Thursday, June 18, 2015

Declaration of Paulette Brandt Re. Leonard Cohen Case No. BC338322


I, Paulette Brandt, declare:
1.               I am a citizen of the United States who currently resides in Los Angeles, California.  I am a
close friend of defendant, Kelley Ann Lynch.  I am over the age of 18 years.  I have personal knowledge of the facts contained in this declaration and if called upon to testify I could and would testify competently as to the truth of the facts stated herein.
2.               I would like to address why, in a prior declaration, I confirmed that Kelley and I kept in touch
in the summer and fall of 2005.  Prior to her phones being shut down, Kelley and I stayed in touch by phone.  Thereafter, I would drop by and visit her primarily on Wednesday mornings throughout the summer and fall of 2005.  August 24, 2005 happened to fall on a Wednesday.  I would frequently arrive quite early in the morning.  I never once saw Kelley fail to answer her door or behave in any manner that would suggest she attempted to evade service.  It seems to me that certain parties feel fairly jaded when speaking about what Kelley was dealing with throughout this period of time.  She could not afford to buy food for her son, herself, or her animals.  I have always assisted people when they fall upon hard times and Kelley is no exception.  We are also quite close friends.  I brought items that she needed, am a known animal lover, picked up dog and bird food, and also brought hygiene items.  I thought it might cheer Kelley up if I helped her color her hair.  She was obviously no longer able to afford her former hairdresser, Mario Lara.  Throughout the summer of 2005, I brought very dark, nearly black dye and helped Kelley color her hair.  I would also help cut it.  She wore it quite short at that period of time.  At some point, I personally felt the dark hair made Kelley look harsh and commented on this.  I only recall that some time after Labor Day 2005, I began bringing blonde dye and this changed Kelley’s looks immensely.  In fact, during the period of time she has stayed with me, I have bought her both dark brown and blonde dye so this is not a unique situation for Kelley.  She frequently changes her hair color and one day might have black hair and the next day it is platinum. 
3.               Kelley and her mother, Joan Lynch, spent a great deal of time in November and December
reviewing legal documents.  Kelley took shorthand notes of Joan’s comments and prepared a draft declaration for her mother to review.  Joan confirmed for Kelley that the declaration represented what she wanted to include and the content of that document was based entirely on her comments.  Kelley mailed the declaration to her mother who confirmed receiving it and told both of us she was mailing it back as soon as possible.  She was concerned there might be a delay over the Christmas holidays.  I know Kelley’s mother was very concerned about her at the time.  She was facing two hearings in two matters related to Leonard Cohen.  I read Joan’s entire declaration to her and she, based on her concerns about the holiday mails, authorized me to conform her signature on the document.  We agreed that she was sending the original signed document which would be presented to the Court.  However, on December 26, 2014, Joan Lynch had a stroke and lost a great deal of her memory.  My own mother, a woman who is older than Joan, has very severe memory problems so I am familiar with that issue.  While I frequently spoke to or said hello to Joan prior to her stroke, she usually sounded in full possession of her faculties.  I under that, as of this time, Joan no longer really knows who I am.  Due to this tragic situation, which Leonard Cohen appears to be attempting to exploit, the Declaration of Joan Lynch’s which I conformed, in accordance with her personal authorization (which she acknowledged was an oral power of attorney), was submitted to the Court.  Joan Lynch spent a considerable amount of time working with Kelley on her declaration and her version of events, and recounting of things she witnessed, deserves to be heard.  She is a lovely, bright woman who, together with Jack Lynch, Leonard Cohen has also falsely accused.
4.               I am aware that Kelley made a conscious decision not to submit a declaration to this Court
from Chad Knaak.  The reason for this is the relentless, years long targeting of her sons.  Chad Knaak is a childhood friend of Rutger Penick’s.  Rutger is Kelley’s older son and a wonderful young man who, as is true for Ray Charles Lindsey, his older brother, have suffered tremendously throughout these difficult 10 years.  As I was present when Kelley asked Chad Knaak to phone Leonard Cohen’s lawyer, I felt I should explain what I personally witnessed and heard that day.  Kelley instructed Chad Knaak to advise this lawyer that she was not served Cohen’s lawsuit and IF he attempted to serve her she would hold him accountable.  I have no recollection as to whether or not she said “again” but I do know that process servers, repo men, and others, were leaving the business cards on her door and documents on the ground outside her door.  I would also like to point out that, if a process server actually visited Kelley’s home, he would have understood that she had a doorbell.  He therefore would not have knocked but would have rung the bell.  I distinctly recall the bell directly to the left of the door.  It lit up at night so one couldn’t miss it. 
