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02/07

AD 440 (Rev, 17.(09; DC 03110) Summons in R Civil AeW(ln

UNITED STATES DISTRICT COURT

for the

District of Columbia

DANIEL PARISI, at al.,

v.

) ) ) ) ) ) )

Civil Action No. 1 ;10-cv-OB97"RJL

Pla/miff

LAWRENCE W, SINCLAIR, at al.,

Defelldont

SUMMONS IN A CIVIL ACTION

To: (Defendant's namt:! and address}

LAWRENCE W. SINCLAIR slkla "Lany Sinclair" 9 Spring Drive

Port Orange, FL 32129

A lawsuit has been filed against you,

Witbir@days after service of this summons on you (not counting tho day YOlI received it) - or-6&days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P- 12 (a)(2) or (3) - you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure- The answer or motion must be served on the plaintiff or pla.intiff's attorney, whose name and address are:

~ie~tird 0 p~' if

Po-1ibt1 150fJfP .') 550 W1 ~ ('hi W""r/l1"'rr4"~ D.c. {).OO{l7

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.

You also must file your answer or motion with the court.

ANGELA D. CAESAR, CLERK OF COURT

Date: t,J (~Lto. 7(

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PAGE 02/25

Filed 05/28/10 Page 1 of 2

r.t .' ' r""\. •

CIVIL COVER SH EET

I (ll) PLAI,"TlFFS

1----------------------------------"-----------

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lNETWORK LLC, and WHITE HOUSE COMMUNICATIONS~rd

__ M •• •• • MY~ ~ I

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9a~,?_ 1: 1 O-cv-00897 -RJL Document 1 Filed 05(28f10 Page 1 of 18

. CLERK

UNITED STATES DISTRICT COURT, US DISTRICT &.

FOR THE DISTIUCT ()F COLUMBIADANHRUPTCY COURTS

DANIEL PARISI, 1465 Rou te 23 Wayne, NJ 07470,

WHrrEHOUSE.COM INC" 1465 Route 23

Wayne, NJ 07470,

WHITEHOUSE NETWORK LLC, 1465 Route 23

Wayne, NJ 07470, and

WHITE HOUSE COMMUNICATIONS INC., PTY 4684, BOX 0843-03073

Balboa, Anoon 0000 Panama,

Plaintiffs,

v,

LAWRENCE W. SINCLAIR a/k/a "Larry Sinclair", 9 Spring Drive

Port Orange, FL 32129,

ffiFFREY RENSE,

1680 Ashland Street Ashlan;' OR 97520,

BAR~S & NOBLE, INC., 122 Fifth Avenue

New York, NY 10011,

BARNESANDNOBLB.COM LLC, 76 Ninth Avenue

New York, NY 10011,

AMAZON. COM, INC., 410 Terry Avenue Seattle, WA 98109,

\

) ) ) ) ) ) ) ) )

)

)

)

)

) Civil Action No. )

) COMPLAINT AND JURY ) DEMAND

~ "1: ~h

Case: 1: 1 O~cv-00897 • ~ ~

Assigned To: Leon, RIchard J. .~,._. '141('

Assign. Date: 5/28/201~ VA

Description: PI/Malpractice -e ,.

.:. C"E:IV~D

.. \ • -.j l: ,I

FILED

MAY 28 2010

.Plerk, u.s. Dllltrlct & Bankruptpy Oallrt9 for thll Dlstrll:t ot Glliumbli

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

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BOOKS-A"MlLLION~ INC., 402 Industrial Lane Birminghmn, AL 35211, and

Defendants.

) ) ) ) ) )

) ) )

--_.-_._ •..... _--_ ----)

STNCLAIR PUBLISHING, INC., 9 Spring Drive

PorL Orange, FL 32129,

Plalntiffs, Daniel Parisi, Whitehouse.corn Inc., Whitehouse Network LLC, and While

House Communications Inc. (collectively referred to as "plaintiffs"), by counsel, files this

complaint against defendants, Lawrence W. Sinclair, Jeffrey Rense, Sinclair Publishing, lnc.,

Barnes & Noble, lnc., Barnesandnoble.corn LLC, Amazon.com, Inc., and Books-A-Million, Inc.

(collectively referred to as "defendants"), and alleges as follows:

PARTIES

1. Plai ntiff, Daniel Parisi (,'Parisi"), is a citizen of New Jersey.

2. Plaintiff, Whitehouse.corn Inc., is ~I New Jersey corporation with its principal

place of business in Wayne, New Jersey.

3. Plaintiff, Whitehouse Network LLC ("WN"), is a New Jersey corporation with its

principal place of business in Wayne) New Jersey.

4. Plaintiff, White House Communications Inc. ("WHCl"), is a Panama corporation

with its principal place of business in Panama.

5. Defendant, Lawrence W. Sinclair a/k/a "Larry Sinclair" CSinclair"L is a citizen

of Florida.

