Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
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___________________________________
Kelley Lynch
See Related Case File BC341120 (Ex Parte Application in Intervention for
Order Protecting & Preserving Documentary Evidence; Natural Wealth August
2, 2005 Complaint attached thereto as Exhibit A.)
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has threatened to take or has taken, improper and unlawful actions, including
bribery and intimidation of a witness [Kelley Lynch], subornation of perjury,
defamation, disparagement
These acts were not isolated, but all in furtherance of an improper and unlawful
scheme to extort and recover from Plaintiffs and their insurers losses allegedly
sustained by Cohen that, if they even occurred, were solely the result of
Cohens own exorbitant spending, his own neglect and mismanagement of his
financial, legal and personal affairs
Cohens extortion scheme was eventually exposed by Lynch and ultimately
frustrated
Detailed allegations of Cohens scheme to commit extortion against Plaintiffs,
his fraudulent statements and actions in furtherance of that scheme, and other
tortious conduct, and Plaintiffs damages and prayer for relief flowing
therefrom, are set forth below.
In addition, Cohen has made clear that he asserts rights over certain
investment funds that belong to Traditional Holdings, LLC (Traditional
Holdings), a dissolved Kentucky entity that was managed and 99.5% owned by
Lynch and 0.5% owned by Cohen.
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GENERAL ALLEGATIONS
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18. Cohen is a songwriter and singer who has been, and continues to be, a well
known celebrity.
19. Lynch was Cohen's [personal] manager and agent for approximately 20
years, until late 2004.
20. Throughout this 20-year period, Lynch handled Cohen's business affairs and
much of his personal affairs.
21. Throughout their 20-year relationship, Cohen repeatedly affirmed to the
public and to those working on his business affairs (including, but not limited
to, those working on his recordings, sales and investments) that Lynch handled
these affairs on his behalf, and that they were to treat Lynch as his exclusive
agent and representative. He provided her with various special and durable
powers of attorney to those ends.
22. Since at least 1995, and at least until late 2004, Cohen maintained
business addresses in Los Angeles, California. Cohens mailing address was 419
Larchmont, Suite [88], Los Angeles, California 90004 (the Larchmont
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Address). The Larchmont Address is a post office box only. [Suite 91 was
Lynchs management company address.]
The First Sony Sale
24. As a result of Cohen's success as a songwriter and singer, and under
Lynchs management, Cohen generated millions of dollars worth of royalties
and other intellectual property assets (together, Cohen's IP or IP).
25. From the early 1990s, impressed with a new strategy used by other
Hollywood celebrities to cash in on their future revenue streams from IP rights
and increase short-term income (called a "Pullman" or "Bowie" bond, after the
artist David Bowie who first used it), Cohen worked aggressively with
advisors, including Greg McBowman, to auction off portions of his IP to the
highest bidder.
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26. In or about 1996, representing that certain of these IP interests were held
by a shareholder corporation of his creation named Leonard Cohen Stranger
Music, Inc. ("Stranger"), Cohen commenced negotiations to sell Stranger to
Sony Music International (Sony) for $6.3 million (the First Sony Sale).
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37. Ultimately, Cohen decided to transfer some of the income from the First
Sony Sale into charitable remainder trusts. On October 30, 1996, Cohen
established [two charitable remainder] trusts: the Sabbath Day Charitable
Trust (the "Sabbath Day Trust"), the Cohen Family Charitable Trust (the "Cohen
Family Trust")
38. Approximately $5 million of the proceeds from the First Sony Sale was
transferred to the Trusts. Cohen contracted with TAS to invest the Trusts
assets.
39. These Trusts significantly decreased Cohens up-front tax exposure, and
also enabled him to draw down considerable funds to maintain his extravagant
"celebrity" lifestyle.
40. Cohen's consistent and prolific spending. Cohen repeatedly withdrew
large amounts of the Trusts assets. On repeated occasions, TAS notified Cohen
that Cohen was spending more than recommended. On one such occasion,
on April 13, 2001, Greenberg, on behalf of TAS, wrote to Cohen:
I am writing to you to discuss the income withdrawals youve received from
your portfolio and to provide you with some helpful guidelines for the future.
When we originally constructed your portfolio in 1997, you may remember that
we had extensive conversations about how much you required for your annual
living expenses. Accordingly, we budgeted for withdrawals of $300K/year.
[Cohen through] Lynch has assured me that much of this money went towards
business investments that will provide you some return in the future. . . . At
your current rate of withdrawals, you may continue to spend down your
investments. . . . . Please feel free to contact me anytime at (303) 440-6500
should you have any additional questions or concerns.
