Kelley Lynch<kelley.lynch.2010@gmail.com> |  Tue, Oct 23, 2012 at 6:13 PM
| ||||||||||||||||||||||||||
| To: "Francisco.A.Suarez" <Francisco.A.Suarez@verizon.net>, Dennis <Dennis@riordan-horgan.com>, *IRS.commissioner@irs.gov, Washington Field <washington.field@ic.fbi.gov>, "Kelly.Sopko" <Kelly.Sopko@tigta.treas.gov>, ASKDOJ <ASKDOJ@usdoj.gov>, "Doug.Davis" <Doug.Davis@ftb.ca.gov>, rbyucaipa <rbyucaipa@yahoo.com>, Robert MacMillan <robert.macmillan@gmail.com>, moseszzz <moseszzz@mztv.com>, a <anderson.cooper@cnn.com>, wennermedia <wennermedia@gmail.com>, "Hoffman, Rand" <rand.hoffman@umusic.com>, woodwardb <woodwardb@washpost.com>, "harriet.ryan" <harriet.ryan@latimes.com>, "hailey.branson" <hailey.branson@latimes.com>, "glenn.greenwald" <glenn.greenwald@guardiannews.com>, lrohter <lrohter@nytimes.com>, "stan.garnett" <stan.garnett@gmail.com> | |||||||||||||||||||||||||||
Reply | Reply to all | Forward | Print | Delete | Show original
| |||||||||||||||||||||||||||
Francisco,
Here is my Motion to Quash Cohen's fraudulently obtained Boulder restraining order. You cannot obtain judgments, orders, and verdicts via fraud, perjury, lies, and concealment. His perjury - which I read in his declaration AFTER the hearing - is addressed in this Motion. I should have defaulted into the Motion to Quash because he didn't respond. Who knows what these judges are thinking. I have heard that Cohen/Kory contacted Boulder PD, LAPD, and S&MPD about me. That's what my lawyer, David Moorhouse (in Boulder), thought. He also thought the DA of Los Angeles had the power and motive to take me to King Drew. The entire file is falsified. Chris/Homeland Security also appeared to think the Los Angeles DA had the power or motive to bring a SWAT team and have me taken to Killer King. I was questioned about Phil Spector en route. This is addressed in my letter to Alan Jackson. No respsonse to that - apart from their appearance in my trial. See the transcripts. And then, Cooley's deranged attempt to obtain a restraining order via a satirical email (concealed in part from the court) via Captain Jack Horvath's LIE that I contacted them in 2007. Horvath is an investigator. This is not the entire Motion to Quash but it will give you a good overview. The exhibits are not attached but were filed. The legal issues my lawyers were dealing with (via Cohen's lawyers) have come a long way. It was, at that time, about money owed me. After reading the Motion to Vacate Cohen's lawsuit (that Gianelli and others threatened me over via non-verifiable warrants that may not relate to me and one that was dismissed) and this Motion to Quash Cohen's fraudulently obtained order in Colorado should give you a good idea of what is going on and the extent of the perjury, fraud, concealment, lies, and the tactics Cohen and others have used to destroy me. But, Judge Vanderet thinks no one should be targeted. Who knows what is wrong with the man. Maybe he was just impressed with another Hollywood fraud - to quote Boies Schiller. All the best, Kelley Motion To Quash Cohen's Fraud - Boulder, Colorado BOULDER COUNTY COURT Boulder Justice Center 1777 Sixth Street Boulder, Colorado 80306 LEONARD NORMAN COHEN, Plaintiff vs. Case No. C0072008C 000776 KELLEY ANN LYNCH, Defendant MOTION TO QUASH PLAINTIFF'S PROTECTIVE ORDER Defendant Kelley Lynch moves the Court to quash Plaintiff's fraudulent yet Permanent Civil Protection Order issued pursuant to Section 13-14-102 C.R.S. on the grounds that Plaintiff committed perjury in his fraudulent and falsified Declaration submitted to the Court and because Defendant was not properly served the Verified Complaint/Motion for Civil Protection Order and the Temporary Protection Order. After recently reviewing the Court records, Defendant learned that process server, Karl Scharck, filed a Return of Service on August 26, 2008 stating he served the Verified Complaint/Motion for Civil Protection Order and the Temporary Protection Order by leaving it with Defendant who refused service. This is an outright lie. The process server entered private property, without permission, and did not attempt to contact Defendant. He pounded on the door and shoved the document under the door. Defendant had a witness present. Due to the fraudulent proof of service Defendant maintains that the Court does not at this time have jurisdiction. She has attempted to ask Springer and Steinberg if they would like to serve her properly or reschedule a new hearing but has heard nothing back. Defendant has authorized Cohen, through Springer and Steinberg, to serve Yongzin Rinpoche on her behalf. For the record, Defendant did promise the Court that she would not contact Springer and Steinberg but that was prior to learning that the process server perjured himself. It was also prior to reading through the lies in Plaintiff Leonard Norman Cohen's Declaration – proving to Defendant that he has no respect, whatsoever, for any Court of law and will perjure himself whenever it works to his benefit. Furthermore, Defendant is representing herself and feels that all efforts to prevent her from communicating about legal and/or tax matters is illegal, unconstitutional, and violates her rights to freedom of speech and due process of law. The Declaration of Leonard N. Cohen marked as Exhibit A in the Court records appears to be an entirely falsified and fraudulent document and proves that Cohen is actually monitoring Defendant. This is an Internal Revenue Service matter because Defendant went to the Internal Revenue Service after her lawyers and accountant confirmed that Cohen and his advisers committed civil criminal tax fraud. Since being told that she was exposed to criminal tax fraud and used as an unwitting pawn, Plaintiff’s attempts to crush, destroy, silence, and terrorize her have been relentless. He has also targeted her children and parents. These are my responses to the fraudulent statements in Cohen's Declaration: 1. Defendant was Leonard Norman Cohen's personal manager and personal assistant for approximately seventeen (17) years. I was never Cohen's business manager and he is well aware of that. Plaintiff has had business managers – such as Rich Feldstein – over the years. He has had many advisers and all attempts to turn Defendant into something she was not won't address his disdain for taxes. 