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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: 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 SUPPLEMENTAL AFFIDAVIT OF "SUSAN" POLGAR, JOEL CHANNING, WILLIAM GOICHBERG WILLIAM GOICHBERG THE UNITED STATES CHESS FEDERATION, BILL HALL, HERBERT Document Filed Electronically RODNEY VAUGHN, GREGORY ALEXANDER, FRANK NIRO, GRANT PERKS, WILLIAM BROCK, RANDALL HOUGH, RANDY BAUER, JIM BERRY, TEXAS TECH UNIVERSITY and UNITED STATES OF AMERICA, Defendants _________________________________________x WILLIAM GOICHBERG, being duly sworn, deposes and states: 1. This supplemental affidavit responds to plaintiff s "Affidavit in Opposition to Motion to Dismiss on Diversity Issue" filed on February 4, 2008. Mr. Sloan's affidavit is simply wrong when he states, among other things, that my residence at 2084 Route 94, Salisbury Mills, New York 12577 does not exist. To the contrary, it does indeed exist. 2. I have attached as Exhibit A a Certified Deed of my residence at 2084 Route 94, Salisbury Mills, New York 12577. The Deed has been certified by the Clerk of Orange County, New York. 3. I have attached as Exhibit B various public property records pertaining to my residence at 2084 Route 94, Salisbury Mills, New York 12577, which identify me as the owner of said property. The attached records are maintained by Orange County and accessible to the public at http://propertydata.orangecountygov.com . Log in, select "Blooming Grove" for municipality and enter "Goichberg" for last name. For more property information click on the numbers 3-1-9 under'Tax ID." 4. As I affirmed in my first affidavit, I currently reside at 2084 Route 94, Salisbury Mills, New York 12577. This is my home, my domicile and my permanent place of residence. 5. I have never had a mailbox at this residence. Instead, I maintain a post office box in Salisbury Mills, New York. I have maintained this post office box since 1991. 6. I do travel occasionally for business and pleasure, but I always intend to and do return to my domicile at 2084 Route 94, Salisbury Mills, New York 12577. 7. During calendar year 2007, I made one business trip to the western part of the United States, which included directing chess tournaments in California and Nevada. 8. I do own a second home in Mt. Vernon, New York. I have owned the Mt. Vernon, New York home since 2002. 9. During 2008, I plan to attend and direct various chess tournaments in New Jersey, Massachusetts, Connecticut, New York, Illinois, Ohio, Pennsylvania and Texas. Even though I will be traveling, I intend to and will return to my domicile at 2084 Route 94, Salisbury Mills, New York 12577. ______________________ WILLIAM GOICHBERG Sworn to and subscribed before me this 11 day of February, 2008. ___________________ GEORGE W. BROWN Commissioner of Deeds In and For the City of Mount Vernon Commission Expires Dec. 31, 2008 |
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On Oct 3, 12:39*am, samsloan wrote:
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: 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 * * * * * * SUPPLEMENTAL AFFIDAVIT OF "SUSAN" POLGAR, JOEL CHANNING, * * * * * * * * * * * * * * * * WILLIAM GOICHBERG WILLIAM GOICHBERG * * * *THE UNITED STATES CHESS FEDERATION, BILL HALL, HERBERT * * * * * * * * * *Document Filed Electronically RODNEY VAUGHN, GREGORY ALEXANDER, FRANK NIRO, GRANT PERKS, WILLIAM BROCK, RANDALL HOUGH, RANDY BAUER, JIM BERRY, TEXAS TECH UNIVERSITY and UNITED STATES OF AMERICA, * * * * * * * * * * * * * * * * Defendants *_________________________________________x * * * * WILLIAM GOICHBERG, being duly sworn, deposes and states: 1. This supplemental affidavit responds to plaintiff s "Affidavit in Opposition to Motion to Dismiss on Diversity Issue" filed on February 4, 2008. Mr. Sloan's affidavit is simply wrong when he states, among other things, that my residence at 2084 Route 94, Salisbury Mills, New York 12577 does not exist. To the contrary, it does indeed exist. 2. I have attached as Exhibit A a Certified Deed of my residence at 2084 Route 94, Salisbury Mills, New York 12577. The Deed has been certified by the Clerk of Orange County, New York. 3. I have attached as Exhibit B various public property records pertaining to my residence at 2084 Route 94, Salisbury Mills, New York 12577, which identify me as the owner of said property. The attached records are maintained by Orange County and accessible to the public athttp://propertydata.orangecountygov.com. Log in, select "Blooming Grove" for municipality and enter "Goichberg" for last name. For more property information click on the numbers 3-1-9 under'Tax ID." 4. As I affirmed in my first affidavit, I currently reside at 2084 Route 94, Salisbury Mills, New York 12577. This is my home, my domicile and my permanent place of residence. 5. I have never had a mailbox at this residence. Instead, I maintain a post office box in Salisbury Mills, New York. I have maintained this post office box since 1991. 6. I do travel occasionally for business and pleasure, but I always intend to and do return to my domicile at 2084 Route 94, Salisbury Mills, New York 12577. 7. During calendar year 2007, I made one business trip to the western part of the United States, which included directing chess tournaments in California and Nevada. 8. I do own a second home in Mt. Vernon, New York. I have owned the Mt. Vernon, New York home since 2002. 9. During 2008, I plan to attend and direct various chess tournaments in New Jersey, Massachusetts, Connecticut, New York, Illinois, Ohio, Pennsylvania and Texas. Even though I will be traveling, I intend to and will return to my domicile at 2084 Route 94, Salisbury Mills, New York 12577. * * * * * * * * * * * * * * * * * * * * * * * * ______________________ * * * * * * * * * * * * * * * * * * * * * * * * *WILLIAM GOICHBERG Sworn to and subscribed before me this 11 day of February, 2008. *___________________ GEORGE W. BROWN Commissioner of Deeds In and For the City of Mount Vernon Commission Expires Dec. 31, 2008 Wow Sam you really fried his balls. |
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