UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

)
DANIEL PARISI, et al., )
)
Plaintiffs, )
)
v. ) No. 1:10-cv-00897-RJL
)
LAWRENCE W. SINCLAIR a/k/a “Larry Sinclair”, )
et al., )
)
Defendants. )
)

PLAINTIFFS’ MOTION FOR DEFAULT JUDGMENT
AGAINST DEFENDANT SINCLAIR PUBLISHING, INC.

Plaintiffs, Daniel Parisi, Whitehouse.com Inc., Whitehouse Network LLC, and White
House Communications Inc. (collectively referred to as “plaintiffs”), by counsel, files this
motion for a default judgment against defendant Sinclair Publishing, Inc. (“SPI”). Plaintiffs seek
a judgment against SPI in the amount of $5,000,000. In addition, the Court should enter
judgment ordering an accounting and imposition of a constructive trust as to SPI’s proceeds from
its defamatory statements and its ownership of any assets, including copyrights.
Plaintiffs’ motion for a default judgment against SPI is supported by the accompanying
memorandum in support. A proposed order is attached.
Dated: July 8, 2010 Respectfully submitted,


/s/ Richard J. Oparil
Richard J. Oparil (D.C. Bar No. 409723)
PATTON BOGGS LLP
2550 M Street, NW
Washington, DC 20037
(202) 457-6000
(202) 457-6315 (fax)

Case 1:10-cv-00897-RJL Document 24 Filed 07/08/10 Page 1 of 3
PDF processed with CutePDF evaluation edition www.CutePDF.com
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Kevin M. Bell
PATTON BOGGS LLP
8484 Westpark Drive
McLean, VA 22102
(703) 744-8000
(703) 744-8001 (fax)

Attorneys for Plaintiffs


5106341
Case 1:10-cv-00897-RJL Document 24 Filed 07/08/10 Page 2 of 3
CERTIFICATE OF SERVICE

I hereby certify that on July 8, 2010, a copy of the foregoing was served on counsel for
the parties that have appeared in the case by the Court’s ECF system and on the following by
first class mail:
Lawrence W. Sinclair
9 Spring Drive
Port Orange, FL 32129

Sinclair Publishing, Inc.
9 Spring Drive
Port Orange, FL 32129


s/ Richard J. Oparil
Richard J. Oparil (DC Bar No. 409723)
5106341
Case 1:10-cv-00897-RJL Document 24 Filed 07/08/10 Page 3 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

)
DANIEL PARISI, et al., )
)
Plaintiffs, )
)
v. ) No. 1:10-cv-00897-RJL
)
LAWRENCE W. SINCLAIR a/k/a “Larry Sinclair”, )
et al., )
)
Defendants. )
)

PLAINTIFFS’ MOTION FOR DEFAULT JUDGMENT
AGAINST DEFENDANT SINCLAIR PUBLISHING, INC.

Plaintiffs, Daniel Parisi, Whitehouse.com Inc., Whitehouse Network LLC, and White
House Communications Inc. (collectively referred to as “plaintiffs”), by counsel, files this
motion for a default judgment against defendant Sinclair Publishing, Inc. (“SPI”). Plaintiffs seek
a judgment against SPI in the amount of $5,000,000. In addition, the Court should enter
judgment ordering an accounting and imposition of a constructive trust as to SPI’s proceeds from
its defamatory statements and its ownership of any assets, including copyrights.
Plaintiffs’ motion for a default judgment against SPI is supported by the accompanying
memorandum in support. A proposed order is attached.
Dated: July 8, 2010 Respectfully submitted,


/s/ Richard J. Oparil
Richard J. Oparil (D.C. Bar No. 409723)
PATTON BOGGS LLP
2550 M Street, NW
Washington, DC 20037
(202) 457-6000
(202) 457-6315 (fax)

Case 1:10-cv-00897-RJL Document 24 Filed 07/08/10 Page 1 of 3
- 2 -
Kevin M. Bell
PATTON BOGGS LLP
8484 Westpark Drive
McLean, VA 22102
(703) 744-8000
(703) 744-8001 (fax)

Attorneys for Plaintiffs


5106341
Case 1:10-cv-00897-RJL Document 24 Filed 07/08/10 Page 2 of 3
CERTIFICATE OF SERVICE

I hereby certify that on July 8, 2010, a copy of the foregoing was served on counsel for
the parties that have appeared in the case by the Court’s ECF system and on the following by
first class mail:
Lawrence W. Sinclair
9 Spring Drive
Port Orange, FL 32129

Sinclair Publishing, Inc.
9 Spring Drive
Port Orange, FL 32129


s/ Richard J. Oparil
Richard J. Oparil (DC Bar No. 409723)
5106341
Case 1:10-cv-00897-RJL Document 24 Filed 07/08/10 Page 3 of 3


UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

)
DANIEL PARISI, et al., )
)
Plaintiffs, )
)
v. ) No. 1:10-cv-00897-RJL
)
LAWRENCE W. SINCLAIR a/k/a “Larry Sinclair”, )
et al., )
)
Defendants. )
)

MEMORANDUM IN SUPPORT OF
PLAINTIFFS’ MOTION FOR DEFAULT JUDGMENT
AGAINST DEFENDANT SINCLAIR PUBLISHING, INC.

