1 Lawrence W.

Sinclair, Pro Se
9 Spring Drive
2 Port Orange, Florida 32129
(386) 506-8912
3 Isinclairgsinclairpublishingllc.com

4
UNITED STATES DISTRICT COURT
5 FOR THE DISTRICT OF COLUMBIA

7 Daniel Parisi, et al., ) CIVIL ACTION NO. 1 : 10-CV-00897-RJL

8 Plaintiff's, ) Defendant's Lawrence W. Sinclair &

) Sinclair Publishing Response to
9 vs. ) Plaintiff's Opposition

10 Lawrence W. Sinclair, a/k/a "Larry )

11 Sinclair" et al . , )

12 Defendants .

13

14 Defendants, Lawrence W. Sinclair and Sinclair Publishing (one and the

15 same) (Ex. A)(Defendant's) respond to the blatantly false assertions in

16 PLAINTIFFS' RESPONSE TO MOTION FOR EXTENSION OF TIME TO FILE ANSWER filed in

this court on June 29, 2010.

18 ARGUMENT

19 Plaintiff's case was filed on May 28, 2010 alleging "defamatory"

20 statements by Defendants in the Book, Barack Obama & Larry Sinclair: Cocaine,

21 Sex, Lies & Murder? Published June 15, 2009. The Statute of Limitations on

22 Slander/Defamation is "two years from the time the statements became known..."

23 Plaintiff's by their own admission in an internet posting on

24 www.whitehouse.com dated February 26, 2008 (Ex. B) acknowledge they were

25 aware of the "alleged" defamatory statements on or before February 26, 2008;

some sixteen (16) months prior to the publication of the book Barack Obama &

Response to Plaintiffs Opposition - 1

 1 Larry Sinclair: Cocaine, Sex, Lies & Murder? and March 17, 2008 Globe

2 Magazine Article (Ex. C) where "alleged" defamatory statements were also

3 published in addition to Larry Sinclair blogs throughout late February 2008

4 to date.

5 Plaintiff's counsel, Richard Oparil, did knowingly file a dishonest

6 statement with this court in his "OPPOSITION & EXHIBITS" in claiming

defendant's "On June 29, one day after their answer was due, Sinclair and SPI

filed a motion to extend." Plaintiff's counsel was sent defendants Motion

dated June 19, 2010 post marked June 21, 2010 just as this Court and other
9
defendants were. Plaintiff's counsel was also sent by email the PDF of said
10
motion and received it on June 20, 2010 as well as READ it on June 20, 2010.
11
Defendants did on June 25, 2010 resend said MOTION via United States Postal
12 Service Express Mail overnight after the Case Administrator claimed the

13 original MOTION mailed June 21, 2010 had not yet been received by the Court.

14 This copy of the MOTION For Extension of Time to File Answer was delivered to

the Clerk of The United States District Court for the District of Columbia at

12:02 PM Monday June 28, 2010; whereby making said MOTION timely filed.
16
(Ex.D)
17

18
Plaintiff's continued use of this court to identify Defendant Lawrence
19
W. Sinclair as a convicted criminal is representative of plaintiff's mindset,
20 Plaintiff's counsel may wish to however be honest with its pleadings before
21 this court. Contrary to Plaintiff's claims and exhibits of a Politico.com

22 article written by Ben Smith, defendant Sinclair disclosed his past history

23 long before any "private investigators for Public Citizen Litigation Group

uncovered..." it. (Ex. E)

24

25

Response to Plaintiffs Opposition - 2

 1 Defendant's have actively sought to retain counsel in this matter and

2 will have no problem providing this court with documentation to that effect.

T However, defendant's will not agree to disclose the names of firms or

individuals contacted to plaintiff's as plaintiff Parisi has a history of

using information to cause attorneys to be contacted and harassed for having

5
contact with Defendant. Plaintiff did on February 23, 2008 threaten
6
defendant Sinclair in an attempt to obtain copies of emails between defendant
7
Sinclair and California attorney Gloria Allred.

