Updated March 14, 2012 @ 3:09 PM ET
We have obtained the complete document and have attached all 122 pages to the Document Number 158 below. We have also linked yet a third declaration dated December 20, 2011 of Tammy Byrnes, which you can see HERE. After an initial quick review of the latest Motion by Parisi its has become clear that while Larry Sinclair’s story has remained consistent for four plus years despite the unbelievable efforts to get him to change it, Daniel Parisi’s claims in this case have now changed at least five different times with him changing declarations as his resident status and location(which he has filed three different declarations under penalty of perjury claiming to be a resident of a different location in each one), to calling Mrs. Byrnes a relative of Sinclair’s to correctly in August 2011 claiming Mrs. Byrnes did not know Sinclair and NO ONE used her phones to ever make calls to Sinclair to yesterday filing yet two more declarations from Mrs. Byrnes claiming her phone was used to call Los Angeles and Duluth Minnesota but that she did not make the calls, but now stating “the only other person who had access to my cell phone was my boyfriend at that time whose name is Michael Carson.” From Declaration of Tammy Byrnes dated Dec 20, 2011 This is a stark difference from Mrs. Byrnes SWORN declaration dated August 5, 2011 when she swore “Nor did anyone else use my telephones to provide Mr. Sinclair with any tip. Any statement to the contrary is false.” From Declaration of Tammy Byrnes Aug 5, 2011
Note that all documents linked to this article ARE public records available to anyone from the United States District Court for the District of Columbia Clerks office.
March 14, 2012 1:08 AM ET
Counsel for Plaintiff Daniel Parisi et al did at 7:41 PM March 13, 2012 file a Motion to Amend/Alter the Judges Feb 28, 2012 Order dismissing the claims against Lawrence W. Sinclair.
U.S. District Court
District of Columbia
Notice of Electronic Filing
The following transaction was entered by Oparil, Richard on 3/13/2012 at 7:41 PM and filed on 3/13/2012
|Case Name:||PARISI et al v. SINCLAIR et al|
|WHITEHOUSE NETWORK LLC|
|WHITE HOUSE COMMUNICATIONS INC.|
|WARNING: CASE CLOSED on 03/05/2012|
MOTION to Alter Judgment as to  Order on Motion to Dismiss, Reconsideration and for Leave to File an Amended and Supplemental Complaint by DANIEL PARISI, WHITE HOUSE COMMUNICATIONS INC., WHITEHOUSE NETWORK LLC, WHITEHOUSE.COM INC. (Attachments: # (1) Memorandum in Support of Motion to Reconsider, Alter or Amend Judgment and Leave to File an Amended and Supplemental Complaint, # (2) Exhibit 1 – Proposed Amended and Supplemental Complaint, # (3) Exhibit 2, # (4) Exhibit 3, # (5) Exhibit 4, # (6) Exhibit 5, # (7) Exhibit 6, # (8) Exhibit 7, # (9) Exhibit 8, # (10) Exhibit 9, # (11) Exhibit 10, # (12) Text of Proposed Order)(Oparil, Richard)
The Motion also contained Motion For Leave to File Amended/Supplemental Complaint and “New” claims against Sinclair and Sinclair Publishing, Inc. Due to problems with the US District Courts ECF (Electronic Case Filing) system all documents were not accessible and we hope to have them after contacting the Court tomorrow. Requests sent to Parisi counsel Richard Oparil of Washington, DC’s Patton Boggs LLP to have the documents emailed resulted in Mr. Oparil sending copies of documents we were already in possession of. The new filing by Parisi is interesting in that it is almost exactly the same thing which has been filed on at least two other occasions which were denied by the Court. The filings attempt to introduce “new” evidence which has already been stricken from the record once and which contradicted Parisi claims in February 2011 when he alleged that the owner of telephone numbers (in Sinclair’s book Barack Obama & Larry Sinclair: Cocaine, Sex, Lies & Murder? as being the numbers from which Sinclair received a tip concerning the 2008 polygraph) was a “relative of Sinclair” and thereby could not be considered to be even remotely credible. In August 2011 Parisi filed “Notice of Additional Evidence” where he claimed that Tammy Byrnes (the owner of two telephone numbers listed in Sinclair’s book) had provided sworn declarations stating she did not know Larry Sinclair; had never spoken with Larry Sinclair; and that “NO ONE called Larry Sinclair from my phones.”
I do not know and, to the best of my knowledge, I have never spoken with Lawrence W. (“Larry”) Sinclair. I have never called Mr. Sinclair nor have I ever received a telephone call from him. I did not provide Mr. Sinclair or anyone else with an “anonymous tip on February 25, 2008 or at any other time. Nor did anyone else use my telephones to provide Mr. Sinclair with any tip. Any statement to the contrary is false. From Declaration of Tammy Byrnes Aug 5, 2011
The claim that Mrs. Byrnes did not know Larry or had never spoken with Larry were truthful claims, but Larry had already made that clear in his reply in support of his motion to Dismiss or for Summary Judgment filed in Feb 2011. Parisi even tried to claim that the calls Larry received from Maine on Feb 25, 2008 were calls he had reported for harassment.
When Larry responded to Parisi’s Aug 2011 filing he pointed out that the Private Investigator plaintiffs obtained sworn declarations from had already once been sanctioned over his own failure to be truthful in declarations under the penalty of perjury. In addition Larry pointed out the fact that Mrs. Byrnes declaration stated “NO ONE used my phones to call Larry Sinclair,” while the declaration of the private investigator stated “Mrs. Byrnes states to her knowledge no one called Larry Sinclair from her phones.” Now in the Motion filed late today Parisi claims that “Sinclair DID receive calls from the two phone numbers owned by Mrs. Byrnes in Feb 2008, but that Mrs. Byrnes says she did not make those calls.”