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41. Cohen responded to these warnings with additional demands for money,
or with complaints about the message. For example, during a telephone
conversation with Greenberg in June 2000, Lynch asked that TAS stop saying
that Leonard is spending too much. Leonard would be really offended to hear
this. Expenses are higher right now due to withholding of royalties and
expenses associated with [the] new album.
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52. Westins proposed plan had the following basic components: a limited
liability company which eventually became Traditional Holdings would be
created. Blue Mist would transfer certain IP assets to Traditional Holdings in
exchange for a deferred annuity, to be paid to Cohen beginning in about 10
years. Traditional Holdings would then sell the assets it received from Blue
Mist to Sony. The tax plan prevented Cohen, the annuitant, from owning more
than a de minimis interest in Traditional Holdings. Therefore, Cohen would own
less than 1%, and another person who ultimately was Lynch would own the
remaining LLC interest (more than 99 percent).
53. Westin outlined this proposal to Cohen and Lynch both orally and in a series
of letters and other written communications between October 2000 and
December 2000. See, e.g., Exh. 1 attached.
54. In these written communications, Westin explicitly warned Cohen that since
the annuity plan gave significant transactional control to Lynch, and also
potentially placed tax and other burdens upon her as majority shareholder, the
plan would work only if Cohen and Lynch maintained (as they had in the past) a
long-term relationship of personal and professional trust which would secure
their mutual obligations as manager of the obligor (Lynch) and annuitant
(Cohen). See, e.g., Exh. 2 attached.
55. Cohen carefully reviewed, understood, and signed off on the ownership
structure of Traditional Holdings including the fact that Lynch would own 99
percent of Traditional Holdings membership interests, so as (among other
reasons explained by Westin) to avoid any suggestion of self-dealing.
56. First, Cohen reviewed the Traditional Holdings Articles of Organization,
and reviewed and executed the Traditional Holdings Operating Agreement,
which set forth in detail the entitys ownership structure and managerial
procedures. See, Traditional Holdings Articles of Organization and Operating
Agreement (Exh. 3 attached).
57. Second, Cohen participated, at his request, in conference calls with Westin
and Lynch and Greenberg during which the structure was carefully
reviewed.
58. Third, Cohen talked about the structure of Traditional Holdings privately
with Lynch, including when he forced her to discuss it with him while he took a
bubble bath.
59. Fourth, in addition to several explanatory faxes he received from Westin
describing Traditional Holdings, Cohen communicated specific questions
relating to Traditional Holdings ownership and transactional structure, which
questions Westin answered in a letter written directly to Cohen on December 4,
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2000, and faxed (as with his prior memos) directly to Lynch and Cohen. See,
Exh. 2.
60. Moreover, regardless of whether Lynch owned 1 percent or 100 percent of
the shares of Traditional Holdings, Cohen knew or should have known that she
had or came to have authority through a durable power of attorney and
pursuant to her role as Traditional Holdings manager to act, and give
directions, on Traditional Holdings and on his own behalf. See, e.g., Exh. 3.
61. Likewise, no matter who owned the majority of shares of Traditional
Holdings, the obligation to fulfill a deferred annuity obligation to Cohen
remained the same. Thus, Cohen's interests in the firm (the long term annuity
payments) were identical, no matter how his purported ownership interest in
the assets were held and invested in the interim.
62. In December 2000, Westin created Traditional Holdings as a Kentucky
limited liability company. Lynch was named as the initial manager in the
Articles of Organization, and both Cohen and Lynch were appointed as
managers in the Operating Agreement. Id. Also in December 2000, Cohen
signed a Private Annuity Agreement with Traditional Holdings which document
sets forth Traditional Holdings annuity obligations to Cohen. See, Private
Annuity Agreement (Dec. 7, 2000) (Exh. 4 attached). Lynch signed the Private
Annuity Agreement on Traditional Holdings behalf. Westin maintained, and
continues to maintain, that the company and its annuity contract with Cohen
are legitimate under prevailing interpretations of the federal tax code.
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Sony completed its due diligence and approved Traditional Holdings role in the
Second Sony Sale.
68. In April 2001, the Second Sony Sale was completed. The gross proceeds of
the Second Sony Sale were approximately $8 million, less certain identified
costs, expenses, and holdbacks for undelivered work.
