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November 3, 2004

Discrimination Complaint Against USADSF, Jordan, Ammons And Scoggins Is Being Filed

From: DeafSportLawsuit - Nov 3, 2004



*Discrimination Complaint Before New York State Human Rights Division

*USADSF's Response and the Pinchas Rebuttal with 17 Evidentiary Exhibits

*USADSF's Covert Support for Jordan and Ammons at Their 2001-2004 Lawsuit Cases in Baltimore

*Dispute Over Selection of USADSF's Representative to New CISS EC

*In What Manner 2007 GOC President and Secretary Were Selected

*A Crony of Ammons is the Newest Salaried CISS Secretary General

*USADSF's Evasiveness to Deal With Pinchas Face-to-Face

*Defamation of Character Appeal and Property Theft Lawsuit vs. Ammons are Still Pending in Richmond, Virginia, and Washington, D.C.

*The "Inexperienced" Scoggins, Jordan and Ammons and Their Instant Elevation to Top Positions in USADSF and CISS

*Jordan as "A Genial Patriarch" and Role Model for Scoggins and Ammons

*USADSF and Scoggins "Spit Out" Russian Valery Rukhledev's July 27, 2004 Friendly Recommendation and Compromising Initiative to USADSF to Produce Joint Proposal by Russia and USA to Nominate Pinchas as an Independent Candidate for Any CISS EC Position Pursuant CISS Constitution Rule Number 15

*Jordan as the Pinchas-Paranoid, so-called CISS "Retiree" and Anarchist is Prime Fundament of All Troubles in Today's Deaf Sports World

*The Scoggins Scandal: Breach of Confidentiality, Betrayal and Hypocrisy by Publicly-Elected USADSF President

*New Discrimination Lawsuit vs. USADSF, 2 Anarchists and Scoggins is Submitted before USA District Court in New York

To:      State of New York

           Executive Department, Division of  Human Rights

From: Mr. Rafael Pinchas,Complaintant

Re:     Discrimination Complaint against USADSF, Jordan, Ammons and Scoggins

           Case Number 101100710

Date:  November 1, 2004


This is to acknowledge the receipt your office mail package dated October 14, 2004, which included the October 11, 2004 United States Deaf Sports Federation's ( herein, "USADSF" ) response and its various attachments ( total 31 pages ).

Below are my rebuttals, which are supported by 17 various Exhibits, arguments, facts and comments.

The Pinchas Rebuttal to USADSF's Various Statements

USADSF's Statement: "This ( USADSF ) office has never received your August 3, 2004 correspondence to the USADSF."

Pinchas' Rebuttal: This statement by USADSF is a questionable one. Assuming that this office mailed the correspondence to USADSF on August 3, 2004 and if USADSF did not receive it in timely manner then this correspondence should have been returned to this office as "a non-deliverable mail" item. This thing, as I understand, did not happen and your office did not receive back the August 3, correspondence it mailed initially and directly to the USADSF Home Office in Sioux Falls, North Dakota, on or about August 3, 2004.

USADSF's Statement: "It is worth noting that the lawsuits against three individuals with the CISS has been recently dismissed by the court."

Pinchas' Rebuttal: This statement is a very clear indication and obvious proof that USADSF has been siding with Jerald Jordan ( "Jordan" ) and Donalda Ammons ( "Ammons" ) and against me in the three different lawsuit cases in Baltimore, MD, which I initiated in 2001 and 2003 against the three deaf sports anarchists. It should be corrected that the International Committee of Sports for the Deaf/Deaflympics ( "CISS" ) as an organization was never named as a lawsuit party as USADSF wrongfully claimed in its response to this office. It should also be noted that the defamation lawsuit matter involving Ammons, Jordan and this complaintant is not over as an appeal before the U.S. Court of Appeals for the Fourth Circuit, in Richmond, VA ( Case Number 04-1993, telephone number 804-916-2700 ), is still pending. In addition, Ammons is still engaged in another lawsuit matter related to her alleged property theft charge before the Court in Washington, D.C ( Felix Shlimovich, plaintiff, vs. Ammons and Slava Klimov,

co-defendants, Civil Action Number 002425-04, District of Columbia Superior Court

Washington, D.C., telephone number 202-879-1492 ).

