Syndney Holland Answer To Redstone Complaint

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CONFORMED COPY
ORIGINAL FILED
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Superior Cotut ot California

County of Los Angeles
Mark Holscher (SBN 139582)

mark.holscher@kirkland.com
Sierra Elizabeth (SBN 268133)
sierra. elizabeth@kirkland. com
KIRKLAND & ELLIS LLP
333 South Hope Street
Los Angeles, California 90071
Telephone: (213) 680-8400
Facsimile:
(213) 680-8500
DEC 12,2016
Sherri R. Carter, Executive Officer/Clerk
By Victor Sino-Cruz, Deputy
Counsel for Defendant

SYDNEY HOLLAND
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF LOS ANGELES
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SUMNER M. REDSTONE,
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Case No. BC638054
Plaintiff,
SYDNEY HOLLANDS ANSWER TO
PLAINTIFF SUMNER M. REDSTONES
COMPLAINT
vs.
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MANUELA HERZER, SYDNEY

HOLLAND; and DOES 1-10, inclusive,
Complaint Filed: October 25, 2016
Defendants.
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DEFENDANT SYDNEY HOLLANDS ANSWER
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Defendant SYDNEY HOLLAND (Sydney), through her attorneys, hereby answers Plaintiffs
unverified Complaint (Complaint), as follows:
GENERAL DENIAL
In accordance with the provisions of Code of Civil Procedure 431.10(d), Sydney denies,
generally and specifically, each and every allegation, statement, matter and purported cause of action
contained in the Complaint.
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***
For five years, Sydney and Plaintiff Sumner Redstone (Redstone) enjoyed a loving, romantic
relationship. Their courtship began in the fall of 2010, when Redstone hired Patti Stanger, The
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Millionaire Matchmaker to find him a girlfriend who was not only young and beautiful, but also
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intelligent, funny, and who shared Redstones Jewish faith.
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Patti knew Sydney was the perfect match, and contacted her right away.
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Almost immediately, the pair hit it off. They took long drives down the Malibu coast, listening
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to Tony Bennett and Frank Sinatra. They went to restaurants and shared Redstones favorite dessert,
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chocolate mousse. They watched movies and baseball. They attended charity events, movie premieres,
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and parties thrown on Redstones behalf. Before they knew it, they were spending nearly every waking
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moment with each other.
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By 2011, Redstone proposed to Sydney with a beautiful 9 carat yellow canary engagement ring,
and asked her to move in with him.
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She happily accepted.
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While Redstone often showed his affection by showering Sydney with jewelry, artwork, and
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cash gifts, he also frequently surprised her with beautiful red roses and orchids, or thoughtful notes:
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He listened to her and mentored her. He helped Sydney conceive her daughter, and was by
Sydneys side when her daughter was born in their home. He repeatedly told Sydney that he wanted to
spend the rest of his life with her and that he wanted to adopt her daughter. He added her daughter to his
Will. He assured her that he would take care of them for the rest of their lives. They were, by all
accounts, a close family unit.
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While Sydney could not match Redstones financial generosity, her love was no less deep, and
they enjoyed a mutually beneficial union through their love, support, and care for one another.
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A.
As Redstones primary companion, Sydney took on all the duties of a fiance and eventual wife.
Sydney took on all the duties of a fiance and eventual wife
She scheduled all his medical, dental, and therapy appointments and Redstone designated her as his
agent in his advance health care directive. When he wasnt feeling well, she was up with him during the
night:
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She added a much-needed womans touch to the home they now shared by decorating and
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reorganizing the furniture. She hosted Sunday movie days and arranged home-visits with long-time
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friends and guestsincluding well-known figures like Charlie Rose, Sherry Lansing, and Mike Milken.
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She also coordinated Redstones visits and meetings with Redstones business associates,
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Phillipe Dauman, Lesile Moonves, Carl Folta, George Abrams, Ace Greenberg, Tom Dooley, Steven
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Sweetwood, Brad Gray, Leonard Goldberg, Arnold Kopelson, and Robert Evans. Sydney scheduled
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Redstones appearances at shareholder meetings, as well as on earnings calls, for Viacom and CBS. She
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even helped Redstone organize a meeting of the entire board at their home in March 2013.
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Throughout their entire relationship, Redstone remained very active in the business activities of
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Viacom and CBS. He continued in his role as Executive Chairman of CBS and Executive Chairman and
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founder of Viacom. Numerous Securities and Exchange Commissions (SEC) filings reflect
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Redstones active and effective involvement in these complex business affairs:
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In an August 2, 2012 filing, Redstone stated: CBSs content continues to fuel the success of
this great company. In a world where great programming commands premium pricing, we
continue to hit on all the cylinders. I am extremely pleased with our terrific second-quarter
results.
In a May 1, 2013 CBS filing, Redstone stated: CBS has started the year with a terrific first
quarter. Our premium content and multiplatform distribution strategy are leading to results
that are better than ever.
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Just days before Redstones large cash gift to Sydney, in a May 8, 2014 filing, Redstone
stated: Im more excited than ever about the growth prospects before us and about all that
Leslie [Moonves] and his team are achieving quarter after quarter.
Less than a month after Redstones gift, another filing confirmed his active role in his
businesses: CBSs strategy of producing premium content across its businesses and all
around the world is the cornerstone of our continued success.
In fact, during the time he was with Sydney, Redstones contribution to his companies was
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recognized and rewarded by the boards. Redstones annual CBS salary increased over $100,000
between 2010 and 2012 based on the Compensation Committees evaluation of Mr. Redstones
performance, salary history and appropriate pay levels compared to our other senior executives. His
annual salary at Viacom increased a quarter of a million dollars beginning on January 1, 2014.
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After conducting a performance based evaluation, the Compensation Committee rewarded
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Redstone with a bonus above and beyond his projected bonus each year he was with Sydney. In 2011,
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his target bonus was $5 million but he received double that amount for his continued [oversight] of the
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Board of Directors where [u]nder his guidance, [CBS] had record-breaking results in key metrics,
