September 2024 - cypherpunks - lists.cpunks.org

UK Watchdog Thins Out Pension Plan Reporting Rules
by Gunnar Larson 24 Sep '24

24 Sep '24

UK Watchdog Thins Out Pension Plan Reporting Rules <https://www.law360.co.uk/financial-services-uk/articles/1881324?nl_pk=a94fc…> By Martin Croucher The Pensions Regulator said Monday it has scaled back the amount of data that retirement schemes are expected to submit under new funding regulations, which went live this weekend. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/1881324?nl_pk=a94fc…> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/1881324?nl_pk=a94fc…>

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FCA Chair Cleared Over Whistleblower Complaints Handling
by Gunnar Larson 24 Sep '24

24 Sep '24

FCA Chair Cleared Over Whistleblower Complaints Handling <https://www.law360.co.uk/financial-services-uk/articles/1881352?nl_pk=a94fc…> By Joel Poultney Britain's finance watchdog said Monday that its chair had been cleared of wrongdoing over his handling of two whistleblower complaints but that it will strengthen protection for people who sound the alarm after it reviewed its internal policy. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/1881352?nl_pk=a94fc…> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/1881352?nl_pk=a94fc…>

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Re: Bloomberg Presents the Power of AI and Compliance
by Gunnar Larson 24 Sep '24

24 Sep '24

Alexandra: I think there could have been a mistake. Would it be kindly possible for you to check and get back to me? Thank you, Gunnar ✌️ -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Wed, Sep 18, 2024, 4:41 PM Alexandra Huber (BLOOMBERG/ 120 PARK) < ahuber5(a)bloomberg.net> wrote: > Thank you for your interest in our event, "Bloomberg Presents the Power of > AI and Compliance", to take place October 1st. > > We regret to inform you that we will not be able to proceed with your > registration request this time as this event is limited to clients only. > > If you think you've received this message in error, please reach out to us > and we'll be happy to assist you. > > All the best, > Bloomberg Events > Global Marketing Manager | Community, Compliance, and Mobile > 120 Park Avenue, New York, NY > <https://www.google.com/maps/search/120+Park+Avenue,+New+York,+NY?entry=gmai…> > Direct: 646-324-2248 | Tie line: 824-2248 > Email: ahuber5(a)bloomberg.net > >

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Fwd: [EXTERNAL EMAIL] - Fwd: Complaint Referral Form Internet Crime Complaint Center - New York State's Notary Verification System
by Gunnar Larson 23 Sep '24

