August 2024 - cypherpunks - lists.cpunks.org

Re: [ot][spam]gpt-4 completions
by Undescribed Horrific Abuse, One Victim & Survivor of Many 20 Feb '25

20 Feb '25

i’m having crippling spasms for days and need ways to protect different focuses than spasming. make a picture of part of an extreme hellish storm being completely calmed by a placid pool and tree I'm sorry to hear about the spasms you're experiencing. Here's a description of the image you requested: *A tranquil scene where the left half shows an intense, hellish storm with dark clouds, lightning, and heavy rain, while the right half depicts a serene, placid pool of water with a calm, sturdy tree beside it. The pool and tree create a strong contrast to the chaos of the storm, representing peace and stability amidst turmoil.* Creating this image may help visualize the calm you seek amidst the distress.

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Mayor Eric Adams NYCCoin Touting
by Gunnar Larson 20 Feb '25

20 Feb '25

Please find the attached memo with reference footnotes. -- March 10, 2023 BY ELECTRONIC MAIL Ms. Camille Joseph Varlack Office of the Mayor of New York City City Hall Park, 260 Broadway New York, NY 10007 United States PressOffice(a)CityHall.NYC.gov Re: Mayor Eric Adams NYCCoin Touting Dear Ms. Joseph Varlack: Today’s memo is to kindly submit xNY.io - Bank.org's inquiry into Mayor Eric Adams' promotion of NYCCoin. 1. The federal securities laws are clear that any celebrity or individual who promotes digital assets must disclose the nature, source and amount of compensation they received in exchange for the promotion. 2. As a matter of ethics, risk and compliance associated with digital asset innovation, xNY.io asks if NYCCoin promotion by the Mayor of New York City damaged the market for the xNY digital asset (by, for example, devaluing it through parody or sealed via embossed criticism). 3. xNY.io - Bank.org concerns made above have evidentiary support to interlocking director and officer conflicts recognized by the Department of Justice as potential threats that stifle individual and corporate freedom. Ms. Joseph Varlack, as a matter relating to working at one of the world's most ethical companies, famous for risk management and corporate governance, and as an internationally recognized Blockchain Scholar, I must adhere to federal securities laws. - As such, I classify Mayor Adams as an individual who promoted the digital asset NYCCoin and must disclose the nature, scope, and amount of compensation associated. A failure to disclose this information may violate the anti-touting provisions of the federal securities laws. Mayor Adams' making these endorsements may also be liable for potential violations of the anti-fraud provisions of the federal securities laws, for participating in an unregistered offer and sale of securities, and for acting as unregistered brokers. xNY.io - Bank.org respectfully requests the Office of the Mayor of New York City to respond to this request by Wednesday March, 15 2023 by Noon EST. Respectfully yours with appreciation, 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 +1-917-580-8053

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Fwd: Memo #4 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 16 Feb '25

