SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

Civil Division
Central District, Stanley Mosk Courthouse, Department 48

24STCV17314 November 21, 2024

AMANDA GHOST, AN INDIVIDUAL, et al. vs REBEL 8:30 AM
WILSON, AN INDIVIDUAL

Judge: Honorable Thomas D. Long CSR: Kathy Thibodeaux, #9858

Judicial Assistant: Emily Ma Reyes ERM: None
Courtroom Assistant: Roger E. Lomeli Deputy Sheriff: None

APPEARANCES:
For Plaintiff(s): Samuel A. Moniz and Camille Marilia Vasquez (Telephonic) (via CourtConnect)
For Defendant(s): Bryan J. Freedman, Jean-Paul Jassy, and Jacob T. Bolan

NATURE OF PROCEEDINGS: DEFENDANT'S SPECIAL MOTION TO STRIKE FIRST

AMENDED COMPLAINT PURSUANT TO CODE OF CIVIL PROCEDURE §425.16

PLAINTIFFS' MOTION FOR LEAVE TO TAKE LIMITED DISCOVERY

Pursuant to Government Code §§68086, 70044, and California Rules of Court, Rule 2.956, Katie
Thibodeaux, CSR #: 9858, certified shorthand reporter is appointed as an official Court reporter
pro tempore in these proceedings, and is ordered to comply with the terms of the Court Reporter
Agreement. The Order is signed and filed this date.

The matters are called for hearing.

The Court issues a Tentative Ruling and hears oral argument.

The Court, having heard oral argument, takes the matter under submission.

LATER:

The Court, having taken the matter under submission, now rules as follows:

On July 12, 2024, Plaintiffs Amanda Ghost, Gregor Cameron, and Vince Holden filed this action
against Defendant Rebel Wilson. On July 29, 2024, the Plaintiffs filed a First Amended
Complaint (“FAC”).

On October 21, 2024, Wilson filed a Special Motion to Strike under Code of Civil Procedure
§425.16 (“anti-SLAPP motion”).
Minute Order Page 1 of 9
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 48

24STCV17314 November 21, 2024

AMANDA GHOST, AN INDIVIDUAL, et al. vs REBEL 8:30 AM
WILSON, AN INDIVIDUAL

Judge: Honorable Thomas D. Long CSR: Kathy Thibodeaux, #9858

Judicial Assistant: Emily Ma Reyes ERM: None
Courtroom Assistant: Roger E. Lomeli Deputy Sheriff: None

On October 29, 2024, the Plaintiffs filed a Motion for Leave to Take Limited Discovery in order
to oppose the anti-SLAPP motion.

I. DEFENDANT'S SPECIAL MOTION TO STRIKE FIRST AMENDED COMPLAINT

PURSUANT TO CODE OF CIVIL PROCEDURE §425.16

The DEFENDANT'S SPECIAL MOTION TO STRIKE FIRST AMENDED COMPLAINT

PURSUANT TO CODE OF CIVIL PROCEDURE §425.16 filed by Rebel Wilson on
10/21/2024 is Denied.

“A cause of action against a person arising from any act of that person in furtherance of the
person’s right of petition or free speech under the United States Constitution or California
Constitution in connection with a public issue shall be subject to a special motion to strike unless
the court determines that the plaintiff has established that there is a probability that the plaintiff
will prevail on the claim.” (Code of Civil Procedure §425.16, subd.[b][1].)

“A court’s consideration of an anti-SLAPP motion involves a two-step process. ‘First, the court
decides whether the defendant has made a threshold showing that the challenged cause of action
is one arising from protected activity. The moving Defendant’s burden is to demonstrate that the
act or acts of which the Plaintiff complains were taken “in furtherance of the [defendant]’s right
of petition or free speech under the United States or California Constitution in connection with a
public issue,” as defined in the statute. [Citation.] If the court finds such a showing has been
made, it then determines whether the plaintiff has demonstrated a probability of prevailing on the
claim.’ [Citation.] In the second step, the plaintiff must only bring forward sufficient evidence to
make out a viable prima facie case at trial, a burden that ‘is not particularly high.’ [Citation.]”
(O&C Creditors Group, LLC v. Stephens & Stephens XII, LLC (2019) 42 Cal.App.5th 546, 565
- 566.)

a. Plaintiffs’ Request for Judicial Notice Granted in Part

The Plaintiffs’ Request for Judicial Notice of Exhibits 12, 14, 16, 21 - 27 is Granted. In doing so,
the Court takes Judicial Notice of only their existence, not the truth of their contents.

b. Evidentiary Objections Overruled

The Plaintiffs’ 65 pages of Objection Nos. 1 - 49 are Overruled.

