BACKGROUND 

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.