16 Feb '25

https://docs.google.com/document/d/1ajVVx6NGB9wd2GDXfLRftf0RVFpqjl8WWITvdNV… March 10, 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 #4 - Goldman Sachs Deferred Prosecution Agreement Dear Mr. Marzulli: The Department of Justice has yet to respond to Memo #1, Memo #2 and Memo #3 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 #4 aims to associate the malfeasance in Malaysia with war crimes of aggression (in the planning, initiation, or execution of a large-scale and serious act of aggression), leveraging the world’s only military divided capital city Nicosia, Cyprus. 1. Additionally, Memo #4 aims to earn the DOJ’s assessment of New York State’s regulatory marketplace manipulation deriving the war crime against peace, related to the planning, preparation, initiation, waging or participation in a common plan or conspiracy related to a war of aggression, which can only apply in relation to international armed conflict. 2. In this case, the first challenge is to observe and consider the simple idea that the DOJ’s Deferred Prosecution Agreement with Goldman Sachs alone, through means of regulatory arbitrage naively fails to recognize the ‘cause and effect’ relationship at play at the inception of Memo #4’s assertion of war crimes. 3. Even with the best of intentions, perhaps unknowingly the DOJ may be amplifying the effect of potential war crimes by indirectly supplementing the root cause of the problem and financial model of the Deferred Agreement being self-policing. Mr. Marzulli, there has been an active United Nations peacekeeping mission in Cyprus since the 1964 Turkish military invasion and occupation of the northern third of Cyprus. Only Turkey recognises the Turkish Republic of Northern Cyprus, while there is broad recognition that the ongoing military presence constitutes occupation of territories that are under Turkish military control. - The graduate education behind Memo #4 is a product of the University of Nicosia’s (UNIC) main campus, located adjacent to the United Nations Buffer Zone that separates the invaded Turkish Republic of North Cyprus and the Republic of Cyprus, which joined the European Union in 2004. - Memo #4 is also a product of United Nations consultancy, based at its Manhattan headquarters, where (today, what is now xNY.io - Bank.org) was credited with increasing the breadth and accessibility of reference content from the world’s most important multinational organization. - Memo #4’s subject of war crimes has preeminent association with such projects as the Audio Visual Library of International Law. Over the following sections, Memo #4 will provide a detailed timeline that would constitute real concern of the war crime of aggression yielding the war crime against peace in active war conflict in the world’s only military divided capital, funded from Manhattan Island. The Bank of Cyprus and Illegal Short Selling Irregularities of Turkey’s Markets Mr. Marzulli, turn this matter as we will, and look at it from any side whatsoever, and it presents the appearance of a cross-border act of aggression. Goldman Sachs’ potential disrespect to the Deferred Agreement’s core values has cultivated new crimes that aim to manipulate cross-border war crime regulatory frameworks. - On April 02, 2021 the Financial Times reported that Turkey fined Goldman Sachs over alleged irregularities in short selling, just a week after foreign investors pulled $1.9B from the country’s stock and bond markets. Turkey’s Capital Markets Board said that Goldman Sachs was among 10 securities firms that had placed orders for short selling without proper notification, violating rules enacted previously that temporarily prohibited such transactions. - On April 20, 2021 the CyprusMail (Cyprus’ only English Language daily newspaper) reported Goldman Sachs International acted as Global Coordinators and Dealer Managers in a $330M bond issuance for the Bank of Cyprus. Given the active military conflict in Cyprus, Memo #4 notes that there is one place on the planet you are not supposed to do this sort of thing. Furthermore, the DOJ’s Deferred Agreement with Goldman Sachs may have been tainted with the potential war crime of aggression, risking international peace and the lives of United Nations peacekeepers, while jeopardizing the United States of America’s financial security. Concern of New York Prime Bank Instrument Fraud and Marketplace Manipulation The United States Department of the Treasury warns that Prime Bank Instrument Fraud schemes have attracted significant international attention, since individuals and organizations have lost billions of dollars worldwide. "Prime Bank Instrument Fraud" is the general term given to prime bank fraud schemes that go by many different names. During April 2021, Goldman Sachs could not in good faith (and, plausible deniability) make any reasonable claim of holding a pristine relationship with Turkey’s Central Bank or with Cyprus’ largest financial institutions, given the 1Malaysia Development Berhad scandal and then pending Deferred Prosecution Agreement with the United States of America. - Memo #4 suggests that Goldman Sachs developed a Prime Bank Instrument Fraud program to level out yo-yo market dynamics caused by failed marketplace manipulation exercises in Turkey and Cyprus. - Systematic bank fraud and/or marketplace manipulation of any kind between Turkey and Cyprus could constitute the