Kelley Lynch's Email To DOJ Re: Leonard Cohen's Perjured Testimony, City Attorney's Tactics, & Former DA Steve Cooley's Failure To Investigate Or Prosecute Serious & Willful Criminal Negligence

From: Kelley Lynch <kelley.lynch.2010@gmail.com>
Date: Thu, Nov 20, 2014 at 2:12 PM
Subject: Re:
To: DOJ, FBI, IRS cc:  Multiple Parties

Hi DOJ,

I don't know why Ray's "default judgment" custody matter was raised as an issue.  He was over 18 by this time.  In any event, Cohen and Kory initially went into Ray's father's office and falsely accused me of having sex with Oliver Stone and others.  Clearly, they intended to stir up a custody matter.  I was also falsely accused of having sex with Richard Westin to obtain the annuity obligation that was extinguished, without my knowledge, from the 2003 TH federal tax return.  Please take a look at the attached documents.  They would include the Schedule I am preparing re. all statements in Greenberg's Amended Complaint that I agree with.  I was in contact with Boies Schiller - NOT Neal Greenberg.  I've also attached the draft declarations I've now received from Clea Surkhang, Dan Meade, and Palden Ronge that will be attached to my motions.  I've attached my mother's declaration that was filed in the probation retaliation matter.  That declaration was signed December 24, 2013 which was two days before my mother had a stroke. She was extremely concerned about my welfare.  I, as you should know, never "suggested" that Leonard Cohen was responsible for the "accident that befell" Rutger.  There is no evidence to support that outrageous statement and I agree with my mother - that line of questioning and testimony is evidence of the evil individuals involved in this matter.  Streeter failed to advise the jurors that I was upset with Cooley for his failure to investigate the criminal negligence in Rutger's Whole Foods matter as many young people were exposed to very dangerous circumstances that were clearly serious and willful.  Leonard Cohen will say anything.  He is a professional liar.

All the best,

Kelley

Streeter:  All right.  Did does Ms. Cohen [Lynch] have any children?  The Court:  Ms. Kelley – Ms. Lynch.  Streeter;  I’m sorry.  Does Ms. Lynch have any children?  Cohen:  Yes, Ma’am.  She has two sons.  Streeter:  Did she ever mention any of her children in any of the voicemail messages?  Cohen:  Yes, many times.  She – she accused me of being indirectly responsible for her losing custody of one child.  Streeter:  What was that child’s name?  Cohen:  That child’s name was Ray Lindsey – Streeter:  Does she have another child?  Cohen:  Yes, she has another child.  Streeter:  What’s that child’s name?  Cohen:  His name is Rutger Bennett [Penick].  Streeter:  Does she ever mention Rutger – Cohen:  Yes, many times she suggested I was responsible for an accident that befell him.  RT 57-58

DRAFT DECLARATIONS

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 6^th day of October 2014 at Longmont, Colorado.

                                                                        ___________________________________

                                                                        Clea Surkhang

 DECLARATION OF PALDEN RONGE

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. 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.      My wife, Lila Rich, and I have known Kelley for years.  I personally met her in approximately

1988.  We are close family friends and I know her sons, Rutger and Ray.  We 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.  Kelley worked as Cohen’s personal manager for many years.  I met Mr. Cohen socially with Kelley on numerous occasions.  It never once crossed my mind that they were involved in any type of intimate dating relationship.  Nor had I heard anything to indicate that their relationship was anything but professional.  I know Kelley’s ex-husband, Douglas Penick, the father of her younger son (Steve Lindsey), and from 1988 through the present feel it is accurate to say that her relationship with Leonard Cohen was a professional business relationship.

5.      I also 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 attended the January 17, 2014 hearing in this matter and had hoped to testify on Kelley’s behalf. 

The opportunity to do so was not presented.   I visited Kelley throughout the 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.  At that time, she had bright blue eyes, very dark short hair, was approximately 5’6”, and very thin (perhaps weighing 110 pounds).  For years, she had worn her hair very light blonde and it took me some time to grow accustomed to Kelley’s dark hair and new look.

7.      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 the summons and complaint. 

CAR ACCIDENT.

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 6^th day of October 2014 at Los Angeles California.

                                                                        ___________________________________

                                                                        Palden Ronge

 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. 

2.      I first met Ms. Lynch in 1978 when Chogyam Trungpa Rinpoche, a well known Tibetan Buddhist

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 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.  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 6^th day of October 2014 at Halifax, Nova Scotia, Canada.

                                                                        ___________________________________

                                                                        Daniel J. Meade

 JOAN LYNCH DECLARATION SUBMITTED TO COURT DECEMBER 2013 RE. PROBATION RETALIATION MATTER

 DECLARATION OF JOAN MARIE LYNCH

I, Joan Marie Lynch, do state and declare as follows:

1. I am a citizen of the United States and a resident of the State of Texas.  Kelley Lynch is my

daughter.  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. My husband, John Lynch, and I have a very close relationship with Kelley and her sons, Rutger

Penick and Ray Charles Lindsey.  In 1992, my husband and I relocated from Philadelphia, Pennsylvania to Los Angeles to be near Kelley and our grandsons.  We were extremely involved in the upbringing of our grandsons, saw them on a daily basis, picked them up from school, knew their friends, attended school and sporting activities, spent a great deal of time in their home, and enjoyed a very warm and close relationship with our daughter and her family.  We also worked with Kelley and saw her on a daily basis.

3. Until his death in April 1988, Kelley worked as Marty Machat’s legal and personal assistant.  It

was during this period of time that Kelley became acquainted with Phil Spector and Leonard Cohen.

4. For approximately 17 years, from 1988 until the fall of 2004, Kelley worked as Leonard Cohen’s

personal manager and in other capacities.  From approximately 1996 through 2001, Kelley also worked as Adam Cohen’s personal manager.  Adam Cohen is a musician in his own right and the son of Leonard From approximately 1988 until 1991, Kelley worked as an intern/assistant to Phil Spector.

5. Although Cohen has stated to the contrary, Kelley never worked as his business manager.  She

did not handle matters related to taxation, corporations, finances, investment decisions or advice, accounting, estate planning, or legal issues.  Leonard Cohen had a team of professional representatives handling these matters.  Those individuals included, but were not limited to, Neal Greenberg (investor/financial advisor), Richard Westin (tax and corporate lawyer), Arthur Indursky (transactional lawyer), Don Friedman (transaction lawyer), Stuart Fried (transaction lawyer), Jean Ransick (bookkeeper), Burt Goldstein (accountant), Ken Cleveland (accountant), Peter Shukat (transaction lawyer), Jeffrey Hafer (transactional lawyer), Jonas Herbsman (transational lawyer), Rich Feldstein (business manager), Peter Lopez (transactional lawyer), Bud Talbot (Dean Witter), Lee Alpert (lawyer), Reeve Chudd (estate planning lawyer), Herschel Weinberg (personal lawyer and family friend), Greg McBowman (royalty consultant), and others.

6.       Jean Ransick, who resided in New York City, worked as Leonard Cohen’s bookkeeper from

approximately 1988 through 1997.  Thereafter, Cohen hired his daughter’s friend, Jen Brown, to assist with his bookkeeping.  Cohen never replaced Jen Brown with another bookkeeper and additional work fell upon Kelley.  At some point, Cohen asked my husband to assist with check writing, bills, and other administrative matters.

7. From approximately 1992 through the winter of 2005, I worked as Kelley’s personal assistant and

office administrator.  My daughter had two businesses:  Stranger Management, a personal entertainment management company, and Amazing Card Company, a greeting card company.  My duties included general office management tasks, supervising all employees, handling the phones, receiving mail and faxes and distributing them, communicating with Cohen and his representatives, communicating with Adam Cohen and his representatives, assisting Adam and Lorca Cohen with various matters, ordering Canadian drafts for Cohen’s Montreal properties, faxing information to Cohen and his representatives, transmitting phone messages to Leonard Cohen, apprising Cohen and Kelley of personal and corporate bank balances, transmitting sales figures and royalty statements to Kelley and Cohen, receiving and shipping fedex packages, arranging for notaries, overseeing the filing systems, and generally handling all administrative duties.  I personally oversaw the filing system that included Kelley and Cohen’s records as well as the corporate records.

8. I worked with my daughter on a daily basis for over 12 years and am well aware of how the office

functioned.  I know Leonard Cohen and his family extremely well.  I oversaw the work of all Stranger Management and Amazing Card Company employees.  That would include, but is not limited to, Kelly Owens, Betsy Perks, Morgan Martin, Sarah Vienot, all greeting card company employees, and brief temporary employees such as Julie Isenberg.  My daughter, Karen Lynch, also worked with us for a period of time until she left to work for Billboard Magazine and/or Peter Lubin of Giant Records.

9. In or around 1996, Leonard Cohen hired my husband to oversee the construction and renovation

of his garage and commercial building on Melrose Avenue.  Jack had been a General Contractor in Philadelphia, Pennsylvania and Cohen was having difficulties with this project.  At some point thereafter, as addressed above, Cohen asked my husband to assist him with additional tasks.  Neither my husband nor I ever worked as Leonard Cohen’s bookkeepers.     

10. In or around 1996, Leonard Cohen converted his garage into a recording studio and guest suite. 

At that time, Cohen instructed me to make arrangements to pick up boxes of older business documents and other items (many of which Kelley brought with her when she moved her office from NY to LA) he stored in his garage.  Due to the fact that our offices were literally overflowing with other Cohen business documents and boxes of archival documents, it was agreed that Kelley would store these items in her home garage.  Leonard Cohen was well aware that Kelley agreed to store these boxes in her home and he also understood that she had a home office which she worked from on a daily basis.   Given the fact that Kelley carpooled on a daily basis, she would arrive at the office at approximately 8:30, leave the office at 2:00 PM, pick up the children, return home, and work from her home office.  Leonard Cohen was aware of her schedule.  He also understood that she was in charge of pizza lunch at Ray’s school on Fridays, took horseback riding lessons twice a week, and could (and would) contact me when she was unavailable.  Leonard Cohen was not only in touch with Kelley throughout the weekday, he frequently phoned her at home on weekends and during the evenings.  She would begin making calls to Europe at 6 AM or so from her home.  At one point, she also car pooled Lorca Cohen and Steve Lindsey’s daughter, Jennifer.  Cohen would frequently join her for the ride.  I think it’s safe to say that Cohen and Kelley were inseparable.  They routinely had lunch together.  I would prepare copies of documents for Kelley to review at lunch with Cohen.  When Kelley returned from her lunches with Cohen, I would be given instructions on how to respond to requests from Cohen’s representatives, fans, website hosts, record companies, etc.  Cohen was fully apprised of his business affairs, financial matters, accounting issues, legal matters, the status of the deals he demanded, expenditures related to his family and friends, and everything in his life.  Leonard Cohen was a shrewd businessman who micro-managed his affairs.

11. I am well aware of Kelley’s compensation agreements with both Leonard Cohen and Adam

Cohen. I handled deposits into all of their accounts.  I was present for conversations Leonard Cohen and Adam Cohen had with Kelley regarding her services and compensation.  Kelley’s fees for her services as personal manager were 15% of gross income.  That is the agreement she had with both Leonard Cohen and Adam Cohen. Adam Cohen and Kelley’s agreement was written on a small post-it note that she had on the wall in her office.  This agreement always amused Adam Cohen.  Leonard Cohen also compensated Kelley with 15% of all his intellectual property due to the extraordinary amount of work she did on his behalf including with respect to music and book publishing and marketing, publicity, assisting his fan websites, business matters related to his artwork and lithographs, various activities related to Sasaki Roshi’s Zen centers (including almost single-handedly organizing and arranaging Roshi’s 90^th formal birthday party that included custom designed pins, banners, a book, and other items and serving on Rinzai Ji’s Board of Directors), his children, his girlfriends, houses he owned worldwide, and a wide variety of assistance with his personal and professional life. 

12.   For years, Leonard Cohen did not compensate Kelley fully and properly for her services as his

personal manager.  This issue came to a head sometime in or around 1996 when Kelley rented an office on Keniston Avenue in Los Angeles.  At that time, and I was present for these discussions, Cohen agreed to pay Kelley 15% of his gross income and promised that he would have an accountant review her compensation from 1988 to ensure that she received the full 15% commission for all years she worked as his personal manager.  I also recall taking notes of their agreement because I contacted Peter Shukat, Cohen’s lawyer, to follow up on a draft agreement he was preparing with respect to her services and fees for work she did as Cohen’s personal manager.  I recall the draft agreement being faxed through. 

