Tuesday, November 18, 2014

Kelley Lynch Asks Richard Dallett About Leonard Cohen & Her Mother's Stroke

From: Kelley Lynch <kelley.lynch.2010@gmail.com>
Date: Tue, Nov 18, 2014 at 8:33 PM
Subject: Re:
To: dale <dale@pikelleyandassociates.com>, "irs.commissioner" <irs.commissioner@irs.gov>, Washington Field <washington.field@ic.fbi.gov>, ASKDOJ <ASKDOJ@usdoj.gov>, "Division, Criminal" <Criminal.Division@usdoj.gov>, rbyucaipa <rbyucaipa@yahoo.com>, "Doug.Davis" <Doug.Davis@ftb.ca.gov>, Dennis <Dennis@riordan-horgan.com>, MollyHale <MollyHale@ucia.gov>, nsapao <nsapao@nsa.gov>, fsb <fsb@fsb.ru>, khuvane <khuvane@caa.com>, blourd <blourd@caa.com>, Robert MacMillan <robert.macmillan@gmail.com>, "g.robertson" <g.robertson@doughtystreet.co.uk>, a <anderson.cooper@cnn.com>, wennermedia <wennermedia@gmail.com>, Mick Brown <mick.brown@telegraph.co.uk>, "glenn.greenwald" <glenn.greenwald@firstlook.org>, lrohter <lrohter@nytimes.com>, Harriet Ryan <harriet.ryan@latimes.com>, "hailey.branson" <hailey.branson@latimes.com>, "stan.garnett" <stan.garnett@gmail.com>, sedelman <sedelman@gibsondunn.com>, JFeuer <JFeuer@gibsondunn.com>, "kevin.prins" <kevin.prins@ryan.com>, rwest0@gmx.com, Sherab Posel <poselaw@gmail.com>, info <info@ripaladrang.org>, "YesheRimpoche@aol.com" <bhakhatulku@yahoo.com>, info <info@kibi-edu.org>, spriyer@aol.com, lodigg@savetibet.org, "steve@blottermusic.com" <steve@blottermusic.com>, "steve@radicalmusic.com" <steve@radicalmusic.com>, karen <karen@softwheresolutions.com>, Douglas Penick <mpduke1@msn.com>, Chewyguru <gesarmukpo@yahoo.com>, Daniel Meade <trimesamten1@gmail.com>, Palden Ronge <mediamessenger@gmail.com>, Richard Dallett <richard@boischamois.com>

Hi Richard,

What do you think of my mother's declaration?  She then had a stroke - probably over this situation.



On Tue, Nov 18, 2014 at 8:15 PM, Kelley Lynch <kelley.lynch.2010@gmail.com> wrote:


I, Joan Marie Lynch, do state and declare as follows:
  1. I am a citizen of the United States who resides in the State of Texas.  Kelley Lynch is my daughter.  Except as to those matters stated on information and belief, I have personal knowledge of the facts set forth below and could and would testify competently if asked to do so.  I would have willingly testified during my daughter’s 2012 trial but was never contacted by her court appointed lawyers. 
  2. I have known Kelley since birth.  My husband, John Lynch, and I have a very close relationship with Kelley and her sons, John Rutger Penick and Ray Charles Lindsey.  Prior to Ray’s birth in 1992, my husband and I relocated to Los Angeles to be near Kelley and the boys.  We were extremely involved in their upbringing, saw them on a daily basis, picked them up from school, knew their friends, attended school and sporting activities, and enjoyed a very warm and close relationship with our daughter and her family.  We were also with our daughter on a daily basis and, because we lived quite close, spent a great deal of time at her home as well.
  3. In the Spring of 2005, my husband and I moved to Texas to be near our younger daughter and her family.
  4. From approximately 1992 through the winter of 2004, I worked as Kelley’s personal assistant and office administrator.  During that period of time, my daughter had two businesses: Stranger Management, her personal management company, and Amazing Card Company, her greeting card company.
  5. For approximately 17 years, from 1988 until the fall of 2004, Kelley worked as Leonard Cohen’s personal manager and in other capacities.  She was not Leonard Cohen’s business manager and did not handle matters related to tax, IRS filings, corporations, finances, investments, accounting, and things of that nature.  Leonard Cohen had a team of professional representatives handling those matters.
  6. From approximately 1996 through 2001, Kelley also worked as Adam Cohen’s personal manager.  Adam Cohen is Leonard Cohen’s son and a recording artist in his own right.
  7. I am aware that my daughter has been victimized by malicious lies, slander, and false accusations that were repeated throughout her trial.  It is my understanding that the prosecutor denied Kelley release on her own recognizance by, among other things, advising the court that she is a flight risk and dangerous to her community as well as estranged from her sons.  Kelley is and was not a flight risk or dangerous to her community.  She is not estranged from her sons but the current matter, and certain parties who have targeted members of my family, has created enormous stress for Kelley and her sons. 
  8. I have reviewed most of the trial transcript, sentencing memorandum, and other documents with my daughter.  An inconceivable amount of false information was provided to the jury about my daughter by both the prosecution and her own trial lawyers. 
9.      Kelley met Leonard Cohen and Phil Spector while working for music industry attorney, Marty Machat.  After Marty Machat’s death in 1988, Kelley worked as Leonard Cohen’s personal manager and, for a number of years, Phil Spector’s personal assistant.
