On Jan 6, 1:50 am, wrote:
samsloan wrote:
OK. I have read their moving papers. I do not know why everybody is so
impressed with them. I think I can beat this fairly easily.

For one thing, Bill Goichberg claims to reside at an address he has
never revealed previously and says that he has lived there since 1991.

Can one keep a secret address and then reveal it just to defeat a
diversity claim?

He owns a house there, pays taxes and votes there. This argument is a
loser, as any attorney would have told you if you had bothered to ask

Even if he wins on that one, all I need to do is drop him as a
defendant and then I have complete diversity.

It's not that easy. See Federal Rules of Civil Procedure 15(a). You
could probably refile from scratch if you really want to waste more of
the USCF members' money.

I do not buy their argument that the federal obscenity statute fails
to create a civil cause of action. By the way, does anybody here
disagree that the postings by the Fake Sam Sloan were obscene?

Sam Sloan

(Sigh.) It doesn't matter whether you buy it or not. It's the law. A
criminal statue does not provide a private right of civil action. If
you think the posts violated a law, you can try to persuade a U.S.
Attorney to prosecute. Brian Lafferty already tried that without
success, but you've never let futility get in the way of your actions,
have you?

Bill Goichberg lives a vagabond life, constantly traveling from place
to place, from chess tournament to chess tournament, from horse racing
track to horse racing track. It is true that he has a telephone number
in Salisbury Mills but of the many times I have called that number
nobody has ever answered the phone. He seems to have it on permanent
voicemail. For the past more than 40 years, Bill Goichberg has carried
ads for his chess tournaments in every issue of Chess Life, always
providing an address where to send the entry fees for his chess
tournaments. The street address he provides in this pleading has never
previously been provided anywhere else. I know many people who know
Bill Goichberg even better than I do and none of them have ever heard
of this street address before. If what he says is true, he has been
keeping his residence address secret for the last 17 years and has
revealed it now just to defeat my diversity claim.

So far, Goichberg has submitted no evidence in support of his claim.
He has provided no income tax returns, no deed or title to property,
no gas nor electric bills nor anything else to establish that his
primary domicile is in New York State. (The law speaks of "domicile"
not residence, and I will have to research this distinction.)

Bill Goichberg is not presently in New York State. He is now in
Southern California and plans to stay there at least through the
winter. His claim is that he "intends to return to New York State". I
wonder if that is legally sufficient to defeat a diversity claim

Sam Sloan

samsloan wrote:
On Jan 6, 1:50 am, wrote:
samsloan wrote:
OK. I have read their moving papers. I do not know why everybody is so
impressed with them. I think I can beat this fairly easily.

For one thing, Bill Goichberg claims to reside at an address he has
never revealed previously and says that he has lived there since 1991.

Can one keep a secret address and then reveal it just to defeat a
diversity claim?

He owns a house there, pays taxes and votes there. This argument is a
loser, as any attorney would have told you if you had bothered to ask

Even if he wins on that one, all I need to do is drop him as a
defendant and then I have complete diversity.

It's not that easy. See Federal Rules of Civil Procedure 15(a). You
could probably refile from scratch if you really want to waste more of
the USCF members' money.

I do not buy their argument that the federal obscenity statute fails
to create a civil cause of action. By the way, does anybody here
disagree that the postings by the Fake Sam Sloan were obscene?

Sam Sloan

(Sigh.) It doesn't matter whether you buy it or not. It's the law. A
criminal statue does not provide a private right of civil action. If
you think the posts violated a law, you can try to persuade a U.S.
Attorney to prosecute. Brian Lafferty already tried that without
success, but you've never let futility get in the way of your actions,
have you?

Bill Goichberg lives a vagabond life, constantly traveling from place
to place, from chess tournament to chess tournament, from horse racing
track to horse racing track. It is true that he has a telephone number
in Salisbury Mills but of the many times I have called that number
nobody has ever answered the phone. He seems to have it on permanent
voicemail. For the past more than 40 years, Bill Goichberg has carried
ads for his chess tournaments in every issue of Chess Life, always
providing an address where to send the entry fees for his chess
tournaments. The street address he provides in this pleading has never
previously been provided anywhere else. I know many people who know
Bill Goichberg even better than I do and none of them have ever heard
of this street address before. If what he says is true, he has been
keeping his residence address secret for the last 17 years and has
revealed it now just to defeat my diversity claim.

So far, Goichberg has submitted no evidence in support of his claim.
He has provided no income tax returns, no deed or title to property,
no gas nor electric bills nor anything else to establish that his
primary domicile is in New York State. (The law speaks of "domicile"
not residence, and I will have to research this distinction.)

