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SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

Lead Case No: BC599321
Judge: Michael P. Vicencia
Dept: S-26
Complaint Filed: October 29, 2015

Plaintiffs:

KENDRA GATT, BRIANNA BORDON, and YAZMIN BROWN

vs.

Defendants:

USA TAEKWONDO, LATIN AMERICAN INTERNATIONAL
TAEKWONDO FEDERATION, LTD., d/b/a GLOBAL AMERICAN
INTERNATIONAL TAEKWONDO FEDERATION, INC., NV
TAEKWONDO TRAINING AND FITNESS CENTER, CALIFORNIA
UNIFIED TAEKWONDO ASSOCIATION, UNITED STATES OLYMPIC
COMMITTEE, GARY JOHANSEN, KRYSTAL GRAHAM, MARC
GITELMAN, and DOES 1-50 inclusive
____________________________________________________
VIDEO DEPOSITION OF GARY JOHANSEN
September 27th, 2016
____________________________________________________
PURSUANT TO NOTICE, the video
deposition of GARY JOHANSEN, was taken on behalf of
the Plaintiffs at the 121 South Tejon Street, Suite
900, Colorado Springs, Colorado, on September 27,
2016, at 1:44 p.m., before Karen J. Hathcock,
Registered Merit Reporter, Registered Shorthand
Reporter and Notary Public within the State of
Colorado.
1 A P P E A R A N C E S
2 ON BEHALF OF THE PLAINTIFF KENDRA GATT:
3 KENNETH C. TUREK, ESQ.
Turek Law, P.C.
4 600 B Street, Suite 2400
San Diego, California 92101
5
ON BEHALF OF THE PLAINTIFF BRIANNA BORDON:
6
JONATHAN C. LITTLE, ESQ.
7 Saeed & Little, LLP
1433 North Meridian Street
8 Suite 202
Indianapolis, Indiana 46202
9
ON BEHALF OF THE PLAINTIFF YAZMIN BROWN:
10
STEPHEN ESTEY, ESQ.
11 Estey Bomberger, LLP
2869 India Street
12 San Diego, California 92103
13 ON BEHALF OF THE DEFENDANT U.S. OLYMPIC COMMITTEE
and GARY JOHANSEN:
14
MARGARET HOLM, ESQ.
15 Bonne Bridges Mueller O'Keefe & Nichols
SEDGWICK, LLP
16 2020 Main Street, Suite 1100
Irvine, California 92614
17
ON BEHALF OF THE DEFENDANT USA TAEKWONDO:
18
EVAN OKAMURA, ESQ.
19 Reback McAndrews Kjar Warford &
Stockalper, LLP
20 1230 Rosecrans Avenue, #450
Manhattan Beach, California 90266
21
Also Present: Rodney Hudson, Videographer
22 Chris McCleary
23
24
25

Page 2
1 I N D E X Page
2

EXAMINATION OF GARY JOHANSEN
3 September 27, 2016
4 By Mr. Estey: 6
5 By Mr. Little: 107
6 By Ms. Holm: 135
7 By Mr. Little: 137
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Page 3
1 I N D E X (Cont.)
2 INITIAL
DEPOSITION EXHIBITS REFERENCE
3

For the Plaintiffs:
4 09:35:59

17 Email from Ladytkd to John Ruger, 59
5 Gary Johansen, dated March 12, 2014 09:24:49
6 20 American Arbitration Association - 41 09:24:49

Commercial arbitration Tribunal - AWARD
7

21 Email from Ladytkd to Malia Arrington, 59
8 Gary Johansen, dated March 7, 2014
9 22 String of Emails 74
10 22A String of Emails 78
11 23 String of Emails 81
12 24 String of Emails 87
School of Law
13

25 Biography of Gary Johansen 89
14

26 NGB Best Practices Seminar Agenda 92
15

27 United States Olympic Committee - 94
16 Policy Regarding NGB Commercial
Agreements
17

28 Article - "Under Fire - Askinas out as 97
18 CEO of USA Taekwondo
19 29 String of Emails 100
20 30 Peak Insurance Group Document 114
21
22
23
24
25