13. In October 2004, Leonard Cohen unexpectedly flew in from Montreal, Canada.  He had left Mt.

Baldy permanently sometime around 1998.  In October 2004, he and Anjani Thomas were visiting Cohen’s home in Montreal.  As I recall, Kelley (who handled many household and personal matters for Cohen) had dropped his car off at the repair shop and he called our office to find out where it was and asked her to join him for coffee and drop him off at the repair shop.  Cohen walked over to our office and he and Kelley left together.  When Kelley returned she advised me that their conversation was bizarre.  I distinctly recall her telling me that Cohen was interested in Betsy Superfon’s sex life.  Superfon, a friend of Steve Lindsey’s, had recently befriended Kelley and had a tendency to stir up problems with Lindsey.  Steve Lindsey is the father of Kelley’s younger son, Ray.  Cohen was not only interested in Superfon’s sex life but questioned Kelley about an IRS investigation into Superfon’s phone sex line business.  Cohen also evidently questioned Kelley about a young woman by the name of Julie Isenberg.  Isenberg was the daughter of Superfon’s former business partner, Joel Isenberg. Julie Isenberg worked for us for approximately one week in August of 2004 and Cohen met her at that time.  After Kelley returned from Starbucks, she jokingly commented that she thought Cohen might be planning to blackmail Superfon.  Neither Kelley nor Cohen mentioned anything having to do with financial or banking irregularities.    I find it impossible to believe that Cohen discovered irregularities in his personal bank accounts and he personally received his bank statements, reviewed them, asked questioned about them, had Kelley break them down into categories of expenses for him, and obsessively paid attention to his financial affairs, income, and bank balances.  It never occurred to me at this time that there was anything wrong in Kelley’s professional relationship with Leonard Cohen. 

14. At some point not long after Cohen returned from Montreal, he again visited our offices and

agreed to provide Kelley with an advance.  She explained to Cohen that she had extraordinary expenses related to her greeting card company.  I was present for this conversation.  Cohen acknowledged that he had not delivered an album for years, had not toured for years, and felt confident that the third Sony deal would close and they would receive substantial income from the lithograph deal, studio album sales, book sales, and his tour.  Cohen instructed me to retrieve his checkbook and he provided Kelley with a check.  Kelley gave me the check and asked me to send a messenger to deposit it in her City National Bank account.  As I was leaving for the day, I set the check aside and sent the messenger the next day.  At that time, we learned that the bank would not honor the check.   I have since learned that Cohen has falsely accused Kelley attempted a last minute “raid” on his account.  This is an entirely fabricated story.  Leonard Cohen began pressuring Kelley privately to meet with him and Richard Westin and I personally believe this move on his part was intentional and possibly well planned.  Leonard Cohen thinks things through very carefully and is extraordinary strategic and manipulative.  He is not the religious sage the news media has presented to the world.    

15. On October 21, 2004, Kelley advised me that she and Cohen would no longer be working

together.  He repeatedly asked her, including in my presence, if she would meet with him and Richard Westin, his personal tax lawyer, who was flying in at the end of the month.  Kelley refused and this issue, and corporate matters, created serious problems between the two of them.  She repeatedly advised me that Cohen asked her to hand over certain corporate books and records.  Cohen planned to meet with his tax lawyer, Richard Westin, and asked Kelley to assist them with various corporate matters.  Kelley refused to meet with Cohen and Westin.  She ultimately decided to give the corporate books and records to her lawyers.  It was highly unusual for Leonard Cohen to request that Richard Westin fly in from Kentucky.  I assumed there were serious problems related to the corporate structures or other matters Westin handled for Cohen. 

16. I am familiar with the numerous corporate entities that Kelley has an ownership in.  I frequently

handled the corporate files.  These were removed from our offices by Leonard Cohen and/or his daughter, Lorca Cohen in October 2005.  The corporate records clearly prove that Kelley has an ownership interest in Traditional Holdings, LLC and Blue Mist Touring Company, Inc.  Leonard Cohen was fully aware of this fact and all corporate records.  I was present for discussions between Kelley, Cohen, and his representatives, with respect to these entities.  I was present when Kelley and Cohen reviewed corporate documents prepared by Richard Westin and other Cohen representatives.  I frequently followed up with Richard Westin and others regarding their requests. 

17.  Leonard Cohen was well aware that he compensated Kelley with 15% of all intellectual property

as compensation for work she had done over the years.  This compensation was separate and distinct from her fees as Cohen’s personal manager.  Leonard Cohen personally dictated a portion of the Blue Mist Touring Company Minutes related to this compensation and the non-revocable assignments.  Kelley was compensated with a 15% ownership interest in Blue Mist Touring which owned the intellectual property assets.  Leonard Cohen was fully aware that Kelley, whom he personally asked to assist him, owned 99.5% of Traditional Holdings, LLC.  Leonard Cohen was also aware that LC Investments, LLC, a company owned entirely by Cohen, began collecting royalties for assets owned by Blue Mist Touring Company, Inc. due to the fact that SOCAN (performing rights association) refused to pay royalties to a company not wholly owned by the writer, Leonard Cohen.  That was their internal policy.  LC Investments, LLC was created to accommodate a bond securitization deal with CAK. 

18.  I specifically heard Leonard Cohen and Kelley discuss the need to have an accounting done at

some point in time.  Cohen felt a third party accountant could be brought in after the close of the third planned intellectual property deal.  It was my understanding that this accounting would address commissions due Kelley for the period she was not properly compensated as his personal manager, monies expended by Kelley on behalf of Adam and Lorca Cohen (including a publicist and independent record promotion for Adam Cohen), advances and/or loans Kelley or Cohen received from the corporate entities, and that the intellectual property itself would be valued. 

19. Kelley did not ask Leonard Cohen’s lawyer to come up with a scheme for her to receive capital

gains treatment on her commissions.  Richard Westin, who frequently spoke to me about all matters, would recommend various tax planning schemes.  As I recall, Westin always suggested that Kelley and Leonard Cohen form companies in Nevada.  This frustrated Kelley and Cohen himself believed this to be a reckless strategy.  Kelley frequently viewed Richard Westin’s suggestions as incoherent and inexplicably complicated. She refused his attempts to handle her commissions in complicated manners.  At one point in or around April 2001, Westin created the Ekajati Company for Kelley.  That was his plan with respect to handling her commission as capital gains.  He had also faxed through a completely incoherent set of paperwork related to an employer/employee pension plan that neither Kelley nor I could understand.  Kelley was not compensated with shares of Blue Mist Touring in some scheme related to capital gains.  Leonard Cohen has simply decided to confuse issues.  It is my personal belief that Leonard Cohen tends to become consumed with greed.  Kelley refused to use the Ekajati Company and refused to entertain other Westin recommended schemes.  Kelley’s ownership interest in Blue Mist Touring Company, Inc. has nothing to do with her commissions for services rendered Cohen as his personal manager. 

20. Since approximately 2002, Kelley had grown increasingly suspicious about Cohen, Neal

Greenberg, Richard Westin, and others.  This was due to conversations she had with them, letters and emails she received, and their ongoing concerns about tax matters.  At one point, Kelley was told that Richard Westin made the IRS nervous due to his evasiveness.  Kelley informed me that perhaps the IRS would like to drop by the office, review the paperwork related to various deals, and explain to her if they found any irregularities or problems with the tax planning.  In particular, Richard Westin’s emails and letters were alarming and became increasingly so.  They raised issues about Internal Revenue Service and tax matters, informed her that Neal Greenberg intended to screw her over, and appeared to intentionally confuse issues.  Neal Greenberg and Richard Westin repeatedly raised the fact that Leonard Cohen’s level of borrowing from Traditional Holdings, LLC was completely unacceptable.  Kelley repeatedly advised me that she felt Cohen and his representatives had used her horrendously.  In September 2004, Richard Westin wrote Kelley and Leonard Cohen that he had concerns about Traditional Holdings, LLC and expressed concerns about a possible IRS audit.   It was at this time that Kelley informed me that she was hiring Betsy Superfon’s accountant, Dale Burgess, and would no longer work with Ken Cleveland.   

21.  Leonard Cohen assured us that he intended to repay his Traditional Holdings, LLC corporate

loans and expenses.  Richard Westin frequently asked me to remind Kelley and Leonard Cohen that his loans needed to be repaid as quickly as possible with interest.  Cohen was finishing up his studio album; planned to deliver a new book and pursue a lithograph deal; continuously advised us that he planned to tour; and was pursuing a third intellectual property deal. 

22.  Cohen personally found Neal Greenberg’s admonishments about his future finances absurd,

understood he would make extremely large sums off his business plans and touring, but was concerned about Greenberg and Westin having details about his personal finances.  Leonard Cohen was fanatical about our confidentiality with respect to his financial matters.  He personally advised me, time and time again, that he did not want these matters discussing with anyone including his son and daughter,  Cohen also specifically advised me not to discuss financial arrangements or corporate matters with his family members and others.  We, of course, were absolutely confidential with this information. From my perspective, Leonard Cohen liked to keep people divided, did not want them interacting with one another, and only shared certain information with certain parties.  Kelley may very well have been the only individual in his life who had access to every area of his life, knew his family and girlfriends intimately, interacted with his friends, attended events with him, joined him at the Zen Center frequently, travelled with him, shopped with him, stayed at his the various homes he owned, was familiar with the most intimate details of his life, and they were inseparably close.  There is no one in this world who knows Leonard Cohen in the manner in which Kelley does.  I believe his betrayal of their friendship came as quite a shock.  The allegations in his lawsuit, when she was finally able to review them, were startling.  I was also stunned that Leonard Cohen would begin blaming me, my husband, and younger daughter for things we had nothing whatsoever to do with.  It is my personal opinion that Leonard Cohen has acted with malice, vengeance, and vindictiveness towards my daughter and I am convinced that he has acted out of desperation.  He is not as self-assured and confident as he may lead one to believe and he is obsessed with news accounts of his life, fan websites, and anything he views as a slight.  Cohen only had a handful of journalists he would routinely relate with.  One of those is Brian Johnson of MacLean’s Magazine.  I believe Cohen understood, all too well, that he was able to manipulate these journalists who are frequently devoted fans and want further access to his life. 

23.   From approximately 1990 through 1995, our office was downstairs from Leonard Cohen’s

apartment and his daughter lived there while she attended high school.  Kelley treated Lorca Cohen like her own daughter.  Lorca Cohen spent nearly every evening, while in high school, with Kelley and her family.  Kelley even assisted Lorca Cohen with her homework.  Kelley was extremely supportive when Adam Cohen was in a tragic automobile accident.  She visited the hospital in Toronto and also attempted to keep Suzanne Elrod, who resided in Paris, up-to-date on Adam’s progress.  Kelley was literally part of the Cohen family.  Our families spent many holidays together.  Kelley knew everyone in Cohen’s life.  His friends would speak with her.  Journalists like Leon Weiseltier befriended her.  Many people used Kelley in an attempt to become closer with Cohen. 

24.  From approximately 1995 through 2004, our offices were located one block from Cohen’s house. 

He, Lorca Cohen, and others had keys and unfettered access to our offices.  Cohen would frequently visit our office on weekends and evenings where he would review business and personal matters.  He also used the color photocopier for his artwork projects and would leave notes or instructions for me or Kelley. 

25. If Kelley was unavailable when Cohen called, he would ask me to review phone messages, faxes,

and mail.  He frequently instructed me on the handling of requests for information and other matters.  Cohen routinely asked me to review his sales figures and bank balances.  Sony faxed through sales figures once a week.  One of the first things I did when I arrived at work was to phone the automated City National Bank phone to obtain the balances in Cohen’s personal and corporate accounts.  This is information Cohen requested on a daily basis although.  Cohen was also in possession of all banking details and the automated City National Bank number where his personal and the corporate accounts were maintained. 

26.   It is imposible to believe that Cohen would suddenly notice financial irregularities in his personal

and/or the corporate and investment accounts as he was completely familiar with those accounts.  His personal bank statement went to his home.  He reviewed the corporate and investments statements and would place them in his outbox for filing when he finished reviewing them.  Leonard Cohen has come up with an entirely fabricated version of events that in no way relates to how our office functioned; how information was conveyed to him; and with respect to his financial and business affairs. 