6. Defendant, Jeffrey Rcnse ("Rellse"); I;; (I citizen of Oregon.

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7. Defendant, Bartles & Noble, [nco is a Delaware corporation, with its principal

place of business in New York, New York. B&N is registered to do business in the District of Columbia and has one or more retail stores in (his District.

S. Defendant, Barnesandnoble.com L..LC, is a Delaware limited liability corporation,

with its principal place of business in New York, New York.

9. Barnes & Noble, Inc- and Barnesandnoble.com LLC are hereinafter referred to as

'~B&N" .

.10. Defendant, Amazon.corn, Inc. ("Amazon"), is a Delaware corporation, with its

principal place of business in Seattle, Washington.

1 L Defendant, Books-A-Million. Inc. ("BAM"), is <I Delaware corporation, with its

principal place of business in Birmingham, Alabama. BAM is registered to do business in the District of Columbia and has one or more retail stores in this District.

12. Defendant, Sinclair Publishing, Inc, ("SPI"), is a Florida corporation, with its

principal place of business in Port Orange, Florida.

JURlSDICTION AND VENUE

l3_ Subject matter jurisdiction exists pursuant to 28 USc. § 1332 in that pJaintirf.~

nnd defendants are citizens of different states and the matter in dispute exceeds the sum or value of $75,000, exclusive of interests and costs.

14. Personal jurisdiction over the defendants is proper in this District. Defendants

have continuous and systemic contacts with the District of Columbia and have been and are conducting and doing business in this District. Personal jurisdiction also exists pursuant to D.C. Code § J 3-423.

15. Venue exists in this District pursuant to 28 U.S.c. ~§ 1391(c).

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BACKGROUND

] o. Parisi is engaged in the business of owing and developing domain names and

websites.

17. WHeT owns the domain name) Whitehouse.corn, Whitehouse.com Inc. and WN

operate the Whitehouse.com domain name and website. They have been and arc engaged in efforts to develop that website into a profitable business venture. In 2008, efforts were underway to develop Whitehouse.com into a politically-oriented website. Plaintiffs hoped to follow the J110del of successful political sites such as huffingtonpost.col1l, which in December 20(1) raised $~5 million in II single investment and a total valuation of almost SH)O mill inn, according 10 published reports.

18, Sinclair is a self-confessed convicted felon and former drug user and trafficker.

He has used multiple aliases.

He operates self-promotional websitcs, including

Iarrysinclair.com, larrysinclair.org and larrysinclairforcongress.com.

19. On February 10,2007. then Senator Burack Obama ("Obama") announced that he

WHs running for President of the United Stares.

20. On January 3, 2008 Obarna won the Iowa Democratic caucus.

21. On or about January 18,2008, Sinclair posted a You'Tube video in which he made wild allegations regarding the purchase, sale and usc of drugs and sexual activity by and between Sinclair and Obarna on November 6 lind 7, 1999.

22. Sinclair hoped and expected to profit and personally benefit from his drug and I'lCX

allegations against the Presidential candidate.

23. In or about February 2008, after he became aware of Sinclair's allegations and as

part of its effort to develop a polhical website, Parisi contacted Sinclair. He offered to pay Sinclair $10,000 [0 take polygraph examinations and to pay him $100,000 if the examinations

·4·

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showed Sinclair was telling the truth. Whitehouse.ccm, Inc. later paid Sinclair $20,000 by check as pari of a modified agreement.

24. On or about February 22, 2008, polygraph examinations of Sinclair were

administered by Edward Gelb ("Gelb")} a certified polygraph examiner and past President of the American Polygraph Association and well known examiner, at his office in Los Angeles Cal ifornia. Sinclair was involved with and agreed to the selection of Gclb.

25. In Los Angles} Sinclair was interviewed fOI; a few hours, which was videotaped.

2(). Gelb administered two polygraph examinations, one pertaining to the drug

allegation and the other on the sex allegation. Both examinations were videotaped. According to Gelbs report, Sinclair indicated deception on both examinations, which Was corroborated by a second examiner in his office. These results Were further corroborated on 01' about February 26, 200~, by a third party polygraph examiner, Gordon Barland.

27. Whitehouse.com provided Sinclair with a copy of the polygraph examination

results and posted the results online.

2H. Sinclair repeatedly represented to Parisi that he was going to identify and put

Parisi and Whitehouse.corn in touch with an alleged limousine driver, who allegedly was with Sinclair and Ob~IlJl~J when the alleged drug and sex acts occurred in "1999_ Despite his assurances, Sinclair never revealed the identity of the alleged driver to Parisi or Whitehouse.corn or put them in contact with him.

29. On Of about March 13, 2008, Sinclair filed a complaint in this Court against four

bloggers for defamation and "reckless misrepresentation", in an action captioned Sinclair v. r(lbeS()ckn~dD, et at, Civil Action No. OB~434~JDB. The case was dismissed on February 10, 2009.

