REQUEST FOR JUDICIALCLARIFICATION OF AMBIGUITIES INDEFAULT JUDGMENTFILED MAY 15, 2006

The default judgment entered May 15, 2006 in Case No. BC 338322 is ambiguous and overly broad as to numerous federal tax and corporate matters. Defendant Kelley Lynch asks this Court to clarify the following issues the judgment raises:

1. Kelley Lynch has a legal 15% ownership interest in Blue Mist Touring Company, Inc. The assignments are non-revocable, were not removed from this entity, and remain there. Lynchs partnership interest was not addressed on the federal tax returns, prepared by Cohens account, when she was compensated with a 15% ownership interest in or around 1998. The judgment states that Lynch is not the rightful owner in any assets in Blue Mist Touring Company, Inc. and alleges that Lynchs shares were held in her alleged capacity as Trustee for the benefit of Leonard Cohen. Lynchs shares were not held in this capacity and there is no evidence to support that including, but not limited to, Richard Westins November 2004 email. Lynch would like the Court to clarify how this determination was made; what assets were in this corporation; what Trust or other document was submitted to the Court proving that Lynch held her shares as trustee for Cohens equitable title ; what the stock certificates she was issued represent; how compensation from a corporation (as noted in the Minutes addressed in the Complaint) represents her fees for services rendered to Cohen personally as his personal manager; what value the Court placed on these assets; and, how the Court obtained jurisdiction over a party not named in the complaint, a Delaware corporation whose California business registration was suspended by the FTB. Finally, Lynch asks the Court to clarify whether or not the Court views this judgment as a formal corporate dissolution of the Delaware entity.

2. Kelley Lynch has a legal 99.5% ownership interest in Traditional Holdings, LLC. Although Cohen and Westin assured Lynch that the assets owned by Blue Mist Touring Company, Inc. would be formally transferred from Blue Mist Touring Company, Inc. to Traditional Holdings, LLC at the time she was asked to provide Richard Westin with a limited Power of Attorney to form this entity, no assets were transferred or assigned to Traditional Holdings, LLC. Tax returns were submitted to Internal Revenue Service for the years 2001, 2002, and 2003. Those returns were prepared by Leonard Cohens personal corporate and tax lawyer, Richard Westin. Lynch was included on those returns as a partner, K-1 partnership documents were transmitted to Internal Revenue Service, and Lynch paid taxes in accordance with those documents. The judgment states that Lynch is not the rightful owner in any assets in Traditional Holdings, LLC and alleges that Lynchs shares were held in her alleged capacity as Trustee for the benefit of Leonard Cohen. Lynchs shares were not held in this capacity and there is no evidence to support that allegation. Lynch would like the Court to clarify how this determination was made; what assets were in this corporation; what Trust or other document was submitted to the Court proving that Lynch held her shares as trustee for Cohens equitable title; what the stock certificates she was issued represent; what value the Court placed on these assets; and, how the Court obtained jurisdiction over a party not named in the complaint, a Kentucky business that never registered to do business in California and does not have any ties to California. It does not have a place of business, business address, phone number, payroll, and /or a bank account in California. Leonard Cohen submitted an Affidavit in the Natural Wealth Case in Colorado attached to Lynchs declaration as Exhibit IIII. That Affidavit addresses payments to be made to Lynch, with respect to her promissory note, for the years 2001 through 2004. These amounts appear as misappropriations on the expense ledger and are not identified as legitimate corporate distributions. Does the Court believe this proves the expense ledger is fraudulent? How can this be rectified? Did the Court simply assume that Leonard Cohen was correct when he took the position that payments made with respect to the corporate books and records (including the two payments in the management agreement; corporate records re. Class A and B stock; and profit/loss sharing) were fraudulent even though they were agreed upon and confirmed in Richard Westins March 6, 2002 letter that Cohen confirmed receiving at the time? This letter was referred to the Complaint.

Finally, Lynch asks the Court to clarify whether or not the Court views this judgment as a formal corporate dissolution of the Kentucky entity and whether the 2001, 2002, and 2003 federal tax returns are fraudulent.

3. Kelley Lynch has a 15% ownership interest in Old Ideas, LLC. Although Cohen and Westin assured Lynch that this Delaware entity was formed as a partnership in June 2004, Lynch has not been provided with any tax information. She has no evidence that the intellectual property that was to be assigned to this entity was actually assigned. That would include, but is not limited to, all intellectual property related to Cohens 2004 studio album Dear Heather. The judgment itself does not mention this entity. The language states that any interest she has in any legal entities set up for the benefit of Cohen she holds as trustee for Cohens equitable title. Lynch did not hold her shares in any entity, including Old Ideas, LLC in equitable title for Leonard Cohen. Lynch would like the Court to clarify how this determination was made; what assets were in this entity; what Trust or other document was submitted to the Court proving that Lynch held her shares as trustee for Cohens equitable title; why Richard Westin confirmed in June 2004 emails that this entity was a partnership for income tax purposes; what value the Court placed on these assets; and, how the Court obtained jurisdiction over a party not named in the complaint at all. Finally, Lynch asks the Court to clarify whether or not the Court views this judgment as a formal corporate dissolution of this Delaware entity.