69. Of these proceeds, Cohen had already requested and received $1 million as
an advance in November 1999. Cohen was well aware of this $1 million
advance because it became the subject of a tax dispute with the Internal
Revenue Service in 2002. However, Cohens accountants [Westin and others],
including Ken Cleveland, managed to avoid the consequences of this tax
dispute, by convincing Sony to withdraw and reissue its 1099 in the amount of
$0.
70. Of the remaining proceeds of the Second Sony Sale, approximately $6.65
million was delivered to Traditional Holdings. Of this $6.65 million, the
following amounts were paid to cover the [Cohens] costs involved in closing
and negotiating the Second Sony Sale:
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None of these listed expenses had anything to do with either the formation of
the annuity plan or
with Traditional Holdings dealings with TAS or any other Plaintiff. Westin did
receive a modest fee for his work on the Traditional Holdings documents, and
for consulting with Sony on Cohen[s] behalf
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deliver contracts and agreements; and transact business of any kind or class on
behalf of Cohen. See Durable General Power of Attorney (Jan 31, 2002) (Exh. 5
attached).
Communications with Cohen and Lynch Regarding Traditional Holdings
and the Trusts
75. [Following the 2001 close of the Traditional Holdings, LLC deal] Agile
Group, LLC began to send official monthly statements to Cohen at the
Larchmont Address (the record address for Traditional Holdings) setting forth
the performance of the Traditional Holdings funds invested in the Agile Safety
Fund. See, e.g., Exhibit 6 (example of monthly statements sent by independent
outside administrator). In addition, Agile Group, LLC sent monthly [emails] to
Cohen which, as a courtesy, summarized [the asset valuation of Traditional
Holdings, LLC].
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76. TAS continued to send full monthly financial statements by first class
mail to Cohen that included reports on all accounts in which he held an
interest, direct or indirect, including the Trusts and Traditional Holdings. Id.
(example of monthly financial statements sent by TAS)
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and his tax lawyer] Westin. Cohens tax attorney Westin also was aware of and
in regular communication with [Cohen, Greenberg, Lynch, and possibly others]
concerning the shareholder loans and other aspects of the affairs and
management of Traditional Holdings.
82. The March 5, 2002 Traditional Holdings Board Meeting Minutes, prepared
[by Westin], state that the level of borrowing was undesirable and [the
members] expressed their assent that further borrowing was discouraged, even
though the borrowers [Cohens] credit and collateral were good.
83. Cohen, however, gave no sign that he had any intention of abating his
spending habits. In an e-mail to Lynch dated March 4, 2002, Cohen thanked
Lynch for keeping [him] informed, and instructed her to give lots of money
to everyone.
88. Because these shareholder loans were to be repaid, and because it was
necessary to protect the entitys integrity for tax purposes, these shareholder
loans were properly characterized, on Cohens tax attorney Westins [and
Greenbergs] advice, as Traditional Holdings assets when calculating the
entitys value.
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YOU TO CURB YOUR SPENDING OR YOU WILL OUTLIVE YOUR MONEY. See,
Letter from N. Greenberg to L. Cohen (June 25, 2004) (Exh. 8 attached).
Greenberg [evidently so concerned actually stood Cohen up after confirming
that he would fly into] Los Angeles to discuss Cohen's "quite desperate"
situation with him personally. Id.
The Pending Third Sony Sale
95. Lynch [gave] assurances that [Westin advised her that he would document]
all loans [with promissory notes] and assur[ed] that they would be paid off
when Cohen received the money from another, upcoming Sony transaction
[album delivery, tour, lithograph deal, etc.]
96. Indeed, beginning in 2003, Cohen (through Lynch) informed Plaintiffs of yet
a third sale pending to Sony (the Third Sony Sale)
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97. According to [projected figures], the Third Sony Sale [should] result in
upwards of $7.8 million
98. As part of Cohens preparation to close the Third Sony Sale Westin
prepared loan schedules for the payback of the Traditional Holdings loans from
2001 and 2002 and forwarded those schedules to Agile Group, LLC and TAS.
99. In October 2004, Cohen and Lynch had a major falling out, the details of
which remain unknown to Plaintiffs. As a result of this falling out, the Third
Sony Sale which appeared to be on the verge of consummation never
happened.
100. On October 21, 2004, [according to Greenberg] Cohen personally
contacted Greenberg by e-mail and informed him that Lynch was busy with
other aspects of [his] career, and therefore, Cohen had relieved her of all
financial responsibilities. Cohen further stated that Lynch need not be copied
on your statements or reports, and that Cohen's new accountant would be in
touch.