USADSF's Statements: "The USADSF Board agreed that face-to-face interviews were not feasible due to financial limitations of this organization. This position announcement carefully indicated that videoconferencing interviews might be substituted for person-to-person interviews.This board had no choice but to remove him from the final candidate list to be interviewed."

Pinchas' Rebuttal: If USADSF faced financial difficulties then it would not in the first place initiate its bid for the rights to host a very huge and what would-be costly world-class sporting event such as the 2007 Deaflympic Winter Games before the CISS Congress delegates ( USADSF "won" the bid to host the 2007 Games at the 38th CISS Congress held in Sundsvall, Sweden, on February 28, 2003 ). And if USADSF had "financial limitations" to conduct face-to-face interviews of the candidates, then USADSF would not have in the first place advertised its two-sentence Position Announcement statement in a manner such as,

"Finalists may be invited for an interview with the USADSF Executive Board in Frankfort, KY during the weekend of October 4-5,2003. Expenses will be paid by the USADSF."

Interestingly, in its response pages to this office USADSF cleverly and purposefully chose to conceal this two-sentence Position Announcement statement.

Thus, USADSF did not comply with this Position Announcement statement when this

Complaintant – twice on September 26 and then on October 3, 2003 – asked USADSF in his e-mail messages the similarly-sounding questions such as,

"Is there another alternative to conduct the planned October 4, 2003 interview?" ( see

EXHIBIT 1 ), and

"What is the other alternative?" ( see EXHIBIT 2 ).

USADSF did not respond to these questions at all.

Moreover, if it was necessary, I was even prepared to fly to the site of an interview at my own expense as I have always done by attending the many CISS Congresses and Deaflympic Games held in different and far away countries of the globe at my own personal expense ( both Jordan and Ammons know it very well that since 1977 I have loyally and actively been attending the CISS Congresses and Deaflympic Games held in different countries, your office may also verify this fact by reviewing my resume ).

On the other hand, USADSF handled the interview process of the three finalists – Dwight

Benedict, Geraldine Francini and this complaintant – in a questionable, suspicious, unfair and uneven-handed manner.

Let me describe the three unusual things related to the interview.

On September 24, 2003, USADSF e-mailed to each of these finalists letters advising the day and time each finalist would be scheduled for an interview via the videocam system.

On that day the first person to receive the e-mail letter was Miss Francini at time of 10.47.42 a.m. ( see EXHIBIT 3 ), then it was Mr. Benedict at the time of 10.49.26 a.m. ( see EXHIBIT 4 ), then the last third person to receive the letter was this complaintant at time of 10.54.01 a.m. ( see EXHIBIT 5 ). What was unusual and unequal was that I, the last person to receive the September 24, 2003 e-mail letter, was scheduled the first person to be interviewed on October 4 at 11.00 a.m., while Mr. Benedict was scheduled to be interviewed on that same day at 3.00 p.m. Miss Francini got a preferential treatment when she was set up for an interview a day later, on October 5, at 8 a.m.

The second unusual and troublesome thing was that both Mr. Benedict and Miss Francini, upon my investigation, were personally contacted by USADSF and/or Ammons to apply for the 2007 DeaflympicWinter Games Organizing Committee ( "GOC 2007" ) positions in advance.

Upon information and belief, Ammons is a long time friend of Miss Francini ( she one time ago bore a married surname of Mrs. Alonzo Whitt ). Ammons and Mr. Benedict work at the same place – the closely-knit Gallaudet University campus in Washington, D.C. – for many years.

The third unusual thing, which USADSF chose not to report in its response to this office was that there actually were the two open positions for the GOC 2007 – Chairman and Secretary General – and both positions had at one and same time been filed by Mr. Benedict and Miss Francini, respectively ( see EXHIBIT 6 ).

Therefore, USADSF did not inform me about the second position – Secretary General – in any form, shape and manner beforehand.

