanotta. I'm Christine Lepera. I am here 9 We also have an understanding, I
10 to take your deposition in the case. We 10 believe on the record, that no one is
11 understand you have given some documents, and 11 going to call Ms. Germanotta to trial.
12 you have given some documents that have been 12 We are going to use this transcript
13 produced by Ms. Sebert that we will question 13 for the trial.
14 you about. 14 Is that acceptable to everyone?
15 The deposition transcript is going 15 MR. PEARL: Yes.
16 to be confidential and the exhibits that we 16 MS. LEPERA: Okay, Orin, is that
17 use in connection with it also will be kept 17 okay?
18 confidential. 18 MR. SNYDER: I am not a party to
19 A. I understand. 19 the case but whatever agreements you
20 Q. And let me just say out of the 20 have.
21 gate that I have absolutely no interest in 21 MS. LEPERA: I have a number of
22 prying into your privacy or your personal 22 documents that we can probably
23 life. None of that. We are very much 23 expedite things if I can get
24 cognizant and mindful of how important these 24 authenticated. For example, what we
25 issues are to women everywhere, and that I 25 have done, actually, is provide, you
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2 know, all of the text messages that 2 prepared to testify. But I just want
3 Ms. Sebert produced. I have a full 3 everyone to understand that, as she
4 binder of them and, you know, we can 4 has publicly stated in other contexts,
5 just range them from Bates stamp to 5 as a sex abuse survivor, and I know
6 Bates stamp. I am not going to 6 this from my own personal experience
7 question you about all of them. 7 with family members, there are trigger
8 MR. SNYDER: We will 8 events, and this deposition has proved
9 authenticate them all. 9 to be a trigger event for Ms.
10 MS. LEPERA: That's what I would 10 Germanotta, and she has experienced in
11 like to hear. We will give you copies 11 the past few hours some PTSD reactions
12 of the binders so you have them for 12 which is causing some trauma and
13 yourselves in case you don't have all 13 emotional reactivity. So she is
14 of them already which I think you 14 crying now the record will reflect.
15 should have. 15 That doesn't mean she is unable to
16 You wanted to say something? 16 testify truthfully and competently,
17 MR. SNYDER: Thanks, everyone. 17 and she is prepared to do so, but I
18 So on behalf of Ms. Germanotta, we are 18 just want the record to reflect that
19 here pursuant to the stipulation 19 she is in a state of emotional upset
20 ordered by the Court. Ms. Germanotta 20 and may need, from time to time, even
21 is competent to testify today. I just 21 though we all share the interest of
22 spent the last hour or so with her, 22 getting this deposition done as
23 and she has clear recollection to the 23 expeditiously and efficiently as
24 extent her recollection still exists 24 possible, may need to just take some
25 and she -- her -- she is competent and 25 breaks.
Page 8 Page 9
2 In that regard, I just 2 Mr. Gottwald is here listening from
3 respectfully request that unless 3 his location.
4 absolutely necessary, that questioning 4 (Whereupon, Germanotta Exhibit
5 into her own personal circumstances or 5 1, KRS_ESI0024484 through '0025887 was
6 her own personal experiences should be 6 marked for identification as of this
7 avoided unless it is in a, you know, 7 date by the Reporter.)
8 good faith and legitimate search for 8 MR. SNYDER: We will stipulate
9 the truth. 9 documents KRS_ESI0024484 through and
10 I see very little relevance, if 10 including '25887 are text messages
11 any, to delving into details of Ms. 11 between my client and Ms. Sebert.
12 Germanotta's personal life, and so I 12 They were received by her or sent by
13 just want to make that clear. In fact 13 her as the text indicates and to the
14 my client asked me to state that 14 extent you need authentication, you
15 clearly on the record. Anything else 15 can -- we stipulate that our client
16 you want to say in that regard? 16 showed all these, will authenticate
17 THE WITNESS: I will do my very 17 each one on which her number appears
18 best to answer. 18 as having been sent or received.
19 MS. LEPERA: As I said right out 19 MS. LEPERA: That is her number
20 of the gate, Orin, that's my intention 20 on each of them?
21 not to invade or disturb your privacy. 21 MR. SNYDER: Yes.
22 THE WITNESS: I know that. 22 MS. LEPERA: Also, the content
23 MR. SNYDER: I understand we 23 was provided by her directly, not
24 have a visitor on the phone. 24 someone on her behalf so that the
25 MS. LEPERA: On the LiveNote, 25 communications --
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2 MR. SNYDER: She typed the texts 2 it said "Read," it was a message you read
3 herself, yes. So stipulated. 3 from Ms. Sebert?
4 MS. LEPERA: You have the same 4 A. Yes.
5 stipulation, Bo. 5 Q. Okay. Thank you. Again, I will
6 MR. PEARL: In they were the 6 state very clearly, my intentions are not to
7 texts produced, we will authenticate. 7 pry into anything personal. There are
8 MS. LEPERA: They are the ones 8 certain things that are redacted that your
9 that your client produced. 9 counsel has represented are just about your
10 (Whereupon, Germanotta Exhibit 10 personal experience, and I would like to just
11 2, LG0001 through '004 was marked for 11 make that clear on the record. That I don't
12 identification as of this date by the 12 want to -- if it has anything to it --
13 Reporter.) 13 MR. SNYDER: Let me correct
14 BY MS. LEPERA: 14 that. The redactions are reflective
15 Q. So, Ms. Germanotta, what I have 15 of content that has nothing to do with
16 put in front of you is a confidential 16 any issue in dispute in this case, for
17 document production by your counsel to us, 17 example. Just hypothetically but not
18 and it's got a Bates stamp number in the 18 actually. Ms. Germanotta could have
19 bottom LG0001 through '4. 19 said I stubbed my toe and it is
20 These are text messages also that 20 bleeding, and I need to go to the
21 you exchanged with Ms. Sebert in or around 21 doctor. She could have said, oh, my
22 the dates indicated? 22 stomach hurts because I ate bad
23 A. Yes. 23 shellfish. She could have said, oh, I
24 Q. So if it says "Sent," it was a 24 am tired, I was out late last night.
25 message that you sent to Ms. Sebert, and if 25 Extraneous personal information we
Page 12 Page 13
2 actually did not redact, I don't 2 in a very clear, linear fashion, so
3 believe. Personal information that 3 there is nothing you are representing
4 might even be relevant to the subject 4 in these redacted sections that either
5 matter of this case. 5 speaks about anything with respect to
6 MS. LEPERA: You did not redact? 6 Kesha and Dr. Luke and/or Dr. Luke
7 MR. SNYDER: In fact, we 7 generally and/or doing anything in
8 produced a massive amount of such 8 connection with publicity, perhaps,
9 personal information. Had we intended 9 for example.
10 to redact such information, you would 10 MR. SNYDER: Absolutely not.
11 not see much of the content here, for 11 Q. So that representation is
12 example, where she talks about her own 12 consistent with your understanding, Ms.
13 experience. So the redactions reflect 13 Germanotta?
14 personal matters that two friends 14 A. Yes.
15 would talk about in addition to the 15 MS. LEPERA: We will reserve on
16 subject they are talking about here. 16 that but we can talk about it.
17 So completely far afield from and not 17 MR. SNYDER: I will also say
18 in the context of the subject matter 18 relatedly because Jeff reminds me that
19 of Dr. Luke and Kesha and the related 19 we didn't redact anything that would
20 issues. So it could be they are 20 be -- meet the threshold for
21 talking about Dr. Luke and then they 21 discoverability under the CPLR.
22 can go into a segue about, you know, 22 So even something that might be
23 my mother is pissing me off. Mine 23 related to something that would lead
24 too. That kind of thing. 24 to discoverable information, we really
25 MS. LEPERA: If I can just say 25 were very circumspect in our
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2 redactions. Just that when two 2 Q. Did you speak to her at that point
3 friends talk by text, they veer off 3 and introduce each other?
4 into things that have nothing to do 4 A. Not exactly.
5 with other things. That's the 5 Q. How did you meet her, why don't
6 dividing line. 6 you just describe --
7 MS. LEPERA: Absolutely. I have 7 A. Well --
8 no desire to get into anything that's 8 Q. -- the interaction?
9 irrelevant unrelated to the items that 9 A. I got to Dr. Luke's house with
10 we just described. And we will 10 Troy Carter and Vincent Hubbert. We walked
11 obviously talk about that just in case 11 in. As we were walking down the hallway, I
12 it is required. 12 saw a girl in a bed to the left of me behind
13 BY MS. LEPERA: 13 a door, and then I walked into what was Dr.
14 Q. Can you, Ms. Germanotta, tell me, 14 Luke's studio and sat down with him and Troy
