More of the USCF legal saga: I am not endorsing this lawsuit and I am not commenting on the merit of it. USCF members can make their own conclusion. However, members need to know what is going on before they can make informed decisions.

IN THE CIRCUIT COURT FOR THE SEVENTH JUDICIAL CIRCUITSANGAMON COUNTY, ILLINOISSAM SLOAN, )Plaintiff )- Against - ) 2011MR000159WILIAM 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 )COMPLAINTNOW COMES Sam Sloan, Plaintiff, and hereby files thiscomplaint against William Goichberg, Ruth Haring, Randy Bauer, JamesBerry, Allen Priest, Gary Walters, Michael Atkins, Michael Nietman,Bill Hall, the Continental Chess Association, Inc. and the UnitedStates of America Chess Federation, Inc. (“USCF”) and alleges asfollows:1. This is a proceeding for Declaratory Relief seeking to restore SamSloan to the ballot as a candidate for Election to the Executive Boardof the United States Chess Federation. It also seeks the removal ofWilliam Goichberg from the Executive Board and a permanent bar againstGoichberg from holding any position as an officer of the United StatesChess Federation or from running slates of candidates for election.The Plaintiff Sam Sloan is a long standing member of the United StatesChess Federation, having been a member since 1956. Plaintiff submittedhimself for candidacy for the current 2011 election but has beenremoved from the ballot this year due to Plaintiffs assertion ofvoting regulation manipulation by the Defendants.2. This Court has personal jurisdiction over Defendants as Defendantshave performed duties as directors or officers of a corporationorganized under the laws of Illinois. 735 ILCS 5/2-209(a)(12). None ofthe Defendants reside in Illinois, and therefore venue is proper inthis county pursuant to 735 ILCS 5/2-101. Defendants have previouslyfiled suit in this county and Court, and therefore providesindisputable assertion that venue in this Court is proper. TheDefendants previously filed the case United States of America ChessFederation vs. Susan Polgar and Paul Truong in this same court. Thiscase should be marked as related to that other case.3. Defendant USCF is an Illinois not-for-profit corporation in goodstanding, with its principal place of business in Crossville,Tennessee. The USCF is the official, not-for-profit United Statesmembership organization for chess players and chess supporters of allages and strengths, from beginners to Grandmasters. The average ormedian age of USCF members is ten years old. The USCF is governed by aBoard of Delegates, composed of a seven-member Executive Board,Delegates at Large, and over 125 Delegates apportioned among U.S.States.4. The seven-member Executive Board ("EB") are tasked with managingthe affairs of the USCF between the annual meetings of the Board ofDelegates who are the true Board of Directors for the USCF.5. Defendant James 'Jim' Berry is the President of the USCF. DefendantRuth Haring is the Vice President of the USCF.6. Defendant Randy Bauer is the Vice President of Finance of the USCFwhose term expires at the beginning of the next Board of Delegatesmeeting in July 2011 to be held in Orlando, FL.7. Gary Walters and Michael Nietman are seeking re-election to the EBthrough the 2011 elections.8. Michael Atkins is a long term employee of William Goichberg and theContinental Chess Association, Inc. He has performed significantcompensated duties to William Goichberg prior to Atkins' tenure as amember of the EB.9. Allen Priest is a member or chairman of many USCF committeesincluding the “Forum Oversight Committee” which has acted as a Boardof Censors so as to bar any negative comments about Goichberg or anypositive comments about Sam Sloan from being posted to the USCF IssuesForum. Allen Priest is currently seeking a position on the EB throughthe 2011 elections.10. Bill Hall is the Executive Director of the USCF who is oncontractual terms of employment with the USCF.11. Bill Hall's contract is set to expire this year and is a topic ofrenegotiation for the EB that will be comprised as a result of the2011 election.12. Defendant William Goichberg has been an officer of the USCF aseither President, Vice-President, Executive Director orMember-at-Large since 1996 with minor gaps caused by being 'termedout' from time-to-time in accordance to the Bylaws of the USCF. UnderRule by Goichberg, the USCF has lost more than two million dollars andis now on the brink of bankruptcy.13. Defendant William Goichberg is also the sole owner of theContinental Chess Association ('CCA'), a for-profit corporation, whichis the dominate force