Arsenio Hall v. Sinead O'Connor - complaint.pdf

8/17/2019 Arsenio Hall v. Sinead O'Connor - complaint.pdf

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MARTTN D. SrNGE_R BAR NO. 73166)LYNDAB.coLDMAN1nan No. rrlzosyLAVELY & SINGERPROFESSIONAL CORPORATION2049 Century ark East,Suite 2400Los Angeles, aliforni 90067 2906Tel . : 310) 56-3501Fax: 3 0) 556-3615Email [email protected]

[email protected]

Attomeys or PlaintiffARSENIOHALL

.,sst,Flh5RilAY

5 2010

3

gateSUPERIOR COURT OF THE STATE OF CALIFONNTE

FOR THE COLINTYOF LOS ANGELES WEST DISTRICTludgeMitchell.

ARSENIOHALL, an ndividual.

Plaintiff,

O'CONNOR, an ndividual; andthrough 10, nclusive,

Defendants.

CASENo.sci.25'7i)9COMPLAINT FOR LIBEL

DEMAND FOR JURY TRIAL

))))))))))

SINEADDOES 1

Plaintiff Arsenio Hall

l ' Desperate, ttention-seeker inead O'Connor has maliciously publishedoutlandish defamatory ies about comedian Arsenio Hall, falsely accusing him of supplyingillegal "hard drugs" "over the decades" o the recently deceased musical artist, prince, and of

spiking her with drugs once years ago. The malicious statements made by o,Connor areabsolutely alse, and o'connor's heinous accusations hat Hall engaged n this criminal conductare despicable, abricated ies.

2' o'Connor is now known perhaps as much for her bizarre,unhinged ntemet rantsas for her music. This time, she argeted Hall with wild and false accusations hat he had beenPrince's drug supplier or decades nd had somehow been esponsible or prince,s death.

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("Plaintiff'or "Hall") hereby alleges as ollows:

WHAT THIS CASE IS ABOUT

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However' o'connor knew that there was no truth whatsoever o the vicious ies she spewedabout Hall on her Facebook age, and hat she had concocted hem and had no basis o believethat they were true' Among other things, o'connor has repeatedly admitted hat she actuallydetested Prince during his life,

that she had a feud with prince, and that she once had a violentfistfight with Prince and spat on him repeatedly after she old prince ..to go f,*k himself.,,significantly, o'connor has also publicly acknowledged hat she actually met prince onlv..acouple of times" after he wrote the song hat made her famous, so she would have no basis ohave personal knowledge of anyone who may have allegedly provided prince with illegal ..harddrugs" "over the decades" and certainly no factual basis whatsoever o believe hat Hall had doneso. In fact, he had not.

3' Hall has only had minimal contact with o'connor, and ast had contactwith herapproximately 5 years ago' The ruth s that Hall never supplied llegal drugs o prince, and henever spiked"o'connor with drugs. However, versince 'connor posed er malicious ndreckless ies about Hall on her "OFFICIALFacebook age" where hey have been ommentedon and orwarded housands f times), her brazen ies have spread ike wildfireacross he mediathroughout he united states and he world, causing ubstantial arm o Hall,s reputation.

4' Hall will not stand dly by whileo'connor attempts o get attention or herself yrecklessly spreading malicious, vile lies that he engaged n egregious criminal conduct whichfalsely links Hall to Prince's death, and Hall is therefore bringing this libel action to clear hisname and to set he record straight.

THE PARTIES

5' Plaintiff Arsenio Hall is an accomplished comedian and actor, and at all times

relevant hereto has been, a resident of the county of Los Angeles, State of california.6' Plaintiff is informed and believes and based hereon alleges hat Defendant sinead

o'connor ("o'connor" or "Defendant") is, and at all times relevant hereto was, an Irish citizen.Plaintiff fuither alleges on information and belief that o'connor throughout her career hastraveled on multiple occasions o the county of Los Angeles and the State of california. plaintifffurther alleges on information and belief that Defendant o'connor purposefully and specifically

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targeted Plaintifl known to reside and work in Los Angeles, California, and purposefully

directed her wrongful acts alleged herein oward Plaintiff in Los Angeles, California. plaintiff

further alleges on information and belief that in engaging n the conduct alleged herein,Defendant O'Connor engaged n

tortious conduct which has had an effect in the County of LosAngeles and n the State of California.

