IN THE HIGH COURT OF JUSTICE ANTIGUA AND BARBUDA CIVIL DIVISION BETWEEN: ALKI DAVID Petitioner -and- DAVID BOIES, MARTIN DELUCA, and BOIES SCHILLER FLEXNER LLP Respondents --- PETITION FOR DECLARATORY RELIEF, INJUNCTION, AND SANCTIONS FOR MALICIOUS PROSECUTION, ABUSE OF PROCESS, AND CONSPIRACY TO THE HONOURABLE COURT: The Petitioner, ALKI DAVID, respectfully applies to this Honourable Court for declaratory relief, injunction, and sanctions against the above-named Respondents, and states as follows: I. INTRODUCTION 1. This Petition arises from the deliberate and malicious filing of civil proceedings in the United States District Court, Southern District of New York (SDNY), against the Petitioner and the Honourable Prime Minister of Antigua and Barbuda, Gaston Browne. Filed by Boies Schiller Flexner LLP under David Boies and Martin DeLuca, the case was dismissed by SDNY on June 5, 2025, recognizing it as a baseless fishing expedition. This supports the Government of Antigua and Barbuda’s public position labelling the litigation as malicious and abusive. 2. The Respondents’ actions form part of a coordinated campaign to destabilize the Petitioner and the Government of Antigua through malicious litigation and reputational sabotage. These actions were backed by CBS Corporation, leveraging Boies Schiller as a proxy to retaliate against the Petitioner’s media platform, CBSYouSuck.com, which exposes corruption within the media monopoly. 3. The Petitioner previously prevailed in legal action against CBS Interactive and in FilmOn v. DoubleVerify, where corporate defamation was proven. DoubleVerify, owned by Comcast, is linked to Boies Schiller, which acted to suppress the Petitioner’s broadcasting ventures and intellectual property. 4. The Petitioner was also targeted through attempts to unlawfully seize control of his company, Hologram USA, including its valuable patent portfolio related to the Michael Jackson Hologram Tour. Key conspirators include John Branca, Gloria Allred, Lisa Bloom, and Ari Emanuel, the latter of whom later acquired the Petitioner’s Malibu residence, unlawfully seized through perjured testimony by Chasity Jones. 5. David Boies maintained deep legal and financial relationships with Lisa Bloom (notably during the Epstein litigation), Tom Girardi, and Louis Freeh. These individuals, alongside Fred Heather, coordinated threats and legal warfare against the Petitioner and his mother, Mrs. Dimitra David, including coercion to pay millions under threat of false criminal allegations. 6. Fred Heather, while acting as the Petitioner’s lawyer, concealed his partnership with Robert Shapiro (who threatened the Petitioner’s life) and Louis Freeh. This constitutes gross legal misconduct and fiduciary betrayal. 7. Anthony Pellicano, known enforcer and convicted racketeer, visited the Petitioner’s Malibu home twice pretending to broker peace with Gloria Allred. That same week, Pellicano coordinated a planned hit on the Petitioner through Joseph Chora, acting on behalf of Allred and Bloom. 8. Daphne Barak, half-sister of former Israeli PM Ehud Barak and long-time associate of David Boies and Shari Redstone, took $10,000 from the Petitioner under false pretenses, promising positive media coverage. Instead, she coordinated with Nir Yatom (son of Mossad chief Danny Yatom) and the Petitioner’s brother-in-law Dani Peretz—agents reselling Black Cube services in Switzerland—to funnel intelligence and weaponize a $100M family trust against the Petitioner. Barak has been to Antigua before, bribing the late Asot Michael by her own admission—one million dollars to affect elections. 9. Mrs. Dimitra David, aged 84, was threatened with having her son falsely convicted of rape if she did not cooperate. She was forced to undergo psychiatric evaluations to defend her sanity in the face of intimidation by Fred Heather, Shapiro, and Freeh’s network. Her life and that of her attorney, Themis Sophos, has been threatened by Dani Peretz, Fred Heather, and Robert Shapiro, and also attacked directly by Louis Freeh in concert. Freeh was in Sardinia with Peretz last summer for three weeks according to witnesses. Peretz has weaponized $100 million he stole against the Petitioner with Freeh and Fred Heather. 10. This network constitutes a transnational criminal enterprise based in Hollywood that uses lawfare, perjury, surveillance, and corrupt litigation to target and extort high-net-worth individuals—of which the Petitioner is one. This includes actions in Antigua, the UK, Switzerland, and the United States. They have repeatedly attempted to steal the Petitioner’s hologram patents and have been repeatedly sued for it. II. PRAYER FOR RELIEF WHEREFORE, the Petitioner respectfully requests the Honourable Court to: 1. Declare that the Respondents’ actions constitute malicious prosecution, abuse of process, and an act of international lawfare; 2. Issue an injunction prohibiting any further coordinated legal action by the Respondents or their affiliates against the Petitioner in Antigua; 3. Recommend referral of this case to international legal and human rights authorities, including the UN and INTERPOL; 4. Grant orders for restitution and