14 June
2015
Judge
Robert Hess
Los
Angeles Superior Court
Department
24
111 N.
Hill Street
Los
Angeles, California 90012
Re:
Kelley Lynch – Case No. BC338322
Dear
Judge Hess,
I am
writing to confirm that I prepared and provided Kelley Lynch with the
declaration attached hereto. I was unavailable to provide the actual
physical signature on this document prior to the date Kelley submitted her
Motion for Terminating Sanctions. I therefore provided her with my
limited power of attorney which authorized her to conform my signature on the
declaration. I also provided her with the signature page which I
understand she now intends to submit to the Court. I can attest hereto
that the attached declaration, which is identical to the declaration submitted
to this Court with Kelley Lynch’s Motion for Terminating Sanctions, was
initially submitted with my full authorization and consent. I am willing
to provide the Court with a notarized copy of this declaration if necessary.
I would
also like to confirm that I attended the January 17, 2014 hearing in this case
and intended to testify. I remain willing to testify should the
opportunity arise to do so in the future.
If you
have any questions, please feel free to contact me directly at RDACTED.
Thank
you.
Very truly yours,
/s/ Palden
Ronge
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. I am a close personal friend of Kelley Lynch’s. 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.
My wife, Lila Rich, and I have
known Kelley for many years. I
personally met her approximately
1988. We are close family
friends and I know her parents and sons, Rutger and Ray. Over the years, we have 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 and
handled her other business matters.
Kelley worked as Cohen’s personal manager for approximately 17
years. It never once crossed my mind
that Kelley and Mr. Cohen were ever involved in any type of intimate dating or
engagement relationship. Nor had I heard
anything to indicate that their relationship was anything but
professional.
5.
I have 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 visited Kelley throughout the
spring and 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, and specifically throughout the month of August 2005, due
to the fact that she changed the color radically. At that time, she had bright blue eyes, very
dark short hair, was approximately 5’6,” quite thin, and weighed approximately
110 pounds. For years, she had worn her
hair very light blonde and it took me some time to grow accustomed to Kelley’s very
dark hair and new look.
7.
In mid-June, Kelley was rear-ended
by a driver on Mandeville Canyon Road.
She was seriously
injured and hospitalized for head trauma and other medical
issues. I believe she also broke her
nose and seriously injured her neck and back.
I visited Kelley in the hospital at that time and, apart from her
physical injuries, she was her usual intelligent, caring, and humorous
self. I recall bringing her sushi.
8.
Shortly after this accident,
another driver on Mandeville Canyon Road, presumably on his cell
phone and not paying attention, pulled out suddenly and quickly
from a side street and slammed into Kelley’s passenger side. Kelley was again injured and this accident
destroyed her car. She was planning to
visit Lila and myself in Ojai, California and was unable to do so due to the
damage the car sustained.
9.
I am aware of the fact that Kelley
was home throughout the summer and fall of 2005. I
frequently visited, understood she had no transportation or money,
and when I rang the bell, she would simply open the door. It didn’t appear that she was attempting to
evade anyone. She informed me repeatedly
that she wanted to be served Cohen’s lawsuit and review the specific
allegations in the Complaint.
10. 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 this lawsuit. She was also extremely frustrated with the
conduct of and tactics used by Leonard Cohen’s representatives.
I declare under the penalty of perjury
under the laws of the State of California that the foregoing is true and
correct.
This
declaration is executed on this 9th day of March 2015 in Los Angeles,
California.
___________________________________
Palden
Ronge
