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Main
Date: 04 Feb 2008 14:41:58
From: Sam Sloan
Subject: First Draft - Affidavit in Opposition - Commernts Please
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK __________________________________________ Sam Sloan, Plaintiff, Civil Action No. 07-CV-8537 (DC) -against- Hoainhan "Paul" Truong, Zsuzsanna "Susan" Polgar, Joel Channing, William Goichberg, The United States Chess Federation, Bill Hall, Herbert Rodney Vaughn, Gregory Alexander, Frank Niro, Grant Perks, William Brock, Randall Hough, Randy Bauer, Jim Berry, Texas Tech University and United States of America, Defendants __________________________________________ AFFIDAVIT IN OPPOSITION TO MOTION TO DISMISS ON FEDERAL QUESTIONS ISSUE __________________________________________ Samuel H. Sloan, the plaintiff herein, being duly sworn, deposes and says: 1. I make this affidavit in opposition to the motion by various defendants to dismiss this action on the grounds of lack of a federal question. 2. Frankly, I consider the issues raised by the moving defendants to be frivolous. There are a great abundance of federal questions here. I think the defendants are just trying to buy time and to convince their clients that they are doing the best they can. 3. The United States Chess Federation ("USCF") has 86,000 members. Every state of the 50 states have members, with the least being Wyoming with about 500 members. The USCF represents the United States of America internationally. We are the equivalent to the United States Olympic Committee, except that instead of representing the USA in hundreds of sports, we only represent the USA in one activity, chess. 4. It is obvious that if the United States Olympic Committee or any other comparable organization such as the National Football League or the National Basket ball Association had experienced the massive election fraud, identity theft, online forgery, impersonations, misappropriations of funds and so on as have characterized the USCF in the past two years, the FBI would have moved in already and started making arrests. There would be people in jail now. There has not happened because there is not that much interest in chess. 5. There have been three forensic reports produced thus far. There are the Mottershead Report, the Jones Report and the Ulevitch Report. These three reports all reach the same conclusion. The Mottershead Report has proved absolutely, conclusively that Hoainhan "Paul" Truong sent 2464 fake or forged Internet postings over a two year period from June 25, 2005 until October, 2007. That is two thousand four hundred sixty four postings, most of which impersonated me, Sam Sloan, although some of them impersonated Ray Gordon, Andrew Zito and other real or fake personalities. 6. As to why I in particular would be the target of most of these impersonations, the best way to explain it is that I am the equivalent of the "Jack Anderson" of chess. Jack Anderson as you will recall was a newspaper columnists reporting on J. Edgar Hoover's apparent ties to the Mafia, Watergate, the John F. Kennedy assassination, the Nixon Administration, the Savings and Loan scandal, the CIA plans to assassinate Fidel Castro, the Iran-Contra affair and so on. He was a crusader against corruption. Henry Kissinger called Jack Anderson "the most dangerous man in America". The USCF Insiders such as Bill Goichberg have the same view of me as Richard Nixon had of Jack Anderson. 7. Because I have a wide readership, anybody wanting to bring down the USCF leadership might decide to impersonate me. Paul Truong is a complete nobody in the world of chess. When he started impersonating me, nobody would have bothered to read anything written by him. Therefore, when he wanted to attack somebody he would sign my name rather than his own name to his postings. Over the period of two and a half years, Truong, whom we now know to have been "The Fake Sam Sloan" as he was called, attacked virtually every significant chess personality except for Paul Truong, Susan Polgar and Joel Channing. The fact that he never attacked Joel Channing is one of the reasons that I believe that Joel Channing was in on this from the beginning. 8. I wish to emphasize that it is 100% proven that Paul Truong did this. Not merely 99% sure, not merely "beyond reasonable doubt", but absolutely 100% certain, no doubt at all. 9. Next, the motivation. The motivation is clear: He did it to attack the rivals of his wife, Susan Polgar, and ultimately to seize control of the financial assets of the United States Chess Federation, which has $3.2 million in annual revenues. 10. One of the most frequent targets of attack by "The Fake Sam Sloan" is Beatriz inello, a woman chess grandmaster and President of the United States Chess Federation from 2003 to 2005. The Fake Sam Sloan has called her a "bulldyke" one hundred times in Internet postings over a period of two years. Paul Truong, this time not in disguise, went to the Scholastic Counsel and other scholastic groups and told them that inello was a lesbian. Truong also called me, Sam Sloan, on the phone in 2004 and told me that inello was a lesbian. 11. Most of the postings by the Fake Sam Sloan, whom we now know to be Truong, contained sexual references, usually making claims about the sexual preferences of the targets. For example, Grandmaster Alexandria Kosteniuk, a Russian girl who lives in Florida, is called "a Lolita". Truong also conducted a campaign to kick Kosteniuk's name off the USCF Rating lists, since Kostenuik was rated higher than Susan Polgar (who falsely claims to be a "world champion") and to kick the picture of Kosteniuk out of Chess Life magazine to be replaced by pictures of Polgar. (In 2004-2005 most issues of Chess Life magazine had pictures of Kosteniuk. In 2006-2007 almost every issue of Chess Life had pictures of Polgar.) 12. Among the most frequent other targets of attack by The Fake Sam Sloan were US Woman's Champion Jennifer Shahade, former USCF President Don Schultz, and Chairman of the Seattle Chess Foundation Erik Anderson. 13. Please remember that most of these thousands of attacks were signed "Sam Sloan". It thus appeared that I, the Real Sam Sloan, was attacking all of these people. Also, the 2464 "Fake Sam Sloan" postings found by the Mottershead Report to have been made by Paul Truong were crossposted to two and sometimes three usenet groups, rec.games.chess.politics , rec.games.chess.misc and alt.chess. Thus, counting the crosspostings, there were more than five thousand postings. These postings were not made on just one website located in just one state. They were made on Usenet and broadcast all over the entire world and picked up and preserved in every country of the world. The total readership of these postings was at least in the hundreds of thousands and probably in the millions. 14. In challenging the jurisdiction of this court to consider this issue, the defendants have cited exactly one case. Best Van Lines, Inc. v. Walker, 490 F.3d 239 (2d Cir. 2007). However, that case does not lead to the conclusion they seek, for several reasons. 15. Best Van Lines, Inc. v. Walker, 490 F.3d 239 (2d Cir. 2007) involved a website in Iowa that posts reviews of moving companies. I have looked at this website and it contains statements such as "this moving company scratched my furniture", "that moving company lost my suitcase" and so on. I have yet to find a favorable review of any moving company on that website. 16. Best Van Lines is a moving company located in New York that was subjected to allegedly defamatory reks by the Walker website in Iowa. Ass a result, suit was filed in the Southern District of New York. 17. The District Court ruled and the Second Circuit affirmed that Best Van Lines must sue in Iowa, where the Walker website is located. By analogy, this is similar to a case of a small-town in newspaper in Iowa that has a few readers in New York. 18. However, the case presented here is different for a number of reasons. One is that the defamatory postings were not made on a simple website. They were broadcast and propagated all around the world in every country of the world. In the Best Van Lines case, if the computer hosting the Walker website were to crash, nobody in the entire world would be able to see it any more. However, in the case presented here, if one computer or even one hundred computers crash, the Truong postings will still be visible in many other places. Indeed, when Truong was apprehended, he stayed up all night in Mexico City where he was at the time trying to delete as many of these postings as he possibly could. He was able to delete many of them from Google Newsgroups, because that is where he had first posted them, but he still has not been able to delete them from Forte Inc. Agent, from Giganews.com or from the many other services that carry these newsgroups. 19. William Brock in his motion to dismiss states that his postings which in general stated that I am a child molester were all posted from his CPA Office in the Chicago Loop. However, the location of his personal computer is of little moment. What is important is where he posted them. Not only did he post them on the Usenet groups around the world, but he posted them on such places as the New York Times website which is obviously located in New York State. 20. An example of Brock's postings on the New York Times website is at: http://gambit.blogs.nytimes.com/2007/10/08/the-lawsuit-against-polgar-and-truong-et-al-a-forum/ 21. There, you will see numerous postings by William Brock on the New York Times website where he provides links to places where, he claims, one can find proof that I am a child molester and a child pornographer. Mr. Brock is obviously a sick, disturbed man. Clearly, Mr. Brock cannot now claim that the New York courts have no jurisdiction over this. 22. Best Van Lines, Inc. v. Walker, 490 F.3d 239, 250-51 (2d Cir. 2007) involved a moving company in New York complaining about a website in Iowa. However, in the case before this court, defendants have made a point of posting on forums read by the widest possible readership which are broadcast Worldwide. Even after the filing and service of this lawsuit, Defendant William Brock has made defamatory postings to the New York Times website which is, of course, located in New York. The New York Times has published ten articles about this case, three in the paper print version of the newspaper and the other seven on the online or "Gambit Blog" of the Newspaper. William Brock has continued posting his defamatory material accusing me of being a pornographer to these New York Times Gambit Blogs even while this case has been pending before this court. The first of these articles in the New York Times was "Chess Group Officials Accused of Using Internet to Hurt Rivals" by DYLAN LOEB McCLAIN Published: October 8, 2007 Kindly take a look at it. 23. Similarly, William Brock has posted these claims that I am a child molester to the "Daily Dirt" column of the chessninja.com website which is based in New York and operated by Mig Greengard in Greenwich Village, New York City and he has posted to the Susan Polgar Blogspot at susanpolgar.blogspot.com during which time and until approximately May, 2007 Susan Polgar resided in Rego Park, Queens, New York. Mr. Brock has posted 97 times to my biography on the Wikipedia Encyclopedia. Most importantly, William Brock has posted thousands of times since 2004 to the Internet Usenet groups rec.games.chess.politics and rec.games.chess.misc . These Usenet postings are not maintained at any one location. They are propagated and broadcast all over the world. If one computer crashes there will be plenty of others to back it up. That is the reason why the Internet is called "the World Wide Web". Although Google Newsgroups is the most popular place to post to and view these newsgroups, there are many others including Forte Agent and Giganews. 