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Case 2024-01107 - Appellate Division - 1st Dept
Main Motion to Stop A+E Networks from airing Where is Wendy Williams March 2024
https://drive.google.com/file/d/17wNXGF4ywsigdVIWe8hChwrs3Bx1KscU/view?usp=sharing
Affidavit of attorney conservator guardian Sabrina Morrissey March 2024
https://drive.google.com/file/d/11C0MIa-h-Zn_QsOdQv0j6rBsZBmfwKs0/view?usp=sharing
Short Caption: Sabrina Morrissey v. A&E Television Networks, LLC et al Case Type in Court of Original Instance: Civil Action - General
New York Supreme Civil Index Number: 650893/2024
Sabrina Morrissey , acting in her capacity as Temporary Guardian of W.W.H. v. A&E Television Networks, Llc, Entertainment One Reality Productions, Llc
Information from Court of Original Instance
Index/Court: 650893/2024 - New York Supreme Civil Judge: Margaret A. Chan Order Appealing From Date: 02/22/2024 Notice of Appeal Date: 02/23/2024 Order Entered Date: 02/22/2024 Notice of Appeal Filed Date: 02/23/2024
Petitioners
Name Represented By
Sabrina Morrissey , acting in her capacity as Temporary Guardian of W.W.H., Respondent HOLLOMAN, ELLEN V on 02/24/2024
Cadwalader, Wickersham & Taft LLP
DEVEREUX, AMANDA LYNN on 02/24/2024
CADWALADER, WICKERSHAM & TAFT LLPRespondents
Name Represented By
A&E Television Networks, LLC , Defendant-Appellant STROM, RACHEL F on 02/23/2024
Davis Wright Tremaine LLP
EVERDELL, ABIGAIL BAIN on 02/23/2024
DAVIS WRIGHT TREMAINE LLP
MAZUREK, CARL ANTON ROSEBUSH on 02/23/2024
Davis Wright Tremaine
Entertainment One Reality Productions, LLC , Defendant-Appellant STROM, RACHEL F on 02/23/2024
Davis Wright Tremaine LLP
EVERDELL, ABIGAIL BAIN on 02/23/2024
DAVIS WRIGHT TREMAINE LLP
MAZUREK, CARL ANTON ROSEBUSH on 02/23/2024
Davis Wright Tremaine
Document List
Documents
Agreement for project
https://iapps.courts.state.ny.us/nyscef/ViewDocument?docIndex=8ySjJvZxDLEhM3Ywtz6Rhw==
Order to seal
https://iapps.courts.state.ny.us/nyscef/ViewDocument?docIndex=8L5tDeBSxCGi1Ivtpnoi4Q==
Letter to court about sealed documents
https://iapps.courts.state.ny.us/nyscef/ViewDocument?docIndex=cdbwUD1qzIiT7ni0LFLvpg==
Proposed order to temporary restraint A E
https://iapps.courts.state.ny.us/nyscef/ViewDocument?docIndex=230NHMvN7p3KCCi5nhq1kA==
Motion Order on Document Seal
https://iapps.courts.state.ny.us/nyscef/ViewDocument?docIndex=4VSHVWaPGh2vSaGOxbTpmA==
1 COPY OF NOTICE OF APPEAL WITH PROOF OF FILING / INFORMATIONAL STATEMENT / ORDER OR JDMT APPEALED FROM
Sealed Strom, R.
Filed: 02/23/2024
Received: 02/23/2024 Processed
2 COPY OF SEALING ORDER -
Sealed Strom, R.
Received: 02/23/2024 Processed
3 APPLICATION FOR INTERIM RELIEF W/SUPPORTING DOCUMENTS INCLUDING EXHIBIT(S) (Motion #946)
Sealed Strom, R.
Filed: 02/23/2024
Received: 02/23/2024 Processed
4 COPY OF SEALING ORDER (M) (Motion #946)
Sealed Strom, R.
Filed: 02/23/2024
Received: 02/23/2024 Processed
5 ORDER (Motion #946)
Sealed Court User
Filed: 02/23/2024
Received: 02/23/2024 Processed
1 SUMMONS + COMPLAINT *Corrected*
Sealed Holloman, E.
Filed: 02/21/2024
Received: 02/28/2024 Processed
2 LETTER / CORRESPONDENCE TO JUDGE
Letter from E. Holloman to Judge Chan re. Motion to Seal Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
Confirmation Notice
3 EXHIBIT(S) - A
On-Camera Talent Agreement Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
Confirmation Notice
4 ORDER TO SHOW CAUSE - ACCOMPANYING COMMENCEMENT DOC(S) (PROPOSED) (Motion #001)
Plaintiff's OSC to Seal Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
Confirmation Notice
5 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF PROPOSED OSC/EXPARTE APP (Motion #001)
Sealed Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
6 EXHIBIT(S) - A (Motion #001)
Sealed Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
7 MEMORANDUM OF LAW IN SUPPORT (Motion #001)
Sealed Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
8 RJI -RE: OTHER (Motion #001)
Sealed Holloman, E.
