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

Page 6?2 '1 of exit

 rv- 2  
IN THE STATE COURT OF EFFINGHAM COUNTY ma ion RECO 1
STATE OF GEORGIA
JANE cos:53
Plaintiff, CIVIL FILE NO. ?can-is 
ST13CV058RT

vs. 

USA GYMNASTICS, INC d/b/a 
USA GYMNASTICS, 
METRO, IN (3., and 
WILLIAM A. MCCABE 

Defendants. 
ORDER

The Plaintiff?s Motion to Compel having been read and considered and upon considering
the oral arguments of both parties it is hereby, ORDERED and ADJUDGED that Plaintiffs
Motion to Compel is hereby GRANTED in part and RESERVED in part.

That defendant USA Gymnastics, Inc, (Mb/a USA Gymnastics is hereby ORDERED to
produce within ten (10) days to Plaintiff cOpies of any and all coaches complaint ?les from
January 1, 1996 to December 31, 2006 regarding complaints, both formal and informal, of sexual
misconduct by a professional member or about sexual abuse of member athletes by member
coaches. Defendant USA Gymnastics is also hereby ORDERED to produce within ten (10) days
cepies of any and all written or electronic complaints sent to USA Gymnastics by either a victim
or victim?s parents involving allegations of sexual abuse or sexual misconduct by a professional
member from January 1, 1996 to December 31, 2006. All documents produced pursuant to this
Order will be protected by the Stipulated Con?dentiality and Protective Order signed on June 15,

2015.

The Court reserves ruling on. the portion of the Plaintiff?s Motion to Compel on the issue
of the production of ?nancial information associated with the Defendant?s investigation into

complaints Oif?sexua] misconduct by member coaches.

so ORDERED THIS 7 3% day of 2015.

(ML

RONALD K. 
COURT OF EFFINGHAM COUNTY