DECLARATION OF CLEA SURKHANG
I, Kelley
Lynch, do state and declare as follows:
1.
I am a citizen of
the United States and currently reside in Longmont, Colorado. Except as
to those matters stated on information and belief, I have personal
knowledge of the facts set forth herein and could and would testify competently
if asked to do so.
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.
3.
During the mid-to-late 1980s,
Kelley and I lived in New York City. We
saw each other every
week for dinners and over the weekends. Kelley had a young son at the time and they
lived together in a beautiful apartment that she kept spotless.
4.
In 1987, I
moved from New York City to Colorado.
Kelley and I remained in close touch and
visited
when we were able to do so. My husband,
Yongzin Rinpoche, is also a close friend of Kelley’s.
5.
I visited or spent 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.
6.
I am aware that Kelley worked as Leonard Cohen’s personal
manager. She never once indicated
that they
were having an intimate relationship. We
frequently had girl talks and he was not someone she was ever interested in
dating. I specifically recall asking her
directly: Were you dating? Did you ever find Cohen attractive? Her answer was always “No.”
7.
I’ve watched Kelley’s boys, Rutger and Ray, throughout
their childhoods. They are both bright,
good
hearted fellows. Kelley is an amazingly
strong, kind-hearted being, that has worked her entire life to help her
children, parents, friends, and everyone who asked for her assistance. Her care for others is genuine and
profound.
8.
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 blue eyes, and wore her hair a very dark shade of brown
and short.
9.
Since Leonard Cohen filed his lawsuit against Kelley, in
the summer of 2005, she has continually
maintained
that she was not served the summons and complaint.
10. I am quite
confident in Kelley’s integrity and the fact that she was as professional and
straightforward with 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 and that I executed this
Declaration on the 6th day of October 2014 at Longmont, Colorado.
___________________________________
Clea
Surkhang