15 when do you remember first meeting Kesha 15 Carter and Vincent Hubbert and he played us
16 Sebert in person, if ever? 16 some records. And then Dr. Luke left the
17 A. It was many years ago at Dr. 17 room and the girl walked out and introduced
18 Luke's studio. 18 herself. She didn't say Kesha, but she said
19 Q. Where was that? Do you remember, 19 that's me on that record, and it was Flo
20 was it in California? 20 Rida.
21 A. It was in California, yes. 21 Q. Is that about 2008, does that
22 Q. Okay. And were you at that point 22 sound about right?
23 in communication with her either through 23 A. I don't recall the exact year.
24 email, text, or phone before meeting her? 24 Q. So you hadn't been communicating
25 A. No. 25 by text or email or phone with her prior to
Page 16 Page 17
2 that time? 2 the public --
3 A. No. 3 A. Yes.
4 Q. Just say for purposes of 4 Q. -- when you saw that?
5 discussion, it was around 2008. When did you 5 A. Yes.
6 first start communicating with her via text 6 Q. Now, you started texting with her
7 or email or phone? When I say "her," I mean 7 around that time?
8 Kesha Sebert. 8 A. Yes. As I recall, it was around
9 A. As I recall, it was after I saw 9 that time.
10 this case in social media. 10 Q. Okay. This chain of emails which
11 Q. When it was filed by Kesha? 11 we have as Germanotta 2 that you produced are
12 A. No. I don't recall exactly. I 12 in 10/29/2013 through 10/30/2013. So really
13 just remember I saw an article about her 13 just a span of a couple of days.
14 case. 14 Do you see that?
15 Q. Right. So did you understand that 15 A. Yes.
16 Ms. Sebert had brought certain claims against 16 Q. When this first exchange occurred
17 Mr. Gottwald for various improprieties and 17 with her, you had previously seen the
18 the like and you saw that filing or an 18 allegations that she had made against Mr.
19 article about that; is that right? 19 Gottwald about rape?
20 A. I saw information about Kesha that 20 MR. PEARL: Objection.
21 was related to her having difficulty getting 21 Misstates the prior testimony.
22 away from a record producer that had 22 MR. SNYDER: I will object also.
23 allegedly raped her. 23 I don't know if this is the first or
24 Q. Okay. So the communication about 24 the second or the third. I would just
25 him having raped her had been out there in 25 appreciate that the questions not be
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2 imbedded with factual predicates. The 2 MR. SNYDER: As I understand it,
3 witness is unaware in 2008 or the 3 you and Proskauer had numerous
4 first text, because I will start 4 conversations. We have had
5 having problems to the extent you will 5 conversations with you. We produced,
6 say she is adopting the fashion 6 that is, the client and her lawyers
7 predicate of your question. 7 produced all emails that she has in
8 So I have no idea whether this 8 her custody, possession, or control.
9 is the first, or second, or third. 9 I actually think we didn't produce
10 And there is no way Stefani does 10 anything. Kesha produced everything,
11 either. 11 as I recall.
12 MR. PEARL: I will just object 12 Am I right?
13 for lack of foundation. Misstates the 13 MS. LEPERA: This document was
14 prior testimony. Calls for 14 produced --
15 speculation. 15 MR. SNYDER: Whatever we
16 Q. When you had this exchange with 16 produced is what we have. There is
17 her, whether it was the first, second, had 17 nothing that we have that we haven't
18 you previously seen the allegations that she 18 produced. That Kesha didn't already
19 made about my client with respect to rape? 19 produce.
20 MR. PEARL: Objection. Lacks 20 In other words, we only
21 foundation. Calls for speculation. 21 produced, as I understand the
22 A. I don't recall. 22 agreement, we only produced documents
23 Q. Okay, that's fine. Now, these are 23 that hadn't already been previously
24 the only text messages you were able to 24 produced.
25 locate in connection with the Subpoena? 25 MS. LEPERA: So if I am
Page 20 Page 21
2 understanding correctly, it is not 2 Dr. Luke, or accusations against Dr. Luke?
3 that Ms. Germanotta does not have the 3 MR. SNYDER: I guess I have to
4 texts that we have authenticated as 4 answer that question. My
5 Exhibit 1; she just didn't provide the 5 understanding is no, but I was not
6 additional copies of those? 6 personally involved in the production
7 MR. SNYDER: I wasn't involved 7 of the prior emails. I was just
8 in the case, but my understanding is 8 involved in the reproduction, already
9 that was the agreement among counsel; 9 produced emails with changes and
10 that we were going to produce 10 redactions.
11 documents to the extent they hadn't 11 MS. LEPERA: Okay.
12 been produced already. 12 MR. SNYDER: Let's take it off
13 MS. LEPERA: So my question is 13 line. She doesn't know.
14 -- 14 MS. LEPERA: We will reserve on
15 MR. SNYDER: This witness has no 15 that, and all I want to do is find out
16 personal knowledge of the collection 16 from you, at the appropriate point
17 efforts. It was done by counsel. 17 when you had a chance to look at
18 BY MS. LEPERA: 18 Exhibit 1, if there is anything
19 Q. So really what I am just trying to 19 initial beyond what, you know, 1 and
20 get at here is whether or not, other than 20 2.
21 Exhibit 1, which is the text messages that 21 Okay. Let's move on.
22 Ms. Sebert produced which we ran the Bates 22 BY MS. LEPERA:
23 stamps on and Exhibit 2, are there any other 23 Q. What's the current status of your
24 text messages or emails in, Ms. Germanotta, 24 relationship with Ms. Sebert today?
25 in your possession that relate to Kesha, 25 MR. PEARL: Objection.
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2 Q. If you have any relationship, 2 A. Sorry, I thought you meant before.
3 friendship? 3 Q. No, after.
4 MR. PEARL: Objection; vague and 4 A. Yeah.
5 ambiguous. 5 Q. Okay. How many times have you
6 A. She is my friend. 6 been in her presence face-to-face?
7 Q. When was the last time you spoke 7 A. I don't recall the exact number.
8 to her? 8 Q. It was a couple or 20, some range?
9 A. I don't recall. 9 A. I would say less than ten times.
10 Q. Have you spoken to her in the past 10 Q. Okay. And would you speak on the
11 year? 11 phone as well to texting?
12 A. Yes. 12 A. Less than ten and that would
13 Q. Have you spoken to her about this 13 include like seeing her at events.
14 matter? When I say "this matter," this is 14 Q. Without discussing matters?
15 this case, this controversy, in the past 15 A. Well, just, I need to clarify they
16 year? 16 weren't all personal meetings.
17 A. I don't recall. 17 Q. Can we narrow then many sort of
18 Q. Okay. You identified earlier one 18 personal meetings, what you would
19 time you initially met her. Had you ever 19 characterize as personal meetings with her?
20 been with her face to face beside that one 20 MR. SNYDER: If any.
21 time? 21 Q. If any.
22 A. No. 22 A. I had one that I recall.
23 Q. You have never been in her 23 Q. Okay. Can you tell me what you
24 presence except when you saw her at Dr. 24 remember about that?
25 Luke's house? 25 A. She came to the studio where I
Page 24 Page 25
2 was, and she and I had a very heartfelt and 2 A. Yes.
3 emotional conversation about what she had 3 Q. What were the details she told
4 been through and what I had been through. 4 you?
5 Q. Okay. Do you remember, not what 5 A. Well, she told me that he used
6 you told her about what you went through, but 6 power and manipulation in some fashion or
7 what she told you about what she went through 7 some type of verbiage. I am not repeating
8 with respect to any specificity? 8 exactly the words that came out of her mouth,
9 A. I don't recall on that day 9 but that he used power and manipulation to
10 exactly, no. 10 control her, and that she had been given a
11 Q. Okay. Did she discuss a rape 11 happy pill, that he offered her something and
12 allegation against my client on that date, do 12 that she took it, and that she woke up and
13 you know? 13 didn't remember, and that's what she told me.
14 A. On that day, I don't recall if we 14 Q. Is that the extent of the details
15 discussed it that day. What we discussed was 15 you remember of her ever saying about -- and
16 what I recall was her immense sadness and 16 I am specifically talking about sexual rape,
17 depression and fear. She was visibly very 17 not any other --
18 different than when I had seen her before, 18 A. So am I. So am I.
19 and -- but I can't say specifically what 19 Q. That's the details I am looking to
20 exactly we spoke about. I just recall that 20 see whether she communicated to you any --
21 it was emotional, and I wanted to be there 21 A. That's what I meant to imply, yes,
22 for her. 22 manipulation, control. These are all things
23 Q. Okay. So, actually, did she ever 23 that happen when women get raped.
24 tell you anything specific or any details 24 Q. Okay, but I am speaking
25 about any alleged rape of her by my client? 25 specifically with respect to her.
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2 A. Yes, and that's what she told me. 2 Q. Okay. And was anybody else
