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At all times material hereto, defendant, Penn State, acted by and through itsauthorized agents, servants, and employees, including President, Graham B. Spanier (“Spanier”),Senior Vice President for Finance and Business, Gary C. Schultz (“Schultz”), Athletic Director,Timothy M. Curley (“Curley”), Gerald Sandusky (“Sandusky”), a defensive coordinator for theUniversity’s football team, and Head Football Coach, Joseph W. Paterno (“Paterno”), all of whom were acting within the full course and scope of the authority vested in them by defendant.7.
Penn State’s football program has, for decades, been integral to the University’sreputation and finances. The school’s “Nittany Lions” are and have been a source of significantrevenue for the school, through, among other things, ticket sales, television broadcasts, andmerchandising.8.
At all times material hereto, defendant had a paramount financial interest in protecting the reputation and commercial viability of its football program.9.
Beginning in 1969, Gerald Sandusky was employed by defendant, Penn State,serving in a variety of coaching positions, most notably as the defensive coordinator of theschool’s heralded Nittany Lions football team, a position he held for 23 years. As set forth in thisComplaint, however, Sandusky’s affiliation with Penn State continued after the formalconclusion of his coaching tenure, as defendant conferred upon Sandusky “emeritus” rank andagreed to a retirement contract that conferred upon Sandusky numerous privileges, including theuse of a University office and telephone, and the perpetual use of defendant’s facilities.10.
Sandusky is a pedophile; a rapist disguised as an avuncular sports figure. At alltimes material hereto, Sandusky used his position and status at Penn State as a means of introducing himself to young boys, many of whom would become victims of his sexual assaults.