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Monday, October 29, 2012

Evidence That Will Be Attached To My Motion To Vacate/Declaration - Which Has Been Sent To The IRS, FBI, DOJ, Treasury, FTB, Dennis Riordan, & My Lawyers 

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Declaraton of Paulette Brandt - Probation Retaliation

DECLARATION OF PAULETTE BRANDT

I, Paulette Brandt, do state and declare as follows:

1. Ì am a citizen of the United States who resides in Los Angeles, California.  Except as to those matters state on information and belief, I have personal knowledge of the facts set forth and could and would testify competently if asked to do so.
2. I have worked in the entertainment industry for my entire adult life.  I have worked for Phi l Spector, Abkko Records, Apple Records, Columbia Pictures, and others. 
3. I initially met Kelley approximately 25 years ago.  We met when she relocated to Los Angeles from New York City.  We have stayed in close touch for the last 15-20 years. 
4. Kelley is a close personal friend of Phil Spector’s.  I have worked with Kelley in an official capacity.  For approximately 17 years, she worked as Leonard Cohen’s personal manager, handled his publishing and book publishing administration, and worked in other capacities.  She was not Cohen’s business manager.  Kelley also worked as Adam Cohen’s personal manager.  She was very skillful in this position, and others, and has been credited with re-invigorating Cohen’s career.  A business manager is a CPA who handles accounting and things of that nature.  A personal manager is an entirely different position. 
5. Kelley has also been a steadfast and stable friend and acquaintance.  Kelley has been my houseguest for nearly six months.  I am aware that she is being maliciously slandered and maligned.  Kelley has no alcohol, drug, or substance abuse issues.  She does not have mental health issues.  She is entirely down to earth, focused, looking for work, and relating to quite a lot of business and legal matters.  I can assure the court that Kelley has no anger problems and absolutely no propensity for violence.  I cannot imagine where these allegations originated as they are wholly and entire untrue. 
6. Kelley is very close with her family including her sons.  She has many close friends who have been extremely supportive throughout this ordeal and remain close to her. 
7. Over the years, I have worked with a number of celebrities including Phil Spector, Connie Stevens, and Dudley Moore.  I have arranged for their security and am very familiar with what to look for in terms of risks.  The notion that Kelley is a danger to society, Leonard Cohen, her former prosecutor, or anyone else, is positively laughable. 
8. Kelley has many high profile friends and acquaintances and has no interest whatsoever in Leonard Cohen.  She is attempting to address very serious business and legal matters.  I don’t believe she ever really even thinks about him.  It is his actions and conduct towards her, and her family, that disturb her. 
9. It is my understanding that Leonard Cohen testified that he and Kelley were in an intimate sexual dating relationship.  Kelley and I have always shared intimate details of our lives with one another.  Never once have I heard that she and Cohen were in any type of sexual or intimate dating relationship but perhaps that was his desire.  I have, on the other hand, heard stories about his conduct with respect to her.  That would include insisting that she read business and legal documents to him while he soaked in the bubble bath; looking at people defecating on one another in front of her; and engaging in entirely unprofessional and unacceptable conduct. 
10. I am aware and understand that Kelley is on summary misdemeanor probation and has been accused of violating the terms of her probation.  Kelley engages in no unlawful conduct whatsoever.  She rarely goes out.  We are together 24/7.  She has been relentlessly targeted by, among others, Stephen Gianelli and Susanne Walsh who I understand is Leonard Cohen’s fan and frequently copies his lawyer in on her emails.  I too have been a recipient of emails from these individuals and others, including Kelley’s former landlord, Ray Lawrence.  After Ray Lawrence divulged my personal details to Stephen Gianelli, these three individuals began a campaign of harassment respect to me.  They falsely accused Kelley of many things and I was extremely disturbed by their slanderous accusations.  I too have been slandered by these individuals.  To this day, Stephen Gianelli continues to harass me.  In fact, I am now receiving emails, U.S. mail, and phone calls that I believe relates to this coordinated campaign of harassment.  I recently received a number of extremely disturbing and frightening phone calls.  One individual identified themselves as Stephen Gianelli and and threatened to kill me if I did not remain silent about matters involving Kelley, Phil Spector, and Leonard Cohen. I have no idea who this man is; his conduct suggests that he is not stable and possibly engaged in criminal activity; and, for all I know, he could be outside of my home.  He is most definitely stalking Kelley and me.