in organized, large money stake chesstournaments ($100,000-$250,000 in prizes) across the United States,held under the auspices of the USCF. As such he is also the largestcustomer of the USCF through advertisement fees, fees for rating histournaments, and new membership / renewal membership acquisition.14. In years past there were spirited election campaigns for USCFExecutive Board with many candidates running. For example, in 1999there were 17 candidates running. In 2009 there were ten candidatesrunning. However, in the last few years William Goichberg has becomeextremely aggressive about attacking or blocking anybody opposed tohis policies which benefit his for-profit organization at the expenseof all other organizers and the federation, so as to prevent them fromeven running. As a result, those not in accordance with WilliamGoichberg policies have almost all given up, considering runningagainst the Goichberg machine to be a waste of time and money.15. Defendant Goichberg, in an attempt to provide a false front forhis motives, commissioned the Governance Task Force ('GTF'), which wascomprised of individuals that he exerts influence over.16. The GTF was headed by a personal friend of Defendant Goichbergnamed Joseph Lux. The deputy of the GTF was Defendant Allen Priest, aGoichberg sycophant.17. The USCF and the Executive Board ignored the suggestion ofdelegates to have the GTF members be comprised of a group of crosspolitical parties to ensure fairness. Instead Goichberg sycophantswere the only active members.18. The GTF proposed by-law changes that were presented to a meetingof the delegates held in Irvine California on August 8, 2010 after theelection period had already stated and candidates were circulatingpetitions. The delegates were not informed of the nature and extent ofthe changes and were led to believe that this was a routine measure.The proposal was not announced in advance and was not in the advanceagenda. No count was made so it could not be determined if the 2/3rdsvote as required in the bylaws was met.19. The charter of the GTF was to make recommendations for improvementof the governance structure of the USCF.20. A crucial change that was the outcome of the GTF and voted upon atthe annual meeting of delegates was changes in election processes.First it required a new structure of signatures, where 15 signaturesof delegates were required from 5 different states. Second it requiredUSCF members to register in order to vote.21. This crucial change was hastily implemented during an electionyear, instead of providing time for the new guidelines to becomedistributed appropriately to the USCF membership community and thedelegates that were not able to attend the meeting. The next electionis in 2013, only two years away.22. Meeting minutes from the annual board of delegates meeting werenot made available until December 4, 2010, four months after meeting.No voice or video recordings have been made available, though theywere made during the meeting.23. These by-law changes still as of the date of this complaint havenot been posted. No copy is available anywhere. The posted by-laws arestill not reflective of the important changes that have taken place.They are nearly one year old and are dated May 2010.24. Election petition due dates were changed from previous years. Inpast years, the last day to circulate petitions was January 10. Thisyear it was moved up to December 31, 2010 without adequateannouncement to the membership and the candidates. Delegates not inattendance at the annual meeting in Irvine California on August 8,2010 were not informed of this. Since no communications directed atthe delegates are performed by the federation, those not in attendancein Irvine are not aware of these changes.25. In the closing days of the petitioning period, when two candidateswho were members of the Goichberg Slate did not have enoughsignatures, Defendant Bill Hall changed the 'received by' requirementset forth in the by-laws to 'post-marked' by. This was to benefitmembers of the “Goichberg Slate”, Allen Priest and Gary Walters, whowere having difficulty collecting signatures due to being unknown inthe chess community. Defendant Hall also should have known the officewas to be closed on December 31 and did not communicate that theoffice was closed unless someone proactively asked about it. Thischange in Bylaws is not within the power granted to Defendant Hall asthe Executive Director.26. The Bylaws state that the petitions were to be sent to theElection Committee, not the USCF office. No information on how to sendthe