2. Cohen has a pattern of blaming his advisers and employees for things they have not done – some examples of his pattern of blaming others include blaming Marty Machat, after his death, for his tax fraud; alleging that his first managers (Mary Martin and Judy Berger) stole the publishing to his songs "Suzanne," "Dress Rehearsal Rag," and "Story of Isaac;" blaming his tour manager, Geoff Clennell, of stealing from him on "The Future" tour; blaming Phil Spector for drowning his vocals; blaming Jorge Calderon and Steve Meador (musicians on one of his tours) for sabotaging his band; blaming Jennifer Warnes for giving away 1/3 of the song “Song of Bernadette” to someone who only wrote or played a chord on the piano; and, generally lying for his own self-serving reasons. Defendant had nothing to do with his complex corporate structures and elaborate tax planning, off-shore accounts, Swiss bank account, abandoned green card, various social security numbers, and possible residence issues in Canada. These issues are at the very heart of this matter and explain the lengths Plaintiff has gone in his attempts to "silence," crush, terrify, and destroy Defendant and her family. Defendant would like to point out to the Court that she had a day job – serving as Cohen's personal manager, personal assistant, and family slave – and he had professional advisers handling the corporate structures and tax matters. Those advisers included – but were not limited to: Neal Greenberg, Richard Westin, Arthur Indursky, Don Friedman, Stuart Fried, the Grubman Indursky firm, Greg McBowman, Ken Cleveland, Reeve Chudd, Peter Lopez, Peter Shukat, Jonas Herbsman, Steve Blanq, the Hochman Rettig firm, Burt Goldstein, and others. Cohen, Greenberg, and Westin were wrapped in attorney/client privilege – essentially leaving Defendant in the dark. Defendant's Mother was actually fired after Defendant and Plaintiff attended an event for the tribute album she put together for him – he was furious that Defendant refused to have sex with him in Toronto. Defendant's Mother can testify to this fact and believes Cohen – who was never Defendant's lover (regardless of his lies to the news media) – has been especially malicious and vindictive with Defendant because of his obsession with her for so many years. Defendant has first-hand personal knowledge and experience of that "obsession." Perhaps this is why he lied to her young son's "father" about her having had sex with Oliver Stone and Richard Rutowski – two men who can take the stand and testify that those allegations are outright lies and do not really address the very serious issues of tax fraud that have been raised. Yongzin Rinpoche can testify to the fact that he was present when Cohen's tax lawyer, Richard Westin, visited Defendant in Los Angeles. At that time, Yongzin Rinpoche advised Defendant that Westin was a pain in the ass and to get rid of him. Cohen's allegation that she had sex with his tax lawyer to get a private annuity obligation, that was extinguished from the 2003 tax return – without Defendant’s understanding or knowledge, is absurd and outrageous. 3. Defendant was not terminated for cause and no termination was ever discussed. After receiving a tax notice relating to Defendant’s 2001 return, changing accountants, hiring lawyers, and being advised that she had been dragged into tax fraud, Defendant refused to meet with Leonard Norman Cohen and his tax lawyer (Richard Westin) in order to unravel certain entities. Defendant also refused to bring the corporate books, records, assignments, stock certificates, etc. to any meeting and this seemed to pave the way for the abusive and malicious tactics that have been used against her and her family – presumably to prevent her from going to the Internal Revenue Service and other agencies, to undermine my credibility, and prevent Defendant from testifying against Cohen and his advisers. This is precisely what Defendant intends to do. The emails to the IRS Commissioner's Staff and others have documented what Defendant and her family and friends have gone through since Defendant was advised that she was used as an unwitting pawn and exposed to Cohen's criminal tax fraud. These emails and Ann Diamond’s article posted on her public website lead to the fraudulent restraining order and nothing else whatsoever. Defendant had no idea that Cohen was even in the country and does not believe making a good faith attempt to determine what has happened and where her assets have gone, etc., can possibly be construed as harassment. Exhibit A - Ann Diamond’s Draft Article. 4. Defendant has repeatedly asked for a complete and proper forensic accounting, and other documentation and explanations, from Cohen and his advisers. The "ledger" attached to Cohen's fraudulent suit against Defendant in Los Angeles Superior Court is incomplete and missing a tremendous amount of back-up documentation and conveniently omits assets owned by Defendant. Exhibit B – Dale Burgess' Fax to Dianne DiMascio & Kelley Lynch dated February 3, 2003. 5. Cohen took loans from Traditional Holdings, LLC that were to be repaid within three (3) years at 6% interest. Robert Kory wrote Defendant's advisers asking if Defendant would forgive these loans. Defendant will not forgive Cohen's debt to Traditional Holdings, LLC and views every single distribution – regardless of how it is characterized – as a debt that should be repaid at 6% interest by Cohen. Defendant also intends to hold Neal Greenberg and Richard Westin personally responsible for permitting the assets of Traditional Holdings, LLC to be wasted. They both apparently understood that Cohen’s level of borrowing was dangerous to the structure itself. Cohen and his advisers are aware that the income from the sale to Sony of certain assets (that were never transferred into Traditional Holdings, LLC) was not reported on the 2001 federal income tax return; the promissory note Defendant signed and had notarized was extinguished from the 2002 tax return; and, the