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April 2025
- 7 participants
- 724 discussions

Re: Memo #4 - Goldman Sachs Deferred Prosecution Agreement; Bloomberg Women's Buy-Side Network - AI: The Future of Investing; BREAKING: Ex-Girardi CFO Gets 10 Years For 'Devastating' Fraud
by Gunnar Larson 16 Apr '25
by Gunnar Larson 16 Apr '25
16 Apr '25
Goldman Sachs:
Yesterday, xNY.io - Bank.org's co-founder Gunnar Larson was at Bloomberg's
New York Headquarters for "Bloomberg Women's Buy-Side Network - AI: The
Future of Investing."
*xNY.io - Bank.org had a great time at Bloomberg yesterday at the Women's
Buy-Side Network AI: The Future of Investing:*
- https://www.facebook.com/share/p/16JBnzxDCJ/
BREAKING: Ex-Girardi CFO Gets 10 Years For 'Devastating' Fraud
<https://www.law360.com/legalethics/articles/2324647?nl_pk=87c9365b-e736-431…>
By Rachel Scharf
A California federal judge sentenced Girardi Keese's former chief financial
officer to just over 10 years in prison Friday for aiding firm leader Tom
Girardi's $15 million client theft scheme while also embezzling $6 million
for himself, saying the two interrelated schemes "had devastating and
far-reaching effects."
Read full article »
<https://www.law360.com/legalethics/articles/2324647?nl_pk=87c9365b-e736-431…>
| Save to favorites »
<https://www.law360.com/legalethics/articles/2324647?nl_pk=87c9365b-e736-431…>
- xNY.io - Bank.org knows Goldman Sachs knows that Goldman Sachs'
Chairman of the Board of Directors was mentioned at Bloomberg yesterday.
xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
Thank you,
Gunnar Larson
--
Gunnar Donald Arthur Peter Larson
*xNY.io - Bank.org*
917-580-8053
NEW YORK, NEW YORK 10001
On Sun, Apr 6, 2025, 7:49 AM Gunnar Larson <g(a)xny.io> wrote:
> Goldman Sachs:
>
> xNY.io - Bank.org is worried that Gomdman Sachs efforted and failed to
> defame xNY.io - Bank.org co-founder Gunnar Larson.
>
> Ex-Bank VP's Defamation Claims Dismissed By NJ Panel
> <https://www.law360.com/banking/articles/2320018?nl_pk=e602c558-f520-472e-90…>
>
> By Carla Baranauckas
>
> A former Pennsylvania bank vice president's claims of retaliation,
> defamation and trade libel were properly tossed by a New Jersey trial court
> that found the bank's statement that she had engaged in criminal behavior
> was substantially true even though she was never convicted of a crime, a
> state appellate panel said in a published opinion.
>
> Opinion attached |
>
> FinCEN Warns About Ongoing ISIS Threats, Banking Red Flags
> <https://www.law360.com/banking/articles/2320089?nl_pk=e602c558-f520-472e-90…>
>
> By Sarah Jarvis
>
> The Financial Crimes Enforcement Network has advised financial
> institutions that the Islamic State group continues to pose a threat to the
> U.S., detailing various red flags which banks should be on the lookout for
> to report suspicious activity tied to the terrorist organization.
>
> 1 document attached | Read full article »
> <https://www.law360.com/banking/articles/2320089?nl_pk=e602c558-f520-472e-90…>
> | Save to favorites »
> <https://www.law360.com/banking/articles/2320089?nl_pk=e602c558-f520-472e-90…>
>
> Justices Broaden RICO Reach To Personal Injuries
> <https://www.law360.com/banking/articles/2264334?nl_pk=e602c558-f520-472e-90…>
>
> By Sam Reisman
>
> The U.S. Supreme Court on Wednesday expanded the type of civil actions
> that can be brought under a federal racketeering statute, asserting that
> claims stemming from personal injuries are redressable if they can be shown
> to have caused economic harm.
>
> Opinion attached | Read full article »
> <https://www.law360.com/banking/articles/2264334?nl_pk=e602c558-f520-472e-90…>
> |
> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
>
> Thank you,
>
> Gunnar Larson
> --
> Gunnar Donald Arthur Peter Larson
>
> *xNY.io - Bank.org*
> 917-580-8053
> NEW YORK, NEW YORK 10001
>
> On Fri, Mar 21, 2025, 6:40 PM Gunnar Larson <g(a)xny.io> wrote:
>
>> Dear Goldman Sachs:
>>
>> Today, xNY.io - Bank.org doubles down on our commitment to Peace on
>> Planet Earth.
>>
>> xNY.io - Bank.org shares 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."*
>>
>> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
>>
>> Thank you,
>>
>> Gunnar Larson
>> --
>> Gunnar Donald Arthur Peter Larson
>>
>> *xNY.io - Bank.org*
>> 917-580-8053
>> NEW YORK, NEW YORK 10001
>>
>> *----- (PAGE BREAK) -----*
>>
>> *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."*
>>
>> *INTRODUCTION*
>>
>> *March 24, 2022*
>>
>>
>> * -
>> 158 Highlights: https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=…
>> <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.
>>
>> ____________________
>>
>>
>>
>>
>> *BACKGROUNDSeptember 8, 2022*
>>
>> - *190 Highlights: https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=…
>> <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.
>>
>> ____________________
>>
>>
>>
>>
>>
>>
>> *BACKGROUNDOctober 31, 2022 -
>> 25 Highlights: https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=…
>> <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.
>> ____________________
>>
>>
>>
>>
>>
>>
>> *BACKGROUNDNovember 10, 2022 -
>> 66 Highlights: https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=…
>> <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.
>>
>> ____________________
>>
>>
>>
>>
>>
>>
>> *BACKGROUNDJanuary 19, 2023 -
>> 53 Highlights: https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=…
>> <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.
>>
>> On Mon, Mar 17, 2025, 10:35 AM Gunnar Larson <g(a)xny.io> wrote:
>>
>> Goldman Sachs:
>>
>> Is Goldman Sachs a potential negligent terrorist organization?
>>
>> - *xNY.io - Bank.org demands a response from Goldman Sachs confirming
>> your firm is innocent of possible terrorism actions across your Investment
>> Bank. *
>>
>> Combs Jury To Be Closely Vetted For May Trial
>> <https://www.law360.com/newyork/articles/2311047?nl_pk=b53aa520-5013-4a8d-a5…>
>>
>> By Pete Brush
>>
>> A Manhattan federal judge said Friday that he plans to open Sean "Diddy"
>> Combs' criminal trial on sex-trafficking charges on May 12 after a lengthy
>> jury-vetting process, laying out his plan after the jailed hip-hop icon
>> denied charges in a superseding indictment.
>>
>> Letter attached | Read full article »
>> <https://www.law360.com/newyork/articles/2311047?nl_pk=b53aa520-5013-4a8d-a5…>
>> | Save to favorites »
>> <https://www.law360.com/newyork/articles/2311047?nl_pk=b53aa520-5013-4a8d-a5…>
>>
>> Three Arrows Beats FTX To Get $1.5B Bankruptcy Claim
>> <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a5…>
>>
>> By Alex Wittenberg
>>
>> The liquidators of failed cryptocurrency hedge fund Three Arrows Capital
>> have prevailed in a dispute with FTX Trading Ltd. over the allowance of a
>> $1.53 billion bankruptcy claim, with a Delaware judge deciding to grant
>> Three Arrows' bid to change its original claim despite FTX asserting that
>> the move was made in bad faith.
>>
>> Opinion attached | Read full article »
>> <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a5…>
>> | Save to favorites »
>> <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a5…>
>> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
>>
>> Thank you,
>>
>> Gunnar Larson
>> --
>> Gunnar Donald Arthur Peter Larson
>> xNY.io - Bank.org
>> 917-580-8053
>>
>> On Sun, Mar 16, 2025, 1:35 PM Gunnar Larson <g(a)xny.io> wrote:
>>
>> Art Director/Designer: Ken Carson
>> Photographers: Charles Wiesehahn, David Vine, Stan Schafer, H. Armstrong
>> Robert's
>> Copywriter: Bill Drier
>> Agency: Conaway & Lyon, Inc.
>> Client: Nation's Business
>>
>> *oops.*
>>
>> We hate to cloud your day, but we'd like
>> to bring you up to date on a few things the
>> experts have to say about our future relationships with Russia.
>>
>> The outlook is anything but rosy.
>>
>> It seems we could all be blown to hell be-
>> cause of an incredible Kremlin capacity for
>> misjudging what they can get away with
>> in their drive to communize the world.
>>
>> In other words, the cold war, though
>> vastly changed, is far from over.
>>
>> It's perils are not diminishing. If any-
>> thing they're on the increase.
>>
>> And continued disintegration of the So-
>> viet bloc may tempt the Russians into new
>> and desperate measures.
>>
>> In short: the Reds are still on the make.
>> And though they definitely do not want a
>> nuclear war, they seem to be continually
>> blundering to the brink.
>>
>> Take the Cuban missile crisis, for exam-
>> ple. The Russians thought they could plant missiles in Cuba without
>> obstacles. They
>> never dreamed President Kennedy would
>> stand up to them.
>>
>> Another example, Czechoslovakia. The
>> Russians actually expected to be welcomed as they plunged into Prague.
>>
>> In the end, either of these miscalcula-
>> tions could have triggered a showdown. A
>> showdown leading to a humiliating defeat.
>> Or disaster.
>>
>> The cover story of the December issue
>> of Nation's Business tells more of the story.
>> (To over 2,000,000 of the nation's business
>> men.)
>>
>> Why a political report in a magazine like
>> ours? That's simple. If it affects business,
>> it'll be there.
>>
>> Which is probably why we have over 854,000 businessmen paying to
>> subscribe to our magazine.
>>
>> Which, when you think about it, is at
>> least one happy note to leave you with.
>>
>> If you're an advertiser.
>>
>> *Nation's Business *
>> *We Reach more businessmen than any other business magazine *
>>
>> On Sat, Mar 15, 2025, 6:16 PM Gunnar Larson <g(a)xny.io> wrote:
>>
>> *Please find the attached memo with 32 reference footnotes.*
>>
>> *xNY.io - Bank.org | Memo #2 - JPMorgan Chase Board of Directors ESG
>> Marketplace Manipulation:*
>>
>> -
>> https://docs.google.com/document/d/1bxERzXknAFfVW3YsDpNB-GPlVoiLAeeBXUrxwOF…
>>
>>
>> May 1, 2022
>>
>> BY ELECTRONIC MAIL
>>
>> Investor Relations
>> Board of Directors, JPMorgan Chase & Co.
>> 277 Park Avenue
>> New York, NY 10172-0003
>> JPMCinvestorrelations(a)jpmchase.com
>>
>> Re: JPMorgan Chase Board of Directors ESG Marketplace Manipulation
>>
>> Dear Board of Directors:
>>
>> xNY.io - Bank.org recently contacted JPMorgan Chase’s board of directors
>> to communicate our concern(s) that potentially JPMorgan Chase may be
>> engaging in exploitation of more than $100B of ESG asset liabilities, across
>> international regulatory arbitrage structures, while headquartered in
>> Manhattan. Specifically, the duty to promote the success of the company
>> is that a director must act in the way that she considers, in good faith,
>> and would be most likely to promote the success of the company for the
>> benefit of its members as a whole.
