Motion Exhibit 5 - Declaration of Joan Lynch - 03.13.15 FINAL

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DECLARATION OF JOAN MARIE LYNCH

I, Joan Marie Lynch, do state and declare as follows:
1. I am a citizen of the United States and a resident of the State of Texas.
Kelley Lynch is my
daughter. Except as to those matters stated on information and belief, I have
personal knowledge of the facts set forth herein and could and would testify
competently if asked to do so.
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2. My husband, John Lynch, and I have a very close relationship with Kelley
and her sons, John
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Rutger Penick and Ray Charles Lindsey. In 1992, my husband and I relocated
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from Philadelphia, Pennsylvania to Los Angeles to be near Kelley and our
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grandsons. We were extremely involved in the upbringing of our grandsons,
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saw them on a daily basis, picked them up from school, knew their friends,
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attended school and sporting activities, spent a great deal of time in their
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home, and enjoyed a very warm and close relationship with our daughter and
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her family. My husband and I saw Kelley and her sons on a daily basis.
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3. Until his death in April 1988, Kelley worked as Marty Machats legal and
personal assistant. It
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was during this period of time that Kelley became acquainted with Phil Spector
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and Leonard Cohen as they were both clients of Machat & Machat.
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4. For approximately 17 years, from 1988 until the fall of 2004, Kelley
worked as Leonard Cohens
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personal manager and in other capacities. From approximately 1996 through
2001, Kelley also worked as Adam Cohens personal manager. Adam Cohen is a
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musician in his own right and the son of Leonard From approximately 1988
until 1991, Kelley worked as an intern/assistant to Phil Spector.
5. Kelley never worked as Leonard Cohens business manager. She did not
handle matters related
to taxation, corporations, finances, investment decisions or advice, accounting,
estate planning, or legal issues. Leonard Cohen had a team of professional
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representatives handling these matters. Those individuals included, but were
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not limited to, Neal Greenberg (investor/financial advisor), Richard Westin (tax
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and corporate lawyer), Arthur Indursky (transactional lawyer), Don Friedman
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(transaction lawyer), Stuart Fried (transaction lawyer), Jean Ransick
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(bookkeeper), Burt Goldstein (accountant), Ken Cleveland (accountant), Peter
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Shukat (transaction lawyer), Jeffrey Hafer (transactional lawyer), Jonas
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Herbsman (transactional lawyer), Rich Feldstein (business manager), Peter
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Lopez (transactional lawyer), Bud Talbot (Dean Witter, investor), Lee Alpert
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(estate planning attorney), Reeve Chudd (estate planning attorney), Herschel
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Weinberg (personal lawyer and family friend), Greg McBowman (royalty
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consultant), and others.

6. Jean Ransick, who resided in New York City, worked as Leonard Cohens
bookkeeper from
approximately 1988 through 1997. Thereafter, Cohen hired his daughters
friend, Jen Brown, to assist with his bookkeeping. At some point, Cohens
accountant (Ken Cleveland) noted that Brown kept sloppy and unprofessional
records. Cohen let her go, did not replace her with another bookkeeper, and
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by default additional work fell upon our office. We generally transmitted

information and documents when requested by Cohens representatives.
7. From approximately 1992 through the winter of 2005, I worked as
Kelleys personal assistant and
office administrator. My daughter had two businesses: Stranger Management,
a personal entertainment management company, and Amazing Card Company, a
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greeting card company. My duties included general office management tasks,
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supervising all employees, handling the phones, receiving mail/faxes and
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distributing them, communicating with Cohen and his representatives,
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communicating with Adam Cohen and his representatives, communicating with
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record companies and others, assisting Adam and Lorca Cohen with various
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matters, ordering Canadian drafts for Cohens Montreal properties, faxing
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information to Cohen and his representatives, transmitting phone messages to
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Leonard Cohen, apprising Cohen and Kelley of personal and corporate bank
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balances, transmitting sales figures and royalty statements to Kelley and
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Cohen, receiving and shipping FedEx packages, arranging for notaries,
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overseeing the filing systems, and generally handling all administrative duties.
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I personally oversaw the filing system that included Kelley and Cohens records
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as well as the corporate records.
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8. I worked with my daughter on a daily basis for over 12 years and am well
aware of how the office
functioned. I know Leonard Cohen and his family extremely well. I oversaw
the work of all Stranger Management and Amazing Card Company employees.
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That would include, but is not limited to, all permanent and temporary
employees.
9. In or around 1996, Leonard Cohen hired my husband, Jack Lynch, to
oversee the construction
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and renovation of his garage and commercial building on Melrose Avenue that
Cohen purchased for his daughters use as a commercial store, Boo Radley.
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Cohen converted his garage into a record studio and guest suite. Jack had
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been a General Contractor in Philadelphia, Pennsylvania and Cohen was having
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difficulties with the completion of construction/renovation of his garage. At
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some point thereafter, Cohen asked my husband to assist him with additional
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tasks.
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During the garage renovation, Cohen had everything stored there
removed. That includes, but is
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not limited to, an old Mercedes he gave to Vajra Rich and boxes of old business
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records. Cohen personally instructed me to make arrangements to pick up
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boxes of older business documents and other items (many of which Kelley
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brought with her when she moved her office from NY to LA) he stored in his
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garage. Due to the fact that our offices were literally overflowing with other
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Cohen business, personal, and archival documents, it was agreed that Kelley
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would store these items in her home garage. I personally discussed the fact
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that Kelley agreed to store these items at her home with Leonard Cohen on
numerous occasions. At the time, he appeared appreciative.
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11.
Given the fact that Kelley carpooled on a daily basis, from
approximately 1999 until 2005, she

would arrive at the office at approximately 8:30, leave the office at 2:00 PM,
pick up the children from school, return home, and work from her home office.
Leonard Cohen was well aware of her schedule and frequently contacted me
personally when he was unable to reach Kelley. Leonard Cohen was not only in
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touch with Kelley throughout the weekday, he frequently phoned her at home
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on weekends and during the evenings. She would begin making calls to Europe
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at 6 AM or so from her home.
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Leonard Cohen and Kelley also routinely had lunch together. In
preparation for their lunch
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meetings, I would prepare copies of documents for Kelley to review at lunch
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with Cohen. When Kelley returned from her lunches with Cohen, I would be
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given instructions on how to respond to requests from his representatives, fans,
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website hosts, record companies, etc.
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From what I personally witnessed, Cohen was fully apprised of his
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business affairs, financial
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matters, accounting issues, legal matters, the status of the deals he demanded,
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expenditures related to his family and friends, and everything in his life.
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Leonard Cohen is a shrewd businessman who micro-managed, controlled, and

directed every aspect of his business and personal affairs. His creative abilities
did not prevent him from focusing on business matters. In fact, in 1994
Leonard Cohen asked Kelley to fly to New York to meet with Eric Kronfeld, CEO
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of Polygram, to discuss a possible intellectual property deal. Cohen continually

advised us that he wanted sales from The Future included in any accountings
prepared with respect to a potential sale. He understood that this album was
his best selling album and the royalties would flow through for a number of
years and then dwindle. It was at this time that Cohens interest in intellectual
property deals began. The deals were not my daughters idea. Furthermore,
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Kelley and Greg McBowman advised Leonard Cohen that they did not believe
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he should sell the intellectual property. Kelley repeatedly advised me that she
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felt a bond securitization with either Charles Koppelman or David Pullman was
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a much better deal. In that way, Cohen could maintain ownership of his
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intellectual property. Cohen expressed concern about the future of the music
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industry.
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I am well aware of Kelleys compensation agreements with both
Leonard Cohen and Adam

Cohen. I was present for conversations related to this issue and handled
deposits into all of their accounts. I was present when Leonard Cohen and
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Adam Cohen had discussions with Kelley regarding her services and
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compensation. Kelleys fees for her services as personal manager were 15% of
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all gross income. That is the agreement she had with both Leonard Cohen and
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Adam Cohen. Leonard Cohen also compensated Kelley with 15% of all his
intellectual property due to the extraordinary amount of work she did on his
behalf including with respect to music and book publishing and marketing,
publicity, assisting his fan websites, business matters related to his artwork and
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lithographs, various activities related to Sasaki Roshis Zen centers (including

almost single-handedly organizing and arranging Roshis 90th formal birthday
party that included custom designed pins, banners, a book, and other items and
serving on Rinzai Jis Board of Directors), his children, his girlfriends, houses
he owned worldwide, and a extraordinary assistance with his personal and
professional life.
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15.
For years, Leonard Cohen had not properly compensate Kelley fully
for her services as his
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personal manager. Cohen and Kelley frequently discussed this matter in my
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presence. This issue came to a head sometime in or around 1995 when Kelley
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rented an office on Keniston Avenue in Los Angeles. At that time, and I was
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present for these discussions, Cohen agreed to pay Kelley 15% of his gross
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income and provide her with a 15% ownership interest in all his intellectual
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property. Additionally, Cohen promised her that he would have an accountant
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review her compensation from 1988 to ensure that she received the full 15%
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commission for all years she worked as his personal manager.
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16.
During the time I worked with Kelley, Leonard Cohen actively
pursued numerous intellectual

property deals. At least two of those deals (1996 Sony/ATV sale and 2001
Traditional Holdings, LLC sale) were formally closed. As of October 2004,
Kelley and Cohens representatives were actively involved in negotiations with
respect to a third intellectual property deal. Cohen repeatedly expressed
concerns about the future of the music industry and was the driving force
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behind these deals.

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Leonard Cohen and Kelley had a very close business relationship
and friendship that I personally
believe was familial in nature. That relationship changed in the fall of 2004. It
was my understanding, at the time, that Leonard Cohen became extremely
upset when he heard Kelley hired a new accountant, lawyers, and indiscreetly
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expressed her concerns about corporate and tax matters.

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In October 2004, Leonard Cohen unexpectedly flew in from
Montreal, Canada. He had left Mt.

Baldy, a Zen center he frequently visited from approximately 1994 through
1998, permanently sometime around 1998. In October 2004, he and Anjani
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Thomas were visiting Cohens home in Montreal. As I recall, Kelley (who
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handled many household and personal matters for Cohen) had dropped his car
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off at the repair shop and he called our office to explain that he was in town and
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to find out where his car was. I distinctly recall Cohen asking her to join him for
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coffee and, after I confirmed that his car was ready to be picked up, drop him
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off at the repair shop. Cohen walked over to our office and he and Kelley left
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together. When Kelley returned she advised me that their conversation was
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bizarre. I recall her telling me that Cohen was inexplicably interested in Betsy
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Superfons sex life. Superfon, a friend of Steve Lindseys (the father of Kelleys
younger son, Ray Charles Lindsey), had recently befriended Kelley and had a
tendency to stir up problems with Lindsey. Cohen was apparently not only
interested in Superfons sex life but questioned Kelley about an IRS
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investigation into Superfons phone sex line business. Cohen also evidently
questioned Kelley about a young woman by the name of Julie Isenberg.
Isenberg was the daughter of Superfons former business partner, Joel
Isenberg. Julie Isenberg worked for us for approximately one week in August of
2004 and Cohen met her during that time. After Kelley returned from
Starbucks, she jokingly commented that she thought Cohen might be planning
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to blackmail Superfon. At that time, neither Kelley nor Cohen mentioned
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anything having to do with financial or banking irregularities or any difficulties
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between them. I personally find it impossible to believe that Cohen discovered
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irregularities in his personal bank accounts as he personally received his bank
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statements at his home, reviewed them, asked questioned about them, had
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Kelley break them down into categories of expenses and gifts, and obsessively
paid attention to his financial affairs, income, and bank balances.
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At some point in October 2004, not long after Cohen returned from
Montreal, he again visited

our offices and, at that time, agreed to provide Kelley with an advance. In my
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presence, he explained to Cohen that she had extraordinary expenses related to
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her greeting card company. Cohen acknowledged that he had not delivered an
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album for years, had not toured for years, and felt confident that the third Sony
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deal would close and they would receive substantial income from the lithograph
deal, studio album sales, book sales, and his tour. He and Kelley also addressed
the fact that they planned to value her interest in all intellectual property and,
when these deals closed Cohen planned to compensate her for that interest.
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Cohen instructed me to retrieve his checkbook and he provided Kelley with a

check. Kelley gave me the check and asked me to send a messenger to deposit
it in her City National Bank account. As I was leaving for the day, I set the
check aside and sent the messenger the next day. At that time, we learned that
the bank would not honor the check. I have since learned that Cohen has
falsely accused Kelley attempted a last minute raid on his account. This is an
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entirely fabricated story. Leonard Cohen has a talent and long history of
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fabricating stories about people and events. Those stories relate to Phil
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Spector, Janis Joplin, Bay of Pigs, Yom Kippur War, and now my daughter.
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At some point in October 2004, after his return from Montreal,
Leonard Cohen began pressuring
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Kelley privately to meet with him and Richard Westin, his tax and corporate
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lawyer. Kelley, who was concerned about corporate and tax matters as they
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related to numerous entities, refused to meet with them. It was my
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understanding that Westin planned to fly into Los Angeles the last weekend of
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October 2004. It was also my understanding that Cohen began pressuring
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Kelley to hand over numerous corporate books and records. Cohen had
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repeatedly asked Kelley to assist him and Westin in unraveling certain issues
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related to these entities.
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21.
I am familiar with the numerous corporate entities that Kelley has
an ownership in. I frequently
handled the corporate files. These files, together with all personal, business,
and archival materials were removed from our offices by Leonard Cohen and/or
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his daughter, Lorca Cohen in October 2004. I was present when they removed
this property. I am personally aware of the fact that Leonard Cohen and/or
Lorca Cohen personally removed many business files that belonged to Kelley. It
was and remains my understanding that Kelley had a legal ownership interest
in the following entities: Blue Mist Touring Company, Inc. (15%), Traditional
Holdings, LLC (99.5%), and Old Ideas, LLC (15%).
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I was present for conference call, and other, discussions between
Kelley, Cohen, and his
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representatives, with respect to these entities. I was present when Kelley and
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Cohen reviewed corporate documents prepared by Richard Westin and other
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Cohen representatives. I frequently followed up with Leonard Cohen, Richard
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Westin and others regarding their requests and instructions related to
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corporate documents, agreements, minutes, assignments, and so forth. I also
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routinely faxed all business documents received from Cohens representatives
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(including as they related to the corporate entities), Sony and music publishers
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(including sales figures on his catalogue and royalty checks), potential buyers,
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etc. to Leonard Cohen personally. Leonard Cohen had a fax at his home and
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the Mt. Baldy Zen Center. Cohen also would routinely fax documents to our
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office. Those would include materials to be sent to his fan websites such as the
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Leonard Cohen files. He filed the online sites from his home, Mt. Baldy, and
elsewhere.
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23.
Leonard Cohen was well aware that he compensated Kelley with
15% of all intellectual property

(assigned to Blue Mist Touring Company, Inc.) as compensation for work she
had done over the years. This compensation was separate and distinct from
her fees as Cohens personal manager. Leonard Cohen personally dictated a
portion of the Blue Mist Touring Company Minutes related to this
compensation. Richard Westin prepared non-revocable assignments that Kelley
and Cohen executed. Kelley was compensated with a 15% ownership interest
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in Blue Mist Touring and 99.5% of Traditional Holdings, LLC. Blue Mist
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Touring Company, Inc. owned all Cohen intellectual property while Traditional
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Holdings, LLC was formed to accommodate the 2001 Sony sale and provide an
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annuity obligation to Cohen. In or around June 2004, I was present when
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Cohen confirmed that he planned to assign all intellectual property, related to
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the studio album Dear Heather, to an entity he intended to name Old Ideas,
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LLC. Cohen advised Kelley that, in accordance with their compensation
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agreement, she would have a 15% ownership interest in that entity and the
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intellectual property. Both Kelley and I had discussions with Richard Westin
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about this compensation and I recall Westin confirming that he formed this
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entity as a partnership.
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As Leonard Cohen was exploring a possible bond securitization deal
with CAK at some point in

the late 1990s, an entity by the name of LC Investments, LLC was formed. This
entity was owned 100% by Leonard Cohen. As I recall, SOCAN (the Canadian
performing rights society) refused to pay certain royalties to a company not
owned 100% by Cohen and therefore Cohen and Kelley agreed that LC
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Investments, LLC would collect those royalties although the actual assets were
owned by Blue Mist Touring Company, Inc. LC Investments, LLC was created
specifically to accommodate a bond securitization deal with CAK.
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Richard Westin, who routinely spoke to me about all matters he was
handling for Cohen, would

frequently recommend various tax planning and/or corporate schemes. I think
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its safe to say that Westin drove my daughter insane with what she felt were
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cockamamie schemes. Kelley frequently informed me that she viewed Richard
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Westins suggestions as incoherent and inexplicably complicated. I recall an
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IRS inquiry into Cohens gift of stock to the Mt. Baldy Zen Center. A lawyer
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representing Cohen with one of the tax issues that arose advised Kelley that the
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IRS agent handling this matter had grown concerned about Westins
evasiveness. Kelley expressed her concern as well.
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Since approximately 2002, Kelley had grown increasingly
suspicious about Cohen, Neal

Greenberg, Richard Westin, and others. This was due to conversations she had
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with them, letters and emails she received, and their ongoing concerns about
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tax and corporate matters. In particular, Richard Westins emails and letters
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were alarming and became increasingly so. They raised ongoing concerns
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about Internal Revenue Service and tax matters, informed her that Neal
Greenberg intended to screw her over, and appeared to intentionally confuse
issues. By the fall of 2004, Kelley continuously advised me that she felt Cohen
and his representatives had used her horrendously. In September 2004,
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Richard Westin wrote Kelley and Leonard Cohen that he had concerns about
Traditional Holdings, LLC and expressed concerns about undesirable tax
inquires. I believe this was the final straw for my daughter.
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Leonard Cohens loans (and expenditures) from Traditional
Holdings, LLC were an ongoing

source of concern. Richard Westin and Neal Greenberg, who I also spoke with
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routinely, repeatedly raised concerns about Leonard Cohens level of
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borrowing. Richard Westin frequently explained to me that Cohen had an
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obligation to repay these loans, with interest, and the loans themselves needed
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to be documented. This, of course, is not something that either Kelley or I
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would handle. On the other hand, Leonard Cohen personally addressed the fact
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that he understood that these loans had to be repaid.
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As Cohen was finishing up his studio album; planned to deliver a new book and
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pursue a lithograph deal; continuously advised us that he planned to tour; and
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was pursuing a third intellectual property deal, there was obviously no
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discussion about the fact that Cohen had the ability to repay the loans. It was
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my understanding that Leonard Cohen had borrowed millions of dollars from
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that entity to purchase homes for his son and girlfriend, pay his personal taxes,
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and to cover other personal and business expenses.
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28.
At some point in early 2004, Neal Greenberg became concerned
about Leonard Cohens
spending habits. I personally faxed these letters to Cohen, and placed copies in
his in-box, and recall his becoming gravely offended by Greenbergs remarks
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with respect to his personal spending. At that time, Cohen advised both Kelley
and me that we were not to discuss his future income and/or deals with
Greenberg or his other representatives. Cohen understood that would make
extremely large sums off his business plans and touring and found Greenbergs
warnings offensive. It is important to note that Leonard Cohen was fanatical
about our confidentiality with respect to his financial matters. He personally
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advised me, time and time again, that he did not want these matters discussing
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with anyone including his son and daughter. Cohen also specifically advised me
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not to discuss financial arrangements or corporate matters with his family
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members and others. We, of course, were absolutely confidential with this
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information.
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29.
From my perspective, Leonard Cohen liked to keep people divided,
did not want them
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interacting with one another, was adamant that details related to his financial
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situation remained private, and only shared certain information with certain
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parties. Kelley may very well have been the only individual in his life who had
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access to every area of his life, knew his family and girlfriends intimately,
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interacted with his friends, attended events with him, joined him at the Zen
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Center frequently, travelled with him, shopped with him, stayed at his the
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various homes he owned, was familiar with the most intimate details of his life,
and they were inseparably close. There is no one in this world who knows
Leonard Cohen in the manner in which Kelley does. I believe his betrayal of
their friendship came as quite a shock.
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30.
The allegations in Cohens lawsuit, which Kelley was finally able to
review when they were posted

online at some point in 2010, were startling. At that time, she reviewed them
to me and we were both shocked. I was also stunned to learn that Leonard
Cohen would begin blaming me, my husband, and younger daughter for things
we had nothing whatsoever to do with. It is my personal opinion that Leonard
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Cohen has acted with malice, vengeance, and vindictiveness towards my
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daughter and I am convinced that he has acted out of desperation and
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retaliated against her. Leonard Cohen is
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obsessed with news accounts of his life, fan websites, and becomes extremely
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angry when he views believes he has been criticized. Cohen only had a handful
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of journalists he would routinely relate with. One of those is Brian Johnson of
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MacLeans Magazine. I believe Cohen understood, all too well, that he was
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able to manipulate these journalists who are frequently devoted fans. It is my
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understanding that, around the period Cohen filed his lawsuit, he granted Brian
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Johnson an interview. It is also my understanding that Steve Lindsey provided
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Johnson with extremely false and self-serving comments about my daughter.