7 Plaintiff is informed and believes and based hereon alleges hat pursuant oCalifornia Code of Civil Procedure $ 474,the ictitiously named Defendants ued herein as DoesI through 10, nclusive, and each of them, were n some manner esponsible r legally iable forthe actions, events' ransactions and circumstances lleged herein. The true names and capacitiesof such fictitiously named Defendants whether ndividual, corporate, associate r otherwise

arepresently unknown to Plaintiff and Plaintiff will seek eave of Court to amend his Complaint toassert he true names and capacities of such ictitiously named Defendants when the same havebeen ascertained. or convenience, all Defendants shall sometimes be collectively referred toherein as "Defendants"' and each reference o a named Defendant herein shall also refer to theDoe Defendants, and each of them.

8' Plaintiff is informed and believes and based hereon alleges hat at all materialtimes each Defendant was and is the agent, employee, partner, oint venturer, co-conspirator,owner, principal and employer of each of the remaining Defendants and at all times hereinmentioned was acting within the course and scope of that agency, employment, partnership,conspiracy, ownership or joint venture. Plaintiff is fuither informed and believes and basedthereon alleges hat the acts and conduct of each Defendant alleged herein were known to, andauthorized or ratified by, the officers, directors, and managing agents of each other Defendant.

9' Commencing n or about May2,2016,O'Connor ecklessly ndmaliciouslyposted a statement n her "OFFICIAL Facebook age" laiming hat "long time hard drug user,,Prince got his drugs ver he decades" rom Hall,and hat Hall had supposedly..spiked,, er"years ago" (the Defamatory ies"). The Defamatory ies are absolutely alse, abricated ndfictional.

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l0' O'Connor is well known for her media antics and or seeking attention hrough

inflammatory Facebook posts and other attention-grabbing media tactics, such as her recent

shocking proclamation hat all of Prince's unreleased musical ecordings ought o be..cremated,,

and destroyed. nce o'Connor'sDefamatory Lies about Hall were published on her Facebook

page, hey were rapidly disseminated by mainstream and gossip media circling the globe, as

o'Connor undoubtedly ntended. As a consequence f o'Connor's vile Defamatory Lies, fans ofthe iconic musical artist Prince were wrongly led to believe that Hall engaged n criminal conduct

as Prince's decades-long rug supplier and that he supposedly somehow esponsible or prince,s

death. This is extraordinarily damaging o Hall's reputation.

11. O'Connor published her Defamatory Lies recklessly nd maliciously, knowing

that they were false, or without having any reasonable basis whatsoever o believe that they were

true. O'Connor has repeatedly stated n the media that she met Prince only a few times and that

she actually "detested" Prince (notwithstanding hat Prince wrote her biggest hit song), and that

she old Prince "to go fx** himself," had a violent "fistfight" with Prince and exchanged blows

with him, and hat she'ospat n him quite a bit." Given O'Connor's admitted animosity oward

Prince during his lifetime, and her admitted highly infrequent and unfriendly contact with him,

O'Connor was obviously not in a position to have any personal knowledge about who, if anyone,

might have allegedly supplied Prince with illegal drugs "over the decades." yet, she ecklessly

and maliciously spread he brazen ie that Hall engaged n illegal criminal conduct by supposedly

acting as Prince's drug supplier, knowing that was false or without having any reasonable asis

whatsoever o believe that it was true. Similarly, either with actual knowledge of falsity or

without any reasonable basis o believe that it was true, she alsely accused Hall of engaging n

criminal conduct by "spiking,'her with drugs years ago.

12. O'Connor's malicious nternet ublication f brazen ies alsely ccusing all ofengaging n serious riminal conduct y supposedly upplyingPrince with hard drugs over hedecades, ndof "spiking" her, esulted n her Defamatory ies becomingwidespread ndubiquitous. Within 48 hours after o'Connor initially posted er Defamatory ies about Hall onher Facebook age, hey had more han 5,000 Facebook Likes,"more han 3,000Facebook

)

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?"Shares"'and more han2,400 acebook comments." Makingmatters orse, he DefamatoryLieswere ead not onlyby readers f o'connor's Facebook age, ut by countless eoplewhoread he nnumerable rint and nternet media eports about her alse Facebook ost.

l3' By publishing heDefamatory ies on her Facebook age, laintiffalleges ninformationand belief hat o'connor intended hat hey would be read, and were ead,

throughout the city and county of Los Angeles and the State of califomia, where plaintiff livesand works, as well as throughout he world.

