Dear Goldman Sachs: xNY.io - Bank.org has made 37 highlights to Nanjing Audit University's "*Can D&O insurance improve corporate ESG performance*?" for Meta Platforms' Board. *Can D&O insurance improve corporate ESG performance?:* - https://drive.google.com/file/d/1kYBR93f7fzdculQZk9MGUkPlX23WTKQm/view?usp=d... xNY.io - Bank.org respectfully reserves all Interjurisdictional rights. Thank you, Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053 On Fri, Mar 21, 2025, 1:19 AM Gunnar Larson <g@xny.io> wrote:

Dear Goldman Sachs:

Will Goldman Sachs' Board Directors submit the Board to an audit of the Deferred Agreement’s mandates?

xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution Agreement holds certain risk requirements.

*Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:*

- https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d...

*"Periodic Risk-Based Review *

* 5. The Company will develop these compliance policies and procedures on the basis of a periodic risk assessment addressing the individual circumstances of the Company, in particular the foreign bribery risks facing the Company, including, but not limited to, its geographical organization, interactions with various types and levels of government officials, industrial sectors of operation, potential clients and business partners, use of third parties, gifts, travel and entertainment expenses, charitable and political donations, involvement in joint venture arrangements, importance of licenses and permits in the Company’s operations, degree of governmental oversight and inspection, and volume and importance of goods and personnel clearing through customs and immigration. *

* 6. The Company shall review its anti-corruption compliance policies and procedures no less than annually and update them as appropriate to ensure their continued effectiveness, taking into account relevant developments in the field and evolving international and industry standards."*

Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk.

*Forum Statement on OCC’s Removal of Reputation Risk*

*Washington, D.C. – *Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk:

“We appreciate the OCC’s action to ensure bank supervision is focused on financial and other material risks. Today’s decision is an important step to create a more transparent and effective regulatory environment. We look forward to continuing to work with the Administration and Congress to identify solutions that allow America’s leading banks to continue to best serve their customers.”

###

*The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.*

*Visit our website: **fsforum.com* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-r/>

*Follow us on X **@fsforum* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-y/> * and **LinkedIn* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-j/>

[image: Twitter] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-t/>[image: LinkedIn] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-i/>[image: Website] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-d/>[image: Instagram] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-h/>[image: Threads] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-k/>[image: YouTube] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-u/>

<https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-o/>

The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Thu, Mar 20, 2025, 8:31 AM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

xNY.io - Bank.org is concerned Goldman Sachs is potentially 'obstructing justice' against xNY.io - Bank.org's global enterprise.

Swiss Bank Accused Of Ignoring $1B Kuwaiti Bribery Scheme <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_main=1&nlsidx=0&nlaidx=1>

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=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_more=1&nlsidx=0&nlaidx=1> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_later=1&nlsidx=0&nlaidx=1>

Goldstein Says Feds 'Misled' Court With Obstruction Claim <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_main=1&nlsidx=1&nlaidx=6>

By Phillip Bantz

U.S. Supreme Court lawyer and SCOTUSblog publisher Tom Goldstein wants a Maryland federal judge to sanction prosecutors in his tax evasion case for a "pattern of false and misleading statements" to the court accusing him of hiding millions in cryptocurrency and bribing his former law firm manager.

2 documents attached | Read full article » <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_more=1&nlsidx=1&nlaidx=6> | Save to favorites » <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_later=1&nlsidx=1&nlaidx=6> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Wed, Mar 19, 2025, 3:11 PM Gunnar Larson <g@xny.io> wrote:

...

*Trump Administration Gives All Clear to Laundering Money through Shell Companies and Bribing Foreign Officials*

By Pam Martens and <https://wallstreetonparade.com/about-3/about/>Russ Martens <https://wallstreetonparade.com/about-3/about/>: March 19, 2025 ~

[image: Trump, Pied Piper] <https://wallstreetonparade.com/wp-content/uploads/2020/08/Trump-Pied-Piper.jpg>On February 10, President Donald Trump issued an Executive Order <https://www.whitehouse.gov/presidential-actions/2025/02/pausing-foreign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security> that suspended the Foreign Corrupt Practices Act (FCPA) for 180 days, giving an all clear to U.S. corporations to bribe officials in foreign countries to get business deals approved. The order bars federal prosecutors from starting any new FCPA investigations, enforcing new actions and orders a review of existing FCPA investigations to “restore proper bounds” on applying the FCPA law.

The FCPA, enacted in 1977, has been the law of the United States for almost half a century. In July 2020, the Justice Department and Securities and Exchange Commission issued a comprehensive and updated guide to the FCPA. It explained its purpose as follows <https://www.justice.gov/criminal/criminal-fraud/file/1292051/dl?inline> :

“Foreign bribery is a scourge that must be eradicated. It undermines the rule of law, empowers authoritarian rulers, distorts free and fair markets, disadvantages honest and ethical companies, and threatens national security and sustainable development. This updated Guide is meant not only to summarize the product of the dedicated and hardworking individuals who combat foreign bribery as part of their work for the U.S. government, but also to help companies, practitioners, and the public — many of whom find themselves on the front lines of this fight —prevent corruption in the first instance. We hope that the Guide will continue to be an invaluable resource in those efforts.”

In early March the Trump administration gutted another anti-corruption law, the Corporate Transparency Act.

The Corporate Transparency Act became law in 2021. Its goal is to curb anonymous shell companies from money laundering in the U.S. behind a dark curtain. It requires that the true owners of these shell companies must file that beneficial ownership information into a federal registry established by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and it imposes stiff fines and up to two years in prison for failure to do so.

Quietly, with little fanfare on March 2, Trump’s newly installed Treasury Secretary (hedge fund honcho Scott Bessent <https://wallstreetonparade.com/2024/11/donald-trumps-treasury-nominee-made-big-bets-this-year-on-chinese-stocks-and-a-big-short-on-the-u-s-market/>) announced that he would not enforce the Corporate Transparency Act as the law was written. The statement from the Treasury Department said this <https://home.treasury.gov/news/press-releases/sb0038>:

“The Treasury Department is announcing today that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either. The Treasury Department will further be issuing a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only. Treasury takes this step in the interest of supporting hard-working American taxpayers and small businesses and ensuring that the rule is appropriately tailored to advance the public interest.”

We have read regulatory announcements by the U.S. Treasury Department for decades. We have never read anything from prior administrations that is so unprofessionally constructed or that so brazenly thumbs its nose at duly passed laws by the U.S. Congress.

These two bizarre rollbacks of anti-corruption legislation raise the obvious question: Who benefits?

Donald Trump himself comes to mind.

In March 2017, USA Today published an explosive expose <https://www.usatoday.com/story/news/world/2017/03/28/trump-business-past-ties-russian-mobsters-organized-crime/98321252/> that revealed the following:

“Trump’s privately held company works through a network of subsidiaries and partnerships that make direct connections hard to trace, particularly since he has refused to release his tax filings. In addition, some of the Trump Organization’s investors and buyers operate through shell companies and limited liability corporations that hide the identities of individual owners.”

The article drilled down further to these specifics:

“• A member of the firm that developed the Trump SoHo Hotel in New York is a twice-convicted felon who spent a year in prison for stabbing a man and later scouted for Trump investments in Russia.

“• An investor in the SoHo project was accused by Belgian authorities in 2011 in a $55 million money-laundering scheme.

“• Three owners of Trump condos in Florida and Manhattan were accused in federal indictments of belonging to a Russian-American organized crime group and working for a major international crime boss based in Russia.

“• A former mayor from Kazakhstan was accused in a federal lawsuit filed in Los Angeles in 2014 of hiding millions of dollars looted from his city, some of which was spent on three Trump SoHo units.

“• A Ukrainian owner of two Trump condos in Florida was indicted in a money-laundering scheme involving a former prime minister of Ukraine.

“…What’s more, Trump and his companies have had business dealings with Russians that go back decades, raising questions about whether his policies would be influenced by business considerations.”

In 2008 Trump’s son, Donald Jr., told Russian media while he was in Moscow that “Russians make up a pretty disproportionate cross-section of a lot of our assets; say in Dubai, and certainly with our project in SoHo and anywhere in New York. We see a lot of money pouring in from Russia. There’s indeed a lot of money coming for new-builds and resale reflecting a trend in the Russian economy and, of course, the weak dollar versus the ruble” according to USA Today reporting in December 2016 <https://www.usatoday.com/story/news/world/2016/12/15/donald-trump-russia-wealthy-condo-buyers/95464922/> . On Wed, Mar 19, 2025, 11:22 AM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

xNY.io - Bank.org is prepared to take any potential arguments to every Supreme Court on Planet Earth for consideration.

NBA Asks High Court To Weigh In On VPPA Data Sharing Suit <https://www.law360.com/cybersecurity-privacy/articles/2312508?nl_pk=fb101149-eb3b-4ea0-9196-fcd8c48ca69a&utm_source=newsletter&utm_medium=email&utm_campaign=cybersecurity-privacy&utm_content=2025-03-19&read_main=1&nlsidx=0&nlaidx=1>

By Gina Kim

The NBA has urged the U.S. Supreme Court to weigh in on a Second Circuit decision that revived a Video Privacy Protection Act suit alleging that the league shared video viewing activities of its website's visitors with Meta, arguing that the plaintiff lacked standing since the information wasn't publicly disseminated or highly personal.

Petition attached | Read full article » <https://www.law360.com/cybersecurity-privacy/articles/2312508?nl_pk=fb101149-eb3b-4ea0-9196-fcd8c48ca69a&utm_source=newsletter&utm_medium=email&utm_campaign=cybersecurity-privacy&utm_content=2025-03-19&read_more=1&nlsidx=0&nlaidx=1> | Save to favorites » <https://www.law360.com/cybersecurity-privacy/articles/2312508?nl_pk=fb101149-eb3b-4ea0-9196-fcd8c48ca69a&utm_source=newsletter&utm_medium=email&utm_campaign=cybersecurity-privacy&utm_content=2025-03-19&read_later=1&nlsidx=0&nlaidx=1> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Wed, Mar 19, 2025, 10:23 AM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

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.

Tennis Governing Bodies Are A 'Cartel,' Players Claim In Suit <https://www.law360.com/competition/articles/2312142?nl_pk=6e763a2a-9f82-44c1-ad37-dbb872fe3785&utm_source=newsletter&utm_medium=email&utm_campaign=competition&utm_content=2025-03-19&read_main=1&nlsidx=0&nlaidx=15>

By David Steele

Twelve current and former tennis professionals filed a proposed antitrust class action in New York federal court on Tuesday, accusing the sport's governing bodies of operating as a "cartel" that manipulates pay and rankings, forces unsafe playing conditions, and exposes players to unfair investigations and discipline.

Complaint attached | Read full article » <https://www.law360.com/competition/articles/2312142?nl_pk=6e763a2a-9f82-44c1-ad37-dbb872fe3785&utm_source=newsletter&utm_medium=email&utm_campaign=competition&utm_content=2025-03-19&read_more=1&nlsidx=0&nlaidx=15> | Save to favorites » <https://www.law360.com/competition/articles/2312142?nl_pk=6e763a2a-9f82-44c1-ad37-dbb872fe3785&utm_source=newsletter&utm_medium=email&utm_campaign=competition&utm_content=2025-03-19&read_later=1&nlsidx=0&nlaidx=15>

States Oppose Term In Sandoz Price-Fixing Deal With Fla. <https://www.law360.com/competition/articles/2311936?nl_pk=6e763a2a-9f82-44c1-ad37-dbb872fe3785&utm_source=newsletter&utm_medium=email&utm_campaign=competition&utm_content=2025-03-19&read_main=1&nlsidx=0&nlaidx=8>

By Jared Foretek

State enforcers still locked in price-fixing litigation against generic-drug maker Sandoz are raising objections to a cap on what they could win through settlements in Florida's recent agreement with the company, telling the Connecticut federal judge weighing approval that it would block or delay potential settlements of their own.

Notice attached | Read full article » <https://www.law360.com/competition/articles/2311936?nl_pk=6e763a2a-9f82-44c1-ad37-dbb872fe3785&utm_source=newsletter&utm_medium=email&utm_campaign=competition&utm_content=2025-03-19&read_more=1&nlsidx=0&nlaidx=8> | Save to favorites » <https://www.law360.com/competition/articles/2311936?nl_pk=6e763a2a-9f82-44c1-ad37-dbb872fe3785&utm_source=newsletter&utm_medium=email&utm_campaign=competition&utm_content=2025-03-19&read_later=1&nlsidx=0&nlaidx=8>

BlackRock Calls Red States' Suit Over Coal Prices 'Farfetched' <https://www.law360.com/competition/articles/2312190?nl_pk=6e763a2a-9f82-44c1-ad37-dbb872fe3785&utm_source=newsletter&utm_medium=email&utm_campaign=competition&utm_content=2025-03-19&read_main=1&nlsidx=0&nlaidx=12>

By Katryna Perera

BlackRock Inc. and two other large asset managers have urged a Texas federal judge to toss claims brought by a coalition of Republican-led states alleging the firms ran a scheme to drive up coal prices as part of an "investment cartel," saying the case "spins a farfetched theory."