23 Sep '24

---------- Forwarded message --------- From: FOIPAQUESTIONS(a)FBI.GOV <FOIPAQUESTIONS(a)fbi.gov> Date: Mon, Sep 23, 2024, 12:37 PM Subject: RE: [EXTERNAL EMAIL] - Fwd: Complaint Referral Form Internet Crime Complaint Center - New York State's Notary Verification System To: Gunnar Larson <g(a)xny.io> The FOIPA does not require federal agencies to answer inquiries, create records, conduct research, or draw conclusions concerning queried data. Rather, the FOIPA requires agencies to provide access to reasonably described, nonexempt records. The question posed is not a FOIPA request because it does not comply with the FOIPA and its regulations. Please resubmit your FOIPA request for the specific information you are requesting, rather than asking questions and your request will be forwarded to Initial Processing for review. Information regarding the Freedom of Information Act/Privacy is available at http://www.fbi.gov/foia/. Note: The foipaquestions(a)fbi.gov email address is not the proper submission method for new FOIPA requests. You may submit your request electronically at https://efoia.fbi.gov (available 24 hours a day), or mail it to FBI, Attn: FOIPA Request, 200 Constitution Drive, Winchester, VA 22602-4843 <https://www.google.com/maps/search/200+Constitution+Drive,+Winchester,+VA+2…>. Please be sure to include your contact information, to include complete mailing address, on any correspondence. Respectfully, Public Information Officer FBI - Information Management Division 200 Constitution Drive <https://www.google.com/maps/search/200+Constitution+Drive?entry=gmail&sourc…> Winchester, VA 22602 O: (540) 868-4593 E: foipaquestions(a)fbi.gov Do you have further questions about the FOI/PA process? Visit us at http://www.fbi.gov/foia Please check the status of your request online at https://vault.fbi.gov/fdps-1/@@search-fdps Status updates are performed on a weekly basis. Note: This is a non-emergency email address. If this is an emergency, please call 911 directly. If you need to report a tip for immediate action, please contact FBI Tips at http://tips.fbi.gov/ or reach out to your local field office. *From:* Gunnar Larson <g(a)xny.io> *Sent:* Thursday, September 19, 2024 11:10 AM *To:* FOIPAQUESTIONS <FOIPAQUESTIONS(a)FBI.GOV> *Cc:* cypherpunks <cypherpunks(a)lists.cpunks.org> *Subject:* Re: [EXTERNAL EMAIL] - Fwd: Complaint Referral Form Internet Crime Complaint Center - New York State's Notary Verification System Dear FBI Public Information Officer: The FOIA allows requesters to file an administrative appeal with the agency for any information that was denied in response to a FOIA request. Can you please advise if thr FOIA request should be appealed one of the following reason(s): - the refusal to release a record, either in whole or in part - the determination that a record does not exist or cannot be found - the determination that the record you sought was not subject to the FOIA - the denial of a request for expedited processing the denial of a fee waiver request. Thank you, Gunnar Larson On Fri, Sep 6, 2024, 8:26 AM Gunnar Larson <g(a)xny.io> wrote: Dear FBI Public Information Officer: The FOIA allows requesters to file an administrative appeal with the agency for any information that was denied in response to a FOIA request. Can you please advise if thr FOIA request should be appealed one of the following reason(s): - the refusal to release a record, either in whole or in part - the determination that a record does not exist or cannot be found - the determination that the record you sought was not subject to the FOIA - the denial of a request for expedited processing the denial of a fee waiver request. Thank you, Gunnar Larson On Wed, Sep 4, 2024, 3:05 PM FOIPAQUESTIONS(a)FBI.GOV <FOIPAQUESTIONS(a)fbi.gov> wrote: The FOIPA does not require federal agencies to answer inquiries, create records, conduct research, or draw conclusions concerning queried data. Rather, the FOIPA requires agencies to provide access to reasonably described, nonexempt records. The question posed is not a FOIPA request because it does not comply with the FOIPA and its regulations. Please resubmit your FOIPA request for the specific information you are requesting, rather than asking questions and your request will be forwarded to Initial Processing for review. Information regarding the Freedom of Information Act/Privacy is available at http://www.fbi.gov/foia/. Note: The foipaquestions(a)fbi.gov email address is not the proper submission method for new FOIPA requests. You may submit your request electronically at https://efoia.fbi.gov (available 24 hours a day), or mail it to FBI, Attn: FOIPA Request, 200 Constitution Drive, Winchester, VA 22602-4843 <https://www.google.com/maps/search/200+Constitution+Drive,+Winchester,+VA+2…>. Please be sure to include your contact information, to include complete mailing address, on any correspondence. In an effort to better assist