My arguments are that had I known that there was an open position for the Secretary General and if I failed with my application for the Chairman position, then I would have also applied for the position of Secretary General as an insurance.

Other major arguments are

1) that USADSF failed to demonstrate to this office the copies of resume of Mr. Benedict and Miss Francini. This way it denied this office the chance to clearly, fairly, rationally and justly examine, compare and judge as to what kind of background each finalist had, etc.

2) that both Mr. Benedict and Miss Francini, unlike this complaintant, are gainfully employed; USADSF still decided to chose "busy persons" ( i.e., Mr. Benedict and Miss Francini ) for these two "physically and mentally stressful" positions over

"a non-busy and unemployed" person ( i.e., this complaintant );

3) USADSF's e-mail letter dated October 3, 2003, among the other things, stated that "we ( USADSF ) will submit your name to the GOC 2007 Chair in consideration of using your resources towards one of the committees." ( see EXHIBIT 7 ). As time goes on, this statement by USADSF has been an empty talk gesture because to this day I have not been offered any position in the GOC 2007 structure.

What is more, in spite of the above arguments and reasons, USADSF had not, instead given me any opportunity to be interviewed in-person as the Position Announcement clearly stated.

Thus, it is my position that in order to desperately find a way to disqualify me USADSF had an advance information from my lawsuit adversaries ( Ammons and Jordan ) that I had no videosystem equipment in my own possession, therefore, USADSF found an excuse – a very poor one – that since I failed to locate such an equipment, I must be disqualified as a finalist.

In the sum, USADSF's response statement such as,

"this board had NO CHOICE but to remove him from the final candidate list to be interviewed,"

was a totally unjustified and wholly unsubstantiated one.

Finally, USADSF could not justify its October 11, 2004 cover letter statement sent to this office when it wrote to say that "In fact, EVERY EFFORT was made for him ( Pinchas ) to participate in the interview process for the position of the Chair of the 2007 Winter Deaflympic Games Organizing Committee."

The fact was that USADSF did not make EVERY EFFORT because USADSF did not want to meet me in-person in order to conduct the face-to-face interview.

USADSF's Statement: "it was our position and will be that the next nominee will be picked from the current USADSF board if the current incumbent chooses not to run again."

Pinchas' Rebuttal: USADSF never advised me to say that 'the next nominee will be picked from the current USADSF board." Instead, it used the term such as, "USADSF family." In my July 4, 2004 two-page e-mail communication to Scoggins ( see

EXHIBIT 8 ), I posed many different questions to her and USADSF. However, to date, I have not received any response to these questions.

Specifically, on that e-mail communication, I presented a question such as,

"What is your definition of USADSF family?"

Such a specific question has also gone unanswered by either USADSF or Scoggins.

In addition, USADSF has its own Rules and Regulations, in which there is not a single word mentioned as to the procedure and criteria of selecting of an USADSF Representative to the CISS Executive Committee quadrennially.

USADSF's Statements: "It is the position of the USADSF Board that he has not been discriminated against because; 1) Mr. Pinchas has not been involved in the USA Deaf Sports Federation activities in recent years; 2) He is not currently active with any of our National Sports Federations and 3) lack of his participation in the annual House of Delegates meetings, representing various organizations, for more than ten years. In other words, he has not been involved enough to represent the USA Deaf Sports Federation effectively in order to be nominated as the USADSF representative to the CISS Executive Committee."

Pinchas' Rebuttal: These above statements are shocking, belittling and insulting ones. These statements by USADSF also paint me as "an effectively inexperienced and unqualified" individual.

Obviously, USADSF and Scoggins have failed to appreciate, recognize and acknowledge my versatile, voluntary and long time involvement with the deaf sports, locally, nationally and internationally.

A careful review of my resume should educate any person, including your office staff, as to what kind of work and contribution I have done in the area of the deaf sports during my life in five different countries: the Soviet Union, Israel, Russia, Uzbekistan and USA.

Although I have not held any official position in the USADSF and its affiliated organizations recently, I had been involved with the USADSF and its people in different ways.

