Ongoing “Prolix” Criminal Harassment, Witness Tampering, Etc. Many from April 2016

At no time did Lynch advise Alan Hootnick that her letters to Phil Spector came back. She advised Alan Hootnick that she heard directly from Phil Spector and Gianelli wants to elicit that information from her. Paulette Brandt’s letter clearly states that her letter was returned. It does not mention Lynch’s. This is one of Gianelli’s tactics.
From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Fri, Apr 29, 2016 at 8:05 AM
Subject:
To: alan hootnick <ahootnick@yahoo.com>

Alan,

Re: Lynch’s Facebook message to you stating that all of Lynch/Brandt’s letters to Phil Spector in prison were being returned unopened, see this email Kelley Lynch forwarded to Dennis Riordan. Lynch attached it to her RICO complaint as a part of Exhibit 1. It says the same thing as Lynch told you in her Facebook message (which she now denies).

She just cannot keep track of her lies. But I can.

Stephen Gianelli

Attached: Paulette Brandt email dated 2-23-2013 – STATING THAT ALL PRISON EMAIL TO PS RETURNED UNOPENED

The ongoing relentless harassment for seven straight years.

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Fri, Apr 29, 2016 at 1:07 PM
Subject: Re: The Chevron v. Donziger RICO complaint cited by Lynch as evidence that her complaint is not prolix
To: Kelley Lynch <kelley.lynch.2013@gmail.com>

The beauty of it is the Court will dismiss on it’s own. It doesn’t need to hear from non-parties.

Cohen offered me 50% community property, etc. because Lynch stole from him? Who would ever believe that? Lynch’s property, corporate property, etc. is not Leonard Cohen’s property. Leonard Cohen is the individual who stole – from Lynch, corporations, Machat & Machat and – according to Machat – from Phil Spector.

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Fri, Apr 29, 2016 at 12:44 PM
Subject: Re: No wonder you fired your attorneys when they urged you to mediate. You would have had to face up to exactly what happened.
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>

You would not take Cohen’s money then, but you want it now? Ha!

You would not mediate because you did not want to provide the answers that would have been required. So you ran away and created this smoke screen to deflect from your own theft.

The fraud in Kory’s January 14, 2005 memorandum; the use of that threatened fraud to attempt to force Lynch into a settlement; and the fact that there is evidence wholly undermining these fraudulent misrepresentations. Cohen was advised not to sell his IP; the CAK declaration proves that he elected to abort the CAK deal and pursue the Sony transaction; Cohen’s personal expenses are not corporate expenses.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Fri, Apr 29, 2016 at 8:49 AM
Subject: No wonder you fired your attorneys when they urged you to mediate. You would have had to face up to exactly what happened.
To: Kelley Lynch <kelley.lynch.2013@gmail.com>

Case 2:16-cv-02771-SVW-Ft=M Document 1-8 Filed 04/22/16 Page 11of 50 Page ID #:411

Claim by Cohen of fraud in the inducement against Greenberg, Westin, Grubman, McBowman, and Lynch for failure to advise Cohen that discounting royalties for sale was ill advised and would serve only to create transaction fees.

Impact of Cohen selling his royalty rights (because he thought he was out of money) as compared to had he maintained those streams of income.

Damage for lost pro.fits, transaction fees, theft losses, negative tax consequences .

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Fri, Apr 29, 2016 at 4:34 AM
Subject:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>

Excerpted from district court order dismissing state court complaint removed to federal district court as “too prolix”. https://scholar.google.com/scholar_case?case=13048924753780484633&q=phillips+v.+depaul&hl=en&as_sdt=2,14&as_ylo=2012

As may be perfectly appropriate under state court practice, the Complaint couples the plaintiffs’ pleading of evidence with a vengeance (its 134 paragraphs occupy just over 56 pages) with a substantial number of exhibits whose aggregate bulk exceeds that of the Complaint itself by a substantial margin. If such a filing had been attempted in this District Court as an original matter, there is no question that this Court would have stricken it as noncompliant with Fed. R. Civ. P. (“Rule”) 8(a), which calls for (1) “a short and plain statement of the grounds for the court’s jurisdiction” and (2) “a short and plain statement of the claim showing that the pleader is entitled to relief.”

That poses something of a dilemma. Pleading in the federal courts is of course controlled by the Rules, but plaintiffs’ counsel can scarcely be faulted for conforming to state court practice in a lawsuit filed there in the first instance. All the same, this Court is loath to thrust on defense counsel the task of pleading in response to such an extraordinarily prolix Complaint that would not have passed muster if brought here in the first instance.

Accordingly plaintiffs’ counsel are ordered to file, as promptly as possible, a self-contained Amended Complaint that more reasonably meets the Rule 8(a) standards,[1] after which defense counsel are ordered to file a responsive pleading within 21 days of their receipt of that Amended Complaint.That task on both sides should readily be capable of completion before the initial status hearing, which (as always) this Court orders to be held 49 days after the original Complaint’s filing in this federal court.

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Fri, Apr 29, 2016 at 12:41 PM
Subject: Re: The Chevron v. Donziger RICO complaint cited by Lynch as evidence that her complaint is not prolix
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>

Ms. Lynch,

In the Chevron case bribe money was paid to judges and other foreign officials to influence a judicial result in a very complex scheme.

In your case, you simply believe that the evidence presented in support of the 2006 default J would have been rebutted by your testimony and documents had you appeared in opposition thereto.

The two cases are world’s apart, literally and figuratively.

They are miles from “identical”. Of course you also see parallels between your 2012 harassment prosecution and the Phil Spector murder case, so trying to explain this to you is probably pointless.

In any event, if indeed you are correct that the two cases are “identical” that proves my point: If Chevron could plead it in a 50 page complaint, your 250 page pleading + 400 pages of exhibits is indeed “prolix’.

Leonard Cohen’s legal representative, Gianelli, attempts to spin the facts. They’re argument: the length and complexity of Cohen’s scheme is the victim’s fault and Cohen feels confident that he got away with his unlawful acts. The RICO Defendants procured their judgments through fraud. They used fabricated evidence. There is fraud upon courts. The judgments have been used to extort money and property from Lynch. The issues are nearly identical to Chevron’s except the fraud upon the U.S. Courts is egregious.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>

Date: Fri, Apr 29, 2016 at 1:35 AM
Subject: The Chevron v. Donziger RICO complaint cited by Lynch as evidence that her complaint is not prolix
To: alan hootnick <ahootnick@yahoo.com>
Cc: Kelley Lynch <kelley.lynch.2013@gmail.com>

Kelley Lynch cites the court to the RICO case that Chevron filed in the Southern District of New York suing plaintiff’s attorney Steven Donziger; his Ecuadorian colleagues Pablo Fajardo and Luis Yanza; several Ecuadorian business organizations , the Amazon Defense Front and Selva Viva; and Stratus Consulting, a Boulder, Colo.-based consulting firm – along with more than FIFTY ADDITIONAL DEFENDANTS, alleging a massive scheme to corrupt the Ecuadorian judicial system, that included alleged bribes to public officials, in order to procure a billion dollar judgment against Chevron.

The complaint filed in the Southern District of NY in 2011 was FIFTY PAGES LONG and had only TWO EXHIBITS attached to it.

The alleged criminal enterprise alleged in that case was a breathtaking fraud of global proportions taking place partly in the United States, partly in South America that involved fabricated consulting reports, the paid solicitation of phony sham Ecuadorian plaintiffs who in fact suffered no injuries at all, and hundreds of alleged actual cash bribes paid to Ecuadorian judges and other officials to carry out the alleged criminal enterprise.

And yet, Chevron managed to say all of that in a FIFTY (50) PAGE COMPLAINT appended to which were TWO (2) exhibits.

Nor did the complaint consist of a rambling account of the parties’ dealings from 2001 through the present, nor did the complaint quote transcripts, song lyrics, poetry, Tibetan spiritual leaders, child custody declarations signed in 2005, nor did it consist of a disjointed, blow-by-blow account of two civil lawsuits (one in state court one in federal court), restraining order proceedings in Colorado and California or a 2012 criminal case, or quotations from a public defender and a court appointed appeals lawyer opining that the misdomenaor case resulting in Lynch’s conviction was an attempt to subvert the IRS and to keep the Phil Spector verdict from being overturned on appeal, nor were there long narrative references to bubble baths, penises, work related injuries sustained by the plaintiff’s children, magazine articles, draft magazine articles, and Youtube interview. Nor did the complaint attach over a hundred lengthy exhibits, including entire court files, hearing transcripts and other unorganized, unedited material.

