COURT OF ARBITRATION FOR SPORT ------------------------------------------------------ DRAFT RAFAEL I.PINKHASOV PINCHAS, Plaintiff -against- STATEMENT OF CLAIM JERALD M.JORDAN, DONALDA K. AMMONS, JOHN M. LOVETT, Defendants. ------------------------------------------------------ THE PARTIES 1. Plaintiff is Rafael I. Pinkhasov Pinchas ( "Pinchas" ),  a former Chairman of the International Committee of  Sports for the Deaf ( "CISS" ) Awards Commission and authority on the history of the CISS and Deaflympic Games, an Olympic-style competition among the deaf people, xxxxxxxxxxx 2. Defendant is Jerald M. Jordan ( "Jordan" ), a former CISS President and unconstitutionally-appointed Member of the CISS Legal Commission, xxxxxxx 3. Defendant is Donalda K. Ammons, an unconstitutionally-elected CISS Secretary General and unconstitutionally-appointed Member of the CISS Legal Commission, xxxxxxx 4. Defendant is John M.Lovett, an unconstitutionally-elected CISS President and unconstitutionally-appointed Member of the CISS Legal Commission, xxxxx 5. Pinchas, Jordan, Ammons and Lovett are profoundly deaf persons and the main modes of their communication are English, American Sign Language and Gestuno, which is the International Sign Language of the Deaf. JURISDICTION 6. Pinchas, a firm believer in law and order and long-time lover and supporter of the international sports movement, voluntarily and fully accepts the jurisdiction of this Court. 7. Jordan, Ammons and Lovett, long-time international sports officials with the CISS, continue to maintain good working relationships with many different International Sports Federations ( including the International Olympic Committee  and General Assembly of International Sports Federations ), which recognize the existence of this Court. Jordan is also the only deaf recipient of the highest award of  the International Olympic Committee - the Olympic Order - since 1995. Therefore, for the reasons stated above, Jordan, Ammons and Lovett should agree to voluntarily, fully and in good faith accept the jurisdiction of this Court. 8. This Statement of Claim is a purely international sports-related  dispute matter. Consequently, since this Court is a specialized international sports law dispute forum, it should be the ideally proper and appropriate place to handle and arbitrate the dispute in question. 9. The decentralized office of this Court in New York City, New York, USA, should be the suggested venue of this arbitration matter because of the residence's proximity of the three out of four litigants in this matter  - Pinchas, Jordan and Ammons, and because of the availability of the American Sign Language interpreters in this city. STATEMENT OF CLAIM 10. Between September 17, 2001 and April 7, 2003, Pinchas as plaintiff and Jordan, Ammons and Lovett as defendants, were engaged in their lawsuit and countersuit actions  titled WMN-01-2758 before the USA District Court for the District Court of Maryland in Baltimore, Maryland, USA. This lawsuit case was closed, in which  no one emerged victorious. 11. Another lawsuit action involving Pinchas as plaintiff and Jordan and Ammons as defendants and titled WMN-03-857 was filed at the same USA District Court for the District Court of Maryland in Baltimore, Maryland, USA., on March 24, 2003. This  lawsuit action was closed on August 8, 2003. One of the main reasons of that case's closure was that "as a general rule, courts will not interfere with the internal affairs of a voluntary membership organization"  such as the CISS,  and that " whether the CISS violated its internal rules is not simply a question for this Court to determine." 12. The main counts of this Statement of Claim are rule violations and defamation of character. These two main counts also deal with the core and crux issue of this Statement of Claim, namely, "Who is the CISS persona-non-grata"? Count One: Rule Violations 13. Below  is the detailed list of 114 different cases of violations presented as Paragraph 14 through 127, each of which was mishandled by Lovett, Ammons and Jordan  between 2000 and to now. These 114 cases demonstrate 343  rule violations of the CISS Constitution ( see Exhibit A ), Deaflympic Games Regulations ( see Exhibit B )   and Deaf World Championship Regulations  ( see Exhibit C ) committed by Jordan, Ammons and Lovett in  2000, 20001, 20002 and 2003: 2000 14. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1., 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he took part as CISS President at the CISS Executive Committee meeting, including his meeting  audience with the IOC President Mr. Juan Antonio Samaranch, in Lausanne, Switzerland. 15. Violations of CISS Constitution rules  7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she took part as CISS Secretary General at the CISS Executive Committee meeting, including her meeting  audience with the IOC President Mr. Juan Antonio Samaranch, in Lausanne, Switzerland. 16. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he took part as CISS President at July 31, 2000 Sydney Olympic Games Torch Relay running. 17. Violation of CISS Constitution rule 10.4.6  as the CISS Executive Committee meeting took place in Taipei, Taiwan. 18. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he took part as CISS President at the CISS Executive Committee meeting in Taipei, Taiwan. 19. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she took part  as CISS Secretary General  at the CISS Executive Committee meeting in Taipei, Taiwan. 2001 20. Violation of CISS Constitution rule 10.4.6 as Rome, Italy, twice - in  March and July, 2001 - hosted  the CISS Executive Committee meetings. 21. Violations of CISS Constitution rules 10.2.7 and 10.2.7.11 as the CISS Home Office was opened in the city of Silver Spring, Maryland, USA. 22. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he took part as CISS President at the March, 2001 CISS Executive Commitee meeting in Rome, Italy. 23. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she took part as CISS Secretary General at the March, 2001 CISS Executive Committee meeting in Rome, Italy. 24. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett, Ammons, Jordan and Ms. Rebecca Adam  as they were engaged as members of the CISS Legal Commission in preparing, drafting and finalizing of the May 24, 2001 CISS Constitution, Deaflympic Games Regulations and Deaf World Championship Regulations booklets. 25. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2, 8.2 and Deaflympic Games Regulations rule 17.D  by Ammons as she made as CISS Secretary General excessive visits to the site of the 19th Deaflympic Summer Games in Rome, Italy. 26. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he took part as CISS President at the July, 2001 CISS Executive Committee meeting in Rome, Italy. 27. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she took part as CISS Secretary General at the July 2001 CISS Executive Committee meeting in Rome, Italy. 28. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he took part as CISS President  at the 37th CISS Congress and 19th Deaflympic Summer Games activities. 29. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she took part as CISS Secretary General at the 37th CISS Congress and 19th Deaflympic Summer Games activities. 30. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he was elected as CISS President for the year period of 2001-2005 at the 37th CISS Congress. 31. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she was elected as CISS Secretary General for the year period of 2001-2005 at the 37th CISS Congress. 32. Violations of CISS Constitution rules 5.1.2, 5.1.2.1, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2  by Mr. Dogan Ozdemir as he was elected as a Member of the CISS Executive Committee for the year period of 2001-2005  at the 37th CISS Congress. 33. Violations of CISS Constitution rules 3.1, 3.1.11, 4, 4.2, 10.4.2, 10.4.3, 10.4.4 and 15 by Lovett, including his CISS Legal Commission, as he excluded Pinchas as an election candidate for the CISS Executive Committee Member position for the year period of 2001-2005 at the 37th CISS Congress. 34. Violations of CISS Constitution rules 3.1 and 3.1.11 by Lovett as he removed  Pinchas and did not give Pinchas the opportunity to renew his term as the Chairman of the CISS Awards Commission for the year period of 2001-2003. 35. Violations of the CISS Constituition rules 3.1 and 3.1.11 by Lovett as he did not give  Pinchas the opportunity to be considered for the vacant and appointed CISS Executive Committtee position of the Sports Director for the year period of 2001-2005. 