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Old December 15th 09, 01:18 PM posted to rec.games.chess.politics,misc.legal,rec.games.chess.misc,alt.chess
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Default Bradlow vs. Sloan, Motion to Stay Eviction

OMG! Another San Francisco "Doe" action!

samsloan wrote:
SAMUEL H. SLOAN
2550 Webster Street
San Francisco CA 94115

917-507-7226
646-938-0454
917-659-3397

SUPERIOR COURT OF CALIFORNIA

CITY OF SAN FRANCISCO

David A. Bradlow, Chapter 11 Trustee for the
Bankruptcy Estate of Arden Van Upp,

Plaintiff

- against -

Samuel H. Sloan and Does 1 to 10, Inclusive

Defendants

Case No. 09-631354

Motion to Stay Eviction Proceedings and to Dismiss this case.

Samuel H. Sloan, being duly sworn deposes and states:

1. Without proper notice to me, the Trustee in Bankruptcy is seeking
to evict me from 2550 Webster Street, a residence I have maintained
for at least the last 18 years since 1991.

2. I first learned of this when a neighbor informed that the sheriff
had been by seeking to evict me. As I had no knowledge of this, I
looked around and found an envelope addressed to me with no return
address on it. I had not opened the envelope because it has no return
address on it and therefore I had assumed that it was junk mail.

3. When I opened this envelope, I found that it contained a document
entitled “Prejudgment Claim of Right to Possession”.

4. I attach a copy of this envelope as an exhibit. The envelope is
hand addressed, almost certainly in the handwriting of the trustee,
David A. Bradlow. I request that a sample of his handwriting be taken
to determine whether he wrote my name and address on the envelope and,
if he did not do it, who did.

5. I have resided on the top floor of 2550 Webster Street since at
least 1991. I maintain the house, pay the PG&E Gas and Electric Bills
and I also help Arden Van Upp, the owner, with her legal matters. I
have known her since 1966.

6. I filed a motion last month in federal bankruptcy court, In Re
Arden Van Upp, Case No. 09-31932 TEC, to remove David Bradlow as
trustee and dismiss this bankruptcy case. My motion is available on
PACER and is still pending. It has not been acted upon by the judge.
Even if it is denied, Mr. Bradlow's days as trustee are numbered. Mark
my words, by two weeks from today, David Bradlow will not be the
trustee any more. I will not tell you how this will happen, but it
will happen.

7. The Trustee, David A. Bradlow, is a con man and a scam artist. He
is desperately trying to sell the house at 2550 Webster Street so he
can get a cut on the sale price. The house is appraised at $7.5
million. The trustee wants to sell the house for only $2.55 million to
one of his cronies by the name of Patrick A. Kenealy, who is
represented by Caryl Welborn, 220 Montgomery Street, Suite 417, San
Francisco, California 94104, Tel: (415) 513-3606; Fax: (415) 78201415,
Email:
.

8. Anybody can see that this property at 2550 Webster Street is worth
vastly more than $2.55 million. The house is a city, state and
nationally protected landmark and heritage. It is on the tourist maps
of San Francisco. A gaggle of tourists walk by the house every day and
take pictures of it.

9. The trustee, David A. Bradlow, is trying to steal the house, pure
and simple. In fact, there is an article about this in the San
Francisco Examiner for September 20, 2009 entitled “a steal” about the
obvious corruption on the part of the trustee for wanting to sell the
house for such a ridiculously low amount.

10. The selling price set by Mr. Bradlow is so low that not only will
there be no money left after the sale, but the debtor will be even
more deeply in debt. There will not be enough money left to pay the
mortgage after all the expenses, plus Mr. Bradlow's cut and fee (which
he has left out of his calculations submitted to the court). This will
enable him to go after the other properties owned by the debtor, so
that he can steal those properties too.

11. In addition to stealing the house by selling it for a ridiculously
low price and taking a cut and a fee, Mr. Bradlow is churning legal
fees. His team of lawyers including Elizabeth Berke-Dreyfus of the
friendly law firm of Wendel, Rosen, Black and Dean, 1111 Broadway,
24th Floor, Oakland CA 94607, is charging the debtor $425 an hour to
evict me!!! Imagine that I am such an important person that they need
to pay $425 an hour to get rid of me. Elizabeth Berke-Dreyfus has made
numerous court appearances in this eviction case and of course she
charges $425 an hour to take the BART over from Oakland too. Do not
worry. She will get paid. The crooked trustee has already taken
$100,000 out of the debtor's bank accounts and you can be sure that he
will not return even one penny of it. All of it will be used up in
“legal fees” to evict Sam Sloan, plus other ridiculous boondoggles
such as putting plastic sheets on top of the house, which the trustee
has done twice in the last few weeks and is the most ridiculous and
absurd thing imaginable.

12. The reason the trustee, David A. Bradlow, is so desperately trying
to have me evicted is because I am the person who is stopping him from
selling the house and reaping these vast profits he will get from
stealing the house. He has a hard time selling the house with me in
it. Meanwhile, due slightly to my efforts, we are close to re-
financing the house. Mr. Bradlow wants to sell the house to his friend
on December 22, 2009. That is the date he has set. He wants me to be
evicted before then. He has set it up so that it is a foregone
conclusion that his friend, Mr. Patrick Kenealy, will get the house.
The restrictions on anybody else who tries to bid against Mr. Kenealy
are so onerous that nobody can make it. To begin with, any bidder must
put up a non-refundable cash deposit in advance of $78,000. He must
also prove that he has the in excess of $2.55 million in the bank.
Even if he meets all these requirements, the trustee can unilaterally
reject any bidder and award the house to his friend anyway.

10. I fully intend to seek criminal indictments against Mr. Bradlow
and to put him in prison for a long time. I am not kidding either. Mr.
Bradlow needs to serve a long prison sentence, even though he will
have to be kept protected in the gay tank.

11. Please understand that I am not against Mr. Bradlow just because
he is a flaming faggot. I am a long time supporter of gay rights. I
encourage them to come out and do whatever they feel like doing with
each other. I hope they have a good time, too. However, I do not want
gays coming into my house and especially not into my bedroom. Mr.
Bradlow is trying to steal my home which I have maintained for the
last 18 years. It is not because Mr. Bradlow is a queer that I object,
and, after all, this is San Francisco. It is because David A. Bradlow
is a thief.

WHEREFORE, for all of the reasons set forth above, the order of
eviction should be vacated, these proceedings should be stayed, and
this case should be dismissed.


_______________________
Samuel H. Sloan

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