5. While at first I knew Mr. Warner did not do these things to me, I eventually I began to question whether he actually did. On numerous occasions, I was told by Ms. Wood, Esme Bianco and others that these things happened to Ms. Wood and Ms. Bianco; asked whether the same things happened to me; and told that I may just be misremembering what happened, repressing my memories of what happened, or that my memories had not yet surfaced—which they said happened to people against whom these acts were perpetrated. I was asked whether I was repressing memories to just get through day-to-day life, and whether it was easier just to not think about what actually happened than accept reality. They also said it was important for people to come forward so that no one else gets hurt.
6. I also recall that in one of the group meetings I attended with Ms. Wood and Ms. Gore, Ms. Gore said they could arrange security for anyone who felt in danger from Mr. Warner. I recall that Ms. Bianco said during this discussion that private investigators had been parked outside of her house and probably were parked outside of mine. I also had separate conversations with Ms. Bianco during this time period in which she told me her relationship with Mr. Warner was similar to that described by Ms. Wood. She insisted that I was repressing memories like she and other supposed victims of Mr. Warner had done.
7. Eventually, I started to believe that what I was repeatedly told happened to Ms. Wood and Ms. Bianco also happened to me.
8. In or around January 2021, I attended a call on which Ms. Wood said that on a certain day she would post to her social media naming Mr. Warner as her abuser, and that we all should do the same on or around the same day. I discussed with Ms. Gore making such a statement on my Instagram page accusing Mr. Warner of abuse. Ms. Gore drafted the statement, and I gave her my password to post it. The narrative ultimately posted to my account on or around February 1, 2021 contained untrue statements about Mr. Warner, including that there was violence and non-consensual sexual activity in our brief relationship, and that I had repressed memories of the same. As another example, there was no branding or cutting experienced during the brief relationship and certainly no “Marilyn Manson” initials carved on my body.
9. On June 29, 2021, a complaint was filed in the lawsuit Ashley Lindsay Morgan Smithline v. Brian Warner et al., Case No. 2:21-cv-5289. The complaint was filed by my attorney at the time, Jay Ellwanger. Ms. Bianco told me Mr. Ellwanger was her lawyer and that I should use him. Mr. Ellwanger did not review the contents of the complaint with me before filing it and did not send me a draft of the complaint to approve before filing it. The complaint contained untrue statements about Mr. Warner, including that there was violence and non-consensual sexual activity in our brief relationship, and that I had repressed memories of the same until meeting with Ms. Wood, Ms. Gore, and others in 2020. Leading up to the filing of the complaint, I felt pressured by Mr. Ellwanger to go on a press tour, which included an interview on The View and an interview and photoshoot with People magazine. I was very uncomfortable doing this press but felt pressured to do it.
10. After the lawsuit was filed on my behalf, I fired Mr. Ellwanger, and the case was dismissed. I never received any money from Mr. Warner and am not seeking any money from him. I have no intention of refiling any lawsuit against Mr. Warner.
11. I never intended to pursue criminal charges against Mr. Warner and have no intention now of ever pursuing criminal charges, as Mr. Warner did not ever assault or abuse me.
12. Looking back, I feel I was manipulated by Ms. Wood, Ms. Gore, Ms. Bianco, and Mr. Ellwanger to spread publicly false accusations of abuse against Mr. Warner.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
If you or someone you know has been affected by sexual assault, we encourage you to reach out for support:
RAINN National Sexual Assault Hotline
http://www.rainn.org
1 800 656 HOPE (4673)
Crisis Text Line
SMS: Text “HELLO” or “HOLA” to 741-741
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