5.               Since submitting my declaration to this Court, I have been routinely harassed by Stephen
Gianelli and Leonard Cohen’s fan, Susanne Walsh.  Stephen Gianelli seems particularly interested in slandering and intimidating me.  It does concern me that, as a long time resident of Los Angeles, I apparently do not have access to the same services an individual such as Leonard Cohen does.  Leonard Cohen is, of course, a Canadian citizen staying in this country as a guest of our government. 
6.               In June 2014, I sent my former tenant a rent demand letter which she disregarded.  I then filed
a Complaint in Small Claims Court.  During the first hearing, after the Court instructed the parties to participate in mediation and show one another evidence, Karina Von Watteville informed me and the mediator that she phoned Robert Kory (Cohen’s lawyer) and was advised to sue Kelley.  Kelley had sent Karina Von Watteville a handful of cease and desist letters, over the course of months, addressing her obsession with her, slander, and remarks to others that she planned to have Kelley “investigated” and “get her in trouble.”  The call to Robert Kory was Karina Von Watteville’s response to my rent demand letter.  She previously advised me that she does not know Leonard Cohen.  At the second Small Claims Court hearing, the same situation occurred, and this time (in front of the mediator), Karina Von Watteville began slandering Kelley, ranting about Leonard Cohen and Robert Kory, and showed us the handful of cease and desist letters which she stated were evidence in my Small Claims matter.  She said she planned to tell the Court that Kelley was trying to have her deported by ICE.  At no time did Kelley ever mention having Von Watteville deported.  This is simply how Karina Von Watteville thinks.  I was awarded a judgment of $6,700.  Suddenly, Stephen Gianelli ended up representing Von Watteville.  He wrote the legal document she provided the Small Claims Court and began harassing us over this matter.  I then lost the Small Claims case.  I personally do not believe the call to Robert Kory followed by Stephen Gianelli’s legal representation were mere coincidences. 
I declare under the penalty of perjury under the laws of the State of California that the foregoing is true
This declaration was executed on this 16th day of June 2015 in Los Angeles, California.

                                                            PAULETTE BRANDT


I, Paulette Brandt, declare:
1.               I am a citizen of the United States who currently resides in Los Angeles, California.  I am a
close personal friend of defendant, Kelley Ann Lynch.  I am over the age of 18 years.  I have personal knowledge of the facts contained in this declaration and if called upon to testify I could and would testify competently as to the truth of the facts stated herein.
2.               I have worked in the entertainment industry for years and have held positions with Apple
Records, ABKCO Records, Columbia Pictures, and Phil Spector.
3.               I first met Kelley Lynch when Phil Spector and I visited Marty Machat’s office years ago. 
Marty Machat was an entertainment industry attorney who represented Phil Spector and Leonard Cohen.
4.               When Kelley moved to Los Angeles in the early 1990s, we reconnected and she and I began
communicating regularly and developed a strong friendship.  She is a close personal friend of Phil Spector’s and worked as his assistant from approximately 1988 until sometime in 1991.  I then went back to work for Mr. Spector.  I worked as his personal assistant from some point in 1991 until 2002.
5.               Throughout the summer and fall of 2005, I visited Kelley at her home in Brentwood,
California approximately once a week.  I usually would arrive at her house around 8 A.M. and stay for a few hours, sometimes longer.  She and Leonard Cohen parted ways at some point in the fall of 2004 and, as of April 2005, she had reported allegations that he committed tax fraud to Internal Revenue Service.  It is my understanding that Leonard Cohen then withheld commissions she was due and refused to address her ownership interest in certain intellectual property.  This situation caused financial ruin for Kelley and, it is my personal belief, led to the lawsuit in this case.
6.               When I visited Kelley in the summer and fall of 2005, I would bring food for her animals, hair
dye, and other items she could not afford.  Kelley’s phone and then electricity were shut off.
7.               During this period of time, I would also dye and cut Kelley’s hair.
8.               Kelley did not attempt to evade service of Leonard Cohen’s lawsuit.  She has a legal
background and has been extremely frustrated over this situation.  Cohen’s lawyers absolutely refused to communicate with her, at all, throughout the entire litigation in this case.  She was representing herself and wanted to file an answer to Cohen’s Complaint but was unaware of the actual allegations raised.  We both read the news accounts. 