petitions to the Election Committee was provided to any potentialcandidates. Instead all petitions were forced to be sent to the USCFoffice, the same office whose Executive Director has a vested interestin the outcome of the election.27. An appropriate and complete list of delegates were not availableonline and to this date the full list is not known. The lack ofknowing who are the delegates (thus the true directors of thecorporation) means that the federation is filing false documents withthe State of Illinois and are only listing the EB members as the boardof directors (which is incorrect as a bylaw amendment exists statingthat the delegates are the Board of Directors, not the EB).28. Due to the inaccurate and incomplete information on who exactlyare the members of the board of delegates, previous delegates signedelection petitions for Plaintiff Sloan, only to be rejected by theUSCF office.29. The election committee did not receive physical copies(scanned/faxed/photocopied) of election petitions or the proof ofreceipt of petitions by the due date. They received a MS Word documentwith purported names and ID's of people that signed the petitions.This determination was used to qualify or disqualify signatures. TheUSCF staff under the auspices of the Executive Director Bill Hallvalidated each signature themselves. This is a conflict of interest asthere is no independence in the verification process.30. Plaintiff was elected to the USCF Executive Board in 2006 but wasdefeated when he ran for re-election in 2007 in part due to the “FakeSam Sloan” controversy in which another candidate for election who wasat the time allied with William Goichberg impersonated him more than2500 times making obscene and scatological newsgroup postings.Plaintiff is an announced candidate for the current 2011 election buthas been kicked off the ballot this year due primarily to themanipulations of William Goichberg, the long time control person ofthe USCF.31. This action seeks to restore Sam Sloan to the ballot for thecurrent USCF election. Secondly, because Bill Goichberg persistentlyviolates the most fundamental rule involving not-for-profitcorporations in that he runs the USCF for his own personal profit andbenefit by running big money cash prize chess tournaments, Plaintiffseeks the permanent removal of Bill Goichberg from holding any officeor position in the USCF and further seeks a court order enjoiningGoichberg from running slates of candidates for office in the USCF,from posting articles on his websites attacking opponents of hisslates, from circulating petitions to get his candidates on the ballotelected and from in any way interfering in the USCF Election process.32. Defendants Gary Walters, Michael Neitman and Allen Priestconstitute the "Goichberg Slate" in the current USCF Election. MichaelAtkins and Michael Neitman are current members of the USCF ExecutiveBoard. Gary Walters and Michael Neitman are running for re-election.Michael Atkins is a long time employee of Bill Goichberg and hasworked as assistant director at many Goichberg tournaments.33. Defendant William Goichberg is the control person of the USCF.Goichberg dominates and controls the USCF Executive Board. For almostevery year since 1996, with just a few gaps, Goichberg has been acontrol person, holding the positions of President, Vice-President,Executive Director or Member-at-Large for all but a few of thoseyears. Goichberg was USCF President from 2005 to 2010 when he was termlimited out and became member-at-large, but he still controls theboard because, for the last three elections since 2007, no candidatehas been elected to the Executive Board without receiving theendorsement of Goichberg. The “Goichberg Slate” swept the 2008, 2009and 2010 elections. Under Rule by Goichberg the USCF has lost morethan two million dollars and is now on the brink of bankruptcy.34. Defendant William Goichberg is also the sole owner of theContinental Chess Association, a for-profit corporation. TheContinental Chess Association dominates the market for prize moneychess tournaments. During most of the weekends of every calendar year,the Continental Chess Association holds cash prize money tournamentsaround the United States in almost every state except for New Jersey,where Goichberg is unofficially persona non grata. Goichberg holdsmajor big money tournaments in the major holiday weekends, such as his“World Open” held in Philadelphia on July 4th weekend with GuaranteedCash Prizes of $225,000, the Chicago Open with $100,000 GuaranteedCash Prizes, the North American Open in Las Vegas and