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Midnightwalk

Midnightwalk's Journal
Midnightwalk's Journal
May 26, 2021

Divided Highway. As a freeway comes down, Syracuse, New York, faces its legacy of segregation


For more than 50 years, Interstate 81 has cut through the heart of hard-luck Syracuse, New York, raining vehicle exhaust on its Southside neighborhood, where most residents are Black and poor.

Now, New York State wants to replace that elevated stretch of freeway with a street-level boulevard to knit the city’s urban grid back together. Construction could begin as soon as next year.

The plan has stirred visions of renewal in a city where one in three residents lives in poverty. Some here say it could also make amends to Black residents who were displaced by Interstate 81’s construction decades ago and have been living in its shadow ever since.'

“When they put that highway up they destroyed this community,” said David Rufus, a lifelong Southside resident who is now an organizer for the New York Civil Liberties Union (NYCLU). “Now here’s an opportunity to right that wrong by bringing it down.”


[link:https://graphics.reuters.com/USA-BIDEN/INFRASTRUCTURE-FREEWAYS/qzjpqbzzyvx/|]
May 17, 2021

Summary of Greenberg's Plea deal

My il-legally trained read of the plea deal. Not a lawyer. Corrections welcome.

It details Greenberg’s crimes and mentions two people involved in his covid-19 loan schemes aka Economic Injury Disaster Loan (EIDL)s.

The first 25 pages cover the plea deal. Lists the counts that he will plead to and says the rest will be dropped. Has to cooperate. Even “Personalization of Element” which I guess is what he’ll be asked at allocution”

The minimums and average times are long

Then details on counts

Count 1
Sounds like he has a sex compulsion. There’s a month of expenses, june 2017, where he paid around $425 each time for sex. Later in 2020 he wondered how fast he could blow 100k on “p...y”. Did the counting and math in head, but at that rate it is close to $10k per month for 3 years.

Regardless this is the count that covers the minor. Throw the book at him.

Count 8 and 9 and the feds
Aka fake driver licenses. Some for himself but maybe he sold some. Basically he uses his role at the dmv to make false ids.

First he bought a boat from someone and then used that person’s info to create a license with Greenberg’s address without that persons knowledge . Then another with Greenberg’s photo.

He then proceeded to make these federal offenses. Don’t do this at home kiddies.

Greenberg was the Tax Collector. He used his Tax Collector credit card to purchase a badge (license) making machine from office depot. Turns out the machine and were manufactured in France. That’s all it takes. Hello federales.

He couldn’t keep using the poor boat seller’s info to make licenses but no worries. There was a basket where the dmv kept the old licenses after renewals until they could be diligently destroyed every 45 days. Apparently they have to age before shredding.


Count 14 and the fire
The crypto currency. Big deal, but you can read good summaries about it I think and this isn’t one of them. Basically used his position to embezzle funds to make short term investments for the office but used it to buy crypto currency for himself instead

That wasn’t enough, so he used some of the proceeds to buy around $58,000 of servers to mine crypto currencies. Those servers wound up in the Tax Collector’s Office because of Covid.

Those machines couldn’t be examined because.....



Those machines
were damaged in a fire, which occurred due to a power surge caused by the way in which the machines were daisy chained together. The expenses incurred for the server room buildout,fire damage, and server room tear down in the Lake Mary branch were approximately $98,000. All of those costs were due to Greenberg using Tax Collector Office funds to benefit himself personally , including by operating a business out ofthe Tax Collector's Office for his personal benefit under the guise of Government
Blockchain Systems.


Yes, sounds like he plugged all these high powered servers which burn electricity like crazy into the same extension chords.

Count 24 or how republicans win elections
This is about Greenberg having an opponent in his re-election bid for the Tax Man gig and committing crimes to win.

Greenberg first sent a letter to the head of the school where the victim worked as a teacher then to 8 other faculty members. The letters were sent as if written by a student and described his concerns about a inappropriate homosexual relationship between and his friend who was also a student. Ages not mentioned.

Then Greenberg created imposter facebook and Twitter accounts making racist statements posing as the teacher.

Can’t paste either easily. You can see them on pages 71 and 72 of the doc.

Count 26 The covid loans and baby I can’t get enough
This is about fraud in applying for and getting covid-19 loans aka economic injury disaster loans (EIDL). This is where two other people who seem to be in legal trouble are mentioned. The recruiter conspirator and the SBA guy. Well covered elsewhere but one part caught me eye.

