"samsloan" wrote in message
...
Susan Polgar has filed a motion to dismiss the counterclaim filed by
Sam Sloan in the case of Polgar vs. USCF filed in the United States
District Court for the Northern District of Texas Lubbock Division, 08-
CV-00169

http://www.anusha.com/polgar-motion-to-dismiss.pdf
http://www.anusha.com/polgar-notice-of-motion.pdf

Note that she acknowledges the existence of "a questionable DVD
related to Polgar's divorce proceedings in New York".

I would be interested in hearing your opinion as to how I should
respond to this motion. My inclination is to file a cross-motion for
Summary Judgment based on the Mottershead Report and the two other
reports plus my own affidavit and other evidence. I think I could win
this motion especially since neither Truong nor Polgar are willing to
deny in writing that they are "The Fake Sam Sloan". Thus, there is no
triable issue of fact.

No. ITFP, unless their lawyer is braindead they have denied or will deny
every allegation you make except their names and addresses and maybe even
those. For purposes of the sj motion their sworn denials will be taken as
true and the other evidence (affidavit from expert controverting the
Mottershead report) will be taken "in the light most favorable" to them.
Thus you will not meet your burden of proving that no zero zilch nil none
controverted facts exist and that no jury could possibly find in their
favor. ITSP, you have to prove they did whatever stupid thing you petty
obssessive retards are suing each other over; they don't have to prove they
didn't do it. Their failure to deny that they did what you allege does not
without more constitute proof that they did what you allege