The Chevron v. Donziger complaint was extremely complex, involved more than fifty parties, acting in two different countries, and it did that in 50 cogent pages and two exhibits.

Nor was the length of that complaint litigated in that matter at all.

No comparison on any level to Kelley Lynch’s 250 page complaint attaching another 400 pages of exhibits and also incorporating by reference UNTRANSCRIBED audio interview that ramble on for hours and are total hearsay, or an “evidence blog” created on WordPress that the Court is asked to find and read.

Utterly prolix. Indeed, a new record for “prolix” is set with this ridiculous pro se pleading, which in essence seeks to relitigate Kelley Lynch’s dispute with Leonard Cohen from 2004 through the present. Declare all of the prior, final judgments and orders null and void, declare Lynch in the right, and award her declaratory, injunctive and damage relief arising from the very transactions and prior business dealings covered by those orders and judgments.

Talk about delusional, wishful thinking – all wrapped up in legalese “monkey see, monkey do” lifted from other attorneys’ (inapplicable) work product.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>

Date: Fri, Apr 29, 2016 at 12:15 AM
Subject:
To: alan hootnick <ahootnick@yahoo.com>
Cc: Kelley Lynch <kelley.lynch.2013@gmail.com>

As if asking to file a 658 page complaint is not enough, Lynch “incorporates by reference” her UNTRANSCRIBED “Truth Sentinel” podcast interviews with Ann Diamond of several hours in duration and this blog https://racketeeringact.wordpress.com/ into the complaint – and asks the Court to listen to/read them!

This is the crazy pro se complaint from hell. No way will this fly on any level. That is before the court even gets into the specific deficiencies I mentioned.

See this dismissal order of an 108 page pro se complaint (quoted in relevant part below):

https://cases.justia.com/federal/district-courts/oklahoma/okwdce/5:2016cv00003/95634/5/0.pdf?ts=1459350591

“Under Rule 8(a), a complaint must contain: (1) a short and plain statement of

the grounds for the court’s jurisdiction, (2) a short and plain statement of the claim

showing that the pleader is entitled to relief, and (3) a demand for the relief sought.

Fed. R. Civ. P. 8(a). Though complaints drafted by pro se litigants are given more

leeway than those drafted by attorneys, they still must be coherent enough to allow for

an intelligent response. Carpenter v. Williams, 86 F.3d 1015, 1016 (10th Cir. 1996).

And although the Court is required to construe Plaintiff’s pleadings liberally, it does

not “assume the role of advocate” and “should dismiss claims which are supported

only by vague and conclusory allegations.” Northington v. Jackson, 973 F.2d 1518,

1521 (10th Cir. 1992). Although some allowance is made for certain deficiencies, such

as unfamiliarity with pleading requirements, failure to cite appropriate legal authority,

and confusion of legal theories, Garrett v. Selby Connor Maddux & Janer, 425 F.3d

836, 840 (10th Cir. 2005), “the court cannot take on the responsibility of serving as

the litigant’s attorney in constructing arguments and searching the record.” Id. Finally,

the Court “will not supply additional factual allegations to round out a plaintiff’s

complaint or construct a legal theory on a plaintiff’s behalf.” Whitney v. New Mexico,

113 F.3d 1170, 1173-74 (10th Cir.1997) (citing Hall v. Bellmon, 935 F.2d 1106, 1110

(10th Cir. 1991)).

Therefore, dismissal is proper under Rule 8 when a pro se complaint is

unreasonably long, rambling, and otherwise filled with irrelevant material. Mitchell

City of Colo. Springs, Colo., 194 F. App’x 497, 498 (10th Cir. 2006) (unpublished)

(affirming dismissal of complaint for being “verbose, prolix and virtually impossible

to understand” and a “rambling, massive collection of facts . . . completely lacking in

clarity and intelligibility”); Ausherman v. Stump, 643 F.2d 715, 716 (10th Cir.1981)

(holding that a “prolix” complaint that was a “rambling narration of the discord that

developed between [the parties]” violated Rule 8(a)); see also Firewood v. New

Mexico’s Bernalillo County Metropolitan Detention Ctr., 583 F. App’x 875, 876 (10th

Cir. Nov. 26, 2014) (unpublished) (“[e]ven though we must construe the pro se brief

liberally . . . we can scarcely identify, much less evaluate, the ‘appellant’s contentions

and the reasons for them.’”).

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Thu, Apr 28, 2016 at 10:52 PM
Subject: RE: Proposed 658 page “RICO complaint” that you lodged with the Central District Court on April 22, 2016
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>

Ms. Lynch,

Sorry but there is no magic solution. There is no path from “time-barred” and “Rooker-Feldman barred” to a federal court “RICO suit”.

You’re done. You just have not figured that out yet.

Any day now that will be made clear by the Court.

“Notwithstanding any filing fee, or any portion thereof, that may have been paid, the court shall dismiss the case at any time if the court determines that … the action … is frivolous or malicious [or] fails to state a claim on which relief may be granted…”.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Thu, Apr 28, 2016 at 10:44 PM
Subject: RE: Proposed 658 page “RICO complaint” that you lodged with the Central District Court on April 22, 2016
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>

Your complaint has not been accepted for filing yet; as I have told you repeatedly, the Court will first review it under section 1915 (e) for facial merit BEFORE deciding whether to allow you to file it without paying a $400 fee and if the complaint lacks merit it will be dismissed.

No summons will be issued and no service of the complaint may be made and the case may not proceed unless the complaint survives scrutiny. It won’t.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Thu, Apr 28, 2016 at 10:37 PM
Subject: RE: Proposed 658 page “RICO complaint” that you lodged with the Central District Court on April 22, 2016
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: PAULETTEBRANDT8@gmail.com, alan hootnick <ahootnick@yahoo.com>

Ms. Lynch,

The “situation” – referring to your civil RICO claims – was “over” when four years passed following the first date upon which you sustained a “business injury” i.e., when defendants first deprived you of commissions, royalties, intellectual property and business enterprise interests. One can argue that your business injuries first occurred a reasonable time after you left Cohen’s employ and did not get paid, but there is no credible way to argue that you had not sustained “business injury” by the time that (due to withholding of alleged sums due you) you first defaulted on your home mortgage in 2005.

I am not “lying” about my informed opinions regarding the merits of your proposed “RICO complaint” any more than I was “lying” when I said you would lose your direct appeal (and why), when I said you would lose your application for habeas relief (and why), when I said you would lose your motion to vacate the 2006 judgment (and why), when I told you that your “motion for terminating sanctions” would be deemed a “motion to reconsider” (and why), that the IRS motion to dismiss your tax court petition would be granted (and why), and that your 9th Circuit appeal would be deemed “frivolous” and dismissed. You accused me of “lying” on all of these occasions as well. More recently, you also accused the Court of “lying” at your September 1, 2015 motion to vacate hearing of “lying” as well.

I was not “lying” then and I am not “lying” now. What would be the point? In a matter of days (not weeks or months) there will be a written order from the Court on the facial merit of your “RICO complaint”. It will pass muster or it won’t. You will be given an opportunity to amend, or you won’t.

Then we will see who the “liar” is. It won’t be me. I have not been wrong yet.

Stephen Gianelli

Writing for myself.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Thu, Apr 28, 2016 at 9:48 PM
Subject: RE: Proposed 658 page “RICO complaint” that you lodged with the Central District Court on April 22, 2016
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: Entire_World@gmail.com

Ms. Lynch,

With all due respect, if you believe that none of the allegations of your complaint are “conclusory” then you don’t know what “conclusory” means. Specifically, and by way of one example only, your “business injury” claim – apart from mentioned that you lost “two businesses” simply recite the legal conclusion that you sustained injury to your business. Your complaint does not specify the type of injury, how it occurred, when it occurred, or the dollar amount of injury you sustained. Similarly, although your complaint recites the legal conclusion that as a proximate result of defendants wrongful conduct you sustained business injury you fail to set forth any facts at all from which a plausible inference to that effect can be drawn with respect to each of your predicate acts, which are also alleged in general, conclusory terms. To the extent you do specify “business injury” it is clear that you sustained that injury more than four years prior to April 22, 2016. The civil RICO statute begins to accrue (run) when the plaintiff discovers or should have discovered her business injury – NOT when she discovers the fraud causing the business injury or all of the details of her RICO claim. Your complaint confuses the rule that the first and last predicate acts be ten years apart with the applicable four year statute of limitations. Neither can be tolled by your seven months of incarceration.