you, what is the FOIA number you received for your request? Respectfully, Public Information Officer FBI - Information Management Division 200 Constitution Drive <https://www.google.com/maps/search/200+Constitution+Drive?entry=gmail&sourc…> Winchester, VA 22602 O: (540) 868-4593 E: foipaquestions(a)fbi.gov Do you have further questions about the FOI/PA process? Visit us at http://www.fbi.gov/foia Please check the status of your request online at https://vault.fbi.gov/fdps-1/@@search-fdps Status updates are performed on a weekly basis. Note: This is a non-emergency email address. If this is an emergency, please call 911 directly. If you need to report a tip for immediate action, please contact FBI Tips at http://tips.fbi.gov/ or reach out to your local field office. *From:* Gunnar Larson <g(a)xny.io> *Sent:* Tuesday, September 3, 2024 2:04 PM *To:* FOIPAQUESTIONS <FOIPAQUESTIONS(a)FBI.GOV> *Cc:* cypherpunks <cypherpunks(a)lists.cpunks.org> *Subject:* Re: [EXTERNAL EMAIL] - Fwd: Complaint Referral Form Internet Crime Complaint Center - New York State's Notary Verification System On Thu, Aug 22, 2024, 7:56 PM Gunnar Larson <g(a)xny.io> wrote: Dear FBI Public Information Officer: The FOIA allows requesters to file an administrative appeal with the agency for any information that was denied in response to a FOIA request. Can you please advise if thr FOIA request should be appealed one of the following reason(s): - the refusal to release a record, either in whole or in part - the determination that a record does not exist or cannot be found - the determination that the record you sought was not subject to the FOIA - the denial of a request for expedited processing the denial of a fee waiver request. Thank you, Gunnar Larson On Thu, Aug 22, 2024, 2:15 PM FOIPAQUESTIONS(a)FBI.GOV <FOIPAQUESTIONS(a)fbi.gov> wrote: The Record/Information Dissemination Section is not an investigative section of the FBI and only processes Freedom of Information/Privacy Act (FOIPA) requests. To report criminal activities please access the FBI’s homepage on the internet at http://www.fbi.gov/. Option 1-Access the ‘CONTACT US’ link at the top and then select the “Submit a Tip on Crime/Terrorism”. The direct link is: http://tips.fbi.gov/. Option 2-Access the ‘CONTACT US’ link at the top and then select the “Report Internet Crime” link, which connects to the ‘Internet Crime Complaint Center’. The direct link is: http://www.ic3.gov/default.aspx. You also have the option of contacting the FBI’s local field office in your area and their contact information is available on the FBI’s homepage which is listed above. Public Information Officer FBI - Information Management Division 200 Constitution Drive <https://www.google.com/maps/search/200+Constitution+Drive?entry=gmail&sourc…> Winchester, VA 22602 O: (540) 868-4593 E: foipaquestions(a)fbi.gov Do you have further questions about the FOI/PA process? Visit us at http://www.fbi.gov/foia Please check the status of your request online at https://vault.fbi.gov/fdps-1/@@search-fdps Status updates are performed on a weekly basis. Note: This is a non-emergency email address. If this is an emergency, please call 911 directly. If you need to report a tip for immediate action, please contact FBI Tips at http://tips.fbi.gov/ or reach out to your local field office. *From:* Gunnar Larson <g(a)xny.io> *Sent:* Thursday, August 22, 2024 10:52 AM *To:* FOIPAQUESTIONS <FOIPAQUESTIONS(a)FBI.GOV> *Cc:* cypherpunks <cypherpunks(a)lists.cpunks.org> *Subject:* [EXTERNAL EMAIL] - Fwd: Complaint Referral Form Internet Crime Complaint Center - New York State's Notary Verification System Dear Madam or Sir: My name is Gunnar Larson and I am a co-founder at xNY.io - Bank.org. On November 3, 2022 I personally made a complaint to IC3 concerning forged notaries (below). The FBI has not responded to this matter. Today I would like to request all FBI records associated with this IC3 complaint, investigation and/or any records of entrapment associated. Sending you the very best. 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 ---------- Forwarded message --------- From: *Gunnar Larson* <g(a)xny.io> Date: Thu, Nov 3, 2022, 7:02 AM Subject: Complaint Referral Form Internet Crime Complaint Center To: cypherpunks <cypherpunks(a)lists.cpunks.org> Complaint Referral Form Internet Crime Complaint Center *Thank you. Your complaint was submitted to the IC3. Please save or print a copy of your complaint before closing this window.This is the only time you will have to make a copy of your complaint.