>>
>> -
>>
>> Failure by a board to adequately consider ESG-related risks,
>> particularly entity-specific compliance risks such as breach of securities
>> laws, could serve as the basis for liability of individual directors or
>> officers for breach of their fiduciary duties.
>>
>> Given JPMorgan’s five cout felonies, xNY.io - Bank.org is concerned with
>> your board of director governance in preventing ESG fraud. xNY.io -
>> Bank.org’s assessment of JPMorgan’s board embraces fundamentals including
>> liquidity risk and protecting New York ESG cross border innovation from
>> marketplace manipulation.
>>
>> -
>>
>> According to JPMorgan’s August 2021 Sovereigns and ESG whitepaper,
>> the bank states that governance carries the largest weight of the three ESG
>> pillars across scores, as it is the most empirically relevant for asset
>> prices.
>> -
>>
>> JPMorgan notes that philosophically, the bank views good governance
>> as a foundational pillar for positive ESG developments in other pillars.
>>
>> Today’s memo follows protocol suggested by the United States of America,
>> in that JPMorgan Chase’s board of directors is responsible to xNY.io -
>> Bank.org’s enterprise and the Department of the Interior, in connection
>> with any action alleging a violation of the Endangered Species Act, by any
>> person (“person” means an individual, corporation, partnership, trust,
>> association, or any other private entity) claiming the benefit of any
>> exemption or permit under the Act, who shall have the burden of proving
>> that the exemption or permit is applicable, or has been granted, and was
>> valid and in force at the time of alleged violation.
>>
>> xNY.io - Bank.org has made 91 highlights to the Department of Interior’s
>> Endangered Species Act for JPMorgan Chase’s board of directors reference.
>>
>>
>> 1.
>>
>> xNY.io - Bank.org has reason to believe in the JPMorgan Chase board
>> of directors’ engagement of ESG marketplace manipulation, risking your ESG
>> portfolio’s future at the cost of New York digital asset innovation.
>> 2.
>>
>> xNY.io - Bank.org references your 2021 Environmental Social and
>> Governance Report, totaling $117B of ESG “development funding”
>> transferred from New York to Caribbean and Eastern European accounts.
>> 3.
>>
>> xNY.io - Bank.org is concerned of JPMorgan Chase board directors
>> leveraged marketplace manipulation techniques in allocating ESG funds to
>> engage in potential harassment (the term "harassment" means any act of
>> pursuit, torment, or annoyance) of some of the world’s most precious
>> endangered species protected by domestic and international governance.
>> 4.
>>
>> JPMorgan Chase’s $2.3B ESG “wind farm” facility is characterized by
>> the Washington Post as a potential misuse of ESG assets (and board
>> policies) to fund probable violation(s) of the Marine Mammal Protection Act
>> of 1972.
>>
>> Looking internationally, xNY.io - Bank.org is concerned of further ESG
>> marketplace manipulation structures, sacrificing endangered species, via
>> JPMorgan Chase’s board directed ESG investments in the Caribbean (your
>> largest ESG investment region). xNY.io - Bank.org signals that JPMorgan’s
>> board of directors is party to the Convention on Nature Protection and Wild
>> Life Preservation in the Western Hemisphere.
>>
>> Being clear, any violation of the Endangered Species Act, the Marine
>> Mammal Protection Act and/or the Convention on Nature Protection and
>> Wild Life Preservation in the Western Hemisphere … Requires xNY.io -
>> Bank.org to consult JPMorgan Chase board members on ESG allocations that
>> may be in conflict with construction, or other development projects, or
>> other forms of economic activity.
>>
>> xNY.io - Bank.org asks JPMorgan Chase board directors to return the
>> Secretary of Department of the Interior’s approval, confirming licensing
>> and/or exclusion to the Endangered Species Act, with further authorization
>> of “harassment” pursuant to exemption(s). Including (if available) a
>> similar Environmental Protection Agency permit that is applicable and is
>> valid and in force.
>>
>> -
>>
>> Due to the riskiness of ESG portfolio mismanagement in violation of
>> the Endangered Species Act, ESG marketplace manipulation risk(s) may
>> trigger causal shocks to New York State monetary and regulatory innovation.
>> -
>>
>> According to JPMorgan’s sovereign fund ESG research, “A common
>> complaint about ESG analysis is that data can be difficult to source. Some
>> sovereign data is in fact more readily available than corporate data given
>> the multitude of multinational organizations and NGOs – including the World
>> Bank, the IMF and the United Nations.”
>> -
>>
>> The European Central Bank provides support to the eurozone sovereign
>> debt market but has more restrictions on what and how much it can buy, so
>> eurozone bonds can trade with more credit risk premium compared to other
>> major developed market bonds.
>> -
>>
>> Whatever the case may be, JPMorgan disclosures detail significant
>> concern of lapse in board governance and ESG portfolio risk with potential
>> violation of the Endangered Species Act, risking ESG portfolio default(s)
>> in Europe and the United States risking ESG customer financial abuse.
>>
>> Forbes recently profiles JPMorgan Chase ESG investments as problematic,
>> highlighting that your board of directors potentially are allocating ESG
>> proceeds in competition with human rights at the expense of customers’ best
>> interests while investing heavily in fossil fuels. A letter to JPMorgan
>> Chase’s board of directors from ESG scholars (including, The Sierra Club,
>> Public Citizen, Greenpeace, Amazon Watch, Revolving Door Project,
>> Rainforest Action Network and the Center for International Environmental
>> Law) suggests the bank would “...lock us into energy sources that are
>> overly expensive and subject to wild price swings, and that exacerbate
>> rather than ease global conflict.”
>>
>> xNY.io - Bank.org aims to protect ESG digital asset innovation and
>> JPMorgan’s board should understand your proprietary ESG scoring matrix
>> should signal seismic marketplace manipulation risk if directors are in
>> potential violation of any Endangered Species Act covenant.
>>
>> -
>>
>> Head of Europe, Middle East, and Africa (EMEA) distribution at JP
>> Morgan Asset Management says, “In Europe, we do not have a semi-transparent
>> product – like the US and Australia – which would add further complexity to
>> the trading. For example, the US has several models which make it harder
>> for the AP to guess what the actual fund looks like and therefore the costs
>> might be higher accordingly.”
>> -
>>
>> Given, JPMorgan may potentially be in breach of United States
>> Endangered Species Act provisions, similar risk of ESG asset failure(s) may
>> include Europe, Middle East, Africa and Australia international law, as
>> ratified by the Convention on International Trade in Endangered Species of
>> Wild Fauna and Flora.
>>
>> While directors and officers are likely to be particularly focused on the
>> risk that they may be found personally liable for a breach of their duties,
>> proper ESG compliance with fiduciary obligations requires acting to a
>> higher standard. Given the defenses available to fiduciaries, and the
>> difficulty in bringing claims for breach of fiduciary duty, a director or
>> officer found to be liable for such ESG breaches will generally have acted
>> egregiously. This ‘sliding scale’ of the standards to which directors and
>> officers should adhere.
>>
>> Following the Endangered Species Act, xNY.io - Bank.org kindly petitions
>> JPMorgan’s board of directors, in connection with all ESG investments,
>> claiming the benefit of any exemption or permit under the United States
>> Department of the Interior’s Endangered Species Act … Shall have the
>> burden of proving that an exemption or permit is applicable, or has been
>> granted, and is valid and in force.
>>
>> -
>>
>> At JPMorgan’s earliest convenience (within 60 days of receipt of this
>> memo) xNY.io - Bank.org kindly requests a certified copy of JPMorgan
>> Chase’s approval by the Department of the Interior, being a license and/or
>> exclusion to the Endangered Species Act and/or the Marine Mammal Protection
>> Act.
>> -
>>
>> JPMorgan Chase suggests a commitment to anti-corruption compliance is
>> central to the success of its business. Your board of directors stand to
>> maintain that trust by promoting a corporate culture that encourages
>> ethical business practices and compliance with both the letter and the
>> spirit of the laws of the countries in which the JPMorgan conducts business.
>>
>>
>> xNY.io - Bank.org’s research guidance from the United States Securities
>> and Exchange Commision, supports the international community in taking
>> actions to address ESG issues on a global basis, and those actions that can
>> have a material impact on companies.
>>
>> Future correspondence concerning ESG innovation is at your board’s
>> leisure.
>>
>> Respectfully yours with appreciation,
>>
>> Gunnar Larson | xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>,
>> PBC
>> MSc
>> <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> -
>> Digital Currency
>> MBA
>> <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> -
>> Entrepreneurship and Innovation (ip)
>> G(a)xNY.io +1-646-454-9107
>>
>> On Fri, Mar 14, 2025, 6:34 PM Gunnar Larson <g(a)xny.io> wrote:
>>
>> Goldman Sachs:
>>
>> Is Goldman Sachs a potential negligent terrorist organization?
>>
>> - *xNY.io - Bank.org demands a response from Goldman Sachs confirming
>> your firm is innocent of possible terrorism actions across your Investment
>> Bank. *
>> - *xNY.io - Bank.org demands Goldman Sachs' answer by 12:00pm EST**,
>> Monday, March 17, 2025.*
>>
>>
>>
>> On Fri, Mar 21, 2025, 3:25 AM Gunnar Larson <g(a)xny.io> wrote:
>>
>>> Dear Goldman Sachs:
>>>
>>> xNY.io - Bank.org has made 37 highlights to Nanjing Audit University's "*Can
>>> D&O insurance improve corporate ESG performance*?" for Meta Platforms'
>>> Board.
>>>
>>> *Can D&O insurance improve corporate ESG performance?:*
>>>
>>> -
>>> https://drive.google.com/file/d/1kYBR93f7fzdculQZk9MGUkPlX23WTKQm/view?usp=…
>>>
>>>
>>>
>>> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
>>>
>>> Thank you,
>>>
>>> Gunnar Larson
>>> --
>>> Gunnar Donald Arthur Peter Larson
>>> xNY.io - Bank.org
>>> 917-580-8053
>>>
>>> On Fri, Mar 21, 2025, 1:19 AM Gunnar Larson <g(a)xny.io> wrote:
>>>
>>>> Dear Goldman Sachs:
>>>>
>>>>
>>>> Will Goldman Sachs' Board Directors submit the Board to an audit of the
>>>> Deferred Agreement’s mandates?
>>>>
>>>>
>>>> xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution
>>>> Agreement holds certain risk requirements.
>>>>
>>>> *Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:*
>>>>
>>>> -
>>>> https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=…
>>>>
>>>> *"Periodic Risk-Based Review *
>>>>
>>>> * 5. The Company will develop these compliance policies and procedures
>>>> on the basis of a periodic risk assessment addressing the individual
>>>> circumstances of the Company, in particular the foreign bribery risks
>>>> facing the Company, including, but not limited to, its geographical
>>>> organization, interactions with various types and levels of government
>>>> officials, industrial sectors of operation, potential clients and business
>>>> partners, use of third parties, gifts, travel and entertainment expenses,
>>>> charitable and political donations, involvement in joint venture
>>>> arrangements, importance of licenses and permits in the Company’s
>>>> operations, degree of governmental oversight and inspection, and volume and
>>>> importance of goods and personnel clearing through customs and
>>>> immigration. *
>>>>
>>>> * 6. The Company shall review its anti-corruption compliance policies
>>>> and procedures no less than annually and update them as appropriate to
>>>> ensure their continued effectiveness, taking into account relevant
>>>> developments in the field and evolving international and industry
>>>> standards."*
>>>>
>>>> Financial Services Forum President and CEO Kevin Fromer issued the
>>>> following statement after the Office of the Comptroller of the Currency
>>>> (OCC) announced it will no longer examine its regulated institutions for
>>>> reputation risk.