11. Stephen Gianelli initiated communications with Kelley’s prosecutor, and others, at the City Attorney’s office.  She has no idea how he obtained the email addresses of a number of Deputy City Attorneys.  Kelley attempted to refute malicious and slanderous lies being directed to her prosecutor about her.  Her sons, family members, and were copied in.  I was copied in on many of these communications as well and can state unequivocally that Kelley’s intention was NOT to harass the prosecutor but to defend herself and refute these falsehoods with the truth and facts. 
12. I have witnessed Kelley attempt to file complaints with the City Attorney’s office.  She repeatedly contacted them in an attempt to have the probation violation documents served.  At one point, she was told by that office that the judge was wrong – the Court was the party that would serve the documents.  Kelley did not receive the Notice of Probation Violation; Witness List; and Proposed Evidence for almost a full month following her September 25, 2013 hearing.  I was present for that hearing and heard Kelley ask the judge for an extension so that she had the appropriate time needed to research the issues and prepare her defense.  She has not had the appropriate time and is at a great disadvantage due to the fact that she is not represented, has no money, and no transportation.
13. Kelley has also been in touch with the State of Kentucky, Franchise Tax Board, and Internal Revenue Service over the past month or so.  All three tax authorities have advised her to contact Leonard Cohen with respect to the K-1 partnership tax documents he has issued her.  She is not in possession of IRS form 1099 for the year 2004.  This has created a tremendous amount of stress for Kelley as she is potentially facing a wage garnishment although she owes no taxes.
14. I have worked in Accounting for Columbia Pictures.  I have reviewed Leonard Cohen’s alleged forensic report.  It is a meaningless list of numbers with a handful of random back-up documents.  A proper accounting should show the entire picture.  That would include assets, liabilities, corporate ownership interests, outstanding loans/advances, and so forth and so on.  Kelley is not in possession of a proper accounting.
15. Kelley has also been attempting to obtain her file from the Public Defender’s Office.  I have personally, on her behalf, contacted them.  She recently received 17 CDs of evidence from her trial but is awaiting the remainder of her file.  This has frustrated her and affected the appeal and writ of habeas corpus she has filed to date.
16. I have reviewed a great deal of the trial transcript and evidence from Kelley’s 2012 trial.  It is overwhelmingly obvious that she was not represented at all.  The jurors were misled by highly inflammatory rhetoric, false accusations, and misinformation.  This was presented to them by both the prosecutor and her trial lawyers.
17. Kelley was pro per throughout the litigation matters with Leonard Cohen.  She recently filed a motion to vacate his 2005 lawsuit due to lack of service.  She is representing herself in the instant matter and a number of other matters. I am aware that Kelley was not served Cohen’s lawsuit; had no female co-occupant in or around August 2005; and was not notified of or served the default judgment that was subsequently entered against her.  I would definitely have invited Kelley to stay with me, rather than allow her to end up homeless, but due to her circumstances (including having her phones and electricity shut down) we fell out of touch for a spell.
18. Kelley is a law abiding citizen.  I invited her to stay with me in May 2013 and she has been my guest since that time.  Kelley rarely goes out; we are together nearly 24 hours a day; she is close with her family, friends, and Tibetan Buddhist religious advisers; and, I have never seen her attempt to harass, stalk, threaten, or attempt to annoy anyone.  On the contrary, I believe certain parties have attempted to intimidate Kelley and have indeed harassed, stalked, threatened, and annoyed her.  It has been entirely frustrating for Kelley.  Her family, including her sons, have been through a tremendous ordeal and she is gravely concerned for their welfare.  Kelley’s parents are elderly.  She worries about the impact of these matters, including the attempt to hold her in violation of her probation, on her parents, sons, other relatives, and friends.  It has been very disturbing to witness.
19. In the news media, trial transcripts, emails I receive from strangers, and elsewhere, Kelley and her reputation have been rendered unrecognizable.  She has been accused of being, among other things, a prostitute, heroin addict, drunk, drug addict, ex-lover of Leonard Cohen’s, abusive mother, thief, and a liar.  It is my belief that this is nothing other than an all out attempt to discredit Kelley, destroy her reputation, and create an image of her that is completely fraudulent and disgraceful.  It appears to relate to litigation matters, Phil Spector, the IRS, and, the 2012 trial. 
20. It is my understanding that Kelley has been ordered to pay certain fines and restitution as part of her probation.  These financial requirements relate, in great part, to issues related to domestic violence and legal representation.  The slander, false accusations in the news media, online campaign of harassment and attempts to discredit her; the trial and domestic violence order have all made it almost impossible for her to find work.
