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Date: 04 Oct 2008 05:02:35
From: samsloan
Subject: Affidavit in Support of Motion to Reconsider
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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 AND MOTION FOR RECONSIDERATION
OF THIS COURT'S DECISION DATED OCTOBER 1, 2008
__________________________________________
PLEASE TAKE NOTICE that the undersigned hereby moves this court for an
order granting reconsideration of this courts order dated October 1,
2008 on the grounds that Document #37 which this court cited in
denying reconsideration of the judgment or this court dated August 29,
2008, which dismissed this complaint, was never served on Plaintiff
and is improper for other reasons and thus was improperly filed and
should not have been considered by this court.
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:
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
Patrick M. O'Brien, Esq.
Attorney for William Brock
309 Elmore Street
Park Ridge, Illinois 60068-3569
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 FOR RECONSIDERATION OF THIS COURTS ORDER DATED OCTOBER 1, 2008
WHICH DENIED RECONSIDERATION OF THE JUDGMENT DISMISSING THIS COMPLAINT
__________________________________________
STATE OF NEW YORK )
ss:
COUNTY OF BRONX )
Samuel H. Sloan, being duly sworn, deposes and says:
1. I hereby move for reconsideration of this court's order dated
October 1, 2008 which denied reconsideration of the judgment dated
August 29, 2008 dismissing this action.
2. I was shocked to receive this court's order dated October 1, 2008
which denied my motion for reconsideration of this courts judgment on
the grounds that the documents upon which this court based its
decision are to be found in document number #37, because I have never
been served with and had never seen or heard about such documents.
3. Yesterday, I went to the courthouse and obtained from your law
clerk, Jennie, a copy of document #37. This action was necessary
because document #37 is not to be found in the files of this case or
in the public record room.
4. I was shocked to discover that document #37 does not have an
affirmation of service attached. As far as I know, no document is
allowed to be filed in court without an affidavit or an affirmation
attached. I would like to know how Proskauer Rose, who filed this
document, was able to slip this through the court security system and
file a document without including an affirmation or affidavit of
service. I wish to emphasize that prior to being given a copy of this
document by your law clerk yesterday, I had never seen, never been
served with or knew anything about document #37.
5. I asked your law clerk to double check to see if it was really true
that document #37 was filed without an affirmation of service
attached. She double-checked and affirmed that document #37 did not
have an affirmation of service attached.
6. Had I seen document #37 previously, I would have protested
immediately because it contains obvious falsehoods or at least
questionable statements. This probably explains why it was not served
on me. Document #37, as provided to me yesterday by your law clerk, is
annexed as Exhibit A.
7. Document #37 consists of an affidavit of William Goichberg dated
February 11, 2008 sworn to before George W. Brown, Commissioner of
Deeds of the City of Mt. Vernon New York. I question this because a
Commissioner of Deeds does not have authority to act outside of his
locality and Goichberg was in California at the time. This particular
issue was debated in a discussion that was broadcast online during the
USCF Executive Board meeting in Crossville Tennessee. in which Mr.
Goichberg stated that he was unwilling to leave the State of
California at any time during the month of February 2008 and therefore
he was insisting that the February Board meeting be held in
California. Paul Truong vehemently objected to this, stating that he
was willing to travel to any other state except for California. This
debate was broadcast over the Internet and was watched by dozens of
USCF members, so there are a lot of witnesses to Mr. Goichberg making
that statement. The audio of that debate has been preserved and should
be available at
http://evansvillescholasticchess.org/webcast/
8. Even if it turns out that Mr. Goichberg changed his mind and flew
back to New York, this affidavit is improper because a requirement of
NEW YORK STATE LAW is that any affidavit must recite the location
where the affidavit is signed. For example, my affidavit here and all
of the affidavits I have filed in this court have contained the words:
STATE OF NEW YORK )
ss:
COUNTY OF BRONX )
9. Any affidavit without such words is invalid. In this case, since we
know that Goichberg was in California at the time, a serious criminal
offense may have been committed in that a false notary signature may
have been included.
10. This is included in New York Real Property Law Section =A7 309-a
which provides:
=A7 309-a. Uniform forms of certificates of acknowledgment or proof
within this state. 1. The certificate of an acknowledgment, within
this state, of a conveyance or other instrument in respect to real
property situated in this state, by a person, must conform
substantially with the following form, the blanks being properly
filled:
State of New York)
)ss.:
County of ............)
