Kelley Lynch's Son Provides Witness Statements Re. Tactics Employed by Leonard Cohen & Others, & Stephen Gianelli's Harassment

DECLARATION OF JOHN RUTGER PENICK

I, JOHN RUTGER PENICK, declare:
1.        I am a citizen of the United States who currently resides in Los Angeles, California.  I am the son of defendant, Kelley Ann Lynch.  I am over the age of 18 years.  I have personal knowledge of the facts contained in this declaration and if called upon to testify I could and would testify competently as to the truth of the facts stated herein.
2.         At some point in October 2004, my mother and Leonard Cohen parted ways.  She had worked as his personal manager for approximately 17 years.  It was my understanding that they parted ways because my mother hired a new accountant, was referred to tax lawyers, and issues arose with respect to my mother’s belief that Leonard Cohen had committed tax fraud.  My mother eventually reported those allegations to the Internal Revenue Service and other tax authorities.  Since that time, Leonard Cohen and others, including my stepfather Steve Lindsey, have engaged in malicious and abusive tactics directed at my mother, me, and my younger brother, Ray Charles Lindsey.
3.         In the fall of 2004 and early 2005, I understood that Leonard Cohen was attempting to force my mother into a deal or settlement.  I heard many conversations about this.  Steve Lindsey actually tried to encourage me to convince my mother to enter into a deal with Leonard Cohen that would be very attractive for her.  She refused to negotiate with Leonard Cohen, although he owed her a tremendous amount of money, because she felt he was asking her to provide false testimony against his representatives. 
4.         Steve Lindsey and my mother separated in 1997.  As of the fall of 2004, my stepfather, Steve Lindsey, was in a new relationship and his girlfriend, Dinah Englund, was pregnant with their daughter.  My mother had sole custody of my brother until May 2005.  The three of us lived together from 1997 until May 2005 when a custody matter was initiated.
5.         By the spring of 2005, Steve Lindsey, who had an abusive personality and temperament, was becoming increasingly aggressive and hostile towards my mother, brother, and me.  At some point, he hired custody lawyer, Daniel Bergman, and they pursued a completely concocted custody matter involving my brother, Ray Charles Lindsey. 
6.         I was present for the hearings in that case and know for a fact that the custody matter was based on lies.  My mother was a wonderful parent, provided us with a great environment, loved us, and was never even remotely abusive to either of us.  Steve Lindsey used fraudulent restraining orders as a tactic against my mother. 
7.           Both Steve Lindsey and Leonard Cohen owe my mother a tremendous amount of money and I believe they coordinated the custody and litigation matters to force her into deals with them.  From approximately May 2005, when the custody matter arose, until my brother was 18, Steve Lindsey failed to have my brother phone my mother although I was present when the Court ordered him to have Ray call her every other night.  Steve Lindsey also prohibited my mother and other members of our family from seeing Ray.  His lawyer, Daniel Bergman, refused to communicate with her although I was present when he was ordered to do so by the court.  It is my understanding that Daniel Bergman now represents Leonard Cohen in a related case.  I would assume he represents Leonard Cohen in order to further distress and harass my mother. 
8.         It is my understanding that Leonard Cohen’s October 2005 restraining order against my mother involved his declaration that addressed my brother’s custody matter and a May 25, 2005 SWAT incident at our home.  I would like to address these matters with the Court based on what I personally witnessed. 
9.         On the morning of May 25, 2005, my mother phoned and asked me to pick my brother up at the house.  Ray did not feel well that day, stayed home from school, and this caused Steve Lindsey to become angry which frequently happened with him.  My mother said Steve Lindsey, Ray’s father, had repeatedly called that morning and was becoming threatening and abusive.  My mother informed me that she did not want Steve Lindsey on our property and asked me to meet Steve Lindsey at the bottom of the hill with Ray.  Lindsey intended to drive Ray to school.  I personally spoke to Steve Lindsey who confirmed this arrangement.  As I was a block away, and Lindsey said he was in Beverly Hills, I immediately drove home, picked Ray up, and drove down the hill.  I was accompanied by my friend, Evan Reiss. 
