DECLARATION OF PAULETTE BRANDT
I, Paulette Brandt, declare:
1.
I am a citizen of the United
States who currently resides in Los Angeles, California. I am a
close friend of defendant, Kelley Ann Lynch. I am over the age of 18 years. I have personal knowledge of the facts contained in this
declaration and if called upon to testify I could and would testify competently
as to the truth of the facts stated herein.
2.
I would like to address why, in a prior
declaration, I confirmed that Kelley and I kept in touch
in the summer
and fall of 2005. Prior to her phones
being shut down, Kelley and I stayed in touch by phone. Thereafter, I would drop by and visit her
primarily on Wednesday mornings throughout the summer and fall of 2005. August 24, 2005 happened to fall on a
Wednesday. I would frequently arrive
quite early in the morning. I never once
saw Kelley fail to answer her door or behave in any manner that would suggest
she attempted to evade service. It seems
to me that certain parties feel fairly jaded when speaking about what Kelley
was dealing with throughout this period of time. She could not afford to buy food for her son,
herself, or her animals. I have always
assisted people when they fall upon hard times and Kelley is no exception. We are also quite close friends. I brought items that she needed, am a known
animal lover, picked up dog and bird food, and also brought hygiene items. I thought it might cheer Kelley up if I
helped her color her hair. She was
obviously no longer able to afford her former hairdresser, Mario Lara. Throughout the summer of 2005, I brought very
dark, nearly black dye and helped Kelley color her hair. I would also help cut it. She wore it quite short at that period of
time. At some point, I personally felt
the dark hair made Kelley look harsh and commented on this. I only recall that some time after Labor Day
2005, I began bringing blonde dye and this changed Kelley’s looks
immensely. In fact, during the period of
time she has stayed with me, I have bought her both dark brown and blonde dye
so this is not a unique situation for Kelley.
She frequently changes her hair color and one day might have black hair
and the next day it is platinum.
3.
Kelley and her mother, Joan Lynch, spent a great
deal of time in November and December
reviewing
legal documents. Kelley took shorthand
notes of Joan’s comments and prepared a draft declaration for her mother to
review. Joan confirmed for Kelley that
the declaration represented what she wanted to include and the content of that
document was based entirely on her comments.
Kelley mailed the declaration to her mother who confirmed receiving it
and told both of us she was mailing it back as soon as possible. She was concerned there might be a delay over
the Christmas holidays. I know Kelley’s
mother was very concerned about her at the time. She was facing two hearings in two matters
related to Leonard Cohen. I read Joan’s
entire declaration to her and she, based on her concerns about the holiday
mails, authorized me to conform her signature on the document. We agreed that she was sending the original
signed document which would be presented to the Court. However, on December 26, 2014, Joan Lynch had
a stroke and lost a great deal of her memory.
My own mother, a woman who is older than Joan, has very severe memory
problems so I am familiar with that issue.
While I frequently spoke to or said hello to Joan prior to her stroke,
she usually sounded in full possession of her faculties. I under that, as of this time, Joan no longer
really knows who I am. Due to this
tragic situation, which Leonard Cohen appears to be attempting to exploit, the
Declaration of Joan Lynch’s which I conformed, in accordance with her personal
authorization (which she acknowledged was an oral power of attorney), was
submitted to the Court. Joan Lynch spent
a considerable amount of time working with Kelley on her declaration and her
version of events, and recounting of things she witnessed, deserves to be
heard. She is a lovely, bright woman
who, together with Jack Lynch, Leonard Cohen has also falsely accused.
4.
I am aware that Kelley made a conscious decision
not to submit a declaration to this Court
from Chad
Knaak. The reason for this is the
relentless, years long targeting of her sons.