Plaintiffs, Daniel Parisi, Whitehouse.com Inc., Whitehouse Network LLC, and White
House Communications Inc. (collectively referred to as “plaintiffs”), by counsel, files this
memorandum in support of its motion for a default judgment against defendant Sinclair
Publishing, Inc. (“SPI”). Plaintiffs seek a judgment against SPI in the amount of $5,000,000. In
addition, the Court should enter judgment ordering an accounting and imposition of a
constructive trust as to SPI’s proceeds from its defamatory statements and its ownership of any
assets, including copyrights. The relief requested is supported by the declaration of plaintiff
Daniel Parisi (“Parisi”). (Ex. 1).
BACKGROUND
On May 28, 2010, plaintiffs filed their complaint against defendants, Lawrence W.
Sinclair, Jeffrey Rense, SPI, Barnes & Noble, Inc., Barnesandnoble.com LLC, Amazon.com,
Inc., and Books-A-Million, Inc. (collectively referred to as “defendants”). (Dkt. No. 1). On an
application for a default judgment, the factual allegations in the complaint are taken as true. See,
e.g., Pope v. United States, 323 U.S. 1, 12 (1944); Ryan v. Homecomings Fin. Network, 253 F.3d
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778, 780 (4th Cir. 2001); Goddess v. United Fin. Group, 559 F.2d 557, 560 (9th Cir. 1977) Ford
Motor Co. v. Cross, 441 F. Supp. 2d 837, 848 (E.D. Mich. 2006); Chanel, Inc. v. Gordashevsky,
558 F. Supp. 2d 532, 535 (D.N.J. 2008); International Painters & Allied Trades Indus. Pension
Fund v. R.W. Amrine Drywall Co., 239 F. Supp. 2d 26, 30 (D.D.C. 2002).
According to the complaint, Parisi is engaged in the business of owing and developing
domain names and websites. (Dkt. No. 1 ¶ 16). 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 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. (Id. ¶ 17).
Unfortunately, that business plan was disrupted by plaintiffs involvement with defendant
Sinclair, a self-confessed convicted felon and former drug user and trafficker. He has used
multiple aliases. He operates self-promotional websites, including larrysinclair.com,
larrysinclair.org and larrysinclairforcongress.com. (Id. ¶ 18).
On February 10, 2007, then Senator Barack Obama (“Obama”) announced that he was
running for President of the United States. On January 3, 2008 Obama won the Iowa Democratic
caucus. Approximately two weeks later, on January 18, 2008, Sinclair posted a YouTube video
in which he made wild allegations regarding the purchase, sale and use of drugs and sexual
activity by and between Sinclair and Obama on November 6 and 7, 1999. Sinclair hoped and
expected to profit and personally benefit from his drug and sex allegations against the
Presidential candidate. (Id. ¶¶ 19-22).
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In February 2008, after he became aware of Sinclair’s allegations and as part of its effort
to develop a political website, Parisi contacted Sinclair. He offered to pay Sinclair $10,000 to
take polygraph examinations and to pay him $100,000 if the examinations showed Sinclair was
telling the truth. Whitehouse.com, Inc. later paid Sinclair $20,000 as part of a modified
agreement. (Id. ¶ 23).
On 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 California. Sinclair was
involved with and agreed to the selection of Gelb. (Id. ¶ 24).
Gelb administered two polygraph examinations, one pertaining to the drug allegation and
the other on the sex allegation. Both examinations were videotaped. According to Gelb’s report,
Sinclair indicated deception on both examinations, which was corroborated by two examiners.
Whitehouse.com then provided Sinclair with a copy of the polygraph examination results and
posted the results online. (Id. ¶¶ 26-27).
On 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. (Id. ¶ 30).
In June 2009, Sinclair self-published through SPI, a copyrighted book entitled Barack
Obama & Larry Sinclair: Cocaine, Sex, Lies & Murder? (referred to as “the book” or “Sinclair’s
book”). (Id. ¶ 31). SPI owned and continues to own the copyright. (Ex. 2).
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Sinclair’s book repeated his story about drugs, sexual activity and Donald Young’s
murder. The book also contains vicious attacks on Parisi and Whitehouse.com. Sinclair’s book
is replete with false, defamatory and derogatory statements regarding Parisi and the website,
including without limitation, the following:
▪ In fact, at 12:48 a.m. on February 25, 2008 (the day before
Barland’s review was even conducted), I received a telephone tip
from 207-252-2796 and 207-899-0872, advising me that the
polygraph was rigged and was arranged by Dan Parisi and Obama
Campaign advisor David Axelrod. The man giving me the tip
stated that, “Axelrod and the Obama campaign had agreed to pay
Dan Parisi of Whitehouse.com, $750,000 to arrange a rigged
polygraph. Parisi and Axelrod were in a heated argument because
the Obama camp wanted Parisi to publish that 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 a million dollars agreed on.”
When I received this information, I contacted Dan Parisi and
informed him of what was stated, and I 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.com that he had been threatened
repeatedly by “Sinclair’s supporters and that Whitehouse.com
would not publish anything further regarding Larry Sinclair.” In
addition, Parisi immediately shut down Whitehouse.com,
completely scrubbed the site of all posts and comments on the
Larry Sinclair/Barack Obama story, and revamped the format of
the website requiring individuals to register with Whitehouse.com
before being able to comment. It was at that time,
Whitehouse.com became the staunchest promoters of Barack
Obama, while slamming Hillary Clinton non-stop. I also had
asked Parisi to respond; I forwarded the information to 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 FEC 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 not have
made a single individual payment.
Immediately after confronting Whitehouse.com’s Dan Parisi about
the allegations that he arranged a rigged polygraph exam, he issued
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a stop payment of the check issued to me for the polygraph exam.
You see, Parisi had made a deal with David Axelrod and the
Obama campaign. All of this occurred on the very day that I
published emails to Mr. Parisi asking for his response to the claims
made in an anonymous telephone tip.
▪ The information Edward Gelb had obtained from the extensive
pre-polygraph interview suddenly was being posted on the internet
at DemocraticUnderground.com, MyBarackObama.com,
HuffingtonPost.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 a deal
with advisor David Axelrod, that 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.com received $750,000 from the Obama campaign
through AKR Media to organize an effort to publicly discredit me.
When I confronted Parisi with this allegation, he did not deny it
but instead withdrew the second exonerating polygraph report of
Dr. Gordon Barland. He also failed to post the video of my
polygraph as he and Whitehouse.com promised they would do. He
even removed posts from their web site altogether, claiming that
they had “had 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.com . . . .
(Dkt. No. 1 ¶ 32). Rense, 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 net and on
my program, the Obama power base immediately organized a
clearly high-level, multi-faceted assault on him featuring bizarre
events like top advisor David Axelrod allegedly hiring internet
porn merchant, Don Parisi, of the otherwise commercial porn site,
Whitehouse.com, to set up 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 I. Gelb, polygraph examiner for hire, who
among other things represented himself as having a Ph.D. when he
apparently does not.
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(Id. ¶ 33). In addition, various “product descriptions” of Sinclair's book by Amazon, BAM and
Amazon also make false and defamatory statements regarding plaintiffs. (Id. ¶¶ 35-36, 38-39).
SPI, Sinclair, B&N, Amazon, and BAM, have offered for sale and sold Sinclair’s book
throughout the United States, including in the District of Columbia, in stores and/or through
internet order and delivery. (Id. ¶ 34).
The above described Sinclair’s book and promotional statements (referred to as “the
defamatory statements”) referred to Parisi and Whitehouse.com by name, were made of and
concerning him and Whitehouse.com, and were so understood by those reading the defamatory
statements.
1
(Id. ¶ 41). The following include the defamatory statements that plaintiffs allege to
be false and misleading as they pertain to Parisi and Whitehouse.com and form the basis for the
claims alleged herein:
a. Plaintiffs have never discussed Sinclair or his allegations with David Axelrod or
the Obama campaign, or anyone acting on their behalf.
b. Plaintiffs have never conspired, criminally or otherwise, with Obama, the Obama
campaign or Axelrod or anyone acting on their behalf.
c. Plaintiffs have never entered into an agreement, contract, or understanding with
David Axelrod, the Obama campaign, or anyone acting on their behalf.
d. Plaintiffs never agreed to accept or be paid money or other benefit by David
Axelrod, the Obama campaign, or anyone acting on their behalf, for any purpose.