This activity was obviously coordinated.
31.
From approximately 1990 through 1995, our office was downstairs
from Leonard Cohens
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apartment and his daughter lived there while she attended high school. Kelley
treated Lorca Cohen like her own daughter. Kelley drove Lorca to school on a
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daily basis, spent nearly every evening evening with her, assisted her with her
homework, and treated her like a daughter. Kelley was also extremely close to
Adam Cohen and was supportive when he was involved in a tragic automobile
accident. She visited the hospital in Toronto and also attempted to keep his
mother, Suzanne Elrod, up-to-date on Adams progress. Additionally, Kelley was
quite close with Cohens sister, Esther, and even visited her in Florida while she
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had chemotherapy. Kelley was literally part of the Cohen family. Our families
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spent many holidays together. Kelley knew everyone in Cohens life. His
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friends would speak with her. Journalists like Leon Weiseltier befriended her.
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Many people used Kelley in an attempt to become closer with Cohen.
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32.
From approximately 1995 through 2004, our offices were located
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one block from Cohens house.
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He, Lorca Cohen, and others had keys and unfettered access to our offices.
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Cohen would frequently visit our office on weekends and evenings where he
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would review business and personal matters. He also used the color
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photocopier for his artwork projects and would leave notes or instructions for
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me or Kelley. Many of those notes were left on documents he left in his out-box.
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It was Cohens practice to review financial statements, royalty statements, bank
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statements, faxes, and other business and personal documents left for him, in
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his outbox advising me that they were reviewed and could be filed. It is
preposterous for Cohen to now claim that he was unaware that he received
and/or reviewed this information. That would include, but is not limited to,
corporate bank statements, all royalty statements and payments, Neal
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Greenbergs financial statements, all business faxes, sales figures, and so forth
and so on.
33.
If Kelley was unavailable when Cohen called our offices, he would
ask me to review phone

messages, faxes, and mail. He frequently instructed me on the handling of
requests for information and other matters. Cohen routinely asked me to
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review his sales figures and bank balances. Sony faxed through sales figures
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once a week. One of the first things I did when I arrived at work was to phone
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the automated City National Bank phone to obtain the balances in Cohens
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personal and corporate accounts. This is information Cohen requested on a
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daily basis although. Cohen was also in possession of all banking details and
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the automated City National Bank number where his personal and the
corporate accounts were maintained.
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It is impossible to believe that Cohen would suddenly notice
financial irregularities in his

personal and/or the corporate and investment accounts as he was completely
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familiar with those accounts, all deposits, and all expenditures. His personal
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bank statement went to his home. Leonard Cohen has come up with an entirely
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fabricated version of events that in no way relates to how our office functioned;
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how information was conveyed to him; and with respect to his financial and
business affairs.
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35.
Cohen was fastidious with respect to matters related to sales
figures, finances, royalties, income,

and expenses. Cohen understood that royalties were paid on a quarterly or biyearly basis. He was also aware that the main payments with respect to royalty
income were received from Sony, Sony/ATV, the performance rights societies,
and book publishers. He knew precisely when royalties were received from
these sources. He also knew precisely what advances were paid and when. In
addition to placing copies of royalty statements and payment information in his
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in-box, I would fax Cohen copies of those documents. With respect to the
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negotiations and advance for the studio album Dear Heather, Kelley and
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others spent nearly a year negotiating the terms and conditions. Cohen was
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well aware of this fact and refused to deliver his studio album until the advance
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payment was received.
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36.
Difficulties would frequently arise with Sony. At one point,
executives of Sony asked to meet
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with Kelley. They expressed concern about Leonard Cohens threatening
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behavior and letters to Don Ienner, President of Columbia Records. Problems
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arose between Cohen and Paul Burger, President of Sony International.
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Problems also arose with Denise Donlon of Sony Canada. That issue related to
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her position that Cohen was a Canadian roster artist. I always suspected
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Cohen was concerned about his tax and residence issues in Canada. I know
26
27
28
that he and Kelley reviewed that situation with Van Penick and, after doing so,
Cohen and Herschel Weinberg (a Cohen family friend and attorney) decided
Cohen should forget his plans to return to Canada and reapply for a U.S. green
card.
3
4
5
6
37.
Cohen constantly monitored the amounts of money he provided his
son, daughter, friends, and

others. He expressed frustration at the voluntary monthly gifts he provided the
mother of his children, Suzanne Elrod, and others. I personally faxed many
hostile letters from Leonard Cohen to Adam Cohen regarding his finances.
Cohen was disturbed that Adam and Lorca Cohen could not live on $5,000 to
10
11
12
13
14
15
$6,000 per month each in addition to other expenses.

38.
Cohen has a pattern of falsely blaming his advisers and others. For
example, over the years

Cohen frequently advised journalists that his first managers stole the
intellectual property related to numerous songs (including Suzanne) although
16
17
there was no evidence to support these allegations. At some point during his
18
1993 Future tour, Cohen began having difficulties with his tour manager and
19
certain band members. He began accusing his tour manager of stealing from
20
him. Kelley was overwhelmed with work during that tour, had negotiated the
21
merchandising deal with Peter Lubin, was dealing with all tour personnel,
22
23
24
25
26
visas, insurance, payroll (with Cohens accountant), offers, and so forth. Kelley
decided to have one of the concerts spontaneously audited.
39.
During the Future tour, Cohens accountants were on the east
coast and the Wiltern concert
27
28
was in Los Angeles. Don Was, a record producer, referred Cohen and Kelley to
Richard Feldstein who was a highly respected business manager. I was present
3
4
5
6
at the Wiltern when Cohen and Kelley personally met with Feldstein and Cohen
hired him to audit the concert and other tour documents and financials.
Feldstein concluded that there were no irregularities with respect to the tour
accounts. It is my personal opinion that Leonard Cohen falsely accuses people
of ripping him off to deflect attention from other issues and to break
agreements he has made.
10
11
12
40.
Cohen decided to hire Rich Feldstein as his business manager and
accountant. He notified Burt
13
Goldsteins office, who handled his accounting for years (prior to meeting
14
Kelley), that he would no longer require their services. Feldstein eventually
15
wrote Cohen that he felt they should meet more frequently face to face and
16
17
raised concerns about his reluctance to pay estimated taxes. Cohens response
18
was to fire Rich Feldstein. I faxed Feldsteins letter to Cohen and recall this
19
situation because the letter Cohen dictated to Kelley in response was appalling.
20
He fired Rich Feldstein and, from what I recall, advised him that accounting
21
was not a religion. I personally faxed that letter to Feldstein.
22
23
24
25
26
27
28
41.
Cohen ultimately replaced Rich Feldstein with Ken Cleveland. The
IRS audited issues related to

the 1996 Stranger Music gift of charitable stock. Cohen needed an accountant
in Los Angeles. Steve Lindsey, who was Cohens record producer,
recommended Ken Cleveland. As the outcome of the audit was successful and
Cleveland was in the Los Angeles area, Cohen decided to hire Cleveland as his
accountant.
3
4
5
6
42.
In or around 1988, Kelley and her husband, Douglas Penick,
referred Cohen to their investment

advisor, Bud Talbot of Dean Witter Reynolds. Bud Talbot had a long standing
relationship with the Penick family and had invested their substantial wealth
for years. I recall visiting Kelley when Leonard Cohen was in New York City.
His personal lawyer, Herschel Weinberg, and he were unraveling matters
10
11
related to certain corporate matters and off-shore accounts Cohen had prior to
12
Marty Machats death. It was at this time that Cohen asked her who she and
13
Douglas used to invest their money. Cohen then hired Bud Talbot to handle his
14
investments.
15
43.
Kelley did not know Leonard Cohen well until following Marty
16
17
Machats death. Kelley and
18
Douglas Penick were married in 1988 and had dated for a considerable time
19
prior to their marriage. She and Cohen most definitely did not have a brief
20
intimate relationship at this time or throughout the years. It is my personal
21
opinion that Leonard Cohen most definitely wanted to have such a relationship
22
23
24
25
26
and was obsessed with my daughter. I believe this may explain some of his
vindictive behavior towards her.
44.
In or around 1996, Neal Greenberg visited the Tibetan Buddhist
teacher His Holiness Kusum
27
28
Lingpa in Los Angeles. Kelley, Oliver Stone, and others, sponsored a Buddhist
center, Orgyen Khachod Ling, for His Holiness who spent half his time in Tibet
3
4
5
6
7
8
9
and half in the United States. Leonard Cohen met Neal Greenberg during this
visit. He personally decided to hire Greenberg as his financial and investment
adviser. Kelley did not actually know Neal Greenberg prior to his visiting Los
Angeles. She was acquainted with his ex-wife, Karen Greenberg.
45.
Neal Greenberg introduced Cohen and Kelley to tax lawyer Richard
Westin and others. Kelley
10
11
did not know Westin and would have been unable to recommend him to anyone.
12
Cohen hired Westin who then worked as his personal tax and corporate lawyer
13
for years. Neal Greenberg, Richard Westin, and other advisers, handled all
14
estate planning, accounting, corporate matters, tax and financial issues,
15
investments, and/or legal work. At no time did Kelley advise Leonard Cohen
16
17
with respect to these matters. She never prepared a legal or financial
18
document for Leonard Cohen or the corporate entities. He relied solely on his
19
team of professionals for that advice. Kelley followed their directions, advice,
20
and instructions. At Cohens request, I typed a letter wrapping Neal Greenberg
21
into attorney/client privilege with Cohen and Westin.
22
23
24
25
26
27
28
46.
Leonard Cohen demanded the intellectual property deals that
became the subject of his lawsuit

against my daughter in 2005. The first deal closed in 1996; the second deal
closed in 2001; and, Kelley, together with Cohens representatives, was working
on the third deal when she and Cohen parted ways. She was also assisting with
the delivery, release, and marketing of the studio album Dear Heather, album
packaging information, a very lucrative lithograph deal, the imminent release
3
4
5
6
7
8
9
of Book of Longing, and many other matters. Cohen and Kelley also
discussed his plans to tour.
47.
I have reviewed Cohens complaint in this matter with my daughter
and the entire

narrative was fabricated and in no way represents the facts or evidence. It is
my personal belief that this lawsuit was filed against my daughter in retaliation
10
11
for her reporting allegations that Cohen committed tax fraud to the Internal
12
Revenue Service. In April 2005, Kelley reported those allegations to IRS. I am
13
aware of the fact that Kelley was dealing with Agent Bill Betzer of the IRS and
14
confided in me that she planned to address the allegations of Leonard Cohens
15
tax fraud with him. Her lawyers had advised her that Cohens tax fraud was
16
17
18
19
20
21
criminal in nature. Agent Betzer called our offices and I am aware that Kelley
was speaking with him about a number of issues.
48.
Kelley did not receive overpayments with respect to her work as
Cohens personal manager. She

never worked as Cohens business manager. She had an ownership interest in
22
23
Traditional Holdings, LLC, Blue Mist Touring Company, Inc., all intellectual
24
property, and was advised that she would be compensated with 15% ownership
25
interest in intellectual property and royalty income related to the Dear
26
Heather studio album. It was my understanding that Richard Westin was
27
28
forming an entity known as Old Ideas, LLC and both Kelley and Cohen would
have an ownership interest in that entity.
3
4
5
6
As of the fall of summer of 2004, when we were working on the album

packaging, Cohen advised us that the Dear Heather publishing should be
assigned to Old Ideas, LLC. I reviewed business documents wherein Richard
Westin confirmed that he had formed this entity as a partnership and
understood that Kelley had a 15% interest in it.
49.
Leonard Cohen is the individual who determined when these
10
11
entities would be created and he is
12
the individual who named these entities. I was present when Cohen signed
13
many corporate documents, stock certificates, and am aware that he was fully
14
aware and consented to Kelleys ownership interest. It is my personal opinion
15
that not only has Leonard Cohen attempted to blame his wrongdoing on Kelley,
16
17
18
19
20
21
and others, but has also attempted to benefit by depriving her of property she
owns and monies due her.
50.
It is my understanding that very similar problems arose for Machat
& Machat, with Cohen, after

Marty Machats death. Leonard Cohen evidently refused to pay Machat &
22
23
Machat commissions they were entitled to and may very well have concealed
24
evidence related to their ownership interest in and entity known as Stranger
25
Music, Inc. For years, Steven Machat advised Kelley that he and his father had
26
27
28
a 15% ownership interest in that entity. It is my understanding that, after she

and Cohen parted ways, Kelley began reviewing older business documents and
came across evidence that Machat & Machat did in fact have an ownership
interest in Stranger Music, Inc. At some point, Kelley contacted Steven Machat
3
4
5
6
7
8
9
and provided him with this evidence. Shortly before parting ways with Cohen,
Kelley advised me that she saw a file at Cohens house containing a bearer
bond payable to R&M Productions. She believed that related to a company
owned by Machat & Machat.
51.
Leonard Cohen is the individual who controlled the work done by
his representatives. That
10
11
would include the negotiations and terms of the intellectual property deals.
12
Cohen demanded complex stock deals. Leonard Cohens artistic endeavors did
13
not prevent him from being fully aware of or involved with his business affairs.
14
It was my understanding that he has a background in business and law. Cohen
15
frequently accompanied Kelley to meetings with Sony. If he knew Kelley was
16
17
18
19
20
21
attending a meeting about one of his business matters, he would begin calling
incessantly.
52.
I am aware of the fact that Leonard Cohen was on conference calls
regarding these deals with

Kelley, Richard Westin, Neal Greenberg, and others. I am the individual who
22
23
would frequently arrange and place the conference calls. I would also remain
24
on the line for many calls and take notes for Kelley. I also frequently sat with
25
Kelley while she was on the phone with Cohen, his representatives, and other
26
27
28
parties. Kelley took shorthand notes of all her calls. Many of those notes were
in files that Cohen and his daughter removed from our offices.
1
2
3
4
5
6
53.
Cohen was an aggressive micro-manager who required, at times,
hourly updates on negotiations,

deals, and other matters. At times, he drove Kelley insane with his relentless
demands and inquiries. It is important to note that Kelley had many other
responsibilities and was required to spend countless hours, for years, working
on these deals. It is impossible to explain what a personal manager does but it
is extremely time consuming and involves overseeing every single aspect of an
artists affairs. Kelley actually archived Leonard Cohens body of work. He was
10
11
the last individual to have his watercolor notebook of artwork. I recall our
12
searching the office well before they parted ways. Cohen personally confirmed
13
for me that he recalled having this journal at his home and scanning the
14
artwork. He simply fabricated information he advised the Court that Kelley had
15
in her possession. Cohen and/or his daughter took all business files, including
16
17
the corporate, banking, and financial files, and Kelley had her lawyers transmit
18
the corporate books to Cohens lawyers. Cohen and/or his daughter took all
19
files related to royalty statements, business agreements, book and music
20
publishing matters, and the corporate entities. They also took two tables that
21
Leonard Cohen personally gave Kelley and she was upset that they removed
22
23
property belonging to her. Every file in our office filing cabinets, for the most
24
part, belonged to my daughter. Cohen never attempted to make arrangements
25
to have the files copied and simply demanded access to the office and he and
26
27
28
his daughter removed what they felt they were entitled to including my
daughters business files.
1
2
3
4
5
6
7
8
9
54.
If Leonard Cohen had not demanded complex stock deals, Kelley
would have received a much

larger commission and there would have been far more interested parties. I
personally heard Leonard Cohen constantly demand stock deals. His
representatives worked directly for him.
55.
I distinctly recall Greg McBowman, Cohens royalty consultant who
also handled audits, flying

into Los Angeles. Greg and I were quite close. He and Kelley both advised me
10
11
that they did not believe Cohen should sell the intellectual property assets.
12
They, and others, repeatedly advised me that the CAK bond deal was a much
13
better deal. I was also quite close with Cohens transaction lawyer, Peter
14
Lopez, who worked extremely diligently on the CAK deal. Cohen personally
15
decided not to pursue the CAK bond deal and instead chose to do these deals
16
17
18
19
20
21
with Sony.
56.
I was in Kelleys office when Stuart Bondell of Sony called to offer
$8 million for the second

intellectual property deal. Kelley hung up and phoned Cohen who advised her
that he wanted to pursue the deal with Sony. Cohen was extremely concerned
22
23
about dropping the CAK deal and pursuing a deal with Sony because he wasnt
24
convinced Sony would close the deal. His conditions required Sony to make a
25
non-refundable good faith down payment of $1 million. Sony agreed and these
26
27
28
funds were wired into his personal account. Cohens decided not to pursue a
bond securitization deal with CAK that Kelley and his other representatives
were negotiating. Kelley repeatedly advised me that she felt the CAK deal was
the better deal because CAK offered to loan or advance Cohen approximately
3
4
5
6
$5.8 million and he had the ability to retain ownership interest in the
intellectual property. CAK filed a lawsuit against Cohen over this situation and
ultimately Leonard Cohen decided not to pay Peter Lopez, his transactional
attorney in the CAK matter, legal fees due for nearly two years of work. To the
best of my recollection, Peter Lopezs legal bill totaled approximately $100,000.
Peter Lopez had nothing to do with Cohens decision to pursue a deal with Sony
10
11
12
13
14
15
rather than CAK. The situation merely seemed to provide Leonard Cohen with
an excuse not to pay Peter Lopez for services rendered.
57.
After the Sony deal closed in 2001, Leonard Cohen came into our
office and congratulated Kelley

on her hard work and the successful outcome of the negotiations. He brought
16
17
flowers for both of us and took us to lunch. At that time, Cohen discussed his
18
personal expenses with respect to the deal and instructed me to type a list and
19
direct Greenberg to pay these costs from the Traditional Holdings, LLC
20
account. This list of expenses related to his personal representatives, advisers,
21
and other expenses. I typed the authorization letter, Cohen reviewed and
22
23
signed it, and I personally faxed it to Neal Greenberg. Leonard Cohen was
24
keenly aware of his personal transaction fees. It is my understanding that
25
Leonard Cohen has now taken the position that he was unaware of his own
26
27
28
transaction fees with respect to these deals. He was extremely aware of the
work his representatives were doing and their fees. I personally recall retainer
agreements Cohen signed with Arthur Indursky/Grubman, Indursky firm and
Greg McBowman in connection with these deals.
3
4
5
6
58.
Every year when I worked for Kelley, she received a W2 or 1099
from Leonard Cohen.

Kelley was entitled to 15% of all gross income from all sources. It is my
understanding that Cohen refuses to provide Kelley with a 1099 for the year
2004. I also understand that Kelley has attempted to address K-1 partnership
documents she received from LC Investments, LLC and Traditional Holdings.
10
11
She has also repeatedly asked Leonard Cohen to provide the information in his
12
possession needed to prepare and complete a proper accounting. I was present
13
when Leonard Cohen and his daughter, Lorca Cohen, personally removed
14
business and personal records from our offices. The banking, accounting,
15
financial, investment, and corporate files, royalty statements, agreements, and
16
17
other relative information were in those files. My daughter was not present
18
when Cohen removed his property. He had become threatening and Kelley
19
decided to look for new office space so as not to be near him. It is absurd that
20
he has now alleged that she is stalking him or wants to attend one of his
21
concerts. That is a fantasy on his part. Since filing this lawsuit, Leonard Cohen
22
23
24
25
26
and his lawyers have refused to communicate with Kelley over extremely
legitimate matters. Those issues include federal tax matters.
59.
I was present when Kelley and Cohen reviewed Richard Westins fax
of December 4, 2000.
27
28
Leonard Cohen and Kelley were sitting in her office when Westins original
email was received. Cohen and Kelley, who were sitting at her office computer,
3
4
5
6
prepared an email addressing Westin s suggestions, asking additional

questions, and printed out a copy that I faxed to Westin and filed. I vividly
recall this conversation because Cohen was adamant that he did not want Lorca
or Adam listed as beneficiaries or involved with any of these structures or
deals.
60.
Kelley explained to Cohen and me that she was not completely
10
11
comfortable with the
12
arrangement that was ultimately recommended. That arrangement involved
13
Kelley owning 99.5% of Traditional Holdings, LLC and being asked to provide a
14
promissory note in the amount of $245,000 for her ownership interest. In my
15
presence, she asked Cohen for an Indemnity Agreement. Cohen instructed me
16
17
to phone Westin to advise him to prepare the Indemnity Agreement which was
18
then signed by both Cohen and Kelley and notarized. I made a copy of this
19
agreement and placed it in the Traditional Holdings, LLC corporate file that
20
Cohen ultimately took from our office with other corporate records. The
21
Annuity Agreement was also placed in this file. Many of the corporate
22
23
documents were signed by Leonard Cohen and notarized. I believe Cohen
24
understands that Kelley does not have the wherewithal financially to defend
25
herself legally. There are witnesses to everything that has occurred and a
26
27
28
tremendous amount of evidence. It is also my understanding that, since the

spring of 2005, Leonard Cohen planned to use restraining orders to undermine
Kelleys credibility and prevent her from serving as a witness against him.
Steve Lindsey used similar tactics against Kelley.
3
4
5
6
61.
I frequently handled the corporate paperwork that was provided by
Richard Westin and other

Cohen representatives. I would arrange for notaries and photocopy the
documents for Cohen and Kelley. These documents were always placed on his
desk in our offices and faxed to his home, cabin at Mt. Baldy, or wherever he
was presently staying. Copies of everything were placed in the files and
10
11
12
13
14
15
corporate books. The notary, who sometimes came to the office, would explain
what Cohen or Kelley was signing.
62.
Richard Westin, Neal Greenberg, and Cohens other advisers,
continually directed Kelley on how

to handle corporate documents, what should be executed, who should sign,
16
17
when it was necessary to have documents notarized, if the documents should
18
be placed in the corporate books or files, or when to simply hold a document
19
until further notice. We followed these instructions very carefully.
20
21
63.
Kelley and I had no involvement with Cohens legal, investment,
corporate, tax or accounting
22
23
matters. That would include the preparation of his tax returns. We would
24
simply follow the instructions of Cohen, or Cohens lawyers and/or accountants,
25
and provide them with the documents or information they requested.
26
27
28
64.
At some point in early 2002, Sony issued a $7 million 1099 to
Cohen. Kelley asked me to fax it
to Cohens accountant, Ken Cleveland. I recall the drama that broke out
among Cohen, Greenberg, Westin, and Cleveland over this 1099. Richard
3
4
5
6
7
8
9
Westin assured me that Sony mistakenly issued the 1099; Cleveland was
extremely upset by the penalties and interest that would have accrued; and
Cohen advised me that he phoned and spoke to Cleveland about the situation.
The hysteria surrounding this situation alarmed Kelley.
65.
Another Sony 1099 in the amount of $1 million had similarly caused
a tremendous amount of
10
11
12
13
14
15
drama with Cohen and his representatives. The issues related to IRS matters
and these deals became increasingly troubling.
66.
On October 21, 2014, Kelley advised me that she and Cohens
relationship problems were

irreparable and they would no longer work together. I recall speaking with
16
17
Stuart Fried that morning. Stuart was Cohens transactional attorney. Kelley
18
had left a message explaining that she and Cohen were parting ways. Earlier
19
that morning, Stuart had called to say Sony/ATV finally put an offer in for the
20
third and final intellectual property deal Cohen demanded. Stuart Fried
21
appeared shocked by the news and advised me that artists do not want to pay
22
23
24
25
26
27
28
their managers what they are owed.