36. Violation of Deaf World Championship Regulations rule 2.B as Greece was awarded the rights to host the World Championship in Basketball in 2002. 37. Violation of Deaf World Championship Regulations rule 2.B as Israel was awarded the rights to host  the World Championship in Orienteering in 2003. 38. Violation of World Championship Regulations rule 2.B as Taiwan was awarded the rights to host the World Championship in Bowling in 2003. 39. Violation of Deaf World Championship Regulations rule 2.B as Bulgaria was awarded the rights to host World Championship in Badminton in 2003. 40. Violation of Deaf World Championship Regulations rule 2.B as Bulgaria was awarded the rights to host  World Championship in Wrestling in 2004. 41. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 as Lovett was re-appointed as a Member of the CISS Legal Commission. 42. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 as Ammons was re-appointed as a Member of the CISS Legal Commission. 43. Violations of  CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 as Jordan was re-appointed as a Member of the CISS Legal Commission. 44. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 as Ms. Rebecca Adam was re-appointed as a Member of the CISS Legal Commission. 45. Violation of Deaflympic Games Regulations Rule 20.E as  the Official Results Book of the 19th Deaflympic Summer Games was released belatedly. 46. Violation of World Championship Regulations rule 4.D as the final results of the World Championships in Martial Arts held in Ostia, Italy, were never published in the CISS e-News Magazine. 47. Violation of Deaflympic Games Regulations rule 8.C as ice hockey was  included on the program of the 15th Deaflympic Winter Games. 48. Violation of Deaflympic Games Regulations rule 12.A  as deadline date for nations to register in ice hockey as a team sports for the 15th Deaflympic Winter Games was November 1, 2001. 2002 49. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2, 8.2 and 15 by Ammons as on January 4, 2002 she announced as CISS Secretary General about reinstatement of ice hockey as an official medal event of the 15th Deaflympic Winter Games. 50. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he took part as CISS President at the CISS Executive Committee meeting in Sundsvall, Sweden. 51. Violations of CISS Consitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she took part as CISS Secretary General at the CISS Executive Committee meeting in Sundsvall, Sweden. 52. Violations of CISS Constitution rules 5.1.2, 5.1.2.1, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2  as Dogan Ozdemir  took part as a Member of the CISS Executive Committee at the CISS Executive Committee meeting in Sundsvall, Sweden. 53. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she took part as CISS Secretary General at the 46th National Association of the Deaf  of USA Convention and Deafway II. 54. Violations of CISS Constitution rules 10.2.7 and 10.2.7.11 as the CISS Home Office was relocated to the city of Frederick, Maryland, USA. 55. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he met  as CISS President with the President of International Olympic Committee, Dr. Jacques Rogge, and International Olympic Committee Sports Director, Mr. Gilbert Felli, in Lausanne, Switzerland. 56. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he met as CISS President with the President of International Paralympic Committee, Mr. Philip Craven,  in Bonn, Germany. 57. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he took part as CISS President  at the CISS Team Management meeting, including drawing of the 15th Deaflympic Winter Games for ice hockey, in Bonn, Germany. 58. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she took part as CISS Secretary General at the CISS Management Team meeting, including drawing of the 15th Deaflympic Winter Games for ice hockey,  in Bonn, Germany. 59. Violation of Deaf World Championship Regulations rule 1.F  as the First World Championship in Basketball took place July18-28, 2002 in Athens, Greece. 60. Violation of Deaf World Championship Regulations rule 1.G as naming the event as the First World Championship in Basketball for women in Athens, Greece. 61. Violation of Deaf World Championship Regulations rule 1.G as the title of world champions and gold medals were awarded to the members of USA  team among the women at the First World Championship in Basketball. 