This action might not be possible to undo. Are you sure you want to continue?
Opposition to Plaintiffs Emergency Motion - 1
1 Lawrence W. Sinclair
d/b/a Sinclair Publishing
2 Post Office Box 1963
Washington, DC 20013
3 386-506-8912 email@example.com
THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
) ) ) )
) Case No.: 1: 1 O-cv-00897 -RJL )
DANIEL PARlSI, et al.,
LA WRENCE W. SINCLAIR, et al.,
DEFENDANT SINCLAIR'S OPPOSITION TO "PLAINTIFFS' EMERGENCY MOTION TO REQUIRE DEFENDANTS LAWRENCE W. SINCLAIR AND SINCLAIR PUBLISHING INC TO PRESERVE DISCOVERABLE INFORMATION AND DOCUMENTS
Defendant LAWRENCE W. SINCLAIR and LA WRENCEW. SINCLAIR d/b/a Sinclair
Publishing (formerly Sinclair Publishing, Inc.) ( Sinclair), pro se, opposes "PLAINTIFFS'
EMERGENCY MOTION TO REQUIRE DEFENDANTS LAWRENCE W. SINCLAIR
AND SINCLAIR PUBLISHING INC TO PRESERVE DISCOVERABLE
INFORMATION AND DOCUMENTS" and states as follows:
Plaintiffs' counsel Richard Oparil has filed a completely unnecessary Motion
23 before this Honorable Court based on conjecture and lacking in facts.
Plaintiffs' counsel Richard Oparil claims Defendants' Sinclair has and/or is
25 destroying "Globe Magazines" plaintiffs' claim are discoverable evidence. Mr. Oparil has LIED
1 2 3 4 5 6
Opposition to Plaintiffs Emergency Motion - 2
in making this claim. The Globe Magazines are in very good hands and are indeed being preserved (probably more so than they would or could have been in defendants current living arrangements. )
3. Defendant Sinclair has repeatedly informed plaintiffs' counsel, Richard Oparil
that considering defendant is not allowed to file electronically in this action; Plaintiffs must
submit all requests and communications to defendant in writing via United States Mail, United 7
Parcel Service or FedEx, but NOT by email.
Plaintiffs' counsel Richard Oparil in his motion and his "Declaration" states
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
"Sinclair seems to revel in the prospect of destroying evidence," which again is yet another knowingly false claim made by counsel before this court with no evidence that any "discoverable evidence" has been destroyed.
Defendant Sinclair has the right to offer co-defendants in this case, under Joint
Defense Privilege to arrange to have copies of files pertaining to this action copied at their expense. Plaintiffs' counsel Richard Oparil is not entitled to email defendant Sinclair and make demands nor is Mr. Oparil entitled to demand a blanket order that I maintain everything in my possession as if it were discoverable evidence in this action.
6. Defendant Sinclair states he has not destroyed any file, document or other item
which would be considered relevant to this action. Sinclair further states that while Plaintiffs' counsel Richard Oparil makes unfounded claims in writing before this court on a regular basis, the evidence shows that Plaintiff Daniel Parisi and Plaintiffs' counsel Richard Oparil have "scrubbed" whitehouse. com of evidence demonstrating their claims to be baseless (Exhibit 1 Whitehouse. com today September 10,2010) (Exhibit 2 Whitehouse. com February 2008 before
8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
1 2 3 4 5 6
Opposition to Plaintiffs Emergency Motion - 3
Plaintiffs scrubbed all content prior to filing this action.) Exhibit 3 Reports Dan Parisi and Whitehouse. com "scrubbed" whitehouse. com of articles posted by Plaintiff in June 2008)
7. Plaintiffs' counsel Richard Oparil has lied to this Honorable Court in yet another
written pleading in claiming he attempted to "meet and confer" pursuant to Court rules. Defendant Sinclair did contact Mr. Oparil by email after Oparil refused to answer his phone or return phone calls asking to meet in person to discuss the issues of this action. Oparil simply responded "what for."