10.       When I arrived home, my mother and Ray were waiting outside.  Ray was on the phone with his father.  I got out of my car, walked over to Ray, took the phone and informed Steve that I was leaving the house with Ray immediately, and handed the phone to my mother.  When I arrived at the bottom of Mandeville Canyon, Cloris Leachman, rather than Steve Lindsey, was waiting to take custody of Ray.  She waved me over and I dropped Ray off with her.  I then saw Steve Lindsey and approximately 7 or more LAPD squad cars racing up Mandeville Canyon Road.  I turned around, drove up the hill, and saw Lindsey speaking to the police officers.  I believe he was providing them with a lay-out of the property.  I explained to LAPD that my mother was in the house alone; I had just been with her, and confirmed that I had spoken with Lindsey moments earlier and we agreed that we would meet at the bottom of Mandeville where he would pick Ray up.  I also explained that I dropped my brother off with Cloris Leachman who was Lindsey’s girlfriend’s mother.  LAPD was uninterested in what I, and others, had to say and appeared to be relying specifically on what Steve Lindsey told them.  Steve Lindsey had not been to our house and was not in a position to tell LAPD anything.  I heard Steve Lindsey confirm that he called the police.  I later heard that my Aunt Karen, my mother’s sister, phoned LAPD but I have spoken with her directly and she assured me that this was not the case.  At some point, as the situation unfolded, Steve Lindsey received a phone call and left.
11.       The SWAT incident continued to unfold and would last for approximately three to four hours.  LAPD, based on what they were advised by Steve Lindsey, asked if my mother had access to a gun and/or weapon.  I confirmed for LAPD that my mother did not have a gun and/or weapon in her house.  I also confirmed that I, as I was over the age of 18 at the time, owned a rifle that was legally registered.  I explained to LAPD that I lived in a separate guest house on the property; my mother did not have keys to the guest house; the door was locked; and the gun was locked in my closet and locked inside a case.  My mother did not have keys to the guest house, closet or the case. 
12.       LAPD questioned me about our dogs.  I explained that we had two large Akitas.  Throughout the incident, LAPD advised me that they intended to shoot my mother; would let me stay and watch or take me somewhere; and planned to shoot our dogs.  At the end of the SWAT incident, LAPD personally informed me that our dog was the hostage and they were taking precautions.  I was also informed that Inglewood PD was present. 
13.       At no point did LAPD ask my mother to come out; approach our front door; attempt to phone her; or attempt to determine what was actually going on.  Nothing was going on other than the fact that my mother kept my younger brother home sick and Steve Lindsey became angry. 
14.       At one point, LAPD asked me to trick my mother into coming out of the house.  I therefore asked my mother if she would like a cigarette.  I believe LAPD felt that was her “hostage demand” although she did not have a hostage; they understood I had taken my brother down the street; and, she was in the house alone.  My mother came out of the house, with our dog Shadow on a leash, and asked LAPD “Who is my hostage?  My dog?”  My mother was wearing nothing other than a bikini and it was very clear that she did not have a gun or weapon and Shadow was on a leash.
15.       After a considerable amount of time passed, LAPD decided they would enter our house, neutralize my mother, and asked me to lead the way.  There were officers on our hillside and crouched under the windows.  I believe assault weapons and bean bag guns were deployed.  LAPD directed me to lead them into the house.  I followed their instructions and we noticed that my mother was in the backyard.  LAPD rushed through the house into our backyard.  At that time, my mother dove into the pool.  I witnessed this.  When my mother surfaced, she asked an LAPD officer not to “hurt” her and he replied that they were not there to hurt her but were there to help her.  Without questioning my mother or explaining why, LAPD handcuffed my mother.  As she was only wearing a bikini, I went inside, noticed that my mother had locked Shadow in the bathroom, and grabbed a brocade jacket for her.  LAPD then led my mother out front.  Two officers pulled up and my mother was placed into the back of the car.
16.       A woman who identified herself as Erma Oppenhein asked me if I was okay and wanted to know if my mother was on any medications.  I responded that I was okay and informed her that my mother was on heart and asthma medication.  These officers then drove off with my mother. 
17.       Shortly after LAPD left, I received a phone call from Steve Lindsey.  He asked me if I would go into Leonard Cohen/Robert Kory’s office and sign over/transfer our house to Cohen and/or Kory.  I recall Lindsey asking me to have my mother formally committed and he mentioned their wanting me to sign some paperwork to this effect.  I was 18 years old at the time.  I decided to phone my father, Douglas Penick, who advised me to speak to a lawyer first.  I decided not to return Steve Lindsey’s call.  Lindsey also informed me that, if I agreed to sign over/transfer our house to Leonard Cohen and/or Robert Kory, Cohen would provide him with money and they would assist me financially.
