Wednesday, July 29, 2015

Kelley Lynch's Email to Leonard Cohen's Lawyers Re. Motions She Filed Today With LA Superior Court

From: Kelley Lynch <>
Date: Wed, Jul 29, 2015 at 1:24 AM
Subject: Motions Filed 07.28.15 - Case No. BC 338322
To: Dan Bergman <>, Michelle Rice <>, "*IRS.Commisioner" <*>, Washington Field <>, ASKDOJ <>, "Division, Criminal" <>, "Doug.Davis" <>, Dennis <>, MollyHale <>, nsapao <>, fsb <>, rbyucaipa <>, khuvane <>, blourd <>, Robert MacMillan <>, a <>, wennermedia <>, Mick Brown <>, "glenn.greenwald" <>, Harriet Ryan <>, "hailey.branson" <>, "stan.garnett" <>, Mike Feuer <>, Opla-pd-los-occ <>, "Kelly.Sopko" <>, Whistleblower <>, Attacheottawa <>,

Daniel Bergman and Michelle Rice,

I filed numerous documents with LA Superior Court today.  Those documents include the following:  Motion to Strike Memorandum of Costs; Motion to Vacate Renewal of Judgment; Motion to Vacate Domestic Violence Order; and two Notices of Appeal.  The Notices of Appeal relate to the Ex Parte Application Order sealing documents and the Court's denial of my Motion for Terminating Sanctions.

I am attaching hereto a copy of the Motion to Strike Memorandum of Costs and Motion to Vacate Renewal of Judgment.  

I returned home from downtown quite late and have not had access to Paulette's scanner.  Therefore, in the morning, we will scan and serve you the conformed cover sheets, signature pages, and proof of service for all documents apart from the Motion to Vacate the domestic violence order.  Michelle Rice is the attorney of record in that case and there is no agreement with respect to email service.  Due to the fact that, while Scott Edelman was served, issues have now arisen with respect to service and my Motion to Vacate, unless the Court orders me to serve you electronically (as is the case in Case No. BC338322), I will serve those documents electronically.  The Motion to Vacate the domestic violence order was placed in the mail tonight.  The attorney of record, Michelle Rice, will receive those documents.

The Notices of Appeal were also mailed.  As I was previously asked (prior to the agreement to serve you electronically) to serve Daniel Bergman physical documents in Case No. BC338322, I also mailed the Notices of Appeal to him early this evening.  I will scan those Notices and email them to you tomorrow.

Please note that one motion contains a schedule of exhibits with respect to the Motion for Terminating Sanctions.  I want to remind you that Judge Hess personally informed both of you (who asked the question at the time) that no future documents had to be filed under seal.  This conversation took place at the Ex Parte hearing.  I did not attach the corporate evidence, etc. itself.

As a courtesy, I also enclose herewith one document (Motions filed 07.28.15) with the motions and exhibits/declarations contained therein.  I have also enclosed the separate documents that were filed.  

If you have any questions, please let me know.

Kelley Lynch