Memorandum attached | Read full article » <https://www.law360.com/competition/articles/2312190?nl_pk=6e763a2a-9f82-44c1-ad37-dbb872fe3785&utm_source=newsletter&utm_medium=email&utm_campaign=competition&utm_content=2025-03-19&read_more=1&nlsidx=0&nlaidx=12> | Save to favorites » <https://www.law360.com/competition/articles/2312190?nl_pk=6e763a2a-9f82-44c1-ad37-dbb872fe3785&utm_source=newsletter&utm_medium=email&utm_campaign=competition&utm_content=2025-03-19&read_later=1&nlsidx=0&nlaidx=12> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Wed, Mar 19, 2025, 8:04 AM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

Trading Giant Virtu Must Face Suit Over Confidentiality Issues <https://www.law360.com/capitalmarkets/articles/2312402?nl_pk=35f19b02-1b5d-4d87-9886-0568d6f0b360&utm_source=newsletter&utm_medium=email&utm_campaign=capitalmarkets&utm_content=2025-03-19&read_main=1&nlsidx=0&nlaidx=1>

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-4d87-9886-0568d6f0b360&utm_source=newsletter&utm_medium=email&utm_campaign=capitalmarkets&utm_content=2025-03-19&read_more=1&nlsidx=0&nlaidx=1> | Save to favorites » <https://www.law360.com/capitalmarkets/articles/2312402?nl_pk=35f19b02-1b5d-4d87-9886-0568d6f0b360&utm_source=newsletter&utm_medium=email&utm_campaign=capitalmarkets&utm_content=2025-03-19&read_later=1&nlsidx=0&nlaidx=1> 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@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=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-18&read_main=1&nlsidx=1&nlaidx=7> > > 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=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-18&read_more=1&nlsidx=1&nlaidx=7> > | Save to favorites » > <https://www.law360.com/mergersacquisitions/articles/2311598?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-18&read_later=1&nlsidx=1&nlaidx=7> > > Activist Investor Calls For Reconstitution Of Parkland's Board > <https://www.law360.com/mergersacquisitions/articles/2311698?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-18&read_main=1&nlsidx=0&nlaidx=6> > > 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=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-18&read_more=1&nlsidx=0&nlaidx=6> > | Save to favorites » > <https://www.law360.com/mergersacquisitions/articles/2311698?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-18&read_later=1&nlsidx=0&nlaidx=6> > > 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=d... > > *"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@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=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-18&read_main=1&nlsidx=0&nlaidx=0> >> >> 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=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-18&read_more=1&nlsidx=0&nlaidx=0> >> | Save to favorites » >> <https://www.law360.co.uk/financial-services-uk/articles/2311596?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-18&read_later=1&nlsidx=0&nlaidx=0> >> >> - 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=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-18&read_main=1&nlsidx=0&nlaidx=1> >> >> 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=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-18&read_more=1&nlsidx=0&nlaidx=1> >> | Save to favorites » >> <https://www.law360.co.uk/financial-services-uk/articles/2311414?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-18&read_later=1&nlsidx=0&nlaidx=1> >> 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@fsforum.com> >> Date: Mon, Mar 17, 2025, 5:22 PM >> Subject: Forum Welcomes Nomination for Fed Vice Chair for >> Supervision >> To: Gunnar Larson <G@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/> >> >

Goldman Sachs: Mastercard Seeks To Limit Swipe Fee Damages Bill <https://www.law360.co.uk/financial-services-uk/articles/2314558?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=2> By Lucia Osborne-Crowley Mastercard urged a tribunal on Monday to limit the damages it must pay to intermediaries such as Worldpay over unlawful interchange fees, arguing that the acquirers' proposed damages bill is too broad and covers too long a period of time. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2314558?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=2> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2314558?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=2> Feds, Javice Rest In Trial Over JPMorgan's $175M Frank Buy <https://www.law360.com/newyork/articles/2315077?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=4> By Stewart Bishop Manhattan federal prosecutors and Charlie Javice on Monday both wrapped up their cases in the trial of the former Frank CEO and another executive, who are accused of tricking JPMorgan into buying the education startup for $175 million based on false information. Read full article » <https://www.law360.com/newyork/articles/2315077?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=4> | Save to favorites » <https://www.law360.com/newyork/articles/2315077?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=4> Hayes Appeal Set To Test Theory Of Rate-Rigging Convictions <https://www.law360.co.uk/financial-services-uk/articles/2313950?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=0> By Christopher Crosby Two former City traders will appeal against their convictions for rigging interest rates before Britain's top court on Tuesday in a case that could have implications for the premise that underpins the rate-rigging prosecutions of dozens of others in the wake of the 2008 financial crisis. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2313950?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=0> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2313950?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=0> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights. Thank you, Gunnar Larson -- Gunnar Donald Arthur Peter Larson *xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001 On Fri, Mar 21, 2025, 6:40 PM Gunnar Larson <g@xny.io> wrote:

Dear Goldman Sachs:

Today, xNY.io - Bank.org doubles down on our commitment to Peace on Planet Earth.

xNY.io - Bank.org shares 492 highlights to: *"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."*

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson

*xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001

*----- (PAGE BREAK) -----*

*492 highlights to:** "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."*

*INTRODUCTION*

*March 24, 2022*

* - 158 Highlights: https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=d... <https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=drivesdk>*

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=d... <https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=drivesdk>*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@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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=3>

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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=3> | Save to favorites » <https://www.law360.com/newyork/articles/2311047?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=3>

Three Arrows Beats FTX To Get $1.5B Bankruptcy Claim <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=7>

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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=7> | Save to favorites » <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=7> 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@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@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-GPlVoiLAeeBXUrxwOFT...

May 1, 2022

BY ELECTRONIC MAIL

Investor Relations Board of Directors, JPMorgan Chase & Co. 277 Park Avenue New York, NY 10172-0003 JPMCinvestorrelations@jpmchase.com

Re: JPMorgan Chase Board of Directors ESG Marketplace Manipulation

Dear Board of Directors:

xNY.io - Bank.org recently contacted JPMorgan Chase’s board of directors to communicate our concern(s) that potentially JPMorgan Chase may be engaging in exploitation of more than $100B of ESG asset liabilities, across international regulatory arbitrage structures, while headquartered in Manhattan. Specifically, the duty to promote the success of the company is that a director must act in the way that she considers, in good faith, and would be most likely to promote the success of the company for the benefit of its members as a whole.

-

Failure by a board to adequately consider ESG-related risks, particularly entity-specific compliance risks such as breach of securities laws, could serve as the basis for liability of individual directors or officers for breach of their fiduciary duties.

Given JPMorgan’s five cout felonies, xNY.io - Bank.org is concerned with your board of director governance in preventing ESG fraud. xNY.io - Bank.org’s assessment of JPMorgan’s board embraces fundamentals including liquidity risk and protecting New York ESG cross border innovation from marketplace manipulation.

-

According to JPMorgan’s August 2021 Sovereigns and ESG whitepaper, the bank states that governance carries the largest weight of the three ESG pillars across scores, as it is the most empirically relevant for asset prices. -

JPMorgan notes that philosophically, the bank views good governance as a foundational pillar for positive ESG developments in other pillars.

Today’s memo follows protocol suggested by the United States of America, in that JPMorgan Chase’s board of directors is responsible to xNY.io - Bank.org’s enterprise and the Department of the Interior, in connection with any action alleging a violation of the Endangered Species Act, by any person (“person” means an individual, corporation, partnership, trust, association, or any other private entity) claiming the benefit of any exemption or permit under the Act, who shall have the burden of proving that the exemption or permit is applicable, or has been granted, and was valid and in force at the time of alleged violation.

xNY.io - Bank.org has made 91 highlights to the Department of Interior’s Endangered Species Act for JPMorgan Chase’s board of directors reference.

1.

xNY.io - Bank.org has reason to believe in the JPMorgan Chase board of directors’ engagement of ESG marketplace manipulation, risking your ESG portfolio’s future at the cost of New York digital asset innovation. 2.

xNY.io - Bank.org references your 2021 Environmental Social and Governance Report, totaling $117B of ESG “development funding” transferred from New York to Caribbean and Eastern European accounts. 3.

xNY.io - Bank.org is concerned of JPMorgan Chase board directors leveraged marketplace manipulation techniques in allocating ESG funds to engage in potential harassment (the term "harassment" means any act of pursuit, torment, or annoyance) of some of the world’s most precious endangered species protected by domestic and international governance. 4.

JPMorgan Chase’s $2.3B ESG “wind farm” facility is characterized by the Washington Post as a potential misuse of ESG assets (and board policies) to fund probable violation(s) of the Marine Mammal Protection Act of 1972.

Looking internationally, xNY.io - Bank.org is concerned of further ESG marketplace manipulation structures, sacrificing endangered species, via JPMorgan Chase’s board directed ESG investments in the Caribbean (your largest ESG investment region). xNY.io - Bank.org signals that JPMorgan’s board of directors is party to the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere.

Being clear, any violation of the Endangered Species Act, the Marine Mammal Protection Act and/or the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere … Requires xNY.io - Bank.org to consult JPMorgan Chase board members on ESG allocations that may be in conflict with construction, or other development projects, or other forms of economic activity.

xNY.io - Bank.org asks JPMorgan Chase board directors to return the Secretary of Department of the Interior’s approval, confirming licensing and/or exclusion to the Endangered Species Act, with further authorization of “harassment” pursuant to exemption(s). Including (if available) a similar Environmental Protection Agency permit that is applicable and is valid and in force.

-

Due to the riskiness of ESG portfolio mismanagement in violation of the Endangered Species Act, ESG marketplace manipulation risk(s) may trigger causal shocks to New York State monetary and regulatory innovation. -

According to JPMorgan’s sovereign fund ESG research, “A common complaint about ESG analysis is that data can be difficult to source. Some sovereign data is in fact more readily available than corporate data given the multitude of multinational organizations and NGOs – including the World Bank, the IMF and the United Nations.” -

The European Central Bank provides support to the eurozone sovereign debt market but has more restrictions on what and how much it can buy, so eurozone bonds can trade with more credit risk premium compared to other major developed market bonds. -

Whatever the case may be, JPMorgan disclosures detail significant concern of lapse in board governance and ESG portfolio risk with potential violation of the Endangered Species Act, risking ESG portfolio default(s) in Europe and the United States risking ESG customer financial abuse.

Forbes recently profiles JPMorgan Chase ESG investments as problematic, highlighting that your board of directors potentially are allocating ESG proceeds in competition with human rights at the expense of customers’ best interests while investing heavily in fossil fuels. A letter to JPMorgan Chase’s board of directors from ESG scholars (including, The Sierra Club, Public Citizen, Greenpeace, Amazon Watch, Revolving Door Project, Rainforest Action Network and the Center for International Environmental Law) suggests the bank would “...lock us into energy sources that are overly expensive and subject to wild price swings, and that exacerbate rather than ease global conflict.”

xNY.io - Bank.org aims to protect ESG digital asset innovation and JPMorgan’s board should understand your proprietary ESG scoring matrix should signal seismic marketplace manipulation risk if directors are in potential violation of any Endangered Species Act covenant.

-

Head of Europe, Middle East, and Africa (EMEA) distribution at JP Morgan Asset Management says, “In Europe, we do not have a semi-transparent product – like the US and Australia – which would add further complexity to the trading. For example, the US has several models which make it harder for the AP to guess what the actual fund looks like and therefore the costs might be higher accordingly.” -

Given, JPMorgan may potentially be in breach of United States Endangered Species Act provisions, similar risk of ESG asset failure(s) may include Europe, Middle East, Africa and Australia international law, as ratified by the Convention on International Trade in Endangered Species of Wild Fauna and Flora.

While directors and officers are likely to be particularly focused on the risk that they may be found personally liable for a breach of their duties, proper ESG compliance with fiduciary obligations requires acting to a higher standard. Given the defenses available to fiduciaries, and the difficulty in bringing claims for breach of fiduciary duty, a director or officer found to be liable for such ESG breaches will generally have acted egregiously. This ‘sliding scale’ of the standards to which directors and officers should adhere.

Following the Endangered Species Act, xNY.io - Bank.org kindly petitions JPMorgan’s board of directors, in connection with all ESG investments, claiming the benefit of any exemption or permit under the United States Department of the Interior’s Endangered Species Act … Shall have the burden of proving that an exemption or permit is applicable, or has been granted, and is valid and in force.

-

At JPMorgan’s earliest convenience (within 60 days of receipt of this memo) xNY.io - Bank.org kindly requests a certified copy of JPMorgan Chase’s approval by the Department of the Interior, being a license and/or exclusion to the Endangered Species Act and/or the Marine Mammal Protection Act. -

JPMorgan Chase suggests a commitment to anti-corruption compliance is central to the success of its business. Your board of directors stand to maintain that trust by promoting a corporate culture that encourages ethical business practices and compliance with both the letter and the spirit of the laws of the countries in which the JPMorgan conducts business.

xNY.io - Bank.org’s research guidance from the United States Securities and Exchange Commision, supports the international community in taking actions to address ESG issues on a global basis, and those actions that can have a material impact on companies.

Future correspondence concerning ESG innovation is at your board’s leisure.

Respectfully yours with appreciation,

Gunnar Larson | xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>, PBC MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/> - Entrepreneurship and Innovation (ip) G@xNY.io +1-646-454-9107

On Fri, Mar 14, 2025, 6:34 PM Gunnar Larson <g@xny.io> wrote:

Goldman Sachs:

Is Goldman Sachs a potential negligent terrorist organization?

