Petition to Validate Republican Party Designating Petitions

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_______________________________________________________________

SAMUEL H. SLOAN,

Petitioner,

-against-

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, Commissioners of Elections of the City of New York, constituting the Board of Elections in the City of New York and BIBI S. KHAN, THEODORE ALATSAS, KHOURSHED CHOWDHURY, DIANE HASLETT RUDIANO, GLADYS PEMBERTON, AARON MASLOW, LORI MASLOW, HY SINGER, HARVEY R. CLARKE, KING'S COUNTY REPUBLICAN PARTY,

Respondents.
________________________________________________________________________

PETITION IN SUPPORT OF MOTION TO VALIDATE DESIGNATING PETITIONS

________________________________________________________________________

TO THE SUPREME COURT OF THE STATE OF NEW YORK

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. Petitioner is a candidate for election to the United States Congress from the Tenth Congressional District. The incumbent is Edolphus Towns. Petitioner is a duly qualified voter residing at 920 Belmont Avenue, Brooklyn NY 11208, which is within the Tenth Congressional District.

3. Designating Petitions naming Petitioner as a candidate for United States Congress were filed with the New York City Board of Elections on July 15, 2004. On August 4, 2004, Petitioner was ruled off the ballot. A copy of the notice is annexed hereto as Exhibit A. By statute, Petitioner has three business days to file a validating petition with the Supreme Court of the State of New York. Thus, Monday, August 9, 2004, is the last day to file. A copy of the Election Calendar is annexed hereto as Exhibit B.

4. On July 19, 2004, General Objections to the petitions of Petitioner were filed by Bibi S. Khan of 100 Hill Street, Brooklyn NY 11208, represented by Theodore Alatsas, who is counsel to the Kinges County Republican Party. A copy of this general objection is annexed hereto as Exhibit C.

5. On July 26, 2004, Specific Objections to Petitioner's petitions were filed by Bibi S. Khan of 100 Hill Street, Brooklyn NY 11208, also represented by Theodore Alatsas. A copy of the cover sheet of these specific objections is annexed hereto as Exhibit D.

6. On August 3, 2004, Petitioner filed objections to the specific objections of Bibi S. Khan. A copy of the objections to her objections is annexed hereto as Exhibit F. The objections to her objections included the fact that her voting address is false and fraudulent. Bibi S. Khan is registered to vote at 100 Hill Street, Brooklyn NY 11208. However, this is fraudulent, as she does not reside there and has not resided there since at least 1997. This makes Bibi S. Khan guilty of a Class E felony. This means that her voter registration is not valid. Because her voter registration is not valid, she is not registered to vote. Because she is not registered to vote, she lacks standing to file objections to my petitions. Since she is the only person who filed objections to my petitions, the Board of Elections cannot declare my petitions invalid. Bibi S. Khan must go directly to jail and cannot collect $200. Two hundred dollars is the amount she has been getting for serving as a poll watcher for the Republican Party on election days.

7. More importantly, Diane Haslett Rudiano, who is the Chief Clerk of the King's County Board of Elections, is registered to vote at a fake and fraudulent address. She is registered to vote since 1988 at 258 Schenck Avenue, Brooklyn NY 11207. This is in East New York near the Van Siclen Station of the A-Train. There are almost no white people living in that neighborhood and it should have long been obvious that an Upper-Crust White Lady like Diane Rudiano could not be living there in that somewhat run-down modest frame house in a black neighborhood. The actual resident of that address is Theresa McGovern, who is 98 years old and who purchased that house on November 20, 1952. She apparently has an arrangement whereby she receives mail at that address for Diane Haslett Rudiano. However, this is not legal. A person must be registered to vote at the place at which they actually reside. It cannot be just a place of business or work or a friend's address. It must be an actual residence.

