Penn's complaint: the fine print

Billed as a mega-fight, UFC welterweight champion Georges St. Pierre defeated lightweight titleholder B.J. Penn on Jan. 31, but that was just the beginning of the battle.

Since then, a very public situation has erupted amidst accusations of St. Pierre's camp illegally applying Vaseline or "greasing" their fighter, giving him an unfair advantage and endangering Penn during their bout.

The 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 Phil Nurse. Officials wiped the welterweight champion down with a towel between rounds and monitored the corner closely until the bout's halt.

That has not stemmed the tide of either side. St. Pierre's camp is adamant that there was no intentional infraction, while Penn's camp just as strongly argues that it was a preconceived plan.

Penn and his camp on Monday filed a 20-page formal complaint against St. Pierre and his camp with the Nevada State Athletic Commission. Several of the key points of interest presented in the excerpts from the complaint below.

ALLEGATIONS AS TO GEORGES ST. PIERRE:

It is Penn's understanding and belief that other renowned mixed martial arts fighters have openly complained of and expressed statements consistent with Penn's experience during the Bout against Pierre, that is, that Pierre's body was highly and unnaturally slippery well beyond that contemplated and experienced by veteran mixed martial arts fighters and, based thereon, Penn alleges that the application of Vaseline/petroleum jelly or some substance to Pierre's body by his agents, employees and/or co-conspirators during the Bout was not an innocent and/or inadvertent act or mistake but, in fact, a calculated strategy and an intentional act by Pierre to have a substance applied to his body during the Bout that would result in his body becoming highly and unnaturally slippery.

... Penn alleges that prior to the Bout Pierre ingested a substance that would cause his body to become highly and unnaturally slippery during the Bout and that such an act was not innocent and/or an inadvertent mistake but, in fact, a calculated strategy and an intentional act by Pierre to ingest this substance such that his body would become highly and unnaturally slippery during the Bout.

PRE-BOUT WARNING TO THE COMMISSION ABOUT PIERRE "GREASING":

Prior to the Bout a member(s) of Penn's Team notified and forewarned the Commission and/or its agents, representatives or employees that Pierre may/will engage in conduct unbecoming of the sport of unarmed combat and in violation of the regulations of the NRS and NAC, specifically, that Pierre will apply Vaseline/petroleum jelly or some substance to his body and/or knowingly, willingly and/or intentionally allow the application of a substance to/on his body that will be slippery or cause his body to become highly and unnaturally slippery during the Bout.

The basis of Penn's and Penn's Team's belief are the comments and statements made by other veteran mixed martial arts fighters who have participated in bouts against Pierre as well as other comments made pertaining to Pierre's Team about "greasing" ... Based on the aforementioned information and belief Penn alleges that Pierre is and at all relevant times alleged herein a knowing and willing participant to the unfair, illegal and unsanctioned actions and activities complained of ...

REQUEST TO MONITOR ST. PIERRE:

The member(s) of Penn's Team requested that the Commission and/or its agents, representatives or employees closely monitor and observe Pierre and members of Pierre's Team to determine if they applied any substances (Vaseline/petroleum jelly or such other substances that would cause Pierre's body to be and/or become highly and unnaturally slippery) to/on Pierre's body prior to the Bout and to ensure that no substances (Vaseline/petroleum jelly or such other substances that would cause Pierre's body to be and/or become highly and unnaturally slippery) would be and/or was applied to/on Pierre's body during the Bout by members of Pierre's Team.

ACTUAL "GREASING" DURING THE BOUT BY PIERRE:

Notwithstanding the grave concern of Penn and Penn's Team, as well as the direct and explicit warnings made by Penn's Team to the Commission and/or its agents, representatives and/or employees, Pierre was in fact caught by the Commission for "greasing" during the Bout by the application of a substance to his body that created a highly and unnaturally slippery surface.

In addition to the unfair, illegal and unsanctioned act of "greasing," it was also seen and observed that Pierre received excessive or undue spraying or throwing of water during the period of rest between rounds which is a violation of the rules and regulations of the Commission.

HEALTH AND SAFETY OF PENN:

Penn's Team discussed and warned the Commission and/or its agents, representatives or employees about the aforementioned matters for the following reasons including, but not limited to, ensuring a fair and just Bout, ensuring that the rules and regulations of the NRS and NAC were maintained and to ensure the integrity of the sport, the Commission and the laws of the State of Nevada. Notwithstanding such warnings, and as a direct result of the circumstances complained of herein, Penn did in fact suffer a cranial concussion during the Bout; specifically, by Pierre being "greased up" he (Pierre) was able to easily and readily slip out of Penn's renowned defensive and offensive submission holds and techniques. As such, Penn was unable to fairly and properly defend himself in a manner consistent with that contemplated in unarmed combat because of the highly and unnaturally slippery nature of a "greased up" Pierre.

It is Penn's belief and based thereon he alleges that the unfair, illegal and unsanctioned advantages gained by Pierre "greasing up"... illegally and improperly neutralized and nullified Penn's mixed martial arts fighting skills including, but not limited to, Penn's Brazilian Jiu Jitsu as he was unable to control, hold or submit a "greased up" Pierre who readily "slipped out" of Penn's Brazilian Jiu Jitsu and grappling submission techniques during the Bout.

It is Penn's belief and based thereon he alleges that the aforementioned activities are the equivalent to violating the NRS and NAC rules and regulations relating to the illegal and improper use of banned steroids which is clearly codified in the NRS and NAC.

(The Penn complaint went on to cite several NRS and NAC sections to support its claims and to build a foundation for its request for disciplinary action against St. Pierre and his camp.)

RELIEF SOUGHT AND REQUEST FOR DISCIPLINARY ACTION:

-- That the Commission fine Pierre, individually, as well as Jackson, Nurse (his named cornermen) and (other) licensed (unnamed individuals). (Such a fines could be as much as $250,000 per individual.)

-- The Commission suspend or revoke Pierre's license as well as (those of Pierre's other licensees.)

-- That the Commission... change the result of the Bout to a "no contest."

-- That the Commission find that Pierre (and his other licensees acted) as co-conspirators.

-- That the Commission require Pierre to undergo and submit to a pre-bout supervised and monitored shower and/or hygiene cleansing upon his arrival to all future bouts to ensure that no substances exist on Pierre's body.

-- All other relief that the Commission deems just and proper.

NOTICE OF HEARING AND REQUEST FOR EVIDENCE:

Penn further requests that the Commission schedule the necessary hearings such that (the) Complaint will be addressed in full and the parties be provided with sufficient time to gather and prepare the evidence and to ensure the attendance of witnesses.

Based on the severity of the allegations set forth herein, Penn respectfully requests that the Commission take the appropriate action of temporarily suspending Pierre's license to compete as an unarmed combatant and/or to serve as a second until this matter is fully resolved.

(Editor's Note: While the above wording is taken directly from the complaint filed by Penn and his camp, it is not the full 20-page text that was filed with the Nevada State Athletic Commission, but select points from within the complaint.)