10.  In her opening statement, and throughout the trial, the prosecutor made many false statements about my daughter.  For instance, Kelley and Leonard Cohen did not have a brief intimate relationship in the 80s.  During this period of time, Kelley was married, had given birth to her eldest son, and hardly knew Leonard Cohen.  Kelley was not Leonard Cohen’s business manager.  Since the death of Marty Machat, Kelley has worked as Cohen’s personal – not business – manager.  Things did not start “to go not very well” between Kelley and Leonard Cohen.  She refused to meet with him and his tax lawyer, Richard Westin, and hired lawyers and a new accountant to deal with the issues between them. Kelley did not begin a campaign of harassment against Leonard Cohen.  She was represented, he became increasingly aggressive with her, and it is Leonard Cohen who began a campaign to discredit my daughter and ultimately began meeting with my grandson’s father in what appears to have been a coordinated custody matter. 
So the people believe that the evidence will show in the case of people of the State of California versus Kelley Lynch that during the 80s, Mr. Leonard Cohen, who was a singer – was and is a singer/songwriter, but also a poet, struck up a relationship with Ms. Lynch.  They had a brief intimate relationship, and then at some point after that the relationship ended in the late 80s when Mr. Cohen’s business manager died, Mr. Cohen hired Ms. Lynch, first as his personal assistant, and then ultimately as his business manager.  RT 37  Streeter:  But unfortunately around 2004 or so, things started to go not very well between Mr. Cohen and Ms. Lynch.  And Mr. Cohen ended the business relationship that he had with Ms. Lynch.  Unfortunately, that was not the end of it for Ms.Lynch, the evidence will show.  The evidence will show that shortly after the termination of the business relationship by Mr. Cohen that Ms. Lynch began an onslaught, a campaign of harassment on Mr. Cohen. RT 37-38

  1. In or around October 2004, Kelley and Leonard Cohen parted ways.     
12.  I am aware that my daughter has been falsely accused of having mental health, anger issues, a propensity for violence, alcohol and drug abuse issues.  My daughter has never, including at this period in time, had mental health or substance abuse issues.  I cannot imagine where this information came from but it most certainly has nothing whatsoever to do with my daughter or her character.  It is my understanding that the prosecutor in this matter continues to falsely accuse Kelley of having mental health and substance abuse issues.  These issues appear to have arisen, and continue to be used by the prosecution, in an attempt to discredit my daughter.  I speak to my daughter nearly every day and she is quite candid about the issues she is dealing with.  It is difficult to imagine how a lawyer would conclude that someone has mental health issues.  I understand that the prosecutor relied on a domestic violence counselor who concluded, without meeting my daughter, that she had mental health issues.  I cannot imagine why a domestic violence counselor would be involved in this matter in any way.  Kelley and Leonard Cohen were never in an intimate sexual dating relationship. 
13.  I am aware that my daughter was not actually represented by her court appointed lawyers throughout her trial.  These lawyers never contacted my husband and myself, never returned my youngest daughter’s phone calls, and seem to have most of their facts wrong.  Kelley was not told about a plea deal and when she brought this up with her court appointed trial lawyers after the trial began, she was not advised that she had the opportunity to accept the plea deal.  We spoke frequently while Kelley was in jail.  I am also aware that the Public Defender’s Office refuses to provide Kelley with her file and this has been extremely frustrating for her throughout her appeal  process.
14.  Kelley advised me that she intended to abandon her appeal due to the fact that her prosecutor lied to LAPD about her.  I thought this was a good idea as she has been exposed to an inconceivably outrageous situation with respect to her trial, these prosecutors, Leonard Cohen, and others.  It is my understanding that the appellate division refused to permit Kelley to abandon her appeal.  I am also aware of the fact that the prosecutor advised LAPD that she was terrified by a drone Valentine card my daughter sent to various recipients.  This allegation seems absurd and preposterous and it is my personal belief that the prosecutor does have ulterior motives with respect to my daughter. 
15.  I am aware that the Boulder County Court advised Kelley, prior to her wages being garnished in or around September 2011, that Leonard Cohen’s restraining order expired.  I am also aware that Kelley had no idea that Cohen had obtained a domestic violence order against her in California.  Kelley attempted to deal with the state wage garnishment, and other matters, but Leonard Cohen has steadfastly refused to provide her with necessary tax documents and information.  Kelley could not have knowingly and willfully violated a restraining order since she was advised that the Boulder, Colorado order expired.  My father was a magistrate and our family does indeed have a respect for justice.  Justice does not involve deception, lies, and the targeting of an innocent individual.    
16.  I am extremely aware of the fact that Kelley attempted to contact Leonard Cohen and his lawyers in order to address outstanding business matters, litigation matters, slanderous statements, to request tax, accounting, and financial information.  It is my understanding that the prosecutor in Kelley’s trial referred to her as a con artist and advised the jury that the tax issues are a ruse.  Nothing could be further from the truth.  My daughter reported Leonard Cohen’s tax fraud to the IRS in or around April 2005.  Thereafter, he retaliated.  Leonard Cohen is an individual who cannot live in Canada due to his apparent tax and residence issues.  It is unclear to me why the prosecutor would make these types of statements knowing that Kelley’s emails have been addressed to the IRS, FBI, and others.  I personally spoke with Agent Kelly Sopko of the Treasury Department and am aware that she met with Kelley and advised her to report Leonard Cohen’s tax fraud to an IRS agent in Los Angeles.  Kelley has been documenting everything she has gone through since reporting Leonard Cohen’s tax fraud and I think it is a very wise decision.  His Holiness Kusum Lingpa is the individual who initially suggested this to my daughter.  Thereafter a number of lawyers advised her to document everything.  That is what her emails represent. 