8. Diano Rudiano is the Secretary of the King's County Republican Party. She has been conducting a campaign against Petitioner since May 5, 2004 in her dual capacities of being both the Secretary of the King's County Republican Party and the Chief Clerk of the King's County Board of Elections, to block the candidacy of Petitioner for United States Congress. Because she is registered to vote at a fraudulent address, she is not properly registered to vote. Because of that, she was not validly elected and serving as District Leader of District 54 of the King's County Republican Party. Because she is not validly serving as a district leader, this means that her acts of speaking against Petitioner as a candidate, her calls to all of the other district leaders, her taking of several telephone votes to stop Petitioner from being the candidate, the clerk's certificates she signed in her capacity of being the Chief Clerk of the King's County Board of Elections, all of this is invalid because she obtained the position of being Chief Clerk of the King's County Board of Elections as a patronage job as part of a deal where half of such jobs are given to Republicans and the other half are given to Democrats.

9. Since Diane Haslett Rudiano is registered to vote at a fake address she must be removed from her positions of both the Chief Clerk of the King's County Board of Elections and the Secretary of the King's County Republican Party and the District Leader of District 54 of King's County Republican Party. She also must go directly to jail. I have made a complaint to the King's County District Attorney about the fact that Diane Haslett Rudiano is holding public office on a false and fraudulent basis by being registered to vote and voting since 1988 at an address where she does not actually reside and she is using her position to block me from running as a candidate for US Congress. A copy of a letter from the Brooklyn DA's Office is annexed hereto as Exhibit E.

10. Petitioner is a registered voter with no party enrollment. Petitioner is known as a blank voter, which means that he is registered to vote but is not a member of any recognized political party. However, on or about April 30, 2004, Petitioner handed in a change of party enrollment form for the purpose of enrolling as a Republican. This change in enrollment will not be effective until after the November elections.

11. At a meeting of the Executive Committee of the King's County Republican Party on May 5, 2004, Petitioner was nominated and seconded as a candidate for election to the United States Congress for the Tenth Congressional District. A quorum was present and the assembled body voted overwhelming in favor of Petitioner, especially since there was no other previously announced candidate for this office. At the conclusion of that meeting, Petitioner was informed by Aaron Maslow, the Chairman of the Meeting, that he had been granted a Wilson-Pakula, which gave him the right to petition for signatures and to run for election as a Republican. However, Diane Haslett Rudiano, who occupied multiple positions of being secretary and minute taker of the meeting plus is the Chief Clerk of the King's County Board of Elections, had said that she wanted to take a weighted telephone vote of the district leaders to determine who the candidate would be. During the meeting, Mariana Blume, a district leader, had suddenly and to everyone's surprise said that she would like to be a candidate for US Congress. Because of this last moment announcement from a long-established Republican Party member, it was decided to hold a telephone vote on who would be the candidate. It was decided that the telephone vote would be taken and counted by Diane Haslett Rudiano and would be concluded by Wednesday, May 12, 2004.

12. The Petitioner, Samuel H. Sloan, won the subsequent telephone vote by a vote of 972.5 to 444. The only person who voted for Mariana Blume was Mariana Blume herself. Her district has 888 voters who are enrolled as Republicans. As the female district leader, she was entitled to vote half of these votes. She voted those 444 votes for herself, but nobody else voted for her, and so the Petitioner, Samuel H. Sloan, won the nomination.

13. At a Republican Party meeting at "Giando of the Water" on the evening of May 12, 2004, with more than 200 Republican Party members present including almost all of the party's district leaders and candidates, Petitioner (along with his wife and daughter) were introduced to the assembled crowd as the Republican Party Candidate for the Tenth Congressional District of Brooklyn. Diane Haslett Rudiano was present at the meeting and made no objection. Mariana Blume tried to object was but ignored by the chairman of the meeting. Later at the meeting, Mariana Blume complained to Petitioner that they were trying to find a black woman, any black woman, to run for Congress rather than either of them.

