10 un 2 13 14 15 16 1" 18 19 20 a 2 4 2s 26 a 28 MICHELLE L, RICE, SBN 235189 KORY & RICE, LLP’ 19300 Wilshire Blvd, Suite 200 [Beverly Hills, Califia 90212 Telephone: (310) 285-1630 Facsimile: (310) 278-7641 BERGMAN LAW GROUP 21600 Oxnard Steet, Suite 1060 ‘Woodland Hills, CA 91367 Telephone: (818) 999-9100 Facsimile: (818) 999-9184 | Attomeys for PLAINTIFFS LEONARD NORMAN COHEN; LEONARD COHEN INVESTMENTS, LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES-CENTRAL DISTRICT "ASE NO.: BC338322 LATED CASE NO.: BCM1120 Delaware Limited Lisbility Company, ssigned tothe Hon. Robert L. Hess ep 24 Plainiti, y "LAINTIFFS' NOTICE OF MOTION AND jOTION FOR SANCTIONS AGAINST /KELLEY LYNCH, an individual; RICHARD A. [DEFENDANT KELLEY LYNCH PURSUANT] WESTIN, an individual; DOES I through 50, [TO CCP §1008(a) AND CCP $128.7; inclusive, EMORANDUM OF POINTS AND UTHORITIES IN SUPPORT Defendants HEREOF ‘TO THE COURT AND DEFENDANT AND MOVING PARTY IN PRO PER: PLEASE TAKE NOTICE that on Septcmber 3, 2015 at 8:30 aan. at the above referenced Court located at 111 North Hill Sweet, Los Angeles, California, 90012, before the Honorable Robert L. Hess, Judge of the Los Angeles Superior Cour, Plaintiffs Leonard Norman Cohen and Leonard Cohen Investments, LLC will move the Coust under California Code of Civil Procedure Sections 1008(4) and 128.7 for an order awarding Plaintiffs sanctions against Defendant Kelley Lynch in10 u 2 13 “4 1s 16 ” 18 19 20 a 25 6 a” ‘conneetion with Defendant's Motion For Terminating und Other Sanctions filed with the Court on March 17, 2015. Plaintiffs’ Motion for Sanctions is based on the grounds that Defendant’s Motion violates Cal. Code of Civ. Proc. §1008 and is legally and factually frivolous in violation of CCP §128.1(b)(2) and §128.7(6X3). Further, Defendant's Motion was filed for the improper purpose of harassment of Plaintiff and his attorneys in violation of CCP §128.7()(1) as evidenced by: i) the voluminous nature of the filing itself, totaling over 1,100 pages, which violates California Rules of [Court and contains considerable extraneous and salacious content meant to vexate and harass |Cohen; i) the intentional disclosure of Cohen's attorney-client privileged communications with his former and current attorneys as exhibits to her declaration fled in support of her motion; ii) the false imputation of criminal conduct to Cohen; iv) the false imputation of criminal and | unethical conduct to Cohen's current attomeys; and ) the wholly pre-extual use of the sham filing as a vehicle to continue her public campaign of harassment of Cohen as evidenced by her May 7, 2015 “press release” published on her Internet blog which repeats the false accusations of criminal conduct made in her motion and threatens future litigation against Cohen and his attorneys. For the violations of CCP §1008(d) and CCP §128.7(b, Plains will sek nonmonetary under CCP §128,7(4) to issue remedial directives to sanctions pursuant to the Court's author eter future misconduct. Plaintiffs will seek an order from this Cour fr the following relief: 1) to either prohibit Lynch from filing any further motions in this ease, Civil Case Number /BC 358522, or, in the alternative, require Lynch to seek leave to file from the Supervising Judge ofthe Los Angeles Superior Court before filing any further motions inthis case 2) to order Lynch to rewm Plait [documents to Plaintiffs’ counsel within 7 days of the dete of the Court’s order and to cet Gis? attomey-client privileged and confidential iting, under the penalty of perjury, that all of Plaintiffs’ atomey-clent privileged ond confidential documents heve been reumed to Plaintif* counsel, inhaling all hard copies and electronically stored versions of such documents in her possession. Lynch's failure to return Plainifs attorey-clicat privileged or other confidential documents to Plants’ counsel within 7 days of the date of the Cours order or the false eeetfication by Lynch that all etomey-clent Notive of Motion2 23 4 25 27 28 privileged or confidential documents have been returned to Plaintiffs may subject Lynch to being held in contempt of Cour. 3) to prohibit Lynch fiom further dissemination or publication of Plaintiffs’ attorney-client privileged and confidential documents to thitd parties, including publication of Plaintiffs’ attorney-client privileged and other confidential documents on Lynch's personal web blog located at upstsiverdeepbook blogspot.com, or anywhere else on the Internet 4) Because Lynch has obteined Court services in bad faith for the purposes of harassment of Plaintits, Plaintiffs will algo move this Court to revoke the August 9, 2013 Order on Court Fee ‘Waiver pursuant to its authority under California Government Code $8631 and §68636(9. Plaintiffs’ Motion for Sanctions is based upon the attached Memorandum of Points and Authorities in support ofthe motion and the exhibits attached thereto; the entire Cour file in this matter, and upon such evidence as may be introduced atthe hearing. DATED: May*¥ 2015 Respectfully submitted, ATTORNEY FOR PLAINTIFFS Notice of Motion" 2 B 4 15 6 18 19 20 4 Bo 26 ” 8 ‘TABLE OF CONTENTS, INTRODUCTION AND SUMMARY OF ARGUMENT ....csscveesutesetneeal i. LYNCH’S 2015 MOTION VIOLATES CcP §1008, ‘A, Lynch's 2015 Motion Seeks the Same Relief as 2013 Motion [Vacating the Default Judgment] and Does Not Meet Statutory Requirements of CCP §1008,......mn2 B. CCP §1008(d) Provides for Sanctions under CCP §128.7... IL LYNCH’S 2015 MOTION IS LEGALLY AND FACTUALLY FRIVOLOUS AND WAS FILED SOLELY FOR THE PURPOSES OF VEXATION AND HARASSMENT OF PLAINTIFF AND HIS ATTORNEYS... . ‘A. Legal Standards for Sanetions under CCP §128.7, 3 BB. Lynch's ‘Fraud on the Court’ Claim asa Basis for Equitable Relief From the Default Judgment is Legally Frivolous. 3 . Lynch's 2015 Motion is Factually Frivol0us.....vse eae) Lane's 2015 Motion Was Fed Solely to Verate and Haas Phi and His Attomeys. 7 IV. SANCTIONS UNDER CCP §128.7 ARE NECESSARY TO DETER REPETITIVE FRIVOLOUS AND HARASSING FILINGS... 12 4 CCR 4128.71) Allows he Cot Cit an Appropriate Sanction o Deter Repeated Misconduct. B, The Court May Also Enjoin Future Frivolous and Harassing Filings Through Its Satay Ahr sue “Nononetary Dreier” ax Sanctions under cP §128.7(8), C. Lymeh Has Obtained Court Services in Bad Faith. occ ssesssentnnenenenl™ 3 Vv. CONCLUSION. wal [PLAINTIES' MOTION FOR SANCTIONS AGAINST DEFENDANT KELLEY LYNCH PURSUANT TO GCP 410418 1247n 2 4 25 26 a7 28 TABLE OF AUTHORITIES California State Cases Cedars-Sinai Medieal Center v. Superior Court, 18 Cal. 4" 1 Cal, 1998). Conn v. Superior Court of Los Angeles County, 196 Cal. App. 3d 774 (Cal. Ct. App. 2" 1987). CS. WO, 230 Cal. App. 423 (Cal. Ct. App. 22014). Day v. Collingwood, 144 Cal, App. " 1116 (Cal. Ct. App. 4" 2006). Garcia v, Hejmadl, '58 Cal, App. * 674 (Cal. Ct. App. * 1997). Gauilleminw. Stein, 104 Cal. App. 4 156 (Cal. Ct, App. 3"'2002).. Hammel!» Britton, 19 Cal. 24 72 (Cal. 1941) Hopkins & Carley v. Gens, 200 Cal. App. 4" 1401 (Cal. Ct App. 6" 2011). in Re Margarita D, ‘72.Cal. App. 4 1288 (Cal. Ct. App. 4* 1995). In Re Marriage of Falcone & Fyke, 164 Cal. App. 4 814 (Cal. Ct. App. 6" 2008). Levy y Blum, 92 Cal. App. 4625 (Cal. Ct. App. S* 2001), Ly, Majestic Industry Hills LEC, T7T Cal, App. 4 585 (Cal. Ct. App. 2" 2009) Musaelian v. Adams, 45 Cal, 48512 (Cal. 2008), Olmstead v. Arthur J. Gallagher & Co., '32.Cal, 4th 804 (Cal, 2004). Peake v. Underwood, 227 Cal. App. 4 428 (Cal. Ct App. 42014) Page Number(s) 1 FF" MOTION FOR SANCTIONS AGAAST DEFENDANT KELLEY LYNCH PURSUANT TO CC 10K 040128710 n n 13 4 18 16 1" 18 19 20 a n 2B 4 2s 26 20 28 TABLE OF AUTHORITIES California State Cases Page Number(s ‘Sporn v. Home Depot USA, Ine 126 Cal. App. 4 1294 (Cal. Ct. App. 4" 2008), Steven M. Garber & Associates v. Eskandarian, 150 Cal. App. 4 813 (Cal. Ct. App. 2™ 2007). Taylor v. Varga, 37 Cal. App. 4" 750 (Cal. CL App. 2" 1995), Wallis v. PHL Associates, In., 168 Cal. App. 4" 882 (Cal. Ct. App. 3" 2008). United States Court of Appeals, Ninth Circuit Business Guides, In. v, Chromatie Communications Enterprises, In, 892 F.2d 802 (9 Cir. 1989), Ringgold-Lockhart v. County of LA. 1761 F.3d 1057 (9" Cir, 2014) Warren. Guelker, 29 F.3d 1386 (9" Cis. 1994), United States District Courts, Californ California Sportfishing Protection Alliance v. Callaway, 2013 WI. 4482849, 2013 US. Dist. LEXIS 118097 (E.D. Cal. 2013). ‘Quintero v. Fresno Unified School District, 2013 WL 1832681, 2013 U.S. District LEXIS 62580 (E.D, Cal, 2013) tutes California Code of Civil Procedure $128.5. gu287. $128.10) §128.7(b)(1). §128.7(b)2). 5,14 3.9 34,5575 13, 4 45 27 a PLAINTIFFS’ MOTION FOR SANCTIONS AGAINST DEFENIANT KELLEY LYNCH PURSUANT TO CCP #10) 282n 2 B 1“ 15 16 ” 18 19 a n 23 u as 6 ca ‘TABLE OF AUTHORITIES Statutes Number(s $128.706)0). esceetnnennnaninnsinnnniesninmnnnnnninnnninnd $12BIBooresesnne a oe 2.1315 $128.70... ; 3 1008. Ce 3 $1086)... 3 $1008¢). estnnntinnnnnnnnnnn 2 California Bvidence Code $647, $9S2aannennee evenness 8 California Government Code §68631 215 §68634(0)... 1s 968636(0. 21s Califomia Penal Code S180. . sesenennnntnnnnnene un California Rules of Court BANO@)snsstnnsnieninnnnnnanns - 6 an. 3.11130). 31113@... [PLAINTIIS MOTION FOR SANCTIONS AGAINST DEFENDANT KELLEY LYNCHPURSUANT TD GOP (10) 1287” 18 19 20 a n 23 24 2s 26 2 ‘TABLE OF AUTHORITIES Federal Rules of Civil Procedure FED.R.CIV.. 11 Page Number(s 4810 1" n 8 “4 18 16 "7 18 19 20 a 2 2s 6 a 2% ‘MEMORANDUM OF POINTS AND AUTHORITIES INTRODUCTION AND SUMMARY OF ARGUMENT Lynch waited nearly seven and a half years (May 2006 ~ August 2013) to move to set aside the May 15, 2006 Default Juigment (“Default Judgment"). During that peiod, Lynch ignored the Default Judgment and instead undertook her mul-year couse of harassment of Cohen and his attorneys. See Plaintiffs’ Opp. to 2013 Motion to Vacate, Edelman Decl. (12, 20. Her harassment of Cohen continued unabated until she was arrested in March 2012 and then convicted in juy wil for violating Cohen’s Permanent Protective Order in April 2012. (People v. Lynch Los Angeles Superior Court, Case No. 2CA04539), Following a 6-month incarceration (March 2012-September 2012), Lynch filed an appeal lof her conviction. 