Motion Exhibit 4

MOTION EXHIBIT 4
DECLARATION OF KELLEY LYNCH
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Kelley Lynch declares:

1. I am a resident of Los Angeles, California and the age of 18, and have
personal knowledge of
the facts set forth hereinbelow and can competently testify thereto if called as a
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witness.
2.
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In approximately 1984, I began working for legendary
entertainment industry attorney, Marty Machat. From approximately 1994
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until the time of his death, in April 1988, I worked as Mr. Machats personal
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and legal assistant. Mr. Machat and his son, Steven Machat, had an
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entertainment industry clientele. It was during this period of time that I was
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introduced to Phil Spector and Leonard Cohen who were two of Machat &
Machats legendary clients. After Mr. Machats death in April 1988, Leonard
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Cohen hired me to work as his personal manager. I worked as Leonard Cohens

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personal manager from approximately April 1988 through October 21, 2004.
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Following Marty Machats death, Phil Spector hired me as his personal
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assistant/intern. I worked for Mr. Spector from sometime in 1988 through,
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although not nearly as regularly, some point in 1991. Thereafter, my friend and
now roommate, Paulette Brandt, returned to Mr. Spectors employ and I
devoted my time and energy specifically to Leonard Cohen, my family, and
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- 1 DECLARATION OF KELLEY LYNCH
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other projects. Beginning in approximately 1996, I began working as Adam

Cohens personal manager. Adam Cohen is Leonard Cohens son. See also
Kelley Lynch Case History.
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When Phil Spector and Leonard Cohen first hired me, I worked
from New York City where I resided with my husband, Douglas Penick, and our
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son, Rutger Penick. This was a particularly busy moment in time as Leonard
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Cohen had recently released his studio album, Im Your Man, and embarked
on a very successful world tour. Additionally, Cohen was unraveling certain
matters with his family friend and personal lawyer, Herschel Weinberg, which
required a tremendous amount of work on the part of his representatives and
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myself as contracts had to be renegotiated and, in many instances, Cohen did

not have agreements in territories and his books had not been published in
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most territories.
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In late 1989, at the specific request of Leonard Cohen, my family
and I moved to Los Angeles where I resided until approximately the fall of
2006. From 2006 through June 2013, I was not a resident of Los Angeles, apart
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from a relatively brief period of time when I visited my son in 2010 and took a
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temporary position. From 2006 through the Spring of 2007, I lived in Santa
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Ana, California. From the Spring/early summer of 2007, I was invited to Erie,
Colorado by Yongzin Rinpoche and his wife. Shortly thereafter, I took a long-
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term temporary position with Deneuve Construction in Boulder, Colorado. I left

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Boulder, Colorado at sometime in late 2008 and went to stay with family friends
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in Northern New Jersey. I stayed there for a number of months, assisted them
with business matters, and decided to return to California to meet up with His
Holiness Kusum Lingpa who planned to travel from Tibet. I stopped in
Colorado and learned that His Holiness became ill in Bejing, China, returned to
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Golok, Tibet, and died on February 26, 2009. At some point, I met a young
woman who asked me to travel with her to Texas. I stayed in Texas until I
decided to visit my son in Los Angeles, California at some point in the winter of
2009. I then stayed with Rutger until approximately the late spring of 2010. I
visited with him for approximately 6 months. At some point midway through
this visit I discovered Leonard Cohens Complaint in this matter online. I
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contacted Judge Freemans courtroom and his court reporter returned my call.
I was attempting to determine what evidence was provided to the court and any
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details I could with respect to the secret mediations and Cohens agreement
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with Richard Westin. I briefly discussed this matter with a lawyer who advised
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me to file a motion to vacate. He also instructed me to address Cohens perjury

in my declaration. I began researching default judgments and other legal
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issues related to vacating a judgment. A friend of mine in Ft. Lauderdale,

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Florida invited me to stay with him. I left Los Angeles, flew to Ft. Lauderdale,
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and stayed with this individual until approximately December 2011 at which
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point I relocated to Berkeley, California. One of the reasons I chose to relocate
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to Berkeley, California is due to the fact that many Tibetan lamas are there,
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including my friend Anam Thubten Rinpoche. At some point after moving to

Berkeley, California, I was hired by GCI, a company who handles ACLU and
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Southern Poverty Law campaigns. At some point in January 2012, my son

drove to Berkeley, California and brought me evidence he had stored since we
were evicted from our home in December 2005. He has been threatened
publicly over that evidence. I worked for GCI until just before I was arrested
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on March 1, 2012 and extradited to Los Angeles, California without the benefit
of an extradition hearing which Berkeley PD assured me I was entitled to.
Neither Berkeley PD nor I could figure out how a court had jurisdiction over
me. Therefore, someone at Berkeley PD phoned LAPD and was advised that the
order I violated was somehow related to the 2008 Boulder, Colorado order that
the Boulder Combined Court repeatedly advised me expired on February 15,
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2009. Somehow this fact was not raised during my 2012 trial; the evidence was
not obtained; and the prosecutor and my lawyers either lied about everything,
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did not understand the facts; and the jurors ultimately advised my lawyers in
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debriefing of the follow: they wanted to hear from IRS; one juror relied on the
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prosecutors statements about Traditional Holding, LLCs assets although the

judge instructed the jury not to rely on attorney statements (one juror felt sorry
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for Cohen); and, evidently some jurors felt I was rough on the prosecutor. For
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reasons I cannot imagine, people seem to think that lying is acceptable,
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targeting people is acceptable, destroying a family is appropriate, stealing is
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acceptable, and the correct response is to send thank you notes and flowers. I
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remain unconvinced and view this as evidence of highly confused and neurotic
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thought processes. I was convicted and sentenced under domestic violence

statutes although there was and remains no domestic violence. The Boulder
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Combined Court was quite clear about that fact. I was incarcerated from
March 1, 2012 until September 2012. I returned to the Bay Area. I spent
countless hours attempting to coerce my file out the public defenders office,
work with my appellate attorney on my appeal (without the benefit of my file or

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critical information), and wrote a writ of habeas corpus without the benefit of
my file or critical information. In June 2013, I relocated to Los Angeles,
California. At that time, I continued researching issues related to the Motion to
Vacate. This is quite difficult given the fact that I still do not have many
documents in this or the related case. On August 9, 2013, my appellate

attorney, as a courtesy, filed the Motion to Vacate. He did not participate in the
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research or writing of that document. While I had provided him with an

Answer to my Complaint he inadvertently failed to attach that document. Mr.
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Suarez, who was kind enough to file this document for me, also turned my
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declaration and the case history into one document and signed it. I authorized
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him to sign on my behalf. He then crossed off Exhibit C on Rutgers

declaration and wrote B. Due to the fact that I have worked at law firms in
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various parts of this country, I used a perjury statement that California does not
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use although I think that one does take this oath to the best of their knowledge
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and belief. That generally addresses the fact that I have not resided in Los
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Angeles, California, except for a brief visit in 2010, from 2006 through June
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2013. I also did not have the financial ability to file a motion and fly in for a
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hearing. Therefore, I diligently pursued what I was capable of and in a timely
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manner filed the Motion to Vacate within two months of returning to Los
Angeles County.
5.
When I originally moved to Los Angeles at some point around early
1990, Leonard Cohen was focused on his 1993 studio album The Future. My
relationship with Douglas Penick quickly fell apart (primarily due to the fact
that he despised Los Angeles, and we separated and later divorced). At some
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point, Leonard Cohen introduced me to his record producer, Steve Lindsey, and
we ultimately ended up together and have a son, Ray Charles Lindsey. For
approximately two years, my family and I lived one block from Leonard Cohens
mid-Wilshire home and we became quite close in terms of our business
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relationship and socially. At this time, Cohen was engaged to actress Rebecca
DeMornay. In the winter of 1992, due to Lindseys concerns about the Los
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Angeles riots, our family moved from the mid-Wilshire area and leased a house
on Mandeville Canyon Road in Brentwood, California. I then maintained the
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lease on our former premises and moved my management company offices
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there. It was around this time that Leonard Cohen and I entered into a new
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agreement with respect to my services as his personal manager. That

agreement included, but was not limited to, paying me the proper commission
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for my services as his personal manager (15%) and compensating me with 15%
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of all intellectual property. Everything was relatively congenial during this
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period of time. Leonard Cohens daughter, Lorca Cohen, was frequently at my
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home for dinner and I frequently helped her with homework; drove her, my step
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daughter, and son to and from their respective schools; and the situation was
all rather familial.
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The next several years were quite busy. In 1993, Leonard Cohen
delivered The Future album and undertook a world tour. In 1994, Cohen
released his book of selected poems and songs, Stranger Music: Selected
Poems and Songs. Following that release, Cohen participated in a selective

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book tour. At some point in 1994, Cohen felt he had been drinking too much
and needed a place he could spend time focused on his music, art, and literary
works, in an environment that provided solitude, discipline, and allowed him to
live a relatively independent life. Cohen was provided with a two-cabin suite at
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the Mt. Baldy Zen Center. From approximately 1994 through 1998, Leonard
Cohen spent time on Mt. Baldy which is located approximately 45 minutes from
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Los Angeles. He was also frequently in Los Angeles where he maintained a

home. In 1996, Leonard Cohen was ordained as a Buddhist monk but that
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seemed to be more of a formality than any type of actual religious vow.
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Leonard Cohen was not, contrary to the allegations in his Complaint, in a
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rigorous retreat during his Mt. Baldy phase. He worked on his musical,
literary, and artwork projects; gave quite a number of interviews; participated
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in the filming of a documentary; recorded at least two new songs; oversaw the
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compilation and production of at least one live album; began regularly
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communicating with a fan site, the Leonard Cohen Files, which he viewed as a
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critical marketing tool; and was frequently in Los Angeles staying in his home
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which was located one block from my office. Cohen and his daughter, Lorca
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Cohen, both had keys to my office and Cohen personally spent time alone there
during evenings and weekends because that is where the color copier was kept
and it gave him the quiet opportunity to review his business, personal, and fan
correspondence and materials.

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At some point in 1994, His Holiness Kusum Lingpa, a Tibetan lama,
visited Los Angeles. It was through this visit that I met Oliver Stone.
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Eventually Oliver Stone and I sponsored a Los Angeles Buddhist center for His
Holiness which was located downstairs from my personal management office. I
became quite friendly with Mr. Stone, we got to know one anothers families,
and spent a considerable amount of time together. Oliver Stone released
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Natural Born Killers in 1994. Three of Leonard Cohens songs were included
in the soundtrack bringing quite a bit of attention to Cohen in the United States
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where he previously had a relatively limited audience. At some point in or

around late 2004, or early 2005, Leonard Cohen and his lawyer would falsely
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accuse me of having sex with Oliver Stone in a blatant attempt to stir up a
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custody matter with my younger sons father.
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8.
In or around 1994, Leonard Cohen understood that many major
music publishing deals were being entered into throughout the industry. In
1995, David Bowie had entered into a highly publicized $50 million bond
securitization deal with David Pullman of the Pullman Group. This deal became
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known as the Bowie Bond and Cohen, together with his representatives,
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fervently pursued a similar type of deal. Cohen would now like to change
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history by alleging that he was misled into pursuing these deals; was led to
believe he had less royalty income than he actually did; and has replaced the
facts of what actually unfolded with an entirely fabricated, self-serving
narrative. Cohen has taken the position that he was not actively involved in
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either the first (1996) intellectual property deal with Sony/ATV or the second
(2001) intellectual property deal with Sony. The actual facts and evidence
prove that he was intimately involved with these deals and was the driving
force behind them and the reason for the unnecessarily complex structures,
stock sales, and problematic tax issues. It seems highly improbable that
anyone would go to such lengths to create this mess when it would have been
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so much easier to simply sell the assets. This would have attracted more
potential buyers, brought in a considerably high sales price, and the fees
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generated by the deals would have been far greater. The complex structures
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and tax planning were conjured up for the sole benefit of Leonard Cohen. The
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purpose of these structures was to find a way for Leonard Cohen to avoid
paying ordinary income taxes. This has apparently been an issue for Cohen
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since at least 1977 when a tax memo was prepared for him that took the
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position that, although Cohen had residences in the U.S. and Canada, he was
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not obligated to pay taxes in either country and encouraged him to funnel
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income into off-shore accounts.
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9.
In 1995, the tribute album Tower of Songs: The Songs of Leonard
Cohen was released by A&M Records. Cohen was actively involved in this
project and provided numerous interviews to the news media. He also had me
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phone Chris Doritos, KCRW, in 1997 to arrange an interview related to the

various tribute albums that had been released. I had received a number of
tribute albums in the mail and Cohen thought it would be interesting to give an
interview about them. In this interview Cohen confirms that his son, Adam
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Cohen just signed a record deal. That is part of the income I used (with a
pension fund I had) to purchase my home in Brentwood, California. Cohen has
advised a number of people, including Steven Machat, that I bought my home
with his money. That is blatantly false. I, together with an attorney, also
negotiated a substantial publishing deal for Adam Cohen in 1997. I also

conceived of and worked as co-executive producer on the tribute album. This
interview is quite revealing on a number of fronts.
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Excerpt Interview with Leonard Cohen, KCRW, February 18, 1997:

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Chris Doritos: Leonard Cohen released his first album by Christmas that year,
1967, Songs of Leonard Cohen. Since then he has released 11 albums of songs
and they have been covered over the years by Jennifer Warrens, REM, Peter
Gabriel, U2's Bono, Nick Cave, Diana Ross [goes on], this is just to name a few.
And we recently just heard from Leonard and we heard about a couple of new
tribute albums one from The Czech Republic and one from Spain a Flamenco
tribute album, and that now makes what six tribute albums in all the other ones
being Jennifer Warrens, I'm Your Fan, A Norwegian Tribute album, and Tower
of Song a collection of performances by [the names of some of the artists].
1990's Trouser Press, which is sort of like the bible of mainstream rock
lamented that: " Leonard is better known from usually inferior versions of his
songs." Well, we'll get Leonard's take as he joins us this hour on KCRW's
Morning Becomes Eclectic, right now it's Bono's version of Hallelujah.
[song: Hallelujah by Bono from "Tower of Song tribute album"]
Chris: - That's Hallelujah originally found on the Leonard's album Various
Positions release 1984 Columbia records. That's a version from Bono of U2
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taken from Tower of Song, a Tribute album, of course a tribute to the writings
of Leonard. I'm Chris Doritos on Morning Becomes Eclectic KCRW happy to
have in the studio, Leonard, welcome. [some minor technical difficulties]
Chris: - welcome back.
Leonard: Thanks for having me down, I appreciate it.
Chris: - It's good to have you here. I was startled when I got the phone call from
Kelley at your office. She says, "yeah we got these wild tribute albums. One
from the Czech Republic and one from Spain." These just landed in your
mailbox?
Leonard: yeah, they landed in the mailbox. And I was very impressed by the
performances and the treatment and I thought who can I turn to, to let people
hear this. Because these records are not readily available, or even available at
all, here in America. So I thought I'd like people to hear them.
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Chris: I see. Have you been writing lately?
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Leonard: Yes Ive been blackening pages, here and there, and scratching away.
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Chris: The reason I ask is because I was curious when we might get another
studio album from you.
Leonard: Ive been getting the same interest from the record company.
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Chris: Thats good, thats a positive sign.
Leonard: There is no special time or date for it. Its gonna take a while.
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Chris: It is gonna take a while.

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Leonard: Im just finishing a book now. Ive been concentrating on that for the
past few months.
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Chris: Is there anything you could tell us about it, at this point.
Leonard: Oh, its just a collection pieces over the past few years.
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Chris: I see. So are they new writings?
Leonard: New writings.

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Chris: They are new writings. The last studio album was the Future from
1992. It actually had a couple of songs on there that you didnt write; that were
cover versions.
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Chris: I should also point out that your son, Adam

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Cohen: Oh, my son does beautiful work. He is the real thing. He really knows
how to sing.
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Chris: He just recently got a record deal.
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Cohen: Yes, he signed with Sony and he is in the midst of recording now. Hes
written some very very beautiful songs.
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http://www.leonardcohenfiles.com/kcwr.html
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10.
In 1996, Armelle Brusq produced a documentary called Spring
1996. The film described the daily routing of the Zen monks at Mt. Baldy Zen
Center. Cohen is featured in the film and his cabin with his Technics KN 3000
synthesizer and computers are shown. He sings verses from his new song A
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Thousand Kisses Deep and recites three unpublished poems. The
documentary also shows Lynchs management office when Cohen visits with the
film maker. Spring 1996 also contains footage of Cohen in the recording studio,
working with his sound engineer and violinist, and then heading off with the
film maker to dine at Canters. The film ends with the song Never Any Good
which Cohen was recording for an upcoming live album. Leonard Cohen was
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not in a rigorous religious retreat; used Mt. Baldy as an opportunity to focus on

writing; and spent considerable amounts of time in Los Angeles with his
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daughter, Lynch, at Rinzai-Ji Zen Center, and in the recording studio. Cohen
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evidently felt that highlighting the time spent at a formal religious retreat,
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where he was absolutely viewed as a patron, would work best with his
rescission argument. The following You Tube links, which the Court should
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review, give an overview of Cohens cabin at Mt. Baldy, some of the material he
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was working on at the time, and his frequent trips to Los Angeles, California
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and my office. The interview footage, with Cohen in front of a white wall, was
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filmed in the office I provided Cohen in my management offices. The other
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footage of Cohen in his robes, in his office (which was provided as a courtesy to
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this individual), shows the boxes of archival materials (a great number of items
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from these materials appeared in Cohens related case matter) Cohen and his
daughter removed from my offices with every one of my personal business files.
Leonard Cohen - A Thousand Kisses Deep - 1996 Demo
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Scene from the French documentary "Leonard Cohen Spring 96", shot in
Leonard Cohen's cabin at Mt. Baldy Zen monastery by Armelle Brusq. Leonard
Cohen is recording song A Thousand Kisses Deep, using Technics KN 3000
synthesizer. The track is apparently an early, demo version to different lyrics
and complete different melody than one composed in collaboration with Sharon
Robinson, for 2001 album Ten New Songs. Also, the poem included in the 2006
Book of Longing, recited during 2008 Tour, doesn't have some of lyrics from
this demo.
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https://www.youtube.com/watch?v=ko7Pyz55ziU
Leonard Cohen on Mt. Baldy
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Video of Leonard on Mount Baldy. This was filmed in 1996 and it documents
Leonard's experiences and routine while at Mt. Baldy. I believe this "film" was
shot by a French artist named Armelle Brusq.
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https://www.youtube.com/watch?v=HJuJQI0RMiw
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11.
From 1996 until approximately 2001, I also worked as Adam
Cohens personal manager. Adam Cohen is Leonard Cohens son.

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12.
In late 1996, Bob Hilburn interviewed Leonard Cohen about the
Tower of Song tribute album. At the time, Mr. Hilburn, who personally met
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with Cohen on Mt. Baldy, confirmed: The 61-year-old songwriter and poet
hasn't turned his back on the world. He frequently heads down the mountain to
Los Angeles in his four-wheel-drive vehicle, either to visit an affiliated Zen
center, to visit his daughter in the Mid-Wilshire area or meet with Kelley Lynch,
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his manager. Leonard Cohen frequently gave interviews from Mt. Baldy and in
this case agreed to meet with Mr. Hilburn to talk about the tribute album that
will be released Tuesday by A&M Records. The collection, titled "Tower of
Song: The Songs of Leonard Cohen," features versions of his works by such
artists as Bono of U2, Peter Gabriel, Elton John, Willie Nelson, Sting, Billy Joel,
Aaron Neville, Tori Amos and Trisha Yearwood. Bob Hilburn also confirmed
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some of the projects Cohen was working on at that time: Cohen has plenty of
time here to devote to his writing. At present, he's working on an illustrated
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book of poems and songs for a future album. His workroom contains a primitive
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Macintosh computer and a synthesizer, tools for his music and his graphic art.
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There is also a radio in the room but no CD or cassette player. He has to go out
to his vehicle to play a CD. Exhibit A: Robert Hilburn Article; photo of Cohen
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working at Mt. Baldy.

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13.
In 1997, during his Mt. Baldy phase, Cohen oversaw the selection
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and release of More Best of Leonard Cohen album, which included the track,
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Never Any Good, and an experimental piece

The Great Event.
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14.
At some point in or around 1998, Cohen more or less left Mt. Baldy.
In 2001, he released his studio album Ten New Songs in 2001. In October
2004, Cohen released his studio album Dear Heather. Cohen's book of
poetry and drawings, Book of Longing, was published in May 2006. These
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projects were the focus of much of Cohens energy during his Mt. Baldy phase.
At no point did Leonard Cohen and I cease communicating; we spoke and saw
one another regularly; and he was not only kept apprised of the status of the
deals he demanded, he micro-managed them. This is not the image Cohen has
attempted to cultivate throughout his legal adventures.

BACKGROUND
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15.
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As stated above, I did not reside in Los Angeles from approximately
the fall of 2006 through June 2013 apart from an extended visit with my son
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and during the period of time when I was incarcerated from approximately
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March 2012 through September 2012. During my 2010 visit with my son, I took
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a temporary position with a paralegal group in Santa Monica, California. While

I began researching the issues related to a motion to vacate, I was not in Los
Angeles long enough to fully research, write, or file the document. I was also
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viciously attacked when I made my intentions a matter of public record. In
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fact, Leonard Cohens fan, Susanne Walsh, a Bay Area lawyer, Stephen Gianelli,
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and others seemed to intensify their harassment, stalking, and intimidation of
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my relatives, friends, and others. These individuals, and others, have engaged
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in what is clearly a highly coordinated campaign of harassment and slander

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meant to discredit me, discourage me from seeking legal remedies, and

intimidate people in my life. The activity continues to this day and the issues
relate to Leonard Cohen, slandering me, intimidating my witnesses, IRS and tax
fraud, and Phil Spector.

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I have attached an email and documents the Boulder Combined
Court sent me on or about April 10, 2014. The Court confirmed that their order
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was not a domestic violence order and their computer print-out (and
conversations Ive had with the Court) revealed that employees who reviewed
their computer data when speaking with me (or others) interpreted the
information incorrectly when they advised me that the order expired on
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February 15, 2009. Evidently the temporary order, which was vacated on
September 2, 2008, expired on February 15, 2009. The reason this information
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is relevant here, apart from the use of restraining orders as litigation tactics, is
due to the fact that Robert Kory and Michelle Rice provided this Court with
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copies of their domestic violence related restraining orders (granted without
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a hearing) which were evidently issued with the assistance of the City
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Attorney's Family Violence Unit. The Boulder Combined Court stated

unequivocally that This case is not a domestic violence case which can be
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verified on the top right of the first page of the ICON; noted as "Type:
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Protection Order". On the motion for civil protection order, the Petitioner only
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checked off Stalking and Physical Assault, Threat, or Other Situation but not
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Domestic Abuse. On of Leonard Cohens concerns, when applying for this
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order, had to do with my online posts refuting appalling slander as well as my

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communications with third parties such as IRS, FBI, DOJ, and Dennis Riordan.
Exhibit B: Boulder Combined Court email and attached evidence; Kory & Rice
domestic violence related orders.
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One of the issues this declaration addresses relates to Leonard
Cohens tactics. Those tactics have included the use of fraudulent restraining
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orders; coercion; the use of my sons as weapons; strong arm negotiating

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tactics; slanderous and defamatory allegations; lack of service; refusal of an
endless stream of lawyers to communicate with me; entrapment techniques;
perjured testimony and statements; and what appear to be operatives who have
targeted nearly everyone in my life past, present, and possibly future. My
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roommate, Paulette Brandt, I, and many others (including both of my sons and
sister) have been relentlessly harassed over issues relating to Leonard Cohen,
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this case, and federal tax matters. The harassment continues to this very day.
This is some of the background to the situation at hand.
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I have encountered numerous confusing and misleading situations
and statements with Los Angeles Superior Court. Those issues include, but are
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not limited to, being advised not to file a proof of service until after a new judge
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was appointed and a date set for a hearing on the motion; being advised that
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this Court does not accept CourtCall; being advised that, given the fact that I
filed my motion, I simply had to show up at the hearing with witnesses; and
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spending nearly two years attempting to obtain a transcript of the March 23,
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2012 bail hearing (Case No. 2CA94539-01). That case also involves a situation
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with respect to me and Leonard Cohen. I have been repeatedly advised (by
both LA Superior Court and the Court Reporters Office) that, due to the fact
that Judge Mayerson retired, a transcript was no longer available; due to the
fact that he no longer has a department with LA Superior Court, it is impossible

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to order a transcript; misdemeanor hearings are not recorded; misdemeanor
hearings are recorded but no one knows where the tapes are located; and other
variations on this general theme. Paulette Brandt and I were then surprised
when Judge Mayerson prevailed over a hearing in a matter related to the
domestic violence orders. On or about June 17, 2014, after advising the
individual at LA Superior Court that I would complain to the chief judge of Los
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Angeles Superior Court over the situation, I was referred to Rosalina Nava.
Ms. Nava was kind enough to provide me with the court reporters name and
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number and I was finally able to order a transcript of the March 23, 2012 bail
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hearing. On August 14, 2014, I received a copy of that transcript from Annette
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Van Olden. This hearing was important for a number of reasons.
Exhibit C:
Emails with court reporters re. March 23, 2012 hearing transcript.
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This transcript is of great importance due to the fact that Leonard
Cohen testified, when asked if I ever stole from him, with the words just my
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peace of mind. I have attached hereto a MacLeans article dated August 22,
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2005. This was publishing approximately one week after Cohen filed the
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Complaint in the instant matter. Cohen is quoted extensively in this article;
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posed for photographs; and provided the journalist (an awe inspired fan really)
20
with some of the emails he sent his financial adviser, Neal Greenberg. I
1
2
suppose Cohen may also have provided MacLeans with my photograph which
is included as well. At the end of the article, Brian Johnston includes this
interview with Cohen. Cohen had evidently contacted Johnson months earlier
in an email, and while dining with Johnson, explained that he had been stripped
4
of most of his assets, and was mired in a legal battle with his money managers,
who would excuse him of extortion. He said it would get nasty and personal,
and that his name would be dragged through the mud. Johnson found
Greenbergs lawsuit amusing from what I can tell. I can assure this Court that I
did not. It is important to note that Cohen must have provided Johnson with
Steve Lindseys information as he is quoted and lied about my being suicidal.
9
10
But what is most telling is Cohens comment that he was not accusing me of
theft. Cohen moved offensively in the news media and had to defend himself
11
against Greenbergs allegations and, no doubt, anticipated that something
12
might unfold after I reported the allegations that he committed criminal tax
13
fraud to Internal Revenue Service on April 15, 2005 and provided IRS with an
abundance of evidence. This article sets forth Leonard Cohens fabricated
14
fantastical narrative that is in no way, shape, or form supported by the evidence

15
or the facts. Exhibit C-1: MacLeans article. August 22, 2005.
16
20.
17
The March 23, 2012 hearing transcript is of great importance.
First, one of the individuals in the courtroom was an investigator with District
18
Attorney Steve Cooleys office. During my 2012 trial, Steve Cooley, prosecutor
19
Alan Jackson, appellate attorney Dennis Riordan, and Phil Spector were
20
constant themes. In fact, the prosecutor elicited testimony about Phil Spector
1
2
and a gun from witness Leonard Cohen. I do not believe this situation was
merely coincidental given the fact that the District Attorneys Office presented
a version of Leonard Cohens gun story in their Motion in Limine (Case No.
BA255233) in an attempt to introduce prior bad acts against Phil Spector. This
4
particular version of Leonard Cohens good rock n roll gun story about Phil
Spector involves Mr. Spector pointing a semi-automatic pistol at Cohens
chest. Mick Brown, UK Telegraph, has advised me that Cohens testimony or
statements were presented to the Grand Jury in the Spector case. Exhibit D:
Phil Spector Motion in Limine (Excerpted pages Leonard Cohen gun incident);
Mick Brown emails.
9
10
21.
While this information may seem tangential, it is not. As Ive stated
above, Phil Spector was a constant theme during my 2012 trial. Leonard Cohen
11
12
testified about Phil Spector. His testimony contradicts the statements used by
the prosecutors in the Phil Spector matter. Leonard Cohen evidently was not
13
afraid when Phil Spector allegedly held a gun to his head but fears for his life
14
over my alleged emails that LAPDs report describes as generally being
15
requests for tax information. Leonard Cohen testified during my trial that Phil
Spector held a gun to his head and was absolutely certain that the weapon was
16
an automatic. Perhaps that, in and of itself, is not problematic however, on

