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Who is Morgan Tremaine? Here's why TMZ refuses to allow staffer to testify for Johnny Depp

'TMZ seeks a protective order precluding Plaintiff from eliciting or Mr. Tremaine from disclosing TMZ's privileged information during the testimony,' the motion states

Morgan Tremaine, a former employee of celebrity tabloid TMZ, appeared on Johnny Depp's witness list for the defamation trial between him and former wife Amber Heard. However, TMZ filed an emergency 7-page motion to block testimony from Tremaine.

"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 promise it made here. With this motion, TMZ seeks a protective order precluding Plaintiff from eliciting or Mr. Tremaine from disclosing TMZ's privileged information during the testimony," the emergency motion states.

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The story titled "JOHNNY DEPP GOES OFF ON AMBER... SMASHES WINE GLASS, BOTTLE" was posted on TMZ on August 12, 2016, when Tremaine was a field assistant manager for the portal. "The most fascinating thing about forcing Morgan onto the stand is whether or not he flips on Heard and expose whether she was a source," a case snitch told OK!.

"If Heard or someone from her team dealt directly with Morgan, it will be used by the plaintiff, Depp, to prove that she was on a campaign to discredit her estranged husband. That is powerful stuff. It's also potentially damaging for TMZ as no media organization would want a former staffer to go rogue and start exposing what are supposed to be confidential sources," the source added.

"According to a published report, TMZ's former employee, Morgan Tremaine, 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 source's rights. According to the Radar Online report, Plaintiff plans to elicit testimony from Mr. Tremaine regarding TMZ's confidential source in an effort to 'impeach' the credibility of Defendant," the motion reads.

It adds, "Mr. Tremaine was a field assignment manager with TMZ at the time the Article was published, but no longer works for the company. Mr. Tremaine purports to know the identity of TMZ's confidential source, his information would be based on rumor and conjecture. Further, 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's interest in protecting its privileged newsgathering information is not otherwise adequately represented by the current parties to the action, or by the witness, a former employee. If TMZ 'did not uphold the confidentiality of its' sources, one would reasonably expect an 'oppressive effect on' TMZ," the motion continues.

The trial is being held in a courtroom in Fairfax, Virginia, which is why the motion further states, "Virginia courts recognize a privilege, rooted in the First Amendment, protecting the relationship between journalists and their confidential sources and preventing those confidential sources from being outed in discovery or at trial." It continues, "Here, it appears that Plaintiff seeks TMZ's confidential source information purely for purposes of impeaching the credibility of Defendant and not because the information has anything directly to do with the elements of the underlying defamation case."

As per Variety, the outlet's attorneys state, "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."

"Ms. Heard, you testified yesterday that when you left the courthouse after obtaining the domestic violence restraining order against Mr. Depp, you walked out to a sea of paparazzi and cameras. Right?" Johnny Depp's lawyer Camille Vasquez asked during cross-examination. Heard replied, "That's correct." When Vasquez further asked, "You knew the media was going to be there, didn't you?" Heard responded, "No I did not. I assumed since it's a public building, there was that possibility. But I was shocked."