67.
Sometime shortly after they parted ways, Cohen and Kelley once
again meet at Starbucks. Kelley

was stuck in traffic and running late. She called to ask me to have one of her
employees meet Cohen to let him know she was on her way. My husband and I
agreed to meet Kelley at her home after the meeting. Kelley was reluctant to
meet with Cohen alone but her lawyers assured her that it was fine. At this
3
4
5
6
meeting, Leonard Cohen informed Kelley that he would give her whatever she
wanted but he needed her assistance. She refused. Cohen apparently became
quite threatening and aggressive with her. According to what Kelley told me,
he demanded that she meet him at his lawyers office to sign a settlement
agreement without her lawyers present. When Kelley returned, Cohen phoned
and advised her that her lawyers could accompany her to the meeting with his
10
11
lawyer but they would have to remain silent. I answered the phone and was
12
present throughout the conversation. Kelley informed Cohen that she would
13
not meet with him; had no intentions of signing a settlement agreement;
14
demanded that he pay her what he owed her; and advised him to stop
15
threatening her. It was my understanding, at the time, that Leonard Cohen
16
17
demanded Kelleys assistance and sought her testimony against his
18
representatives. During this period of time, Leonard Cohen also repeatedly
19
called me and my husband. He thanked us for our work and assured my
20
husband that his work had been impeccable. However, he was upset that
21
Kelley refused to meet with him and asked if there was anything we could do to
22
23
assist him. Thereafter, he began threatening Kelley by falsely accusing us of
24
placing his money in off-shore accounts. My husband and I never
25
misappropriated anything from Leonard Cohen nor did we place his funds in
26
27
28
off-shore accounts. Cohen also accused my younger daughter and her husband
of using his money to start their computer business. That is also blatantly false.
Kelley did not begin harassing Leonard Cohen after they parted ways. She
refused to meet with him or talk to him due to his increasingly aggressive and
3
4
5
6
threatening conduct. Leonard Cohen is the individual who began harassing my

daughter including by involving Steve Lindsey in the situation and concocting a
custody matter with him. I distinctly recall, during October and November of
2004, Kelley complaining that Cohen was calling her morning, noon, and night
sometimes as early as 5 AM. She explained that Cohen, Greenberg, and
Westin were completely hysterical and begged her to be reasonable and work
10
11
12
13
14
15
with Cohen.
68.
At no time did I hear from Leonard Cohen or Kelley that there was
an informant who met

with Lorca Cohen to advise her that Cohen could not retire. During this period
of time, I was in the office on a daily basis and spoke with Cohen numerous
16
17
times. Never one was this ridiculous accusation raised. Nor did I hear from
18
Leonard Cohen or Kelley anything related to her allegedly supporting a
19
gigolo. These accusations are absurd. Leonard Cohen fabricates stories for
20
the news media. These stories have involved Phil Spector, Janis Joplin, Bay of
21
Pigs, and Yom Kippur War. Leonard Cohen likes intrigue and, like his idol
22
23
Garcia Lorca, has attempted to present himself to the world as a revolutionary,
24
field commander, or spy. He refers to his fans as his constituents. Having fans
25
would be beneath Leonard Cohen.
26
27
28
69.
I am the individual, at both Stranger Management and Amazing
Card Company, who supervised
everyones work. There was not one employee, apart from Kelley, who would
have been in a position to advise Leonard Cohen or his daughter that he could
3
4
5
6
7
8
9
not retire. No one had access to the corporate books, records, financial and
bank statements, agreements, and so forth. And, due to the confidential nature
of a great deal of material at our offices, no one was permitted to randomly
explore and rifle through files or corporate records.
70.
In or around August 2004, Kelley hired an individual to assist with
her greeting card company.
10
11
Julie Isenberg was introduced to us by Betsy Superfon. Superfon and Julie
12
Isenbergs father had been partners in a phone sex line company. Julie
13
Isenberg worked for Amazing Card Company for approximately one week. Her
14
position involved packing orders as Christmas orders were shipped in August. I
15
directly supervised Isenbergs work and was present at all times when she
16
17
would have been in the office. I recall Isenberg spending most of her time on
18
the phone looking for work. She was extremely incompetent and
19
unprofessional. At no time would Julie Isenberg have access to corporate
20
books, records, files, financial information, royalty income, or be in a position to
21
determine corporate ownership interests or decide that Leonard Cohen could
22
23
24
25
26
not retire. It is my understanding that Julie Isenberg was the so-called

informant who advised Lorca Cohen that her father could not retire.
71.
In 2005, Betsy Superfon informed me and Kelley that Julie Isenberg
had assaulted her maid, stole
27
28
her jewelry and dog, and was last seen stripping and doing drugs in Las Vegas.
Superfon also explained that Julie Isenberg was jealous of Kelley. Superfon also
3
4
5
6
told me and Kelley that her former partner, Julies father, had placed $90
million from their business in Swiss bank accounts. I never really knew if this
was gossip or reality. I understood that the business had been quite successful
and Superfon spent money lavishly and lived in a gorgeous house in Malibu.
My husband and I visited her on numerous occasions and spent one Christmas
evening there. Betsy Superfon may very well have been jealous of Kelley.
10
11
Leonard Cohen and Steve Lindsey constantly phoned call and she was the focus
12
of their attention. I know that Superfon accompanied Kelley when she visited
13
Esther Cohen in Florida during her chemotherapy sessions. Kelley was quite
14
fond of Esther Cohen and I knew her quite well myself.
15
72.
I never heard, from Cohen or Kelley, that he discovered she had
16
17
misappropriated monies or
18
there were irregularities with his City National Bank account. I am aware that
19
Leonard Cohen eventually went into City National Bank and falsely accused
20
Kelley of certain things. I worked for years with Marie DeMirdjian, City
21
National Bank, and would imagine that she was simply impressed with Leonard
22
23
Cohens performance. It is my understanding that based on gossip and
24
innuendo City National Bank froze and closed Kelleys personal and business
25
accounts as well as Rutgers personal account. Kelley advised me that Leonard
26
Cohen and his lawyer were discussing her City National Bank accounts with
27
28
Marie DeMirdjian and I suggested that she have her lawyers address this
situation in writing.
3
4
5
6
73.
Throughout the fall of 2004 and winter of 2005, Cohen continued to
pressure Kelley into settling

with him. At some point, he hired former District Attorney Ira Reiner to
represent him in private mediations. He wanted Kelleys help with those
mediations. I understand that he offered her 50% community property and
confirmed that she was entitled to her 15% commission with respect to her
10
11
services as his personal manager and her 15% ownership interest in all
12
intellectual property. I also understand that Leonard Cohen offered Kelley 50%
13
community property or palimony and there were discussions about paying her
14
$10,000/month walking around money.
15
74.
Kelley was concerned that should she enter into any type of
16
17
settlement with Cohen, although he
18
owed her a tremendous amount of money, she would be engaged in an attempt
19
to possibly cover up tax fraud or be involved with extortion attempts and
20
insurance fraud. Cohen was pressuring her to testify against Neal Greenberg,
21
Richard Westin, and others. Kelley also feared that he was falsely accusing her
22
23
24
25
26
colleagues, Greg McBowman and Stuart Fried, of committing fraud. This

profoundly disturbed her.
75.
At some point in or around November 2004, we moved our offices
to Santa Monica, California.
27
28
Prior to that, Leonard Cohen and his daughter made arrangements to pick up
Cohens personal and business property from our offices. I was present when
3
4
5
6
his property was removed and that would include, but is not limited to, all
business files, corporate business files, correspondence, bank and investment
statements, boxes of archival materials, and other materials. At no time did
either Leonard or Lorca Cohen advise me that any items were missing or had
not been returned. At no time did Kelley take Leonard Cohens personal or
business property to her home where she also had an office. I do recall
10
11
Leonard Cohen removing tables and other property, including framed
12
lithographs, that belonged to Kelley. She later complained that Cohen had
13
removed property belonging to her and corporations she had an ownership
14
interest in.
15
76.
In the fall of 2004 and early 2005, Kelley was represented by the
16
17
law firm of DiMascio &
18
Berardo. She became extremely frustrated with them and was concerned that
19
they were not properly representing her, did not have a handle on the legal
20
issues or evidence, and were encouraging her to make a deal that concerned
21
her. She was also frustrated that they were unable to obtain materials
22
23
necessary to prepare a proper accounting (including with respect to the
24
corporate entities) from Cohen and his lawyers. Kelley fired DiMascio &
25
Berardo in early 2005 and, based on Steve Lindseys recommendation, hired
26
27
28
Mike Taitelman. I was present when Kelley phoned Taitelman to discuss his
phone conversation with one of Cohens lawyers. Kelley was extremely upset
when Taitelman advised her that this lawyer explained to him that if Kelley did
as Cohen and his lawyers wanted, they would say she was used as a pawn, and
3
4
5
6
if not they would say she orchestrated the mess that has now arisen. When
Kelley got off the phone, she and I discussed this conversation and I advised
her to find more suitable legal advice. It was simply not my experience that any
of the lawyers who had represented her in this matter had her best interests in
mind.
77.
At some point in the spring of 2005, prior to my husband and my
10
11
moving to Texas, Kelley was
12
contacted by a lawyer who also worked as His Holiness Kusum Lingpas
13
translator. This individual worked for Boies Schiller and represented Cohens
14
financial adviser, Neal Greenberg. I was somewhat concerned with this
15
individuals sudden friendship with my daughter and cautioned her that he
16
17
might be using her to obtain information or evidence to assist his client. Kelley
18
assured me that Norman Posel was completely professional and even offered to
19
help her find legal representation. However, at some point, Kelley advised me
20
that Norman Posel seemed to be pursuing her romantically. This, of course,
21
alarmed me and seemed out of line.
22
23
24
25
26
27
28
78.
In the Spring of 2005, Kelley read me an email where Boies Schiller
advised Kelley that they were

concerned Leonard Cohen and his lawyer were attempting to engage her in
criminal conduct. Boies Schiller explained to Kelley that she should go wired to
her meetings with Cohen and/or his lawyer and I distinctly recall them advising
her to contact the District Attorneys Office to have them wire her for any such
meetings. Kelley had been contacted by the Los Angeles District Attorneys
3
4
5
6
office with respect to Phil Spector and was relating to Investigator Brian
Bennett of that office. Kelley had called me when Investigator Bennett stopped
by her house in the winter of 2005 to question her about her friendship with
Phil Spector. Someone had evidently placed an anonymous tip to the DAs
office about her friendship with Phil Spector. I recall Kelley becoming upset
when she asked her lawyers to call Investigator Bennett. DiMascio advised
10
11
Kelley that she was concerned the DAs office had actually stopped by Kelleys
12
house with respect to the allegations that Leonard Cohen committed criminal
13
tax fraud. I advised Kelley to inform Investigator Bennett that Leonard Cohen
14
was attempting to blackmail her and he and his lawyer were encouraging Steve
15
Lindsey to take Kelleys younger son from her custody. It seemed entirely
16
17
18
19
20
21
coercive and tactical on their part.

79.
While this situation was unfolding, Steve Lindsey was becoming
increasingly aggressive and

abusive with my daughter and her sons. He and his girlfriend, Dinah Englund,
were expecting a baby and Lindsey was under pressure financially and
22
23
emotionally. He has problems controlling himself and Kelley, Rutger, and Ray
24
frequently received the brunt of his anger. I believe Leonard Cohen understood
25
he could easily work Steve Lindsey up and encourage him to create a custody
26
27
28
matter with respect to Ray. I have watched how Leonard Cohen treated the
mother of his own children. He demonized her.
1
2
3
4
5
6
80.
It is my understanding that after Kelley and Cohen parted ways,
Steve Lindsey began meeting

with Cohen and his lawyer. I was present on numerous occasions when Lindsey
advised Kelley that it was in her best interests to settle with Leonard Cohen.
Lindsey informed us that he met with Cohen and Robert Kory, was shown a
manila file that they referred to as evidence, and were threatening to have her
jailed. I asked him what was in the manila file and Steve acknowledged that he
had not seen the actual evidence. I reminded Steve that Kelley owned 15% of
10
11
all Cohens intellectual property and had an ownership interest in numerous
12
corporate entities. I also told him that I thought he should mind his own
13
business. I frequently had encounters with Steve Lindsey where I was forced to
14
address his utterly abusive and aggressive conduct towards my daughter and
15
grandsons. He was also openly hostile with Kelleys nephew, Gesar Mukpo,
16
17
who lived with her off and on for approximately 10 years. Gesar advised me
18
that Jennifer Lindsey wanted to move out of Kelley and Steves house because
19
her father was so abusive and Jennifer repeatedly told me horror stories about
20
her father. I knew all the young people in Kelleys life and spoke to them
21
extensively. Chloe Favella, a friend of Rutgers who worked with us, could not
22
23
24
25
26
27
28
believe how abusive Steve Lindsey was with Kelley, Rutger, Ray, and others.
81.
Steve Lindsey advised Kelley, in my presence, that Leonard Cohen
visited his office and

informed him that she had sex with Oliver Stone and Richard Rutowski. Steve
Lindsey was livid and also told Kelley that Cohen personally informed him that
she had sex with Cohen. Kelley was not attracted to Leonard Cohen and
continuously complained about his conduct and sexual harassment. I am
3
4
5
6
familiar with Oliver Stone and Richard Westin who were friends of Kelleys. I
am also my daughters confidante. She never had sex with either of these
individuals and it is my unshakeable belief that Leonard Cohen intended to stir
up a custody matter to pressure Kelley into cooperating with him. It is not hard
to stir up problems with Steve Lindsey. I have seen it happen repeatedly. He is
an unstable individual, with a horrendous temper, who was consumed with
10
11
jealousy with respect to my daughter. He frequently used their son as a
12
weapon. It is obscene to think of Leonard Cohen and his lawyer meeting with
13
Steve Lindsey and lying about Kelley and discussing her fictional sex life.
14
Cohen clearly understood that Lindsey is an extremely jealous man.
15
82.
These tactics were successful as, in conjunction with a SWAT
16
17
incident on May 25, 2005, Lindsey
18
coordinated a custody matter that involved evidence submitted by Leonard
19
Cohen, Robert Kory, and Betsy Superfon. I have reviewed the custody
20
documents with Kelley and found the allegations astounding and
21
overwhelmingly fraudulent and false. Kelley was a wonderful mother who took
22
23
great care of her sons. It is my understanding that evidence exists that
24
Lindsey, Cohen, Kory, and Superfon conspired to have Kelley falsely arrested on
25
May 25, 2005. I personally believe that Steve Lindsey and Leonard Cohen used
26
27
28
the custody matter to crush my daughter. It also clearly had to do with money.
Following the filing of the custody matter, Kelley was advised by an LAPD
Sergeant that she should make a deal with Steve Lindsey. I was with my
daughter almost every day until my husband and I moved in the spring of 2005.
3
4
5
6
She was under a tremendous amount of stress, attempting to salvage her

greeting card company and sell her home, but Kelley has always worked well
under stress and she was very devoted to her sons at this time and cared for
them exceedingly well, as she always had. Although Cohen and Lindsey owed
Kelley a tremendous amount of money, they seemed to use the circumstances to
pressure her into making deals.
10
11
83.
At some point in the winter of 2005, Kelley called to advise me that
she was shocked to learn that
12
13
Betsy Superfon (without Kelleys awareness or permission) was attempting to
14
negotiate with Cohen and/or Kory on her behalf. While Betsy Superfon did not
15
know Cohen, she advised us that in the fall of 2004 he contacted her. She
16
17
explained that she was merely attempting to assist Kelley by speaking with
18
Cohen and his lawyer. When Kelley asked Superfon, in my presence, why she
19
provided Steve Lindsey with a declaration in the custody matter, she advised us
20
that she did not know what she was signing. She also spoke to me directly and
21
advised me that she felt, if anything were true, Kelley had been too good to her
22
23
24
25
26
27
28
sons.
84.
At one point, Steve Lindsey had his father, Mort Lindsey, speak with
Cohen and Robert Kory.

Mort phoned Kelley and attempted to persuade her to enter into a settlement
with Kelley. She steadfastly refused and advised Mort and Judy Lindsey that
Cohen committed criminal tax fraud. Mort Lindsey was kind enough to
recommend a number of accountants and lawyers to Kelley. I was present
3
4
5
6
7
8
9
when Mort phoned Kelley after speaking with Leonard Cohen and his lawyer. I
advised Mort that the best thing he could do was to explain to his son why he
should remove himself from Kelleys personal business affairs.
85.
In all the years I worked with Kelley, Steve Lindsey had no
involvement with her business or

professional affairs. They separated in 1997 and there was no reason for him to
10
11
12
13
14
15
meet with Leonard Cohen concerning Kelley. I would assume that Lindseys
motivation involved a financial element.
86.
My grandson, Rutger, advised me that immediately following the
May 25, 2005 SWAT incident,

Steve Lindsey phoned him and asked him to go in and sign over or transfer my
16
17
18
19
20
21
daughters house to Leonard Cohen.

87.
Steve Lindsey also called to advise us about the SWAT incident. My
husband advised Lindsey to

pay Kelley what he owed her. Kelley had merely kept her son home from
school. She phoned me during the SWAT incident and explained what was
22
23
unfolding. She was extremely alarmed that armed men had placed Rutger in a
24
compromised position and she felt his life was endangered. Kelley also advised
25
me that no one came to her door and/or explained what was taking place. I
26
27
28
advised Kelley to contact an attorney. Rutger advised me that he told LAPD

that he had just been with his mother, she was in the house alone, he had just
dropped his brother off with Cloris Leachman, and they simply disregarded
what he had to say. Rutger said that due to Steve Lindseys aggressive
3
4
5
6
behavior, his mother did not want him on his property. She called Rutger and
he came home, picked up Ray, and dropped him off at the bottom of the hill. He
also confirmed directly to Steve Lindsey that this was the plan Kelley phoned
me from King Drew. I could not believe what I was hearing. UCLA was five
minutes from her home and LAPD took her to South Central and questioned her
about Phil Spector. Kelley explained that she had no idea how they knew she
10
11
and Phil Spector were friends. I told Kelley to have the doctor phone me if he
12
felt the need to do so. My daughter has no history of mental health issues but
13
this allegation has been used, including by the City Attorney of Los Angeles, to
14
discredit my daughter. I find that somewhat questionable as the City Attorney
15
of Los Angeles serves as LAPDs legal representatives. In any event, I
16
17
immediately assumed that Steve Lindsey and Leonard Cohen were behind this
18
incident. Rutger told me he saw and heard Steve Lindsey lying to LAPD about
19
his mother. Although Rutger had been with his mother earlier, had just driven
20
his brother down the street, LAPD chose not to believe what he told them. I
21
have a very difficult time understanding that situation. I have reviewed the
22
23
King Drew file with Kelley and that is not her file. It is a different Kelly Lynch.
24
The social security number, date and place of birth, and other information did
25
not relate to my daughter. Evidently LAPD lied in the report because Rutger
26
told me the female officer asked him two questions: Are you okay and is your
27
28
mother on any medication? Rutger informed me personally that he told them
he was okay and his mother was on heart medication.
3
4
5
6
88.
Steve Lindsey owed Kelley a tremendous amount of money and had
not repaid her for loans he

took or child expenses she advanced on behalf of Ray and Steves daughter,
Jennifer Lindsey. I am aware that Steve Lindsey assured Kelley continuously
that he would repay her monies loaned to him, 100% of all monies expended on
behalf of his daughter, and 50% of all monies expended on behalf of Ray. It is
10
11
my understanding that these amounts are still outstanding. At the time the
12
custody matter was filed, it was my understanding that Lindsey had financial
13
problems.
14
89.
15
After Kelley and Cohen parted ways, she repeatedly advised me that
he refused to provide her
16
17
with documents in his possession that would allow for the preparation of a
18
proper accounting. As I have stated above, I was present when Leonard Cohen
19
and his daughter, Lorca Cohen, picked up all his files and other property. As I
20
have explained, this information was in the property they removed from our
21
offices. That would include records related to the following: financial, bank,
22
23
24
25
26
tax, royalty statements, sales figures, agreements, and corporate

documentation.
90.
As of the fall of 2004, Leonard Cohen was not broke. He had
received $1 million advance with
27
28
respect to the delivery of Dear Heather. Cohen also planned to tour,
understood Kelley was pursuing a lucrative lithograph deal for him, intended to
3
4
5
6
submit Book of Longing to his publishers, and was well aware of the fact that
Kelley and his representatives were in the midst of the third intellectual
property deal he demanded. Cohen frequently spoke to me about his plans to
tour but advised me not to speak to anyone, and in particular Sony, about that
fact. I was at Kelleys home in 2004 when Kelleys lawyers advised her that
Cohen planned to go on tour to blow the whistle on Neal Greenberg and
10
11
Richard Westin. I suppose when he couldnt coerce Kelley into a settlement,
12
or providing false testimony against his representatives, that he had a back-up
13
plan.
14
15
91.
Leonard Cohen, as Ive stated above, is a shrewd businessman who
oversaw every aspect of his
16
17
business affairs. He was extremely controlling with respect to Kelley. Due to
18
the fact that he was travelling rather extensively, Leonard Cohen personally
19
asked Kelley if she would execute Powers of Attorney which would allow her to
20
act on his behalf in his absence. I was present for this conversation. His
21
lawyer prepared the documents. Cohen was also buying houses for his son and
22
23
girlfriend and needed Kelley to assist with the closings. Kelley did not ask to be
24
in control of Cohens financial affairs and was not. She was placed in a
25
position, through these Powers of Attorney and bank signature privileges, to
26
assist Leonard Cohen. The individual who controlled all of his personal,
27
28
business, financial, and investment affairs was Leonard Cohen. I have never
met an individual as controlling as Leonard Cohen.
3
4
5
6
92.
I was present for numerous conversations between Leonard Cohen
and Kelley regarding his

loans from Traditional Holdings, LLC. On at least one occasion, Leonard Cohen
personally instructed me to phone Richard Westin to advise him to obtain all
information regarding his loans/advances from Neal Greenberg. Cohen also
asked me to advise Westin to prepare any necessary promissory notes or legal
10
11
documents. Neal Greenberg is the individual who invested Cohens money and
12
authorized the distributions from Traditional Holdings and he is the individual
13
who had this information. I frequently informed Richard Westin, Neal
14
Greenberg, and others, that Kelley was not their personal assistant and they
15
should contact whatever representative of Cohens had the information they
16
17
18
19
20
21
needed or wanted conveyed.