Chad Knaak is a childhood friend of Rutger Penick’s. Rutger is Kelley’s older son and a wonderful
young man who, as is true for Ray Charles Lindsey, his older brother, have
suffered tremendously throughout these difficult 10 years. As I was present when Kelley asked Chad Knaak
to phone Leonard Cohen’s lawyer, I felt I should explain what I personally
witnessed and heard that day. Kelley
instructed Chad Knaak to advise this lawyer that she was not served Cohen’s
lawsuit and IF he attempted to serve her she would hold him accountable. I have no recollection as to whether or not
she said “again” but I do know that process servers, repo men, and others, were
leaving the business cards on her door and documents on the ground outside her
door. I would also like to point out
that, if a process server actually visited Kelley’s home, he would have
understood that she had a doorbell. He
therefore would not have knocked but would have rung the bell. I distinctly recall the bell directly to the
left of the door. It lit up at night so
one couldn’t miss it.
5.
Since submitting my declaration to this Court, I
have been routinely harassed by Stephen
Gianelli and
Leonard Cohen’s fan, Susanne Walsh. Stephen
Gianelli seems particularly interested in slandering and intimidating me. It does concern me that, as a long time
resident of Los Angeles, I apparently do not have access to the same services
an individual such as Leonard Cohen does.
Leonard Cohen is, of course, a Canadian citizen staying in this country
as a guest of our government.
6.
In June 2014, I sent my former tenant a rent demand
letter which she disregarded. I then
filed
a Complaint
in Small Claims Court. During the first
hearing, after the Court instructed the parties to participate in mediation and
show one another evidence, Karina Von Watteville informed me and the mediator
that she phoned Robert Kory (Cohen’s lawyer) and was advised to sue Kelley. Kelley had sent Karina Von Watteville a
handful of cease and desist letters, over the course of months, addressing her
obsession with her, slander, and remarks to others that she planned to have
Kelley “investigated” and “get her in trouble.”
The call to Robert Kory was Karina Von Watteville’s response to my rent
demand letter. She previously advised me
that she does not know Leonard Cohen. At
the second Small Claims Court hearing, the same situation occurred, and this
time (in front of the mediator), Karina Von Watteville began slandering Kelley,
ranting about Leonard Cohen and Robert Kory, and showed us the handful of cease
and desist letters which she stated were evidence in my Small Claims
matter. She said she planned to tell the
Court that Kelley was trying to have her deported by ICE. At no time did Kelley ever mention having Von
Watteville deported. This is simply how
Karina Von Watteville thinks. I was
awarded a judgment of $6,700. Suddenly,
Stephen Gianelli ended up representing Von Watteville. He wrote the legal document she provided the
Small Claims Court and began harassing us over this matter. I then lost the Small Claims case. I personally do not believe the call to
Robert Kory followed by Stephen Gianelli’s legal representation were mere
coincidences.
I declare under the penalty of perjury
under the laws of the State of California that the foregoing is true
This
declaration was executed on this 16th day of June 2015 in Los Angeles,
California.
____________________________________
PAULETTE BRANDT
EXHIBIT A
ORIGINAL DECLARATIONS PREPARED
TO SUBMIT WITH KELLEY LYNCH’S
MOTION FOR TERMINATING SANCTIONS
MOTION FOR TERMINATING SANCTIONS
DECLARATION OF PAULETTE BRANDT
I, Paulette Brandt, declare:
1.
I am a citizen of the United States who currently
resides in Los Angeles, California. I am a
close
personal friend of defendant, Kelley Ann Lynch. I am over the age of 18 years. I have personal knowledge of the facts contained in this declaration
and if called upon to testify I could and would testify competently as to the
truth of the facts stated herein.
2.
I have worked in the entertainment
industry for years and have held positions with Apple
Records,
ABKCO Records, Columbia Pictures, and Phil Spector.
3.
I first met Kelley Lynch when Phil
Spector and I visited Marty Machat’s office years ago.
Marty
Machat was an entertainment industry attorney who represented Phil Spector and
Leonard Cohen.
4.
