Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 04/28/2022 05:52 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk
1 KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
MICHAEL J. KUMP (SBN 100983)
2 mkump@kwikhlaw.com
SHAWN HOLLEY (SBN 136811)
3 sholley@kwikhlaw.com
KATHERINE T. KLEINDIENST (SBN 274423)
4 kkleindienst@kwikhlaw.com
808 Wilshire Boulevard, 3rd Floor
5 Santa Monica, California 90401
Telephone: 310.566.9800
6 Facsimile: 310.566.9850
7 Attorneys for Defendant
EVAN RACHEL WOOD
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11
808 WILSHIRE BOULEVARD, 3RD FLOOR
BRIAN WARNER, p/k/a MARILYN Case No. 22STCV07568
FAX 310.566.9850
SANTA MONICA, CALIFORNIA 90401
12 MANSON,
Assigned to Hon. Teresa A. Beaudet, Dept. 50
13 Plaintiff,
DECLARATION OF EVAN RACHEL
14 vs. WOOD IN SUPPORT OF SPECIAL
MOTION TO STRIKE PORTIONS OF
TEL 310.566.9800
15 EVAN RACHEL WOOD; ASHLEY GORE, PLAINTIFF S COMPLAINT PURSUANT
a/k/a ILLMA GORE, TO CODE OF CIVIL PROCEDURE §
16 425.16 AND FOR ATTORNEYS FEES
Defendants.
17 [Notice of Motion and Motion, Declaration of
Michael J. Kump, Request for Judicial Notice,
18 Notice of Lodging, and Proposed Order filed
concurrently herewith]
19
Date: December 13, 2022
20 Time: 2:00 p.m.
Dept.: 50
21
Reservation ID: 324970224500
22
Action Filed: March 2, 2022
23 Trial Date: None Set
24
25
26
27
28
DECLARATION OF EVAN RACHEL WOOD ISO SPECIAL MOTION TO STRIKE
1 DECLARATION OF EVAN RACHEL WOOD
2 I, Evan Rachel Wood, declare as follows:
3 1. I am a defendant in this action. I submit this declaration in support of my Special
4
5 . If called as a witness, I could and would competently testify to all the
6 facts within my personal knowledge except where stated upon information and belief.
7 2. I have been working as a professional actress since I was 5 years old. When I was
8 14 years old, I starred in the movie Thirteen, a teen drama about a seventh grade student dabbling
9 in drugs, sex, and crime after being befriended by a troubled classmate. I have appeared in many
10 other films, including The Wrestler, Whatever Works, The Ides of March, and Charlie
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11 Countryman, and I have voiced characters in animated films such as Strange Magic and Frozen II.
808 WILSHIRE BOULEVARD, 3RD FLOOR
FAX 310.566.9850
SANTA MONICA, CALIFORNIA 90401
12 I have also appeared in television series such as Westworld, Mildred Pierce, and True Blood.
13 3. I met Brian Warner in 2006 at a party at Chateau Marmont when I was just 18
14 years old. Mr. Warner approached me and told me that he was a big fan of my work in Thirteen.
TEL 310.566.9800
15 Mr. Warner said he wanted to talk to me about a project he was working on called
16 Phantasmagoria about Lewis Carroll and his subconscious. When I first met him, Mr. Warner
17 he was. By that time, Mr. Warner had
18 already been world-
19 4. My relationship with Mr. Warner began as a friendship under the auspices of a
20 professional collaboration on the film Phantasmagoria. Then, one day, when I was about to leave
21 town to film a movie, Mr. Warner kissed me. I was still 18 years old at the time, and Mr. Warner
22 was 37 years old.
23 5. Thereafter, I began a romantic relationship with Mr. Warner that continued, on and
24 off, until 2010. During that time, I was often photographed by paparazzi, there were many articles
25 written about my relationship with Mr. Warner, and I was asked about the relationship in media
26 interviews.
