Sloan vs. Truong, Polgar, USCF et al, 07 CIV 8537

[samsloan]

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
__________________________________________

Sam Sloan,

Plaintiff,

-against-

Hoainhan "Paul" Truong, Zsuzsanna "Susan" Polgar, Joel Channing,
William Goichberg, The United States Chess Federation, Bill Hall,
Herbert Rodney Vaughn, Gregory Alexander, Frank Niro, Grant Perks,
William Brock, Randall Hough, Randy Bauer, Jim Berry, Texas Tech
University and United States of America,

Defendants

__________________________________________

VERIFIED COMPLAINT

__________________________________________

Samuel H. Sloan, the plaintiff herein, being duly sworn, deposes and
says:

1. This action is brought to redress identity theft, impersonation,
election fraud, accounting fraud, insider self-dealing and other
insider wrong-doing in connection with the United States Chess
Federation.

2. Jurisdiction is based on diversity of citizenship, federal
questions, election fraud and the constitution and laws of the United
States. The amount in controversy exceeds $75,000.

3. Defendants Hoainhan "Paul" Truong ("Truong") and Zsuzsanna "Susan"
Polgar ("Polgar"), a married couple living together, have for more
than two years engaged in violations of 47 USC §223(h)(1) by sending
over the Internet thousands of obscene messages likely to be read by
children while disguising their identities by impersonating Plaintiff
and other well known chess personalities. They have sent or
transmitted more than three thousand Internet postings under the name
of "Sam Sloan". These postings have become known in the World Chess
Community as "Fake Sam Sloan postings". They have also posted as "Ray
Gordon" (a publisher of a series of books on how to seduce women) and
these have become known as "Fake Ray Gordon Postings". They have also
posted as a variety of real or anonymous personalities including
Beatriz Marinello, Stan Booz, "Jackass Lafferty", JudgementDay, Bob
Bennett and many others.

4. Truong and Polgar have made these fake Internet postings while
running as candidates for election to the Executive Board of the
United States Chess Federation. Their purpose in impersonating
primarily Sam Sloan but others as well has been to get themselves and
their slate of candidates elected so as to take control of the United
States Chess Federation and its finances. Most of the postings by the
Fake Sam Sloan are obscene, pornographic and defamatory attacks on
other chess personalities. Thus, both Sloan and the subjects of these
attacks are all victims. The United States Chess Federation has
approximately 86,000 members and $3.2 million in annual revenues.
Truong and Polgar have engaged in a wide-ranging disinformation
campaign to discredit their rivals, to win election and to get their
hands on the money. During the recently concluded election campaign,
Polgar accused a rival candidate of being a homosexual pedophile with
a history of soliciting boys playing in chess tournaments he directed
for sex. Polgar and Truong have often accused Beatriz Marinello, a
member of the USCF Scholastic Council and a former USCF President, of
being a lesbian. (Marinello says that she is not a lesbian, that she
has been married twice and is currently married.)

5. The postings impersonating Plaintiff, known as the "Fake Sam Sloan
postings", have been on Internet newsgroups rec.games.chess.politics
and rec.games.chess.misc . These groups are carried on a wide variety
of Internet servers, are broadcast around the world with tens of
thousands of readers and are permanently kept and preserved. Here are
some recent examples of the postings by Polgar and Truong:

Subject: Sam Sloan soliciting 8 year old girls Date: Wed, 19 Sep 2007
09:01:43 -0700

Subject: Actions against a child rapist Sam Sloan Date: Fri, 14 Sep
2007 06:16:03 -0700

Subject: Re: Brian Lafferty replaces Sam Sloan as the biggest dickhead
Date: Sun, 16 Sep 2007 21:30:20 -0700

Subject: Attorney Brian Lafferty is a horse's ass Date: Wed, 12 Sep
2007 15:03:31 -0700

Subject: Re: Fucking lying scumbag Brian Lafferty Date: Tue, 11 Sep
2007 20:42:22 -0000

Subject: Actions against Sam Sloan for molesting children Date: Sun,
09 Sep 2007 20:41:01 -0700

Subject: Sam Sloan whines like a pig on a stick Date: Sun, 09 Sep 2007
05:55:15 -0700

Subject: Sam went down on a 12 year old Japanese girl Date: Thu, 06
Sep 2007 08:18:42 -0700

6. All of the above are just a few quick examples of the more than
three thousand Internet postings by Polgar and Truong since June,
2005. These postings are likely to be read by children, since the
average USCF member is ten years old. Although they appear all to be
by or against Sam Sloan, it has been proven through IP addresses that
all of the above postings were by Polgar and Truong. As Truong and
Polgar have moved around from place to place, the IP address of the
Fake Sam Sloan has moved with them. When they went to Hungary, the
Fake Sam Sloan stopped posting until they returned. When they recently
got jobs as faculty members of Texas Tech University in Lubbock,
Texas, the Fake Sam Sloan also started posting from the university
computers at Texas Tech University. Then, when last week they went to
Mexico City for the World Chess Championship, the Fake Sam Sloan also
started posting from Mexico City. Just as criminals are often caught
by a simple slip-up and mistake, Polgar and Truong were finally caught
and positively identified by website administrator Brian Mottershead
when they logged in and posted as the Fake Sam Sloan, the Fake Ray
Gordon and then themselves under their real names from the same
computer first at Texas Tech University and later at Mexico City. From
Mexico City, they posted from NNTP-Posting-Host: 201.134.236.150 on
September 25, 2007, and from the same computer logged into the USCF
Forums. This constitutes proof positive that both the Fake Sam Sloan
and the Fake Ray Gordon plus "Jackass Laffety", judgem...@clerk.com
and a host of others are all Polgar and Truong.

7. Prior to the start of this dis-information campaign, Sam Sloan
enjoyed a sterling reputation as an investigative reporter and was
held in the highest regard by the World Chess Community. Polgar and
Truong on the other hand had a bad reputation and were known
collectively by the euphemism of "Trollgar". (See also for example
former US Women's Champion Jennifer Shahade's acclaimed book "Chess
Bitch" in which she refers to them as "Trulgar" on page 105.) During
the recently concluded election campaign, Bill Goichberg mailed 17,000
(seventeen thousand) postcards to USCF voting members falsely accusing
Plaintiff of wide-ranging wrong doing, and urging in the strongest
possible terms that the voters vote against Sloan. Goichberg also put
up a new website at http://www.checkmate.us to specifically attack
Sloan. This combined with the three thousand obscene postings by the
Fake Sam Sloan, now proven to be by Polgar and Truong, have poisoned
the well and will make a new election difficult to conduct fairly.

8. The Fake Sam Sloan first started posting on exactly June 25, 2005
when plaintiff was up in the air flying from New York to Chicago to
play his famous grudge match with Bill Brock. Since then, there have
been more than three thousand postings by the Fake Sam Sloan. The
purpose of these thousands of Internet postings impersonating Sloan
and others was to win election and to gain control of the financial
assets and revenues of the United States Chess Federation. They
succeeded by winning the election in a mail-in ballot in which the
votes were counted on July 27, 2007. Polgar and Truong won the
election in a field of ten candidates and were elected to four year
terms. However, one of the candidates on their slate, Mikhail
Korenman, was defeated and thus they have only three votes on a seven
member board. Their group includes Joel Channing who is a fellow
Polgarista. One member of their slate, Randy Bauer, defected after
winning election and has consistently voted against them. The defeated
candidates include incumbent board members Don Schultz (a former USCF
President) and Sam Sloan. Because they only have three votes, Susan
Polgar was unable to get herself elected as President of the USCF and
had no choice but to accept the honorary title of "Chairman of the
USCF", an unofficial position with no powers or duties. Truong
accepted an unofficial position of VP of Marketing and Public
Relations.

9. This action seeks to set aside the election on the grounds of
massive election fraud and other irregularities as set forth more
fully below. Plaintiff seeks the reinstatement of the three board
members who lost their seats on the recent election, who were Sam
Sloan, Don Schultz and Beatriz Marinello, until a new election is held
and that a new election be held at the earliest practicable date, to
be supervised by the Department of Justice (and for this reason the
United States of America is named as a defendant). Plaintiff seeks a
court order barring Truong and Polgar from running for election.
Plaintiff seeks a court order removing Joel Channing and Bill
Goichberg from the Executive Board of Directors of the United States
Chess Federation. Plaintiff seeks the removal of Bill Hall from his
position as Executive Director of the United States Chess Federation
for financial irregularities and other grounds. Plaintiff seeks
damages in the amount of twenty million dollars plus punitive and
exemplary damages.

THE PARTIES

10. Sam Sloan ("Sloan"), whose full name is Samuel Howard Sloan, is a
member of the United States Chess Federation and has been a member for
51 years since 1956. Sloan was elected to the Executive Board of the
United States Chess Federation in 2006 but was defeated when he ran
for re-election in 2007. Sloan is one of the best known chess
journalists in the world for his investigative reports and his
newspaper and magazine articles and more recently for his Internet
postings and website. In the 1970s, Sloan was a registered broker-
dealer making markets in over-the-counter stocks and bonds. In legal
circles, Sloan is best known for about 20 published and reported
decisions involving federal securities laws. (However, Sloan is NOT
the Sloan of Sloan vs. New York Stock Exchange. He is only the Sloan
of Sloan vs. SEC.) Sloan is presently a book publisher and is CEO and
President of Ishi Press, a book publishing company headquartered in
Japan with a branch in the US. Sloan resides at 1664 Davidson Avenue,
Apt. 1B, Bronx NY 10453, tel. 917-507-7226, email address is
sams...@samsloan.com .

11. The United States of America Chess Federation ("USCF") is a Not-
For-Profit 501(c)(4) corporation that was incorporated in Illinois on
December 27, 1939. Although an Illinois corporation, it has never had
an office in Illinois. The USCF office was located at 80 East 11th
Street, New York, New York 10003 until 1967 when it moved to Newburgh
NY and later to New Windsor NY. There, it maintained an office until
2006. It moved its principal office to Crossville Tennessee in about
March 2005 and closed its New Windsor office in early 2006. The USCF
is governed by a seven-member volunteer elected Executive Board who
hires a paid Executive Director. The USCF has 23 paid employees in
Crossville Tennessee and four paid consultants elsewhere. Revenues are
$3.2 million per year. Most revenues come from membership dues and
rating fees, plus running national scholastic championships. The
biggest profit center is the National Elementary Championship, in
which as many as 4,000 children compete and earns a profit of as much
as $150,000 annually. The principal asset of the USCF is the "Life
Membership Assets" or LMA which are funds that are supposed to be set
aside when a new Life Member joins and pays $1000 life membership
dues. In 1999, the LMA had $2 million mostly invested in mutual funds.
The USCF lost $2 million from 1999 through 2003 mostly due to
mismanagement but possibly due to fraud and theft while George DeFeis
and Frank Niro were executive directors during that period. The USCF
books and records are in such bad condition that nobody really knows
where the money went. It is only known that it used to have $2 million
and it does not have it any more. The address is United States Chess
Federation, PO Box 3967, Crossville, Tennessee 38557-3967.

