Preview
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
11766 Wilshire Boulevard, Suite 750
5 Los Angeles, CA 90025
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
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KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11
11766 WILSHIRE BOULEVARD, SUITE 750
TEL 310.566.9800 • FAX 310.566.9850
BRIAN WARNER, p/k/a MARILYN Case No. 22STCV07568
12 MANSON, Assigned to Hon. Teresa A. Beaudet, Dept. 50
LOS ANGELES, CA 90025
13 Plaintiff,
DEFENDANT EVAN RACHEL WOOD’S
14 vs. ANSWER TO PLAINTIFF’S
UNVERIFIED COMPLAINT
15 EVAN RACHEL WOOD; ASHLEY GORE,
a/k/a ILLMA GORE,
16 Action Filed: March 2, 2022
Defendants. Trial Date: May 1, 2024
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DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT
1 Defendant Evan Rachel Wood (“Wood”), by and through her counsel of record, hereby
2 answers Plaintiff Brian Warner’s (p/k/a Marilyn Manson) unverified Complaint (the “Complaint”),
3 as modified by the Court’s May 9, 2023 ruling granting Defendants’ anti-SLAPP motions, as
4 follows:
5 GENERAL DENIAL
6 Pursuant to California Code of Civil Procedure § 431.30, Wood generally and specifically
7 denies each of the allegations contained in the Complaint, and the whole thereof, and denies that
8 Plaintiff has sustained any injury or loss by reason of any act or omission of Wood. Wood further
9 denies that Plaintiff has been damaged in any amount whatsoever and alleges that Plaintiff is not
10 entitled to any legal or equitable relief against Wood.
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11 AFFIRMATIVE DEFENSES
11766 WILSHIRE BOULEVARD, SUITE 750
TEL 310.566.9800 • FAX 310.566.9850
12 Without admitting any of the allegations in the Complaint, and without assuming any
LOS ANGELES, CA 90025
13 burden of proof, burden of persuasion, or burden of production not imposed by law, Wood alleges
14 the following separate and independent defenses to the Complaint:
15 FIRST AFFIRMATIVE DEFENSE
16 (Failure to State a Claim)
17 1. Plaintiff's Complaint, and each cause of action alleged therein, fails to state facts
18 sufficient to constitute a cause of action against Wood.
19 SECOND AFFIRMATIVE DEFENSE
20 (No Civil Conspiracy)
21 2. Plaintiff’s causes of action against Wood are barred, in whole or in part, because
22 Plaintiff has not alleged, and cannot establish, facts establishing a conspiracy to commit a
23 specified tort.
24 THIRD AFFIRMATIVE DEFENSE
25 (No Vicarious Liability)
26 3. Plaintiff’s causes of action against Wood are barred, in whole or in part, because
27 Plaintiff has not alleged, and cannot establish, that Wood can be held liable for any other person’s
28 conduct.
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DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT
1 FOURTH AFFIRMATIVE DEFENSE
2 (Lack of Damages/Causation)
3 4. Plaintiff’s causes of action are barred, in whole or in part, because Plaintiff has not
4 suffered actual harm, injury in fact, or lost money or property as a result of any action or omission
5 by Defendants.
6 FIFTH AFFIRMATIVE DEFENSE
7 (Intervening Cause)
8 5. Plaintiff’s causes of action are barred, in whole or in part, because Plaintiff’s own
9 conduct and/or intervening third party conduct was a superseding cause of the alleged injuries to
10 Plaintiff.
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11 SIXTH AFFIRMATIVE DEFENSE
11766 WILSHIRE BOULEVARD, SUITE 750
TEL 310.566.9800 • FAX 310.566.9850
12 (Lack of Intent)
LOS ANGELES, CA 90025
13 6. Plaintiff’s causes of action are barred, in whole or in part, because Wood lacked the
14 requisite intent.
