Friday, September 18, 2015

The Declarations Leonard Cohen Has Falsely Advised LA Superior Court Kelley Lynch Forged And/Or Fabricated & The Limited Powers Of Attorney Now Submitted To The Court As Well




1.        I am a citizen of the United States who currently resides in Los Angeles, California.  I am the son 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.        My mother and I lived at 2648 Mandeville Canyon Road, Los Angeles, California, from approximately November 1997 until December 28, 2005.  My brother, Ray Charles Lindsey, lived with us until May 25, 2005.  We lived in this home during the summer and fall of 2005.  On December 28, 2005, we were evicted by the Los Angeles Sheriff’s Department. 
4.        At no time did my mother and I have a female “co-occupant” who resembled the individual described in the Proof of Service related to Leonard Cohen’s lawsuit. 
5.         No one in our house was ever advised to evade service and this was never discussed. 
6.         The individual the process server alleges to have served, under penalty of perjury, is described as Jane Doe, white female, 5’ 7”, 135 pounds, blonde hair, black eyes - co-occupant.  No such individual resided with my mother and I during this period of time or at any other time during our residency in this home.  I am unaware of any individual who matches the description provided by the process server in this matter.   On August 24, 2005, my mother did not match this description. 
7.         In the late summer and fall of 2005, Chad Knaak stayed with us.  Chad and I have been friends since childhood.
8.        The process server has stated, under penalty of perjury, that he attempted to serve the summons and complaint in the above referenced matter on August 17, 19, 20, 21, 22, and 23, 2005 and notes that no one was home.  My mother, Kelley Lynch, was home at all times during this period.  As I lived with my mother, and was home at some point every day, I can unequivocally state that my mother was home each and every day throughout the summer and fall of 2005.  My mother had been in two car accidents, neither due to any fault on her part, and did not have transportation throughout most of the summer and fall of 2005.  Her car was completely destroyed and I, and others, brought food and other items home as she had no transportation.  Our house was located quite far up Mandeville Canyon Road and my mother would have had to walk miles to a store.  My mother also did not have any money at this time for any form of transportation, her phone, electricity, and other bills.  
9.         In the spring of 2005, and the month of August specifically, my mother wore her hair very dark brown, almost black, and extremely short.  She continued to wear her hair in this manner throughout the summer and early fall of 2005.  Paulette Brandt visited us regularly and would bring food for the animals and hair dye for my mother.  During the summer and fall of 2005, and the month of August specifically, my mother was very thin, had blue eyes, and was approximately 5’6” tall.
10.       On or about August 16, 2005, I became aware of Leonard Cohen’s lawsuit against my mother because my stepfather, Steve Lindsey, called a friend of mine who brought it to her attention.  Chloe Favella called me about the lawsuit and I told my mother who said she was already aware because a journalist had contacted her.  Paulette Brandt also printed out news articles and brought them when she visited.
11.       On August 24, 2005, a little over a week after Leonard Cohen filed his lawsuit, my mother came into my room and asked my friend Chad Knaak if he would phone Leonard Cohen’s lawyer and leave a message from her.  It was my understanding that my mother found his name and contact information online.  She had handwritten the information on a piece of paper and handed it to Chad.  My mother’s phone had been shut off and she was unable to place the call personally.  I was present when my mother asked Chad to call Cohen’s lawyer to advise him that she had not been served Leonard Cohen’s lawsuit and explain to him that IF he attempted to serve her the lawsuit she would hold him personally accountable.  Although I do not know who answered the phone, I distinctly heard Chad tell the individual on the other end of the line that my mother had not been served Cohen’s lawsuit and IF this lawyer attempted to serve her the lawsuit she would hold him personally accountable.  My mother was present for this call as well.  Chad was very professional with the individual he spoke with.  I all recall my mother asking him to be polite during the call. 
12.       It is my understanding that my mother was never served Cohen’s lawsuit.  Since the summer of 2005, my mother has continually advised me that she was not served Leonard Cohen’s lawsuit and had no idea what the actual allegations were until the Complaint was posted online when she visited me at some point in 2010.  I know this situation frustrated her and, from what I recall, Leonard Cohen’s lawyers refused to speak with my mother.  She would borrow my phone to attempt to speak with them and I was present for quite a number of these calls.
13.       At the beginning of October 2005, our internet service was shut down and my mother would have to ask people to borrow or use their computer so she could check her emails and respond to those she received. 
14.       On December 28, 2005, the Los Angeles Sheriff’s Department evicted us from our home.  My mother ended up homeless in Santa Monica for approximately 8 months.  I went to live with family friends in Brentwood, California.
15.       Although this is out of chronological order, at some point in the fall of 2004, based on Leonard Cohen’s statements to City National Bank, my personal bank account had a freeze places on it and was closed.
16.       In or around January 2012, I visited my mother in Berkeley, California.  At that time, I delivered boxes of evidence (and other items) I stored in my Los Angeles, California storage center since we were evicted from our home in December 2005.  Until that time, my mother had no personal access to these documents.
17.       I am aware that on April 15, 2005, my mother reported the allegations that Leonard Cohen committed criminal tax fraud to Internal Revenue Service.
I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct.
This declaration is executed on this 9th day of March 2015 in Los Angeles, California.