For example, between 1995 and 2004 I have written up many stories in different publications extolling the deaf USA persons' - athletes and representatives - performances in different international sporting events; in December, 1998 in Washington, D.C., I took an active part in the tripartite USADSF-USA Deaf Basketball-American Basketball Association of the Deaf reconciliation meetings; in 1999 I applied for the position of the 2001 USA Deaflympic Games Committee Team Director ( I was

unsuccessful with this application primarily due to clandestine meddling by Jordan among the selections panel ); in 2001 I assisted the then USADSF Vice President Sam Sonnenstrahl with the valuable information presentation related to the CISS/Deaflympic Games history quiz. These various and voluntary projects took much of my own time, energy and money. These facts, however, are unreported in my long and eventful resume.

Thus, it would be offensive and unjustified for anyone to say that "I have not been involved in USADSF activities in recent years" directly or indirectly.

Moreover, in spite of my varied skills in the area of sports, USADSF in recent years had made no effort to invite me or inform me to attend an USADSF House of Delegates meeting primarily because USADSF was ( and is still ) influenced by Jordan, its organization's doyen and my nemesis in the still ongoing lawsuit matter. In addition, USADSF had not prominently and openly advertised the date of this year's House of Delegates meeting via the mail or mass media or its website ( i.e., many deaf sports lovers and supporters in this country, for example, have no idea of the next date and location of the 2004 USADSF House of Delegates meeting in advance ).

On the other hand, it will be historically and factually relevant to note in what kind of manners Scoggins, Jordan and Ammons themselves, in spite of their "inexperience in the area of sports," were ascended to the top-level positions in both USADSF and CISS before.

In 1995 Scoggins herself was instantly elevated to the top position of USADSF Vice President in spite of the facts that she had prior limited "sports experience" ( see EXHIBIT 9 ). By analyzing the material from the now-defunct USADSF's DEAF SPORTS REVIEW magazine, you may note that the only major sports experience Scoggins had was that she was a member-athlete of the USA swimming and volleyball teams at the 1973 and 1977 Deaflympic Games, respectively. Her experience in the area of sports administration, according to that magazine's story, was nil. Furthermore, before her rapid moving up to the key position in USADSF, upon information and belief, she by then "was not active with any of USADSF' ( then known as the AAAD ) National Sports Federations and that she lacked in her participation in the annual House of Delegates ( then known as the AAAD Board of Directors ) meetings, representing various organizations, for more than 10 years." In spite of all this, Scoggins still somehow got appointed or elected to the vice-presidential position in USADSF in 1995.

As for Jordan, before he was nominated for the CISS Executive Committee position of President in 1971, he was regarded as an internationally inexperienced sports functionary.

To corroborate this fact, please note the frank statement Jordan himself wrote in the well-respected CISS Bulletin magazine ( JJ's Jottings, the CISS Bulletin, Number 178, February, 1995, page 4 ):

"He ( Mr. Sondergaard ) then nominated me ( i.e., Mr. Jordan for the CISS President

position ) and to my even greater surprise, I was elected. In many ways, it was a big challenge since I was completely lacking in international experience except for my four years on the CISS Executive Committee" ( see EXHIBIT 10 ).

Regarding Ammons, in 1997, in spite of her inexperience in international sports, USADSF still one-sidedly chose to nominate Ammons for a CISS Executive Committee position of Secretary General.

To support this fact, please note that Ammons herself candidly acknowledged this in her recent, October 8, 2004 statement published in the ( see EXHIBIT 11 ).

"I was thrust into the ( CISS) Secretary General position ( in 1997 ) with very limited preparation and experience."

In spite of this statement and Ammons' current status as an anarchist, lawsuit litigant and fundamentally incompetent international sports administrator/leader, USADSF still decided to unanimously and uncontestedly re-submit her name for the position of the CISS Executive Committee President-candidate for the 2005-2009 year term.