Defendant Sinclair has not destroyed anything that could be considered "discoverable Evidence" as claimed by plaintiffs' counsel Richard Oparil with full knowledge his claims were false. Sinclair did inform counsel for plaintiff that the "Globe Magazines" were not "unique" evidence where they could not be obtained from another source like the publisher who actually published them.
Plaintiffs counsel Richard Oparil seems to think defendants Sinclair are going to bow down to his every demand, this will not happen. Plaintiffs' counsel must identify specifically what he intends to requests in discovery. Plaintiffs have as is documented by more than 2 years on the internet destroyed evidence and internet articles that they themsel ves claim in the Complaint to be defamatory.
Wherefore Defendant Sinclair opposes "PLAINTIFFS' EMERGENCY MOTION TO REQUIRE DEFENDANTS LAWRENCE W. SINCLAIR AND SINCLAIR PUBLISHING INC TO PRESERVE DISCOVERABLE INFORMATION AND DOCUMENTS" and requests this court DENY said Motion.
Opposi t.ion to Plaintiffs Emergency Motion - 4
Further, Defendants Sinclair ask this Honorable Court sanction Richard Oparil and Patton
Boggs LLP for filing out right false statements in attempting to obtain an order from this court
that is not necessary.
Respectfully submitted this 11 til day of September 2010.
/s rence W. Sinclair
Lawrence W. Sinclair, Pro Se
On Behalf of Lawrence W. Sinclair and
Former Sinclair Publishing, Inc. NOW Lawrence W. Sinclair
d/b/a Sinclair Publishing Post Office Box 1963 Washington, DC 20013
<firstname.lastname@example.org>: delivery via
19 mail.global.f tbridge.com[184.108.40.206]:25: 2502.6.0
CERTIFICATE OF SERVICE
The undersigned certifies that on September 11,2010 the foregoing "DEFENDANT SINCLAIR'S OPPOSITION TO "PLAINTIFFS' EMERGENCY MOTION TO REQUIRE DEFENDANTS LAWRENCE W SINCLAIR AND SINCLAIR PUBLISHING INC TO PRESERVE DISCOVERABLE INFORMATION AND DOCUMENTS" was filed with the Clerk of the Court in person to be served by operation of the Court's electronic filing system upon:
Richard J Oparil and Kevin M. Bell of Patton Boggs LLP, attorneys for plaintiffs; Stephen
6 Smith, Mathew Segal, Kari Vander Stoep and John Longstreth of K&L Gates LLP, attorneys for defendant Amazon.com Inc.; Linda Steinman and John Eastburg of Davis Wright Tremaine LLP, 7 attorneys for Defendant Barnes & Noble, Inc.
8 The undersigned further certifies that the foregoing was delivered via email on Septembe
11,2010 at 12:25 AM on the following:
<Cindi.Street@ingramcontent.com>: delivery via
mx5 21.us.emailfiltering.com [220.127.116.11]: 25: 250 accepted (692709252)
<Iindasteinman@dwt.com>: delivery via dwt.com.mail1.psmtp.com[18.104.22.168]:25: 250 Thanks
<ROparil@PattonBoggs.com>: delivery via
pattonboggs .co m. inbound 15 .mx logi c .net [2 08.65.144.13]: 25: 250 Bac kend Replied [dc50b8c4.0.89482.00-2377.108826.p02c11m023.mxlogic.net]: 2.0.0 o8B4Udal006852 Message accepted for
<Steven.email@example.com>: delivery via mailwest.huschblackwell.com[22.214.171.124]:25: 250 ok: Message 28780009 accepted
Opposition to Plaintiffs Emergency Motion - 5
Find Local Personal Injury I Disability Lawyers.
