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MARTTN D. SrNGE_R
(BAR NO. 73166)

LYNDAB. coLDMAN1nanNo. rrlzosy

LAVELY & SINGER

PROFESSIONALCORPORATION
3 2049CenturyparkEast,Suite2400
LosAngeles,California 90067-2906
4 T e l.:(3 1 0 )5 5 6 -3 5 0 1
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Email: mdsinger@lavelysinger.com
Igoldman@lavelysinger.
com
6
Attomeysfor PlaintiffARSENIOHALL
7

ilAY05 2010

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gate
SUPERIORCOURT OF THE STATE OF CALIFONNTE

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9

FORTHE COLINTYOF LOS ANGELES- WESTDISTRICT

ludgeMitchell
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ARSENIOHALL, an individual.

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Plaintiff,

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t 4 SINEAD O'CONNOR, an individual; and
DOES1 through 10, inclusive,
l5
Defendants.

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.sci.25'7i)9
CASENo.

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COMPLAINT FOR LIBEL

DEMAND FOR JURY TRIAL

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Plaintiff Arsenio Hall ("Plaintiff'or "Hall") herebyalleges

as follows:

t9
20

WHAT THIS CASE IS ABOUT

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Desperate,attention-seeker
SineadO'Connor has maliciously published

2l

outlandish defamatorylies about comedianArsenio

))

illegal "hard drugs" "over the decades"to the recently

deceasedmusical artist, prince, and of

Hall, falsely accusinghim of supplying

23 spiking her with drugs once yearsago. The malicious

statementsmade by o,Connor are

24 absolutelyfalse,and o'connor's heinousaccusationsthat

Hall engagedin this criminal conduct

_l

2s

26

(D
&.

are despicable,fabricatedlies.
2'

o'Connor is now known perhapsas much for her bizarre,unhinged

intemet rants

2 7 as for her music. This time, she targetedHall with

wild and false accusationsthat he had been
28 Prince's drug supplierfor decadesand had somehow
prince,s
beenresponsiblefor

(:)
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death.

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However' o'connor knew that there

was no truth whatsoeverto the vicious lies she
spewed
about Hall on her Facebookpage,and
that shehad concoctedthem and had no basis
to believe
that they were true' Among other things,
o'connor has repeatedlyadmitted that she actually
detestedPrince during his life, that she
had a feud with prince, and that she once had
a violent
fistfight with Prince and spat on him repeatedly
after she told prince ..to go f,*k himself.,,
significantly, o'connor has also publicly
acknowledgedthat sheactuallymet prince onlv..a
couple of times" after he wrote the song
that made her famous, so she would have no
basis to
have personalknowledge of anyone
who may have allegedly provided prince with
illegal ..hard
drugs" "over the decades"and certainly
no factual basiswhatsoeverto believe that
Hall had done
so. In fact, he had not.

l1

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Hall hasonly hadminimalcontactwith o'connor,

t2 approximately25 yearsago' The truth is

that

andlasthadcontactwith her

Hall neversuppliedillegal drugsto prince,and he

13 never"spiked"o'connor with drugs.However,

eversinceo'connor posedhermaliciousand

t 4 recklesslies aboutHall on her "OFFICIAL

Facebook

page"(wheretheyhavebeencommented

t 5 on andforwardedthousandsof times),her
brazen
t6 throughouttheunited statesandthe world,
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lies havespreadlike wildfire acrossthe media

causingsubstantialharmto Hall,s reputation.

Hall will not standidly by whileo'connor

recklessly spreadingmalicious, vile

attemptsto getattentionfor herselfby

lies that he engagedin egregiouscriminal

conduct which

1 9 falsely links Hall to Prince's death, and

Hall is therefore bringing this libel action
to clear his
20 name and to set the record straight.
2l
22

THE PARTIES
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Plaintiff Arsenio Hall is an accomplished

comedian and actor,

23 relevant heretohas been,a resident

of the
24
2S
26
27
28

and at all times

county of Los Angeles, Stateof california.

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Plaintiff is informed and believes

and basedthereon allegesthat Defendant
sinead
o'connor ("o'connor" or "Defendant")
is, and at all times relevant heretowas,
an Irish citizen.
Plaintiff fuither allegeson information
and belief that o'connor throughout her
careerhas
traveled on multiple occasionsto
the county of Los Angeles and the State
of california. plaintiff
further allegeson information and
belief that Defendant o'connor purposefully
and specifically
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targetedPlaintifl known to resideand work in Los Angeles,

California, and purposefully
directedher wrongful actsallegedherein toward Plaintiff in
Los Angeles,California.plaintiff

further allegeson information and belief that in engagingin the

conduct alleged herein,

Defendant O'Connor engagedin tortious conduct which has

had an effect in the County of Los

Angelesand in the Stateof California.

