5.00 FACTUAL BACKGROUND

5.01 In the summer of 2001 parents enrolled her into the gymnastics program at the
World Olympic Gymnastics Academy in Dallas, Texas. NC was 12 years old at the
time, and she was excited about the opportunity to advance her gymnastics skills. WOGA was a
well-known gymnastics facility, as it has been the training for several US. Olympians. When
parents enrolled her into program, they placed their trust and expectations that NC
would be properly cared for and treated in a respectful, professional and healthy manner.

5.02 Approximately one year into the program at WOGA, a coach by the name of Chris
Wagoner expressed his interest in being NC ?s coach. He told NC that she had the potential to be a
great gymnast. He told her that he wanted ?to take her as far as possible and as fast as possible, but
your ass belongs to me.? He also told NC that she would have to do whatever he said. Over the
course of the next several months, NC trained with Wagoner virtually everyday, for extensive hours.
They trained some days until 10:00 pm to midnight.

5.03 In the summer of 2002, Wagoner began advising NC that her development was being

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held back because of her ?weight problem. NC weighed approximately 85 lbs. at the time.
Wagoner suggested that NC consider bulimia as a means for losing and controlling her weight, and
he recommended NC speak with another student who Wagoner knew was bulimic. NC became
bulimic and started losing weight. Eventually, NC developed health problems to the point that she
was throwing up uncontrollably and throwing up blood. Additionally, body lost a lot of
strength, which led to her sustaining numerous injuries and developing other health problems. When

NC informed Wagoner of her health problems due to bulimia, Wagoner told her that he would help

her through it, but that she could not tell her parents.

 

PLAIN ORIGINAL PETITION . PAGE 4