Home I Find a Lawyer
Page I of I
Find Personal Injury t.awvers:
Personal Injury / Disability Lawyers
Your First Name:
Welcome to WhitehouseLawyers.com. We are the Nationwide Leader In Connecting You to Top Lawyers. If you have been seriously injured in an accident or at work we are here to help you. Fill out our simple form to find top real lawyers, you then cboose which lawyer works best for you. This service is absolutely free with no obligations.
Your Last Name:
Select a State
j Submit I
Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine Mgryland
Massac;!:J_us~ Michigan Minnesota MississirJQi Mjssouri Montana Nebraska Nevada
/'\lew Hampshire New Jersey
New Mex_Lc.o New York North Carolina North DakQta Ollio QklaJlQnm Oregon PennsyJvani~ Rhode Island S_o_uth Carolina
South Dakota Tennessee_ Texas
l,/Nh iLelJT1Qll! \licginia \i\Jashin9lQn West Virgi_oia Wisconsin Wyoming
© 2010 WhiteHouseLawvers,com. All Rights Reserved. I Website Desigl' bV l%%~t Asat@ WebStudio46.com
N CI c:a t.:I
» Whitehouse.com Or Is It Whitewash.com? - Blogger News Network
Page I of8
High-quality English language analysis and editorial writing on the news.
• About BNN
• BNN Editorial Policies
• Posting Guideline~
• Write for BNN
• Loain & Write!
Whitehous~.com Or Is It Whitewash.com?
Posted on June 19th, 2008
by Simon Barrett in 2008 Election Coveraae, JllQggsRhere News Read 4,670 times.
Larry Sinclair strikes again!
The Main Stream Media seem to have taken the approach that the name Larry Sinclair does not exist. There has been almost no mention of the press conference held yesterday where Larry pulled out his somewhat doubtful but none the less humorous tale of driving around in the back of a limo, while he and Barak Obama engaged in some less than heterosexual activities, and did a couple of lines of Cocaine. Oh, and the cocaine was obtained by Obama. This entire story has the credibility of some of the claims made by late night infomercials!
Larry's press conference yesterday ended somewhat ignominiously, with him being v"'cuffed and led away by the Feds. His lawyer, resplendent in Kilt (he told the audience it was to do with his anatomical design, trousers jiii~~ijiil were too constricting) was unable to assist, as
his law license is currently suspended.
The interesting aspect in this circus was the involvement of Whitehouse.com, they used to be a porn site, but I guess they have discovered that there is more money in politics that naked flesh.
Whitehouse.com were the folks that
Page 1 of 1
!.lcCain vs Ob.ma: McCain: 42.9 noema: 4S_8 Olhec 10.2
Should Obama choose Clinton as his running mate?
WfliteH>ouse.cem Larry Sinclair Polygraph Press Conference at National Press Club June 18 at 4:00 PM
611612008 8:0 Q P 1,1
WASHINGTON, June 1L 2008;;,:~~~_ Whitehouse,co will
hold a press conference regarding the Larry Sinclair controversy on June 18,2008 in the Visagor lounge of the National Press Club, 529 14th Street NW, Washington, DC
. 20045_ Signup will start at 3:00 PM, and the actual conference will
Wh 0 would yo u vote lor President belw'een McCain and Clinton?
Who would you vote for President between MGCain and Obama?
Page 1 of 1
tJ. WhiteH?use cam • Ch~nging the Face of Politics . Wind~ In!er';;; Exp~~r . - _ - - - _, _ - ~('gjm
AYG Info' I Get More
\ look for Map • 'i~ A'Jtofill ~ Serd to.
'"'- 2008 Election
529 14th Street NW, Washington, DC 20045. Signup will start at 3:00 PM, and the actual conference will start at approximately 4:00 PM, following the conclusion of Mr. Sinclair's press conference, ...,ihich is schedule_dearlier in the day,
National Press Club,
During the press conference, Wfliteliollse,Gom will release the results of the polygraph examinations, the reports of the experts, and a video of Mr. Sinclair taken while the examinations were being administered.