27. Cohen was fastidious with respect to matters related to sales figures, finances, income, and

expenses.  Cohen understood that royalties were paid on a quarterly or bi-yearly basis.  He knew precisely when royalties were received from Sony, book publishers, and others.  He also knew precisely what advances were paid and when.  The lion’s share of income came from relatively few sources and Leoanrd Cohen was well aware of those sources and the timing of the payments.  Additionally, I would fax Cohen copies of checks we received.  Leonard Cohen was also well aware of any and all advances made to him.  With respect to the negotiations and advance for the studio album “Dear Heather,” Kelley and others spent nearly a year negotiating the terms and conditions.  Kelley had an excellent relationship with the Sony executives and legal/business affairs division worldwide and with all of Cohen’s representatives.

28.  Difficulties would arise with Sony.  At one point, executives of Sony asked to meet with Kelley. 

They expressed concern about Leonard Cohen’s threatening behavior and letters to Don Ienner, President of Columbia Records.  Problems arose between Cohen and Paul Burger, President of Sony International.   Problems also arose with Denise Donlon of Sony Canada.  That issue related to her position that Cohen was a Canadian roster artist.  I always suspected Cohen was concerned about his tax and residence issues in Canada.  I know that he and Kelley reviewed that situation with Van Penick and, after doing so, Cohen and Herschel Weinberg (a family friend and attorney) decided Cohen should forget his plans to return to Canada and reapply for a U.S. green card.   

29.  Leonard Cohen personally received and reviewed all mail and faxes.  These items were placed on

his desk and we frequently faxed him sales figures, business documents, royalty statements, financial statements, bank statements, information from his representatives, requests from fan based websites, and other information. 

30. Cohen constantly monitored the amounts of money he provided his son, daughter, friends, and

others.  He expressed frustration at the voluntary monthly gifts he provided the mother of his children, Suzanne Elrod, and others.  I personally faxed many hostile letters from Leonard Cohen to Adam Cohen regarding his finances.  Cohen was disturbed that Adam and Lorca Cohen could not live on $5,000 to $6,000 per month each in addition to other expenses. 

31. At some point during his 1993 “Future” tour, Cohen began having difficulties with his tour

manager and certain band members.  He began accusing his tour manager of stealing from him.  Kelley was overwhelmed with work during that tour, had negotiated the merchandising deal with Peter Lubin, was dealing with all tour personnel, Visas, insurance, payroll (with Cohen’s accountant), offers, and so forth.  I do not believe Cohen compensated her properly for her services in connection with this tour.  He had a sense of entitlement about him.

32.    During the Fuiture tour, Cohen’s accountants were on the east coast and he wanted someone in

Los Angeles who could audit the concerts.  Don Was referred Cohen to Richard Feldstein.  Cohen personally met with Feldstein at the Wiltern Theater and hired him to audit the concert and other tour documents.  Feldstein concluded that there were no irregularities with respect to the tour income.  It is my personal opinion that Leonard Cohen falsely accuses people of ripping him off to deflect attention from other issues and to break agreements he has made.    

33. Feldstein eventually wrote Cohen that he felt they should meet more frequently face to face and

raised concerns about his reluctance to pay estimated taxes.  Cohen’s response was to fire Rich Feldstein.  I faxed Feldstein’s letter to Cohen and recall this situation because the letter Cohen dictated to Kelley in response was appalling.  He fired Rich Feldstein and, from what I recall, advised him that accounting was not a religion.  I personally faxed that letter to Feldstein.

34. Leonard Cohen, who had used Burt Goldstein as his accountant prior to Marty Machat’s death,

continued working with him until sometime around 1996.  When the IRS audited issues related to the 1996 Stranger Music gift of charitable stock, Cohen needed an accountant in Los Angeles.  Steve Lindsey, who was Cohen’s record producer, recommended Ken Cleveland.  As the outcome of the audit was successful and Cleveland was in the Los Angeles area, Cohen decided to replace Burt Goldstein with Ken Cleveland.

35. In or around 1988, Kelley and her husband, Douglas Penick, referred Cohen to their investment

advisor, Bud Talbot of Dean Witter Reynolds.  Bud Talbot had a long standing relationship with the Penick family and had invested their substantial wealth for years.  I recall visting Kelley when Leonard Cohen was in New York City.  His personal lawyer, Herschel Weinberg, and he were unraveling matters related to certain corporate matters and off-shore accounts Cohen had prior to Marty Machat’s death.  It was at this time that he asked her who she and Douglas used to invest their money.  Kelley did not know Leonard Cohen well until following Marty Machat’s death.  She and Cohen most definitely did not have a brief intimate relationship at this time or throughout the years.  Leonard Cohen most definitely wanted to have such a relationship and was obsessed with my daughter. I believe this may explain some of his vindictive behavior towards her. 

36. In or around 1996, Neal Greenberg visited the Buddhist teacher His Holiness Kusum Lingpa in

Los Angeles.  Kelley, Oliver Stone, and others, sponsored a Buddhist center, Orgyen Khachod Ling, for His Holiness.  Leonard Cohen met Neal Greenberg during this visit.  He personally decided to hire Greenberg as his financial and investment adviser.  Kelley did not actually know Neal Greenberg prior to his visiting Los Angeles.  She was acquainted with his ex-wife, Karen Greenberg, and had no idea that he was an investor so she most certainly could not recommend him to Cohen.  I am aware that Kelley and Cohen personally phoned one of Greenberg’s other clients who confirmed that he was very comfortable with Greenberg’s investment strategies. 

37. Neal Greenberg introduced Cohen and Kelley to tax lawyer Richard Westin and others.  Cohen

hired Westin who then worked as his personal tax and corporate lawyer for years.  Neal Greenberg, Richard Westin, and other advisers, handled all estate planning, accounting, corporate matters, tax and financial issues, investments, and/or legal work.  At no time did Kelley advise Leonard Cohen with respect to these matters.  She never prepared a legal or financial document for Leonard Cohen or the corporate entities.  He relied solely on his team of professionals for that advice.  Kelley followed their directions, advice, and instructions.  At Cohen’s request, I typed a letter wrapping Neal Greenberg into attorney/client privilege with Cohen and Westin.

38. Leonard Cohen demanded the intellectual property deals that became the subject of his lawsuit

against my daughter in 2005.  The first deal closed in 1996; the second deal closed in 2001; and, Kelley, together with Cohen’s representatives, was working on the third deal when she and Cohen parted ways.  She was also assisting with the delivery, release, and marketing of the studio album “Dear Heather,” album packaging information, a very lucrative lithograph deal, the imminent release of “Book of Longing,” and other matters.  Cohen and Kelley also discussed his plans to tour.

39. I have reviewed Cohen’s complaint in this matter with my daughter and the entire

narrative was obviously fabricated.  In April 2005, Kelley reported Cohen’s tax fraud to IRS.  I am aware of the fact that Kelley was dealing with Agent Bill Beter of the IRS and confided in me that, once her own taxes were paid, she planned to address the allegations of Leonard Cohen’s tax fraud with him.  Agent Betzer called our offices and I am aware that Kelley was speaking with him about a number of issues.  Cohen’s lawsuit is obviously retaliation given the amount of time he spent attempting to coerce her into a settlement with him that included offers of substantial compensation.

40.  Kelley did not receive overpayments with respect to her work as Cohen’s personal manager.  She

never worked as Cohen’s business manager.  She has an ownership interest in Traditional Holdings, LLC, Blue Mist Touring Company, Inc., all intellectual property, and was advised that she would be compensated with 15% ownership interest in intellectual property and royalty income related to the “Dear Heather” studio album.  As of the fall of summer of 2004, when we were working on the album packaging, Cohen advised us that the “Dear Heather” publishing should be assigned to an entity known as Old Ideas, LLC.  Richard Westin informed Kelley that he understood she was to receive a 15% ownership interest in Old Ideas, LLC when he created the entity.  I reviewed emails Richard Westin sent regarding Old Ideas, LLC and filed them in the Old Ideas, LLC file that Cohen eventually took from our offices. 

41. Leonard Cohen is the individual who determined when these entities would be created and he is

the individual who named these entities.  I was present when Cohen signed many corporate documents, stock units, and am aware that he was fully aware and consented to Kelley’s ownership interest.  It is my personal opinion that not only has Leonard Cohen attempted to blame his wrongdoing on Kelley, he has also attempted to benefit by depriving her of property she owns and monies due her.  It is my understanding that very similar problems arose for Machat & Machat, with Cohen, after Marty Machat’s death.  I recall Steven Machat’s allegations that Machat & Machat owned 15% of Stranger Music, Inc. but never saw any paperwork supporting this allegation.  I understand that Kelley, when reviewing old business documents in the fall of 2004, came across evidence that Machat & Machat had an ownership interest in Stranger Music, Inc., contacted Steven Machat, and provided him with this evidence.  It is also my understanding that Steven Machat advised Kelley to sue Leonard Cohen for theft.  Boies Schiller advised Kelley, and I reviewed their emails with her, that they felt Cohen was attempting to engage her in criminal conduct and also advised her to sue Leonard Cohen for theft.  They seemed quite clear that Cohen was attempting to blame his wrongdoing on Kelley.  In fact, Boies Schiller attempted to help Kelley find legal representation.  After firing DiMascio & Berardo, Boies Schiller sent Kelley to two different law firms in Los Angeles.  In one email I reviewed, Boies Schiller told Kelley to explain to these lawyers that they understood it was a tax matter,  they had reviewed the corporate records and other evidence, understood Cohen owed her millions, and advised Kelley that she should offer them 30% of what Cohen owed her to represent her.  Boies Schiller also advised Kelley to go wired to her meetings with Leonard Cohen and his lawyers.  I distinctly recall them advising Kelley to contact the District Attorney’s Office.  It is my personal belief that Neal Greenberg’s lawyer, at Boies Schiller, used Kelley horrendously and may actually have attempted to lead her to believe that he was in love with her.  I found the situation thoroughly disturbing and know that Kelley discussed this situation at great length with Yongzin Rinpoche.  Rutger also informed me, after Greenberg’s lawyer visited Kelley’s home, that he felt he was the enemy.  His Holiness Kusum Lingpa, who was Greenberg and his lawyer’s teacher, explained to me that these two individuals will end up in hell for their conduct with respect to my daughter.  His Holiness appointed Kelley to be his lineage holder and wanted her to give empowerments, put his teachings into books, and guard his teachings.  His Holiness repeatedly informed me that he believed Leonard Cohen was an asshole who was going to hell.   Every time I spoke with His Holiness, and we were quite close, he informed me that Leonard Cohen and Steve Lindsey are crazy or insane. 

42. Leonard Cohen is the individual who controlled the work done by his representatives.  That

would include the negotiations and terms of the intellectual property deals.  Cohen demanded complex stock deals.  Leonard Cohen’s artistic endeavors did not prevent him from being fully aware of or involved with his business affairs.  It was my understanding that he has a background in business and law.  Cohen frequently accompanied Kelley to meetings with Sony.  If he knew Kelley was attending a meeting about one of his business matters, he would begin calling incessantly. 

43. I am aware of the fact that Leonard Cohen was on conference calls regarding these deals with

Kelley, Richard Westin, Neal Greenberg, and others. I am the individual who would frequently arrange and place the conference calls.  I would also remain on the line for many calls and take notes for Kelley.  I also frequently sat with Kelley while she was on the phone with Cohen, his representatives, and other parties.  Kelley took shorthand notes of all her calls.  Many of those notes were in files that Cohen and his daughter removed from our offices. 

44. Cohen was an aggressive micro-manager who required, at times, hourly updates on negotiations,

deals, and other matters.  At times, he drove Kelley insane with his relentless demands and inquiries.  It is important to note that Kelley had many other responsibilities and was required to spend countless hours, for years, working on these deals.  It is impossible to explain what a personal manager does but it is extremely time consuming and involves overseeing every single aspect of an artist’s affairs.  Kelley actually archived Leonard Cohen’s body of work.  He  was the last individual to have his watercolor notebook of artwork.  I recall our searching the office well before they parted ways.  Cohen personally confirmed for me that he recalled having this journal at his home and scanning the artwork.  He simply fabricated information he advised the Court that Kelley had in her possession.  Cohen and/or his daughter took all business files, including the corporate, banking, and financial files, and Kelley had her lawyers transmit the corporate books to Cohen’s lawyers.  Cohen and/or his daughter took all files related to royalty statements, business agreements, book and music publishing matters, and the corporate entities.  They also took two tables that Leonard Cohen personally gave Kelley and she was upset that they removed property belonging to her. 

45. If Leonard Cohen had not demanded complex stock deals, Kelley would have received a much

larger commission and there would have been far more interested parties.  I personally heard Leonard Cohen constantly demand stock deals.  His representatives worked directly for him.