21. I can unequivocally state that Kelley does not want to contact the City Attorney of Los Angeles regarding these matters.  It is frustrating for her.  I encouraged her to follow up with respect to service of the Notice of Probation Violation which has evidently led to further complications for her.  Kelley’s communications with the City Attorney’s Office have been entirely legitimate.
22. Recently, I was present when Kelley phoned the Boulder County Courthouse and spoke to the Clerk’s office.  She was advised that the “permanent” Boulder, Colorado civil harassment order expired.  Prior to her arrest, Kelley advised me that it expired in or around 2010.  At that time, she had also spoken with the Boulder Court.  I have been dealing with many legal matters, before LA Superior Court, and am frequently given wrong or misinformation.  I was present in Department 47 when Kelley was personally advised that she was not permitted to review her file although she is self-represented.
23. I am very familiar with domestic violence orders and how abused these orders are.  I have been assisting Keith Roizman who is also the victim of a fraudulent domestic violence order.  These orders are highly abused tactics that are used in divorces, family affairs, and they are successful in business disputes. 
24. Kelley sent me a copy of the drone Valentine card that is evidently an element of her probation violation matter.  I found the card humorous and charming.  I cannot imagine any reasonably intelligent person viewing it in any other context.  Kelley is also extremely interested in current political affairs and current affairs and keeps herself abreast of these matters.  This card cannot possibly be taken as a threat by Kelley’s prosecutor.  Kelley did not create or post the card online and she obviously doesn’t have access to a military drone.  There is no threat, let alone a credible threat.  I have been involved in an investigation related to a viable and credible death threat.  A letter was sent, through the U.S. mail, advising District Attorney Steve Cooley and City Attorney Carmen Trutanich that they would be killed if they did not drop charges against Keith Roizman by a certain date.  I was told by LAPD’s TMU that, due to the fact that the date had passed, it was no longer viewed as a credible threat.  Kelley’s email, to the FBI and DOJ, with the drone Valentine card was sent on February 14, 2013 and that date has long passed.  It is astounding to me that the individual who sent the viable and credible threat, pretending to be Keith Roizman, was not charged or prosecuted but Kelley has been.  I am a woman, recipient of the drone Valentine card, and see no threat whatsoever and cannot possibly imagine who would view it in that light without having ulterior motives.
25. It is my opinion, based on everything I’ve seen and heard, that Leonard Cohen has motive for targeting Kelley.  He appears to have  issues related to tax fraud; does not appear to want to pay his representatives properly; and corporate books and records seem to prove that Kelley is the owner of shares of at least two corporate entities and intellectual property.  Cohen also evidently withheld commissions he owes her.
26.  I have reviewed, and been copied in on, emails Kelley has sent to the City Attorney.  These are in response to Stephen Gianelli’s emails to various parties with the City Attorney copied in.  Clearly Kelley has a right to refute slanderous allegations.  She does not know who Stephen Gianelli is …. Gianelli began emailing Kelley’s prosecutor, Sandra Jo Streeter, and another woman by the name of Vivienne Swaningan at the City Attorney’s office.  His emails, copied to many people (including Kelley’s sons, sister, me, and others), are slanderous, defamatory, and appear to be attempts to discredit Kelley, destroy her reputation, intimidate people in her life, terrorize her and her family, and put her in a position where she could be accused of a probation violation. 
27. I have witnessed Kelley’s calls to LAPD TMU.  I confirmed for the Threat Management Unit, who I have dealt with on the Keith Roizman matter, that Stephen Gianelli has been harassing me.  I have also confirmed eceived harassing emails from Leonard Cohen’s fan, Susanne Walsh.  I do not know these individuals.  I have confirmed for LAPD’s TMU that I received at least one death threat.  Kelley has been gravely concerned about the impact of this activity on her elderly parents, sons, family members, and others.  I have also spoken with Kelley’s appellate attorney, Francisco, about this ongoing campaign of harassment.  He too receives countless harassing emails from Stephen Gianelli and possibly others.
28. Kelley currently has a number of physical problems that involve high blood pressure, asthma, heart palpitations, and anxiety. 
29. Kelley and I have a wonderful relationship.  She is a blessing.  We are not, as Gianelli has accused us, drunken, drug addicted lesbians or whores.  He seems dead set on intimidating people in Kelley’s life and isolating her.  His activity relates to Phil Spector, Leonard Cohen, the IRS, and the discrediting and undermining of Kelley Lynch.  It is impossible to believe that this activity is a hobby or casual interest.  He seems like an absolute professional. 