                                                            JOHN RUTGER PENICK


I, Clea Surkhang, do state and declare as follows:
1.       I am a citizen of the United States who currently resides in Longmont, Colorado.  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 here.
2.      I have been a close friend of Kelley Lynch’s for over 29 years.  We met at a Buddhist seminary in
the summer of 1985.
2.      During the mid-to-late 1980s, Kelley and I both lived in New York City.  We saw each other
every week for dinners and spent time with one another over the weekends.  Kelley had a young son at the time and they lived together in a beautiful apartment that she kept spotless.
3.      In 1987, I moved from New York City to Colorado.  Kelley and I remained in close touch and

visited one another when we were able to.  My husband, Yongzin Rinpoche, is also a close personal friend of Kelley’s.
4.      I have spent time substantial time with Kelley over the years, watched her children grow up, and
know that she is a very caring mother.  Her first love is her children. 
5.      I am aware that Kelley worked as Leonard Cohen’s personal manager for approximately 17 years.
She never once indicated that they were having an intimate dating or engagement relationship, brief or otherwise.  Over the years, we have frequently had long girl talks and Leonard Cohen was simply not someone she was ever interested in dating or attracted to.  I specifically recall asking her directly:  “Were you dating?”  “Did you ever find Cohen attractive?”   Her answer was always “No.”
6.      I’ve watched Kelley’s sons, Rutger and Ray, throughout their childhoods.  They are both bright,
good hearted fellows.  Kelley is an amazingly strong, kind-hearted being, who has worked her entire life to help her children, parents, friends, and everyone who needed her assistance.  Her care for others is genuine and profound. 
7.      My husband and I visited Kelley in the late spring/early summer of 2005.  At that time, she was
approximately 5’6”, very thin, had large blue eyes, and wore her hair a very dark shade of brown and extremely short.  I recall this because her appearance had changed radically from the last time I saw her.
8.      Since Leonard Cohen filed his 2005 lawsuit against Kelley , she has continually maintained that
she was not served the summons and complaint.
9.      In the spring/early summer of 2007, my husband and I invited Kelley to stay with us at my
mother’s home in Erie, Colorado. 
10.  I am quite confident in Kelley’s integrity and the fact that she is as professional and
 straightforward in her business dealings as she has been in her friendship.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct.  On the 4th day of December 2015, I verbally authorized Kelley Lynch to execute this declaration on my behalf in Los Angeles, California.

