Legal Threats from William Brock

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Date: 10 Nov 2007 06:05:56
From: samsloan
Subject: Legal Threats from William Brock

I have received a letter from a lawyer named Patrick O'Brien
<[email protected] > claiming to represent William Brock,
threatening to find a Rule 11 Motion for sanctions against me unless I
withdraw my suit against Mr. Brock.

I am utterly terrified. Which should I do?

It is to be recalled that Mr. Brock had repeatedly dared me to file a
lawsuit against him, while at the same time he was posting thousands
of articles to this forum accusing me of being a "child molester".
These articles have continued even after I filed this suit.

Sam Sloan

Date: 16 Nov 2007 13:11:19
From:
Subject: Re: Legal Threats from William Brock

On Nov 16, 2:37 pm, samsloan <[email protected] > wrote:
> On Nov 16, 3:27 pm, [email protected] wrote:
>
>
>
> > On Nov 16, 8:48 am, samsloan <[email protected]> wrote:
>
> > > Following Brock's online confession that he dreams of being a child
> > > molester, he has defaulted in the federal case filed against him.
>
> > > Brock was served in his CPA office in Chicago Loop on October 26,
> > > 2007. He had 20 days to answer. The last day to answer was November
> > > 15, 2007, which was yesterday.
>
> > > He has not answered. Therefore, his time to answer has expired.
>
> > > Brock needs to pay me $20 million. I will accept check, cash, money
> > > order or PayPal.
>
> > > Brock should get a PACER account athttp://pacer.psc.uscourts.gov/uspci.html
>
> > > That way, his jailhouse lawyer can file electronically and we can all
> > > read his answer.
>
> > > Of course, that will cost 8 cents a page to buy but, hey, life is
> > > unfair.
>
> > > Sam Sloan
>
> > In your alternate universe, do I have a full head of hair?
>
> I will start the Bill Brock technique.
>
> Day 1
>
> Days that Bill Brock has failed to pay the $20 million he owes.

In your alternate universe, I have $30 million: no problem!

Date: 16 Nov 2007 14:25:42
From: Richard
Subject: Re: Legal Threats from William Brock

[email protected] wrote:
>
> In your alternate universe, I have $30 million: no problem!
>

If he's in an alternate universe, he probably cant read your replies.

Date: 16 Nov 2007 12:37:19
From: samsloan
Subject: Re: Legal Threats from William Brock

On Nov 16, 3:27 pm, [email protected] wrote:
> On Nov 16, 8:48 am, samsloan <[email protected]> wrote:
>
>
>
> > Following Brock's online confession that he dreams of being a child
> > molester, he has defaulted in the federal case filed against him.
>
> > Brock was served in his CPA office in Chicago Loop on October 26,
> > 2007. He had 20 days to answer. The last day to answer was November
> > 15, 2007, which was yesterday.
>
> > He has not answered. Therefore, his time to answer has expired.
>
> > Brock needs to pay me $20 million. I will accept check, cash, money
> > order or PayPal.
>
> > Brock should get a PACER account athttp://pacer.psc.uscourts.gov/uspci.html
>
> > That way, his jailhouse lawyer can file electronically and we can all
> > read his answer.
>
> > Of course, that will cost 8 cents a page to buy but, hey, life is
> > unfair.
>
> > Sam Sloan
>
> In your alternate universe, do I have a full head of hair?

I will start the Bill Brock technique.

Day 1

Days that Bill Brock has failed to pay the $20 million he owes.

Date: 16 Nov 2007 12:27:51
From:
Subject: Re: Legal Threats from William Brock

On Nov 16, 8:48 am, samsloan <[email protected] > wrote:
> Following Brock's online confession that he dreams of being a child
> molester, he has defaulted in the federal case filed against him.
>
> Brock was served in his CPA office in Chicago Loop on October 26,
> 2007. He had 20 days to answer. The last day to answer was November
> 15, 2007, which was yesterday.
>
> He has not answered. Therefore, his time to answer has expired.
>
> Brock needs to pay me $20 million. I will accept check, cash, money
> order or PayPal.
>
> Brock should get a PACER account athttp://pacer.psc.uscourts.gov/uspci.html
>
> That way, his jailhouse lawyer can file electronically and we can all
> read his answer.
>
> Of course, that will cost 8 cents a page to buy but, hey, life is
> unfair.
>
> Sam Sloan

In your alternate universe, do I have a full head of hair?

Date: 16 Nov 2007 06:48:08
From: samsloan
Subject: Re: Legal Threats from William Brock

Following Brock's online confession that he dreams of being a child
molester, he has defaulted in the federal case filed against him.

Brock was served in his CPA office in Chicago Loop on October 26,
2007. He had 20 days to answer. The last day to answer was November
15, 2007, which was yesterday.

He has not answered. Therefore, his time to answer has expired.

Brock needs to pay me $20 million. I will accept check, cash, money
order or PayPal.

Brock should get a PACER account at
http://pacer.psc.uscourts.gov/uspci.html

That way, his jailhouse lawyer can file electronically and we can all
read his answer.

Of course, that will cost 8 cents a page to buy but, hey, life is
unfair.

Sam Sloan

Date: 14 Nov 2007 12:35:35
From: samsloan
Subject: Re: Legal Threats from William Brock

No. 07 CV 8537
___________________________________________________________________________=
___

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
___________________________________________________________________________=
___

SAM SLOAN, )
)
Plaintiff, )
)
v=2E ) The Honorable
) DENNY CHIN,
HOAINHAN "PAUL" TRUONG, ) Judge Presiding.
WILLIAM BROCK, et al., )
)
Defendants. )
)
___________________________________________________________________________=
___

Defendant William Brock's Motion for Rule 11 Sanctions

Defendant William Brock ("Brock") moves for sanctions against
plaintiff Sam Sloan ("Sloan") pursuant to Fed. R. Civ. P. 11. In
support of this motion, Brock states as follows:
Sloan pleads in his Complaint that he "was elected to the Executive
Board of the United States Chess Federation ["USCF"] in 2006 but was
defeated when he ran for re-election in 2007." Complaint =B6 10. Sloan
brought this lawsuit, purportedly under the Court's federal-question
jurisdiction and diversity jurisdiction, Complaint =B6 2, against 13
individual defendants, USCF, Texas Tech University, and the United
States of America. He alleges that the individual defendants
committed defamation and other alleged wrongdoing in connection with
Sloan's unsuccessful campaign for reelection to the USCF Executive
Board. As to Brock specifically, Sloan alleges that Brock posted to
the USCF forum and other sites on the Internet assertions that Brock
is "a child molester, a pornographer and a purveyor of 'kiddie porn.'"
See Complaint =A7=A7 62-63.
This Court should award Brock Rule 11 sanctions against Sloan because
(1) controlling Second Circuit caselaw establishes that there is no
basis for personal jurisdiction over Brock, a citizen of Illinois and
(2) Sloan has not pled a basis for subject-matter jurisdiction over
Brock. As such, Sloan's claims against Brock are not "warranted by
existing law or by a nonfrivolous argument for the extension,
modification, or reversal of existing law or the establishment of new
law[.]" Fed. R. Civ. P. 11(b)(2). It should also be noted that
Sloan, although not a lawyer, is quite familiar with the legal
system. In addition to his felony conviction in Virginia in 1992, see
Complaint =B6 24, he pleads that, "In legal circles, Sloan is best known
for about 20 published and reported decisions involving federal
securities laws." Id. =B6 10. These include a 1978 case in which
Sloan, proceeding pro se, orally argued and briefed a case before the
Supreme Court of the United States, winning 9-0. His opposing counsel
was Harvey Pitt, then the General Counsel of the SEC, who later served
as Chairman of the SEC in 2001-03. See SEC v. Sloan, 436 U.S. 103
(1978).
As required by Rule 11's "safe harbor" provision, Fed. R. Civ. P. 11(c)
(1)(A), the undersigned counsel served a copy of this motion on Sloan
by e-mail on November 8, 2007, and by mail on November 9, 2007,
requesting that Sloan withdraw his claim against Brock within 21 days
after service. See Exhibit A, infra. Sloan has not done so.

There is no basis for personal jurisdiction over Brock.

