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Old March 3rd 05, 10:51 PM
 
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Default Marinello Case: Proposed Order to Show Cause

At Special Term of the
Supreme Court of the State of
New York, County of Orange
on the ___ day of _______, 2005

Present: Hon.
__________________________________________________ __________________

Sam Sloan

Petitioner
INDEX No. 2004-7739
-against-

Beatriz Marinello, Tim Hanke, Stephen Shutt,
Elizabeth Shaughnessy, Randy Bauer, Bill Goichberg,
Kenneth M. Chadwell and United States Chess Federation,

Respondents.
__________________________________________________ ______________________

ORDER TO SHOW CAUSE
__________________________________________________ ______________________

Upon the annexed petition of Sam Sloan duly verified the 27th day of
February 2005 and upon the original petitions and upon all of the
papers and proceedings had herein, it is hereby

ORDERED, that the respondents show cause before this Court at a
Special Term thereof to be held at the County Courthouse in Orange
County at 255 Main Street, Goshen, NY 10924 in Room ____ on the ____
day of March, 2005 at _____ AM of that day or as soon thereafter as
counsel can be heard why an order should not be made and entered
herein:

1. A freeze on all the bank accounts of the USCF at Key Bank in
Newburgh until a hearing can be had.

2. A temporary restraining order and a preliminary and permanent
injunction restraining and enjoining Beatriz Marinello, Tim Hanke,
Steven Shutt and Elizabeth Shaughnessy from taking any actions at all
with respect to the USCF until a hearing can be had. Beatriz Marinello,
Tim Hanke, Steven Shutt and Elizabeth Shaughnessy may not hire
employees, fire employees, buy anything, sell anything, enter into
contracts, write checks or pay or receive money or do anything at all
with respect to the United States Chess Federation.

3. A temporary restraining order and a preliminary and permanent
injunction restraining and enjoining the United States Chess Federation
or its officers or employees from doing anything to effectuate a move
to Crossville, Tennessee or to anywhere else absent the order of this
court.

4. An order enjoining Beatriz Marinello and Tim Hanke from signing any
check or transferring any funds of the United States Chess Federation.

5. An order directing Beatriz Marinello and Elizabeth Shaughnessy to
return to the USCF all expense money they have received from the USCF
except for money for expenses incurred while attending regular
scheduled quarterly meetings of the Executive Board.

6. An order disqualifying Michael J. Matsler or the law firm of Rider,
Weiner & Frankel PC from representing the defendants herein.

7. Such other and further relief as may be deemed just and equitable.


Pending a heariug before this court, it is hereby

ORDERED

1. The USCF accounts at Key Bank in Newburgh are frozen until a hearing
can be had.

2. A temporary restraining order and a preliminary and permanent
injunction is hereby issued restraining and enjoining Beatriz
Marinello, Tim Hanke, Steven Shutt and Elizabeth Shaughnessy from
taking any actions at all with respect to the USCF until a hearing can
be had. Beatriz Marinello, Tim Hanke, Steven Shutt and Elizabeth
Shaughnessy may not hire employees, fire employees, buy anything, sell
anything, enter into contracts, write checks or pay or receive money or
do anything at all with respect to the United States Chess Federation.

3. A temporary restraining order and a preliminary and permanent
injunction is hereby issued restraining and enjoining the United States
Chess Federation or its officers or employees from doing anything to
effectuate a move to Crossville, Tennessee or to anywhere else absent
an order of this court.

4. Beatriz Marinello and Tim Hanke are hereby enjoined from signing any
check or transferring any funds of the United States Chess Federation
in New York State.

5. Beatriz Marinello and Tim Hanke are hereby ordered and directed to
return to Key Bank in New Windsor any funds of the USCF which they may
have transferred out of New York State.

6. All further actions are stayed pending a hearing on this motion.

Sufficient Cause appearing therefore, it is further

ORDERED, that Service of a Copy of this Order to Show Cause, together
with a copy of the papers upon which it is granted on the law firm of
Rider, Weiner & Frankel PC on or before the ____ day of ___________
2005 be deemed good and sufficient service thereof.
________________________________
J. S. C.

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