04/04/08 08:59 FAX 206 682 0875. JOHNSON FLORA oor ‘ ED 2 KING ooh WASHINTON ‘THE HONORABLE STEVEN (:. GONZALEZ 8 APR O4 2008 ‘Heoring Dete: Fridey, Feb. 8, 2008 4 Without oral argument SEA 5 SUPERIOR COURT CLERK 6 a IN THE SUPERIOR COURT OF WASHINGTON STATE FOR KING COUNTY © lors CORNELL, » Q ? 10 ‘Plaintiff, ) NO, 06-2-24639-0 SBA 2 nw ve 2 ' ) DECLARATION OF CHR'S: 12 OLDAL, WARTELLE &CO.,P.S.,2 ) CORNELL INSUPPORT ‘ashington Professional Service ) OF PLAINTIFF'S OPPOSITION: 13 \Corporation; LEE E. JOHNSON; ) YO GEORGE DEFENDANT'S: A. GEORGE; and JANET A. ) MOTION TO STRIKE EXERT ae GE ING. P.S., a Washington ) DESIGNATIONS OF MARTIN 45 [Professional Service Corporation; ) SINGER AND NEAL HERSH ) 16 Defendants.) CHRIS CORNELL declares under penalty of perjury under the laws cf the State of [Washington as follows: ‘Lam over the age of 18, make this Declaration based on personal knowledge, and am JSoropetent to testify to the faces stated in this Declaration, ‘I was bom in Seattic on July 20, 1964, J am a professional musician, ‘singer and ongrwriter, [have written, recorded and performed mausic with the bands Soundgarden, (Temple of the Dog, and Audioslave. In addition Ihave released two solo albams. Thave Jf'on soveral music awards, including Grammys. In 2007 I was nominated for, but did not IDECL. OF C, CORNELL IN SUPP. OF PLTFS JOHNSON | FLORA JOPP. TO GEORGE DFT's MINTO STRIKE Men pera tee IEXPERT DESIGNATIONS OF SINGER & HERSH-1 Seite Webst (9 206.206. 5a5 () 206.592.0575 ORIGINAL356: NI Page:2/< 04/04/2008 18:56:56 Hotel PLAZA ATHENEE 015367 66 66 __. Page:2/ 04/04/08 _00:00 FAX 206 632 0675 JOKNSON FLORA Boos 14 16 16 7 18 19 at 23 24 28 26 yin, a Granny for the best song in a motion picture forthe song "You Know My Namne” ftom the James Bond movie Casino Royal. Individually, and the bands that save been ia, 1 Jasve sold 20 milion records. Jn 1990 J marcied Soundgarden’s manager, Susan Silver, Soundgarden broke up in 1997 and, thereafter, I ecorded and released my fist solo album, Euphoria Moming. Ispent Imost of my time away from home from 1998, The relationship had deteriorated and by 1998, ‘was very much addicted to alcobol and spent litle to no time at home. I suf'ered from jecute depression, substance abuse and slcoholism, Tbad already left the hous» before on more than one oseasion and we had discussed divorce before. : Tn 2002 I joined Audioslave. ‘The members of my band had an intervention with mo, | checked myself into treatment at a rehabilitation feclity in Colifornia (“Proraises”), During ithe tone I wos in treatment and as part of the counseling T was receiving, I-carae to the jealization that I could no longer stay married to Susan Silver, 1 did not love ser and, in fact, was a trigger for my alcohol abuse, During my troxtment Thad a visit with Susan, told that I did not love her anymore and that I was ending the marriage for gocd this time. [Susan was emotionally distranght and refused to lt go. We had undergone marriage counseling and I did everything I could to keep it together for our daughter L:ly, but L Jeoutda’t do it, Nothing worked and my aleobolinm and depression became Worse, ven affor Susan and I were ivorved and Imarried Vicky, Susan refi'sed to let go. Se sent me inappropriate emails, icing om ray 4th betday ting me Ct sho was thinking and “dreaming” of me, The felitionship between Susan and Thas biome very Jnsry. We are current in tigation dver guitars thal Tus in my caoer a which ee bas retained, and we have had mmerous arguments regarding our daughter Lily. ECL. OF C. CORNELL IN SUPP. OF PLTFS JOHNSON | FLORA . 7 GEORGE DFT'S MINTO STRIKE 2505 oir ran, Ste 500 [EXPERT DESIGNATIONS OF SINGER & HERSH -2 Sentie, WA 98121 (9 208,986,866 "(208.582.067504/04/2008 18:5; 2470808 56 Hotel PLAZA ATHENEE 01 53 67 66 66 Page:1/« 09:01 FAK 206 682 0675 SJOENSON FLORA Boos ‘separated from Susan in July of 2002. I met my wife Vicky Karayiar.xis in Jannary {2003 at an Audioslave event in Paris that her publicity company was orgenizing for us. We fell in love and I wanted to marry her and have children with her, Even before we were [married we had fertility counseling. (Ms. ‘George’s lawyers have actually asked for my wife Vicky's medical records to try to determine whether she was pregnant st the time of the |divorce, but the fact is, it was not something that concemed either Vicky ome) Jn October 2003 I retained Janet George to represent me in my divorce from Susan, George filed the divorce in October 2003 and Ltold her that I wanted to slit everything {50-50 with Susan, since she had been there from the beginning, inclading 50 yer cent of the [royalties from my songs created while we were married. Prior to the Christmas holidays in 2004 I told Janet that Susan could liave the two jhomes that Susan and I owned (one in West Sesttie and one in California} fre> and clear. 1 did this in response to Janet's ioquiry about what [could use as leverage with Susan to got ear aca a ee [planning to get married when the divorce was final. The reason that I offered the two homes is because I wanted to move on and it was supposed to be incentive for Susar to finish the divorce. I asked Janet that if I did this, when could we be done snd she said “March 1.” JPssed on that, Tmude it very clear tos, George that, ifthe divoroe was not final on Mirch 1, the two homes would be taken off the table and we would go to trial. Janet George never told me that by signing an Agreement with paragieph 7A that I jWould be giving ownership interest ia my music copyrights to Susax Silver, Lalso jDderstand that she has testified that I told her at the mediation that I “knew wverything” jsbout intellectual property. This is absolutcly false. I was relying on Janet and she told me DECL. OF C, CORNELL IN SUPP. OF PLTF'S JOHNSON | FLORA |OPP. TO GEORGE DFT’S MTN TO STRIKE JEXPERT DESIGNATIONS OF SINGER & HERSH - 3 oe Rou eee (0 206.9968506 {9 206.682.0875 i