>>>>
>>>>
>>>> *Forum Statement on OCC’s Removal of Reputation Risk*
>>>>
>>>> *Washington, D.C. – *Financial Services Forum President and CEO Kevin
>>>> Fromer issued the following statement after the Office of the Comptroller
>>>> of the Currency (OCC) announced it will no longer examine its regulated
>>>> institutions for reputation risk:
>>>>
>>>> “We appreciate the OCC’s action to ensure bank supervision is focused
>>>> on financial and other material risks. Today’s decision is an important
>>>> step to create a more transparent and effective regulatory environment. We
>>>> look forward to continuing to work with the Administration and Congress to
>>>> identify solutions that allow America’s leading banks to continue to best
>>>> serve their customers.”
>>>>
>>>> ###
>>>>
>>>> *The Financial Services Forum is an economic policy and advocacy
>>>> organization whose members are the eight largest and most diversified
>>>> financial institutions headquartered in the United States. Forum member
>>>> institutions are a leading source of lending and investment in the United
>>>> States and serve millions of consumers, businesses, investors, and
>>>> communities throughout the country. The Forum promotes policies that
>>>> support savings and investment, financial inclusion, deep and liquid
>>>> capital markets, a competitive global marketplace, and a sound financial
>>>> system.*
>>>>
>>>>
>>>> *Visit our website: **fsforum.com*
>>>> <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-r/>
>>>>
>>>> *Follow us on X **@fsforum*
>>>> <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-y/>
>>>> * and **LinkedIn*
>>>> <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-j/>
>>>>
>>>>
>>>> [image: Twitter]
>>>> <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-t/>[image:
>>>> LinkedIn]
>>>> <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-i/>[image:
>>>> Website]
>>>> <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-d/>[image:
>>>> Instagram]
>>>> <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-h/>[image:
>>>> Threads]
>>>> <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-k/>[image:
>>>> YouTube]
>>>> <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-u/>
>>>>
>>>>
>>>> <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-o/>
>>>>
>>>> The Financial Services Forum is an economic policy and advocacy
>>>> organization whose members are the eight largest and most diversified
>>>> financial institutions headquartered in the United States. The Forum
>>>> promotes policies that support savings and investment, financial inclusion,
>>>> deep and liquid capital markets, a competitive global marketplace, and a
>>>> sound financial system.
>>>> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
>>>>
>>>> Thank you,
>>>>
>>>> Gunnar Larson
>>>> --
>>>> Gunnar Donald Arthur Peter Larson
>>>> xNY.io - Bank.org
>>>> 917-580-8053
>>>>
>>>> On Thu, Mar 20, 2025, 8:31 AM Gunnar Larson <g(a)xny.io> wrote:
>>>>
>>>>> Goldman Sachs:
>>>>>
>>>>> xNY.io - Bank.org is concerned Goldman Sachs is potentially
>>>>> 'obstructing justice' against xNY.io - Bank.org's global enterprise.
>>>>>
>>>>> Swiss Bank Accused Of Ignoring $1B Kuwaiti Bribery Scheme
>>>>> <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8…>
>>>>>
>>>>> By Lucia Osborne-Crowley
>>>>>
>>>>> A Swiss bank turned a blind eye to a scheme of corrupt payments
>>>>> orchestrated by the former director of Kuwait's pensions authority by
>>>>> failing to make reasonable inquiries into suspicious accounts, lawyers for
>>>>> the body told a court on Wednesday.
>>>>>
>>>>> Read full article »
>>>>> <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8…>
>>>>> | Save to favorites »
>>>>> <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8…>
>>>>>
>>>>> Goldstein Says Feds 'Misled' Court With Obstruction Claim
>>>>> <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-…>
>>>>>
>>>>> By Phillip Bantz
>>>>>
>>>>> U.S. Supreme Court lawyer and SCOTUSblog publisher Tom Goldstein wants
>>>>> a Maryland federal judge to sanction prosecutors in his tax evasion case
>>>>> for a "pattern of false and misleading statements" to the court accusing
>>>>> him of hiding millions in cryptocurrency and bribing his former law firm
>>>>> manager.
>>>>>
>>>>> 2 documents attached |
>>>>> <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-…>
>>>>>
>>>>
1
7
NJ Atty Disbarred For Misappropriating Estate Funds
<https://www.law360.com/legalethics/articles/2325494?nl_pk=87c9365b-e736-431…>
By Emily Sawicki
The New Jersey Supreme Court has disbarred an attorney after finding that
he knowingly misappropriated funds from a client in an estate matter and
then spent years ducking disciplinary authorities and practicing with a
suspended license.
2 documents attached | Read full article »
<https://www.law360.com/legalethics/articles/2325494?nl_pk=87c9365b-e736-431…>
| Save to favorites »
<https://www.law360.com/legalethics/articles/2325494?nl_pk=87c9365b-e736-431…>
1
0
FCA Accuses Director Of £1M Investor Fraud Scheme
<https://www.law360.co.uk/financial-services-uk/articles/2325436?nl_pk=9aaa8…>
By Ronan Barnard
The finance regulator said Tuesday that it was prosecuting the director of
a trading advice company that it alleges made more than £1 million ($1.3
million) by misleading investors and operating an investment business
without authorization.
Read full article »
<https://www.law360.co.uk/financial-services-uk/articles/2325436?nl_pk=9aaa8…>
| Save to favorites »
<https://www.law360.co.uk/financial-services-uk/articles/2325436?nl_pk=9aaa8…>
1
0

16 Apr '25
Ambassador Julie S. Davis: Welcoming back to Limassol 🇨🇾 the USNS LARAMIE
for scheduled maintenance and shore leave for the ship’s crew. 🇺🇸 USNS
LARAMIE has been at sea providing critical logistical support for #USNavy
ships operating in the region. U.S. Navy's Military Sealift Command U.S.
Naval Forces Europe-Africa/U.S. Sixth Fleet
https://www.facebook.com/share/1BN3AFNT6S/
1
0
Google Fired Workers For Pro-Palestine Views, Suit Says
<https://www.law360.com/technology/articles/2324975?nl_pk=b6acf8b6-b37c-4b07…>
By Emmy Freedman
Staging a peaceful protest to denounce harassment of Muslim and Arab
employees at Google and the tech giant's support of Israeli military
operations got many workers at the company unlawfully fired, a proposed
class action filed in California federal court said.
Complaint attached | Read full article »
<https://www.law360.com/technology/articles/2324975?nl_pk=b6acf8b6-b37c-4b07…>
| Save to favorites »
<https://www.law360.com/technology/articles/2324975?nl_pk=b6acf8b6-b37c-4b07…>
1
0
Ms. Caswell:
*xNY.io - Bank.org is excited to announce our campaign, "2025 SUMMER OF
LOVE" from April 15, 2025 through December 15, 2025.*
- xNY.io - Bank.org founder Gunnar Larson was a writer at
LitigationFinanceJournal.com, or Legal Funding Journal in 2022.
*Meta Platforms should understand that xNY.io - Bank.org supports semantics
empowering freedom of thought as a human right; Holding new opportunities
for modern international recognition of the right to cognitive liberty.*
Defense Strategies After Justices' Personal Injury RICO Ruling
<https://www.law360.com/cannabis/articles/2324118?nl_pk=a981d81f-1a94-4659-8…>
In Medical Marijuana v. Horn, the U.S. Supreme Court recently held that the
Racketeer Influenced and Corrupt Organizations Act can be invoked by some
plaintiffs with claims arising from personal injuries — but defense counsel
can use the limitations on civil RICO claims to seek early dismissal in
such cases, say attorneys at Debevoise.
Opinion attached | Read full article »
<https://www.law360.com/cannabis/articles/2324118?nl_pk=a981d81f-1a94-4659-8…>
| Save to favorites »
<https://www.law360.com/cannabis/articles/2324118?nl_pk=a981d81f-1a94-4659-8…>
Animal Rescue Wants Early Win In TM Suit Against Ex-Leader
<https://www.law360.com/competition/articles/2325076?nl_pk=6e763a2a-9f82-44c…>
By P.J. D'Annunzio
Pennsylvania-based animal rescue Last Chance Ranch has asked a federal
judge to rule that its former executive director copied its name and
trademarks for a competing nonprofit she created, arguing that the
infringement was obvious.
Motion attached | Read full article »
<https://www.law360.com/competition/articles/2325076?nl_pk=6e763a2a-9f82-44c…>
| Save to favorites »
<https://www.law360.com/competition/articles/2325076?nl_pk=6e763a2a-9f82-44c…>
Meta Accused Of Hiding $4B In Facebook Ad Overcharges
<https://www.law360.com/technology/articles/2324935?nl_pk=b6acf8b6-b37c-4b07…>
By Dorothy Atkins
South Carolina-based fitness company Iron Tribe has hit Meta Platforms Inc.
with a proposed class action in California federal court, alleging the
social media giant secretly overcharged Facebook advertisers $4 billion by
using a flawed "blended price" auction system that it hid from advertisers
and took years to correct.
Complaint attached | Read full article »
<https://www.law360.com/technology/articles/2324935?nl_pk=b6acf8b6-b37c-4b07…>
| Save to favorites »
<https://www.law360.com/technology/articles/2324935?nl_pk=b6acf8b6-b37c-4b07…>
*Litigating Universal Cognitive Liberty January 17, 2022 Commercial,
Premium is an article Gunnar wrote. *
-
https://litigationfinancejournal.com/litigating-universal-cognitive-liberty/
*Discussing Freedom of thought as recognized by the Universal Declaration
of Human Rights (UDHR).*
---------- Forwarded message ---------
From: *Gunnar Larson* <g(a)xny.io>
Subject: Litigating Universal Cognitive Liberty January 17,
2022 Commercial, Premium
Check out my recent article: https://litigationfinancejournal.com/litigating
-universal-cognitive-liberty/
Litigating Universal Cognitive Liberty
Freedom of thought is recognized by the Universal Declaration of Human
Rights (UDHR). Interestingly,, cognitive liberty is not recognized as an
international human right. Some want to change that, making the argument
that humanity has the right to be free to think whatever they want (freedom
of thought).
The Ottawa Citizen reports
<https://ottawacitizen.com/news/national/defence-watch/military-leaders-saw-…>
that
the Canadian armed forces have launched ‘psychological operations’ as an
experiment in government propaganda to counter civil disobedience.
International human rights scholars are quick to point out that the lack of
protection of cognitive liberty in such instances is due to the relative
lack of technology capable of directly interfering with mental autonomy at
the time the core human rights treaties were created.
Similar to a ransomware attack, the technology behind such operations can
be abused. Canada is said to have exploited advanced technologies without
the authority to do so. Even worse, it is alleged that Canada forcefully
abused technology in the unsanctioned production of reports that appeared
to be aimed at cognitive activities of Canadians.
- Other reports highlight similar technologies being explored by the New
York City Police Department.