2015 Motion, Lynch Decl $4. Shorly ater losing her criminal appeal in May 2013, Lynch's next order of business was to seek to set aside the $7,341,345 Default Judgment, Lynch was granted an Order on Court Fee Waiver fee inthis matter on August 9, 2013. Exh. 1. That same day, Lynch fled in forma pauperis & Motion to Vacate and/or Modify the Default Judgment Entered May 15, 2006 on the grounds of extrinsic fraud with regard to the alleged lack of service of the summons and complaint. (“2013 Motion”). Lynch's 2013 Motion was heard on January 17, 2014 and denied with prejudice. Minute Order, Jan. 17, 2014. The Court found Lynch’s 2013 Motion “not even cotorably meritorious” Jand that Lynch had not shown thet she was enitled to equitable relief. Certified Hearing Transcript, p. 18, lines 18-19 ("Transcript"), The Cour also cite! numerous “procedural issues” and deficiencies with regard to her fling Lynch now files « Motion for Terminating Sanctions (C2015 Motion”) that seeks the same equitable relief and regurgitates essentially the same arguments and presents the same facts as the 2013 Motion. Inthe 2015 Motion, Lynch not only The Court observed that Lynch fled to atach a Proof of Service to her moving papers (Transcript 3, lines 83; hat Lynch ha failed toile a Proposed Answer to her Metin Transcript, p. 7 ies 23-25) that her 2-page motion exceeded the 15 page lit Transerip p.3, ines 17-18) and that Lynch hed not bahered to sig er delration, tsrby rendering iin the Cou’ etiation "wots." (Tansrp p.3, ines 23-25). Additonal, he Court also ound ha lyn 66-pge "Case Histor” war impermissible the eto that was incorporate by relrence sd her Memorandum in support of ee retin Trane, 3, ies 1921). Pir Pint” Motion For Santon Again Defendant Kelley Lynch Pursuant to CCP 9§ 1008(4) an 128710 u 2 13 rr 16 uv 18 1” 0 2 n 23 4 25 26 a7 28 Violates California Rules of Cour, but also impermissibly discloses in the public record Cohen's stiomey-lient privileged and other confidential docoments as exhibits to her declaration. As demonstrated moe fll in Plains’ Opposition, Lynch's 2015 Motion violates Califia Code of Civil Procedure (“CCP”) §1008, is utterly devoid of legal and factual merit, and as such, is sanctionable under CCP §128.7(0x2) and CCP §128.7(8)). In violation of CCP $128.78, the purpose of Lynch’s 2015 Motion is not to assert any arguably legitimate legal right, but rather to circumvent Protective Orders to prevent Lynch’s harassment of Cohen and to attempt to destroy [Cohen's attorney-client privilege with his former and current attomeys by publishing Cohen's | aomey client privileged communications inthe public reord in furtherance of her planned future litigation egeinst Cohen. Lynch refuses to accept the finality ofan adverse judgment and defies the authority ofthe Cour. In order to deter future repeated misconduct, Plaintiffs respectfilly request thatthe Court impose noamonetay sanctions under CCP §128,7() in the form of the Couns directives: 1) to bar Lynch from fling any farther motions in Civil Case No, BC 338322 or require Lynch to seek leave to file from the Supervising Judge of the Los Angeles Superior Court before filing any further motions in this mater; 2) to return all of Cohen's attorney-client privileged and other confidential documents stil inher possession; and 3) enjoin Lynch's further dissemination and publication of Cohen's privileyed and confidential documents. Funker, as is clear from her two successive frivolous filings, Lynch has obiained court services in bad faith in violation of Califomia Government Code §68636(9. Under the Cour’s statutory authority pursuant to [Government Code §68631, Plaintfs also request thatthe Court revoke the August 9, 2013 Order on Court Fee Waiver in this mater to deter future frivolous and harassing filings Il, LYNCH’S 2015 MOTION VIOLATES CCF §1008 ‘A. Lynch's 2015 Motion Seeks the Same Relief as 2013 Motion [Vacating the Default ‘Jadgment] and Does Not Meet the Statutory Requirements of CCP §1008. Having been unsuccessful in her first attempt to vacate the Default Judgment on the rounds of “extrinsic fraud” due to the alleged lack of service of the summons and complaint, [Lynch is attempting a “second bite at the apple” by filing a second, successive motion for Plinffs' Motion For Sanctions Against Defendant Kelly Lynch Pursuant to CCP §§ 1008(4) and 128.7,equitable reli from the Default Judgment, Lynch's 2015 Motion violates CCP §1008, which is the sole authority allowing a party to seek reconsideration ofan order or to renew a previously denied motion, CCP §1008(¢). Specifically, section 1008(e) provides in pertinent part “No pplication o reconsider any order or forthe renewal of previous motion may be considered by ary judge or court unless made according otis section” CCP §1008(). Lynch's declaration filed in support of her 2015 Motion doesnot meet the requirements in [CCP §1008(4) for renewed motions. Section 1008(8) provides in relevant past “A party who ication for an order whi orginally made an ap spplication forthe same order upon new of diferent fats [or] crcumstances..n which eas i shall be shown by affidavit what application was made before, when and to what judge, what order or decisions were made, and what new or diferent fcts,eireumsiances, or law are claimed 1 be shown.” CCP §1008(bycmphasis added), Lynch fils to show what “new or different fats, was refused...may make @ subsequent circumstances, or law” have arisen in the fourteen months since the 2013 Motion. Lynch also provides no explanation forthe failure to produce the evidence she seeks to introduce in her new declaration or bring her “fraud on the Court” argument in her 2013 Motion, The fects that Lynch socks to introduce in her declaration, consisting of Lynch's own declared “personal knowledge”, were obviously always within her possession, so they are, by definition, not “new.” Garcia v, Himadi, $8 Cal. App. 4" 674,690 (Cal. Ct. App. 1* 1997). B. CCP §1008(d) provides for Sanctions under CCP §128.7 ‘A renewed motion that docs not meet the statutory requirements of CCP §1008 will be denied and may be punished as a contempt and with sanctions pursuant to section 128.7. CCP '§1008(d); Taylor v. Vargs, 37 Cal. App. 4" 750, 761 (Cal. Ct, App. 2° 1995)(sanctions awarded for violation of section 1008 for duplicative motion o vacate default. Section 1008 was amended in 198 to substitute Setion 1287 fr Section 1285 in subdivision d2 re apization of Ca. Code Civ Proc. 51285 and 1287 does not pend on whther te abuses esrb in Ene nu 10 (at Sn), at, Seto 287 spon rtm nse pn fo oer Panury |, 1995, and any ober pleating, writen note, robe sir paper edn that mater. hd, CCP $128.70), ten Psi" Complain was fed August 13,2005, the operative sanctions att in § 1008) was Sein 128.7 -3- lit’ Motion For Sanctions Against Defendut Kaley Lynch Pursuant to OCP $§ 1008) ad 128.710 un 2 1B 4 15 16 " 18 19 20 a n 2B 24 2s 26 Fo I, LYNCH’S 2015 MOTION IS LEGALLY AND FACTUALLY FRIVOLOUS AND WAS FILED SOLELY FOR THE PURPOSES OF VEXATION AND HARASSMENT OF PLAINTIFF AND HIS ATTORNEYS A. Legal Standards for Sanctions under CCP §128.7 Seotion 128.7 authorizes tral courts to impose sanctions to check abuses in the fling of v.Adams, 45 Cal. 4 pleadings, petitions, written notices of motions or similar papers. Mus 512, 518 fn 2 (Cal. 2009), Code of Civ. Proc. §128.7 requires that an altomey or unrepresented lnarty in a civil action sign all pleadings, petitions, notice of motions and other similar papers. |CCP §128.7(a) (emphasis supplied.) The signature indicates the attomey or unrepresented party certifies that the paper is not being presented for an improper purpose; that legal contentions are yarranted by law or nonftivolous argument for extension, modification or reversal of existing law the allegations and factual contentions have evidentiary support; and denials of factual contentions are warranted by the evidence, CCP §128.7(b); Day v. Collingwood, 144 Cal, App. 41116, 1126 (Cal. Ct. App. 4" 2006); Levy v. Blum, 92 Cal. App. 4" 625, 636 (Cal. Ct. App. 5" 2001), Section 128.7 was adopted to apply Federal Rule of Civil Procedure 11 as amended in } 1993 to cases brought after January 1, 1995. Guillemin v, Stein, 104 Cal. App. 4" 156, 167 (Cal. CL App. 3% 2002), Because of this intent and the fact that the wording of CCP §128.7 subdivisions (2) and (@), is almost identical to FRCP 11(bX2) and (6), federal case law construing Rule 11 is persuasive authority with regard to the mesning of CCP §128,7. Guillemin, 104 Cal. App. 4 at p. 167; See also Musaclian v, Adams, 197 Cal. App. 4" 1251, 1257 (Cal. C. JApp. 1" 2011). Under both Code Civ. Proc. §128.7 and FRCP 11, there are three types of submitted papers that warrant sanctions: (1) factually frivolous (not well-grounded in fact); (2) egally fivolous (not warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law); and (3) papers interposed for an improper purpose. Gaillemin, 104 Cal. App. 4" at 167. ‘A motion that is frivolous and/or interposed for improper purposes is sanctionable conduct under Section 128.7. See, eg, Liv. Majestic Industry Hills LLC, 177 Cal. App. 4® 585, 589 (Cal. [cx, App. 2" 2009)trial court awarded sanctions to defendant pursuant to CCP §128.7 on the Plaintiffs" Motion For Sanctions Against Defendant Kelly Lynch Pursuant to CCP §§ 1008( end 128.710 u 2 13 4 1s 16 " 18 19 20 a n 23 4 25 26 a 28 {round that Li's motion to vacete was frivolous.); Hopkins & Carley v. Gens, 200 Cal. App. 4 1401 (Cal. Ct. App. 62011), Sanctions under 128.7 and Rule 11 have also been imposed upon in propria persona litigants who file frivolous motions forthe sole purposes of harassment, See, €., /In Re Marriage of Falcone & Eyke, 164 Cal. App. 4" 814, 830 (Cal. Ct. App. 6% 2008)(Section 128.7 monetary sanctions against in propria persona wife for her motions against former husband that were “reckless, baseless and frivolous”); Quintero v, Fresno Unified Schoo! Distict, 2013, WL 1832681, 2013 U.S. Dist. LEXIS 62580 (E.D. Cal. 2013). Lynch asserts in her 2015 Motion that “[Piaintiffs] have taken advantage of Dependent Isic, Defendant] du to the fact that she has been self-represented since the Complaint in this ‘matter was fled.” 2015 Motion, Memo., p. 12. Lynch should be held to the same standards as an stiomey litigant. Section 128.7, by its terms, applies to propria persona litigants as well as sttomeys. CCP §128.7(b),(c); In Re Marriage of Falcone & Fyke, 164 Cal. App. 4 814, 826 (Cal Ct. App. 6" 2008). Federal Rule 11 has also been held to apply to partes proceeding in propria persona, Warren v. Guelker, 29 F.3d 1386, 1390 (9! Cir. 1994). Lynch is not a litigant without any background or experience in the law.? Lynch told the Court in the January 17, 2014 hearing that she had undertaken the legal research and drafted her 2013 Motion. Transcript, p. 18, lines 27-28; p. 19, lines 1-3. In response, the Court found that there was “no excuse” for the numerous defecs in her 2013 Motion, Transeriptp. 