                                                                        Clea Surkhang

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, 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
or avoid 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 was covered in 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:
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 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.
3.               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. 
4.               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.
5.               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.
6.               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.
7.               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.
8.               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.
9.               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.
10.           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.
11.           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. 
12.           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. 
13.           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. 
14.           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.” 
15.           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.
16.           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. 
17.           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, the believe they can take advantage of her because she is self-represented.  The tactics that have been used against her are appalling.
18.           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


From: Paulette Brandt <>
Date: Wed, May 29, 2013 at 10:55 AM
Subject: Fwd: Kelley Lynch has posted your contact information on her blog
To: Kelley Lynch <>

Dear Kelley,
This is what Gianelli sent me.  I just ignored it.  He knows not what he says.  Stay well.

---------- Forwarded message ----------
Date: Sun, Mar 10, 2013 at 3:38 PM
Subject: Kelley Lynch has posted your contact information on her blog

Dear Ms. Brandt:
Kelley Lynch has posted your name and email address on her blog, and is pretending that the two of you are of a like mind respecting her “theory” that entertainer Leonard Cohen is on a “crusade” to destroy Phil Spector, and also “stole” from Marty Marchant [sic]. (She claims Mick Brown of Rolling Stone [UK Telegraph] told her that Leonard Cohen testified before the Phi Spector grand jury and from this she infers that Cohen’s “perjury” is responsible for Spector’s murder conviction, even though Cohen neither testified before the grand jury nor at either one of Phil Spector’s murder trials.)
Be forewarned, Kelley Lynch is very disturbed and mistakes silence in the face of emails as a “relationship” and silence in the face of several hundred or more emails as a “dear friendship”.
And should she turn on you, you can expect 10,000 emails accusing you of every crime known to mankind, CC to the IRS, the FBI, Governors, prosecutors and the media.
See here:
Kelley Lynch also forwarded her email to you to various email recipients, including the FBI, IRS, and Franchise Tax Board and members of the media,  implying that the two you are in “conversation”; here is her distribution  list:
From: Kelley Lynch <>
Date: Sun, Mar 10, 2013 at 2:18 PM
Subject: Fwd: Have you seen this?
To: Dennis <>, "*irs. commissioner" <*>, ASKDOJ <>, Washington Field <>, "Kelly.Sopko" <>, "Doug.Davis" <>, rbyucaipa <>, Robert MacMillan <>, moseszzz <>, a <>, "Hoffman, Rand" <>, wennermedia <>, "harriet.ryan" <>, "hailey.branson" <>, Mick Brown <>, woodwardb <>, "glenn.greenwald" <>, lrohter <>

Hello Mr. Riordan,

Paulette sent me a lovely link featuring Blaine on Aphrodite Jones. The system works beautifully for the criminal. Paulette worked for Phil for years and NO ONE contacted her - not the prosecutors, not the news media, etc. No one cares about the truth. They like the garbage de riguer gun stories. They sell.

See link, above.
Excerpts from email to Kelley Lynch: 

Saturday, February 23, 2013

Phil Spector's Former Assistant

Dear Kelley,

I'm so glad to hear from you. 

I've learned that there are tons of really bad people out there with no consciences.  I have a hard time relating.  The "incident" at Phil's house gave the cops just what they needed to crush him - forget what the truth was.  I saw Phillip after the incident and he told me what happened - and I believe him.  He told me that before leaving, Lana took one of the guns from the foyer and told him "this is what I
can do to your cock" - and simulated going down on it - and it went off.  No suicide - no murder - an accident.  I have also been told that there was a "madam" who wanted to testify that Lana had done this before (obviously without the slip), but was not allowed to testify because she was going to say that she had hired Lana on occasion, and this would have made Lana look bad - and God forbid we taint the name of a deceased woman who made a stupid fatal mistake when they could destroy Phillip who the police hated for some time - you know, the little guy who made good - better than them.  Remember, smart cops don't exist.  If they have a high i.q. they are not hired.  They look for followers, not leaders.  I went to the trials twice.  I don't know what they did to him.  He was shaking and much slower than the Phillip you and I have known most of our lives.  I don't know what they had him on.  He was so happy to see me and came over to me and threw his arms  around me.  I felt so helpless.  I don't know about his wife, Rochelle.  I sincerely hope she loves him.  I DO know about Michelle Blaine - she's a thief and a liar - a lowlife who had a plan from the get-go.  She has a blog where she trashes him so badly.  One would think if she despised him that much, how come she was working as his Assistant, and had me ousted to do so.  I don't know how she got me fired, although I do believe Janis had a part in that too.  I don't know why.  My "romantic" days with him were long gone and I had no sights for him in that way.  But I will always love him, but I am not In love with him and had not been for many many years.  If I had still been working for Phillip, the incident would never have happened.  Michelle Blaine took away Phillip's protection and the buffers he needed.

