October 2024 - cypherpunks - lists.cpunks.org

NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 06 Dec '24

06 Dec '24

Ms. Scott: NY-DFS recently asked for public comment concerning "Proposed Guidance on Assessment of the Character and Fitness of Directors, Senior Officers, and Managers" mentioned here: https://www.dfs.ny.gov/industry_guidance/industry_letters/il20230509_guidan… . xNY.io - Bank.org asks if the NY-DFS will extend deadline for public comment to August 5, 2023 from June 30, 2023. As requested by NY-DFS, today we provide (in a separate attachment) evidence of any documented exceptions to compliance with the "Suggested Questions to Facilitate Initial and Ongoing Assessment of Designated Persons’ Character and Fitness." We have collated 19 references comprising 205 highlights that touch on the five key areas below: https://drive.google.com/drive/folders/1FTRRFFhQHDxf-oR9WOZz0a2gRtC9ZWVO. -Harassment and Discrimination Policies -Conflict of Interest Policy -Insider Trading Policy -Records Management Policy -Corporate Opportunity Policy xNY.io - Bank.org is seeking NY-DFS' extension for public comment to August 5, 2023 so that the New York Banking community has time to complete Q2-23 earnings call disclosures. As documented in the above 19 references, we feel extra time for public comment is warranted to ensure that xNY.io - Bank.org did not play a significant role or otherwise contribute in a meaningful way to the conduct that led to regulatory action or proceeding without ample notice. Per point one of NY-DFS' "Suggested Questions to Facilitate Initial and Ongoing Assessment of Designated Persons’ Character and Fitness," can you kindly acknowledge that you have reviewed and understand our appeal seeking extension for public comment to August 5, 2023? We hope to hear from you before June 30, 2023 given obvious factors. Sending you the very best regards. Thank you, Gunnar -- Gunnar Larson xNY.io | Bank.org MSc - Digital Currency MBA - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-917-580-8053 New York, New York 10001

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Advisory board goal for Post Office scandal victims to be returned to rightful financial position
by Gunnar Larson 06 Dec '24