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30. On or about June 18, 2008, Sinclair held a press conference in the District of

Columbia to repeat his drug and Sex allegations and alleged that a church choir master, Donald

Young, was murdered On December 23, 2007 and suggested that Obama or his campaign was

somehow involved in the murder. However, Sinclair did not mention the Young allegation

during his hours long interview with Gelb or during the polygraph examinations.

3 L In June 2009, Sinclair self-published through SPI, a copyrighted book entitled

Burack Obama & Larry Sinclair: Cocaine, Sex, Lies & Murder? (referred to as "the book" or

"Sinclair's book"), which is incorporated herein by reference.

32. Sirtclair's book repeated his story about drugs, sexual activity and Donald

Young's murder, The book also contains vicious attacks on Parisi and Whitehouse.corn.

Sinclair's book is replete with false, defamatory and derogatory statements regarding Perlsl and

the website, including without limitation, the following:

In fact, at 12:48 a.m. on February 25. 2008 (the day before Bar land's review was even conducted), I received l:I telephone lip from 207·252-2796 and 207-899-0872, advising me that the polygraph was rigged and was arranged by Dan Parisi and Oburna Campaign advisor David Axelrod. The man giving me; the tip stated that, "Axelrod and the Obarna campaign had agreed to pay Dan Parisi of Whitehouse.corn, $750,000 to arrange a rigged polygraph. Parisi and Axelrod were in a heated argument because the Obama camp wanted Parisi 10 publish thai you had failed the polygraph faster than what Parisi had said. Parisi was refusing to publish anything further on the polygraph until he was paid the other half of the three-quarters of <I million dollars agreed on."

When I received this information, I contacted Dan Parisi and informed him of what was stated, and 1 asked Parisi to confirm or deny the allegations, Instead of Parisi denying or confirming the allegations that he refused to respond to the statements and then posted a statement on Whitehouse.corn that he had been threatened repeatedly by "Sinclair's supporters and that Whitehouse.com would not publish anything further regarding Larry Sinclair." III addition, Parisi Irnmcdlatelv shut down Whitebouse.corn, completely scrubbed the site of all posts and comments 011 the Larry Sinclair/Burack Obarna story, and revamped the format of

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the website requiring individuals to register with Whitehouse.com before being able to comment. rt was at that lime, Whitehouse.corn became the staunchest promoters of Barack Obarna, while slamming Hillary Clinton non-stop, I also had asked Parisi to respond: r forwarded the information (0 Chicago Tribune reporter John Crewdson and asked him to look into who the tipster was. Crewdson actually spoke to the tipster and was told the same thing. In addition, the tipster stated that I should look very carefully at the FEe campaign finance reports for the period from January 1 through March 31, 2008 for the payments to Parisi. The tipster also advised me that Parisi had many different holding companies, and the Obama campaign would nOI have made a single individual payment.

Immediately after confronting Whitehouse.corn's Dan Parisi about the allegations that he arranged a rigged polygraph exam, he issued a stop payment of the check issued 10 me for the polygraph exam. You see, Parisi had made a deal with David Axelrod and the Obarna campaign. All of this occurred on the very day that J published emails to Mr. Parisi asking for his response to the claims made in an anonymous telephone tip.

The information Edward Gelh hac! obtained from the extensive pre-polygraph interview suddenly was being posted on the internet at Democraticllnderground.corn, MyBarackObama.com, Huffingtonf'ost.com, and others. Only the information had been distorted and edited. In fact, it was after the rigged "polygraph/fishing expedition" arranged by Dan Parisi in ~I deal with advisor David Axelrod, rha: direct attacks began on the internet and by phone against my father's last wife, my nieces and nephews, my mother and my brothers and sisters,

Finally, in February 2008 I was told anonymously that Dan Parisi of Whitehouse.corn received $750,000 from the Obarna campaign through AKR Media to organize £111 effort to publicly discredit me; When 1 confronted Parisi with this allegation, he did 1101 deny it but instead withdrew the second exonerating polygraph report of Dr. Gordon Harland. He also failed to post the video of my polygraph as he and Whitehouse.corn promised they would do. He even removed posts from their web site altogether, claiming that they had "bad enough of the attacks by Sinclair's supporters and Sinclair himself."

[T[he polygraph exam was announced by the internet pornography fraud Dan Parisi on Whitehouse.corn ....

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33. Rcnse, who operates a website (rense.com) and has a nationwide radio show.

wrote a foreword to Sinclair's book. The foreword contains false, defamatory and derogatory

statements regarding the plaintiffs, including without Limitation .. the following:

As soon as Larry Sinclair began to make 'noise' on the nel and 011 my program, the Obama power base immediately organized a clearly high-level, multi-faceted assault. on him featuring bizarre events J ike top advisor David Axelrod allegedly hiring internet porn merchant, Don Parisi, of the otherwise commercial porn site, Whitehouse.com, to set LIp an embarrassingly rigged polygraph 'examination' of Larry which he graciously made himself available for. The test, as you will read, was administered by the strange and rather shady Edward 1. Gelb, polygraph examiner for hire, who among other things represented himself as having a Ph.D. when he apparently docs not.