46. I distinctly recall Greg McBowman, Cohen’s royalty consultant who also handled audits, flying

into Los Angeles.  Greg and I were quite close.  He and Kelley both advised me that they did not believe Cohen should sell the intellectual property assets.  They, and others, repeatedly advised me that the CAK bond deal was a much better deal.  Cohen personally decided not to pursue the CAK bond deal and instead chose to do these deals with Sony.

47. I was in Kelley’s office when Stuart Bondell of Sony called to offer $8 million for the second

intellectual property deal.  Kelley hung up and phoned Cohen who advised her that he wanted to pursue the deal with Sony.  Cohen was extremely concerned about dropping the CAK deal and pursuing a deal with Sony because he wasn’t convinced Sony would close the deal.  His conditions required Sony to make a non-refundable good faith down payment of $1 million.  Sony agreed and these funds were wired into his personal account.  Cohen’s decided not to pursue a bond securitization deal with CAK that Kelley and his other representatives were negotiating.  Kelley repeatedly advised me that she felt the CAK deal was the better deal because CAK offered to loan or advance Cohen approximately $5.8 million and he had the ability to retain ownership interest in the intellectual property.  CAK filed a lawsuit against Cohen over this situation and ultimately Leonard Cohen decided not to pay Peter Lopez, his transactional attorney in the CAK matter, legal fees due for nearly two years of work.  Peter Lopez had nothing to do with Cohen’s decision to pursue a deal with Sony rather than CAK.  The situation merely seemed to provide Leonard Cohen with an excuse not to pay Peter Lopeze for services rendered.

48. After the Sony deal closed in 2001, Leonard Cohen came into our office and congratulated Kelley

on her hard work and the successful outcome of the negotiations.  He brought flowers for both of us and took us to lunch.  At that time, Cohen discussed his personal expenses with respect to the deal and instructed me to type a list and direct Greenberg to pay these costs from the Traditional Holdings, LLC account.  This list of expenses related to his personal representatives, advisers, and the settlement he arrived at with CAK.  I typed the authorization letter, Cohen reviewed and signed it, and I personally faxed it to Neal Greenberg.  Leonard Cohen was keenly aware of his personal transaction fees.  It is my understanding that Leonard Cohen has now taken the position that he was unaware of his own transaction fees with respect to these deals.  He was extremely aware of the work his representatives were doing and their fees.  I personally recall retainer agreements Cohen signed with Arthur Indursky/Grubman, Indursky firm and Greg McBowman in connection with these deals.

49. Every year when I worked for Kelley, she received a W2 or 1099 from Leonard Cohen. 

Kelley was entitled to 15% of all gross income from all sources.  It is my understanding that Cohen refuses to provide Kelley with a 1099 for the year 2004.  I also understand that Kelley has attempted to address K-1 partnership documents she received from LC Investments, LLC and Traditional Holdings.  She has also repeatedly asked Leonard Cohen to provide the information in his possession needed to prepare and complete a proper accounting.  I was present when Leonard Cohen and his daughter, Lorca Cohen, personally removed business and personal records from our offices.  The banking, accounting, financial, investment, and corporate files, royalty statements, agreements, and other relative information  were in those files.  My daughter was not present when Cohen removed all of his property.  He had become threatening and Kelley decided to look for new office space so as not to be near him.  It is absurd that he has now alleged that she is stalking him or wants to attend one of his concerts.  That is a fantasy on his part.  Since filing this lawsuit, Leonard Cohen and his lawyers have refused to communicate with Kelley over extremely legitimate matters. 

50. I was present when Kelley and Cohen reviewed Richard Westin’s fax of December 4, 2000. 

Leonard Cohen and Kelley were sitting in her office when Westin’s original email was received.  Cohen and Kelley, who were sitting at her office computer, prepared an email addressing Westin’ s suggestions, asking additional questions, and printed out a copy that I faxed to Westin and filed.  I vividly recall this conversation because Cohen was adamant that he did not want Lorca or Adam listed as beneficiaries or involved with any of these structures or deals.

51. Kelley explained to Cohen and me that she was not completely comfortable with the

arrangement that was ultimately recommended.  That arrangement involved Kelley owning 99.5% of Traditional Holdings, LLC and being asked to provide a promissory note in the amount of $245,000 for her ownership interest.  In my presence, she asked Cohen for an Indemnity Agreement.  Cohen instructed me to phone Westin to advise him to prepare the Indemnity Agreement which was then signed by both Cohen and Kelley and notarized.  I made a copy of this agreement and placed it in the Traditional Holdings, LLC corporate file that Cohen ultimately took from our office with other corporate records.  The Annuity Agreement was also placed in this file.  Many of the corporate documents were signed by Leonard Cohen and notarized.  I believe Cohen understands that Kelley does not have the wherewithal financially to defend herself legally.  There are witnesses to everything that has occurred and a tremendous amount of evidence.  It is also my understanding, since the spring of 2005, that Leonard Cohen planned to use restraining orders to undermine Kelley’s credibility and prevent her from serving as a witness against him.  Steve Lindsey used similar tactics against Kelley. 

52. I frequently handled the corporate paperwork that was provided by Richard Westin, and other

Cohen representatives.  I would arrange for notaries and photocopy the documents for Cohen and Kelley.  These documents were always placed on his desk in our offices or faxed to his home, cabin at Mt. Baldy, or wherever he was presently staying.  Copies of everything was placed in the files and corporate books.  The notary, who sometimes came to the office, would explain what Cohen or Kelley were signing. 

53. Richard Westin, Neal Greenberg, and Cohen’s other advisers, continually directed Kelley on how

to handle corporate documents, what should was be executed, who should sign, when it was necessary to have documents notarized, if the documents should be placed in the corporate books or files, or when to simply hold a document until further notice.  We followed these instructions very carefully. 

54. Kelley and I had no involvement with Cohen’s investment, corporate, tax or accounting matters. 

That would include the preparation of his tax returns.  We would simply follow the instructions of Cohen, or Cohen’s lawyers and/or accountants, and provide them with the documents or information they requested. 

55. At some point in early 2002, Sony issued a $7 million 1099 to Cohen.  Kelley asked me to fax it

to Cohen’s accountant, Ken Cleveland.   I recall the drama that broke out among Cohen, Greenberg, Westin, and Cleveland over this 1099.  Richard Westin assured me that Sony mistakenly issued the 1099; Cleveland was extremely upset by the penalties and interest that would have accrued; and Cohen advised me that he phoned and spoke to Cleveland about the situation.  The hysteria surrounding this situation alarmed Kelley.    

56. Another Sony 1099 in the amount of $1 million had similarly caused a tremendous amount of

drama with Cohen and his representatives.  The issues related to IRS matters and these deals became increasingly troubling. 

57. On October 21, 2014, Kelley advised me that she and Cohen’s relationship problems were

irreparable and they would no longer work together.  I recall speaking with Stuart Fried that morning.  Stuart was Cohen’s transactional attorney.  Kelley had left a message explaining that she and Cohen were parting ways.  Earlier that morning, Stuart had called to say Sony/ATV finally put an offer in for the third and final intellectual property deal Cohen demanded.  Stuart Fried appeared shocked by the news and advised me that artists do not want to pay their managers what they are owed. 

58. Sometime shortly after they parted ways, Cohen and Kelley once again meet at Starbucks.  Kelley

was stuck in traffic and running late.  She called to ask me to have one of her employees meet Cohen to let him know she was on her way.  My husband and I agreed to meet Kelley at her home after the meeting.  Kelley was reluctant to meet with Cohen alone but her lawyers assured her that it was fine.  At this meeting, Leonard Cohen informed Kelley that he would give her whatever she wanted but he needed her assistance.  She refused.  Cohen apparently became quite threatening and aggressive with her.  According to what Kelley told me, he demanded that she meet him at his lawyer’s office to sign a settlement agreement without her lawyers present.  When Kelley returned, Cohen phoned and advised her that her lawyers could accompany her to the meeting with his lawyer but they would have to remain silent.  I answered the phone and was present throughout the conversation.  Kelley informed Cohen that she would not meet with him; had no intentions of signing a settlement agreement; demanded that he pay her what he owed her; and advised him to stop threatening her.  It was my understanding, at the time, that Leonard Cohen demanded Kelley’s assistance and sought her testimony against his representatives. 

59.  During this period of time, Leonard Cohen also repeatedly called me and my husband.  He

thanked us for our work and assured my husband that his work had been impeccable.  However, he was upset that Kelley refused to meet with him and asked if there was anything we could do to assist him.  Thereafter, he began threatening Kelley by falsely accusing us of placing his money in off-shore accounts.  My husband and I never misappropriated anything from Leonard Cohen – nor did we place his funds in off-shore accounts.  Cohen also accused my younger daughter and her husband of using his money to start their computer business.  That is blatantly false.  Kelley did not begin harassing Leonard Cohen after they parted ways.  She refused to meet with him or talk to him due to his increasingly aggressive and threatening conduct.  Leonard Cohen is the individual who began harassing my daughter including by involving Steve Lindsey in the situation and concocting a custody matter with him.   

60. At no time did I hear from Leonard Cohen or Kelley that there was an “informant” who met

with Lorca Cohen to advise her that Cohen could not retire.  Nor did I hear from Leonard Cohen or Kelley anything related to her allegedly supporting a “gigolo.”  These accusations are ridiculous.  Leonard Cohen fabricates stories for the news media.  These stories have involved Phil Spector, Janis Joplin, Bay of Pigs, and Yom Kippur War.  Leonard Cohen likes intrigue and, like his idol Garcia Lorca, has attempted to present himself to the world as a revolutionary, field commander, or spy.  He refers to his fans as his constituents.  Having fans would be beneath Leonard Cohen.   

61. I am the individual, at both Stranger Management and Amazing Card Company, who supervised

everyone’s work.  There was not one employee, apart from Kelley, who would have been in a position to advise Leonard Cohen or his daughter that he could not retire.  No one had access to the corporate books, records, financial and bank statements, agreements, and so forth.  And, due to the confidential nature of a great deal of material at our offices, no one was permitted to randomly explore and rifle through files or corporate records.

62. In or around August 2004, Kelley hired an individual to assist with her greeting card company. 

Julie Isenberg was introduced to us by Betsy Superfon.  Superfon and Julie Isenberg’s father had been partners in a phone sex line company.  Julie Isenberg worked for Amazing Card Company for approximately one week.  Her position involved packing orders as Christmas orders were shipped in August.  I directly supervised Isenberg’s work and was present at all times when she would have been in the office.  I recall Isenberg spending most of her time on the phone looking for work.  She was extremely incompetent and unprofessional.  At no time would Julie Isenberg have access to corporate books, records, files, financial information, royalty income, or be in a position to determine corporate ownership interests or decide that Leonard Cohen could not retire.  It is my understanding that Julie Isenberg was the so-called “informant” who advised Lorca Cohen that her father could not retire. 

63. In 2005, Betsy Superfon informed me and Kelley that Julie Isenberg had assaulted her maid, stole

her jewelry and dog, and was last seen stripping and doing drugs in Las Vegas.  Superfon also explained that Julie Isenberg was jealous of Kelley.  Superfon also told me and Kelley that her former partner, Julie’s father, had placed $90 million from their business in Swiss bank accounts.  I never really knew if this was gossip or reality.  I understood that the business had been quite successful and Superfon spent money lavishly and lived in a gorgeous house in Malibu.  My husband and I visited her on numerous occasions and spent one Christmas evening there.  Betsy Superfon may very well have been jealous of Kelley.  Leonard Cohen and Steve Lindsey constantly phoned call and she was the focus of their attention.  I know that Superfon accompanied Kelley when she visited Esther Cohen in Florida during her chemotherapy sessions.  Kelley was quite fond of Esther Cohen and I knew her quite well myself. 

64. I never heard, from Cohen or Kelley, that he discovered she had misappropriated monies or

there were irregularities with his City National Bank account.  I am aware that Leonard Cohen eventually went into City National Bank and falsely accused Kelley of certain things.  I worked for years with Marie DeMirdjian, City National Bank, and would imagine that she was simply impressed with Leonard Cohen’s performance.  It is my understanding that based on gossip and innuendo City National Bank froze and closed Kelley’s personal and business accounts as well as Rutger’s personal account.  Kelley advised me that Leonard Cohen and his lawyer were discussing her City National Bank accounts with Marie DeMirdjian and I suggested that she have her lawyers address this situation in writing.    