06 Dec '24

https://www.computerweekly.com/news/252529287/Advisory-board-goal-for-Post-… The board set up to monitor the compensation scheme for Post Office scandal victims agrees goal of returning them to the financial position they would be in had the scandal never happened Karl Flinders, Chief reporter and senior editor EMEA Published: 18 Jan 2023 12:15 The advisory board set up to oversee compensation awards to 555 victims of the Post Office Horizon scandal has agreed a goal of returning them to the financial position they would have been in had the scandal not happened. Thousands of former subpostmasters were blamed for accounting shortfalls caused by errors in the Post Office accounting software. They were forced to repay huge sums, and were often bankrupted as a result. Many were prosecuted and sent to prison. The scandal destroyed the lives and livelihoods of the former subpostmasters and their families for decades, with many suffering stress-related illness. Suicides have been linked with the scandal. In its first meeting, the GLO Compensation Scheme Advisory Board met representatives of the Department for Business, Energy and Industrial Strategy (BEIS). The board agreed: “As with the general law, the goal should be to restore the claimants to the position that they would have been in if the scandal had not happened.” The 555 former subpostmasters and Post Office branch workers were part of a Group Litigation Order (GLO), which in 2019 proved that the software used by Post Office branches, known as Horizon, was causing the unexplained shortfalls they were blamed for. They proved the software, from Fujitsu, was to blame, and forced the Post Office to admit this was the case after nearly 20 years of denying it. The Justice for Subpostmasters Alliance The victory for the 555 subpostmasters in the High Court, all part of the Justice for Subpostmasters Alliance (JFSA), were awarded £58m in damages, but after their legal costs – provided by a litigation funder that requires repayment with interest – were taken out, they were left with just £11m to share. This left people that had lost homes, businesses and huge sums of money with an average of a few thousand pounds each. The judgements in the High Court case, which was paid for by the victims, also triggered the unravelling of one of the biggest miscarriages of justice in British history. So far, more than 80 former subpostmasters have had wrongful convictions for theft and fraud overturned. The court ruling also forced the Post Office to set up a compensation scheme for any subpostmaster affected by the Horizon errors. But the Post Office and its government backer did not allow any of the 555 that took part in the court action to apply, citing that the compensation that was already paid was “full and final”. Alan Bates, the former subpostmaster who set up the JFSA in 2009 and has chaired it since, wrote to the government after the court victory, demanding it paid the legal costs to leave JFSA members with fairer compensation, but the government refused. But Bates and JFSA members kept pushing the government for justice, and through generating public pressure and instigating a judicial review forced the government to set up a statutory public inquiry into the Horizon scandal, which is ongoing. Although compensation was initially left out of the terms of reference of the public inquiry, the JFSA and its supporters forced the government to include an examination of compensation. Fair compensation The JFSA kept fighting for fair compensation, just as they had fought for justice for over a decade, and in June, the government was forced to agree to pay it. The GLO Compensation Scheme Advisory Board, set up to oversee the JFSA compensation scheme, is made up of University of Oxford professor Christopher Hodges, who is chair, peer James Arbuthnot and MP Kevan Jones, who have supported and campaigned for justice for victims of the Horizon scandal for two decades. Arbuthnot said he was encouraged by the first meeting of the board with BIES representatives. “Two key principles – the need for the goal to be to restore the claimants to the position that they would have been in if the scandal had not happened, and the imperative of speed of compensation – were agreed,” he said. “Now we need to ensure that both are carried out.” Jones said: “Good progress was made during the first meeting of the GLO Compensation Scheme Advisory Board, including the parameters of the scheme. The next meeting will be in February, where we will discuss setting up the scheme as soon as possible.” JFSA chair Bates said: “An oversight board was something very much missing in previous schemes and it offers reassurance to the scheme that people that have been so supportive over the years are involved. It also provides some transparency.” In 2009, Computer Weekly told the stories of seven subpostmasters affected by the problems (see timeline of Computer Weekly articles below). Read all Computer Weekly articles about the scandal since 2009 May 2009: Bankruptcy, prosecution and disrupted livelihoods – postmasters tell their story. September 2009: Postmasters form action group after accounts shortfall. November 2009: Post Office theft case deferred over IT questions. May 2010: A pilot of the new Horizon Online system at Royal Mail has been scaled back after connectivity problems and outages. February 2011: Post Office faces legal action over alleged accounting system failures. October 2011: 85 subpostmasters seek legal support in claims against Post Office computer system. June 2012: Post Office launches external review of system at centre of legal disputes. January 2013: Post Office admits Horizon system needs more investigation. January 2013: Post Office announces amnesty for Horizon evidence. January 2013: Post Office wants to get to bottom of IT system allegations. June 2013: Investigation into Post Office accounting system to drill down on strongest cases. July 2013: Post Office Horizon system investigation reveals concerns. October 2013: End in sight for subpostmaster claims against Post Office’s Horizon accounting system. October 2013: Former Lord Justice of Appeal Hooper joins Post Office Horizon investigation. November 2013: 150 subpostmasters file claims over “faulty” Horizon accounting system. September 2014: Fresh questions raised over Post Office IT system’s role in fraud cases. December 2014: MPs blast Post Office over IT system investigation and remove backing. December 2014: Why MPs lost faith in the Post Office’s IT investigation, but vowed to fight on. December 2014: MPs to debate subpostmaster IT injustice claims. December 2014: MP accuses Post Office of acting ‘duplicitously’ in IT investigation. January 2015: MPs force inquiry into Post Office subpostmaster mediation scheme. January 2015: Post Office faces grilling by MPs over Horizon accounting system. February 2015: Post Office CIO will talk to any subpostmaster about IT problems, promises CEO. March 2015: Post Office ends working group for IT system investigation day before potentially damaging report. March 2015: MPs seek reassurance over Post Office mediation scheme. March 2015: Retiring MP aims to uncover truth of alleged Post Office computer system problems. April 2015: Post Office failed to investigate account shortfalls before legal action, report claims. April 2015: Criminal Courts Review Commission set to review subpostmasters’ claims of wrongful prosecution. June 2015: Post Office looking to replace controversial Horizon system with IBM, says MP. July 2015: Campaigners call for independent inquiry into Post Office Horizon IT system dispute. October 2015: James Arbuthnot takes Post Office IT fight to House of Lords. November 2015: The union that represents Post Office subpostmasters has warned of a problem with the Horizon accounting system. November 2015: An email from Post Office IT support reveals a problem with the Horizon system and supporting processes that could lead to accounting errors. November 2015: Group litigation against Post Office being prepared in Horizon dispute. February 2016: Post Office faces group litigation over Horizon IT as subpostmasters fund class action. June 2016: Post Office chairman Tim Parker says there would be “considerable risk” associated with changing its Horizon computer system. November 2016: The legal team hired by a group of subpostmasters will take their case to the next stage. January 2017: The group action against the Post Office that alleges subpostmasters have been wrongly punished for accounting errors gets green light from the High Court of Justice. March 2017: 1,000 subpostmasters apply to join IT-related group litigation against Post Office. April 2017: Investigation into claims of miscarriages of justice in relation to a Post Office accounting system has appointed a forensic accountant firm. May 2017: Hundreds of subpostmasters have applied to join IT-related legal action since March. July 2017: Post Office defence in computer system legal case due this week. August 2017: Campaigners submit initial evidence in group litigation against Post Office over controversial Horizon IT system. October 2017: Subpostmasters’ group action against the Post Office reaches an important milestone. November 2017: An end is in sight for subpostmasters’ campaign against alleged wrongful prosecution, which they blame on a faulty computer system. November 2017: The High Court judge managing the subpostmasters versus Post Office legal case over an allegedly faulty computer system tells legal teams to cooperate. January 2018: Forensic investigation into Post Office IT system at centre of legal case nears completion. April 2018: Criminal Cases Review Commission forensic examination of the IT system at the centre of a legal case against the Post Office has raised further questions. May 2018: Post Office branches unable to connect to Horizon computer system for several hours after morning opening time. October 2018: After over a decade of controversy, next week marks the beginning of a court battle between subpostmasters and the Post Office. November 2018: Case against Post Office in relation to allegedly faulty computer system begins in High Court. November 2018: High Court case in which subpostmasters are suing the Post Office has revealed a known problem with a computer system at the core of the dispute. November 2018: A High Court trial, where subpostmasters are suing the Post Office for damages caused by an allegedly faulty IT system, ends second week. November 2018: Post Office director admits to Horizon errors and not sharing details with subpostmaster network. November 2018: The High Court trial in which subpostmasters are suing the Post Office has reached an important stage. December 2018: CCRC may hold off subpostmaster decision until after Post Office Horizon trial. December 2018: Court case where subpostmasters are suing the Post Office set to span at least four trials and extend into 2020. January 2019: Subpostmasters’ campaign group attacks Post Office CEO Paula Vennells’ New Year honour amid ongoing court case. January 2019: Thousands of known errors on controversial Post Office computer system to be revealed. March 2019: Tech under spotlight at High Court in second subpostmasters versus Post Office trial. March 2019: Post Office considered Horizon IT system “high-risk”, court told. March 2019: CCRC watching Post Office Horizon trial closely. March 2019: Judge rules that Post Office showed “oppressive behaviour” in response to claimants accused of accounting errors they blamed on Horizon IT system. March 2019: Post Office “lacked humanity” in the treatment of subpostmasters, says peer. March 2019: A High Court judge heard that the Post Office did not investigate a computer system error that could cause losses, despite being offered evidence. March 2019: The Post Office legal team in the case brought by more than 500 subpostmasters has called for the judge to be recused after questioning his impartiality. March 2019: A senior civil servant asked the Post Office to repay public money it had wrongly allocated to paying legal costs. April 2019: Subpostmaster claimants’ legal team makes application for the Post Office to pay millions of pounds of costs associated with trial. April 2019: Post Office to appeal judgment from first Horizon trial. April 2019: The Post Office’s claim that the judge overseeing the case concerning its controversial Horizon IT system was biased has been dismissed. April 2019: MP questions government over Post Office Horizon case. April 2019: Government says no conflict of interest in trial despite Post Office chairman’s dual role. May 2019: The Court of Appeal has refused the Post Office’s application to appeal a major decision in the Horizon IT trial. May 2019: The Post Office has applied for permission to appeal judgments from the first trial in its IT-related legal battle with subpostmasters. May 2019: The judge in the Post Office Horizon trial has ordered the organisation to pay the legal costs of its courtroom adversaries, and refused to give permission to appeal a major judgment. June 2019: Post Office asks Court of Appeal for permission to appeal judgment in first Horizon trial. July 2019: The Post Office has admitted that some subpostmasters are at risk of accounts not balancing due to an error it does not understand. July 2019: Problem revealed during High Court trial left subpostmaster with £18,000 surplus after IT system failed to register full amount of cash scanned in. August 2019: Subpostmasters suffering slow running and frozen terminals while Post Office searches for a fix to issues apparently caused by a software update. August 2019: The Post Office has fixed the latest problems with its Horizon system, affecting hundreds of branches. October 2019: A High Court judgment for a trial that focused on the Post Office’s IT system at the centre of a multimillion-pound litigation will be announced early next month. November 2019: The Court of Appeal has rejected a Post Office application to appeal judgments made in its multimillion-pound battle with subpostmasters over IT system failures. November 2019: Peer calls for clear-out of Post Office board after Court of Appeal confirms major court defeat. December 2019: The Post Office has settled its long-running legal dispute with subpostmasters, and will pay £57.75m in damages. December 2019: Subpostmansters ended their legal battle with the Post Office at the optimal time, according to the lawyer that managed the High Court action. December 2019: Subpostmansters proved right on IT system failures as calls for full public