2 3 26 25 Honorable Paris Kallas Heating Date: October 3, 2008 Hearing Time: 9:00 a.m. With Oral Argument IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON, COUNTY OF KING SUSAN SILVER, NO. 07-2-16253-4SEA. Plaintiff, vs. REPLY DECLARATION OF CHRIS CORNELL CHRIS CORNELL, Defendant. CHRIS CORNELL declares: 1. Lam the defendant in this action. I am a U.S. citizen, over the age of 18 years, and am competent to testify. I make this declaration based on my personal knowledge of the facts set forth herein, in reply to Plaintiff's Opposition to Comell’s Summary Judgment Motion. 2. In her declaration, Susan Silver claims she still represents all of the former band members of Soundgarden. That is not true. They are now represented by Kelly Curtis. On September 10, 2008, I attended a meeting with Mr. Curtis and the other former Soundgarden members to discuss band business. Susan was not there. I went to that meeting only because Susan was not managing the other former band members and would not be ORIGINAL .... 280 Tw noe SoM 1 Uon rene sree 2966201290 LASHER T 2 | Hou s DECLARATION OF PETER CORNELL ~ 1 Fesersow (1si911$699948,D0C}involved. If she had still been managing them, I absolutely would not have gone in person to ‘meet with them. As the manager of Soundgarden in 2002-2004, she had a duty to notify me, as a former member of Soundgarden, of the location of my professional equipment and deliver it to me before or at the time of our divorce through now. 3. Susan now itemizes my personal belongings that she put into storage. She does not list my Graoumy awards, unpublished works, or guitars. If she had provided me a list in 2003 when she had my belongings moved, or told me what she had kept, I would have known that she did not move the guitars or other items to storage. She did not provide a list then, and did not tell me she had kept the guitars. 4. Susan certainly did tell me she was moving my stuff to storage. She claims that she never talked to me about my personal belongings after December 2002, but later in her declaration she says we met in New York during the 2003 holiday season to discuss asset division, We definitely discussed asset division then and at other times before our divorce, which included talking about who would get which assets, One of our discussions included Susan telling me that she had moved my personal belongings to the storage unit. In none of those discussions did Susan say she had or planned to keep my guitars. 5. I did not visit the storage unit in the fall of 2003 or at any other time after our separation. I did open a couple of boxes to get some clothes out before they were moved to storage during a visit to the house when Eric Garcia was moving boxes out of the house and told me that all of my stuff had been boxed up and was being moved to storage at Susan’s direction. I got the clothes out of the boxes before they were moved to storage. I did not go to the storage unit, nor did I have access. Eric and Susan had the only keys to the storage unit. I was not given a key despite many requests. When I talked to Denny and Susan in February 2007 and was told that Susan had all of my guitars, I directed my attorneys to access the storage unit to confirm whether there were any guitars there, They had to have the lock drilled to get into the storage unit, 2 Get | HOWAPFED | Brummer 1 Oy | TRS | SANS DECLARATION OF PETER CORNELL —2, taygs™ EBBERSON ceed escent (151918699948,.00C)"1 2 B 15 16 8 19 20 21 2 m4 25 26 6. Susan says the guitars were in the guitar rack in the furnace room when 1 visited in December 2002. I did not look in the furnace room during that visit, but even if I had, the guitars were not there after Susan had my belongings moved to storage. I did look in the furnace room on one of my later visits, after I had seen Eric moving my stuff out of the house, and did not see any guitars there. I also did not see any guitars in the garage or anywhere else in the house after that. Based on these observations, coupled with the fact that Eric and Susan both told me that all of my belongings were being moved to storage, I believed the guitars had been moved to the storage unit with all of my other belongings. I did not know that the guitars were in a case hidden behind a blanket under the loft in the back of the garage, as Eric testified in his deposition. No one told me the guitars had been moved there. No one showed me where they had been moved. I would not have been able to see them unless I searched through storage, I had no reason to do that and Susan would have surely objected. Our property settlement was not a game of hide-and-seek. Susan, as my wife and as my professional manager, should have told me she kept my guitars at the West Seattle house. Pre My brother, Peter, asked to borrow one of my Les Paul guitars. I told him he could borrow it and to pick it up from Denny Markopoulos. I believed that guitar was at Denny’s so I called Denny and told him Peter would be coming by to pick up the guitar. Eric says I called him. I remember calling Denny, not Eric. If I did call Bric, I would have told him that Peter wanted the 88 Les Paull and Eric would have gotten it for him wherever it was located. Eric had a key to the storage unit, and had in the past gone and retrieved things from storage for me. If the guitar was at Denny’s, Eric would have gone to Denny's to get it. Either way, the guitar was under my control. 8. As [ testified in my deposition, there were several guitars at Denny’s house that I had left there. I specifically recall the following guitars being at Denny’s house: the Gretsch Rock Jet (“Black Hole Sun guitar”), 1953 Telecaster, Cherry Sunburst Les Paul, and Arromere saw Ao 1, | qEASHERL- | mootmeUncvSanee 2 mt) HOLeaPren | mrumnseer ° OF 2) Tspernya | sans waserso DECLARATION OF PETER CORNELL —-3 eva EBBERSON Paeeaeee te: (1519086895480)