From: Kelley
Lynch <kelley.lynch.2010@gmail.com>
Date: Wed, May 27, 2015 at 7:49 PM
Subject: Fwd: Cohen v Lynch – BC 338322 – Filed and Conformed Documents
To: "*irs. commissioner" <*IRS.Commissioner@irs.gov>, Washington Field <washington.field@ic.fbi.gov>,": Division, Criminal" <Criminal.Division@usdoj.gov>, "Doug.Davis" <Doug.Davis@ftb.ca.gov>, Dennis <Dennis@riordan-horgan.com>, MollyHale <MollyHale@ucia.gov>, nsapao <nsapao@nsa.gov>, fsb <fsb@fsb.ru>, rbyucaipa <rbyucaipa@yahoo.com>, khuvane <khuvane@caa.com>, blourd <blourd@caa.com>, Robert MacMillan <robert.macmillan@gmail.com>, a <anderson.cooper@cnn.com>, wennermedia <wennermedia@gmail.com>, Mick Brown <mick.brown@telegraph.co.uk>, "glenn.greenwald" <glenn.greenwald@firstlook.org>, lrohter <lrohter@nytimes.com>, Harriet Ryan <harriet.ryan@latimes.com>, "hailey.branson" <hailey.branson@latimes.com>, "stan.garnett" <stan.garnett@gmail.com>, "USLawEnforcement@google.com" <USLawEnforcement@google.com>, Feedback <feedback@calbar.ca.gov>, mike.feuer@lacity.org, "mayor.garcetti" <mayor.garcetti@lacity.org>, OPLA-PD-LOS-OCC@ice.dhs.gov, "Kelly.Sopko" <Kelly.Sopko@tigta.treas.gov>, sylvie@sylviesimmons.com, mrice@koryrice.com, dbergman@bergman-law.com, ted@tedmcdonnell.com
Date: Wed, May 27, 2015 at 7:49 PM
Subject: Fwd: Cohen v Lynch – BC 338322 – Filed and Conformed Documents
To: "*irs. commissioner" <*IRS.Commissioner@irs.gov>, Washington Field <washington.field@ic.fbi.gov>,": Division, Criminal" <Criminal.Division@usdoj.gov>, "Doug.Davis" <Doug.Davis@ftb.ca.gov>, Dennis <Dennis@riordan-horgan.com>, MollyHale <MollyHale@ucia.gov>, nsapao <nsapao@nsa.gov>, fsb <fsb@fsb.ru>, rbyucaipa <rbyucaipa@yahoo.com>, khuvane <khuvane@caa.com>, blourd <blourd@caa.com>, Robert MacMillan <robert.macmillan@gmail.com>, a <anderson.cooper@cnn.com>, wennermedia <wennermedia@gmail.com>, Mick Brown <mick.brown@telegraph.co.uk>, "glenn.greenwald" <glenn.greenwald@firstlook.org>, lrohter <lrohter@nytimes.com>, Harriet Ryan <harriet.ryan@latimes.com>, "hailey.branson" <hailey.branson@latimes.com>, "stan.garnett" <stan.garnett@gmail.com>, "USLawEnforcement@google.com" <USLawEnforcement@google.com>, Feedback <feedback@calbar.ca.gov>, mike.feuer@lacity.org, "mayor.garcetti" <mayor.garcetti@lacity.org>, OPLA-PD-LOS-OCC@ice.dhs.gov, "Kelly.Sopko" <Kelly.Sopko@tigta.treas.gov>, sylvie@sylviesimmons.com, mrice@koryrice.com, dbergman@bergman-law.com, ted@tedmcdonnell.com
Michelle Rice and
Daniel Bergman,
I am in receipt of
these documents sent to my alternate email account. That account was
created due to Stephen Gianelli and Susanne Walsh's ongoing criminal harassment
with respect to IRS, Leonard Cohen, and Phil Spector matters. Also,
Karina Von Watteville now. She called Robert Kory after receiving
Paulette Brandt's rent demand letter.
This is the
substitution of attorney I received. Daniel Bergman's name is not on this
but his name is on the legal documents. I have never heard of such a
situation in my life. Would you please explain this to me and explain how
Judge Hess' order was modified? Is there a document I have not been
served?
