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Main
Date: 16 Jan 2009 16:49:48
From: samsloan
Subject: Final Draft as actually filed - Motion for Sanctions against Brock
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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 five
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 five 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: 17 Jan 2009 16:41:43
From:
Subject: Re: Final Draft as actually filed - Motion for Sanctions against
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On Jan 17, 3:07=A0pm, "foad" <[email protected] > wrote:
>
> numbfuckingskull
> fuckwitted
> shitbrain.
>
> sorry for any confusion.
Charming.
David Ames
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Date: 18 Jan 2009 00:47:52
From: foad
Subject: Re: Final Draft as actually filed - Motion for Sanctions against Brock
|
<[email protected] > wrote in message
news:[email protected]...
On Jan 17, 3:07 pm, "foad" <[email protected] > wrote:
>
> numbfuckingskull
> fuckwitted
> shitbrain.
>
> sorry for any confusion.
Charming.
David Ames
=========
I take I've lost your vote for MissCongeniality.
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Date: 17 Jan 2009 07:56:49
From: samsloan
Subject: Re: Final Draft as actually filed - Motion for Sanctions against
|
On Jan 17, 10:22=A0am, "foad" <[email protected] > wrote:
> A more interesting question is the conflict that Judge Chin's opinion rai=
ses
> between legal precedent in the Fourth Circuit, where Judge Bauman said th=
at
> your pleading in a prior case was "utterly lacking in merit,"
You are wrong as usual.
Judge Arnold Bauman, the judge in Sloan vs Richard M. Nixon, 60 FRD
228 (1973), was in the Second Circuit, in the same courthouse that the
current judge now sits.
Funny thing you just reminded me of. I few months after Judge Bauman
dismissed my complaint, I was in the New York City subway riding the
number 4 train when, because the subway was crowded, I literally
bumped into Judge Bauman. I was for some reason surprised to see a
federal judge riding the subways with the common people. I did not say
anything and I hoped that he did not recognize me.
I called the judge's law clerk and asked him to ask Judge Bauman to
change his opinion because everybody was ridiculing me because of it.
(Remember that Nixon was still president at the time.) The judge's law
clerk asked the judge and reported back to me that Judge Bauman
believes in preserving the historical record and will never agree to
change that decision.
Sam Sloan
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Date: 17 Jan 2009 20:07:49
From: foad
Subject: Re: Final Draft as actually filed - Motion for Sanctions against Brock
|
"samsloan" <[email protected] > wrote in message
news:a1bb4373-8cc2-41de-8d7c-ee9200936139@r13g2000vbp.googlegroups.com...
Judge Arnold Bauman, the judge in Sloan vs Richard M. Nixon, 60 FRD
228 (1973), was in the Second Circuit, in the same courthouse that the
current judge now sits.
==============
I am certainly willing to admit when I make a mistake. If I understand you
correctly, what you're saying is that there is no conflict between circuits
regarding the critical issue of whether you are a complete numbfuckingskull
and thus in both circuits it is settled law that you are utterly fuckwitted
and a shitbrain.
Thanks for clearing that up and sorry for any confusion.
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Date: 17 Jan 2009 06:51:07
From: samsloan
Subject: Re: Final Draft as actually filed - Motion for Sanctions against
|
On Jan 16, 9:02=A0pm, billbrock <[email protected] > wrote:
> This is going to be fun!
Amazing. Bill Brock actually likes being sued by me.
For those of you out there in the peanut gallery, what is going on is
this:
Most of you thought that this case was over in August, when the judge
dismissed my complaint "with prejudice" on August 29, 2008
However, that is not the case, because Bill Brock through his attorney
decided to keep the case alive by filing a Rule 11 Motion for
sanctions against me on October 3, 2008.
The basis for his motion was that even though I am not an attorney,
since I had defeated the SEC and its hot-shot young attorney Harvey
Pitt in the United States Supreme Court in SEC vs. Samuel H. Sloan,
436 US 103 (1978), therefore I should be held to the same [high]
standards that real lawyers are held and therefore I should be subject
to sanctions.
I thought that Mr. O'Brien's order was frivolous and ridiculous and I
did not bother to respond.
However, on December 11, 2008, the court entered a scheduling order
telling me when I must respond to this motion.
I protested. I called the clerks office asking: How can he do this
since the case was over months ago? The clerk's office said that as
long as that Rule 11 Motion is pending, the case is still alive and
before the courts
I was extremely busy because I have reprinted 27 books during the last
two months to get them ready for Christmas Shopping, see
http://search.barnesandnoble.com/booksearch/isbninquiry.asp?ean=3D092389146=
3
so I could not file my response until the Christmas holidays were
over.