inquiry mount. December 2019: Criminal Courts Review Commission to review Horizon judgment “swiftly”. December 2019: National Federation of Subpostmasters cries foul after court ruling on controversial computer system. December 2019: Former Post Office CEO apologises to subpostmasters over Horizon scandal. December 2019: Call for former Post Office CEO to step down from public roles after IT court battle lost. January 2020: Fujitsu must face scrutiny following Post Office Horizon trial judgment. January 2020: Subpostmaster group calls for government to pay legal costs for Horizon trial. January 2020: Why subpostmasters are calling on the government to pay Horizon trial costs. January 2020: Department for Business, Energy & Industrial Strategy says it did not make decisions in the Post Office’s recent court battle. January 2020: Government should not be allowed to dismiss subpostmasters’ claims over Horizon IT scandal. January 2020: Police sent information about potential Fujitsu staff perjury in subpostmaster prosecutions. January 2020: Prosecutions are a significant step closer to being sent to the Court of Appeal as Criminal Courts Review Commission forms a group of commissioners to review them. January 2020: Alan Bates: The “details man” the Post Office paid the price for ignoring. February 2020: The government has refused to pay the huge legal costs subpostmasters incurred in their battle with the government-owned Post Office, which they won. February 2020: Members of Parliament seeking a public inquiry into the Post Office Horizon scandal face huge challenges, but pressure and time could force justice. February 2020: Calls for inquiry into Post Office IT scandal increase in Parliament, with cross-party support. February 2020: Care Quality Commission to review concerns over Paula Vennells’ appointment after they were raised by a former NHS consultant psychiatrist. February 2020: Government admits it was too passive managing Post Office as parliamentary pressure builds. February 2020: Minister says Post Office IT experts misled the government when it asked questions about subpostmasters’ concerns over Horizon IT system. March 2020: Boris Johnson commits to “getting to the bottom of” Post Office Horizon IT scandal. March 2020: Boris Johnson’s commitment to inquiry into Post Office scandal in doubt. March 2020: MPs call on PM to commit to full public inquiry into Post Office Horizon IT scandal. March 2020: Those who did not play by the rules in Post Office Horizon scandal “should face prosecution”. March 2020: MPs told to hold to account those responsible for Post Office Horizon IT scandal. March 2020: The Post Office has sparked anger with secret settlements with subpostmasters outside the recent legal action against it. March 2020: Labour MP Karl Turner tells Computer Weekly that the Post Office Horizon scandal is the most grotesque version of predatory capitalism he has ever seen. March 2020: MP Kevan Jones has warned a government minister not to repeat the mistakes of predecessors in relation to the Post Office Horizon IT scandal. March 2020: Criminal Cases Review Commission to use Microsoft Teams to ensure review of subpostmaster prosecutions is held on time. March 2020: Post Office postpones subpostmaster compensation scheme amid Covid-19 crisis. March 2020: Meeting reviewing subpostmaster applications to appeal criminal prosecutions moves into second day. March 2020: Subpostmaster prosecutions to be considered by Court of Appeal for miscarriages of justice. March 2020: How subpostmasters made legal history with biggest referral of potential miscarriages of justice. April 2020: Met Police examines information about evidence given in court by Fujitsu staff on the Horizon IT system. May 2020: Subpostmasters who had their lives ruined by the Post Office’s faulty IT system have received their damages after a High Court victory. May 2020: A senior Post Office executive at the centre of an IT scandal, who tried to mislead a High Court judge in relation to it, has left the organisation without fanfare despite many years of service. May 2020: Post Office re-examines hundreds of prosecutions that could have resulted from faults in Horizon IT system. June 2020: A campaign group representing subpostmasters wrongly prosecuted for theft and false accounting by the Post Office is raising money to help clear the names of victims of the scandal. June 2020: Subpostmasters to force scrutiny of government’s role in Post Office IT scandal. June 2020: The Criminal Cases Review Commission sends 47 more subpostmaster cases to Court of Appeal and asks government to review private prosecution powers. June 2020: Select committee chair writes to former Post Office CEO demanding answers over her role in IT scandal. June 2020: The government has been accused of launching a review that fails in getting to the bottom of one of the biggest miscarriages of justice in UK history. June 2020: Subpostmasters will not cooperate with government review into IT scandal. June 2020: The government’s proposed review of the Post Office IT scandal has received a further setback as forensic accountants join subpostmasters in refusing to back it. June 2020: Call for government review of Post Office Horizon scandal to have the power to force individuals to give evidence under oath. June 2020: Subpostmasters seeking justice in the Post Office Horizon IT scandal are regaining momentum in Parliament. June 2020: Healthcare regulator will be discussing concerns about former NHS boss chairing an NHS trust at an upcoming meeting. June 2020: Second Sight is working with law firm in appeals by subpostmasters against criminal convictions in Horizon IT scandal. June 2020: Post Office and Fujitsu blame each other for many of the failings in the Horizon IT scandal that wrecked lives. June 2020: Parliamentary Justice Committee to hold short inquiry into the rules and regulations surrounding private organisations’ ability to initiate criminal proceedings. July 2020: Victims of the Post Office Horizon IT scandal need to raise thousands of pounds in a week or those responsible for their suffering will avoid scrutiny. July 2020: The government is set to face scrutiny over its involvement in the Post Office Horizon IT scandal, described as one of the biggest miscarriages of justice in modern UK history. September 2020: The government repeats that it won’t pay victims’ legal costs and confirms review into the scandal will not have the power to call witnesses. September 2020: Subpostmasters still not being told about all the known errors in the controversial Post Office branch accounting and retail system that they use. October 2020: The Post Office has chosen not to contest 44 out of 47 appeals, meaning most are likely to have their names cleared, but others still face a Court of Appeal battle for justice. October 2020: MPs are demanding the government holds a full statutory public inquiry into the Post Office IT scandal. October 2020: NHS regulator continues enquiries about the appointment of former Post Office CEO at Imperial College Healthcare NHS Trust as more damning details emerge. October 2020: Government minister met with former subpostmaster online in an attempt to get victims of the Post Office Horizon scandal involved in government review. October 2020: The Post Office is focusing urgently on fixing an IT error suffered by a subpostmaster amid the ongoing IT scandal. October 2020: Labour politicians are calling for the government to give the Post Office Horizon scandal inquiry the power to force witnesses to give evidence if they don’t cooperate. October 2020: Imperial College Healthcare NHS Trust has asked for external review of its process when appointing controversial executive. November 2020: Government faces scrutiny of its handling of the Post Office IT scandal that destroyed subpostmasters’ lives and livelihoods. November 2020: Post Office branches offline during busy business hours after suffering an IT error that the Post Office said related to IT from supplier Fujitsu. November 2020: Fujitsu is refusing to explain what caused a national system outage in Post Office branches last week, despite the Post Office confirming the issue was the fault of the supplier. November 2020: The Metropolitan Police opens criminal investigation into Fujitsu staff who gave evidence in trials of subpostmasters wrongly prosecuted and even imprisoned for financial crimes. November 2020: Post Office criticised over vagueness of its explanation of the cause of a UK-wide IT failure that saw subpostmasters unable to do business. November 2020: Post Office says planned firmware update caused the problem that left branches unable to do business for 90 minutes. November 2020: Court documents reveal the names of the Fujitsu employees under investigation for potentially providing misleading information in criminal trials. November 2020: The government allowed the Post Office to ‘run amok’ and destroy lives, says complaint to Parliamentary Ombudsman. November 2020: Campaigning politician demands access to documents that could prove that the Post Office lied. December 2020: Government denies responsibility for the abuse inflicted on subpostmasters by the Post Office over faulty IT system. December 2020: CEO at the centre of the scandal that saw innocent people bankrupted and some sent to prison steps down from NHS role as pressure for her resignation grows. December 2020: History made as subpostmasters wrongly prosecuted in Horizon IT scandal have convictions quashed. December 2020: The appointment of a former Post Office executive, who tried to mislead a judge, in the Football Association of Wales has been questioned by an MP. December 2020: Court of Appeal indicates subpostmasters can pursue appeal route that could do more damage to Post Office’s reputation. January 2021: NHS trust defends its director appointment process following an external review of its recruitment of former Post Office CEO Paula Vennells. January 2021: Lawyers call for changes to digital evidence rule that made it easier for the Post Office to ‘bamboozle courts’ and make subpostmasters pay a heavy price for its IT failings. January 2021: The Criminal Cases Review Commission (CCRC) has referred four more subpostmasters’ criminal convictions to appeal, as part of the biggest miscarriage of justice in modern UK history. February 2021: A former senior developer who worked for Fujitsu on the Post Office IT system that led to subpostmasters being falsely accused of fraud, has claimed bosses knew of fundamental flaws before going live. February 2021: Subpostmasters call for Boris Johnson to pause and reshape the government’s Horizon inquiry. February 2021: Vote of no confidence in Football Association of Wales boss triggered by recruitment of former Post Office executive who tried to mislead a judge in IT trial. March 2021: Government agrees to change private prosecution rules that were abused by the Post Office in its pursuit of subpostmasters wrongly accused of financial crimes. March 2021: Subpostmaster victims who have spent millions bringing the Post Office IT scandal to light have received no reply to their concerns from Boris Johnson. March 2021: MP condemns department’s ‘bizarre’ rejection of freedom of information request linked to Post Office IT scandal. March 2021: Football Association Wales boss steps down after losing confidence motion triggered by appointment of an executive involved in the Post Office IT scandal. March 2021: The Scottish Criminal Cases Review Commission (SCCRC) is reviewing five cases of potential miscarriage of justice in relation to subpostmaster prosecutions. March 2021: Subpostmasters heading to Court of Appeal to clear their names in what is potentially the biggest miscarriage of justice in English legal history. March 2021: The Post Office does not have enough money to pay compensation to the subpostmasters it wrongfully prosecuted. March 2021: Angela van den Bogerd has left her role at the Football Association of Wales, following criticism of her part in Post Office IT scandal. March 2021: Court of Appeal hearing reveals Post Office instructed employees to destroy documents that undermined an insistence that its Horizon computer system was robust. March 2021: The Post Office was warned that a former Fujitsu employee had misled courts when giving evidence on its behalf. March 2021: Boris Johnson agrees with MP that those responsible for the Post Office Horizon scandal should be brought to book. March 2021: Former Post Office chief was paid over £400,000 when she left despite the organisation being involved in what would become the biggest miscarriage of justice in UK history. April 2021: The UK government faces a potential judicial review over its Post Office Horizon IT scandal inquiry, after subpostmasters formally wrote to the government seeking one. April 2021: The government is listening to calls for changes in how digital evidence is considered in court, as Post Office IT scandal spells out current rule’s inadequacy. April 2021: The Post Office's controversial contract with Fujitsu has been extended another year to help the organisation manage its exit. April 2021: The Post Office is to move work done by Fujitsu in-house when its outsourcing contract ends, and is already recruiting IT experts. April 2021: The Post Office has revealed the end to its controversial Horizon IT system which, through its errors and the Post Office's denial of them, caused huge suffering. April 2021: The UK government is the only block to fair compensation for subpostmasters who were wrongly punished for accounting shortfalls. April 2021: The Court of Appeal has overturned the criminal convictions of 39 subpostmasters who were blamed and punished for accounting shortfalls caused by computer errors. April 2021: Former Post Office CEO Paula Vennells has left roles in the church, Morrisons and Dunelm after postmasters’ convictions were overturned in the Court of Appeal. April 2021: The biggest miscarriage of justice in UK history is set to get bigger as more subpostmasters take their cases to the Court of Appeal. May 2021: Post Office IT scandal CEO has no excuse for her inaction in preventing the biggest miscarriage of justice in UK history, says Criminal Cases Review Commission chairperson. May 2021: Subpostmasters, MPs and the public call for a full statutory judge-led public inquiry into the Post Office Horizon scandal, following another damning court judgment. May 2021: Government says it wants to ensure a fair pay-out for the 555 subpostmasters who defeated the Post Office in a legal battle. May 2021: The Post Office