You are now in receipt
of all evidence related to tax matters. I have the federal tax returns
for Traditional Holdings, LLC, am listed as a partner, did not prepare them,
K-1s were transmitted to IRS, and I paid taxes. The notice from IRS to my
former address (which was rented under my name because it was my apartment on
75th Street) has my name on it. There is no attorney/client privilege.
That letter relates to Leonard Cohen's numerous social security numbers.
I see you would like the file sealed. I have presented all of this
evidence to IRS, FBI, DOJ, and others.
I am enclosing the
document Index I provided the Court with my Motion for Terminating Sanctions.
Which documents do you believe have attorney/client privilege and belong
to Leonard Cohen.
What signatures on
what declarations are fraudulent? Paulette Brandt signed mine and was
authorized to sign my mother's. My mother's declaration states that and I
also read the declaration to her in its entirety. Other people were
present. Is it Rutger's declaration? Palden Ronge's declaration?
Dan Meade's declaration? Or my own declaration? Please
clarify. The burden is on you to prove that allegation.
I refuse to play games
with Court orders or service issues. Also, attorneys of record.
Daniel Bergman is not an attorney of record per the Substitution document
so I do not understand why he is on these legal documents. He was in
willful violation of Judge Karlan's order to communicate with me. His
client was in violation of the court order to have my son phone me - until he
was 18. That's an extraordinary contempt of court issue. Is Cohen
now paying Lindsey's legal fees by paying for Daniel Bergman? I would like
a clarification as to why Bergman is on these documents. I previously
filed State Bar Complaints about him. I have them in my possession.
I have asked for
clarification of the default judgment amount. You have one amount here
and Gianelli, who appears to be an unofficial member of Cohen's legal defense
team, has publicly stated - in a slanderous blog and elsewhere - that the
judgment amount is $13.8 million. Which is it? That seems like a
reasonable request.
There is nothing wrong
with my Press Release. I realize Leonard Cohen has attempted to control
the news media and moved offensively with his interview with Brian Johnson -
after Greenberg sued him. Did Cohen also provide MacLean's with my
photograph? The two harrowing incidents never happened. Ted has his
facts straight and reviewed my blog and questioned me about it. I see
that Cohen and Kory/Rice participated in that interview.
I would appreciate
your response about Daniel Bergman. The address the Court has re. my
email account is kelley.lynch.2010@gmail.com and
the documents should be served there - per Court Order.
I will serve you,
Michelle Rice, with the motion to vacate the fraud domestic violence order.
I will let you know
if, per your demands, I decide to withdraw my Motion for Terminating Sanctions.
I intend to call my
book TACTICS because that's all I see on Leonard Cohen's part. The
conduct of the news media, Sylvie Simmons, Ted McDonnell, and others is
unconscionable. The ongoing harassment of nearly every witness who has
provided me with a declaration (including Paulette Brandt, Phil Spector's
former girlfriend and assistant) is outrageous. The targeting of my sons
is and was as well.
Kelley Lynch
MOTION
FOR TERMINATING SANCTIONS
DOCUMENT
INDEX
17
March 2015
Notice of Motion
Motion & Memorandum of Points & Authorities
Proposed Order
MOTION
EXHIBITS
Exhibit
1: Defendant Kelley Lynch’s
Proposed Answer to Complaint
Exhibit
2: Natural Wealth Lawsuit –
Kelley Lynch’s Summary of Factual Allegations
&
Statements. Natural Wealth Real Estate, Inc., et al. v. Leonard
Cohen, et al.
Case No. Case 1:05-cv-01233-LTB
Exhibit 3: Kelley
Lynch’s Summary of Fraudulent Misrepresentations in Plaintiff’s
Complaint. Case
No. BC
338322.
Exhibit
4: Declaration of Kelley Lynch
Exhibit
5: Declaration of Joan Marie
Lynch
Exhibit
6: Declaration of John Rutger
Penick
Exhibit
7: Declaration of Paulette
Brandt
Exhibit
8: Declaration of Clea Surkhang
Exhibit
9: Declaration of Palden Ronge
Exhibit 10: Declaration of
Daniel J. Meade
Exhibit 11: Clarification of
Ambiguities in Default Judgment filed May 15, 2006
DECLARATION
OF KELLEY LYNCH
EXHIBITS
EXHIBITS
Exhibit A: Robert Hilburn Article; photo of Cohen
working at Mt. Baldy.