private annuity obligation was extinguished from the 2003 tax return. This was done by Cohen's advisers for Cohen's benefit without Defendant’s knowledge. She believes the Traditional Holdings' "scheme" was conjured up by Cohen, Greenberg, and, Westin – primarily – who understood Enron's empty shell companies and the "Bowie Bond" concept. The plan seems to have been to roll Traditional Holdings, LLC back into LC Investments, LLC. Defendant could not have breached any fiduciary duty because it was extinguished and would not have arisen until 2011 in any event. Furthermore, Defendant acted solely in accordance with Cohen and his advisers' instructions and advice. Exhibit C - DiMascio Letter to Kory dated December 17, 2004. Defendant has been advised that Cohen's transaction fees – in connection with the Sony sale (paid for by Traditional Holdings) totaled approximately 30% and views those fees as outstanding debt. Defendant was told that the penalties and interest with respect to the tax fraud – on three (3) entities – approximated $30 million as of the fall of 2004. Defendant was offered 50% community property, palimony, 30% royalties – based on her ownership interest and commissions, other reimbursements, and asked to participate in what she believes was an illegal mediation – presumably to lie and say Cohen was defrauded by his advisers. There was also some discussion – between Dale Burgess and Robert Kory – about $10,000 a month walking around money for Defendant. That was not Defendant's experience or perception and she refused to participate deciding instead to pay her own outstanding taxes (as instructed by her CPA) for the years 2001 through 2003 and report the tax fraud to the Internal Revenue Service. Fortunately, Cohen is on a worldwide tour – reportedly making approximately $2 million per concert (not including record royalties, merchandising, publishing, performance income, etc.) – and will now have the assets to pay all debts, tax payments, and can reimburse Defendant the commissions, royalties, ownership interest in certain entities, and so forth, owed her. Defendant will separately address issues relating to wrongful termination, fraud, conversion, intentional tort, etc. when she is able to speak with Bruce Cutler. Boies Schiller informed Defendant that she has a $15 million suit against Cohen relating to these issues. Exhibit D - Lynch Email to DiMascio & Berardo dated April 13, 2005. 6. Defendant firmly believes that she was defrauded by Cohen because she owned 99.5% of Traditional Holdings, LLC and 15% of Blue Mist Touring Company, Inc. Defendant was never a trustee on these entities but rather has corporate books and records, assignments, documentation, and stock certificates proving her ownership interests. Lynch is in possession of an email from Richard Westin advising her that he believed she was entitled to 15% ownership interest in Old Ideas, LLC when he formed that entity. Westin also emailed Lynch that he never represented her and confirmed that Traditional Holdings, LLC was a valid entity with a real private annuity obligation. Unfortunately, Westin emailed that to Lynch after extinguishing the annuity obligation from the tax return. Defendant has amended and filed final tax returns for Traditional Holdings, LLC in order to prevent Cohen and his advisers from doing anything further in her name. She has asked the IRS Commissioner’s Staff to determine precisely what should have been done on all tax returns relating to Traditional Holdings, LLC, Blue Mist Touring Company, Inc., LC Investments, LLC, and Old Ideas, LLC – and to calculate the taxes that should have been paid and all penalties and interest. 7. Defendant was never a partner on the entity known as LC Investments, LLC and there are no corporate documents proving otherwise. The Internal Revenue Service advised Defendant that K1s had been issued to her for the years 2004 and 2005 by LC Investments, LLC. There was also a K1 issued to her in the State of Kentucky by this entity. Defendant maintains that these were illegally issued as she was never a partner. Nevertheless, Defendant intends to claim 99.5% of LC Investments, LLC as her rightful property due to the actions of Cohen and his advisers. Exhibit E - K1s issued by LC Investments, LLC to Cohen and Lynch and Westin Letter to State of Kentucky dated October 6, 2004. 8. Defendant refused to enter an appearance in Cohen's fraudulent lawsuit against her in Los Angeles Superior Court. She advised Cohen, his lawyers, and others that she was not served the lawsuit, refused to participate in fraud, and had been advised that Cohen had committed civil and criminal tax fraud. Defendant believes that lawsuit was brought solely due to the fact that she went to the Internal Revenue Service and State of Kentucky regarding Cohen's tax fraud – that may extend to two countries (the United States and Canada) and may go back to at least 1977 in the United States. A 1977 tax memo exists advising Cohen not to pay taxes anywhere he has a residence but cautioning him not to have a green card. Cohen did have a green card and – after Marty Machat’s death in 1988 - abandoned that and attempted to blame Mr. Machat for the problems he himself created. He also had a number of social security numbers, off-shore holding accounts, and a disdain for paying ordinary income taxes. 9. Defendant refused to enter an appearance in Neal Greenberg's lawsuit against Cohen related to the so-called interpleaded funds. Defendant believes that is a fraudulent matter as well and maintains that Plaintiff Leonard Norman Cohen, Greenberg, Westin, and others, came up with a scheme to cover their actions. Defendant believes they have acted in collusion in an attempt to defend themselves against allegations of tax fraud – civil and/or criminal - or securities violations. 