3 Q. Right. So she said she was raped 3 present when you were having the conversation
4 on one incident, one occasion? 4 that you mentioned when she came to the
5 A. That is what I recall, was the 5 studio to visit you?
6 incident that she told me about, the happy 6 A. There were -- no, I don't recall.
7 pill, and the -- that she woke up and that 7 We moved privately to the back room. John
8 she didn't remember. 8 Janick came by at one point.
9 Q. Did she tell you any other details 9 Q. I will get back to that in a
10 about that night and her, where she was, what 10 minute.
11 she was doing? 11 (Whereupon, Germanotta Exhibit
12 A. No, I don't -- I don't recall. 12 3, KRS_ESI_0024810 through '4873 was
13 Q. Whether she was drinking? 13 marked for identification as of this
14 MR. PEARL: Objection. 14 date by the Reporter.)
15 Compound. 15 Q. Why don't you take a moment, Ms.
16 Q. Did she tell you anything about 16 Germanotta and look at what we marked as
17 being at a particular -- 17 Exhibit 3 which are part of the text messages
18 A. I don't recall exactly. 18 contained in Exhibit 1 with Bates stamps
19 Q. Okay. That's all I am trying to 19 '0024810 through '73.
20 do, to see if you remember any of the details 20 MR. SNYDER: She is reading
21 of the alleged rape that she communicated to 21 them. Give us a moment.
22 you beyond what you have said. Ever. That's 22 MS. LEPERA: Absolutely.
23 pretty much it? 23 MR. SNYDER: You are going to be
24 A. I don't recall. That's what I 24 asking questions about specific texts?
25 recall the most. 25 MS. LEPERA: Yes, that's right.
Page 28 Page 29
2 MR. SNYDER: So we will go 2 A. Yes.
3 through them. 3 Q. And turning, then, going to, if
4 MS. LEPERA: Just for context. 4 you have gone through, I don't need to, go
5 THE WITNESS: Can I have a 5 through to '0024829, again, a statement by --
6 highlighter, if possible? 6 a text message by Ms. Sebert to you, I am
7 MR. SNYDER: Okay. 7 asking, saying, quote, "she could bring the
8 Q. So these text messages, I want to 8 whole thing to a head."
9 just bring you to -- pass through up until 9 Do you see that?
10 '0024825. Do you see there is a text message 10 A. Yes.
11 from Ms. Sebert to you stating that, quote, 11 Q. Was she referring to Katy Perry,
12 "I'm really upset with Katy perry?" 12 to your knowledge and understanding?
13 A. Yes. 13 A. Yes.
14 Q. You are familiar with Katy Perry? 14 Q. Then we have on '0024834 another
15 A. Yes. 15 text from Ms. Sebert to you, quote, this is
16 Q. Have you ever met her in person? 16 on 2/26/2016, quote, "she was raped by the
17 A. Yes. 17 same man."
18 Q. Have you communicated with her via 18 Do you see that?
19 text or email? 19 A. Um-hum.
20 MR. SNYDER: About this matter? 20 Q. Did you understand -- first of
21 MS. LEPERA: Yes, about this 21 all, you received this when Ms. Sebert sent
22 matter. 22 it to you, correct?
23 A. No. 23 A. Yes.
24 Q. And would you consider her to be a 24 Q. Did you understand that the "she"
25 friend? 25 she was referring to was Katy Perry?
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2 A. Yes. 2 Q. Do you recall any facts she might
3 Q. Did you understand that the man 3 have said --
4 she was referring to was Mr. Gottwald? 4 A. No.
5 A. Yes. 5 Q. -- to back that up?
6 Q. And then there are a series of 6 She didn't say, for instance, that
7 further emails with respect to Ms. Perry but 7 Ms. Perry had told her that, right?
8 I am not going to belabor those right now so 8 A. No.
9 you can put those to the side. 9 Q. And you certainly didn't have and
10 MR. PEARL: Objection. They are 10 don't have any firsthand knowledge of
11 actually text messages. 11 anything with respect to Ms. Perry and my
12 MS. LEPERA: Did I say emails 12 client, correct?
13 again? Thank you. I appreciate that. 13 A. No, I don't.
14 It's old school. 14 Q. You never asked her if this
15 MR. PEARL: I understand. I do 15 statement about her -- you never asked Ms.
16 it all the time. 16 Perry if the statement that Ms. Sebert made
17 Q. So Ms. Perry didn't ever tell you 17 about her was true?
18 that Mr. Gottwald had raped her, correct? 18 A. Never.
19 A. No. 19 Q. So would it surprise you to know
20 Q. Ms. Perry didn't tell you he 20 that she has adamantly denied any such
21 sexual assaulted her in any way? 21 conduct under oath?
22 A. No. 22 A. No, it doesn't.
23 Q. Did Ms. Sebert tell you what her 23 Q. It doesn't surprise you?
24 basis was of making that statement ever? 24 A. No.
25 A. Not in a way that I can recall. 25 Q. Why is that?
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2 A. Well, because, I mean, I never 2 trying to put words in your mouth. Just
3 actually really believed necessarily that he 3 trying to ask whether or not you can look
4 had done that to her. I know that I was 4 back to your year of 2005 and know whether or
5 speaking with Kesha and supporting her, but 5 not that was the year you first met her?
6 the truth is that I never saw anything with 6 A. No, it was not that year.
7 my own two eyes with Katy, and the truth is 7 Q. It was later, correct?
8 that my opinion of the situation was formed 8 A. It was later.
9 based on the fact that I had seen Kesha in 9 Q. Okay. And are you aware that she
10 Luke's studio in her underwear when she was 10 has made the accusation that the alleged rape
11 young, and I was there. 11 happened in 2005?
12 Q. Okay. But in that instance, that 12 A. No.
13 was not what she had described to you as the 13 Q. You didn't know that, okay.
14 situation of the alleged rape, correct? 14 Now, Ms. Sebert testified under
15 A. No. 15 oath and I will read, I will put the
16 Q. And do you know whether or not the 16 transcript reference into the record that
17 -- did she ever tell you the year of when she 17 Mr. Janick -- you know John Janick, and do
18 claimed the incident occurred? 18 you know him from the business and working
19 A. No, she didn't. 19 with him?
20 Q. Well, was this -- this time that 20 A. Yes.
21 you saw her in the house, was it in 2005? 21 Q. He, according to Ms. Sebert, said
22 A. I don't recall the exact year that 22 to both you and Ms. Sebert that my client
23 it was. I think we might have just 23 raped Katy Perry?
24 established it was 2008. 24 MR. PEARL: Are you reading from
25 Q. I am just trying to -- I am not 25 the exact transcript?
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2 MS. LEPERA: Yes. No, I am not 2 brought up, obviously, the Katy
3 quoting her. I am paraphrasing. I am 3 thing."
4 going to give you the transcript 4 Question. "Tell me exactly what
5 references. It is 565/11, 567/2. 5 he said."
6 MR. PEARL: I am not worried 6 Answer. "I already did."
7 about it. I am just asking, because 7 Question. "No, tell me exactly
8 you said you are going to read from 8 what he said."
9 the transcript. 9 Answer. "Well, he was just
10 MS. LEPERA: I am. 10 speaking and because he knew that I
11 Q. I am reading on Page 575, 24 to 11 had known her for so long."
12 lines -- to page 579 line 2. It is a little 12 Question. "Did he say I have
13 bit out of context, but it's in the core of 13 known you -- I know you have known
14 this. 14 Katy Perry for a long time. Ms.
15 Question. "Okay, so just is 15 Sebert?"
16 that basically everything you can 16 Answer. "I don't remember his
17 remember that's all about the 17 exact words leading up to it, but I
18 conversation between you and Gaga and 18 think he maybe had asked me or
19 Janick for part of it?" 19 something insinuating, oh, you have
20 Answer. "I mean, that's with me 20 known for awhile. And I said, yes, I
21 and Janick and then Janick and then 21 was in her Kissed a Girl music video."
22 Janick came in." 22 Question. "Right."
23 Excuse me. Answer. "Then 23 Answer. "And he said, quote, so
24 Janick came in and the thing that 24 you know that Dr. Luke raped Katy
25 sticks out most in my mind is when he 25 Perry, too?""
Page 36 Page 37
2 Question. "Those were his exact 2 Q. In the presence of both of you?
3 words?" 3 A. Yes, and I don't know that he used
4 Answer. "It was like he said 4 the word "rumor." I don't recall exactly the
5 that Dr. Luke had raped Katy Perry." 5 way he said it. I just recall that it was
6 Did Mr. Janick say in your. 6 brought up.
7 presence that Mr. Gottwald raped Katy Perry? 7 Q. Okay. By him?
8 MR. PEARL: I am just going to 8 A. Yes.
9 object to the long lead up of the 9 Q. But did he say it happened or did
10 testimony, and I am not sure that the 10 he say he had heard something?
11 witness was able to follow it. But go 11 MR. SNYDER: If you recall.
12 ahead and answer. 12 Q. If you recall.
13 Q. Were you able to follow that? 13 A. I don't recall. You know, I am --
14 MR. SNYDER: Can you rephrase 14 Q. Okay. So did he say anything
15 the question, please? 15 beyond that, about this topic; i.e., Mr.
16 MS. LEPERA: The one I just 16 Gottwald and Katy Perry?
17 asked? 17 A. He was there to be supportive to
18 MR. SNYDER: Let's just have a 18 her, and I had a conversation with him and
19 new question on the record. 19 her about what we can do to speak with Sony