In addition there were a lot of new and relevant developments
including especially the new lawsuit the USCF filed against Polgar in
the Illinois State Courts on December 29, 2008.
Also, kindly recall that I told Candidate Brian Lafferty on this forum
last week that I lack the power to drop the case because Bill Brock is
keeping the case alive and before the courts.
So, I finally had time to file my response and cross-motion to Bill
Brock's motion yesterday. I set yesterday as my self-imposed deadline
because yesterday was the last full day that the courts were open
while Bush was still president. I will be very busy with important
work to do after Bush leaves office and Kathy Boudin takes office as
our next US Attorney General, so I had to get it filed by yesterday.
I made it to the courthouse just in time and filed it and got it file
stamped by the clerk at 4:32 PM.
I was half expecting the clerk to say that it was too late and could
not be filed, but the clerk did not say that. He spent a long time
looking over my 135 page motion very carefully and checking the
court's docket sheet and finally said that it was OK, and file stamped
it and accepted a second copy as the courtesy copy for the judge.
So, the question I have now is: Is this entire case with all 16
defendants still pending before the judge or does the court only have
the limited jurisdiction to decide Brock's Rule 11 Motion and my Cross-
Motion. In other words, does the court now have jurisdiction to re-
open and re-visit the case entirely?
I do not know the answer to this question and I would like to hear the
opinions of others as to the answer.
Sam Sloan
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| | |
Date: 17 Jan 2009 16:38:53
From: Kulin Remailer
Subject: Re: Final Draft as actually filed - Motion for Sanctions against
|
On Sat, 17 Jan 2009 06:51:07 -0800, samsloan wrote:
> On Jan 16, 9:02 pm, billbrock <[email protected]> wrote:
>
>> This is going to be fun!
>
> Amazing. Bill Brock actually likes being sued by me.
Your posts seem to have the potential for long-run entertainment and I
would like to come up to speed.
Could you give us a 500-word summary of this fascinating case. Perhaps
another few hundred words about your own obviously fascinating life.
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Date: 17 Jan 2009 15:22:34
From: foad
Subject: Re: Final Draft as actually filed - Motion for Sanctions against Brock
|
"samsloan" <[email protected] > wrote in message
news:[email protected]...
I will be very busy with important
work to do after Bush leaves office and Kathy Boudin takes office as
our next US Attorney General,
===============
Let me guess: you're going to be named Assistant Undersecretary of Stupid.
So, the question I have now is: Is this entire case with all 16
defendants still pending before the judge or does the court only have
the limited jurisdiction to decide Brock's Rule 11 Motion and my Cross-
Motion. In other words, does the court now have jurisdiction to re-
open and re-visit the case entirely?
I do not know the answer to this question and I would like to hear the
opinions of others as to the answer.
===========
As I understand it, Judge Chin examined your pleading, found it and you
retarded, and dismissed the case. Without a motion for reconsideration or
suchlike, that opinion stands and you are considered retarded as a matter of
law. The question before the court now is whether you are to be considered
so retarded that your venality demands a further monetary fine, or whether
you are merely stupid, contemptible, and incompetent and can be let off with
a warning.
A more interesting question is the conflict that Judge Chin's opinion raises
between legal precedent in the Fourth Circuit, where Judge Bauman said that
your pleading in a prior case was "utterly lacking in merit," "utterly
without legal basis" and that over his long career, having seen "many
misguided lawsuits" that "this must be the nadir." If Judge Chin's decision
is read, as I believe it can be, to say that your pleading in the Brock case
was the worst and most fucking stupidest paper ever filed in a US court,
that would conflict with Judge Bauman, who said that the pleading in his
case was the most utterly fucking stupid and retarded juridical pleading in
the history of mankind. Such a conflict betwen circuits might give rise to
jurisdiction in the US Supreme Court, where this important issue could be
decided once and for all.
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Date: 17 Jan 2009 14:19:12
From: David L. Martel
Subject: Re: Final Draft as actually filed - Motion for Sanctions against Brock
|
Sam,
Instead of providing evidence of this harrassment you suggest that the
Judge Google around for himself. I wonder what the judge will think when he
reads that?
Good luck,
Dave M.
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Date: 17 Jan 2009 13:48:47
From: foad
Subject: Re: Final Draft as actually filed - Motion for Sanctions against Brock
|
So to recap. You sue Brock. The suit is dismissed with prejudice, with the
judge terming your allegations "nonsensical attacks that do not belong in a
pleading filed in a judicial proceeding." Your next step is to file a motion
for sanctions on the ground that the defendant got you kicked off ebay,
noting that the judge did not "put one and one together" and acted "totally
irrational" in dismissing your complaint.
