Ms. James: On top of everything else, we will need to blow the SDNY whistle tomorrow morning on wire fraud.
Thank you for your continued service. Gunnar Larson -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Thu, Nov 7, 2024, 3:48 AM Gunnar Larson <[email protected]> wrote: > Attorney General James: > > A republican innovator like Gunnar Larson is proud of the election > results. > > However, Ms. James, you saw our research on One Million Black Women > recently. > > Word has it, Ms. Harris is part of a group of co-conspirators behind this > all. > > Personally, I will be forced to engage the tactics below if you, Ms. > James, do not solve One Million Black Women's sponsored discrimination by > Ms. Harris. > > Warm regards, > > Gunnar Larson ✌️ > > ---------- Forwarded message --------- > From: Gunnar Larson <[email protected]> > Date: Thu, Oct 31, 2024, 1:19 PM > Subject: 492 Highlights to UNITED STATES DISTRICT COURT SOUTHERN DISTRICT > OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. > HILLARY R. CLINTON, et al., Defendants. ____________________ > To: cypherpunks <[email protected]> > > > > March 24, 2022 > > 15 Highlights: > https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=drivesdk > > 1. In the run-up to the 2016 Presidential Election, Hillary Clinton and > her cohorts > orchestrated an unthinkable plot – one that shocks the conscience and is > an affront to this nation’s democracy. Acting in concert, the Defendants > maliciously conspired to weave a false narrative that their Republican > opponent, Donald J. Trump, was colluding with a hostile foreign > sovereignty. > The actions taken in furtherance of their scheme—falsifying evidence, > deceiving law enforcement, and exploiting access to highly-sensitive data > sources - are so outrageous, subversive and incendiary that even the events > of Watergate pale in comparison. > > 2. Under the guise of ‘opposition research,’ ‘data analytics,’ and other > political > stratagems, the Defendants nefariously sought to sway the public’s trust. > They worked together with a single, self-serving purpose: to vilify Donald > J. Trump. Indeed, their far-reaching conspiracy was designed to cripple > Trump’s bid for presidency by fabricating a scandal that would > be used to trigger an unfounded federal investigation and ignite a media > frenzy. > > 3. The scheme was conceived, coordinated and carried out by top-level > officials at the > Clinton Campaign and the DNC—including ‘the candidate’ herself—who > attempted to shield her involvement behind a wall of third parties.1 To > start, the Clinton Campaign and the DNC enlisted the assistance of their > shared counsel, Perkins Coie, a law firm with deep Democrat ties, in the > hopes of obscuring their actions under the veil of attorney-client > privilege. Perkins Coie was tasked with spearheading the scheme to find—or > fabricate—proof of a sinister link between Donald J. Trump and Russia. > > To do so, Perkins Coie launched parallel operations: on one front, Perkins > Coie partner Marc Elias led an effort to produce spurious ‘opposition > research’ claiming > to reveal illicit ties between the Trump Campaign and Russian operatives; > on a separate front, Perkins Coie partner Michael Sussmann headed a > campaign to develop misleading evidence of a bogus ‘back channel’ > connection between e-mail servers at Trump Tower and a Russian-owned > bank. > > 4. Marc Elias, in his mission to obtain derogatory anti-Trump ‘opposition > research,’ commissioned Fusion GPS, an investigative firm, and its > co-founders, Peter Fritsch and Glenn Simpson, and directed them to dredge > up evidence—actual or otherwise—of collusion between Trump and Russia. > Fritsch and Simpson, in turn, enlisted the assistance of Orbis Ltd. and its > owner, Christopher Steele, to produce a series of reports purporting to > contain proof of the > supposed collusion. Of course, the now fully debunked collection of > reports, known as the “Steele Dossier,” was riddled with misstatements, > misrepresentations and, most of all, flat out lies. In truth, the Steele > Dossier was largely based upon information provided to Steele by his > primary > sub-source, Igor Danchenko, who was subsequently indicted for falsifying > his claims. Even more damning, Danchenko had close ties to senior Clinton > Campaign official, Charles Halliday Dolan, Jr., who knowingly provided > false information to Danchenko, who relayed it to Steele, who > reported it in the Steele Dossier and eagerly fed the deceptions to both > the media and the FBI. This duplicitous arrangement existed for a singular > self-serving purpose – to discredit Donald J. Trump > and his campaign. > > 5. At the same time, Michael Sussmann, in his hunt for