14. In spite of the fact that the Petitioner Samuel H. Sloan was the duly nominated candidate of the Republican Party for election to the Tenth Congressional District of Brooklyn, Diane Haslett Rudiano has ever since led a fight to stop Petitioner from appearing on the ballot. This is a conflict of interest because Diane Haslett Rudiano is also the Chief Clerk of the King's County Board of Elections. Starting on the morning of Thursday May 13, Diane Haslett Rudiano started calling other officials of the King's County Republican Party to inform them that she had discovered on Petitioner's website that he is a Muslim. She was assisted in this by Gladys Pemberton, who is also a district leader. By her statements that the Petitioner is a Muslim, Diane Haslett Rudiano and Gladys Pemberton were able to stir up calumny and ridicule against the Petitioner. In addition, Diane Haslett Rudiano and Gladys Pemberton spent many hours reading the more than 3024 pages on Petitioner's website and found many places in which Petitioner expressed disagreement with the policy of the US President. Petitioner had in fact fully disclosed his areas of disagreement with the policies of the US President in his candidate's statement which he had distributed to the members of the King's Country Republican Party Executive Committee on May 5. For example his candidates statement said, "I am opposed to government surveillance of our Internet communications, detentions without trial, national guardsmen in the subways and police barricades around Police Plaza, especially in view of the taxpayer expense of these activities. Right now, the federal income tax brings in $ 1.7 trillion, and yet we have deficit spending. This must be greatly reduced."

15. Anybody reading this would realize that Petitioner was not adhering to the Official Republican Party Line. In their campaign to remove Petitioner from being the duly nominated candidate, Diane Haslett Rudiano and Gladys Pemberton used these statements as part of a campaign to subject Petitioner to calumny and ridicule.

16. Because of these acts of Diane Haslett Rudiano and Gladys Pemberton, on the morning of May 13, 2004, Aaron Maslow announced that Adrienne Britton was the Republican Party candidate. This was entirely wrong because Adrienne Britton had not been nominated or seconded for this nomination.

17. It happened by chance that Petitioner knew Adrienne Britton and so he called her. Adrienne Britton told Petitioner that she was not running for Congress, had no intention of running for Congress and this was the craziest thing she had ever heard of because nobody other than Petitioner had even told her that she had been nominated for Congress. Adrienne Britton demanded that her name be removed for any petition.

18. Subsequently, Aaron Maslow announced that Isabelle Jefferson was the Republican Party Candidate for Congress. Petitioner attempted to contact Isabelle Jefferson only to discover that she had left New York City in April to go to stay with her family in South Carolina and was not expected to return until September. Isabella Jefferson is 76 years old and had never run for federal office before. It was obvious that her name was put on just to fill up a space and to stop Petitioner from running for and being elected to United States Congress.

19. Nevertheless, in spite of the fact that Isabelle Jefferson could not be contacted to determine whether she was even willing to run for US Congress, Aaron Maslow had petitions printed and circulated listing Isabelle Jefferson rather than Sam Sloan as the official candidate. These petitions were then submitted to the Board of Elections. Sure enough, as soon as Isabelle Jefferson returned from Charleston, South Carolina and found out that she was being listed as a candidate for US Congress, she demanded that her name be removed.

20. Thereupon, Diane Haslett Rudiano notarized a statement by Isabelle Jefferson declining the nomination as a candidate. Then, instead of substituting the name of Sam Sloan who had been voted in as a candidate by both the Executive Committee and by a weighted vote of the District Leaders, they instead put in the name of Harvey R. Clarke who was a newly registered voter who registered to vote for the first time on June 4, 2004. This substitution of a candidate was signed by Hy Singer, Lori Maslow and Gladys Pemberton and was notarized by Diane Rudiano.

21. All of the above changes, first putting on Adrienne Britton, then Isabelle Jefferson and finally Harvey R. Clarke, were made without following any formal rules or procedures. No meetings were held. No votes were taken. The primary actor in all of this was Diane Haslett Rudiano, who kept using her position of Chief Clerk of the King's County Board of Elections to put in whomever she wanted as a candidate for US Congress.

22. The King's County Republican Party circulated petitions for all the Republican Party Candidates including candidates for State Senate, State Legislature and Civil Court Judge and each of these petitions listed Isabelle Jefferson as the official Republican Party Candidate for US Congress. These petitions were fraudulent. Isabelle Jefferson was not the Official Republican Party Candidate for Congress. Samuel H. Sloan was the official Republican Party Candidate for Congress. Accordingly, all signed petitions bearing the name of Isabelle Jefferson as a candidate for US Congress should be deemed as petitions for Sam Sloan as a candidate for US Congress.