PhiladelphiaOpen with similar prizes, and until 2009 the Foxwoods Open followingwhich the Foxwoods Casino kicked him out. In addition to these majortournaments, Goichberg holds minor tournaments on most weekends withcash prizes ranging from about $4,000 to about $10,000 each.35. All of these cash prize money tournaments are held under theauspices of the USCF. They are all USCF Rated. They are all advertisedin Chess Life magazine. Goichberg so dominates the market for prizemoney tournaments that it has proven nearly impossible for othertournament organizers to compete with him. Several organizers who havetried to compete against Goichberg have suffered severe financiallosses and some have even gone bankrupt.36. In years past there were spirited election campaigns for USCFExecutive Board with many candidates running. For example, in 1999there were 17 candidates running. In 2009 there were ten candidatesrunning. For many years Goichberg was a pariah in the USCF due to hisrunning exclusively big money tournaments, often in gambling casinos,especially since the median age for USCF members is 10 years old.Goichberg, knowing he could not get elected, did not run. However, inthe last few years Goichberg has become extremely aggressive aboutattacking or blocking anybody opposed to his policies so as to preventthem from even running. As a result, those not in accordance withGoichberg policies have almost all given up, considering runningagainst the Goichberg machine to be a waste of time and money.37. Among the things that Goichberg does to stop anybody not blessedby him from running or being elected is he sends out huge massmailings primarily advertising his prize money tournaments but alsotelling the voters whom to vote for. Goichberg typically mails 17,000(seventeen thousand) postcards in a batch. Goichberg also posts on histournament websites including http://www.chesstour.com/ articlesattacking and ridiculing any candidate not favored or endorsed byGoichberg, for example at http://www.checkmate.us/ . Goichberg alsohires assistant directors for his tournaments who also campaign forhis candidates while running his tournaments and while making pairingsand ruling on disputes.38. Not satisfied with the fact that he already has a virtual monopolyon big time cash prize money chess tournaments and he has such a lockon the elections that almost all would-be candidates have given uptrying to run against him, Goichberg now is trying to avoid evenhaving to go to the trouble to run candidates for election by changingthe election rules so as to make it virtually impossible for anybodynot nominated by Goichberg even to get on the ballot.39. In order to do this a “Governance Task Force” was createddominated by Goichberg himself plus Goichberg sycophants Joe Lux andAllen Priest. Joe Lux was made the Chairman. This “Governance TaskForce” was originally set up to try to address the problems created bythe fact that Goichberg had the USCF in his iron grip. A fatal errorwas made by allowing Goichberg to serve on a committee which wassupposed to deal with the problems caused by Goichberg. Goichbergproceeded to take control of the committee.40. The result was a proposal by Goichberg to disenfranchise the30,000 voting members of the USCF and to give control of the electionprocess to the 125 delegates. Since a high percentage of the delegatesare employees of Goichberg working as assistant directors in the prizemoney tournaments held by Goichberg around the USA and all thedelegates from New York State are personally appointed by Goichberg,this meant that Goichberg would virtually control who got on theballot. The original Goichberg proposal was that in order to get onthe ballot a prospective candidate would need to obtain the signaturesof 40 of the 125 delegates from 15 different states. Since Goichbergholds tournaments in more than 15 different states and more than 40delegates either work for Goichberg or are beholding to Goichberg andsince nobody else does this, this meant that Goichberg would decidewho got on the ballot.41. At the USCF Delegates meeting in Irvine, California in August2010, in response to objections to the Draconian Rules proposed byGoichberg, Goichberg agreed to reduce the number to 25 delegates from15 different states. Goichberg stated at a by-laws committee meetingchaired by Goichberg sycophant Allen Priest that 25 delegates shouldbe required to sign because in the past some of the candidates hadbeen “rather poor”.42. There were still grumblings about this so as the USCF Delegatesmeeting held on August 7, 2010 in Irvine, California