Page 4
1 (WHEREUPON, the following proceedings were

2 taken pursuant to the Colorado Rules of Civil

3 Procedure:)

4 THE VIDEOGRAPHER: Good afternoon. My 01:42:58

5 name is Rodney Hudson. I'm the video operator 01:42:59

6 today, and I'm employed by Imagine Reporting, 01:43:03

7 located at 600 West Broadway, Suite 1225, San Diego, 01:43:05

8 California. 01:43:11

9 Today's date is September 27th, 2016. The 01:43:12

10 present time is 1:44 p.m. 01:43:16

11 The current location of this deposition is 01:43:19

12 121 South Tejon, Colorado Springs, Colorado. 01:43:23

13 Today's witness is Gary Johansen in the 01:43:26

14 case of Gatt, et al. v. USA Taekwondo, et al. 01:43:31

15 This deposition was noticed by Estey & 01:43:39

16 Bomberger, et al., for the Plaintiff. 01:43:41

17 Will counsel for the parties please 01:43:43

18 identify themselves and state for whom they are 01:43:45

19 appearing. 01:43:47

20 MR. ESTEY: Steve Estey for Plaintiff 01:43:47

21 Yazmin Brown. 01:43:49

22 MR. LITTLE: John Little for Plaintiff 01:43:51

23 Brianna Bordon. 01:43:51

24 MR. TUREK: Ken Turek for Plaintiff Kendra 01:43:53

25 Gatt. 01:43:55

Page 5
1 MR. OKAMURA: Evan Okamura for Defendant 01:43:56

2 USA Taekwondo. 01:43:56

3 MS. HOLM: Margaret Holm for Defendant 01:43:58

4 United States Olympic Committee. 01:43:58

5 GARY JOHANSEN, 01:44:11

6 having been sworn to tell the truth, testified as 01:44:11

7 follows: 01:44:11

8 EXAMINATION 01:44:11

9 BY MR. ESTEY: 01:44:11

10 Q. Good afternoon, sir. Could you state your 01:44:12

11 name and spell your last for the record, please. 01:44:14

12 A. Gary Johansen, J-O-H-A-N-S-E-N. 01:44:17

13 Q. All right. Have you ever had your 01:44:20

14 deposition taken before? 01:44:22

15 A. No. 01:44:23

16 Q. All right. Let me go over some of the 01:44:25

17 ground rules even though you are an attorney. 01:44:27

18 Do you understand that your testimony here 01:44:29

19 today is under penalty of perjury? 01:44:29

20 A. Yes. 01:44:32

21 Q. The court reporter to your left will take 01:44:32

22 down everything that's said. At a later date, 01:44:34

23 she'll type up in a transcript or a booklet format. 01:44:36

24 You'll be given an opportunity to review the 01:44:36

25 transcript and make any changes you feel are 01:44:36

Page 6
1 necessary, but I want to caution you, if you make a 01:44:44

2 substantial change, like a "yes" to a "no," that 01:44:48

3 could prove embarrassing and -- and could affect 01:44:50

4 your credibility at trial. That's the reason it's 01:44:54

5 very important to give us the most truthful, 01:44:55

6 accurate and complete testimony here today, okay? 01:44:55

7 A. Okay. 01:44:59

8 Q. All right. If you don't understand a 01:45:02

9 question, please have me rephrase it. 01:45:03

10 If you answer a question, I'll assume you 01:45:05

11 understood it. Is that fair? 01:45:06

12 A. If I don't understand a question, I'll ask 01:45:09

13 you to rephrase it. 01:45:11

14 Q. Good deal. 01:45:12

15 Any reason why we can't go forward with 01:45:13

16 the deposition? 01:45:15

17 A. None. 01:45:15

18 Q. All right. Let's start with your 01:45:17

19 educational background since high school, please. 01:45:18

20 A. I went to the University of Iowa. Got my 01:45:22

21 undergraduate degree. And then I got my legal 01:45:26

22 degree from the University of Iowa as well. I did 01:45:29

23 take some MBA courses at American University. 01:45:32

24 Q. All right. What was your undergrad degree 01:45:36

25 in Iowa? 01:45:38

Page 7
1 A. General science and psychology. 01:45:39

2 Q. And what year was that? 01:45:45

3 A. 1967. 01:45:46

4 Q. Okay. And then you're -- you got a JD? 01:45:48

5 A. Yes. 01:45:52

6 Q. And what year was that? 01:45:52

7 A. 1970. 01:45:54

8 Q. Are you licensed to practice law in the 01:45:57

9 state? 01:45:59

10 A. In Colorado? 01:46:00

11 Q. Any state. 01:46:01

12 A. Yes. 01:46:02

13 Q. All right. And any other states? 01:46:03

14 A. Yes. 01:46:06

15 Q. What other states? 01:46:06

16 A. Iowa, Alaska, Colorado, Washington, D.C., 01:46:09

17 Connecticut, New York, and New Mexico. 01:46:17

18 Q. So, you've taken a few bars. 01:46:22

19 A. Yes. 01:46:24

20 Q. All right. Let's talk about your 01:46:28

21 occupational background. 01:46:34

22 Who is your current employer? 01:46:35

23 A. United States Olympic Committee. 01:46:36

24 Q. And your title? 01:46:39

25 A. Associate General Counsel. 01:46:40

Page 8
1 Q. How long have you been Associate General 01:46:45

2 Counsel? 01:46:47

3 A. I started at the USOC in 1999. 01:46:48

4 Q. And that was your title then? 01:46:54

5 A. Yes. I believe so. 01:46:56

6 Q. And that's your title today? 01:46:57

7 A. Yes. 01:46:59

8 Q. What are your duties as Associate General 01:46:59

9 Counsel? 01:47:02

10 A. I provide legal counsel to the United 01:47:03

11 States Olympic Committee. 01:47:04

12 Q. And who is your boss? 01:47:11

13 A. Chris McCleary. 01:47:13

14 Q. Is he here? 01:47:15

15 A. Yes, he is. 01:47:17

16 Q. Oh, okay. 01:47:18

17 And how long has Mr. McCleary been your 01:47:21

18 boss? 01:47:24

19 A. For a year and nine months. 01:47:24

20 Q. Okay. Prior to Mr. McCleary, who was 01:47:27

21 your -- who was your boss? 01:47:29

22 A. Rick Adams. I had a dual reporting. Also 01:47:30

23 Rana Dershowitz. 01:47:36

24 Q. Okay. And your office physically is -- is 01:47:39

25 located here in -- in Colorado Springs? 01:47:49

Page 9
1 A. Yes, it is. 01:47:51

2 Q. All right. And do you have people below 01:47:55

3 you that you have to supervise? 01:47:57

4 A. I supervise a paralegal. 01:48:00

5 Q. So, on a day-to-day basis, what are you 01:48:12

6 doing as legal counsel for the USOC? 01:48:15

7 A. I handle issues dealing with anti-doping 01:48:19

8 matters, organizational matters dealing with our 01:48:24

9 membership, and athlete matters. 01:48:29

10 Q. And you say regarding your membership. 01:48:36

11 What is -- what's -- what's -- what's the membership 01:48:38

12 you speak of? 01:48:39

13 A. The USOC has various members, member 01:48:40

14 organizations. 01:48:44

15 Q. Are those the National Governing Bodies 01:48:45

16 we've been talking about? 01:48:47

17 A. They would be one class of members, yes. 01:48:48

18 Q. Who else can be a member of the USOC? 01:48:50

19 A. There's a community-based sports 01:48:53

20 organization member, there's an armed services 01:48:55

21 member, there's recognized sport organization 01:48:58

22 member, and there's an education-based member, or 01:49:01

23 members. 01:49:06

24 Q. Okay. And then as far as the athletes, 01:49:10

25 are those -- are those the actual athletes that 01:49:11

Page 10
1 represent the USOC and the United States of America? 01:49:14

2 A. When you say "represent," we have certain 01:49:19

3 athletes that go to the Olympic Pan American and 01:49:23

4 Paralympic Games. 01:49:28

5 Q. Okay. 01:49:31

6 A. They may call with regard to questions or 01:49:31

7 have issues that they would like to have resolved. 01:49:33

8 Q. All right. Other than the Olympics -- 01:49:35

9 other than the athletes that go to the Olympics and 01:49:37

10 Paralympics and Games, are there other athletes that 01:49:41

11 are members of USOC? 01:49:44

12 A. I believe your question is incorrect. The 01:49:46

13 individuals that I'd mentioned, the Paralympic, Pan 01:49:49

14 American, and Paralympic athletes are not members of 01:49:52

15 the USOC. 01:49:56

16 Q. Okay. You mentioned earlier that there 01:49:57

17 were athletes that were members of the USOC. 01:49:59

18 A. I do not recall saying that -- 01:50:01

19 Q. Maybe my notes are -- 01:50:03

20 A. -- but if I did, it's incorrect. 01:50:04

21 Q. Maybe my notes are incorrect. 01:50:06

22 All right. So, do you deal on a 01:50:07

23 day-to-day basis with organizations and -- and 01:50:09

24 athletes. The athletes you speak of are -- are who? 01:50:14

25 A. Athletes involved in the Olympic, 01:50:20

Page 11
1 Paralympic and Pan American movement -- 01:50:21

2 Q. All right. 01:50:25

3 A. And -- and day-to-day, it may or may not 01:50:25

4 deal with an athlete issue on a day-to-day basis. 01:50:29

5 Q. Okay. Are you familiar with USA 01:50:35

6 Taekwondo? 01:50:42

7 A. I am. 01:50:44

8 Q. How so? 01:50:45

9 A. They're a National Governing Body of the 01:50:45

10 United States Olympic Committee -- or recognized by 01:50:48

11 the United States Olympic Committee. 01:50:51

12 Q. What is a National Governing Body? 01:50:54

13 A. That's a designation that's set out in the 01:50:56

14 Amateur Sports Act. That organization is the 01:50:59

15 governing body for a particular Olympic, Paralympic 01:51:02

16 or Pan American sport. 01:51:06

17 Q. All right. That's the Ted Stevens Act you 01:51:08

18 speak of? 01:51:11

19 A. Yes. 01:51:11

20 Q. Okay. And what's your understanding of 01:51:12

21 the relationship between the USOC and the NGBs? 01:51:13

22 A. They're separate organizations. 01:51:18

23 Q. How so? 01:51:20

24 A. They're incorporated separately. They're 01:51:21

25 managed separately. They're entirely separate 01:51:24

Page 12
1 organizations. 01:51:28

2 Q. Does the USOC have any power or control 01:51:29

3 over the NGBs? 01:51:33

4 A. No. 01:51:35

5 Q. None at all? 01:51:35

6 A. No. 01:51:36

7 Q. Does the USOC have the ability to 01:51:37

8 decertify an NGB? 01:51:42

9 A. Yes. 01:51:44

10 Q. Okay. And if the USOC decertifies an NGB, 01:51:45

11 what are the consequences of that decertification? 01:51:49

12 A. The NGB no longer is a member of the 01:51:51

13 United States Olympic Committee, and it's no longer 01:51:54

14 a National Governing Body for its particular sport. 01:51:58

15 Q. And you heard testimony from Ms. Arrington 01:52:03

16 about an athlete who wants to become an Olympic 01:52:06

17 athlete, the way they do that is they become a 01:52:10

18 member of the NGB, correct? 01:52:14

19 A. That may or not be correct. 01:52:16

20 Q. Okay. 01:52:18

21 A. If -- they -- they would not necessarily 01:52:19

22 have to be a member of the National Governing Body. 01:52:22

23 Q. And why do you say that? 01:52:26

24 A. Because some National Governing Bodies 01:52:27

25 have no individual members. 01:52:30

Page 13
1 Q. For example? 01:52:31

2 A. Basketball. To my knowledge, basketball 01:52:32

3 is a National Governing Body that only has 01:52:36

4 organizational members. 01:52:40

5 Q. What about USA Taekwondo? 01:52:41

6 A. I believe that athletes are members of USA 01:52:45