compensation for damages, including loss of property and intellectual rights; 5. Refer violations by officers of the court (including Fred Heather and Robert Shapiro) to appropriate bar disciplinary tribunals; 6. Grant any further relief this Honourable Court deems just. CASE STATEMENT: RICO ENTERPRISE BY GLORIA ALLRED, LISA BLOOM & CO. Plaintiff: Alkiviades “Alki” David Defendants: Gloria Allred, Lisa Bloom, Tom Girardi, Gary Dordick, and others Cause of Action: Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. §§ 1961–1968 Exhibits Referenced: AD-1, Pages 1–77+ (detailed herein) INTRODUCTION: A SYNDICATE IN LEGAL ROBES This is a case about organized legal warfare masquerading as justice. Including Gloria Allred, Lisa Bloom, and their inner circle—including disbarred and imprisoned attorney Tom Girardi—have operated what can only be described as a racketeering enterprise under the guise of law firms. These firms—Allred, Maroko & Goldberg; The Bloom Firm; and Girardi Keese—have systematically weaponized civil litigation to extort public figures like Plaintiff Alki David, leveraging false claims, defamation, media manipulation, and fraudulent court tactics in California and abroad, including Switzerland. Their misconduct has been egregious, well-coordinated, and lucrative. This lawsuit is a reckoning. EXHIBITS THAT DEMAND JUDICIAL NOTICE Exhibit 1 – Visual Evidence of Conspiracy On page 40, a now-viral meme ("SCAM INC.") lays out the heart of the RICO web: Gloria Allred, Tom Girardi, and Lisa Bloom—pictured together—representing a public face of legitimacy hiding a criminal enterprise. Exhibit 2 – Swiss Legal Rejection of Their Enterprise On pages 58–61, Swiss courts formally reject enforcement of Allred’s U.S. punitive damage judgments, citing Article 135(2) Swiss Private International Law. Lauren Reeves and Mahim Khan falsely claimed Plaintiff was criminally convicted, which under Swiss Penal Code Articles 173 and 174 constitutes wilful defamation—a criminal act. Swiss attorney Arthur Seppey corroborates these abuses. Exhibit 3 – Witness Coaching & Document Forgery On page 51, a letter from attorney Murray Greenberg details how Allred’s team, during the Mahim Khan trial, forged opposing counsel’s signature on an exhibit list—while lead defense counsel Ellyn Garofalo was under wildfire evacuation. Judge Michelle Williams Court ignored this felony-level misconduct. Exhibit 4 – Police Report: Witness Intimidation by Khan On page 37, a Woodbridge Police Department report shows Mahim Khan threatened her roommate’s daughter to prevent her from testifying for Plaintiff David. This is a clear act of witness intimidation and obstruction of justice. Exhibit 5 – YouTube Footage: Bloom Screaming “Rape” in Courthouse Lobby On page 40, a public video shows Lisa Bloom screaming defamatory rape accusations in a public courthouse foyer, traumatizing bystanders including a mother and her child. Video: Alki David Attacks the Crew (YouTube) Exhibit 6 – Instagram Polygraph Report On page 67, Plaintiff’s Instagram displays a confidential polygraph exoneration confirming no misconduct occurred—ignored by the media, buried by Allred and Bloom. MODUS OPERANDI: NAME, SHAME, AND SHAKEDOWN Step 1: Target high-net-worth individuals (David, Steve Wynn, Alan Dershowitz, 50 Cent, Princess Latifa) with salacious, media-ready lawsuits. Step 2: Coach "victims" using fear, threats, and promises of payout (see affidavits of Carl Bowen and Mary Rizzo). Step 3: Flood courts with nearly identical lawsuits through shell firms and law firm proxies (Allred sends one plaintiff to Bloom, who passes another to Dordick, etc.). Step 4: Use media blackmail via TMZ, The Daily Beast, and the LA Times to pressure settlements (Taylor dropped her claims after three years of public maligning). Step 5: Attempt extraterritorial collection—violating Swiss law to freeze international assets in Gstaad, Switzerland, despite non-final U.S. judgments. THE RICO FRAMEWORK (18 U.S.C. §§ 1962(b), (c), (d)) Each named attorney and firm is a "culpable person" participating in an enterprise engaging in: Extortion (via settlement demands and public smearing) Mail and Wire Fraud (through fraudulent filings and coached testimony) Witness Tampering (threats, payments, forgery, and signature falsification) Bribery and Obstruction of Justice (e.g., Goldberg’s falsified court documents) International Criminal Violations (Article 173 and 174 SCC – Switzerland) DAMAGES Over $150 million USD in fraudulent judgments Lost profits from derailed IPOs of FilmOn and SwissX Destruction of Plaintiff’s reputation and psychological distress International asset freezes and litigation costs CONCLUSION: LAW AS A WEAPON OF TYRANNY This case proves the adage: "Where law ends, tyranny begins." The Defendants in this matter have twisted the rule of law into a cash machine. They are not advocates. They are racketeers hiding behind legal credentials, weaponizing the MeToo movement, silencing dissent with media echo chambers, and harvesting settlements from a trail of manufactured victims. Justice must now respond. DATED this ___ day of June, 2025. Respectfully submitted, ALKI DAVID, Petitioner (in person)