He was arrested on june 23 and continued committing fraud up to at least July 6.
On June 23, 2020, Greenberg was arrested in this case. He had his initial
appearance that day and was released on conditions, which included a prohibition on committing any new criminal offenses and a statement advising him that any new criminal violations would result in the possibility of additional terms of imprisonment
due to the fact that he was on pretrial release in his federal criminal case.


He couldn’t get enough but you probably have.

[link:https://assets.documentcloud.org/documents/20708963/greenberg-plea-agreement.pdf|]

The end
May 8, 2021

Happy moon rise

[img][/img]

May 8, 2021

Notes on Judge Amy Berman Jackson's ruling on the DoJ memo leading to Barr's letter to congress

I don't know why I got into reading and summarizing these decisions, but I find them interesting and writing it out helps me organize my thoughts. Hope you enjoy. Not a lawyer. I had some issues cutting and pasting and had to do some piece-wise. Apologies if messed something up. I'll correct anything pointed out.

The Memorandum Opinion lays out the timeline of Mueller delivering his report, Barr delivering his 4 page summary over the weekend, Mueller writing his letter saying "

The summary letter the Department sent to Congress and released to the public late in the afternoon of March 24 did not fully capture the context, nature, and substance of this Office’s work and conclusions.


It's was a good reminder of when the report came out and then the obvious cover up letter to congress. Basically nothing to see here, president is innocent. Those were a bad few days in a sea of bad days.

Here's that in full:
MEMORANDUM OPINION
On Friday, March 22, 2019, Special Counsel Robert S. Mueller, III delivered his Report of the Investigation into Russian Interference in the 2016 Presidential Election to the then-Attorney General of the United States William P. Barr

But the Attorney General did not share it with anyone else.

Instead, before the weekend was over, he sent a letter to congressional leaders purporting to “summarize the principal conclusions” set out in the Report, compressing the approximately 200 highly detailed and painstakingly footnoted pages of Volume I – which discusses the Russian government’s interference in the election and any links or coordination with the Trump campaign – and the almost 200 equally detailed pages of Volume II – which concerns acts taken by then-President Trump in connection with the investigation – into less than four pages.

The letter asserted that the Special Counsel “did not draw a conclusion – one way or the other – as to whether
the examined conduct constituted obstruction,” and it went on to announce the Attorney General’s
own opinion that “the evidence developed during the Special Counsel’s investigation is not
sufficient to establish that the President committed an obstruction-of-justice offense.”

The President then declared himself to have been fully exonerated

The Attorney General’s characterization of what he’d hardly had time to skim, much less, study closely, prompted an immediate reaction, as politicians and pundits took to their microphones and Twitter feeds to decry what they feared was an attempt to hide the ball.

Even the customarily taciturn Special Counsel was moved to pen an extraordinary public rebuke on March 27:

The summary letter the Department sent to Congress and released to the public late in the afternoon of March 24 did not fully capture the context, nature, and substance of this Office’s work and conclusions. We communicated that concern to the Department on the morning of March 25. There is now public confusion about critical aspects of the results of our investigation. This threatens to undermine a central purpose for which the Department appointed the Special Counsel: to assure full public confidence in the outcome of the investigations"


Then a long description of what the case is about and releveant laws. Here's a mish mash of my take and quotes

The case involves summary judgement involving FOIA requests on two documents, referred to Document 6 and Document 15. There's a second issue about expediting, and that is ruled moot.

Then a discussion about what goes into making a summary judgement and some background on FOIA. Interesting. There's one paragraph that stood out to me emphasizing accuracy is critical:

Above all, though, it is essential that agency affidavits be accurate. “[S]ummary judgment may be granted on the basis of agency affidavits” in FOIA cases, when those affidavits “contain reasonable specificity of detail rather than merely conclusory statements,” and when “they are not called into question by contradictory evidence in the record or by evidence of agency bad faith.” Judicial Watch, Inc. v. U.S. Secret Serv., 726 F.3d 208, 215 (D.C. Cir. 2013), quoting Consumer Fed’n of Am. v. Dep’t of Agric., 455 F.3d 283, 287 (D.C. Cir. 2006). As the D.C. Circuit has emphasized, this Court should be able to depend on the accuracy of submissions that are intended “to permit adequate adversary testing of the agency’s claimed right to an exemption.”


