I would like you to review the items Cohen is arguing are attorney/client privileged. That would include corporate records and other materials that relate to my ownership interests in Traditional Holdings, LLC, Old Ideas, LLC, and Blue Mist Touring Company, Inc. I wonder if they'll claim a/c privilege re. the illegal K-1s they transmitted to IRS from LCI indicating that I am a partner. They have attempted to argue that my K-1s (from Traditional Holdings, LLC) are a/c privileged. I have never seen anything so deranged in my entire life. My emails advising Westin that my offices were not corporate offices or (to Cohen and Westin) advising them that I did not handle IRS matters, tax, corporate, accounting, or legal matters (including loan documents) are a/c prvileged? No.
Three documents belong to Machat & Machat and Steven Machat authorized me to maintain copied of those documents.
Neither Bergman nor Rice have responded to my request to email me a copy of the "redacted declaration" I prepared for IRS, submitted to IRS with evidence, and then filed with my motion for terminating sanctions.
They are now engaged in an absurd argument that because I have filed one motion to vacate, and then their fraud and perjury in obtaining Judge Hess' order to dismiss that, I am acting in bad faith. Leonard Cohen has slandered me in the news media. He moved offensively with MacLean's. The custody matter was clearly coordinated. He has now shamelessly hired Daniel Bergman who destroyed my sons' lives. My sons have been criminally harassed for six straight years. Ray himself understood the issues he was being harassed over (and his mother slandered) related to IRS, Leonard Cohen, and Phil Spector. Rutger will attend the June 23, 2015 hearing.
They have now falsely accused me of submitting fraudulent declarations to the court. Unfortunately, Jules Zalon (who just wrote the judge with instructions for me to provide opposing counsel with a copy of that letter) was unable to "sign" his letter. I would like Jules Zalon to testify at the Sanctions hearing and the judge acknowledged that he accepts CourtCall with out-of-state individuals. I would also like Steven Machat to testify. See our conversation below.
Finally, I would like IRS to provide me with an opinion re. the legal documents submitted to the Court and served upon me. I was assisted, with my research, re. the frauduluent "domestic violence" order, by the Chief Justice's Assistant (California Supreme Court) and you cannot register a foreign order (fraud or otherwise) as a domestic violence order when the original was not. The Judicial Council and I spoke about the motion I am filing to vacate that but I am now being accused of having animosity towards Michelle Rice.
I explained to Jules Zalon (who knows my parents and sister - she worked for him and Machat & Machat) that he cannot believe the tactics these people engage in and the conduct on their part.
I am working on my Reply to their absurd and obscene Opposition to my Motion for Terminating Sanctions. It is NOT a motion for reconsideration. An order can be vacated if it was obtained using an extensive pattern of perjury and fraud (fraud upon the court). There is no statute re. fraud upon the court.
I cannot believe a Canadian citizen simply hires lawyers, engages in this type of conduct, and behaves to unconscionably with the full awareness that IRS, FBI, DOJ, and others are copied in. Michelle Rice, on February 14, 2011 wrote and LIED to me, IRS, FBI, Treasury, Dennis Riordan, and Ron Burkle. Perhaps Michelle Rice should stop lying and then she won't be so paranoid. That isn't actually the practice of law.
I sent my Press Release to the Chief Justice of the California Supreme Court's Assistant. I do hope she enjoyed it. Perhaps it's time for CIA to de-activate tyhe Manchurian Candidate as the mind control techniques have obviously failed. I can assure you that Cohen - not I - is the individual who informed me that he was in the CIA MKULTRA program. He has told others the same thing. Please take a look at my press release and let me know what you believe in this document shows malice re. my Motion for Terminating Sanctions? Leonard Cohen wants my "fee waiver" now.
Stephen Gianelli's email was and remains pathetic - with Bergman and Kory (not Rice) copied in. However, Marianne I (who must have been at the hearing with Judge Hess) and Mongochili are on the case now. I will submit their emails to Judge Hess. I intend to bring all their tactics to the attention of the Court. In fact, I am thinking of calling my book TACTICS.
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
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 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
