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ExhibitB; Page17; lines19-27

Begins: "Dear Kelley"

Continues to: "...Very trulyyours ..."

Relevance.No connectionwhatsoever to subject ofcurrent motion.Lack of Foundation.Appears to quote a letterwith no showing ofauthenticity

Grant _Deny

ExhibitB; Page18;Lines4-27

Begins: "ln the fall of 2004,after hearing that Lynch wasreporting his tax fraud ...."

Continues to: "...The entiresituation has exposed Lynch toblackmail, extortion, falseaccusations, slander,defamation, and threats."

Relevance.No connectionwhatsoever to subject ofcurrent motion.Conclusions andal legations rather thanfactual statements.lntentional defamatorystatements made forimproper purpose withno connection tocurrent matter beforethe Court.

Grant _Deny

ExhibitB; Page19;Lines5-6

"matters involvi ng [Plaintiff 's]and Kory's attempts to extortmonies"

lmproper opiniontestimony;Conclusions andal legations rather thanfactual statements.lntentional defamatorystatements made forimproper purpose withno connection tocurrent mafrer beforethe Court,

Grant _Deny

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ExhibitB; Page19; line'11

"his tax fraud" Improper opiniontestimony;Conclusions andal legations rather thanfactual statements.I nte ntio nal defamato rystatements made forimproper purpose withno connection tocurrent mafrer beforethe Court.

Grant _Deny

ExhibitB; Page20; Iines14-14-15

[Plaintiff], Kory, Greenberg,Westin, and others,endeavored to obstruct justice,acted corruptly, and had thespecific intent to interfere witha number of proceedings.

improper opiniontestimony;Conclusions andal legations rather thanfactual statements.

Grant _Deny

ExhibitB; page22; lines6-7

Lynch was convinced that[Plaintiff's] tax strategies wereundertaken for the solepurpose of evading taxes.

Relevance.lmproper Opinion.This opinion is simply notrelevant to any issuebefore the court. Theopinion is not admissibleunder Evidence Codesection 800.

Grant _Deny

ExhibitB; Page22; lines23-28

Begins " The IRC prohibits non-residents from beingshareholders ..."

Continues to: "...income taxreturn in proportion to his orher"

Relevance,Lack of Foundation.lmproper Opinion.Declarant has noexpertise to allow adeclaration on tax laws.

Grant _Deny

ExhibitB; pagelines 1-6

Begins "ownership interest andare taxed ...."

Continues to "...what appearsto be unlawful andlor criminalconduct."

Relevance.Lack of Foundation.lmproper Opinion.Declarant has noexpertise to allow adeclaration on tax laws.

Grant _Deny

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ExhibitB; Page28; lines1-3

"income taxes and remainunder the radar of the lnternalRevenue Service, State ofKentucky, and Franchise TaxBoard. Lynch eventuallyheard from [Plaintiff's] lawyer,Robert Kory, that there was taxfraud on every Cohen relatedentity, including StrangerMusic."

Hearsay.Lack of Foundation.Declarant has noexpertise to allow adeclaration on tax laws.Declaration quotesunauthenticatedstatements of otherpersons.

Grant _Deny

ExhibitB; Page29; line7

"propose strategies to reduceor evade taxation"

Relevance.No connectionwhatsoever to subject ofcurrent motion.Lack of Foundation.Declarant has noexpertise to allow adeclaration on tax laws.Declaration quotesunauthenticatedstatements of otherpersons.

Grant _Deny

ExhibitB; page29; line28 -page30; line1

"At their luncheon in the springof 2005, Kory confirmed thatthe holding periods wereillegal."

Hearsay.Declaration quotesunauthenticatedstatements of otherpersons.Lack of Foundation,Declarant has noexpertise to allow theopinion

Grant _Deny

ExhibitB; Page30; lines15-22

Begins: "Other suspect, andpotentially illegal ...."

Continues to "...shamtransactions, and so forth andso on."

lmproper Opinion.Lack of Foundation.Declarant has noexpertise to allow theopinion.

Grant _Deny

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ExhibitB; Page30; lines23-28

Begins "Ed Dean's fax ...."

Continues to: "...affect theamount of sale proceedspayable

Relevance.Authenticity. Purports toquote a letter. Nocompliance with EvidenceCode sections 140011401.

Grant _Deny

ExhibitB; Page31; lines1-28

Begins "to the trusts I do notbelieve ...."

Continues to: "l own 15h andBob Johnston of SincereProductions"

Relevance.Authenticity. Purports toquote parts of variousbusiness letters with noconnection to subject ofmotion and nocompliance with EvidenceCode sections 14OOl1401.

Grant _Deny

ExhibitB; Page32; lines1-14;lines13-14

Begins: "lnc. owns 15/"...."