- In 2021
<https://gothamist.com/news/city-settles-lawsuit-protesters-who-accused-nypd…>,
members of the National Lawyers Guild won $650,000 in litigation financed
fees from abuse of the technology in New York.
The semantics empowering freedom of thought as a human right hold new
opportunities for modern international recognition of the right to cognitive
liberty.
-----(PAGE BREAK)-----
*Ukrainian President Volodymyr Zelenskyy: The 2025 60 Minutes Interview
transcript:*
- *https://www.instagram.com/reel/DIZ_JjGRmeD/?igsh=MTViazN6emllY2dxaw==
<https://www.instagram.com/reel/DIZ_JjGRmeD/?igsh=MTViazN6emllY2dxaw==>*
*Secretary of Defense Pete Hegseth -- and he did not disappoint:*
- *https://www.facebook.com/reel/1325168828707386?sfnsn=mo&mibextid=J7ZoRX
<https://www.facebook.com/reel/1325168828707386?sfnsn=mo&mibextid=J7ZoRX>*
*Prince of Wales Boards Helicopter & Prince of Wales Arrives at BAFTAs (and
other videos): *
-
*https://www.facebook.com/reel/1827574018031589?mibextid=9drbnH&s=yWDuG2&fs=e*
<https://www.facebook.com/reel/1827574018031589?mibextid=9drbnH&s=yWDuG2&fs=e>
- *https://www.facebook.com/share/v/1EMwv9uqWD/*
<https://www.facebook.com/share/v/1EMwv9uqWD/>
-
*https://www.facebook.com/reel/1421684045477950?mibextid=9drbnH&s=yWDuG2&fs=e*
<https://www.facebook.com/reel/1421684045477950?mibextid=9drbnH&s=yWDuG2&fs=e>
-
*https://www.facebook.com/reel/1935763340542313?mibextid=9drbnH&s=yWDuG2&fs=e*
<https://www.facebook.com/reel/1935763340542313?mibextid=9drbnH&s=yWDuG2&fs=e>
xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
Gunnar Larson ✌️
--
Gunnar Donald Arthur Peter Larson
*xNY.io - Bank.org*
917-580-8053
NEW YORK, NEW YORK 10001
On Tue, Apr 15, 2025, 5:08 PM Gunnar Larson <g(a)xny.io> wrote:
> Ms. Caswell:
>
> In the run-up to the 2024 Presidential Election, Mark Zuckerberg and
> co-horts 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.
>
> *Meet The New Mark Zuckerberg | The Circuit*
> Bloomberg Originals <https://m.youtube.com/@business>
>
>
> -
> https://drive.google.com/file/d/1F4fIREOiXvBx_sDR8sLoij8WBvMMoLI9/view?usp=…
>
> *Ukrainian President Volodymyr Zelenskyy: The 2025 60 Minutes Interview
> transcript*
>
> *Speaking directly to President Trump in English, Ukrainian President
> Volodymyr Zelenskyy says: “You think you understand what's going on here…
> But, please, before any kind of decisions, any kind of plans for
> negotiations, come to see the people — civilians, warriors, hospitals,
> churches, children destroyed or dead.” https://cbsn.ws/3EluQQQ
> <https://cbsn.ws/3EluQQQ>*
>
> - *https://www.facebook.com/share/v/1G1jtZR6GH/
> <https://www.facebook.com/share/v/1G1jtZR6GH/>*
>
> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
>
> Thank you,
>
> Gunnar Larson
> --
> Gunnar Donald Arthur Peter Larson
>
> *xNY.io - Bank.org*
> 917-580-8053
> NEW YORK, NEW YORK 10001
>
> On Mon, Apr 14, 2025, 7:52 AM Gunnar Larson <g(a)xny.io> wrote:
>
>> Ms. Caswell:
>>
>> In the run-up to the 2024 Presidential Election, Mark Zuckerberg and
>> co-horts 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.
>> *Watch "Big Bear Bald Eagle Live Nest - Cam 1" on YouTube:*
>> <https://www.youtube.com/live/B4-L2nfGcuE?si=S4L8-QXZGWlt6gUl>
>>
>> <https://www.youtube.com/live/B4-L2nfGcuE?si=S4L8-QXZGWlt6gUl>
>> - <https://www.youtube.com/live/B4-L2nfGcuE?si=S4L8-QXZGWlt6gUl>
>> https://www.youtube.com/live/B4-L2nfGcuE?si=S4L8-QXZGWlt6gUl
>>
>> *Eagle_Eye_Cherry.jpg:*
>>
>> -
>> https://drive.google.com/file/d/1IODnPT53-MmcUuJLFNZ1thmWQ5LAC4EW/view?usp=…
>>
>> *Watch "BREAKING NEWS: President Trump And Cabinet Take Multiple
>> Questions About Tariffs, China At Meeting" on YouTube:*
>> <https://youtu.be/JYAAH3BlQQM?si=BpXAJS_WSRhKFsb_>
>>
>> <https://youtu.be/JYAAH3BlQQM?si=BpXAJS_WSRhKFsb_>
>> - <https://youtu.be/JYAAH3BlQQM?si=BpXAJS_WSRhKFsb_>
>> https://youtu.be/JYAAH3BlQQM?si=BpXAJS_WSRhKFsb_
>>
>> Tether-Backed Crypto Co. Can't Duck Swan's Trade Secrets Suit
>> <https://www.law360.com/capitalmarkets/articles/2324047?nl_pk=35f19b02-1b5d-…>
>>
>> By Katryna Perera
>>
>> A California federal judge has ruled that an entity backed by
>> cryptocurrency Tether can't escape a trade secrets suit from crypto trading
>> firm Swan Bitcoin, which claims the entity reneged on a commitment to
>> provide financing for a bitcoin mining deal and induced Swan employees to
>> quit and steal the firm's proprietary information.
>>
>> Order attached | Read full article »
>> <https://www.law360.com/capitalmarkets/articles/2324047?nl_pk=35f19b02-1b5d-…>
>> | Save to favorites »
>> <https://www.law360.com/capitalmarkets/articles/2324047?nl_pk=35f19b02-1b5d-…>
>> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
>>
>> Thank you,
>>
>> Gunnar Larson
>> --
>> Gunnar Donald Arthur Peter Larson
>>
>> *xNY.io - Bank.org*
>> 917-580-8053
>> NEW YORK, NEW YORK 10001
>>
>> On Wed, Apr 9, 2025, 11:49 AM Gunnar Larson <g(a)xny.io> wrote:
>>
>>> Ms. Caswell:
>>>
>>> - Moscow Stock Exchange Logo: https://tinyurl.com/3v2fd3y2
>>> - Meta's (Facebook) Logo: https://tinyurl.com/2p8csm8u
>>> - What is extremely interesting, the copyright case below was filed
>>> on March 8, 2021:
>>> https://dockets.justia.com/docket/new-york/nysdce/1:2021cv02007/555642
>>> - Meta announced its brand and logo on October 28, 2021:
>>> https://about.fb.com/news/2021/10/founders-letter/
>>>
>>> BREAKING: Ex-Russian Politician Convicted Of Breaching UK Sanctions
>>> <https://www.law360.co.uk/financial-services-uk/articles/2321737?nl_pk=9aaa8…>
>>>
>>> By Christopher Crosby
>>>
>>> A former Russian politician once appointed by President Vladimir Putin
>>> to office in occupied Crimea was convicted of breaching U.K. sanctions in a
>>> London court on Wednesday.
>>>
>>> Read full article »
>>> <https://www.law360.co.uk/financial-services-uk/articles/2321737?nl_pk=9aaa8…>
>>> | Save to favorites »
>>> <https://www.law360.co.uk/financial-services-uk/articles/2321737?nl_pk=9aaa8…>
>>> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
>>>
>>> Thank you,
>>>
>>> Gunnar Larson
>>> --
>>> Gunnar Donald Arthur Peter Larson
>>>
>>> *xNY.io - Bank.org*
>>> 917-580-8053
>>> NEW YORK, NEW YORK 10001
>>>
>>> On Fri, Mar 28, 2025, 2:42 AM Gunnar Larson <g(a)xny.io> wrote:
>>>
>>>> Ms. Caswell:
>>>>
>>>> - Moscow Stock Exchange Logo: https://tinyurl.com/3v2fd3y2
>>>> - Meta's (Facebook) Logo: https://tinyurl.com/2p8csm8u
>>>> - What is extremely interesting, the copyright case below was filed
>>>> on March 8, 2021:
>>>> https://dockets.justia.com/docket/new-york/nysdce/1:2021cv02007/555642
>>>> - Meta announced its brand and logo on October 28, 2021:
>>>> https://about.fb.com/news/2021/10/founders-letter/
>>>>
>>>>
>>>> *-----(PAGE BREAK)-----*
>>>>
>>>> *Russian State-Sponsored Network's Attempt to Dismiss Copyright Lawsuit
>>>> On Fair Use Grounds Denied *
>>>>
>>>> -
>>>> https://www.mondaq.com/unitedstates/copyright/1174834/russian-state-sponsor…
>>>>
>>>> TV-Novosti, a non-profit operating the Russian state-controlled
>>>> RT(formerly Russia Today) television networks and 38 associated RT YouTube
>>>> channels, has been sued for copyright infringement by Business Casual, an
>>>> American media company that creates documentary content, based on its use
>>>> of translated clips of Business Casual's documentaries in its own videos
>>>> posted to YouTube.
>>>>
>>>> Business Casual creates short original historical documentaries which
>>>> it posts to its YouTube channel. Its documentaries frequently feature
>>>> photographs of historical figures, using a process called "parallax" which
>>>> "transforms century-old low-resolution photographs into dramatically
>>>> restored high-resolution photographs" and "turn[s] two-dimensional images
>>>> into three-dimensional models . . . simulating a depth-of-field. This
>>>> optical illusion provides Business Casual's videos with an immersive
>>>> three-dimensional look and feel."
>>>>
>>>> The lawsuit relates to two of Business Casual's documentaries—"How
>>>> Rockefeller Built His Trillion Dollar Oil Empire" and "J.P. Morgan
>>>> Documentary: How One Man Financed America"—clips of which Business Casual
>>>> alleges TV-Novosti incorporated into three separate videos on its
>>>> "RT-Arabic" YouTube channel, including portions featuring parallax-enhanced
>>>> images, altering the brightness and saturation of the copied content and
>>>> replacing Business Casual's watermark with TV-Novosti's own in order to
>>>> hide from YouTube's algorithms.
>>>>
>>>> TV-Novosti moved to dismiss the copyright claims, arguing that it's use
>>>> of the clips is protected as fair use. However, after considering each of
>>>> the four statutory factors, Judge Koeltl of the Southern District of New
>>>> York denied TV-Novosti's motion, holding that while three of the four
>>>> factors weighed against finding fair use, "[t]he fourth factor, which the
>>>> Supreme Court has described as 'the single most important element of fair
>>>> use,' cannot be determined without further factual development."
>>>>
>>>> Specifically, regarding the first factor, concerning the transformation
>>>> of the use, Judge Koeltl found that while TV-Novosti's videos take portions
>>>> of the plaintiff's videos, re-arrange them, and add new commentary to them,
>>>> TV-Novosti had not made any meaningful changes to the visual clips
>>>> themselves, and "[m]erely overlaying new audio does not effect a sufficient
>>>> transformation . . . to find fair use as a matter of law." The Court
>>>> further noted that TV-Novosti had "not changed the purpose of the
>>>> parallax-enhanced images," i.e., to provide visual illustration for the
>>>> overlain audio commentary, but had instead "simply lifted the copyrighted
>>>> depictions . .. for the purpose of illustrating [TV-Novosti's] own video."
