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Watch "President Trump Full Speech to Joint Session of Congress" on YouTube https://youtu.be/cR5Dmj6GK88?si=Cjo_Il0oSgveb27a
by Gunnar Larson 20 Mar '25

20 Mar '25

https://youtu.be/cR5Dmj6GK88?si=Cjo_Il0oSgveb27a Watch "President Trump Full Speech to Joint Session of Congress" on YouTube

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Del. House Panel Sends Corporate Law Rework To Final Vote
by Gunnar Larson 20 Mar '25

20 Mar '25

Del. House Panel Sends Corporate Law Rework To Final Vote <https://www.law360.com/mergersacquisitions/articles/2312777?nl_pk=34b724c6-…> By Jeff Montgomery A Delaware House committee on Wednesday sent toward a possible final House vote corporation law amendments that would create new "safe harbor" protections for officers, directors and controlling stockholders, shielding them from liability if they have conflicting interests in some corporate acts. Read full article » <https://www.law360.com/mergersacquisitions/articles/2312777?nl_pk=34b724c6-…> | Save to favorites » <https://www.law360.com/mergersacquisitions/articles/2312777?nl_pk=34b724c6-…>

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Swiss Bank Accused Of Ignoring $1B Kuwaiti Bribery Scheme
by Gunnar Larson 20 Mar '25

20 Mar '25

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…>

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'WE GOT LAZY': Vice President JD Vance outlines the dramatic steps the Trump administration is taking to "undo 40 years of failed economic policy" in the United States, charting the course for successful businesses to be built right here in America. https://www.facebook.com/share/r/15zEpaXYmc/
by Gunnar Larson 20 Mar '25

20 Mar '25

https://www.facebook.com/share/r/15zEpaXYmc/ 'WE GOT LAZY': Vice President JD Vance outlines the dramatic steps the Trump administration is taking to "undo 40 years of failed economic policy" in the United States, charting the course for successful businesses to be built right here in America.

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https://www.instagram.com/reel/DHYjBJpsqW6/?igsh=MTUza2U0MzlrOXFucw==
by Gunnar Larson 19 Mar '25

19 Mar '25

https://www.instagram.com/reel/DHYjBJpsqW6/?igsh=MTUza2U0MzlrOXFucw==

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Gunnar Larson for Vice President: https://www.instagram.com/reel/DHY94YguvMk/?igsh=MTUyZ253aXo0NXBpOA==
by Gunnar Larson 19 Mar '25

19 Mar '25

https://www.instagram.com/reel/DHY94YguvMk/?igsh=MTUyZ253aXo0NXBpOA== Gunnar Larson for Vice President

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Watch "264th NYC St. Patrick's Day Parade 2025" on YouTube
by Gunnar Larson 19 Mar '25

19 Mar '25

https://www.youtube.com/live/cxadWKKg7I8?si=5iDXMYrvr63Rk5h4 Watch this

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Glad to see astronauts Sunita Williams and Barry Wilmore return safely to Earth. Their journey back shows exemplary human determination and teamwork. I applaud everyone who made it possible and salute the astronauts for their strength and perseverance. Wishing them good health!
by Gunnar Larson 19 Mar '25

19 Mar '25

https://www.facebook.com/share/p/12GCf8PgCfJ/ Glad to see astronauts Sunita Williams and Barry Wilmore return safely to Earth. Their journey back shows exemplary human determination and teamwork. I applaud everyone who made it possible and salute the astronauts for their strength and perseverance. Wishing them good health!

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Assistant Chief DJ wants all of you to know that we are hiring for a full time patrol officer position. If you are interested in applying, email Lt. Bennett Thomas at bthomas@kemahtx.gov. The starting pay is $58,000. https://www.facebook.com/share/p/1M6hyZAD9J/
by Gunnar Larson 19 Mar '25

19 Mar '25

https://www.facebook.com/share/p/1M6hyZAD9J/ Assistant Chief DJ wants all of you to know that we are hiring for a full time patrol officer position. If you are interested in applying, email Lt. Bennett Thomas at bthomas(a)kemahtx.gov. The starting pay is $58,000.