18.       When my mother was taken from our house, LAPD informed me that they intended to search the premises.  They did not appear to be in possession of a search warrant for either my mother’s house or my guest house.  I stayed while they searched and found nothing.  They confirmed that there was no hostage.  LAPD also searched my guest house and understood that my rifle was locked in the guest house; locked in my closet; and locked in a case.  LAPD removed my rifle from our property.  They did not give their reasons for doing so.  I later received a call from LAPD advising me that I could pick the rifle up from West LAPD.  My mother and I picked it up and LAPD had removed the lock from the case.           
19.       After the SWAT incident, my mother phoned and informed me that LAPD had taken her to King Drew Hospital in South Central.  I was in shock that LAPD would take my mother to South Central.  UCLA was approximately 10 minutes from our home.  She explained that Dr. D’Angelo, who worked at King Drew, advised her to wait her turn and she would be promptly released.  Dr. D’Angelo also confirmed for me that my mother was being released.  Evan Reiss and I drove to King Drew to pick my mother up.  At the hospital, Dr. D’Angelo came outside to speak to me and confirmed that he was releasing my mother and did not agree with LAPD’s assessment that she was dangerous to herself and/or others.  He also confirmed that there was nothing in the file that would cause my mother to lose custody of my brother.  My mother was concerned that the SWAT incident was being used to coordinate a custody matter.  We would later find out that her concerns were valid.  My mother also informed me that LAPD questioned her about Phil Spector and possible gun incidents on the way to King Drew.  She couldn’t figure out how LAPD understood she knew Phil Spector.
20.       My mother, who was picking up her property while I spoke with Dr. D’Angelo, then walked out of King Drew.  Evan and I drove her home.  Ray called while we were driving home but, at that time, we didn’t realize Steve Lindsey had filed a custody matter with LA Superior Court.  The custody matter was filed due to the SWAT and Killer King incidents.  My mother explained that she was drugged against her will at King Drew and discussed how dangerous the environment was.
21.       At this time, due to the King Drew and SWAT incidents, Steve Lindsey also obtained a restraining order against my mother.  My mother is the individual who was abused by Steve Lindsey and simply did not want him on our property due to his own aggressive behavior.  I do know for a fact that Ray felt tremendous pressure and fear when his father would lose his temper.  I believe the custody matter, SWAT incident, and restraining orders were used tactically to discredit my mother and prevail in numerous lawsuits that would be brought against her by Leonard Cohen and Steve Lindsey.
22.       Once we learned that a custody matter had been filed, we also discovered that Betsy Superfon, a friend of Steve Lindsey’s, and Leonard Cohen’s lawyer, Robert Kory, submitted declarations in that matter.   Betsy Superfon would later inform me personally that she didn’t know what she was signing when she signed the declaration Lindsey provided her.  Betsy also told me she felt my mother, if anything, was too good to me and my brother. 
23.       Robert Kory’s declaration involved allegations that my mother misappropriated monies from Leonard Cohen and addressed the time my mother and brother stopped into his office.  My mother attempted to speak to him about legal and business matters between her and Leonard Cohen. 
During my mother’s 2012 trial, my brother’s custody matter was raised as an issue.  Robert Kory testified that my mother “interrogated” my brother at his office.  I have spoken to my mother and brother about this matter, including immediately after it occurred, and both confirmed that my mother simply asked Ray some questions related to information he had heard about Leonard Cohen’s tax fraud, missing state tax returns, her share of intellectual property and commissions due her, and their threats to put in her in jail.  Those threats were repeated to me and my brother in the spring of 2005 by Steve Lindsey who said he would assist Leonard Cohen.  I also personally heard information about Leonard Cohen’s tax fraud, missing state returns, my mother’s share of intellectual property and commissions due her, and her requests for tax information.
24.       On April 15, 2005, my mother reported Leonard Cohen’s tax fraud to Agent Betzer, Internal Revenue Service.  She had previously reported it to other tax authorities. 
25.       Steve Lindsey and Daniel Bergman refused to allow me to see Ray.  The entire custody matter was based on lies and I believe it was meant to crush and destroy my mother.  It was also used to pressure me and Ray. 