10. Plaintiff, Leonard Norman Cohen, took out a fraudulent restraining order against Defendant in Los Angeles. That has since expired. Defendant believes this was a desperate attempt to prevent her from addressing very serious issues of tax fraud and the fact that she was defrauded by Plaintiff. Cohen has gone to extraordinary lengths to crush and silence Defendant – including having his lawyer, Robert Kory, file a Declaration in her younger son's "custody matter" after the child witnessed a conversation about tax fraud, threats, stolen intellectual property, missing tax returns, and so forth. Defendant maintains that all of this activity was coordinated – presumably to prevent her from reporting the tax fraud and "encouraging" her to testify in a manner in which Plaintiff wanted. Defendant does not believe a fraudulent restraining order is a proper means to prevent her from determining what has actually occurred with respect to Blue Mist Touring Company, Inc., Traditional Holdings, LLC, LC Investments, LLC, Old Ideas, LLC, and possibly other entities. Robert Kory told Defendant, at their luncheon, that she had a cause of action against every one of Cohen's advisers, confirmed that certain holding periods were illegal, and confirmed that there was tax fraud on every entity – going back until at least 1996 and possibly relating to the sale of assets by Stranger Music, Inc. and Bad Monk Publishing to Sony, as well as the failed CAK bond deal. 11. Defendant has no idea why Plaintiff is interested in her terminated AOL accounts. Defendant gave the Internal Revenue Service, Phil Spector, and others the passwords to tsimar@aol.com and ekajati@aol.com so they could review all emails between Defendant, Cohen, his advisers, and others, and make an independent determination as to what had gone on. 12. After being victimized by Cohen's utterly malicious tactics, Defendant believes his allegation that she has referred to him in highly offensive pejorative terms is ludicrous. Defendant maintains that he is "deranged," a "criminal" who has defrauded the United States government and perjured himself in a number of courts in the United States, a fraud who has possibly perjured himself in Phil Spector's "secret grand jury," and has advised Cohen and others that His Holiness Kusum Lingpa believes he is an "asshole who is going to hell." Defendant has disclosed facts that she was privy to regarding Cohen and was advised, by Norman Posel of Boies Schiller and others, that Cohen was going to destroy her if she told the truth about him. Defendant mailed the email sent her by Boies Schiller – stating that they were going to destroy her - to the FBI in Denver. The truth is the defense to slander. Cohen himself told Lynch that Freda Guttman advised Ann Diamond that Lorca Cohen had made comments at Concordia University alleging that her father had molested her. Lynch was asked by Cohen to speak to her brother-in-law, Van Penick, about Cohen’s concerns that he slept with a 15-year old nanny and statutes of limitations; residence and tax issues that concerned him in Canada; U.S. tax credits for donating his body of work to the University of Toronto; and the fact that Ann Diamond repeated Freda Guttman’s remarks to her on a public website. Ann Diamond was threatened by Kory Law Firm around the time Cohen flew into Boulder to take out a fraudulent restraining order. Defendant views this as a desperate act – solely meant to silence her and to prevent her from addressing various issues with Robert Kory and Michelle Rice. Defendant is representing herself and believes she has a right to determine where her assets have gone and precisely how much she is owed by Plaintiff. Boies Schiller, after reviewing a tremendous amount of evidence, advised Defendant that Plaintiff owed her millions. Given the fact that neither Cohen nor his advisers will address these issues, Defendant has taken the position that any monies advanced her, distributed to her or anyone from Traditional Holdings, LLC, paid to her in accordance with corporate books and records, given to her without supplying her with a requested 1099, etc., are gifts. Defendant believes Plaintiff should now pay the gift taxes. Defendant further maintains that Cohen owes the taxes, penalties, and interest in connection with his advisers work relative to all entities and Lynch's involvement with said entities for his sole benefit and with his full knowledge and awareness. Defendant also maintains that she is entitled to $240,000/year, $20,000/year, and possibly other distributions, etc., in connection with Traditional Holdings, LLC – as stated clearly in the corporate books and records. If there is an accounting issue with respect to Blue Mist Touring Company, Inc., Defendant believes Cohen should take full responsibility for that and notes that his former CPA, Ken Cleveland, and her former CPA, Dale Burgess, both feel the assets allegedly sold by Traditional Holdings, LLC are still in Blue Mist Touring Company, Inc. 13. Defendant has not falsely alleged that Cohen committed tax fraud. Defendant was told (by DiMascio & Berardo, Dale Burgess, CPA, and others) that he committed both civil and criminal tax fraud and exposed her to it unwittingly. Mike Taitelman, a lawyer who briefly represented Defendant, had a phone conversation with Robert Kory. He advised Defendant that if she did what they wanted her to do they would say Defendant was used as a pawn – which she was. If not, they would say Defendant orchestrated this incredibly insane "mess." Taitelman also advised Defendant to look at the risks and conditions and apparently told Kory he wanted her protected. She did and decided to stand on her own. Bert Deixler told Defendant he could walk her into the Attorney General of the State of California and have the poet arrested. He also apparently had conversations with DiMascio and Kory. It was Defendant's intention, all along, to report this "matter" to the Internal Revenue Service, the State of Kentucky, and others. After paying all taxes she was advised to pay, Defendant informed Agent Bill Betzer of the Internal Revenue Service – on April 15, 2005 – that she believed there was fraud on various entities. Agent Betzer advised Defendant to bring this matter to the attention of the IRS through a lawyer and to go get what was rightfully hers – 99.5% of Traditional Holdings, LLC and 15% of Blue Mist Touring Company, Inc. Eventually, Agent Betzer advised Defendant to call the Fraud Hotline. She did. Defendant also contacted the IRS through its website and phoned them in Washington, D.C. – and explained some of the malicious and vicious tactics being used against her. Agent Betzer confirmed that Miss Hall, who Lynch spoke with at the IRS in Washington, called her. Mr. John Maunts of the State of Kentucky advised Defendant to put the Blue Mist Touring Company assignments in a safety deposit box when she contacted them. Defendant has also brought this matter to the attention of Mr. Rob Watts/State of Kentucky, the California Franchise Tax Board, the California Department of Corporations, and others. 