samsloan
2012-04-03 22:06:51 UTC
IN THE CIRCUIT COURT FOR THE SEVENTH JUDICIAL CIRCUIT
SANGAMON COUNTY, ILLINOIS
SAM
SLOAN, )
)
)
)
Plaintiff )
)
- Against - ) 2011MR000159
)
WILIAM GOICHBERG, )
RANDY BAUER, )
JAMES BERRY, )
RUTH HARING, )
ALLEN PRIEST, )
GARY WALTERS, )
MICHAEL ATKINS, )
MICHAEL NIETMAN, )
BILL HALL, )
CONTINENTAL CHESS ASSOCIATION, INC, )
UNITED STATES OF AMERICA CHESS FEDERATION, INC, )
an Illinois Not for Profit Corporation )
)
Defendants )
OPPOSITION TO MOTION TO DISMISS PURSUANT TO COMBINED MOTION PURSUANT
TO SECTION § 2-619.1 AND - RENEWED MOTION FOR A TEMPORARY RESTRAINING
ORDER AND A PRELIMINARY INJUNCTION
Sam Sloan, being duly sworn, deposes and says:
1. I am the Plaintiff herein. I have personal knowledge of the matters
set forth herein and, if called upon to testify, could and would
competently testify thereto.
2. Although the defendants style this as a combined motion to dismiss
pursuant to SECTION § 2-619.1, they provide no grounds for doing so
nor do they include a memorandum or affidavit or any other evidence in
support of this motion. Plus, this is a singularly inappropriate time
to make this particular motion because of big developments going on
inside the USCF right now. I called opposing counsel to ask why on
Earth he would make this motion right now as opposed to any other
time.
3. It turns out that opposing counsel was totally unaware of the
important events now taking place. What is going on in that on March
20, 2012 (two weeks ago) Gregory Alexander pleaded guilty on San
Francisco Federal Court to one count of hacking into the email account
of Randy Hough, a USCF Board member at the time. As part of his guilty
plea, Alexander read under oath a 10-15 minute prepared statement in
which he described his activities and linked them to others including
Susan Polgar and Paul Truong. As part of the sentence imposed that
day, Gregory Alexander agreed to turn states evidence and to testify
against his co-conspirators. The sentencing judge on this case, Judge
Elizabeth D. LaPorte, stated in open court that it was obvious that
more people were involved in this case than just Alexander and it was
obvious that more wide-ranging offenses or a conspiracy were involved
more than the one hacking offense to which Alexander pleaded guilty.
See
3:09-cr-00719-EMC USA v. Alexander
4. I was present in the courtroom when this happened. Thus, I am a
witness to these events. However, the court immediately thereafter
issued sealing orders. As a result, the PACER file on this case shows
nothing. Take a look at:
https://ecf.cand.uscourts.gov/cgi-bin/HistDocQry.pl?233725420142788-L_1_0-1
5. Looking at the PACER file you will see that two documents were
sealed on March 20, 2012 plus a sealing order was entered pursuant to
Sealing Order - General Order 54 on March 23, 2012.
6. I believe and several others familiar with the case believe that
these sealing orders pertain to sealed indictments. I know of no other
reason why these documents should still be sealed. The USCF is hoping
for and expecting indictments to be issued for Susan Polgar and Paul
Truong. The purpose for the lengthy guilty plea read by Gregory
Alexander was to implicate Polgar and Truong. We have long known that
Gregory Alexander was working for Polgar and Truong. Alexander was
only a pawn in their game, if you will.
7. However, it seems likely that Alexander intends to testify against
more than just Susan Polgar and Paul Truong. I believe that he intends
to testify against Bill Goichberg and Bill Hall as well. It is an
absolute fact that Bill Hall, Bill Goichberg, Susan Polgar and Paul
Truong were all partners in crime, whereas Alexander was just their
agent. They combined forces to stop me from being re-elected after I
had previously been elected to a one year-term on the USCF board.