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strengthened its financial position, and executed strategies to create and deliver value to its shareholders
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and to position [CBS] for long-term success. In 2012, Redstone also received a $10 million bonus,
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again doubling the target. The same in 2013. In 2014, Redstone was rewarded with $4 million over and
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above his $5 million target bonus. At Viacom, Redstones target bonus increased from $6 million to
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$7.15 million in 2014, but each year he received well above that amount for his [oversight of] the
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activities of the Board of Directors where [u]nder his leadership and vision, [Viacom] enhanced its
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financial position and continued to strengthen its overall business.
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Even when Redstones health began to decline, Sydney did everything she could to fulfill
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Redstones wish to live as long as humanly possible. She remained by Redstones side through every
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appointment and hospital visit. She hired an additional team of skilled nurses, doctors, and other care-
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givers who could provide 24-hour care. For example, when Redstones former primary care physician
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was unable to commit the significant additional time needed to care for Redstone, Sydneyon
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recommendation from Redstones close friend Mike Milkenhired a new primary care physician, Dr.
Gold, who remains Redstones trusted physician to this day. Sydney spoke with Dr. Gold about
Redstones care weekly. Dr. Gold closely observed Sydney with Redstone and saw that she was very
attentive to Redstones health care. Dr. Gold knew that without Sydney, Redstone would not be alive to
this day.
Sydney also welcomed Manuela Herzer (Herzer) into her home to help with Redstones health
care. Herzer was a close longtime friend and ex-girlfriend of Redstones and she cared for Redstone
deeply. Both Sydney and Herzer did everything they could to make sure that Redstone lived as
comfortable as possible and remained mentally active and vibrant, as reflected in the sworn declaration
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of Redstones granddaughter, Keryn Redstone:
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Reflecting Redstones love and gratitude for Sydney, Redstone added Sydney to his estate plan
bequeathing her a portion of his estate, amending his 2003 Trust to ensure that she could remain in their
home after his death, and giving her custody of his dogs, Sugar and Butterfly. He also told his estate
planning attorney, David Andelman (Andelman) that he wanted to marry Sydney and adopt her
daughter. Redstone shared the following letter with Sydney to keep her up to date on the process:
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Redstones generosity to Sydney was in stark contrast to his continued refusal to recognize any
member of his family in any version of his personal trust.
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B.
It was no secret, that long before Sydney met Redstone, the Redstone family was wrought with
Sydney tries to rebuild Redstones relationship with his daughter Shari Redstone
conflict. Indeed, in 2007, Redstone made clear to the boards of both Viacom and CBS that his daughter
Shari Redstone (Shari) should not succeed him after his death. In 2014, while he was dating Sydney,
he reaffirmed his wishes and provided Sydney with a copy of the following letter so that she could
ensure his wishes were carried out after his death:
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Redstone also frequently expressed his fundamental disagreements with Shari publically:
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Nevertheless, when Sydney entered Redstones life, she worked hard to try to bring the feuding
family together. Indeed, in the first few years of Sydney and Redstones relationship, Sydney had good
relationships with nearly all of Redstones family. Sydney communicated with the family frequently,
and arranged visits and calls from Shari, her children, Brandon Korff, Tyler Korff, and Kimberlee
Ostheimer, and Redstones great-grandchildren. The security guest log, which was routinely provided to
Sydney, indicates at least 16 visits from Shari during 2012-2014, which Sydney helped facilitate:
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She also invited Shari and her children to gatherings at the house, including Redstones 90th
birthday party which Sydney planned and threw for Redstone.
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And since Shari knew that she had to accept Sydney to have a relationship with her father, the
two had a very cordial relationship and frequently expressed kind sentiments to one another:
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C.
But Redstone did not trust Shari. Redstone knew that Sydney provided him with unconditional
Nevertheless, Redstone tries to protect Sydney from Shari
love, companionship, comfort, care, assistance, protection, affection, society, and moral support
throughout their relationship. In turn, he wanted to protect her, as any good partner would. As his
relationship with Sydney progressed, Redstone became fearful that Sydneys share in Redstones will or
the gifts that he had given her throughout their relationship, might be diluted or eliminated by litigation
from his family, especially Shari, after his death. Both Redstone and Sydney sensed an increasing
hostility and jealousy from Shari shortly after Sydneys daughter was born, whom she inevitably saw as
an additional threat to her eventual multibillion-dollar empire. Shari watched with her very own eyes,
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her fathers growing bond with Sydney and her daughter. She saw what was becoming a tight family
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bond that she always wished for.
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In fact, Sharis hostility and jealousy boiled over in the summer of 2014, when she hired legal
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counsel and threatened to sue Sydney and Herzer for undue influence over Redstone. Thus, to further
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protect Sydney, and the financial gifts that he had given her, Redstone hired four different legal teams to
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protect the women he cared about most. The additional teams worked alongside Redstones attorneys,
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Andelman and Leah Bishop (Bishop) to ensure that Redstones bequests to Sydney were iron-clad and
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could not be later challenged by Shari. Indeed, Redstone safeguarded his gifts and bequests by
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obtaining certificates of independent approval by independent legal counsel and Redstones physicians
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each time he amended his estate plan to confirm and document his capacity. Redstone also asked Shari
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to sign a letter releasing any potential legal claims she had against Sydney. It was so important to
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Redstone that he promised to exclude Shari from his funeral if she refused to agree to release any
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potential claims she had against Sydney:
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But Shari didnt care. Although she knew that all her father wanted was to give him and Sydney
peace of mind, she coldly refused. Shari was prepared to jeopardize going to her own fathers funeral so
that she could seek to later pursue a vendetta against Sydney despite the fact that Redstones gifts to
Sydney were made with stringent review and approval by Redstones counsel while he was the vibrant
Chairman of Viacom and CBS.
D.
Redstone gave money and gifts to many other women