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Re: Memo #4 - Goldman Sachs Deferred Prosecution Agreement; Trading Giant Virtu Must Face Suit Over Confidentiality Issues
by Gunnar Larson 19 Mar '25

19 Mar '25

Goldman Sachs: Trading Giant Virtu Must Face Suit Over Confidentiality Issues <https://www.law360.com/capitalmarkets/articles/2312402?nl_pk=35f19b02-1b5d-…> By Katryna Perera A New York federal judge has trimmed a consolidated class action accusing trading giant Virtu Financial Inc. of misleading investors on issues around access to confidential customer trading information, finding that one category of statements in the complaint is not actionable but otherwise allowing the suit to proceed. Order attached | Read full article » <https://www.law360.com/capitalmarkets/articles/2312402?nl_pk=35f19b02-1b5d-…> | Save to favorites » <https://www.law360.com/capitalmarkets/articles/2312402?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 On Tue, Mar 18, 2025, 12:46 PM Gunnar Larson <g(a)xny.io> wrote: > Goldman Sachs: > > The whole idea of Goldman Sachs' Deferred Prosecution Agreement is to > uphold oversight of the Board Directors' Independence; To uphold the > Agreement's mandates; And to respect 'third-party' relationships. > > Littler Elects 6 New Members To Board Of Directors > <https://www.law360.com/mergersacquisitions/articles/2311598?nl_pk=34b724c6-…> > > By Tracey Read > > Littler Mendelson PC has elected six new members to its 19-member, 2025 > board of directors, the management-side employment and labor law firm > announced Monday. > > Read full article » > <https://www.law360.com/mergersacquisitions/articles/2311598?nl_pk=34b724c6-…> > | Save to favorites » > <https://www.law360.com/mergersacquisitions/articles/2311598?nl_pk=34b724c6-…> > > Activist Investor Calls For Reconstitution Of Parkland's Board > <https://www.law360.com/mergersacquisitions/articles/2311698?nl_pk=34b724c6-…> > > By Jade Martinez-Pogue > > Activist hedge fund Engine Capital on Monday called for a comprehensive > reconstitution of Calgary, Alberta-based Parkland Corp.'s board of > directors, saying that the current board has overseen "meaningful > underperformance" and demonstrated "zero interest" in engaging with its > shareholders. > > Read full article » > <https://www.law360.com/mergersacquisitions/articles/2311698?nl_pk=34b724c6-…> > | Save to favorites » > <https://www.law360.com/mergersacquisitions/articles/2311698?nl_pk=34b724c6-…> > > 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 employee, customer and vendor data requirements. > > *Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:* > > - > https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=… > > *"Proper Oversight and Independence * > > > - *7. The Company will assign responsibility to one or more senior > corporate executives **of the Company for the implementation and > oversight of the Company’s anti-corruption **compliance code, > policies, and procedures. Such corporate official(s) shall have the > authority to **report directly to independent monitoring bodies, > including internal audit, the Company’s Board **of Directors, or any > appropriate committee of the Board of Directors, and shall have an > adequate **level of stature and autonomy from management as well as > sufficient resources and authority to **maintain such autonomy.* > > *Third-Party Relationships* > > > - *14. The Company will institute appropriate risk-based due diligence > and compliance **requirements pertaining to the retention and > oversight of all agents and business partners, **including: **a. properly > documented due diligence pertaining to the hiring and appropriate **and > regular oversight of agents and business partners; ..."* > > 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 Tue, Mar 18, 2025, 7:13 AM Gunnar Larson <g(a)xny.io> wrote: > >> Goldman Sachs: >> >> Your firm's Deferred Prosecution Agreement with the United States of >> America was a supreme agreement; To protect New Yorkers and Americans from >> Goldman Sachs' potential future descresions. >> >> *xNY.io - Bank.org's running hypothesis is to move the Deferred Agreement >> conversation forward on or before March 24, 2025. * >> >> 6 Bombshell Moments From Staley's Bid To Clear His Name >> <https://www.law360.co.uk/financial-services-uk/articles/2311596?nl_pk=9aaa8…> >> >> By Christopher Crosby >> >> Jes Staley has suffered a bruising week as he testified about his >> relationship