REQUEST FOR JUDICIAL

CLARIFICATION OF AMBIGUITIES IN
DEFAULT JUDGMENT
FILED MAY 15, 2006

The default judgment entered May 15, 2006 in Case No. BC 338322 is
ambiguous and overly broad as to numerous federal tax and corporate
matters. Defendant Kelley Lynch asks this Court to clarify the following
issues the judgment raises:
1. Kelley Lynch has a legal 15% ownership interest in Blue Mist Touring
Company, Inc. The assignments are non-revocable, were not removed
from this entity, and remain there. Lynchs partnership interest was
not addressed on the federal tax returns, prepared by Cohens
account, when she was compensated with a 15% ownership interest in
or around 1998. The judgment states that Lynch is not the rightful
owner in any assets in Blue Mist Touring Company, Inc. and alleges
that Lynchs shares were held in her alleged capacity as Trustee for
the benefit of Leonard Cohen. Lynchs shares were not held in this
capacity and there is no evidence to support that including, but not
limited to, Richard Westins November 2004 email. Lynch would like
the Court to clarify how this determination was made; what assets
were in this corporation; what Trust or other document was submitted
to the Court proving that Lynch held her shares as trustee for Cohens
equitable title ; what the stock certificates she was issued represent;
how compensation from a corporation (as noted in the Minutes
addressed in the Complaint) represents her fees for services rendered
to Cohen personally as his personal manager; what value the Court
placed on these assets; and, how the Court obtained jurisdiction over
a party not named in the complaint, a Delaware corporation whose
California business registration was suspended by the FTB. Finally,
Lynch asks the Court to clarify whether or not the Court views this
judgment as a formal corporate dissolution of the Delaware entity.
2. Kelley Lynch has a legal 99.5% ownership interest in Traditional
Holdings, LLC. Although Cohen and Westin assured Lynch that the
assets owned by Blue Mist Touring Company, Inc. would be formally
transferred from Blue Mist Touring Company, Inc. to Traditional
Holdings, LLC at the time she was asked to provide Richard Westin
with a limited Power of Attorney to form this entity, no assets were
transferred or assigned to Traditional Holdings, LLC. Tax returns
were submitted to Internal Revenue Service for the years 2001, 2002,
and 2003. Those returns were prepared by Leonard Cohens personal
corporate and tax lawyer, Richard Westin. Lynch was included on

those returns as a partner, K-1 partnership documents were

transmitted to Internal Revenue Service, and Lynch paid taxes in
accordance with those documents. The judgment states that Lynch is
not the rightful owner in any assets in Traditional Holdings, LLC and
alleges that Lynchs shares were held in her alleged capacity as
Trustee for the benefit of Leonard Cohen. Lynchs shares were not
held in this capacity and there is no evidence to support that
allegation. Lynch would like the Court to clarify how this
determination was made; what assets were in this corporation; what
Trust or other document was submitted to the Court proving that
Lynch held her shares as trustee for Cohens equitable title; what the
stock certificates she was issued represent; what value the Court
placed on these assets; and, how the Court obtained jurisdiction over
a party not named in the complaint, a Kentucky business that never
registered to do business in California and does not have any ties to
California. It does not have a place of business, business address,
phone number, payroll, and /or a bank account in California. Leonard
Cohen submitted an Affidavit in the Natural Wealth Case in Colorado
attached to Lynchs declaration as Exhibit IIII. That Affidavit
addresses payments to be made to Lynch, with respect to her
promissory note, for the years 2001 through 2004. These amounts
appear as misappropriations on the expense ledger and are not
identified as legitimate corporate distributions. Does the Court
believe this proves the expense ledger is fraudulent? How can this
be rectified? Did the Court simply assume that Leonard Cohen was
correct when he took the position that payments made with respect to
the corporate books and records (including the two payments in the
management agreement; corporate records re. Class A and B stock;
and profit/loss sharing) were fraudulent even though they were
agreed upon and confirmed in Richard Westins March 6, 2002 letter
that Cohen confirmed receiving at the time? This letter was referred
to the Complaint.
Finally, Lynch asks the Court to clarify whether or not the Court views
this judgment as a formal corporate dissolution of the Kentucky entity
and whether the 2001, 2002, and 2003 federal tax returns are
fraudulent.
3. Kelley Lynch has a 15% ownership interest in Old Ideas, LLC.
Although Cohen and Westin assured Lynch that this Delaware entity
was formed as a partnership in June 2004, Lynch has not been
provided with any tax information. She has no evidence that the
intellectual property that was to be assigned to this entity was
actually assigned. That would include, but is not limited to, all
intellectual property related to Cohens 2004 studio album Dear
Heather. The judgment itself does not mention this entity. The