34, Sinclair, B&N, Amazon, BAM, and SPI offer for sale and sell Sinclair's book

throughout the United Stales, including in the District of Columbia, in stores and/or through

internet order and delivery.

35. In its "Product Description" of Sinclair's book; Amazon makes false and

defamatory statements regarding plaintiffs, including without limitation, that: "You'll read how

the Obarna campaign used internet porn king Dan Parisi and Ph.D. fraud Edward l. Gelb to

conduct" a rigged polygraph exam in an attempt to make the Sinclair story go away. , .. This is a

staggeringly true story of how the sitting U.S. President with the help of the Mainstream Media.

the Chicago Police Department, the FBI, the Delaware Attorney General and others got away

with murder and more. , .

"

(h ttpt] /Wl1>·Y.', a mazon. com/ Ba rack -Obama- Larry <Sincla i i>

Cocaille/dp/0578013878/ref=sr j _1 ?ie=UTF8&s=ho()ks&.qid=J273680146&sr=1-]~ W!C! also

"From the Publisher" description).

36. Amazon also offers for sale and sells a Kindle book reader edition of Sinclair's

book. Amazon's "Product Description" for the Kindle edition falsely represents that the book is

".100% true." II goes on to falsely stare that: "You'll read how the Obama campaign used

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internet porn king Dan Parisi and Ph,D, fraud Edward L Gelb to conduct H rigged polygraph exam in an attempt to make the Sinclair story go IIWHY .. ,. This is a staggeringly irue story of how the sitting U.s, President with the help of the Mainstream Media, the Chicago Police Department, the FBI, the Delaware Attorney General and others got away with murder and more .... " Pursuant to ~ 5.1.3 of its Digital Publication Distribution Agreement with authors. including Sinclair and/or SPI, Amazon is "entitled to determine what content we accept in and distribute through the Program in our sole discretion." Pursuant to 'II 5.4.1, Amazon pays the author a royalty of 35% of the applicable list. price for such digital book, net of certain

expenses.

37. Amazon also sells and offers to sell similar books in other countries, including the

United Kingdom (through www.amazon.co.uk), Canada (through www.amllZOI!.(.'o.ca), Japan (through www.amazon.co.jps, France (through www.unuizon.co.jrs, and Germany (through www.amazon.co.de ).

3H. BAM makes false and defamatory statements regarding plaintiffs, including

without limitation, that: "You'll read how the Obama campaign used internet porn king Dun Parisi and Ph.D. fraud Edward I, Gelb to conduct a rigged polygraph exam in an attempt to make the Sinclair story go away.'; (hctp:/IH.'Ww.booksamillion..c()m/product/97R()578013~79?id=

4735050662228#).

31), B&N promoted the Sinclair book by publishing on its website a product

description representing thai "[yjou'Il read how the Obama campaign used internet porn king Dan Parisi and Ph,D. fraud Edward I. Gelb to conduct a rigged polygraph exam in an attempt LO make the Si nclair story go away." This affirmative act of publication is more (han mere distribut ion.

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Case 1: 1 O~cv-008g7 -RJL Document 1 Filed 05/28/10 Page 10 of 18

4(1. 13&N has submission guidelines f-or the review and acceptance of new books. In

pertinent parr, the guidelines state that:

If you would like your title to be considered by our buyers, please submit a finished copy (no manuscripts please) of the book along with marketing and promotion plans, trade reviews, and a note describing how the book meets the competition (what makes il unique) to: [B&Nl .... The information must include the ISBN and the suggested" retail price. The review process takes about six weeks. . .. All books will be considered for store placement based on subject matter and salability, provided the supplier submits a completed and signed Vendor Compliance Certification Form.

(Available ar http://www.bamesandnobleinC-comlforYliblishers/How _to _Sllbmitjl_Book/How _

to_SlIhmit_a_Bookhlml). In addition, B&N also has guidelines providing that:

Why should Barnes & Noble place your title on its shelves?

Tell us what makes your book unique or special. What is your marketing plan? Send us your publicity and promotional plans, along with any reviews or articles that may have been written about your book(s).

(hrtp:I/l,vww.barnesmzdnobleinc:.contlfor _Qltthors/how _to_work_with_lmlhow_to_work_with_lm,

httnl#ishll). Thus, had B&N following its own procedures for accepting books, it was or should

have been aware of the contents of Sinclair's book before it was accepted, offered for sale, and

sold.

41- The above described Sinclair's book and promotional statements (referred to as

"the defamatory statements") referred to Parisi and Whitehouse.corn by name, were made of and

concerning him and Whitehnuse.corn, and were so understood by those reading the defamatory

statements.

42. Third-parties have repeated and republished the defamatory statements orally and

ill writing.