20 Q. Did Mr. Janick say in your 20 about potentially maybe bringing her over to
21 presence and Ms. Sebert's presence that my 21 Interscope, and that I would look after her.
22 client, Mr. Gottwald, raped Katy Perry? 22 Q. Okay. But I am really just
23 A. He said he had heard a rumor. 23 focusing on what, if anything, he said that
24 Q. Janick said he heard a rumor? 24 you recall about an allegation of Mr.
25 25 Gottwald raping Katy Perry.
A. Yes.
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2 A. He said something like I heard he 2 A. No, I didn't take from his comment
3 raped Katy, too. 3 that he actually knew.
4 Q. Okay. So would it surprise you 4 Q. That it was a fact?
5 that he has testified under oath that he 5 A. And he didn't purport it to be
6 never said that? 6 fact, or it didn't feel that way in the room.
7 A. No, it doesn't surprise me. 7 Q. Okay. So when Ms. Sebert says
8 Q. But you heard that statement from 8 that Mr. Janick said Dr. Luke raped Katy
9 him? 9 Perry, he did not say that, correct?
10 A. Yes. 10 MR. PEARL: Objection. Asked
11 Q. Which he said he had heard that 11 and answered.
12 from someone? 12 A. I mean, I heard back what she said
13 A. I recall him saying something that 13 -- of what she said and, you know, I think I
14 felt like he had heard -- like it's a rumor. 14 answered for you the best that I can.
15 Q. Right. You certainly didn't come 15 Q. Right. My question is really
16 out of that room thinking he had personal 16 whether or not he said it as a fact --
17 knowledge of that it was a fact that Mr. 17 MR. SNYDER: Objection. Asked
18 Gottwald raped Katy Perry? 18 and answered.
19 A. Can you just rephrase that so I 19 Q. -- as she has portrayed it?
20 can answer it properly? 20 A. No, he didn't.
21 Q. Sure. So you didn't take from his 21 Q. Okay.
22 comment that he actually knew -- 22 MR. SNYDER: I will also object
23 A. No. 23 to "as she portrayed it." I am just
24 Q. -- that Mr. Gottwald raped Katy 24 going to ask you repeatedly to not put
25 Perry? 25 your opinions and factual predicates
Page 40 Page 41
2 into questions because then my client, 2 the following question, did Kesha's
3 when she answers the question, could 3 testimony substantially comport with
4 be interpreted by someone as adopting 4 your recollection of what happened
5 your subjective views of the testimony 5 that day in the studio? That might be
6 as just said, as she portrayed or the 6 an interesting question if the truth
7 factual predicates. So. 7 is the goal here.
8 MS. LEPERA: Let me clarify. As 8 MS. LEPERA: Orin, with all due
9 she said it. As she testified. 9 respect, and we have known each other
10 MR. SNYDER: That's your 10 a long time, it is a very different
11 opinion. 11 thing to say I heard a rumor that
12 MS. LEPERA: No, I am quoting 12 someone was raped. This is a very
13 it. He didn't say as she -- 13 serious accusation. These are very
14 MR. SNYDER: The question you 14 serious issues.
15 are not asking her is do you 15 A. And I answered your question, and
16 substantially agree with your -- with 16 we all know how serious this is here.
17 Kesha's characterization of the 17 Q. Exactly. And then to say it is a
18 comments at issue. You haven't asked 18 rumor versus to say it is a fact and I know.
19 that question but you are trying to 19 That's what I am asking.
20 put words in her mouth to conform to 20 A. I answered you.
21 your theory of the case. 21 MR. SNYDER: I didn't hear her
22 MS. LEPERA: No, not at all. 22 testimony saying it is a fact and I
23 MR. SNYDER: If you want to ask 23 know it. That's what you are you
24 her, which is actually if you are 24 telling my witness she said.
25 searching for the truth, you would ask 25 MS. LEPERA: I am just reading
11
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Page 42 Page 43
2 it. 2 Do you have any other answer
3 MR. SNYDER: Well, I have a 3 other than the one you just gave?
4 different interpretation of that 4 MS. LEPERA: Can you not
5 testimony, actually. 5 interrupt me?
6 I will be right back. Keep 6 MR. SNYDER: You know, the
7 going. 7 witness is here, but the tricking and
8 MS. LEPERA: Do you want a 8 trapping you are doing is not really
9 break? 9 appropriate.
10 MR. SNYDER: No. Just grabbing 10 MS. LEPERA: There is no
11 snacks. 11 tricking and trapping.
12 Q. So when Ms. Sebert sent you the 12 MR. SNYDER: She said it says
13 text that we were looking at previously in 13 what it says. You want to argue
14 Exhibit 3, '024834. 14 whether this is -- we all know what
15 A. Yes. 15 the legal issue is. Is it a fact --
16 Q. Did you -- there is nothing stated 16 MS. LEPERA: Correct.
17 in this text, is there, that there is a rumor 17 MR. SNYDER: So don't try to get
18 that she was raped by the same man, correct? 18 my witness to adopt your theory in the
19 MR. SNYDER: Objection. 19 case. She is not going to do it.
20 Argumentative. You can answer. 20 MS. LEPERA: No, I am asking
21 A. It says what it says. 21 what she understood.
22 Q. She is stating that Ms. Perry was 22 MR. SNYDER: She gave you the
23 raped by Mr. Gottwald, right? 23 answer. She said it says what it
24 MR. SNYDER: Objection. Asked 24 says.
25 and answered. 25 MS. LEPERA: That's not an
Page 44 Page 45
2 answer. 2 A. Um-hum.
3 A. I understand this to say that Katy 3 Q. What are you saying; are you
4 Perry was raped by Dr. Luke. 4 referring back to the statement she made --
5 Q. Okay. Thank you. 5 MR. SNYDER: Wait. Wait. Wait.
6 We are moving along here. You 6 Isn't the "it's sick" from 615?
7 will be happy to know. 7 THE WITNESS: Yes, from Kesha.
8 Had you ever communicated with 8 It is not me.
9 anyone else that -- 9 MS. LEPERA: That's from Kesha?
10 A. Can I just make something clear 10 MR. SNYDER: Right. Don't we
11 about this? I understand it to say that in 11 know that 615 is Kesha?
12 that's what it means. But it is not what I 12 MR. PEARL: That's Kesha.
13 understood when she wrote it to me. I form 13 Q. Then the next statement, the next
14 my own opinions about each and every person 14 page, I believe, is from you to her,
15 and everything separately and differently. 15 saying, quote, "She is probably
16 So I just want to make it clear that it's 16 really afraid to lose everything."
17 just what I understand about what that says. 17 Do you see that?
18 It's just a sentence that means that, but I 18 A. Yes.
19 don't understand it to mean for fact that 19 Q. Is that you saying that about
20 that's what happened. 20 Ms. Perry?
21 Q. Okay. So can I just ask you, the 21 A. Yes.
22 next page of this text, it says, '0024835, 22 Q. Okay. So were you of the mindset
23 Bates stamp number, from you to Ms. Sebert, 23 that she had been raped by Mr. Gottwald and
24 and you are saying, quote, "it's sick" close 24 was afraid to say something?
25 quote. 25 MR. PEARL: Objection. Vague
12
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Page 46 Page 47
2 and ambiguous. Lacks foundation. 2 Q. Ms. Germanotta, did you ever see
3 Calls for speculation. 3 Ms. Sebert other than the two incidents that
4 MR. SNYDER: You may answer. 4 you have described in person having a
5 A. I was really and truly trying to 5 conversation of a personal nature?
6 be supportive of her and listen to her. It 6 A. Yes.
7 is my personal opinion with rape survivors 7 Q. Can you identify when that was?
8 that it's very difficult to come forward, and 8 A. I saw her like really briefly. I
9 if she hadn't come forward or if she hadn't 9 just saw her in passing at Center Staging or
10 told me herself or I hadn't seen anything, I 10 SAR. A rehearsal space.
11 would never make an assumption like that as 11 Q. You had a personal conversation?
12 someone that works in that space and that 12 A. She just said hello quickly, and I
13 advocates for women who are sexual assault 13 actually rushed to get out because I was
14 survivors. I was speaking with Kesha in a 14 working.
15 very casual personal way so that I can help 15 Q. I am only looking for any, not
16 her feel not alone. 16 casual, you said you saw her approximately
17 Q. Right. And, clearly, obviously, 17 ten times. I am not looking for any casual
18 there is a kinship and a connection that you 18 interaction, only something where you had a
19 felt with her based on your role as an 19 conversation about her personal experiences.
20 advocate in this industry? 20 A. No, not that I recall.
21 A. Absolutely. 21 Q. Now, the time when you saw Ms.
22 MS. LEPERA: Let's take a short 22 Sebert in Mr. Gottwald's studio, home studio
23 break. 23 scenario, did you know whether or not she was
24 (Whereupon, a recess was held.) 24 living there?
25 BY MS. LEPERA: 25 A. No.
Page 48 Page 49
2 Q. Did you know whether there were 2 the first time, and I met him briefly at
3 other song writers living there or working 3 Jimmy Iovine's showcase party.
4 there such as Kojack? 4 Q. Which happened first, do you
5 A. No, I just saw her in the back in 5 remember?
6 her underwear on a bed. 6 A. I don't recall and it was very
7 Q. Do you know whose room that was 7 brief. Just a hello. I was introduced with
8 and whether there were other songwriters and 8 a handshake or someone brought me over to