19, lines 46. B. Lyneh’s ‘Fraud on the Court? Claim asa Basis for Equitable Relief From the Default Judgment is Legally Frivolous Whether an action is frivolous is governed by an objective standard: any reasonable attorney would agree itis totally and completely without merit. Levy v, Blum, 92 Cal. App. 4” 625, 635 (Cal. Ct. App. S" 2001); Guilemin, 104 Cal. App. 4 at 167 (Section 128.7 requires only that the conduct be “objectively unreasonable” to be sanctionable) Lynch worked four years asa egal astnt to New York atamsy Marin Macht, Cohen's fermer story ad manager, Lynch Desk, 2. Lynch alo deslares tha ee has worked Taw ims varius pats of de cut)” ah tok temporary poston witha poalga group in Santa Moni In 2010 when she was vsing be son. Lyneh Dec ins $21; $11 Ese Pant" Motion For Stetons Agsist Defends iy Lyne Pursuant to CCP $§ 1008) and 128710 " 2 13 4 18 16 7 18 19 20 un n 23 24 25 26 a 28 Lynch's “fraud upon the Court” clsim as a basis for equitable relief from the Default Judgment is totally and completely without merit and therefore legally fivolous because Lynch assert claims of intinsic fraud, Lynch's own cited case authority, decided under California law and procedure, demonstrates that after the time to appeal has expired, that equitable relief will only be granted upon a showing of extrinsic, nt inns, fraud. 2015 Motion, pp 5-7 and cases ited therein; Plaintiffs" Opp. to 2015 Motion, Section II! (A)(B). Fundamentally and fatally, Lynch does not demonstrate how any ofthe alleged misconduct on the pat of Plaintiff and his attorneys, operated to deprive her of presenting her claims or defense in the original action. In Re ‘Margarita D., 72 Cal. App. 4" 1288, 1294 (Cal. Ct. App. 4" 1999) trinsie fraud is one party's preventing the other ftom having his day in cour.”), All of the alleged acts involve issues that go to the merits of the underlying action and are therefore intrinsic. Hammell v. Britton, 19 Cal. 24 72, 82 (Cal. 1941). Perjury, concealment, falsification or suppression of evidence, and fraud occurring during the course of the proceeding have all been held to be intrinsic, not extrinsic, fraud. See Cedars-Sinai Medical Center v, Superior Court, 18 Cal. 4" 1, 10 (Cal. 1998). As such, the alleged acts of misconduct, falsely imputed to Plaintiff and his attorneys, do not form a basis for equitable relief from the Default Judgment. ‘Without including such request for relief in her Notice of Motion in violation of California Rules of Court 3.1!10(a), Lynch also seeks an order “that the Court will provide Defendant Kelley [Lynch with a clarification of the ambiguities in the May 15, 2006 Default Judgment” 2015 Motion, Proposed Order, No. 4, Vol. IV. Lynch's argument that the Default Judgment contains “clerical errors” and is “ambiguous” is legally frivolous and is made in bad faith. See Plaitiffs? [Opp. To 2015 Motion, Section IV(A)(B). Lynch's roquest for “clarification” is nothing more than a transparent attempt to argue the merits ofthe underlying case, Procedurally and substantively, Lynch is precluded from advancing affirmative defenses | er unclean hands argument) advancing any contentions on the merits, or objecting to Plaintiffs! evidence to support the Default Judgment. Steven M, Garber & Associates v. Eskandarian, 150 Cal, App. 4” 813, 823-824 (Cal. Ct. App. 2° 2007); See also Sporn v. Home Depot USA, Ine., Paint’ Motion For Stetions Against Defendant Kelley Lynch Pursuant to CCP 8§ 1008(4 nd 128.710 " 2 13 4 18 6 18 » 2» 4 2 23 4 2s 26 u 28 126 Cal. App. 4 1294, 1302-1303 (defaulted defendant lacks standing to complain of type of evidence offered in the prove-up.) C. Lynch’s Motion is Fuctually Frivolous Lynch significantly reprises her argument advanced in her 2013 Motion that she was not served the summons and complaint and that the allegedly false proof of service is evidence of extrinsic fraud, Lynch altempts to present additional declarations from her housemate, Paulette [Brandt, and her son, Rutger Penick, as well as from her mother, Joan Lynch, and three of her long time friends (Ronge, Meade and Surkhang). All of these additional declarations purport to o additional “facts” surrounding service ofthe summons and complaint, but ultimately fal Because * Opp. to 2015 Motion, Section II (B)(3)(). What is more, even if the declarations were properly signed, they the signatures on the additional declarations appear tobe fraudulent. See Pi are not sufficient to overcome Plaintiffs’ prima facie evidence of valid service. See Plains’ Opp. to 2013 Motion, Sestion V(A); Cal. Evid. Code §647, Lynch's claim of “fraudulent mispresentations” in Plaintiffs" Complaint is also factually frivolous. 2015 Motion, Exh. 3. A “judgment by default is said to ‘confess’ the material facts alleged by the Plaintiff, ie. the Defendant’ fuilure to answer as the same effect as an express admission ofthe matters well pleaded in the complain.” Garber, 150 Cal. App. 4° at §23, Thus, the allegations in Plaintiffs? Complaint are deemed admitted by Lynch and bar her factual contentions contained in Exhibit 3, Procedurally the entry of default and the Default Judgment bar Lynch from advancing any contentions on the merits. Id. D. Lymeh’s 2015 Motion Was Filed Solely to Vexate and Harass Plaintiff and Fis Attorneys: Lynch's 2015 Motion is being prosecuted for the improper purpose of harassment in violation of CCP §128.7(b\1). Notable atthe outset is that Lynch only first sought to vacate the Default Judgment in August 2013, net iy @ year and a half after her eriminal coavieton in April 2012 for violating Cohen's Permanent Protective Order. People v. Lynch, Los Angeles Superior JCourt, Case No, 2CA04539, Since Cohen's Permanent Protective Order prevents Lynch from harassing Cohen or having any direct contact with him, Lynch hus sought to cireumvent the 1. Plats’ Motion Ror Sanctions Agunst Defendant Kelly Lynch Pursuant to CCP §§1008() and 128.710 u 2 13 14 18 16 ” 8 9 20 1 2 23 4 25 2 28 Protective Order by her indirect harassment through her successive meritless filings for relief from tne Default Judgment in this Court. The purpose of Lynch's 2015 Motion is not to assert any arguably legitimate Legal right, but rather for the improper purpose of harassment as evidenced by i) the voluminous nature ofthe filing itself, totaling over 1,100 pages, which violates California Roles of Court and is meant to vexate and harass Cohen's atomeys; i) the intentional dislosure lof Coben's attomey-client privileged communications in the public record; ii) the false imputation of criminal conduct to Cohen; iy) the false imputation of ciminal and unethicl conduct to Cohen's curent attomeys; and v the wholly pe-textual use ofthe lgelly and factually frivolous 2015 Motion asa vehicle to continue her public campaign of harassment of Cohen as evidenced by her “press release” published on her Intemet blog which repeats the fale accusations of criminal conduct made inher 2015 Motion and threatens future litigation against Cohen and his stomeys. 1. Lynch’s Voluminous Filing Violates California Rules of Court and Contains Content Meant to Vexate and Harass Plaintiff and His Attorneys Lynch's 2015 Motion violates California Rules of Court 3.1113 with regard to both the length and content of the supporting memorandum. In violation of Rule 3.1113(6), Lynch's Memorandum, while at least supecicially complying with Rule 3.1113 in terms of its 15-page eng, provides no facts or analysis to support he legal contentions and no citation to declaration or exhibit references, thereby forcing Plaintiffs and the Court to wade through her massive filing to attempt to “eull” and “distil support for her legal contentions from her voluminous filing totaling over 1,100 pages. Because Lynch impermissibly incorporates by reference not only the 6s.page “Case History” previously filed with her 2013 Motion, but also her new 109-page declaration in support of her 201$ Motion (wich itself attached 90 exhibits), Lynch's Memorandum vastly exceeds page limitations imposed in Rule 3.1113(). See 2015 Motion, Memo, p. 1. The sheer volume of Lynch's filing, coupled with a Memorandum that is utterly devoid of any kind of analysis or reference to factual support for her legal contentions is evidence Jof Lynch's intent to vexate and harass Plainifls'attomeys. Plants" Motion For Sanctions Against Defendant Keley Lynch Pursuant to CCP $6 1008(¢) and 128.72. Lynch Impermissibly Publishes Attorney-Client Privileged Documents as Exhibits to Her Declaration Lynch improperly discloses Cohen's attorney-client privileged communications with many lof Cohen's former and current lawyers in her declaration filed in support of her 2015 Mation. [Lynch also attaches numerous sttomey-client privileged communications as exhibits to her declaration. Lynch, as Cohen’s former personal manager and agent, does not hold the privilege and cannot waive the privilege on behalf of Cohen. Cal. Evid, Code §952.! When Lynch was terminated in October 2004, Cohen demanded return of all of his business records and personal property. Plaintiffs" Opp. To 2013 Motion, Edelman Decl. 4916-17. When Lynch refused to return his business records and personal property, Cohen filed a Complaint for Recovery of Personal Property and obtained an Order on the Writ of Possession (Related Civil Case No. BC 341120), which was executed by the Santa Monica Sheriff's Department at Lynch's residence in (October 2005. Id. Lynch’s wrongful retention of Cohen’s privileged communications with his legal representatives is only further compounded by her public disclosure of those privileged ‘communications in the public record. Such willful misconduct is deserving of the severest of sanctions, Wallis v, PHL Assoc, Ine, 168 Cal. App. 4* 882 (Cal. Ct. App. 3" 2008)(Section 128.5 monetary sanctions awarded against attomey and her clients for facilitating public disclosure of wade secrets); Conn v. Superior Court of Los Angeles County, 196 Cal. App. 34.774 (Cal. Ct, App. 2 1987\(Section 128.5 sanctions imposed for ex-employee’s failure to return attorney-client privileged dacuments that had been misappropriated from former employer). ‘As an example of Lynch's advertent disclosure of attorney-client privileged information, Lynch discusses the contents ofa letter sent to Cohen from the lew firm of Grubman, Indursky & Schindler, P.C. dated Apel 18, 2001 in her declaration at $75. Despite the leer being clearly marked “ATTORNEY CLIENT COMMUNICATION: PRIVILEGED AND CONFIDENTIAL", California Evidence Code Seaton 982 provides: "confidential communication between clit and lnvyee" means formation waned bawean s clin and his o er lawyer ine course ofthat relationship ane in condos bya means which, so far he cllont