Defendant Lawrence W. Sinclair a/k/a "Larry Sinclair" and Defendant

9 Sinclair Publishing, Inc are effective June 29, 2010 one in the same.

10 Sinclair Publishing, Inc has been dissolved. In addition, should plaintiff's

11 continue to argue that Sinclair Publishing, Inc could not be represented in

defendants MOTION For EXTENSION TO FILE ANSWER, defendant argues that

plaintiff s have failed to obtain proper service on Defendant Sinclair

13
Publishing, Inc considering that no such service has to this date been made
14
on Sinclair Publishing, Inc. Registered Agent of Service. Thereby Sinclair
15
Publishing, Inc still has no date for which to file an answer to plaintiff's
16 complaint.
17 CONCLUSION

18 Defendant's respectfully move this court based on the aforementioned to

19 1. GRANT defendant's Motion for Extension of Time to File Answer

2. ORDER Plaintiff's counsel to produce the post-marked envelope

20
containing defendants Motion for Extension to File Answer mailed to
21
plaintiff.
22
3. Sanction as the Court deems reasonable Counsel for Plaintiff's
23
for filing false statements with this court as to the filing dates of
24
defendant's MOTION.
25 4. Any other relief as is appropriate.

Response to Plaintiffs Opposition - 3

 4

5 Dated this 30th day of June, 2010 Respectfully Submitted

6
Lawrence W. Sinclair, Pro Se
Lawrence W. Sinclair d/b/a
7
Sinclair Publishing
9 Spring Drive
8 Port Orange, Florida 32129
(386) 506-8912
9 lsinclair@sinclairpublishingllc.com

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Response to Plaintiffs Opposition - 4

 1 CERTIFICATE OF SERVICE

2 I hereby certify that on June 30, 2010, a copy of the foregoing

was served on the following by email and first class mail placed
3 in the United States Mail after 5:00 PM Eastern Time:
4
Richard J. Oparil
Patton Boggs LLP
2550 M Street, NW
Washington, D.C. 20037
7 R0paril@pattonboggs.com
Counsel for Plaintiff's

Linda Steinman
Davis Wright Tremaine LLP
1633 Broadway, 27th Floor
10 New York, NY 10019
lindasteinmanSdwt.com
11 Counsel for Defendant's Barnes & Noble; Barnesandnoble.com LLC
12
Amazon.com Inc
410 Terry Avenue
Seattle, WA 98109
14
Books-A-Million, Inc
15 402 Industrial Lane
Birmingham, AL 35211
16

17

18

19

20

21

22

23

24

25

Response to Plaintiffs Opposition - 5

Exhibit A
 COVER LETTER

TO: Amendment Section

Division of Corporations

SUBJECT: Sinclair Publishing, inc

DOCUMENT NUMBER: P09000032898

The enclosed Articles of Dissolution and fee are submitted for filing.

Please return all correspondence concerning this matter to the following:

Lawrence W. Sinclair
(Name of Contact Person)

dba Sinclair Publishing

(Firm/Company)

9 Spring Drive
(Address)

Port Orange. Florida 32129

(City/State and Zip Code)

For further information concerning this matter, please call:

Lawrence W. Sinclair at ( 386 \ 506-8912

(Name of Contact Person) (Area Code & Daytime Telephone Number)

Enclosed is a check for the following amount:

Q$35 Filing Fee D$43.75 Filing Fee & [7]$43.75 Filing Fee & Q$52.50 Filing Fee,
Certificate of Status Certified Copy Certificate of Status &
(Additional copy is Certified Copy
enclosed) (Additional copy is
enclosed)
MAILING ADDRESS: STREET ADDRESS:
Amendment Section Amendment Section
Division of Corporations Division of Corporations
P.O. Box 6327 Clifton Building
Tallahassee, FL 32314 2661 Executive Center Circle
Tallahassee, FL 32301
 ARTICLES OF DISSOLUTION

Pursuant to section 607.1403, Florida Statutes, this Florida profit corporation submits the following articles
of dissolution:

FIRST: The name of the corporation as currently filed with the Florida Department of State:

Sinclair Publishing Inc

SECOND: The document number of the corporation f if known): PQ9QQQ032898

Lawrence W
THIRD: The date dissolution was authorized: - Sinclair

Effective date of dissolution if applicable: JUHG 29, 2010

(no more than 90 days after dissolution file date)

FOURTH: Adoption of Dissolution (CHECK ONE)

[/] Dissolution was approved by the shareholders. The number of votes cast for dissolution
was sufficient for approval.