17
April 5, 2012, at the outset of my trial, Leonard Cohen wrote to the prosecutor
18
and included a version of his highly embellished Phil Spector gun story that, in
19
this telling, involved Mr. Spector pressing an automatic into Cohens neck.
20
This testimony, and the three separate versions of a gun incident involving Mr.
1
2
Spector, is material to this matter because it shows that Leonard Cohen has a
pattern and practice of changing stories, adding details, and fabricating
narratives. What makes this testimony so disturbing is the fact that for 20
years Leonard Cohen told me Phil Spector never held a gun on him and
4
5
6
7
8
9
10
11
12
13
14
continually advised me that his stories about Spector were good rock n roll
stories. Exhibit E: Trial Transcript (RT 308-309).
PD: Now, I want to talk to you about what you mean by threatened. You
actually -- you were telling us about Phil Spector. You were testifying about
talking to the LAPD. Cohen: Yes, Sir. PD: And you talked to the LAPD with
your attorney, correct? Cohen: With an attorney present, yes, Sir. PD: And
thats when you asked that or your attorney someone asked that Ms. Lynch
leave? Cohen: The attorney asked that Ms. Lynch leave. PD: So when Ms.
Lynch left, you started talking about an interview or story about Phil Spector,
correct? Cohen: Correct. PD: And how he would oftentimes have guns when
you were producing an album, correct? He would have guns in the studio when
he was producing an album with you? Cohen: Thats correct. PD: And, in fact,
one time you told the detective that, quote Well, before I go there, was Mr.
Spector -- was he drunk at the time when he had these guns? Cohen: I dont
remember, Sir. PD: Was he hostile at the time? Cohen: Not to me. PD:
Okay. But he actually put a gun to your head? Is that correct? Cohen:
Thats correct. PD: It was a revolver? Cohen: No, it wasnt a revolver. It
was an automatic. PD: But you werent actually -- you didnt feel threatened
when he put a gun to your head? Cohen: No, Sir. RT 308-309
15
16
22.
Leonard Cohen was a witness at the March 23, 2012 trial. He
perjured himself when he testified that I was his business manager. (RT 8)
17
There is a huge distinction between a personal manager and business manager
18
and I was the former. For approximately 17 years, I worked as Leonard
19
Cohens personal manager. Leonard Cohen testified that We have three
20
restraining orders against Ms. Lynch. (RT8) I am completely unaware of the

1
2
allegations made in connection with the 2005 restraining order matter. I did
not attend the hearing, Cohen and his lawyers refuse to provide me with any
documents, and I am unaware of the allegations made. I was present at the
2008 hearing in Boulder; personally asked the judge to make that order
4
permanent; and after the hearing discovered the excessive fraud and perjury in
the declaration Cohen provided the Court when applying for the TRO. Cohen
could not be bothered to attend the hearing and simply sent his
lawyer/witnesses, Robert Kory and Michelle Rice, in his stead. While I did ask
the judge to make the order permanent (a rather confusing word given the
fact that it has different meanings in different jurisdictions and some of the
9
10
permanent orders actually expire), have no arguments about service issues

(apart from the revolting fact that the process server ran around Boulder,
11
Colorado advising people that he had a check for my sons accident where his
12
fingers were ripped off), advised the judge that I found the situation insane, and
13
most certainly did not agree to an order of any sort that was based on fraud
and perjury which I did not discover until after I reviewed the court file
14
following the hearing and discovered Leonard Cohens startling declaration. As

15
for the third order, Cohen is evidently addressing the registration of the foreign
16
Boulder, Colorado order with LA Superior Court on May 25, 2011. I believe
17
that is in fact a new order. That order is at issue and somehow transformed
18
into a domestic violence order although Leonard Cohen and I were never in
19
an intimate dating or engagement relationship and the Boulder, Colorado

order was not a domestic violence order. Natural Wealths June 2005
20
1
2
3
4
Complaint addressed the fact that Cohen planned to use restraining orders to
discredit me and prevent me from serving as a credible witness.
23.
What Leonard Cohen has failed to address is the fact that his
representatives refused to communicate with me during the litigation in this

matter; other matters; and both he and his representatives refuse to provide
me with IRS required tax and corporate information and are using the
6
restraining order to argue that it prevents them from transmitting IRS required
tax information and effecting service on certain Cohen representatives who also
serve as witnesses and happen to be the registered agent for one of the
Plaintiffs, LC Investments, LLC. At the March 23, 2012 hearing, Cohen
10
confirmed that his email address is baldymonk@aol.com. (RT 10) This will
become relevant with respect to evidence submitted with this motion and
11
12
declaration. Cohen concealed the fact that I repeatedly contacted him to

request IRS required tax and corporation information. I was unaware of the
13
fact that he and his legal representatives had taken the position that, not only
14
do the restraining orders interfere with the transmission of federal tax
15
documents, but the default judgment in this matter absolves Leonard Cohens
obligation to provide me with tax information for the years 2004 and 2005. The
16
prosecution also essentially printed out the same email over and over again to
17
ensure that their binders looked thick. One issue that annoyed Leonard Cohen,
18
according to his testimony, is his own desire to die by firing squad (RT 18). At
19
least thats what he told me since approximately 1989 when he was interviewed
20
for Rolling Stone Magazine by Mikal Gilmore. Mr. Gilmores brother was
1
2
executed by firing squad in the United States and this somehow struck Cohens
fancy because for the next 15 years or so, he continuously advised me that he
would like to die by firing squad and furnished details such as what his last
meal would be, the fact that he would have a cigarette, etc. Another issue that
4
annoyed Leonard Cohen is my parody email regarding former DA Steve Cooley
(RT 18). I am not all that clear as to why any comment of mine with respect to
Steve Cooley would cause Leonard Cohen to live in a state of fear but Ive
given up trying to figure it out. The repeated references to Steve Cooley by
Leonard Cohen are one of the reasons I do feel this might be a very material
issue. At one point during the March 23, 2012 hearing, Cohen was asked Are
9
10
you aware that Ms. Lynch is involved in some sort of a tax proceeding with the
IRS and he answers that he understands she failed to file. (RT 20) I have not
11
failed to file my tax returns. Leonard Cohen refuses to provide me with the
12
information I have been requesting for approximately 10 straight years now. I
13
evidently have to file a lawsuit to obtain IRS required tax and corporate
information. I am not involved in a tax proceeding of any sort. On April 15,
14
2005, I reported allegations that Leonard Cohen committed criminal tax fraud
15
to Internal Revenue Service. During the March 23, 2012 hearing, Cohen is
16
asked when the last time he saw me was and he acknowledged that he hasnt
17
seen me since 2004. He is then asked the following questions: Q: Has she
18
vandalized any of your property during that time? Cohen: No. Q: Or stolen
19
anything? Cohen: Just my peace of mind. (RT 20) Leonard Cohen has
accused me of misappropriating over $5 million and his answer to a question
20
1
2
about my stealing from him is essentially no just his peace of mind. I would
like to point out that the expense ledger includes alleged misappropriations
for the year 2004 and Leonard Cohen is exceedingly aware of the default
judgment and forensic accounting used to support that judgment. Therefore,

4
it is truly impossible that he might have misunderstood the question and felt my
lawyer was asking him if he thought I may have stolen a potted plant, or
something similar, from his front porch. On a final note, with respect to the
March 23, 2012 hearing, Cohen was asked if I was employed by him as a
business manager. Cohen answers correct although I was not. He is then

asked Was that the extent of your relationship? and his answer was Yes, Sir.
9
10
(RT 20). I believe it is important for this Court to take note of Cohens
contradictory testimony, blatant lies, and self-serving fraudulent
11
misrepresentations. I have only addressed the more extreme examples in these
12
documents. Exhibit F: Transcript March 23, Hearing. Cohen changed his
13
14
15
16
17
18
19
20
testimony during my 2012 trial over the relationship issue:

PD: Okay. Now, you also mentioned earlier that there was a brief intimate
relationship between you and Ms. Lynch, correct? Cohen: Thats
correct. PD: You wouldnt say that that was probably the best idea, to have a
romantic relationship with your business partner, correct? Streeter: Objection;
relevance. Court: Overruled. Cohen: I dont think it goes to the description of
romantic. PD: But it was a sexual relationship, correct? Cohen: It was an
intimate relationship, yes. PD: Was it a sexual relationship? Cohen: It
involved a sexual -- yes. PD: Now, it was - It was actually spanning years,
correct? Cohen: Im sorry? PD: It actually spanned years, correct? Cohen: I
dont know how long it spanned, Sir. PD: Okay. But you would agree with me
that it was on and off for a period of time? Cohen: Yes, Sir. PD: Now why did
that that part of the relationship, what you called the intimate part of the
relationship, why did that end or when did it end? Court: Those are two
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
different questions. PD: Ill go with the latter. PD: When did it end? Cohen: I
dont remember exactly when it ended. Like many relationships, it -- it just
dissolved. PD: But its fair to say that it ended before your business
relationship ended, correct? Cohen: Thats correct. PD: Okay. And do you
know why it ended? Cohen: I would say that part of the relationship exhausted
itself and dissolved naturally. RT 276 PD: Okay. Do you remember testifying
on March 23rd at another hearing? Cohen: March 23rd, yes. PD: Of this year.
You were in this courthouse testifying, correct? Cohen: That is correct. PD:
Now, you were asked if this was -- if your relationship with Ms. Lynch was
purely a business relationship. Do you remember that? Cohen: I did. PD: And
you actually said that it was, yes, purely a business relationship. Cohen: I have
said repeatedly that there was an intimate relationship, but the lady denies it.
So I did not want to insist. PD: Im not asking you about what Ms. Lynch said.
Im asking about what you said. You said that yes, that it was purely a
business relationship, correct? Cohen: May I explain. PD: Im just asking for
if thats what you said on March 23rd. Cohen: Yes. PD: In fact, you were
asked a follow up question that -- asking you if that was the extent of it, and
again you said yes, that was the extent of it, correct? Cohen: Correct. RT 273277
PD: When you testified on March 23rd, you said that -- you didnt give the same
answer that you gave now, correct, regarding your relationship with Ms.
Lynch? Cohen: Thats correct. PD: Okay. But you -- when you did testify, you
stood in front of the counsel table, you raised your right hand, correct? Cohen:
Correct. PD: You swore to tell the truth, the whole truth? Cohen: Correct.
Kelly: And then the same oath that you just took right now, correct? Before
testifying, correct? Cohen: Correct. PD: Okay. And you understand that you
were under the penalty of perjury on March 23rd? Streeter: Objection;
argumentative. Court: Sustained. Kelly: Nothing further. RT 321-322
16
17
23.
Leonard Cohen has a pattern of falsely accusing his
representatives; stealing from them; and, withholding commissions due them.

18
This identical situation occurred with his former managers, Machat & Machat.
19
Marty Machat, as Ive said, passed away in April 1988. Leonard Cohen
20
1
2
personally removed the corporate records from Mr. Machats office and after he
and I parted ways, I discovered a very relevant letter. Marty Machats letter to
Cannon Carter of Irving Trust Company dated November 25, 1970 confirmed
that Stranger music was owned by Leonard Cohen (70%), 15% by Machat &
4
Machat, and allegedly record producer Bob Johnston had a 15% ownership
interest. A spreadsheet created at the time of the Stranger Music, Inc. sale to
Sony shows prior owners of this entity limited to Leonard Cohen and his former
managers, Mary Martin and Judith Berger. It then shows Leonard Cohen and
his two charitable remainder trusts as the owners of the asset. It fails to show
the ownership interests of Machat & Machat or Bob Johnston. This company
9
10
owned the intellectual property related to Leonard Cohens music publishing

catalogue. Immediately after Mr. Machats death, Leonard Cohens attorney
11
and I negotiated to buy back the rights to Suzanne and two other songs
12
which were then assigned to Stranger Music, Inc. The Complaint in this matter
13
alleges that Leonard Cohen Stranger Music, Inc. (as the company came to be
known when it registered to do business in California) was wholly owned by
14
Leonard Cohen. That allegation is contradicted by Marty Machats letter to

15
Irving Trust Company. This is extremely relevant because it proves that, time
16
and time again, Leonard Cohen conceals information, breaches contracts,
17
falsely accuses others of misrepresenting him, and seems to steal from people.
18
It also may be evidence that proves Leonard Cohen removed corporate records
19
from Marty Machats office, after his death, and sanitized the files and
20
1
2
3
4
corporate records intentionally. Exhibit G: Marty Machat letter dated

November 25, 1990; Stranger Music, Inc. Spreadsheet.
24.
On January 5, 1972, Berger, Berger & Beal (Cohens prior
managers) transmitted a letter and enclosures to Marty Machat regarding

Stranger Music, Inc. The letter acknowledged receipt of full payment in
accordance with the terms of the Stock Purchase Agreement dated May 28,
6
1970 between Stranger Music., Inc., as buyer, and Mary Martin and E. Judith
Berger, as sellers. Enclosed with this letter were the stock shares owned by
Mary Martin; stock shares owned by E. Judith Berger, Security assignments for
the 36 compositions; reassignment to Stranger Music, Inc., of the said 36
10
compositions. The list of 36 compositions is attached to this letter. It is

relevant to note that for years Leonard Cohen has publicly stated that his first
11
12
managers, Berger & Martin, stole the copyrights to Suzanne, Dress

Rehearsal Rag, and Song of Isaac. These three songs do not appear on the
13
assignment list transmitted, with the actual assignments, to Mr. Machat. After
14
Marty Machats death, Cohens transaction lawyer and I negotiated the
15
purchase of those three songs on behalf of Cohen and at no time was there
evidence that these copyrights were ever stolen. Steven Machat, in his book
16
Gods, Gangsters, confirms that Cohen, falsely accused Berger & Marti of
17
ripping him off. Steven Machat is not merely a bystander with a casual opinion,
18
his father and he worked as Cohens managers and attorneys and negotiated
19
many deals on Cohens behalf for a period of nearly 20 years. Exhibit H:
20
Berger, Berger & Beal letter to Marty Machat dated January 5, 1972.
1
2
26.
Steven Machat and his father worked as Cohens personal
managers and attorneys until Marty Machats death in April 1988. Steven
Machat is familiar with the early deals; he and Marty Machat had the same
compensation agreement with Cohen that I had; and, Cohen allegedly stole
4
their share of intellectual property, refused to pay them commissions due, and
stopped paying royalty payments related to the song When I Need You.
Steven Machats comments about Leonard Cohen are extremely material:
Leonard was desperate to get rid of this two managers, Judy Berger and Mary
Martin, who he believed had stolen the rights to his songs and records early on
in his career. Even back then, Cohen was convinced that women were ripping
9
10
him off. He signed an agreement, and when he wanted to get rid of the
contract, he accused everyone of ripping him off. You could say it became
11
repeat behaviour. My father duly got rid of Berger and Martin, set up a new
12
company called Stranger Music for Cohen and agreed to manage Leonard for
13
15% as well as 15% of Stranger. The idea of the company was twofold: one, to
maintain ownership of the copyrights duly created; and two, to minimise
14
Leonards exposure to American tax, just like any other rich individual trying to
15
16
17
minimise their tax liabilities. Exhibit I: Email to Steven Machat dated March
2, 2015 confirming book excerpts.
27.
When Marty Machat was ill, Herschel Weinberg sent a letter
18
advising Mr. Machat to release all of Leonard Cohens files to him. I spoke to
19
Mr. Machat about this letter and he told me to release all of the files to Cohen
20
and did not believe it was necessary to copy the files. Phil Spector also
1
2
requested that his files be returned and Mr. Machat confirmed that they should
be shipped to Mr. Spector in California. Other individuals were equally
concerned about their personal files and the situation was quite overwhelming
and very upsetting. Leonard Cohen personally flew into New York to meet with
4
Marty Machat and his companion, Avril Giacabbi privately. He was also
meeting with Herschel Weinberg. At one point, Cohen advised me that Marty
Machat stole his $400,000 advance on Im Your Man. I was present when Mr.
Machat returned from Sony, after picking the check up, and recalled that he
told me he stopped at Bankers Trust and deposited the check into his attorney
escrow account. Cohen then phoned Avril Giacobbi who confirmed with
9
10
Charles Aaron, Bankers Trust, that this was precisely what had occurred.
Cohen didnt say much and, due to the extreme confusion and drama
11
surrounding the situation leading up to Marty Machats death, I didnt think too
12
much about the allegation. During this period, Leonard Cohen came into Marty
13
Machats suite of offices and wanted to enter his personal office. While I
normally had the keys to Marty Machats office, and was advised to permit
14
Cohen to enter and relax when he was in New York, I had recently gone to
15
Martys 5th Avenue apartment, picked him up with a car service, helped him
16
into the office (because he was quite weak from the cancer), and accompanied
17
him back to our offices. After Marty finished whatever he was working on, I
18
accompanied him back to his apartment, visited with him for a while, and
19
inadvertently left the key to his office in his apartment. I, therefore, did not
have access to Mr. Machats office. Leonard Cohen instructed me to call Marty
20
1
2
to ask if it would be all right for him to hire a locksmith to open the door to let
him in. Marty had no problem with that request and I called a locksmith who
came by shortly thereafter. Leonard Cohen then entered Mr. Machats office by
himself. I did not enter Mr. Machats office with Cohen and sometime later he
4
exited the office. I do not recall what, if anything, he took with him. I do recall
his advising me that he was going to see Herschel Weinberg and then stop by
Martys apartment for a visit. He said he had some paperwork to review with
Marty.
8
9
10
11
12
28.
At this time, Cohen also advised me that he had an account in the
Netherlands. He asked me to find the phone number for New Era, BV on my

rolodex which I did and wrote it down for him.
29.
After Cohen resolved whatever matters he and Herschel Weinberg,
Charlie Aarons of Bankers Trust, and Marty Machat were addressing, he left
town. He did not return for Mr. Machats funeral in April 1988. Cohen asked if
13
14
I would be willing to replace Marty Machat as his manager. I was somewhat

conflicted due to the fact that Steven Machat offered to keep me on for a spell.
15
Steven Machat and I became quite close during the period leading up to his
16
fathers death and I liked the idea of working for him very much. However, due
17
to the drama that was occurring with respect to Avril Giacobbi and others, I
concluded that I simply did not want to be caught up in the middle. After the
18
day of Marty Machats funeral, I never again spoke with Avril Giacobbi due to
19
her conduct leading up to his death. Leonard Cohen personally avoided her
20
1
2
like the plague throughout the years I represented him because she was
convinced that Machat & Machat had a 15% ownership interest in Stranger
Music, Inc. Steven Machat also advised me of this. Marty Machat personally
asked me to witness his last Will & Testament. I, therefore, assumed that I
4
would be called as a witness by one of these parties should they decide to
pursue the matter legally. That never occurred. While I was visiting him one
day, Marty Machat privately asked me to assist Steven Machat, told me he was
brilliant , and asked me provide him with whatever information or evidence he
8
9
10
requested.
30.
In any event, I decided to work for Leonard Cohen and made
arrangements, based upon his direct instructions, to have the remainder of his
files moved to my apartment on the Upper West Side. Mark Cristini, an
11
12
attorney who rented office space from Machat & Machat, was present and
specifically advised me that he called Steven Machat to inform him that Cohen
13
instructed me to remove the files and that this is what was occurred. I left the
14
office and some, but not all, of the materials Cohen advised me belonged to him
15
were delivered to the apartment. As Cohen never advised me to follow up with

Steven Machat, or made an issue out of the matter, I assumed that Steven
16
Machat had reviewed the files and removed what did not belong to Leonard
17
Cohen. I was aware at some point after Marty Machats death that Steven
18
Machat was questioning the whereabouts of certain bearer bonds, corporate
19
records, and other materials, that he believed were in his fathers office.
20
Evidently, Mark Cristini had advised Steven Machat that the bearer bonds were
1
2
in his fathers office before his death. In 2011, I advised Steven Machat that
shortly before Cohen and I parted ways, I was sitting at his work table in his
apartment, and flipped open a file nonchalantly. I am convinced that inside that
file was a bearer bond made payable to R&M Productions. Steven Machat
4
confirmed that R&M Productions was Machat & Machats company, where they
placed their publishing, and the letters R and M stood for his parents
initials, Roz and Marty Machat. Exhibit J: Transcript of Steven Machat &
Kelley Lynch conversation.
8
9
10
31.
In the documents that were shipped to my apartment was a tax
memorandum from Ken Fratto to Bill Dubey regarding Tax Planning for
Leonard Cohen. This document is dated August 22, 1977 and was prepared on
Elmer Fox, Westheimer & Co (CPA) letterhead. This document is essentially a
11
12
blue print for committing tax evasion or tax fraud. The document takes the
position that Leonard Cohen, who owned houses in several countries, did not
13
have to pay taxes in the United States, Canada, or Greece. It instructs Cohen
14
not to have a U.S. green card and goes into some detail about funneling monies
15
into off-shore accounts, how to handle U.S. source income, and to remain a
Canadian citizen while residing outside of Canada. It is my personal belief that
16
Leonard Cohen filed non-resident income tax returns in the United States while
17
holding a U.S. green card that he obtained in 1970. The IRS would have to
18
confirm that for a fact. This memorandum is astounding and may very well
19
prove that Leonard Cohen has a 40 plus year history of tax fraud and/or evasion
20
in the United States and Canada. That would explain the lengths this man has
1
2
gone to destroy my life; coerce me into what I viewed as illegal deals; and
illegally seize my business records and property. It would not explain Leonard
Cohens conduct in court or with respect to the Internal Revenue Service.
Nothing would explain that satisfactorily. Exhibit K: Elmer Fox, Westheimer &
4
Co. Tax Planning Memo for Leonard Cohen dated August 22, 1977.
32.
6
On September 12, 1988, Internal Revenue Service wrote Cohen c/o
Lynch with respect to SSN: xxx-xx-8917. This SSN differs from Cohens
present SSN which ends in 5124. Cohen had provided his accountant, Burt
Goldstein, with a Power of Attorney to deal with this matter. In fact, it was
Cohen who brought his numerous social security number problem to both Burt
10
Goldstein and my attention after Marty Machats death. Apparently the

information the Internal Revenue Service had on file (re. Cohens SSN) did not
11
12
agree with the information the Social Security Administration had on file.
Leonard Cohen testified that he never changed his SSN. That is perjured
13
testimony and the fact that he had numerous social security numbers is
14
extremely suspect. Exhibit L: IRS Notice dated September 12, 1988.
15
16
17
[Confusion re. alternate SSN & IRS account]

32.
After Marty Machats death in April 1988, Leonard Cohen and his
personal family friend and lawyer, Herschel Weinberg, began unraveling offshore accounts; establishing new entities in Delaware; dealing with Sony on at
18
least one recording contract that was evidently inadvertently assigned to a

19
Nevada entity Cohen created; etc. Leonard Cohen advised me that he planned
20
1
2
to abandon his green card and return to Canada. I was not privy to most
conversations or matters that he and Herschel Weinberg were privately dealing
with. Herschel Weinberg was a fanatic about attorney/client privileged
matters. Over the years, Cohen did speak to me about many of these matters
4
and I became familiar with some of them from our conversations or documents
I discovered. I was also asked to work with Cohens transaction attorneys, at
the Shukat firm, on some auxillary issues connected to the unraveling of the off-
shore accounts or matters being reviewed by Cohens immigration attorney in
Niagara Falls. Cohen understood that my brother-in-law was a very intelligent

attorney in Halifax, Nova Scotia. He expressed great concern about the
9
10
possibility that Canada would view him as a resident and ask him to pay taxes
for prior years. Evidently Cohen did not pay Canadian taxes. Cohen personally
11
asked me to speak with Van Penick, my brother-in-law, about Canadian
12
Residence issues. On October 26, 1988, I received a letter from Van who
13
explained that For Income Tax purpose, if you are resident in a country which
levies Income Tax, then generally your tax is calculated on your world-wide
14
income from all sources Van went into some of the factors that figure into the
15
Canadian residence equation which include: location of dwelling places;
16
location of spouse and dependents; location of personal property and social
17
ties; intention to be resident in a particular country shown, for example, by
18
renting out your home (not selling it) and retaining your resident club
19
memberships when you move to another country. Leonard Cohen and I phoned
my brother-in-law to discuss this at greater length. In the Case History
20
1
2
attached to my Motion to Vacate, I addressed some of the issues that concerned

Cohen with respect to Canada and badges of residency. Cohen felt that he
might potentially be viewed as a resident and, after consulting with Herschel
Weinberg, decided to abandon his U.S. green card and apply for another.
4
Initially, and this became a relatively famous Immigration case (as Cohen
repeatedly pointed out because that bothered him), Cohen attempted to apply
for a new green card through the corporation L.C. Stranger Music, Inc. This
attempt failed. Cohen again applied and was ultimately granted a new green
card in 1993 based on his own recognizance. Leonard Cohen personally

advised me that the final deciding factor in his decision to reapply for a U.S.
9
10
11
12
13
green card is the fact that Canada Revenue asks where you paid your taxes the
prior year while IRS does not. Please also see Case History. Exhibit M: Van
Penicks letter to Kelley Lynch dated October 26, 1988.
34.
In 1989, Leonard Cohen and Herschel Weinberg continued
unraveling certain off-shore accounts, publishing contracts assigned to those

accounts, and continued to relate to issues that arose in connection with
14
Cohens U.S. residency status. On or about December 7, 1989, Leonard Cohen

15
wrote his friend, Dominique Issermann, a letter transmitting the sum of
16
$100,000. as a gift to her from his Amro Bank Account (No. 47-25-92-874) in
17
Amstelveen, The Netherlands. This letter was notarized at the time. It is
18
evidence that Leonard Cohen followed the advice contained in a 1977 tax
19
memorandum instructing him to maintain ties with Canada, remain outside of

Canada, declare U.S. source income, and funnel international publishing into an
20
1
2
off-shore account. That is precisely what this bank account is and the funds
deposited into that account, as will be addressed in this declaration below,
related to music publishing income. Unfortunately, Leonard Cohen was in
possession of a U.S. green card while funneling music publishing income to

4
this, and possibly other, off-shore accounts. Due to the fact that I was involved
in creating new publishing agreements, I am familiar with this situation.
Furthermore, Dominique Issermann sent her draft letter for Leonard Cohen to
me. This matter is also relevant because the non-revocable corporate
assignments, related to intellectual property assets, date back to 1967 and

were not valued prior to the entry of default judgment. Exhibit N: LC letter to
Dominque Issermann dated December 7, 1989 (off-shore account).
10
35.
11
12
The above referenced account may have linked to a company known
as New Era, B.V. in the Dutch Antilles. To the best of my recollection New Era,
B.V. administered the worldwide music compositions written by Leonard Cohen.
13
After Marty Machats death, Cohen and Herschel Weinberg, unraveled the off-
14
shore accounts and Cohens new entertainment transaction attorney and,
15
pursuant to Leonard Cohens instructions, created new agreements with new

publishers or replaced the New Era B.V. agreements with Stranger Music, Inc.
16
agreements. Jonas Herbsman, one of Cohens transaction attorneys, wrote a

17
letter to Herschel Weinberg, Esquire, on January 8, 1990. He confirmed that a
18
letter had been prepared acknowledging the assignment to Stranger Music,
19
Inc. of musical compositions that were previously administered by New Era,
20
B.V. and forwarded a copy of same to the various subpublishers having

1
2
agreements with New Era, B.V. At the time this letter was written, Warner
Bros. Music Italy S.R.L. had returned a fully-executed copy of their agreement
with Stranger Music, Inc. Other letters and agreements were sent to
publishers listed on the attached letter. These songs were owned, at the time,
4
5
6
by Stranger Music, Inc. Exhibit O: Jonas Herbsman letter to Herschel

Weinberg dated January 8, 1990.
36.
On February 19, 1991, Leonard Cohen entered into an agreement
with the Society of Computers and Music Publishers of Canada (SOCAN). This
agreement was automatically extended throughout the entire time I worked for
Leonard Cohen. The agreement is terminated by written confirmation. This
10
agreement was assigned to Blue Mist Touring Company, Inc. in 1998. SOCAN,
based on internal rules and regulations, refused to pay royalties to Blue Mist
11
12
Touring Company, Inc. as it was not a company wholly owned by Leonard

Cohen, the writer. Therefore, due to the fact that Cohen was examining a bond
13
securitization deal with CAK, it was agreed that LC Investments, LLC would
14
collect the royalties paid by SOCAN while Blue Mist Touring Company, Inc.
15
actually owned the assets. These royalties should have been transferred to
Blue Mist Touring Company, Inc. and included on the federal tax returns. At
16
various times, Westin mentioned this could be problematic but felt the IRS
17
18
would never stumble upon the SOCAN agreement. Exhibit P: SOCAN

Agreement (with Leonard Cohen).
19
20
1
2
37.
Clause 39 of Leonard Cohens Complaint asserts that Blue Mist
Company, Inc. was formed in Delaware in March 1993. Blue Mist Touring
Company, Inc., a Delaware entity, was not formed in 1993. The entity, formerly
known as Leonard Cohen Productions, Inc., a Delaware entity, was formed in

4
1989. LC Productions, Inc., was formed, by Leonard Cohen, after Marty
Machats death in 1989. Cohen worked with his family friend and lawyer,
Herschel Weinberg, after Marty Machats death to unravel and sort through
many corporate, financial, and other issues. I do recall Leonard Cohen advising
Sony, sometime following Mr. Machats death, that Marty Machat inadvertently
assigned his record contract to a Nevada entity. I am unclear if that entity was
9
10
11
12
Leonard Cohen Productions, Ltd., a Nevada entity, that was formed sometime
around 1970.
38.
In 1993, this entity was registered to do business in California. The
Certificate of Amendment of Certificate of Incorporation of Leonard Cohen
13
Productions, Inc., signed by Leonard Cohen on March 11, 1993, resolved to
14
amend the name of the corporation to Blue Mist Touring Company, Inc. Blue
15
Mist Touring Company, Inc. continues to list its business address as my former
P.O. Box; me as the registered agent; and my former office address as the agent
16
address. Its status is SOS/FTB forfeited. Exhibit Q: Leonard Cohen

