Case 1:10-cv-00897-RJL Document 75 Filed 11/02/10 Page 1 of 3

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

)
DANIEL PARISI, et al., )
)
Plaintiffs, )
)
v. ) No. 1:10-cv-0897-RJL

et
)
LAWRENCE W. SINCLAIR a/k/a “Larry Sinclair”, )
et al., )

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)
Defendants. )
)

or
PLAINTIFFS’ REPLY TO SINCLAIR’S OCTOBER 25, 2010 LETTER
RESPONDING TO THE COURT’S OCTOBER 20, 2010 ORDER
FOR SPI TO RETAIN COUNSEL
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Plaintiffs, Daniel Parisi (“Parisi”), Whitehouse.com Inc., Whitehouse Network LLC

(“WNL”), and White House Communications Inc. (“WCI”) (collectively referred to as

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“plaintiffs”), hereby reply to the October 25, 2010 letter of defendant Lawrence Sinclair, which
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was written in response to the Court’s October 20, 2010 Order that defendant Sinclair

Publishing, Inc. (“SPI”) retain counsel by November 15 or show cause why SPI should not be
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sanctioned, including by entry of a default judgment. (Dkt. No. 65). A copy of Mr. Sinclair’s

letter is attached as Ex. 1.

Sinclair’s letter states that he has attempted to retain counsel to act for SPI to no avail.
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He writes that neither he nor SPI have the financial ability to retain counsel. Mr. Sinclair states

that he moved from Florida to Washington, D.C. to obtain counsel and was unsuccessful.

Sinclair now resides in Tennessee. His letter does not set forth any reasonable prospect that SPI

will be able to engage counsel to represent it in this litigation by November 15, 2010 or at any

time thereafter.

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 Case 1:10-cv-00897-RJL Document 75 Filed 11/02/10 Page 2 of 3

As the Court’s Order set forth, a corporation can only file documents and appear in court

proceedings through licensed counsel. Plaintiffs respectfully request that if counsel for SPI has

not entered an appearance here by November 15, the Court should sanction SPI, including by

granting plaintiffs’ motion for a default judgment against SPI.

Granting SPI additional time would prejudice plaintiffs. SPI and Mr. Sinclair were

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served on June 7, 2010. (Dkt. Nos. 3-4). A default judgment can be enforced. SPI should not be

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provided with additional time in which to potentially hide or dissipate any assets that it might

still own. Moreover, a default as to SPI would not affect Mr. Sinclair’s ability to assert whatever

or
personal defenses he might have to the claims against him.

For the foregoing reasons, plaintiffs’ motion for sanctions against SPI, including default

judgment, should be granted.

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Dated: November 2, 2010 Respectfully submitted,
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/s/ Richard J. Oparil
Richard J. Oparil (D.C. Bar No. 409723)
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PATTON BOGGS LLP

2550 M Street, NW
Washington, DC 20037
(202) 457-6000
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(202) 457-6315 (fax)

Kevin M. Bell
PATTON BOGGS LLP
8484 Westpark Drive
McLean, VA 22102
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(703) 744-8000
(703) 744-8001 (fax)

Attorneys for Plaintiffs

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 Case 1:10-cv-00897-RJL Document 75 Filed 11/02/10 Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on November 2, 2010, a copy of the foregoing was served on counsel

for the parties that have appeared in the case by the Court’s ECF system and on the following by

electronic mail:

Lawrence W. Sinclair

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PO Box 9222
Chattanooga, TN 37412
218-269-2274

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larry@larrysinclair.org

or
/s/ Richard J. Oparil
at Richard J. Oparil (DC Bar No. 409723)
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5129997
 Case 1:10-cv-00897-RJL Document 75-1 Filed 11/02/10 Page 1 of 4

Exhibit 1

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