1
Since publication of the defamatory statements, SPI and Sinclair have made other untrue
statements of fact about the plaintiffs orally or in writing, including in postings on the internet.
(See, e.g., Dkt. No. 1 ¶ 43 & Ex. 3).
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e. Plaintiffs have never “made a deal with David Axelrod and the Obama campaign”
for any purpose, including without limitation, to arrange a rigged polygraph
examination of Sinclair.
f. Plaintiffs did not “rig” Sinclair’s polygraph examinations.
g. Plaintiffs have never helped anyone to get 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.
(Id. ¶ 44). 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. (Id. ¶ 45). Prior to the filing of this action,
defendants knew or had reason to know of the defamatory statements. (Id. ¶ 47).
SPI has benefited and profited from Sinclair’s book and the other defamatory statements.
(Id. ¶ 46).
As a direct and proximate result of the defamatory statements of the defendants, the
Whitehouse.com website was shut down in 2008. Whitehouse.com 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. (Id. ¶ 48).
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On May 28, 2010, Sinclair, responding to a case and desist letter on behalf of SPI, left
plaintiffs’ counsel the following voice message:
Mr. Oparil, Lawrence Sinclair. I received a FedEx letter from you
dated May 27, 2010 addressed to Sinclair Publishing Inc.
requesting that we cease and desist from publishing, offering for
sale and selling a book titled “Barack Obama and Larry Sinclair:
Cocaine, Sex, Lies and Murder?” which you claim that you
represent Daniel Parisi and Dan Parisi claims that it’s defamatory
and disparaging.
Here’s my answer to your letter. HELL, NO. We will not cease
and desist from publishing, offering for sale and selling the book,
and I welcome Mr. Parisi to try to take legal action. Contracts that
were drawn up between Mr. Parisi and myself and, uh -- well,
you’ll talk to your client. The answer is HELL, NO.
(Id. ¶ 50). On May 28, 2010, Sinclair sent a letter to plaintiffs’ counsel confirming SPI would
not cease and desist from publishing, offering for sale, and selling the book. (Id. ¶ 51 & Ex. 4).
The complaint alleges four claims on which plaintiffs seek recovery from SPI:
defamation (libel per se/libel) (¶¶ 54-64), false light invasion/misappropriation of privacy (¶¶ 65-
69), business disparagement (¶¶ 70-76), and tortious interference with economic advantage (¶¶
77-82). Plaintiffs’ complaint included a request for 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 accounting and construction trust as to defendants’ proceeds from the
defamatory publications;
d. attorneys’ fees and expenses as allowed by law;
e. costs; and
f. such other relief as the Court deems just and proper.
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All defendants have been served, with the exception of Rense, who has been ducking
service for weeks.
ARGUMENT
I. ENTERING DEFAULT JUDGMENT IS APPROPRIATE.
Plaintiffs have fulfilled the prerequisite for moving for a default judgment by requesting
that the Clerk of this Court enter default against SPI pursuant to Rule 55(a) of the Federal Rules
of Civil Procedure. See Structural Concrete Prod., LLC v. Clarendon America Ins. Co., 244
F.R.D. 317, 328 (E.D. Va. 2007) (recognizing that before the plaintiff can move for default
judgment, the clerk or the court must enter default); R.W. Amrine Drywall, 239 F. Supp. 2d at 30
(accord). The Clerk of the Court entered default against SPI on July 1, 2010. (Dkt. No. 18).
Default judgment should be entered against SPI pursuant to Fed. R. Civ. P. 55(b) because
it failed to plead or otherwise defend this action. R.W. Amrine Drywall, 239 F. Supp. 2d at 30;
Music City Music, et al. v. Alfa Foods, Ltd., 616 F. Supp. 1001, 1002 (E.D. Va. 1985). SPI did
not timely file any answer to the complaint. Fed. R. Civ. P. 12(a)(1)(A)(i) provides that a
defendant shall serve its answer within 21 days of service of the summons and complaint. Here,
the summons and complaint was served on SPI on June 7, 2010. (Dkt. No. 4). SPI’s answer was
thus due on June 28, 2010.
2
However, to date, no answer to the complaint has been filed. SPI’s

2
On June 28, 2010, Sinclair filed a motion for an extension for himself and SPI. (Dkt. No.
14). However, as stated in plaintiffs’ opposition to that motion, Sinclair is not an attorney and
thus cannot represent a corporation pro se. (Dkt. No. 15 at 2). Additionally, Sinclair has
indicated that SPI has been “dissolved” (in an apparent attempt to avoid liability and having to
hire counsel) and that SPI would not be answering the complaint. (Dkt. No. 17 Ex. A).
SPI and Sinclair have also indicated that SPI was not properly served even though it is
undisputed that plaintiffs personally served the summons and complaint on Sinclair, an officer of
SPI. (Dkt. Nos. 4, 17; Exs. 5, 6). Such service is proper under Fed. R. Civ. P. 4(h). See, e.g.,
Cambridge Holdings Group, Inc. v. Federal Ins. Co., 489 F.3d 1356, 1361 (D.C. Cir. 2007)
(Rule 4(h)(1) provides a method for effecting service “by delivering a copy of the summons and
of the complaint to an officer, a managing or general agent, or to any other agent authorized by
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failure to defend is its own decision. As such, plaintiffs should be entitled to a default judgment
against that defendant. Where, as here, a party does not respond to a properly served summons
and complaint, a default judgment, though drastic, is the appropriate and, indeed, only recourse.
See, e.g., In re Knight, 833 F.2d 1515, 1516 (11th Cir. 1987)(where party offers no good reason
for late filing of answer, entry of default judgment appropriate); R.W. Amrine Drywall, 239 F.
Supp. 2d at 30; First City Nat'l Bank of Fort Worth v. Cook, 117 F.R.D. 390 (N.D. Tex. 1987)
(default judgment appropriate where party served has failed to answer).
II. PLAINTIFFS HAVE STATED CLAIMS AGAINST SPI.
A. Defamation
Parisi has pled facts stating a defamatory claim against the defendants, including SPI. In
June 2009, SPI published the false and misleading defamatory statements about Parisi in
Sinclair’s book and promotional statements. The defamatory statements referred to Parisi by
name, were made of and concerning him, and were so understood by those reading the
defamatory statements. SPI made and published the defamatory statements with knowledge of
their falsity or with reckless disregard for their truth. Moreover, the statements were so
excessive, intemperate, unreasonable and abusive as to preclude any conclusion other than SPI
was motivated by actual malice against Parisi.