7 Taekwondo. 01:52:48

8 Q. If a Taekwondo athlete wanted to become 01:52:49

9 an Olympic athlete, he must -- he or she must become 01:52:49

10 a member of that NGB of USA Taekwondo, correct? 01:52:54

11 A. I don't know that that's the case that 01:52:59

12 they must be a member of USA Taekwondo. My 01:53:00

13 understanding is that Taekwondo has a membership 01:53:05

14 category for athletes. 01:53:09

15 Q. If I wanted to find an answer to that 01:53:11

16 question, where would I locate that answer? 01:53:13

17 A. I would ask USA Taekwondo. 01:53:15

18 Q. Okay. So, USOC has the power to decertify 01:53:18

19 the -- the -- the NGB. What other powers does the 01:53:23

20 USOC hold over the NGB? 01:53:27

21 MS. HOLM: Well, he said does- -- there 01:53:32

22 are no powers or control. You could put that word 01:53:33

23 into it. He said the USOC can decertify. 01:53:36

24 Q. (By Mr. Estey) You would -- you would 01:53:41

25 agree with me that the -- that the USOC's ability to 01:53:42

Page 14
1 decertify an NGB is a -- a power it holds over 01:53:45

2 the -- the NGB, correct? 01:53:49

3 A. Under the Ted Stevens Act, United States 01:53:50

4 Olympic Committee has authority to recognize 01:53:53

5 National Governing Bodies, and then it has the 01:53:56

6 authority to take that recognition away. 01:54:00

7 Q. Okay. And that's a better word. We'll 01:54:02

8 use that word, okay? 01:54:04

9 So, the USOC has the authority over the 01:54:05

10 NGBs to decertify them, correct? 01:54:08

11 A. That authority is not set out in the Ted 01:54:12

12 Stevens Olympic and Amateur Sports Act. 01:54:16

13 Q. And I -- I -- I appreciate that. That's 01:54:19

14 not my question, though. 01:54:20

15 It's your understanding that the USOC has 01:54:22

16 the authority to decertify an NGB? 01:54:24

17 A. USOC can take away the recognition of a 01:54:27

18 National Governing Body. 01:54:31

19 Q. Okay. And does the -- does the USOC have 01:54:34

20 the authority to take any other actions against an 01:54:37

21 NGB? 01:54:40

22 A. Any other actions. Funding. We fund 01:54:44

23 certain organ- -- certain National Governing Bodies. 01:54:49

24 Q. All right. Tell me about the funding. 01:54:52

25 What is -- what is -- what role does USOC play in 01:54:53

Page 15
1 the funding of the NGBs? 01:54:56

2 A. They fund National Governing Bodies, and 01:54:58

3 this really is not my area, but for High Performance 01:55:00

4 programs. 01:55:04

5 Q. Okay. And the USOC has the authority to 01:55:04

6 take away that funding from the NGBs, correct? 01:55:07

7 A. Through an agreement, correct. 01:55:10

8 Q. Okay. Any other authorities that you're 01:55:12

9 aware of that the USOC maintains over the -- the 01:55:15

10 NGBs? 01:55:19

11 A. No. 01:55:21

12 Q. Okay. In order to be certified or 01:55:22

13 maintain certified status with the USOC, do the NGBs 01:55:26

14 have to pay any sort of dues? 01:55:32

15 A. Currently, no. 01:55:35

16 Q. You say "currently no." Why are you 01:55:37

17 qualifying that? Is there a plan in the future to 01:55:39

18 require dues? 01:55:42

19 A. At one time, I believe that there were 01:55:42

20 dues for USOC members. My understanding is the USOC 01:55:45

21 no longer collects the dues from members. 01:55:47

22 Q. Are the NGBs required to contribute money 01:55:51

23 towards this SafeSport Center? 01:55:55

24 A. My understanding is that they are. 01:55:58

25 Q. Okay. 01:56:01

Page 16
1 A. When you say required, they are requested 01:56:03

2 to provide money for the SafeSport organization. 01:56:07

3 Q. And if they don't, what are the 01:56:10

4 consequences? 01:56:13

5 A. I suppose they could lose their funding, 01:56:15

6 primarily. 01:56:18

7 Q. Okay. Are the -- are the NGBs required by 01:56:25

8 the USOC to maintain certain types of insurance? 01:56:29

9 A. Yes. 01:56:36

10 Q. All right. And what types of insurance 01:56:36

11 are the NGBs required to maintain? 01:56:38

12 A. I do not know the answer to that question. 01:56:43

13 Q. And if the NGBs do not maintain 01:56:46

14 insurance that the USOC had requested, what are the 01:56:51

15 consequences? 01:56:53

16 A. They're required to maintain certain 01:56:56

17 insurance under an agreement the USOC has with the 01:56:59

18 NGB. 01:57:02

19 The consequences, again, would be that 01:57:03

20 they would lose funding under that agreement. 01:57:06

21 Q. Okay. All right. Who currently is your 01:57:08

22 main contact at USA Taekwondo? 01:57:10

23 A. Keith Ferguson. 01:57:15

24 Q. Okay. And he was -- 01:57:17

25 A. Let me -- let me -- 01:57:18

Page 17
1 Q. Sure. Go ahead. 01:57:19

2 A. -- be more specific. 01:57:20

3 Keith Ferguson is the current CEO or 01:57:21

4 Executive Director of USA Taekwondo. 01:57:26

5 Q. All right. And prior to Mr. Ferguson, who 01:57:31

6 was your main contact? 01:57:33

7 A. I don't know about main contact. It would 01:57:37

8 have been the CEO or Executive Director. 01:57:39

9 Q. All right. Is that generally your -- your 01:57:45

10 main contact with the NGBs; the CEO or the Executive 01:57:46

11 Director? 01:57:52

12 A. Generally, but I think when you say "main 01:57:52

13 contact," it's not that I have main contacts with 01:57:55

14 the National Governing Bodies. 01:57:58

15 Q. Fair enough. 01:58:00

16 Did -- did you -- you know a -- a lady by 01:58:01

17 the name of Ronda Sweet, right? 01:58:03

18 A. I do know Ronda Sweet. 01:58:05

19 Q. Have you met her in person? 01:58:07

20 A. I believe that I have. 01:58:09

21 Q. All right. Why do you believe you have? 01:58:10

22 A. I have a rec- -- recollection that she and 01:58:13

23 I have spoken in person. 01:58:15

24 Q. Okay. And when do you first believe you 01:58:17

25 met -- strike that. 01:58:21

Page 18
1 When do you first believe you communicated 01:58:22

2 with Ms. Sweet? 01:58:23

3 A. Many years ago. 01:58:25

4 Q. When you say "many," are you talking about 01:58:29

5 3, 10, 30? 01:58:31

6 A. 10. 01:58:36

7 Q. Okay. And at the time that you first 01:58:37

8 communicated with Ms. Sweet, did -- did she hold a 01:58:41

9 title within USA Taekwondo? 01:58:44

10 A. I do not believe so. 01:58:48

11 Q. Okay. Do you know if she ever held a 01:58:50

12 title within USA Taekwondo? 01:58:51

13 A. I believe at one time Ms. Sweet was on the 01:58:55

14 Board of Directors. She may have been Chair, but I 01:58:58

15 do not know. 01:59:01

16 Q. How would you describe your current 01:59:04

17 relationship with Ms. Sweet? 01:59:06

18 A. I'm not sure that I have a relationship 01:59:14

19 with Ms. Sweet. She has reached out to me from time 01:59:15

20 to time. 01:59:20

21 Q. All right. Positive, negative view of 01:59:22

22 Ms. Sweet? 01:59:26

23 A. Neutral. 01:59:28

24 Q. And when you and Ms. Sweet communicate, 01:59:34

25 generally, what are the -- what are you -- what are 01:59:37

Page 19
1 you guys talking about? 01:59:39

2 A. Most of my communications with Ms. Sweet 01:59:43

3 have been via email. 01:59:46

4 Q. Okay. And we've got some of those emails 01:59:48

5 here today. 01:59:51

6 She sends you emails when she thinks that 01:59:54

7 there's been misconduct, specifically sexual 01:59:57

8 misconduct between coaches and athletes, right? 02:00:02

9 MS. HOLM: Well, objection. Lack of 02:00:06

10 foundation as to why she sends them and what her 02:00:08

11 thought process is. 02:00:11

12 I don't know how you can answer the 02:00:14

13 question, but if you can, go right ahead. 02:00:16

14 A. Most of my communications via email with 02:00:18

15 Ms. Sweet -- and I don't want you to imply from that 02:00:21

16 that there's been many of them -- they deal with 02:00:24

17 governance issues concerning Taekwondo. USA 02:00:26

18 Taekwondo. 02:00:30

19 Q. Okay. Now, it's my understanding that USA 02:00:31

20 Taekwondo was put on probation by the USOC at some 02:00:33

21 point. Are you familiar with that? 02:00:38

22 A. I am. 02:00:39

23 Q. All right. How so? 02:00:40

24 A. A Section 10 complaint was filed against 02:00:43

25 USA Taekwondo. 02:00:46

Page 20
1 Q. What's a Section 10 complaint? 02:00:48

2 A. Section 10 of the USOC bylaws allows a 02:00:49

3 member of the National Governing Body, or someone 02:00:54

4 who is eligible to become a member of the National 02:00:57

5 Governing Body, to file a complaint with the USOC 02:00:59

6 alleging that that National Governing Body is not 02:01:02

7 fulfilling its requirements under the Ted Stevens 02:01:07

8 Olympic and Amateur Sports Act. 02:01:10

9 Q. Who filed that complaint? 02:01:13

10 A. It was filed by a number of individuals. 02:01:14

11 Q. All right. Can I have their names, 02:01:17

12 please? 02:01:19

13 A. I do not recall all of the names, but one 02:01:20

14 of the individuals was Bruce Harris, and the other 02:01:23

15 individual was -- I believe his first name was 02:01:27

16 Bernard Robinson. 02:01:29

17 So, there were two complaints, to make 02:01:34

18 myself clear. 02:01:36

19 Q. When was the Title 10 complaint filed? 02:01:38

20 A. I believe in -- well, there were two -- 02:01:44

21 two Section 10 complaints filed. I believe they 02:01:48

22 were filed in 2011. 02:01:51

23 Q. All right. And after the complaints were 02:01:55

24 filed, at some point, USOC put USA Taekwondo on 02:01:59

25 probation, right? 02:02:05

Page 21
1 A. Yes. 02:02:07

2 Q. Did you have any role in that 02:02:08

3 decision-making process? 02:02:10

4 A. No. I served as legal counsel to the 02:02:13

5 hearing panel. 02:02:16

6 Q. All right. And who was the hearing panel? 02:02:17

7 A. They were Susanne Lyons, Sarah Conrad, and 02:02:21

8 Glen Merry. 02:02:29

9 Q. And when an NGB like USA Taekwondo is 02:02:35

10 placed on probation by the USOC, what are the 02:02:41

11 consequences of -- of being put on probation? It's? 02:02:45

12 MS. HOLM: Vague and ambiguous as to what 02:02:50

13 you mean by consequences, but if you understand the 02:02:52

14 question. 02:02:56

15 A. Generally speaking, the National Governing 02:03:01

16 Body is given a period of time in which to resolve 02:03:03

17 the compliance issues that the hearing panel found 02:03:08

18 it to be in violation of the requirements under the 02:03:13

19 Act. 02:03:17

20 Q. (By Mr. Estey) And during this time 02:03:18

21 period, are the NGB's rights as an NGB limited in 02:03:20

22 any way? 02:03:31

23 A. Depends on what you mean by "rights." 02:03:37

24 The answer is no. There may be certain 02:03:39

