From: martinottmann@yahoo.com (Martin Ottmann)

Subject: Declaration of Chad Slater aka Kylie Bradford - September 13th, 2001

Date: 16 Jan 2003 03:56:06 -0800

Message-ID: <71d327bb.0301160356.6f1a8353@posting.google.com>


I, Chad Slater declare:

1. I am an indivdual residing in Los Angeles and have used the alias
Kyle Bradford in certain professional acting endeavors. I am named as
a defendant in this lawsuit. The facts set forth in this declaration
are personally known to me and I have first-hand knowledge thereof. If
called as a witness, I could and would testify competently to those
facts under oath.

2. On or about May 3, 2001, I heard on a news report that I was being
sued for defamation by Tom Cruise. I was subsequently served with a
copy of that lawsuit. The lawsuit arises out of a false and defamatory
article written by a Spanish-language magazine named "TV y NOVELAS"
which falsely stated that I had given an interview to a French website
and had said that I had a homosexual affair with Tom Cruise. mr.
Cruise sue me believing that I was spreading this false story.

3. The article written by TV y NOVELAS is completely and utterly
false. I have never met Mr. Cruise, and have never had a homosexual
affair with him. I have never told anyone that I had an affair with
Mr. Cruise. moreover, I have never been to France, and I have never
given an interview to a French website.

4. Shortly after the lawsuit was filed, I became aware that my
estranged wife, Kristina Ann Kristin, was going to sell an interview
to the National Enquirer in which she was going to falsely stat that I
had told her on numerous occasions that I had an affair with Mr.
Cruise. I immediately called Ms. Kristin and asked her why she would
lie to the National Enquirer in this manner. I told Kristin that I had
never met Mr. Cruise and that she should not lie to the Enquirer. Ms.
Kristin told me she was desperate for money and that the National
Enquirer was going to pay her for her story. Ms. Kristin stated that
she was willing to lie because she needed the money that the National
Enquirer was going to pay her.

5. I never told Ms. Kristin that I had an affair with Mr. Cruise.
Indeed, I have never said that to anyone. No such affair ever
happened, and anyone who claims to the contrary is lying.

6. Ms. Kristin has a history of selling stories to tabloid
publications for large amounts of money. While we were married, Ms.
Kristin sold a story to a British Newspaper called "The People" in
which she claimed to have had an affair with another celebrity. on
that occasion, Ms. Kristin received $ 30,000 for her story.

I declare under penalty of perjury under the laws of the State of
California that the foregoing is true and correct.

Executed on September 13, 2001, at Los Angeles, California.

[Signature]
CHAD SLATER

From: martinottmann@yahoo.com (Martin Ottmann)

Subject: Re: Declaration of Chad Slater aka Kylie Bradford - September 13th, 2001

Date: 16 Jan 2003 14:02:26 -0800

Message-ID: <71d327bb.0301161402.24c5911f@posting.google.com>


martinottmann@yahoo.com (Martin Ottmann) wrote in message news:<71d327bb.0301160356.6f1a8353@posting.google.com>...

> I, Chad Slater declare:

> 

> 1. I am an indivdual residing in Los Angeles and have used the alias

> Kyle Bradford in certain professional acting endeavors. I am named as

> a defendant in this lawsuit. The facts set forth in this declaration

> are personally known to me and I have first-hand knowledge thereof. If

> called as a witness, I could and would testify competently to those

> facts under oath.


[...]

Here is the case docket:

Case Number: BC249690
TOM CRUISE VS CHAD SLATER

Filing Date: 05/02/2001
Case Type: Defamation (Slander/Libel) (General Jurisdiction)
Status: Default Judgment Pursuant to Decl. 12/20/2002

Future Hearings:
None

Parties:

BRADFORD KYLE - Defendant

CRUISE TOM - Plaintiff

GREENBERG GLUSKER FIELDS - Attorney for Pltf/Petnr

KESTER & ISENBERG - Attorney for Defendant/Respondent

KIRSTIN KRISTINA ANN - Defendant/Respondent

SLATER CHAD - Defendant

Documents Filed (Filing dates listed in descending order):

12/20/2002 Partial Dismissal(not entire case) (W/O PRJ AS TO DOES 2 TO
10 ONLY )
Filed by Attorney for Plaintiff/Petitioner

12/20/2002 Request to Enter Judgment
Filed by Attorney for Plaintiff/Petitioner

12/20/2002 Statement of Case (BRIEF STATEMENT OF THE CASE IN SUPP OF
DEFAULT JUDGMENT )
Filed by Attorney for Plaintiff/Petitioner

12/20/2002 Declaration (DEC OF TOM CRUISE IN SUPP OF REQ FOR ENTRY OF
JUDGMENT ON DEFAULT )
Filed by Attorney for Plaintiff/Petitioner

12/19/2002 Declaration (of ricardo p.cestero in supp of default
judgment )
Filed by Attorney for Plaintiff/Petitioner

09/23/2002 Remittitur (DISMISSED APPEAL FILED 2-5-02 IS DISMISSED S/T
RECORDS 9-24-02 )
Filed by Clerk

07/17/2002 Ord (DCA) Dismissing Appeal
Filed by Clerk

03/08/2002 Points and Authorities (of plntf re osc for failure to
proceed with default judgment against deft )
Filed by Attorney for Plaintiff/Petitioner