62. Violation of Deaf World Championship Regulations rule 1.G as silver medals were awarded to the members of Lithuania team among the women at the First World Championship in Basketball. 63. Violation of Deaf World Championship Regulations rule 1.G as bronze medals weree awarded to the  members of Greece team among the women at the First World Championship in Basketball. 64. Violation of Deaf World Championship Regulations rule 2.G as CISS  President or his representative made an inspection visit to the site of the First World Championship in Basketball during the same month in which the proposed championship was to take place. 65. Violation of Deaf World Championship Regulations rule 2. H  as CISS Technical Director in Basketball made an inspection visit to the site of the First World Championship in Basketball, in December, 2001. 66. Violation of Deaf World Championship Regulations rule 13. C ( b ) as the National Sports Association of Greece ( or its Organizing Committee ) arranged and paid an inspection visit by the CISS Technical Director in Basketball to the site of the First World Championship in Basketball, in December, 2001. 67. Violation of Deaf World Championship Regulations rule 5. A  as national teams were invited to take part in the First World Championship in Basketball several months after the end of the 37th CISS Congress. 68. Violation of Deaf World Championship Regulations rule 8.A as final registration of teams for the First World Championship in Basketball were submitted in May, 2002. 69. Violation of Deaf World Championship Regulations rule 13.A  as the National Sports Association of Greece organized the event as the First World Championship in Basketball  ( not as the Deaflympic Championships  in Basketball ). 70. Violation of Deaflympic Games Regulations rule 3.A as Taipei, Taiwan, submitted its bid to host the 21st Deaflympic Summer Games on or before June 1, 2002. 71. Violation of Deaflympic Games Regulations rule 3.A  as Athens, Greece, submitted its bid to host the 21st Deaflympic Summer Games after June 1, 2002. 72. Violation of Deaflympic Games Regulations rule 12. A   as deadline date for nations to register in  men's football as a team sports for the 20th Deaflympic Summer Games was December 1, 2002. 2003 73. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 as Lovet took part as CISS President at the 15th Deaflympic Winter Games activities. 74. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2, 8.2, 10.2.3 and 10.2.3.1  as Ammons took part as CISS Secretary General and Acting CISS President at the  38th CISS Congress and 15th Deaflympic Winter Games activities. 75. Violations of CISS Constitution rules 5.1.2, 5.1.2.1, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2  as Dogan Ozdemir took part as a Member of the CISS Executive Committee at the CISS Executive Committee meeting,  38th CISS Congress and 15th Deaflympic Winter Games activities. 76. Violations of CISS Constitution rules 3.1, 3.1.11 and 15 as Pinchas was not allowed to take part  as a delegate of Uzbekistan at the 38th CISS Congress 77. Violation of Deaflympic Games Regulations rule 3.G as Taipei, Taiwan, chose September 5-15,2009  as the date period  for  hosting the 21st Deaflympic Summer Games. 78. Violations of  CISS Constitution rule 8.2 and Deaflympic Games Regulations rule 3.A  as Park City, Utah, USA, submitted its bid to host the 16th Deaflympic Winter Games before the start of the 38th CISS Congress. 79. Violation of Deaflympic Games Regulations rule 3.G as  Park City, Utah, USA, chose the month of February or March, 2007,  as the date period for hosting the 16th Deaflympic Winter Games. 80. Violations of Deaflympic Games Regulations rules 19. A and 19.C as an official poster of the 20th Deaflympic Summer Games was belatedly released. 81. Violation of Deaflympic Games Regulations rule 4.F as the Organizing Committee of the 20th Deaflympic Summer Games  belatedly appointed its official travel agent for the travel and accomodation needs of all sporting teams that plan to take part at the 20th Deaflympic Summer Games. 82. Viloations of CISS Constitution rules 10.2.3 and 10.2.3.1 as the first day session of the 38th CISS Congress took place. 83. Violations of CISS Constitution rules 10.2.3 and 10.2.3.1 as the Minutes of the 37th CISS Congress were approved at the first day session of the 38th CISS Congress. 