25 requirements that the NGBs must fulfill. 02:03:43

Page 22
1 Q. All right. And what were the requirements 02:03:49

2 the -- the USOT was required to fulfill while on 02:03:50

3 probation? 02:03:54

4 A. It had to undergo -- it had to look at its 02:03:54

5 management. It had to look at its financial 02:03:58

6 pictures. For example, those -- those would be two. 02:04:03

7 Q. There was an issue with a -- a grievance 02:04:09

8 policy, too, right? 02:04:11

9 A. That's correct. 02:04:12

10 Q. And what is a grievance policy? 02:04:13

11 A. A grievance policy -- the -- the Ted 02:04:15

12 Stevens Olympic and Amateur Sports Act requires that 02:04:16

13 each National Governing Body have a grievance 02:04:21

14 procedure in its bylaws. 02:04:23

15 So, the -- the USA Taekwondo was required 02:04:25

16 to look at that grievance policy or procedure. 02:04:27

17 Q. All right. Why were they told to look at 02:04:31

18 that grievance policy and procedure? 02:04:33

19 A. Because they had issues with their 02:04:36

20 grievance process. 02:04:38

21 Q. All right. And what type of issues were 02:04:39

22 they having with their grievance process? 02:04:41

23 A. The allegations of the complaints were 02:04:46

24 that numerous grievances had been filed relating to 02:04:50

25 the Board election, and that those grievances had 02:04:56

Page 23
1 not been processed. 02:05:01

2 Q. Now, that grievance process, that's al- -- 02:05:03

3 that -- that also includes the process that the -- 02:05:04

4 an athlete would pursue if they had a complaint 02:05:09

5 against a coach who was sexually abusing them, 02:05:15

6 correct? 02:05:19

7 A. It could. 02:05:20

8 Q. Okay. And so this -- this Section 10 02:05:23

9 complaint comes in, alleges numerous problems with 02:05:30

10 the USA Taekwondo including the grievance procedure, 02:05:33

11 USOC hears the -- the case. Is it called a case? 02:05:38

12 A. Well, the USOC does not hear -- 02:05:44

13 Q. All right. 02:05:47

14 A. -- anything. 02:05:47

15 Q. All right. Well, Lyons, Conrad and Merry 02:05:47

16 get together and determine that there's going to 02:05:50

17 be -- they're going to put on USAT on probation, 02:05:52

18 right? 02:05:55

19 A. They are the hearing panel. 02:05:56

20 Q. All right. So, the hearing panel 02:05:57

21 convenes, right? 02:06:00

22 A. Yes. 02:06:01

23 Q. And they come to a conclusion that there's 02:06:01

24 a number of issues that need to be addressed within 02:06:04

25 USA Taekwondo, right? 02:06:07

Page 24
1 A. There is a hearing -- 02:06:10

2 Q. Yeah. 02:06:11

3 A. -- and then they would make a 02:06:11

4 determination. 02:06:13

5 Q. Right. 02:06:13

6 And they had the hearing, right? 02:06:13

7 A. They did. 02:06:15

8 Q. And they made a determination, right? 02:06:15

9 A. They did. 02:06:17

10 Q. And one of the determinations they made 02:06:18

11 was that USAT grievance procedure was flawed? 02:06:20

12 A. The -- the decisions of the hearing panel 02:06:31

13 are a matter of public record, so one could look at 02:06:35

14 those decisions to determine exactly what the 02:06:39

15 findings of the hearing panel were. 02:06:42

16 When you say their process was flawed, I 02:06:45

17 believe it was more of an implementation of their 02:06:48

18 procedures rather than the procedures themselves. 02:06:52

19 Q. Okay. So, the procedures may have been 02:06:56

20 okay, they just weren't executing on them correctly? 02:06:57

21 A. Correct. 02:07:01

22 Q. Okay. And as a result of these 02:07:01

23 deficiencies, there was a recommendation by the 02:07:05

24 hearing panel to put USA Taekwondo on probation, 02:07:10

25 right? 02:07:14

Page 25
1 A. Correct. 02:07:14

2 Q. From what -- what date were they -- was 02:07:14

3 USA Taekwondo put on probation? 02:07:17

4 A. I do not recall the specific date. 02:07:29

5 Q. Would have been in 2011, right? 02:07:32

6 A. I believe it was in 2012. 02:07:34

7 Q. Okay. Early, mid, late 2012, do you know? 02:07:37

8 A. I believe the first quarter of 2012. 02:07:46

9 Q. Okay. And then how long did that 02:07:49

10 probation last? 02:07:50

11 A. Six months. 02:07:52

12 Q. All right. And how was it that USAT was 02:07:54

13 able to get off probation? 02:07:58

14 A. They -- there was continuing reports to 02:08:03

15 the hearing panel with regard to their status, and 02:08:09

16 the actions that they had taken in which to resolve 02:08:13

17 these compliance issues. 02:08:17

18 Q. Did USOC put any sort of advisory board in 02:08:20

19 place during this probationary period for USA 02:08:23

20 Taekwondo? 02:08:27

21 A. The hearing panel recommended that there 02:08:28

22 would be an advisory committee. 02:08:30

23 Q. Why did the hearing panel recommend an 02:08:33

24 advisory committee? 02:08:36

25 MS. HOLM: Well, the only thing I'm going 02:08:38

Page 26
1 to have to say in this regard is to the extent you 02:08:39

2 can communicate that, and not violate any 02:08:43

3 attorney-client communications that would have 02:08:47

4 occurred as a result of you being legal counsel to 02:08:49

5 the panel. 02:08:53

6 A. I guess I don't believe that I can answer 02:09:00

7 that question. 02:09:02

8 Q. (By Mr. Estey) All right. What was the 02:09:02

9 role of the advisory committee that the USOC put in 02:09:05

10 place on behalf of USA Taekwondo? 02:09:09

11 A. To provide guidance to Taekwondo to deal 02:09:13

12 with the compliance issues. 02:09:17

13 Q. Anything else? 02:09:19

14 A. That would be the role. 02:09:22

15 Q. Any other role? 02:09:25

16 A. No. Not that I'm aware of. 02:09:27

17 Q. And the advisory committee consisted of 02:09:29

18 who? 02:09:32

19 A. The advisory committee consisted of five 02:09:35

20 individuals. 02:09:38

21 Q. Can I have their names? 02:09:41

22 A. I can't recall the individuals that sat on 02:09:46

23 the advisory committee except for one person which 02:09:50

24 was Glenn Merry. 02:09:54

25 Q. And where is Mr. Merry now? 02:09:56

Page 27
1 A. I believe he lives in New Jersey. 02:09:59

2 Q. All right. Were these advisory personnel, 02:10:04

3 were they -- were they paid for their -- their 02:10:08

4 service? 02:10:10

5 A. They were not. 02:10:11

6 Q. Okay. And you believe the advisory 02:10:13

7 committee was in place for the six months you 02:10:16

8 believe the USAT was on probation? 02:10:20

9 A. Yes. I -- they were in existence for 02:10:27

10 longer than six months, since the probation was 02:10:30

11 extended. 02:10:33

12 Q. Oh. Let's talk about that. Why -- when 02:10:34

13 was probation extended? To what time period? 02:10:36

14 A. It was extended after the six-month period 02:10:40

15 of time. 02:10:43

16 Q. In total, how long was USA Taekwondo on 02:10:44

17 probation? 02:10:49

18 A. That, I can't give you an accurate 02:10:50

19 figure. It was extended -- my recollection is it 02:10:55

20 was extended twice. 02:11:00

21 Q. Do you know why it was extended twice? 02:11:01

22 A. To allow Taekwondo to become -- or to come 02:11:04

23 into compliance. 02:11:07

24 Q. Okay. And so during this -- this -- I 02:11:10

25 mean, if it got extended twice. Six times three to 02:11:11

Page 28
1 me is 18. Does that sound about right? 02:11:15

2 A. Yes. 02:11:19

3 Q. So, 18 months. That would have taken us 02:11:20

4 into the middle of 2014, is that right? 02:11:26

5 A. No. 02:11:29

6 Q. Okay. How am I wrong? 02:11:30

7 MS. HOLM: Can you tell him approximately 02:11:32

8 when it was that they were no longer on probation. 02:11:33

9 That might be easier. 02:11:36

10 MR. ESTEY: Yeah, that would be easier. I 02:11:37

11 think in the middle of 2013. I am right. I'm 02:11:37

12 wrong, so... 02:11:41

13 MS. HOLM: Later than that. 02:11:41

14 MR. ESTEY: All right. 02:11:41

15 Q. (By Mr. Estey) Walk me through the dates, 02:11:41

16 please. 02:11:43

17 A. My recollection is that USA Taekwondo came 02:11:44

18 off probation on October 10th of 2013. 02:11:47

19 Q. Okay. And during this time period, did 02:11:54

20 USA Taekwondo have its own Board of Directors? 02:11:59

21 A. It did. 02:12:03

22 Q. All right. And who was the -- who was 02:12:04

23 running USA Taekwondo during this time period? 02:12:07

24 Mr. Harris? 02:12:13

25 A. Bruce Harris was CEO, Executive Director, 02:12:15

Page 29
1 I believe, for part of the time frame. 02:12:20

2 Q. Okay. And was there another person that 02:12:26

3 was the CEO or Executive Director? 02:12:28

4 A. My recollection is that, prior to 02:12:31

5 Mr. Harris, Eric Parthen -- 02:12:33

6 Q. All right. 02:12:36

7 A. -- was CEO. 02:12:36

8 Q. Now, you're not the attorney for USA 02:12:40

9 Taekwondo, right? 02:12:42

10 A. I am not. 02:12:43

11 Q. Okay. So, did you have any communications 02:12:44

12 with Harris or -- or Parthen during the time of this 02:12:46

13 probationary period? 02:12:49

14 A. I don't recollect. 02:12:53

15 Q. Okay. You would agree with me that the 02:12:59

16 safety of our athletes is the number one priority 02:13:01

17 for the U.S. Olympic Committee? 02:13:06

18 A. No. I believe that SafeSport is an issue 02:13:13

19 that's of concern to the United States Olympic 02:13:19

20 Committee and to society as a whole. 02:13:24

21 Q. All right. But you don't agree with me 02:13:28

22 that the safety of our athletes is the USOC's number 02:13:30

23 one priority? 02:13:33

24 A. It's a -- it -- it's a concern to the 02:13:35

25 USOC. 02:13:37

Page 30
1 The USOC has a lot of priorities, if you 02:13:40

2 will. Chief among them is sending athletes to the 02:13:43

3 Olympic, Pan American, and Paralympic games, and 02:13:47

4 doing well at those games. 02:13:51

5 Q. Yeah, but you want to protect your 02:13:52

6 athletes from being sexually abused. That's a top 02:13:54

7 priority, right, sir? 02:13:58

8 A. The USOC does not have athletes. 02:13:59

9 Q. Okay. Walk me through that. You -- you 02:14:02

10 send athletes to the Olympics, but they're not your 02:14:03

11 athletes? 02:14:07

12 A. That's correct. 02:14:08

13 Q. Okay. What -- I'm -- I'm obviously 02:14:09

14 ignorant in that area, so why -- why is it they're 02:14:10

15 not your athletes? 02:14:12

16 A. They're nominated by the National 02:14:15

17 Governing Bodies to the USOC. The USOC then enters 02:14:16

18 those athletes into the Olympic, Paralympic, or Pan 02:14:22

19 American games. 02:14:27

20 Q. Okay. And so is the USOC then relying 02:14:28

21 upon the NGBs to make sure our athletes are safe? 02:14:32