Then, after I had been defeated for re-election, they started fighting
with each other. Evidence of this conspiracy starts with a meeting
held in Chicago in early August 2006 involving these four persons plus
Bill Brock and Herbert Rodney Vaughn and several other anti-Sam Sloan
people. The purpose of this meeting was to devise a strategy either to
stop me from taking the office on the board to which I had just been
elected or to remove me from the board or to prevent me from becoming
re-elected the following year.
8. The 2500 “Fake Sam Sloan” postings that followed were part of the
strategy by Hall, Goichberg, Polgar and Truong to discredit me. Truong
had already been doing this, as the first Fake Sam Sloan posting
appeared on the Internet in June 2005 while I was playing the infamous
“grudge match” against Bill Brock in Chicago. (I won the match.)
Truong greatly accelerated his Fake Sam Sloan postings after I took
office on the board. (It is a remarkable coincidence, as I think that
it is just a coincidence, that almost everything about this case took
place in Illinois. I was playing chess with Bill Brock in Chicago when
the first Fake Sam Sloan posting appeared. I took USCF office in a
meeting in Chicago in August 2006. Polgar, Truong, Goichberg, Hall,
Brock, and Vaughn held their war conference meeting in Chicago too.)
9. On March 20, 2012, I was allowed to address the federal court as a
victim of the crime and the judge admitted into the record a letter I
had written that the judge had previously read. I annex this letter
hereto as Exhibit A. This letter explains in much greater detail
exactly what the crimes by Alexander consisted of. All these documents
plus a transcript of the guilty plea will become available when the
judge unseals these documents. I am not sure when that will happen but
I suspect that they are waiting for arrests to be made that could
include some of the above named people or possibly all of them.
10. The reason that Gregory Alexander got into the position where he
could commit the crimes for which he has plead guilty is that he was
appointed by Bill Hall and Bill Goichberg to be the moderator of the
USCF Issues Forum, even though Alexander has no background in chess
and was not known to be a chess player. He received the appointment as
moderator because he was outspoken on his attacks on me. Similarly,
Herbert Rodney Vaughn a/k/a tanstaafl was subsequently appointed
moderator because he too had little background in chess but he was
also outspoken in his attacks on me.
11. I really do not know why Bill Goichberg and Bill Hall have been
going to such extreme lengths to stop me from being elected to the
board. They certainly know that I would easily be elected in a fair
election because I am one of the best known chess personalities in the
world and far better known than anybody currently on the board. I
suppose the reason they are so opposed to having me on the board is I
am always pointing out that the USCF has lost money every year since
Goichberg took power except for the one year that I was on the board,
the 2006-2007 fiscal year, and in the most recent year where there was
a small profit. In the years since Goichberg took power in 1996, the
USCF has lost more than $2 million dollars twice plus they allowed
Polgar and Truong to get away with stealing a laptop out of the USCF's
office in New Windsor New York. I have been harping on this issue of
this stolen laptop ever since because it contained all the USCF's
financial data and without it is it impossible to reconstruct what
happened to the missing $2 million dollars. Goichberg and Hall could
have taken steps to recover this missing laptop such as by calling the
police but have not done so.
12. At the telephone conference call by this court on August 22, 2011,
opposing counsel made a number of misleading statements. I was not
allowed to respond and then the judge said “This case is over” and
hung up the telephone. Opposing counsel said that I was guilty of
latches by not pursuing this case more aggressively. The answer that I
was not allowed to give was that all Summer long I had been calling
the clerks of the court asking for a hearing on this matter. The court
officers including the judge's secretary said I could not get a
hearing on my motion for a TRO because the judge was away on Summer
Vacation and could not hear this case until he came back. I also asked
this case to be re-assigned to Judge Zappa who had been the judge on
the predecessor case of Polgar and Truong vs. USCF. I was informed
that while the previous case had been Judge Zappa's case, the new case
was Judge Schmidt's case and could not be reassigned without
permission of Judge Schmidt, who was away. Thus, the first date that I
had been able to get was August 22 which was after the new board had
already taken office.
