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xNY.io - Bank.org | DOJ Memo #2 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 29 Nov '24
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
1
53

Does Short-selling Discipline Earnings Manipulation? Disciplined Short Sellers Handbook (W/58 Highlights Attached)
by Gunnar Larson 26 Nov '24
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).
1
9
Video: Put the puck in the back of the net, Gunnar
https://www.instagram.com/p/C3VWQBasHan/?igsh=MXg0aTlseHN4b2UxNQ==
1
2

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
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.
1
1
THE MONEY GAME MAR. 30, 2022
Crypto’s Most Powerful Regulator Is Here Adrienne Harris, New York’s
financial watchdog, has enormous sway over the industry’s future.

By Kevin T. Dugan, staff writer at Intelligencer, who covers money and
business

Photo: Victor Llorente
Thirteen years after the birth of cryptocurrency, it was supposed to be
time for Washington to rein it in. Instead, the White House punted, and the
Securities and Exchange Commission is still hashing out how it’s going to
oversee the $2 trillion industry. State watchdogs have filled that vacuum,
making Adrienne Harris, the head of the New York State Department of
Financial Services, by default the most powerful crypto regulator in the
country.
While states such as Florida and Wyoming have adopted a laissez-faire
approach to regulation, attracting a sizable chunk of the booming industry,
more money and jobs are still flowing into New York than any other city,
making it the de facto crypto capital of the U.S. “There’s a misconception
that having rigorous regulation turns off innovative companies,” Harris
tells me during an hour-long interview at her office looking out onto the
Statue of Liberty last month. “That hasn’t been our experience here.”
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Harris was tapped as the first Black woman to lead DFS last year. She came
into her position after a turn working in Silicon Valley and representing
Wall Street banks, a résumé that critics have used to paint her as too
close to the industries she is regulating. She’s eager to dispel any
criticism that she’s soft as a regulator, especially when it comes to
crypto. Harris says she’s looking to expand the agency’s remit, hire new
regulators, and possibly watch over lending and asset management in
decentralized finance, a.k.a. DeFi, one of the fastest-growing crypto
industries, which has been prone to very large hacks.
The agency’s power over the industry lies mostly with the BitLicense, a
required if unloved permit for crypto exchanges to operate within state
lines. When it was first introduced in 2014, it was meant to be a model for
the country, but the crypto industry has attacked the license for being too
strict, limiting what people can trade, and requiring expensive
anti-money-laundering operations, which, it should be noted, most
traditional financial institutions are required to maintain. For Harris,
the problem isn’t that it’s too restrictive — it’s that the process of
getting one, which has stretched years for some companies, is too slow. “If
you think about the companies that are BitLicensees, and even the companies
in the queue, having the imprimatur of ‘Have you passed regulatory muster
with a stringent regulatory regime?’ — I think the good actors see that as
a good thing,” she says.
Created in 2011, DFS has been a regulator feared more than any of its
counterparts in other states for the power it has over banks, insurance
companies, and a host of other financial institutions. It brought ambitious
money-laundering cases against banks like BNP Paribas (a settlement that
resulted in several bankers losing their jobs), fined Deutsche Bank for its
relationship with Jeffrey Epstein, and levied a $2.5 million fine on the
National Rifle Association for selling its so-called murder insurance in
the state. “DFS has a lot of teeth, and the sky’s the limit if the agency
is exercised properly,” says state Sen. John Liu of Queens, a member of the
state finance committee. “DFS compelled multinational banks to cough up $15
billion. We were able to build a couple bridges with that money. We still
have much infrastructure in the state of New York that might benefit from
DFS’s vigorous functions.”
But part of DFS’s mandate is to keep the state’s economy healthy, a
balancing act when it means protecting consumers from predatory, but also
lucrative, companies. “For me, it’s an opportunity to bring my lived
experience as a woman of color,” Harris says. So far, she has established
the agency’s first climate division, frozen fees for check-cashing
businesses that target the poor, and looked into non-bank lenders for
evidence of redlining. “It’s important to me that those voices are at the
table and being heard,” she says. “I bring a sort of pragmatism. It’s one
thing to sit in our offices with nice views and make policy, but it’s
another thing, in my mind, to really run the water through the pipes.”
In 2008, Harris joined Sullivan & Cromwell, a law firm so close with
Goldman Sachs that it has long sent its lawyers to work in-house at the
investment bank. It was there that she worked for H. Rodgin “Rodge” Cohen,
then the law firm’s chairman and the so-called trauma surgeon of Wall
Street. Cohen remembers Harris working late into the night writing
near-flawless memorandums so they’d be ready on his desk in the morning.
“She just brought what I’d call a penetrating intelligence to the problems
that were at hand,” Cohen tells me. “Many of the problems we get, you
cannot just look up the answer in a book. It’s a question of judgment and
trying to apply rules written often for other circumstances.” Still, it was
clear that corporate law wasn’t for her. “Her heart was really in public
service,” he says. From there, she went on to work for the Treasury
Department, then the Obama White House, where she focused on policies
around the then-upstart fintech industry.
After the administration turned over, Harris took a spin through the
revolving door between government and business. Her New York
financial-disclosure forms show a superabundance of work with the tech and
finance industries: She sat on the boards of six companies and nonprofits,
including LendingClub, which had recently settled with the Federal Trade
Commission over claims it had misled users on fees. She also advised 11
companies, owned two, and invested in or on behalf of two others. “I just
thought, well, if you’re going to make policy about it, you should do the
thing — run the company, build the company,” she says. “At the time, I felt
very comfortable going to a start-up because I thought, well, coming out of
government, you’re not making a ton of money. And if this start-up blows
up, I’ll probably be no worse off, financially speaking.”
It seems Harris did well enough. One real-estate tech company at which she
worked went public last summer, and Harris appears to have cashed out.
Since the disclosures were for 2020, they didn’t include her stake in
Forethought, a private A.I.-based customer-service company that announced
in December that it had attracted such investors as Harris, Ashton Kutcher,
and Gwenyth Paltrow. When I asked her about Forethought, Harris said her
investment in the company predated her time at DFS, that all her
investments are now in a blind trust, and that she would recuse herself
from any dealings with companies she has conflicts with.
