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Main
Date: 03 Oct 2007 07:07:37
From: samsloan
Subject: Motion for a TRO in Sloan vs. Truong, Polgar et al, 07 CIV 8537
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
__________________________________________
Sam Sloan,
Plaintiff,
-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
__________________________________________
MOTION FOR A TEMPORARY RESTRAINING ORDER AND A PRELIMINARY AND A
PERMANENT INJUNCTION
__________________________________________
Samuel H. Sloan, being duly sworn, deposes and says:
1=2E This is an action brought to overturn the election results of the
election for the Executive Board of the United States Chess
Federation. In this election, Susan Polgar, Paul Truong, Randy Bauer
and Jim Berry were elected and Don Schultz and Sam Sloan were voted
out of office along with Beatriz inello who did not run for re-
election because she was having a kidney transplant operation at the
time of the election. The new board took office on August 4, 2007. No
prior application has been made for the relief requested herein in
this or any other court.
2=2E Last week, Brian Mottershead, a volunteer website administrator who
has been building a new website for the USCF, was able to prove
conclusively that a person impersonating Plaintiff and who had posted
three thousand obscene messages on the Chess Poltics Internet
newsgroup was in fact Polgar and Truong. The proof that Polgar and
Truong were in the form of IP addresses. This previously unknown
person posting as Plaintiff Sam Sloan had long been known as the "Fake
Sam Sloan". During the election campaign, the Fake Sam Sloan had
posted three thousand obscene messages to the Internet newsgroups
rec.games.chess.politics and rec.games.chess.misc . These were the
most obscene messages imaginable, so obscene that I am even reluctant
to type them here.
3=2E Here are a few of the relatively less objectionable ones:
"If you pay me $5,000 I will let my wife Kayo suck your dick."
"I will convert that Bulldyke inello with my 4 =BC inch power tool"
"Jackass Lafferty is a dickhead"
4=2E Obviously, if these sort of postings had been made by the Real me,
I would deserve to lose the election. However, Mottershead assisted by
Hal Bogner, a former managing director of ICC, the Internet Chesss
Club, proved that all of these three thousand postings were made by
Susan Polgar and Paul Truong. Polgar and Truong are a ried couple
living together and using the same computer so it is impossible to
determine which of them posted this or if both of them did.
5=2E The way that Mottershead was able to prove that they made all these
postings was that he made a small programming change to the
main.uschess.org/forums The change was that any time anybody logged
into the forums, their IP address would be come visible. The IP
address is a series of numbers telling computers as they communicate
with each other where they are. As soon as Mottershead made this
change, he could see that Polgar and Truong had logged into the USCF
Forums and were simultaneously posting as the Fake Sam Sloan and the
Fake Ray Gordon from the same computer.
6=2E Further evidence that all of the above postings were by Polgar and
Truong is that as Truong and Polgar have moved around from place to
place, the IP address of the Fake Sam Sloan has moved with them. When
they went to Hungary, the Fake Sam Sloan stopped posting until they
returned. When they recently got jobs as faculty members of Texas Tech
University in Lubbock, Texas, the Fake Sam Sloan also started posting
from the university computers at Texas Tech University. Then, when
last week they went to Mexico City for the World Chess Championship,
the Fake Sam Sloan also started posting from Mexico City. Just as
criminals are often caught by a simple slip-up and mistake, Polgar and
Truong were finally caught and positively identified by website
administrator Brian Mottershead when they logged in and posted as the
Fake Sam Sloan, the Fake Ray Gordon and then themselves under their
real names from the same computer first at Texas Tech University and
later at Mexico City. From Mexico City, they posted from NNTP-Posting-
Host: 201.134.236.150 on September 25, 2007, and from the same
computer logged into the USCF Forums.
7=2E This proof is so conclusive that Polgar and Truong have not even
denied it. However, they have started that they are going to sue
Mottershead, Bogner and Lafferty for invasion of their privacy. In
addition, they and they supporters have protested to the board about
the methods used by Mottershead to uncover the identity of the Fake
Sam Sloan. Correspondence between board members are known as "BINFOS"
which means "Board Information" and are available after a time delay
to USCF members only at http://secure.uschess.org/binfo
8=2E Here is a letter by Paul Truong to the board dated September 26,
2007:
Before we vote on this matter, I ask the board to first review a very
serious matter regarding the USCF forums. Without consulting the
board, programmer(s) of the USCF forums decided to enable a feature to
publicly display the IPs of all members of the USCF forums. Once
again, our right to privacy has been compromised. This will put all of
our members at risk because of hackers. This will also create serious
potential problems for the USCF. This is not the first time
programmer(s) of the USCF forums have made important decisions that
can negatively effect the entire federation without consulting the
board. I strongly believe that this matter has to be resolved before
other issues of the forum can proceed. I cannot vote on this matter
until this problem is fixed. Best regards, PT
9=2E Here is one BINFO dated September 28, 2007 that just became
available this morning:
Bill Hall and the EB:
Consider this an official request for the following sets of documents
which are corporate documents and as a USCF member in good standing,
entitled to review them:
1=2E Written letter of authorization from the ED and EB authorizing
Brian Mottershead to publicly post Internet Protocol (IP) addresses of
USCF members placing postings on the USCF Issues Forums.