Brock, as he establishes in his affidavit submitted in support of his
motion to dismiss, has been a citizen of Illinois for the past 30
years, and has never been a citizen or resident of New York. Notably,
Sloan does not contend otherwise. He pleads that Brock: "is a
Chicago CPA residing in Chicago," is "Past President of the Illinois
Chess Association," his "CPA office [is] in the Chicago Loop," and his
address is "230 West Monroe, Suite 330, Chicago, Illinois
60606-4701." Complaint =B6 35.
Sloan alleges no connection between Brock and New York other than that
Brock has posted comments on the Internet that are presumably
accessible in New York (and anywhere else in the world). See
Complaint =B6=B6 35, 62-65. As Brock's affidavit establishes, all of
these posts were made from Brock's computers in Chicago, Illinois.
Again, Sloan does not allege otherwise.
It is well-settled that a defendant's acts of posting on the Internet,
from a state other than New York, defamatory allegations about a
person do not give rise to personal jurisdiction over the defendant in
New York. This is definitively established by the Second Circuit's
recent controlling decision in Best Van Lines, Inc. v. Walker, 490 F.
3d 239 (2d Cir. 2007). There, the Second Circuit, affirming a
decision by Judge Lynch of this Court, held that an Iowa resident's
posting to the Internet of defamatory information about the plaintiff,
a New York-based moving company, did not give rise to personal
jurisdiction over the defendant in New York. The Court noted that New
York's long-arm statute expressly exempts causes of action for
defamation of character from the provisions of its long-arm statute
pertaining to "commission of a tortious act" within or without the
state of New York. Id. at 244-45 (citing 35 N.Y. C.P.L.R. =A7=A7 302(a)
(2), 302(a)(3)).
As to section 302(a)(1) of the C.P.L.R., relating to "transact[ing]
any business within the state or contract[ing] anywhere to supply
goods or services in the state," 35 N.Y. C.P.L.R. =A7 302(a)(1), the
Second Circuit noted that federal district courts in New York have
consistently held that:
the posting of defamatory material on a website accessible in New York
does not, without more, constitute "transact[ing] business" in New
York for the purposes of New York's long-arm statute. See Realuyo [v.
Villa Abrille, 01 Civ. 10158,] 2003 WL 21537754, at *7, 2003 U.S.
Dist. LEXIS 11529, at *20-21 (deciding that the availability of an
article on a website, without more, does not amount to "transaction of
business" for purposes of section 302(a)(1)); see also Starmedia
Network, Inc., 00 Civ. 4647, 2001 WL 417118, at *3, 2001 U.S. Dist.
LEXIS 4870, at *7 (S.D.N.Y. Apr. 23, 2001) ("[I]t is now well
established that one does not subject himself to the jurisdiction of
the courts in another state simply because he maintains a web site
which residents of that state visit.") (citation and quotation
indication omitted). In addition, to the extent that there are
business transactions incident to establishing a website, a defamation
claim based on statements posted on a website does not "arise from"
such transactions. See Realuyo, 2003 WL 21537754, at *7, 2003 U.S.
Dist. LEXIS 11529, at *20-22 (finding that "the publication of the
article was not the transaction of business in New York" and the
defamation claim did not arise from advertising links on the website;
see also Competitive Techs., Inc. v. Pross, 13297/2006, 14 Misc. 3d
1224(A), 2007 WL 283075, at *3, 2007 N.Y. Misc. LEXIS 217, at *8 (Sup.
Ct. Suffolk County, Jan. 26, 2007) (concluding that libelous
statements posted on a Yahoo! message board did not give rise to
jurisdiction because they were "not in connection with any business
transactions").

Best Van Lines, 490 F.3d at 250-51. Following these cases, the Second
Circuit held that the defendant's posting of defamatory statements
about plaintiff on the "Black List Report" on his website, his
defamatory answer to a user's question about the plaintiff, and his
solicitation of donations did not give rise to personal jurisdiction
over the defendant in New York. Id. at 253-55.
There is no legitimate basis upon which Sloan can distinguish Best Van
Lines from this case. If anything, the lack of personal jurisdiction
over Brock here follows a fortiori from Best Van Lines. The defendant
in that case operated an Internet business, a not-for-profit website
that provided information about household movers and solicited
donations from the public. Id. at 240, 254-55. Here, Sloan does not
contend that Brock operated an Internet business, but rather that he
has posted defamatory statements about Sloan on public forums operated
by the USCF and others. Complaint =B6=B662-63. It is thus even more
difficult than in Best Van Lines to contend that Brock's posting of
defamatory statements about Sloan constituted "transacting business"
in New York for purposes of the state's long-arm statute.

Sloan has not pled any basis for subject-matter jurisdiction over his
claim against Brock.

Sloan does not explain what, if anything, is the substantive basis for
his claim against Brock. That claim appears to sound in defamation,
if anything. See Complaint =B6 62 ("defendants . . . have posted
thousands of times on the Internet accusations that Plaintiff is a
child molester, a pornographer and a purveyor of 'kiddie porn'").
That is of course a state, not federal, cause of action, cf. Paul v.
Davis, 424 U.S. 693 (1976) (defamation not actionable under 42 U.S.C.
=A7 1983), and thus provides no basis for federal-question jurisdiction.
1
Nor has Sloan pled a basis for diversity jurisdiction. "It is well
established that the party seeking to invoke jurisdiction under 28
U=2ES.C. =A71332 bears the burden of demonstrating that grounds for
diversity exist and that diversity is complete." Herrick Co. v. SCS
Communications, Inc., 251 F.3d 315, 322-23 (2d Cir. 2001) (citation
and internal quotation ks omitted). Sloan's complaint, far from
pleading that complete diversity exists, suggests that it does not.
Sloan pleads that he resides in New York, and that defendant William
Goichberg resides in both New York and California. Complaint =B6 22.
If Sloan and Goichberg are both "citizens" of New York (the statutory
term, 28 U.S.C. =A71332, which does not equate to "residence," see
Franceskin v. Credit Suisse, 214 F.3d 253, 255-56 (2nd Cir. 2000)
(collecting cases)), then the Court lacks diversity jurisdiction, as
well.

Conclusion

In short, controlling Second Circuit caselaw establishes that Sloan
has no basis for claiming that this Court has personal jurisdiction
over Brock, nor has Sloan pled any basis for subject-matter
jurisdiction over his claim against Brock. This Court should
accordingly impose sanctions against Sloan pursuant to Federal Rule of
Civil Procedure 11, and should award Brock the attorney's fees and
costs he incurred in defending this action.

Respectfully submitted,

_______________________________
Patrick M. O'Brien
Law Offices of Patrick M. O'Brien
309 Elmore St.
Park Ridge, IL 60068-3569
(847) 692-2320
[email protected]
Attorney for Defendant William Brock

Date: 14 Nov 2007 22:21:46
From: I.P. Knightly
Subject: Re: Legal Threats from William Brock

samsloan wrote:
>... As to Brock specifically, Sloan alleges that Brock posted to
> the USCF forum and other sites on the Internet assertions that Brock
> is "a child molester, a pornographer and a purveyor of 'kiddie porn.'"
> See Complaint �� 62-63. ...

Sloan's suing Brock because Brock defamed himself?

Date: 14 Nov 2007 11:10:59
From: help bot
Subject: Re: Legal Threats from William Brock

On Nov 14, 7:37 am, The Historian <[email protected] > wrote:

> > > into in Central Park on a Sunday when I was seventeen. I'm going about 30
> > > mph
>
> > Okay, so you were speeding recklessly...
>
> That was certainly an excessive rate of speed for a multi-use path.
>
> > > with the right of way
>
> > Can you explain this statement? I'm not sure I comprehend
> > a claim to having the right of way on a bicycle, unless say,
> > there are signs everywhere prohibiting other forms of traffic
> > (for instance, a bikes-only trail).
>
> Trail users, regardless of how they are moving, should follow normal
> traffic patterns for road use. However, many pedestrians, either from
> ignorance or to feel safer with all those big bad bicycles around,
> walk against trail traffic. Still, bicycles should brake for
> pedestrians in all cases. Cyclists are the 18 wheeled trucks of the
> bike path, even if they aren't riding a Surley Long Haul Trucker.
>
> > > and he stands perpendicular to me, right in my
> > > path.

Okay, so he suffers from a delusion that the path in
Central Park belongs to him, and him alone.

> > This used to happen around here all the time; but of
> > course, all those silly squirrels are now dead. :<(
>
> Wasn't the path big enough for Mr. Gordon to go around the child?

Go around? Are you kidding, this guy believes
he *owns* the path. Let everyone else get out
of *his way*, or suffer the consequences!