Of course, Sydney and Herzer were not the only beneficiaries of Redstones
overwhelming generosity. During the time that Sydney and Herzer lived with Redstone, he was worth
over $6 billion and receiving millions of dollars in annual compensation and bonuses as Executive
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Chairman of CBS and Viacom. He lived his life as he wanted, despite what others thought, said, or
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found to be acceptable. Sydney learned early on the cardinal rule about life in the Redstone universe: it
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was his way or the highway. Redstone wanted her attention solely on him, even though he was not
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willing to give the same. Redstone was extremely generous, not just to Sydney and Herzer, but to many
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others, and he always gave of his own free-will. Redstone was strong-willed and did what he wanted
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when he gave gifts to Sydney. Those closest to him observed that he was mentally sharp at the time he
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gave the gifts. His house managers even stated so in sworn declarations:
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Over the five-year period that they were together, Redstone only gifted Sydney approximately
1.5% of his net worth; monies which were approved by Redstones attorneys and witnessed by
Redstones advisors, physicians, friends, and staff including Redstones house managers, Carlos and
Aurora Martinez. In fact, even Leslie MoonvesRedstones close friend and CBS Chief Executive
Officerknew about Redstones largest monetary gift to Sydney, on May 20, 2014. In contrast,
Redstone gave tens of millions of dollars to various other womenwho he had no intention of marrying
and was not in love withat the time he was engaged to marry Sydney. Women who did nothing more
than provide sexual favors.
Now, as a result of this lawsuit, the lurid nature of these relationships and the significant amounts
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of money that Redstone paid to these women, are directly at issue. Sydney may be forced to disclose
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their identities and call Redstones celebrity friends and Viacom and CBS executives as witnesses. By
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way of example, just while Sydney was living with Redstone:
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He gave one of his mistressesan aspiring reality show producerapproximately $21 million;
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He gave a flight attendant on the CBS corporate jet approximately $18 million;
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He later slept with her sister, who he gave approximately $6 million;
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He gave another woman who he had formally met through Patti Stanger $10-11 million;
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He gave another mistresswho claimed to be a modelover $7 million;
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He gave a friend of his grandsons girlfriend a job at Showtime and approximately $6