101. On October 22, 2004, Cohen sent another e-mail to Greenberg stating that
Lynch no longer represents me, and directing Greenberg not to respond to
any of her instructions. Cohens letter of termination [sent to Lynch after her
lawyers letter was received by Westin and Cohen] to Lynch was, according to
Lynch, backdated to precede the release of Cohen's most recent album, "Dear
Heather."
102. On or about October 24, 2004 [according to Greenberg], Cohen again
communicated directly with Greenberg by e-mail, stating that his business
address was no longer the Larchmont Address or Keniston Address. With
allegations flying fast and furious from Cohen and later Kory that Lynch was
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a. $2,084,518 had been deposited into Cohens own personal bank account;
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Friedman, and Ken Cleveland]. Specifically, they requested that she falsely
testify that [Cohens representatives defrauded him, engaged in fraud in the
inducement, etc.] Cohen sought to obtain this testimony from Lynch
125. Lynch's cooperation in Cohens extortion scheme was critical. [According
to Greenberg] Cohen believed that he could not only could use Lynch as a
witness against Plaintiffs, but could also buy or coerce her silence as against
himself at the same time
126. Thus, [according to Greenberg] Cohen pressed for private "mediation" as
an alternative to a public lawsuit, knowing full well that with Lynch's
cooperation and silence, many of the critical documents [would be concealed]
his aggressive tactics to avoid taxes at all costs, and his desire to capitalize on
and benefit from all of his intellectual property during his lifetime to fuel an
extravagant lifestyle would not be the subject of discovery. Thus, his
phony allegations would stand unrebutted.
127. Thus, by deliberate misrepresentations and omissions of critical
facts Cohen could knowingly and deliberately misrepresent his
objectives long history of aggressive tax management
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view that she, along with Cohen, was a victim of the misconduct of Plaintiffs
and Westin. While Cohen hoped that Lynch would support [him].
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136. Thereafter, on January 11, 2005, Kory wrote to DiMascio, telling her that
[former Los Angeles District Attorney Ira Reiner believed] properly framed
letters to Greenberg and to Westin would cause their insurance companies to
show up.
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137. Cohen and Kory then scheduled a meeting with DiMascio, with Kory
proposing that Cohen and Lynch both be present to endorse a final agreement
and secure full cooperation. [Lynch, as she had consistently done since
parting ways with Cohen refused to attend any meeting where he would be
present.]
138. Lynch declined to attend the meeting in person. Instead, DiMascio went to
the meeting on Lynchs behalf in early February 2005, after which she reported
to Lynch: [Cohen and Kory] want your cooperation in pursuing [the Plaintiffs]
and Richard Westin
139. Repeatedly, from at least November 2004 through April 2005, Kory made
known to Lynch, directly, through counsel, through Steve Lindsay (the father of
Lynchs youngest child and one of Cohens record producers), through others
that he had extraordinary negotiating authority from Cohen to "forgive" any
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a. contacting City National Bank, where Lynch, Lynchs son had personal
banking accounts, and convincing City National Bank to put a freeze on all
[their personal and business] accounts [based on fraudulent allegations and
rumors];
b. alleging that Lynch's father and mother were depositing funds for Lynch in
secret offshore bank accounts
c. threatening Lynch that she would go to jail if she did not cooperate, and
having her younger son's father, Steve Lindsay, who was also Cohens record
producer, repeat these threats in the child's presence;
d. threatening to "go to child services, encouraging Steve Lindsay to file legal
action to remove Lynchs younger (and his) son from her custody, and
submitting affidavits (from Kory and Superfon) supporting that effort;
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exposed their scheme to Plaintiffs, Cohen and Kory also continued to take
additional steps against Plaintiffs in furtherance of their extortion scheme
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152. In further pursuit of the scheme to pressure Plaintiffs into paying for
Cohens alleged losses, Cohen and Kory arranged a meeting with Plaintiffs and
their counsel to be held at an airport hotel in Denver, Colorado on June 5, 2005.
See, T. Barnett Aff. (Exh. 9) 32.
154. On or about June 2, 2005, Kory contacted the Courtyard by Marriott,
Denver International Airport hotels sales office and contracted to reserve a
conference room at the hotel for June 5, 2005.