17.  As I have said, it is my understanding that Leonard Cohen testified that he and my daughter were in an intimate sexual dating relationship.  At no time was Kelley in any such relationship with Leonard Cohen.  The notion is ridiculous.  It is my understanding that the LAPD report states that Kelley and Leonard Cohen had a “sexual relationship.”  This is blatantly untrue and my daughter was a professional businesswoman.  I am Kelley’s confidante, aware of everything that goes on in her life, speak to her at least once a day (and always have apart from the period of time when she was homeless), and know the men who have been her life.  Kelley was not attracted to Leonard Cohen and it is my personal opinion that he was obsessed with my daughter.  I can assure you that my daughter has no interest in Cohen and no interest in attending one of his concerts.  I have never heard of anything so absurd in my entire life.  Leonard Cohen and my daughter had a professional business relationship and were close friends.  I am well aware of the fact that Leonard Cohen is a story teller, will say anything to achieve his own goals, and embellishes stories for the news media and others.  At no point, in the mid-to-late 80s, or at any time thereafter, were Kelley and Leonard Cohen involved in an “intimate” sexual relationship.
18.  Our family was very close with the Cohen family.  I know Leonard Cohen quite well and spoke to him just about every day for over a decade and saw him frequently. I was extremely close with Cohen’s son and daughter, Adam and Lorca Cohen.  I was also quite close with Esther Cohen, Leonard Cohen’s sister.  Our families celebrated all major holidays together including Thanksgiving, Christmas, and New Year’s. 
19.  It is my understanding that Leonard Cohen testified that he is a Jew who celebrates the Sabbath every week and has done so the entire time he worked with my daughter.  During the entire time I knew Leonard Cohen, it was not my understanding that he was a practicing Jew.  I understood that his family was Jewish.  I never knew Cohen to attend Temple or celebrate any Jewish holidays.  At all times, I understood that Leonard Cohen was Buddhist.  In fact, I was present when he took formal monk vows at Mt. Baldy Zen Center and renounced his attachment to material possessions.  I never once heard that Leonard Cohen celebrated the Jewish Sabbath.  It is my understanding that information Kelley provided to the FBI and other agencies was used against her.  Kelley was exposed to many dangerous conditions while homeless.  Due to the fact that she abided by a court order in place at the time (related to my younger grandson’s outrageous custody matter), Kelley was unable to leave California to stay with her family.  During her period of homelessness Kelley was exposed to a wide variety of people and evidently heard quite a number of disturbing things which she reported to the appropriate authorities.  For some reason, this information was used by the prosecution and Cohen in an attempt to prove that Kelley is affiliated with the Aryan Nation and this information was an implied threat to Cohen.  Kelley is not affiliated with any hate groups and never has been.  The notion is absurd and preposterous.
Streeter:  Now, when Ms. Lynch was in your employ, did you – did you ever celebrate any Jewish holy days and invite Ms. Lynch to those celebrations?  Cohen:  Yes.  Our family celebrates the Sabbath on Friday night, and Ms. Lynch was often invited to that evening,  Streeter:  Ms. Lynch was in your employ for about 15 years more or less … And are you saying that for the entire 15 years every – you would celebrate every Sabbath?  Cohen:  We occasionally missed. Some of us were out of town.  More or less is the custom of the family.  Streeter:  And did you ever express to Ms. Lynch how important your Jewish faith was to her?  Cohen:  I think she was well aware of that.   RT 134

20.  While Leonard Cohen spent time with Sasaki Roshi and at his zen centers in Los Angeles and Mt. Baldy, he was always actively involved in his business affairs.  He was in constant touch with my daughter and our office throughout this entire period of time and frequently stayed in Los Angeles. Leonard Cohen and Kelley were in constant contact by phone, fax, and email.  They spoke on the phone constantly throughout the day.  I cannot think of a time when they were not in constant contact, including when he would travel. 
21.  One of my positions with Stranger Mgmt. and Amazing Card Company was answering the phone. If Kelley was unavailable when Cohen called, he would ask me for details regarding his business matters, question me about calls, speak to me about his residences in Canada and Greece and any drafts/funds needed to pay bills for those residences, etc.  I handled these matters as a courtesy for Leonard Cohen as I worked directly for my daughter.    
22.  I frequently spoke with Cohen’s other representatives and business affiliates including, but not limited to, his lawyers, royalty consultant, accountant, book publishers, record label, musicians, fans, fan club representatives, bank representatives, financial and investment consultant, etc.  Cohen frequently had me transfer him to my husband, Jack Lynch, who handled a variety of things for both Leonard Cohen and my daughter.  Leonard Cohen was keenly interested in his financial matters including his income and expenses, record sales figures, and so forth and so on.  Nothing was concealed from Leonard Cohen who had full access to Kelley’s office.
23.    I obviously know Kelley’s ex-husbands and fathers of her sons, Douglas Penick and Steven Clark Lindsey, exceedingly well.  Douglas Penick is Rutger’s father and Steve Lindsey’s is Ray’s father.  My husband and I were extremely close with Judy and Mort Lindsey, Raý’s grandparents, during the time we lived in California.  We celebrated most holidays and birthdays with Judy and Mort Lindsey.  They were extremely close with my daughter, Kelley and both Rutger and Ray. 
24.  I am extremely aware that a custody matter arose for Kelley, with respect to her younger son, in 2005.  It is my belief that Steve Lindsey initiated the custody matter due to his relationship with Dinah Englund and for financial reasons.  It is my personal belief that issues re. jealousy may have entered into Lindsey’s decision to file for custody of Ray.  Additionally, he owed my daughter a tremendous amount of money with respect to expenses she paid on behalf of his daughter, Jennifer Lindsey, Ray Charles Lindsey, and loans she advanced him. 
25.  Kelley and Steve Lindsey separated sometime in 1997 and my daughter essentially raised her sons on her own.  Douglas Penick resided in Colorado and primarily spent time with Rutger during holidays and summer vacation.  Steve Lindsey resided in Los Angeles and would visit Ray after school and take him out on weekends.  Ray rarely, if ever, stayed with Steve. Kelley is a loving and kind mother who cared for all aspects of her sons’ lives.  She was never abusive with either of them and any allegations to the contrary are outrageous.  Kelley is extremely devoted to both of her sons and devoted her life to them.  She rarely went out and, if she traveled for business reasons, my husband and I would stay with the boys.  Kelley is, of course, concerned about the welfare of her sons particularly given the fact that they continue to be targeted by strangers.