84. Violations of CISS Constitution rules 10.2.3 and 10.2.3.1 as Proposal Number 1 ( name change of CISS to IDC - International Deaflympic Committeee ) was voted at the first day session of the 38th CISS Congress. 85. Violations of CISS Constitution rules 10.2.3 and 10.2.3.1 as Proposal Number 2 ( creation of International  Federations in various sports ) was voted at the first day session of the 38th CISS Congress. 86. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2, 8.2, 10.2.3 and 10.2.3.1 as delegation of USA was allowed to participate at the 38th CISS Congress. 87. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2, 8.2, 10.2.3 and 10.2.3.1  as delegation of Australia was allowed to participate at the 38th CISS Congress. 88. Violations of CISS Constitution rules 10.2.3 and 10.2.3.1 as the delegation of Italy was granted an observer status to participate at the first day session of the  38th CISS Congress. 89. Violations of CISS Constitution rules 10.2.3 and 10.2.3.1 as the delegation of Norway was granted an observer status  to participate at the first day  session of the  38th CISS Congress. 90. Violations of CISS Constitution rules 10.2.3 and 10.2.3.1 as the CISS Finance report, including taking away of US $15,000.00 for legal expenses  of Lovett, Ammons and Jordan, was approved by the delegates at the first day session of the 38th CISS Congress. 91. Violation of Deaf World Championship Regulations rule 2. B  as Bulgaria was awarded the rights to host World Championship in Orienteering in 2003. 92. Violations of  CISS Constitution rule 8.2 and Deaf World Championship Regulations rule 2.B  as USA was awarded the rights to host World Championship in Cycling in 2006. 93. Violation of Deaflympic Games Regulations rule 12.H  as determination of a fine in the amount of US $5,000.00 to be levied for the withdrawal of a team from the final round of the 20th Deaflympic Summer Games was made at the 38th CISS Congress. 94. Violation of Deaflympic Games Regulations rule 8.C as water polo was included as a medal event for the 20th Deaflympic Summer Games. 95. Violation of Deaflympic Games Regulations rule 8.C as handball was included as a medal event for the 20th Deaflympic Summer Games. 96. Violation of Deaflympic Games Regulations rule  8. A ( i ) and ( ii ) as beach volleyball was included as a medal sports for the 20th Deaflympic Summer Games. 97. Violation of Deaflympic Games Regulations rule  9.G as athletes of USA were allowed to take part at the 15th Deaflympic Winter Games competitions. 98. Violation of CISS Constitution rule 8.2 as the delegation of USA was allowed to march in the Opening Ceremonies of the 15th Deaflympic Winter Games. 99. Violation of CISS Constitution rule 8.2 as members of the ice hockey team of USA were awarded bronze medals at 15th Deaflympic Winter Games. 100. Violation of CISS Constitution rule 8.2 as Miss Amanda Goyne of USA was awarded the gold medal in women's alpine skiing giant slalom event at the 15th Deaflympic Winter Games. 101. Violation of CISS Constitution rule 8.2 as Miss Kelly Duran of USA was awarded the silver medal in women's alpine skiing giant slalom event at 15th Deaflympic Winter Games. 102. Violation of CISS Constitution rule 8.2 as Miss Amanda Goyne of USA was awarded the silver medal in women's alpine skiing slalom event at the 15th Deaflympic Winter Games. 103. Violation of CISS Constitution rule 8.2 as Miss Kelly Duran was awarded the bronze medal in women's alpine skiing slalom event at the 15th Deaflympic Winter Games. 104. Violation of CISS Constitiution rule 8.2 as Miss Amanda Goyne was awarded the bronze medal in women's alpine skiing parallel slalom event at the 15th Deaflympic Winter Games. 105. Violation of CISS Constitution rule 8.2 as Miss Sheila de Lao of USA was awarded the gold medal in women's snowboarding half-pipe event at the 15th Deaflympic Winter Games. 106. Violation of CISS Constitution rule 8.2 as Miss Marina Lavelle of USA was awarded the silver medal in women's snowboarding half-pipe event at the 15th Deaflympic Winter Games. 107. Violation of CISS Constitution rule 8.2 as Miss Nicole Lanning of USA  was awarded the bronze medal in women's snowboarding half-pipe event at the 15th Deaflympic Winter Games. 