93.
Cohen personally asked me to call Richard Westin to ask him if
Kelley would be responsible for

any payments with respect to her promissory note (Traditional Holdings) after
his death. Westin advised me that she would not. I, in turn, conveyed this
22
23
information to Cohen and Kelley. At no time was I aware of a trust with respect
24
to either Blue Mist Touring or Traditional Holdings. I was unaware of any
25
discussions about a trust or Kelley holding her interest in these companies for
26
27
28
the benefit of Leonard Cohen. I personally believe this is something Leonard

Cohen conjured up together with his fabricated story.
1
2
3
4
5
6
94.
Neal Greenberg is the individual who would have been in charge of
loan schedules, profit and

loss statements, and so forth. He would have been in possession of this
information. Kelley was not responsible for preparing and/or disseminating tax,
accounting, financial, investment, or legal documents or forms. I recall Kelley
continually complaining that she found Neal Greenbergs statements to be
incoherent and repeatedly asked him to address things in a manner in which
she and Cohen could understand. She felt he was intentionally obfuscating
10
11
matters by intentionally complicating them. I was present numerous times
12
when Kelley complained to Neal Greenberg and asked him to write things in
13
plain English that she and Cohen could understand. Kelley was also concerned
14
that Greenberg provided Cohen with one statement that listed various
15
accounts.
16
17
18
95.
Leonard Cohen, Neal Greenberg, and Richard Westin continually
advised me and Kelley that all
19
disbursements and expenditures from Traditional Holdings, LLC should be
20
addressed as shareholder loans and required legal documentation. Westin
21
would later recharactize anything that was not a shareholder loan. That is not
22
23
something Kelley or I would have handled. Kelley did not prepare legal
24
documents on Cohens behalf. I am aware of the fact that Kelley was to receive
25
$20,000/year, $24,000/year, and $240,000/year (from profit that was supposed
26
27
28
to be distributed in accordance with Cohen and Kelleys proportionate

ownership interest) in distributions from Traditional Holdings. These monies
were addressed in the corporate records and management agreement Richard
Westin prepared. Richard Westin explained to me personally that $44,000 was
3
4
5
6
being distributed so that Kelley could repay her promissory note and $240,000
was being distributed to her yearly for potential taxes or tax consequences.
Westin also advised me personally that Kelley should receive 100% of the
profits. I do not know what was ultimately decided Kelley was unable to obtain
profit and loss statements from Neal Greenberg. I followed up on her requests
with Neal Greenberg.
10
11
12
96.
I visited Mt. Baldy on numerous occasions with my daughter and
Cohen. In 1996, I was present
13
when Leonard Cohen took formal vows to become a monk. I was frequently in
14
contact with Cohen when he visited Mt. Baldy. I handled interview requests
15
and frequently scheduled interviews. Kelley and I assisted Cohen when Armelle
16
17
Brusq was filming her documentary, in Los Angeles and Mt. Baldy, called Spring
18
of 1996. I personally visited Leonard Cohens cabin which was outfitted with a
19
recording unit, phone, fax, and computer.
20
21
97.
Leonard Cohen was not actually in a strict Buddhist retreat. It was
my understanding that
22
23
Cohens stay on Mt. Baldy was a working retreat and Cohen explained to me
24
that he was felt he was taking far too many drugs and drinking heavily and
25
meditation helped him with those issues.
26
27
28
98.
During his Mt. Baldy phase, from 1994 through 1998, Leonard
Cohen was frequently in
Los Angeles. Joshu Sasaski Roshi had a center in Los Angeles and would stay
there. Cohen had a home in Los Angeles. Kelley and I also assisted two Robert
3
4
5
6
the Fan, two women who released a periodic Leonard Cohen newsletter, and his
fan based website hosts. I also handled the news clippings generated by
Cohens press clipping service and would keep maintain the notebooks they
were stored in. I was not paid by Leonard Cohen for any of my services while
in my daughters employ and I did a tremendous amount of work on his behalf.
Leonard Cohen was extremely obsessed with his news coverage, record and
10
11
12
13
14
15
book sales and reviews, and continuously provided various fan websites with
materials I would mail or FedEx on his behalf.
99.
I initially opened the letters Neal Greenberg sent containing the
IRS warnings. I found it rather

odd that Greenberg didnt email these letters directly to Leonard Cohen if they
16
17
were so urgent. I believe these letters were classic cover your ass letters but
18
the IRS warnings were of concern. I was
19
present when Kelley read these letters to Cohen, heard him advise her not to
20
discuss his future income with Greenberg, and heard Kelley advise Cohen that
21
she was concerned about the IRS warnings, Richard Westin, and the
22
23
outstanding loans or advances. I personally faxed these letters to Cohen. Of
24
course, I recall this because most people do not receive letters about potential
25
IRS DANGERS. Cohen assured her that he intended to repay his loans in full
26
27
28
with interest and there was no need to be concerned. I was under the
impression that Neal Greenberg sent these letters to cover himself legally and
to address serious concerns about the Internal Revenue Service. I found
Greenbergs conduct increasingly disturbing. He personally informed me that
3
4
5
6
Leonard Cohens loans were dangerous to Traditional Holdings and had to be

repaid. I asked him why such complicated structures were created. Greenberg
advised me that this is what Leonard Cohen wanted. Cohen demanded stock
deals. I repeatedly heard Kelley, Leonard Cohens lawyers, Greg McBowman,
Sony, and others, complain about the stock deals he demanded.
100.
As I have stated above, I would sit with Kelley while she worked
10
11
and, in particular, when
12
she was on the phone with Cohen and others. She would frequently ask me to
13
provide her with a file or documents. This is how we worked. Many of these
14
calls took place on a speaker phone. Cohen would frequently come into the
15
office and sit with me and Kelley before going down the hall to the office she
16
17
provided him. I continually heard Leonard Cohen tell my daughter that he
18
would compensate her for his office and other expenses. I do not believe he
19
ever did.
20
21
101.
In the fall of 2004, Kelley and Cohen received a letter from Richard
Westin advising them
22
23
that the IRS might inquire as to certain corporate tax related matters. I was
24
present when Kelley phoned Cohen to discuss this letter. Kelley was extremely
25
concerned about the issues raised in this letter. Cohens lawyers and
26
27
28
representatives handled all accounting and tax matters on behalf of these

entities.
1
2
3
4
5
6
102.
I specifically recall Kelley discussing the Traditional Holdings, LLC
management
agreement with Leonard Cohen. Richard Westin prepared this document.
They reviewed the fact that she was to receive $24,000/year, $20,000/year and
$20,000/month. It was my understanding that these amounts were being
provided to Kelley for potential tax liabilities, to repay the promissory note, and
in accordance with the corporate books and records. I place a fully executed
copy, with Kelley and Cohens signatures, of this agreement in the corporate
10
11
file. Leonard Cohen and/or his daughter removed that file from our offices.
12
This same file contained a fully executed copy of the non-revocable assignments
13
to Blue Mist (that were to be transferred), Kelleys fully executed promissory
14
note, copies of minutes, faxes from Westin, and other documents.
15
103.
I was present when Kelley and Cohen discussed the repayment of
16
17
her promissory note
18
and the profit and loss sharing with respect to this entity. Leonard Cohen
19
understood that profits and losses would be distributed in accordance with
20
ownership interests. After Ken Clevelands alarm over Sonys $7 million 1099
21
to Cohen, Kelley asked Richard Westin to prepare a letter explaining these
22
23
corporate structures and her role in connection with them. Westin faxed a
24
letter to our office and I, in turn, distributed copies to Kelley and Cohen. I
25
recall Kelley becoming upset after learning of things in hindsight that had not
26
27
28
been explained to her previously. Richard Westin assured me that things would
smooth out with these complex matters. Kelley routinely complained that she
could not believe how many complicated corporate entities there were and had
no idea why anyone would ever create such an unnecessarily complicated
3
4
5
6
scenario. By 2004, Kelley had no idea where money for Cohen to pay his bills
was to come from. She and I repeatedly asked Cohen, Greenberg, and Westin.
We had no idea what entity or account would pay Cohens tax bills. I personally
left messages for all parties and frequiently never heard back from Greenberg
or Westin. It was thoroughly frustrating for both of us. If Cohens accountant
prepared one of the charitable trust tax returns, Kelley or I would have to call
10
11
Neal Greenberg and ask them to provide a check from the entity to pay
12
Cleveland. The amount of work this caused for our office was inconceivable.
13
Kelley frequently expressed her frustrations with Cohen. At one point in the
14
summer of 2004 (he had not yet received the advance on Dear Heather),
15
Cohen informed us that he was dissatisfied with Neal Greenberg and did not
16
17
18
19
20
21
plan on having him invest future income.

104.
In September 2004, after receiving the alarming letter from
Richard Westin, Kelley

contacted Betsy Superfon. Superfon referred Kelley to her accountant, Dale
Burgess, and Kelley decided to fire Ken Cleveland and work with Dale Burgess
22
23
at that time. He ultimately referred her to a law firm. At that time, Kelley had
24
me phone Ken Cleveland, who I spoke with directly, to advise him that she
25
would be working with another accountant and would no longer require his
26
27
28
services and Burgess would prepare and file her 2003 return. Clevelands work
with Kelley was limited to preparing her tax returns on a yearly basis. We
provided him, Cohen, and other accountants or business managers with
whatever information they requested.
3
4
5
6
105.
Leonard Cohen was extremely supportive of my daughters work
with respect to the

development of Amazing Card Company, LLC. He advised her that he would
help her in any way possible and even offered to invest in the company. I was
present when Kelley asked Cohen for a personal loan with respect to this
company. He offered to lend her $100,000 and instructed me to type a fax
10
11
asking Neal Greenberg to make this money available to her. I typed it and
12
Leonard Cohen personally signed that document. When Kelley asked Cohen if
13
he would like to handle this as a loan or issue a 1099, he advised her that it was
14
a gift. I personally faxed this document to Neal Greenberg. There were times
15
when Leonard Cohen was quite generous with my daughter. I do believe that
16
17
18
19
20
21
he really loved her and he continuously advised me that he did.

106.
Kelley and I were confused when checks for her would be made
payable to Kelley with

the notation f/b/o Leonard Cohen. When I phoned Tim Barnett in Neal
Greenbergs office, I was advised that this was their inter-office policy. There
22
23
was ongoing confusion as to how Kelley should sign documents. At times she
24
was asked to sign as the corporate owner; at other times she was advised to
25
sign under the Power of Attorney. Kelley followed the instructions of Leonard
26
Cohen, Neal Greenberg, and Richard Westin.
27
28
1
2
3
4
5
6
107.
Leonard Cohen had extraordinary expenses for an individual who
had not delivered a

studio album since 1993. The next studio album was delivered sometime in
2001. He had homes to maintain in Los Angeles, Greece, and Montreal. He
had a number of assistants including, but not limited to, Betsy Perks in Los
Angeles and Lee Taylor in Montreal. He had numerous legal and business
advisors. His household in Greece was cared for by his housekeeper who was
also compensated for her services.
Cohen gave the mother of his children
10
11
substantial monthly gifts. He loaned many people money. Cohen personally
12
bought homes for his son and girlfriend and a commercial building for his
13
daughter, Lorca Cohen. Cohen felt that owning a store might help Lorca Cohen
14
who had been going through a difficult time. I frequently spoke to Cohen about
15
expenses related to his son and daughter. Leonard Cohen also paid the
16
17
mortgage on Lorca Cohens Melrose Avenue property and spent quite a lot on
18
furniture purchases from her business. I recall extraordinary amounts of
19
money being spent to renovate Anjani Thomas home and garden. He also gave
20
extravagant gifts to people. For example, he bought Jill (Elton Johns
21
managers assistant) a $17,000 statue from a Don Henley charitable event and
22
23
Anjani Thomas an $18,000 baby grand piano. He frequently instructed me to
24
advise Kelley to have checks or wires sent to various family members and
25
friends. Leonard Cohen, as Ive said, can be generous and he was particularly
26
27
28
generous with his close friends like Eric Lerner, Mort Rosengarten, Sandra
Alvarez (his housekeeper), and members of the Zen community. I thought it
was very kind of him to provide the funds for his housekeeper and a Zen monks
children to attend private school. He gave a great deal of money to various zen
3
4
5
6
centers. Cohen personally informed me that if he died he wanted to make sure

Kelley was properly cared for. I believe this had something to do with why he
didnt name Lorca and Adam Cohen beneficiaries in connection with the
Traditional Holdings dealings. And, I also believe that he had a difficult time
explaining this to Anjani Thomas, who was exceedingly jealous of my daughter
from what I could tell, after Kelley and he parted ways. I have heard that Ken
10
11
Cleveland informed my daughter that he thought this situation sounded like
12
Enron, could not believe a court would grant Lindsey custody of their child, and
13
felt that Anjani Thomas had a role in what happened to Kelley. I have watched
14
Anjani Thomas in action. She spent months convincing Cohen to remove Kelley
15
from his estate and health care planning instruments. I know that this caused
16
17
alarm for Lorca Cohen and Esther Cohen and spoke to both of them about
18
Thomas. They both felt she was using Leonard Cohen for his money and
19
couldnt believe how fast she was able to convince him to buy her a house, pay
20
for recording sessions, and so forth. I never trusted her with my daughter for a
21
moment. She relentlessly badmouthed Leonard Cohen in my presence which I
22
23
found disturbing given the gifts he was bestowing upon her By the time Cohen
24
and Kelley parted ways, Anjani Thomas was using Kelley as her personal
25
manager, household assistant, gardener, and slave. It was outrageous.
26
27
28
108.
With the proceeds from the sale of Stranger Music, Inc. in 1996,
Leonard Cohen donated
$500,000 to the Mt. Baldy Zen Center. His home in Canada required upkeep
and he paid his assistant. After Cohen was advised to close his Canadian bank
3
4
5
6
accounts, I handled the ordering of Canadian drafts. That is how Cohen elected
to handle his Canadian bills. He helped support numerous women in his life
including Jung Kim, a young woman who became increasingly disturbed with
Leonard Cohen. He advised me that Jung Kim, who visited our offices, was
accusing him of stalking her with a check. Cohen also gave Dominique
Issermann a gift of $100,000. These are gifts that he definitely did not want
10
11
brought to the attention of his children or Suzanne Elrod. He was concerned,
12
as he explained to me many times, that Suzanne Elrod and his children would
13
pressure him for more money.
14
15
109.
It was my understanding that Leonard Cohen could not live in
Canada due to tax and
16
17
residence problems. I recall serious issues arising with respect to his green
18
card. After abandoning his U.S. green card, he was advised (and I frequently
19
handled these calls and files) that Canada could view him as a resident. Cohen
20
decided not to return to Canada and to reapply for a U.S. green card which he
21
finally received at some point around 1993. It was my understanding that
22
23
Kelleys brother-in-law, Van Penick, advised Cohen that he could have residence
24
and tax issues in Canada and informed him that he should rent out his
25
Canadian residences, give up his temple membership, and close his bank
26
27
28
accounts. At that time, Cohen decided to close his Canadian bank account and
instructed me to pay his Canadian bills with drafts ordered through City
National Bank. Cohens assistant, Lee Taylor, would fax his Canadian bills to
me and Cohen approved all payments. Cohen chose not to rent his houses or
3
4
5
6
relinquish his temple membership.

110.
I also handled calls and paperwork related to Cohens personal
legal matters. In 2003,
problem arose for Cohen with one of his former girlfriends, Ann Diamond. Ann
Diamond heard from a friend of Cohens in Montreal, Freda Guttmann, that
Lorca Cohen advised her classmates that Leonard Cohen molested her. She
10
11
published this information on her website and Leonard Cohen was extremely
12
disturbed. He demanded that Lorca Cohen, who had been staying in Montreal
13
around that time, return to Los Angeles and it was at this time that he bought
14
the Melrose property. Kelley contacted Van Penick, and ultimately
15
recommended that he advise Ann Diamond that the situation upset Lorca
16
17
Cohen tremendously. Cohen was concerned that these allegations would find
18
their way into the newspapers. This situation was ultimately resolved but I do
19
recall Leonard Cohen began bad-mouthing Ann Diamond and advising people,
20
including me and Kelley, that Diamond was stalking him. We never heard from
21
or saw Ann Diamond and felt Cohen went on the offensive due to the public
22
23
24
25
26
27
28
accusations.
111.
It is my understanding that in June 2005, Neal Greenberg filed a
lawsuit against Leonard

Cohen and his lawyer for threatening to take or take actions against him and
his companies which were unlawful. Greenberg raised allegations relate to
bribery and intimidation of a witness. That witness was my daughter, Kelley
Lynch, and she conveyed much of Cohen and his lawyers tactics to me. The
3
4
5
6
intermittently offered her generous settlements or threatened her. Steve