23. On May 5, 2004, the Executive Committee of the King's County Republican Party voted overwhelmingly to grant Petitioner a "Wilson-Pakula". Subsequently, however, statements appeared in the press that the leadership of the King's Country Republican Party was stating that the Wilson-Pakula was not properly issued because of some defect in the procedure that was followed. This is all part of a conspiracy to stop Petitioner from being elected to Congress. Petitioner seeks a declaration that he is entitled to run as the Republican Party Candidate for Congress.

24. At the meeting on May 5, 2004, leaders of the King's County Republican Party recommended to Petitioner that he seek the nominations of the Conservative Party and the Independence Party and they handed him a flyer giving him the telephone numbers to the relevant persons in those parties. Petitioner contacted and appeared before the screening committees of both parties. Petitioner was told by Jeffrey Kassar, Chairman of the King's County Conservative Party, that they would probably follow the Republican Party lead. Later, Jeffrey Kassar informed Petitioner that he was rejected as a Conservative Party candidate because he had been rejected by the Republican Party because, according to Mr. Kassar, the Republican Party did not like Petitioner's website.

25. Although Petitioner was never notified that his Wilson-Pakula was invalid or had been revoked, statements appeared in the press stating that Republican Party officials had stated that the Wilson-Pakula was not valid. On June 7, 2004, an article appeared in the Courier Life chain of newspapers and at stating the following:

By Erik Engquist
As printed in the Courier Life Newspapers
June 7, 2004

ODDBALL EYES TOWNS When you're strange, no one remembers your name. So sang The Doors, anyway. If they're right, Sam Sloan will have a hard time connecting with voters in the race against Rep. Ed Towns, an entrenched Democrat. But chances are, Sloan won't even make the ballot because he blew his cover-that is, the appearance of normalcy-when making his pitch to Republican district leaders.

Initially, Sloan might have seemed like an intriguing candidate to the G.O.P. because he claims to speak 15 languages including Spanish "virtually fluently," to be an expert chess player, and to be the last non-lawyer to have represented himself before the Supreme Court and won (in 1978, when as a bond trader he was sued by the SEC, represented by Harvey Pitt).

Sloan, a sometime cab driver and author, had even run before-as a Libertarian in the special election to succeed Assemblyman Al Vann in February 2002. Not that he did very well. Of the 2,610 people who went to the polls, exactly 11 voted for Sloan. On his candidate's statement, the 59-year-old Sloan expressed views in keeping with Republican ideology. "I support small government, low taxes, low spendingE oppose rent control," he wrote, for example. Sloan wrote that as "a man of high ethical and moral principles," he would only accept campaign contributions up to $2,000 from individuals and nothing from corporations. He didn't mention that that's the law for all congressional candidates.

That, along with Sloan's failure to comb his hair for his campaign photo, were the first signs that something was amiss. Brooklyn Republican leaders met with Sloan after he expressed interest in challenging Towns, but postponed an endorsement vote because "some of our leaders got bad vibes about him," one leader said.

Sloan later called a district leader to lobby for the nomination and said, "Don't you know I'm famous? I'm on the Internet." Big mistake. The leader quickly went on-line and discovered Sloan's personal Web page, which explores such questions as "Are women genetically programmed to spread their legs when a man approaches?" Sloan also writes on the site, "Women feel a genetic need to strip naked, spread their legs and pose on the Internet. That is my opinion."

Brooklyn Republicans no doubt concluded it might be difficult for Sloan to attack Towns on the character issue. Elsewhere on his Web site, Sloan describes the "female rapists" of the Trobrian Islands, off the coast of Papua New Guinea. He posts a photo of an attractive, topless "typical Trobrian Islander girl" and comments, "I am sure that you will agree that it would be a horrible experience to be raped by such a girl."