9 persons living in that house at the time? 9 him. Something like that.
10 MR. PEARL: Objection. 10 Q. Both times?
11 Compound. 11 A. Sorry?
12 MR. SNYDER: And asked and 12 Q. Both times?
13 answered. 13 A. Yes, both times.
14 A. No, I don't know. 14 Q. Okay. And did you have any
15 Q. I take it you didn't see any 15 conversations with him about Ms. Sebert?
16 interaction between Ms. Sebert and Mr. 16 A. No.
17 Gottwald? 17 Q. Did you have -- ever have any
18 MR. PEARL: Objection. Vague 18 conversations with him about any issues
19 and ambiguous. 19 related to sexual assault or abuse?
20 A. No. 20 A. No.
21 Q. Now, in terms of Mr. Gottwald, 21 Q. You never worked with him,
22 what, if any, times -- when have you met him, 22 correct?
23 if ever? 23 A. No.
24 A. I met him that day that I 24 Q. I mean, you would agree with me,
25 mentioned, the same day that I saw Kesha for 25 wouldn't you, that the accusation of rape is
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2 a very serious thing? 2 to answer it again or if you have a
3 A. Yes. 3 different answer, go ahead. But it's
4 MR. PEARL: Objection. 4 the last time I am going to allow you
5 A. Yes, ma'am, it is. 5 to answer the question.
6 Q. And is it something that is 6 So do you have any different
7 horribly damaging to a person's reputation? 7 answer?
8 MR. PEARL: Objection. Lacks 8 MR. PEARL: Hold on. I will
9 foundation. 9 object that it lacks foundation.
10 Q. An accusation of rape. Is an 10 Vague and ambiguous. Doesn't refer to
11 accusation of rape something that is 11 false allegations.
12 seriously damaging to someone's reputation, 12 MS. LEPERA: Are you done?
13 particularly when made public? 13 Q. The question is, have you ever
14 MR. PEARL: Objection. Lacks 14 stated to anyone that what happened with
15 foundation. 15 respect to the accusations against Mr.
16 A. I wouldn't be at liberty to make a 16 Gottwald bruised his reputation?
17 factual answer about that. 17 MR. SNYDER: It's a different
18 Q. You don't know whether or not that 18 question now.
19 is something -- if a statement that so and so 19 MS. LEPERA: It is a different
20 raped so and so, particularly in a public 20 question.
21 arena, that that statement wouldn't quote 21 A. I don't recall.
22 bruise their reputation? 22 Q. Do you have any reason to doubt
23 MR. SNYDER: You just asked the 23 saying something like that?
24 question. She gave her answer. She 24 MR. PEARL: Objection. Asked
25 is here as a non-party. If you want 25 and answered.
Page 52 Page 53
2 A. Any reason to doubt, yes, I don't 2 of it, whether it is true or not, it's going
3 fully remember. 3 to damage their reputation, correct?
4 Q. You would agree with me, wouldn't 4 MR. SNYDER: Objection. Asked
5 you, that Mr. Gottwald's reputation has been 5 and answered for the third time. You
6 bruised by virtue of the allegations against 6 may answer again.
7 him? 7 A. I do not think that I am at
8 MR. SNYDER: Objection. Asked 8 liberty to speak for the entire world on what
9 and answered. 9 they think about this issue.
10 MR. PEARL: Objection. Vague 10 Q. Okay. Let me ask you this, with
11 and ambiguous. Lacks foundation. 11 respect to Mr. Gottwald himself, you have
12 MR. SNYDER: You can answer 12 absolutely no personal knowledge or
13 again. 13 information as to any interaction between him
14 A. Reputation, if you are asking 14 and Ms. Sebert, correct, physical or
15 about his reputation in the world, I don't 15 otherwise?
16 feel at liberty to speak for the entire 16 A. Yes, I do have knowledge.
17 world. So if you are asking what my view is 17 Q. What is the knowledge that you
18 of his reputation, I made my view of him and 18 have of their physical interaction?
19 his reputation when I saw her in that back 19 A. She told me that he assaulted her.
20 room. That was an image that -- of something 20 Q. No, I understand that. I mean
21 that happened to me, and I felt and knew in 21 your personal knowledge. You don't have any
22 my heart that she was telling the truth, and 22 facts other than what she said to you to
23 I believe her. 23 support that, correct?
24 Q. Okay. So but the question really 24 A. Well, you know -- when men assault
25 is, regardless of that, if someone is accused 25 women, they don't invite people over to
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Page 54 Page 55
2 watch -- 2 not horrible.
3 Q. I understand. 3 A. You are suggesting that she is
4 A. -- as witnesses. 4 lying.
5 Q. I understand. 5 Q. I am suggesting that if we have a
6 A. And when this happens in this 6 dispute between two people and one says it's
7 industry, it is kept extremely secret, and it 7 true and one says it's false, you don't know
8 is compounded by contracts and manipulative 8 -- you may believe, but you don't know the
9 power scenarios that actually include this 9 facts of what happened?
10 very situation that we are all in right now. 10 A. I believe it to be true.
11 Q. But, again, there are people that 11 Q. I understand. But you don't have
12 are falsely accused of rape, aren't there? 12 any factual knowledge?
13 You think there has never been a false 13 A. Oh, I have factual knowledge of
14 accusation of rape? 14 her depression. I have factual knowledge of
15 MR. SNYDER: Objection; 15 her need for support and love. I have
16 argumentative. You don't have to 16 factual knowledge of the spiral that I
17 answer the question. You don't have 17 watched that girl go down. I have factual
18 to answer that question. 18 knowledge of trauma. I am informed and
19 A. You -- how about all of the women 19 intelligent about this issue. That girl has
20 that are accused of being liars and how she 20 experienced serious trauma and she is in the
21 was slut shamed in front of the world, how 21 middle of it right now. And you are all a
22 about that? 22 party to it.
23 Q. How about a situation where it's 23 Q. You are not knowledgeable of the
24 not true, and I am not suggesting that it 24 source of her trauma?
25 doesn't happen, and I am not suggesting it's 25 A. Oh, oh, oh, ma'am, you are not. I
Page 56 Page 57
2 have lived it. 2 argumentative.
3 Q. The facts -- 3 A. Why on earth would this girl tell
4 A. I have lived it. 4 the entire world that this happened? Why on
5 Q. The facts of a situation, if 5 earth? Do you know what it's like for
6 someone were to say that your father raped 6 survivors? Do you know what it's like to
7 someone and you knew it was false and that 7 tell people? Don't you role your eyes at me.
8 person had all these trauma symptoms, okay, 8 You should be ashamed of yourself.
9 and the same ones, perhaps, the same trauma 9 Q. I am not rolling my eyes.
10 symptoms, but you knew your father didn't do 10 MR. SNYDER: Let's take a break.
11 it. 11 Q. No, I am not ashamed of myself at
12 A. How would I know my father didn't 12 all.
13 do it? 13 MR. SNYDER: Let's take a break.
14 Q. Would you automatically believe he 14 (Whereupon, a recess was held.)
15 did? 15 BY MS. LEPERA:
16 A. If my father did it, then he did 16 Q. Ms. Germanotta, did you ever meet
17 it. 17 Ms. Sebert's mom, Pebe Sebert?
18 Q. I understand but would you 18 A. I don't recall.
19 automatically believe it; would you 19 Q. Did you ever indicate to either
20 automatically presume it to be true? 20 Kesha Sebert or Pebe Sebert that they can use
21 A. I believe her. 21 your name in documents saying that if Mr.
22 Q. I understand. 22 Gottwald didn't let Kesha out of certain
23 A. And I know it to be true. 23 contracts you were you going to go publicly
24 Q. You weren't there, correct? 24 out to say that he abused her?
25 MR. SNYDER: Objection; 25 MR. PEARL: Objection. Lacks
15
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Page 58 Page 59
2 foundation. 2 documents from a multiplicity of
3 A. I don't know. 3 persons including retweets and
4 MR. PEARL: Vague and ambiguous. 4 comments below retweets.
5 And compound. 5 MS. LEPERA: Yes.
6 (Whereupon, Germanotta Exhibit 6 MR. SNYDER: What we can
7 4, collection of documents was marked 7 stipulate to is where it reads
8 for identification as of this date by 8 xoxo,Joanne@ladygaga, and there is
9 the Reporter.) 9 text directly below, that originates
10 Q. Ms. Germanotta, I have marked as 10 from my client.
11 Exhibit 4 a series of documents that have 11 THE WITNESS: Except in the case
12 been produced in this case by us that were 12 of retweets.
13 obtained on social media. I would like you 13 MR. SNYDER: That's in the case
14 to identify, if you could, your Twitter 14 of retweets where all she is doing is
15 handle first for me, is it @ladygaga? 15 forwarding under her handle quote
16 MR. SNYDER: Xoxo, Joanne. 16 unquote third-party tweets.
17 Q. What about your Instagram handle? 17 MR. PEARL: I share in the
18 A. It's Lady Gaga. 18 objection.
19 Q. So looking at this document and 19 MR. SNYDER: But as it happens,
20 you can take your time and go through it, my 20 I don't think any of the quote
21 question is really very simple -- simply, are 21 comments close quote as that term is