war crime of aggression. - Furthermore, Memo #4 argues that Goldman Sachs may have tried to bambooze governments in New York, Cyprus and Turkey through regulatory arbitrage loopholes, while Goldman seemingly may have not considered the totality of such actions as war crimes. Turkey has the highest inflation in Europe. It has the second-highest rate of inflation among emerging markets, just behind Argentina. It has the 13th highest inflation rate in the world, ranking it between South Sudan and Nigeria. After Goldman Sachs was fined for illegal stock and bond market short selling by the Turkish government, logic would argue further malfeasance potentially could have been avoided by the DOJ’s 1Malaysia Development Berhad investigation. - On April 15, 2021 CNBC reported that Goldman Sachs (note, the previous section’s milestones of April 02, 2021 and April 20, 2021) crucially removed its bias toward Turkey tightening interest rates. Goldman issued guidance highlighting the fact that the bank thought that, “…the removal of the tightening bias against rising inflation expectations suggests that the TCMB (Turkish Central Bank) now has a more dovish reaction function.” - On August 14, 2021 the CyprusMail reported serious concern among economists about data reporting from the Turkish Statistical Institute. Ahmet Takan, a former official with the office of the Turkish prime minister, acted as a whistle blower, warning that Turkey potentially was manipulating inflation data. - On September 1, 2021 Reuters reported that Goldman Sachs hiked Turkish growth forecasts. Goldman economists issued guidance stating, "Overall, the Turkish economy has been able to grow faster than we thought without a deterioration in its external balances, as the pickup in foreign demand has been very supportive." - On November 30, 2021 Reuters reported that Goldman Sachs trimed Turkey’s 2022 growth forecast. Goldman Sachs' Murat Unur stated, "We think that the GDP figures released today tell us little about the pace of economic activity going forward as the recent sell-off in the Lira is likely to impact economic activity significantly" Mr. Marzulli, the DOJ’s Deferred Prosecution Agreement with Goldman Sachs was signed on October 21, 2021. The timeline of events above do not coincide with terms and conditions of the Deferred Agreement mandated by the United States of America. Furthermore, as an international graduate scholars of the world’s only military divided capital on the planet, xNY.io - Bank.org should be protected from any association of crimes against peace, related to the planning, preparation, initiation, waging or participation in a common plan or conspiracy related to a war of aggression, which can only apply in relation to international armed conflict. War Crimes Against Humanity Mr. Marzulli, xNY.io - Bank.org is concerned that potential breaches to the Deferred Agreement are impacting our global enterprise. Crimes against humanity can be committed in peacetime as well as during an armed conflict. Even a single act could fall under this exclusion ground provided it forms part of a widespread or systematic attack against a civilian population and the act is committed by any person (including a civilian) who had knowledge of the attack and the link of the act to the attack. 1. We are looking to learn more about the DOJ’s approach to assessing any potential breaches to the Deferred Agreement’s mandates as we determine New York State’s role in cross-border bank regulation and corresponding innovation beyond war crimes against humanity. 2. In order to establish whether a war crime or a crime against humanity has been committed, the case officer should consult the relevant international instruments and case law. 3. Crimes against humanity are fundamentally inhumane acts, committed as part of a systematic or widespread attack. Inhumane acts, which could reach this threshold when committed pursuant to or in furtherance of a State or organizational policy (potentially, New York State bank regulation). 4. Persecution against any identifiable group or collectivity on political, racial, national, ethnic, cultural, religious, gender, or other grounds that are universally recognised as impermissible under international law. 5. Furthermore, we have made 28 highlights to the Deferred Agreement providing supporting reference to Memo #4’s overarching premise. xNY.io - Bank.org submits Memo #4 for DOJ consideration of other inhumane acts of a similar character intentionally causing great suffering, or serious injury to body or to mental or physical health. Some crimes against humanity would require an additional specific intent, such as Goldman Sachs willfully disrespecting New York State and/or overall peace and security of the United States of America. Memo #1, Memo #2, Memo #3 and Memo #4 outline instances that correspond with the associated definitions of the potential war crimes abroad and jeopardize the future of bank innovation from New York, at great sacrifice to the Homeland. We hope to learn the DOJ’s approach to comment on Memo #4’s subject matter or, without delay refer these concerns to the International Criminal Court and/or International Court of Justice for comment. 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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SpaceX Interlocking Directors’ Intent to Manipulate Markets
by Gunnar Larson 16 Feb '25