2=2E Written letter of authorization from the ED and EB authoring Brian
Mottershead to perform 'forensic analysis' to determine 'identity' of
anonymous posters on non-USCF operated Internet-based discussion
forums.
3=2E Description of responsibilities for Brian Mottershead in his role
as Interim System Administrator for the USCF.
4=2E Copy of the contract between the USCF and Hal Bogner for services
being rendered by Mr. Bogner to the USCF.
10. The proof that Polgar and Truong have been impersonating Sam Sloan
and Ray Gordon was posted to the Internet newsgroup
rec.games.chess.politics and elsewhere on September 26, 2007. Here is
the proof:
by Brian Mottershead on Wed Sep 26, 2007 6:02 am #71050
I am going now to give a general characterization of the information
that is the main.uschess.org logs. Later today, I hope I will receive
permission to post the actual lines from the logs for the inspection
of concerned USCF members.
I already presented two posts that were made on the
rec.games.chess.politics newsgroup, both posted by the "Fake Ray
Gordon". One of these had the IP address 75.111.194.9, a Suddenlink
cable IP address from Texas. This post is one of six that were made by
FRG on September 19. The other post was one made from 201.134.236.150
yesterday. This is an IP address in Mexico City.
Now, this web site keeps both regular web logs and a log that is
maintained by the joomla-bridge for this forum. The regular web logs
record the date/time, IP address, the request, including query string,
and the user agent string that was sent by the browser for every hit
on the web server. The joomla-bridge log keeps all of this
information, plus it gives the Joomla user id, and the Joomla and
phpbb3 usernames of the user for each hit on the forums.
Starting on September 16, a particular user was logged in on the
forums and made numerous requests on the forum software with the IP
address 75.111.194.9. This continued until September 20. During this
time, with one short exception every hit by this user, at least when
logged in under his account, was from this IP address. The exception
was a short visit to the forums when the person accessed the forums
from an IP address associated with university in Texas. After the
short interruption he went back to 75.111.194.9. It was during this
period that all the posts in the forum with a poster IP of
75.111.194.9 occurred. September 19, which is when the 6 FRG posts
from 75.111.194.9 were made in the newsgroup, fell toward the end of
this period.
Later, on September 20, the person stopped using 75.111.194.9, and
appeared briefly with another IP, from a cell phone company. Then,
still later on September 20, the person started using 201.134.236.150,
which is an IP address in Mexico City. Though the person had stopped
posting in the forums by then, he still needed to be logged into the
forums in order to read the USCF Issues forum and to check PM's. All
those accesses, of which there were many, were from 201.134.236.150.
The usage of 201.134.236.150 continued through last night throughout
the night. It looks like the person was up all night monitoring this
forum. During the night, he was apparently also busy deleting large
numbers of FRG and FSS posts from the usenet groups. It was this
Mexico City IP, 201.134.236.150, which was used to post the second of
the two posts I presented last night, the one that referred to me and
Bogner as "crooks" and speculated as to whether we were stealing
credit card numbers from USCF members.
So, not only do the IP addresses on posts in the forums tie these two
IP addresses associated with FRG to the forum member, but the logs
show that a specific forum member was using these two IP addresses
essentially continuously on this forum, with the exception of the
short visit from the university.
There is also evidence from the User Agent strings. User agent strings
are information sent by web browsers to servers to describe
themselves, so that the servers know what kind of browser it is, and
can generate the appropriate HTML. Different browsers occasionally
require different HTML code. Essentially all of the thousands of posts
made during the last several months by FRG and FSS have had the same
user agent string as the September 19 Usenet post that I posted. This
was:
Mozilla/4.0 (compatible; MSIE 7.0; AOL 9.0; Windows NT 6.0;
SLCC1; .NET CLR 2.0.50727; Media Center PC 5.0; .NET CLR 3.0.04506;
InfoPath.2),gzip(gfe),gzip(gfe)
This is a quite specific user agent string, and in the logs for the
forums, there have been only two users with this user agent string
since the joomla-bridge logs started to be kept on September 14. One
of those two users accessed the forums rarely in the period, and by
looking at timestamps, it is possible to eliminate that person as a
possibility, even without considering IP addresses. The other user
with this user agent string was the same person who was coming into
this forum from 75.111.194.9 and who posted here under that IP. I
repeat that this is the IP from which FRG made 6 posts to the Usenet
groups on September 19.
Next, you will note that the user agent string is different on the
Usenet post by FRG yesterday from Mexico City. This was: Mozilla/4.0
(compatible; MSIE 7.0; AOL 9.0; Windows NT 6.0; SLCC1; .NET CLR
2=2E0.50727; Media Center PC 5.0; .NET CLR 3.0.04506; Tablet PC
2=2E0),gzip(gfe),gzip(gfe)
This second string is similar to the first, but it is a Tablet PC 2.0.
