FILED 09 DEC 2015 10:17 am Civil Administta?on E. MASCUILLI Exhibit L. State University Vs 13110319500128 Case Control. No.: 151 11035 Confidential John Doe 102 THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY, ASSOCIATION INSURANCE COMPANY, PLAINTIFF CIVIL ACTION VS. NO. 004126 THE STATE JANUARY TERM, 2012 UNIVERSITY and JOHN DOE A, DEFENDANTS I I A 2014 Friday, November 21, Oral Deposition of JOHN DOE 102 held 1221 East College Avenue, 16801, at Hilton Garden Inn, State College, Penneylvania, commencing at 11:53 on the above date, before Kelly M. Johnston, Court Reporter and Notary Public in the Commonwealth of GOLKOW TECHNOLOGIES, INC. 877.370.3377 ph/917.591.5672 fax deps@golkow.com Golkow Technologies, Inc. 03195 Con?nlbh1215111035 03195 Confidential John Doe 102 1 And so was someone you 2 trusted? 3 A Oh, yeahthe Penn State students 5 that was on duty at night? 6 A I u? I can't say a hundred percent; I 7 believe she may have been taking some kind of 8 courses or something with childhood 9 development. 10 Eventually, I know she in the middle of 11 all this, she was interviewing for some post or 12 something in that she eventually went out 13 there for that I heard later. 14 Now, I'm assuming the sexual abuse 15 incident occurred at night? 16 A. Oh, yeah. 17 Okay. So did you come back are we 18 talking, like, middle of the night that you come 19 back? 20 A I would imagine I was back by 10:30 at the 21 latest. 22 Okay. You come back into the Nittany 23 House at 10:30, the sexual abuse incident had 24 occurred. Did you go directly to . and tell Golkow Technologies, Inc. Connolbki:15111035 Confidential John Doe 102 Golkow Technologies, her? A No, no, she wouldn't have been there that late. Okay, that's what I was trying to A Yeah. So would it be the next day? A Yeah, it was the next morning. And do you remember what she told you? A I believe she prepared me to get in trouble For sneaking out? A Exactly. She was I believe it was something along the lines of no matter what comes of this, you should say something, but you should be prepared to faCe consequences for how you got out -- Right. A not, you Now, did you relay to the incident that occurred? A. Probably not in as much detail as written there. What do you remember telling her? A I was a 16?year-old boy, so I would say I 95 percent trusted and five percent had a crush on ann '11 .LIJ. Inc. Pag l03195 John Doe 102 Confidential 1 her, so I probably ?s I can't remember a hundred 2 percent, but I would imagine I didn't go into full 3 detail as it is here. 4 Did you let her know there had been 5 inappropriate sexual contact 6 A Yes. 7 with Mr. Sandusky? 8 A Yeah. 9 What did she tell you to do, other than be 10 prepared for possible getting in trouble for having 11 snuck out? Did she tell you you need to speak to 12 somebody? 13 A She recommended that I talk to the 14 assistant, before going to the director, 15 because the director may be focused on the fact that 16 we were sneaking out and flip out on us. 17 Okay. Did you, in fact, go speak to 1d 19 A I tried to, but they like, the office 20 was so small that she, as soon as I told her I 21 needed to talk to her, she called him in on the 22 meeting, so he was there regardless. A 23 Okay- And the "he" being Mr. Gordon? 24 A Yes. mini ?ame??hd8l?03195 Golhon Technologies, Inc. I ge 3 dolkow Technologies, Inc. 24' Confidential a John Doe 102 And this is the next day, also, same day? A This was yeah, we would have got up, so it probably would have been somewhere 8:00, 9 o'clock. In the morning? A Yeah, very early. So you're in Mr. Gordon's office with and you communicate the fact that there had been an inappropriate Sexual abuse incident that occurred? A Yes . Do you remember again, did you stay away from details, or did you at least make sure they knew that something inappropriate had occurred? A I can't you know, again, this is 27, whatever years of hindsight, I can?t one hundred percent remember, but I do remember I was, you know, probably tiptoeing around the sneaking out part more But I I and trying to cover my own behind there. can't remember, I don't know a hundred percent, I can't answer that. Well, did you at least communicate to them that something inappropriate had occurred between and definitely involving the A Oh, yeah, pr 96: Control 151 '1 3 3 03195 11035 Confidential John Doe 102 1 parties involved here, definitely. 2 Okay. And you then at least you or 3 she says, 's report says that ?they tried 4 to poke holes in my story?. Do you remember 5 anything specifically about that? 6 A I always got the impression that the 7 director of the Nittany House, Cliff, I always 8 thought he didn't like me, but I would later come to 9 realize I don?t think he liked anybody there or his 10 job, and I think that that guy would have poked 11 holes in anybody?s story to cover his own ass. 12 But, yes, I definitely, from almost the 13 second sentence, was just more relentless 14 questioning than this, you know, and it was all over 15 the map, you 16 Did they try to question whether or not, 17 in fact, Mr. Sandusky had sexually abused you in 18 some fashion? 19 A. I don't remember any direct questions that 20 he was trying to prove my story or not prove my 21 story. I remember it more as two almost separated 22 in the fact that, A, you admitted to sneaking out, 23 and I had to implicate a couple other people in the 24 house, and that, B, where was I gonna go with this? Fn. Golkow Technologies, Inc. 3195 Confidential John Doe 102 1 You know, was it something I was just gonna tell him 2 or was I gonna call my mom, anybody at and pass 3 the information on. 4 And what did you say to that issue? 5 A I Well, he didn't put it to me like that; he 6 didn't say, look, this is what I want you to do with 7 it. That's just where it was going was at some 8 point, it got to the point of, well, you're lying, 9 you know, this we never definitely didn't get 10 into details that were here, you know, about that, 11 but it was I would say, yeah, they were 12 definitely poking holes in my story. 13 Did you tell him what you wanted to do 14 with your reporting of this inappropriate sexual 15 conduct? 16 A No, no, because at that time, as a 1? 16?year?old, I assumed they would handle it. 18 Now, again, I'm only going by what it 19 says, it says, and as you had feared, "the director 20 yelled at me". 2l A Yeah, the guy went nuts. 22 What was he yelling at you about? 