12. The USCF has 86,000 members of which the largest group are
scholastic members, age 12 and under. The USCF has 23,000 scholastic
members, 4,000 economy scholastic members and 5,000 family members of
which about half are of scholastic age, for a total of about 30,000
members age 12 and under. It also has 6,000 youth members age 15 and
under, 9,000 young adult members age 24 and under, 20,000 adult
members, 10,000 life members and 600 prison members. The average,
median or largest group of USCF members is 10 years old. After these
members pass age 16, they almost all drop out but then re-join again
at age 36 when their kids are ten years old.

13. The United States Chess Federation is the official origin of chess
in the United States, recognized by FIDE, the World Chess Federation.
The USCF holds the United States Chess Championship, the US Woman's
Championship, the US Open Championship, the National Elementary
Championship, The National Junior High School Championship, the
National High School Championship, the US Junior Championship and
other national events. It qualifies representatives to play for the
World Chess Championship. It sends teams every two years to compete in
the World Chess Olympiad. It sends representatives to compete in the
World Youth Championships, World Junior Championship and Pan American
Youth Championships. It publishes "Chess Life" magazine and "Chess
Life for Kids" magazine. It rates chess players under the USCF rating
system with a range in ratings from 2800 down to 100. It awards titles
of Senior Master, Master, Expert, Class A, B, C, D and E (but not
grandmaster, which is a FIDE title). There are more than 600,000
players in the USCF ratings database, almost all of them being present
or former USCF members. It operates an Internet forum, the most
important section being the "USCF Issues" Forum, in which adult USCF
members may post opinions on a variety of USCF topics.

14. Zsuzsanna "Susan" Polgar, also known as Zsuzsa Polgar ("Polgar"),
is one of the strongest chess players in the world. Her FIDE rating is
2577 which puts her at about number 200 in the world overall. Her USCF
rating is 2597 which, if she were active, would make her the number 21
rated chess player in the United States. Her history is remarkable.
Born on April 19, 1969 in Budapest, Hungary, by age 13 she was already
one of the top women players in the world. By age 14, she was easily
the strongest woman chess player in the world. She had the highest
rating in the world with 2430 and was rated 50 points higher than the
official Woman's World Champion, Maya Chiburdanidze of the Republic of
Georgia. She would almost without doubt have competed for and won the
woman's world championship except that her father refused to allow her
to compete for that title because he was opposed on principle to
"Women's Chess". This started tremendous battles between Zsuzsa, her
bull-headed father, Laszlo, and the Hungarian Chess Federation, with
the Hungarian Chess Federation trying by every possible means to force
her father to let her play for the world chess championship, because
the Hungarian authorities knew that Zsuzsa would win the World
Championship for the pride and patriotism of the Nation of Hungary, if
only they could force Zsuzsa to sit down at the board and play chess.
The Hungarian authorities even tried to put Laszlo Polgar in prison as
a way to force Zsuzsa to play chess and also because he was not
allowing her to go to school either. The President of the Hungarian
Chess Federation was Sandur Serenyi, who was a close personal friend
and former Communist cellmate of Kadar, the President of Hungary, and
they put pressure on Zsuzsa and her father in every possible way
because they knew that Zsuzsa would beat Chiburdanidze and win the
World Championship for Hungary, if only they could force her to play.
Nevertheless. Laszlo Polgar stood his ground and for that reason
Zsuzsa never competed for the Woman's World Championship until she
reached the legal age of 21 and her father could no longer control
her. Zsuzsa never went to school and has had no formal education,
except for a brief stint as an adult at a special sports college in
Minsk, USSR.. Her father made her play and study chess 10 hours a day
from age 4 until adulthood. She is often featured on TV and in the
public media for her fantastic chess playing abilities, including most
recently the BBC program entitled "Make Me a Genius".

15. Zsuzsa finally did win the Woman's World Championship in 1996 by
virtually wiping out the opposition while playing as an American, not
as a Hungarian. However, by then she had already spent at least seven
years of her life fighting battles against the Hungarian Chess
Federation. She then started fighting similar battles against FIDE,
the World Chess Federation, and later against the United States Chess
Federation. FIDE striped her of her World Championship title in 1999
for refusing to defend it on various pretexts, although she actually
wanted two million dollars, whereas FIDE was only willing to put up
$100,000, which they were getting from the Chinese. Zsuzsa wanted her
World Championship match with Xie Jun postponed to September 1999
because this was the height of the dot-com era and a company had filed
a S-1 registration statement with the SEC to go public with, among
other things, the Polgar-Xie Jun Match. This might seem like a silly
idea but a lot of more silly ideas went public during that era.
However, the dot-com bubble burst, the company never went public and
Zsuzsa never got the $2 million. Zsuzsa effectively retired from chess
in 1992, later started playing again just to win the Woman's World
Championship, then retired again in 1996 and since then for the last
11 years has played in only two official FIDE rated tournaments, both
of which were held in 2004. Otherwise, she has confined herself
primarily to paid celebrity appearances and exhibitions.

16. In spite of the fact that her real accomplishments are
considerable, Zsuzsa has the unfortunate tendency to exaggerate her
achievements and to falsely state that she achieved things that she
has not achieved. For example, she often refers to herself or has
others in her entourage refer to herself as "The World Chess
Champion". After FIDE stripped her of her title in 1999 for refusing
to defend it, Zsuzsa sued FIDE for the restoration of her title. In
2001, FIDE settled the suit by paying her $25,000 which equaled her
attorneys fees but refused to restore her title. Zsuzsa apparently
considers that she still has the title. She often has it said that she
"Won the Woman's World Championship four times". This is nonsense as
she only won it once although admittedly she probably would have won
it four times if her father had allowed her to play. She states that
she has been in the top three women in the world for the past 15
years. This is another nonsense claim as she has not even been on the
world ranking list except for one year in the last 11 years due to
inactivity, plus there are several Chinese and one Indian woman of her
caliber nowadays who might be able to beat her if she played. She
claims to have been the first woman to qualify for the Overall (or
"Men's") World Championship cycle. This too is nonsense as Pia
Cramling was the first to play for the Overall title and Susan has
never played for the official FIDE Overall World Title. She has the
odd habit of describing everything he does in grandiose terms and
naming everything she does after herself, such as the "Susan Polgar
World Open Championship for Girls" which drew a grand total of 41
mostly weak players. Polgar is presently a faculty member of Texas
Tech University in Lubbock, Texas, where she resides. Her address is c/
o Texas Tech University, Box 45080, Lubbock, Texas 79409-5080.

17. Hoainhan "Paul" Truong ("Truong"), born in June 1965 in South
Vietnam, makes so many fantastic and unbelievable claims about himself
that it has proven impossible to determine what the truth is. He
claims to be a boat person who came to America as a refugee, to have
refused a seat on the last helicopter out of Vietnam, to have won 11
national chess championships and 120 chess tournaments, and that after
arriving in America as a penniless refugee to have risen to the top
and to have become a captain of industry, to have rescued and saved
many billion dollar companies, and to have made millions for himself,
so that he was able to retire at age 32. He also has claimed to have a
PhD degree, but he has withdrawn that claim. He has refused to provide
a verifiable resume or any verifiable information about the companies
he worked for and rescued. Detractors say that none of his claims are
true, that he did business under the name of "Paul Derazza", sold
Florida land to retired New Yorkers at inflated prices, made a lot of
people angry and was strongly urged by associates of people he had
swindled to retire or else. Detractors also say that both he and Susan
Polgar have been expelled for computer cheating from several Internet
chess playing servers, including the Internet Chess Club ("ICC") and
US Chess Live. Plaintiff has no idea which of these claims are true
and which are not, because all of these claims, both positive and
negative, have proven to be unverifiable. Although Truong claims to
have won 11 national chess championships and to have been a "media
sensation" in Vietnam, the Vietnam Chess Association says that he was
a player there but that he never won a national chess championship of
that country. Similarly, there is no record of him ever having won a
national chess championship in the United States either. He is a
master strength chess player, although he rarely plays in tournaments.
He once lost a tournament chess game to Plaintiff. Truong is presently
a faculty member of Texas Tech University in Lubbock, Texas, where he
resides. His address is c/o Texas Tech University, Box 45080, Lubbock,
Texas 79409-5080.

18. Polgar and Truong became associated together starting in 2002,
while getting a divorce from her husband, Jacob Shutzman, but until
recently have denied any romantic involvement, insisting that their
relationship was purely business, with Truong being the "business
manager" of Polgar. When they announced in December 2006 that they
were both running for election to the USCF Executive Board, they
continued to maintain that their relationship was entirely business.
At about the same time, rumors started to circulate that they were
actually married to each other. While they conducted their election
campaign on the USCF Issues Forum, they were asked many times whether
they were married or not. Every time this question was asked they
complained to the moderators and got the question deleted. Their six
campaign statements in Chess Life magazine contained no mention of
them being married to each other. Thus, they were able to campaign for
and to win election to four year terms on the USCF Executive Board by
fraudulent means in that the general membership was never informed
that they were married to each other. This charade unraveled when a
newspaper reporter in Lubbock, Texas reported that they were married
to each other. After considerable delay, Susan eventually acknowledged
this relationship on her website in late May, 2007. It still remains
unknown when and where they were married to each other or how long
they have been married.

19. Polgar and Truong are followed by an entourage of supporters and
sycophants who have become known as "Polgarites" or the "Polgaristas".
They are opposed by others known as the Contra-Polgaristas. Internet
battles are being waged daily between the Polgaristas and the Contra-
Polgaristas, sweeping across various Internet forums and even the
Wikipedia encyclopedia. Although outnumbered, the Polgaristas seem to
be winning because several of them have been appointed as moderators
of the USCF Issues Forum which gives them the power to delete any
negative comments about Polgar. As a result, Polgar has become known
by various euphemisms including "The Name that One Dare Not Speak",
"S.ome P.oor S.oul" and "Chairman Susan". Polgar has responded with
demands that the USCF Issues Forum be shut down or that the "trouble
makers" be "permanently banned". On September 14, 2007, Susan wrote to
the other board members:

From: SusanPolgar@xxxxxxx
Date: Fri, 14 Sep 2007 23:01:25 EDT
Delivered-to: USCF BINFO System

We need a prompt system with as little bureaucracy as possible. Once a
system is in place and the trouble makers are properly sanctioned
including permanent banning, there will be no problem with the forum.
99% of the problems are caused by less than 10 people.