with Jeffrey Epstein, culminating in an admission by the >> former banker that he had sex with a member of the disgraced financier's >> staff. >> >> Read full article » >> <https://www.law360.co.uk/financial-services-uk/articles/2311596?nl_pk=9aaa8…> >> | Save to favorites » >> <https://www.law360.co.uk/financial-services-uk/articles/2311596?nl_pk=9aaa8…> >> >> - Further inquiry could eventually summerise an enterprise software >> racket perpetuated by Goldman Sachs; >> - Perhaps, an enterprise software RICO could be argued visavie >> Goldman Sachs' software relationships at Coinbase, Fireblocks, Robinhood, >> Apple Card and WorldBank.org; >> - While under active Deferred Prosecution Agreement with the United >> States of America. >> >> FCA Fines, Bans Odey For Obstructing Misconduct Probe >> <https://www.law360.co.uk/financial-services-uk/articles/2311414?nl_pk=9aaa8…> >> >> By Christopher Crosby >> >> The Financial Conduct Authority banned Crispin Odey on Monday and fined >> the hedge fund boss £1.8 million ($2.3 million) after concluding that he >> had attempted to thwart an internal probe into sexual misconduct >> allegations. >> >> Read full article » >> <https://www.law360.co.uk/financial-services-uk/articles/2311414?nl_pk=9aaa8…> >> | Save to favorites » >> <https://www.law360.co.uk/financial-services-uk/articles/2311414?nl_pk=9aaa8…> >> xNY.io - Bank.org's research could paint a stark image for Gomdman Sachs' >> Board Directors if the firm knowingly made efforts to defraud the United >> States of America *AND *xNY.io - Bank.org symaltaniouly; While under an >> active Deferred Prosecution Agreement with the United States of America. >> >> 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 >> >> ---------- Forwarded message --------- >> From: *Laura Peavey* <lpeavey(a)fsforum.com> >> Date: Mon, Mar 17, 2025, 5:22 PM >> Subject: Forum Welcomes Nomination for Fed Vice Chair for Supervision >> To: Gunnar Larson <G(a)xny.io> >> >> >> The Forum congratulates Michelle Bowman on her nomination to serve as the >> Federal Reserve Board’s Vice Chair for Supervision. >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-r/> >> >> *Forum Welcomes Nomination for Fed Vice Chair for Supervision* >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-y/> >> >> *“Banking regulation and supervision play critical roles in ensuring a >> safe and sound financial system.”* >> >> *Washington, D.C. – *Financial Services Forum President and CEO Kevin >> Fromer issued the following statement today after President Trump announced >> his nomination of Federal Reserve Governor Michelle Bowman to serve as the >> Federal Reserve Board’s Vice Chair for Supervision: >> >> “The Forum congratulates Governor Bowman on her nomination and commends >> President Trump for his action to fill this position. Banking regulation >> and supervision play critical roles in ensuring a safe and sound financial >> system. The Vice Chair for Supervision focuses on the policies and >> practices which affect the ability of banks to serve our economy and >> contribute to financial stability. America’s leading banks—the strongest >> and most diversified financial institutions based in the United States—look >> forward to working with the next Vice Chair for Supervision to implement >> sound regulation and effective supervision that promotes economic growth.” >> >> ### >> >> *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-thttudn-njyjukhihy-j/> >> >> *Follow us on X **@fsforum* >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-t/> >> * and **LinkedIn* >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-i/> >> >> >> [image: Twitter] >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-d/>[image: >> LinkedIn] >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-h/>[image: >> Website] >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-k/>[image: >> Instagram] >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-u/>[image: >> Threads] >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-o/>[image: >> YouTube] >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-b/> >> >> <https://financialservicesforum.cmail20.com/t/r-l-thttudn-njyjukhihy-n/> >> >> 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. >> >> On Mon, Mar 17, 2025, 3:02 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 >>> >>> *----- (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. >>>>>> >>>>>>

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