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    Case 2:20-cv-01218-RSL-MLP Document 139 Filed 12/18/20 Page 1 of 29 1 THE HONORABLE RICHARD A. JONES 2 THE HONORABLE MARY ALICE THEILER 3 4 5 6 UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 8 9 VICKY CORNELL, individually, and in No. 2:20-cv-01218−RAJ−MAT her capacity as the Personal Representative 10 of the Estate of Christopher John Cornell SECOND AMENDED COMPLAINT a/k/a Chris Cornell, 11 JURY DEMAND Plaintiffs, 12 v. 13 SOUNDGARDEN, a purported 14 Washington General Partnership, KIM A. THAYIL, MATT D. CAMERON, 15 HUNTER BENEDICT SHEPHERD, RIT VENERUS and CAL FINANCIAL 16 GROUP, INC., 17 Defendants. 18 19 Plaintiff Vicky Cornell, individually and in her capacity as the Personal Representative of 20 the Estate of Christopher John Cornell (collectively, “Plaintiffs”), hereby files Plaintiffs’ First 21 Amended Complaint against defendants Soundgarden, Kim Thayil, Matt Cameron, Hunter 22 Benedict Shepherd, Rit Venerus, and Cal Financial Group, Inc. (collectively, “Defendants”). 23 24 25 26 SECOND AMENDED COMPLAINT Perkins Coie LLP (No. 2:20−cv−01218−RAJ−MAT)–1 1201 Third Avenue, Suite 4900 Seattle, WA 98101-3099 Phone: 206.359.8000 Fax: 206.359.9000 Case 2:20-cv-01218-RSL-MLP Document 139 Filed 12/18/20 Page 2 of 29 1 I. INTRODUCTION 2 “Everybody out for my blood, everybody want my percent ... 3 They just want to take what is mine, how much more can they get.” 4 - Sweet Revenge 5 1. In 2009, Chris Cornell penned these lyrics about his former Soundgarden 6 bandmates after they unlawfully (and unsuccessfully) attempted to deprive him of his rights in 7 connection with the valuable musical works that he created for the band.