appointment or by law to receive service of process”); Vax-D Medical Technologies, LLC v.
Texas Spine Medical Center, 485 F.3d 593, 596 (11th Cir. 2007) (service shall be effected by
delivering a copy of the summons and of the complaint to an officer or a managing or general
agent); Larsen v. Mayo Medical Center, 218 F.3d 863, 868 (8th Cir. 2000) (Rule 4(h) “provides
for service on a corporation by delivering a copy of the summons and complaint to an officer,
manager or authorized agent of the corporation.”). Sinclair is an officer of SPI, as registered
with the State of Florida. (Ex. 5 Ex. A). Contrary to SPI and Sinclair’s apparent belief, there is
no legal requirement that a corporation must be served only through its resident agent. Sinclair
and SPI simply have no clue. (Ex. 6).
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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, Parisi is a
pornographer, criminally conspired with Axelrod and the Obama campaign, rigged polygraph
examination results, received improper funds from the Obama campaign or Axelrod, and assisted
Obama to get away with murder. The defamatory statements were not privileged and were
published by the defendants with malice, hatred, contempt and ill will toward Parisi and with the
desire to cause him economic injury, including lost business and opportunities. Indeed, Parisi
has suffered reputational and economic damages.
B. False Light Invasion/Misappropriation of Privacy
The facts pled in the complaint show that the published false defamatory statements
concerning Parisi place him in a false light which would be highly offensive to a reasonable
person and defendants, including SPI, have misappropriated his right to privacy. SPI 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. As a direct and proximate result, Parisi has suffered
economic damages.
C. Business Disparagement
While the first two claims are by Parisi, Whitehouse.com Inc., Whitehouse Network
LLC, and White House Communications Inc. are the plaintiffs for the next two.
SPI knowingly and intentionally published multiple defamatory written statements of fact
to third persons, including, inter alia, that in 2008-09, Whitehouse.com contained pornography
and engaged in unlawful and fraudulent conduct. When these statements were made, SPI had
actual knowledge of the falsity of their statements and had actual serious doubts as to the truth of
their statements, yet made the statements with knowledge of their falsity and in reckless
disregard of the truth. SPI made and disseminated their false statements to multiple third
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parties – including the general public through dissemination via the Internet and the press – in an
effort to impugn the reputation of Whitehouse.com and its owners and management.
The false and defamatory statements made by defendants were made with actual malice,
and are therefore unprivileged. As a direct and proximate result, plaintiffs incurred damages,
including special damages.
D. Tortious Interference with Economic Advantage
Plaintiffs had a valid business relationship or expectancy with respect to the website
Whitehouse.com. SPI was well aware of that relationship or expectancy, yet nevertheless
intentionally interfered with it. As a direct and proximate result of SPI’s wrongful conduct,
plaintiffs are entitled to recover damages.
III. REMEDIES
The default judgment sought does not “differ in kind from, or exceed in amount, what is
demanded in the pleadings.” Fed. R. Civ. P. 54(c). “[A] judgment should give the relief to
which a party is entitled, regardless of whether it is legal or equitable or both.” Adv. Comm.
Notes to Rule 54(c). The Court must determine the amount to be awarded:
A defaulting defendant is deemed to admit every well-pleaded
allegation in the complaint. Although the default establishes a
defendant’s liability, the court is required to make an independent
determination of the sum to be awarded unless the amount of
damages is certain. Moving for a default judgment, the plaintiff
must prove its entitlement to the requested damages. In ruling on
such a motion, the court may rely on detailed affidavits or
documentary evidence to determine the appropriate sum for the
default judgment. Finally, the movant is entitled to all reasonable
inferences from the evidence offered.
R.W. Amrine Drywall, 239 F. Supp. 2d at 30 (citations omitted).
The Complaint seeks a total award of compensatory damages of at least $ 30 million. On
this motion, plaintiffs ask the Court to enter default judgment against SPI for a portion of that
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amount, $5 million. (Ex. 1, Parisi Decl. ¶ 10). The requested award is supported by the attached
declaration of Parisi, who has been engaged in the business of owing and developing domain
names and websites. He been in this market for 14 years and have extensive experience in
buying and selling websites and domains. (Parisi Decl. ¶ 6). 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 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. (Parisi Decl. ¶ 7). In
2004, Microsoft Corporation sold Slate, a politically oriented site, for between $15 million and
$20 million to the Washington Post Co. (Parisi Decl. ¶ 8).
Plaintiffs 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 Parisi’s knowledge of the
industry, plaintiffs have been damaged in the amount of $30,000,000. (Parisi Decl. ¶ 9). Given
SPI’s apparent meager circumstances, a judgment in the amount of $5,000,000 should be
entered.
3
(Parisi Decl. ¶ 10).
In addition, the Court should enter judgment ordering 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. (Parisi Decl. ¶ 11).

3
Plaintiffs do not seek to include any award of punitive damages or costs in the judgment.
Case 1:10-cv-00897-RJL Document 24-1 Filed 07/08/10 Page 13 of 14

- 14 -
CONCLUSION
For the foregoing reasons, plaintiffs respectfully request that their motion for a default
judgment against SPI be granted.
Dated: July 8, 2010 Respectfully submitted,


/s/ Richard J. Oparil
Richard J. Oparil (D.C. Bar No. 409723)
PATTON BOGGS LLP
2550 M Street, NW
Washington, DC 20037
(202) 457-6000
(202) 457-6315 (fax)

Kevin M. Bell
PATTON BOGGS LLP
8484 Westpark Drive
McLean, VA 22102
(703) 744-8000
(703) 744-8001 (fax)

Attorneys for Plaintiffs


5105627
Case 1:10-cv-00897-RJL Document 24-1 Filed 07/08/10 Page 14 of 14
Exhibit 1
Case 1:10-cv-00897-RJL Document 24-2 Filed 07/08/10 Page 1 of 3
--1
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
)
DANIEL PARISI, et ai., )
)
Plaintiffs, )
v. ) Civil Action No. 1O-0897-RJL
)
LAWRENCE W. SINCLAIR alkJa "Larry Sinclair", et ai., )
)
Defendants. )
-------------------)
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. I am currently a citizen of New Jersey but will be moving to the District of
Columbia.
3. Plaintiff, Whitehouse.com Inc., is a New Jersey corporation with its principal
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 2 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
O ~
f ~
Daniel Parisi
- 2 ­
Case 1:10-cv-00897-RJL Document 24-2 Filed 07/08/10 Page 3 of 3
Exhibit 2
Case 1:10-cv-00897-RJL Document 24-3 Filed 07/08/10 Page 1 of 2



BARACK OBAMA & LARRY SINCLAIR: Cocaine, Sex, Lies & Murder?




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Search Request: Left Anchored Copyright Number = txu001647812
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Type of Work: Text
Registration Number / Date: TXu001647812 / 2009-06-23
Application Title: BARACK OBAMA & LARRY SINCLAIR: Cocaine, Sex, Lies & Murder?
Title: BARACK OBAMA & LARRY SINCLAIR: Cocaine, Sex, Lies & Murder?
Description: Electronic file (eService)
Copyright Claimant: Lawrence W Sinclair. Address: 9 Spring Drive, Port Orange, FL, 32129, United States.
Date of Creation: 2009
Authorship on Application: Lawrence W Sinclair, 1961- ; Domicile: United States; Citizenship: United States.
Authorship: text, photograph(s), editing.
Pre-existing Material: text, photographs.
Basis of Claim: text, photographs, editing.
Rights and Permissions: Sinclair Publishing, Inc, 9 Spring Drive, Port Orange, FL, 32129, United States, (386)
761-0606, info@sinclairpublishingllc.com
Copyright Note: C.O. correspondence.
Names: Sinclair, Lawrence W, 1961-
Sinclair, Lawrence W
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Case 1:10-cv-00897-RJL Document 24-3 Filed 07/08/10 Page 2 of 2

