DECLARATION OF PAULETTE BRANDT
I, Paulette Brandt, do state and declare as follows:
1. Ì am a citizen of the United States who resides in Los Angeles, California. Except as to those matters state on information and belief, I have personal knowledge of the facts set forth and could and would testify competently if asked to do so.
2. I have worked in the entertainment industry for my entire adult life. I have worked for Phi l Spector, Abkko Records, Apple Records, Columbia Pictures, and others.
3. I initially met Kelley approximately 25 years ago. We met when she relocated to Los Angeles from New York City. We have stayed in close touch for the last 15-20 years.
I am under the impression that Paulette and I first met at Marty Machat’s office in NYC. Paulette and I struck up a friendship after I relocated to LA from NYC. That would have been in or around December 1989 or January 1990. I was very close with Phillip at this time and during the period when Phillip, Jr. was dying and passed away. Paulette then went back to work for Phillip in 1991 after Phillip, Jr’s death. Paulette and I remained quite friendly and to this day she is one of my best friends.
4. Kelley is a close personal friend of Phil Spector’s. I have worked with Kelley in an official capacity. For approximately 17 years, she worked as Leonard Cohen’s personal manager, handled his publishing and book publishing administration, and worked in other capacities. She was not Cohen’s business manager. Kelley also worked as Adam Cohen’s personal manager. She was very skillful in this position, and others, and has been credited with re-invigorating Cohen’s career. A business manager is a CPA who handles accounting and things of that nature. A personal manager is an entirely different position.
5. Kelley has also been a steadfast and stable friend and acquaintance. Kelley has been my houseguest for nearly six months. I am aware that she is being maliciously slandered and maligned. Kelley has no alcohol, drug, or substance abuse issues. She does not have mental health issues. She is entirely down to earth, focused, looking for work, and relating to quite a lot of business and legal matters. I can assure the court that Kelley has no anger problems and absolutely no propensity for violence. I cannot imagine where these allegations originated as they are wholly and entire untrue.
Paulette does not touch alcohol but Gianelli has repeatedly harassed us with slanderous emails (and online posts) lying that she drinks.
6. Kelley is very close with her family including her sons. She has many close friends who have been extremely supportive throughout this ordeal and remain close to her.
7. Over the years, I have worked with a number of celebrities including Phil Spector, Connie Stevens, and Dudley Moore. I have arranged for their security and am very familiar with what to look for in terms of risks. The notion that Kelley is a danger to society, Leonard Cohen, her former prosecutor, or anyone else, is positively laughable.
This statement came from Sandra Jo Streeter during the “bail” hearing where Cohen testified that I never stole from him – just his peace of mind – and confirmed that we were in a purely business relationship. He lied that I failed to file my returns and this man has no idea about my tax returns. He was not my husband. Kory, Gianelli, and others have lied about my tax returns, payments, and filings. The prosecutor also lied that I was estranged from my sons. The situation she lied about re. Jonathan Maihart was documented for Congressman Waxman in 2005. Congressman Waxman faxed me those emails in 2008. I also discussed SWAT, King Drew, etc. with Congressman Waxman in 2005.
8. Kelley has many high profile friends and acquaintances and has no interest whatsoever in Leonard Cohen. She is attempting to address very serious business and legal matters. I don’t believe she ever really even thinks about him. It is his actions and conduct towards her, and her family, that disturb her.
9. It is my understanding that Leonard Cohen testified that he and Kelley were in an intimate sexual dating relationship. Kelley and I have always shared intimate details of our lives with one another. Never once have I heard that she and Cohen were in any type of sexual or intimate dating relationship but perhaps that was his desire. I have, on the other hand, heard stories about his conduct with respect to her. That would include insisting that she read business and legal documents to him while he soaked in the bubble bath; looking at people defecating on one another in front of her; and engaging in entirely unprofessional and unacceptable conduct.
It is absolutely vile that Los Angeles Superior Court would, without notice, merely assign me a dating relationship with someone who exposed himself to me, etc. The City Attorney clearly spun Cohen’s own conduct using the unconstitutionally vague “intent to annoy” statute. The U.S. Supreme Court has confirmed that annoyance statutes are unconstitutional.