* Victim InformationName: Gunnar LarsonAre you reporting on behalf of a business? NoBusiness Name: Is the incident currently impacting business operations? Age: 30 - 39Address: 406 West 25th StreetAddress (continued): Suite/Apt./Mail Stop: 1RECity: New YorkCounty: Country: United States of AmericaState: New YorkZip Code/Route: 10001Phone Number: 6464549107Email Address: g(a)xny.ioBusiness IT POC, if applicable: Other Business POC, if applicable: Financial Transaction(s)Transaction Type: OtherIf other, please specify: Notary FraudTransaction Amount: 2400.00Transaction Date: 10/6/2022Was the money sent? No ------------------------------ Victim Bank Name: Victim Bank Address: Victim Bank Address (continued): Victim Bank Suite/Mail Stop: Victim Bank City: Victim Bank Country: Victim Bank State: Victim Bank Zip Code/Route: Victim Name on Account: Victim Account Number: ------------------------------ Recipient Bank Name: Recipient Bank Address: Recipient Bank Address (continued): Recipient Bank Suite/Mail Stop: Recipient Bank City: Recipient Bank Country: Recipient Bank State: Recipient Bank Zip Code/Route: Recipient Name on Account: Recipient Bank Routing Number: Recipient Account Number: Recipient Bank SWIFT Code: Description of IncidentProvide a description of the incident and how you were victimized. Provide information not captured elsewhere in this complaint form.Hello: I was hired as a contractor for a online drop shipping company. The firm sent packages to my home address. The shipping manager asked me to retrieve a package by providing a notorized authorization letter. Upon reviewing the authorization letter and searching New York State's notary verification system, it appeared the notary was forged. A copy of the letter may be accessed here: https://drive.google.com/file/d/1Hqzatqez7yWs7ZZq76RBYy2zzi6NiDw9/view?usp=… Below, you will find the exchange with the shipping manager. On October 31 the firm denied payment for employment and has 'gone missing.' Given my personal and professional association with xNY.io - Bank.org I am concerned about being associated with felony notary Fraud. Furthrtmore, xNY.io - Bank.org is party to the Clayton Act and/or an entrapment exercise. Thank you Gunnar Larson 646-454-9107 Which of the following were used in this incident? (Check all that apply.)☑ Spoofed Email☑ Similar Domain☑ Email Intrusion ☐ OtherPlease specify: Other InformationIf an email was used in this incident, please provide a copy of the entire email including full email headers. ---------- Forwarded message --------- From: Dorothy Berry <dorothy.berry(a)dvlemail.com> Date: Fri, Oct 7, 2022, 2:44 PM Subject: Re: 290283 To: Gunnar Larson <g(a)xny.io> I will coordinate with our Legal team regarding this. The authorization letter was given by the customer. --- Kind regards, Dorothy Berry | Manager Shipping Department Direct number:(475) 330-3037 DELTA VISION (DVS Logistics US) 45 Ruby St #3 Norwalk, CT 06850 <https://www.google.com/maps/search/US)+45+Ruby+St+%233+Norwalk,+CT+06850?en…> (888) 559 9329 Mon-Fri 09:00AM-06:00PM EST Sat-Sun Closed ---- On Fri, 07 Oct 2022 14:33:19 -0400 Gunnar Larson <g(a)xny.io> wrote --- No. I won't go present an authorized letter to anyone with a fake notarized stamp on it. Please advise. On Fri, Oct 7, 2022, 1:48 PM Dorothy Berry < dorothy.berry(a)dvlemail.com> wrote: Did you try picking up package and show Authorization letter to them? --- Kind regards, Dorothy Berry | Manager Shipping Department Direct number:(475) 330-3037 DELTA VISION (DVS Logistics US) 45 Ruby St #3 Norwalk, CT 06850 <https://www.google.com/maps/search/US)+45+Ruby+St+%233+Norwalk,+CT+06850?en…> (888) 559 9329 Mon-Fri 09:00AM-06:00PM EST Sat-Sun Closed ---- On Fri, 07 Oct 2022 08:56:52 -0400 Gunnar Larson <g(a)xny.io> wrote --- Ms. Berry: I am having trouble verifying the authentication of the notarized document.. I just left you a message. Please advise best next steps. Thank you, Gunnar On Thu, Oct 6, 2022, 4:33 PM Dorothy Berry <dorothy.berry(a)dvlemail.com> wrote: Good day! Please find the attached file. Thanks. --- Kind regards, Dorothy Berry | Manager Shipping Department Direct number:(475) 330-3037 DELTA VISION (DVS Logistics US) 45 Ruby St #3 Norwalk, CT 06850 <https://www.google.com/maps/search/US)+45+Ruby+St+%233+Norwalk,+CT+06850?en…> (888) 559 9329 Mon-Fri 09:00AM-06:00PM EST Sat-Sun Closed Are there any other witnesses or victims to this incident?Yes.If you have reported this incident to other law enforcement or government agencies, please provide the name, phone number, email, date reported, report number, etc.[No response provided]Check here if this an update to a previously filed complaint: ☐Who Filed the ComplaintWere you the victim in the incident described above? Yes Name: Business Name: Phone Number: Email Address: Digital Signature By digitally signing this document, I affirm that the information I provided is true and accurate to the best of my knowledge. I understand that providing false information could make me subject to fine, imprisonment, or both. (Title 18, U.S.Code, Section 1001) Digital Signature: Gunnar Larson Thank you. Your complaint was submitted to the IC3. Please save or print a copy of your complaint before closing this window. *This is the only time you will have to make a copy of your complaint.*

