16 7 18 19 a mn 2s Honorable Paris Kallas Hearing Date: February 29, 2008 ‘Without Oral Argument Moving Party’s Pleadings IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON COUNTY OF KING SUSAN SILVER, NO. 07-2-16253-4SEA Plaintiff, AMENDED REPLY DECLARATION OF VICKY CORNELL vs. CHRIS CORNELL, Defendant. I, Vicky Cornell, hereby deciare as follows: 1. This declaration is made of my personal knowledge and 1 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. Ihave not “pressed charges” against the process server, Matthew Turner, who is now the subject of criminal charges in Los Angeles. The Los Angeles City Attorney brought the charges after an investigation by the Los Angeles Police Department. 1 was personally present in court at the hearing when the Judge ruled that the criminal charges [ERSTE mee owner sce sca SEATTLE, WA 88101-4000 AMENDED REPLY DECLARATION Greene seca OF VICKY CORNELL 3” 18 » 20 2 2 2B 1" 25 26 against Mr. Turner were sufficient and that an additional restraining order protecting me and my family would not be issued against Mr.Tumer because the Court did not view Mr. Turner as a stalker. The Court stated it viewed this as a one-time event. The actions of Mr. Tumer remain of grave concer 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. Tumer out of fear for her personal safety at his hands. Mr. Turmer is now on his third attorney. While Mr. Axel parses the issue of who actually hired Mr. Turner, 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 attomey, was provided our home address by our attomey, 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. Tumer in violation of Mr. Hamerlinck’s agreement with Ms. Ebberson. 4. Mr. Axel’s assertion that I have committed perjury is a powerfull accusation which I take very seriously. I have reviewed paragraph 19 of Mr. Axel’s Decleration. 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 I was present at the deposition of Susan Silver, I viewed the videotaped transcript of her deposition taken by Mr. Matty 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. 5. The heinous death threat that was traced to London was ultimately determined to be a rerouting of a blog. On the Fluttergirl website there is a link to a letter Ms. Silver sent to her neighbors signed “Susan Silver (aka. The Rock Star’s Wife)” months after she was TAS HER] 2200 Tw sou sosees ZREFEL | o01 Uicon srr HOLZAP FEL] sexe wa 961014000 AMENDED REPLY DECLARATION ieonjene- 120 OF VICKY CORNELL ~2 fre (2) an0250810 2 B “ 16 "7 18 19 2 2B 2 6 divorced from Chris. See Exhibit attached here and incorporated by this reference. 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 Chris. 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 Cornell AMENDED REPLY DECLARATION OF VICKY CORNELL~3