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Newly Revealed Affidavit by William Goichberg



 
 
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  #1  
Old October 3rd 08, 05:39 AM posted to rec.games.chess.politics,rec.games.chess.misc,alt.chess,rec.games.chess.computer,misc.legal
samsloan
external usenet poster
 
Posts: 13,525
Default Newly Revealed Affidavit by William Goichberg

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

  #2  
Old October 3rd 08, 08:10 PM posted to rec.games.chess.politics,rec.games.chess.misc,alt.chess,rec.games.chess.computer,misc.legal
none
external usenet poster
 
Posts: 2,022
Default Newly Revealed Affidavit by William Goichberg

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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