10. I am aware and understand that Kelley is on summary misdemeanor probation and has been accused of violating the terms of her probation. Kelley engages in no unlawful conduct whatsoever. She rarely goes out. We are together 24/7. She has been relentlessly targeted by, among others, Stephen Gianelli and Susanne Walsh who I understand is Leonard Cohen’s fan and frequently copies his lawyer in on her emails. I too have been a recipient of emails from these individuals and others, including Kelley’s former landlord, Ray Lawrence. After Ray Lawrence divulged my personal details to Stephen Gianelli, these three individuals began a campaign of harassment respect to me. They falsely accused Kelley of many things and I was extremely disturbed by their slanderous accusations. I too have been slandered by these individuals. To this day, Stephen Gianelli continues to harass me. In fact, I am now receiving emails, U.S. mail, and phone calls that I believe relates to this coordinated campaign of harassment. I recently received a number of extremely disturbing and frightening phone calls. One individual identified themselves as Stephen Gianelli and and threatened to kill me if I did not remain silent about matters involving Kelley, Phil Spector, and Leonard Cohen. I have no idea who this man is; his conduct suggests that he is not stable and possibly engaged in criminal activity; and, for all I know, he could be outside of my home. He is most definitely stalking Kelley and me.
Gianelli continues to harass us. This has and will continue to be documented. The situation with Ray Lawrence – including the conspiracy to destroy evidence (send it to Michelle Rice), etc. – has been documented as well. My sons’ declarations were signed by them personally. I have the original signature copies.
11. Stephen Gianelli initiated communications with Kelley’s prosecutor, and others, at the City Attorney’s office. She has no idea how he obtained the email addresses of a number of Deputy City Attorneys. Kelley attempted to refute malicious and slanderous lies being directed to her prosecutor about her. Her sons, family members, and were copied in. I was copied in on many of these communications as well and can state unequivocally that Kelley’s intention was NOT to harass the prosecutor but to defend herself and refute these falsehoods with the truth and facts.
Gianelli initiated contact with Streeter via email – harassing me, my sons, sister, Paulette Brandt and others. This has been well documented. What has now been discovered is the fact that Rice asked Gianelli for Lawrence’s fraud order; Rice was communicating with the so-called prosecutor; and Cohen’s PI communicated with LAPD’s TMU. Suarez was clear: he viewed Streeter’s conduct as criminal obstruction of justice. I’ve asked IRS, FBI, and DOJ to investigate. I have Suarez’s letter about Gianelli harassing him and confirming that he views my trial as an IRS matter that demands an investigation.
12. I have witnessed Kelley attempt to file complaints with the City Attorney’s office. She repeatedly contacted them in an attempt to have the probation violation documents served. At one point, she was told by that office that the judge was wrong – the Court was the party that would serve the documents. Kelley did not receive the Notice of Probation Violation; Witness List; and Proposed Evidence for almost a full month following her September 25, 2013 hearing. I was present for that hearing and heard Kelley ask the judge for an extension so that she had the appropriate time needed to research the issues and prepare her defense. She has not had the appropriate time and is at a great disadvantage due to the fact that she is not represented, has no money, and no transportation.
City Attorney willfully concealed evidence during the so-called probation hearing. The prosecutor lied to the judge about me and FBI. I will obtain that transcript. Swanigan, whose declaration is entirely perjured, confirmed that she does not know Gianelli.
13. Kelley has also been in touch with the State of Kentucky, Franchise Tax Board, and Internal Revenue Service over the past month or so. All three tax authorities have advised her to contact Leonard Cohen with respect to the K-1 partnership tax documents he has issued her. She is not in possession of IRS form 1099 for the year 2004. This has created a tremendous amount of stress for Kelley as she is potentially facing a wage garnishment although she owes no taxes.