26.       Leonard Cohen would also use restraining orders to discredit my mother.  My mother has never threatened Leonard Cohen.  Leonard Cohen and his lawyers have refused to communicate with my mother for approximately 10 street years and I believe it’s to say that the situation is thoroughly frustrating.  I have been copied on her emails since the spring of 2005 and at no time did I read anything that was threatening or harassing towards Leonard Cohen or anyone else.  My mother is the individual who has been relentlessly slandered, harassed, threatened, and intimidated.
27.       In the Spring of 2005, my mother was advised by His Holiness Kusum Lingpa to document everything we were going through in emails with witnesses copied in.  I was frequently copied on those emails.  The primary reason for my mother’s emails was to document everything she had gone through since she reported the allegations that Leonard Cohen committed criminal tax fraud to Internal Revenue Service.  The emails, as my mother has explained many times, are documenting everything for the Internal Revenue Service due to the retaliation over tax matters.  The custody matter was clearly coordinated by Leonard Cohen, Steve Lindsey, and their lawyers.  It was my understanding that my mother lost the custody matter because, due to her financial circumstances, she was unable to afford a custody lawyer; the tactics used against her have been malicious; and the results of these actions led to a default that caused the Court to give Steve Lindsey custody of my brother.
28.       Leonard Cohen filed a retaliatory with a lawsuit (LA Superior Court Case No. BC338322).  I have submitted declarations to Los Angeles Superior Court confirming that my mother was not served Cohen’s lawsuit; we did not have a co-occupant or know anyone who resembled the individual the process server said he served; my mother did not resemble the individual; no one attempted to evade service; and my mother has relentlessly address this matter for years.  I have also submitted declarations addressing the fact that I was present when my mother asked Chad Knaak, a friend of mine who lived with us at the time, to call Cohen’s lawyer and advise him that she was not served the lawsuit and if he attempted to serve her she would hold him personally accountable for emotional distress.  She also asked Chad Knaak to advise Leonard Cohen’s lawyer that she viewed this lawsuit as Cohen’s attempt to cover up tax fraud.
29.       At the time Lindsey filed the custody matter, he owed my mother a tremendous amount of money and that seemed to be part of his motive.  I also understood that he had been meeting with Leonard Cohen and Robert Kory about my mother.  Steve Lindsey refused to pay my mother what he owed her for Ray’s upbringing and support.  He also refused to repay her for monies she expended on behalf of his daughter, Jennifer Lindsey, who lived with us before my mother and Lindsey broke up in 1997.  Leonard Cohen also owed my mother money and, after they parted ways, stopped paying her.  My mother had also loaned Steve Lindsey money.  He simply refused to address these matters and permitted my mother to end up homeless. 
30.       I have addressed the fact that my mother was not served Leonard Cohen’s lawsuit.  I have witnessed my mother’s attempts to address this with Leonard Cohen and/or his lawyers.  She was always told that they would not speak to her and hung up on her.  They refused to respond to her emails addressing this, requests for tax information, and other business and legal matters.
31.       As of the summer of 2005, my mother’s phone was shut down at some point and many people (including Paulette Brandt, Palden Ronge, Yongzin Rinpoche, Choegon Rinpoche, and Lama Lhanang) kept in touch with us by stopping by the house.  Various people brought food, supplies for our animals, and others items.  As I was forced to take a job at Whole Foods, I also purchased items for my mother.  My mother had no money by this time.  Leonard Cohen and Steve Lindsey refused to pay her what they owed her.  It was my understanding that Leonard Cohen would pay my mother what he owed her if she testified against his representatives.  It was also my understanding that Sergeant Joe, who monitored my mother’s July 2005 visit at Roxbury Park with my brother (although she was the abused party), advised her to go into Daniel Bergman’s office and make a deal that would make her happy.  She refused to negotiate under these terms and conditions.  I drove my mother to meet with my brother and Sergeant Joe.   
32.       In mid-October 2005, Leonard Cohen’s lawyer showed up at our house with the Sheriff’s Department.  LASD searched our house and took many items.  I was present and they said they were permitted to seize anything with Leonard Cohen’s name on it.  My mother was upset because they took her business and personal files and items.  The Sheriff’s Department returned and seized items that were in our garage since we moved to 2648 Mandeville Canyon Road.  My mother had stored these items as a favor for Leonard Cohen for years. 
