DECLARATION
OF DANIEL J. MEADE
I, Daniel
J. Meade, do state and declare as follows:
1.
I am a citizen of
the Halifax, Nova Scotia, Canada. I was born and raised in the United
States.
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.
teacher, appointed me to the
position of Executive Director to the Philadelphia branch of Vajdrahatu
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
closest friends. We have stayed in close contact consistently for
over 35 years.
5.
I also
know Kelley's parents, grandparents, brother, sister, sons and second husband,
Douglas
Penick, who is 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 and 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 with 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 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.
There were numerous children and teenagers in her home during the
evenings and weekends. 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. Douglas Penick is Rutger's
father and a close friend of mine.
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,
were extremely possessive of
her, privately conducted themselves in a jealous and hostile manner towards her,
and became angry and vicious when she was unable to tend to them specifically.
10. In the
35 years I have known Kelley, I have never once heard that she and Cohen were
in a brief,
intimate dating
relationship. I have, on the other hand,
heard first hand that she felt Cohen’s conduct towards her was technically
sexual harassment 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.
12. 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 6th day of October 2014 at Halifax, Nova Scotia,
Canada.
SIGNED___________________________________
Daniel
J. Meade
