1. 4:08-cv-02753-TLW -TER Date Filed 07/19/10 Entry Number 134 Page 1 of 11
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF SOUTH CAROLINA
FLORENCE DIVISION
Howard K. Stern, as Executor of the ) Civil Action No. 4: 08 - CV -2753 - TLW
Estate of Vickie Lynn Marshall, a/k/a )
Vickie Lynn Smith, a/k/a Vickie Lynn )
Hogan, a/k/a Anna Nicole Smith, )
)
Plaintiffs, )
) ANSWER OF STANCIL SHELLEY,
vs. ) A/K/A FORD SHELLEY AND GINA
) THOMPSON SHELLEY TO FIRST
Stancil Shelley, a/k/a Ford Shelley, G. ) AMENDED COMPLAINT
Ben Thompson, Gaither Bengene )
Thompson, II, Melanie Thompson, Gina )
Thompson Shelley, Susan Brown, and The )
Law Offices of Susan M. Brown, P.C., )
)
Defendants.
The defendants Stancil Shelley, a/k/a Ford Shelley and Gina Thompson Shelley,
answering the First Amended Complaint of the plaintiff herein would show unto this
Honorable Court as follows:
FOR A FIRST DEFENSE
1. Each and every allegation not hereinafter specifically admitted, denied or
explained is denied.
FOR A SECOND DEFENSE AND BY WAY OF ANSWER
2. Defendants admit upon information and belief the allegations of Paragraphs 1
and 2.
3. Admit the allegations of Paragraph 3 through 7.

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4. Admit upon information and belief the allegations of Paragraphs 8 and 9.
5. Answering Paragraph 10, these defendants would admit that Brown was at
certain times the authorized agent of Ben, Gaither or Melanie.
6. These answering defendants have insufficient information and belief to admit
or deny the allegations of Paragraph 11 and therefore deny the same and demand strict proof
thereof.
7. The allegations of Paragraph 12 state a conclusion of law and therefore no
response is required. To the extent a response is required, the defendants have insufficient
information and belief to admit or deny and therefore deny and demand strict proof thereof.
8. Admit the allegations of Paragraphs 13 – 17.
9. Admit upon information and belief the allegations of Paragraphs 18 – 20
10. Admit the allegations of Paragraph 21.
11. Admit upon information and belief the allegations of Paragraph 22.
12. Answering Paragraphs 23 -25, these defendants admit only so much of the
allegations as allege that Brown and the Law Firm are subject to the jurisdiction of this Court;
these defendants specifically deny any allegations as to a conspiracy.
13. Admit the allegations of Paragraphs 26 and 27.
14. The allegations of Paragraph 28 set forth conclusions of law and therefore, no
response is necessary. To the extent a response may be required, the defendants have
insufficient information to admit or deny, and therefore, the allegations are denied and strict
proof demanded thereof.
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15. Admit the allegations of Paragraphs 29 and 30.
16. The allegations of Paragraph 31 set forth conclusions of law and therefore, no
response is necessary. To the extent a response may be required, the defendants have
insufficient information to admit or deny, and therefore, the allegations are denied and strict
proof demanded thereof.
17. Answering Paragraph 32, these defendants would show that Ms. Smith was
living in the Bahamas in a property known as the Horizons at the time of her death. All other
allegations of Paragraph 32 are denied.
18. Admit the allegations of Paragraphs 33 and 34.
19. Answering Paragraph 35, these defendants would show that they were aware
that an eviction notice was to be served but have no personal knowledge as to the circumstances
of the service.
20. Admit the allegations of Paragraph 36.
21. The defendants have insufficient information and belief to admit or deny the
allegations of Paragraph 37 and therefore, deny the same and demand strict proof thereof.
22. Upon information and belief, these defendants admit the allegations of
Paragraph 38.
23. These defendants have insufficient information to admit or deny the
allegations of Paragraph 39 and, therefore, deny the same and demand strict proof thereof.
24. Answering Paragraph 40, these defendants would show that the dispute with
Ms. Smith became publicized but would deny that publicity was instigated by the defendants.
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These defendants would admit that a press conference was held in November, 2006. All other
allegations are denied.
25. Answering Paragraph 41, these defendants would admit appearance on FOX
but deny the appearance was to publicize the contentious dispute with Ms. Smith.
26. Deny Paragraph 42.
27. Answering Paragraph 43, these defendants deny the entry into Horizons was
wrongful.
