13.

14.

Plaintiff admits to the plain language of Article 10 Gymnastics Bylaws but

denies that complaints are handled by USA Gymnastics exclusively under Article 10.

Article 9 is also a provision utilized by and applicable to the Defendant?s-obligations to
its members when it receives information about a member coach?s sexual misconduct
against a member athlete. I

Plaintiff denies that the USA. Gymnastics Bylaws do not provide for the investigation of

rumors, anonymous claims, or hearsay allegations. There is no language in Article 9 or

10 that prohibits the investigation of rumors, anonymous claims or hearsay allegations.

Additionally, the 54 coaches complaint ?les produced by Gymnastics prove that

15.

complaints were handled in a variety of ways, including investigation where there is no
statement from the aggrieved member or the parent or guardian of the aggrieved member,
as well as no investigation when there is a statement from the aggrieved member or the
parent or guardian of the aggrieved member. The complaint ?les also contain evidence
that the Defendant has investigated rumors, anonymous claims or hearsay allegations.
Plaintiff denies that every Complaint must be substantiated by a written, signed statement
from the aggrieved member or the parent or guardian of the aggrieved member. First, the I
Bylaws in effect in 1998 do not contain this limitation. Secondly, the 54 coaches
complaint ?les produced by USA Gymnastics prove that complaints were handled in a
variety of ways, including investigation where there is no statement from the aggrieved
member or the parent or guardian of the aggrieved member, as well as no investigation
when there is a statement from the aggrieved member or the parent or guardian of the

aggrieved member. Finally, Robert Colarossi testi?ed he inherited the policy from the

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