> And if traffic was so heavy that he couldn't pass the kid, why was
he
> clocking 30 MPH?

I think maybe the kid obstructed *his path* deliberately,
as in a twisted sense of humor -- cause a crash, make
someone panic. Like when you used to throw rocks
from that overpass at the cars below, or when you had
that magnifying glass, and would terrorize ants with it --
remember?

> There has to be more to this story.

Okay. So that kid went on to bigger and better
things. His name? Lex Luthor, as I recall. He made
a brief appearance later in the movie "athon Man",
starring Dustin Hoffman -- he knocks DH down while
he is running in Central Park, during a shoot.

-- help bot

Date: 14 Nov 2007 04:37:57
From: The Historian
Subject: Re: Legal Threats from William Brock

On Nov 13, 10:33 am, help bot <[email protected] > wrote:
> On Nov 10, 11:15 am, "Ray Gordon, creator of the \"pivot\""
>
> <[email protected]> wrote:
> > First I have to let Sam finish imploding, hwoever, and that may take a few
> > months. He reminds me of an eight year-old I once almost crashed my bicycle
> > into in Central Park on a Sunday when I was seventeen. I'm going about 30
> > mph
>
> Okay, so you were speeding recklessly...

That was certainly an excessive rate of speed for a multi-use path.

> > with the right of way
>
> Can you explain this statement? I'm not sure I comprehend
> a claim to having the right of way on a bicycle, unless say,
> there are signs everywhere prohibiting other forms of traffic
> (for instance, a bikes-only trail).

Trail users, regardless of how they are moving, should follow normal
traffic patterns for road use. However, many pedestrians, either from
ignorance or to feel safer with all those big bad bicycles around,
walk against trail traffic. Still, bicycles should brake for
pedestrians in all cases. Cyclists are the 18 wheeled trucks of the
bike path, even if they aren't riding a Surley Long Haul Trucker.

> > and he stands perpendicular to me, right in my
> > path.
>
> This used to happen around here all the time; but of
> course, all those silly squirrels are now dead. :<(

Wasn't the path big enough for Mr. Gordon to go around the child? And
if traffic was so heavy that he couldn't pass the kid, why was he
clocking 30 MPH? There has to be more to this story.

Date: 13 Nov 2007 07:33:29
From: help bot
Subject: Re: Legal Threats from William Brock

On Nov 10, 11:15 am, "Ray Gordon, creator of the \"pivot\""
<[email protected] > wrote:

> First I have to let Sam finish imploding, hwoever, and that may take a few
> months. He reminds me of an eight year-old I once almost crashed my bicycle
> into in Central Park on a Sunday when I was seventeen. I'm going about 30
> mph

Okay, so you were speeding recklessly...

> with the right of way

Can you explain this statement? I'm not sure I comprehend
a claim to having the right of way on a bicycle, unless say,
there are signs everywhere prohibiting other forms of traffic
(for instance, a bikes-only trail).

> and he stands perpendicular to me, right in my
> path.

This used to happen around here all the time; but of
course, all those silly squirrels are now dead. :<(

> I fly over my handlebars and barely avoid injury, but my thumb (and
> 180+ bowling average) were wrecked for almost a year. Decided not to purse
> pro bowling as a result.

Too bad. Had you been /killed/ while trying to assert
your "right of way" by running down a child, you might
have (posthumously) been given a Darwin Award.

> Guys like Sloan don't do the image of a pro-se any favors. I've worked for
> big and small law firms in more than one state, and never had my work sent
> back by a judge when an attorney signed off on it (they didn't edit it or
> anything). Because of his fine, um, "work," my pleadings are lumped in with
> that garbage.

But Mr. Sloan makes you look good in comparison.
I'd love to play in a big tournament, on the board right
next to him; imagine the spectators, upon seeing his
Damiano's Defense slop, and right next to it a /real
chess game/.

Anyway, your Mother probably forgot to inform you
that...

*the pedestrian* always has the right of way.

------

A recent exception was a story in my local paper
in which a police officer was en route to a high-speed
chase, and smacked a pedestrian who he claimed
stepped right out in front of him for no reason. If
queried, the pedestrian could say nothing (he is
dead) to contradict this version of the story.

-- help bot

Date: 13 Nov 2007 09:55:59
From: Richard
Subject: Re: Legal Threats from William Brock

help bot wrote:
>
> Too bad. Had you been /killed/ while trying to assert
> your "right of way" by running down a child, you might
> have (posthumously) been given a Darwin Award.
>
>

I don't believe you can be given one any other way!

Date: 13 Nov 2007 19:11:39
From: Kent Wills
Subject: Re: Legal Threats from William Brock

As I understand it, on Tue, 13 Nov 2007 09:55:59 -0700, Richard
<[email protected] > wrote:

>help bot wrote:
>>
>> Too bad. Had you been /killed/ while trying to assert
>> your "right of way" by running down a child, you might
>> have (posthumously) been given a Darwin Award.
>>
>>
>
>
>
>I don't believe you can be given one any other way!

Technically not given one.

--
Kent
"I'm a ten gov a day guy. It's all I know, and it's all
you need to know, gov!"
- Shouting George

Date: 11 Nov 2007 12:10:44
From:
Subject: Re: Legal Threats from William Brock

On Nov 11, 10:14 am, "Ted E Bear" <[email protected] > wrote:
> On 10-Nov-2007, samsloan <[email protected]> wrote:
>
> > I have received a letter from a lawyer named Patrick O'Brien
> > <[email protected]> claiming to represent William Brock,
> > threatening to find a Rule 11 Motion for sanctions against me unless I
> > withdraw my suit against Mr. Brock.
>
> This is the 21 day "safe harbor" letter. You now have to decide if you
> have, or can develop, relevant evidence to support your contentions. If you
> have such relevant evidence, then you might assume that this letter is just
> scare tactics to force you to drop your case against Mr. Brock. However if
> you do not have such relevant evidence, and a Rule 11 motion is in fact
> made, you might have some explaining to do at the end of the case. Lawsuits
> are always two edged swords, if you lose you might just find that DIY
> lawyering can be a dangerous undertaking.
>
> > I am utterly terrified. Which should I do?
>
> Go and seek legal counsel from a real lawyer. This is no place for
> amateurs, and Rule 11 has serious teeth, it's not something to play around
> with.
>
>
>
> > It is to be recalled that Mr. Brock had repeatedly dared me to file a
> > lawsuit against him, while at the same time he was posting thousands
> > of articles to this forum accusing me of being a "child molester".
> > These articles have continued even after I filed this suit.
>
> You are in the center of a minefield, you need legal assistance from a
> lawyer. You are an amateur that is going up against a number of
> professionals. The bait in the shark pool, it's up to you if you want to be
> eaten. The fact that someone is talking bad about you on the internet is
> irrelevant, the very reason that Darrow made that comment about "having a
> fool for a client" refers to the tendancy of amateurs to get all emotional
> and personally affronted by the case, and let their emotions color their
> judgement. It's quite obvious you are too personally involved here to make
> proper judgements as to what you should do. Seek professional help.
>
> TEB
>
> --
> When asked about the perks of being famous: "I get to go to a lot of
> overseas places, like Canada." Britney Spears
>
> ----== Posted via Newsfeeds.Com - Unlimited-Unrestricted-Secure Usenet News==----http://www.newsfeeds.comThe #1 Newsgroup Service in the World! 120,000+ Newsgroups
> ----= East and West-Coast Server Farms - Total Privacy via Encryption =----

Attorney TEB,

I don't think you are ster or more professional than anyone else.
You come in here, as an ATTORNEY,
And place yourself better than the "common man." I think TED is what
gives attorneys a bad name.

Your behavior, Mr. Bear, is being reported to the bar, if you continue
to harass a pro se litigant.

Enough! It is unethical to interfere in Mr. Sloan's case. Sloan said
he didn't have the money to hire an attorney. You now come in
And write things that could get you in trouble.

You talk about Ray Gordon, you talk about Sam Sloan, let's talk about
YOU, in the form of a bar complaint, if I ever
Catch you giving any more legal advice to Gordon or Sloan.

YOU RUDE ASS HOLE, you go to hell!

cus Roberts

Date: 11 Nov 2007 16:19:50
From: Kent Wills
Subject: Re: Legal Threats from William Brock

As I understand it, on Sun, 11 Nov 2007 12:10:44 -0800,
[email protected] wrote:

>Attorney TEB,

He's not an attorney.