22 MS. HOLM: Well, it's an overbroad 02:14:43

23 question, and it calls for some speculation as to 02:14:44

24 the entirety of the US -- USOC. 02:14:47

25 If you can answer the question the way 02:14:49

Page 31
1 it's been phrased. 02:14:51

2 A. Do you want to repeat it? 02:14:51

3 MR. ESTEY: You can... 02:14:53

4 (Last question read back.) 02:14:53

5 A. That would be one of the obligations of a 02:15:04

6 National Governing Body; to insure that all 02:15:05

7 participants, all of its members, have a safe 02:15:10

8 environment. 02:15:13

9 Q. And when I say safe, I'm -- I'm -- I'm 02:15:14

10 including an athlete, should we say, from -- from 02:15:15

11 being sexually abused by their coach. You 02:15:22

12 understood that when I'm talking about keeping the 02:15:25

13 athletes safe? 02:15:27

14 A. Yes. 02:15:31

15 Q. Okay. And how does the USOC then assess 02:15:32

16 the NGBs of keeping our athletes safe from being 02:15:37

17 sexually abused? 02:15:42

18 A. We're -- we're a different organization 02:15:49

19 than the National Governing Bodies. We provide 02:15:51

20 funding to our National Governing Bodies. 02:15:55

21 As you know, the USOC has now endeavored 02:15:58

22 to have a SafeSport program. 02:16:05

23 Q. And the SafeSport program is designed to 02:16:09

24 assist the NGBs in keeping our athletes safe from 02:16:11

25 being sexually abused by the coaches, correct? 02:16:16

Page 32
1 A. Would you repeat that question? 02:16:20

2 MR. ESTEY: Sure. 02:16:21

3 Could you read it back, please. 02:16:21

4 (Last question read back.) 02:16:32

5 A. Depends on what do you mean by "assist"? 02:16:38

6 It's a -- a program that's designed to provide a 02:16:45

7 SafeSport environment for athletes that are 02:16:51

8 participating under the membership or under the 02:16:56

9 competition guidelines of a National Governing Body. 02:17:00

10 Q. All right. And the NGBs are required to 02:17:04

11 maintain a form of the SafeSport initiative in order 02:17:06

12 to be recognized as an NGB by the USOC, correct? 02:17:11

13 A. I don't know that that's correct. 02:17:17

14 Q. Why don't you know that? You heard 02:17:18

15 Ms. Arrington -- 02:17:20

16 MS. HOLM: It's a little bit argumentative 02:17:21

17 of saying why don't you know, but do you want to 02:17:21

18 start the question over again. 02:17:21

19 MR. ESTEY: I'll try it again. I'll try 02:17:25

20 it again. 02:17:26

21 Q. (By Mr. Estey) You heard Ms. Arrington 02:17:27

22 talk about that issue, right? 02:17:30

23 A. I did. 02:17:31

24 Q. All right. And so it was her 02:17:31

25 understanding that the NGBs had to have implemented 02:17:32

Page 33
1 some form of SafeSport by the end of 2013, right? 02:17:36

2 A. That's correct. 02:17:40

3 Q. Okay. And if they did not implement some 02:17:41

4 form of Safebo -- SafeSport by 2013, were there any 02:17:46

5 consequences that they could suffer from the USOC? 02:17:50

6 A. I believe Ms. Arrington said that they 02:17:53

7 could lose their funding. 02:17:56

8 Q. Okay. And you agree with that answer, 02:17:59

9 right? 02:18:01

10 A. Yes. 02:18:02

11 Q. Okay. Now, prior to 2013, before the 02:18:03

12 SafeSport initiative was required to be implemented, 02:18:08

13 what type of policies, procedures, or materials did 02:18:13

14 USOC provide the NGBs to assist them in keeping our 02:18:19

15 athletes safe from being sexually abused? 02:18:27

16 MS. HOLM: Well, it may call for a 02:18:34

17 speculation, lack of foundation as to this witness' 02:18:34

18 knowledge. You know, it's compound the way it's 02:18:38

19 phrased. It might be easier to break it down into 02:18:40

20 different categories. 02:18:45

21 Q. (By Mr. Estey) Do you understand the 02:18:46

22 question? 02:18:47

23 A. It's -- I'm not sure that I can answer 02:18:50

24 that question. That's not really my area. 02:18:52

25 Q. Okay. What -- all right. Fair enough. 02:18:55

Page 34
1 Do you have any background or training in 02:19:12

2 the area of sex abuse? 02:19:15

3 A. No. 02:19:17

4 Q. Okay. Are you familiar with a -- a -- a 02:19:19

5 lady by the name of Mandy Meloon? 02:19:32

6 A. I know of Mandy Meloon. 02:19:35

7 Q. All right. How do you know of Mandy 02:19:37

8 Meloon? 02:19:40

9 A. I've heard the name. I know that she 02:19:44

10 filed a Section 9 complaint with regard to our 02:19:46

11 participation rights. 02:19:48

12 Q. Okay. And you were employed with the USOC 02:19:51

13 at the time? 02:19:54

14 A. At what time? 02:19:55

15 Q. At the time she filed that complaint? 02:19:56

16 A. Yes. 02:19:59

17 Q. Okay. And once she filed that complaint, 02:20:00

18 was -- was there ultimately a hearing? 02:20:04

19 A. There was. 02:20:07

20 Q. Okay. And did you play any role in that 02:20:08

21 hearing? 02:20:10

22 A. The USOC was not a party to the Section 9 02:20:11

23 complaint. 02:20:16

24 Q. Okay. And so you didn't play any role in 02:20:17

25 that? 02:20:22

Page 35
1 MS. HOLM: Vague and ambiguous. What do 02:20:22

2 you mean by "role"? 02:20:24

3 Q. (By Mr. Estey) Did you -- I mean, did you 02:20:25

4 have any -- you WERE aware that Mandy Meloon filed a 02:20:27

5 complaint, right? 02:20:29

6 A. Yes. 02:20:32

7 Q. At the time, right? 02:20:32

8 A. Yes. 02:20:33

9 Q. And how did you become aware of that? 02:20:33

10 A. Section 9 complaints are filed with the 02:20:35

11 United States Olympic Committee. 02:20:37

12 Q. Then do you have an understanding as to 02:20:41

13 why Section 9 complaints are filed with the USOC 02:20:43

14 rather than the NGBs? 02:20:46

15 A. It's set out -- it's set out in the USOC 02:20:49

16 bylaws that Section 9 complaints should be filed 02:20:53

17 with the United States Olympic Committee. 02:20:56

18 They could also be filed with the National 02:20:59

19 Governing Board. 02:21:00

20 A complaint with regard to partici- -- 02:21:02

21 participation rights could also be filed with the 02:21:04

22 National Governing Body. 02:21:07

23 Q. All right. So, in Meloon's case, she 02:21:09

24 filed with the USOC, right? 02:21:11

25 A. Correct. 02:21:13

Page 36
1 Q. Sometime in 2007, is that right? 02:21:14

2 A. That's my understanding. 02:21:16

3 Q. Okay. And what do you base that 02:21:17

4 understanding on? 02:21:18

5 A. The -- my recollection of the filing of 02:21:22

6 the complaint and the decision that was issued by 02:21:24

7 the arbitrator. 02:21:27

8 Q. Okay. And you've read that decision, 02:21:28

9 right? 02:21:29

10 A. I have. 02:21:30

11 Q. Okay. Did you monitor -- I mean -- let me 02:21:32

12 ask you this: Did you appear at the hearing? 02:21:38

13 A. I had no formal appearance, no. 02:21:42

14 Q. And I understand that -- were you present 02:21:45

15 at the hearing? How's that? 02:21:49

16 A. My recollection is that the hearing was a 02:21:51

17 telephonic hearing. 02:21:53

18 Q. And were you present on the telephone for 02:21:55

19 that hearing? 02:21:57

20 A. I may have been present for all or part of 02:21:57

21 it. I don't recall. 02:22:00

22 Q. And why would you have been present for 02:22:02

23 all or part of it? 02:22:05

24 A. On Section 9 complaints, in general, they 02:22:09

25 invoke participation rights. And it's not uncommon 02:22:13

Page 37
1 for me to listen into those hearings to see what the 02:22:18

2 issues are, to gain some knowledge of understanding 02:22:22

3 of the issues, and then be able to speak with the 02:22:26

4 National Governing Bodies of the way -- for example, 02:22:30

5 ways that they can improve their selection process. 02:22:34

6 Q. How many Section 9 hearings have you 02:22:37

7 either personally attended or listened on the 02:22:39

8 telephone? 02:22:41

9 A. How many? I don't recall. 02:22:44

10 Q. More than five? 02:22:47

11 A. I'd say yes. 02:22:49

12 Q. More than 10? 02:22:49

13 A. Probably. 02:22:52

14 Q. More than 20? 02:22:52

15 A. I don't know if more than 20 or not. 02:22:57

16 Q. Okay. Somewhere between 10 and 20? 02:22:59

17 A. That's a guess. 02:23:01

18 Q. I don't want you to guess. But I'm 02:23:02

19 entitled to your best estimate. 02:23:04

20 A. Best estimate, 10 to 20. 02:23:06

21 Q. Okay. And how many of these Section 9 02:23:09

22 complaints involve, in whole or in part, allegations 02:23:11

23 of -- of sexual abuse? 02:23:17

24 A. Very few. 02:23:24

25 Q. And you said very few. Are we talking 02:23:26

Page 38
1 about three or less? 02:23:29

2 A. I don't really recall how many could have 02:23:31

3 involved what we'll call SafeSport issues. I just 02:23:34

4 don't recall. 02:23:39

5 Q. Well, Mandy Meloon, part of her complaint 02:23:41

6 was that she was being sexually abused by -- by Jean 02:23:44

7 Lopez, right? 02:23:48

8 A. I don't think that's the case. 02:23:50

9 Q. What do you -- why don't you think that's 02:23:51

10 the case? 02:23:52

11 A. From reading the decision, the issue was 02:23:52

12 whether or not she had violated USA Taekwondo's Code 02:23:54

13 of Conduct. 02:23:59

14 Q. And that's the main part of the decision. 02:24:03

15 I agree with you. But were there any allegations of 02:24:05

16 inappropriate sexual misconduct between Lopez and 02:24:08

17 Meloon? 02:24:12

18 MS. HOLM: If you know. 02:24:14

19 A. I don't -- I don't recall what -- we were 02:24:15

20 not a party to that matter. I don't recall much 02:24:18

21 about that hearing, if anything. 02:24:23

22 Q. (By Mr. Estey) But you got a copy of the 02:24:26

23 arbitrator's decision, right? 02:24:28

24 A. Yes. 02:24:30

25 Q. All right. And how did you go about 02:24:30

Page 39
1 getting a copy of the arbitrator's decision? 02:24:31

2 A. Section 9 complaints, the decisions are 02:24:34

3 provided to the General Counsel's office of the 02:24:37

4 United States Olympic Committee. 02:24:39

5 Q. Okay. And once you got the opinion -- 02:24:42

6 and -- and you read it, right? 02:24:43

7 A. Whether or not I read it at the time, I 02:24:46

8 can't recall. 02:24:48

9 Q. All right. At some point you read it, 02:24:48

10 right? 02:24:50

11 A. I've read it recently. 02:24:51

12 Q. Do you recall reading it in or about 2007? 02:24:53

13 A. Most likely, I took a look at it, but I 02:24:56

14 don't recall. 02:24:59

15 Q. All right. Let's -- 02:25:00

16 MR. ESTEY: What's next in order? 02:25:02

17 COURT REPORTER: You still have 17 if you 02:25:17

18 want to do that. 02:25:17

19 MR. ESTEY: No. I got 17. 02:25:17

20 What's that. 02:25:17

21 MS. HOLM: Nine -- 20? I thought it was 02:25:17

22 19. 02:25:17

23 MR. ESTEY: Yeah. 02:25:17