23 A Well, pretty much everything. I mean, I 24 don't ever remember having a conversation with the I (?nun Th. 1?11i - . . I 3 Golkow Technologies, Inc. kiwc?g??s 195 Control No.: 1511 1035 Confidential John Doe 102 1 guy that he didn't yell, for one. But it was just 2 yelling about, you know, everything is this and you 3 guys are F'n it up, you know, every time I turn 4 around, you know, I got something to deal with, all 5 the, you know, the same thing anybody might say in 6 their job. 7 But it it kind of escalated slowly. So 8 at the first, I guess I was being yelled at for, 9 like I said, breaking the rules and then presenting 10 this story to him, and then I got the impression he 11 thought I was lying to him and just wasting his 12 time; and then at some point, they stopped 13 questioning me and talked amongst themselves. 14 And "themselves" being and Cliff 15 Gordon? 16 A Yeah. 17 And did they then send you back to your 18 roomhad like a dining area, 20 I don't know if I'd call it a dining room, but there 21 was a big dining room table, and I was sitting out 22 there; they gave me a chair and made me turn around 23 and face the wall, seemingly as far away from that 24 office as I could be while they talked. Case ID: 1311 Golkow Technologies, Inc. Page 36 COHUOINOJISI 3195 Confidential John Doe 102 1 Okay. So you weren't privy 2 A No. 3 you couldn't hear what they were saying? 4 A No. 5 Okay. It then says, several hours later, 6 you saw Sandusky and Jim Tarman leaving the house by 7 the front door. 8 A Yes. I didn?t see them come in. 9 Okay. Who is Jim Tarman, do you know? 10 A Now, that, also, I never mentioned that 11 dude by name. The only thing I remember, 'cause as 12 they left the only thing I remember about that was told his last name you're 14 gonna apologize to this guy and this guy; and he had 15 a blue polo shirt on that had the little script 16 embroidery of Penn State, and I believe it had an 17 embroidered little football. 18 Okay. So how do you know that was 19 Mr. Tarman? 20 A I at the time, I didn't. It was said 21 to me you're gonna apologize to Coach and you?re 22 gonna apologize to Mr. and I'm just phonetically 23 remembering the name n? Harman, something like that. 24 And so I would if I had to I wouldn't testify Golkow Technologies, Inc. 3195 Confidential John Doe 102 1 under oath it was Jim Tarman. 2 But you remember someone phonetically 3 saying to you that 4 A Yes, you will w~ you will write a letter 5 of apology to Coach and this man, and it was 6 Mr. Harman, Carman, something along those lines. 7 Now, do you have any idea how 8 Mr., assuming it was Mr. Tarman or Harman, and 9 Mr. Sandusky came to the Nittany House? 10 A No. 11 Do you know if Mr. Gordon called them? 12 A I can't say for sure.- 13 Okay. 14 A. I would I mean, no, I can't say for 15 sure. 16 Okay. It says: (Reading.) Mr. Gordon 17 told John Doe 102 to apologize to Sandusky and 18 Tarman for telling lies, adding that, "you're 19 probably going to be moved from Nittany House". 20 Did you, in fact, apologize to 21 Mr. Sandusky and Tarman? 22 A I was not told that I had to verbally 23 apologize to them. I was told that I would write 24 them a letter of apology. Golkow Technologies, Inc. V40 Pag;3??3195 Confidential John Doe 102 1 And what was ?n what were you to write a 2 letter apologizing for? 3 A It was what the situation was, they 4 were leaving the front door; this guy was I never 5_ heard him say we'll take care of it or we'll handle 6 it, that's just what he said. 7 And who?s the 8 A Clint Gordon. 9 Okay. 10 A He was leading them out the door, I was 11 sitting the front door's here (indicating); I was 12 probably 15 feet over there, still facing the wall, 13 you know, trying to see what was going on, and he 14 said to me, you're gonna write a letter of apology, 15 and then he added about, the part about being moved, 16 but he said, you're gonna get your ass kicked out of 17 the Nittany House. 18 And the threat all along was if you had to 19 get removed from the Nittany House, you got put in 20 Centre County Youth Detention until they figured out 21 what to do with you after that, send me to another 22 group home. So basically it was a threat of going 23 to the Bellefonte, the one in Bellefonte, the Centre 24 County Youth Detention Center. Case ID: i311 Golkow Technologies, Inc. Page 39 Control No.1 151 Confidential John Doe 102 1 Which is a more serious 2 A. It's prison for juveniles. 3 Okay. But my question is, what were you 4 told you needed to apologize for? A Like I said, it was just a comment. It 6 was just he never said anything, it Was nothing 7 more than you will write a letter of apology to him 8 and this man, and that was it. That was kind of his 9 way of, you know, we got this, I guess. 10 Okay. So do you know whether or not 11 Mr- Gordon communicated to Mr. Sandusky and, 12 assuming it's Mr. Harman or Tarman, what you had 13 told Mr. Gordon about the sexual abuse incident? 14 A I can't say a hundred percent sure, but I 15 doubt they just showed going. 17 That's my question, do you know how they 18 got there or why they were there? 19 A We had a back door the office was right 20 off the kitchen, so there was a back door, there was 21 like a set of steps, and there.was a yard out back, 22 and then it faced like another street, so there was 23 not another house there or parking. 24 And there was a small, little door that Golkow Technologies, Inc. Control No.1 15111035 Confidential - John Doe 102 03195 1 basically was only used for us to go out, and I 2 would assume that?s how they came in, because it was 3 otherwise, they would've had to come past me 4 where I was sitting to come in the front door. 5 Had you ever seen this Mr. Harman or 6 Tarman in this house before? 7 A. Nope. 8 Did you ever write a letter of apology? 9 A No, no, there?s no if you read the next 10 paragraph, it went downhill pretty quick. 11 Okay. Did Mr. Gordon ever talk to you 12 about this your communication to him about this 13 incident again? 14 A Never had the chance. 15 Okay. So tell me what happened after you 16 were told you needed to apologize to these two 17 gentlemen or you needed to write a letter of apology 18 to these two gentlemen. 19 A They went back and ?e Mr. Gordon and 20 I don't remember her last name, went back in 21 the office, and all I remember is a lot of screaming 22 and yelling. And at that point, I walked over to 23 the closet, I grabbed a coat that wasn't even mine, 24 and just hauled ass. tonnarr? 