Best wishes,
Susan Polgar

www.SusanPolgar.com
www.SusanPolgar.blogspot.com
www.SusanPolgarFoundation.org

20. Joel Channing is a controversial real estate developer in Palm
Beach Gardens, Florida, where he resides. In 2002 and 2003 he
organized a bid to move the USCF Headquarters from New Windsor, New
York to Palm Beach Gardens. The bid was awarded and the move approved
and announced. Then, some months later, John McCrary, then USCF
President, announced that the USCF was moving to Crossville, without
even consulting or notifying the Palm Beach Gardens group. Later, the
Crossville proposal was dropped but was reinstated in 2004 after the
Crossville City Attorney threatened to file suit if the USCF did not
move there. Angered by these shenanigans, Joel Channing decided to run
for election. He was elected to the USCF Executive Board for a four-
year term in July 2005 in a hotly contested election in which all of
the candidates who supported the move to Crossville were defeated. He
took office in August 2005. As he had been opposed to the move to
Crossville, it was assumed that he would cancel the move, but instead
after he took office as VP of Finance he went ahead with the
completion of the move and the construction of a new $650,000 USCF
building there. He has since become known for his bullying tactics,
demanding changes in the USCF accounting system, yelling and screaming
a lot during closed sessions of the board, and for once reaching under
the table during a USCF board meeting and putting his hand on the
thigh of an attractive female board member, who immediately rebuffed
his advances. He is now a strong supporter of Polgar and is considered
to be a Polgarista. He sought to make Polgar the president but could
not get enough votes. His address is 5520 PGA Blvd., Suite 200, Palm
Beach Gardens, Florida 33418.

21. In 2005, while a candidate for USCF Election, Channing filed a
civil suit for libel and slander against a rival real estate developer
and former business partner in Palm Beach Gardens Florida after the
rival had posted on the Chess Politics newsgroup that Channing had a
"terrible reputation" in Florida and cared nothing about chess. This
suit was reported in the Palm Beach Gardens Post. Channing has made
threats to sue chess personalities, including a threat to sue former
Chairman of the Finance Committee and CPA Stan Booz. After winning
election, Channing demanded that the USCF take out "Internet
insurance" at a cost of $11,000 to protect board members from
criticism on the USCF Forums so that moderators could remove
criticisms of board members from the USCF Forum without being sued.
Channing apparently believes that this Internet insurance will allow
him to sue critics including especially Sam Sloan and to collect since
he assumes that Sloan has no money. Channing often expresses the need
to get rid of Sam Sloan in BINFOS to the other board members. (BINFOS
are private emails between board members and stands for "Board
Information".)

22. William Goichberg is President of the United States Chess
Federation and is THE BIGGEST CHESS ORGANIZER IN THE WORLD. He also
plays the horses. For example, his 35th Annual World Open held June 30-
July 4, 2007 offered $400,000 in prizes, with $280,000 guaranteed. No
other chess tournament in the world comes close to this. Goichberg
resides in Arcadia, California near the Santa Anita Race Track when
the horses are running and in New York when the Mets are playing and
spends the rest of his time moving about the country organizing and
running his big money chess tournaments, the biggest of which are the
Foxwoods Open, the Chicago Open and the North American Open. His
address is US Chess, PO Box 3967, Crossville, Tennessee 38557-3967.

23. Bill Hall is Executive Director of the United States Chess
Federation and resides in Crossville, Tennessee. He was hired in June
2005 after the move to Crossville. Prior to being hired, his work
experience consisted of being a substitute teacher of high school
physics and a door-to-door salesman of Amway Products. He once
attended MIT. He had never worked in a corporate office prior to being
hired as Executive Director of the USCF. He is a strong, expert-rated
chess player and has a congenial "nice guy" personality but, in the
opinion of plaintiff, has proven himself to be utterly incompetent and
totally worthless as an Executive Director of the USCF, an opinion
that is shared by Beatriz Marinello who originally hired him, and many
others. His address is c/o United States Chess Federation, PO Box
3967, Crossville, Tennessee 38557-3967.

24. Herbert Rodney Vaughn resides in Kentucky after previously
residing in Chicago. His address is 1154 Duncan Ridge Road, Lewisburg,
KY 42256. He first became to the attention in the world of chess in
2006 by writing hundreds of articles on the Internet attacking Sam
Sloan under the anonymous screen name of Tanstaafl, while Sloan was
running for election. He repeatedly refused to reveal his actual
identity when asked. After Sloan was elected anyway, he organized and
became the leader of a group determined to overturn the election
results and to stop or prevent Sloan from taking office on the board.
He came to the USCF delegates meeting in Chicago held August 13-14,
2006 and without revealing his identity as "tanstaafl" claimed to be a
Delegate from the State of Ohio and, because nobody was paying
attention or knew who he was, managed to get seated as a delegate. He
then proceeded to tie up the delegates meetings with motions directed
to stopping Sloan from taking office or getting him removed from
office. He tried to get the delegates to refuse to certify the results
of the election and after learning both that there was insufficient
support for that idea and that USCF Counsel Michael Matsler had
advised that a refusal to certify the election results would be
ineffective anyway, Vaughn got passed a by-laws change making it
easier to recall or remove an elected board member. Addressing the
well-known fact that in 1992 Sloan was convicted in a child custody
case in Virginia involving his daughter Shamema (the case is reported
on Lexus-Nexus. Be sure to look at the 6-3 Virginia Court of Appeals
Decision in which the opinion of the three dissenting judges makes it
obvious that Sloan was not guilty.). Vaughan moved a by-laws change
that a "convicted felon" may not serve on the board. The delegates
modified this motion to say that the convicted felon must disclose his
conviction in the candidates statement published in Chess Life and is
given 100 extra words to do so. The end result of all these efforts by
Vaughan to stop Sloan from taking office was that they failed although
two of his motions passed. After the delegates meeting was concluded
and the new board took office, the new board passed a rule that all
posters to the USCF Forums must reveal their USCF ID number so that
anonymous posters are not allowed. This became known as the "Herbert
Vaughan Rule" because through this rule it was revealed that Herbert
Vaughn was the same person as tanstaafl. Vaughn then proceeded to file
a 400 page ethics complaint against Sloan in color in which he
complained about among other things the Herbert Vaughn Rule. Eleven of
the 16 Counts in the Vaughn Ethics Complaint were dismissed by the
USCF Ethics Committee on the grounds of no jurisdiction, one was
dismissed on the merits and the remainder are pending on appeal.

25. Knowing the overt hostility of Vaughn towards Sloan, Bill Hall
appointed Vaughn as a moderator of the USCF Forums, giving Vaughn the
power to remove from public view any posting. Vaughn has proceeded to
remove from public view more than one thousand postings by USCF
members, not only by Sloan. Almost every posting even mildly critical
of members of the USCF Executive Board or of Bill Hall have been
removed from public view. In theory, there is a "Forum Oversight
Committee" or "FOC" with the power to restore postings but most
members of the FOC have resigned, citing pressure from board members
to remove any posting critical of them. They are resigning because of
pressure from members of the Executive Board to ban certain posters
and because of threats by certain members of the Executive Board to
shut down the USCF Forums altogether. Here is an example posted at the
time of his resignation by Wayne Praeder at:
http://members.aol.com/wpraeder/bbs.htm
http://members.aol.com/wpraeder/newaug.htm

"Board Member Intermediation

"There seems to be a considerable amount of posting as well as
correspondence from our leadership and technical support staff
expressing their various opinions on what is appropriate or not
appropriate regarding the forum. The impact of this intermediation
with the membership is noticeable.

"I did want to express concern about board members expressing
displeasure with various posts or moderator actions and suggesting
also that comments referring to themselves or their colleagues be
removed. This has been exacerbated by requests to ban others from the
forums. This action combined with various comments from our leadership
about shutting down the forums lends a chilling effect to the process
and contributes to dysfunctional forum moderation.

"Even if our leaders are hyper-sensitive to criticism they need to be
models of decorum for all of us and be prepared to productively answer
critics and not suppress them. Improving organizational behavior must
start at the top. The USCF must have those who represent it to lead by
example. Note personal attacks should not be allowed but the idea is
not to stifle criticism, debate, or even disagreement as one can have
polite discourse and still challenge others' points of view, their
record, their statements, their actions, their behavior, and their
opinions.

"The Forum Oversight Committee

"I understand all this intermediation by our leaders should not
influence FOC actions but it does as such behavior encourages
individual and arbitrary interpretation of the AUG that the forum
members all have agreed to follow. In my opinion this arbitrariness,
interestingly enough, also empowers what the leadership labels
disrespectfully as malcontents as well as provides a rationale for
those in authority not to maintain their public accountability."

26. Tragically, one forum moderator committed suicide on September 2,
2007. The reasons for his suicide are not known, but he called
plaintiff just two days before he died and expressed deep concern
about threats that were being made to sue him. Duncan Oxley of Marina,
California was a long time friend of plaintiff and had several times
reinstated postings that had been pulled by Vaughn. Oxley also had
been a moderator for seven years on both ICC and US ChessLive and had
been involved in suspending Polgar and Truong from these chess playing
sites for computer cheating.

27. Gregory Alexander is a full-blown Polgarista. He resides in
Seattle, Washington. His address is 8416 Monte Cristo Drive, Everett,
WA 98208. He is a new member of the USCF having joined just recently
and played his first rated game of chess only last month. In spite of
his lack of knowledge of chess and chess players, he was appointed as
a member of the FOC for the obvious purpose of deleting any negative
comments about Polgar. Soon thereafter, he was moved down to the even
more sensitive position of moderator. He soon got into raging battles
with the other moderators and the FOC. Often he would remove a posting
and another moderator such as Duncan Oxley or Mike Aigner would
reinstate it. Then, when the FOC ordered a posting reinstated, Gregory
Alexander would remove it a second time. Finally, he resigned after a
brief but tumultuous time as moderator, because the FOC was in the
process of voting to censure and sanction him for disobeying their
orders to restore posts. He then went public with attacks on the other
moderators and the FOC. He has set up and established a copycat forum
at http://www.chessdiscussion.com on behalf of Polgar and Truong that
looks so much like the USCF Forum with the same design, colors and
layout as to confuse readers into believing that they are looking at
the original. Gregory Alexander has been viciously attacking the
system administrators who discovered and proved that Polgar and Truong
are one and the same as the Fake Sam Sloan and the Fake Ray Gordon.

28. Frank Niro was USCF Executive Director from 2001 to 2003. He was a
well-liked and congenial guy who was liked especially by Plaintiff.
However, in August 2003 he suddenly disappeared and soon thereafter it
became apparent that he was a big crook. The circumstances of his
disappearance were that he had been reporting that the USCF had a
$300,000 surplus for the 2002-2003 fiscal year. He walked out the door
of the USCF offices after writing himself a check for $3000 for
expenses, supposedly on his way to Los Angeles, never to be seen
again. Frank Niro simply disappeared. A few days later in the middle
of the Finance Committee Workshop in Los Angeles a Federal Express
arrived with the audited financial statements. The USCF Treasurer,
Frank Camaratta, opened the package proudly thinking it would show a
$300,000 surplus only to discover that it showed a $300,000 deficit.
This startling development caused USCF President John McCrary to
resign. Camaratta subsequently resigned as well. Beatriz Marinello,
elected to be a hapless and beautiful wallflower, to everyone's shock
and surprise, suddenly became USCF President. On August 20, 2003, she
walked in the USCF Offices in New Windsor NY and, realizing that the
USCF could no longer make payroll, fired 17 long standing staff
members on the spot, reducing the staff from 40 to 23. She noticed
that the USCF's laptop computer on which all the financial records
were recorded was missing but had no idea what had happened to it.