11. Please note that this requirement as to a Commissioner of Deeds is
even stronger than that with respect to a Notary Public, because a
Commissioner of Deeds has no authority to act outside of his local
jurisdictional bounds. Thus, a Commissioner of Deeds for the City of
Mt. Vernon New York loses the authority to act once he steps across
the city line and leaves the City of Mt. Vernon. On the other hand, a
notary public has authority to act throughout the State of New York.
However, neither a Commissioner of Deeds nor a Notary Public has the
authority to act within the State of California. (How do I know this?
It is on the test that I passed to become a notary public.)
12. I was served by Proskauer Rose with an affidavit of William
Goichberg in support of his motion to dismiss that was sworn to the
9th day of January 2008 and is notarized by Pi Ning Cheung, Notary
Public - California, Los Angeles. I mentioned this affidavit in my
opposition to Goichberg's motion to dismiss, dated February 2, 2008.
However, it appears that this affidavit was never filed in court.
Instead, it seems that the affidavit dated February 11, 2008 was
substituted, which may explain another reason why I was not previously
aware of it.
13. Another strange fact is that included in the Bill of Costs filed
by Proskauer Rose is a check for $5 dated February 6, 2008 paid to the
Orange County Clerk in payment for a certified copy of the deed to the
property owned by Bill Goichberg. This is included in document #42 in
the PACER file of this case. It is odd that a high powered $500 (five-
hundred-dollar) per hour law firm like Proskauer Rose goes to the
trouble of writing out a check for five dollars to pay the Clerk of
Orange County for a copy of the deed, when Bill Goichberg should have
been able to provide a copy of that deed himself, provided that he was
in New York and not in California of course. I realize that Proskauer
Rose is assigned counsel, assigned by Chubb Corporation, who has
provided Directors and Officers Insurance, so neither Bill Goichberg
nor the USCF has to pay for the time and trouble that it took for
Proskauer Rose to obtain a copy of that deed. However, even though
Goichberg does not care, I find it wasteful and inappropriate and even
insulting to Proskauer Rose that Goichberg could not provide the deed
himself.
14. This indicates that Goichberg was in California on February 6,
2008. I have provided his exact address. Goichberg was staying in Room
267 of the Santa Anita Inn, located at 130 West Huntington Drive,
Arcadia, CA 91007 and was eating 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. A Great place!! All you can
eat for $10 !!!
15. This brings us to a false or misleading statement in the Goichberg
affidavit. He writes that he travels =93occasionally=94 and further
states:
7. During calendar year 2007, I made one business trip to the western
part of the United States, which included directing chess tournaments
in California and Nevada.
16. If it is really true that he made only =93one business trip=94, that
=93one trip=94 lasted a long time, probably at least six months. I know
this because I was on the board with him during most of 2007. He was
at Bally's Casino in Las Vegas for his North American Open held
December 26-29, 2006. Then we had a board meeting in Monrovia,
California, a suburb of Los Angeles, on February 2-3, 2007. Then we
had another board meeting on May 17-18, 2007 in Stillwater, Oklahoma.
Goichberg came in from California for that meeting. Finally, Goichberg
held his annual World Open Championship in Philadelphia on July 4-7,
2007. The USCF delegates meeting and my last board meeting was held in
Chicago on August 10-12, 2007. That was where Polgar and Truong took
my place on the board. So, we know that if Goichberg really took only
=93one trip=94 west, that trip lasted from December, 2006 until at least
May 2007. I am fairly certain that after the Stillwater, Oklahoma
meeting, Goichberg went back to California. Also, he seems to be
playing with words. We know that by December 2007 he was back in Las
Vegas for his North American Open and that by January 9, 2008 he was
back in Los Angeles, because that is the date of his affidavit dated
January 9, 2008. We need to know exactly what Mr. Goichberg means in
his affidavit by =93occasionally=94 and by =93one business trip=94. Does a
trip that starts in December 2006 and ends in May 2007 and another
trip that begins in December 2007 and ends some time in 2008
constitute one trip in 2007 or two trips or none? Remember that
Goichberg is using his claim to have made only =93one business trip=94 to
defeat this court's diversity jurisdiction. Also, what is a =93business
trip=94? Is it opposed to a non-business trip?
17. Now, Goichberg tells us to look at the website for Blooming Grove
at http://propertydata.orangecountygov.com/ . So, naturally I did.
18. This shows that the Goichberg property is: Swis: 332089 Tax Map
ID# 3-1-9. By clicking on =93Show Tax Map (PDF)=94 one sees a tax map. Lot
3-1-9 is in the far lower right corner of the tax map. (It took me a
long time to find this). Lot 9 is the corner lot on the corner of
Route 94 and Penny Lane. The areal view and also the Google maps view
shows that there is an empty lot on the corner. It is true that there
is a clump of trees there and there could be a structure, difficult to
see, within that clump of trees. However, that would not necessarily
be a residence. It could be a horse barn, a wood shed, a dog house or
some other kind of structure. We do not know. We do know that there is
no postal address there, recognized by the US Post Office. Goichberg
has admitted that.
