From: Kelley Lynch <firstname.lastname@example.org>
Date: Tue, Mar 17, 2015 at 5:45 PM
Subject: Case No. BC338322 - Motion for Terminating Sanctions & Request for Judicial Notice
To: Jeffrey Korn <email@example.com>, "irs.commissioner" <firstname.lastname@example.org>, Washington Field <email@example.com>, ASKDOJ <ASKDOJ@usdoj.gov>, "Division, Criminal" <Criminal.Division@usdoj.gov>, "Doug.Davis" <Doug.Davis@ftb.ca.gov>, Dennis <Dennis@riordan-horgan.com>, MollyHale <MollyHale@ucia.gov>, nsapao <firstname.lastname@example.org>, fsb <email@example.com>, rbyucaipa <firstname.lastname@example.org>, khuvane <email@example.com>, blourd <firstname.lastname@example.org>, Robert MacMillan <email@example.com>, a <firstname.lastname@example.org>, wennermedia <email@example.com>, Mick Brown <firstname.lastname@example.org>, "glenn.greenwald" <email@example.com>, lrohter <firstname.lastname@example.org>, Harriet Ryan <email@example.com>, "hailey.branson" <firstname.lastname@example.org>, "stan.garnett" <email@example.com>, sedelman <firstname.lastname@example.org>, JFeuer <JFeuer@gibsondunn.com>, Feedback <email@example.com>, "USLawEnforcement@google.com" <USLawEnforcement@google.com>, firstname.lastname@example.org, "Perusse, Bernie (Montreal Gazette)" <email@example.com>
Cc: Paulette Brandt <firstname.lastname@example.org>
Pursuant to your suggestion of the other day, I enclose herewith the Motion for Terminating Sanctions, Motion Exhibits, three exhibits related to my declaration, Proposed Order, and Request for Judicial Notice.
Paulette Brandt will send you a separate email confirming your receipt of these documents. She is listed on the proof of service.
I have not attached most exhibits referred to in my declaration and will begin scanning them now. I will also scan the conformed cover sheet for both the motion and request for judicial notice as well as signature pages for all documents. Additionally, Paulette Brandt's declaration has a handwritten final paragraph which she approved as she was with me at Los Angeles Superior Court. These exhibits should be fully scanned later tonight.
I have enclosed, for your reference an exhibit index (which I placed behind the notice of motion/memorandum, Volume Covers (a total of four volumes were filed with the Court but we removed the first cover and simply left the Notice of Motion per the Court's instructions). All declarations were properly signed this time.
The hearing is scheduled for June 23, 2015. I have brought Gianelli and Walsh's ongoing harassment to the attention of Judge Hess. That would include with respect to my witnesses. Paulette Brandt is a witness and has provided me with numerous declarations.
Until Judge Hess rules in this matter, I will continue to address all legal issues that Gianelli writes me about with you, the attorney of record in this case, as he has not entered a formal notice of appearance in this case. It does seem as though he is moonlighting but that doesn't explain Cohen's fan, Susanne Walsh. I have also addressed these harassing emails (and witness intimidation/tampering) in the Proposed Order.
Finally, I included the documents you filed with Judge Hess without requesting judicial notice in my Request for Judicial Notice.
If you have a copy of a formal agreement with me (and any Cohen representative) relating to service by email (for which there are more formal rules when an individual is pro per), please email that to me. I agreed to no such request and no such request was made. Finally, I am appalled that your co-counsel, Michelle Rice, would provide the District Court in Colorado with incorrect contact information for me. She doesn't know me; does not represent me; had no authority to provide the court with any information; and I did not enter an appearance due to concerns about an attempt to cover up criminal tax fraud and obstruct justice. I brought these concerns to the attention of Judge Lewis Babcock. These tactics are unconscionable.
I noticed, while at Court, that you flied something on January 28, 2014. I was not served that document and was not here at the time.