So when Hochul appointed Harris to lead DFS, she was attacked by the left.
Zephyr Teachout and Cynthia Nixon both criticized Harris as being
insufficiently independent, thanks to her connections in tech and finance.
The American Prospect dug up a speech in which she characterized regulators
as looking for “no-nos” and “icky things.”
Harris has also advised the cash-advance companies Earnin, Brigit, and
SmartWage (based in South Africa), according to her disclosures. In 2019,
DFS led a multi-state investigation into the cash-advance industry over
whether they created debt traps and state banking and anti-usury laws,
since equivalent interest rates for the fees they charged would reach as
high as 469 percent. A person directly familiar with the investigation told
me that Harris’s predecessor was presented with multiple options for
furthering the investigation, including reaching a settlement, but
ultimately never made a decision. DFS wouldn’t comment.
So, of all the companies to work for, why them? “My role, when I was
working with those companies, was not to dictate price pricing or business
model. It was more to say: Here’s how regulators would view this. Here’s
why you should engage with them. Let me help you engage with them and
figure out these issues and how you can also serve customers. Less pricing
and business model, but, as an adviser who’s not in the day-to-day, helping
to sort of guide a culture and mentality,” she says.
Did she disagree with those arguing that these companies created debt traps
for consumers?
“I think it’s hard to paint with a broad brush,” she says. “I think we
should always always be careful with any new products and services, that
they are affordable and non-predatory, not creating debt traps, and that
they’re solving a real problem for consumers. And I think some do that and
some don’t.”
Last summer, after Andrew Cuomo resigned as governor, many of his
appointees went with him, including then-superintendent of DFS, Linda
Lacewell. Soon Harris’s old boss, Cohen, had recommended her to Kathryn
Wylde, the president and CEO of the Partnership for New York, a
business-advocacy group that has advised DFS. “The folks at Sullivan &
Cromwell thought that Adrienne would be a terrific candidate to field for
that job given her eight years of experience in the Obama administration
and the fact that she was somebody who understood industry,” Wylde says.
“On the theory that a regulator should know something about the industries
they’re regulating — which may be a novel concept but struck me as a valid
one — I thought she sounded like a terrific candidate.” Harris sailed
through her confirmation, with 63 senators voting for her and nine against.
“When the regulated are complaining that the regulator is being too
aggressive, that generally means the regulator is doing their job.” said
Michael Gianaris, the state senator from Queens who voted against Harris’s
nomination and, in 2019, tanked Amazon’s proposed HQ2 in New York. “Cuomo
was a prick, and the people he appointed tended to share his bare-knuckles
approach to the world. In some cases, that’s actually not a bad thing.”
While the crypto industry doesn’t appear to be getting the reprieve it had
been hoping for, other industries will surely lobby Harris to make similar
gestures toward the business community. For instance, Wylde says that
insurance companies are hoping that Harris will lower the reserves they are
required to have on hold, which they claim are higher than what’s required
by other states. “There are some long-standing issues that the industry has
that they feel that they’ve got a fresh start on with Adrienne’s
leadership,” she says.
Still, crypto is going to play a major part in how Harris’s tenure is
defined. “It’s clear that New York is doing well now and the companies that
came and started here five to ten years ago are doing well,” says Matt
Homer, a former deputy superintendent at DFS and the current
executive-in-residence at the venture-capital fund NYCA Partners. “It’s not
totally clear what the future will look like five to ten years from now.”
New York is the home base for major exchanges such as Coinbase and Gemini,
and it’s also home to shady NFT front-running scandals and alleged rapping
billionaire money launderers. That such a volatile industry could implode
and damage New York’s economy is apparent. “I understand that other states
may have gone the opposite way of the BitLicense, but there are things we
can do here in New York that will hopefully inform the federal regulators
as they continue to think about this space,” Harris said. “It’s a new world
with crypto, with DeFi, with NFTs.”
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4

The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents' ? Bitcoin News
by Gunnar Larson 21 Nov '24
by Gunnar Larson 21 Nov '24
21 Nov '24
Whete is Kathryn Haun when you need her on NYCCoin?
.....
https://news.bitcoin.com/the-silk-road-investigation-a-pattern-of-bad-behav…
by Jamie Redman
Oct 22, 2019
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
Kathryn Haun, a general partner at U.S. venture capital firm Andreessen
Horowitz, has revealed in recent interviews how she helped take down the
Silk Road when she was working for the Attorney General’s office. According
to her accounts, the U.S. government agency also asked her to help “start
shutting down technology before it’s built.” Haun’s story also highlights
how the U.S. government’s evidence against the Silk Road transpired because
of double agents.
Also read: FBI Agent Admits to Stealing Silk Road Bitcoins Seized by U.S.
Marshals
Kathryn Haun Was Asked to Disrupt Bitcoin in 2012
During the last few years, governments worldwide have been cracking down on
digital assets like on and off-ramps that are tied to fiat. Regulations are
far stricter than they were in the early days, when governments first heard
about cryptocurrencies like bitcoin. Andreessen Horowitz general partner
Kathryn Haun has a lot of experience working with government agencies when
it comes to the cryptocurrency economy. She witnessed the takedown of the
Silk Road darknet marketplace and before she started she was even asked to
help dismantle the Bitcoin network. During an interview with CNBC, Haun
revealed how a colleague mentioned the up and coming technology to her in
2012.
“‘We have this perfect assignment for you – there’s this thing called
Bitcoin and we need to investigate it,'” Haun told the news outlet on
October 6. “That was the first time I’d ever heard of bitcoin,” she added.
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
Former Silk Road investigator Kathryn Haun.
Attempts to shut down Bitcoin by agencies such as the U.S. Department of
Justice were fruitless ventures, Haun detailed. “It would have been akin to
saying ‘let’s go prosecute cash,'” the former prosecutor said. “What we
heard with Libra were the same criticisms [about Bitcoin],” Haun remarked.
While discussing the similarities between her early days with Bitcoin in
contrast to Libra, she continued:
They got more attention because of the high-profile nature of the project
and the fact that Facebook was involved. I think it would be a really
dangerous thing, and frankly a dangerous precedent to start shutting down
technology before it’s built.