If these facts are true, you seem to have made a tactical error. You will
get no where asking the judge to sanction Brock's lawyer, who is merely
acting zealously to represent his client's interests. Instead, you should
ask the judge to sanction himself. Obviously it is ultimately the judge's
fault that you got thrown off ebay, because had he not abused his discretion
by finding you brain damaged as a matter of law you might at this very
moment be bidding on some lovely bric a brac or summat. In fact, rather than
asking for sanctions you should probably demand that the judge sentence
himself to death. There is precedent for such a ruling, see for example Bugs
Bunny vs Fudd et al, 53 Looneytunes 736 (1962). Good luck.
"samsloan" <[email protected] > wrote in message
news:[email protected]...
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
__________________________________________
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 five
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 �Paul� Truong and Zsuzsanna �Susan� 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 �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 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 five 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 �child molester�.
3. This process has continued every single day. Every day, defendant
Bill Brock calls me a �child molester� 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 �Sam Sloan Child Molester� 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 �child molestation� that
he has admitted to having.
8. This goes far beyond just Internet postings. Mr. Brock has pursued
me and my family members, including my wife and children, on a broad
front. Only Monday of this week, my wife was called down to testify
before the New York State Department of State on a complaint filed by
Bill Brock. Mr. Brock is trying to have my license and my wife's
license as a notary public revoked. I enclose an an exhibit a copy of
the complaint filed by Bill Brock with the New York State Department
of State against my wife.
9. By the way, does not this complaint filed by Bill Brock with the
New York State Department of State give New York Jurisdiction over
this case?
10. In addition, Bill Brock has had both me and my wife kicked off of
Ebay, so I cannot sell the books that I publish on Ebay, thereby
depriving me and my family of a substantial source of income. Mr.
Brock does not deny doing these things. To the contrary he BRAGGS that
he has done this. Here is his posted comment on having me kicked out
of Ebay.
billbrock
View profile
(2 users) More options Jul 28 2008, 2:34 pm
Newsgroups: alt.marketing.online.ebay, rec.games.chess.politics
From: billbrock <[email protected] >
Date: Mon, 28 Jul 2008 12:34:29 -0700 (PDT)
Local: Mon, Jul 28 2008 2:34 pm
Subject: Re: Thank you Bill Brock for your One Penny book!!!
Reply to author
|
| |
Date: 16 Jan 2009 18:02:38
From: billbrock
Subject: Re: Final Draft as actually filed - Motion for Sanctions against
|
On Jan 16, 6:49=A0pm, samsloan <[email protected] > wrote:
> UNITED STATES DISTRICT COURT
> SOUTHERN DISTRICT OF NEW YORK
> __________________________________________
> Sam Sloan,
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0Plaint=
iff,
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =
=A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0Civil Action No. 07-CV-8537 (DC)
> =A0 =A0 =A0 =A0 -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,
>
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0Defend=
ants
> =A0__________________________________________
>
> 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 five
> years and this stalking and harassment is continuing to this day
> through this court process involving this case.
>
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =
=A0 =A0 =A0 =A0 =A0 =A0 Yours, etc.
>
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =
=A0 =A0 =A0 =A0 =A0 =A0 Samuel H. Sloan
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =
=A0 =A0 =A0 =A0 =A0 =A0 1664 Davidson Ave., Apt. 1B
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =
=A0 =A0 =A0 =A0 =A0 =A0 Bronx NY 10453-7877
>
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =
=A0 =A0 =A0 =A0 =A0 =A01-917-507-7226
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =
=A0 =A0 =A0 =A0 =A0 =A01-917-659-3397
>
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =
=A0 =A0 =A0 =A0 =A0 =A0 [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,
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 Plaintiff=
,
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =
=A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 Civil Action No. 07-CV-8537 (DC)
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0-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,
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0Defend=
ants
> __________________________________________
>
> MOTION and CROSS-MOTION for Rule 11 Sanctions against Defendant
> William Brock and his counsel Patrick M. O'Brien
> __________________________________________
>
> STATE OF NEW YORK =A0 =A0 =A0 =A0)
> =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0ss:
> COUNTY OF BRONX =A0 =A0 =A0 =A0 )
>
> 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 five 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 tha=
t
> 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
> =A0 =A0 =A0 =A0 (2 users) =A0More 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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