- cypherpunks - lists.cpunks.org

Death of a cypherpunk
by pro2rat＠yahoo.com.au 08 Apr '24

08 Apr '24

OG Toadie, John Gilmore, failing the anarchist test and contributing to a death-of-cypherpunks thread in the late 90s. Barlow instant fail- DOA Republican Kapor fail by 2000 - death by Lotus Position Hughes fail by 2002 - the coward dies a thousand deaths Gilmore? Activist sure. Anarchist? Never to my knowledge. https://hackernoon.com/cypherpunks-write-code-john-gilmore-and-the-electron…

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SpaceX Corporation Board of Directors One Rocket Road Hawthorne, California 90250 Sales@SpaceX.com Re: Potential SpaceX Interlocking Directors’ Intent to Manipulate Markets
by Gunnar Larson 07 Apr '24

07 Apr '24

https://docs.google.com/document/d/1lv9Wt6y1ld4bNap0z3epIxttEGiP_oVpfxH0GTS… May 21, 2022 BY ELECTRONIC MAIL SpaceX Corporation Board of Directors One Rocket Road Hawthorne, California 90250 Sales(a)SpaceX.com Re: Potential SpaceX Interlocking Directors’ Intent to Manipulate Markets Dear SpaceX Board of Directors: >From our New York headquarters, xNY.io - Bank.org, PBC embodies the notion that rather than a merry-go-round, the process of change and innovation is like a slide. Today’s memo aims to notify the SpaceX Corporation of concern of potential market manipulation that could impact cross-border digital asset innovation, free speech in the United States of America, the global ESG economy and Moon exploration. We do not see this as a stereotypical democrat versus republican battle (as Mr. Musk alludes). We see this as a risk arbitrage matter for xNY.io - Bank.org’s profit (subject to regulatory approval). Some may argue a scheme to leverage the protection of “free speech” has led to Twitter deal advisors attempting a $44B LBO market manipulation exercise. Further cause for reasonable concern is warranted if similar intent is at play in the form of Tesla’s ESG scam claim. xNY.io - Bank.org indicators signal risk of possible intent to manipulate public and private markets prompting clarification of the SpaceX Corporation’s intent concerning Moon exploration and exploitation as a ESG digital asset vault. To be very clear, SpaceX directors should understand xNY.io - Bank.org’s work to protect cross-border digital asset innovation was born before Twitter's prospective LBO. Our concern specific to the intent of Twitter’s LBO deal makers is party to our work in New York to usurp Goldman Sachs and JP Morgan Chase board directors who may be potentially engaged in similar market manipulation referenced here: 1. xNY.io - Bank.org | DOJ Memo #4 - Goldman Sachs Deferred Prosecution Agreement. 2. xNY.io - Bank.org | Memo #2 - JPMorgan Chase Board of Directors ESG Marketplace Manipulation. 3. xNY.io - Bank.org’s work also includes research into oil and nickel marketplace manipulation as an ESG concern. The Twitter LBO includes Goldman Sachs and JP Morgan Chase operating as deal advisors. As referenced above, claims of Twitter robot scams and claims of Tesla ESG scams display a pattern of questionable intent. xNY.io - Bank.org asks SpaceX to clarify your board's intent concerning the Moon and any connection to USDD (now in Moon phase). SpaceX directors may agree that the Moon can also be defined as one of the most valuable ESG digital asset vaults known to modern humanity. Protecting the Moon from explo8itation is fundamental to Space exploration. SpaceX is party to any potential Twitter deal maker advisors that may exercise questionable intent risking the Moon’s ESG vault potential. xNY.io - Bank.org is concerned with interlocking directorate syndicates that include SpaceX, Tesla, PayPal, Goldman Sachs and BitGo. This setup breeds a galaxy of third and fourth party risk(s) at the demise of pure cross-border digital asset innovation. Twitter robots are not the focus of the Orlando Police Department Pension Fund, who suggests that Twitter’s LBO is suspected of questionable intent as potentially illegal. - Mr. Musk’s ingenuity as an entrepreneur is historic and greatly respected as a model inside our organization. As a Gates Scholar and Blockchain Scholar holding international law distinction(s) The concept of the Moon being an ESG digital asset vault is logic USDD seemingly embodies. - For obvious reasons, we seek SpaceX’s board to confirm if the intent behind your CEO’s Twitter LBO and Tesla ESG claims and if SpaceX is party to a USDD type matter given your syndicate’s close association with USDP. xNY.io - Bank.org kindly asks the SpaceX Corporation board of directors to respond within 15 days of receipt of this correspondence. Default in the form of no response within 15 days is not an extortion technique on our part. Rather, it is a design benefit in disclosing our intent post 15 days to ask for approval to engage New York’s False Claims Act in response to SpaceX, Tesla, PayPal and Meta interlocking directors potentially engaging in digital asset marketplace manipulation (exemplified by USDP and USDD) that may exploit Space and Moon exploration at xNY.io - Bank.org, PBC’s overall expense. Respectfully yours, 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 CC: Tesla Board of Directors Twitter Board of Directors Goldman Sachs Board of Directors JP Morgan Chase Board of Directors

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Fwd: Your Freedom of Information Law ("FOIL") Request FOIL-2023-095358-021587 - Robinhood BitLicense Records Appeal - NY-DFS
by Gunnar Larson 07 Apr '24

