After a month of telegraphing their intentions,
The 20-page document, filed on Monday with the Nevada State Athletic Commission, requests sanctions against St. Pierre, his cornermen, and other unknown licensees of the commission, and requests a formal hearing into the matter.
The complaint, drafted by Penn legal representative
Penn succumbed to St. Pierre's furious ground-and-pound attack 20 minutes after their encounter began, with Penn's cornermen throwing in the towel between the fourth and fifth rounds.
Controversy erupted inside the cage between the first and second rounds when the NSAC was alerted to the inappropriate use of Vaseline by St. Pierre cornerman
The document cites unnamed mixed martial arts fighters who complained about St. Pierre's use of greasing agents as evidence of his culpability.
"It is Penn's belief ... that the aforementioned strategies were intentional and were orchestrated by Pierre as a means to unfairly and illegally defeat Penn in a regulated and sanctioned championship bout that prohibits the aforementioned conduct and that such calculated actions by Pierre were implemented as a means to prevent Penn from defending himself in a manner consistent with that contemplated in unarmed combat due to the highly and unnaturally slippery nature of Pierre during the bout," the document states.
Penn and his representative also allege that St. Pierre "ingested a substance that would cause his body to become highly and unnaturally slippery during the bout."
Nurse, Jackson trainer
The complaint requests numerous punishments for St. Pierre's camp. It asks the commission to fine St. Pierre, Jackson, Nurse, and the unnamed parties up to $250,000; suspend St. Pierre's license as well as the licenses of Jackson, Nurse, and the unnamed parties; change the result of the bout to a "no contest;" and require Pierre undergo a pre-bout shower to make sure no substances exist on his body.
St. Pierre's manager,