14. I have worked in Accounting for Columbia Pictures. I have reviewed Leonard Cohen’s alleged forensic report. It is a meaningless list of numbers with a handful of random back-up documents. A proper accounting should show the entire picture. That would include assets, liabilities, corporate ownership interests, outstanding loans/advances, and so forth and so on. Kelley is not in possession of a proper accounting.
15. Kelley has also been attempting to obtain her file from the Public Defender’s Office. I have personally, on her behalf, contacted them. She recently received 17 CDs of evidence from her trial but is awaiting the remainder of her file. This has frustrated her and affected the appeal and writ of habeas corpus she has filed to date.
16. I have reviewed a great deal of the trial transcript and evidence from Kelley’s 2012 trial. It is overwhelmingly obvious that she was not represented at all. The jurors were misled by highly inflammatory rhetoric, false accusations, and misinformation. This was presented to them by both the prosecutor and her trial lawyers.
17. Kelley was pro per throughout the litigation matters with Leonard Cohen. She recently filed a motion to vacate his 2005 lawsuit due to lack of service. She is representing herself in the instant matter and a number of other matters. I am aware that Kelley was not served Cohen’s lawsuit; had no female co-occupant in or around August 2005; and was not notified of or served the default judgment that was subsequently entered against her. I would definitely have invited Kelley to stay with me, rather than allow her to end up homeless, but due to her circumstances (including having her phones and electricity shut down) we fell out of touch for a spell.
Cohen, Kory & Rice lied in pleadings that Paulette materially changed her testimony. After the court refused to permit her and Palden Ronge to testify, Paulette provided greater detail re. what she intended to address during oral testimony. Paulette and I lost touch once I was evicted. She had no way of finding me as I ended up homeless.
18. Kelley is a law abiding citizen. I invited her to stay with me in May 2013 and she has been my guest since that time. Kelley rarely goes out; we are together nearly 24 hours a day; she is close with her family, friends, and Tibetan Buddhist religious advisers; and, I have never seen her attempt to harass, stalk, threaten, or attempt to annoy anyone. On the contrary, I believe certain parties have attempted to intimidate Kelley and have indeed harassed, stalked, threatened, and annoyed her. It has been entirely frustrating for Kelley. Her family, including her sons, have been through a tremendous ordeal and she is gravely concerned for their welfare. Kelley’s parents are elderly. She worries about the impact of these matters, including the attempt to hold her in violation of her probation, on her parents, sons, other relatives, and friends. It has been very disturbing to witness.
19. In the news media, trial transcripts, emails I receive from strangers, and elsewhere, Kelley and her reputation have been rendered unrecognizable. She has been accused of being, among other things, a prostitute, heroin addict, drunk, drug addict, ex-lover of Leonard Cohen’s, abusive mother, thief, and a liar. It is my belief that this is nothing other than an all out attempt to discredit Kelley, destroy her reputation, and create an image of her that is completely fraudulent and disgraceful. It appears to relate to litigation matters, Phil Spector, the IRS, and, the 2012 trial.
The slander, defamation, harassment, stalking, etc. continues. Gianelli now slanders me to third parties.
20. It is my understanding that Kelley has been ordered to pay certain fines and restitution as part of her probation. These financial requirements relate, in great part, to issues related to domestic violence and legal representation. The slander, false accusations in the news media, online campaign of harassment and attempts to discredit her; the trial and domestic violence order have all made it almost impossible for her to find work.
The Colorado order, issued without findings, was and is not a DMV order. The California order is evidence of fraud, etc. There is VAWA funding fraud.
21. I can unequivocally state that Kelley does not want to contact the City Attorney of Los Angeles regarding these matters. It is frustrating for her. I encouraged her to follow up with respect to service of the Notice of Probation Violation which has evidently led to further complications for her. Kelley’s communications with the City Attorney’s Office have been entirely legitimate.
22. Recently, I was present when Kelley phoned the Boulder County Courthouse and spoke to the Clerk’s office. She was advised that the “permanent” Boulder, Colorado civil harassment order expired. Prior to her arrest, Kelley advised me that it expired in or around 2010. At that time, she had also spoken with the Boulder Court. I have been dealing with many legal matters, before LA Superior Court, and am frequently given wrong or misinformation. I was present in Department 47 when Kelley was personally advised that she was not permitted to review her file although she is self-represented.