9.               I was with Kelley when she repeatedly attempted to Cohen’s lawyers about their failure to
serve her, her interest in participating in discovery, and other issues related to this and other cases that involved the two of them.  It is my understanding that the default judgment in this matter was used against Kelley in Natural Wealth’s lawsuit against Leonard Cohen.  That lawsuit was not resolved until September 5, 2008 when the judge entered his opinion and relied on the default judgment in this case.
10.           It is my personal opinion that Leonard Cohen saw an opportunity not to serve Kelley,
understood she was not represented by counsel, and felt it would be easier to simply obtain 
a default judgment against her.  Kelley did not have the money to hire an attorney.  She didn’t even have the money to travel downtown to pick up a copy of the Complaint.  However, that is not Kelley’s responsibility.  The Plaintiffs are responsible for properly serving defendant. 
11.           Kelley answered her door whenever I visited.  She was not attempting to avoid or evade
anyone.  She also answered it in my presence when she was served legal documents in unrelated matters.  Because Kelley was bankrupted over this situation, her creditors filed lawsuits as well. 
12.           The process server indicates that he attempted to serve Kelley at 8:45 AM on August 23, 2005
and notes that he knocked but no one answered.  Kelley had a doorbell; the back of her house had wall to ceiling plate glass windows; she would not have had the lights on in the morning; and, Kelley always turns the lights out when she leaves a room. 
13.           I visited Kelley on August 24, 2005 when the process serve allegedly served her.  I arrived, as
was customary, quite early in the morning.  I recall Kelley’s frustration because Leonard Cohen’s lawsuit had been filed a week or so earlier and she still had not been served.  I had read about the case online.  The LA Times brought the lawsuit to Kelley’s attention and asked her for a quote.  I suggested that Kelley phone Cohen’s lawyer to ask him if there was a problem with service.  We discussed this while I cut and dyed Kelley’s hair a very dark shade of brown, almost black.
14.           Kelley and I then went online and found Cohen’s lawyer’s name in some of the articles
published at that time.  I was present when Kelley googled this lawyer’s name and phone number.  We then walked outside to her son’s guesthouse.  Kelley went inside and I stood in the doorway.  Rutger and his friend, Chad Knaak, were inside with Kelley. 
15.           Due to the fact that Kelley’s phone had been turned off, Kelley asked Chad to phone Cohen’s
lawyer to advise him that she was not served the lawsuit and IF he attempted to serve her she would hold him personally accountable.  Kelley handed Chad the paper she had written Scott Edelman’s name and number on.  She asked Chad to be polite and professional when he spoke to Edelman.  Chad called and had a conversation with someone at the law firm of Gibson, Dunn.  Chad explained that he was Kelley’s housemate and repeated the message that she had NOT been served.  While Chad was on the phone with Cohen’s law firm, Kelley asked him to inform the party on the other end that the lawsuit was retaliation over the fact that she reported allegations related to Cohen’s alleged tax fraud to Internal Revenue Service and viewed the lawsuit as retaliation.
16.           At the time Leonard Cohen filed his lawsuit, he granted at least one interview to MacLean’s
Magazine and his dissemination of defamatory statements about Kelley caused severe harm to her reputation.  This lawsuit, and the news accounts of what occurred, have also exposed Kelley to quite a number of individuals who have relentlessly targeted her, members of her family, close friends, and others.
17.           From approximately June 2005 through October 2005, I personally dyed Kelley’s hair very
dark brown.  On August 24, 2005, Kelley had very short, extremely dark (nearly black) hair, large blue eyes, was extremely thin, and was approximately 5’6” tall.  She did not resemble the individual described in the proof of service at all.  It is impossible that a process server would describe her, at this time, as having blonde hair when her hair color was almost black; black eyes when her eyes are very bright blue; or being of medium build when she was exceedingly thin.  It is possible that a process server could view Kelley as being approximately 5’7” but that is the only detail that I personally believe could be used to describe Kelley as of August 24, 2005.
18.           I visited with Kelley for quite a long time that day and have reviewed my records from that
period.  Kelley, Rutger, Chad, and I were alone at Kelley’s house.  There was no other female present and Kelley did not have a female “co-occupant.”  Chad Knaak was staying with Kelley and Rutger.  No one came to the door that morning and the process server clearly relied on an out-dated description of Kelley.