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43. Since publication of the defamatory statements, defendants and others may have

made other untrue statements of fact about the plaintiffs orally Or in writing, including in postings on the internet, of which plaintiffs are not currently aware.

44. The defamatory statements are false and misleading as they pertain to Parisi and

Whitehouse.corn. The undisputable true facts are that, inter alia:

a, Plaintiffs have never discussed Sinclair or his allegations with David Axelrod or the Obarna campaign, or anyone acting on their behalf.

b.Plainliffs have never conspired. criminally or otherwise, with Obama, the Obama campaign or Axelrod or anyone acting on their behalf.

c. Plaintiff.') have never entered into an agreement, contract, or understanding with David Axelrod, the Obarna campaign, or anyone acting On their behalf.

d. Plaintiffs never agreed to accept or be paid motley or other benefit by David Axelrod, the Obama campaign, or anyone acting on their behalf. for any purpose.

e. Plaintiffs have never "made a deal with David Axelrod and {he Obuma campaign' for any purpose, including without limitation, to arrange a rigged polygraph examination of Sinclair.

I, Plaintiffs did not "rig" Sinclairs polygraph examinations.

g. Plaintiffs have never helped anyone to gel away with murder.

h. Parisi is not and has never been a pornographer. He has not produced, created or made any pornographic material.

i. During the relevant time period, Whitehouse.com did not contain pornographic material.

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Case 1:1 O-cv~00897 -RJL Document 1 Filed 05/28/10 Page 12 of 18

45. The defamatory statements were made and published by defendants with

knowledge of their falsity or with reckless disregard for their truth. The defamatory statements

were made without any evidence, direct or circumstantial, that they were true when made.

Sinclair's book. and the statements published by other defendants did not contain a scintilla of

factual support for their wildly false and reckless untrue statements.

46. The defendants have benefited and profited from Sinclair's book and the other

defamatory statements.

47. Prior to the filing of this action, defendants knew or had reason to know of the

defamatory statements.

4S. As a direct and proximate result of the defamatory statements of the defendants.

the Whitehouse.corn website was shut down in 2008. Whitehouse.corn had hoped to sell the site

to political/news entities, particularly during the historic 2008 presidential election year, but was

unable to do so in light of the taint of Sinclair's defamation, Plaintiffs have actual and special

damages in the amount of at least $30,000,000.

49. Prior to the filing of this action. B&N, Amazon, BAM and SPl were made aware

of the alleged defamatory statements, but continue to publish, offer for sale and/or sell Sinclair's

book.

50. In fact, on May 28, 2010, Sinclair, responding to a case and desist letter on l)ci1alf

of SPI, l<:.in plaintilfs' counsel the following voice message:

Mr. Oparil, Lawrence Sinclair. 1 received a FedEx letter from you dated M~IY 27, 2010 addressed 10 Sinclair Publishing Inc. requesting that we cease and desist from publishing} offering for sale and selling a book titled "Barack Obama and LaITY Sinclair:

Cocaine, Sex, Lies and Murder?" which you claim r.h'lt you represent Daniel Parisi and Dan Parisi claims that it's defamatory and disparaging.

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Case 1:10-cv-00897 ... RJL Document 1 Filed 05/28/10 Page 13 of 18

Here's my answer to your letter. HELL, NO. We will no! cease and desist from publishing, offering for sale and selling the book, and I welcome Mr. Parisi to try 1.0 take legal action. Contracts that were drawn up between Mr. Parisi and myself and, uh -- well, YDu'lI talk to your client. The answer is HELL, NO.

51. On May 28, 201O~ Sinclair sent a letter to plaintiffs; counsel confirming SPI

would not cease and desist from publishing, offering for sale, and selling the book.

52. the documents referred to in this complaint are incorporated herein by reference.

53, Defendants are joint tortfeasors and are jointly and severally Hable for the causes

of actiun alleged herein.

COUNT I (Libel Per Se I Llbel)

54. The foregoing allegations of the complaint are incorporated by reference.

55. In or "bout June 2009. defendants published the defamatory statements III

Sinclair's book and promotional statements,

56. The defamatory statements referred to Parisi by name, were made of and

concerning him, and were so understood by those reading the defamatory statements,

57. The defamatory statements are false and misleading as they pertain to Parisi.

5~. The defamatory statements were made and published by defendants with

knowledge of their falsity or with reckless disregard for their truth.

59. The defamatory statements were so excessive. intemperate, unreasonable and

abusive as 1.0 preclude any conclusion other than the defendants were actuated by actual malice.

60. The defamatory statements are libelous on their face, in that they expose Parisi to

hatred, contempt, ridicule and obloquy because they published statements that. inter alia, Paris;

is a pornographer, criminally conspired with Axelrod and the Obarna campaign, rigged

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Case 1:10-cv-00897-RJL Document 1 Filed 05/28/10 Page 14 of 18

polygraph examination results, received improper funds from the Obarna campaign or Axelrod,

and assisted Obama to get away with murder.

