To THE HONORABLE UNITED STATES DISTRICT JUDGE:
SUSAN POLGAR AND THE UNITED STATES OF AMERICA CHESS FEDERATION, INC., BILL GOICHBERG, JIM BERRY, RANDY BAUER, RANDALL HOUGH, BILL HALL, BRIAN MOTTERSHEAD, HAL BOGNER, CONTINENTAL CHESS INCORPORATED; BRIAN LAIFERTY, KARL S. KRONENBERGER; AND KRONENBERGER BURGOYNE, LLP jointly file this Stipulation of Dismissal With Prejudice pursuant to Rule 41(a)(2) ofthe FEDERAL RULES OF CIVIL PROCEDURE, and would respectfully show the Court as follows:

I. PARTIES AND PROCEDURAL BACKGROUND

1. This case consists of two actions which have been consolidated into the above-
numbered case. Cause No. 5:08-CV-0169-C was originally filed in this Court by Susan Polgar against the United States of America Chess Federation, Inc. ("USCF"), and Bill Goichberg, Jim Berry, Randy Bauer, and Randall Hough, all Individually and in their Representative Capacities as Members of the Executive Board of the USCF; Bill Hall, Individually and in his RepresentativeCapacity as Executive Director of the USCF; Brian Mottershead, Hal Bogner, Continental Chess Incorporated; Jerome Hanken, Brian Lafferty, Sam Sloan, Karl S. Kronenberger; and Kronenberger Burgoyne, LLP.

2. Former Cause No. 3 :08-CV-05126-MHP was originally filed in the Northern District
of California by the USCF and Randall Hough against Susan Polgar and an individual named Gregory Alexander. Thereafter, Susan Polgar filed a counterclaim against Randall Hough and third- party claims against Bill Goichberg, Bill Hall, Randy Bauer, Jim Berry, and Karl Kronenberger.

3_ Cause No. 3:08-CV-05125-MHP was transferred from California to this Court, and on January 4, 2010, this Court consolidated said cause with the above-numbered action, Cause No. 5:08-CV-0169-C.

4. On January 13, 2010, this Court severed the claims of the USCF and Randall Hough against Gregory Alexander into Cause No. 5:09-CV-246-C and administratively closed that case.

II. STIPULATION OF DISMISSAL

5. Susan Polgar has agreed to settle and release her claims and causes of action against the USCF, William Goichberg a.k.a. Bill Goichberg, James E. Berry a.k.a. Jim Berry, Randall Bauer a.k.a. Randy Bauer, and Randall Hough (Individually and in their Representative Capacities as Members of the Executive Board of the USCF); William H. Hall a.k.a. Bill Hall (Individually and in his Representative Capacity as Executive Director of the USCF); Brian Mottershead, Harold M. Bogner a.k.a. Hal Bogner, Continental Chess Incorporated, Jerome Hanken, Brian Lafferty, Karl S. Kronenberger, and Kronenberger Burgoyne, LLP. (Jerome Hanken has passed away since the filing of the lawsuit, and Susan Polgar has agreed to release his Estate of any and all claims against Mr. Hanken.)

6. Furthermore, Susan Polgar has agreed to settle and release her counterclaim against Randall Hough and her third-party claims against William. Goichberg a.k.a. Bill Goichberg, William H. Hall a.k.a. Bill Hall, Randall Bauer a.k.a. Randy Bauer, James E. Berry a.k.a. Jim Berry, and Karl Kronenberger. Susan Polgar has executed a Compromise, Settlement and Release of All Claims to this effect.

7. The USCF and Randall Hough have agreed to settle and release their claims against Susan Polgar and have executed a Compromise, Settlement and Release of All Claims to that effect.

8. Further, any claim by or between Paul Truong and any of the parties to this Stipulation have been compromised and settled as well. The parties hereto and Paul Truong have executed a Compromise, Settlement and Release of All Claims to this effect.

9. Accordingly, any and all claims by and between Susan Polgar and Paul Truong, and The United States of America Chess Federation, Inc., Bill Goichberg, Jim Berry, Randy Bauer, Randall Hough, Bill Hall, Brian Mottershead, Hal Bogner, Continental Chess Incorporated, Brian Lafferty, Karl S. Kronenberger, Kronenberger Burgoyne, LLP, Jerome Hanken, and the Estate of Jerome Hanken have been settled and released.

10. After the execution of the Compromise, Settlement and Release of All Claims, the only remaining, pending claims before this Court in Cause No. 5:08-CV-169-C are those claims by and between Susan Polgar and Sam Sloan. Susan Polgar expressly reserves her claims and causes of action against Sloan and does not intend to dismiss said claims by way of this stipulation.

11. Further, by entering into this stipulation of dismissal, the USCF and Randall Hough do not intend to dismiss their claims against Gregory Alexander, which have been severed into Cause No. 5:09-CV-246-C and administratively closed, and expressly reserve said claims and causes of action.

12. For these reasons, Susan Polgar moves this Court to dismiss her claims in Cause No. 5:08-CV-0169-C against the USCF, William Goichberg a.k.a. Bill Goichberg (individually and in his representative capacity as a member of the Executive Board of the USCF), James E. Berry a.k.a. Jim Berry (individually and in his representative capacity as a member of the Executive Board of the USCF), Randall Bauer a.k.a. Randy Bauer (individually and in his representative capacity as a member ofthe Executive Board of the USCF), Randall Hough (individually and in his representative capacity as a member of the Executive Board of the USCF), William H. Hall a.k.a. Bill Hall (individually and in his representative capacity as Executive Director of the USCF), Brian Mottershead, Harold M. Bogner a.k.a. Hal Bogner, Continental Chess Incorporated, Jerome Hanken (and the Estate of Jerome Hanken, Deceased), Brian Lafferty, Karl Kronenberger, and Kronenberger Burgoyne, LLP with prejudice to Susan Polgar.

13. Further, Susan Polgar moves this Court to dismiss her counterclaim against Randall Hough and her third-party claims against William Goichberg a.k.a. Bill Goichberg, William H. Hall a.k.a. Bill Hall, Randall Bauer a.k.a. Randy Bauer, James E. Berry a.k.a. Jim Berry, and Karl Kronenberger with prejudice to Susan Polgar.

14. Further, the USCF and Randall Hough move this Court to dismiss their respective claims against Susan Polgar with prejudice to the USCF and Randall Hough.

15. Any pending claim by or against Paul Truong should be dismissed with prejudice as well.




1The parties filing this Stipulation of Dismissal know of no claim, counterclaim, crossclaim, or third party claim pending, filed by or against Paul Truong, and originating in either cause number 5:08-cv-00169 or 3:08-cv05125-MEIP. To the best of each party's knowledge and that of their counsel, no live claim, counterclaim, crossclaim or third party claim by or against Paul Truong exists at this time. The parties have included any claims relating to Paul Truong in this Stipulation of Dismissal as a result of the Court's reference to potential live claims pending by or against Paul Truong in the Court's Order partially granting Defendant Hal Bogner's Motion to Compel Paul Truong [docket no. 231].