17
Productions, Inc. Certificate of Amendment of Certificate of Formation
18
(changed name to BMT) dated March 11, 1993; Articles of Incorporation of
19
Leonard Cohen Productions, Ltd., Nevada; Statement and Designation by
20
foreign corporation.
1
2
39.
My fax to Richard Feldstein, Cohens business manager, dated
December 7, 1993, fax is highly material and contains a quote from an opinion
Cohen received with respect to his potential Canadian residency problems.
These concerns of his continued after he abandoned his 1970 green card and
4
obtained a new one in 1993: If Leonard leaves Canada for more than two
years and gives up substantially all ties with Canada, such as closing bank
accounts, ceasing to donate to Canadian charities, emigrating with his family,
and winding up the majority of his active business enterprises in Canada, while
acquiring residency elsewhere, he would only then be considered to have given

up his Canadian residence. Leonard Cohens question to his business
9
10
manager is contained in my final paragraph to Richard Feldstein: I probably

should have been more specific in my fax to you: if Leonard were to give a
11
donation to a Canadian charity would this in fact jeopardize his position that he
12
is not a Canadian resident. Please advise. Leonard Cohen was extremely
13
concerned about his potential tax/residence issues in Canada. I have discussed

this situation with Canada Revenue. This document is also relevant because
14
Robert Korys declaration takes the position that Cohen is in good standing
15
with tax authorities throughout the world and there is evidence that this may
16
be a defense rather than a fact. It also relates to bias and motive. Exhibit R:
17
Kelley Lynch fax to Richard Feldstein dated December 7, 1993.
18
19
20
40.
After Leonard Cohen personally met with, and hired, Neal
Greenberg, an attorney by the name of Ed Dean was brought onboard to assist

with the creation of two charitable remainder trusts Cohen decided to create. I
1
2
am aware of only two trusts. The expense ledger appears to list a third trust
that may very well be the revocable trust created for probate. I do not recall
any Cohen account with Greenberg, including these two charitable remainder
trusts, being assigned to the revocable trust. Ed Dean, who had previously
4
raised concerns about assigning personal service contracts to these entities,
wrote on November 15, 1996: I am confident that the IRS could not
successfully argue that the charitable trusts are receiving compensation
income or unrelated business taxable income that would disqualify them for
tax-exempt status. This letter also addresses the concerns that had been
raised with respect to issues involving self dealing. I personally believe IRS
9
10
11
12
could successfully argue these matters. Exhibit S: Ed Dean letter to LC and KL

dated November 15, 1996.
41.
Neal Greenbergs February 10, 1998 fax to Cohens transaction
attorney, Jonas Herbsman, is evidence that Greenberg was extremely
13
instrumental in the corporate, tax, and financial issues that arose with respect
14
to the intellectual property deals being pursued. This fax addresses the fact
15
that Greenberg had spoken to Richard Westin the night before regarding
Sonys concerns about tax matters. This was a relentless and continuous
16
issue. Leonard Cohen is the individual who demanded complex corporate

17
structures and the tax issues that arose are due to his attempts to evade paying
18
ordinary income taxes, a topic he routinely obsessed over. These issues also
19
made these deals unattractive to most buyers other than Sony Music who
20
owned certain rights that made them more valuable to Sony. Exhibit T: Neal
1
2
3
4
Greenbergs fax to Cohens transaction attorney, Jonas Herbsman February 10,

1998.
42.
Leonard Cohen, his lawyers and representatives, handled all
corporate matters. During Lynchs 2012 trial, Cohen confirmed that the
corporate accounting and corporate books were handled under the direction of
his lawyer. Attached hereto are the annual minutes of Blue Mist Touring
6
Company, Inc. from 1993 through 1998. They are signed by Leonard Cohen
who, at that time, was sole shareholder and Kelley Lynch as assistant secretary.
Cohens lawyer, Herschel Weinberg, personally asked if I would agree to serve
as assistant secretary and I simply agreed to do so. I had no ulterior motives
10
and was not planning a coup with respect to Leonard Cohen that related to
corporate assets and intellectual property. He obviously needed to argue that
11
12
someone controlled him but has actually argued that he views himself as the
alter ego of these entities and has engaged in self-dealing. It would be humanly
13
impossible to control Leonard Cohen. Attached hereto is Richard Westins June
14
1, 1998 letter to me. In the letter, Westin asked if I could locate the book
15
publishing contracts related to Cohens 11 books that were published as of that

date. He also requested a copy of the SOCAN performing rights society
16
agreement that relates to the writers share of intellectual property. At this

17
time, Cohen and his representatives were entertaining a number of potential
18
deals. Various potential buyers were interested in purchasing Cohens literary
19
work as they felt it would be a valuable asset. Cohen agreed to offer his
20
literary work, as contained in his first 11 books, for sale. Richard Westin
1
2
therefore prepared Minutes of a Special Meeting of the Board of Directors of

Blue Mist Corporation and the assignments were presented for consideration.
Leonard Cohen agreed to transfer, as the creator, the following books to the
corporation: Let Us Compare Mythologies; Spice Box of Earth; Favorite Game;

4
Flowers for Hitler; Parasites of Heaven; Beautiful Losers; Selected Poems
(1968); Energy of Slaves; Death of a Ladys Man; Book of Mercy; and Stranger
Music. The Board reviewed the copyright certificates and it was agreed that
counsel for the corporation [Richard Westin] would prepare and submit notices
of assignment of copyright with respect to all the above books. Also addressed
in these Minutes and assigned at this time were Leonard Cohens rights to 1)
9
10
the writers share of music publishing (excluding the publishing share sold to
Sony/ATV in 1996) which included writers share of performance income and
11
artist record royalties from Sony Music International for the sale of records
12
worldwide. It was agreed that these rights were embodied in the attached
13
documents beneath the cover page captioned WRITERS/ARTISTS SHARES

and attached to these Minutes. The President of the company, Leonard Cohen,
14
authorized the acceptance of these works on behalf of Blue Mist Touring

15
Company, Inc. This document is signed. Leonard Cohen and his daughter,
16
Lorca Cohen, went into my office and removed every single business file they
17
felt entitled to. That would include my personal business and corporate
18
records. The original of this document would have been in those files. As of
19
this date, these assets were formally assigned to BMT and the minutes reflect
that fact. Exhibit U: Richard Westin letter to Kelley Lynch dated June 1, 1998;
20
1
2
3
4
Minutes of a Special Meeting of the Board of Directors of Blue Mist

Corporation; Trial Transcript (page 279-293).
PD: Okay. Who handled your corporate books at the time, as of 2004? Cohen:
Who was handling it? PD: Who handled your corporate accounting, your
corporate books? Cohen: A number of people handled it under the direction of
my my lawyer. [RT 279-283]
5
6
7
8
43.
According to the Cohens Opposition to CAKs Motion for an Order
of Attachment dated August 30, 2000, in early 1999, Cohen, through certain of
his representatives, engaged in preliminary discussions with CAK concerning a
possible loan transaction. Specifically, the parties discussed the possibility that
plaintiffs (CAK) would make a loan to an entity established by Cohen for that
10
purpose in an amount to be determined that would be secured by a security
11
interest in the Rights and the royalty income generated therefrom. Following
12
further discussions between the parties, on or about May 10, 1999, CAK and
13
Cohen signed a document entitled Proposed Royalty Income Loan for Leonard
Cohen Summary of Terms & Conditions (the Term Sheet). This litigation
14
relates to the document Cohen signed and the payment of a $290,000

15
Origination Fee. This document confirms that Leonard Cohen terminated
16
CAKs engagement and Cohens representatives discussed with Sony Music
17
their acquisition of the Rights. In November of 1999, Cohens representatives
18
conformed CAK that Cohen was seriously considering selling the Rights to
Sony, if acceptable financial and related terms could be reached. In response,
19
CAK wrote Cohens personal manager and advised her that in light of the
20
1
2
recent events regarding Sony and their potential offer to purchase Leonard
Cohens assets, we offer an alternative to the proposed Loan structure. This
document confirms that Cohen decided not to proceed with the CAK loan. It
also confirms that CAK would direct their communications to Cohens lawyers,
4
copying me, but on this one occasion they sent a letter (without copying
Cohens lawyers) to my office. The document that was sent at this time was a
commitment letter, that triggered an obligation, requesting that Cohen
confirm his agreement by signing the letter and returning a fully executed copy
to CAK by 5 PM on November 19, 1999. One of the key arguments in this

particular matter has to do with CAKs failing to communicate with Cohens
9
10
lawyer, simply sending a commitment letter to my office, and the fact that I
placed this on Cohens desk (as was my custom and routine) for him to review.
11
I assumed that, as with every single other document in that matter, CAK had
12
sent a copy to Cohens lawyers. Exhibit V: Cohens Opposition to CAKs Motion
13
14
15
for an Order of Attachment dated August 30, 2000.

44.
Leonard Cohens declaration in the CAK bond deal confirms that he
was well aware of this deal, the 2001 Sony deal, and he made the ultimate
decisions and was the driving force behind them. He is aware that I was his
16
personal manager, as is his lawyer, and understands that he receives

17
substantial royalties. Leonard Cohen also confirmed that I receive what I view
18
to be substantial royalties, on a regular basis, from sales of my albums and uses
19
of my compositions. This completely undermines and contradicts allegations
20
in the Complaint that Leonard Cohen felt an intellectual property sale was
1
2
financially urgent. Exhibit W: Leonard Cohens Declaration dated August 30,

2000[CAK litigation, Case No. 00 Civ. 1068 (DAB), United States District Court,
Southern District of New York].
3
4
45.
In March of 1999, Leonard Cohen instructed Richard Westin to
cancel Cohens sole ownership in Blue Mist Touring Company, Inc. (500 shares)
5
and issue Lynch 75 shares of Blue Mist, representing a 15% equity interest, and
6
himself (Cohen) 425 shares, representing an 85% equity interest. The
corporate minutes, according to Cohens Complaint, were issued to Lynch as
compensation for her services to the Corporation, with great gratitude for her
efforts. Leonard Cohen personally dictated that language. Exhibit W-1: Blue
10
11
12
Mist Touring Company, Inc. Stock Ledger (Westins handwriting).

46.
Ken Clevelands fax to Kelley Lynch dated June 24, 1999. This fax
relates to an IRS audit of Cohens decision to give Mt. Baldy a gift of LC

Stranger Music, Inc. stock in anticipation of the closing of the 1996 deal with
13
14
Sony/ATV. Cohen hired Ken Cleveland to handle this audit and then decided to
keep him on as his accountant due to the successful outcome of the audit. This
15
fax is relevant because the P.S. states: Kelley, the IRS has the SSN as 5724. I
16
will call them on it but I dont think it will get you out of the audit. Leonard
17
Cohens last for SSN numbers are 5124 and the Court should review the above
mentioned IRS Notice related to an entirely different SSN. This is confirmed in
18
the attachment to this letter. Confusion with respect to IRS matters, Cohens
19
social security number, corporate ID numbers were a continual issue and high
20
1
2
suspect. Leonard Cohen personally signed the Power of Attorney to IRS

proving that he hired Cleveland and he notified IRS that Cleveland was his
representative. Leonard Cohens letter to Mt. Baldy dated November 1, 1996
shows that he is very familiar with the first Sony deal and his personal decision
4
to make a gift to the Center in form of capital stock of Leonard Cohen
Stranger Music, Inc., a New York corporation. 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.
8
9
10
47.
Ken Clevelands fax of July 22, 1999 answered certain questions I
had asked. He confirmed that he did have Leonard Cohens personal Power of
Attorney on file; was handling Adam Cohens tax matters with IRS and had set
up a payment plan; would file extensions for the truth and individuals until
11
12
October 15, 1999 and would like the information by September 15th; confirms
that corporate returns are due by September 15th and he would appreciate that
13
information by August 15th; and, addresses the IRS audit of Cohens decision to
14
restructure LC Stranger Music, Inc. (in anticipation of the closing the 1996
15
Sony deal) and give Mt. Baldy Zen Center a gift of stock totaling approximately
$500,000. Ken Cleveland advised me that he spoke with Steve Insfeld (who
16
was part of Cohens previous accounting firm), about stock appraisals (one did
17
not appear to exist) and an item on the worksheet Insfeld sent me. Ken
18
Cleveland noticed that Sony valued the stock at a certain amount (which was
19
NOT the payment amount to Cohen) and deducted $142,723.23 for outstanding
20
liabilities and paid the various stockholders a lesser amount. Ken Cleveland
1
2
asked Cohens former accountant if the $142,000 was an advance that Cohen
counted as income in prior years and paid tax on or , if he didnt pay tax on it, is
there a note and did Cohen pay interest on the funds to prove to IRS that it
was in fact a loan and was not income. The handling of income as loans was
4
5
6
7
8
9
an ongoing issue and one that I suspect would interest Internal Revenue
Service. Exhibit Y: Ken Cleveland fax to Kelley Lynch dated July 22, 1999.
48.
Leonard Cohens Complaint in this matter alleges that while Lynch
and Westin were still

working on their joint project SOCAN refused to agree to pay Cohens
performance royalties to a company not wholly owned by a member artist.
10
Accordingly, in furtherance of the plan to control all of Cohens royalties, either
11
Lynch or Westin suggested the formation of a new entity, Leonard Cohen
12
Investments, LLC. LCI LLC was formed as a sole member (with Cohen owning
100% interest) Delaware limited liability company on October 19, 1999. Once
13
14
LCI LLC was formed SOCAN was instructed to pay Cohens performance
royalties directly to LCI LLC. I didnt have a joint project with Richard
15
Westin who represented Leonard Cohen. It makes absolutely no sense
16
whatsoever that I would create a company wholly owned by Leonard Cohen in
17
order to control all of Cohens royalties particularly as I have a 15%

ownership interest in Blue Mist Touring Company, Inc. and the intellectual
18
property assets it owns. Leonard Cohens estate planning attorney, Reeve

19
Chudd, caused the formation of LC Investments, LLC. His explanation
20
1
2
regarding the creation of this entity, as set forth in his September 8, 1999
letter, is as follows: Dear Kelley, This memorandum summarizes my
discussions with Peter [Lopez], my partner Ken Luer and Paul Baumgarten
regarding LCs contemplated transaction. Peter Lopez worked as Cohens

4
transaction attorney and Paul Baumgarten was part of CAKs negotiating team.
This entity was formed to accommodate a potential bond securitization deal
that Cohen addresses in his declaration attached hereto. With the approval of
Paul Baumgarten, the transaction documents will be drafted so that (1) LC
transfers the specified music rights to the LLC and (2) the lender permits LC to
then transfer his interest in the LLC to the Trust without any further consent
9
10
from the lender. This trust is a revocable trust specifically for probate
purposes. The single member LLC will be disregarded for income tax
11
purposes Thus, the royalty income from the music rights will be received by
12
the LLC as ordinary income, and LC will report such income, for income tax
13
purposes in the same manner, as if he received it directly Because LC is

treated (for income tax purposes) as the owner of these income rights, they will
14
not be considered assets under Section 1221(e) of the Internal Revenue Code.
15
Accordingly, the LLC structure of this transaction will not change the rights (or
16
the LLC interest into a capital asset, capable of a sale generating capital gain
17
or loss. The purpose of the use of the LLC, as Peter has alluded to in the past
18
are (1) from LCs point of view, to create a bankruptcy-protected entity which
19
will protect LCs personal assets from the creditors of the LLC (e..g. the lender
in this transaction); and (2) from the lenders point of view, to create a
20
1
2
bankruptcy remote entity, the assets of which (i.e., the music rights
transferred by LC) will not be reachable by LCs creditors if he were to file
personal bankruptcy. This letter also confirms that Leonard Cohen is the sole
owner of LC Investments, LLC. This entity was created specifically to

4
accommodate the CAK bond deal that Leonard Cohen, according to his own
declaration, decided not to pursue. Nothing was assigned to this entity and the
assets are owned by Blue Mist Touring Company, Inc. The reason nothing was
assigned to LCI is due to the fact that it had no purpose whatsoever other than
the proposed CAK bond securitization deal. Exhibit Z: Reeve Chudd letter to
Kelley Lynch dated September 8, 1999.
9
10
49.
LC Investments, LLC was formed by Leonard Cohens estate
planning attorney who worked with, among others, Cohens transaction

11
12
attorney (Peter Lopez), Richard Westin, and others. The specific reason for the
formation of this entity was to accommodate the proposed CAK bond deal
13
securitization. At this moment in time, the CAK deal was on the verge of
14
closing. In November 1999, Sony would step in with a very solid offer and
15
Cohen personally decided to pursue that deal rather than close the CAK deal.
Nothing was assigned to LC Investments, LLC and the reason for that is
16
because he had no purpose, other than to accommodate CAKs demands, and

17
18
the bond securitization deal fell apart due solely to the decisions of Leonard
Cohen who was keenly involved in all of these deals.
19
20
1
2
50.
CAK demanded a bankruptcy proof entity. While the details, as to
who Cohen would ultimately pursue intellectual property deals or a bond

securitization with, were being sorted out, an issue arose with SOCAN. Their
policies prohibit them from paying royalties related to the writers share of
4
income to any entity not owned 100% by the writer. Leonard Cohen and I
agreed that LC Investments, LLC could therefore collect the royalties with
respect to the assets owned by Blue Mist Touring Company, Inc. in order to
accommodate this situation. Cohen ultimately chose not to pursue the CAK
bond deal and therefore nothing was formally assigned to LC Investments, LLC
or transferred from Blue Mist Touring Company, Inc. Leonard Cohens
9
10
fabricated narrative in no way resembles what actually occurred and he and his
representatives appear to be making it up as they are going along. I tend to
11
doubt I would create an entity wholly owned by Leonard Cohen in order to
12
control anything. Exhibit AA: LC Investments, LLC Certificate of Formation
13
14
15
dated October 19, 1999; Operating Agreement dated August 21, 2000.
51.
At the beginning of November 1999, as the CAK deal was on the
verge of closing, I received a call from Stuart Bondell of Sony. Sony did not
want Cohen involved with the bond securitization deal. It set precedence for
16
other artists; caused Sony to pay someone other than the artist; and interfered
17
with Sonys ability to pay advances to their artists which, as Stuart Bondell
18
wisely noted, are the currency of the music industry. After this call, I phoned
19
Leonard Cohen who advised me that he would agree to pursue the intellectual
20
property deal with Sony, and forego the bond securitization deal, if they paid
1
2
him a substantial, non-refundable deposit or prepayment in the amount of $1

million. Cohen wanted Sony to show their good faith and intention to swiftly
move through this deal and close it. Sony agreed and on November 5, 1999
transferred $1 million into Leonard Cohens personal bank account. The

4
amount was deemed a partial prepayment against the proposed $8 million
buyout of certain intellectual property and contractual rights. Cohen, his
representatives, and I began what would become a very long and complex
series of negotiations. CAK continued to offer different terms that Cohen
ultimately chose not to entertain. We were also involved with negotiations

related to Cohens recording contract, royalty rate, and were considering other
possible intellectual property deals as well.
10
52.
11
12
Leonard Cohens email of May 19, 2000 confirms that he was the
controlling and directing force behind the intellectual property deals: Dear
Kelley, I received Dons email which you kindly forwarded to me. I must
13
confess I am losing patience, and frankly losing interest in this deal. The
14
dragging of feet is deafening. I dont know if its you, or the lawyers, or Sony,
15
but something is very wrong. I had a good bond deal on the table with CAK,
until Sony spoke up, and now I am in litigation with CAK, and Sony is busy
16
revising the figures downwards. Cohen goes onto state that he believes Sony
17
destroys my deal with CAK (so as not to establish any precedent of their artists
18
leaving the fold), dumps me into litigation, then they postpone the closing of
19
their deal for seven months until they can discover that my catalogue sales are
20
lagging and then they will lower the price. This is too obvious and too familiar.
1
2
Cohen was intimately involved in what he views as his deals. He understands

that the royalty income being generated is dwindling. The reason he knows
this is because he was completely aware of all income related to intellectual
property assets, performance income, book publishing, and so forth and so on.
4
These deals were an extraordinary amount of work; required ongoing
negotiations; and were unnecessarily complicated by Cohens demands related
to the sale of stock versus a rather straightforward asset sale. No one on earth,
who simply wanted to pick up some quick income, would create complicated
structures that very few potential buyers were interested in unless that
individual was interested in avoiding personal income taxes. This letter also
9
10
confirms that CAK sued Leonard Cohen personally and the payment of
settlement amounts with respect to that litigation have nothing whatsoever to
11
do with Traditional Holdings, LLC except Leonard Cohens belief that these
12
entities are his personal piggy banks and he is their alter ego. It is important
13
for the Court to understand that the purpose of Cohens letter, which he wrote
while requesting my thoughts, had as its sole intention the goal of urging Sony
14
to move more swiftly with respect to the deal and give them a clear warning
15
that he will withhold the studio album he planned to deliver. Cohen may have
16
decided to change his tactic of threatening Sony executives, like Don Ienner,
17
since the time Bob Bowlin and Mel Ilbermann called me into their office to
18
advise me that Don Ienner does not appreciate receiving threatening faxes
19
from Leonard Cohen. I assured them that I received them all the time and the
ones Don was on the receiving end of were mild in comparison. Exhibit BB:
20
1
2
3
4
Leonard Cohens email (baldymonk@aol.com) dated May 19, 2000 to Kelley

Lynch (tsimar).
53.
Richard Westins May 23, 2000 memorandum addressed the
concerns he and Ken Cleveland had with respect to the use of Blue Mist
Touring Company, Inc. in connection with a stock sale to Sony Music and
collapsible corporation issues. Westin begins this memorandum by positing

6
the theory that Internal Revenue Code Section 341 contains a weapon
designed to prevent the manipulation of collapsible corporations. The
Congressional fear behind the provision is that aggressive taxpayers would
convert ordinary income into capital gains by hiding the ordinary income in a
10
corporation. For example, a taxpayer might buy whiskey in barrels, contribute

the barrels to a corporation and wait a year and a day and sell the stock of the
11
12
corporation at a favorable long-term capital gain. The Congressional remedy is

to render gains on sales of such stock as ordinary gains as opposed to capital
13
gains. The result is highly adverse. While I have no tax expertise, a simple
14
plain reading of the words collapsible corporation together with the concept
15
that one is essentially attempting to convert ordinary income into capital gains
tax treatment, I feel it is safe to assume that this involves some form of
16
potentially illegal shenigans that involves tax evasion. I must say that I had
17
grave concern about this issue; the one year and a day holding periods; and,
18
with respect to the ongoing and relentless attempts to transform ordinary
19
income into capital gains. Nevertheless, this is not my area of expertise and
20
that is precisely why Leonard Cohen had a professional team of lawyers,

1
2
accountants, business managers, financial advisers, and others, counseling him

on these and other matters. Richard Westin goes onto confirm that Arguably,
Blue Mist falls into the collapsible corporation category and concludes that in
order to finesse the issue, he [Ken Cleveland] and I agree that we should have
4
Blue Mist make a so-called Section 341(f) election. Evidently, according to
this memorandum, that would permit the sale of stock in this manner while
addressing the collapsible corporation concerns. Exhibit CC: Richard
Westin Memorandum dated May 23, 2000.
8
9
10
54.
Westin instructed Cohen and myself as to what needs to be done at
this time: The corporation needs to have a board meeting at once in which it
consents to Section 341(f) treatment. There is also a letter to file with the IRS.
The contract with Sony should assure that the election is not somehow
11
12
repudiated or undermined. The consent is given by means of a statement,

signed by a duly authorized officer, that the corporation consents to have the
13
gain recognition provisions of Section 341(f) apply to dispositions of its Section
14
341(f) assets. The statement is filed with the district director having
15
jurisdiction over the corporations income tax return for the year for which the
statement is filed. The consent is effective for six months (beginning of the
16
date filed). There is no limitation on the number of consents which may be

17
filed. Leonard will be that officer, namely President. I will provide a letter for
18
that. On or around September 21, 2000, Richard Westin faxed through the
19
letter Blue Mist Touring Company, Inc. sent to Internal Revenue Service
20
advising them that the corporate taxpayer consents, pursuant to the lawful
1
2
Board action, to have Section 341(f)(2) of the Internal Revenue Code apply to
any disposition by it of subjection f assets as provided in that section.
Leonard Cohen, as President, personally signed this document. This document,
signed by Cohen, does tend to prove (particularly given the fact that is a simple
4
one page letter, that Leonard Cohen understood Blue Mist Touring Company,
Inc. was the entity that owned the intellectual property assets, some of which
were being sold to Sony, and his representatives felt this IRS election was
important at the time due to the fact that the intent of all parties involved was
to pursue the second Sony intellectual property deal through a Blue Mist
Touring Company, Inc. stock sale. To summarize, Section 341(f) election,
9
10
according to this memorandum, permits the sale of stock in this manner while
addressing the collapsible corporation concerns. Therefore, Leonard Cohen
11
understood that the intellectual property was in Blue Mist Touring Company,
12
Inc. and the parties intent was to pursue a stock sale which he personally
13
14
15
demanded. Exhibit DD: BMT letter to IRS re. 341(f) election.

55.
The regulations, according to Westin, also evidently require the
corporation to attach a copy of the corporations consent to its income tax

return for the year of the sale. I attach hereto a copy of Blue Mist Touring
16
Company, Incs 2000 federal tax return. The 341(f) election, signed personally
17
by Leonard Cohen, is not attached. I also attach hereto a copy of Blue Mist
18
Touring Company, Incs 1999 federal tax return. The $1 million pre-payment
19
from Sony on this deal was not reported as income to this entity in the year it
20
was received (1999). Nor is there any evidence on the 2000 tax return proving
1
2
that this prepayment was handled as a loan or advance between Leonard

Cohen and Blue Mist Touring Company, Inc. All parties were clear that the
intellectual property assets were owned by Blue Mist Touring Company, Inc.
and yet Leonard Cohen personally took possession of that income which later
4
became the subject of an IRS audit. That audit clearly should be revisited. The
original audit was handled by Hochman, Rettig who Cohen personally hired.
When I attempted to provide them with the Traditional Holdings, LLC
corporate documents and annuity agreement, noting that I wondered if
something might be wrong, Steve Blanq personally advised me that Richard

Westin spoke to him and reminded him about his attorney/client privilege with
9
10
Leonard Cohen. I found that rather mind-boggling given the fact that I had a
99.5% ownership interest in Traditional Holdings, LLC and the IRS was
11
auditing a prepayment against the 2001 intellectual property deal. Richard
12
Westins May 23, 2000 memorandum to KL and Leonard Cohen. Exhibits EE:
13
14
15
BMT 1999 and 2000 federal tax return.

56.
On September 15, 2000, Leonard Cohen, as Assignor and on behalf
of LC Investments, LLC, attempted to assign Property to LC Investments, LLC

as trustee for the Leonard Cohen Family Trust. The trust is a revocable trust
16
for the sole purpose of avoiding probate. The Property Cohen attempted but
17
failed to transfer into this entity is described in Exhibit A attached hereto:
18
Exclusive Songwriter Agreement between Sony/ATV an Leonard Cohen dated
19
November 18, 1996 and SOCAN agreement. The SOCAN agreement is dated
20
February 19, 1991 and included an attachment consisting of a certain

1
2
agreement dated April 14, 1967 between BMI Canada and Leonard Cohen.
These properties are owned by Blue Mist Touring Company, Inc. and were not
Leonard Cohens to assign to LC Investments, LLC. Exhibit FF: Cohen signed
Assignment (signature page only) dated September 15, 2000.

4
57.
Richard Westins September 16, 2000 letter addresses matters
related to various corporate

6
entities: 1) Blue Mist binder: I placed the original stock 500 share certificate
7
for Leonard Cohen Productions after the particular set of Minutes and wrote
8
VOID/CANCELED over the certificate of Leonard Cohen Production stock.
This shows that Leonard Cohen directed his lawyer to cancel his stock interest
10
in Leonard Cohen Productions, Inc. 2) Leonard Cohen Productions Binder: I
11
placed the original certificate of incorporation at the front of the binder where
12
it belongs I put a copy of the documents relating to the name change at the
front of the binder Now it makes sense that there are two binders [Blue Mist
13
14
Touring, Inc. and Leonard Cohen Productions, Inc.] Except for the trivial fact
that tax returns (showing no income) should have been filed, I think the volume
15
is in adequate order to pass must in a due diligence inquiry. The lack of tax
16
returns is unlikely to upset anyone. LC Investments, LLC Binder: I want to
17
hang onto this folder. There are some problems that need to be straightened
out. This letter should prove that Blue Mist Touring Company, Inc. was
18
previously LC Productions. It clearly states that no tax returns previously filed

19
with respect to this entity. I am unclear how the Delaware LC Productions
20
1
2
3
4
entity relates to the Nevada LC Productions entity. Exhibit GG: Richard

Westins September 16, 2000 letter to Kelley Lynch.
58.
In October, 2005, Los Angeles Sheriffs Department, related Case
No. BC341120, unlawfully seized corporate, partnership, and tax information

from me unlawfully. I have an ownership interest in Blue Mist Touring
Company, Inc., Traditional Holdings, LLC, Old Ideas, LLC, and possibly with
6
respect to other entities. Cohen has simply fabricated a narrative and, by
failing to serve me the summons & complaint, wrongfully converted my
property to his. However, based on his testimony that he is not obligated to
provide me with any tax information, it is overwhelmingly obvious that his
10
motive relates to undesirable IRS inquiries. LASDs Inventory, which is

incomplete and does not accurately address the seized items, indicates an
11
12
unlawful seizure of property belonging to me, Machat & Machat, and Phil
Spector. That would include, but is not limited to, the horn slave [master tape]
13
of Elton Johns Im Your Man and the master to Elton Johns Im Your Man
14
recording These tracks are related to a tribute album I worked as executive
15
producer on that contained cover versions of Leonard Cohen songs. The seized
property also included a mix tape of an Adam Cohen recording and Steve
16
Lindseys Adam Cohen Reel. I worked as Adam Cohens personal manager

17
and these items did not belong to Leonard Cohen. Other items seized were
18
Adam Cohens Tell Me Everything (2 reels); Box of records Leonard Cohen
19
promotion use (Stranger Managements property); Box Misc. Videos (Stranger
20
Managements property); Box Misc. Books Leonard Cohen (Stranger

1
2
Managements property); Box Misc. Stranger Music Documents Leonard

Cohen (Machat & Machat property); Box No Top 2 Books Tower of
Songs, The Songs of Leonard Cohen (Stranger Managements Property); Box
Misc. Books/Damaged (Stranger Managements Property); Box Misc Books

4
Leonard Cohen (Stranger Managements Property); Box Misc.
Documents/Blue Mist (Kelley Lynch Property); Box Blue Mist Touring, Inc.
Misc. Legal Papers(Stranger Managements Property); Box Labeled Stranger
Management (Stranger Management Property); Box Gold Star Recording
Reel Tape Heart On Phil Spector (Phil Spector Property); Box Documents
Traditional Holdings, LLC (Kelley Lynchs Property); Box Misc. Tax
9
10
11
12
13
14
Returns; Box Misc. Leonard Cohen Productions, Ltd. (Belongs to BMT;

Nevada Entity).
59.
Exhibit HH: LASD Inventory dated October 18 & 24, 2005.
Leonard Cohen did not need to file a lawsuit to prepare a full
accounting with respect to

these corporate entities or amounts paid to him, myself, or anyone else. Cohen
and his daughter, Lorca Cohen, personally removed all business and corporate
15
records from my offices. That would include my business files which Cohen
16
refuses to return. Leonard Cohen was in possession of all bank statements
17
(personal and corporate), financial records, accounting records, corporate

records (including, as of October 2004, all corporate books that were provided
18
Greenberg, Glusker), royalty statements, agreements, and so forth and so on.