Exhibit B: Boulder Combined Court email and attached
evidence; Kory & Rice domestic violence related orders.
Exhibit C: Emails with court reporters re. March 23,
2012 hearing transcript.
Exhibit C-1: MacLean’s article. August 22,
2005.
Exhibit D: Phil Spector Motion in Limine (Excerpted
pages – Leonard Cohen gun incident); Mick Brown emails.
Exhibit E: Trial Transcript (RT 308-309).
Exhibit F: Transcript March 23, Hearing.
Exhibit G: Marty Machat letter dated November 25,
1990; Stranger Music, Inc. – Spreadsheet.
Exhibit H: Berger, Berger & Beal letter to Marty
Machat dated January 5, 1972.
Exhibit I: Email to Steven Machat dated March 2, 2015
confirming book excerpts.
Exhibit J: Transcript of Steven Machat & Kelley
Lynch conversation.
Exhibit K: Elmer Fox, Westheimer & Co. Tax
Planning Memo for Leonard Cohen dated August 22, 1977.
Exhibit L: IRS Notice dated September 12,
1988. [Confusion re. alternate SSN & IRS account]
Exhibit M: Van Penick’s letter to Kelley Lynch dated
October 26, 1988.
Exhibit N: LC letter to Dominque Issermann dated
December 7, 1989 (off-shore account).
Exhibit O: Jonas Herbsman letter to Herschel Weinberg
dated January 8, 1990.
Exhibit P: SOCAN Agreement (with Leonard Cohen).
Exhibit Q: Leonard Cohen Productions, Inc.
Certificate of Amendment of Certificate of Formation (changed name to BMT)
dated March 11, 1993; Articles of Incorporation of Leonard Cohen Productions,
Ltd., Nevada; Statement and Designation by foreign corporation.
Exhibit R: Kelley Lynch fax to Richard Feldstein
dated December 7, 1993.
Exhibit S: Ed Dean letter to LC and KL dated November
15, 1996.
Exhibit S-1: Richard Westin letter to Kelley Lynch dated
February 5, 1998 (Blue Mist).
Exhibit T: Neal Greenberg’s fax to Cohen’s
transaction attorney, Jonas Herbsman February 10, 1998.
Exhibit U: Richard Westin letter to Kelley Lynch
dated June 1, 1998; Minutes of a Special Meeting of the Board of Directors of
Blue Mist Corporation; Trial Transcript (page 279-293).
Exhibit V: Cohen’s Opposition to CAK’s Motion for an
Order of Attachment dated August 30, 2000.
Exhibit W: Leonard Cohen’s Declaration dated August
30, 2000[CAK litigation, Case No. 00 Civ. 1068 (DAB), United States District
Court, Southern District of New York].
Exhibit X: Ken Cleveland fax to Kelley Lynch dated
June 24, 1999; Leonard Cohen POA to IRS; Leonard Cohen letter to Mt. Baldy Zen
Center dated November 1, 1996.
Exhibit Y: Ken Cleveland fax to Kelley Lynch dated
July 22, 1999.
Exhibit Z: Reeve Chudd letter to Kelley Lynch dated
September 8, 1999.
Exhibit AA: LC Investments, LLC Certificate of
Formation dated October 19, 1999; Operating Agreement dated August 21, 2000.
Exhibit BB: Leonard Cohen’s email (baldymonk@aol.com) dated
May 19, 2000 to Kelley Lynch (tsimar@aol.com).
Exhibit CC: Richard Westin Memorandum dated May 23,
2000.
Exhibit DD: BMT letter to IRS re. 341(f) election.
Exhibits EE: BMT 1999 and 2000 federal tax return.
Exhibit FF: Cohen signed Assignment (signature page
only) dated September 15, 2000.
Exhibit GG: Richard Westin’s September 16, 2000
letter to Kelley Lynch.
Exhibit HH: LASD Inventory dated October 18 & 24,
2005.
Exhibit II: May 21, 1994 letter to Kelley Lynch from
Tom Robbins.
Exhibit JJ: Don Friedman’s letter to Stuart Bondell,
Sony, dated September 19, 2000.