07 Apr '24

---------- Forwarded message --------- From: Gunnar Larson <g(a)xny.io> Date: Wed, Feb 21, 2024, 2:21 PM Subject: Fwd: Your Freedom of Information Law ("FOIL") Request FOIL-2023-095358-021587 - Robinhood BitLicense Records Appeal - NY-DFS To: Mazza, Stephanie (DFS) <Stephanie.Mazza(a)dfs.ny.gov> Cc: Reader, Shaun <sreader(a)curtis.com>, <letitia.james(a)ag.ny.gov>, Harris, Adrienne A (DFS) <Adrienne.Harris(a)dfs.ny.gov>, < Recordsaccessofficer(a)dfs.ny.gov>, <cypherpunks(a)cpunks.org> In accordance with Public Officers Law § 89(4), xNY.io - Bank.org elects to appeal this determination to withhold the Robinhood BitLicense Records. Turn this matter as we will, any side whatsoever appears to require obstruction of justice. We further demand NY-DFS send xNY.io - Bank.org an update on the aforementioned appeal within five (5) business days. Reserving all rights, xNY.io - Bank.org is seeking relevant relief in California on Robinhood. Warm regards, Gunnar ---- SENT VIA EMAIL Email: G(a)xny.io February 21, 2024 Mr. Gunnar Larson xNY.io – Bank.org 406 West 25th Street New York, NY 10001 Re: Freedom of Information Law (“FOIL”) Tracking No. 2023-095358 Dear Mr. Larson, I write in response to the FOIL request that you submitted to the New York State Department of Financial Services (“Department”), which has been assigned the above-referenced tracking number and reads as follows: Dear Madam or Sir: On August 2, 2022 the Superintendent of Financial Services Adrienne A. Harris announced that Robinhood Crypto, LLC (“RHC”) would pay a $30 million penalty to New York State for significant failures in the areas of bank secrecy act/anti-money laundering (“BSA/AML”) obligations and cybersecurity that resulted in violations of the Department’s Virtual Currency Regulation (23 NYCRR Part 200), Money Transmitter Regulation (3 NYCRR Part 417), Transaction Monitoring Regulation (23 NYCRR Part 504), and Cybersecurity Regulation (23 NYCRR Part 500). xNY.io - Bank.org would like to 1. receive any and all records related to NY-DFS' investigation of Robinhood Crypto. Including (but not limited to) records concerning the bespoke Supervisory Agreement Robinhood Crypto has with the Department of Financial Services mentioned here: https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202208021. 2. In addition, xNY.io - Bank.org seeks any and all records concerning New York's approach to Robinhood Crypto and Goldman Sachs compliance programs mandated by the United States Department of Justice, Criminal Division, Fraud Section and Money Laundering and Asset Recovery Section mentioned here: https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r- m8N21_1Sp/view?usp=drivesdk. 3. Finally, xNY.io - Bank.org seeks records concerning New York's regulatory approval of Robinhood Crypto engaging a fine of $30M to implement heightened controls and additional procedures and policies relating to electronic surveillance and investigation, due diligence on transactions or clients and the use of third-party intermediaries across business units; and enhancing anti-corruption training for all management and relevant employees. To the extent the request is reasonably described, the Department construes the request as seeking the records, correspondence, and work product exchanged between Robinhood and the Department in accordance with the Department’s August 1, 2022 Consent Order (“responsive records”). The records that you seek relate to an ongoing Department investigation. Accordingly, your request is denied pursuant to Public Officers Law § 87(2)(e)(i) (the “law enforcement exemption”), which excepts from disclosure records that are compiled for law enforcement purposes and that, if disclosed, would interfere with law enforcement investigations. The purpose behind the law enforcement exemption is to protect an agency’s investigative process from being compromised by revealing the scope and nature of an agency's investigation before an investigation is complete. See Matter of Pittari v. Pirro, 258 A.D.2d 202 (2d Dep’t 1999). It also bears noting that the law enforcement exemption applies to both civil and criminal investigatory files. See Madeiros v. Dep’t of Educ., 30 N.Y.3d 67 (2017). In this instance, releasing the requested records would interfere with the Department’s investigative process. Thus, the Department is not disclosing the records that you request pursuant to Public Officers Law § 87(2)(e)(i). Moreover, in addition to withholding the responsive records pursuant to Public Officers Law § 87(2)(e)(i), the Department also is withholding the responsive records pursuant to Public Officers Law § 87(2)(a), which specifically exempts from disclosure records exempted by a state or federal statute. The applicable statutory provision is N.Y. Banking Law (“Banking Law”) § 36(10), which states, in pertinent part, that reports of examinations and investigations and correspondence and memoranda concerning or arising out of such examinations and investigations are confidential and shall not be made public. The statute fosters open communication between the Department and its regulated institutions, a necessity for effective regulation of financial institutions, by ensuring that records transmitted to the Department in connection with its supervision of a financial institution are protected from disclosure. The responsive records that were transmitted between Robinhood and the Department in connection with the Department’s supervision of Robinhood as a licensed money transmitter pursuant to New York Banking Law, constitute correspondence and reports concerning and arising out of an investigation and are, therefore, required to be kept confidential and exempt from disclosure under Banking Law § 36(10). The expectation that records transmitted to the Department will remain confidential is essential to encouraging candor and open communications between the Department, its regulated entities, and the entities undergoing regulatory review that submit such records. Release of such sensitive records, albeit responsive records, may have a chilling effect on the willingness of regulated entities to share information and cooperate with supervisors to resolve issues, and thus confidentiality is critical to the Department’s ability to perform its regulatory mandate and purpose. Accordingly, the exemption set forth in Public Officers Law § 87(2)(a) via Banking Law § 36(10) covers the responsive records. In accordance with Public Officers Law § 89(4), you may appeal this determination to withhold the records within 30 days by sending an email to FOIL.Appeals(a)dfs.ny.gov. Very truly yours, Stephanie Mazza Associate Attorney ---------- Forwarded message --------- From: <Stephanie.Mazza(a)dfs.ny.gov> Date: Wed, Feb 21, 2024, 1:26 PM Subject: Your Freedom of Information Law ("FOIL") Request FOIL-2023-095358-021587 To: <G(a)xny.io> Dear Mr. Larson: Attached please find the Department's determination regarding the aforementioned FOIL request. Because your request has been answered, your request is now closed. Tracking Number:FOIL-2023-095358-021587

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F.B.I. Examining Free Airfare Upgrades Received by Adams - The New York Times
by Gunnar Larson 07 Apr '24