61. The defamatory statements have been available to, read or seen by members of

the public, including without limitation, citizens of the District of Columbia, The Sinclair book

has been offered for sale and sold to the public, including without limitation, in the District of

Columbia.

62. The defamatory statements were not privileged and Were published by the

defendants with malice, hatred, contempt and ill will toward Parisi and with tile desire LO cause

him economic injury, including lost business and opportunities.

6), As a direct and proximate result of the foregoing, Parisi has suffered loss of

reputation, shame, obloquy, mortification, as well as lost business and opportunities, in an

amount to be proven HI trial in excess of $30,000,000.

(14, Because of defendants' malice in publishing the defamatory statements. Parisi is

entitled to an award of reasonable punitive damages in excess of treble the amount of

compensatory damages.

COUNT II

(false Light Invasion/Misapprop r iation of Prlvacy)

65. The foregoing allegations of the complaint are incorporated by reference.

66. The published false defamatory statements concerning Parisi place him in a false

light which would be highly offensive to a reasonable person.

67. Defendants had knowledge of Or acted in reckless disregard as to the falsity of the

publicized matter and the false light in which Parisi would be placed.

68. Defendants have misappropriated Parisis right to privacy.

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Case 1: 1 O-cv-00897 -RJL Document 1 Filed 05/28/10 Page 15 of 18

69. As a direct and proximate result. of the foregoing, Parisi has suffered damages in

an amount to be proven at trial in excess of $30,000,000.

COUNT III (Business Disparagement)

70. The foregoing allegations of this complaint are incorporated by reference.

71. Defendants, and each of them, knowingly and intentionally published multiple

defamatory written statements of fact to third persons, including, inter aliu, thaI in 200H-09,

Whitehouse.corn contained pornography and engaged in unlawful and fraudulent conduct.

72. At the time they made the defamatory statements, defendants, and each of them,

had actual knowledge of the falsify of [heir statements and had actual serious doubts a~ 10 the

truth of their statements, yet made the statements with knowledge of their falsity and in reckless

disregard of their truth or falsity. Nevertheless, defendants made and disseminated their false

statements to multiple third parties - including the general public through dissemination via the

Internet and the press - in an effort to impugn the reputation of Whitehouse.corn and irs owners

and management,

73. The false and defamatory statements made by defendants were made with actual

malice, and are therefore unprivileged.

74. As a direct and proximate result of the foregoing, Whitehouse.com incurred

damages, including special damages.

75. As a direct and proximate result of defendants' wrongful conduct,

Whitehouse.com is entitled to recover damages, in an amount to be determined at. trial in excess

of $30,000,000.

76. Further, defendants' wrongful conduct and business disparagement. W(lS made

with the intent LO vex, injure and harm Whitehouse.corn so as to constitute oppression, fraud find

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Case 1:10~cv;-00897-RJL Document 1 Filed OS/28/10 Page 16 of 18

malice justifying an award of exemplary and punitive damages in lUI amount to be determined at

trial.

CQUNTIV

(Tortious Interference with Economic Advantage)

77. The foregoing allegations of this complaint are incorporated by reference.

7R. At aJJ relevant time, Whitehouse.corn had a valid business relationship Of

expectancy with respect to the website.

79. Defendants had knowledge of such relationship or expectancy.

80. Defendants intentionally interfered with the business relationship.

8 L As a direct and proximate result of de fendants' wrongful conduct,

Whitehouse.corn is entitled to recover damages, in an amount to be determined at lri(ll in excess

of $30,000,000.

82. Further, defendants' tortious interference was made with the intent to vex, injure

and harm Whitehouse.corn so as to constitute oppression, fraud and malice justifying an award of

exemplary and punitive damages xu an amount to be determined at trial.

COUNTY (Civil Conspiracy)

K3. The foregoing allegations of this complaint arc incorporated by reference.

H4. The defendants have combined and conspired for an unlawful purpose,

i.e., defamation, business disparagement and tortious tnterferencc with economic advuntage, with

the intent to injure plaintiffs.

~5, Defendants have done one or more overt acts in furtherance of their conspiracy.

86. As a direct and proximate result of the civil conspiracy, plaintiffs have been

injured by the defendants in an amount to be proven at trial, in eXC(,!R!; of $30,00{),000.

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Case 1:10-cv-00897-RJL Document 1 Flied 05/28/10 Page 17 of 18

DE.MANI) FOR RELIEF

WHEREFORE, plaintiffs request this COUt'l to enter judgment in their favor and against

defendants, awarding them the following relief:

a. compensatory and consequential damages from defendants in an amount to be

proven at trial but in excess of $30,000,000;

b. punitive damages to the maximum amount permitted by law;

c. an accountlng and construction trust as to defendants' proceeds from the

defamatory publications;

d. attorneys' fees and expenses HS allowed by law;

c. costs; and

f such other relief as the Court deems just and proper.

.JURY DEMAND

Plaintiffs hereby demand trial by jury as to all issues in this action triable of right by a

jury.

