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Date: 25 Sep 2008 16:12:51
From: samsloan
Subject: Goichberg Non-Diversity Affidavit
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Case 1:07-cv-08537-DC Document 16 Filed 01/04/2008
PROSKAUER ROSE LLP
Jeremy M. Brown, Esq. (JB-7652)
One Newark Center
Newark, New Jersey 07102-5211
Telephone: 973.274.3200
Facsimile: 973.274.3299
e-mail: [email protected]
Attorneys for Defendants The United States Chess Federation, Joel
Charming, William Goichberg, Bill Hall, Herbert Rodney Vaughn, Gregory
Alexander, Grant Perks, Randall Rough, Randy Bauer, Paul Truong Susan
Polgar and Jim Berry
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-------------------------------------------------x
SAM SLOAN,
Plaintiff, Civil Action No. 07-CV-8537 (DC)
vs.
HOAINHAN "PAUL" TRUONG, ZSUZSANNA AFFIDAVIT OF WILLIAM
"SUSAN" POLGAR, JOEL CHANNING, GOICHBERG
WILLIAM GOICHBERG, THE UNITED STATES
CHESS FEDERATION, BILL HALL, HERBERT
RODNEY VAUGHN, GREGORY ALEXANDER, Document Filed Electronically
FRANK NIRO, GRANT PERKS, WILLIAM
BROCK, RANDALL ROUGH, RANDY BAUER,
JIM BERRY, TEXAS TECH UNIVERSITY and
UNITED STATES OF AMERICA,
Defendants.
--------------------------------------------------x
WILLIAM GOICHBERG, being duly sworn, deposes and states:
1. I currently reside at 2084 Route 94, Salisbury Mills, New York
15277. This is my home, my domicile and my permanent place of
residence.
2. I have lived at and maintained my residence and home at 2084 Route
94, Salisbury Mills, New York 12577 since 1991.
3. I vote exclusively in the State of New York.
4. I pay taxes in the State of New York and not any other state.
5. I do not reside or maintain a residence, home or domicile anywhere
other than in the State of New York.
I declare under penalty of perjury that the foregoing is true and
correct.
William Goichberg
Sworn to and subscribed before me
this 19 day of November 2007
Yvonne D. Mosca
Commissioner of Deeds for the
City of Mount Vernon New York
https://ecf.nysd.uscourts.gov/doc1/12714288535
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Date: 25 Sep 2008 23:26:41
From: Wlodzimierz Holsztynski (Wlod)
Subject: Re: Goichberg Non-Diversity Affidavit
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On Sep 25, 5:42 pm, samsloan <[email protected] > wrote:
>
> The real issue is not whether there is a structure on the property or
> not. The issue is whether Goichberg can be found there on a regular
> basis. Is Goichberg a "citizen" of the place? Or, does he just visit
> there from time to time to check up on the property?
>
> This deed is the only document of any kind submitted to the court,
> other than Goichberg's affidavit above.
>
> [...]
>
> Another curious fact is that Proskauer Rose paid a check in the amount
> of $5 dated February 6, 2008 to the Orange County Clerk to order a
> copy of the deed. That check is in the PACER record. Why did not
> Goichberg supply a copy of the deed himself? Why did a $500 per hour
> high powered lawyer have to take the time to write a check for $5 to
> pay for a copy of the deed? Of course, we know part of the reason.
> This was because Goichberg was residing in California and rarely came
> to New York.
What about electricity bills & payment checks (or similar)?
Wlod
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Date: 25 Sep 2008 19:37:35
From:
Subject: Re: Goichberg Non-Diversity Affidavit
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samsloan wrote:
> However, the affidavit above plus the deed, without more, are clearly
> insufficient to establish that Goichberg is a "citizen" of New York
> State to the exclusion of any other state. The statement by the judge
> that Goichberg submitted "the deed to his house in Orange County, New
> York" is incorrect because this deed fails to make any mention of a
> house. Also, the "property tax records for his New York residence"
> must refer to the "New York State Transfer Tax" of $560 dated November
> 12, 1991 noted on the deed. This is not "property tax", and there are
> no other records in the file.
The judge didn't agree, and you don't get a vote.
> Another curious fact is that Proskauer Rose paid a check in the amount
> of $5 dated February 6, 2008 to the Orange County Clerk to order a
> copy of the deed. That check is in the PACER record. Why did not
> Goichberg supply a copy of the deed himself? Why did a $500 per hour
> high powered lawyer have to take the time to write a check for $5 to
> pay for a copy of the deed? Of course, we know part of the reason.
> This was because Goichberg was residing in California and rarely came
> to New York.
>
> Sam Sloan
Because a competent attorney doesn't file an affidavit without
verifying the facts. He has ethical duties and can be sanctioned. You,
having the ethics of syphilitic weasel and no assets, are not so
constrained.
You do realize that you just disproved your own claim, don't you?
Moron.
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Date: 25 Sep 2008 19:20:56
From: SBD
Subject: Re: Goichberg Non-Diversity Affidavit
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On Sep 25, 6:48=A0pm, Brian Lafferty <[email protected] > wrote:
> Who is Joel Charming?
Someday, his prince will come.
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Date: 25 Sep 2008 17:42:32
From: samsloan
Subject: Re: Goichberg Non-Diversity Affidavit
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On Sep 25, 7:23=A0pm, johnny_t <[email protected] > wrote:
> samsloan wrote:
>
> > 1. I currently reside at 2084 Route 94, Salisbury Mills, New York
> > 15277. This is my home, my domicile and my permanent place of
> > residence.
