Count VIII Theft of Trade Secrets (18 U.S.C. § 1830-32)

1. The Plaintiff owns and possesses certain non-public, proprietary, sensitive and confidential information and data, including without limitation, DNS data.

2. DNS internet traffic data houses highly proprietary, sensitive and confidential data. For example, among other things, an analysis of raw DNS data could reveal a comprehensive view into an individual or a company’s website traffic, e-mail traffic, webmail traffic, chat messaging, in addition to the types of technology, hardware, software, programs, securities and processes being utilized by the servers.

3. Neustar and Joffe, at the direction of Perkins Coie, Sussmann, Clinton Campaign, DNC, and Clinton, exploited access to non-public data sources and/or servers, and unlawfully acquired, stole and exploited sensitive, proprietary and confidential internet data, including without limitation, DNS information, traffic, and/or data originating from computers and/or servers:

(i)located at Plaintiff’s private apartment in Central Park West in New York and belonging to the Plaintiff; and

(ii) located at Trump Tower and belonging to The Trump Organization, in which Plaintiff has an ownership interest (collectively, with the computers and/or servers house in Plaintiff’s private apartment, “Plaintiff’s Servers”).

1. Joffe and Neustar exploited their access to non-public data to, among other things, mine DNS traffic and other data from Plaintiff’s Servers for the purpose of gathering derogatory information about the Plaintiff.

2. In doing so, Joffe and Neustar intentionally accessed, without authorization, Plaintiff’s Servers.

[page 89]

>>15938672

1. Defendants, Neustar and Joffe, violated the Defend Trade Secrets Act, 18 U.S.C. § 1832(a)(1), by knowingly obtaining the Plaintiff’s confidential records by fraud, artifice, and deception and, thereafter, stealing, appropriating, taking, carrying away, and concealing the theft of the Plaintiff’s confidential records with intent to convert the Plaintiff’s confidential records, which are related to products sold in interstate and foreign commerce, to the Defendants’ own benefit, while knowing and intending that such misappropriation would injure the Plaintiff.

2. Defendants, Perkins Coie, Sussmann, Clinton Campaign, DNC, and Clinton, conspired with Neustar and Joffe to commit the above-named acts in furtherance of the overarching conspiracy to denigrate and spread injurious falsehoods to harm the Plaintiff’s political career and to impede his ability to effectively govern.

3. Defendants, Perkins Coie, Sussmann, Clinton Campaign, DNC, and Clinton, conspired with Neustar and Joffe to violate the Defend Trade Secrets Act, 18 U.S.C. § 1832(a)(1), by assisting, aiding, and abetting Neustar and Joffe in obtaining Plaintiff’s proprietary, sensitive and confidential information and data by fraud, artifice, and deception and, thereafter, stealing, appropriating, taking, carrying away, and concealing the theft of Plaintiff’s confidential records with intent to convert Plaintiff’s confidential records, which are related to products sold in interstate and foreign commerce, to Defendants’ own benefit, while knowing and intending that such misappropriation would injure the Plaintiff

4. Each of the Defendants, Perkins Coie, Sussmann, Clinton Campaign, DNC, and Clinton, were aware of, and active participants in, the conspiracy for Neustar and Joffe’s to violate the Defend Trade Secrets Act, 18 U.S.C. § 1832, and each of the RICO Defendants committed at least one act in furtherance of this goal.

1. The theft of the protected trade secrets has damaged the Plaintiff.

2. The actions of Defendants, Neustar and Joffe, constitute theft of trade secrets in violation of 18 U.S.C. § 1832(a)(1).

3. The actions of Defendants, Perkins Coie, Sussmann, Clinton Campaign, DNC, and Clinton, constitute a conspiracy to steal trade secrets in violation of 18 U.S.C. § 1832(a)(5).

[pages 91-92]

ANNAPOLIS, MD: "On Thursday, Governor Larry Hogan announced $45 million of investments into major violent crime initiatives, but his push to re-fund the police, hasn’t been met without criticism. Hogan proposed $3.5 million to fund new positions in the U.S. Attorney’s Office and another $6.5 million to expand the Baltimore Police Department’s Warrant Apprehension Task Force.

“Baltimore City leaders will never get control of the out-of-control violence if they don’t arrest more, prosecute more and give tougher sentences to the most violent criminals,” said Hogan.

While Hogan says investments into public safety is how to address violent crimes, others such as Zakyia Sankara-Jabar, Co-Founder & Co-Director of Racial Justice Now! argues that more policing doesn’t mean more safety, especially to black and brown people.

“Black people are occupied by the police, we’re seen as the object of fear by certain people, and and the police is oftentimes weaponized against our communities,” said Sankara-Jabar.

Hogan also noted during his press conference that the state has invested money in trying to address the root issues of crime such as mental health and workforce development. But Hogan says violent offenders need to be off the street and in jail."

https://www.localdvm.com/news/maryland/gov-hogan-announces-45m-in-initiatives-to-address-crime/

>>15938737

I remember reading that. The burger didn't change at all…no mold, and I think insects weren't interested either. kek

>>15938745

Hogan is term-limited. This is his last.