is aware, dicoses he Infomation fo thir arson othr tha hese who are pretentorher he ineres af the cr ne consultation or tase a whom dcloure reasonably necessary for the ranmsion of the formation the acomplhmen ofthe purpone for which the lnyer icone, od Includes legal opinion formed andthe avice given bythe lawyer the course ofthat rations. -9- Pint’ Motion For Sanctions Against Defendat Kelly Lynch Pursuant t9 CCP §§ 10084) and 128.7it VV. ‘The Grubman firm continues to represent Lynch attaches that communication as Exhi JCohen. Lynch describes former Cohen lawyer Herschel Weinberg as being “fanatic about sttorney-client privileged matters” (Decl. 32), yet discloses a privileged communication between former Cohen transactional lawyer Jonas Herbsman and Weinberg. Lynch Decl., Exh. 0.7 3. Lynch Falsely Imputes Criminal Conduct to Cohen Lynch's intent fo haress Plaintiff is demonstrated in her declaration submitted in support of her 2015 Motion, in which Lynch accuses Cohen of various criminal ats including: (}) theft fom, his former managers and advisors (Lynch Decl. $23 on p.19, $26, $70); (i) perjury in her 2012 criminal trial (Lynch Decl, $721, 22, 32, 88, 124, 126); (ii) “perjury” in a “secret” grand jury in the Phil Spector murder trial regarding @ gun incident that occurred in a recording studio decades ago (Lynch Decl. $120, 21, 110, 122, 124); and (iv) tax fraud (Lynch Decl 4$8, 22,31, 7, 63, 86, 90, 110). Lynch's unsubstantiated allegations of criminal conduct are extraneous to these proceedings and advanced by Lynch for no legitimate purpose, but only to harass Plaintiff Lynch's inclusion of numerous references to Cohen's alleged fax fend in her declaration is particularly telling of Lynch’s malevolent intent to continue her harassment of Cohen with this public Hiing. Lynch states in her declaration “as I advised this Court im the January 17, 2014 Incaring on the Motion to Vacat...this Court has no jurisdiction to hear federal tax matters.” Lynch Decl. 4115. Despite acknowledging that tax matters are not germane to these postjudgment proceedings, Lynch continues to repeat her allegations that Cohen has committed tax fraud and leven baldly asserts “Cohen has @ 40 plus year history of tax fraud and/or evasion in the United States and Cenads.” Lynch Decl, 31. Her recklessness in making these accusations is made apparent when she later concedes: “I have no expertise in tax or corporate matters” (Lynch Deel 489, 61) and “I was quite clear with Cohen, Westin, and others that I did not handle tex, financial, accounting, legal, conporate, or IRS matters.” Lynch Decl. (100, with regard toforer Cohen atomey and Lynch's co-defendant Richard Westin, Lynch acknowledges that Westin id not represent her (Lynch Deck. 75, 89, 92) and Yepeatdly tees to Westin as Con's “personal jer” ($55) ‘and "persona ax and corpora asorey" (8), yet dssoses humerous atooey-cleat privileged communications between Cohen and West ibe declaration and evan publishes thse communication as exhbis. See, eg Lach Deel, Exh. CC, KK, LL, MN, NN, YY. =10- Pint’ Motion For Sontons Against Defendant Kelley Lynch Pursuant to CCP §§ 1008) and 128.710 ny} 2 3 “4 1s 4, Lynch Also Falsely Imputes Criminal and Unethical Conduct to Plaintiffs" Current Attorneys In furtherance of Lynch's intent to harass Plaintiffs’ attomeys, Lynch accuses Cohen's current attorneys, Michelle Rice and Robert Kory, of having committed perjury in both her 2012 criminal tial and in their declarations filed in support of Plaintiffs" Opposition to Lynch's 2013, Motion. Exh, HHHH. On this basis, she seeks to move the Court to refer Kory and Rive to the California State Bar for disciplinary action” and refer them, along with Plaintiff to the “District, Attomey's Office for perjury prosecutions.” See Proposed Order, Nos. 2 & 3, Vol. IV. Lynch's allegations of misconduct on the part of attomeys Kory and Rice are patently frivolous and muliciously asserted for no legitimate purpose, but only as retribution for their having participated as witnesses in Lynch's criminal trial in April 2012 for violations of Cohen's Permanent Restraining Order. * She points to no statements made by Rice and Kory either in the criminal trial or in their declarations that are perjurious. Lynch’s mere denial of the veracity of [Kory and Rice's statements is not enough to prove “perjury.” See Cal. Penal Code §118(). Lynch was convicted in a jury trial, in which twelve jurors gauged the credibility of the witnesses (Cohen, Kory and Rice) testimony. Her criminal conviction was affirmed on appeal in May 2013. Plaintiffs’ Opp. To 2013 Motion, Rice Decl. $30. Lynch also baselessly accuses Rice of having a ‘conflict of interest” because she is “Leonard Cohen’s lawyer and puid witness” and seeks an order for her to withdraw as counsel for (Cohen in this cuse, See Proposed Order, No. 9, Vol. IV. The apparent genesis of Lynch's animosity towards Attomey Rice is that Rice domesticated Cohen's Colorado Permanent Restraining Order in California in May 2011. Lynch Decl. 22. Rice also made the LAPD police report which lead to her arrest in Berkeley in March 2012 and was a witness at Lynch’s 2012 criminal wal. (Lynch Decl. ¥4, 116) psf evident Lys 215 Motions meant to harass Coben a is cron atoms Loch dot nt seis Set Edina of Gion Dut, atorey who scaly fed the Compl seved he amon nd compan obaedthe OfatSugant agate of perry. Edina sme ese of Ssnaepeentve (i, mistepesetton inhi elrtin sbi suppor of Pt" Oppsin ynchs 2013 oton. Lyneh Des 27. Pai profere Eines declemon rete {yes aso in Rer2013 Mion that she was not propery served he summons an compa U1 Plait’ Motion For Sancons Against Defendant Kelley Lach Pursuant to CCP §§ 1008) and 128.75. Lynch’s “Press Release” Announces Her 2015 Motion and Republishes False Allegations of Criminal Conduet on the Part of Plaintiff and His Attorneys (On May 7, 2015 Lynch posted Press Release" on er Inmet log “smnouncing” the fume 23, 2015 hearing at and ne for he Moin for ering Santon bef Cur sce Key Lynch, Kelley Lynh~ Leonard Cohen Hearing Before LA Superior Cor ae 23, 2015, May 7, 2015, hitpivedspbook blogsptcom/2015Sfsle unch-eonad-he: ean ast visited on May 25,205. Se Exhibit, She also flowed hs Blo posing sth «mass email consning the content of May 7, 2015 Inmet posting which vas sn fo least 50 recipients, many of whom are Cohen’s friends and colleagues in the music business. See Sib 3, The s-aled “ess ele”, posted on he Inmet which eps her llegaions of criminal const onthe pat of Cohen and his Iyer is meant o atc he wide pone tenon t her 2015 Motion andthe scons and defamatory allegations contained wii, Notwithstanding this Court's famary 17, 204 Ode denying her 2013 Motion wth rie ad the Cour’ fining tha Plain’ personal serie upon Lynch was proper, Lynsh cams “Sage Hes wil ofcourse, be sing without personal jusiton over Kelley Lynch s she was never seve Leotrd Coen’ lel cmp or suo” 1d Lynch's “press release” leaves no doubt that the legally and factually frivolous 2015 Motion was sham fling and was nt mest 0 assert any legitimate legal claim or ight. Lynch's 2015 Motion was meant solely forthe purposes of harassment and as a pretextual attempt to cloak her reckless, baseless, salacious and outrageous claims of impropriety against Cohen and his layers with tigation privilege, so that she may repeat those allegtions with impunity in a wider public forum on the Interact. IV, SANCTIONS UNDER CCP §128.7 ARE NECESSARY TO DETER REPETITIVE FRIVOLOUS AND HARASSING FILINGS te Sanction (o Deter A. CCP §128.7(4) Allows the Court to Craft an Appropr Repeated Misconduct “The purpose of Section 128.7 isto deter frivolous filings. In Re Mariage of Falcone & Evke, 164 Cal. App. 4° 814, 826 (Cal. Ct. App. 6" 2008). Section 128.7 provides that “[a} sanction imposed for violation of subdivision (b) shall be limited to what is sufficient to deter =12- Pim? Mion For Sanctions Against Defend Kiley Lymch Pursuant to CCP §§ 1008) and 128.7repetition of this conduct or comparable conduct by others similarly situated." CCP §128.7(@). A court has broad discretion to impose sanctions if the moving party satisfies the elements of the sanctions statute. Peake v. Underwood, 227 Cal. App. 4" 426, 441 (Cal. Ct. App. 4" 2014), Sanctions under CCP §128.7 may consist of, or include directives of @ nonmonetary nature, an order to pay a penalty into cour, or, if imposed on motion and warranted for effective deterrence, an order directing payment fo the movement of some or all ofthe reasonable ttomey’s fees and other expenses incurred as a direct result ofthe violation. CCP §128.7(). Federal case law construing Rule 11 (28 U.S.C. is persuasive authority on the meaning of section 128.7. Peake, 227 Cal. App. 4 at 440. The pro se status of a violator may be relevant to the Court's discretionary choice of the appropriate sanction in a given case. Bus. Guides, nev Chromatic Comme'n Enter, Ine, 892 F.2d 802, 811 (9! Cit. 1989), A court can properly considera party's ability to pay monetary sanctions as one factor in assessing sanctions. Warren ¥. Guelker, 29 F.3d 1386, 1390 (9" Cir. 1994). It cannot, however, decline to impose any sanction, where a violation has arguably occured, simply because a party is proceeding prose. Id. at p. 1390, “A contrary conclusion would effectively place all unrepresented partes beyond the reach of Rule 11" 1d, at p. 1390 B. ‘The Court May Also Enjoin Future Frivolous and Harassing Filings Through Its Statutory Authority to Issue “Nonmonetary Directives” as Sanctions for Violation of CCP §128.7 Section 128.74) specifically provides fora sation that may take the form of “directives Jos nonmonctary nature.” CCP §128.7(4). Nonmonetry dresives under Rule 1 have included prohibitions on r-filing funher ations based on the same fats and claims and prohibitions from raking ny fuer filings in particular case In Quintero v, Fresno Unified Schoo! District, a District Court awarded Rule 11 sanctions in favor of defendant school district against Quintero, a pro se plaintiff, for filing a frst amended complaint which was found to be bath iivolous an fled forthe improper purpose of harassment | Quinero v. Fresno Unified School District, 2013 WL 1832681 *6, US. Dist, LEXIS 62580 *21 (ED. Cal. 2013), As sanctions for Quintero's filing, Fresno Unified sought an order banning -13- Pali Motion For Sanetions Ast Defendant Kelley Lynch Pursuant to CCP 9§ 10084 snd 128.710 2 B 1“ 15 16 7 18 9 4 n 2 24 28 un Quintero fiom filing further actions based onthe same fats and claims and monetary sanctions in ine form of atomey's fees. Id, at “4. The District Court awarded Fresno Unified $2,000 in atiomey's fees and expenses and also ordered Quintero not to re-fle his clams in federal court id. ae 21. ‘In Califo Sporshing Protection Alianee v. Callaway, the District Court found po se | defendant Callaway’s motion for sanctions against plaintiff CalSpa friviolous under Rule 11. Cal. | Sportshing Poot, Allimce v, Callavay, 2013 WL 4482849 ¢6, 2013 US. Dist. LEXIS 118097 +21-22 (ED. Cal. 2013). The grounds for Callavay's sanetions motion was his belie thet declarations that CalSpa had filed in opposition to his motions to dismiss and for summary judgment contained false and misleading statements that were relied upon by the magistrate judge in denying the motions, I, at *9. In a prior proceeding, CalSps had obiained © $29 million attomey's fees a8 sanction against Callavay under Rule 11 for his fivolous sanctions motion, the magistae issued default judgment against Callaway. 