This document is a 47-page legal declaration submitted as evidence in a court case. It provides a detailed rebuttal of defamatory statements made about the declarant in a book. The declarant denies allegations of criminal acts and homosexual relationships. Descriptions of their actual close personal relationships contradict the book's claims. The declarant also questions the credibility of anonymous sources and asserts the book was written with actual malice.
25. Case 1:07-cv-08536-DC Document 150 Filed 09/28/2009 Page 25 of 47
in drag.”
58. Indeed, there is no comparison between anything shown on the Anna
Nicole Show, and the lies written in Blonde Ambition. I am dubious of Rita Cosby’s and
Mr. Littlefield’s claims to have watched both seasons of the Anna Nicole Show in writing
Blonde Ambition (especially since I recently confirmed that only the first season is
available on DVD). However, the show is extremely relevant to the issue of actual
malice. Anybody who watched the show would have seen my extremely close
relationships with Anna and Daniel, a closeness that cannot be faked. The reciprocated
love evident in the show would make the false and defamatory statements in Blonde
Ambition highly implausible. This is only underscored when combined with the suspect
nature of every so-called source.27
Libelous Statements 1 & 2: Criminal Lewd Act, and Videotaped Homosexual Act
59. There is absolutely no truth to the statements in Blonde Ambition at pages
202-204, apparently from Jackie Hatten, to the effect that Larry Birkhead and I were
engaged in homosexual sex at a party. There is absolutely no truth to the statements in
Blonde Ambition at page 204, apparently from Don Clark and Wilma Vicedomine, to the
effect that Anna watched a homosexual videotape of Larry Birkhead and me. Both
stories are entirely fictional.
60. I am heterosexual. I am not homosexual. I have never engaged in any
type of remotely “romantic” or “sexual” activity with Larry Birkhead or any other man.
61. I have never been videotaped during any sexual act, or been involved in
any sexual video.
27
A true and correct copy of the DVD of the first season of the Anna Nicole Show and
additional scenes released by E! are filed under seal as Exhibit 12 hereto.
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