When stripped of excess verbiage and boiler plate conclusory allegations you have copied from other RICO complaints, case law and statute, your complaint boils down to this: The fraudulent use of state court judgments and orders to conceal tax fraud, deprive you of income and property, and to prevent you from brining your affirmative claims to court. You expressly seek to have those judgments and orders invalidated as “fraudulent”, to enjoin their enforcement, and to recover damages flowing from the fraud. That is the classic kind of federal claim that the Rooker-Feldman doctrine operates to preclude. Only the United States Supreme Court has the power to set aside a state court judgment on petition for a writ of certiorari. Your allegation of “bribery” is nothing more than an alleged “generous settlement offer”. Many federal cases have held that alleged perjury and other abusive tactics to obtain a civil judgment do not constitute predicate acts under RICO.

Your called “supplemental claims” under state common law are all subject to a 2-year statute of limitations and are all time-barred and suffer from additional defects.

Last, 28 USC § 1915 (e) (2) states in relevant part:

Therefore, the Court is required to dismiss your complaint whether or not you subsequently “pay to have the complaint filed”.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Thu, Apr 28, 2016 at 1:14 PM
Subject: Proposed 658 page “RICO complaint” that you lodged with the Central District Court on April 22, 2016
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: Entire_World@gmail.com

Ms. Lynch,

I finally located the proposed “RICO complaint” that you lodged with the Central District Court on April 22, 2016 and I have finished reading it.

The bottom line is that your complaint is fatally deficient in all of the ways I previously outlined and in myriad additional ways, including a failure to state which defendants and alleged co-conspirators committed precisely which alleged predicate acts, the “who, when, why and where” of each predicate act, including the dates and perpetrators thereof, and FACTS from which a plausible inference can be drawn of the existence of a criminal enterprise, the existence of a RICO conspiracy, the commission of any predicate acts, the specific “business injuries” that are alleged or FACTS from which a plausible inference can be drawn that the alleged predicate acts directly caused any alleged “business injury”.

Instead, your complaint is entirely conclusory in those necessary respects – not facts at all are set forth.

There can be no doubt that this complaint will be dismissed PRIOR to the issuance of a summons and that your application to proceed in forma pauperis will be denied.

In addition, I seriously doubt that you will be allowed an attempt to amend to correct this abortion of a “complaint” because I don’t believe that it can be saved by amendment. You basically complain of the outcomes of criminal and civil litigation that resulted in final judgments in the former case more than four years before you filed your complaint and in the latter case more than ten years before.

Your complaint is silent on the dates upon which you allegedly sustained the loss of your two businesses, but it is clear from the totality of your allegations and exhibits that it was beyond the four year RICO statute of limitations – which runs from the date you sustained or should have discovered you sustained the alleged business losses.

I know you think your RICO complaint cleaver, but it is utterly and completely without merit and will be dismissed, ultimately (if not in the initial order) with prejudice.

Both you and your enabler Paulette Brandt will both know that I am right as soon as the order is issued pursuant to section 1915 (e).

That is all.

Stephen Gianelli

Writing on my own behalf.

From: Stephen R. Gianelli <stephengianelli@gmail.com>
Date: Wed, Apr 27, 2016 at 10:49 PM
Subject: Kelley Lynch admits that her “RICO suit” has not yet been “filed” and she vows not to amend the suit even if asked by the court to do so
To: Entire <World@gmail.com>
Cc: kelley.lynch.2013@gmail.com, kelley.lynch.2010@gmail.com, paulettebrandt8@gmail.com, ahootnick@yahoo.com, karina.inger.v@gmail.com

Kelley Lynch writes in a blog posted email dated yesterday:

“If the Court doesn’t accept the Complaint as is, that will not be the end of the situation. Ultimately, if necessary, I will sue the IRS for relying on a state court judgment procured by fraud. The TH federal tax returns will also be at issue.”

She intends to go from one frivolous, attempted lawsuit against a wealthy celebrity to another even more frivolous lawsuit against the Internal Revenue Service.

Ms. Lynch, you need different hobbies.

PS to Paulette Brandt: None of this is going to pay the rent Ms. Lynch owes you, is it?

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Thu, Apr 28, 2016 at 1:40 AM
Subject: Re: Fw: WELL AFTER CLOSE OF BUSINESS ON WEDNESDAY, APRIL 27, 2016 THERE – STILL – IS NO “RICO SUIT” *FILED* BY KELLEY LYNCH IN ANY FEDERAL DISTRACT COURT IN THE US
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>, Paulette Brandt <paulettebrandt8@gmail.com>, Karina Von Watteville <karina.inger.v@gmail.com>
Ms. Lynch,
There is no need for me to violate protocol and attempt direct contact with a federal judge who is (apparently, if you are to be believed) currently evaluating your PROPOSED, NOT YET FILED “RICO suit” for facial merit pursuant to 28 USC § 1915 (e). I am able to check PACER and determine for myself that no lawsuit filed by “Kelley Lynch” is currently filed or pending in ANY federal district court in the United States.
I am on record as predicting that (as I said if and when you submit your complaint for IFP review) the Central District Court will deny your application to proceed IFP and DISMISS your complaint as failing to state a claim upon which relief may be granted – because it is utterly and completely frivolous and without merit as a matter of law and that the Court will cite one or more of the dozen grounds that I have set forth to you – chapter and verse with statutory and case authorities – ad nauseam in numerous emails over the last 12-months.
Then – because you have been so insultingly adamant about calling me a “liar” (and worse) – I am going to GLOAT. Big-time.
Stephen Gianelli
Writing for myself alone.

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Wed, Apr 27, 2016 at 11:43 PM
Subject: Re: Fw: WELL AFTER CLOSE OF BUSINESS ON WEDNESDAY, APRIL 27, 2016 THERE – STILL – IS NO “RICO SUIT” *FILED* BY KELLEY LYNCH IN ANY FEDERAL DISTRACT COURT IN THE US
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: Paulette Brandt <paulettebrandt8@gmail.com>, alan hootnick <ahootnick@yahoo.com>, Karina Von Watteville <karina.inger.v@gmail.com>
Ms. Lynch,
1. Calling a judge ex-parte regarding a matter that may (or may not be) be pending before him on your application for permission to file a proposed RICO complaint without paying a filing fee (in forma pauperis) – if you even filed an request IFP and are not making all of this up – would be highly inappropriate.
2. The published number is NOT for the judge in any event; it is the number of the judge’s clerk’s extension.
3. Calling the court is not going to change the fact that as of right now, no RICO (or any) suit listing “Kelley Lynch” as a plaintiff is FILED with any federal district court in the United States.
4. IF you in fact transmitted a PROPOSED RICO suit to the court, along with an application to proceed in forma pauperis, the current status is that it is awaiting prefilling review of your IFP application and on the merits pursuant to 28 USC § 1915 (e) which section REQUIRES the court to DISMISS your suit IF it appears to be “frivolous” OR if it “fails to state a claim on which relief may be granted”. Regarding the later criterion, case law holds that a complaint that is so “prolix” that it fails to give fair notice to the defendants of the claims that they must defend against at trial may be dismissed following § 1915 (e) review.
5. IF you in fact transmitted a PROPOSED RICO suit to the court, along with an application to proceed in forma pauperis, it won’t be long now before your proposed RICO complaint is declared to be utterly and completely without merit in a written order signed by a federal judge and posted on PACER – which order I will be downloading, carefully reading and I will have QUITE A BIT TO SAY ABOUT at that time – including “I told you so”.
On Thu, Apr 28, 2016 at 9:11 AM, Kelley Lynch <kelley.lynch.2013@gmail.com> wrote:

Call the judge and harass him, Gianelli.
JUDGE STEPHEN V. WILSON
Court Clerk: Paul Cruz
Court Reporter: Deborah Gackle Courtroom No.: 6
Telephone No.: 213-894-2881
Telephone No.: 213-620-1149
———- Forwarded message ———-

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Wed, Apr 27, 2016 at 10:09 PM
Subject: WELL AFTER CLOSE OF BUSINESS ON WEDNESDAY, APRIL 27, 2016 THERE – STILL – IS NO “RICO SUIT” *FILED* BY KELLEY LYNCH IN ANY FEDERAL DISTRACT COURT IN THE US
To: Entire_World@gmail.com
Civil Party Search
Thu Apr 28 00:03:03 2016No Records Found

User: Gianelli

Client: NO CLIENT
Search: Civil Party Search Name lynch, kelley NO 470 (Racketeer/Influenced Organization) All Courts

No records found

Receipt 04/28/2016 00:03:03 52441236
User Gianelli
Client NO CLIENT
Description Civil Party Search
Name lynch, kelley NO 470 (Racketeer/Influenced Organization) All Courts
Pages 1 ($0.10)

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Wed, Apr 27, 2016 at 12:46 AM
Subject: Re: FW:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: Karina Von Watteville <karina.inger.v@gmail.com>, alan hootnick <ahootnick@yahoo.com>

