SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK 

SEAN PENN, an individual,
Index No. 159710/2015

Plaintiff,

- against 

DECLARATION OF
MADONNA LOUISE CICCONE

LEE DANIELS, an individual, and
JOHN DOES 1-100,

Defendants.


STATE OF NEW YORK 

ss.:
COUNTY OF NEW YORK 

MADONNA LOUISE CICCONE, declares, under penalty of perjury, the following:

1. I am a singer, songwriter, producer, actress, businesswoman, and philanthropist. I
currently reside in the State of New York. From approximately August, 1985 through
September, 1989, I was married to Sean Penn, the plaintiff in the above-captioned action. I make
this Declaration based on my personal knowledge of events that occurred both during and
subsequent to our marriage and would testify to such at deposition.

2. I have known Sean Penn for over thirty years. Over the decades, I have known
Scan to be a caring, compassionate individual, as well as an extremely talented actor, creative

artist, and philanthropist, including in connection with his work as CEO of the Haitian Relief

Organization.

 

3. I am aware of the allegations that have surfaced over the years accusing Sean of
incidents of physical assault and abuse against me. Speci?cally, I am aware of the allegations
concerning an alleged incident that occurred in June, 1987, whereby (according to tabloid
reports), Sean allegedly struck me with ?a baseball bat.? I know the allegations in those and
other reports to be completely outrageous, malicious, reckless, and false.

4. I am also aware of allegations concerning an incident that occurred in December,
1989, which purportedly resulted in Sean?s arrest for domestic assault and battery against me. I
know those allegations to be false. While we certainly had more than one heated argument
during our marriage, Sean has never struck me, ?tied me up,? or physically assaulted me, and any
report to the contrary is completely outrageous, malicious, reckless, and false.

Dated: New York, New York
October 1 2015



MADONNA ISE CICCONE