27 6. At the beginning of our relationship, Mr. Warner would tell me that I had inspired
28 him to make music and art again, that I was his soulmate, and that he loved me. However, the
2
1 relationship became increasingly abusive over time. During the course of our relationship,
2 Mr. Warner raped me, tortured me, tied me up, beat me, starved me, deprived me of sleep, and
3 shocked sensitive parts of my body. Mr. Warner also isolated me from friends and family, hacked
4 into and monitored my email and social media accounts, and threatened my life and the lives of
5 my friends and family.
6 7. In 2010, I found the courage to end my relationship with Mr. Warner. After I left to
7 go film The Ides of March, I changed my telephone number and left Mr. Warner for good. I did
8 not see him for years after that. In 2014, I ran into Mr. Warner at an event in Los Angeles. Before
9 I left the event, Mr. Warner would not me alone, and at one point he leaned over and said,
10
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11 against me, which made me fear that he would retaliate against me if I spoke publicly about the
808 WILSHIRE BOULEVARD, 3RD FLOOR
FAX 310.566.9850
SANTA MONICA, CALIFORNIA 90401
12 abuse or did anything else to make him angry.
13 8. Although I escaped from the relationship with Mr. Warner in 2010, coming to
14 terms with the effects of years of physical and emotional abuse, and feeling safe enough to talk
TEL 310.566.9800
15 about it despite threats of retaliation, took much longer. I did not begin speaking about the
16 domestic violence that I experienced until November 2016. And I did not publicly name
17 Mr. Warner as my abuser until February 1, 2021.
18 9. Once I began speaking about the abuse, I connected with other activists including
19 Amanda Nguyen, the CEO and founder of Rise. In February 2018 I testified before the United
20
21 Rights in all fifty states. I testified to some of the details of the abuse I suffered, but I was not yet
22 ready to publicly name Mr. Warner as my abuser.
23 10. After testifying before Congress, some women contacted me who claimed to have
24 experienced similar abuse inflicted by Mr. Warner. This was when it became clear to me that I
25 y victim.
26 11. Around that time, I approached attorney Gloria Allred with evidence of Mr.
27 left the relationship with
28 Mr. Warner, and I was told that the statute of limitations for my claims against Mr. Warner had
3
1 already expired. I was surprised and shocked to learn that there was no longer a remedy for the
2 crimes committed against me.
3 12. My experience led me to begin advocating to extend the statute of limitations for
4 domestic violence in California. In April 2019, I testified before the California Senate in support
5 of the Phoenix Act, which passed unanimously and extended the time victims of domestic abuse
6 have to press charges against their abuser. When I testified before the California Senate, I
7 described the type of abuse I had experienced, but I was still not ready to name Mr. Warner as my
8 abuser.
9 13. In or around late 2018 or early 2019, I told Amy Berg about The Phoenix Act and
10 the work I was doing to extend the statute of limitations and elevate the voices of survivors of
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11 domestic violence. Around that time, we began filming events that ultimately became part of the
808 WILSHIRE BOULEVARD, 3RD FLOOR
FAX 310.566.9850
SANTA MONICA, CALIFORNIA 90401
12 documentary, Phoenix Rising, which chronicles my experiences and my work in connection with
13 The Phoenix Act. The two-part documentary premiered at the Sundance Film Festival in January
14 2022 and debuted on HBO on March 15 and 16, 2022.
TEL 310.566.9800
15 14. On October 21, 2020, I met with some of the other victims of Mr. Warner. The
16 meeting was filmed for the documentary Phoenix Rising. However, some of the people who
17 attended the meeting did not want to be filmed or did not want to appear in the documentary. We,
18 of course, respected their wishes. In my experience, being a survivor of domestic violence can
19 sometimes feel very lonely, and speaking to people who had similar experiences made me feel like
20 there are people who believe me, support me, and understand what I am going through.
21 15. On February 1, 2021, I named Mr. Warner as my abuser for the first time in a post
22 on my Instagram account. A true and correct copy of my February 1, 2021 Instagram post is
23 attached hereto as Exhibit 1.
24 16. I have never pressured anyone to make false accusations against Mr. Warner or to
25 be part of the Phoenix Rising documentary. The statements I have made about the abuse inflicted
26 by Mr. Warner are true. I have no reason to doubt the accusations made against Mr. Warner by
27 other survivors. Groupie movie on
28 Dinner for Five and the civil complaints filed against him by other victims last year. I am also
4
1 aware that accusations of physical and sexual abuse of minors have been made against Mr.