Uncovering the Silk Road and Parallel Investigations
During another recently published interview with Haun, the Andreesen
Horowitz partner spoke with Hayman Capital founder Kyle Bass about her role
during the prosecution of the Silk Road marketplace. “The Silk Road was
making millions of dollars a month and they were generating a lot of
revenue,” Haun stressed. She doesn’t remember exactly how the Silk Road
case got opened in New York, but she recalls Senator Chuck Schumer read a
Wired article that prompted him to wonder why the marketplace was allowed
to exist. “So the Southern District of New York, which is another Attorney
General’s office – I was in the U.S. Attorney General’s office in San
Francisco – SDNY opened the case and was trying to figure out who was
behind the Silk Road. At this same time, a D.C. office was also trying to
figure out who was running the Silk Road — And there were parallel
investigations going.”
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
Haun discusses the Silk Road investigation with Hayman Capital founder Kyle
Bass.
Haun explained that the government had task forces comprised of many
alphabet soup agencies: “We’re talking the FBI, CIA, Secret Service, DEA,
ATF, and the U.S. Marshals,” she underlined. “One task force, the one out
of Washington D.C., they had an undercover agent. That undercover agent was
able to befriend the person running the Silk Road. All the government knew
at the time was that the person running the Silk Road went by the nickname
‘DPR’ for ‘Dread Pirate Roberts’ from the movie ‘The Princess Bride.’ So
they didn’t know who DPR was, but the undercover agent actually set up an
attempt to buy the Silk Road.”
The Foundation of Evidence from the Silk Road Case Stemmed from Double
Agents
According to the former prosecutor, the undercover agent struck many online
conversations with DPR and proceeded for the next two years to engage and
message with the moniker. “A lot of things went wrong on both sides — From
the Silk Road side, 2013 was a really bad year for the Silk Road because
what you had was a person who had an online persona called ‘Death from
Above,’” Haun said. “Death from Above starting extorting DPR and saying ‘if
you don’t pay me hundreds of thousands of dollars in bitcoin I’m going to
reveal your identity to law enforcement.’ Meanwhile, there was another
online persona who went by the moniker ‘French Maid.’ French Maid was
selling DPR information about the government’s investigation. French Maid
told DPR the Feds are closing in and the end is near and you are about to
be had.” Haun added:
The government didn’t know any of this then and it all came out after the
fact. In the midst of this, something else really bad happened in 2013 —
About 21,000 bitcoins, which is today in excess of roughly $150 million
dollars, went missing overnight from the Silk Road. From Silk Road vendor
accounts and from what you might consider the petty cash account — Although
there’s nothing petty about 21,000 bitcoins.
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
Haun’s story begs the question: How much evidence would the government have
without the use of double agents and rogue officers manipulating the
investigation?
During the remainder of the interview, Haun discussed Curtis Green’s role
with the Silk Road and said Green showed the Feds “how the Silk Road
worked, how to log into it, how to reset vendor PINs and passwords, and of
course [Green] had that access because he was the key administrator.” Haun
also said Green even gave his laptop to the Feds to keep as evidence. The
discussion with Kyle Bass shows how government agents claim to have
dismantled the Silk Road from the words of a former Federal prosecutor.
However, Haun wasn’t involved with the DPR takedown first hand, but she was
very much involved with investigating rogue agents. At first, when she
heard about the first rogue agent she took it with “a grain of salt” and
actually said it was a shame the tipster was smearing a Federal agent’s
good name. But the tipster was insistent and she decided to look into it.
“We saw that this agent who we got the tip for was liquidating hundreds of
thousands of dollars, if not millions a month, in cryptocurrency. So I
thought it’s probably another undercover operation and there’s probably a
legitimate explanation,” Haun explained.
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
>From left to right — Carl Mark Force, Shaun Bridges, and Curtis Green all
played a ‘double agent’ role in the Silk Road investigation. Curtis Green
was a Silk Road moderator who was told by the U.S. government to fake his
own death.
Haun concluded that the rogue agent was caught telling exchanges to destroy
transaction histories. Because undercover agents who are running undercover
operations shouldn’t be asking for evidence to be destroyed, it raised a
red flag Haun said. Her team found a “pattern of really bad behavior to put
it mildly” and in the end, it turned out the rogue agent was both online
personas: French Maid and Death from Above. Essentially, the interview with
Haun shows that Curtis Green, Shaun Bridges, and Carl Mark Force were
acting as double agents during the entire investigation. The discussion
with Haun further highlights how the Silk Road case was quite messy and
many constitutional laws were broken by rogue agents in order to disrupt
the site. Still, the U.S. government, with no thought toward constitutional
law and a complete disregard for true justice, based all their Silk Road
evidence on the shameful ethics of Curtis Green and two rogue cops — Carl
Mark Force and Shaun Bridges.
It goes to show that the many unanswered questions surrounding the case,
like how government agents found the Silk Road’s IP address, which wasn’t
due to a faulty ‘captcha’ screen as claimed, were likely due to perfidious
agents gone rogue.
1
1

19 Nov '24
Dear Department of the Treasury:
On 04/20/2022 (below), we contacted your esteemed office with concern of
potential MiamiCoin (MIA Coin) klepocracy. MIA Coin and NYCCoin were born
product of Stacks (STX) powered by POX technology.
Today, xNY.io - Bank.org seeks Treasury's assessment on digital asset
market manipulation and likely klepocracy associated with MIA Coin, FTX
Stadium, the Mayor of Miami and Miami Dade County that has impacted our
global enterprise.
1) In March 2021, FTX, a cryptocurrency exchange, acquired the naming
rights to the arena for $135 million. The NBA approved the deal in early
April, and the arena was fully renamed to FTX Arena in June 2021:
https://www.nba.com/heat/news/heat-partners-with-ftxus
2) In September 2021, Miami Mayor Francis Suarez was interviewed by Fox
Business on MIA Coin and how it generated $5M for the City of Miami. Mayor
Suarez suggested that MIA Coin translates to increased life quality:
https://twitter.com/FrancisSuarez/status/1440090602213871617?s=20&t=Ue01mCO…
3) In January 2022, FTX announced trading of STX:
https://help.ftx.com/hc/en-us/articles/360059081712-FTX-has-listed-AXS-HUM-…
>From xNY.io - Bank.org's initial kelpocracy memo to Treasury, market forces
show multiple fraud and market manipulation instances spanning FTX, STX and
MIA Coin that have directly impacted our enterprise in New York.