29. Four years later, Frank Niro appeared on the Internet with his own
website at http://www.chesssafari.com . The website was taken down
shortly thereafter. Turns out that after disappearing in August 2003,
Niro had gone into hiding in Polgar and Truong's building in Forest
Hills, Queens. Niro publicly thanked Polgar and Truong from recovering
the laptop computer from the USCF offices and bringing it to him.
After questioning all witnesses, the following facts have emerged.
After the USCF Delegates meeting in Los Angeles, Mike Nolan was placed
in charge of the New Windsor office. However, an emergency in Nebraska
where he resided had caused him to resign only a few days later. On
the morning of August 20, 2003 he left the USCF offices after
observing that the laptop computer was sitting on Frank Niro's desk
(Niro having not resigned but simply disappeared). As Nolan was
walking out the door, he observed Paul Truong and Susan Polgar walking
past him in the door. A few minutes later Beatriz Marinello arrived
with her new VP of Finance Tim Hanke. Polgar and Truong were no longer
there. In other words, Polgar and Truong stole the laptop computer.

30. Polgar and Truong have since admitted that they took the laptop
computer. However, they claimed that they had permission to do so.
However, all witnesses and all persons involved have been questioned
and nobody gave them permission to take the computer which would have
contained the data to determine what happened to the missing $600,000
and possibly what happened to the entire $2 million that the USCF lost
from 1996 to 2003. Plaintiff while on the board has repeatedly
demanded the return of the laptop computer and Polgar, Truong and
presumably Niro have refused to return it. (Please note that corporate
records are required by law to be kept and preserved for seven years.
Thus, if Polgar, Truong or Niro have erased or disposed of that laptop
computer, they have committed a crime.) Niro reportedly now resides in
the Seattle, Washington area and Polgar and Truong have visited him
there recently. His exact address is unknown, as he is still hiding
out. His mailing address is c/o Delilah Rene Luke, KRWM, 3650 131st
Avenue SE, Suite 550, Bellevue, WA 98006.

31. After Plaintiff took office on the USCF Executive Board after
winning the 2006 election, he demanded and eventually received a CD
showing all the checks received and paid since 2001. This CD showed
checks for huge amounts of money (by chess standards) being paid to
various Polgar entities including Susan Polgar, Inc. Polgar Chess
Authority, Susan Polgar Foundation and Susan Polgar herself. These
checks total around $50,000 which is a lot of money especially since
Polgar seems to have done little or nothing to deserve them. No
explanation has been provided as to what these checks are for. The 990
Form filed with the IRS shows that Frank Niro formed the Susan Polgar
Foundation, Inc. as a not-for-profit corporation while Niro was
Executive Director of the USCF. Frank Niro remains a trustee of the
Susan Polgar Foundation to this day. This, checks signed by Niro
paying money to the Susan Polgar Foundation were essentially checks
paid to himself, an obvious violation of conflict of interest. No
member of the board was ever informed of this until it was discovered
in late 2006 while Plaintiff was on the board.

32. In March, 2003, Frank Niro representing the USCF secretly signed a
contract with Polgar and Truong, under which among other things the
USCF would put up $50,000 and Polgar and Truong would provide
"training" for the 2004 United States Woman's Team to be sent to the
World Chess Olympiad in Spain. This contract was ridiculous as the
USCF was tottering on the brink of bankruptcy and did not even have
money to send a team Calvia, Spain to play, much less $50,000 to train
one. This contract was kept top secret from the board and was not
known until is was discovered months after Frank Niro had disappeared.
The USCF subsequently reached a settlement with Polgar in 2006 and
paid her $20,000. In appears that monthly pictures of Polgar that were
published in Chess Life magazine in every issue in 2006 was part of a
settlement, especially since Polgar played in only one chess
tournament that entire year and that was an unofficial event organized
by herself. (Polgar was paid double, as the Kasparov Chess Foundation
also paid her.)

33. In October, 2003, after Frank Niro had disappeared and Grant Perks
had taken over as executive director, Polgar and Truong sent an
invoice demanding payment of $17,000, mostly for celebrity appearance
fees. None of these appearance fees had been authorized by the board,
nor did the board even know about them. Grant Perks was instructed by
the new VP of Finance Tim Hanke, "Don't pay them a penny".
Accordingly, Grant Perks did not pay. Grant Perks was fired shortly
thereafter (although he claims that he quit before they could fire
him) and Bill Goichberg took over as volunteer executive director. In
December, 2003, Goichberg secretly paid Polgar $13,358.36. This
payment was kept secret until Plaintiff discovered it in November,
2006, three years later. In a board meeting in Stamford, Connecticut,
on November 17-18, 2006 Beatriz Marinello informed the board that she
had been USCF President at that time and that she had not known and
would not have agreed to this payment to Polgar of $13,358.36.

34. Grant Perks is a Ohio CPA residing in Bexley, Ohio. He is
currently Chairman of the Finance Committee and a member of the Audit
Committee of the USCF. He was Executive Director of the USCF for three
months in August to November 2003 and Chief Financial Officer of the
USCF from January to May 2005. It has been reported that he was fired
both times but he claims that he quit. He is a cover-up guy,
consistently trying to stop the discovery of any inside financial
information about the USCF. For example, he juggled the books so that
a reported loss of $57,915 for the fiscal year ending May 31, 2007 was
converted to a $3,000 surplus by the time the delegates met in August,
2007. Perks ran for USCF election in 2006 and was defeated by Sloan.
After losing the election, Perks tried to overturn the election
results by filing an ethics complaint hoping that the Ethics Committee
could vacate the results. Perks even advocated changing the by-laws by
eliminating the Executive Board altogether so that Sloan could not
take a seat on the board. These efforts were unsuccessful. At the
delegates meeting on August 12, 2006 in Oak Brook, Illinois, Perks
left a note with Pat Knight, Assistant USCF Executive Director,
purporting to appoint Herbert Rodney Vaughn, Paul Troung and William
Brock as delegated from Ohio, although none of them lived in Ohio. All
three of these individuals were known to be vehemently hostile to
Plaintiff and the purpose of these purported appointments was to stop
Plaintiff from taking office or to remove Plaintiff from office
shortly after taking office. Plaintiff contents that these
appointments were ineffective and a violation of the USCF by-laws and
the two anti-Sloan by-law amendments sponsored and voted in by these
purported delegates are null and void, especially since Perks did not
attend the delegates meeting but left before the meeting had started.
(Although made a "delegate" by Perks, Brock did not take a seat as a
delegate because he had just resigned his USCF membership in protest
to the election of Sloan.) The address of Grant Perks is 391 South
Gould Road, Columbus Ohio 43209.

35. William Brock is a Chicago CPA residing in Chicago. Brock is Past
Chairman of the Audit Committee of the USCF, Past Chairman of the
Finance Committee of the USCF and Past President of the Illinois Chess
Association. For unknown reasons Brock has an obsessive compulsive
need to attack Sloan ten times a day. Every day for more than three
years since 2004, Brock has called Sloan a child molester, a pedophile
and a purveyor of kiddie-porn and Poke-Porn. Nobody seems to know why
Brock does this although one theory relates to the fact that Pokemon
has a cartoon character named "Brock". The claims by Bill Brock that
Sloan is a pedophile pornographer and so on have no basis in fact, yet
he keeps making these claims. He stalks Sloan on the Internet and
follows him around. For example, if Sloan posts on the ChessNinja
site, Brock will come behind him and post there too. The same thing
for Wikipedia and every other site. Brock seems to be a sick man, as
there is no other explanation for this behavior. This spectacle has
been so remarkable that a peanut gallery of spectators follows them
around. In June, 2005 a group of these spectators got together and put
up $1000 cash for Sloan to play a Grudge Match against Brock. Even
though Sloan was the underdog since Brock was rated more than 100
points higher, Sloan agreed to fly to Chicago and play the match in
Brock's CPA office in the Chicago Loop. The match was refereed by now
disgraced Arbiter Larry Cohen. Among the spectators who put up money
for the match was Randy Bauer, who is now a USCF Board member. Bauer
assumed that Brock would win easily and he wanted to see Sloan
humiliated. Thousands watched this match over the Internet as it was
played. They were astonished when Sloan beat Brock and won the $1000
green cash. The games are preserved and recorded with comments on
chessgames.com and numerous other websites. The address of William
Brock is 230 West Monroe, Suite 330, Chicago, Illinois 60606-4701.

36. It was during the lead-up to this chess match that the Fake Sam
Sloan first appeared and started posting. The Fake Sam Sloan posted
while Sloan was up in the air flying to Chicago and therefore could
not read the Internet and respond. Obviously, under these
circumstances, Brock was an immediate suspect. Nobody suspected Truong
or Polgar because at that time Sloan was still on friendly terms with
Polgar, having been friends with her since 1986. It is certain by
following the threads that the Fake Sam Sloan who first posted on June
25, 2005 is the same person as the Fake Sam Sloan who is posting right
now, today.

37. Randall Hough is a professional chess tournament organizer
residing in Los Angeles, California. He is a member of the Executive
Board of the United States Chess Federation, having been elected to a
three year term in 2006. He has been called a mindless sycophant and
lapdog of Goichberg by Sloan, but in truth he does sometimes exercise
independent thought and action, although not often. Hough resides at
1826 Garvey Avenue, Unit 5, Alhambra, California 91803.

38. Randy Bauer is a member of the Executive Board of the United
States Chess Federation having been elected in 2007 to a four year
term. He was also a member of the board during the 2004-2005 year but
was defeated when he ran for re-election. He is best known for having
been Budget Director of the State of Iowa under Governor Tom Vilsack
who later ran for President of the United States. Bauer was Chairman
of the USCF Finance Committee for two years from 2005 to 2007 but did
not do anything. He resides at 3923 - 153rd Street, Uniondale, Iowa
50323.

39. Jim Berry is a member of the Executive Board of the United States
Chess Federation having been elected in 2007 to a three year term. He
resides in Stillwater, Oklahoma where he is on the Board of Directors
of a major bank. His address is PO Box 351, Stillwater, Oklahoma
74056.

40. Texas Tech University is a university located in Lubbock, Texas.
It recently hired Polgar and Truong to be members of its faculty
perhaps without doing a thorough background check. Polgar was allowed
to give a commencement speech to graduates of that university, ironic
since Polgar never went to school herself much less a university.
Texas Tech even gave her an honorary doctoral degree and now refers to
her as "Dr. Polgar". In introducing her to the students before her
commencement speech, the University President said that she had won
the Woman's World Championship four times. This statement was utterly
false, but Polgar, who was standing beside him, did not contradict it.
The address is simply Texas Tech University, Lubbock, Texas 79409.

41. Texas Tech University has allowed Polgar and Truong to use the
computers of the University to impersonate Sam Sloan and Ray Gordon
and to post Fake Sam Sloan and Fake Ray Gordon messages on the
Internet.

42. The United States of America is named as a defendant herein
because Plaintiff is petitioning for the Department of Justice to
supervise a new election for the Executive Board of the United States
Chess Federation.