13. Judge before hanging up the telephone, Judge Schmidt made the
absurd and ridiculous statement that his court lacks jurisdiction to
remove board members from the USCF board and he was not going to enter
an order or entertain a motion to do exactly that without
jurisdiction. This statement was absurd and ridiculous (with all lack
of any respect) because Judge Zappa had done exactly the thing that
Judge Schmidt had said could not be done. Attached as Exhibit B herein
is the Press Release issued by the USCF Executive Director Bill Hall
that said that Susan Polgar and Paul Truong had been removed from the
USCF Board by the order and judgment of the Sangamon County Court.
Here is what the press release says:
USCF Agrees to Settle Lawsuits with Susan Polgar and Paul Truong
By USCF Executive Board
January 23, 2010
The USCF announced it has agreed to a settlement with Susan Polgar and
Paul Truong stemming from lawsuits filed by both parties. Polgar’s
lawsuit, filed in August 2008, alleged libel, slander, defamation and
other claims. USCF’s California lawsuit, adding claims against Susan
Polgar in October 2008, alleged email hacking and wire fraud. The
USCF also filed an Illinois lawsuit against Susan Polgar and Paul
Truong to remove them as Executive Board members and end their
relationship with the USCF for not acting in the best interests of the
USCF.
Under the settlement agreement, all named parties except Gregory
Alexander and Sam Sloan have agreed to dismiss all claims and counter-
claims in the actions in Texas and California. The Illinois lawsuit
will end with a judgment confirming that Susan Polgar and Paul Truong
are no longer Executive Board members. The USCF’s civil case against
Alexander for email hacking and wire fraud continues, and Alexander is
also facing similar federal criminal charges in California.
As part of the settlement, Polgar and Truong have agreed to never
contest the USCF Executive Board’s action in revoking their USCF
memberships; acknowledge that they are no longer members of the USCF
or members of the USCF Executive Board; agree to never seek, run for,
or accept a leadership position in the USCF; and will never contest
the Delegate’s actions that ratified the decisions of the USCF
Executive Board at the August 2009 Annual Delegates Meeting.
Under the settlement, the USCF will allow Polgar and Truong to be
playing, non-members of the USCF and will be listed as “Playing Non-
Member Status.”
The USCF Insurer, Ansur America Insurance Company, a member of
Frankenmuth Financial Group, has agreed to provide $131,000 to the
USCF and $39,000 to Polgar’s attorneys.
The USCF is pleased that this matter is finally settled and that no
USCF funds will go to Polgar and Truong. Additionally, the USCF
receives $131,000 to agree to a settlement.
14. As you can see, the press release specifically states, “The
Illinois lawsuit will end with a judgment confirming that Susan Polgar
and Paul Truong are no longer Executive Board members.” This shows
that at least in the opinion of that judge, this court does have
jurisdiction to remove a sitting board member of a corporation
incorporated in the State of Illinois. By the way, I wrote a book
about this exact subject. My book is entitled “How to Take Over a
Publicly Held Corporation” ISBN 1881373010. It is all about hostile
takeovers of publicly held corporations. Anybody with any knowledge of
corporate law knows that state court judges of chancery can and often
do make changes in corporate boards. The judge of this court who said
in open court that he had no jurisdiction to make changes in the USCF
board may be a fine judge of child custody cases and criminal cases
but he obviously knows nothing about corporate law.
15. Attached hereto as Exhibit C is the very complaint filed by my
worthy opponent in his lawsuit against Polgar and Truong. As you will
see, the allegations in his complaint against Polgar and Truong are
much the same as my allegations against Goichberg and some of the
other defendants. This is not a coincidence. I copied his complaint
and used them to the extent that they apply to some of the defendants
on the current list. Then I filed this case in the same court that he
filed his case for the same reason. I assumed that I would get the
same judge, a judge who knows something about corporate law. Instead,
I got a different judge who knows nothing and says that the courts of
Illinois have no jurisdiction over a case such as this.