We kindly seek your esteemed appraisal of the matter.
Warm regards,
Gunnar
--
Gunnar Larson - xNY.io - Bank.org
MSc - Digital Currency
MBA - Entrepreneurship and Innovation (ip)
G(a)xNY.io
+1-646-454-9107
New York, New York 10001
On Wed, Apr 20, 2022, 4:38 PM Gunnar Larson <g(a)xny.io> wrote:
> Dear Department of the Treasury:
>
> From the prompt of FinCEN's Resource Center, the details below are kindly
> submitted to your esteemed attention.
>
> Please let me know if I can be of any assistance.
>
> Sending you the very best regards.
>
> Thank you,
>
> Gunnar Larson
> --
> *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
> New York, New York 10001
>
> ---------- Forwarded message ---------
> From: Gunnar Larson <g(a)xny.io>
> Date: Fri, Apr 15, 2022 at 1:17 PM
> Subject: MIA Coin and POX Kleptocracy: CORRUPTION FIN-2022-A001 - SAR
> 38(m).
> To: <FRC(a)fincen.gov>
> Cc: cypherpunks <cypherpunks(a)lists.cpunks.org>
>
>
> Dear FinCEN:
>
> xNY.io - Bank.org, PBC thanks you for sending yesterday's advisory on
> kleptocracy and foreign public corruption. We have made 30 highlights to
> the FIN-2022-A001
> <https://drive.google.com/file/d/1yF3qDQG19J-qN1vUPC36lQfVClq3HPXB/view?usp=…>
> advisory for reference.
>
> *The aim of today's memo is to learn FinCEN's insights into MIA Coin and
> the consensus algorithm Proof of Transfer (POX). xNY.io - Bank.org, PBC is
> concerned about potential MIA Coin and City Coin kleptocracy that may be
> affecting our global enterprise. *
>
> *FinCEN may note that NYCCoin is illegal in New York State, given the
> BitLicense mandate. As such, we are not concerned with NYCCoin's legality
> given the clear BitLicense mandate. *
>
> - On February 4, 2022 we submitted a City of Miami records request for
> any and all correspondence between the City of Miami concerning CityCoins,
> MIA Coin and Stacks (STX). Additionally, any and all related correspondence
> concerning CityCoins, MIA Coin, Stacks (STX), Digital World Acquisition
> Corp and Harvard Management Company.
> - Today, April 15, 2022
> <https://drive.google.com/file/d/1OyVUBq8PcG7SVZ5lUp_oWyL0IDAR5uTP/view?usp=…>
> we have yet to receive the 13, 092 records. Attached you will find our
> latest correspondence with Miami, notifying them of our intention to
> contact FinCEN concerning MIA Coin and POX.
> - Conducting independent marketplace research, xNY.io - Bank.org, PBC
> established a premise to potential kleptocracy between the City of Miami
> and City Coins, of Iceland <https://who.is/whois/citycoins.co>
> international registration. Furthermore, MineMiamiCoin.com is registered
> in Germany <https://who.is/whois/minemiamicoin.com>.
> - Please find the City of Miami's resolution
> <https://drive.google.com/file/d/1IrQwP46alrnQXRxIoXxm8kifZMVTRB_x/view?usp=…>approving
> gifts from City Coins ... Furthermore, City Coins suggests a $25,000
> "reward"
> <https://drive.google.com/file/d/1Eb2Q-LZNApwQRyjbBcD5-_yEW0Id51QD/view?usp=…>
> (that may be confused as bribery) for Mayors who participate.
>
> MIA Coin is powered by POX
> <https://drive.google.com/file/d/1wL2kN6aMfsyT-T7g01YJSBB8meMn2SWg/view?usp=…>,
> a computer protocol that may exploit the U.S. and international financial
> systems to launder illicit gains, including through the use of shell
> companies, offshore financial centers, and professional service providers
> who enable the movement and laundering.
>
> MIA Coin' POX protocol is a wealth extraction tool that unfairly rewards
> an inside group of miners, rewarding patronage networks that benefit his
> inner circle and regime. These practices harm the competitive landscape of
> financial markets and often have long-term corrosive effects on good
> governance, democratic institutions, and human rights standards.
>
> FinCEN, we are concerned Miami's City Coin
> <https://drive.google.com/file/d/1IrQwP46alrnQXRxIoXxm8kifZMVTRB_x/view>
> resolution potentially confirms Miami leaders as kleptocrats, using their
> position and influence to enrich themselves and their networks of corrupt
> actors.
>
> Finally, we understand that MIA Coin and POX operations are powered by
> international data warehouses, located in Iceland, Germany and Hong Kong.
> For these reasons, given FinCEN's alert on kleptocracy and foreign public
> corruption we kindly seek guidance.
>
> Sending you the very best regards.
>
> Thank you,
>
> Gunnar Larson
> --
> *Gunnar Larson - xNY.io <http://www.xNY.io> - Bank.org <http://Bank.org>,
> PBC*
> 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
> New York, New York 10001
>
> ---------- Forwarded message ---------
> From: Financial Crimes Enforcement Network <
> fincenupdates(a)public.govdelivery.com>
> Date: Thu, Apr 14, 2022 at 2:46 PM
> Subject: FinCEN Updates: FinCEN Issues Advisory on Kleptocracy and Foreign
> Public Corruption
> To: <g(a)xny.io>
>
>
> *You are subscribed to FinCEN Updates. The information below is available
> at Fincen.gov.*
>
> *FinCEN Issues Advisory on Kleptocracy and Foreign Public Corruption*
>
> The Financial Crimes Enforcement Network (FinCEN) today issued an advisory
> on kleptocracy and foreign public corruption, urging financial institutions
> to focus their efforts on detecting the proceeds of foreign public
> corruption — a priority for the U.S. Government as it continues to
> implement the U.S. Strategy on Countering Corruption
> <https://lnks.gd/l/eyJhbGciOiJIUzI1NiJ9.eyJidWxsZXRpbl9saW5rX2lkIjoxMDAsInVy…>.