USADSF's Statement: "( on February 22, 2004 ) The USADSF president responded to Mr. Pinchas that the USA Deaf Sports Federation has no jurisdiction over the job position of CISS Secretary General and referred his request to the CISS Search Committee. The USADSF had, and has no involvement in the CISS operations or the naming of the eventual candidate for the position of CISS Secretary General."

Pinchas' Rebuttal: There is no such a thing like the CISS Search Committee. Although USADSF refused to assist me, its member in good standing, for the job position application in any manner, USADSF was covertly engaged in encouraging another USADSF member, Tiffany Granfors, to be selected for this position. This was done in spite of the solid fact that Miss Granfors has little or limited experience in the international affairs ( again, USADSF did not bother to produce to this office a copy of Miss Granfors' resume in order to enable this office to appropriately evaluate and independently judge as to what kind of a candidate Miss Granfors is, compared to this complaintant ). Additionally, the major reason of hiring of Miss Granfors for the position was that she, like Miss Francini, is a crony of Ammons as well as a close friend of Scoggins.


Jordan, now aged 77, is the core and crux of all the above-described problems and troubles faced by me in the upper echelons of both USADSF and CISS. Jordan has since

1979 been suffering with the so-called "Pinchas phobia and personal loathing of Pinchas".

Scoggins, 47, and Ammons, 51, are worshipping and looking up at Jordan as "their genial patriarch" and role model, i.e., Scoggins, Ammons, USADSF and CISS are very dependent on Jordan for his advise and guidance on any major and delicate policy matter, including in the matter of Pinchas. Jordan is still USADSF Chairman of Governance Committee, he is also the most influential and senior advisor for both USADSF and CISS. A typically sly, cold-faced and constantly-unsmiling Jordan is also known for his lifelong anti-Soviet ( and anti-Uzbekistani ) views.

If there was no Jordan inside the organizations of both USADSF and CISS, then my status and position application/s in both organizations would be very different ones.

USADSF was also engaged in the act of retaliation against me because of my continued lawsuit matter against its "beloved" members Jordan and Ammons and because at times I have written up truthful, accurate and factual stories – but unfavorable ones to USADSF's view - about USADSF and its members, especially about Jordan and Ammons, in my website which innately infuriated USADSF.

Therefore, for self-interest of Jordan, Ammons and Scoggins, and to the detriment of the deaf sports movement in the USA and world, USADSF not only retaliated me, but it also discriminated against me for the following solid motives:

a) USADSF handled the GOC 2007 selection process for the two positions – Chairman and Secretary General – in an unprofessional, secretive and biased manner;

b) USADSF intentionally chose the "do-nothing attitude" with my application for the job position of the CISS Secretary General;

c) USADSF did not handle the matter of USADSF Representative to the CISS Executive Committee for the new 2005-2009 year term in a free, democratic and contested manner;

d) USADSF was unreceptive to the February 13, 2004 "friendly-letter of recommendation" by the Russians ( I was their member before) to seriously consider my name as an USADSF Representative to the CISS Executive Committee for the 2005-2009 year term ( see EXHIBIT 12 ). ( Note: USADSF never delivered its letter-reply directly to Mr. Valery Rukhledev, the February 13, 2004 letter signatory; Mr. Rukhledev as the Father of the Deaf Sports in Russia is also the real power man in the Russian deaf sports circles while Mr. Nikolay Klimov is formally a titular head of the organization; Mr. Rukhledev has just informed me that he never saw the February 25, 2004, March 3 and 11, 2004 letters exchanged between Scoggins and Mr. Klimov; Mr. Klimov is the father of Slava Klimov, who along with his accomplice Ammons is a co-defendant in the above-described lawsuit case in Washington, D.C.; Mr. Rukhledev is having an uneasy relationship with Mr. Nikolay Klimov because of his son Slava's meddling in the international deaf sports politics ).

e) USADSF again ignored Mr. Valery Rukhledev's July 27, 2004 "friendly recommendation" letter to work out and produce a joint proposal by both – Russia and USA – "to nominate my name as an independent candidate for any position in the CISS Executive Committee for the 2005-2009 year term, pursuant to the CISS Constitution Rule Number 15" ( see EXHIBIT 13 ). ( Note: Mr. Rukhledev is currently challenging Ammons for the position of the CISS President at the coming January 4, 2005 39th CISS Congress election contest session to be held in Melbourne, Australia ).