16. Regarding my previous statement that now that Gregory Alexander
has gone states evidence and is expected to testify against Polgar and
Truong, I attach Exhibit D which is an affidavit filed by Gregory
Alexander in the related case in San Francisco. As you will see, he
accuses Goichberg and Hall of doing exactly the same things that they
are accusing him of doing. In short, they are all guilty of much the
same crimes. In addition, another egregious violation was committed by
Goichberg and Hall while I was a sitting board member. They allowed
Herbert Rodney Vaughn, an outspoken organizer of anti-Sam Sloan
groups, to come to the USCF's office in Crossville Tennessee and spend
two days browsing and going through the USCF's computer, compiling
information to use in a 400-page ethics complaint Vaughn brought
against me. In so doing, they gave Vaughn access to a tremendous
quantity of private, personal information about USCF members including
their email addresses, used names and passwords. Nobody can know how
much information Vaughn collected or what use he put this too but all
of this was at least unethical and possibly even illegal. Vaughn was
not a USCF employee and not subject to any supervision and oversight.
This was one of the many things that Goichberg and Hall did to stop me
from being re-elected to the board.
17. So here you have the USCF Executive Director, Bill Hall, and the
USCF President, Bill Goichberg, allowing an outsider to use the USCF's
home computer and the USCF Office Staff to compile a supposed ethics
complaint against a sitting member of the USCF Board of Directors. Any
executive director of any normal not-for-profit corporation would have
been fired on the spot for such an outrageous act.
18. The current situation is that the USCF is closer than ever to
going under. Finances are worse than ever. Meanwhile, with the deaths
of Mike Goodall and Jerry Hanken, Bill Goichberg is the only big time
tournament organizer left in the USA. The death of Mike Goodall has an
effect on the outcome of this case, because Mike Goodall was a
delegate and voting member. He died on October 5, 2010. He was my best
friend and I have been appointed administrator of his estate. He died
just after signing my petition to run for USCF election. However, it
was not found among his papers until after the petitioning period had
passed. That one signature was enough even by their count to put me on
the ballot.
19. Goichberg runs the USCF like his own personal company. Even some
members of the current board privately express unhappiness that
Goichberg continues to run the show. However, they can do nothing
because Goichberg's organization, the Continental Chess Association,
pays out about a million dollars in cash prizes every year. At every
election, Goichberg does mass mailings to tens of thousands of USCF
members telling them whom to vote for. Nobody can run against this
machine. The other board members are truly volunteers, but Goichberg
is running the USCF as a business, for personal profit. Meanwhile
services are declining and membership is dropping like a stone because
almost all the membership benefits have been cut except for the right
to play in Goichberg tournaments.
WHEREFORE, for all of the reasons set forth above, this motion to
dismiss should be denied, the motion for a temporary restraining order
and a preliminary injunction must be granted.
___________________
Sam Sloan
1664 Davidson Ave., Apt. 1B
Bronx NY 10453-7877
Tel. 917-507-7226
***@gmail.com
April 3, 2012
Sworn to Before Me this 3rd
Day of April, 2012
________________________
NOTARY PUBLIC
Exhibit A
Letter by Sam Sloan to the sentencing judge in United States against
Gregory Alexander
Exhibit B
Press Release issued by the USCF Executive Director Bill Hall that
said that Susan Polgar and Paul Truong had been removed from the USCF
Board by the order and judgment of the Sangamon County Court.
Exhibit C
The complaint filed by my worthy opponent in his lawsuit against
Polgar and Truong. As you will see, the allegations in his complaint
against Polgar and Truong are much the same as my allegations against
Goichberg and some of the other defendants.
Exhibit D
Affidavit filed by Gregory Alexander in the related case in San
Francisco.