Exhibit 3
Case 1:10-cv-00897-RJL Document 24-4 Filed 07/08/10 Page 1 of 3
Sinclair Publishing, Inc
Home About Us Book Exhibits Titles SP, Inc Authors
Wholesale Orders Contact Us
NOTICE
Barack Obama & Larry Sinclair: Cocaine, Sex, Lies & Murder? has TEMPORARILY been removed from the
distribution channels. This action is the result of a baseless Civil Complaint filed in U.S. District Court for
the District of Columbia by the DC Law Firm Patton Boggs, LLP on behalf of Daniel Parisi and
Whitehouse.com (the former internet porn site)
Published June 16, 2010
On June 15, 2010, exactly one year to the day that Barack Obama & Larry Sinclair: Cocaine, Sex, Lies & Murder? was published, our distributor
notified Sinclair Publishing, Inc that the book "...has been temporarily pulled from distribution." Ingram Content Group was served with an identical
civil complaint by Daniel Parisi and Patton Boggs LLP on June 10, 2010. The Cease & Desist letter of the same date from Patton Boggs makes it
clear counsel for the Plaintiff is using the same internet warriors that Paul Levy of Public Citizens Litigation Group used to attack and spread false
claims.
In the Parisi complaint, Richard Oparil of Patton Boggs makes claims that are complete and utter lies:
1. Oparil's claim that Larry Sinclair ever agreed to put Dan Parisi in contact with the limo driver is out right false. This claim, made by Dan Parisi in
Feb 2008 was quickly demonstrated to be an outright LIE.
2. Oparil's claim that Larry Sinclair or the Book Barack Obama & Larry Sinclair: Cocaine, Sex, Lies & Murder? accuses Dan Parisi of being involved
in the cover up of a murder IS AN OUT RIGHT LIE! Nowhere in the book nor anywhere else have Larry Sinclair ever made any such claims in regards
to the murder of Donald Young.
3. Oparil's claim that the polygraph by Edward Gelb was corroborated by another examiner in Gelbs office on Feb 22, 2008 is interesting considering
that Edward Gelb, Dan Parisi and Parisi assistant Robert Braddock ALL stated in Gelb's office on 2-22-2008 that the results of the exam would NOT
BE KNOWN until Monday (2-25-08) at the earliest. So someone is lying here.
4. Whitehouse.com did not shut down in 2008 due to the statements in Larry Sinclair's book, considering the book was not published or available
until June 15, 2009. Whitehouse.com has been scrubbed prior to the filing of this complaint but some very interesting posts have been located that
will show Plaintiffs have out right lied in their complaint.
Larry Sinclair & Sinclair Publishing, Inc will fight Parisi's baseless suit.
Today, June 7, 2010 @ 7:55 PM I was served "Summons in a Civil Action" filed in the United States District Court for the District of Columbia,
"Daniel Parisi, et al, v Lawrence W. Sinclair, et al. Case number 1:10-cv-0897-RJL (the RJL being District Judge Richard J. Leon (left) who the case
was assigned to.
The claims by Parisi in this action are laughable in that he claims he has been slandered by my writing in Barack Obama & Larry Sinclair: Cocaine,
Sex, Lies & Murder? that he was an "internet porn merchant and pornographer."
For any DC Law Firm to attempt to argue Parisi is not a pornographer is laughable. After reading the complaint I can say with confidence Patton
Boggs will NOT prevail and I am making it clear here and now that we will counter sue Parisi and demand all phone, financial, email, web site
comments, posts etc for Parisi, Axelrod, Obama for America, Barack Obama, Edward Gelb, and so much more.
I stand by every word in the book and if anyone has been assaulted, libeled and slandered I believe a jury will find that person to be me, not Parisi.
Dan Parisi & Patton Boggs, LLP Have Filed Suit : Let the Ride and Discovery Begin
Parisi v Sinclair Complaint
Parisi v Ingram Complaint Cease & Desist Ingram
Home http://sinclairpublishingllc.com/
1 of 2 6/18/10 2:19 PM
Case 1:10-cv-00897-RJL Document 24-4 Filed 07/08/10 Page 2 of 3
Obama & Larry Sinclair Left.
Sinclair: Cocaine, Sex, Lies & Murder?
sidelined, Bonnie and Angela find that
Savannah offers more than meets the eye.
When they first arrived at The Magnolias, they
had planned on a nice quiet stay at a
two-hundred-year-old bed and breakfast; not
the eighty-year-old murder of Colonel
Blanchard, the disembodied voice of Hermoine,
and the mysterious melody that is heard by all
of the inn’s guests each midnight. When The
Magnolias’ hostess, Miss Harriet Champion, is
found murdered in the Confederate Room, is it
the ghastly deed of the ghost of Colonel
Blanchard . . . or did Miss Champion stumble
upon a distant secret of one of the inn’s
employees or guests? Amateur sleuth Bonnie
Ferguson feels certain that she can unravel the
mysteries of The Magnolias, the haunting
music, and the murder of Colonel Blanchard.
Her avid sleuthing brings her to Bonaventure
Cemetery, but will she have the courage to
uncover the truth . . . or will unseen forces and
family secrets silence her?
Barack Obama …
Lawrence W Sincl…
$12.91
Showing 1 - 1 of 2
results
Privacy
Barack Obama and Larry Sinclair
1 2 >
affair that led to murder? Would you notify the authorities or would you "let
sleeping dogs lie?" What would you do if you inadvertently caused the death
of an individual? Would you acknowledge the deed or would you withhold
the information?
These are questions that Cathy Billings must answer in the suspense novel,
Go Tell Aunt Rhody: Southern Murder X2.
Cathy, a CNA at Shepherd-of-the-Hills Nursing Home, refinishes furniture in
her garage as a hobby. When her husband, Harry, brings her an old chest of
drawers from south Georgia, what she discovers hidden behind one of the
drawers changes the rest of her life. The discovery of a diary written by a
woman, Lynette, in 1938 reveals a year in the lives of a family in LaFayette,
Georgia and uncovers secret murder. The diary piques Cathy's interest, and
she becomes so obsessed with it, she cannot rest until she has found out
what has happened to Lynette and her family. Aided by her co-worker and
best friend, Gigi, Cathy embarks on a quest that causes her to question her
own values and beliefs. When she finds that Lynette is still living, she is
forced to make decisions that will have a lasting impact, not only the lives of
the family in the diary, but on her own family's lives, as well. Set against the
beautiful backdrops of Chattanooga, Tennessee and LaFayette, Georgia,
Go Tell Aunt Rhody chronicles the journeys of two women, separated by
decades, and the choices that they make when faced with adversity. Each,
guided by the Cosmos, must make her own way into the unknown, despite
the consequences.
Go Tell Aunt R…
Thornton Parsons …
$21.44
Showing 1 - 1 of 1
results
Privacy
Go Tell Aunt Rhody: Southern Murder X2
Home http://sinclairpublishingllc.com/
2 of 2 6/18/10 2:19 PM
Case 1:10-cv-00897-RJL Document 24-4 Filed 07/08/10 Page 3 of 3