FOIA rule 5 is the key to the decision:
FOIA Exemption 5
Defendant withheld the two records in dispute in this case pursuant to FOIA Exemption 5, which bars disclosure of “inter-agency or intra-agency memorandums or letters that would not be available by law to a party other than an agency in litigation with the agency.” 5 U.S.C. § 552(b)(5).

A document may be properly withheld under Exemption 5 if it satisfies “two conditions: its source must be a [g]overnment agency, and it must fall within the ambit of a privilege against discovery under judicial standards that would govern litigation against the agency that holds it.”


There are two privileges:
Deliberative process privilege
The deliberative process privilege “allows the government to withhold documents and other materials that would reveal advisory opinions, recommendations and deliberations comprising part of a process by which governmental decisions and policies are formulated.”

.....

To accomplish that goal, “[t]he deliberative process privilege protects agency documents that are both predecisional and deliberative.”


Predicisional is important later on


The attorney-client privilege

....

“The attorney-client privilege protects confidential communications from clients to their attorneys made for the purpose of securing legal advice or services.” Tax Analysts v. IRS, 117 F.3d 607, 618 (D.C. Cir. 1997), citing In re Sealed Case, 737 F.2d 94, 98–99 (D.C. Cir. 1984). “Its purpose is to encourage full and frank communication between attorneys and their clients and thereby promote broader public interests in the observance of law and administration of justice.”

....

But the mere fact that the communication involves a member of the bar does not end the
inquiry. See Mead Data Cent., 566 F.2d at 253 (“The privilege does not allow the withholding of documents simply because they are the product of an attorney-client relationship . . . .”). For instance, the privilege does not extend to a “government attorney’s ‘advice on political, strategic, or policy issues, valuable as it may [be].’”


That last paragraph is also important later.

Now why the motion to release document 15 was granted

Defendant has not met its burden to justify withholding under the deliberative process privilege.

The memorandum is largely deliberative. But the Court cannot find the record to be “predecisional,” because the materials in the record, including the memorandum itself, contradict the FOIA declarants’ assertions that the decision-making process they have identified was in fact underway. Moreover, the record supplies reason to question whether the communication preceded any decision that was made.


The OLC had two people say why the document was predeicisional. See page 18 if interested. The judge quotes CREW (the plaintiff on document 15). They made the decisions before the memo.

CREW had difficulty swallowing this explanation.

DOJ’s . . . arguments rest on the demonstrably false proposition that the memo was submitted to the Attorney General to assist him in making a legitimate decision on whether to initiate or decline prosecution of the President for obstructing justice . . . . [H]owever, the Special Counsel already had made final prosecutorial judgments and the time for the Attorney General to challenge those judgments had passed. Whatever the contents of the March 24, 2019 OLC memo, it was not part of a deliberation about whether or not to prosecute the President.


The judge can't reveal what's in the memo. But she talks about the two sections of the memo and points out that section 1 was completely strategic and political. Not deliberative or predecisional.

What the Court can say without revealing the content of the redacted material is that there were two sections to this memorandum. Section I offers strategic, as opposed to legal advice, about whether the Attorney General should take a particular course of action, and it made recommendations with respect to that determination, a subject that the agency omitted entirely from its description of the document or the justification for its withholding. This is a problem because Section I is what places Section II and the only topic the agency does identify – that is, whether the evidence gathered by the Special Counsel would amount to obstruction of justice – into its proper context.


Here's a key piece. They produced the letter to congress without having reviewed the report and before any deliberative predecision discussions. By the time this memo about the letter was made Barr had already decided not to prosecute Trump for obstruction:
Moreover, the redacted portions of Section I reveal that both the authors and the recipient of the memorandum had a shared understanding concerning whether prosecuting the President was a matter to be considered at all. In other words, the review of the document reveals that the Attorney General was not then engaged in making a decision about whether the President should be charged with obstruction of justice; the fact that he would not be prosecuted was a given.