] Dissolution was approved by the shareholders through voting groups.

The following statement must be separately provided for each voting group entitled
to vote separately on the plan to dissolve:

The number of votes cast for dissolution was sufficient for approval by

Shareholder Vote of 180 for Dissolution

(voting group)

Signa
(By a director, presidenTBrother officer - if directors or officers have not been selected, by
an incorporator - if in the hands of a receiver, trustee, or other court appointed fiduciary, by
that fiduciary)

Lawrence W. Sinclair
(Typed or printed name of person signing)

Chairman & Sole Share Holder

(Title of person signing)

Filing Fee; S35

m
x
(WhiteHouse.com - Changing the Face of Politics - Mozilla FirefoK
le Edit View History Bookmarks lools Help

http://66.218.69, li/search/cache?ei=UIF-8&p=whitehouse.com&fi'=sfp8!ij=ww!w.whitehouse,c ASP.

ip Big Head DC "••& WhiteHouse.com - Changing the .

No pressure though. It's just that her entue polilical hie, Jeff Emanuel
including more than a decade as first lacfv of Arkansas, 8 LonctWar Journal
years m the White House as first lady and now almost 8 Michael Yon
years as a powerful United States senator, comes down to
Michelle Malkjn
a few minutes of television debate against a guy who just
rolled into town yesterday, where she not only needs to win
No End But Victory
(she almost always wins) but win so huge as to make
Outside the Wire
Obama look like some kind of idiot midget-clown. Pat deary
Peacii Pundit
Good luck, Hillary? And look, spending decades in the Powerllne
Senate wont be so bad Just look what it did for LBJI Protein Wisdom
Rathergate
We have cancelled all postings to this site until we have our registration process implemented Rieht World View
sometime tomorrow afternoon. At that time you will need to register bef ore you can post Right Reason
comments. Right Wing News
Share this article: Dm I Del.icio.us J* I Yahoo £J Right Wing Nut House
Rob Bluey
Rush ymbaucih
We are no longer going to post anything else on Larry Sinclair Matter Scrappleface
2/26/2006 2:35 PM ST Karnick
The Corner (NRQ)
Aflerthe events ofvesterday and this morning we will no longer be posting the video of the The! Dgngyan
Polygraph testing or the secondary Polygrapher Expert's results. To be accused of taking a The Hillary Spot
bribe to suppress this story along wilh all of the hate mail and messages sen! by Larry Sinclair The Minority Report
supporters who believe we did something to tainlthe results has been very disturbing. this is an adventure
JjwnhaJI
No matter what we put up it will nevei be good enough for his supporters. Mr. Sinclair was also Victory* Caucus
given every opportunity to let us talk to the limousine driver to corroborate his story and he failed
Washington Times
to do so. This will be the last post on (his matter as this matter needs to be pul to bed. We will
be going back to regular reporting.
Liberal Blog Roil
American Street
A|ThPundi|
Blogqing of the Pres
BjuecjrassjRoots
Blue Indiana
BjueJersey
Share this article: Digy '"' I Del.icio.us •* I Yahoo £1 Brendan Calling
Buckeye State Slog

