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Main
Date: 02 Feb 2008 06:50:52
From: samsloan
Subject: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
__________________________________________
Sam Sloan,
Plaintiff,
Civil Action No. 07-CV-8537 (DC)
-against-
Hoainhan "Paul" Truong, Zsuzsanna "Susan" 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
__________________________________________
AFFIDAVIT IN OPPOSITION TO
MOTION TO DISMISS ON DIVERSITY ISSUE
__________________________________________
Samuel H. Sloan, the plaintiff herein, being duly sworn, deposes and
says:
1. I make this affidavit in opposition to the motion by William
Goichberg and others to dismiss this action on the grounds of lack of
diversity jurisdiction. This affidavit only addresses the diversity
issue. I will address other issues in other affidavits.
2. Please note that the affidavit of William Goichberg in support of
his motion to dismiss sworn to the 9th day of January 2008 is
notarized by Pi Ning Cheung, Notary Public - California, Los Angeles.
3. It seems odd that a person who claims to reside in New York and who
has known about this lawsuit since it was filed on October 2, 2007
would not be able to obtain a notary public in New York State who is
willing to state that he knows Mr. Goichberg.
4. I have known William Goichberg since 1961 when he defeated me in
the Eastern Open Chess Championship in Washington DC. One would
imagine that since I have known him for 47 years and served on the
board with him for one year that I would know where he lives.
5. In his moving affidavit he states that his residence is at 2084
Route 94, Salisbury Mills NY 12577. If that is the case, how come I
cannot find this address listed anywhere? Not only it is not listed
anywhere as his address, but it is not listed anywhere at all.
6. In fact, the address of 2084 Route 94, Salisbury Mills NY 12577
DOES NOT EXIST.
7. My investigation confirms that 2084 Route 94, Salisbury Mills NY
12577 is not a residence or a domiciliary address. I have checked
every possible source for the address of 2084 Route 94, Salisbury
Mills NY 12577. For example, I checked the US Postal Service website
which has the full 9-digit zip code for every address in America at
http://zip4.usps.com/zip4/welcome.jsp
8. Inputting that address yields the following answer:
We're sorry! We were unable to process your request.
The address was not found. Please check the address below.
You may want to utilize the Yellow Pages and/or White Pages below.
9. I have checked every other possible source, including
mapquest.com , Google Earth, Google Maps and none of them show an
address in existence of 2084 Route 94, Salisbury Mills NY 12577.
10. A real estate site, zillow.com , shows 2084 Route 94, Salisbury
Mills NY 12577, to be an empty lot.
11. Bill Goichberg had better come up with a really good explanation
for this.
12. Bill Goichberg lives a vagabond life, constantly traveling from
place to place, from chess tournament to chess tournament, from horse
racing track to horse racing track. It is true that he has a telephone
number in Salisbury Mills but in the many times I have called that
number over a period of many years nobody has ever answered the phone.
He seems to have it on permanent voicemail. For the past more than 40
years, Bill Goichberg has carried ads for his chess tournaments in
every issue of Chess Life, always providing another address where to
send the entry fees for his chess tournaments. The street address he
provides in this pleading has never previously been provided anywhere
else. I know many people who know Bill Goichberg even better than I do
and none of them had ever heard of this street address before. If what
he says is true, he has been keeping his residence address secret for
the last 17 years and has revealed it now just to defeat my diversity
claim.
13. So far, Goichberg has submitted no evidence in support of his
claim. He has provided no income tax returns, no deed or title to
property, no gas nor electric bills nor anything else to establish
that his priy domicile is in New York State. (The law speaks of
"domicile" not residence.)
14. Bill Goichberg is not presently in New York State. He is now in
Southern California and has been there since October.. He currently
resides at the Santa Anita Inn, at 130 West Huntington Drive, Arcadia,
CA 91007 and plans to stay there at least through the winter. As the
name suggests, it is next to the Santa Anita Race Track where Bill
Goichberg is a race horse handicapper. He plays a system based on the
USCF Rating System.
15. His claim is that he "intends to return to New York State". Intent
to return to New York does not establish residence or domicile and
does not defeat diversity jurisdiction. Indeed, asserting that he
intends to return is a tacit admission by Mr. Goichberg that he is not
currently a resident or domiciliary of New York State.
16. Accordingly, diversity is established and a motion to dismiss on
that ground must be denied. At a very minimum there will have to be a
fact-hearing where Goichberg will be required to produce evidence if
he has any that he is domiciled in New York State, especially since he
is nowhere to be found in New York State and has not been here in
quite some time.
17. In addition, it is not necessary to reach diversity because there
are federal questions involved in this case. Also, if worse comes to
worst I would just have to drop Goichberg as a defendant because it is
clear that all of the other defendants are domiciled outside of New
York State.
_____________________
Samuel H. Sloan
1664 Davidson Ave., Apt. 1B
Bronx NY 10453
917-507-7226
1-347-869-2465
[email protected]
STATE OF NEW YORK )
ss:
COUNTY OF BRONX )
VERIFICATION
_________________________
Signature of Petitioner
On the 2nd Day of February, 2008 before me personally came Samuel H.
Sloan to me known to be the person described herein and who executed
the foregoing instrument. Such person duly swore to such instrument
before me and duly acknowledged that he executed the same.
_____________________________
NOTARY PUBLIC
Affidavit of Service
Samuel H. Sloan, being duly sworn, deposes and says that on February
2, 2008 he mailed the within affidavit in opposition to motion to
dismiss this action for lack of diversity to the following addresses:
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 "Paul" Truong and Zsuzsanna "Susan" Polgar
50 Jericho Quadrangle
Jericho NY 11753-2729
Emily E. Daughtry
Attorney for United States of America
US Attorney's Office
86 Chambers Street, 3rd Floor
New York NY 10007-2632
Patrick M. O'Brien, Esq.