AFFIDAVIT OF SERVICE
I hereby state that I am not a party, I am over 18 years of age and I
served a copy of this motion and the exhibits attached thereto to the
following:
David A. Herman
Giffin, Winning, Cohen & Bodewes
One West Old State Capital Building
Suite 600 - Myers Building
Springfield IL 62701
SANGAMON COUNTY, ILLINOIS
SAM
SLOAN, )
)
)
)
Plaintiff )
)
- Against - ) 2011MR000159
)
WILIAM GOICHBERG, )
RANDY BAUER, )
JAMES BERRY, )
RUTH HARING, )
ALLEN PRIEST, )
GARY WALTERS, )
MICHAEL ATKINS, )
MICHAEL NIETMAN, )
BILL HALL, )
CONTINENTAL CHESS ASSOCIATION, INC, )
UNITED STATES OF AMERICA CHESS FEDERATION, INC, )
an Illinois Not for Profit Corporation )
)
Defendants )
OPPOSITION TO MOTION TO DISMISS PURSUANT TO COMBINED MOTION PURSUANT
TO SECTION § 2-619.1 AND - RENEWED MOTION FOR A TEMPORARY RESTRAINING
ORDER AND A PRELIMINARY INJUNCTION
Sam Sloan, being duly sworn, deposes and says:
1. I am the Plaintiff herein. I have personal knowledge of the matters
set forth herein and, if called upon to testify, could and would
competently testify thereto.
2. Although the defendants style this as a combined motion to dismiss
pursuant to SECTION § 2-619.1, they provide no grounds for doing so
nor do they include a memorandum or affidavit or any other evidence in
support of this motion. Plus, this is a singularly inappropriate time
to make this particular motion because of big developments going on
inside the USCF right now. I called opposing counsel to ask why on
Earth he would make this motion right now as opposed to any other
time.
3. It turns out that opposing counsel was totally unaware of the
important events now taking place. What is going on in that on March
20, 2012 (two weeks ago) Gregory Alexander pleaded guilty on San
Francisco Federal Court to one count of hacking into the email account
of Randy Hough, a USCF Board member at the time. As part of his guilty
plea, Alexander read under oath a 10-15 minute prepared statement in
which he described his activities and linked them to others including
Susan Polgar and Paul Truong. As part of the sentence imposed that
day, Gregory Alexander agreed to turn states evidence and to testify
against his co-conspirators. The sentencing judge on this case, Judge
Elizabeth D. LaPorte, stated in open court that it was obvious that
more people were involved in this case than just Alexander and it was
obvious that more wide-ranging offenses or a conspiracy were involved
more than the one hacking offense to which Alexander pleaded guilty.
See
3:09-cr-00719-EMC USA v. Alexander
4. I was present in the courtroom when this happened. Thus, I am a
witness to these events. However, the court immediately thereafter
issued sealing orders. As a result, the PACER file on this case shows
nothing. Take a look at:
https://ecf.cand.uscourts.gov/cgi-bin/HistDocQry.pl?233725420142788-L_1_0-1
5. Looking at the PACER file you will see that two documents were
sealed on March 20, 2012 plus a sealing order was entered pursuant to
Sealing Order - General Order 54 on March 23, 2012.
6. I believe and several others familiar with the case believe that
these sealing orders pertain to sealed indictments. I know of no other
reason why these documents should still be sealed. The USCF is hoping
for and expecting indictments to be issued for Susan Polgar and Paul
Truong. The purpose for the lengthy guilty plea read by Gregory
Alexander was to implicate Polgar and Truong. We have long known that
Gregory Alexander was working for Polgar and Truong. Alexander was
only a pawn in their game, if you will.
7. However, it seems likely that Alexander intends to testify against
more than just Susan Polgar and Paul Truong. I believe that he intends
to testify against Bill Goichberg and Bill Hall as well. It is an
absolute fact that Bill Hall, Bill Goichberg, Susan Polgar and Paul
Truong were all partners in crime, whereas Alexander was just their
agent. They combined forces to stop me from being re-elected after I
had previously been elected to a one year-term on the USCF board.