07 Apr '24

https://www.nytimes.com/2024/04/05/nyregion/eric-adams-turkish-airlines-upg… F.B.I. Examining Free Airfare Upgrades Received by Adams Federal prosecutors and F.B.I. agents are scrutinizing international flights taken by Mayor Eric Adams of New York aboard Turkey’s national air carrier, Turkish Airlines. Share full article 54 Mayor Eric Adams photographed at a news conference while wearing a dark suit and tie. The campaign fund-raising of Mayor Eric Adams of New York has been the subject of a broad federal corruption investigation.Credit...David Dee Delgado for The New York Times William K. RashbaumMichael RothfeldDana Rubinstein By William K. Rashbaum, Michael Rothfeld and Dana Rubinstein April 5, 2024 Federal authorities investigating Mayor Eric Adams’s campaign fund-raising have been examining valuable flight upgrades they believe he received from Turkish Airlines that elevated him to its highest class of seats available on international trips, according to people with knowledge of the matter. The scrutiny is part of a broad corruption inquiry that has already led the F.B.I. to search the homes of the former top New York-based executive of Turkish Airlines and aides to Mr. Adams, who has frequently traveled abroad and has made no secret of his affinity for flying on the Turkish carrier. The investigation burst into public view in November after F.B.I. agents searched the homes of the former airline executive, Cenk Öcal, the mayor’s liaison to the Turkish community, Rana Abbasova, and his chief fund-raiser, Brianna Suggs — and seized Mr. Adams’s electronic devices. The inquiry has shaken an administration that has become increasingly mired in investigations and beset by legal and ethical problems. ADVERTISEMENT SKIP ADVERTISEMENT The broader investigation has focused at least in part on whether the Turkish government conspired with Mr. Adams’s mayoral campaign to funnel foreign money into its coffers, and whether Mr. Adams pressured the New York City Fire Department to sign off on Turkey’s new high-rise consulate in Manhattan despite safety concerns. Mr. Adams’s relationship with Turkish Airlines has extended beyond that of simply being a passenger. He has attended meetings and events with representatives of the air carrier, which is half-owned by the Turkish government’s sovereign wealth fund. Some of those interactions took place in the presence of Turkish business leaders and diplomats with their own close ties to Turkey’s government and its president, Recep Tayyip Erdoğan. Federal prosecutors in Manhattan and F.B.I. agents conducting the inquiry have developed evidence that Mr. Öcal helped arrange at least some of the upgrades in coordination with Ms. Abbasova, two of the people familiar with the federal investigation said. They and others interviewed for this article spoke on condition of anonymity to discuss the ongoing federal investigation. Mr. Adams, who extolled Turkish Airlines in 2017 when he told a pro-government publication that the carrier “is my way of flying,” received the upgrades both while serving as Brooklyn borough president and as mayor, on both official and personal trips, some of the people said. ADVERTISEMENT SKIP ADVERTISEMENT Brendan R. McGuire, a lawyer for the mayor and his 2021 campaign, said there was nothing wrong with Mr. Adams’s receipt of the upgrades. “As borough president, the mayor consistently disclosed his official travel to Turkey, did not receive any improper upgrades and did nothing inappropriate in exchange for an upgrade,” Mr. McGuire said. “Speculation is not evidence. We look forward to a just and timely conclusion to this investigation.” The F.B.I. searches on Nov. 2 prompted the mayor’s abrupt return from a trip to Washington, D.C., where he was seeking federal aid for the city’s migrant crisis. They were followed by weeks of news coverage focused on the corruption inquiry, but agents and prosecutors have made few public moves since then. Mr. Adams has not been accused of wrongdoing, and it remains unclear whether the investigation will lead to criminal charges against him, Mr. Öcal, Ms. Abbasova or anyone else. ADVERTISEMENT SKIP ADVERTISEMENT A lawyer for Ms. Abbasova, Rachel Maimin, declined to comment. After repeated attempts to reach Mr. Öcal, including visits to his New Jersey home and messages left with his wife, he declined to answer questions or provide the name of his lawyer. A representative of Turkish Airlines declined to comment, as did spokesmen for the F.B.I. and the federal prosecutors from the U.S. attorney’s office for the Southern District of New York, who are jointly conducting the inquiry. Mr. Adams has long boasted of being an avid traveler, and he has taken trips in recent years to Turkey, the Dominican Republic, Trinidad and Tobago, Ecuador, Colombia, Mexico, Monaco, Ghana, Azerbaijan, Greece, Israel, Jordan, Saudi Arabia, Qatar, Senegal and China. He has talked about retiring to Azerbaijan, Israel and Lebanon. It was unclear how many free upgrades Mr. Adams accepted while flying Turkish Airlines or what their total value was. In 2023, round-trip business class seats on Turkish Airlines between the United States and Turkey generally cost at least $3,400 apiece — or about four times as much as an economy class seat, travel industry experts said. ADVERTISEMENT SKIP ADVERTISEMENT It was also unclear what, if anything, Mr. Öcal, the airline or the Turkish government might have gained from awarding the upgrades. But Mr. Adams received the upgrades during a period in which he and the airline were developing a close relationship, a New York Times review of city emails suggests. Mr. Adams has flown on Turkish Airlines since at least August 2015, when as Brooklyn borough president he took an official trip to Turkey and the carrier funded travel that his aides valued at about $1,500. Mr. Adams took a second official trip four months later, justifying it by saying he needed to speak about “city marketing” at a conference, meet with local officials and visit a refugee camp, city records show. Mr. Adams flew Turkish Airlines on that trip as well, according to the records. ADVERTISEMENT SKIP ADVERTISEMENT On another trip to Turkey in 2017, this time in a private capacity, he gave an interview praising Turkish Airlines to The Daily Sabah, saying that it accommodated his dietary needs and lauding its security protocols. Sent from 2015 to 2021, while Mr. Adams was borough president, the emails reviewed by The Times make reference to a series of private meetings between Mr. Adams, Turkish Airlines executives and Turkish government officials and businesspeople, as well as appearances with them at public events. Image An excerpt from an email about scheduling a dinner with Mr. Adams and Turkish Airlines. Emails obtained by The New York Times show that Mr. Adams’s relationship with Turkish Airlines dates at least to his time as Brooklyn borough president. Often the meetings and appearances were arranged through Ms. Abbasova, Mr. Adams’s liaison to the Turkish community. ADVERTISEMENT SKIP ADVERTISEMENT More than a few involved Mr. Öcal, who appeared to be on a first-name basis with Mr. Adams. “Cenk from turkish airlines opening,” Mr. Adams wrote to his staff in response to one invitation to an event, possibly referring to Mr. Öcal’s speaking slot. Mr. Öcal would later serve as one of several hundred people on Mr. Adams’s mayoral transition team. The first meeting described in the emails was scheduled for May 2016, when Ms. Abbasova inquired if he could attend a “dinner w Turkish Airlines.” The emails did not specify with whom he would be meeting, but his assistant responded that he would be available. He agreed to another meeting, a dinner with Mr. Öcal at Liman, a Turkish restaurant in Brooklyn, in April 2017, the emails show. Also scheduled to attend were the chairman and treasurer of the Türken Foundation, an American charity with close ties to the Turkish government. It was incorporated in 2014 by a son of Mr. Erdoğan and another man, who at the time was a board member of Turkish Airlines. Mr. Erdoğan’s daughter currently sits on its board. Image Another excerpt from an email. Mr. Adams attended meetings and events with Turkish business and government officials. The Türken Foundation’s chairman, Behram Turan, its treasurer, Memiş Yetim, and another board member would go on to give a total of $6,000 to Mr. Adams’s mayoral campaign from 2018 to 2021, contributions that were first reported by The City. Mr. Adams’s campaign refunded $1,000 to Mr. Turan to comply with the rules of the city’s public matching funds program. ADVERTISEMENT SKIP ADVERTISEMENT Reached late last year, Mr. Turan, an engineer who lives in New Jersey, said he was an American citizen who has lived in the country for 30 years. He added that there was nothing inappropriate about his donation. On Thursday, Mr. Yetim said he could not remember the dinner with Mr. Adams. Mr. Turan declined to comment. In September 2017, Mr. Adams attended a Türken Foundation dinner and event with Mr. Erdoğan at the Mandarin Oriental hotel in Manhattan. Mr. Adams would later present Mr. Yetim with a proclamation honoring the Türken Foundation for “outstanding achievements and contributions to society.” In December 2017, Mr. Adams was scheduled to attend another dinner, this time with Turkish consular officials, at a Brooklyn seafood restaurant run by two of his close friends. Mr. Öcal and another top Turkish Airlines official were on the guest list, the emails show. ADVERTISEMENT SKIP ADVERTISEMENT In 2019, the emails show, Ms. Abbasova passed along an invitation from Turkish Airlines for Mr. Adams to attend a gala at the Metropolitan Club in Manhattan. Mr. Adams had another event that night but an internal staff memo noted that he would do his best to attend, the emails show. Ms. Abbasova would be on site and provide frequent updates, the memo said. Mr. Adams did make it to the event, which featured Turkish dishes, a raw bar and high-end cocktails. He even took the microphone to speak, according to an article in Elite Traveler, a luxury lifestyle publication, which published photos of the event, including several of Mr. Öcal in a shiny blue tuxedo. Mr. Adams was the only city official listed in the account of the night, along with Turkish consular officials and diplomats, business leaders and Martha Stewart. Mr. Adams won the Democratic mayoral primary in June 2021. Soon after, he contacted the commissioner of the New York Fire Department at the time and urged him to allow the opening of the Turkish consulate building, which had been held up over fire safety concerns. The building received a temporary certificate of occupancy that September — shortly before Mr. Erdoğan presided over the consulate’s grand opening in Manhattan. Mr. Adams previously said it was part of his role as borough president “to notify government agencies of issues on behalf of constituents and constituencies.” ADVERTISEMENT SKIP ADVERTISEMENT In May 2022, the Turkish Philanthropy Funds, a New-York based nonprofit devoted to supporting social investments in the Turkish and Turkish American communities, held its 15th anniversary gala at the Metropolitan Museum of Art. Mr. Adams, who made remarks at the event, was there in a dark suit, posing with the foundation’s chairman and the night’s honoree, the billionaire founder of the strained yogurt company Chobani. Mr. Öcal was there too, and was photographed in a tuxedo with the Turkish ambassador to the United States and their wives. It is unclear if he interacted with Mr. Adams that night. Their fortunes had gone in opposite directions. Mr. Öcal had been fired by Turkish Airlines by then, according to a Turkish news report, and Mr. Adams was newly ensconced as the mayor.