- *xNY.io - Bank.org demands a response from Goldman Sachs confirming your firm is innocent of possible terrorism actions across your Investment Bank. * - *xNY.io - Bank.org demands Goldman Sachs' answer by 12:00pm EST**, Monday, March 17, 2025.*

On Fri, Mar 21, 2025, 3:25 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

xNY.io - Bank.org has made 37 highlights to Nanjing Audit University's "*Can D&O insurance improve corporate ESG performance*?" for Meta Platforms' Board.

*Can D&O insurance improve corporate ESG performance?:*

- https://drive.google.com/file/d/1kYBR93f7fzdculQZk9MGUkPlX23WTKQm/view?usp=d...

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Fri, Mar 21, 2025, 1:19 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

Will Goldman Sachs' Board Directors submit the Board to an audit of the Deferred Agreement’s mandates?

xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution Agreement holds certain risk requirements.

*Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:*

- https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d...

*"Periodic Risk-Based Review *

* 5. The Company will develop these compliance policies and procedures on the basis of a periodic risk assessment addressing the individual circumstances of the Company, in particular the foreign bribery risks facing the Company, including, but not limited to, its geographical organization, interactions with various types and levels of government officials, industrial sectors of operation, potential clients and business partners, use of third parties, gifts, travel and entertainment expenses, charitable and political donations, involvement in joint venture arrangements, importance of licenses and permits in the Company’s operations, degree of governmental oversight and inspection, and volume and importance of goods and personnel clearing through customs and immigration. *

* 6. The Company shall review its anti-corruption compliance policies and procedures no less than annually and update them as appropriate to ensure their continued effectiveness, taking into account relevant developments in the field and evolving international and industry standards."*

Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk.

*Forum Statement on OCC’s Removal of Reputation Risk*

*Washington, D.C. – *Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk:

“We appreciate the OCC’s action to ensure bank supervision is focused on financial and other material risks. Today’s decision is an important step to create a more transparent and effective regulatory environment. We look forward to continuing to work with the Administration and Congress to identify solutions that allow America’s leading banks to continue to best serve their customers.”

###

*The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.*

*Visit our website: **fsforum.com* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-r/>

*Follow us on X **@fsforum* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-y/> * and **LinkedIn* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-j/>

[image: Twitter] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-t/>[image: LinkedIn] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-i/>[image: Website] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-d/>[image: Instagram] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-h/>[image: Threads] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-k/>[image: YouTube] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-u/>

<https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-o/>

The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Thu, Mar 20, 2025, 8:31 AM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

xNY.io - Bank.org is concerned Goldman Sachs is potentially 'obstructing justice' against xNY.io - Bank.org's global enterprise.

Swiss Bank Accused Of Ignoring $1B Kuwaiti Bribery Scheme <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_main=1&nlsidx=0&nlaidx=1>

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=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_more=1&nlsidx=0&nlaidx=1> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_later=1&nlsidx=0&nlaidx=1>

Goldstein Says Feds 'Misled' Court With Obstruction Claim <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_main=1&nlsidx=1&nlaidx=6>

By Phillip Bantz

U.S. Supreme Court lawyer and SCOTUSblog publisher Tom Goldstein wants a Maryland federal judge to sanction prosecutors in his tax evasion case for a "pattern of false and misleading statements" to the court accusing him of hiding millions in cryptocurrency and bribing his former law firm manager.

2 documents attached | <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_more=1&nlsidx=1&nlaidx=6>

Goldman Sachs: Will Goldman Sachs' Board Directors submit the Board to an audit of the Deferred Agreement’s mandates? - xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution Agreement holds certain risk requirements. *Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:* - https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d... *"Periodic Risk-Based Review * * 5. The Company will develop these compliance policies and procedures on the basis of a periodic risk assessment addressing the individual circumstances of the Company, in particular the foreign bribery risks facing the Company, including, but not limited to, its geographical organization, interactions with various types and levels of government officials, industrial sectors of operation, potential clients and business partners, use of third parties, gifts, travel and entertainment expenses, charitable and political donations, involvement in joint venture arrangements, importance of licenses and permits in the Company’s operations, degree of governmental oversight and inspection, and volume and importance of goods and personnel clearing through customs and immigration. * * 6. The Company shall review its anti-corruption compliance policies and procedures no less than annually and update them as appropriate to ensure their continued effectiveness, taking into account relevant developments in the field and evolving international and industry standards."* StanChart Loses Bid To Ax £762M From Iran Sanctions Claim <https://www.law360.co.uk/financial-services-uk/articles/2315191?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_main=1&nlsidx=0&nlaidx=5> By William Janes Standard Chartered on Tuesday lost its bid to strike out claims from passive investors worth £762 million ($987 million) as part of litigation against the bank for allegedly making untrue or misleading statements about its noncompliance with sanctions. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2315191?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_more=1&nlsidx=0&nlaidx=5> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2315191?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_later=1&nlsidx=0&nlaidx=5> Traders Fight To Overturn 'Unsafe' Rate-Rigging Convictions <https://www.law360.co.uk/financial-services-uk/articles/2315168?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_main=1&nlsidx=0&nlaidx=0> By Sophia Dourou Two traders urged Britain's highest court on Tuesday to overturn their convictions for rate-rigging, arguing that it was not automatically dishonest of them to take into account their "trading advantage" when they made interest rate submissions. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2315168?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_more=1&nlsidx=0&nlaidx=0> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2315168?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_later=1&nlsidx=0&nlaidx=0> Briton Bids To Overturn 'Unlawful' Bribery Extradition Request <https://www.law360.co.uk/financial-services-uk/articles/2315186?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_main=1&nlsidx=0&nlaidx=1> By Ronan Barnard A Briton wanted in South Africa over an alleged £36 million ($46 million) government bribery scandal argued in a London court Tuesday that the extradition should be overturned, as the original request is unlawful. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2315186?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_more=1&nlsidx=0&nlaidx=1> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2315186?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_later=1&nlsidx=0&nlaidx=1> FCA Boss Presses Pro-Reform MPs For Clarity On Risk <https://www.law360.co.uk/financial-services-uk/articles/2314540?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_main=1&nlsidx=0&nlaidx=2> By Alex Davidson The chief executive of the Financial Conduct Authority called Tuesday on MPs pressing for regulatory reform for clarification of how much risk is acceptable in the pursuit of growth as he warned of a potential rise in money laundering and property defaults. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2314540?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_more=1&nlsidx=0&nlaidx=2> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2314540?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-26&read_later=1&nlsidx=0&nlaidx=2> xNY.io - Bank respectfully reserves all Interjurisdictional rights. Thank you, Gunnar Larson -- Gunnar Donald Arthur Peter Larson *xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001 On Tue, Mar 25, 2025, 2:09 PM Gunnar Larson <g@xny.io> wrote:

Goldman Sachs:

xNY.io - Bank.org shares with Goldman Sachs' Board Directors; 187 highlights to the Department of Justice’s " *Prosecuting Computer Crimes, Computer* *Crime and Intellectual Property Section, Criminal Division*," published by the Office of Legal Education, Executive Office for United States Attorneys.

*Computer Crimes Manual Highlights.pdf:*

- https://drive.google.com/file/d/11tbgHgDg8qagomO-NBffvIFpxXKmBC3g/view?usp=d...

xNY.io - Bank.org has organized seven references to xNY.io - Bank.org's Apple Card research for Goldman Sachs' Board Directors.

*xNY.io - Bank.org: Apple Card NYDFS Superintendent Linda Lacewell:*

- https://drive.google.com/drive/folders/1TK34x1EdMVKJkJ3oWreaen9ETHoTezjq

xNY.io - Bank.org's research on Apple Card paints a stark image for Goldman Sachs' Board Directors if the firm knowingly made effort to defraud the United States of America *AND* xNY.io - Bank.org*; *

- While under active Deferred Prosecution Agreement with the United States of America.

UMich Students Sue Over Ex-Coach's Alleged Hacking <https://www.law360.com/cybersecurity-privacy/articles/2314702?nl_pk=fb101149-eb3b-4ea0-9196-fcd8c48ca69a&utm_source=newsletter&utm_medium=email&utm_campaign=cybersecurity-privacy&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=8>

By Carolyn Muyskens

Student-athletes are claiming the University of Michigan and a software company failed to safeguard their private information from an assistant football coach recently charged with computer crimes, filing a lawsuit one day after the former coach's indictment was unveiled.

Complaint attached | Read full article » <https://www.law360.com/cybersecurity-privacy/articles/2314702?nl_pk=fb101149-eb3b-4ea0-9196-fcd8c48ca69a&utm_source=newsletter&utm_medium=email&utm_campaign=cybersecurity-privacy&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=8> | Save to favorites » <https://www.law360.com/cybersecurity-privacy/articles/2314702?nl_pk=fb101149-eb3b-4ea0-9196-fcd8c48ca69a&utm_source=newsletter&utm_medium=email&utm_campaign=cybersecurity-privacy&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=8> xNY.io - Bank respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson

*xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001

On Tue, Mar 25, 2025, 11:14 AM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

Mastercard Seeks To Limit Swipe Fee Damages Bill <https://www.law360.co.uk/financial-services-uk/articles/2314558?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=2>

By Lucia Osborne-Crowley

Mastercard urged a tribunal on Monday to limit the damages it must pay to intermediaries such as Worldpay over unlawful interchange fees, arguing that the acquirers' proposed damages bill is too broad and covers too long a period of time.

Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2314558?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=2> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2314558?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=2>

Feds, Javice Rest In Trial Over JPMorgan's $175M Frank Buy <https://www.law360.com/newyork/articles/2315077?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=4>

By Stewart Bishop

Manhattan federal prosecutors and Charlie Javice on Monday both wrapped up their cases in the trial of the former Frank CEO and another executive, who are accused of tricking JPMorgan into buying the education startup for $175 million based on false information.

Read full article » <https://www.law360.com/newyork/articles/2315077?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=4> | Save to favorites » <https://www.law360.com/newyork/articles/2315077?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=4>

Hayes Appeal Set To Test Theory Of Rate-Rigging Convictions <https://www.law360.co.uk/financial-services-uk/articles/2313950?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=0>

By Christopher Crosby

Two former City traders will appeal against their convictions for rigging interest rates before Britain's top court on Tuesday in a case that could have implications for the premise that underpins the rate-rigging prosecutions of dozens of others in the wake of the 2008 financial crisis.

Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2313950?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=0> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2313950?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=0> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson

*xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001

On Fri, Mar 21, 2025, 6:40 PM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

Today, xNY.io - Bank.org doubles down on our commitment to Peace on Planet Earth.

xNY.io - Bank.org shares 492 highlights to: *"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."*

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson

*xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001

*----- (PAGE BREAK) -----*

*492 highlights to:** "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."*

*INTRODUCTION*

*March 24, 2022*

* - 158 Highlights: https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=d... <https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=drivesdk>*

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=d... <https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=drivesdk>*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@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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=3>

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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=3> | Save to favorites » <https://www.law360.com/newyork/articles/2311047?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=3>

Three Arrows Beats FTX To Get $1.5B Bankruptcy Claim <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=7>

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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=7> | Save to favorites » <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=7> 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@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@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-GPlVoiLAeeBXUrxwOFT...

May 1, 2022

BY ELECTRONIC MAIL

Investor Relations Board of Directors, JPMorgan Chase & Co. 277 Park Avenue New York, NY 10172-0003 JPMCinvestorrelations@jpmchase.com

Re: JPMorgan Chase Board of Directors ESG Marketplace Manipulation

Dear Board of Directors:

xNY.io - Bank.org recently contacted JPMorgan Chase’s board of directors to communicate our concern(s) that potentially JPMorgan Chase may be engaging in exploitation of more than $100B of ESG asset liabilities, across international regulatory arbitrage structures, while headquartered in Manhattan. Specifically, the duty to promote the success of the company is that a director must act in the way that she considers, in good faith, and would be most likely to promote the success of the company for the benefit of its members as a whole.

-

Failure by a board to adequately consider ESG-related risks, particularly entity-specific compliance risks such as breach of securities laws, could serve as the basis for liability of individual directors or officers for breach of their fiduciary duties.

Given JPMorgan’s five cout felonies, xNY.io - Bank.org is concerned with your board of director governance in preventing ESG fraud. xNY.io - Bank.org’s assessment of JPMorgan’s board embraces fundamentals including liquidity risk and protecting New York ESG cross border innovation from marketplace manipulation.

-

According to JPMorgan’s August 2021 Sovereigns and ESG whitepaper, the bank states that governance carries the largest weight of the three ESG pillars across scores, as it is the most empirically relevant for asset prices. -

JPMorgan notes that philosophically, the bank views good governance as a foundational pillar for positive ESG developments in other pillars.

Today’s memo follows protocol suggested by the United States of America, in that JPMorgan Chase’s board of directors is responsible to xNY.io - Bank.org’s enterprise and the Department of the Interior, in connection with any action alleging a violation of the Endangered Species Act, by any person (“person” means an individual, corporation, partnership, trust, association, or any other private entity) claiming the benefit of any exemption or permit under the Act, who shall have the burden of proving that the exemption or permit is applicable, or has been granted, and was valid and in force at the time of alleged violation.

xNY.io - Bank.org has made 91 highlights to the Department of Interior’s Endangered Species Act for JPMorgan Chase’s board of directors reference.