COUNT I

TRUONG AND POLGAR IMPERSONATED PLAINTIFF WITH THREE THOUSAND INTERNET
POSTINGS FROM JUNE 25, 2007 TO THE PRESENT DATE

43. Plaintiff repeats and re-alleges each and every allegation of
Paragraphs 1 thought 42 of this complaint.

44. The Internet postings by the "Fake Sam Sloan" started on June 25,
2005 while Plaintiff was running in the 2005 election in which he was
defeated. Here is the first or one of the first postings by the Fake
Sam Sloan:

Newsgroups: rec.games.chess.politics
From: "Sam Sloan" <whoc...@registerednurses.com>
Date: 25 Jun 2005 09:58:39 -0700
Local: Sat, Jun 25 2005 12:58 pm
Subject: Why did Marinello and Shaughnessy make a deal with Natrol?

2 questions for Dr. Dubeck:

1. How many members did the USCF lose under Beatriz Marinello?

FACT: The USCF lost the most members ever under Beatriz Marinello.
It's the worst record by any president.

2. How much money did Beatriz Marinello and Elizabeth Shaughnessy make
for signing a deal with Natrol for selling BrainSpeed pills to kids?
If they didn't then why don't they tell us who signed the stupid deal
with Natrol? Cat got their tongues?

FACT: Both are making a living in scholastic chess and both endorsed a
dumb deal to sell chess wonder pills to kids. What does that say about
their judgment?

These are two of the reasons why I will vote for myself 4 times.

If you need me, contact me through Bill Brock.

46. Note that the email address for the Fake Sam Sloan was at that
time whoc...@registerednurses.com . Plaintiff has never had that
email address. It attacks USCF President Beatriz Marinello and board
member Elizabeth Shaughnessy. This was the first of several email
addresses for the Fake Sam Sloan. Only a few days later, the Fake Sam
Sloan changed email addresses to sl...@journalist.com . Note that it
says "If you need me, contact me through Bill Brock". This shows that
the Fake Sam Sloan knew that I was on an early morning flight to
Chicago to play a chess match will Bill Brock and thus would not be
able to respond immediately to this posting.

47. Here is a posting from a different email address only five days
later. It is clear from a variety of clues that it is the same person:

Newsgroups: rec.games.chess.politics
From: "SamSloan" <sl...@journalist.com>
Date: 30 Jun 2005 16:48:53 -0700 Local:
Thurs, Jun 30 2005 7:48 pm
Subject: Bulldyke Marinello lies again

How much money did you make for Natrol? Why only apologized to the
scholastic community? What about the rest of the members? Where's that
apology letter? How much money did you make as COO and President? I'm
not supporting Bauer, Shutt, Shaughnessy, or John until you're
converted. The best candidate is clearly me.
Sam Sloan

48. Note that the email address for the Fake Sam Sloan was at that
time sl...@journalist.com. Plaintiff has never had that email address.
The posting attacks USCF President Beatriz Marinello as a "bulldyke".
An Internet search for the word "Bulldyke" will produce 41 uses of
this term. All of them have now been shown to have been authored by
Polgar and Truong. Polgar is known for long disliking Marinello, who
is her rival because she is also a chess master and is the Former
South American Woman's Champion and she is also more beautiful than
Polgar. This posting also makes disparaging comments about four
opponents for USCF election, Bauer, Shutt, Shaughnessy, and George
John. This demonstrates that the Fake Sam Sloan was trying to
influence the outcome of the election. (All four of those candidates
lost that election, as did Plaintiff.)

49. Evidence establishes that board members William Goichberg and Joel
Channing have known all along that Paul Truong was the Fake Sam Sloan.
Their actions since the uschess.org website administrator proved
through IP addresses that Paul Truong and the Fake Sam Sloan are one
and the same demonstrates this. Goichberg has ordered the Forum
Moderators to remove all postings pertaining to Truong being the Fake
Sam Sloan but he is allowing criticism of the administrator, Brian
Mottershead, who proved this. Members are being allowed to attack and
vilify Mottershead all they want, but any criticism of Truong or
Polgar is not allowed. In addition, Goichberg is disobeying and
ignoring advice of counsel in this regard. USCF Counsel, Michael
Matsler has advised Goichberg to collect the evidence and get Truong
off the board as soon as possible or else be implicated in a cover-up.
Goichberg has done exactly the opposite. He had ordered the forum
moderators to remove all the evidence from public view plus he had
asked Polgar and Truong plus two other board members who have
indicated that they want to resign amid this ascandal, Joel Channing
and Jim Berry to stay on the board until he can find a satisfactory
replacement to run against Sloan and Donna Alaria. (Donna Alarie is a
USCF member who has been investigating the finances and has uncovered
many financial irregularities.) Thus, what is going on right now is a
Brezhnev-style Soviet Cover-Up led and directed by the USCF President
Bill Goichberg.

50. Further evidence that Goichberg and Channing have known for more
than one year that Truong was impersonating Sloan comes in the form of
the following email that Sloan sent to the entire board including
Goichberg and Channing one year ago on July 30, 2006 just a few days
before Sloan who had already won the election was scheduled to take
his seat on the board:

From: sl...@ishipress.com (Sam Sloan) Date: Mon, 31 Jul 2006 16:59:44
GMT Local: Mon, Jul 31 2006 12:59 pm

Subject: Paul Truong is the Fake Sam Sloan

The big mystery in chess over the past year and especially over the
just completed election period has been the identity of the Fake Sam
Sloan. The Fake Sam Sloan has been flooding the chess newsgroups and
especially rec.games.chess.politics with so many postings that it was
sometimes difficult for anyone to discuss anything else. There were
times when the Fake Sam Sloan would post 20 or 30 articles in a batch,
covering all of the active discussion topics so that is became
difficult to find the real discussions that were taking place.

Eventually, every regular viewer of the groups came to realize that
there was a Fake Sam Sloan posting and that there were certain
telltale signs to make it possible to distinguish between the Real Sam
Sloan and the Fake. For example, postings by the Real Sam Sloan were
usually long and literate. Postings by the Fake Sam Sloan were usually
short and obscene, often only one line long.

One problem was that there were imitators. At one point there seemed
to be four Fake Sam Sloans posting, each with a different writing and
posting style, so this made it even more difficult to distinguish the
Real Sam Sloan from the Fakes.

However, the other Fake Sam Sloans would usually lose interest and
quit after a short while. The Real Fake Sam Sloan continued
persistently for more than a solid year with no breaks, whereas the
Fake Fake Sam Sloans would quit after a week or two.

A break came when the Fake Sam Sloan abruptly stopped posting on July
4, 2006, a day when the real live Sam Sloan was in Philadelphia
handing out campaign literature to the voters and therefore could not
possibly be posting on the Internet. Then, on July 21, 2006, just
after the votes had finished being counted and it had been determined
that Sam Sloan had been elected, ChessPromotion, previously identified
as Paul Truong, started a barrage of postings attacking Sam Sloan,
often posting as many as 25 times in one day to the USCF Forums.

Although the style of writing and other things were different, one
similarity was the habit of filling up all the active discussion
topics with the same repetitions messages so that no other subject
could be discussed. Only the Fake Sam Sloan had done that and when
Paul Truong started doing the same thing, it suddenly became apparent
that Paul Truong was the Fake Sam Sloan.

That was not the only clue. Almost from the beginning, ever since July
17, 2005, Stan Booz and Neil Brennen had both been saying that Paul
Truong was the Fake Sam Sloan. However, since Booz and Brennen were
themselves suspected of being the Fake Sam Sloan, their postings were
discounted.

The first Fake Sam Sloan posting was on June 25, 2005 as
whoc...@registerednurses.com from NNTP-Posting-Host: 66.2.156.67 .

That was just as the real live Sam Sloan was flying to Chicago to play
the Famous Grudge Match against Bill Brock. That Fake Sam Sloan
clearly knew that the Real Sam Sloan would be flying to Chicago and
would not be on the Internet at that point in time. That Fake Sam
Sloan seemed to be Ray Gordon. He posted 16 times from that address
and quit only three days later on June 28. He last posted from NNTP-
Posting-Host: 66.2.156.242 .

Previously, somebody was posting from whoc...@registerednurses.com
but as Ray Gordon, who wrote on June 18, 2005 from NNTP-Posting-Host:
4.237.38.175 : "What do you expect from scumbags like Booz and his
chief bull dyke Marinelle?"

This is the form of postings by the Fake Sam Sloan to the present. A
Google search of the word bulldyke (one word) will show that this word
has been used 41 times, always by the Fake Sam Sloan and always in
reference to Beatriz Marinello. Bull dyke (two words) had been used 73
times, always in reference to Beatriz Marinello.

Because there were nine postings from as whocares @
registerednurses.com and signed Ray Gordon from June 18 to June 24,
2005, but after that postings from as whoc...@registerednurses.com
were signed Sam Sloan, this led everyone to conclude that the Fake
Sam Sloan was Ray Gordon. However, the Real Ray Gordon denied that
this was him, and it now seems obvious that that was a Fake Ray
Gordon. There were many other postings by a Fake Ray Gordon later on
and the Real Ray Gordon actually filed suit in federal court in the
Eastern District of Pennsylvania against Google about this. He lost
the case and the court's decision against him has become part of his
signature.

Previously, there were 22 unsigned posting from that same email
address. Most of them attacked Marinello as a Bull Dyke, but many of
them also attacked Goichberg, Channing and Hanke as well. One said:

"beatchess, goichberg, hanke, ES are all scumbags. Who gives a fuck
about them?"

The next Fake Sam Sloan first posted on June 28, 2005 from
sl...@journalist.com and NNTP-Posting-Host: 66.2.156.214 and last
posted on December 17, 2005 from that address. He thereafter
immediately shifted over the sl...@whoever.com and started posting
from there. It was clearly the same fake, as the writing style and
content was the same.

On July 18, 2005, there was a posting from and NNTP-Posting-Host:
4.237.41.219 but signed StanB which said: "Sam, you're a scumbag. Do
you like 12 year old girls?"

This seemed to be something that the real Stan Booz would write,
leading many to conclude that Stan Booz was the Fake Sam Sloan. Just
six minutes later there was a posting from the same email address but
from NNTP-Posting-Host: 4.237.38.188 which said:" What about a
bulldyke like Marinello? Who does she have to play with?"

The last posting from sloan @ journalist .com was on January 11, 2006
and NNTP-Posting-Host: 64.12.116.69

The next Fake Sam Sloan seems to have been a different person. This
Fake Sam Sloan never attacked Marinello but attacked other people
instead, posting at sl...@whocares.com and NNTP-Posting-Host:
152.163.100.69 from only January 4 to January 11, 2006.

There have been several other Fake Sam Sloans, but they do not show
the characteristics of the main one, who most often calls Marinello a
bulldyke. For example there was sams...@ishiipress.com (note the ii
in ishiipress) who only posted a few times.

The most recent Fake Sam Sloan is sams...@usa.com This one first
posted on March 17, 2006 from NNTP-Posting-Host: 205.188.117.73 and
last posted on July 4, 2006 from NNTP-Posting-Host: 152.163.100.67 .