This declaration is a follow up to my August 5, 2011 declaration.
I requested a copy of my telephone records from Sprint for the cell phone that I had in 2008- (207) 252-2796 – Sprint provided me with copies of four bills for the following time periods:
12/19/2007 – 01/18/2008; 01/19/2008 – 02/18/2008; 02/19/2008 – 03/18/2008; 03/19/2008 – 04/18/2008
A copy of the bills are attached
I reviewed the bill for February 23, 2008 showing a call made to Los Angeles, California. I did not make that call. I also reviewed the bill for February 25, 2008, showing several calls made to Duluth and Anoka, Minnesota. I did not make any of those telephone calls.
NOTE: Though the above stated the copies of the phone records are attached to the declaration the phone records were not attached to the declaration filed in the case at 7:41 PM March 13, 2012. See the Declaration HERE
In addition Parisi has gone from the original claims that Mrs. Byrnes was a relative of Larry Sinclair in Feb 2011; to claims that NO ONE called Larry Sinclair from the phone numbers listed in his book in August 2011; to now claiming that “The records show that the tipster called Sinclair prior to Feb 25, 2008 (the calls that Parisi claims never happened) once to his Hotel room in Los Angeles, and that now Sinclair’s tip is unreliable because Sinclair and the tipster may have colluded with each other.” Larry never colluded with anyone.
In addition, despite this article Why Do People Swear To Being Truthful When They Know They Are Lying? which was published August 19, 2011 clearly showing the “Declaration of Robert Braddock” doesn’t match what can and has clearly been found on his resume, the filing contains that very declaration. Lets just include what is clearly on Mr. Braddock’s professional resume at the writing of this article as published on linkedin.com, please note the section in RED:
Rob Braddock Jr.’s Summary
Democratic Political Fundraising Consultant.
Rob Braddock Jr.’s Experience
Progressive Capital Strategies
April 2011 – Present (1 year)
Progressive Capital Strategies is a full-service political and non-profit fundraising firm.
We specialize in developing and executing effective, targeted fundraising efforts for Democratic politicians on the local, state and federal level. Our team has the experience and the expertise to guide campaigns on every level to maximize fundraising potential.
Executive Board Member / Director of Fundraising
The Open Source Democracy Foundation
November 2010 – October 2011 (1 year)
A founding executive board member of The Open Source Democracy Foundation, a non-profit organization that is committed to improving government by harnessing the Internet as a tool for education and advocacy.
L.A. Harris & Associates
November 2008 – November 2010 (2 years 1 month)
Implemented finance / fund raising plans for Democratic politicians seeking the office of U.S. Senate, U.S. House of Representatives and State Senate, including the 2010 special election in PA-12 (Congressman Critz) and State Senator Mike Oliverio’s primary upset over a 28 year incumbant in WV-1.
Mary Norwood for Mayor
November 2008 – November 2009 (1 year 1 month)
Implemented finance and fund raising plan; exceeded $2,000,000 goal.
Harry Taylor for Congress
August 2008 – November 2008 (4 months)
Implemented finance and fund raising plan; raised more money than any previous Democratic campaign in the district.
Director of Business Development
September 2007 – August 2008 (1 year)
Conceived and spearheaded new site development; conceptualization, branding, hiring, content generation and monetization. Site is currently undergoing redesign.
Director of Sales and Business Development
August 2004 – September 2007 (3 years 2 months)
Developed entire business and sales platform. Hired, trained and supervised 25 sales representatives and achieved $7,200,000 in yearly billables within 2 years.
Despite this little fact Parisi still filed with his Motion on March 13, 2012 a declaration from Robert Braddock which swears he worked for Whitehouse.com as a videographer/reporter from Jan 2008 to June 2008! That’s somewhat less “Director of Business Development which is what Mr. Braddock’s professional resume states was his position at Whitehouse.com from September 2007 to August 2008.
Yesterday’s Court filing by Parisi demonstrates without any doubt Larry Sinclair DID receive the phone calls on Feb 25, 2008 that he said he did. The fact that Parisi now claims Sinclair worked “in collusion with the tipster” is yet another attempt to somehow try to save his civil suit which changes every time anyone involved in the case files a motion or a response/opposition to a Parisi motion. Look we would be fooling ourselves if we thought that Daniel Parisi or for that matter Patton Boggs LLP have any intention of moving on and ending this harassment litigation, but for Parisi to now for a third time try to file an amended or supplemented complaint which contains yet again even more contradictions; attempts to now want to argue on behalf of Barack Obama; and claim emotional duress is just simply an abuse of the courts by an officer of the court (Patton Boggs & Attorney Richard Oparil). One thing is clear, Barack Obama is NOT a party or plaintiff in this case and Parisi might want to remember the clear statements made on Feb 28, 2011 in open court, “we are not challenging the claims against Barack Obama made by Mr. Sinclair.”
But on March 13, 2012 at 7:41 PM Daniel Parisi by and through his counsel has now CONFIRMED for the world to see in a PUBLIC RECORD that despite claiming Larry Sinclair was lying about ever receiving any telephone calls from the numbers printed in his book, that Mr. Sinclair WAS and IS telling the TRUTH about those calls. And while it is clear the filing is meant to lure Mr. Sinclair into creating an dispute of material fact, it will not work.