>>>> In addition, the Court found that the fact that TV-Novosti could have
>>>> sought to pay for the clips, but didn't, and tried to hide its use of the
>>>> excerpts from YouTube's algorithms, also weighed against a finding a fair
>>>> use under the first factor.
>>>>
>>>> Regarding the second factor, concerning the nature of the copyrighted
>>>> work, the Court initially noted that factual material such as that at
>>>> issue, "cuts less closely to the core of copyright." Nevertheless, the
>>>> Court held that the fact that source material for Business Casual's videos
>>>> was in the public domain weighed against finding fair use, because TV
>>>> Novosti could have simply used public domain photos of the historical
>>>> figures, rather than the modified clips, to create its videos.
>>>>
>>>> Regarding the third factor, concerning the amount of use in relation to
>>>> the copyrighted work as a whole, the Court noted that while only "small
>>>> portions of the entire copyrighted works were used"—excerpts of 7 seconds,
>>>> 1 minute and 28 seconds, and 8 minutes and 50 seconds in length—the
>>>> portions were "not so trivial as to warrant dismissal under the de minimis
>>>> doctrine."
>>>>
>>>> Lastly, regarding the fourth factor, concerning the effect of the use
>>>> on the potential market for or value of the copyrighted work, the Court
>>>> noted that this factor "ask[s] not whether the second work would damage the
>>>> market for the first (by, for example, devaluing it through parody or
>>>> criticism), but whether it usurps the market for the first by offering a
>>>> competing substitute." With this framing, the Court thus found that while
>>>> one the one hand, TV-Novosti's "videos are alternative ways of learning
>>>> about the lives of J.P. Morgan and John D. Rockefeller," on the other hand,
>>>> they "have a broader focus and are in a different language, meaning that
>>>> they cater to a different audience." These differences, the Court held,
>>>> were significant enough to preclude the Court from "determining the effect
>>>> of [TV-Novosti's] videos on the market for [Business Casual's] videos at
>>>> this time."
>>>>
>>>> The Court's recognition of the weight of the fourth factor in
>>>> determining fair use means that there may still be hope for TV-Novosti—time
>>>> (and fact discovery) will tell. For now, the takeaway may very well be
>>>> that parties seeking to raise a fair use defense should take care to
>>>> emphasize any characteristics of their use that distinguish not just their
>>>> work, but its target audience, including the scope of the work and the
>>>> language (if any) which communicates it.
>>>>
>>>> *-----(PAGE BREAK)-----*
>>>>
>>>> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
>>>>
>>>> Thank you,
>>>>
>>>> Gunnar Larson
>>>> --
>>>> Gunnar Donald Arthur Peter Larson
>>>>
>>>> *xNY.io - Bank.org*
>>>> 917-580-8053
>>>> NEW YORK, NEW YORK 10001
>>>>
>>>> On Fri, Mar 28, 2025, 2:22 AM Gunnar Larson <g(a)xny.io> wrote:
>>>>
>>>>> Art Director/Designer: Robert W. Wilvers
>>>>> Photographer: Paul Seligman
>>>>> Copyeditor: Gene Case
>>>>> Agency: Jack Tinker & Partners, Inc.
>>>>> Client: Rockefeller for President
>>>>>
>>>>> *Why I Run. *
>>>>>
>>>>> America cries out for a leader.
>>>>>
>>>>> Events overwhelm us. Change outruns us.
>>>>>
>>>>> Headlines deliver us our daily jolt.
>>>>>
>>>>> "Things are in the saddle, and ride mankind" -- this warning we have
>>>>> let come true.
>>>>>
>>>>> I run for President because I do not believe this must happen to us.
>>>>>
>>>>> I believe we can recapture control of *things.*
>>>>>
>>>>> I believe we can end the drift, the doubt, the division.
>>>>>
>>>>> I intend to say how, here, in this newspaper. I intend to write that
>>>>> course I believe America must follow.
>>>>>
>>>>> My beliefs will not be tailored to please the voters of this region or
>>>>> that. What I believe in New York. I believe in Nebraska. And I will answer
>>>>> for it throughout the campaign.
>>>>>
>>>>> I do not take my case to Republicans alone. It is a nation and not
>>>>> just a party which needs leading, healing, uniting.
>>>>>
>>>>> I begin tomorrow, on a subject that has tormented us like none other
>>>>> in our recent history: Riot.
>>>>>
>>>>> *Nelson A. Rockefeller*
>>>>>
>>>>> On Thu, Mar 27, 2025, 9:12 AM Gunnar Larson <g(a)xny.io> wrote:
>>>>>
>>>>>> Ms. Caswell:
>>>>>>
>>>>>> This morning xNY.io - Bank.org was again targeted by Meta Platforms.
>>>>>> Why?
>>>>>>
>>>>>> This will not be tolerated much longer.
>>>>>>
>>>>>> - *Did Meta Platforms work to "actively frustrate" xNY.io -
>>>>>> Bank.org business operations world-wide; *
>>>>>> - *Or did Meta Platforms work not to "actively frustrate" xNY.io
>>>>>> - Bank.org business operations world-wide? *
>>>>>>
>>>>>> 2nd Circ. Finds Pieces Missing From Lego IP Ruling
>>>>>> <https://www.law360.com/newyork/articles/2316011?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>>
>>>>>> By Elliot Weld
>>>>>>
>>>>>> The Second Circuit instructed a Connecticut federal judge Wednesday
>>>>>> to rethink his decision that an injunction blocking the sale of a Lego
>>>>>> competitor's figurines also applies to a later design, saying the lower
>>>>>> court's failure to explain its decision suggests it "may have simply
>>>>>> imported its prior reasoning."
>>>>>>
>>>>>> Order attached | Read full article »
>>>>>> <https://www.law360.com/newyork/articles/2316011?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>> | Save to favorites »
>>>>>> <https://www.law360.com/newyork/articles/2316011?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>>
>>>>>> Jay-Z's New Evidence May Save Claim Buzbee Tried Extortion
>>>>>> <https://www.law360.com/newyork/articles/2316247?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>>
>>>>>> By Rachel Scharf
>>>>>>
>>>>>> A California state court judge said Wednesday that new evidence
>>>>>> submitted by Shawn "Jay-Z" Carter "has thrown a monkey wrench" in his
>>>>>> analysis of the rapper's feud with personal injury lawyer Tony Buzbee, and
>>>>>> he's now inclined to keep alive an extortion claim stemming from
>>>>>> now-abandoned rape allegations.
>>>>>>
>>>>>> Read full article »
>>>>>> <https://www.law360.com/newyork/articles/2316247?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>> | Save to favorites »
>>>>>> <https://www.law360.com/newyork/articles/2316247?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>> xNY.io - Bank.org respectfully reserves all Interjurisdictional
>>>>>> rights.
>>>>>>
>>>>>> Thank you,
>>>>>>
>>>>>> Gunnar Larson
>>>>>> --
>>>>>> Gunnar Donald Arthur Peter Larson
>>>>>>
>>>>>> *xNY.io - Bank.org*
>>>>>> 917-580-8053
>>>>>> NEW YORK, NEW YORK 10001
>>>>>>
>>>>>> On Wed, Mar 26, 2025, 6:49 AM Gunnar Larson <g(a)xny.io> wrote:
>>>>>>
>>>>>>> Dear Ms. Caswell and Seroius Fraud Office:
>>>>>>>
>>>>>>> xNY.io - Bank.org has not heard from you.
>>>>>>>
>>>>>>> *Prince of Wales Boards Helicopter & Prince of Wales Arrives at
>>>>>>> BAFTAs:*
>>>>>>>
>>>>>>> -
>>>>>>> https://www.facebook.com/reel/1827574018031589?mibextid=9drbnH&s=yWDuG2&fs=e
>>>>>>> - https://www.facebook.com/share/v/1EMwv9uqWD/
>>>>>>>
>>>>>>> In the run-up to the 2024 Presidential Election, Mark Zuckerberg and
>>>>>>> co-horts 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.
>>>>>>>
>>>>>>> Ex-Private Equity Exec Denies Data Theft, Alleges Misconduct
>>>>>>> <https://www.law360.co.uk/financial-services-uk/articles/2314836?nl_pk=9aaa8…>
>>>>>>>
>>>>>>> By William Janes
>>>>>>>
>>>>>>> A former manager at private equity firm Appian Capital Advisory LLP
>>>>>>> has denied stealing the company's data and poaching staff and clients,
>>>>>>> telling a London court the business sued him after pushing him out because
>>>>>>> he voiced concerns about his boss's misconduct.
>>>>>>>
>>>>>>> Read full article »
>>>>>>> <https://www.law360.co.uk/financial-services-uk/articles/2314836?nl_pk=9aaa8…>
>>>>>>> | Save to favorites »
>>>>>>> <https://www.law360.co.uk/financial-services-uk/articles/2314836?nl_pk=9aaa8…>
>>>>>>>
>>>>>>> MoneyLion Gets CFPB Military Lending Suit Cut, But Not Axed
>>>>>>> <https://www.law360.com/fintech/articles/2315357?nl_pk=31322029-63eb-4d40-ac…>
>>>>>>>
>>>>>>> By Katryna Perera
>>>>>>>
>>>>>>> A New York federal judge has trimmed the Consumer Financial
>>>>>>> Protection Bureau's suit against MoneyLion Technologies, tossing claims
>>>>>>> that alleged improper use of an arbitration agreement and disclosure
>>>>>>> violations while allowing the remainder to proceed.
>>>>>>>
>>>>>>> Opinion attached | Read full article »
>>>>>>> <https://www.law360.com/fintech/articles/2315357?nl_pk=31322029-63eb-4d40-ac…>
>>>>>>> | Save to favorites »
>>>>>>> <https://www.law360.com/fintech/articles/2315357?nl_pk=31322029-63eb-4d40-ac…>
>>>>>>>
>>>>>>> Diddy Producer's Atty Gets Warning For 'Shocking' Statement
>>>>>>> <https://www.law360.com/fintech/articles/2315616?nl_pk=31322029-63eb-4d40-ac…>
>>>>>>>
>>>>>>> By Rachel Scharf
>>>>>>>
>>>>>>> A New York federal judge threatened counsel for one of Sean "Diddy"
>>>>>>> Combs' former music producers with sanctions Monday for a pattern of false
>>>>>>> statements and inappropriate insults in civil sexual assault litigation,
>>>>>>> calling one statement in the attorney's court filings "not just disturbing,
>>>>>>> but shocking."
>>>>>>>
>>>>>>> Opinion attached | Read full article »
>>>>>>> <https://www.law360.com/fintech/articles/2315616?nl_pk=31322029-63eb-4d40-ac…>
>>>>>>> | Save to favorites »
>>>>>>> <https://www.law360.com/fintech/articles/2315616?nl_pk=31322029-63eb-4d40-ac…>
>>>>>>>
>>>>>>> Watch here:
>>>>>>>
>>>>>>> *"Meet The New Mark Zuckerberg | The Circuit"*
>>>>>>> Bloomberg Originals <https://m.youtube.com/@business>
>>>>>>>
>>>>>>>
>>>>>>> -
>>>>>>> https://drive.google.com/file/d/1F4fIREOiXvBx_sDR8sLoij8WBvMMoLI9/view?usp=…
>>>>>>>
>>>>>>> xNY.io - Bank.org respectfully reserves all Interjurisdictional
>>>>>>> rights.