Bill Goichberg is not presently in New York State. He is now in
Southern California and plans to stay there at least through the
winter. His claim is that he "intends to return to New York State". I
wonder if that is legally sufficient to defeat a diversity claim

Sam Sloan



Did you try looking in the telephone book, Sam? It took me thirty
seconds to find his address in the white pages. But by all means try
this on the judge. Convincing him you're an idiot should help to get
this time-wasting nonsense tossed.

On Jan 6, 7:53 am, samsloan wrote:
It is true that he has a telephone number
in Salisbury Mills but of the many times I have called that number
nobody has ever answered the phone. He seems to have it on permanent
voicemail.

I don't blame him. Knowing you might call would prompt most folks to
screen via voicemail.

On Jan 7, 2:12 am, wrote:
samsloan wrote:
On Jan 6, 1:50 am, wrote:
samsloan wrote:
OK. I have read their moving papers. I do not know why everybody is so
impressed with them. I think I can beat this fairly easily.

For one thing, Bill Goichberg claims to reside at an address he has
never revealed previously and says that he has lived there since 1991.

Can one keep a secret address and then reveal it just to defeat a
diversity claim?

He owns a house there, pays taxes and votes there. This argument is a
loser, as any attorney would have told you if you had bothered to ask

Even if he wins on that one, all I need to do is drop him as a
defendant and then I have complete diversity.

It's not that easy. See Federal Rules of Civil Procedure 15(a). You
could probably refile from scratch if you really want to waste more of
the USCF members' money.

I do not buy their argument that the federal obscenity statute fails
to create a civil cause of action. By the way, does anybody here
disagree that the postings by the Fake Sam Sloan were obscene?

Sam Sloan

(Sigh.) It doesn't matter whether you buy it or not. It's the law. A
criminal statue does not provide a private right of civil action. If
you think the posts violated a law, you can try to persuade a U.S.
Attorney to prosecute. Brian Lafferty already tried that without
success, but you've never let futility get in the way of your actions,
have you?

Bill Goichberg lives a vagabond life, constantly traveling from place
to place, from chess tournament to chess tournament, from horse racing
track to horse racing track. It is true that he has a telephone number
in Salisbury Mills but of the many times I have called that number
nobody has ever answered the phone. He seems to have it on permanent
voicemail. For the past more than 40 years, Bill Goichberg has carried
ads for his chess tournaments in every issue of Chess Life, always
providing an address where to send the entry fees for his chess
tournaments. The street address he provides in this pleading has never
previously been provided anywhere else. I know many people who know
Bill Goichberg even better than I do and none of them have ever heard
of this street address before. If what he says is true, he has been
keeping his residence address secret for the last 17 years and has
revealed it now just to defeat my diversity claim.

So far, Goichberg has submitted no evidence in support of his claim.
He has provided no income tax returns, no deed or title to property,
no gas nor electric bills nor anything else to establish that his
primary domicile is in New York State. (The law speaks of "domicile"
not residence, and I will have to research this distinction.)

Bill Goichberg is not presently in New York State. He is now in
Southern California and plans to stay there at least through the
winter. His claim is that he "intends to return to New York State". I
wonder if that is legally sufficient to defeat a diversity claim

Sam Sloan

Did you try looking in the telephone book, Sam? It took me thirty
seconds to find his address in the white pages. But by all means try
this on the judge. Convincing him you're an idiot should help to get
this time-wasting nonsense tossed.

I am calling your bluff on this one. Would you ,mind telling us where
you found this?

I have searched and have never found the address he provides in his
court papers.

Go to
http://switchboard.intelius.com/resu...oichberg&qs=NY

There you will find:

Bill Goichberg
3054 US RT 9W
NEW WINDSOR, NY 12553

However, that is the former address of the USCF. They moved out in
2006, which is one of the issues I have reased in my complaint.

There is also:

S Goichberg
450 E PROSPECT AVE
MOUNT VERNON, NY 10553
(914) 667-8743

However, that was the address of his father, Sol Goichberg, who died
30 years ago. (I happen to remember that Sol Goichberg died while Bill
was playing in an international tournament in Norway.)

That was also the address of his mother until she died last year. Bill
Goichberg has been staying there recently when he is in New York, but
I do not believe that he intends to make that as his permanent home.

Now, kindly tell me where you found the residence street address (not
a PO box) for Bill Goichberg that he cites in his court papers here?

Sam Sloan