108. Violation of CISS Constitution rule 8.2 as Miss Sheila de Lao of USA was awarded the silver medal in women's snowboarding parallel slalom event at the 15th Deaflympic Winter Games. 109. Violation of CISS Constitution rule 8.2 as Miss Marina Lavelle of USA was awarded the bronze medal in women's snowboarding parallel slalom event at the 15th Deaflympic Winter Games. 110. Violation of CISS Constitution rule 8.2 as Mr. Darrick de Lao of USA was awarded the silver medal in men's snowboarding half-pipe event at the 15th Deaflympic Winter Games. 111. Violation of CISS Constitution rule 8.2 as Mr. Jeremy Cline of USA was awarded the bronze medal in men's snowboarding  half-pipe event at the 15th Deaflympic Winter Games. 112. Violation of CISS Constitution rule 8.2 as Mr. Jeffrey Pollock of USA was awarded the bronze medal in men's snowboarding giant slalom event at the 15th Deaflympic Winter Games. 113. Violation of CISS Constitution rule 8.2 as Mr. William Loftus of USA was awarded the bronze medal in men's snowboarding parallel slalom  event at the 15th Deaflympic Winter Games. 114. Violation of Deaflympic Games Regulations rule 7.E as gold, silver and bronze medals were awarded to the winners in  women's nordic skiing 5 km race event at the 15th Deaflympic Winter Games. 115. Violation of Deaflympic Games Regulations rule 7.E as gold, silver and bronze medals were awarded to the winners in women's nordic skiing 10 km classic race event at the 15th Deaflympic Winter Games. 116. Violation of Deaflympic Games Regulations rule 7.E as gold and silver medals were awarded to the winners in women's nordic skiing 3x5 km relay event at the 15th Deaflympic Winter Games. 117. Violation of Deaflympic Games Regulations rule 7.E as gold, silver and bronze medals were awarded to the winners in women's nordic skiing 15 km race event at the 15th Deaflympic Winter Games. 118. Violation of Deaflympic Games Regulations rule 7.E as gold, silver and bronze medals were awarded to the winners in men's nordic skiing 3x10 km relay event at the 15th Deaflympic Winter Games. 119. Violation of Deaflympic Games Regulations rule 7.E as gold , silver and bronze medals  were awarded to the winners in women's snowboarding half-pipe event at the 15th Deaflympic Winter Games. 120. Violation of Deaflympic Games Regulations rule 7.E as gold, silver and bronze medals were awarded to the winners in women's snowboarding giant slalom event at the 15th Deaflympic Winter Games. 121. Violations of Deaflympic Games Regulations rule 7.E  as gold, silver and bronze medals were awarded to the winners in men's snowboarding half-pipe event at the 15th Deaflympic Winter Games. 122. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he took part as CISS President at the XIVth  World Congress of the World Federation of the Deaf activities in Montreal, Canada. 123. Violations of CISS Constitution rules 7.1.2, 7.1.3,  8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she took part as CISS Secretary General at the XIVth  World Congress of the World Federation of the Deaf activities in Montreal, Canada. 124. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Lovett as he took part as CISS Presdent at the CISS Management Team meeting in Montreal, Canada. 125. Violations of CISS Constitution rules 7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 by Ammons as she took part as CISS Secretary General at the CISS Management  Team meeting in Montreal, Canada. 126. Violations of CISS Constitution rules 10.2.7, 10.2.7.7, 10.4.7, 10.4.7.1, 10.4.7.6  and Deaf World Championships Regulations rule 1.H  as  the name of the event as World Deaf Tennis Championship was used for Dresse and Maere Cup events held  in Poertschach, Austria. 127. Violations of CISS Constitution rules  7.1.2, 7.1.3, 8.1.1, 8.1.1.1, 8.1.1.2 and 8.2 as Lovett as CISS President took part at the Dresse and Maere Cup events activities in Poertschach, Austria. Count Two: Defamation  of Character 128. Pinchas invested considerable amount of his time, money and energy by obtaining his advanced university degree in the specialized field of international service. Pinchas, unlike Jordan, Ammons and Lovett,  possesses a  M. A. degree in International Affairs, which he  earned from the School of International Service at the American University in Washington, D. C., USA.. 129. Since the end of July, 2001, Jordan, Ammons and Lovett have denied Pinchas the opportunity to work for the international service organization such as the CISS. 130. During 2002 and 2003, by undermining Pinchas' previous and long time voluntary  international service work on behalf of the CISS,  Jordan, Ammons and Lovett made their numerous defamatory statements about Pinchas publicly. 