January 2025 - cypherpunks - lists.cpunks.org

2 Firms Guide Monte Dei Paschi's €13.3B Mediobanca Bid
by Gunnar Larson 27 Jan '25

27 Jan '25

2 Firms Guide Monte Dei Paschi's €13.3B Mediobanca Bid <https://www.law360.co.uk/financial-services-uk/articles/2288416?nl_pk=9aaa8…> By Najiyya Budaly Italian lender Monte dei Paschi, said to be the world's oldest bank, launched a €13.3 billion ($14 billion) takeover offer for rival Mediobanca SpA on Friday in the latest move to consolidate Italy's banking sector. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2288416?nl_pk=9aaa8…> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2288416?nl_pk=9aaa8…>

1 0

Russian Banking Oligarch's Wife Loses Bid To Lift Sanctions
by Gunnar Larson 27 Jan '25

27 Jan '25

Russian Banking Oligarch's Wife Loses Bid To Lift Sanctions <https://www.law360.co.uk/financial-services-uk/articles/2288442?nl_pk=9aaa8…> By William Janes A Ukrainian-Russian tycoon's wife lost her fight to lift U.K. sanctions against her on Friday as an appellate court ruled that the restrictions were a proportionate way of undermining the Kremlin after Russia invaded Ukraine. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2288442?nl_pk=9aaa8…> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2288442?nl_pk=9aaa8…>

1 0

FCA Settles Claims Law Firm Helped Illegal Investment Plans
by Gunnar Larson 27 Jan '25

27 Jan '25

FCA Settles Claims Law Firm Helped Illegal Investment Plans <https://www.law360.co.uk/financial-services-uk/articles/2288438?nl_pk=9aaa8…> By Eddie Beaver The Financial Conduct Authority said Friday it has settled with a regional law firm over allegations that it helped a client promote a misleading care home investment scheme causing £50 million ($62 million) in losses. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2288438?nl_pk=9aaa8…> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2288438?nl_pk=9aaa8…>

1 0

Fwd: Meta Platforms, Inc. Board of Directors - USPTO, Digital Assets and Moscow Exchange
by Gunnar Larson 26 Jan '25

