| |
Main
Date: 16 Jan 2009 08:33:57
From: samsloan
Subject: Motion for Rule 11 Sanctions Against Bill Brock and Attorney Patrick
|
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
__________________________________________
Sam Sloan,
Plaintiff,
Civil Action No. 07-CV-8537 (DC)
-against-
Hoainhan =93Paul=94 Truong, Zsuzsanna =93Susan=94 Polgar, Joel Channing,
William Goichberg, The United States Chess Federation, Bill Hall,
Herbert Rodney Vaughn, Gregory Alexander, Frank Niro, Grant Perks,
William Brock, Randall Hough, Randy Bauer, Jim Berry, Texas Tech
University and United States of America,
Defendants
__________________________________________
NOTICE OF MOTION of Plaintiff's Rule 11 Cross-Motion for Sanctions
against Defendant William Brock and his counsel, Patrick M. O'Brien
__________________________________________
PLEASE TAKE NOTICE that the undersigned hereby moves this court for
Rule 11 Sanctions against Defendant William Brock and his counsel
Patrick M. O'Brien, on the grounds that Mr. Brock and his counsel are
stalkers and harassers of Plaintiff and his family for the last four
years and this stalking and harassment is continuing to this day
through this court process involving this case.
Yours, etc.
Samuel H. Sloan
1664 Davidson Ave., Apt. 1B
Bronx NY 10453-7877
1-917-507-7226
1-917-659-3397
[email protected]
Copy to:
Patrick M. O'Brien, Esq.
Attorney for William Brock
309 Elmore Street
Park Ridge, Illinois 60068-3569
Jeremy Brown
Attorney for USCF, William Goichberg defendants
Proskauer Rose LLP
One Newark Center
Newark NJ 07102-5211
Joseph J. Ortego
Nixon Rose LLP
Attorneys for Hoainhan =93Paul=94 Truong and Zsuzsanna =93Susan=94 Polgar
50 Jericho Quadrangle
Jericho NY 11753-2729
Emily E. Daughtry
US Attorney's Office
86 Chambers Street, 3rd Floor
New York NY 10007-2632
Arthur M. Handler
805 Third Avenue, 8th Floor
New York NY 10022
Scot M. Graydon
Attorney for Texas Tech University
Assistant Attorney General, General Litigation Division
Attorney General of Texas
PO Box 12548
Austin Texas 78711-2446
June Duffy
Assistant Attorney General of New York
120 Broadway
New York NY 10271
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
__________________________________________
Sam Sloan,
Plaintiff,
Civil Action No. 07-CV-8537 (DC)
-against-
Hoainhan =93Paul=94 Truong, Zsuzsanna =93Susan=94 Polgar, Joel Channing,
William Goichberg, The United States Chess Federation, Bill Hall,
Herbert Rodney Vaughn, Gregory Alexander, Frank Niro, Grant Perks,
William Brock, Randall Hough, Randy Bauer, Jim Berry, Texas Tech
University and United States of America,
Defendants
__________________________________________
MOTION and CROSS-MOTION for Rule 11 Sanctions against Defendant
William Brock and his counsel Patrick M. O'Brien
__________________________________________
STATE OF NEW YORK )
ss:
COUNTY OF BRONX )
Samuel H. Sloan, being duly sworn, deposes and says:
1. I hereby move for Rule 11 Sanctions against Defendant William Brock
and his counsel Patrick M. O'Brien.
2. The defendant and his counsel herein have been stalking and
harassing me and my family for the last four years since 2004, for
what reason I do not know, because I had never even heard of either
one of them until I noticed what eventually became thousands of
postings on the Internet calling me a =93child molester=94.
3. This process has continued every single day. Every day, defendant
Bill Brock calls me a =93child molester=94 hundreds of times PER DAY.
4. Even today, as I am typing these very words, Bill Brock has already
called me a child molester several times this morning, and it is now
only 7:00 AM. This will continue all day long today. By the end of
today Mr. Brock will have called me a child molester at least a
hundred more times.
5. Just to make this entirely clear, I have never in my entire life
been arrested, charged, implicated, accused, indicted, convicted,
investigated or any thing else remotely related to child molestation
or any other sex crime of any nature whatever by any court, any law
enforcement authority or any other governmental investigating body
anywhere in any country of the world.
6. The fact thar Bill Brock calls me a child molester hundreds of
times per day can be easily verified. Just do a simple Google search
for the words =93Sam Sloan Child Molester=94 and you will find right now
3710 referenced to that, almost all of which will be signed by Bill
Brock. That is only a small portion of the number of times that Bill
Brock has called me a child molester.
7. Mr. Brock is obviously a very sick, emotionally disturbed man. He
is also dangerous. He needs a long rest in a mental institution where
he can learn to deal with his fantasies about =93child molestation=94 that
he has admitted to having.
8. This goes far beyond just Internet postings. Mr. Brock has pursued
me and my family members, including my wife and children, on a broad
front. Only Monday of this week, my wife was called down to testify
before the New York State Department of State on a complaint filed by
Bill Brock. Mr. Brock is trying to have my license and my wife's
license as a notary public revoked. I enclose an an exhibit a copy of
the complaint filed by Bill Brock with the New York State Department
of State against my wife.
9. By the way, does not this complaint filed by Bill Brock with the
New York State Department of State give New York Jurisdiction over
this case?
10. In addition, Bill Brock has had both me and my wife kicked off of
Ebay, so I cannot sell the books that I publish on Ebay, thereby
depriving me and my family of a substantial source of income. Mr.
Brock does not deny doing these things. To the contrary he BRAGGS that
he has done this. Here is his posted comment on having me kicked out
of Ebay.
billbrock
View profile
(2 users) More options Jul 28 2008, 2:34 pm
Newsgroups: alt.marketing.online.ebay, rec.games.chess.politics
From: billbrock <[email protected] >
Date: Mon, 28 Jul 2008 12:34:29 -0700 (PDT)
Local: Mon, Jul 28 2008 2:34 pm
Subject: Re: Thank you Bill Brock for your One Penny book!!!
Reply to author
|
|
| |
Date: 27 Jan 2009 07:48:10
From: samsloan
Subject: Re: Motion for Rule 11 Sanctions Against Bill Brock and Attorney
|
On Jan 27, 10:24=A0am, billbrock <[email protected] > wrote:
> Any word from the Court?
You need to apply for an account with PACER. To get one, apply at:
http://pacer.psc.uscourts.gov/uspci.html
Warning: The cost is 8 cents per page.
If you had one, you would know that there is no word from the court
yet.
I am tracking five federal cases there and I check there once every
few days.
They are:
Sloan vs. Smith in the Western District of Virginia
Sloan vs. Truong in the Southern District of New York.
Polgar vs. USCF in the Northern District of Texas
USCF vs. Polgar in the Northern District of California
Parker vs, Polgar and Truong in the Eastern District of Pennsylvania
None of these cases have any changes or new entries in the last few
days.
Potentially the most significant case is the Illinois state case of
USCF vs. Polgar and Truong in Springfield, Illinois. Being a state
court case, it is not on the PACER system.
Sam Sloan
|
| |
Date: 16 Jan 2009 16:47:22
From: samsloan
Subject: Re: Motion for Rule 11 Sanctions Against Bill Brock and Attorney
|
The motion was filed today in the federal courthouse at 4:32 PM.
I made some slight typographical changes before filing it.
I will send the final version to opposing counsel by email as well as
by regular mail.
Sam Sloan
|
|