1~11 Golkow Technologies, Inc. Con?nlb?i:151 11035 Confidential a John Doe 102 1 You left the house? 2 A I was gone, like 3 You ran_out of the house? 4 .A 9:00, 9:30 in the morning, yeah. 5 Okay. 6 A Actually, I ran the whole way until I 7 reached campus because I thought for sure somebody 8 would be chasing me. 9 What were you well, let?s just ask 10 this, why did you feel the need to get out of the 11 house so quickly? 12 A Again, I'm putting myself back, as a 13 42?year?old man, in the thoughts of a 16~year~old, 14 but at that time, it felt like there was no other 15 reason; I just had to get the hell out of there, I 16 had to. I didn't know where I was going, what I was 17 gonna do, but I just had to get out. 18 What were you worried about or why were 19 you 20 A Everything. Everything. I didn't I 21 had no idea what was gonna happen next. I didn't 22 know if somebody was gonna come take me, I didn?t 23 know if they were gonna call my probation officer 24 and say, look, we want this guy out of here, do Golkow Technologies, Inc. 3195 Conuulbh1:15111035 Confidential John Doe 102 something with him. I would say there was probably a million thoughts running through my mind, and the flee instinct just kicked in and I was gone. Did you ever think about going and telling anybody else about the sexual abuse incident other than Mr. Gordon? A At that moment, no. .At that moment, I just wanted to put as much distance between that place and whoever may be looking for me as possible. And did you ever tell anybody, other than obviously your lawyer, about the sexual abuse incident, other than Mr. Gordon? A How far down the I mean, are we still in the time line of this? (Indicating.) Well, let's stay with the time line of this and then I'll take you forward_in time. A All right. Yeah, yeah, down the road, yeah, I did. Who did you speak to? A. Well, when I went to the After I had gotten, I don't know, recaptured I was sent to the by the Tor awhile, and kaelEsd??l Golkow Technologies, Inc. 03195 Page 43 Confidential John Doe 102 the team that year, so they always had people who had connections that would come in and either talk to us or spend time with us as I don't know if it was part of something or whatever, but it wasn't unusual to see football people. But I don't remember him just stopping by and coming in and walking through the actual property. And I assume you had never seen Mr. Sandusky and this Mr. Tarman or Harman together A No. at the Nittany House; is that correct? A. No. So at no point did you ever write the apology letter A No. that Mr. Gordon described? A No. But the minute I walked out that door, their reSponsibility was notify the police, and as far as they were concerned, I'm sure I was not their problem anymore. And I assume there had never been there still has never been any follow~up to what you had told Mr. Gordon about the sexual abuse incident? 03195 Golkow Technologies, Inc. Confidential John Doe 102 1 A. Not that I'm aware of. 2 Okay. 3 MR. ENGELMYER: I haVe no further 4 questions. 5 6 EXAMINATION '7 8 BY MS. KORNFELD: 9 John Doe 102, I have only a couple of 10 questions for you. My name is Linda Kornfeld, and I 11 am insurance coverage counsel for the University. 12 And we've been speaking about the incident referred 13 to in the document we've been reviewing where you 14 spoke with Mr. Gordon, and just so I'm clear on your 15 testimony, your memory is that you told Mr. Gordon 16 about the actual abuse by Mr. Sandusky; is that 17 correct? 18 A. Yes. Specifically, the golf course and 19 all that. 20 Right. And then you, in the report and 21 also as you've testified, an individual, whose name 22 you don't remember, but it's you have phonetic 23 memory, you don't know if it's Tarman or Harman or 24 some other name; is that correct? Caninw.i 3?03195 Golkow Technologies, Inc. LLOLI . J. Page Control o. 48 15111035 FILED 09 DEC 2015 10:17 am Civil Administration E. MASCUILLI Exhibit P. Case ID: 131103195 Control N0.: 1511 .1035 Michael J. McQueary 1 IN THE COURT OF COMMON PLEAS 2 PHILADELPHIA COUNTY, 3 CIVIL ACTION ASSOCIATION INSURANCE 4 COMPANY, Plaintiff, 5 VS. - JANUARY TERM, 2012 THE STATE 6 UNIVERSITY AND JOHN DOE A, Defendants. NO: 04126 THE STATE CIVIL ACTION 8 UNIVERSITY, Plaintiff, 9 NOVEMBER TERM, 2013 10 ASSOCIATION INSURANCE COMPANY, 11 Defendants. NO: 03195 12 THE CIVIL ACTION UNIVERSITY, 13 Plaintiff, vs. NOVEMBER TERM, 2013 14 ASSOCIATION INSURANCE 15 COMPANY, Defendants. NO: 03197 16 17 Wednesday, August 26, 2015 18 I I Videotaped oral deposition of MICHAEL 19 J. taken pursuant to notice, was held at the Hilton Garden Inn, 1221 East College Avenue, State 20 College, 16801, at 9:44 on the above date, before Lisa DePascale, a Court Reporter 21 and Notary Public of the Commonwealth of and Delaware. 22 GOLKOW TECHNOLOGIES, INC. 23 877.370.3377 ph 917.591.5672 fax deps?golkow.com 24 Golkow Technologies, Inc. Con?olbhi:15111035 Michael J. McQueary the offense? 2 A. Yes. 3 Q. Did there come a time when you observed Gerald 4 engaged in what you believe to be 5 inappropriate conduct with a minor? 6 MS. ROMAGNOLI: Objection. 7 BY MR. GAGNE: 8 Q. You can answer. 9 A4 Yes. 10 Q. And when did that occur? 11 A. It was the year of 2001. 12 Q. Do you recall what month that was? 13 A. February. 14 Q. Okay. And at that time, you were a graduate 15 assistant; is that right? 16 A. Yes. 17 Q. And I'd like you to describe for me in your own 18 words what it was that you observed? 19 A. Inappropriate sexual molestation of a minor. 20 Q. Okay. Let's see if we can break it down, what 21 happened. Where did you make this observation? 22 A. In one of the shower room facilities of the 23 Penn State football program. 24 Q. And what building was that? Golkow Technologies, Inc. Ck$6d??df??03l95 Michael J. McQueary 1 A. Lasch football building. 2 Q. And what time of day did this take place? 3 A. Nighttime. 4 Q. And do you recall why did you w? why were in 5 that building at that time? 6 A. I had come to bring back some shoes and to do 7 some work on a Friday night. 8 Q. And tell me what you were doing. So you came 9 to bring back the shoes, were you did you have an 10 office you were bringing them to or where were you 11 going to bring the shoes? 12 A. I was 13 MS. ROMAGNOLI: Objection. 14 BY MR. GAGNE: 15 Q. You can answer. 16 A. Okay. I was eventually going to my office, but 17 I had the shoes in my Car and wanted to drop them off 18 in my locker in the shower room facility. 19 Q. Okay. So did you, in fact, approach your 20 [locker? 