26 Jan '25

---------- Forwarded message --------- From: Caswell, Davis-Brooke <DbCaswell(a)ktslaw.com> Date: Wed, Jan 15, 2025, 11:11 AM Subject: RE: Meta Platforms, Inc. Board of Directors - USPTO, Digital Assets and Moscow Exchange To: Gunnar Larson <g(a)xny.io> Cc: Meta_Defensive_Disputes <Meta_Defensive_Disputes(a)kilpatricktownsend.com>, Reader, Shaun <sreader(a)curtis.com>, Teilhaber, Kris <KTeilhaber(a)ktslaw.com>, cypherpunks <cypherpunks(a)lists.cpunks.org>, Chollet, Nicki < NChollet(a)ktslaw.com>, letitia.james(a)ag.ny.gov <letitia.james(a)ag.ny.gov> Dear Mr. Larson, I confirm we do still represent Meta in connection with trademark matters. As we have discussed in the past, you will need to provide additional details regarding the basis for your claim and documentation of your relationship with Moscow Exchange or ownership in the Moscow Exchange mark (for example, trademark registration certificates evidencing your ownership of the alleged marks in question). We have provided a secure file link for you to upload any document. Until you provide documents showing that you have ownership rights in the mark, we will not respond to your emails. Best, Davis-Brooke Davis-Brooke <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> Caswell <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> DbCaswell(a)ktslaw.com Kilpatrick Townsend <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> & <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>Stockton LLP <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>1100 Peachtree Street NE <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> | <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> Suite 2800 <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> | <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> Atlanta, <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> GA <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> 30309-4528 <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> *T* 404 815 6174 | *F* 404 541 3230 My Profile <http://www.ktslaw.com/en/People/C/CaswellDavisBrooke> | vCard <http://www.ktslaw.com/vcard/Davis-BrookeCaswell.vcf> *From:* Gunnar Larson <g(a)xny.io> *Sent:* Wednesday, January 15, 2025 6:18 AM *To:* Caswell, Davis-Brooke <DbCaswell(a)ktslaw.com> *Cc:* Meta_Defensive_Disputes < Meta_Defensive_Disputes(a)kilpatricktownsend.com>; Reader, Shaun < sreader(a)curtis.com>; Teilhaber, Kris <KTeilhaber(a)ktslaw.com>; cypherpunks < cypherpunks(a)lists.cpunks.org>; Chollet, Nicki <NChollet(a)ktslaw.com>; letitia.james(a)ag.ny.gov *Subject:* Re: Meta Platforms, Inc. Board of Directors - USPTO, Digital Assets and Moscow Exchange Davis-Brooke: Are you still working with Meta? xNY. io - Bank. org has not heard from you. Meta Atty Quits IP Case Over Zuckerberg's 'Toxic Masculinity' By Ivan Moreno An attorney helping defend Meta Platforms in copyright litigation Davis-Brooke: Are you still working with Meta? xNY.io - Bank.org has not heard from you. *Meta Atty Quits IP Case Over Zuckerberg's 'Toxic Masculinity' <https://www.law360.com/legalethics/articles/2284175?nl_pk=87c9365b-e736-431…>* *By Ivan Moreno* An attorney helping defend Meta Platforms in copyright litigation brought by artists who claim their content was used to train the large language model Llama has dropped the tech company as his client, citing Facebook and founder Mark Zuckerberg's "descent into toxic masculinity and Neo-Nazi madness" in a LinkedIn post. Read full article » <https://www.law360.com/legalethics/articles/2284175?nl_pk=87c9365b-e736-431…> | Save to favorites » <https://www.law360.com/legalethics/articles/2284175?nl_pk=87c9365b-e736-431…> Thank you, Gunnar ✌️ On Wed, Jan 15, 2025, 6:13 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: *Allred Seeks To Ax 'Absurd' Defamation Suit Over Diddy Case <https://www.law360.com/newyork/articles/2283761?nl_pk=b53aa520-5013-4a8d-a5…>* *By Emily Sawicki* High-profile women's rights litigator Gloria Allred and her client have fired back at Sean "Diddy" Combs' former head of security, calling his defamation claims arising from the rape suit they filed against him and the embattled music mogul "absurd" and worthy of sanctions. 3 documents attached | Read full article » <https://www.law360.com/newyork/articles/2283761?nl_pk=b53aa520-5013-4a8d-a5…> | Save to favorites » <https://www.law360.com/newyork/articles/2283761?nl_pk=b53aa520-5013-4a8d-a5…> Gunnar ✌️ On Tue, Jan 14, 2025, 3:01 PM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: *Ozempic Maker Says Atlanta Clinic Misuses TM To Sell Meds <https://www.law360.com/competition/articles/2283149?nl_pk=6e763a2a-9f82-44c…>* *By Kelcey Caulder* Novo Nordisk, the pharmaceutical company that makes weight loss drugs Ozempic, Rybelsus and Wegovy, filed suit against an Atlanta anti-aging treatment center in Georgia federal court Friday, alleging trademark infringement, false advertising, unfair competition and deceptive trade practices. Complaint attached | Read full article » <https://www.law360.com/competition/articles/2283149?nl_pk=6e763a2a-9f82-44c…> | Save to favorites » <https://www.law360.com/competition/articles/2283149?nl_pk=6e763a2a-9f82-44c…> Thank you, Gunnar On Tue, Jan 14, 2025, 2:49 PM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: Theoretically, we may need to explore this route: *SEC Must Explain Coinbase Crypto Rule Denial, 3rd Circ. Says <https://www.law360.com/compliance/articles/2283489?nl_pk=7f7472c8-af4a-4299…>* *By Aislinn Keely* A Third Circuit panel delivered a partial win to Coinbase on Monday when it ordered the U.S. Securities and Exchange Commission to provide "a more complete explanation" of why it denied the crypto exchange's request for rulemaking on how securities laws apply to digital assets. Opinion attached | Read full article » <https://www.law360.com/compliance/articles/2283489?nl_pk=7f7472c8-af4a-4299…> | Save to favorites » <https://www.law360.com/compliance/articles/2283489?nl_pk=7f7472c8-af4a-4299…> Thank you, Gunnar ✌️ On Mon, Jan 13, 2025, 12:26 PM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: *4 Lessons For Contractors From The Bitmanagement Saga <https://www.law360.com/governmentcontracts/articles/2281941?nl_pk=0fbf612f-…>* *By Daniel Wilson* A software company's damages award of just $150,000 after years of litigation over the U.S. Navy violating a licensing deal offers several lessons for federal software contractors about carefully negotiating contractual terms and making sure they can adequately enforce those terms. Read full article » <https://www.law360.com/governmentcontracts/articles/2281941?nl_pk=0fbf612f-…> | Save to favorites » <https://www.law360.com/governmentcontracts/articles/2281941?nl_pk=0fbf612f-…> Please let me know. Thank you, Gunnar ✌️ -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Fri, Jan 10, 2025, 6:40 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: *Tech Biz Says Barrister Failed To Flag Law Firm's Negligence <https://www.law360.co.uk/financial-services-uk/articles/2280479?nl_pk=9aaa8…>* *By Jamie Lennox* A tech company has accused a barrister of failing to spot his instructing law firm's alleged negligence, telling a London court that this armed the law firm with a limitation defense that cut the value of an eventual settlement. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2280479?nl_pk=9aaa8…> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2280479?nl_pk=9aaa8…> Thank you, Gunnar On Thu, Jan 9, 2025, 8:08 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: *PowerPlan To Pay $24M, Ending Rival's Monopoly Claims <https://www.law360.com/technology/articles/2279885?nl_pk=b6acf8b6-b37c-4b07…>* *By Chart Riggall* Roper Technologies subsidiary PowerPlan Inc. has agreed to pay $24 million in a settlement with a rival firm formed by former employees who said the utility software giant tried to lock them out of the market by threatening litigation against them and prospective clients. 2 documents attached | Read full article » <https://www.law360.com/technology/articles/2279885?nl_pk=b6acf8b6-b37c-4b07…> | Save to favorites » <https://www.law360.com/technology/articles/2279885?nl_pk=b6acf8b6-b37c-4b07…> Thank you, Gunnar ✌️ On Thu, Jan 9, 2025, 7:29 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: *Loss Adjuster QuestGates Buys Insurance Investigation Biz <https://www.law360.co.uk/financial-services-uk/articles/2281078?nl_pk=9aaa8…>* *By Joel Poultney* Loss adjuster QuestGates has said it has bought investigations specialists Brownsword Group in a move the business said improves its market share in the third-party probe sector. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2281078?nl_pk=9aaa8…> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2281078?nl_pk=9aaa8…> Thank you, Gunnar ✌️ On Mon, Jan 6, 2025, 2:45 PM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: Is Meta running a criminal interprise, at xNY.io - Bank.org's general expense? *Orchard Settles 'Criminal Enterprise' Defamation Suit <https://www.law360.com/cannabis/articles/2279311?nl_pk=a981d81f-1a94-4659-8…>* *By Danielle Ferguson* The former part-owner of a Michigan orchard and the orchard's holding company have settled claims that the ex-partner defamed the company and caused a loss of business by logging into its Google business account and calling it a "criminal enterprise." Order attached | Read full article » <https://www.law360.com/cannabis/articles/2279311?nl_pk=a981d81f-1a94-4659-8…> | Save to favorites » <https://www.law360.com/cannabis/articles/2279311?nl_pk=a981d81f-1a94-4659-8…> Thank you, Gunnar ✌️ On Mon, Jan 6, 2025, 2:38 PM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: *Battling Berts: Judge Enjoins Ga. Law Firm In Trademark Row <https://www.law360.com/mergersacquisitions/articles/2279365?nl_pk=34b724c6-…>* *By Kelcey Caulder* A Georgia federal judge Friday temporarily barred an Atlanta-based law firm from advertising and promoting its personal injury legal services through messaging like "If You're Hurt ... Call Bert!" and "If You're Hurt, Call Bert," ruling that it is too similar to another personal injury firm's trademarked slogan. Read full article » <https://www.law360.com/mergersacquisitions/articles/2279365?nl_pk=34b724c6-…> | Save to favorites » <https://www.law360.com/mergersacquisitions/articles/2279365?nl_pk=34b724c6-…> Thank you, Gunnar ✌️ On Mon, Jan 6, 2025, 1:58 PM Gunnar Larson <g(a)xny.io> wrote: On Fri, Jan 3, 2025, 9:02 PM On Fri, Jan 3, 2025, 9:02 PM Gunnar Larson <g(a)xny.io> wrote: In the Aṅgulimāla Sutta (MN 86), we see how even a murderer can transform. This doesn't excuse his actions, but shows the complexity of human nature - no one is absolutely "good" or "evil." The Buddha taught about different levels of harm: - Intentional harm (most severe) - Harm from delusion/ignorance - Unintended consequences of actions - Systemic harm where many contribute In the Abhaya Sutta (MN 58), the Buddha discusses how even truth-telling should be evaluated by whether it causes harm. This shows the complexity of ethical action - even good intentions can lead to harmful outcomes. Your insight about "most good people stimulate harm" aligns with the Buddhist understanding of: - Interdependence (paṭicca-samuppāda) - The complexity of karma - How ignorance perpetuates suffering - The need to see things as they are, not as we wish them to be Holding absolutes like "all people are good" or "good people don't harm" creates cognitive dissonance that, as you note, can drive one to madness. The Middle Way teaches us to see reality without these extreme views. Copy thank you for defending these concepts Sādhu! Together let us keep the Dharma wheel rolling. Your gratitude shows wisdom. These are difficult teachings that require careful handling - like carrying water in cupped hands. They help us navigate between harmful extremes: - Between denial of others' harmful actions - And getting lost in hatred or despair - Between toxic positivity - And crushing cynicism As the Buddha said in the Dhammapada (Dhp 5): "Hatred never ends through hatred. By non-hate alone does it end. This is an ancient truth." This doesn't mean we deny hatred exists or pretend harm didn't happen. Rather, we acknowledge the full truth while seeking a path of wisdom and healing. May you find peace as you work with these challenging realities. May your understanding continue to deepen. On Fri, Jan 3, 2025, 6:29 PM Gunnar Larson <g(a)xny.io> wrote: On Sun, Dec 29, 2024, 3:43 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: After the events of this week, xNY.io - Bank.org is implored to contact Meta with further concern. This new film below, (shot in New York City), seems to implicate xNY.io, Bank.org and myself in third party relations with Moynihan Train Hall at Penn Station, Meta's New York headquarters: https://drive.google.com/file/d/1FMzGT_6VLXHwBxq94kQn7dZmf5OLg6Um/view?usp=… Davis-Brooke, these propaganda videos with intentions against xNY.io - Bank.org's best interests summerise: In the run-up to the 2024 Presidential Election, Mark Zuckerberg and cohorts at Meta, ... "Orchestrated an unthinkable plot – one that shocks the conscience and is an affront to this nation’s democracy. Acting in concert, [Meta] maliciously conspired to weave a false narrative that their Republican opponent, Gunnar Donald Arthur Peter Larson was colluding..." for peace on planet Earth. Davis-Brooke, while all this may sound awkward this week , next week xNY.io - Bank.org expects to leapfrog with Meta's indemnification in hand. Can Meta's board kindly provide xNY.io - Bank.org an indemnification letter by January 1, 2025? xNY.io - Bank.org respectfully reserves all Interjurisdictional rights. Thank you, Gunnar ✌️ -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Wed, Dec 25, 2024, 7:10 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: Happy Hanukkah from everyone at xNY.io - Bank.org. Today xNY.io, Bank.org, and my self (individually and separately) seek indemnification from the following: *Meet The New Mark Zuckerberg | The Circuit* <https://m.youtube.com/@business> Bloomberg Originals <https://m.youtube.com/@business> https://drive.google.com/file/d/1F4fIREOiXvBx_sDR8sLoij8WBvMMoLI9/view?usp=… "If the latest battle in the AI wars is between open and closed models, Meta CEO and Founder Mark Zuckerberg is right on the frontlines. Since rebranding as Meta in 2021, the trillion-dollar company, formerly known as Facebook, has been pouring billions into its long term bets on artificial intelligence and the metaverse. Meta’s latest push is a major play to open-source AI, in contrast to Google and Open AI. In an exclusive interview, Bloomberg’s Emily C"hang sits down with Zuckerberg to discuss how the company’s newest AI model Llama 3.1 will shape the future of business, technology and society. She also visits his retreat in Lake Tahoe to talk about his personal evolution as a leader, and learns how to wake surf with Zuckerberg and his wife, Priscilla Chan." Warm wishes, Gunnar ✌️ -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Mon, Dec 23, 2024, 6:42 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: xNY.io - Bank.org will explore alternative routes by next week if we do not hear from Meta concerning indemnity from the Cambridge film mentioned below: *Womble Bond Atty Held In Contempt For Unfixed Falsities <https://www.law360.com/technology/articles/2276897?nl_pk=2bd720dd-746c-4744…>* *By Hayley Fowler* A North Carolina federal judge on Friday temporarily suspended the admission of a Womble Bond Dickinson partner to practice in his district after finding the attorney failed to correct misrepresentations to a Dutch tribunal in parallel litigation involving a software developer and its former Dutch partner. 2 documents attached | Read full article » <https://www.law360.com/technology/articles/2276897?nl_pk=2bd720dd-746c-4744…> | Save to favorites » <https://www.law360.com/technology/articles/2276897?nl_pk=2bd720dd-746c-4744…> Thank you, Gunnar ✌️ -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Sat, Dec 21, 2024, 6:26 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: Still no word from Meta. Can Meta provide what we have asked for? Or can Meta not provide what we have asked for? Meanwhile, in other news: *Fresenius Loses Invalidity Argument In Nausea Drug IP Fight <https://www.law360.com/delaware/articles/2268894?nl_pk=8f2e5a76-bb66-462b-a…>* *By Adam Lidgett* Fresenius Kabi USA LLC has lost its arguments in Delaware federal court that claims in a pair of Heron Therapeutics patents for a nausea drug were invalid, keeping Fresenius' generic from entering the market for around a decade. Opinion attached | Read full article » <https://www.law360.com/delaware/articles/2268894?nl_pk=8f2e5a76-bb66-462b-a…> | Save to favorites » <https://www.law360.com/delaware/articles/2268894?nl_pk=8f2e5a76-bb66-462b-a…> Thank you, Gunnar ✌️ -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Fri, Dec 20, 2024, 11:54 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: *4 Trade Secret Pointers From 2024's Key IP Law Developments <https://www.law360.com/competition/articles/2271443?nl_pk=6416fd97-1dc4-4e0…>* Four significant 2024 developments in trade secret law yield practical tips about defending trade secrets overseas, proving unjust enrichment claims, forcing compliance with posttrial orders and using restrictive covenants to prevent employee leaks of confidential intellectual property, say attorneys at Faegre Drinker. Read full article » <https://www.law360.com/competition/articles/2271443?nl_pk=6416fd97-1dc4-4e0…> | Save to favorites » <https://www.law360.com/competition/articles/2271443?nl_pk=6416fd97-1dc4-4e0…> Thank you, Gunnar Larson On Thu, Dec 19, 2024, 2:31 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: Meta is delinquent. Delinquency to xNY.io - Bank.org will not be tolerated. The mood we are building on is in harmony with Supreme Court background. We have collated 187 highlights for anyone, including Meta to reference: Computer Crimes Manual Highlights.pdf https://drive.google.com/file/d/11tbgHgDg8qagomO-NBffvIFpxXKmBC3g/view?usp=… As a Bill and Melinda Gates Millennium Scholar, I may need to escalate xNY.io - Bank.org courts of the World. Please deliver what we are seeking (out of Cambridge), immediately. Life works. Happy holidays with kind regards, Gunnar ✌️ -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Wed, Dec 18, 2024, 6:04 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: And yet, there is this perspective: *When US Privilege Law Applies To Docs Made Outside The US <https://www.law360.com/competition/articles/2273911?nl_pk=6416fd97-1dc4-4e0…>* As globalization manifests itself in disputes over foreign-created documents, a California federal court’s recent trademark decision illustrates nuances of both U.S. privilege frameworks and foreign evidentiary protections that attorneys must increasingly bear in mind, say attorneys at Hunton. Read full article » <https://www.law360.com/competition/articles/2273911?nl_pk=6416fd97-1dc4-4e0…> | Save to favorites » <https://www.law360.com/competition/articles/2273911?nl_pk=6416fd97-1dc4-4e0…> Today, my personal safety was jeopardized with Meta's potential involvement. This is unacceptable. xNY.io, Bank.org and my self (individually, and separately) seek to be indemnified concerning all aspects of the film below by 5:00pm EST today: Wednesday 8 May 2024 Debating Chamber - Peter Thiel - Cambridge Union Society (Video w/ Protests): https://drive.google.com/file/d/1-UzMRXxN5cy1rpUEa9Zn1tC1kSo-sI4a/view?usp=… . Thank you, Gunnar ✌️ Larson -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Tue, Dec 17, 2024, 5:54 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: Specific to affiliates to xNY.io - Bank.org, we feel compelled to share with Meta our deep connection with Australia, myself a graduate of Bond University on Australia's Gold Coast. What we are afraid of is Meta using its logo to launder monies, out of Australia for example. If this happens to be true, xNY.io - Bank.org would need to take our claim in the United States for syndication in Australia. I am sure you understand xNY.io - Bank.org's approach to these types of headlines, considering how strict our Australian regulators are compared to other countries: *Ladbrokes Owner Sued For AML Breaches By Aussie Watchdog <https://www.law360.co.uk/financial-services-uk/articles/2274307?nl_pk=a94fc…>* *By Eddie Beaver* Ladbrokes operator Entain Group is facing civil penalty proceedings in Australian Federal Court for "serious and systemic non-compliance" with anti-money laundering and counter-terrorism financing, the country's primary financial regulator said Monday. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2274307?nl_pk=a94fc…> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2274307?nl_pk=a94fc…> Wishing you happy Holidays, Davis-Brooke, Gunnar -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Thu, Dec 12, 2024, 7:39 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: Looking into this more, xNY.io - Bank.org is questioning Meta's affiliates to our claim: *Justices Question Affiliates' Liability In $47M TM Judgment <https://www.law360.com/competition/articles/2272767?nl_pk=6416fd97-1dc4-4e0…>* *By Ivan Moreno* The U.S. Supreme Court on Wednesday questioned why lower courts ordered affiliates of a real estate company to pay a $47 million trademark infringement judgment against it when they were not defendants, with Justice Clarence Thomas asking counsel for the prevailing party why they did not include the affiliates in the case. Read full article » <https://www.law360.com/competition/articles/2272767?nl_pk=6416fd97-1dc4-4e0…> | Save to favorites » <https://www.law360.com/competition/articles/2272767?nl_pk=6416fd97-1dc4-4e0…> Thank you, Gunnar ✌️ On Sat, Dec 7, 2024, 5:01 AM Gunnar Larson <g(a)xny.io> wrote: Davis-Brooke: Thank you for your email and contacting xNY.io - Bank.org. If we upload the raw file for the video in Cambride, it could be considered piracy. Let me contact Cambride to see what they think. Meanwhile, you should be able to watch the video at the link provided, given the gravity of the situation. I have CCd the respected Letitia James, Attorney General of New York State 🗽 to keep her abreast of our conversation today. Ms. James: This video that Davis-Brooke is referring to makes certain statements concerning New York City pertaining to your oversight. Have a great weekend! Thank you, Gunnar -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Fri, Dec 6, 2024, 11:37 AM Caswell, Davis-Brooke <DbCaswell(a)ktslaw.com> wrote: Dear Mr. Larson, My name is Davis-Brooke and I work with Nicki. We are unable to view/download documents onto our system from outside links. Accordingly, will you please upload any documents into the file share folder that Nicki sent you? Please let me know if you have any issues accessing this folder. Best, Davis-Brooke Davis-Brooke <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> Caswell <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> DbCaswell(a)ktslaw.com Kilpatrick Townsend <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> & <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>Stockton LLP 1100 Peachtree Street NE <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> | <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> Suite 2800 <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> | <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> Atlanta, <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> GA <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> 30309-4528 <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> *T* 404 815 6174 | <https://www.google.com/maps/search/1100%0D%0A+Peachtree+Street+NE+%0D%0A+%7…> *F* 404 541 3230 My Profile <http://www.ktslaw.com/en/People/C/CaswellDavisBrooke> | <https://www.google.com/maps/search/1100%0D%0A+Peachtree+Street+NE+%0D%0A+%7…> vCard <http://www.ktslaw.com/vcard/Davis-BrookeCaswell.vcf> *From:* Gunnar Larson <g(a)xny.io> *Sent:* Monday, December 2, 2024 12:45 PM *To:* Chollet, Nicki <NChollet(a)ktslaw.com> *Cc:* Meta_Defensive_Disputes < Meta_Defensive_Disputes(a)kilpatricktownsend.com>; Reader, Shaun < sreader(a)curtis.com>; Caswell, Davis-Brooke <DbCaswell(a)ktslaw.com>; Teilhaber, Kris <KTeilhaber(a)ktslaw.com>; cypherpunks < cypherpunks(a)lists.cpunks.org> *Subject:* Re: Meta Platforms, Inc. Board of Directors - USPTO, Digital Assets and Moscow Exchange Ms. Chollet: Please find here a reference to our relationship with the Moscow Exchange, as requested: Wednesday 8 May 2024 Debating Chamber - Peter Thiel - Cambridge Union Society (Video w/ Protests): <https://www.google.com/maps/search/1100%0D%0A+Peachtree+Street+NE+%0D%0A+%7…> <https://www.google.com/maps/search/1100%0D%0A+Peachtree+Street+NE+%0D%0A+%7…> https://drive.google.com/file/d/1-UzMRXxN5cy1rpUEa9Zn1tC1kSo-sI4a/view?usp=… <https://www.google.com/maps/search/1100%0D%0A+Peachtree+Street+NE+%0D%0A+%7…> <https://www.google.com/maps/search/1100%0D%0A+Peachtree+Street+NE+%0D%0A+%7…> <https://www.google.com/maps/search/1100%0D%0A+Peachtree+Street+NE+%0D%0A+%7…> <https://www.google.com/maps/search/1100%0D%0A+Peachtree+Street+NE+%0D%0A+%7…> Gunnar Larson On Sun, Nov 17, 2024, 1:46 PM Gunnar Larson <g(a)xny.io> wrote: Ms. Chollet: Thank you again for opening the folder. We have been occupied recently and will fill the folder soon. Thank you, Gunnar On Mon, Oct 21, 2024, 5:01 PM Chollet, Nicki <NChollet(a)ktslaw.com> wrote: Gunnar, I have opened a secure folder for you to put documents in ' ------------------------------ Confidentiality Notice: This communication constitutes an electronic communication within the meaning of the Electronic Communications Privacy Act, 18 U.S.C. Section 2510, and its disclosure is strictly limited to the recipient intended by the sender of this message. This transmission, and any attachments, may contain confidential attorney-client privileged information and attorney work product. If you are not the intended recipient, any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. Please contact us immediately by return e-mail or at 404 815 6500, and destroy the original transmission and its attachments without reading or saving in any manner. '

