In a complaint filed Friday in Los Angeles Superior Court, Simmons asked the court for a judicial declaration that no assault took place and that ESPN makeup artist Victoria Jackson did not suffer any damages or injuries attributable to him. Simmons, who has no idea who Jackson is, categorically denies her allegations.

Jackson's allegations involve an appearance by the KISS front man on ESPN SportsCenter last November. Simmons, along with KISS' drummer, Eric Singer, appeared on the show in full KISS costume and make-up just before a KISS concert at Los Angeles' Staples Center on the evening of November 24, 2009.

Two months later, Simmons' received a letter from an attorney claiming to represent Ms. Jackson alleging that Simmons accosted her during his brief visit to the ESPN studios. The letter went on to accuse Simmons of supposedly "humping" Ms. Jackson "to the extent that she could feel [him]…grinding into her," and that as a result she "suffered from humiliation, shame, embarrassment, anger, anxiety, loss of sleep and depression." In a follow-up email to Simmons' attorney, Barry E. Mallen of the Los Angeles' law firm Manatt, Phelps & Phillips, Jackson's lawyer demanded that Simmons pay Jackson $185,000 by May 14, 2010 in order to avoid a lawsuit.

In fact, as Simmons' complaint notes, Simmons and Singer were at the ESPN studios for only a few minutes before their appearance on SportsCenter and both were in full costume. Simmons' complaint further points out that Jackson's claim is particularly unbelievable given that Simmons' heavy costume is like a suit of armor, particularly around his groin area, making it impossible for Simmons to have done the kind of grinding that Jackson claims to have experienced.