Exhibits KK: Westin fax to KL and Greg McBowman dated
September 20, 2000.
Exhibit KK-1: Fax from Richard Westin to Cohen and me
dated October 10, 2000.
Exhibit LL: Richard Westin Proposal to Leonard Cohen
dated November 19, 2000.
Exhibit MM: Richard Westin Proposal to Kelley Lynch
and Leonard Cohen dated December 4, 2000.
Exhibit NN: Leonard Cohen letter to Westin dated
December 7, 2000 (wrapping Greenberg in A/C privilege).
Exhibit OO: Annuity Agreement dated December 7, 2000.
Exhibit PP: Kelley Lynch/TH Promissory Note;
Corporate Minutes dated December 21, 2000.
Exhibit QQ: Traditional Holdings Formation documents;
Lynch & Cohen Powers of Attorney to Westin re. TH; State of Kentucky Email;
TH – 2001, 2002, 2003 Annual Reports; Application for Employer ID – prepared by
Westin who signed Kelley Lynch’s name.
Exhibit RR: Traditional Holdings Stock Certificates
No. 1, 2, 3; Stock Ledger.
Exhibit SS: CAK Settlement Agreement dated December
7, 2000.
Exhibit TT: KL Indemnity Agreement dated January 8,
2001.
Exhibit UU: IRS Notice: August 13, 2001 -
$1 million prepayment TH deal.
Exhibit VV: Grubman, Indursky & Schindler letter
dated April 18, 2001 to Cohen and TH.
Exhibit WW: Trial Transcript (pages 285-288)
Exhibit XX: Lynch & Westin emails (cc: Cohen)
dated February 11, 2002.
Exhibit YY: Richard Westin letter dated March 6,
2002.
Exhibit AAA: David Woltz, IRS Office of Chief
Counsel, letter to Richard Westin dated October 8, 2002.
Exhibit BBB: State of Kentucky Schedule K-1 for Lynch
& Cohen – 2003.
Exhibit CCC: Neal Greenberg IRS Danger Warning
letters dated January 16, 2004 and June 25, 2014.
Exhibit DDD: Westin emails re. Old Ideas, LLC; Dear
Heather liner notes – publishing Old Ideas, LLC.
Exhibit FFF: KL email to Leonard Cohen with forwards
of emails to Stuart Bondell (Sony International), Ian MacKay (Sony Canada), and
Denise Donlon (Sony Canada) dated July 22, 2004.
Exhibit GGG: Kelley Lynch (tsimar) email to Leonard
Cohen (baldymonk) dated September 16, 2004 [Commission – 1099 information].
Exhibit HHH: Diane Baxa, City National Bank, email to
Kelley Lynch dated March 29, 2013.
Exhibit III: Trial Transcript (pages 301-303; 319;
290-293)
Exhibit JJJ: Richard Westin email to Kelley Lynch
dated September 24, 2004.
Exhibit KKK: Westin emails to Lynch dated September
20, 2004 (LCI “Office”)
Exhibit LLL: Westin letters to State of Kentucky;
Lynch and Cohen) dated October 6, 2004.
Exhibit: LLL-1: 2001, 2001, and 2003 Traditional
Holdings, LLC tax returns.
Exhibit MMM: DiMascio letter to Robert Kory dated
November 13, 2004 (CNB account freeze).
Exhibit NNN: USPS Mail Fraud Notice &
Confirmation No.OR18421598.
Exhibit OOO: Kelley Lynch email to DiMascio &
Berardo dated January 5, 2005 (accounting fraud re. expense ledger).
Exhibit PPP: DiMascio &Berardo letter to Kelley
Lynch dated February 7, 2005.
Exhibit QQQ: Trial Transcripts (pages
351-358) – Cohen & Rice testimony.
Exhibit RRR: Kory letter to DiMascio dated February
11, 2005 (Traditional Holdings, LLC “problematic” loans to Leonard Cohen).
Exhibit SSS: Steve Lindsey email to Kelley Lynch
dated May 2, 2005.
Exhibit TTT: Ann Diamond (draft article for Rolling Stone).
Exhibit UUU: King Drew May 225, 2005 fraudulent
report.