> The advisory provides typologies and potential indicators of kleptocracy
> and other forms of foreign public corruption, namely bribery, embezzlement,
> extortion, and the misappropriation of public assets.
>
> *News Release:*
>
>
> https://www.fincen.gov/news/news-releases/fincen-issues-advisory-kleptocrac…
> <https://lnks.gd/l/eyJhbGciOiJIUzI1NiJ9.eyJidWxsZXRpbl9saW5rX2lkIjoxMDEsInVy…>
>
> *Advisory: *
>
> https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2022-a001
> <https://lnks.gd/l/eyJhbGciOiJIUzI1NiJ9.eyJidWxsZXRpbl9saW5rX2lkIjoxMDIsInVy…>
>
1
8

Re: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.)
by Gunnar Larson 19 Nov '24
by Gunnar Larson 19 Nov '24
19 Nov '24
Hello:
Thank you for your Jul 16, 2023 response.
xNY.io - Bank.org did not hear from you on
November 29, 2023 as promised.
Can xNY.io - Bank.org please receive the
NYPD body cam footage for NYCCoin Touting by December 31, 2023?
Warm regards,
Gunnar
Gunnar Larson
--
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
On Wed, Dec 6, 2023, 11:11 AM Gunnar Larson <g(a)xny.io> wrote:
> Hello:
>
> Any updates on the body camera footage mentioned below?
>
> Gunnar
>
> Gunnar Larson
> xNY.io - Bank.org
> 917-580-8093
>
> On Thu, Nov 16, 2023, 7:10 AM Gunnar Larson <g(a)xny.io> wrote:
>
>> Dear Madam or Sir:
>>
>> I am just confirming that the NYCCoin body camera footage is still on
>> track for November 29, 2023 delivery. Can you confirm as such please?
>>
>> The matter was recorded late March 2023. And xNY.io - Bank.org must close
>> our EOY-23 books.
>>
>> Any further delay of the body camera footage could be a challenge to N.Y.
>> Executive Law, Article 15
>> Human Rights Law, § 296. Unlawful discriminatory practices:
>>
>> 14. ... whether or not accompanied by the
>> person for whom the dog is being trained.
>>
>> 16. It shall be an unlawful discriminatory practice, unless specifically
>> required or permitted by statute, for any person, agency, bureau,
>> corporation or association, including the state and any political
>> subdivision thereof, to make any inquiry about, whether in any form of
>> application or
>> otherwise, or to act upon adversely to the individual involved, any
>> arrest or criminal accusation of such individual not then pending against
>> that individual which was followed by a termination of that criminal action
>> or proceeding in favor of such individual, as defined in subdivision two of
>> section 160.50 of the criminal procedure law, or by an order adjourning
>> the criminal action in contemplation of dismissal, pursuant to section
>> 170.55, 170.56, 210.46, 210.47, or 215.10 of the criminal procedure law, or
>> by a youthful offender adjudication, as defined in subdivision one of
>> section 720.35 of the criminal procedure law, or by a conviction for a
>> violation sealed pursuant to section 160.55 of the criminal procedure law
>> or by a conviction which is sealed pursuant to section 160.59 or 160.58 of
>> the criminal procedure law, in connection with the licensing, housing,
>> employment, including volunteer positions, or providing of credit or
>> insurance to such individual; provided, further, that no person shall be
>> required to divulge information pertaining to any arrest or criminal
>> accusation of such individual not then pending against that individual
>> which was followed by a termination of that criminal action or proceeding
>> in favor of such individual, as defined in subdivision two of section
>> 160.50 of the criminal procedure law, or by an order adjourning the
>> criminal action in contemplation of dismissal, pursuant to section 170.55,
>> 170.56, 210.46, 210.47, or 215.10 of the criminal procedure law, or by a
>> youthful offender adjudication, as defined in subdivision one of section
>> 720.35 of the criminal procedure law, or by
>> a conviction for a violation sealed pursuant to section 160.55 of the
>> criminal procedure law, or by a conviction which is sealed pursuant to
>> section 160.58 or 160.59 of the criminal procedure law. An individual
>> required or requested to provide information in violation of this
>> subdivision
>> may respond as if the arrest, criminal accusation, or disposition of such
>> arrest or criminal accusation did not occur. The provisions of this
>> subdivision shall not apply to the licensing activities of governmental
>> bodies in relation to the regulation of guns, firearms and other deadly
>> weapons or in relation to an application for employment as a police officer
>> or peace officer as those terms are defined in subdivisions thirty-three
>> and thirty-four of section 1.20 of the criminal
>> procedure law; provided further that the provisions of this subdivision
>> shall not apply to an application for employment or membership in any law
>> enforcement agency with respect to any arrest or criminal accusation which
>> was followed by a youthful offender adjudication, as defined
>> in subdivision one of section 720.35 of the criminal procedure law, or by
>> a conviction for a violation sealed pursuant to section 160.55 of the
>> criminal procedure law, or by a conviction which is sealed pursuant to
>> section 160.58 or 160.59 of the criminal procedure law. For purposes of
>> this subdivision, an action which has been adjourned in contemplation of
>> dismissal, pursuant to section 170.55 or 170.56, 210.46, 210.47 or 215.10
>> of the criminal procedure law, shall not be
>> considered a pending action, unless the order to adjourn in contemplation
>> of dismissal is revoked and the case is restored to the calendar for
>> further prosecution.
>>
>> Thank you,
>>
>> Gunnar
>>
>> Gunnar Larson
>> xNY.io - Bank.org
>> 917-580-8053
>>
>> n, Jul 16, 2023, 11:03 AM IABCMDCNTR <IABCMDCNTR(a)nypd.org> wrote:
>>
>>> Mr. Larson,
>>>
>>> The FOIL request you requested was acknowledged and a response will be on
>>> or about Wednesday, November 29, 2023. They will follow-up with your
>>> request. If the request is denied, and you would like to file a complaint,
>>> we will assist you. Have a good day.