damaging intel > against the > Trump Campaign, turned to Neustar, Inc., an information technology > company, and one of its top executives, Rodney Joffe, a fervent > anti-Trumper who had recently been promised a high-ranking position with > the Clinton Administration, to exploit their access to non-public data in > search of a > secret “back channel” connection between Trump Tower and Alfa Bank. When > it was discovered that no such channel existed, the Defendants resorted to > truly subversive measures – hacking servers at Trump Tower, Trump’s private > apartment, and, most alarmingly, the White House. This > ill-gotten data was then manipulated to create a misleading “inference” > and submitted to law enforcement in an effort to falsely implicate Donald > J. Trump and his campaign.2 All of these acts > were carried out in coordination with the Clinton Campaign and the DNC, at > the behest of certain Democratic “VIPs.”3 > > 6. While their multi-pronged attack was underway, the Defendants seized on > the > opportunity to publicly malign Donald J. Trump by instigating a full-blown > media frenzy. Indeed, the Clinton Campaign and DNC—admittedly on a > “mission” to “raise the alarm” about their contrived Trump-Russia > link4—repeatedly fed disinformation to the media and shamelessly > promoted their false narratives. All the while, Hillary Clinton, Jake > Sullivan, Debbie Wasserman Schultz, and others did their best to > proliferate the spread of those dubious and false claims through > press releases, social media, and other public statements. > > 7. The fallout from the Defendants’ actions was not limited to the public > denigration > of Trump and his campaign. The Federal Bureau of Investigation > (FBI)—relying on the Defendants’ fraudulent evidence—commenced a > large-scale investigation and expended precious time, resources and > taxpayer dollars looking into the spurious allegation that the Trump > Campaign > had colluded with the Russian Government to interfere in the 2016 > presidential election. The effects of this unfounded investigation were > prolonged and exacerbated by the presence of a small faction of Clinton > loyalists who were well-positioned within the Department of Justice and the > FBI > – James Comey, Andrew McCabe, Peter Strzok, Lisa Page, Kevin Clinesmith, > and Bruce Ohr. These government officials were willing to abuse their > positions of public trust to advance the baseless probe to new levels, > including obtaining an extrajudicial FISA warrant and instigating the > commencement of an oversight investigation headed by Special Counsel > Robert Mueller. As a result, Donald J. Trump and his campaign were forced > to expend tens of millions of dollars in legal > fees to defend against these contrived and unwarranted proceedings. > Justice would ultimately prevail – following a two-year investigation, > Special Counsel Mueller went on to exonerate Donald J. Trump and his > campaign with his finding that there was no evidence of collusion with > Russia. > > 8. The full extent of the Defendants’ wrongdoing has been steadily and > gradually exposed by Special Counsel John Durham, who has been heading a > DOJ investigation into the origins of the Trump-Russia conspiracy. To date, > he has already issued indictments to Sussmann and Danchenko, among others, > for proffering false statements to law enforcement officials. As > outlined below, these ‘speaking’ indictments not only implicate many of > the Defendants named herein but also provide a great deal of insight into > the inner-workings of the Defendants’ conspiratorial enterprise. Based on > recent developments and the overall direction of Durham’s > investigation, it seems all but certain that additional indictments are > forthcoming. > > 9. In short, the Defendants, blinded by political ambition, orchestrated a > malicious > conspiracy to disseminate patently false and injurious information about > Donald J. Trump and his campaign, all in the hopes of destroying his life, > his political career and rigging the 2016 Presidential Election in favor of > Hillary Clinton. When their gambit failed, and Donald J. Trump > was elected, the Defendants’ efforts continued unabated, merely shifting > their focus to undermining his presidential administration. Worse still, > the Defendants continue to spread their vicious lies to this day as they > unabashedly publicize their thoroughly debunked falsehoods in an > effort to ensure that he will never be elected again. The deception, > malice, and treachery > perpetrated by the Defendants has caused significant harm to the American > people, and to the Plaintiff, Donald J. Trump, and they must be held > accountable for their heinous acts. > > ____________________ > > > BACKGROUND > > September 8, 2022 > > 190 Highlights: > https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=drivesdk > > Plaintiff initiated this lawsuit on March 24, 2022, alleging that “the > Defendants, blinded by political ambition, orchestrated a malicious > conspiracy to disseminate patently false and injurious > information about Donald J. Trump and his campaign, all in the hopes of > destroying his life, his political career and rigging the 2016 Presidential > Election in favor of Hillary Clinton.” (DE 177, Am. Compl. ¶ 9). On this > general premise, Plaintiff brings a claim for violations of the Racketeer > Influenced and Corrupt Organizations Act (“RICO”), predicated on the theft > of trade secrets, obstruction of justice, and wire fraud (Count I). He > additionally brings claims for: injurious falsehood (Count III); malicious > prosecution (Count V); violations of the Computer Fraud and Abuse Act > (“CFAA”) (Count VII); theft of trade secrets under the Defend Trade Secrets > Act of > 2016 (“DTSA”) (Count VIII); and violations of the Stored Communications > Act (“SCA”) (Count IX). The Amended Complaint also contains counts for > various conspiracy charges and theories of agency and vicarious liability. > (Counts II, IV, VI, and X–XVI). Plaintiff’s theory of this case, set forth > over 527 paragraphs in the first 118 pages of the Amended Complaint, is > difficult to summarize in a concise and cohesive manner. > > It was certainly not presented that way. Nevertheless, I will attempt to > distill it here. > The short version: Plaintiff alleges that the Defendants “[a]cting in > concert . . . maliciously conspired to weave a false narrative that their > Republican opponent, Donald J. Trump, was colluding with a hostile foreign > sovereignty.” (Am. Compl. ¶ 1). The Defendants effectuated this > alleged conspiracy through two core efforts. “[O]n one front, Perkins Coie > partner Mark Elias led an effort to produce spurious ‘opposition research’ > claiming to reveal illicit ties between the Trump > campaign and Russian operatives.” (Id. ¶ 3). > > To that end, Defendant Hillary Clinton and her campaign, the Democratic > National Committee, and lawyers for the Campaign and the Committee > allegedly hired Defendant Fusion GPS to fabricate the Steele Dossier. (Id. > ¶ 4). “[O]n a separate > front, Perkins Coie partner Michael Sussman headed a campaign to develop > misleading evidence of a bogus ‘back channel’ connection between e-mail > servers at Trump Tower and a Russian- > owned bank.” (Id.). Clinton and her operatives allegedly hired Defendant > Rodney Joffe to exploit his access to Domain Name Systems (“DNS”) data, via > Defendant Neustar, to investigate and > ultimately manufacture a suspicious pattern of activity between > Trump-related servers and a Russian bank with ties to Vladimir Putin, Alfa > Bank. (Id. ¶ 3). As a result of this “fraudulent evidence,” the Federal > Bureau of Investigations (“FBI”) commenced “several large-scale > investigations,” which were “prolonged and exacerbated by the presence of a > small faction of > Clinton loyalists who were well-positioned within the Department of > Justice”—Defendants James Comey, Andrew McCabe, Peter Strzok, Lisa Page, > Kevin Clinesmith, and Bruce Ohr. (Id. ¶ 7). > And while this was ongoing, the Defendants allegedly “seized on the > opportunity to publicly malign Donald J. Trump by instigating a full-blown > media frenzy.” (Id. ¶ 6). As a result of this “multi-pronged attack,” > Plaintiff claims to have amassed $24 million in damages.1(Id. ¶ 527). > > Defendants now move to dismiss the Amended Complaint as “a series of > disconnected political disputes that Plaintiff has alchemized into a > sweeping conspiracy among the many individuals Plaintiff believes to have > aggrieved him.” (DE 226 at 1). They argue that dismissal is > warranted because Plaintiff’s claims are both “hopelessly stale”—that is, > foreclosed by the applicable statutes of limitations—and because they fail > on the merits “in multiple independent respects.” (Id. at 2). As they view > it, “[w]hatever the utilities of [the Amended Complaint] as a fundraising > tool, a press release, or a list of political grievances, it has no merit > as a lawsuit.” (Id.). > > I agree. In the discussion that follows, I first address the Amended > Complaint’s structural deficiencies. I then turn to subject matter > jurisdiction and the personal jurisdiction arguments raised by certain > Defendants. Finally, I assess the sufficiency of the allegations as to each > of the > substantive counts. > > ____________________ > > BACKGROUND > > October 31, 2022 > > 25 Highlights: > https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=drivesdk > > > PlaintifP’s