15 SEVENTH AFFIRMATIVE DEFENSE
16 (Statute of Limitations)
17 7. Plaintiff’s causes of action are barred, in whole or in part, by the applicable statute
18 of limitations.
19 EIGHTH AFFIRMATIVE DEFENSE
20 (First Amendment)
21 8. Plaintiff’s causes of action are barred, in whole or in part, as Defendants’ alleged
22 conduct is protected under the First Amendment of the United States Constitution.
23 NINTH AFFIRMATIVE DEFENSE
24 (Litigation Privilege)
25 9. Plaintiff’s causes of action are barred, in whole or in part, by the litigation
26 privilege.
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DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT
1 TENTH AFFIRMATIVE DEFENSE
2 (Common Interest Privilege)
3 10. Plaintiff’s causes of action are barred, in whole or in part, by the common interest
4 privilege.
5 ELEVENTH AFFIRMATIVE DEFENSE
6 (Standing)
7 11. Plaintiff’s causes of action are barred, in whole or in part, because Plaintiff lacks
8 standing to bring his claims.
9 TWELFTH AFFIRMATIVE DEFENSE
10 (Unclean Hands)
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11 12. As a result of Plaintiff’s conduct, words, and/or actions, Plaintiff’s claims against
11766 WILSHIRE BOULEVARD, SUITE 750
TEL 310.566.9800 • FAX 310.566.9850
12 Wood are bare in whole or in part by unclean hands.
LOS ANGELES, CA 90025
13 THIRTEENTH AFFIRMATIVE DEFENSE
14 (Good Faith, Privilege, Justification)
15 13. Plaintiff’s causes of action are barred in whole or in part because the acts or
16 omissions alleged to have been performed by Defendants, if performed at all, were done in good
17 faith and/or were privileged or justified.
18 FOURTEENTH AFFIRMATIVE DEFENSE
19 (Attorneys’ Fees Not Recoverable)
20 14. Plaintiff’s request for attorneys’ fees is barred in whole or in part because Plaintiff
21 cannot state and prove a claim that entitles Plaintiff to recover attorneys’ fees.
22 FIFTEENTH AFFIRMATIVE DEFENSE
23 (No Right to Punitive Damages)
24 15. Plaintiff’s prayer for punitive damages is barred because Plaintiff fails to allege
25 facts sufficient to entitle Plaintiff to recover punitive damages from Wood and cannot establish an
26 entitlement to punitive damages.
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DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT
1 SIXTEENTH AFFIRMATIVE DEFENSE
2 (No Right to Injunctive Relief)
3 16. Plaintiff’s prayer for injunctive relief is barred because there is an adequate remedy
4 at law and because the hardship that would be imposed on Defendants by any such relief would be
5 greatly disproportionate to any hardship that Plaintiff might suffer in its absence.
6 SEVENTEENTH AFFIRMATIVE DEFENSE
7 (Mootness)
8 17. Plaintiff’s prayer for injunctive relief is barred because it is moot.
9 EIGHTEENTH AFFIRMATIVE DEFENSE
10 (Permission or Consent)
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11 18. Plaintiff’s causes of action are barred, in whole or in part, because the conduct
11766 WILSHIRE BOULEVARD, SUITE 750
TEL 310.566.9800 • FAX 310.566.9850
12 alleged was undertaken, if at all, with Plaintiff’s permission, knowledge, acquiescence,
LOS ANGELES, CA 90025
13 ratification, approval, and/or consent.
14 NINETEENTH AFFIRMATIVE DEFENSE
15 (Waiver)
16 19. As a result of Plaintiff’s words and/or conduct, Plaintiff has waived, in whole or in
17 part, the right to obtain relief on his causes of action.
18 TWENTIETH AFFIRMATIVE DEFENSE
19 (Comparative/Contributory Fault)
20 20. Plaintiff’s causes of action are barred in whole or in part because Plaintiff’s own
21 conduct and intervening third party conduct caused all or some of Plaintiff’s alleged injury.