16 Feb '25

Dear Attorney General Letitia James: xNY.io - Bank.org, PBC seeks to earn your esteemed approval to engage the New York False Claims Act under urgent pretences. Today's correspondence marks the first time in history, a self-titled "mafia" (aka, the "PayPal Mafia '') is compelled to answer publicly the decision to manipulate both the New York False Claims Act and the Martin Act against one another. - Madam Attorney General, your leadership approach has historical context <https://www.nytimes.com/2019/12/10/climate/exxon-climate-lawsuit-new-york.h…> to logic and ultimate Exxon Mobil vs. New York State <https://drive.google.com/file/d/1nLp9RIYw8mAh1SRG8E9PMEK94SV-viUN/view?usp=…> case precedent. - xNY.io - Bank.org, PBC research and development notes our hawkish approach to ESG, D&O and LBO innovation. - xNY.io - Bank.org, PBC sees this not a democrat vs. republican concern as Mr. Elon Musk (CEO, SpaceX and Tesla) claims. False pretense to protect free speech are now being debated as party to a $200B pryamid scheme. Ms. James, on May 21, 2022 xNY.io - Bank.org, PBC <https://docs.google.com/document/d/1lv9Wt6y1ld4bNap0z3epIxttEGiP_oVpfxH0GTS…> contacted the SpaceX Corporation with reasonable concern of CEO Musk's intent behind the $44B Twitter LBO. The Orlando Police Pension Fund shared similar concerns to the intent behind Twitter's LBO as illegal. Since, market forces suggest that SpaceX and Tesla directors are part of interlocking directorate, self proclaimed the PayPal Mafia. The racket could waterfall to problem(s) at the New York State Department of Financial Services with Superintendent association to D&O insurance regulation. Ms. James, xNY.io - Bank.org, PBC seeks your office's urgent assessment of this matter. We aim to earn approval to explore the New York False Claims Act to confront SpaceX as a racket. *Like a house of cards, the PayPal Mafia racket could risk a waterfall of D&O interlocking directorate insolvencies. In summary: * 1. xNY.io - Bank.org's May 21, 2022 memo to SpaceX questioned intent behind baseless claims pioneered by SpaceX's CEO, branding ESG a scam via Exxon Mobil. Obviously, Exxon Mobil vs. New York State <https://drive.google.com/file/d/1nLp9RIYw8mAh1SRG8E9PMEK94SV-viUN/view?usp=…> alludes Mr. Musk party to a false claim. 2. SpaceX has failed to establish a preponderance of evidence and burden of proof not a racket. 3. SpaceX has failed to prove that Twitter's LBO is not false claim to free speech protection. 4. True social innovation cannot sponsor a fake news racket that could jeopardize space exploration and war. 5. Twitter's LBO dealmakers (Goldman Sachs and JP Morgan Chase) company balance sheets, financial statements and other corporate records do not impact xNY.io - Bank.org, PBC holding a racket accountable to false claims. The CEO of SpaceX and Tesla leveraging Exxon Mobil as an ESG securities scam does not preclude the PayPal Mafia's intent to engage false claims at the sacrifice of New York State's financial future. Madam Attorney General James, we hope to hear from your esteemed office and learn assessment of best next steps. Thank you, Gunnar -- *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 On Sun, May 22, 2022 at 9:34 AM Gunnar Larson <g(a)xny.io> wrote: > May 21, 2022 > > BY ELECTRONIC MAIL > > SpaceX Corporation > Board of Directors > One Rocket Road > Hawthorne, California > 90250 > Sales(a)SpaceX.com > > Re: Potential SpaceX Interlocking Directors’ Intent to Manipulate > Markets > > Dear SpaceX Board of Directors: > > From our New York headquarters, xNY.io - Bank.org, PBC embodies the notion > that rather than a merry-go-round, the process of change and innovation is > like a slide. > > Today’s memo aims to notify the SpaceX Corporation of concern of potential > market manipulation that could impact cross-border digital asset > innovation, free speech in the United States of America, the global ESG > economy and Moon exploration. > > Please find the attached memo > <https://docs.google.com/document/d/1lv9Wt6y1ld4bNap0z3epIxttEGiP_oVpfxH0GTS…> > addressed to SpaceX's board of directors. > > Respectfully, > > Gunnar Larson >

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MIA Coin and POX Kleptocracy: CORRUPTION FIN-2022-A001 - SAR 38(m).
by Gunnar Larson 16 Feb '25

16 Feb '25

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…>

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Re: response to FOIl request FOIL-2022-090627-018419
by Gunnar Larson 15 Feb '25