>>>>>>>
>>>>>>> Thank you,
>>>>>>>
>>>>>>> Gunnar Larson
>>>>>>> --
>>>>>>> Gunnar Donald Arthur Peter Larson
>>>>>>>
>>>>>>> *xNY.io - Bank.org*
>>>>>>> 917-580-8053
>>>>>>> NEW YORK, NEW YORK 10001
>>>>>>>
>>>>>>> On Tue, Mar 25, 2025, 2:06 PM Gunnar Larson <g(a)xny.io> wrote:
>>>>>>>
>>>>>>>> Ms. Caswell and Seroius Fraud Office:
>>>>>>>>
>>>>>>>> xNY.io - Bank.org shares with you 187 highlights to the Department
>>>>>>>> of Justice’s "*Prosecuting Computer Crimes, Computer **Crime and
>>>>>>>> Intellectual Property Section, Criminal Division*," published by
>>>>>>>> the Office of Legal Education, Executive Office for
>>>>>>>> United States Attorneys.
>>>>>>>>
>>>>>>>> *Computer Crimes Manual Highlights.pdf:*
>>>>>>>>
>>>>>>>> -
>>>>>>>> https://drive.google.com/file/d/11tbgHgDg8qagomO-NBffvIFpxXKmBC3g/view?usp=…
>>>>>>>>
>>>>>>>> UMich Students Sue Over Ex-Coach's Alleged Hacking
>>>>>>>> <https://www.law360.com/cybersecurity-privacy/articles/2314702?nl_pk=fb10114…>
>>>>>>>>
>>>>>>>> By Carolyn Muyskens
>>>>>>>>
>>>>>>>> Student-athletes are claiming the University of Michigan and a
>>>>>>>> software company failed to safeguard their private information from an
>>>>>>>> assistant football coach recently charged with computer crimes,
>>>>>>>> filing a lawsuit one day after the former coach's indictment was unveiled.
>>>>>>>>
>>>>>>>> Complaint attached | Read full article »
>>>>>>>> <https://www.law360.com/cybersecurity-privacy/articles/2314702?nl_pk=fb10114…>
>>>>>>>> | Save to favorites »
>>>>>>>> <https://www.law360.com/cybersecurity-privacy/articles/2314702?nl_pk=fb10114…>
>>>>>>>> xNY.io - Bank respectfully reserves all Interjurisdictional rights.
>>>>>>>>
>>>>>>>> Thank you,
>>>>>>>>
>>>>>>>> Gunnar Larson
>>>>>>>> --
>>>>>>>> Gunnar Donald Arthur Peter Larson
>>>>>>>>
>>>>>>>> *xNY.io - Bank.org*
>>>>>>>> 917-580-8053
>>>>>>>> NEW YORK, NEW YORK 10001
>>>>>>>>
>>>>>>>> On Tue, Mar 25, 2025, 11:00 AM Gunnar Larson <g(a)xny.io> wrote:
>>>>>>>>
>>>>>>>>> Ms. Caswell and Seroius Fraud Office:
>>>>>>>>>
>>>>>>>>> *xNY.io - Bank.org is reaching out to resolve the matters below: *
>>>>>>>>>
>>>>>>>>> -
>>>>>>>>> https://www.facebook.com/reel/1421684045477950?mibextid=9drbnH&s=yWDuG2&fs=e
>>>>>>>>> -
>>>>>>>>> https://www.facebook.com/reel/1935763340542313?mibextid=9drbnH&s=yWDuG2&fs=e
>>>>>>>>>
>>>>>>>>> *Prince of Wales Arrives at BAFTAs:*
>>>>>>>>>
>>>>>>>>> - https://www.facebook.com/share/v/1EMwv9uqWD/
>>>>>>>>>
>>>>>>>>> Justices Decline To Revisit Landmark Press Freedom Ruling
>>>>>>>>> <https://www.law360.com/cybersecurity-privacy/articles/2314693?nl_pk=fb10114…>
>>>>>>>>>
>>>>>>>>> By Katie Buehler
>>>>>>>>>
>>>>>>>>> The U.S. Supreme Court on Monday denied casino mogul and Trump
>>>>>>>>> donor Steve Wynn's bid to overturn a landmark ruling on press freedom that
>>>>>>>>> established a high evidentiary standard for public figures to pursue
>>>>>>>>> defamation claims.
>>>>>>>>>
>>>>>>>>> Read full article »
>>>>>>>>> <https://www.law360.com/cybersecurity-privacy/articles/2314693?nl_pk=fb10114…>
>>>>>>>>> | Save to favorites »
>>>>>>>>> <https://www.law360.com/cybersecurity-privacy/articles/2314693?nl_pk=fb10114…>
>>>>>>>>> xNY.io - Bank.org respectfully reserves all Interjurisdictional
>>>>>>>>> rights.
>>>>>>>>>
>>>>>>>>> Thank you,
>>>>>>>>>
>>>>>>>>> Gunnar Larson
>>>>>>>>> --
>>>>>>>>> Gunnar Donald Arthur Peter Larson
>>>>>>>>>
>>>>>>>>> *xNY.io - Bank.org*
>>>>>>>>> 917-580-8053
>>>>>>>>> NEW YORK, NEW YORK 10001
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On Mon, Mar 24, 2025, 11:41 AM Gunnar Larson <g(a)xny.io> wrote:
>>>>>>>>>
>>>>>>>>>> Ms. Caswell:
>>>>>>>>>>
>>>>>>>>>> xNY.io - Bank.org caught a clip of the BAFTA Awards in London
>>>>>>>>>> that seemingly mentions Mr. Zuckerberg along with xNY.io - Bank.org
>>>>>>>>>> co-founder Gunnar Larson.
>>>>>>>>>>
>>>>>>>>>> *Prince of Wales Arrives at BAFTAs:*
>>>>>>>>>>
>>>>>>>>>> - https://www.facebook.com/share/v/1EMwv9uqWD/
>>>>>>>>>>
>>>>>>>>>> Ex-Buzbee Client Says Roc Nation Can't Exit Conspiracy Suit
>>>>>>>>>> <https://www.law360.com/mergersacquisitions/articles/2314136?nl_pk=34b724c6-…>
>>>>>>>>>>
>>>>>>>>>> By Lynn LaRowe
>>>>>>>>>>
>>>>>>>>>> Shawn "Jay-Z" Carter's company Roc Nation can't exit a lawsuit
>>>>>>>>>> that claims his company conspired to "finance" malpractice suits against
>>>>>>>>>> attorney Tony Buzbee because it was "an integral and driving force" behind
>>>>>>>>>> the alleged misconduct, according to a response filed in Texas federal
>>>>>>>>>> court to a motion to dismiss on jurisdictional grounds.
>>>>>>>>>>
>>>>>>>>>> 3 documents attached | Read full article »
>>>>>>>>>> <https://www.law360.com/mergersacquisitions/articles/2314136?nl_pk=34b724c6-…>
>>>>>>>>>> | Save to favorites »
>>>>>>>>>> <https://www.law360.com/mergersacquisitions/articles/2314136?nl_pk=34b724c6-…>
>>>>>>>>>>
>>>>>>>>>> Wright Says Defamation Suit Did Not Violate Anti-SLAPP Law
>>>>>>>>>> <https://www.law360.com/legalethics/articles/2314252?nl_pk=87c9365b-e736-431…>
>>>>>>>>>>
>>>>>>>>>> By Emily Sawicki
>>>>>>>>>>
>>>>>>>>>> Onetime Federal Trade Commission member and law professor Joshua
>>>>>>>>>> Wright, who recently dropped a $108 million defamation suit against two
>>>>>>>>>> attorneys who accused him of sexual misconduct, is now fighting a sanctions
>>>>>>>>>> bid brought by one of the women, arguing it hinges on "selective — and
>>>>>>>>>> largely misleading — presentation of evidence."
>>>>>>>>>>
>>>>>>>>>> Motion attached | Read full article »
>>>>>>>>>> <https://www.law360.com/legalethics/articles/2314252?nl_pk=87c9365b-e736-431…>
>>>>>>>>>> | Save to favorites »
>>>>>>>>>> <https://www.law360.com/legalethics/articles/2314252?nl_pk=87c9365b-e736-431…>
>>>>>>>>>>
>>>>>>>>>> xNY.io - Bank.org shares the clip above with KTS Law under themes
>>>>>>>>>> of plausible deniability.
>>>>>>>>>>
>>>>>>>>>>
>>>>>>>>>> - *xNY.io - Bank.org has iincluded the United Kingdom's
>>>>>>>>>> Serious Fraud Office for plausible deniability as well. *
>>>>>>>>>>
>>>>>>>>>> Dear Serious Fraud Office:
>>>>>>>>>>
>>>>>>>>>> xNY.io - Bank.org is reaching out to resolve the matters below:
>>>>>>>>>>
>>>>>>>>>> -
>>>>>>>>>> https://www.facebook.com/reel/1421684045477950?mibextid=9drbnH&s=yWDuG2&fs=e
>>>>>>>>>> -
>>>>>>>>>> https://www.facebook.com/reel/1935763340542313?mibextid=9drbnH&s=yWDuG2&fs=e
>>>>>>>>>>
>>>>>>>>>> xNY.io - Bank.org respectfully reserves all Interjurisdictional
>>>>>>>>>> rights.
>>>>>>>>>>
>>>>>>>>>> Gunnar Larson
>>>>>>>>>> --
>>>>>>>>>> Gunnar Donald Arthur Peter Larson
>>>>>>>>>>
>>>>>>>>>> *xNY.io - Bank.org*
>>>>>>>>>> 917-580-8053
>>>>>>>>>> NEW YORK, NEW YORK 10001
>>>>>>>>>>
>>>>>>>>>> On Sat, Mar 22, 2025, 5:16 AM Gunnar Larson <g(a)xny.io> wrote:
>>>>>>>>>>
>>>>>>>>>>> Ms. Caswell:
>>>>>>>>>>>
>>>>>>>>>>> *The Brody of Wall Street* film treatment in the works by
>>>>>>>>>>> xNY.io - Bank.org does potentially have a Peace on the Planet
>>>>>>>>>>> diatribe.
>>>>>>>>>>>
>>>>>>>>>>> - *Ms. Caswell, the current President of Ukraine is a former
>>>>>>>>>>> comic; *
>>>>>>>>>>> - *The CEO of Goldman Sachs is a former disk jockey. *
>>>>>>>>>>>
>>>>>>>>>>> Performing Stand-Up Comedy Makes Me A Better Lawyer
>>>>>>>>>>> <https://www.law360.com/insurance/articles/2292129?nl_pk=347c5954-47a8-495c-…>
>>>>>>>>>>>
>>>>>>>>>>> Whether I’m delivering a punchline on stage or a closing
>>>>>>>>>>> argument in court, balancing stand-up comedy performances and my legal
>>>>>>>>>>> career has demonstrated that the keys to success in both endeavors include
>>>>>>>>>>> reading the room, landing the right timing and making an impact, says
>>>>>>>>>>> attorney Rebecca Palmer.