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Plaintiff is informed and believesand basedthereon allegesthat pursuant

to

7 California Codeof Civil Procedure 474,thefictitiously named

$
Defendantssuedhereinas Does
8

I through 10,inclusive,and eachof them, were in somemanner

responsibleor legally liable for

9 the actions, events'transactionsand circumstancesallegedherein.

The true names

and capacities

1 0 of such fictitiously named Defendantswhether individual, corporate,

associateor otherwise are
1 1 presently unknown to Plaintiff and Plaintiff will seekleave of Court
to amendthis Complaint to
12 assertthe true namesand capacitiesof such fictitiously named Defendants
when the samehave

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been ascertained.For convenience,all Defendantsshall sometimes

be collectively referred to

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herein as "Defendants"' and each referenceto a named Defendant

herein shall also refer to the

1 5 Doe Defendants,and each of them.

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Plaintiff is informed and believesand basedthereon allegesthat at all

material

times each Defendantwas and is the agent,employee,partner,joint

venturer, co-conspirator,

1 8 owner, principal and employer of each of the remaining Defendants

and

at all times herein

1 9 mentioned was acting within the courseand scopeof that agency,

employment, partnership,
20 conspiracy,ownershipor joint venture. Plaintiff is fuither informed
and believesand based
2 l thereon allegesthat the acts and conduct of eachDefendant

alleged herein were known to, and

22 authorized or ratified by, the officers, directors, and managing

agentsof each other Defendant.
23
24

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Commencing
on or aboutMay2,2016,O'Connorrecklessly
andmaliciously

25 posteda statement
on her "OFFICIAL Facebookpage"claiming

that "long time harddrug user,,

26 Prince"got hisdrugsoverthedecades"from Hall, andthatHall had

supposedly..spiked,,

her

27 "yearsago" (the"DefamatoryLies"). The DefamatoryLies are

absolutely

false,fabricatedand

28 fictional.
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O'Connor is well known for her media anticsand for seekingattentionthrough

inflammatory Facebookposts and other attention-grabbingmedia tactics,

such as her recent

shockingproclamationthat all of Prince'sunreleasedmusicalrecordingsought

to be..cremated,,

and destroyed.once o'Connor's DefamatoryLies about Hall were published

on her Facebook

page,they were rapidly disseminatedby mainstreamand gossip media

o'Connor undoubtedlyintended.As a consequence

of o'Connor's vile DefamatoryLies, fans of

the iconic musical artist Prince were wrongly led to believe that Hall engagedin
criminal conduct

as Prince's decades-longdrug supplier and that he supposedlysomehowresponsible prince,s

for

death. This is extraordinarily damagingto Hall's reputation.

10
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11.

circling the globe, as

O'Connor publishedher DefamatoryLies recklesslyand maliciously,knowing

that they were false, or without having any reasonablebasiswhatsoeverto believe

that they were

12 true. O'Connor has repeatedlystatedin the media that she met Prince only a few times and that
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she actually "detested" Prince (notwithstandingthat Prince wrote her biggesthit song),
and that

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

1 5 with him, and that she'ospaton him quite a bit." Given O'Connor's admittedanimositytoward
1 6 Prince during his lifetime, and her admitted highly infrequent and unfriendly contactwith him,
t 7 O'Connor was obviously not in a position to have any personalknowledge about who, if anyone,
1 8 might have allegedly supplied Prince with illegal drugs "over the decades."yet, sherecklessly
l 9 and maliciously spreadthe brazenlie that Hall engagedin illegal criminal conduct by supposedly
20 acting as Prince's drug supplier, knowing that was false or without having any reasonable
basis
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whatsoeverto believe that it was true. Similarly, either with actual knowledge
of falsity or

22 without any reasonablebasis to believe that it was true, she falsely accusedHall of engaging
in
23 criminal conduct by "spiking,'her with drugs years ago.
24

12.