>
>I don't think you are ster or more professional than anyone else.

There was nothing in the post to indicate Ted thinks so
either.

>You come in here, as an ATTORNEY,

No he didn't.

>And place yourself better than the "common man." I think TED is what
>gives attorneys a bad name.
>
>Your behavior, Mr. Bear, is being reported to the bar, if you continue
>to harass a pro se litigant.

How is recommending that someone seek a professional
attorney's advice harassment? Please be specific as I don't see it.

>
>Enough! It is unethical to interfere in Mr. Sloan's case.

Then Mr. Sloan shouldn't seek the opinions of others on
Usenet.
You see, when you post to Usenet, you risk people replying and
giving you their opinions. Ted's opinion is that Sloan should seek
the advice of an attorney. If it should matter in any way, I agree
with Ted.

>Sloan said
>he didn't have the money to hire an attorney. You now come in
>And write things that could get you in trouble.

How would suggesting seeking the advice of a professional
attorney get anyone in trouble?

>
>You talk about Ray Gordon, you talk about Sam Sloan, let's talk about
>YOU, in the form of a bar complaint, if I ever
>Catch you giving any more legal advice to Gordon or Sloan.

He gave no legal advice. He recommended that the poster get
help from an actual lawyer. And I share his opinion.

>
>YOU RUDE ASS HOLE, you go to hell!
>

You seem to know something of rude ass holes.

--
Kent
Vegetarian: Indian word for lousy hunter.

Date: 11 Nov 2007 18:10:26
From: Ray Gordon, creator of the \pivot\
Subject: Re: Legal Threats from William Brock

>>Your behavior, Mr. Bear, is being reported to the bar, if you continue
>>to harass a pro se litigant.
>
> How is recommending that someone seek a professional
> attorney's advice harassment? Please be specific as I don't see it.

The theory behind UPL is that he might encouragre someone to act out against
a pro-se or otherwise cause damages that an attorney would not.

With medical advice, this would be more obvious.

--
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

This group will be restricted to 5,000 members. All new theory from the
creator of the PIVOT!

Don't rely on overexposed, mass-keted commercial seduction methods which
have been rendered worthless through mainstream media exposure. It really
is game over for community material. Beware of Milli Vanilli gurus who
stole their ideas from others!

http://moderncaveman.typepad.com
The Official Ray Gordon Blog

Date: 12 Nov 2007 01:43:44
From: Krus T. Olfard
Subject: Re: Legal Threats from William Brock

"Ray Gordon, creator of the \"pivot\"" (what was that link to the pivot
man again?) whined:

>>>Your behavior, Mr. Bear, is being reported to the bar, if you
>>>continue to harass a pro se litigant.
>>
>> How is recommending that someone seek a professional
>> attorney's advice harassment? Please be specific as I don't see it.
>
> The theory behind UPL is that he might encouragre someone to act out
> against a pro-se or otherwise cause damages that an attorney would
> not.
>
> With medical advice, this would be more obvious.
>
>

Ah, the frootluip with the 0-(some astronomical number) of successes in
court gives another legal opinion.

Wotta fuckin' macaroon...

--
I'm an opinionated bastard. Everything I post is my opinion. If you do
not like my opinions then killfile me - if you like my opinions then send
me money.

The KTO Dictionary of Subjective Language

Tard: n Someone whose actions/words make her/him look like an idiot in
public but s/he is too disconnected to reality to realize it.

Date: 12 Nov 2007 00:02:08
From: Ted E Bear
Subject: Re: Legal Threats from William Brock

On 11-Nov-2007, "Ray Gordon, Windbag" <[email protected] > wrote:

> > How is recommending that someone seek a professional
> > attorney's advice harassment? Please be specific as I don't see it.
>
> The theory behind UPL is that he might encouragre someone to act out
> against a pro-se or otherwise cause damages that an attorney would not.

So why don't you answer the question? You are SUCH a windbag.....
--
"...serial and vexatious litigant in both the state and federal courts..."
Gordon Roy Parker in his Memorandum Opposing Google's MTD

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----= East and West-Coast Server Farms - Total Privacy via Encryption =----

Date: 11 Nov 2007 21:58:13
From: Ted E Bear
Subject: Re: Legal Threats from William Brock

On 11-Nov-2007, [email protected] wrote:

> Attorney TEB,
>
> I don't think you are ster or more professional than anyone else.
> You come in here, as an ATTORNEY,
> And place yourself better than the "common man." I think TED is what
> gives attorneys a bad name.
>
You are entitled to your opinion, just like I am entitled to mine.

> Your behavior, Mr. Bear, is being reported to the bar, if you continue
> to harass a pro se litigant.
>
Joining into a discussion on an public USENET group is not a sactionable
action. If you think it is, then go ahead and do what you have to do. You
are of course, full of the hot air that is evident in most of your posts,
but that's your problem.

> Enough! It is unethical to interfere in Mr. Sloan's case. Sloan said
> he didn't have the money to hire an attorney. You now come in
> And write things that could get you in trouble.

cus, please understand that I don't care what you think. He asked a
question, and I answered. If you don't like that, you can always go for a
walk around your beautiful island and perhaps your attitude will improve.
Or take your pills, as the case may be.

> You talk about Ray Gordon, you talk about Sam Sloan, let's talk about
> YOU, in the form of a bar complaint, if I ever
> Catch you giving any more legal advice to Gordon or Sloan.

I will comment when I feel like it, file your complaint.

> YOU RUDE ASS HOLE, you go to hell!

LOL, is that the best you can do? Strange that you would be so abusive to
someone that you don't know, and has never addressed you. Is everyone from
your "country" so stupid as you?

TEB
--
The definition of insanity is doing the same thing over and over and
expecting different results.
Benjamin Franklin

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Date: 11 Nov 2007 12:55:18
From: John Michaels
Subject: Re: Legal Threats from William Brock

<[email protected] > wrote in message
news:[email protected]...
> On Nov 11, 10:14 am, "Ted E Bear" <[email protected]> wrote:
>> On 10-Nov-2007, samsloan <[email protected]> wrote:
>>
>> > I have received a letter from a lawyer named Patrick O'Brien
>> > <[email protected]> claiming to represent William Brock,
>> > threatening to find a Rule 11 Motion for sanctions against me unless I
>> > withdraw my suit against Mr. Brock.
>>
>> This is the 21 day "safe harbor" letter. You now have to decide if you
>> have, or can develop, relevant evidence to support your contentions. If
>> you
>> have such relevant evidence, then you might assume that this letter is
>> just
>> scare tactics to force you to drop your case against Mr. Brock. However
>> if
>> you do not have such relevant evidence, and a Rule 11 motion is in fact
>> made, you might have some explaining to do at the end of the case.
>> Lawsuits
>> are always two edged swords, if you lose you might just find that DIY
>> lawyering can be a dangerous undertaking.
>>
>> > I am utterly terrified. Which should I do?
>>
>> Go and seek legal counsel from a real lawyer. This is no place for
>> amateurs, and Rule 11 has serious teeth, it's not something to play
>> around
>> with.
>>
>>
>>
>> > It is to be recalled that Mr. Brock had repeatedly dared me to file a
>> > lawsuit against him, while at the same time he was posting thousands
>> > of articles to this forum accusing me of being a "child molester".
>> > These articles have continued even after I filed this suit.
>>
>> You are in the center of a minefield, you need legal assistance from a
>> lawyer. You are an amateur that is going up against a number of
>> professionals. The bait in the shark pool, it's up to you if you want to
>> be
>> eaten. The fact that someone is talking bad about you on the internet is
>> irrelevant, the very reason that Darrow made that comment about "having a
>> fool for a client" refers to the tendancy of amateurs to get all
>> emotional
>> and personally affronted by the case, and let their emotions color their
>> judgement. It's quite obvious you are too personally involved here to
>> make
>> proper judgements as to what you should do. Seek professional help.
>>
>> TEB
>>
>> --
>> When asked about the perks of being famous: "I get to go to a lot of
>> overseas places, like Canada." Britney Spears
>>
>> ----== Posted via Newsfeeds.Com - Unlimited-Unrestricted-Secure Usenet
>> News==----http://www.newsfeeds.comThe #1 Newsgroup Service in the World!
>> 120,000+ Newsgroups
>> ----= East and West-Coast Server Farms - Total Privacy via Encryption
>> =----
>
> Attorney TEB,
>
> I don't think you are ster or more professional than anyone else.
> You come in here, as an ATTORNEY,
> And place yourself better than the "common man." I think TED is what
> gives attorneys a bad name.
>
> Your behavior, Mr. Bear, is being reported to the bar, if you continue
> to harass a pro se litigant.
>
> Enough! It is unethical to interfere in Mr. Sloan's case. Sloan said
> he didn't have the money to hire an attorney. You now come in
> And write things that could get you in trouble.
>
> You talk about Ray Gordon, you talk about Sam Sloan, let's talk about
> YOU, in the form of a bar complaint, if I ever
> Catch you giving any more legal advice to Gordon or Sloan.
>
> YOU RUDE ASS HOLE, you go to hell!
>
> cus Roberts
>
What an idiot. You are even making Gordon look good. Love to see the
paperwork on this compliant. Guy tells another to go seek a lawyer. Yep,
that is going to go far. Like I said, what an idiot.