Attorney for William Brock
309 Elmore Street
Park Ridge, Illinois 60068-3569
Arthur M. Handler
Attorney for William Brock
Handler & Goodman LLP
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
__________________________
Samuel H. Sloan
Sworn to before me this 2nd
Day of February, 2008
______________________________
NOTARY PUBLIC
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Date: 08 Feb 2008 10:14:46
From: samsloan
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
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[quote="mcurtis"][quote="samsloan"]With all of this jibber-jabber,
Bill Goichberg still has not provided a verifiable street address
where he can be found on a regular basis.
[/quote]
Last weekend, Bill was at the Santa Anita Inn, in Arcadia, CA. Does
that help?
~
[img]http://www.ipnow.org/images/1/FFFFFF/000000/myinfo.jpg[/img] Your
IP Address is public information[/quote]
Right:
Goichberg stays in Santa Anita Inn, Room 267 and eats daily at
Sir Georges Smorgasbord
9 Las Tunas Dr
Arcadia, CA 91007
(626) 445-1611
which is on the corner of Santa Anita Avenue and Las Tunas Drive.
Great place!! All you can eat for $10 !!!
Problem is: Goichberg does not know the postal address of the place
where he claims to live in New York, so that causes a problem for him
to establish New York Domiciliary.
Sam Sloan
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Date: 08 Feb 2008 10:22:25
From: J.D. Walker
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
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samsloan wrote:
> [quote="mcurtis"][quote="samsloan"]With all of this jibber-jabber,
> Bill Goichberg still has not provided a verifiable street address
> where he can be found on a regular basis.
> [/quote]
> Last weekend, Bill was at the Santa Anita Inn, in Arcadia, CA. Does
> that help?
> ~
> [img]http://www.ipnow.org/images/1/FFFFFF/000000/myinfo.jpg[/img] Your
> IP Address is public information[/quote]
>
> Right:
> Goichberg stays in Santa Anita Inn, Room 267 and eats daily at
> Sir Georges Smorgasbord
> 9 Las Tunas Dr
> Arcadia, CA 91007
> (626) 445-1611
>
> which is on the corner of Santa Anita Avenue and Las Tunas Drive.
>
> Great place!! All you can eat for $10 !!!
>
> Problem is: Goichberg does not know the postal address of the place
> where he claims to live in New York, so that causes a problem for him
> to establish New York Domiciliary.
>
> Sam Sloan
Is that one of those pig palaces where one has to wear hip waders to
make their way through last weeks spilled food on the floor?
--
Cordially,
Rev. J.D. Walker, MsD, U.C.
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Date: 08 Feb 2008 12:01:28
From: Mike Murray
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
On Fri, 08 Feb 2008 10:22:25 -0800, "J.D. Walker"
<[email protected] > wrote:
>Is that one of those pig palaces where one has to wear hip waders to
>make their way through last weeks spilled food on the floor?
And they don't let musicians with instrument cases in the door ?
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Date: 08 Feb 2008 07:48:09
From: samsloan
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
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[quote="chessoffice"]New York State includes the hamlet of Blooming
Grove (Orange County), the town of Blooming Grove (Orange County), and
another unconnected Blooming Grove far away from Orange County. The
town of Blooming Grove includes Salisbury Mills as well as the hamlet
of Blooming Grove and some other places.
The following appears at the town website (townofbloominggroveny.com/
townhistory.html):
Town of Blooming Grove
(founded in 1799)
The Hamlet of South Blooming Grove was formed in July 2006, king
the creation of the first new community in Orange County in nearly 30
years.
FACTS:
Over 35 square miles
Population (2000 census): 17,351
Median Age: 36
Median Income: $74,428
For a detailed, in-depth look at Blooming Grove's Community Profile,
please visit ePodunk.com
COMMUNITIES WITHIN THE BORDERS OF THE TOWN OF BLOOMING GROVE:
The Village of Washingtonville
The Hamlet of Blooming Grove
The Hamlet of South Blooming Grove
Craigsville
Mountain Lodge
Salisbury Mills
SCHOOL DISTRICTS ATTENDED BY BLOOMING GROVE RESIDENTS:
Washingtonville Central School District
Monroe-Woodbury Central School District
Bill Goichberg[/quote]
With all of this jibber-jabber, Bill Goichberg still has not provided
a verifiable street address where he can be found on a regular basis.
None of these addresses are recognized by the United States Postal
Service.
The courts will need an actual street address, not a PO Box, and so
far Bill Goichberg has not provided one.
Perhaps he should ask the people who live in the house about where the
post office delivers their mail. Every house has an address recognized
by the post office and Bill Goichberg should reveal that address, if
he knows it.
Sam Sloan
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Date: 10 Feb 2008 19:54:41
From: Ray Gordon, creator of the \pivot\
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
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> The courts will need an actual street address, not a PO Box, and so
> far Bill Goichberg has not provided one.
He has an attorney, which is usually all the courts list on PACER.
He also is a USCF officer, which means he can be served through them, or
through CCA, which he owns, OR at one of his tournaments, etc.
--
Ray Gordon, The ORIGINAL Lifestyle Seduction Guru
http://www.cybersheet.com/library.html
Includes 29 Reasons Not To Be A Nice Guy
Ray's new "Project 5000" is here:
http://groups.yahoo.com/group/project-5000
Don't rely on overexposed, mass-keted commercial seduction methods which
no longer work.
Thinking of taking a seduction "workshiop?" Read THIS:
http://www.dirtyscottsdale.com/?p=1187
Beware! VH-1's "The Pickup Artst" was FRAUDULENT. Six of the eight
contestants were actors, and they used PAID TARGETS in the club. The paid
targets got mad when VH-1 said "there are no actors in this club" and ruined
their prromised acting credit. What else has Mystery lied about?
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Date: 11 Feb 2008 01:30:04
From: Guy Macon
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
Someone claiming to be Ray Gordon, creator of the "pivot" wrote:
>> The courts will need an actual street address, not a PO Box, and so
>> far Bill Goichberg has not provided one.