1d, at*21. In liew of awarding CalSpa an ore roibiing Callaway ftom fling any fare documents inte eae ws a anton, It +22. The masts easone the effet of monetary] santos on op of 29000000 deat | judgment is devoid of practical meaning.” Id, at *21. [As was found in CalSpu, the practi efet of imposing monetary sanctions under CCP 512827 against Lynch inthe fae ofthe $7.3 milion Defi udgment would be mesniglss and st suficent to deter fue fvotous and harsng fling. Ihe primary pupose of CP §12.7 is wo dete ivolos and harsing flings, then Plait submit that the only effesive detent would be wo prohibit Lynch rm ing ny futher ton inthis ease, The Court has ary hort w issue suchas pobibion inthe form of ‘nonmoneary deve’ under CCP '§128.7(d). Such an order is natrowly-tailored and does not prevent Lynch's access to the courts as to other claims or matters. Ringgold-Lockhart v. County of L.A., 761 F.3d 1057,1066 (9 Cir, 2014). C. Lynch Mas Obtained Court Services in Bad Faith Lynch obaned an Onder on Court Fe Waiver dic! Col Form FW-005) on August 9, 2013 ile papers inthis ase without payment of fee and cots othe Cou Exh, 1. The Pit Maton or Santos Api etn lly Lynch Psu CCP 60 snd 28.710 u 2 3 “4 1s 6 0 18 19 20 a 2 23 4 25 a process by which an indigent person gains access to the courts by applying for and obtaining a waiver of court fees and costs is governed by Government Code §§68630 to 68641. C.S. v. W.0., 230 Cal. App. 423, 30 (Cal. Ct, App. 2" 2014). California Government Code §68634(@) provides that the fee waiver application shall be determined without regard to the substance of the applicant's pleading or other paper filed. However, Section §68631 provides in pertinent part that “under circumstances set forth in Section 68636, the court may reconsider the initial fee waiver and order the fee waiver withdrawn for future fees and costs or deny the fee waiver retroactively.” Cal, Goy. Code §68631, Section 68636(f) provides: (9 If the court obtains information suggesting that a litigant whose fees and costs were initially waived is obtaining court services in bad faith, or for an improper purpose such as to harass or cause unnecessary delay, orto needlessly inerease the costs of litigation, the court may give notice thatthe litigant is required to appear at @ court hearing to consider ‘whether limitations should be placed on court services for which fees were intially waived ‘As evidenced by her two suecessive meritless filings in this ease, Lynch is obtaining court services in bad faith forthe improper purpose of harassing Pleintff and his attomeys, Vv. CONCLUSION Plaintiffs respectfully request that the Court impose nonmonetary sanctions under CCP 4§128.7(2): 1) to bar Lynch from filing any farther motions inthis matter, Case No. BC 338322 or, alternatively, to order Lynch to seck leave to file from the Supervising Judge of the Superior Court before filing any further motions; 2) (0 return Plaintifs’ attorney-client privileged and other [confidential documents; and 3) to enjoin Lynch’s further dissemination and publication of Plaintiff’ privileged and confidential documents. Further, because Lynch has obtained court services in bad faith for the improper purpose of harassment, Plaintiffs also request that the Court evoke Defendant's August 9, 2013 Order on Court Fee Waiver inthis matter. DATED: May25, 2015, tae SD alge MICHELLE L. RICE KORY & RICE LLP -15- Pint" Motion For Santon Again Defendnt kelley Lynch Pursuant to CCP §§ 1008) snd 128.7Exhibit 1‘Order on Court Fee Waiver ame SD {Superior Court) ‘Superior Court of Catomi uty of Los Angeles the court nye court foog:- AUG 09 2018 FSH MN VanNess Age | saima.gans bane et Gos Smee oa @ sawyer rrglrbonin @ has one (ya aes, phone ander nS oe 3) Rreqeo want conn Rew fied sR COURT corde! roses cure Fi ups ANGELES Seer otc oS ever incase SNOT ER, CADE ne Sef oe ——— inti tencmrti HcttionBnncomaen — foes 222 __| Re v5 Li tie: The cin rr yon waves stot oe San ie or ou EKG Was {ees fis happens od you do wot pay, the cnr emma You py the fos and alse came ou elect fecs If ere ‘chaperone coconsace diay see a bteases yw shy py fees eos os as. tothe wil eour niin Bive doy (Ux form FW 010) Ifyou wi you ease, he al court may ere fiber sie es. I you ele Your cl se $1000 mre, he al ou wil ave ies on he setlewent he A) Aer evn yooh nt: {$C Wane Cour Fas (Retest ave Aol Co Pet Ae pt 0 pent rns yrs tows (oh sec wives Toecet routs wae you cou esd coat ined low. (Cal eof Cr nest) Yor outhouse ot Fay pea Ser Conn Cig tne ceric RaRePEps adi pes "SRE aes Sot epee [Soat'steoewemme Coates meyer oat anon Si LANES fap so dy ten eet de eens pprd lee) “ny sod joy eat taco pea" can es pen hen (2)C1 Adattonal Fee Walver. The cout grass your request and waves your atonal super cout fes and ‘cos that xe checked below, (Cal Riles of Court, rae 336) You do wat hve 1 pay fore check ems ky res sadexpenes Fesforapeace ocr testy is court Fer recur point epers Coutppite spree esa a wibess leprae ts eyend he 60. perod ling the oe ie ere) Donte pci (00D Fee Wave for Appeal. The court grants your rut sad wanes tf nd cos checked lo, or your appeal. (Cal Rules of Court, res 35,336, 626 and 816) Yu do ot ave py fre checked eas. 1) Preparg sad ein lesan raped C1 One speci - = EEariaiiaate =" Order on Court Fee Waive (Superior Cour) Ee Faas Pew fot?Your nae ¥. Co Taecour dents your request fellows: ring ty mis be cade sow. cau carne cess our requir harng oe cout papers ru ad wn your get eqs papers wer arn Opes appetmay ba seman. (YC The cour dates your request because it isiacomplee. Youhave 10 days after the cekgvespotce of iis ode (sede below) + Pay your fes and cos 1 ilea new revised request hat inlades the item ised blo speci incomplete tes) (2) he cout dents your request base he nrmation you provided on he request sows hat you a BOL ll fre foe waiver you request pe eons) a “ie cours econ lak Request or Hearing Aout Court Fee Water Orr (Siperor Cow). ors W006. You have 10 days afer he clk gives noice of is ord (see date belo) ta + Pay you Fes sad costs. ot + Askfora eaig inorder ta sow th csr mare information, (Use form F006 tropes hearng) © © the cour neds more infomation o decide whether to pant yourrequest. Vou mus goo out on he date ‘low. The hearing willbe about (spec questions rependng eligi) __ ‘Name and ederes of coun if dlileest om page [Renn fan cnenwaea maya nag cata rma ae ee opp | cinco omc casper eum btn, co coe pee [fects utes unos apna eet pny Seanad ee : Meng ‘Signore offchod Tal Offer CL Crk Depa: ay Reqort fr Accommdatins. Asis inn sons, compo ie asin option, og luge nts servis a va ou a a ea das eee you beg Cena eck + ls Reps for Acoma, For MC-0, (Cl Cade § 548) | eeity tat am not involved this eas ant (check one!” C} A.ceifct of mln is wached. (handed copy of this onder the pty ad torn, if any listed in and @), atthe cout, on he date blo, pinto pg at Femicnie alla and amomey, any th adresses lite i) an iin o he date blow. lek. be Deputy w008 ape 2 i Order on Court Fee Walver (Superior Court)Exhibit 2River Deep - Phil Spector, Leonard Coben: Kelley Ich Leo pthiverdeephook blogspot com/201510Sheley-}ych leona, River Deep - Phil Spector, Leonard Cohen Blog dedicated to Freedom of Speech and all human beings who are willing to stand up for innocent people caught in this system and against corrupt political entities and opportunistic frauds. Some celebrity gossip also. 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A Complaint was led wih USPS. ‘Sein Cohen ar bce swe te IRS abt x din Se sashes oo sd er," a eat ing a wet 04 we fo toto Adam Cokes andi ie jan Thomas erefeof Rabe Kory Noting Coen ous ici gated once ve 2 Met St ‘os 500600 Lach curator, sine action peel us, and eer et ich ay hn en or [Wh Cohen and Linsey ated wpa tbr eating LA Smee Cou, hata end toe to het oss now xidion coun yooh ‘cle pene ia Low Angi. Loch fore poo cy ‘hee Chem Tangs Rept,» front con il acer wo ‘sanded Naps lie Bir Caer nthe 170 a0 en 987 She ‘syns Tbe ns apy rere [NOTE Lynch wis stedent of Cogyam Trung Rinpoche eed wih it so (hee pen) for ea and was Kusum Ling Repose’ ese ssstan andi hi chor iy age os a nage lee, pverecpbooklogspo.comy2015105 kelley yam. ‘915 453 PMRiver Deep - Pil Spector, Lenard Cohen: Kelley yeh - Leos. nputverdeepbook blogspot com/2015/05rktle-tynh eo 80f9 Join consign wo di bots wo ak Lynch own amet peed Cab santa ct The NY Tae conte Kee Fees qm wich ty pated J 2, Lynch aera de nd ay wee Ee wi i | (OaDecenin 2, shad ge we ce the ome Breed ad ce up hols Set Mena, whieh 39 mare for homes The aie Deptt eer head ec phat wen he boaptin viene hi hw ting tied bya nn sl alr ie shecanpedon he vec 19206, Caker wie marl apmbal 99 lin salen hl pit ypc who doe nats Iyer ening ae Cnt a ee rend apps thre en ony age Ken Faun he pment Loch ny lhough she sas te bene he co docatat ‘ase served suman Atte ie he econ se ol eared ‘temong © she pone cl htsane yr erie son ow he gina sean wih magne hie he wa wing t Whole Foose ae Angad {yeh cal ont fod eo i inn ow Lychee soup jou a Can ner tial the Dine Ants fein ace gad ry ling the Pi peace ih ones Dit ‘Aeon lTenercing eine Resa penal to Che, ed at [A preted oer me igh ole ces icg he Nigh Sele” tod th earn Dey Cara Recent 6 an 17,208, Cod alton th Age Gop wo ou of cour orn feo In pons the AGILE Gropp i cos ‘eng Coen o eft nok ACILE lho esac ars oyeof Lord Cates eta te wold eggs in fe asco et town qc yeh bees Con ad AGILE cole df St cet dey aint pin ea renin pet ht Pl pete’ ner, Bees Cty ‘ni spent beri econ ger er bebo an tan Sh a ‘noo woe md exec he yop, 13, wham ses ot se oe {$205 ating cho Joey ‘Thee dp Coben nese one eagle at Kaley Lc ing iio ine bnkeney Some aw seeing lt ce by fori ino po 0 ou Src ine a ely en A sige song eon abn conti ds mv of mpi, (ethingwie pect re hemi wed