19
It is my personal position that Leonard Cohen had an ulterior motive for
20
1
2
subpoenaing my personal bank records given the fact that they were not
required to prepare an actual accounting. The expense ledger, used to the
support the default judgment, is evidence of financial fraud and fraudulent
evidence. The ledger in no way represents an actual accounting that would

4
take into consideration corporate ownership interests, assets, liabilities, and/or
equities. It is a list of numbers, and a random handful of documents, that is
meaningless. The ledger was not audited and Neal Greenbergs financial data,
in particular, is wholly untrustworthy. Leonard Cohen is the individual who has
stolen from me and withheld commissions due me with respect to services

rendered as his personal manager. An example of the type of my property is
9
10
attached hereto. This is a copy of the May 21, 1994 letter Tom Robbins
personally wrote me after I asked him to write an introduction to the Tower of
11
Songs tribute album. I have advised Leonard Cohens lawyer, Jeffrey Korn,
12
that my property (including all bank records unlawfully seized) should be
13
preserved. Many artists covered Leonard Cohens songs but this was not one
of his albums. I worked as co-executive producer with David Anderle of A&M
14
Records on this project. Exhibit II: May 21, 1994 letter to Kelley Lynch from
15
Tom Robbins.
16
60.
17
On September 19, 2000, Don Friedman, Cohens transaction
attorney, wrote Stuart Bondell of Sony Music. Copied into this letter were
18
Kelley Lynch, Greg McBowman, Richard Westin, Arthur Indursky, and Stuart
19
Fried. The letter summarized the proposed basic structure of the transaction
20
Cohen was pursuing and the assets that Sony was interested in purchasing:
1
2
Blue Mist Touring, Inc. (BMT) is a Delaware corporation, the capital stock of
which is owned 85% by Leonard Cohen and 15% by Kelley Lynch. (Cohen owns
425 shares and Lynch owns 75 shares.) The letter goes onto address the assets
Blue Mist Touring Company, Inc. planned to sell to Sony Music not the actual
4
assets it owned or was legally assigned. The understanding, per this letter, was
that Sony would purchase Cohens and Lynchs stock in BMT (representing
100% of the equity interest in BMT). Cohens Complaint confirms that the
assignments to BMT were not removed and remain in Blue Mist Touring
Company, Inc. Lynch has a rightful ownership interest in this and other
entities. At some point hereafter, Richard Westin phoned me to explain that he
9
10
11
12
had spoken to Ken Cleveland who raised concerns about Blue Mist Touring
Company, Inc. and collapsible corporation concerns. Exhibit JJ: Don
Friedmans letter to Stuart Bondell, Sony, dated September 19, 2000.
61.
While I most certainly have no expertise in tax or corporate
13
matters, and handled nothing having to do with those matters, the article
14
Collapsible Corporations in a Nutshell provides a general overview and
15
addresses the fact that this is used as a tax avoidance device which has long
concerned the U.S. Treasury Department. It is my personal recollection that
16
Cohens representatives decided not to use Blue Mist Touring Company, Inc. to
17
pursue the anticipated stock deal with Sony, due to the collapsible corporation
18
concerns, while Cohens Complaint alleges that Sony refused to pursue the
19
transaction using this entity. That is blatantly untrue and, in fact, Sony began
20
their due diligence with Blue Mist Touring Company, Inc. All parties
1
2
3
4
understood that I had a 15% ownership interest in the entity and the
intellectual property assets it owned
62.
Richard Westin wrote Greg McBowman and myself a letter on
September 20, 2000. At this time, all intellectual property had been formally
and irrevocably assigned to Blue Mist Touring Company, Inc. At this time, the
assets Sony was interested in purchasing were described as those belonging to

6
Blue Mist Touring Company, Inc. while the assets they were not purchasing,
which did in fact belong to Blue Mist, were listed as the property of LC
Investments, LLC. Westin breaks these two sets of assets down: Blue Mist
owns the record royalty entitlements (which does include the mechanical
10
royalties although Sony was not purchasing them) under Recording Agreement
between Leonard Cohen and CBS/Sony. LC Investments would potentially own
11
12
the writers share of music publishing (including the writers share of

performing rights income plus the artist royalty LC receives from Sony Music
13
International for the sale of records worldwide. Westin specifically mentions
14
two agreements: November 18, 1996 Exclusive Songwriter Agreement. This
15
agreement was never assigned to LC Investments, LLC. Nothing was. Westin

fails to address the book publishing that is also owned by Blue Mist Touring
16
Company, Inc. Greg McBowman provided a breakdown of Leonard Cohen and

17
Kelley Lynchs share of the Sony Music sale of the intellectual property listed as
18
belonging to Blue Mist. The sale price was listed as $8 million, due to Cohens
19
demand for a stock deal and the present day valuing of the assets, and the
20
estimated expenses totaled approximately $825,000 as Leonard Cohen well

1
2
understood. Cohens share totaled a net of approximately $6 million while

Lynchs totaled slightly over $1 million. These amounts represent Cohen and
Lynchs rights to the intellectual property specifically described as belonging to
Blue Mist Touring Company, Inc. Proper valuations of all intellectual property
4
owned by Blue Mist Touring Company, Inc. are required as well as an
accounting of the royalty income LC Investments, LLC collected with respect to
assets owned by Blue Mist Touring Company, Inc. Exhibits KK: Westin fax to
KL and Greg McBowman dated September 20, 2000; McBowman schedule.
8
9
10
63.
A fax from Richard Westin to Cohen and me dated October 10, 2000
shows the ongoing concerns related to IRS matters, the use of Blue Mist
Touring Company, Inc. to pursue the stock sale to Sony, and the beginnings of
Westins proposal with respect to a deferred annuity. Westin also raises a
11
12
suggestion related to an Employee Stock Ownership Plan for Blue Mist. The
good news is that Kelley need not participate in either of these plans which
13
she most certainly chose not to. The comments specifically related to IRS
14
concerns are as follows: The problem is that in this case it is being very late in
15
the day and the IRS could argue that the real sale was from Leonard to Sony,
with the role of the insurer ignored. Nevertheless, Cohen pursued the option
16
of using a private annuity, new entity, and has now evidently not only taken the
17
position that he is the alter ego of that entity, who embezzled approximately
18
$6.7 million in corporate assets, but someone entitled to substantial tax refunds
19
due to a theft loss based solely on the Complaint filed in this matter and
20
possibly some version of the expense ledger. Its difficult to know what
1
2
ledger was submitted to IRS because that was submitted to them hastily in
December 2005 approximately six months before the default judgment. The
Complaint and default judgment themselves are evidence of overt acts used to
obstruct justice and, from my perspective, cover up and obfuscate the facts
4
related to the allegations that Cohen committed criminal tax fraud. The news
media coverage of a wanton, reckless female manager, ex-lover, who cold-
heartedly raided the elderly Buddhist Leonard Cohens retirement account
while he was on Mt. Baldy, and apparently wanted to attend one of his concerts
and communicate with him for no legitimate reason, really worked wonders
also. Exhibit KK: Fax from Richard Westin to Cohen and me dated October 10,
2000.
10
64.
11
12
On November 19, 2000, Richard Westin set forth a new proposal for
the disposition of assets, other than those that qualify for capital gain
treatment. The letter is addressed to Mr. Leonard Cohen and is clearly meant
13
to serve as a professional opinion of some sort. Leonard Cohen and I were
14
together when we received this. Cohen submitted a series of questions to
15
Richard Westin in response. Of course, the issues raised with respect to IRS
were of concern: The structure is novel and must be put in place before a
16
contract is entered into or is a sure thing. Neal and I think that the proposal
17
works, but there are no guarantees. The IRS could attack the deal by claiming
18
the real seller to say, Sony was yourself and the rest of the deal was a
19
contribution to an LLC. In other words, the IRS can attempt to unwind the
20
deal. That could be bad because the logical next step would be for the IRS to
1
2
claim that money that actually went to the LLC was a gift from you made
indirectly to your children, thereby attracting significant gift taxes. I will
provide you with an opinion that the deal works. That should eliminate any
penalties, but despite my august station, it may do nothing to discourage a

4
Revenue Agent from pressing the theories I just described. Westin went onto
advise Cohen: In order to get Neal wrapped in attorney-client privilege, it is
important that I get a letter from you (by fax is fine) authorizing me to hire
Neal to act on your behalf, with Neal reporting to me when I seek his financial
and consulting advice. The letter should suggest that this has been the
understanding all along, but we just now decided to formalize the
9
10
arrangement. After further discussions with Richard Westin and Neal

Greenberg, Cohen did provide Westin with the letter he requested on December
11
7, 2004. Prior to submitting that, Cohen wanted Westin to come up with a
12
proposal that would not potentially invite IRS inquiries. Exhibit LL: Richard
13
14
15
Westin Proposal to Leonard Cohen dated November 19, 2000.

65.
Therefore, on December 4, 2000, Westin wrote a letter to Kelley
Lynch and Leonard Cohen with responses Cohen submitted to Westin via email.
Apart from the IRS concerns about self-dealing and gifts to his children, Cohen
16
did not want his children involved in any corporate entity related to him and did
17
not want his children made beneficiaries with respect to this deal. This letter
18
addresses the questions raised. That would include the specific monies allotted
19
to me to repay the promissory note. That amount totaled $24,000. It is
20
addressed in the corporate records and, together with the $20,000 per year
1
2
payment in the management agreement, provided me with the income

necessary to pay down the promissory note and pay the taxes due on the
monies I received. This was Richard Westins proposal and both Leonard
Cohen and Neal Greenberg were well aware of that fact. The decision to use
4
any type of trust was nixed in favor of the LLC. At no time did I sell back my
income shares. I did ask if I could be indemnified and Westin felt Leonard
Cohen could agree to protect me from losses and with respect to certain
liabilities. Of course, a possible argument by the IRS is included in this letter:
The IRS may argue that there never really was a sale by the LLC, that in fact
LC sold the assets to SONY. As long as there is no current contract with SONY,
9
10
it is a tough position for them to take, but not impossible. Certain issues
raised in this fax were discussed, hashed out, and Leonard Cohen decided to
11
proceed with the transaction using a company he named Traditional Holdings,
12
LLC with the full understanding of my 99.5% ownership interest and the reason
13
for that interest. One of the reasons we both understood was due to the fact
that I was investing in this entity. Leonard Cohen also understood that this
14
entity bypassed his estate and reconfirmed this understanding when he signed
15
the Annuity Agreement, prepared by his personal tax and corporate lawyer, on
16
December 7, 2000. Natural Wealths Complaint addresses the fact that Cohen
17
personally was involved in the discussions about these deals, his desire to
18
pursue aggressive stock transactions, his full awareness of Traditional
19
Holdings, LLC structure (including his and my ownership interests); and

understood that the assets in Blue Mist Touring Company, Inc. (specifically
20
1
2
being sold to Sony) were to be valued, formally removed from Blue Mist
Touring Company, Inc.), and formally assigned to Traditional Holdings, LLC. It
was our understanding that Richard Westin would handle these legal
formalities. I was also given assurances that I would receive the Indemnity
4
Agreement on January 21, 2001 Cohen and I executed. See below. It was also
agreed that the parties could borrow monies from Traditional Holdings, LLC.
Any and all loans required documentation and Richard Westin agreed to
prepare those as they arose. It was my understanding, at the time, that
Leonard Cohens loans (advances & expenditures) were to be repaid within 3

years at 6% interest. I was repeatedly advised that all corporate distributions
9
10
to me should be handled as shareholder loans that Westin would recharacterize

at a later date. I was told that any actual loans I received from Traditional
11
Holdings, LLC would have to be repaid before the annuity obligation arose in
12
2011 but a 3-5 year repayment plan would generally be best. Leonard Cohen
13
and I discussed and understood these matters and he was well aware of the
fact that the profit and loss sharing with respect to this entity was
14
commensurate with our ownership interests as set forth in the corporate books
15
and records. I personally read the formal documents, prepared and filed by his
16
lawyer, to Leonard Cohen while we sat at his kitchen table. There was and
17
remains no trust, agreement related to a trust, or any discussion, once Cohen
18
elected to use Traditional Holdings, LLC, about a potential trust. I did not hold
19
my shares of this entity in trust for Leonard Cohen. Exhibit MM: Richard
Westin Proposal to Kelley Lynch and Leonard Cohen dated December 4, 2000.
20
1
2
66.
On December 7, 2000, Leonard Cohen wrote Richard Westin a
letter advising him: Further to our conversation, this is to confirm the

understanding that I have appointed Mr. Neal Greenberg to assist you in your
legal advice to me. Please explain to Mr. Greenberg (if you have not already)
4
that I expect him to treat my communications between himself and yourself in
confidence. This letter was signed by Leonard Cohen and wrapped Cohen,
Westin, and Greenberg in attorney/client privilege essentially leaving me in
the dark. This letter also confirms that Cohen was intimately involved with
these deals, understood all aspects of them (including the use of corporate
structures, etc.), and spoke to his representatives about these matters. Exhibit
9
10
11
12
NN: Leonard Cohen letter to Westin dated December 7, 2000 (wrapping

Greenberg in A/C privilege).
66.
On December 7, 2000, I was induced, by Cohen and his
representatives, to sign an Annuity Agreement. I was advised that Leonard
13
Cohens personal tax lawyer, Richard Westin, would form this entity properly;
14
make any and all necessary assignments; address the assignments that are
15
owned by Blue Mist Touring Company, Inc., would handle all tax matters, and
so forth. I relied on their statements and had no reason to doubt that these
16
matters would be handled properly. The Private Annuity Agreement, dated

17
December 7, 2000 was signed by me and Leonard Cohen and it is notarized.
18
This document sets forth an agreement with respect to an annuity obligation
19
and proves that Cohens arguments about my 99.5% ownership interest in
20
Traditional Holdings, LLC are moot and self-serving. This obligation was real
1
2
and the agreement was binding. The annuity obligation totaled $4,890,000.
Cohen was promised that the payments would begin in or around January 2011.
The Agreement clearly states that the obligations terminate upon the death of
the annuitant, Leonard Cohen. The Agreement also clearly states that Cohen
4
may receive advances (or loans). However, Until an advance has been paid in
full, the unpaid portion thereof shall bear interest and At the discretion of
Purchaser, such advances may be repaid by withholding payments otherwise
due under this Agreement. If Annuitant shall die with advances due and owing
Purchaser [Traditional Holdings, LLC], then such advances shall be satisfied by

Annuitants estate. The Annuitant is Leonard Cohen. His loans, advances,
9
10
and/or personal expenses, relating to Traditional Holdings, LLC are presently in

the vicinity of $6.7 million. That is approximately $2 million above and beyond
11
the annuity obligation. Cohen agreed to repay these loans at an interest rate of
12
3% and understood they had to be repaid within 3 years. He refuses to repay
13
the loans; will not address the loans; concealed this information from the Court;
attempted to argue that his personal expenses are corporate expenses; and has
14
now taken the position that he is free to embezzle nearly $7 million from a
15
corporation due to Los Angeles Superior Courts default judgment. The default
16
judgment releases Cohen from obligations to Lynch but is silent on his
17
obligations to the corporations themselves or the corporations obligations
18
towards Lynch. Additionally, Cohen gave the warranties and representations
19
that the Property he is transferring to the Purchase is free and clear of all
liens, pledges, and encumbrances of any kind whatsoever. The assets belong
20
1
2
to Blue Mist Touring Company, Inc. Cohen understood that the assignments to
that entity were non-revocable and the Complaint confirms that these matters
were not formally unwound or addressed. Richard Westin prepared Traditional
Holdings, LLC Minutes ratifying on behalf of the Company the Private Annuity
4
5
6
Agreement being formally entered into between the Company and Leonard
Cohen, as seller.
67.
Exhibit OO: Annuity Agreement dated December 7, 2000.
On December 7, 2000, I was induced into executing a Promissory
Note with Traditional Holdings, LLC. This document, as is true of the above,
was executed by Leonard Cohen and myself. It was also notarized. I am not in
possession of the original document at this time that there does not seem to be
10
a dispute as to whether or not I was provided with a Promissory Note and

instructed to sign it. This document was prepared by Leonard Cohens
11
12
personal tax and corporate lawyer, Richard Westin. The Note is in the amount
of $240,000. One disturbing aspect of this document is the statement that
13
Traditional Holdings, LLC had its principal place of business c/o Stranger
14
Management, 419 North Larchmont, Suite 91, Los Angeles, California. TH was
15
the holder of this note. I had an ongoing conflict with Richard Westin about his
position with respect to these entities have places of business or offices in
16
California and, specifically, at my former P.O. Box or former office address. It is

17
irrelevant to me whether they legally did or not. I remain convinced that these
18
entities have been treated as shams; all corporate formalities have been
19
willfully disregarded; and Leonard Cohen has now taken the position that he is
20
the alter ego and I was defrauded and fraudulently induced into entering into
1
2
many agreements and included on fraudulently included on various federal and

state tax returns and other documents transmitted to IRS, FTB, and State of
Kentucky. Ultimately, according to my legal and accounting representatives,
this Promissory Note was extinguished from the 2002 Traditional Holdings
4
federal tax return without my knowledge, permission, or authorization.
Perhaps Plaintiffs can now take the legal position that I am in default with
respect to this instrument. Richard Westin prepared the Traditional Holdings,
LLC Minutes ratifying this Promissory and the Management Agreement that
Cohen has interpreted in an interesting manner by willfully disregarding the

fact that it calls for two separate payments and electing to ignore the
9
10
11
12
paragraph that he finds distasteful. Exhibit PP: Kelley Lynch/TH Promissory

Note; Corporate Minutes dated December 21, 2000.
68.
On December 18, 2000, after Leonard Cohens decision to pursue
the 2001 Sony deal using a new entity that would own a private annuity,
13
Richard Westin caused Traditional Holdings, LLC to be formed. I personally
14
provided Cohens tax/corporate lawyer, Westin, with a very limited Power of
15
Attorney that granted him authority to file the formation documents. I also
attach hereto a copy of the Traditional Holdings, LLC 2001, 2002, and 2003
16
Annual Reports prepared by Leonard Cohens personal tax and corporate

17
lawyer, Richard Westin. Exhibit QQ: Traditional Holdings Formation
18
documents; Lynch & Cohen Powers of Attorney to Westin re. TH; State of
19
Kentucky Email; TH 2001, 2002, 2003 Annual Reports; Application for
20
Employer ID prepared by Westin who signed Kelley Lynchs name.

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69.
On December 20, 2000, upon receipt of the Black Beauty binder
and stock certificates Richard Westin presented to Traditional Holdings, LLC, I

was instructed, by Westin, to fill out Stock Certificates 1, 2, and 3 as follows:
Stock Certificate 1 certifies that Kelley Lynch is the owner as to Class B

4
common shares, all; Stock Certificate 2 certifies that Kelley Lynch is the
owner as to Class A common shares, 99.5 percent of all; and, Stock Certificate
3 certifies that Leonard Cohen is the owner as to .5% of all. Stock
Certificates 1 and 2, evidencing my ownership interest in Traditional Holdings,
LLC were signed and dated by me on December 20, 2000. Stock Certificate 3
was signed and dated by Leonard Cohen on January 8, 2001. Leonard Cohens
9
10
Stock Certificate 3, which he personally signed, is a simple one page document

that clearly states that he has a .5% of all units of the above above Limited
11
Liability Company. It is my personal opinion that this Stock Certificate alone
12
proves that Leonard Cohen understood his and my respective ownership
13
interests in Traditional Holdings, LLC well in advance of the closing of this

April 2001 transaction. Leonard Cohen testified at my 2012 trial that his tax
14
lawyer, in hindsight after we parted ways, rectified my ownership interest in

15
this entity. I find that preposterous and illegal. I attach hereto the Stock
16
Ledger filled in by Cohens tax lawyer, Richard Westin, which has entries
17
written by Westin himself. Those entries clearly indicate that Kelley Lynch
18
owns all shares of Class B; Kelley Lynch owns 99.5% of Class A; and, Leonard
19
Cohen owns .5% of Class A common shares. As of the date Cohen and I parted
ways, October 21, 2004, these stock certificates were not cancelled and/or held
20
1
2
3
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in trust for Leonard Cohens benefit. Exhibit RR: Traditional Holdings Stock
Certificates No. 1, 2, 3; Stock Ledger.
70.
John Rosenbergs January 2, 2001 letter to Kelley Lynch. John
Rosenberg was Leonard Cohens litigation attorney who handled the failed CAK
bond deal transaction and settlement negotiations. The Settlement Agreement,
dated December 7, 2000, was between Leonard Cohen and CAK/UCC Lending.
6
Clause 62 of Leonard Cohens Complaint sets forth a rather astounding
argument with respect to his personal transaction fees. The settlement
Plaintiffs accepted totaled $90,000. And yet, the Complaint lists $200,000 for
a failed transaction leading to the 2001. The CAK deal, which Cohen
10
personally chose not to pursue, did not lead to the 2001 sale. They were
pursued separately and this is the reason for the creation of LC Investments,
11
12
LLC. Its difficult to imagine what the remaining $110,000 might relate to.
Peter Lopez, Cohens transaction attorney, who negotiated the CAK deal with a
13
group of other people, including myself, died years after the CAK settlement.
14
After Cohens decision to pursue a stock deal with Sony, rather than the CAK
15
bond deal, Peter Lopez submitted a bill totaling $90,000. Cohen refused to pay
him and I spoke with Peters assistant, Christian, after his death in 2010, who
16
confirmed that the bill remained unpaid. Leonard Cohen made the decision not
17
18
to pursue the CAK deal but saw a reason to defraud Peter Lopez. Exhibit SS:
CAK Settlement Agreement dated December 7, 2000.
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71.
I was quite concerned about investing in an entity, Traditional
Holdings, LLC, via promissory note. No one was able to answer my questions
in a satisfactory manner. I therefore asked for and received an Indemnity
Agreement. I spoke directly with Leonard Cohen about this matter and he
4
agreed to indemnify me. He also instructed his personal tax and corporate
lawyer, Richard Westin, to draw up this document which was signed by both
Cohen and myself on January 8, 2001 and notarized. The agreement confirms
that Kelley Lynch has agreed to assist Leonard Cohen with certain personal
financial arrangements that entail the creation of Traditional Holdings, LLC

and in so doing has provided and will provide value assistance to Leonard
9
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Cohen. The promissory note I signed, in the amount of $240,000, was

notarized as well. For the value received, the Leonard agreed to indemnity,
11
save, and hold harmless Kelley Lynch from any and all claims, actions,
12
damages, liabilities, or litigation arising out of the following circumstances: any
13
obligation on her part to make good on a certain note for$240,000 in favor of

Traditional Holdings, LLC (TH) in the event that TH was for any reason unable
14
to: pay in the full the promise of full payment of a put described in the said;
15
or causes her to have to make any payment to TH (or the assignee or
16
transferree or successor of TH) with respect to the note. Cohen, at his own
17
expense, agreed to faithfully and completely defend and protect me against any
18
and all liabilities arising from this claim, cause of action and/or notice, and shall
19
at once stand in the shoes of Kelley Lynch and pay all amounts due as they
become payable with no right offset or to her claim for immediate and full
20
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2
payment. Cohen further agreed that, if he failed to successfully defend Lynch,

she may defend, pay or settle the claim, with full rights of recourse against
Cohen for any and all fees, costs, expenses and payments, including but not
limited to attorney fees, and settlement payments, made or agreed to be paid,

4
in order to discharge the claim, cause of action, dispute or litigation. This
agreement is also binding upon our heirs, successors, and representatives. My
lawyers continually advised Robert Kory to review this document. I will remind
the Court that Leonard Cohens personal tax lawyer, without my knowledge or
permission, extinguished the promissory note from the Traditional Holdings,

LLC 2002 federal tax returns. It is important to note that I was repeatedly
9
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12
13
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asked to assist Leonard Cohen not to control anything. Exhibit TT: KL

Indemnity Agreement dated January 8, 2001.
72.
Leonard Cohen and his lawyer extinguished the annuity in 2003 and
the promissory note in 2002. Therefore, this indemnity agreement covers

everything.
73.
On August 13, 2001, Internal Revenue Service issued a notice to
15
Leonard Cohen Requesting Information About Your 1999 Tax Return. This
16
inquiry asked Cohen to compare his tax records with the following list which
17
shows income amounts reported to IRS by your payers. This notice is

material and relevant due to the fact that the list provided by IRS includes a $1
18
million 1099 issued to Cohen by Sony in the year 1999. That $1 million was the
19
prepayment against the 2001 Traditional Holdings, LLC deal. Cohen had asked
20
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me to advise Sony that he would pursue the deal with them only if they
provided him with a non-refundable substantial prepayment or down payment
in the amount of $1 million. Leonard Cohen and his representatives handled
this amount as a loan for federal tax purposes in 1999. Sony then issued a
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1099 in the amount of $1 million and transmitted this information to IRS. This
is also evidence that IRS inquiries into the manner in which Cohen and his
representatives handled his tax matters became consistent and increasingly
frequent. Leonard Cohen never transferred (or paid through) this amount to
Traditional Holdings, LLC. Exhibit UU: IRS Notice: August 13, 2001 - $1
million prepayment TH deal.
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74.
Clause 61 of Cohens Complaint lists Traditional Holdings, LLC
payment of $500,000 for federal income taxes and penalties due on Sonys $1
11
12
million advance paid in 1999. This advance was paid directly to Leonard
Cohen; he elected to handle it as a loan rather than the non-refundable
13
prepayment or down payment; Sony is the party that inadvertently issued the
14
$1 million 1099 to Leonard Cohen for the year 1999 which was corrected; and
15
Leonard Cohen did not transfer the $1 million to Traditional Holdings, LLC.
Cohen simply believes that due to his decision that this entity is obligated to
16
pay his personal expenses.