14. Defendant reported Cohen's illegal use of her social security number on the illegally issued K1s from LC Investments, LLC to the Social Security Administration. She then provided the Internal Revenue Service and others this information. Defendant believes this is what Plaintiff is referring to when he states that she made his social security number public. Defendant does not know if Cohen also committed tax evasion but his advisers repeatedly refer to this. 15. Defendant believes Cohen and/or Kory encouraged Steven Clark Lindsey (her young son's father) to place a fraudulent call to 911. This seems to have brought a SWAT Team comprised of at least two police departments – LAPD and Inglewood PD – to Defendant's former home in Brentwood, California. Defendant was not dangerous to herself or others and did not have a hostage. Her young son was taken down the hill prior to the arrival of SWAT by her older son. The police willfully ignored all eye witnesses and relied on remarks made by Steven Clark Lindsey. Steven Clark Lindsey appears to have used this situation to take custody of Defendant's young son when she was taken to King Drew. Dr. D'Angelo of King Drew did not agree with anyone's assessment that Defendant was dangerous to herself or others. In fact, en route to King Drew, Defendant was questioned about Phil Spector while her older son, Rutger Penick, was asked by Steven Clark Lindsey to go into Kory's office and sign over/transfer her house to Leonard Norman Cohen and/or Robert Kory. Lynch does not believe the King Drew file relates to her. It is entirely falsified and notes that she was 19, lists the wrong social security number, wrong date of birth, wrong place of birth, wrong religion, fraudulent medical information, and may relate to paperwork Brian Bennett (Los Angeles District Attorney's Office) brought to Defendant's home when he came to interview her about Phil Spector – after someone placed an anonymous tip about their friendship. According to Brian Bennett that call was placed by a woman. Defendant maintains that Cohen, Lindsey, Kory, Bergman, and others coordinated these events – possibly with the Los Angeles District Attorney, LAPD, Inglewood PD, and others. This is a reasonable assumption and Defendant believes the District Attorney had the power and motive to have her taken to King Drew. She believes this was an attempt to force her to make a deal with Cohen and testify against Phil Spector. This does not necessarily explain why the nurse who told her the file was falsified said she was being transferred. Defendant has asked the IRS Commissioner's Staff, the Department of Justice, Agent Kelly Sopko – Treasury Department, Phil Spector, Bruce Cutler, Doron Weinberg, the Attorney General of California, and others to investigate this. Exhibit F_- King Drew Falsified File on Kelly Lynch and Los Angeles District Attorney’s Internal Memorandum on King Drew dated April 8, 2005. 16. Defendant placed calls to Plaintiff's home during the SWAT incident – where her son was used as a human shield and hostage negotiator (and told that his Mother and dog would be shot) – because she felt what she was watching unfold was directly related to Cohen. Defendant will subpoena those messages when she is properly represented – hopefully by Bruce Cutler – NOTE: Cutler is Phil Spector's problem. I’ve heard from Phil Spector and advised him of Cutler’s actions – he should have handed my letters over to Phil Spector and his legal team due to the testimony about Phil Spector and a gun; the emails between Cohen and the City Attorney re. guns; the involvement of Alan Jackson and Steve Cooley (see Closing Arguments, Cohen’s testimony about Cooley and my emails); and the DA investigator in the courtroom. Defendant has asked Phil Spector to join her in a lawsuit against the District Attorney of Los Angeles, LAPD, Inglewood PD, King Drew, various individual officers – including Maurice Hampton, Erma Oppenhein, Garrin, and others – Leonard Norman Cohen, Steven Clark Lindsey, Betsy Superfon, Robert Kory, Ricardo Cestero – Greenberg Glusker, Scott Edelman and Ken Doran – Gibson Dunn, Ira Reiner, Daniel Bergman, Harvey Steinman, and others. As Mr. Spector is currently on trial for murder Defendant has been unable to discuss this with him. Defendant believes her views that he is innocent put her life in danger. Mr. Spector informed Defendant – after the Lana Clarkson incident – that she committed suicide at his home and he was innocent. Defendant believed him and refused to fabricate or embellish stories about him for the Los Angeles District Attorney. She felt the District Attorney was not satisfied with her views on Phil Spector. This ultimately led to Defendant being threatened by the District Attorney after filing a complaint about Cohen with their Major Fraud Unit and she believes this is nothing other than witness tampering, witness intimidation harassment, etc. In fact, after attempting to leave a message with “Garrin” of LAPD for "Maurice Hampton" of Los Angeles Police Department and speaking with members of “SMART” about Hampton and “Erma Oppenhein,” Officer Storbeck of Boulder Police Department came into Deneuve Construction (where Defendant worked) demanding to know if Defendant was dangerous to herself or others. Defendant has contacted the FBI in Denver about this incident and was advised to ask the District Attorney of Boulder and the Attorney General of Colorado to investigate this incident which she feels proves that various activities are crossing state borders – including, but not limited to, the present matter. 