Apparently, FRG took his laptop with him from Texas to Mexico City,
not his desktop system. Significantly, when the forum user who had
been posting and visiting under 75.111.194.9 suddenly appeared on the
forum with the same Mexico City IP as FRG used, he also had the same
Tablet PC 2.0 user agent string as well. Every hit on this forum from
Mexico City has had that user agent string, the same one as appeared
on the FRG post yesterday.
So both the IP addresses and the user agent strings used by the
particular person on this forum match those used by FRG for the
September 19 and September 26 posts, and one of the user agent strings
matches the one that FRG, FSS, etc have been recording on Usenet for
many months.
11. Note that in the letter above, Mottershead does not specifically
state that Polgar and Truong are the perpetrators of these crimes.
This is because Mottershead wants to avoid being sued. However, it is
common knowledge in the chess community that Polgar and Truong
recently moved from Forest Hills, Queens, New York to Texas Tech
University in Lubbock Texas and last week were in Mexico City for the
World Chess Championship and this information is also on their
websites, so everyone will realize that Mottershead is referring to
Polgar and Truong.
12. These Internet postings by Polgar and Truong constitute violations
of 47 USC =A7223(h)(1) by sending over the Internet thousands of obscene
messages likely to be read by children while disguising their
identities by impersonating Plaintiff and other well known chess
personalities. The USCF has 86,000 members and the average age of
those members is ten years old. Thus, these obscene messages by Polgar
and Truong are likely to be read by children.
13. Because these three thousand obscene Internet postings took place
in the context of a USCF election and because the perpetrators were in
fact elected and the plaintiff was defeated, it is obvious that the
defendants are guilty of election fraud. Accordingly, Plaintiff is
demanding an order setting aside the July 2007 USCF election on the
grounds of election fraud and other irregularities; an order
reinstating the three board members who lost their seats in the recent
election, who were Sam Sloan, Don Schultz and Beatriz inello, until
a new election is held; an order providing that a new election be held
at the earliest practicable date, to be supervised by the Department
of Justice, an order baring Paul Truong and Susan Polgar from running
for election in the United States Chess Federation, and an order
removing Joel Channing and Bill Goichberg from the Executive Board of
Directors of the United States Chess Federation and barring them from
running for election again.
14, Plaintiff has informed former Board members Don Schultz and
Beatriz inello that he will be making this application for a
temporary restraining order and a preliminary injunction which, if
granted, will reinstate them as members of the Board of Directors of
the United States Chess Federation until a new election is held and
both Schultz and inello have agreed to serve on this temporary
board. Note that Beatriz inello did not run for re-election because
she had a kidney transplant operation on July 17, 2007, but since then
the operation has been a complete success and inello is back in
action as the website manager of the US Chess Trust and is teaching
chess classes in New York City Public School in Harlem.
15. The USCF has already retained counsel to represent them in this
lawsuit. Their attorney is Michael Matsler, Rider, Weiner & Frankel,
PC, 655 New Britain Road, Newburgh NY 12553, tel. 845-562-9100, FAX
845-562-9126. I am prepared to contact Mr. Matsler to inform him of
this application if requested to do so by this court. I understand
that Mr. Matsler has already been consulted by the board on this
matter and thus is familiar with the situation.
16. I also have the email addresses of all of the defendants with the
exception of Frank Niro who disappeared in 2003 after running off with
the money but is known to be in the area of Seattle, Washington and I
am prepared to notify all the defendants of this suit by email.
17. A temporary restraining order is required because since it has
been proved that Polgar and Truong are the Fake Sam Sloan the USCF has
gone on lockdown. Truong stayed up all night the night of September
26, 2007 deleting all of his Fake Sam Sloan and Fake Ray Gordon
posting from the Google newsgroups. Through the wonders of the
Internet, Mottershead was able to observe Truong staying up all night
deleting his postings. However, the three thousand postings survive on
Forte Agent and on Giganews.com .
18. The USCF, after being advised by counsel that closing down the
forums will be seen as a cover-up, has left the forums open but had
ordered the moderators Herbert Rodney Vaughn and Tim Sawmiller, who
are the only moderators left after several resigned complaining about
pressure from the board to delete any comments unfavorable to board
members and after the only really good moderator committed suicide, to
either delete or pull for public viewing any reference to the
impersonations by Truong and Polgar of the Fake Sam Sloan. On the
first day that this situation became public, there were within a few
hours more than 150 postings on this topic by a wide variety of USCF
members. All of them were pulled or deleted by Vaughn. As soon as that
happened, another hundred postings appeared on other topics within a
matter of minutes.
19. The following "LOCKED" message was posted by Bill Hall on the USCF
Forums on September 29, 2007:
by nolan on Sat Sep 29, 2007 7:50 pm #71818 Bill Hall has requested
that this message be posted:
Dear Forum Users,
In light of recent events, I feel it is in the best interest of the
USCF to call a moratorium to discussions regarding someone posting as
other real individuals on other discussion forums.
This issue has potential legal liability ramifications from several
directions, and I believe it to be my fiduciary responsibility at this
time to place this topic on pause until more of the facts have been
reviewed.