17
75.
On April 18, 2001 Grubman, Indursky wrote Cohen summarizing
18
the agreement between Sony Music International, Leonard Cohen and

19
Traditional Holdings, LLC. Leonard Cohen and I carefully reviewed this letter.
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I was forced to read it to him while he soaked in a bubble bath and exposed
himself to me. The letter confirms: As a separate matter, we also want to
advise you and Holdings that this firm is not a financial or tax advisor and has
not provided any tax-related advice to you or Holdings in connection with this
4
transaction. In addition, we have had no role in the formation of Holdings (and
have not reviewed or been provided with copies of any of its formation
documents) or in structuring the legal arrangement between you and Holdings.
While we have prepared certain documents required to implement the tax and
financial advice of your other advisors, we have done so at their request and
direction. We have also assisted your tax and financial advisors by providing
9
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explanations of the relevant entertainment industry and intellectual property

issues raised by the transaction. With respect to the tax-related issues
11
presented by the Agreement, we have, pursuant to your and Holdings request,
12
consulted with and followed the advice of Richard Westin. It is our
13
understanding that you are relying on their advice regarding these matters. I
did not provide any advice whatsoever related to tax, financial, corporate, or
14
legal matters. Cohen personally hired Neal Greenberg and Richard Westin.
15
Those were the individuals, who consulted with Cohen about these matters,
16
handling the tax and financial advice. The Grubman firm represented Leonard
17
Cohen. Richard Westin represented Leonard Cohen. I was unrepresented.
18
Exhibit VV: Grubman, Indursky & Schindler letter dated April 18, 2001 to
19
Cohen and TH.
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76.
At Leonard Cohens request, I agreed to a Durable General Power
of Attorney prepared by his attorney. This document was signed by Leonard

Cohen, in his individual capacity and as Trustee of the Leonard Cohen Family
Trust UTD October 2, 1998. It was notarized and Cohen asked my parents to
4
serve as witnesses. Leonard Cohen has not explained the type of mental
impairment he evidently had the entire time I knew him that permitted him to
micro-manage deals, direct his business affairs, scrutinize his sales figures,
royalties, income, finances, and expenditures, sign documents, and so forth. I
do not have Mata Haris miraculous seduction powers and there is no evidence
that Cohen was under a spell of any sort. This is a highly educated individual
9
10
with a background, according to interviews he personally has given over the

years, in business, law, and commerce. Cohen is also highly literate and
11
understands the meanings of words, sentences, agreements, and concepts.
12
And, Cohen has advised at least one interviewer that he personally handled his
13
business matters, negotiations, and financial discussions and would no longer

rely on a lawyer. Leonard Cohen asked me to assist him with many matters;
14
began traveling more extensively; needed my help with homes he purchased

15
(using Traditional Holdings, LLC assets) for his girlfriend and son; and I
16
agreed. That is the actual reason that he executed this Durable Power of
17
Attorney. Cohen testified that he did indeed use assets to purchase homes and
18
took money from the Traditional Holdings, LLC account. He simply refuses to
19
address the fact that the Traditional Holdings, LLC assets had been
dissipated due to the fact that he personally borrowed or caused to be
20
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3
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5
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7
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expended approximately $6.7 million and feels entitled to those sums. Exhibit
WW: Trial Transcript (pages 285-288); Kelley Lynch Power of Attorney.
PD: Now, you learned in 2004 that your that the account that Traditional
Holdings account, the money that you were running low, correct? Cohen: It
was running low PD: That funds in that account, that Traditional Holdings
account, they were running low, yes or no? Do you remember that? Cohen: I - I
discovered that they were being dissipated. PD: Okay. Now, you panicked
correct? Cohen: I was concerned, yes. PD: And in fact you had actually taken
money from that account to buy homes, correct? Cohen: Yes, I had. PD: You
took money from that account to buy a house for your son, correct? Cohen:
Thats correct. PD: To buy a house for your girlfriend? Cohen: Yes. Kelly:
Okay. So you -- its fair to say that you did take money from that account?
Cohen: Thats correct, Sir. PD: You were aware enough about that account to
know that you could take money from that account? Cohen: Thats correct.
PD: Now, isnt it true that well, before I go there, do you blame well, you
actually had a financial consultant who invested the money in that account,
correct? Streeter: Objection; relevance. Court: Let me see counsel at sidebar.
RT 285-288
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77.
At some point in or around February 2002, Sony transmitted a $7
million 1099 to Leonard Cohen for income related to the Traditional Holdings,
13
LLC deal. This caused tremendous hysteria on the part of Leonard Cohen,
14
Richard Westin, Neal Greenberg, Ken Greenberg, and possibly others. I merely
15
faxed the 1099 to Clevelands with a note asking him to call me the following
16
Monday. Cleveland decided to compose a rather alarming letter to Leonard
17
Cohen, which was sent directly to Cohens home in Los Angeles, concluding
18
that he shuddered to think of the penalties and interest due on that amount and
raising other tax, financial, and accounting matters. I attach hereto two emails
19
between Leonard Cohen, Richard Westin, and me dated February 11, 2002. My
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email to Cohen (with Westin copied in) is a response to some of the matters
raised in Clevelands letter that he later advised me and Stuart Fried, Grubman
firm, was a cover-your-ass letter. Some of the issues I addressed were the
sloppy records kept by Cohens bookkeeper, Jen Brown, who was a friend of
4
Lorca Cohens and took over some of the bookkeeping after Jean Ransick
retired in or around 1998; the fact that I would not be the person to handle any
1099 matter including the inadvertent $1 million 1099 Sony issued Cohen
with respect to the non-refundable prepayment on the Traditional Holdings,
LLC deal; the fact that I would not advise anyone on the handling of income as
a loan or anything else for that matter; the countless problems with IRS that
9
10
have arisen due to these deals, corporate structures, and so forth; the fact that
I am incapable of resolving anything with the IRS and I assume, as has always
11
been the case in the past with accountants, that when I forward something to
12
them they are dealing with it; the problems that would arise when Cohens
13
accountant would advise us that substantial tax payments were due on October
15, 2005 (when the returns were finalized and messengered) which provided no
14
time whatsoever to address where the funds to pay the bills would come from;
15
the fact that paperwork needed to be prepared when monies were taken from
16
Traditional Holdings, LLC and Westin was in charge of that; the fact that Ken
17
Cleveland assumed the $7 million was personal income to Cohen when he had
18
worked on the Traditional Holdings, LLC deal; the fact that I am not an
19
accountant and it is not my job to handle many of the things that Ken raised
which would extend to notifying Sony that the 1099 had been issued; the fact
20
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that Cohens entities were causing considerable extra work because I had to
pursue various parties and provide paperwork to have simple bills paid for
accounting services on Cohens behalf; and my position that Ken Clevelands
letter was a blessing in disguise because it gave me an opportunity clarity

4
many things with Leonard Cohen personally. Richard Westin responded to my
email, copying Cohen in on this reply, and confirmed that he agreed with the
issues and statements I made in my email; advising how the situation with
respect to tax returns should be handled; and telling Cohen to hire a new
accountant. Cohen personally elected not to. Exhibit XX: Lynch & Westin
emails (cc: Cohen) dated February 11, 2002.
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78.
Richard Westins letter to Leonard Cohen dated March 6, 2002,
excerpted in the Complaint, gives an overview of these entities and my role.

11
12
Richard Westin advises Cohen that all loans must be documented. That is not
something that I handled. Westin confirms that without my assistance,
13
investment actually, IRS could view this transaction as Leonard Cohen simply
14
selling something to himself. In other words, IRS could raise issues related to
15
self-dealing. Westin explains that I am to be provided with $44,000/year

($20,000 addressed in the Management Agreement; $24,000 addressed in the
16
corporate formation documents). Westin also confirms that I received $240,000

17
from Traditional Holdings, LLC to allow me to pay taxes. As this amount
18
relates to profit, which was to be distributed in accordance with Cohen and
19
my equity interest (99.55% Lynch; .5% Cohen), there are no issues with respect
20
to this amount apart from the fact that I was being allotted monies to pay
1
2
corporate taxes and Westin failed to address (although I repeatedly raised this
issue) how these distributions would ultimately be addressed. I was
continuously assured that Richard Westin would recharacterize the nature of
all share holder loans which is how I was instructed to characterize all
4
distributions. I followed those instructions. The letter then goes onto address
the never ending discussion about Leonard Cohens gifts to family members
and friends. That is also something I would not have handled. Due to some of
the very serious issues that arose with respect to inadvertent Sony 1099s to
Leonard Cohen in the amounts of $1 million and $7 million; IRS inquiry into the
1999 $1 million prepayment against the 2001 Traditional Holdings, LLC deal;
9
10
the fact that the assets remained in Blue Mist Touring Company, Inc.; and, my
involvement in these entities, I asked Richard Westin to write a letter
11
confirming what my role was with respect to these entities for Leonard Cohen
12
personally. In the Complaint filed in this matter, Cohen acknowledged receiving
13
and reviewing this document. A number of these items were addressed, on the
fraudulent expense ledger as misappropriated funds. At least two payments
14
($44,000 each) from Traditional Holdings, LLC to me (and then my repayments

15
16
17
to the entity) are completely missing from the expense ledger. Exhibit YY:
Richard Westin letter dated March 6, 2002.
79.
On March 10, 2002 Richard Westin wrote a letter to Leonard Cohen
18
& Kelley Lynch regarding Traditional Holdings, LLC and comments on the
19
binder which refers to the Black Beauty corporate book. The letter explains
20
certain documents and addresses minutes adopting a management agreement.

1
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Westin explains that all this agreement does is move the money Kelley gets for
managing TH from inside the operating agreement to a separate document.
This is done for the technical reason that it creates tax law clarity to as the
nature of the payment. Having it in the operating agreement makes it unclear

4
whether it is a so-called guaranteed payment or a payment deemed made with
an outsider. Because the allocation provisions in the LLC agreement are
complicated enough, I wanted to remove this piece to keep the tax picture
clearer. This is purely a technical issue. This was fastened on as compensation
in order to keep the structure commercially reasonable. To date, KL has not

been paid. She is owed for the year 2000 and 3 months of 2001. The next
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payment is due June 30. This letter relates specifically to my Management

Agreement which provides for two payments: $20,000 per month and $20,000
11
per year. The only reason Westin decided to create this document, as he clearly
12
states, is due to the tax picture and keeping it clearer. The monies provided
13
for in this agreement are taken from the yearly profits. I have asked Internal
Revenue to address this management agreement as it relates specifically to the
14
tax picture. Leonard Cohen and I signed this management agreement and
15
the minutes were signed as well. At least one copy of this agreement was
16
placed, with the minutes, into my business file that Leonard Cohen wrongfully
17
seized from my office. He is now allegedly arguing that he never signed the
18
document. The same minutes also ratify the stock certificates to be issued by
19
the company and approves the note I signed. Westin also enclosed minutes
ratifying the Private Annuity Agreement signed by Leonard Cohen and Kelley
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Lynch. Westin goes onto address the durable Power of Attorney that I was
asked to sign; was prepared by Richard Westin; and the sole purpose of the
document was to clarify to anyone dealing with later documents that Kelley
had the authority she claimed to deal with Leonards stake in the company. It
4
was also used to assist Cohen with matters such as closings related to the
homes he purchased for his son and girlfriend using Traditional Holdings, LLC
assets. Westin foresaw Cohen amalgamating his loans and repaying them as
one. This is precisely what Leonard Cohen confirmed he planned to do time
after time again. Westin also states that Leonard Cohens pattern of
borrowing is dangerous to the structure and prepared Minutes with respect to
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11
12
that pattern. Exhibit ZZ: Richard Westin letter to Cohen & Lynch dated March
10, 2002.
80.
On October 8, 2002, David Woltz, IRS Office of Chief Trial Counsel,
sent a letter to Richard Westin. Mr. Woltz had begun preparing for trial and
13
requested a meeting and information and documentation. The document
14
request included 1) all documents related to the $1 million payment from Sony,
15
including correspondence, contract, agreements, royalty obligations, loan

documents, emails, letters, checks; 2) all documents related to all royalty
16
arrangements between the Cohen and Sony; 3) all documents that you intend to
17
present to the Tax Court at trial; 4) identify all facts and documents supporting
18
your allegation that the $1 million payment from Sony is not taxable income in
19
the tax year 1999. It is important to note that Cohen argued that this income
20
was not taxable in the year 1999 and would have been recoupable had the deal
1
2
not closed. Sony pursued a deal first with Blue Mist Touring Company, Inc. and
then, due to concerns about collapsible corporations, with Traditional Holdings,
LLC. This $1 million was income to Traditional Holdings, LLC in the year 1999
and should have been transferred to the corporation and repaid with interest.
4
Sony does not have an account with Traditional Holdings, LLC from which they
could recoup this amount. Their account is with Leonard Cohen. David Woltz
should revisit this matter. Furthermore, Cohen requested a substantial, $
million, non-refundable downpayment. At this point, I had serious concerns
about the manner in which both the 1996 and 2001 deals had been handled by
Cohen and certain of his representatives. It is my personal opinion that when
9
10
the IRS began to audit the $1 million prepayment, submitted a document

request to Richard Westin, while I simultaneously asked how to repay the
11
promissory note, it is entirely possible the arguments I am addressing were
12
conjured up in anticipation of further potential inquiries by IRS. It is
13
impossible to imagine that someone who received inadvertent 1099s for $1

million and $7 million, respectively, wouldnt have cause for great alarm,
14
particularly when Leonard Cohens accountant wrote that he shuddered to

15
think of the penalties and interest. A copy of this Motion and all attachments is
16
being simultaneously hand delivered to Agent Lius Tejeda, Internal Revenue
17
Service. Exhibit AAA: David Woltz, IRS Office of Chief Counsel, letter to
18
Richard Westin dated October 8, 2002.
19
20
81.
Richard Westin, Leonard Cohens personal tax and corporate
attorney, prepared and transmitted LC Investments, LLC K-1 partnership for

1
2
the year 2003 to the State of Kentucky. The Kelley Lynch K-1 indicates that I
have a 99.55% ownership interest in LC Investments, LLC while the K-1 for
Leonard Cohen indicates that he has .45% ownership interest in LC
Investments, LLC. Leonard Cohen submitted a declaration to the Court in

4
support of the default judgment. That declaration, the Complaint and other
documents, are evidence that he is the sole owner of LC Investments, LLC. The
LC Investments, LLC K-1s show $0 income for 2003 and undermine the
expense ledger used to support the default. Exhibit BBB: State of Kentucky
8
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Schedule K-1 for Lynch & Cohen 2003; LC Investments, LLC Cohen K-1.
82.
Leonard Cohens Complaint in this matter refers to letters he
received from Neal Greenberg on January 16, 2004 and June 25, 2004,
respectively. While Cohen attempts to argue that I intercepted these letters,
11
12
the notion is preposterous. Leonard Cohen intentionally provided my

management offices mailing address to everyone but his closest friends. I
13
provided Leonard Cohen with an office in Stranger Managements offices. I did
14
not charge Leonard Cohen rent for this office. Cohen had a desk, in box, out
15
box, filing cabinet, table where fan mail was stored until it could be reviewed,
and boxes of archival materials. Cohen had keys to Stranger Managements
16
office and frequently spent time there alone reviewing his mail, statements,
17
business documents, legal documents, corporate records, and all personal and
18
business mail. Cohen and I would spend hours reviewing the materials in his
19
office that were not merely to be filed. What Cohen fails to address with
20
respect to the Warning Letters are the references to IRS matters and his
1
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nearly $6.7 million in loans (and expenditures) from Traditional Holdings, LLC.
Leonard Cohen received and reviewed these letters. His response was to
advise me, and others, not to inform Neal Greenberg of future income. That
included, but was not limited to, the $1 million advance Cohen received with
4
respect to the studio album Dear Heather. Rather than invest this money
with Neal Greenberg, Cohen personally chose to maintain these funds in his
personal City National Bank account. Neal Greenberg was concerned about
Cohens level of borrowing from the Traditional Holdings, LLC account and
advised me of that numerous times. I absolutely conveyed this information to

Leonard Cohen but had no obligation to do so; was not in charge of Cohens
9
10
finances; and was not hired to be his mother. If Neal Greenberg and Richard
Westin felt Cohens level of borrowing was dangerous to the structure they had
11
a duty and obligation to discuss this with Cohen personally. No one had the
12
ability to interfere with Cohen, Westin, and Greenbergs ability to pick up the
13
phone and call one another or email one another directly. Leonard Cohens
Affidavit in the Natural Wealth matter (attached hereto as Exhibit IIII) is highly
14
instructive. It appears that in the year 2002, after IRS began inquiring about
15
numerous matters, Leonard Cohen (and possibly some of his representatives)
16
intentionally began to confuse issues, willfully failed to communicate with one
17
another properly (if that was indeed what occurred), and may have planned to
18
defend themselves in this manner. Of course, at that point in time, Cohen,
19
Westin, and Greenberg felt that Cohen and I would remain close personal
friends. No one that would put me and my family in this type of situation was
20
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ever a friend of mine. And no one who was a friend of mine would lie so
excessively about me and attempt to blame their wrongdoing on me while
wrongfully converting my property to themselves and obtaining fraudulent tax
refunds blaming me while pursuing third party recovery from numerous

4
parties.
Excerpt of January 16, 2004 cover your ass letter.

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8
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11
1. Please make sure the loans from Traditional Holdings, LLC are properly
documents. 2. We havent been reflecting any unearned interest in the value of
the loans from Traditional Holdings on our monthly statements. Hence, the
loan amounts are larger. Also, the monthly earnings amount would be larger is
we reflected the accrued interest. 3. By borrowing so much money, there is an
argument, perhaps remote, that the IRS may question the original transaction.
If the loans have been documented, there is a better case. There would be
millions of dollars of back taxes if the IRS successfully challenges the original
transaction.
12
Excerpt of June 25, 2004 cover your ass letter.

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14
15
16
17
18
19
2. IRS DANGERS: TWO ISSUES. A. The first issue is that Traditional

Holdings is being run without all the formalities required of a business. The
IRS might find it easier to recharacterize the original transaction (the sale for
a private annuity). The fact that our monthly emails to you shows that
Traditional Holdings treats the loan as an asset is good. If you pay the loans
back, that too is good. B. A second issue can arise. Insofar as you have been
taking loans from an operating business, the IRS might classify them as
disguised salary. If so, there are huge back taxes to pay. Once again, our
monthly email which shows you treating the assets as loans effectively (by
treating total assets as including the loan balances) probably only helps a tiny
bit. Paying back the loans will indeed help.
20
Exhibit CCC: Neal Greenberg IRS Danger Warning letters dated January 16,
2004 and June 25, 2014.
2
3
4
5
83.
Leonard Cohen and my compensation agreement had three
components. I was to receive 15% of all gross income; she was to own 15% of
all intellectual property including book publishing and artwork/lithographs;
and, I was to receive an entirely different percentage with respect to
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7
merchandising in connection with Cohens tours. Furthermore, Cohen agreed

to compensate me properly for the period from April 1988 to approximately
1995 when he did not pay me the full 15% commission although I most
certainly was his personal manager and worked incredibly hard and diligently
10
on behalf of this individual and his family. The agreement with respect to
commissions for services rendered as personal manager were, as is customary,
11
in perpetuity for items created and released during the period I served as
12
manager. In this instance, that would be all music publishing, book publishing,
13
lithographs, and other royalty generating products such as sheet music, ring
14
tones, and so forth. On June 30, 2004, Richard Westin wrote and confirmed
15
16
that Old Ideas, LLC had been formed as a Delaware entity and for income tax
purposes it was a partnership. The Certificate of Formation is included in the
body of these emails. Westin confirmed that this was formed as a partnership
17
because he assumed I wanted to get the commission. Westin understood that I
18
have a 15% interest in all Cohens IP including that intellectual property
19
related to the Dear Heather studio album. While he did not represent me,
20
and had no actual understanding of Cohen and my agreements, Richard Westin

1
2
understood very clearly that I had a 15% interest in all intellectual property. As
of October 21, 2004, the publishing related to Dear Heather was to be
assigned to Old Ideas, LLC and that is why this entity appears in the liner
notes. The judgment is silent as to this entity and my 15% ownership interest.
4
This company did not register to do business in California until 2011. Exhibit
DDD: Westin emails re. Old Ideas, LLC; Dear Heather liner notes publishing
Old Ideas, LLC.
84.
Richard Westins email of July 1, 2004 (to Kelley Lynch and Cohens
transaction attorney, Stuart Fried) confirms that he caused CT Corporation
Systems to form Old Ideas, LLC, a Delaware corporation, and it is a
10
partnership for income tax purposes. The reason for this is because Westin
understood that my compensation arrangement with Cohen included a 15%
11
12
ownership interest in all intellectual property. I was assuming you wanted to

be a 15% member to get the commission. While Westin referred to my
13
ownership interest as a commission, he was not my attorney and was not
14
familiar with the specific terms of Cohen and my agreements. It is not
15
16
17
technically a commission. It is an interest in that intellectual property.

85.
My emails to Stuart Bondell, Ian MacKay, and Denise Donlon, Sony
Music, dated July 22, 2004, express Cohens grave concern about being viewed
as a Canadian roster artist. Cohen is one of the only artists, if not the only
18
artist, on Sony who is not assigned to his home country (Canada) but rather is
19
contractually signed internationally through New York. These emails also
20
1
2
demonstrate some of the issues I was actually involved in negotiating. For

example, the royalty rate Cohen received. These emails were forwarded to
Cohen, who had commented that the first email to Ian MacKay and Denise
Donlon (Sony Canada) was an excellent letter. This particular note to Cohen
4
states that I hope this is an excellent letter as well. I tried to be as direct and
as skillful as possible. Sony ultimately wrote Cohen thanking him for
permitting me to step in, cut through the over-lawyering, table certain
unresolved issues, and deliver Dear Heather. I have now evidently
misappropriated my commission for that work. Everything was run past

Leonard Cohen; reviewed with Leonard Cohen; discussed with Leonard Cohen;
9
10
and done in accordance with Cohens wishes, instructions, and demand.

Personally, I could care less where he was signed U.S. or Canada. The
11
obvious concern on his part is the possibility that the tax authorities in Canada
12
might view him as a resident and the fact that he was a Canadian roster artist
13
as evidence of that. Exhibit FFF: KL email to Leonard Cohen with forwards of

emails to Stuart Bondell (Sony International), Ian MacKay (Sony Canada), and
14
Denise Donlon (Sony Canada) dated July 22, 2004.

15
86.
In my (tsimar@aol.com) email to Leonard Cohen (baldymonk) dated
16
September 16, 2004, I respond to Cohens question (contained in the body of

17
the email) Business Expenses $168,254.93 Is that a commission? My
18
response was: Yes, did you receive the attachment to the breakdown. It lists
19
each and every item and the category is next to it. Business expenses include
20
my commission and that is why this is so high. Sorry. As a courtesy, due to

1
2
Cohens obsessive interest in the gifts he provided his family and friends, I
would break down his monthly expenditures (as they appeared on his personal
bank statement) for Cohen and email him this breakdown. This email between
Cohen and myself is highly relevant for a number of reasons. First of all, Cohen
4
is referring to his personal bank statements which were mailed directly to his
home. I did not pick up (or intercept) his mail at his home in Los Angeles.
He lived there and his daughter lived downstairs. Due to the fact that Cohen
was obsessive about the gifts and support he provided his family and others,
income and expenses, I would present him with monthly breakdowns of the
checks written. This was done purely as a courtesy. Cohen also personally
9
10
signed most of the checks (written against his account) that were included with
the statements and copies of all checks, incoming and outgoing wires, bank
11
overdrafts, Canadian drafts, credit card payments, automatic payments, and
12
other items were included (explicitly) with the statements. Another reason for
13
the relevance of this email is that it is dated September 16, 2004. As of

September 16, 2004, Cohen had reviewed his personal bank statement,
14
questioned an item on the statement, and I clarified what that expense was.
15
Cohen reviewed his statements each and every month and I, as a courtesy,
16
would email Cohen a summary showing items in categories he requested (such
17
as gifts to his adult children). The only irregularity Cohen stumbled upon in the
18
October 2004 was my decision to report what I felt was tax fraud to Internal
19
Revenue Service. Exhibit GGG: Kelley Lynch (tsimar) email to Leonard Cohen
(baldymonk) dated September 16, 2004 [Commission 1099 information].
20
1
2
87.
City National Bank provided Stranger Management with a copy of
Cohens personal bank statement so that we had easy access when Cohens
accountants, business manager, or other representatives, requested
information. At no time, prior to September 16, 2004, did Cohen raise concerns
4
about irregularities with respect to this personal account. In this particular
email Cohen is referring to the commission I was paid for services rendered in
connection with the extremely long negotiations and advance related to the
2004 studio album, Dear Heather. I have received no actual royalty payments
or reports in connection with that album or any other income for my share of
intellectual property. The advance Cohen received was deposited directly into
9
10
Cohens personal City National Bank account and I was most certainly entitled
to a commission . Cohen personally confirmed that he was aware of that fact in
11
this email. However, Clause 21, of Kevin Prins declaration, in support of the
12
default judgment, states: As discussed above, no agreement existed between
13
Cohen and Lynch pursuant to which Lynch was to receive any income or
payments from Cohens personal checking account. My agreement with
14
Leonard Cohen, pursuant to my services as his personal manager, was 15% of

15
all gross income. Period. No caveats, no exclusions. Cohen steadfastly refuses
16
to provide me with a 1099 for commissions paid in the year 2004 (including
17
with respect to the amount listed in this email); the documents submitted to
18
this Court are confusing, obfuscate issues, are entirely fraudulent; and nothing
19
is properly addressed on the expense ledger. Furthermore, I believe I was

paid additional commissions from Leonard Cohen personally in the year 2004
20
1
2
and he is the only individual in possession of that information. An additional

element of confusion has arisen because Leonard Cohen has taken the position,
in hindsight, that any checks made payable to me personally are not valid
Evidently, Cohen thinks he has the right to tell me how I should have checks
4
made payable to me. All checks were payable to me personally because
Stranger Management was a d/b/a. Leonard Cohen is an entirely controlling
and aggressive individual. City National Bank confirmed that they do not keep
records dating back this far. Exhibit HHH: Diane Baxa, City National Bank,
8
9
10
email to Kelley Lynch dated March 29, 2013.

88.
Leonard Cohen testified at my 2012 trial that his email account is
the same, baldymonk (aol). He also testified that he had never changed his
social security number and did not have a California drivers license. This
11
12
testimony raises additional problems. Cohen did indeed have numerous social
security numbers and, after Marty Machats death, asked his accountant to
13
resolve this situation. He is well aware that he had previously changed his
14
social security number. Cohen also testified that he does not have a California
15
drivers license. What he failed to address is the fact that, for the entire 20
years I knew him, he used his sisters New York address as his New York
16
drivers license address. Leonard Cohen has resided in California since 1993
17
and the Complaint confirms that he is a resident of Los Angeles. The California
18
DMV has the following rules for new residents to the State of California: If
19
you are a visitor in California over 18 and have a valid driver license from your
20
home state or country, you may drive in this state without getting a California
1
2
driver license as long as your home state license remains valid. If you become
a California resident, you must get a California driver license within 10 days.
Residency is established by voting in a California election, paying resident
tuition, filing for a homeowner's property tax exemption, or any other privilege
4
or benefit not ordinarily extended to nonresidents.
http://www.dmv.ca.gov/portal/dmv/detail/dl/dl_info. These matters are relevant
and material to the issues at hand because they prove that Cohen perjured
himself over the social security information (which I did not email around as
the prosecutor stated during my trial but did bring issues related to the his
numerous social security numbers to the attention of IRS as Agent Sopko
9
10
specifically advised me to do so) but it proves that even with something as

simple as a drivers license, Leonard Cohen feels that he is above the law. It is
11
Leonard Cohens sense of entitlement that has led to his overwhelmingly
12
preposterous situation. Fortunately, he has money and powerful and a team of
13
lawyers, and government actors, who appear willing to say or do anything for
him. Most Americans would be in prison by now. Exhibit III: Trial Transcript
14
(pages 301-303; 319)

15
16
17
18
19
PD: Okay. You also you never changed you know Ms. Lynch had information
regarding your drivers license and social security? Cohen: Thats correct.
PD: You never changed your social security number, correct? Cohen: Thats
correct. PD: You never changed your social security number? Cohen: NO, I
didnt change my social security number. PD: Or your California drivers
license? Cohen: I dont have a California drivers license? PD: Okay. Youve
never changed your email, correct? Cohen: Correct. PD: Its still the same
email, baldymonk, since youve been using since the 90s, correct? Cohen:
Thats correct. RT 301-303
20
1
2
3
Streeter: How come you havent changed your social security number? Cohen:
I dont think thats -- I dont think you can change your social security number.
RT 319
4
5
6
7
89.
I received what I viewed as an alarming email from Richard Westin
on September 24, 2004. Communications with Cohen, Westin, and Greenberg

were becoming increasingly bizarre, paranoid, and incomprehensible. This
email was particularly startling. In this email Westin addressed the tax return
he prepared, as Cohens tax and corporate lawyer, for LC Investments, LLC and
9
tax payments due. At this time, Westin was also handling the tax returns for
10
Traditional Holdings, LLC on Cohens behalf. This rather brief email ends with
11
the following remarkable statements: Incidentally, this year, I plan to stand up
12
13
and fight for you over your position in TH. Out of kindness (or something) you
got into that deal for LCs benefit and then Neal [Greenberg] tried to (pardon
me) fuck you. That has to stop. We need to put our heads together about that.
14
Perhaps I am wrong I hope so. I did not ask Westin for any details about this
15
matter; had already replaced Ken Cleveland with Dale Burgess as an
16
accountant; and had submitted paperwork to IRS confirming they were
17
permitted to discuss her personal tax matters with her new accountant. One
18
thing Greenberg and Westin differed over was whether I should receive nearly
100% of the profit or 50%, if I recall correctly. This occurred at some point
19
during the 2002 extended discussion between all parties including Cohen. This
20
1
2
was particularly odd as this issue was addressed in the corporate records and
something they discussed with Leonard Cohen directly in 2002 when Lynch
inquired about the payments necessary to address the promissory note
requirements. That issue also caused quite a lot of hysteria on the part of
4
Cohen, Greenberg, and Westin. Westin advised Lynch, and he prepared the
corporate records, that the documents provided addressed profit and loss
sharing in accordance with Lynch and Cohens equity interests. At any rate, no
explanation was given for how Greenberg intended to fuck Lynch. Exhibit JJJ:
8
9
10
Richard Westin email to Kelley Lynch dated September 24, 2004.