Date: 11 Nov 2007 15:58:37
From: Ray Gordon, creator of the \pivot\
Subject: Re: Legal Threats from William Brock

> What an idiot. You are even making Gordon look good. Love to see the
> paperwork on this compliant. Guy tells another to go seek a lawyer. Yep,
> that is going to go far. Like I said, what an idiot.

Actually, "Ted E Bear" has been giving what would be construed as legal
advice (as in something only a lawyer is qualified to speak on) for a long
time on these groups.

In Pennsylvania, only attorneys have standing to bring a private UPL lawsuit
on the grounds that he is encroaching on them professionally and harming
them financially, so an attorney could get involved at any time, as could
the Bar Association itself.

Nonattorneys in PA can file a complaint with the PA Bar association, which
then investigates and usually attempts conciliation prior to filing suit.
They might send someone a letter advising them not to do it, but there
wouldn't likely be any penalty first time around.

--
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

This group will be restricted to 5,000 members. All new theory from the
creator of the PIVOT!

Don't rely on overexposed, mass-keted commercial seduction methods which
have been rendered worthless through mainstream media exposure. It really
is game over for community material. Beware of Milli Vanilli gurus who
stole their ideas from others!

http://moderncaveman.typepad.com
The Official Ray Gordon Blog

Date: 11 Nov 2007 16:22:20
From: Kent Wills
Subject: Re: Legal Threats from William Brock

As I understand it, on Sun, 11 Nov 2007 15:58:37 -0500, "Ray Gordon,
creator of the \"pivot\"" <[email protected] > wrote:

>> What an idiot. You are even making Gordon look good. Love to see the
>> paperwork on this compliant. Guy tells another to go seek a lawyer. Yep,
>> that is going to go far. Like I said, what an idiot.
>
>Actually, "Ted E Bear" has been giving what would be construed as legal
>advice (as in something only a lawyer is qualified to speak on) for a long
>time on these groups.
>
>In Pennsylvania, only attorneys have standing to bring a private UPL lawsuit
>on the grounds that he is encroaching on them professionally and harming
>them financially, so an attorney could get involved at any time, as could
>the Bar Association itself.
>
>Nonattorneys in PA can file a complaint with the PA Bar association, which
>then investigates and usually attempts conciliation prior to filing suit.
>They might send someone a letter advising them not to do it, but there
>wouldn't likely be any penalty first time around.

Since no legal advice was given, it's a moot point.
Ted E. Bear stated that the OP should seek the advice of a
professional attorney in the matter.

--
Kent
Nott was shot and Shott was not.
In this case, it's better to be Shott than Nott.

Date: 11 Nov 2007 22:04:53
From: Ted E Bear
Subject: Re: Legal Threats from William Brock

On 11-Nov-2007, "Ray Gordon, creator of the \"pivot\"" <[email protected] >
wrote:

> Actually, "Ted E Bear" has been giving what would be construed as legal
> advice (as in something only a lawyer is qualified to speak on) for a long
> time on these groups.
>
Ray, you construe things all the time, in ways that some legal authorities
have called "incomprehensible". Unfortunately for you, the Courts have so
far not agreed with you.

> In Pennsylvania, only attorneys have standing to bring a private UPL
> lawsuit on the grounds that he is encroaching on them professionally and
> harming
> them financially, so an attorney could get involved at any time, as could
> the Bar Association itself.

I'm not in Pa Ray. So your point is Moot.

> Nonattorneys in PA can file a complaint with the PA Bar association, which
> then investigates and usually attempts conciliation prior to filing suit.
> They might send someone a letter advising them not to do it, but there
> wouldn't likely be any penalty first time around.

File your complaint with the PA bar, be sure and spell my name
correctly....LOL BTW, you lack standing, and personal jurisdiction, as
usual. Your bluster is really quite humorous. Thanks for the laughs.
--
"...serial and vexatious litigant in both the state and federal courts..."
Gordon Roy Parker in his Memorandum Opposing Google's MTD

----== Posted via Newsfeeds.Com - Unlimited-Unrestricted-Secure Usenet News==----
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----= East and West-Coast Server Farms - Total Privacy via Encryption =----

Date: 11 Nov 2007 13:24:48
From: John Michaels
Subject: Re: Legal Threats from William Brock

"Ray Gordon, creator of the "pivot"" <[email protected] > wrote in message
news:[email protected]...
>> What an idiot. You are even making Gordon look good. Love to see the
>> paperwork on this compliant. Guy tells another to go seek a lawyer.
>> Yep, that is going to go far. Like I said, what an idiot.
>
> Actually, "Ted E Bear" has been giving what would be construed as legal
> advice (as in something only a lawyer is qualified to speak on) for a long
> time on these groups.
>
> In Pennsylvania, only attorneys have standing to bring a private UPL
> lawsuit on the grounds that he is encroaching on them professionally and
> harming them financially, so an attorney could get involved at any time,
> as could the Bar Association itself.
>
> Nonattorneys in PA can file a complaint with the PA Bar association, which
> then investigates and usually attempts conciliation prior to filing suit.
> They might send someone a letter advising them not to do it, but there
> wouldn't likely be any penalty first time around.
>

>
Ray, I still doubt that anyone would take this compliant seriously. If you
read the response, it is telling the person to seek a lawyer. No
encroaching on anything or competing. No representation is made that the
person is a lawyer. Just doesn't meet the standards. The idiot can file
the paperwork but got a feeling it is going to be sitting in the IN basket
for a very long time.

You see folks are allowed to give opinions. You don't have to agree with
them but they are allowed to give them. If you the reader decide to follow
them, well, that is your choice and you are responsible for it. Again, this
and many of Ted E Bear responses are opinions. They seem to be pretty
informed ones and pretty accurate but are opinions. Problem is more with
the social rejects who think filing complaints like this is the way to go.
They think that they can get other people to fight their fights.
Unfortunately, they lack of social ability or skills is not the
responsibility of others.

Date: 11 Nov 2007 20:27:03
From: Krus T. Olfard
Subject: Re: Legal Threats from William Brock

[email protected] wrote in
news:[email protected]:

> On Nov 11, 10:14 am, "Ted E Bear" <[email protected]> wrote:
>> On 10-Nov-2007, samsloan <[email protected]> wrote:
>>
>> > I have received a letter from a lawyer named Patrick O'Brien
>> > <[email protected]> claiming to represent William Brock,
>> > threatening to find a Rule 11 Motion for sanctions against me
>> > unless I withdraw my suit against Mr. Brock.
>>
>> This is the 21 day "safe harbor" letter. You now have to decide if
>> you have, or can develop, relevant evidence to support your
>> contentions. If you have such relevant evidence, then you might
>> assume that this letter is just scare tactics to force you to drop
>> your case against Mr. Brock. However if you do not have such
>> relevant evidence, and a Rule 11 motion is in fact made, you might
>> have some explaining to do at the end of the case. Lawsuits are
>> always two edged swords, if you lose you might just find that DIY
>> lawyering can be a dangerous undertaking.
>>
>> > I am utterly terrified. Which should I do?
>>
>> Go and seek legal counsel from a real lawyer. This is no place for
>> amateurs, and Rule 11 has serious teeth, it's not something to play
>> around with.
>>
>>
>>
>> > It is to be recalled that Mr. Brock had repeatedly dared me to file
>> > a lawsuit against him, while at the same time he was posting
>> > thousands of articles to this forum accusing me of being a "child
>> > molester". These articles have continued even after I filed this
>> > suit.
>>
>> You are in the center of a minefield, you need legal assistance from
>> a lawyer. You are an amateur that is going up against a number of
>> professionals. The bait in the shark pool, it's up to you if you
>> want to be eaten. The fact that someone is talking bad about you on
>> the internet is irrelevant, the very reason that Darrow made that
>> comment about "having a fool for a client" refers to the tendancy of
>> amateurs to get all emotional and personally affronted by the case,
>> and let their emotions color their judgement. It's quite obvious you
>> are too personally involved here to make proper judgements as to what
>> you should do. Seek professional help.
>>
>> TEB
>>
>> --
>> When asked about the perks of being famous: "I get to go to a lot of
>> overseas places, like Canada." Britney Spears
>>
>> ----== Posted via Newsfeeds.Com - Unlimited-Unrestricted-Secure
>> Usenet News==----http://www.newsfeeds.comThe #1 Newsgroup Service in
>> the World! 120,000+ Newsgroups ----= East and West-Coast Server Farms
>> - Total Privacy via Encryption =----
>
> Attorney TEB,
>
> I don't think you are ster or more professional than anyone else.
> You come in here, as an ATTORNEY,
> And place yourself better than the "common man." I think TED is what
> gives attorneys a bad name.
>
> Your behavior, Mr. Bear, is being reported to the bar, if you continue
> to harass a pro se litigant.
>
> Enough! It is unethical to interfere in Mr. Sloan's case. Sloan said
> he didn't have the money to hire an attorney. You now come in
> And write things that could get you in trouble.
>
> You talk about Ray Gordon, you talk about Sam Sloan, let's talk about
> YOU, in the form of a bar complaint, if I ever
> Catch you giving any more legal advice to Gordon or Sloan.
>
> YOU RUDE ASS HOLE, you go to hell!
>
> cus Roberts
>
>

Apparently you know rude assholes...

Hmmm...

--
I'm an opinionated bastard. Everything I post is my opinion. If you do
not like my opinions then killfile me - if you like my opinions then send
me money.

The KTO Dictionary of Subjective Language

Tard: n Someone whose actions/words make her/him look like an idiot in
public but s/he is too disconnected to reality to realize it.

Date: 11 Nov 2007 15:18:09
From: Ray Gordon, creator of the \pivot\
Subject: Re: Legal Threats from William Brock

> Attorney TEB,

He's not an attorney. He's a database consultant of some type who does work
for attorneys. He's in the south.

--
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

This group will be restricted to 5,000 members. All new theory from the
creator of the PIVOT!

Don't rely on overexposed, mass-keted commercial seduction methods which
have been rendered worthless through mainstream media exposure. It really
is game over for community material. Beware of Milli Vanilli gurus who
stole their ideas from others!

http://moderncaveman.typepad.com
The Official Ray Gordon Blog

Date: 12 Nov 2007 07:17:20
From: ZFORCE
Subject: Re: Legal Threats from William Brock

"Ray Gordon, creator of the "pivot"" <[email protected] > wrote in message
news:[email protected]...
>> Attorney TEB,
>
> He's not an attorney. He's a database consultant of some type who does
> work for attorneys. He's in the south.
>

Stalk much?

<snicker >

Date: 11 Nov 2007 22:17:49
From: Ted E Bear
Subject: Re: Legal Threats from William Brock

On 11-Nov-2007, "Ray Gordon, Windbag" <[email protected] > wrote:

> > Attorney TEB,
>
> He's not an attorney. He's a database consultant of some type who does
> work for attorneys. He's in the south.

Why Ray, the last time you guessed, you said I was a woman. Pity you can't
read my IP address isn't it? Then you might have a clue how full of methane
you are.
--
"...serial and vexatious litigant in both the state and federal courts..."
Gordon Roy Parker in his Memorandum Opposing Google's MTD

----== Posted via Newsfeeds.Com - Unlimited-Unrestricted-Secure Usenet News==----
http://www.newsfeeds.com The #1 Newsgroup Service in the World! 120,000+ Newsgroups
----= East and West-Coast Server Farms - Total Privacy via Encryption =----

Date: 11 Nov 2007 16:14:58
From: Ted E Bear
Subject: Re: Legal Threats from William Brock

On 10-Nov-2007, samsloan <[email protected] > wrote:

> I have received a letter from a lawyer named Patrick O'Brien
> <[email protected]> claiming to represent William Brock,
> threatening to find a Rule 11 Motion for sanctions against me unless I
> withdraw my suit against Mr. Brock.
>
This is the 21 day "safe harbor" letter. You now have to decide if you
have, or can develop, relevant evidence to support your contentions. If you
have such relevant evidence, then you might assume that this letter is just
scare tactics to force you to drop your case against Mr. Brock. However if
you do not have such relevant evidence, and a Rule 11 motion is in fact
made, you might have some explaining to do at the end of the case. Lawsuits
are always two edged swords, if you lose you might just find that DIY
lawyering can be a dangerous undertaking.

> I am utterly terrified. Which should I do?

Go and seek legal counsel from a real lawyer. This is no place for
amateurs, and Rule 11 has serious teeth, it's not something to play around
with.
>
> It is to be recalled that Mr. Brock had repeatedly dared me to file a
> lawsuit against him, while at the same time he was posting thousands
> of articles to this forum accusing me of being a "child molester".
> These articles have continued even after I filed this suit.

You are in the center of a minefield, you need legal assistance from a
lawyer. You are an amateur that is going up against a number of
professionals. The bait in the shark pool, it's up to you if you want to be
eaten. The fact that someone is talking bad about you on the internet is
irrelevant, the very reason that Darrow made that comment about "having a
fool for a client" refers to the tendancy of amateurs to get all emotional
and personally affronted by the case, and let their emotions color their
judgement. It's quite obvious you are too personally involved here to make
proper judgements as to what you should do. Seek professional help.

TEB

--
When asked about the perks of being famous: "I get to go to a lot of
overseas places, like Canada." Britney Spears

----== Posted via Newsfeeds.Com - Unlimited-Unrestricted-Secure Usenet News==----
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----= East and West-Coast Server Farms - Total Privacy via Encryption =----

Date: 11 Nov 2007 00:49:08
From:
Subject: Re: Legal Threats from William Brock

Ray Gordon, creator of the pivot wrote:
> >> Of course, if Sloan had a brain he would have gone after the ISPs rather
> >> than individuals, and done it in Illinois, where no federal court has
> >> ever
> >> upheld Section 230 immunity. The Seventh Circuit had a track record of
> >> breaking from other circuits and then being upheld by the Supreme Court.
> >> I'm extremely tempted to file there myself for that reason, as well as
> >> USCF
> >> being located there.
> >
> > Not likely.
> >
> > http://blog.ericgoldman.org/archives/2006/11/craigslist_wins.htm
> >
>
> Read the ruling. Criaglist "won" only because there is no "distributor"
> status in Fair Housing cases, so they weren't liable as the "publisher."
>
> Look up Doe v. GTE and read the treatment on Section 230 from the above
> ruling and you'll see it's not so clear.
>
> The 7th is holding out on ISP immunity in defamation cases. Craigslist was
> a Fair Housing Act claim.
>
>
> --
> 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
>
> This group will be restricted to 5,000 members. All new theory from the
> creator of the PIVOT!
>
> Don't rely on overexposed, mass-keted commercial seduction methods which
> have been rendered worthless through mainstream media exposure. It really
> is game over for community material. Beware of Milli Vanilli gurus who
> stole their ideas from others!
>
> http://moderncaveman.typepad.com
> The Official Ray Gordon Blog

I have. While there is some dicta in this and a few other rulings that
has encouraged "jurisdiction shopping" on 230 issues, the chance of
the 7th creating a major circuit split by overturning ten years of
solid case law is somewhere between slim and none. Of course, if you
want to waste your time and, well, someone else's money relitigating
this loser, that's up to you.

While a number of judges have expressed unhappiness with section 230
immunity, they've had to uphold it based on plain language and
precedent. The disputes have been around the edges. (Exactly how much
"editing" do you have to do to forfeit immunity?) As for distributor
liability, no Federal court has been willing to dig up this fossil. A
couple of lower courts in California tried to animate the corpse, but
the Cal Supreme Court stomped on that in Barrett v Rosenthal, pointing
out (among other things) that both the wording and the legislative
history made it clear that Congress did intend to immunize "secondary
publishers." If you really want to challenge this doctrine, you'd have
a better chance writing to your congressman and lobbying him to amend
the law. But not a very good chance.

