EFTA01125772Set 9
2012-08-1027p6,733w
Board
of Directors and Executive Committee, to serve as the WAC Website's webmaster.
8. Defendants' defamatory statements are palpably false and are clearly intended to
defame and publicly humiliate ... Banco Venezolano and its Executive Committee, to serve as the WAC Website's
webmaster. The webmaster of a website exercises virtually complete control of the content over
the website ... also in many instances manages the administrative access, which effectively
enables the webmaster to restrict those who may have access to the website for any purposes.
45. The WAC Website
https://www.justice.gov/epstein/files/DataSet%209/EFTA01125772.pdf