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In the motion, Clem's attorneys noted that beyond her being identified in the video, there is nothing in Hogan's allegations to prove she "at any time had custody or control" of the tape, no allegation involving her as to when the video may have been given to a "third party" and how it landed in Gawker's hands, etc. Basically, she is saying that since there is no direct proof or link that she was involved with the video landing out there publicly, there's no cause for Hogan to sue her for damages.
Clem's attorneys also noted that many of Hogan's claims would fail under Florida law since there is no strong proof that she was involved in any way beyond appearing on the video.
Hogan is seeking $100 million in damages and is attempting to have the video removed from Gawker.
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