>
> Huh.
>
> I google this address, and it drops a pin right on the map. =A0But more
> importantly, when I do a satellite view of this adx it is a developed
> house.
>
> This seems entirely different than a "non-existent" address.
The address of 2084 Route 94 is a real estate lot number. This address
is not recognized by the United States Postal Service. Goichberg
himself told me that he has never received mail at that address.
Since this issue has come up, I have uploaded a copy of the deed filed
by Proskauer Rose on September 9, 2008. Here it is:
http://www.anusha.com/goichberg-deed.pdf
I find this to be the deed to an empty lot. Do you disagree? No street
address is provided.
The real issue is not whether there is a structure on the property or
not. The issue is whether Goichberg can be found there on a regular
basis. Is Goichberg a "citizen" of the place? Or, does he just visit
there from time to time to check up on the property?
This deed is the only document of any kind submitted to the court,
other than Goichberg's affidavit above.
The court, in its decision stated:
"Goichberg has submitted ample evidence to show that he is a "citizen"
of New York for the purposes of diversity jurisdiction, including: the
deed to his house in Orange County, New York; property tax records for
his New York residence; and affidavits attesting that he votes, pays
taxes, and resides exclusively in New York. (See Goichberg Aff. &
Suppl. Aff.)."
However, the affidavit above plus the deed, without more, are clearly
insufficient to establish that Goichberg is a "citizen" of New York
State to the exclusion of any other state. The statement by the judge
that Goichberg submitted "the deed to his house in Orange County, New
York" is incorrect because this deed fails to make any mention of a
house. Also, the "property tax records for his New York residence"
must refer to the "New York State Transfer Tax" of $560 dated November
12, 1991 noted on the deed. This is not "property tax", and there are
no other records in the file.
I am wondering what is going on here. It is difficult to imagine any
judge making such an egregiously wrong decision.
Another curious fact is that Proskauer Rose paid a check in the amount
of $5 dated February 6, 2008 to the Orange County Clerk to order a
copy of the deed. That check is in the PACER record. Why did not
Goichberg supply a copy of the deed himself? Why did a $500 per hour
high powered lawyer have to take the time to write a check for $5 to
pay for a copy of the deed? Of course, we know part of the reason.
This was because Goichberg was residing in California and rarely came
to New York.
Sam Sloan
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Date: 25 Sep 2008 23:48:10
From: Brian Lafferty
Subject: Re: Goichberg Non-Diversity Affidavit
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Who is Joel Charming?
samsloan wrote:
> Case 1:07-cv-08537-DC Document 16 Filed 01/04/2008
>
> PROSKAUER ROSE LLP
> Jeremy M. Brown, Esq. (JB-7652)
> One Newark Center
> Newark, New Jersey 07102-5211
> Telephone: 973.274.3200
> Facsimile: 973.274.3299
> e-mail: [email protected]
>
> Attorneys for Defendants The United States Chess Federation, Joel
> Charming, William Goichberg, Bill Hall, Herbert Rodney Vaughn, Gregory
> Alexander, Grant Perks, Randall Rough, Randy Bauer, Paul Truong Susan
> Polgar and Jim Berry
>
> UNITED STATES DISTRICT COURT
> SOUTHERN DISTRICT OF NEW YORK
>
> -------------------------------------------------x
>
> SAM SLOAN,
> Plaintiff, Civil Action No. 07-CV-8537 (DC)
> vs.
>
> HOAINHAN "PAUL" TRUONG, ZSUZSANNA AFFIDAVIT OF WILLIAM
> "SUSAN" POLGAR, JOEL CHANNING, GOICHBERG
> WILLIAM GOICHBERG, THE UNITED STATES
> CHESS FEDERATION, BILL HALL, HERBERT
> RODNEY VAUGHN, GREGORY ALEXANDER, Document Filed Electronically
> FRANK NIRO, GRANT PERKS, WILLIAM
> BROCK, RANDALL ROUGH, RANDY BAUER,
> JIM BERRY, TEXAS TECH UNIVERSITY and
> UNITED STATES OF AMERICA,
>
> Defendants.
> --------------------------------------------------x
>
> WILLIAM GOICHBERG, being duly sworn, deposes and states:
>
>
> 1. I currently reside at 2084 Route 94, Salisbury Mills, New York
> 15277. This is my home, my domicile and my permanent place of
> residence.
>
> 2. I have lived at and maintained my residence and home at 2084 Route
> 94, Salisbury Mills, New York 12577 since 1991.
>
> 3. I vote exclusively in the State of New York.
>
> 4. I pay taxes in the State of New York and not any other state.
>
> 5. I do not reside or maintain a residence, home or domicile anywhere
> other than in the State of New York.
>
> I declare under penalty of perjury that the foregoing is true and
> correct.
>
> William Goichberg
>
> Sworn to and subscribed before me
> this 19 day of November 2007
>
> Yvonne D. Mosca
> Commissioner of Deeds for the
> City of Mount Vernon New York
>
>
>
> https://ecf.nysd.uscourts.gov/doc1/12714288535
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Date: 25 Sep 2008 16:32:32
From: samsloan
Subject: Re: Goichberg Non-Diversity Affidavit
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> 1. =A0 =A0 =A0I currently reside at 2084 Route 94, Salisbury Mills, New
York
> 15277. This is my home, my domicile and my permanent place of
> residence.
Has anybody noticed that the Goichberg affidavit has the wrong zip
code?
This is, of course, because Goichberg does not know his own zip code.
Sam Sloan
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