Moderators: Please remove all posts pertaining to this topic. Please
place any posters that continue to violate this in the moderation
queue (prior moderator approval required for post to be displayed). I
authorize the moderators to utilize the moderation queue as needed
until further notice.
I hope this issue can be addressed in an expeditious fashion. The
posts that are removed will not be deleted and may return at a future
date. Please help us in protecting the Federation and help to insure
all parties to this matter are treated respectfully and fairly.
Bill Hall
20. The result is that dues-paying USCF Members are being denied
access to their forums which are a membership benefit and are being
prevented from knowing what is going on inside their federation and
expressing their opinions about this subject and in the mean time USCF
insiders are running around deleting all the evidence by removing
postings. Thousands of these Internet postings have already been
deleted or pulled. This situation calls for a TRO. In addition,
Plaintiff maintains that the moderators really have no right to
delete postings by USCF members as long as basic rules of decorum are
followed such as no obscenity. Plaintiff maintains that it is illegal
to use the powers of the moderators to suppress dissent.
21. For example, in December 2006, at about the same time that Polgar
and Truong announced that they were running for USCF election, rumors
started circulating that they were ried to each other. Each time
they were asked this question they complained to the moderators and
had the question deleted. Members also asked questions on the forums
about the millions Truong had supposedly made, about the billion
dollar Fortune 500 Companies Truong had supposedly rescued, about the
four World Championships Polgar claims that she won and many other
questions about the fantastic claims that Truong and Polgar kept
making while running for election. Each time questions like this were
asked, Polgar and Truong complained to the moderators and got the
questions deleted.
22. Plaintiff claims that the USCF Executive Director acted improperly
and possibly even illegally in having all these postings by USCF
members deleted. Plaintiff requests that this court order that all
such postings be reinstated so that the members can view them.
WHEREFORE, for all of the reasons set forth above, Plaintiff requests
a temporary restraining order and a preliminary and permanent
injunction, providing the following:
1=2E The USCF Moderators under the supervision of USCF Executive
Director Bill Hall, shall immediately stop all deletions of postings
by USCF Members to the USCF Forums. Attempts will be made to recover
and restore all postings already deleted, removed or pulled and all
recovered postings shall be made visible so that the members can see
them.
2=2E All IP addresses of the postings shall be restored to that the
members can see the evidence showing who actually made these postings.
3=2E All locked threads shall be unlocked and all postings removed from
visibility shall be made visible to the members again.
4=2E The USCF election held in July 2007 is suspended or vacated and the
results set aside. The former board members are reinstated on the
board and the new board members are removed from the board until a
hearing and final determination can be had.
5=2E Such other and further relief as may be deemed just and equitable.
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
1, the undersigned, the petitioner named in the foregoing petition,
being duly sworn, says:
I have read the foregoing petition subscribed by me and know the
contents thereof and the same is true of my own knowledge, except as
to those matters herein stated to be alleged upon information and
belief and as to those matters I believe it to be true.
_________________________
Samuel H. Sloan
On the 2nd Day of October, 2007 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
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Date: 03 Oct 2007 23:14:37
From: help bot
Subject: Re: Motion for a TRO in Sloan vs. Truong, Polgar et al, 07 CIV 8537
|
On Oct 3, 10:55 pm, Rob <[email protected] > wrote:
> > On the 2nd Day of October, 2007 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
> It isnt legal as there is no Sam Sloan. His legal name is Mohamed
> Ismail Sloan. By coercing a notary public to falsify legal documents a
> potentially greater crime has been comitted? Unless he has again
> legally changed his name back? WHich is it and who are you really?
This is typical of the very personal and biased way
in which things are approached here on rgc. Rob
Mitchell seems fixated on attacking Sam Sloan, who
in turn seems fixated on Susan Polgar. What evidence
is there of "coercion"? Is this technicality pertinent to
the case?
The loon from St.Kitts and Nevitts, who has repeatedly
declared war on the USA -- or so it might seem from his
difficulties with English -- claims that Mr. Sloan, genius
that he is, filed in the wrong jurisdiction, which if true
would hardly surprise me. Also note that in an above
post, many, many words in the legal document were
misspelled, false statements made, etc. (One example
would be where SS claims that his reputation in the
chess community prior to the fake-Sloan attacks was
pristine). It doesn't bode well for a legal solution to this
fiasco.
I noticed that for a long time it was postulated that
there were potentially numerous fake posters here who
attacked the politicos at the USCF. Now nearly everyone
sings a different tune, suggesting that one and only one
impostor, Paul Truong, is responsible for all of it. I find
this kind of inconsistency revealing of the quality of
rational thought going into these accusations. The sort
of "logic" behind it all. (So far as I have seen, the only
individual who has talked rationally about this mess is
the tech guy from the USCF, who amassed geographical
"evidence" implicating PT and/or SP.)
Here's an offhand idea: announce that, due to the
nature of recently uncovered evidence, no one's privacy
has been violated except that of the perpetrator(s). No
details may be released at this time because of legal
restraints, but rest assured that although the guilty
perpetrator(s) may well have cause for complaint, all
others' privacy is guaranteed safe by the court. We
cannot explain without giving away vital secrets relating
closely to national security; profuse apologies, etc.