>>>
>>>
>>>
>>> *COMMAND CENTER, INTERNAL AFFAIRS BUREAU *
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> This e-mail message and any attachment(s) is intended only for the
>>> person and/or entity to which it is addressed and may contain CONFIDENTIAL
>>> or PRIVILEGED material. Any unauthorized review, use, disclosure or
>>> distribution is strictly prohibited and may violate applicable laws
>>> including the Electronic Communications Privacy Act. If you are not the
>>> intended recipient, please contact the sender by reply e-mail and
>>> delete/destroy all copies of the original message. If you are the intended
>>> recipient but do not wish to receive communications through this medium,
>>> please so advise the sender immediately. Please treat this and all other
>>> communications from the New York City Police Department as LAW ENFORCEMENT
>>> SENSITIVE / FOR OFFICIAL USE ONLY. NO REPORT OR SEGMENT THEREOF MAY BE
>>> RELEASED TO ANY MEDIA SOURCES.
>>>
>>>
>>> ------------------------------
>>> *From:* Gunnar Larson <g(a)xny.io>
>>> *Sent:* Sunday, July 16, 2023 10:56 AM
>>> *To:* FDSHelpDesk(a)ethics.ny.gov <FDSHelpDesk(a)ethics.ny.gov>;
>>> ethel(a)jcrope.ny.gov <ethel(a)jcrope.ny.gov>; IABCMDCNTR <
>>> IABCMDCNTR(a)nypd.org>
>>> *Cc:* letitia.james(a)ag.ny.gov <letitia.james(a)ag.ny.gov>;
>>> cypherpunks(a)cpunks.org <cypherpunks(a)cpunks.org>; Harris, Adrienne A
>>> (DFS) <Adrienne.Harris(a)dfs.ny.gov>
>>> *Subject:* Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged
>>>
>>>
>>>
>>>
>>> *CAUTION! EXTERNAL SENDER*
>>>
>>> *STOP WHEN UNSURE.* Never click on links or open attachments if sender
>>> is unknown, and never provide user ID or password. *Suspicious?*
>>> Please report to this email address: reportphishing(a)nypd.org
>>>
>>> Dear New York Ethics Team:
>>>
>>> I am concerned that the FOIL below is subject to obstruction of justice.
>>>
>>> The FOIL request is for access to NYPD body cam footage, for NYCCoin
>>> Touting.
>>>
>>> Ethics Team, I am concerned that the Chief of your office is also the
>>> Chief of the City Mayor's office.
>>>
>>> The body cam footage should have an agreeable time for delivery. I am
>>> concerned that the Mayor is retaliating against NYCoin and the NYPD may be
>>> aware of this.
>>>
>>> The video would or would not delineate any form of unnecessary force.
>>> The NYPD may be aware of this.
>>>
>>> Obviously, xNY is very protective of digital asset innovation. Ethics is
>>> a serious matter and the body cam footage would be helpful concerning
>>> NYCCoin.
>>>
>>> Sincerely yours,
>>>
>>> Gunnar
>>>
>>> Gunnar Larson
>>> xNY.io - Bank.org
>>> 917-580-8053
>>>
>>>
>>> ---------- Forwarded message ---------
>>> From: <donotreply(a)records.nyc.gov>
>>> Date: Fri, Jul 14, 2023, 12:25 PM
>>> Subject: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged
>>> To: <g(a)xny.io>
>>>
>>>
>>> The New York City Police Department (NYPD) has *acknowledged* your FOIL
>>> request FOIL-2023-056-15960
>>> <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960>.
>>>
>>> You can expect a response on or about Wednesday, November 29, 2023.
>>> Additional Information:
>>>
>>> Your request has been assigned to PAA Quagliano (646-610-5296)
>>>
>>>
>>> Please visit FOIL-2023-056-15960
>>> <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960> to
>>> view additional information and take any necessary action.
>>>
>>
1
6

Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.)
by Gunnar Larson 19 Nov '24
by Gunnar Larson 19 Nov '24
19 Nov '24
Dear Honorable Senator Gillibrand:
My name is Gunnar Larson and I am a co-founder at xNY.io - Bank.org.
Today I contact your esteemed office seeking assistance with retrieving the
NYPD body camera footage mentioned below.
The FOIL request was filed with the NYPD on July 14, 2023. The NYPD
responded on July 16, 2023, noting a potential delivery date of the body
camera footage by end of November 2023.
As of today, January 12, 2024 xNY.io - Bank.org has not heard from the NYPD
on receiving the body camera footage.
Senator Gillibrand, I am concerned delay in receiving this body camera
footage may disrespect your #MeToo zero tolerance policy. Humbly, the FBI
should be able to confirm with your office if this is a "Don't Ask, Don't
Tell" matter.
Ultimately, I am concerned this matter should not impact the pure interests
of your Lummis-Gillibrand Responsible Financial Innovation Act.
The FBI should be able to be honest with your office concerning your
Bloomberg Crypto Summit interview with Senator Lummis on the Responsible
Financial Innovation Act. It is my understanding that the NYPD body camera
footage could have been staged politically, given xNY's approach to
NYCCoin.
Senator Gillibrand, your office could offer anyone the opportunity to
engage the new SDNY program here to protect honest integrity of the NYPD:
https://www.wsj.com/articles/u-s-attorney-in-manhattan-launches-program-to-…
.
Thank you Senator Gillibrand.
Sending you the very best regards,
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
---------- Forwarded message ---------
From: Gunnar Larson <g(a)xny.io>
Date: Wed, Jan 10, 2024, 5:36 AM
Subject: Re: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD
body cam footage, for NYCCoin Touting.)
To: IABCMDCNTR <IABCMDCNTR(a)nypd.org>
Cc: <cypherpunks(a)cpunks.org>, ethics.sm.records <records(a)ethics.ny.gov>, <
ethel(a)jcrope.ny.gov>, <letitia.james(a)ag.ny.gov>, Harris, Adrienne A (DFS) <
Adrienne.Harris(a)dfs.ny.gov>, <PressOffice(a)cityhall.nyc.gov>, Reader, Shaun <
sreader(a)curtis.com>, <district3(a)council.nyc.gov>
Good morning NYPD:
Thank you for your Jul 16, 2023 response.
xNY.io - Bank.org did not hear from you on
November 29, 2023 as promised.