2 Warner. In February 2021, I posted copies of letters from Massachusetts Representative Natalie
3 Higgins and Florida Representative Anna V. Eskamani requesting an FBI investigation of Mr.
4 Warner based on multiple allegations of physical and sexual assault, including against minors.
5 True and correct copies of my February 2021 Instagram posts regarding those letters are attached
6 hereto as Exhibit 2.
7 17. Attached hereto as Exhibit 3 is a true and correct copy of the webpage
8 https://www.mansonwiki.com/wiki/Video_Interview:Marilyn_Manson_Dinner_For_Five as it
9
10 Groupie on Dinner for Five.
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11 18.
808 WILSHIRE BOULEVARD, 3RD FLOOR
FAX 310.566.9850
SANTA MONICA, CALIFORNIA 90401
12 Department in connection with criminal investigations of Mr. Warner. On information and belief,
13 those investigations are ongoing.
14 19. After leaving the relationship with Mr. Warner, I reunited with Jamie Bell, who I
TEL 310.566.9800
15 had dated prior to meeting Mr. Warner. Mr. Bell and I were never officially married, but we had a
16 son in 2013.
17 20. In or around November of 2020, I learned that Mr. Warner had been making threats
18 against people who were accusing him of crimes. One person posted an audio recording of
19 Mr. Warner to social media. In the recording, Mr. Warner (whose voice I recognized) says, among
20
21 know where they live, where their fuckin kids go to school, where they work, their par
22 Because of the threats Mr. Warner made when we were dating and when I ran into him 2014, the
23 threats , the types of
24 conduct I observed while dating Mr. Warner, and my involvement in providing evidence in
25 connection with the criminal investigations, I have feared for my safety and the safety of my son.
26 21. In late November 2020, I made the decision to reside exclusively in my home in
27 Tennessee. Thereafter, a dispute arose between myself and my ex, Mr. Bell, regarding the shared
28 custody of our son. On March 1, 2021, in connection with our custody dispute, Mr. Bell filed an ex
5
1 parte application in a parentage action in Los Angeles Superior Court (Matfin-Bell v. Wood; L.A.
2 Superior Court Case No. 21STPT00170). My lawyers and I opposed the ex parte application on
3 March 2, 2021, and I submitted a declaration in connection with that opposition.
4 22. In my declaration, I explained to the Court my involvement in the criminal
5
6 why I feared living in close proximity to him. My declaration attached a copy of the FBI Letter,
7
8 distribute the FBI Letter outside the scope of my custody dispute with Mr. Bell, did not provide a
9 copy to Mr. Warner, and did not leak it to the press. I did not fabricate or forge the FBI Letter.
10 When I received a copy of the FBI Letter, and when I submitted it to the Court, I believed it to be
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11 authentic. I also did not knowingly make any false statements of fact in my declaration.
808 WILSHIRE BOULEVARD, 3RD FLOOR
FAX 310.566.9850
SANTA MONICA, CALIFORNIA 90401
12 23. My intention in filing my declaration, which attached the FBI Letter, was not to
13 cause Mr. Warner emotional distress. Rather, my intention was to explain to the Court why I
14 feared living in close proximity to my abuser. I did not know that Mr. Warner would obtain copies
TEL 310.566.9800
15 of court filings from my confidential custody dispute with Mr. Bell.
16 24. A true and correct copy of the HBO documentary Phoenix Rising (Parts 1 and 2)
17 will be lodged with the Court on a thumb drive as Exhibit 4. Part 1 of Phoenix Rising includes
18 excerpts of Dinner for Five (see timestamp 1:01:34-1:02:37). Part 2
19 of Phoenix Rising includes portions of the October 21, 2020 meeting of survivors beginning at
20 timestamp 2:56.
21 I declare under penalty of perjury under the laws of the State of California that the
22 foregoing is true and correct.