Then, after I had been defeated for re-election, they started fighting
with each other. Evidence of this conspiracy starts with a meeting
held in Chicago in early August 2006 involving these four persons plus
Bill Brock and Herbert Rodney Vaughn and several other anti-Sam Sloan
people. The purpose of this meeting was to devise a strategy either to
stop me from taking the office on the board to which I had just been
elected or to remove me from the board or to prevent me from becoming
re-elected the following year.
8. The 2500 “Fake Sam Sloan” postings that followed were part of the
strategy by Hall, Goichberg, Polgar and Truong to discredit me. Truong
had already been doing this, as the first Fake Sam Sloan posting
appeared on the Internet in June 2005 while I was playing the infamous
“grudge match” against Bill Brock in Chicago. (I won the match.)
Truong greatly accelerated his Fake Sam Sloan postings after I took
office on the board. (It is a remarkable coincidence, as I think that
it is just a coincidence, that almost everything about this case took
place in Illinois. I was playing chess with Bill Brock in Chicago when
the first Fake Sam Sloan posting appeared. I took USCF office in a
meeting in Chicago in August 2006. Polgar, Truong, Goichberg, Hall,
Brock, and Vaughn held their war conference meeting in Chicago too.)
9. On March 20, 2012, I was allowed to address the federal court as a
victim of the crime and the judge admitted into the record a letter I
had written that the judge had previously read. I annex this letter
hereto as Exhibit A. This letter explains in much greater detail
exactly what the crimes by Alexander consisted of. All these documents
plus a transcript of the guilty plea will become available when the
judge unseals these documents. I am not sure when that will happen but
I suspect that they are waiting for arrests to be made that could
include some of the above named people or possibly all of them.
10. The reason that Gregory Alexander got into the position where he
could commit the crimes for which he has plead guilty is that he was
appointed by Bill Hall and Bill Goichberg to be the moderator of the
USCF Issues Forum, even though Alexander has no background in chess
and was not known to be a chess player. He received the appointment as
moderator because he was outspoken on his attacks on me. Similarly,
Herbert Rodney Vaughn a/k/a tanstaafl was subsequently appointed
moderator because he too had little background in chess but he was
also outspoken in his attacks on me.
11. I really do not know why Bill Goichberg and Bill Hall have been
going to such extreme lengths to stop me from being elected to the
board. They certainly know that I would easily be elected in a fair
election because I am one of the best known chess personalities in the
world and far better known than anybody currently on the board. I
suppose the reason they are so opposed to having me on the board is I
am always pointing out that the USCF has lost money every year since
Goichberg took power except for the one year that I was on the board,
the 2006-2007 fiscal year, and in the most recent year where there was
a small profit. In the years since Goichberg took power in 1996, the
USCF has lost more than $2 million dollars twice plus they allowed
Polgar and Truong to get away with stealing a laptop out of the USCF's
office in New Windsor New York. I have been harping on this issue of
this stolen laptop ever since because it contained all the USCF's
financial data and without it is it impossible to reconstruct what
happened to the missing $2 million dollars. Goichberg and Hall could
have taken steps to recover this missing laptop such as by calling the
police but have not done so.
12. At the telephone conference call by this court on August 22, 2011,
opposing counsel made a number of misleading statements. I was not
allowed to respond and then the judge said “This case is over” and
hung up the telephone. Opposing counsel said that I was guilty of
latches by not pursuing this case more aggressively. The answer that I
was not allowed to give was that all Summer long I had been calling
the clerks of the court asking for a hearing on this matter. The court
officers including the judge's secretary said I could not get a
hearing on my motion for a TRO because the judge was away on Summer
Vacation and could not hear this case until he came back. I also asked
this case to be re-assigned to Judge Zappa who had been the judge on
the predecessor case of Polgar and Truong vs. USCF. I was informed
that while the previous case had been Judge Zappa's case, the new case
was Judge Schmidt's case and could not be reassigned without
permission of Judge Schmidt, who was away. Thus, the first date that I
had been able to get was August 22 which was after the new board had
already taken office.
