Saturday, September 26, 2015

Leonard Cohen's Lawyer Should Hit Reply All & Ask Her Own Questions As The Representative Of The Actual Master Mind & Attorney Of Record

From: Kelley Lynch <>
Date: Sat, Sep 26, 2015 at 8:37 AM
Subject: The Criminal Stalker Proxy's Ongoing Harassment, Attempts To Elicit Information, Etc.
To: 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 <>, "mayor.garcetti" <>, Opla-pd-los-occ <>, "Kelly.Sopko" <>, Whistleblower <>, Attacheottawa <>,

Michelle Rice,

Let me know if I can answer any of these questions for you or the proxy operative.

Thank you.

Kelley Lynch

From: Stephen R. Gianelli <>
Date: Sat, Sep 26, 2015 at 7:46 AM
Subject: Important

Finally, Ms. Lynch, I would argue (all these should be separate argument headings to avoid waiver on appeal) that is is not legally possible to for a defendant to make a “general appearance” in a civil action AFTER his or her default has been entered unless and until the default has been set aside (which has not been done in BC338322, obviously).

Note the last sentence of CCP 1014. I believe there is authority that a defendant is NOT entitled to “notice” of pleadings filed in an action after his default is entered. If that is true then it follows he or she cannot “appear” in the action as that phrase is used in section 2014.

Also, look at all of the motions and pleadings specified in CCP 2014 that constitute an “appearance”. NONE of these pleadings (for instance an answer, or a demurrer) may be filed by a defendant who is in default.

On reflection, I just don’t think it possible for a defendant who is not only in default, but whose default judgement has been entered, to make a “general appearance”.

From: Stephen R. Gianelli <>
Date: Sat, Sep 26, 2015 at 7:37 AM

There is also CCP 1014.  A defendant appears in an action when the defendant answers,
demurs, files a notice of motion to strike, files a notice of motion
to transfer pursuant to Section 396b, moves for reclassification
pursuant to Section 403.040, gives the plaintiff written notice of
appearance, or when an attorney gives notice of appearance for the
defendant. After appearance, a defendant or the defendant's attorney
is entitled to notice of all subsequent proceedings of which notice
is required to be given. Where a defendant has not appeared, service
of notice or papers need not be made upon the defendant.

From: Stephen Gianelli <>
Date: Sat, Sep 26, 2015 at 4:14 AM
Subject: Slaybaugh v. Superior Court :: :: California Court of Appeal Decisions :: California Case Law :: California Law :: U.S. Law :: Justia
To: Kelley Lynch <>

This appellate decision sets for the test for when a defendant has made a general appearance - read it carefully. 

You may or may not have made a general appearance by filing a motion to dismiss premised in part on alleged "perjury" - because the grounds were not strictly ‎limited to "jurisdiction" of the court over you.

The REAL issue it seems to me is, did you make a general appearance BEFORE the Court entered judgment against you‎ in May of 2006?

If not, the court lacked jurisdiction over you to enter the judgment in the first instance - let alone "renew" it. 

In any event, that is the argument I would make in opposition to Cohen's waiver through a general appearance argument.

Sent from my BlackBerry 10 smartphone.

From: Stephen R. Gianelli <>
Date: Fri, Sep 25, 2015 at 11:00 PM
Subject: Your September 24, 2015 blog post at 12:34 PM

Now you know who the “mastermind” is. For all of it.

I mean, she says she has a “170 IQ”. Which has got to be a genius record for a lawyer.