Complaint Form

Charities Bureau

New York State Office of the Attorney General

120 Broadway, 3rd Floor

New York, New York 10271



1 Name and Address of Complainant:

James Ziobro

4 Brook Valley Drive

Rochester, NY 14624

Home/Cell: 585-889-5316



Complaint Against:


3 Park Avenue, 17th Floor

New York, NY 10016-5997 USA

Dr. Staeker / 2013 President

Vince Socci / Region 1 Director

Introduction to Allegations:

In a volunteer organization like the IEEE the only financial controls the members have is through the election of the organization's leaders.  Intentional failures to follow rules in elections are thus equivalent to financial impropriety.

Some positions in the IEEE come with significant financial control.  As an example when I held the Office of Rochester Section Chair I could both allocate and disburse $300K.  That is without any other approval or even a second signature.  There is no regular accounting of expenditures given to the members so abuse could go one forever.  Obviously fraud is even easier when officers cooperate.

One of the repeated themes I heard to justify rule violations is that the violations are commonplace across the IEEE.  I cannot speak for that.  However, it would imply fraud on a massive scale.

In 2013 I tried hard to get the IEEE Organization to follow its rules as dictated by its written rules tracing back to its NY Certificate of Incorporation.  Eventually the last recourse was a complaint to the NY Attorney General.  Following my 2013 Complaint the IEEE Leadership violated the organization's rule in order to exact revenge on those filed the Complaint.  This Complaint documents that abuse.

My 2013 Complaint to the Attorney General assumed the fraud was engineered solely by relatively low level IEEE officers and the IEEE upper management was merely incompetent in allowing it to occur.  What became apparent later is that the President and top officers took an active role in acts of malevolent negligence and deception.


Subsequent to IEEE President Staeker receiving a copy of the 2013 Complaint:

Despite legal elections being over 6 months behind schedule the IEEE made no effort to hold legal elections.  Instead the IEEE went on to award Jean Kendrick the office she was promised for her part in the 2012 fraud.  This was done as an election with a single candidate.  IEEE rules require at least two candidates per position.

Cecilia Jankowski, IEEE MGA Managing Director found that the 2012 Rochester Section Nominations Committee violated multiple IEEE rules.  That committee included Dr. Loui and Dr. Lee.  The IEEE President was aware of the violations.  As I mentioned he received a copy of my complaint.  Ms. Jankowski would be the IEEE employee for him to go to if there was any questions.  Despite his knowledge of Loui's and Lee's  past frauds, they are assigned to the 2013 Rochester Section Nominations Committee.  In the context of Section 717 NY NPC Law, Dr Staeker was not acting in good faith.

Dr. Staeker assigned Vince Socci to act on his behalf.  In an October 2013 telephone conversation with me Vince Socci outlined his actions.  According to my notes he advised that same 2013 Nominations Committee to violate IEEE rules in order to keep me off the ballot.  It just happened to be the same person who signed the 2013 Complaint against the IEEE.

Vince Socci also authorized other actions specifically prohibited directly by the IEEE Constitution or other documents referenced in the IEEE Constitution.  For example he authorized the September 2013 Rochester Section Executive Committee (business) Meeting to be conducted without using Robert's Rules of Order.  This is specifically prohibited in the IEEE Constitution.  He also refused to allow the IEEE to follow the rules specified in the IEEE MGA Operations Manual.  In this case he refused to allow the Rochester Section EXCOM a vote on the composition of 2013 Nominations Committee.

Vince Socci would later submit false reports about his actions.  After questions were raised he issued an acknowledgement and attempted to deflect the blame.

Document in my Possession:

All my records are electronic.  I have e-mail exchanges which relate to the allegations as well as pointer to public records.  I will publish them electronically at:

This Complaint has not been submitted to any other agency

There is no court action pending.

There are no objection to sharing this Complaint as the Attorney General see fit.





James M. Ziobro