Minute Order Page 2 of 9
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 48

24STCV17314 November 21, 2024

AMANDA GHOST, AN INDIVIDUAL, et al. vs REBEL 8:30 AM
WILSON, AN INDIVIDUAL

Judge: Honorable Thomas D. Long CSR: Kathy Thibodeaux, #9858

Judicial Assistant: Emily Ma Reyes ERM: None
Courtroom Assistant: Roger E. Lomeli Deputy Sheriff: None

Wilson’s 99 pages of Objection Nos. 1 - 121 are Overruled.

c. Plaintiffs Allege Nine Statements

The Plaintiffs’ sole cause of action for defamation is based on nine statements published in two
manners.

On July 10, 2024, Wilson published a video on her Instagram page. (FAC, ¶¶35, 43.) This video
expressed or implied that (1) Plaintiffs sexually harassed a lead actress involved in the Film; (2)
Plaintiffs embezzled funds from the Film’s financing for personal gain; and (3) Plaintiffs acted
with inappropriate behavior towards the lead actress of the Film. (FAC, ¶43.)

On June 14, 2024, Wilson’s Counsel sent a demand letter to Plaintiffs’ Counsel demanding a
compromise of Wilson’s claims and arguing that Wilson is entitled to writing credit on the Film
and a record label. (FAC, ¶10.) The Plaintiffs allege that Wilson later provided the demand letter
to the media, causing its statements to be republished. (FAC, ¶¶11, 38 - 40, 44.) The demand
letter communicated that (1) Ghost and Cameron embezzled 900,000 Australian Dollars from the
Film; (2) Ghost and Cameron have a pattern and practice of embezzlement, including on other
projects; (3) Ghost and Cameron sexually harassed a lead actress of the Film; (4) Ghost and
Cameron maintained coercive control on a lead actress of the Film and forced her to engage in
depraved sexual demands; (5) a lead actress of the Film is being held captive by Ghost and
Cameron and is being taken across state lines; (6) Cameron used physical aggression to bully
Wilson and wrongfully imprisoned her. (FAC, ¶¶40, 44.)

d. Wilson Has Not Shown that Video Was Protected Activity

“[A]ny written or oral statement or writing made in a place open to the public or a public forum
in connection with an issue of public interest” and “any other conduct in furtherance of the
exercise of the constitutional right of petition or the constitutional right of free speech in
connection with a public issue or an issue of public interest” are protected under the anti-SLAPP
statute. (Code of Civil Procedure §425.16, subds.[e][3], [e][4].)

Wilson argues that she and the Plaintiffs “are public figures and persons ‘in the public eye’ by
virtue of their extensive experience in the entertainment industry, which is the focus of Wilson’s
speech and alleged speech.” (Motion at p. 5.) “While courts have held the public’s interest in the
life and work of entertainers and other celebrities can create an issue of public interest for
Minute Order Page 3 of 9
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 48

24STCV17314 November 21, 2024

AMANDA GHOST, AN INDIVIDUAL, et al. vs REBEL 8:30 AM
WILSON, AN INDIVIDUAL

Judge: Honorable Thomas D. Long CSR: Kathy Thibodeaux, #9858

Judicial Assistant: Emily Ma Reyes ERM: None
Courtroom Assistant: Roger E. Lomeli Deputy Sheriff: None

purposes of section 425.16, subdivision (e) [citation], it is the subject of the Defendant’s speech
or conduct that determines whether an issue of public interest has been implicated for purposes
of anti-SLAPP protection. [Citation.] The defendant’s celebrity status, on its own, is not
sufficient to render anything the defendant says or does subject to anti-SLAPP protection.”
(Bernstein v. LaBeouf (2019) 43 Cal.App.5th 15, 23 (Bernstein).)

Wilson also argues that “[t]he unfortunately endemic issue of inappropriate behavior, including
sexual harassment, on movie sets is a matter of profound and continuing public interest,”
“[e]mbezzlement from film budgets is a matter of public interest, and is frequently the subject of
civil and criminal lawsuits, and reporting in the press,” and “[t]ax fraud is a matter of public
interest.” (Motion at pp. 5 - 6.)