>
>He has an attorney, which is usually all the courts list on PACER.
>
>He also is a USCF officer, which means he can be served through them, or
>through CCA, which he owns, OR at one of his tournaments, etc.
Please don't post articles to games.chess.computer that have nothing
to do with computer chess. Thanks!
--
Guy Macon
<http://www.guymacon.com/ >
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Date: 12 Feb 2008 17:02:36
From: Ray Gordon, creator of the \pivot\
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
>>He also is a USCF officer, which means he can be served through them, or
>>through CCA, which he owns, OR at one of his tournaments, etc.
Guy,
Please stop flooding RGCP with repetitive complaints about crossposting, or
I'll do more of it.
--
Ray Gordon, The ORIGINAL Lifestyle Seduction Guru
http://www.cybersheet.com/library.html
Includes 29 Reasons Not To Be A Nice Guy
Ray's new "Project 5000" is here:
http://groups.yahoo.com/group/project-5000
Don't rely on overexposed, mass-keted commercial seduction methods which
no longer work.
Thinking of taking a seduction "workshiop?" Read THIS:
http://www.dirtyscottsdale.com/?p=1187
Beware! VH-1's "The Pickup Artst" was FRAUDULENT. Six of the eight
contestants were actors, and they used PAID TARGETS in the club. The paid
targets got mad when VH-1 said "there are no actors in this club" and ruined
their prromised acting credit. What else has Mystery lied about?
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Date: 05 Feb 2008 20:47:20
From:
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
The Historian wrote:
> On Feb 5, 8:41 pm, [email protected] wrote:
> > samsloan wrote:
> > > [quote="rfeditor"]Doesn't Sloan's argument amount to accusing Bill
> > > (with the connivance of his attorneys) of perjuring himself in a sworn
> > > affidavit? Isn't there something in the AUG about that? (BTW, I know
> > > several people who have visited Bill at his home. It's hardly
> > > surprising that Sloan is not among them.)[/quote]
> >
> > > Most likely Bill made a mistake in the address. The US Post Office
> > > does not recognize the address of 2084 Route 94, Salisbury Mills NY
> > > 12577.
> >
> > > However, if he does not know his own address, that probably indicates
> > > that he no longer lives there.
> >
> > > When did those several people visit Bill at his home? I will bet that
> > > it was years ago. Once the USCF moved away from New Windsor, there was
> > > no reason for Bill Goichberg to stay near there.
> >
> > > Sam Sloan
> >
> > False. Jerry Hanken has been there several times in recent years. Joe
> > Lux has telephoned him there. Donna Alarie found an on-line photo of
> > the place. Of course you can claim that they're all lying. Maybe
> > everybody's lying. Perhaps They go around tearing down all those false-
> > front buildings when they're not needed to deceive you. But I think
> > Heinlein already wrote that story.
>
> I have a friend who has been urging me to read Heinlein. I haven't,
> since I generally don't read science-fiction. Any recommendation for a
> good 'first' Heinlein, John?
Almost all of his pre-1960 work is great. The later books are, well,
not bad, but sometimes harder to digest. If you can find a copy of
"The Past Through Tomorrow," a collection of his "Future History"
series, it's a good place to start, especially "The Man Who Sold the
Moon" and "Methuselah's Children."
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Date: 05 Feb 2008 20:19:56
From: Rob
Subject: Re: SOUP
|
On Feb 3, 7:55 am, Rob <[email protected] > wrote:
> On Feb 3, 7:24 am, Rob <[email protected]> wrote:
>
> > On Feb 2, 12:24 pm, Rob <[email protected]> wrote:
>
> > > S: ome
> > > O: ther
> > > U: seless
> > > P:ost
>
> > ditto
>
> :-)
16. Rob
View profile
Mohammed Sloan has lost his mind Who- Ha, Who-Ha Look as he may he
just cant find Reason nor a rhyme The greatest of his time? The
greatest in his mind! Mohammed Sloan has lost his mind But it ain't
worth a dime. Mohammed Sloan he breaks the law Who-ha, who -ha Files
lawsuit like you you never saw Annoying like a caw Greatest of all
time? Only in his mind Mohammed Sloan has lost his mind But it ain't
worth a dime. (sung to the tune of "Camptown Racers" - Hide quoted
text -- Show quoted text - > Sam Sloan
More options Feb 3, 12:16 pm
Newsgroups: rec.games.chess.politics, rec.games.chess.misc
From: Rob <[email protected] >
Date: Sun, 3 Feb 2008 10:16:00 -0800 (PST)
Subject: Some Otherwise Useless Post : SOUP
Reply
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Date: 05 Feb 2008 18:12:47
From: The Historian
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
On Feb 5, 8:41 pm, [email protected] wrote:
> samsloan wrote:
> > [quote="rfeditor"]Doesn't Sloan's argument amount to accusing Bill
> > (with the connivance of his attorneys) of perjuring himself in a sworn
> > affidavit? Isn't there something in the AUG about that? (BTW, I know
> > several people who have visited Bill at his home. It's hardly
> > surprising that Sloan is not among them.)[/quote]
>
> > Most likely Bill made a mistake in the address. The US Post Office
> > does not recognize the address of 2084 Route 94, Salisbury Mills NY
> > 12577.
>
> > However, if he does not know his own address, that probably indicates
> > that he no longer lives there.
>
> > When did those several people visit Bill at his home? I will bet that
> > it was years ago. Once the USCF moved away from New Windsor, there was
> > no reason for Bill Goichberg to stay near there.
>
> > Sam Sloan
>
> False. Jerry Hanken has been there several times in recent years. Joe
> Lux has telephoned him there. Donna Alarie found an on-line photo of
> the place. Of course you can claim that they're all lying. Maybe
> everybody's lying. Perhaps They go around tearing down all those false-
> front buildings when they're not needed to deceive you. But I think
> Heinlein already wrote that story.