24 No. We're on the right here. We'll -- 02:25:20

25 we'll go on to 20. 02:25:20

Page 40
1 (Plaintiffs' Deposition Exhibit 20 was 02:25:20

2 identified.) 02:25:20

3 Q. (By Mr. Estey) I'm going to show marked 02:25:20

4 Exhibit 20, and then tell me if you've ever seen 02:25:23

5 this document before. 02:25:26

6 MR. OKAMURA: Is there one more? I'm 02:25:48

7 sorry. 02:25:51

8 MS. HOLM: Oh, I'm sorry. Yeah. I'm 02:25:51

9 marking these and reading them all and hoarding 02:25:52

10 them. Sorry. 02:25:55

11 MR. OKAMURA: Thank you. 02:25:56

12 A. I have -- I have seen this before. 02:25:58

13 Q. (By Mr. Estey) Okay. And -- and you saw 02:26:00

14 it somewhere in -- in sometime back in 2007, right? 02:26:01

15 A. I believe so. I -- I can't remember what 02:26:05

16 I read in 2007. 02:26:08

17 Q. I -- I appreciate that. But when you read 02:26:11

18 it, and the arbitrator states that "Ms. Meloon's 02:26:13

19 core message went to the protection of the young 02:26:17

20 girls in the Olympic movement who could be exposed 02:26:22

21 to situations that are inappropriate and potentially 02:26:26

22 damaging," when you read that sentence, did you have 02:26:30

23 any concerns? 02:26:36

24 MS. HOLM: Again, don't guess. Please 02:26:40

25 tell Mr. Estey what you recall your thought process 02:26:43

Page 41
1 was, if any. 02:26:47

2 A. Well, let me say again, the USOC was not a 02:26:49

3 party to this arbitration. We did not present any 02:26:54

4 evidence. We did not testify at this arbitration. 02:26:57

5 And as to what information the arbitrator 02:27:00

6 based -- based its sentence on, I don't know. 02:27:04

7 Q. (By Mr. Estey) Well, USOC is part of the 02:27:10

8 Olympic movement, right? 02:27:13

9 A. We're the United States Olympic Committee. 02:27:15

10 Q. All right. That's part of the Olympic 02:27:18

11 movement, right? 02:27:21

12 A. Yes. 02:27:22

13 Q. Okay. And so the arbitrator is addressing 02:27:22

14 this sentence to -- to you; USOC, right? 02:27:24

15 A. And United States Taekwondo. 02:27:26

16 Q. Right. 02:27:28

17 And he's saying that there are situations 02:27:29

18 that our athletes can be exposed to that are 02:27:30

19 inappropriate and potentially damaging. 02:27:35

20 Did you have an understanding as to what 02:27:39

21 he was referring to there? 02:27:40

22 A. Like I say, we were not a party to this 02:27:45

23 arbitration. I don't know. You'd have to ask the 02:27:48

24 arbitrator as to what he was referring to. 02:27:52

25 Q. All right. So, did you go -- did you try 02:27:55

Page 42
1 to then go figure out what the arbitrator was trying 02:27:58

2 to say in this -- this first sentence of the fourth 02:28:03

3 paragraph on Page 3 of Exhibit 20? 02:28:06

4 A. I do not believe that I ever spoke with 02:28:08

5 the arbitrator about his decision. 02:28:10

6 Q. Did you speak to anyone about what the 02:28:12

7 arbitrator was trying to tell the USOC and the 02:28:14

8 Olympic movement with this first sentence of the 02:28:19

9 fourth paragraph on Page 3? 02:28:21

10 A. Did I speak with anyone about this? 02:28:24

11 Q. Yes. 02:28:25

12 A. I have no recollections of that. 02:28:25

13 Q. All right. The arbitrator then says, "One 02:28:29

14 would hope that this message is not lost and the 02:28:32

15 young children in Olympic movement are properly 02:28:35

16 supervised, protected and educated." 02:28:38

17 Did you have an understanding as to what 02:28:41

18 the arbitrator was -- was saying in that sentence? 02:28:42

19 A. I don't know what the arbitrator used as 02:28:46

20 evidence to base this sentence on. 02:28:48

21 Q. Did you ever go to try to figure out what 02:28:50

22 the arbitrator was basing this sentence on? 02:28:52

23 A. I have no recollection of doing that. I 02:28:57

24 don't -- I don't recall. 02:29:01

25 Q. Do you know if anyone at the USOC tried to 02:29:01

Page 43
1 determine what the basis for this statement from the 02:29:06

2 arbitrator about young children and the Olympic 02:29:09

3 movement and the requirement they be supervised, 02:29:14

4 protected and educated? 02:29:18

5 A. I don't know. 02:29:21

6 MR. ESTEY: Yeah. I'm not -- I'm -- I'm 02:29:21

7 getting there. That's all right. 02:29:21

8 Q. (By Mr. Estey) Well, when you read it, 02:29:25

9 the arbitrator is saying that one would hope the 02:29:37

10 message is not lost. And you didn't want to -- 02:29:40

11 as -- as Assistant General Counsel, you didn't want 02:29:48

12 to find out what message the arbitrator was talking 02:29:49

13 about? 02:29:53

14 MS. HOLM: Objection. It's argumentative 02:29:54

15 as phrased, misstates his testimony, and I'll 02:29:56

16 instruct him not to answer that question as phrased. 02:29:58

17 MR. ESTEY: And based upon? 02:30:02

18 MS. HOLM: The two objections I just 02:30:04

19 voiced. 02:30:05

20 MR. ESTEY: All right. That's not a 02:30:07

21 basis, again, Peggy, but I'll try to see if I can 02:30:08

22 rephrase it. 02:30:11

23 Q. (By Mr. Estey) The arbitrator's trying to 02:30:12

24 send a message to the USOC here. Do you agree with 02:30:15

25 me? 02:30:19

Page 44
1 A. And the United States -- and -- and USA 02:30:19

2 Taekwondo. 02:30:20

3 Q. Okay. And you, as General -- you as 02:30:23

4 Assistant General Counsel, when you read that, that 02:30:25

5 he's trying to send a message, and you didn't 02:30:28

6 understand the message, is that correct? 02:30:31

7 A. I said that I didn't -- I didn't know what 02:30:33

8 the arbitrator based his -- this paragraph on. 02:30:35

9 Q. All right. So, you didn't understand what 02:30:40

10 the message was? 02:30:41

11 MS. HOLM: Well, it states -- 02:30:42

12 A. Well, the message is what is stated in the 02:30:43

13 decision. 02:30:45

14 Q. (By Mr. Estey) Well, he's saying that 02:30:46

15 there's -- he's concerned that the -- the girls are 02:30:47

16 not properly -- strike that. 02:30:50

17 He's concerned that the athletes are not 02:30:50

18 properly supervised, protected and educated, 02:30:53

19 correct? 02:30:54

20 A. That's what the decision says. 02:30:56

21 Q. Yeah. All right. 02:30:57

22 And so when you read that, did you look 02:30:58

23 into whether or not our athletes were properly 02:31:02

24 supervised, protected and educated? 02:31:05

25 A. Whether or not all athletes are? 02:31:11

Page 45
1 Q. Yes. 02:31:13

2 A. The USOC does not have athletes. 02:31:14

3 Q. Did you look into the fact that -- to 02:31:20

4 whether or not the athletes who are members of the 02:31:24

5 U.S. -- of the NGBs were properly supervised, 02:31:26

6 protected and educated? 02:31:29

7 A. Did I personally? I don't recall having 02:31:30

8 done that. 02:31:33

9 Q. Did you ask someone else to -- to look 02:31:34

10 into that? 02:31:36

11 A. I don't recall. 02:31:37

12 Q. How many arbitrators' opinions have you 02:31:38

13 seen where the arbitrator is trying to send a 02:31:43

14 message to the USOC and the U.S. -- and the NGBs? 02:31:47

15 A. I would say this is -- well, first of all, 02:31:54

16 you indicated the arbitrator trying to send a 02:32:05

17 message to the USOC. I don't know that that's the 02:32:10

18 case. 02:32:14

19 I'm not even sure that when the arbitrator 02:32:14

20 put USOC in here, he doesn't mean USA Taekwondo. He 02:32:16

21 may confused the two. 02:32:22

22 But this is not -- in answer to your 02:32:23

23 question, I don't recall other arbitrator decisions 02:32:25

24 having language like this in them. 02:32:30

25 The most of Section 9 case deal with 02:32:33

Page 46
1 participation issues, which is what this case dealt 02:32:35

2 with as well. 02:32:40

3 Q. Yeah. Well, the arbitrator understood the 02:32:40

4 difference between USOC and USOT, though, because if 02:32:43

5 you look at the -- the Paragraph 3, he distinguishes 02:32:48

6 the two. 02:32:50

7 He says, "As stated, at the conclusion of 02:32:50

8 the final hearing, this arbitrator hopes that the 02:32:53

9 USOC and USAT do not abandon Ms. Meloon as a result 02:32:55

10 of her recent actions." 02:33:01

11 A. He may have understood that there's two 02:33:03

12 different organizations. I'm not sure that he 02:33:06

13 understood that the USOC has no athletes; that these 02:33:08

14 athletes are members of National Governing Bodies of 02:33:09

15 USA Taekwondo. 02:33:09

16 Q. All right. And he goes on to say, "She 02:33:14

17 was, in essence, raised by the USOC, and is a 02:33:17

18 product of their system." 02:33:20

19 "Ms. Meloon is a bright, well-spoken and 02:33:23

20 very capable individual, and when she decides that 02:33:26

21 she no longer wishes to compete, this arbitrator 02:33:31

22 hopes the USOC and the USAT aids in her transition 02:33:35

23 to real life. 02:33:43

24 And you read that paragraph the first time 02:33:45

25 you -- when you -- when you got this decision, 02:33:48

Page 47
1 right? 02:33:49

2 A. I assume so, yes. 02:33:51

3 Q. Do you know if the USOC assisted 02:33:55

4 Ms. Meloon in her transition into real life after 02:33:59

5 this hearing? 02:34:03

6 A. I don't -- I don't recall if any 02:34:05

7 assistance was given to Ms. Meloon by either the 02:34:06

8 USOC or the USA Taekwondo. 02:34:10

9 Q. Where is Miss Meloon now, if you know? 02:34:15

10 A. I don't know. 02:34:18

11 Q. Do you understand that she's is prison? 02:34:18

12 A. I did not know that. 02:34:21

13 Q. If I wanted to find out if -- if -- if the 02:34:24

14 USOC assisted Ms. Meloon in her transition to real 02:34:27

15 life, who -- who would know that information? Who 02:34:32

16 would have -- have that information? 02:34:34

17 MS. HOLM: Well, it may call for some 02:34:35

18 speculation, but -- 02:34:35

19 Q. (By Mr. Estey) If you know. 02:34:40

20 A. I don't know. 02:34:42

21 Q. Okay. All right. Going back to the -- 02:34:43

22 the fourth paragraph of Page 3 of Exhibit 20, it 02:34:49

23 says, "One would hope that the USOC takes a serious 02:34:53

24 look at the level of social interaction between its 02:34:57

25 coaches and athletes, and underage drinking by its 02:35:01

Page 48
1 athletes. Do you see that? 02:35:04

2 A. I do. 02:35:08

3 Q. All right. And you understood that to 02:35:09

4 mean -- to mean that the arbitrator was concerned 02:35:13

5 about the level of social interaction between 02:35:16

6 coaches and athletes and underage drinking by 02:35:21

7 athletes, right? 02:35:23

8 A. Well, let's examine that sentence for -- 02:35:25

9 for -- for a bit. 02:35:26