and ee ome Bes ae nguyen ane have ene om cw pc hat bei olaporeihad tae Prom hi er of eg, Coben wet ene whe Teta Te 511915453 PMRiver Deep - Phil Spector, Leonard Coben: Kelley Lyech Leo. nupiverdeepbook Nogspotnv201Salle-lynch-eoar wha hee 0 Toseby ‘And Fn shane sone Aad my he ee ay dirs edo ly Petty Oe Chace PM $4 meme Never ot Home ler Fst 9069 1115 453 PMExhibit 3Subject: Fc: Proce Relase from Kaley Lynch From: Mari (megan2c2b¢@sol com) To: rkory@konyice.com Date: Thursday, May 7,20159:56 PM Looks ke Kelley ida mass maiing lastnight. | have heard from Kelley n years unt now Mate Original Message From: Kelley Lynch Te jako ; nfo , cupid : Megan2C2B «Megan2c2B@201.com; kim solez : Klevneky 100325.716 <100325,716@compuserve.con>; AzlecRoset : patchen ;bxhondat ; sb ; eboshm toohan2 ; Dondoyle ; clausse ; chantalcras ; bondoye ; OrGrefSB henfranz ; randy -; management <‘managernent@jerniferwames com>; tye. comer : erika ramirez ; jason Lpshu ; chs payne «chit payne @bilboard com> Ce: “IRS. Commision “IRS Commisioner@r gov>; Washington Field ) Dennis ; MoliyHale :neapao : fb -fsb@Isb.1u>; rbyucsipa ; Khwvane rik feuer; stan gamett Sent Thu, May 7, 2015 9:51 pm Subject Press Release PRESS RELEASEWill IRS prosecute singer-songwriter Leonard Coben for criminal tax fraud? ‘Was Leonard Cohen a participant in CIA's MKULTRA program? On June 25, 2015, in Department 24 of Los Angeles Sopedoe Cout, Judge Robert Hess wil determine whether or not be wil wate singe tongwriter Leonard Coa defaljdgment agaist his former personal manages, Kelley Lynch, and sefer Cohen together with is lawyer, Robert Kory and Michelle Rice, to the appropriate authories for perjury prosections and disciplinary actions. Judge Hess wil, of couse, be ating ‘without personal juinition ves Kelley Lynch a she was never served Leonard Cohen lal complaint ot ‘Los Angeles Superior Court ‘Stanley Mosk Courthouse TIN. Hil Steet Depastment 24 Los Angeles, Califoraia 90012 easing: 8:30 AM ‘The details ofthe salacious story iavolving Leonard Cohea, his former personal manager, allegations of ‘ciminal tax fraud, and Cohen's three versions of his fimous Phil Spector gun incident now before LA Superior Court can be found at rverdeepbook.blogspotcom. Journalist Ann Diamone!s article, Whatever Happened to Kelley Lynch, gives very nice, concise overview of what actully unfolded when Leonard Cohen heard Gia the {all of 2004) that his trusted personal manager planned to report his tax fined to Internal Revenue Service. After publishing tis article (enclosed below) on her blog, Leonatd Cohes and his lawyers prompty threatened to sve ‘Ms. Diamond, To date, the media coverage has been limited to Leonard Cohents highly fictional narzative that Kelley Lynch was his dsgeuatled ex lover who embezzled his retirement funds, stalked him for no reeson‘whatsoever and may hare wanted to attend hie concert, While this mther entrain story ha fry tale ing to thereat of the station ie far mote scandalous In addition, Key Lynch was actully prosecuted for among oter things, annoying Leonard Cohen by sckresing the fact that he filely accused het of having sex with Oliver Stone to sti up a custody mate (chat ‘was sucessful though eset a def adymen) explaining ojounait Glens Greenwald he Intrcep) ‘hat Coben exposed himself to Lynch and zoutinely sexually hart her, repeating what Mick Brown (UK “Teleyraph) advised hes — that Coa’ statements/tetimony were presented to Phil Spectors Grand Jurys equeting IRS tx and corporate information that Cohea is xequied to provide es end violating a andlent restraining order (primarily used to discredit and silence Lynch) that the Court repeatedly told her (and Phil Spector's former personal atsistn, Paulette Brandt had exptedin 2009. Te was ducing Kelley Lyncis 2012 tal for annoying Leonard Cohen that she understood he, former Distt Attorney Steve Cooley (who prosecuted Phi Specie), and City Auorney Carmen Truth had publicly joined forces to tage and dace het. Lynch has now notified Cohen, the Cty of Los Angeles and County of Los Anges that she will be igatng these inmes in fader cout Kelley Lynch, Paulette Brandt, and Ann Diamond!’ interviews for Truth Sentinel internet radio program ‘can be found a the following links: "Truth Seatine Episode 39 (Leonard Coben, truth es, gil, ianocenes, law, MK ULTRA) -nmps//soxeyoutae.com /watchbv=|VXTYOATIRE, “Truth Sentinel Episode 40 Phil Spector, tru, les, gui and innocence, murder tia) haps://wwweyounabe.com/watch2v=PBIWMxTwnHig For those of you interested inthe latest legal documents, including declarations, Sed in Case No BC 338322, ‘many of them can be found at this ike hp: /riezdeephook blogspot com/2015 /04/keley-Iyachs-motion-or-teeminating html ‘Whar Mapped to Kelley Lynch? ‘Ann Diamond Kelley Lynch is che woman accused in 2005 of skimming milions from singer Leonard Cohen’ retirement fund. knew of he through fiends of Leonard Cohen, and had heard her described in lowing tems asthe agent ‘who, singlehandedly saved Cohen's earer in he 1990sIn early May of tis year, Lynch suddenly contacted me She suid she was mainly interested ia my pesceptions of Cohen 282 former friend and next doot neighbour in Moatseal. At one time I also studied with his Zen Master io California, and had spent time with him on Hydra, Greece Not having heard her side of the story (I doubt that anyone has, spart from a circle of her closest frends), Iwas curious. Over the next few weeks, she shared several documents pertaining to the case including an afidavie. ‘written and signed by her older son, Rutger “Togethes, they pant a picture very much at variance from the sketchy media image of Lynch as a reckless, delusional woman on the brink of a career meltdown. Lynch's own timeline also inludes disturbing behind- the-scene dealings chac suggest she may have been tet up to take the blame for Cohen's tax station. ‘The following accouats based on what Lynch has cent me Since 2005 when she became the object of media gossip, ite if anything has been heard from Kelley Lynch. ‘A single mother with two sons, Lynch was Leonard Cohes's personal manager from approximately 1988 to 2004, and was known for er sil, hard work, and dedication. Until 2004, Kelley lived and worked in Los Angeles ‘where she stil has many frends and acquaintances in the entertainment world including Phil Spector and Oliver Stone. Her own account of the events that wrecked hee career, vaties widely from the media porta of «reckless, {delusional woman inthe ttoes ofa personal meltdown, Tae meltdown wae rel, however. By late December, 2005, Lynch had lost custody of one son and was homeless snd living on the strects with her older son, Rutge, ‘who witnessed the chain of bizare event that had begun a year cai: 1a 2004, Lynch owed a house in Brentwood, sad stil worked Gor Colin, whi owed let snsey Gor suyaies st other seevices, but wa increasingly involved with his new giliend, Anjani Thomas, ex-wife of Cohen’ attorney, Robert Kory. In etrospect, Lynch believes she was set up by Coben and his representatives to help cover up atx situation ‘which made the IRS “nervous” In September 2004, Cohen's attorney Weston told Lynch tht a financial entity known as Traditional Holdings, LLC could be overturned by the TRS. Lyach, who had been selected asa partner (on the entry, became uneasy and consulted a new accountant, who referred her to tyes, who found lnregulrties in Cohen's tax history both in the US and Canada where he he residences. Rattle by what she was hearing — chat she was being dragged into criminal tax fraud ~ Ich called the IRS in ‘An IRS collection agent advised ber to call the Fraud Hotine, ‘Told that aay further action on her part might implicate her in fraud, Lynch refused to meet with Cohen oe asa ‘over the corporate books. At that stage, Cohen's advisers began claiming that cetain payments, distbutions, of advances made to her were actually "over payments.” Lyach says their accouating was iacomplete and ignored her share of intellectual property, unpaid commissions and royalties, and share ia Traditional Holdings, LLC. Apparently Lynch had also been issued Ki partnership tax documeats and made a partner on another Coben investment entity, LC Tnvestments, LLC, without her permission or awareness Lynch says an increasingly nervous and desperate Cohen was pressuring her to agree to mediation snd told fiend of hers that Lynch was "dhe love of his life" She and Cohen had had brief affair in 1990, but Cohen now ‘was offering her 50% of his “community property" as well as "palimony" through lawyer Robert Kory at a ‘meeting attended by Lynch's legal representatives and het accountant, Dale Burgess. To Lyach, none ofthis made sense at the time.‘Meanwhile, che Los Angeles Distict Attorney's office recived an anonymous tip informing chem that Lyach was friend of producer Phil Spector, whom Lynch maintains is innocent. Coben, on che other hand, had given an interview in which he deserbed a gun-waving Spector who threatened him during secording sesions in 1977 ‘Ataround the same time he was offering her “millions”, Lyach says, Cohen was alvo circulating slanderous sories about her. She believes Cohen encouraged Los Angeles record producer Steve Lindsey, the father of her son Ray, to initiate a custody suit ~on May 25, 2005, the same day 2 25-man SWAT team ftom the LAPD, acting fon a bogus 911 call, suddenly cordoned off her stzect and surzounded her home in response to a "hostage taking” Bair that morning, Lynch says, her 12 year old son Ray woke vp aot feling wel, She sent an email to his ‘school informing them she was Keeping him at home. When the boys father found out Kay was home le became agitated and abusive ove the phone ta Lynch. Lynch says she had young people who worked for her coming and going that day, and did aot want Ray's father ‘coming to the house and stacking he, ashe had i the past. She ealed her older son Rusger, who wae visting a ‘fiend measby, and asked him to pick Ray up and take him down the hill where actress Cloris Leachman waited ia hae car Leachman a friend of Lindsey, took charge of Ray —justas seven LAPD squad eats came speeding up Mandeville Canyon Road in the dzcction of Lys house. With them was Ray's father, Stove Lindsey. “Lynch says she looked out the window and ¢aw armed men on her lawn, Her son Rutger and his friends were telling police there was 20 hostage taking, that they had spent the morning with Lynch, and chat there must be ‘some mistake. For reasons no one understands, LAPD /Inglewood PD decided to balieve Steve Lindsey, who had left che scene Police Inter gave vayiog explanations abou wlat led up to the cident West LAPD