19. Goichberg also states in his affidavit in Document #37 that he
owns a home in Mt. Vernon NY. We do know about that one. That is his
parent's home at 450 Prospect Avenue, Mt. Vernon NY. His father, Sol
Goichberg, died in July 1978 and his mother, Fannie Goichberg, died on
October 29, 2005 at age 96. I knew both of his parents because they
usually came with him to chess that tournaments that he ran. I also
happen to know that over the years there were times when his parents
bailed him out when he lost big money in his chess tournaments.
Goichberg usually guarantees at least $100,000 in cash prizes in the
chess tournaments that he runs and sometimes he does not make the
gate. I have known Bill Goichberg since July 1961 when he defeated me
in the 1961 Eastern Open Chess Championship in Washington DC. I have
been what I have considered to be friends with him since 1964, when we
often met at the Marshall Chess Club. Having known Bill Goichberg for
47 years, I know his history well.
20. If Goichberg had claimed that the address of 450 Prospect Avenue,
Mt. Vernon NY was his actual residence, I would have had a difficult
time winning on this issue because I know that when he is in New York,
that is where he is. I have never been to that house but I am told by
others who have been there that it is a nice home. On the other hand,
I have been told by those who say that they have been to his place in
Salisbury Mills that it is a =93small cottage=94 filled with chess
trophies that he is recycling and other =93junk=94. (When Goichberg runs
scholastic tournaments, he awards the kiddies with trophies, not with
cash. Often, after their picture is taken holding the trophy, the kids
leave behind the trophy they have won, so Goichberg picks them up,
puts a new plaque on them, and awards them again at the next
tournament.)
21. However, Goichberg does not claim 450 Prospect Avenue, Mt. Vernon
NY as his residence. I have no doubt that he inherited the house from
his parents. In any case, since he does not claim residence at Mt.
Vernon NY, it is immaterial for the diversity issue whether he owns a
house there or not. He could be renting it out.
22. From all this, it should be clear that Goichberg travels a great
deal, all the time. There is no one place where he can be found on a
regular basis. For some reason, he does not want his actual residence
revealed, so he uses in this case an address that is not recognized by
the US Postal Service, which is 2084 Route 94, Salisbury Mills NY. I
can understand that he might have good and valid reasons for
concealing his actual address. For example, at the last World Open
held July 4-7, 2008, Goichberg awarded $358,000 in cash prizes.
Naturally, he is concerned that he might be robbed. Fortunately, it is
only us chess players who know how much money he is carrying. Usually,
the Americans who win prizes at his tournaments will accept his check,
but the Russians who come here from Moscow and who usually win the
World Open generally insist on being paid in cash. Goichberg in years
past has hired armed guards at his tournaments, but lately with most
chess players paying with credit cards he does not use them any more.
Also, Goichberg might have tax reasons why he chooses not to use or
even to reveal his actual address.
23. I can think of many possible reasons why Goichberg does not want
his actual whereabouts known. That is not my concern. I am not trying
to start an investigation of his taxes. I hope he makes a million
bucks running his chess tournaments, especially since I know that he
will use the money to run more and bigger chess tournaments. I wish
him every success. I might even win one some day. However, I do not
believe that one who refuses to reveal his actual address can use his
secret address to defeat the diversity jurisdiction of this court.
24. Regarding the statement made by Bill Goichberg at the board
meeting in Crossville Tennessee that he would not be leaving the State
of California at any time during the month of February 2008 I must
point out that the by-laws of the USCF require that transcripts of the
board meetings be kept, maintained and posted on the website. However,
ever since Bill Goichberg became USCF President, no transcripts have
been posted. This indeed is one of the central issues raised in my
complaint. I need those transcripts to help prove my case. Section 31
of the Delegate Actions of Continuing Interest which is part of the by-
laws states:
EB Transcripts and Minutes. The following procedure was adopted for
the documentation of the proceedings of Executive Board meetings:
1. The Secretary or his or her designee shall prepare Minutes based
upon the documentation of motions in the transcripts of the meeting
and submit them to the Executive Board for comments, corrections, and/
or suggestions.
2. The Secretary or his or her designee shall consider the comments
made by the Executive Board and may revise the Minutes where
appropriate. Any deviation from the transcript must be indicated with
an explanation and a reference to the transcript. The transcript must
be available concurrently.