O'Connor'smaliciousinternetpublicationof brazenliesfalselyaccusing
Hall of

25 engagingin seriouscriminal conductby supposedlysupplyingPrincewith hard

drugsover the
26 decades,
andof "spiking" her,resultedin her DefamatoryLies becomingwidespread
and
27 ubiquitous.Within 48 hoursaftero'Connor initially postedher DefamatoryLies
aboutHall on
28 herFacebook
page,theyhadmorethan5,000Facebook"Likes,"morethan3,000Facebook
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PLAINTIFF'SCOMPLAINT

"Shares"'andmorethan2,400Facebook
"comments."Makingmattersworse,theDefamatory
) Lieswerereadnot
only by readers
of o'connor's Facebook
page,but by countless
peoplewho
3 readthe innumerableprint andinternetmedia
reportsabouther falseFacebookpost.
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By publishingtheDefamatory
Lieson herFacebook
page,plaintiff allegeson

informationandbeliefthat o'connor intended

that theywould be read,andwereread,

6 throughout the city and county of Los

Angeles and the Stateof califomia, where plaintiff
lives
7 and works, as well as throughout the world.
8

14'

Among other things, the Defamatory Lies falsely

9 illegal criminal conduct, and the Defamatory

Lies are

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Plaintiff to hatred,contempt, ridicule and

obloquy

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and have a tendencyto injure plaintiff

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assertthat plaintiff engagedin

libelous on their face and clearly expose

and/or causeplaintiff to shunnedor avoided

in his occupation.

The false DefamatoryLies are reasonably

susceptibleof a defamatorymeaning on
l3 their face in that they falsely assertthat
Plaintiff engagedin criminal conduct, and the
t 4 Defamatory Lies have a direct tendency
to injure Plaintiff with respectto his professional
l 5 reputation' characterand business.Plaintiff
is informed and believesand basedthereon
alleges
t 6 that the Defamatory Lies were written and
published by o,connor with actual malice
with
t 7 knowledge that they were false, or with
a recklessdisregardfor the truth.
Plaintiff is informed and believesand

basedthereonallegesthat o,connor

1 9 intentionally portrayedPlaintiff in this

manner knowing that the depiction was false,

or without

20 any reasonablegrounds for believing

it to be true.
21
17'
The DefamatoryLie disseminated
by o'connor wereunprivilegedandwere
)', intendedby
o'connor to directlyinjurePlaintiff with respect
to his professionalreputation,
23 character'tradeandbusiness.Plaintiff is
informedandbelievesandbasedthereonalleges
that
24 Defendantknewor recklesslydisregarded
the fact that the DefamatoryLies would likely damage
25 Plaintiff s reputation.
26

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As a direct and proximateresult of the above

describedconductby o,connor,
27 Plaintiff has suffered generaland special
damagesin an amount not presentryknown,
but
28 believedto be not lessthan Five Million
Dollars ($5,000,000).Although the full nature.
extent
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and amountof thesedamagesare currentlyunknown,the Complaint

trial to insertsuch information if suchamendmentis deemednecessary

by the Court.

l9'

will be amendedat or before

Plaintiff is informedand believesand basedthereonallegesthat the

aforesaidacts

of o'Connor were done intentionallyor with a consciousdisregard plaintiff

of
s rights and with

an intent to vex, injure or annoy Plaintiff such as to constitute oppression,

fraud or malice, thus

6 entitling Plaintiff to exemplary and punitive damagesin an amount appropriate

to punish or set
7 an example of O'Connor, and to deter such conduct in the future which

amount will be proved a

8 trial' Plaintiff is informed and believesand basedthereonallegesthat the

officers, directors

or

9 managing agentsof Defendants,and each of them, authorized,directed

and/or ratified the
1 0 wrongful acts of Defendantsand consequentlyare liable to plaintiff.
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WHEREFORE, Plaintiff prays for judgment againstO'Connor as

follows:

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For compensatorydamagesaccording to proof at the time of trial in an amount

not

lessthan Five Million Dollars ($5,000,000),togetherwith interestthereon

at the maximum legal

t 4 rate;
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For punitive damagespursuantto Civil Code Secti on3294 in an amount

appropriateto punish and set an example of Defendants,and each

of them, and to deter such

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conduct in the future, the exact amount of such punitive damages

subject to proof at the time of
1 8 trial:

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For all costs of suit and reasonableattorneys' fees incurred herein by plaintiffs
as

20 may be provided by law;

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For interest as may be provided by law; and

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For such other and further relief as the Court deemsjust and appropriate.

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,/

24 DATE:May) ,20t6

LAVELY & SINGER

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Attorneys for Plaintif0

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O HALL

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JURY DEMAND

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PlaintiffArsenioHall herebydemandstrial by jury.

,i /'
'DATE:May ,2016

LAVELY & SINGER

PROFES
SIONALCORPORATION
MARTIN D. SINGER ,...-'" /"

LYNDA
B,ggyowy

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,* /,,,

By: ;'' ! "-4

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ARTIN D. SINGE

Attorneysfor Plaintiff ARSEN

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