Affidavit of Elizabeth Shaughnessy

SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION - SECOND DEPARTMENT
_______________________________________________X

Sam Sloan,
AFFIDAVIT
Petitioner-Appellant,
Index No. 2004-7739
against-
Appellate Case: 2005-3754

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

Respondents.

________________________________________________X

STATE OF CALIFORNIA )
)SS.:
COUNTY OF ALAMEDA )

Elizabeth Shaughnessy, being duly sworn, deposes and says:

1. I am currently a member of the Executive Hoard of the United States of America Chess Federation ("USCF''). I was certified as an elected member in August 2004.

2. I reside and work in the State of California. I lived and worked in New York State for a few months in 1964. In the summer of 1964, I left New York State and have not lived or worked in New York State since that time.

3. I have not been in New York State since 1964.

4. I was never served by a process server with Mr.. Sloan's order to show come, affidavit and petition from November 2004 that he filed in the lower court.

5. I understand that Mr. Sloan has made allegations as to me in his current court papers. Mr. Sloan states that I am now an employee of USCF in violation of the By-Laws because I am a member of the Executive Board. I am not an employee. I receive no salary, wages or benefits from USCF in my service as a member of the Executive Board. I do, however, receive expense reimbursement for my travel-related USCF business, which required me to submit receipts and proof of these expenses, which are then reviewed by the USCF and paid upon approval. Mr. Sloan also claims that USCF signed a contract to pay the architect $60,000 under my "supervision". While it is true that I am an architect by training, I have volunteered my services to USCF as a liaison/contact for the architect hired by USCF in Crossville, Tennessee. I do not receive any compensation for these services.


_________________________
Elizabeth Shaughnessy

Sworn to before me this
28th day of April, 2005.

__________________
Notary Public
E. WEST
COMM. *1355831
Notary Public -.California
ALAMEDA COUNTY
My Comm. Exp. May 9, 2006


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