23 Executed April 28, 2022, at _______________, ______________.
24
________________________
25 Evan Rachel Wood
26
27
28
6
EXHIBIT 1
EXHIBIT 2
EXHIBIT 3
EXHIBIT 4
THUMB DRIVE OF VIDEO EXHIBIT LODGED WITH THE COURT
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3 At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of Los Angeles, State of California. My business address is 808 Wilshire
4 Boulevard, 3rd Floor, Santa Monica, CA 90401.
5 On April 28, 2022, I served true copies of the following document(s) described as
DECLARATION OF EVAN RACHEL WOOD IN SUPPORT OF SPECIAL MOTION TO
6 F CIVIL
on the interested parties in this
7 action as follows:
8 Howard E. King, Esq. Attorney for Plaintiff
John G. Snow, Esq. Brian Warner, p/k/a Marilyn Manson
9 Jackson S. Trugman, Esq.
King, Holmes, Paterno & Soriano, LLP
10 1900 Avenue of the Stars, 25th Floor
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
Los Angeles, California 90067
11 Telephone: (310) 282-8989
808 WILSHIRE BOULEVARD, 3RD FLOOR
Email: hking@khpslaw.com
FAX 310.566.9850
SANTA MONICA, CALIFORNIA 90401
12 jsnow@khpslaw.com
jtrugman@khpslaw.com
13
Additional email for service:
14 ksloane@khpslaw.com
TEL 310.566.9800
15 Maggie Ziemianek, Esq. Attorney for Defendant
Hanson Bridgett LLP Ashley Gore a/k/a Illma Gore
16 425 Market Street, 26th Floor
San Francisco, CA 94105
17 Telephone: (415) 995-6438
Email: MZiemianek@hansonbridgett.com
18
Additional email for service:
19 destebanez@hansonbridgett.com
20 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
document(s) to be sent from e-mail address MSanks@kwikhlaw.com to the persons at the e-mail
21 addresses listed in the Service List. I did not receive, within a reasonable time after the
transmission, any electronic message or other indication that the transmission was unsuccessful.
22
I declare under penalty of perjury under the laws of the State of California that the
23 foregoing is true and correct.
24 Executed on April 28, 2022, at Santa Monica, California.
25
26
Mary L. Sanks
27 777781
28
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 04/28/2022 05:52 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk 1 KINSELLA WEITZMAN ISER KUMP HOLLEY LLP MICHAEL J. KUMP (SBN 100983) 2 mkump@kwikhlaw.com SHAWN HOLLEY (SBN 136811) 3 sholley@kwikhlaw.com KATHERINE T. KLEINDIENST (SBN 274423) 4 kkleindienst@kwikhlaw.com 808 Wilshire Boulevard, 3rd Floor 5 Santa Monica, California 90401 Telephone: 310.566.9800 6 Facsimile: 310.566.9850 7 Attorneys for Defendant EVAN RACHEL WOOD 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 808 WILSHIRE BOULEVARD, 3RD FLOOR BRIAN WARNER, p/k/a MARILYN Case No. 22STCV07568 FAX 310.566.9850 SANTA MONICA, CALIFORNIA 90401 12 MANSON, Assigned to Hon. Teresa A. Beaudet, Dept. 50 13 Plaintiff, DECLARATION OF EVAN RACHEL 14 vs. WOOD IN SUPPORT OF SPECIAL MOTION TO STRIKE PORTIONS OF TEL 310.566.9800 15 EVAN RACHEL WOOD; ASHLEY GORE, PLAINTIFF S COMPLAINT PURSUANT a/k/a ILLMA GORE, TO CODE OF CIVIL PROCEDURE § 16 425.16 AND FOR ATTORNEYS FEES Defendants. 17 [Notice of Motion and Motion, Declaration of Michael J. Kump, Request for Judicial Notice, 18 Notice of Lodging, and Proposed Order filed concurrently herewith] 19 Date: December 13, 2022 20 Time: 2:00 p.m. Dept.: 50 21 Reservation ID: 324970224500 22 Action Filed: March 2, 2022 23 Trial Date: None Set 24 25 26 27 28 DECLARATION OF EVAN RACHEL WOOD ISO SPECIAL MOTION TO STRIKE 1 DECLARATION OF EVAN RACHEL WOOD 2 I, Evan Rachel Wood, declare as follows: 3 1. I am a defendant in this action. I submit this declaration in support of my Special 4 5 . If called as a witness, I could and would competently testify to all the 6 facts within my personal knowledge except where stated upon information and belief. 