Dated: May 28, 2010

. Bar No. 409723) ,. p

Attorneys for Plaintiffs

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Case 1:10~cv-00897-RJL Document 1 Filed 05/28/10 Page 18 of 18

(y COIlr7Se/:

Kevin M. Bell (Bar No. 14382) PATTON BOGGS LLP

8484 Wcstpark Drive

Mcl.ean, V A 22102

(703) 744-8000

(703) 744-8001 (fax)

509'1034

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Case 1.: 1 O-cv-00897 -RJL Document 2 Filed OS/28/10 Page 1 of 1

YS

CLERK

_ US DISTRICT &.

JANKRU?TCy COURTS

United States DiRtrJ''t~O'D'';: 23 For the District 0f(~~~B'

) ) )

)

) ) ) ) ) )

CQ·386-i;lnline 10/03

DANIEL PARISI, at aI.,

jFILED

MAY 28 2010

Clerk, 'U.s, Dlstr!ct & Bank', " Courts 'Dr th&_ Dlstrlct Df Call

I,

Case: 1:10-dv-e0897

Assigned To : Leon, Richard i Assign. Date; 5/28/2010 Description: PllMalpractlce

'.

LAWRENCE W. SINCLAIR a/k/a "Larry SinclaIr", et at,

I, Ihe Ulld~r~igued. counsel of record for pfaihtiffs ~~ttify thnt to the best of my knowledge lind

Whltehouse,com Inc" Whitehouse Network,

belief. the follQwiu!1 ate patent companies, subsidilU'iea (If Ilffililltes of LLC, and White House Communications Inc. wllioh have

any olllslnnding securities In the .h!!.nd~ of'the public,

None

409723

/

Th eae representations are made in order tba.t judges of this court m

BAR IDENTIFlCA nON NO.

PATION BOGGS LLP, 2550 M Straet, NW

Address _-

Washington, OC 20037

City State:

(202) 457-6000

Zip Code

Phone Nwnbcr

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UNITED STATES D1STRICT AND BANKRUPTCY COURTS FOR THE DISTRICT OF COLUMBIA

ANGELA D. CAESAR Clerk a/Court.

NOTICE OF RIGHT TO CONSENT TO TRIAL BEFORE A UNITED STATES MAGISTRATE JUDGE

The substantial criminal caseload in this Court and the requirements of the criminal Speedy Trial Act frequently result in the delay in the trial of civil cases. Aware of the hardship and expense to the parties, counsel, and witnesses caused by the delays which are beyond the control of the Court, this notice is to advise you of your right to trial of your case by a United States Magistrate Judge. By statute, 28 USC §636(c), Fed.R.eiv.P. 73 and Local Civil Rule 73.1, the parties, by consent, can try their case by means of a jury trial or bench trial before a United States Magistrate Judge. Appeals from judgments and final orders are taken directly to the United States Court of Appeals for the District of Columbia Circuit, in the same manner as an appeal from a judgment of a District Judge. in a civil case.

WHAT IS THE PROCEDURE?

One of the matters you are required to discuss at the meet-and-confer conference mandated by Local Civil Rule 16.3 is whether the case should be assigned to a United States Magistrate Judge fur all purposes, including trial

Ail parties must consent before the case is assigned to a Magistrate Judge for trial. You may consent at any time prior to trial. If you expressly decline to consent or simply fail to consent early in the case, you are not foreclosed from consenting later in the case. However, a prompt election to proceed before a Magistrate Judge is encouraged because it Will facilitate a more orderly scheduling of the case.

Counsel for the plaintiffhas been furnished a copy of the "Consent to Proceed Before a. United States Magistrate Judge for all Purposes" fonn. If and when the form is executed, your response should be made to the Clerk of the United States District Court only.

WHAT IS THE ADVANTAGE?

The case will be resolved sooner and less expensively. The earlier the parties consent to assigning the case to a Magistrate Judge the earlier a finn and certain trial date can be established, even if the case is to be tried to a jury.

Upon the filing oftbe consent form and with the approval of the District Judge, the case will be assigned to all purposes to a Magistrate Judge.

n:\JIorms\'Notice of Right to Consent to Trial CO·942A 021910 Rev. 02110

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

INITIAL ELECTRONIC CASE FILING ORDER

Subsequent filings in this case must be made electronically using the Court's Electronic Case Filing System (ECF) pursuant to Local Civil Rule 5.4.

o.RDERED that counsel shall:

• Submit in paper, the original and copy of the complaint/notice ofremoval/petition for habeas corpus and any accompanying papers (not in.cluding summons and ch,n cover sheets). Additionally, litigants are hereby required to provide those filings in PDF format on a floppy disk or CD-Rom compact disk, The disk should be clearly labeled with the case number (if known) and the name of the parties. If'unable to deliver the filing on a disk at the time of the new case filing, counsel should e-mail the initiating document and accompanying papers to dcd cmecf@dcd.usoourts.gov by the close of business the day the new case was filed. Failure to supply electronic copies of the new case in a timely manner, will result in the attorney' s name being added to the attorney non-compliant list and shared with the Court's ECF Judge's Committee. Regardless of what option counsel chooses, the complaint/notice of removal/petition for writ of habeas corpus and accompanying papers must come to the Court as PDF documents. Each exhibit to the new case shall be in a separate PDF file, Emlure to submit POI versions the initiating doc:w;n,ents will delay the opeping of the case inECF,

• Register, if not previously registered, to become an electronic filer by completing and returning the enclosed ECF Registration form found on the Court's Website at (www.dcd.uscourts.gQv), The login and password are case specific and can be used for all cases.