3. The transcript of all Open session meetings are to be posted on the
USCF website as soon as practical, so that anyone who has any
questions can access the basic documentation for all motions and can
access Open session discussions that are not likely to be in the
published Minutes. Since any motions made in Closed session must be
voted in Open session as well, the Open session transcripts will be
sufficient to document all motions.
4. The transcripts are to include all Open session activity. The
stenographer must record everything until the meeting is actually
adjourned. No motions are to be voted on the absence of the
stenographer. If it is not on the Open session transcripts it did not
happen! (2000)
25. In summary, here are my points:
(a) Document #37 was not served on me. No affirmation of service is
provided. This violates the fundamental rule that all documents to be
considered by the court must be served on the other side. Therefore,
document #37 should not have been considered by this court.
(b) Another document, dated January 9, 2008, showing Mr. Goichberg to
be in California on that date was served on me but was apparently not
filed in court, in violation of the rules of court. A letter from
Proskauer Rose stating that this affidavit would be filed is annexed
as Exhibit B. If this affidavit was filed it would have to be document
#28, but I believe that document #28 was another affidavit.
(c) The affidavit included in Document #37 is not valid because it
fails to provide the State and County where it was signed. This is in
violation of Section =A7 309-a of Real Property Law, which covers the
Commissioners of Deeds. This is especially disturbing because
Goichberg is known to have been in California at that time and it is
possible that the Commissioner of Deeds was in California too, which
makes his signature invalid.
(d) The affidavit contained in Document #37 is false because it states
that Goichberg travels only =93occasionally=94 and only traveled once to
the Western United States in 2007, but those of us who know Goichberg
well, including myself who have known Goichberg for 47 years, know
that he is constantly traveling and know that he made at least two
trips and that he stayed at least six months in the Western United
States during 2007.
(e) Even conceding that Mr. Goichberg really does own lot number 3-1-9
in the municipality of "Blooming Grove" New York, that does not prove
that there is a habitable house there, that he actually resides there,
that he ever spends the night there, that he is domiciled there or
that he is a citizen of that place for diversity jurisdiction
purposes, especially since it is well known that he actually resides
in other places.
(f) Difficulties in proving that Goichberg stated that he would not be
leaving the State of California any time during the month of February
2008 are caused by the fact that ever since Goichberg has been USCF
President, he has ignored the requirement in the by-laws that a
transcript of all board meetings be made, maintained and posted on the
website. Goichberg should not be allowed to benefit from his refusal
to abide by the by-laws. There are several dozen witnesses who heard
Goichberg make the statement that he would be in California during the
entire month of February 2008, who were either at the meeting in
Crossville or who were viewing the live video broadcast of the meeting
on line.
WHEREFORE, this motion for re-reconsideration should be granted and
the decision and judgment of this court should be vacated and set
aside.
_______________________
Samuel H. Sloan
1664 Davidson Ave., Apt. 1B
Bronx NY 10453-7877
1-917-507-7226
1-917-659-3397
[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.
__________________________________
Signature of Plaintiff
On the 3rd Day of October, 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
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Date: 05 Oct 2008 14:21:00
From: samsloan
Subject: Re: Affidavit in Support of Motion to Reconsider
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On Oct 5, 3:03=A0pm, samsloan <[email protected] > wrote:
> On Oct 4, 8:02=A0am, samsloan <[email protected]> wrote:
>
> >This particular issue was debated in a discussion that was broadcast onl=
ine during the
> > USCF Executive Board meeting in Crossville Tennessee. in which Mr.
> > Goichberg stated that he was unwilling to leave the State of
> > California at any time during the month of February 2008 and therefore
> > he was insisting that the February Board meeting be held in
> > California. Paul Truong vehemently objected to this, stating that he
> > was willing to travel to any other state except for California. This
> > debate was broadcast over the Internet and was watched by dozens of
> > USCF members, so there are a lot of witnesses to Mr. Goichberg making
> > that statement. The audio of that debate has been preserved and should
> > be available athttp://evansvillescholasticchess.org/webcast/
>
> This particular debate, where Goichberg stated that he was not willing
> to leave the State of California and Truong stated that he was willing
> to go to any one of the other 49 states, every state except for
> California, was broadcast athttp://evansvillescholasticchess.org/webcast/=
110407a.m3u/=A0 Clip
> 110407a-21
>
> Sam Sloan
Sorry, that should be
http://evansvillescholasticchess.org/webcast/110407a.m3u clip
110407a-21
Sam Sloan
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Date: 05 Oct 2008 12:03:44
From: samsloan
Subject: Re: Affidavit in Support of Motion to Reconsider
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On Oct 4, 8:02=A0am, samsloan <[email protected] > wrote:
>This particular issue was debated in a discussion that was broadcast onlin=
e during the
> USCF Executive Board meeting in Crossville Tennessee. in which Mr.
