Complaint 12-9-2019
Case 1:19-cv-25045-JEM Document 1 Entered on FLSD Docket 12/09/2019 Page 1 of 24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO. 1:19cv25045 Vicky Cornell, individually, and in her JURY TRIAL DEMANDED capacity, and as the Personal Representative of the Estate of Christopher John Cornell a/k/a Chris Cornell, Plaintiffs, v. Soundgarden, a purported Washington General Partnership, Kim A. Thayil, Matt D. Cameron, Hunter Benedict Shepherd, Rit Venerus and Cal Financial Group, Inc., Defendants. ______________________________________________/ COMPLAINT Plaintiff, Vicky Cornell, individually and in her capacity as the personal representative of the Estate of Christopher John Cornell (collectively, “Plaintiffs”) through counsel, hereby files the following complaint against the defendants, Soundgarden, Kim Thayil, Matt Cameron, Hunter Benedict Shepherd, Rit Venerus and Cal Financial Group, Inc. (collectively, “Defendants”). I. INTRODUCTION “Everybody out for my blood, everybody want my percent … They just want to take what is mine, how much more can they get.” - Sweet Revenge 1. In 2009, Chris Cornell penned these lyrics about his former Soundgarden bandmates after they unlawfully (and unsuccessfully) attempted to deprive him of his rights in connection with the valuable musical works that he created for the band. Ten years later, and after Chris’ untimely passing, these lyrics hauntingly resonate as his former bandmates, once Case 1:19-cv-25045-JEM Document 1 Entered on FLSD Docket 12/09/2019 Page 2 of 24 again, have attempted to “take what is his” – or, more aptly, to steal from his widow and minor children. This wrongful conduct shockingly started shortly after Chris’ untimely death and ultimately forced his widow, Vicky Cornell, to bring this lawsuit.
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