Lindsey often conveyed these threats to Kelley in the presence of her sons. I
personally witnessed this on more than one occasion. I also witnessed Steve
Lindsey becoming completely aggressive and unhinged with respect to my
daughter and grandsons. I personally advised him that I would contact the
police if he continued to threaten, harass, or abuse any of them. It is
10
11
inconceivable to me that LA Superior Court would remove custody of my
12
grandson from his mother and give him to his highly abusive father. LA
13
Superior Court caused inconceivable harm when they made this decision.
14
15
112.
It was my understanding, from what I witnessed and heard, that
Cohen was attempting to
16
17
recover money from Neal Greenberg and Richard Westin. Kelley repeatedly
18
advised me that she was concerned that Cohen planned to engage in insurance
19
fraud. At one point, I was present when Kelley had a conversation with her
20
lawyer wherein she was advised that they spoke to Cohens lawyer. This
21
lawyer, who Kelley was introduced to by Steve Lindsey, was informed by
22
23
Cohens lawyer that if Kelley assisted them, Cohen would take the position that
24
Kelley was used as a pawn. If Kelley did not assist Cohen, he would take the
25
position that she orchestrated the corporate and tax mess he has found himself
26
27
28
in. Leonard Cohen is the individual who controlled my daughter. He had an

entire team of representatives who worked for him personally. Kelley did not
handle anything having to do with Cohens accounting, IRS matters, corporate
matters, financial planning or investments, or the preparation of legal or
3
4
5
6
corporate documents. She most certainly did not orchestrate this nightmare.
113.
I personally scheduled meetings Kelley held with City National
Bank and others with
respect to investing the proceeds from the Traditional Holdings, LLC deal. She
was concerned with what she felt were aggressive and reckless investment
strategies.
10
11
12
114.
At one point in the spring of 2005, Betsy Superfon stopped by
Kelleys house when I was
13
visiting. Superfon explained to us that Cohen felt remorseful, terrified, and had
14
informed Superfon that Kelley was the love of his life and she could have
15
whatever she wanted.
16
17
18
115.
At another point, Betsy Superfon advised me that she phoned
Robert Kory and asked
19
him, on behalf of Kelley, to fax through the type of deal they had in mind. Kory
20
told Superfon that this was not the type of deal one could fax. Superfon felt the
21
deal was illegal.
22
23
24
25
26
27
28
116.
Leonard Cohen and Kelley never had a brief intimate dating
relationship; were never in

any type of relationship other than a business relationship and familial type of
friendship. Kelley frequently complained of Cohens sexual harassment,
unprofessional conduct, and indecent exposure. It is my understanding that
Leonard Cohen has registered a Colorado restraining order with Los Angeles
Superior Court as a domestic violence order. Kelley and Cohen were never in
3
4
5
6
any type of domestic relationship and there was no domestic violence. It is my

personal opinion that Cohen has attempted to address Kelleys public
allegations of sexual harassment, inappropriate conduct, and indecent exposure
including when Cohen forced her to read business and legal documents to her
while he bathed. Kelley was so disturbed by Cohens inappropriate conduct
towards her that she advised me that she would no longer meet with him alone.
10
11
12
13
14
15
She was extremely upset when he looked at internet images of people

defecating on one another in front of her.
117.
From approximately 1995 until we moved our offices, Kelleys
physical business address

was 1044 S. Keniston Avenue, Los Angeles, California and her business P.O. Box
16
17
address was 419 N. Larchmont Blvd., Suite 91, Los Angeles, California. These
18
addresses did not belong to either Leonard Cohen or any corporate entity.
19
Leonard Cohen advised me and my daughter that he intended to reimburse her
20
for the space he used in our offices. It was my understanding that following
21
Cohens planned tour, he and Kelley intended to hire an accountant to prepare
22
23
an accounting that would address corporate ownership interests, commissions
24
due her for work she did as his personal manager from 1988, all loans and/or
25
advances each of them had received, value of her intellectual property assets,
26
27
28
and address any monies either of them expended on behalf of one another. For
example, Kelley personally paid for publicists and independent record
promoters on behalf of Adam Cohen. Leonard Cohen assured Kelley that he
would reimburse her for those expenses should Adam Cohen not be able to do
3
4
5
6
so himself.
118.
It was always my understanding that Leonard Cohen hired Neal
Greenberg, Richard
Westin, and others, to create companies that would reduce Cohens tax
consequences. These individuals worked for Leonard Cohen. They frequently
attempted to use my daughter as their personal assistant. She found this
10
11
offensive and advised them that she was not their personal messenger boy and
12
they should contact whomever they needed, for whatever they needed, directly.
13
It is my opinion that both Neal Greenberg and Richard Westin attempted to use
14
Kelley to meet other wealthy people in Los Angeles. They were interested in
15
investing or working with Betsy Superfon, Ron Burkle, and evidently learned
16
17
that Kelley carpooled with Susan Disney. I was frequently present when
18
Richard Westin would phone my daughter at home. At one point, he decided to
19
visit Los Angeles and Yongzin Rinpoche, who was staying with Kelley advised
20
her to put him back on the plane because as he was a complete pain in the
21
ass. During his visit, Richard Westin made advances towards a friend of
22
23
24
25
26
27
28
Kelleys who later informed me that she felt completely used by this man.
119.
It was my understanding that Cohen would form Traditional
Holdings, LLC to use in

connection with the second Sony sale. Initially, Sony began their due diligence
with Blue Mist Touring Company, Inc. The Grubman firm and Sony were both
aware that Leonard Cohen and Kelley both had an ownership interest in Blue
Mist and the intellectual property assets. Eventually, Cohen and his
3
4
5
6
representatives were concerned about certain tax matters related to the use of
Blue Mist Touring Company, Inc. Kelley repeatedly advised me that she felt
these deals were unnecessarily complex and the corporate and tax matters
inconceivably complicated and incoherent. She grew increasingly frustrated
and suspicious. At one point, Kelley informed me that, due to the fact she could
not get answers from Cohens representatives, she intended to contact the
10
11
Internal Revenue Service directly to ask them to review the corporate
12
structures and deals. She was also alarmed and the number of IRS inquiries in
13
connection with Cohen related matters and entities. In fact, she advised me
14
that she wished she could ask an IRS agent who found Richard Westins
15
conduct evasive to visit our offices and review the files for himself. From the
16
17
winter of 2002, when issues arose with respect to inadvertent 1099s, a tax
18
audit, and other related matters, Kelley was extremely concerned about the
19
activity of Leonard Cohen, Richard Westin, Neal Greenberg, and others.
20
21
120.
At one point, I was present for a conversation where Richard Westin
advised Kelley to
22
23
rip up Blue Mist corporate assignments. Kelley hung up the phone and asked
24
me to make copies of the assignments and advised me that she felt she was
25
being asked to do something illegal. She was compensated with stock in Blue
26
Mist for services she rendered.
27
28
1
2
3
4
5
6
121.
It was my understanding that Blue Mist Touring would transfer
certain intellectual
property assets to Traditional Holdings in exchange for an annuity obligation to
Cohen that would begin in or around January 2012. Traditional Holdings would
then sell the assets it received from Blue Mist to Sony. Leonard Cohen
personally signed the Annuity Agreement. He understood that he could take
loans, had to repay them, and I must have heard from Cohen and his
representatives 1,000 times that Traditional Holdings, LLC bypassed his estate.
10
11
I was extremely familiar with Cohens estate planning documents. I never saw
12
anything having to do with Traditional Holdings, LLC, Blue Mist Touring
13
Company, Inc., or Old Ideas, LLC that would indicate that they were assigned to
14
Leonard Cohens revocable family trust (for estate planning purposes). I do not
15
believe that Leonard Cohens personal bank account, or any investment
16
17
18
19
20
21
account with Neal Greenberg, was assigned to this revocable trust. Leonard
Cohen advised me that he did not want to sign his personal checks as trustee.
122.
I never saw any formal documents transferring, selling, and/or
assigning Blue Mist

Tourings intellectual property assets to Traditional Holdings, LLC. I was,
22
23
however, present when Kelley spoke to Richard Westin who advised her that he
24
would rip up the non-revocable assignments to Blue Mist Touring Company, Inc.
25
When Kelley hung up the phone, we discussed her shorthand notes from that
26
27
28
conversation. Kelley felt she was being asked to do something illegal and asked
me to make copies of the non-revocable assignments to take home. She was
completely alarmed by this conversation with Richard Westin. These
assignments, and all other corporate records, were in the business files
3
4
5
Leonard Cohen and/or his daughter removed from our offices.

123.
transferred assets to
6
7
8
It is my understanding that Blue Mist Touring Company, Inc. never
either LC Investments, LLC or Traditional Holdings, LLC.

124.
I was present when Leonard Cohen personally asked Kelley to
phone Richard Westin to
10
11
ask him if she could be compensated with 15% of LC Investments, LLC if they
12
were transferring assets from Blue Mist Touring Company, Inc. to LC
13
Investments, LLC. Richard Westin wrote and said he felt she should have been
14
compensated with 15% of LC Investments, LLC. However, after Cohen elected
15
not to pursue the CAK bond deal, there was no real purpose for LC
16
17
Investments, LLC. Out of convenience, LC Investments, LLC continued to
18
collect the SOCAN (and possibly other) royalties. Leonard Cohen personally
19
collected the royalty income related to the artist recording contract. These
20
contracts (SOCAN, writers share, and artist recording contract as well as the
21
book publishing and other assets) were assigned to Blue Mist Touring Company,
22
23
24
25
26
27
28
Inc.
125.
At one point, Leonard Cohen and Richard Westin advised us to
begin depositing royalty

income to Blue Mist Touring Company, Inc. Richard Westin later personally
advised me that we should stop depositing the royalty income to Blue Mist
Touring Company, Inc. and wrote a letter addressing the fact that these
deposits should be viewed as inadvertent, 1099s should be issued from Cohen
3
4
5
6
personally with respect to this income, and this information was forwarded to
Ken Cleveland. It was my personal belief that this activity was taking place
due to the fact that Leonard Cohen was pursuing numerous types of asset
deals, had not made a final decision, and no one was clear as to what entity
would be used to pursue the potential deals.
126.
Leonard Cohen was explicitly warned that Kelley would have to
10
11
participate in the
12
Traditional Holdings, LLC to avoid allegations that he participated in self-
13
dealing. He understood that this situation place many burdens on Kelley,
14
including tax burdens. After signing the Indemnity Agreement, Leonard Cohen
15
personally advised me that he was grateful for Kelleys assistance. He and I
16
17
discussed the fact that regardless of ownership interests with respect to
18
Traditional Holdings, LLC he felt completely comfortable because he trusted
19
Kelley and there was an annuity obligation. At Cohens request, I prepared
20
copies of all corporate records for Cohen and placed them in a file which he
21
took home with him. Those documents included all corporate records
22
23
(including the Articles of Organization and Operating Agreement); signed and
24
notarized copies of the Annuity Agreement and Kelleys Indemnity Agreement;
25
notarized copy of Kelleys Promissory Note with Traditional Holdings; stock
26
27
28
units that were issued; the stock ledger; and copies of the faxes or emails
between Cohen, Kelley and Richard Westin with respect to the proposed
structure, their questions, and Westins additional explanations. Cohen advised
me that he needed these documents because he planned to review them with
3
4
5
6
Greenberg and Westin.

127.
I was present for conversations Kelley had with Cohen, as well as
Greenberg and Westin,
where she was advised that she would receive funds necessary to pay taxes,
repay the promissory note, and pay her a salary. Richard Westin informed me
on many occasions, and this was reflected in numerous documents, that Kelley
10
11
would receive $24,000 and $20,000 per year from Traditional Holdings, LLC.
12
These two amounts, totaling $44,000, would be used to repay Kelleys
13
promissory note. An additional amount of $20,000 per month (which could be
14
paid monthly or yearly) was to be distributed to Kelley to be used for whatever
15
taxes she was advised to pay. Westin also explained to me that Kelley was
16
17
entitled to 100% of all profit and loss. I was present when this issue arose
18
again in or around March 2002 between Cohen, Kelley, Westin, and Greenberg.
19
Kelley informed me that Westin advised her and Cohen that the profit and
20
losses would be distributed in accordance with their respective ownership
21
interests: 99.5% to Kelley and .5% to Leonard Cohen.
22
23
24
25
26
27
28
128.
Neal Greenberg and Richard Westin repeatedly advised me that
Kelley, as an owner of
Traditional Holdings, LLC had authority to sign off on loans and/or distributions
from this entity. I personally spoke to each of them about this matter due to the
fact that I handled the paperwork. I also reviewed this with Kelley and Cohen.
1
2
3
4
5
6
129.
At Kelleys direction, I specifically spoke with Richard Westin and
Neal Greenberg about

the need for them to document the loans and distributions from Traditional
Holdings, LLC. I was assured that Richard Westin would prepare any and all
necessary promissory notes and understood that Neal Greenberg was the
individual in possession of these details. Kelley did not handle loan schedules,
financial matters or documents, investments, or legal documents including
promissory notes. This was not her area of responsibility. She transmitted
10
11
12
13
14
15
information to Cohen and his representations as requested and received.

130.
Richard Westin and Neal Greenberg both personally advised me
that for tax purposes all

distributions from Traditional Holdings, LLC should be characterized as
shareholder loans and Richard Westin would later recharacterize them. It was
16
17
my understanding that these shareholder loans would be repaid with interest
18
once the third Sony deal closed. I specifically discussed this matter with Kelley
19
and Cohen. They both understood that there would be substantial income from
20
the third Sony deal, sales of Dear Heather, the lithograph deal Kelley was
21
negotiating, and Cohens tour. Cohen repeatedly admonished Kelley and I not
22
23
to discuss his future income with Neal Greenberg and did not want him to have
24
information regarding his plans to tour. He also did not want Sony pressuring
25
him about his plans to tour.
26
27
28
131.
Kelley was continuously concerned about the Traditional Holdings,
LLC tax
consequences with respect to phantom income being shifted to her and with
respect to corporate distributions. Richard Westin personally assured both of
3
4
5
6
7
8
9
us, on numerous occasions, that the corporate distributions were not taxable
and he would provide Kelley with all necessary tax documents.
132.
Richard Westin was extremely concerned about Leonard Cohens
level of borrowing
from Traditional Holdings, LLC. He expressed concern about potential IRS
inquiries. At one point, Westin faxed through minutes he prepared for
10
11
Traditional Holdings, LLC. Those minutes addressed the fact that Cohens level
12
of borrowing was excessive and should be discouraged. All communications
13
from Richard Westin and others were placed on Leonard Cohens desk, faxed to
14
him, and I was frequently present when he and Kelley reviewed business and
15
legal matters. Leonard Cohen was well aware of the fact that his loans or
16
17
18
19
20
21
advances from Traditional Holdings, LLC had to be repaid with interest.

133.
Neal Greenberg also continuously expressed concern about
Leonard Cohens level of

borrowing from Traditional Holdings, LLC and his other retirement accounts.
Greenberg personally advised me that he believed Cohen used these accounts
22
23
24
25
26
as his personal piggy bank. When I conveyed this message to Cohen, he was
livid that Neal Greenberg would question how he chose to spend his money.
134.
In the spring of 2005, Kelley spoke to an IRS agent about her
suspicions with respect to
27
28
Cohen and numerous entities. Agent Betzer advised my daughter to bring
these allegations to the attention of the IRS fraud unit. It is my personal belief
3
4
5
6
7
8
9
that Leonard Cohen retaliated against Kelley for refusing to assist him, provide
testimony about his representatives, and reporting allegations of criminal tax
fraud to IRS. I would assume he was concerned about his tax situation in
Canada as well.
135.
I was present when Kelleys lawyer advised her that Cohen
intended to go on Oprah to
10
11
promote his new album and tour. At that time, he intended to give interviews
12
to reporters in order to blow the whistle on Neal Greenberg and Richard
13
Westin.
14
136.
15
Cohen continued to pressure Kelley into assisting him in going after
Neal Greenberg,
16
17
Richard Westin, and other representatives of his. It was my understanding that
18
former DA Ira Reiner was brought into handle mediations between Leonard and
19
these parties. Kelley refused to participate.
20
21
137.
I believe Cohen felt he could coerce Kelley into serving as a witness
for him. Cohen used
22
23
24
25
26
the monies he owed her to pressure her into participating in mediations with
him. Due to the fact that she refused to assist him, he withheld monies due her.
138.
Leonard Cohen is the individual who intended to capitalize on and
benefit from the sale
27
28
of intellectual property. It is my personal opinion, based on conversations with
Cohen, that he used aggressive tactics to avoid paying taxes. I also personally
3
4
5
6
7
8
9
believe that Leonard Cohen cannot reside in Canada due to tax and residence
problems.
139.
I am aware of the fact that, at various points before filing this
lawsuit, Cohen offered

Kelley 50% community property and agreed to pay her the commissions she
was due and provide her with compensation that equaled the value of the
10
11
intellectual property assets she owned. Steve Lindsey advised Kelley and me
12
that he understood that Cohen and Kory raised the possibility of providing my
13
husband and myself with $2,000/month walking around money. Kelley was
14
completely confused as to why Cohen would offer her palimony.
15
140.
In or around January 2005, my husband and I babysat Ray while
16
17
Kelley had dinner with
18
her lawyers and accountant who had flown in from San Francisco. When she
19
returned from this meeting she again advised us that Cohen offered her 50%
20
community property and would forgive any and all loans or obligations if she
21
would assist him in going after his representatives.
22
23
24
25
26
27
28
141.
I was present when Betsy Superfon advised Kelley that Cohen felt
that Greenberg was a

criminal. Superfon pleaded with Kelley to cooperate with Cohen for the sake of
her heart, health, and children. She promised Kelley that she could settle this
situation for her immediately and informed us that Cohen was trying to get
Kelley out of this situation. Kelley asked Superfon to phone Cohen or his
lawyer and ask them to fact through the deal they had in mind.
3
4
5
6
142.
Based on what I witnessed at the time, it was my understanding
that Cohens conduct

with respect to my daughter grew increasingly aggressive. One of Neal
Greenbergs lawyers advised Kelley that Cohen planned to crush her, use
restraining orders against her, and planned to prevent her from serving as a
credible witness with respect to Cohens affairs.
10
11
12
143.
Cohen, who appeared to conspire with Steve Lindsey and others,
has used vicious tactics
13
to terrorize, silence, and disparage Kelley. They also coordinated a custody
14
matter which was clearly meant to pressure Kelley into entering into an
15
agreement with Lindsey and Cohen.
16
17
18
144.
I was present when Child Services visited Kelley years earlier. A
case worker advised us
19
that she might bring charges against Lindsey and would require him to attend
20
anger management classes. She also advised us that she felt Lindsey was
21
harassing Kelley and he personally had called her (the caseworker) in a rage.
22
23
Lindsey advised the case worker that Kelley was a great mother. Kelley had a
24
lawyer present for that meeting as these are the types of tactics used in
25
custody matters and litigation.
26
27
28
145.
In the Spring of 2005, Kelley decided to permit Neal Greenbergs
lawyers to review three
huge boxes of evidence. I helped Kelley review, pack, and ship the boxes to
Boies Schiller. It was my understanding that this law firm advised Kelley that
3
4
5
6
Cohen and Kory were attempting to engage her in criminal conduct. They
advised her to contact Los Angeles District Attorney Brian Bennett and ask him
to wire her for any meetings with Cohen and/or Kory. Brian Bennett was an
investigator on the Phil Spector matter. I was familiar with him because he
visited Kelley, advised her that an anonymous tip was made to the DA about her
friendship with Phil Spector, and Kelley called me during their meeting. She
10
11
12
13
14
15
asked if I recalled any incidents where Phil Spector held a gun on her. My
husband and I recalled no such incident.
146.
I worked with my daughter until the Spring of 2005 when my
husband and I moved to

Texas. I reviewed many documents, emails, and am familiar with this situation.
16
17
I am aware of the fact that Leonard Cohen attempted to pressure Kelley into a
18
deal with him and wanted her to testify against his advisors. He used financial
19
tactics and the custody matter to coerce her. Leonard Cohen testified during
20
my daughters 2012 trial that he was the author of her misfortune. There is
21
nothing poetic about what Cohen has done to my daughter, grandsons, or
22
23
24
25
26
27
28
family members.
147.
Kelleys phone was shut off in the summer of 2005. Paulette Brandt
would contact me
from time to time to let me know how Kelley was. Paulette and I discussed the
fact that Kelley was wearing her hair very short and dark brown. She thought
Kelley looked darling. Kelley and I previously had our hair done by Mario Lara.
Obviously, as Kelley could not afford to pay her phone bill, she was unable to
3
4
5
6
hire a hair dresser or even pay for a cab to attend a hearing had she been
aware of any. I never heard of Robert Kory or Michelle Rice in all the years I
worked with Kelley and Leonard Cohen. I would assume their motives for
relentlessly targeting my daughter with Cohen are financial. I understand that
Robert Kory has now replaced Kelley as Cohens manager.
148.
I understand that Leonard Cohen has alleged that Kelley bought her
10
11
home with his
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money. Kelley worked for Adam Cohen as well. The year she bought her home,
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she made substantial fees for deals she did with respect to Adam Cohens
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recording and publishing. Kelley also had a retirement account that she closed
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in order to purchase this house. Steve Lindsey told me that Leonard Cohen
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advised him that Kelley also bought Yongzin Rinpoches house for him. Kelley
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did not buy Yongzin Rinpoches house and he personally confirmed this for me.
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Kelley has been victimized by this pattern of relentless lying and intentional
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rumor mongering. That is precisely how Leonard Cohen operates.
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149.
Cohen is a shrewd manipulator and understands the use of
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propaganda with the news
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media. He made false, disparaging, and defamatory remarks about my
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daughter that have been repeated ad nauseum in the media. It is my personal
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belief that Cohen, who was in the midst of a European tour in August 2008,
flew into Boulder, Colorado to obtain a restraining order against Kelley due to
the fact that she was in touch with journalists, posted factual refutations to his
slanderous statements online, and due to the fact that in July 2008 Ann
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Diamond (an old friend of Cohens) wrote an article she planned to present to
Rolling Stone about the situation between Cohen and Kelley. Diamond posted
this article online. Cohen is obsessed with how people perceive him.
150.
Leonard Cohen has caused substantial damage to my daughter. He
has created economic

