Date: Thu, Mar 17, 2016 at 1:36 PM
Subject: Re: 'Heart to Heart' February 13, 2016
To: alan hootnick <ahootnick@yahoo.com>, Stephen Gianelli <stephengianelli@gmail.com>, Michelle Rice <mrice@koryrice.com>, Robert Kory <rkory@koryrice.com>, "*irs. commissioner" <*IRS.Commissioner@irs.gov>, Washington Field <washington.field@ic.fbi.gov>, ASKDOJ <ASKDOJ@usdoj.gov>, ": Division, Criminal" <Criminal.Division@usdoj.gov>, "Doug.Davis" <Doug.Davis@ftb.ca.gov>, Dennis <Dennis@riordan-horgan.com>, MollyHale <MollyHale@ucia.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>, Harriet Ryan <harriet.ryan@latimes.com>, "hailey.branson" <hailey.branson@latimes.com>, Stan Garnett <stan.garnett@gmail.com>, Mike Feuer <mike.feuer@lacity.org>, "mayor.garcetti" <mayor.garcetti@lacity.org>, Opla-pd-los-occ <OPLA-PD-LOS-OCC@ice.dhs.gov>, "Kelly.Sopko" <Kelly.Sopko@tigta.treas.gov>, Whistleblower <whistleblower@judiciary-rep.senate.gov>, Attacheottawa <AttacheOttawa@ci.irs.gov>, tips@radaronline.com
Mike Feuer,
Please pass along Bobo the Clown's legal opinion to the "stalking" unit. Is Bobo writing Cohen's legal defense while Cohen fantasizes about my fee waiver? I can certainly understand why Streeter was gushing in her cell phone. Doesn't your office want to hire Bobo the Clown?
Kelley Lynch
Photograph of Cohen's Co-Conspirator Stalker in LA Confidential's Sewer System:
From: STEPHEN R. GIANELLI <stephengianelli@
Date: Thu, Mar 17, 2016 at 7:27 AM
Subject: Fw: Kelley Lynch email dated Wed, Mar 16, 2016 at 12:57 PM
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>
Date: Thu, Mar 17, 2016 at 7:27 AM
Subject: Fw: Kelley Lynch email dated Wed, Mar 16, 2016 at 12:57 PM
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>
Ms. Lynch,
1. I have no affiliation with Leonard Cohen whatsoever. We have never met or spoken. We are neither attorney and client, nor are we friends or “co-conspirators” as you alleged on your blog today.
2. That said, you will be filing any RICO suit, if any, in forma pauperis and pro se.
3. The court is required to review in forma pauperis complaints to determine whether summary dismissal is appropriate. See 28 U.S.C. § 1915(e). The court must dismiss a complaint following this initial review that 1. states a frivolous or malicious claim 2. that fails to state a claim on which relief may be granted, or 3. that seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B). Pro se plaintiffs must set forth enough factual allegations to "nudge[] their claims across the line from conceivable to plausible," or "their complaint must be dismissed." Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 569-70 (2007); see also Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) ("A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.").
4. Mr. Posel’s email pasted below was sent to you in 2005 – 11 years ago and well beyond the 4-year statute of limitations applicable to civil RICO actions.
5. Additionally, any RICO complaint would fail to state a claim for relief for myriad additional reasons: Your conspiracy allegations are implausible under Twombly and Ashcroft – especially given your litigation history with Leonard Cohen. Your claim is barred by the res judicata effect of the 2006 judgment in BC338322. The federal district court is required to give the California judgment fill faith and credit, and accord it the same legal effect that it would have under California law. You may not attack the validity of that judgment, or seek damages flowing from its issuance or the manner in which it was procured under the Rooker-Feldman doctrine. You cannot allege any business injuries that occurred within the applicable 4-year statute of limitations. Your alleged predicate acts are more than 10-years apart. Any activity while testifying in court as a witness or as a lawyer is absolutely immune from civil liability. You cannot allege – let alone prove – that Cohen’s music business is an ongoing “criminal enterprise”, or that there is a risk of future criminality.
6. The preliminary review of your complaint will take place BEFORE the clerk of the Central District Court issues a summons and (therefore) before any defendant is served. And, as a result of the above, your complaint will be DISMISSED before any defendant is required to expend any attorney’s fees responding to it – which is the whole point of the preliminary review mandated by 28 U.S.C. § 1915(e).