When Kelley moved to Los Angeles in the
early 1990s, we reconnected and she and I began
communicating
regularly and developed a strong friendship.
She is a close personal friend of Phil Spector’s and worked as his
assistant from approximately 1988 until sometime in 1991. I then went back to work for Mr.
Spector. I worked as his personal
assistant from some point in 1991 until 2002.
5.
Throughout the summer and fall of 2005,
I visited Kelley at her home in Brentwood,
California
approximately once a week. I usually
would arrive at her house around 8 A.M. and stay for a few hours, sometimes
longer. She and Leonard Cohen parted
ways at some point in the fall of 2004 and, as of April 2005, she had reported
allegations that he committed tax fraud to Internal Revenue Service. It is my understanding that Leonard Cohen
then withheld commissions she was due and refused to address her ownership
interest in certain intellectual property.
This situation caused financial ruin for Kelley and, it is my personal
belief, led to the lawsuit in this case.
6.
When I visited Kelley in the summer and
fall of 2005, I would bring food for her animals, hair
dye,
and other items she could not afford.
Kelley’s phone and then electricity were shut off.
7.
During this period of time, I would
also dye and cut Kelley’s hair.
8.
Kelley did not attempt to evade service
of Leonard Cohen’s lawsuit. She has a
legal
background
and has been extremely frustrated over this situation. Cohen’s lawyers absolutely refused to
communicate with her, at all, throughout the entire litigation in this
case. She was representing herself and
wanted to file an answer to Cohen’s Complaint but was unaware of the actual
allegations raised. We both read the
news accounts.
9.
I was with Kelley when she repeatedly
attempted to Cohen’s lawyers about their failure to
serve
her, her interest in participating in discovery, and other issues related to
this and other cases that involved the two of them. It is my understanding that the default
judgment in this matter was used against Kelley in Natural Wealth’s lawsuit
against Leonard Cohen. That lawsuit was
not resolved until September 5, 2008 when the judge entered his opinion and
relied on the default judgment in this case.
10.
It is my personal opinion that Leonard
Cohen saw an opportunity not to serve Kelley,
understood
she was not represented by counsel, and felt it would be easier to simply
obtain
a
default judgment against her. Kelley did
not have the money to hire an attorney.
She didn’t even have the money to travel downtown to pick up a copy of
the Complaint. However, that is not
Kelley’s responsibility. The Plaintiffs
are responsible for properly serving defendant.
11.
Kelley answered her door whenever I
visited. She was not attempting to avoid
or evade
anyone. She also answered it in my presence when she
was served legal documents in unrelated matters. Because Kelley was bankrupted over this
situation, her creditors filed lawsuits as well.
12.
The process server indicates that he
attempted to serve Kelley at 8:45 AM on August 23, 2005
and
notes that he knocked but no one answered.
Kelley had a doorbell; the back of her house had wall to ceiling plate
glass windows; she would not have had the lights on in the morning; and, Kelley
always turns the lights out when she leaves a room.
13.
I visited Kelley on August 24, 2005
when the process serve allegedly served her.
I arrived, as
was
customary, quite early in the morning. I
recall Kelley’s frustration because Leonard Cohen’s lawsuit had been filed a
week or so earlier and she still had not been served. I had read about the case online. The LA Times brought the lawsuit to Kelley’s
attention and asked her for a quote. I
suggested that Kelley phone Cohen’s lawyer to ask him if there was a problem
with service. We discussed this while I cut
and dyed Kelley’s hair a very dark shade of brown, almost black.
14.
Kelley and I then went online and found
Cohen’s lawyer’s name in some of the articles
published
at that time. I was present when Kelley
googled this lawyer’s name and phone number.
We then walked outside to her son’s guesthouse. Kelley went inside and I stood in the
doorway. Rutger and his friend, Chad
Knaak, were inside with Kelley.
15.