1.

xNY.io - Bank.org has reason to believe in the JPMorgan Chase board of directors’ engagement of ESG marketplace manipulation, risking your ESG portfolio’s future at the cost of New York digital asset innovation. 2.

xNY.io - Bank.org references your 2021 Environmental Social and Governance Report, totaling $117B of ESG “development funding” transferred from New York to Caribbean and Eastern European accounts. 3.

xNY.io - Bank.org is concerned of JPMorgan Chase board directors leveraged marketplace manipulation techniques in allocating ESG funds to engage in potential harassment (the term "harassment" means any act of pursuit, torment, or annoyance) of some of the world’s most precious endangered species protected by domestic and international governance. 4.

JPMorgan Chase’s $2.3B ESG “wind farm” facility is characterized by the Washington Post as a potential misuse of ESG assets (and board policies) to fund probable violation(s) of the Marine Mammal Protection Act of 1972.

Looking internationally, xNY.io - Bank.org is concerned of further ESG marketplace manipulation structures, sacrificing endangered species, via JPMorgan Chase’s board directed ESG investments in the Caribbean (your largest ESG investment region). xNY.io - Bank.org signals that JPMorgan’s board of directors is party to the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere.

Being clear, any violation of the Endangered Species Act, the Marine Mammal Protection Act and/or the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere … Requires xNY.io - Bank.org to consult JPMorgan Chase board members on ESG allocations that may be in conflict with construction, or other development projects, or other forms of economic activity.

xNY.io - Bank.org asks JPMorgan Chase board directors to return the Secretary of Department of the Interior’s approval, confirming licensing and/or exclusion to the Endangered Species Act, with further authorization of “harassment” pursuant to exemption(s). Including (if available) a similar Environmental Protection Agency permit that is applicable and is valid and in force.

-

Due to the riskiness of ESG portfolio mismanagement in violation of the Endangered Species Act, ESG marketplace manipulation risk(s) may trigger causal shocks to New York State monetary and regulatory innovation. -

According to JPMorgan’s sovereign fund ESG research, “A common complaint about ESG analysis is that data can be difficult to source. Some sovereign data is in fact more readily available than corporate data given the multitude of multinational organizations and NGOs – including the World Bank, the IMF and the United Nations.” -

The European Central Bank provides support to the eurozone sovereign debt market but has more restrictions on what and how much it can buy, so eurozone bonds can trade with more credit risk premium compared to other major developed market bonds. -

Whatever the case may be, JPMorgan disclosures detail significant concern of lapse in board governance and ESG portfolio risk with potential violation of the Endangered Species Act, risking ESG portfolio default(s) in Europe and the United States risking ESG customer financial abuse.

Forbes recently profiles JPMorgan Chase ESG investments as problematic, highlighting that your board of directors potentially are allocating ESG proceeds in competition with human rights at the expense of customers’ best interests while investing heavily in fossil fuels. A letter to JPMorgan Chase’s board of directors from ESG scholars (including, The Sierra Club, Public Citizen, Greenpeace, Amazon Watch, Revolving Door Project, Rainforest Action Network and the Center for International Environmental Law) suggests the bank would “...lock us into energy sources that are overly expensive and subject to wild price swings, and that exacerbate rather than ease global conflict.”

xNY.io - Bank.org aims to protect ESG digital asset innovation and JPMorgan’s board should understand your proprietary ESG scoring matrix should signal seismic marketplace manipulation risk if directors are in potential violation of any Endangered Species Act covenant.

-

Head of Europe, Middle East, and Africa (EMEA) distribution at JP Morgan Asset Management says, “In Europe, we do not have a semi-transparent product – like the US and Australia – which would add further complexity to the trading. For example, the US has several models which make it harder for the AP to guess what the actual fund looks like and therefore the costs might be higher accordingly.” -

Given, JPMorgan may potentially be in breach of United States Endangered Species Act provisions, similar risk of ESG asset failure(s) may include Europe, Middle East, Africa and Australia international law, as ratified by the Convention on International Trade in Endangered Species of Wild Fauna and Flora.

While directors and officers are likely to be particularly focused on the risk that they may be found personally liable for a breach of their duties, proper ESG compliance with fiduciary obligations requires acting to a higher standard. Given the defenses available to fiduciaries, and the difficulty in bringing claims for breach of fiduciary duty, a director or officer found to be liable for such ESG breaches will generally have acted egregiously. This ‘sliding scale’ of the standards to which directors and officers should adhere.

Following the Endangered Species Act, xNY.io - Bank.org kindly petitions JPMorgan’s board of directors, in connection with all ESG investments, claiming the benefit of any exemption or permit under the United States Department of the Interior’s Endangered Species Act … Shall have the burden of proving that an exemption or permit is applicable, or has been granted, and is valid and in force.

-

At JPMorgan’s earliest convenience (within 60 days of receipt of this memo) xNY.io - Bank.org kindly requests a certified copy of JPMorgan Chase’s approval by the Department of the Interior, being a license and/or exclusion to the Endangered Species Act and/or the Marine Mammal Protection Act. -

JPMorgan Chase suggests a commitment to anti-corruption compliance is central to the success of its business. Your board of directors stand to maintain that trust by promoting a corporate culture that encourages ethical business practices and compliance with both the letter and the spirit of the laws of the countries in which the JPMorgan conducts business.

xNY.io - Bank.org’s research guidance from the United States Securities and Exchange Commision, supports the international community in taking actions to address ESG issues on a global basis, and those actions that can have a material impact on companies.

Future correspondence concerning ESG innovation is at your board’s leisure.

Respectfully yours with appreciation,

Gunnar Larson | xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>, PBC MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/> - Entrepreneurship and Innovation (ip) G@xNY.io +1-646-454-9107

On Fri, Mar 14, 2025, 6:34 PM Gunnar Larson <g@xny.io> wrote:

Goldman Sachs:

Is Goldman Sachs a potential negligent terrorist organization?

- *xNY.io - Bank.org demands a response from Goldman Sachs confirming your firm is innocent of possible terrorism actions across your Investment Bank. * - *xNY.io - Bank.org demands Goldman Sachs' answer by 12:00pm EST**, Monday, March 17, 2025.*

On Fri, Mar 21, 2025, 3:25 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

xNY.io - Bank.org has made 37 highlights to Nanjing Audit University's "*Can D&O insurance improve corporate ESG performance*?" for Meta Platforms' Board.

*Can D&O insurance improve corporate ESG performance?:*

- https://drive.google.com/file/d/1kYBR93f7fzdculQZk9MGUkPlX23WTKQm/view?usp=d...

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Fri, Mar 21, 2025, 1:19 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

Will Goldman Sachs' Board Directors submit the Board to an audit of the Deferred Agreement’s mandates?

xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution Agreement holds certain risk requirements.

*Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:*

- https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d...

*"Periodic Risk-Based Review *

* 5. The Company will develop these compliance policies and procedures on the basis of a periodic risk assessment addressing the individual circumstances of the Company, in particular the foreign bribery risks facing the Company, including, but not limited to, its geographical organization, interactions with various types and levels of government officials, industrial sectors of operation, potential clients and business partners, use of third parties, gifts, travel and entertainment expenses, charitable and political donations, involvement in joint venture arrangements, importance of licenses and permits in the Company’s operations, degree of governmental oversight and inspection, and volume and importance of goods and personnel clearing through customs and immigration. *

* 6. The Company shall review its anti-corruption compliance policies and procedures no less than annually and update them as appropriate to ensure their continued effectiveness, taking into account relevant developments in the field and evolving international and industry standards."*

Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk.

*Forum Statement on OCC’s Removal of Reputation Risk*

*Washington, D.C. – *Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk:

“We appreciate the OCC’s action to ensure bank supervision is focused on financial and other material risks. Today’s decision is an important step to create a more transparent and effective regulatory environment. We look forward to continuing to work with the Administration and Congress to identify solutions that allow America’s leading banks to continue to best serve their customers.”

###

Goldman Sachs: xNY.io - Bank.org has historical significance from the April 02, 2021 Financial Times reporting included apart of Memo #4's 23 footnote references. *Memo #4 - Goldman Sachs Deferred Prosecution Agreement: * - https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d... *-----(PAGE BREAK)-----* *The Bank of Cyprus and Illegal Short Selling Irregularities of Turkey’s Markets* *"...Turn this matter as we will, and look at it from any side whatsoever, and it presents the appearance of a cross-border act of aggression. Goldman Sachs’ potential disrespect to the Deferred Agreement’s core values has cultivated new crimes that aim to manipulate cross-border war crime regulatory frameworks.* - *On April 02, 2021 the Financial Times reported that Turkey fined Goldman Sachs over alleged irregularities in short selling, just a week after foreign investors pulled $1.9B from the country’s stock and bond markets. Turkey’s Capital Markets Board said that Goldman Sachs was among 10 securities firms that had placed orders for short selling without proper notification, violating rules enacted previously that temporarily prohibited such transactions. * - *On April 20, 2021 the CyprusMail (Cyprus’ only English Language daily newspaper) reported Goldman Sachs International acted as Global Coordinators and Dealer Managers in a $330M bond issuance for the Bank of Cyprus. * *Given the active military conflict in Cyprus, Memo #4 notes that there is one place on the planet you are not supposed to do this sort of thing. Furthermore, the DOJ’s Deferred Agreement with Goldman Sachs may have been tainted with the potential war crime of aggression, risking international peace and the lives of United Nations peacekeepers, while jeopardizing the United States of America’s financial security." * *-----(PAGE BREAK)-----* 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 reporting requirements. xNY.io - Bank respectfully reserves all Interjurisdictional rights. Thank you, Gunnar Larson -- Gunnar Donald Arthur Peter Larson *xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001 On Thu, Mar 27, 2025, 8:30 AM Gunnar Larson <g@xny.io> wrote:

Goldman Sachs:

Will Goldman Sachs' Board Directors submit the Board to an audit of the Deferred Agreement’s mandates?

- *xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution Agreement holds certain reporting requirements. *

*Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:*

- https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d...

*"ATTACHMENT D * *REPORTING REQUIREMENTS * *The Company agrees that it will report to the Offices periodically, at no less than twelve-month intervals during a three-year term, regarding remediation and implementation of the compliance program and internal controls, policies, and procedures described in Attachment C. * *During this three-year period, the Company shall: (1) conduct an initial review and submit an initial report, and (2) conduct and prepare at least two follow-up reviews and reports, as described * *below:*"

WeRealize Denies JPMorgan's Breach Claim In JV Dispute <https://www.law360.co.uk/financial-services-uk/articles/2314546?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-27&read_main=1&nlsidx=0&nlaidx=3>

By William Janes

Fintech business WeRealize has hit back at a JPMorgan Chase & Co. unit's latest claim in a protracted battle, denying allegations that it was planning to breach the terms of a joint venture shareholder agreement.

Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2314546?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-27&read_more=1&nlsidx=0&nlaidx=3> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2314546?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-27&read_later=1&nlsidx=0&nlaidx=3> xNY.io - Bank respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson

*xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001

On Tue, Mar 25, 2025, 2:09 PM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

xNY.io - Bank.org shares with Goldman Sachs' Board Directors; 187 highlights to the Department of Justice’s " *Prosecuting Computer Crimes, Computer* *Crime and Intellectual Property Section, Criminal Division*," published by the Office of Legal Education, Executive Office for United States Attorneys.

*Computer Crimes Manual Highlights.pdf:*

- https://drive.google.com/file/d/11tbgHgDg8qagomO-NBffvIFpxXKmBC3g/view?usp=d...

xNY.io - Bank.org has organized seven references to xNY.io - Bank.org's Apple Card research for Goldman Sachs' Board Directors.

*xNY.io - Bank.org: Apple Card NYDFS Superintendent Linda Lacewell:*

- https://drive.google.com/drive/folders/1TK34x1EdMVKJkJ3oWreaen9ETHoTezjq

xNY.io - Bank.org's research on Apple Card paints a stark image for Goldman Sachs' Board Directors if the firm knowingly made effort to defraud the United States of America *AND* xNY.io - Bank.org*; *

- While under active Deferred Prosecution Agreement with the United States of America.

UMich Students Sue Over Ex-Coach's Alleged Hacking <https://www.law360.com/cybersecurity-privacy/articles/2314702?nl_pk=fb101149-eb3b-4ea0-9196-fcd8c48ca69a&utm_source=newsletter&utm_medium=email&utm_campaign=cybersecurity-privacy&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=8>

By Carolyn Muyskens

Student-athletes are claiming the University of Michigan and a software company failed to safeguard their private information from an assistant football coach recently charged with computer crimes, filing a lawsuit one day after the former coach's indictment was unveiled.

Complaint attached | Read full article » <https://www.law360.com/cybersecurity-privacy/articles/2314702?nl_pk=fb101149-eb3b-4ea0-9196-fcd8c48ca69a&utm_source=newsletter&utm_medium=email&utm_campaign=cybersecurity-privacy&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=8> | Save to favorites » <https://www.law360.com/cybersecurity-privacy/articles/2314702?nl_pk=fb101149-eb3b-4ea0-9196-fcd8c48ca69a&utm_source=newsletter&utm_medium=email&utm_campaign=cybersecurity-privacy&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=8> xNY.io - Bank respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson

*xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001

On Tue, Mar 25, 2025, 11:14 AM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

Mastercard Seeks To Limit Swipe Fee Damages Bill <https://www.law360.co.uk/financial-services-uk/articles/2314558?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=2>

By Lucia Osborne-Crowley

Mastercard urged a tribunal on Monday to limit the damages it must pay to intermediaries such as Worldpay over unlawful interchange fees, arguing that the acquirers' proposed damages bill is too broad and covers too long a period of time.

Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2314558?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=2> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2314558?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=2>

Feds, Javice Rest In Trial Over JPMorgan's $175M Frank Buy <https://www.law360.com/newyork/articles/2315077?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=4>

By Stewart Bishop

Manhattan federal prosecutors and Charlie Javice on Monday both wrapped up their cases in the trial of the former Frank CEO and another executive, who are accused of tricking JPMorgan into buying the education startup for $175 million based on false information.

Read full article » <https://www.law360.com/newyork/articles/2315077?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=4> | Save to favorites » <https://www.law360.com/newyork/articles/2315077?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=4>

Hayes Appeal Set To Test Theory Of Rate-Rigging Convictions <https://www.law360.co.uk/financial-services-uk/articles/2313950?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_main=1&nlsidx=0&nlaidx=0>

By Christopher Crosby

Two former City traders will appeal against their convictions for rigging interest rates before Britain's top court on Tuesday in a case that could have implications for the premise that underpins the rate-rigging prosecutions of dozens of others in the wake of the 2008 financial crisis.

Read full article » <https://www.law360.co.uk/financial-services-uk/articles/2313950?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_more=1&nlsidx=0&nlaidx=0> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2313950?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-25&read_later=1&nlsidx=0&nlaidx=0> xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson

*xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001

On Fri, Mar 21, 2025, 6:40 PM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

Today, xNY.io - Bank.org doubles down on our commitment to Peace on Planet Earth.

xNY.io - Bank.org shares 492 highlights to: *"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."*

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson

*xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001

*----- (PAGE BREAK) -----*

*492 highlights to:** "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."*

*INTRODUCTION*

*March 24, 2022*

* - 158 Highlights: https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=d... <https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=drivesdk>*

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=d... <https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=drivesdk>*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@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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=3>

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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=3> | Save to favorites » <https://www.law360.com/newyork/articles/2311047?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=3>

Three Arrows Beats FTX To Get $1.5B Bankruptcy Claim <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=7>

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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=7> | Save to favorites » <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=7> 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@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@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-GPlVoiLAeeBXUrxwOFT...

May 1, 2022

BY ELECTRONIC MAIL

Investor Relations Board of Directors, JPMorgan Chase & Co. 277 Park Avenue New York, NY 10172-0003 JPMCinvestorrelations@jpmchase.com

Re: JPMorgan Chase Board of Directors ESG Marketplace Manipulation

Dear Board of Directors:

xNY.io - Bank.org recently contacted JPMorgan Chase’s board of directors to communicate our concern(s) that potentially JPMorgan Chase may be engaging in exploitation of more than $100B of ESG asset liabilities, across international regulatory arbitrage structures, while headquartered in Manhattan. Specifically, the duty to promote the success of the company is that a director must act in the way that she considers, in good faith, and would be most likely to promote the success of the company for the benefit of its members as a whole.

-

Failure by a board to adequately consider ESG-related risks, particularly entity-specific compliance risks such as breach of securities laws, could serve as the basis for liability of individual directors or officers for breach of their fiduciary duties.

Given JPMorgan’s five cout felonies, xNY.io - Bank.org is concerned with your board of director governance in preventing ESG fraud. xNY.io - Bank.org’s assessment of JPMorgan’s board embraces fundamentals including liquidity risk and protecting New York ESG cross border innovation from marketplace manipulation.

-

According to JPMorgan’s August 2021 Sovereigns and ESG whitepaper, the bank states that governance carries the largest weight of the three ESG pillars across scores, as it is the most empirically relevant for asset prices. -

JPMorgan notes that philosophically, the bank views good governance as a foundational pillar for positive ESG developments in other pillars.

Today’s memo follows protocol suggested by the United States of America, in that JPMorgan Chase’s board of directors is responsible to xNY.io - Bank.org’s enterprise and the Department of the Interior, in connection with any action alleging a violation of the Endangered Species Act, by any person (“person” means an individual, corporation, partnership, trust, association, or any other private entity) claiming the benefit of any exemption or permit under the Act, who shall have the burden of proving that the exemption or permit is applicable, or has been granted, and was valid and in force at the time of alleged violation.

xNY.io - Bank.org has made 91 highlights to the Department of Interior’s Endangered Species Act for JPMorgan Chase’s board of directors reference.

1.

xNY.io - Bank.org has reason to believe in the JPMorgan Chase board of directors’ engagement of ESG marketplace manipulation, risking your ESG portfolio’s future at the cost of New York digital asset innovation. 2.

xNY.io - Bank.org references your 2021 Environmental Social and Governance Report, totaling $117B of ESG “development funding” transferred from New York to Caribbean and Eastern European accounts. 3.

xNY.io - Bank.org is concerned of JPMorgan Chase board directors leveraged marketplace manipulation techniques in allocating ESG funds to engage in potential harassment (the term "harassment" means any act of pursuit, torment, or annoyance) of some of the world’s most precious endangered species protected by domestic and international governance. 4.

JPMorgan Chase’s $2.3B ESG “wind farm” facility is characterized by the Washington Post as a potential misuse of ESG assets (and board policies) to fund probable violation(s) of the Marine Mammal Protection Act of 1972.

Looking internationally, xNY.io - Bank.org is concerned of further ESG marketplace manipulation structures, sacrificing endangered species, via JPMorgan Chase’s board directed ESG investments in the Caribbean (your largest ESG investment region). xNY.io - Bank.org signals that JPMorgan’s board of directors is party to the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere.

Being clear, any violation of the Endangered Species Act, the Marine Mammal Protection Act and/or the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere … Requires xNY.io - Bank.org to consult JPMorgan Chase board members on ESG allocations that may be in conflict with construction, or other development projects, or other forms of economic activity.

xNY.io - Bank.org asks JPMorgan Chase board directors to return the Secretary of Department of the Interior’s approval, confirming licensing and/or exclusion to the Endangered Species Act, with further authorization of “harassment” pursuant to exemption(s). Including (if available) a similar Environmental Protection Agency permit that is applicable and is valid and in force.

-

Due to the riskiness of ESG portfolio mismanagement in violation of the Endangered Species Act, ESG marketplace manipulation risk(s) may trigger causal shocks to New York State monetary and regulatory innovation. -

According to JPMorgan’s sovereign fund ESG research, “A common complaint about ESG analysis is that data can be difficult to source. Some sovereign data is in fact more readily available than corporate data given the multitude of multinational organizations and NGOs – including the World Bank, the IMF and the United Nations.” -

The European Central Bank provides support to the eurozone sovereign debt market but has more restrictions on what and how much it can buy, so eurozone bonds can trade with more credit risk premium compared to other major developed market bonds. -

Whatever the case may be, JPMorgan disclosures detail significant concern of lapse in board governance and ESG portfolio risk with potential violation of the Endangered Species Act, risking ESG portfolio default(s) in Europe and the United States risking ESG customer financial abuse.

Forbes recently profiles JPMorgan Chase ESG investments as problematic, highlighting that your board of directors potentially are allocating ESG proceeds in competition with human rights at the expense of customers’ best interests while investing heavily in fossil fuels. A letter to JPMorgan Chase’s board of directors from ESG scholars (including, The Sierra Club, Public Citizen, Greenpeace, Amazon Watch, Revolving Door Project, Rainforest Action Network and the Center for International Environmental Law) suggests the bank would “...lock us into energy sources that are overly expensive and subject to wild price swings, and that exacerbate rather than ease global conflict.”

xNY.io - Bank.org aims to protect ESG digital asset innovation and JPMorgan’s board should understand your proprietary ESG scoring matrix should signal seismic marketplace manipulation risk if directors are in potential violation of any Endangered Species Act covenant.

-

Head of Europe, Middle East, and Africa (EMEA) distribution at JP Morgan Asset Management says, “In Europe, we do not have a semi-transparent product – like the US and Australia – which would add further complexity to the trading. For example, the US has several models which make it harder for the AP to guess what the actual fund looks like and therefore the costs might be higher accordingly.” -

Given, JPMorgan may potentially be in breach of United States Endangered Species Act provisions, similar risk of ESG asset failure(s) may include Europe, Middle East, Africa and Australia international law, as ratified by the Convention on International Trade in Endangered Species of Wild Fauna and Flora.

While directors and officers are likely to be particularly focused on the risk that they may be found personally liable for a breach of their duties, proper ESG compliance with fiduciary obligations requires acting to a higher standard. Given the defenses available to fiduciaries, and the difficulty in bringing claims for breach of fiduciary duty, a director or officer found to be liable for such ESG breaches will generally have acted egregiously. This ‘sliding scale’ of the standards to which directors and officers should adhere.

Following the Endangered Species Act, xNY.io - Bank.org kindly petitions JPMorgan’s board of directors, in connection with all ESG investments, claiming the benefit of any exemption or permit under the United States Department of the Interior’s Endangered Species Act … Shall have the burden of proving that an exemption or permit is applicable, or has been granted, and is valid and in force.

-

At JPMorgan’s earliest convenience (within 60 days of receipt of this memo) xNY.io - Bank.org kindly requests a certified copy of JPMorgan Chase’s approval by the Department of the Interior, being a license and/or exclusion to the Endangered Species Act and/or the Marine Mammal Protection Act. -

JPMorgan Chase suggests a commitment to anti-corruption compliance is central to the success of its business. Your board of directors stand to maintain that trust by promoting a corporate culture that encourages ethical business practices and compliance with both the letter and the spirit of the laws of the countries in which the JPMorgan conducts business.

xNY.io - Bank.org’s research guidance from the United States Securities and Exchange Commision, supports the international community in taking actions to address ESG issues on a global basis, and those actions that can have a material impact on companies.

Future correspondence concerning ESG innovation is at your board’s leisure.

Respectfully yours with appreciation,

Gunnar Larson | xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>, PBC MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/> - Entrepreneurship and Innovation (ip) G@xNY.io +1-646-454-9107

On Fri, Mar 14, 2025, 6:34 PM Gunnar Larson <g@xny.io> wrote:

Goldman Sachs:

Is Goldman Sachs a potential negligent terrorist organization?

- *xNY.io - Bank.org demands a response from Goldman Sachs confirming your firm is innocent of possible terrorism actions across your Investment Bank. * - *xNY.io - Bank.org demands Goldman Sachs' answer by 12:00pm EST**, Monday, March 17, 2025.*

On Fri, Mar 21, 2025, 3:25 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

xNY.io - Bank.org has made 37 highlights to Nanjing Audit University's "*Can D&O insurance improve corporate ESG performance*?" for Meta Platforms' Board.

*Can D&O insurance improve corporate ESG performance?:*

- https://drive.google.com/file/d/1kYBR93f7fzdculQZk9MGUkPlX23WTKQm/view?usp=d...

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Fri, Mar 21, 2025, 1:19 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

Will Goldman Sachs' Board Directors submit the Board to an audit of the Deferred Agreement’s mandates?

xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution Agreement holds certain risk requirements.

*Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:*

- https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d...

*"Periodic Risk-Based Review *

* 5. The Company will develop these compliance policies and procedures on the basis of a periodic risk assessment addressing the individual circumstances of the Company, in particular the foreign bribery risks facing the Company, including, but not limited to, its geographical organization, interactions with various types and levels of government officials, industrial sectors of operation, potential clients and business partners, use of third parties, gifts, travel and entertainment expenses, charitable and political donations, involvement in joint venture arrangements, importance of licenses and permits in the Company’s operations, degree of governmental oversight and inspection, and volume and importance of goods and personnel clearing through customs and immigration. *

* 6. The Company shall review its anti-corruption compliance policies and procedures no less than annually and update them as appropriate to ensure their continued effectiveness, taking into account relevant developments in the field and evolving international and industry standards."*

Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk.

*Forum Statement on OCC’s Removal of Reputation Risk*

*Washington, D.C. – *Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk:

“We appreciate the OCC’s action to ensure bank supervision is focused on financial and other material risks. Today’s decision is an important step to create a more transparent and effective regulatory environment. We look forward to continuing to work with the Administration and Congress to identify solutions that allow America’s leading banks to continue to best serve their customers.”