Date: 11 Nov 2007 04:03:42
From: Ray Gordon, creator of the \pivot\
Subject: Re: Legal Threats from William Brock

>> Don't rely on overexposed, mass-keted commercial seduction methods
>> which
>> have been rendered worthless through mainstream media exposure. It
>> really
>> is game over for community material. Beware of Milli Vanilli gurus who
>> stole their ideas from others!
>>
>> http://moderncaveman.typepad.com
>> The Official Ray Gordon Blog
>
> I have. While there is some dicta in this and a few other rulings that
> has encouraged "jurisdiction shopping" on 230 issues, the chance of
> the 7th creating a major circuit split by overturning ten years of
> solid case law is somewhere between slim and none.

I wouldn't say that. The "dicta" is more like an "open invitation" to
create a split in a suspect area of law. The 7th has done this before, in a
2003 case that split from every other circuit in employment law. The case
was McDonnell v. Cisneros I believe. The 7th said that retaliatory conduct
by an employer did not have to be employment-related to give rise to a cause
of action. Every other circuit disagreed. I argued the same thing in the
3rd Circuit and lost, but when it got to the Supreme Court, they sided with
the 7th.

>Of course, if you
> want to waste your time and, well, someone else's money relitigating
> this loser, that's up to you.
>
> While a number of judges have expressed unhappiness with section 230
> immunity, they've had to uphold it based on plain language and
> precedent.

Courts are not bound by the precedents of other courts, and there is no
plain language or offline precedent supporting Section 230-style immunity.
Besides, why wouldn't the Supreme Court just answer the question? I'm about
to ask them in my google case, so they have a chance to check in.

There is not a single case in the Supreme Court that would uphold this
immunity, and under the Tenth Amendment, the power (to immunize distributors
of defamation) may rest with the states (that's my argument), since it's not
conveyed by statute. If Section 230 weren't at odds with the laws of all 50
states, your argument would be more convincing. The Supreme Court needs to
resolve this split, and I hope they do it with me against Google.

>The disputes have been around the edges. (Exactly how much
> "editing" do you have to do to forfeit immunity?) As for distributor
> liability, no Federal court has been willing to dig up this fossil. A
> couple of lower courts in California tried to animate the corpse, but
> the Cal Supreme Court stomped on that in Barrett v Rosenthal, pointing
> out (among other things) that both the wording and the legislative
> history made it clear that Congress did intend to immunize "secondary
> publishers." If you really want to challenge this doctrine, you'd have
> a better chance writing to your congressman and lobbying him to amend
> the law. But not a very good chance.

Distributor liability is not a "fossil," especially in cases where the
original defamation is old or the original author cannot be found. When
Section 230 was passed, it was for ISPs who knew how to identify the
original source; that is no longer the case.

Congress can also step in as a last resort, and should, but this needs to go
one step at a time, and the 7th hasn't given any sympathy to that law. They
are not lemmings and they have a good track record in circuit splits.

Besdies, USCF is in Illinois. Sloan didn't even have to shop, and neither
do I. I can sue them there just as easily as here. A lot will depend on
what happens with my Google case. If they deny cert, I have no choice but
to go to the 7th and then go back with a win and let the other side appeal.

--
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

This group will be restricted to 5,000 members. All new theory from the
creator of the PIVOT!

Don't rely on overexposed, mass-keted commercial seduction methods which
have been rendered worthless through mainstream media exposure. It really
is game over for community material. Beware of Milli Vanilli gurus who
stole their ideas from others!

http://moderncaveman.typepad.com
The Official Ray Gordon Blog

Date: 10 Nov 2007 21:43:23
From:
Subject: Re: Legal Threats from William Brock

Ray Gordon, creator of the pivot wrote:
>
> Of course, if Sloan had a brain he would have gone after the ISPs rather
> than individuals, and done it in Illinois, where no federal court has ever
> upheld Section 230 immunity. The Seventh Circuit had a track record of
> breaking from other circuits and then being upheld by the Supreme Court.
> I'm extremely tempted to file there myself for that reason, as well as USCF
> being located there.

Not likely.

http://blog.ericgoldman.org/archives/2006/11/craigslist_wins.htm

Date: 11 Nov 2007 02:29:43
From: Ray Gordon, creator of the \pivot\
Subject: Re: Legal Threats from William Brock

>> Of course, if Sloan had a brain he would have gone after the ISPs rather
>> than individuals, and done it in Illinois, where no federal court has
>> ever
>> upheld Section 230 immunity. The Seventh Circuit had a track record of
>> breaking from other circuits and then being upheld by the Supreme Court.
>> I'm extremely tempted to file there myself for that reason, as well as
>> USCF
>> being located there.
>
> Not likely.
>
> http://blog.ericgoldman.org/archives/2006/11/craigslist_wins.htm
>

Read the ruling. Criaglist "won" only because there is no "distributor"
status in Fair Housing cases, so they weren't liable as the "publisher."

Look up Doe v. GTE and read the treatment on Section 230 from the above
ruling and you'll see it's not so clear.

The 7th is holding out on ISP immunity in defamation cases. Craigslist was
a Fair Housing Act claim.

--
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

This group will be restricted to 5,000 members. All new theory from the
creator of the PIVOT!

Don't rely on overexposed, mass-keted commercial seduction methods which
have been rendered worthless through mainstream media exposure. It really
is game over for community material. Beware of Milli Vanilli gurus who
stole their ideas from others!

http://moderncaveman.typepad.com
The Official Ray Gordon Blog

Date: 10 Nov 2007 15:49:28
From: GeekBoy
Subject: Re: Legal Threats from William Brock

cock sucking faggot ass spammer without a life

"samsloan" <[email protected] > wrote in message
news:[email protected]...
>I have received a letter from a lawyer named Patrick O'Brien
> <[email protected]> claiming to represent William Brock,
> threatening to find a Rule 11 Motion for sanctions against me unless I
> withdraw my suit against Mr. Brock.
>
> I am utterly terrified. Which should I do?
>
> It is to be recalled that Mr. Brock had repeatedly dared me to file a
> lawsuit against him, while at the same time he was posting thousands
> of articles to this forum accusing me of being a "child molester".
> These articles have continued even after I filed this suit.
>
> Sam Sloan
>

Date: 10 Nov 2007 13:04:14
From:
Subject: Re: Legal Threats from William Brock

On Nov 10, 1:27 pm, samsloan <[email protected] > wrote:
> On Nov 10, 2:22 pm, [email protected] wrote:
>
>
>
>
>
> > On Nov 10, 8:05 am, samsloan <[email protected]> wrote:
>
> > > I have received a letter from a lawyer named Patrick O'Brien
> > > <[email protected]> claiming to represent William Brock,
> > > threatening to find a Rule 11 Motion for sanctions against me unless I
> > > withdraw my suit against Mr. Brock.
>
> > > I am utterly terrified. Which should I do?
>
> > > It is to be recalled that Mr. Brock had repeatedly dared me to file a
> > > lawsuit against him, while at the same time he was posting thousands
> > > of articles to this forum accusing me of being a "child molester".
> > > These articles have continued even after I filed this suit.
>
> > > Sam Sloan
>
> > Didn't I warn you about Rule 11, Sam? How many times have I posted
> > Rule 11? The US Supreme
> > Court will not save you from this one.
>
> > Expalin to me why you think this defendant has a legal reason to be
> > included as the defendant?
>
> > cus Roberts
>
> I think that more than one thousand postings calling me a "child
> molester" ought to be sufficient.- Hide quoted text -
>
> - Show quoted text -

Sam

Rule 11 is a bitch!

Amend your suit and make it clearer. You are being attacked under rule
11 because your lawsuit
Rambles. Draft a clear and concise AMENDED COMPLAINT. You are going to
have to defend a rule
11 motions and the Judge can throw you in jail. You, you need to work
on your writing skills a little.
Your suit does not say that Brock has called you a child molester
1,000 times, listing each of the 1000
Instances, the date, the time, and the damage you suffered because of
it.

If you don't amend your complaint like I told you, you might end up in
jail after the hearing.

Now, I offered to hire a lawyer and help you, but you said no. Now,
the shit hits the fan. You better amend that complaint, our there are
going to be SEVERAL rule 11 motions, and the hearing will turn into a
psychiatric exam of you, just like with Ray Gordon. You have pissed
off too many people to get away with this shit, even if you have won
in the US Supreme Court.