26.  It is my personal belief that Steve Lindsey, Leonard Cohen, and others, conspired to have Ray Charles Lindsey removed from my daughter’s custody.  It is also my understanding that the custody matter was also used against Kelley during her trial although my grandson was nearly 20 years of age.  I am aware that Leonard Cohen’s lawyer provided the custody court with a declaration in Ray’s custody matter after she and Ray stopped by for an impromptu meeting.  I have heard that he felt she “interrogated” her son.  Kelley is very honest and has been extremely honest with her sons throughout their lives.  In any event, we all heard many details that were unfolding with respect to Leonard Cohen’s IRS problems, commissions withheld from my daughter, threats that were made, and with respect to other matters.  I also understand that Steve Lindsey had become increasingly aggressive with my daughter during this period of time and began meeting with Leonard Cohen although he had no involvement whatsoever in any business matters between my daughter and Cohen. 
27.  I am aware that my grandson, Ray, was essentially removed from my daughter’s custody by a SWAT team who evidently felt she had a hostage.  I have heard that LAPD ultimately believed the hostage was Kelley’s dog.  I am also aware that Kelley was taken a great distance, to King Drew, and promptly released by the doctor.  It is my understanding that she was questioned about Phil Spector en route to King Drew.  I cannot understand why LAPD would take Kelley to a hospital in South Central when UCLA was right down the street.  After being released from King Drew, Kelley discovered that a custody matter had been filed.  It is also my understanding that after LAPD removed her from her home, my older grandson Rutger was asked to sign over or transfer her home to Leonard Cohen.  It is my personal belief that the custody matter was used to crush my daughter into a deal with both Cohen and Lindsey.  It has most certainly been used to discredit her. 
28.  Kelley is wonderful with young people, helped raise her nephew, Gesar Mukpo and stepdaughter, Jennifer Lindsey, and was surrounded with children and teenagers on a daily basis.  She provided a safe, secure, and fun environment for them.  Many parents were grateful to Kelley for the safe and wholesome environment she created for the teenagers who spent a great deal of time at her home. Her younger son, Ray, frequently had friends over as well.  I actually thought of Ron Burkle’s son as my grandson.  Many of the young people at Kelley’s home would call me Mimi.  Kelley was also extremely helpful with Rutger’s young friend, Chloe, and at one period in time actually brought her to the office on a daily basis.  Many of these teenagers began working after school for Kelley’s greeting card company.  I was in charge of supervising them.
29.  Kelley was also intimately involved in helping to raise Leonard Cohen’s daughter, Lorca, while she attended high school in Los Angeles.  She drove Lorca to and from school, had her over every night after school, fed her, helped with her homework, and generally looked after her. 
30.  Leonard Cohen and Lorca Cohen lived approximately one block away from Kelley’s Keniston Avenue office in Los Angeles.  They both had full access to and were frequently at the office including on weekends and evenings when the office we were not there.  Leonard Cohen was provided with his own office and would frequently review the mail and other documents left in his office for him to review.
31.  It is my understanding that issues have arisen with respect to a number of corporate entities. Kelley’s office did not serve as an office for any Leonard Cohen related corporate entity.  Due to the close proximity of Cohen’s home to Kelley’s office, she rented a Post Office Box at 419 N. Larchmont Blvd., #91, Los Angeles, California. 
32.  I was present when Leonard Cohen, together with Lorca Cohen, arranged to pick up his belongings, files, and personal property.  He was permitted to take whatever he felt belonged to him. He seemed satisfied that he was in possession of everything in our offices and at no time did he express his views that he needed to make additional arrangements to pick up any other property.  My daughter refused to speak to Leonard Cohen at this time and, therefore, I spoke to him personally about these issues.  At no time did he ask to pick up items Kelley stored at her Mandeville Canyon office as a courtesy.  Leonard Cohen was well aware that my daughter had an office in her home and worked from there after picking Ray up from school.  I understand that, rather than making arrangements to pick his property up, he went into court and ultimately had the Sheriff’s Department seize what he felt was his property.  This occurred nearly one year after he and Kelley parted ways. 
33.  I am aware that Kelley’s former landlord has now obtained a restraining order against her.  I am also aware that this man has harassed many others including my daughter, Karen, Kelley’s sons, Paulette Brandt, and Mario Lara.  I spoke with Kelley every single day when she lived with Michael Ingrassia.  I have spoken to Michael Ingrassia and never once did I hear of a complaint about my daughter.  I also understand that this individual sent an entirely pornographic email to Paulette Brandt who has apparently been relentlessly targeted by certain individuals intent to discrediting my daughter and alienating people around her through a variety of intimidation tactics.
34.  It is also my understanding that certain parties have said that Kelley brags about guns.  Kelley does not brag about guns.  I have never heard so many utterly absurd allegations in my life. 
35.  I have heard Leonard Cohen’s testimony about fearing for his life or safety.  Leonard Cohen will say anything.  Kelley has no interest in seeing him, speaking with him, or for that matter hearing about him.  Perhaps it is Leonard Cohen who is actually obsessed with my daughter and has attempted to discredit her to various courts, in the news media, and clearly to the prosecutors in this matter.  I would assume that his issues with respect to the IRS are part of his motivation for destroying my daughter’s life.  I am well aware of how Leonard Cohen operates behind the scenes.  He is obsessed with everything written about himself.  He becomes exceedingly aggressive when he believes he has been criticized.  Leonard Cohen is not the individual portrayed in the news media.  This is a persona he has created.  Leonard Cohen is extremely aware of how to project himself to journalists and others. I would assume that would be true of his performance before a jury.