7 2. I have been working as a professional actress since I was 5 years old. When I was 8 14 years old, I starred in the movie Thirteen, a teen drama about a seventh grade student dabbling 9 in drugs, sex, and crime after being befriended by a troubled classmate. I have appeared in many 10 other films, including The Wrestler, Whatever Works, The Ides of March, and Charlie KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 Countryman, and I have voiced characters in animated films such as Strange Magic and Frozen II. 808 WILSHIRE BOULEVARD, 3RD FLOOR FAX 310.566.9850 SANTA MONICA, CALIFORNIA 90401 12 I have also appeared in television series such as Westworld, Mildred Pierce, and True Blood. 13 3. I met Brian Warner in 2006 at a party at Chateau Marmont when I was just 18 14 years old. Mr. Warner approached me and told me that he was a big fan of my work in Thirteen. TEL 310.566.9800 15 Mr. Warner said he wanted to talk to me about a project he was working on called 16 Phantasmagoria about Lewis Carroll and his subconscious. When I first met him, Mr. Warner 17 he was. By that time, Mr. Warner had 18 already been world- 19 4. My relationship with Mr. Warner began as a friendship under the auspices of a 20 professional collaboration on the film Phantasmagoria. Then, one day, when I was about to leave 21 town to film a movie, Mr. Warner kissed me. I was still 18 years old at the time, and Mr. Warner 22 was 37 years old. 23 5. Thereafter, I began a romantic relationship with Mr. Warner that continued, on and 24 off, until 2010. During that time, I was often photographed by paparazzi, there were many articles 25 written about my relationship with Mr. Warner, and I was asked about the relationship in media 26 interviews. 27 6. At the beginning of our relationship, Mr. Warner would tell me that I had inspired 28 him to make music and art again, that I was his soulmate, and that he loved me. However, the 2 1 relationship became increasingly abusive over time. During the course of our relationship, 2 Mr. Warner raped me, tortured me, tied me up, beat me, starved me, deprived me of sleep, and 3 shocked sensitive parts of my body. Mr. Warner also isolated me from friends and family, hacked 4 into and monitored my email and social media accounts, and threatened my life and the lives of 5 my friends and family. 6 7. In 2010, I found the courage to end my relationship with Mr. Warner. After I left to 7 go film The Ides of March, I changed my telephone number and left Mr. Warner for good. I did 8 not see him for years after that. In 2014, I ran into Mr. Warner at an event in Los Angeles. Before 9 I left the event, Mr. Warner would not me alone, and at one point he leaned over and said, 10 KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 against me, which made me fear that he would retaliate against me if I spoke publicly about the 808 WILSHIRE BOULEVARD, 3RD FLOOR FAX 310.566.9850 SANTA MONICA, CALIFORNIA 90401 12 abuse or did anything else to make him angry. 13 8. Although I escaped from the relationship with Mr. Warner in 2010, coming to 14 terms with the effects of years of physical and emotional abuse, and feeling safe enough to talk TEL 310.566.9800 15 about it despite threats of retaliation, took much longer. I did not begin speaking about the 16 domestic violence that I experienced until November 2016. And I did not publicly name 17 Mr. Warner as my abuser until February 1, 2021. 18 9. Once I began speaking about the abuse, I connected with other activists including 19 Amanda Nguyen, the CEO and founder of Rise. In February 2018 I testified before the United 20 21 Rights in all fifty states. I testified to some of the details of the abuse I suffered, but I was not yet 22 ready to publicly name Mr. Warner as my abuser. 23 10. After testifying before Congress, some women contacted me who claimed to have 24 experienced similar abuse inflicted by Mr. Warner. This was when it became clear to me that I 25 y victim. 26 11. Around that time, I approached attorney Gloria Allred with evidence of Mr. 27 left the relationship with 28 Mr. Warner, and I was told that the statute of limitations for my claims against Mr. Warner had 3 1 already expired. I was surprised and shocked to learn that there was no longer a remedy for the 2 crimes committed against me. 3 12. My experience led me to begin advocating to extend the statute of limitations for 4 domestic violence in California. In April 2019, I testified before the California Senate in support 5 of the Phoenix Act, which passed unanimously and extended the time victims of domestic abuse 6 have to press charges against their abuser. When I testified before the California Senate, I 7 described the type of abuse I had experienced, but I was still not ready to name Mr. Warner as my 8 abuser. 