... ^ Obama who 7... \ ^Hufschm!d-27...| g Tas. , . , we saw that,... i 03:37 PM

Exhibit C
 Hi

WHULKHOGANGH
 INTERNET BUZZ

Obama in New York City while a

political science student at Columbia
University in the early '80s

INGS as college student

mittee chairman Howard Dean, and look bad by failing the polygraph.
Obama's aide Axelrod for conspiracy He says he's been told Obama's
to violate his freedom of speech. camp is behind the lie-detector offer
Now. fueling further controversy - and also contends the Obama cam-
in the ugly scandal is a disputed paign put up hundreds of thousands
polygraph test that was set up and of dollars to "set the entire thing up."
administered by an Internet Web site. "They put a condition in there that
Sinclair took up an offer from White- I'm not allowed to take another poly-
House.com, which is not connected to graph test for four weeks,1' he says.
the government, to take a lie-detector "This was a tactic designed to allow
test about his Obama charges. He was Obama to pretty much lock up the
paid $10,000 for taking it and prom- nomination before I can take another
ised $100,000 if he passed. test and prove my story once and for
He flew to Los Angeles and took the all!"
test administered by former Ameri- In his defense. Gelb tells GLOBE, "I
can Polygraph Association president have never taken a bribe to do anything
Dr.EdGelbonFeb.22. improper in my life. This is a profession
WhiteHouse.com reports Sinclair based on truth, honesty, integrity. I
failed on two key points - the claim that don't think you're ever going to find me
he had sex with Obama, and the charge in a position to compromise that."
that he saw Obama smoke crack, Meanwhile, Sinclair's claims haw
"There was deception indicated sparked Internet whispers about
in both tests,'" the site reported on Obama's sexual history. Some posts
Feb. 24, adding that "another ex- question tHe Democratic £ront-ruj-Lrx0r*s
pert examiner" independently cor- activities while at Columbia University
roborated the findings. But Sinclair in New York in the early 1980s.
"
Q

X
LLI
 UNITED STATES
POSTAL SERVICE,

Date: 06/30/2010

Lawrence Sinclair:

The following is in response to your 06/30/2010 request for delivery information on your
Express Mail(R) item number EO97 8049 292U S. The delivery record shows that this item
was delivered on 06/28/2010 at 12:02 PM in WASHINGTON, DC 20001 to J RAGUSA. The
scanned image of the recipient information is provided below.

Signature of Recipient:

Address of Recipient:

Thank you for selecting the Postal Service for your mailing needs. If you require additional
assistance, please contact your local Post Office or postal representative.

Sincerely,

United States Postal Service

USPS - Track & Confirm Page 1 of 1

UNITEDSTATES
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Label/Receipt Number: EO97 8049 292U S
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Class: Express Mail® Enter Label/Receipt Number.
Status: Delivered

Your item was delivered at 12:02 PM on June 28, 2010 in

WASHINGTON, DC 20001. The item was signed for by J RAGUSA.

Detailed Results:
Delivered, June 28, 2010,12:02 pm, WASHINGTON, DC 20001
Notice Left, June 28, 2010,11:48 am, WASHINGTON, DC 20001
Notice Left, June 26, 2010,10:54 am, WASHINGTON, DC 20001
Arrival at Post Office, June 26, 2010,10:47 am, WASHINGTON, DC 20001
Processed through Sort Facility, June 26, 2010, 8:52 am, WASHINGTON, DC 20074
Processed through Sort Facility, June 25, 2010, 7:20 pm, JACKSONVILLE, FL 32203
Acceptance, June 25, 2010,11:54 am, PORT ORANGE, FL 32127
Electronic Shipping Info Received, June 25, 2010

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http://trkcnfrml .smi ueps 6/30/2010

Lawrence Sinclair

From: Larry Sinclair [Iarry@larrysinclair4congress.com]

Sent: Sunday, June 20, 2010 11:17 AM
To: 'Oparil, Richard'; 'Street, Cindi1; 'Steinman, Linda'
Cc: 'Summerscales, Joanna'
Subject: Parisi et al v Sinclair et al 1:10-cv-00987-RJL Motion For Extension to File Answer
Attachments: Motion Extension.PDF

Greetings:

Attached you will find a PDF copy of a MOTION for Extension To File Answer being mailed to you tomorrow.

The Motion is filed after attempts to get counsel for plaintiffs to agree to an extension failed.

We are confident we will have retained counsel shortly and we are confident we will prevail in this action.