14' Among other things, the Defamatory Lies falsely assert hat plaintiff engaged nillegal criminal conduct, and the Defamatory Lies are libelous on their face and clearly exposePlaintiff to hatred, contempt, ridicule and obloquy and/or cause plaintiff

to shunned or avoidedand have a tendency o injure plaintiff in his occupation.

l5' The false Defamatory Lies are reasonably susceptible of a defamatory meaning ontheir face in that they falsely assert hat Plaintiff engaged n criminal conduct, and theDefamatory Lies have a direct tendency o injure Plaintiff with respect o his professionalreputation' character and business. Plaintiff is informed and believes and based hereon allegesthat the Defamatory Lies were written and published by o,connor with actual malice withknowledge that they were false, or with a reckless disregard or the truth.

16' Plaintiff is informed and believes and based hereon alleges hat o,connorintentionally portrayed Plaintiff in this manner knowing that the depiction was false, or withoutany reasonable rounds or believing it to be true.

17' The Defamatory ie disseminated y o'connor were unprivileged ndwereintended y o'connor to directly njure Plaintiff with respect o his professional eputation,

character' rade and business. laintiff s informed and believes nd based hereon lleges hatDefendant new or recklessly isregarded he fact hat he Defamatory ies would ikely damagePlaintiff s reputation.

l8' As a direct and proximate esult of the above described onduct by o,connor,Plaintiff has suffered general and special damages n an amount not presentry known, butbelieved o be not less han Five Million Dollars ($5,000,000). Although the full nature. extent

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'3and amount of these damages re currently unknown, he Complaint will be amended t or beforetrial to insert such nformation f such amendment s deemed necessary y the Court.

l9' Plaintiff is informed and believes and based hereon alleges hat the aforesaid actsof o'Connor were done ntentionally

or with a conscious isregard of plaintiff s rights and withan intent to vex, injure or annoy Plaintiff such as to constitute oppression, raud or malice, thusentitling Plaintiff to exemplary and punitive damages n an amount appropriate o punish or setan example of O'Connor, and to deter such conduct in the future which amount will be proved atrial' Plaintiff is informed and believes and based hereon alleges hat the officers, directors ormanaging agents of Defendants, and each of them, authorized, directed and/or ratified thewrongful acts of Defendants and consequently are iable to plaintiff.

WHEREFORE, Plaintiff prays for judgment against O'Connor as follows:

l ' For compensatory damages according o proof at the time of trial in an amount notless han Five Million Dollars ($5,000,000), ogether with interest hereon at the maximum egalrate;

2' For punitive damages ursuant o Civil Code Secti on3294 in an amountappropriate o punish and set an example of Defendants, and each of them, and to deter suchconduct in the future, the exact amount of such punitive damages ubject o proof at the time oftrial:

3' For all costs of suit and reasonable attorneys' fees ncurred herein by plaintiffs asmay be provided by law;

4. For interest as may be provided by law; and

5' For such other and further relief as the Court deems ust and appropriate.

b

,/DATE:May ,20t6 LAVELY & SINGER

6

Attorneys for Plaintif0 O HALL

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9 { }

LAVELY & SINGER

JURY DEMAND

PlaintiffArsenio Hall hereby emands rial by ury.

/',i

DATE:May - ,2016PROFES IONALCORPORATIONMARTIND. SINGER ,...-'" /"LYNDA,ggyowy .,i / I , / / . . /

,* /,,, l --- t -By: ; ' ' " -4 , ( ,

ARTIN D. SINGEAttorneys or Plaintiff ARSEN

K \5025-3\PLE\COMPLATNTv2) 0504 6.wpdPLAINTIFF'S COMPLAINT

Arsenio Hall v. Sinead O'Connor - complaint.pdf

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Transcript of Arsenio Hall v. Sinead O'Connor - complaint.pdf