19.              I attended the January 17, 2014 hearing in this case and planned to testify.  When Kelley and
I phoned Department 24 before the hearing, we were told that nothing else had to be filed and she should simply show up for the hearing with witnesses.  Kelley’s friend, Palden Ronge, also attended that hearing with us.  He also visited Kelley throughout the summer and fall of 2005.  Neither of us was given the opportunity to testify.
20.           There is no way the process server saw Kelley on August 24, 2005.  I also do not believe the
process server visited her house on approximately six other occasions.  Kelley was home constantly throughout this period.  She had been in an accident (where she was hit by a careless driver) and left without transportation.  Therefore, I would bring her supplies and items she needed.  She also did not have any money at this period of time.  Every time I visited, Kelley would answer the door and she was clearly not attempting to avoid or evade anyone.  I am aware that there are problems with process service and issues related to lack of service.  On at least one occasion, I personally found legal documents (unrelated to this case) thrown on the ground outside her home.  I am presently assisting with a case where lack of service is an ongoing problem.  In fact, a Bankruptcy Court judge recently dismissed a judgment due to lack of service and fraud in connection with the proof of service.  This appears to be a growing problem in our legal system.
21.           This situation has been utterly frustrating for Kelley because Cohen’s lawyers refused to speak
to her, continued to behave in an unprofessional and hostile manner towards her, and she did not have an opportunity to actually read Cohen’s Complaint until it was posted online in the spring of 2010.  At that time, Kelley called me and we were in disbelief at the allegations Cohen’s lawsuit raised.  Those allegations, from what I can tell, are contradicted by the evidence.  I have become relatively familiar with the corporate records, and other evidence, related to this case.  That would include, but is not limited to, federal corporate tax returns where Kelley is listed as a partner, stock certificates, and contracts.
22.           Shortly after discovering the Complaint online, Kelley moved to Ft. Lauderdale, Florida.  She
did not return to Los Angeles (apart from the period when she was incarcerated for allegedly violating Leonard Cohen’s restraining order by requesting tax information, etc.) until June 2013 when I invited her to stay with me.  Kelley has been my roommate for over a year and a half now.  I view her as one of my dearest friends and a blessing.  What has happened to her is a disgrace.
23.           Since Cohen filed this lawsuit in August 2005, Kelley has continually maintained that she was
not served the lawsuit.  She and Rutger were evicted from their Brentwood home in December 2005.  I personally believe that Cohen and his lawyers feel they can use abusive litigation tactics, including fraudulent restraining orders, against Kelley because she has been representing herself for the past 10 years and has no money to hire an attorney.
I declare under the penalty of perjury under the laws of the State of California that the foregoing is true
This declaration was executed on this 13th day of March 2015 in Los Angeles, California.

                                                            PAULETTE BRANDT

I, Paulette Brandt, declare:
7.               I am a citizen of the United States who currently resides in Los Angeles, California.  I am a
close friend of defendant, Kelley Ann Lynch.  I am over the age of 18 years.  I have personal knowledge of the facts contained in this declaration and if called upon to testify I could and would testify competently as to the truth of the facts stated herein.
8.               I have worked in the entertainment industry all of my adult life and held positions at Apple
Records, ABKCO Records, Columbia Pictures, and worked as Phil Spector’s personal assistant from approximately 1991 through 2002.  I met Kelley through Phil Spector.
9.               Kelley and I became quite close after she moved to Los Angeles and we spoke regularly over
the years.  After Kelley was evicted from her home in December 2005, and ended up homeless due to the situation with Leonard Cohen, she and I lost touch for a spell.  We touched base in 2010, when she was visiting Los Angeles. 
10.           At some point in early 2013, Kelley sent me a note through my Facebook account.  I
responded with an email in February 2013 that she posted on her blog.  See Exhibit 1 attached hereto and made a part hereof.