said they responded t0 seport that someone heard "shots fred." But a company that oversees SWAT said Lynch would have to have « superior caliber weapon to warrant such high rsk entry. A member of the SWAT team claimed to have seen ‘note that Lynch’ sister had placed the call stating Lyach posed “a danger to herself and everyone around her” Hier sister denies this ‘Lynch stayed inside er house and called her former custody layer, Lee Kanon Alpert. She also called Leonard ‘Cobea, assuming he had played a role in the evens unfolding on her lawn. Lyach says che knew Steve Lindsey nad also been meeting with Cohen and his attorney, and had recently told their son Ray that Lynch was “going to jai?” upsetting the boy. She says Cohen taped the phone cal later used in his successful court case against her ~ for waich, Lyach says, she never received a summons, Lynch says, “Police were on my hillside and crouching under my kitchen window” She says the standoff on het lawn continued for sever more hours, disrupting the neighbouthood. Members of Inglewood Police ‘Department alto participated in the operation. Bventually she decided to go into the back yard. Seeing her son Retger acting ss a “human shied and hostage negotiator,” Lynch ventured out front with her Akita on leah and joked tothe cops: "Who am I supposed to be holding hostage? My dog?” ‘The police responded by teling her son they would only shoot Lyach and her dog if necessary. “Tat was whea I dove ino the pool” ‘SWAT team members searched her house, As they entered Lyach’s Afvican Grey parrot, Lou, called out "I see ‘dead people! ~ further alarming the nervous cops,Offering her a hand out of the pool, one officer said dhey were only there to help her and not to hurt hee. “No one asked me if was all sight, no one questioned me about my wellbeing” The Medical Examiners Office later wondered how the police had evaluated her. After stating they were not attesting he, they handeuffed ‘Lynch, sin her bikini. On her way out the doos, hr son managed to hand her a brocade jacket Although she lived near UCLA Medical Center, she was taken in a squad car to King-Drew Medical Centre ia ‘Wats, 40 miles away and a three-hour deve in teaffic. Known as one of Americs’s worst hospitals, King: Drew ‘was recently closed down as a place where patients routinely die from neglect and medical ezors. Dung the long tide through South Central Los Angeles, Lynch says she was questioned closely about hee relationship with Phil Spector, who had been charged with fst degree murder of Lana Clarkson. lathe car, Lyach voiced concern over ‘what awaited her atthe hospital but was told by a woman cop: "This will be good for you." "Tale was being kidnapped” At Emergency, the admitting peychiatsst administered antipsychotic drags without authotization and Jef Lynch {in the waiting rea for hours, stil in her bikini and brocade jacket, and bandeuffed to chai. A nurse advised het she would be transferred — but did not cll het where. Esamining her fle, the arse noticed it sted het a 19 yews old with wrong socal secusity number, wrong date of birth, wrong religion and hes name misspelled as “Kelly Lmch" Lynch thinks i was the same fle she had seen, several months earlier, inthe hands ofthe Special Investigator who came to question her bout Spectoe ‘A second doctor older to wat her tua to ensure no further harm would come to hee, and assured her that ‘aothing in the King Drew report could cause her to lose custody of her child. The folowing day, she was released after nealy 24 hou ia the psych ward Back home, Lynch learned that while she was being held at the hospital her younger son's fates, Steven Clake Lindsey, had filed for custody of her son Ray Chatles Lindsey and obtained a restraining order denying her access to the boy. She says Lindsey attempted to convince doctors at King Drew that she was dangerous, in oxder to have her committed, he says Lindsey also threatened the peychatist who had ber scleased. ‘On that same day, Cohen's atorncy Robert Kory filed a Declacation in the custody matter, as did Betsy Superfon (@ fiend of Cohen, Kory and Lindsey who had beftiended Lynch a few months ealies). Superfon later told [Lynch she dia realize what she was signing, and that Cohen had offered Lindsey money “or something cee” to ‘ake Ray away ftom Lynch, Hier olde son alleges Lindsey offered him money to go to Leonard Cohen's kwyet's office and transfer orsign ‘over Lynch’s house to Cohen or his attorney Robert Kory. Rutger refused and phoned his own father, who advised him to contact « lawyer. ‘Two weeks later, in eaty June, as she drove down her street to buy dog food, a Mercedes sped out of neighbouring driveway and sear ended her eas, Lyach was thrown forward, acturing her nose against the steering well and was knocked unconscious Later, she says, a8 she drove back up the hill to her home, the same diver was standing in his dsiveway and called out: “We are watching you” as she passed, Seeing his injured, bleeding mother enter the house, her older son agin phoned his father, who may have called 911. Accounts wary as whether the call referred to an incident of "domestic violence" ora "drug overdose.” [ther way, police arrived at Lynch’s door forte second time in two weeks. Over the protests of her ton, they ‘entered while she was on the phone toa fiiend, De: Wendi Kasak who stayed on the phone talking with Ratger ‘while police again handcuffed Lynch. This time they ook her to UCLA hospital where her obvious head injuries ‘were ignored. Instead, she was once again deugged and placed in the paychistri unit where che remained for several days[Lynch and her advisors maintain these events were coordinated by Cohen, Kory and Lindsey, with the help of former LA District Attorney Ita Reiner ina well otchestzated plan to eaumatize and discredit hee ~ paving the ‘way for media stores which acessed her of skimming millions from Cohes retirement fund In the suramer of 2005, as Lynch was strugaling to save her home and protect her child from a father her fiends Aescxibe as "viciously anti-social" and “violent”, reports of Leoaaed Cohen's Gancal toubles hit the press. They alleged the 70-something singer had been scammed by his personal manager, Kelley Lynch, who colluded with an advisor at the AGILE Group in Colorado to sead his fale financial statements wile emptying his accounts of ‘lions of dollars. Although listed asthe owner of Traditional Holdings, the entity in question, Lynch says she acwer received aay, statements from the AGILE Group ~- who instead had been sending them to Cohen — having changed her mulling addtess to Cokea's home in Los Angeles She hss since filed a complain with the US Post Office For sail tampering NOTE: It appears that Leonard Cohen, or his representatives, attempted to change Lynch's mailing address from her home in Brentwood, California to his home in Los Angeles, California. A Complaint ‘was fled with USPS, ‘She insists Cohen sued her because she went to the IRS about his tnx situation, She says he ie no, and never was, "broke" and that missing funds west to buy homes for his son Adam Cohen and gilfend, singer Anjani ‘Thomas ex-wife of Robert Kory. Noting Cohen is famous for his financial largesse and once gave Zen Master Sasaki Roshi $500,000 as a gift Lynch also cites hefty payments to advisers, various transaction fes, personal ‘axes, end other monies which may have been sent offshore. While Cote ad Lindsey attempted to persuade others including LA Superior Court, that she intended to flee to Tibet or another non-extraition country, Lynch was isolated and penailess and till in Los Angeles. Lynch was former personal secretary tothe late Chogyam Trungpa Rinpoche, a fambosznt Tibetan spiritual teacher who founded Naropa Insitute in Boulder, Colorado in the 1970s, and died ia 1987. She says various Tibetan lamas are praying for her safety NOTE: Lynch was a student of Chogyam Trungpa Rinpoche; eesided with his son (her nephew) for yeats; and was Kusum Lingpa Rinpoche's personal assistant aad is his chos kyi dags mos and lineage holder. Journalists coresng the story were ether unable or did't bother, to tack Lynch down, and most reported ‘Coben's statement a fact. The NY Times contacted Kelley fort quote which they never printed ‘By July 2005, Lynch had lost her custody batle and Ray went to live with his father. On December 28, she and .uiger were evicted from the house in Brentwood, and ended up homeless ia Santa Monies, which has 20 resources for the homeles. The Police Department gave her 90 help and, she clams, laghed when she brought in evidence that she was being stalked by a knowa serial killer while she camped on the beach, In 2006, Cohen was awarded 2 symbolic $9 million settlement in a civil suit against Lynch, who stil does not have a lawyer representing her. Corporate hooks 2nd other evidence of fraud appear to have been oveslooked by Judge Ken Freeman in is judgment, Lyach says although she admits she has not zead the coutt documents and was never served a summons. Atte time of the decision, she told reporters she lacked the money to make a phone cal That same year, her older soa lost his fingers in an accident with a meat grinder while he was working at ‘Whole Foods in Los Angeles and Lyach could not afford a bas ticket to vist him in hospital “Lynch heard through a journalist chat Cohen later testified for the District Attorney’ office in «secret grand jury‘cating to the Phil Spector case with former Distt Anorney la Reiner acting as his lawyer: Reiner i «personal ‘Giend of Cohen, and as DA. presided ovee some high-profile cases including the “Night Stalker” serial killer and the MeMartin Day Care scandal. Recently, on June 17,2008, Cohea's lawsuit against the Agile Group was thowa out of court for lack of evidence. In esponse the AGILE Group dropped its counter-suit accusing Cohea of defamation and fiaad. AGILE stil claims to be shocked that «singer of Leonard Cohen's talent and stanare would engage ia false accusations against his own representatives, Lynch believes Cohen snd AGILE colladed to defraud het. She continues to deny all allegations against het, and ‘remains hopeful that Phil Spector's wyer, Brace Cutle, will represent her in ecouping damages to her liveliood and reputation. She now lives in snothe state and recenly learned her younger son, 15, whom she has snot seen since July 2005, stopped attending school las Junuary. “These days Coben's fans seem to have expended thee rage at Kelley Lynch for driving thei ido ito bankruptcy. Some now say she unwittingly did them a service — by forcing him to go on tour forthe first time in neatly t0 