A warrant for the arrest of "those" in question has been
issued, and it is expected that a fine approximating
$100,000 will be levied in addition to prison sentence(s)
not to exceed twenty years at hard labor. Then kick
back and see who runs... .
-- help bot
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| |
Date: 03 Oct 2007 20:55:15
From: Rob
Subject: Re: Motion for a TRO in Sloan vs. Truong, Polgar et al, 07 CIV 8537
|
On Oct 3, 8:07 am, samsloan <[email protected] > wrote:
> UNITED STATES DISTRICT COURT
> SOUTHERN DISTRICT OF NEW YORK
> __________________________________________
>
> Sam Sloan,
>
> Plaintiff,
>
> -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
>
> __________________________________________
>
> MOTION FOR A TEMPORARY RESTRAINING ORDER AND A PRELIMINARY AND A
> PERMANENT INJUNCTION
>
> __________________________________________
>
> Samuel H. Sloan, being duly sworn, deposes and says:
>
> 1. This is an action brought to overturn the election results of the
> election for the Executive Board of the United States Chess
> Federation. In this election, Susan Polgar, Paul Truong, Randy Bauer
> and Jim Berry were elected and Don Schultz and Sam Sloan were voted
> out of office along with Beatriz inello who did not run for re-
> election because she was having a kidney transplant operation at the
> time of the election. The new board took office on August 4, 2007. No
> prior application has been made for the relief requested herein in
> this or any other court.
>
> 2. Last week, Brian Mottershead, a volunteer website administrator who
> has been building a new website for the USCF, was able to prove
> conclusively that a person impersonating Plaintiff and who had posted
> three thousand obscene messages on the Chess Poltics Internet
> newsgroup was in fact Polgar and Truong. The proof that Polgar and
> Truong were in the form of IP addresses. This previously unknown
> person posting as Plaintiff Sam Sloan had long been known as the "Fake
> Sam Sloan". During the election campaign, the Fake Sam Sloan had
> posted three thousand obscene messages to the Internet newsgroups
> rec.games.chess.politics and rec.games.chess.misc . These were the
> most obscene messages imaginable, so obscene that I am even reluctant
> to type them here.
>
> 3. Here are a few of the relatively less objectionable ones:
>
> "If you pay me $5,000 I will let my wife Kayo suck your dick."
>
> "I will convert that Bulldyke inello with my 4 =BC inch power tool"
>
> "Jackass Lafferty is a dickhead"
>
> 4. Obviously, if these sort of postings had been made by the Real me,
> I would deserve to lose the election. However, Mottershead assisted by
> Hal Bogner, a former managing director of ICC, the Internet Chesss
> Club, proved that all of these three thousand postings were made by
> Susan Polgar and Paul Truong. Polgar and Truong are a ried couple
> living together and using the same computer so it is impossible to
> determine which of them posted this or if both of them did.
>
> 5. The way that Mottershead was able to prove that they made all these
> postings was that he made a small programming change to the
> main.uschess.org/forums The change was that any time anybody logged
> into the forums, their IP address would be come visible. The IP
> address is a series of numbers telling computers as they communicate
> with each other where they are. As soon as Mottershead made this
> change, he could see that Polgar and Truong had logged into the USCF
> Forums and were simultaneously posting as the Fake Sam Sloan and the
> Fake Ray Gordon from the same computer.
>
> 6. Further evidence that all of the above postings were by Polgar and
> Truong is that as Truong and Polgar have moved around from place to
> place, the IP address of the Fake Sam Sloan has moved with them. When
> they went to Hungary, the Fake Sam Sloan stopped posting until they
> returned. When they recently got jobs as faculty members of Texas Tech
> University in Lubbock, Texas, the Fake Sam Sloan also started posting
> from the university computers at Texas Tech University. Then, when
> last week they went to Mexico City for the World Chess Championship,
> the Fake Sam Sloan also started posting from Mexico City. Just as
> criminals are often caught by a simple slip-up and mistake, Polgar and
> Truong were finally caught and positively identified by website
> administrator Brian Mottershead when they logged in and posted as the
> Fake Sam Sloan, the Fake Ray Gordon and then themselves under their
> real names from the same computer first at Texas Tech University and
> later at Mexico City. From Mexico City, they posted from NNTP-Posting-
> Host: 201.134.236.150 on September 25, 2007, and from the same
> computer logged into the USCF Forums.