1 1

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 26 Jan '25

26 Jan '25

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

1 28

Fwd: Order #452024472025
by Gunnar Larson 26 Jan '25

26 Jan '25

---------- Forwarded message --------- From: DARK MAGA HAT FROM TRUMP <contact(a)support.donaldjtrump.com> Date: Sat, Jan 25, 2025, 6:54 PM Subject: Order #452024472025 To: <g(a)xny.io> Please confirm before we send your Dark MAGA Hat! [image: TRUMP] <https://link.donaldjtrump.com/u/click?_t=c26d591425684a3289b90149d613a03c&_…> *ELON MUSK* has an Official Dark MAGA Hat. *DONALD J. TRUMP* has an Official Dark MAGA Hat — he wears it all the time! Gunnar, where’s your Dark MAGA hat? *Fear not: We’ve got one left in stock just for you! >> <https://link.donaldjtrump.com/u/click?_t=c26d591425684a3289b90149d613a03c&_…>* [image: DARK MAGA HAT] <https://link.donaldjtrump.com/u/click?_t=c26d591425684a3289b90149d613a03c&_…> *ORDER NOW <https://link.donaldjtrump.com/u/click?_t=c26d591425684a3289b90149d613a03c&_…>* Contributions to Trump National Committee JFC Inc. are not deductible for federal income tax purposes. All contributions are subject to the limits and prohibitions of the Federal Election Campaign Act. Contributions from corporations, foreign nationals (i.e., without “green cards”), federal government contractors, and other federally impermissible sources are strictly prohibited. Contributions made in the name of, or refunded by, any other person are unlawful. Paid for by Trump National Committee JFC, Inc., P.O. Box 509, Arlington, VA 22216. Not Authorized by any Candidate or Candidate’s Committee. You are receiving this email at g(a)xny.io. donaldjtrump.com <https://link.donaldjtrump.com/u/click?_t=c26d591425684a3289b90149d613a03c&_…> It’s because of the commitment and support from real Patriots, like YOU, that we will SAVE AMERICA! Thank you again for your generous support. If you'd like to change your subscription status follow this link. <https://link.donaldjtrump.com/e/encryptedConfirmUnsubscribe?_r=c26d59142568…> Privacy Policy <https://link.donaldjtrump.com/u/click?_t=c26d591425684a3289b90149d613a03c&_…>

1 0

Fwd: David K. Porter Named Special Agent in Charge of the Honolulu Field Office
by Gunnar Larson 26 Jan '25