65. Throughout the fall of 2004 and winter of 2005, Cohen continued to pressure Kelley into settling

with him.  At some point, he hired former District Attorney Ira Reiner to represent him in private mediations.  He wanted Kelley’s help with those mediations.  I understand that he offered her 50% community property and confirmed that she was entitled to her 15% commission with respect to her services as his personal manager and her 15% ownership interest in all intellectual property.  I also understand that Leonard Cohen offered Kelley 50% community property or palimony and there were discussions about paying her $10,000 walking around money.

66. Kelley was concerned that should she enter into any type of settlement with Cohen, although he

owed her a tremendous amount of money, she would be engaged in an attempt to possibly cover up tax fraud.  Cohen was pressuring her to testify against Neal Greenberg, Richard Westin, and others.  Kelley also feared that he was falsely accusing her colleagues, Greg McBowman and Stuart Fried, of committing fraud.  This profoundly disturbed her.

67. At some point in or around November 2004, we moved our offices to Santa Monica, California. 

Prior to that, Leonard Cohen and his daughter made arrangements to pick up Cohen’s personal and business property from our offices.  I was present when his property was removed and that would include, but is not limited to, all business files, corporate business files, correspondence, bank and investment statements, boxes of archival materials, and other materials.  At no time did either Leonard or Lorca Cohen advise me that any items were missing or had not been returned.  At no time did Kelley take Leonard Cohen’s personal or business property to her home where she also had an office.  I do recall Leonard Cohen removing tables and other property, including framed lithographs, that belonged to Kelley.  She later complained that Cohen had removed property belonging to her and corporations she had an ownership interest in.

68. While this situation was unfolding, Steve Lindsey was becoming increasingly aggressive and

abusive with my daughter and her sons.  He and his girlfriend, Dinah Englund, were expecting a baby and Lindsey was under pressure financially and emotionally.  He has problems controlling himself and Kelley, Rutger, and Ray frequently received the brunt of his anger.  I believe Leonard Cohen understood he could easily work Steve Lindsey up and encourage him to create a custody matter with respect to Ray.  I have watched how Leonard Cohen treated the mother of his own children.   He demnonized her. 

69. It is my understanding that after Kelley and Cohen parted ways, Steve Lindsey began meeting

with Cohen and his lawyer.  I was present on numerous occasions when Lindsey advised Kelley that it was in her best interests to settle with Leonard Cohen.  Lindsey informed us that he met with Cohen and Robert Kory, was shown a manila file that they referred to as evidence, and were threatening to have her jailed.  I asked him what was in the manila file and Steve acknowledged that he had not seen the actual evidence.  I reminded Steve that Kelley owned 15% of all Cohen’s intellectual property and had an ownership interest in numerous corporate entities.  I also told him that I thought he should mind his own business.  I frequently had encounters with Steve Lindsey where I was forced to address his utterly abusive and aggressive conduct towards my daughter and grandsons.  He was also openly hostile with Kelley’s nephew, Gesar Mukpo, who lived with Kelley off and on for approximately 10 years.  Gesar advised me that Jennifer Lindsey wanted to move out of Kelley and Steve’s house because her father was so abusive and Jennifer repeatedly told me horror stories about her father.  I knew all the young people in Kelley’s life and spoke to them extensively.  Chloe Favella, a friend of Rutger’s who worked with us, could not believe how abusive Steve Lindsey was with Kelley, Rutger, Ray, and others. 

70. Steve Lindsey advised Kelley, in my presence, that Leonard Cohen visited his office and

informed him that she had sex with Oliver Stone and Richard Rutowski.  Steve Lindsey was livid and also told Kelley that Cohen personally informed him that she had sex with Cohen.  Kelley was not attracted to Leonard Cohen and continuously complained about his conduct and sexual harassment.  I am familiar with Oliver Stone and Steve Lindsey who were friends of Kelley’s.  I am also my daughter’s confidante.  She never had sex with either of these individuals and it is my unshakeable belief that Leonard Cohen intended to stir up a custody matter to pressure Kelley into cooperating with him.  It is not hard to stir up problems with Steve Lindsey.  I have seen it happen repeatedly.  He is an unstable individual, with a horrendous temper, who was consumed with jealousy with respect to my daughter.  He frequently used their son as a weapon.  It is obscene to think of Leonard Cohen and his lawyer meeting with Steve Lindsey and lying about Kelley and discussing her fictional sex life.  Cohen clearly understood that Lindsey is an extremely jealous man. 

71. These tactics were successful as, in conjunction with a SWAT incident on May 25, 2005, Lindsey

coordinated a custody matter that involved “evidence” submitted by Leonard Cohen, Robert Kory, and Betsy Superfon.  I have reviewed the custody documents with Kelley and found the allegations astounding and overwhelmingly fraudulent and false.  Kelley was a wonderful mother who took great care of her sons.  It is my understanding that evidence exists that Lindsey, Cohen, Kory, and Superfon conspired to have Kelley falsely arrested on May 25, 2005.  I personally believe that Steve Lindsey and Leonard Cohen used the custody matter to crush my daughter.  It also clearly had to do with money.  Following the filing of the custody matter, Kelley was advised by an LAPD Sergeant that she should make a deal with Steve Lindsey.  I was with my daughter almost every day until my husband and I moved in the Spring of 2005.   She was under a tremendous amount of stress, attempting to salvage her greeting card company and sell her home, but Kelley has always worked well under stress and she was very devoted to her sons at this time and cared for them exceedingly well, as she always had.  Although Cohen and Lindsey owed Kelley a tremendous amount of money, they seemed to use the circumstances to pressure her into making deals.    

72. At some point in the winter of 2005, Kelley called to advise me that she was shocked to learn that

Betsy Superfon (without Kelley’s awareness or permission) was attempting to negotiate with Cohen and/or Kory on her behalf.  While Betsy Superfon did not know Cohen, she advised us that in the fall of 2004 he contacted her.  She explained that she was merely attempting to assist Kelley by speaking with Cohen and his lawyer.  When Kelley asked Superfon, in my presence, why she provided Steve Lindsey with a declaration in the custody matter, she advised us that she did not know what she was signing.  She also spoke to me directly and advised me that she felt, if anything were true, Kelley had been too good to her sons.   

73. At one point, Steve Lindsey had his father, Mort Lindsey, speak with Cohen and Robert Kory. 

Mort phoned Kelley and attempted to persuade her to enter into a settlement with Kelley.  She steadfastly refused and advised Mort and Judy Lindsey that Cohen committed criminal tax fraud.  Mort Lindsey was kind enough to recommend a number of accountants and lawyers to Kelley.  I was present when Mort phoned Kelley after speaking with Leonard Cohen and his lawyer.  I advised Mort that the best thing he could do was to explain to his son why he should remove himself from Kelley’s personal business affairs. 

74. In all the years I worked with Kelley, Steve Lindsey had no involvement with her business or

professional affairs.  They separated in 1997 and there was no reason for him to meet with Leonard Cohen concerning Kelley.  I would assume that Lindsey’s motivation involved a financial element.

75. My grandson, Rutger, advised me that immediately following the May 25, 2005 SWAT incident,

Steve Lindsey phoned him and asked him to go in and sign over or transfer my daughter’s house to Leonard Cohen.  Rutger’s father, Douglas Penick, recommended that he consult an attorney about this matter and he ultimately decided not to take Steve Lindsey’s calls. 

76. Steve Lindsey also called to advise us about the SWAT incident.  My husband advised Lindsey to

pay Kelley what he owed her.  Kelley had merely kept her son home from school.  She phoned me during the SWAT incident and explained what was unfolding.  She was extremely alarmed that armed men had placed Rutger in a compromised position and she felt his life was endangered.  Kelley also advised me that no one came to her door and/or explained what was taking place. I advised Kelley to contact an attorney.  Rutger advised me that he told LAPD that he had just been with his mother, she was in the house alone, he had just dropped his brother off with Cloris Leachman, and they simply disregarded what he had to say.  Rutger said that due to Steve Lindsey’s aggressive behavior, his mother did not want him on his property.  She called Rutger and he came home, picked up Ray, and dropped him off at the bottom of the hill.  He also confirmed directly to Steve Lindsey that this was the plan. 

77.   Kelley phoned me from King Drew.  I could not believe what I was hearing.  UCLA was five

minutes from her home and LAPD took her to South Central and evidently questioned her about Phil Spector.  Kelley explained that she had no idea how they knew she and Phil Spector were friends.  I told Kelley to have the doctor pone me if he felt the need to do so.  I immediately assumed that Steve Lindsey and Leonard Cohen were behind this incident.  Rutger told me he saw and heard Steve Lindsey lying to LAPD about his mother.  Although Rutger had been with his mother earlier, had just driven his brother down the street, LAPD chose not to believe what he told them.  I have a very difficult time understanding that situation.  I have reviewed the King Drew file with Kelley and that is not her file.  It is a different Kelly Lynch.  The social security number, date and place of birth, and other information did not relate to my daughter.  Evidently LAPD lied in the report because Rutger told me the female officer asked him two questions:  Are you okay and is your mother on any medication?  Rutger informed me personally that he told them he was okay and his mother was on heart medication.  I began to wonder if Kelley was actually the Martha Mitchell of Los Angeles without the hat. 

78.  Steve Lindsey owed Kelley a tremendous amount of money and had not repaid her for loans he

took or child expenses she advanced on behalf of Ray and Steve’s daughter, Jennifer Lindsey.  I am aware that Steve Lindsey assured Kelley continuously that he would repay her monies loaned to him, 100% of all monies expended on behalf of his daughter, and 50% of all monies expended on behalf of Ray.  It is my understanding that these amounts are still outstanding.  At the time the custody matter was filed, it was my understanding that Lindsey had financial problems. 

79. After Kelley and Cohen parted ways, she repeatedly advised me that he refused to provide her

with documents in his possession that would allow for the preparation of a proper accounting.  As I have stated above, I was present when Leonard Cohen and his daughter, Lorca Cohen, picked up all his files and other property.  As I have explained, this information was in the property they removed from our offices.  That would include records related to the following:  financial, bank, tax, royalty statements, sales figures, agreements, and corporate documentation.   

80. As of the fall of 2004, Leonard Cohen was not broke.  He had received $1 million advance with

respect to the delivery of “Dear Heather.”  Cohen also planned to tour, understood Kelley was pursuing a lucrative lithograph deal for him, intended to submit “Book of Longing” to his publishers, and was well aware of the fact that Kelley and his representatives were in the midst of the third intellectual property deal he demanded.

81. Leonard Cohen, as I’ve stated above, is a shrewd businessman who oversaw every aspect of his

business affairs.  He was extremely controlling with respect to Kelley.  Due to the fact that he was travelling rather extensively, Leonard Cohen personally asked Kelley if she would execute Powers of Attorney which would allow her to act on his behalf in his absence.  I was present for this conversation.  His lawyer prepared the documents.  Cohen was also buying houses for his son and girlfriend and needed Kelley to assist with the closings.  Kelley did not ask to be in control of Cohen’s financial affairs and was not.  She was placed in a position, through these Powers of Attorney and bank signature privileges, to assist Leonard Cohen.  The individual who controlled all of his personal and business affairs was Leonard Cohen.

82. I was present for numerous conversations between Leonard Cohen and Kelley regarding his

loans from Traditional Holdings, LLC.  On at least one occasion, Leonard Cohen personally instructed me to phone Richard Westin to advise him to obtain all information regarding his loans/advances from Neal Greenberg.  Cohen also asked me to advise Westin to prepare any necessary promissory notes or legal documents.  Neal Greenberg is the individual who invested Cohen’s money and authorized the distributions from Traditional Holdings and he is the individual who had this information.  I frequently informed Richard Westin, Neal Greenberg, and others, that Kelley was not their personal assistant and they should contact whatever representative of Cohen’s had the information they needed or wanted conveyed. 

83. Cohen personally asked me to call Richard Westin to ask him if Kelley would be responsible for

any payments with respect to her promissory note (Traditional Holdings) after his death.  Westin advised me that she would not.  I, in turn, conveyed this information to Cohen and Kelley.  At no time was I aware of a trust with respect to either Blue Mist Touring or Traditional Holdings.  I was unaware of any discussions about a trust.  I personally believe this is something Leonard Cohen conjured up together with his fabricated story. 