17. Defendant was served a copy of Plaintiff's fraudulent restraining order in California but asked Sergeant Fernandez to throw it in the trash can. She herself threw it in the trash can in front of him and asked if everyone in the State of California was participating in Cohen's tax fraud. 18. Defendant has no idea how many emails she has sent documenting the destruction of her life but given the fact that the IRS Commissioner's Staff has been copied in on most, if not all, of them she feels they can have the final say. Defendant said Cohen used prescription meth. This is a story that Cohen himself loved to tell. Cohen also has told the press over the years that he did drugs so she does not understand why he is now complaining about this. Defendant believes Cohen has committed egregious perjury and fraud. 19. Defendant maintains that Plaintiff and his advisers have used Nazi-esque tactics against her – and her parents and children. Defendant does not know what Plaintiff is attempting to prove here but feels he is merely trying to gain the sympathy of the FBI in Denver. Defendant feels that the FBI in Denver is aware that the Aryan Nation exists and they have connections to meth labs. Defendant brought this up for personal reasons that she has brought to the attention of the IRS Commissioner's Staff, the Department of Justice, and others because she felt certain information endangered her life. Having said this, Defendant was amused to note that there is an Aryan Nation dating website. Defendant has no idea if the FBI in Denver lies because she doesn't know them. What Defendant does know is that she and a Duty Agent at the Denver FBI do not necessarily see eye to eye on why Officer Storbeck rolled into Deneuve Construction with the Police Chief's secretary. The Duty Agent did not seem to feel that LAPD was behind this but Defendant feels they were involved. 20. Defendant's house would not have been foreclosed upon if Leonard Norman Cohen and Steven Clark Lindsey paid Defendant the monies they owe her. Defendant believes Cohen is now proving that he is an utterly cruel and malicious man who is capable of anything when forced to defend himself. Defendant never had a disposable cell phone and wonders why Cohen seems upset that Defendant managed to document every detail of what she has and continues to go through – including by using computers at the Apple Store in Santa Monica, California when she was homeless. 21. Defendant has brought her encounters with Santa Monica Police Department to the attention of the IRS Commissioner's Staff, the Department of Justice, Phil Spector, Bruce Cutler, Doron Weinberg, and others. Defendant was told by Officers Rogozik and Arnold that they understood she knew Phil Spector. That comment needs to be investigated as does all the activity that took place between many officers in Santa Monica and Defendant. She was advised that they were playing a game with her and feels some of this is due to the fact that she went to Internal Affairs about Officer D'Andrea and may relate to the Los Angeles District Attorney. It's interesting for Defendant to read that Santa Monica Police Department was closely monitoring her. Defendant feels there is an unbelievable amount of law enforcement all over this story. Defendant has a warrant in Santa Monica for smoking a cigarette on the curb. When she reported this incident to Internal Affairs she had a gang of police officers harassing her. If an officer referred to Defendant as a "5150" Defendant will sue him for slander. Santa Monica Police Department took Defendant to UCLA Harbor after she attempted to report that she believed she was being stalked by Drew Feldman – who has a reputation of stalking homeless women, putting them in rohypnol comas, possibly having gave someone a dirty speed ball which led to their death, and is someone who was on protective custody in Avanol State Prison. Defendant has asked the IRS Commissioner's Staff, the Department of Justice, Phil Spector, Bruce Cutler, Doron Weinberg, and others to investigate what happened to her at UCLA Harbor, King Drew, and UCLA – after she was rear-ended and knocked unconscious on June 13, 2005. Defendant has asked Bruce Cutler to help her attack laws relating to "5150" incidents and restraining orders because she feels they are unconstitutional and violate one's lawful right to due process. She also believes these tactics are highly abused and feels the Courts should understand this also. 22. Defendant came to Erie, Colorado after Yongzin Rinpoche and his wife, Clea Surkhang, extended an invitation to her. Defendant did not say she moved to Colorado to avoid being arrested and maintains that Cohen is and always will be a fiction writer. 23. Defendant does not believe for a moment that Cohen hoped she would remain employed and firmly believes that his lawyer's letters to Phil Shull's attorney (Craig Blockwick) and David Moorhead are evidence of this. In fact, after receiving Robert Kory's letter, David Moorhead advised Defendant that he believed Kory was behind Officer Storbeck's visit to Deneuve Construction. Defendant understands why Plaintiff might find her emails to the IRS Commissioner's Staff, the Department of Justice, Agent Kelly Sopko – Treasury Department, and others disturbing and possibly threatening because she has been told that Cohen committed civil and criminal tax fraud. Defendant has advised Cohen and Kory that they should take restraining orders out against these agencies if they find their presence threatening. 24. Defendant does not know where 90 Arapahoe is in Boulder, Colorado, and cannot understand why Cohen felt she lived there. His lawyer, Robert Kory, wrote her c/o Liz Craig, 7432 Brockway Drive, Boulder, Colorado 80302, and Cohen was aware that she was staying at the Boulder Hostel on 13th Street. In fact, Defendant believes Ronald Mitchell involved himself in this matter as a means to avoid possible liability that arose when Defendant found herself being threatened by various tenants in that building – which she reported to him, the IRS Commissioner's Staff, the Department of Justice, Agent Kelly Sopko – Treasury Department, Phil Spector, Bruce Cutler, Doron Weinberg, and others. Defendant maintains that Cohen and Mitchell are acting in collusion and has asked various agencies and individuals to investigate this possibility. 