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 ,9 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 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 ?ance, 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