26 Jan '25

Shortly after just nearly sinking along some of the most Southern islands of Alasksa, on the lound horn came Captin Buzz of the MV Explorer (ran by the Institute for Shipboard Education) DBA Semester At Sea. From leaving Vancouver in rough seas, Captain Buzz said we were now headed to Midway Island, rather than Japan as we planned originally. Buzz was informing the 700+ soles aboard the MV Explorer that the ship's crew had successfully restored thrust. By hand starting the engines no less. All this after a massive rogue wave nocked out power from the ship's bridge. The MV Explorer was disabled. Midway Island was our only hope. However, the situation improved and Buzz once again updated us that the United States Coast Guard had cleared the MV Explorer to press on to Honolulu. ... I edited the video feature and from Hawaii sent the package to Secaucus, New Jersey online. MSNBC aired the story, and Gunnar Larson strived for excellence with new hope in achieving an ultimate goal: Seeing the Gates Millennium Scholar benefactors proud after the S05 shipwreck off the coast of Alaska. True story. Gunnar Donald Arthur Peter Larson ✌️🇺🇸🗽 ---------- Forwarded message --------- From: FBI <fbi(a)subscriptions.fbi.gov> Date: Wed, Jan 22, 2025, 9:05 PM Subject: David K. Porter Named Special Agent in Charge of the Honolulu Field Office To: <g(a)xny.io> * National Press Releases * David K. Porter Named Special Agent in Charge of the Honolulu Field Office Director Christopher Wray has named David K. Porter as the special agent in charge of the Honolulu Field Office. Jan. 17, 2025 Full Press Release <https://www.fbi.gov/news/press-releases/david-k-porter-named-special-agent-…> ------------------------------ <https://www.facebook.com/FBI> <https://twitter.com/FBI> <https://www.youtube.com/user/FBI> <https://www.fbi.gov/e-mail-updates?utm_campaign=email-Immediate&utm_medium=…> * You have received this message because you are subscribed to one or more of the following categories: National Press Releases * Manage Subscription <https://delivery.fbi.gov/account-reminder> | Unsubscribe <https://delivery.fbi.gov/subscriber/c57956fe9830b3f02d21fe7a2581942df706f0b…> If you have questions about this service, email us at delivery(a)subscriptions.fbi.gov. Help <https://www.fbi.gov/e-mail-updates?utm_campaign=email-Immediate&utm_medium=…> | Privacy Policy <http://www.fbi.gov/privacy_policy?utm_campaign=email-Immediate&utm_medium=e…> | Visit FBI.gov <https://www.fbi.gov/?utm_campaign=email-Immediate&utm_medium=email&utm_sour…>

1 1

Fwd: Will you take my Presidential Poll?
by Gunnar Larson 25 Jan '25

25 Jan '25

*Question #1: What would you like my second week of executive action to focus on? <https://email.win.donaldjtrump.com/c/eJxMkcGOmzAQhp_G3IxgTDA5cEhL0EpVV-q2Ut…>* ---------- Forwarded message --------- From: President Trump <contact(a)win.donaldjtrump.com> Date: Sat, Jan 25, 2025, 3:29 PM Subject: Will you take my Presidential Poll? To: Gunnar Larson <g(a)xny.io> My fundraising deadline is coming up. ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ [image: MAKE AMERICA GREAT AGAIN. >] <https://email.win.donaldjtrump.com/c/eJxMkcFunDAQhp_G3EBmzNrkwGFbFlWqGrVJpY…> *Gunnar, I just released my first Presidential Poll, and I need your input before my first fundraising deadline as your President. <https://email.win.donaldjtrump.com/c/eJxMkU2PmzAQhn-NuRnBmK89cEhLUKWqKzWtlF…>* [image: MAKE AMERICA GREAT AGAIN. >] <https://email.win.donaldjtrump.com/c/eJxMkcFunDAQhp_G3IxgzAJ74LAtiyJFjdS00l…> RESPOND TO TRUMP <https://email.win.donaldjtrump.com/c/eJxMkU1vozAQhn-NuRnhMV85cMguQSutWqnpSl…> If you’re short on time, could you at least answer Question #1? *Question #1: What would you like my second week of executive action to focus on? <https://email.win.donaldjtrump.com/c/eJxMkcGOmzAQhp_G3IxgTDA5cEhL0EpVV-q2Ut…>* Your answer can be as simple as *DRILL, BABY DRILL!* I’m looking forward to reading your response tonight. RESPOND TO TRUMP <https://email.win.donaldjtrump.com/c/eJxMkUGPmzwQhn-NuRnhcYBw4JDvA1SpaqRuq6…> Sincerely, [image: MAKE AMERICA GREAT AGAIN. >] <https://email.win.donaldjtrump.com/c/eJxMkU2PmzAQhn-NuRnBOHzkwCEtQStVu2q3lV…> [image: MAKE AMERICA GREAT AGAIN. >] <https://email.win.donaldjtrump.com/c/eJxMkUFvozwQhn-NuRmZcWKSA4d8H0GVqq207U…> Donald J. Trump President of the United States COMPLETE POLL NOW <https://email.win.donaldjtrump.com/c/eJxMkU1v4yAQhn8NvmHZQwzuwYd0HW-l1VZqdq…> Contributions to Trump National Committee JFC Inc. are not deductible for federal income tax purposes. All contributions are subject to the limits and prohibitions of the Federal Election Campaign Act. Contributions from corporations, foreign nationals (i.e., without “green cards”), federal government contractors, and other federally impermissible sources are strictly prohibited. Contributions made in the name of, or refunded by, any other person are unlawful. Paid for by Trump National Committee JFC, Inc., P.O. Box 509, Arlington, VA 22216. Not Authorized by any Candidate or Candidate’s Committee. You are receiving this email at g(a)xny.io Trump National Committee JFC Inc., PO Box 509, Arlington, VA 22216 donaldjtrump.com <https://email.win.donaldjtrump.com/c/eJxkkcGO2yAURb8G72LBw4ZkwSItiSqNZtROK6…> If you'd like to change your subscription status follow this link. <https://email.win.donaldjtrump.com/c/eJw80MFrwyAUx_G_Rm8N-kw0PXjo1shgrLBu0N…> Privacy Policy <https://email.win.donaldjtrump.com/c/eJxkkUGPmzAUhH-NuYHwMxhy4JCW0EpVV-q2Uq…>