25. With respect to the firing squad comment, Defendant does not believe she could assemble one and places an emphasis on the word "should." This is not a threat but rather addresses Cohen's own desire – as he advised Defendant – to be killed by a firing squad. This is how Plaintiff told Defendant he would like to die. Defendant maintains that her response was tempered and is temperate – given the facts of what has occurred including Cohen and his advisers targeting her children. Defendant was asked for Cohen and Lindsey's addresses. The individuals who asked for their addresses, after witnessing what was going on, did indeed say "accidents happen." Defendant did not say this but merely repeated it. She did not give these individuals Cohen and Lindsey's addresses. 26. Defendant will ask Bruce Cutler, if he agrees to represent her, to subpoena all messages she left for Robert Kory. 27. Defendant does not believe turning in what she has been told is civil and criminal tax fraud qualifies as a threat. Defendant is addressing the police misconduct in Boulder and has asked Bruce Cutler to help her bring a RICO suit against various government agencies, law enforcement, and certain individuals, and maintains that she is the victim of a campaign of harassment that extends to Boulder Police Department. She has brought this to the attention of, and documented it for, the IRS Commissioner's Staff,. the Department of Justice, Agent Kelly Sopko – Treasury Department, the Attorney General of California, the Attorney General of Colorado, the Los Angeles District Attorney, the Boulder District Attorney, LAPD, Boulder Police Department, Internal Affairs, Phil Spector, Bruce Cutler, Doron Weinberg, and others. It demands an investigation. Kory Law Group did not like the fact that Defendant was documenting her situation for government agencies, law enforcement, and the press. They addressed this in their threatening letter to Ann Diamond – obviously meant to silence and scare her. 28. David Moorhead did counsel Defendant and advised her that he felt the District Attorney of Los Angeles was behind her being taken to King Drew noting that the District Attorney had the power and motive to do so unless the cops acted on their own. David Moorhead also felt Robert Kory, as stated above, was somehow involved with or behind Boulder Police Department's visit to Defendant's place of work. David Moorhead did not see any threats and noted that he did not feel Defendant could assemble a firing squad. Defendant actually believes that Cohen should be charged with criminal tax fraud and other things, and arrested. 29. Defendant is free to communicate with the government agencies, law enforcement, journalists, and others she has copied in on her emails because the United States of America guarantees freedom of speech. Defendant has not tracked Cohen's whereabouts or concerts – her friend, Maurice Smith, has been reading the press and has sent Defendant certain articles so that she may address the slander, defamation of character, etc., and the fact that Cohen is making approximately $2 million a night and refuses to pay her what she is owed. Defendant has provided the IRS Commissioner's Staff, the Department of Justice, Agent Kelly Sopko – Treasury Department, Phil Spector, Iris Keitel – ABKCO Records, Ron Burkle, Lee Kanon Alpert, His Holiness Thinley Norbu, His Holiness Karmapa, His Holiness Sharmapa, Bhakha Tulku Rinpoche, and Robert MacMillan with a tremendous amount of evidence supporting her position that Cohen has committed tax fraud and defrauded her. 30. Defendant maintains that Cohen has committed civil and criminal tax fraud. In fact, her former accountant, Dale Burgess, advised Defendant that he believes Criminal Intelligence of the Internal Revenue Service is or should be involved in an investigation of the alleged tax fraud. Defendant also maintains that she believes Cohen perjured himself in Phil Spector's secret grand jury. The reason for this is that Defendant met the detectives from LAPD who came to discuss Cohen's comments about Mr. Spector in the news media. At that time, Steve Cron – an attorney who Defendant knew – advised Defendant to leave Cohen's house because she did not want to be a witness in the Phil Spector Murder Trial. She was later told by Investigator John Thompson that she was probably a witness. Fortunately, she is not on the witness list but rather waiting for Phil Spector to join her in a lawsuit against all the parties that have destroyed her life – including the Los Angeles District Attorney. Cohen told Defendant over the years that he simply did not like the sound of his vocals on the album Phil Spector produced. Phil Spector told Defendant that he found working with Cohen depressing and received hate mail from all eight (8) of Cohen's fans. Cohen told Defendant that he felt upset by having to telegram Phil Spector asking him to finish the album. Cohen also told Defendant that he advised the detectives that his comments to the about Phil Spector throughout the years were merely good rock 'n roll stories. Defendant believes these good rock 'n roll stories have been highly embellished for the news media in order to help Cohen promote his career and sell albums. There is ample evidence that using Phil Spector's name when talking to journalists is a way to achieve celebrity and sell records. Defendant maintains that Cohen owes her millions and will address this more specifically when she is properly represented. Defendant also believes Cohen made some type of deal with the Los Angeles District Attorney which led to her being taken to King Drew. She feels it was an attempt to prevent her from successfully informing the Internal Revenue Service of his tax fraud and coercing testimony against Phil Spector from her. Defendant also maintains that the King Drew file can never be explained away and is evidence of stupidity. 