Wednesday, November 12, 2014

Kelley Lynch Formal Request To Leonard Cohen's Lawyers To Inspect Corporate Records, Stock Certificates, Tax Returns, Corporate Agreements, Etc.

From: Kelley Lynch <>
Date: Wed, Nov 12, 2014 at 1:42 PM
Subject: Request To Inspect Corporate Books & Records
To: Jeffrey Korn and Richard Westin cc:  Greenberg Glusker and Multiple Parties

Jeffrey Korn and Richard Westin,

I am formally requesting [the opportunity] to examine the corporate books and records of LC Productions, Inc., Stranger Music, Inc., Blue Mist Touring Company, Inc., LC Investments, LLC, Traditional Holdings, LLC, and Old Ideas, LLC.  I would like to make arrangements to review these records, all business files and accounting records (Leonard Cohen removed from my offices), federal and state tax returns, stock certificates and ledgers, K-1 partnership documents, any information with respect to a "mistake" Richard Westin rectified, the non-revocable intellectual property assignments to Blue Mist Touring Company, Inc, the failed intellectual property assignments to LCI and TH; all corporate agreements and agreements related to the formal assignments to Blue Mist, all royalty statements related to the formal assignments to Blue Mist, and all information related to the probability that these assets were removed from BMT and placed in another entity or individual's name.  I would also like access to any IP asset valuations.  

I was not served the [lawsuit] or judgment.  The Court does not have jurisdiction over me.  The judgment is void.  The Court does not have jurisdiction over the entities inserted into the default judgment but not named as parties to the suit.  TH has no ties to California.  BMT has forfeited its right to do business in California and is a Delaware entity.  LCI collected royalties for assets owned by BMT.  TH sold assets owned by BMT.  Richard Westin wrote me that, when he formed Old Ideas, LLC, he understood I had a 15% interest and confirmed that it was a partnership.  Stuart Fried was copied in on that email thread in June 2004.  Leonard Cohen agreed to assign all Dear Heather IP and contracts to that entity and planned to use it for touring.  Cohen testified that all items related to "Dear Heather" are on the fraud ledger.  "Dear Heather" is not mentioned on the ledger.  It's a meaningless list of numbers.

I would also like to request access to information related to the lithograph deal Cohen pursued as I was negotiating that.  And, I would like to see Sony/ATV's October 21, 2004 offer for the third IP deal and any subsequent offers.  Cohen testified that he was "examining" this matter.  [New West Records deal]

I would like to point out that in approximately October 2004, my lawyers transmitted the corporate books and records, including stock certificates and assignments, to Greenberg, Glusker on behalf of Cohen.  Those books related to BMT, LCI, and TH.  I had no other records.  Cohen and/or his daughter removed whatever they felt entitled to from my office - including my business records.

Kelley Lynch

P.S.  I would also like to inspect the alleged trust agreement proving I held my interest in these entities/property in trust for Cohen, all trust assignments, and have access to information related to the third "charitable remainder trust" Greenberg maintained.  There were only two so I'm unclear about Judge Babcock's order.