28. Answering Paragraphs 44 and 45, these defendants would admit they were
aware of the Injunction but deny the Injunction was enforceable at the time after Ms. Smith's
death.
29. Deny Paragraph 46.
30. Admit Paragraphs 47 and 48.
31. Answering Paragraph 49, defendants deny entering without authorization.
Further, defendants admit that certain items were taken for safekeeping. Defendants deny all
other allegations.
32. Denies Paragraph 50 and 51.
33. Answering Paragraph 52, these defendants would show that they had tacit
permission to enter and remove property from the premises.
34. Answering Paragraph 53, defendants would admit to removing some of the
personal property listed, but not all of the personal property listed. Defendants deny any
wrongdoing in securing the property.
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35. Answering Paragraphs 54, 55 and 56, these defendants would admit to
obtaining these items but would deny that such items were taken without authorization.
36. Answering Paragraphs 57, 58 and 59, these defendants do not know if these
items were among those secured, but would deny if they were that they were taken without
authorization.
37. Answering Paragraphs 60 and 61, these defendants would admit that such
items were secured but would deny that such items were taken without authorization.
38. Paragraph 62 is denied.
39. Answering Paragraph 63, these defendants would admit that Shelley secured
some items but would deny that he assumed, asserted, and exercised dominion, ownership or
control over such items but rather secured them.
40. Deny Paragraph 64.
41. Admit the allegations of Paragraphs 65-69.
42. Deny the allegations of Paragraph 70, 71 and 72.
43. Answering Paragraph 73, these defendants would show that the Clown video
was provided only to FOX News.
44. Deny the allegations of Paragraph 74.
45. Deny the allegations of Paragraph 75.
46. Upon information and belief, admit the allegations of Paragraph 76.
47. Deny the allegations of Paragraphs 77, 78 and 79.
48. Admit Paragraph 80.
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49. These defendants have insufficient information and belief to admit or deny the
allegations of Paragraphs 81 through 89 and, therefore, deny the same and demand strict proof
thereof.
50. Admit Paragraphs 90 and 91.
51. Answering the allegations of Paragraphs 92-100, these defendants have
insufficient information and belief to admit or deny the allegations of these Paragraphs and
therefore deny the same and demand strict proof thereof.
52. Admit the allegations of Paragraphs 101 – 107.
53. Answering Paragraphs 108-121, these answering defendants have
insufficient information and belief to admit or deny the allegations and therefore deny the same
and demand strict proof thereof.
54. Admit Paragraph 122.
55. These defendants have insufficient information and belief to admit or deny the
allegations of Paragraphs 123-131 and therefore deny the same and demand strict proof thereof.
56. Admit Paragraph 132.
57. Deny Paragraphs 133-139.
58. Admit upon information and belief the allegations of Paragraph 141.
59. Admit Paragraphs 142 and 143.
60. Deny the allegations of Paragraphs 144 and 145.
61. These defendants have insufficient information and belief to admit or deny the
allegations of Paragraph 146 and therefore deny the same and demand strict proof thereof.
62. Admit Paragraphs 147 and 148.
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63. Answering Paragraph 149, Howard Stern requested return of items.
Defendants have insufficient information and belief as to his status and deny the same and
demand strict proof thereof.
64. Answering Paragraph 150, these defendants would show that they secured
certain items and turned them over to legal authorities within three days which included
computers, hard drive, and tapes and miscellaneous papers which constituted the majority of the
items secured. Defendants would further show that the items were taken with tacit permission.
Defendants deny all other allegations.
65. Admit Paragraphs 151 and 152.
66. These defendants have insufficient information or belief to admit or deny the
allegations of Paragraph 153 and, therefore, deny the same and demands strict proof thereof.
67. These defendants have insufficient information or belief to admit or deny the
allegations of Paragraph 154 and, therefore, deny the same and demands strict proof thereof.
These defendants specifically deny that the items were taken without permission.
68. These defendants have insufficient information or belief to admit or deny the
allegations of Paragraph 155 and, therefore, deny the same and demands strict proof thereof.
69. These defendants have insufficient information or belief to admit or deny the
allegations of Paragraph 156 and, therefore, deny the same and demand strict proof thereof.
70. Denies Paragraphs 157 and 158.
71. Answering Paragraph 159, these defendants would deny that the items were
taken without authorization. Defendants admit that not all items secured were turned over to
Horry County.
