Case 1:10-cv-00897-RJL Document 24-2

Filed 07/08/10 Page 1 of 3

Exhibit 1

Case 1:10-cv-00897-RJL Document 24-2

Filed 07/08/10 Page 2 of 3

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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

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DANIEL PARISI, et ai., Plaintiffs, v.

)
)

) ) Civil Action No. 1O-0897-RJL
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LAWRENCE W. SINCLAIR alkJa "Larry Sinclair", et ai., )
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Defendants.

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DECLARATION OF DANIEL PARISI
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, I

could competently testify thereto. 2. Columbia. 3. Plaintiff, Whitehouse.com Inc., is a New Jersey corporation with its principal I am currently a citizen of New Jersey but will be moving to the District of

place of business in Wayne, New Jersey. 4. Plaintiff, Whitehouse Network LLC ("WN"), is a New Jersey corporation with its

principal place of business in Wayne, New Jersey. 5. Plaintiff, White House Communications Inc. ("WHCI"), is a Panama corporation

with its principal place of business in Panama. 6. I am engaged in the business of owing and developing domain names and

websites. I have been in this market for 14 years and have extensive experience in buying and selling websites and domains. 7. WHCI owns the domain name, Whitehouse.com. Whitehouse.com Inc. and WN

operate the Whitehouse.com domain name and website. They have been and are engaged in

Case 1:10-cv-00897-RJL Document 24-2

Filed 07/08/10 Page 3 of 3

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 model of successful political sites such as huffingtonpost.com, which in December 2008 raised $25 million in a single investment and a total valuation of almost $100 million, according to published reports. 8.
It is my understanding that in 2004, Microsoft Corporation sold Slate, a politically

oriented site, for between $15 million and $20 million to the Washington Post Co. 9. We hoped to sell the Whitehouse.com site to political/news entities, but has been

unable to do so in light of the taint of Sinclair's defamation. Based on my knowledge of the industry, plaintiffs have been damaged in the amount of $30,000,000. 10. Plaintiffs ask the Court to enter judgment against SPI for a portion of its damages,

in the amount of $5,000,000. 11. Plaintiffs also seek an accounting and imposition of a constructive trust as to

SPI's proceeds from the defamatory statements and its ownership of any assets, including copyrights.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated: July 8, 2010

Daniel Parisi

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