I declare that the foregoing is true and correct under penalty of perjury under the laws of the State of California, and if called to testify, I would and could testify truthful as to the above.  Executed on this 12^th day of November, 2013.

                                                                                              ________________________________

                                                                                                PAULETTE BRANDT

Dirty Doings Alleged in City Attorney's Office

Dirty Doings Alleged in City Attorney's Office Monday, July 22, 2013 By MATT REYNOLDS ShareThis        LOS ANGELES (CN) - Los Angeles city attorney defamed a Fire Department watchdog, accusing him of targeting minority women attorneys, after he criticized the City Attorney's Office for withholding records, the watchdog claims in court.      Independent Assessor Stephen Miller had been locked in a three-year battle with the former city attorney, Carmen Trutanich, over access to information on employee misconduct in the Fire Department.      Miller last week filed a dense 95-page federal civil rights complaint against Los Angeles, Trutanich, his chief deputy William Carter, and assistant city attorneys Pedro Echeverria, Zna Houston, Janet Jackson and Vivienne Swanigan, alleging free speech violations, harassment, retaliation and defamation.      Miller seeks a jury trial to "vindicate and protect" his constitutional rights, and a court order enjoining the defendants from denying his requests for Fire Department records.      Miller was appointed to his post after a 2006 audit exposed a culture of harassment and hazing in the Fire Department, according to the complaint.      In 2009, voters approved an amendment to the City Charter to appoint an independent assessor. Miller says the amendment gives him access to all information in the Fire Department. The Board of Fire Commissioners appointed him to the position in October 2009.      Miller says his troubles with the City Attorney's Office began just months into his tenure, when he criticized the office in a report on the Fire Department's disciplinary process.      Trutanich's attorneys, in "malicious retaliation," advised the fire department to shut Miller out of disciplinary meetings, claiming he did not have authority to look at private litigation files, according to the lawsuit. Miller says he has faced obstruction ever since.      Miller claims he lodged a state bar complaint in early 2012 against Trutanich, Carter, Echeverria, Houston, Jackson and Swanigan, for their refusal to give him "unfettered access" to Fire Department records.      The state bar closed its investigation into Trutanich and its attorneys in August 2012.      But in the midst of Trutanich's re-election bid for city attorney, the L.A. Times reported that Miller had filed a state bar complaint against Trutanich, alleging misconduct in January 2013.      Miller claims that defendant Carter defamed him in the article by saying he was waging a "smear campaign against dedicated, career pubic servants," and suggesting that Miller's actions were politically motivated.      The dispute came to head on July 1, when Houston and Jackson filed a lawsuit against Miller alleging race and gender discrimination and retaliation, according to the complaint.      The city attorneys, both African-American, claimed that former Mayor Antonio Villaraigosa was complicit in Miller's alleged harassment.      In his countersuit, Miller calls the complaint "frivolous," and says it was filed "for the sole purpose of harassing Villaraigosa, Miller and the City of Los Angeles."      "The true purpose in filing and serving their lawsuit is to aggressively use race, gender and sex as a tactical coercive weapon to advance their own retaliatory motives and strategies in an effort to protect themselves from the consequences of and to profit from their misconduct," the complaint states.      Mike Feuer defeated Trutanich in this year's city elections.      Miller seeks compensatory and punitive damages and costs.      He is represented by Dennis Wagner with Wagner & Pelayes of Riverside.      Neither the City Attorney's Office nor the Fire Department responded to requests for comment.