has contacted hundreds of people it might have wrongly prosecuted for financial crimes. May 2021: The miscarriages of justice involving subpostmasters are the most disturbing element of the Post Office Horizon scandal – but it goes much deeper. May 2021: The supplier at the centre of the Post Office Horizon scandal has so far escaped the ramifications of its role in the biggest miscarriage of justice in UK history. May 2021: Another two former subpostmasters have had their convictions for financial crimes overturned, following a hearing in Southwark Crown Court. May 2021: The government inquiry into the Post Office Horizon scandal is set to be made statutory with the power to compel witnesses and evidence. May 2021: The government confirmed that the inquiry into the Post Office Horizon IT scandal will be given statutory status and wider scope. May 2021: The Justice for Subpostmasters Alliance has agreed to meet the former judge heading up the inquiry into the Post Office scandal that ruined the lives of hundreds of subpostmasters. May 2021: Criminal Cases Review Commission will not allow pressure on its resources to prevent subpostmasters seeking a review of their criminal convictions. May 2021: Professional IT body wants changes to how computer evidence is used in court in the wake of the Post Office case. June 2021: The Post Office Horizon scandal inquiry begins with subpostmaster campaign group waiting for full details before committing its support. June 2021: Whatever the Post Office told government about its decision to sack investigators examining subpostmaster prosecutions for theft could identify if the government was part of a cover-up. June 2021: The Post Office has so far compensated about 400 subpostmasters who suffered losses as a result of computer errors that they were wrongly blamed for. July 2021: Another 10 subpostmasters are set to have their criminal convictions quashed as part of one of the biggest miscarriage of justice in British history. July 2021: The government has made no contact with subpostmasters two months after it said it would work with them to ensure they get speedy and fair compensation. July 2021: The cost of a scheme set up to compensate subpostmasters who were victims of the Horizon IT scandal will exceed £300m. July 2021: The government will pay interim compensation within weeks to subpostmasters who were wrongly convicted of crimes due to computer errors. August 2021: A further four subpostmasters are set to have their wrongful convictions overturned in the latest development in the Post Office Horizon scandal. August 2021: The government has failed to provide fair compensation to the subpostmasters who exposed the full extent of the Horizon scandal to the world. August 2021: Subpostmasters demand more clarity on Horizon public inquiry before committing their support. September 2021: Six more subpostmaster convictions referred for appeal in Post Office IT scandal. September 2021: Government minister holds secret meeting with Post Office Horizon scandal victims. October 2021: The public inquiry into a scandal that saw subpostmasters imprisoned after being blamed for accounting shortfalls will hold its first public hearing early next month. October 2021: A government minister investigating the controversial Horizon IT project in 2000 described the Post Office board of directors as ‘appalling, short-sighted and partisan’. November 2021: The behaviour of Post Office senior management during the Horizon scandal was so egregious that the supplier of the faulty software has escaped a large financial penalty. November 2021: Former Fujitsu staff who gave evidence in subpostmaster trials have been questioned by police for a second time. November 2021: Former subpostmasters convicted of crimes based on data from error-prone Post Office computer system continue to embark on appeals. November 2021: The first hearing in the Post Office Horizon scandal public inquiry hears why victims should be paid compensation immediately. November 2021:The Scottish Criminal Cases Review Commission is investigating eight potential miscarriages of justice linked with faulty Post Office IT system. November 2021: The Post Office will waive professional legal privilege for documents relating to legal advice it received regarding subpostmaster prosecutions. November 2021 A total number of 65 subpostmasters have now had criminal convictions overturned in Post Office Horizon scandal. November 2021 Subpostmasters asked to withdraw support for Post Office scandal inquiry. November 2021: Seven more subpostmasters have been cleared after the Post Office charged them for crimes caused by its faulty Horizon software. November 2021: The Post Office made clear its support for a change in UK law regarding computer evidence that was making prosecution ‘onerous’ – a change which later helped to wrongfully convict subpostmasters. November 2021: The chair of the Post Office scandal public inquiry has confirmed the compensation of a group of subpostmasters will be revisited. December 2021: Government must go further after agreeing to pay compensation for wrongly convicted subpostmasters. December 2021: Pressure on government to pay fair compensation to subpostmasters left out of current schemes. January 2022: Almost 100 MPs have backed a call for the government to reverse its decision to exclude 555 subpostmasters from fair compensation. January 2022: A parliamentary select committee was told that the Post Office is unable to access information to accurately calculate compensation for some Horizon scandal victims. January 2022: The Post Office received subsidies worth over £1bn last year, including a £685m payment just last month, in a scheme labelled Post Office Historical Matters Compensation. January 2022: Government widens subpostmaster miscarriage of justice compensation scheme in Horizon scandal. January 2022: Government officials are open to finding a way to properly compensate victims of the Horizon scandal without setting a dangerous legal precedent. January 2022: The subpostmaster campaign group responsible for exposing the Post Office Horizon scandal is to meet with the government to discuss fair compensation for their suffering. January 2022: Fujitsu cannot hide away as taxpayers pick up the bill for the Post Office scandal triggered by its IT system, say peers. February 2022: Victims of the Post Office Horizon scandal are being denied the millions of pounds they are owed as the government delays compensation resolution. February 2022: Victims of the Post Office Horizon scandal are due to tell their devastating stories to the statutory inquiry. February 2022: MPs are demanding urgent action by the government to provide full compensation to a group of 555 Post Office Horizon scandal victims who have so far been left out. February 2022: Victims of the Post Office Horizon scandal have been suffering in silence for many years, but the current public inquiry is giving them a voice, and people are listening. February 2022: Horizon inquiry questioning raises hopes of fair compensation for victims so far left out. February 2022: Government set to backtrack on untenable position on subpostmaster compensation. March 2022: The Post Office and Fujitsu failed to alert subpostmasters to a software error that caused them to be wrongly blamed for accounting shortfalls. March 2022: Horizon inquiry hearing sheds light on subpostmaster federation’s role in hushing up IT problems. March 2022: 555 subpostmasters to get fair compensation after government U-turn on its stance on High Court settlement. March 2022: Compensation goal finally in sight for 555 Post Office scandal victims, after 13 year campaign. April 2022: Fujitsu bags £430m government contracts despite rising cost of Post Office Horizon scandal. April 2022: The Scottish Criminal Cases Review Commission expects more subpostmasters with potential wrongful convictions to come forward. April 2022: Former subpostmasters who were wrongfully convicted and punished for crimes have not yet received full compensation over a year after their convictions were overturned. April 2022: A former Fujitsu worker has been questioned under caution for the third time as police investigate potential perjury in trials of subpostmasters wrongfully convicted of financial crimes. May 2022: Paula Vennells could be stripped of her CBE as the Honours Forfeiture Committee commits to reconsider its award in the light of the Post Office Horizon scandal. May 2022: Lawyer negotiating compensation for victims of Post Office scandal says the two sides are ‘poles apart’ on valuations. May 2022: Inquiry into Post Office scandal moves to Scotland, with differences in English and Scottish law raising further serious questions about subpostmaster prosecutions. May 2022: The chair of the Post Office Horizon scandal inquiry has brought forward hearings about compensation as victims warn that at this rate “people will die” before they get anything. May 2022: The Criminal Cases Review Commission is to contact 88 more potentially wrongfully convicted Post Office workers. May 2022: The Post Office Horizon IT system at the centre of a national scandal will be replaced by 2025, with a supplier expected to be named in August. May 2022: Victims of the Post Office Horizon scandal in Scotland raise further questions about Post Office and government conduct. May 2022: Government accused of ‘passing the buck’ and ‘not knowing what it is talking about’ after stating it has no plans to review court rules on computer evidence. May 2022: Computer Weekly spoke to the barristers at Henderson Chambers that fought the Post Office in the High Court to expose the widest miscarriage of justice in UK history. June 2022: Two more Post Office Horizon scandal victims have had their wrongful convictions overturned. June 2022: The 555 subpostmasters who exposed the depth of the Post Office Horizon scandal could finally be fairly compensated. June 2022: Forensic accounting firm that ‘knows where the bodies are buried’ will be released from confidentiality obligations by the Post Office to give evidence to public inquiry. June 2022: Lawyers negotiating the compensation valuations for former subpostmasters who suffered wrongful convictions have brought in independent judicial scrutiny to break an impasse. June 2022: Subpostmaster campaign group is a step closer to achieving what it was originally set up to do as government launches compensation scheme for its members who did not receive fair payouts. July 2022: More former subpostmasters have their wrongful convictions for theft and fraud overturned in the Court of Appeal. July 2022: When the Post Office’s lie about the Horizon system failed to silence subpostmaster critics, it took more extreme measures, say victims of the scandal. September 2022: The Met Police have interviewed a former subpostmaster as part of an investigation into potential perjury by former Fujitsu staff. September 2022: Chair of statutory public inquiry into the Post Office Horizon scandal has aired his disappointment over the slow progress in making interim payments to victims. October 2022: The public inquiry into the Post Office scandal has begun phase two with a request for adjournment amid allegations that the Post Office is failing to disclose relevant documents. October 2022: Victims demand that the perpetrators of the Post Office Horizon IT scandal face the public inquiry. October 2022: Fujitsu’s part in causing the extreme suffering of subpostmasters will be made clear as the IT supplier begins giving evidence at a statutory inquiry. October 2022: A dereliction of duty saw subpostmaster federation ignore its members when IT problems hit and allowed the Post Office destroy their lives. October 2022: Politicians are keeping up the pressure to block government contracts being awarded to Fujitsu because of its role in the Post Office Horizon scandal. October 2022: Problems reported with the Post Office’s Horizon IT system before its roll-out should have been regarded as a “show-stopper”. October 2022: Horizon system code writers lacked basic programming skills, according to the task force set up to investigate reported problems with the controversial software. October 2022: Trials of the Horizon computer system in Post Office branches in 1999 led to a warning from subpostmasters that software problems meant “a tragedy was not far away”. November 2022: ‘Hardball’ negotiations between the government, the Post Office and ICL meant subpostmasters were ignored and thrown into a tragedy that could have been averted. November 2022: Post Office investigators were so convinced that subpostmasters were cooking the books that they failed to investigate alleged IT problems, a public inquiry has been told. November 2022: SCCRC has referred six cases of potential wrongful convictions of subpostmasters to the High Court of Justiciary. November 2022: A former Fujitsu technology expert who defended the Horizon system’s robustness in court was unhappy after being ‘manoeuvred’ into acting as an expert witness. November 2022: Insider tells public inquiry that the Post Office continued to roll out the controversial Horizon system despite a ‘considerable’ number of errors, because it was too committed. November 2022: Former members of the ICL team developing software for the Post Office Horizon EPOSS system were unqualified and engaged in poor software development practices. November 2022: The Post Office IT scandal inquiry’s appointed expert IT witness was “troubled” by the lack of integrity of data from the Horizon system that was used to send people to prison. November 2022: Telegram from British Embassy in Tokyo to UK government reveals pressure on ministers to sign off controversial contract. November 2022: The National Federation of Subpostmasters (NFSP) deliberately kept stories of Horizon errors quiet because it “did not want to kill the project”. December 2022: The Post Office was ‘keen’ to make subpostmasters cover unexplained accounting shortfall as its business struggled, public inquiry hears. December 2022: The second phase of the Post Office Horizon IT scandal raised more questions over who did what, when and where, with shocking revelations at every turn. December 2022: The Criminal Cases Review Commission wants former subpostmasters to come forward if they think they were prosecuted by the Post Office based on data from the Horizon computer system. January 2023: Alan Bates, who fought for decades to expose the Post Office Horizon IT scandal, says it would be inappropriate to accept an OBE when former Post Office CEO Paula Vennells holds