>>>>>>>>>>>
>>>>>>>>>>> Read full article »
>>>>>>>>>>> <https://www.law360.com/insurance/articles/2292129?nl_pk=347c5954-47a8-495c-…>
>>>>>>>>>>> | Save to favorites »
>>>>>>>>>>> <https://www.law360.com/insurance/articles/2292129?nl_pk=347c5954-47a8-495c-…>
>>>>>>>>>>>
>>>>>>>>>>> 'Jailhouse Lawyer' Ran Unauthorized Practice, NY Jury Finds
>>>>>>>>>>> <https://www.law360.com/newyork/articles/2313373?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>>>>>>>
>>>>>>>>>>> By Pete Brush
>>>>>>>>>>>
>>>>>>>>>>> A Manhattan federal jury on Thursday convicted a longtime
>>>>>>>>>>> "jailhouse lawyer" who began charging inmates' families for legal services
>>>>>>>>>>> after serving prison time himself, finding he engaged in the unauthorized
>>>>>>>>>>> practice of law but clearing him on a conspiracy count.
>>>>>>>>>>>
>>>>>>>>>>> Read full article »
>>>>>>>>>>> <https://www.law360.com/newyork/articles/2313373?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>>>>>>> | Save to favorites »
>>>>>>>>>>> <https://www.law360.com/newyork/articles/2313373?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>>>>>>>
>>>>>>>>>>> 'Epic Self-Own': Lively Says Baldoni Libel Suit Hikes Damages
>>>>>>>>>>> <https://www.law360.com/newyork/articles/2313628?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>>>>>>>
>>>>>>>>>>> By Rachel Scharf
>>>>>>>>>>>
>>>>>>>>>>> Blake Lively urged a New York federal judge on Thursday to toss
>>>>>>>>>>> Justin Baldoni's claims that she defamed him with sexual harassment
>>>>>>>>>>> allegations, saying the law prohibits such retaliatory libel suits and that
>>>>>>>>>>> he has committed an "epic self-own" that will put him on the hook for
>>>>>>>>>>> additional damages.
>>>>>>>>>>>
>>>>>>>>>>> Memorandum attached | Read full article »
>>>>>>>>>>> <https://www.law360.com/newyork/articles/2313628?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>>>>>>> | Save to favorites »
>>>>>>>>>>> <https://www.law360.com/newyork/articles/2313628?nl_pk=b53aa520-5013-4a8d-a5…>
>>>>>>>>>>>
>>>>>>>>>>> How Calif.'s Wildfire Insurance Crisis Might Affect Texas
>>>>>>>>>>> <https://www.law360.com/insurance/articles/2313111?nl_pk=347c5954-47a8-495c-…>
>>>>>>>>>>>
>>>>>>>>>>> Attorneys at Munsch Hardt examine the implications of
>>>>>>>>>>> California's wildfire insurance crisis for Texas, including potential
>>>>>>>>>>> shifts in coverage availability, regulatory differences and how the
>>>>>>>>>>> insurers in the second-largest U.S. state may react to a major wildfire
>>>>>>>>>>> event.
>>>>>>>>>>>
>>>>>>>>>>> Read full article »
>>>>>>>>>>> <https://www.law360.com/insurance/articles/2313111?nl_pk=347c5954-47a8-495c-…>
>>>>>>>>>>> | Save to favorites »
>>>>>>>>>>> <https://www.law360.com/insurance/articles/2313111?nl_pk=347c5954-47a8-495c-…>
>>>>>>>>>>> xNY.io - Bank.org respectfully reserves all Interjurisdictional
>>>>>>>>>>> rights.
>>>>>>>>>>>
>>>>>>>>>>> Gunnar Larson
>>>>>>>>>>> --
>>>>>>>>>>> Gunnar Donald Arthur Peter Larson
>>>>>>>>>>>
>>>>>>>>>>> *xNY.io - Bank.org*
>>>>>>>>>>> 917-580-8053
>>>>>>>>>>> NEW YORK, NEW YORK 10001
>>>>>>>>>>>
>>>>>>>>>>>
>>>>>>>>>>> On Fri, Mar 21, 2025, 2:26 PM Gunnar Larson <g(a)xny.io> wrote:
>>>>>>>>>>>
>>>>>>>>>>>> *Art Director: Peter Petronio *
>>>>>>>>>>>> *Photographer: Joe Toto*
>>>>>>>>>>>> *Copywriter: Dick Raboy *
>>>>>>>>>>>> *Agency: Carl Ally Inc. *
>>>>>>>>>>>> *Client: Investors Overseas Services *
>>>>>>>>>>>>
>>>>>>>>>>>> *THERE'S MORE MONEY TO BE MADE OUT OF PEACE THAN OUT OF WAR.*
>>>>>>>>>>>>
>>>>>>>>>>>> One of the persistent myths of the 20th century is that war stimulates
>>>>>>>>>>>> economic growth.
>>>>>>>>>>>>
>>>>>>>>>>>> War doesn't stimulate economic growth.
>>>>>>>>>>>>
>>>>>>>>>>>> It stunts it. In countries that aren't fighting the war, as
>>>>>>>>>>>> well as those that are.
>>>>>>>>>>>>
>>>>>>>>>>>> For in both cases, there is a tremendous spending of money,
>>>>>>>>>>>> manpower and time to produce the materials of war. Materials
>>>>>>>>>>>> which have no function other than to destroy.
>>>>>>>>>>>>
>>>>>>>>>>>> Or to be stored, useless, until they are needed to destroy.
>>>>>>>>>>>>
>>>>>>>>>>>> And the simple fact is, evey dollar wasted on destruction means
>>>>>>>>>>>> there is one less dollar to be spent on the products people need and want.
>>>>>>>>>>>>
>>>>>>>>>>>> A dollar less spent on expansion and progress.
>>>>>>>>>>>>
>>>>>>>>>>>> And when expansion and progress isn't as great as it could be,
>>>>>>>>>>>> then profits can't be as great as they should be.
>>>>>>>>>>>>
>>>>>>>>>>>> The way to make money is not through war. It's through peace.
>>>>>>>>>>>>
>>>>>>>>>>>> And by peace we don't mean just an interlude between wars. We
>>>>>>>>>>>> mean a permanent peace.
>>>>>>>>>>>>
>>>>>>>>>>>> But can there be peace?
>>>>>>>>>>>>
>>>>>>>>>>>> We believe so. If enough people in enough countries in this
>>>>>>>>>>>> world are given an opportunity to gain material well-being and a greater
>>>>>>>>>>>> since of personal dignity.
>>>>>>>>>>>>
>>>>>>>>>>>> And this can done through business. Private enterprise.
>>>>>>>>>>>>
>>>>>>>>>>>> Successful businesses breed a healthy economy, in any nation. A
>>>>>>>>>>>> healthy economy means more jobs and better pay for more people. With more
>>>>>>>>>>>> buying power, people can afford the products that will give them a better
>>>>>>>>>>>> standard of living.
>>>>>>>>>>>>
>>>>>>>>>>>> A better living standard will bring people a sense of
>>>>>>>>>>>> accomplishment, and pride, and dignity.
>>>>>>>>>>>>
>>>>>>>>>>>> And with it, a desire for social order that could be far
>>>>>>>>>>>> stronger than desire for violent disorder.
>>>>>>>>>>>>
>>>>>>>>>>>> To accomplish that, for business to be healthy and expanding,
>>>>>>>>>>>> it needs a constant flow of fresh capital.
>>>>>>>>>>>>
>>>>>>>>>>>> At IOS, our job is to convince people all over the world to
>>>>>>>>>>>> invest in business all over the world -- for a profit.
>>>>>>>>>>>>
>>>>>>>>>>>> And we don't mean just people who have million dollar
>>>>>>>>>>>> portfolios with us. We are also vitally interested in the small investor --
>>>>>>>>>>>> including the man who has never invested before.
>>>>>>>>>>>>
>>>>>>>>>>>> If this vast source of potential investment capital can be put
>>>>>>>>>>>> to work, IOS and our investors will, of course, make more money, but
>>>>>>>>>>>> equally important, businesses and people and national economies all over
>>>>>>>>>>>> the world will benefit from this much needed capital.
>>>>>>>>>>>>
>>>>>>>>>>>> And, very importantly, we are convinced that we and others in
>>>>>>>>>>>> the financial community will be participating in a sound business endeavor
>>>>>>>>>>>> which, almost as a by-product, could lead to perhaps the most effective
>>>>>>>>>>>> deterrent to war -- financial security.
>>>>>>>>>>>>
>>>>>>>>>>>> Right now, IOS does business on six continents -- in mutual
>>>>>>>>>>>> funds, banking, investment management, insurance and real estate. In the 12
>>>>>>>>>>>> years we've been in business, more than 500,000 people have
>>>>>>>>>>>> have invested more than one billion dollars through us.
>>>>>>>>>>>>
>>>>>>>>>>>> Our goal is to do business in every country in the free world
>>>>>>>>>>>> and on convincing more and more people to invest in businesses all over the
>>>>>>>>>>>> world.
>>>>>>>>>>>>
>>>>>>>>>>>> --
>>>>>>>>>>>>
>>>>>>>>>>>> *THERE'S MORE MONEY TO BE MADE OUT OF PEACE THAN OUT OF WAR.*
>>>>>>>>>>>>
>>>>>>>>>>>> --
>>>>>>>>>>>> Gunnar Donald Arthur Peter Larson
>>>>>>>>>>>>
>>>>>>>>>>>> *xNY.io - Bank.org*
>>>>>>>>>>>> 917-580-8053
>>>>>>>>>>>> NEW YORK, NEW YORK 10001
>>>>>>>>>>>> On Fri, Mar 21, 2025, 3:59 AM Gunnar Larson <g(a)xny.io> wrote:
>>>>>>>>>>>>
>>>>>>>>>>>>> Ms. Caswell:
>>>>>>>>>>>>>
>>>>>>>>>>>>> - *Did Meta Platforms work to "actively frustrate" xNY.io
>>>>>>>>>>>>> - Bank.org business operations world-wide; *
>>>>>>>>>>>>> - *Or did Meta Platforms work not to "actively frustrate"
>>>>>>>>>>>>> xNY.io - Bank.org business operations world-wide? *
>>>>>>>>>>>>>
>>>>>>>>>>>>> NJ Military Co. Says Ex-Director Took Trade Secrets To Rival
>>>>>>>>>>>>> <https://www.law360.com/competition/articles/2313517?nl_pk=6e763a2a-9f82-44c…>
>>>>>>>>>>>>>
>>>>>>>>>>>>> By Carolina Bolado
>>>>>>>>>>>>>
>>>>>>>>>>>>> A New Jersey company that produces lubricants for military
>>>>>>>>>>>>> artillery sued a former employee Wednesday, claiming he took the company's
>>>>>>>>>>>>> proprietary information and set up a rival company making a nearly
>>>>>>>>>>>>> identical product.