I have a friend who has been urging me to read Heinlein. I haven't,
since I generally don't read science-fiction. Any recommendation for a
good 'first' Heinlein, John?
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Date: 05 Feb 2008 17:41:11
From:
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
samsloan wrote:
> [quote="rfeditor"]Doesn't Sloan's argument amount to accusing Bill
> (with the connivance of his attorneys) of perjuring himself in a sworn
> affidavit? Isn't there something in the AUG about that? (BTW, I know
> several people who have visited Bill at his home. It's hardly
> surprising that Sloan is not among them.)[/quote]
>
> Most likely Bill made a mistake in the address. The US Post Office
> does not recognize the address of 2084 Route 94, Salisbury Mills NY
> 12577.
>
> However, if he does not know his own address, that probably indicates
> that he no longer lives there.
>
> When did those several people visit Bill at his home? I will bet that
> it was years ago. Once the USCF moved away from New Windsor, there was
> no reason for Bill Goichberg to stay near there.
>
> Sam Sloan
False. Jerry Hanken has been there several times in recent years. Joe
Lux has telephoned him there. Donna Alarie found an on-line photo of
the place. Of course you can claim that they're all lying. Maybe
everybody's lying. Perhaps They go around tearing down all those false-
front buildings when they're not needed to deceive you. But I think
Heinlein already wrote that story.
|
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Date: 05 Feb 2008 17:21:53
From:
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
On Feb 5, 6:00 pm, samsloan <[email protected] > wrote:
> [quote="rfeditor"]Doesn't Sloan's argument amount to accusing Bill
> (with the connivance of his attorneys) of perjuring himself in a sworn
> affidavit? Isn't there something in the AUG about that? (BTW, I know
> several people who have visited Bill at his home. It's hardly
> surprising that Sloan is not among them.)[/quote]
>
> Most likely Bill made a mistake in the address. The US Post Office
> does not recognize the address of 2084 Route 94, Salisbury Mills NY
> 12577.
>
> However, if he does not know his own address, that probably indicates
> that he no longer lives there.
>
> When did those several people visit Bill at his home? I will bet that
> it was years ago. Once the USCF moved away from New Windsor, there was
> no reason for Bill Goichberg to stay near there.
>
> Sam Sloan
edited August 14, 2007:
http://en.wikipedia.org/w/index.php?title=New_York_State_Chess_Association&oldid=151295430
"The New York State Chess Association (NYSCA) is the oldest
continuously-run chess organization in the United States [....]
Its president is Bill Goichberg of Salisbury Mills in Orange County,
who is also U.S. Chess Federation president."
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Date: 05 Feb 2008 16:00:18
From: samsloan
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
[quote="rfeditor"]Doesn't Sloan's argument amount to accusing Bill
(with the connivance of his attorneys) of perjuring himself in a sworn
affidavit? Isn't there something in the AUG about that? (BTW, I know
several people who have visited Bill at his home. It's hardly
surprising that Sloan is not among them.)[/quote]
Most likely Bill made a mistake in the address. The US Post Office
does not recognize the address of 2084 Route 94, Salisbury Mills NY
12577.
However, if he does not know his own address, that probably indicates
that he no longer lives there.
When did those several people visit Bill at his home? I will bet that
it was years ago. Once the USCF moved away from New Windsor, there was
no reason for Bill Goichberg to stay near there.
Sam Sloan
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Date: 03 Feb 2008 10:16:00
From: Rob
Subject: Some Otherwise Useless Post : SOUP
|
Mohammed Sloan has lost his mind
Who- Ha, Who-Ha
Look as he may he just cant find
Reason nor a rhyme
The greatest of his time?
The greatest in his mind!
Mohammed Sloan has lost his mind
But it ain't worth a dime.
Mohammed Sloan he breaks the law
Who-ha, who -ha
Files lawsuit like you you never saw
Annoying like a caw
Greatest of all time?
Only in his mind
Mohammed Sloan has lost his mind
But it ain't worth a dime.
(sung to the tune of "Camptown Racers"
>
> Sam Sloan
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Date: 03 Feb 2008 10:13:27
From: samsloan
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
On Feb 3, 1:02 pm, "Chess One" <[email protected] > wrote:
> "samsloan" <[email protected]> wrote in message
>
> news:eb0438d2-93bb-4505-8df6-882ebdedc789@m34g2000hsb.googlegroups.com...
>
>
>
> > On Feb 3, 12:24 pm, "Chess One" <[email protected]> wrote:
> >> "samsloan" <[email protected]> wrote in message
>
> >>news:d5e7bac7-1af1-4d23-8a89-0fd36e3dc643@v46g2000hsv.googlegroups.com...
>
> >> > On Feb 3, 11:54 am, "Chess One" <[email protected]> wrote:
> >> >> "samsloan" <[email protected]> wrote in message
>
> >> >>news:7a436b71-a881-4ed5-b4a5-d403fa3ee03e@c23g2000hsa.googlegroups.com...
>
> >> >> > On Feb 3, 8:29 am, The Historian <[email protected]>
> >> >> > wrote:
> >> >> >> On Feb 3, 4:37 am, samsloan <[email protected]> wrote:
>
> >> >> >> > What does Rob ("The Robber") Mitchell think he is accomplishing
> >> >> >> > by
> >> >> >> > constantly overwriting other people's threads?
>
> >> >> >> Google Groups only displays the title of the most recent post in a
> >> >> >> thread.
>
> >> >> > Right. Now, does Rob ("The Robber") Mitchell think that the USCF is
> >> >> > going to hire him after all or that I am going to let him back in my
> >> >> > group because he keeps doing this?