Due to the fact that Kelley’s phone had
been turned off, Kelley asked Chad to phone Cohen’s
lawyer
to advise him that she was not served the lawsuit and IF he attempted to serve
her she would hold him personally accountable.
Kelley handed Chad the paper she had written Scott Edelman’s name and
number on. She asked Chad to be polite
and professional when he spoke to Edelman.
Chad called and had a conversation with someone at the law firm of
Gibson, Dunn. Chad explained that he was
Kelley’s housemate and repeated the message that she had NOT been served. While Chad was on the phone with Cohen’s law
firm, Kelley asked him to inform the party on the other end that the lawsuit
was retaliation over the fact that she reported allegations related to Cohen’s
alleged tax fraud to Internal Revenue Service and viewed the lawsuit as
retaliation.
16.
At the time Leonard Cohen filed his
lawsuit, he granted at least one interview to MacLean’s
Magazine
and his dissemination of defamatory statements about Kelley caused severe harm
to her reputation. This lawsuit, and the
news accounts of what occurred, have also exposed Kelley to quite a number of
individuals who have relentlessly targeted her, members of her family, close
friends, and others.
17.
From approximately June 2005 through
October 2005, I personally dyed Kelley’s hair very
dark
brown. On August 24, 2005, Kelley had very
short, extremely dark (nearly black) hair, large blue eyes, was extremely thin,
and was approximately 5’6” tall. She did
not resemble the individual described in the proof of service at all. It is impossible that a process server would
describe her, at this time, as having blonde hair when her hair color was
almost black; black eyes when her eyes are very bright blue; or being of medium
build when she was exceedingly thin. It
is possible that a process server could view Kelley as being approximately 5’7”
but that is the only detail that I personally believe could be used to describe
Kelley as of August 24, 2005.
18.
I visited with Kelley for quite a long
time that day and have reviewed my records from that
period. Kelley, Rutger, Chad, and I were alone at
Kelley’s house. There was no other
female present and Kelley did not have a female “co-occupant.” Chad Knaak was staying with Kelley and
Rutger. No one came to the door that
morning and the process server clearly relied on an out-dated description of
Kelley.
19.
I attended the January 17, 2014 hearing in
this case and planned to testify. When
Kelley and
I
phoned Department 24 before the hearing, we were told that nothing else had to
be filed and she should simply show up for the hearing with witnesses. Kelley’s friend, Palden Ronge, also attended
that hearing with us. He also visited
Kelley throughout the summer and fall of 2005.
Neither of us was given the opportunity to testify.
20.
There is no way the process server saw
Kelley on August 24, 2005. I also do not
believe the
process
server visited her house on approximately six other occasions. Kelley was home constantly throughout this
period. She had been in an accident
(where she was hit by a careless driver) and left without transportation. Therefore, I would bring her supplies and
items she needed. She also did not have
any money at this period of time. Every
time I visited, Kelley would answer the door and she was clearly not attempting
to avoid or evade anyone. I am aware
that there are problems with process service and issues related to lack of
service. On at least one occasion, I
personally found legal documents (unrelated to this case) thrown on the ground
outside her home. I am presently
assisting with a case where lack of service is an ongoing problem. In fact, a Bankruptcy Court judge recently
dismissed a judgment due to lack of service and fraud in connection with the
proof of service. This appears to be a
growing problem in our legal system.
21.
This situation has been utterly
frustrating for Kelley because Cohen’s lawyers refused to speak
to
her, continued to behave in an unprofessional and hostile manner towards her,
and she did not have an opportunity to actually read Cohen’s Complaint until it
was posted online in the spring of 2010.
At that time, Kelley called me and we were in disbelief at the
allegations Cohen’s lawsuit raised.
Those allegations, from what I can tell, are contradicted by the
evidence. I have become relatively
familiar with the corporate records, and other evidence, related to this
case. That would include, but is not
limited to, federal corporate tax returns where Kelley is listed as a partner,
stock certificates, and contracts.
22.