Given the emerging situation in USA cryptocurrency markets, we are going to
need to follow up with the NYPD every 10 days until we receive the NYCCoin
touting body camera footage.
Can you please update xNY.io - Bank.org on the status of the footage? We
have received various replies from the City of New York on Mayor Adams'
'first checks in Bitcoin' mentioned here:
https://www.nyc.gov/office-of-the-mayor/news/041-22/mayor-adams-receive-fir…
.
Have a good day.
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
On Mon, Jan 1, 2024, 6:41 AM Gunnar Larson <g(a)xny.io> wrote:
> Good morning:
>
> Happy New Year 2024 to you.
>
> Can we please have an update on this matter?
>
> 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
>
>
> On Fri, Dec 15, 2023, 3:51 PM Gunnar Larson <g(a)xny.io> wrote:
>
>> Hello:
>>
>> Thank you for your Jul 16, 2023 response.
>>
>> xNY.io - Bank.org did not hear from you on
>> November 29, 2023 as promised.
>>
>> Can xNY.io - Bank.org please receive the
>> NYPD body cam footage for NYCCoin Touting by December 31, 2023?
>>
>> Warm regards,
>>
>> Gunnar
>>
>> Gunnar Larson
>> --
>> 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
>>
>> On Wed, Dec 6, 2023, 11:11 AM Gunnar Larson <g(a)xny.io> wrote:
>>
>>> Hello:
>>>
>>> Any updates on the body camera footage mentioned below?
>>>
>>> Gunnar
>>>
>>> Gunnar Larson
>>> xNY.io - Bank.org
>>> 917-580-8093
>>>
>>> On Thu, Nov 16, 2023, 7:10 AM Gunnar Larson <g(a)xny.io> wrote:
>>>
>>>> Dear Madam or Sir:
>>>>
>>>> I am just confirming that the NYCCoin body camera footage is still on
>>>> track for November 29, 2023 delivery. Can you confirm as such please?
>>>>
>>>> The matter was recorded late March 2023. And xNY.io - Bank.org must
>>>> close our EOY-23 books.
>>>>
>>>> Any further delay of the body camera footage could be a challenge to
>>>> N.Y. Executive Law, Article 15
>>>> Human Rights Law, § 296. Unlawful discriminatory practices:
>>>>
>>>> 14. ... whether or not accompanied by the
>>>> person for whom the dog is being trained.
>>>>
>>>> 16. It shall be an unlawful discriminatory practice, unless
>>>> specifically required or permitted by statute, for any person, agency,
>>>> bureau, corporation or association, including the state and any political
>>>> subdivision thereof, to make any inquiry about, whether in any form of
>>>> application or
>>>> otherwise, or to act upon adversely to the individual involved, any
>>>> arrest or criminal accusation of such individual not then pending against
>>>> that individual which was followed by a termination of that criminal action
>>>> or proceeding in favor of such individual, as defined in subdivision two of
>>>> section 160.50 of the criminal procedure law, or by an order adjourning
>>>> the criminal action in contemplation of dismissal, pursuant to section
>>>> 170.55, 170.56, 210.46, 210.47, or 215.10 of the criminal procedure law, or
>>>> by a youthful offender adjudication, as defined in subdivision one of
>>>> section 720.35 of the criminal procedure law, or by a conviction for a
>>>> violation sealed pursuant to section 160.55 of the criminal procedure law
>>>> or by a conviction which is sealed pursuant to section 160.59 or 160.58 of
>>>> the criminal procedure law, in connection with the licensing, housing,
>>>> employment, including volunteer positions, or providing of credit or
>>>> insurance to such individual; provided, further, that no person shall be
>>>> required to divulge information pertaining to any arrest or criminal
>>>> accusation of such individual not then pending against that individual
>>>> which was followed by a termination of that criminal action or proceeding
>>>> in favor of such individual, as defined in subdivision two of section
>>>> 160.50 of the criminal procedure law, or by an order adjourning the
>>>> criminal action in contemplation of dismissal, pursuant to section 170.55,
>>>> 170.56, 210.46, 210.47, or 215.10 of the criminal procedure law, or by a
>>>> youthful offender adjudication, as defined in subdivision one of section
>>>> 720.35 of the criminal procedure law, or by
>>>> a conviction for a violation sealed pursuant to section 160.55 of the
>>>> criminal procedure law, or by a conviction which is sealed pursuant to
>>>> section 160.58 or 160.59 of the criminal procedure law. An individual
>>>> required or requested to provide information in violation of this
>>>> subdivision
>>>> may respond as if the arrest, criminal accusation, or disposition of
>>>> such arrest or criminal accusation did not occur. The provisions of this
>>>> subdivision shall not apply to the licensing activities of governmental
>>>> bodies in relation to the regulation of guns, firearms and other deadly
>>>> weapons or in relation to an application for employment as a police officer
>>>> or peace officer as those terms are defined in subdivisions thirty-three
>>>> and thirty-four of section 1.20 of the criminal
>>>> procedure law; provided further that the provisions of this subdivision
>>>> shall not apply to an application for employment or membership in any law
>>>> enforcement agency with respect to any arrest or criminal accusation which
>>>> was followed by a youthful offender adjudication, as defined
>>>> in subdivision one of section 720.35 of the criminal procedure law, or
>>>> by a conviction for a violation sealed pursuant to section 160.55 of the
>>>> criminal procedure law, or by a conviction which is sealed pursuant to
>>>> section 160.58 or 160.59 of the criminal procedure law. For purposes of
>>>> this subdivision, an action which has been adjourned in contemplation of
>>>> dismissal, pursuant to section 170.55 or 170.56, 210.46, 210.47 or 215.10
>>>> of the criminal procedure law, shall not be
>>>> considered a pending action, unless the order to adjourn in
>>>> contemplation of dismissal is revoked and the case is restored to the
>>>> calendar for further prosecution.
>>>>
>>>> Thank you,
>>>>
>>>> Gunnar
>>>>
>>>> Gunnar Larson
>>>> xNY.io - Bank.org
>>>> 917-580-8053
>>>>
>>>> n, Jul 16, 2023, 11:03 AM IABCMDCNTR <IABCMDCNTR(a)nypd.org> wrote:
>>>>
>>>>> Mr. Larson,
>>>>>
>>>>> The FOIL request you requested was acknowledged and a response will be on
>>>>> or about Wednesday, November 29, 2023. They will follow-up with your
>>>>> request. If the request is denied, and you would like to file a complaint,
>>>>> we will assist you. Have a good day.