90.
Richard Westins email of September 20, 2004 to Kelley Lynch (with
my original message of 9/20/2004 enclosed) addresses my position that Cohen

related entities do not have a business address at my office. This was an
11
12
ongoing situation and I was adamant about my position: There is no office for
this. I have an office here Stranger Mgmt. and LCI has a mailing address.
13
This is only a mailing address so this is not an office for LCI. And theres no
14
way you can make this an office. This is MY office. Westin wrote that it does
15
seem surreal, but California has a decent case for imposing its tax on the
entity. Frankly, it seems unlawful rather than surreal. Westin went onto state
16
that the reason for the decision to use my office address (for Cohen related
17
entities) was that the only office was mine, even though it is little more than a
18
mail drop, it is where the books and records are kept and mail is received,
19
including royalty checks. My business office is not where the mail was
20
received including royalty checks. The mail went, as Cohen and I agreed, to my
1
2
P.O. Box on Larchmont Blvd. That has now been turned into something sinister
as well so I do wonder if Cohen told the truth about his reasons for doing
anything throughout the years. Westin then raised the Franchise Tax Board, an
ongoing concern with respect to these entities, and argued that My advice is
4
to get the entity out of California by establishing some kind of mail drop office
in Nevada or maybe Delaware. I imagine CT Corporation Systems can do it
efficiently. I do it for my consulting company. I use a Nevada service and I hold
my breath hoping KY does not seek to tax the company. Leonard Cohen
refused to entertain the notion of a Nevada company although he appears to

have had one, Leonard Cohen Productions, Ltd., as early as 1972. The issues
9
10
addressed in this email were ongoing concerns about tax matters, state taxes,
and whether or not an office actually existed in California for LC Investments,
11
LLC. As of the date I filed the Motion to Vacate (August 9, 2013), this entity
12
continued to list me as the Registered Agent and my former PO Box as the
13
place of business. Leonard Cohen evidently decided to address that, after the
Motion was filed, and Robert Kory became the Registered Agent and his office
14
address is now the business address. I am evidently not permitted, according

15
to the response documents, to effect service upon the Registered Agent of an
16
LLC that transmitted fraudulent K-1s to the State of Kentucky and IRS
17
indicating that I am a 99.5% partner (Kentucky K1s) with no income for the
18
years 2003, 2004, and 2005. That information, in and of itself, proves that the
19
expense ledger is evidence of perjury, financial and accounting fraud. This

information was transmitted to Internal Revenue Service in an attempt to
20
1
2
defend Leonard Cohen against the allegations that he committed criminal tax
fraud. Robert Kory was quite clear with Agent Tejeda when he wrote that my
prior comments were a nuisance but Agent Sopkos email was a game
changer. In any event, it is quite convenient that Leonard Cohen is able to use
4
fraudulent restraining orders to prevent lawful service of process, prohibit me
from requesting IRS required tax and corporate information, and/or prevent
Leonard Cohen from providing me with that information. It is particularly
convenient given the fact that the default judgment was entered against me on
May 15, 2006, does not appear to be retroactive, and some of the information I
have requested is for the years 2004 and 2005. Blue Mist Touring Company,
9
10
Inc. continues to list Lynch as its Registered Agent and her former P.O. Box as
its place of business. Traditional Holdings, LLC only seems to have an address
11
in Kentucky c/o Richard Westin, Cohens personal tax and corporate lawyer.
12
Exhibit KKK: Westin emails to Lynch dated September 20, 2004 (LCI Office)
13
14
15
91.
On October 6, 2004, adding to my sense of alarm, Richard Westin
provided me with a copy of a letter he sent to the Kentucky Revenue Cabinet.

The letter enclosed Kentucky Form 765 and two K-1s for Lynch and Cohen,
respectively. Westin advised the State of Kentucky that LC Investments, LLC is
16
owned by for the benefit of a person residing in California and The entitys
17
only contact with Kentucky is the formality of being organized here. There is
18
no income from Kentucky and none passes through Kentucky, nor is there any
19
property or payroll here. My ownership interest in this company is listed as
20
99.55%. The K-1 shows $0 income for the year 2003 from LC Investments, LLC.
1
2
Cohen, as Ive stated above, has steadfastly refused to address this matter. I
personally believe this mistake relates to the hysteria over California
Franchise Tax Board inquiries, demands, and notices. Exhibit LLL: Westin
letters to State of Kentucky; Lynch and Cohen) dated October 6, 2004.

4
92.
On or around December 6, 2000, I provided Richard Westin with a
power of that was limited in its terms of only giving authority to act on her
6
behalf in connection with filing documents to establish Traditional Holdings,
LLC. That was the extent of his authority to represent me. In all other matters
related to Leonard Cohen, Richard Westin worked solely for him and there were
no conflicts of interest. Leonard Cohen has attempted to argue that Richard
10
Westin and I were in some type of joint project. The argument is absurd and
blatantly false.
11
12
93.
After Dale Burgess and DiMascio & Berardo reviewed the
Traditional Holdings, LLC tax returns, I was advised that Cohen failed to report
13
14
the 2001 income from the Sony sale; in 2002 (using a separate tax ID number)
Cohen extinguished my promissory note; and, in 2003, Cohen extinguished the
15
private annuity obligation from the federal tax return. This was done without
16
my knowledge, awareness, or permission. Given the fact that Complaint in this
17
matter confirms that Westin failed to file State of Kentucky tax returns on
behalf of Traditional Holdings, LLC, it is of interest to note that the 2003
18
federal tax return contains what appears to be a State of Kentucky return for
19
20
1
2
3
4
this entity. I have attached hereto relevant pages from those tax returns.
Exhibit: LLL-1: 2001, 2001, and 2003 Traditional Holdings, LLC tax returns.
94.
On November 13, 2004, Dianne DiMascio wrote Robert Kory. At
that time, he evidently took over the full representation of Cohen from
Greenberg, Glusker who had been discharged. My lawyer addressed the fact
that City National Bank has placed a freeze on all of the accounts held by Ms.
6
Lynch, as well as the bank account of Ms. Lynchs son at City National Bank.
DiMascio pointed out that I had made a payment to IRS, based on a previously
arranged installment agreement, and the check bounced although the funds
were in my account which is beyond outrageous. The letter confirms that
10
DiMascio & Berardo understood that Cohen had been in contact with Ms. Marie
DeMirdjian of City National Bank about my bank account, based upon
11
12
comments he made to Lynchs lawyers when he met with them on or around

October 30, 2004. I have no further details about that conversation. I was told,
13
by my lawyers, that Cohen attended the meeting with Richard Westin, as his
14
personal legal representative, as well as Riccardo Cestero of Greenberg,
15
Glusker. At that meeting, Richard Westin was evidently asked Why didnt you
set this up legally and he replied This is how we do things in Kentucky.
16
Therefore, one can safely assume that this entity (and possibly the annuity
17
itself) is illegal. The letter confirms that the freeze was placed on my account
18
at the BEHEST of Mr. Cohen but that does not explain the freeze her sons
19
account. The letter also confirms that Kory agreed to contact Ms. DeMirdjian
20
on Monday and demand that the freeze on all accounts be lifted immediately.
1
2
It is important to note that I was forced to ask her lawyers to address Leonard
Cohens harassment of her parents. Only two weeks earlier Cohen had written
my father to say his work was impeccable. That changed when he could not
coerce me into entering into a settlement agreement, or unraveling these

4
entities, and decided to up the ante by making false allegations about her
parents. Exhibit MMM: DiMascio letter to Robert Kory dated November 13,
2004 (CNB account freeze).
95.
On November 20, 2004, I received an inconceivably evil notice in
the mail from the United States Postal Service advising me that the Postal
Service received a change-of-address order asking them to forward mail from
10
my home address (for my business, Stranger Management). I had not filed this
change-of-address with respect to my mail. I phoned USPS and was advised
11
12
that address the mail was being forwarded to was Leonard Cohens home
address in Los Angeles. I received Confirmation #OR18421598 regarding this
13
mail fraud. The tactics used against me have been utterly abusive and, at
14
times, unlawful. Exhibit NNN: USPS Mail Fraud Notice & Confirmation
15
16
17
No.OR18421598.
96.
My January 5, 2005 email to DiMascio & Berardo, and my
accountant (Dale Burgess), addressed financial and accounting fraud with

respect to Cohens expense ledger and an inordinate amount of highly
18
questionable items being placed in Lynchs column. Leonard Cohen was not
19
interested in participating in an actual accounting that would include corporate
20
1
2
ownership interests, proper financial statements, assets, liabilities, and

equities. What the Court should pay specific attention to is the fact that
millions of dollars were randomly placed in my alleged column when these
amounts were not paid to me and had nothing whatsoever to do with me. I
4
literally spent months researching and refuting this information and take great
offense at Cohens deceitful comments that I refused to provide him with an
accounting. Leonard Cohen refused to provide my representatives with royalty
statements, bank statements, agreements, and other information necessary to
prepare an actual accounting. This particular email alone addresses hundreds

of thousands of dollars that actually went to Leonard Cohens account. These
9
10
amounts were simply assigned to my column. At one point, Anjani Thomas and
Adam Cohens homes (Cohens girlfriend and son) were listed in my column.
11
This email also addressed the fact that income or amounts alleged to belong to
12
the revocable family trust (solely for probate purposes) are actually items that
13
relate to Leonard Cohens personal CNB account. Leonard Cohens personal

bank account was not part of the revocable family trust and this is evidence of
14
further fraud. The perjury and fraud related to this particular matter alone is
15
so extensive that it would literally take every lawyer and accountant at the IRS
16
and DOJ in Washington, DC to address it properly. Exhibit OOO: Kelley Lynch
17
email to DiMascio & Berardo dated January 5, 2005 (accounting fraud re.
18
expense ledger).
19
20
97.
On February 7, 2005, after months of negotiations and discussions
between Cohen and Lynchs lawyers and accountants, Dianne DiMascio sent
1
2
me a privileged letter regarding a meeting she attended with Robert Kory.

While I advised my lawyers NOT to provide Cohens representatives with any
documents until there was a formal discovery phase, this letter confirms that
Kory continued to review documents we provided back in November 2004.

4
Lynch is unaware of the documents that were provided to Kory but the letter
goes onto state that We asked for copies of what they have received from
Leonard and they will provide those documents to us. This was clearly a lie
and no documents were ever provided to us. That would include all documents
necessary to prepare a proper forensic accounting. Kory evidently advised

DiMascio that Cohen wanted to settle but came up with some inane position
9
10
that I merely had a show proof that the monies were not hidden in a foreign
bank account. This was and remains a ruse to obfuscate issues. It is my belief
11
that the letters sent to my lawyers, and myself, are nothing other than a paper
12
trail to be used to defend Leonard Cohen. It also was a fabricated narrative
13
used to unlawfully gain access to my personal bank statements which were not
needed for the expense ledger or an accounting for that matter. I have
14
advised Cohen and his legal representatives not to destroy my bank statements
15
and notified them that I will sue over any spoliation issues. Kory, according to a
16
private conversation I had with accountant Ken Cleveland, repeatedly asked for
17
copies of my tax returns. Perhaps they also planned to blackmail me over them.
18
Obviously, Robert Kory is not the Internal Revenue Service so he must have
19
been looking for something specific with respect to my returns. The Traditional
Holdings, LLC assets were dissipated and Leonard Cohen should explain his
20
1
2
position with respect to the nearly $6.7 million in loans (including expenses
paid on his behalf that he authorized) he personally received. Of course, Kory
has attempted to argue that while Leonard Cohen had a right to receive loans
(or expend monies), I had no authority to authorize them. I was provided with a
4
broad and durable Power of Attorney and when Cohen took a loan, I was legally
authorized to provide them. I also didnt have to forge checks because I had
a broad and durable Power of Attorney. That does not explain why checks were
made payable to my name and then also listed f/b/o Leonard Cohen. I
personally believe this is further evidence of some type of plan on the part of
Cohen and his representatives and have asked IRS to review that matter very
9
10
carefully. Additionally, Leonard Cohen (who is a highly literate individual)

signed the Annuity Agreement and understood that Traditional Holdings, LLC
11
was permitted to provide him with loans or advances. In addition to a simple
12
confirmation that she didnt place funds in off-shore accounts (something my
13
parents were wrongfully accused of as well in order to pressure me and coerce

false testimony from me), they wanted my cooperation in pursuing the Agile
14
Group and Richard Westin. In this regard, they seem to want you to
15
acknowledge that you knew that Neal and Richard wanted to defraud Leonard
16
and that you approved their conduct. The mere notion is absurd. Cohen and
17
Kory, both of whom I spoke to privately about these matters, wanted me to
18
testify that Neal Greenberg and Richard Westin defrauded Leonard Cohen.
19
They would have had a snowballs chance in hell of coercing me into saying I
approved of any type of fraud. I most certainly did not. If I was interested in
20
1
2
fraud, I would have entered into a settlement agreement with Leonard Cohen.
I was also told, by Robert Kory, that they were going after Greg McBowman and
members of the Grubman, Indursky law firm for fraud in the inducement. At
lunch, in or around May 2005, Robert Kory personally advised me that I had a
4
cause of action against every one of Cohens representatives and they would
help me pursue those claims. Kory alleged to have evidence that does not exist.
This is how Leonard Cohen, Robert Kory, Michelle Rice, and possibly others,
operate. They also distort evidence and make up facts. Exhibit PPP: DiMascio
8
9
10
&Berardo letter to Kelley Lynch dated February 7, 2005.

98.
In the aforementioned letter, DiMascio emphasized that I owned
99.5% of Traditional Holdings, LLC. That is correct. The default judgment

does not change that fact. The default judgment does not actually change any
11
12
facts. It is evidence of theft. Leonard Cohen has also alleged fraud and
rescission due to the fact that he had to unwind these transactions and find a
13
narrative for Internal Revenue Service. Michelle Rice, co-counsel in this case,
14
was very transparent when she testified as follows: But, as you know, you can
15
make any kind of allegations in a Complaint. When I reviewed the attorney

notes I was provided from my 2012 trial, I noticed that public defender Nikhil
16
Ramnaney (who I believe attempted to represent me properly but did not have
17
the facts straight and did not have the time to represent me properly) focused
18
on this particularly telling comment as well. I personally disagree with Ms.
19
Rices theory and I know for a fact she is willing to lie as unpleasant as that
20
word may appear. I would also be interested to know who the 50 Does were.
1
2
Clearly, Cohen and his legal representatives believed that there were
approximately 50 people at fault and yet I do not see any evidence of one other
actual defendant apart from Richard Westin. It is also highly problematic that
Neal Greenberg was not a defendant in this case. I recently discovered that
4
Leonard Cohen filed some type of case in the U.S. District Court in Los Angeles,
California that may have involved some type of arbitration with Greenberg. I
have no further details but do find it rather strange that the Colorado lawsuit
really only seemed to substantively argue attorneys fees.
8
9
10
99.
DiMascio ends with comments about TH Tax Returns. Cohens
Complaint confirms that his personal tax lawyer, Richard Westin, failed to file
Kentucky state tax returns. It is my personal opinion that Robert Kory
attempted to con my lawyers when he acknowledged that he did not know if
11
12
any federal TH tax returns were filed and, if they were, he does not know which
one was filed for the 2001 tax year the one dated March 3, 2001, March 5,
13
2001, or March 9, 2001. Why would Cohen and Kory bring former IRS
14
employee Mike Mesnick on board to sort out IRS and tax issues if they were not
15
in possession of the tax returns? The most alarming aspect of DiMascios letter
is the statement that: Neither Kory, nor David, and myself feel comfortable
16
contacting the IRS for copies of filed tax returns as we do not know whether
17
this will alert the Service to possibly inquiry into TH. We all agreed that we
18
want to avoid this result. It seems rather bizarre that IRS would become
19
alerted to Traditional Holdings, LLCs failure to report $8 million in income
20
through a simple request for a copy of the tax returns. In fact, Leonard Cohen
1
2
now seems convinced that IRS is uninterested in this blatant failure to report
income. Hes evidently hedging his bets. The letter ends with DiMascio
advising Kory to look closely at the Indemnity Agreement for TH before
taking a position with respect to indemnification. I asked for, and received, an

4
Indemnity Indemnity Agreement well in advance of the closing of the 2001 TH
deal. Leonard Cohen and I personally discussed my interest in this document
and he authorized Westin to prepare this document. Evidently it is merely
another agreement that Leonard Cohen believes he can willfully disregard,
breach, and/or explain away. The following excerpts from my 2012 trial relate
to Leonard Cohen and Michelle Rices testimony. That would include the
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mistake Westin evidence rectified and Michelle Rices understanding that a

restraining order prohibits her from transmitting tax documents to me but does
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not prevent her from emailing me and advising me that I must use the
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discovery process in this case to obtain IRS required tax information. Exhibit
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QQQ: Trial Transcripts (pages 351-358)

PD: Now I want to talk to you about this issue in 2004. You had a financial
crisis, correct? Cohen: Thats right, Sir. PD: And you you had a company
thats called Traditional Holdings, correct? Cohen: Correct. PD: Now, this
company, you created this company before you sold copyrights to Sony, correct?
Cohen: I dont know. PD: Okay. Do you know why you created this company?
Cohen: No, not really. PD: Okay. SO you had no involvement with the creation
of the company? Cohen: It wasnt it was it was created in some some tax
purposes. I asked two questions when it was created. I asked: Is it legal and
it is safe? PD: And what were the answers to those questions? Cohen: The
questions answers were yes and yes. But, Sir, all these matters PD:
Objection; no question pending. Court: Just wait for a question. PD: Now, you
agree with me that you created this company, Traditional Holdings, for tax
purposes, correct? Cohen: I dont know, Sir. It was created and I asked two
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questions concerning the creation. PD: Okay. Now, you were aware that
99.5% of that company was owned by Ms. Lynch, correct? Cohen: That was a
mistake and it was rectified by the lawyer who drew up the papers. And in
arbitration a substantial sum of money was awarded me for his mistake. PD:
And that lawyers name? Cohen: Richard Westin. PD: And you had arbitration
with him? Cohen: Thats correct. PD: And when did you have that
arbitration? Cohen: I dont remember the exact date. I think it was perhaps
2007. PD: Now, you learned in 2004 that your that the account that
Traditional Holdings account, the money that you were running low, correct?
Cohen: It was running low PD: That funds in that account, that Traditional
Holdings account, they were running low, yes or no? Do you remember that?
Cohen: I - I discovered that they were being dissipated. PD: Okay. Now, you
panicked correct? Cohen: I was concerned, yes. PD: And in fact you had
actually taken money from that account to buy homes, correct? Cohen: Yes, I
had. PD: You took money from that account to buy a house for your son,
correct? Cohen: Thats correct. PD: To buy a house for your girlfriend?
Cohen: Yes. Kelly: Okay. So you -- its fair to say that you did take money
from that account? Cohen: Thats correct, Sir. PD: You were aware enough
about that account to know that you could take money from that account?
Cohen: Thats correct. PD: Now, isnt it true that well, before I go there, do
you blame well, you actually had a financial consultant who invested the
money in that account, correct? Streeter: Objection; relevance. Court: Let
me see counsel at sidebar. RT 285-288
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PD: Now, Ms. Rice, Im going to show you this email. Do you recognize this as
the same email that you sent to Ms. Lynch? Rice: Yes. PD: And the portion of
the email I believe theres some extraneous forwards in that Rice: Uh huh.
PD: -- to Ms. Streeter, and Mr. Streeter sent that to me. But in the portion that
you drafted to Ms. Lynch, do you see a bracketed portion that Ive highlighted?
Rice: I do. PD: Could you read that portion out loud, please? Rice: It says,
Through the Full Faith & Credit Clause of the United States Constitution,
protect orders issued by a sister state, in this case Colorado, are recognized
and fully enforceable in any jurisdiction in the United States. Mr. Cohens
protective order is registered in the State of California and will be fully
recognized and enforced by California law enforcement. I want to take this
opportunity to remind you that the Colorado order never expires and can only
be canceled or modified by the Court from which it was issued. PD: Thank
you, Ms. Rice. Now, again, you sent this email on February 14th; is that correct?
Rice: Correct. PD: Okay. And you didnt actually file the Colorado order in
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California until May 25th, which is approximately three months later; is that
correct? Rice: That is correct. PD: So you told Ms. Lynch that you had filed it
when in fact you hadnt at that point. Rice: Well, at that point we were actually
doing research, legal research regarding how to file it in the State of California.
And I was actively involved in the research portion, and we were going to file
that you know, around the time that we said that we were going to file it in the
date of that email, February 14, 2011, because it was. PD: Thank you. So you
were doing research, you said, but you had not actually filed it yet? Rice: That
is technically correct, yes. PD: And you didnt actually file it until
approximately three months later in Superior Court? Rice: That is correct.
PD: Now I want to take you back to the actual permanent restraining order
hearing in Colorado. You said you were present during that hearing; is that
correct? Rice: I was. PD: And Mr. Cohen was also present during that
hearing? Rice: Mr. Cohen was not at the permanent restraining order hearing.
He appeared and testified for the preliminary hearing which was August 15th.
PD: Okay. Were you there on that hearing? Rice: I was. PD: Now, for that
permanent hearing, were you the only other person present as a witness? Rice:
No. Mr. Kory was there as well. PD: You and Mr. Kory together, and another
attorney, Mr. Steinberg; is that correct? Rice: Harvey Steinberg was the
Colorado counsel. Im not admitted in Colorado, so we had to retain local
counsel. PD: Now, you observed this entire proceeding as it occurred? Rice:
Yes. PD: And Ms. Lynch was also present. Rice: She was. PD: Okay. Now, is
this the first time youve met Ms. Lynch? Rice: No. PD: When was the first
time you met her? Rice: She came to our office a couple of times [one time
perjury]. PD: When did she come to your office? Rice: I believe it was
probably Spring of 2005. PD: And both occurrences were in Spring of 2005
that she came to your office? Rice: One may have been in the summer of 2005.
PD: So both in 2005? Rice: Well, there was a third one, yet another
proceeding that, yes, I had occasion to interact with Ms. Lynch, yes. During
2005 PD: And even though you were there to testify at this permanent
hearing and evidentiary hearing, it didnt actually take place; isnt that correct?
Rice: That is correct. And it was at Ms. Lynchs insistence that the evidentiary
hearing not proceed. RT 351-354 PD: But isnt it also true that Ms. Lynch,
during that proceeding, asked the judge if she could attack this restraining
order at a later date and he told her he couldnt give her legal advice; isnt that
correct? Rice: Correct. It was actually a female judge. It was Carolyn
Enichen. RT 355 PD: Isnt it also true that Ms. Lynch asked the Court, in open
Court, whether or not or whom she could direct inquiries regarding any
ongoing litigation because Mr. Cohen and her were in litigation at that point?
Rice: That is incorrect. There was no ongoing litigation at that point. By the
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point when we had the 2008 permanent restraining order haring, the default
judgment had been rendered by the LA Superior Court in May of 2006.
Perjured Testimony Judge Babcocks Opinion in the Colorado matter was not
rendered until September 5, 2008. This hearing was September 2, 2008. This
is a very serious material lie. There are also very serious federal tax and
corporate matters outstanding. PD: Okay. Was there also a case in in
Federal District of Colorado between Mr. Neal Greenberg against both your
client, Leonard Cohen, and also naming Ms. Lynch as a defendant regarding
the same issues that surrounded the end of their business relationship? Rice; I
believe that the Federal District Court action was also concluded by the time
the permanent restraining order, but I again, Id have to look there. But we
filed a motion for summary judgment on behalf of Mr. Cohen in May of 2008.
The September 2008 hearing was sixth months later. PD: So there was
litigation in 2008 where Ms. Lynch was a party, Mr. Cohen was also a party and
it was in the State of Colorado; it that correct? Rice: In 2008, correct. But by
the time the permanent restraining order hearing concluded, that action had
concluded with regard to Mr. Cohen. RT 355-357 PD: And you were an
attorney of record in the federal case? Rice: I was. RT 357 PD: So you were
familiar with the pleadings of that case and the procedural posture of that
case? Rice: It is to the best of my recollection that Ms. Lynch never made an
appearance in that lawsuit. She never answered any complaint that Mr.
Greenberg filed. She you know, this was a multiyear litigation matter that I
only became attorney of record for Mr. Cohen in the later stages of that. Prior
to that, he had Colorado counsel, Jay Horowitz. PD: But indeed the nature of
the allegation in that lawsuit involved very heavily the relationship between Ms.
Lynch and Mr. Cohen; is that correct? Rice: No. I would characterize the
litigation in that way. RT 357 PD: How would you characterize it? Rice: I I
mean, basically, the investment firm sued Mr. Cohen first, and I believe Ms.
Lynch was only made a party later in the proceeding. So I would characterize
it as basically primarily between the investment adviser and Mr. Cohen in the
beginning stages. He also sued Mr. Kory. PD: But isnt it also true that in that
allegation of that lawsuit that Ms. Lynch, Mr. Cohn and Mr. Kory were engaged
in civil extortion and fraud against the Plaintiff in that case, Mr. Greenberg?
Rice: That is what they can state in the Complaint. But, as you know, you can
make any kind of allegations in a Complaint PD: And they named Ms. Lynch
as one of the conspirators in that civil conspiracy; is that also correct? Rice: I
dont believe Ms. Lynch was named as a co-conspirator. RT 358
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100. On February 11, 2005, Robert Kory wrote Dianne DiMascio. He

allegedly made substantial progress on the tax analysis. This letter takes the
position that Kory does not believe Leonard has any material exposure, though
depending on how we handle Traditional Holdings, he may have some tax

4
liability if and when loans to him from Traditional Holdings are forgiven.
Leonard Cohen personally hired Richard Westin who prepared the federal tax
returns. Those tax returns, for the years 2001, 2002, and 2003, failed to report
the income from the 2001 Sony sale; extinguished my promissory note in 2002;
and extinguished the annuity obligation in 2003. This was brought to my

attention by my lawyers and accountants in the fall of 2005. Clearly, I
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personally have no exposure with respect to the tax returns because I has no
expertise in tax matters and was quite clear with Cohen, Westin, and others,
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that I did not handle tax, financial, accounting, legal, corporate, or IRS matters.
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All income must be reported to the Internal Revenue Service on an annual tax
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return. In fact, Internal Revenue views unreported income as potential tax

fraud activity. Exhibit RRR: Kory letter to DiMascio dated February 11, 2005
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(Traditional Holdings, LLC problematic loans to Leonard Cohen).