pleadings and theories were obviously and fatally defective > from the very > inceptionof this action. Plaintiff's initial Complaint spanned 108 pages > and S08 paragraphs. DE 1 (March 24, 2022). It named 28 individual > defendants, as well as 10 John Does and 10 ABC Corporations. /d. > Less than a month after the Complaint was filed, Hillary Clinton moved to > dismiss it with prejudice. DE 52 (Apr. 20,2022). Defendant Clinton’s motion > identified manyofthe fundamentalfactual deficiencies and legal flaws that > would ultimately lead this Court to dismiss the Amended > Complaint: namely, (1) that Plaintifs claims were untimely on their face, > DE 52 at 1-5; (2) that Plaintiff's own tweets confirmed his knowledge ofhis > supposed claimsno later than October 2017, DE 52 at 2-3; (3) that > Plaintiffs Complaint was replete with inadequate and conclusory > allegations, DE 52 at 6; (4) that Plaintiff failed to allege a RICO > enterprise, DE 52 at 7; (5) that > Plaintiff failed to allege the predicate act of theft of trade secrets > based on DNS information, DE 52 at 8-9; (6) thatPlaintifffailedtoallege the > predicate act ofobstructionofjustice in part because > he identified no “official proceeding,” DE 52 at 9-10; (7) that Plaintiff > failed to allege a patter of racketeering activity, DE 52 at 11-12; (8) > that Plaintiff failed to adequately allege RICO standing because his > supposed injuries were almostentirely undescribed, DE 52.at 12-14; (9) > that Plaintiffs injurious falsehood claim was barred by the First > Amendment, DE 52 at 15-17; (10) that Plaintiff failed to allege almost > every necessary clementof injurious falsehood under Florida law, DE 52 at > 17-18; (11) that Plaintiff failed to allege a malicious prosecution claim > as to any official proceeding and, in particular, as to the properly > predicated Crossfire Hurricane investigation, DE 52 at 19-20; and (12) that > Plaintiff failed to allege a claim for “agency” because it is not an > independent cause of action under Florida law. > > In response, Plaintiff's counsel indicated that they planned to amend the > Complaint. DE 66 (Apr. 21, 2022). Defendant Clinton did not oppose > counsel's request for an extension of time in whichto amend. See, e.g., DE > 102 (Apr. 27,2022). In the intervening period, other Defendants > joined Clinton's motion to dismiss and filed their own motions > alertingPlaintiff and his counsel to additional fatal defects in the > Complaint. See DE 124 (John Podesta), 139 (Peter Fritsch, Fusion GPS, Glenn > Simpson); 141 (DNC Services Corporation, Democratic National Committee, > Debbie Wasserman Schultz); 143 (Perkins Coie); 144 (Nellie Ohr); 145 (Robby > Mook): 146 (Michael > Sussmann); 147 (Mare Elias); 149 (HFACC); 157 (Rodney Joffe); 159 (Igor > Danchenko); 160 (Neustar, Inc.); 162 & 163 (Charles Halliday Dolan, Jr.); > 165 (Jake Sullivan). With respect to each motion, Plaintiff's counsel > indicated that they planned to amend in response to the motions, and > Defendants did not oppose extensionsof time to allow them to do so. See DE > 153 (May 17,2022). PlaintifP’s counsel filed the Amended Complaint > approximately two months after receiving Defendant Clinton’s motion to > dismiss and with the benefit of Defendants” additional motions in > the interim. DE 177 (June 21, 2022). “But despite this briefing, > PlaintifPs Amended Complaint failed to cureanyofthe deficiencies.”DE 267 at > 63-64 (Sept. 8, 2022) (“0p.”). “Instead, Plaintiff added eighty new pages > of largely irrelevant allegations that did nothing to salvage the legal > sufficiency of his claims.” Op. at 64. The Amended Complaint is “193 pages > in length, with 819 numbered paragraphs,” and “contains 14 counts, names 31 > defendants, 10 “John Does” described as fictitious and unknown persons, and > 10 *ABC Corporations’ identified as fictitious and > unknown entities.” Op. at 4. > ____________________ > > BACKGROUND > > November 10, 2022 > > 66 Highlights: > https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=drivesdk > > The Complaint. In March 2022, Charles Dolan was among 29 defendants > initially sued by Mr. Trump. (DE 1). He was identified as a former chairman > of the DNC, a senior official in the Clinton Campaign, and a close > associate of and advisor to Hillary Clinton. The Complaint alleged > that in April 2016, Mr. Dolan participated in discussions about the > creation of a “dossier” to smear Mr. Trump and disseminate false > accusations to the media (Compl. ¶ 79), and at the direction of > Ms. Clinton assisted in preparation of the dossier (Compl. ¶ 81). > According to the Complaint, an allegation contained within the dossier that > Mr. Trump engaged in salacious sexual activity in a > Moscow hotel was derived