f) USADSF, in the interests of ethnic, geographical diversification and equal employment opportunity, was insensitive and inconsiderate by denying me, a profoundly deaf foreign-born, New York state resident and naturalized citizen of USA, the opportunity to be involved in any suitable leadership/administration position in its own USADSF structure, including in the positions eloquently described above. As a result, USADSF is probably the only national deaf organization in this prosperous and abundant land of immigrants that does not have a deaf foreign-born and/or New York state resident as an appointee or electee in the executive position of USADSF as of today.

Overall, because of my national origin and long-standing personal animosity with the anti-Soviet ( and anti- Uzbekistani )-oriented Jordan, I have been denied the opportunity to fairly, appropriately and equally participate or be interviewed for each of the following positions of 1) GOC 2007 Chair, 2) GOC 2007 General Secretary, 3) CISS Secretary General, 4) U.S. Representative to the CISS Executive Comittee and 5) Independent Candidate for the CISS Executive Committee by USADSF, Jordan, Ammons and Scoggins.

Discrimination is widely defined as treating one person unfairly over another according to factors unrelated to their ability or potential, such as age, disability, sex or national origin

Thus, USADSF, Jordan, Ammons and Scoggins not only violated Title VII of the Civil Rights Act of 1964, as codified, 42 U.S.C. $$ 2000e to 2000e-17 ( amended in 1972, 1978 and by the Civil Rights Act of 1991, Public Law No. 102-166 ) but they also violated the CISS Constitution Rule Number 3.1.11 ( USADSF, for instance, is an affiliate member of CISS ), which states the following

"to promote Deaf Sports without discrimination on the ground of religion, politics, economics, sex or race."

Lastly, one significant and scandalous affair should not be condoned by this office.

This affair is related to a very unpleasant and outrageous incident, which questions and demonstrates the issues of credibility, neutrality and trust of Scoggins as a publicly-elected President of USADSF.

Not only Scoggins has been covertly rooting for Jordan and Ammons in my three different, costly and nerve-wracking lawsuit cases in Baltimore, MD, but she also did something improper, unethical and unprofessional.

And instead of being a strictly and responsibly neutral, impartial and confidential USADSF President in office, let me emphasize, Scoggins did the opposite.

On March 16, 2004, I sent to Scoggins my e-mail letter by expressing my trepidation and concern to her over whether Scoggins and USADSF Board "leaked any information related to me to the outsiders".

On that same day, later on, Scoggins immediately replied by saying that "my board and I forwarded no emails nor communications on you. If it was forwarded, it was not intentional on anyone's part ( the USADSf Board ) because any issues related to you are confidential in nature" ( see EXHIBIT 14 ).

Now, please review the different letters ( these documents were obtained and seen by me for the first time just recently when your office sent to me the copies of the October 11, 2004 USADSF response package ) ( see EXHIBITS 15 and 16 ). These now-revealed documents are vividly demonstrating the facts that Scoggins and/or USADSF lied to me by breaking up the confidentiality rule.


1) USADSF and/or Scoggins made a secret fax dispatch to Ammons regarding a copy of the February 13, 2004 letter by Mr. Rukhledev to USADSF and Scoggins ( this letter copy Ammons also relayed to the hands of Lennart Edwall, the recently-ousted President of the European Deaf Sports Organization from Sweden ), and

2) there was a clandestine exchange of February 25, 2004 and March 3, 2004 letters by Scoggins and Mr. Klimov, in which my name was prominently showcased.

How untruthful, untrustworthy, treacherous and hypocritical Scoggins was towards me!

P.S. A separate discrimination lawsuit naming USADSF, 2 anarchists and Scoggins as defendants has recently been filed by Pinchas before the USA District Court in New York ( the contents of this lawsuit papers will be provided to you upon request only ).