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101. On May 2, 2005, Steve Lindsey, Lynchs younger sons father, sent
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an email advising me that Robert Kory is not my lawyer. Kory had evidently
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phoned Lindsey, who he did not know, in a last ditch attempt to have you settle
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this. I thought it was probably the best thing to do. But its your life, sorry I
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tried to help. He told me today and before you were going to jail, so reluctantly
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I talked to him and Leonard about having my father help out. Sorry, I thought
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you were in over your head since he told me you dont have that attorney you
said you did. Leonard Cohen and Robert Kory certainly became emboldened
after I was briefly represented by Bert Deixler. Bert Deixler personally advised
me, after reviewing the evidence she left with him, that he could walk me into
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the Attorney Generals Office and have the poet arrested. This email is
evidence that Leonard Cohen and Robert Kory evidently thought threatening
me through my younger sons father was an appropriate negotiating tactic.
Approximately three weeks after this attempt to threaten me into a settlement
agreement, a custody matter would be coordinated. Exhibit SSS: Steve

Lindsey email to Kelley Lynch dated May 2, 2005.
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102. On May 25, 2005, a SWAT incident occurred at my home that was
featured in Ann Diamonds draft article for Rolling Stone. This incident arose
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because I, as was my right, elected to keep my younger son home from school
due to the fact that he was not feeling well. Steve Lindsey was relatively
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hysterical at this moment in time. He was in a new relationship with Dinah
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Englund; they had a new baby; and he had extreme financial concerns. The
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Natural Wealth lawsuit confirms that Leonard Cohen, Robert Kory, Steve
Lindsey, and Betsy Superfon conspired to have me falsely arrested on this date.
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That would seem self-evident given the fact that the SWAT and Killer King
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matters have been used against me in connection with the coordinated custody
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matter and raised in connection with fraudulent restraining orders and during
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my 2012 trial. The bottom line is this: I kept my son home from school. At
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some point that morning, I asked my older son to pick my younger son up and
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drop him off at the bottom of the hill with his father who I did not want on my
property in the extremely aggressive mental state he exhibited on the phone.
Lindsey demanded that he be permitted to pick my younger son up and take
him to school. My older son did indeed pick my younger son up but the party
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waiting at the bottom of the hill for my younger son was actress Cloris
Leachman, the mother of Dinah Englund. Rutger dropped Ray off with
Leachman and saw Steven Lindsey and approximately 7 or so squad cars racing
up the hill to my former home on Mandeville Canyon. Rutger had just been
with me; spoke with Lindsey moments before and was told he was in Beverly
Hills; and understood that I was alone in my house and his brother was no
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longer there. Rutger and his friend, Evan Reiss, returned to our home and
what unfolded thereafter is inconceivably outrageous. Approximately 20-25
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armed men were in front of my home; at times they had my son in front of their
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weapons; and they willfully disregarded his statements that I was home alone;
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he had taken his brother down the street; and chose to rely on Steve Lindseys
statements while willfully disregarding Rutgers. Evan Reiss was also with
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Rutger when he picked Ray up. At that time, Rutger took the phone from Rays
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hand, handed it to me, put Ray in the car, and I confirmed this for Lindsey who
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was on the other end of the phone and hung up. Therefore, Lindsey was well
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aware that Ray was not on my property and our son was being driven down the
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street to meet him. I have not seen the police reports related to this incident;
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advised DOJ, IRS, and FBI that I believe they should obtain these documents;
but understand, from conversations Ive had with West LAPD, that the police
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heard that shots were fired. No shots were fired; I did not have access to my
sons rifle in his separate locked guest house; and the rifle was legally
registered and not a reason for SWAT to descend on my home. As the Court
should understood, the people of the United States have second amendment
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rights. I personally felt that my son, who was over the age of 18, should learn
safe fire arm handling procedures and saw nothing wrong with his going to a
gun club to learn to handle a rifle. I also was very demanding about the fact
that, given the fact that we had a minor in our home, the rifle had to be locked
in Rutgers guest house; locked in his closet; and locked in a case so that there
were numerous obstacles preventing my younger son from gaining access.
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Furthermore, the bullets were not kept in the same vicinity as the gun. In any
event, this situation evidently disturbed Steve Lindsey although he had no
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problem whatsoever insisting that we purchase a handgun after the riots in Los
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Angeles. I had problems with that and ultimately decided, after Lindsey and I
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separated in 1997, that I did not want a hand gun in my home and gave it to
him. He was well aware of that fact. I thought my dogs, some of which were
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highly trained guard dogs, were much better protection. Evidently, LAPD felt
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the same because Rutger assured these officers that I was in the house alone;
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his brother was no longer present; and I had no access to his rifle. That did not
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deter these individuals. Rutger was advised that Inglewood PD was present.
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At various times, he was advised that these officers would shoot me, shoot my
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dog, he could stay and watch, or they would take him somewhere. From my
perspective, Rutger was used as a hostage negotiator, human shield, and
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placed in a very dangerous situation. At no time was I asked to come out of my

house. At no time did anyone come to my door. At one point, I was absurdly
asked what my hostage demands were although the officers were told that I
was in the home alone. At another point, Rutger asked if I would like a
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cigarette and, from what I could tell, was in front of many armed men. I,
therefore, came out of my house, with my dog on my leash, and asked Who is
my hostage? My dog? I think its important to note that I was also in my
bikini and these officers could clearly see that I did not have a weapon and
posed no threat to them. In any event, the situation ended with LAPD rushing
my backyard; illegally detaining me in handcuffs; and transporting me nearly 3
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hours (in traffic) to King Drew based upon their obscene position that I might
be dangerous to myself or others while surrounded by armed men who willfully
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disregarded the facts of the situation. Ultimately, Rutger was advised by some
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of these officers that my dog was my hostage and they were taking precautions.
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After I was removed from my home, Steve Lindsey (who had left earlier)
phoned Rutger to ask him to go into Leonard Cohen/Robert Korys office to sign
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over or transfer my house to them. Lindsey advised Rutger that he would be

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compensated and Lindsey would be provided with money to care for us. Rutger
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immediately phoned his father, was advised to consult with a lawyer, and
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decided not to respond to any further calls Lindsey made. Exhibit TTT: Ann
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Diamond (draft article for Rolling Stone).
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103. While this scenario was unfolding, I was taken to King Drew,
questioned about Phil Spector en route, asked about any gun incidents that
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involved Mr. Spector, and advised that this would be good for me when I
questioned why I was being taken so far from my home in Brentwood and
whether or not King Drew would place me in a dangerous environment. I
attach hereto the first page of the King Drew report related to that incident.
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The Court should note that my name, as usual, is misspelled; my religion is
listed as Christian while I am a Buddhist; the birth place is listed as California
when I was born in Pennsylvania; the original date of birth is listed as August 5,
1985 (and crossed off after I advised King Drew on the phone later that my date
of birth was 1/27/57); the original social security number listed is not mine (and
was crossed off after I advised King Drew on the phone later that this was not
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my social security number); and the Medical identification number is not mine.
This file does not represent me. The entire file is fraudulent. I was advised by
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the Social Security Administration that the original social security number used
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relates to someone whose name is similar to Kelly Lynch but is not Kelly
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Lynch. I was also advised by SSA to file a criminal complaint about this matter
which I have done. Obviously, I have asked IRS, FBI, and DOJ to thoroughly
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investigate this situation. I have repeatedly attempted to gather facts about

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this incident but have been stonewalled every step of the way. The incident
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was addressed, together with matters related to Leonard Cohen, tax fraud,
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harassment, etc. in a September 2009 letter I sent to Phil Spectors prosecutor
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Alan Jackson. This letter was hand delivered to former DA Steve Cooley, DDA
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Alan Jackson and DDA Truc Do, two of the prosecutors in the Spector case.
This is a very serious incident; led to the loss of custody of my younger son (via
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default judgment); has been used by Leonard Cohen to obtain a 2005

fraudulent restraining order; and continues to be used to discredit me. I
personally think it should horrify people rather than serve to discredit me. One
tactic that has been used against me repeatedly is character assassination. I

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can assure this Court that calling me a drunken slut, and other names, will not
deter me from seeking appropriate legal remedies and addressing the truth of
this obscene scenario. Exhibit UUU: King Drew May 225, 2005 fraudulent
report.
Lindsey Declaration Custody Matter May 25, 2005 (coordinated with

SWAT Korys Declaration)
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Page 2: Until approximately October, 2004, Respondent worked as a manager

for singer/songwriter/poet Leonard Cohen. However, she was terminated due
to suspicion that she stole over $8 million from Mr. Cohen. It is my
understanding that over approximately the past seven months, Mr. Cohen and
his attorney, Robert Kory, have been attempting to negotiate with Respondent
to avoid filing a lawsuit.
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Mr. Korys attempts at negotiation have been without success, and he in on the
verge of filing a complaint against Respondent. A criminal action may also be
brought against Respondent, and she has told me that she may face time in jail.
LIE. ATTACH HIS EMAIL WHERE HE SAYS KORY TOLD HIM THAT.
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Page 3: LAPD Lindsey called. 20 officers around the house. LAPD asked
Lindsey to go to the house. One officer asked if she kept any guns. Rutger
said he owned one but it was in the guesthouse.
Page 4: Confirms that he approached me and told me to contact Cohen to
negotiate a deal.
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Page 5: Lindsey received a phone call from Kory informing him that KL and
Ray had come to his office unannounced, and Respondent was exhibiting
strange behavior such as interrogating Ray.
Exhibit VVV: Trial Transcript (pages 293-297)

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Cohen Testimony at trial 2012:
PD: Now, I also want to talk to you in 2005 there was a custody issue with
Ms. Lynch and her son, Ray, Ray Lynch. Do you remember that? Cohen: I
know there was a custody issue. PD: Okay. Now, you now that the police came
to her house, correct? Cohen: Yes, Sir. PD: And her son was given to her
father, correct? Cohen: Do you mean at that moment? PD: Around that time,
yes, in 2005. Cohen: Do you mean when the police came to her house, her son
was given to father or subsequently? PD: Subsequently. Cohen: I Im not
completely aware of the details of that custody battle. PD: Okay. But you were
aware that the police was at Ms. Lynchs house, correct? Cohen: Thats
correct. PD: Do you know how the police got there? Cohen: I believe it was
Ms. Lynch called them. PD: You believe Ms. Lynch called them? Cohen: Yes.
In one of her domestic partners emails, he says that You yourself called the
police. PD: And when was this Cohen: Otherwise thats thats the only
information I have about the police. PD: When was that email that youre
referring to? Cohen: I dont remember. PD: Can you give an estimate?
Cohen: 2005. PD: Okay. You actually wrote a declaration in 2005, correct?
Cohen: No, Sir. PD: You never wrote a declaration in 2005? Cohen: No. PD:
May I approach? Court: Yes. PD: May I approach the witness? Court: Yes.
PD: Let the record actually, I believe shes marked this already.
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Defense Exhibit A Leonard Cohen 2005 Declaration [in support of 1st

restraining order?]
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Court: Whats the title of the document, Mr. Kelly? PD: Defense A will be the
it will be a declaration of Leonard Cohen. Do you recognize that document I
just gave you? Cohen: All those things are correct. PD: Okay. And you
actually wrote that declaration in 2005, correct? Cohen: Yes, Sir. PD: Okay.
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No in that declaration you say that on May 25, 2005, LAPD responded to a 911
emergency call at Ms. Lynchs resident. Cohen: Thats correct. PD: How did
you know that information? Cohen: Ms. Lynch wrote hundreds of emails about
that incident. PD: And in in 2005 she wrote hundreds of emails? Cohen:
Over the years shes written hundreds, if not thousands, of emails about that
particular incident. PD: But, you wrote this in October of 2005, correct?
Cohen: Yes, Sir. PD: So she wrote hundreds of emails between? Cohen: I
dont know how many emails she wrote in that period. PD: Okay. Isnt it true
that your attorney wrote a declaration in her custody issue? Cohen: Thats
true, yes. PD: Okay. So your attorney got involved in Ms. Lynchs custody with
her son, correct? Cohen: Yes, after an incident in my attorneys office. PD:
Okay. So thats correct? Cohen: Yes, Sir. PD: And you also said in your
declaration that Ms. Lynch had a psychiatric evaluation? Cohen: Thats true.
PD: How did you know that information? Cohen: Ms. Lynch wrote about that
in her emails. RT 293-297
141. On June 5, 2005, Natural Wealth Real Estate, Inc. (Neal Greenberg
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and other Greenberg companies) sued Leonard Cohen and Robert Kory.
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Leonard Cohen had to confront and defeat Neal Greenbergs allegations that he
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and his lawyer, Robert Kory, engaged in improper and criminal conduct
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including bribery, intimidation of a witness (Lynch), witness tampering,

extortion, coercion, mail fraud, wire fraud, legal conspiracy, racketeering,
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subornation of perjury, defamation, and disparagement. See Motion Exhibit 2

(Greenberg Amended Complaint; Factual Statements.)
104. On August 3, 2005, while representing myself and before this
retaliatory lawsuit was filed, I wrote Leonard Cohen (baldymonk) and Robert
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Kory (rkory@rbklaw.com) confirming that I had notified Agent Betzer of IRS
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that I was going to the IRS Criminal Investigation Unit. The email also advises
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Cohen and Kory that both IRS and the Kentucky Revenue Cabinet told me they
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view Traditional Holdings, LLC as a partnership. I ask Cohen and Kory if the
actual problem is the fact that Cohens lawyer failed to report the gross income
on the 2001 TH tax returns; extinguished my promissory note in 2002; and
extinguished the annuity obligation in 2003. This letter also confirms that the
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reason Cohen and I parted ways was due to the fact that I refused to meet with
Cohen and Westin and unravel this entity (and other matters) without my own
representation. The letter notes that once my lawyers wrote Cohen and Westin,
on October 27, 2004, the blackmail began. I close this letter by asking Cohen
why he and his representatives intentionally dragged me into tax fraud. I have
not received an answer yet but I assume this lawsuit is part of their response.
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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).
105. On August 15, 2005, Leonard Cohen and LC Investments, LLC filed
the Complaint in the instant matter.
106. On August 24, 2005, the proof of service related to the Summons
and Complaint was filed with this Court and it is evidence of fraud.
107. On October 11, 2005, Leonard Cohen filed the Complaint in Related
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Case No. BC341120. Jeffrey Korn has provided me with numerous documents
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filed in that matter but refuses to provide me with the proof of service related
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to the Complaint and/or Steve Lindseys declaration. Steve Lindsey had not
seen me in over 5 months and we had not lived together since 1997. Therefore,
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any declaration Lindsey provided with respect to what I stored for Leonard
Cohen as a courtesy, including in my garage, is entirely irrelevant and no doubt
misleading. I did hear Michelle Rice, standing in my garage, discuss Steve
Lindsey on her cell phone with someone when she accompanied the Los
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Angeles Sheriffs Department to my home to retrieve Leonard Cohens
abandoned property that he failed to make arrangements to pick up after
being advised, by my lawyers, to do so. I do not have time to address the
fraudulent misrepresentations or potential perjury in the related case. In the
spring of 2010, Judge Freemans court reporter brought the separate related
case to my attention.
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108. On November 14, 2005, Tactical Allocation Services, LLC (a Neal

Greenberg company) filed an Ex Parte Application in Intervention for Order
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Protecting & Preserving Documentary Evidence, Etc. On November 14, 2004

Judge Kenneth Freeman denied the Application. This Application contains very
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serious evidence and facts. Since I was unaware of the case, it would have
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been impossible to comply with CCP 514.030(1)(a). However, I do not
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understand how a court can legally order me to deposit $100,000 to

provisionally recover possession of my own property. That would include, but
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is not limited to, my business files, corporate and partnership documents, and
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federal and state tax returns. I was advised by LASD that they were permitted
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to take anything with Leonard Cohens name on it. I found that statement
19
highly questionable. My personal business files were not Leonard Cohens
20
property and LASD to seize them. The proper manner in which that should
1
2
have been handled is by Cohens lawyer contacting me and asking if they could
make copies of my files, pay for the copying, and pick up/delivering the files
back to me. I had no obligation to preserve Leonard Cohens abandoned
property and a photocopy of a manuscript in a business file is worth the ink and
4
paper it is written on. I have received legal advice about that matter in
connection with Leonard Cohens desire to donate his body of work to the
University of Montreal in exchange for a U.S. tax credit. His lawyer informed
me that he was not an alchemist and every lawyer I spoke with (at Cohens
request) told me these items were worth precisely what the ink and paper were
worth. In the instant case, less than $300. I had a legal right to destroy those
9
10
items and, in the alternative, send them to the IRS Commissioners Staff in
Washington, DC. Cohen was not interested in the three plastic PROCAN
11
statues and gave them to me. I wasnt interested in them either. Thats why
12
they were stored in a box in my garage that rats had been in for a number of
13
14
15
years.
109. Tactical Allocations Services, LLC advised LA Superior Court that
the seized documents should be preserved and maintained because such an
order is necessary to prevent the potential loss or destruction of relevant
16
evidence pending discovery in the Colorado matter between Cohen and Agile.
17
It was also necessary to preserve for any potential IRS prosecution and my
18
personal litigation matters. As Tactical Allocations advised LA Superior Court,
19
there would be no harm in preserving that evidence and, in fact, an order of
20
the kind requested is likely to protect the rights and interests of all parties
1
2
here. Tactical Allocations Ex Parte order confirms that Leonard Cohen

conspired with others to defraud and extort money from Agile through (among
other things) a threat of defamation which would irreparably damage Agiles
reputation. Central to Cohens extortionate scheme was the continued

4
concealment of critical documents in the possession of defendant here, Kelley
Lynch documents proving that Cohen and others effected their conspiracy and
that the conspirators should have been and were aware that their threats of
legal action against Agile and others were entirely pretextual. The document
goes onto state that Cohen recently commenced the present action without
breathing a word of it to Agile or its attorneys a calculated attempt at
9
10
concealment that served his purposes. The lawsuits aim, as reflected on the
face of the complaint, was to recover possession of certain business, financial
11
and other documents and items from Lynch, his former personal manager,
12
whom he accuses of misappropriating several million dollars. (Lynch is also a
13
defendant in the Colorado action, although she is not accused of being a coconspirator with Cohen.) When Lynch refused to cooperate in Cohens
14
extortionate scheme against Agile [and others] by declining to cover up and

15
lie for him, Cohens gambit became to seize documents in Lynchs possession
16
(some of which she had previously revealed to Agile [Boies Schiller actually].
17
According to the Ex Parte Application, Cohen filed this second lawsuit here
18
against Lynch without the required Notice of Related Case (Counsel is required
19
to file and serve a Notice of Related Case promptly upon learning that the
action is related to another pending action CRC 804(a)) which Cohen and his
20
1
2
counsel knew from the start). Leonard Cohen and his legal team engage in
these types of deceptive practices, including as they relate to service issues,
because it furthers their goal of winning at all costs. As Cohen is aware, Lynch
has made no appearance in either of the other cases and, as he no doubt

4
anticipated, she made no appearance here is a very astute remark. I was not
served the Summons & Complaint in the instant matter and, with respect to the
Colorado case, had no interest in the interpleader funds and advised Judge
Babcock that I personally believed the lawsuit was meant to obfuscate issues,
cover up potential criminal tax fraud, and obstruct justice. I also did not
provide the U.S. District Court for the District of Colorado with my email
9
10
address or Phil Spectors California address and find it odd that someone else
filed information on my behalf. I believe that may have been Michelle Rice, an
11
individual I do not know who has spent approximately 10 years targeting me,
12
lying about me and many issues involved in this case, and received a promotion
13
due to her work with respect to me. The Ex Parte Application confirms that I
own 99.5% of Traditional Holdings, LLC and Cohen owned .5% and, beginning
14
on page 5, addresses some of the underlying facts. However, Cohens

15
communications with Neal Greenberg were not screened by me and his
16
Affidavit in that matter proves otherwise. Leonard Cohen is an adult who was
17
free to communicate with any of his representatives and did. This document
18
fails to address Leonard Cohens loans from Traditional Holdings, LLC that
19
total approximately $6.7 million but does confirm that The boxes of documents
secretly obtained by Cohen include documents pertaining to Traditional
20
1
2
Holdings, LLC and Blue Mist. I have a legal ownership interest in both of
those entities and the government had no right to seize my property. It is my
personal belief that I have now irretrievably lost evidence otherwise available if
this order had been granted or the property was not seized. Tactical
4
Allocations even offered to copy the documents at their own expense. I have no
information related to David Givens statement that My office first learned of
this lawsuit by chance, while discussing issues pertaining to the First L.A.
Action with the Sheriffs Department. Nor do I understand what LASD had to
do with this case. Jeffrey Korn failed to provide copies of all exhibits attached
to this document including LASDs inventory. Nevertheless, I have obtained
9
10
11
12
a copy of that document. See Related Case File (Ex Parte Application in
Intervention for Order Protecting & Preserving Documentary Evidence; Natural
Wealth August 2, 2005 Complaint attached thereto as Exhibit A.)
110. I have attached hereto my February 17, 2007 complaint to the
13
California State Bar regarding former District Attorney Steve Cooley. This is
14
highly relevant as Leonard Cohen, the former District Attorney, and the City
15
Attorney joined forces against me when I was falsely arrested and imprisoned
in 2012. I had previously filed a complaint with Lieutenant William Brown,
16
Special Operations, District Attorneys office. This complaint addresses the fact
17
that I filed a complaint regarding Cohen, his theft from me, and tax fraud, with
18
Cooleys Major Fraud Unit in 2006. This unit was evidently headed by
19
Spectors prosecutor, Alan Jackson. At that point, Cooleys office (who had
20
approached me regarding Phil Spector and advised me that I was probably a

1
2
witness as early as the winter of 2005), became utterly hostile to me; began
threatening me; hung up on me; and began bullying me. I memorialized some
of that conduct in this complaint and kept the IRS, FBI, DOJ, Treasury, Phil
Spectors legal team, and others, apprised of the situation as it unfolded. The
4
title of the suits I addressed therein were Leonard Cohen Tax Fraud; State of
California v. Phil Spector. Attached to my complaint is this statement about
the DA: If it comes to Phil Spector, I suppose he didnt like my messages
reminding him that Cohen told the detectives [LASD] one thing about Phil
Spector (a good rock n roll story) and then seems to have perjured himself
before a secret grand jury. Thats just a guess could have been something
9
10
else I said. I also attach hereto a copy of my February 17, 2007 complaint to
the State Bar regarding Steve Lindseys custody lawyers, Daniel Bergman and
11
Dana Wolinsky. The custody matter was most definitely coordinated with a
12
number of things including this case. The complaint notes that I am the
13
mother of two children who have basically been destroyed by Petitioner, his
lawyers, and others. It also addresses the vicious tactics many California
14
State Bar members have used against me. This is evidently commonplace when
15
one is representing oneself. I did hear from the California State Bar regarding
16
Steve Cooley. They essentially advised me that the District Attorney does not
17
have jurisdiction over federal tax matters. The theft from me of millions of
18
dollars in intellectual property and commissions due is not a federal tax matter
19
but it is interesting to note that nearly every single matter I am involved with
before LA Superior Court seems to be nothing other than a federal tax matter.
20
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2
3
4
Exhibit XXX: Kelley Lynch State Bar Complaints re. Cooley & Lindseys custody
lawyers dated February 17, 2007.
111. On February 28, 2007, I received the attached letter from the State
Bar of California with respect to my complaint regarding former DA, Steve
Cooley. The State Bar reviewed the Complaint and, after careful review,
determined that the matter did not warrant further investigation or

6
prosecution. Some examples they provided me with are as follows: For
example we do impose discipline for prosecuting a criminal case where there is
evidence to support charges and We cannot impose discipline for alleged
failure to prosecute a criminal case where there is evidence to support
10
charges. The first matter relates to Phil Spectors trial and the second to the
DAs failure to prosecute Leonard Cohen. Evidently, according to the State Bar,
11
12
the decisions of District Attorneys are not subject to review by the State Bar of
courts, absent some other crime such as bribery. I do not know if a quid pro
13
quo would technically satisfy a bribery claim. Exhibit YYY: State Bar Letter re.
14
Cooley dated February 28, 2007.
15
16
17
112. In or around February 2007, I received a phone call from Agent

Kelly Sopko of the U.S. Treasury. She advised me that she would be flying into
Los Angeles and made arrangements to meet with me. Sometime shortly
thereafter, I met with Agent Sopko and her partner. We discussed a variety of
18
matters include my emails documenting matters for IRS. Agent Sopko

19
confirmed that the IRS Commissioners Staff was reading my emails and
20
1
2
various parties were handling various aspects of them. Other matters were
discussed. On March 6, 2007, following that meeting, I received an email from
Agent Sopko [that has been entered into evidence in this and other matters by
Leonard Cohen] referring me to Agent Luis Tejeda, head of a fraud group at

4
IRS. What I discussed with Agent Sopko and her partner related to the
allegations of criminal tax fraud I originally reported to IRS Agent Bill Betzer
on April 15, 2005; IRS directly via its website; and IRS in Washington, DC due
to the high profile nature of this matter and the unconscionable tactics
(including the Swat incident and custody matter) being used against me. And
now this lawsuit. Agent Sopko advised me that Agent Tejeda needed a
9
10
summary of all important details, with as much specificity as I have. I have

documented everything in emails to IRS since reporting these allegations to
11
them on April 15, 2005. Agent Sopko specifically noted that examples of
12
evidence supporting these allegations would be copies of any paperwork
13
involved, social security numbers of people involved, etc. As Leonard Cohen

had at least two social security numbers, I am not clear on which was is
14
legitimate or why he had a second.

15
113. In Korys letter dated March 9, 2007 to Agent Tejeda/IRS (attached

16
to his declaration), he uses the default judgment to defend Leonard Cohen with
17
Agent Tejeda, head of fraud IRS LA. This letter confirms that In response to
18
Mr. Cohens civil claims, Ms. Lynch has been sending mass emails to a wide
19
range of individuals including Mr. Cohens friends, business associates and the
20
press. In many of those communications, she has alleged that she is reporting
1
2
Mr. Cohen to the Internal Revenue Service for tax fraud. While a nuisance,
these communications have had little effect in part because the emails involved
incoherent ranting and because there was no evidence that the Internal
Revenue Service was taking her allegations serious. Now the situation has
4
changed. Ms. Lynch has managed to obtain a return email from Special Agent
Kelly Sopko, the contents of which I read to you. In our call ,you asked me how
I had access to that email. I answered that it had been forward [sic] to Mr.
Cohen and me from Ms. Lynch by email. Attached are copies of several emails
from Ms. Lynch in which she forwards the email from Agent Sopko to a very
broad email list, including another such email sent today. You will note from
9
10
the enclosed emails that her circulation of the communications from Agent
Sopko is increasing. One of the more notable fraudulent allegations contained
11
in Korys letter to Agent Tejeda is as follows: Please note that Ms. Lynch is
12
using communications from the Internal Revenue Service to defame Mr. Cohen
13
and to use the threat of an IRS investigation to attempt to extort resolution of

civil claims. First of all, I didnt sign a secrecy agreement about this matter
14
with IRS or Treasury. I do feel it was nave of me to make this information

15
public and now believe that tax fraud should be reported confidentially to IRS.
16
I did not think through the consequences of my actions which have been
17
extreme. Second, I have not attempted to extort a civil settlement or claim
18
from Leonard Cohen. Steve Lindsey is very clear in his May 25, 2005
19
declaration, attached hereto, that Cohen/Kory spent 7 months attempting to

coerce me into a deal/settlement. I refused because I felt that offering false
20
1
2
testimony about Cohens representatives, and possibly engaging in insurance

fraud, was illegal. The settlement offers involved specific requirements that I
assist Cohen in mediations against Neal Greenberg, Richard Westin, and
possibly others. Third, I have a right to communicate with the Internal

4
Revenue Service, former business associates, and the news media. Kory was
very clear at this time that Sopkos email was a game changer. The head of
fraud for the Western Division of the United States, Agent Luis Tejeda, was now
involved. In any event, Korys emails from May 2005 confirm that he has
extremely generous negotiating authorities and further confirms that he

understood I had reported the allegations that Cohen committed criminal tax
fraud to IRS, State of Kentucky, and the DAs Criminal Division.
10
114. On September 5, 2008, Judge Lewis Babcock, in the Natural Wealth

11
12
matter, relied on the default judgment in this matter when wrongfully

converting assets belonging to Traditional Holdings, LLC to Leonard Cohen
13
personally. I was added as a defendant in this matter solely with respect to the
14
interpleader funds before the Court. I advised Judge Babcock that I refused to
15
participate in this matter due to the fact that I had serious concerns related to
the use of that lawsuit to obstruct justice and cover up criminal tax fraud.
16
Judge Babcock wrote that The final judgment of the California court settles the
17
dispute between Lynch and Cohen over ownership of the interpleaded funds.
18
The amount of approximately $154,000 was evidently released directly to
19
Leonard Cohen. The reason for this outcome is due to the following language
20
inserted into the judgment that declared I was not the owner of any assets in
1
2
Traditional Holdings, LLC and any interest I had in any other entity related to
Cohen she [held] as trustee for Cohens equitable title. These are blatant
falsehoods. In addition to this particular example of fraud that has crossed
state borders, Michelle Rice testified during my trial that at the time of the
4
Boulder, Colorado hearing (September 2, 2008) there was no litigation matter
involving me and Leonard Cohen. That was obviously perjured testimony.
There continue to be ongoing tax, corporate, and litigation matters that now
include the fact that I intend to file a federal lawsuit against Cohen over this
situation. Judge Babcocks order was raised in my 2012. Exhibit ZZZ: Judge
Lewis Babocks Order dated September 5, 2005; Trial Transcript (pages 356)
9
10
11
12
13
PD: Isnt it also true that Ms. Lynch asked the Court, in open Court, whether or
not or whom she could direct inquiries regarding any ongoing litigation
because Mr. Cohen and her were in litigation at that point? Rice: That is
incorrect. There was no ongoing litigation at that point. By the point when we
had the 2008 permanent restraining order hearing, the default judgment had
been rendered by the LA Superior Court in May of 2006. RT 356
14
15
16
Perjured Testimony Judge Babcocks Opinion in the Colorado matter was not
rendered until September 5, 2008. This hearing was September 2, 2008. This
is a very serious material lie. There are also very serious federal tax and
corporate matters outstanding.
17
115. Robert Kory attached his December 20, 2008 letter to IRS to his
18
declaration in an attempt to defend his client, Leonard Cohen. I was appointed
19
Tax Matters partner, on federal tax returns, by Leonard Cohens personal tax
20
lawyer, Richard Westin. It is my personal opinion that Leonard Cohen wasted

1
2
the entire $8 million income that was produced in connection with the 2001
Sony deal. I, therefore, hand wrote a 1099 from Traditional Holdings, LLC and
sent it to the IRS Commissioners Staff in Washington, DC. I asked the IRS
Commissioners Staff to advise me if I had used the wrong form for this item. I
4
never handled tax matters, as Cohen understood, and was not clear about that
issue. The 1099 notes that I believe Traditional Holdings, LLC is a shell
company with an extinguished annuity, and addresses the fact that Cohen
personally received the $1 million non-refundable prepayment or down
payment in 1999; and the balance, less recoupment deductions (Cohens

personal account with Sony) and delivery requirement items. I also advised
9
10
IRS Note: Will deal with Kentucky and California tax issues once the IRS
issues required opinion letter and Kelley Lynch addresses the LA Superior
11
Court fraud, the fact that she was defrauded, and obtains a proper and
12
complete forensic accounting for this entity, Blue Mist, and, LC Investments,
13
LLC, etc. I have repeatedly requested a proper accounting that addresses

corporate ownership interests, assets, liability, equity, and financial statements.
14
I have also asked the IRS for formal Opinions, or private letter rulings, with
15
respect to these entities and a wide variety of issues. A copy of this 1099 was
16
sent to Leonard Cohen. Robert Kory then wrote IRS and lied about many
17
matters. That would include his allegation that this document is fraudulent
18
and I was Cohens business manager. The letter states that Kory addressed
19
this matter with Mr. Tejeda in your fraud department. It refers to the
fraudulent default judgment which is being used to argue federal tax matters
20
1
2
with IRS and, specifically, the allegations that Leonard Cohen committed
criminal tax fraud. And finally, Her sending the fraudulent 1099 is a violation
of the Colorado restraining order and an indication as Ms. Lynchs continuing
and illegal harassment of Mr. Cohen. Kory, of course, provided no evidence

4
that the IRS has elected to disregard this form 1099 or in support of his
statements about Agent Tejeda. Time and time again, Leonard Cohen and his
representatives rely on innuendo, false allegations, gossip, rumor, and hearsay
to advance their case. As I advised this Court in the January 17, 2014 hearing
on the Motion to Vacate, Robert Kory does not represent IRS, does not speak
for IRS, and this Court has no jurisdiction to hear federal tax matters. Agent
9
10
Luis Tejeda, who is routinely quoted by Robert Kory, is the only individual who
can confirm his position with respect to this matter. As Kory knows, I issued a
11
subpoena to Agent Tejeda during my 2012 trial but Judge Robert Vanderet did
12
not believe, from what I could tell, that I had a right to defense witnesses or
13
impeach evidence. That would include Cohens refunds from IRS that I only
discovered on April 9, 2012 when the prosecutor blind-sided my lawyer with
14
the IRS Binder mid-trial although she had met with Kory, according to my
15
16
17
public defenders, two weeks earlier. Exhibit AAAA: IRS Binder Index (April 9,
2012 Trial Evidence).
116. In or around May 1, 2011 [original report date Wilshire PD]
18
Michelle Rice and Robert Kory evidently went into LAPDs Wilshire Division to
19
discuss what they alleged to be my ongoing harassment of Leonard Cohen.
20
Officer Manjra took the report and stated that Mrs. Rice submitted a detailed
1
2
summary of as to what has transpired since summer of 2005. All the contact
which Mrs. Lynch made with Mr. Cohen and his attorneys are highlighted in a
five page summary. See attached summary. See large envelope containing CD
ROMS. The two CD ROMS contain data logs of phone calls and email. There
4
is no information in this report to indicate or explain how this matter ended up
with LAPDs TMU, a celebrity stalking unit who also handles government
workplace violence matters. The summary of the report is as follows: In the
1980s the victim and suspect had a sexual relationship. For approximately 17
years the victim employed the suspect as his personal assistant and business
manager. In 2004, the victim fired the suspect, after learning the suspect
9
10
misappropriated over $5 million of the victims money. In 2005, the victim filed
a civil action against the suspect in an attempt to recover the misappropriated
11
funds. During and after the civil action the suspect harassed the victim with
12
both telephone calls and emails. In September of 2008, Boulder, Colorado
13
courts granted the victim a permanent restraining order, which DOES NOT
EXPIRE. Since 2005, the suspect has violated the restraining order many,
14
many times. Exhibit BBBB: LAPD Report (emails are generally requests for
15
tax information.)
16
117. The LAPD summary is followed by notes re. the Investigation.