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Video: Put the puck in the back of the net, Gunnar
by Gunnar Larson 07 Apr '24

07 Apr '24

Video: Put the puck in the back of the net, Gunnar https://www.instagram.com/p/C3VWQBasHan/?igsh=MXg0aTlseHN4b2UxNQ==

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Video: Movies and Innovation (Smoking Gun)
by Gunnar Larson 07 Apr '24

07 Apr '24

Movies and Innovation Video (Smoking Gun): https://www.instagram.com/reel/C23Ph80vP5l/?igsh=MXZhd2dqNDZ3ejNlYg==

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Fwd: xNY.io - Bank.org, PBC | Memo #1 - The People’s Republic of China on ESG and D&O Innovation
by Gunnar Larson 07 Apr '24

07 Apr '24

---------- Forwarded message --------- From: Gunnar Larson <g(a)xny.io> Date: Wed, Jun 8, 2022, 2:12 PM Subject: xNY.io - Bank.org, PBC | Memo #1 - The People’s Republic of China on ESG and D&O Innovation To: <Adrienne.Harris(a)dfs.ny.gov> Cc: Weber, Richard (DFS) <Richard.weber(a)dfs.ny.gov>, Weintraub, Cathy (DFS) <Cathy.Weintraub(a)dfs.ny.gov>, Alexi Anania <a(a)xny.io> June 8, 2022 BY ELECTRONIC MAIL Superintendent, Adrienne A. Harris New York State Department of Financial Services One State Street New York, New York 10004 Adrienne.Harris(a)dfs.ny.gov Re: The People’s Republic of China on ESG and D&O Innovation Dear Madam Superintendent: xNY.io - Bank.org, PBC is proud to be under the esteemed oversight of your distinguished office. Today’s memo signals concern of recent ESG and D&O research published by Nanjing Audit University of the People’s Republic of China. The institution is operated under the auspices of the Jiangsu <https://en.wikipedia.org/wiki/Jiangsu> Provincial Government, the National Audit Office of China <https://en.wikipedia.org/wiki/National_Audit_Office_of_China> and the People's Bank of China <https://en.wikipedia.org/wiki/People%27s_Bank_of_China>. Kindly find the attached memo <https://docs.google.com/document/d/1THKGP530wiMOKurCd79mHSFfW6GvCrOJsRzyA_J…> addressed to your honorable attention. Respectfully yours, Gunnar Larson -- *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 New York, New York 10001 June 8, 2022 BY ELECTRONIC MAIL Superintendent, Adrienne A. Harris New York State Department of Financial Services One State Street New York, New York 10004 Adrienne.Harris(a)dfs.ny.gov Re: The People’s Republic of China on ESG and D&O Innovation Dear Madam Superintendent: xNY.io - Bank.org, PBC is proud to be under the esteemed oversight of your distinguished office. Today’s memo signals concern of recent ESG and D&O research published by Nanjing Audit University of the People’s Republic of China. The institution is operated under the auspices of the Jiangsu <https://en.wikipedia.org/wiki/Jiangsu> Provincial Government, the National Audit Office of China <https://en.wikipedia.org/wiki/National_Audit_Office_of_China> and the People's Bank of China <https://en.wikipedia.org/wiki/People%27s_Bank_of_China>. xNY.io - Bank.org, PBC is concerned that the Nanjing Audit University and the People’s Bank of China potentially could be mis-representing intent related to ESG and D&O innovation, at the expense of our global enterprise. 1. According to the Council on Forign Relations, China is the world’s top emitter, producing more than a quarter of the world’s annual greenhouse gas emissions, which contribute to climate change. 2. Nanjing Audit University’s “theoretical analysis and hypothesis developments” suggest that the People’s Republic of China is embryonic in the enforcement of ESG and/or D&O mandates. Meanwhile, suggesting Bloomberg as a reputational capital. 3. xNY.io - Bank.org, PBC has collated 37 highlights to Nanjing Audit University’s ESG and D&O research for NY-DFS consideration. As a Bill and Melinda Gates Scholar and Blockchain Scholar holding international law distinction(s) My international graduate research has touched on Western profit of China’s water resources. xNY.io - Bank.org, PBC seeks to protect pure New York State ESG and D&O innovation. Madam Superindnet, we attentively recognize you are the world’s most powerful regulatory leader in this regard. >From this humble perspective, xNY.io - Bank.org, PBC seeks to earn your respect and consideration to explore the New York False Claims Act as a potential channel. xNY.io - Bank.org, PBC hopes New York State welcomes this assessment at the liberty of your honorable office. Respectfully yours, 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 CC: Mr. Richard Webber