33.       For years, my mother stored boxes of old business documents of Leonard Cohen’s in our garage.  He had renovated his garage and my mother agreed to store these items for him.  I have spent a considerable amount of time with Leonard Cohen and my mother – at her office, his home, and at our home.  I also know his son and daughter, Adam and Lorca Cohen.  My mother worked as both Adam and Leonard Cohen’s personal managers.
34.       On December 28, 2005, my mother and I were evicted from our home.  She ended up homeless in Santa Monica.  I went to live with family friends.  For a period of approximately one year my mother was essentially homeless.  I personally believe Leonard Cohen and Steve Lindsey, together with their lawyers, intentionally bankrupted my mother so she would be unable to defend herself. 
35.       By January 2007, my mother was living with an elderly woman in Santa Ana, California.  On February 3, 2007, I was in a serious industrial accident at Whole Foods.  I was not trained or qualified to work on the meat grinder which we later found out had not been functioning properly for some time.  The safety guard was removed without my knowledge.  This led to the loss of my fingers and part of my hand.  I understand that Leonard Cohen testified, at my mother’s 2012 trial, that she blamed him for this accident.  That is a blatant lie.  My mother understood that Whole Foods caused this accident.  In fact, my mother repeatedly contacted the District Attorney’s office about this matter and asked them to investigate potential criminal negligence. I was copied on some of the emails my mother sent the District Attorney’s office and their failure to investigate upset my mother tremendously. 
36.       My mother was aware that Leonard Cohen and Steve Lindsey owed her a tremendous amount of money and, if they paid her what they owed her, I would have been in college.  I felt the same way.  I am aware that corporate records exist proving that my mother has an ownership interest in numerous corporate entities and Cohen related intellectual property.  I am also aware Leonard Cohen offered my mother numerous settlements.  I personally heard that my mother was offered many types of settlement offers, including  50% community property, by Cohen and/or Kory.  I am also aware that Leonard Cohen refused to pay my mother for commissions due her.
37.       In the spring of 2007, my mother came to stay with me for a spell.  Yongzin Rinpoche and his wife, Clea Surkhang Westphal, then invited my mother to visit with them at their home outside of Boulder, Colorado.  My mother relocated to Colorado in the spring of 2007.  Eventually my mother took a long term temporary position with Deneuve Construction in Boulder, Colorado which she seemed to enjoy. 
38.       I did hear, from time to time, that Leonard Cohen and Steve Lindsey, together with their lawyers, continued to harass my mother in Colorado.  I was also copied in on emails throughout this period of time.  Those emails asked Leonard Cohen, or his lawyers, to provide my mother with IRS documentation; a corporate accounting; monies due my mother; and she also attempted to address the fact that she was not served Leonard Cohen’s lawsuit.  I actually met with my mother’s attorney, David Moorhead, in Boulder, Colorado and confirmed a great deal of this information for him. 
39.       I understand that at some point in 2008, Leonard Cohen flew into Boulder, Colorado to obtain yet another restraining order against my mother.  Leonard Cohen, and his lawyers, have gone to extraordinary lengths to target and discredit my mother.  It is my understanding that the Boulder Court informed my mother that the Colorado order expired in February 2009.  I know for a fact that she believed the original Boulder, Colorado order expired.  She believed this before she was arrested in March 2012.  Apparently Leonard Cohen registered the foreign Colorado order, my mother was unaware of that fact, and this created a new domestic violence order although my mother was never in a dating relationship with Leonard Cohen. 
40.       At some point in 2008, while my mother was still staying with Yongzin Rinpoche and his family, I received a phone call from an insurance company lawyer.  The individual advised me that they represented the insurance company for Thomas Bradshaw.  On June 13, 2005, Thomas Bradshaw rear-ended my mother, knocked her unconscious, broke her nose, caused head trauma, and injured our shitzu, Charlie, who eventually died.  This lawyer informed me that Thomas Bradshaw lied to the police about that accident and they wanted my mother to testify for them and against him.  I called my mother, passed along the message, and provided her with the lawyer’s name and number. 