24. There is a big difference between the Bill Brock postings and the Paul Truong postings. Bill Brock signs his own name. He openly states that he is the poster and has many times challenged and dared me to sue him. 25. Paul Truong, however, signs MY NAME to his postings. He says that he is me. This is a much more serious case of Internet Identity Theft, Forgery and Impersonation. 26. Paul Truong does post under his own name on the USCF Issues Forum on the uschess.org website, because Fake-Name postings are not allowed there (This rule was enacted to stop Herbert Rodney Vaughn who posts as tanstaafl from posting his anonymous attacks on me.) Here is a posting by Truong on Tue Jul 25, 2006 11:32 am #16962 Well, as a life member of the USCF and someone who devote a lot of time, energy and money to promote scholastic chess, and someone with children playing chess, the background of a board member is vital to me, especially when someone has a horrific sexual history with minors. You are entitled to your opinion and I am entitled to mine. Sam Sloan is a danger to my children, the young members of the USCF and a serious legal liability to the USCF. Frankly, it appalls me the there are people who are willing to close their eyes and accept this monster. 27. As we now know, the real danger to Truong's children is Paul Truong himself because two judges of the Queens Family Court, Judge Friedman and Referee Nigron, have issued orders of protection prohibiting Paul Truong and Susan Polgar from inflicting corporal punishment on their children for refusing to play chess. I have never received any such order of this nature from any judge. 28. Not only has Bill Brock stated that I am a child molester thousand of times on the public newgroups, but he was also allowed to post that on the USCF website: by billbrock on Fri Jul 21, 2006 11:19 am #16303 For the record: Sam Sloan is a convicted felon. His two felony convictions directly impacted the safety and well-being of his children, but were not sexual in nature AFAIK. For the record: I maintain that Sloan is a child molester by his self-admitted conduct. He has never been convicted of such. 29. On this last point, I ask this court to search Lexus-Nexus and find the 6-3 decision by the Virginia Court of Appeals which affirmed my conviction. Please read carefully the opinion by the three dissenting judges. That dissenting opinion makes it clear that I was not remotely guilty of anything and could not possibly have been convicted in a properly conducted trial with a proper defense. 30. All this pertains to just one count of the complaint, namely the thousands of Internet postings by Truong and Brock impersonating me or calling me a "child molester" and other names. 31. There are four other counts to the complaint, numerous sub-counts and numerous causes of action. 32. One of these concerns the criminal theft by Truong and Polgar on August 20, 2003 of the USCF laptop computer which would have contained information about the missing two million dollars of USCF funds. 33. In 1999 the USCF had approximately two million dollars on deposit with the Oberweiss Fund, a mutual fund listed on the New York Stock Exchange. 24. By 2003 that two million dollars had been reduced to five dollars. Since there was no point in having an account with only five dollars in it, the Oberweiss account was closed. When the account was closed, Frank Niro, who was the Executive Director at the time, changed the accounting system to hide the horrific losses. The real question is: Who lost the money and what happened to it? The two Executive Directors during the relevant period were George DeFeis and Frank Niro. Both probably padded their resumes to get hired. DeFeis probably did not really have a Masters Degree in Business administration from Bernard Baruch School of Finance. Frank Niro claimed that he had received as award of "Hospital Administrator of the Year" but we have not been able to find out what hospital and what organization gave this award. (On this point, Bill Hall is a vast improvement on his predecessors. Unlike DeFeis and Niro who probably padded their resumes, Bill Hall honestly admits that he has no qualifications whatever for the job of Executive Director.) In either case, nearly two million dollars is missing and the laptop is missing too that would tell us what happened to the money. Polgar and Truong have admitted to taking the laptop, which was obviously criminal theft, and they have refused to return it. Bill Goichberg has made no effort to recover the laptop. Frank Niro is named as a defendant to this lawsuit but his own attorney, Proskauer Rose, has been unable to locate him. Truong and Polgar know where Frank Niro is. They have even visited him in Washington State fairly recently and posed for pictures with him there which are on the susanpolgar.com website, but refuse to reveal where he can be contacted. Frank Niro has also posted about this case on Paul Truong's chessdiscussion.com website so he certainly knows about it. 25. I personally believe that George DeFeis lost most of the money but that Frank Niro ripped of a fair piece of change for himself and is hiding, waiting for the statute of limitations to expire. 26. Meanwhile, Jeff Loomis, who was the Chief Financial Officer under DeFeis has suddenly reappeared TODAY !!! and has just posted on Susan Polgar's Chess Discussion group. Perhaps we can bring him in since the rest of them have absconded. 27. In short, there are more than enough grounds for federal jurisdiction here. Also, if not here, then where? If this sort of case does not raise a federal question, it then becomes possible for someone in Timbuktu, Mali, or in Russia, China or Nigeria to blanket the Internet with fraudulent postings. We already have millions of "Nigerian Scam" letters being received in people's email boxes every day. Undoubtedly, there are people who fall for these scams because the emails keep coming. Would this court rule that a victim would have to go to Nigeria to sue them? We also have a United States Presidential Election coming up and already there have been reports and complaints of similar Internet scams involving the presidential candidates. Those cases are much smaller than the instant case in that here we have 2,464 fake Usenet postings impersonating me and others, whereas most comparable cases involve just one or two emails. 28. A comparable and relevant case is Global Ministries vs. Cablevision Lightpath, CV 06-3669 (DRH) decided in the Eastern District of New York on November 30, 2006. This case involves an issue in this case, because that case turned on the right to obtain IP addresses. The Mottershead Report which found that Paul Truong had made the 2,464 Usenet postings under the name of Sam Sloan tracked the IP addresses of the various computers used by Truong and matched them with the computers used by the "Fake Sam Sloan". This showed a rekable coincidence in that where ever Paul Truong was the Fake Sam Sloan was there too. When Paul Truong posted from Rego Park, Queens, the Fake Sam Sloan posted from Rego Park Queens too. When Paul Truong moved to Lubbock, Texas to work for Texas Tech University the Fake Sam Sloan moved there. When Paul Truong and Susan Polgar went to Mexico City in September 2007 to visit the World Chess Championship, the Fake Sam Sloan posted from there too. Not only that, but they used the same computers, the same IP address and the same User Agent String. 29. With this happened consistently over and over again it became obvious that the Fake Sam Sloan and Paul Truong were one and the same. 30. This is why Paul Truong's priy defense as reported by the New York Times is that the evidence against him was "illegally" obtained. 31. However, in Global Ministries vs. Cablevision Lightpath, CV 06-3669 (DRH) decided November 30, 2006, the court ruled: III.Ms. Brown's Constitutional Rights The court must consider whether granting the petition will violate Ms. Brown's constitutional rights. The unknown defendant is alleged to have used Cablevision's services to access the stored electronic communications of petitioner, without authorization. In addition, the unknown defendant logged into the e-mail account of an employee of petitioner and used that person's e-mail to send fictitious messages of termination to other employees. Such a person has a "minimal expectation of privacy," if any, in using an Internet service provider to engage in such tortious conduct. See Sony Music Entertainment, Inc. V. Does 1-40, 326 F.Supp. 2d 556 (S.AN.Y.2004) ("defendants have little expectation of privacy in downloading and distributing copyrighted songs without permission.) 32. In the case presented here, we already know Mr. Truong's IP addresses. Brian Mottershead found them in the course of his duties as Administrator of the uschess.org website. Here is where Paul Truong made his big mistake. As "the Fake Sam Sloan", he personally attacked Brian Mottershead, thereby giving Mr. Mottershead the incentive to research and find out who was writing these nasty things about him. 33. On a related subject, Gregory Alexander, who is also a defendant here, has been contacting the authors of the three reports that prove that Paul Truong did it and has been making threatening and intimidating reks. Gregory Alexander has repeatedly contended that Brian Mottershead committed a crime by revealing the IP address of Paul Truong. I suspect that Gregory Alexander may have committed some offenses related to threatening or intimidating a federal witness. 34. Robert Jones, author of the "Jones Report", wrote the following: "Just wanted to let you know that I had an odd phone call from someone purporting to be from the USCF but I'm not sure if that is really the case. I answered the phone and this guy said he was Gregory Alexander from the USCF and immediately launched into a series of questions about my expertise in internet forensics, had I ever given evidence in court, etc. I was a bit taken aback but figured he was a USCF staffer or lawyer or something. I was happy to give him that information but then he asked me if I was aware that Brian Mottershead had hacked into his account, and was I aware the Paul Truong had criticized him two weeks before he prepared his report and would that knowledge change my conclusions on the data analysis. I explained to him exactly what I say in the report that I performed a technical analysis of the data associated with the Mottershead report and that I stand by the conclusions in my report. I said that I don't know Truong, Mottershead or any of the other players in this dispute. He then went on to say that Truong is a friend of his and that he has evidence that Truong is not involved in any of this - something about a friend of his has seen plane tickets (?) - and that making a defense against the claims out there against Truong is very difficult. I reiterated that my analysis was a straight technical analysis, done in response to your request, as an independent review of Mottershead's report. 35. Gregory Alexander is not "from the USCF". He is a close associate of Polgar and Truong. He is also the webmaster of their website. The "plane tickets" defense we already know about. It is one of the standard defenses Truong uses. Another is the "somebody is following me" defense. The "plane tickets" defense was used in the "Voice of Reason" case where Mig Greendard who had previously been one of their strongest supporters realized that his Daily Dirt website was being bombarded with postings by all sorts of different people all saying the same thing and all posting from the same IP address. This is one of Paul Truong's modus operandi. Truong creates dozens of fake personalities and posts under their names. When Mig Greengard realized that all these different identities were the same person, Truong and Polgar claimed that it could not have been them since they were traveling at the time and were on an airplane in mid-flight. This is probably the sort of "rock solid" evidence they claim to have recently provided to the board proving that it was not them. An Internet gadfly has posted what he calls "The List of the Blind Monkey" listing so far 41 ridiculous defenses presented by Truong allies which supposedly prove that they could not possibly be responsible for the 2,464 postings by the Fake Sam Sloan. The "somebody is following me" defense we know about too. It was also used by Paul Truong when in 2003 it was proven through IP addresses that he was the same person as "Bob Bennett". 