Ms. Lynch,
I do not represent Ms. Von Watteville currently but I have tried literally hundreds of jury trials to verdict and countless court trials to judgment in California Superior Court in counties as far south as San Diego and as far north as Humboldt during my 37 year trial career as a Californian lawyer.
I have made and opposed thousands of trial motions to limit and exclude evidence.
Although I retired in April of 2013, I keep my law license current and I still read the published appellate opinions and keep up with high profile legal matters and also follow litigation that people I know are litigating as counsel.
Based on this experience, I not only know the California Evidence Code intimately, I have a very good practical sense of how an experienced trial judge will rule on hearsay, relevance and Evidence Code section 352 objections.
In my expert opinion, there is zero chance that any trial judge will allow you to even mention the name “Sam Manning” in court, or will allow you to attempt to prove that Ms. Von Watteville is habitually untruthful, or will allow you to introduce evidence on a any subject except the truth or falsity of the precise false, libelous, and unprivileged statements and publications by you and the other defendants that Ms. Von Watteville elects to proceed to jury trial on. What false statements to base her case on is entirely up to her.
You can take the stand and deny making the statements in the face of your mass emails and blog posts to the contrary and you can attempt to introduce ADMISSIBLE, first hand evidence of the truth of your statements that Ms. Von Watteville is a prostitute, a paid dominatrix, and defrauded Paulette Brandt of $6,700. There is no other defense available to you.
Parties are not allowed to simply trash each other with random dirt.
If you had a law degree, passed the bar, and then spent decades trying cases as I have you would know this. But you don’t. And you are not even aided by common sense.
Stephen Gianelli
Writing for myself
On Wed, Apr 27, 2016 at 8:09 AM, Kelley Lynch <kelley.lynch.2013@gmail.com> wrote:

Stephen Gianelli and Karina Von Watteville,
I am advising the two of you to cease and desist. My RICO suit was filed. Is Von Watteville amused? She should be concerned about her baseless, fraudulent, extortionate lawsuit. An answer will be filed next week. Make no mistake about that. I want the Court to pay close attention to the Menning case, the fact that this woman argues that people force her into homelessness, KVW’s sense of entitlement and contradictory “stories,” and the fact that this woman used the credit card of a dead man the day he died and the day after. I am also aware of the fact that KVW encouraged Christian Slater’s father to sue him and his mother. The two of you engaged in egregious witness tampering with Linda Carol.
Neither of you know Oliver Stone, Ron Burkle, or David Geffen. That’s for certain. Is everyone amused with FBI? I suppose that’s why the moron at the DA’s office, Cooley’s personal “investigator,” told me to tell the Denver FBI “Merry Christmas.” This town is corrupt; government actors in this town are corrupt; the court system is corrupt and this is not a secret. People have long viewed LA as LA Confidential and rightly so.
Leonard Cohen is the individual who advised people that he was a participant in CIA’s MK Ultra Program. Cohen is the individual who advised many journalists that he was recon during the Bay of Pigs. The fool fantasizes about men holding guns on him and all women who criticize him are scorned “lovers” or women stalking and harassing him. As his friend Irving Layton concluded: Cohen is a narcissist who hates himself. He’s also consumed with revenge fantasies.
Cease and desist.
Kelley Lynch

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Tue, Apr 26, 2016 at 9:49 PM
Subject: RE: FW:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: Karina Von Watteville <karina.inger.v@gmail.com>, alan hootnick <ahootnick@yahoo.com>

“What does Karina Von Watteville have to do with my RICO suit?” Absolutely nothing, except that I thought that (since she is suing you in an unrelated matter) she might find your desperate lies to be amusing. She, along the rest of the world, sees that you have lost all touch with reality.

Are you going to file an answer to her complaint “next week” just like you file your “RICO suit”? Ha!

Does David Geffen have a copy of your imaginary RICO suit too? (Don’t forget to send one to Oliver Stone, Ron Burkle, the Washington DC Field Office of the FBI, the CIA and Russian intelligence as well! Ha! Maybe you could convert a copy to binary code and beam it to Mars as well! Ha!)

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Tue, Apr 26, 2016 at 9:18 PM
Subject: RE: FW:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>, PAULETTEBRANDT8@gmail.com

I have a PACER account. I have no need to call any court that you are pretending to have a suit pending in.

As of right now, which is after 9:00 PM in LA on Tuesday, April 26 there is NO RICO suit listing you as plaintiff on file in the Central District.

From: Kelley Lynch [mailto:kelley.lynch.2013@gmail.com]
Sent: Tuesday, April 26, 2016 10:00 PM
To: alan hootnick; Stephen Gianelli
Cc: *irs. commissioner; Washington Field; ASKDOJ; : Division, Criminal; Doug.Davis; Dennis; MollyHale; fsb; rbyucaipa; khuvane; blourd; Robert MacMillan; a; wennermedia; Mick Brown; glenn.greenwald; Harriet Ryan; hailey.branson; Stan Garnett; Mike Feuer; mayor.garcetti; Opla-pd-los-occ; Kelly.Sopko; Whistleblower; Attacheottawa; tips@radaronline.com; bruce
Subject: Re: FW:

Gianelli,

Call the Court. Demand an explanation from the judge as to precisely why this Complaint does not appear on Pacer.

Kelley Lynch

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Tue, Apr 26, 2016 at 1:16 AM
Subject: FW:
To: blind <distribution@gmail.com>

FYI

From: Stephen Gianelli [mailto:stephengianelli@gmail.com]
Sent: Tuesday, April 26, 2016 11:05 AM
To: alan hootnick
Subject: Re: Spector

I missed the digits.

What email were they in?

It is possible that Lynch merely LODGED her complaint with the Central District court with an “application to file in forma pauperis” (IFP) (basically Latin for fee waiver application) — EXCEPT in federal court, including any appeals court — BEFORE in forma pauperis status may be granted, the court is required by act of congress (28 US Code § 1915, subd. (e)) to review the proposed complaint for facial merit according to the same standards that the court would apply to a defense motion to dismiss for failure to state a claim for relief under Federal Rules of Civil Procedure (FRCP) rule 12.

Until that review process is complete, the complaint would not be “FILED” (merely “lodged”) pending review of the application IFP, including the merits review.

That may be why the complaint is not showing as “filed” on PACER even though she may have delivered the complaint to the court for processing, and even though the matter may have been assigned a case number for tracking purposes. In that case her copy would be stamped “RECEIVED” not “FILED”.

I tend to believe that it would still show up on PACER though, which is real time docket information.

Unless Lynch shit $400 for a filing fee or knows someone who would even have, let alone giver her, $400 (also doubtful) she submitted the complaint, or will if she does, IFP.

If and when that occurs no SUMMONS is issued in such case pending further order of the court. (A summons is the technical document that brings a served defendant before the court, and no service of the suit on any defendant can occur without issuing a summons).

Lynch (like many pro se litigants who have just enough legal knowledge to delude themselves) suffers from a compulsion to lay out the ENTIRE chronological history of her constellation of grievances that she calls a “conspiracy to ruin my life” at all times in every court filed document. To such people, the more the better, as if “if only the judge knew everything I knew of course I would win my case”. To lynch, more is more. She must tell it from the beginning, like the Bible. At each stage she must also include long (1,000+ word) quotations from Cohen lyrics, magazine articles, hearing transcripts, correspondence, etc. What she invariably winds up with is a 300 page pleading, with another 700 pages of attached material.

This is not going to fly in federal court, because FRCP rule 8 mandates that the complaint consist of a “short and plain” statement of the claim. This is known as “notice pleading”, just enough of the major elements to put the defendants on notice of the nature of the claims. “Facts” are learned in discovery. Attachments to the complaint, and overly long “prolix” complaints are discouraged.

That will be the first red flag to any judge reviewing her complaint as an IFP.

The second red flag will be Lynch’s copious references to past civil and criminal litigation between her and the defendants. It is very common for pro se litigants to simply assume that after they lose in state court, in a civil or a criminal case, they can simply file a lawsuit in federal court and get a “do-over” on the merits. Not so, and there are strict rules to prohibit just that.

The third red flag will be Lynch’s theory that my emails to her constitute separate predicate acts of “wire fraud” under the RICO statute – which is ridiculous on a number of fronts. First, because wire fraud not only requires an intent to deceive, but an intent to do so to steal money or property from the victim of the mail fraud. No way can my emails reciting Lynch’s personal. psychiatric, and legal history or lecturing her on the law be stretched to support a theory that I sent them to get defraud Lynch into send me money or property.