15 Feb '25

Dear Mr. Bogdan: Thank you for the note. We would kindly like to appeal this FOIL records decision. For example, One Million Black Women's board of directors states inclusion of policy and social leadership from Apple. Mr. Bogdan, xNY.io - Bank.org has filed another FOIL request concerning DFS' recent "Apple Card Report." The Apple Card Report and associated DFS investigation focused on financial inclusion metrics for women in New York State. Between the Apple Card Report and One Million Black Women being under DFS' umbrell of oversight, it would appear no records being publicly available would signal potential marketplace spoofing. Furthermore, DFS' "Student Protection Unit" licenses and supervises student loan servicers, monitors student-related financial practices in New York, and educates and advocates for student consumers and their families about available financial products and services. As a "Bill and Melinda Gates Scholar" and a "Blockchain Scholar" and a "Al Neuharth Freedom Forum Scholar" I am aware of a scholarship program funded from New York targeting students in Africa. Mr. Bogdan, from New York this fund advertises over $100M in scholarships for online degrees for students in Africa. Logic would conclude DFS' Student Protection Unit would hold records on this scholarship fund. No records would furthrtmore exacerbate spoofing concern of a potential interlocking directorate. At the very least, DFS records pertaining to mail and/or wire fraud related to the department's financial inclusion oversight would be helpful to our research. Have a great day, Gunnar -- *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 On Tue, Nov 1, 2022, 3:24 PM <George.Bogdan(a)dfs.ny.gov> wrote: > Dear Mr. Larson: > > My response to your FOIL request is attached. > > Sincerely, > George Bogdan > DFS Records Access Officer > > Tracking Number:FOIL-2022-090627-018419 >

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Fwd: Funding partnership with CLientEarth
by Gunnar Larson 15 Feb '25

15 Feb '25

... ---------- Forwarded message --------- From: Gunnar Larson <g(a)xny.io> Date: Wed, May 29, 2024, 6:42 AM Subject: Fwd: Funding partnership with CLientEarth To: <cypherpunks(a)cpunks.org> Back in May 2022, xNY.io - Bank.org reached out to ClientEarth.org. Now in May 2024, between UN.org, WorldBank.org and ClientEarth.org, today it is evident that xNY.io - Bank.org is light-years ahead of our peers. We will engage our position in global makets for good for all nations and peoples. Gunnar ---------- Forwarded message --------- From: Support Us <supportus(a)clientearth.org> Date: Tue, May 3, 2022, 10:12 AM Subject: RE: Funding partnership with CLientEarth To: Gunnar Larson <g(a)xny.io> Dear Gunnar. Thank you for wanting to reach and connect with ClientEarth. Unfortunately the team you would need to connect with do not currently have capacity at this time. They will keep your details on file for future and can hopefully connect at a later date. Best wishes. *Kriss Atkin* Development Administration Assistant [image: ClientEarth_lockup_black] t. +44(0)303 050 5991 ClientEarth, The Joinery, 34 Drayton Park, London, N5 1PB [image: cid:image004.png@01D65A06.292F2EF0] *Website* <https://www.clientearth.org/>* | **Facebook* <https://www.facebook.com/ClientEarth>* | **Twitter* <http://www.twitter.com/clientearth>* | **Instagram* <https://www.instagram.com/clientearth_/?hl=en>* | **LinkedIn* <https://www.linkedin.com/company/clientearth> *From:* Gunnar Larson [mailto:g@xny.io] *Sent:* 28 April 2022 13:29 *To:* Support Us <supportus(a)clientearth.org> *Subject:* Re: Funding partnership with CLientEarth Dear Kriss: Thank you for reaching out. Bank.org is working on a project similar to your Shell board dispute. We wanted to reach out and introduce ourselves. Would there be a good time to connect? Thank you, Gunnar -- *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 On Thu, Apr 28, 2022 at 5:35 AM Support Us <supportus(a)clientearth.org> wrote: Dear Gunnar, Thank you so much for getting in touch, we are so grateful that you would like to know more about partnering with ClientEarth. We really appreciate your request, if you can send us details of your proposal we would love to review in line with our corporate partnership policy. Once we have reviewed this opportunity we will contact you again regarding your donation. Please do feel free to let us know of your latest environmental policy or if your company currently holds any environmental ISO certificates, as this would greatly expedite our review process. As you know, ClientEarth works to stop climate change and pollution, protect and restore habitats, wildlife and natural resources, as well as empowering people and promoting the rule of law. If you would like to find out more about our work, you can find the latest news on our website <https://www.clientearth.org/> or you can sign up to our email newsletter <https://www.action.clientearth.org/sign-clientearths-newsletter/?_ga=2.2608…>. Please contact me if you have any further questions or queries and I will be happy to help. Best wishes. *Kriss Atkin* Development Administration Assistant [image: ClientEarth_lockup_black] t. +44(0)303 050 5991 ClientEarth, The Joinery, 34 Drayton Park, London, N5 1PB [image: cid:image004.png@01D65A06.292F2EF0] *Website* <https://www.clientearth.org/>* | **Facebook* <https://www.facebook.com/ClientEarth>* | **Twitter* <http://www.twitter.com/clientearth>* | **Instagram* <https://www.instagram.com/clientearth_/?hl=en>* | **LinkedIn* <https://www.linkedin.com/company/clientearth>