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Law Society of Scotland on Post Office Scandal Litigation - Litigation Finance Journal
by Gunnar Larson 06 Dec '24

06 Dec '24

Check out my recent article: https://litigationfinancejournal.com/law-society-of-scotland-on-post-office… The Law Society of Scotland shares a new debrief of the Post Office scandal. The story goes: When the Horizon computer system found over 736 sub-postmasters were allegedly grifting from the United Kingdom’s postal budgets, they were summarily punished. However, Horizon’s back office capabilities were later found to contain bugs and other system defects that allegedly found workers at fault by mistake. Enter litigation funding, a utility that many of the former post office workers found necessary to clear their name. According to the Law Society of Scotland, February of 2022 saw the initiation of a public debate and investigation on the totality of the Post Office scandal’s effects. The whole affair is being dubbed an extreme case of United Kingdom justice malfeasance. Furthermore, the Law Society explains that about 10% of the 736 criminal records have been overturned. A class of 555 claimants have won restitution, totaling £20,000 each. Click here to read more about the Law Society of Scotland’s take on the Post Office Scandal.

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Mayor Adams' Calendar Request
by Gunnar Larson 30 Nov '24

30 Nov '24

Dear Madam or Sir: xNY.io - Bank.org kindly seeks access to New York City Mayor Eric Adams' May 7,8,9 2024 schedule. Additionally, xNY.io - Bank.org seeks access to records if the Executive Chamber is aware of any international travel of Mayor Adams during this time period. Best regards, Gunnar -- Gunnar Larson xNY.io - Bank.org 917-580-8053

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Bank.org Baby Bond Fund
by Gunnar Larson 29 Nov '24

29 Nov '24

While people are trying to corner the Mayor of New York City, we all need to keep in mind the books at the United Nations are cooked. xNY.io - Bank.org has went to NY-DFS' Superintendent on the 'cooked books' at the UN, but she must be too busy to care. UNICEF announced a CryptoFund sometime back. The Bank.org Baby Bond Fund was created as a common sense solution to all of this. ----- Bank.org Baby Bond Fund: https://docs.google.com/document/d/1RcPD2k0TIv-Ybc1e-Yg56UhN1o0HLx7Knynu7Nr… After surveying the global bond market, ironically there is no notable "world's best baby bond." Bank.org aims to meet the obvious market need for quality innovation in the baby bond economy, by launching the Bank.org Baby Bond Fund. UNICEF launched a CryptoFund as a new financial vehicle allowing UNICEF to receive, hold, and disburse cryptocurrency - a first for the United Nations. From our unique experiences in cryptocurrencies and emerging markets, our vision for the Bank.org Baby Bond Fund is to engage logic, need and opportunity to spark quality innovation in baby bond development. Below are key highlights supporting our vision behind the Bank.org Baby Bond Fund: Today, with over 40% of the world's population under 35, there is no global "kitchen table" baby bond champion. Bank.org is tactically attractive to support and justify leading developed and emerging markets as a global baby bond champion. Geopolitical influences support buy side emerging market dynamics at the heart of Bank.org Baby Bond Fund development. The Bank.org Baby Bond Fund vision is to capture an optimistic growth story, fostering a positive bond value lifecycle trade. Global population sampling summarizes the need for a mature approach to quality baby bond product development, according to UNICEF. Answering a call from UNICEF and UNDP, the Bank.org Baby Bond Fund aims to become the standard child bond financial instrument of value. Operating with the benefit of fundamentals and hindsight, it is highly likely the Bank.org Baby Bond Fund will positively impact the lives of children globally, potentially greater than cryptocurrency innovation.

