SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
_________________________________________
SAMUEL H. SLOAN,
Petitioner,
Index
No. 401051/2010
-against-
CHRIS EDES
Respondents.
_________________________________________
MOTION TO JOIN WARREN REDLICH AS PARTY DEFENDANT AND FOR SANCTIONS
AGAINST CHRIS EDES AND WARREN REDLICH
________________________________________________________________________
Samuel H. Sloan, the petitioner herein, being duly sworn, states:
1. This proceeding is brought under Election Law Sections 16-100 and 16-102.
2. I hereby move this court to join Warren Redlich as a party
defendant and for sanctions against Chris Edes, now Former Chairman of
the New York State Libertarian Party, and Warren Redlich. Warren
Redlich is a practicing attorney at law. His primary practice is in
the Albany area where he defends traffic tickets, primarily DWI
(Driving while Intoxicated) and speeding tickets.
3. Warren Redlich stated in an email that he advised Respondent Chris
Edes, now former Chairman of the Libertarian Party of the State of New
York, to ignore the order of this court requiring him to give me the
membership list of the New York Libertarian Party, because it was not
“properly served”. Here is a direct quote:
“As a legal matter, Sam did not serve Edes properly, so Edes did not
have to respond.”
4. Mark Axinn, the new chairman of the Libertarian Party of New York
State admits in his motion papers that Chris Edes was notified that
the judge had signed the order on 2:36 PM, which just minutes after
the order was signed. In fact, I emailed Chris Edes using the
computers in the jury room just next door to the court room that the
order had been signed. I also emailed this information to all five
Libertarian Party email and discussion groups and I emailed it to
Warren Redlich personally. I then scanned and emailed the signed order
in PDF Format to all parties and email discussion groups just about
one hour later. This news also appeared on the Albany Times Union
website just a few minutes after the judge signed the order and Jeff
Russell, former Chairman of the New York Libertarian Party, posted the
link to the Times Union story on all the Libertarian Party email
groups. All of this happened before 4:00 PM that day.
5. In addition, I personally served Chris Edes with the order the
following morning in Albany before the Convention was about to begin.
Chris Edes responded that he was refusing to give me the list. He
stated that Mark Axinn had told him that the court order was expired
and was not valid. I asked Mark Axinn about this and he replied that
he had told Chris Edes no such thing.
6. To this day, Chris Edes still had not given me the mailing list.
Thus, he is in contempt of court. It is reported in the Albany Times
Union and in the Yonkers Tribune that I lost the nomination by a vote
or 27 to 17. Thus, a switch of only 6 votes would have resulted in my
getting the nomination. Had I been allowed to mail my campaign
literature to all 280 members of the New York Libertarian Party, it is
obvious that I would have gotten the 6 or 12 votes to receive the
nomination.
7. Warren Redlich states in a posting that he got the nomination
because Eric Sundwall contacted the membership, Here is a direct
quote:
“This is not a knock on Chris, but I don't see where he did anything
to favor me over anyone else. Eric Sundwall is the one who networked
with LP members across the state to get support for my candidacy. Sam
and his campaign team failed to make the same effort or failed to
persuade.”
8. However Eric Sundwall had the membership list. Eric Sundwall was
the Chairman of the New York Libertarian Party last year. He was also
the campaign manager for Warren Redlich. Thus, he had the complete
list and could lock up the convention before it started. This explains
why Warren Redlich did no campaigning and stated in Internet postings
that he had been assured of the Libertarian Party nomination.
9. Another candidate who tried to run was Kristin Davis, “The
Manhattan Madam”. She states that she did not attend the convention
because insiders told her that the result had already been decided.
Here is a quote:
> From: Kristin Davis <kris...@kristindavis2010.com>
> Date: April 29, 2010 2:23:33 PM EDT
> Subject: RE: Internal Libertarian Feuding while the World is being destroyed
>
> Thank you for this very honest and articulate email. I don't particularly
> care to be involved in a discussion with the LPNY at this time.
>
> However, I do want to thank you for distributing the material (didn't know
> you did that) and for being proactive and realizing why, and how, the
> communication had been stifled.
>
> It is unfortunate that the LPNY is not democratic. I attended private and
> public meetings with the LPNY where Redlich did not attend. I have lent my
> name to the cause because I am a Libertarian and garnered much press for the
> party.
>
> Only to receive some internal communication from party insiders saying the
> nomination was already pre-determined. Up until the night before we tried to
> resolve this but NO ONE had any clear answers. It became apparent that I was
> only being used for publicity purposes.
>
> I am running regardless under a new party I create that will be democratic
> and advocate for personal freedom and reform. I will get the 50,000 votes
> (and then some) while Redlich only gets a minimal amount. The only way he
> can get his name in the paper is to call me a whore which is preposterous.
>
> Warm Regards,
> Kristin Davis
10. In fact, Warren Redlich did no campaigning other than a speech to
the Manhattan Libertarian Party where he read a list that is supposed
to be his idea of a joke of ten reasons why he is not qualified to be
governor which are, among others (1) I have never been caught with a
prostitute, (2) I have never been convicted of a felony (3) I have
never been married to more than one woman at the same time, and so on.
This list is also on his website and on youtube.com
11. Warren Redlich did not show up at a meetup for the candidates
scheduled for April 11, 2010 by Scott Lieberman, a member of the
National Committee nor did he appear at the debates scheduled for
April 12, 2010. He stated that he did not come to those events because
his nomination as Libertarian Party candidate had already been
assured.
12. Meanwhile, I spent more than $800 of my own personal money on my
campaign for this nomination, which is the most money that anybody has
ever spent for a Libertarian Party nomination.
13. As an attorney Warren Redlich is required to advise his clients to
obey court orders. Chris Edes did not obey the order of this court
because he still to this day has not given me the membership list.
Warren Redlich should be sanctioned as an attorney because he told
Chris Edes to ignore the court order. Accordingly, I am asking this
court to enjoin Warren Redlich from running as a Libertarian Party
Candidate.
14. In spite of having been personally served with the court order,
Chris Edes ignored the order and chaired the meeting as though nothing
had happened. He should have disqualified himself from chairing the
meeting because he was in contempt of an order of the court. He also
announced the results of the vote count.
WHEREFORE, for all of the reasons set forth above this court should
join Warren Redlich as a party defendant and impost sanctions against
Chris Edes, now Former Chairman of the New York State Libertarian
Party, and Warren Redlich and this court should and grant such other
and further relief as may be just and equitable.
________________________
Samuel H. Sloan
Sworn to Before me this 30th
Day of April 2010
_________________________
NOTARY PUBLIC
________________________
Samuel H. Sloan
1664 Davidson Avenue, Apt. 1B
Bronx NY 10453
917-507-7226
917-659-3397
samsl...@gmail.com
STATE OF NEW YORK )
ss:
COUNTY OF NEW YORK )
VERIFICATION
I, the undersigned, the petitioner named in the foregoing petition,
being duly sworn, says:
I have read the foregoing petition subscribed by me and know the
contents thereof and the same is true of my own knowledge, except as
to those matters herein stated to be alleged upon information and
belief and as to those matters I believe it to be true.
__________________________________
Signature of
Petitioner
On the 30th Day of April, 2010 before me personally came Samuel H.
Sloan to me known to be the person described herein and who executed
the foregoing instrument. Such person duly swore to such instrument
before me and duly acknowledged that he executed the same.
_____________________________
NOTARY PUBLIC
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