36.  I have been advised that the prosecutor advised the jury that Kelley stole from Cohen and did not have an exit strategy.  This is another utterly absurd accusation.  I continue to be amazed at what certain people are willing to say about my daughter.  Leonard Cohen evidently advised the news media that an informant told his daughter that he could not retire.  This story apparently relates to an individual by the name of Julie Isenberg.  In or around August 2005, Kelley hired a young woman, Julie Isenberg, to assist with the packing of greeting card company orders.  She worked for Amazing Card Company for approximately one week, while Kelley was in Hawaii, and I supervised her work. Julie Isenberg did not have keys to our office and had no opportunity to review corporate books, financial documents, accounting records, and so forth and so on.  I distinctly recall Julie Isenberg spending most of her time at our office on the phone trying to find work or a job.  I have also heard that Leonard Cohen accused my daughter of having a gigolo.  These stories are ridiculous and wholly untrue.  Furthermore, I am well aware that Leonard Cohen compensated Kelley with a 15% interest in a corporation that owns his intellectual property.  That arrangement had nothing whatsoever to do with Kelley’s commissions for her work as his personal manager.    
37.  Kelley became increasingly concerned about Leonard Cohen’s behavior towards her.  She no longer wanted to spend time alone with him and started her greeting card company with the plan to literally get away from him.  Kelley would complain that he had her read business and legal documents while he soaked in bubble baths and engaged in other conduct that was highly inappropriate and unprofessional.  I have been advised that the prosecutor in Kelley’s trial attempted to prove that a male colleague exposing himself to his female colleague is an intent on the victim’s part to annoy the individual who would ordinarily be viewed as engaging in extremely inappropriate and outrageous conduct towards his colleague.  I must say that I have never heard such outrageous accusations in my entire life.  The entire trial never ceases to amaze me.    
38.  I am aware of the compensation agreement between Kelley and Leonard Cohen.  She received a 15% commission and a 15% ownership interest in Blue Mist Touring Company, Inc. and Leonard Cohen’s intellectual property.  I am aware that Kelley was working on many things prior to her parting ways with Cohen.  She has not been compensated for her work.  Kelley performed many services for Leonard Cohen and his family members.  Those additional services included, but were not limited to, her work as Cohen’s publishing administrator, publicist, and book publishing agent.  While Kelley worked as Cohen’s personal manager, she assisted him tremendously with his personal life; children; book publishing; music publishing; archiving his body of work; and actually served on the Board of Directors of Rinzai-Ji Zen Center. 
39.  I am aware that Kelley has an ownership interest in a number of Cohen related corporate entities. And, I am aware that, after they parted ways, Leonard Cohen offered Kelley various settlements that included whatever she wanted and 50% community property.  Kelley did not feel comfortable entering into a deal or settlement with Cohen.  It seems absurd to hear that Cohen would make these types of offers to my daughter and then falsely accuse her of stealing from him.  I have never heard of anything in my life although Cohen did falsely accuse my husband and I of placing his monies in off-shore accounts in South America and apparently falsely accused my younger daughter, Karen, of starting her computer business with his money.  As I have stated above, Leonard Cohen will say anything.  No one in my family misappropriated anything from Leonard Cohen.
40.  From approximately 1995 through 1998, Kelley and Oliver Stone (together with others) sponsored Orgyen Khachod Ling, for His Holiness Kusum Lingpa.  This Tibetan Buddhist center was downstairs from our offices and, during this period of time, I came to know His Holiness very well and many of his students.  That would include Oliver Stone and Steven Segal.  Leonard Cohen also spent time at this Buddhist center. 
41.  It is my understanding that in late 2004 or early 2005, Leonard Cohen and his lawyer met with Steven Clark Lindsey and advised him that she had sex with Oliver Stone.  At no point was Kelley involved in a sexual or romantic relationship with Oliver Stone.  It is also my understanding that Cohen and his lawyer alleged that Kelley had sex with Cohen’s tax lawyer, Richard Westin, and her friend, Richard Rutowski.  I know both of these individuals and at no time did Kelley have a sexual or romantic relationship with them.  It is my personal belief that both Leonard Cohen and Steve Lindsey were jealous when it came to Kelley; have acted vindictively and with malice towards her; and, conspired to create a custody matter through these false accusations that would have personally benefitted them.  Both Lindsey and Cohen owe Kelley a tremendous amount of money.  I have also been advised that the prosecutor in Kelley’s trial was under the impression that Kelley’s attempts to address Cohen’s slanderous statements about her and Oliver Stone was actually her intent to annoy him.  I am unable to follow that line of thought.
42.  I am aware that the prosecutor also accused Kelley of annoying Leonard Cohen over his very publicly documented use of various drugs and felt my daughter intended to annoy him.  It seems impossible to annoy someone else by addressing their own conduct.  I understand that Leonard Cohen testified that my daughter attempted to assail his reputation and I think that comment speaks for itself.  Leonard Cohen has a long history of drug usage that is well documented in the news media.  He frequently joked about obtaining prescription meth from his doctor by advising the doctor that he clearly didn’t intend to knock over a gas station.  It seems obvious to me that Kelley has been prosecuted for many issues that should be covered by the First Amendment with respect to freedom of speech. 
43.  It is my understanding that, since approximately 2004, Kelley has attempted to request a great deal of information and/or materials from Leonard Cohen with respect to monies due her; her interest in corporate entities and intellectual property; and with respect to other tax and business matters.  That would include, but is not limited to, a 1099.  Every year I worked with Kelley, Leonard Cohen provided her with a year-end tax document.  Kelley is still unable to obtain a copy of the tax document she requires and is potentially facing a wage garnishment due to this.  I understanding that the prosecutor advised the jury that Kelley does not need a tax document.  She does.  It is also my understanding that the prosecutor advised the jury that Leonard Cohen did not have the information Kelley requires.  Leonard Cohen was Kelley’s employer and is the individual that would have this information.  Furthermore, I was present when he and/or his daughter, Lorca Cohen, picked these files up from our office in October 2004.  It would seem to me that if someone actually had provided another party with a year-end tax form, as required by the IRS, that they would be more than happy to provide them with a duplicate copy.  That is precisely what we would have done if requested by, for example, one of Leonard Cohen’s record producers.   I am not sure that I really understand this issue – that someone would steadfastly refuse to provide my daughter with tax and other legitimately needed documentation, forcing my daughter to request it for years, and then put her on trial.  Something is wrong. 