21 A. Yes. 22 Q. Okay. And what did you hear, see just tell 23 me what happened as you were approaching your locker. 24 MS. ROMAGNOLI: Objection. Golkow Technologies, Inc. Cksedigdf?203l95 Connolbk1315111035 Michael J. McQueary 1 THE WITNESS: Okay . 2 BY MR. GAGNE: 3 Q. By the way, with respect to, you know, counsel 4 for Penn State, your own attorney may object to 5 questions, but I think your attorney will tell you 6 that unless he instructs you not to answer a question, 7 despite an objection, you can answer the question. 8 A. Okay. 9 MR. STROKOFF: I would also say to 10 pause, as you have been doing, in caSe 11 Ms. Romagnoli or Mr. Gagne want to debate the 12 issue 13 THE WITNESS: Okay. 14 MR. STROKOFF: before you proceed. 15 THE WITNESS: Okay. So if you could 16 ask that question again. 17 MR. GAGNEV: Okay. 18 BY MR. GAGNE: 19 Q. You were you approaching your locker to 20 place these shoes in the locker? 21 A. Yes. I was going to the locker room, yes. 22 Q. And tell when me what happened then? 23 A. Okay. I opened the door to the looker room, 24 heard noises coming from the shower room. Golkow Technologies, Inc. Control No: I. 51 1, 1035 Michael J. MoQueary 1 Q. Let's Stop there. 2 A. Okay. 3 Q. What was the nature of the noise that you 4 heard? 5 MS. ROMAGNOLI: Objection. 6 THE WITNESS: Slapping sounds. 7 BY MR. GAGNE: 8 Q. Okay. And then what happened? 9 A. I entered another opening, doorway, but the 10 door was open. My locker is immediately to my right 11 as you enter that door, so I went to that locker and 12 stood in front of it. 13 Q. And there is a shower is there a shower in 14 the Vicinity of your locker? 15 A. In the same locker room. It's not right next 16 to my locker, no. 17 Q. And an and these slapping sounds, did it sound 18 like what did it sound like? Did it sound like 19 somebody hitting an object How would you characterize the slapping? 22 MS. ROMAGNOLI: ObjECtion. 23 THE WITNESS: Skin on skin, 24 slapping- Golkow Technologies, Inc. Ckse?ige?m403195 15111035 Michael J. McQueary 1 BY MR. GAGNE: 2 Q. And what did you do then? 3 A. I looked over my right shoulder into a mirror 4 in the locker room that allowed me to look at a 5 45~degree angle, through the reflection into the 6 shower, actual shower area. 7 Q. And what did you see when you looked in the 8 mirror? 9 A. Mr. Sandusky standing behind a boy, back to 10 or front to back, and.his arms wrapped around him. 11 Q. Mr. Sandusky's arms wrapped around the child? 12 A. Yes. In a very extreme, close, clOSe nature, 13 and it was extremely alarming. 14 Q. Were you able to observe, when you looked in 15 the mirror, whether there was any genital contact 16 between Mr. Sandusky and the boy? 17 MS. ROMAGNOLI: Objection. 18 THE WITNESS: "Genital contact"? I 19 need some more just tell me what you mean by 20 "genital contact." 21 BY MR. GAGNE: 22 Q. Well 23 A. Just so I'm sure. 24 Golkow Technologies, Inc. Control No: 15111035 Michael J. McQueary 1 Q. you said that Mr. Sandusky and the boy were 2 physically very close, correct? 3 A. Absolutely. 4 Q. How much, if any, space was between them when 5 you were looking in the mirror? 6 A. None that I could see. 7 Q. Okay. Did you observe Mr. Sandusky?s genital 8 inside of the young boy? 9 No. I can't say that I observed that. 10 Q. We're we're, again, limited to your 11 observation in the mirror. Were Mr. Sandusky and the 12 boy making any motions? 13 MS. ROMAGNOLI: Objection. 14 BY MR. GAGNE: 15 Q. Or were they standing still? 16 A. Slow, slight motions. 17 Q. I Did you hear either of them at this time say 18 anything or make any verbal sounds? 19 A. No. 20 Q. After you made this observation in the mirror, 21 what did you do? 22 A. I turned back to my locker room, to my locker, 23 not my locker room, sorry, my locker, probably tried 24 to gather my thoughts for a second, then I stepped to Golkow Technologies, Inc. (lme?ige??603l95 Michael J. McQueary 1 my right to make sure I was seeing through the mirror 2 what I thought I saw, and I looked directly into the 3 shower with my own eyes. 4 Q. And what did you step into the shower room? 5 A. No. No, the shower room is away. 6 Q. So how, just estimating if you can, how far 7 away were you from Mr. Sandusky and the boy? 8 MS. ROMAGNOLI: Objection. At what 9 point, Paul? 10 BY MR. GAGNE: 11 Q. When you m? when you looked directly into the 12 room, how far away were you from them? 13 A. Maybe four or five paces. Again, I'm guessing. l4 five yards. 15 Q. Was there anything obstructing your View of 16 Mr. Sandusky and the boy? 17 A. No, nothing obstructing it. 18 Q. Was the area lit well enough for you to see i9 them? 20 A. Yes. 21 Q. And what did you see when you looked directly 22 into the room? 23 A. The same exact as I've already described. 24 Q. Mr. Sandusky in very close front to back Golkow Technologies, Inc. Ckwa?Wya3?103195 Michael J. McQueary 1 physical contact with the boy? 2 Yes. 3 Q. Did he still have his arms around him? 4 A. Yes. 5 Q. When you looked directly into the room, did 6 either did you hear them say anything or make any 7 verbal noises? 8 A. No. 9 Q. And again, did you, when you looked directly 10 into the room, did you see any genital penetration 11 MS. ROMAGNOLI: Objection. 12 BY MR. GAGNE: 13 Q. by Mr. Sandusky? 14 MS. ROMAGNOLI: Objection. 15 THE WITNESS: I did not see penetration 16 with my own eyes, no. 17 BY MR. GAGNE: 18 Q. Did you reach a conclusion as to what was 19 taking place? 20 MS. ROMAGNOLI: Objection. 21 THE WITNESS: Yes. 22 BY MR. GAGNE: 23 Q. And what was your conclusion? 24 A. He was doing something severely inappropriate Golkow Technologies, Inc. (kme?ig?f?803195 Control No: 15111035 Michael J. McQueary 1 and sexual to that boy. 2 Q. What did you do then? 3 A. Turned back to my locker. At some point, put 4 the shoes in my locker and slammed my locker door 5 shut. 6 Q. Okay. Why did you slam the door shut? 7 A. Out of haste, out of trying to let someone know 8 I was there. You can imagine I?m extremely flustered 9 by now. 10 Q. Did you say anything to Mr. Sandusky or to the 11 boy? 12 A. No. 13 Q. Can are you able to describe the boy that 14 you saw? 15 A. Describe himyou know what color he was? 17 .A. A white, Caucasian. 18 Q. Can you estimate his height at all? 19 A. Strictly a guess. 20 Q. What was his age? What did his age appear to 21 be to you? 22 MS. ROMAGNOLI: Objection. 