These assertions of public interest due to the identity of the parties and a broad public interest are
insufficient to show that they are protected activity. “[I]n order to satisfy the public issue/issue of
public interest requirement of section 425.16, subdivision (e)(3) and (4) of the anti-SLAPP
statute, in cases where the issue is not of interest to the public at large, but rather to a limited, but
definable portion of the public (a private group, organization, or community), the constitutionally
protected activity must, at a minimum, occur in the context of an ongoing controversy, dispute or
discussion, such that it warrants protection by a statute that embodies the public policy of
encouraging participation in matters of public significance.” (Du Charme v. International
Brotherhood of Electrical Workers (2003) 110 Cal.App.4th 107, 119 (Du Charme).)

“[T]he statute requires that there be some attributes of the issue which make it one of public,
rather than merely private, interest. A few guiding principles may be derived from decisional
authorities. First, ‘public interest’ does not equate with mere curiosity. Second, a matter of public
interest should be something of concern to a substantial number of people. Thus, a matter of
concern to the speaker and a relatively small, specific audience is not a matter of public interest.
Third, there should be some degree of closeness between the challenged statements and the
asserted public interest; the assertion of a broad and amorphous public interest is not sufficient.
Fourth, the focus of the speaker’s conduct should be the public interest rather than a mere effort
‘to gather ammunition for another round of [private] controversy. . . .’ Finally, ‘those charged
with defamation cannot, by their own conduct, create their own defense by making the claimant
a public figure.’ A person cannot turn otherwise private information into a matter of public
interest simply by communicating it to a large number of people.” (Weinberg v. Feisel (2003)
110 Cal.App.4th 1122, 1132 - 1133 (Weinber), citations omitted.)

“[A] court must consider the context as well the content of a statement in determining whether
Minute Order Page 4 of 9
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 48

24STCV17314 November 21, 2024

AMANDA GHOST, AN INDIVIDUAL, et al. vs REBEL 8:30 AM
WILSON, AN INDIVIDUAL

Judge: Honorable Thomas D. Long CSR: Kathy Thibodeaux, #9858

Judicial Assistant: Emily Ma Reyes ERM: None
Courtroom Assistant: Roger E. Lomeli Deputy Sheriff: None

that statement furthers the exercise of constitutional speech rights in connection with a matter of
public interest.” (FilmOn.com Inc. v. DoubleVerify Inc. (2019) 7 Cal.5th 133, 149 (FilmOn).)
“First, we ask what ‘public issue or [ ] issue of public interest’ the speech in question
implicates—a question we answer by looking to the content of the speech. (§425.16,
subd.[e][4].) Second, we ask what functional relationship exists between the speech and the
public conversation about some matter of public interest. It is at the latter stage that context
proves useful.” (Id. at pp. 149 - 150.)

The “public interests” of “inappropriate behavior, including sexual harassment, on movie sets,”
“embezzlement from film budgets,” and “tax fraud” (Motion at pp. 5-6) are broad and
amorphous public interests that are not closely related to the challenged statements. In the video,
Wilson spoke about the Film, her directing debut, “the joy of the movie being selected,” and her
business partners preventing the movie from premiering. (FAC, ¶35.) She asserted that they
stopped the premiere because she “discovered bad behavior by these business partners,”
identifying Plaintiffs by name. (FAC, ¶35.) Wilson states that she reported “their bad behavior
when I found out not minor things, big things, you know, inappropriate behavior towards the
lead actress of the film, embezzling funds from the film’s budget.” (FAC, ¶35.) She also asserts
that Ghost “has a history of doing this kind of thing, mainly to music artists but also to people in
the film business. So, the thing is, these people are forced to sign NDAs or, you know, otherwise
threatened or bullied to not speak out.” (FAC, ¶35.)

These statements are not made in the context of an ongoing controversy, dispute, or discussion
about “inappropriate behavior, including sexual harassment, on movie sets,” “embezzlement
from film budgets,” and “tax fraud.” They were not made during Wilson’s participation in
matters of public interest. (See Du Charme, supra, 110 Cal.App.4th at p. 119.) Instead, they were
made in the context of Wilson’s private business dispute with the Plaintiffs surrounding the
production and premiere of the Film. (See, e.g., ¶¶7 - 10.) Additionally, “[t]he United States
Supreme Court also has rejected the claim that assertions of criminal conduct automatically fall
within the public interest. [Citation.] As we have noted, there are no charges pending against
plaintiff, and defendant has not taken action intended to result in a criminal investigation or
prosecution. The fact that defendant’s statements accuse plaintiff of criminal conduct make them
defamatory on their face. [Citation.] It does not automatically make them a matter of public
interest.” (Weinberg, supra, 110 Cal.App.4th at p. 1135.)