41.       Immediately following the June 13, 2005 accident, LAPD again came to our house.  Due to the SWAT incident, my friend and I informed LAPD that my mother did not want them to enter our house.  They disregarded our statements, pushed past us, walked back to my mother’s room, demanded that she hang up the phone, and took her out of the house in handcuffs although she was sitting in her room, quietly speaking to her friend on the phone, and was injured and bleeding.  My mother had gone out to buy dog food when she was rear ended on Mandeville by Thomas Bradshaw.  At first, when I saw my mother, I thought Steve Lindsey hit her.  She was completely discombobulated and unclear about what had happened.  I believe she thought I was in the car accident.  I saw the accident site.  This time LAPD took my mother to UCLA.  She was there for approximately 24 hours; I thought she was in the Emergency Room the entire time; and, she was released and came home.  UCLA confirmed that my mother had head trauma due to this accident.  My mother explained that LAPD visited her in the UCLA Emergency Room and confirmed that they understood she had been rear-ended. 
42.       After LAPD left our house this time, I noticed that someone had tried to break into the house, while my mother and I had been out that evening, and the bathroom window and mirror were both broken.  I decided not to contact LAPD about earlier break-in due to their conduct with my mother. 
43.       In or around June 2009, I discovered Blogonaut’s Law Blog, owned by Stephen Gianelli, which appeared to be dedicated to slandering and discrediting my mother.  Stephen Gianelli, an absolute strange, has now spent over six years harassing and stalking me, my brother, mother, other family members and friends.  His obsession with us relates to Leonard Cohen, IRS matters, and the Phil Spector case.  My mother is a close personal friend of Phil Spector’s.  I have known Mr. Spector since I was quite young and last saw him after the incident in his home.  He picked my mother up and took her out to dinner.  Stephen Gianelli, and others, have also harassed my mother over the SWAT and King Drew incidents, Ray’s custody matter, and the incident at Phil Spector’s house.  I have been copied on these harassing emails.  It is my understanding that Phil Spector personally informed my mother that the incident at his house was a suicide. 
44.       Stephen Gianelli seems intent on slandering and discrediting my mother; isolating her from friends and family; scaring people and turning them against her; and harming my mother.  He also appears to intimidate, threaten, stalk, and harass witnesses or people who are supportive of my mother. 
45.       In June 2013, I received a disturbing email from Stephen Gianelli me that my mother had returned to Los Angeles (which I, of course, knew) and explaining that he had communicated with the City Attorney of Los Angeles who planned to arrest my mother again.  By that time, I understood my mother had spoken to the FBI about the situation with Gianelli and LAPD had evidently informed my mother to maintain all emails from Gianelli and Walsh.  I decided to reply to see what Gianelli had on his mind and attempted to be cordial in my response.  His email alarmed me and caused me to become concerned about my mother’s welfare.  Gianelli continued to slandered my mother to me and my brother horrendously and continued to falsely accuse of her of many things.
46.       From approximately November 2012 for nearly two years, Stephen Gianelli (and Leonard Cohen’s fan, Susanne Walsh) wrote the City Attorney’s office falsely accusing my mother of many things, slandering her horrendously, and harassing all of us.  Stephen Gianelli and Leonard Cohen’s fan, Susanne Walsh, were essentially using the City Attorney’s office to harass my mother.  I was copied on those emails.  My brother and other members of our family and friends were also copied on these emails.  My mother continuously advised the City Attorney that she did not want to be copied on emails to them.  She was concerned about me and my brother and attempted to address the slanderous allegations made to numerous government officials.  The City Attorney never bothered to respond and we continued to be harassed.  At that time, Ray and I were residents of Los Angeles.  Not too long ago, Stephen Gianelli and Susanne Walsh resumed writing the City Attorney and continued to copy me.  My mother also attempted to refute false allegations and information being presented by these strangers to the Los Angeles City Attorney, District Attorney, and other government officials.
47.       In July 2013, my brother wrote Stephen Gianelli and Susanne Walsh to advise them that their emails were making him physically ill.  My brother has been harassed by these individuals, and others, since he was a minor.  Leonard Cohen’s lawyer, Michelle Rice, has been copied on some of the harassing emails sent by Gianelli and Walsh.  Following my brother’s email to Gianelli, Walsh, and others, I also wrote Stephen Gianelli to advise him to stop targeting my mother because she was poor and unable to defend herself. 
48.       It is my understanding that Leonard Cohen has somehow obtained a domestic violence order against my mother and testified during her 2012 trial that they were “lovers.”  I spent a tremendous amount of time with my mother – including at her offices – and also worked for Amazing Card Company when it was located one block from Leonard Cohen’s house and in Santa Monica, California.  I would also visit Leonard Cohen’s apartment with my mother.  At no time did I hear or witness anything that would lead me to believe that my mother and Cohen were or had been in any type of dating or engagement relationship.  I always personally felt that Leonard Cohen and Steve Lindsey were obsessed with my mother and behaved like jealous men towards her.