23 THE WITNESS: Eleven 11 or 12. But 24 again, that's a guess; could be, you know, give Golkow Technologies, Inc. Ckmodlge??d03l95 Control Nd: 15.111035 Michael J. McQueary 1 or take a year or two. 2 BY MR. GAGNE: 3 Q. After you slammed your locker, what happened 4 then? 5 A. I stepped, again, toward the locker, which is 6 also towards or not towards the locker. Let me 7 backtrack towards the shower opening, which is also 8 toward the door to leave, paused for a moment, looked 9 directly into the shower again and then left. 10 Q. When you looked into the shower that second 11 time, what did you see? 12 A. That would be the third time. 13 Q. Including the mirror? 14 A. Yes, sir. 15 Q. Okay. So you had looked in the mirror directly 16 into the shower. This was your third view of the 17 situation? 18 A. Yes. 19 Q. Okay. And what did you see at that time? 20 A. Both people facing me and looking at me, 21 side?by?side. 22 Q. By the way, I'm assuming, but I shouldn't, both 23 Mr. Sandusky and the young boy were naked; is that 24 correct? Golkow Technologies, Inc. Case??gel 321d 03195 Con?olbk1215111035 Michael J. McQueary 1 A. Yes. 2 Q. When you saw that they were both facing you, 3 did you make contact with either Mr. Sandusky or 4 the boy? 5 A. Yes. 6 Q. Do you have any doubt that they saw that you 7 were there? 8 A. No doubt. 9 MS. ROMAGNOLI: Objection. 10 BY MS. ROMAGNOLI: 11 Q. Did you say anything to either of them? 12 A. No. 13 Q. Did they say anything to you? 14 A. NO. 15 Q. When Mr. Sandusky and the boy were facing you, 16 how far apart were they? 17 A. Were they from each other? 18 Q. From each other, yes. 19 A. Side by side, maybe a foot or two. 20 Q. Did the boy, based on his facial expression or 21 posture, appear to be in any discomfort or distress to 22 you? 23 MS. ROMAGNOLI: Objection. 24 THE WITNESS: Certainly maybe Golkow Technologies, Inc. Connolbh1115111035 Michael J. McQueary 1 embarrassed, but again, you're guessing by an 2 expression on someone's face. 3 BY MR. GAGNE: 4 Q. After you observed Mr. Sandusky and the boy 5 facing you in the shower, what did you do then? 6 A. I walked out the locker room. 7 Q. Were you concerned that Mr. Sandusky might 8 resume the conduct you had observed? 9 MS. ROMAGNOLI: Objection. 10 THE WITNESS: NO. 11 BY MR. GAGNE: 12 Q. And why is that? 13 A. They had broken it up. They looked right at 14 me, and again, in a quick, hurried, hastened train of 15 thought, assumed that they were going to leave and he 16 knew someone had caught him. 17 Q. By the way, is there any doubt in your mind 18 that that this was Gerald Sandusky that you were 19 looking at? 20 A. No doubt. 21 Q. And was there any doubt in your mind that you 22 had observed something sexual occurring? 23 A. NO doubt. 24 Q. Did you then leave ~h leave the Lasch building? Golkow Technologies, Inc. Control No: 15111035 Michael J. McQueary 1 A. No. 2 Q. And what did you do then? 3 A. I went up to my office. 4 Q. And where is your office in relation to the 5 to the shower room? 6 A. It's on the second floor. So it's one floor 7 above the shower room. 8 Q. What did you do in your office? 9 A. Called my father at his home. 10 Q. Tell me about the conversation with your 11 father, please. 12 A. Again, I was extremely upset. I told him what 13 I had just saw. He asked me are you okay, and I think 14 he may have asked, is anyone else there? And he said 15 come over to the house right away. 16 Q. Did you did you tell your father the details 17 of what you had seen, on the phone? 18 A. Not extreme detail, no. No. 19 Q. To the best of your recollection, and that's n~ 20 that's all I'm looking for is your best recollection 21 at this point, what did you tell your father you had 22 seen? 23 A. That Mr. Sandusky was doing something sexual to 24 a boy in the shower. Golkow Technologies, Inc. (kme?lgeuh303195 Connolbh1215111035 father and Mr. Dranov understood that what you had seen was sexual in nature? BY MR. Q. what your next step should be? A. Q. father? A. first thing in the morning and let him know right away. Q. police Q. A. about it first and foremost. Michael J. McQueary MS. ROMAGNOLI: Objection. GAGNE: And is there any doubt in your mind that your MS. ROMAGNOLI: Objection. THE WITNESS: NO doubt. GAGNE: And did you discuss with your father what Yes. And what decision did you arrive at with your The end decision was to call Coach Paterno Did you discuss with your father whether the should be contacted? Yes. And did you do that that evening? No. Why not? We just thought it best that Coach Paterno knew Golkow Technologies, Case?ggel?iOB 195 Connolfhi:15111035 Inc. Michael J. McQueary 1 Q. Why Coach Paterno? 2 A. There is background to it, but 3 Q. Well, give me whatever background you feel I 4 should have to understand. 5 A. Okay. Coach Paterno has always made it clear 6 that anything that happens in the football office, the 7 football program, on the facilities, he know about it 8 first if it?s of a nature that is I don't know how 9 to word high level or extreme or that he should be 10 aware of. And so after much debate, again, with my 11 father and Dr. Dranov, that's what we decided to do. 12 Q. Joe Paterno was your boss, correctthe evening that you saw 15 Mr. Sandusky with the boy, other than talk to your 16 father and Dr. Dranov about it, did you talk to anyone 17 else about it? 18 A. I can't remember if I did, but I may have. 19 Q. Other than your father and Dr. Dranov, who may 20 you have discussed it with? 21 A. My girlfriend at the time, possibly. 22 Q. And what was her name? 23 Al At that time it was 24 Q. Was employed by the University? Golkow Technologies, Inc. (l?e?gg?3?603l95 Control No.3 1511 1.035 Michael J. McQueary .1 A. No. 2 Q. And did you subsequently talk to Coach Paterno 3 about the matter? 4 A. Yes. 5 Q. And please describe how that came to take 6 place. 7 A. Let me make sure we're clear. I did not talk 8 to Coach Paterno about it that night. 9 Q. Okay. 10 A4 Okay. So the following morning, I called Coach 11 Paterno on the phone and said I need to come over to 12 his house to discuss something. 13 Q. And what did he say? 14 A. On the phone? 15 Q. Yes. I'm sorry, yes. 16 As He said I'm not hiring you, so don't waste your 17 time. And I said, it's not about that, Coach. It's 18 about something very serious, and he said well, come 19 over right awayYes. 22 Q. When you arrived at Coach Paterno's residence, 23 was anyone else there? 24 A. I don't think I saw anyone else there that Golkow Technologies, Inc. I Control No: 151 1 1035 Michael J. McQueary 1 morning. 