10 The arbitrator said he hopes that the USOC 02:35:28

11 takes a serious look at the level of social 02:35:32

12 interaction between its coaches and athletes. 02:35:34

13 Q. Yeah. 02:35:37

14 A. We do not have coaches and athletes. The 02:35:37

15 National Governing Bodies do, but not the USOC. 02:35:40

16 Q. Fair enough. 02:35:45

17 Have you read that sentence and -- and 02:35:46

18 he's concerned, the arbitrator is concerned about 02:35:52

19 the level of social interaction between coaches and 02:35:54

20 athletes' underage drinking, right? 02:35:59

21 A. That's what the decision says. 02:36:01

22 Q. All right. And did the USOC take a 02:36:03

23 serious look at these issues after reading this 02:36:06

24 opinion? 02:36:11

25 A. The USOC is concerned about SafeSport 02:36:11

Page 49
1 issues, and that's why, since 2007 up through the 02:36:15

2 current date, the USOC has implemented SafeSport 02:36:20

3 policies. 02:36:24

4 Q. Well, SafeSport didn't take effect until 02:36:26

5 2013, right? 02:36:30

6 A. That's -- I'm not sure that's accurate. 02:36:33

7 The USOC started looking at SafeSport long before 02:36:37

8 2013. 02:36:44

9 Q. It -- it -- it was not required to be 02:36:44

10 implemented by the NGBs until 2013, right? 02:36:47

11 A. The SafeSport policy was not required to 02:36:52

12 be implemented until that time. 02:36:54

13 Q. Right. Okay. 02:36:56

14 So, from 2007, when this opinion came out, 02:36:56

15 'til -- 'til 2013, what was USOC doing to prevent 02:37:00

16 underage drinking by its athletes? 02:37:12

17 MS. HOLM: Well, it's argumentative as 02:37:16

18 phrased. When you says "its athletes," in light of 02:37:16

19 this witness' testimony, but you can answer the 02:37:18

20 question if you can. 02:37:22

21 A. Again, we don't have athletes. The USOC 02:37:23

22 does have programs to assist athletes and its had 02:37:27

23 those programs for some time. We provide -- there's 02:37:31

24 an insurance program for athletes. There's a jobs 02:37:34

25 program for athletes. We currently have an 02:37:38

Page 50
1 education program for athletes. We've worked with 02:37:41

2 certain states that have tuition benefits for 02:37:42

3 athletes. 02:37:48

4 So, the USOC is concerned about SafeSport 02:37:49

5 issues, not only among its athlete population, but 02:37:56

6 all participants in the Olympic, Paralympic and Pan 02:37:58

7 American movement. 02:38:02

8 Q. My question is little bit more direct. 02:38:03

9 From '07 'til -- 'till 2013, when 02:38:06

10 SafeSport was required, what did the USOC do to 02:38:06

11 prevent sexual misconduct between coaches and 02:38:16

12 athletes, and underage drinking by -- by -- by 02:38:20

13 athletes? 02:38:24

14 MS. HOLM: It may call for speculation, 02:38:25

15 but if you know, you could answer the question. 02:38:27

16 A. These athletes are athletes of National 02:38:32

17 Governing Bodies. So, National Governing Bodies may 02:38:35

18 have had programs -- SafeSport programs for its 02:38:40

19 participants. 02:38:43

20 MR. ESTEY: Can I have my question read 02:38:43

21 back, please. 02:38:43

22 (Last question read back.) 02:39:26

23 MR. ESTEY: I -- I can reask it. 02:39:26

24 Q. (By Mr. Estey) All right. After 02:39:39

25 receiving this arbitrator's award -- decision in -- 02:39:40

Page 51
1 in -- in '07, and from '07 to the time that 02:39:43

2 SafeSport was mandated in 2013, what did the USOC do 02:39:46

3 to assist in the prevention of sexual misconduct 02:39:52

4 between coaches and athletes, and underage drinking 02:39:57

5 by the athletes? 02:40:02

6 MS. HOLM: And, again, my objection would 02:40:03

7 be lack of foundation, may call for speculation, but 02:40:05

8 if you could answer the question, go right ahead. 02:40:08

9 A. There may have been programs that the USOC 02:40:11

10 had. There -- there may have been discussions with 02:40:17

11 National Governing Bodies, but I am not aware of 02:40:18

12 those specifics. 02:40:21

13 Q. (By Mr. Estey) All right. Who would be 02:40:22

14 aware of those specifics? 02:40:22

15 A. Malia Arrington. 02:40:25

16 Q. Well, she wasn't around in '07. 02:40:28

17 A. That's correct. 02:40:30

18 Q. So, from '07 'til the time Arrington came 02:40:31

19 aboard in 2011, who would be the person that I can 02:40:34

20 talk to who would know what steps USOC took to 02:40:38

21 assist in the prevention of sexual misconduct 02:40:44

22 between coaches and athletes, and underage drinking 02:40:47

23 by the athletes? 02:40:50

24 A. I don't know who that person would be. 02:40:53

25 Q. Was there anyone designated by the USOC to 02:40:56

Page 52
1 operate in that role during the time period 2007 to 02:41:02

2 2011? 02:41:07

3 MS. HOLM: Again, may call for 02:41:08

4 speculation, lack of foundation. 02:41:09

5 If you know. 02:41:11

6 A. Was there anyone at the USOC designated to 02:41:11

7 speak with National Governing Bodies with regard to 02:41:15

8 SafeSport issues? 02:41:18

9 Q. (By Mr. Estey) Well, SafeSport didn't -- 02:41:19

10 wasn't around in '07, was it? 02:41:20

11 A. So maybe you should ask your question 02:41:22

12 again then. 02:41:25

13 Q. Yeah. 02:41:25

14 From 2007 to 2011, there was no SafeSport, 02:41:26

15 do you agree? 02:41:30

16 A. The USOC has always been concerned with 02:41:32

17 the safety of participants in the Olympic, 02:41:35

18 Paralympic and Pan American Movement. 02:41:40

19 Q. All right. The question is, '07 to 2011, 02:41:43

20 there was no SafeSport initiative, correct? 02:41:47

21 MS. HOLM: You mean, specifically there 02:41:52

22 was no SafeSport initiative, as we're talking about 02:41:53

23 that -- that title. 02:41:57

24 MR. ESTEY: Correct. 02:41:58

25 A. I don't think that's correct. I believe 02:42:01

Page 53
1 that, in 2010, there was a -- a -- there was a group 02:42:03

2 of individuals that were looking at the SafeSport 02:42:11

3 issues. 02:42:13

4 Q. (By Mr. Estey) All right. But it had not 02:42:14

5 been implemented yet, right? 02:42:15

6 A. That had not, to my knowledge. 02:42:18

7 Q. Okay. And so from 2007 to 2011, what was 02:42:20

8 the USOC doing to prevent sexual misconduct between 02:42:24

9 coaches and athletes? 02:42:29

10 A. I think I answered that question. There 02:42:33

11 may have been individuals that have spoken with the 02:42:35

12 National Governing Bodies with regard to these type 02:42:38

13 of issues, but -- but I'm not aware of that. I -- I 02:42:41

14 can't provide that information to you. 02:42:43

15 Q. Can you point to me -- point me to any 02:42:45

16 written policies or procedures or guidelines that 02:42:47

17 were in effect from '07 to 2011 that were designed 02:42:50

18 to prevent sexual misconduct between coaches and 02:42:55

19 athletes? 02:42:59

20 A. I don't know if there were such 02:43:02

21 guidelines. They may have existed in Codes of 02:43:04

22 Ethics. National Governing Bodies may have had 02:43:09

23 their own SafeSport policies. 02:43:13

24 Q. Okay. was there anything preventing the 02:43:15

25 USOC from implementing the SafeSport initiative 02:43:17

Page 54
1 prior to 2013? 02:43:25

2 MS. HOLM: Well, there's a lack of 02:43:27

3 foundation as to this witness' involvement in that 02:43:29

4 process. Calls for speculation. 02:43:33

5 If you can answer it. 02:43:34

6 A. Was there anything that prevented the 02:43:36

7 USOC? Not to my knowledge. 02:43:37

8 Q. (By Mr. Estey) All right. I mean, USOC 02:43:40

9 has been aware of -- of the issue of -- of coaches 02:43:43

10 sexually abusing athletes for a number of years, 02:43:46

11 correct? 02:43:49

12 MS. HOLM: Well, again, this witness is 02:43:51

13 going to have to testify about his knowledge, and to 02:43:54

14 the extent you want to make that USOC -- 02:43:57

15 MR. ESTEY: And that's a fair -- that's a 02:44:00

16 fair objection. 02:44:01

17 MS. HOLM: That's what my problem is was 02:44:01

18 most of the question at this moment in time. He may 02:44:03

19 be the wrong person to be talking to, generally 02:44:06

20 speaking. 02:44:08

21 MR. ESTEY: Yeah. 02:44:09

22 Q. (By Mr. Estey) Generally speaking, the 02:44:10

23 USOC is generally aware of coaches potentially 02:44:11

24 sexually abusing their athletes, correct? 02:44:15

25 A. I mean, I can't speak on behalf of the 02:44:21

Page 55
1 USOC whether or not there was an occasion where the 02:44:23

2 USOC received notice or received information about 02:44:28

3 that. It's possible. 02:44:31

4 Q. All right. Going back to Exhibit 20, and 02:44:33

5 Paragraph 4 of the last page: "One would hope that 02:44:42

6 the circumstances leading to the suspension of 02:44:45

7 Ms. Meloon will not reoccur in the life of another 02:44:47

8 young Olympic hopeful." Do you recall reading that 02:44:51

9 sentence? 02:44:55

10 A. If I read the opinion in 2007, I'm sure 02:44:57

11 that I read that sentence. 02:45:02

12 Q. All right. And did you have an 02:45:03

13 understanding as to what the arbitrator was 02:45:04

14 referring to in that sentence? 02:45:05

15 A. You would have to ask the arbitrator. 02:45:09

16 I -- I don't know what the arbitrator is referring 02:45:19

17 to. 02:45:22

18 Q. All right. Well, did you ask for 02:45:23

19 clarification from the arbitrator? 02:45:25

20 A. I did not. 02:45:27

21 Q. Do you know if anyone from the USOC asked 02:45:29

22 for clarification from the arbitrator? 02:45:32

23 A. I do not know if anyone asked for 02:45:34

24 clarification. 02:45:37

25 Q. Well, this is the -- the only opinion you 02:45:38

Page 56
1 said you've seen where the arbitrator is sending a 02:45:38

2 message of this nature to USOC, right? 02:45:43

3 MS. HOLM: That's argumentative as 02:45:47

4 phrased. It misstates the context of his testimony. 02:45:47

5 Instruct him not to answer the question. 02:45:50

6 Q. (By Mr. Estey) Well, you -- you said -- 02:45:52

7 you said earlier you've never seen language like 02:45:52

8 this in an -- in an arbitrator's opinion, right? 02:45:56

9 A. I don't recall seeing language like this 02:46:00

10 in an arbitrator's opinion dealing with -- well, 02:46:02

11 that's not true. 02:46:07

12 There have been other Section 9 cases that 02:46:07

13 have dealt with SafeSport issues. Whether or not 02:46:11

14 the arbitrator in those particular cases had any 02:46:13

15 direction for the National Governing Body, I can't 02:46:21

16 recall. 02:46:25

17 Q. All right. Well, after you read this, did 02:46:25