>
> >> >> > I assume that Rob ("The Robber") Mitchell is the same person as
> >> >> > "Tennessee Vols" who has been attacking people over on Susan
> >> >> > Polgar's
> >> >> >http://www.chessdiscussion.com
>
> >> >> Nah! This is our own Which Mitch? Remember, the guy posted stuff at
> >> >> 'your'
> >> >> Yahoo group for 2 years until he asked questions about /your/ er...
> >> >> 'activities' and responsibilites for such reks as you make above!
>
> >> >> This is the real "Lex" Mitchell" aka "Blair-Slayer", and unless you
> >> >> are
> >> >> in
> >> >> truth, Super-Sloan of Metropolis, you'd bett'rn not mess up your
> >> >> Mitchells,
> >> >> boy, cuz this doggee /is/ gonna hunt!
>
> >> >> BTW - you really should not reveal materials about job applicants at
> >> >> uscf
> >> >> any more than you may sensibly comment on employee's medical
> >> >> conditions -
> >> >> its against the law.
>
> >> >> If indeed you did just mention that I believe you renew your offence,
> >> >> and
> >> >> therefore legal resentment of it can be renewed. :(
>
> >> >> Phil Innes
>
> >> > So, in other words, you are saying that I should not let readers know
> >> > that Rob ("The Robber") Mitchell applied twice for a job with the
> >> > USCF, was turned down, and has been attacking the USCF here ever
> >> > since.
>
> >> Whether you should do so or not is of an imperative factor ['should']
> >> known
> >> only to yourself; but whether you break the law in doing so is less
> >> equivocal: You do.
>
> >> Phil Innes
>
> > In that case, kindly go to the DA and get this miscreant off the
> > streets.
>
> > (I thought your law license had expired.)
>
> What you might think instead is that this continued instance of indiscretion
> may have a couple of consequences - that someone calls you to account for
> it, and secondly, who would trust such a person near personnel records
> again? And will that not utterly sink your remaining future political
> chances?
>
> My decency licence has not expired, neither is this keyboard likely to.
>
> Phil Innes
By the way, you never had a decency license.
Incidentally, I was not on the board when Rob ("The Robber") Mitchell
applied for jobs working for the USCF, and I played no role in the
decisions not to hire him.
Sam Sloan
|
| |
Date: 03 Feb 2008 09:47:26
From: samsloan
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
On Feb 3, 12:24 pm, "Chess One" <[email protected] > wrote:
> "samsloan" <[email protected]> wrote in message
>
> news:d5e7bac7-1af1-4d23-8a89-0fd36e3dc643@v46g2000hsv.googlegroups.com...
>
>
>
> > On Feb 3, 11:54 am, "Chess One" <[email protected]> wrote:
> >> "samsloan" <[email protected]> wrote in message
>
> >>news:7a436b71-a881-4ed5-b4a5-d403fa3ee03e@c23g2000hsa.googlegroups.com...
>
> >> > On Feb 3, 8:29 am, The Historian <[email protected]> wrote:
> >> >> On Feb 3, 4:37 am, samsloan <[email protected]> wrote:
>
> >> >> > What does Rob ("The Robber") Mitchell think he is accomplishing by
> >> >> > constantly overwriting other people's threads?
>
> >> >> Google Groups only displays the title of the most recent post in a
> >> >> thread.
>
> >> > Right. Now, does Rob ("The Robber") Mitchell think that the USCF is
> >> > going to hire him after all or that I am going to let him back in my
> >> > group because he keeps doing this?
>
> >> > I assume that Rob ("The Robber") Mitchell is the same person as
> >> > "Tennessee Vols" who has been attacking people over on Susan Polgar's
> >> >http://www.chessdiscussion.com
>
> >> Nah! This is our own Which Mitch? Remember, the guy posted stuff at
> >> 'your'
> >> Yahoo group for 2 years until he asked questions about /your/ er...
> >> 'activities' and responsibilites for such reks as you make above!
>
> >> This is the real "Lex" Mitchell" aka "Blair-Slayer", and unless you are
> >> in
> >> truth, Super-Sloan of Metropolis, you'd bett'rn not mess up your
> >> Mitchells,
> >> boy, cuz this doggee /is/ gonna hunt!
>
> >> BTW - you really should not reveal materials about job applicants at uscf
> >> any more than you may sensibly comment on employee's medical conditions -
> >> its against the law.
>
> >> If indeed you did just mention that I believe you renew your offence, and
> >> therefore legal resentment of it can be renewed. :(
>
> >> Phil Innes
>
> > So, in other words, you are saying that I should not let readers know
> > that Rob ("The Robber") Mitchell applied twice for a job with the
> > USCF, was turned down, and has been attacking the USCF here ever
> > since.
>
> Whether you should do so or not is of an imperative factor ['should'] known
> only to yourself; but whether you break the law in doing so is less
> equivocal: You do.
>
> Phil Innes
In that case, kindly go to the DA and get this miscreant off the
streets.
(I thought your law license had expired.)
|
| | |
Date: 03 Feb 2008 13:02:28
From: Chess One
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
"samsloan" <[email protected] > wrote in message
news:eb0438d2-93bb-4505-8df6-882ebdedc789@m34g2000hsb.googlegroups.com...
> On Feb 3, 12:24 pm, "Chess One" <[email protected]> wrote:
>> "samsloan" <[email protected]> wrote in message
>>
>> news:d5e7bac7-1af1-4d23-8a89-0fd36e3dc643@v46g2000hsv.googlegroups.com...
>>
>>
>>
>> > On Feb 3, 11:54 am, "Chess One" <[email protected]> wrote:
>> >> "samsloan" <[email protected]> wrote in message
>>
>> >>news:7a436b71-a881-4ed5-b4a5-d403fa3ee03e@c23g2000hsa.googlegroups.com...
>>
>> >> > On Feb 3, 8:29 am, The Historian <[email protected]>
>> >> > wrote:
>> >> >> On Feb 3, 4:37 am, samsloan <[email protected]> wrote:
>>
>> >> >> > What does Rob ("The Robber") Mitchell think he is accomplishing
>> >> >> > by
>> >> >> > constantly overwriting other people's threads?