131. These defamatory statements about Pinchas by Jordan, Ammons and Lovett included, among the other things, their labeling of Pinchas as the "CISS persona-non-grata." 132. Statement by Jordan, Ammons and Lovett such as, "Mr. Pinchas has blatantly, deliberately and intentionally violated Section 15 of the CISS Constitution" ( or, CISS Constitution rule 15 ) was false, misleading and defamatory. 133. Statement by Jordan, Ammons and Lovett such as, "...he ( Pinchas  ) dependent on welfare," was false, misleading and defamatory. 134. Statement by Jordan, Ammons and Lovett such as, "...Pinchas asked the court to allow him to subpoena numerous documents and correspondences from CISS, USA Deaf Sports Federation and its President, Dr. Bobbie Beth Scoggins," was  false, misleading and defamatory. 135. Statement by Jordan, Ammons and Lovett such as, "...Pinchas also asked  the Court to authorize him to be a delegate to the CISS Congress in Sweden," was  false, misleading and defamatory. 136. Statements by Jordan, Ammons and Lovett such as, "The court stated that Pinchas "has offered no evidence beyond his own unsupported allegations" and that plaintiff's descriptions of incidents were "extremely vague and indefinite," were  false, misleading and defamatory. 137. Statements by Jordan, Ammons and Lovett contained in Paragraph 131  through 136  with their false, misleading and defamatory contents against Pinchas have continuously been published over the worldwide internet - the CISS e-News Magazine, Number 213, June 2003 - twenty-four hours a day, seven days a week and are continuing unabated to this day. 138. Because Jordan, Ammons and Lovett have been elected and/or appointed as the CISS officials under the highly-questionable manner and because Jordan, Ammons and Lovett have rampantly, anarchically, blatantly and irresponsibly committed breaches of 343 rules of the CISS Constitution, Deaflympic Games Regulations and Deaf World Championship Regulations in 2000, 2001, 2002 and 2003, it will be the position, argument and justification by Pinchas to demonstrate at a hearing that  Jordan, Ammons and Lovett are the ones ( not Pinchas )  who are the "CISS personas non-grata." 139. Pinchas repeats and realleges all of the allegations contained in Paragraph 11 through 138, inclusive, as if set forth at length. 140. Pinchas suffered aggravation, distress, humiliation, bad image and negative reputation caused by the aforementioned acts of Jordan, Ammons and Lovett. 141. As a direct and proximate result of various acts by Jordan, Ammons and Lovett against Pinchas, Pinchas has suffered actual and consequential damages, including but not limited to damages to his reputation, the amount of such damages are currently unknown but will be proven at a hearing. 142. The acts of rule violations and defamation of character by Jordan, Ammons and Lovett against Pinchas were intentional and were committed willfully and maliciously. 143. As a result, in addition to its actual damages, Pinchas is entitled to exemplary damages in an amount as a hearing panel may find necessary to punish Jordan, Ammons and Lovett for their wrongful conduct and deter Jordan, Ammons and Lovett and others similarly situated, from engaging in such a wrongful conduct in the future. WHEREFORE, Pinchas prays for judgment against Jordan, Ammons and Lovett as follows: a. For compensatory and consequential damages in an amount to be proved at  a hearing but which amount exceeds this Court's jurisdictional minimum. b. For exemplary and punitive damages in an amount sufficient to make an example of Jordan, Ammons and Lovett and to deter them and others similarly situated from engaging in similar wrongful conduct in the future. c. For reasonable costs incurred in this action. d. For such other and further relief as this Court may deem just and proper.            Dated: xxxxx, 2003            Queens, New York, USA Respectfully Submitted, _______________________ Rafael I. Pinkhasov Pinchas Plaintiff TO: Kelby N. Brick, Attorney for Defendants