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72. Answering Paragraph 160, defendants admit that Stern has made numerous
demands but these defendants would show that all items have been turned over to either legal
authorities, Mr. Birkhead, or the Estate.
73. Admit the allegations of Paragraphs 161 and 162.
74. Answering the allegations of Paragraph 163, Defendants admit some items
were given to Mr. Birkhead. All other allegations are denied.
75. Admit Paragraph 164.
76. Answering Paragraph 165, these defendants would show that it delivered
various items to Mr. Birkhead but deny the remaining allegations.
77. Answering Paragraph 166, these defendants admit that Shelley did not
surrender to Mr. Birkhead all the personal property but would deny that such property was
taken without authorization.
78. Denies Paragraph 167.
79. Admits Paragraph 168.
80. Answering Paragraph 169, admit that certain property was turned over to
Stern's counsel but denies that such property had been taken without authorization.
81. Answering Paragraph 170, defendants admits that the property turned over to
Mr. Stern did not include property that had been turned over to Mr. Birkhead or various legal
authorities. Defendants specifically deny that such property was taken without permission.
82. These defendants have insufficient information and belief to admit or deny the
allegations of Paragraphs 171 and 172 and therefore, deny the same and demand strict proof
thereof.
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83. Admit Paragraph 173.
84. These defendants have insufficient information and belief to admit or deny the
allegations of Paragraphs 174-177 and therefore, deny the same and demand strict proof thereof.
85. Admit Paragraph 178.
86. These defendants have insufficient information and belief to admit or deny the
allegations of Paragraph 179 and therefore, deny the same and demand strict proof thereof.
87. Admit Paragraph 180.
88. These defendants have insufficient information and belief to admit or deny the
allegations of Paragraphs 181 and 182 and therefore, deny the same and demand strict proof
thereof.
89. Admit Paragraphs 183 and 184.
90. These defendants have insufficient information and belief to admit or deny the
allegations of Paragraphs 185-189 and therefore, deny the same and demand strict proof thereof.
91. Admit Paragraphs 190.
92. These defendants have insufficient information and belief to admit or deny the
allegations of Paragraph 191 and therefore, deny the same and demand strict proof thereof.
93. Deny the allegations of Paragraph 192 and 193.
94. Answering Paragraph 194, these defendants re-allege the foregoing defenses
as if repeated herein verbatim.
95. Denies Paragraph 195 – 212.
96. Answering Paragraph 213, these defendants re-allege the foregoing defenses
as if repeated herein verbatim.
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97. Denies Paragraphs 214-223.
98. Answering Paragraph 224, these defendants re-allege the foregoing defenses
as if repeated herein verbatim.
99. Deny Paragraphs 225 and 226.
100. Admit Paragraph 227.
101. The allegations of Paragraph 228 constitute a legal conclusion to which
no response is required; to the extent a response is required, the allegations are denied.
102. Deny Paragraphs 229-233.
103. Answering Paragraph 234, these defendants re-allege the foregoing
defenses as if repeated herein verbatim.
104. Deny Paragraphs 235-239.
105. Answering Paragraph 240, these defendants re-allege the foregoing
defenses as if repeated herein verbatim.
106. Deny Paragraphs 241-247.
107. Answering Paragraph 248, these defendants re-allege the foregoing
defenses as if repeated herein verbatim.
108. Deny Paragraphs 249-255.
109. Answering Paragraph 256, these defendants re-allege the foregoing
defenses as if repeated herein verbatim.
110. Deny the Paragraphs 257 – 259.
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FOR A THIRD DEFENSE
111. Defendants plead the statute of limitations as a defense and bar to this
action.
WHEREFORE, having fully answered the Complaint of the plaintiff, the
defendants prays that the Complaint be dismissed, and for such other and further relief as the
Court may deem just and proper.
NELSON MULLINS RILEY & SCARBOROUGH LLP
By:
Susan P. MacDonald
Federal Bar No. 984
E-Mail: susan.macdonald@nelsonmullins.com
3751 Robert M. Grissom Parkway / Suite 300
Post Office Box 3939 (29578-3939)
Myrtle Beach, SC 29577-3165
(843) 448-3500
Attorneys for Defendants Stancil Shelley a/k/a Ford Shelley
and Gina Thompson Shelley
Myrtle Beach, South Carolina
July 19, 2010
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