Uh-oh, it looks like they're panicking. We have an emergency motion filed by TMZ to protect who leaked them the video. And we know it was Amber. So let's go ahead and read this motion. We don't have to read all of it, but let's go ahead and start. Emergency motion to intervene by EHM productions for limited purpose of a certain journalist's privilege. EHM productions ain't the owner and operator of the celebrity news website TMZ.com to collectively TMZ by and through undersigned counsel submits this emergency motion to intervene for the limited purpose of asserting the journalist's privilege pursuant to Supreme Court rule 314. According to a published report, TMZ's former employee, Morgan Tremheim has been called to testify at trial, imminently on behalf of plaintiff Johnny Depp. Regarding information provided to TMZ by a confidential source, in violation of TMZ's and the sources rights under Virginia rule of evidence to 508 and Brown versus Commonwealth. With this motion, TMZ seeks a protective order, precluding plaintiff from eliciting from Mr. Tremine, Tremaine, Tremaine from disclosing TMZ's privileged information during the testimony. Oh, interesting. TMZ is uncertain whether Mr. Tremaine is appearing pursuant to a trial subpoena. If he is, TMZ likewise requests that the court quash the subpoena. Journalists' promises of confidentiality are vital to reporting the news. That is why the law strongly protects the ability of journalists to keep their promises, the court should permit TMZ to keep the promises it made here. TMZ is a news organization had courted in California that primarily covers entertainment and celebrity news. Yes, this video was provided to journalists at TMZ in California by a confidential source. TMZ promised this source that it would maintain their confidentiality and would not disclose their name or other information about them. TMZ makes such promises of confidentiality from time to time so that it may publish information in the public interest, and it relies on the journalist's privilege protecting the identity of confidential sources to do so. TMZ's source has not, at any time since they provided the video, waived their rights to confidentiality or indicated to TMZ that it was released from its promise of confidentiality. Yesterday, May 23, TMZ learned from a report published in radar online at 3.30pm that plaintiff in this matter intended to call Morgan Tremaine to testify very shortly. According to the radar online report, plaintiff plans to elicit testimony from Mr. Tremaine, Tremaine, regarding TMZ's confidential source in an effort to quote unquote, impeach the credibility of defendant. Mr. Tremaine was a field assignment manager with TMZ at the time the article was published, but no longer works for the company. He had nothing to do with TMZ's receded the video and on TMZ's information in behalf, Mr. Tremaine lacks first-hand knowledge of the identity of the confidential source who provided TMZ with the video. To the extent that Mr. Tremaine purports to know the identity of TMZ's confidential source, his information would be based on rumor and conjecture. Furthermore, any information that Mr. Tremaine may provide concerning TMZ's confidential source was obtained in the course of his employment with TMZ and he lacks the authority to breach TMZ's confidentiality agreement with its source. TMZ now brings this motion to enforce its and its sources rights under the journalist privilege and to prevent the unauthorized breach of that privilege. TMZ should be permitted to intervene for a limited purpose. Intervention permits an interested non-party with leave of the court to voluntarily join a lawsuit already in progress so that the non-partis interest can be defended. The intervener may seek to intervene in the litigation in full or to participate in the action for a specified limited purpose. The claim or defense of the intervener must be, quote, germane to the subject matter of the proceeding. The germane this requirement means that the intervener has an interest that is, quote, relevant or closely ally to some aspect of the litigation. Whether to permit intervention and the pending lawsuit rests in the sound discretion of the court. TMZ's interest in the litigation is not only germane but tangible and highly relevant. Namely, it seeks to preserve its statutory constitutional and common law privilege to safeguard its news gathering and confidential sources which may be challenged should its former employee take the stand and be subject to questioning. The news media is regularly permitted to intervene in instances in which it seeks to indicate its first amendment rights. Here, where the threat is to TMZ's own ability to protect its sources, the interest is direct. Moreover, TMZ's interest in protecting its privileged news gathering information is not otherwise adequately represented by the current parties to the action or by the witness or a former employee. If TMZ did not uphold the confidentiality of its sources, one would reasonably expect an oppressive effect on TMZ. It should be permitted to intervene for the limited purpose of vindicating its and its sources rights. Virginia Court recognized a privilege rooted in the first amendment protecting the relationship between journalists and their confidential sources and preventing those sources from being outed in discovery or at trial. A similar privilege exists in California where the news gathering an issue occurred. This privilege of confidentiality should yield only when the parties need for it is essential to a fair trial. The Virginia Supreme Court has held that impeachment does not qualify for does not qualify when a litigants right to impeachment evidence quote collides with the newsman's privilege of confidentiality the privilege prevails unless the parties seeking the impeachment evidence can show that it is somehow quote unquote material to an element of a party's claim or defense. Likewise, in its defamation case, a confidential source information is not essential quote unquote where it is not directly relevant to an element of the defamation claim. Let's see, TMZ or here it appears plaintiff seeks TMZ's confidential source information purely for purposes of impeaching the credibility of defendant did not because the information has anything directly to do with the elements of the underlying defamation case as noted in effort to obtain impeachment evidence for its own sake is insufficient to overcome the privilege and the question of who provided a leak tape to TMZ is irrelevant to the elements of defamation. The identity of TMZ source has no bearing on whether for example the statements plaintiff is challenging are substantially true or whether defendant acted with the requisite degree of fault for the foregoing reasons TMZ respectfully request this court to its intervene into issue in order preventing Morgan Tremine from testifying regarding TMZ's confidential source. Boom, that is very interesting in my opinion. I think that that kind of shows, I mean come on guys, who else could the source be besides the person who took the video? I think we all know who this confidential source is and I mean I would also kind of argue that TMZ is not necessarily like a legitimate news organization. They're like, they're more like a tabloid but whatever, I mean I guess that's still news. So I just found that very interesting. We'll see what happens and how the judge will order on this motion. We'll see if Mr. Tremaine is able to testify or not.