You have got to find a lawyer and get some kind of help with amending
your complaint.

You need to see a lawyer. If you really think you have a 20 million
dollar damage complaint, then a (broke) personal injury attorney will
take your case in New York, less most of your defendants.

cus Roberts

Date: 10 Nov 2007 20:23:32
From:
Subject: Re: Legal Threats from William Brock

On Nov 10, 1:27 pm, samsloan <[email protected] > wrote:
> On Nov 10, 2:22 pm, [email protected] wrote:
>
>
>
> > On Nov 10, 8:05 am, samsloan <[email protected]> wrote:
>
> > > I have received a letter from a lawyer named Patrick O'Brien
> > > <[email protected]> claiming to represent William Brock,
> > > threatening to find a Rule 11 Motion for sanctions against me unless I
> > > withdraw my suit against Mr. Brock.
>
> > > I am utterly terrified. Which should I do?
>
> > > It is to be recalled that Mr. Brock had repeatedly dared me to file a
> > > lawsuit against him, while at the same time he was posting thousands
> > > of articles to this forum accusing me of being a "child molester".
> > > These articles have continued even after I filed this suit.
>
> > > Sam Sloan
>
> > Didn't I warn you about Rule 11, Sam? How many times have I posted
> > Rule 11? The US Supreme
> > Court will not save you from this one.
>
> > Expalin to me why you think this defendant has a legal reason to be
> > included as the defendant?
>
> > cus Roberts
>
> I think that more than one thousand postings calling me a "child
> molester" ought to be sufficient.

http://www.direkickfeud.blogspot.com

Date: 10 Nov 2007 11:27:02
From: samsloan
Subject: Re: Legal Threats from William Brock

On Nov 10, 2:22 pm, [email protected] wrote:
> On Nov 10, 8:05 am, samsloan <[email protected]> wrote:
>
> > I have received a letter from a lawyer named Patrick O'Brien
> > <[email protected]> claiming to represent William Brock,
> > threatening to find a Rule 11 Motion for sanctions against me unless I
> > withdraw my suit against Mr. Brock.
>
> > I am utterly terrified. Which should I do?
>
> > It is to be recalled that Mr. Brock had repeatedly dared me to file a
> > lawsuit against him, while at the same time he was posting thousands
> > of articles to this forum accusing me of being a "child molester".
> > These articles have continued even after I filed this suit.
>
> > Sam Sloan
>
> Didn't I warn you about Rule 11, Sam? How many times have I posted
> Rule 11? The US Supreme
> Court will not save you from this one.
>
> Expalin to me why you think this defendant has a legal reason to be
> included as the defendant?
>
> cus Roberts

I think that more than one thousand postings calling me a "child
molester" ought to be sufficient.

Date: 10 Nov 2007 11:22:12
From:
Subject: Re: Legal Threats from William Brock

On Nov 10, 8:05 am, samsloan <[email protected] > wrote:
> I have received a letter from a lawyer named Patrick O'Brien
> <[email protected]> claiming to represent William Brock,
> threatening to find a Rule 11 Motion for sanctions against me unless I
> withdraw my suit against Mr. Brock.
>
> I am utterly terrified. Which should I do?
>
> It is to be recalled that Mr. Brock had repeatedly dared me to file a
> lawsuit against him, while at the same time he was posting thousands
> of articles to this forum accusing me of being a "child molester".
> These articles have continued even after I filed this suit.
>
> Sam Sloan

Didn't I warn you about Rule 11, Sam? How many times have I posted
Rule 11? The US Supreme
Court will not save you from this one.

Expalin to me why you think this defendant has a legal reason to be
included as the defendant?

cus Roberts

Date: 10 Nov 2007 14:59:53
From: artichoke
Subject: Re: Legal Threats from William Brock

On Nov 10, 9:05 am, samsloan <[email protected] > wrote:
> I have received a letter from a lawyer named Patrick O'Brien
> <[email protected]> claiming to represent William Brock,
> threatening to find a Rule 11 Motion for sanctions against me unless I
> withdraw my suit against Mr. Brock.
>
> I am utterly terrified. Which should I do?
>
> It is to be recalled that Mr. Brock had repeatedly dared me to file a
> lawsuit against him, while at the same time he was posting thousands
> of articles to this forum accusing me of being a "child molester".
> These articles have continued even after I filed this suit.
>
> Sam Sloan

What is Rule 11? Specifically why does he believe he is entitled to
sanctions?

Date: 10 Nov 2007 11:15:35
From: Ray Gordon, creator of the \pivot\
Subject: Re: Legal Threats from William Brock

>> I am utterly terrified. Which should I do?
>>
>> It is to be recalled that Mr. Brock had repeatedly dared me to file a
>> lawsuit against him, while at the same time he was posting thousands
>> of articles to this forum accusing me of being a "child molester".
>> These articles have continued even after I filed this suit.
>>
>> Sam Sloan
>
> What is Rule 11? Specifically why does he believe he is entitled to
> sanctions?

I AM NOT A FUCKING LAWYER. GET MENTAL HELP IF YOU RELY ON USENET FOR LEGAL
ADVICE. I SPEAK ONLY AS A LAYMAN OR ONE WHO MIGHT SIT ON A JURY. NOW LEAVE
ME ALONE BAR ASSOCIATE FASCISTS

Now that that's out of the way:

He's more or less claiming Sloan's lawsuit was without merit and filed in
bad faith. He's probably just trying to get Sam to pull the case, since
Rule 11 gives him 21 days to pull it without sanctions. If, after 21 days,
Sam doesn't pull the lawsuit, then the attorney can move the court for the
relief sought. The legal community is split on this 21-day "safe harbor"
because it gives a pass to a lot of stuff they think should be sanctioned.

Of course, if Sloan had a brain he would have gone after the ISPs rather
than individuals, and done it in Illinois, where no federal court has ever
upheld Section 230 immunity. The Seventh Circuit had a track record of
breaking from other circuits and then being upheld by the Supreme Court.
I'm extremely tempted to file there myself for that reason, as well as USCF
being located there.

First I have to let Sam finish imploding, hwoever, and that may take a few
months. He reminds me of an eight year-old I once almost crashed my bicycle
into in Central Park on a Sunday when I was seventeen. I'm going about 30
mph, with the right of way, and he stands perpendicular to me, right in my
path. I fly over my handlebars and barely avoid injury, but my thumb (and
180+ bowling average) were wrecked for almost a year. Decided not to purse
pro bowling as a result.

Guys like Sloan don't do the image of a pro-se any favors. I've worked for
big and small law firms in more than one state, and never had my work sent
back by a judge when an attorney signed off on it (they didn't edit it or
anything). Because of his fine, um, "work," my pleadings are lumped in with
that garbage.

Need I also remind Mr. Sloan that he was on the board while *I* was being
impersonated, and I think some of his attention during that time could have
been put to better use, though he did appear to move the board to do
something. I personally think he's far more effective outside of court than
in court, but who knows? It's his dime, maybe more than a dime if he gets
nailed on Rule 11.

In Sam's shoes, I'd be much more concerned about Texas Tech doing this than
any other Defendant, since the 11th Amendment is pretty clear. All I asked
of Texas Tech is that they be an efficient witness and not derstroy
evidence, and their attorney told me they would. Judging by the frenzy
there the day after my call, they seem to be very diligent in preserving the
truth.

--
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

This group will be restricted to 5,000 members. All new theory from the
creator of the PIVOT!

Don't rely on overexposed, mass-keted commercial seduction methods which
have been rendered worthless through mainstream media exposure. It really
is game over for community material. Beware of Milli Vanilli gurus who
stole their ideas from others!

http://moderncaveman.typepad.com
The Official Ray Gordon Blog

Date: 10 Nov 2007 20:50:06
From: foad
Subject: Re: Legal Threats from William Brock

"Ray Gordon, creator of the "loadinthepants" <[email protected] > wrote in
message news:[email protected]...

> path. I fly over my handlebars and barely avoid injury, but my thumb (and
> 180+ bowling average) were wrecked for almost a year. Decided not to purse
> pro bowling as a result.

Thank god you had your career as a professional hypmotizing gymnastics
instructor handicapping seduction guru typist to fall back on.

> Guys like Sloan don't do the image of a pro-se any favors.

Bwah. That's rich.