###

Dear Goldman Sachs: In 2022, xNY.io founder and co-founder of Bank.org, Gunnar Larson was a writer at LitigationFinanceJournal.com or Legal Funding Journal. Below are two articles Mr. Larson wrote. Hong Kong and Singapore Litigation Investment Forecast <https://litigationfinancejournal.com/hong-kong-and-singapore-litigation-investment-forecast/> International arbitration has experienced an uptick in activity over the past decade, with litigation finance driving increased accessibility to quality arbitration outcomes. Hong Kong and Singapore have both passed regulations to authorize third party funding in each jurisdiction. New research sponsored <https://drive.google.com/file/d/1eqM4r9MPm7JDSBEo8QlHcG8uKDTrW13t/view?usp=sharing> by the Chinese University of Hong Kong, led by faculty of law professor Can Eken profiles Hong Kong and Singapore’s regulatory environment in granular detail. Eken compares and contrasts nuances between both markets, while asking what innovations Hong Kong and Singapore may embrace to further expand third party funding engagement across the international arbitration spectrum. Governments in Hong Kong and Singapore overwhelmingly embrace a ‘soft touch’ approach to litigation finance regulation. Forecasting the region’s growth prospects signal both Hong Kong and Singapore are in competition to be Asia’s arbitration capital, supported by friendly third party funding regulation. Eken suggests that with the high cost associated with international arbitration, viability is often framed by financial capacity. With such need, Hong Kong and Singapore are recognized as having pioneered international arbitration regulation, legalizing the use of third party funding agreements. As an added bonus, we have included 36 highlights <https://drive.google.com/file/d/1eqM4r9MPm7JDSBEo8QlHcG8uKDTrW13t/view?usp=sharing> to Eken’s 23 page essay for your general reference. Check out my new article: https://litigationfinancejournal.com/singapore -ministry-of-laws-new-conditional-fee-agreement-framework/#more-9848 *Singapore Ministry of Law’s New Conditional Fee Agreement Framework * Today (May 4, 2022) marks a historic day in Singapore. Attorneys in Singapore can now enter into conditional fee agreements (CFA) under Singapore’s new CFA framework. The new CFA provisions are an addition to traditional fee agreements under Singapore’s Legal Profession Act. The new CFA framework in Singapore includes CFAs counter-party contracts such as “win, more fee”, “no win, no fee”, and “no win, less fee.” The new CFA framework <https://www.mlaw.gov.sg/news/press-releases/2022-04-29-framework-cfas-in-singapore-commence-4-may-2022> will apply to Singapore-based attorneys, and in some instances to foreign law practitioners. Mediation and arbitration will also be covered as part of the CFA framework. This will include partial coverage of Singapore International Criminal Court (SICC) proceedings. According to the Ministry of Law, the new CFA framework aims to help build out Singapore as a hub for litigation innovation, while enhancing aspects of the country’s legal system. As required by the Ministry of Law, attorneys have strict requirements associated with CFA agreements. Click here <https://www.mlaw.gov.sg/news/press-releases/2022-04-29-framework-cfas-in-singapore-commence-4-may-2022> to read the details in full. *Gunnar Larson * *xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>* MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/> - Entrepreneurship and Innovation (ip) G@xNY.io +1-917-580-8053 New York, New York 10001 On Fri, Mar 21, 2025, 6:40 PM Gunnar Larson <g@xny.io> wrote:

Dear Goldman Sachs:

Today, xNY.io - Bank.org doubles down on our commitment to Peace on Planet Earth.

xNY.io - Bank.org shares 492 highlights to: *"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."*

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson

*xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001

*----- (PAGE BREAK) -----*

*492 highlights to:** "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."*

*INTRODUCTION*

*March 24, 2022*

* - 158 Highlights: https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=d... <https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=drivesdk>*

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=d... <https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=drivesdk>*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@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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=3>

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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=3> | Save to favorites » <https://www.law360.com/newyork/articles/2311047?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=3>

Three Arrows Beats FTX To Get $1.5B Bankruptcy Claim <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=7>

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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=7> | Save to favorites » <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=7> 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@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@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-GPlVoiLAeeBXUrxwOFT...

May 1, 2022

BY ELECTRONIC MAIL

Investor Relations Board of Directors, JPMorgan Chase & Co. 277 Park Avenue New York, NY 10172-0003 JPMCinvestorrelations@jpmchase.com

Re: JPMorgan Chase Board of Directors ESG Marketplace Manipulation

Dear Board of Directors:

xNY.io - Bank.org recently contacted JPMorgan Chase’s board of directors to communicate our concern(s) that potentially JPMorgan Chase may be engaging in exploitation of more than $100B of ESG asset liabilities, across international regulatory arbitrage structures, while headquartered in Manhattan. Specifically, the duty to promote the success of the company is that a director must act in the way that she considers, in good faith, and would be most likely to promote the success of the company for the benefit of its members as a whole.

-

Failure by a board to adequately consider ESG-related risks, particularly entity-specific compliance risks such as breach of securities laws, could serve as the basis for liability of individual directors or officers for breach of their fiduciary duties.

Given JPMorgan’s five cout felonies, xNY.io - Bank.org is concerned with your board of director governance in preventing ESG fraud. xNY.io - Bank.org’s assessment of JPMorgan’s board embraces fundamentals including liquidity risk and protecting New York ESG cross border innovation from marketplace manipulation.

-

According to JPMorgan’s August 2021 Sovereigns and ESG whitepaper, the bank states that governance carries the largest weight of the three ESG pillars across scores, as it is the most empirically relevant for asset prices. -

JPMorgan notes that philosophically, the bank views good governance as a foundational pillar for positive ESG developments in other pillars.

Today’s memo follows protocol suggested by the United States of America, in that JPMorgan Chase’s board of directors is responsible to xNY.io - Bank.org’s enterprise and the Department of the Interior, in connection with any action alleging a violation of the Endangered Species Act, by any person (“person” means an individual, corporation, partnership, trust, association, or any other private entity) claiming the benefit of any exemption or permit under the Act, who shall have the burden of proving that the exemption or permit is applicable, or has been granted, and was valid and in force at the time of alleged violation.

xNY.io - Bank.org has made 91 highlights to the Department of Interior’s Endangered Species Act for JPMorgan Chase’s board of directors reference.

1.

xNY.io - Bank.org has reason to believe in the JPMorgan Chase board of directors’ engagement of ESG marketplace manipulation, risking your ESG portfolio’s future at the cost of New York digital asset innovation. 2.

xNY.io - Bank.org references your 2021 Environmental Social and Governance Report, totaling $117B of ESG “development funding” transferred from New York to Caribbean and Eastern European accounts. 3.

xNY.io - Bank.org is concerned of JPMorgan Chase board directors leveraged marketplace manipulation techniques in allocating ESG funds to engage in potential harassment (the term "harassment" means any act of pursuit, torment, or annoyance) of some of the world’s most precious endangered species protected by domestic and international governance. 4.

JPMorgan Chase’s $2.3B ESG “wind farm” facility is characterized by the Washington Post as a potential misuse of ESG assets (and board policies) to fund probable violation(s) of the Marine Mammal Protection Act of 1972.

Looking internationally, xNY.io - Bank.org is concerned of further ESG marketplace manipulation structures, sacrificing endangered species, via JPMorgan Chase’s board directed ESG investments in the Caribbean (your largest ESG investment region). xNY.io - Bank.org signals that JPMorgan’s board of directors is party to the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere.

Being clear, any violation of the Endangered Species Act, the Marine Mammal Protection Act and/or the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere … Requires xNY.io - Bank.org to consult JPMorgan Chase board members on ESG allocations that may be in conflict with construction, or other development projects, or other forms of economic activity.

xNY.io - Bank.org asks JPMorgan Chase board directors to return the Secretary of Department of the Interior’s approval, confirming licensing and/or exclusion to the Endangered Species Act, with further authorization of “harassment” pursuant to exemption(s). Including (if available) a similar Environmental Protection Agency permit that is applicable and is valid and in force.

-

Due to the riskiness of ESG portfolio mismanagement in violation of the Endangered Species Act, ESG marketplace manipulation risk(s) may trigger causal shocks to New York State monetary and regulatory innovation. -

According to JPMorgan’s sovereign fund ESG research, “A common complaint about ESG analysis is that data can be difficult to source. Some sovereign data is in fact more readily available than corporate data given the multitude of multinational organizations and NGOs – including the World Bank, the IMF and the United Nations.” -

The European Central Bank provides support to the eurozone sovereign debt market but has more restrictions on what and how much it can buy, so eurozone bonds can trade with more credit risk premium compared to other major developed market bonds. -

Whatever the case may be, JPMorgan disclosures detail significant concern of lapse in board governance and ESG portfolio risk with potential violation of the Endangered Species Act, risking ESG portfolio default(s) in Europe and the United States risking ESG customer financial abuse.

Forbes recently profiles JPMorgan Chase ESG investments as problematic, highlighting that your board of directors potentially are allocating ESG proceeds in competition with human rights at the expense of customers’ best interests while investing heavily in fossil fuels. A letter to JPMorgan Chase’s board of directors from ESG scholars (including, The Sierra Club, Public Citizen, Greenpeace, Amazon Watch, Revolving Door Project, Rainforest Action Network and the Center for International Environmental Law) suggests the bank would “...lock us into energy sources that are overly expensive and subject to wild price swings, and that exacerbate rather than ease global conflict.”

xNY.io - Bank.org aims to protect ESG digital asset innovation and JPMorgan’s board should understand your proprietary ESG scoring matrix should signal seismic marketplace manipulation risk if directors are in potential violation of any Endangered Species Act covenant.

-

Head of Europe, Middle East, and Africa (EMEA) distribution at JP Morgan Asset Management says, “In Europe, we do not have a semi-transparent product – like the US and Australia – which would add further complexity to the trading. For example, the US has several models which make it harder for the AP to guess what the actual fund looks like and therefore the costs might be higher accordingly.” -

Given, JPMorgan may potentially be in breach of United States Endangered Species Act provisions, similar risk of ESG asset failure(s) may include Europe, Middle East, Africa and Australia international law, as ratified by the Convention on International Trade in Endangered Species of Wild Fauna and Flora.

While directors and officers are likely to be particularly focused on the risk that they may be found personally liable for a breach of their duties, proper ESG compliance with fiduciary obligations requires acting to a higher standard. Given the defenses available to fiduciaries, and the difficulty in bringing claims for breach of fiduciary duty, a director or officer found to be liable for such ESG breaches will generally have acted egregiously. This ‘sliding scale’ of the standards to which directors and officers should adhere.

Following the Endangered Species Act, xNY.io - Bank.org kindly petitions JPMorgan’s board of directors, in connection with all ESG investments, claiming the benefit of any exemption or permit under the United States Department of the Interior’s Endangered Species Act … Shall have the burden of proving that an exemption or permit is applicable, or has been granted, and is valid and in force.

-

At JPMorgan’s earliest convenience (within 60 days of receipt of this memo) xNY.io - Bank.org kindly requests a certified copy of JPMorgan Chase’s approval by the Department of the Interior, being a license and/or exclusion to the Endangered Species Act and/or the Marine Mammal Protection Act. -

JPMorgan Chase suggests a commitment to anti-corruption compliance is central to the success of its business. Your board of directors stand to maintain that trust by promoting a corporate culture that encourages ethical business practices and compliance with both the letter and the spirit of the laws of the countries in which the JPMorgan conducts business.

xNY.io - Bank.org’s research guidance from the United States Securities and Exchange Commision, supports the international community in taking actions to address ESG issues on a global basis, and those actions that can have a material impact on companies.

Future correspondence concerning ESG innovation is at your board’s leisure.

Respectfully yours with appreciation,

Gunnar Larson | xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>, PBC MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/> - Entrepreneurship and Innovation (ip) G@xNY.io +1-646-454-9107

On Fri, Mar 14, 2025, 6:34 PM Gunnar Larson <g@xny.io> wrote:

Goldman Sachs:

Is Goldman Sachs a potential negligent terrorist organization?

- *xNY.io - Bank.org demands a response from Goldman Sachs confirming your firm is innocent of possible terrorism actions across your Investment Bank. * - *xNY.io - Bank.org demands Goldman Sachs' answer by 12:00pm EST**, Monday, March 17, 2025.*

On Fri, Mar 21, 2025, 3:25 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

xNY.io - Bank.org has made 37 highlights to Nanjing Audit University's "*Can D&O insurance improve corporate ESG performance*?" for Meta Platforms' Board.

*Can D&O insurance improve corporate ESG performance?:*

- https://drive.google.com/file/d/1kYBR93f7fzdculQZk9MGUkPlX23WTKQm/view?usp=d...

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Fri, Mar 21, 2025, 1:19 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

Will Goldman Sachs' Board Directors submit the Board to an audit of the Deferred Agreement’s mandates?

xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution Agreement holds certain risk requirements.

*Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:*

- https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d...

*"Periodic Risk-Based Review *

* 5. The Company will develop these compliance policies and procedures on the basis of a periodic risk assessment addressing the individual circumstances of the Company, in particular the foreign bribery risks facing the Company, including, but not limited to, its geographical organization, interactions with various types and levels of government officials, industrial sectors of operation, potential clients and business partners, use of third parties, gifts, travel and entertainment expenses, charitable and political donations, involvement in joint venture arrangements, importance of licenses and permits in the Company’s operations, degree of governmental oversight and inspection, and volume and importance of goods and personnel clearing through customs and immigration. *

* 6. The Company shall review its anti-corruption compliance policies and procedures no less than annually and update them as appropriate to ensure their continued effectiveness, taking into account relevant developments in the field and evolving international and industry standards."*

Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk.

*Forum Statement on OCC’s Removal of Reputation Risk*

*Washington, D.C. – *Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk:

“We appreciate the OCC’s action to ensure bank supervision is focused on financial and other material risks. Today’s decision is an important step to create a more transparent and effective regulatory environment. We look forward to continuing to work with the Administration and Congress to identify solutions that allow America’s leading banks to continue to best serve their customers.”

###

*The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.*

*Visit our website: **fsforum.com* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-r/>

*Follow us on X **@fsforum* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-y/> * and **LinkedIn* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-j/>

[image: Twitter] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-t/>[image: LinkedIn] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-i/>[image: Website] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-d/>[image: Instagram] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-h/>[image: Threads] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-k/>[image: YouTube] <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-u/>

<https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-o/>

The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Thu, Mar 20, 2025, 8:31 AM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

xNY.io - Bank.org is concerned Goldman Sachs is potentially 'obstructing justice' against xNY.io - Bank.org's global enterprise.