>>>>>>>>>>>>>
>>>>>>>>>>>>> Complaint attached | Read full article »
>>>>>>>>>>>>> <https://www.law360.com/competition/articles/2313517?nl_pk=6e763a2a-9f82-44c…>
>>>>>>>>>>>>> | Save to favorites »
>>>>>>>>>>>>> <https://www.law360.com/competition/articles/2313517?nl_pk=6e763a2a-9f82-44c…>
>>>>>>>>>>>>>
>>>>>>>>>>>>> Nippon Calls Consumer Suit Over US Steel Merger 'Baseless'
>>>>>>>>>>>>> <https://www.law360.com/competition/articles/2313485?nl_pk=6e763a2a-9f82-44c…>
>>>>>>>>>>>>>
>>>>>>>>>>>>> By Hailey Konnath
>>>>>>>>>>>>>
>>>>>>>>>>>>> Nippon Steel Corp. has urged a California federal court to
>>>>>>>>>>>>> throw out a consumer suit over its blocked $14.9 billion merger with U.S.
>>>>>>>>>>>>> Steel Corp., calling it yet another "in a long line of baseless lawsuits"
>>>>>>>>>>>>> over a merger of public companies that they have "no standing to challenge
>>>>>>>>>>>>> in the first place."
>>>>>>>>>>>>>
>>>>>>>>>>>>> Motion attached | Read full article »
>>>>>>>>>>>>> <https://www.law360.com/competition/articles/2313485?nl_pk=6e763a2a-9f82-44c…>
>>>>>>>>>>>>> | Save to favorites »
>>>>>>>>>>>>> <https://www.law360.com/competition/articles/2313485?nl_pk=6e763a2a-9f82-44c…>
>>>>>>>>>>>>>
>>>>>>>>>>>>> Chinese Pool Firms Banned From US Sales Until Judgment Is Paid
>>>>>>>>>>>>> <https://www.law360.com/competition/articles/2313510?nl_pk=6e763a2a-9f82-44c…>
>>>>>>>>>>>>>
>>>>>>>>>>>>> By Ryan Harroff
>>>>>>>>>>>>>
>>>>>>>>>>>>> A North Carolina federal judge barred multiple Chinese
>>>>>>>>>>>>> companies and their owner from importing and selling pool equipment in the
>>>>>>>>>>>>> United States until they pay off a prior $17.8 million judgment after
>>>>>>>>>>>>> finding them in contempt for "actively frustrating" collection efforts by
>>>>>>>>>>>>> moving money around despite restraining orders.
>>>>>>>>>>>>>
>>>>>>>>>>>>> Order attached | Read full article »
>>>>>>>>>>>>> <https://www.law360.com/competition/articles/2313510?nl_pk=6e763a2a-9f82-44c…>
>>>>>>>>>>>>> | Save to favorites »
>>>>>>>>>>>>> <https://www.law360.com/competition/articles/2313510?nl_pk=6e763a2a-9f82-44c…>
>>>>>>>>>>>>>
>>>>>>>>>>>>> xNY.io - Bank.org respectfully reserves all
>>>>>>>>>>>>> Interjurisdictional rights.
>>>>>>>>>>>>>
>>>>>>>>>>>>>
>>>>>>>>>>>>> Thank you,
>>>>>>>>>>>>>
>>>>>>>>>>>>>
>>>>>>>>>>>>> Gunnar Larson
>>>>>>>>>>>>>
>>>>>>>>>>>>> --
>>>>>>>>>>>>>
>>>>>>>>>>>>> Gunnar Donald Arthur Peter Larson
>>>>>>>>>>>>>
>>>>>>>>>>>>> xNY.io - Bank.org
>>>>>>>>>>>>>
>>>>>>>>>>>>> 917-580-8053
>>>>>>>>>>>>>
>>>>>>>>>>>>> On Fri, Mar 21, 2025, 3:23 AM Gunnar Larson <g(a)xny.io> wrote:
>>>>>>>>>>>>>
>>>>>>>>>>>>>> Ms. Caswell:
>>>>>>>>>>>>>>
>>>>>>>>>>>>>> xNY.io - Bank.org has made 37 highlights to Nanjing Audit
>>>>>>>>>>>>>> University's "*Can D&O insurance improve corporate ESG
>>>>>>>>>>>>>> performance*?" for Meta Platforms' Board.
>>>>>>>>>>>>>>
>>>>>>>>>>>>>> *Can D&O insurance improve corporate ESG performance?:*
>>>>>>>>>>>>>>
>>>>>>>>>>>>>> -
>>>>>>>>>>>>>> https://drive.google.com/file/d/1kYBR93f7fzdculQZk9MGUkPlX23WTKQm/view?usp=…
>>>>>>>>>>>>>>
>>>>>>>>>>>>>> *Musk Party Videos:*
>>>>>>>>>>>>>>
>>>>>>>>>>>>>> Ms. Caswell, "Party Video Two" is arguably funny; Applicable
>>>>>>>>>>>>>> to New York False Claims Act; NYAG contingent.
>>>>>>>>>>>>>>
>>>>>>>>>>>>>> - Musk Party Video One:
>>>>>>>>>>>>>> https://www.facebook.com/MayeMusk/videos/1793857438109391/?mibextid=CDWPTG
>>>>>>>>>>>>>> - Musk Party Video Two:
>>>>>>>>>>>>>> https://www.facebook.com/reel/1668070603848995?sfnsn=mo&mibextid=J7ZoRX
>>>>>>>>>>>>>>
>>>>>>>>>>>>>> xNY.io - Bank.org respectfully reserves all
>>>>>>>>>>>>>> Interjurisdictional rights.
>>>>>>>>>>>>>>
>>>>>>>>>>>>>> Thank you,
>>>>>>>>>>>>>>
>>>>>>>>>>>>>> Gunnar Larson
>>>>>>>>>>>>>> --
>>>>>>>>>>>>>> Gunnar Donald Arthur Peter Larson
>>>>>>>>>>>>>> xNY.io - Bank.org
>>>>>>>>>>>>>> 917-580-8053
>>>>>>>>>>>>>>
>>>>>>>>>>>>>> On Wed, Mar 19, 2025, 1:39 PM Gunnar Larson <g(a)xny.io> wrote:
>>>>>>>>>>>>>>
>>>>>>>>>>>>>>>
>>>>>>>>>>>>>>> ---------- Forwarded message ---------
>>>>>>>>>>>>>>> From: *Gunnar Larson* <g(a)xny.io>
>>>>>>>>>>>>>>> Subject: Litigating Universal Cognitive Liberty January 17,
>>>>>>>>>>>>>>> 2022 Commercial, Premium
>>>>>>>>>>>>>>>
>>>>>>>>>>>>>>> Check out my recent article:
>>>>>>>>>>>>>>> https://litigationfinancejournal.com/litigating-universal-cognitive-liberty/
>>>>>>>>>>>>>>>
>>>>>>>>>>>>>>> Litigating Universal Cognitive Liberty
>>>>>>>>>>>>>>>
>>>>>>>>>>>>>>> Freedom of thought is recognized by the Universal
>>>>>>>>>>>>>>> Declaration of Human Rights (UDHR). Interestingly,, cognitive liberty is
>>>>>>>>>>>>>>> not recognized as an international human right. Some want to change that,
>>>>>>>>>>>>>>> making the argument that humanity has the right to be free to think
>>>>>>>>>>>>>>> whatever they want (freedom of thought).
>>>>>>>>>>>>>>>
>>>>>>>>>>>>>>> The Ottawa Citizen reports
>>>>>>>>>>>>>>> <https://ottawacitizen.com/news/national/defence-watch/military-leaders-saw-…> that
>>>>>>>>>>>>>>> the Canadian armed forces have launched ‘psychological operations’ as an
>>>>>>>>>>>>>>> experiment in government propaganda to counter civil disobedience.
>>>>>>>>>>>>>>> International human rights scholars are quick to point out that the lack of
>>>>>>>>>>>>>>> protection of cognitive liberty in such instances is due to the relative
>>>>>>>>>>>>>>> lack of technology capable of directly interfering with mental autonomy at
>>>>>>>>>>>>>>> the time the core human rights treaties were created.
>>>>>>>>>>>>>>>
>>>>>>>>>>>>>>> Similar to a ransomware attack, the technology behind such
>>>>>>>>>>>>>>> operations can be abused. Canada is said to have exploited advanced
>>>>>>>>>>>>>>> technologies without the authority to do so. Even worse, it is alleged that
>>>>>>>>>>>>>>> Canada forcefully abused technology in the unsanctioned production of
>>>>>>>>>>>>>>> reports that appeared to be aimed at cognitive activities of Canadians.
>>>>>>>>>>>>>>>
>>>>>>>>>>>>>>> - Other reports highlight similar technologies being
>>>>>>>>>>>>>>> explored by the New Y
>>>>>>>>>>>>>>>
>>>>>>>>>>>>>>>
>>>>>>>>>>>>>>>
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Meta Accused Of Hiding $4B In Facebook Ad Overcharges
<https://www.law360.com/technology/articles/2324935?nl_pk=b6acf8b6-b37c-4b07…>
By Dorothy Atkins
South Carolina-based fitness company Iron Tribe has hit Meta Platforms Inc.
with a proposed class action in California federal court, alleging the
social media giant secretly overcharged Facebook advertisers $4 billion by
using a flawed "blended price" auction system that it hid from advertisers
and took years to correct.
Complaint attached | Read full article »
<https://www.law360.com/technology/articles/2324935?nl_pk=b6acf8b6-b37c-4b07…>
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<https://www.law360.com/technology/articles/2324935?nl_pk=b6acf8b6-b37c-4b07…>
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Allianz Unit Challenges Augusta Golf Club's $2.4M Award
<https://www.law360.com/insurance/articles/2325089?nl_pk=347c5954-47a8-495c-…>
By Chart Riggall
Allianz SE subsidiary Fireman's Fund Insurance Co. on Friday asked a
federal judge to strike down a $2.4 million storm damage appraisal in favor
of an Augusta, Georgia, golf club that the insurer said goes far beyond
what it agreed to cover.
Complaint attached | Read full article »
<https://www.law360.com/insurance/articles/2325089?nl_pk=347c5954-47a8-495c-…>
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<https://www.law360.com/insurance/articles/2325089?nl_pk=347c5954-47a8-495c-…>
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16 Apr '25
Insurers Not Liable For Counterfeit Drug Suit, 6th Circ. Says
<https://www.law360.com/insurance/articles/2325268?nl_pk=347c5954-47a8-495c-…>
By Elizabeth Daley
Insurers do not have to cover a Michigan pharmacy accused of selling
counterfeit HIV medication, the Sixth Circuit affirmed Monday, finding that
policy exclusions prevented the coverage.
Opinion attached | Read full article »
<https://www.law360.com/insurance/articles/2325268?nl_pk=347c5954-47a8-495c-…>
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<https://www.law360.com/insurance/articles/2325268?nl_pk=347c5954-47a8-495c-…>
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Ransomware Payouts, Forensic Costs Falling, Law Firm Says
<https://www.law360.com/health/articles/2324681?nl_pk=0f5983ea-0173-4e74-85e…>
By Allison Grande
The measures that companies are putting in place to guard against
ransomware attacks are starting to pay off, with the amount that's being
doled out to contain the impact of these incidents and the cost of forensic
investigations dropping last year, according to a new BakerHostetler report.
Report attached | Read full article »
<https://www.law360.com/health/articles/2324681?nl_pk=0f5983ea-0173-4e74-85e…>
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<https://www.law360.com/health/articles/2324681?nl_pk=0f5983ea-0173-4e74-85e…>
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