Declaration of Kelley Lynch - Probation Violation

DECLARATION OF KELLEY LYNCH

I, Kelley Lynch, do state and declare as follows:

1. Ì am a citizen of the United States who resides in Los Angeles, California.  Except as to those matters state on information and belief, I have personal knowledge of the facts set forth and could and would testify competently if asked to do so.
2. These are my responses to the accusations and allegations raised in Vivienne Swanigan’s Declaration.
3. Immediately upon Lynch’s release from Lynwood Jail, she was contacted by various parties including, but not limited to, Stephen Gianelli, Susanne Walsh, the 14^th Sheepdog, and Kelly Green.  She has received inconceivably vile and malicious emails from these parties.  They appear to be engaged in a highly coordinated campaign of criminal harassment.  They have relentlessly targeted my sons, sister, elderly parents, and just about everyone in my life.  I have no idea who these individuals are but am aware that Gianelli is a lawyer from the Bay Area and Susanne Walsh is Leonard Cohen’s fan who frequently copies his lawyer, Michelle Rice, in on her emails.  Since moving the Los Angeles, California, my roommate – Paulette Brandt – has been relentlessly harassed by Ray Lawrence, Susanne Walsh, and Stephen Gianelli.  Some of the harassment was addressed in the following document that includes the declarations of Ray Charles Lindsey and Paulette Brandt.
4. On or about November 20, 2012, Stephen Gianelli wrote prosecutor Sandra Jo Streeter a malicious and vile email slandering me.  He proceeded to send this email to my sons and others.  My younger son has been quite clear – these emails have made him physically ill.  My older son simply advised Gianelli to SHUT UP and informed him that his life was worthless or meaningless.  The City Attorney, in keeping with their practice throughout my trial, has concealed the totality of circumstances, attached evidence that they feel advances their argument while suppressing evidence that is favorable to Defendant, and have highlighted information and details that are taken out of context and appear to be random.  Gianelli continued to write Streeter, copying in my sons and others.  I, in turn, refuted the malicious lies and slanderous accusations as is my right.  I have been documenting everything I have gone through since reporting Cohen’s tax fraud to the IRS, on or about April 15, 2005, for the IRS, FBI, DOJ, Treasury, FTB, Phil Spector, Dennis Riordan, the news media, and others.  That is entirely legitimate.  I also am entitled to my personal opinions including as they relate to government and a prosecutor, and others, who are willing to lie, and engage in other misconduct, in order to obtain convictions.  I have no idea what happened between November 2012 and January 2013 with respect to emails Stephen Gianelli, and others, were sending prosecutor Sandra Jo Streeter given the fact that Workplace Violence did not become involved until January 2013.  I am convinced that Stephen Gianelli is engaged in a proxy war that relates to all matters having to do with Leonard Cohen, the IRS, and Phil Spector.  Investigator William Frayeh/DA’s Office concluded that this man is a “shady character” who may have found a sympathetic ear with Phil Spector prosecutor Alan Jackson about me.  I have no doubt about that.  None of my behavior is “directed” at Streeter regardless of Swanigan’s gratuitous comment.
5. I am not convinced I was actually “convicted,” following a “fair trial,” and intend to file a Petition with the Court of Appeals once I am in receipt of her file from the Public Defender’s Office.  The trial record is replete with false statements, perjured testimony, and a great deal of information was misleading, blatantly false, and evidence was concealed, withheld, or otherwise suppressed.  That would include the fact that I was never in an intimate sexual dating relationship with Leonard Cohen; there is no domestic violence; and, I do not have the IRS required form 1099 for the year 2004.  The IRS is not in receipt of that required form either.  In the Spring of 2013, the IRS advised me to file fraud form 3949(a) with respect to Leonard Cohen’s fraudulently obtained refund and the illegal K-1s he has transmitted to the IRS and State of Kentucky, wrongfully indicating that I am a partner on an entity he is the sole owner of – LC Investments, LLC.  The IRS, State of Kentucky, and FTB continue to advise me to contact Cohen to ask him to rescind the K-1s for the years 2003, 2004, and 2005.  They completely undermine the fraudulent expense ledger/report due to the fact that they note that I had $0 income from that entity for those years. 
