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Parisi v Sinclair: 75 - REPLY re 65 Order

Parisi v Sinclair: 75 - REPLY re 65 Order

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Published by Lewis Clark
Parisi v Sinclair: 11/02/2010 75 REPLY re 65 Order,,, Plaintiffs Reply To Sinclairs October 25, 2010 Letter Responding To October 20, 2010 Order For SPI To Retain Counsel filed by DANIEL PARISI, WHITE HOUSE COMMUNICATIONS INC., WHITEHOUSE NETWORK LLC, WHITEHOUSE.COM INC.. (Attachments: # 1 Exhibit 1)(Oparil, Richard) (Entered: 11/02/2010)
Parisi v Sinclair: 11/02/2010 75 REPLY re 65 Order,,, Plaintiffs Reply To Sinclairs October 25, 2010 Letter Responding To October 20, 2010 Order For SPI To Retain Counsel filed by DANIEL PARISI, WHITE HOUSE COMMUNICATIONS INC., WHITEHOUSE NETWORK LLC, WHITEHOUSE.COM INC.. (Attachments: # 1 Exhibit 1)(Oparil, Richard) (Entered: 11/02/2010)

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Published by: Lewis Clark on Nov 03, 2010
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11/08/2010

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UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA
)DANIEL PARISI,
et al.
, ))Plaintiffs, ))v. ) No. 1:10-cv-0897-RJL)LAWRENCE W. SINCLAIR a/k/a “Larry Sinclair”, )
et al.
, ))Defendants. ))
PLAINTIFFS’ REPLY TO SINCLAIR’S OCTOBER 25, 2010 LETTERRESPONDING TO THE COURT’S OCTOBER 20, 2010 ORDERFOR SPI TO RETAIN COUNSEL
Plaintiffs, Daniel Parisi (“Parisi”), Whitehouse.com Inc., Whitehouse Network LLC(“WNL”), and White House Communications Inc. (“WCI”) (collectively referred to as“plaintiffs”), hereby reply to the October 25, 2010 letter of defendant Lawrence Sinclair, whichwas written in response to the Court’s October 20, 2010 Order that defendant SinclairPublishing, Inc. (“SPI”) retain counsel by November 15 or show cause why SPI should not besanctioned, including by entry of a default judgment. (Dkt. No. 65). A copy of Mr. Sinclair’sletter is attached as Ex. 1.Sinclair’s letter states that he has attempted to retain counsel to act for SPI to no avail.He writes that neither he nor SPI have the financial ability to retain counsel. Mr. Sinclair statesthat he moved from Florida to Washington, D.C. to obtain counsel and was unsuccessful.Sinclair now resides in Tennessee. His letter does not set forth any reasonable prospect that SPIwill be able to engage counsel to represent it in this litigation by November 15, 2010 or at anytime thereafter.
Case 1:10-cv-00897-RJL Document 75 Filed 11/02/10 Page 1 of 3
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 As the Court’s Order set forth, a corporation can only file documents and appear in courtproceedings through licensed counsel. Plaintiffs respectfully request that if counsel for SPI hasnot entered an appearance here by November 15, the Court should sanction SPI, including bygranting plaintiffs’ motion for a default judgment against SPI.Granting SPI additional time would prejudice plaintiffs. SPI and Mr. Sinclair wereserved on June 7, 2010. (Dkt. Nos. 3-4). A default judgment can be enforced. SPI should not beprovided with additional time in which to potentially hide or dissipate any assets that it mightstill own. Moreover, a default as to SPI would not affect Mr. Sinclair’s ability to assert whateverpersonal defenses he might have to the claims against him.For the foregoing reasons, plaintiffs’ motion for sanctions against SPI, including default judgment, should be granted.Dated: November 2, 2010 Respectfully submitted, /s/ Richard J. OparilRichard J. Oparil (D.C. Bar No. 409723)PATTON BOGGS LLP2550 M Street, NWWashington, DC 20037(202) 457-6000(202) 457-6315 (fax)Kevin M. BellPATTON BOGGS LLP8484 Westpark DriveMcLean, VA 22102(703) 744-8000(703) 744-8001 (fax)Attorneys for Plaintiffs- 2 -
Case 1:10-cv-00897-RJL Document 75 Filed 11/02/10 Page 2 of 3
 
 
CERTIFICATE OF SERVICE
I hereby certify that on November 2, 2010, a copy of the foregoing was served on counselfor the parties that have appeared in the case by the Court’s ECF system and on the following byelectronic mail:Lawrence W. SinclairPO Box 9222Chattanooga, TN 37412218-269-2274larry@larrysinclair.org /s/ Richard J. OparilRichard J. Oparil (DC Bar No. 409723)
5129997
Case 1:10-cv-00897-RJL Document 75 Filed 11/02/10 Page 3 of 3

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