>>>>>
>>>>>
>>>>>
>>>>> *COMMAND CENTER, INTERNAL AFFAIRS BUREAU *
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> This e-mail message and any attachment(s) is intended only for the
>>>>> person and/or entity to which it is addressed and may contain CONFIDENTIAL
>>>>> or PRIVILEGED material. Any unauthorized review, use, disclosure or
>>>>> distribution is strictly prohibited and may violate applicable laws
>>>>> including the Electronic Communications Privacy Act. If you are not the
>>>>> intended recipient, please contact the sender by reply e-mail and
>>>>> delete/destroy all copies of the original message. If you are the intended
>>>>> recipient but do not wish to receive communications through this medium,
>>>>> please so advise the sender immediately. Please treat this and all other
>>>>> communications from the New York City Police Department as LAW ENFORCEMENT
>>>>> SENSITIVE / FOR OFFICIAL USE ONLY. NO REPORT OR SEGMENT THEREOF MAY BE
>>>>> RELEASED TO ANY MEDIA SOURCES.
>>>>>
>>>>>
>>>>> ------------------------------
>>>>> *From:* Gunnar Larson <g(a)xny.io>
>>>>> *Sent:* Sunday, July 16, 2023 10:56 AM
>>>>> *To:* FDSHelpDesk(a)ethics.ny.gov <FDSHelpDesk(a)ethics.ny.gov>;
>>>>> ethel(a)jcrope.ny.gov <ethel(a)jcrope.ny.gov>; IABCMDCNTR <
>>>>> IABCMDCNTR(a)nypd.org>
>>>>> *Cc:* letitia.james(a)ag.ny.gov <letitia.james(a)ag.ny.gov>;
>>>>> cypherpunks(a)cpunks.org <cypherpunks(a)cpunks.org>; Harris, Adrienne A
>>>>> (DFS) <Adrienne.Harris(a)dfs.ny.gov>
>>>>> *Subject:* Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> *CAUTION! EXTERNAL SENDER*
>>>>>
>>>>> *STOP WHEN UNSURE.* Never click on links or open attachments if
>>>>> sender is unknown, and never provide user ID or password.
>>>>> *Suspicious?* Please report to this email address:
>>>>> reportphishing(a)nypd.org
>>>>>
>>>>> Dear New York Ethics Team:
>>>>>
>>>>> I am concerned that the FOIL below is subject to obstruction of
>>>>> justice.
>>>>>
>>>>> The FOIL request is for access to NYPD body cam footage, for NYCCoin
>>>>> Touting.
>>>>>
>>>>> Ethics Team, I am concerned that the Chief of your office is also the
>>>>> Chief of the City Mayor's office.
>>>>>
>>>>> The body cam footage should have an agreeable time for delivery. I am
>>>>> concerned that the Mayor is retaliating against NYCoin and the NYPD may be
>>>>> aware of this.
>>>>>
>>>>> The video would or would not delineate any form of unnecessary force.
>>>>> The NYPD may be aware of this.
>>>>>
>>>>> Obviously, xNY is very protective of digital asset innovation. Ethics
>>>>> is a serious matter and the body cam footage would be helpful concerning
>>>>> NYCCoin.
>>>>>
>>>>> Sincerely yours,
>>>>>
>>>>> Gunnar
>>>>>
>>>>> Gunnar Larson
>>>>> xNY.io - Bank.org
>>>>> 917-580-8053
>>>>>
>>>>>
>>>>> ---------- Forwarded message ---------
>>>>> From: <donotreply(a)records.nyc.gov>
>>>>> Date: Fri, Jul 14, 2023, 12:25 PM
>>>>> Subject: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged
>>>>> To: <g(a)xny.io>
>>>>>
>>>>>
>>>>> The New York City Police Department (NYPD) has *acknowledged* your
>>>>> FOIL request FOIL-2023-056-15960
>>>>> <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960>.
>>>>>
>>>>> You can expect a response on or about Wednesday, November 29, 2023.
>>>>> Additional Information:
>>>>>
>>>>> Your request has been assigned to PAA Quagliano (646-610-5296)
>>>>>
>>>>>
>>>>> Please visit FOIL-2023-056-15960
>>>>> <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960>
>>>>> to view additional information and take any necessary action.
>>>>>
>>>>
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With the news this week, from the archive:
https://thecapital.io/article/breaking-news-robinhood-rebrands-as-libra---M…
*Breaking News: Robinhood Rebrands as 'Libra'*
SILICON VALLEY - Embroiled in the naturally malevolent evolutionary controversy
of brand fakery
<https://thecapital.io/article/robinhoods-brand-fake-vs-paypals-crypto-corru…>
in the name of manipulating humanity, Robinhood Markets (a financial
services company) rocked the brand marketing world by finally coming to its
senses while vindicating Mr. Hood’s legacy. The company has distanced
itself from the old Robinhood firm image of “we take advantage of our
customers” with a fresh rebrand as ‘Libra.’
Celebrated humanitarian Richard Simmons applauded the name change. “Mr.
Hood’s story of altruism is loved by young and old alike world-wide. Today
Mr. Hood is vindicated from association to the former Robinhood’s tricky
company shenanigans. The new ‘Libra’ image is a super smart act of serving
our country well... I hope the all-stars at Bear Stearns will join me in
congratulating the new ‘Libra’ brand,” Simmons said.
*The nature and timing of the brand change raised eyebrows in New York, a
recent familiar reaction to news from our pals
<https://thecapital.io/article/robinhoods-brand-fake-vs-paypals-crypto-corru…>
from the Valley.Gleefully contemplating the long term impact on society,
this reporter touts the courage of the real Mr. Hood for opposing forces
similar to that of the former Robinhood.*
History will celebrate the newly minted Libra, which will be hailed for its
valor in rebranding, even though it did so to escape the regulatory cloud
that has hung over the Robinhood project since it first came into the
public domain.
(A Satirical Monograph on the News)
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