No, you would never hear me talking badly about Phillip,  He actually was the significant older male figure in my life.  I spent way more time with him than I did with my Dad - and he loved me.  You may have seen me on Court TV where I came to his defense.  The whole thing destroyed many many people - and there Phillip sits - in a room smaller that the smallest bathroom in his house.  How cruel.
And they have put him so far away that you can't even get to him to visit him.  I wrote to him once, but the letter came back.

With love, 


Example of emails received and forwarded to Kelley Lynch.

On Thu, Mar 12, 2015 at 2:41 PM, Paulette Brandt <> wrote:

---------- Forwarded message ----------
Date: Tue, Mar 10, 2015 at 5:04 AM
Subject: As expected, no "motion" filed, nor will it ever be

Case Summary

Case Summary
Please make a note of the Case Number.
Click here to access document images for this case. 
If this link fails, you may go to the Case Document Images site and search using the case number displayed on this page.

Case Number:  BC338322

Filing Date:  08/15/2005
Case Type:  Fraud (no contract) (General Jurisdiction)
Status:  Default Judgment Pursuant to Decl. 05/09/2006
Future Hearings 


From: Paulette Brandt <>
Date: Thu, Mar 12, 2015 at 2:42 PM
Subject: Fwd: You now have 7.5 hours to file your purported "motion" as threatened (or not - like so many times before)
To: Kelley Lynch <>

---------- Forwarded message ----------
Date: Mon, Mar 9, 2015 at 8:59 AM
Subject: You now have 7.5 hours to file your purported "motion" as threatened (or not - like so many times before)

It is now 9:00 am Los Angeles time on March 9, 2015 on the day you most recently claimed (twice) that you would be filing your “motion” to refer Leonard Cohen and others for a perjury prosecution in case number BC338322, the matter wherein default judgment in the amount of $7.9M was entered against you and you were permanently enjoined from asserting any ownership interest in any Cohen related entities or in any entities created for Cohen’s benefit.

The courthouse closes at 4:30 pm.

You have seven and a half hours to file your “motion”.

I’ll reserve judgment until 4:30 pm.

From: Paulette Brandt <>
Date: Thu, Mar 12, 2015 at 2:43 PM
Subject: Fwd: Your YouTube comments of today
To: Kelley Lynch <>

---------- Forwarded message ----------
Date: Mon, Mar 9, 2015 at 1:21 AM
Subject: Your YouTube comments of today

Ms. Lynch,

You just posted that Lana Clarkson’s fingerprints were found on the bullets found in the gun that killed her.

This was never brought out during the first or second murder trial, it was never mentioned in any news article, and Mr. Spector’s  defense attorney never mentioned it to me in any of our numerous communications during the retrial. Nor is this “fact” mentioned in ANY of Phil Spector’s many post-conviction appellate briefs.

Such evidence, if it existed, would have guaranteed a NOT GUILTY verdict and would guarantee that Mr. Spector would be out on bail pending appeal and not dying in a prison medical facility.

Therefore, one can say with absolute certainty that you are LYING again as usual.



I, Ray Charles Lindsey, declare as follows:

1.    I am over the age of eighteen.  The following facts are within my personal knowledge and, if called and sworn as a witness, I could and would testify competently thereto.

2.    I am a resident of California.

3.    Since approximately 2009, I have been receiving emails from Stephen Gianelli, Susanne Walsh (Leonard Cohen’s fan), and others.  Leonard Cohen’s lawyer, Michelle Rice, was copied in on some of these emails..  Apart from Leonard Cohen, I do not know these people and have never met them.  These individuals were also posting on the internet about my mother.  Most of the emails related to matters involving Leonard Cohen, IRS, and Phil Spector.  