Exhibit VVV: Trial Transcript (pages 293-297)
Exhibit WWW: KL email to Cohen & Kory dated July
30, 2004 & August 3, 2004 (advising them that I have reported the
allegations that Cohen committed criminal tax fraud).
Exhibit XXX: Kelley Lynch State Bar Complaints re.
Cooley & Lindsey’s custody lawyers dated February 17, 2007.
Exhibit YYY: State Bar Letter re. Cooley dated
February 28, 2007.
Exhibit ZZZ: Judge Lewis Babock’s Order dated
September 5, 2005; Trial Transcript (pages 355 …)
Exhibit AAAA: IRS Binder Index (April 9, 2012 Trial
Evidence).
Exhibit BBBB: LAPD Report (emails are generally requests
for “tax” information.)
Exhibit CCCC : Trial Transcript (RT 40).
Exhibit DDDD: Trial Transcript (RT 56-57).
Exhibit EEEE: Bail Hearing Transcript (RT 6 – DA
Investigator).
Exhibit FFFF: (April 18, 2011 email testimony - RT 160-161; 266)
Exhibit GGGG: Trial Transcript (Spector &
Cooley: RT 40, 60-61, 56-57, 157-159, 305, 265-266); Mick Brown
emails.
Exhibit GGGG-1: (SSN & Driver’s
License: RT 301-303, 319)
Exhibit HHHH: Schedules of Perjury – Declarations
Leonard Cohen, Michelle Rice, Robert Kory, and
Kevin Prins; Misrepresentatives in Declaration of Scott
Edelman.
Exhibit IIII: Cohen Affidavit - Natural Wealth
(Complaint attached as Exhibit “A” to Tactical Allocation’s Ex Parte
Application in Intervention for Order Protecting & Preserving Evidence
Related Case No. BC341220).
Proof of Service
Filed concurrently: Request for Judicial Notice
---------- Forwarded
message ----------
From: Lauren W. <lwilhite@koryrice.com>
Date: Wed, May 27, 2015 at 3:36 PM
Subject: Cohen v Lynch – BC 338322
To: "Kelley.Lynch.2013@gmail.com" <Kelley.Lynch.2013@gmail.com>
From: Lauren W. <lwilhite@koryrice.com>
Date: Wed, May 27, 2015 at 3:36 PM
Subject: Cohen v Lynch – BC 338322
To: "Kelley.Lynch.2013@gmail.com" <Kelley.Lynch.2013@gmail.com>
Dear Ms. Lynch:
Ms. Rice asked that I
send you the attached Notice of Substitution of Attorney that I mailed to you
on May 21, 2015, and that we filed with the Court on that same day.
Kind regards,
Lauren Wilhite
Kory & Rice, LLP
9300 Wilshire Blvd.,
Suite 200
Beverly HIlls, CA 90212
Tel: 310-285-1630
Fax: 310-278-7641
NOTICE: This email is
confidential and may be legally privileged. It is intended solely for the
addressee. If you have received this email in error, please destroy this
message immediately along with all attachments, if any, and please report the
receipt of this message to the sender at the address listed above. Thank you
for your cooperation.
---------- Forwarded
message ----------
From: Lauren W. <lwilhite@koryrice.com>
Date: Wed, May 27, 2015 at 3:37 PM
Subject: Cohen v Lynch – BC 338322 – Filed and Conformed Documents
To: "Kelley.Lynch.2013@gmail.com" <Kelley.Lynch.2013@gmail.com>
From: Lauren W. <lwilhite@koryrice.com>
Date: Wed, May 27, 2015 at 3:37 PM
Subject: Cohen v Lynch – BC 338322 – Filed and Conformed Documents
To: "Kelley.Lynch.2013@gmail.com" <Kelley.Lynch.2013@gmail.com>
Dear Ms. Lynch:
Ms. Rice asked that I
send you the attached copies of the five conformed documents that were filed
with the Court in the above matter yesterday.
Kind regards,
Lauren Wilhite
Kory & Rice, LLP
9300 Wilshire Blvd., Suite 200
Beverly HIlls, CA 90212
NOTICE: This email is confidential and may be
legally privileged. It is intended solely for the addressee. If you have
received this email in error, please destroy this message immediately along
with all attachments, if any, and please report the receipt of this message to
the sender at the address listed above. Thank you for your cooperation.