7. You must be aware of all of this, since you have not pulled the trigger on this “RICO suit” you have been threatening to file since 2009, told the 9th Circuit Court of Appeals in a signed declaration you planned to file on March 3, 2016, but never seem to get around to actually filing.
8. The reason you have not, and will not, pulled the trigger on this “RICO suit” is that you are now fully aware that it will be DISMISSED before any defendant is even bothered with it, and consequently there is no point to filing it. Leonard Cohen can afford the best lawyers money can buy, and I would therefore assume that they are aware of all of this as well, MEANING, that your threats to do so have lost their impact; no one cares at this point.
Stephen R. Gianelli
Attorney-at-Law (ret.)
Crete, Greece
---Forwarded message---
From: Kelley Lynch <kelley.lynch.2010@
Date: Wed, Mar 16, 2016 at 12:57 PM
Subject:
To: Dave Chipman, Sherab Posel, "*IRS.Commisioner" <*IRS.Commisioner@irs.gov>, Washington Field <washington.field@ic.fbi.gov>, ASKDOJ <ASKDOJ@usdoj.gov>, "Division, Criminal" <Criminal.Division@usdoj.gov>, "Doug.Davis" <Doug.Davis@ftb.ca.gov>, Dennis <Dennis@riordan-horgan.com>, MollyHale <MollyHale@ucia.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
Date: Wed, Mar 16, 2016 at 12:57 PM
Subject:
To: Dave Chipman, Sherab Posel, "*IRS.Commisioner" <*IRS.Commisioner@irs.gov>, Washington Field <washington.field@ic.fbi.gov>, ASKDOJ <ASKDOJ@usdoj.gov>, "Division, Criminal" <Criminal.Division@usdoj.gov>, "Doug.Davis" <Doug.Davis@ftb.ca.gov>, Dennis <Dennis@riordan-horgan.com>, MollyHale <MollyHale@ucia.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
Dave Chipman and Norman Posel,
I am enclosing a copy of the email I received from Posel on August 11, 2005. I am about to file a federal RICO suit against Leonard Cohen and others. I would like to show the federal court evidence related to Cohen/Kory's plans to destroy me and my children. I also happen to believe that evidence should have been submitted to Judge Babcock in Colorado. After all, it is highly relevant, material, and goes to motive and retaliation.
Please let me know if you are wiling to provide me with the memorandum at this time.
Kelley Lynch
The Stalker removed this from his harassing email:
Email dated August 11, 2005 from lsdorje@verizon.net
Please see our complaint against LC and RK re. the allegation about destroying you and your children. There may be a memo in the file relating to this allegation. I will check with Dave Chipman about that, and whether it is a public document that can be shared at this time.
Please see our complaint against LC and RK re. the allegation about destroying you and your children. There may be a memo in the file relating to this allegation. I will check with Dave Chipman about that, and whether it is a public document that can be shared at this time.
On Thu, Mar 17, 2016 at 1:34 PM, Kelley Lynch <kelley.lynch.2013@gmail.com> wrote:
Mike Feuer,
Feel free to read Bobo the Clown's legal opinions on behalf of Cohen. Is Cohen still fantasizing about my "fee waiver?" Ask the stalking unit ifthey think I'm dealing with Bobo the Clown or a fruitcake.Thank you.Kelley LynchOn Thu, Mar 17, 2016 at 1:33 PM, Kelley Lynch <kelley.lynch.2013@gmail.com> wrote:Kory & Rice,I'm not interested in Bobo the Clown's legal opinions re. Cohen and my RICO suit.Kelley LynchOn Thu, Mar 17, 2016 at 1:33 PM, Kelley Lynch <kelley.lynch.2013@gmail.com> wrote:Alan Hootnick,Did you enjoy Bobo the Clown's RICO argument re. Leonard Cohen? Was the clown and his professional shopper wife enjoying one of theirsoirees? After he goes to his events does he begin researching Cohen's legal issues while harassing me, my sons, Paulette Brandt, etc?
Kelley Lynch---------- Forwarded message ----------
From: Stephen R. Gianelli <stephengianelli@gmail.com>
Date: Thu, Mar 17, 2016 at 6:29 AM
Subject: 'Heart to Heart' February 13, 2016
To: kelley.lynch.2013@gmail.com
Cc: ahootnick@yahoo.comYes, it was an AMAZING party at the De Young Museum.Thanks for sharing!