• All subsequent filings must be made electronically.

• Have a PACER (Public Access to Court Electronic Records) account, in order to view dockets and documents. Call 800-676 ... 6856 or visit www.pacer.psc.uscourts.goy for additional information.

• Schedule a training class at the Courthouse by going to the Court's ECF Internet Website (www. dcd.uscourts.gov/ecf.html), Also, filing instructions and an interactive tutorial can be found at this Internet Website.

lEON,J. RJl

UNITED STATES DISTRICT JUDGE

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6 fHIi' :4 &5'9

g: b·-ad

=H&Pi 4M119'

a H

XII';

United States District Court Fer The District of Columbia

.ELECTRONIC CASE .FILES ATTORNEy/PARTICIPANT REGISTRATION FORM

LlVESYSTEM

This form shall be used to register for an account on the Court's Electronic Case Files (ECF) syst€t1J: and to subscribe to the ReF email (Listserver) notification service. Registered attorneys and other participants will have privileges both to electronically submit documents, and to view and retrieve electronic docket sheets and documents for all cases assigned to the Electronic Case Files system. Listserver subscribers receive email messages whenever the Court wishes to electronically notify ECF registrants ef pertinent ECF Information,

The following information is required for registration:

If you are appointed pro bono Or pro hac vice, please provide the case number:

First Name/Middle Initial/Last Name:

Last four digits cf Social Security Number: ,

DC Bar ID#: _

Finn Name: ~ __ . _

Finn Address

Voice Phone Number: ~

FAX Phon" Number: ~ _

Internet E-Mllil Addn:N~: _

By submitting this registration form, the undersigned agrees to abide by the following rules:

1. This system is for use only in cases permitted by the U.S. Districl Court/or the District OfCo1uft1bi(J., It may be used to file and view electronic documents, docket sheets, and notices. Please visit the Court's EeF Internet Website to schedule training.

2. Pursuant to Federal Rule of Civil Procedure l I, every pleading) motion, and other paper (except list, schedules, statements or amendments thereto) shall be signed by at least: one attorney of record or, if the party is not represented by an attorney I aU papers shall be signed by the party. An anomey's/participent's password issued by the court combined with the user's identification, serves as and constitutes the attcrney's/participant's

PAGE 25/25

'6'

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signature. Therefore, an attorney/participant must protect and secure the password issued by the court. Iftbere is any reason to suspect the password bas been compromised in any way, it is the duty and responsibility of the attorney/participant to immediately notify the court. This should include the resignation or reassignment of the person with authority to use the password, The COlil1 will immediately delete that password from the electronic filing system and issue a new password.

3. An attorney's/participant's registration will not waive conventional service of a summons and complaint, subpoena, or other judicial process; submit the client to the jurisdiction of the Court; or operate as a consent to accept service of pleadings. documents, and orders in actions in which such attorney/participant has not entered an appearance. An attorney's/participant's registration will constitute a waiver in law only of conventional service of other non-process pleadings, documents, and orders in the case, The attomcy/participant agrees to accept, on behalf of the client, service of notice of the electronic filing by hand, facsimile or authorized e-mail.

4. Upon receipt of your login and password, you are strongly encouraged to change your

password, which may be done through the Utilities function, to a name easily recalled, You may be subjected to a fee, should the Clerk's Office have tel create a new password for you, or alternatively, you may be requited to appear in person to receive your new password.

5. Attorneys must be active members of the bar of this Court} or government attorneys who are employed or retained by the United States, or who have been permitted to proceed pro hac vice, must file pleadings electronically.

6_ Whenever a filer's e-mail address changes. the USer agrees to update their BCF profile to show the new e-mail address. The system is robust enough to pennit counsel to change their own e-mail address within the ECF System. Effective December 9,2008, pursuant tile directions from the Court's Information Technology Committee, the Clerk's Office will no longer monitor bounced e-mails.

Please return this fonn to:

U.S. District Court for the District of Columbia Attn: Attorney Admissions

333 Constitution Avenue NW, Room 1825 Washington, DC 2000 I

0,. FAX to: Peggy Trailillm

U.S. District Court for the District of Columbia (202) 354-3067

ADPlicaut's Signature:

Full Last Name

Initial of PirstName

Last 4 Digits SS#

PAGE 25/25

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