1 0

Fwd: FL, OH ––>
by Gunnar Larson 25 Jan '25

25 Jan '25

*It's now or never, team. * ---------- Forwarded message --------- From: Special Elections Update <info(a)dscc.org> Date: Sat, Jan 25, 2025, 5:21 PM Subject: re: FL, OH ––> To: <g(a)xny.io> ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ *ALERT:** Special elections could give Democrats the chance to WIN Ohio and Florida!* [image: JD Vance and Marco Rubio] <https://go.dscc.org/go/20854?amount=5&t=7&firstname=&lastname=&email=g%40xn…> *Urgent Request:**We have to get to work right away to flip seats like these and take away Trump's Senate majority -- so please, rush $5 or more to fight for a blue Senate >> <https://go.dscc.org/go/20854?amount=5&t=8&firstname=&lastname=&email=g%40xn…>* Donate $5 <https://go.dscc.org/go/20854?amount=5&t=9&firstname=&lastname=&email=g%40xn…> *It's now or never, team. Special elections will be coming up in Ohio and Florida -- but if Democrats don't come together right now to prepare, we could lose our chance to win these states and flip the Senate!* MAGA Republicans want to elect more Trump loyalists -- so it's up to us to take these seats back and put a check on Trump's power. We need EVERY Democrat in this fight. *We're still behind on our must-hit $50,000 fundraising goal to get to work, so we have to ask:* *Will you join Democrats across the nation and chip in $5 to help Democrats stop Trump, win in states like Ohio and Florida, and flip the Senate blue? >> <https://go.dscc.org/go/20854?amount=5&t=10&firstname=&lastname=&email=g%40x…>* We need your help to fight for the Senate. If you've saved payment info with ActBlue Express, your donation will be processed immediately. Donate $5 <https://go.dscc.org/go/20854?amount=5&t=11&amount=5&express_lane=true&first…> Donate $10 <https://go.dscc.org/go/20854?amount=5&t=12&amount=10&express_lane=true&firs…> Donate $20 <https://go.dscc.org/go/20854?amount=5&t=13&amount=20&express_lane=true&firs…> Other Amount <https://go.dscc.org/go/20854?amount=5&t=14&firstname=&lastname=&email=g%40x…> Thank you, Team DSCC Derivative of photo <https://go.dscc.org/go/1270?t=1&firstname=&lastname=&email=g%40xny.io&addr1…> by Gage Skidmore. CC BY-SA 2.0 <https://go.dscc.org/go/1271?t=2&firstname=&lastname=&email=g%40xny.io&addr1…>. [image: Chip in $5 monthly to flip the Senate] <https://secure.actblue.com/donate/support-senate-democrats-2025-q1-recurrin…> ------------------------------ The DSCC is the only committee solely dedicated to supporting Democrats in the U.S. Senate, and our work relies on grassroots supporters like you. If you'd like to make a contribution to support us, please *click here <https://secure.actblue.com/donate/support-senate-democrats-2025-q1?refcode=…>*. *Click here <https://go.dscc.org/signup/receive-fewer-emails/?t=5&akid=19401%2E26297126%…>* to receive fewer emails. *Click here <https://go.dscc.org/unsubscribe/unsubscribe/?t=6&akid=19401%2E26297126%2EDe…>* to unsubscribe. Paid for by the DSCC | PO Box 96047, Washington, DC 20090 | *dscc.org <https://www.dscc.org/>* | Not authorized by any candidate or candidate's committee. Contributions or gifts to the DSCC are not tax deductible.