>>
>> >> >> Google Groups only displays the title of the most recent post in a
>> >> >> thread.
>>
>> >> > Right. Now, does Rob ("The Robber") Mitchell think that the USCF is
>> >> > going to hire him after all or that I am going to let him back in my
>> >> > group because he keeps doing this?
>>
>> >> > I assume that Rob ("The Robber") Mitchell is the same person as
>> >> > "Tennessee Vols" who has been attacking people over on Susan
>> >> > Polgar's
>> >> >http://www.chessdiscussion.com
>>
>> >> Nah! This is our own Which Mitch? Remember, the guy posted stuff at
>> >> 'your'
>> >> Yahoo group for 2 years until he asked questions about /your/ er...
>> >> 'activities' and responsibilites for such reks as you make above!
>>
>> >> This is the real "Lex" Mitchell" aka "Blair-Slayer", and unless you
>> >> are
>> >> in
>> >> truth, Super-Sloan of Metropolis, you'd bett'rn not mess up your
>> >> Mitchells,
>> >> boy, cuz this doggee /is/ gonna hunt!
>>
>> >> BTW - you really should not reveal materials about job applicants at
>> >> uscf
>> >> any more than you may sensibly comment on employee's medical
>> >> conditions -
>> >> its against the law.
>>
>> >> If indeed you did just mention that I believe you renew your offence,
>> >> and
>> >> therefore legal resentment of it can be renewed. :(
>>
>> >> Phil Innes
>>
>> > So, in other words, you are saying that I should not let readers know
>> > that Rob ("The Robber") Mitchell applied twice for a job with the
>> > USCF, was turned down, and has been attacking the USCF here ever
>> > since.
>>
>> Whether you should do so or not is of an imperative factor ['should']
>> known
>> only to yourself; but whether you break the law in doing so is less
>> equivocal: You do.
>>
>> Phil Innes
>
> In that case, kindly go to the DA and get this miscreant off the
> streets.
>
> (I thought your law license had expired.)
What you might think instead is that this continued instance of indiscretion
may have a couple of consequences - that someone calls you to account for
it, and secondly, who would trust such a person near personnel records
again? And will that not utterly sink your remaining future political
chances?
My decency licence has not expired, neither is this keyboard likely to.
Phil Innes
>
|
| |
Date: 03 Feb 2008 09:01:51
From: samsloan
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
On Feb 3, 11:54 am, "Chess One" <[email protected] > wrote:
> "samsloan" <[email protected]> wrote in message
>
> news:7a436b71-a881-4ed5-b4a5-d403fa3ee03e@c23g2000hsa.googlegroups.com...
>
>
>
> > On Feb 3, 8:29 am, The Historian <[email protected]> wrote:
> >> On Feb 3, 4:37 am, samsloan <[email protected]> wrote:
>
> >> > What does Rob ("The Robber") Mitchell think he is accomplishing by
> >> > constantly overwriting other people's threads?
>
> >> Google Groups only displays the title of the most recent post in a
> >> thread.
>
> > Right. Now, does Rob ("The Robber") Mitchell think that the USCF is
> > going to hire him after all or that I am going to let him back in my
> > group because he keeps doing this?
>
> > I assume that Rob ("The Robber") Mitchell is the same person as
> > "Tennessee Vols" who has been attacking people over on Susan Polgar's
> >http://www.chessdiscussion.com
>
> Nah! This is our own Which Mitch? Remember, the guy posted stuff at 'your'
> Yahoo group for 2 years until he asked questions about /your/ er...
> 'activities' and responsibilites for such reks as you make above!
>
> This is the real "Lex" Mitchell" aka "Blair-Slayer", and unless you are in
> truth, Super-Sloan of Metropolis, you'd bett'rn not mess up your Mitchells,
> boy, cuz this doggee /is/ gonna hunt!
>
> BTW - you really should not reveal materials about job applicants at uscf
> any more than you may sensibly comment on employee's medical conditions -
> its against the law.
>
> If indeed you did just mention that I believe you renew your offence, and
> therefore legal resentment of it can be renewed. :(
>
> Phil Innes
So, in other words, you are saying that I should not let readers know
that Rob ("The Robber") Mitchell applied twice for a job with the
USCF, was turned down, and has been attacking the USCF here ever
since.
Sam Sloan
|
| | |
Date: 03 Feb 2008 12:24:55
From: Chess One
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
"samsloan" <[email protected] > wrote in message
news:d5e7bac7-1af1-4d23-8a89-0fd36e3dc643@v46g2000hsv.googlegroups.com...
> On Feb 3, 11:54 am, "Chess One" <[email protected]> wrote:
>> "samsloan" <[email protected]> wrote in message
>>
>> news:7a436b71-a881-4ed5-b4a5-d403fa3ee03e@c23g2000hsa.googlegroups.com...
>>
>>
>>
>> > On Feb 3, 8:29 am, The Historian <[email protected]> wrote:
>> >> On Feb 3, 4:37 am, samsloan <[email protected]> wrote:
>>
>> >> > What does Rob ("The Robber") Mitchell think he is accomplishing by
>> >> > constantly overwriting other people's threads?
>>
>> >> Google Groups only displays the title of the most recent post in a
>> >> thread.
>>
>> > Right. Now, does Rob ("The Robber") Mitchell think that the USCF is
>> > going to hire him after all or that I am going to let him back in my
>> > group because he keeps doing this?
>>
>> > I assume that Rob ("The Robber") Mitchell is the same person as
>> > "Tennessee Vols" who has been attacking people over on Susan Polgar's
>> >http://www.chessdiscussion.com
>>
>> Nah! This is our own Which Mitch? Remember, the guy posted stuff at
>> 'your'
>> Yahoo group for 2 years until he asked questions about /your/ er...
>> 'activities' and responsibilites for such reks as you make above!