>
> 7. This proof is so conclusive that Polgar and Truong have not even
> denied it. However, they have started that they are going to sue
> Mottershead, Bogner and Lafferty for invasion of their privacy. In
> addition, they and they supporters have protested to the board about
> the methods used by Mottershead to uncover the identity of the Fake
> Sam Sloan. Correspondence between board members are known as "BINFOS"
> which means "Board Information" and are available after a time delay
> to USCF members only athttp://secure.uschess.org/binfo
>
> 8. Here is a letter by Paul Truong to the board dated September 26,
> 2007:
>
> Before we vote on this matter, I ask the board to first review a very
> serious matter regarding the USCF forums. Without consulting the
> board, programmer(s) of the USCF forums decided to enable a feature to
> publicly display the IPs of all members of the USCF forums. Once
> again, our right to privacy has been compromised. This will put all of
> our members at risk because of hackers. This will also create serious
> potential problems for the USCF. This is not the first time
> programmer(s) of the USCF forums have made important decisions that
> can negatively effect the entire federation without consulting the
> board. I strongly believe that this matter has to be resolved before
> other issues of the forum can proceed. I cannot vote on this matter
> until this problem is fixed. Best regards, PT
>
> 9. Here is one BINFO dated September 28, 2007 that just became
> available this morning:
>
> Bill Hall and the EB:
>
> Consider this an official request for the following sets of documents
> which are corporate documents and as a USCF member in good standing,
> entitled to review them:
>
> 1. Written letter of authorization from the ED and EB authorizing
> Brian Mottershead to publicly post Internet Protocol (IP) addresses of
> USCF members placing postings on the USCF Issues Forums.
>
> 2. Written letter of authorization from the ED and EB authoring Brian
> Mottershead to perform 'forensic analysis' to determine 'identity' of
> anonymous posters on non-USCF operated Internet-based discussion
> forums.
>
> 3. Description of responsibilities for Brian Mottershead in his role
> as Interim System Administrator for the USCF.
>
> 4. Copy of the contract between the USCF and Hal Bogner for services
> being rendered by Mr. Bogner to the USCF.
>
> 10. The proof that Polgar and Truong have been impersonating Sam Sloan
> and Ray Gordon was posted to the Internet newsgroup
> rec.games.chess.politics and elsewhere on September 26, 2007. Here is
> the proof:
>
> by Brian Mottershead on Wed Sep 26, 2007 6:02 am #71050
>
> I am going now to give a general characterization of the information
> that is the main.uschess.org logs. Later today, I hope I will receive
> permission to post the actual lines from the logs for the inspection
> of concerned USCF members.
>
> I already presented two posts that were made on the
> rec.games.chess.politics newsgroup, both posted by the "Fake Ray
> Gordon". One of these had the IP address 75.111.194.9, a Suddenlink
> cable IP address from Texas. This post is one of six that were made by
> FRG on September 19. The other post was one made from 201.134.236.150
> yesterday. This is an IP address in Mexico City.
>
> Now, this web site keeps both regular web logs and a log that is
> maintained by the joomla-bridge for this forum. The regular web logs
> record the date/time, IP address, the request, including query string,
> and the user agent string that was sent by the browser for every hit
> on the web server. The joomla-bridge log keeps all of this
> information, plus it gives the Joomla user id, and the Joomla and
> phpbb3 usernames of the user for each hit on the forums.
>
> Starting on September 16, a particular user was logged in on the
> forums and made numerous requests on the forum software with the IP
> address 75.111.194.9. This continued until September 20. During this
> time, with one short exception every hit by this user, at least when
> logged in under his account, was from this IP address. The exception
> was a short visit to the forums when the person accessed the forums
> from an IP address associated with university in Texas. After the
> short interruption he went back to 75.111.194.9. It was during this
> period that all the posts in the forum with a poster IP of
> 75.111.194.9 occurred. September 19, which is when the 6 FRG posts
> from 75.111.194.9 were made in the newsgroup, fell toward the end of
> this period.
>
> Later, on September 20, the person stopped using 75.111.194.9, and
> appeared briefly with another IP, from a cell phone company. Then,
> still later on September 20, the person started using 201.134.236.150,
> which is an IP address in Mexico City. Though the person had stopped
> posting in the forums by then, he still needed to be logged into the
> forums in order to read the USCF Issues forum and to check PM's. All
> those accesses, of which there were many, were from 201.134.236.150.
> The usage of 201.134.236.150 continued through last night throughout
> the night. It looks like the person was up all night monitoring this
> forum. During the night, he was apparently also busy deleting large
> numbers of FRG and FSS posts from the usenet groups. It was this
> Mexico City IP, 201.134.236.150, which was used to post the second of
> the two posts I presented last night, the one that referred to me and
> Bogner as "crooks" and speculated as to whether we were stealing
> credit card numbers from USCF members.
>
> So, not only do the IP addresses on posts in the forums tie these two
> IP addresses associated with FRG to the forum member, but the logs
> show that a specific forum member was using these two IP addresses
> essentially continuously on this forum, with the exception of the
> short visit from the university.
>
> There is also evidence from the User Agent strings. User agent strings
> are information sent by web browsers to servers to describe
> themselves, so that the servers know what kind of browser it is, and
> can generate the appropriate HTML. Different browsers occasionally
> require different HTML code. Essentially all of the thousands of posts
> made during the last several months by FRG and FSS have had the same
> user agent string as the September 19 Usenet post that I posted. This
> was:
> Mozilla/4.0 (compatible; MSIE 7.0; AOL 9.0; Windows NT 6.0;
> SLCC1; .NET CLR 2.0.50727; Media Center PC 5.0; .NET CLR 3.0.04506;
> InfoPath.2),gzip(gfe),gzip(gfe)
>
> This is a quite specific user agent string, and in the logs for the
> forums, there have been only two users with this user agent string
> since the joomla-bridge logs started to be kept on September 14. One
> of those two users accessed the forums rarely in the period, and by
> looking at timestamps, it is possible to eliminate that person as a
> possibility, even without considering IP addresses. The other user
> with this user agent string was the same person who was coming into
> this forum from 75.111.194.9 and who posted here under that IP. I
> repeat that this is the IP from which FRG made 6 posts to the Usenet
> groups on September 19.