from Mr. Dolan. (Compl. ¶ 91). Mr. Dolan was sued > for RICO > conspiracy (Count II), conspiracy to commit injurious falsehood (Count > IV), and conspiracy to > commit malicious prosecution (Count VI). > > The Warning Letter. On May 31, 2022, counsel for Mr. Dolan wrote the > attorneys for Mr. Trump. They warned: > > 1. That Mr. Dolan had no role in any conspiracy related to the Steele > dossier. > > 2. That Mr. Dolan was not a source for the allegations of sexual activity. > > 3. That Mr. Dolan had not been in contact with any defendant other than > Igor Danchenko, > and that Mr. Dolan’s contacts with Mr. Danchenko involved business > interests and help for a conference in Moscow. > > 4. That Mr. Dolan had never been chairman of the DNC. > > 5. That Ms. Clinton was on record through a spokesperson as stating she > had no recollection of Mr. Dolan. > (DE 268-1). > > The letter requested that Mr. Dolan not be named as a defendant in any > forthcoming > Amended Complaint. The letter further warned that if he were to be named, > or if he was not dropped from the original Complaint, Rule 11 sanctions > would be sought. > > The Amended Complaint. On June 21, 2022, Plaintiff filed an Amended > Complaint, as > had been expected. It ballooned to 193 pages, 819 paragraphs and 31 > defendants. With respect to Mr. Dolan, the allegations remained essentially > the same. But in the Amended Complaint, Mr. Dolan was identified somewhat > more vaguely as the former chairman of a “national Democratic > political organization.” (Am. Compl. ¶ 96). Elsewhere, he was described as > a “senior Clinton Campaign Official.” (Am. Compl. ¶ 4). Moreover, and > somewhat inexplicably, Mr. Dolan was identified in the Amended Complaint as > a citizen and resident of New York, despite a declaration that Mr. Dolan > had provided to Plaintiff’s lawyers explaining that Mr. Dolan was a > resident of > Virginia. (Am. Compl. ¶ 20; DE 268-2). > The Sanctions Motion and Memorandum. On July 15, 2022, Mr. Dolan served on > Mr. > Trump’s lawyers a motion seeking sanctions pursuant to Rule 11. The motion > pointed out that the change in Mr. Dolan’s purported title from “former > chairman of the DNC” in the original Complaint to “former chairman of a > national Democratic political organization,” in the Amended Complaint did > not solve the problems identified in the warning letter because Mr. Dolan > had never > been the chairman of any such organization. The motion further explained > that Mr. Dolan’s role in the Clinton Campaign was limited to knocking on > doors as a volunteer. The motion also stated > that Mr. Dolan had never been a resident of New York, that Mr. Dolan had > told Plaintiff’s lawyers so, and that the allegations of the Amended > Complaint to that effect demonstrated a lack of diligence over something > easily checked. > > Mr. Dolan’s motion for sanctions went on to place the Trump lawyers on > notice of a critical failure in their claims, warning them that the > Danchenko Indictment referenced throughout the Amended Complaint not only > failed to support their allegations against Mr. Dolan but contradicted > them. That warning continues to be unheeded. > > ____________________ > > BACKGROUND > > January 19, 2023 > > 53 Highlights: > https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=drivesdk > > Plaintiff initiated this lawsuit on March 24, 2022, alleging that “the > Defendants, blinded by political ambition, orchestrated a malicious > conspiracy to disseminate patently false and injurious information about > Donald J. Trump and his campaign, all in the hope of destroying his life, > his > political career, and rigging the 2016 Presidential Election in favor of > Hillary Clinton.” (DE 1 ¶ 9). > > The next day, Alina Habba, Mr. Trump’s lead counsel told Fox News’ Sean > Hannity: > You can’t make this up. You literally cannot make a story like this up . . > . and President Trump is just not going to take it anymore. If you are > going to make up lies, if you are going to try to take him down, he is > going to fight you back. And that is what this is, this is the beginning of > all that.1 She then explained on Newsmax: What the real goal [of the suit] > is, is democracy, is continuing to make sure that our elections, continuing > to make sure our justice system is not obstructed by political enemies. > That cannot happen. And that’s exactly what happened. They obstructed > justice. They > continued the false narrative . . . This grand scheme, that you could not > make up, to take down an opponent. That is un-American.2 > On April 20, 2022, less than a month after the Complaint was filed, > Hillary Clinton moved for dismissal with prejudice. Her motion identified > substantial and fundamental