1ei:1otlse.com focuses on giving average Americans a greater voice on issues facing.the country. Whitehouse,Gom, whichis celebrating its 11th year, has been visited by over 100 million people since its inception in 1997. INe are not affiliated with or endorsed by U.S. Government
Jillp :77 sites .google.comtslte/expedl tereVlews! Wh:iteliouse I .J P'
» Whitehouse.corn Or Is It Whitewash. com? - Blogger News etwork
Page 2 of8
persuaded Larry Sinclair to take a polygraph test, a test that he apparently failed. Yesterday Whitehouse.com had booked time right after Larry's press conference, for one of their own.
During the press conference, Whitehouse. com will release the results of the polygraph examinations, the reports of the experts, and a video of Mr. Sinclair taken while the examinations were being administered.
This was the lead article on their site for several days. But this morning there was no sign of it. The good news is that Whitehouse.com is about as popular as a dose of herpes, and not refreshed by the search engines very often, so Google still had the original version of the page cached.
Screen grabs available here and here.
I wonder what went wrong? Cold feet?
I was not there, but a press friend had this to say about whitehouse.com
Whitehouse handed out talking points but from the one account I have .... Parisi's equipment broke and then he walked out without answering any questions .... which wasn't noticeable, since almost no one showed up ....
So, is whitehouse. com the real thing, or are they just as sleazy as the previous porn owners? It seems to me that while they may not have had huge credibility before, they now have zero! If you advertise a story, you should go through with it. In the print world, you have to live by what you print. In the internet world, you can always delete it. But Whitewash.corn didn't take into account the fact that the traces are left. There is always a copy if you look hard enough. A quick 'reality scan' of whitehouse.com' reveals that they do not have a huge amount of credibility. The Alexa rating puts them somewhere between the storm drain and the sewer, and Technorati barely registers their existence.
h1;1P:llzzsimonb. b 10 gs.Q ot. com
Let Others Know About This Post These icons link to social bookmarking sites where readers can share and discover new web pages .
• II] .~
• III .~ .[;J
. iii .IQ
http://www.bloggemews.netI1163 1 0
» Whitehouse.com Or Is It Whitewash.corn? - Blogger News Network
Page 3 of8
Click Below To Rate This Post:
(6 votes, average: 4.17 out of 5)
I Loading ...
4 users commented in " Whitehouse.com Or Is It Whitewash.com? "
Follow-up comment rss or Leave a Trackback OfficialWire said,
in June 21 st, 2008 at 9:48 am
We are actively monitoring this topic. While I do not actually believe (read: want to believe) LaITY Sinclair, I remember The Rev. Ted Haggard and know that stranger things have happened. A member of our staff has written to Mr. Obama's new Fight'TheSmears.corn website, but as of today, we have not received a reply. I would have thought that they would have posted this one to the website since no one at from their campaign wants to discuss the allegations. As for Sinclair's criminal past, he would be Al Capone and it would not make his claims untrue.
Simon BaITett said,
in June 21st, 2008 at 10:56 am
Larry's story has the credibility, and longevity of an Ice SCUlpture in Dubai! But, what surprises me is the response, or should I say lack of response from whitehouse.com
in June 24th, 2008 at 8:16 am
The polygraph that Whitehouse.com set up does have some results you can believe.
After he realized that Whitehouse. com was setting him up, Larry Sinclair had the polygraph results analyzed by a real expert.
in July 8th, 2008 at 10:56 pm
I be live Mr. Sinclair's story. I don't think this guy could possibly make all this up. I also believe his polygraph test was altered. They are trying to muzzle this guy. They want to destroy the guy, taking his SSD away from him. Unbelievable!
Leave A Reply
http://www . bloggernews.netJl16 310
» Whitehouse.com Or Is It Whitewash.com? - Blogger News Network
Page 4 of8
Email Address (*private)
Post My Comment
Find out here
The Latest in
How will health Care reform affect you?