At the hearing, Wilson’s Counsel emphasized Geiser v. Kuhns (2022) 13 Cal.5th 1238 (Geiser)
for the proposition that speech may implicate a public issue even if it also implicates a private
dispute. (See also Motion at p. 5, fn. 1; Reply at p. 1.) In Geiser, the California Supreme Court
Minute Order Page 5 of 9
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 48

24STCV17314 November 21, 2024

AMANDA GHOST, AN INDIVIDUAL, et al. vs REBEL 8:30 AM
WILSON, AN INDIVIDUAL

Judge: Honorable Thomas D. Long CSR: Kathy Thibodeaux, #9858

Judicial Assistant: Emily Ma Reyes ERM: None
Courtroom Assistant: Roger E. Lomeli Deputy Sheriff: None

made explicit the standard for analysis under FilmOn: “FilmOn’s first step is satisfied so long as
the challenged speech or conduct, considered in light of its context, may reasonably be
understood to implicate a public issue, even if it also implicates a private dispute. Only when an
expressive activity, viewed in context, cannot reasonably be understood as implicating a public
issue does an anti-SLAPP motion fail at FilmOn’s first step.” (Geiser, supra, 13 Cal.5th at pp.
1253 - 1254.)

Here, Wilson’s statements have only a limited connection to the asserted public issues.
“[V]irtually always, defendants succeed in drawing a line—however tenuous—connecting their
speech to an abstract issue of public interest." (FilmOn, supra, 7 Cal.5th at p. 150.) “‘[I]t is not
enough that the statement refer to a subject of widespread public interest; the statement must in
some manner itself contribute to the public debate.’” (Ibid.) Wilson did not contribute to the
public debate about inappropriate behavior, sexual harassment, embezzlement, or tax fraud. Her
speech is not comparable to the protest in Geiser, which “might have served the purpose of
facilitating a repurchase of the property” (a private issue), but “also served to draw attention to
the alleged unfairness of the business practices” used for the foreclosure and eviction. (Geiser,
supra, 13 Cal.5th at p.1255.) There, “[t]he context makes clear that [the] sidewalk protest
furthered public discussion of the public issues it implicated.” (Ibid.) Here, Wilson’s speech did
not further the public discussion of the asserted public issues. Instead, it focused on her side of
an otherwise private business dispute about her involvement with the Film.

Wilson argues that the challenged statements could affect large numbers of people beyond the
direct participants because many people worked on the Film and could be affected by its success
or failure. (Motion at p. 6.) She argues that “[t]he number of people who worked on the film [‘a
cast of over 140 and a production crew of hundreds more’], and coverage of it as Wilson’s
directorial debut, show that the film and its success are matters of public interest.” (Ibid.).
Wilson relies on Tamkin v. CBS Broadcasting, Inc. (2011) 193 Cal.App.4th 133 to show that the
creation of a television episode can be an issue of public interest. There, the alleged acts were
based on using the Plaintiffs’ names in drafts of the scripts and disseminating those scripts and
casting synopses. (Tamkin, supra, 193 Cal.App.4th at p. 143.) The acts were in furtherance of the
right to free speech because “[t]he creation of a television show is an exercise of free speech,”
and “defendants’ acts helped to advance or assist in the creation, casting, and broadcasting of an
episode of a popular television show.” (Ibid.) Wilson’s video was not part of the creation of the
Film and did not advance its production.

The Court finds that the video is not protected activity under the anti-SLAPP statute.

Minute Order Page 6 of 9

 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 48

24STCV17314 November 21, 2024

AMANDA GHOST, AN INDIVIDUAL, et al. vs REBEL 8:30 AM
WILSON, AN INDIVIDUAL

Judge: Honorable Thomas D. Long CSR: Kathy Thibodeaux, #9858

Judicial Assistant: Emily Ma Reyes ERM: None
Courtroom Assistant: Roger E. Lomeli Deputy Sheriff: None

e. Wilson Has Not Shown that Transmitting Demand Letter Was Protected Activity

“[A]ny written or oral statement or writing made in connection with an issue under consideration
or review by a legislative, executive, or judicial body, or any other official proceeding authorized
by law” is protected under the anti-SLAPP statute. (Code of Civil Procedure §425.16,
subd.[e][2].)

“Under the plain language of section 425.16, subdivisions (e)(1) and (e)(2), as well as the case
law interpreting those provisions, all communicative acts performed by attorneys as part of their
representation of a client in a judicial proceeding or other petitioning context are per se protected
as petitioning activity by the anti-SLAPP statute.” (Cabral v. Martins (2009) 177 Cal.App.4th
471, 479 - 480.) “An attorney’s communication with opposing counsel on behalf of a client
regarding pending litigation directly implicates the right to petition and thus is subject to a
special motion to strike.” (GeneThera, Inc. v. Troy & Gould Professional Corp. (2009) 171
Cal.App.4th 901, 908.)