11.           Following that, I received an email from a stranger, Stephen Gianelli, attempting to turn me
against Kelley and slandering her.  Since that time, I have received countless harassing emails from this individual and another individual by the name of Susanne Walsh (Leonard Cohen’s fan).  I do not respond to his emails.  He frequently copies in Kelley’s sons, sister, Deputy City Attorney Vivienne Swanigan, and Investigator William Frayeh, an investigator on the Phil Spector case.  Gianelli and Walsh, together with others, appeared to work in tandem.  In fact, Gianelli worked with Michelle Blaine, Phl Spector’s former assistant to target and shut down Kelley’s blog and email accounts.  Stephen Gianelli’s  harassing emails continue until this day.  I have contacted LAPD’s TMU about this matter and spoken with LAPD detectives about this harassment.  I have also spoken with Investigator Frayeh about the harassing emails as has Kelley.  This situation is material to Leonard Cohen’s lawsuit and default judgment.  Stephen Gianelli has publicly stated that he has communicated with Leonard Cohen’s lawyers since 2009.  I have attached some of the most recent harassing emails I’ve received.  The content relates to Phil Spector, DNA evidence on the ammunition, and the motion Kelley is filing at this time in Case No. BC 3383232.  See Exhibit 2 attached hereto and made a part hereof.
12.           On or about June 1, 2013, Kelley returned to Los Angeles, California.  She had not resided
here, apart from her visit with Rutger in 2010, since the fall of 2006.  She has resided with me
since June 2013.  I have spoken with Kelley’s appellate attorney, Francisco Suarez, about this campaign of harassment.  He too received emails from these individuals, for over a year, and asked me to serve as a witness for Kelley.  Mr. Suarez advised Kelley to forward these emails to the FBI and bring them to the attention of LAPD’s TMU who were involved with Kelley’s arrest in March 2012 in connection to her alleged violation of a restraining order Leonard Cohen obtained and her general requests for tax information.  Many people who have provided Kelley with declarations have been harassed.  Kelley, I, her sons, and others harassed immediately after she moved in with me.  In July 2013, her younger son, Ray Charles Lindsey, provided her with a declaration addressing this campaign of harassment. It has made him physically ill.  Kelley was and remains concerned about the effects of this situation on both of her sons.  Her sister’s lawyer advised Gianelli to cease and desist.  He refuses to do so.  I have spoken with Kelley’s mother, who authorized me to sign her declaration that was submitted with the motion, and she expressed grave concern about this situation.  See Exhibit 3 attached hereto and made a part hereof.
13.           Kelley and I recently were interviewed by Truth Sentinel, a small internet radio program.  We
discussed Leonard Cohen and Phil Spector and these cases.  We mentioned the organized email harassment campaign.  Stephen Gianelli then went onto that site and began slandering Kelley and posting comments about the forensic science in Phil Spector’s case.  I personally believe that this activity is meant to discredit Kelley, undermine her potential as a credible witness, and also serves to intimidate people who support her, and isolate Kelley.  See Exhibit 4 attached hereto and made a part hereof.
14.           I have provided the Court with a separate declaration specifically addressing issues related to
Cohen’s failure to serve Kelley the Summons & Complaint in this case.  Given the fact that I was with Kelley on the morning of August 24, 2005 and was present when Chad Knaak phoned Cohen’s lawyer, I believe it is abundantly clear that she was not served.
15.           I have witnessed Kelley’s attempts to obtain the transcript for the March 23, 2012 hearing
where Cohen was asked if Kelley stole from him and replied “just my peace of mind.”  That is highly relevant and material testimony that critically undermines Cohen’s “misappropriations” argument and I will point out that the “expense ledger” covers “misappropriations’ in 2004.  Kelley spent over a year and a half contacting LA Superior Court and the Court Reporter’s office.  I have also called them on her behalf.  For over a year and a half Kelley was told that, because Judge Mayerson retired, she would be unable to obtain transcripts of this hearing; the hearings were recorded but no one knew where the tapes were maintained or how she could obtain them; without a present courtroom department for Judge Mayerson no one could assist her; a court reporter would not have been present during a misdemeanor hearing; and other similar comments.  Finally, on or about June 17, 2014, Kelley located and reached the court reporter who was present for the March 23, 2012 hearing.  I was present when Kelley spoke to the court reporter in June 2014 for the first time and loaned Kelley $75 for the transcript.
16.           On or about August 14, 2014, Kelley received the transcript for the March 2012 hearing after
diligently pursuing it since her release from jail, in the Cohen restraining order violation matter, mid-September 2012.
17.           Since July 2014, Kelley has diligently worked on the motion she has submitted to the Court.  A
lawyer she worked for in her 20s advised Kelley that the legal issues raised in these matters had his head spinning.  Kelley has spent countless hours researching legal issues related to this motion.  She also did not have access to her evidence.  I drove to the Bay Area, where it was stored, and picked it up for her. 