2 Q. And did you talk to Coach Paterno about what 3 you had seen? 4 A. Yes. 5 Q. Again, to the best of your recollection, what 6 did you tell Coach_Paterno you had seen? 7 MS. ROMAGNOLI: Objection. 8 THE WITNESS: Do you want word for 9 word? 10 BY MR. GAGNE: 11 Q. As best you can as best you can relay that, 12 yes. 13 A. I can't relay word?for?word, but I did tell him 14 that I saw Gerald Sandusky in an extreme, 15 sexually?natured situation and molesting a boy. 16 Q. Did you use the term "molesting," if you 1? recall? 18 A. I can't recall. 19 Q. Did you make clear to Coach Paterno that what 20 you had seen was sexual in nature? 21 MS. ROMAGNOLI: Objection. 22 THE WITNESS: Yes, no doubt. 23 BY MR. GAGNE: 24 Q. Do you have any doubt that Coach Paterno Case?ggel 331 03195 Connolbki:15111035 Golkow Technologies, Inc. Michael J. McQueary understood that what you had seen was sexual in nature? MS. Objection. THE WITNESS: No doubt. BY MR. GAGNE: Q. Did Coach Paterno ask you any questions? A. I think he said he asked me on a personal level, you know, emotionally, mentally, if I was okay. And I you know, he could tell I was really upset. But I don't recall him asking me any other questions, per se. Q. He didn't ask you for additional detail about what you had seen? A. No. MS. ROMAGNOLI: Objection. BY MR. GAGNE: Q. Did Coach Paterno seem surprised by what you were telling him? MS. ROMAGNOLI: Objection. THE WITNESS: Seem surprised? I don?t I wouldn't characterize surprise, but again, he may have been. I don?t want to put a reading of thoughts into his mind when he clearly didn't say I'm surprised, you know, or Golkow Technologies, Inc. Caseplagel 5311 03195 15111035 Michael J. McQueary something. 2 BY MR. GAGNE: 3 Q. Did Coach Paterno instruct you to take any 4 further action? 5 A. Not that morning, no. 6 Q. Did Coach Paterno tell you what he intended to 7 do about the matter? 8 Somewhat, yes. 9 Q. And what did he tell you? 10 He said I need to think about this, who to 11 tell, and I'll let you know. He led me to believe he 12 was going to tell some people and try to handle it. 13 Q. And did he tell you who he Was going to 14 contact? 15 A. I don't believe he did at that time, no. 16 Q. How long did the meeting or conversation with 17 Coach Paterno at his home last? 18 A4 Not long. And again, I'm guessing, so it's a 19 guess but eight, ten, twelve minutes. 20 Q. And did you describe to Coach Paterno, 21 step?by?step, what you had seen, meaning you 22 approached your locker, you observed something in the 23 mirror, and then directly looked into the shower? Did 24 you give him that Golkow Technologies, Inc. Case??gelfal 03195 Connolbki:15111035 Michael J. McQueary 1 A4 No, not 2 MS. ROMAGNOLI: Objection. 3 THE WITNESS: not step by step. 4 BY MR. GAGNE: 5 Q. But you did tell him, is it correct, that you 6 had seen Gerald Sandusky engage in sexual conduct with 7 a young boy? 8 MS- ROMAGNOLI: Objection. 9 THE WITNESS: Are you quoting me or ?e 10 BY MR. GAGNE: 11 Q. I'm asking if that's the essence of what you 12 told him. 13 A. Yes. 14 Q. Okay. You're not able to say word?for?word 15 exactly what you told Coach Paterno? 16 A. No. 17 Q. Did you tell Coach Paterno that you had 18 observed Gerald Sandusky engaged in anal intercourse 19 with the boy? 20 I MS. ROMAGNOLI: Objection. 21 THE WITNESS: No, I did not say that. 22 BY MR. GAGNE: 23 Q. Do you recall, at all, what words you did use 24 to describe what you had seen? Casegg?eif?g 03195 Connolbhi:15111035 Golkow Technologies, Inc. Michael J. McQueary No. Again, that the message was, and the message he received was, that it was extremely sexual; It was bad. It was inappropriate, and it was molestation of a boy. Q. At that time was Coach Sandusky an active member of the coaching staff at Penn State? MS. ROMAGNOLI: Objection. THE WITNESS: NO. BY MR. GAGNE: Q. Were you aware at that time that he was retired? A. Yes. Q. And was it unusual to see Coach Sandusky in the Penn State facilities after his retirement? MS. ROMAGNOLI: Objection. THE WITNESS: NO. BY MR. GAGNE: Q. When would you typically see Coach Sandusky in the Penn State football facilities after his retirement? A. Oh, all the time in the facilities. There was I guess the answer to your question is, there were no typical times; he was in there sporadically all the time. Golkow Technologies, Inc. Case??gel 33 03195 Control No.: 15111035 Michael J. McQueary And was this the first time you had seen him in the presence of a young child? MS. ROMAGNOLI: Objection. THE WITNESS: Up to that point? BY MR. GAGNE: Q. Up to that point? A. No. Okay. You had seen him with children before? A. Yes. Q. Okay. A. It was common. Q. Did you know what The SeCOnd Mile was? A. Yes. Q. What was The Second Mile to your understanding? A. It's a charity to help underprivileged children. I'm not to be frank with you, I'm not sure how they helped them, financially or through scholarships or something, but it was a charity to help underprivileged children. That?s all I know. Q. And to your knowledge, were the children that you saw Gerald Sandusky with participants in Second Mile? MS. ROMAGNOLI: ObjeCtion. Golkow Technologies, Inc. Cas e1 53% 03195 Control No.: 15111035 Michael J. McQueary MR. GAGNE: Q. If you know. A. I think you assume that as a player. Q. Now, you said you communicated to Coach Paterno, and he understood, that what you had seen was sexual in nature; is that correct? MS. ROMAGNOLI: Objection. THE WITNESS: Yes. BY MR. GAGNE: Q. How did Coach Paterno communicate his understanding to you? How do you know that's what he understood? he he did, A. Well, on a personal note again, or a personal level, ask me if I was okay. And you just came to understand that he knew it was very serious at the end by saying he needed to think about it, think about who to tell. That's how he communicated it. Q. And you clearly communicated to him did you clearly communicate to him that what you had seen was, in your opinion, sexual in nature? Objection. THE WITNESS: Yes. Golkow Technologies, Inc. Camn?g?hg 03195 Connolbh1115111035 Michael J. McQueary 1 BY MR. GAGNE: 2 Q. Did you hear back from Coach Paterno, 3 subsequent to that, regarding the matter? 