Shortly after discovering the Complaint
online, Kelley moved to Ft. Lauderdale, Florida. She
did
not return to Los Angeles (apart from the period when she was incarcerated for
allegedly violating Leonard Cohen’s restraining order by requesting tax
information, etc.) until June 2013 when I invited her to stay with me. Kelley has been my roommate for over a year
and a half now. I view her as one of my
dearest friends and a blessing. What has
happened to her is a disgrace.
23.
Since Cohen filed this lawsuit in
August 2005, Kelley has continually maintained that she was
not
served the lawsuit. She and Rutger were
evicted from their Brentwood home in December 2005. I personally believe that Cohen and his
lawyers feel they can use abusive litigation tactics, including fraudulent
restraining orders, against Kelley because she has been representing herself for
the past 10 years and has no money to hire an attorney.
I declare under the penalty of perjury
under the laws of the State of California that the foregoing is true
This
declaration was executed on this 13th day of March 2015 in Los Angeles,
California.
____________________________________
PAULETTE BRANDT
DECLARATION OF PAULETTE BRANDT
I, Paulette Brandt, declare:
7.
I am a citizen of the United
States who currently resides in Los Angeles, California. I am a
close friend of defendant, Kelley Ann Lynch. I am over the age of 18 years. I have personal knowledge of the facts contained in this
declaration and if called upon to testify I could and would testify competently
as to the truth of the facts stated herein.
8.
I have worked in the entertainment industry all of
my adult life and held positions at Apple
Records,
ABKCO Records, Columbia Pictures, and worked as Phil Spector’s personal assistant
from approximately 1991 through 2002. I
met Kelley through Phil Spector.
9.
Kelley and I became quite close after she moved to
Los Angeles and we spoke regularly over
the
years. After Kelley was evicted from her
home in December 2005, and ended up homeless due to the situation with Leonard
Cohen, she and I lost touch for a spell.
We touched base in 2010, when she was visiting Los Angeles.
10.
At some point in early 2013, Kelley sent me a note
through my Facebook account. I
responded
with an email in February 2013 that she posted on her blog. See Exhibit 1 attached hereto and made a part
hereof.
11.
Following that, I received an email from a
stranger, Stephen Gianelli, attempting to turn me
against
Kelley and slandering her. Since that
time, I have received countless harassing emails from this individual and
another individual by the name of Susanne Walsh (Leonard Cohen’s fan). I do not respond to his emails. He frequently copies in Kelley’s sons,
sister, Deputy City Attorney Vivienne Swanigan, and Investigator William
Frayeh, an investigator on the Phil Spector case. Gianelli and Walsh, together with others,
appeared to work in tandem. In fact,
Gianelli worked with Michelle Blaine, Phl Spector’s former assistant to target
and shut down Kelley’s blog and email accounts.
Stephen Gianelli’s harassing
emails continue until this day. I have
contacted LAPD’s TMU about this matter and spoken with LAPD detectives about
this harassment. I have also spoken with
Investigator Frayeh about the harassing emails as has Kelley. This situation is material to Leonard Cohen’s
lawsuit and default judgment. Stephen
Gianelli has publicly stated that he has communicated with Leonard Cohen’s
lawyers since 2009. I have attached some
of the most recent harassing emails I’ve received. The content relates to Phil Spector, DNA
evidence on the ammunition, and the motion Kelley is filing at this time in
Case No. BC 3383232. See Exhibit 2
attached hereto and made a part hereof.
12.
On or about June 1, 2013, Kelley returned to Los
Angeles, California. She had not resided
here, apart
from her visit with Rutger in 2010, since the fall of 2006. She has resided with me
since June
2013. I have spoken with Kelley’s
appellate attorney, Francisco Suarez, about this campaign of harassment. He too received emails from these
individuals, for over a year, and asked me to serve as a witness for
Kelley. Mr. Suarez advised Kelley to
forward these emails to the FBI and bring them to the attention of LAPD’s TMU
who were involved with Kelley’s arrest in March 2012 in connection to her
alleged violation of a restraining order Leonard Cohen obtained and her general
requests for tax information. Many
people who have provided Kelley with declarations have been harassed. Kelley, I, her sons, and others harassed
immediately after she moved in with me.