In connection with the Film, Wilson fought for writing credit, credit with the writers of the music
for the Film, and a record label with an external music group. (FAC, ¶7.) Wilson’s demand letter
to the Plaintiffs demanded a compromise of her claims, writing credit, and a record label. (FAC,
¶10.)

Wilson argues that “the Demand Letter relates to prelitigation communications from lawyers, but
allegedly was disseminated by Wilson to the press after the original Complaint was filed,” and
she “not only seriously considered claims against Plaintiffs, but she ultimately brought those
claims in a Cross-Complaint filed in this action.” (Motion at p. 6.)

Wilson’s October 1, 2024 Cross-Complaint generally alleges breaches of contract and fiduciary
duty (failure to provide writing credit and record deal), a single event of false imprisonment,
misrepresentations about the Film partnership, and emotional distress from bullying and
harassing Wilson for reporting misconduct.

“[A] statement is ‘in connection with’ litigation under section 425.16, subdivision (e)(2) if it
relates to the substantive issues in the litigation and is directed to persons having some interest in
the litigation.” (Neville v. Chudacoff (2008) 160 Cal.App.4th 1255, 1266.) The anti-SLAPP
statute is “construed broadly, to protect the right of litigants to ‘the utmost freedom of access to
the courts without the fear of being harassed subsequently by derivative tort actions.’” (Healy v.
Tuscany Hills Landscape & Recreation Corp. (2006) 137 Cal.App.4th 1, 5.)
Minute Order Page 7 of 9
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 48

24STCV17314 November 21, 2024

AMANDA GHOST, AN INDIVIDUAL, et al. vs REBEL 8:30 AM
WILSON, AN INDIVIDUAL

Judge: Honorable Thomas D. Long CSR: Kathy Thibodeaux, #9858

Judicial Assistant: Emily Ma Reyes ERM: None
Courtroom Assistant: Roger E. Lomeli Deputy Sheriff: None

The demand letter does not fit this description. The creation of the demand letter (directed at the
Plaintiffs) and the service of it on the Plaintiffs is protected activity. But that is not the basis for
the Plaintiffs’ claims. Instead, the Plaintiffs allege that Wilson (or someone acting on her behalf
and at her direction) transmitted the demand letter to the media for republication. (FAC, ¶¶11, 39
- 40, 44.) The republication of Wilson’s own demand letter does not subject Wilson to a risk of
subsequent tort litigation based on the underlying contemplated litigation (the claims in her later-
filed Cross-Complaint). Wilson’s alleged statements republication by the media (through
transmission of the demand letter) were not directed to persons having some interest in the
litigation. The republication of the demand letter’s contents to the media was not made in
connection with litigation. It is no different than providing the same statements in a different
format (not a demand letter) to unrelated parties who have no interest or involvement in the
contemplated litigation.

The Court finds that republishing the statements in the demand letter through transmission to the
media is not protected activity under the anti-SLAPP statute.

f. Conclusion

Because the Court finds that the statements are not protected activities subject to an anti-SLAPP
motion, the Court does not proceed to the second prong of the analysis for the Plaintiffs’
likelihood of prevailing on the merits.

Accordingly, the anti-SLAPP motion is hereby Denied.

II. PLAINTIFFS' MOTION FOR LEAVE TO TAKE LIMITED DISCOVERY

The PLAINTIFFS' MOTION FOR LEAVE TO TAKE LIMITED DISCOVERY filed by Gregor
Cameron, Amanda Ghost, Vince Holden on 10/29/2024 is Denied.

The Plaintiffs seek leave to conduct a brief, limited-scope deposition of Wilson to enable them to
fully respond to the anti-SLAPP motion.

The Court denies the anti-SLAPP motion, so the Motion for Limited Discovery is therefore
Denied as moot.

Clerk is to give notice.

Minute Order Page 8 of 9
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 48

24STCV17314 November 21, 2024

AMANDA GHOST, AN INDIVIDUAL, et al. vs REBEL 8:30 AM
WILSON, AN INDIVIDUAL

Judge: Honorable Thomas D. Long CSR: Kathy Thibodeaux, #9858

Judicial Assistant: Emily Ma Reyes ERM: None
Courtroom Assistant: Roger E. Lomeli Deputy Sheriff: None

Certificate of Mailing is attached.

Minute Order Page 9 of 9