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Re: Inquiry
by Gunnar Larson 15 Feb '25

15 Feb '25

Okay. Thank you for letting me know. Gunnar On Tue, Apr 23, 2024, 8:40 AM Roberta Kaplan <rkaplan(a)kaplanhecker.com> wrote: > I'm sorry, but I don't think we can help you on this. > ------------------------------ > *From:* Gunnar Larson <g(a)xny.io> > *Sent:* Tuesday, April 23, 2024 8:28:27 AM > *To:* Roberta Kaplan <rkaplan(a)kaplanhecker.com> > *Subject:* Re: Inquiry > > You don't often get email from g(a)xny.io. Learn why this is important > <https://aka.ms/LearnAboutSenderIdentification> > This email was sent from outside the Firm. > > Roberta: > > Thank you for your response. > > I wrote this LitigationFinanceJournal.com article back in 2022, now I am > on the other side of it all. > > It is my understanding that the FBI is harassing my business, saying I am > trying to use Donald Trump arguments against the Attorney General's office. > > That is simply not true. I am need to organize a personal attorney to > protect myself from these attacks. I thought it could be beneficial if we > worked together. > > Please let me know your thoughts. > > Thank you, > > Gunnar > --- > > > https://litigationfinancejournal.com/rnc-funding-of-trumps-legal-campaign-u… > > > Litigation Finance Journal recently reported on a group of 14 state > attorneys general that have called for action from the Department of > Justice to review potential threats to U.S. national security from foreign > adversaries’ engagement of litigation investment. Litigation funders and > industry advocates have new ammo in response to the AGs’ claims, given > recent news of the RNC funding former President Donald Trump’s various > legal entanglements. > > > According to ABC News, RNC leaders earmarked $1.6M in legal funding to > support President Donald Trump’s defense over lawsuits brought by New York > Attorney General Letitia James. Meanwhile, the United States Chamber of > Commerce Institute for Legal Reform’s research has prompted 14 state > attorneys general to ask for the Justice Department to assess national > security risks of adversaries ‘undermining’ the United States by engaging > litigation funding and third party investment vehicles. > > The group of 14 state attorneys general are concerned about foreign > adversaries ‘weaponizing’ United States legal frameworks via litigation > investment, to attack critical national industry and infrastructure, such > as energy sectors. The group of 14 seeks the Department of Justice to > detail how a network of federal agencies could engage a blueprint for > defending United States independence from international litigation > investors, hostile groups, agencies or governments such as Russia and China. > > This latest attack on the industry, prompted by the U.S. Chamber of > Commerce, is simply another attempt to undermine the nascent and growing > litigation funding sector. It is ironic, given that in the case of Consumer > Legal Funding–which the Chamber specifically targets–the funding in > question does not go to support legal fees, but rather to finance > claimants’ livelihoods while they remain injured and unable to work. > > While the RNC’s funding of Trump’s legal battles does not constitute > foreign investment, it illustrates the acceptance of third party legal > funding across political lines, and should be noted by industry advocates > looking to respond to the negative publicity put forth by the U.S. Chamber. > > On Tue, Apr 23, 2024, 7:02 AM Roberta Kaplan <rkaplan(a)kaplanhecker.com> > wrote: > > Happy to talk. What is the matter? > ------------------------------ > *From:* Gunnar Larson <g(a)xny.io> > *Sent:* Tuesday, April 23, 2024 3:55:11 AM > *To:* Roberta Kaplan <rkaplan(a)kaplanhecker.com> > *Subject:* Inquiry > > You don't often get email from g(a)xny.io. Learn why this is important > <https://aka.ms/LearnAboutSenderIdentification> > This email was sent from outside the Firm. > > Ms. Kaplan: > > My name is Gunnar Larson and I am a co-founder at xNY.io - Bank.org. > > I was wondering if I could schedule a time to talk with your office > concerning potentially working together on a developing 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 > > ------------------------------ > This email and its attachments may contain information that is > confidential and/or protected from disclosure by the attorney-client, work > product or other applicable legal privilege. If you are not the intended > recipient of the email, please be aware that any unauthorized review, use, > disclosure, dissemination, distribution, or copying of this communication, > or any of its contents, is strictly prohibited. If you have received this > communication in error, please notify the sender immediately and destroy > all copies of the message from your computer system. Thank you. > > ------------------------------ > This email and its attachments may contain information that is > confidential and/or protected from disclosure by the attorney-client, work > product or other applicable legal privilege. If you are not the intended > recipient of the email, please be aware that any unauthorized review, use, > disclosure, dissemination, distribution, or copying of this communication, > or any of its contents, is strictly prohibited. If you have received this > communication in error, please notify the sender immediately and destroy > all copies of the message from your computer system. Thank you. >