31. Defendant believes Cohen hunted her down in Boulder, Colorado, and finds that deeply disturbing. Defendant has no interest, whatsoever, in Cohen, his concerts, or his lies. Defendant's attempts to truthfully address what has gone on with respect to her, Leonard Norman Cohen, Phil Spector, her parents, her children, and others, is not going to abate. Defendant did not move from California to evade the jurisdiction of California law enforcement but would like to determine why she has become well-known to them when she rarely even had a parking ticket prior to having Cohen's tax fraud confirmed to her and being told that she could not make any type of deal. In fact, Defendant was told that her only options were to amend the tax returns and/or go to the Internal Revenue Service. Defendant did not trust anyone to amend the tax returns, has no idea what has actually been done in her name, and brought the allegations of civil and criminal tax fraud to Agent Bill Betzer of the Internal Revenue Service, the Internal Revenue Service via it's website, the State of Kentucky, the California State Franchise Tax Board, and has provided evidence to the IRS Commissioner's Staff via their email address *IRS.Commissioner@irs.gov. Defendant met with agents from the U.S. Treasury Department and advised them that she believes her son's custody matter arose from her discovery of Cohen's tax fraud. Robert Kory's Declaration is evidence of this. Agent Sopko provided Defendant with the name of the head of fraud for the IRS in Los Angeles. Defendant then contacted him and provided him with information she felt might be relevant. Exhibit G - Agent Kelly Sopko's email to Kelley Lynch dated March 6, 2007. Defendant maintains that Cohen's sole motivation for filing a fraudulent lawsuit against her is the fact that she brought the allegations of tax fraud to the attention of the IRS Commissioner's Staff, Mr. John Maunts – State of Kentucky, and others. Defendant maintains that Cohen is disturbed that his attempts to silence, terrify, crush, and destroy her did not work. This is evidence, to Defendant, of what this man is capable of – including attempting to have Defendant and Phil Spector take the fall for him. Defendant believes Cohen made a deal with the Los Angeles District Attorney that relates to Defendant and Mr. Spector and may somehow involve his lawyer, former District Attorney Ira Reiner, who was apparently guiding Cohen's attempt to have illegal mediations and was communicating with Lynch’s lawyers. Defendant has mailed evidence that Cohen and Kory advised Norman Posel, Boies Schiller, and possibly others, that they were going to destroy her and her children to the IRS Commissioner’s Staff, the Department of Justice, Agent Kelly Sopko – Treasury Department, the Denver FBI, and others. Defendant was told by Greenberg's lawyer, Dan Scheid, that the witness and evidence tampering the Denver FBI Duty Agent told her would be considered criminal, relates to Leonard Norman Cohen, Robert Kory, and possibly Steven Clark Lindsey, Betsy Superfon, and others. Defendant has asked the IRS Commissioner's Staff, the Department of Justice, Agent Kelly Sopko – Treasury Department, Phil Spector, Bruce Cutler, Doron Weinberg, and others, to investigate these allegations. Defendant has repeatedly made it clear to Cohen, his advisers, and others that she plans to address all of this in a legal manner. She refuses to stoop to rotten, shabby, malicious legal tactics. Defendant and others believe this particular matter, and the fact that Cohen was so desperate that he flew into Boulder, is evidence that he is insane, unstable, desperate, and volatile. His lawyers are merely liars, from what Defendant has experienced, who are willing to lie in court and in documents filed with the court, and who should be investigated and disbarred – and probably charged with aiding and abetting an attempted cover up of criminal tax fraud and arrested. In fact, a former attorney for Leonard Norman Cohen (Ed Dean) told Lynch this: If the IRS Commissioner believes there is fraud and not negligence he will come in after the lawyers and accountants as well. Defendant believes the IRS should investigate the roles Cohen's various advisers played in his various tax planning schemes. Given the fact that Kory "himself" has written Defendant that the IRS will demand to review certain matters going back many years, Defendant wonders why Cohen did not go to the IRS with her – particularly if he believes he was defrauded by his advisers. Defendant also wonders why – after alleging that Neal Greenberg had committed securities violations – Cohen did not go to the SEC as she did. All of this leads Defendant to believe that Cohen, Greenberg, Westin, and others, conspired with one another and planned the lawsuits in LA Superior Court and the U.S. District Court in Denver. It certainly gives the appearance that they have acted in collusion. The result of these suits appears to have been to discredit Defendant while protecting one another and attempting to cover up the fact that all these parties were involved in creating and structuring these entities and in the creation of this complicated tax scheme - for the sole benefit of Leonard Norman Cohen. In fact, Neal Greenberg is attempting to take cover behind Defendant. He has been advised not to use any documents or information she permitted Boies Schiller to review in an attempt to defend himself. Defendant was egregiously used by his lawyer, Norman Posel, when he worked for Boies Schiller – after he was asked by His Holiness Kusum Lingpa to protect her. Instead, His Holiness Thinley Norbu, His Holiness the 17th Gyalwa Karmapa, His Holiness the 14th Sharmapa, Bhakha Tulku Rinpoche, Bruce Cutler, Doron Weinberg, Ron Burkle, Robert MacMillan, Lee Kanon Alpert, Iris Keitel of ABKCO Records, the IRS Commissioner's Staff, the Department of the Treasury, Agent Kelly Sopko of the Treasury Department, the Denver FBI, and oth
| |||||||||||||||||||||||||||
Tuesday, October 23, 2012
Kelley Lynch vs. Leonard Cohen - Motion To Quash Addressing Cohen's Fraud, Perjury, Lies & Concealment Re. The Boulder Order