4. While Leonard Cohens declaration, in support of the judgment, and the Complaint itself states that he is the sole owner of LC Investments, LLC, this entity transmitted K-1 partnership documents to the State of Kentucky and Internal Revenue Service for the years 2003, 2004, and 2005. These K-1 partnership documents indicate that Lynch is a 99.5% owner of this entity. The documents indicate, and this was reported to the Internal Revenue Service and State of Kentucky, that Lynch received $0 income from this entity for the years 2003, 2004, and 2005. The fraudulent expense ledger shows income to Lynch for the years 2003 and 2004. Lynch would the Court to clarify whether she did or did not receive income. If she did not receive income, Lynch would like the Court to confirm that the ledger is fraudulent. If she did receive income, Lynch would like the Court to clarify the actual amount of income received. No assets were assigned to LC Investments, LLC. They are owned by Blue Mist Touring Company, Inc. Lynch would like the Court to clarify if the income she allegedly received from LC Investments, LLC (according to the expense ledger but not according to the K-1s transmitted to the tax authorities) is actually income from Blue Mist Touring Company, Inc. and whether she should receive a tax document from Blue Mist Touring Company, Inc. for the years 1999 through 2004.

5. How did the Court determine that Leonard Cohen does not owe Lynch commissions for services rendered and owed for future commissions? This issue was not raised in the Complaint or argued. Did the Court take the position that slave labor is legal? Lynch worked for years on the third intellectual property deal Cohen was examining. On October 21, 2004 Sony/ATV, according to the Grubman firm, put in their initial offer. Lynch also was working on Dear Heather matters; a lithograph deal; and the inclusion of Cohen material in a New West Record deal. These are some examples of the services Lynch provided or matters she was working on.

6. Leonard Cohen steadfastly refuses to provide Lynch with IRS required form 1099 and partnership K-1s with respect to these entities for the years 2004, 2005, and 2006 (as the judgment was not entered until May 15, 2006). Cohen has taken the position that this judgment absolved his obligations with respect to Lynch and these entities. He is the individual in possession of the necessary tax documents, etc. although the Deputy City Attorney argued, during Lynchs 2012 trial, that an employee is the individual in possession of information an employer must report on IRS required forms 1099 and K-1s.

7. Cohen willfully refuses to rescind the K-1s LC Investments, LLC transmitted to State of Kentucky and Internal Revenue Service. Did the Court determine that Lynch is a partner in this entity and, if so, what evidence was provided to make this conclusion? Lynchs 2004 and 2005 federal tax account transcripts prove that this entity transmitted K-1s to IRS for the years 2004 and 2005. Leonard Cohens declaration, submitted to this Court in support of the judgment (and the Complaint itself), clearly states that he is the 100% sole owner of this entity. See Leonard Cohens declaration dated January 24, 2006: 4. I am the sole owner of (ii) Leonard Cohen Investments, LLC (LCILLC), a limited liability company established in 2000 to hold certain of my intellectual property assets. Exhibit A: Transcripts of Lynchs IRS account for the years 2004 and 2005 showing K-1s related to LC Investments, LLC and no 1099 from Leonard Cohen personally.

8. Did the Court determine that Leonard Cohen has the right to keep the royalty income he collects (via his personal CNB account and LC Investments, LLC) with respect to assets owned by Blue Mist Touring Company, Inc.

9. Did the Court determine that it was acceptable for Traditional Holdings, LLC to: 1) fail to report the income from the Sony sale on the 2001 tax return; 2) extinguish Lynchs promissory note on the 2002 tax return; 3) extinguish the annuity obligation from the 2003 tax return? What was the basis for this decision? How did the Court conclude that there was an annuity obligation in light of the fact that this obligation was extinguished from the 2003 federal tax returns?

10. Why has the Court failed to address Leonard Cohens Traditional Holdings, LLC loans/expenditures totaling approximately $6.7 million? The Annuity Agreement was addressed in the Complaint and that Agreement (signed by Leonard Cohen and notarized) acknowledges that Cohen may take loans/advances but they must be repaid within 3 years. The interest that was agreed to was 6%.

11. What is the Courts position with respect to Traditional Holdings, LLC corporate distributions vis a vis the formation documents and management agreement?

12. How does the fraudulent domestic violence, a modified version of the 2008 Boulder, Colorado order registered with LA Superior Court on May 25, 2011, prevent Lynch from requesting IRS required tax documents or prohibit Cohen from providing them to Lynch if indeed the Court believes he is obligated to provide Lynch with this information. LAPDs report clearly states that Lynchs alleged emails were generally requests for tax information and yet their file was forwarded to the City Attorney. That report is replete with fraudulent statements Cohen and his representatives reported to LAPD.

13. Is the default judgment retroactive and, if so, to what date it extends to.

PROPOSED LANGUAGE (attached to Default Judgment):

Default judgment is also entered against Defendant Kelley A. Lynch (Lynch) on Plaintiffs claims for imposition of constructive trust and declaratory and injunctive relief. It is therefore ORDERED, ADJUDGED AND DECREED that a constructive trust is imposed on the money and property that Lynch wrongfully took and/or transferred acting in her capacity as Trustee for the benefit of Plaintiff Leonard Norman Cohen (Cohen).

It is DECLARED that: (1) Lynch is not the rightful owner in any assets in Traditional Holdings, LLC, Blue Mist Touring Company, Inc. or any other entity related to Cohen; (2) that any interest she has in any legal entities set up for the benefit of Cohen she holds as trustee for Cohens equitable title; (3) that she must return that which she improperly took, including but not limited to loans; and (4) that Cohen has no obligations or responsibilities to her.

It is further ORDERED, ADJUDGED AND DECREED that Lynch is enjoined from conveying any rights or assets to any third party so as to frustrate Cohens equitable interest, and from exercising her alleged rights in these legal entities, including any alleged rights to transfer, move, convey, loan, borrow, or in any way exercise control over any funds or property received from Cohen.

EXHIBIT ATranscripts of Lynchs IRS account for the years 2004 and 2005