4.    My mother was Leonard Cohen’s personal manager for approximately 17 years.  They had a falling out in the fall of 2004 to my knowledge. My mother is also a friend of Phil Spector. 

5.    On or around May 6, 2013, Ray Lawrence began privately emailing me.  I don’t not know him and have never met him.  He made serious accusations about my mother and was angry with my Aunt Karen.  Karen is my mother’s sister. 

6.    While Ray Lawrence was in Minnesota, my mother lived with his roommate, Michael Ingrassia.  My mother moved out of their house on June 4, 2013 and shortly thereafter I began receiving an onslaught of emails from him, Stephen Gianelli, and Susanne Walsh.  My mother was the target of those emails.  Ray Lawrence accused my mother of many things, including stealing Michael Ingrassia’s computer.  My mother then sent out an email from Michael Ingrassia confirming that he had given her the computer. 
The accusations were confusing and disturbing.  Whenever one of these individuals accused my mother of something in their mass emails, she would refute them, asked Gianelli, Walsh, Lawrence, and others, to stop emailing her, asked them to stop contacting her sons, family members, and friends, and/or advised them to cease and desist.

7.    On or around June 18, 2013, I wrote Stephen Gianelli, Susanne Walsh, and Ray Lawrence advising them to stop contacting me and my immediate family because their emails were making me ill.  See Exhibit A.

8.    On June 21, 2013, my brother, Rutger Penick, responded to these emails and addressed the fact that he felt Stephen Gianelli was picking on my mother because she is poor.  He sent a copy of that email to Ray Lawrence and Susanne Walsh.  My mother and I were copied in as well.  See Exhibit B.

9.    At some point, Ray Lawrence’s emails made demands on my mother about property and evidence she left at his house with his permission.. He began threatening to destroy them, sell them, or provide her documents to Leonard Çohen’s lawyer, Michelle Rice.  Gianelli and Walsh also sent emails advising Lawrence to send my mother’s evidence and paperwork to Michelle Rice.  This was upsetting to my mother and she emailed the recipients of the emails the agreement she and Lawrence had entered into permitting her to store her belongings at his house.

9.    The emails from Ray Lawrence were extremely slanderous and accusatory with respect to my mother and were upsetting and confusing.  For the time being, they seem to have stopped.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed on July 17, 2013 at Los Angeles, California.

Ray Charles Lindsey 


From: Ray Lindsey
Date: Tue, Jun 18, 2013 at 9:50 PM
Subject: I'm getting physically ill
To: Susanne Walsh <>
Cc: Ray Lawrence <>, "STEPHEN R. GIANELLI" <>

Please discontinue contacting anyone in my immediate family. This is causing me to become ill as a result of the consistent bullshit. I just want everything to stop. I know I've added my share to the pool, but this is getting too much for me. I'm getting in over my head and it's hurting my heart to have to see my mother go through as a result of her own actions and the actions of others.

Can't we all just practice compassion for one moment, please.


From: Rutger Penick
Date: Fri, Jun 21, 2013 at 5:48 AM
Subject: Re: I'm getting physically ill
Cc: Kelley Lynch <>, Ray Lawrence <>, Susanne Walsh <>

Stephen shut up already. Live the rest of your worthless life without picking on the poor. I am sure that makes you feel superior.


Rutger Penick | MCTS:Windows 7


Truth Sentinel Episode 40 (Phil Spector, truth, lies, guilt and innocence, murder trial)


Published on Feb 3, 2015

Truth Sentinel Episode 40 - part 2 of Truth, lies, guilt & innocence looks at the case of Phil Spector and asks if a retrial is needed. We speak to his former assistant Paulette Brandt, to Kelley Lynch and our resident researcher Seth Davis from 2 Real News.