Swiss Bank Accused Of Ignoring $1B Kuwaiti Bribery Scheme <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_main=1&nlsidx=0&nlaidx=1>

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=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_more=1&nlsidx=0&nlaidx=1> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_later=1&nlsidx=0&nlaidx=1>

Goldstein Says Feds 'Misled' Court With Obstruction Claim <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_main=1&nlsidx=1&nlaidx=6>

By Phillip Bantz

U.S. Supreme Court lawyer and SCOTUSblog publisher Tom Goldstein wants a Maryland federal judge to sanction prosecutors in his tax evasion case for a "pattern of false and misleading statements" to the court accusing him of hiding millions in cryptocurrency and bribing his former law firm manager.

2 documents attached | <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_more=1&nlsidx=1&nlaidx=6>

On Fri, Mar 21, 2025, 6:40 PM Gunnar Larson <g@xny.io> wrote:

Dear Goldman Sachs:

Today, xNY.io - Bank.org doubles down on our commitment to Peace on Planet Earth.

xNY.io - Bank.org shares 492 highlights to: *"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."*

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson

*xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001

*----- (PAGE BREAK) -----*

*492 highlights to:** "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."*

*INTRODUCTION*

*March 24, 2022*

* - 158 Highlights: https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=d... <https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=drivesdk>*

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=d... <https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=drivesdk>*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@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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=3>

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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=3> | Save to favorites » <https://www.law360.com/newyork/articles/2311047?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=3>

Three Arrows Beats FTX To Get $1.5B Bankruptcy Claim <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=7>

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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=7> | Save to favorites » <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=7> 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@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@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-GPlVoiLAeeBXUrxwOFT...

May 1, 2022

BY ELECTRONIC MAIL

Investor Relations Board of Directors, JPMorgan Chase & Co. 277 Park Avenue New York, NY 10172-0003 JPMCinvestorrelations@jpmchase.com

Re: JPMorgan Chase Board of Directors ESG Marketplace Manipulation

Dear Board of Directors:

xNY.io - Bank.org recently contacted JPMorgan Chase’s board of directors to communicate our concern(s) that potentially JPMorgan Chase may be engaging in exploitation of more than $100B of ESG asset liabilities, across international regulatory arbitrage structures, while headquartered in Manhattan. Specifically, the duty to promote the success of the company is that a director must act in the way that she considers, in good faith, and would be most likely to promote the success of the company for the benefit of its members as a whole.

-

Failure by a board to adequately consider ESG-related risks, particularly entity-specific compliance risks such as breach of securities laws, could serve as the basis for liability of individual directors or officers for breach of their fiduciary duties.

Given JPMorgan’s five cout felonies, xNY.io - Bank.org is concerned with your board of director governance in preventing ESG fraud. xNY.io - Bank.org’s assessment of JPMorgan’s board embraces fundamentals including liquidity risk and protecting New York ESG cross border innovation from marketplace manipulation.

-

According to JPMorgan’s August 2021 Sovereigns and ESG whitepaper, the bank states that governance carries the largest weight of the three ESG pillars across scores, as it is the most empirically relevant for asset prices. -

JPMorgan notes that philosophically, the bank views good governance as a foundational pillar for positive ESG developments in other pillars.

Today’s memo follows protocol suggested by the United States of America, in that JPMorgan Chase’s board of directors is responsible to xNY.io - Bank.org’s enterprise and the Department of the Interior, in connection with any action alleging a violation of the Endangered Species Act, by any person (“person” means an individual, corporation, partnership, trust, association, or any other private entity) claiming the benefit of any exemption or permit under the Act, who shall have the burden of proving that the exemption or permit is applicable, or has been granted, and was valid and in force at the time of alleged violation.

xNY.io - Bank.org has made 91 highlights to the Department of Interior’s Endangered Species Act for JPMorgan Chase’s board of directors reference.

1.

xNY.io - Bank.org has reason to believe in the JPMorgan Chase board of directors’ engagement of ESG marketplace manipulation, risking your ESG portfolio’s future at the cost of New York digital asset innovation. 2.

xNY.io - Bank.org references your 2021 Environmental Social and Governance Report, totaling $117B of ESG “development funding” transferred from New York to Caribbean and Eastern European accounts. 3.

xNY.io - Bank.org is concerned of JPMorgan Chase board directors leveraged marketplace manipulation techniques in allocating ESG funds to engage in potential harassment (the term "harassment" means any act of pursuit, torment, or annoyance) of some of the world’s most precious endangered species protected by domestic and international governance. 4.

JPMorgan Chase’s $2.3B ESG “wind farm” facility is characterized by the Washington Post as a potential misuse of ESG assets (and board policies) to fund probable violation(s) of the Marine Mammal Protection Act of 1972.

Looking internationally, xNY.io - Bank.org is concerned of further ESG marketplace manipulation structures, sacrificing endangered species, via JPMorgan Chase’s board directed ESG investments in the Caribbean (your largest ESG investment region). xNY.io - Bank.org signals that JPMorgan’s board of directors is party to the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere.

Being clear, any violation of the Endangered Species Act, the Marine Mammal Protection Act and/or the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere … Requires xNY.io - Bank.org to consult JPMorgan Chase board members on ESG allocations that may be in conflict with construction, or other development projects, or other forms of economic activity.

xNY.io - Bank.org asks JPMorgan Chase board directors to return the Secretary of Department of the Interior’s approval, confirming licensing and/or exclusion to the Endangered Species Act, with further authorization of “harassment” pursuant to exemption(s). Including (if available) a similar Environmental Protection Agency permit that is applicable and is valid and in force.

-

Due to the riskiness of ESG portfolio mismanagement in violation of the Endangered Species Act, ESG marketplace manipulation risk(s) may trigger causal shocks to New York State monetary and regulatory innovation. -

According to JPMorgan’s sovereign fund ESG research, “A common complaint about ESG analysis is that data can be difficult to source. Some sovereign data is in fact more readily available than corporate data given the multitude of multinational organizations and NGOs – including the World Bank, the IMF and the United Nations.” -

The European Central Bank provides support to the eurozone sovereign debt market but has more restrictions on what and how much it can buy, so eurozone bonds can trade with more credit risk premium compared to other major developed market bonds. -

Whatever the case may be, JPMorgan disclosures detail significant concern of lapse in board governance and ESG portfolio risk with potential violation of the Endangered Species Act, risking ESG portfolio default(s) in Europe and the United States risking ESG customer financial abuse.

Forbes recently profiles JPMorgan Chase ESG investments as problematic, highlighting that your board of directors potentially are allocating ESG proceeds in competition with human rights at the expense of customers’ best interests while investing heavily in fossil fuels. A letter to JPMorgan Chase’s board of directors from ESG scholars (including, The Sierra Club, Public Citizen, Greenpeace, Amazon Watch, Revolving Door Project, Rainforest Action Network and the Center for International Environmental Law) suggests the bank would “...lock us into energy sources that are overly expensive and subject to wild price swings, and that exacerbate rather than ease global conflict.”

xNY.io - Bank.org aims to protect ESG digital asset innovation and JPMorgan’s board should understand your proprietary ESG scoring matrix should signal seismic marketplace manipulation risk if directors are in potential violation of any Endangered Species Act covenant.

-

Head of Europe, Middle East, and Africa (EMEA) distribution at JP Morgan Asset Management says, “In Europe, we do not have a semi-transparent product – like the US and Australia – which would add further complexity to the trading. For example, the US has several models which make it harder for the AP to guess what the actual fund looks like and therefore the costs might be higher accordingly.” -

Given, JPMorgan may potentially be in breach of United States Endangered Species Act provisions, similar risk of ESG asset failure(s) may include Europe, Middle East, Africa and Australia international law, as ratified by the Convention on International Trade in Endangered Species of Wild Fauna and Flora.

While directors and officers are likely to be particularly focused on the risk that they may be found personally liable for a breach of their duties, proper ESG compliance with fiduciary obligations requires acting to a higher standard. Given the defenses available to fiduciaries, and the difficulty in bringing claims for breach of fiduciary duty, a director or officer found to be liable for such ESG breaches will generally have acted egregiously. This ‘sliding scale’ of the standards to which directors and officers should adhere.

Following the Endangered Species Act, xNY.io - Bank.org kindly petitions JPMorgan’s board of directors, in connection with all ESG investments, claiming the benefit of any exemption or permit under the United States Department of the Interior’s Endangered Species Act … Shall have the burden of proving that an exemption or permit is applicable, or has been granted, and is valid and in force.

-

At JPMorgan’s earliest convenience (within 60 days of receipt of this memo) xNY.io - Bank.org kindly requests a certified copy of JPMorgan Chase’s approval by the Department of the Interior, being a license and/or exclusion to the Endangered Species Act and/or the Marine Mammal Protection Act. -

JPMorgan Chase suggests a commitment to anti-corruption compliance is central to the success of its business. Your board of directors stand to maintain that trust by promoting a corporate culture that encourages ethical business practices and compliance with both the letter and the spirit of the laws of the countries in which the JPMorgan conducts business.

xNY.io - Bank.org’s research guidance from the United States Securities and Exchange Commision, supports the international community in taking actions to address ESG issues on a global basis, and those actions that can have a material impact on companies.

Future correspondence concerning ESG innovation is at your board’s leisure.

Respectfully yours with appreciation,

Gunnar Larson | xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>, PBC MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/> - Entrepreneurship and Innovation (ip) G@xNY.io +1-646-454-9107

On Fri, Mar 14, 2025, 6:34 PM Gunnar Larson <g@xny.io> wrote:

Goldman Sachs:

Is Goldman Sachs a potential negligent terrorist organization?

- *xNY.io - Bank.org demands a response from Goldman Sachs confirming your firm is innocent of possible terrorism actions across your Investment Bank. * - *xNY.io - Bank.org demands Goldman Sachs' answer by 12:00pm EST**, Monday, March 17, 2025.*

On Fri, Mar 21, 2025, 3:25 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

xNY.io - Bank.org has made 37 highlights to Nanjing Audit University's "*Can D&O insurance improve corporate ESG performance*?" for Meta Platforms' Board.

*Can D&O insurance improve corporate ESG performance?:*

- https://drive.google.com/file/d/1kYBR93f7fzdculQZk9MGUkPlX23WTKQm/view?usp=d...

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Fri, Mar 21, 2025, 1:19 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

Will Goldman Sachs' Board Directors submit the Board to an audit of the Deferred Agreement’s mandates?

xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution Agreement holds certain risk requirements.

*Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:*

- https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d...

*"Periodic Risk-Based Review *

* 5. The Company will develop these compliance policies and procedures on the basis of a periodic risk assessment addressing the individual circumstances of the Company, in particular the foreign bribery risks facing the Company, including, but not limited to, its geographical organization, interactions with various types and levels of government officials, industrial sectors of operation, potential clients and business partners, use of third parties, gifts, travel and entertainment expenses, charitable and political donations, involvement in joint venture arrangements, importance of licenses and permits in the Company’s operations, degree of governmental oversight and inspection, and volume and importance of goods and personnel clearing through customs and immigration. *

* 6. The Company shall review its anti-corruption compliance policies and procedures no less than annually and update them as appropriate to ensure their continued effectiveness, taking into account relevant developments in the field and evolving international and industry standards."*

Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk.

*Forum Statement on OCC’s Removal of Reputation Risk*

*Washington, D.C. – *Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk:

“We appreciate the OCC’s action to ensure bank supervision is focused on financial and other material risks. Today’s decision is an important step to create a more transparent and effective regulatory environment. We look forward to continuing to work with the Administration and Congress to identify solutions that allow America’s leading banks to continue to best serve their customers.”

###

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The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Thu, Mar 20, 2025, 8:31 AM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

xNY.io - Bank.org is concerned Goldman Sachs is potentially 'obstructing justice' against xNY.io - Bank.org's global enterprise.

Swiss Bank Accused Of Ignoring $1B Kuwaiti Bribery Scheme <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_main=1&nlsidx=0&nlaidx=1>

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=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_more=1&nlsidx=0&nlaidx=1> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_later=1&nlsidx=0&nlaidx=1>

Goldstein Says Feds 'Misled' Court With Obstruction Claim <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_main=1&nlsidx=1&nlaidx=6>

By Phillip Bantz

U.S. Supreme Court lawyer and SCOTUSblog publisher Tom Goldstein wants a Maryland federal judge to sanction prosecutors in his tax evasion case for a "pattern of false and misleading statements" to the court accusing him of hiding millions in cryptocurrency and bribing his former law firm manager.