ArI~ h'IJ ~nnnrp
BloggerNews On The Air
We are pleased to announce our latest endeavor, Blogger News is now sponsoring some radio shows on Blog Talk Radio. You can check our full schedule, and listen to previous broadcasts here, and we hope that you will join us on the air in this new venture.
Haliegh Cummings update -Every Sunday at 3pm central
» Whitehouse.com Or Is It Whitewash. com? • Blogger News Network
Page 5 of8
Listen to internet radio with Si 1011 Barrett on Blog Talk Radio
Hot Topics, In-Depth:
While BloggerNews.net is known to provide up to the minute information on a wide variety of topics, at times a more in-depth analysis of a topic that is being written about by our writers is warranted. This section of BNN provides just that - an area of the site that looks deeper into a topic, delves into the actual facts behind it, and provides more than just a summary overview of what is happening right here and now.
From something as mundane as an overview of how credit scores work, to life and death topics such as mesothelioma, we are committed to creating a growing library of information for our readers. Click below to review the topics covered so far, and check back soon as new ones are to be added regularly!
Click Here to Review our 'Hot TORies, In·De.Qth' section.
Recently Published Topics, by category:
Friends Of Blogger News
BNN would like to recognize these two individuals for the enormous help they have provided us in our investigations
TJ Hart News Director for The Sk 97.3 News Talk Radio
Investigator William Cobra Staubs, Bill comes through when others do not.
BloggerNews.net Wants You!
» Whitehouse.com Or Is It Whitewash. com? - Blogger News Network
Page 6 of8
Got something to say?
We Can Help You Tell The World.
CI ick here to email Simon (Our Editor) for details ...
• DVD Review: Paul McCartney Reall Is Dead - The Last Testament Of Gear e Harrison
• Nine Years Later ... What Have We Learned? How Have We Chan ed?
• DVD Review: Hunter S. Thompson - His Final Hours - Final 24
• Surviving The 21st Century - It's in The Water!
• More ATM Skimmers Being Used By Gangs
• Why Cheap Generic Medicine can Kill
• Canadian Researcher: 'We must abandon the claim that the (family) court has been actin__g_W
children's best interests'
• RP In The GuIfOr Union Carbide In Rho al- Which Was Worse?
• You Can't Yell "Fire" in a Crowded Theater When There Is None!
• Osama bin Laden's 2002 'letter to America,' Full Text
• Larry Sinclair That Polygraph Just Won't Go Awa !
• LaITY Sinclair Has One More Kick At The Obama Cat
• L Sinclair's Full Statement: PolygmQh EXQert Flunks Credibili Test?
• Larry Sinclair: Obama Accuser Fails Pol raphs
• Larry Sinclair: Controversy Surrounds Pol arID Ex ert
September 201 0 SMTWTFS
1 2 J 4 5. Q 1 8 2 10 11 12 13 1415 161718 19 20 21 22 23 24 25
» Whitehouse. com Or Is It Whitewash.com? - Blogger News Network
2627282930 « Aug
• fumtember 2010
• August 2010
• July 2010
• June 2010
• May 201Q
• March 2010
• February 2010
• January 2010
• December 2009
• November 2009
• October 2009
• S~.Rtember 2009
• Augyst 2009
• July 2009
• M;zy 2009
• March 2009
• February 2009
• Januar 2009
• December 2008
• November 2008
• October 2008
• September 200~
• August 2008
• J1Jly 2008
• June 2008
• ME 2008
• March 2008
• Febl~ 2008
• January 2008
• December 2007
• November 2007
• October 2007
• Sentember 2007
• August 2007
• July 2007
• June 2007
• May 2007
• April 2007
• March 2007
• February 2007
• Januar 2007
This action might not be possible to undo. Are you sure you want to continue?
We've moved you to where you read on your other device.
Get the full title to continue reading from where you left off, or restart the preview.