Reply
 
LinkBack Thread Tools Display Modes
  #1   Report Post  
Old March 21st 05, 02:01 AM
Sam Sloan
 
Posts: n/a
Default USCF Cross-Motion to Dismiss

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
__________________________________________

SAM SLOAN,

NOTICE OF CROSS

MOTION TO

DISMISS PETITION

Petitioner

Index No. 2004-7739
-against-

BEATRIZ MARINELLO, TIM HANKE, STEPHEN
SHUTT, ELIZABETH SHAUGHNESSY, RANDY BAUER,
BILL GOICHBERG, KENNETH M. CHADWELL, AND
UNITED STATES CHESS FEDERATION,

Assigned Judge:

Lawrence I. Horowitz,JSC
Respondents.
__________________________________________


PLEASE TAKE NOTICE that, upon the annexed affirmation of
Michael J. Matsler dated November 29, 2004, the affidavit of Bill
Goichberg sworn to November 24, 2004, the affidavit of Dr. Leroy
Dubeck sworn to November 24, 2004, the affidavit of Michael Reis sworn
to November 22, 2004, and the exhibits thereto, the undersigned
counsel representing the United States of America Chess Federation
("USCF") and the other respondents will cross-move this Court, at the
courthouse located at 255-275 Main Street, Goshen, New York on
December 10, 2004 at 9:00 a.m. or as soon thereafter as counsel may be
heard, for an order dismissing the petition, and denying petitioner's
motion for a preliminary injunction and order of attachment, pursuant
to CPLR 404(a) and 3211 on the grounds that 1) this Court lacks
personal jurisdiction over the respondents by reason of petitioner's
failure to effectuate lawful service of process; 2) this Court lacks
personal jurisdiction over the individual respondents other than Bill
Goichberg as non-domiciliaries under CPLR 302; and
3) petitioner fails ID state a claim or cause of action for which this
Court can grant relief ; and other relief as the Court deems proper,
together with an award of attorneys fees and costs pursuant to Part
137 of the Rules of the Chief Administrator of the Courts.

Dated: November 29, 2004
New Windsor, NY

Rider, Weiner &
Frankel, P.C.
Attorney for
Respondents
655 Little Britain
Road
New Windsor, NY 12553
(845)562-9100

By:
_____________________
Michael J.
Matsler

TO: Sam Sloan
Petitioner
331 Beach 32nd Street, Apartment 19K
Far Rockaway, NY 11691


RIDER, WEINER & FRANKEL, PC.
F O. BOX 2280 NEWBURGH, N. Y 12550 (845) 562-9100


Reply
Thread Tools
Display Modes

Posting Rules

Smilies are On
[IMG] code is Off
HTML code is Off
Trackbacks are On
Pingbacks are On
Refbacks are On


Similar Threads
Thread Thread Starter Forum Replies Last Post
Reply to Affidavit of Leroy Dubeck Sam Sloan rec.games.chess.misc (Chess General) 22 March 29th 05 04:44 PM
Reply to Affidavit of Leroy Dubeck Sam Sloan rec.games.chess.politics (Chess Politics) 51 March 29th 05 04:44 PM
More Fraud Don't Bother Me ASCACHESS rec.games.chess.politics (Chess Politics) 51 August 23rd 04 06:07 PM
Message from Yasser Seirawan about drug testing Tim Hanke rec.games.chess.politics (Chess Politics) 60 December 17th 03 07:04 PM
Peterson Lawsuit Sam Sloan rec.games.chess.misc (Chess General) 4 August 26th 03 01:52 PM


All times are GMT +1. The time now is 04:44 AM.

Powered by vBulletin® Copyright ©2000 - 2019, Jelsoft Enterprises Ltd.
Copyright 2004-2019 ChessBanter.
The comments are property of their posters.
 

About Us

"It's about Chess"

 

Copyright © 2017