5.04 As an alternative means for controlling her weight, Wagoner suggested that NC
consider using cocaine. He explained to NC that cocaine would give her extra energy for her
workouts, and it would also help her ?weight problem? by suppressing her appetite.

5.05 One evening, while NC was at WOGA for practice, Wagoner convinced her to leave
the with him and he took her go to a biker bar on Harry Hines Blvd. called Strokers Ice House.
While NC was there, she was approached by a man who walked up to her and started talking to her
about cocaine. He then took her outside behind the bar and gave her some cocaine. He also gave
NC his phone number so she could call him whenever she needed more. Subsequent to that
encounter, NC began using cocaine prior to her gymnastics workouts, and she told Wagoner that she
was using cocaine to control her weight instead of bulimia. Fully aware of this, Wagoner did
nothing. Instead, he simply told NC to ?be careful with it [cocaine]?, and he continued to train her.

5.06 In September 2002, NC was asked to help Wagoner and his ?anc?, another WOGA
coach, move into a new apartment. While NC was at their apartment, Wagoner told NC that he
wanted to be more than just her coach, and he kissed NC. NC was 14 years old at the time. He also
tried to have sex with NC, despite NC telling him to stop. Wagoner eventually stopped because he
was afraid his ?anc?, who was in the next room, would hear them. He told NC that she could not
tell anyone about what had happened, and if she did, she would be kicked off the gymnastics team.
He also told NC that he had worked as a ?hit man? before, and he implied that if she ever said
anything, he would hurt her family. The next day, Wagoner and NC were at the WOGA facility, and
Wagoner took NC to the back room and persuaded her to have intercourse and oral sex with him.

In fear for her safety, as well as her family?s, NC did not say anything.

 

PLAINTIFF ?8 ORIGINAL PETITION PAGE 5

5.07 Over the course of the next year, on virtually a daily basis, Wagoner engaged in
sexual conduct with NC, including fondling, sexual intercourse and oral sex. Wagoner had sex with
NC at the WOGA in Richardson, Texas, in the dance room, the employees? room, the party
room and in the area. On several occasions, Wagoner took NC away from the to nearby
parking garages and a shopping mall, where he would have sex with NC. Further, during private
workouts, Wagoner would fondle NC in her genitalia why she stretched. Wagoner also had sex with
NC at the WOGA in Plano, Texas, in the back room, the side room that had a one way mirror,
the boy?s bathroom and the storage room.

5.08 NC was traumatized and scared throughout this entire ordeal. While she wanted to
tell someone, she chose not to because of the threats Wagoner had made. As such, NC had no where
to turn, and she simply hoped that it would stop one day.

5.09 During this time period, there were several instances at WOGA where some of the
parents observed Wagoner touching girls, including NC, in an inappropriate manner. Complaints
were made to the owners of WOGA, yet nothing was done. WOGA did transfer Wagoner to their
in Plano, but WOGA continued to allow Wagoner to coach girls, including NC, one?on?one.

5.10 Eventually, Wagoner?s ?anc? discovered his relationship with NC. Wagoner le?
WOGA and NC quit training at WOGA. Wagoner continued to stalk and harass NC, but he
eventually moved to Florida. NC continued using cocaine and her life continued to spiral downward.
NC was caught at school with drugs and she was arrested. At that point, NC revealed what she had
been enduring over the past year or so. The police authorities eventually arrested Wagoner, and he
has been indicted on four counts of aggravated sexual assault with a minor. Plaintiff is under the

belief that Wagoner has confessed to the charges.

 

PLAINTIFF ?8 ORIGINAL PETITION PAGE 6