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McAfee Founder?s Neighbor Dead in Belize After Dogs Poisoned
by Gunnar Larson 07 Apr '24

07 Apr '24

Subject: McAfee Founder’s Neighbor Dead in Belize After Dogs Poisoned McAfee Founder’s Neighbor Dead in Belize After Dogs Poisoned McAfee Founder’s Neighbor Dead in Belize After Dogs Poisoned https://www.bloomberg.com/news/articles/2012-11-12/mcafee-founder-is-suspec… John McAfee, the founder of the popular anti-virus software maker, is considered “a person of interest” in the murder of U.S. citizen Gregory Faull and has yet to be located, Belize National Security Ministry spokesman Raphael Martinez said.

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Your own Nelson Mandela of this glorius globalized and cosmopolitan Cryptoanarchist Revolution
by pro2rat＠yahoo.com.au 07 Apr '24

07 Apr '24

Who is the Nelson Mandela of worldwide social revolution for 500, please Alex https://marc.info/?l=cypherpunks&m=100774924423922&w=2 Reposts to properly reflect the post-1995 politics of this list. Viva la revolution!

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492 Highlights to UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants. ____________________
by Gunnar Larson 07 Apr '24

07 Apr '24

On March 24, 2024 ... 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=… 1. In the run-up to the 2016 Presidential Election, Hillary Clinton and her cohorts orchestrated an unthinkable plot – one that shocks the conscience and is an affront to this nation’s democracy. Acting in concert, the Defendants maliciously conspired to weave a false narrative that their Republican opponent, Donald J. Trump, was colluding with a hostile foreign sovereignty. The actions taken in furtherance of their scheme—falsifying evidence, deceiving law enforcement, and exploiting access to highly-sensitive data sources - are so outrageous, subversive and incendiary that even the events of Watergate pale in comparison. 2. Under the guise of ‘opposition research,’ ‘data analytics,’ and other political stratagems, the Defendants nefariously sought to sway the public’s trust. They worked together with a single, self-serving purpose: to vilify Donald J. Trump. Indeed, their far-reaching conspiracy was designed to cripple Trump’s bid for presidency by fabricating a scandal that would be used to trigger an unfounded federal investigation and ignite a media frenzy. 3. The scheme was conceived, coordinated and carried out by top-level officials at the Clinton Campaign and the DNC—including ‘the candidate’ herself—who attempted to shield her involvement behind a wall of third parties.1 To start, the Clinton Campaign and the DNC enlisted the assistance of their shared counsel, Perkins Coie, a law firm with deep Democrat ties, in the hopes of obscuring their actions under the veil of attorney-client privilege. Perkins Coie was tasked with spearheading the scheme to find—or fabricate—proof of a sinister link between Donald J. Trump and Russia. To do so, Perkins Coie launched parallel operations: on one front, Perkins Coie partner Marc Elias led an effort to produce spurious ‘opposition research’ claiming to reveal illicit ties between the Trump Campaign and Russian operatives; on a separate front, Perkins Coie partner Michael Sussmann headed a campaign to develop misleading evidence of a bogus ‘back channel’ connection between e-mail servers at Trump Tower and a Russian-owned bank. 4. Marc Elias, in his mission to obtain derogatory anti-Trump ‘opposition research,’ commissioned Fusion GPS, an investigative firm, and its co-founders, Peter Fritsch and Glenn Simpson, and directed them to dredge up evidence—actual or otherwise—of collusion between Trump and Russia. Fritsch and Simpson, in turn, enlisted the assistance of Orbis Ltd. and its owner, Christopher Steele, to produce a series of reports purporting to contain proof of the supposed collusion. Of course, the now fully debunked collection of reports, known as the “Steele Dossier,” was riddled with misstatements, misrepresentations and, most of all, flat out lies. In truth, the Steele Dossier was largely based upon information provided to Steele by his primary sub-source, Igor Danchenko, who was subsequently indicted for falsifying his claims. Even more damning, Danchenko had close ties to senior Clinton Campaign official, Charles Halliday Dolan, Jr., who knowingly provided false information to Danchenko, who relayed it to Steele, who reported it in the Steele Dossier and eagerly fed the deceptions to both the media and the FBI. This duplicitous arrangement existed for a singular self-serving purpose – to discredit Donald J. Trump and his campaign. 5. At the same time, Michael Sussmann, in his hunt for damaging intel against the Trump Campaign, turned to Neustar, Inc., an information technology company, and one of its top executives, Rodney Joffe, a fervent anti-Trumper who had recently been promised a high-ranking position with the Clinton Administration, to exploit their access to non-public data in search of a secret “back channel” connection between Trump Tower and Alfa Bank. When it was discovered that no such channel existed, the Defendants resorted to truly subversive measures – hacking servers at Trump Tower, Trump’s private apartment, and, most alarmingly, the White House. This ill-gotten data was then manipulated to create a misleading “inference” and submitted to law enforcement in an effort to falsely implicate Donald J. Trump and his campaign.2 All of these acts were carried out in coordination with the Clinton Campaign and the DNC, at the behest of certain Democratic “VIPs.”3 6. While their multi-pronged attack was underway, the Defendants seized on the opportunity to publicly malign Donald J. Trump by instigating a full-blown media frenzy. Indeed, the Clinton Campaign and DNC—admittedly on a “mission” to “raise the alarm” about their contrived Trump-Russia link4—repeatedly fed disinformation to the media and shamelessly promoted their false narratives. All the while, Hillary Clinton, Jake Sullivan, Debbie Wasserman Schultz, and others did their best to proliferate the spread of those dubious and false claims through press releases, social media, and other public statements. 