hardships for her and damaged her reputation.
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151.
I am extremely concerned that Leonard Cohen, and others, will
retaliate against me for
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providing this declaration. My daughter has been relentlessly slandered by
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Leonard Cohen. It is my opinion that he set out to undermine her credibility
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and destroy her reputation. I am aware that both of my daughters, grandsons,
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Kelleys friends, and others have been relentlessly targeted and harassed by
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strangers who include at least one of Leonard Cohens fans. Paulette Brandt
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has been relentlessly targeted and expressed her concern to me when she
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received a telephonic death threat. Kelley has gone to LAPD, FBI, and other law
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enforcement agencies with respect to these threats. I have personally advised
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her to document everything for IRS, FBI, and others. I was present in 2005
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when His Holiness Kusum Lingpa advised my daughter to begin documenting
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everything. I also spoke with Agent Sopko, U.S. Treasury, in 2005. It is my
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understanding that, two years after Kelley first reported the allegations re.
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Cohens tax fraud to IRS, Agent Sopko flew into meet with her and then advised
Kelley to contact Agent Luis Tejeda of the IRS in Los Angeles.
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152.
Leonard Cohen is the individual who controlled my daughter, the
corporate decisions,
handling of tax matters and these deals, bank and financial accounts, etc.
Leonard Cohen is a shrewd micro-manager who contacted my daughter
constantly every day she worked for him for the entire 12 years I worked with
her. It is unconscionable that he would now take the positions he had.
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153.
Cohen did relate to Kelley as a personal assistant as well as a
personal manager.
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However, during certain periods he had personal assistants working for him.
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Sarah Vienot worked for my daughter and Leonard Cohen for a number of
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years in the early 90s. Leonard Cohen advised us to let her go because she
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wasnt the type of personal assistant he wanted. Betsy Perks worked as
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Cohens assistant and household manager. He let her go at some point when he
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was visiting India. Even when Cohen traveled he was in constant contact with
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our office and always able to receive faxes and/or emails.
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154.
I have encouraged Kelley to do what His Holiness Kusum Lingpa
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and a number of
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lawyers have advised her to do since 2005: document everything in emails,
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creating a legal record of what has occurred, and copy in witnesses.
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I declare under penalty of perjury under the laws of the State of California that
the foregoing is
true and correct and that I executed this Declaration on the 21st day of
December, 20l3 at __________________, Texas.
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_______________________________________
Joan Marie Lynch
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EXHIBIT A
ADDENDUM TO
DECLARATION OF JOAN MARIE LYNCH
I, Joan Marie Lynch, do state and declare as follows:
1. I am a citizen of the United States and a resident of the State of Texas.
Kelley Lynch is my
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daughter. Except as to those matters stated on information and belief, I have

personal knowledge of the facts set forth herein and could and would testify
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competently if asked to do so.
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I have reviewed the declarations of Steve Lindsey, Robert Kory, and Betsy
Superfon that were attached to my grandson, Ray Charles Lindseys, custody
matter documents. As this matter was clearly coordinated by, at the very least,
Steve Lindsey, Leonard Cohen, and Robert Kory, I feel it is utterly relevant and
material to address their unconscionable statements and conduct. It most
certainly relates to Leonard Cohens lawsuit against my daughter because he,
and others, has attempted to coerce, force, and crush her into a deal with him
that she believed would have been illegal. This is an Addendum to the main
declaration I have provided my daughter in connection with Leonard Cohens
lawsuit against her (Case No. BC338322) and other related matters. I have
also asked my daughter to provide a copy of my declarations to the Internal
Revenue Service.
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I personally know Steve Lindsey, Leonard Cohen (who Kory represents), and
Betsy Superfon and remain convinced that this custody matter was coordinated
for a number of reasons. Those reasons would include, but are not limited to,
crushing my daughter into a settlement with Leonard Cohen and financial
settlement and new custody arrangement with Steve Lindsey. I have personally
spoken to both of my grandsons about this matter as it was occurring, over the
years, and believe the Court destroyed their lies over these lies and others.
DECLARATION OF STEVE LINDSEY
1. Steve Lindseys declaration starts out with the preposterous allegation
that my daughter
planned to flee this country for Tibet. My daughter never planned to flee this
country for Tibet, or any country, and the allegation sounds ridiculous. In the
summer of 2005, my daughter (at the request of His Holiness Kusum Lingpa)
planned to take her two sons, Rutger and Ray, to visit His Holiness monastery
in Golok, Tibet. Due to her busy work schedule, she did not have an
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opportunity to visit earlier. Given the fact that Oliver Stone, Richard Rutowski,
and many other Americans had visited this monastery, we saw no potential
problems with the trip. Both of my grandsons have been recognized as
reincarnated tulkus in accordance with the traditions of Tibetan Buddhism.
They were both enthroned by His Holiness Kusum Lingpa. I was present for
both enthronements. Rutger is an emanation of Apong Terton and Ray is an
emanation of the warrior King Gesar of King. My daughter is His Holiness
Kusum Lingpas lineage holder and chos kyi dags mos which essentially means
that she was entrusted with his teachings and placed in a position to guard and
protect them. It also means that she is the copyright holder. His Holiness
assured me many times that he wanted Kelley to personally transmit his
teachings worldwide. He specifically told me that my daughter, who he called
Sergyi Metok, golden flower and bestowed the name Odzer Chenma upon
her as well viewed her as his lineage holder and chos kyi dags mos globally and
in Tibet as well. He wanted her to perform the enthronements. He wanted her
to put his materials into books and make what she felt was appropriate
available. He mentioned to me personally that he wished she would start with
a book on three historical kings of Tibet. He was entrusting his entire body of
work to Kelley and understood that she would ensure that any financial
compensation would be transmitted to his monastery in Tibet. His Holiness had
the utmost faith in my daughter, her abilities, and looked upon her as though
she were his daughter or granddaughter. My husband and I were very close
with His Holiness. In the summer of 2005, His Holiness wanted Kelley to visit
Tibet, take the throne next to him and his son, Hung Kar Dorje Rinpoche, and
participate in a Tibetan enthronement of her sons. This was a rare and most
unusual opportunity. I can assure this Court that Kelley had no plans to move
to Golok, Tibet. First and foremost, China only authorizes three month visas
and ones visits to Tibet are carefully monitored. Beyond that, I tend to doubt
Kelley could survive the winters where temperatures drop to 100 below zero
and tears freeze. I personally believe Kelley should have taken Cohens offer of
50% percent community property, recorded Leonard Cohen, Steven Lindsey,
and others, dropped the tapes off at the local IRS/FBI Crime Unit, and moved to
Moscow, Russia. I have never witnessed a more appalling situation in my entire
life.
2. In the fall of 1997, Kelley and Steve Lindsey separated. They had leased
a house
on Mandeville Canyon Road and, due to the burdensome overhead, Kelley
decided to move. My husband and I located a home a bit further up Mandeville
Canyon Road that was for sale. The house was in need of renovations and my
husband, who has a construction and engineering background, felt that he and
Kelley could handle the basic issues which were primarily cosmetic. As Kelley
had recently closed large deals for Adam Cohen, whom she also managed, she
was in a position to purchase a home. After looking for houses and condos to
rent, and examining the exorbitant rental prices, my husband and I convinced
Kelley to purchase the house on Mandeville Canyon Road. Kelley also had a
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pension plan for a number of years and decided to use that to ensure that a
higher down payment would provide for lower mortgage payments. By the end
of November 1997, Kelley and her sons moved into this home. Her nephew,
Gesar Mukpo, joined them shortly thereafter. Gesar lived with Kelley, on and
off, for years, and is also an incarnation of a Tibetan tulku whose father,
Chogyam Trungpa Rinpoche, was Kelleys teacher since she was a young
teenager. Ive always said Kelleys introduction to Buddhism made me believe
in karma because this happened when we transferred her to Catholic school
in 9th grade. Kelley and Steve basically had an agreement that Ray would live
with her; Steve could visit after the school day ended; and, if Ray and Steve
worked it out; Ray could spend Wednesday night and time on the weekend
alone with his father. That actually did not happen all that frequently. Every
once in a while, Steve Lindsey would keep Ray at his house overnight. Kelley
was my grandsons primary caregiver and parent. That changed on May 25,
2005 and the events that unfolded appear to have been planned by Leonard
Cohen, Steve Lindsey, Robert Kory, and possibly Betsy Superfon.
3. My daughter worked as Leonard Cohens personal manager from 1988
until October 2004.
Leonard Cohen did not terminate my daughter. I was present when these
events unfolded in the fall of 2004 and Leonard Cohen must have forgotten that
fact. He may also believe that I have forgotten that he falsely accused my
husband and myself of hiding his money in off-shore accounts or falsely accused
my younger daughter, Karen Lynch, and her husband of starting their computer
business with his cash. These things never happened but Cohen knows how
to embellish a story and needed to confront and defend himself against very
serious allegations related to criminal tax fraud and those raised by his
investor, Neal Greenberg, in his June 2005 lawsuit. My daughter reported
Leonard Cohens tax fraud to Internal Revenue Service on April 15, 2005 and,
after witnessing what was unfolding, I encouraged to do so. What actually
occurred is that my daughter refused to meet with Leonard Cohen and his tax
lawyer, Richard Westin, a man I spoke with frequently. Cohen told us, and me
personally, that Westin planned to fly into Los Angeles at the end of October
2004 to unravel some of the issues having to do with numerous corporate
entities. Kelley refused to assist them with the unwinding of their transactions
and refused to hand over corporate books and records. In September 2004, my
daughter replaced her accountant, Ken Cleveland, with Dale Burgess. She
received a recommendation from Betsy Superfon, an acquaintance of hers, for a
new accountant. She had grown increasingly concerned about tax and
corporate matters, did not want to share Cohens accountant, and wanted an
independent review of those matters. It was my understanding, at the time,
that Leonard Cohen heard my daughter planned to go into the IRS and had
already changed accountants and planned or had already hired attorneys.
There was no issue related to misapprorpriations because we all, and that
includes Leonard Cohen, understood that Kelley owned 15% of all Cohens
intellectual property dating back to 1967; had a 15% ownership interest in Blue
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Mist Touring Company, Inc.; had a 99.5% interest in Traditional Holdings, LLC;
and, had a 15% ownership interest in Old Ideas, LLC. I personally handled
many of the clerical issues related to these corporate matters including faxing
information to Leonard Cohen, Richard Westin, and other representatives,
receiving faxes, filing the in our business files, placing the documents on
Leonard Cohens desk, inserting them into the corporate books, and so forth. I
am also well aware of the fact that Leonard Cohen and his daughter, Lorca
Cohen, came into our offices (Kelley was not present) and unlawfully removed
every business file of Kelleys. Apart from Leonard Cohens archived body of
work, financial and investment statements, corporate documents related to LC
Investments, LLC (an entity wholly owned by Leonard Cohen), the books
outside of his office, and some other materials, every single file (that filled
three large filing cabinets, a bookshelf in Kelleys office, boxes stored in her
office and my husbands), every file belonged to my daughter. Leonard Cohen
even removed artwork and tables he had previously given her. He removed
awards that belonged to my daughter. He and his daughter felt entitled to take
whatever they wanted. I would also like to note that Leonard Cohens behavior
during this period of time was aggressive, hostile, retaliatory, and threatening.
I witnessed this situation in its entirety. Cohen personally wrote my husband
that his work was impeccable but later, after Kelley refused to go into his
lawyers office and sign a settlement agreement without her lawyer present, he
began threatening her. My husband and I were at Kelleys home when she met
with Cohen, returned and explained his illegal demands, and then called her in
my presence and threatened her further.
I was present, at our offices when Cohens property and my daughters, was
removed and never once did Leonard Cohen advise me that anything was
missing. I personally find it impossible to believe that someone who was
missing so many valuable items, whose lawyers with dealing with Kelleys
lawyers, wouldnt mention their valuable missing items. In October 2004, and I
reviewed the letter, Kelleys lawyer advised Richard Westin, Cohens personal
tax and corporate lawyers, that Cohen should make arrangements to pick up
his property from my daughter. Cohen evidently received that letter since,
after her lawyers asked them to attend a meeting at their office, he and Westin
attended to explain Kelleys participation in numerous corporate entities and
any liabilities Cohen or his representatives exposed her to. Cohen was well
aware that my daughter had a home office and, as a courtesy, stored boxes of
older documents in her garage. He personally asked me to make arrangements
to have those boxes picked up from his garage, catalogue the contents for him,
and have them delivered to Kelleys home. Cohen had hired my husband to
oversee the construction on his garage. He had to clear the garage out
completely, and this is where the boxes were initially stored, because he was in
the process of renovating the garage and transforming it into a home recording
studio and guest suite for his sister. I have no idea why business issues
between Kelley and Leonard Cohen were raised in Ray Charles Lindseys
custody matter in any event. My daughter was not terminated for suspicion of
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anything and did not misappropriate anything. Leonard Cohen owes my

daughter a substantial amount of money and I personally am aware that he
took loans from certain corporate entities that he understood had to be repaid.
I sat in on many meetings with Cohen and my daughter; sat through and took
notes of conference calls on speaker phones; spoke to him and all his
representatives; know how Kelley, Cohen, his representatives and our operated;
and understand that Cohen reviewed all documents, financial statements, bank
statements, corporate records, and all business and personal matters. He
micro-managed the intellectual property deals, demanded complex stock deals,
and drove my daughter out of her mind. She did far more than any personal
manager I know and he used her horrendously. Cohen called our offices
morning, noon, and night. I personally would fax him (either at Mt. Baldy, his
home, hotels, or elsewhere) almost every single business document that came
into our office. He called on a daily basis about bank balances, sales figures,
royalty income, and knew when these items arrived or were paid through.
Leonard Cohen was not in a retreat on Mt. Baldy from 1994 through 1999. He
regularly visited Mt. Baldy and was routinely in Los Angeles and in our office.
He and his daughter, Lorca Cohen, also had keys to our office and spent time
there alone. Cohen would use the color copier and review his business and
personal correspondence. He frequently left notes for Kelley and me on those
documents and placed them on my desk. He also noted when I could file other
documents such as his bank statements, corporate bank statements, investment
statements, corporate records, legal documents, fan mail, pay a Canadian bill
(with a Canadian draft), deal with something related to his housekeeper in
Hydra Greece, or send photographs to a fan who had requested an autograph.
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4. Steve Lindseys declaration raises issues that have nothing whatsoever to