Respectfully,

Lawrence Sinclair
Sinclair Publishing, Inc
9 Spring Drive
Port Orange, Florida 32129
lsinclair@sinclairpublishingllc.com
www.sinclairpublishingllc.com
386-506-8912/866-966-6599

Tracking:
Recipient Read
'Oparil, Richard' Read: 6/20/2010 12:27 PM
'Street, Cindi' Read: 6/20/2010 2:09 PM
'Steinman, Linda1 Read: 6/21/2010 9:56 AM
'Summerscales, Joanna'
Lawrence Sinclair
From: Oparil, Richard [ROparil@PattonBoggs.com]
To: Larry Sinclair
Sent: Sunday, June 20, 2010 12:27 PM
Subject: Read: Parisi et al v Sinclair et al 1:10-cv-00987-RJL Motion For Extension to File Answer

Your message

To: Oparil, Richard; 'Street, Cindi'; 'Steinman, Linda'

Cc: 'Summerscales, Joanna'
Subject: Parisi et al v Sinclair et al 1:10-cv-00987-RJL Motion For
Extension to File Answer
Sent: Sun, 20 Jun 2010 11:17:22-0400

was read on Sun, 20 Jun 2010 12:27:14 -0400

Exhibit E
^^^_____ **mu MM
This ma JLJ
D
EMOCRATIC frontrunner Barack
Obama is caught up in a shocking
gay sex and drug scandal that could
derail his White House campaign!
In a video posted on the popular
Internet Web site YouTube.com, a
man identifying himself as Larry
Sinclair claims he had sex with Obama
in a limousine and a hotel room over a
three-day period in November 1999 - and
also did cocaine with him.
"I met Obama at an upscale lounge in
Chicago," Sinclair says in the video.
"After having a few drinks, Obama and
I left in my limo...and Mr. Obama acquired
powder cocaine for my use, crack cocaine
for his use.
"I performed oral sex on Senator
Obama, who at the time was a state
representative for the state of Illinois."
Sinclair adds that he also had sex
with Obama in a hotel room in Gurnee,
111., two nights later.
He says he's making these accusa-
tions now because Obama hasn't been
truthful about his drug use.
The senator has admitted using drugs
as a youth but steadfastly denies using
them in recent years.
Sinclair, an ex-con, is offeringtotake a
lie detector test and challenges the pres-
idential hopeful - who's been married
to lawyer wife Michelle for 15 years
- to also take a polygraph to see who is
telling the truth,
Obama, 46, has electrified crowds
nationwide while rolling up an impres-
sive string of primary victories against
his rival Hillary Clinton, but Sinclair's
stunning allegations could torpedo his
White House ambitions, say experts.
Sinclair's YouTube video was posted
on Jan. 18 and has been viewed more
than a quarter-million times - and
counting. Meanwhile, GLOBE tracked
down a man who claims to be Sinclair
in Duluth, Minn.
Although Sinclair has provided no
evidence to back up his outrageous
Obama stories, the 46-year-old man
tells GLOBE that he's spent time in
prison in Florida, Arizona and Colo-
rado on credit card fraud and other
charges,
He also admits trafficking in cocaine
and marijuana and "moving"' people
from Mexico to the United States.
He says he's been disabled since a
"work-related accident" in 2001 and
has now been diagnosed with a brain
tumor and given "a little more than a
year" to live,
Met in a bar
Sinclair tells GLOBE that after meet-
ing Obama in a Chicago bar. he told
the charismatic politician that he could
"use a line (of cocaine) to wake up,"
Obama then "made a phone call and
said he could get it for me,
"I gave Barack Obama $250, which
he used to purchase the drugs. It made
no difference to me that he was in the teen in his memoir. Dreams from Mv
Sinclair (aka Lawrence W SB
D
Plaintiff. j»ef ft.
Siaiack Olans, David Axefowl, JB
Uvnieciiiiic National CB»»wmt<;t.
Obama's accuser Larr
filed a lawsuit against
Democratic politician
supporters after they:
his YouTube.com vide*
his claims about havin
drugs with the senate
Bombsheff
Megan
Hughes
was bedded
Jsy Obama,
sources say
state legislature, but it makes a
difference to me now that he's
running for president, I contacted
him last fall and said. 'All you
need to do is to acknowledge you
were wrong about the dates you
last used drugs,' None of this would
have come out."
Obama detailed his drug uae as a
 * ^S0r m^B ^ mm mmm m \^ mm* » WP- ^MI MB; w an «nm

<THIS MAN SBS:*WE WERE LOVERS!'

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