02/07/2002 Ntc to Atty re Notice of Appeal
Filed by Clerk

02/05/2002 Notice of Appeal (NOTICE TO PREPARE REPORTERS ELECTION TO
PROCEED 5.1 )
Filed by Plaintiff

12/31/2001 Memorandum of Costs
Filed by Defendant

12/11/2001 Order (BY DEFT: KRISTINA ANN KIRSTIN STRIKING PLFF'S FIRST
AMD COMPLT & DISMISSING KIRSTI W/PRJ FROM THIS ACTION )
Filed by Attorney for Defendant/Respondent

12/06/2001 Statement of Decision
Filed by Attorney for Plaintiff/Petitioner

12/05/2001 Objection Document
Filed by Attorney for Deft/Respnt

11/30/2001 Objection Document (TO (PROPOSED) STATEMENT OF DECISION
SUBMITTED BY DEFT. )
Filed by Attorney for Plaintiff/Petitioner

11/27/2001 Notice of Continuance
Filed by Clerk

10/15/2001 Notice (OF ERRATA RE: PLAINTIFF'S SURREPLY IN OPP TO
KRISTINA ANN KIRSTIN'S SPECIAL MOTION TO STRIKE )
Filed by Attorney for Plaintiff/Petitioner

10/12/2001 Miscellaneous-Other (RESP. TO PLAINTIFF'S SURREPLY TO
SPECIAL MOTION TO STRIKE FIRST AMENDED COMPLAINT )
Filed by Attorney for Defendant/Respondent

10/09/2001 Opposition Document (SURREPLY TO KRISTIN ANN SPECIAL MOTION
TO STRIKE )
Filed by Attorney for Plaintiff/Petitioner

09/21/2001 Reply to Motion
Filed by Attorney for Deft/Respnt

09/14/2001 Declaration
Filed by Attorney for Pltf/Petnr

09/14/2001 Miscellaneous-Other (PLFF'S APPENDIX OF NON-CAL AUTHORITIES
IN SUPP OF OPP TO SPECIAL MOTION TO STRIKE FIRST AMENDED COMPLAINT )
Filed by Attorney for Plaintiff/Petitioner

09/14/2001 Points and Authorities
Filed by Attorney for Pltf/Petnr

09/05/2001 Miscellaneous-Other (Appendix Of NOn California Authorities
Cited )
Filed by Attorney for Defendant/Respondent

09/05/2001 Declaration
Filed by Attorney for Defendant/Respondent

09/05/2001 Declaration
Filed by Attorney for Defendant/Respondent

09/05/2001 Declaration
Filed by Attorney for Defendant/Respondent

09/05/2001 Motion to Strike
Filed by Attorney for Defendant/Respondent

08/31/2001 Proof of Service (by mail )
Filed by Attorney for Plaintiff/Petitioner

08/21/2001 Default Entered (against Chad Slater aka Kyle Bradford )
Filed by Attorney for Pltf/Petnr

08/08/2001 Answer to First Amended Complaint
Filed by Attorney for Defendant/Respondent

07/31/2001 Proof of Service (summons first amended complaint; first
amended complaint )
Filed by Attorney for Plaintiff/Petitioner

07/31/2001 Proof of Service (summons on first amended complaint first
amended complaint )
Filed by Attorney for Plaintiff/Petitioner

06/18/2001 First Amended Complaint
Filed by Attorney for Plaintiff/Petitioner

06/18/2001 Summons Issued
Filed by Attorney for Plaintiff/Petitioner

06/12/2001 Notice of Status Conference filed

05/14/2001 Amendment to Complaint (Doe 1 to be Kristina Ann Kirstin )
Filed by Attorney for Plaintiff/Petitioner

05/02/2001 Complaint

Proceedings Held (Proceeding dates listed in descending order):

12/20/2002 at 01:30 pm in department 47, Aurelio Munoz, Presiding
Ruling on Submitted Matter - Granted

12/19/2002 at 08:35 am in department 47, Aurelio Munoz, Presiding
Order to Show Cause (CONFIRM DEFAULT JUDGMENT) - OSC Discharged

12/11/2002 at 08:35 am in department 47, Aurelio Munoz, Presiding
Order to Show Cause (RE CONFIRM DEFAULT JUDGMENT) - Proceeding
continued

09/11/2002 at 08:30 am in department 47, Aurelio Munoz, Presiding
Non-Appearance (Case Review) - Completed

03/13/2002 at 08:35 am in department 47, Aurelio Munoz, Presiding
Order to Show Cause (RE DEFAULT JUDGMENT AS TO SLATER) - OSC
Discharged

12/13/2001 at 08:31 am in department 47, Aurelio Munoz, Presiding
Further Status Conference (**CONT. FROM 12/4/01 PER C.O.M.**) - Matter
is heard, matter continued

12/07/2001 at 08:30 am in department 47, Aurelio Munoz, Presiding
Non-Appearance (Case Review) - Court makes order

11/07/2001 at 02:30 pm in department 47, Aurelio Munoz, Presiding
Court Order - Completed

10/17/2001 at 08:30 am in department 47, Aurelio Munoz, Presiding
Motion to Strike (SPECIAL MOTION(CONT FROM 9/26/01)) - Granted

09/26/2001 at 08:30 am in department 47, Aurelio Munoz, Presiding
Motion to Strike (SPECIAL) - Proceeding continued

08/29/2001 at 08:31 am in department 47, Aurelio Munoz, Presiding
Initial Status Conference - Matter is heard, matter continued