a motion was madeto require that candidates for election obtain the signatures of atleast 50 voting members of whom at least 15 must be delegatesrepresenting at least 5 different states. The maker of this motion wasAllen Priest who himself was a candidate for election. This motionpassed with virtually no debate or discussion. Several delegates whowere present and who voted in favor of the motion have since statedthat they did not know what the motion was as it was not explained norwas in announced in advance and they would never have voted for thismotion had they known what it was.43. The by-laws require that there be a 2/3rds vote for any by-lawchange, especially those not included on the advance agenda. Thisby-law change was not in the advance agenda. No count was taken orshow of hands to see if the 2/3rds requirement had been met.44. Since the election campaign was already underway and severalprospective candidates including Gary Walters were circulating themeeting room asking delegates to sign their petitions, this by-lawchange should not have taken effect until the next election cycle,which will be in 2012. However, the Goichberg controlled USCF officehas allowed this by-law change to become effective retroactively sothat it controls the current election campaign which had already beenstarted before this by law change had been voted upon.45. Prior to this change, in order to get on the ballot, a candidateneeded the signatures of 30 adult voting members of which there areabout 30,000. After this change, one needed 50 signatures of adultvoting members of which at least 15 must be delegates representing atleast 5 different states. With only 125 delegates assuming all thepositions are filled (which is not the case) this made it vastly moredifficult.46. In spite of the extreme difficulty of meeting these vastly moredifficult requirements, Candidate Sam Sloan circulated petitions andobtained the signatures of 90 members of which 70 ruled valid. These70 signatures including 16 delegates representing 11 different states.Thus Sloan easily met the requirements.47. Nevertheless, Goichberg Stooge Bill Hall ruled that 4 of thosesignatures were invalid and thereupon has kicked Sloan off the ballot.Most of those allegedly invalid signatures are from the State of NewJersey where Goichberg is persona non grata. The three New Jerseydelegates whose signatures were ruled invalid were former USCFPresident Leroy Dubeck, Steve Ferrero and Aaron Kiedes. They alsoinvalidated the signature of Gary Alan Fine of Illinois and EricJohnson of Pennsylvania.48. At the same time a member of the Goichberg Slate, Allen Priest,did not have enough signatures even though Goichberg was going aroundthe North American Open where he was the director on December 30, 2010(the day before the deadline) twisting the arms of delegates to getthem to sign for Priest. Bill Hall extended the deadline for thebenefit of Allen Priest and Gary Walters (neither of whom aretournament chess players and are only candidates as a result of beingGoichberg stooges) by extending the deadline so that the petitions didnot have to be received but only mailed by December 31.49. Candidate Sam Sloan has never to this day been notified that hehas been kicked off the ballot. Page 10 of the February Chess Lifestates that nominating petitions have been received from fivecandidates, Sevan Muradian, Mike Nietman, Allen Priest, Sam Sloan andGary Walters. However, the April Chess Life, page 11 only lists thenames and candidates of four candidates, omitting Sam Sloan.50. Having eliminated one candidate by having his signatures ruledinvalid, Goichberg is now attacking the remaining non-Goichbergcandidate by stating that he is not “loyal” to the USCF because hescheduled a chess tournament to be held on the same weekend as aGoichberg tournament, the Midwest Class tournament. Seehttp://www.checkmate.us/muradian.htmWHEREFORE, for these any other reasons more fully set forth in theaccompanying affidavits and exhibits, Plaintiff demands the followingrelief:1. An Order Restoring Sam Sloan to the ballot for the coming USCF election.2. An order removing William Goichberg from the board and permanentlybarring William Goichberg from holding any office in the USCF or fromrunning slates of candidates or influencing the results of electionsthrough post card mailings, websites and other means as long as hecontinues to hold large cash prize big money chess tournaments forprofit associated with the USCF.Respectfully Submitted,Sam Sloan

Labels: Chess Politics, Corruption, Dirty Politics, Lawsuit, USCF