March 8, 2017
VIA E-MAIL & U.S. MAIL
MR. LAWRENCE F. PROBST III
President of the United States Olympic Committee
United States Olympic Committee
1 Olympic Plaza
Colorado Springs, CO 80909
Dear President Probst,
My name is John Manly, I am an attorney in California and I write this letter on behalf of
more than seventy (70) young girls and women who are victims of sexual abuse and whom I
represent. These women and girls were serially, sexually abused by Dr. Lawrence Nassar (“Dr.
Nassar”), former USA Gymnastics National and US Women’s Gymnastics Olympic Team doctor,
for more than 20 years.
Our clients include Olympians, National Team members, World Champions, collegiate
athletes and recreational gymnasts, as well as the regional and local athletes who were exposed
to this monster and other molester coaches affiliated with USA Gymnastics. This letter demands,
on behalf of our clients as well as all women who have suffered from this scourge at USA
Gymnastics, that USA Gymnastics be de-certified as the National Governing Body for
gymnastics, by the United States Olympic Committee (USOC).
The reasons for our request for the de-certification of USA Gymnastics by the USOC are
straightforward, clear and indeed required under Federal law. The Ted Stevens Amateur Sports
Act mandates that all athletes have a right to compete, free from discrimination. Without
question, the serial rape and molestation of hundreds of girls, by coaches, trainers and other USA
Gymnastics’ staff, materially inhibits these women’s ability to participate in their sport and is
discriminatory on its face.

 MR. LAWRENCE F. PROBST III
President of the United States Olympic Committee
United States Olympic Committee
March 8, 2017
Page 2

USA Gymnastics leadership and the majority of its Board has enabled sexual predators
for decades, through inaction and concealment. In short, the leadership of USA Gymnastics has,
and continues to, defend the indefensible. The Indianapolis Star reports that over the course of 20
years, there have been over 360 cases of coaches being accused of sexually abusing girls.
Currently, there are 80 pending criminal allegations lodged against Dr. Nassar for sexual abuse,
alone. This is despicable. USOC has an obligation to act, and demanding the resignation of Mr.
Penny is clearly not enough. This is an organization that has no credibility when it comes to child
protection. USA Gymnastics needs to be held accountable and reorganized from top to bottom.
While the call for Mr. Penny’s resignation is long overdue and applauded, Mr. Penny is
only a symptom of this endemic problem. The entire USA Gymnastics’ leadership and
management shares the blame for this failure. If the wholesale rape of hundreds of children
because of organizational culture and indifference is not enough, then respectfully, what is? We
await your reply.
Very truly yours,

JOHN C. MANLY, ESQ.
MANLY, STEWART & FINALDI