22 TWENTY-FIRST AFFIRMATIVE DEFENSE
23 (Laches)
24 21. Plaintiff’s causes of action are barred in whole or in part by the doctrine of laches.
25 TWENTY-SECOND AFFIRMATIVE DEFENSE
26 (Estoppel)
27 22. Plaintiff’s causes of action are barred in whole or in part by the doctrine of
28 estoppel.
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DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT
1 TWENTY-THIRD AFFIRMATIVE DEFENSE
2 (Failure to Mitigate)
3 23. As a result of Plaintiff’s knowledge, conduct, words, actions, and/or failure to act,
4 Plaintiff’s claims for relief are barred or limited because Plaintiff failed to exercise reasonable care
5 and diligence to mitigate his alleged damages.
6 TWENTY-FOURTH AFFIRMATIVE DEFENSE
7 (Reservation of Other Defenses)
8 24. Wood has insufficient information upon which to form a belief as to whether she
9 may have additional unstated affirmative defenses. Wood reserves the right to assert other
10 affirmative defenses as this action proceeds up to and including the time of trial.
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
11 PRAYER FOR RELIEF
11766 WILSHIRE BOULEVARD, SUITE 750
TEL 310.566.9800 • FAX 310.566.9850
12 WHEREFORE, Wood respectfully pray for judgment as follows:
LOS ANGELES, CA 90025
13 1. That Plaintiff takes nothing by his Complaint and be afforded no relief against
14 Wood;
15 2. That Plaintiff’s claims be dismissed with prejudice and that judgment be entered in
16 favor of Wood;
17 3. That Wood be awarded her attorneys’ fees and costs of suit herein; and
18 4. For such further and additional relief as the Court deems just and proper.
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20 DATED: May 19, 2023 Respectfully submitted,
21 KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
22
23 By:
Michael J. Kump
24 Attorneys for Defendant EVAN RACHEL WOOD
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DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT
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 11766
4 Wilshire Boulevard, Suite 750, Los Angeles, CA 90025.
5 On May 19, 2023, I served true copies of the following document(s) described as
DEFENDANT EVAN RACHEL WOOD’S ANSWER TO PLAINTIFF’S UNVERIFIED
6 COMPLAINT on the interested parties in this action as follows:
7 Howard E. King, Esq. Attorney for Plaintiff
John G. Snow, Esq. Brian Warner, p/k/a Marilyn Manson
8 Jackson S. Trugman, Esq.
King, Holmes, Paterno & Soriano, LLP
9 1900 Avenue of the Stars, 25th Floor
Los Angeles, California 90067
10 Telephone: (310) 282-8989
KINSELLA WEITZMAN ISER KUMP HOLLEY LLP
Email: hking@khpslaw.com
11 jsnow@khpslaw.com
11766 WILSHIRE BOULEVARD, SUITE 750
TEL 310.566.9800 • FAX 310.566.9850
jtrugman@khpslaw.com
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LOS ANGELES, CA 90025
Additional email for service:
13 ksloane@khpslaw.com
14 Margaret Ziemianek, Esq. Attorney for Defendant
Lawrence M. Cirelli, Esq. Ashley Gore a/k/a Illma Gore
15 G. Thomas Rivera III, Esq.
Hanson Bridgett LLP
16 425 Market Street, 26th Floor
San Francisco, CA 94105
17 Telephone: (415) 995-6438
Email: MZiemianek@hansonbridgett.com
18 lcirelli@hansonbridgett.com
trivera@hansonbridgett.com
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Additional email for service:
20 destebanez@hansonbridgett.com
21 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
22 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.
23
I declare under penalty of perjury under the laws of the State of California that the
24 foregoing is true and correct.