> Goichberg stated that he was unwilling to leave the State of
> California at any time during the month of February 2008 and therefore
> he was insisting that the February Board meeting be held in
> California. Paul Truong vehemently objected to this, stating that he
> was willing to travel to any other state except for California. This
> debate was broadcast over the Internet and was watched by dozens of
> USCF members, so there are a lot of witnesses to Mr. Goichberg making
> that statement. The audio of that debate has been preserved and should
> be available athttp://evansvillescholasticchess.org/webcast/
This particular debate, where Goichberg stated that he was not willing
to leave the State of California and Truong stated that he was willing
to go to any one of the other 49 states, every state except for
California, was broadcast at
http://evansvillescholasticchess.org/webcast/110407a.m3u/ Clip
110407a-21
Sam Sloan
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Date: 04 Oct 2008 14:04:45
From: foad
Subject: Re: Affidavit in Support of Motion to Reconsider
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"samsloan" <[email protected] > wrote in message
news:61b4e655-e590-49dd-bb21-ac2760d3664b@u65g2000hsc.googlegroups.com...
8. Even if it turns out that Mr. Goichberg changed his mind and flew
back to New York, this affidavit is improper because a requirement of
NEW YORK STATE LAW is that any affidavit must recite the location
where the affidavit is signed. For example, my affidavit here and all
of the affidavits I have filed in this court have contained the words:
STATE OF NEW YORK )
ss:
COUNTY OF BRONX )
9. Any affidavit without such words is invalid. In this case, since we
know that Goichberg was in California at the time, a serious criminal
offense may have been committed in that a false notary signature may
have been included.
10. This is included in New York Real Property Law Section � 309-a
which provides:
� 309-a. Uniform forms of certificates of acknowledgment or proof
within this state. 1. The certificate of an acknowledgment, within
this state, of a conveyance or other instrument in respect to real
property situated in this state, by a person, must conform
substantially with the following form, the blanks being properly
filled:
State of New York)
)ss.:
County of ............)
11. Please note that this requirement as to a Commissioner of Deeds is
even stronger than that with respect to a Notary Public, because a
Commissioner of Deeds has no authority to act outside of his local
jurisdictional bounds. Thus, a Commissioner of Deeds for the City of
Mt. Vernon New York loses the authority to act once he steps across
the city line and leaves the City of Mt. Vernon. On the other hand, a
notary public has authority to act throughout the State of New York.
However, neither a Commissioner of Deeds nor a Notary Public has the
authority to act within the State of California. (How do I know this?
It is on the test that I passed to become a notary public.)
=================
I applaud your efforts to put one over on the court. Many judges are barely
literate political party hacks, so perhaps you will get lucky. However,
nearly everyone -- even a judge -- will have heard of the well known
Weinstein case, wherein it is written ("on whatever it is that they write on
up there") that
"there is no requirement that a certificate of acknowledgment contain the
precise language set forth in the Real Property Law. Rather, an
acknowledgment is sufficient if it is in substantial compliance with the
statute" (Weinstein v Weinstein, 2007 N.Y. App. Div. LEXIS 720).
Stee--rike one.
Moreover, if as you claim "Goichberg was in California at the time" then
section 309-a, which applies to "certificate of an acknowledgment, within
this state" does not apply, as California is not "within this state."
California is in fact a whole other country, nearly.
Stee-rike two.
And finally, assuming your unfounded allegation regarding Goichberg's
whereabouts is true -- he wasn't in NY because at some point he said he
wasn't planning on going to NY is hardly proof that he never went to NY --
your accusation that the Commissioner of Deeds committed "a serious criminal
offense" is unlikely to move the court, as "section 309-a (1) . .. . does
not require notary to observe execution" (In re Levison, 2004 N.Y. App. Div.
LEXIS 12601). Rather, "the undersigned personally appeared ***OR personally
known to me OR proved to me on the basis of satisfactory evidence*** to be
the individual whose name is subscribed to." So if Goichberg was in CA and
signed and fedexed the doc to NY where it was notarized on the basis
Steer-rike three.
Motion denied. Sanctions for frivolous filing and lying to the court?
Unlikely. Judges take pity on the pro se, who have a fool for a client.
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