decades, ACTA, singer songwriter Leonard Cohen continues to ide a wave of sympathy, gathering wide support om the susie word and even some British royalty: Unquestionably his career 2nd finances have benefited from news reports that he is too impoverished to reir. From his tower of tong, Cohen has written Temile when I'm angry cheat and Iie Tao wit have wo de ‘TogetbyMichele L Rice, Een, (98N 226129) [ Kory & Ric, LL 9300 Wishre Bhd, Suite 200, Boveri His, CA 8022 tasminera: 10285-1699 ana met wonsaee gn coco comm ‘niowerrotgwat Leonard Noman Cohen; Leon Caen investments LC [SoreRoR counr oF caLoRwA counry or Los Angeles aarannane TR i Seat Emmonrcate: Los Angoles, CA 90012 SACOM Cir Distt = Stanley Mosk Courthouse ‘Ranmifmermonet Leonard Norman Coheneonard Cohen Investments locrexourREsrONDENT: Kelley Lynch aan ‘PROOF OF SERVICE -CIL sossasze |check mathod of etvice only one): 2 Pesan ere leymt 1 eyovmntoxivay | noe Hon. Robert L Hess TS eyaesenpeserice J oyra (ey Barns saree owns 24 (D0 not us hs proof of sence show sence of Sunmons and compl) 1. Atte tne csanin was ve 18 yar of age an nat part to his etn. 2 My rsiene or busines adress 9800 Wilshire Blvd, Suite 200, Beverly His, CA 90212 3.) Theta umber or cron sane oss fom which ered the cocuments is Compo Fsrce was fe er ‘souren sor 4 On(estor May 26, 2018 saved be fetowng documents foe (ZI The donate a eas he Aechnanto Prof of Srvee-Cia (Documents Sed (om POS 400), 5. Laeved te doeurani onthe person or persons below, 2 flows 2. Namo ofperson servos: Kelley Lynch CZ (Compete irsace was persona sevice, mal, rami dry, or messenge sence) ‘uses redone! ress hae parson vas seve: 1764 N. Van Ness Avenue, Hollywood, CA 90028 2) (Compin#sonce was by fa cb sence) (1) Faxnunber er cloconis cance actress whae prion wat ere: 2) Tine tse: Toe aes, eats, nd ce aplabiefomaten sbot persons seed on ha Achmet lo Proofat Sanco Cia Parr: Soned) (ot POS-O) 6. Tha docs wor sored byte fowig means (pec 4. 8y personal service perenalydelverdthe daemons oe porsons a he secs ted inom (1) Fora as aposeicd yn stay, Goma vea agate he ere) arate stormy flee by Hain docu, ran ensipe or paskage dea need o dently ho ay bar ered, wi eaotont ora ral ‘hate ofthe cae, sehteon te nous orn ha momng en rent evening 2) Fo apa, delay vas rade {@ite py acy avenge dosoneie tthe par enone th some paren ot younger en 18 Year ge beeen ehourcfeghtin te maning an hin he aren. ‘PROOF OF SERVICE—CMIL aS (Proof of Service) ae‘Leena Norman CohensLeanard Gaben invasimentsv Kelly Lynch ecases22 ‘.b [By Unied Stats mal | noe he ecunerts na ssid enelpe rpsckge assed th pasos aie ‘asesasr info ard (pty ne (9) esos te sae once wih be Uns Sites Pet Sere wih he postage uy prea (2) paces te eostp fr sales nd mat towing cur rn buen pacts, 1am ei fiir Smt ears proscar alec an roca coveeaece to ating. ON fo er ay tat ‘espandance speed rcalcion ard malig, le epoetain erry cove otcaeae wh ‘ind Sues Por Seven, na cons ervone wh posape My Pepa ama residert er employed inte coury where healing coaaes, The envelope or peckage wes placa he ala (Giranfamay emo = ©. CZ) By overnight datvery,lenconed be decamats nan ewveep or pactge provide by an ovemigh der, ‘Sor andnifesa othe persone athe sereana um & placate enslave ope lectin ‘nd ovamigh svar at an Sto ors rea sce op ox be overt Sebey ea. 4: By messanger servic, | served ine documena by placing thamin an envtore o pacage sessed oe pesons tine acresas ine tor nape a oteasana maasege ane avin. (deca Dy {te mesungar must socmpony ts Pra of Src rb anand he Dsoaion a tessonge bw) ©: By taxtansmieson. Sasnd onan sremsnt fhe pares to scp sero by fox veers fede dose {Pine pesaa ate ex mambo etn tom. No erorwae roped bythe machin nt bad A sop fe ‘eon fox tanamiaen, woh pool ached [By otactrni service Bess on a courtorse oan arent of hepato acl elaconi cove, cass he ‘Bouman be Santo fh peroneal ie acon san aaSosre lee ie 8, | dele under ona of parry andor he ew ih Stat of Ctra that the feeping ius a cone Laren vite Arse abba. eer —— Mar Laal tie ar cach cain Gt coped ore spat ett em esr ml 8G) DECLARATION OF MESSENGER [by personal src. | peranay deer the envelope or ackage ciao he daar bove othe prsns athe ‘Sloe ae ncn © 1) Fra party presente y an afore, clay was race ota aoe ct 2 he storeys ‘fice by mung the cum ah anos paca hich ve cea ba erty he aorey bag eenes. Sith reaper ra nnn charge aie achen th out offing ihe ering and we rete. 2) ra pry delay ua made foe po by aug te dossrnnt at hepa’ faces wh sme ron a YS {tan tayes of age batcen he auto ht te naring ana hint res. [Atta te of seven, tas over 18 yr of abe Lam not pty tothe sbovecferencos pal posse, "served th envelope o pacape a a sboe, on | dere unr penty ope under be ls othe Stato Calfoa hate oeoing se an cone. at Weep PROOF OF SERVICE—CWMIL (Proof of Service)POs.040(0) ‘SHORT TIRE Leonard Nonnan Coben, Leonard Cohen lnvestneats y | ===" kL Kelley Lynch Bc338922 ATTACHMENT TO PROOF OF SERVICE—CIVIL (DOCUMENTS SERVED) (hie Atschment iors wth em POS 40) The documents tat wore served ae ae lowe (decrib sch decamnt opty PURSUANT TO CCP SECTION 100s¢) and CoP SECTION 1287 MEMORANDUM OF POINTS AND) [AUTHORITIES IN SUPPORT! PLAINTIFFS STREL |PURSUANT TO CCP SECTION1008(4) and CCP SECTION 128.7 TEYTS ‘COI [EvNcis 8 33630, PLAINTTETS! INTENT TO MOVE FOR SANCTIONS UNDER GCP SECTIONS (008(a) and 128.7 ‘SGRRER” ATTAGHMENT TO PROOF OF SERVICE CIVIL (OOCUMENTS SERVED) oe Ll ‘Proof of Service)Pos.o10 Mice. Rie, Esa, (SON 226189) [Kon Fe, LP 8200 visio ve, Suto 200, Bevery Hils, CA 0212 rapranys: 10251090 ran rt sama scrarnns moOgKoHTCS. cor Inver Forum Leonard Norman Cehen; Leonard Cohen Investments LLC. [SUPERORCOURT oF caLromMa counry or Los Angeles Greiner 1 Ra Seoat TYMO RCE Los Angols, CA 90012 SE Cenval Distt - Stanlay Mock Courtrause TANTRRPETTIONER: Leonard Norman CahenLaonard Cohen Investments loerevoawrmesronnens: Kelley Lynch —— ‘PROOF OF SERVICE—CIViL scssesz2 |check method of serves fonty one): Joyrenontseree CZ] Byatt] yovermih Dovey (Sl ovtmewngersorte =] oyrax_ £1 oy eevee core 24 (D0 not use ths prof of erie fo show sence of Summons and complaint) 4. Ath tie of sen | ws ve £8 yar of age and nota party oth ac 2 My rescence or buses aes is ‘8300 Wilshire Bivd., Suite 200, Beverly His, CA 90212 3. (1) Tre frrunber or ecto snc aes muh se he docuansl compl sarico was by ocr ‘Sete sence: “ance Hon, Reber Hess 4: On(etes May 28, 2015 Ieeved he owing document (sec ‘The dosanent ae statin he Atachment to Proof Sorice-Ci (Documents Sere fn POS-4G(0) 5. | swethedocumens on ih porson or persons below, low 4. Name ofpaeonsovet: Kelley Lynch CEI (Compe snice wae by porsana sero, ma, ovomigh dlr, or messanger sanice) uso o ale ede where person was eo 1764 N. Van Ness Avenue, Hollywood, CA 90028 © 1 (Comite irsanice was y fx or ett enon) (9) Faxqurrereoonc sven acess where pean wae eae (2) Tine servis (7 tre nanos, aseses, snd oer aplabeinomatin about porwr served ison ie Aste Proof [envcench (Paras Served (erm POS O40) 6. The documents wore serve he lng means (sec 1 By personal service, personaly elves he documents othe oon tthe adresses Kein tom 51) For ‘in reorserteg yan ses debary wes made othe eloney era he tsneys lesb ang he cine, [Rannveopo pusage doa noid te arty be atomey ba served, ih 2 enon rw nada Charge ee once, been te fous ahi tte rTornng ed vente earn (2) or apart every wos made {Site pay ey lear he Jocurarts lhe prs econ wh ware psn ot younger nan Te earsofage belveen Rohous ofan a naming ans he reg. a PROOF OF SERVIGE—CIvIL Raa ‘Proof of Service)Pos. ‘leonard Norman CoheniLeansrd Cohen Invastments v Keey Lynch] 0sse522 {6b [18 Unted Stats ml | enone he documents saad mules or package adress oe pane she ‘loess lam Sand epectyore (1172 epost he ested ero wt he Und Sis Postal Serio, wi the osane uly seep (2) placed te envelne fer entcten ane mang, flewirg ou eshary busines practices, |aready familar fi hs bosons pace a along and presen coreeponsence formating, One sre de ht ‘arossendenae a leat clon se matg, is posted in fe enay course ofbuaiess wh he ‘Sed Sits Peat Sarve, sole eve ws sap a pep. ama eden oramplyed ine anywhere th rig cocared. Tho erelee or pacage wot laidin he rast (Siyand ala) [5 By overnight elven. lence th doamentsn ar enviar o package prove by an veoh very ‘lrarand etssed ane prson a he asteans nt 8 alana he etalon pace fo ion [Srdoveih dey stan ois ar argu size rp nox ote wens Sevey carr 6.1 By mossengor servis. | serene docurana by placing her nen anclope o package aes ithe parsons te asisecs ned in and poviig ie oa poten nansnger alee sven (Aaeoaton 07 lhe mesengormust company ths Pra! f Snes oe coriaraan te Deira of Meer Delw) +. By faxtanamision, Bare on on agreran ole paris to acon cence ty fox arson kd th documents {eine prsane athe fx rumberefdn en Ne Src was repaoa by He oxmaine et used. Acpy of reared bef taransason, whieh pnd each 4 (ay cecwone sores. Based ona cout oreo an aresrent a te paris acopt lector seve, caused ie ‘Semen tobe sti peers al ho Osco eve aaeses td i ©. decor uncersenay egy unde ous of ie Stat of fois ate regoing is te 8nd core. Dat: May 28,2015, tLeuren Wits > ee Uddhete. NRT TERT ———— decrees in oe nin eta alow mt be compare spate cto fon mesenger mus be sche) DECLARATION OF MESSENGER [5 Bypersenatserice. | personaly detvared te envope cpackage recived am he deisrant soe othe persons atthe ‘stdcres ets n tern (3) For pry peste yan soy, ivy Wa rage fo teste oe stoneys ‘es by baer he docurars nan envoys er pacoge, whith wis albedo ery te ttey bring ere, aha ‘ens! een inva in enage ene ion achven te hors rain he mame on tre tw eweig. (@) Fora pany, deve was mace th ary ob mag te Gocanars oh prs essen ws spoon ot younger then (ysis age bowoen he hots ofaght nthe naring ava sbi De eer, ‘Ait nee, tae ovr 18 yar of ge. | arin party ite sbovevteencod ga possedrg. | sored te eovalpe or fackge, 8 sie above, om | doco ur ona of peru he ew fhe Sef Calo that te forego oT ‘PROOF OF SERVICE—GwL {Proof of Service)Pos.040(0) [ Per Lig Nai Ce, Laid Cae vein oe ATTACHMENT TO PROOF OF SERVICE—CIVIL (DOCUMENTS SERVED) (tate use wt om POS-42) ‘The documents that were sorved are as follows (describe each document specifically: PLAINTIFFS" NOTICE OF MOTION AND MOTION FOR SANCTIONS AGAINST KELLEY LYNCH [PURSUANT TO CCP SECTION 1008(¢) and CCP SECTION 128.1; MEMORANDUM OF POINTS AND \UTHORITIBS IN_SUPPORT THEREOF. -D] ORDER ON SAN ™ TN SUANT TO CCP SECTION1008(é) and CCP SECTION 128.7 TET, DMAY 26, - [CYNCH, BC 338322, PLAINTIFFS’ INTENT TO MOVE FOR SANCTIONS UNDER CCP SECTIONS Hoos and 428.7 di SEREGEEGRE, artacrment To PROOF oF senvice—enL(oocumENTs SERVED) par La. “sinner (Prestof Sree)