13. Judge before hanging up the telephone, Judge Schmidt made the
absurd and ridiculous statement that his court lacks jurisdiction to
remove board members from the USCF board and he was not going to enter
an order or entertain a motion to do exactly that without
jurisdiction. This statement was absurd and ridiculous (with all lack
of any respect) because Judge Zappa had done exactly the thing that
Judge Schmidt had said could not be done. Attached as Exhibit B herein
is the Press Release issued by the USCF Executive Director Bill Hall
that said that Susan Polgar and Paul Truong had been removed from the
USCF Board by the order and judgment of the Sangamon County Court.
Here is what the press release says:
USCF Agrees to Settle Lawsuits with Susan Polgar and Paul Truong
By USCF Executive Board
January 23, 2010
The USCF announced it has agreed to a settlement with Susan Polgar and
Paul Truong stemming from lawsuits filed by both parties. Polgar’s
lawsuit, filed in August 2008, alleged libel, slander, defamation and
other claims. USCF’s California lawsuit, adding claims against Susan
Polgar in October 2008, alleged email hacking and wire fraud. The
USCF also filed an Illinois lawsuit against Susan Polgar and Paul
Truong to remove them as Executive Board members and end their
relationship with the USCF for not acting in the best interests of the
USCF.
Under the settlement agreement, all named parties except Gregory
Alexander and Sam Sloan have agreed to dismiss all claims and counter-
claims in the actions in Texas and California. The Illinois lawsuit
will end with a judgment confirming that Susan Polgar and Paul Truong
are no longer Executive Board members. The USCF’s civil case against
Alexander for email hacking and wire fraud continues, and Alexander is
also facing similar federal criminal charges in California.
As part of the settlement, Polgar and Truong have agreed to never
contest the USCF Executive Board’s action in revoking their USCF
memberships; acknowledge that they are no longer members of the USCF
or members of the USCF Executive Board; agree to never seek, run for,
or accept a leadership position in the USCF; and will never contest
the Delegate’s actions that ratified the decisions of the USCF
Executive Board at the August 2009 Annual Delegates Meeting.
Under the settlement, the USCF will allow Polgar and Truong to be
playing, non-members of the USCF and will be listed as “Playing Non-
Member Status.”
The USCF Insurer, Ansur America Insurance Company, a member of
Frankenmuth Financial Group, has agreed to provide $131,000 to the
USCF and $39,000 to Polgar’s attorneys.
The USCF is pleased that this matter is finally settled and that no
USCF funds will go to Polgar and Truong. Additionally, the USCF
receives $131,000 to agree to a settlement.
14. As you can see, the press release specifically states, “The
Illinois lawsuit will end with a judgment confirming that Susan Polgar
and Paul Truong are no longer Executive Board members.” This shows
that at least in the opinion of that judge, this court does have
jurisdiction to remove a sitting board member of a corporation
incorporated in the State of Illinois. By the way, I wrote a book
about this exact subject. My book is entitled “How to Take Over a
Publicly Held Corporation” ISBN 1881373010. It is all about hostile
takeovers of publicly held corporations. Anybody with any knowledge of
corporate law knows that state court judges of chancery can and often
do make changes in corporate boards. The judge of this court who said
in open court that he had no jurisdiction to make changes in the USCF
board may be a fine judge of child custody cases and criminal cases
but he obviously knows nothing about corporate law.
15. Attached hereto as Exhibit C is the very complaint filed by my
worthy opponent in his lawsuit against Polgar and Truong. As you will
see, the allegations in his complaint against Polgar and Truong are
much the same as my allegations against Goichberg and some of the
other defendants. This is not a coincidence. I copied his complaint
and used them to the extent that they apply to some of the defendants
on the current list. Then I filed this case in the same court that he
filed his case for the same reason. I assumed that I would get the
same judge, a judge who knows something about corporate law. Instead,
I got a different judge who knows nothing and says that the courts of
Illinois have no jurisdiction over a case such as this.