22 these your comments that you posted or you 22 used in the context of social media
23 tweeted on social media in support of Kesha? 23 are attributed to her, but, rather,
24 MR. SNYDER: Objection. The 24 third-parties.
25 document pertains a multiplicity of 25 MS. LEPERA: Well, can we look
Page 60 Page 61
2 at the first page? 2 Q. That was from you. The second
3 Q. Is that your comment there? 3 page, we will just go through it quickly, is
4 MR. SNYDER: No, that's not a 4 the Instagram post by you. Is that where you
5 comment. That's a tweet. The 5 have reposted something that someone else
6 comments are what appear below the 6 tweeted on your Instagram post as opposed to
7 tweet. 7 your Twitter?
8 MS. LEPERA: I am not asking 8 A. Yes, that's my Instagram and I
9 that. 9 posted a --
10 Q. I am asking whether or not you 10 Q. A tweet from someone else?
11 made any comments on your Twitter or your 11 A. A tweet from @TeiShi.
12 Instagram that are contained in here, not the 12 Q. The next page, same -- is that the
13 comments below. 13 same scenario that you posted on your
14 MR. SNYDER: The problem is with 14 Instagram --
15 your use of the word "comments." If 15 A. Yes.
16 you call it a tweet, that's the noun 16 Q. -- a tweet that someone else had
17 that exists and may be in Webster's 17 written about Ms. Sebert?
18 dictionary by now. It is not a 18 A. Yes.
19 comment. 19 Q. Then the next page is entitled
20 Q. Is that a tweet that you posted on 20 "xoxo,Joanne Retweeted." Is that retweeting
21 or about February 20, 2016, quote, "There are 21 the Dazed article?
22 people all over the world who love you 22 A. Yes.
23 @KeshaRose. And I can say truly I am in awe 23 Q. Is the language underneath that,
24 of your bravery"? 24 "@KeshaRose is being treated like a human
25 A. Yes. 25 jukebox in a cage" from that article, or is
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Page 62 Page 63
2 that something you stated? 2 your Instagram on the next page?
3 A. That's not my words. That was 3 A. Yes.
4 written by Dazed. 4 Q. The next one, '58029 is a repost
5 Q. Okay. 5 or retweet by you of the Gavin Newsom tweet;
6 A. None of the retweets are my words. 6 is that correct?
7 Q. Got it. So, similarly, with the 7 A. I don't know really what that is.
8 next page, you are just retweeting a Time 8 It's not my words.
9 article? 9 Q. Right. But that is your tag, your
10 A. Yes. That's Time's words. 10 handle on top at the left?
11 Q. Next page there is a photo of you 11 A. Yes.
12 with Ms. Sebert, correct? 12 Q. The next page it appears that's
13 A. Yes. 13 the same content from Gavin Newsom is on your
14 Q. Is this in the Village Recording 14 Instagram; is that correct?
15 Studio? 15 A. Yes. It is a post of Gavin
16 A. Yes. 16 Newsom's post.
17 Q. Who took the picture, do you 17 Q. Okay. Then we have the next page
18 remember? 18 '030, "PeopleOverProfit." This is an actual
19 A. I don't recall. 19 tweet from you on your Twitter?
20 Q. Okay. And this is something that 20 A. Yes.
21 you actually then tweeted, correct? 21 Q. And those are your words on top,
22 A. Yes. 22 "#PeopleOverProfit you can #FreeKesha if you
23 Q. And said "Free Kesha"? 23 #FreeDrLuke Do what is RIGHT not what is
24 A. Yes. 24 better for business."
25 Q. Okay. And then you also put it on 25 A. Yes, I wrote those words.
Page 64 Page 65
2 Q. Next page, plaintiff SO58031, 2 connection with your public statements on her
3 there is a Twitter account, again, of yours 3 behalf, whether or not you would get her
4 noted, and this is the statement below that, 4 approval before you did them?
5 "@kesharose I'll be thinking of u 2nite. 5 A. I don't recall.
6 This is not over we'll stand by u until you 6 Q. She encouraged you to do them?
7 are free to live a HAPPY life. Everyone 7 A. No.
8 deserves that"? 8 MR. PEARL: Objection.
9 A. Yes. 9 Misstates the testimony.
10 Q. That's you. The plaintiff's 10 Q. No?
11 SO58035, again, this is a document that was 11 A. No.
12 from your Twitter; is that correct? 12 MR. PEARL: Argumentative.
13 A. Yes. 13 Q. So when you created this graphic,
14 Q. And did you write underneath your 14 what you were suggesting is that there is a
15 Twitter handle the words, "#FreeEveryWoman 15 sexual assault happening in this office?
16 #FreeKesha"? 16 MR. SNYDER: Objection.
17 A. Yes. 17 MR. PEARL: Objection.
18 Q. Did you create this graphic which 18 MR. SNYDER: Objection to form.
19 shows a studio and has words "This is not a 19 A. What the flyer is meant to convey
20 bedroom. This is my Office."? 20 is that the studio is a workspace for women
21 A. Yes. 21 where we should be protected and feel safe
22 Q. Did you show this to Ms. Sebert to 22 and it's not a bedroom; meaning it is not a
23 get approval for posting this? 23 place where we go that men should expect to
24 A. I don't recall. 24 have sex with us.
25 Q. Do you remember generally, in 25 Q. Okay. Was it -- okay.
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Page 66 Page 67
2 Similarly, the next page, '58038, 2 Q. "Jen is Always Right"?
3 again, from your Twitter, is that a graphic 3 A. I don't know if that's who wrote
4 and language you created, "This is not a 4 it.
5 date. This is a job interview."? 5 Q. Okay. There came a point in time
6 A. Yes. 6 where you gave an interview on Carson Daly;
7 Q. Similarly, the next page where 7 is that right?
8 there is your Twitter handle again, "This is 8 A. Yes.
9 not a bar. This is your classroom." Did you 9 Q. And did you, in that interview,
10 create that a graphic as well? 10 make certain statements with respect to
11 A. Yes, I did. 11 Ms. Sebert?
12 Q. Again, there is repeats of those 12 MR. PEARL: Objection. Vague
13 three graphics on your Instagram; is that 13 and ambiguous. Lacks foundation.
14 correct? 14 Q. Did you make any statements in
15 A. Yes. 15 that interview with Ms. Sebert?
16 Q. The next three pages. Okay. And 16 A. I answered questions.
17 with respect to '58037, is that a Twitter -- 17 Q. Did any of the questions result in
18 your Twitter handle, and did you tweet, 18 answers about Ms. Sebert and her situation
19 quote, "The big problem: It's tough to get 19 and controversy with Dr. Luke?
20 courts to believe rape victims"? 20 A. Yes.
21 A. Yes, I tweeted that. It looks 21 Q. You have on -- if you can turn to
22 like, though, because it is in quotes, I 22 the page right before, PLTS058042. Is this
23 can't be sure, I would have to look at the 23 something that you posted on your Twitter,
24 article, but it looks like I was quoting the 24 "Do the right thing@sony#PeopleOverProfit"?
25 writer of this Vox. 25 A. Yes, this is a quote tweet. So
Page 68 Page 69
2 the Sony music to drop Dr. Luke article that 2 have to be eradicate some of the contractual
3 was on thewrap.com is inside of the tweet, 3 relationships, is that --
4 and I wrote, prayer hands, "Do the right 4 MR. PEARL: Objection. Calls
5 thing@sony#PeopleOverProfit." 5 for a legal conclusion.
6 Q. Supporting the dropping of Dr. 6 Q. -- what you were hoping would
7 Luke, is that the inference? 7 occur?
8 A. No. 8 MR. PEARL: Objection. Calls
9 Q. When you said "Do the right thing 9 for a legal conclusion. Lacks
10 @sony," what did you mean by that? 10 foundation.
11 A. Well, I wanted Sony to stand by 11 A. I was hoping that Kesha would be
12 Kesha. 12 freed from her contract.
13 Q. And do what? 13 Q. Contracts?
14 A. And help free her. 14 A. So that she would be able to be on
15 Q. How? 15 her own and not under his control, because
16 A. Well, unfortunately, no matter who 16 her being under his control is making her
17 I talked to and who I asked internally, it 17 sick, and the only way to keep her from
18 turns out that not even Sony could free 18 getting more sick and to help her survive is
19 Kesha. That Dr. Luke had to. 19 to get her out of that toxic situation where
20 Q. When you say "free," do you mean 20 she is being abused.
21 from the contract? 21 Q. Do you have any knowledge or
22 A. From not just a contract but from 22 history of Ms. Sebert's background before she
23 a completely abusive, toxic, and terrifying 23 met Dr. Luke?
24 situation. 24 A. No.
25 Q. So to do that, though, it would 25 Q. Do you have any knowledge as to
18
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2 whether or not there was any prior sexual 2 in any way prior to meeting Dr. Luke.
3 abuse? 3 A. I know she is from the country.
4 MR. PEARL: Objection; 4 Q. Right. I am talking about
5 irrelevant. 5 anything personal with respect to her life.
6 MS. LEPERA: Whether she told 6 A. No.
7 her. 7 Q. So there was no discussions about
8 MR. PEARL: I am going to 8 anything having to do with her private life
9 caution you that if you start talking 9 or sexual history with you?
10 about Kesha's background and things 10 MR. PEARL: Objection.
11 that happened to her as a child, I 11 Harassing.
12 will stop the deposition and call the 12 A. About what?
13 judge. 13 MR. PEARL: Asked and answered.
14 MS. LEPERA: I just asked her 14 Q. I am asking whether or not she
15 whether she told her. I am entitled 15 told you anything about it. That's all.
16 to know that. 16 MR. PEARL: Irrelevant;