language states that any interest she has in any legal entities set up
for the benefit of Cohen she holds as trustee for Cohens equitable
title. Lynch did not hold her shares in any entity, including Old
Ideas, LLC in equitable title for Leonard Cohen. Lynch would like the
Court to clarify how this determination was made; what assets were in
this entity; what Trust or other document was submitted to the Court
proving that Lynch held her shares as trustee for Cohens equitable
title; why Richard Westin confirmed in June 2004 emails that this
entity was a partnership for income tax purposes; what value the
Court placed on these assets; and, how the Court obtained jurisdiction
over a party not named in the complaint at all. Finally, Lynch asks the
Court to clarify whether or not the Court views this judgment as a
formal corporate dissolution of this Delaware entity.
4. While Leonard Cohens declaration, in support of the judgment, and
the Complaint itself states that he is the sole owner of LC
Investments, LLC, this entity transmitted K-1 partnership documents
to the State of Kentucky and Internal Revenue Service for the years
2003, 2004, and 2005. These K-1 partnership documents indicate that
Lynch is a 99.5% owner of this entity. The documents indicate, and
this was reported to the Internal Revenue Service and State of
Kentucky, that Lynch received $0 income from this entity for the years
2003, 2004, and 2005. The fraudulent expense ledger shows
income to Lynch for the years 2003 and 2004. Lynch would the Court
to clarify whether she did or did not receive income. If she did not
receive income, Lynch would like the Court to confirm that the ledger
is fraudulent. If she did receive income, Lynch would like the Court to
clarify the actual amount of income received. No assets were
assigned to LC Investments, LLC. They are owned by Blue Mist
Touring Company, Inc. Lynch would like the Court to clarify if the
income she allegedly received from LC Investments, LLC (according
to the expense ledger but not according to the K-1s transmitted to
the tax authorities) is actually income from Blue Mist Touring
Company, Inc. and whether she should receive a tax document from
Blue Mist Touring Company, Inc. for the years 1999 through 2004.
5. How did the Court determine that Leonard Cohen does not owe Lynch
commissions for services rendered and owed for future
commissions? This issue was not raised in the Complaint or argued.
Did the Court take the position that slave labor is legal? Lynch
worked for years on the third intellectual property deal Cohen was
examining. On October 21, 2004 Sony/ATV, according to the Grubman
firm, put in their initial offer. Lynch also was working on Dear
Heather matters; a lithograph deal; and the inclusion of Cohen
material in a New West Record deal. These are some examples of the
services Lynch provided or matters she was working on.