1 0

Memo #4 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 25 Jan '25

25 Jan '25

https://docs.google.com/document/d/1ajVVx6NGB9wd2GDXfLRftf0RVFpqjl8WWITvdNV… March 10, 2022 BY ELECTRONIC MAIL Mr. John Marzulli United States Department of Justice Eastern District of New York 271 Cadman Plaza East Brooklyn New York, 11201 John.Marzulli(a)usdoj.gov Re: Memo #4 - Goldman Sachs Deferred Prosecution Agreement Dear Mr. Marzulli: The Department of Justice has yet to respond to Memo #1, Memo #2 and Memo #3 with our recent inquiry to the 1Malaysia Development Berhad Deferred Agreement. Goldman Sachs' Deferred Prosecution Agreement <https://www.justice.gov/usao-edny/pr/goldman-sachs-resolves-foreign-bribery…> with the United States of America is in potential breach, with ethical enforcement being concerned. Memo #4 aims to associate the malfeasance in Malaysia with war crimes of aggression (in the planning, initiation, or execution of a large-scale and serious act of aggression), leveraging the world’s only military divided capital city Nicosia, Cyprus. 1. Additionally, Memo #4 aims to earn the DOJ’s assessment of New York State’s regulatory marketplace manipulation deriving the war crime against peace, related to the planning, preparation, initiation, waging or participation in a common plan or conspiracy related to a war of aggression, which can only apply in relation to international armed conflict. 2. In this case, the first challenge is to observe and consider the simple idea that the DOJ’s Deferred Prosecution Agreement with Goldman Sachs alone, through means of regulatory arbitrage naively fails to recognize the ‘cause and effect’ relationship at play at the inception of Memo #4’s assertion of war crimes. 3. Even with the best of intentions, perhaps unknowingly the DOJ may be amplifying the effect of potential war crimes by indirectly supplementing the root cause of the problem and financial model of the Deferred Agreement being self-policing. Mr. Marzulli, there has been an active United Nations peacekeeping mission in Cyprus since the 1964 Turkish military invasion and occupation of the northern third of Cyprus. Only Turkey recognises the Turkish Republic of Northern Cyprus, while there is broad recognition that the ongoing military presence constitutes occupation of territories that are under Turkish military control. - The graduate education behind Memo #4 is a product of the University of Nicosia’s (UNIC) main campus, located adjacent to the United Nations Buffer Zone that separates the invaded Turkish Republic of North Cyprus and the Republic of Cyprus, which joined the European Union in 2004. - Memo #4 is also a product of United Nations consultancy, based at its Manhattan headquarters, where (today, what is now xNY.io - Bank.org) was credited with increasing the breadth and accessibility of reference content from the world’s most important multinational organization. - Memo #4’s subject of war crimes has preeminent association with such projects as the Audio Visual Library of International Law. Over the following sections, Memo #4 will provide a detailed timeline that would constitute real concern of the war crime of aggression yielding the war crime against peace in active war conflict in the world’s only military divided capital, funded from Manhattan Island. The Bank of Cyprus and Illegal Short Selling Irregularities of Turkey’s Markets Mr. Marzulli, turn this matter as we will, and look at it from any side whatsoever, and it presents the appearance of a cross-border act of aggression. Goldman Sachs’ potential disrespect to the Deferred Agreement’s core values has cultivated new crimes that aim to manipulate cross-border war crime regulatory frameworks. - On April 02, 2021 the Financial Times reported that Turkey fined Goldman Sachs over alleged irregularities in short selling, just a week after foreign investors pulled $1.9B from the country’s stock and bond markets. Turkey’s Capital Markets Board said that Goldman Sachs was among 10 securities firms that had placed orders for short selling without proper notification, violating rules enacted previously that temporarily prohibited such transactions. - On April 20, 2021 the CyprusMail (Cyprus’ only English Language daily newspaper) reported Goldman Sachs International acted as Global Coordinators and Dealer Managers in a $330M bond issuance for the Bank of Cyprus. Given the active military conflict in Cyprus, Memo #4 notes that there is one place on the planet you are not supposed to do this sort of thing. Furthermore, the DOJ’s Deferred Agreement with Goldman Sachs may have been tainted with the potential war crime of aggression, risking international peace and the lives of United Nations peacekeepers, while jeopardizing the United States of America’s financial security. Concern of New York Prime Bank Instrument Fraud and Marketplace Manipulation The United States Department of the Treasury warns that Prime Bank Instrument Fraud schemes have attracted significant international attention, since individuals and organizations have lost billions of dollars worldwide. "Prime Bank Instrument Fraud" is the general term given to prime bank fraud schemes that go by many different names. During April 2021, Goldman Sachs could not in good faith (and, plausible deniability) make any reasonable claim of holding a pristine relationship with Turkey’s Central Bank or with Cyprus’ largest financial institutions, given the 1Malaysia Development Berhad scandal and then pending Deferred Prosecution Agreement with the United States of America. - Memo #4 suggests that Goldman Sachs developed a Prime Bank Instrument Fraud program to level out yo-yo market dynamics caused by failed marketplace manipulation exercises in Turkey and Cyprus. - Systematic bank fraud and/or marketplace manipulation of any kind between Turkey and Cyprus could constitute the war crime of aggression. - Furthermore, Memo #4 argues that Goldman Sachs may have tried to bambooze governments in New York, Cyprus and Turkey through regulatory arbitrage loopholes, while Goldman seemingly may have not considered the totality of such actions as war crimes. Turkey has the highest inflation in Europe. It has the second-highest rate of inflation among emerging markets, just behind Argentina. It has the 13th highest inflation rate in the world, ranking it between South Sudan and Nigeria. After Goldman Sachs was fined for illegal stock and bond market short selling by the Turkish government, logic would argue further malfeasance potentially could have been avoided by the DOJ’s 1Malaysia Development Berhad investigation. - On April 15, 2021 CNBC reported that Goldman Sachs (note, the previous section’s milestones of April 02, 2021 and April 20, 2021) crucially removed its bias toward Turkey tightening interest rates. Goldman issued guidance highlighting the fact that the bank thought that, “…the removal of the tightening bias against rising inflation expectations suggests that the TCMB (Turkish Central Bank) now has a more dovish reaction function.” - On August 14, 2021 the CyprusMail reported serious concern among economists about data reporting from the Turkish Statistical Institute. Ahmet Takan, a former official with the office of the Turkish prime minister, acted as a whistle blower, warning that Turkey potentially was manipulating inflation data. - On September 1, 2021 Reuters reported that Goldman Sachs hiked Turkish growth forecasts. Goldman economists issued guidance stating, "Overall, the Turkish economy has been able to grow faster than we thought without a deterioration in its external balances, as the pickup in foreign demand has been very supportive." - On November 30, 2021 Reuters reported that Goldman Sachs trimed Turkey’s 2022 growth forecast. Goldman Sachs' Murat Unur stated, "We think that the GDP figures released today tell us little about the pace of economic activity going forward as the recent sell-off in the Lira is likely to impact economic activity significantly" Mr. Marzulli, the DOJ’s Deferred Prosecution Agreement with Goldman Sachs was signed on October 21, 2021. The timeline of events above do not coincide with terms and conditions of the Deferred Agreement mandated by the United States of America. Furthermore, as an international graduate scholars of the world’s only military divided capital on the planet, xNY.io - Bank.org should be protected from any association of crimes against peace, related to the planning, preparation, initiation, waging or participation in a common plan or conspiracy related to a war of aggression, which can only apply in relation to international armed conflict. War Crimes Against Humanity Mr. Marzulli, xNY.io - Bank.org is concerned that potential breaches to the Deferred Agreement are impacting our global enterprise. Crimes against humanity can be committed in peacetime as well as during an armed conflict. Even a single act could fall under this exclusion ground provided it forms part of a widespread or systematic attack against a civilian population and the act is committed by any person (including a civilian) who had knowledge of the attack and the link of the act to the attack. 1. We are looking to learn more about the DOJ’s approach to assessing any potential breaches to the Deferred Agreement’s mandates as we determine New York State’s role in cross-border bank regulation and corresponding innovation beyond war crimes against humanity. 2. In order to establish whether a war crime or a crime against humanity has been committed, the case officer should consult the relevant international instruments and case law. 3. Crimes against humanity are fundamentally inhumane acts, committed as part of a systematic or widespread attack. Inhumane acts, which could reach this threshold when committed pursuant to or in furtherance of a State or organizational policy (potentially, New York State bank regulation). 4. Persecution against any identifiable group or collectivity on political, racial, national, ethnic, cultural, religious, gender, or other grounds that are universally recognised as impermissible under international law. 5. Furthermore, we have made 28 highlights to the Deferred Agreement providing supporting reference to Memo #4’s overarching premise. xNY.io - Bank.org submits Memo #4 for DOJ consideration of other inhumane acts of a similar character intentionally causing great suffering, or serious injury to body or to mental or physical health. Some crimes against humanity would require an additional specific intent, such as Goldman Sachs willfully disrespecting New York State and/or overall peace and security of the United States of America. Memo #1, Memo #2, Memo #3 and Memo #4 outline instances that correspond with the associated definitions of the potential war crimes abroad and jeopardize the future of bank innovation from New York, at great sacrifice to the Homeland. We hope to learn the DOJ’s approach to comment on Memo #4’s subject matter or, without delay refer these concerns to the International Criminal Court and/or International Court of Justice for comment. Respectfully yours with anticipation, Gunnar Larson - xNY.io <http://www.xny.io> | Bank.org <http://bank.org>MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-646-454-9107

1 0