Sloan also writes in detail about orgies he organized at Cal-Berkeley and his sexual conquests, potency, and refusal to use condoms. For example: "I was tested to have an exceptionally high sperm count of 144 million sperm per cc, whereas most American men have less than 20 million sperm per ccEy potency is demonstrated by the fact that I have eight children plus historically all of my girlfriends have become pregnant right away." This might not be what Republicans have in mind when they talk about family values.

Embarrassingly, before researching Sloan, Republican leaders voted to give him an exemption so he could run as a Republican despite not being a registered party member. They were relieved to discover their action was technically invalid. The party later chose Isabelle Jefferson to run against Towns, meaning Sloan would have to collect signatures on his own from the few registered Republicans in the V-shaped congressional district, which runs from Sloan's neighborhood of East New York to Midwood and to Boerum Hill.

It would be a daunting task, but Sloan strikes us as the kind of guy who might try it. He's already spent countless thousands of hours on such projects as tracing his family tree back to the 1500s to prove his relation to King Erik XIV of Sweden, and that he and Queen Elizabeth II are 12th cousins two times removed. Somehow, we believe that. After all, there is a history of madness in the British royal family.

26. Because of reading these and similar statements in the press, combined with the fact that Officials of the King's County Republican Party refused even to talk to him plus the fact that Petitioner received an e-mail from Gladys Pemberton stating that his Wilson-Pakula was not valid, Petitioner could not dare to circulate petitions to run for election as a Republican. This left Petitioner with no choice but to file a case in federal court.

27. In a telephone hearing on July 8, 2004 in that case, which is Sloan vs. Rudiano, No. 04 Civ. 2791 (DGT), Judge David G. Trager ruled that, assuming that the facts are as Petitioner states that they are (which will be determined at a later hearing), Petitioner was entitled to circulate petitions as a Republican Candidate for US Congress.

28. Since the last day to file petitions was July 15, 2004, this left Petitioner only 7 days to collect 886 Republican Party signatures, whereas all other candidates had six weeks from June 8, 2004 to July 15, 2004 to collect the signatures.

29. An article dated July 19, 2004 appearing in the Courier Life chain of newspapers and at http://www.lidbrooklyn.org/bp.htm stated the following:

A federal judge said he was inclined to agree with Sam Sloan's argument that Sloan received a valid Wilson-Pakula from the Republican Party, qualifying him to seek ballot access on the Republican line. Unfortunately for Sloan, the case was heard just a week before the petition deadline, leaving him with the impossible task of getting valid signatures from 886 registered Republicans in the 11th Congressional District by midnight on July 15. Sloan was struggling to find three Republicans to place on his committee on vacancies, let alone 886 to sign his petitions (which he hadn't even printed). Looks like Sloan will only be able to claim a moral victory for his would-be campaign against Rep. Ed TownsE

30. Volunteers supporting Sam Sloan for Congress thereafter collected and filed with the Board of Elections designating petitions. The petitions were filed on July 15, 2004, the last day to file. However, these were promptly challenged in objections signed by Bibi S. Khan.

31. This matter was then referred to the Chief Clerk of the King's County Board of Elections, who happens to be Diane Haslett Rudiano, the same person who has been trying since May 5, 2004 to block the candidacy of the Petitioner.

32. Attached hereto as Exhibit G is the Clerk's Report signed by Diane Haslett Rudiano and her subordinate, Maryrose Sattie. Based upon this clerk's report, Petitioner was kicked off the ballot.

33. Petitioner also filed Objections to the Petitions signed on behalf of Isabelle Jefferson. Petitioner objected to some of the petitions on the ground that they were witnessed by Diane Haslett Rudiano and Bibi S. Khan, both of whom were registered to vote at false addresses. Attached hereto as Exhibit H is one sheet of objections of Petitioner in which it is stated: "False address for subscribing witness. Diane Rudiano does not reside at 258 Schenck Avenue."

34. In an obvious violation of the Conflict of Interest Rules, Diane Rudiano ruled in her clerk's certificate that the signatures she witnessed were valid.

35. All of the above acts constituted violations of New York Election Law and the Constitutional and Statutory Rights of the Petitioner as well as the by-laws of the Republican Party.

