HED
MUFEB 2B PHI 42
Honorable Paris Kallas
Hearing Date: February 29, 2008
Without Oral Argument
Moving Party’s Pleadings
iuetaliy
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
COUNTY OF KING
SUSAN SILVER,
NO, 07-2-16253-4SEA
Plaintiff,
vs. REPLY DECLARATION OF
VICKY CORNELL
CHRIS CORNELL,
Defendant.
I, Vicky Comell, hereby declare as follows:
1. This declaration is made of my personal knowledge and I am competent to
attest to the facts set forth here. It now appears that Susan Silver is utilizing the legal process
to personally attack me, engage in smear tactics, and even attempt to accuse me of perjury.
‘The following are but a few of the many false and inaccurate representations made in the
Declaration of Bradford J. Axel in Opposition to Motion to Quash Subpoena,
2. The lawsuit against Denny Markopoulos was dismissed after Mr. Markopoulos
testified that he gave the guitars to Susan Silver.
3. Thave not “pressed charges” against the process server, Matthew Turner, who
is now the subject of criminal charges in Los Angeles. The Los Angeles City Attomey
brought the charges after an investigation by the Los Angeles Police Department. J was
personally present in court at the hearing when the Judge ruled that the criminal charges
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my family would not be issued against Mr. Turner because the Court did not view
Mr. Tuer as a stalker. The Court stated it viewed this as a one-time event. The actions of
‘Mr. Tumer remain of grave concem to me for our family’s safety. My concems were
reinforced when Mr, Turner's first attorney appeared with a bodyguard and requested that
she be relieved of representing Mr. Tuer out of fear for her personal safety at his hands.
‘Mr. Tumer is now on his third attomey. While Mr. Axel parses the issue of who actually
hired Mr. Tumer, he is Ms. Silver’s counsel and acted on her behalf in hiring Mr. Turner's
firm to serve process. The fact remains that Mr. Hamerlinck, Susan Silver’s family law
attorney, was provided our home address by our attorney, Ms. Ebberson, for one weekend,
for emergency purposes only. In violation of his agreement to use that address in the case of
an emergency during Lily’s residential time with my husband and me, Mr. Axel admits that
he obtained our address from Mr. Hamerlinck and Mr. Axel provided it to Mr. Turner in
violation of Mr. Hamerlinck’s agreement with Ms. Ebberson.
4, Mr, Axel’s assertion that I have committed perjury is a powerful accusation
which I take very seriously. I have reviewed paragraph 19 of Mr. Axel’s Declaration. He
misrepresents the question that was directed to me. The question was “Were you present?
Did you see the deposition?” My answer was “I did.” I did not testify that J was present at
the deposition of Susan Silver, I viewed the videotaped transcript of her deposition taken by
Mr. Marty Singer in the intellectual property litigation where she was instructed not to
answer questions regarding her role in the internet death threats made against me and my
family, and I stand by my testimony which is otherwise accurately set forth at Exhibit M to
Mr. Axel’s Declaration.
The heinous death threat that was traced to London was ultimately determined
5,
to be a rerouting of a blog. In the Fluttergirl website, Ms. Silver referred to herself as the
“Rock star’s wife” months after she was divorced from Chris. These documents previously
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have been provided to the Court. The posting of death threats against me and my unborn
child began immediately following July 2004 (after their divorce) when Chris told Susan
Silver that she had to stop her emails where she said she was “thinking and dreaming” of
him. Ms. Silver has gone to great lengths to invade our family’s privacy, including using
Lily’s nanny to gather information inside our home which information found its way to the
internet and attempting to use the nanny to serve legal process on Charis. All of this is well
documented and has been placed before the Court in prior declarations.
I declare under penalty of perjury under the laws of the State of Washington that the
foregoing is true and correct to the best of my knowledge and belief.
SIGNED AND DATED this 28" day of February, 2008 at Miami, Florida
FACSIMILE SIGNATURE ATTACHED
Vicky Comell
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