4 A1 Yes. 5 Q. And tell me about that. 6 A. .Are you tell are you asking me if 7 immediately, within a day or two 8 Q. Let's 9 A. or are you talking about the whole entire 10 span up until the end of Coach Paterno's life? 11 Q. Let's start with immediately, in the next day 12 or week or so, did you hear back? 13 A. Yes. Yes. 14 Q. And what did you hear from him? 15 A. I heard that he had taken it to some senior 16 officials at the University and that they would be 17 contacting me. 18 Q. And did he tell you who that was? 19 A. I don't believe he did, no. 20 Q. What else, if anything, did he say other than 21 that you would be contacted by officials? 22 A. He just asked me again on a personal note if I 23 was okay. 24 Q. And what did you tell him? Golkow Technologies Inc. case?EIc?ngel?y 03195 Michael J. McQueary 1 A. I said, yeah, Coach, I'm okay. 2 Q. Did you subsequently were you subsequently 3 contacted by any Penn State officials? 4 A. Yes. 5 Q. And who was that? 6 Al The first time 7 Q. Yes. 8 A. I was contacted? 9 Q. Yes. 10 A. On a phone Call from Mr. Curley. 11 Q. Timothy CurleyAnd what was Mr. Curley's position at the 14 University at that time? 15 A. Athletic Director. 16 Q. And did Mr. Curley come to your office, meet 17 with you, did he call you? 18 A. Called me. 19 Q. Okay. What did he-say in that phone call? 20 A. He Said Coach Paterno had told him that I had 21 seen something that was serious and that he would like 22 to talk to me further. 23 Q. And did you arrange to talk to Mr. Curley? 24 A. Yes. 7 Golkow Technologies, Inc. 03195 Con?clb?1:15111035 Michael J. McQueary the way, how far how long, if you recall, how long after the incident that you observed did Mr. Curley call you? A. Again, it's a guess, but roughly ten days or so. Q. In that intervening ten days or so, did you talk further with Coach Paterno about what you had seen? A. Again, once or twice, only him checking on me personally. I hope I'm getting that point aoross, just to make sure I was okay. Q. In that intervening ten days or so, did you see Coach Sandusky again? A. No. Q. Other than the people you've already testified about, your father, Dr. Dranov, possibly your girlfriend, and Coach Paterno, before you spoke with Mr. Curley, did you talk to anyone else about what you had seen? I may have mentioned it briefly, again, may have, to one of my coworkers, but I can't say that I know for sure that I did. Q. And do you know who that was that you may have mentioned it to? Golkow Technologies, Inc. C3863?g?3? 03195 Control N0.: 15111035 Michael J. McQueary A. No. I couldn't put a guess on it. 2 Q. So did you subsequently meet with Mr. Curley?? 3 A. Yes. 4 Q. -And how long was that after his initial phone 5 call to you? 6 A. Oh, it may have been that afternoon or the next 7 afternoon. It was after that phone call, it was 8 very quick. 9 Q. And where did you meet with Mr. Curley? 10 In a small conference room in the Bryce Jordan 11 Center. 12 Q. And was anyone else present when you met with 13 Mr. Curley? 14 A. Yes. 15 Q. And who was that? 16 A. Mr. Schultz. 17 Q. Is that Gary Schultz? 18 A. Yes. 19 Q. And do you know what Gary Schultz's title at 20 the University was at that timethe vice presidents of the 22 University. 23 Q. Did you know what his responsibilities were? 24 MS. ROMAGNOLI: Objection. Golkow Technologies, Inc. Ckwegg??ugi 03195 Control No.: 151 1.1035 Michael J. McQueary 1 THE WITNESS: They covered a lot of 2 things, I know that. 3 BY MR. GAGNE: 4 Q. Did you know at that time whether his 5 responsibilities included oversight or supervision of .6 the Penn State Police Department? 7 MS. ROMAGNOLI: Objection. 8 THE WITNESS: Yes. 9 BY MR. GAGNE: 10 Q. Yes, that was the case? 11 A. Yes. 12 Q. And to the best of your recollection, can you, 13 please, describe for me what you told Mr. Curley and 14 Mr. Schultz? 15 A. It was very much the same exact meeting that I 16 had with Mr. Paterno, that I had witne58ed and walked 17 into a situation where Jerry Sandusky was in an 18 extreme, sexually~natured situation with a minor boy 19 in the shower, and it was awful and bad and, you know, 20 molestation of a boy. 21 Q. Did Mr. Schultz and Mr. Curley ask you any 22 questions about what you had seen? 23 A. I don't remember them asking me any questions. 24 Q. Did they seem surprised by what you were Golkow Technologies, Inc. {iwe?ige??i 03195 Michael J. McQueary 1 telling them? 2 MS. ROMAGNOLI: Objection. 3 THE WITNESS: Again, like I said about 4 trying to read Mr. Paterno's feelings, I 5 wouldn't want to try to read into what they '6 were portraying to me. Maybe surprised, but 7 more or less blank. 8 BY MR. GAGNE: 9 Q. Did Mr. Schultz or Mr. Curley tell you that 10 they had previously heard of Mr. Sandusky engaged in 11 inappropriate conduct with children? 12 .A. No. 13 MS. ROMAGNOLI: Objection. 14 THE WITNESS: No, they never mentioned 15 that to me. 16 BY MR. GAGNE: 17 Q. Did Coach Paterno tell you, when you met with 18 him at his house on Saturday morning, that he had had 19 previously heard of Mr. Sandusky engaged in 20 inappropriate contact with children? 21 MS. ROMAGNOLI: Objection. 22 THE WITNESS: Let me make sure I 23 understand the question. Are you saying 24 that ?u ask it a different way if you could. 1 Th1 ?1 "1 1 uaseplali?eL 34121 03135 Golkow Technologies, Inc. Control NO.Z 15111035 Michael J. McQueary MR. GAGNE: Q. When you met with Coach Paterno that Saturday morning to describe to him what you had seen, did -he did Coach Paterno tell_you that he had previously heard anything about Coach Sandusky engaged in inappropriate conduct with children? MS. ROMAGNOLI: Objection. THE WITNESS: I don't I don't know if I remember him saying that. BY MR. GAGNE: Q. Is there any doubt in your mind that you communicated to Mr. Curley and Mr. Schultz that what you had observed Mr. Sandusky doing was sexual in nature? MS. ROMAGNOLI: Objection. THE WITNESS: Ask the question again. MR. GAGNE: Could you read that question back, please? (The court reporter read back the pertinent testimony.) THE WITNESS: No, no doubt. BY MR. GAGNE: 1 Golkow Technologies, Inc. maxi Th: k,5 ??el?l 03195 Control N0.: 15111035 Michael J. McQueary 1 Q. And do you have any doubt that Mr. Curley and 2 Mr. Schultz understood that, at least as you described 3 it to them, what you had observed was sexual in 4 nature? 5 MS. ROMAGNOLI: Objection. 6 THE WITNESS: No doubt. 7 BY MR. GAGNE: 8 Q. And how do you know that they understood that? 9 A. They said it was serious. They thanked me for 10 telling them, and they said they would handle it and 11 look into it more, and said that they would take it 12 seriously and handle it. 13 Q. Did they tell you what they were going to do to 14 handle it? 15 AA Not at that time, no, not at all. 16 Q. Did you discuss with Mr. Schultz and Mr. Curley 17 in that meeting whether the police or other 18 authorities should be informed about what you had 19 seen? 20 Ms. ROMAGNOLI: Objection. 