million;
He gave another mistress approximately $1.5 million;
He gave an ex-fiance and Paramount employee an undisclosed amount; and
He paid for a college students tuition at the University of Southern California and gave her
an undisclosed amount.
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Indeed, that the Complaint only names Sydney and Herzer as Defendants, when Redstone knows
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that there were (and possibly still are) many other women who he gave tens of millions of dollars to
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(during this same time-period that he alleges Sydney and Herzer had total control of his life) makes no
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sense. Whether naming DOES 1-10, inclusive was designed to intimidate these womenwho are
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presently identifiablefrom coming forward, is unclear.
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E.
Despite Redstones infidelity (and many other acts committed by Redstone and uncomfortable
Redstone was the one in control of Sydney, not the other way around
requests he made of Sydney that will not be detailed here) Redstone repeatedly told Sydney that she was
the only woman that he truly loved. She believed him.
Nevertheless, it was clear who controlled the relationship: Redstone. Redstone, the self-made
billionaire who built National Amusements, Inc. into a powerhouse that includes Viacom, Paramount,
and CBS; survived a hotel fire by holding onto a ledge for hours; and was fond of saying, Im not going
to die; was not one to take direction. For many years, Sydney had to be home for lunch and dinner
with him 7 days a week because Redstone expected her to be. When Redstone went to sleep, he
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demanded she go to sleep as well even if she didnt want to. Redstone forbid her from going out at
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night without him; again, she complied. She could not travel or take trips without him or spend time
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with friends. Her friendships withered and died. But, as always, he could do whatever he wanted.
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After years of monogamous commitment to Redstone (with none in return) and living in a very
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controlled environment, Sydney succumbed to a short-lived affair. Naively, when Sydney confessed her
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indiscretion to Redstone, she hoped for the same forgiveness and understanding that she had shown him
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during all of his affairs. But, to her devastation, Redstone broke off their engagement and asked Sydney
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to move out. He did not, however, ask her to return the gifts or money that he had given her.
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F.
Redstone and Sydney continued to care for each other just months before the filing
of this lawsuit
Over the next few months, Sydneys departure and end to their relationship destroyed Redstone.
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Herzer recounted that he cried inconsolably for Sydney and went into a visible downward spiral both
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physically and mentally. Very quickly, the wonderful attributes that made Redstone the man that he
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was, disappeared. It was true, unlike the other women in Redstones life, Sydneys departure deeply
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pained Redstone illuminating the depth of love Redstone had for her.
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Sydney tried her best to show Redstone her remorse. She sent letters, cards, flowers, and gifts to
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his home. She called the house, only to find the line was disconnected and the number changed. She
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only later learned that Shari had instructed the staff to block Sydney from Redstones life to ensure that
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there was no reconciliation. Shari instructed security to refuse to let Sydney or her deliveries through.
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She told the staff to screen Sydneys calls and refused to let Redstone speak to her. She filtered
Redstones mail to make sure that Sydneys heartfelt apologies did not reach him.
But Shari could only control so much. When Redstone successfully bypassed Sharis controls,
he immediately arranged a visit with Sydney. During that meeting in late fall 2015, Redstone wanted to
know why she had an affair. He needed to know what made their relationship fall apart. He missed
Sydneys daughter. Sydney jumped at the opportunity to speak with Redstone. However, her attempts
were once again thwarted by Sharis meddling. Sydney was escorted to Redstones formal living room
where she found Redstone watching TV. She quickly noticed Shari just an arms-length from Redstone.
Shari greeted Sydney with a cold stare, ignored Sydneys effort to exchange pleasantries and refused to
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speak to Sydneys daughter. When Sydney asked to speak with Redstone privately about their most
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personal matters, Shari refused to go. She sat perched over her father while Sydney profusely
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apologized for the biggest mistake of her life. Shari saw Redstone getting emotional and, fearful he may
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forgive Sydney, pressured Redstone to tell Sydney to leave. Eventually, he did. Again, Redstone never
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mentioned any regret about the gifts he gave to Sydney nor did he ask for his money back.
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Sydney, Redstone visited with Sydneys daughter, whom Sydney believes still remains in Redstones
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Will. Redstone never requested the return of the gifts he had given to Sydney or, by extension, her
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daughter. Indeed, in the near-year since Sydney moved out in 2015, Redstone has never asked for any
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of the gifts back or claimed that Sydney took advantage of him, until this lawsuit; which was filed
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shortly after Redstone requested to see Sydneys daughter a second time.
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***
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AFFIRMATIVE DEFENSES
In accordance with Code of Civil Procedure 431.30(b), Sydney sets forth the following
affirmative defenses. By setting forth these affirmative defenses, Sydney does not assume the burden of
proving any fact, issue, or element of a cause of action where such burden properly belongs to Plaintiff.
Moreover, nothing stated herein is intended to be construed as an acknowledgment that any particular
issue or subject matter is relevant to Plaintiffs allegations. Furthermore, Sydney is in the process of
conducting a factual investigation of Plaintiffs claims, and thus reserves the right to amend or
supplement the affirmative defenses accordingly.
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FIRST AFFIRMATIVE DEFENSE
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(Equitable Estoppel)
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Redstone is equitably estopped from asserting any claim for relief against Sydney respecting the
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matters that are the subject of the Complaint based on Redstones conduct, representations, and contrary
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arguments in (1) In Re Advance Health Care Directive of Sumner M. Redstone, L.A. Super. Ct., No.
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BP168725, (2) Feuer v. Dauman, Del. Ch. Ct., No. 12579-CB, (3) Feuer v. Redstone, Del. Ch. Ct., No.
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12575-CB, (4) City of Sunrise Gen. Employees Ret. Plan v. Redstone, Del. Ch. Ct., No. 12545-CB, and