In July 2013, her younger son, Ray Charles Lindsey, provided her with a
declaration addressing this campaign of harassment. It has made him physically
ill. Kelley was and remains concerned
about the effects of this situation on both of her sons. Her sister’s lawyer advised Gianelli to cease
and desist. He refuses to do so. I have spoken with Kelley’s mother, who
authorized me to sign her declaration that was submitted with the motion, and
she expressed grave concern about this situation. See Exhibit 3 attached hereto and made a part
hereof.
13.
Kelley and I recently were interviewed by Truth
Sentinel, a small internet radio program.
We
discussed
Leonard Cohen and Phil Spector and these cases.
We mentioned the organized email harassment campaign. Stephen Gianelli then went onto that site and
began slandering Kelley and posting comments about the forensic science in Phil
Spector’s case. I personally believe
that this activity is meant to discredit Kelley, undermine her potential as a
credible witness, and also serves to intimidate people who support her, and
isolate Kelley. See Exhibit 4 attached
hereto and made a part hereof.
14.
I have provided the Court with a separate
declaration specifically addressing issues related to
Cohen’s
failure to serve Kelley the Summons & Complaint in this case. Given the fact that I was with Kelley on the
morning of August 24, 2005 and was present when Chad Knaak phoned Cohen’s
lawyer, I believe it is abundantly clear that she was not served.
15.
I have witnessed Kelley’s attempts to obtain the
transcript for the March 23, 2012 hearing
where Cohen
was asked if Kelley stole from him and replied “just my peace of mind.” That is highly relevant and material
testimony that critically undermines Cohen’s “misappropriations” argument and I
will point out that the “expense ledger” covers “misappropriations’ in
2004. Kelley spent over a year and a
half contacting LA Superior Court and the Court Reporter’s office. I have also called them on her behalf. For over a year and a half Kelley was told
that, because Judge Mayerson retired, she would be unable to obtain transcripts
of this hearing; the hearings were recorded but no one knew where the tapes
were maintained or how she could obtain them; without a present courtroom
department for Judge Mayerson no one could assist her; a court reporter would
not have been present during a misdemeanor hearing; and other similar comments.
Finally, on or about June 17, 2014,
Kelley located and reached the court reporter who was present for the March 23,
2012 hearing. I was present when Kelley
spoke to the court reporter in June 2014 for the first time and loaned Kelley
$75 for the transcript.
16.
On or about August 14, 2014, Kelley received the
transcript for the March 2012 hearing after
diligently
pursuing it since her release from jail, in the Cohen restraining order
violation matter, mid-September 2012.
17.
Since July 2014, Kelley has diligently worked on
the motion she has submitted to the Court.
A
lawyer she worked
for in her 20s advised Kelley that the legal issues raised in these matters had
his head spinning. Kelley has spent
countless hours researching legal issues related to this motion. She also did not have access to her
evidence. I drove to the Bay Area, where
it was stored, and picked it up for her.
18.
The default judgment has caused problems for Kelley
with respect to her 2004 and 2005
federal and
state tax returns. Leonard Cohen refuses
to provide Kelley with a 1099 for 2004 and corporate tax information for 2004
and 2005. She cannot file her tax
returns without this information.
I have personally spoken with IRS, and
other tax authorities, on Kelley’s behalf.