84. Neal Greenberg is the individual who would have been in charge of loan schedules, profit and

loss statements, and so forth.  He would have been in possession of this information.  Kelley was not responsible for preparing and/or disseminating tax, accounting, financial, investment, or legal documents or forms.  I recall Kelley continually complaining that she found Neal Greenberg’s statements to be incoherent and repeatedly asked him to address things in a manner in which she and Cohen could understand.  She felt he was intentionally obfuscating matters by intentionally complicating them.  I was present numerous times when Kelley complained to Neal Greenberg and asked him to write things in plain English that she and Cohen could understand.  Kelley was also concerned that Greenberg provided Cohen with one statement that listed various accounts.     

85. Leonard Cohen, Neal Greenberg, and Richard Westin continually advised me and Kelley that all

disbursements and expenditures from Traditional Holdings, LLC should be addressed as shareholder loans and required legal documentation.  That is not something Kelley or I would have handled.  Kelley did not prepare legal documents on Cohen’s behalf.  I am aware of the fact that Kelley was to receive $20,000/year, $24,000/year, and $240,000 in distributions from Traditional Holdings.  These monies were addressed in the corporate records and management agreement Richard Westin prepared.  Richard Westin explained to me personally that $44,000 was being distributed so that Kelley could repay her promissory note and $240,000 was being distributed to her yearly for potential taxes or tax consequences.  Westin also advised me personally that Kelley should receive 100% of the profits.  Kelley was unable to obtain profit and loss statements from Neal Greenberg.  I followed up on her requests with Neal Greenberg. 

86. I visited Mt. Baldy on numerous occasions with my daughter and Cohen.  In 1996, I was present

when Leonard Cohen took formal vows to become a monk.  I was frequently in contact with Cohen when he visited Mt. Baldy.  I handled interview requests and frequently scheduled interviews.  Kelley and I assisted Cohen when Armelle Brusq was filming her documentary, in Los Angeles and Mt. Baldy, called Spring of 1996.  I personally visited Leonard Cohen’s cabin which was outfitted with a recording unit, phone, fax, and computer.  

87. Leonard Cohen was not actually in a Buddhist retreat.  It was my understanding that Cohen’s stay

on Mt. Baldy was a working retreat and Cohen explained to me that he was felt he was taking far too many drugs  and drinking heavily and meditation helped him with those issues. 

88. During his Mt. Baldy phase, from 1994 through 1998, Leonard Cohen was frequently in Los

Angeles.  Joshu Sasaski Roshi had a center in Los Angeles and would stay there.  Cohen had a home in Los Angeles.  Kelley and I also assisted two Robert the Fan, two women who released a periodic Leonard Cohen newsletter, and his fan based website hosts.  I also handled the news clippings generated by Cohen’s press clipping service and would keep maintain the notebooks they were stored in.  I was not paid by Leonard Cohen for any of my services while in my daughter’s employ and I did a tremendous amount of work on his behalf.  Leonard Cohen was extremely obsessed with his news coverage, record and book sales and reviews, and continuously provided various fan websites with materials I would mail or fedex on his behalf.

89. Towards the end of his Mt. Baldy phase, Cohen began actively communicating with a fan website

known as the Leonard Cohen files.  He began providing that website with materials he wanted published.  Cohen was frequently in the office reviewing his archival materials that he would have me fax or mail to Jarkko Arjatsalo who ran that site.  Leonard Cohen understands marketing and was well aware that he needed to relate to his fans and engage in some form of promotion with respect to the live albums and studio album he was working on at the time.  I also frequently scheduled studio time over the years.    

90. I initially opened the letters Neal Greenberg sent containing the IRS warnings.  I was present

when Kelley read these letters to Cohen, heard him advise her not to discuss his future income with Greenberg, and heard Kelley advise Cohen that she was concerned about the IRS warnings, Richard Westin, and the outstanding loans or advances.  Cohen assured her that he intended to repay his loans in full with interest and there was no need to be concerned.  I was under the impression that Neal Greenberg sent these letters to cover himself legally and to address serious concerns about the Internal Revenue Service.  I found Greenberg’s conduct increasingly disturbing.  He personally informed me that Leonard Cohen’s loans were dangerous to Traditional Holdings and had to be repaid.  I asked him why such complicated structures were created.  Greenberg advised me that this is what Leonard Cohen wanted.  Cohen demanded stock deals.  I repeatedly heard Kelley, Leonard Cohen’s lawyers, Greg McBowman, Sony, and others, complain about the stock deals he demanded. 

91. As I have stated above, I would sit with Kelley while she worked and, in particular, when she was

on the phone with Cohen and others.  She would frequently ask me to provide her with a file or documents.  This is how we worked.  Cohen would frequently come into the office and sit with me and Kelley before going down the hall to the office she provided him.  I continually heard Leonard Cohen tell my daughter that he would compensate her for his office and other expenses.  I do not believe he ever did. 

92. In the fall of 2004, Kelley and Cohen received a letter from Richard Westin advising them that

the IRS might inquire as to certain corporate tax related matters.  I was present when Kelley phoned Cohen to discuss this letter. 

93. I specifically recall Kelley discussing the Traditional Holdings, LLC management agreement with

Leonard Cohen.  Richard Westin prepared this document.  They reviewed the fact that she was to receive $24,000/year, $20,000/year and $20,000/month.  It was my understanding that these amounts were being provided to Kelley for potential tax liabilities, to repay the promissory note, and in accordance with the corporate books and records.

94. I was present when Kelley and Cohen discussed the repayment of her promissory note and the

profit and loss sharing with respect to this entity.  Leonard Cohen understood that profits and losses would be distributed in accordance with ownership interests.  After Ken Cleveland’s alarm over Sony’s $7 million 1099 to Cohen, Kelley asked Richard Westin to prepare a letter explaining these corporate structures and her role in connection with them.  Westin faxed a letter to our office and I, in turn, distributed copies to Kelley and Cohen.  I recall Kelley becoming upset after learning of things in hindsight that had not been explained to her previously.  Richard Westin assured me that things would smooth out with these complex matters.  Kelley routinely complained that she could not believe how many complicated corporate entities there were and had no idea why anyone would ever create such an unnecessarily complicated scenario.  By 2004, Kelley had no idea where money for Cohen to pay his bills was to come from.  She and I repeatedly asked Cohen, Greenberg, and Westin.  We had no idea what entity or account would pay Cohen’s tax bills.  I personally left messages for all parties and frequiently never heard from Greenberg or Westin.  It was thoroughly frustrating for both of us.  If Cohen’s accountant prepared one of the charitable trust tax returns, Kelley or I would have to call Neal Greenberg and ask them to provide a check from the entity to pay Cleveland.  The amount of work this caused for our office was inconceivable.  Kelley frequently expressed her frustrations with Cohen.  At one point in the summer of 2004 (he had not yet received the advance on “Dear Heather”), Cohen informed us that he was unsatisfied with Neal Greenberg and did not plan on having him invest future income. 

95. In September 2004, after receiving the alarming letter from Richard Westin, Kelley contacted

Betsy Superfon.  Superfon referred Kelley to her accountant, Dale Burgess, and Kelley decided to fire Ken Cleveland and work with Dale Burgess at that time.  He ultimately referred her to a law firm.  At that time, Kelley had me phone Ken Cleveland, who I spoke with directly, to advise him that she would be working with another accountant and would no longer require his services.  Cleveland’s work with Kelley was limited to preparing her tax returns on a yearly basis.  We provided him, Cohen, and other accountants or business managers with whatever information they requested. 

96. Leonard Cohen was extremely supportive of my daughter’s work with respect to the

development of Amazing Card Company, LLC.  He advised her that he would help her in any way possible and even offered to invest in the company.  I was present when Kelley asked Cohen for a personal loan with respect to this company.  He offered to lend her $100,000 and instructed me to type a fax asking Neal Greenberg to make this money available to her.  I typed it and Leonard Cohen personally signed that document.  When Kelley asked Cohen if he would like to handle this as a loan or issue her a 1099, he advised her that it was a gift.  I personally faxed this document to Neal Greenberg.  There were times when Leonard Cohen was quite generous with my daughter.  I do believe that he really loved her and he continuously advised me that he did. 

97. Kelley and I were confused when checks for her would be made payable to Kelley with the

notation f/b/o Leonard Cohen.  When I phoned Tim Barnett in Neal Greenberg’s office, I was advised that this was their inter-office policy.  There was ongoing confusion as to how Kelley should sign documents.  At times she was asked to sign as the corporate owner; at other times she was advised to sign under the Power of Attorney.  Kelley followed the instructions of Leonard Cohen, Neal Greenberg, and Richard Westin.

98. Leonard Cohen had extraordinary expenses for an individual who had not delivered a studio

album since 1993.  The next studio album was delivered sometime in or around August 2004.  He had homes to maintain in Los Angeles, Greece, and Montreal.  He had a number of assistants including, but not limited to, Betsy Perks in Los Angeles and Lee Taylor in Montreal.  He had numerous legal and business advisors.  His household in Greece was cared for by his housekeeper who was also compensated for her services.    Cohen gave the mother of his children substantial monthly gifts.  He loaned many people money.  Cohen personally bought homes for his son and girlfriend and a commercial building for his daughter, Lorca Cohen.  Cohen felt that owning a store might help Lorca Cohen who had been going through a difficult time.  I frequently spoke to Cohen about expenses related to his son and daughter.  Leonard Cohen also paid the mortgage on Lorca Cohen’s Melrose Avenue property and spent quite a lot on furniture purchases from her business.  I recall extraordinary amounts of money being spent to renovate Anjani Thomas’ home and garden.  He also gave extravagant gifts to people.  For example, he bought Jill (Elton John’s manager’s assistant) a $17,000 statue from a Don Henley charitable event and Anjani Thomas an $18,000 baby grand piano.  He frequently instructed me to advise Kelley to have checks or wires sent to various family members and friends.  Leonard Cohen, as I’ve said, can be generous and he was particularly generous with his close friends like Eric Lerner, Mort Rosengarten, and members of the Zen community.  I thought it was very kind of him to provide the funds for his housekeeper and a Zen monk’s children to attend private school.  He gave a great deal of money to various zen centers.  Cohen personally informed me that if he died he wanted to make sure Kelley was properly cared for.  I believe this had something to do with why he didn’t name Lorca and Adam Cohen beneficiaries in connection with the Traditional Holdings dealings.  And, I also believe that he had a difficult time explaining this to Anjani Thomas, who was exceedingly jealous of my daughter from what I could tell, after Kelley and he parted ways.  I have heard that Ken Cleveland informed my daughter that he thought this situation sounded like Enron, could not believe a court would grant Lindsey custody of their child, and felt that Anjani Thomas had a role in what happened to Kelley.  I have watched Anjani Thomas in action.  She spent months convincing Cohen to remove Kelley from his estate and health care planning instruments.  I know that this caused alarm for Lorca Cohen and Esther Cohen and spoke to both of them about Thomas.  They both felt she was using Leonard Cohen for his money and couldn’t believe how fast she was able to convince him to buy her a house, pay for recording sessions, and so forth.  I never trusted her with my daughter for a moment.  She relentlessly badmouthed Leonard Cohen in my presence which I found disturbing given the gifts he was bestowing upon her  By the time Cohen and Kelley parted ways, Anjani Thomas was using Kelley as her personal manager, household assistant, gardener, and slave.  It was outrageous. 

99.  With the proceeds from the sale of Stranger Music, Inc. in 1996, Leonard Cohen donated

$500,000 to the Mt. Baldy Zen Center.  His home in Canada required upkeep and he paid his assistant.  After Cohen was advised to close his Canadian bank accounts, I handled the ordering of Canadian drafts.  That is how Cohen elected to handle his Canadian bills.  He helped support numerous women in his life including Jung Kim, a young woman who became increasingly disturbed with Leonard Cohen.  He advised me that Jung Kim, who visited our offices, was accusing him of stalking her with a check.  Cohen also gave Dominique Issermann a gift of $100,000.  These are gifts that he definitely did not want brought to the attention of his children or Suzanne Elrod.  He was concerned, as he explained to me many times, that Suzanne Elrod and his children would pressure him for more money. 

100. It was my understanding that Leonard Cohen could not live in Canada due to tax and

residence problems.  I recall serious issues arising with respect to his green card.  After abandoning his U.S. green card, he was advised (and I frequently handled these calls and files) that Canada could view him as a resident. Cohen decided not to return to Canada and to reapply for a U.S. green card which he finally received at some point around 1993.  It was my understanding that Kelley’s brother-in-law, Van Penick, advised Cohen that he could have residence and tax issues in Canada and informed him that he should rent out his Canadian residences, give up his temple membership, and close his bank accounts.  At that time, Cohen decided to close his Canadian bank account and instructed me to pay his Canadian bills with drafts ordered through City National Bank.  Cohen’s assistant, Lee Taylor, would fax his Canadian bills to me and Cohen approved all payments.  Cohen chose not to rent his houses or relinquish his temple membership. 