36. In the last month or so, new fake posters have appeared. Their postings are "remailed automatically by anonymizing remailer software". They sometimes sign as "Sam Sloan" but usually do not give a name at all. Top suspects are Gregory Alexander and Paul Truong but it could be anybody. These anonymous fakes are posting every day lately, so please take a look. 37. Another issue in this case concerns the sale of the USCF building in New Windsor. In November, 2004, the USCF owned a fully paid for office building in New Windsor, New York. Bill Goichberg took it upon himself to sell it. He never consulted the board. There was no debate nor vote on this issue. At least two board members, Frank Brady and Don Schultz, were adamantly opposed to this sale and would have voted against had it come up for a vote. Unfortunately, Bill Goichberg who was Executive Director at the time, seems to treat the USCF as if he owns it and makes decisions without consulting the delegates or the board. The complete USCF minutes for every meeting for that period are available online. One can check the minutes and see that nowhere in the minutes does it show that the board ever debated, voted on and passed a resolution to sell the building. In short, the sale of the building was illegal, without corporate authority. 38. It is important to note that New Windsor is in Orange County which is in the Southern District of New York. Since most of the bad acts that are the subject of this lawsuit took place in New Windsor, this establishes the jurisdiction and venue of this court. 39. Finally, the USCF election itself was rife with fraud. Three times during the election campaign period I was suspended from posting for ten days each. Goichberg and Co. appointed the most hostile moderators they could find to moderate my postings and the postings of anybody who supported me including Gregory Alexander, Herbert Rodney Vaughn and Louis Blair. Not only was I suspended from posting but anybody who supported me was suspended from posting as well. Anybody who asked an embarrassing question of Polgar and Truong had their postings pulled and was suspended from posting. Questions asking Polgar and Truong whether they were ried to each other or not were not allowed. Questions were not allowed asking about the eleven national chess championships Truong falsely claims to have won or about the fake PhD degree Truong claimed to have had or about the billion dollar corporations Truong claims to have rescued and saved. More than one thousand postings were pulled by the pro-Truong and Polgar moderators. Dozens of individual USCF members were suspended from posting. I protested vehemently at the appointments by Goichberg of these anti-Sloan and pro-Polgarite moderators. Goichberg supported Polgar and Truong for election until just before the ballots were mailed out. Sometimes, Goichberg would appoint a moderator who failed to understand that his mandate was to stop me and my supporters from posting. Although vehemently hostile to me at the time they were appointed, a few of the moderators suddenly saw the light and reversed course. Examples of this are Ron Suarez and Steve Owens (�Steve of Tennessee�). When Goichberg and Channing realized that these moderators were not carrying out their mandate to muzzle me, they would contact these moderators, telling them to crack down on me and my supporters. At least two moderators resigned, protesting interference by the board, and one of the moderators committed suicide. 40. At a hearing, I will demonstrate and prove that Bill Goichberg and Joel Channing knew all along that Paul Truong was the "Fake Sam Sloan". They took no steps to stop him from doing this because it served their purposes to have someone impersonating me. Because of these and numerous other irregularities, I will be asking this court to declare the election null and void and to schedule a new election. I will also request that this court enjoin Polgar, Truong, Goichberg and Channing from running for office again or from ever holding office in the United States Chess Federation again, due to their numerous bad acts committed by these four defendants. 41. I am attaching as exhibits the three forensic reports that prove that Paul Truong did it. These are The Mottershead Report, the Jones Report and the Ulevitch Report. These reports are supported by more than one thousand pages of data that are available online. 42. In addition, I am attaching two orders of protection of the Queens Family Court prohibiting Susan Polgar and Paul Truong from abusing their children (by forcing them to play chess) plus several newspaper articles about this case. These have been three articles in the print edition of the New York Times about this case, plus seven additional articles in the online version of the New York Times, plus articles in the Boston Globe, the New York Post, the Lubbock Texas Avalanche Journal, the Daily Toreador campus newspaper of Texas Tech University, plus articles in "The Independent" newspaper in England. There are at least twenty online blogs and websites devoted to this case and there have been at least one thousand Internet postings about this case. (If this court or any of the attorneys have received any "nutty" or "screwball" letters about this case, I hope that the court recognizes that I have nothing to do with them. There are some seriously disturbed people out there who also happen to play chess.) 43. Also, be prepared to hear the "I am a victim" defense. If you look at Susan Polgar's blogs and websites you would believe that there is this massive conspiracy against her involving now the majority of the Executive Board of the United States Chess Federation (who finally stripped her of her fake titles on Saturday, February 2, 2008 (two days ago)). According to her, the USCF Board now joins co-conspirators the World Chess Federation ("FIDE"), newspaper reporters in the New York Times and other publications, the Hungarian Chess Federation and others. This probably explains why Polgar and Truong switched attorneys two weeks ago. She has been playing the role of "Everybody is Against me Because I am a Poor Jewish Girl" for the past 25 years. If you look at her performance on the BBC Broadcast "My Brilliant Brain - Make Me a Genius", now available on YouTube, you would never imagine that she never went to school and never learned the basic skills of reading, writing and arithmetic. Her two children complain that she cannot help with them with their homework in the second grade because she never learned that stuff. The only thing she can do is play chess (very well). She communicates with the outside world by emails and Internet postings that are undoubtedly written by Paul Truong and others, that she will no doubt disavow when the time comes. She already claims that she did not write her book "Queen of the King's Game" which attacks numerous of her past sponsors and benefactors. WHEREFORE, the motions to dismiss this case must be denied. _____________________ Samuel H. Sloan 1664 Davidson Ave., Apt. 1B Bronx NY 10453 917-507-7226 1-347-869-2465 [email protected] STATE OF NEW YORK ) ss: COUNTY OF BRONX ) VERIFICATION _________________________ Signature of Petitioner On the 4th Day of February, 2008 before me personally came Samuel H. Sloan to me known to be the person described herein and who executed the foregoing instrument. Such person duly swore to such instrument before me and duly acknowledged that he executed the same. _____________________________ NOTARY PUBLIC Affidavit of Service Samuel H. Sloan, being duly sworn, deposes and says that on February 4, 2008 he mailed the within affidavit in opposition to motion to dismiss this action for lack of diversity to the following addresses: Jeremy Brown Attorney for USCF, William Goichberg defendants Proskauer Rose LLP One Newark Center Newark NJ 07102-5211 Joseph J. Ortego Nixon Rose LLP Attorneys for Hoainhan "Paul" Truong and Zsuzsanna "Susan" Polgar 50 Jericho Quadrangle Jericho NY 11753-2729 Emily E. Daughtry Attorney for United States of America US Attorney's Office 86 Chambers Street, 3rd Floor New York NY 10007-2632 Patrick M. O'Brien, Esq. Attorney for William Brock 309 Elmore Street Park Ridge, Illinois 60068-3569 Arthur M. Handler Attorney for William Brock Handler & Goodman LLP 805 Third Avenue 8th Floor New York NY 10022 Scot M. Graydon Attorney for Texas Tech University Assistant Attorney General, General Litigation Division Attorney General of Texas PO Box 12548 Austin Texas 78711-2446 June Duffy Assistant Attorney General of New York 120 Broadway New York NY 10271 __________________________ Samuel H. Sloan Sworn to before me this 4th Day of February, 2008 ______________________________ NOTARY PUBLIC
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Date: 05 Feb 2008 12:31:02
From: [email protected]
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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As for advice on this, drop all the silly charges and stick to the one that matters. You have been impersonated by (you believe and can show evidence supporting your charge) Paul Truong. The USCF, Bill Brock, etc had nothing to do with it. You have the potential to make this an interesting case. So much of your life has been spent creating an on-line identity that you can make a much better case that this caused harm to you than most people could. Lay off the assertions of your huge importance in the non- virtual world, to USCF elections and such; these can be countered by showing your low vote totals. Above all, drop the Jack Anderson claim; this smells of megalomania. I am not a lawyer, but it looks like you have turned a pretty clear specific complaint into something that will be dismissed as being a fishing expedition, much too vague to press charges on. It is important to keep this in play until Truong is forced to testify under oath; don't blow your chance! Jerry Spinrad On Feb 4, 8:41=A0am, [email protected] (Sam Sloan) wrote: > UNITED STATES DISTRICT COURT > SOUTHERN DISTRICT OF NEW YORK > __________________________________________ > > Sam Sloan, > > =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 =A0 =A0 =A0 =A0 Civil > Action No. 07-CV-8537 (DC) > =A0 =A0 =A0 =A0 -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, > > =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 Defendants > __________________________________________ > > AFFIDAVIT IN OPPOSITION TO MOTION > TO DISMISS ON FEDERAL QUESTIONS ISSUE > > __________________________________________ > > Samuel H. Sloan, the plaintiff herein, being duly sworn, deposes and > says: > > 1. I make this affidavit in opposition to the motion by various > defendants to dismiss this action on the grounds of lack of a federal > question. > > 2. Frankly, I consider the issues raised by the moving defendants to > be frivolous. There are a great abundance of federal questions here. I > think the defendants are just trying to buy time and to convince their > clients that they are doing the best they can. > > 3. The United States Chess Federation ("USCF") has 86,000 members. > Every state of the 50 states have members, with the least being > Wyoming with about 500 members. The USCF represents the United States > of America internationally. We are the equivalent to the United States > Olympic Committee, except that instead of representing the USA in > hundreds of sports, we only represent the