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M A N L Y, S T E W A R T & F I N A L D I
19100 Von Kar man Ave., S uit e 800
Ir vi ne, Cali fornia 92612
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25.

As part of the training, coaching, preparation and/or conditioning of elite level

gymnasts at THE RANCH, the KAROLYI DEFENDANTS took custody, control, dominion,
and/or sole supervision of the minor female gymnasts placed in their charge at THE RANCH.
Under the applicable law, BELA KAROLYI and MARTA KAROLYI (as well as their agents,
employees, and/or servants of KAROLYI TRAINING CAMPS, LLC, KAROLYI WORLD
GYMNASTICS INC., and KAROLYI'S ELITE who were also in contact with minor children)
were “mandated reporters” as their duties involved the direct contact with minor children. Such
an obligation required BELA KAROLYI and MARTA KAROLYI to report any suspected child
abuse upon belief that abuse was occurring.
26.

Plaintiff is informed and believes, and on that basis alleges, that the KAROLYI

DEFENDANTS allowed the Perpetrator (NASSAR) to be in contact with minor children,
including the Plaintiff, in order to purportedly provide medical care and treatment to the minor
children in the custody, care, and control of the KAROLYI DEFENDANTS. It was under this
guise that KAROLYI DEFENDANTS permitted the Perpetrator (NASSAR), as a matter of
custom and practice, to be alone with minor child gymnasts, including the Plaintiff, to sexually
abuse, harass, and molest them.
27.

Plaintiff is informed and believes, and on that basis alleges that the KAROLYI

DEFENDANTS instituted a regime of intimidation and fear at THE RANCH for the minor
children under their custody, care, and control. Plaintiff is informed and believes that BELA
KAROLYI and MARTA KAROLYI engaged in tortious and unlawful behavior, and created a
toxic environment where the Perpetrator (NASSAR) was given opportunity to perpetrate and
continue his systematic sexual abuse of minor children, without abatement. Plaintiff is informed
and believes and on that basis alleges that minor child gymnasts, including the Plaintiff, were
subjected to physical, sexual, and emotional abuse while at THE RANCH.
28.

Periodically, Defendants BELA KAROLYI and MARTA KAROLYI engaged in

unlawful and tortious conduct directed at minor child gymnasts that included, but was not limited
to: striking minor child gymnasts, scratching minor child gymnasts until they bled, encouraging
-12COMPLAINT FOR DAMAGES