101. I also handled calls and paperwork related to Cohen’s personal legal matters.  In 2003,

problem arose for Cohen with one of his former girlfriends, Ann Diamond.  Ann Diamond heard from a friend of Cohen’s in Montreal, Freda Gutmann, that Lorca Cohen advised her classmates that Leonard Cohen molested her.  She published this information on her website and Leonard Cohen was extremely disturbed.  He demanded that Lorca Cohen, who had been staying in Montreal around that time, return to Los Angeles and it was at this time that he bought the Melrose property.  Kelley contacted Van Penick, and ultimately recommended that he advise Ann Diamond that the situation upset Lorca Cohen tremendously.  Cohen was concerned that these allegations would find their way into the newspapers.  This situation was ultimately resolved but I do recall Leonard Cohen began bad-mouthing Ann Diamond and advising people, including me and Kelley, that Diamond was stalking him.  We never heard from or saw Ann Diamond and felt Cohen went on the offensive due to the public accusations.   

102. It is my understanding that in June 2005, Neal Greenberg filed a lawsuit against Leonard

Cohen and his lawyer for threatening to take or take actions against him and his companies which were unlawful.  Greenberg raised allegations relate to bribery and intimidation of a witness.  That witness was my daughter, Kelley Lynch, and she conveyed much of Cohen and his lawyer’s tactics to me.  The intermittently offered her generous settlements or threatened her.  Steve Lindsey often conveyed these threats to Kelley in the presence of her sons.  I personally witnessed this on more than one occasion.  I also witnessed Steve Lindsey becoming completely aggressive and unhinged with respect to my daughter and grandsons.  I personally advised him that I would contact the police if he continued to threaten, harass, or abuse any of them. 

103. It was my understanding, from what I witnessed and heard, that Cohen was attempting to

recover money from Neal Greenberg and Richard Westin.  Kelley repeatedly advised me that she was concerned that Cohen planned to engage in insurance fraud.  At one point, I was present when Kelley had a conversation with her lawyer wherein she was advised that they spoke to Cohen’s lawyer.  This lawyer, who Kelley was introduced to by Steve Lindsey, was informed by Cohen’s lawyer that if Kelley assisted them, Cohen would take the position that Kelley was used as a pawn.  If Kelley did not assist Cohen, he would take the position that she orchestrated the corporate and tax mess he has found himself in.  Leonard Cohen is the individual who controlled my daughter.  He had an entire team of representatives who worked for him personally.  Kelley did not handle anything having to do with Cohen’s accounting, IRS matters, corporate matters, financial planning or investments, or the preparation of legal or corporate documents.  She most certainly did not orchestrate this nightmare. 

104. I personally scheduled meetings Kelley held with City National Bank and others. 

She was concerned with what she felt were aggressive and reckless investment strategies.

105. At some point in early 2005, Kelley was contacted by Neal Greenberg’s lawyer who was a

student of His Holiness Kusum Lingpa.  I was extremely concerned that this individual was using my daughter and cautioned her about communicating with him.  It is my personal opinion that this individual used my daughter and pretended he was in love with her to obtain information for his client.  I was present for one conversation Kelley had with this man.  She was extremely concerned that Cohen was attempting to engage her in what she felt might be extortion or insurance fraud.  Cohen’s attempts to threaten Kelley continued throughout the spring of 2005.  Cohen appeared to be interested in Kelley’s testimony against Neal Greenberg, Richard Westin, and others.  He made promises to pay her the value of the intellectual property assets and commissions due her if she would assist him in going after these individuals.  She refused.

106. At one point in the spring of 2005, Betsy Superfon stopped by Kelley’s house when I was

visiting.  Yongzin Rinpoche and his wife were also present.  Superfon explained to us that Cohen felt remorseful, terrified, and had informed Superfon that Kelley was the love of his life and she could have whatever she wanted.  Kelley asked Superfon to contact Cohen’s lawyer to ask that they fax through the deal Cohen had in mind.

107. Superfon left Kelley’s house and, while I was present, called to advise her that Cohen’s

lawyer informed her that this was not the type of deal that could be faxed through.  Kelley and Superfon concluded that the deal must be illegal or improper.  Superfon also explained to Kelley that Cohen’s lawyer would like to have a private lunch with the two of them to discuss the proposed deal.  I advised Kelley not to attend any such meeting although Superfon had explained that Cohen would pay Kelley what he owed her and would give her anything.

108. Leonard Cohen and Kelley never had a brief intimate dating relationship; were never in

any type of relationship other than a business relationship and familial type of friendship.  Kelley frequently complained of Cohen’s sexual harassment, unprofessional conduct, and indecent exposure.  It is my understanding that Leonard Cohen has registered a Colorado restraining order as a “domestic violence” order against my daughter.  Kelley and Cohen were never in any type of domestic relationship and there was no domestic violence.  It is my personal opinion that Cohen has attempted to address Kelley’s public allegations of sexual harassment, inappropriate conduct, and indecent exposure – including when Cohen forced her to read business and legal documents to her while he bathed.  Kelley was so disturbed by Cohen’s inappropriate conduct towards her that she advised me that she would no longer meet with him alone.  She was extremely upset when he looked at internet images of people defecating on one another in front of her. 

109. From approximately 1995 until we moved our offices, Kelley’s physical business address

was 1044 S. Keniston Avenue, Los Angeles, California and her business P.O. Box address was 419 N. Larchmont Blvd., Suite 91, Los Angeles, California.  These addresses did not belong to either Leonard Cohen or any corporate entity.  Leonard Cohen advised me and my daughter that he intended to reimburse her for the space he used in our offices.  It was my understanding that following Cohen’s planned tour, he and Kelley intended to hire an accountant to prepare an accounting that would address corporate ownership interests, commissions due her for work she did as his personal manager from 1988, all loans and/or advances each of them had received,  value of her intellectual property assets, and address any monies either of them expended on behalf of one another.  For example, Kelley personally paid for publicists and independent record promoters on behalf of Adam Cohen.  Leonard Cohen assured Kelley that he would reimburse her for those expenses should Adam Cohen not be able to do so himself. 

110. It was always my understanding that Leonard Cohen hired Neal Greenberg, Richard

Westin, and others, to create companies that would reduce Cohen’s tax consequences.  These individuals worked for Leonard Cohen.  They frequently attempted to use my daughter as their personal assistant.  She found this offensive and advised them that she was not their personal messenger boy and they should contact whomever they needed, for whatever they needed, directly.   It is my opinion that both Neal Greenberg and Richard Westin attempted to use Kelley to meet other wealthy people in Los Angeles.  They were interested in investing or working with Betsy Superfon, Ron Burkle, and evidently learned that Kelley carpooled with Susan Disney.  I was frequently present when Richard Westin would phone my daughter at home.  At one point, he decided to visit Los Angeles and Yongzin Rinpoche, who was staying with Kelley advised her to put him back on the plane because as he was a complete “pain in the ass.”  During his visit, Richard Westin made advances towards a friend of Kelley’s who later informed me that she felt completely used by this man.

111. It was my understanding that Cohen would form Traditional Holdings, LLC to use in

connection with the second Sony sale.  Initially, Sony began their due diligence with Blue Mist Touring Company, Inc.  The Grubman firm and Sony were both aware that Leonard Cohen and Kelley both had an ownership interest in Blue Mist and the intellectual property assets.  Eventually, Cohen and his representatives were concerned about certain tax matters related to the use of Blue Mist Touring Company, Inc.  Kelley repeatedly advised me that she felt these deals were unnecessarily complex and the corporate and tax matters inconceivably complicated and incoherent.  She grew increasingly frustrated and suspicious.  At one point, Kelley informed me that, due to the fact she could not get answers from Cohen’s representatives, she intended to contact the Internal Revenue Service directly to ask them to review the corporate structures and deals.  She was also alarmed and the number of IRS inquiries in connection with Cohen related matters and entities.  In fact, she advised me that she planned to ask an IRS agent who found Richard Westin’s conduct evasive to visit our offices and review the files for himself.  At one point, Kelley began joking that she had the FBI on speed dial.  She felt they might want to profile Cohen.  Due to her genuine concerns, Kelley had me make additional copies of all deal related documents for her to keep at home. 

112. At one point, I was present for a conversation where Richard Westin advised Kelley to

rip of Blue Mist corporate assignments.  Kelley hung up the phone and asked me to make copies of the assignments and advised me that she felt she was being asked to do something illegal.  She was compensated with stock in Blue Mist for services she rendered. 

113. It was my understanding that Blue Mist Touring would transfer certain intellectual

property assets to Traditional Holdings in exchange for an annuity obligation to Cohen that would begin in or around January 2012.  Traditional Holdings would then sell the assets it received from Blue Mist to Sony. 

114. I never saw any formal documents transferring, selling, and/or assigning Blue Mist

Touring’s intellectual property assets to Traditional Holdings, LLC.  I was, however, present when Kelley spoke to Richard Westin who advised her that he felt she should rip up the non-revocable assignments to Blue Mist Touring Company, Inc.  When Kelley hung up the phone, she read me her shorthand notes from their conversation and advised me that she felt she was being asked to do something illegal.  Kelley asked me to make copies of the non-revocable assignments and give her the original assignments to take home.  She was completely alarmed by this conversation with Richard Westin.

115. It is my understanding that Blue Mist Touring Company, Inc. never transferred assets to

either LC Investments, LLC or Traditional Holdings, LLC.    

116. Leonard Cohen was explicitly warned that Kelley would have to be in control of

Traditional Holdings, LLC to avoid allegations that he participated in self-dealing.  He understood that this situation place many burdens on Kelley, including tax burdens.  After signing the Indemnity Agreement, Leonard Cohen personally advised me that he was grateful for Kelley’s assistance.  He and I discussed the fact that regardless of ownership interests with respect to Traditional Holdings, LLC he felt completely comfortable because he trusted Kelley and there was an annuity obligation.  At Cohen’s request, I prepared copies of all corporate records for Cohen and placed them in a file which he took home with him.  Those documents included all corporate records (including the Articles of Organization and Operating Agreement); signed and notarized copies of the Annuity Agreement and Kelley’s Indemnity Agreement; notarized copy of Kelley’s Promissory Note with Traditional Holdings; stock units that were issued; the stock ledger; and copies of the faxes or emails between Cohen, Kelley and Richard Westin with respect to the proposed structure, their questions, and Westin’s additional explanations.  Cohen advised me that he needed these documents because he planned to review them with Greenberg and Westin.

117. I was present for conversations Kelley had with Cohen, as well as Greenberg and Westin,

where she was advised that she would receive funds necessary to pay taxes, repay the promissory note, and pay her a salary.  Richard Westin informed me on many occasions, and this was reflected in numerous documents, that Kelley would receive $24,000 and $20,000 per year from Traditional Holdings, LLC.  These two amounts, totaling $44,000, would be used to repay Kelley’s promissory note.  An additional amount of $20,000 per month (which could be paid monthly or yearly) was to be distributed to Kelley to be used for whatever taxes she was advised to pay.  Westin also explained to me that Kelley was entitled to 100% of all profit and loss.  I was present when this issue arose again in or around March 2002 between Cohen, Kelley, Westin, and Greenberg.  Kelley informed me that Westin advised her and Cohen that the profit and losses would be distributed in accordance with their respective ownership interests:  99.5% to Kelley and .5% to Leonard Cohen. 

118. Neal Greenberg and Richard Westin repeatedly advised me that Kelley, as an owner of

Traditional Holdings, LLC had authority to sign off on loans and/or distributions from this entity.  I personally spoke to each of them about this matter due to the fact that I handled the paperwork.  I also reviewed this with Kelley and Cohen. 

119. At Kelley’s direction, I specifically spoke with Richard Westin and Neal Greenberg about

the need for them to document the loans and distributions from Traditional Holdings, LLC.  I was assured that Richard Westin would prepare any and all necessary promissory notes and understood that Neal Greenberg was the individual in possession of these details.

120. Richard Westin and Neal Greenberg both personally advised me that for tax purposes all

distributions from Traditional Holdings, LLC should be characterized as shareholder loans and, if necessary, they would recharacterize them.  It was my understanding that these shareholder loans would be repaid with interest once the third Sony deal closed.  I specifically discussed this matter with Kelley and Cohen.  They both understood that there would be substantial income from the third Sony deal, sales of “Dear Heather,” the lithograph deal Kelley was negotiating, and Cohen’s tour.  Cohen repeatedly admonished Kelley and I not to discuss his future income with Neal Greenberg and did not want him to have information regarding his plans to tour.  He also did not want Sony pressuring him about his plans to tour.