>
> Next, you will note that the user agent string is different on the
> Usenet post by FRG yesterday from Mexico City. This was: Mozilla/4.0
> (compatible; MSIE 7.0; AOL 9.0; Windows NT 6.0; SLCC1; .NET CLR
> 2.0.50727; Media Center PC 5.0; .NET CLR 3.0.04506; Tablet PC
> 2.0),gzip(gfe),gzip(gfe)
>
> This second string is similar to the first, but it is a Tablet PC 2.0.
> Apparently, FRG took his laptop with him from Texas to Mexico City,
> not his desktop system. Significantly, when the forum user who had
> been posting and visiting under 75.111.194.9 suddenly appeared on the
> forum with the same Mexico City IP as FRG used, he also had the same
> Tablet PC 2.0 user agent string as well. Every hit on this forum from
> Mexico City has had that user agent string, the same one as appeared
> on the FRG post yesterday.
>
> So both the IP addresses and the user agent strings used by the
> particular person on this forum match those used by FRG for the
> September 19 and September 26 posts, and one of the user agent strings
> matches the one that FRG, FSS, etc have been recording on Usenet for
> many months.
>
> 11. Note that in the letter above, Mottershead does not specifically
> state that Polgar and Truong are the perpetrators of these crimes.
> This is because Mottershead wants to avoid being sued. However, it is
> common knowledge in the chess community that Polgar and Truong
> recently moved from Forest Hills, Queens, New York to Texas Tech
> University in Lubbock Texas and last week were in Mexico City for the
> World Chess Championship and this information is also on their
> websites, so everyone will realize that Mottershead is referring to
> Polgar and Truong.
>
> 12. These Internet postings by Polgar and Truong constitute violations
> of 47 USC =A7223(h)(1) by sending over the Internet thousands of obscene
> messages likely to be read by children while disguising their
> identities by impersonating Plaintiff and other well known chess
> personalities. The USCF has 86,000 members and the average age of
> those members is ten years old. Thus, these obscene messages by Polgar
> and Truong are likely to be read by children.
>
> 13. Because these three thousand obscene Internet postings took place
> in the context of a USCF election and because the perpetrators were in
> fact elected and the plaintiff was defeated, it is obvious that the
> defendants are guilty of election fraud. Accordingly, Plaintiff is
> demanding an order setting aside the July 2007 USCF election on the
> grounds of election fraud and other irregularities; an order
> reinstating the three board members who lost their seats in the recent
> election, who were Sam Sloan, Don Schultz and Beatriz inello, until
> a new election is held; an order providing that a new election be held
> at the earliest practicable date, to be supervised by the Department
> of Justice, an order baring Paul Truong and Susan Polgar from running
> for election in the United States Chess Federation, and an order
> removing Joel Channing and Bill Goichberg from the Executive Board of
> Directors of the United States Chess Federation and barring them from
> running for election again.
>
> 14, Plaintiff has informed former Board members Don Schultz and
> Beatriz inello that he will be making this application for a
> temporary restraining order and a preliminary injunction which, if
> granted, will reinstate them as members of the Board of Directors of
> the United States Chess Federation until a new election is held and
> both Schultz and inello have agreed to serve on this temporary
> board. Note that Beatriz inello did not run for re-election because
> she had a kidney transplant operation on July 17, 2007, but since then
> the operation has been a complete success and inello is back in
> action as the website manager of the US Chess Trust and is teaching
> chess classes in New York City Public School in Harlem.
>
> 15. The USCF has already retained counsel to represent them in this
> lawsuit. Their attorney is Michael Matsler, Rider, Weiner & Frankel,
> PC, 655 New Britain Road, Newburgh NY 12553, tel. 845-562-9100, FAX
> 845-562-9126. I am prepared to contact Mr. Matsler to inform him of
> this application if requested to do so by this court. I understand
> that Mr. Matsler has already been consulted by the board on this
> matter and thus is familiar with the situation.
>
> 16. I also have the email addresses of all of the defendants with the
> exception of Frank Niro who disappeared in 2003 after running off with
> the money but is known to be in the area of Seattle, Washington and I
> am prepared to notify all the defendants of this suit by email.
>
> 17. A temporary restraining order is required because since it has
> been proved that Polgar and Truong are the Fake Sam Sloan the USCF has
> gone on lockdown. Truong stayed up all night the night of September
> 26, 2007 deleting all of his Fake Sam Sloan and Fake Ray Gordon
> posting from the Google newsgroups. Through the wonders of the
> Internet, Mottershead was able to observe Truong staying up all night
> deleting his postings. However, the three thousand postings survive on
> Forte Agent and on Giganews.com .