156. Thereafter, on June 3, 2005, Plaintiffs provided Kory, as promised, a draft
complaint
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157. The draft complaint also revealed to Cohen and Kory, for the first time,
that Lynch and others had already exposed the extortion scheme. In particular,
the draft complaint demonstrated that Plaintiffs were aware of Cohens scheme
to use economic compensation, emotional intimidation, and other forms of
undue pressure to coerce Lynch to provide false testimony
158. Thereafter, on June 4, 2005, having learned that the scheme had been
disclosed, and notwithstanding the fact that they knew that Plaintiffs national
counsel had already arrived in Denver for the June 5 meeting, Cohen and Kory
cancelled their reservations with the Denver hotel, cancelled the planned
meeting, and thereafter refused phone calls from Plaintiffs national counsel.
159. Given Cohen and Korys conduct and threats, and their cancellation of the
Denver meeting which they themselves had proposed, Plaintiffs commenced
this lawsuit the next day by filing their Complaint in Boulder County District
Court, from which it was later removed to this Court.
Cohen and Korys Conduct and Communications Directed Towards
Plaintiffs in Colorado
Were Intended to Cause Injury in Colorado
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160. From about November 2004 until June 2005, as part of and in furtherance
of his scheme to extort funds Cohen, through Kory, engaged in a continuing
course of communications
163. [According to Greenberg] Cohen and Korys true purpose and motive
was to gather information that could be cast in a false light and used to extort
funds from
Cohen and Kory Carry Out Their Threats to Disparage and Defame
Plaintiffs
176. Acting with Cohens knowledge, authority and consent, and within the
course and scope of his agency, attorney, joint venture, and co-conspirator
relationships with Cohen, Kory immediately disseminated the press release to
various third parties, including, inter alia various industry and press
representatives, with the knowledge and intent that such third parties would
immediately cause the publication of the press release in industry publications,
and on interactive websites, including blogs, message boards, and the like, that
could be accessed in Colorado, in other states across the United States, and
throughout Canada.
178. Cohen and Kory knew that the false, disparaging, and defamatory press
release was not made in furtherance of any lawful objective or within the scope
of the litigation and that the intended recipients were not involved in or
closely connected with the litigation.
182. Cohen and Korys press release and Cohens additional statements and
publications were false, and known to be false when made, and/or omitted to
disclose or state material facts that were necessary to make the statements,
and their portrayal of [Kelley Lynch and possibly others were] inaccurate and
misleading.
183. Despite their continuing knowledge of falsity, Cohen and Kory have taken
no steps to retract these statements or to cause their removal As a result, the
false, disparaging and defamatory statements have continued to be published
to this day, and remain accessible to persons throughout the state of Colorado,
across the United States, and throughout Canada and the world.
Through Their Publications and Other Tortious Conduct, Cohen and
Kory Have Caused
Plaintiffs to Suffer Economic Injury in Colorado
185. Cohen and Kory also knew that their false, disparaging, and defamatory
press release and other statements and publications would be disseminated to
interactive websites that could be accessed
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and Betsy Superfon) are and/or were employed by and/or associated with an
enterprise within the meaning of C.R.S. 18-17-103(2).
252. [According to Greenberg] Cohen and the other co-conspirators not
currently named as Defendants herein (including Robert Kory, Steve Lindsay
and Betsy Superfon) knowingly conducted or participated, directly or indirectly,
in such enterprise through a pattern of racketeering activity, within the
meaning of C.R.S. 18-17-103 (3) and (5), and in violation of C.R.S. 18-17-104
(3).
253. [According to Greenberg] Cohen and the other co-conspirators not
currently named as Defendants herein (including Robert Kory, Steve Lindsay
and Betsy Superfon) conspired or endeavored to conduct or participate,
directly or indirectly, in such enterprise through a pattern of racketeering
activity, in violation of C.R.S. 18-17-104(4).
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(a) Mail fraud, within the meaning of 18 U.S.C. 1341 (See, supra 245(a));
(b) Wire fraud, within the meaning of 18 U.S.C. 1343 (Id.);
(c) Interference with commerce by threats, within the meaning of 18 U.S.C.
1951 (See, supra 245(f));
(d) Criminal extortion, within the meaning of C.R.S. 18-3-207 (See, supra
245(b));
(e) Bribing a witness [Kelley Lynch], within the meaning of C.R.S. 18-8-703
(See, supra 245(c));
(f) Intimidating a witness; within the meaning of C.R.S. 18-8-704 (See, supra
242(d));
(g) Tampering with a witness [Kelley Lynch], within the meaning of C.R.S. 188-707 (See, supra 245(a)).
255. The predicate acts described herein formed a pattern of racketeering
activity, were related to the conduct of the enterprise, and were related to each
other as part of the common plan described in paragraph 244 above.
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