Exhibit 4
Case 1:10-cv-00897-RJL Document 24-5 Filed 07/08/10 Page 1 of 4
Case 1:10-cv-00897-RJL Document 24-5 Filed 07/08/10 Page 2 of 4
Case 1:10-cv-00897-RJL Document 24-5 Filed 07/08/10 Page 3 of 4
Case 1:10-cv-00897-RJL Document 24-5 Filed 07/08/10 Page 4 of 4

Exhibit 5
Case 1:10-cv-00897-RJL Document 24-6 Filed 07/08/10 Page 1 of 7
1
2
3
7
8
9
1 0
1 1
12
1 3
1 4
15
16
1 7
1 8
19
20
21
22
23
24
25
Lawrence W. Sinclair, Pro Se
9 Spring Drive
Port Orange, Florida 32129
(386) 506-8912
lsinclair@sinclairpublishingllc.com
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Daniel Parisi, et al,
Plaintiff(s),
) Case No.: 1 :1 0-cv-00897-RJL
)
) Defendant's Opposition To Plaintiff's
) Affidavit for Default
vs.
Lawrence W. Sinclair,et al.,
Defendant(s)
Lawrence W. Sinclair (Defendant) and Sinclair Publishing, Inc do hereby
oppose Plaintiff's AFFIDAVIT IN SUPPORT OF DEFAULT dated June 30, 2010 and
received July 6, 201 0.
Defendant Lawrence W. Sinclair does on behalf of himself and on behalf
of Sinclair Publishing point out that Plaintiff's AFFIDAVIT is knowingly
false as filed with the Clerk of the Court.
Defendant Sinclair Publishing, Inc HAS NOT been properly served by
Plaintiff's as claimed by Plaintiff Counsel Richard Oparil. Sinclair
Publishing, Inc Registered Agent Mary Grasmick and address for service, 1 860
Stella Lane #21 7, Fort Walton Beach, Florida 32548 has never been served any
Complaint by Plaintiff's neither personally nor by mail. (Ex A)
Case 1:10-cv-00897-RJL Document 24-6 Filed 07/08/10 Page 2 of 7
2
3
4
5
6
7
8
9
10
1 1
1 2
1 3
1 4
1 5
1 6
1 7
18
19
20
21
22
23
24
25
Respectfully submitted this 6
th
day of July 2010.
Lawrence W. Sinclair
For Lawrence W. Sinclair &
Sinclair Publishing
9 Spring Drive
Port Orange, FL 321 29
Case 1:10-cv-00897-RJL Document 24-6 Filed 07/08/10 Page 3 of 7
Exhibit A
Case 1:10-cv-00897-RJL Document 24-6 Filed 07/08/10 Page 4 of 7
Electronic Articles of Incorporation P09000032898
For Aprill 3,2009
Sec. Of State
Ipoole
SINCLAIR PUBLISHING INCORPORATED
The undersigned incorporate*, for the purpose of forming a Florida
profit corporation, hereby adopts the following Articles of Incorporation:
Article I
The name of the corporation is:
SINCLAIR PUBLISHING INCORPORATED
Article II
The principal place of business address:
1860 STELLA LANE
#217
FT WALTON BEACH, FL. 32548
The mailing address of the corporation is:
POST OFFICE BOX 4671
FT WALTON BEACH, FL. 32549
Article III
The purpose for which this corporation is organized is:
ANY AND ALL LAWFUL BUSINESS. PUBLISHING OF VARIOUS WRITTEN
WORKS OF FICTION. NON-FICTION, BIOGRAPHICAL. TRUE CRIME AND
POLITICAL HISTORY OF VARIOUS AUTHORS.
Article IV
The number of shares the corporation is authorized to issue is:
200 (100 PERFERRED AND 100 COMMON)
Article V
The name and Florida street address of the registered agent is:
MARY GRASMICK
1860 STELLA LANE
#217
FT WALTON BEACH, FL. 32548
Case 1:10-cv-00897-RJL Document 24-6 Filed 07/08/10 Page 5 of 7
I certify that I am familiar with and accept the responsibilities of P09000032898
registered agent. ApHMS, 2009
Sec. Of State
Registered Agent Signature: MARY GRASMICK 'P°
ole
Article VI
The name and address of the incorporator is:
LAWRENCE W. SINCLAIR
POST OFFICE BOX 4671
FT WALTON BEACH, FLORIDA 32549
Incorporator Signature: LAWRENCE W. SINCLAIR
Article VII
The initial officer(s) and/or director(s) of the corporation is/are:
Title: COB
LAWRENCE W SINCLAIR
POST OFFICE BOX 4671
FT WALTON BEACH, FL. 32549
Title: VP
MARY G GRASMICK
POST OFFICE BOX 4671
FT WALTON BEACH, FL. 32549
Title: VP
C MCARNEY
POST OFFICE BOX 4671
FT WALTON BEACH, FL. 32549
Title: VP
M A URBAN
POST OFFICE BOX 4671
FT WALTON BEACH, FL. 32549
Title: VP
B ILESKOSEK
POST OFFICE BOX 4671
FT WALTON BEACH, FL. 32549
Article VIII
The effective date for this corporation shall be:
04/13/2009
Case 1:10-cv-00897-RJL Document 24-6 Filed 07/08/10 Page 6 of 7
Certificate of Service
I certify that I, Lawrence W. Sinclair, did on this 6
th
day of July, 2010, place postage pre-paid, in
the United States Mail, First Class (and via email a .pdf copy of same) a true and exact copy of
Defendant's Opposition To Plaintiff's Affidavit for Default and Answer in Case No.: l:10-cv-00897-
RJL to the following:
Richard J. Oparil
Patton Boggs LLP
2550 M Street, NW
Washington, D.C. 20037
ROparil@pattonboggs.com
Counsel for Plaintiffs
Cindi Street
Assistant General Counsel
Lightning Source Inc.
One Ingram Blvd
LaVergne, TN 37086
Cindi.Street@ingramcontent.com
Linda Steinman
Davis Wright Tremaine LLP
1633 Broadway, 27th Floor
New York, NY 10019
lindasteinman@dwt.com
Counsel for Defendant's Barnes & Noble; Barnesandnoble.com LLC
Amazon.com Inc
410 Terry Avenue
Seattle, WA 98109
Books-A-Million, Inc
402 Industrial Lane
Birmingham, AL 35211
Lavtfrence
Sinclair Pu
Case 1:10-cv-00897-RJL Document 24-6 Filed 07/08/10 Page 7 of 7

Exhibit 6
Case 1:10-cv-00897-RJL Document 24-7 Filed 07/08/10 Page 1 of 7
Oparil, Richard
From: Oparil, Richard
Sent: Thursday, July 08, 2010 1:13 PM
To: 'Lawrence Sinclair'
Subject: RE: Answer and Defendants Opposition to Default
Page 1 of 6
7/8/2010
Feel free.
From: Lawrence Sinclair [mailto:lsinclair@sinclairpublishingllc.com]
Sent: Thursday, July 08, 2010 1:06 PM
To: Oparil, Richard
Subject: RE: Answer and Defendants Opposition to Default
Mr.Oparil,

MynameisLawrenceSinclairor“Larry”tomyfriendsandfamily,itisnotnownorhasiteverbeen“DUDE!”
YouruseofthistermbringsmebacktophonecallsfromaDCAttorney(soheclaimed)whousedthistermin
addressingme.

