Stephen Penny, Jr.
Doe vs. USA Gymnastics, Inc.

December 9, 2015
Page 6

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of your last deposition, that you'd like to change or

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add to?

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A

No.

The only -- nothing I would like to change.

The

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only clarification that I thought was worthwhile was

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as it relates to the role of our attorney in dealing

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with investigations, if you will, and especially when

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I first became CEO and a lot of the time frame that

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we're talking about between '05 and '07, '08.

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Jack Swarbrick was legal counsel for USA

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Gymnastics, and so much of the activities around these

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types of issues was managed by our attorney, and it

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still is today, because the investigative process and

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things like that are all done through legal counsel.

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So, that's the only thing that kind of came to

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mind as I was reviewing the deposition and some of the

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conversations that Mike and I have had related to, you

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know, topics we've discussed.

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Q

So as far as the changes that you or -- the

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clarification -- excuse me -- that you're talking

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about for your previous deposition is that you in

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conjunction with the attorney for USAG at the time,

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Jack Swarbrick dealt with issues of sexual misconduct

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of Members?

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A

Yeah.

We referred -- in the deposition, we referred

to sort of the Executive Office dealing with issues

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