Moreover, there is no plausible connection between me sending Lynch these emails and any of the defendants – let alone a connection amounting to a criminal conspiracy – except in Lynch’s mind.

Forth, there is no plausible connection between my emails and any “business injury” that Lynch could plausibly seek in her complaint.

So basically, the court will start reading, eyes will roll, and they will figure out a way to dismiss the complaint with prejudice, before it is technically filed or served. Then it will be filed simply to make a record of why the IFP application is being denied and the complaint dismissed per section 1915 (e).

More likely, Lynch cannot even get it together to print, copy and transmit her complaint to the court, and she is lying about all of it.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Wed, Apr 27, 2016 at 10:34 AM
Subject: RE:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>
Civil Party Search
Wed Apr 27 12:31:29 2016No Records Found
User: Gianelli

Client: NO CLIENT
Search: Civil Party Search Name lynch, kelley NO 470 (Racketeer/Influenced Organization) All Courts

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From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Wed, Apr 27, 2016 at 10:27 AM
Subject: Re:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>
“Why would a federal court give any type of preclusive effect to judgments, verdicts, and orders obtained by fraudulent means?” Probably because of a little thing called the United State Constitution, Good Faith and Credit Clause as codified by 28 U.S.C. § 1738. (No exceptions for Kelley Lynch, you should have looked that up, sorry.)
“My RICO suit was filed.” if you believe that you have a different definition of “filed” than every lawyer and judge in the United States. If your suit was filed (as distinguished from, for example, lodging your proposed complaint with a district court along with a petition to proceed in forma pauperis, awaiting the court’s PERMISSION to file without the filing fee and its section 1915 (e) merits review) the suit would show up on PACER, but it does not. Nor will you produce an endorse filed face page of the complaint. Therefore, no it was not.
Filed means filed, docketed and listed on PACER.
Which proves you have NEVER filed a RICO suit.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Wed, Apr 27, 2016 at 7:58 AM
Subject:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>

ROOKER-FELDMAN

United States District Courts do not have jurisdiction over challenges to state court decisions. See District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 483

16 (1983); Rooker v. Fidelity Trust Co., 263 U.S. 413, 415-16 (1923). Federal appellate review of state court judgments can only occur in the United States Supreme Court, by appeal or by writ of certiorari. Id. Under this principle, generally referred to as the Rooker-Feldman

Doctrine, a party losing his case in state court is barred from seeking what in substance would be appellate review of the state judgment in a United States District Court based on the party’s claim that the state judgment itself violates his or her federal rights. Johnson v. DeGrandy, 512 U.S. 997, 1005-06 (1994).

The United States Sixth Circuit Court of Appeals has applied two elements to a Rooker Feldman analysis. First, in order for the Rooker-Feldman doctrine to apply to a claim presented in federal district court, the issue before the court must be inextricably intertwined with the claim asserted in the state court proceeding. Catz v. Chalker, 142 F.3d 279, 293 (6th Cir. 1998); see Tropf v. Fidelity National Title Insurance Co., 289 F.3d 929, 937 (6th Cir. 2002).

“Where federal relief can only be predicated upon a conviction that the state court was wrong, it is difficult to conceive the federal proceeding as, in substance, anything other than a prohibited appeal of the state court judgment.” Catz, 142 F.3d at 293. The Rooker-Feldman doctrine applies when the party losing his case in state court files suit in federal district court seeking redress for an injury allegedly caused by the state court’s decision itself. Coles v. Granville, 448 F.3d 853, 857-59 (6th Cir. 2006). Second, the Rooker-Feldman doctrine precludes a district court’s jurisdiction where the claim is a specific grievance that the law was invalidly or unconstitutionally applied in plaintiff’s particular case as opposed to a general constitutional challenge to the state law applied in the state action. Id.

RES JUDICATA

A federal court must give a state court judgment the same preclusive effect it would have in the courts of the rendering state. 28 U.S.C. § 1738; Dubuc v. Green Oak Township, 312 F.3d 736, 744 (6th Cir. 2002). Under California law, a “judgment by default is just as conclusive upon the issues tendered by the complaint as if rendered after answer filed and trial on allegations denied by the answer.” (O’Brien v. Appling (1955) 133 Cal. App. 2d 40, 42.) In California, “[a] judgment by default is a complete adjudication of all the rights of the parties embraced in the prayer of the complaint. …” (Freeze v. Salot (1954) 122 Cal. App. 2d 561, 566.) In this state, a default judgment is res judicata “as to all issues aptly pleaded in the complaint and defendant is estopped from denying in a subsequent action any allegations contained in the former complaint.” (Fitzgerald v. Herzer (1947) 78 Cal. App. 2d 127, 131-132.)

HECK v. HUMPHREY RULE

Under the Heck v. Humphrey rule, any federal damages action that arises out of an arrest or criminal conviction that alleges that the plaintiff was wrongfully arrested and/or prosecuted is barred, unless the Plaintiff can plead and prove that the state court conviction she sustained was set aside on direct appeal or following a petition for a writ of habeas corpus. (Heck v. Humphrey, 512 U.S. 477 (1994).)

Therefore, any attempts by you in any federal lawsuit to allege that the 2006 default judgment in BC338322 is invalid as based on “fraud” and “perjury” and that you have sustained damages thereby would be dismissed. Any attempt by you to contradict the allegations Cohen’s 2005 complaint in BC338322 would be precluded by res judicata and subject your complaint to dismissal.

Rather, the federal district court would be required to assume that you were guilty of the offenses charged in your 2012 criminal case and alleged in your probation violation matter and found by the court to be true in 2014. The court would also be required to assume all factual allegations

set forth in Cohen’s 2005 complaint to be true and the findings set forth in the declaratory relief portion of the 2006 judgment to be true as well.

All of these grounds for dismissal operate independently of, and cumulatively to, the four year statute of limitations for filing a RICO action that runs from the date of discovery of the business injuries alleged in the complaint as well as the other technical rules of pleading imposed by FRCP rule 12, and the rules of pleading applicable to RICO actions.

Stephen Gianelli

Writing for myself alone

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Wed, Apr 27, 2016 at 3:10 AM
Subject: FAQ: How do I file a complaint if I am also filing a motion to proceed in forma pauperis? (You don’t, you “lodge” it as a “proposed complaint”. It will be ACTUALLY FILED only if your Application re IFP status is granted.)
To: Kelley Lynch <kelley.lynch.2013@gmail.com>

How do I file a complaint if I am also filing an application to proceed in forma pauperis?

The first document you will file will be the “Application for Leave Proceed In Forma Pauperis” (IFP). You will lodge your proposed complaint, cover sheet, and any summonses as attachments to the Application for Leave to File In Forma Pauperis.

IF the court grants the application to proceed IFP, the clerk will then (and only then) file the proposed complaint and issue any proposed summonses.

The court may also deny the application to proceed IFP, and dismiss the complaint with or without prejudice for any of the grounds stated in 28 USC § 1915 (e).

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Wed, Apr 27, 2016 at 3:29 AM
Subject: Lawyer for Phil Spector’s wife calls divorce heartbreaking – Yea, I am sure it is, now that the gravy train is over
To: alan hootnick <ahootnick@yahoo.com>

http://www.msn.com/en-us/music/celebrity/lawyer-for-phil-spectors-wife-calls-divorce-heartbreaking/ar-BBsjzSW?ocid=spartandhp

LOS ANGELES (AP) — An attorney for Phil Spector’s wife called a divorce filing by the imprisoned music producer heartbreakingly bizarre and said she has provided the best possible care for him.

Attorney Aaron Abramowitz wrote in a statement Tuesday that Rachelle Spector has been devoted to her husband and has been providing him support and the best possible care while he is incarcerated.

“This whole situation is heartbreakingly bizarre,” Abramowitz wrote. “It is regrettable that Mr. Spector has failed to recognize the efforts made by Rachelle in spending tens of thousands of dollars on his medical and dental costs while incarcerated.”

Court records in Stockton, California, show Spector filed for divorce on March 18. A copy of his filing, which was first reported by celebrity website TMZ, was not immediately available.

Spector, 75, is housed at a prison facility in Stockton that provides medical and mental health care to the state’s sickest inmates, including those with chronic conditions.

He is famous for revolutionizing rock music with his “Wall of Sound” that merged beautiful vocal harmonies with lavish orchestral arrangements to produce such pop hits as “Da Doo Ron Ron,” ”Be My Baby,” ”He’s a Rebel” and the Righteous Brothers’ version of “You’ve Lost that Loving Feeling.”

Abramowitz said Rachelle Spector obtained her pilots license to make it easier to visit her husband.

