Peter R. Afrasiabi (Bar No. 193336) pafrasiabi@onellp.com John Tehranian (Bar No. 211616) jtehranian@onellp.com ONE LLP 4000 MacArthur Blvd. East Tower, Suite 500 Newport Beach, CA 92660 Telephone: (949) 502-2870 Facsimile: (949) 258-5081 Attorneys for Defendant, JEREMY SCOTT ase Document 13-2 Filed 10/29/15 Page 1 of 5 Page ID #:67 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION JOSEPH TIERNEY, professionally known as ?Rime,? an individual; Plaintiff, v. MOSCHINO S.P.A., an Italian corporation; JEREMY SCOTT, an individual; and DOES 1-10 inclusive. Defendants. Case No. 2: (PJWX) Hon. Stephen V. Wilson DECLARATION OF JEREMY SCOTT IN SUPPORT OF DEFENDANT JEREMY MOTION TO STRIKE COMPLAINT PURSUANT TO CAL. CIV. PROC. CODE 425.16 Date: December 7, 2015 Time: 1:30 pm. Courtroom: 6 2nd Floor SCOTT DECLARATION ISO MOTION TO STRIKE COMPLAINT PURSUANT TO C.C.P. 425.16 Case 2:15-cv-05900-SVW-PJW Document 13-2 Filed 10/29/15 Page 2 of 5 Page ID #:68 Vogue Bazaar Harper’s ase Document 13-2 Filed 10/29/15 Page 3 of 5 Page ID #:69 5. For example, my rendition of an evening gown for the opera-attending beau monde (a true and correct copy of which is featured below) features a print replete with nutritional content information and graphics as if the gown were a giant bag of junk food. This tongue-in-cheek riff on Brahmin formal wear is not merely clothing; it highlights the disposable nature of fashion and speaks to the potentially dichotomous nature of inner and outer beauty and the waist/waste and excess of consumer culture. 6. In another example, my particular rendition of military headgear (a true and correct copy of which is featured below), which singer Rihanna famously wore in her 2 SCOTT DECLARATION ISO MOTION TO STRIKE COMPLAINT PURSUANT TO C.C.P. 425.16 ase Document 13-2 Filed 10/29/15 Page 4 of 5 Page ID #:70 music video Hard, features helmets with large disc ears that are evocative of Mickey Mouse, thereby communicating the inherently puerile nature of war. VII 7. For the works at issue in the instant case, as the Creative Director at Moschino, I came up with a concept for a dress to be worn at the celebrated Met Gala and a graffiti-based collection that subverted the seriousness of traditional black-tie fashion while also commenting on the way in which society obj ectifies women by literally imposing cultural symbols and meaning upon them. I used the medium of graffiti, and the way in which street artists impose cultural symbols and meaning upon the vernacular landscape, to create a metaphor of a sophisticated woman literally tagged with graffiti, much like any light pole, brick wall or mail box on the street corner. 3 SCOTT DECLARATION ISO MOTION TO STRIKE COMPLAINT PURSUANT TO C.C.P. 425.16 Case 2:15-cv-05900-SVW-PJW Document 13-2 Filed 10/29/15 Page 5 of 5 Page ID #:71 8. 1 Although I had the idea of doing a graffiti-based collection, I did not design 2 the actual print on the dress and suit at issue in this suit and I did not design the RIME 3 graphics on two items reproduced in the Plaintiffs Complaint, 12. Those graphic were 4 selected and created by a graphic artist at Moschino completely independently of me. 9. 5 I have been fortunate enough to receive significant accolades for the 6 expressive vision of my work. For example, in the past year, I was the subject of a feature- ? length documentary, Jeremy Scott: The People 's Designer, which focuses on my life's 8 work and its artistry and includes interviews with numerous celebrities whom I regularly 9 dress and design for, including Rihanna, Miley Cyrus, Madonna, Paris Hilton, Katy Perry, 1O Jared Leto, Lady Gaga and others; noted Italian publisher Rizzoli published the definitive 11 retrospective on my work, Jeremy Scott (and, as The New York Post noted in its review, 12 "[£]lipping through the colorful pages, his subversive humor and ability to comment on 13 culture through clothes comes through loud and clear"); and, I designed the costumes for 14 Katy Perry's celebrated Super Bowl XLIX halftime show, which was one of the most- 15 watched television events in history. 16 10. I feel blessed to be able to do something I love for a living. Fashion has a 17 unique ability to communicate who we are at any given time in history and what we are 18 feeling as a society. As an inherently creative individual, the ability to design and create 19 fashion with an expressive message that I can share with the world lies at the core of my 20 being. 21 22 23 24 I declare under penalty of perjury under the laws of the United States of America that the foregoing is true ~ ~ t . Executed this · day of October, 2015, at Los Angeles, California. 25 26 27 28 4 SCOTT DECLARATION ISO MOTION TO STRIKE COMPLAINT PURSUANT TO C.C.P. § 425.16