USA in one activity, chess. > > 4. It is obvious that if the United States Olympic Committee or any > other comparable organization such as the National Football League or > the National Basket ball Association had experienced the massive > election fraud, identity theft, online forgery, impersonations, > misappropriations of funds and so on as have characterized the USCF in > the past two years, the FBI would have moved in already and started > making arrests. There would be people in jail now. There has not > happened because there is not that much interest in chess. > > 5. There have been three forensic reports produced thus far. There are > the Mottershead Report, the Jones Report and the Ulevitch Report. > These three reports all reach the same conclusion. The Mottershead > Report has proved absolutely, conclusively that Hoainhan "Paul" Truong > sent 2464 fake or forged Internet postings over a two year period from > June 25, 2005 until October, 2007. That is two thousand four hundred > sixty four postings, most of which impersonated me, Sam Sloan, > although some of them impersonated Ray Gordon, Andrew Zito and other > real or fake personalities. > > 6. As to why I in particular would be the target of most of these > impersonations, the best way to explain it is that I am the equivalent > of the "Jack Anderson" of chess. Jack Anderson as you will recall was > a newspaper columnists reporting on J. Edgar Hoover's apparent ties to > the Mafia, Watergate, the John F. Kennedy assassination, the Nixon > Administration, the Savings and Loan scandal, the CIA plans to > assassinate Fidel Castro, the Iran-Contra affair and so on. He was a > crusader against corruption. Henry Kissinger called Jack Anderson "the > most dangerous man in America". The USCF Insiders such as Bill > Goichberg have the same view of me as Richard Nixon had of Jack > Anderson. > > 7. Because I have a wide readership, anybody wanting to bring down the > USCF leadership might decide to impersonate me. Paul Truong is a > complete nobody in the world of chess. When he started impersonating > me, nobody would have bothered to read anything written by him. > Therefore, when he wanted to attack somebody he would sign my name > rather than his own name to his postings. Over the period of two and a > half years, Truong, whom we now know to have been "The Fake Sam Sloan" > as he was called, attacked virtually every significant chess > personality except for Paul Truong, Susan Polgar and Joel Channing. > The fact that he never attacked Joel Channing is one of the reasons > that I believe that Joel Channing was in on this from the beginning. > > 8. I wish to emphasize that it is 100% proven that Paul Truong did > this. Not merely 99% sure, not merely "beyond reasonable doubt", but > absolutely 100% certain, no doubt at all. > > 9. Next, the motivation. The motivation is clear: He did it to attack > the rivals of his wife, Susan Polgar, and ultimately to seize control > of the financial assets of the United States Chess Federation, which > has $3.2 million in annual revenues. > > 10. One of the most frequent targets of attack by "The Fake Sam Sloan" > is Beatriz inello, a woman chess grandmaster and President of the > United States Chess Federation from 2003 to 2005. The Fake Sam Sloan > has called her a "bulldyke" one hundred times in Internet postings > over a period of two years. Paul Truong, this time not in disguise, > went to the Scholastic Counsel and other scholastic groups and told > them that inello was a lesbian. Truong also called me, Sam Sloan, > on the phone in 2004 and told me that inello was a lesbian. > > 11. Most of the postings by the Fake Sam Sloan, whom we now know to be > Truong, contained sexual references, usually making claims about the > sexual preferences of the targets. For example, Grandmaster Alexandria > Kosteniuk, a Russian girl who lives in Florida, is called "a Lolita". > Truong also conducted a campaign to kick Kosteniuk's name off the USCF > Rating lists, since Kostenuik was rated higher than Susan Polgar (who > falsely claims to be a "world champion") and to kick the picture of > Kosteniuk out of Chess Life magazine to be replaced by pictures of > Polgar. (In 2004-2005 most issues of Chess Life magazine had pictures > of Kosteniuk. In 2006-2007 almost every issue of Chess Life had > pictures of Polgar.) > > 12. Among the most frequent other targets of attack by The Fake Sam > Sloan were US Woman's Champion Jennifer Shahade, former USCF President > Don Schultz, and Chairman of the Seattle Chess Foundation Erik > Anderson. > > 13. Please remember that most of these thousands of attacks were > signed "Sam Sloan". It thus appeared that I, the Real Sam Sloan, was > attacking all of these people. Also, the 2464 "Fake Sam Sloan" > postings found by the Mottershead Report to have been made by Paul > Truong were crossposted to two and sometimes three usenet groups, > rec.games.chess.politics , rec.games.chess.misc and alt.chess. Thus, > counting the crosspostings, there were more than five thousand > postings. These postings were not made on just one website located in > just one state. They were made on Usenet and broadcast all over the > entire world and picked up and preserved in every country of the > world. The total readership of these postings was at least in the > hundreds of thousands and probably in the millions. > > 14. In challenging the jurisdiction of this court to consider this > issue, the defendants have cited exactly one case. Best Van Lines, > Inc. v. Walker, 490 F.3d 239 (2d Cir. 2007). However, that case does > not lead to the conclusion they seek, for several reasons. > > 15. Best Van Lines, Inc. v. Walker, 490 F.3d 239 (2d Cir. 2007) > involved a website in Iowa that posts reviews of moving companies. I > have looked at this website and it contains statements such as "this > moving company scratched my furniture", "that moving company lost my > suitcase" and so on. I have yet to find a favorable review of any > moving company on that website. > > 16. Best Van Lines is a moving company located in New York that was > subjected to allegedly defamatory reks by the Walker website in > Iowa. Ass a result, suit was filed in the Southern District of New > York. > > 17. The District Court ruled and the Second Circuit affirmed that Best > Van Lines must sue in Iowa, where the Walker website is located. By > analogy, this is similar to a case of a small-town in newspaper in > Iowa that has a few readers in New York. > > 18. However, the case presented here is different for a number of > reasons. One is that the defamatory postings were not made on a simple > website. They were broadcast and propagated all around the world in > every country of the world. In the Best Van Lines case, if the > computer hosting the Walker website were to crash, nobody in the > entire world would be able to see it any more. However, in the case > presented here, if one computer or even one hundred computers crash, > the Truong postings will still be visible in many other places. > Indeed, when Truong was apprehended, he stayed up all night in Mexico > City where he was at the time trying to delete as many of these > postings as he possibly could. He was able to delete many of them from > Google Newsgroups, because that is where he had first posted them, but > he still has not been able to delete them from Forte Inc. Agent, from > Giganews.com or from the many other services that carry these > newsgroups. > > 19. William Brock in his motion to dismiss states that his postings > which in general stated that I am a child molester were all posted > from his CPA Office in the Chicago Loop. However, the location of his > personal computer is of little moment. What is important is where he > posted them. Not only did he post them on the Usenet groups around the > world, but he posted them on such places as the New York Times website > which is obviously located in New York State. > > 20. An example of Brock's postings on the New York Times website is > at: > > http://gambit.blogs.nytimes.com/2007/10/08/the-lawsuit-against-polgar... > > 21. There, you will see numerous postings by William Brock on the New > York Times website where he provides links to places where, he claims, > one can find proof that I am a child molester and a child > pornographer. Mr. Brock is obviously a sick, disturbed man. Clearly, > Mr. Brock cannot now claim that the New York courts have no > jurisdiction over this. > > 22. Best Van Lines, Inc. v. Walker, 490 F.3d 239, 250-51 (2d Cir. > 2007) involved a moving company in New York complaining about a > website in Iowa. However, in the case before this court, ... > > read more =BB
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Date: 07 Feb 2008 13:31:02
From: Rob
Subject: Re: Why deal?
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On Feb 7, 1:32=A0pm, Mike Murray <[email protected] > wrote: > On Wed, 6 Feb 2008 21:35:33 -0800 (PST), Rob <[email protected]> > wrote: > > >I read somewhere in a newsgroup post that some member of the board was > >trying to settle this behind closed doors with Sloan. Or something > >like that. ... If you could kindly bring me up to speed with the > >FACTs of what has gone on over the last two months sansthew > >speculation from other parties, I would be most appreciative. > > If I *knew* all the facts, I'd also be appreciative. :-) > > Gregory Alexander made some claims recently that Donna Alarie was in > covert cahoots with Sam. =A0She challenged Gregory on this claim, and > the consensus seems to be that his attempts at substantiation have > been weak. =A0The fact that one listens to Sloan and occasionally talks > to him doesn't demonstrate an alliance. =A0She's not on the USCF board, > of course, but is an active state representative, AFAIK. =A0This could > be what you're referencing. > > It wouldn't surprise me if some board members (or their surrogate) had > been in contact with RSS, asking what it would take to make this thing > go away. =A0 But I don't recall seeing anything concrete. From what I > understand, offers and suggestions made in this sort of negotiation > can remain privileged and confidential, and can't be used in > subsequent court proceedings, but, not being a lawyer, I might be > wrong on this. > > Since all the key players, even those technically just USCF members > currently, seem to know each other and have long histories of > interaction, it would be easy to claim that anything initiated by damn > near anybody could be a trial balloon by the board. =A0Dunno. > > A lot of strange anonymouse claims are popping up -- your guess is as > good as mine as to what they mean. > > > > > I thinkfor the most part you tend to be openminded and rather neutral in= this > >stuff. Thanks, > >Rob- > Thanks Mike! I would have responded sooner back to your post. The weather here has distracted us all. I think all of us wish we knew all of the facts. I think it's time for a full and open disclosure by all parties on everything. I am not a poker player but it seems to me from what I have observed is the person who is holding the best hand is willing to show all of their cards first. Didn't Paul and Susan offer fully disclose everything if the opposing side did or was it the other way around? I really don't know. I will also confess a personal bias as I know Paul and Susan on a personal level. I would naturally tend to believe them before I would someone like Sloan. In the mean time, by Sloans ability to act as perpetual gadfly to the USCF, it ahs become mired in legal suits. The appearance is that his ego is more important than an entire organization dedicated to promoting a game he claims to love. Well, I have gone on about nothing that will change anything long enough. Thanks for responding in your usual level- headed way. :-) Best Wishes, Rob
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Date: 07 Feb 2008 14:51:26
From: Mike Murray
Subject: Re: Why deal?