6. I was prosecuted and sentenced for violating a domestic violence order I was not notified of or served.  The original 2008 Boulder, Colorado order is a civil harassment order that cannot be modified.  Approximately five or six months after my release from Lynwood, I phoned LA Superior Court’s Domestic Violence division; spoke to someone; and after providing them with the case number for the restraining order at issue, I was asked if Leonard Cohen was my boyfriend.  Leonard Cohen and I have never been in any type of dating and/or sexual relationship.  LA Superior Court also advised me that I had to be notified and/or served with this order which they understood was a foreign order.  The Boulder, Colorado order can only be modified by the original court and yet somehow it has transformed from a civil harassment order into a domestic violence order.  It is my position that LA Superior Court has no jurisdiction over me and this is an issue I plan to take to the U.S. Supreme Court if need be.  I am aware of my sentence and continue to contest that as well.
7. Lynch did not begin a campaign of email and telephone harassment of DCA Streeter and is astounded that Swanigan would sign her declaration under the penalty of perjury.  My email account is not, as Swanigan states, Kelly.lynch.2010@gmail.com. 
8. My phone calls and emails did not originally center around alleged IRS wrongs although I am aware that Sandra Jo Streeter lied about me and federal tax matters.  That would include accusing me of being a “con artist” and advising the jury that the tax issues were a “ruse.” I have asked the Internal Revenue Service to investigate her entire trial and the false statements and perjured testimony regarding tax matters.  Swanigan forgot to note that I phoned the City Attorney’s Office numerous times – originally – to advise them that I did not want to be copied in on emails with prosecutor Sandra Jo Streeter and felt Michelle Rice had violated the terms of the restraining orders via Susanne Walsh’s emails that copied her in.  I have no idea why this woman would go to the lengths she has and then permit Walsh to copy her in on emails to me, my sons, and others.  I spoke to LAPD’s TMU about this situation.  I have also spoken, at length, with the FBI in Oakland and Los Angeles about these emails and the fact that these individuals can be prosecuted for lying to the FBI which is precisely what they have done.  That includes with respect to my federal and state tax returns.  In any event, Swanigan evidently is unaware of the actual nature of my calls and emails but is the “lead attorney on … Workplace Violence Unit; … responsible for analyzing workplace violence complaints …” She is also one of the subjects of Steve Miller’s federal civil rights lawsuit that involves allegations, directly related to the City Attorney and members of this Unit also involved with Lynch (namely Swanigan and Hugo Rossiter) of retaliation.  Exhibit:  Front page of Steve Miller federal lawsuitsuit.http://firelawblog.com/files/2013/07/LACityAttorneys.pdf 
9. I am not in need of psychological counseling regardless of the lies the City Attorney seems determine to perpetuate about me.  I am completely unaware of any issues having to do with mental health, disciplinary problems, etc. with respect to DCA Sandra Jo Streeter, Vivienne Swanigan, Susan Schmitter, Hugo Rossiter, and others at the City Attorney’s Office and believe that information is entirely relevant.  Their perceptions are also at issue.
10. My emails, primarily addressed to the IRS, FBI, DOJ, Treasury, FTB, and Dennis Riordan do not center around “perceived wrongs against” me in my criminal trial.  I have addressed, in my appeal and initial writ of habeas corpus, false statements, perjured testimony, and prosecutorial misconduct.  With my appellate attorney’s advice and counseling, I attempted to abandon my appeal due to what I am convinced is prosecutorial retaliation on the part of Sandra Jo Streeter with respect to her false allegations about me to LAPD’s TMU.  I am convinced that Streeter “lied to LAPD” about me and the ongoing conduct on the part of the City Attorney’s office, with respect to me, is indeed “unconscionable government conduct.” My appellate attorney was convinced that my 2012 trial was actually an IRS matter that demands and IRS investigation and advised me that he thought Streeter’s lies to LAPD about me could be viewed as criminal obstruction of justice.  That informed my decision to abandon my appeal.  I have no idea what Streeter’s “ulterior motives” are or were.  I witnessed numerous lawyers from the City Attorney’s Office inform judges that my case was rare or unusual due to the fact that it involves a celebrity.  Streeter, not knowing me or my life at all, simply told the jury that my life seemed “fabulous” and felt that Cohen had a right to expose his penis to me, engage in sexual harassment, and was then entitled to feel annoyed.  I am filing Complaints with the Criminal Grand Jury of Los Angeles, District Attorney’s Justice Integrity Division, Department of Justice, State Bar, and others, that will more fully address this situation.
