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  • Parisi V Sinclair: (UNCONFIRMED FILING) Defendant's Opposition To Plaintiff's Emergency Motion To Preserve Discoverable Information..

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    Lewis Clark
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    [UNCONFIRMED FILING] Defendant's Opposition to Plaintiff's Emergency Motion to Preserve Discoverable Information..

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    Parisi v Sinclair: [UNCONFIRMED FILING] Defendant's Opposition to Plaintiff's Emergency Motion to Preserve Discoverable Information..

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    [UNCONFIRMED FILING] Defendant's Opposition to Plaintiff's Emergency Motion to Preserve Discoverable Information..

    Copyright:

    Attribution Non-Commercial (BY-NC)
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    237 views19 pages

    Parisi V Sinclair: (UNCONFIRMED FILING) Defendant's Opposition To Plaintiff's Emergency Motion To Preserve Discoverable Information..

    Uploaded by

    Lewis Clark
    [UNCONFIRMED FILING] Defendant's Opposition to Plaintiff's Emergency Motion to Preserve Discoverable Information..

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF or read online from Scribd
    Flag for inappropriate content
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    10 12 13 16 vv 18 19 2 22 23 24 Lawrence W. Sinclair Wb/a Sinclair Publishing Post Office Box 1963 Washington, DC 20013 386-506-8912 |sinclain@sinclairpublishinglle.com THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA. DANIEL PARISI, et al., Plaintiff's, vs Case No.: 1:10-ev-00897-RJL LAWRENCE W. SINCLAIR, et al., Defendant's 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 LAWRENCE W. 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: 1, Plaintiffs’ counsel Richard Oparil has filed a completely unnecessary Motion before this Honorable Court based on conjecture and lacking in facts. 2. Plaintiff’ counsel Richard Oparil claims Defendants’ Sinclair has and/or is destroying “Globe Magazines” plaintiffs” claim are discoverable evidence. Mr. Oparil has LIED Opposition to Plaintiffs Emergency Motion - 1 in making this claim. The Globe Magazines ate ii 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 Parcel Service or FedEx, but NOT by email. 4, Plaintiffs’ counsel Richard Oparil in his motion and his “Declaration” states “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. 5. 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 Plaintifts? 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 Whitchouse.com today September 10, 2010) (Exhibit 2 Whitehouse.com February 2008 before Opposition to Plaintiffs Emergency Motion — 10 u 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 afier 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.” CONCLUSION 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. PlaintiflS’ counsel must identify specifically what he intends to requests in discovery. Plaintiffs have as is documented by more than 2 years on the intemet destroyed evidence and internet articles that they themselves 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, Opposition to Plaintiffs Emergency Motion - ” 18 1g 20 21 22 23 24 25 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" day of September 2010. Lawrence W. Sinclair, Pro Se On Behalf of Lawrence W. Sinclair and Former Sinclair Publishing, Inc. NOW Lawrence W. Sinclaii d/b/a Sinclair Publishing Post Office Box 1963 Washington, DC 20013 Opposition to Plaintiffs Emergency Motion - 4 10 ul 12 4 1s 16 17 18 19 24 25 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 Cour’s electronic filing system upon: Richard J Oparil and Kevin M. Bell of Patton Boggs LLP, attorneys for plaintiffs; Stephen 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 attorneys for Defendant Bames & Noble, Inc. ‘The undersigned further certifies that the foregoing was delivered via email on September 11, 2010 at 12:25 AM on the following: : delivery via dwt.com.maill.psmtp.com[64.18.4.10}:25 250 Thanks : delivery via pattonboggs.com.inbound15.mxlogic.net{208,65,144.13]:25: 250 Backend Replied [de50b8c4.0.89482,00-2377.108826.p02clim023.mxlogic.net]: 2.0.0 8B 4Udal006852 Message accepted for

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