44.  I am aware that at some point in 2005, Kelley reported Leonard Cohen’s tax fraud to the Internal Revenue Service and other agencies.  This has caused tremendous obstacles for my daughter and it is obvious, from my perspective, that this is one of his reasons for the retaliation against my daughter.  It is my personal opinion that this was extremely naïve on Kelley’s part.  I remain convinced that she should have entered into a settlement with Leonard Cohen and avoided all of this.  Cohen was actively pursuing a settlement agreement and/or deal with Kelley.
45.  I am aware that Leonard Cohen filed a lawsuit against Kelley after she reported his tax fraud to the IRS.  Since that time, she has advised me that she was not served the complaint or notified about the default judgment.  The process server noted that he served a female co-occupant at Kelley’s Brentwood home.  Kelley had no female co-occupant.  She lived alone with her sons, Rutger and Ray, until May 25, 2005 when the SWAT incident occurred and custody of Ray was removed from her in an outrageous manner.  Thereafter, she lived alone with her son, Rutger.  I have never seen an individual who resembles the Jane Doe described to me. 
46.  Kelley and Rutger were evicted from their home on Mandeville Canyon Road, Brentwood, California in December 2005.  It is my understanding that the prosecutor accused Kelley of being the only individual who testified to this fact.  Perhaps if Kelley’s court appointed lawyers had contacted me (or other members of our family), we could have corroborated this and a great deal of other information.  Nevertheless, I cannot understand why the prosecutor would be so convinced that Kelley, a woman she does not know, is a liar, someone who was evidently stalking Cohen for a 1099, or believes that Kelley actually thinks she has a relationship with Bruce Cutler.  Kelley contacted Bruce Cutler regarding her friend Phil Spector.  She was alarmed, and it is indeed bizarre, by the issues related to Phil Spector, the District Attorney of Los Angeles, Leonard Cohen’s embellished stories, and the questions about Phil Spector’s prosecutor.  Kelley does not and never has believed she knows Bruce Cutler.  She believed, as do I, that Phil Spector was entitled to know what was unfolding during her trial.  It has occurred to me that the prosecutor was star struck and impressed with Leonard Cohen. Or, perhaps she views Kelley as threatening due to the fact that Kelley has criticized her and the prosecution in her letters to Bruce Cutler.  Kelley has also asked the IRS, FBI, and others, to investigate her trial an other matters.  It’s difficult to say what would motivate someone, like the prosecutors in this case, I do not personally know but their conduct with respect to my daughter is indeed strange.  That would include the prosecutor’s attempt to have my daughter drugged and committed to a locked facility over her letter writing skills and a non-existent intimate dating relationship with Leonard Cohen.  I remain convinced that this would have placed my daughter in harm’s way and cannot imagine what psychologist would make this decision without actually meeting the subject of their report.  As I’ve said, Kelley and Cohen were never in a brief intimate dating or sexual relationship ever.  There was and remains no domestic violence.  And yet, I understand that the psychologist who wanted Kelley drugged and committed was a domestic violence counselor who would have committed her to a domestic violence institution.  As with many allegations and issues in my daughter’s trial, I have never heard anything as outrageous as this in my entire life.  Kelley explained that she was critical of the prosecutor in her letters to Bruce Cutler and I would assume that this had something to do with the prosecutor’s attempts to have her drugged and committed.  I can assure the court that this would have been a very dangerous situation for Kelley for a number of reasons that would include her heart condition, high blood pressure problems, and other health issues.
47.  It is my understanding that the prosecutor refuted Kelley’s attempts to be released on her own recognizance at her bail hearing.  Evidently she advised the court that Kelley was estranged from her sons, a flight risk, and a danger to her community.  These allegations are absurd.  Kelley was not estranged from her sons although I can confirm that her sons have been through an unconscionable ordeal that has left them confused and upset at times.  Kelley is neither a flight risk nor a danger to her community.  In fact, prior to her arrest she worked with the public on a daily basis for nearly one year. Her work involved a campaign for the ACLU.  I suppose one can say anything if so inclined but it seems to me that evidence supporting one’s allegations should be a requirement.  It would seem to me that no one in the prosecutor’s office or at LAPD actually investigated the issues that led to Kelley’s arrest in the Bay Area.  She did not live in Los Angeles at the time.  Both of her sons did, however. 
48.  It is my understanding that the judge at Kelley’s trial publicly stated that she has no respect for the justice system.  I would not actually call what Kelley has faced “justice” and tend to doubt that anyone sane would either.  Kelley has been slandered, maligned, falsely accused of many things, and now she is evidently being retaliated against.  Who would respect that?  My father was a magistrate and I cannot imagine him engaging in this type of a situation or participating in the destruction of an innocent person’s life.  Times have apparently changed.  I have also heard that the judge would have offered Kelley probation but felt that she wouldn’t abide by an order.  First of all, I cannot imagine what judge would grant Leonard Cohen a restraining order against my daughter.  But, beyond that, it seems impossible to abide by an order that someone is unaware of.  In fact, that does not seem legal.  It does not make any sense at all to demand that someone abide by a court order that 1) they were advised had expired; or, 2) they didn’t know about.  One can safely assume that this is the reason for serving people with legal documents and notifying them of the allegations.  Kelley is the individual who has been relentlessly targeted for years now. 