11. The allegation that I said Streeter and/or LAPD threatened me is vague and therefore I am unable to respond properly.  The Opening and Closing arguments are filled with lies.  Leonard Cohen exposed his penis to me and that is ordinarily viewed as indecent exposure and sexual harassment.  During my trial, this was evidently my intent to “annoy” Leonard Cohen.  Actually, Streeter made disparaging and vile remarks about me to the jury. 
12. My emails to the City Attorney, including those to Streeter and Swanigan, are most certainly not in violation of the terms of my probation.  I have every right to communicate grievances to my so-called government; to seek redress; file complaints; represent myself with the expectation that opposing counsel will conduct themselves professionally; refute malicious slander and lies; address the ongoing harassment and stalking of my sons and others; follow up with respect to documents that I should have been promptly served; and so forth and so on.  Many of these rights arise within the context of the First Amendment to the United States Constitution and will be addressed in a federal lawsuit.  It is also my personal opinion that the City Attorney is retaliating against me and this is their affirmative defense.
13. On February 14, 2013, Lynch sent the FBI and DOJ a series of emails addressing a number of issues including the fraudulent use of phony threats against people (ie., the drone Valentine card at issue), the lack of the statutory required “dating relationship,” Oriola v. Thaler that addresses the fact that there is no appropriate definition in California with respect to the phrase “dating relationship.” No words were typed onto this card.  I found this card online at a site that deals with serious political issues that relate to, among other things, drone campaigns.  I also worked, for nearly a year, on ACLU campaigns that included issues related to warrantless surveillance, illegal government surveillance of its citizens, the CIA and drones, etc.  The only phrase in the Valentine’s Day email that related to Streeter was the P.S. “Hopefully Streeter won’t charge me with terrorist threats.”  I receive numerous responses to the Valentine’s Day Card.  All reasonable and intelligent individuals thought it was cute and funny.  Lynch typed nothing onto the card which she found posted online at WEBSITE ADDRESS with an article by Glenn Greenwald posted underneath the image/words which cannot be taken separately or out of context.  The same is true for the email thread.  Exhibit:  Emails in response to drone card and entire drone card thread.
14. I have no potential for violence and find this false accusation highly slanderous and damaging to my reputation.  I have asked the DOJ and FBI to investigate the City Attorney’s Domestic Violence Unit and the possibility that this probation matter is retaliatory.  I have advised IRS, FBI, DOJ, Treasury, FTB, and Dennis Riordan that the City Attorney and LAPD’s TMU continue to monitor her.  I continue to send the City of Los Angeles’ IP information, and visits to her blog, to the FBI privately.  Due to the issues raised, during my trial, with respect to Phil Spector, DA Steve Cooley, DDA Alan Jackson, and Leonard Cohen’s highly embellished good rock and roll gun story about Phil Spector, I have also asked Phil Spector to have his legal team and investigators investigate this matter.  It is the conduct of the City Attorney’s Office that is disturbing – not Lynch’s.  The fact that they refuse to take responsibility for their actions, while tasked with prosecuting people, is a highly problematic situation.
15. I have re-routed all emails to the IRS, FBI, DOJ, Treasury, and Dennis Riordan.  My appellate attorney advised me to forward all emails from Gianelli, Walsh, Lawrence, and others, to the FBI. 
16. LAPD’s TMU did not intervene with respect to me and my communications to government but that does raise very serious legal issues that will be pursued.  LAPD’s TMU has no right to prevent me from airing grievances directed at my government.  I phoned LAPD’s TMU to discuss something unrelated to the February 14, 2013 Valentine’s Day email thread.  Detective Viramontes then phoned me back and mentioned that Hugo Rossiter had contacted him.  He asked me if the drone card was a joke.  The drone card was and remains an example of what I believe is an out of control government entity as I have more fully addressed with the DOJ and others.  At that time, Viramontes advised me that Streeter was “terrified.” I asked him if he thought she had psychiatric problems and suggested that he phone her directly and ask her if the real threat here is the IRS and FBI.  After all, I have been extremely public about my views on this situation and the fact that it demands an investigation.  Viramontes said he would ask Streeter that question. 