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(5) Dauman v. Redstone, Mass. Prob. & Fam. Ct., No. 16E0020. For example, Redstone, as recently as
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November of last year, argued that he retained the capacity to make decisions regarding his estate
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planning documents including his Advance Health Care Directive. Counsel for Redstone also made
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repeated representations to other judicial officers that while Redstone was acting as Chairman of
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Viacom and CBSat the same time as the gifts in questionhe was fully capable of making complex
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decisions to reshape a multi-billion dollar corporation. Counsel are estopped now from making false
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factual and legal claims that at the same time he was capable of independently controlling his
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businesses, he was under total control by Sydney and Herzer and subject to undue influence.
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SECOND AFFIRMATIVE DEFENSE
(Statute of Limitations)
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Sydney is informed and believes, and thereon alleges, that Redstones claims are barred by the
applicable statutes of limitations.
THIRD AFFIRMATIVE DEFENSE
(Setoff and Recoupment)
To the extent Redstone is awarded any damages, liability for which Sydney wholly denies,
Sydney is entitled to recoupment for the reasonable value of services provided.
FOURTH AFFIRMATIVE DEFENSE
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(Privilege/Justification)
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Redstone is barred from recovery for Intentional Infliction of Emotional Distress because any
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actions or statements alleged in the Complaint were privileged under Cal. Civ. Code 47(c) or otherwise
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justified.
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FIFTH AFFIRMATIVE DEFENSE
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(Laches)
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Redstones claim is barred by the doctrine of laches for unreasonable delay in bringing this
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action.
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SIXTH AFFIRMATIVE DEFENSE
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(Consent)
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Redstone is barred from recovery because Redstone consented to the alleged harm by Sydney.
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SEVENTH AFFIRMATIVE DEFENSE
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(Failure to State a Cause of Action on Which Relief May Be Granted)
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The Complaint, and each alleged cause of action alleged therein, fails to state facts sufficient to
constitute a cause of action, or any cause of action on which relief may be granted, against Sydney.
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EIGHTH AFFIRMATIVE DEFENSE
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(Failure to Plead Fraud with Particularity)
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Redstones claims are barred because he failed to plead the allegations of fraud with
particularity.
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NINTH AFFIRMATIVE DEFENSE
(Acquiescence and Waiver)
Redstone has waived, relinquished and/or abandoned any claim for relief against Sydney
respecting the matters that are the subject of the Complaint.
TENTH AFFIRMATIVE DEFENSE
(Intervening Acts)
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Redstone is barred from recovery against Sydney because Redstones harm was caused by an
event or person that occurred after the allegations in the Complaint occurred.
ELEVENTH AFFIRMATIVE DEFENSE
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(No Entitlement to Punitive Damages)
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Neither the Complaint nor any purported cause of action alleged therein states facts sufficient to
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entitle Redstone to an award of punitive damages against Sydney, and the prayer for punitive damages
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should be dismissed as a matter of law.
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TWELFTH AFFIRMATIVE DEFENSE
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(Unconstitutional Fine or Penalty)
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The imposition of any punitive damages in this matter would constitute a criminal fine or penalty
and should, therefore, be remitted on the ground that the award violates the United States Constitution.
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THIRTEENTH AFFIRMATIVE DEFENSE
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(Promissory Estoppel)
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Redstones claims are barred based on promissory estoppel because Redstone made
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representations to Sydney, Sydney reasonably relied on those representations, and Redstone now seeks
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to change his position causing substantial harm to Sydney.
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FOURTEENTH AFFIRMATIVE DEFENSE
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(Acts of Third Parties)
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Redstones claim is barred because it is the direct product of extraneous acts of third parties
attempting to interfere with economic relations.
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FIFTEENTH AFFIRMATIVE DEFENSE
(Abuse of Process)
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Redstones claim is barred because Redstone filed this complaint for improper purposes
including embarrassment and revenge.
SIXTEENTH AFFIRMATIVE DEFENSE
(Impossibility)
Redstones claims against Sydney are based on an underlying contract for domestic services in
exchange for Redstones financial support. Redstones claims based on that agreement are barred
because performance by Sydney was impossible after Sydney was exiled from Redstones life.
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SEVENTEENTH AFFIRMATIVE DEFENSE
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(Impracticability)
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exchange for Redstones financial support. Redstones claims on that agreement are barred because any
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performance by Sydney was excused because further performance was no longer practical.
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EIGHTEENTH AFFIRMATIVE DEFENSE
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(Mistake)
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exchange for Redstones financial support. Redstones claims are barred because the parties were
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mistaken regarding the terms of the agreement for support and domestic services between Redstone and
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Sydney.
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NINETEENTH AFFIRMATIVE DEFENSE
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(Frustration of Purpose)
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exchange for Redstones financial support. Redstones claims are barred because the purpose of the
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agreement between Sydney and Redstone was frustrated by unforeseen events, therefore excusing
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Sydney from further obligations on their contract.
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TWENTIETH AFFIRMATIVE DEFENSE
(Excuse)
exchange for Redstones financial support. Redstones claims are barred because her performance under
the contract was excused when third-parties made it impossible for Sydney to perform on the contract.
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DATED: December 12, 2016
KIRKLAN D J&'ELLI S LLP
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^'ftfark Holscher (SBN 139582)