The Spectors met at a Hollywood restaurant in 2003, shortly after he was arrested in the shooting death of Lana Clarkson. The producer was later convicted of killing Clarkson and is serving sentence of 19 years to life.

The pair married in 2006, and Rachelle Spector has been running her husband’s businesses while he is imprisoned. She also obtained a private investigator license to assist with her husband’s appeal of the conviction.

Phil Spector’s attorney, John H. McKinley, had no immediate comment on Abramowitz’s statement Tuesday.

Anthony McCartney can be reached at http://twitter.com/mccartneyAP

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Tue, Apr 26, 2016 at 11:21 AM
Subject: As of 4/26/2016, 11:08 am LA time, PACER has NO RECORD of any RICO suit filed by Kelley Lynch
To: blind <distribution@gmail.com>
Civil Party Search
Tue Apr 26 13:07:38 2016No Records Found

User: Gianelli

Client: NO CLIENT
Search: Civil Party Search Name lynch, kelley NO 470 (Racketeer/Influenced Organization) All Courts

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For information or comments, please contact: PACER Service Center
Browse Aloud

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Tue, Apr 26, 2016 at 2:02 AM
Subject: REAL-TIME RSS FEED FOR EVERY CIVIL RICO CASE FILED IN THE CENTRAL DISTRICT OF CALIFORNIA
To: Entire_World@gmail.com

In addition to PACER (which as of 3 minutes ago has no record of any suit filed by anyone named Kelley Lynch in any federal district court in the United States – including in the Central District of California), the legal publisher JUSTIA maintains a real-time RSS feed listing all civil RICO filings made in the Central District of California that is automatically updated.

Kelley Lynch is not listed as a plaintiff.

The six last civil RICO filings in the Central District were on 4/18/2016, 4/15/2016,4/12/2016, 4/8/2016, 3/30/2016, and 3/17/2016.

See RSS feed here: https://dockets.justia.com/browse/state-california/court-cacdce/noscat-13/nos-470

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Tue, Apr 26, 2016 at 1:45 AM
Subject:
To: alan hootnick <ahootnick@yahoo.com>
Okay, attached find an example of a complaint filed against entertainer Taylor Swift in the Central District for copyright infringement on 10/28/2015, the plaintiffs application to proceed in forma pauperis filed 10/28/2015, and the November 10, 2015 order denying IPF status and DISMISSING the complaint for failure to plausibly state a claim on which relief may be granted.
I can tell from handwritten date the plaintiff signed the complaint and the handwritten date on the IFP application that it was “filed” the same day it was presented to the court, October 28, 2015.
The IFP application was denied and the complaint dismissed on November 10, about two weeks later.
The complaint – which was filed in the Central District – was uploaded to pacer the same day it was filed.
If Lynch had actually filed a case on or before Friday (as she claims) then the action would be visible on PACER. (Unless it is so damn voluminous it is taking a couple of days for the district court to scan and upload the complaint to PACER, but there should at least be a case started and indexed.)
Note that the order contains a good discussion of the standards to review the merits of an IFP complaint.

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Mon, Apr 25, 2016 at 9:36 PM
Subject: Re:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>
Oooooooh! I don’t know! It must be a CONSPIRACY!!!!!!!

Oh, and BTW, “Case information appears on the PACER system in real time and is available for retrieval immediately.”http://www.aallnet.org/chapter/swall/meeting2012/H2Handout.pdf

Therefore, if it is not on PACER (and as of 7:31 am Greece time which is 9:32 pm LA time on Monday, April 25, 2016 it IS NOT ON PACER) then the case HAS NOT been “filed” yet. Especially give the fact that you cannot produce a case # or other evidence of filing.

Maybe David Geffen has that “evidence”? Or maybe Kevin and Brian do at CSAA? Ha!!!

Lying loser thinks we are as stupid as she is.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Mon, Apr 25, 2016 at 1:24 PM
Subject: RE:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>, Karina Von Watteville <karina.inger.v@gmail.com>

You are living proof of the adage “stupid people should not lie”.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Mon, Apr 25, 2016 at 1:19 PM
Subject: RE:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>

You do understand, don’t you, that delivering a proposed complaint + an application for in forma pauperis filing status and receiving a “received: stamp is different from “FILING” a complaint and having a summons issued?

One commences a lawsuit and means there is indeed a pending “RICO suit”, the former doesn’t.

And it would have just as much trouble to look up a phone number for the federal district court and type it on an email as to simply type the actual case number in the reference line or email field.

Of course, unless you have actually “FILED” a complaint, and have an endorsed filed copy thereof, of course you could not provide a case number.

You remind me of a prospective client who kept promising me a $20,000 retainer “just as soon as a wife transfer from my broker” comes through. He gave me the name and phone number of his bank, the manager’s name, but he could never provide a Fed wire #. You want to know why? He was lying, and I dropped him like a hot rock on emergency motion to withdraw.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Mon, Apr 25, 2016 at 10:33 AM
Subject: RE:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: Entire_World@gmail.com

That’s the thing about lawsuits: either they are FILED (in which case there is an ACTION NUMBER and proof of filing in the form if an endorsed filed copy) OR THERE ISN’T. also, in federal court, IF filed, it is instantly on PACER and PACER indicates you have NEVER FILED ANY LAWSUIT, LET ALONE A RICO SUIT. And, you case will either be dismissed OR IT WON’T BE DISMISSED.

No room for lies and bullshit. Liar.

Produce the action number and/or an endorsed filed copy of the complaint. Or admit you lied.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Mon, Apr 25, 2016 at 1:27 PM
Subject:
To: Entire_World@gmail.com

The last RICO suit was filed in the Central District on April 18. And not by Kelley Lynch.

https://dockets.justia.com/browse/state-california/court-cacdce/noscat-13/nos-470

Jeffrey Charles vs. Bank of America, et al

Filed: April 18, 2016 as 2:2016cv02636

Defendant: Bank of America, Bank of America, N.A., Does and others

Plaintiff: Jeffrey Charles

Court: Ninth Circuit › California › California Central District Court

Type: Other Statutes › Racketeer/Corrupt Organization

Harassment over Gianelli’s client, Karina Von Watteville, and the baseless, retaliatory, and extortionate lawsuit she filed (after she and Gianelli terrorized an individual preparing a declaration; she phoned Robert Kory in response to Paulette Brandt’s rental arrears demand letter; and Gianelli represented her and assisted in defrauding Ms. Brandt of $6,700 awarded to her by the Small Claims Court).

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Sat, Mar 26, 2016 at 2:06 AM
Subject: RE: Kelley Lynch email dated Friday, March 25, 2016 11:36 PM
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>

That is not my understanding.

I do know this: Unless you and Paulette Brandt can not only introduce ADMISSIBLE EVIDENCE (not hearsay, admissible evidence) proving ALL OF THE FOLLOWING Karina Von Watteville is a “thief”, moved into Brandt’s evidence with the intention not to pay rent AT THAT TIME, is a prostitute, a paid dominatrix, is dirty, allows her cats to defecate on the floor and does not clean it up, habitually infests wherever she lives with cockroaches and bed bugs, AND defrauded Sam Manning – then you and Paulette are going to lose in court. That is my “analysis” or just call it a “guess”. But as you know, my legal predictions always come true – from the outcome of your criminal appeal, to your motions to vacate, to Brandt’s small claims action and related motion. I am always right.

No, I am not saying KVW “defrauded” anyone – I am saying that UNLESS you can PROVE SHE DID, and prove each and every one of the other awful accusations you have made about her, you and Paulette Brandt are going to lose in court.

I suggest that you and Paulette take a crash course on the California Evidence Code – because admissible “proof” in a court of law is not “Linda Carol told me”.

Maybe you can call one of your IMAGINARY friends like David Geffen someone from the CIA or “ICE” to testify that these things are true. But whomever you call to the stand, they better have FIRST HAND KNOWLEDGE of ALL the things you alleged, because even if one out of six slanderous statements was false, you and Paulette still go down like the Titanic.

Second, that is just to get the evidence ADMITTED in court. Just because evidence is relevant and ADMISSIBLE does not mean that you will persuade the jury that the evidence is true, for example your criminal harassment case, where they believed the prosecution evidence and did not believe you

For example, your probation revocation hearing, where the court believed the prosecution evidence and did not believe you or Paulette.

Best of luck to you and Paulette!

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Fri, Mar 25, 2016 at 11:07 PM
Subject: RE: Kelley Lynch email dated Friday, March 25, 2016 11:36 PM
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: Karina Von Watteville <karina.inger.v@gmail.com>

What is your LEGAL AUTHORITY for the statement that a prayer for monetary relief contained in a civil complaint that is $1.00 or more constitutes the crime of extortion?