23. I am very familiar with domestic violence orders and how abused these orders are. I have been assisting Keith Roizman who is also the victim of a fraudulent domestic violence order. These orders are highly abused tactics that are used in divorces, family affairs, and they are successful in business disputes.
24. Kelley sent me a copy of the drone Valentine card that is evidently an element of her probation violation matter. I found the card humorous and charming. I cannot imagine any reasonably intelligent person viewing it in any other context. Kelley is also extremely interested in current political affairs and current affairs and keeps herself abreast of these matters. This card cannot possibly be taken as a threat by Kelley’s prosecutor. Kelley did not create or post the card online and she obviously doesn’t have access to a military drone. There is no threat, let alone a credible threat. I have been involved in an investigation related to a viable and credible death threat. A letter was sent, through the U.S. mail, advising District Attorney Steve Cooley and City Attorney Carmen Trutanich that they would be killed if they did not drop charges against Keith Roizman by a certain date. I was told by LAPD’s TMU that, due to the fact that the date had passed, it was no longer viewed as a credible threat. Kelley’s email, to the FBI and DOJ, with the drone Valentine card was sent on February 14, 2013 and that date has long passed. It is astounding to me that the individual who sent the viable and credible threat, pretending to be Keith Roizman, was not charged or prosecuted but Kelley has been. I am a woman, recipient of the drone Valentine card, and see no threat whatsoever and cannot possibly imagine who would view it in that light without having ulterior motives.
25. It is my opinion, based on everything I’ve seen and heard, that Leonard Cohen has motive for targeting Kelley. He appears to have issues related to tax fraud; does not appear to want to pay his representatives properly; and corporate books and records seem to prove that Kelley is the owner of shares of at least two corporate entities and intellectual property. Cohen also evidently withheld commissions he owes her.
26. I have reviewed, and been copied in on, emails Kelley has sent to the City Attorney. These are in response to Stephen Gianelli’s emails to various parties with the City Attorney copied in. Clearly Kelley has a right to refute slanderous allegations. She does not know who Stephen Gianelli is …. Gianelli began emailing Kelley’s prosecutor, Sandra Jo Streeter, and another woman by the name of Vivienne Swaningan at the City Attorney’s office. His emails, copied to many people (including Kelley’s sons, sister, me, and others), are slanderous, defamatory, and appear to be attempts to discredit Kelley, destroy her reputation, intimidate people in her life, terrorize her and her family, and put her in a position where she could be accused of a probation violation.
27. I have witnessed Kelley’s calls to LAPD TMU. I confirmed for the Threat Management Unit, who I have dealt with on the Keith Roizman matter, that Stephen Gianelli has been harassing me. I have also confirmed eceived harassing emails from Leonard Cohen’s fan, Susanne Walsh. I do not know these individuals. I have confirmed for LAPD’s TMU that I received at least one death threat. Kelley has been gravely concerned about the impact of this activity on her elderly parents, sons, family members, and others. I have also spoken with Kelley’s appellate attorney, Francisco, about this ongoing campaign of harassment. He too receives countless harassing emails from Stephen Gianelli and possibly others.
28. Kelley currently has a number of physical problems that involve high blood pressure, asthma, heart palpitations, and anxiety.
29. Kelley and I have a wonderful relationship. She is a blessing. We are not, as Gianelli has accused us, drunken, drug addicted lesbians or whores. He seems dead set on intimidating people in Kelley’s life and isolating her. His activity relates to Phil Spector, Leonard Cohen, the IRS, and the discrediting and undermining of Kelley Lynch. It is impossible to believe that this activity is a hobby or casual interest. He seems like an absolute professional.
I declare that the foregoing is true and correct under penalty of perjury under the laws of the State of California, and if called to testify, I would and could testify truthful as to the above. Executed on this 12th day of November, 2013.
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PAULETTE BRANDT