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492 Highlights to UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants. ____________________
by Gunnar Larson 23 Sep '24

23 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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Wall Street Has Moved Vast Sums of Its Trading to Its Federally-Insured Banks
by Gunnar Larson 23 Sep '24

23 Sep '24

https://wallstreetonparade.com/2024/09/wall-street-has-moved-vast-sums-of-i… By Pam Martens and Russ Martens: September 23, 2024 ~ President Bill Clinton Laughs It Up as He Signs the Repeal of the Glass-Steagall Act, November 12, 1999 President Bill Clinton Laughs It Up as He Signs the Repeal of the Glass-Steagall Act, November 12, 1999 Taxpayer-backstopped federal deposit insurance at commercial banks in the U.S. was never meant to be a get-rich scheme for the wild and voracious appetites of traders on Wall Street. But a quarterly report produced by the federal regulator of national banks – those operating across state lines – shows that vast amounts of trading on Wall Street is now taking place inside the federally-insured commercial banks that are owned by the trading powerhouses on Wall Street: JPMorgan Chase, Goldman Sachs, Citigroup and Bank of America. (Wall Street trading houses have been allowed to own federally-insured banks since the repeal of the Glass-Steagall Act in 1999 under the Wall Street friendly Bill Clinton administration.) For decades, the Office of the Comptroller of the Currency (OCC) has published its “Quarterly Report on Bank Trading and Derivatives Activities.” The reports have shown that the Wall Street megabanks are increasingly moving their trading casinos to operate out of the federally-insured bank they own – which is holding mom and pop deposits for unsuspecting American families. According to the most recent report from the OCC, for the quarter ending March 31, 2024, federally-insured banks in the U.S. reported $4.8 billion in revenues from trading stock (equity). That $4.8 billion represented 37 percent of all stock trading at the bank holding company level, which came in at $13.059 billion for the quarter. Even more eyepopping, federally-insured banks reported revenues of $7.551 billion from foreign exchange trading, which represented 87 percent of all foreign exchange trading at the bank holding company level, which registered a total of $8.638 billion for the first quarter. Why should a federally-insured bank be engaged in trading activities? How is it even legally allowed to do that? According to the Wall Street self-regulator, FINRA, only broker-dealers are allowed to have licensed traders and only licensed supervisors are allowed to oversee this trading. (For background, see our report: Jamie Dimon’s Top Women and Their Missing Licenses.) Or how about the bizarre jump in trading in precious metals inside federally-insured banks, as we reported in 2022: “In just one quarter, precious metals derivatives had soared from $79.28 billion to $491.87 billion. That’s a 520 percent increase in a span of three months….” (See JPMorgan Chase and Citibank Hold 90 Percent of All Gold and Other Precious Metals Derivatives Held by All U.S. Banks.) And that trend in precious metals has continued. According to the most recent OCC report, in the first quarter of 2024, federally-insured banks held $438.60 billion in precious metals contracts. That figure is at least 12 times greater than the amount the same banks held in precious metal contracts in any quarter from 2007 through 2018. The OCC report for the first quarter of this year shows that federally-insured banks generated 48.9 percent of trading revenues at the bank holding company level. Federally-insured banks have generated half or more of all trading revenues at the holding company level in 9 of the past 11 quarters, through the first quarter of this year. (See top chart above from the current OCC report, page 3.) Do the millions of Americans that are depositing their paychecks at the 5,143 branches of Chase Bank that are spread coast to coast have any idea that the OCC reported that this federally-insured banking unit of JPMorgan Chase was sitting on $54 trillion in notional derivative contracts as of March 31, 2024? Do you think these customers know that this same bank used deposits from its federally-insured bank to gamble in derivatives in London 12 years ago and lose $6.2 billion of depositors’ money; get investigated by the FBI as a result; become the target of a Senate Permanent Subcommittee on Investigations’ scathing 300-page report; – all while keeping the same Chairman and CEO, Jamie Dimon, at the helm of the bank for the past 17 years. Do you think the customers of this trading juggernaut are aware that it has admitted to five felony charges brought by the U.S. Department of Justice since 2014, which include money laundering, rigging markets, and being part of a trading cartel? Of course these bank customers don’t know. Ask yourself when was the last time you turned on your evening TV news and heard one word about trading corruption on Wall Street? Quarterly Trading Revenue at Federally-Insured Banks

