- 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. (
, 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