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Memo #3 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 29 Nov '24

29 Nov '24

https://docs.google.com/document/d/1QFZ2sFXx1cSYRcZTOGdPelZbVtuhpHuCKk011Uz… February 21, 2022 BY ELECTRONIC MAIL Mr. John Marzulli United States Department of Justice Eastern District of New York 271 Cadman Plaza East Brooklyn New York, 11201 John.Marzulli(a)usdoj.gov Re: Memo #3 - Goldman Sachs Deferred Prosecution Agreement <https://www.justice.gov/criminal-fraud/file/1329926/download> Dear Mr. Marzulli: The Department of Justice has yet to respond to Memo #1 <https://docs.google.com/document/d/1OsxfjN3TUepftKklopkQDSMwFWstWozuku4IPPu…> and Memo #2 <https://docs.google.com/document/d/10BYgCtCf9F7A4YnhN792cTBU6P-pfdaOg0UTRbt…> with our recent inquiry to the 1Malaysia Development Berhad Deferred Agreement. Goldman Sachs' Deferred Prosecution Agreement <https://www.justice.gov/usao-edny/pr/goldman-sachs-resolves-foreign-bribery…> with the United States of America is in potential breach, with ethical enforcement being concerned. Memo #3 <https://docs.google.com/document/d/1QFZ2sFXx1cSYRcZTOGdPelZbVtuhpHuCKk011Uz…> aims to associate malfeasance with Marketplace Manipulation. The 2021 Apple Card Investigation What would Steve Jobs say? xNY.io - Bank.org feels this is one part of a broader discussion we must have about equal credit access. Corruption occurs when the private search for economic advantage and personal advancement clashes with laws and norms that condemn such behavior. Further complicating the picture, some illegal corrupt transactions drain public resources away from education, health care, and effective infrastructure—the kinds of investments that can improve economic performance and raise living standards for all. The cost of corruption is greater than the sum of lost money. Distortions in spending priorities undermine the ability of the state to promote sustainable and inclusive growth. This is possible in a framework already characterized by weak law that creates both a certain alteration of the rules of the market and perverse dynamics distorting the economy and inhibiting free competition. - Goldman Sachs has a history of poor ethical stewardship, at the global level. Similarly, New York's former Governor Andrew Cuomo and NY-DFS Superintendent Linda Lacewell are now world famous for women's rights. - On March 23, 2021, Lacewell published NY-DFS' Findings on Apple Card and its Underwriter Goldman Sachs Bank. Former Superintendent of NY-DFS, Ms. Linda Lacewell's stone faced propaganda assured that Apple Card did not discriminate against women, while under Goldman Sachs management. - The red flags started to appear when an authorized user drew attention to the following: A person who relies on a spouse's access to credit, and only accesses those accounts as an authorized user, may incorrectly believe they have the same credit profile as the spouse. - xNY.io - Bank.org recently collated 61 highlights <https://drive.google.com/file/d/1xH16OKyuXzB-MVqIznMWDE9w8RRdmZCw/view> to the Report on Apple Card Investigation from March 2021. Mr. Marzulli, the Apple Card investigation was to assess women's access to equitable finance. March 2021 also saw New York State Attorney General Letitia James' formal green light to launch an independent investigation <https://nypost.com/2021/02/27/second-woman-accuses-gov-andrew-cuomo-of-sexu…> into sexual harassment allegations Lodged against Gov. Andrew Cuomo. Lacewell's legacy is authoring reports disparaging women. The integrity of the Apple Card investigation must be rationally considered as flawed. Likewise, Goldman Sach has a history of unethical posturing on matters specific to women and girls (via global regulatory arbitrage structures). 1. Mr. Marzulli, Peter Oppenheimer is Apple's former CFO and in 2014 joined Goldman Sachs' board of directors and serves on key committees such as Audit (Chair), Governance, Risk. 2. There is no logical reason for Apple to trust the Apple Card Report and Apple’s former CFO is well aware of the legacy of Goldman's unethical antics and regulatory arbitrage frameworks that take advantage of the world's most vulnerable populations. 3. Mr Marzulli, at the very least, it is now clear that New York’s former Superintendent is famous for publishing reports that disperage women. Given the obvious logical factors at play, it may appear that elements of the Deferred Agreement may have been ignored in the facts, figures and assessment of impact on women and girls concerning the Apple Card Report under the former Superintendent. We seek DOJ guidance on the Apple Card Report as a marketplace manipulation instrument. Next, Memo #3, will explore our organization’s management analysis of marketplace manipulation partnering with MoneyGram and Ripple. United States and Africa Marketplace Manipulation Instruments xNY.io - Bank.org feels this is one part of a broader discussion of marketplace manipulation architectures operating from lower Manhattan that potentially function as a cross-border regulatory arbitrage banking operation in the United States and Africa. - MoneyGram, which has about 227,000 global money transfer agent locations in 191 countries and territories, was recapitalized in 2008 (same year as Bitcoin's whitepaper <https://www.ussc.gov/sites/default/files/pdf/training/annual-national-train…> ). - Walmart is the only MoneyGram agent, for both the Global Funds Transfer and Financial Paper Products segments, that accounts for more than 10% of revenue. In 2020, Walmart accounted for 13% of total MoneyGram’s revenue and 16% in 2019 and 2018. - Goldman Sachs acquired an equity interest of 63 percent in MoneyGram for about $710 million. Per the 2008 agreement, MoneyGram also received $500 million in debt financing from Goldman Sachs (Cordeiro 2011) <https://sciwheel.com/work/citation?ids=10952410&pre=&suf=&sa=0>. - Goldman Sachs as a MoneyGram investor has a Participation Agreement with Walmart Inc. under which the Investor is obligated to pay Walmart certain percentages of any accumulated cash payments received by the Investor in excess of the Investor's original investment in the Company (MONEYGRAM INTERNATIONAL INC 2021) <https://sciwheel.com/work/citation?ids=10952491&pre=&suf=&sa=0>. - In 2016, Ripple received New York’s First NY-DFS BitLicense for an Institutional Use Case of Digital Assets (Larsen 2016) <https://sciwheel.com/work/citation?ids=10953308&pre=&suf=&sa=0>. Shortly after being NY-DFS accredited, Ripple announced it was teaming up with MoneyGram to test payments using Ripple’s xRP virtual currency. During this time, Ripple was making headlines as the xRP digital currency had surged — and fallen — dramatically (Browne 2018) <https://sciwheel.com/work/citation?ids=10953324&pre=&suf=&sa=0>. Soon after, Ripple announced a $50 million investment in MoneyGram snagging a 10% equity stake in the firm. Brad Garlinghouse, Ripple’s CEO, added that his firm would support MoneyGram’s “further expansion” into the European and Australian payment corridors (De 2019) <https://sciwheel.com/work/citation?ids=10953333&pre=&suf=&sa=0>. Connecting the dots, MoneyGram is now one of the most expensive transfer providers (Tierney 2019) <https://sciwheel.com/work/citation?ids=10953437&pre=&suf=&sa=0> on planet Earth. Customers incur fees for postal mail, telephone calls, electronic mail, and other computerized messaging services. - Computer crimes as a threat is no less a threat because it is contingent, because the speaker does not intend or is unable to carry it out when the threat was not directly communicated to the MoneyGram customer as a target, or because the language used might be considered cryptic or ambiguously not part of the current New York BitLicense mandate. - Ripple simply made MoneyGram’s business more efficient, thus accruing more profits for Goldman Sachs directed out of Manhattan. - From 2019 - 2020, MoneyGram received more than $40 million in market development fees from Ripple Labs in return for providing liquidity to its On-Demand Liquidity (ODL) network. It can be calculated that 10%-15% of the proceeds came from Walmart customers, who are some of the most disenfranchised Americans financially. Over the last five years, through conscious organizational HR management, Goldman Sachs created layer upon layer of New York BitLicense-related disguises and cross-border systems under potential conspiracy and plausible deniability to computer crimes and marketplace manipulation. Goldman Sachs' various direct and/or indirect BitLicensee connections profit daily from virtual currency market manipulation computer crimes with cross-border reach, operating as a large syndicate group from lower Manhattan. New York banks have a long and profitable history of exploiting regulatory arbitrage. Similar to the MoneyGram instance, some evidence shows that Goldman Sachs also seems to have entered Africa. - What is astonishing is that Ripple is powering some of www.JUMO.World’s <http://www.jumo.world> bank customers (Ripple 2020) <https://sciwheel.com/work/citation?ids=10959408&pre=&suf=&sa=0>, in a troublesome manner similar to MoneyGram. - Given that several enforcement actions and lawsuits in the United States specifically targeted banks’ treatment of minority borrowers (Taibbi 2014 ) <https://sciwheel.com/work/citation?ids=10961062&pre=&suf=&sa=0>, it may not be surprising to learn of www.Jumo.World or “JUMO” (Buchak et al. 2017) <https://sciwheel.com/work/citation?ids=10956108&pre=&suf=&sa=0> - A domain extension, in this case “.World” domain, is the targeted subject area of a computer program. It is a term used in software engineering (Wikipedia 2021) <https://sciwheel.com/work/citation?ids=10968017&pre=&suf=&sa=0>: During the fourth quarter of 2018, JUMO successfully finalized a $65 million capital raise that was led by Goldman Sachs in New York. JUMO is a full technology software stack for building and running financial services, targeted at the world’s most disadvantaged populations. Today, JUMO operates across numerous African markets including Tanzania, Ghana, Zambia, Kenya, Uganda, and most recently in Pakistan, with plans to expand further across the sub-continent. 1. Since its launch in 2014, more than 15 million people have saved or borrowed on the JUMO platform, with over $1.6 billion in funds disbursed to customers. Nearly 70% of JUMO’s customers are micro and small business owners. 2. JUMO targets the unbanked population across several emerging and developing markets. A variety of JUMO’s partnerships with leading banks and mobile network operators creates a marketplace where consumers can access financial services and banks can access a new pool of mobile money customers (Vostok Emerging Finance Ltd 2020) <https://sciwheel.com/work/citation?ids=10955874&pre=&suf=&sa=0>. 3. Given the regulatory environment in Africa, it could be suggested that from New York, Goldman Sachs and Ripple’s organizational HR management structures once again aim to profit from some of the most vulnerable of the human population. Memo #1 <https://docs.google.com/document/d/1OsxfjN3TUepftKklopkQDSMwFWstWozuku4IPPu…>, Memo #2 <https://docs.google.com/document/d/10BYgCtCf9F7A4YnhN792cTBU6P-pfdaOg0UTRbt…> and Memo #3 <https://docs.google.com/document/d/1QFZ2sFXx1cSYRcZTOGdPelZbVtuhpHuCKk011Uz…> profile instances that correspond with potential breaches to the Deferred Agreement that are impacting our global enterprise. Finally, we have made 28 highlights to Deferred Agreement <https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=…> as a reference resource tool. We are looking forward to learning more about the DOJ’s approach to assessing any potential breaches to the Deferred Agreement’s mandates. Respectfully yours with anticipation, Gunnar Larson - xNY.io <http://www.xny.io> | Bank.org <http://bank.org>MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-646-454-9107