Continues to: "...Sincerely"

Relevance.Authenticity. Purports toquote a letter- Nocompliance with EvidenceCode sections 14OAl1401.

Grant _Deny

ExhibitB; Page32; line27-Page 33;line 7

Begins "Dear Kelley ..."

Continues tot "...1 miss youtoo."

Relevance.Authenticity. Purports toquote a letter. Nocompliance with EvidenceCode sections 14A011401.

Grant _Deny

ExhibitB; Page33; lines8-9

"[Plaintiff's ] arrogance,aggression, jealousy, andmisogynistic tendencies are allself-evident in this letter"

lmproper opiniontestimony;Conclusions andallegations rather thanfactual statements.lntentional defamatorystatements indeclaration made forimproper purpose withno connection tocurrent matter betorethe Court.

Grant _Deny

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ExhibitB; Page33; line24-Page34; line2

Begins: "Dear Richard ...."

Continues to: "... Regards."

Relevance. Materiality.Authenticity. Purports toquote a letter. Nocompliance with EvidenceCode sections 140011401.

Grant _Deny

ExhibitB; Page34; lines1-28

Begins: "prepayment againstthe proposed ...."

Continues to: "[Plaintiff] andCAK entered into a"

Relevance. Grant _Deny

ExhibitB; Page36; lines1-2

"[Plaintiff] has a pattern ofbreaching contracts. lt arisesfrom his sense of entitlement."

improper opiniontestimony;Conclusions andal legations rather thanfactual statements.I ntentional defamatorystatements made forimproper purpose withno connection tocurrent matter beforethe Coufi,

Grant _Deny

ExhibitB; Page36; lines6-13

Begins: "Excerpts from thatOption are as follows ...."

Continues to: "...in failedattempt to assign away incomeform the personal services."

Relevance,Authentieity. Purports toquote a communication,form unspecified.

Grant _Deny

ExhibitB; Page36; line18-Page37; lineI

Begins: "Dear Kelley,...."

Continues to: "...Let's tatksoon."

Relevance.Hearsay.Authenticity. Purports toparaphrase an e-mail. Nocompliance with EvidenceCode sections 140011401.

Grant _Deny

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ExhibitB; Page37; lines9-24

Begins: "Richard Westin'sFacsimile Message toLynch ...."

Continues to: "they viewed thatdeal as bankruptcy proof"

Relevance,Authenticify. Purports toquote a communication,form unspecified. Nocompliance with EvidenceCode sections 140011441.

Grant _Deny

ExhibitB; Page38; lines1-17

Begins: "substantialroyalties...."

Continues to: "... ldeclareunder penalty of perjury thatthe foregoing is true andcorrect. Dated:August 30, 200.Signed"

Relevance,Authenticity. Purports tobe an excerpt from a legalcase file. No request forjudicial notice and nosupporting Exhibit.

Grant _Deny

ExhibitB; Page38; lines22-27

Begins: "Don Friedman'smemorandum of September19, 2000 ...."

Continues to: "...Thismemorandum is aconfirmation"

Relevance.Hearsay.Authenticity. Purports toquote a communication,form unspecified. Nocompliance with EvidenceCode sections 140A11401.

Grant _Deny

ExhibitB; Page39; lines7-20

Begins: "Paul Gilbert of Sonycalled to ask us to provideSony with ...."

Continues to: "in order toprotect Sony against tax andother corporate liabilities."

Relevance.Hearsay,Authenticity. Purports toquote a communication,form unspecified. Nocompliance with EvidenceCode sections 140011401.

Grant _Deny

ExhibitB; Page40; Iine6-line 28

Begins: "ln a fax dated October10,2000, Greg McBowmanasked ...."

Continues to: "...RichardWestin"

Relevance.Hearsay.Authenticity.Quotes or paraphrasesvarious allegedcommunications ofunspecified form.

Grant _Deny

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ExhibitB; Page44; lines28-page45;lineS

Begins: "ln 2001, he failed toreport the income from ...."

Continues to: "...They werebrought to her attention byDale Burgess and Dimascio &Berardo."

Relevance.Hearsay.The sequence ends withdeclarant admitting nopersonal knowledge andsaying the informationwas brought to herattention by someoneelse.

Grant _Deny

ExhibitB; Page45; lines9-22

Begins: " As a separate matter,we also want to advise you....

Continues to: "lt is ourunderstanding that you arerelying on their adviceregarding these matters."

Relevance.Authenticity.Purports to quote a letter.No basis in declarationfrom which to ascertainauthenticity.

Grant _Deny

ExhibitB; Page45; lines27-28

"A federal controversy appearsto have arisen"

Speculation.No Foundation.Declarant has noapparent knowledge orexpertise to express thisopinion.

Grant _Deny

ExhibitB; Page46; lines4-25

Begins: "You have requestedmy opinion ...."

