August 2024 - cypherpunks - lists.cpunks.org

xNY.io - Bank.org | DOJ Memo #2 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 19 Sep '24

19 Sep '24

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

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Memo #3 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 18 Sep '24

18 Sep '24

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

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Fwd: Memo #4 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 17 Sep '24

17 Sep '24

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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Fwd: Memo #4 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 16 Sep '24

16 Sep '24

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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Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.)
by Gunnar Larson 16 Sep '24

16 Sep '24

Dear Mr. Mazur: Thank you for your email. I was not arrested by the NYPD and am a model New York City resident with a clean record. Are you suggesting that someone else associated to NYCCoin was arrested and that is why the footage is sealed? Mr. Mazur, your letter proclaims, "Accordingly, all associated records related to an arrest which has been sealed under Criminal Procedure Law Section 160.50 are exempted from disclosure; and, absent a notarized authorization from the accused/arrested person, or an unsealing order from the court, any records associated with this incident may not be disclosed." The NYPD has no standing to ask for a notary in exchange for my body camera footage. Please provide the requested body camera footage by May 13, 2024 or it possibly will be essential to seek injunctive relief in California. Warm regards with appreciation, Gunnar Larson ---------- Forwarded message --------- From: FOIL APPEALS <FOILAppeals(a)nypd.org> Date: Fri, May 3, 2024, 2:43 PM Subject: RE: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.) To: Gunnar Larson <g(a)xny.io> Appeal determination attached. Respectfully, [image: Signature New] *CONFIDENTIALITY NOTICE: This email and any attachments may contain confidential and privileged information for the use of the designated recipient(s) named above. If you are not the intended recipient, you are hereby notified that you have received this communication in error and that any review, use or disclosure of it or its contents is prohibited and may violate laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of this communication. Please treat this and all other communications from the New York City Police Department as** LAW ENFORCEMENT SENSITIVE / FOR OFFICIAL USE ONLY.* *From:* Gunnar Larson <g(a)xny.io> *Sent:* Thursday, May 2, 2024 9:30 AM *To:* FOIL APPEALS <FOILAppeals(a)nypd.org>; IABCMDCNTR <IABCMDCNTR(a)nypd.org> *Cc:* letitia.james(a)ag.ny.gov; Harris, Adrienne A (DFS) < Adrienne.Harris(a)dfs.ny.gov>; Reader, Shaun <sreader(a)curtis.com>; cypherpunks(a)cpunks.org *Subject:* Re: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.) You don't often get email from g(a)xny.io. Learn why this is important <https://aka.ms/LearnAboutSenderIdentification> Dear Madam or Sir: The notarized waiver is non-executable to the NYPD given a forged notary matter the FBI is aware of. Furthermore, contact was made with the office of the Attorney General on the forged notary concern. The NYPD has no standing to ask for a notary in exchange for my body camera footage. Please provide the requested body camera footage by May 13, 2024 or it possibly will be essential to seek injunctive relief in California. Warm regards with appreciation, Gunnar Larson On Tue, Mar 26, 2024, 7:33 AM FOIL APPEALS <FOILAppeals(a)nypd.org> wrote: The records responsive to your request are specifically exempted by state or federal statute [§87(2)(a)] in that they have been SEALED pursuant to New York Criminal Procedure Law §160.55. Please provide a notarized waiver (see attached). Respectfully, [image: Signature New] *CONFIDENTIALITY NOTICE: This email and any attachments may contain confidential and privileged information for the use of the designated recipient(s) named above. If you are not the intended recipient, you are hereby notified that you have received this communication in error and that any review, use or disclosure of it or its contents is prohibited and may violate laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of this communication. Please treat this and all other communications from the New York City Police Department as** LAW ENFORCEMENT SENSITIVE / FOR OFFICIAL USE ONLY.* *From:* Gunnar Larson <g(a)xny.io> *Sent:* Tuesday, March 26, 2024 2:49 AM *To:* FOIL APPEALS <FOILAppeals(a)nypd.org> *Cc:* letitia.james(a)ag.ny.gov; Harris, Adrienne A (DFS) < Adrienne.Harris(a)dfs.ny.gov>; cypherpunks(a)cpunks.org *Subject:* Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.) You don't often get email from g(a)xny.io. Learn why this is important <https://aka.ms/LearnAboutSenderIdentification> Hello: This body camera footage is being requested by the individual who is subject to the footage. As such, I am appealing this decision. Gunnar -- Gunnar Larson xNY.io - Bank.org 917-580-8053 ---------- Forwarded message --------- From: <donotreply(a)records.nyc.gov> Date: Mon, Mar 25, 2024, 9:42 AM Subject: [OpenRecords] Request FOIL-2023-056-15960 Closed To: <g(a)xny.io> The New York City Police Department (NYPD) has *closed* your FOIL request FOIL-2023-056-15960 <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960> for the following reasons: - In regard to the document(s) which you requested, I must deny access to these records on the basis of Public Officers Law Section 87(2)(b) as such information, if disclosed, would constitute an unwarranted invasion of personal privacy. - Your request under the Freedom of Information Law (FOIL) is denied because the records you requested are exempt from disclosure under FOIL because they are specifically exempted from disclosure by state or federal statute. Public Officers Law sec. 87(2)(a). - Your request under the Freedom of Information Law (FOIL) is denied on the ground that the records you requested are exempt from disclosure under FOIL because disclosure would constitute an unwarranted invasion of personal privacy. Public Officers Law secs. 87(2)(b) and 89(2)(b). You may appeal the decision to deny access to material that was redacted in part or withheld in entirety by contacting the agency's FOIL Appeals Officer: foilappeals(a)nypd.org <foilappeals(a)nypd.org?subject=FOIL-2023-056-15960%20-%20Appeal> within 30 days. On Fri, Jan 12, 2024, 2:59 AM Gunnar Larson <g(a)xny.io> wrote: 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.