IRS confirmed that they are not in receipt of a 2005 required form 1099
from Leonard Cohen for Kelley; IRS has not received K-1 partnership documents
for companies Kelley has a legal partnership in; and, IRS advised me that
Kelley should contact Leonard Cohen personally to request this information and
ask him to rescind the K-1s his company, LC Investments, LLC, transmitted to
IRS in 2004 and 2005 indicating that Kelley is a partner on that entity. Problems have also arisen due to the fact
that Kelley was included on Traditional Holdings, LLC 2001, 2002, and 2003
federal tax returns, paid taxes, but the Court determined (when entering the
default against her) that she has no legal interest in that entity. The IRS records and filings and State Court
judgment contradict one another.
19.
I worked in
Statement Preparation at Columbia Pictures in the 1980s. I have never seen an
accounting that resembles the “expense
ledger” Cohen used to support the May 2006 default judgment. It is a meaningless list of numbers with no
information about corporate ownership interests, equity, assets, or
liabilities. Any advances to Kelley and
Cohen are missing or have been falsely represented as being
“misappropriated.” Advances are
customary in the entertainment industry.
Leonard Cohen’s loans are not addressed.
He has apparently taken loans of approximately $6.7 million in
connection with the Traditional Holdings, LLC entity alone. I have reviewed the corporate records, stock
units, agreements, and federal tax returns and am familiar with the evidence in
general. Kelley has a legal interest in
numerous “Cohen related” entities; is owed commissions for services rendered;
and the “expense ledger” appears to be evidence of financial and accounting
fraud.
20.
I would like
to briefly address the restraining orders Cohen has obtained against
Kelley. I
believe he has used these as a litigation
tactic and they thoroughly discredit Kelley.
I have spoken directly with the Boulder Combined Court on approximately
three separate occasions in the past couple of years about the restraining
order Cohen obtained against Kelley in September 2008. On each occasion, the Boulder Combined Court
advised me that the 2008 order expired on February 15, 2009 and the judge
entered the Motion to Dismiss (that Kelley filed after the hearing) on January
12, 2009. Boulder Combined Court also
advised me that the order Cohen obtained there was not a “domestic violence
order.”
21.
I have also
spoken with Los Angeles Superior Court about Cohen’s registration of the 2008
Boulder order in California on May 25,
2011. I have been advised by Los Angeles
Superior Court that this order is a Family Court matter and relates to
“domestic violence.” Kelley was
prosecuted in 2012 under domestic violence statutes. I am addressing this issue because Michelle
Rice, in her January 4, 2014 declaration submitted to this Court, mentioned
“criminal restraining orders” they obtained against Kelley. Those orders, granted without a hearing, are
“domestic violence related” orders.
Somehow the original 2008 Boulder order has transformed into a “domestic
violence” matter.
22.
Kelley is
filing a motion to address the wrongful restraint related to Cohen’s litigation
tactic
restraining orders in the next week or
so. She has been researching those
issues diligently as well.
23.
I would
finally like to point out that from 2005 until the present, Leonard Cohen’s
legal
representatives refuse to communicate with
Kelley. She was not served the Complaint
in this matter and has been served
documents that were not filed with this Court (including the Objections
document Jeffrey Korn served her with the day before the January 2014 hearing
and Korn’s proposed order). It is
extremely obvious that Leonard Cohen and his legal representatives have abused
the justice system, restraining order process, and Kelley. Clearly, they believe they can take advantage
of her because she is self-represented.
The tactics that have been used against her are appalling.
24.
I was
present when Kelley phoned Jeffrey Korn, attorney of record in this case, to
advise him
that she planned to file this motion and
serve him. He advised her that he didn’t
know if he was the attorney of record and she could serve him a “courtesy
copy.” Jeffrey Korn is the attorney of
record in this case. Stephen Gianelli
has not entered a formal appearance in this case and Kelley has been advised to
address the Cohen legal issues Gianelli emails her about with Jeffrey Korn as
he has filed a formal appearance on Cohen’s behalf.
I declare under the penalty of perjury
under the laws of the State of California that the foregoing is true
This declaration
is executed on this 13th day of March 2015 in Los Angeles, California.
____________________________________
PAULETTE BRANDT