9 13. In or around late 2018 or early 2019, I told Amy Berg about The Phoenix Act and 10 the work I was doing to extend the statute of limitations and elevate the voices of survivors of KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 domestic violence. Around that time, we began filming events that ultimately became part of the 808 WILSHIRE BOULEVARD, 3RD FLOOR FAX 310.566.9850 SANTA MONICA, CALIFORNIA 90401 12 documentary, Phoenix Rising, which chronicles my experiences and my work in connection with 13 The Phoenix Act. The two-part documentary premiered at the Sundance Film Festival in January 14 2022 and debuted on HBO on March 15 and 16, 2022. TEL 310.566.9800 15 14. On October 21, 2020, I met with some of the other victims of Mr. Warner. The 16 meeting was filmed for the documentary Phoenix Rising. However, some of the people who 17 attended the meeting did not want to be filmed or did not want to appear in the documentary. We, 18 of course, respected their wishes. In my experience, being a survivor of domestic violence can 19 sometimes feel very lonely, and speaking to people who had similar experiences made me feel like 20 there are people who believe me, support me, and understand what I am going through. 21 15. On February 1, 2021, I named Mr. Warner as my abuser for the first time in a post 22 on my Instagram account. A true and correct copy of my February 1, 2021 Instagram post is 23 attached hereto as Exhibit 1. 24 16. I have never pressured anyone to make false accusations against Mr. Warner or to 25 be part of the Phoenix Rising documentary. The statements I have made about the abuse inflicted 26 by Mr. Warner are true. I have no reason to doubt the accusations made against Mr. Warner by 27 other survivors. Groupie movie on 28 Dinner for Five and the civil complaints filed against him by other victims last year. I am also 4 1 aware that accusations of physical and sexual abuse of minors have been made against Mr. 2 Warner. In February 2021, I posted copies of letters from Massachusetts Representative Natalie 3 Higgins and Florida Representative Anna V. Eskamani requesting an FBI investigation of Mr. 4 Warner based on multiple allegations of physical and sexual assault, including against minors. 5 True and correct copies of my February 2021 Instagram posts regarding those letters are attached 6 hereto as Exhibit 2. 7 17. Attached hereto as Exhibit 3 is a true and correct copy of the webpage 8 https://www.mansonwiki.com/wiki/Video_Interview:Marilyn_Manson_Dinner_For_Five as it 9 10 Groupie on Dinner for Five. KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 18. 808 WILSHIRE BOULEVARD, 3RD FLOOR FAX 310.566.9850 SANTA MONICA, CALIFORNIA 90401 12 Department in connection with criminal investigations of Mr. Warner. On information and belief, 13 those investigations are ongoing. 14 19. After leaving the relationship with Mr. Warner, I reunited with Jamie Bell, who I TEL 310.566.9800 15 had dated prior to meeting Mr. Warner. Mr. Bell and I were never officially married, but we had a 16 son in 2013. 