17. Lynch didn’t resume her campaign of harassment and finds Swanigan’s assessment frightening and alarming.  Stephen Gianelli resumed his communications with Streeter.  I have no idea if Gianelli wrote Streeter without her knowledge but tend to doubt she was unaware that he was writing her about me for months, copying in my sons, sister, and others.  Both of my sons have advised Gianelli, and others, to cease and desist.  Paulette Brandt advised him, and others, to cease and desist.  My sister’s attorney, Jim Walker, personally spoke to Gianelli and advised him to cease and desist.  My appellate attorney advised me to contact LAPD’s TMU about the situation.  And, my appellate attorney sought legal advice from an internet expert.  He then advised me that there is nothing I can do about this unconscionable activity.  I am entitled to my opinions and that would include with respect to Gianelli’s proxy war that involves Cohen fan, Susanne Walsh, Michelle Rice, Kelly Green, and others.  As early as 2007, Kelly Green (who works in tandem with Gianelli, Walsh, and others) posted on a blog that demonized Phil Spector and glorified DDA Alan Jackson.  Gianelli and Phil Spector’s former assistant, Michelle Blaine, and others, targeted Lynch’s email accounts and blogs, had them taken down, and publicly congratulated one another.
18. Lynch continues to re-route all emails to the IRS, FBI, DOJ, Treasury, FTB, and Dennis Riordan.
19. There is nothing reliable about Stephen Gianelli writing the City Attorney, on June 12, 2013, and advising him that I relocated to Hollywood, California.  I do not know Stephen Gianelli but believe he may have been behind the credible death threat Paulette Brandt recently received. 
20. Stephen Gianelli is the individual who obtained both Streeter and Swanigan’s email addresses and began slandering me to them while copying in my sons, family members, friends, and others.
21. I have no idea how many alleged emails Swanigan has received from me.  I think Swanigan should be clear that the words “white supremacist” and “murder” relate to a Dallas FBI investigation and information I provided them that relates to their investigation into the Aryan Nation.  That issue was used against me during my trial.  The Dallas FBI’s investigation into a murder, Aryan Nation, Cartel, meth labs, and meth cooks (according to Streeter and Cohen) is now an implied threat against Leonard Cohen.  Of course, I have asked the FBI to thoroughly investigate that matter and other information I have provided law enforcement with respect to criminal activity.  It is my personal belief, based upon what I witnessed and the trial transcript, that Sandra Jo Streeter belongs in prison.  I am not alone in that assessment.  Perhaps that’s what actually terrifies her since she lied about IRS and federal tax matters and potentially obstructed justice. 
22. I do not write emails 7 days a week/24 hours a week.  I would not ask Swanigan for legal advice.  I might pose a rhetorical question to her.  I would never take legal advice from someone willing to lie under penalty of perjury and in other ways. 
23. My emails are entirely legitimate and the same will be true for my federal lawsuit and complaints to the Criminal Grand Jury of Los Angeles, DA’s Justice Integrity Division, Department of Justice, State Bar, and Ethics Commission with whom I recently spoke about this situation and my views that this probation violation is actually retaliation and potentially an affirmative defense.
24. I do indeed maintain a blog at riverdeepbook.blogspot.com however that blog url address is incorrectly presented in Swanigan’s declaration. 
25. Whether or not LAPD has verified my email address is a matter of hearsay as of this moment in time.
26. I would like to know what happened to all emails between November 2012 and January 2013 and what, if any, other emails Streeter has received from Gianelli, Walsh, and others that relate to my 2012 trial and probation matters.

I declare that the foregoing is true and correct under penalty of perjury under the laws of the State of California, and if called to testify, I would and could testify truthfully as to the above.  Executed this 12^th day of November, 2013.

                                                                        _____________________________________

                                                                        Kelley Lynch