21 THE WITNESS: Did I discuss it with 22 them? 23 BY MR. GAGNE: 24 Q. Yes. 03 .195 Connolb?1115111035 Golkow Technologies, Inc. Michael J. McQueary 1 A. No, just that I thought it was extremely 2 serious. And again, by having Mr. Schultz there, it?s 3 my belief that the police are being notified. 4 Q. And approximately how long did this meeting 5 with Mr. Schultz and Mr. Curley take place? 6 A. Again, it's a guess, 15 minutes. 7 Q. And did you describe to Mr. Curley and 8 Mr. Schultz that you had seen Mr. Sandusky in close 9 front?to?back contact with a child in the showers? 10 MS. ROMAGNOLI: Objection. 11 BY MR. GAGNE: 12 Q. Did you give them that detail? 13 A. I can't remember if I gave them that exact 14 detail. 15 Q. Do you remember what details you gave them? 16 .A. That he was molesting a boy for sure, and that 17 it was extremely sexual and bad. 18 Q. Did you give them the step?by?step detail of 19 how you saw.it in the mirror and then 20 A. I can't remember if I did that, no. 21 Q. directly? And when you told them that you 22 had seen Mr. Sandusky molesting a boy in the showers, 23 did they ask you exactly, you know, what was he doing? 24 MS. ROMAGNOLI: Objection. {meggb?34?03lg5 Golkow Technologies, Inc. Connolbki:15]11035 Michael J. McQueary 1 Q. And to the best of your recollection, what did 2 you talk about with Coach Bradley? 3 A. Frankly, at some point in time, I discussed, 4 briefly, what I had seen. And some I'm sure I 5 can't discuss I mean I can?t not discuss, I 6 can't remember every single time Tom and I talked 7 about Sandusky. I mean, we lived together, the whole 8 nine yards. So, you know, I?m sure we talked about 9 several things 10 Q. When ?m 11 A. but I can't 12 Q. I'm sorry. 13 A. can't remember everything. 14 Q. When you told Coach Bradley what you had seen, 15 what was his reaction? 16 MS. ROMAGNOLI: ObjectiOn; foundation. 17 THE WITNESS: Not not shocked. 18 BY MR. GAGNE: 19 Q. Did he tell you that he had had information 20 concerning Gerald Sandusky and children? 21 A. He said he knew of some things. 22 Q. And did he tell you what he knew of? 23 A. Yeah. 24 Q. What did he tell you? 6 Golkow Technologies, Inc. ag Michael J. McQueary A. He said another assistant coach had come to him 2 in the early about a very similar situation to 3 mine, and he said that he had e? someone had come to 4 him as far back as the early '80s about seeing Jerry 5 doing something with a boy. 6 Q. Did he identify who the other coaches were that 7 had given him this information? 8 MS. ROMAGNOLI: ObjeCtion. 9 THE WITNESS: The one in the early 10 '90s, yes. 11 BY MR. GAGNE: 12 Q. And who was that? 13 A. Greg Schiano. 14 Q. Greg Schiano? 15 A. Yes. 16 Q. And did he give you any details about what 17 Coach Schiano had reported to him? 18 MS. ROMAGNOLI: Objection. 19 THE WITNESS: No, only that he had I 20 can't remember if it was one night or one 21 morning, but that Greg had come into his office 22 white as a ghost and said he just saw Jerry 23 doing something to a boy in the shower. And 24 that's it. That's all he ever told me. Golkow Technologies, Inc. Ckx?rolfio. .03195 :15111035 Michael J. McQueary 1 BY MR. GAGNE: 2 Q. Did he tell you what, if anything, he had done 3 about that? 4 MS. ROMAGNOLI: Objection. 5 THE WITNESS: No, he didn't share that 6 with me. 7 BY MR. GAGNE: 8 Q. You don't know if Coach Bradley reported that 9 to anyone? 10 A. I do not know that. 11 Q. And what detail did if any, did he give you 12 about the incident in the early '808? 13 Al None, just that someone had seen him, him being 14 Jerry, doing something to a boy. But again, I don?t 15 know anything other than setting. I mean, I don't 16 know setting, know nothing about that. 17 Q. To the best of your recollection, when did this 18 conversation with Coach Bradley take place? 19 A. Oh, it?s sometime after 2001, mid when I say 20 mid 20008, meaning like 2005, '06; it could have been 21 anywhere in there. But I can't remember an exact date 22 at all. 23 Q. I'll represent to you that when we took his 24 deposition, Fran Ganter testified that Coach Bradley {3&0 Golkow Technologies, Inc. Page 68 onUnlDui.15 103195 111035 Michael J. McQueary 1 had verbally complained to Coach Ganter about Coach 2 Sandusky and his being permitted to be on the Penn 3 State facilities. 4 Did Coach Bradley ever express such 5 opinions to you? 6 MS. ROMAGNOLI: Objection. 7 THE WITNESS: Yeah. You know, Tom was 8 kind of a ~w yeah, he would be upset and 9 frustrated about that, like I was. You know 10 when I said before, I think you asked a 11 question would I ever express if I was 12 frustrated or complained about Jerry being 13 around; it was probably both of us complaining 14 to each other about it. 15 BY MR. GAGNE: 16 Q. Did any other members of the football Staff 17 communicate any communicate to you any knowledge 18 they had regarding Jerry Sandusky and kids? 19 MS. ROMAGNOLI: Objection. 20 THE WITNESS: Can I ask a time period, 21 like ever? 22 BY MR. GAGNE: 23 Q. After 2001. 24 A. After 2001? CassID2131 03195 Golkow Technologies, Inc. Pipe 69 Control 0.: 15111035 FILED 07 JAN 2016 01:04 pm Civil Administration . OWENS KASOWITZ, BENSON, TORRES FRIEDMAN LLP By: Ierold Oshinsky, Esq. Linda Kornfeld, Esq. Natasha Roma gnoli, Esq. Admitted Pro Hac Vice 1633 Broadway New York, NY 10019 (212) 506?1700 joshinsky@kasowitz.com lkomfeld@kasowitz.com nromagnoli@kasowitz.com NARDUCCI, MOORE, FLEISHER, ROEBERG WOLFE LLP By: Patrick J. Wolfe, Jr, Esq. PA Attorney ID. No. 80871 589 Skippack Pike, Suite 300 Blue Bell, 19422 (215) 628?3939 THE STATE UNIVERSITY, Plaintiff, V. ASSOCLUION INSURANCE Defendant. 1 COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY, NOVERMBER TERM 2013 CIVIL ACTION NO. 03195 MOTION CONTROL No. 151 1 1033 PRAECIPE TO TO THE PROTHONOTARY: The documents being requested to be attached are requested to be ?led under seal in accordance with this Court?s December 4, 2015 Order, a copy of which immediately follows this Praecipe. Kindly supplement The State University?s Opposition to Manufacturers? Association Insurance Company?s Motion for Paitial Summary Judgment, Control No. 15111033, with the unredacted Answer, Opposition Memorandum of Law and Exhibits 3 and 4, all of which should be ?led under seal. CaseID: 131103195 Control NO.: 15111033