7. The fallout from the Defendants’ actions was not limited to the public denigration of Trump and his campaign. The Federal Bureau of Investigation (FBI)—relying on the Defendants’ fraudulent evidence—commenced a large-scale investigation and expended precious time, resources and taxpayer dollars looking into the spurious allegation that the Trump Campaign had colluded with the Russian Government to interfere in the 2016 presidential election. The effects of this unfounded investigation were prolonged and exacerbated by the presence of a small faction of Clinton loyalists who were well-positioned within the Department of Justice and the FBI – James Comey, Andrew McCabe, Peter Strzok, Lisa Page, Kevin Clinesmith, and Bruce Ohr. These government officials were willing to abuse their positions of public trust to advance the baseless probe to new levels, including obtaining an extrajudicial FISA warrant and instigating the commencement of an oversight investigation headed by Special Counsel Robert Mueller. As a result, Donald J. Trump and his campaign were forced to expend tens of millions of dollars in legal fees to defend against these contrived and unwarranted proceedings. Justice would ultimately prevail – following a two-year investigation, Special Counsel Mueller went on to exonerate Donald J. Trump and his campaign with his finding that there was no evidence of collusion with Russia. 8. The full extent of the Defendants’ wrongdoing has been steadily and gradually exposed by Special Counsel John Durham, who has been heading a DOJ investigation into the origins of the Trump-Russia conspiracy. To date, he has already issued indictments to Sussmann and Danchenko, among others, for proffering false statements to law enforcement officials. As outlined below, these ‘speaking’ indictments not only implicate many of the Defendants named herein but also provide a great deal of insight into the inner-workings of the Defendants’ conspiratorial enterprise. Based on recent developments and the overall direction of Durham’s investigation, it seems all but certain that additional indictments are forthcoming. 9. In short, the Defendants, blinded by political ambition, orchestrated a malicious conspiracy to disseminate patently false and injurious information about Donald J. Trump and his campaign, all in the hopes of destroying his life, his political career and rigging the 2016 Presidential Election in favor of Hillary Clinton. When their gambit failed, and Donald J. Trump was elected, the Defendants’ efforts continued unabated, merely shifting their focus to undermining his presidential administration. Worse still, the Defendants continue to spread their vicious lies to this day as they unabashedly publicize their thoroughly debunked falsehoods in an effort to ensure that he will never be elected again. The deception, malice, and treachery perpetrated by the Defendants has caused significant harm to the American people, and to the Plaintiff, Donald J. Trump, and they must be held accountable for their heinous acts. ____________________ BACKGROUND September 8, 2022 190 Highlights: https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=… Plaintiff initiated this lawsuit on March 24, 2022, alleging that “the Defendants, blinded by political ambition, orchestrated a malicious conspiracy to disseminate patently false and injurious information about Donald J. Trump and his campaign, all in the hopes of destroying his life, his political career and rigging the 2016 Presidential Election in favor of Hillary Clinton.” (DE 177, Am. Compl. ¶ 9). On this general premise, Plaintiff brings a claim for violations of the Racketeer Influenced and Corrupt Organizations Act (“RICO”), predicated on the theft of trade secrets, obstruction of justice, and wire fraud (Count I). He additionally brings claims for: injurious falsehood (Count III); malicious prosecution (Count V); violations of the Computer Fraud and Abuse Act (“CFAA”) (Count VII); theft of trade secrets under the Defend Trade Secrets Act of 2016 (“DTSA”) (Count VIII); and violations of the Stored Communications Act (“SCA”) (Count IX). The Amended Complaint also contains counts for various conspiracy charges and theories of agency and vicarious liability. (Counts II, IV, VI, and X–XVI). Plaintiff’s theory of this case, set forth over 527 paragraphs in the first 118 pages of the Amended Complaint, is difficult to summarize in a concise and cohesive manner. It was certainly not presented that way. Nevertheless, I will attempt to distill it here. The short version: Plaintiff alleges that the Defendants “[a]cting in concert . . . maliciously conspired to weave a false narrative that their Republican opponent, Donald J. Trump, was colluding with a hostile foreign sovereignty.” (Am. Compl. ¶ 1). The Defendants effectuated this alleged conspiracy through two core efforts. “[O]n one front, Perkins Coie partner Mark Elias led an effort to produce spurious ‘opposition research’ claiming to reveal illicit ties between the Trump campaign and Russian operatives.” (Id. ¶ 3). To that end, Defendant Hillary Clinton and her campaign, the Democratic National Committee, and lawyers for the Campaign and the Committee allegedly hired Defendant Fusion GPS to fabricate the Steele Dossier. (Id. ¶ 4). “[O]n a separate front, Perkins Coie partner Michael Sussman headed a campaign to develop misleading evidence of a bogus ‘back channel’ connection between e-mail servers at Trump Tower and a Russian- owned bank.” (Id.). Clinton and her operatives allegedly hired Defendant Rodney Joffe to exploit his access to Domain Name Systems (“DNS”) data, via Defendant Neustar, to investigate and ultimately manufacture a suspicious pattern of activity between Trump-related servers and a Russian bank with ties to Vladimir Putin, Alfa Bank. (Id. ¶ 3). As a result of this “fraudulent evidence,” the Federal Bureau of Investigations (“FBI”) commenced “several large-scale investigations,” which were “prolonged and exacerbated by the presence of a small faction of Clinton loyalists who were well-positioned within the Department of Justice”—Defendants James Comey, Andrew McCabe, Peter Strzok, Lisa Page, Kevin Clinesmith, and Bruce Ohr. (Id. ¶ 7). And while this was ongoing, the Defendants allegedly “seized on the opportunity to publicly malign Donald J. Trump by instigating a full-blown media frenzy.” (Id. ¶ 6). As a result of this “multi-pronged attack,” Plaintiff claims to have amassed $24 million in damages.1(Id. ¶ 527). Defendants now move to dismiss the Amended Complaint as “a series of disconnected political disputes that Plaintiff has alchemized into a sweeping conspiracy among the many individuals Plaintiff believes to have aggrieved him.” (DE 226 at 1). They argue that dismissal is warranted because Plaintiff’s claims are both “hopelessly stale”—that is, foreclosed by the applicable statutes of limitations—and because they fail on the merits “in multiple independent respects.” (Id. at 2). As they view it, “[w]hatever the utilities of [the Amended Complaint] as a fundraising tool, a press release, or a list of political grievances, it has no merit as a lawsuit.” (Id.). I agree. In the discussion that follows, I first address the Amended Complaint’s structural deficiencies. I then turn to subject matter jurisdiction and the personal jurisdiction arguments raised by certain Defendants. Finally, I assess the sufficiency of the allegations as to each of the substantive counts. ____________________ BACKGROUND October 31, 2022 25 Highlights: https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=… PlaintifP’s pleadings and theories were obviously and fatally defective from the very inceptionof this action. Plaintiff's initial Complaint spanned 108 pages and S08 paragraphs. DE 1 (March 24, 2022). It named 28 individual defendants, as well as 10 John Does and 10 ABC Corporations. /d. Less than a month after the Complaint was filed, Hillary Clinton moved to dismiss it with prejudice. DE 52 (Apr. 20,2022). Defendant Clinton’s motion identified manyofthe fundamentalfactual deficiencies and legal flaws that would ultimately lead this Court to dismiss the Amended Complaint: namely, (1) that Plaintifs claims were untimely on their face, DE 52 at 1-5; (2) that Plaintiff's own tweets confirmed his knowledge ofhis supposed claimsno later than October 2017, DE 52 at 2-3; (3) that Plaintiffs Complaint was replete with inadequate and conclusory allegations, DE 52 at 6; (4) that Plaintiff failed to allege a RICO enterprise, DE 52 at 7; (5) that Plaintiff failed to allege the predicate act of theft of trade secrets based on DNS information, DE 52 at 8-9; (6) thatPlaintifffailedtoallege the predicate act ofobstructionofjustice in part because he identified no “official proceeding,” DE 52 at 9-10; (7) that Plaintiff failed to allege a patter of racketeering activity, DE 52 at 11-12; (8) that Plaintiff failed to adequately allege RICO standing because his supposed injuries were almostentirely undescribed, DE 52.at 12-14; (9) that Plaintiffs injurious falsehood claim was barred by the First Amendment, DE 52 at 15-17; (10) that Plaintiff failed to allege almost every necessary clementof injurious falsehood under Florida law, DE 52 at 17-18; (11) that Plaintiff failed to allege a malicious prosecution claim as to any official proceeding and, in particular, as to the properly predicated Crossfire Hurricane investigation, DE 52 at 19-20; and (12) that Plaintiff failed to allege a claim for “agency” because it is not an independent cause of action under Florida law. In response, Plaintiff's counsel indicated that they planned to amend the Complaint. DE 66 (Apr. 21, 2022). Defendant Clinton did not oppose counsel's request for an extension of time in whichto amend. See, e.g., DE 102 (Apr. 27,2022). In the intervening period, other Defendants joined Clinton's motion to dismiss and filed their own motions alertingPlaintiff and his counsel to additional fatal defects in the Complaint. See DE 124 (John Podesta), 139 (Peter Fritsch, Fusion GPS, Glenn Simpson); 141 (DNC Services Corporation, Democratic National Committee, Debbie Wasserman Schultz); 143 (Perkins Coie); 144 (Nellie Ohr); 145 (Robby Mook): 146 (Michael Sussmann); 147 (Mare Elias); 149 (HFACC); 157 (Rodney Joffe); 159 (Igor Danchenko); 160 (Neustar, Inc.); 162 & 163 (Charles Halliday Dolan, Jr.); 165 (Jake Sullivan). With respect to each motion, Plaintiff's counsel indicated that they planned to amend in response to the motions, and Defendants did not oppose extensionsof time to allow them to do so. See DE 153 (May 17,2022). PlaintifP’s counsel filed the Amended Complaint approximately two months after receiving Defendant Clinton’s motion to dismiss and with the benefit of Defendants” additional motions in the interim. DE 177 (June 21, 2022). “But despite this briefing, PlaintifPs Amended Complaint failed to cureanyofthe deficiencies.”DE 267 at 63-64 (Sept. 8, 2022) (“0p.”). “Instead, Plaintiff added eighty new pages of largely irrelevant allegations that did nothing to salvage the legal sufficiency of his claims.” Op. at 64. The Amended Complaint is “193 pages in length, with 819 numbered paragraphs,” and “contains 14 counts, names 31 defendants, 10 “John Does” described as fictitious and unknown persons, and 10 *ABC Corporations’ identified as fictitious and unknown entities.” Op. at 4. ____________________ BACKGROUND November 10, 2022 66 Highlights: https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=… The Complaint. In March 2022, Charles Dolan was among 29 defendants initially sued by Mr. Trump. (DE 1). He was identified as a former chairman of the DNC, a senior official in the Clinton Campaign, and a close associate of and advisor to Hillary Clinton. The Complaint alleged that in April 2016, Mr. Dolan participated in discussions about the creation of a “dossier” to smear Mr. Trump and disseminate false accusations to the media (Compl. ¶ 79), and at the direction of Ms. Clinton assisted in preparation of the dossier (Compl. ¶ 81). According to the Complaint, an allegation contained within the dossier that Mr. Trump engaged in salacious sexual activity in a Moscow hotel was derived from Mr. Dolan. (Compl. ¶ 91). Mr. Dolan was sued for RICO conspiracy (Count II), conspiracy to commit injurious falsehood (Count IV), and conspiracy to commit malicious prosecution (Count VI). The Warning Letter. On May 31, 2022, counsel for Mr. Dolan wrote the attorneys for Mr. Trump. They warned: 1. That Mr. Dolan had no role in any conspiracy related to the Steele dossier. 2. That Mr. Dolan was not a source for the allegations of sexual activity. 3. That Mr. Dolan had not been in contact with any defendant other than Igor Danchenko, and that Mr. Dolan’s contacts with Mr. Danchenko involved business interests and help for a conference in Moscow. 4. That Mr. Dolan had never been chairman of the DNC. 5. That Ms. Clinton was on record through a spokesperson as stating she had no recollection of Mr. Dolan. (DE 268-1). The letter requested that Mr. Dolan not be named as a defendant in any forthcoming Amended Complaint. The letter further warned that if he were to be named, or if he was not dropped from the original Complaint, Rule 11 sanctions would be sought. The Amended Complaint. On June 21, 2022, Plaintiff filed an Amended Complaint, as had been expected. It ballooned to 193 pages, 819 paragraphs and 31 defendants. With respect to Mr. Dolan, the allegations remained essentially the same. But in the Amended Complaint, Mr. Dolan was identified somewhat more vaguely as the former chairman of a “national Democratic political organization.” (Am. Compl. ¶ 96). Elsewhere, he was described as a “senior Clinton Campaign Official.” (Am. Compl. ¶ 4). Moreover, and somewhat inexplicably, Mr. Dolan was identified in the Amended Complaint as a citizen and resident of New York, despite a declaration that Mr. Dolan had provided to Plaintiff’s lawyers explaining that Mr. Dolan was a resident of Virginia. (Am. Compl. ¶ 20; DE 268-2). The Sanctions Motion and Memorandum. On July 15, 2022, Mr. Dolan served on Mr. Trump’s lawyers a motion seeking sanctions pursuant to Rule 11. The motion pointed out that the change in Mr. Dolan’s purported title from “former chairman of the DNC” in the original Complaint to “former chairman of a national Democratic political organization,” in the Amended Complaint did not solve the problems identified in the warning