17 MR. PEARL: It is totally 17 inappropriate.
18 irrelevant. It is harassing and so 18 A. I don't recall. I really don't
19 inappropriate. 19 understand the question, either.
20 MS. LEPERA: It is so not 20 Q. Well, there is a point in time
21 irrelevant. 21 which she met Dr. Luke which you don't know
22 MR. PEARL: It is totally 22 the date, but whatever.
23 inappropriate. 23 I am asking, did she discuss with
24 Q. I am just asking whether or not 24 you any of the events of her life prior to
25 she gave you any information about her life 25 meeting Dr. Luke that were either of a
Page 72 Page 73
2 personal nature or of a nature of abuse? 2 foundation. Calls for speculation.
3 MR. PEARL: Objection. 3 MR. SNYDER: I would
4 Q. If any. 4 respectfully ask if you can show her
5 A. I don't recall. 5 the document that might refresh her
6 Q. Okay. That's all I am asking. 6 recollection.
7 You obviously have no knowledge or 7 Q. It is in the binder. It is
8 information about her prior life, correct? 8 KRS_ESI --
9 MR. SNYDER: Objection to form. 9 MR. SNYDER: All I am saying is,
10 You can answer. 10 I can tell you she is not going to
11 A. That's such a broad question about 11 have a present recollection of the
12 her life. I know she is from the country. I 12 verbiage in particular texts.
13 know she loves music. I know she has a nice 13 MS. LEPERA: Sure.
14 family. I mean, what do you want me to 14 MR. SNYDER: So if you show her
15 answer here? 15 the text and see if it refreshes her
16 Q. Have you met the family? 16 recollection, then she will answer the
17 A. Not that I know -- no, not that I 17 question. Thank you.
18 can recall. 18 Q. Let's pull out KRS_ESI_025161 to
19 Q. Do you recall receiving a text 19 '63, 0025163. Do you have it? I know it's a
20 from Ms. Sebert to you in and around March of 20 big binder.
21 2016 where she said, quote, here is the plan 21 Is there a text message on that
22 if you are down for it. Spam the world on 22 page from you to Ms. Sebert where you say,
23 all social media at Sony tomorrow? Like 23 quote, "I won't post anything without your
24 cray, close quote? 24 approval ok?"
25 MR. PEARL: Objection. Lacks 25 A. Yes.
19
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2 Q. Did you say that? 2 time.
3 A. Yes. If it says it here I said 3 MR. SNYDER: You went backwards.
4 it, I said it. 4 MS. LEPERA: I am just trying to
5 Q. I am asking you to turn to 5 go faster.
6 KRS_ESI_025304 to '309. 6 MR. SNYDER: Again, I stipulated
7 MR. SNYDER: It is dated 7 that all of the texts from LG with the
8 3/4/2016. 8 201 area code are from her. So her
9 MS. LEPERA: Yes, March 4, 2016. 9 testimony for the purpose of trial is
10 Q. Is there a text from you to Ms. 10 that she wrote all of those words on
11 Sebert that says, quote, "So u feel like we 11 those texts. So if you are just going
12 should keep pressuring them from the 12 to ask her whether she wrote them, we
13 outside?" "Or did the flyers work?" 13 already stipulated to that.
14 Did you write that to Ms. Sebert? 14 If you have questions about what
15 A. Yes. 15 she wrote, obviously, she will answer
16 Q. Who were you speaking about 16 your questions.
17 pressuring? 17 Q. So, obviously, as Mr. Snyder just
18 A. Dr. Luke. 18 said, the statement that you made, quote, "So
19 Q. You said "them." Is "them" 19 he's buckling" ellipsis "Because he's
20 Dr. Luke? 20 watching his reputation bruise." "Cuz we're
21 A. Yes, Dr. Luke and Sony. 21 not backing down jigga!!!" is a statement
22 Q. And KRS_ESI_0025293 to '96, 22 that you wrote, correct?
23 please. 23 A. Um-hum.
24 MR. SNYDER: One second, please. 24 Q. When you said "his reputation was
25 MS. LEPERA: Sure, take your 25 being bruised," what did you mean by that?
Page 76 Page 77
2 A. I was speaking to her personally 2 the world, of giving a voice to somebody that
3 about, you know, watching the situation. 3 needed a voice, because she is a sexual
4 But, you know, I stand by my testimony that 4 assault survivor, and she deserves to have a
5 Kesha and I had a personal relationship 5 voice. It was in service of not only the
6 during this time and these texts reflect the 6 music industry community but of the sexual
7 personal nature of it. I was speaking to her 7 assault survivor community, and I was
8 as a supporter. I always wanted her to feel 8 steadfastly passionate about making sure that
9 loved. I know during this time that she felt 9 she never felt alone.
10 very attacked by the world and that her 10 Q. Okay. Can you turn to
11 character was being attacked and that she was 11 KRS_ESI_0024918 to '20, please.
12 being called a liar and that she was doing 12 There is a text, as we have
13 this to just get out of a deal, and I was 13 authenticated, that you wrote on February 29,
14 there for her, and I said a lot of things to 14 2016, where you say, quote, "Can you call
15 comfort her. 15 me --" to Ms. Sebert, quote, "Can you call me
16 Q. In the internal text 16 today sometime I know you are resting I just
17 communications? 17 think this would make Luke really unravel and
18 A. Yes. 18 the more he unravels the more guilty he
19 Q. There were also a lot of external 19 looks" ellipse, "Let's get this dude." Close
20 postings by you supporting her position, 20 quote.
21 correct? 21 Did you write that?
22 A. My external postings are not meant 22 A. Yes.
23 in any way to damage anyone's reputation. 23 Q. When you say "Let's get this
24 All of my postings, all of my retweets were 24 dude," what did you mean by that?
25 in the spirit of informing young women around 25 A. I wanted Dr. Luke to let her go.
20
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2 Q. What did you mean by let's get 2 that if you let -- if you let her out
3 him? 3 of her contract she won't accuse you
4 A. I wanted to get him to break so 4 of certain things.
5 that he would let her go. 5 Q. I am just asking whether or not
6 Q. Do you have any knowledge or 6 you were aware of any of that predicate took
7 information about what occurred prior to Ms. 7 place --
8 Sebert's filing of her claims against Dr. 8 MR. PEARL: Are you aware that
9 Luke in connection with statements that were 9 you pled that? You are asking if she
10 made that if you let me out of my contract, I 10 was aware that it happened?
11 won't say certain things? 11 MS. LEPERA: Correct. Yes.
12 MR. PEARL: Objection. 12 MR. PEARL: Are you aware that
13 Q. Are you aware of any of that back 13 she pled that?
14 story? 14 BY MS. LEPERA:
15 MR. PEARL: Objection. Lacks 15 Q. Are you aware it happened or
16 foundation. Assumes facts not in 16 discussed it with her. That's all.
17 evidence. Introduces false facts. 17 A. I don't recall.
18 A. I don't -- 18 Q. That's fine. That's fine.
19 MR. PEARL: Settlement 19 Did you ever send Sony an actual
20 privilege. 20 letter asking that they, effectively, free
21 MS. LEPERA: Well, actually, in 21 Kesha, you know, from the contract with Dr.
22 our pleading, we have made it very 22 Luke?
23 clear that during the course of the 23 A. I don't recall if I personally
24 year prior to her filing there were 24 sent it to them. But I did write them a
25 statements made to the very effect 25 letter.
Page 80 Page 81
2 Q. Okay. So there was a letter that 2 what? You have given me --
3 you drafted on behalf of Kesha, whether you 3 MS. LEPERA: I assume --
4 sent it or someone sent it on your behalf, 4 MR. SNYDER: If you want here to
5 asking for Sony to let her out of the 5 read documents, give her documents,
6 contract? 6 and she will read them. I am not
7 MR. SNYDER: That's compound and 7 sifting through --
8 you said on her behalf. Why don't you 8 MS. LEPERA: Did you just
9 just ask her what happened? 9 basically --
10 MR. PEARL: I join in the 10 MR. SNYDER: I apologize. I
11 objection. 11 didn't see the cup there.
12 Q. Can you pull first KRS_ESI_0024862 12 MS. LEPERA: You just basically
13 to '64. 13 threw --
14 MR. SNYDER: Would have been 14 MR. SNYDER: I didn't throw.
15 helpful if you had a smaller binder. 15 MS. LEPERA: -- a binder to me,
16 Very cumbersome. 16 and this is this whole thing is about
17 MS. LEPERA: How? 17 sexual abuse, and you just threw a
18 MR. SNYDER: The way you 18 binder at me, knocked over my coffee
19 generally do it is you actually give 19 cup.
20 the exhibits out in advance as opposed 20 MR. SNYDER: Your coffee cup is
21 to giving a non-party -- 21 empty. I didn't throw anything.
22 MS. LEPERA: You have them. 22 MS. LEPERA: You did. You threw
23 Sandra Crawshaw has them. Sorry, I 23 the binder. You slammed it down on
24 can't help you with that. 24 me. Orin, come on. We have known
25 MR. SNYDER: Can't help me with 25 each other a long time. The computer
21
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Page 82 Page 83
2 fell. 2 Let the record reflect that when
3 MR. SNYDER: Excuse me. I have 3 you put the binder down no matter how
4 watched you throughout this 4 soft, it has a loud thump. I did not
5 deposition, your conduct is 5 throw --
6 underhanded and inappropriate -- 6 MS. LEPERA: I didn't see the
7 MS. LEPERA: No, it is not. 7 computer fall or the coffee cup fall.