The judge throws some shade at Barr for ummm inaccuracy.
All of this contradicts the declarant’s ipse dixit that since the Special Counsel did not resolve the question of whether the evidence would support a prosecution, “[a]s such, any determination as to whether the President committed an obstruction-of-justice offense was left to the purview of the Attorney General.” Brinkmann Decl. ¶ 11. It also calls into question the accuracy of Attorney General Barr’s March 24 representation to Congress: “The Special Counsel’s decision to describe the facts of his obstruction investigation without reaching any legal conclusions leaves it to the Attorney General to determine whether the conduct described in the report constitutes a crime.” March 24 Letter at 3


She then kind throws some shade and an elbow at the DoJ:
And the in camera review of the document, which DOJ strongly resisted, see Def.’s Opp. to Pl.’s Cross Mot. [Dkt. # 19] (“Def.’s Opp.”) at 20–22 (“In Camera Review is Unwarranted and Unnecessary”), raises serious questions about how the Department of Justice could make this series of representations to a court in support of its 2020 motion for summary judgment:
[T]he March 2019 Memorandum (Document no. 15), which was released in part to Plaintiff is a pre-decisional, deliberative memorandum to the Attorney General from OLC AAG Engel and PADAG Edward O’Callaghan . . . .


She notes that "hey another court found you trying to pull this crap and I'll include it in the decision"
As noted above, summary judgment may be granted on the basis of agency affidavits in FOIA cases, when “they are not called into question by contradictory evidence in the record or by evidence of agency bad faith.” Judicial Watch, Inc., 726 F.3d at 215, quoting Consumer Fed’n, 455 F.3d at 287.
But here, we have both. Another court in this district has expressed “grave concerns about the objectivity of the process that preceded the public release of the redacted version of the Mueller Report.”


Quoting from the other court:
Although Attorney General Barr can be commended for his effort to expeditiously release a summary of Special Counsel Mueller’s principal conclusions in the public interest, the Court is troubled by his hurried release of his March 24, 2019 letter well in advance of when the redacted version of the Mueller Report was ultimately made available to the public. The speed by which Attorney General Barr released to the public the summary of Special Counsel Mueller’s principal conclusions, coupled with the fact that Attorney General Barr failed to provide a thorough representation of the findings set forth in the Mueller Report, causes the Court to question whether Attorney General Barr’s intent was to create a one-sided narrative about the Mueller Report – a narrative that is clearly in some respects substantively at odds with the redacted version of the Mueller Report


She's mauling them at this point:
And of even greater importance to this decision, the affidavits are so inconsistent with evidence in the record, they are not worthy of credence. The review of the unredacted document in camera reveals that the suspicions voiced by the judge in EPIC and the plaintiff here were well-founded, and that not only was the Attorney General being disingenuous then, but DOJ has been disingenuous to this Court with respect to the existence of a decision-making process that should be shielded by the deliberative process privilege. The agency’s redactions and incomplete explanations obfuscate the true purpose of the memorandum, and the excised portions belie thenotion that it fell to the Attorney General to make a prosecution decision or that any such decision was on the table at any time


Then she goes into who got together to produce the memo. I love that she made a who emailed who chart (chart not in decision, but it does say it's available somewhere). Who knew who you meet with can have an effect. They should have hired a lawyer.



The Court has created a chart listing all of the emails in chronological order. It is attached to this opinion as Attachment 1 and incorporated in the opinion as part of the Court’s factual findings. The emails are exchanged among Stephen A. Engel, an Assistant Attorney General in the Office of Legal Counsel; Brian C. Rabbitt, the Chief of Staff in the Office of the Attorney General; Rod Rosenstein, the Deputy Attorney General; and Edward C. O’Callaghan, the Principal Associate Deputy Attorney General, and at least one is copied to another person in OLC: Henry C. Whitaker (OLC).


The memo the DOJ attorneys were working on was the advice the OLC was going to give them. Remember deliberative and predecisional. The fix was already in and OLC was in on it and not independent. (my opinion)

The emails show not only that the authors and the recipients of the memorandum are working hand in hand to craft the advice that is supposedly being delivered by OLC, but that the letter to Congress is the priority, and it is getting completed first. At 2:16 pm on Sunday, March 24, the Attorney General’s Chief of Staff advises the others: “We need to go final at 2:25 pm,” and Rod Rosenstein, the Deputy Attorney General, summons everyone to a meeting at 2:17 pm. Attachment 1 at 4. At 2:18 pm, Steven Engel in the OLC replies to this email chain related to the draft letter, and he attaches the latest version of the memo to the Attorney General, saying: “here’s the latest memo, btw, although we presumably don’t need to finalize that as soon.” Id.; see also id. at 6 (finalizing the letter just before 5:00 pm on March 24 and the memorandum just before 9:00 am on March 25). In sum, the set of emails contained in plaintiff’s Exhibit A undermines the uninformed assertions in the declarations uponwhich the defense relies
.

There's discussion of why attorney client privildge doesn't apply because these jokers were acting politically, but this is already too long so read the doc if you want that.