Sierra Elizabeth (SBN 268133)
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Attorneys for Defendant Sydney Holland
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PROOF OF SERVICE
I, Laura Bay, am employed in the County of Los Angeles, State of California. I am over the
age of 18 and not a party to the within action. My business address is 333 South Hope Street, Los
Angeles, California 90071.
On December 12, 2016, the foregoing document was served on the interested parties in this
action as follows:
[
] By causing a copy of the document to be personally served by hand to the person at
the addresses set forth below
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[ X ] By placing the document listed above in a sealed envelope with postage thereon fully
prepaid, in the United States mail at Los Angeles, California addressed as set forth below. I am
familiar with the firm's practice of collection and processing correspondence for mailing. Under that
practice it would be deposited with the United States Postal Service on that same day with postage
thereon fully prepaid in the ordinary course of business.
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Robert Klieger
Marshall Camp
Andrew Walsh
HUESTON HENNIGAN LLP
523 West 6th Street, Suite 400
Los Angeles, CA 90014
Telephone: (213)788-4370
Ronald Richards
Nicholas Bravo
THE LAW OFFICES OF RONALD RICHARDS
& ASSOCIATES, A.P.C.
P.O. Box 11480
Beverly Hills, CA 90213
Telephone: (310)556-1001
Attorneys for PlaintiffSumner M. Redstone
Attorneys for Defendant, Manuela Herzer
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[ X ] (STATE) I declare under penalty of perjury under the laws of the State of
California that the above is true and correct.
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PROOF OF SERVICE