8 MR. SNYDER: -- in the 8 MR. SNYDER: Excuse me. Excuse
9 questioning of this witness. I did 9 me. I did not throw it at you. I did
10 not throw anything. It happens to be 10 not move an ounce of liquid in any
11 a binder -- excuse me. 11 coffee cup and for you to suggest that
12 MS. LEPERA: No, I will not 12 --
13 excuse you. 13 MS. LEPERA: Why are you being a
14 MR. SNYDER: If you won't let me 14 bully?
15 talk, we will leave the deposition, 15 MR. SNYDER: For you to suggest
16 and we will call the judge. Let me 16 that there is some sexual assault
17 say something. 17 going on here because I put a binder
18 MS. LEPERA: Why do you have to 18 down --
19 defend yourself? 19 MS. LEPERA: I didn't say sexual
20 MR. SNYDER: Let me tell you 20 assault. I said this a topic of the
21 something; the binder weighs about six 21 day. And for you to be violent like
22 pounds. Therefore, when I placed it 22 that.
23 in front of you, it had the physical 23 MR. SNYDER: I was not violent.
24 effect, as a matter of physics, to 24 MS. LEPERA: Yes, you were. I
25 fall on the table. 25 don't want to get into it anymore.
Page 84 Page 85
2 Forget it. I forgive you. 2 on substantively? That's all. Forget
3 MR. SNYDER: We have limited 3 about the throwing. Just please don't
4 time in this deposition. 4 do it again.
5 MS. LEPERA: So let's go. 5 MR. SNYDER: I didn't throw
6 BY MS. LEPERA: 6 anything. I handed you back the
7 Q. I would like you to look -- 7 binder that's too big.
8 MR. SNYDER: When you give me a 8 MS. LEPERA: And the coffee is
9 shopping bag of documents and sift 9 all the way over my exhibit, by the
10 through them to find them. 10 way.
11 MS. LEPERA: We gave these 11 MR. SNYDER: There is no coffee.
12 documents to her prior counsel. 12 MS. LEPERA: There is no coffee?
13 MR. SNYDER: Hand her exhibits, 13 MR. SNYDER: Now there is.
14 and she will look at the exhibits. 14 MS. LEPERA: Come on.
15 MS. LEPERA: I did this so that 15 MR. SNYDER: Good one,
16 we wouldn't have exhibits like this 16 Christine. Leopards don't change
17 and sit here all day and go one by 17 their spots.
18 one. Is that what you would have 18 MS. LEPERA: We have known each
19 preferred? Now maybe we could have 19 other since what --
20 put in two binders; I apologize for 20 MR. SNYDER: Doesn't matter.
21 that. 21 You are up to your same old tricks.
22 MR. SNYDER: I prefer to not 22 MS. LEPERA: It's okay, Orin.
23 have to sift -- 23 The reality will be reality.
24 MS. LEPERA: Is it possible to 24 MR. SNYDER: I think the reality
25 turn to that document so we can move 25 is clear on the record here today much
22
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Page 86 Page 87
2 to your regret. 2 A. Yes.
3 MS. LEPERA: No, not really. I 3 Q. Was that a reference to getting
4 know you think that. 4 Dr. Luke out of Sony?
5 MR. SNYDER: So why don't we -- 5 MR. PEARL: Objection. Vague
6 BY MS. LEPERA: 6 and ambiguous. Calls for a legal
7 Q. KRS_ESI_0024862-'64. 7 conclusion.
8 MR. SNYDER: I don't know what 8 A. I was speaking to her in a
9 document you just said. I can't 9 personal capacity and encouraging her that we
10 memorize numbers. 10 were going to do everything that we could to
11 MS. LEPERA: I will say it 11 help her.
12 again. All you have to do is ask me. 12 Q. Right. But my question was, when
13 MR. SNYDER: Please. 13 you say "get him out," what did you mean by
14 MS. LEPERA: KRS_ESI0024862-'64. 14 that?
15 Were you able to find it? 15 A. What I meant was whether he let
16 Again, I would have been happy to give 16 her go or Sony let him go or -- yeah, that
17 you these documents in any way. We 17 was it because she couldn't let herself go.
18 tried to email. We didn't get much 18 So that would have been my -- I would have
19 back and forth and you are probably 19 liked for them -- for them to just listen
20 busy. 20 when she asked to be let go, but there
21 Q. Is this a text that you wrote to 21 weren't a lot of options, unfortunately.
22 Ms. Sebert that says, quote, "were gonna find 22 Q. Right. My question is really
23 a way either get you out or get him out"? 23 simply, when you say "were going to find a
24 A. Yes. 24 way to get you out or get him out," out of
25 Q. Do you see that? 25 what? Him out of what?
Page 88 Page 89
2 2 MS. LEPERA: I think we are, you
A. Out of the -- out of whatever
3 3 know, pretty close to finished. I
situation that was keeping him in control of 4
4 her life and career. don't know what my timeframe is, but
5 probably close to it. So why don't we
5 Q. Did you mean out of Sony? 6 just take a break. Let's see if I
6 MR. PEARL: Objection. Asked 7 have anything else.
7 and answered. Calls for a legal 8 (Whereupon, a recess was held.)
8 conclusion. Calls for speculation. 9 MS. LEPERA: I am going to just
9 MS. LEPERA: I am asking what 10 reserve any additional time after Mr.
10 11 Pearl questions, assuming questions.
she meant.
11 12 If not, I have nothing further.
A. I thought I made it clear that --
12 13 MR. PEARL: I have nothing.
either that she would get let out of the deal 14
13 or he would get let out of the deal. MS. LEPERA: Then we are done.
15 (Whereupon, at 4:29 p.m., the
14 Q. Get let out of which deal? 16 Examination of this Witness was
15 A. Out of his deal. 17 concluded.)
16 Q. With who? 18
17 A. With -- is it Sony with his 19
18 company, I guess, or whatever. 20 __________________________
19 Q. Okay. That's what I am asking, STEFANI GERMANOTTA
20 21
thank you.
21 A. So whatever scenario we could find Subscribed and sworn to before me
22 this _____ day of ________, 2017.
22 or think of that could possibly help her and 23 __________________________
23 there were not a lot.
24
NOTARY PUBLIC
Q. Okay. That's really all I was 24
25 looking for. 25
23
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Page 90 Page 91
1 1
2 EXHIBITS 2 CERTIFICATE
3 3
4 4 STATE OF NEW YORK )
5 EXHIBIT EXHIBIT PAGE : SS.:
6 NUMBER DESCRIPTION 5 COUNTY OF NASSAU )
7 6
Exhibit 1 KRS_ESI0024484 through 9
8 7 I, REBECCA SCHAUMLOFFEL, a Notary
'0025887
9 8 Public for and within the State of New York,
Exhibit 2 LG0001 through '004 10
10
9 do hereby certify:
Exhibit 3 KRS_ESI_0024810 27
10 That the witness whose examination
11 through '4873
11 is hereinbefore set forth was duly sworn and
12 Exhibit 4 Collection of 58
12 that such examination is a true record of the
13 documents 13 testimony given by that witness.
14
14 I further certify that I am not
15
15 related to any of the parties to this action
16 INDEX 16 by blood or by marriage and that I am in no
17
17 way interested in the outcome of this matter.
18 EXAMINATION BY PAGE 18 IN WITNESS WHEREOF, I have hereunto
19
19 set my hand this 15th day of September, 2017.
20 MS. LEPERA 4 20 __________________________
21 21 REBECCA SCHAUMLOFFEL
22 22
23 INFORMATION AND/OR DOCUMENTS REQUESTED 23
24 INFORMATION AND/OR DOCUMENTS PAGE 24
25 (NONE) 25
Page 92
1 ERRATA SHEET FOR THE TRANSCRIPT OF:
2 Case Name: Lukasz Gottwald v. Kesha Rose Sebert
3 Dep. Date: September 12, 2017
4 Deponent: Stefani Germanotta
5 CORRECTIONS:
6 Pg. Ln. Now Reads Should Read Reason
7 __ __ _________ ______________ __________
8 __ __ _________ ______________ __________
9 __ __ _________ ______________ __________
10 __ __ _________ ______________ __________
11 __ __ _________ ______________ __________
12 __ __ _________ ______________ __________
13 __ __ _________ ______________ __________
14 __ __ _________ ______________ __________
15 __ __ _________ ______________ __________
16 __ __ _________ ______________ __________
17 _______________________
18 Signature of Deponent
19
20 SUBSCRIBED AND SWORN BEFORE ME
21 THIS____DAY OF________,2017
22 _____________________________
23 (Notary Public) MY COMMISSION EXPIRES:________
24
25
24
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Lady Gaga's Deposition in Dr. Luke's Defamation Lawsuit

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Lady Gaga's Deposition in Dr. Luke's Defamation Lawsuit

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FILED: NEW YORK COUNTY CLERK 01/29/2019 06:39 PM INDEX NO.

2 SUPREME COURT OF THE STATE OF NEW YORK

13 DEPOSITION OF STEFANI GERMANOTTA

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A 40:16 49:24 52:4 60:6 11:22 6:5,6 10:18 20:22

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TSG Reporting - Worldwide (877) 702-9580

90:16 64:8 77:4 door (1) ellipsis (1) 83:8

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69:22 71:9 47:3 41:6 67:2 35:21

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9:5,9 90:7 81:15,22 82:7,12,18 1:4,7 50:5 55:25 53:24 65:23

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MYERS (1) numerous (1) 23:10,23 24:5,11,23 Park (1) 50:7

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relate (1) REQUESTED (1) 47:13 54:9 separately (1)

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TSG Reporting - Worldwide (877) 702-9580

17:21 18:14 36:10 66:13,16 trapping (2) Twitter (12) V

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TSG Reporting - Worldwide (877) 702-9580

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