25 Executed on May 19, 2023, at Los Angeles, California.
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Mary L. Sanks
28 827092
7
DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT
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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 11766 Wilshire Boulevard, Suite 750 5 Los Angeles, CA 90025 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 11766 WILSHIRE BOULEVARD, SUITE 750 TEL 310.566.9800 • FAX 310.566.9850 BRIAN WARNER, p/k/a MARILYN Case No. 22STCV07568 12 MANSON, Assigned to Hon. Teresa A. Beaudet, Dept. 50 LOS ANGELES, CA 90025 13 Plaintiff, DEFENDANT EVAN RACHEL WOOD’S 14 vs. ANSWER TO PLAINTIFF’S UNVERIFIED COMPLAINT 15 EVAN RACHEL WOOD; ASHLEY GORE, a/k/a ILLMA GORE, 16 Action Filed: March 2, 2022 Defendants. Trial Date: May 1, 2024 17 18 19 20 21 22 23 24 25 26 27 28 DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT 1 Defendant Evan Rachel Wood (“Wood”), by and through her counsel of record, hereby 2 answers Plaintiff Brian Warner’s (p/k/a Marilyn Manson) unverified Complaint (the “Complaint”), 3 as modified by the Court’s May 9, 2023 ruling granting Defendants’ anti-SLAPP motions, as 4 follows: 5 GENERAL DENIAL 6 Pursuant to California Code of Civil Procedure § 431.30, Wood generally and specifically 7 denies each of the allegations contained in the Complaint, and the whole thereof, and denies that 8 Plaintiff has sustained any injury or loss by reason of any act or omission of Wood. Wood further 9 denies that Plaintiff has been damaged in any amount whatsoever and alleges that Plaintiff is not 10 entitled to any legal or equitable relief against Wood. KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 AFFIRMATIVE DEFENSES 11766 WILSHIRE BOULEVARD, SUITE 750 TEL 310.566.9800 • FAX 310.566.9850 12 Without admitting any of the allegations in the Complaint, and without assuming any LOS ANGELES, CA 90025 13 burden of proof, burden of persuasion, or burden of production not imposed by law, Wood alleges 14 the following separate and independent defenses to the Complaint: 15 FIRST AFFIRMATIVE DEFENSE 16 (Failure to State a Claim) 17 1. Plaintiff's Complaint, and each cause of action alleged therein, fails to state facts 18 sufficient to constitute a cause of action against Wood. 19 SECOND AFFIRMATIVE DEFENSE 20 (No Civil Conspiracy) 21 2. Plaintiff’s causes of action against Wood are barred, in whole or in part, because 22 Plaintiff has not alleged, and cannot establish, facts establishing a conspiracy to commit a 23 specified tort. 24 THIRD AFFIRMATIVE DEFENSE 25 (No Vicarious Liability) 26 3. Plaintiff’s causes of action against Wood are barred, in whole or in part, because 27 Plaintiff has not alleged, and cannot establish, that Wood can be held liable for any other person’s 28 conduct. 2 DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT 1 FOURTH AFFIRMATIVE DEFENSE 2 (Lack of Damages/Causation) 3 4. Plaintiff’s causes of action are barred, in whole or in part, because Plaintiff has not 4 suffered actual harm, injury in fact, or lost money or property as a result of any action or omission 5 by Defendants. 6 FIFTH AFFIRMATIVE DEFENSE 7 (Intervening Cause) 8 5. Plaintiff’s causes of action are barred, in whole or in part, because Plaintiff’s own 9 conduct and/or intervening third party conduct was a superseding cause of the alleged injuries to 10 Plaintiff. KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 SIXTH AFFIRMATIVE DEFENSE 11766 WILSHIRE BOULEVARD, SUITE 750 TEL 310.566.9800 • FAX 310.566.9850 12 (Lack of Intent) LOS ANGELES, CA 90025 13 6. Plaintiff’s causes of action are barred, in whole or in part, because Wood lacked the 14 requisite intent. 