6. Leonard Cohen steadfastly refuses to provide Lynch with IRS required

form 1099 and partnership K-1s with respect to these entities for the
years 2004, 2005, and 2006 (as the judgment was not entered until
May 15, 2006). Cohen has taken the position that this judgment
absolved his obligations with respect to Lynch and these entities. He
is the individual in possession of the necessary tax documents, etc.
although the Deputy City Attorney argued, during Lynchs 2012 trial,
that an employee is the individual in possession of information an
employer must report on IRS required forms 1099 and K-1s.
7. Cohen willfully refuses to rescind the K-1s LC Investments, LLC
transmitted to State of Kentucky and Internal Revenue Service. Did
the Court determine that Lynch is a partner in this entity and, if so,
what evidence was provided to make this conclusion? Lynchs 2004
and 2005 federal tax account transcripts prove that this entity
transmitted K-1s to IRS for the years 2004 and 2005. Leonard
Cohens declaration, submitted to this Court in support of the
judgment (and the Complaint itself), clearly states that he is the 100%
sole owner of this entity. See Leonard Cohens declaration dated
January 24, 2006: 4. I am the sole owner of (ii) Leonard Cohen
Investments, LLC (LCILLC), a limited liability company established in
2000 to hold certain of my intellectual property assets. Exhibit A:
Transcripts of Lynchs IRS account for the years 2004 and 2005
showing K-1s related to LC Investments, LLC and no 1099 from
Leonard Cohen personally.
8. Did the Court determine that Leonard Cohen has the right to keep the
royalty income he collects (via his personal CNB account and LC
Investments, LLC) with respect to assets owned by Blue Mist Touring
Company, Inc.
9. Did the Court determine that it was acceptable for Traditional
Holdings, LLC to: 1) fail to report the income from the Sony sale on
the 2001 tax return; 2) extinguish Lynchs promissory note on the
2002 tax return; 3) extinguish the annuity obligation from the 2003
tax return? What was the basis for this decision? How did the Court
conclude that there was an annuity obligation in light of the fact that
this obligation was extinguished from the 2003 federal tax returns?
10.
Why has the Court failed to address Leonard Cohens
Traditional Holdings, LLC loans/expenditures totaling approximately
$6.7 million? The Annuity Agreement was addressed in the Complaint
and that Agreement (signed by Leonard Cohen and notarized)

acknowledges that Cohen may take loans/advances but they must be

repaid within 3 years. The interest that was agreed to was 6%.
11.
What is the Courts position with respect to Traditional
Holdings, LLC corporate distributions vis a vis the formation
documents and management agreement?
12.
How does the fraudulent domestic violence, a modified
version of the 2008 Boulder, Colorado order registered with LA
Superior Court on May 25, 2011, prevent Lynch from requesting IRS
required tax documents or prohibit Cohen from providing them to
Lynch if indeed the Court believes he is obligated to provide Lynch
with this information. LAPDs report clearly states that Lynchs
alleged emails were generally requests for tax information and yet
their file was forwarded to the City Attorney. That report is replete
with fraudulent statements Cohen and his representatives reported to
LAPD.
13.
Is the default judgment retroactive and, if so, to what date it
extends to.

PROPOSED LANGUAGE (attached to Default Judgment):

Default judgment is also entered against Defendant Kelley A. Lynch
(Lynch) on Plaintiffs claims for imposition of constructive trust and
declaratory and injunctive relief. It is therefore ORDERED, ADJUDGED
AND DECREED that a constructive trust is imposed on the money and
property that Lynch wrongfully took and/or transferred acting in her
capacity as Trustee for the benefit of Plaintiff Leonard Norman Cohen
(Cohen).
It is DECLARED that: (1) Lynch is not the rightful owner in any assets in
Traditional Holdings, LLC, Blue Mist Touring Company, Inc. or any other
entity related to Cohen; (2) that any interest she has in any legal entities set
up for the benefit of Cohen she holds as trustee for Cohens equitable title;
(3) that she must return that which she improperly took, including but not
limited to loans; and (4) that Cohen has no obligations or responsibilities
to her.
It is further ORDERED, ADJUDGED AND DECREED that Lynch is enjoined
from conveying any rights or assets to any third party so as to frustrate
Cohens equitable interest, and from exercising her alleged rights in these
legal entities, including any alleged rights to transfer, move, convey, loan,
borrow, or in any way exercise control over any funds or property received
from Cohen.

EXHIBIT A
Transcripts of Lynchs IRS account for the years 2004 and 2005