May 4, 2021

Some quotes from Dominion's response to Powell's motion to dismiss

I am not a lawyer and might have misinterpreted everything I read. These are just parts I found interesting or amusing. Corrections/clarifications welcome. I *think* I can quote liberally from public document. If someone knows better, please tell me and I'll delete.

It starts off pointing out a little confusion in Powell's argument

After proclaiming that “I can hardly wait to put forth all the evidence we’ve collected on Dominion, starting with the fact it was created to produce altered voting results in Venezuela for Hugo Chávez,” that “votes were in fact altered and manipulated” “in the 2020 US General Election,” and that “you would have to be a damn fool and abjectly stupid not to see what happened here, for anybody who’s willing to look at the real evidence,” Powell now claims that “no reasonable person would conclude that the statements were truly statements of fact.”1 At the same time, Powell asserts that she herself “believes them now.”


I can't wait to show my evidence, you'd be stupid not to believe me, no reasonable person would believe me and I do. Ooooh my head hurts...

They do a quick couple of paragraphs on the lies (more later), and and the first section with

After lying about the evidence supporting her claims, Powell now asks this Court to create unprecedented immunity for attorneys to wage televised disinformation campaigns.


They list 4 major issues to be determined by the courts: Actionability, Accountability personal jurisdiction and agency and deceptive trade practices. YES! they will use her fundraising against her.

Her statements are actionable because they can be proven false.

Seeking to evade liability for her false statements, Powell argues that “no reasonable person would conclude that the statements were truly statements of fact.” (Mem. 27-28.) In advancing this argument, Powell studiously avoids putting her defamatory statements before the Court because they are reasonably understood as assertions of fact that are capable of being proven true or false, and because Powell herself repeatedly asserted they could be proven with evidence she possessed or posted to her fundraising website. For example, during her defamatory campaign, Powell falsely claimed that:


What did she claim? Lots of stuff, some legal arguments. Here's the last paragraph which is a good summary and a good smack down (she does not)...

Powell’s statements are provably false. She either has a video of Dominion’s founder admitting that he can change a million votes or she does not (she does not). Dominion was either created in Venezuela to rig elections or it was not (it was not). Dominion either rigged the 2020 election by weighting, flipping, switching, and trashing votes or it did not (it did not). Dominion either bribed officials or it did not (it did not). Powell’s own motion confirms that her statements are susceptible of being proven false by disputing that they are false. (Mem. 37.)


The next covers whether "opinion" is a defense. I like the footnote:
Even if Powell had qualified her statements by saying “in my opinion” (she did not), “opinion” is not a magic word that can be invoked to ward off defamation liability. “If a speaker says, ‘In my opinion John Jones is a liar,’ [s]he implies a knowledge of facts which lead to the conclusion that Jones told an untruth. ... Simply couching such statements in terms of opinion does not dispel these implications; and the statement, “In my opinion Jones is a liar,” can cause as much damage to reputation as the statement, “Jones is a liar.” Milkovich, 497 U.S. at 18-19; see also Gross, 82 N.Y.2d at 155 (noting that the statement “I believe John is a thief” would not be materially different from the statement, “John is a thief”).


She never said "in my opinion. So much the worse.

Here's one paragraph calling her a liar a few times. I count 4 times they call Powell a liar. (highlighted):
Powell’s statements are actionable because her disclosure of facts was both “incorrect [and] incomplete.” Milkovich, 497 U.S. at 18-19. As alleged in the Complaint, Powell deceived millions of people into believing that Dominion had committed the “greatest crime of the century if not the life of the world” by lying about having a video of Dominion’s founder and evidence of kickbacks (which she never disclosed to her viewers or posted to her fundraising website because they do not exist) and by touting evidence that Powell knew was false and misleading. (Compl. ¶¶ 7, 70, 87-109, 111, 181 (bb), 188.)


I didn't realize that some time after Powell saying something like only an idiot would listen to me she doubled down on d'souzas podcast that "just kidding about just kidding i'm really serious". Again, I'm not a lawyer, but that doesn't seem too B-R-I-T. I tried to duplicate the highlights from the doc. Don't sue me if I messed up.