Truth Sentinel Episode 39 (Leonard Cohen, truth, lies, guilt, innocence, law, MK Ultra)

Published on Feb 2, 2015
Truth Sentinel Episode 39. Truth, lies, Guilt & innocence. We talk to Kelley Lynch about her legal battles with Leonard Cohen. Writer Anne Diamond joins us to talk about her experiences of dating & living next door to Cohen along with his links to MK Ultra. Anthony K talks about MK Ultra and the experiments that broke every ethical code of practice.


I, Palden Ronge, do state and declare as follows:
1.       I am a citizen of the Canada and permanent resident of the United States.  I currently
reside in Los Angeles California. I am a close personal friend of Kelley Lynch’s.  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.      My wife, Lila Rich, and I have known Kelley for many years.  I personally met her approximately
1988.  We are close family friends and I know her parents and sons, Rutger and Ray.  Over the years, we have visited each other socially on many occasions and participated in many religious events together. 
3.      Kelley was an excellent and loving mother.  She took her role as a parent seriously and saw to it
that her sons received the best education.  She ensured that their personal needs were met in every way.  Ms. Lynch was particularly diligent in supervising her children to insulate them from the urban youth culture of drug and alcohol abuse.  Kelley’s sons are wonderful young men.
4.      I have known Kelley to be a well-connected, professional woman, who multi-tasked at a dizzying
pace as she managed the business affairs for Leonard Cohen and handled her other business matters.  Kelley worked as Cohen’s personal manager for approximately 17 years.  It never once crossed my mind that Kelley and Mr. Cohen were ever involved in any type of intimate dating or engagement relationship.  Nor had I heard anything to indicate that their relationship was anything but professional. 
5.      I have worked with Kelley when she and Oliver Stone sponsored a Tibetan  Buddhist meditation
center for His Holiness Kusum Lingpa.  His Holiness Kusum Lingpa was a highly regarded Tibetan Buddhist master.  I had the good fortune to serve as an interpreter for this remarkable man and was involved in translating certain religious texts.  His Holiness appointed Kelley to be his chos kyi dags mos (lineage holder) and she worked quite diligently on his behalf.  It is my personal belief that Kelley conducts herself professionally, ethically, and honestly in all areas of her life.
6.      I visited Kelley throughout the spring and summer of 2005.  His Eminence Choegon Rinpoche, a
mutual friend, often accompanied me on these visits.  I distinctly recall Kelley’s appearance in the summer of 2005, and specifically throughout the month of August 2005, due to the fact that she changed the color radically.  At that time, she had bright blue eyes, very dark short hair, was approximately 5’6,” quite thin, and weighed approximately 110 pounds.  For years, she had worn her hair very light blonde and it took me some time to grow accustomed to Kelley’s very dark hair and new look.
7.      In mid-June, Kelley was rear-ended by a driver on Mandeville Canyon Road.  She was seriously
injured and hospitalized for head trauma and other medical issues.  I believe she also broke her nose and seriously injured her neck and back.  I visited Kelley in the hospital at that time and, apart from her physical injuries, she was her usual intelligent, caring, and humorous self.  I recall bringing her sushi.
8.      Shortly after this accident, another driver on Mandeville Canyon Road, presumably on his cell
phone and not paying attention, pulled out suddenly and quickly from a side street and slammed into Kelley’s passenger side.  Kelley was again injured and this accident destroyed her car.  She was planning to visit Lila and myself in Ojai, California and was unable to do so due to the damage the car sustained.
9.      I am aware of the fact that Kelley was home throughout the summer and fall of 2005.  I
frequently visited, understood she had no transportation or money, and when I rang the bell, she would simply open the door.  It didn’t appear that she was attempting to evade anyone.  She informed me repeatedly that she wanted to be served Cohen’s lawsuit and review the specific allegations in the Complaint.
10.   I distinctly recall during the summer and fall of 2005 Kelley’s frustrated attempts to address the
fact that she was not served Leonard Cohen’s lawsuit.  Kelley has continuously and consistently maintained that she was not served this lawsuit.  She was also extremely frustrated with the conduct of and tactics used by Leonard Cohen’s representatives.
I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct.
This declaration is executed on this 9th day of March 2015 in Los Angeles, California.

