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Old December 10th 04, 11:51 AM
Spam Scone
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Default Reply to Affidavit of Bill Goichberg

Sam Sloan wrote:
(blather snipped)

5. The opponents have said that I failed to serve all the defendants
personally. However it would have been impossible to do so. Two of

defendants were in Spain for the World Chess Olympiad although they
may have arrived back in the US before the court signed the order.
However, look at the title page of Chess Life which I attach. Three
defendants list their address as being the New Windsor address of the
USCF. Therefore, by serving the office, I have served them. One
defendant, Elizabeth Shaughnessy, has no address listed at all,

for an e-mail address.

Is this the "dog ate my homework" school of pleading?

6. I originally filed in this court along with a request for a waiver
of filing fees on Monday November 8, 2004. The following day the

called and indicated that the request would not be granted. Since I
knew that the defendants were desperately trying to move the money to
Tennessee, I was trying to get a freeze on the bank account without
prior notice to them. When I found out that this plan would not be
successful, I moved on to Plan B, which was to serve everybody right

7. On Wednesday, November 10, 2004 I arranged for a copy of all the
papers to be served on everybody I could think of who might want to
participate in this case, including all potential opponents. I had 27
people served in all. Here is a partial list:

Beatriz Marinello
Tim Hanke
Stephen Shutt
Elizabeth Shaughnessy
Randy Bauer
Bill Goichberg
Kenneth M. Chadwell
Harry Sabine
Leroy Dubeck
Steve Doyle
Harold Winston
Don Schultz
Frank Brady
Harold Dondis
Michael Atkins
Steve Immitt
Glenn Petersen
John Donaldson, Mechanics Institute Chess Club
Mike Goodall
Jerry Hanken
Kathleen Merz
Larry Evans

8. Each of these persons were mailed four documents on November 10,
2004. These were the Petition, the Affidavit in Support, the
Memorandum of Law and the Proposed Order to Show Cause. Many of these
were received by Friday November 12, 2004 and all of them would have
been received by Monday, November 15, 2004. Thus, by November 16,

when this court signed the order to show cause, all of the defendants
had received a complete set of papers. None of these mailings were
returned by the post office and all of them had return addresses.

Yes, but it wasn't issued by the court at the time you sent out your
silly mailing.

9. The order to show cause was signed on November 16, 2004. I

it by Fax late the same day. The following morning, November 17,

all of the defendants were served by both certified mail and regular
mail. In addition, they were all served by e-mail as I knew the email
addresses of all of them. The papers were also posted on the Chess
Politics Newsgroup which all of them read

on my own website at

The order said "personal service". It did not say "nail and mail".
(snip remaining legal nonsense)

What a waste of a notary's stamp!

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Old December 10th 04, 03:16 PM
Doctor SBD
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Mr. Turton said:

The order said "personal service". It did not say "nail and mail".
(snip remaining legal nonsense)

Now Sam (call me Ismail) thinks he is Luther and is nailing his theses to the
churchhouse door?

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Old December 10th 04, 03:48 PM
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"Now Sam (call me Ismail) thinks he is Luther and is nailing his theses to the
churchhouse door?" -- SBD

Sam Sloan should stick to the legal issues. His name-calling is deplorable.
Regardless of the outcome of this lawsuit, the personal ambitions of a few
people (and by now it's becoming clear who they are) should not be allowed to
trump what's best for American chess.

It was obvious from the start that the move to Crossville was a tragic
decision. This board has stonewalled all legitimate questions, but let's hope
it has the courage to reconsider the options at its next meeting in Florida.

The only thing worse than making a mistake is failing to correct it while
there's still time.

__________________________________________________ ______________
"FIDE has made its decision. Players who refuse to be drug tested will not be
able to play chess." -- Dr. Press, co-founder of the FIDE Medical Commission.
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