2 documents attached | <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_more=1&nlsidx=1&nlaidx=6>

---------- Forwarded message --------- From: Gunnar Larson <g@xny.io> Date: Fri, Mar 21, 2025, 6:40 PM Subject: Re: Memo #4 - Goldman Sachs Deferred Prosecution Agreement; 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." To: <gs-investor-relations@gs.com>, Marzulli, John (USANYE) < John.Marzulli@usdoj.gov>, Harris, Adrienne A (DFS) < Adrienne.Harris@dfs.ny.gov>, <letitia.james@ag.ny.gov> Cc: <jan.bischoping@bnpparibas.com>, cypherpunks < cypherpunks@lists.cpunks.org>, Elena Kontemeniotis < kontemeniotis.e@unic.ac.cy>, <iab@nypd.org>, < JPMCinvestorrelations@jpmchase.com>, Antonis Polemitis < polemitis.an@unic.ac.cy>, <PressOffice@cityhall.nyc.gov> Dear Goldman Sachs: Today, xNY.io - Bank.org doubles down on our commitment to Peace on Planet Earth. xNY.io - Bank.org shares 492 highlights to: *"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."* xNY.io - Bank.org respectfully reserves all Interjurisdictional rights. Thank you, Gunnar Larson -- Gunnar Donald Arthur Peter Larson *xNY.io - Bank.org* 917-580-8053 NEW YORK, NEW YORK 10001 *----- (PAGE BREAK) -----* *492 highlights to:** "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."* *INTRODUCTION* *March 24, 2022* * - 158 Highlights: https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=d... <https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=drivesdk>* 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=d... <https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=drivesdk>*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=d... <https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=drivesdk>*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@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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=3> 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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=3> | Save to favorites » <https://www.law360.com/newyork/articles/2311047?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=3> Three Arrows Beats FTX To Get $1.5B Bankruptcy Claim <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_main=1&nlsidx=0&nlaidx=7> 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-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_more=1&nlsidx=0&nlaidx=7> | Save to favorites » <https://www.law360.com/newyork/articles/2311139?nl_pk=b53aa520-5013-4a8d-a57c-18936227adef&utm_source=newsletter&utm_medium=email&utm_campaign=newyork&utm_content=2025-03-17&read_later=1&nlsidx=0&nlaidx=7> 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@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@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-GPlVoiLAeeBXUrxwOFT... May 1, 2022 BY ELECTRONIC MAIL Investor Relations Board of Directors, JPMorgan Chase & Co. 277 Park Avenue New York, NY 10172-0003 JPMCinvestorrelations@jpmchase.com Re: JPMorgan Chase Board of Directors ESG Marketplace Manipulation Dear Board of Directors: xNY.io - Bank.org recently contacted JPMorgan Chase’s board of directors to communicate our concern(s) that potentially JPMorgan Chase may be engaging in exploitation of more than $100B of ESG asset liabilities, across international regulatory arbitrage structures, while headquartered in Manhattan. Specifically, the duty to promote the success of the company is that a director must act in the way that she considers, in good faith, and would be most likely to promote the success of the company for the benefit of its members as a whole. - Failure by a board to adequately consider ESG-related risks, particularly entity-specific compliance risks such as breach of securities laws, could serve as the basis for liability of individual directors or officers for breach of their fiduciary duties. Given JPMorgan’s five cout felonies, xNY.io - Bank.org is concerned with your board of director governance in preventing ESG fraud. xNY.io - Bank.org’s assessment of JPMorgan’s board embraces fundamentals including liquidity risk and protecting New York ESG cross border innovation from marketplace manipulation. - According to JPMorgan’s August 2021 Sovereigns and ESG whitepaper, the bank states that governance carries the largest weight of the three ESG pillars across scores, as it is the most empirically relevant for asset prices. - JPMorgan notes that philosophically, the bank views good governance as a foundational pillar for positive ESG developments in other pillars. Today’s memo follows protocol suggested by the United States of America, in that JPMorgan Chase’s board of directors is responsible to xNY.io - Bank.org’s enterprise and the Department of the Interior, in connection with any action alleging a violation of the Endangered Species Act, by any person (“person” means an individual, corporation, partnership, trust, association, or any other private entity) claiming the benefit of any exemption or permit under the Act, who shall have the burden of proving that the exemption or permit is applicable, or has been granted, and was valid and in force at the time of alleged violation. xNY.io - Bank.org has made 91 highlights to the Department of Interior’s Endangered Species Act for JPMorgan Chase’s board of directors reference. 1. xNY.io - Bank.org has reason to believe in the JPMorgan Chase board of directors’ engagement of ESG marketplace manipulation, risking your ESG portfolio’s future at the cost of New York digital asset innovation. 2. xNY.io - Bank.org references your 2021 Environmental Social and Governance Report, totaling $117B of ESG “development funding” transferred from New York to Caribbean and Eastern European accounts. 3. xNY.io - Bank.org is concerned of JPMorgan Chase board directors leveraged marketplace manipulation techniques in allocating ESG funds to engage in potential harassment (the term "harassment" means any act of pursuit, torment, or annoyance) of some of the world’s most precious endangered species protected by domestic and international governance. 4. JPMorgan Chase’s $2.3B ESG “wind farm” facility is characterized by the Washington Post as a potential misuse of ESG assets (and board policies) to fund probable violation(s) of the Marine Mammal Protection Act of 1972. Looking internationally, xNY.io - Bank.org is concerned of further ESG marketplace manipulation structures, sacrificing endangered species, via JPMorgan Chase’s board directed ESG investments in the Caribbean (your largest ESG investment region). xNY.io - Bank.org signals that JPMorgan’s board of directors is party to the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere. Being clear, any violation of the Endangered Species Act, the Marine Mammal Protection Act and/or the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere … Requires xNY.io - Bank.org to consult JPMorgan Chase board members on ESG allocations that may be in conflict with construction, or other development projects, or other forms of economic activity. xNY.io - Bank.org asks JPMorgan Chase board directors to return the Secretary of Department of the Interior’s approval, confirming licensing and/or exclusion to the Endangered Species Act, with further authorization of “harassment” pursuant to exemption(s). Including (if available) a similar Environmental Protection Agency permit that is applicable and is valid and in force. - Due to the riskiness of ESG portfolio mismanagement in violation of the Endangered Species Act, ESG marketplace manipulation risk(s) may trigger causal shocks to New York State monetary and regulatory innovation. - According to JPMorgan’s sovereign fund ESG research, “A common complaint about ESG analysis is that data can be difficult to source. Some sovereign data is in fact more readily available than corporate data given the multitude of multinational organizations and NGOs – including the World Bank, the IMF and the United Nations.” - The European Central Bank provides support to the eurozone sovereign debt market but has more restrictions on what and how much it can buy, so eurozone bonds can trade with more credit risk premium compared to other major developed market bonds. - Whatever the case may be, JPMorgan disclosures detail significant concern of lapse in board governance and ESG portfolio risk with potential violation of the Endangered Species Act, risking ESG portfolio default(s) in Europe and the United States risking ESG customer financial abuse. Forbes recently profiles JPMorgan Chase ESG investments as problematic, highlighting that your board of directors potentially are allocating ESG proceeds in competition with human rights at the expense of customers’ best interests while investing heavily in fossil fuels. A letter to JPMorgan Chase’s board of directors from ESG scholars (including, The Sierra Club, Public Citizen, Greenpeace, Amazon Watch, Revolving Door Project, Rainforest Action Network and the Center for International Environmental Law) suggests the bank would “...lock us into energy sources that are overly expensive and subject to wild price swings, and that exacerbate rather than ease global conflict.” xNY.io - Bank.org aims to protect ESG digital asset innovation and JPMorgan’s board should understand your proprietary ESG scoring matrix should signal seismic marketplace manipulation risk if directors are in potential violation of any Endangered Species Act covenant. - Head of Europe, Middle East, and Africa (EMEA) distribution at JP Morgan Asset Management says, “In Europe, we do not have a semi-transparent product – like the US and Australia – which would add further complexity to the trading. For example, the US has several models which make it harder for the AP to guess what the actual fund looks like and therefore the costs might be higher accordingly.” - Given, JPMorgan may potentially be in breach of United States Endangered Species Act provisions, similar risk of ESG asset failure(s) may include Europe, Middle East, Africa and Australia international law, as ratified by the Convention on International Trade in Endangered Species of Wild Fauna and Flora. While directors and officers are likely to be particularly focused on the risk that they may be found personally liable for a breach of their duties, proper ESG compliance with fiduciary obligations requires acting to a higher standard. Given the defenses available to fiduciaries, and the difficulty in bringing claims for breach of fiduciary duty, a director or officer found to be liable for such ESG breaches will generally have acted egregiously. This ‘sliding scale’ of the standards to which directors and officers should adhere. Following the Endangered Species Act, xNY.io - Bank.org kindly petitions JPMorgan’s board of directors, in connection with all ESG investments, claiming the benefit of any exemption or permit under the United States Department of the Interior’s Endangered Species Act … Shall have the burden of proving that an exemption or permit is applicable, or has been granted, and is valid and in force. - At JPMorgan’s earliest convenience (within 60 days of receipt of this memo) xNY.io - Bank.org kindly requests a certified copy of JPMorgan Chase’s approval by the Department of the Interior, being a license and/or exclusion to the Endangered Species Act and/or the Marine Mammal Protection Act. - JPMorgan Chase suggests a commitment to anti-corruption compliance is central to the success of its business. Your board of directors stand to maintain that trust by promoting a corporate culture that encourages ethical business practices and compliance with both the letter and the spirit of the laws of the countries in which the JPMorgan conducts business. xNY.io - Bank.org’s research guidance from the United States Securities and Exchange Commision, supports the international community in taking actions to address ESG issues on a global basis, and those actions that can have a material impact on companies. Future correspondence concerning ESG innovation is at your board’s leisure. Respectfully yours with appreciation, Gunnar Larson | xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>, PBC MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/> - Entrepreneurship and Innovation (ip) G@xNY.io +1-646-454-9107 On Fri, Mar 14, 2025, 6:34 PM Gunnar Larson <g@xny.io> wrote: Goldman Sachs: Is Goldman Sachs a potential negligent terrorist organization? - *xNY.io - Bank.org demands a response from Goldman Sachs confirming your firm is innocent of possible terrorism actions across your Investment Bank. * - *xNY.io - Bank.org demands Goldman Sachs' answer by 12:00pm EST**, Monday, March 17, 2025.* On Fri, Mar 21, 2025, 3:25 AM Gunnar Larson <g@xny.io> wrote:

Dear Goldman Sachs:

xNY.io - Bank.org has made 37 highlights to Nanjing Audit University's "*Can D&O insurance improve corporate ESG performance*?" for Meta Platforms' Board.

*Can D&O insurance improve corporate ESG performance?:*

- https://drive.google.com/file/d/1kYBR93f7fzdculQZk9MGUkPlX23WTKQm/view?usp=d...

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Fri, Mar 21, 2025, 1:19 AM Gunnar Larson <g@xny.io> wrote:

...

Dear Goldman Sachs:

Will Goldman Sachs' Board Directors submit the Board to an audit of the Deferred Agreement’s mandates?

xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution Agreement holds certain risk requirements.

*Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:*

- https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d...

*"Periodic Risk-Based Review *

* 5. The Company will develop these compliance policies and procedures on the basis of a periodic risk assessment addressing the individual circumstances of the Company, in particular the foreign bribery risks facing the Company, including, but not limited to, its geographical organization, interactions with various types and levels of government officials, industrial sectors of operation, potential clients and business partners, use of third parties, gifts, travel and entertainment expenses, charitable and political donations, involvement in joint venture arrangements, importance of licenses and permits in the Company’s operations, degree of governmental oversight and inspection, and volume and importance of goods and personnel clearing through customs and immigration. *

* 6. The Company shall review its anti-corruption compliance policies and procedures no less than annually and update them as appropriate to ensure their continued effectiveness, taking into account relevant developments in the field and evolving international and industry standards."*

Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk.

*Forum Statement on OCC’s Removal of Reputation Risk*

*Washington, D.C. – *Financial Services Forum President and CEO Kevin Fromer issued the following statement after the Office of the Comptroller of the Currency (OCC) announced it will no longer examine its regulated institutions for reputation risk:

“We appreciate the OCC’s action to ensure bank supervision is focused on financial and other material risks. Today’s decision is an important step to create a more transparent and effective regulatory environment. We look forward to continuing to work with the Administration and Congress to identify solutions that allow America’s leading banks to continue to best serve their customers.”

###

*The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.*

*Visit our website: **fsforum.com* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-r/>

*Follow us on X **@fsforum* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-y/> * and **LinkedIn* <https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-j/>

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<https://financialservicesforum.cmail20.com/t/r-l-thtulykl-njyjukhihy-o/>

The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson -- Gunnar Donald Arthur Peter Larson xNY.io - Bank.org 917-580-8053

On Thu, Mar 20, 2025, 8:31 AM Gunnar Larson <g@xny.io> wrote:

...

Goldman Sachs:

xNY.io - Bank.org is concerned Goldman Sachs is potentially 'obstructing justice' against xNY.io - Bank.org's global enterprise.

Swiss Bank Accused Of Ignoring $1B Kuwaiti Bribery Scheme <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_main=1&nlsidx=0&nlaidx=1>

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=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_more=1&nlsidx=0&nlaidx=1> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/2312696?nl_pk=9aaa8860-7735-4b56-abff-576e74202fd7&utm_source=newsletter&utm_medium=email&utm_campaign=financial-services-uk&utm_content=2025-03-20&read_later=1&nlsidx=0&nlaidx=1>

Goldstein Says Feds 'Misled' Court With Obstruction Claim <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_main=1&nlsidx=1&nlaidx=6>

By Phillip Bantz

U.S. Supreme Court lawyer and SCOTUSblog publisher Tom Goldstein wants a Maryland federal judge to sanction prosecutors in his tax evasion case for a "pattern of false and misleading statements" to the court accusing him of hiding millions in cryptocurrency and bribing his former law firm manager.

2 documents attached | <https://www.law360.com/mergersacquisitions/articles/2312749?nl_pk=34b724c6-95c5-49a3-b963-aea9d35fbb95&utm_source=newsletter&utm_medium=email&utm_campaign=mergersacquisitions&utm_content=2025-03-20&read_more=1&nlsidx=1&nlaidx=6>