16. Regarding my previous statement that now that Gregory Alexander
has gone states evidence and is expected to testify against Polgar and
Truong, I attach Exhibit D which is an affidavit filed by Gregory
Alexander in the related case in San Francisco. As you will see, he
accuses Goichberg and Hall of doing exactly the same things that they
are accusing him of doing. In short, they are all guilty of much the
same crimes. In addition, another egregious violation was committed by
Goichberg and Hall while I was a sitting board member. They allowed
Herbert Rodney Vaughn, an outspoken organizer of anti-Sam Sloan
groups, to come to the USCF's office in Crossville Tennessee and spend
two days browsing and going through the USCF's computer, compiling
information to use in a 400-page ethics complaint Vaughn brought
against me. In so doing, they gave Vaughn access to a tremendous
quantity of private, personal information about USCF members including
their email addresses, used names and passwords. Nobody can know how
much information Vaughn collected or what use he put this too but all
of this was at least unethical and possibly even illegal. Vaughn was
not a USCF employee and not subject to any supervision and oversight.
This was one of the many things that Goichberg and Hall did to stop me
from being re-elected to the board.
17. So here you have the USCF Executive Director, Bill Hall, and the
USCF President, Bill Goichberg, allowing an outsider to use the USCF's
home computer and the USCF Office Staff to compile a supposed ethics
complaint against a sitting member of the USCF Board of Directors. Any
executive director of any normal not-for-profit corporation would have
been fired on the spot for such an outrageous act.
18. The current situation is that the USCF is closer than ever to
going under. Finances are worse than ever. Meanwhile, with the deaths
of Mike Goodall and Jerry Hanken, Bill Goichberg is the only big time
tournament organizer left in the USA. The death of Mike Goodall has an
effect on the outcome of this case, because Mike Goodall was a
delegate and voting member. He died on October 5, 2010. He was my best
friend and I have been appointed administrator of his estate. He died
just after signing my petition to run for USCF election. However, it
was not found among his papers until after the petitioning period had
passed. That one signature was enough even by their count to put me on
the ballot.
19. Goichberg runs the USCF like his own personal company. Even some
members of the current board privately express unhappiness that
Goichberg continues to run the show. However, they can do nothing
because Goichberg's organization, the Continental Chess Association,
pays out about a million dollars in cash prizes every year. At every
election, Goichberg does mass mailings to tens of thousands of USCF
members telling them whom to vote for. Nobody can run against this
machine. The other board members are truly volunteers, but Goichberg
is running the USCF as a business, for personal profit. Meanwhile
services are declining and membership is dropping like a stone because
almost all the membership benefits have been cut except for the right
to play in Goichberg tournaments.
WHEREFORE, for all of the reasons set forth above, this motion to
dismiss should be denied, the motion for a temporary restraining order
and a preliminary injunction must be granted.
___________________
Sam Sloan
1664 Davidson Ave., Apt. 1B
Bronx NY 10453-7877
Tel. 917-507-7226
***@gmail.com
April 3, 2012
Sworn to Before Me this 3rd
Day of April, 2012
________________________
NOTARY PUBLIC
Exhibit A
Letter by Sam Sloan to the sentencing judge in United States against
Gregory Alexander
Exhibit B
Press Release issued by the USCF Executive Director Bill Hall that
said that Susan Polgar and Paul Truong had been removed from the USCF
Board by the order and judgment of the Sangamon County Court.
Exhibit C
The complaint filed by my worthy opponent in his lawsuit against
Polgar and Truong. As you will see, the allegations in his complaint
against Polgar and Truong are much the same as my allegations against
Goichberg and some of the other defendants.
Exhibit D
Affidavit filed by Gregory Alexander in the related case in San
Francisco.
AFFIDAVIT OF SERVICE
I hereby state that I am not a party, I am over 18 years of age and I
served a copy of this motion and the exhibits attached thereto to the
following:
David A. Herman
Giffin, Winning, Cohen & Bodewes
One West Old State Capital Building
Suite 600 - Myers Building
Springfield IL 62701