36. Theresa McGovern purchased the house located at 258 Schenck Avenue on November 20, 1952. The deed is recorded at the Brooklyn Recorder's Office in Liber 8022 Page 313. There has never been a mortgage or encumbrance on the house. The online computer records only go back to 1965 and therefore the deed cannot be downloaded at http://www.nyc.gov/html/dof/html/acris.html . A copy of the deed is annexed hereto and marked Exhibit I. The deed is illegible because it is 52 years old, but that is the deed.

37. The house at 100 Hill Street was sold by Bibi S. Khan and George Khan on December 10, 1990. The Deed is recorded on Reel 2658 Page 1441. A Copy of the deed is annexed hereto and marked Exhibit J.

38. Therefore, unless Diane Haslett Rudiano can prove that she is a rent paying tenant at 258 Schenck Avenue, is it rather conclusive that she is representing District 54 on a fraudulent basis and also she is holding a high-paying job as Chief Clerk of the King's County Board of Elections on a fraudulent basis. I expect her to be removed from those positions soon.

39. I mailed the affidavit in Exhibit F by certified mail on August 3, 2004 to Bibi S. Khan and Diane Haslett Rudiano at their respective addresses. These mailings can be tracked with the following numbers at http://www.usps.com/shipping/trackandconfirm.htm?from=global&page=0035trackandconfirm .

7003 2260 0004 4662 5287 Bibi S. Khan
7003 2260 0004 4662 5294 Diane Haslett Rudiano

40. The certified letter addressed to Bibi S. Khan was forwarded to another address. Here is the what the USPS website states:

Track & Confirm

Shipment Details
You entered 7003 2260 0004 4662 5287 Your item was forwarded to a different address at 10:13 am on August 07, 2004 in BROOKLYN, NY 11208. This was because of forwarding instructions or because the address or ZIP Code on the label was incorrect. Information, if available, is updated every evening. Please check again later. Here is what happened earlier: UNDELIVERABLE AS ADDRESSED, August 05, 2004, 5:46 pm, BROOKLYN, NY 11208 NOTICE LEFT, August 05, 2004, 11:39 am, BROOKLYN, NY 11208 ENROUTE, August 05, 2004, 9:11 am, BROOKLYN, NY 11208 ACCEPTANCE, August 03, 2004, 4:00 pm, BROOKLYN, NY 11201

41. Attached hereto as Exhibit K is the certified mail receipt. Attached hereto as Exhibit L is the printout from the USPS website.

42. Petitioner sent the affidavit marked Exhibit F to Diane Haslett Rudiano at 258 Schenck Avenue, Brooklyn NY 11207. This one was signed for and returned. However, the signature was not that of Diane Rudiano. The signature was obviously of Theresa McGovern, the 98 year old woman who lives there. Attached hereto as Exhibit M is the certified mail receipt. Attached hereto as Exhibit N is the signed and returned green card.

43. In March, 2004, Petitioner was asked by Gally Lim, a Republican Party political activist and the person who collected the most signatures of any person in both the Bloomberg campaign for Mayor and in the Pataki Campaigns, to become a candidate for US Congress, since the Republican Party had no candidate at that time. On Thursday, March 31, 2004, Gally Lim took Petitioner and his baby to a cocktail party in Mill Basin, Brooklyn, featuring Mayor Bloomberg. Mayor Bloomberg held the baby, Sandra Sloan, aged 2, in his arms for a photo opportunity by the assembled news photographers.

44. Because of the support of Gally Lim, a prodigious collector of signatures, Petitioner decided to run for election and so notified almost all of the leaders of the Republican Party in Brooklyn.

45. Because of the near impossibility of obtaining the 3500 signatures which a non-party member is required to obtain to get on the ballot, Petitioner has sought the nomination of various political parties, including the Republican Party.

46. The Tenth Congressional District has the following numbers of registered voters: Republican 17636, Democratic 251608, Independence 5678, Conservative 849, Working Families 714, Blank 38,853. Total registered voters 318,387.