Continues to: "...The concept ofthe private annuity is that anytax is deferred until paymentsbegin."

No Foundation.Purports to quote a letter.No basis in declarationfrom which to ascertainauthenticity. Nocompliance with EvidenceCode sections 140011401.

Grant _Deny

ExhibitB; Page47; lines16-24

Begins: "[Plaintiff] owes loansand/or advances to TraditionalHoldings, LLC totaling millionsof dollars ...."

Continues tot "...Fraudulentmisrepresentations and forother reasons."

No Foundation.Declarant has noknowledge or expertise toallow the opinion.

Grant _Deny

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ExhibitB; Page48; lines1-4

Begins: "ln our review of your1999 tax return ...."

Continues to: "...Please use theenclosed envelope to send anysupporting documents youwant us to consider."

Authenticity.No Foundation.Purports to quote a letter.No basis in declarationfrom which to ascertainauthenticity.Nocompliance with EvidenceCode sections 140011401.

Grant _Deny

ExhibitB; Page48; lines10-28

Begins: "As of January 2002,the IRS continued to address[Plaintiff 's] tax deficiency ...."

Continues to: "...1n 1999, youreceived a $1 million advancefrom Sony. Your"

Hearsay.Authenticity.No Foundation.

Grant _Deny

ExhibitB; Page6; lines14-23

Begins "management team toldme...."

Continues to: "...penalties tothe IRS for underpayment oftaxes."

Hearsay,Authenticity.No Foundation,

Grant _Deny

ExhibitB; Page49; line20-Page51; line10

Begins "Richard Westin letterto [Plaintiff] dated March 6,2002: ...;'

Continues to: "...everythingshould be quite smooth anduncomplicated."

Hearsay.Authenticity.No Foundation.Purports to quote orparaphrase a letter. Nobasis in declaration fromwhich to ascertainauthenticity. Nocompliance with EvidenceCode sections 14AOl1401.

Grant _Deny

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ExhibitB; Page51 line1'l

"The above letter essentiallyaddress Cohen's use ofcorporations in an attempt toevade taxes."

No Foundation.lmproper opiniontestimony;I nte nti o n a I d ef a m ato rystatements made forimproper purpose withno connection tocurrent matter beforethe Court.

Grant _Deny

ExhibitB; Page51; line16-21

Begins "Stuart Friend's fax toRichard Westin dated ...."

Continues to: "...Sincerely PaulGilbert."

Hearsay.Authenticity.No Foundation,Purports to quote a letter.No basis in declarationfrom which to ascertainauthenticity.Nocompliance with EvidenceCode sections 14OAl1401.

Grant _Deny

ExhibitB; Page52; lines1-2

"lt was around this time thatBlanq advised Lynch thatRichard Westin's evasivenessmade the Ogden, Utah IRSagent nervous."

Hearsay. Grant _Deny

ExhibitB; Page52; lines6-14

Begins: "ln 2003 and 2004, theFranchise Tax Board ...."

Continues tot "... the apparenttax deficiency."

Speculation.No Foundation.

Grant _Deny

ExhibitB; Page52; Iine15

"[Plaintiff's] failure to file statetax returns"

Speculation.No Foundation.

Grant _Deny

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ExhibitB; Page53; lines1-22

Begins "Richard Westin's letterto [Plaintiff] ...."

Continues to: "...to ask the IRSto review the corporatestructures, private annuityagreement, and related taxreturns."

Hearsay.No Foundation.Authenticity.Purports to paraphrasevarious sourcesOpinions stated with noproper foundation indeclaration.I ntenti on al defa m atorystatements made forimproper purpose withno connection tocurrent matter beforethe Court.

Grant _Deny

ExhibitB; Page53; line25

"Lynch believes this was anintentional mistake"

lmproper OpinionNo Foundation.Opinions stated with noproper foundation indeclaration.

Grant _Deny

ExhibitB; Page53; line28-page54; line10.

Begins: "The K-1s, whichreflect a 99.5% ownershipinterest on Lynch's part withrespect to LCl, are clearlyfraudulent.,.."

Continues to: "...State ofKentucky, is unlawful. Thesame is true for the K-1s LClnvestments, transmitted to theIRS (with respect to KelteyLynch) for the years 2004 and2005.

I

I Hearsay.I lto foundation.I Purports to paraphraseldocuments.Opinions stated with noproper foundation indeclaration.I ntentional defamatorystatements made forimproper purpose withno connection tocurrent matter beforethe Court.

Grant _Deny

ExhibitB; Page54; lines14-27

Begins: " Lynch is convincedthat the steps with respect tothese corporations are a steptransaction."Continues to: "the tax law willnot regard the"

Relevance.lmproper Opinion.Opinions stated with noproper foundation indeclaration.

Grant _Deny

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