121. Kelley was continuously concerned about the tax consequences with respect to phantom

income being shifted to her and with respect to corporate distributions.  Richard Westin personally assured both of us, on numerous occasions, that the corporate distributions were not taxable and he would provide Kelley with all necessary tax documents.

122. Richard Westin was extremely concerned about Leonard Cohen’s level of borrowing

from Traditional Holdings, LLC.  He expressed concern about potential IRS inquiries.  At one point, Westin faxed through minutes he prepared for Traditional Holdings, LLC.  Those minutes addressed the fact that Cohen’s level of borrowing was excessive and should be discouraged.  All communications from Richard Westin and others were placed on Leonard Cohen’s desk, faxed to him, and I was frequently present when he and Kelley reviewed business and legal matters.  Leonard Cohen was well aware of the fact that his loans or advances from Traditional Holdings, LLC had to be repaid with interest. 

123. Neal Greenberg also continuously expressed concern about Leonard Cohen’s level of

borrowing from Traditional Holdings, LLC and his other retirement accounts.  Greenberg personally advised me that he believed Cohen used these accounts as his personal piggy bank.  When I conveyed this message to Cohen, he was livid that Neal Greenberg would question how he chose to spend his money.

124. In the spring of 2005, Kelley spoke to an IRS agent about her suspicions with respect to

Cohen and numerous entities.  It is my personal belief that Leonard Cohen retaliated against Kelley for refusing to assist him and reporting allegations of tax fraud to IRS.

125. I was present when Kelley’s lawyer advised her that Cohen intended to go on Oprah to

promote his new album and tour.  At that time, he intended to give interviews to reporters in order to blow the whistle on Neal Greenberg and Richard Westin.

126. Cohen continued to pressure Kelley into assisting him in going after Neal Greenberg,

Richard Westin, and other representatives of his.  It was my understanding that Ira Reiner was brought into handle mediations between Leonard and these parties.  Kelley refused to participate.

127. I believe Cohen felt he could coerce Kelley into serving as a witness for him.  Cohen used

the monies he owed her to pressure her into participating in mediations with him.  Due to the fact that she refused to assist him, he withheld monies due her.

128. Leonard Cohen is the individual who intended to capitalize on and benefit from the sale

of intellectual property.  It is my personal opinion, based on conversations with Cohen, that he used aggressive tactics to avoid paying taxes.  I also personally believe that Leonard Cohen cannot reside in Canada due to tax and residence problems.

129. I am aware of the fact that, at various points before filing this lawsuit, Cohen offered

Kelley 50% community property and agreed to pay her the commissions she was due and provide her with compensation that equaled the value of the intellectual property assets she owned.  Steve Lindsey advised Kelley and me that he understood that Cohen and Kory raised the possibility of providing my husband and myself with $2,000/month walking around money.  Kelley was completely confused as to why Cohen would offer her palimony.

130. In or around January 2005, my husband and I babysat Ray while Kelley had dinner with

her lawyers and accountant who had flown in from San Francisco.  When she returned from this meeting she again advised us that Cohen offered her 50% community property and would forgive any and all loans or obligations if she would assist him in going after his representatives.

131. I was present when Betsy Superfon advised Kelley that Cohen felt that Greenberg was a

criminal.  Superfon pleaded with Kelley to cooperate with Cohen for the sake of her heart, health, and children.  She promised Kelley that she could settle this situation for her immediately and informed us that Cohen was trying to get Kelley out of this situation.  Kelley asked Superfon to phone Cohen or his lawyer and ask them to fact through the deal they had in mind.

132. Based on what I witnessed at the time, it was my understanding that Cohen’s conduct

with respect to my daughter grew increasingly aggressive.  One of Neal Greenberg’s lawyers advised Kelley that Cohen planned to crush her, use restraining orders against her, and planned to prevent her from serving as a credible witness with respect to Cohen’s affairs. 

133. Cohen, who appeared to conspire with Steve Lindsey and others, has used vicious tactics

to terrorize, silence, and disparage Kelley.  They also coordinated a custody matter which was clearly meant to pressure Kelley into entering into an agreement with Lindsey and Cohen.

134. I was present when Child Services visited Kelley … case worker advised us that she might

bring charges against Lindsey and would require him to attend anger management classes.  She also advised us that she felt Lindsey was harassing Kelley and he personally had called her (the caseworker) in a rage.  Lindsey advised the case worker that Kelley was a great mother.

135. In the Spring of 2005, Kelley decided to permit Neal Greenberg’s lawyers to review three

huge boxes of evidence.  I helped Kelley review, pack, and ship the boxes to Boies Schiller.  It was my understanding that this law firm advised Kelley that Cohen and Kory were attempting to engage her in criminal conduct.  They advised her to contact Los Angeles District Attorney Brian Bennett and ask him to wire her for any meetings with Cohen and/or Kory.  Brian Bennett was an investigator on the Phil Spector matter.  I was familiar with him because he visited Kelley, advised her that an anonymous tip was made to the DA about her friendship with Phil Spector, and Kelley called me during their meeting.  She asked if I recalled any incidents where Phil Spector held a gun on her.  My husband and I recalled no such incident.

136.                      I worked with my daughter until the Spring of 2005 when my husband and I moved to

Texas.  I reviewed many documents, emails, and am familiar with this situation.  I am aware of the fact that Leonard Cohen attempted to pressure Kelley into a deal with her and wanted her to testify against his advisors.  He used financial tactics and the custody matter to coerce her.

137.                      Kelley’s phone was shut off in the summer of 2005.  Paulette Brandt would contact me

from time to time to let me know how Kelley was.  Paulette and I discussed the fact that Kelley was wearing her hair very short and dark brown.  She thought Kelley looked darling.  Kelley and I previously had our hair done by Mario Lara.  Obviously, as Kelley could not afford to pay her phone bill, she was unable to hire a hair dresser or even pay for a cab to attend a hearing had she been aware of any.  I never heard of Robert Kory or Michelle Rice in all the years I worked with Kelley and Leonard Cohen.  I would assume their motives for relentlessly targeting my daughter with Cohen are financial.  I understand that Robert Kory has now replaced Kelley as Cohen’s manager.

138.                      I understand that Leonard Cohen has alleged that Kelley bought her home with his

money.  Kelley worked for Adam Cohen as well.  The year she bought her home, she made substantial fees for deals she did with respect to Adam Cohen’s recording and publishing.  Kelley also had a retirement account that she closed in order to purchase this house.  Steve Lindsey told me that Leonard Cohen advised him that Kelley also bought Yongzin Rinpoche’s house for him.  Kelley did not buy Yongzin Rinpoche’s house and he personally confirmed this for me.  Kelley has been victimized by this pattern of relentless lying and intentional rumor mongering.  That is precisely how Leonard Cohen operates. 

139. Cohen is a shrewd manipulator and understands the use of propaganda with the news

media.  He made false, disparaging, and defamatory remarks about my daughter that have been repeated ad nauseum in the media.  It is my personal belief that Cohen, who was in the midst of a European tour in August 2008, flew into Boulder, Colorado to obtain a restraining order against Kelley due to the fact that she was in touch with journalists, posted factual refutations to his slanderous statements online, and due to the fact that in July 2008 Ann Diamond (an old friend of Cohen’s) wrote an article she planned to present to Rolling Stone about the situation between Cohen and Kelley.  Diamond posted this article online.

140. Leonard Cohen has caused substantial damage to my daughter.  He has created economic

hardships for her and damaged her reputation. 

141. I am extremely concerned that Leonard Cohen will retaliate against me for providing this

declaration.  My daughter has been relentlessly slandered by Leonard Cohen.  It is my opinion that he set out to undermine her credibility and destroy her reputation.  I am aware that both of  my daughters, grandsons, Kelley’s friends, and others have been relentlessly targeted and harassed by strangers who include at least one of Leonard Cohen’s fans.  Paulette Brandt has been relentlessly targeted and expressed her concern to me when she received a telephonic death threat. Kelley has gone to LAPD, FBI, and other law enforcement agencies with respect to these threats.  I have personally advised her to document everything for IRS, FBI, and others.  I was present in 2005 when His Holiness Kusum Lingpa advised my daughter to begin documenting everything in emails and instructed her to copy in witnesses.  I thought this was a very intelligent piece of advice.  It is my understanding that Kelley’s emails have disturbed Leonard Cohen.  It is unfortunate that his own conduct has not.  I also understand that Kelley’s prosecutor, throughout her 2012 trial, lied relentlessly about my daughter.  It is hard not to view Los Angeles as entirely corrupt.  My father was a Magistrate, who frequently worked with the Police Chief and District Attorney (who were frequently guests in our home), handled subpoenas and other matters, and I have never seen or heard of anything as insane as this situation in my entire life.  And that includes judges lying publicly about my daughter and treating her with disdain and aggression.  This is completely unprofessional and unacceptable judicial conduct.  I also understand that members of the City Attorney’s office retaliated against my daughter.  She and I reviewed many documents together  I have come to the conclusion that I am very relieved I no longer live in Los Angeles where people have such jaded personalities and celebrity adoration is rampant.  After Kelley read me the emails where the City Attorney of Los Angeles actively encouraged someone engaged in criminal conduct with respect to my family to continue harassing Kelley and instructed that individual to convey official messages from their office to her, I assured Kelley that there is a reason why people view Los Angeles as thoroughly corrupt.  It is my personal belief that, after lying about Kelley throughout her 2012 trial, and with the full understanding that Kelley asked the IRS and FBI to investigate the matter, that her prosecutor and others retaliated against my daughter.  I do hope the IRS and FBI investigates this situation thoroughly.  I also happen to believe that Kelley was targeted due to her friendship with Phil Spector and her belief that Mr. Spector is innocent.  Paulette Brandt has also assured me that she feels Mr. Spector is innocent and both Kelley and Paulette have constantly told me that they have never seen Phil Spector with a gun and he has been rendered unrecognizable.  I would assume that is one of the reasons that the District Attorney of Los Angeles joined forces with Leonard Cohen in targeting Kelley.  Leonard Cohen’s extremely embellished gun stories about Phil Spector probably caught the attention of the District Attorney.  This might explain why, after Kelley filed a complaint with their Major Fraud Unit, the DA’s office began threatening her and ultimately refused to prosecute Leonard Cohen for theft.  That, of course, is simply my personal opinion.  I also understand that Los Angeles hasn’t nailed a celebrity since Fatty Arbuckle. 

142.                      On a final note, I would like tos ay that I encouraged my daughter to phone the FBI

every time she was threatened by the District Attorney or law enforcement.  I understand that Yongzin Rinpoche has also advised Kelley to report the activity with respect to the individuals targeting her, my grandsons, younger daughter, and Paulette, to FBI and other law enforcement agencies.  It seems self-evident that the parties that are falsely accusing Kelley of many things are the parties with motive.  I would like to point out to this Court that I personally spoke with His Holiness Kusum Lingpa who told me he has never experienced anything like Kelley’s SWAT incident in Tibet.  I am also aware that His Holiness Thinley Norbu, who was asked to protect Kelley and her sons, was concerned about her welfare.  I can understand why.  I know I am.  She is dealing with powerful foes, who appear to be politically connected, may be members of law enforcement, and do not have my daughter’s best interests at heart.  I know His Holiness Sharmapa advised Kelley, as early as 2005, that he believed she was the victim of corrupt politicians and law enforcement.  As corruption is ancient, I believe His Holiness Sharmapa understood precisely what he was addressing with my daughter.  I also understand that Sharmapa himself has been personally slandered over this situation with my daughter.  I feel she is in excellent company.  Thank you for taking the time to listen to my thoughts and experiences with respect to this situation.  I will say this – any judge who gave custody of my grandson to his father, or believes Leonard Cohen, should immediately seek psychiatric care.  It is my understanding that Judge Vanderet was disturbed that Kelley has no faith in the justice system.  I found that deeply disturbing as there does not appear to be a functioning justice system at LA Superior Court.  I understand that Judge Vanderet was present when Leonard Cohen confessed to committing perjury on the witness stand and did nothing.  I think that sums things up.

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 23rd day of December, 20l3 at __________________, Texas.

                                                                        _______________________________________

                                                                        Joan Marie Lynch