Here is that last posting: "I left you alone for a few weeks and now
you want to go crazy? Up yours scumbag! You're history. Run asshole! I
hate all the fucking bull dykes in the USCF. They can all gag on my
dick. "Sam Sloan"

The latest Fake Sam Sloan had learned to delete his postings shortly
after they appeared. During the election period he would often post 20
or 30 per day. However, those that survive in some format were those
to which there was a response. Most regulars learned to just not
respond so that they would go away.

What is the proof that the main Fake Sam Sloan was all this time Paul
Truong? In 2004, Paul Truong called me to inform me that Beatriz
Marinello was a lesbian. I told him that I did not believe it, as she
had been married to a prominent New York chess master. Truong replied
that this was just a green card marriage.

A consistent theme throughout these Fake Sam Sloan postings is that
Beatriz Marinello is a bulldyke. Most people have no care nor concern
about the private life of a chess player or anybody else for that
matter. Obviously the Fake Sam Sloan does.

The Fake Sam Sloan consistently has certain people that he attacks.
Most notable are Stan Booz and Neil Brennen. He also attacks Ray
Gordon and Tim Hanke.

So, one must look for someone who dislikes Sam Sloan, Beatriz
Marinello, Stan Booz, Neil Brennen, Ray Gordon and Tim Hanke.

Paul Truong is known to dislike all those people. There are few people
who dislike all of those people, especially since most people who like
Sam Sloan dislike Beatriz Marinello and most people who like Beatriz
Marinello dislike Sam Sloan.

There is the fact that the Fake Sam Sloan and the Real Paul Truong
often post as many as 25 times per day. Not many people have time for
that. Truong says that he is retired and apparently has lots of spare
time on his hands.

Truong has a long history of creating fake personalities. For example,
it is proven that he was "Bob Bennett" although he still denies this.
Paul Truong now posts as ChessPromotion to the USCF Forums and as
ChessMarketing to the Yahoo groups and never signs his real name.

Two of the primary targets of attack by the Fake Sam Sloan have stated
from the beginning that Paul Truong was the Fake Sam Sloan.

On July 17, 2005, Stan Booz wrote: "I don't; I think its your good
buddy PT."
http://groups.google.com/group/rec.games.chess.politics/msg/668ac6133...
On July 17, 2005, Neil Brennen wrote (obviously referring to Paul
Truong):
http://groups.google.com/group/rec.games.chess.politics/msg/8abb320be...
"> >http://www.geobytes.com/IpLocator.htm?GetLocation
> OK. This is mildly interesting but does not prove much.
> sloan @ journalist.com (one of the fake posters) posts at 4.237.41.136
> According to the above website, that is in Flushing, NY.

"Doesn't a well-known female GM (recently praised in a press release
by an alleged co-worker as one of the three top GMs in the world) run
a chess school near Flushing? Didn't the male half of Trollgar like to
post under assumed names?"

Under the heading Who am I? In a posting that was soon thereafter
deleted, the Fake Sam Sloan provided a list of 11 persons who could
possibly be himself.

As chess master Bruce Leverett noted, the Fake Sam Sloan would have to
be a person whose name was not on the list and who has a history of
deleting his own postings.

http://groups.google.com/group/rec.games.chess.politics/msg/16ab72bf6...

Paul Truong fits both criteria. Thus, it is proven that Paul Truong is
the Fake Sam Sloan. All evidence points to Truong. No evidence points
in any other direction. Truong had the knowledge, the resources, the
motivation and the capability to perpetuate this hoax. Being retired
he has a lot of time on his hands and the time and the resources to
post as many as 25 of these fake messages per day.

When all other possibilities have been excluded, the remaining one,
however improbable, must be the truth.

The Real Sam Sloan

51. In response to the above letter, Goichberg and Channing did not
take any appropriate action which might have included further
investigation to establish the identity of the Fake Sam Sloan. To the
contrary, Goichberg, without board authorization, wrote the first of
five letters to USCF Counsel Michael Matsler asking how he could get
rid of Sam Sloan and stop him from taking his seat on the board to
which he has been elected. To his credit, Mr. Matsler replied to each
of these letters that basically there was no way to do it without
risking legal liability and that for example refusal to certify the
election results would be ineffective. (These five letters are
available on the Confidential USCF BINFOS online.) Michael Matsler's
attorney's bill for August 2006 of $2,790 and for September 2006 of
$1998, for a grand total of $4788 was for responding to these repeated
inquiries by Bill Goichberg asking how to get rid of Sam Sloan. These
bills were paid by the USCF and Plaintiff contends that Goichberg
should reimburse the USCF because it was only in the interest of
Goichberg and not in the interest of the USCF that Sloan not be
allowed to take his seat on the board.

52. Throughout his one year on the board, Plaintiff demanded that the
USCF undertake an investigation to determine who the Fake Sam Sloan
was. The board had it easily within its power to determine the
identity of the Fake Sam Sloan because during the latter half of 2006
and the first half of 2007 it often occurred that the Real Sam Sloan
(the plaintiff here) would post something to the USCF Forums, which
are closed and can only be read by registered adult USCF members, and
within 15 minutes the Fake Sam Sloan would copy and paste the same
thing to the public newsgroup, rec.games.chess.politics , while
usually changing a few words to exaggerate or reverse the meaning.
Since there is usually light traffic on the USCF Forums with five or
less members logged in at any one time, and since this happened often,
it would have been an easy task for Mike Nolan, the USCF website
administrator, to determine which one of those five was the Fake Sam
Sloan. Also, Mike Nolan could have done the same thing that Brian
Mottershead did last week, which was check the IP address of Paul
Truong and Susan Polgar and compare that with the IP address of the
Fake Sam Sloan and the Fake Ray Gordon. Not only did Bill Goichberg
and Joel Channing fail to tell Mike Nolan to do this but rather they
told him not to do it. They also severely and publicly criticized
Sloan for making this suggestion and publicly censured him for this.

53. The above facts and circumstances clearly establish that not only
Polgar and Truong but also Goichberg and Channing were active
participants in the impersonations of Sloan in the three thousand
Internet postings by the Fake Sam Sloan. For these and other reasons,
Polgar, Truong, Goichberg and Channing should be removed from the
Executive Board of the United States Chess Federation and should be
made to pay money damages. It may also be pointed out that there may
be criminal penalties for the above actions.

COUNT II

THE PICTUREGATE AFFAIR

54. Plaintiff repeats and re-alleges each and every allegation of
Paragraphs 1 though 53 of this complaint.

55. After Sloan won the 2006 election, catching Polgar, Truong,
Goichberg and Channing off-guard because they thought he had no
chance, Polgar and Truong who had been silent during the election
campaign suddenly launched a tremendous barrage of personal attacks on
Sloan. A bizarre claim that Polgar suddenly made was that in 1986 when
Sloan was staying as a guest at the Polgar home in Budapest, Sloan had
propositioned Polgar and asked to sleep with her when she was "a minor
at the time". She claimed that she had rebuffed his advances, that
Sloan had been kicked out of the family home and that she had not had
anything to do with him or wanted anything to do with him ever since.
It was stated that Sloan was a "child molester" for wanting to sleep
with a 17-year-old girl, Susan Polgar.

56. Sloan countered that nothing like that has occurred, Sloan had
never been kicked out of the Polgar Family home in Budapest. He has
stayed there several times in 1986 the last time being when they all
departed together to play in the Copenhagen Open Championship in
Denmark won by Smyslov and after that they had traveled together to
chess tournaments in San Juan Puerto Rico and Rio Gallegos Argentina
and that a book published by Laszlo Polgar, Susan's father, in
Budapest, showed Sam Sloan and Susan Polgar together appearing very
friendly to each other. In addition Sloan pointed out that in 2003
Susan Polgar had asked Sloan to pose with her for a picture taken by
Truong and that picture is available on the Internet by a simple
Google search for "Sam Sloan Susan Polgar".

57. Polgar and Truong had apparently forgotten about that picture and
when it was discovered by Grant Perks that it was available on the
Internet they started a tremendous barrage of personal attacks on
Sloan, joined in by Goichberg and Channing. This became known in chess
circles as the "Picturegate Affair".

58. Goichberg and Channing repeatedly demanded that the picture be
removed from the Internet. Sloan replied that the picture needed to
stay up because it proved that the accusations by Polgar and Truong
were false. This resulted in Goichberg writing more letters to
attorney Michael Matsler asking what legal action could be taken to
bring about the removal of the picture. This resulted in more legal
bills incurred by the USCF. Goichberg and Channing made a motion that
Sloan be publicly censured for the picture. In the heat of the debate,
Sloan replied that not only was the Polgar-Truong Story entirely false
but the actions of Goichberg and Channing were, "like a bull in a
china shop", at the point of forcing Sloan to reveal what had really
happened between himself and Susan Polgar in 1986 and that his
relationship with Polgar had been "not entirely Platonic".

59. This resulted in even more outrage. On the motion to censure,
Goichberg, Channing and Goichberg's lapdog Hough voted to censure and
Schultz and Marinello voted against. Sloan was required to abstain and
so the motion passed. The motion publicly censuring Sloan for the
Picturegate Affair and related matters was publicly posted on the Home
Page on the uschess.org website where it has been read by tens of
thousands and possibly millions of people.

60. Plaintiff contends that this public humiliation of Sloan and two
other motions censuring Sloan that were also posted on the USCF Home
Page were entirely unwarranted and improper and as a result the
defendants should be required to pay to Plaintiff ten million dollars
in damages.

COUNT III

ACCUSATIONS THAT PLAINTIFF IS A CHILD MOLESTER AND A PURVEYOR OF
"KIDDIE PORN"

61. Plaintiff repeats and re-alleges each and every allegation of
Paragraphs 1 though 60 of this complaint.

62. Throughout this entire affair, defendants to this action have
posted thousands of times on the public Internet accusations that
Plaintiff is a child molester, a pornographer and a purveyor of
"kiddie porn". This accusation is utterly false. Not only is it not
true but Sloan has never been arrested, convicted, accused,
investigated, charged, questioned or anything of that nature by any
competent legal authority. Nevertheless these accusations have been
posted so many thousands of times that the response by others is, "if
that is true, stop bothering us and call the cops".

63. The main purveyor of these false accusations in Defendant William
Brock. Brock was banned from posting to the USCF Forums for this but
he has continued to post to other public forums the same or similar
accusations, including even on the Wikipedia Encyclopedia where he
listed Sloan under the category of "child molesters". Nobody seems to
know why Brock keeps doing this. In this, Brock has been joined by
Polgar and Truong posting both as themselves and as the Fake Sam
Sloan, by Herbert Rodney Vaughn, by Joel Channing and by several other
defendants.

64. Please note that unlike traditional print media such as newspapers
which are often thrown away and forgotten about the next day, these
Internet postings will be preserved and kept for the next one thousand
years long after all of us are dead. Even if the original posters
decide to delete these postings they will already have been picked up
and spread around the Internet. A simple search for the words Sam
Sloan child molester will return numerous postings mostly by Bill
Brock. There are so many that they can never be completely removed.