do with a custody
matter. It sounds more like a business negotiation that involves Leonard Cohen
and his lawyer, Robert Kory. I am convinced this custody matter was
coordinated by these parties. Leonard Cohen and his lawyers spent months
attempting to force or coerce my daughter into a settlement. I witnessed this
for months. My daughter was offered 50% community property and I was
present when she discussed that fact with her lawyers on the phone. In fact,
my husband and I babysat for our grandsons when Kelley went out to dinner
with her lawyers and accountant and returned. Her accountant flew in for a
meeting with Cohens lawyer. During this time, she was offered 50%
community property and discussions were had, from what I heard from
numerous parties, about $10,000/month walking around money for her;
$2,000/month walking around money for my husband and myself; and generally
anything she wanted. In fact, I was present for a conversation Kelley had with
Betsy Superfon. Superfon advised Kelley that Cohen would give her anything
she wanted and most certainly her share of these entities, the intellectual
property, and commissions due her. Superfon, at Kelleys request, called Kory
to advise him that Kelley was interested in a settlement and would like
Cohen/Kory to fax the document through. Superfon also told me that Cohen
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personally told her he would give Kelley anything she wanted, felt remorseful
and terrified, and mentioned that Kelley was the love of his life. I think
Leonard Cohen did view my daughter as the love of his life and it is my
personal opinion that he has retaliated against her viciously for that very
reason. Kory advised Superfon that this was not the type of deal one could fax.
He urged Superfon to arrange a lunch meeting that would include himself,
Kelley, and Superfon. Superfon, my daughter, and I all felt that a deal that
could not be faxed through was an illegal deal.
5. Steve Lindseys declaration states that Mr. Korys attempts at
negotiation have been
without success, and he ins on the verge of filing a complaint against
Respondent [Kelley]. A criminal action may also be brought against
Respondent, and she has told me several times she may face time in jail. My
daughter did indeed refuse to enter into any type of settlement or negotiations
with Leonard Cohen, or Robert Kory, because she felt their offers required her
to provide false testimony against Cohens advisers. Kelley repeatedly advised
me that Cohen and Kory wanted her to testify, in private meditations, that all of
his representatives defrauded him. Many of these men were Kelleys friends
and colleagues who I knew quite well. Kelley never said she was going to jail.
Cohen and Kory told Lindsey that and I was present when Lindsey repeated
that information to my daughter in front of my grandson. I personally believed
this threat was being used to blackmail her. My daughter is in possession of all
corporate records proving she has an ownership interest in these entities. Why
would she go to jail when, in fact, she is the individual who reported Cohens
tax fraud to Internal Revenue Service on April 15, 2005 and has provided IRS
with a tremendous amount of evidence. In 2005, I personally spoke to Agent
Bill Betzer numerous times when he was trying to assist Kelley with a payment
plan she had previously entered into with IRS. My daughters personal
financial matters are not a concern of Leonard Cohen or Steve Lindsey. She
wasnt married to either man and they did not file joint personal tax returns
together. I encouraged my daughter to explain to Agent Betzer what she
personally was dealing with and the fact that the tax fraud appeared egregious,
seemed to involve numerous corporate entities, may date back many years, and
Cohen may also have problems with his resident and tax matters in Canada as
well. There is a reason this man cannot live in Canada.
6. Steve Lindsey appears to have an interest in my daughters personal
finances. Lindsey and
my daughter did not mix their finances because His Holiness Kusum Lingpa (in
1994) advised my daughter not to formally marry Steve Lindsey (which they
planned to do) and not to mingle her finances with his. He said this to her by
the pool of her first house on Mandeville and I couldnt have agreed with him
more. I did suggest that, at the very least, she get a ring out of the ordeal.
As Lindsey seems concerned about my daughters finances, I would assume he
was worried that he might have to pay her the monies he owes her for loans
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and expenses related to his daughter, Jennifer Lindsey, and their son, Ray
Lindsey. Steve Lindsey repeatedly told my daughter, and I have discussed this
with him personally numerous times, that he would repay her in full for the
monies she expended on behalf of his daughter (including private school for a
number of years), and pay her of all the monies she expended on behalf of
Ray (including his private school tuition). Lindsey also routinely borrowed
money from my daughter. He has not repaid her any of the outstanding
amounts and actually preferred to let the mother of his son end up homeless. I
think that speaks volumes about this man. My daughter had a business line of
credit with American Express that seems to interest Steve Lindsey. My
daughter had a very viable and successful greeting card business and is an
excellent business woman and personal manager. Everyone who worked with
my daughter loved her and that includes some of Cohens representatives she
was asked to offer personal testimony about. I know that Kelley was
particularly close to Greg McBowman, Stuart Fried, and a number of Sony
executives. Leonard Cohen and Steve Lindsey act as though they were my
daughters controlling, obsessive husbands. I can attest to the fact that these
men controlled my daughter and behaved, at times, utterly aggressive and
jealous. Perhaps thats why Leonard Cohen, and his lawyer, went into Lindseys
office to advise him that Kelley had sex with Oliver Stone. I asked Kelley if this
was Cohens legal defense and advised her to ask him to provide her with the
videotape proving she and Oliver had sex. I also suggested to my daughter that
Cohen may actually have been under the bed during her encounters with
Oliver. I was my daughters confidante and know who she was interested in
romantically. I can assure this Court that my daughter had no interest in Cohen
and wanted to get as far away from him, as soon as she possibly could. She
supported a number of people and could not easily resign from her position
although I know she wanted to and this is why she started her greeting card
company. At no time did my daughter have sex with Oliver Stone. He was a
friend of hers and, from what I could tell, he was a very good man and father
who appreciated Kelleys sons. Oliver Stone was quite generous with His
Holness Kusum Lingpa (who, I might note, loved him and spoke about him
frequently) and Kelleys stepdaughter and nephew, Gesar Mukpo. Both of them
interned with Oliver. Leonard Cohen and his lawyer clearly understood that by
working Steve Lindsey up, which is not hard to do, they could create a custody
matter and put more pressure on Kelley. My daughter lost custody of her son
by default. I have never heard of anything so insane in my entire life and
question the legality of that issue. I also question the legality of a default
judgment that is evidence of theft, based on fraud and perjury, that willfully
ignores corporate records and federal tax returns. My daughter has been
accused of having a $30,000 handbag, $20,000/month pharmacy bill, spending
thousands of dollars a week on dinners with Hollywood friends, and generally
painted as an out of control spend thrift. These allegations are all false, meant
to serve the goals of Cohen and others, and my daughter hardly if ever went
out. When she did, my husband and I babysat our grandsons. We also stayed
with them when Kelley travelled which she did due to her work with both
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Leonard and Adam Cohen. Kelley, at times, would be in Europe for weeks at a
time on promotion or concert tours. My daughter rarely took a vacation due to
her schedule. Her schedule was brutal and did not interfere with her
wonderful parenting skills. Her sons were her priority and, I might add, so
were her father and myself. Kelley is also a wonderful sister and friend. She
has also been blessed with the presence of many of the worlds greatest
Tibetan lamas in her life. That would include His Holiness Sharmapa who has
been particularly kind in his guidance of Kelley throughout this period. He
clearly understands corruption and motivating factors. Leonard Cohen was not
in a Buddhist retreat of any sort I am familiar with. It appeared to me that his
period on Mt. Baldy served as a photo backdrop and opportunity to have a new
story for the news media. His good rock n roll stories about Phil Spector were
growing old and tired.
7. I continued to work with my daughter, after she and Cohen parted ways,
and was with her
all day every day and present at her home on the weekends until my husband
and I moved sometime in the spring of 2005. She was not dangerous to
anyone. She is a wonderful, caring, down-to-earth, compassionate, brilliant,
and fun individual. She does not suffer fools easily. After Kelley and Cohen
parted ways, she was focused on her greeting card company and, I might note,
quite relieved to be away from Leonard Cohen. He had made her life
miserable, sheer hell, for years. He also sexually harassed her for years.
Cohen forced her to read business documents while he bathed in a bubble bath
and exposed himself to her. She was continually upset by his conduct and
became very reticent about traveling alone with him. This is not appropriate
conduct and I was shocked that a prosecutor would think this conduct was
acceptable. My daughter was extremely upset when she came back from
Cohens one day not too long before they parted ways. He had evidently looked
at people defecating on one another in front of her. She no longer wanted to be
alone with him. She also expressed concern about what her sons had access to
on the internet.
8. My daughter was an excellent mother who supervised her sons and cared
for their every
need. She carpooled on a daily basis because she wanted to be available to
drive her younger son to and from school and remain home with her sons after
she dropped everyone off. Rutger was home schooled, from sixth through
twelfth grade, and his teachers were with him throughout the day. Home
schooling ones child, in the manner Kelley did, is no different than having them
in a private school. One of the main reasons Kelley home schooled Rutger is
due to the fact that she was appalling by Paul Revere Jr. High and its staff.
Kelley actually cared for one young girl, Chloe Favella, for quite a long time and
brought her to work with her on a daily basis. Chloe was home schooled
through LA Unified and basically was given homework every two weeks and left
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on her own for the remainder of the time which Kelley and I both disapproved
of vigorously.
I was with Kelley every day from approximately December 1992 through
approximately April 2005. I know everyone involved in this utterly outrageous
situation. Part of the problem, from what I can tell, is the court system in Los
Angeles. Another part of the problem is the lack of evidence required by this
court system.
My daughter has repeatedly complained about being given misinformation by
the Courts themselves, not being able to obtain transcripts, and not being
served numerous lawsuits and other documents. It seems rather odd that I
would know of these things and the court system would not. I am also aware
that Kelley has represented herself and opposing counsel and the prosecutors
take advantage of that with their well-developed tactics. I know for a fact
Kelley was not served Leonard Cohens lawsuit. From the winter of 2005, she
wore her hair very very short and extremely dark brown. She could not longer
afford her hair dresser, Mario Lara, and found it easier to just cut her hair
short, which was quite flattering, and decided she wanted to wear it very dark
for a change. My daughter has changed her hair color throughout the years. I
repeatedly advised Kelley that the color she was using was almost black and far
too harsh for her complexion. No one who went to my daughters home in the
winter through summer of 2005 would look at her and describe her in any way
other than the following manner: approximately 56 tall, exceedingly thin
(possibly 102 pounds), huge blue eyes, and very very dark almost black hair.
Ive looked at the proof of service. My daughter would not evade service and
constantly told me that documents, such as Neal Greenbergs lawsuit, were
thrown outside her front door. My daughter does not leave lights on when she
leaves a room or is not in the room. She did not leave lights on in the daytime.
The back of her house was floor to ceiling plate glass windows. Her front door
had plate glass window on either side (also floor to ceiling) so the process
server would have seen her had he actually bothered to go to her house. My
daughter shared a driveway with another family. Their mail boxes, on the
street, were unmarked. People frequently missed the house and would go to
the road above my daughters home where there was a cluster mailboxes and
numerous homes. My daughter was also home everyday throughout the
summer and fall of 2005. I spoke to her constantly until her phones were shut
off and then she would use Rutger, or another teenagers, cell phone. Her car
was destroyed, she had no transportation, and was focused on attempting to
sell her home and other matters. She did not go out and the process server did
not come to her house five or six days straight. There was no reason for her to
avoid service. My daughter has a legal background, worked as a legal assistant
(or paralegal) years and years ago and has worked with lawyers continuously
throughout the years. Leonard Cohen obviously supplied the process server
with a description, which was then relied upon, of my daughter from the time
he knew her and she had changed her appearance. Its as simple as that. He
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will say and do anything. Ive witnessed this over the years and am well aware
that he has a tendency to fabricate and highly embellish stories. I was present
for many interviews and have heard countless versions of Leonard Cohens Phil
Spector gun incident, Bay of Pigs involvement, role in the Yom Kippur War,
and even recall Kelley and Cohen coming into the office one day after lunch and
Kelley saying Mother, did you know Leonard was in the CIA MK Ultra
program? He apparently told her that at lunch. I assured my daughter that
the CIA did not need to drug him. I was aware of Cohens pharmacologist and
the fact that he took prescription meth, other drugs, drank too heavily, and
definitely has psychiatric problems. I think hes been quite public about those
issues even if he conjured up one of his carefully crafted remarks, that
frequently takes months to come up with, that she assailed his reputation
with her rhetorical question: Are you on drugs? I personally think, based on
his conduct towards her, its a highly relevant and material question but Im not
a star struck prosecutor or judge. However, reading about someones dark
psychiatric problems, such as Cohens, and dealing with them intimately (not
sexually intimately) are entirely different. Its very difficult to deal with
someone who has serious mental instabilities and routinely abuses substances.
I also know that Steve Lindseys lawyer did not serve my daughter with legal
documents. This is extremely concerning and has very serious implications for
individuals as well as the court system itself.
9. And, for the record, at no time throughout my daughters life did she tell
me that Phil
Spector held a gun on her. I am extremely fond of Phil Spector and know him
somewhat. In fact, from my perspective, Phil Spector saved my daughters life
one time. My daughter has asthma and a heart condition and was taking
medications that she repeatedly advised me made her dizzy and interfered with
her ability to breath. My daughter has been hospitalized over these matters. I
have very similar conditions, and heart problems run in my family, so I know
what she is dealing with. In fact, Kelley was taken to the hospital numerous
times while living in the Bay Area for this precise condition. She also tends to
naturally become dehydrated. Kelley is also very sensitive to medications and
does not like to take them. Her son Rutger is very similar. They have an
allergy, for instance, to all forms of narcotics and, in particular, opiates. Beta
blockers can also be quite problematic. Phil Spector and my daughter called
me one night, when she was visiting him in Pasadena, and said she felt faint.
He was concerned she was going to pass out. I advised him to call 9/11. I
distinctly recall this conversation for obvious reasons and due to the fact that
this is the first time I actually spoke to him beyond cordial greetings when he
phoned my daughter. I do recall Phil Spector saying to my daughter, at that
time, that I reminded him of Doris Day. There was nothing suspicious about
what happened; I have no motive to lie; and Kelley was taken to the hospital;
and I was at her home waiting when she returned. She did make a joke that
she had to make a suicide attempt to get out of his home but Kelley has a
very dark sense of humor and constantly made fun of the horrific rumors and
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gossip about Phil Spector. I know she used to tell him (and me) that she
wanted him to record her singing The Long & Winding Road To Your Door,
Phil. That had to do with her suspicions that gold diggers were targeting him,
his taste in certain women was terrible, and the women were lying about not
being able to leave or being forced to escape. My daughter never had any
incident of this nature. I also worked with Phil Spectors driver, who Kelley
employed and was in our office constantly. Never once did I hear anything that
would cause me to become concerned. Morgan Martin was thrilled to work for
Phil Spector. I know my daughter loves him. She has known him since she was
in her early twenties and they are very close friends. I am aware that they had
dinner after the incident in his home and he explained what happened, that the
woman shot herself after dancing around with a gun in his foyer, and Kelley felt
terribly about what he was going through. Phil Spector called her frequently
during that period of time. I know. I answered the phones. He also sent her at
least one hilarious card and numerous funny faxes. If theres one thing I can
say about Phil Spector he has a great sense of humor. What has happened to
him is quite tragic.
My daughter called me, when the DAs investigator visited her about Phil
Spector, and asked me if I could recall Phil Spector holding a gun on her or my
younger daughter, Karen, and my response was No. My husband could recall
no such incident either. My daughter was dragged into the Phil Spector matter,
Cohen ended up testifying about Spector and a gun during her trial, Cohens
statements were used by the prosecutors and possibly before the Grand Jury,
and Kelley was told she was probably a witness in that matter. Although my
daughter felt Cohen, Spectors DA, and others might literally confess to being
in a blatant legal conspiracy involving her, I assured her that they would never
confess. My father was a Magistrate and I grew up surrounded by judges. The
Police Chief and DA played cards at my home every Saturday. My father issued
warrants. I know how this system works and I personally believe much of what
my daughter has gone through relates to her friendship with Phil Spector and
her belief that he is innocent. I also believe he is innocent and Leonard Cohen
personally advised me on numerous occasions that Phil Spector never held a
gun on him. I distinctly recall discussing this matter when detectives, involved
with the Spector case, called our offices to speak with my daughter about
arranging a meeting with Cohen. I answered the phones and Leonard Cohen
was concerned about these calls. Cohen was extremely nervous, and told me
he didnt want to be involved and had nothing to offer because his stories about
Spector were good rock n roll stories. Cohen personally told my daughter and
me to put these detectives off, if possible. When it was no longer was possible,
and a meeting was arranged with Cohen, I advised my daughter that her
decision to have her lawyer, Steve Cron, present was a good idea. She did not
want to be dragged into Phil Spectors matter and did not want the detectives
questioning her. She was concerned that it might result in a custody matter
because she felt Steve Lindsey was willing to use anything against her. The day
the detectives met with Cohen, my daughter walked over to his house from our
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office and met with Cohen and Cron. Cron advised her to leave when she told
him that she was actually the person with a long and intimate friendship with
Phil Spector. My daughter walked back to our office, told me she met the
detectives briefly, explained that they seemed nice, and Cohen came over to our
offices afterwards and told us that he confirmed for these detectives that his
stories about Phil Spector were highly embellished good rock n roll stories and
Spector never held a gun on him. It is my understanding that Cohen testified at
my daughters 2012 trial that Spector held a gun to his head. I do not believe a
word this man says and do wish the public defenders had called me, asked for a
declaration, or returned my younger daughters calls. I am also aware of the
fact that they got many details wrong and never advised her of a plea deal, told
her she could accept one after the trial began and she questioned them, or met
with her. They also refused to provide her with a copy of her file. The situation
is quite disturbing.
10.
I do believe my daughter was, and continues to be, under enormous
stress throughout this
10 year period. I am concerned about the probation matter and have reviewed
the trial transcript with my daughter. It appears that every word uttered by the
prosecutor, Leonard Cohen, and his lawyers is fabricated, a lie, self-serving,
and at times completely absurd. I have provided my daughter with a
declaration in that matter. At no time were Leonard Cohen and my daughter in
any type of brief, intimate, or statutory dating or engagement relationship.
Leonard Cohen was obsessed with my daughter, personally advised me many
times that he loved her, would have done anything for her, offered to buy her
house or anything she wanted, and she refused. He also offered to buy her
things like a $50,000 solid gold watch that she also refused. She didnt have to
steal from him. She was a professional business woman, worked hard, helped
him with his career substantially, and has now become some sort of helpful
assistant. Nothing could be further from the truth. My daughter does not like
to take gifts from people and I often cautioned her that these types of gifts
come with solid strings attached to them. My daughter hardly knew Leonard
Cohen in the mid-80s. She was dating Moses Znaimer, other men, and married
Douglas Penick in 1988. She was very close with Phil Spector and the mother
of his children, Janis Zavala, at this period of time and they were very kind and
generous with my daughter. They sent her books, clothes, and many items that
once belonged to Nicole or Phillip, Jr. Leonard Cohen knows how to tell a story
that will dazzle the news media, his fans, and others. He clearly felt his version
of events, which has no basis in reality, would work better if my daughter was
the stereotypical disgruntled ex-lover, obsessed with him, went off the deep
end, stole his money and spent it on Hollywood parties, harassed him for no
reason, and was LAPDs perfect definition of a celebrity stalker. I would
assume Cohen researched celebrity stalkers and gave them precisely what they
needed to hear right down to his comments about my daughter wanting to
attend his concert. My daughter didnt want to attend his concerts when she
knew him and turned down offers, for instance, to fly first class to Paris, stay at
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the Four Seasons, and travel with him for a few days throughout Europe. That
would sound glamorous and highly inviting to most people. My daughters
children were of greater importance to her than any so-called illusion of a
Hollywood life. My daughter was never in a sexual relationship with Cohen
or anyone for that matter and I found that reference in LAPDs report deeply
disturbing. I have no idea what that means apart from a perception on
someones part that my daughter was a hooker rather than Cohens personal
manager, publishing administrator, publicist, personal assistant, confidante,
mother, and slave and worked in other capacities as well. There are many
hard working individuals in the entertainment industry. Very creative, fun, and
talented people. These individuals are not necessarily stars and stars are not
necessarily intelligent, creative, talented, or interesting. Ive known quite a
few in my day. Kelley was exceedingly hard working and so were the
individuals she worked with in the industry. This is a business like every other
business. My daughter did not get in over her head. She had nearly $1 million
in equity in her home; owned a collection of antique cards and artwork (that
she used as prototypes for her business) worth a substantial amount, was
negotiating many deals (including a multi-million publishing deal that Cohen
demanded and multi-million lithograph deal), Cohen was delivering a new
studio album and planned to tour, she made very good money, and she had a
relatively simple life. One of her main expenses involved baby sitters because
she did not want her sons alone in the house. Many teenagers spent time at my
daughters home, and sometimes lived with her when their parents could not
care for them, so she was exceptionally cautious about monitoring their
behavior at all times. My husband and I visited constantly. Kelley was a
wonderful, kind, and attentive mother. The house was beautiful and impeccably
clean. She loved her sons and animals which included two large Akitas, two
small Shitzus, an African Grey, and a variety of reptiles. My daughter rarely, if
ever dated, after she and Lindsey broke up for fear someone would behave
abusively towards her sons or end up being a bad influence. Evidently, all you
need at LA Superior Court is a checkbook and a good story. I have heard that
being a celebrity helps. According to my daughter, many prosecutors informed
judges that her case was rare or unusual because a celebrity was involved.
11.
My daughter does not and never has had mental health issues.
That is not true for either
Cohen or Lindsey and that should obviously be taken into consideration. Cohen
has personally discussed his dark psychiatric problems. Lindsey has spent
years in therapy and has a serious anger management problem. I have
witnessed him, time and again, treat my daughter and her sons horrendously.
His abuse is primarily verbal abuse. I have advised Lindsey, on a number of
occasions, if he lays a hand on either of my grandsons (as he has my daughter),
I will personally call the police and have him arrested. I was on the phone with
my daughter and grandson, Ray, throughout the morning of May 25, 2005. I
know for a fact that my grandson did not feel well. He was also upset because
his father was calling repeatedly and screaming at him and my daughter. He
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was unhinged at this time and I believe part of it had to do with his involvement
with Dinah Englund, the fact that they were having a baby, and his financial
problems at the time. Many teenagers were coming and going throughout
morning. I remember saying hello to some of them. My daughters greeting
card company office was now located in Santa Monica. Some of the teenagers
who worked for us were Rutgers childhood friend, Jonathan, Evans girlfriend,
Tara, and Christine. I worked with these teenagers and know that Kelley tried
to help them. They were exceedingly difficult to oversee which was my
personal job. They were not disciplined; some were dishonest; others had
overstated their qualifications. Aref also worked for my daughter and was at
her home that morning. Soon after we hung up the phone a SWAT incident
occurred. Evidently Steve Lindsey phoned the police and told them something
about my daughter having a hostage. That hostage may have been my
grandson who was not home when the police arrived. My daughter did not
want Lindsey on her property due to his conduct. That morning, he had been
demanding that he be permitted to come to the house, pick Ray up, and take
him to school. He liked to control situations and I personally believe he was
secretly planning to take Ray from Kelley for a number of months or change the
custody arrangement they had worked out. She asked Rutger to take Ray down
to the hill to meet his father. I have heard this from both Kelley and Rutger. I
would assume Lindsey pressured Ray, who has been traumatized (as has
Rutger), to say whatever his father wanted. Ray was afraid of his father. My
grandson, Rutger, has told me numerous times that he told the police what
happened, that Ray was not home, he had just been at the house and took his
brother down the street, dropped him off with Cloris Leachman, and they didnt
listen to him. While Rutger was handing Ray over to Leachman, he saw
Lindsey and approximately 7 squad cars racing up Mandeville. Rutger
returned to find the police there with Lindsey. I do not know the details related
to the police but I know that my daughter was inside the house alone, in a
bikini, when she looked out the window and saw what appeared to be 25-30
armed men around her house and in front of her son. She called me as the
situation unfolded and told me she had no idea what they wanted; no one came
to her door; no one asked her to come out; and she had no idea what one of
them was talking about when they asked what her hostage demands were. I
immediately knew Lindsey was involved and assumed Cohen was somehow
involved also. I told my daughter to call a lawyer and call LAPD to find out
what was going on. My daughter had a friend call LAPD and she called her
former custody lawyer, Lee Kanon Alpert. My younger daughter, Karen, did not
phone the police. She has assured me of this. My daughter, Kelley, was told by
LAPD that someone phoned them and they were either told that my younger
daughter called or received a call from my younger daughter. That never
happened. Steve Lindsey confirmed in his declaration that he phoned LAPD.
At some point, the incident ended with my daughter diving into the pool, my
grandson being told that the dog was her hostage and they were taking
precautions, and my daughter being unlawfully removed from her home and
taken hours from her house to King Drew in South Central when UCLA was
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right down the street. I am also aware of the fact, which I find unspeakably
evil, that my grandson was told LAPD would shoot my daughter and shoot their
dog. It is of interest to note that someone actually phoned LAPD, who
apparently knew what was happening, and told that individual that Kelley
should call LAPD. My daughter called me from King Drew the next morning
and told me LAPD questioned her about Phil Spector and a gun incident. She
also told me she was drugged against her will, had called Yongzin Rinpoche,
was worried about Rutger and Ray, and a nurse told her she was being
transferred and the file contained the wrong date of birth and wrong social
security number. I advised my daughter to immediately demand a new doctor,
which she did, and she was then asked by this new doctor to wait her turn and
then released. The doctor did not agree with LAPD and neither do I. Theres
far more to this incident and nothing will ever explain why my daughter was
taken to a dangerous mental ward nearly three hours from her home in traffic.
Nothing will ever explain the entirely fraudulent file either. The doctor assured
my daughter and Rutger, who also confirmed this for me, that she would not
lose custody of Ray over this incident. However, when she returned home she
discovered that a custody matter had been coordinated. Shortly thereafter, she
would find out that Leonard Cohens lawyer provided the court with a
declaration. There is one other incident that occurred the day of SWAT that I
think is highly material. My grandson, Rutger, personally advised me that
Steven Lindsey called him, after his mother was taken from the house (in a
bikini and handcuffs), and asked him to go in and sign over their home to
Leonard Cohen. Rutger was evidently promised some sort of money and
Lindsey said Cohen would give him money to care for my daughter. Leonard
Cohen doesnt own my daughters house and this situation sounds terribly
illegal. Fortunately, my grandson phoned his father, Douglas Penick, who
advised him to consult a lawyer first and then made the decision on his own not
to respond to Lindseys calls. I personally believe the individual who was in
danger here was my daughter and anyone who says otherwise is a bald-faced
liar. And, obviously these incidents have been used to discredit my daughter
which I assume was part of the grander scheme. Rutger also told me the police
asked him two questions before taking his mother away: Are you okay and is
your mother on any medications? He advised them that he was and his mother
was on heart medication. That is apparently not is what appeared in the King
Drew report that Kelley reviewed with me some time ago.
12.
Steve Lindsey repeatedly threatened my daughter with a custody
matter and has lied about
her excessively. In fact, the doctor at King Drew told Rutger later, and he
discussed this with me, that Steve Lindsey (after my daughter was released)
attempted to convince him that my daughter was dangerous. The doctor
disagreed and told Rutger that no alcohol was involved in the situation either. I
know that for a fact because I was on the phone with my daughter while the
incident was unfolding outside. My daughter never has and does not have
substance abuse or mental health issues. I am tired of these lies and found the
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prosecutors actions, including her attempt to have my daughter drugged and