OhIhaveaclue,Iknowforafactyourclientisliarandafraud.Yousirwilladdressmebynameornotatall.

Iwillattachyouremailtomynextfilingwiththecourt.

Respectfully,

LawrenceW.Sinclaird/b/a
SinclairPublishing
9SpringDrive
PortOrange,Florida32129
PH386Ͳ506Ͳ8912/866Ͳ966Ͳ6599
www.sinclairpublishingllc.com

DISCLAIMER:
ThiseͲmailmessagecontainsconfidential,privilegedinformationintendedsolelyfortheaddressee.Pleasedo
notread,copy,ordisseminateitunlessyouaretheaddressee.Ifyouhavereceiveditinerror,pleasecallusat
(866)966Ͳ6599andasktospeakwiththemessagesender.Also,wewouldappreciateyourforwardingthe
messagebacktousanddeletingitfromyoursystem.Thankyou.

Case 1:10-cv-00897-RJL Document 24-7 Filed 07/08/10 Page 2 of 7

From: Oparil, Richard [mailto:ROparil@PattonBoggs.com]
Sent: Thursday, July 08, 2010 12:58 PM
To: Lawrence Sinclair
Subject: RE: Answer and Defendants Opposition to Default

Dude, you have no clue.

From: Lawrence Sinclair [mailto:lsinclair@sinclairpublishingllc.com]
Sent: Thursday, July 08, 2010 12:52 PM
To: Oparil, Richard
Subject: RE: Answer and Defendants Opposition to Default
Mr.Oparil:

First,IwillnotagreetoremoveanyoppositiontoyourAffidavit,Iamnotauthorizedtoacceptserviceonbehalf
ofSP,Inc,onlytheregisteredagentis/wasandwewillstandbyourpositionthatyouhavenotproperlyserved
SPI.

Second,youwereaskedtoagreetoanadditional30daysformetoretaincounselandfileananswer,yousir
chosetoshowyourassandrefusetoagreetothatrequest.InsteadyoufiledstatementswiththecourtthatI
havemadenoeffortstoretaincounselwhichstatementisoutrightfalse.

Third,ifyouarestatingthattheclerkenteradefaultJudgmentbeadvisedthatsuchentrywillbeappealed.

Fourth,youcouldhavesavedallpartiesthisbackandforthbysimplyagreeingtotherequestforanadditional
30daystoretaincounselandfileananswer.Insteadyouwantedtoactlikeyouandyourclientaresomehow
aboveus.IamcontinuingtoattempttoretaincounselandasofthistimeIAMSinclairPublishingandIwillnot
sitbackandallowyoutoobtainajudgmentbecauseyoudidnotwanttogiveusreasonabletimetoretain
counselwhileatthesametimeagreeingtogiveotherdefendantsyouthinkyouaregoingtoreachasettlement
withanextensiontofiletheiranswer.

MypostingofnoticesregardingthelegalmakeupofSinclairPublishinginnowayimpliednorindicatedSP
wouldnotfileananswer,yousimplyassumedsuchwherebymakinganassoutofyourself.

Finally,Isuggestyouadviseyourclientastothelegalobligationtopreservealldocumentsandrecords;mostof
whichIcanalreadyshowyourclienthasscrubbed.

Iwillbeoutoftowntillnextweek,andatthattimeIwillprepareandfileamotiontodismiss.InadditionIwill
continuetotryandretaincounsel.

Ibelieveyouwillfindmypositionclear.ThepleadingswerereceivedintheClerk'sofficetoday.Oh,anSPIhas
beendissolved,notjustpurportedtohavebeen.

Respectfully,

LawrenceW.Sinclaird/b/a
SinclairPublishing
9SpringDrive
PortOrange,Florida32129
Page 2 of 6
7/8/2010
Case 1:10-cv-00897-RJL Document 24-7 Filed 07/08/10 Page 3 of 7
PH386Ͳ506Ͳ8912/866Ͳ966Ͳ6599
www.sinclairpublishingllc.com

DISCLAIMER:
ThiseͲmailmessagecontainsconfidential,privilegedinformationintendedsolelyfortheaddressee.Pleasedo
notread,copy,ordisseminateitunlessyouaretheaddressee.Ifyouhavereceiveditinerror,pleasecallusat
(866)966Ͳ6599andasktospeakwiththemessagesender.Also,wewouldappreciateyourforwardingthe
messagebacktousanddeletingitfromyoursystem.Thankyou.

From: Oparil, Richard [mailto:ROparil@PattonBoggs.com]
Sent: Thursday, July 08, 2010 11:07 AM
To: Lawrence Sinclair
Subject: RE: Answer and Defendants Opposition to Default