65. Plaintiff demands judgment in the amount of ten million dollars
for the allegations in this count.

COUNT IV

ILLEGAL SALE OF THE USCF BUILDING IN NEW WINDSOR NY AND ILLEGAL MOVE
TO CROSSVILLE TENNESSEE

66. Plaintiff repeats and re-alleges each and every allegation of
Paragraphs 1 though 65 of this complaint.

67. At the annual USCF Delegates meeting in Cherry Hill NJ in August
2002, Frank Niro, who was USCF Executive Director at the time,
proposed that the USCF sell the building in New Windsor NY and move to
Miami, Florida where the World Chess Hall of Fame would offer land to
build a building there. Niro claimed that he had a buyer for the
building in New Windsor who was willing to pay $600,000, which was
more than the market value of the building, because this buyer wanted
to build a shopping mall there and had already purchased all the
surrounding property and just needed this one last piece.

68. Because Frank Niro was at that time held in high regard and it was
not yet known that he was a big crook, the delegated voted by a slim
margin to approve this plan.

69. Turns out that the whole thing was a lie, a complete fabrication.
There was no such buyer. Nobody was planning to build a shopping mall
there. Also, the proposal from the World Chess Hall of Fame that the
USCF build a building on their land was an exceptionally bad deal.
Since there was no such buyer, the building was not sold at that time.

70. In November 2004, Bill Goichberg, who by then had become Executive
Director, on his own without any vote by the delegates or the board,
sold the New Windsor Building for $513,000.

71. This was an exceptionally bad deal and would never have been
approved by the delegates. Goichberg claimed that the August 2002 vote
to sell the building gave him the authority to sell it in November
2004, more than two years later, without further action by the board.
However, between 2002 and 2004 as everybody knows the market for real
estate similar to this building had doubled. While $600,000 in 2002
might have been a good deal, $513,000 in 2004 was an exceptionally bad
deal.

72. The Board subsequently voted to move to Crossville, Tennessee. The
final vote to move was a telephone vote that passed by only 3-1 and
was taken just weeks before the new board was going to take over. By
then, three board members had dropped out and there were only four
active board members left. One of the drop-outs, VP of Finance Tim
Hanke, had left a message that he had volunteered to go to Iraq and
fight in the War. His final message dated February 2004 was about
Polgar's threat to sue him. This decision to move to Crossville was
taken without asking for or receiving the advice of legal counsel.
Plaintiff maintains that the legal requirements for a volunteer board
of a not-for-profit corporation to bring about such a major move and
change were not met.

73. The move to Crossville has proven to be a disaster. Apparently,
the board believed that the USCF could hire the hillbillies in
Crossville cheaper than the big city slickers in New Windsor. The
opposite has proven true. The new hires in Crossville were all hired
at higher salaries than their laid-off counter-parts in New Windsor
were making. In addition the new people in Crossville make a lot of
mistakes. The fact that the board hired an utterly worthless Executive
Director has not helped either. The USCF lost a reported $130,000
during its first fiscal year in Crossville. Although in the just
completed fiscal year after Grant Perks cooked the books, there is an
officially reported surplus of $3,000, that includes $107,000 in
imaginary money and in real money the USCF lost $150,000.

74. Plaintiff demands a declaratory judgment that the sale of the
building in New Windsor and the move to Crossville was null and void.

COUNT V

FINANCIAL IRREGULARITIES INCLUDING THE PENSION/PROFIT SHARING PLAN AND
OTHERS

75. Plaintiff repeats and re-alleges each and every allegation of
Paragraphs 1 though 74 of this complaint.

76. Prior to being elected to the board Plaintiff was informed by a
former CFO of the USCF that there were major irregularities in the
pension/profit sharing plan and in one case as large sum of money that
was owed to a former employee had been absorbed into the general
operating account instead.

77. Accordingly, as soon as Plaintiff took his seat on the board, at
his first meeting of the board on August 14, 2006, he immediately
demanded complete information about the Pension / Profit Sharing Plan.
Bill Hall, Executive Director, stated that he could not do that
because virtually all USCF records from the former New Windsor office
had been lost or destroyed during the move to Crossville. A debate or
discussion of this subject continued for about 45 minutes. Everybody
on the board understood that the records were going to be unavailable.

78. As a member of the board, Plaintiff was legally a Trustee of the
Pension/Profit Sharing Plan. Accordingly, Plaintiff feared being
implicated in a cover up if he kept secret the fact that all financial
records had been lost or destroyed. Therefore, after waiting for a
week in the hope that the missing records might turn up, Plaintiff
went public with this and revealed this information.

79. Bill Goichberg immediately started yelling and screaming in public
that this was not true and he has frequently cited this as a false
statement by Sloan. Meanwhile, the missing financial records have not
shown up.

80. More than one year has since passed. In all this time, not one
document, not one financial record, not even one piece of paper from
the New Windsor Office has been produced. It is true that the 2003
Truong four-way contract and the 2000 AF4C contract to hold the US
Championship have been produced and these were two of the documents
that Plaintiff had been demanding, but those documents were found in
the files of the USCF's lawyer Michael Matsler, not in the USCF
offices in Crossville.

81. One of the perks of being on the board are that board members are
appointed as liaisons to various committees. There are numerous
volunteer committees of the USCF and members of those committees are
usually experts in that field. For example, members of the USCF
ratings committee are likely to be PhDs in probability and statistics.
However, after Sloan took office on the board Goichberg refused to
appoint Sloan as a liaison to any committee, not even to the new
committee that had been formed on Sloan's motion, the Olympic Hosting
Committee. Thus, Sloan and the members who voted for Sloan were denied
the influence that a board member is entitled to have.

82. After Sloan took office on the board, Goichberg, as USCF
President, instructed Dan Lucas, the editor of Chess Life, not to
publish Sloan's name in the magazine, except as required for being a
member of the board. Thus, if Plaintiff played an interesting game of
chess, that game would not be published in Chess Life. On at least two
occasions a journalist submitted an article for publication in Chess
Life with the name of Sam Sloan in the article and the editor of Chess
Life struck out Sloan's name, so that when the article appeared the
name of Plaintiff was not there. In addition, Plaintiff is a publisher
of books and published four chess books while on the board. The
regular book reviewers for Chess Life submitted reviews of Sloan's
books for publication in Chess Life magazine and none of these reviews
have been published for the same reason.

83. Because of the allegations in this complaint as set forth above,
including the allegations made by Bill Goichberg, William Brock and
other defendants, Plaintiff was expelled from the Marshall Chess Club
located at 23 West Tenth Street, New York NY in April, 2007. Plaintiff
had been a regular denizen of that club for more than 40 years since
1964. Plaintiff has suffered grievous loss and harm as a result of
being expelled from the Marshall Chess Club, all of which was caused
by the Defendants.

84. The by-laws of the USCF require that either a transcript or a tape
recording of ever meeting of the USCF Executive Board be posted on the
Governance page of the USCF Website. Plaintiff has persistently
demanded that this by-law be observed and that a tape or a transcript
of the meeting in Oak Brook Illinois held on August 14, 2006, the
meeting held in Stamford Connecticut on November 17-18, 2004, the
meeting held in Monrovia, California on February 3-4, 2007 and the
telephone conference call in which the US Championship was discussed
held on February 25, 2007 be posted on the USCF website. These demands
have been ignored. Plaintiff has been harmed by this, because if those
tapes or transcripts were posted it would prove that Goichberg,
Channing and Hall are lying and Sloan is telling the truth and not the
other way around, because Goichberg, Channing and Hall claim that they
are telling the truth and Plaintiff is lying.

85. Plaintiff is a close personal friend of Bobby Fischer, a former
World Chess Champion and a fugitive from justice. The USCF by-laws
have stated that all US grandmasters recognized as US grandmasters by
FIDE, the World Chess Federation, are automatically USCF members. They
thus should have their membership ID number posted on the USCF
website. Bobby Fischer is recognized by FIDE as a US Grandmaster and
thus under the by-laws is automatically a USCF member. USCF President
Bill Goichberg has refused to put the name and ID Number of Bobby
Fischer on the USCF Website on religious grounds in that Fischer is
anti-Semitic. This is a violation of 42 USC 1983. This court should
order that Bobby Fischer be recognized as a USCF member and his name
and number be placed on the website. (As far as being a fugitive from
justice is concerned, the USCF has 600 prison members, some of whom
are psychopathic mass murderers. This is not by any means a bar to
USCF membership.)

86. Plaintiff, while a member of the board, has persistently demanded
to see all documents pertaining to the Pension/Profit Sharing Plan.
Plaintiff believes that the USCF has either a huge liability or else
no liability at all. In 2003 the USCF had 40 employees. On August 20,
2003, Beatriz Marinello, the new USCF President, fired 17 of them. In
2005, at the time of the move to Crossville, only seven employees
agreed to move, and the rest were dismissed. Thus, the USCF has 33
former employees who have worked an average of seven years. Because
almost all records have been lost or destroyed, it has been impossible
to identify which employed are entitled to receive benefits. While
Plaintiff was on the board, the USCF made two payments to former
employees of about $23,000 each. The employees were Jamie Anson and
Barbara DeMaro. Plaintiff is informed by a former CFO that one of
those two was not entitled to any money at all. Since the USCF
Executive Director has been persisting stonewalling on this issue,
plaintiff demands that the court order the relevant documents be
produced, if they can be found and still exist.

87. During the year 2006, Chess Life magazine was filled with pictures
of Polgar, articles about Polgar to such an extent that in some issues
one could hardly turn a page with out finding more about Polgar. As a
result, Chess Life became known sarcastically a "Polgar Life
Magazine". During this entire time Polgar has played in only two chess
tournaments and both of those tournaments were unofficial 30-minute
events not rated by FIDE. Thus, Polgar had done nothing in 2006 to
justify any publicity at all. This tremendous amount of favorable
publicity was part of a conspiracy for her and her followers to run
for election and be elected, so as to gain financial control of the
USCF. They were not even required to pay the normal $250 filing fee to
run, as Polgar has stated on her blogspot that she only spent $50 to
run.

88. Throughout the 2006-2007 year when Plaintiff was on the board,
USCF President blamed almost all of the problems the USCF was facing
on Plaintiff, whereas the real problem was caused by Goichberg. For
example, in November, 2006, Goichberg announced on the USCF website
that the 2007 US Championship would be a 32 player knock-out event
played partly online over the Internet with a final four in Las Vegas.
Qualification to play in the tournament would be about 50% by playing
in Bill Goichberg tournaments such as the North American Open and the
American Open of Randy Hough, which are otherwise small, minor league
events. This was an obvious case of self-dealing.

89. This announcement caused tremendous outrage among the members and
the players, especially the part about playing the US Championship
online. Only one top player, Joel Benjamin, agreed to play. There was
no sponsor. Nobody was willing to ;put up money for this event.

90. This announcement of the online US Championship was never approved
by the board. The board never discussed it and was never notified of
it. The first time the board had ever heard of this plan was when we
read it on the USCF website. The board would never have approved of
this plan if it had been allowed to vote on it.

91. When this plan failed for lack of a sponsor, Goichberg blamed
Plaintiff. It was all because of Sam Sloan that nobody was willing to
sponsor this deal, claimed Goichberg. Actually, Sloan had nothing to
do with it.