hospitalized, especially egregious. My daughter wrote letters to Bruce Cutler
and I can assure you that this is precisely what she should have done. Leonard
Cohen was testifying against Phil Spector on the stand, with the District
Attorneys investigator in the courtroom, and he has an absolute right to
confront his accuser. Furthermore, this is a very serious and dangerous
situation. There are powerful political entities involved here and they have
clearly joined forces with Leonard Cohen. There was and remains no domestic
violence. The Boulder, Colorado order is not domestic violence. My daughter
has repeatedly informed me, including before her arrest, that the Boulder Court
told her this order expired in February 2009. These restraining orders are
fraudulent and a litigation and publicity tactic. I would assume that Cohen
wasnt coached during the bail hearing when he testified that my daughter
never stole from him, just his peace of mind, and confirmed that they were in a
purely business relationship. I look forward to his next round of explanations
and excuses. The man cannot tell the truth. It is my personal opinion that he is
a con artist, fraud, and thief who has a lifelong history of tax fraud in the
United States and Canada. He has used Phil Spector, and his ridiculous gun
story, to advance his career. This dazzled awe-inspired journalists. I have
repeatedly advised my daughter to continue to document everything publicly
for IRS, FBI, DOJ, Phil Spectors legal team, the news media and others. I have
also advised her to contact Oliver Stone. His Holiness Kusum Lingpa originally
advised my daughter to document everything in emails, with witnesses, and I
think that was a very wise piece of advice. I have no doubt that Leonard Cohen
finds it annoying. Shes telling the truth and he hates people who see right
through him and his highly embellished, fabricated narratives. Leonard Cohen
is concerned with one thing and one thing only: Leonard Cohen. I think his
actions towards my daughter, and in this and related matters, are evidence of
that fact. But, being a celebrity in Los Angeles carries a tremendous amount of
weight, as I am well aware, and he has the wealth to hire a team of lawyers to
lie about my daughter, conceal evidence, fabricate facts, and destroy her.
These issues have been used to discredit her although I do not really
understand what they have to do with Cohens lawsuit against my daughter
since there is an abundance of evidence proving she owns the intellectual
property, is owed substantial commissions for work she performed and future
commissions, and her main problem is that she has been forced to represent
herself and the tactics used against her are horrifying and abusive. That would
include the use of fraudulent restraining orders provided to Cohen numerous
times without evidence or witnesses and based on false allegations and
perjured statements. I am well aware of the fact that my daughter is in need of
tax information including a 1099 for the year 2004. She has repeatedly
attempted to obtain this information for a period of 10 years. My daughters
wages were garnished in 2011 because she is being prevented from filing her
2004 and 2005 tax returns. The California FTB gave her 60 days to obtain the
information she wanted. The prosecutor lied about this and other matters so
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the jury evidently thought my daughter was lying when, in fact, she is telling
the truth. I am also aware of the fact that for every year my daughter worked
for Cohen she was provided with a year-end tax document. She is also in need
of corporate tax information and an accounting. I have looked at the ledger
and it means absolutely nothing. Steve Lindsey personally told me that Cohen
or his lawyer showed him a manila folder and told him that this was the
evidence against my daughter. He had no idea what was in the folder and the
story sounded farcical. I advised Lindsey to stay out of this situation as he was
never involved in my daughters business affairs. I have no idea why he was
meeting with Cohen or Kory. Betsy Superfon told me he was attempting to
encourage my daughter to make a deal and wanted to keep Ray out of Cohens
IRS matter.
13.
My daughter did ask Steve Lindsey if he would phone Dr. Dre or
someone at Aftermath to
see if they had any work she might be able to do. While my daughter
remortgaged her house it was becoming difficult for her to keep up with the
bills months after she and Cohen parted ways. Cohen refused to pay her what
he owed her; she incurred tens of thousands in legal and accounting bills
attempting to deal with his insanity; and Lindsey refused to pay her anything he
owed her. She was also forced to rent a space that was three times the rent
that her former office rent was. She did not want to be near Cohen or even see
him. Cohen and his daughter lived one block from our offices. I worked with
my daughter in Santa Monica as well. We did not take any of Cohens property
to Santa Monica. I am the individual who was at our former offices when the
moving company picked our property up. My daughter was not present. She
was at our new office space. Cohen and his daughter had already picked his
property up including his boxes of archived materials. Cohen told me
personally, after we searched the office months before they parted ways, that
he found his water color notebook. It was in his home and he had scanned it. I
was in possession of the files of scans and know this is the case. He later
evidently thought this might be a useful story to use in order to have the
Sheriffs Department seize my daughters property and his old files many of
which also belonged to my daughter or Machat & Machat. My daughter did not
have an original manuscript of his. She may have had a photocopy of an old
document that meant nothing to her. My daughter packed up every single
thing Cohen gave her, including original water colors and other very expensive
items, and intended to donate them to charity after the ordeal shes been
through. Her situation reads like a Lifetime Movie. As I have said, I arranged
to have those boxes taken to my daughters home and made a list of the content
for Cohen before they were shipped there. I think Cohen wanted to sanitize the
files and grab whatever corporate, business, and tax records he could. My
daughter was very public about the fact that she was shipping boxes of
evidence to Internal Revenue Service in Washington, DC. I would assume
Cohen understood this and made a move. Thats a more plausible theory. I was
present at a birthday party that Dr. Dres son attended. My grandson, Ray, and
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Andrew Burkle were present as well. At that party, Dr. Dres bodyguard told my
daughter that they played paintball in the park, for real, and would come up
behind one another and hold guns to each others heads. My daughter found
that story to be relatively amusing and probably repeated it to Steve Lindsey.
Lindsey apparently found a way to embellish this story for the Court. Lindsey
also knew Larry Flint, and said he would call him for Kelley, but she didnt want
to work for a magazine that was involved with pornography. It is my
understanding that Lindsey told the Court my daughter wanted to be a whore
and that is an outrageously false allegation. Leonard Cohen and Steve Lindsey
are unstable misogynists with motive. Steve Lindsey and Leonard Cohen have
intentionally stated in numerous documents that my daughter sounded drunk
or high. My daughter does not have substance abuse problems. These men did
from what I recall. The situation sounds like Cohen and Lindsey think theyre
in the middle of a vile and vulgar divorce proceeding.
14.
Lindsey against states, in his declaration, that he approached
Respondent [my daughter] and
told her to contact Mr. Cohen to negotiate a deal. He goes onto say that she
responded by saying maybe she should go live in Tibet. I have no idea why
Steve Lindsey inserted himself into Kelleys business affairs with Cohen. She
was represented by lawyers from the fall of 2004 until the Spring of 2005.
When she could no longer afford legal representation, it appeared to me that
Lindsey began pressuring her to enter into a deal with Cohen. Cohen and
Lindsey should have simply paid my daughter what they owed her and thats
precisely what my husband told Lindsey when he phoned us after the SWAT
incident. He understands these men and these types of tactics. I was present
years ago when Child Services came to Kelleys home. Lindsey understands
vicious custody and legal tactics. He took his daughter from her mother and
told us repeatedly that her mother abandoned her. His daughter was seriously
damaged by this and my daughter provided her with a wonderful and loving
environment. It turned out that, years later, Lindseys daughter visited her
mother and the entire situation was made up, she had not been abandoned as
an infant, and the situation was nothing but Lindseys slander about another
woman he was involved with. Steve Lindsey is extremely abusive and hostile
towards women. He personally advised me that Dinah Englund drank too
much. This is how he operates. The woman from Child Services advised us
that she thought Lindsey was harassing my daughter; Lindsey called screaming
at her that she was a great mother the woman said Lindsey was in a rage;
and she was going to either charge him or recommend that he attend anger
management. Nothing ever happened, naturally. Lindsey had apparently
brought my son late to school and needed to make up a story for the reason he
was late. Naturally, he blamed my daughter.
15.
I have addressed my recollection of the day Kelley and Ray stopped
by Robert Korys office
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unannounced in my declaration. Kelley was asked to pick her son up from

school and thought they would stop by for a few minutes to try to sort the
situation out. Cohen and Kory had been attempting to force her into a deal,
wanted to meet with her, but I assume that Rays presence (as a witness) was
highly problematic. I have no idea who Robert Kory is, and we did not deal
with him the entire time I knew Cohen, but he sounds like a maniac and
profound liar. It is my understanding that his partner, Michelle Rice, has
actually made partner targeting my daughter and she appears to lie about her,
and many issues, continuously. I would assume their motive involves wanting
to represent Leonard Cohen. I understand as well that they now actually serve
as his paid witnesses which sounds highly suspect and questionable. In fact, I
do not understand how they can actually serve in dual positions Cohens
lawyer and his paid representatives.
16.
Lindseys declaration goes onto state that It is my understanding
that this email is referring
to Respondents plan to escape incarceration after stealing money from Mr.
Cohen. Apparently, Respondent believes that people are threatening me, which
is not true. My daughter has stolen from no one. On the contrary, Leonard
Cohen has stolen from her and owes her millions. My daughter was advised to
contact the investigator on the Phil Spector matter, who visited her home, and
go wired to meetings with Cohen or his lawyers. At the time, she read me the
lawyers email who gave her that advice and hopefully she followed that advice.
Leonard Cohen owes her millions. I do recall that Cohen was represented by
former DA Ira Reiner so perhaps Reiner had a relationship with Spectors DA
and they worked out a deal about Cohen offering testimony about some version
of his gun story in exchange for help with his alarming IRS problems.
Corruption is not always just blatant forms of bribery, etc. but can come in the
form of cronyism. I instructed my daughter to phone the DA investigator and
confirm to him that Leonard Cohen was attempting to blackmail her. She
assured me she did and said he told her his wife would kill Robert Kory if he
did to her what he did to my daughter. I did not assume the investigator was
speaking literally and am aware that people are being prosecuted for what used
to be their manner of speech. That would now include the insanity with
Kelleys prosecutor and a Valentines Day card that had a photograph of a
military drone and a cute sentiment. Only someone with motive would view
that as a threat. Its interesting that these threats of jail were used in the
custody matter and in an attempt to coerce my daughter into entering into a
deal with Leonard Cohen. I was convinced that my daughter made the right
decision when she phoned Agent Bill Betzer of the IRS on April 15, 2005 to
discuss what was going on with respect to Leonard Cohen, the allegations
relating to his alleged criminal tax fraud, and these corporate entities.
17.
Lindseys declaration then states that On or about 3, 2005, I
received another email from
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Respondent stating that Also, tell Kory I plan to sleep with his father and exwife. If theyre not careful, Ill have sex with Leonard and Adam. Before you
know it all of LA will be under my spell. Im going to have to sleep with movie
producers, agents, and hair dressers. Authors. Ill be busy you might have to
pick Ray up at school more often. This was Kelleys response to the ongoing
allegations, made by Cohen and Kory (and repeated to her, including in my
presence, and the presence of her sons, by Steve Lindsey) that they went into
his office, and told him at other times, that my daughter had sex with Oliver
Stone, Cohens tax lawyer to get an annuity obligation, and her friend, Richard
Rutowski. My daughter did not have sex with these men and these allegations
were used to stir up a custody matter. Oliver Stone and Richard Rutowski were
my daughters friends. My daughter has an excellent dark sense of humor. Her
comments were obviously facetious. My daughters other comments were also
quoted in Lindseys declaration, that I will take Ray into that agency [Child
Protection Services] and have him tell this story. Its downright abusive of
Robert Kory and Leonard Cohen. Read these words: they are deadly serious.
No one including you will put my children in any type of problematic
situation do you see where we are going? Get a lawyer and get out of my
story. Steve Lindsey personally advised me that Leonard Cohen and Robert
Kory repeatedly encouraged him to take custody of my grandson away from my
daughter. I think their motive is more than obvious. I also understand that the
prosecutor used this matter, and my older grandsons horrific accident, to
discredit my daughter. That speaks volumes about what this woman is capable
of and she sounds positively evil and pathologically unstable. Steve Lindsey
has simply, as is his nature and pattern, lied about my daughter and fabricated
information. I have known Lindsey since 1992 and am aware that he cannot
tell the truth and does not handle his finances well or repay his debts. I could
go through Steve Lindseys declaration in greater detail but there is no need to
do so. His motive is obvious: he is an opportunist, horrendous father, someone
incapable of telling the truth, an individual who cannot take responsibility for
his actions or repay his debts, and will do anything he wants and that includes
destroying his sons life. My daughter became an inconvenience to Lindsey. He
had a new girlfriend, a celebrity mother-in-law, and baby on the way. He
wanted my daughter out of the picture and Leonard Cohen, being the brilliant
con man and manipulator that he is, also saw an opportunity. Cohen and
Lindsey also understood that my husband and I, as well as my daughter Karen,
lived in Texas at the time and would be unable to attend any hearings. We
moved to Texas after Kelley could no longer afford to employ us. Both of these
men understood that fact.
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DECLARATION OF ROBERT KORY
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1. Robert Kory begins his declaration by stating that he is representing

Leonard Cohen in the
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negotiations with my daughter. One can then safely assume that this
declaration has to do with those negotiations. This document is part of those
negotiations. In other words, it is a tactic.
2. Korys declaration states that he and Cohen have evidence
demonstrating that Ms. Lynch
stole over $8 million from Mr. Cohen over a period of approximately six to
seven years. Because of same, Mr. Cohen terminated Ms. Lynchs employment
in or about late October 2004. Since that time, we have attempted to negotiate
with Ms. Lynch to resolve the matter without the necessity of court
intervention. My daughter did not steal anything from Cohen and I am well
aware of the evidence, have handled that evidence, know for a fact that Cohen
was entirely familiar with it, and faxed or handed a great deal of it to him
personally. What evidence could Leonard Cohen have apart from the corporate
books, records, stock certificates, signed and notarized agreements, federal tax
returns, etc? There is no other evidence. There is his Complaint, which I have
reviewed with my daughter, and every word is a lie. I have addressed a great
deal of those lies and false allegations in my declaration. I have also explained
the types of offers Ive heard about including by Leonard Cohen personally.
3. Kory then presents his version of what happened when my daughter and
grandson stopped
by his office unannounced. I know for a fact that he fabricated stories about
Jonathan Maihart who, working as a messenger, stopped by his office and the
offices of two of Kelleys lawyers. No one else thought a Latino gang member
stopped by. Thats because no one else has the motive Robert Kory evidently
has. Jonathan Maihart, who Kory thought was Kelleys son John, when he
stopped by, is Persian. He was not in a gang when my husband and I knew him.
Kelley employed him briefly in an attempt to help this young man. We have not
seen him since her card company closed in 2005. I spoke with my daughter
and Ray, on the cell phone, immediately after they left Korys office. Ray told
me he thought his mother should have told Kory to go fuck himself. While I
do not approve of that language, it is what he said, and he told me the man was
aggressive and evil. He also said he had to go to the bathroom and wanted to
leave. Kelley and Ray confirmed that she spoke to Kory about Cohens tax
fraud, missing state tax returns, monies Cohen owes her, and their threats. Ray
confirmed that he has heard this information and told me personally that he felt
his mother should have mentioned the Kentucky Revenue Cabinet. Thats
how familiar my grandson was with the details. I remember that comment
specifically because it made me laugh.
4. I believe Kory has described criminal witness tampering when he states
When she finished
questioning Ray, she turned to me and stated, Ray is going to be my witness
when you try to destroy me and then she left. Ray was indeed a witness and
confirmed for me personally what he heard. He specifically advised me that his
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mother simply made statements to Kory and asked Ray if he had heard those
statements. Ray also told me that his mother told him, before they went in,
that he should be totally honest. And, Ray told me that before they went into
the office he told his mother he had to pee but they couldnt find a bathroom so
he told her to be quick and thats why he wanted to leave Korys office. My
grandson was not interrogated and it sounds like whoever Kory is, he has
hung around with Leonard Cohen for far too long. I am attaching Robert Korys
declaration to this statement.
DECLARATION OF BETSY SUPERFON
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1. I know Betsy Superfon fairly well and have spent considerable amounts of
time with her.
She was very close with Steve Lindsey and, at some point, attempted to insert
herself into my daughters life. They did seem to be quite close for a spell and
Kelley seemed to have fun with Betsy.
2. Betsy would frequently stop by Kelleys house, on the way to the casino,
and spend some
time with her. She and Kelley also spent some time shopping, took a trip to Las
Vegas at one point, and Betsy joined Kelley and her sons on a trip to Hawaii. I
spent time with the two of them as well.
3. Betsy Superfon told me that Lindsey or his lawyer faxed her this
declaration and she had no
idea what she was signing. She told me the only comment she had about Kelley
as a mother is that she was too good to her children. This particular
declaration, which appears to rely more on gossip than anything else, sounds
more like Steve Lindseys type of narrative than Betsys.
4. Ray was an exceedingly well behaved young man and that includes in
Kelleys presence and
my husband and my presence as well. He did not like to be around his father
and resisted spending time alone with him or staying at his house. He felt
more comfortable when Dinah Englunds niece and nephew were around and
he appeared to develop a crush on Englunds niece. At no time did my
daughter tell anyone, including Superfon, that she hoped Lindseys baby would
die. In fact, Kelley spent considerable time planning a baby shower for Dinah
Englund with Steve Lindseys mother. Judy Lindsey and Kelley gave Dinah a
baby shower at the Peninsula Hotel. I personally sent a gift as I was under the
weather. No one had any hard feelings. We were all very happy for Steve and
Dinah. Kelley is a mature adult and does not have a jealous nature. She is also
exceedingly generous. Kelley even took care of Englunds niece and nephew
while Dinah Englund gave birth to Lindseys baby. It is my understanding that
Lindsey and Englund have now parted ways and I assume a serious custody
issues will arise that, with Cloris Leachman involved, will not be as easy as the
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other two custody matters Lindsey has provoked were. Lindsey is incapable,
from what I can tell, of having adult relationships or parenting his children.
Hes not evil; he just simply is incapable of having these relationships. I would
like to note that I love his parents, Judy and Mort Lindsey, very much and we
had a long and wonderful relationship. Mort Lindsey died while Kelley was
incarcerated which is unconscionable. She and Mort were exceedingly close.
5. Kelley is an extraordinary cook and her sons were well fed and well cared
for. She can and
does cook anything and everything. My daughter prepared meals for my
grandsons since they were born. She also made them breakfast, packed their
lunches, nursed them while they were sick, assisted them with homework,
oversaw their education, hired tutors to help them, drove them and their
friends everywhere, and spent a tremendous amount of time with them. Betsy
Superfon is the individual who does not appear to know how to cook and
frequently suggested that she and Kelley order take-out from various
restaurants in Brentwood because she was in a hurry and wanted to get to the
Casino in time. I dont think Brentwood restaurants serve junk food. Kelleys
children were well provided for and lived a very comfortable and decent life.
Rutger told me his childhood was idyllic and his mother was his best friend.
Kelley also provided food and shelter for every teenager in the neighborhood.
His Holiness Kusum Lingpa advised her not to let Rutger out at night, or at all
actually, in Los Angeles and she decided to make a comfortable environment
where everyone was welcome if they behaved themselves. One man, Rameens
father, told Kelley he was eternally grateful for her assistance with his son.
Kelley let Rameen stay with her for the better part of a year while his parents
divorced. I recall this man asking her what religious beliefs she held because
he thought it was exemplary. My daughter has simply been demonized by many
people.
My daughter has read this declaration back to me and I have confirmed this
document with Paulette Brandt. I have also provided additional comments to
Paulette and authorized her to sign this document on my behalf. I am also
providing a separate declaration for my daughter to submit in connection with
Leonard Cohens restraining order against her. I am quite concerned about my
daughters welfare and the ongoing targeting of her, my grandsons, and
younger daughter. It appears that the individuals stalking, slandering, and
harassing my daughter would like her isolated, discredited, and intimidated.
My grandsons and have relentlessly targeted by these individuals for
approximately six years now.
I declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.
Executed on December 23, 2013, at Flower Mound, Texas (Joan Lynchs verbal
authorization) and Hollywood, California (Paulette Brandts residence).
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_____________________________________
Joan M. Lynch
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Motion Exhibit 5 - Declaration of Joan Lynch - 03.13.15 FINAL

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Motion Exhibit 5 - Declaration of Joan Lynch - 03.13.15 FINAL

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1

DECLARATION OF JOAN MARIE LYNCH

daughter. Except as to those matters stated on information and belief, I have

competently if asked to do so.

from Philadelphia, Pennsylvania to Los Angeles to be near Kelley and our

grandsons. We were extremely involved in the upbringing of our grandsons,

- 1 Declaration of Joan Marie Lynch

personal manager and in other capacities. From approximately 1996 through

representatives handling these matters. Those individuals included, but were

and corporate lawyer), Arthur Indursky (transactional lawyer), Don Friedman

(transaction lawyer), Stuart Fried (transaction lawyer), Jean Ransick

(bookkeeper), Burt Goldstein (accountant), Ken Cleveland (accountant), Peter

Shukat (transaction lawyer), Jeffrey Hafer (transactional lawyer), Jonas

Herbsman (transactional lawyer), Rich Feldstein (business manager), Peter

(estate planning attorney), Reeve Chudd (estate planning attorney), Herschel

Weinberg (personal lawyer and family friend), Greg McBowman (royalty

consultant), and others.

- 2 Declaration of Joan Marie Lynch

by default additional work fell upon our office. We generally transmitted

greeting card company. My duties included general office management tasks,

supervising all employees, handling the phones, receiving mail/faxes and

distributing them, communicating with Cohen and his representatives,

communicating with Adam Cohen and his representatives, communicating with

matters, ordering Canadian drafts for Cohens Montreal properties, faxing

information to Cohen and his representatives, transmitting phone messages to

balances, transmitting sales figures and royalty statements to Kelley and

Cohen, receiving and shipping FedEx packages, arranging for notaries,

as well as the corporate records.

- 3 Declaration of Joan Marie Lynch

been a General Contractor in Philadelphia, Pennsylvania and Cohen was having

difficulties with the completion of construction/renovation of his garage. At

During the garage renovation, Cohen had everything stored there

removed. That includes, but is

records. Cohen personally instructed me to make arrangements to pick up

numerous occasions. At the time, he appeared appreciative.

Given the fact that Kelley carpooled on a daily basis, from

approximately 1999 until 2005, she

at 6 AM or so from her home.

Leonard Cohen and Kelley also routinely had lunch together. In

preparation for their lunch

meetings, I would prepare copies of documents for Kelley to review at lunch

given instructions on how to respond to requests from his representatives, fans,

website hosts, record companies, etc.

From what I personally witnessed, Cohen was fully apprised of his

business affairs, financial

Leonard Cohen is a shrewd businessman who micro-managed, controlled, and

- 5 Declaration of Joan Marie Lynch

of Polygram, to discuss a possible intellectual property deal. Cohen continually

I am well aware of Kelleys compensation agreements with both

Leonard Cohen and Adam

- 6 Declaration of Joan Marie Lynch

lithographs, various activities related to Sasaki Roshis Zen centers (including

he owned worldwide, and a extraordinary assistance with his personal and

for her services as his

personal manager. Cohen and Kelley frequently discussed this matter in my

property. Additionally, Cohen promised her that he would have an accountant

commission for all years she worked as his personal manager.

During the time I worked with Kelley, Leonard Cohen actively

pursued numerous intellectual

- 7 Declaration of Joan Marie Lynch

respect to a third intellectual property deal. Cohen repeatedly expressed

behind these deals.

Leonard Cohen and Kelley had a very close business relationship

and friendship that I personally