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On Thu, 7 Feb 2008 13:31:02 -0800 (PST), Rob <[email protected] > wrote: > I am not a poker player but it seems to me from what I >have observed is the person who is holding the best hand is willing to >show all of their cards first. If you have a winning hand, you don't advertise it. You want to suck the other guy(s) in. Sometimes you bluff but mostly for "advertising". After all the cards are dealt and all the bets are in, it doesn't make any difference who shows first. >Didn't Paul and Susan offer fully >disclose everything if the opposing side did or was it the other way >around? AFAIK, they offered to mutually make public all the existing USCF correspondence and internal documentation associated with the case, but did not offer to comply with the USCF attorney's request to open up PT's ISP records, and for PT to make a legally binding denial of being the FSS. My opinion is that their openness gambit is a promotional distraction. > I really don't know. I will also confess a personal bias as I >know Paul and Susan on a personal level. I would naturally tend to >believe them before I would someone like Sloan. It's always hard to believe someone with whom you've had cordial and correct relations may have a dark side. But, most of us have been unpleasantly surprised more than once by this sort of thing. A fellow I worked with for several years once spontaneously blurted out to me, "You know,Murray, you can't tell about some people. I look like a mild-mannered guy, but sometimes I just go home and beat hell out of my wife." It's really not a question of believing Sam Sloan. Yes, he filed suit, so they have to respond to him. And his suit, again IMO, contains all sorts of ancillary issues only tenuously related to the FSS. The key "deliverables" are the Mottershead Report and the evaluation of that report by two experts. Assuming the underlying data matches PT's ISP records, the only alternative to believing PT is the FSS seems to be a far-fetched multi-year hacking scheme. IMO, the FSS is an online bully and deliberately chose to impersonate (mostly) Sloan and Parker because (1) of the relatively poor opinion most posters had of these two folks, (2) their history of unsuccessful pro se litigation seemed to indicate there was no real danger in antagonizing either or both, (3) neither appeared to have the technical skills or financial resources to seriously threaten "unmasking" him. (I have a fourth reason, but it's too speculative to mention, more along the lines of Innes' stylistic analysis) The FSS used these impersonations to beat on a wide variety of chess personalities and to promote or denigrate a wide variety of issues. Again, as time passed, the FSS became more and more convinced of his invulnerability and this led to the carelessness that Mottershead pounced upon. Since Mottershead, the anonymouse posts have gone through remailers, something the FSS never bothered with earlier. >In the mean time, by Sloans ability to act as perpetual gadfly to the >USCF, it ahs become mired in legal suits. The appearance is that his >ego is more important than an entire organization dedicated to >promoting a game he claims to love. Sloan likes the limelight, no question about it. But he's been around chess for over fifty years and really loves the game, IMO. I keep asking myself, would *anything* have happened if Sam had *not* filed suit? Dunno. >Well, I have gone on about nothing that will change anything long >enough. Thanks for responding in your usual level- headed way. :-) >Best Wishes, >Rob
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Date: 06 Feb 2008 21:35:33
From: Rob
Subject: Re: Why deal?
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On Feb 6, 12:24 pm, Mike Murray <[email protected] > wrote: > On Tue, 5 Feb 2008 20:18:37 -0800 (PST), Rob <[email protected]> > wrote: > > >Mike, > >I have been away for a while but little seems to have changed. The > >same groups attack another group without shame with any hint of > >suggestive impropriety being presented. I may need for you to get me > >up to speed on what these "secret meetings" with Sloan are about ect. > >Thanks Rob > > Secret meetings with Sloan? Not ringing a bell. Can you be more > specific? I read somewhere in a newsgroup post that some member of the board was trying to settle this behind closed doors with Sloan. Or something like that. It amazes me how reading the news groups gives on an impression that USCF stands for the Useless Sloan Chess Federation.Anyway, If you could kindly bring me up to speed with the FACTs of what has gone on over the last two months sansthew speculation from other parties, I would be most appreciative. I think for the most part you tend to be openminded and rather neutral in this stuff. Thanks, Rob
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Date: 07 Feb 2008 11:32:46
From: Mike Murray
Subject: Re: Why deal?
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On Wed, 6 Feb 2008 21:35:33 -0800 (PST), Rob <[email protected] > wrote: >I read somewhere in a newsgroup post that some member of the board was >trying to settle this behind closed doors with Sloan. Or something >like that. ... If you could kindly bring me up to speed with the >FACTs of what has gone on over the last two months sansthew >speculation from other parties, I would be most appreciative. If I *knew* all the facts, I'd also be appreciative. :-) Gregory Alexander made some claims recently that Donna Alarie was in covert cahoots with Sam. She challenged Gregory on this claim, and the consensus seems to be that his attempts at substantiation have been weak. The fact that one listens to Sloan and occasionally talks to him doesn't demonstrate an alliance. She's not on the USCF board, of course, but is an active state representative, AFAIK. This could be what you're referencing. It wouldn't surprise me if some board members (or their surrogate) had been in contact with RSS, asking what it would take to make this thing go away. But I don't recall seeing anything concrete. From what I understand, offers and suggestions made in this sort of negotiation can remain privileged and confidential, and can't be used in subsequent court proceedings, but, not being a lawyer, I might be wrong on this. Since all the key players, even those technically just USCF members currently, seem to know each other and have long histories of interaction, it would be easy to claim that anything initiated by damn near anybody could be a trial balloon by the board. Dunno. A lot of strange anonymouse claims are popping up -- your guess is as good as mine as to what they mean. > I thinkfor the most part you tend to be openminded and rather neutral in this >stuff. Thanks, >Rob
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Date: 05 Feb 2008 20:18:37
From: Rob
Subject: Why deal?
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On Feb 5, 3:28 pm, Mike Murray <[email protected] > wrote: > On Tue, 5 Feb 2008 13:04:07 -0800 (PST), > "[email protected]" <[email protected]> > wrote: > > >I think that he will listen to legal advice, and that the lawyers will > >tell him that the case against him for perjury given the evidence > >collected would be very hard to defend, while the admission that he > >made the posts simply to make fun of Sloan, which (he will contend) > >might be viewed as impolite but is not a crime, especially given > >Sloan's general reputation and attacks he can cite; and that this > >charge can be beaten. Of course, his preference would be to get the > >case dismissed, which still seems like a definite possibility. > > The FSS has been an umbrella term for a wide variety of > impersonations. Some problems with your analysis: > > First, it's hard to admit being the FSS only to make fun of the RSS, > without getting caught up in the many FSS posts which used the RSS > (and Parker) as a club to attack other chess personalities. > > Second, some of the FSS posts involved threats of harm to persons > widely regarded as unstable. > > Third, some of the posts involved outright slander, for example, where > the FSS suggested Bognar's company might be involved in credit card > fraud. > > Fourth, some important aspects of PT's career involve scholastic chess > and academic programs, where the number of obscene, misogynistic and > racist posts made under a variety of assumed identities might be the > kiss of death. > > Fifth, others may be waiting for the RSS's suit to reveal something > juicy before initiating their own legal actions. > > Of course, none of these lessens the consequences of perjury, but they > do suggest cutting a deal with the RSS many not end the tribulations. Mike, I have been away for a while but little seems to have changed. The same groups attack another group without shame with any hint of suggestive impropriety being presented. I may need for you to get me up to speed on what these "secret meetings" with Sloan are about ect. Thanks Rob
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Date: 06 Feb 2008 10:24:10
From: Mike Murray
Subject: Re: Why deal?
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On Tue, 5 Feb 2008 20:18:37 -0800 (PST), Rob <[email protected] > wrote: >Mike, >I have been away for a while but little seems to have changed. The >same groups attack another group without shame with any hint of >suggestive impropriety being presented. I may need for you to get me >up to speed on what these "secret meetings" with Sloan are about ect. >Thanks Rob Secret meetings with Sloan? Not ringing a bell. Can you be more specific?
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Date: 05 Feb 2008 13:04:07
From: [email protected]
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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On Feb 5, 2:37=A0pm, The Historian <[email protected] > wrote: > On Feb 5, 3:31 pm, "[email protected]" > > <[email protected]> wrote: > > As for advice on this, drop all the silly charges and stick to the one > > that matters. You have been impersonated by (you believe and can show > > evidence supporting your charge) Paul Truong. The USCF, Bill Brock, > > etc had nothing to do with it. > > > You have the potential to make this an interesting case. So much of > > your life has been spent creating an on-line identity that you can > > make a much better case that this caused harm to you than most people > > could. > > Hmm, I'd never considered that aspect of the case. So it's not so much > Sam Sloan's good name he is defending, but the name, good or bad, he's > created for himself. > > Lay off the assertions of your huge importance in the non- > > > virtual world, to USCF elections and such; these can be countered by > > showing your low vote totals. Above all, drop the Jack Anderson claim; > > this smells of megalomania. > > > I am not a lawyer, but it looks like you have turned a pretty clear > > specific complaint into something that will be dismissed as being a > > fishing expedition, much too vague to press charges on. > > > It is important to keep this in play until Truong is forced to testify > > under oath; don't blow your chance! > > > Jerry Spinrad > > Jerry, what leads you to believe Truong will tell the truth under > oath? I think that he will listen to legal advice, and that the lawyers will tell him that the case against him for perjury given the evidence collected would be very hard to defend, while the admission that he made the posts simply to make fun of Sloan, which (he will contend) might be viewed as impolite but is not a crime, especially given Sloan's general reputation and attacks he can cite; and that this charge can be beaten. Of course, his preference would be to get the case dismissed, which still seems like a definite possibility. Jerry Spinrad
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Date: 05 Feb 2008 13:28:44
From: Mike Murray
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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On Tue, 5 Feb 2008 13:04:07 -0800 (PST), "[email protected]" <[email protected] > wrote: >I think that he will listen to legal advice, and that the lawyers will >tell him that the case against him for perjury given the evidence >collected would be very hard to defend, while the admission that he >made the posts simply to make fun of Sloan, which (he will contend) >might be viewed as impolite but is not a crime, especially given >Sloan's general reputation and attacks he can cite; and that this >charge can be beaten. Of course, his preference would be to get the >case dismissed, which still seems like a definite possibility. The FSS has been an umbrella term for a wide variety of impersonations. Some problems with your analysis: First, it's hard to admit being the FSS only to make fun of the RSS, without getting caught up in the many FSS posts which used the RSS (and Parker) as a club to attack other chess personalities. Second, some of the FSS posts involved threats of harm to persons widely regarded as unstable. Third, some of the posts involved outright slander, for example, where the FSS suggested Bognar's company might be involved in credit card fraud. Fourth, some important aspects of PT's career involve scholastic chess and academic programs, where the number of obscene, misogynistic and racist posts made under a variety of assumed identities might be the kiss of death. Fifth, others may be waiting for the RSS's suit to reveal something juicy before initiating their own legal actions. Of course, none of these lessens the consequences of perjury, but they do suggest cutting a deal with the RSS many not end the tribulations.