49.       My mother and I have always been extremely close and she tells me everything.  I know how she felt about Leonard Cohen and she hated to stop by his house alone and frequently complained that he sexually harassed her, exposed himself to her, and once looked at people defecating on one another online in front of her.  She mentioned that last detail to me because she was concerned that Ray might see these types of things online. 
50.       At some point, Steve Lindsey told me personally that Leonard Cohen and his lawyer, Robert Kory, came into his office and advised him that my mother had sex with Oliver Stone who is a friend of ours.  I have known Oliver Stone since I was quite young.  He was a friend of His Holiness Kusum Lingpa; helped with His Holiness’ Buddhist center; and spent time at our home.  I have also spent considerable time at events with my mother and Mr. Stone.  One time we attended a private audience with the Dalai Lama together.  Oliver Stone’s wife and baby were with us for that audience and at other times.  At no time did I ever witness anything other than a friendship between Mr. Stone and my mother.  Steve Lindsey was furious about this accusation and I believe it was used to stir up a custody matter.  Steve Lindsey also asked me if my mother’s friend, Richard Rutowski, was my mother’s boyfriend.  Apparently, Leonard Cohen and his lawyer also told Lindsey that my mother and Richard Rutowski were having an affair when they were together.  Richard Rutowski, who was a friend of Oliver Stone’s, was our family friend, also helped with the Buddhist center, and was not my mother’s boyfriend. 
52.       I believe our lives were destroyed because Leonard Cohen and Steve Lindsey owe my mother money and my mother reported the allegations that Leonard Cohen committed tax fraud to Internal Revenue Service.
53.       I would like to confirm that for approximately 10 years now, my mother has attempted to ask Leonard Cohen for IRS documents she requires.  He has apparently refused to provide her with this information.  This situation has been addressed in countless emails I have been copied on over the years.  My mother has also attempted to refute the slanderous emails sent to me, my brother, her friends, and many others.  She has constantly advised me that Stephen Gianelli is not an attorney of record in any Leonard Cohen matter but he writes as though he is defending Leonard Cohen legally.  I have received countless legal opinions from him regarding Leonard Cohen matters. 
54.       I would like to advise this Court that my mother is a wonderful human being; does not have mental health issues; has never had substance abuse problems; and is the individual who needs protection. 
55.       I offered to testify during my mother’s 2012 trial; was available to testify in the related case she is presently involved with regarding Leonard Cohen; and have provided my mother with declarations. I personally believe this is why I have been relentlessly targeted, stalked, and harassed.
56.       I think it is important for this Court to understand that my mother, brother, I, and many others, have been relentlessly harassed by many parties for years now.  We have specifically been harassed over Leonard Cohen and these legal issues.  I am not a party to any lawsuit related to Leonard Cohen and there is no reason for people to harass me over Leonard Cohen legal issues, IRS matters, or the default judgment he obtained.  At times, Leonard Cohen’s lawyers have been copied on harassing emails sent to me personally. 
57.       At no time did my mother intend to harass or annoy Leonard Cohen.  She has relentlessly advised the parties harassing us to cease and desist.  I have advised them to cease and desist.  My brother asked them to stop sending these emails.  My aunt’s attorney advised Stephen Gianelli to cease and desist.  It is my personal belief that Stephen Gianelli, and others, have intentionally attempted to provoke my mother by harassing me and my brother. 
58.       I  also recall Stephen Gianelli writing Daniel Bergman, now Leonard Cohen’s lawyer, at one point, and advising him that he would be willing to provide a declaration in Ray’s custody matter although this man does not know any of us and has no valid or legal reason whatsoever for contacting us.  My brother was a minor when Stephen Gianelli, Susanne Walsh, and others began harassing him.  My mother was concerned that some of these adult strangers could potentially be sexual predators and brought this to the attention of the District Attorney, City Attorney, LAPD, and others.  I was copied on many of those emails.
59.       Leonard Cohen, Steve Lindsey, and others, have used devious tactics with my mother and have continuously benefitted from their deceitful and abusive conduct. 
I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct.
This declaration is executed on this 21st day of July 2015 in Los Angeles, California.

                                                            ____________________________________
                                                            JOHN RUTGER PENICK

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