                                                                        Palden Ronge


I, Daniel J. Meade, do state and declare as follows:
1.      I am a citizen of Halifax, Nova Scotia, Canada. I was born and raised in the United States. 
I am a close personal friend of Kelley Lynch’s.  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.
teacher, appointed me to the position of Executive Director to the Philadelphia branch of Vajradhatu International Buddhist Organization.  At that time, I was also quite close with her first husband, Richard Dallett.  In fact, when Kelley was married to Mr. Dallett, I worked with him on numerous projects.  My wife and I spent a great deal of time socializing with Kelley and Richard Dallett.
3.      Kelley's volunteer work with Philadelphia Dharmadhatu included serving as my personal
secretary and administrative assistant for approximately 2-1/2 years.  I was always pleased with her professional demeanor and diligent work.
4.      Kelley Lynch and I have remained extremely close friends to this day.  I view her as one of my
dearest friends.  We have stayed in close and constant contact consistently for over 35 years.
5.        I also know Kelley's parents, grandparents, brother, sister, sons and second husband, Douglas
Penick, who is also a friend of mine.  Kelley has a very close relationship with her family.
6.      In all the years I have known her, I have appreciated her kindness and generosity towards me and
others, as well as various organizations and Buddhist causes.  His Holiness Kusum Lingpa appointed Kelley Lynch to be his lineage holder.  Kelley and Oliver Stone sponsored a Tibetan Buddhist center for Kusum Lingpa Rinpoche and he evidently also appreciated certain qualities that she embodies. 
7.      Kelley is a quick wit and possesses a great sense of humor.  I would like to share a story about
her with the Court:  Approximately 13 years ago, my long term lady friend, also a friend of Kelley's, was diagnosed with terminal cancer.  For the next 4 months, Kelley called me every day to check in about my state of mind as I was the primary care giver.  Her support during this period of time was invaluable and greatly appreciated.  After my friend's death, Kelley generously flew me out to Los Angeles to visit and recuperate.  My son also joined us.  She took a bit of time off work to tend to my needs.  I was able to spend time with and became intimately acquainted with her sons, Rutger and Ray.  I found the home environment to be very loving, uplifted and dignified in a particular sort of Buddhist style.  Kelley was a great host and obviously a good and decent mother.  It was a very pleasant 5-6 weeks for me.  But, during my stay I witnessed a few rather unpleasant incidents:  I was well aware that Kelley worked as Leonard Cohen's personal manager.  I had been a fan of his music and poetry since the age of 13.   One day the phone rang while Kelley was in the shower, I picked up and Leonard Cohen asked “Is Kelley there?”  I responded by asking “Who are you?”  He replied “I am Leonard.”  I then simply said “Leonard who?” and his response was to become angry.  He then hung up on me.   I actually meant this as a joke.  Of course, I knew it was Leonard Cohen.  His voice is very recognizable.  Later that morning, Mr. Cohen emailed Kelley a very personal and vicious letter.  She read it to me and I could not believe what an abusive, humorless, and aggressive asshole he was to her.  My little dream of the man who wrote these profound song lyrics immediately went down the local toilet in Los Angeles at that time.  I asked Kelley to give me a copy of this letter so I could share it with the world at large and inform them about this man's true nature.  I was in disbelief at his level of hostility particularly given the fact that he holds himself out to the world as some sort of religious sage.  He was clearly jealous of my presence.  Kelley discreetly declined to provide me with a copy of this exceedingly disturbing email.  I do not believe she refused to give me the letter simply to protect her position as Mr. Cohen’s personal manager.  I believe she declined out of a sense of respect for Leonard Cohen and may have been trying to keep his weaknesses and unconscionable conduct towards her private.
8.      The second unpleasant incident I would like to share is as follows:  One day, while visiting Kelley
and her family, I was relaxing by the pool.  Kelley's great home care assistant, Elena, had brought