Where is the “threat” element for the crime of extortion set forth in Penal Code §§ 518-519?

For a person who not only lacks any legal training but has lost 10 out of the 10 legal motions/petition/proceedings she has been involved in (including the 2009 Colorado motion to vacate and the 2008 criminal tress pass trial) and has been 100% wrong about HER prediction of legal outcomes in her various matters to cite own “knowledge” as legal authority as your reply to my citation of the applicable criminal statute (which is written in plain English) and an on-point California Supreme Court case decided in 2006 is a bit ridiculous, don’t you think?

You cannot define extortion, you cannot explain why your opinion of what extortion is contrary to the Penal Code definition relied on by California’s highest court, you just “know” that the California Supreme Court is wrong?

And this is the legal compass you are using to navigate the labyrinth of legal and appellate proceedings you are now in the middle of? Ha! No wonder you lose every time you walk into a courtroom!

Why don’t you visit the West Hollywood station to “report a crime” to wit: “extortion” consisting entirely of filing a civil complaint that asks for more than $1.00 in damages and see what you are told? (When the sergeant on duty stops laughing long enough to speak.) Ha!

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Fri, Mar 25, 2016 at 10:23 PM
Subject: RE: Kelley Lynch email dated Friday, March 25, 2016 11:36 PM
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>

Ms. Lynch,

“Extortion is the obtaining of property from another, with his consent … induced by a wrongful use of force or fear….” (Pen.Code, § 518.) Fear, for purposes of extortion “may be induced by a threat, either: [¶] … [¶] 2. To accuse the individual threatened … of any crime; or, [¶] 3. To expose, or impute to him . . . any deformity, disgrace or crime[.]” (Pen.Code, § 519.) (See Flatley v. Mauro 39 Cal. 4th 299.) The unilateral act of filing a civil complaint that sets forth a demand for monetary relief lacks the necessary “threat” element of Penal Code §§ 518-519 and is therefore not actionable “extortion”.

“Fraud” includes the necessary elements of reasonable reliance by the person claiming fraud on a false statement of material fact that causes the person damage. Fritz Cos., Inc., 30 Cal. 4th 167, 184. To argue that a claim is barred by the applicable statute of limitations has expired is not a statement of material fact, let alone a false one; it is a legal argument.

You use these legal terms like you have a clue about what they mean. They have precise meanings, and you can’t make up those definitions as you go along.

Stephen Gianelli

Crete, Greece

Writing on my won behalf.

ENCLOSED:

From: Kelley Lynch [mailto:kelley.lynch.2013@gmail.com]
Sent: Friday, March 25, 2016 11:36 PM
To: alan hootnick; Stephen Gianelli
Subject: Fwd:

Alan Hootnick,

If KVW demanded $1, it is extortion. There is also fraud upon the Small Claims court which will now be addressed with LA Superior Court. Fraud and extortion are criminal conduct. KVW has not been slandered, libeled, or defamed but let’s see what Gianelli’s illustrious client has written. I have a writing sample of hers that involves attempting to extort $10,000 from Paulette Brandt in response to her Small Claims case.

The criminal stalker should move onto other victims now. His campaign of terrorism is coming to an end.

Kelley Lynch

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Mon, Apr 25, 2016 at 9:47 AM
Subject: RE: UNLIKE KELLEY LYNCH, PACER DOES NOT LIE. AND CALLING SOMEONE A “FAGGOT”, A “PUNK-ASS” AND A “MOTHER-F*^$ER” IS INDEED ABUSIVE YOU PIECE OF JAIL TRASH
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: Entire_World@gmail.com

Ha! If you FILED a RICO suit, then what is the federal docket number? “Filed” in the legal world means accepted for filing by the federal district court as indicated by a “filed” stamp on the file/service copies you hand endorsed. “Filed” means that your complaint was assigned to a judge and assigned an action number and was entered into the PACER system where it can be viewed in real time.

So produce an action number, or admit that you are LYING – just like you liked about David Geffen walking into your hovel at 2:00 am early Easter Morning as you were “doing that stations of the cross” and “making Rutger’s Easter basket” (and in between sending out bizarre and obscene mass emails to me, apparently!

Better yet, produce an endorsed filed copy of the face page of the complaint.

Or shut up.

ENCLOSED:

From: Kelley Lynch [mailto:kelley.lynch.2013@gmail.com]
Sent: Monday, April 25, 2016 6:37 PM
To: *irs. commissioner; Washington Field; ASKDOJ; : Division, Criminal; Doug.Davis; Dennis; MollyHale; fsb; rbyucaipa; khuvane; blourd; Robert MacMillan; a; wennermedia; Mick Brown; glenn.greenwald; Harriet Ryan; hailey.branson; Stan Garnett; Mike Feuer; mayor.garcetti; Opla-pd-los-occ; Kelly.Sopko; Whistleblower; Attacheottawa; tips@radaronline.com; alan hootnick; bruce
Cc: Stephen Gianelli
Subject: Fwd: UNLIKE KELLEY LYNCH, PACER DOES NOT LIE.

IRS, FBI, and DOJ,

The criminal is angry. I didn’t call him a “faggot” or “punk ass” “mother f^*ker” in response to his 20 or so insane emails highlighting tabloid articles about Phil Spector. I filed a RICO suit and this criminal’s lies will never change that fact. This man’s obsession is absolutely unconscionable. Imagine the type of human being that would terrorize someone’s family members for years? He is a dangerous to society. Am I jail trash because the City Attorney set me up and lied? I think not and I think the people involved in setting me up belong in prison.

Kelley

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Mon, Apr 25, 2016 at 1:46 AM
Subject: UNLIKE KELLEY LYNCH, PACER DOES NOT LIE
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: Entire_World@gmail.com
Civil Party Search
Mon Apr 25 02:47:13 2016No Records Found

User: Gianelli

Client: NO CLIENT

No records found

Receipt 04/25/2016 02:47:13 51177288
User Gianelli
Client NO CLIENT
Description Civil Party Search
Name lynch, kelley NOS 470 All Courts Page: 1
Pages 1 ($0.10)

For information or comments, please contact

From: Kelley Lynch [mailto:kelley.lynch.2013@gmail.com]
Sent: Monday, April 25, 2016 8:02 AM
To: Stephen Gianelli; *irs. commissioner; Washington Field; ASKDOJ; : Division, Criminal; Doug.Davis; Dennis; MollyHale; fsb; rbyucaipa; khuvane; blourd; Robert MacMillan; a; wennermedia; Mick Brown; glenn.greenwald; Harriet Ryan; hailey.branson; Stan Garnett; Mike Feuer; mayor.garcetti; Opla-pd-los-occ; Kelly.Sopko; Whistleblower; Attacheottawa; tips@radaronline.com; alan hootnick
Subject: Fwd: Kelley Lynch email dated Sunday, April 24, 2016 7:28 AM

Gianelli,

No one’s abusing you. You are a lying criminal stalker who has terrorized my sons for seven straight years now. You’re an ambulance chaser. That’s not abusive. It’s a fact.

Cohen owes me the tax information and that’s an issue in my RICO suit that was indeed filed, liar.ß

Cohen exposed his penis to me. A friend thought, since Cohen felt so brazen in his harassing conduct with me, perhaps he would like to talk about penis size. The man questioned me over Cohen’s forcing me to read business/legal documents to him while he exposed himself and took bubble baths. NAMBLA was about you – the criminal stalker who attempted to lure my minor son into communicating with you, an adult stranger, criminal, and liar. Torn fingers? Yes, I know, you’re such a criminal you wrote the “bloody stump” email and the prosecutor, being out of your school of filthy lawyering, went at me over my son’s accident. Cohen’s the porn artist. You want to talk about Phil Spector. I have all your harassing emails from last night and this morning with tabloid articles highlighted. Well, if it said “tax info,” it meant tax information and someone must have concealed something. I guess that’s why Cohen wrote in response to “tax info” that he sees my son copied in.

You’re a criminal. Cease and desist, clown.

Kelley Lynch

Harassment of Kelley Lynch & Paulette Brandt with Karina Von Watteville Copied In

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Mon, Apr 25, 2016 at 12:53 AM
Subject: Re: FW: Kelley Lynch email dated Sunday, April 24, 2016 7:28 AM
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>, Karina Von Watteville <karina.inger.v@gmail.com>, Paulette Brandt <paulettebrandt8@gmail.com>

As of right now per pacer no RICO suit. Liar.

