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Old September 30th 08, 05:36 PM posted to rec.games.chess.politics,rec.games.chess.misc,alt.chess,rec.games.chess.computer,misc.legal
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Default Surprising Call From Jim Killion Representing Susan Polgar

I just received a surprising call at 11:53 AM from Jim Killion in
Texas, who represents Susan Polgar.

He asked me to agree to withdraw my counterclaim against Susan Polgar.

When I refused to agree, he said that he would file a motion to
dismiss my claim on the grounds that it fails to state a claim on
which relief would be granted.

He then asked me to come to Texas at my expense for a deposition.

I said that I would be willing to be deposed at any time in New York
but I would not be able to come to Texas especially at my own expense
for a deposition.

He said that in that case he will file a motion with the federal court
to REQUIRE me to travel to Texas for a deposition.

I told him to go ahead.

I find it noteworthy that his client, Susan Polgar, who lives in
Texas, is not willing to submit to a deposition in Texas, but he
believes that the federal court will require me to come to Texas for a
deposition.

Sam Sloan
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Old September 30th 08, 05:42 PM posted to rec.games.chess.politics,rec.games.chess.misc,alt.chess,rec.games.chess.computer,misc.legal
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Default Surprising Call From Jim Killion Representing Susan Polgar

samsloan wrote:
I just received a surprising call at 11:53 AM from Jim Killion in
Texas, who represents Susan Polgar.

He asked me to agree to withdraw my counterclaim against Susan Polgar.

When I refused to agree, he said that he would file a motion to
dismiss my claim on the grounds that it fails to state a claim on
which relief would be granted.

He then asked me to come to Texas at my expense for a deposition.

I said that I would be willing to be deposed at any time in New York
but I would not be able to come to Texas especially at my own expense
for a deposition.

He said that in that case he will file a motion with the federal court
to REQUIRE me to travel to Texas for a deposition.

I told him to go ahead.

I find it noteworthy that his client, Susan Polgar, who lives in
Texas, is not willing to submit to a deposition in Texas, but he
believes that the federal court will require me to come to Texas for a
deposition.

Sam Sloan


It is likely that the Federal court will require that he depose you in
NYC at his client's expense. Let him make his motion to dismiss. I
suspect your claim for defamation will survive.
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Old October 1st 08, 05:09 AM posted to rec.games.chess.politics,rec.games.chess.misc,alt.chess,rec.games.chess.computer,misc.legal
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Default Surprising Call From Jim Killion Representing Susan Polgar

On Sep 30, 11:36*am, samsloan wrote:

I find it noteworthy that his client, Susan Polgar, who lives in
Texas, is not willing to submit to a deposition in Texas, but he
believes that the federal court will require me to come to Texas for a
deposition.

Sam Sloan


She can't afford a deposition. Her hubby's bankrupt, remember?
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