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Date: 05 Feb 2008 23:18:04
From: Ray Gordon, creator of the \pivot\
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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> Fifth, others may be waiting for the RSS's suit to reveal something > juicy before initiating their own legal actions. Old saying on Wall Street: the second mouse gets the cheese. -- Ray Gordon, The ORIGINAL Lifestyle Seduction Guru http://www.cybersheet.com/library.html Includes 29 Reasons Not To Be A Nice Guy Ray's new "Project 5000" is here: http://groups.yahoo.com/group/project-5000 Don't rely on overexposed, mass-keted commercial seduction methods which no longer work. Thinking of taking a seduction "workshiop?" Read THIS: http://www.dirtyscottsdale.com/?p=1187 Beware! VH-1's "The Pickup Artst" was FRAUDULENT. Six of the eight contestants were actors, and they used PAID TARGETS in the club. The paid targets got mad when VH-1 said "there are no actors in this club" and ruined their prromised acting credit. What else has Mystery lied about?
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Date: 05 Feb 2008 12:37:53
From: The Historian
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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On Feb 5, 3:31 pm, "[email protected]" <[email protected] > wrote: > As for advice on this, drop all the silly charges and stick to the one > that matters. You have been impersonated by (you believe and can show > evidence supporting your charge) Paul Truong. The USCF, Bill Brock, > etc had nothing to do with it. > > You have the potential to make this an interesting case. So much of > your life has been spent creating an on-line identity that you can > make a much better case that this caused harm to you than most people > could. Hmm, I'd never considered that aspect of the case. So it's not so much Sam Sloan's good name he is defending, but the name, good or bad, he's created for himself. Lay off the assertions of your huge importance in the non- > virtual world, to USCF elections and such; these can be countered by > showing your low vote totals. Above all, drop the Jack Anderson claim; > this smells of megalomania. > > I am not a lawyer, but it looks like you have turned a pretty clear > specific complaint into something that will be dismissed as being a > fishing expedition, much too vague to press charges on. > > It is important to keep this in play until Truong is forced to testify > under oath; don't blow your chance! > > Jerry Spinrad Jerry, what leads you to believe Truong will tell the truth under oath?
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Date: 07 Feb 2008 19:36:37
From: The Historian
Subject: Re: Why deal?
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On Feb 7, 5:51 pm, Mike Murray <[email protected] > wrote: > On Thu, 7 Feb 2008 13:31:02 -0800 (PST), Rob <[email protected]> > wrote: > > > I am not a poker player but it seems to me from what I > >have observed is the person who is holding the best hand is willing to > >show all of their cards first. > > If you have a winning hand, you don't advertise it. You want to suck > the other guy(s) in. Sometimes you bluff but mostly for > "advertising". After all the cards are dealt and all the bets are in, > it doesn't make any difference who shows first. > > >Didn't Paul and Susan offer fully > >disclose everything if the opposing side did or was it the other way > >around? > > AFAIK, they offered to mutually make public all the existing USCF > correspondence and internal documentation associated with the case, > but did not offer to comply with the USCF attorney's request to open > up PT's ISP records, and for PT to make a legally binding denial of > being the FSS. My opinion is that their openness gambit is a > promotional distraction. > > > I really don't know. I will also confess a personal bias as I > >know Paul and Susan on a personal level. I would naturally tend to > >believe them before I would someone like Sloan. > > It's always hard to believe someone with whom you've had cordial and > correct relations may have a dark side. But, most of us have been > unpleasantly surprised more than once by this sort of thing. A fellow > I worked with for several years once spontaneously blurted out to me, > "You know,Murray, you can't tell about some people. I look like a > mild-mannered guy, but sometimes I just go home and beat hell out of > my wife." > > It's really not a question of believing Sam Sloan. Yes, he filed > suit, so they have to respond to him. And his suit, again IMO, > contains all sorts of ancillary issues only tenuously related to the > FSS. The key "deliverables" are the Mottershead Report and the > evaluation of that report by two experts. Assuming the underlying > data matches PT's ISP records, the only alternative to believing PT is > the FSS seems to be a far-fetched multi-year hacking scheme. > > IMO, the FSS is an online bully and deliberately chose to impersonate > (mostly) Sloan and Parker because (1) of the relatively poor opinion > most posters had of these two folks, (2) their history of > unsuccessful pro se litigation seemed to indicate there was no real > danger in antagonizing either or both, (3) neither appeared to have > the technical skills or financial resources to seriously threaten > "unmasking" him. (I have a fourth reason, but it's too speculative to > mention, more along the lines of Innes' stylistic analysis) Would it be that both Parker and Sloan were the two posters who most prominently criticized Susan Polgar? The FSS > used these impersonations to beat on a wide variety of chess > personalities and to promote or denigrate a wide variety of issues. > > Again, as time passed, the FSS became more and more convinced of his > invulnerability and this led to the carelessness that Mottershead > pounced upon. Since Mottershead, the anonymouse posts have gone > through remailers, something the FSS never bothered with earlier. > > >In the mean time, by Sloans ability to act as perpetual gadfly to the > >USCF, it ahs become mired in legal suits. The appearance is that his > >ego is more important than an entire organization dedicated to > >promoting a game he claims to love. > > Sloan likes the limelight, no question about it. But he's been around > chess for over fifty years and really loves the game, IMO. I keep > asking myself, would *anything* have happened if Sam had *not* filed > suit? Dunno. > > >Well, I have gone on about nothing that will change anything long > >enough. Thanks for responding in your usual level- headed way. :-) > >Best Wishes, > >Rob
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Date: 10 Feb 2008 14:43:38
From: Ray Gordon, creator of the \pivot\
Subject: Re: Why deal?
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> Would it be that both <ray> and Sloan were the two posters who most > prominently criticized <snip>? Not initially. The timing in my case suggests that my concerns about the chess life hiring were the trigger. The 9/19 post was made days after I chose not to sue and they thought they were in the clear. When one wants to flush out an anonymous attacker, however, the best way to do it is to test their claims of objectivity. Often when they can't admit why they're so passionate about something, they overstep, cross lines, and well, you know the rest. -- Ray Gordon, The ORIGINAL Lifestyle Seduction Guru http://www.cybersheet.com/library.html Includes 29 Reasons Not To Be A Nice Guy Ray's new "Project 5000" is here: http://groups.yahoo.com/group/project-5000 Don't rely on overexposed, mass-keted commercial seduction methods which no longer work. Thinking of taking a seduction "workshiop?" Read THIS: http://www.dirtyscottsdale.com/?p=1187 Beware! VH-1's "The Pickup Artst" was FRAUDULENT. Six of the eight contestants were actors, and they used PAID TARGETS in the club. The paid targets got mad when VH-1 said "there are no actors in this club" and ruined their prromised acting credit. What else has Mystery lied about?
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Date: 07 Feb 2008 21:21:19
From: Mike Murray
Subject: Re: Why deal?
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On Thu, 7 Feb 2008 19:36:37 -0800 (PST), The Historian <[email protected] > wrote: >> (I have a fourth reason, but it's too speculative to >> mention, more along the lines of Innes' stylistic analysis) >Would it be that both Parker and Sloan were the two posters who most >prominently criticized Susan Polgar? Something like that.. Both said stuff that was over the top and out of line, IMO. If PT had come in as himself (or as an anonymouse) and verbally flogged 'em, I doubt anybody would have done other but nod approval.
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Date: 10 Feb 2008 14:44:38
From: Ray Gordon, creator of the \pivot\
Subject: Re: Why deal?
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> Something like that.. Both said stuff that was over the top and out > of line, IMO. You mean that Susan Polgar is a dumb cunt who can't choose men? -- Ray Gordon, The ORIGINAL Lifestyle Seduction Guru http://www.cybersheet.com/library.html Includes 29 Reasons Not To Be A Nice Guy Ray's new "Project 5000" is here: http://groups.yahoo.com/group/project-5000 Don't rely on overexposed, mass-keted commercial seduction methods which no longer work. Thinking of taking a seduction "workshiop?" Read THIS: http://www.dirtyscottsdale.com/?p=1187 Beware! VH-1's "The Pickup Artst" was FRAUDULENT. Six of the eight contestants were actors, and they used PAID TARGETS in the club. The paid targets got mad when VH-1 said "there are no actors in this club" and ruined their prromised acting credit. What else has Mystery lied about?
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Date: 08 Feb 2008 21:40:22
From: an anonymouse
Subject: Re: Why deal?
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Mike Murray wrote: > On Thu, 7 Feb 2008 19:36:37 -0800 (PST), The Historian > <[email protected]> wrote: > > >> (I have a fourth reason, but it's too speculative to > >> mention, more along the lines of Innes' stylistic analysis) > > >Would it be that both Parker and Sloan were the two posters who most > >prominently criticized Susan Polgar? > > Something like that.. Both said stuff that was over the top and out > of line, IMO. If PT had come in as himself (or as an anonymouse) and > verbally flogged 'em, I doubt anybody would have done other but nod > approval. A fair appraisal. So, does PT deserve crucifixion because of a momentary lapse of judgement, a few unwise words uttered twice? PT got into a bad habit, that is all there is to it, and pursued things with his youthful zest and vigor that makes him so refreshing an asset in other spheres. This whole thing should not become a meal ticket for life for Sam. Not even a soup kitchen for him. If even a wooden USCF nickel is paid over to Sam, I'd consider it a travesty. Bye-bye from me to the USCF as far as my future membership and dues are concerned. I have no hard feelings at all against Sam, but it is just that I can't see what the blazes this has to do with the USCF, other officers, Bill B. and so on. PT and Sam, that is all it should have been. All the conspiracy chatter is hooey. I appeal to the better side of Sam, to set aside these petty matters, to see the bigger picture, to play the elder statesman, to display his good heart, to secure his place in history, to forgive his transgressor, to move on and upwards. I apologize for the dirty speculations of my anony-brethren. They make me ashamed. This whole scandal cross-posted by the usual suspect into the privacy or anony-posting newsgroups is responsible for some or most of the anonymice. Eventually, having no interest in chess, they will get bored teasing cus and probing Brian, find something better to do and vanish. Please, Sam, stop the cross-posting vandalism. Thanks. Sam, if you are one of the anonymice, or know the answer, tell me how I can switch this No-Archive switch to off. Thanks again. [an anonymouse]
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Date: 11 Feb 2008 01:27:01
From: help bot
Subject: Re: Why deal?