1 6

morning spam / first draft reboot 3? 4? 5?
by Undescribed Horrific Abuse, One Victim & Survivor of Many 15 Sep '24

15 Sep '24

this is a parallel thread for the morning spam thread, alongside: - morning spam - morning spam reboot (where is this? from when message history got corrupt) - mind controlled utopia - hybrid mcboss this is still book 1 first draft.

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XNY.IO - BANK.ORG: 108 Highlights to The U.S. International Development Finance Corporation (DFC) Congressional Budget Justification - Fiscal Year 2025
by Gunnar Larson 14 Sep '24

14 Sep '24

XNY.IO - BANK.ORG: 108 Highlights to The U.S. International Development Finance Corporation (DFC) Congressional Budget Justification - Fiscal Year 2025: https://drive.google.com/file/d/1gNz-SmoUpZdG9XxXlJ2ZUk_npxYK5Nkb/view?usp=… ---- FY 2025 DFC Request Executive Summary Program Budget and Policy Objectives The FY 2025 program budget request of $1,008 million will enable DFC to grow its portfolio by addressing the significant unmet financing needs in priority sectors and regions that align with U.S. development and foreign policy objectives. DFC leverages its resources to unlock private sector growth and contribute to bridging the $40+ trillion infrastructure need in the developing world. Congress created DFC through the BUILD Act in part to offer a better and more sustainable alternative to China’s Belt and Road Initiative (BRI). DFC catalyzes investment from the private sector and empowers developing countries, helping them leverage their own resources—including human capital and commodities—to tackle poverty, accelerate sustainable economic growth for underserved populations, and become stable U.S. trading partners. Unlike the development approach of the People’s Republic of China (PRC), which often burdens countries with unsustainable sovereign debt and projects that are unsuitable for local conditions, DFC’s efforts are directed toward supporting private entities, mobilizing private capital, and building resilient market economies. DFC emphasizes partnership with the private sector and looks for opportunities to support small businesses and underserved communities, with the goal of sustainable growth. DFC’s financing is a cost-effective way to make significant development and strategic impact around the world because DFC’s private investment model allows each dollar of appropriations to go further. In FY 2023, the agency leveraged $622.6 million in program funding to mobilize more than $9.28 billion in support of 132 projects. In three short years since DFC’s inception in FY 2020, the Corporation has achieved 92 percent growth in annual commitments by dollar value and 65 percent growth in the number of projects committed. To remain a competitive alternative to the PRC and other authoritarian governments, DFC will continue to need robust funding in FY 2025 and beyond to counter the aggressive posture that the PRC has taken in emerging markets. The $1,008 million budget request will support a long-term strategy that DFC has developed to focus on five key sectors that help promote vibrant economies, healthy populations, and stable societies. Administrative Expenses DFC requests $245 million for administrative expenses. This level will support necessary staffing and other support costs to advance U.S. development and strategic foreign policy goals. DFC will use the administrative budget to foster an effective and efficient organization, maintain a fiscally responsible agency, and strengthen its portfolio management capacity. Among other priorities, DFC’s FY 2025 funding will support the expansion of DFC’s overseas presence to continue sourcing quality and impactful projects in local markets, increase underwriting capacity to grow DFC’s portfolio, improve monitoring and evaluation of our developmental impact, and scale mission support functions to meet staff growth and the demands of the program. DFC will use administrative resources to attract and retain the skilled and professional workforce needed to achieve its development and foreign policy objectives. DFC will also direct administrative resources toward expanding stakeholder engagement and improving business development. In addition, administrative resources will enable the Corporation to strengthen management and oversight structures, especially for complex and higher value, higher impact transactions, ensuring DFC can manage risks and monitor results in a manner that maximizes the foreign policy and developmental value of its portfolio.

1 1

Re: [crazy][fiction] Second Draft B traffick boss sequel mc dissociation soap
by Undescribed Horrific Abuse, One Victim & Survivor of Many 14 Sep '24

14 Sep '24

“when you moisturize an itching area and your body responds by itching unbearably all over everywhere else like crazy, you know you didn’t give yourself enough comfort and safety after the last bout of torture flashbacks”

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 09 Sep '24

09 Sep '24

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

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Fwd: Inquiry
by Gunnar Larson 09 Sep '24

09 Sep '24

---------- Forwarded message --------- From: Gunnar Larson <g(a)xny.io> Date: Tue, Apr 23, 2024, 8:43 AM Subject: Re: Inquiry To: Roberta Kaplan <rkaplan(a)kaplanhecker.com> Cc: Stephanie Lake <slake(a)kaplanhecker.com> 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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