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Case Document 41 Filed 10/09/07 Page 11 of 15

discovery process not only limits the ability of USA Gymnastics to prepare its defenses for trial,
but also materially limited the plaintiff?s deposition by preventing USA Gymnastics from
preparing an examination relating to her specific allegations of harm. Accordingly, USA
Gymnastics respectfully requests that the Court compel Mary Doe to fully and completely
respond to this request, and also consider granting USA Gymnastics leave for additional
deposition time with plaintiff.

Mary Doe?s Response:

Plaintiff Mary Doe is still working through the damages that she sustained
at the hands of the USGF ?Professional Member? coach. Before this motion was ?led, on
September 18, 2007, Defendant USA Gymnastics completed a deposition of Ms Doe?s
treating who addressed the subject matter of Interrogatory No. 12 in great detail.

See, Declaration of Kevin P. Mahoney ?led in conjunction with this pleading.

INTERROGATORY N0. 13: What total sum of money in damages do you seek to
recover from USA Gymnastics in this action?

ANSWER: Verbatim Text] There is no amount of money that would fairly
compensate a woman for the devastation of adolescent sexual abuse at the hands of an authority
?gure ?Professional Member? of a governing body for the sport of Gymnastics in the
USA). Accordingly, it is virtually impossible to quantif
/However, mediation conducted in Jane Doe v. USA Gymnastics, a remarkably similar case

. defense mock trials, revealed that the value of the Hammond case under Oregon law, would be



approximately one million dollars. That figure would include general and special damages,

including the cost of future counseling.

   

ymnastics rgume

Once again, Mary Doe fails to participate in the discovery process -- even though the
requested information is within the scope of her mandatory initial disclosures under Rule 26 and

has not previously been provided, despite requests from counsel. Moreover, Mary Doe?s answer

CR 37 SUBMISSION REGARDING USA Cairncross Hempelmann? RS,
INTERROGATORIES TO MARY DOE Law O??t?ces

524 Second Avenue, Suite 5 00
CAUSE C06-1812JLR 1 1 Seattle. Washington 98104-2323

Phone: 206-587-0700 0 Fax: 206-587-2308
[004200152 nnr- I '1