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xNY.io - Bank.org | DOJ Memo #2 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 29 Nov '24

29 Nov '24

https://docs.google.com/document/d/10BYgCtCf9F7A4YnhN792cTBU6P-pfdaOg0UTRbt… February 1, 2022 BY ELECTRONIC MAIL Mr. John Marzulli United States Department of Justice Eastern District of New York 271 Cadman Plaza East Brooklyn New York, 11201 John.Marzulli(a)usdoj.gov Re: Memo #2 - Goldman Sachs Deferred Prosecution Agreement <https://www.justice.gov/criminal-fraud/file/1329926/download> Dear Mr. Marzulli: The Department of Justice has yet to respond to Memo #1 with our recent inquiry <https://docs.google.com/document/d/1OsxfjN3TUepftKklopkQDSMwFWstWozuku4IPPu…> to the 1Malaysia Development Berhad Deferred Agreement. Goldman Sachs' Deferred Prosecution Agreement <https://www.justice.gov/usao-edny/pr/goldman-sachs-resolves-foreign-bribery…> with the United States of America is in potential breach, with ethical enforcement being concerned. Memo #2 aims to associate the malfeasance in Malaysia with the Middle East. The Bank of London vs. The Bank of London and the Middle East - November 30, 2021 two New York based firms lead investment in The Bank of London based in the United Kingdom. - July 1, 2007 The Bank of London and the Middle East opened in the United Kingdom. - The Bank of London and the Middle East confirms they have no association with The Bank of London (correspondence referenced here <https://drive.google.com/file/d/1ZLYO6qxOX5TIn0kPd69SQbvG-mn0I5R_/view?usp=…> ). The Bank of London seemingly has been funded from New York to irritate the Middle East. Recently, we made 91 highlights of research <https://drive.google.com/file/d/1O2piNMJ3CI0wbfaFW33to3KhgOgZ8-dl/view?usp=…> associated with The Bank of London and the Middle East's recent sale to a firm in Kuwait. Harvey Schwartz is the Chairperson at The Bank of London, after spending over 20 years at Goldman Sachs Group, where he oversaw sales and trading, finance, technology, and operations. He completed his tenure as the firm’s President and Co-Chief Operating Officer. He joined Goldman Sachs in 1997 and subsequently held numerous senior leadership positions including Chief Financial Officer, Global Co-Head of the Securities Division, amongst other positions. He additionally served as a member of the firm’s Management Committee and co-headed its Risk Committee, Steering Committee on Regulatory Reform and Finance Committee. Mr. Schwartz established the firm’s Investment Policy Committee on which he also served as a member. It would appear that Mr. Schwartz has no friendly diplomatic agenda in London banking, potentially looking to profit off of The Bank of London and the Middle East. Furthermore, Goldman Sachs seemingly has a part in the scheme from New York. Bank of London and the Middle East is listed on the NASDAQ, Dubai. - Mr. Marzulli, during a recent telephone discussion together it was your general assessment that the Deferred Agreement in question was self policing. Can you kindly advise at your earliest convenience what (if any) DOJ systems, processes and control mechanisms are in place to monitor the purity of the Deferred Agreement? - Furthermore, if the Deferred Agreement is self-policing, can the DOJ kindly share any and all supporting material information that would prevent the agreement from being violated without the DOJ's general oversight? - Finally, we have made 28 highlights to Deferred Agreement <https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=…> as a reference resource tool. Memo #1 and Memo #2 both outline instances that correspond with the associated highlight references. We are concerned that potential breaches to the Deferred Agreement are impacting our global enterprise. We are looking forward to learning more about the DOJ’s approach to assessing any potential breaches to the Deferred Agreement’s mandates. Respectfully yours with anticipation, Gunnar Larson - xNY.io <http://www.xny.io> | Bank.org <http://bank.org>MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-646-454-9107

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Does Short-selling Discipline Earnings Manipulation? Disciplined Short Sellers Handbook (W/58 Highlights Attached)
by Gunnar Larson 26 Nov '24

26 Nov '24

Does Short-selling Discipline Earnings Manipulation? xNY.io - Bank.org recently collated international graduate scholar working notes coining the "Crypto Computer Crimes Manual <https://drive.google.com/file/d/11tbgHgDg8qagomO-NBffvIFpxXKmBC3g/view?usp=…>" as per best disclosure practices to illustrate various potential scenarios when market conditions are met and a Board of Directors potentially exploits blockchain technological software innovation with forecastable reckless consequences. The Disciplined Short Sellers Handbook serves as a Manual supplement ... Detailing the hypothesis that short-selling has a disciplining role vis-à-vis the managers forcing them to reduce earning manipulation. Across 33 countries, the Handbook documents a significantly negative relationship between lending supply and activism in the short sell market and earnings manipulation. Collectively, findings suggest that short selling provides an external governance mechanism to discipline managerial incentives. xNY.io highlights that the authors of the faculty and research study confirm the main hypotheses and provide evidence of a beneficial effect of the short-selling market on the corporate market. In other words, short-selling generates a disciplining effect similar to the effect produced by the contestability of the firm in the context of M&As. In this regard, short selling contributes not only to the information environment of the market but also to the contracting institutions of the real economy. Suggesting that in general the disciplining role of short-selling is the strongest for firms with weak internal governance or less transparent information environments. We share 58 highlights to the Handbook <https://drive.google.com/file/d/1aLcmN5c2PJiqHYR5dy8C8qMNVyclw8lu/view?usp=…> as a disclosure technique, foreshadowing xNY.io's disciplined approach to trading in the near term (subject to regulatory scrutiny).

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Video: Put the puck in the back of the net, Gunnar
by Gunnar Larson 25 Nov '24

25 Nov '24

Video: Put the puck in the back of the net, Gunnar https://www.instagram.com/p/C3VWQBasHan/?igsh=MXg0aTlseHN4b2UxNQ==

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492 Highlights to UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants. ____________________
by Gunnar Larson 24 Nov '24