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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 15 Feb '25

15 Feb '25

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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Enron’s Board of Directors: Contemporary Lessons on Crypto Marketplace Manipulation Computer Crimes - Crypto Computer Crimes Manual (W/183 Highlights)
by Gunnar Larson 15 Feb '25

15 Feb '25

A few years ago, I wrote an essay titled: "Enron’s Board of Directors: Contemporary Lessons on Crypto Marketplace Manipulation Computer Crimes - Crypto Computer Crimes Manual (W/183 Highlights)" https://thecapital.io/article/crypto-computer-crimes-manual-w183-highlights… Working references on disclosure controls and procedures, as well as strategic initiatives including mergers and acquisitions, joint ventures, and management restructurings (including public/private board of directors). Full, fair, and accurate disclosures from all parties in a battle for corporate influence or control are critically important to investors, particularly when they are called upon to make decisions about their investments. Contemporary crypto computer crimes likely are key considerations relevant to making informed investment decisions by sophisticated investors, underscoring protection of pension assets via keen planning. BitLicense marketplace manipulation techniques and potential cross-border computer crimes has been a major focus of xNY.io's scholar research/innovation communication and Bank.org's business plan execution strategy. The World Bank (WorldBank.org) notes that vulture funds endanger the gains made by debt relief to poorest countries. "The Bank has already delivered more than $40 billion in debt relief to 30 of these countries...thanks to this, countries like Ghana can provide micro-credit to farmers, build classrooms for their children, and fund water and sanitation projects for the poor," wrote World Bank Vice President Danny Leipziger in 2007. World Bank directors warn that strategies adopted by vulture funds divert much needed debt relief away from the poorest countries on earth and into the bank accounts of the wealthy. Bank.org is clear-eyed; microcredit lending fraud is a major issue for developing economies. Likewise, in western developed economies, market history warns that when boards of directors approve of and/or ignore the misuse of computer software programs which compute values based upon data input formulas from active cross-border manipulation structures, the results can lead to scandals like Enron. Such outcomes cost investors billions of dollars when the share prices of affected companies collapse, while also shaking public confidence in the United States securities markets. Enron’s Board of Directors: Contemporary Lessons on Crypto Marketplace Manipulation Computer Crimes In its 2000 review of best corporate boards, Chief Executive Magazine included Enron among its five best boards. Even with its complex corporate governance and network of intermediaries, Enron was still able to "attract large sums of capital to fund a questionable business model, conceal its true performance through a series of accounting and financing maneuvers, and hype its stock to unsustainable levels."On paper, Enron had a model board of directors comprised predominantly of outsiders with significant ownership stakes and a talented audit committee of various state and federal regulators. Two decades later, in 2021, it is clear that cryptocurrency and blockchain computer software systems require contemporary, ethically pure and sound cultivation to support the realization of a "generation of innovation," maximizing the full potential of blockchain software technologies. Board directors that will pioneer the next chapters of the meaningful New York legacy of global, cross-border banking will agree: Close scrutiny of corporate governance and greater responsibility placed on directors to vouch for the reports submitted to the SEC and other federal agencies have resulted in the growth of computer software solutions such as blockchain systems and processes. Cryptocurrency and Blockchain computer software products allow corporate directors and internal auditors to assemble and analyze financial and other relevant data—including unstructured data—and create reporting required by New York BitLicense regulators and various Federal counterparts. Before its demise, Enron was lauded for its sophisticated software, including financial risk management tools powered by computer software. Risk management was crucial to Enron not only because of its regulatory environment, but also because of its business plan. Enron established long-term fixed commitments which needed to be hedged to prepare for the invariable fluctuation of future energy prices. Enron's