Filed: 02/21/2024
Received: 02/26/2024 Processed
9 ADDENDUM - COMMERCIAL DIVISION (840C) (Motion #001) Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
Confirmation Notice
10 ORDER TO SHOW CAUSE ( PROPOSED ) (Motion #002)
Plaintiff's OSC for Injunctive Relief and TRO Holloman, E.
Filed: 02/21/2024
Received: 02/26/2024 *** Pending ***
Confirmation Notice
11 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF PROPOSED OSC/EXPARTE APP (Motion #002)
Sealed Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
12 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF PROPOSED OSC/EXPARTE APP (Motion #002)
Sealed Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
13 EXHIBIT(S) - A (Motion #002)
Sealed Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
14 EXHIBIT(S) - B (Motion #002)
Sealed Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
15 EXHIBIT(S) - C (Motion #002)
On-Camera Talent Agreement Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
Confirmation Notice
16 EXHIBIT(S) - D (Motion #002)
USB Flash Drive Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
Confirmation Notice
17 EXHIBIT(S) - E (Motion #002)
Transcription Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
Confirmation Notice
18 MEMORANDUM OF LAW IN SUPPORT (Motion #002)
Sealed Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
19 NOTICE OF APPEARANCE (POST RJI)
Notice of Appearance of Ellen V. Holloman Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
Confirmation Notice
20 NOTICE OF APPEARANCE (POST RJI)
Notice of Appearance of Amanda L. Devereux Devereux, A.
Filed: 02/26/2024
Received: 02/26/2024 Processed
Confirmation Notice
21 NOTICE OF HARD COPY EXHIBIT FILING
Notice of Hard Copy Submission Holloman, E.
Filed: 02/26/2024
Received: 02/26/2024 Processed
Confirmation Notice
22 LETTER / CORRESPONDENCE TO JUDGE (Motion #001)
Letter in Opposition to Order to Show Cause to Seal Strom, R.
Filed: 02/27/2024
Received: 02/27/2024 Processed
Confirmation Notice
23 EXHIBIT(S) - A (Motion #001)
Sealed Strom, R.
Filed: 02/27/2024
Received: 02/27/2024 Processed
24 EXHIBIT(S) - B (Motion #001)
Appellate Division Order Strom, R.
Filed: 02/27/2024
Received: 02/27/2024 Processed
Confirmation Notice
25 DISCLOSURE STATEMENT Strom, R.
Filed: 02/27/2024
Received: 02/27/2024 Processed
Confirmation Notice
26 ORDER - OTHER (NON-MOTION) Court User
Filed: 02/28/2024
Received: 02/28/2024 Processed
Confirmation Notice
27 STIPULATION - OTHER - ( REQUEST TO SO ORDER )
Joint Stipulation Regarding Pending Motion to Seal, dated 3/8/2024 Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 *** Pending ***
Confirmation Notice
28 EXHIBIT(S) - 1
Sealed Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
29 EXHIBIT(S) - 2
Verified Complaint - Redacted (Dkt. 1) Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
Confirmation Notice
30 EXHIBIT(S) - 3
Sealed Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
31 EXHIBIT(S) - 4
Holloman Aff. in Support of Motion to Seal - Redacted (Dkt. 5) Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
Confirmation Notice
32 EXHIBIT(S) - 5
Sealed Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
33 EXHIBIT(S) - 6
Memo of Law in Support of Motion to Seal Redacted (Dkt. 7) Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
Confirmation Notice
34 EXHIBIT(S) - 7
Sealed Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
35 EXHIBIT(S) - 8
Request for Judicial Intervention - Redacted (Dkt. 8) Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
Confirmation Notice
36 EXHIBIT(S) - 9
Sealed Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
37 EXHIBIT(S) - 10
Holloman Aff. Pursuant to Rule 202.7(f) - Redacted (Dkt. 11) Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
Confirmation Notice
38 EXHIBIT(S) - 11
Sealed Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
39 EXHIBIT(S) - 12
Morrissey Aff. - Redacted (Dkt. 12) Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
Confirmation Notice
40 EXHIBIT(S) - 13
Sealed Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
41 EXHIBIT(S) - 14
Memo of Law in Support of TRO - Redacted (Dkt. 18) Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
Confirmation Notice
42 EXHIBIT(S) - 15
Sealed Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
43 EXHIBIT(S) - 16
Ex. A to Strom Ltr. - Email dated Feb. 22, 2024 - Redacted (Dkt. 23) Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
Confirmation Notice
44 LETTER / CORRESPONDENCE TO JUDGE
Letter to Judge Chan from E. Holloman dated 3/8/2024 re. Request to File a Corrected Version of the ... show more Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
Confirmation Notice
45 EXHIBIT(S) - 1
Sealed Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
46 EXHIBIT(S) - 2
Sealed Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
47 EXHIBIT(S) - 3
Corrected version of Memo of Law - Redacted Holloman, E.
Filed: 03/08/2024
Received: 03/08/2024 Processed
Confirmation Notice
48 DECISION + ORDER ON MOTION (Motion #001) Court User
Filed: 03/14/2024
Received: 03/11/2024 Processed
Confirmation Notice
49 NOTIFICATION OF ORDER EXTENDING RESTRICTION *Corrected*
Plaintiff's Notification of Order Extending Restriction dated 3/12/2024 Holloman, E.
Filed: 03/12/2024
Received: 03/14/2024 Processed
Confirmation Notice
TEXT FROM MAIN MOTION LINKED ABOVE
FILED UNDER SEAL
1
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
SABRINA E. MORRISSEY, ESQ., acting in her capacity as
Temporary Guardian of W.W.H.,
Plaintiff,
-againstA&E TELEVISION NETWORKS, LLC and
ENTERTAINMENT ONE REALITY PRODUCTIONS, LLC
Defendants.
Index No. 650893/2024
VERIFIED COMPLAINT
FOR INJUNCTIVE RELIEF
Sabrina Morrissey, Esq., acting in her capacity as Temporary Guardian of W.W.H., files
this Complaint for injunctive relief against Defendants A&E Television Networks, LLC (ìA&E
Networksî) and Entertainment One Reality Productions, LLC (ìEntertainment Oneî), and, upon
personal knowledge as to her own conduct and upon information and belief with respect to the
conduct of others, alleges the following:
NATURE OF THE ACTION
1. W.W.H. is a prominent and accomplished individual who has earned her status as
an icon in the African American community and beyond through her highly successful multimedia
career over the past three decades. Unfortunately, in recent years, serious medical issues have
severely diminished W.W.H.ís capacity to maintain her personal and business affairs, necessitating
guardianship proceedings.
2.
FILED: NEW YORK COUNTY CLERK 03/08/2024 05:31 PM INDEX NO. 650893/2024
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 03/08/2024
FILED UNDER SEAL
2
3. In May 2023, W.W.H. was finally diagnosed by doctors at Weill Cornell Medical
Center with frontotemporal lobe dementia and progressive aphasia.
4. On February 2, 2024, Defendants A&E Television Networks, LLC (ìA&E
Networksî) and Entertainment One Reality Productions, LLC (ìEntertainment Oneî) released
a trailer of a purported documentary entitled ìWhere is Wendy Williams?î on its website (the
ìTrailerî),1
and announced that the full documentary will be aired by Lifetime Networks (which
is owned by Defendant A&E Networks) in two parts on February 24-25, 2024. The Trailer, which
appears to contain privately-shot footage of W.W.H. in an obviously disabled state, shamelessly
exploits W.W.H. and portrays her in an extremely demeaning and undignified manner, incorrectly
states that W.W.H. is ìbroke,î and cruelly implies that W.W.Hís disoriented demeanor is due to
substance abuse and intoxication. The Trailer has been disseminated and discussed on YouTube
and other social media platforms by multiple gossip vloggers and other users, where it has been
watched and commented on by hundreds of thousands if not millions of people. The Trailer has
been viewed on Lifetime Networksí official YouTube channel over 725,000 times.2
5. It is readily apparent that the complete promised documentary would even further
portray W.W.H. in a humiliating and demeaning manner, unconscionably exploiting W.W.H.ís
condition, and perhaps even disclosing her personal and private medical diagnosis, for perceived
1
See Re: Lifetime Announces A Two-Night Documentary Event ìWhere is Wendy
Williams?î, A+E Networks, https://www.aenetworks.com/article/re-lifetime-announces-a-twonight-documentary-event-where-is-wendy-williams (last visited Feb. 20, 2024). Error! Hyperlink
reference not valid.
2
See Lifetime, Where is Wendy Williams? Official Trailer, YouTube (Feb. 2, 2024),
https://www.youtube.com/watch?v=OjJDhf5ll70 (last visited Feb. 20, 2024)..
FILED: NEW YORK COUNTY CLERK 03/08/2024 05:31 PM INDEX NO. 650893/2024
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 03/08/2024
FILED UNDER SEAL
3
ìentertainment valueî and the prurient interest of television viewers. This blatant exploitation of
a vulnerable woman with a serious medical condition who is beloved by millions within and
outside of the African American community is disgusting, and it cannot be allowed.
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