factual and legal flaws. Each of the other > Defendants followed suit, pointing to specific problems with the claims > against them. The problems in the Complaint were obvious from the start. > They were identified by the Defendants not once but twice, and Mr. Trump > persisted anyway. > > Despite this briefing and the promise “to cure any deficiencies,” > Plaintiff’s counsel filed the Amended Complaint on June 21, 2022. (DE 177). > The Amended Complaint failed to cure any of the defects. See DE 267, Order > of Dismissal (September 8, 2022). Instead, Plaintiff added > eighty new pages of largely irrelevant allegations that did nothing to > salvage the legal sufficiency of his claims. (DE 267 at 64). The Amended > Complaint is 193 pages in length, with 819 numbered paragraphs, and > contains 14 counts, names 31 defendants, 10 John Does described as > fictitious and unknown persons, and 10 ABC Corporations identified as > fictitious and unknown entities. > > On July 14, 2022, the United States moved pursuant to the Westfall Act, 28 > U.S.C. § 2679 (d)(i), to substitute itself as Defendant for James Comey, > Andrew McCabe, Peter Strzok, Lisa Page, and Kevin Clinesmith. (DE 224). On > July 21, 2022, I granted the motion to substitute. (DE 234). > > On September 8, 2022, I dismissed the case with prejudice as to all > Defendants except for the United States. > > 3 I issued a detailed and lengthy Order, which I incorporate by reference > here. > (DE 267). I found that fatal substantive defects which had been clearly > laid out in the first round of briefing, precluded the Plaintiff from > proceeding under any of the theories presented. I found that the Amended > Complaint was a quintessential shotgun pleading, that its claims were > foreclosed by existing precedent, and its factual allegations were > undermined and contradicted by the public reports and filings upon which it > purported to rely. I reserved jurisdiction to adjudicate issues > pertaining to sanctions. > > Undeterred by my Order and two rounds of briefing by multiple defendants, > Ms. Habba > continued to advance Plaintiff’s claims. In a September 10, 2022, > interview with Sean Hannity, the host asked her “Why isn’t [Hillary > Clinton] being held accountable for what she did?” Ms. Habba’s response > reiterated misrepresentations on which this lawsuit was based: > > Because when you have a Clinton judge as we did here, Judge Middlebrooks > who I had asked to recuse himself but insisted that he didn’t need to, he > was going to be impartial, and then proceeds to write a 65-page scathing > order where he basically ignored every factual basis which was backed up by > indictments, by investigations, the Mueller report, et cetera, et cetera, > et cetera, not to mention Durham, and all the testimony we heard there, we > get dismissed. > Not only do we get dismissed, he says that this is not the proper place > for recourse for Donald Trump. He has no legal ramifications. > > Where what [sic] is the proper place for him? Because the FBI won’t help > when you can do anything, obstruct justice, blatantly lie to the FBI, > Sussmann’s out, he gets acquitted, where do you go? > > That’s the concern for me, where do you get that -- that recourse?4 She > also indicated that, while Mr. Trump doubted the suit would succeed, she > nevertheless “fought” to pursue it: You know, I have to share with you a > story, Sean, that I have not > shared with anybody. The recourse that I have at this point is obviously > to appeal this to the 11th Circuit as Gregg said. But when > I brought this case and we were assigned you know, this judge and we went > through the recusal process, we lost five magistrates, including Reinhart > [sic] who’s dealing with the boxes as we know. > The former president looked at me and he told me, you know what Alina. > You’re not going to win. You can’t win, just get rid of it, > don’t do the case. And I said, no, we have to fight. It’s not right what > happened. And you know, he was right, and it’s a sad day for > me personally because I fought him on [it] and I should have listened, but > I don’t want to lose hope in our system. I don’t. So, > you know I’m deciding whether we’re going to appeal it.5 Defendants now > move to recover attorneys’ fees and costs under Fed. R. Civ. P. 11, 28 > U.S.C. § 1927, the Defend Trade Secrets Act, and/or this Court’s inherent > power. (DE 280 at 1). > In Part II, I find that a sanction under this Court’s inherent power is > appropriate. I do so by examining Plaintiff’s (and his lawyers’) conduct > throughout this litigation. In Part III, I look to Plaintiff’s conduct in > other cases. And in Part IV, I determine the reasonableness of Defendants’ > attorneys’ fees and costs. > > >