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On Feb 11, 2:50 am, "[email protected]" <[email protected] > wrote: > > After I sued them, they made some subtle changes in their retention and > > search policies, that better protect authors' rights. I don't know if it > > was my suit or a general concern, but the policy did change. > > So, would you care to state what these "subtle changes" actually were ? > > Or is this *yet another* case of you making claims without evidence ? Um, Earth to moron: a lawsuit is a matter of public record; he needn't provide any "evidence" since any dufus who wants to can research the matter for himself. It's a bit like my relating of what former world champ Tigran Petrosian has written; along came some doubting-Thomases, who at first insisted that TP had not written what I said, on account of them not liking me; this later transmogrified into them insisting that I needed to name the book or article, and finally, to a demand for page numbers and extensive quotations. Logic dictates that no matter how many of these "steps" I might take, the matter would remain in doubt to those who are quite ignorant of chess history, so what was in fact required was a spot of research on their part, to set things straight in their puny minds. But don't let this guy intimidate you; he has never argued successfully before the Supreme Court. Just kick back and watch how the pros do it-- watch lawyer Sam Sloan, not Flash Gordon. -- help bot
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Date: 10 Feb 2008 11:50:33
From: samsloan
Subject: Re: Why deal?
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Path: g2news1.google.com!news3.google.com!proxad.net! feeder1-2.proxad.net!feeder.erje.net!news.exosphere.de! news2.arglkargh.de!news.dizum.com!sewer-output!mail2news-x2!mail2news Subject: Re: Why deal? Newsgroups: rec.games.chess.politics,rec.games.chess.misc From: an anonymouse <[email protected] > X-No-Archive: yes References: <[email protected] > Message-ID: <[email protected] > Date: Fri, 8 Feb 2008 21:40:22 +0000 (UTC) Mail-To-News-Contact: [email protected] Organization: [email protected] On Feb 8, 4:40 pm, an anonymouse <[email protected] > wrote: > Mike Murray wrote: > > On Thu, 7 Feb 2008 19:36:37 -0800 (PST), The Historian > > <[email protected]> wrote: > > > >> (I have a fourth reason, but it's too speculative to > > >> mention, more along the lines of Innes' stylistic analysis) > > > >Would it be that both Parker and Sloan were the two posters who most > > >prominently criticized Susan Polgar? > > > Something like that.. Both said stuff that was over the top and out > > of line, IMO. If PT had come in as himself (or as an anonymouse) and > > verbally flogged 'em, I doubt anybody would have done other but nod > > approval. > > A fair appraisal. So, does PT deserve crucifixion because of a momentary > lapse of judgement, a few unwise words uttered twice? PT got into a bad > habit, that is all there is to it, and pursued things with his youthful > zest and vigor that makes him so refreshing an asset in other spheres. > > This whole thing should not become a meal ticket for life for Sam. Not > even a soup kitchen for him. If even a wooden USCF nickel is paid over > to Sam, I'd consider it a travesty. Bye-bye from me to the USCF as far > as my future membership and dues are concerned. I have no hard feelings > at all against Sam, but it is just that I can't see what the blazes this > has to do with the USCF, other officers, Bill B. and so on. PT and Sam, > that is all it should have been. All the conspiracy chatter is hooey. > > I appeal to the better side of Sam, to set aside these petty matters, to > see the bigger picture, to play the elder statesman, to display his good > heart, to secure his place in history, to forgive his transgressor, to > move on and upwards. > > I apologize for the dirty speculations of my anony-brethren. They make > me ashamed. This whole scandal cross-posted by the usual suspect into > the privacy or anony-posting newsgroups is responsible for some or most > of the anonymice. Eventually, having no interest in chess, they will > get bored teasing cus and probing Brian, find something better to do > and vanish. Please, Sam, stop the cross-posting vandalism. Thanks. > > Sam, if you are one of the anonymice, or know the answer, tell me how I > can switch this No-Archive switch to off. Thanks again. > > [an anonymouse] This response is just to preserve this posting, that will otherwise be deleted in 5 days.
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Date: 11 Feb 2008 00:11:27
From: Guy Macon
Subject: Re: Why deal?
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samsloan wrote: >This response is just to preserve this posting, that will >otherwise be deleted in 5 days. Nope. It will stay on various NNTP servers for years or longer. Once again you are confusing Google Groups -- a commercial website that downloads material from Usenet, inserts advertisements, and then pretends that it is original content -- with the actual Usenet that Google Groups parasitises. -- Guy Macon <http://www.guymacon.com/ >
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Date: 10 Feb 2008 18:02:54
From: Mike Murray
Subject: Re: Why deal?
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On Mon, 11 Feb 2008 00:11:27 +0000, Guy Macon <http://www.guymacon.com/ > wrote: > > > >samsloan wrote: > >>This response is just to preserve this posting, that will >>otherwise be deleted in 5 days. > >Nope. It will stay on various NNTP servers for years or longer. > >Once again you are confusing Google Groups -- a commercial website >that downloads material from Usenet, inserts advertisements, and >then pretends that it is original content -- with the actual Usenet >that Google Groups parasitises. And if a person compounds that by confusing Google with a real newsreader.... it gets ugly real fast.
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Date: 11 Feb 2008 01:49:15
From: Ray Gordon, creator of the \pivot\
Subject: Re: Why deal?
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> > And if a person compounds that by confusing Google with a real > newsreader.... it gets ugly real fast. Google operates a web-based USENET server and a separate USENET archive. After I sued them, they made some subtle changes in their retention and search policies, that better protect authors' rights. I don't know if it was my suit or a general concern, but the policy did change. -- Ray Gordon, The ORIGINAL Lifestyle Seduction Guru http://www.cybersheet.com/library.html Includes 29 Reasons Not To Be A Nice Guy Ray's new "Project 5000" is here: http://groups.yahoo.com/group/project-5000 Don't rely on overexposed, mass-keted commercial seduction methods which no longer work. Thinking of taking a seduction "workshiop?" Read THIS: http://www.dirtyscottsdale.com/?p=1187 Beware! VH-1's "The Pickup Artst" was FRAUDULENT. Six of the eight contestants were actors, and they used PAID TARGETS in the club. The paid targets got mad when VH-1 said "there are no actors in this club" and ruined their prromised acting credit. What else has Mystery lied about?
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"Ray Gordon" wrote: >> And if a person compounds that by confusing Google with a real >> newsreader.... it gets ugly real fast. > > Google operates a web-based USENET server and a separate USENET archive. > > After I sued them, they made some subtle changes in their retention and > search policies, that better protect authors' rights. I don't know if it > was my suit or a general concern, but the policy did change. So, would you care to state what these "subtle changes" actually were ? Or is this *yet another* case of you making claims without evidence ?
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Date: 10 Feb 2008 14:45:45
From: Ray Gordon, creator of the \pivot\
Subject: Re: Why deal?
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>I can't see what the blazes this > has to do with the USCF, other officers, Bill B. and so on. Be patient. -- Ray Gordon, The ORIGINAL Lifestyle Seduction Guru http://www.cybersheet.com/library.html Includes 29 Reasons Not To Be A Nice Guy Ray's new "Project 5000" is here: http://groups.yahoo.com/group/project-5000 Don't rely on overexposed, mass-keted commercial seduction methods which no longer work. Thinking of taking a seduction "workshiop?" Read THIS: http://www.dirtyscottsdale.com/?p=1187 Beware! VH-1's "The Pickup Artst" was FRAUDULENT. Six of the eight contestants were actors, and they used PAID TARGETS in the club. The paid targets got mad when VH-1 said "there are no actors in this club" and ruined their prromised acting credit. What else has Mystery lied about?
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Date: 09 Feb 2008 09:27:47
From: The Historian
Subject: Re: Why deal?
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On Feb 9, 10:17 am, Mike Murray <[email protected] > wrote: > >I appeal to the better side of Sam, to set aside these petty matters, to > >see the bigger picture, to play the elder statesman, to display his good > >heart, to secure his place in history, to forgive his transgressor, to > >move on and upwards. > > This sort of happy-ending-with-lessons-learned scenario usually > involves the transgressor TAKING RESPONSIBILITY FOR HIS ACTIONS. Do > you envision this as part of the script ? He's an anonymouse, Mike. He can't even take responsibility for his own posting.
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Date: 09 Feb 2008 12:03:30
From: Mike Murray
Subject: Re: Why deal?
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On Sat, 9 Feb 2008 09:27:47 -0800 (PST), The Historian <[email protected] > wrote: >He's an anonymouse, Mike. He can't even take responsibility for his >own posting. I don't have a problem with someone posting anonymously. There may be professional or personal reasons, separate from the discussion topic, for not disclosing one's identity. I do think it helps continuity in discussion if the anonymouse adopts a consistent online handle.
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Date: 09 Feb 2008 07:17:00
From: Mike Murray
Subject: Re: Why deal?
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On Fri, 8 Feb 2008 21:40:22 +0000 (UTC), an anonymouse <[email protected] > wrote: >Mike Murray wrote: >> On Thu, 7 Feb 2008 19:36:37 -0800 (PST), The Historian >> <[email protected]> wrote: >> >Would it be that both Parker and Sloan were the two posters who most >> >prominently criticized Susan Polgar? >> Something like that.. Both said stuff that was over the top and out >> of line, IMO. If PT had come in as himself (or as an anonymouse) and >> verbally flogged 'em, I doubt anybody would have done other but nod >> approval. >A fair appraisal. So, does PT deserve crucifixion because of a momentary >lapse of judgement, a few unwise words uttered twice? PT got into a bad >habit, that is all there is to it, and pursued things with his youthful >zest and vigor that makes him so refreshing an asset in other spheres. Your two sentences above contradict each other. A bad habit pursued with zest and vigor does not equate to a "momentary lapse in judgment, a few unwise words uttered twice". The FSS made several thousand posts, many going far beyond retribution for caddish behavior against Ms Polgar. Falsely using the names of real people, the FSS (1) slandered folks who supported various USCF issues opposed by the FSS, (2) falsely associated with the RSS, folks who opposed the Board candidacies supported by the FSS, (3) attempted to manipulate the Board election of the USCF, a non-profit corporation, (4) physically threatened people. >...I can't see what the blazes this >has to do with the USCF, other officers, Bill B. and so on. PT and Sam, >that is all it should have been. All the conspiracy chatter is hooey. PT was part of slate of candidates, essentially attempting to take over the USCF, and, arguably, was the architect of this endeavor. The USCF is a multi-million dollar business with many employees. Seems like any mano-e-mano stuff between him and Sloan was relegated far into the background. The FSS attacked *all* the alternatives to this slate. The FSS attacked supporters of alternative candidates. >I appeal to the better side of Sam, to set aside these petty matters, to >see the bigger picture, to play the elder statesman, to display his good >heart, to secure his place in history, to forgive his transgressor, to >move on and upwards. This sort of happy-ending-with-lessons-learned scenario usually involves the transgressor TAKING RESPONSIBILITY FOR HIS ACTIONS. Do you envision this as part of the script ?