Mr. Sinclair,

You signeu both of the filings maue ȋnot yet fileu by the CouitȌ on behalf of SPIǡ acting
proseǤ While you have the iight to appeai prose anu iepiesent youiself in youi
peisonal capacityǡ you uo not have the iight to iepiesent SPIǤ You aie not an attoineyǤ
As plaintiffs have pieviously inuicateu ȋBktǤ NoǤ ͳͷ at ʹȌǡ a coipoiation such as SPI
cannot appeai without an attoineyǤ See,e.g.ǡ ʹͻ 0ǤSǤCǤ Ț ͳ͸ͷͶǢ Rowlandv.California
Men'sColonyǡ ͷͲ͸ 0ǤSǤ ͳͻͶǡ ʹͲʹ ȋͳͻͻ͵ȌǢ K.M.A.,Inc.v.Gen.MotorsAcceptanceCorp.ǡ ͸ͷʹ
FǤʹu ͵ͻͺǡ ͵ͻͻ ȋͷth CiiǤ ͳͻͺͳȌǢ Palazzov.GulfOilCorp.ǡ ͹͸Ͷ FǤʹu ͳ͵ͺͳǡ ͳ͵ͺͶǦͺ͸ ȋͳͳth
CiiǤ ͳͻͺͷȌǢ Flynnv.ThibodeauxMasonry,Inc.ǡ ͵ͳͳ FǤ SuppǤ ʹu ͵Ͳǡ ͵͹ ȋBǤBǤCǤ ʹͲͲͶȌǢ
Lennonv.McCloreyǡ ͵ FǤ SuppǤ ʹu ͳͶ͸ͳǡ ͳͶ͸ʹ nǤͳ ȋBǤBǤCǤ ͳͻͻͺȌǤ Theiefoieǡ when they
aie ieceiveu anu fileu by the couitǡ plaintiffs will move to stiike both uocuments as to
SPIǤ Please let me know if you will agiee to withuiaw the poition of these uocuments
peitaining to SPI without foicing us to file a motion anu buiuen the CouitǤ
Fuitheiǡ both filings take the position that seivice of piocess on SPI is ueficient because
plaintiffs peisonally seiveu youǡ an officei of SPIǡ iathei than SPI̵s iesiuent agentǤ The
Feueial Rules of Civil Pioceuuie ȋas well as state lawȌ aie quite cleai that seivice on a
uefenuant coipoiationǡ such as SPIǡ may be maue on an officeiǤ FeuǤ RǤ CivǤ PǤ ͶȋhȌ
pioviuesǡ in ielevant paitǡ thatǣ
0nless feueial law pioviues otheiwise oi the uefenuant̵s
waivei has been fileuǡ a uomestic oi foieign coipoiationǡ oi a
Page 3 of 6
7/8/2010
Case 1:10-cv-00897-RJL Document 24-7 Filed 07/08/10 Page 4 of 7
paitneiship oi othei unincoipoiateu association that is
subject to suit unuei a common nameǡ must be seiveuǣ
ȋͳȌ in a juuicial uistiict of the 0niteu Statesǣ
ȋAȌ in the mannei piesciibeu by Rule ͶȋeȌȋͳȌ foi seiving an
inuiviuualǢ oi
ȋBȌ bydeliveringacopyofthesummonsandofthe
complainttoanofficer,amanagingorgeneralagentǡ oi
any othei agent authoiizeu by appointment oi by law to
ieceive seivice of piocess Ǥ Ǥ Ǥ Ǥ ȏEmphasis auueuǤȐ
See,e.g.,CambridgeHoldingsGroup,Inc.v.FederalIns.Co.ǡ Ͷͺͻ FǤ͵u ͳ͵ͷ͸ǡ ͳ͵͸ͳ
ȋBǤCǤ CiiǤ ʹͲͲ͹Ȍ ȋRule ͶȋhȌȋͳȌ pioviues a methou foi effecting seivice ̶by ueliveiing a
copy of the summons anu of the complaint to an officeiǡ a managing oi geneial agentǡ oi
to any othei agent authoiizeu by appointment oi by law to ieceive seivice of piocess̶ȌǤ
ExǤ A to both of youi filings show that you aie an officei of SPIǤ The piocess seivei̵s
affiuavit aveis that you weie seiveu by hanuǤ Plaintiffs thus piopeily seiveu SPI anu
the Cleik̵s entiy of uefault against SPI ȋBktǤ NoǤ ͳͺȌ was coiiectly issueuǤ Please let me
know if you will agiee to withuiaw the ̶opposition̶ to my affiuavit oi if it will be
necessaiy to move to stiike itǤ
To uateǡ SPI has faileu to timely anu piopeily answei the complaintǤ Youi vaiious
missives iegaiuing the puipoiteu ̶uissolution̶ of SPI inuicateu that the company
woulu not be answeiing the complaintǤ
Finallyǡ I woulu ieminu you thatǡ as a iesult of the litigationǡ you anu SPI aie unuei an
obligation to pieseive all uocumentsǡ infoimation anu mateiial ȋincluuing electionic
infoimationȌ that may leau to the uiscoveiy of eviuenceǤ
Richard J. Oparil
Patton Boggs LLP
2550 M St., NW
Washington, DC 20037
(202) 457-6496 (telephone)
(202) 669-2257 (cell)
(202) 457-6315 (fax)
roparil@pattonboggs.com
From: Lawrence Sinclair [mailto:lsinclair@sinclairpublishingllc.com]
Sent: Tuesday, July 06, 2010 7:14 PM
To: Oparil, Richard; 'Steinman, Linda'
Subject: Answer and Defendants Opposition to Default
Page 4 of 6
7/8/2010
Case 1:10-cv-00897-RJL Document 24-7 Filed 07/08/10 Page 5 of 7
Greetings:

AttachedpleasefindDefendantsANSWERandOppositiontoDefault.

Mr.Oparil,pleasebeverycarefulwhatyoustateinpleadingsfiledwiththeCourt.NeverhaveInorSP,Incnow
knownasLawrenceWSinclairdbaSinclairPublishing,everindicatednorimpliedthatSP,Incwouldnotbefiling
ananswer.Inadditionsir,YounoryourclienthaveproperlyservedSinclairPublishing,Incasclearlynotedon
yourownexhibit.

Respectfully,

LawrenceW.Sinclaird/b/a
SinclairPublishing
9SpringDrive
PortOrange,Florida32129
PH386Ͳ506Ͳ8912/866Ͳ966Ͳ6599
www.sinclairpublishingllc.com

DISCLAIMER:
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notread,copy,ordisseminateitunlessyouaretheaddressee.Ifyouhavereceiveditinerror,pleasecallusat
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DISCLAIMER:
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Please do not read, copy, or disseminate it unless you are the addressee. If you have received it in error,
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This e-mail and all other electronic (including voice) communications from the sender's firm are for
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Page 5 of 6
7/8/2010
Case 1:10-cv-00897-RJL Document 24-7 Filed 07/08/10 Page 6 of 7
This e-mail message contains confidential, privileged information intended solely for the addressee.
Please do not read, copy, or disseminate it unless you are the addressee. If you have received it in error,
please call us (collect) at (202) 457-6000 and ask to speak with the message sender. Also, we would
appreciate your forwarding the message back to us and deleting it from your system. Thank you.
This e-mail and all other electronic (including voice) communications from the sender's firm are for
informational purposes only. No such communication is intended by the sender to constitute either an
electronic record or an electronic signature, or to constitute any agreement by the sender to conduct a
transaction by electronic means. Any such intention or agreement is hereby expressly disclaimed unless
otherwise specifically indicated. To learn more about our firm, please visit our website at
http://www.pattonboggs.com.
Page 6 of 6
7/8/2010
Case 1:10-cv-00897-RJL Document 24-7 Filed 07/08/10 Page 7 of 7

5106334
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

)
DANIEL PARISI, et al., )
)
Plaintiffs, )
v. ) Civil Action No. 10-0897-RJL
)
LAWRENCE W. SINCLAIR a/k/a “Larry Sinclair”, et al., )
)
Defendants. )
)

PROPOSED ORDER GRANTING DEFAULT JUDGMENT
Upon consideration of the plaintiffs’ motion for a default judgment against Sinclair
Publishing, Inc. (“SPI”), and any response thereto, it is hereby
ORDERED that plaintiffs’ motion for a default judgment against SPI is hereby
GRANTED; and it is further hereby
ORDERED, that SPI shall pay to plaintiffs the sum of five million dollars ($5,000,000);
and it is further hereby
ORDERED, that there shall be 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.
SO ORDERED this ________ day of ________________, 2010.


UNITED STATES DISTRICT JUDGE


Case 1:10-cv-00897-RJL Document 24-8 Filed 07/08/10 Page 1 of 1