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Old December 30th 05, 09:37 PM posted to rec.games.chess.politics
Sam Sloan
 
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Default Sloan vs. Rudiano, Republican Party, 04 Civ. 2791, Proposed Order to Show Cause

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
__________________________________________________ _____________


SAMUEL H. SLOAN,


Plaintiff,


Order to Show Cause


No. 04 Civ. 2791 (DGT)


-against-


DIANE HASLETT RUDIANO, GLADYS PEMBERTON, AARON
MASLOW, HY SINGER, KING'S COUNTY REPUBLICAN PARTY,
ISABELLA JEFFERSON, BROOKLYN REPUBLICANS UNITED
FOR NEW LEADERSHIP, NEW YORK REPUBLICAN STATE
COMMITTEE, SANDY TREADWELL, PETER S. KOSINSKI, and
CAROL BERMAN, NEIL W. KELLERHER, HELENA MOSES
DONOHUE and EVELYN J. ACQUILA, Commissioners of Elections,
Constituting the New York State Board of Elections, and New York
City Commissioners of Elections NERO GRAHAM, FREDERIC M.
UMANE, WEYMAN A. CAREY, MICHAEL J. CILMI, MARK B.
HERMAN, DOUGLAS A. KELLNER, TERRENCE C. O'CONNOR,
NANCY MOTTOLA-SCHACHER, STEPHAN H. WEINER,


Defendants.
__________________________________________________ _____________


UPON READING AND FILING the annexed affidavit of Samuel H. Sloan and
the exhibits attached thereto and the summons and complaint and upon
all of the papers and proceeding had herein, let the defendants show
cause at the US Courthouse at 225 Cadman Plaza East, Brooklyn, New
York 11201 on the ____ day of July, 2004 at _____ o'clock in courtroom
________ why an order should not be made granting a temporary
restraining order and a preliminary and permanent injunction providing
the following:


1. A preliminary and permanent injunction requiring that the
Defendants grant to Plaintiff a Wilson-Pakula allowing him to petition
for election as an Republican Party Candidate or an order declaring
that as a non-enrolled voter Plaintiff does not need a Wilson-Pakula
to run as an Republican Party candidate.


2. A preliminary and permanent injunction requiring that the name of
the Plaintiff be placed on the primary ballot as a candidate for
Congress for the Tenth Congressional District (which means, if the
election is uncontested as is presently the case that Plaintiff will
be the Republican Party candidate in the general election in
November).


3. A preliminary and permanent injunction and a declaratory judgment
declaring that all petitions listing Isabella Jefferson as the
official candidate of the King's County Republican Party be declared
invalid, null and void in entirety.


4. A preliminary and permanent injunction requiring that the name of
the Plaintiff be placed on the ballot in the General Election in
November as a candidate for Congress from the 10th Congressional
District.


5. A preliminary and permanent injunction enjoining Diane Haslett
Rudiano from acting as the Chief Clerk of the King's County Board of
Elections and as the Secretary of the King's County Republican Party
or any other position of that party on the grounds of conflict of
interest in that she has used those multiple positions to stop
Plaintiff from becoming a candidate for and being elected to United
States Congress.


6. Such other and further relief as may be just and equitable.


________________________
U.S.D.J.

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