17 20. In or around November of 2020, I learned that Mr. Warner had been making threats 18 against people who were accusing him of crimes. One person posted an audio recording of 19 Mr. Warner to social media. In the recording, Mr. Warner (whose voice I recognized) says, among 20 21 know where they live, where their fuckin kids go to school, where they work, their par 22 Because of the threats Mr. Warner made when we were dating and when I ran into him 2014, the 23 threats , the types of 24 conduct I observed while dating Mr. Warner, and my involvement in providing evidence in 25 connection with the criminal investigations, I have feared for my safety and the safety of my son. 26 21. In late November 2020, I made the decision to reside exclusively in my home in 27 Tennessee. Thereafter, a dispute arose between myself and my ex, Mr. Bell, regarding the shared 28 custody of our son. On March 1, 2021, in connection with our custody dispute, Mr. Bell filed an ex 5 1 parte application in a parentage action in Los Angeles Superior Court (Matfin-Bell v. Wood; L.A. 2 Superior Court Case No. 21STPT00170). My lawyers and I opposed the ex parte application on 3 March 2, 2021, and I submitted a declaration in connection with that opposition. 4 22. In my declaration, I explained to the Court my involvement in the criminal 5 6 why I feared living in close proximity to him. My declaration attached a copy of the FBI Letter, 7 8 distribute the FBI Letter outside the scope of my custody dispute with Mr. Bell, did not provide a 9 copy to Mr. Warner, and did not leak it to the press. I did not fabricate or forge the FBI Letter. 10 When I received a copy of the FBI Letter, and when I submitted it to the Court, I believed it to be KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 authentic. I also did not knowingly make any false statements of fact in my declaration. 808 WILSHIRE BOULEVARD, 3RD FLOOR FAX 310.566.9850 SANTA MONICA, CALIFORNIA 90401 12 23. My intention in filing my declaration, which attached the FBI Letter, was not to 13 cause Mr. Warner emotional distress. Rather, my intention was to explain to the Court why I 14 feared living in close proximity to my abuser. I did not know that Mr. Warner would obtain copies TEL 310.566.9800 15 of court filings from my confidential custody dispute with Mr. Bell. 16 24. A true and correct copy of the HBO documentary Phoenix Rising (Parts 1 and 2) 17 will be lodged with the Court on a thumb drive as Exhibit 4. Part 1 of Phoenix Rising includes 18 excerpts of Dinner for Five (see timestamp 1:01:34-1:02:37). Part 2 19 of Phoenix Rising includes portions of the October 21, 2020 meeting of survivors beginning at 20 timestamp 2:56. 21 I declare under penalty of perjury under the laws of the State of California that the 22 foregoing is true and correct. 23 Executed April 28, 2022, at _______________, ______________. 24 ________________________ 25 Evan Rachel Wood 26 27 28 6 EXHIBIT 1 EXHIBIT 2 EXHIBIT 3 EXHIBIT 4 THUMB DRIVE OF VIDEO EXHIBIT LODGED WITH THE COURT 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Los Angeles, State of California. My business address is 808 Wilshire 4 Boulevard, 3rd Floor, Santa Monica, CA 90401. 5 On April 28, 2022, I served true copies of the following document(s) described as DECLARATION OF EVAN RACHEL WOOD IN SUPPORT OF SPECIAL MOTION TO 6 F CIVIL on the interested parties in this 7 action as follows: 8 Howard E. King, Esq. Attorney for Plaintiff John G. Snow, Esq. Brian Warner, p/k/a Marilyn Manson 9 Jackson S. Trugman, Esq. King, Holmes, Paterno & Soriano, LLP 10 1900 Avenue of the Stars, 25th Floor KINSELLA WEITZMAN ISER KUMP HOLLEY LLP Los Angeles, California 90067 11 Telephone: (310) 282-8989 808 WILSHIRE BOULEVARD, 3RD FLOOR Email: hking@khpslaw.com FAX 310.566.9850 SANTA MONICA, CALIFORNIA 90401 12 jsnow@khpslaw.com jtrugman@khpslaw.com 13 Additional email for service: 14 ksloane@khpslaw.com TEL 310.566.9800 15 Maggie Ziemianek, Esq. Attorney for Defendant Hanson Bridgett LLP Ashley Gore a/k/a Illma Gore 16 425 Market Street, 26th Floor San Francisco, CA 94105 17 Telephone: (415) 995-6438 Email: MZiemianek@hansonbridgett.com 18 Additional email for service: 19 destebanez@hansonbridgett.com 20 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the document(s) to be sent from e-mail address MSanks@kwikhlaw.com to the persons at the e-mail 21 addresses listed in the Service List. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. 22 I declare under penalty of perjury under the laws of the State of California that the 23 foregoing is true and correct. 24 Executed on April 28, 2022, at Santa Monica, California. 25 26 Mary L. Sanks 27 777781 28