92. Finally, in March, 2007, Frank K. Berry of Stillwater, Oklahoma
(and identical twin brother of the newly elected board member) bailed
out the US Championship by putting up $50,000. However, the prize
money was small compared to the 2006 US Championship which has a
$250,000 prize fund and it required the players to travel to Oklahoma
at their own expense. Most of the players live in the New York City
area. As a result, Joel Benjamin protested vehemently and refused to
play. Benjamin had been the only grandmaster willing to play under the
original Goichberg plan of an online US Championship. Benjamin wrote
an article published in "New In Chess" magazine in the Netherlands
stating that all the problems with the US Championship were the fault
of Sam Sloan. Benjamin blamed Plaintiff for things that were actually
done by Goichberg, obviously buying the Goichberg story-line.

93. Throughout the one year that Plaintiff was on the board, Goichberg
operated the USCF on the basis of one man rule. The big issues were
not decided by discussion, debate and vote by the board. Goichberg
decided and no decision by Goichberg could be overturned because he
had the secure vote of his lapdog Hough and the vote of Channing who
has stated that he will vote against anything that Sloan votes for and
vica-versa. Sloan had three votes if he needed them and Goichberg had
three votes whether he needed them or not. It has been the policy of
Schultz to abstain any time he knows that he is on the losing side and
an abstain vote by Schultz is really a no vote.

94. Since in any 3-3 tie vote the motion fails, this meant that
Goichberg could just do any thing he felt like and the opposition
could never overturn his decision because the opposition only had
three votes on a six vote board.

95. The best example of the problem this created was the US
Championship. Traditionally the US Championship is a 16-player round
robin with invitation by rating. Goichberg wanted it to be a big Swiss
with qualification by Swiss tournaments organized by Goichberg and his
allies Hough and Hanken. This of course puts money in Goichberg's
pocket because the players in these big money Swisses must pay entry
fees to Goichberg. The other board members, Sloan, Schultz and
Marinello objected to this. Finally, at the February 3-4, 2007 meeting
in Monrovia, California, Sloan made a motion modified slightly by
Channing which provided that no decision could be made about the US
Championship without a vote by the board. Goichberg surprisingly voted
for this motion and it passed 6-0. Goichberg then proceeded to do what
he had already been doing which is completely ignore the rest of the
board. Goichberg invited whomever he wanted to invite, including an
expert rated girl rated only 2188 while ignoring such really strong
players as Ben Finegold who is rated 2611. The board would never have
approved this. This is just one of many ridiculous and self-serving
decisions that Goichberg made and will continue to make as long as he
is allowed one-man rule of the USCF. Then, when things go wrong,
Goichberg says that it is all the fault of Sam Sloan.

WHEREFORE, for all of the reasons set forth above, Plaintiff demands,

1. An order setting aside the July 2007 USCF election on the grounds
of election fraud and other irregularities.

2. An order reinstating the three board members who lost their seats
in the recent election, who were Sam Sloan, Don Schultz and Beatriz
Marinello, until a new election is held.

3. An order providing that a new election be held at the earliest
practicable date, to be supervised by the Department of Justice.

4. An order baring Paul Truong and Susan Polgar from running for
election in the United States Chess Federation.

5. An order removing Joel Channing and Bill Goichberg from the
Executive Board of Directors of the United States Chess Federation and
barring them from running for election again.

6. An order removing of Bill Hall from his position as Executive
Director of the United States Chess Federation for financial
irregularities and other grounds.

7. An order reinstating Bobby Fischer as a member of the United States
Chess Federation and directing that his membership and ID number be
posted in the Membership Services Area of the USCF website.

8. Damages in the amount of twenty million dollars plus punitive and
exemplary damages.

Samuel H. Sloan
1664 Davidson Ave., Apt. 1B
Bronx NY 10453

(917) 507-7226
1-347-869-2465
sams...@samsloan.com

STATE OF NEW YORK )
ss:
COUNTY OF BRONX )

VERIFICATION

1, 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 2nd Day of October, 2007 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

[The Historian]

On Oct 3, 9:00 am, samsloan <samhsl...@gmail.com> wrote:
> UNITED STATES DISTRICT COURT
> SOUTHERN DISTRICT OF NEW YORK
> __________________________________________
>
> Sam Sloan,
>
> Plaintiff,
>
> -against-
>
> Hoainhan "Paul" Truong, Zsuzsanna "Susan" Polgar, Joel Channing,
> William Goichberg, The United States Chess Federation, Bill Hall,
> Herbert Rodney Vaughn, Gregory Alexander, Frank Niro, Grant Perks,
> William Brock, Randall Hough, Randy Bauer, Jim Berry, Texas Tech
> University and United States of America,
>
> Defendants

(Snip legal twaddle)

Since Sam Sloan has drawn my name into this, let me state for the
record that, aside from my personal stalker (any need to name names?)
and Sam Sloan, I don't know of anyone who suspected me of authoring
the alleged "Fake Sam Sloan" postings. Also, I'm unaware that Mr.
Truong or GM Polgar have any feelings for me one way or another.

[samsloan]

On Jan 22, 3:20 pm, Nomen Nescio <nob...@dizum.com> wrote:
> Exhibit 1
>
> Sloan vs. Truong, Polgar, USCF et al, 07 CIV 8537

> UNITED STATES DISTRICT COURT
> SOUTHERN DISTRICT OF NEW YORK

> Sam Sloan,
> Plaintiff

> -against-
> Hoainhan "Paul" Truong, Zsuzsanna "Susan" Polgar, Joel Channing,
> William Goichberg, The United States Chess Federation, Bill Hall,

> Herbert Rodney Vaughn, Gregory Alexander, FRANK NIRO, Grant Perks,

> William Brock, Randall Hough, Randy Bauer, Jim Berry, Texas Tech
> University and United States of America,
> Defendants
>

> Exhibit 2
>
> DEFENDANTS' MOTION TO DISMISS PLAINTIFF'S COMPLAINT
> PURSUANT TO FEDERAL RULES OF CIVIL PROCEDURE 12(b)(1) & 12(b)(2)
> /../
> Defendant Niro is not locatable. (Brown Affidavit - P5)
> /../
> Dated: January 4, 2008
> PROSKAUER ROSE LLP
> sd/ Jeremy M. Brown
> Jeremy M. Brown (JB-7652)
> One Newark Center, 18th Floor
> Newark, New Jersey 07102
> Telephone: 973.274.3200
> Facsimile: 973.274.3299
> jbr...@proskauer.com
>
> Exhibit 3
>
> Mr. Frank Niro (Chess Safari)
> Address for legal service available from:http://www.blogger.com/profile/11858781138703849298
> Last online: Saturday, January 19, 2008
> Online activity indicator (last 90 days): 23/90
> Email address: <withheld>
>
> Would anyone be surprised that Mr. Niro has been very easily contactable
> at all times since he was discharged from hospital? Even Yahoo correctly
> lists his current address in Oregon City. Not locatable? Think again.
> Want a copy of Mr. Niro's December mail to PR? Reply here to ask.
> Think Bill G. did not have this address during the last 2 months? Think
> again. Think I cannot prove this? Think again.
> Mr. Niro should never have been named in this suit. It is shameful he was
> dragged in. I know why the mistatements were made. To protect innocents.
> Similarly all should understand why the FSS statements were made.
> To protect innocents. Who never checked before they voted.
> Those who think they can was their hands now/ think again.
> What four agree, only one cannot be punished for. United we stand.
> In two weeks Hon. Judge Chin will dismiss the frivolous lawsuit and deny
> permission to appeal. Then the cowardice of the traitors will be exposed.

What you have posted is an Internet Blog address for Frank Niro.
Unfortunately, that is not a street address so we do not know where he
is so that he can be served with legal process.

What this does demonstrate is that Frank Niro is active on the
Internet so he knows about the lawsuit so he has been evading service
of process.

Sam Sloan

[zdrakec]

"7. Prior to the start of this dis-information campaign, Sam Sloan
enjoyed a sterling reputation as an investigative reporter and was
held in the highest regard by the World Chess Community. "

What unmitigated bullshit. I'm sure that Leko, at least, is most
impressed with your qualities as an investigative reporter.

[samsloan]

On Jan 23, 1:00 am, Nomen Nescio <someb...@dizum.com> wrote:
> On Jan 22, 4:59 pm, samsloan <samhsl...@gmail.com> wrote:
> Thank you for your revealing reply to the other anon.
> fyi, I am not the same as any of the other anonymice who've posted in
> other threads. NN is the generic name for people posting via Dizum. As
> your lawsuit has featured repeatedly in the privacy groups, and you are
> quite famous there, you may now have even 10 wannabe FSS anonymice who
> are figuring out how to best troll, forge, mislead or ridicule you.
> Eventually you will realize that the experts upon whom you have relied
> are not that expert and that Paul was victim of a chilling conspiracy.

>
> > Unfortunately, that is not a street address so we do not know where he
> > is so that he can be served with legal process.
>

> A street address in Oregon City is listed by Yahoo's premium (fee-based)
> person finding service.
> Do you actually believe Frank's whereabouts are unknown to each and every
> one of the other defendants and their attorneys?

>
> > What this does demonstrate is that Frank Niro is active on the
> > Internet so he knows about the lawsuit so he has been evading service
> > of process.
>

> That he is active on the internet does not in itself prove anything of
> the sort, as you know.
> Explain to me exactly why Frank deserved this action, as he obviously
> played no role in the FSS affair, and unlike almost everyone else in
> your opinion, did not encourage, collude or conspire with the true FSS,
> or turn a blind eye to his misdemeanors or excesses.
> That you dislike Frank and view him as a failure (and you are not alone
> here) is not any reason to enjoin him in the suit. He is not a well man.
> Do you wish to be responsible for Frank having a relapse?
> If your explanation is compelling (with due respect, the reason in your
> petition is not), I shall email you Frank's address for service.

There is a highly qualified law firm, Proskauer Rose, who has agreed
to provide legal representation to Frank Niro FREE OF CHARGE. All he
has to do is call them and agree to be represented by them.

If you know where Frank Niro is, I suggest that you notify him of this
generous offer.

While you are doing that, you can please ask Frank Niro to return the
laptop computer that Susan Polgar and Paul Truong stole on his behalf.

Sam Sloan

[Nomen Nescio]

Exhibit 1

Sloan vs. Truong, Polgar, USCF et al, 07 CIV 8537

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

Sam Sloan,
Plaintiff

-against-
Hoainhan "Paul" Truong, Zsuzsanna "Susan" Polgar, Joel Channing,
William Goichberg, The United States Chess Federation, Bill Hall,

Herbert Rodney Vaughn, Gregory Alexander, FRANK NIRO, Grant Perks,

William Brock, Randall Hough, Randy Bauer, Jim Berry, Texas Tech
University and United States of America,
Defendants

Exhibit 2

Exhibit 3

[zdrakec]

Oh, if you want to contend perjury, just look at this contention of
Sloan's in his complaint:

"7. Prior to the start of this dis-information campaign, Sam Sloan
enjoyed a sterling reputation as an investigative reporter and was
held in the highest regard by the World Chess Community. "

As bald-faced a lie as I have ever seen.