49.  I would like to reiterate the following:  Kelley and Leonard Cohen did not have a brief intimate or dating relationship.  Since Marty Machat’s death in 1988, Kelley worked as Cohen’s personal manager. In the fall of 2004, Kelley refused to meet with Leonard Cohen and his tax lawyer.  She hired a new accountant and lawyers.  That is what unfolded.  She did not engage in a campaign of harassment but has had her life destroyed over this situation.  I now understand that the latest prosecutor continues to lie about  my daughter.  I have encouraged her to report this information to the Department of Justice; forward the harassing emails to the IRS and FBI; and file a complaint with the Criminal Grand Jury of Los Angeles.  I also advised her to refute the malicious lies and slander, being transmitted to the prosecution by strangers emailing them (copying in my daughters, grandsons, and others), and cannot imagine why this would annoy the prosecution.  If it was so annoying, it would seem wise to contact Kelley immediately or advise the strangers to cease and desist.  I also understand that Kelley was represented by a lawyer during her appeal so contacting him would have been another reasonable option.  Perhaps there is more to the probation violation accusations than meets the eye because it makes absolutely no sense whatsoever.  Kelley’s roommate, Paulette Brandt, is also the target of strangers and the situation is exceedingly disturbing.  I, of course, am concerned about my daughter’s welfare and the welfare of my grandsons.  The court should be as well.  Clearly, Kelley has no access to a military drone and has no history of violence, anger problems, or anything else she has been falsely accused of.  The situation with respect to the military drone Valentine card is one of the most absurd and bizarre situations I have ever heard of in my entire life.  Perhaps this is normal conduct at LA Superior Court.  Kelley obviously does not have a “kill list” but I personally do believe that the prosecutor used this as a means to retaliate against my daughter.
50.  It is my understanding that Leonard Cohen testified that he feared for his safety and the safety of his children and grandchildren.  This statement is absurd particularly given the lengths Leonard Cohen has gone to destroy my daughter.  Leonard Cohen will say anything that serves his own purposes and ulterior motives.  However, Kelley has not seen Cohen in years and refused to speak to him or meet with him prior to their parting of ways so it seems highly improbable that she would suddenly show up at his house.  This may simply be wishful thinking on Cohen’s part. 
51.  I am familiar with a journalist by the name of Mick Brown of the UK Telegraph and have spoken with Mr. Brown in the past.  It is my understanding that Mick Brown advised my daughter that Leonard Cohen made an appearance in Phil Spector’s grand jury – either through his testimony or by statements presented.  I am aware that this information deeply upset and disturbed my daughter.  I am not certain that I understand the type of person who would sit idly by when an innocent person may be serving a life sentence.  But perhaps that’s naïve.  I am aware that Leonard Cohen now has three different versions of a gun story involving Phil Spector before LA Superior Court.  That does not surprise me.  It is my understanding that the prosecutor concealed a version Cohen emailed her from the jury in my daughter’s trial that may very well have undermined Cohen’s testimony in this regard.  I also understand that the prosecutor and Kelley’s lawyers failed to advise the jury that Cohen testified, at her bail hearing, that she never stole from him.  I am also aware that Kelley has attempted to bring this information to the attention of the prosecution and that may also have led to the decision to charge her with a probation violation using an absolutely insane story about a drone card that she did not even create. 
52.  On February 3, 2007, my grandson, Rutger Penick, lost three fingers in an accident at Whole Foods in Brentwood, California.  Rutger was not trained or qualified to use the meat grinder that was the cause of this accident.  I am aware of the fact that the prosecutor and Leonard Cohen raised this horrific incident during Kelley’s 2012 trial and attempted to use it against her in an attempt to gain a conviction.  It is my understanding that Leonard Cohen owes my daughter a tremendous amount of money and has continuously asked him to pay her what is due.  Kelley most definitely would have had Rutger in college full time and he would not have been forced to take a job.  That is simply the truth.  I cannot even conceive of a situation where a mother would have her son’s tragedy used against her in an attempt to gain a conviction.  I find this particular situation unspeakably evil.
53.  It is also my understanding that my younger grandson’s custody matter was used against my daughter in an attempt to gain a conviction against her.  As stated above, my daughter was a wonderful, kind, and devoted mother who was never abusive in any way whatsoever to her children, the children she helped raised, or anyone else.  As I’ve said, it is my belief that Leonard Cohen and Steve Lindsey coordinated the custody matter for reasons that have nothing whatsoever to do with the reality of Kelley’s role as a mother to her sons.
54.  I have recently reviewed the declarations Steve Lindsey, Betsy Superfon, and Robert Kory provided LA Superior Court with respect to my grandson’s custody matter.  I know Betsy Superfon well.   The custody matter was clearly coordinated with the SWAT incident and Kelley’s being taken to King Drew on May 25, 2005.  Kelley kept her son, Ray, home sick from school that day.  It is my personal belief that Kelley, Rutger, and Ray were all afraid of Steve Lindsey.  Apart from his abusive personality and temper, he has a strong tendency to over-react to situations.  I am aware that Kelley asked my grandson, Rutger, to pick his brother up and take him down the street to meet his father. Steve Lindsey had become increasingly aggressive over his new relationship and the baby.  Cloris Leachman was waiting to pick up Ray as the SWAT incident unfolded.  A custody matter was clearly coordinated with the SWAT incident. 
55.  I am aware of the fact that Steve Lindsey was meeting with Leonard Cohen and his lawyer regarding Kelley.  They apparently wanted her to make a deal and Lindsey even had his father, Mort Lindsey, phone Cohen/Kory and then Kelley to encourage all parties to work out a deal.