Syndney Holland Answer To Redstone Complaint

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Syndney Holland Answer To Redstone Complaint

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m

Superior Cotut ot California

Mark Holscher (SBN 139582)

Counsel for Defendant

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

Case No. BC638054

MANUELA HERZER, SYDNEY

Complaint Filed: October 25, 2016

DEFENDANT SYDNEY HOLLANDS ANSWER

contained in the Complaint.

intelligent, funny, and who shared Redstones Jewish faith.

moment with each other.

She happily accepted.

accounts, a close family unit.

Sydney took on all the duties of a fiance and eventual wife

Redstones active and effective involvement in these complex business affairs:

After conducting a performance based evaluation, the Compensation Committee rewarded

financial position and continued to strengthen its overall business.

of Redstones granddaughter, Keryn Redstone:

ensure his wishes were carried out after his death:

Nevertheless, Redstone tries to protect Sydney from Shari

bond that she always wished for.

potential claims she had against Sydney:

Chairman of Viacom and CBS.

Redstone gave money and gifts to many other women

than provide sexual favors.

way of example, just while Sydney was living with Redstone:

He later slept with her sister, who he gave approximately $6 million;

He gave another mistresswho claimed to be a modelover $7 million;

He gave a friend of his grandsons girlfriend a job at Showtime and approximately $6

He gave another mistress approximately $1.5 million;

He gave an ex-fiance and Paramount employee an undisclosed amount; and

presently identifiablefrom coming forward, is unclear.

the only woman that he truly loved. She believed him.

shortly after Redstone requested to see Sydneys daughter a second time.

supplement the affirmative defenses accordingly.

SECOND AFFIRMATIVE DEFENSE

THIRD AFFIRMATIVE DEFENSE

(Setoff and Recoupment)

Sydney is entitled to recoupment for the reasonable value of services provided.

FOURTH AFFIRMATIVE DEFENSE

FIFTH AFFIRMATIVE DEFENSE

SIXTH AFFIRMATIVE DEFENSE

SEVENTH AFFIRMATIVE DEFENSE

(Failure to State a Cause of Action on Which Relief May Be Granted)

EIGHTH AFFIRMATIVE DEFENSE

(Failure to Plead Fraud with Particularity)

NINTH AFFIRMATIVE DEFENSE

(Acquiescence and Waiver)

respecting the matters that are the subject of the Complaint.

TENTH AFFIRMATIVE DEFENSE

ELEVENTH AFFIRMATIVE DEFENSE

(No Entitlement to Punitive Damages)

should be dismissed as a matter of law.

TWELFTH AFFIRMATIVE DEFENSE

(Unconstitutional Fine or Penalty)

THIRTEENTH AFFIRMATIVE DEFENSE

to change his position causing substantial harm to Sydney.

FOURTEENTH AFFIRMATIVE DEFENSE

(Acts of Third Parties)

FIFTEENTH AFFIRMATIVE DEFENSE

SIXTEENTH AFFIRMATIVE DEFENSE