18.           The default judgment has caused problems for Kelley with respect to her 2004 and 2005
federal and state tax returns.  Leonard Cohen refuses to provide Kelley with a 1099 for 2004 and corporate tax information for 2004 and 2005.  She cannot file her tax returns without this information. 
I have personally spoken with IRS, and other tax authorities, on Kelley’s behalf.  IRS confirmed that they are not in receipt of a 2005 required form 1099 from Leonard Cohen for Kelley; IRS has not received K-1 partnership documents for companies Kelley has a legal partnership in; and, IRS advised me that Kelley should contact Leonard Cohen personally to request this information and ask him to rescind the K-1s his company, LC Investments, LLC, transmitted to IRS in 2004 and 2005 indicating that Kelley is a partner on that entity.  Problems have also arisen due to the fact that Kelley was included on Traditional Holdings, LLC 2001, 2002, and 2003 federal tax returns, paid taxes, but the Court determined (when entering the default against her) that she has no legal interest in that entity.  The IRS records and filings and State Court judgment contradict one another. 
19.           I worked in Statement Preparation at Columbia Pictures in the 1980s.  I have never seen an
accounting that resembles the “expense ledger” Cohen used to support the May 2006 default judgment.  It is a meaningless list of numbers with no information about corporate ownership interests, equity, assets, or liabilities.  Any advances to Kelley and Cohen are missing or have been falsely represented as being “misappropriated.”  Advances are customary in the entertainment industry.  Leonard Cohen’s loans are not addressed.  He has apparently taken loans of approximately $6.7 million in connection with the Traditional Holdings, LLC entity alone.  I have reviewed the corporate records, stock units, agreements, and federal tax returns and am familiar with the evidence in general.  Kelley has a legal interest in numerous “Cohen related” entities; is owed commissions for services rendered; and the “expense ledger” appears to be evidence of financial and accounting fraud. 
20.           I would like to briefly address the restraining orders Cohen has obtained against Kelley.  I
believe he has used these as a litigation tactic and they thoroughly discredit Kelley.  I have spoken directly with the Boulder Combined Court on approximately three separate occasions in the past couple of years about the restraining order Cohen obtained against Kelley in September 2008.  On each occasion, the Boulder Combined Court advised me that the 2008 order expired on February 15, 2009 and the judge entered the Motion to Dismiss (that Kelley filed after the hearing) on January 12, 2009.  Boulder Combined Court also advised me that the order Cohen obtained there was not a “domestic violence order.” 
21.           I have also spoken with Los Angeles Superior Court about Cohen’s registration of the 2008
Boulder order in California on May 25, 2011.  I have been advised by Los Angeles Superior Court that this order is a Family Court matter and relates to “domestic violence.”  Kelley was prosecuted in 2012 under domestic violence statutes.  I am addressing this issue because Michelle Rice, in her January 4, 2014 declaration submitted to this Court, mentioned “criminal restraining orders” they obtained against Kelley.  Those orders, granted without a hearing, are “domestic violence related” orders.  Somehow the original 2008 Boulder order has transformed into a “domestic violence” matter.
22.           Kelley is filing a motion to address the wrongful restraint related to Cohen’s litigation tactic
restraining orders in the next week or so.  She has been researching those issues diligently as well. 
23.           I would finally like to point out that from 2005 until the present, Leonard Cohen’s legal
representatives refuse to communicate with Kelley.  She was not served the Complaint in this matter and has  been served documents that were not filed with this Court (including the Objections document Jeffrey Korn served her with the day before the January 2014 hearing and Korn’s proposed order).  It is extremely obvious that Leonard Cohen and his legal representatives have abused the justice system, restraining order process, and Kelley.  Clearly, they believe they can take advantage of her because she is self-represented.  The tactics that have been used against her are appalling.
24.           I was present when Kelley phoned Jeffrey Korn, attorney of record in this case, to advise him
that she planned to file this motion and serve him.  He advised her that he didn’t know if he was the attorney of record and she could serve him a “courtesy copy.”  Jeffrey Korn is the attorney of record in this case.  Stephen Gianelli has not entered a formal appearance in this case and Kelley has been advised to address the Cohen legal issues Gianelli emails her about with Jeffrey Korn as he has filed a formal appearance on Cohen’s behalf.
I declare under the penalty of perjury under the laws of the State of California that the foregoing is true
This declaration is executed on this 13th day of March 2015 in Los Angeles, California.


                                                            PAULETTE BRANDT