>>
>> This is the real "Lex" Mitchell" aka "Blair-Slayer", and unless you are
>> in
>> truth, Super-Sloan of Metropolis, you'd bett'rn not mess up your
>> Mitchells,
>> boy, cuz this doggee /is/ gonna hunt!
>>
>> BTW - you really should not reveal materials about job applicants at uscf
>> any more than you may sensibly comment on employee's medical conditions -
>> its against the law.
>>
>> If indeed you did just mention that I believe you renew your offence, and
>> therefore legal resentment of it can be renewed. :(
>>
>> Phil Innes
>
> So, in other words, you are saying that I should not let readers know
> that Rob ("The Robber") Mitchell applied twice for a job with the
> USCF, was turned down, and has been attacking the USCF here ever
> since.
Whether you should do so or not is of an imperative factor ['should'] known
only to yourself; but whether you break the law in doing so is less
equivocal: You do.
Phil Innes
> Sam Sloan
|
| |
Date: 03 Feb 2008 06:25:56
From: samsloan
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
On Feb 3, 8:29 am, The Historian <[email protected] > wrote:
> On Feb 3, 4:37 am, samsloan <[email protected]> wrote:
>
> > What does Rob ("The Robber") Mitchell think he is accomplishing by
> > constantly overwriting other people's threads?
>
> Google Groups only displays the title of the most recent post in a
> thread.
Right. Now, does Rob ("The Robber") Mitchell think that the USCF is
going to hire him after all or that I am going to let him back in my
group because he keeps doing this?
I assume that Rob ("The Robber") Mitchell is the same person as
"Tennessee Vols" who has been attacking people over on Susan Polgar's
http://www.chessdiscussion.com
Sam Sloan
|
| | |
Date: 03 Feb 2008 11:54:39
From: Chess One
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
"samsloan" <[email protected] > wrote in message
news:7a436b71-a881-4ed5-b4a5-d403fa3ee03e@c23g2000hsa.googlegroups.com...
> On Feb 3, 8:29 am, The Historian <[email protected]> wrote:
>> On Feb 3, 4:37 am, samsloan <[email protected]> wrote:
>>
>> > What does Rob ("The Robber") Mitchell think he is accomplishing by
>> > constantly overwriting other people's threads?
>>
>> Google Groups only displays the title of the most recent post in a
>> thread.
>
> Right. Now, does Rob ("The Robber") Mitchell think that the USCF is
> going to hire him after all or that I am going to let him back in my
> group because he keeps doing this?
>
> I assume that Rob ("The Robber") Mitchell is the same person as
> "Tennessee Vols" who has been attacking people over on Susan Polgar's
> http://www.chessdiscussion.com
Nah! This is our own Which Mitch? Remember, the guy posted stuff at 'your'
Yahoo group for 2 years until he asked questions about /your/ er...
'activities' and responsibilites for such reks as you make above!
This is the real "Lex" Mitchell" aka "Blair-Slayer", and unless you are in
truth, Super-Sloan of Metropolis, you'd bett'rn not mess up your Mitchells,
boy, cuz this doggee /is/ gonna hunt!
BTW - you really should not reveal materials about job applicants at uscf
any more than you may sensibly comment on employee's medical conditions -
its against the law.
If indeed you did just mention that I believe you renew your offence, and
therefore legal resentment of it can be renewed. :(
Phil Innes
> Sam Sloan
|
| |
Date: 03 Feb 2008 05:55:29
From: Rob
Subject: Re: SOUP
|
On Feb 3, 7:24 am, Rob <[email protected] > wrote:
> On Feb 2, 12:24 pm, Rob <[email protected]> wrote:
>
> > S: ome
> > O: ther
> > U: seless
> > P:ost
>
> ditto
:-)
|
| |
Date: 03 Feb 2008 05:29:43
From: The Historian
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
On Feb 3, 4:37 am, samsloan <[email protected] > wrote:
> What does Rob ("The Robber") Mitchell think he is accomplishing by
> constantly overwriting other people's threads?
Google Groups only displays the title of the most recent post in a
thread.
|
| |
Date: 03 Feb 2008 05:24:49
From: Rob
Subject: Re: SOUP
|
On Feb 2, 12:24 pm, Rob <[email protected] > wrote:
> S: ome
> O: ther
> U: seless
> P:ost
ditto
|
| |
Date: 03 Feb 2008 01:37:36
From: samsloan
Subject: Re: Affidavit in Opposition to Motion to Dismiss on Diversity Issue
|
On Feb 2, 9:50 am, samsloan <[email protected] > wrote:
> UNITED STATES DISTRICT COURT
> SOUTHERN DISTRICT OF NEW YORK
> __________________________________________
>
> Sam Sloan,
>
> Plaintiff,
> Civil Action No. 07-CV-8537 (DC)
> -against-
>
> Hoainhan "Paul" Truong, Zsuzsanna "Susan" 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
> __________________________________________
>
> AFFIDAVIT IN OPPOSITION TO
> MOTION TO DISMISS ON DIVERSITY ISSUE
>
> __________________________________________
>
> Samuel H. Sloan, the plaintiff herein, being duly sworn, deposes and
> says:
>
> 1. I make this affidavit in opposition to the motion by William
> Goichberg and others to dismiss this action on the grounds of lack of
> diversity jurisdiction. This affidavit only addresses the diversity
> issue. I will address other issues in other affidavits.
>
> 2. Please note that the affidavit of William Goichberg in support of
> his motion to dismiss sworn to the 9th day of January 2008 is
> notarized by Pi Ning Cheung, Notary Public - California, Los Angeles.
>
> 3. It seems odd that a person who claims to reside in New York and who
> has known about this lawsuit since it was filed on October 2, 2007
> would not be able to obtain a notary public in New York State who is
> willing to state that he knows Mr. Goichberg.