15 SEVENTH AFFIRMATIVE DEFENSE 16 (Statute of Limitations) 17 7. Plaintiff’s causes of action are barred, in whole or in part, by the applicable statute 18 of limitations. 19 EIGHTH AFFIRMATIVE DEFENSE 20 (First Amendment) 21 8. Plaintiff’s causes of action are barred, in whole or in part, as Defendants’ alleged 22 conduct is protected under the First Amendment of the United States Constitution. 23 NINTH AFFIRMATIVE DEFENSE 24 (Litigation Privilege) 25 9. Plaintiff’s causes of action are barred, in whole or in part, by the litigation 26 privilege. 27 28 3 DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT 1 TENTH AFFIRMATIVE DEFENSE 2 (Common Interest Privilege) 3 10. Plaintiff’s causes of action are barred, in whole or in part, by the common interest 4 privilege. 5 ELEVENTH AFFIRMATIVE DEFENSE 6 (Standing) 7 11. Plaintiff’s causes of action are barred, in whole or in part, because Plaintiff lacks 8 standing to bring his claims. 9 TWELFTH AFFIRMATIVE DEFENSE 10 (Unclean Hands) KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 12. As a result of Plaintiff’s conduct, words, and/or actions, Plaintiff’s claims against 11766 WILSHIRE BOULEVARD, SUITE 750 TEL 310.566.9800 • FAX 310.566.9850 12 Wood are bare in whole or in part by unclean hands. LOS ANGELES, CA 90025 13 THIRTEENTH AFFIRMATIVE DEFENSE 14 (Good Faith, Privilege, Justification) 15 13. Plaintiff’s causes of action are barred in whole or in part because the acts or 16 omissions alleged to have been performed by Defendants, if performed at all, were done in good 17 faith and/or were privileged or justified. 18 FOURTEENTH AFFIRMATIVE DEFENSE 19 (Attorneys’ Fees Not Recoverable) 20 14. Plaintiff’s request for attorneys’ fees is barred in whole or in part because Plaintiff 21 cannot state and prove a claim that entitles Plaintiff to recover attorneys’ fees. 22 FIFTEENTH AFFIRMATIVE DEFENSE 23 (No Right to Punitive Damages) 24 15. Plaintiff’s prayer for punitive damages is barred because Plaintiff fails to allege 25 facts sufficient to entitle Plaintiff to recover punitive damages from Wood and cannot establish an 26 entitlement to punitive damages. 27 28 4 DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT 1 SIXTEENTH AFFIRMATIVE DEFENSE 2 (No Right to Injunctive Relief) 3 16. Plaintiff’s prayer for injunctive relief is barred because there is an adequate remedy 4 at law and because the hardship that would be imposed on Defendants by any such relief would be 5 greatly disproportionate to any hardship that Plaintiff might suffer in its absence. 6 SEVENTEENTH AFFIRMATIVE DEFENSE 7 (Mootness) 8 17. Plaintiff’s prayer for injunctive relief is barred because it is moot. 9 EIGHTEENTH AFFIRMATIVE DEFENSE 10 (Permission or Consent) KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 18. Plaintiff’s causes of action are barred, in whole or in part, because the conduct 11766 WILSHIRE BOULEVARD, SUITE 750 TEL 310.566.9800 • FAX 310.566.9850 12 alleged was undertaken, if at all, with Plaintiff’s permission, knowledge, acquiescence, LOS ANGELES, CA 90025 13 ratification, approval, and/or consent. 14 NINETEENTH AFFIRMATIVE DEFENSE 15 (Waiver) 16 19. As a result of Plaintiff’s words and/or conduct, Plaintiff has waived, in whole or in 17 part, the right to obtain relief on his causes of action. 