letter because Mr. Dolan had never been the chairman of any such organization. The motion further explained that Mr. Dolan’s role in the Clinton Campaign was limited to knocking on doors as a volunteer. The motion also stated that Mr. Dolan had never been a resident of New York, that Mr. Dolan had told Plaintiff’s lawyers so, and that the allegations of the Amended Complaint to that effect demonstrated a lack of diligence over something easily checked. Mr. Dolan’s motion for sanctions went on to place the Trump lawyers on notice of a critical failure in their claims, warning them that the Danchenko Indictment referenced throughout the Amended Complaint not only failed to support their allegations against Mr. Dolan but contradicted them. That warning continues to be unheeded. ____________________ BACKGROUND January 19, 2023 53 Highlights: https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=… Plaintiff initiated this lawsuit on March 24, 2022, alleging that “the Defendants, blinded by political ambition, orchestrated a malicious conspiracy to disseminate patently false and injurious information about Donald J. Trump and his campaign, all in the hope of destroying his life, his political career, and rigging the 2016 Presidential Election in favor of Hillary Clinton.” (DE 1 ¶ 9). The next day, Alina Habba, Mr. Trump’s lead counsel told Fox News’ Sean Hannity: You can’t make this up. You literally cannot make a story like this up . . . and President Trump is just not going to take it anymore. If you are going to make up lies, if you are going to try to take him down, he is going to fight you back. And that is what this is, this is the beginning of all that.1 She then explained on Newsmax: What the real goal [of the suit] is, is democracy, is continuing to make sure that our elections, continuing to make sure our justice system is not obstructed by political enemies. That cannot happen. And that’s exactly what happened. They obstructed justice. They continued the false narrative . . . This grand scheme, that you could not make up, to take down an opponent. That is un-American.2 On April 20, 2022, less than a month after the Complaint was filed, Hillary Clinton moved for dismissal with prejudice. Her motion identified substantial and fundamental factual and legal flaws. Each of the other Defendants followed suit, pointing to specific problems with the claims against them. The problems in the Complaint were obvious from the start. They were identified by the Defendants not once but twice, and Mr. Trump persisted anyway. Despite this briefing and the promise “to cure any deficiencies,” Plaintiff’s counsel filed the Amended Complaint on June 21, 2022. (DE 177). The Amended Complaint failed to cure any of the defects. See DE 267, Order of Dismissal (September 8, 2022). Instead, Plaintiff added eighty new pages of largely irrelevant allegations that did nothing to salvage the legal sufficiency of his claims. (DE 267 at 64). The Amended Complaint is 193 pages in length, with 819 numbered paragraphs, and contains 14 counts, names 31 defendants, 10 John Does described as fictitious and unknown persons, and 10 ABC Corporations identified as fictitious and unknown entities. On July 14, 2022, the United States moved pursuant to the Westfall Act, 28 U.S.C. § 2679 (d)(i), to substitute itself as Defendant for James Comey, Andrew McCabe, Peter Strzok, Lisa Page, and Kevin Clinesmith. (DE 224). On July 21, 2022, I granted the motion to substitute. (DE 234). On September 8, 2022, I dismissed the case with prejudice as to all Defendants except for the United States. 3 I issued a detailed and lengthy Order, which I incorporate by reference here. (DE 267). I found that fatal substantive defects which had been clearly laid out in the first round of briefing, precluded the Plaintiff from proceeding under any of the theories presented. I found that the Amended Complaint was a quintessential shotgun pleading, that its claims were foreclosed by existing precedent, and its factual allegations were undermined and contradicted by the public reports and filings upon which it purported to rely. I reserved jurisdiction to adjudicate issues pertaining to sanctions. Undeterred by my Order and two rounds of briefing by multiple defendants, Ms. Habba continued to advance Plaintiff’s claims. In a September 10, 2022, interview with Sean Hannity, the host asked her “Why isn’t [Hillary Clinton] being held accountable for what she did?” Ms. Habba’s response reiterated misrepresentations on which this lawsuit was based: Because when you have a Clinton judge as we did here, Judge Middlebrooks who I had asked to recuse himself but insisted that he didn’t need to, he was going to be impartial, and then proceeds to write a 65-page scathing order where he basically ignored every factual basis which was backed up by indictments, by investigations, the Mueller report, et cetera, et cetera, et cetera, not to mention Durham, and all the testimony we heard there, we get dismissed. Not only do we get dismissed, he says that this is not the proper place for recourse for Donald Trump. He has no legal ramifications. Where what [sic] is the proper place for him? Because the FBI won’t help when you can do anything, obstruct justice, blatantly lie to the FBI, Sussmann’s out, he gets acquitted, where do you go? That’s the concern for me, where do you get that -- that recourse?4 She also indicated that, while Mr. Trump doubted the suit would succeed, she nevertheless “fought” to pursue it: You know, I have to share with you a story, Sean, that I have not shared with anybody. The recourse that I have at this point is obviously to appeal this to the 11th Circuit as Gregg said. But when I brought this case and we were assigned you know, this judge and we went through the recusal process, we lost five magistrates, including Reinhart [sic] who’s dealing with the boxes as we know. The former president looked at me and he told me, you know what Alina. You’re not going to win. You can’t win, just get rid of it, don’t do the case. And I said, no, we have to fight. It’s not right what happened. And you know, he was right, and it’s a sad day for me personally because I fought him on [it] and I should have listened, but I don’t want to lose hope in our system. I don’t. So, you know I’m deciding whether we’re going to appeal it.5 Defendants now move to recover attorneys’ fees and costs under Fed. R. Civ. P. 11, 28 U.S.C. § 1927, the Defend Trade Secrets Act, and/or this Court’s inherent power. (DE 280 at 1). In Part II, I find that a sanction under this Court’s inherent power is appropriate. I do so by examining Plaintiff’s (and his lawyers’) conduct throughout this litigation. In Part III, I look to Plaintiff’s conduct in other cases. And in Part IV, I determine the reasonableness of Defendants’ attorneys’ fees and costs.

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