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Date: 04 Feb 2008 19:19:57
From: Ted E Bear
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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In the absence of a properly drafted "Amended Complaint", I predict that this case will be dismissed. The advantage of an Amended Complaint are many. First you can more carefully address the arguments raised in the various Motions to Dismiss and remove extraneous material from your pleading. Secondly, misjoinder of parties can be corrected. And most important, all the MTD are then MOOT. Ask Ray, he usually files an Amended Complaint when he finds out what the objections are. Sadly he only refiles more word salad with no substance, but he has IMHO, learned the age old tactic of the stall. Amateurs always paint with a broad brush and try and right the "wrongs" of the world. Professionals determine what laws have been broken, who broke them, what the precedents are, and keep their pleadings on point. They also don't sue people the Court does not have personal jurisdiction over. Perhaps you should that in mind and reread what you are proposing to file. If it looks frivolous, and sounds frivolous, it probably is a duck... Disclaimer, do not consider any of the above to be legal advice. It's a statement of my opinion only, protected by the First Amendment. You are free to ignore me, in fact it would be better if you did..... Thank you. Posted Via Usenet.com Premium Usenet Newsgroup Services ---------------------------------------------------------- ** SPEED ** RETENTION ** COMPLETION ** ANONYMITY ** ---------------------------------------------------------- http://www.usenet.com
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Date: 04 Feb 2008 15:09:49
From: Ray Gordon, creator of the \pivot\
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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On behalf of pro-ses everywhere, especially those who used to work at big law firms and had to prepare pleadings that held up in court, I thank you for carrying the flag in court as only you can. Your impact on pro-se cases eveywhere is simply beyond words, Samuel H. Sloan. -- Ray Gordon, The ORIGINAL Lifestyle Seduction Guru http://www.cybersheet.com/library.html Includes 29 Reasons Not To Be A Nice Guy Ray's new "Project 5000" is here: http://groups.yahoo.com/group/project-5000 Don't rely on overexposed, mass-keted commercial seduction methods which no longer work. Thinking of taking a seduction "workshiop?" Read THIS: http://www.dirtyscottsdale.com/?p=1187 Beware! VH-1's "The Pickup Artst" was FRAUDULENT. Six of the eight contestants were actors, and they used PAID TARGETS in the club. The paid targets got mad when VH-1 said "there are no actors in this club" and ruined their prromised acting credit. What else has Mystery lied about?
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Date: 04 Feb 2008 15:04:54
From: Jonathan Kamens
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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Sam, It appears that there are a lot of allegations in your proposed affidavit which have nothing to do with the defendants' motion to dismiss. I assume that you have already made these allegations in the filings in which you initiated the lawsuit. If you did, then you don't need to repeat them here, and if you didn't, then you need to amend your lawsuit, rather than including new allegations in this filing, because it's not the appropriate place for it. This filing should specifically respond to the defendants' reasoning in their motion to dismiss. Repeating and/or raising new allegations in a response to a motion to dismiss makes you look like a raving loony, which I doubt is the image you wish to project to the judge. IANAL, so take this advice for whatever you think it's worth. -- Help stop the genocide in Darfur! http://www.genocideintervention.net/
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Date: 06 Feb 2008 06:16:59
From: samsloan
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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On Feb 4, 10:49 am, samsloan <[email protected] > wrote: > On Feb 4, 10:33 am, [email protected] wrote: > > > > > On Feb 4, 9:30 am, samsloan <[email protected]> wrote: > > > > On Feb 4, 10:13 am, [email protected] wrote: > > > > > On Feb 4, 9:04 am, [email protected] (Jonathan Kamens) > > > > wrote: > > > > > > Sam, > > > > > [...] > > > > > > Repeating and/or raising new allegations in a response to a motion to > > > > > dismiss makes you look like a raving loony, which I doubt is the image > > > > > you wish to project to the judge. > > > > > [...] > > > > > Jonathan, > > > > > You're speaking to someone who's prevailed in the Supreme Court, one > > > > of the finest legal minds of our times. > > > > > I think Mr. Sloan should correct the spelling of the name of cus > > > > Roberts' future colleague (only one "s" in "Oberweis") and call it a > > > > day. > > > > Thank you, Bill Brock, for correcting the spelling error in my > > > affidavit against you. > > > > I shall also use your quote "one of the finest legal minds of our > > > times" on the back cover blurb of my next book. > > > > Sam Sloan > > > You have my permission: guess who'll be collecting the royalties on > > your next book? > > Seriously, my next book is really good. It has about 200 pictures in > it. > > http://www.amazon.com/dp/0923891900 > > However, as it is being printed right now, it is too late to quote > you. It only quotes the Boston Globe article about me on the back > cover blurb. > > Sam Sloan If you want to order this book, you had better order it right now because it is in the very final stages of production. Within no more than 2 or 3 days the book will be out and Amazon will raise the price, I believe. http://www.amazon.com/dp/0923891900 Sam Sloan
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Date: 04 Feb 2008 17:53:47
From: Guy Macon
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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Jonathan Kamens wrote: [SNIP] Jonathan, when Sam Slaon crossposts to... rec.games.chess.politics, misc.legal, rec.games.chess.misc, tx.politics, rec.games.chess.computer, alt.chess, soc.culture.usa ... please trim the newsgroups when you reply to whatever subset you determine the post to be on-topic in. Certainly this has nothing to do with Texas politics or computer chess, so you shouldn't be posting it to tx.politics or rec.games.chess.computer. -- Guy Macon <http://www.guymacon.com/ >
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Date: 04 Feb 2008 07:49:12
From: samsloan
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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On Feb 4, 10:33 am, [email protected] wrote: > On Feb 4, 9:30 am, samsloan <[email protected]> wrote: > > > > > On Feb 4, 10:13 am, [email protected] wrote: > > > > On Feb 4, 9:04 am, [email protected] (Jonathan Kamens) > > > wrote: > > > > > Sam, > > > > [...] > > > > > Repeating and/or raising new allegations in a response to a motion to > > > > dismiss makes you look like a raving loony, which I doubt is the image > > > > you wish to project to the judge. > > > > [...] > > > > Jonathan, > > > > You're speaking to someone who's prevailed in the Supreme Court, one > > > of the finest legal minds of our times. > > > > I think Mr. Sloan should correct the spelling of the name of cus > > > Roberts' future colleague (only one "s" in "Oberweis") and call it a > > > day. > > > Thank you, Bill Brock, for correcting the spelling error in my > > affidavit against you. > > > I shall also use your quote "one of the finest legal minds of our > > times" on the back cover blurb of my next book. > > > Sam Sloan > > You have my permission: guess who'll be collecting the royalties on > your next book? Seriously, my next book is really good. It has about 200 pictures in it. http://www.amazon.com/dp/0923891900 However, as it is being printed right now, it is too late to quote you. It only quotes the Boston Globe article about me on the back cover blurb. Sam Sloan
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Date: 04 Feb 2008 08:44:41
From: Mike Murray
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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On Mon, 4 Feb 2008 07:49:12 -0800 (PST), samsloan <[email protected] > wrote: >Seriously, my next book is really good. It has about 200 pictures in >it. > >http://www.amazon.com/dp/0923891900 How did you get Ms Exner to co-author ?
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Date: 04 Feb 2008 07:33:15
From:
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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On Feb 4, 9:30 am, samsloan <[email protected] > wrote: > On Feb 4, 10:13 am, [email protected] wrote: > > > > > On Feb 4, 9:04 am, [email protected] (Jonathan Kamens) > > wrote: > > > > Sam, > > > [...] > > > > Repeating and/or raising new allegations in a response to a motion to > > > dismiss makes you look like a raving loony, which I doubt is the image > > > you wish to project to the judge. > > > [...] > > > Jonathan, > > > You're speaking to someone who's prevailed in the Supreme Court, one > > of the finest legal minds of our times. > > > I think Mr. Sloan should correct the spelling of the name of cus > > Roberts' future colleague (only one "s" in "Oberweis") and call it a > > day. > > Thank you, Bill Brock, for correcting the spelling error in my > affidavit against you. > > I shall also use your quote "one of the finest legal minds of our > times" on the back cover blurb of my next book. > > Sam Sloan You have my permission: guess who'll be collecting the royalties on your next book?
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Date: 04 Feb 2008 07:30:59
From: samsloan
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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On Feb 4, 10:13 am, [email protected] wrote: > On Feb 4, 9:04 am, [email protected] (Jonathan Kamens) > wrote: > > > Sam, > > [...] > > > Repeating and/or raising new allegations in a response to a motion to > > dismiss makes you look like a raving loony, which I doubt is the image > > you wish to project to the judge. > > [...] > > Jonathan, > > You're speaking to someone who's prevailed in the Supreme Court, one > of the finest legal minds of our times. > > I think Mr. Sloan should correct the spelling of the name of cus > Roberts' future colleague (only one "s" in "Oberweis") and call it a > day. Thank you, Bill Brock, for correcting the spelling error in my affidavit against you. I shall also use your quote "one of the finest legal minds of our times" on the back cover blurb of my next book. Sam Sloan
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Date: 04 Feb 2008 07:13:50
From:
Subject: Re: First Draft - Affidavit in Opposition - Commernts Please
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On Feb 4, 9:04 am, [email protected] (Jonathan Kamens) wrote: > Sam, > [...] > > Repeating and/or raising new allegations in a response to a motion to > dismiss makes you look like a raving loony, which I doubt is the image > you wish to project to the judge. > [...] Jonathan, You're speaking to someone who's prevailed in the Supreme Court, one of the finest legal minds of our times. I think Mr. Sloan should correct the spelling of the name of cus Roberts' future colleague (only one "s" in "Oberweis") and call it a day.
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