24 Nov '24

INTRODUCTION March 24, 2022 158 Highlights: https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=… 1. In the run-up to the 2016 Presidential Election, Hillary Clinton and her cohorts orchestrated an unthinkable plot – one that shocks the conscience and is an affront to this nation’s democracy. Acting in concert, the Defendants maliciously conspired to weave a false narrative that their Republican opponent, Donald J. Trump, was colluding with a hostile foreign sovereignty. The actions taken in furtherance of their scheme—falsifying evidence, deceiving law enforcement, and exploiting access to highly-sensitive data sources - are so outrageous, subversive and incendiary that even the events of Watergate pale in comparison. 2. Under the guise of ‘opposition research,’ ‘data analytics,’ and other political stratagems, the Defendants nefariously sought to sway the public’s trust. They worked together with a single, self-serving purpose: to vilify Donald J. Trump. Indeed, their far-reaching conspiracy was designed to cripple Trump’s bid for presidency by fabricating a scandal that would be used to trigger an unfounded federal investigation and ignite a media frenzy. 3. The scheme was conceived, coordinated and carried out by top-level officials at the Clinton Campaign and the DNC—including ‘the candidate’ herself—who attempted to shield her involvement behind a wall of third parties.1 To start, the Clinton Campaign and the DNC enlisted the assistance of their shared counsel, Perkins Coie, a law firm with deep Democrat ties, in the hopes of obscuring their actions under the veil of attorney-client privilege. Perkins Coie was tasked with spearheading the scheme to find—or fabricate—proof of a sinister link between Donald J. Trump and Russia. To do so, Perkins Coie launched parallel operations: on one front, Perkins Coie partner Marc Elias led an effort to produce spurious ‘opposition research’ claiming to reveal illicit ties between the Trump Campaign and Russian operatives; on a separate front, Perkins Coie partner Michael Sussmann headed a campaign to develop misleading evidence of a bogus ‘back channel’ connection between e-mail servers at Trump Tower and a Russian-owned bank. 4. Marc Elias, in his mission to obtain derogatory anti-Trump ‘opposition research,’ commissioned Fusion GPS, an investigative firm, and its co-founders, Peter Fritsch and Glenn Simpson, and directed them to dredge up evidence—actual or otherwise—of collusion between Trump and Russia. Fritsch and Simpson, in turn, enlisted the assistance of Orbis Ltd. and its owner, Christopher Steele, to produce a series of reports purporting to contain proof of the supposed collusion. Of course, the now fully debunked collection of reports, known as the “Steele Dossier,” was riddled with misstatements, misrepresentations and, most of all, flat out lies. In truth, the Steele Dossier was largely based upon information provided to Steele by his primary sub-source, Igor Danchenko, who was subsequently indicted for falsifying his claims. Even more damning, Danchenko had close ties to senior Clinton Campaign official, Charles Halliday Dolan, Jr., who knowingly provided false information to Danchenko, who relayed it to Steele, who reported it in the Steele Dossier and eagerly fed the deceptions to both the media and the FBI. This duplicitous arrangement existed for a singular self-serving purpose – to discredit Donald J. Trump and his campaign. 5. At the same time, Michael Sussmann, in his hunt for damaging intel against the Trump Campaign, turned to Neustar, Inc., an information technology company, and one of its top executives, Rodney Joffe, a fervent anti-Trumper who had recently been promised a high-ranking position with the Clinton Administration, to exploit their access to non-public data in search of a secret “back channel” connection between Trump Tower and Alfa Bank. When it was discovered that no such channel existed, the Defendants resorted to truly subversive measures – hacking servers at Trump Tower, Trump’s private apartment, and, most alarmingly, the White House. This ill-gotten data was then manipulated to create a misleading “inference” and submitted to law enforcement in an effort to falsely implicate Donald J. Trump and his campaign.2 All of these acts were carried out in coordination with the Clinton Campaign and the DNC, at the behest of certain Democratic “VIPs.”3 6. While their multi-pronged attack was underway, the Defendants seized on the opportunity to publicly malign Donald J. Trump by instigating a full-blown media frenzy. Indeed, the Clinton Campaign and DNC—admittedly on a “mission” to “raise the alarm” about their contrived Trump-Russia link4—repeatedly fed disinformation to the media and shamelessly promoted their false narratives. All the while, Hillary Clinton, Jake Sullivan, Debbie Wasserman Schultz, and others did their best to proliferate the spread of those dubious and false claims through press releases, social media, and other public statements. 7. The fallout from the Defendants’ actions was not limited to the public denigration of Trump and his campaign. The Federal Bureau of Investigation (FBI)—relying on the Defendants’ fraudulent evidence—commenced a large-scale investigation and expended precious time, resources and taxpayer dollars looking into the spurious allegation that the Trump Campaign had colluded with the Russian Government to interfere in the 2016 presidential election. The effects of this unfounded investigation were prolonged and exacerbated by the presence of a small faction of Clinton loyalists who were well-positioned within the Department of Justice and the FBI – James Comey, Andrew McCabe, Peter Strzok, Lisa Page, Kevin Clinesmith, and Bruce Ohr. These government officials were willing to abuse their positions of public trust to advance the baseless probe to new levels, including obtaining an extrajudicial FISA warrant and instigating the commencement of an oversight investigation headed by Special Counsel Robert Mueller. As a result, Donald J. Trump and his campaign were forced to expend tens of millions of dollars in legal fees to defend against these contrived and unwarranted proceedings. Justice would ultimately prevail – following a two-year investigation, Special Counsel Mueller went on to exonerate Donald J. Trump and his campaign with his finding that there was no evidence of collusion with Russia. 8. The full extent of the Defendants’ wrongdoing has been steadily and gradually exposed by Special Counsel John Durham, who has been heading a DOJ investigation into the origins of the Trump-Russia conspiracy. To date, he has already issued indictments to Sussmann and Danchenko, among others, for proffering false statements to law enforcement officials. As outlined below, these ‘speaking’ indictments not only implicate many of the Defendants named herein but also provide a great deal of insight into the inner-workings of the Defendants’ conspiratorial enterprise. Based on recent developments and the overall direction of Durham’s investigation, it seems all but certain that additional indictments are forthcoming. 9. In short, the Defendants, blinded by political ambition, orchestrated a malicious conspiracy to disseminate patently false and injurious information about Donald J. Trump and his campaign, all in the hopes of destroying his life, his political career and rigging the 2016 Presidential Election in favor of Hillary Clinton. When their gambit failed, and Donald J. Trump was elected, the Defendants’ efforts continued unabated, merely shifting their focus to undermining his presidential administration. Worse still, the Defendants continue to spread their vicious lies to this day as they unabashedly publicize their thoroughly debunked falsehoods in an effort to ensure that he will never be elected again. The deception, malice, and treachery perpetrated by the Defendants has caused significant harm to the American people, and to the Plaintiff, Donald J. Trump, and they must be held accountable for their heinous acts. ____________________ BACKGROUND September 8, 2022 190 Highlights: https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=… Plaintiff initiated this lawsuit on March 24, 2022, alleging that “the Defendants, blinded by political ambition, orchestrated a malicious conspiracy to disseminate patently false and injurious information about Donald J. Trump and his campaign, all in the hopes of destroying his life, his political career and rigging the 2016 Presidential Election in favor of Hillary Clinton.” (DE 177, Am. Compl. ¶ 9). On this general premise, Plaintiff brings a claim for violations of the Racketeer Influenced and Corrupt Organizations Act (“RICO”), predicated on the theft of trade secrets, obstruction of justice, and wire fraud (Count I). He additionally brings claims for: injurious falsehood (Count III); malicious prosecution (Count V); violations of the Computer Fraud and Abuse Act (“CFAA”) (Count VII); theft of trade secrets under the Defend Trade Secrets Act of 2016 (“DTSA”) (Count VIII); and violations of the Stored Communications Act (“SCA”) (Count IX). The Amended Complaint also contains counts for various conspiracy charges and theories of agency and vicarious liability. (Counts II, IV, VI, and X–XVI). Plaintiff’s theory of this case, set forth over 527 paragraphs in the first 118 pages of the Amended Complaint, is difficult to summarize in a concise and cohesive manner. It was certainly not presented that way. Nevertheless, I will attempt to distill it here. The short version: Plaintiff alleges that the Defendants “[a]cting in concert . . . maliciously conspired to weave a false narrative that their Republican opponent, Donald J. Trump, was colluding with a hostile foreign sovereignty.” (Am. Compl. ¶ 1). The Defendants effectuated this alleged conspiracy through two core efforts. “[O]n one front, Perkins Coie partner Mark Elias led an effort to produce spurious ‘opposition research’ claiming to reveal illicit ties between the Trump campaign and Russian operatives.” (Id. ¶ 3). To that end, Defendant Hillary Clinton and her campaign, the Democratic National Committee, and lawyers for the Campaign and the Committee allegedly hired Defendant Fusion GPS to fabricate the Steele Dossier. (Id. ¶ 4). “[O]n a separate front, Perkins Coie partner Michael Sussman headed a campaign to develop misleading evidence of a bogus ‘back channel’ connection between e-mail servers at Trump Tower and a Russian- owned bank.” (Id.). Clinton and her operatives allegedly hired Defendant Rodney Joffe to exploit his access to Domain Name Systems (“DNS”) data, via Defendant Neustar, to investigate and ultimately manufacture a suspicious pattern of activity between Trump-related servers and a Russian bank with ties to Vladimir Putin, Alfa Bank. (Id. ¶ 3). As a result of this “fraudulent evidence,” the Federal Bureau of Investigations (“FBI”) commenced “several large-scale investigations,” which were “prolonged and exacerbated by the presence of a small faction of Clinton loyalists who were well-positioned within the Department of Justice”—Defendants James Comey, Andrew McCabe, Peter Strzok, Lisa Page, Kevin Clinesmith, and Bruce Ohr. (Id. ¶ 7). And while this was ongoing, the Defendants allegedly “seized on the opportunity to publicly malign Donald J. Trump by instigating a full-blown media frenzy.” (Id. ¶ 6). As a result of this “multi-pronged attack,” Plaintiff claims to have amassed $24 million in damages.1(Id. ¶ 527). Defendants now move to dismiss the Amended Complaint as “a series of disconnected political disputes that Plaintiff has alchemized into a sweeping conspiracy among the many individuals Plaintiff believes to have aggrieved him.” (DE 226 at 1). They argue that dismissal is warranted because Plaintiff’s claims are both “hopelessly stale”—that is, foreclosed by the applicable statutes of limitations—and because they fail on the merits “in multiple independent respects.” (Id. at 2). As they view it, “[w]hatever the utilities of [the Amended Complaint] as a fundraising tool, a press release, or a list of political grievances, it has no merit as a lawsuit.” (Id.). I agree. In the discussion that follows, I first address the Amended Complaint’s structural deficiencies. I then turn to subject matter jurisdiction and the personal jurisdiction arguments raised by certain Defendants. Finally, I assess the sufficiency of the allegations as to each of the substantive counts. ____________________ BACKGROUND October 31, 2022 25 Highlights: https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=… PlaintifP’s pleadings and theories were obviously and fatally defective from the very inceptionof this action. Plaintiff's initial Complaint spanned 108 pages and S08 paragraphs. DE 1 (March 24, 2022). It named 28 individual defendants, as well as 10 John Does and 10 ABC Corporations. /d. Less than a month after the Complaint was filed, Hillary Clinton moved to dismiss it with prejudice. DE 52 (Apr. 20,2022). Defendant Clinton’s motion identified manyofthe fundamentalfactual deficiencies and legal flaws that would ultimately lead this Court to dismiss the Amended Complaint: namely, (1) that Plaintifs claims were untimely on their face, DE 52 at 1-5; (2) that Plaintiff's own tweets confirmed his knowledge ofhis supposed claimsno later than October 2017, DE 52 at 2-3; (3) that Plaintiffs Complaint was replete with inadequate and conclusory allegations, DE 52 at 6; (4) that Plaintiff failed to allege a RICO enterprise, DE 52 at 7; (5) that Plaintiff failed to allege the predicate act of theft of trade secrets based on DNS information, DE 52 at 8-9; (6) thatPlaintifffailedtoallege the predicate act ofobstructionofjustice in part because he identified no “official proceeding,” DE 52 at 9-10; (7) that Plaintiff failed to allege a patter of racketeering activity, DE 52 at 11-12; (8) that Plaintiff failed to adequately allege RICO standing because his supposed injuries were almostentirely undescribed, DE 52.at 12-14; (9) that Plaintiffs injurious falsehood claim was barred by the First Amendment, DE 52 at 15-17; (10) that Plaintiff failed to allege almost every necessary clementof injurious falsehood under Florida law, DE 52 at 17-18; (11) that Plaintiff failed to allege a malicious prosecution claim as to any official proceeding and, in particular, as to the properly predicated Crossfire Hurricane investigation, DE 52 at 19-20; and (12) that Plaintiff failed to allege a claim for “agency” because it is not an independent cause of action under Florida law. In response, Plaintiff's counsel indicated that they planned to amend the Complaint. DE 66 (Apr. 21, 2022). Defendant Clinton did not oppose counsel's request for an extension of time in whichto amend. See, e.g., DE 102 (Apr. 27,2022). In the intervening period, other Defendants joined Clinton's motion to dismiss and filed their own motions alertingPlaintiff and his counsel to additional fatal defects in the Complaint. See DE 124 (John Podesta), 139 (Peter Fritsch, Fusion GPS, Glenn Simpson); 141 (DNC Services Corporation, Democratic National Committee, Debbie Wasserman Schultz); 143 (Perkins Coie); 144 (Nellie Ohr); 145 (Robby Mook): 146 (Michael Sussmann); 147 (Mare Elias); 149 (HFACC); 157 (Rodney Joffe); 159 (Igor Danchenko); 160 (Neustar, Inc.); 162 & 163 (Charles Halliday Dolan, Jr.); 165 (Jake Sullivan). With respect to each motion, Plaintiff's counsel indicated that they planned to amend in response to the motions, and Defendants did not oppose extensionsof time to allow them to do so. See DE 153 (May 17,2022). PlaintifP’s counsel filed the Amended Complaint approximately two months after receiving Defendant Clinton’s motion to dismiss and with the benefit of Defendants” additional motions in the interim. DE 177 (June 21, 2022). “But despite this briefing, PlaintifPs Amended Complaint failed to cureanyofthe deficiencies.”DE 267 at 63-64 (Sept. 8, 2022) (“0p.”). “Instead, Plaintiff added eighty new pages of largely irrelevant allegations that did nothing to salvage the legal sufficiency of his claims.” Op. at 64. The Amended Complaint is “193 pages in length, with 819 numbered paragraphs,” and “contains 14 counts, names 31 defendants, 10 “John Does” described as fictitious and unknown persons, and 10 *ABC Corporations’ identified as fictitious and unknown entities.” Op. at 4. ____________________ BACKGROUND November 10, 2022 66 Highlights: https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=… The Complaint. In March 2022, Charles Dolan was among 29 defendants initially sued by Mr. Trump. (DE 1). He was identified as a former chairman of the DNC, a senior official in the Clinton Campaign, and a close associate of and advisor to Hillary Clinton. The Complaint alleged that in April 2016, Mr. Dolan participated in discussions about the creation of a “dossier” to smear Mr. Trump and disseminate false accusations to the media (Compl. ¶ 79), and at the direction of Ms. Clinton assisted in preparation of the dossier (Compl. ¶ 81). According to the Complaint, an allegation contained within the dossier that Mr. Trump engaged in salacious sexual activity in a Moscow hotel was derived from Mr. Dolan. (Compl. ¶ 91). Mr. Dolan was sued for RICO conspiracy (Count II), conspiracy to commit injurious falsehood (Count IV), and conspiracy to commit malicious prosecution (Count VI). The Warning Letter. On May 31, 2022, counsel for Mr. Dolan wrote the attorneys for Mr. Trump. They warned: 1. That Mr. Dolan had no role in any conspiracy related to the Steele dossier. 2. That Mr. Dolan was not a source for the allegations of sexual activity. 3. That Mr. Dolan had not been in contact with any defendant other than Igor Danchenko, and that Mr. Dolan’s contacts with Mr. Danchenko involved business interests and help for a conference in Moscow. 4. That Mr. Dolan had never been chairman of the DNC. 5. That Ms. Clinton was on record through a spokesperson as stating she had no recollection of Mr. Dolan. (DE 268-1). The letter requested that Mr. Dolan not be named as a defendant in any forthcoming Amended Complaint. The letter further warned that if he were to be named, or if he was not dropped from the original Complaint, Rule 11 sanctions would be sought. The Amended Complaint. On June 21, 2022, Plaintiff filed an Amended Complaint, as had been expected. It ballooned to 193 pages, 819 paragraphs and 31 defendants. With respect to Mr. Dolan, the allegations remained essentially the same. But in the Amended Complaint, Mr. Dolan was identified somewhat more vaguely as the former chairman of a “national Democratic political organization.” (Am. Compl. ¶ 96). Elsewhere, he was described as a “senior Clinton Campaign Official.” (Am. Compl. ¶ 4). Moreover, and somewhat inexplicably, Mr. Dolan was identified in the Amended Complaint as a citizen and resident of New York, despite a declaration that Mr. Dolan had provided to Plaintiff’s lawyers explaining that Mr. Dolan was a resident of Virginia. (Am. Compl. ¶ 20; DE 268-2). The Sanctions Motion and Memorandum. On July 15, 2022, Mr. Dolan served on Mr. Trump’s lawyers a motion seeking sanctions pursuant to Rule 11. The motion pointed out that the change in Mr. Dolan’s purported title from “former chairman of the DNC” in the original Complaint to “former chairman of a national Democratic political organization,” in the Amended Complaint did not solve the problems identified in the warning letter because Mr. Dolan had never been the chairman of any such organization. The motion further explained that Mr. Dolan’s role in the Clinton Campaign was limited to knocking on doors as a volunteer. The motion also stated that Mr. Dolan had never been a resident of New York, that Mr. Dolan had told Plaintiff’s lawyers so, and that the allegations of the Amended Complaint to that effect demonstrated a lack of diligence over something easily checked. Mr. Dolan’s motion for sanctions went on to place the Trump lawyers on notice of a critical failure in their claims, warning them that the Danchenko Indictment referenced throughout the Amended Complaint not only failed to support their allegations against Mr. Dolan but contradicted them. That warning continues to be unheeded. ____________________ BACKGROUND January 19, 2023 53 Highlights: https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=… Plaintiff initiated this lawsuit on March 24, 2022, alleging that “the Defendants, blinded by political ambition, orchestrated a malicious conspiracy to disseminate patently false and injurious information about Donald J. Trump and his campaign, all in the hope of destroying his life, his political career, and rigging the 2016 Presidential Election in favor of Hillary Clinton.” (DE 1 ¶ 9). The next day, Alina Habba, Mr. Trump’s lead counsel told Fox News’ Sean Hannity: You can’t make this up. You literally cannot make a story like this up . . . and President Trump is just not going to take it anymore. If you are going to make up lies, if you are going to try to take him down, he is going to fight you back. And that is what this is, this is the beginning of all that.1 She then explained on Newsmax: What the real goal [of the suit] is, is democracy, is continuing to make sure that our elections, continuing to make sure our justice system is not obstructed by political enemies. That cannot happen. And that’s exactly what happened. They obstructed justice. They continued the false narrative . . . This grand scheme, that you could not make up, to take down an opponent. That is un-American.2 On April 20, 2022, less than a month after the Complaint was filed, Hillary Clinton moved for dismissal with prejudice. Her motion identified substantial and fundamental factual and legal flaws. Each of the other Defendants followed suit, pointing to specific problems with the claims against them. The problems in the Complaint were obvious from the start. They were identified by the Defendants not once but twice, and Mr. Trump persisted anyway. Despite this briefing and the promise “to cure any deficiencies,” Plaintiff’s counsel filed the Amended Complaint on June 21, 2022. (DE 177). The Amended Complaint failed to cure any of the defects. See DE 267, Order of Dismissal (September 8, 2022). Instead, Plaintiff added eighty new pages of largely irrelevant allegations that did nothing to salvage the legal sufficiency of his claims. (DE 267 at 64). The Amended Complaint is 193 pages in length, with 819 numbered paragraphs, and contains 14 counts, names 31 defendants, 10 John Does described as fictitious and unknown persons, and 10 ABC Corporations identified as fictitious and unknown entities. On July 14, 2022, the United States moved pursuant to the Westfall Act, 28 U.S.C. § 2679 (d)(i), to substitute itself as Defendant for James Comey, Andrew McCabe, Peter Strzok, Lisa Page, and Kevin Clinesmith. (DE 224). On July 21, 2022, I granted the motion to substitute. (DE 234). On September 8, 2022, I dismissed the case with prejudice as to all Defendants except for the United States. 3 I issued a detailed and lengthy Order, which I incorporate by reference here. (DE 267). I found that fatal substantive defects which had been clearly laid out in the first round of briefing, precluded the Plaintiff from proceeding under any of the theories presented. I found that the Amended Complaint was a quintessential shotgun pleading, that its claims were foreclosed by existing precedent, and its factual allegations were undermined and contradicted by the public reports and filings upon which it purported to rely. I reserved jurisdiction to adjudicate issues pertaining to sanctions. Undeterred by my Order and two rounds of briefing by multiple defendants, Ms. Habba continued to advance Plaintiff’s claims. In a September 10, 2022, interview with Sean Hannity, the host asked her “Why isn’t [Hillary Clinton] being held accountable for what she did?” Ms. Habba’s response reiterated misrepresentations on which this lawsuit was based: Because when you have a Clinton judge as we did here, Judge Middlebrooks who I had asked to recuse himself but insisted that he didn’t need to, he was going to be impartial, and then proceeds to write a 65-page scathing order where he basically ignored every factual basis which was backed up by indictments, by investigations, the Mueller report, et cetera, et cetera, et cetera, not to mention Durham, and all the testimony we heard there, we get dismissed. Not only do we get dismissed, he says that this is not the proper place for recourse for Donald Trump. He has no legal ramifications. Where what [sic] is the proper place for him? Because the FBI won’t help when you can do anything, obstruct justice, blatantly lie to the FBI, Sussmann’s out, he gets acquitted, where do you go? That’s the concern for me, where do you get that -- that recourse?4 She also indicated that, while Mr. Trump doubted the suit would succeed, she nevertheless “fought” to pursue it: You know, I have to share with you a story, Sean, that I have not shared with anybody. The recourse that I have at this point is obviously to appeal this to the 11th Circuit as Gregg said. But when I brought this case and we were assigned you know, this judge and we went through the recusal process, we lost five magistrates, including Reinhart [sic] who’s dealing with the boxes as we know. The former president looked at me and he told me, you know what Alina. You’re not going to win. You can’t win, just get rid of it, don’t do the case. And I said, no, we have to fight. It’s not right what happened. And you know, he was right, and it’s a sad day for me personally because I fought him on [it] and I should have listened, but I don’t want to lose hope in our system. I don’t. So, you know I’m deciding whether we’re going to appeal it.5 Defendants now move to recover attorneys’ fees and costs under Fed. R. Civ. P. 11, 28 U.S.C. § 1927, the Defend Trade Secrets Act, and/or this Court’s inherent power. (DE 280 at 1). In Part II, I find that a sanction under this Court’s inherent power is appropriate. I do so by examining Plaintiff’s (and his lawyers’) conduct throughout this litigation. In Part III, I look to Plaintiff’s conduct in other cases. And in Part IV, I determine the reasonableness of Defendants’ attorneys’ fees and costs.

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