56.  I am aware that Kelley and her son, Ray, stopped into Cohen’s lawyer’s office in 2005.  I understand that at some time thereafter, Leonard Cohen and his lawyer (a man I never heard of or met) provided Steve Lindsey with declaration in this custody matter.  I also understand that Steve Lindsey was meeting with Leonard Cohen and his lawyer in an attempt to force Kelley into a settlement agreement with Cohen.
57.  I am aware that for months Leonard Cohen attempted to force Kelley into a settlement deal with him and I understand that he offered her 50% community property and was willing to pay her what he owed her.  Kelley refused to enter into any deal with Leonard Cohen and was concerned about the legality of doing so.   
58.  My daughter has no history involving any type of anger or anything that would require anger management.  I find the prosecution’s ongoing allegations that my daughter has a propensity for violence deeply disturbing and believe this might relate to some form of retaliation on their part. 
59.  My daughter, Karen Lynch, husband, and I were shocked that Kelley’s trial lawyers did not contact us prior to or during her 2012 trial.  Karen Lynch left messages for Kelley’s lawyers and we all would have been willing to provide declarations and/or testify.  Karen also advised Kelley’s public defender that she would like to send clothes for her to wear during her trial.  She heard nothing back.
60.  I am convinced that these matters were orchestrated, involve legal issues and other serious matters, and Leonard Cohen, Steve Lindsey, and others, have done everything in their power to hurt and destroy my daughter.  I am well aware of the fact that the main issues relate to Leonard Cohen, the IRS, and Phil Spector.
61.  I understand that prosecutor Sandra Jo Streeter attempted to use a childhood friend of my grandson’s against Kelley.  We have known Jonathan Maihart since he was a child.  He is from a Persian family and, to the best of my knowledge, was not a member of a Latino gang.  Kelley hired many teenagers to work for her greeting card company.  Jonathan Maihart was one of those teenagers and, from time to time, would handle things like picking up documents, etc. for Kelley.  We have not seen Jonathan since 2005 when he stopped working for Kelley and her greeting card company. Evidently the prosecutor advised the court that Jonathan Maihart was a Latino gang member.  I am not sure why this was raised, at all, at Kelley’s bail hearing.  It sounds, in keeping with the rest of Kelley’s trial, ludicrous.
62.  It is my understanding that Leonard Cohen is a Canadian citizen cannot reside in Canada due to tax and residence problems.
63.  I am aware of the fact that the prosecutor is under the impression that my daughter is not permitted to speak or address the things she has gone through.  That apparently includes contacting individuals like Paul Shaffer of the David Letterman show.  My daughter, Kelley, knows Paul Shaffer due to her friendship with Phil Spector.  In fact, my younger daughter is acquainted with Paul Shaffer also.  As I’ve said, it seems that Kelley was prosecuted over issues related to her speech that are clearly protected by the United States Constitution. 
64.  It is my understanding that Kelley was dragged into the Phil Spector matter after an anonymous tip was placed to the DA’s office about her friendship with Phil Spector.  I am aware that Kelley was told, by an investigator at the DA’s office, that she was probably a witness in the Phil Spector mater.  I would assume that Leonard Cohen and/or Steve Lindsey were involved with that anonymous tip.
65.  It is my understanding that Kelley has been relentlessly harassed by individuals she does not know. These individuals include a lawyer from the Bay Area, Stephen Gianelli, and Leonard Cohen’s fan, Susanne Walsh.  My husband and I do not know Stephen Gianelli but this man actually phoned us.  It is my understanding that these individuals continue to harass and contact my grandsons, Rutger and Ray, even though they have both asked him not to.  This is a deeply disturbing situation as I also understand that the underlying reason for the probation violation relates to Stephen Gianelli, Susanne Walsh, and Ray Lawrence’s contacts with the City Attorney’s office about my daughter.  I absolutely advised my daughter to refute the malicious lies and slander particularly given the fact that her sons, sister, and others were copied in.  I believe the City Attorney should have immediately put an end to this activity as my family, and in particular my grandsons, have been relentlessly targeted and suffered tremendously.  It is also my understanding that one of the lawyers at the City Attorney’s office actually actively encouraged a stranger to harass my daughter and raised issues regarding a conspiracy.  It is definitely my opinion that the situation with respect to the City Attorney and my daughter sounds conspiratorial.  Why would a professional lawyer encourage someone who has relentlessly harassed and terrorized my family and many others to email Kelley?  I tend to doubt there’s a viable explanation for that. 
66.  I am aware that Kelley attempted to refute slanderous allegations being raised by a stranger in emails with the City Attorney’s office copied in.  I personally advised my daughter to refute those statements and remain convinced that it is in my daughter’s best interests to continue to document everything in emails with a variety of parties copied in.  That would include the IRS, FBI, DOJ, Treasury, FTB, and Phil Spector’s attorney.
67.  It is my position that when Kelley reported Cohen’s tax fraud to the IRS, and other agencies, she exposed herself to the obstacles that have arisen.  I also believe that the allegations that she brought to the IRS re. Cohen’s tax fraud and the Phil Spector matter are the reasons my daughter was on trial and is now on probation. 
68.  Finally, it is my personal opinion that this case should be dropped and the parties targeting my daughter should be held accountable for their actions.  I also believe her conviction should be dismissed.  It is astounding to think that a court of law would permit this travesty of justice to continue.  I take great offense at Judge Robert Vanderet’s slanderous statements about my daughter.  I do think it is important to note that she is His Holiness Kusum Lingpa’s lineage holder and friends with many inconceivably great Tibetan lamas.  Not one of them has advised her that she has any type of mental health issues.  The reason for that is due to the fact that she does not.
I declare under penalty of perjury, under the laws of the state of California and Texas, that the foregoing is true and correct.  This Declaration was signed this 23rd day of December, 2013.

`                                                                       ____________________________
                                                                              Joan Marie Lynch