17
This investigation evidently took place on October 11, 2011 @ 1100 hours.
18
Detectives R. Smith and I met with the victim and his attorneys [listed as
19
witnesses above the Summary], Michelle Rice and Robert Kory. The meeting
20
took place at Michelle Rice and Robert Korys law office, located at 9300
1
2
Wilshire Blvd., Beverly Hills, California. Mr. Cohen stated that he and the
suspect had a casual sexual relationship in the 1980s. In 1988 the person
handling his business affairs died. The victim replaced him with the suspect,
hiring her as his personal assistant and business manager. In 2004 the victim
4
discovered that the suspect stole over $5 million of his money. The victim
terminated the suspect and filed a civil action against her in 2005. The suspect
began sending him numerous emails from her AOL email account. The suspect
also created several Gmail accounts and continues sending email messages to
the victim. The messages were emailed directly to the victim as well as cc
the messages to third parties. Most of the messages were disturbing and
9
10
11
defamatory toward the victim and his family. The contents of the emails often
had the victims personal address, private home telephone number and some
contained his social security number.
12
13
118. LAPDs June 14, 2011 report states: The violations occurred via
14
direct phone calls to the victim and emails to the victims attorneys, Rice and
15
Kory. The emails generally were in request of tax and financial information to
amend Kelley Rice [sic Lynch] 2001 through 2010 tax returns. Neither
16
17
Robert Kory nor Michelle Rice were part of the 2008 original Boulder, Colorado
order. The judge included their physical place of business where Leonard
18
Cohen has an office. I had been to that office once in 2005 months before
19
Cohen obtained his first tactical restraining order against me.
20
1
2
119. During my 2012 trial, where the default judgment was used against
me, the prosecutor began eliciting testimony about Phil Spector. The IRS, Phil
Spector, and the default judgment were the key issues throughout this trial.
The prosecutor argued that the default judgment is essentially evidence of

4
theft using a default judgment entered against me when the Court lacked
jurisdiction to do so. Her closing argument included utterly inane comments
about my having sticky fingers and not having an exit strategy. The two
primary things I didnt have was an excellent attorney and money. The fact that
I have not been represented throughout this matter, and others, is highly
relevant and material as well. The Complaint and default judgment have been
9
10
used to prosecute me, destroy my reputation, filed and amend federal tax
returns, obtain fraudulent IRS and FTB tax refunds, defend Cohen to the head
11
of tax fraud at IRS in Los Angeles, and is now being used to prevent me from
12
requesting/receiving IRS required tax and corporate information for 2004 and
13
14
15
2005 and thereafter.

120. Cohens testimony about Phil Spector throughout this 2012 trial
shows a pattern that tends to prove he is a chronic liar who may have received
some form of quid pro quo from the former District Attorney, Steve Cooley, who
16
elected not to prosecute Cohen after I filed a Complaint with his Major Fraud
17
Unit which was evidently headed by Spector prosecutor Alan Jackson. The
18
prosecutor advised the jurors that I fought with the DA over this issue. Ive
19
never spoken to Steve Cooley. I was extremely upset that the DAs office
20
refused to investigate and/or prosecute the individuals whose criminal

1
2
negligence led to my sons horrifying accident at Whole Foods. I think any

parent would be and this was a very serious public safety issue. Exhibit CCCC :
Trial Transcript (RT 40).
3
4
5
There is the evidence will show that Ms. Lynch was upset and Mr. Cohen and
fought with the District Attorneys office, the LA County District Attorneys
office didnt fie charges against Mr. Cohen. And some of those emails that were
sent to Mr. Cooley, the email will say Execute Steve Cooley. RT 40
6
7
8
121. Although I have no idea why Steve Cooley, Alan Jackson, Phil
Spector, and Dennis Riordan, and IRS were constant themes throughout my
2012 trial, the IRS remains a constant theme in the instant matter. Cohen has
advised this Court that the prejudice to him, should the motion be vacated, is
10
the fact that he filed his 2005 tax return and amended his 2004 and 2003 tax
11
returns using the Complaint. The evidence in the IRS binder proves that he
12
did not use the actual default judgment to file his returns, or obtain substantial
13
refunds from IRS, but rather rushed to the IRS with the Complaint. Thats the
primary motive behind this fabricated narrative.
14
15
122. Leonard Cohen testified that he has had no contact with Phil
Spector since they worked on the joint album project. However, in a BBC radio
16
17
interview, from 1994, he alleges that he and Spector had recently spoken and
goes onto say that Spectors no longer mad at him. Cohen also testified that I
18
accused him of perjuring himself in the Spector Grand Jury. According to the
19
prosecutor, this was evidently annoying to Cohen. I have been very clear that
20
Mick Brown, UK Telegraph, advised me that he reviewed the Phil Spector

1
2
Grand Jury testimony and Cohens testimony/statements were presented. I

have spoken with the legal adviser to the Grand Jury who could not advise me
what witness presented this testimony or statements. She advised me to
contact Phil Spectors appellate attorney about the numerous versions of the
4
Leonard Cohen good rock n roll story about Phil Spector before LA Superior
Court. Cohen was under oath during my trial when he testified that Spector
held a gun to his head and it was an automatic. I have also included below the
language from an email Leonard Cohen provided to the prosecutor at the outset
of my trial. In that particularly email, Cohen advised the prosecutor that

Spector held a gun to his neck. During my trial, Leonard Cohen testified that
9
10
Spector held an automatic weapon to his head. The District Attorney, in their
motion in limine in the Phil Spector Murder Trial (and, possibly before the
11
Spector Grand Jury, if Mick Brown was correct when he advised me that he
12
reviewed the Grand Jury Testimony and Cohen statements were included in the
13
transcript), used a version of Cohens good rock n roll story about Phil Spector
holding a semi-automatic weapon to his chest. There are now three versions of
14
this incident before LA Superior Court and/or with local LA government

15
16
17
18
19
20
officials. It just depends which courtroom you were in at the time, I suppose.
Exhibit DDDD: Trial Transcript (RT 56-57)..
Streeter: Did Ms. Lynch ever mention People that both you and she knew?
Cohen: She talked about some well-known singers that both of us know.
Streeter: Im sorry well-known Cohen: She talked about some well-known
singers that both of us knew. Streeter: Such as who, Mr. Cohen? Cohen: Such
as Bob Dylan. Streeter: What about did she ever mention Phil Spector or
Phillip in any of those? Cohen: Yes, she accused me of she accused me of
testifying before a Secret Grand Jury which resulted in the conviction of Mr.
1
2
Spector. Streeter: Do you know Mr. Spector? Cohen: I knew him. He

produced a record of songs that we wrote together. It was in 1977. Streeter:
But you had no dealings with him since then; is that right? Cohen: No, I dont
believe I havent seen him. I dont remember if it was 77 or 78 that the
record came out. But since then, no, I have had no contact with him. RT 56-57
3
4
BBC Radio Interview With Leonard Cohen:
5
6
7
8
9
Transcript of BBC Radio 1 programme about Leonard Cohen, broadcast Sunday

7/8/94. Hesitations, "you know"s and other verbal tics have largely been
removed, except where useful to indicate the rhythm of the spoken words (LC
becomes particularly hesitant when talking about his time with Phil Spector).
Due to the fact that it was (apparently) unscripted, the grammar represents
patterns of speech, and may appear odd at first sight. Songs in brackets were
played (usually in part) during the programme, and often faded into the
background during the following speech. Excerpt [Cohen]: Hes [Phil Spector]
not mad any longer, Ive spoken to him on the phone recently, hes really quite
reasonable and calm, but we were, you know, I was flipped out at the time
10
11
http://www.webheights.net/speakingcohen/bbctrans.htm
12
Leonard Cohen (baldymonk@aol.com)
13
to Sandra Jo Streeter (email sandrajo.streeter@lacity.org)
14
cc: Michelle Rice (mrice@koryrice.com)

Thu, April 5, 2012 at 9:31 PM
15
16
Dear Ms. Streeter,

17
18
19
This is a short note I prepared for a biographer last year. I know youve been
burdened with an enormous heap of material, but this rounds off the answer to
question you asked about Phil Spector.
20
1
2
3
Sincerely,
L
PHIL SPECTOR
4
5
Shortly after the death of Lana Clarkson, I was visited in my home by two
detectives from the Homicide Bureau of the Los Angeles Sheriffs Department,
Detective Paul Fournier, and Detective Richard Tomlin.
6
7
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9
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Kelley Lynch thought it would be a good idea to have a lawyer present, so she
arranged for Attorney Steven M. Cron to be there for the interview. Mr. Cron
asked Kelley Lynch to excuse herself, and she left the room.
Apparently the detectives had come across some old interviews I did in 1978 or
1979 in which I spoke of the difficulties of recording Death of a Ladys Man
with Phil Spector: the brandishing of guns, armed bodyguards, drunkenness,
and Phils famous megalomania. Even though Phil put his arm around my
shoulder and pressed an automatic into my neck, except for the real possibility
of an accident, I never at any moment that that Phil meant to do me harm. I
never felt seriously threatened. I conveyed this to the detectives. I said the
incident was repeated in the press over the years, with exaggerations, but it
was basically just a good rock n roll story.
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Then they asked me when I had last seen Phil Spector. I said its been over 20
years. They were very surprised. They said they were under the impression we
were close friends. I said no. Hearing this they thanked me for my time,
finished their coffees, and left. It was clear that I was not to be considered a
valuable witness.
I was never approached again by anyone concerned with the case. Needless to
say, I did not testify before a Grand Jury.
20
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123. During the trial, the prosecutor (who had DA Steve Cooleys
investigator in the courtroom) elicited testimony about Phil Spector and a gun.
This was confirmed, as well, during the March 23, 2012 bail hearing when
Judge Mayerson asked who was in the courtroom. At that time, I decided to
4
contact Phil Spector through his trial attorney, Bruce Cutler. This led the
prosecutor to consult a domestic violence counselor who decided I should be
committed to a mental hospital and drugged. Streeter felt my letters to Cutler
were too chatty. I ultimately did write Phil Spector directly and he personally
responded. After all, Phil Spector has as much right to confront his accuser as
I do. Exhibit EEEE: Bail Hearing Transcript (RT 6 DA Investigator).
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Court: Well, there are three people in the courtroom. Are any of them defense
witnesses? Perroni: No, Your Honor. Streeter: No, they are not witnesses,
Your Honor. One is an investigator with Mr. Cohens law firm. The lady sitting
at the back is an investigator with the District Attorneys Office, and I believe
the other gentleman is a defense attorney, correct? He is a defense attorney.
Court: All right. As long as they are not witnesses, they are certainly entitled
to remain in the courtroom. Streeter: The reason why the District Attorney
investigator is here, Your Honor, is in the number of the emails that Ms. Lynch
has sent, shes also made threats against Mr. Cooley. That is why the District
Attorneys investigator is here today. Court: Shes entitled. Bail Hearing RT 6.
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PD: Do you think Steve Cooley was reading all of these emails? Cohen: I
wouldnt be surprised if he was. PD: Okay. But you dont know? Cohen: No,
Sir. PD: Do you believe that he was? Cohen: I believe that people close to him
were. PD: Do you believe that the IRS was reading every single one of these
emails? Streeter: Objection; relevance. Court: Sustained. RT 305
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124. As of April 5, 2012, according to the evidence the prosecutor

provided my lawyers during my high profile trial, the prosecutor was in
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possession of an email from Leonard Cohen regarding Phil Spector, his Grand
Jury, and the alleged Spector gun incident. The prosecutor elicited testimony
from Cohen about an April 18, 2011 email I sent Dennis Riordan, Phil Spectors
appellate attorney. In that email, I confirmed for Mr. Riordan that Cohen told
4
me for 20 years that Spector never held a gun on him. The prosecutor asked
Cohen to review the email and confirm that he was one of the recipients. He
confirmed that he was and then read the portion the prosecutor found relevant:
my comments to Dennis Riordan. Exhibit FFFF: (April 18, 2011 email
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testimony - RT 160-161; 266)

Streeter: I have Peoples 13. Now, thinking back to the emails that you
received from Ms. Lynch about Mr. Spector, would she use his whole name or
would she use part of his name, or did it vary? Cohen: It varied, but I think it
was usually Phil Spector Occasionally when she spoke of him as someone she
knew well, I think she would call him Phillip. Streeter: Im going to show you
an email. Its April 18, 2011. I misspoke. Its at 8.11 AM. Just look at the
first page on the date. See if that refreshes your recollection. Let me know
when youve done. Cohen: Yes Maam. Streeter: Did does that refresh your
recollection as to whether or not you received an email on April 18, 2011 at
approximately 8.11 AM in the morning. Cohen: Yes, this is the email I
received. Streeter: See if that email helps you recall whether or not there was
any mention of either a Phil, a Phillip, or Phil Spector in the email. Cohen: In
this particular email, Mr. Spector is called Phillip. Streeter: Okay. And on
what page is the email? What page is the mention of Mr. Spector? Cohen: I
havent studied the whole email, but it begins on the first page. Streeter: How
many pages is that particular email, Mr. Cohen? Cohen: Seven pages
Streeter: Is your name mentioned in any way with Phillip, Mr. Cohen? Cohen:
Yes. It says, Cohen told me Phillip never held a gun on him, and that would
support what he told LAPD. RT 160-161
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PD: I wanted to start, basically, where we left off in talking about certain
emails. Ms. Streeter asked you about certain emails. Do you remember that.
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Cohen: Yes, she asked me about many. PD: Now, one of thee emails that she
mentioned was sent on April 18, 2011 at around 8.11 AM Do you remember
testifying about that email? Cohen: Yes, I believe I did. Kelly: Okay. And when
you testified about that email, you said that you remember receiving that
email? RT 265 Cohen: I think I did. Kelly: Can you point out where exactly
on the list of recipients that your email address shows up? Cohen: Perhaps I
missed this one. Kelly: Okay. But you did testify, though, that you remember
receiving that email, correct? Do you remember testifying to that? Cohen: I
believe I did. Kelly: Okay. Were you wrong when you -- did you misspeak when
you said that? Cohen: I havent checked every address. Kelly: Okay. You can
take a moment -- Cohen: Its very small. Kelly: Take all the time that you need.
Cohen: If you say its not here, I understand what your point will be PD:
And so youve had a chance to look over that email, the recipients? Cohen:
Yes. PD: And your email is not on that, correct? Cohen: Thats correct. RT
266
125. During cross-examination, my lawyers focused on Cohens mental
state and asked him if he was afraid of Phil Spector when he allegedly held a
gun to Cohens head. Cohen testified that he was not. He was evidently afraid
of my emails that LAPDs report confirms were generally requests for tax
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information. His testimony about a gun contradicts the version the DA used in
motions filed with the Court in the Phil Spector matter.
126. Also during cross-examination, Leonard Cohen confirmed that he
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was actually not a recipient of the April 18, 2011 email. This email is highly
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material and relevant. The reason for this is due to the fact that 1) the
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prosecutor concealed the elements of the email addressed to Internal Revenue
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Service and Cohens lawyer, Michelle Rice, by saying she misspoke when she
noted that she misspoke and the time was actually 8.11 AM and concealed the
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relevant 5.44 AM portions of the email; 2) Cohens testimony about the gun and
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Spector contradicts the version he provided the prosecutor at the beginning of

my trial (as well as the version the DA used in the Spector case); and, 3) it
proves that Cohen continually lies under oath. He was not copied in on the
April 18, 2011 email and he confirmed that he reviewed it and he was. This
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was clearly a way to elicit testimony about Phil Spector and a gun incident.
The emphasis on former DA Steve Cooley, Spector prosecutor Alan Jackson,
Phil Spector, and Dennis Riordan, throughout my 2012 trial, was and remains
inexplicable. And, while prosecutor Sandra Jo Streeter advised the jurors that I
fought with the LA DAs office (which is not factual) she did not explain the
details or provide any evidence supporting that assertion or providing any
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information as to why the DA elected not to prosecute Leonard Cohen or how

she obtained that information. In December 2006, without knowledge of the
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terms of the default judgment, I filed a complaint with the DAs Major Fraud
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Unit against Leonard Cohen with respect to his theft from me, fraud, and issues
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related to the entities in the default judgment. I was questioned by the

prosecutor over this complaint. She seemed to believe that I thought I could
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find the tax information Cohen refuses to provide me on Cooleys website.

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Exhibit GGGG: Trial Transcript (Spector & Cooley: Pages 40, 60-61, 56-57,
157-159, 305, 265-266); Mick Brown emails.
There is the evidence will show that Ms. Lynch was upset and Mr. Cohen and
fought with the District Attorneys office, the LA County District Attorneys
office didnt file charges against Mr. Cohen. RT 40
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She accused me of testifying before a secret grand jury which resulted in the
conviction of Phil Spector. RT Streeter: Okay, in any of her emails, did she ever
mention Phil Spector? Cohen: She often mentioned Phil Spector, repeating
over and over that I had testified before a Grand Jury and I was involved in the
conviction of Phil Spector. RT 60-61
127. Because I have asked the Court to terminate this matter based upon
5
egregious fraud upon the court and refer this matter to the appropriate
authorities, I have prepared general summaries of the perjured statements in
the declarations of Leonard Cohen, Robert Kory, and Michelle Rice that were
submitted in response to my Motion to Vacate. I do have additional evidence
but feel that the evidence I have attached hereto, and made a part hereof, gives
a very good general overview of what actually occurred and what has unfolded
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to date. Exhibit HHHH: Schedules of Perjury Declarations Leonard Cohen,

Michelle Rice, Robert Kory, and Kevin Prins; Misrepresentatives in Declaration
of Scott Edelman.
128. I have attached the following exhibits to this declaration in support
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of my motion:
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Exhibit A: Robert Hilburn Article; photo of Cohen working at Mt. Baldy.
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Exhibit B: Boulder Combined Court email and attached evidence; Kory & Rice
domestic violence related orders.
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Exhibit C: Emails with court reporters re. March 23, 2012 hearing transcript.
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Exhibit C-1: MacLeans article. August 22, 2005.
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Exhibit D: Phil Spector Motion in Limine (Excerpted pages Leonard Cohen

gun incident); Mick Brown emails.
Exhibit E: Trial Transcript (RT 308-309).

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Exhibit F: Transcript March 23, Hearing.
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Exhibit G: Marty Machat letter dated November 25, 1990; Stranger Music, Inc.
Spreadsheet.
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Exhibit H: Berger, Berger & Beal letter to Marty Machat dated January 5,
1972.
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Exhibit I: Email to Steven Machat dated March 2, 2015 confirming book

excerpts.
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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.
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Exhibit L: IRS Notice dated September 12, 1988. [Confusion re. alternate SSN
& IRS account]
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Exhibit M: Van Penicks letter to Kelley Lynch dated October 26, 1988.
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Exhibit N: LC letter to Dominque Issermann dated December 7, 1989 (off-shore

account).
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Exhibit O: Jonas Herbsman letter to Herschel Weinberg dated January 8, 1990.
Exhibit P: SOCAN Agreement (with Leonard Cohen).

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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.
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Exhibit R: Kelley Lynch fax to Richard Feldstein dated December 7, 1993.
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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 Greenbergs fax to Cohens transaction attorney, Jonas

Herbsman February 10, 1998.
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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).
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Exhibit V: Cohens Opposition to CAKs Motion for an Order of Attachment

dated August 30, 2000.
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3
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Exhibit W: Leonard Cohens 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.
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Exhibit Y: Ken Cleveland fax to Kelley Lynch dated July 22, 1999.
Exhibit Z: Reeve Chudd letter to Kelley Lynch dated September 8, 1999.
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Exhibit AA: LC Investments, LLC Certificate of Formation dated October 19,

1999; Operating Agreement dated August 21, 2000.
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Exhibit BB: Leonard Cohens email (baldymonk@aol.com) dated May 19, 2000
to Kelley Lynch (tsimar).
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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.
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Exhibit FF: Cohen signed Assignment (signature page only) dated September
15, 2000.
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Exhibit GG: Richard Westins September 16, 2000 letter to Kelley Lynch.
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Exhibit HH: LASD Inventory dated October 18 & 24, 2005.
Exhibit II: May 21, 1994 letter to Kelley Lynch from Tom Robbins.
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Exhibit JJ: Don Friedmans letter to Stuart Bondell, Sony, dated September 19,
2000.
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Exhibits KK: Westin fax to KL and Greg McBowman dated September 20, 2000.
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Exhibit KK-1: Fax from Richard Westin to Cohen and me dated October 10,
2000.
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Exhibit LL: Richard Westin Proposal to Leonard Cohen dated November 19,
2000.
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Exhibit MM: Richard Westin Proposal to Kelley Lynch and Leonard Cohen
dated December 4, 2000.
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Exhibit NN: Leonard Cohen letter to Westin dated December 7, 2000

(wrapping Greenberg in A/C privilege).
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Exhibit OO: Annuity Agreement dated December 7, 2000.
Exhibit PP: Kelley Lynch/TH Promissory Note; Corporate Minutes dated

December 21, 2000.
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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 Lynchs name.
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Exhibit RR: Traditional Holdings Stock Certificates No. 1, 2, 3; Stock Ledger.
Exhibit SS: CAK Settlement Agreement dated December 7, 2000.

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Exhibit TT: KL Indemnity Agreement dated January 8, 2001.
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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)
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Exhibit XX: Lynch & Westin emails (cc: Cohen) dated February 11, 2002.
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Exhibit YY: Richard Westin letter dated March 6, 2002.

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Exhibit AAA: David Woltz, IRS Office of Chief Counsel, letter to Richard Westin
dated October 8, 2002.
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Exhibit BBB: State of Kentucky Schedule K-1 for Lynch & Cohen 2003.
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Exhibit CCC: Neal Greenberg IRS Danger Warning letters dated January 16,
2004 and June 25, 2014.
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Exhibit DDD: Westin emails re. Old Ideas, LLC; Dear Heather liner notes
publishing Old Ideas, LLC.
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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.
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Exhibit GGG: Kelley Lynch (tsimar) email to Leonard Cohen (baldymonk) dated
September 16, 2004 [Commission 1099 information].
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Exhibit HHH: Diane Baxa, City National Bank, email to Kelley Lynch dated
March 29, 2013.
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Exhibit III: Trial Transcript (pages 301-303; 319; 290-293)
Exhibit JJJ: Richard Westin email to Kelley Lynch dated September 24, 2004.
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Exhibit KKK: Westin emails to Lynch dated September 20, 2004 (LCI Office)
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Exhibit LLL: Westin letters to State of Kentucky; Lynch and Cohen) dated
October 6, 2004.
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Exhibit: LLL-1: 2001, 2001, and 2003 Traditional Holdings, LLC tax returns.
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Exhibit MMM: DiMascio letter to Robert Kory dated November 13, 2004 (CNB
account freeze).
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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).
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Exhibit PPP: DiMascio &Berardo letter to Kelley Lynch dated February 7, 2005.
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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).
11
Exhibit SSS: Steve Lindsey email to Kelley Lynch dated May 2, 2005.
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Exhibit TTT: Ann Diamond (draft article for Rolling Stone).
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Exhibit UUU: King Drew May 225, 2005 fraudulent report.

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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).
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Exhibit XXX: Kelley Lynch State Bar Complaints re. Cooley & Lindseys custody
lawyers dated February 17, 2007.
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2
3
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Exhibit YYY: State Bar Letter re. Cooley dated February 28, 2007.
Exhibit ZZZ: Judge Lewis Babocks 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
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information.)
Exhibit CCCC : Trial Transcript (RT 40).

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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)
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Exhibit GGGG: Trial Transcript (Spector & Cooley: RT 40, 60-61, 56-57, 157159, 305, 265-266); Mick Brown emails.
15
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Exhibit GGGG-1: (SSN & Drivers License: RT 301-303, 319)
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Exhibit HHHH: Schedules of Perjury Declarations Leonard Cohen, Michelle

Rice, Robert Kory, and
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Kevin Prins; Misrepresentatives in Declaration of Scott Edelman.
20
Exhibit IIII: Cohen Affidavit - Natural Wealth (Complaint attached as Exhibit

A to Tactical Allocations Ex Parte Application in Intervention for Order
Protecting & Preserving Evidence Related Case No. BC341220).
I declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.

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Dated: 12 March 2015

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______________________________________
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Kelley Lynch, In Propria Persona
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Motion Exhibit 4 - Declaration of Kelley Lynch - 03.16.15 FINAL

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Motion Exhibit 4 - Declaration of Kelley Lynch - 03.16.15 FINAL

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DECLARATION OF KELLEY LYNCH

Kelley Lynch declares:

In approximately 1984, I began working for legendary

entertainment industry attorney, Marty Machat. From approximately 1994

Cohen hired me to work as his personal manager. I worked as Leonard Cohens

Following Marty Machats death, Phil Spector hired me as his personal

assistant/intern. I worked for Mr. Spector from sometime in 1988 through,

- 1 DECLARATION OF KELLEY LYNCH

other projects. Beginning in approximately 1996, I began working as Adam

on a very successful world tour. Additionally, Cohen was unraveling certain

required a tremendous amount of work on the part of his representatives and

myself as contracts had to be renegotiated and, in many instances, Cohen did

In late 1989, at the specific request of Leonard Cohen, my family

term temporary position with Deneuve Construction in Boulder, Colorado. I left

- 2 DECLARATION OF KELLEY LYNCH

me to file a motion to vacate. He also instructed me to address Cohens perjury

issues related to vacating a judgment. A friend of mine in Ft. Lauderdale,

point I relocated to Berkeley, California. One of the reasons I chose to relocate

including my friend Anam Thubten Rinpoche. At some point after moving to

- 3 DECLARATION OF KELLEY LYNCH

Southern Poverty Law campaigns. At some point in January 2012, my son

of an extradition hearing which Berkeley PD assured me I was entitled to.

prosecutors statements about Traditional Holding, LLCs assets although the

reasons I cannot imagine, people seem to think that lying is acceptable,

targeting people is acceptable, destroying a family is appropriate, stealing is

thought processes. I was convicted and sentenced under domestic violence

- 4 DECLARATION OF KELLEY LYNCH

work with my appellate attorney on my appeal (without the benefit of my file or

my file or critical information. In June 2013, I relocated to Los Angeles,

California. At that time, I continued researching issues related to the Motion to

documents in this or the related case. On August 9, 2013, my appellate

research or writing of that document. While I had provided him with an

him to sign on my behalf. He then crossed off Exhibit C on Rutgers

hearing. Therefore, I diligently pursued what I was capable of and in a timely

- 5 DECLARATION OF KELLEY LYNCH

When I originally moved to Los Angeles at some point around early

mid-Wilshire home and we became quite close in terms of our business

lease on our former premises and moved my management company offices

agreement with respect to my services as his personal manager. That

of all intellectual property. Everything was relatively congenial during this

period of time. Leonard Cohens daughter, Lorca Cohen, was frequently at my

- 6 DECLARATION OF KELLEY LYNCH

Poems and Songs. Following that release, Cohen participated in a selective

works, in an environment that provided solitude, discipline, and allowed him to

Los Angeles. He was also frequently in Los Angeles where he maintained a

seemed to be more of a formality than any type of actual religious vow.

Leonard Cohen was not, contrary to the allegations in his Complaint, in a

compilation and production of at least one live album; began regularly

correspondence and materials.

At some point in 1994, His Holiness Kusum Lingpa, a Tibetan lama,

Holiness which was located downstairs from my personal management office. I

and spent a considerable amount of time together. Oliver Stone released

where he previously had a relatively limited audience. At some point in or

accuse me of having sex with Oliver Stone in a blatant attempt to stir up a

custody matter with my younger sons father.

In or around 1994, Leonard Cohen understood that many major

- 8 DECLARATION OF KELLEY LYNCH

income into off-shore accounts.

In 1995, the tribute album Tower of Songs: The Songs of Leonard

phone Chris Doritos, KCRW, in 1997 to arrange an interview related to the

pension fund I had) to purchase my home in Brentwood, California. Cohen has