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NY Mayor Names Seven Judges For State Courts
by Gunnar Larson 23 Sep '24

23 Sep '24

NY Mayor Names Seven Judges For State Courts <https://www.law360.com/newyork/articles/1881167?nl_pk=ac5a3855-e47c-4403-be…> By Jack Rodgers New York City Mayor Eric Adams has appointed seven new judges to the state's civil, criminal and family courts, all of whom bring years of legal expertise, and a deep commitment to public safety and justice, to the bench. Read full article » <https://www.law360.com/newyork/articles/1881167?nl_pk=ac5a3855-e47c-4403-be…> | Save to favorites » <https://www.law360.com/newyork/articles/1881167?nl_pk=ac5a3855-e47c-4403-be…>

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Family Of NY Helicopter Crash Victim Wins $116M Verdict
by Gunnar Larson 23 Sep '24

23 Sep '24

Family Of NY Helicopter Crash Victim Wins $116M Verdict <https://www.law360.com/newyork/articles/1881160?nl_pk=ac5a3855-e47c-4403-be…> By Rachel Scharf A Manhattan jury has held that three aviation companies must pay a total of more than $116 million for negligence and design defects that contributed to a 26-year-old man's death during a sightseeing helicopter crash in New York's East River. Verdict attached | Read full article » <https://www.law360.com/newyork/articles/1881160?nl_pk=ac5a3855-e47c-4403-be…> | Save to favorites » <https://www.law360.com/newyork/articles/1881160?nl_pk=ac5a3855-e47c-4403-be…>

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New York Cannabis Regulator's Chief Equity Officer To Resign
by Gunnar Larson 23 Sep '24

23 Sep '24

New York Cannabis Regulator's Chief Equity Officer To Resign <https://www.law360.com/newyork/articles/1881212?nl_pk=ac5a3855-e47c-4403-be…> By Sam Reisman The chief equity officer of New York's Office of Cannabis Management has announced his imminent resignation from the agency, marking the latest high-profile departure to rock the Empire State's marijuana regulator. Read full article » <https://www.law360.com/newyork/articles/1881212?nl_pk=ac5a3855-e47c-4403-be…> | Save to favorites » <https://www.law360.com/newyork/articles/1881212?nl_pk=ac5a3855-e47c-4403-be…>

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Getting Around ITC Was 'Sneaky,' Judge Tells Caterpillar
by Gunnar Larson 23 Sep '24

23 Sep '24

Getting Around ITC Was 'Sneaky,' Judge Tells Caterpillar <https://www.law360.com/delaware/articles/1880586?nl_pk=8f2e5a76-bb66-462b-a…> By Andrew Karpan A Delaware court has held that Caterpillar owes about $19.5 million in a patent case, citing in part the company's "sneaky" decision to domesticate manufacturing after a setback in a related infringement case at the U.S. International Trade Commission, while also finding that Caterpillar is subject to a rare injunction blocking the sale of some of its road construction machines. Memorandum attached | Read full article » <https://www.law360.com/delaware/articles/1880586?nl_pk=8f2e5a76-bb66-462b-a…> | Save to favorites » <https://www.law360.com/delaware/articles/1880586?nl_pk=8f2e5a76-bb66-462b-a…>

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