SUING THE NEW YORK TIMES
for libel & journalistic fraud
* * *
SUPREME COURT OF THE STATE OF NEW YORK
WESTCHESTER COUNTY -- #19841-05
PLAINTIFFS' June 1, 2006 NOTICE OF CROSS-MOTION
for Sanctions,
Disciplinary Referrals, Disqualification of Mr. Freeman & The New York Times
Legal Department, Default Judgment, Summary Judgment & Other Relief
Plaintiff Sassower's
June 1, 2006 Affidavit
in Opposition to NYT Dismissal Motion & in Support of Plaintiffs'
Cross-Motion
Exhibit U:
November 16, 2005 program of New York University Law
School Alumni Association
Exhibit V-1:
Summons with Notice, filed & dated November 4, 2005
Exhibit V-2: Affidavit of
Richard P. Simmonds, sworn February 23,2006
Exhibit V-3: Affidavit of
Robert Haak, sworn February 28, 2006
Exhibit W: George
Freeman's Notice of Appearance & Demand for
Complaint, March 1, 2006
Exhibit X-1:
Elena Sassower's March 9, 2006 letter to George Freeman
Exhibit X-2:
Elena Sassower's March 15, 2006 letter to George
Freeman
Exhibit X-3:
George Freeman's March 14, 2006 letter to Elena
Sassower
Exhibit X-4:
Elena Sassower's March 17, 2006 letter to George
Freeman
Exhibit X-5:
postmarked envelope from NYT Co., March 20, 2006
Exhibit Y:
Eli Vigliano's Affirmation of Service, March 21, 2006
Exhibit Z-1:
Elena Sassower's April 17, 2006 letter to George Freeman
Exhibit Z-2:
George Freeman's April 18, 2006 letter to Elena Sassower
Exhibit Z-3:
Elena Sassower's May 1, 2006 letter to George Freeman
Exhibit Z-4:
George Freeman's May 8, 2006 letter to Elena Sassower
Exhibit Z-5:
Elena Sassower's May 23, 2006 letter to George Freeman
Exhibit Z-6:
George Freeman's May 23, 2006 e-mail
Exhibit AA-1:
coverpage & 2-page excerpt of SJC June 25, 1996
hearing
Exhibit AA-2: CJA's
website "Paper Trail to Jail": as it appeared in
weeks preceding dismissal
motion
Exhibit BB-1:
Elena Sassower's June 30, 1992 letter to Arthur
Sulzberger, Jr. enclosing June 30, 1992 complaint to
NYC Department of Consumer Affairs
& Sulzberger's
editorial statement "From the Publisher"
Exhibit BB-2:
July 14, 1992 letter from NYT Co. Vice President &
General Counsel Solomon B.
Watson, IV,
to NYC Dept of
Consumer Affairs
Exhibit BB-3:
July 15, 1992 letter from Arthur Sulzberger to Elena
Sassower
Plaintiffs'
June 1, 2006 Memorandum of Law in Opposition to NYT Dismissal Motion & in Support of
Plaintiffs' Cross-Motion