18 TWENTIETH AFFIRMATIVE DEFENSE 19 (Comparative/Contributory Fault) 20 20. Plaintiff’s causes of action are barred in whole or in part because Plaintiff’s own 21 conduct and intervening third party conduct caused all or some of Plaintiff’s alleged injury. 22 TWENTY-FIRST AFFIRMATIVE DEFENSE 23 (Laches) 24 21. Plaintiff’s causes of action are barred in whole or in part by the doctrine of laches. 25 TWENTY-SECOND AFFIRMATIVE DEFENSE 26 (Estoppel) 27 22. Plaintiff’s causes of action are barred in whole or in part by the doctrine of 28 estoppel. 5 DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT 1 TWENTY-THIRD AFFIRMATIVE DEFENSE 2 (Failure to Mitigate) 3 23. As a result of Plaintiff’s knowledge, conduct, words, actions, and/or failure to act, 4 Plaintiff’s claims for relief are barred or limited because Plaintiff failed to exercise reasonable care 5 and diligence to mitigate his alleged damages. 6 TWENTY-FOURTH AFFIRMATIVE DEFENSE 7 (Reservation of Other Defenses) 8 24. Wood has insufficient information upon which to form a belief as to whether she 9 may have additional unstated affirmative defenses. Wood reserves the right to assert other 10 affirmative defenses as this action proceeds up to and including the time of trial. KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 11 PRAYER FOR RELIEF 11766 WILSHIRE BOULEVARD, SUITE 750 TEL 310.566.9800 • FAX 310.566.9850 12 WHEREFORE, Wood respectfully pray for judgment as follows: LOS ANGELES, CA 90025 13 1. That Plaintiff takes nothing by his Complaint and be afforded no relief against 14 Wood; 15 2. That Plaintiff’s claims be dismissed with prejudice and that judgment be entered in 16 favor of Wood; 17 3. That Wood be awarded her attorneys’ fees and costs of suit herein; and 18 4. For such further and additional relief as the Court deems just and proper. 19 20 DATED: May 19, 2023 Respectfully submitted, 21 KINSELLA WEITZMAN ISER KUMP HOLLEY LLP 22 23 By: Michael J. Kump 24 Attorneys for Defendant EVAN RACHEL WOOD 25 26 27 28 6 DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT 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 11766 4 Wilshire Boulevard, Suite 750, Los Angeles, CA 90025. 5 On May 19, 2023, I served true copies of the following document(s) described as DEFENDANT EVAN RACHEL WOOD’S ANSWER TO PLAINTIFF’S UNVERIFIED 6 COMPLAINT on the interested parties in this action as follows: 7 Howard E. King, Esq. Attorney for Plaintiff John G. Snow, Esq. Brian Warner, p/k/a Marilyn Manson 8 Jackson S. Trugman, Esq. King, Holmes, Paterno & Soriano, LLP 9 1900 Avenue of the Stars, 25th Floor Los Angeles, California 90067 10 Telephone: (310) 282-8989 KINSELLA WEITZMAN ISER KUMP HOLLEY LLP Email: hking@khpslaw.com 11 jsnow@khpslaw.com 11766 WILSHIRE BOULEVARD, SUITE 750 TEL 310.566.9800 • FAX 310.566.9850 jtrugman@khpslaw.com 12 LOS ANGELES, CA 90025 Additional email for service: 13 ksloane@khpslaw.com 14 Margaret Ziemianek, Esq. Attorney for Defendant Lawrence M. Cirelli, Esq. Ashley Gore a/k/a Illma Gore 15 G. Thomas Rivera III, Esq. Hanson Bridgett LLP 16 425 Market Street, 26th Floor San Francisco, CA 94105 17 Telephone: (415) 995-6438 Email: MZiemianek@hansonbridgett.com 18 lcirelli@hansonbridgett.com trivera@hansonbridgett.com 19 Additional email for service: 20 destebanez@hansonbridgett.com 21 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 22 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. 23 I declare under penalty of perjury under the laws of the State of California that the 24 foregoing is true and correct. 25 Executed on May 19, 2023, at Los Angeles, California. 26 27 Mary L. Sanks 28 827092 7 DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT