Stephen Belafonte v. Melanie Janine Brown (Mel B - Scary Spice)

Case 1:24-cv-22045-XXXX Document 1 Entered on FLSD Docket 05/29/2024 Page 1 of 48
IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA
STEPHEN BELAFONTE,
Plaintiff,
v. Civil Action No. ____________________
MELANIE JANINE BROWN,
Defendant.
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
Plaintiff, STEPHEN BELAFONTE (“Mr. Belafonte” or “Plaintiff”), by and through his
undersigned counsel, hereby files this Complaint for Damages and Injunctive Relief against
Defendant MELANIE JANINE BROWN (“Mel B,” “Ms. Brown” or “Defendant”), and alleges
the following:
PRELIMINARY STATEMENT
1. This action arises from the total takedown of Plaintiff by his celebrity ex-wife Ms.
Brown (known as “Mel B” of the Spice Girls), who has spent the better part of the last decade
engaging in a deliberate and wide-ranging campaign to cause him severe emotional distress and
destroy his reputation. Ms. Brown has stopped at nothing to falsely charge Plaintiff with crimes
and horrific offenses, including physical beatings, rape, financial abuse, emotional abuse, sex
trafficking, and illegal gun possession.
2. The long-brewing harassment orchestrated by Ms. Brown began with a fraudulent
claim of domestic violence in 2017—which Ms. Brown dismissed shortly after filing but just
before Plaintiff and had his day in court. Despite claiming that “Mr. Belafonte would and could
hurt me and my children,” intending for such statements to be broadly disseminated to the
international gossip press, Ms. Brown soon dismissed her own baseless claims, gave Mr.
Belafonte primary custody of their minor child, and was forced to pay out over half a million
dollars.
3. Ms. Brown’s campaign of abuse has continued to the present day with the 2024
re-publication of her best-selling book about her marriage to Plaintiff, wherein Ms. Brown has
leveraged her thirty years of fame to attack Mr. Belafonte in a malicious and vindictive global
smear.
4. From lying to the courts and the public about Mr. Belafonte beating her, causing
a split lip and swollen face, to fabricating a jealous attack over the recording artist Usher during
filming as a judge on the reality competition series The X Factor, to incredible stories of Mr.
Belafonte cutting off her funds, leaving her with no credit cards, no internet, and only $936 in
her bank account, Ms. Brown has been profiting off of her public lies as she portrays Mr.
Belafonte as a “monster” on global television and media appearances and in her ironically-
named book with co-writer Louise Gannon: Brutally Honest: The Sunday Times Bestseller.
5. Defendant’s relentless attacks have been calculated to ensure maximum coverage
of her false narratives and exact maximum damage to Mr. Belafonte’s reputation and emotional
state, to say nothing about the effects on their biological daughter, whose primary custody was
tellingly awarded to Mr. Belafonte. In recent statements to the media, Defendant has told the
world, “I am telling the truth because Mr. Belafonte has never sued me.” After staying quiet
through years of continuous emotional attacks in order to protect his young daughter from a
drawn-out and public litigation, and suffering from humiliation and severe emotional distress
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while his ex-wife did everything she could to destroy him, Mr. Belafonte is left with no choice
but to stand up for himself, and expose “Mel B’s” lies to the Court and the world.
STATEMENT OF CASE
6. Following a ten-year, tumultuous marriage, during which Ms. Brown repeatedly
harassed and mistreated Mr. Belafonte, Ms. Brown filed for divorce. Ms. Brown exploited the
divorce proceedings to abuse and harass Mr. Belafonte, including by depriving him of access to
his daughter for several months and having him removed from his home. Ms. Brown’s vexatious
litigation of the couple’s divorce left Mr. Belafonte with no choice but to defend himself against
the numerous false charges Ms. Brown brought against him, so that he could gain custody of and
maintain a good relationship with his daughter, “M.B.”
7. Notwithstanding Ms. Brown’s efforts to brand Mr. Belafonte a violent spouse and
unfit father—labeling him as a “monster” and an “abuser”—Mr. Belafonte has had primary
custody of M.B. since 2019. During this time, Ms. Brown has barely maintained a relationship
with M.B.—visiting her in the United States only once during the past four years, even though
she has flown to the United States, for work-related appearances and tapings, on multiple
occasions to appear on, inter alia, “America’s Got Talent” in Los Angeles, talk shows in New
York City, and a television show in Utah. Moreover, Ms. Brown frequently rejects to practice the
daily, court-ordered telephone calls to M.B. for multiple days at a time, having accepted only
fifteen of M.B.’s thirty phone calls in the past month. Attached as Exhibit 1 is a Message Report
from Our Family Wizard (the couple’s co-parenting app) showing Ms. Brown’s frequent
rejection of M.B.’s phone calls.
8. In 2017, Ms. Brown withdrew the temporary restraining order against Mr.
Belafonte in the family court proceedings after it became clear that she had no evidence to
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support her false allegations against him and more importantly, after Mr. Belafonte came forward
with documentary and other evidence showing the falsity of her allegations. Nevertheless, the
damage had been done. As a result of Ms. Brown’s false allegations of rape, illegal gun
possession, sex trafficking, production of illegal pornography, domestic battery, and child
endangerment, Mr. Belafonte lost access to his home and children. Further, Mr. Belafonte was
treated like a criminal and subjected to a raid of his home conducted by the Federal Bureau of
Investigation (FBI), the Bureau of Alcohol, Tobacco, and Firearms (ATF), and local police.
Investigations by these bodies of law enforcement concluded in no criminal charges for Mr.
Belafonte.
9. Having abandoned her battle against Mr. Belafonte in family court, Ms. Brown
decided to spin a false narrative about Mr. Belafonte in the court of public opinion, knowing that
the public would be sympathetic toward her given her large fanbase and status as a famous,
internationally renowned celebrity. In contrast, Mr. Belafonte is not a public figure and does not
enjoy the same capability to control the public narrative about him.
10. Ms. Brown leveraged her celebrity status to portray herself as a domestic abuse
victim in order to market and sell a memoir laden with egregious lies. This has enabled Ms.
Brown to build herself a new career and enrich herself at the expense of Mr. Belafonte’s
reputation and emotional wellbeing. In private, however, Ms. Brown bluntly admits that “charity
doesn’t pay the bills,” and that her true intentions are to leverage her charitable appeal for further
sales, celebrity, and opportunity.1 Screenshots of text messages from Ms. Brown to fellow
1
Ms. Brown recently issued a public apology to fellow Spice Girls for ‘shutting the door’ on them and keeping her
distance from them during her marriage to Mr. Belafonte. See <https://sg.news.yahoo.com/mel-b-apologised-spice-
girls-160000351.html> Her public statements are contrary to her assertions disdaining a reunion for charity
fundraising, made in private to the Spice Girls with whom she was in regular contact throughout her marriage to Mr.
Belafonte.
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members of the Spice Girls are reproduced directly below, demonstrating Ms. Brown’s disdain
toward charity work:
11. Since reinventing herself as spokesperson for abuse victims, Ms. Brown has
turned her lies into a full-blown career as a charity ambassador for Women’s Aid, a UK-based
organization for women escaping domestic violence, and gained further celebrity from a book
written to profit from those lies.
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12. Upon information and belief, Ms. Brown is enriching herself through her charity
ambassadorship at Women’s Aid. More shockingly, Ms. Brown’s egregious lies about Mr.
Belafonte resulted in her appointment to the Most Excellent Order of the British Empire (MBE),
a British order of chivalry rewarding one’s contributions to, among other things, charitable and
welfare organizations.
13. When the cameras were off her, however, Ms. Brown waged a destructive
campaign of abuse of her own, reaching nearly everyone around Mr. Belafonte’s and their child’s
orbit. She called their daughter’s dentist in Los Angeles from the UK to falsely inform them of a
restraining order against Mr. Belafonte and that he physically abused her. Attached as Exhibit 2
is correspondence from M.B.’s dental office detailing Ms. Brown’s false statements resulting in
continued delay of M.B.’s dental care. She called the police to perform a so-called welfare check
on M.B. when M.B., Mr. Belafonte, and Mr. Belafonte’s sister all informed her that M.B. was
fine. She lodged false police reports claiming that M.B. had no bed to sleep on and no food to
eat in an effort to manipulate the child protection system.
14. Further, Ms. Brown did and continues to perpetuate and publicize the false
narrative of Mr. Belafonte as a violent and abusive man from 2018 until the present, through
incessant and relentless media appearances and interviews.
15. Specifically, in 2018, Defendant published false and defamatory statements
wrongfully accusing Mr. Belafonte of domestic violence, emotional abuse, and financial abuse,
in a Sunday Times bestselling autobiography titled Brutally Honest. The defamatory publications
were then republished in 2024 with three additional chapters to the book, as well as changes and
updates within the original chapters in an effort to cause even greater damage to Mr. Belafonte’s
reputation.
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16. From 2018 to the present, Ms. Brown has also published the same or similar false
and defamatory statements regarding Mr. Belafonte at numerous high-profile talk shows and
press interviews in the United States, including, among others, The View, The Tonight Show, The
Late Late Show, Today with Hoda & Jenna, and The Jennifer Hudson Show. Ms. Brown did so to
ensure that her false and defamatory statements would be published and republished in the
United States.
17. The wrongful publications of the defamatory statements by Defendant, which
portray Mr. Belafonte as a cruel, manipulative, and violent spouse, have severely harmed and
continue to harm Mr. Belafonte.
18. As a result of Defendant’s defamatory statements, Mr. Belafonte has received
hundreds of hate comments and messages on social media platforms, as well as threatening
messages from strangers that, on information and belief, are fans of Ms. Brown’s. A small
sampling of some of the hate messages received by Plaintiff is attached hereto as Exhibit 3.
Accordingly, the widespread publication of Defendant’s defamatory statements has not only
injured Mr. Belafonte’s mental health, but it has also endangered his and his daughter’s life.
19. Mr. Belafonte now brings this action to hold Defendant accountable for the
blatant lies and defamatory publications that she published, republished, and spread about Mr.
Belafonte to a worldwide audience. Mr. Belafonte also seeks damages and injunctive relief for
the severe emotional distress caused by Ms. Brown’s intentional and outrageous actions. Mr.
Belafonte seeks injunctive relief, corrective relief, and monetary damages.
THE PARTIES
20. Mr. Belafonte is an individual residing in Miami, Florida.
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21. Upon information and belief, Melanie Janine Brown is an individual residing in
Leeds, United Kingdom.
JURISDICTION AND VENUE
22. This Court has original subject matter jurisdiction pursuant to 28 U.S.C. § 1332.
As set forth above, Plaintiff’s state of citizenship (Florida) is diverse from Defendant’s state of
citizenship (United Kingdom), and the amount in controversy exceeds $75,000.00, exclusive of
interest, costs, and attorneys’ fees.
23. At the time of the publication of the defamatory statements and communications
set forth in this Complaint, Mr. Belafonte was a resident and citizen of the State of Florida. As a
direct result of Defendant’s false and defamatory statements published to the worldwide media,
Mr. Belafonte has been the subject of numerous derogatory news articles and sustained severe
reputational damage while a resident and citizen of Florida.
24. Further, at the time of publication of the defamatory statements and
communications set forth in this Complaint, Defendant was fully aware that Mr. Belafonte
resided in and was a citizen of Florida. Defendant intended and had actual knowledge that the
defamatory and damaging statements would be published in her book, Brutally Honest, and
disseminated in the worldwide media, including throughout Florida.
25. Ms. Brown also had actual knowledge that her defamatory and injurious
statements made in the numerous, widely promoted talk shows would be viewed by millions of
people throughout the world, including in the State of Florida.
26. Defendant’s false and malicious statements about the Plaintiff were accessible on
network television and the Internet in the state of Florida and were, in fact, accessed by third
parties in the State of Florida.
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27. Defendant willfully, purposefully, and intentionally directed her defamatory
statements at and target Mr. Belafonte, a Florida resident and citizen. Defendant acted with
actual malice and full knowledge that her statements were false and were intended to discredit
and destroy Mr. Belafonte’s reputation.
28. Defendant is subject to personal jurisdiction in the state of Florida pursuant to Fla.
Stat. 48.193(1)(a)(2), because she committed intentional tortious acts within the State of Florida.
29. Furthermore, Defendant has sufficient minimum due process contacts with
Florida because she intentionally published defamatory statements with the actual knowledge
and intent of causing maximum damage to Mr. Belafonte’s reputation in the state of Florida and
worldwide. By intentionally publishing false and defamatory statements about Mr. Belafonte
with actual knowledge and intent that the false and defamatory statements would be published
and disseminated in Florida, Defendant reasonably anticipated being haled into court in the state
of Florida. Thus, the exercise of personal jurisdiction over Defendant comports with traditional
notions of fair play and substantial justice.
30. Venue is proper in this judicial district under 28 U.S.C. § 1391(b)(2) because a
substantial part of the events giving rise to this action occurred in Miami-Dade County, Florida;
Mr. Belafonte resides and is domiciled in Miami-Dade County, Florida; and the damage to Mr.
Belafonte’s reputation occurred in Miami-Date County, Florida.
FACTS RELEVANT TO ALL CLAIMS
31. Mr. Belafonte is a film and television producer, director and talent manager.
32. Ms. Brown is one of five members of the world renowned, English girl group, the
Spice Girls. Formed in 1994, the Spice Girls are the best-selling girl group of all time,2 having
sold 100 million records worldwide and amassed a number of high-profile awards in the music
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industry, including three American Music Awards, four Billboard Music Awards, give Brit
Awards, three MTV Europe Music Awards, and one MTV Video Music Award.3
33. By 1998, the Spice Girls had grossed an estimated $500-800 million through an
abundance of endorsement deals and merchandise sales, as well as an additional $300 million in
music and video sales from just October 1997 to October 1998.4 The commercial success and fan
following garnered by the Spice Girls was largely unprecedented and often compared to
“Beatlemania,” the fanaticism surrounding the Beatles.
34. The Spice Girls continued to enjoy worldwide fame and commercial success over
the course of the following three decades. Following a hiatus from 2000 to 2007, the Spice Girls
reunited for a worldwide tour, the Return of the Spice Girls, which was the highest-grossing
concert tour in 2007-2008, producing $107.2 million in ticket sales and merchandising and $200
million in sponsorship and advertisement deals. Four of the five reunited once again in 2019 for
the Spice World Tour, whereby each participating member was reportedly paid £12 million.
35. In addition to their touring success, the Spice Girls continue to be an iconic
cultural phenomenon worldwide, transcending their careers as musicians and performers. Upon
information and belief, the personal lives of each member of the Spice Girls, including that of
Mel B, continue to be the subject of great interest in various media, including print media, talk
shows, tabloids, and gossip columns.
36. Ms. Brown and Mr. Belafonte began dating in 2006. The couple married on June
6, 2007, in Las Vegas. Ms. Brown gave birth to M.B. in 2011. Prior to their marriage, Mr.
Belafonte had one daughter by a previous relationship (“G.B.”), and Ms. Brown had two
2
https://ew.com/movies/2019/06/12/spice-girls-animated-movie-paramount/
3
https://en.wikipedia.org/wiki/Spice_Girls
4
Id.
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daughters, one by a previous marriage (“P.B.”), and the second (“A.B.”) by Eddie Murphy, the
actor and comedian, whom Ms. Brown dated for approximately three or four months.
37. Ms. Brown filed for divorce in or around March 2017, which was settled in
August 2017 and finalized in 2018. Mr. Belafonte was awarded and continues to have primary
custody of M.B.
38. Throughout their ten-year marriage and thereafter, Ms. Brown has demonstrated a
pattern of publishing false and defamatory statements about various individuals in her personal
life, sometimes going so far as to accuse those persons of committing heinous crimes in
retaliation for their honesty regarding her serious substance abuse problem.
39. For example, in 2017, Ms. Brown was sued for defamation by Lorraine Gilles, a
former nanny that had taken care of the couple’s children for approximately seven years. See
Lorraine Gilles v. Melanie Brown, California Superior Court (Los Angeles County) Case No.
BC658783 (Filed April 20, 2017). The allegedly defamatory statements in that action included
Ms. Brown’s public statements that, inter alia, Mr. Belafonte was having an extramarital affair
with Ms. Gilles, got Ms. Gilles pregnant, and coerced Ms. Brown into threesomes with Ms.
Gilles. In fact, it was Ms. Brown that had an intimate relationship with Ms. Gilles for nearly the
entire seven years of Ms. Gilles’ employment—and Ms. Brown later admitted that her
accusations regarding the affair between Ms. Gilles and Mr. Belafonte were false. Ms. Brown’s
attempt to dismiss Ms. Gilles’ lawsuit on anti-SLAPP grounds was unsuccessful, and the denial
of her motion was affirmed on appeal because the reviewing court found that Ms. Gilles’ lawsuit
was rightfully filed. In 2019, Ms. Brown paid Ms. Gilles the hefty sum of £ 1.8 million in
satisfaction of a settlement reached in that lawsuit.5 A screenshot of a portion of the widely
5
https://www.dailymail.co.uk/tvshowbiz/article-6909765/Mel-B-settles-defamation-lawsuit-former-nanny-Lorraine-
Gilles-court-1-8million.html
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publicized TMZ article demonstrating Ms. Brown’s public admission regarding her relationship
with Ms. Gilles is reproduced directly below:
40. On another occasion, at an interview with Piers Morgan in or around March 2019,
Ms. Brown implied that she had a sexual tryst with fellow bandmate Geri Halliwell Horner. In a
statement released by Ms. Horner’s press representative, Ms. Horner denied that there had been
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any sexual relationship between herself and Mel B and expressed disappointment and hurt that
Ms. Brown would propagate such false statements.6
41. In 2018, Ms. Brown falsely accused Rusty Updegraff, another nanny formerly in
her employ, of sexually assaulting her children, in retaliation for Mr. Updegraff confronting her
about her heavy drinking, sexual relationships with strangers who frequented her home, cocaine
use around the children, as well as neglect of her children.7 In video recorded evidence, Ms.
Brown made these false accusations to several third parties who knew Mr. Updegraff personally,
going so far as to state that the nanny was “fucking the children up the arsehole.” Moreover, Ms.
Brown lied that there had been a police investigation in connection with this alleged sexual
assault, even though there was no such investigation and no related police report had been filed.
Ms. Brown was more interested in discrediting Mr. Updegraff to members of the community
than the emotional harm she would be causing her family by spinning false sexual assault
accusations. At the same time, Ms. Brown’s outrageous conduct regarding Mr. Updegraff was
calculated to cause Mr. Belafonte severe emotional distress as it demonstrated Ms. Brown’s
flagrant disregard of the emotional and psychological impact of the sexual assault accusations on
his children.
42. Additionally, Ms. Brown was sued in 2019 by an employee of hers, Gary
Madatyan, for, among other claims, intentional infliction of emotional distress. Mr. Madatyan
alleged in his lawsuit that Ms. Brown’s psychiatrist, Dr. Charles Sophy, wrote prescriptions for
controlled substances in Mr. Madatyan’s name intended for use by Ms. Brown, so as to avoid
6
https://www.eonline.com/news/1028835/geri-halliwell-addresses-mel-b-s-very-hurtful-claims-about-their-sexual-
relationship
7
https://www.dailymail.co.uk/news/article-6119699/Mel-B-constantly-drunk-abusive-puts-children-risk-says-ex-
Stephen-Belafonte.html
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detection.8 See Poghos Karen “Gary” Madatyan v. Melanie Brown, California Superior Court
(Los Angeles County), Case No. 19STCV34181. Upon information and belief, Mr. Madatyan
and Ms. Brown have settled this dispute for an undisclosed sum.
43. Throughout their marriage, Mr. Belafonte slowly pulled back from his own career
as a film and TV producer and instead focused on assisting with Ms. Brown’s career by serving
as her manager and landing her business deals and various gigs as an artist.
44. The couple’s marriage was heavily impacted by Ms. Brown’s serious substance
abuse problem, which included the abuse of cocaine, alcohol, and prescription drugs, including,
but not limited to antidepressants and valium, as well as dangerous combinations of the
foregoing drugs with alcohol. For much of their marriage, Mr. Belafonte was deeply concerned
for Ms. Brown’s health and wellbeing, as well as the health and wellbeing of their children, as
evidenced in attached Exhibit 4, a text message from Plaintiff to Defendant concerning her
efforts to stop drinking.
45. Often, while under the influence of drugs or alcohol, Ms. Brown would
hallucinate, make up false stories, and remember them sober and blame Mr. Belafonte for her
behavior, making him the enemy because he was the only one that would confront her about her
addiction behavior or drunken and intoxicated episodes. Mr. Belafonte implored Ms. Brown to
seek help in connection with her rampant alcohol and drug abuse. In response, and in an effort to
deflect blame for her substance abuse and her irresponsible behavior while under the influence,
Ms. Brown would lash out at Mr. Belafonte and hurl abusive verbal attacks at him or blame him
for her irresponsible behavior. Attached as Exhibit 5 is a small sampling of text conversations
8
https://www.dailymail.co.uk/news/article-7509465/Mel-Bs-close-friend-Gary-Madatyan-accuses-using-abusing-
bombshell-lawsuit.html.
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between Ms. Brown and Mr. Belafonte demonstrating Ms. Brown’s abusive language and
belligerent behavior.
46. Ms. Brown’s intoxicated episodes grew so frequent and so out of control that, in
order to protect her and help her and her therapist understand the extent of her actions, on a
handful of occasions, Mr. Belafonte took video of Ms. Brown acting out violently or
inappropriately, such as when she tried to “pound” vodka shots with her teen daughter, or when
she left their London apartment in the middle of the night in her pajamas to get a glass of wine.
But despite Mr. Belafonte’s intentions, Ms. Brown turned his acts against him, publicly and
falsely charging him with taking and sharing illegal “revenge porn”-type videos.
47. Throughout their marriage, Ms. Brown would also frequently ridicule Mr.
Belafonte’s physical appearance and medical condition. For instance, on at least one occasion,
Ms. Brown made disparaging remarks to at least one third-party about Mr. Belafonte’s
experience with lupus, an autoimmune illness with severe symptoms. A screenshot containing
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Ms. Brown’s text messages disparaging Mr. Belafonte’s appearance and lupus symptoms is
reproduced directly below. Ms. Brown’s deliberate pattern of ridicule and disparagement was
outrageous and calculated to cause Mr. Belafonte severe emotional distress.
48. In fact, on at least one occasion, after falsely claiming in public and in court that
Mr. Belafonte was threatening to publicize sexual content of her, Ms. Brown shared a video
depicting Mr. Belafonte engaging in sexual activity with a third-party individual. (Plaintiff was
forwarded and currently holds a copy of said message disseminating the referenced video).
49. Furthermore, on many occasions, Ms. Brown would call Mr. Belafonte repeatedly
if he failed to answer his phone, or would engage in a pattern of sending him incessant text
messages of a jealous or spiteful nature. Ms. Brown sometimes did this while the couple were
apart and staying in different time zones, such that it was daytime in Australia or the United
Kingdom where she was working and nighttime in Los Angeles where Mr. Belafonte was
sleeping, thereby interrupting Mr. Belafonte’s asleep. Ms. Brown’s deliberate pattern of
harassment was outrageous and calculated to perturb Mr. Belafonte and cause him severe
emotional distress. By way of example, and not
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limitation, screenshots of text conversations, showing a pattern of harassment inflicted by Ms.
Brown, are reproduced directly below:
50. Additionally, on at least one occasion in November 2010, Ms. Brown was
photographed by paparazzi in a public setting in London in what appeared to be an extramarital
dalliance with the actor, Tamer Hassan. For example, the Daily Mail ran an article entitled “Look
away now, Stephen! Mel B gets VERY touchy-feely with hardman actor Tamer Hassan,” and
posted at https://www.dailymail.co.uk/tvshowbiz/article-1332569/Mel-B-gets-VERY-touchy-
feely-hardman-actor-Tamer-Hassan.html. The publications of these photographs—which Ms.
Brown instigated—subjected Mr. Belafonte to ridicule and emotional distress. Further, Mr.
Belafonte would come to learn that Ms. Brown did have an extramarital affair during her London
trip in November 2010. Since that time, the couple’s relationship went downhill and Mr.
Belafonte’s trust in their marriage was irreparably broken.
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51. In April 2017, in the course of divorce proceedings, Ms. Brown took the
psychological warfare she was waging against Mr. Belafonte to unprecedented heights. Ms.
Brown applied for a temporary restraining order against Mr. Belafonte, submitting a declaration
in support thereof (the “TRO Declaration”), dated April 2, 2017. The TRO Declaration falsely
charged Mr. Belafonte with, among other things, brutal domestic violence, felony gun
ownership, kidnapping, extortion, financial abuse, and cruel and malevolent behavior. Ms.
Brown submitted the TRO Declaration, which was outrageous on its face, with the specific intent
to destroy Mr. Belafonte’s personal life and reputation, to separate him from his daughter, and to
cause him severe emotional distress. Unfortunately, the family court in California granted Ms.
Brown’s application for the restraining order, which resulted in Mr. Belafonte’s removal from
their marital home, as well as a court order preventing Mr. Belafonte from seeing or contacting
M.B. Moreover, concurrently with her filing the TRO declaration, Ms. Brown also emptied the
couple’s bank accounts, which caused Mr. Belafonte severe hardship in obtaining alternative
housing upon his court-ordered removal from their marital home.
52. The statements made by Ms. Brown in the TRO Declaration were intentionally
and maliciously made with the intent to deliberately inflict humiliation, mental anguish, and
severe emotional and physical distress upon Mr. Belafonte, and were made in wanton and
reckless disregard of such consequences to Mr. Belafonte. A temporary restraining order was
granted as a result of the outrageous charges made in the TRO declaration, which prevented Mr.
Belafonte from seeing or contacting his daughter until the restraining order was withdrawn.
53. In particular, in the TRO declaration, Ms. Brown fabricated from whole cloth
specific incidents in which Mr. Belafonte supposedly beat her. One such fabricated incident in
the TRO declaration is recounted as follows:
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a. “In July 2012, while I was taping the X Factor in Sydney, Australia, I was sent by
the show to New York to do what was called a “Home Visit” segment. Usher, the
recording artist/producer, was to appear in the segment with me. On the evening
of the taping, [Mr. Belafonte] flew into a rage claiming that I had been flirting
with Usher all day. [Mr. Belafonte] was clearly jealous without reason. [Mr.
Belafonte] punched me with a closed fist in the face causing my lip to split and
then swell. I asked [Mr. Belafonte] how I was supposed to work with a swollen
lip, and he told me that I should have thought of that before I decided I wanted to
“flirt with and fuck” Usher. [/] When I showed up on set with a swollen lip,
people began asking questions. I lied in order to cover for [Mr. Belafonte] and
told everyone that I had an allergic reaction to shellfish. My lip and lower portion
of my face was swollen to the point that I had to be filed from a particular angle
so that the injury would not show up on tape. The producers called a doctor for
me because my face was so bad. The doctor gave me a steroid injection in order
to treat what I told him was an allergic reaction. I risked my own health by taking
a medically unnecessary injection because of my fear of [Mr. Belafonte] and what
he would do if I did not cover for him.”
b. But the so-called attack was a complete fabrication, as demonstrated by
contemporaneously taken photographs, including ones taken by paparazzi the
same night as the Usher appearance (July 25, 2012). Attached as Exhibit 6 are
photographs dated July 25, 2012, the first showing Ms. Brown on set with Usher,
and the second showing Ms. Brown in the same outfit later that evening, where
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Ms. Brown shows no signs of any injury whatsoever.9 And less than 48 hours
later, on July 27, after having brunch with friends, Ms. Brown was back on air
making a TV appearance on “Good Afternoon America” July 27, 2012 with no
evidence of a “split lip” or swelling.10 Ms. Brown even posted a photo of Usher
on her Instagram in April 2013, a year after the “attack” without any apparent
distress about the incident. Attached as Exhibit 7 are photographs of Ms. Brown
having brunch with friends, Ms. Brown’s Good Afternoon America appearance,
and a screenshot of the April 2013 Instagram post.
c. The totally fabricated incident, cunningly incorporating the highly famous
musician Usher, was published with the deliberate motive to cause all the TRO
declaration to become widely published in gossip columns and similar
publications.
54. Given Ms. Brown’s celebrity status, Ms. Brown was fully aware that the TRO
Declaration would be publicized and made available to the public at large. Indeed, the TRO
Declaration and the false statements therein about Mr. Belafonte were publicized on major news
outlets in the United States and internationally, including, but not limited to, TMZ, Page Six,
Entertainment Tonight, Daily Mail, The Sun, and Us Weekly.
55. Moreover, Ms. Brown’s outlandish accusations did not stop with the TRO
Declaration. On at least one occasion, Ms. Brown contacted a third party with whom the couple
had engaged in consensual group sexual intimacy, and asked this woman to participate in the
family court proceedings by falsely accusing Mr. Belafonte of raping her. Unfortunately for Ms.
9
Paparazzi captured Ms. Brown leaving a restaurant on the night of July 27, 2012, which was published by the
Daily Mail the following day, available at <https://www.dailymail.co.uk/tvshowbiz/article-2179359/Mel-B-gets-
helping-hand-Kim-Kardashians-best-pal-Jonathan-Cheban-night-out.html>.
20
Brown, this woman submitted a statement to the family court detailing that her sexual encounter
with the couple was consensual, that Mr. Belafonte had not raped or otherwise sexually assaulted
her, that Ms. Brown had contacted her and requested that she lie about Mr. Belafonte, and that
she had refused that request. Although unsuccessful, Ms. Brown’s attempt to induce a third party
to charge Mr. Belafonte with rape was deliberately undertaken to cause, and did, in fact, cause
Mr. Belafonte severe emotional distress.
56. Unfortunately, the widespread reporting about the parties’ divorce was only the
first link in an extensive and continuing chain of false and defamatory narratives publicized and
perpetuated by Defendant about Mr. Belafonte.
57. The defamatory statements that are the subject of this action were made by
Defendant with the deliberate purpose of portraying Mr. Belafonte as a cruel, manipulative, and
violent spouse that subjected Ms. Brown to years of humiliation, exploitation, and abuse.
58. As part of the scheme to portray Mr. Belafonte as a malevolent spouse, Ms.
Brown appeared in a “public service” style, domestic violence awareness video in 2021, in which
she is beaten bloody by an actor. The video has garnered 1.3 million views and is available at
the following link: < https://www.youtube.com/watch?v=r6xWu4xaKTg>.
59. A screenshot from this video was then included in an article written by Louise
Gannon and published by The U.S. Sun on December 31, 2021, which depicted Ms. Brown’s
face bloodied and bruised by make up as it appears in the video.
10
Ms. Brown’s appearance on Good Afternoon America, dated July 27, 2012, is available at
<https://www.youtube.com/watch?v=2hIwFeJuE7c>.
21
60. Ms. Gannon’s article provided no context whatsoever for this screenshot. She did
not clarify that the bruises on Ms. Brown’s face are the product of make-up applied for the
purpose of her domestic violence portrayal in the public awareness campaign video, and she did
not even mention the existence of the campaign video. Rather, as shown above, the screenshot is
captioned “Mel B suffered during her ‘horrendous abusive marriage,’” and shortly after the
screenshot, Ms. Gannon stated as follows: “Melanie, who has appeared as a judge on TV shows
including The X Factor and America’s Got Talent, moved back home from Los Angeles to Leeds
from LA two years ago after finally walking out on her abusive ten-year marriage to TV
producer Stephen Belafonte.” The juxtaposition of the foregoing statement, alongside the
screenshot and the caption appended thereto, created the false and defamatory impression that
Mr. Belafonte caused the injuries depicted in the photograph.
22
61. Additionally, numerous other news outlets republished articles regarding the
domestic violence awareness video, similarly juxtaposing the screenshot of Ms. Brown from the
video with photos of Mr. Belafonte, leading readers to conclude that Mr. Belafonte caused the
injuries depicted in the photograph. Screenshots of two such headlines, each of which placed a
photograph of Mr. Belafonte next to the image of Ms. Brown with make-up from the domestic
violence campaign video, are reproduced directly below:
62. Upon information and belief, Ms. Brown encouraged and directed Ms. Gannon to
make the foregoing statement in her article, with knowledge of its false implication that Mr.
23
Belafonte had caused the “injuries” depicted in the photograph, or at least with reckless disregard
as to its truth. Furthermore, the juxtaposition of the screenshot caption and the quoted statement
naming Mr. Belafonte were made with knowledge or reckless disregard as to the defamatory
consequences, namely of portraying Mr. Belafonte as a cruel and violent spouse.
63. Defendant likewise acted with knowledge and reckless disregard of the truth in
writing her “tell-all” memoir, ironically titled Brutally Honest. Specifically, the false and
defamatory statements written and published by Defendant about Mr. Belafonte in Brutally
Honest (originally published in 2018 and re-published as a new edition in 2024) include, among
others, the following:
a. “I know what it’s like to be beaten down. I know what it’s like to be punched,
humiliated and isolated, and to feel there is no way out except suicide.”
b. “He was the one that decided where I lived, who I saw (unless I was working),
what my money was spent on, who looked after our kids (not me but a selection
of nannies or members of his family). It was up to him where I was a piece of filth
that day, a goddess or a whore.”
c. “Chris told me later that he had never witnessed any man speak to a woman the
way Stephen talked to me. ‘Ugly,’ ‘Slut,’ ‘Fat,’ ‘Stupid,’ ‘Bitch,’ ‘Worthless,’
‘Drunk,’ ‘Pathetic,’ ‘Monkey,’ ‘Derelict.’ They’d become just words said so many
times to me that I would absorb them like a sponge.”
d. “I also accepted that he checked all my emails and answered them, deleted them –
same with my phone messages, Twitter and Instagram pages. He controlled my
bank accounts and my work schedule.”
24
e. “I know that none of my family could see beyond the wall of Stephen. My email
addresses kept changing, we moved house every year, all my old employees and
friends had fallen by the wayside.”
f. “He was disdainful of my work; he’d refuse to watch the recorded shows on TV,
or he would talk loudly all the way through them while the girls and I were trying
to watch.”
g. “He would look through my handbag, scroll through my phone, looking for
evidence of bad behaviour.”
h. “And then it happens. Bang! Screaming, shouting. Your husband is up, and then
he is on the floor brawling with the two men. One gets up, but the other man is
still on the floor, and he is being punched again and again. Blood is pouring from
the man’s head, and two other men are shouting, pulling him away.”
i. “You see someone take a photograph. Stephen’s sweatshirt has been ripped from
his massive, barrel of a chest and he is up, panting and pacing in the bar as staff
(you can see one barman looking terrified) ask you to leave. The man with the
blood pouring from his head is taken to hospital and now you know he is going to
make you call your lawyers and those lawyers are going to have to stop charges
being brought (they did). I felt I had no choice but to defend Stephen. In a press
statement, I claimed that he had been rushing to defend my honour.”
j. “After a series of what my mum now describes as ‘the most abusive, disgusting
and terrifying’ phone calls, he had successfully cut my parents out of our lives,
making me feel like the best thing for me was to have no contact: no calls, no
emails, nothing.”
25
k. “The entire circle of people I trusted and relied on most in the world was
decimated within a year and a half. My parents, my friends –even my gorgeous,
smart personal assistant Janet Neale, who worked for me for five years when I
moved out to LA – hated Stephen from the get-go.”
l. “When I was working on The X Factor, in a two-hour period he would call my
phone fifty times, asking where I was, what I was doing, tell me when I had to be
back, accusing me of sleeping with Simon Cowell (obviously, I wasn’t), accusing
Chris of covering up my affair with Simon (he didn’t, as I wasn’t).”
m. “All I thought was that I needed to get out of the room but for some reason the
door was jammed. I can’t clearly remember what happened next but I remember
throwing myself at the door, crashing my full weight . . . against it. I felt like a
trapped animal.”
n. “I had ADHD and I believed I was, as Stephen told so many, many times, ‘thick
as pig shit.’”
o. “Stephen kept a gun in our bedroom. He knew I hated guns, he knew I was
frightened of them. I didn’t want guns in our house. I didn’t want guns anywhere
near me.”
p. “He’s left porn magazines open in [P.B.’s] bathroom.”
q. “You’re a washed-up old has-been Spice Girl with two kids by two different men.
You are lucky you have me, now.”
r. “‘Look at your arms. They look flabby and saggy. You’re old and you’re ugly.’
‘Get your face out of my sight.’ ‘Your fucking arse, Melanie. It’s fucking
disgusting.’ He would get louder and louder, pushing his face right in front of
26
mine to tell me how stupid and ugly I was. ‘You should thank God you have me
because no one else would want you.’”
s. “in the middle of some social gathering at our house, Stephen started screaming at
me, calling me a whore.”
t. “Stephen had control of the finances, chose where we lived and who looked after
the kids. He had strong views on what we ate, what I wore (he always liked me to
wear black), what handbag and shoes I has on, where we went.”
u. “I never saw the cruelty that was inflicted on my daughter’s sweet, gentle dog,
Lordy. He was old, he had bad hips. He would not hurt a fly. Stephen would beat
him in front of [P.B.].”
v. “When I left Stephen, I walked away with nothing but $936 in a bank account (the
only one I had access to) and suitcases full of clothes, books and toys.”
w. “I didn’t even know Amazon existed before April 2017, and within a matter of
weeks I was their best customer.”
x. “I agreed to drop domestic violence charges in order for all the sixty four sex
tapes he had made during our marriage not to be shown in open court.”
y. “I have no idea whether Stephen’s stories about his father being a drug dealer are
true. I do know (from his brothers and sisters) that there were an awful lot of
drugs consumed in the house by him (LSD and marijuana), and that his dad,
Kenneth Stansbury, a Black African American, was a Golden Gloves-winning
boxer in New Jersey (he won the title in 1964) with a record of violence and
abuse. At the age of eighteen, Kenneth was charged with trying to kill his own
father, Theodore (the charge was later dropped), but he went on to build up a rap
27
sheet which included domestic violence, assault and threatening police. In 1968
when Kenneth was twenty one, he was charged with malicious mischief,
fornication, using profanity and threatening a police officer, telling him, ‘I’ll put a
bullet in you.’ Steve was his father’s son. He comes from a line of criminals. His
grandfather, Theodore has criminal history for adultery, not paying child support
and abandoning his wife. But even his own family would say – and they did – that
Steve was the nastiest of them all.”
64. Furthermore, Ms. Brown has published the following false and defamatory
statements about Mr. Belafonte throughout various press appearances and interviews from 2018
until the present:
a. On November 26, 2018, at an appearance on “Loose Women” to promote her then
newly published memoir, Ms. Brown stated as follows (available at
<https://www.youtube.com/watch?v=Z8kX4gqPEN8>):
i. “looking back, there were so many warning signs and red flags, but when
you’re in that kind of relationship, which is very abusive on many
different levels, you end up taking the blame and thinking that it’s your
fault.”
ii. “on my wedding night, things started to happen which were very abusive.”
iii. “I lived in complete panic and fear whenever I was at home with him.”
iv. “My kids weren’t allowed to eat at the table.” Below is a photograph
showing Ms. Brown’s children enjoying a family dinner at the table:
28
b. On December 10, 2018, at an appearance on the Steve Harvey Show, Ms. Brown
stated as follows (available at
<https://www.youtube.com/watch?v=d7gOoDpk9Pc>):
i. “I just wanted to highlight that abuse is unacceptable, and I lived it for ten
years, with my abuser, my then husband. And it’s something that I felt
very ashamed about.”
ii. “When you’re in an abusive relationship, you don’t want anybody to know
that. It is very embarrassing and you feel very riddled with shame and
guilt and when I left my abuser, I wanted to speak about it loud and
proud.”
c. On May 25, 2019, in an appearance as the featured guest on Piers Morgan’s “Life
Stories,” Ms. Brown stated as follows:
29
i. “I’d get threatened with ‘I’m gonna expose the sex tapes, I’m gonna ruin
your career, you’re never gonna be hireable, I’m gonna tell everybody
about how much you drink, how much you do drugs,’ which to me was
devastating.”
1. In fact, as set forth in Paragraph 48, it was Ms. Brown that shared a
video depicting Mr. Belafonte engaging in sexual activity with a
third-party individual.
ii. “when I left my ex, I couldn’t even be touched. I was paranoid, I had
nightmares. I couldn’t actually feel safe with somebody.”
1. In fact, Ms. Brown was dating at least one individual publicly in
2017, after having left Mr. Belafonte.11 Attached as Exhibit 8 are
multiple text messages showing that Ms. Brown was dating and
having intimate relationships with multiple individuals after
leaving Mr. Belafonte.
d. In a December 2018 interview with syndicated journalist Allison Kugel, which
was later published in Miami Living Magazine on April 24, 2020, Ms. Brown
stated as follows (available at <https://www.miamilivingmagazine.com/post/mel-
b-on-sex-drugs-abuse-her-epic-healing-journey>):
i. “I’m very much a source of information when it comes to coercive
behavior and abuse, because I’ve lived it for ten years.”
ii. “I [was] at my most vulnerable when my abuser came into my life.”
11
Ms. Brown’s relationship was reported on in gossip columns. See, e.g.,
<https://www.dailymail.co.uk/tvshowbiz/article-4869106/Mel-B-seen-public-time-Ryan-Lawrence.html>
30
iii. “The book addresses things like why it took me so long to leave. It’s
because you’re trapped, and you don’t have friends and family because
you’ve been isolated due to how your abuser does things.”
iv. “I haven’t taken a drug since the day I left him [ex-husband, Stephen
Belafonte]. What you’ll find in these abusive relationships is that the
abuser is the one that provides you with all your alcohol and all your
drugs. I’ve never had an addictive personality. I’m addicted to loving life,
but that’s about it.”
1. In fact, Ms. Brown has continued to consume alcohol and illegal
drugs in M.B.’s presence. Attached as Exhibit 9 is a Minute Order
from the Superior Court of California, County of Los Angeles,
ordering Ms. Brown to refrain from being “under the influence of
alcohol or other substance which substantially impairs her ability
to care for [M.B.]”
v. In response to Ms. Kugel’s comment regarding an alleged rape witnessed
by Ms. Brown’s eldest daughter, Ms. Brown stated, “I guess one time she
snuck up[stairs] because she heard me screaming or crying. She jutted the
door open a little bit and she witnessed that, which I didn’t even know
she’d witnessed until after I’d left him two years ago and started writing
the book. She was adamant about that story going in the book. That story
didn’t go in the book, but it actually went into an interview that she did,
and she was adamant to talk about it.”
31
e. On December 26, 2020, in an exclusive interview with The Sun, Ms. Brown
stated as follows (available at <https://www.thesun.co.uk/tv/13579017/mel-b-
corrie-bosses-yasmeen-abuse-storyline/>):
i. “I didn’t realise for so many years that I was in a coercive relationship. It
was only through doing my book that I began to fully understand the
situation I had been living in for ten years.”
ii. Further, The Sun article embedded multiple photographs of Mr. Belafonte,
accompanied with captions such as “The Spice Girl has told about her
personal experience, after allegedly being abused for years in her marriage
with Stephen Belafonte.”
f. On May 17, 2021, following the release of the domestic violence public
awareness video discussed at Paragraphs 46-48, Ms. Brown gave an interview to
ITV News (available at
<https://www.youtube.com/watch?v=l59nuaHQFWk&t=64s> and published at
<https://www.itv.com/news/calendar/2021-05-17/mel-b-appears-in-video-
highlighting-the-different-stories-of-domestic-violence>) in which she stated as
follows:
i. “Some women don’t have access to their phones, even their finances, like
in my situation, you are completely cut off from a regular, normal world,
and what becomes your normality is living in an abusive relationship with
no way out.”
32
ii. The ITV News article explicitly reference Mr. Belafonte and the
allegations from Brutally Honest, and the two-minute video embedded
therein contains several photographs of Mr. Belafonte with Ms. Brown.
g. Also on May 17, 2021, Ms. Brown appeared in an interview with Good Morning
Britain, during which she stated as follows (available at
<https://www.youtube.com/watch?v=7vFO-qLFneM>):
i. “People in these situations, they don’t feel like they have a way out,
they’ve been already isolated from their friends and their family, and that’s
one of the major signs that somebody is in one of those kinds of
relationships, just like I was.”
ii. “I was really happy to go to work because that was my safe place.”
iii. “Well, this is the thing—you don’t want to discuss it because like I said
before, and I’ve written about it in my book, Brutally Honest, you’re
riddled with shame and guilt and you’re embarrassed, and you don’t think
anybody’s going to believe you. Your abuser is constantly bringing you
down, constantly calling you names, constantly making you feel
worthless.”
h. Ms. Brown gave an additional interview on May 17, 2021, to Simon Hattenstone
of the Guardian, during which she stated as follows (published at <
https://www.theguardian.com/society/2021/may/17/mel-b-on-domestic-abuse-
trauma-and-recovery-in-my-mind-there-was-no-way-out>):
i. “I tried to leave seven times, so you can imagine how desperate I was in
those 10 years. I didn’t have anywhere to go, I didn’t have my own credit
33
card, I didn’t have a car, I’ve got three kids, I was very on the edge of self-
destruction.”
ii. “It starts with tiny things,” such as “Oh, don’t wear that dress – I’ve
bought you this dress. . . It wasn’t like: ‘Put this dress on!’ It was: ‘Look
what I’ve bought for you! I saw you looking at it on Net-a-Porter.’ And
you think: ‘Oh my God, that’s so sweet!” when actually they’re starting to
take over everything.”
iii. “I didn’t even know what colour I liked any more because those choices
were taken away from me for so long. And I just accepted it.”
1. In fact, Mr. Belafonte did not control Ms. Brown’s wardrobe.
Throughout their marriage, Ms. Brown always employed
professional stylists who, in addition to styling her outfits for work
appearances, would also ensure that she had fashionable everyday
wear for any non-work appearances outside of the home.
i. On March 7, 2022, in an exclusive interview with HELLO! magazine, Ms. Brown
stated as follows (available at
<https://www.hellomagazine.com/celebrities/20220307134768/mel-b-still-feels-
post-abuse-trauma-womens-aid/>):
i. “[A]s a woman, as a mother, as a wife, I went through ten years of
emotional abuse and went through some of the worst emotional lows I've
ever experienced.”
ii. Further, the HELLO! magazine article that published the interview named
Mr. Belafonte explicitly in its introduction.
34
j. On May 9, 2022, at an interview with Piers Morgan for “Talk TV” (available at,
<https://www.youtube.com/watch?v=Lh5wdn3yy78>) Ms. Brown commented on
the then ongoing defamation trial between Amber Heard and Johnny Depp by
stating, as follows:
i. "This is such a very sensitive topic for me because it's so personal—but to
me this case is so not entertainment for me. What I worry about is that it's
going to damage future men, women from coming forward and making
their own claims, or the justice system having doubt or not believing.”
ii. Further, Newsweek reported on the interview with Piers Morgan one day
later, whereby it discussed the 2018 release of Brutally Honest and named
Mr. Belafonte explicitly in connection with the allegations of “torment and
physical abuse” detailed in the memoir. The Newsweek article can be
accessed at <https://www.newsweek.com/mel-b-amber-heard-johnny-
depp-trial-fears-prince-william-1705102>.
k. On January 9, 2023, at an appearance on Fox’s “Special Forces, Ms. Brown stated
as follows (available at <https://www.youtube.com/watch?v=wIelUm8R3oM>):
i. “since I came out of a really abusive relationship, for ten years I was in
that…”
ii. “the reminder of self-worthlessness and being called so many names day
after day for ten years.”
l. On January 18, 2023, at an appearance on “LIVE with Kelly and Ryan,” Ms.
Brown stated as follows (available at
<https://www.youtube.com/watch?v=oWQLQMLezXw>):
35
i. “it was a very very horrific, abusive relationship.”
ii. “at the time when I brought out my book in 2015, I was the only one
talking about it.”
iii. “when you’ve gone through something like that, you feel so broken, and
you feel so worthless and low ‘cuz you’re being told, day in and day out,
you’re—I mean, the horrible things I got told for ten years. You’re
confidence is on the floor—put aside that, the physical abuse, the coercive
control, the financial control, I was left just in bits and pieces.”
m. On January 20, 2023, at an appearance on The View, Ms. Brown stated as follows
(available at <https://www.youtube.com/watch?v=JAewUG7OHl8>):
i. “Unfortunately, I had a very abusive, ten-year marriage.”
ii. “When you’ve been through something like that, you walk out of it feeling
so broken, and feeling so worthless, you’re riddled with shame and guilt.”
n. On November 7, 2023, at an appearance on Howie Mandel’s podcast, “Howie
Mandel Does Stuff,” Episode No. 146, Ms. Brown stated as follows (available at
<https://www.youtube.com/watch?v=E7cfobPFjyg>):
i. In response to Mr. Mandel’s question whether she “came really close to
death,” Ms. Brown responded, “oh yeah, many times, at the hands of my
abuser,” that the children “witnessed it[the purported physical abuse many
times” and that she was “too terrified” to go to the police.
o. More recently, with the 2024 republication of Brutally Honest, Ms. Brown
appeared on the View on March 25, 2024, where she stated as follows (available
at < https://www.youtube.com/watch?v=tKKkb1WZyqc>):
36
i. “I was not in contact with my family and my friends.”
ii. “I was isolated from my family.”
iii. “I was financially abused, emotionally abused.”
iv. “I saw it [the X Factor earnings] go into my account, and then he [Mr.
Belafonte] took it out of my account.”
v. “I never thought I’d be able to actually buy my own house because I was
financially abused.”
vi. “This book isn’t a he said, she said, it’s actually facts, hence I haven’t been
sued, it’s been out quite some time.”
p. On March 25, 2024, at an appearance on “Today with Hoda and Jenna,” (available
at < https://www.youtube.com/watch?v=jXMbrKmxmpI>), Ms. Brown stated as
follows:
i. “my very abusive, ten-year marriage;”
ii. ““when you’re in that kind of abusive relationship, you’re separated from
friends, from your family, your close ones.”
q. On January 25, 2024, at an appearance on “The Jennifer Hudson show,”
(available at <https://www.youtube.com/watch?v=P_4IkluWc7A>), Ms. Brown
stated as follows:
i. “I went through a ten-year, terrible abusive marriage.”
r. An article published on February 23, 2024 by the U.S. Sun quoted her stating as
follows (available at <https://www.the-sun.com/entertainment/10482822/mel-b-
broke-abusive-relationship/>):
37
i. “I didn’t have access to a credit card during my relationship and was
working 24/7.”
s. On January 9, 2024, at an appearance on “The Tonight Show Starring Jimmy
Fallon,” (available at <https://www.youtube.com/watch?v=avV4m-JY-MY>), Ms.
Brown stated as follows:
i. “I’d gone through a ten-year, very abusive relationship.”
t. On April 9, 2024, at an appearance on “Relationshit w/Kamie Crawford,”
(available at < https://www.youtube.com/watch?v=I56phWFeRRg>), Ms. Brown
stated as follows:
i. “She saw me being sexually abused.”
ii. “He locked the bathroom door, and he left me to die basically and didn’t
let me get to the ambulance.”
iii. “I was about to full on charge him with domestic violence, kidnapping one
of my kids, everything.”
65. The above statements are knowingly and materially false.
66. Mr. Belafonte has never physically, sexually, emotionally, or financially abused
Ms. Brown.
67. Mr. Belafonte did not leave Ms. Brown to die and did not block her from
accessing life-saving assistance.
a. Further, Ms. Brown’s account of the foregoing incident in Brutally Honest stands
in stark contrast to her description of it in her TRO declaration, in which she
stated as follows:
In December 2014, [Mr. Belafonte] came to the UK. [Mr.

Belafonte]’s abuse, coupled with the mind-games became
38
overwhelming. In a moment of emotional and physical exhaustion,

I took an entire bottle of Aspirin. I immediately regretted the
action, and tried to call 999 (England's version of 911), and [Mr.
Belafonte] blocked me from calling for help. He threw me in the
bedroom (without a phone) and locked the door, telling me to ‘die,
bitch!’ I tried to break down the door, and eventually I was able to
break the lock as it was very old. Seeing that I opened the door,
[Mr. Belafonte] pushed it shut. Each time I would pry the door
open and try to squeeze out, [Mr. Belafonte] would slam the door
on my head. I kept telling him that I wanted to get my stomach
pumped and I begged him to let me out. At some point, my friend
Randy came over, but forced him to leave. Randy apparently called
an ambulance for me, but [Mr. Belafonte] turned it away.
b. In fact, Mr. Belafonte promptly called poison control to ascertain whether he
could quickly assist Ms. Brown prior to the arrival of an ambulance. At no point
did Mr. Belafonte prevent Ms. Brown from contacting an ambulance or otherwise
calling for help. In fact, an ambulance did arrive and it was Ms. Brown who
refused to get in it. Instead, she continuously demanded to be taken to Simon
Cowel’s home. At no point did Ms. Belafonte lock the door on Ms. Brown or
otherwise block the way to prevent Ms. Brown from getting out of the apartment
to seek medical assistance, nor did any physical interaction take place between
Ms. Brown and Mr. Belafonte. Contrary to her internally inconsistent accounts of
this incident, Ms. Brown had locked herself in the children’s bedroom, not the
bedroom she shared with Mr. Belafonte nor the bathroom as is claimed in Brutally
Honest. Like most conventional bedroom doors, this door was only capable of
being locked from the inside where Ms. Brown was located, and not from the
outside. In any event Ms. Brown and Mr. Belafonte were not alone the night of
the suicide attempt—both the nanny Lorraine Gilles and Ms. Brown’s driver Chris
Little were present. Ms. Gilles provided a lengthy deposition concerning how the
39
evening played out, and Mr. Little confirmed that no physical altercation
occurred.
68. Mr. Belafonte did not isolate Ms. Brown from her friends and family. Throughout
the entirety of their marriage, Ms. Brown continued to enjoy a vibrant and active social life with
full freedom to arrange her day-to-day life as she saw fit. Attached as Exhibit 10 are a small
sampling of photographs of Ms. Brown and various of her friends demonstrating the falsity of
her statements regarding social isolation. On the contrary, upon information and belief, Ms.
Brown’s family members (either with her or on their own) sold to the media false harmful stories
about Mr. Belafonte to the media, and false stories about Ms. Brown. Attached as Exhibit 11 is a
series of email communications showing the sales of false stories about Mr. Belafonte by Ms.
Brown’s family members.
69. Mr. Belafonte never kept firearms in the couple’s marital home. The false
statements regarding Mr. Belafonte’s gun possession, when considered alone and without
innuendo, charge him with the infamous crime of unlawful weapons possession, and tend to
subject him hatred, distrust, and contempt, and therefore constitute defamation per se.
70. Mr. Belafonte has never taken photographs or videos of a graphic or intimate
nature depicting Ms. Brown without her knowledge and consent. Further, Mr. Belafonte has
never threatened to release photographs or videos of a graphic or intimate nature depicting Ms.
Brown. In fact, as communications definitively will show, it was Ms. Brown who surreptitiously
took intimate videos of Mr. Brown and shared them with third parties without his consent. Such
false statements accusing him of this despicable and criminal act while perpetrating the same act
on her own caused further emotional distress and reputational harm to Mr. Belafonte.
40
71. Mr. Belafonte has never kidnapped his children or stepchildren, or otherwise
directed for the couple’s children to be taken out of the country without Ms. Brown’s consent.
72. Mr. Belafonte has never abused, emotionally or physically, his children and
stepchildren, or otherwise endangered his children and stepchildren. In particular, he never left
open porn magazines in P.B.’s bathroom, never beat P.B.’s dog in front of P.B., and has always
had an appropriate, even amicable, relationship with P.B. Attached as Exhibit 12 is a small
sampling of text conversations between Mr. Belafonte and P.B. demonstrating the amicable
nature of their relationship, and an email message from Ms. Brown thanking Plaintiff “for
rescuing” P.B.
73. Upon information and belief, Ms. Brown directed P.B. to contribute a false
narrative in her book and threatened to cut her off if she did not comply. Ms. Brown and her
mother Andrea also pursued extreme measures to convince A.B. to distrust and fear Mr.
Belafonte. Such actions were intended to and did cause serious emotional distress to Mr.
Belafonte.
74. Mr. Belafonte has never abused or otherwise endangered any pets or animals.
75. Mr. Belafonte was not motivated by a jealous rage when he got involved in a bar
fight at the May Fair Hotel in London in 2010. Rather, he rushed to Ms. Brown’s defense after a
couple of intoxicated strangers were behaving in an aggressive manner and making obscene
remarks about Ms. Brown. Furthermore, when London police arrived on the scene, they did not
seek to arrest Mr. Belafonte nor press charges against him. In fact, the police asked Mr. Belafonte
if he would like to press charges against the aggressive strangers, which Mr. Belafonte declined
to pursue.
41
76. Mr. Belafonte has never misappropriated, or otherwise appropriated for his own
use, any funds earned by Mel B from the X Factor or other avenues. Mr. Belafonte did not
transfer any funds from Ms. Brown’s bank accounts unbeknownst to Ms. Brown. At all relevant
times, an accountant engaged by the couple would direct payments and oversee the couple’s
marital finances, and all such actions taken by the accountant exceeding five thousand dollars
required Ms. Brown to “personally authorize” the transaction. Indeed, forensic accountants
retained by the couple during their divorce proceedings concluded that there was no indication
that Mr. Belafonte ever misappropriated Ms. Brown’s earnings. On the contrary, shortly before
she filed her divorce and TRO papers, Ms. Brown directed the accountant to close the marital
joint bank account and open a new bank account to move all the couple’s funds, along with
future incoming funds, into her new account, leaving Mr. Belafonte with nothing.
77. Ms. Brown was not left with $936 upon leaving Mr. Belafonte, as she claims in
Brutally Honest and elsewhere. Nor was she left without a credit card. Rather, on March 15,
2017, Ms. Brown entered into a lease for a luxurious mansion in Beverly Hills, CA, where her
monthly rent was $27,000, and the requisite security deposit was $54,000. Further, bank
statements produced by Ms. Brown during divorce proceedings show that she had a 6-figure
account balance during this time. Ms. Brown was also receiving $25,000 per month from in child
support from her ex, Eddie Murphy, and was in possession of hundreds of thousands of dollars of
jewelry, including her $250,000 wedding ring and an $80,000 Rolex watch. Attached as Exhibit
13 is a redacted copy of one of Ms. Brown’s credit cards (a Visa “Black Card”), Ms. Brown’s
lease agreement dated March 15, 2017, a redacted copy of a bank statement in the name of her
corporation, Osiris, Inc., dated March 31, 2017, and deposition testimony from the couple’s
accountant Michael Sobelman.
42
78. Defendant’s actions caused Plaintiff to be kicked out of his house while she lived
in a separate Beverly Hills home. Her emptying out the couple’s bank accounts left Plaintiff
homeless, sleeping in his car with no money or home while the media printed one article after the
other about what a “monster” Plaintiff was. Ms. Brown’s acts of harassment, abuse and
defamation led to Plaintiff not being able to see his daughter or step daughter, whom he raised
for ten years, and forced Plaintiff to endure unimaginable personal distress, financial ruin, public
humiliation, and false criminal charges.
79. As a result of Defendant’s actions, Plaintiff has endured years of waking up to
articles about him being accused of beating his wife. Defendant’s actions led the FBI, ATF and
police showing up at Plaintiff’s house with the gossip website TMZ filming. For years, Plaintiff
has been forced to live in fear and stress from monthly attacks by his ex-wife from
internationally broadcasted media interviews, a best-selling book, and countless social media
posts.
80. As a result of Defendant’s actions, Plaintiff has suffered from severe post-
traumatic stress disorder. He is frequently unable to sleep at night due to night sweats and bouts
of terror. In addition, Defendant’s acts have caused Plaintiff to suffer from severe panic attacks
and related physical health issues, including high blood pressure, requiring medication treatment
of Amlodipine.
FIRST CLAIM FOR RELIEF

Defamation Per Se
81. Mr. Belafonte repeats, realleges, and incorporates the preceding paragraphs herein
as if fully stated under this claim.
82. Defendant intentionally made false statements of fact about Mr. Belafonte within
Brutally Honest.
43
83. Defendant intentionally made false statements of fact about Mr. Belafonte
throughout the aforementioned media appearances.
84. The false statements charging Mr. Belafonte with physical abuse of Mel B, when
considered alone and without innuendo, charge him with the infamous crime of battery, and tend
to subject him to hatred, distrust, and contempt, and therefore constitute defamation per se.
85. The false statements concerning Mr. Belafonte’s behavior on the night of Mel B’s
suicide attempt, when considered alone and without innuendo, charge him with the infamous
crime of attempted voluntary manslaughter and therefore constitute defamation per se.
86. The false and defamatory statements concerning the threat of releasing videos of a
graphic or intimate nature, when considered alone and without innuendo, charge Mr. Belafonte
with the infamous crimes of extortion and revenge porn, and tend to subject him hatred, distrust,
and contempt, and therefore constitute defamation per se.
87. The false and defamatory statements concerning the kidnapping of children, when
considered alone and without innuendo, charge Mr. Belafonte with the infamous crime of
kidnapping, and tend to subject him hatred, distrust, and contempt, and therefore constitute
defamation per se.
88. The false and defamatory statements concerning Mr. Belafonte invading Mel B’s
phone and email account so as to impersonate her or misappropriate her earnings, when
considered alone and without innuendo, charge Mr. Belafonte with violations of the Computer
Fraud and Abuse Act and the Florida Communications Fraud Act, and tend to subject him hatred,
distrust, and contempt, and therefore constitute defamation per se.
44
89. The foregoing false statements were made maliciously and willfully in an attempt
to discredit Mr. Belafonte and to portray Mr. Belafonte as a cruel, manipulative, and violent
spouse.
90. The statements were intended to and did cause harm to Mr. Belafonte’s personal
reputation, as well as his business and professional reputation in the entertainment industry.
91. The statements were made with knowledge of their falsity, or at the very least,
with reckless disregard for their truth, and with wanton and willful disregard of the reputation
and rights of Mr. Belafonte.
92. Defendant has no privilege to assert the false and disparaging statements.
93. Upon information and belief, Defendant republished the defamatory statements to
cause further reputational damage to Mr. Belafonte.
94. Defendant’s false and disparaging statements are of the type that tend to subject
one and have, in fact, subjected Mr. Belafonte to hatred, distrust, ridicule, contempt, and
disgrace.
95. As a direct and proximate result of Defendant’s unlawful, deliberate, and
malicious conduct as set forth above, Mr. Belafonte has been, and will continue to be, damaged
irreparably, both monetarily and reputationally.
SECOND CLAIM FOR RELIEF

Defamation by Implication
97. Defendant juxtaposed a series of facts so as to imply a defamatory connection
between them. Defendant also created defamatory implications by omitting facts.
45
98. The omission of context surrounding the screenshot from the domestic violence
awareness video, which depicted Mel B in makeup to resemble bruising, created the false and
defamatory impression that the bruises were caused by Mr. Belafonte abusing Mel B.
99. The true statements of fact concerning Mr. Belafonte’s father’s criminal history,
juxtaposed with the technically true statement that “Steve was his father’s son,” that his father
“went on to build a rap sheet which included domestic violence, assault and threatening a police
officer, telling him, ‘I’ll put a bullet in you,’” and that “[a]t the age of eighteen, [Mr. Belafonte’s
father] was charged with trying to kill his own father,” create the false and defamatory
impression that Mr. Belafonte was a violent criminal and domestic batterer like his father.
100. As a direct and proximate result of Defendant’s unlawful, deliberate, and
malicious conduct as set forth above, Mr. Belafonte has been, and will continue to be, damaged
irreparably, both monetarily and reputationally.
THIRD CLAIM FOR RELIEF

Intentional Infliction of Emotional Distress
102. Defendant’s conduct as alleged above was extreme, outrageous, heartless,
atrocious, and utterly intolerable in a civilized society, and beyond all bounds of decency.
103. The statements made by Ms. Brown were made with the intent to deliberately
inflict humiliation, mental anguish, and emotional and physical distress upon Mr. Belafonte, and
were made in wanton and reckless disregard of such consequences to Mr. Belafonte.
104. As a direct and proximate result of Defendant’s extreme and outrageous conduct,
Mr. Belafonte did, in fact, suffer humiliation, mental anguish, and severe emotional distress.
46
105. As a result of such severe emotional distress, Mr. Belafonte has been, and will
continue to be, damaged irreparably, both monetarily and reputationally.
PRAYER FOR RELIEF
106. Wherefore, Plaintiff prays for judgment against Defendant, and each of them, as
follows:
a. Judgment on the claims set forth above;
b. An award of compensatory damages according to proof at trial, but in an amount
no less than five million dollars ($5,000,000), as well as punitive and exemplary
damages where authorized;
c. An order enjoining Defendant and those in active concert with Defendant from
publishing any further defamatory statements concerning Mr. Belafonte;
d. An order enjoining Defendant from speaking about Brutally Honest or Mr.
Belafonte in any public appearances and interviews;
e. An order directing Defendant to undertake such remedial efforts as the court
deems necessary to restore Mr. Belafonte’s reputation;
f. Prejudgment and post-judgment interest at the applicable rate;
g. An award for reasonable attorneys’ fees, costs, and disbursements, where
applicable; and
h. Such other and further relief the Court deems just and proper.
DEMAND FOR TRIAL BY JURY
Please take notice that Mr. Belafonte hereby demands trial by jury for all issues so triable.
47
Dated: May 29, 2024 Respectfully submitted,
/s/ Roberto Ledesma

Roberto Ledesma
[email protected]
David D. Lin (pro hac vice forthcoming)
[email protected]
Anna Iskikian (pro hac vice forthcoming)
[email protected]
LEWIS & LIN, LLC

77 Sands Street, 6th Floor
Brooklyn, NY 11201
Tel: (718) 243-9323
Fax: (718) 243-9325
Counsel for Plaintiff Stephen Belafonte
48
Case 1:24-cv-22045-XXXX Document 1-1 Entered on FLSD Docket 05/29/2024 Page 1 of 3
Message Report
Generated: 05/22/2024 at 08:21 AM by stephen belafonte OurFamilyWizard
ourfamilywizard.com
Number of messages: 14 [email protected]
Timezone: America/Los_Angeles (866) 755-9991
Parents: stephen belafonte, Mel JB

Child(ren): m brown
Third Party:
Message 1 of 14
Sent: 04/15/2024 at 05:01 AM
From: stephen belafonte
To: Mel JB (First Viewed: 04/19/2024 at 05:53 AM)
Subject: Missed FaceTime
Attachments: Me_Motha_84.jpeg (233 KB)
See attached M ’s calls to you this morning. You did not answer.
Message 2 of 14
Sent: 04/18/2024 at 08:59 AM
To: Mel JB (First Viewed: 04/19/2024 at 05:53 AM)
Subject: Missed FaceTimes
Me_Motha_85.jpeg (237 KB)
See attached Madison’s calls to you from today and yesterday. You didn’t answer.
Message 3 of 14
Sent: 04/21/2024 at 09:09 AM
To: Mel JB (First Viewed: Never)
See M ’s calls to you this morning. You did not answer.
Message 4 of 14
Sent: 04/22/2024 at 08:16 AM
See attached M ’s calls to you today. You did not answer.
Page 1 of 3
Message 5 of 14
Sent: 04/25/2024 at 01:31 PM
See attached M ’s calls to you this morning! You did not answer.
Message 6 of 14
Sent: 04/28/2024 at 09:09 AM
See attached M ’s calls to you this morning. You did not answered
Message 7 of 14
Sent: 04/29/2024 at 08:21 AM
Subject: Missed FaceTime calls
See attached M ’s calls to you this morning. You did not answer
Message 8 of 14
Sent: 05/02/2024 at 05:13 AM
See attached M ’s calls to you this morning. You did not answer
Message 9 of 14
Sent: 05/08/2024 at 04:51 AM
See M ’s calls to you this morning. You did not answer.
Page 2 of 3
Message 10 of 14
Sent: 05/09/2024 at 05:18 AM
See M ’s calls to you this morning, you did not answer.
Message 11 of 14
Sent: 05/10/2024 at 12:34 PM
See below M ’s calls to you this morning. You did not answer again.
Message 12 of 14
Sent: 05/12/2024 at 09:19 AM
Me_Motha_96.jpeg (239 KB)
See attached M ’s calls to you from yesterday AND today on Mother’s Day. You did not answer again. This the 5th day in row of not answering
her calls.
Message 13 of 14
Sent: 05/13/2024 at 05:01 AM
See attached M ’s calls to you this morning. You did not answer. Day 6 of not answering.
Message 14 of 14
Sent: 05/17/2024 at 08:15 AM
Attachments: Screenshot_2024-05-17_at_7.54.58_AM_1.jpeg (239 KB)
See attached M ’s calls to you this morning. You did not answer.
Page 3 of 3
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

Family Division
Stanley Mosk Dept. - 64
BD656090
MELANIE BROWN VS STEPHEN BELAFONTE
December 13, 2022
8:30 AM
Honorable Mark A. Juhas, Judge
Mary Arnold, Judicial Assistant Not Reported, Court Reporter
NATURE OF PROCEEDINGS: Proposed Ex Parte RFO Emergency Orders for Support filed by
Respondent on December 13, 2022
The following parties are present for the aforementioned proceeding:
No Appearances
The matter is not called for hearing.
The Court, having read and considered the pleadings filed in this matter, makes the following orders:
The Court sets a hearing on January 11, 2023 at 8:30am in Department 64. Respondent shall serve
Petitioner with her papers by noon on December 14, 2022. Respondent shall file and serve any opposition by
December 30, 2022. Any reply will be filed and served by January 3, 2023.
A. Orders relating to Appointment of Minor’s Counsel to Assist M with Immediate:
An order pursuant to Family Code Section 3150(a) and California Rule of Court, Rule 5.240 (b), the Court
appoints minor’s counsel for the minor child, M B (hereinafter “M ”), with the first
available of the following proposed minor’s counsel ordered as appointed minor counsel upon confirmation of
availability: Sonia Dujan or Cynthia Glasser. The Court reserves over payment of minor’s counsel fees.
Upon confirmation of appointment and filing of a Judicial Council Form FL-323, minor’s counsel shall
promptly communicate with M ,M ’s Court-appointed therapist, Karin Manger, L.C.S.W, the
parties, and any other individuals counsel deem appropriate and necessary to investigate the best interests of
M .
Minor’s counsel is to hold the psychotherapist-patient privilege on behalf of the minor child; the limited waiver
of same ordered on May 23, 2018 allows Ms. Manger to communicate with parties’ counsel shall remain in
place and extend to minor’s counsel as well.
B. Orders relating to M ’s Ability to Communicate with Respondent, Ms. Manger, and Minor’s
Counsel while in Petitioner’s Care:
Minute Order Page 1 of 2

Case 1:24-cv-22045-XXXX Document 1-11 Entered on FLSD Docket 05/29/2024 Page 34/26/24,
Gmail - my crazy mother of 123:27 PM
Ian watching p!!!!
Sent from my iPhone
On 24 Feb 2012, at 09:20, Melanie Brown < > wrote:
[Quoted text hidden]
https://mail.google.com/mail/u/3/?ik=c764e6cb7c&view=pt&search=a…simpl=msg-f:1394659717671401510&simpl=msg-f:1394660766029165653 Page 3 of 3
of 123:30 PM
Gmail - FW: FYI - Mel B's Family Feud Deepens After They Accuse The 'X Factor' Star Of Bending The Truth About Her Tough Upbringing
Mel B and her mum, Andrea, pictured in 1997
Mel said: “I grew up in Harehills.”
Before Kayleigh added: “The place where I come from gets quite a bad name. But Mel B was brought
up in the same area so it makes you realise people from that place can still make it and get
somewhere.”
of 123:30 PM
Gmail - FW: FYI - Mel B's Family Feud Deepens After They Accuse The 'X Factor' Star Of Bending The Truth About Her Tough Upbringing
But Mel's mum Andrea blasted her daughter's claims, revealing she actually grew up in a semi-
detached house in a completely different part of town.
“Melanie was brought up in Harehills? Well, that’s news to us. It’s always been Kirkstall, the other
side of town," she told The Mirror.
Mel's sister Danielle, added: “That’s what happens when you forget your roots. I might start saying I
grew up in Buckingham Palace.”
Mel B and her sister Danielle in happier times
The former Scary Spice became estranged from her mother Andrea, father Martin and sister
Danielle in 2008 after she renewed her wedding vows with husband Stephen Belafonte, who they
blamed for taking Mel away from her family.
Mel has previously admitted to living in a different part of Leeds during the filming of the 2009
documentary, 'Seven Days On The Breadline', which saw her living with a family in Harehills.
She said: “I knew a little about what to expect in Harehills because it’s always had a tough
reputation.
“Despite the fact I was born in Leeds and grew up on another council estate in the city, I was
shocked at the level of deprivation and the absence of hope I found when I went back to Harehills for
the first time in about 20 years.”
Last week, Mel showed off her incredible bikini body on a romantic break with husband Stephen in
Mexico...
Case 1:24-cv-22045-XXXX Document 1-11 Entered on FLSD Docket 05/29/2024 Page 10 of
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Stephen Belafonte v. Melanie Janine Brown (Mel B - Scary Spice)

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Case 1:24-cv-22045-XXXX Document 1 Entered on FLSD Docket 05/29/2024 Page 1 of 48

IN THE UNITED STATES DISTRICT COURT

v. Civil Action No. ____________________

MELANIE JANINE BROWN,

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

Plaintiff, STEPHEN BELAFONTE (“Mr. Belafonte” or “Plaintiff”), by and through his

trafficking, and illegal gun possession.

2. The long-brewing harassment orchestrated by Ms. Brown began with a fraudulent

5. Defendant’s relentless attacks have been calculated to ensure maximum coverage

6. Following a ten-year, tumultuous marriage, during which Ms. Brown repeatedly

maintain a good relationship with his daughter, “M.B.”

rejection of M.B.’s phone calls.

toward charity work:

written to profit from those lies.

eat in an effort to manipulate the child protection system.

incessant and relentless media appearances and interviews.

15. Specifically, in 2018, Defendant published false and defamatory statements

17. The wrongful publications of the defamatory statements by Defendant, which

continue to harm Mr. Belafonte.

18. As a result of Defendant’s defamatory statements, Mr. Belafonte has received

Belafonte seeks injunctive relief, corrective relief, and monetary damages.

20. Mr. Belafonte is an individual residing in Miami, Florida.

Leeds, United Kingdom.

JURISDICTION AND VENUE

interest, costs, and attorneys’ fees.

reputational damage while a resident and citizen of Florida.

24. Further, at the time of publication of the defamatory statements and

disseminated in the worldwide media, including throughout Florida.

people throughout the world, including in the State of Florida.

parties in the State of Florida.

27. Defendant willfully, purposefully, and intentionally directed her defamatory

and destroy Mr. Belafonte’s reputation.

notions of fair play and substantial justice.

Belafonte’s reputation occurred in Miami-Date County, Florida.

FACTS RELEVANT TO ALL CLAIMS

“Beatlemania,” the fanaticism surrounding the Beatles.

shows, tabloids, and gossip columns.

satisfaction of a settlement reached in that lawsuit.5 A screenshot of a portion of the widely

with Ms. Gilles is reproduced directly below:

Ms. Brown would propagate such false statements.6

efforts to stop drinking.

outrageous and calculated to cause Mr. Belafonte severe emotional distress.

emotional distress. By way of example, and not

limitation, screenshots of text conversations, showing a pattern of harassment inflicted by Ms.

Brown, are reproduced directly below:

photographed by paparazzi in a public setting in London in what appeared to be an extramarital

feely-hardman-actor-Tamer-Hassan.html. The publications of these photographs—which Ms.

Belafonte’s trust in their marriage was irreparably broken.

housing upon his court-ordered removal from their marital home.

the TRO declaration is recounted as follows:

a medically unnecessary injection because of my fear of [Mr. Belafonte] and what

he would do if I did not cover for him.”

b. But the so-called attack was a complete fabrication, as demonstrated by

contemporaneously taken photographs, including ones taken by paparazzi the

making a TV appearance on “Good Afternoon America” July 27, 2012 with no

and a screenshot of the April 2013 Instagram post.

c. The totally fabricated incident, cunningly incorporating the highly famous

declaration to become widely published in gossip columns and similar

Entertainment Tonight, Daily Mail, The Sun, and Us Weekly.

Mr. Belafonte severe emotional distress.

perpetuated by Defendant about Mr. Belafonte.

the following link: < https://www.youtube.com/watch?v=r6xWu4xaKTg>.

face bloodied and bruised by make up as it appears in the video.

Mr. Belafonte caused the injuries depicted in the photograph.