me food.  Elena was a delightful individual who took great care of Kelley's sons and home while she was at work.  Kelley was extremely busy working as Cohen’s personal manager and also owned a greeting card company.  She devoted a tremendous amount of time to her sons, work, and charitable work.  Kelley is a tireless individual.  Elena would help with the boys when they returned from school or other activities, assist with meal preparations, and appeared to love Kelley and the boys.  Elena’s presence in the home was important.  Kelley home-schooled her older son and carpooled her younger soon.  She had an office in her home and worked there in the afternoons and on weekends.  There were always numerous children and teenagers in her home.  Kelley provided a stable environment for these young people but was very careful with boundaries and discipline.  Kelley was essentially a single mother, raising her children with the assistance of her parents, and wanted an adult present in the household at all times.  Suddenly, out of the blue, Steven Lindsey showed up unannounced - meaning he did not call or email asking if it was an appropriate time to drop by.  Steve Lindsey is the father of Kelley’s younger son, Ray.  I suppose he felt entitled to behave in this manner because he was Ray's genetic father and felt he could do as he liked, in an arrogant fashion, as rich people tend to do. Kelley was not pleased with the invasion and from what I witnessed neither were her sons or Elena.  I was sitting by the pool, clueless as to Lindsey's arrival, when he sat down next to me.  He tried to be nice about the death of my girlfriend.  The aggression Steve Lindsey brought into that home was, from my perspective, overwhelming and loud.  After helping to calm things down inside, Kelley came out and made a few dark jokes about death, in a Monty Python sort of way.  She was trying to help me through my grief in her playful fashion.  Steve Lindsey became offended by Kelley and my interactions.  He stormed off angry and, from what I could hear from outside, Ray was in the house quite upset.  I asked Kelley – “Does he always invade your home unannounced?”  She replied, “Yes, whenever he wants to.”  I thought “How sad for Ray and Rutger and you.”  Kelley and her sons were very, very close.
9.      It is my personal belief that both Leonard Cohen and Steve Lindsey were obsessed with Kelley,
extremely possessive of her, privately conducted themselves in a jealous and hostile manner towards her, becoming angry, paranoid, and vicious when she was unable to immediately tend to their specific needs.
10.  In the 35 years I have known Kelley, I never once heard that she and Cohen were in a brief,
intimate statutory required dating or engagement relationship.  I have, on the other hand, heard first hand that she felt Cohen’s conduct towards her was harassing, uncomfortable, and thoroughly unprofessional.  At times, throughout the years, Kelley and I have been involved in an intimate dating relationship and I feel absolutely confident that had she been involved in a similar relationship with Cohen she would have shared that information with me.  Kelley and I have a very direct and honest friendship. 
11.  Since  2005, when Leonard Cohen filed his lawsuit against Kelley, she has consistently maintained
that she was not served the lawsuit.  This has been extremely frustrating for her.  Kelley and I have discussed the tactics Leonard Cohen has used against her, the unprofessional conduct of his representatives, slanderous comments to the news media, and fraudulent restraining orders to discredit her.  Kelley has no interest in Leonard Cohen whatsoever.  She has an interest in resolving the legal issues, obtaining tax and corporate information she requires, and maintaining the private and simple life she always have.
12.  In the 35 or so years I have known Kelley (who is from Pennsylvania), it was never my
understanding that she was a friend of Neal Greenberg’s.  Greenberg lived in Boulder, Colorado and perhaps they ran into one another briefly at a Buddhist or social event. 
13.  I have spent a great deal of time in religious retreats.  In fact, when I was quite young I was in a 6
month retreat.  I have never heard of a rigorous Buddhist “retreat” where an individual has a work room, computer, fax, phone, keyboard, participates in documentaries and interviews, records albums, and comes and goes as one pleases.
14.  These are my thoughts about what a good person Kelley Lynch is.  I have no fiduciary concerns
here.  She is simply an old friend of mine and I am concerned about her welfare and the welfare of her sons.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct and that I executed this Declaration on the 4th day of March 2015 at Halifax, Nova Scotia, Canada.

                                                                        Daniel J. Meade