Powell: Oh no, I am not backtracking a bit. What they are misquoting from and taking out of context is the statement from a new decision out of the D.C. Circuit that is binding in my case. And it’s not what I said at all. I firmly believe everything I said was true. It was based on thousands of pages of affidavits, expert reports, mathematical analysis that cannot be challenged, statistical work that cannot be challenged. I mean, the data does not lie. And there was, in fact, massive widespread fraud through this election and Donald Trump should be president right now. In fact, if the law were applied correctly, he is
.
D’Souza: So you’re not taking any of it back. You’re not taking refuge in the distinction between fact and opinion. It seems to me what you’re saying is, “Yes, I have the opinion that there was widespread fraud, but this is not an opinion free floating in the ether. It’s an opinion anchored in a whole bunch of testimonies, affidavits, all types of evidence, statistical evidence, and so on. It’s opinion that is rooted in fact. ...

Powell: I’m not backing up one inch. Everything I said about Dominion, I had a factual basis for. Any reasonable person looking at the evidence I’ve seen would have to come to the same conclusion.


They say it better than I could dream
In sum, after representing to this Court that “no reasonable person would conclude that [her] statements were truly statements of fact,” Powell went on television the following week to tell viewers “there was, in fact, widespread fraud through this election.” Id.; Mem. 27-28. Powell’s lies are plainly actionable and she should be held accountable.


On to malice. The standard:
A. Powell intentionally lied and manufactured fake evidence.
As Defendants acknowledge (Mem. 36), the “actual malice” standard does not require complaints to cite evidence proving that a defendant knew her statements were false; rather, a complaint pleads actual malice where it alleges facts giving rise to a plausible inference that the defendant knew or recklessly disregarded that her statements were false.


Let's count how many times they call her a liar again. I'm grinning while highlighting
Repeatedly over a period of months, Powell published false statements about Dominion, knowing or recklessly disregarding that they are false, including by intentionally lying about having evidence that does not exist; manufacturing, misrepresenting, and cherry-picking evidence; purposefully avoiding or intentionally disregarding abundant and publicly available evidence, facts, and reliable sources rebutting and disproving her false claims; espousing inherently improbable accusations; forming and sticking to a false preconceived narrative in spite of the facts; relying on and putting forward facially unreliable sources; and—when specifically put on notice of the truth and asked to retract—doubling down on and republishing the false accusations.


More good stuff on malice, but you can read it yourself . In it is where they bring up making money off your lies is malice.
The Complaint alleges numerous facts giving rise to a plausible inference that Powell lied about Dominion not because she believed her lies but to raise funds for and direct traffic to her fundraising website, to sell books and t-shirts, to raise her public profile as an attorney, “media figure,” and possibly a presidential candidate, to curry favor with then-President Donald Trump for benefits she expected to receive as a result of that association, such as a pardon for her client Michael Flynn.


Jurisdictional stuff. I'm sure it's important and fascinating to some people. I skimmed before i nodded off. One excerpt:
Dominion has been unfairly subjected to the hatred, contempt, and distrust of tens of millions of American voters, and the elected officials who are Dominion’s actual and potential customers have received emails, letters, and calls from their constituents demanding that they avoid contracting with Dominion or using Dominion machines. As a result, elected officials, insurers, and potential investors have been deterred from dealing with Dominion, putting Dominion’s contracts in more than two dozen states and hundreds of counties and municipalities in jeopardy and significantly hampering Dominion’s ability to win new contracts.


Finally, part of the conclusion:
CONCLUSION
Acting on behalf of her fundraising website, her law firm, and herself, Sidney Powell went to D.C. and helped launch one of the most damaging disinformation campaigns in American history, fooling millions of people into believing that Dominion had stolen the 2020 election. (Compl. ¶¶ 24- 27, 52, 62.) Now that Dominion seeks to hold Powell accountable in the city where Powell waged that campaign, Powell asks the Court to dismiss this case for lack of personal jurisdiction or to transfer the case to Texas. The only connection that Texas has to this case is that
42
Case 1:21-cv-00040-CJN Document 39 Filed 05/03/21 Page 54 of 56
Powell may have left Texas to come to D.C. to transact the business and utter many of the falsehoods giving rise to this case. For weeks, a process server saw no sign of Powell at her asserted residence in Texas. Powell was ultimately served outside her house in North Carolina— another state having no meaningful connection to this case. This case arises out of a D.C.-based defamatory campaign, which had serious repercussions for Dominion and the public in D.C.


Hope you find this interesting.

Forgot link
[link:https://www.documentcloud.org/documents/20697152-dominion-response-to-powell-mtd?responsive=1&title=1|]


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