>
> 4. I have known William Goichberg since 1961 when he defeated me in
> the Eastern Open Chess Championship in Washington DC. One would
> imagine that since I have known him for 47 years and served on the
> board with him for one year that I would know where he lives.
>
> 5. In his moving affidavit he states that his residence is at 2084
> Route 94, Salisbury Mills NY 12577. If that is the case, how come I
> cannot find this address listed anywhere? Not only it is not listed
> anywhere as his address, but it is not listed anywhere at all.
>
> 6. In fact, the address of 2084 Route 94, Salisbury Mills NY 12577
> DOES NOT EXIST.
>
> 7. My investigation confirms that 2084 Route 94, Salisbury Mills NY
> 12577 is not a residence or a domiciliary address. I have checked
> every possible source for the address of 2084 Route 94, Salisbury
> Mills NY 12577. For example, I checked the US Postal Service website
> which has the full 9-digit zip code for every address in America athttp://zip4.usps.com/zip4/welcome.jsp
>
> 8. Inputting that address yields the following answer:
>
> We're sorry! We were unable to process your request.
> The address was not found. Please check the address below.
> You may want to utilize the Yellow Pages and/or White Pages below.
>
> 9. I have checked every other possible source, including
> mapquest.com , Google Earth, Google Maps and none of them show an
> address in existence of 2084 Route 94, Salisbury Mills NY 12577.
>
> 10. A real estate site, zillow.com , shows 2084 Route 94, Salisbury
> Mills NY 12577, to be an empty lot.
>
> 11. Bill Goichberg had better come up with a really good explanation
> for this.
>
> 12. Bill Goichberg lives a vagabond life, constantly traveling from
> place to place, from chess tournament to chess tournament, from horse
> racing track to horse racing track. It is true that he has a telephone
> number in Salisbury Mills but in the many times I have called that
> number over a period of many years nobody has ever answered the phone.
> He seems to have it on permanent voicemail. For the past more than 40
> years, Bill Goichberg has carried ads for his chess tournaments in
> every issue of Chess Life, always providing another address where to
> send the entry fees for his chess tournaments. The street address he
> provides in this pleading has never previously been provided anywhere
> else. I know many people who know Bill Goichberg even better than I do
> and none of them had ever heard of this street address before. If what
> he says is true, he has been keeping his residence address secret for
> the last 17 years and has revealed it now just to defeat my diversity
> claim.
>
> 13. So far, Goichberg has submitted no evidence in support of his
> claim. He has provided no income tax returns, no deed or title to
> property, no gas nor electric bills nor anything else to establish
> that his priy domicile is in New York State. (The law speaks of
> "domicile" not residence.)
>
> 14. Bill Goichberg is not presently in New York State. He is now in
> Southern California and has been there since October.. He currently
> resides at the Santa Anita Inn, at 130 West Huntington Drive, Arcadia,
> CA 91007 and plans to stay there at least through the winter. As the
> name suggests, it is next to the Santa Anita Race Track where Bill
> Goichberg is a race horse handicapper. He plays a system based on the
> USCF Rating System.
>
> 15. His claim is that he "intends to return to New York State". Intent
> to return to New York does not establish residence or domicile and
> does not defeat diversity jurisdiction. Indeed, asserting that he
> intends to return is a tacit admission by Mr. Goichberg that he is not
> currently a resident or domiciliary of New York State.
>
> 16. Accordingly, diversity is established and a motion to dismiss on
> that ground must be denied. At a very minimum there will have to be a
> fact-hearing where Goichberg will be required to produce evidence if
> he has any that he is domiciled in New York State, especially since he
> is nowhere to be found in New York State and has not been here in
> quite some time.
>
> 17. In addition, it is not necessary to reach diversity because there
> are federal questions involved in this case. Also, if worse comes to
> worst I would just have to drop Goichberg as a defendant because it is
> clear that all of the other defendants are domiciled outside of New
> York State.
>
> _____________________
> Samuel H. Sloan
> 1664 Davidson Ave., Apt. 1B
> Bronx NY 10453
>
> 917-507-7226
> 1-347-869-2465
> [email protected]
>
> STATE OF NEW YORK )
> ss:
> COUNTY OF BRONX )
>
> VERIFICATION
>
> _________________________
> Signature of Petitioner
>
> On the 2nd Day of February, 2008 before me personally came Samuel H.
> Sloan to me known to be the person described herein and who executed
> the foregoing instrument. Such person duly swore to such instrument
> before me and duly acknowledged that he executed the same.
>
> _____________________________
> NOTARY PUBLIC
>
> Affidavit of Service
>
> Samuel H. Sloan, being duly sworn, deposes and says that on February
> 2, 2008 he mailed the within affidavit in opposition to motion to
> dismiss this action for lack of diversity to the following addresses:
>
> 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 "Paul" Truong and Zsuzsanna "Susan" Polgar
> 50 Jericho Quadrangle
> Jericho NY 11753-2729
>
> Emily E. Daughtry
> Attorney for United States of America
> US Attorney's Office
> 86 Chambers Street, 3rd Floor
> New York NY 10007-2632
>
> Patrick M. O'Brien, Esq.
> Attorney for William Brock
> 309 Elmore Street
> Park Ridge, Illinois 60068-3569
>
> Arthur M. Handler
> Attorney for William Brock
> Handler & Goodman LLP
> 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
>
> __________________________
> Samuel H. Sloan
>
> Sworn to before me this 2nd
> Day of February, 2008
>
> ______________________________
> NOTARY PUBLIC
What does Rob ("The Robber") Mitchell think he is accomplishing by
constantly overwriting other people's threads?
|
| |
Date: 02 Feb 2008 10:32:27
From:
Subject: Re: SOUP
|
On Feb 2, 12:24=A0pm, Rob <[email protected] > wrote:
> S: ome
> O: ther
> U: seless
> P:ost
If Sam would go to a law school, he would realize that he is going to
lose a lawsuit that he could otherwise win.
cus Roberts
|
|