>
> 18. The USCF, after being advised by counsel that closing down the
> forums will be seen as a cover-up, has left the forums open but had
> ordered the moderators Herbert Rodney Vaughn and Tim Sawmiller, who
> are the only moderators left after several resigned complaining about
> pressure from the board to delete any comments unfavorable to board
> members and after the only really good moderator committed suicide, to
> either delete or pull for public viewing any reference to the
> impersonations by Truong and Polgar of the Fake Sam Sloan. On the
> first day that this situation became public, there were within a few
> hours more than 150 postings on this topic by a wide variety of USCF
> members. All of them were pulled or deleted by Vaughn. As soon as that
> happened, another hundred postings appeared on other topics within a
> matter of minutes.
>
> 19. The following "LOCKED" message was posted by Bill Hall on the USCF
> Forums on September 29, 2007:
>
> by nolan on Sat Sep 29, 2007 7:50 pm #71818 Bill Hall has requested
> that this message be posted:
>
> Dear Forum Users,
>
> In light of recent events, I feel it is in the best interest of the
> USCF to call a moratorium to discussions regarding someone posting as
> other real individuals on other discussion forums.
>
> This issue has potential legal liability ramifications from several
> directions, and I believe it to be my fiduciary responsibility at this
> time to place this topic on pause until more of the facts have been
> reviewed.
>
> Moderators: Please remove all posts pertaining to this topic. Please
> place any posters that continue to violate this in the moderation
> queue (prior moderator approval required for post to be displayed). I
> authorize the moderators to utilize the moderation queue as needed
> until further notice.
>
> I hope this issue can be addressed in an expeditious fashion. The
> posts that are removed will not be deleted and may return at a future
> date. Please help us in protecting the Federation and help to insure
> all parties to this matter are treated respectfully and fairly.
>
> Bill Hall
>
> 20. The result is that dues-paying USCF Members are being denied
> access to their forums which are a membership benefit and are being
> prevented from knowing what is going on inside their federation and
> expressing their opinions about this subject and in the mean time USCF
> insiders are running around deleting all the evidence by removing
> postings. Thousands of these Internet postings have already been
> deleted or pulled. This situation calls for a TRO. In addition,
> Plaintiff maintains that the moderators really have no right to
> delete postings by USCF members as long as basic rules of decorum are
> followed such as no obscenity. Plaintiff maintains that it is illegal
> to use the powers of the moderators to suppress dissent.
>
> 21. For example, in December 2006, at about the same time that Polgar
> and Truong announced that they were running for USCF election, rumors
> started circulating that they were ried to each other. Each time
> they were asked this question they complained to the moderators and
> had the question deleted. Members also asked questions on the forums
> about the millions Truong had supposedly made, about the billion
> dollar Fortune 500 Companies Truong had supposedly rescued, about the
> four World Championships Polgar claims that she won and many other
> questions about the fantastic claims that Truong and Polgar kept
> making while running for election. Each time questions like this were
> asked, Polgar and Truong complained to the moderators and got the
> questions deleted.
>
> 22. Plaintiff claims that the USCF Executive Director acted improperly
> and possibly even illegally in having all these postings by USCF
> members deleted. Plaintiff requests that this court order that all
> such postings be reinstated so that the members can view them.
>
> WHEREFORE, for all of the reasons set forth above, Plaintiff requests
> a temporary restraining order and a preliminary and permanent
> injunction, providing the following:
>
> 1. The USCF Moderators under the supervision of USCF Executive
> Director Bill Hall, shall immediately stop all deletions of postings
> by USCF Members to the USCF Forums. Attempts will be made to recover
> and restore all postings already deleted, removed or pulled and all
> recovered postings shall be made visible so that the members can see
> them.
>
> 2. All IP addresses of the postings shall be restored to that the
> members can see the evidence showing who actually made these postings.
>
> 3. All locked threads shall be unlocked and all postings removed from
> visibility shall be made visible to the members again.
>
> 4. The USCF election held in July 2007 is suspended or vacated and the
> results set aside. The former board members are reinstated on the
> board and the new board members are removed from the board until a
> hearing and final determination can be had.
>
> 5. Such other and further relief as may be deemed just and equitable.
>
> Samuel H. Sloan
> 1664 Davidson Ave=
., Apt. 1B
> Bronx NY 10453
>
> (917) 507-7226
> 1-347-869-2465
> samsl...@samsloan=
.com
>
> STATE OF NEW YORK )
> ss:
> COUNTY OF BRONX )
>
> VERIFICATION
>
> 1, the undersigned, the petitioner named in the foregoing petition,
> being duly sworn, says:
> I have read the foregoing petition subscribed by me and know the
> contents thereof and the same is true of my own knowledge, except as
> to those matters herein stated to be alleged upon information and
> belief and as to those matters I believe it to be true.
>
> _________________________
> Samuel H. Sloan
>
> On the 2nd Day of October, 2007 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
It isnt legal as there is no Sam Sloan. His legal name is Mohamed
Ismail Sloan. By coercing a notary public to falsify legal documents a
potentially greater crime has been comitted? Unless he has again
legally changed his name back? WHich is it and who are you really?
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