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Sun, Apr 24, 2016 at 9:47 PM
Subject: Re: Kelley Lynch email dated Sunday, April 24, 2016 7:28 AM
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: blinddistribution <blinddistribution@gmail.com>, alan hootnick <ahootnick@yahoo.com>

Well, the person is recognized in a profession, has been financially successful, corresponds with Spector in prison, and more recently he telephones collect and (last time I inquired) spoke daily on the phone and the person has also visited him in prison a dozen times.
The person reached out to me to ask me to explain the probable timing of the appeals process and my views on its probable success. What I said in response was related to Spector, who praised my understanding of the case and who was “grateful” for my time and effort in explaining matters to his friend at no charge.
She has not told me anything about Spector that he did not give permission to tell me.
I would say she is an excellent source of information about Spector and how he feels about Kelley Lynch.
Far more so than someone (like you) who has not heard from Spector for ten years!
So dismiss it with sarcasm if you must. But I know a lot more CURRENT information about Spector’s legal and personal situation that you or Paulette Brandt ever will.

Stephen Gianelli Does Not Know Phil Spector, Kelley Lynch or Paulette Brandt – At All

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Sun, Apr 24, 2016 at 8:57 PM
Subject: Re: Kelley Lynch email dated Sunday, April 24, 2016 7:28 AM
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>, blinddistribution <blinddistribution@gmail.com>
Ms. Lynch,
I happen to know from a friend of Phil Spector’s, whose name is not Alan Hootnick, that Phil Spector regards you as crazy and will have nothing to do with you. Spector called my source almost every day from prison through the last time we exchanged emails, I made specific inquiries about you, and there is no way he would write to you or call you or take your calls. Ever.
He is accepting correspondence from – and returning it to – certain people, and my source is one of them.
The same goes for Rachelle Spector for that matter and everyone else close to Phil Spector or formerly close to him.
Your Facebook message merely corroborates what I already knew.
Kelley Lynch Has In Fact Heard From Phil Spector

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Sun, Apr 24, 2016 at 1:41 PM
Subject: Re: Kelley Lynch email dated Sunday, April 24, 2016 7:28 AM
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>, Paulette Brandt <paulettebrandt8@gmail.com> No, now you are changing the subject, which is whether you have communicated with Spector WHILE HE WAS IN PRISON and the answer (which I already knew from someone who speaks to him every day) is no way.
Paulette went to see him ONCE during the trial, according to a school teacher and Spector fan I still correspond with who attended every single day of the trial.
But you, Lynch, did not.
I also know from multiple persons that Spector stopped taking your calls ten years ago. You called him drunk, he things you are crazy, and he changed his mobile. He never took your calls again.
We are not speaking of the 1980’s.
Now go to 7-11 with what’s left of your $20 and buy a HoHo and a coke.
Fat. over the hill, irrelevant losers lying about the celebrities they still know. No David Geffen, no Phil Spector, no Oliver Stone. I speak of NOW, for the last decade, not your has been ancient history.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Sat, Apr 23, 2016 at 10:18 PM
Subject: FW: Kelley Lynch email dated Sunday, April 24, 2016 7:28 AM
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>

Ms. Lynch,

The FACT that Phil Spector has filed for divorce has been reported in multiple media outlets all over the world https://www.google.gr/search?q=phil+spector+divorce&ie=&oe=

It is not “tabloid gossip”.

I knew this was coming from a source who is close to Phil Spector, the airplane that his wife bought, and other details (that Mrs. Spector had “moved on” emotionally) since before Christmas of 2015. Another source told me the TMZ story was about to be published last week.

I know more about Phil Spector, his appeal, his legal matters, and his life in general that you will ever know and pretend to know.

Phil Spector thinks you are crazy, and he has nothing to do with you. While Paulette is generally liked, you are regarded by everyone around Spector as a weirdo to be avoided if possible. If Paulette was honest with you, she would tell you the same thing, since she also knows this full well.

You wouldn’t tell me what you know? Ha! That is a laugh! You have copied me with all manner of emails revealing everything there is to know about you – where you are moving, where you are living, where you are having lunch, who Paulette used to date, where Paulette is for Easter, what music you listen to, when you are fired, who your public defenders are – there is no detail about your life and the people around you that you have not revealed in mass emails. It is impossible to get you to shut up about “what you (claim to) know”. Ha!

Last, if you were so uninterested in what the “tabloids” have to say, you would not be ccing 90% of your emails to Radar on Line, which is the internet arm of the National Inquirer – the most notorious tabloid in the United States. But you are nothing if not hypercritical.

You really are a joke.

Stephen Gianelli

Writing for myself alone.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Sun, Apr 24, 2016 at 3:05 AM
Subject: D-I-V-O-R-C-E: It’s no rumor, it is fact
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Among the items Spector, 76, alleges Short has purchased is a $350,000 airplane, an Aston Martin and a Ferrari, expensive plastic surgery, expensive jewelry and two homes for her mom, TMZ reports.

Meanwhile, Spector says his bride only gives him $300 a month from his private stash to survive in jail.

Too bad you have spent so much energy sucking up to Rachelle! Ha!

Driving a Ferrari, an Aston Martin, a $350K plane, and TWO houses for her mom? AND putting hubby on a $300/month budget?

http://pagesix.com/2016/04/24/phil-spector-accuses-wife-of-blowing-fortune-seeks-divorce/

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Sun, Apr 24, 2016 at 9:46 AM
Subject: Re:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Again with the “RICO suit”. Ha! No lawsuit naming “Kelley Lynch” as a “plaintiff” is on file in any federal district court, and it never will be.

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Sun, Apr 24, 2016 at 9:40 AM
Subject: Re:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Cc: alan hootnick <ahootnick@yahoo.com>
1. I do not now, nor have I ever “represented” Leonard Cohen, nor have I ever met nor have I ever spoken to the man.
2. I am not “affiliated” in any way with the Phil Spector “prosecution” – which ended, BTW, with the final judgment of conviction entered in 2009 upon Spector’s sentence and remand to state prison. Indeed, even Spector’s trial prosecutors Truc Do and Alan Jackson are no longer affiliated with the “prosecution”; they left government service for private practice years ago. I have never been part of the Phil Spector prosecution. Prosecutors rely on paid members of the District Attorney’s staff, nor sub rosa secret agents.
3. I have never “consulted with” Gary or Louis Spector.
4. I have never taken a public position on Phil Spector’s guilt or innocence. I have been consistent in public and private since I first started following the case during the retrial: Phil Spector did not receive a fair trial. The trial should have been about what happened the night Lana Clarkson died. Instead it was (improperly in my view) about Phil Spector’s alleged bad character. In addition, the trial judge put his hand on the scales of justice when he improperly allowed the prosecution to use him during retrial as a “witness” for the prosecution on a critical issue and to characterize him to the jury as such.
5. I have never stated anything different than the above. I have never done anything except root for an acquittal and (after the judgment of conviction) a reversal and a new trial. I have been totally consistent for six years. Your spin on my public statements – that I was only pretending to support Phil Spector’s right to a fair trial – in order to “infiltrate” the defense as an agent for the prosecution is just asinine. There is no other way to say it. There is zero evidence to support that wild fantasy on your part.
On Sun, Apr 24, 2016 at 4:19 PM, Kelley Lynch <kelley.lynch.2013@gmail.com> wrote:

Stephen Gianelli,
I have received countless emails from you yesterday and last night about Phil Spector. Why act like a coward? Why not admit that you 1) represent Leonard Cohen; 2) are affiliated with the Spector prosecution; and, 3) have consulted with Gary and Louis Spector about their father’s estate. You’re a gossiping moron.
You have harassed me for years over Bruce Cutler. Why not call him up and harass him over how much you believe Rachel Spector spends. Maybe he would be interested in your deranged obsession.
Cease and desist.
Kelley Lynch

From: Stephen Gianelli <stephengianelli@gmail.com>
Date: Sun, Apr 24, 2016 at 9:24 AM
Subject: Re:
To: Kelley Lynch <kelley.lynch.2013@gmail.com>
Why would I seek information about Phil Spector from you when I already knew the divorce was coming in December of 2015?
YOU are the one who is out-of-the-Spector-information-loop, as proven by your initial reaction to the Spector divorce story: You dismissed it as “tabloid gossip”. It isn’t.

From: STEPHEN R. GIANELLI <stephengianelli@gmail.com>
Date: Sat, Apr 23, 2016 at 11:05 PM
Subject: Well coordinated my ass
To: Kelley Lynch <kelley.lynch.2013@gmail.com>

Phil Spector files for divorce from Rachelle Short: Report

WENN.COM

First posted: Saturday, April 23, 2016 10:58 AM EDT | Updated: Saturday, April 23, 2016 11:09 AM EDT

Phil Spector and wife Rachelle Short. (REUTERS)