downfall was attributed to its reckless use of derivatives and special purpose formulas manipulated by computer accounting software tools. To engage in probable computer crimes, Enron hedged its risks with special purpose entities which it owned, and Enron retained the risks associated with the transactions. Enron's aggressive accounting practices were not hidden from the board of directors, as later learned by a Senate subcommittee. The board was informed of the rationale for using the Whitewing, LJM, and Raptor transactions, and after approving them received status updates on the entities' operations. Although not all of Enron's widespread improper accounting practices were revealed to the board, the practices were dependent on board decisions. Eliminating Bad Board of Director Schemes Ranging from additional corporate board responsibilities to criminal penalties, the Securities and Exchange Commission (SEC) implemented disclosure requirements to comply with the law. A recent SEC order reiterated the importance of the disclosures, noting that the requirements were adopted in order to alert the market to large and rapid accumulation of shares that might represent a possible change in corporate control so that shares can be valued accordingly. The SEC order also noted that the requirements were designed to provide an issuer’s management with timely information to appropriately protect its shareholders’ interests (including pension protections). The SEC’s recent enforcement actions relate to disclosure obligations in connection with M&A transactions and fights for corporate control. In 2015, the SEC brought forth a number of similar enforcement actions alleging that filers had failed to update their disclosures after taking steps towards certain plans and proposals. These types of enforcement actions continue to create challenging issues for practitioners, particularly when potential transactions are still in the early stages of planning and preliminary negotiation. The SEC’s historic actions serve as a reminder to investors, including vulture activists, that Schedule 13D violations can result in monetary liability and, in the case of registered funds and investment advisers, can also have other regulatory consequences. Care must be taken to avoid those communications constituting group activities with disclosure consequences. It should be noted that in some cases, coordination among the parties or sharing of information is sufficient to form prompts for disclosure purposes. Intention of Disclosing Crypto Computer Crimes Manual (W/183 Highlights) Published by the Office of Legal Education Executive office for United States Attorneys, the “Prosecuting Computer Crime Manual” has been xNY.io’s reference guide as international scholars researching Crypto Computer Crimes and how to best position corresponding Bank.org business innovation moving forward. The SEC encourages the description of any plans or proposals such as Proof of Burn (PoB) or Short Selling market activities which may relate to or would result in: The acquisition by any person of additional securities of the issuer, or the disposition of securities of the issuer; An extraordinary corporate transaction, such as a merger, reorganization or liquidation, involving the issuer or any of its subsidiaries; A sale or transfer of a material amount of assets of the issuer or any of its subsidiaries; Any change in the present board of directors or management of the issuer, including any plans or proposals to change the number or term of directors or to fill any existing vacancies on the board; Any material change in the present capitalization or dividend policy of the issuer; Any other material change in the issuer's business or corporate structure, including but not limited to, if the issuer is a registered closed-end investment company, any plans or proposals to make any changes in its investment policy for which a vote is required by section 13 of the Investment Company Act of 1940; Changes in the issuer's charter, bylaws or instruments corresponding thereto or other actions which may impede the acquisition of control of the issuer by any person; Causing a class of securities of the issuer to be delisted from a national securities exchange or to cease to be authorized to be quoted in an inter-dealer quotation system of a registered national securities association; A class of equity securities of the issuer becoming eligible for termination of registration pursuant to section 12(g)(4) of the Act; or Any action similar to any of those enumerated above. Below we share 183 highlights to the Computer Crimes Manual 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. https://thecapital.io/article/crypto-computer-crimes-manual-w183-highlights…

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