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Parisi v Sinclair 98-Declarations and Statemetns of Disuputed Material Facts

Parisi v Sinclair 98-Declarations and Statemetns of Disuputed Material Facts

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Published by Lewis Clark
Parisi v Sinclair : 98- # 1 Declaration of Daniel Parisi, # 2 Declaration of Richard J. Oparil,# 45 Statement of Disputed Material Facts 02/11/2011
Parisi v Sinclair : 98- # 1 Declaration of Daniel Parisi, # 2 Declaration of Richard J. Oparil,# 45 Statement of Disputed Material Facts 02/11/2011

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Published by: Lewis Clark on Feb 11, 2011
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et al.
, ))Plaintiffs, )v. ) Civil Action No. 10-0897-RJL)LAWRENCE W. SINCLAIR a/k/a “Larry Sinclair”,
et al.
, ))Defendants. ))
I, Daniel Parisi, declare under penalty of perjury that the following is true and correct.1. I have personal knowledge of the facts stated herein and if called upon to do so, Icould competently testify thereto.2. I make this declaration in opposition to the motion to dismiss or for summary judgment filed by defendant Lawrence Sinclair (“Sinclair”).3. I am the individual plaintiff in this case and the owner of Whitehouse.com Inc.and Whitehouse Network LLC (“WN”). I am the President of Whitehouse.com Inc. and WhiteHouse Communications Inc. (“WHI”) (collectively referred to as “plaintiffs”).4. My correspondence and emails with Sinclair all refer to myself as the President of Whitehouse.com Inc. All of my dealings with Sinclair were as an officer of Whitehouse.com.5. I am engaged in the business of owning and developing domain names andwebsites. (Dkt. No. 1 16). WCI owns the domain name whitehouse.com. Whitehouse.comInc. and WNL operate the whitehouse.com domain name and website. They have been and areengaged in efforts to develop that website into a profitable business venture. In 2008, effortswere underway to develop Whitehouse.com into a politically-oriented website. Plaintiffs hopedto follow the model of successful political sites such as huffingtonpost.com, which in December 
Case 1:10-cv-00897-RJL Document 98-1 Filed 02/11/11 Page 1 of 22
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 - 2 -2008raised $25 million in a single investment and a total valuation of almost $100 million,according to published reports. (
¶ 17). In 2009, as discussed below, WNL began efforts todevelop a “Whitehouse Network” television venture. (Ex. 1).
 6. On February 10, 2007, then Senator Barack Obama (“Obama”) announced that hewas running for President of the United States. On January 3, 2008 Obama won the IowaDemocratic caucus. One of Obama’s campaign advisers and consultants was David Axelrod(“Axelrod”). Axelrod served as Senior Advisor to the President until earlier this year.7. Approximately two weeks later, on January 18, 2008, Sinclair posted a YouTubevideo in which he made wild allegations regarding the purchase, sale and use of drugs and sexualactivity by and between Sinclair and Obama on November 6 and 7, 1999. (Ex. 42). WhileSinclair’s underlying story gave rise to the events that followed involving the plaintiffs, the truthor falsity of Sinclair’s statement about Obama is not at issue here; there is no allegation that plaintiffs were defamed or disparaged as a result of that story.8. Sinclair is a self-admitted drug user and trafficker. (Book at 25-30, 33).
Sinclair has pled guilty and spent years in prison for forgery, theft, and writing bad checks. (Book at 19-22, 24-28; Ex. 2). Moreover, I understand that there is an outstanding felony warrant for “LarryWayne Sinclair” in Colorado. (Exs. 3-6). While in prison, Sinclair was cited for numerousinfractions. (
See, e.g.
, Exs. 7-8). Sinclair has also been involved in bizarre conduct, such ascreating bullet-ridden photographs of Obama and his wife (Ex. 9). Further, while claiming to bedisabled, he has publicized photographs showing him engaged in a series of strenuous activities(Ex. 10). Last year, Sinclair allegedly tried to commit suicide. (Ex. 43). Further, in a July 16,
True and correct copies of the exhibits referenced are being filed separately.
It is my understanding that Sinclair’s book (paperback version) has been filed with theCourt and may be located at Dkt. No. 61 Ex. 1.
Case 1:10-cv-00897-RJL Document 98-1 Filed 02/11/11 Page 2 of 22
 - 3 -2008 interview and at the June 18, 2008 National Press Club event, Sinclair said he has a“terminal” brain tumor. (Exs. 11-12, 43).9. In February 2008, after I became aware of Sinclair’s allegations and as part of itseffort to develop a political website, I contacted Sinclair. Whitehouse.com offered to paySinclair $10,000 to take polygraph examinations and to pay him $100,000 if the examinationsshowed Sinclair was telling the truth. (Dkt. No. 1 ¶ 23; Dkt. No. 94 Exs. C-D). Whitehouse.commade the offer to promote the site and to further its goal of becoming a first-class political venue.10. As a precondition to Sinclair agreeing to be subject to a polygraph test, I made itclear to him that I had no ties to Barack Obama or his campaign. In fact, I said so publicly. Thefollowing was posted on Whitehouse.com and sent to Sinclair by email prior to test:We are not affiliated in any way with any of the candidates or anyof the parties. I have never met or communicated with DavidAxelrod or Barack Obama. Obviously since I never met either of them I do not have friendship [sic] with either of them.(Ex. 13 at 1, February 16, 2008 email). That statement was true when it was made and it remainstrue to this day.11. To be clear, plaintiffs were not contacted by Barack Obama, his campaign, DavidAxelrod or anyone associated with him pertaining in any way to Sinclair. I was not asked or hired to rig a polygraph examination of Sinclair. I have never had any meeting, conversation or other communication, written or oral, with Obama, his campaign, Axelrod or anyone associatedwith him. I have never been paid any money by Obama, his campaign, David Axelrod or anyoneassociated with him. The allegations in Sinclair’s book pertaining to plaintiffs’ involvement withthe polygraph to benefit Obama and his campaign are unequivocally false. We hiredindependent experts who provided us with results.
Case 1:10-cv-00897-RJL Document 98-1 Filed 02/11/11 Page 3 of 22

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