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Date: 16 Jan 2009 08:33:57
From: samsloan
Subject: Motion for Rule 11 Sanctions Against Bill Brock and Attorney Patrick
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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 =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
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Date: 27 Jan 2009 07:48:10
From: samsloan
Subject: Re: Motion for Rule 11 Sanctions Against Bill Brock and Attorney
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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
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Date: 16 Jan 2009 16:47:22
From: samsloan
Subject: Re: Motion for Rule 11 Sanctions Against Bill Brock and Attorney
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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
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