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Muradian Moves to Quash USCF Subpoena

On Wed, 01 Jul 2009 11:42:39 -0400, MrVidmar <...@nowhere.com
MOTION TO QUASH FOR NON-PARTY INDIVIDUAL
TO THE HONORABLE MARILYN H. PATEL:
COMES NOW, Sevan A. Muradian, a non-party to the above mentioned legal
proceedings, files this Motion to Quash, and moves the Court as follows:
Motion to Quash for non-party individual.
Case No. 3:08-cv-05126-MHP

FACTUAL BACKGROUND
1. My name is Sevan A. Muradian (MURADIAN) and I reside at 5119 North
Kenneth Avenue Chicago, IL 60630.
2. I am a member of the United States Chess Federation (USCF).
3. I am a duly elected member of the Board of Delegates representing the
interests of chess players in the State of Illinois.
4. I am an organizer of chess events in the Chicago, IL area.
5. I am a non-party in the above mentioned case.
6. Mr. Karl Kronenberger (KRONENBERGER) issued a subpoena (EXHIBIT A) on
04/23/2009 which was served on 04/30/2009 to MURADIAN.
7. KRONENBERGER and MURADIAN discussed various aspects of the subpoena
in which KRONENBERGER extended the response date until 06/30/2009
(EXHIBIT B)
8. Via email, MURADIAN raised the concern to KRONENBERGER that the scope
of the subpoena was too broad and KRONENBERGER refused to narrow the
scope of the subpoena (EXHIBIT C) to address only areas pertaining to
pending litigation.
ARGUMENT
KRONENBERGER seeks to have MURADIAN divulge any and all communications
between Susan Polgar (POLGAR) and Paul Truong (TRUONG) that relates to
any of the following: the USCF, the Executive Director (ED), the
Executive Board (EB), and the Board of Delegates (BOD).
Any discussions of chess events, local / national / international, would
be inclusive to the USCF as they are the governing body of chess in the
United States. These discussions would include information on bids being
made or events being planned for the future which would then be made
available to other parties, who have no need to know, due to standard
legal proceedings and due to KRONENBERGER also being a defendant in the
State of Texas for litigation with POLGAR. Many parties that
KRONENBERGER is co-defendants with have no need to know of current or
future events being planned by MURADIAN that have been discussed with
POLGAR and/or TRUONG.
Additionally stating 'any communications' in reference to the ED, the
EB, and the BOD infers that any discussions pertaining to any matters,
related to litigation or not, which may or may not express personal
opinions and other personal matters, would be made available to parties
with no need to know, and potentially made public.
Motion to Quash for non-party individual.
Case No. 3:08-cv-05126-MHP

PRAYER

Non-party individual MURADIAN, requests the subpoena issued by
KRONENBERGER (EXHIBIT A) in this case, be quashed.
Respectively submitted,
Sevan A. Muradian
5119 North Kenneth Avenue Chicago, IL 60630
847.274.1352 (mobile) 847.919.0450 (fax)



On Wed, 01 Jul 2009 12:06:37 -0400, MrVidmar <...@nowhere.com
The court docket notes that this motion for non-party was filed with the
court by Polgar's attorneys, Gonzalez and Leigh.

On Wed, 1 Jul 2009 09:31:43 -0700 (PDT), Rob <...@gmail.com
On Jul 1, 11:06 am, MrVidmar <...@nowhere.com
Is this the same guy with the North American Chess Federation? What is
the relationship of that organization to the USCF?

On Wed, 01 Jul 2009 12:41:06 -0400, MrVidmar <...@nowhere.com
Yes. It's not in my interest to answer your question. The facts will
all come out in due course in the appropriate venue.

On Wed, 01 Jul 2009 20:32:57 -0400, MrVidmar <...@nowhere.com
I would think that Mr. Muradian, who is a USCF board member/delegate,
would be bending over backwards to provide USCF counsel with all
possibly relevant information, particularly after he asked for and was
given a significant extension of time to respond to the USCF's subpoena.
Helping the USCF to his utmost is, after all, his fiduciary duty. One
hopes he is not resisting turning over relevant information in his
possession needed for the USCF to prosecute his acquaintances, Ms.
Polgar and Mr. Truong.

This is the second USCF delegate who has resisted helping USCF counsel
when asked to provide possibly relevant material in their possession.
The other delegate is Ms. Alarie who was not sent a subpoena as I
prevailed on USCF counsel to first request materials by letter rather
than subpoena. I suppose no good deed goes unpunished.

On Thu, 2 Jul 2009 01:02:09 -0700 (PDT), samsloan <...@gmail.com
Here is the allegation in the complaint in Polgar vs. USCF that
pertains to Sevan Muradian. Sevan Muradian is the "one tournament
organizer" referred to in the complaint. In view of the fact that he
has been brought into the case by Susan Polgar, I cannot imagine any
possible grounds he might have to quash the subpoena. If he does not
like being subpoenaed, he should complain to Susan Polgar:

27. For example, one tournament organizer recently made an excellent
bid to the USCF to host various national championships in Chicago. One
of Goichberg’s most profitable chess tournaments also takes place in
Chicago at a similar time. The motion to award a multiple year bid to
the Chicago organizer would have passed 3 (Yes) - 2 (No) -1
(Abstention) if Goichberg had recused himself from voting due to his
conflict of interest with Continental Chess. Goichberg refused to
recuse himself, and his Board majority refused to ask him (Goichberg)
to recuse himself, and the motion was at a 3-3 deadlock when the Board
voted. The USCF sees annual cash inflows in the range of $3.2 million
through the dues of its 80,000 members, grants, gifts, advertisements,
bequests, sponsorships, et cetera. At one time, the USCF annual
revenues exceeded $6 million. For the last thirty years, Goichberg,
through his constant presence on the USCF Executive Board, has managed
to unlawfully cause many thousands of dollars to be unfairly directed
to his pocket, his political allies, and the coffers of Continental
Chess.

Discussion Title: Muradian Moves to Quash USCF Subpoena
Title Keywords: Muradian  Moves  Quash  USCF  Subpoena 


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