Fi : FIL ED Kina, Coury, WASHINGTON NOV = > aang SI SUPERIOR Coun o1 SUPERIOR COURT OF WASHINGTON COUNTY OF KING SUSAN SILVER, NO. 07-2-16253-4SEA Plaintiff, v. DECLARATION OF SUSAN SILVER IN OPPOSITION TO CHRIS CORNELL, MOTION TO EXCLUDE Defendant. REDACTEDuu 13 14 15 16 7 “18 19 20 | “at & 25 HONORABLE PARIS K. KALLAS Special Discovery Master Colleen Kinerk Sentember 9. 2008. 9:30 AM: (with Oral Argument) IN THE SUPERIOR COURT OF WASHINGTON FOR KING COUNTY SUSAN SILVER, Case No.:,07-2-16253-4 SEA Plaintiff, DECLARATION OF SUSAN v. SILVER IN OPPOSITION TO MOTION TO EXCLUDE |CHRIS CORNELL, ae ~ Defendaht. I, Susan Silver, am over the age of 18, have personal knowledge of all the facts stated herein and declare as follows: 1. Por over 28 years, Ihave been in the music industry. Tam the manager of several musicians and musical groups, and-was the manager of the Seattle band Soundgarden (of which Chris Comell was a part) from 1986 until it disbanded. T-til represent three of the former band ‘members’ intetests in Soundgarden. + AEE 2 Mr, Comellwas a struggling, unlnown inusician when we began dating in 1985, 1 was martied to him from 1990 to-2004. Mr. Comell and Thad one child, Lily, bom ia June 2000. “Toward the end of our marriage, Mr. Comell developed slcohoV/substance abuse . problems. In Septeniter 2002 he left for business in Califomia and, after an intervention by me and bis fonner Audioslave band pariners, Mr. Cornell entered into a rehabilitation facility. DECLARATION OF SUSAN SILVERIN OPPOSITION TO MOTIONTO EXCLUDE: 1 ‘4912-901 359992 dr, : fern cvate susan SeATLE WASH ete (9 STOKESLAWRENCE, PS.© OO mk 10 i “pa 3 4 15 16 17 : 18 RRP BRR BR GS 3. In October 2002, I visited Mr. Comell in California while he was a patient in rehabilitation. At that time, he told me that he would not be returning to our home, One year later, in October 2003, he filed for divorce. 4: In late January 2004, Tteceived a call from my divorce attorney telling me Mr. Comell had reserved the date of March Ist to mediate our divorce and that T would comply with that date “or else”. Little had been done by either of us towards preparing for 2 divorce so the deadline date and the threat caught tne by surprise. My attorney told me 5 weeks would not be Jenough time to value Mr. Comell’s professional goodwill, which was something I had significantly contributed to as his spouse and imusic manager for over 17 years. : 5. ‘Mr. Cornell offered to release his interest in two houses we owned (one in West Seattle and one in Ojai, CA), along with all of their contents, in excharige for (i) release of my interest in a cabin (which Mr. Comell originally suggested we put into a trust for our daughter) ‘and condo we owned, along wit their contents, and (i) releage of my intoest in his professional goodwill. We would evenly split all other property acquired up to the date he filed for divorce. 6. However, Mr: Comell repeatedly conditioned his offer on meeting the March Ist deadline. understand that Me. Cornell wanted an immediate divorce because his current wife Was pregnant at the time, and Mr. Comell wanted to avoid taking the time to valve his professional goodwill: Despite the shortness of time arid my concerns about the value of his professional goodwill and other assets, I agreed to mediate a settlement on March, 1, 2004, the ‘“deadlinie” imposed by Mr. Cornell. “7. At mediation, we reached agreement oi these terms and signed a Property ‘Settlement Agreement on Mirch 1, 2004 (“2004 PSA”) to that effect. A guitar rack with roughly 15 guitars were among the contenti of the West Selattle home st the time of signing the 2004 PSA., We al entered into a separate pareatng plan on that dete, The next day, Mr. Cornell had the divorce decree entered with the Court. ; DECLARATION OF SUSAN SILVER IN OPPOSITION TO MOTION TO EXCLUDE -2 44912001 35599200