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Brief in opposition

Brief in opposition

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Published by lc_nichols5019
'John Doe 6' opposes Penn State's motion to delay his case.
'John Doe 6' opposes Penn State's motion to delay his case.

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Published by: lc_nichols5019 on Mar 05, 2013
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03/05/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA JOHN DOE 6Plaintiff v. THE PENNSYLVANIA STATEUNIVERSITY, THE SECOND MILE ANDGERALD SANDUSKY, INDIVIDUALLYAND IN HIS OFFICIAL CAPACITY FOR THE SECOND MILE,DefendantsCIVIL ACTION:::::: No. 2:13-cv-00336-AB:::::: JURY TRIAL DEMANDED:: ______________________________________________________________________________ 
PLAINTIFF’S OPPOSITION TO DEFENDANT PENN STATE UNIVERSITY’SMOTION TO STAY
 For the reasons set forth in the Memorandum of Law filed concurrently with this Motion,Plaintiff John Doe 6 opposes the Motion of Defendant Pennsylvania State University for a stayin this action. Plaintiff incorporates its Memorandum of Law in Opposition to the Motion toStay as though fully set forth herein at length.Dated this ___1st____ day of _______March____, 2013By: __________/s/___________________ Brian Ketterer, Esquire ( Bar #88898)Hal Kleinman, Esquire (Bar #92702) JANET, JENNER & SUGGS, LLC1777 Reisterstown RoadSuite 165Baltimore, MD 21208(410) 653-3200(410) 653-6903 (fax)
Case 2:13-cv-00336-AB Document 22 Filed 03/01/13 Page 1 of 12
 
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 ________/s/______________________ Howard Alan Janet, Esquire(Pro Hac Vice)Kenneth M. Suggs, Esquire(Pro Hac Vice) Jason B. Penn, Esquire(Pro Hac Vice) JANET, JENNER & SUGGS, LLC1777 Reisterstown Road, Suite 165Baltimore, MD 21208(410) 653-3200(410) 653-6903 (fax)Attorneys for Plaintiffs
Case 2:13-cv-00336-AB Document 22 Filed 03/01/13 Page 2 of 12
 
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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA JOHN DOE 6Plaintiff v. THE PENNSYLVANIA STATEUNIVERSITY, THE SECOND MILE ANDGERALD SANDUSKY, INDIVIDUALLYAND IN HIS OFFICIAL CAPACITY FOR THE SECOND MILE,DefendantsCIVIL ACTION:::::: No. 2:13-cv-00336-AB:::::: JURY TRIAL DEMANDED::: _____________________________________________________________________________
MEMORANDUM OF LAW OF PLAINTIFF JOHN DOE 6 IN OPPOSITION TO DEFENDANTPENN STATE UNIVERSITY’S MOTION TO STAY
 Plaintiff John Doe 6 (hereafter “Plaintiff” or “John Doe 6”), by his attorneys, Janet, Jenner &Suggs, LLC, submits the following Memorandum of Law in Opposition to the Motion to Stay submittedby Defendant The Pennsylvania State University (hereafter “PSU.”)
BACKGROUND
Beginning in May 1998, Defendant Gerald Sandusky engaged in indecent contact with John Doe6 and sexually abused him. According to a report prepared at PSUs behest by former Judge and FBIDirector Louis Freeh, (attached hereto as Exhibit 1) Sandusky had engaged in sexually deviate conducton the Penn State Campus as early as the 1970’s. PSU recognized and/or should have recognized thatSandusky was using his position as a University employee and University facilities to bring minor boys
Case 2:13-cv-00336-AB Document 22 Filed 03/01/13 Page 3 of 12

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