47. In order to get on the ballot as an Republican Party candidate, Petitioner must obtain the signatures of 5% of the registered Republican Party members in his district, which is exactly 882 signatures. Petitioners will experience great difficulty in obtaining these signatures because of the lack of help and the opposition of the Republican Party leadership.

48. Defendants include 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, and Stephen H. Weiner.

49. For the past more than three months Petitioner has been seeking the Republican Party line in his campaign for US Congress from the 10th Congressional District, which is entirely in Brooklyn. He is a registered blank, meaning that he has no party registration. For this reason, he cannot run as a Republican or as a Democrat, for example, unless they grant him a Wilson-Pakula. New York Election Law Section 6-120(3), the "Wilson-Pakula" law, states:

"3. The members of the party committee representing the political subdivision of the office for which a designation or nomination is to be made, unless the rules of the party provide for another committee, in which case the members of such other committee ... may, by a majority vote of those present at such meeting provided a quorum is present, authorize the designation or nomination of a person as candidate for any office who is not enrolled as a member of such party as provided in this section. ... The certificate of authorization shall be filed not later than four days after the last day to file the designating petition ... to which such authorization relates. The certificate of authorization shall be signed and acknowledged by the presiding officer and the secretary of the meeting at which such authorization was given."

50. The Republican Party Respondents are discriminating against the Petitioner on the grounds of religion, Muslim, and race, White, and sex, male. They want a black Christian female, anyone will do. This is a violation of the civil rights of Petitioner.

51. On May 5, 2004 on "Candidate's Night" Petitioner was granted a Wilson-Pakula by the King's County Republican Party. However, they have failed and refused to file this Wilson-Pakula with the Board of Elections. The clear intention of the majority of voters present at the May 5, 2004 meeting of the Executive Committee of the King's County Republican Party was to nominate Sam Sloan as their candidate. This is established by the fact that the Republican Party does not like primaries. They would never have granted a Wilson-Pakula to a candidate if they had any intention of nominating any other candidate.

52. The only reason a vote was not taken then and there making Petitioner a candidate was that Diane Rudiano said that she wanted to take a weighted telephone vote. The telephone vote was taken over the next week and Petitioner prevailed. Nevertheless, Diane Rudiano has continued aggressively to take action after action to block Petitioner from being listed on the ballot as a candidate.

53. All of the actions of both Diane Rudiano and Bibi S. Khan are invalid because they are both registered to vote at a false address.

WHEREFORE, for all of the reasons set forth above, the Petitioner demands:

1. An Order declaring valid, proper and legally effective the designating petitions heretofore filed in the office of the Board of Elections of the City of New York designating the petitioner herein, Samuel H. Sloan, as a candidate in the Republican Primary to be held on September 14, 2004 for election to the Office of Congressman in the United States Congress representing the 10th Congressional District of Brooklyn New York; and

2. An Order directing, requiring and commanding the Board of Elections in the City of New York to place and print the name of the petitioner herein on the ballot as a candidate for election to the United States Congress from the Tenth Congressional District in the Republican Primary to be held on September 14, 2004; and

3. An order enjoining and restraining the said Board of Elections in the City of New York from printing, issuing or distributing for use during said Primary Election in the Tenth Congressional District any official ballot upon which the name of the petitioner does not appear as a candidate for election to the United States Congress.

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

________________________
Samuel H. Sloan

Sworn to Before me this 9th
Day of August 2004

_________________________
NOTARY PUBLIC

________________________
Samuel H. Sloan
920 Belmont Avenue
Brooklyn NY 11208

718-277-6957
347-351-9352
samsloan@samsloan.com


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I have filed three petitions for a Writ of Certiorari in the US Supreme Court. All of the petitions I have filed seek to be reinstated on the ballot as a candidate for US Congress for the Tenth Congressional District of New York.

Here are the petitions I have filed in the United States Supreme Court, in HTML Format:

Here are the same three petitions exactly as filed in downloadable PDF Format:

Here are the same petitions on the US Supreme Court website:


Here is what I have filed thus far:


Here are other candidates for election:
My Home Page

Contact address - please send e-mail to the following address: samsloan@samsloan.com