18 you discuss this paragraph with anyone at USOC? 02:46:29

19 A. It's possible. 02:46:32

20 Q. Well, anything's possible. Do you recall 02:46:33

21 doing it? 02:46:35

22 A. If I would have discussed it with anyone, 02:46:36

23 it probably would have been with the General 02:46:40

24 Counsel. 02:46:42

25 Q. Did -- did USOC make any changes to its 02:46:44

Page 57
1 policies or procedures after this arbitrator's 02:46:49

2 decision of May 25th, '07? 02:47:01

3 MS. HOLM: Well, I have to object to the 02:47:03

4 form of the question. Its lack of foundation as to 02:47:05

5 any knowledge base for this witness to give a 02:47:07

6 response. Calls for speculation. 02:47:10

7 If you can answer. 02:47:12

8 A. Well, certainly, we've made changes to our 02:47:14

9 policies and procedures as of 2013. 02:47:16

10 Q. (By Mr. Estey) All right. But from '07 02:47:21

11 to 2013, were any changes made to policies and 02:47:24

12 procedures to help prevent coaches sexually abusing 02:47:26

13 the athletes? 02:47:32

14 MS. HOLM: Again, objection. Lack of 02:47:33

15 foundation. Calls for potential speculation. 02:47:34

16 Please don't guess. If you know, please 02:47:37

17 tell him. 02:47:40

18 A. I don't know of any changes to policies 02:47:43

19 and procedures. 02:47:45

20 Q. (by Mr. Estey) During that time period of 02:47:46

21 '07 to 2013? 02:47:47

22 A. During that time period. 02:47:50

23 Q. All right. And who would know if any 02:47:51

24 changes were made during that time period? 02:47:53

25 A. I don't know. 02:47:56

Page 58
1 (Plaintiffs' Deposition Exhibit 21 was 02:47:58

2 identified.) 02:47:58

3 Q. (By Mr. Estey) All right. Let's go to 02:48:17

4 Exhibit 21. 02:48:19

5 (Plaintiffs' Deposition Exhibit 17 was 02:48:33

6 identified.) 02:48:33

7 Q. (By Mr. Estey) Let me to go back to -- 02:48:33

8 yeah. We'll go -- we'll go -- actually, we're going 02:48:35

9 to go back to Exhibit 17 now. 02:48:35

10 And take a look at that and let me know if 02:48:37

11 you've ever seen -- let me know when you're ready, 02:48:42

12 sir. 02:49:05

13 A. All right. I believe I've seen this 02:49:06

14 before. 02:49:16

15 Q. And when do you think you first saw that? 02:49:17

16 A. Probably sometime in March of 2014. 02:49:22

17 That -- that's when it's dated. 02:49:25

18 Q. Now, this is a -- an email from Ronda 02:49:27

19 Sweet to, it looks like, you and -- and John Ruger, 02:49:31

20 right? 02:49:34

21 A. Correct. 02:49:38

22 Q. And it's Gitelman about a SafeSport link, 02:49:39

23 and then also about Gitelman, right? 02:49:41

24 MS. HOLM: Could I see -- who did you say 02:49:47

25 it was between? 02:49:49

Page 59
1 Q. Sweet, Ruger and Johansen. 02:49:51

2 MS. HOLM: Okay. It was from Sweet? 02:49:53

3 MR. ESTEY: Right. 02:49:55

4 MS. HOLM: To John Ruger and Johansen. 02:49:55

5 Okay. 02:49:58

6 A. Sorry. What was your question? 02:50:09

7 Q. (By Mr. Estey) That Sweet's sending you 02:50:10

8 an email about USAT SafeSport, the link, and then 02:50:13

9 also about Gitelman, right? 02:50:18

10 A. Yes. 02:50:20

11 Q. All right. And let's back up a little 02:50:21

12 bit. 02:50:23

13 What -- you -- you became aware at some 02:50:23

14 point that -- that Yazmin Brown alleged that -- that 02:50:25

15 Gitelman sexually abused her, right? 02:50:28

16 A. I believe that I -- the first time I 02:50:38

17 became aware of that is when I read the complaint 02:50:39

18 that was filed against the USOC and USA Taekwondo. 02:50:44

19 Q. Okay. And when was that, do you know? 02:50:50

20 A. Sometime this year. 02:50:51

21 Q. In 2016? 02:50:52

22 Well, this is a -- this is a -- an email 02:50:57

23 from March of 2014, and Sweet's talking about 02:51:01

24 Gitelman, right? 02:51:05

25 A. She is. 02:51:07

Page 60
1 Q. All right. And so when she says, "Before 02:51:08

2 you look at the before and after shots, I noticed 02:51:10

3 that Gitelman renewed his school membership in 2014 02:51:14

4 after he was suspended 10-13." 02:51:17

5 Did you understanding -- understanding 02:51:21

6 what she was referring to there? 02:51:21

7 A. Well, I think my understanding is what it 02:51:40

8 says; that Gitelman was still participating in the 02:51:43

9 school. 02:51:47

10 Q. No. I appreciate that. But you just told 02:51:49

11 me that you didn't know anything about the Yazmin 02:51:51

12 Brown complaint until this year 2016, and my 02:51:55

13 question is, well, as of 2014, Ronda Sweet's 02:51:57

14 emailing you about Gitelman's suspension and his 02:52:00

15 membership, right? 02:52:04

16 A. Correct. 02:52:06

17 Q. Did you have an understanding back in 02:52:06

18 March of 2014 what Sweet was referring to? 02:52:08

19 A. In terms of Yazmin Brown? 02:52:11

20 Q. Yes. 02:52:14

21 A. This email doesn't mention Yazmin Brown. 02:52:15

22 Q. It mentions Gitelman's suspension though, 02:52:18

23 right? 02:52:19

24 A. That's correct. 02:52:21

25 Q. All right. Did you know that Gitelman had 02:52:22

Page 61
1 been -- had been suspended allegedly as of October 02:52:25

2 '13? 02:52:27

3 A. I didn't know when he was suspended. 02:52:29

4 Q. Okay. Well, when she sent you this email 02:52:33

5 in March of 2014, and she's talking about Gitelman 02:52:35

6 being suspended and coaching, I mean, did you say, 02:52:37

7 Well, what are you talking about? I have no idea 02:52:41

8 what you're talking about, or did you write back and 02:52:43

9 say, Oh, I -- I -- I know exactly what's going on. 02:52:47

10 I mean, what -- what was your thought process? 02:52:48

11 A. Well, there had been previous emails with 02:52:51

12 with regard to Gitelman, is my understanding. So, I 02:52:54

13 knew that Taekwondo had been looking in -- into his 02:52:57

14 activities, and I knew that they had been conducting 02:52:59

15 a hearing process with regards to him. 02:53:02

16 Q. All right. So, you knew that, at least 02:53:05

17 March of 2014, there was an ongoing hearing process 02:53:07

18 of Gitelman? 02:53:11

19 A. I don't know if I knew it was ongoing. 02:53:13

20 I -- I guess I probably knew it was ongoing. 02:53:14

21 Q. Did you know who the complainant was? 02:53:18

22 A. I did not. 02:53:20

23 Q. Okay? 02:53:20

24 A. Or if I did, I didn't recall it. I don't 02:53:20

25 recall that I knew at this time. 02:53:23

Page 62
1 Q. Okay. All right. At least as of March of 02:53:24

2 2014, Gitelman apparently was -- was renewing his -- 02:53:27

3 his membership in USA Taekwondo, right? 02:53:32

4 A. I would have no knowledge of that. 02:53:38

5 Q. All right. And you -- you were aware that 02:53:41

6 he was allegedly suspended in October of 2013? 02:53:44

7 A. My understanding was that there was a 02:53:48

8 provisional suspension in 2013. 02:53:51

9 Q. And what do you base that understanding 02:53:54

10 on? 02:53:56

11 A. An email. 02:53:56

12 Q. From? 02:53:57

13 A. I believe it was an email that I wrote. 02:53:58

14 Q. To whom? 02:54:01

15 A. I don't recall. It was one of the 02:54:02

16 exhibits that was provided today. 02:54:05

17 Q. Well, if Gitelman was suspended in -- in 02:54:06

18 October '13, do you have any understanding or any 02:54:08

19 idea why he was able to renew his membership the 02:54:12

20 following year? 02:54:16

21 A. I do not. 02:54:17

22 Q. Did you ever look into that with -- with 02:54:18

23 USAT? 02:54:20

24 A. I did not. 02:54:21

25 Q. Why not? 02:54:22

Page 63
1 MS. HOLM: Well, objection. It's 02:54:23

2 argumentative as phrased. It assumes that was the 02:54:24

3 responsibility for him to do. 02:54:27

4 Q. (By Mr. Estey) Well, you've got a coach 02:54:29

5 that's -- that's been accused of sexually abusing 02:54:31

6 students, supposedly suspended, but then his 02:54:34

7 membership is allowed to renew the following year. 02:54:38

8 Is -- is that of concern to you as -- as Assistant 02:54:41

9 General Counsel for USOC? 02:54:43

10 A. Well, it says he renewed his school 02:54:46

11 membership in 2014. I don't know what that means, 02:54:48

12 "renewed his school membership." 02:54:50

13 Q. All right. Did you look in -- 02:54:52

14 A. That may be different than Gitelman 02:54:52

15 renewing a membership in Taekwondo. 02:54:54

16 Q. All right. Did you look into that? 02:54:57

17 A. I did not. 02:54:59

18 Q. All right. Was that important to you? 02:54:59

19 Was that part of your duties to look into situations 02:55:00

20 where -- when a coach is suspended one year, and 02:55:05

21 then allowed to renew his school membership the next 02:55:08

22 year? 02:55:11

23 A. It's not part of my duty. 02:55:11

24 Q. Okay. So, after you read this email from 02:55:16

25 Sweet in March of 2014, did you take any action? 02:55:22

Page 64
1 A. I don't recall. I may have forwarded it 02:55:27

2 on to Malia Arrington, but I don't recall. 02:55:29

3 Q. All right. We're going to show you marked 02:55:34

4 21, and it is a -- here you go -- an email from 02:55:37

5 Sweet to you and -- and -- and Arrington. 02:55:42

6 Tell me if you've seen this email before. 02:55:49

7 A. I have. 02:55:53

8 Q. And do you recall reading it in about 02:55:55

9 March of 2014? 02:55:57

10 A. I don't recall reading it then, but that's 02:56:00

11 the -- the date on the email. 02:56:03

12 Q. All right. And -- and she basically 02:56:04

13 outlines what's happening with -- with the Gitelman 02:56:05

14 hearing, right? 02:56:10

15 MS. HOLM: While he read, could we take a 02:56:13

16 quick break so I can go to the restroom? 02:56:39

17 MR. ESTEY: Sure. Sure. 02:56:41

18 MS. HOLM: Thank you. 02:56:41

19 A. She understand -- or I understand this 02:56:42

20 to -- her -- her understanding of what's going on 02:56:43

21 with the Gitelman dispute, or Git- -- Gitelman 02:56:49

22 grievance hearing. 02:56:51

23 Q. And did you know the status of the -- the 02:56:52

24 Gitelman hearing at this point? 02:56:54

25 A. I do not recall. 02:56:58

Page 65
1 Q. All right. How many other hearings were 02:57:01

2 you aware of at this time involving allegations of 02:57:04

3 sexual misconduct between a coach and an athlete? 02:57:06

4 MS. HOLM: I'm not quite sure I understand 02:57:12

5 the scope of that question. 02:57:16

6 MR. ESTEY: He said he doesn't recall 02:57:16

7 the -- the -- the status of the -- the Gitelman 02:57:16

8 hearing. I wanted to know -- find out -- I mean, 02:57:16

9 were there a bunch of them going on at the same 02:57:20

10 time, that's the reason why he didn't know, or I 02:57:22

11 want to know why. I mean -- strike that. 02:57:24

12 Q. (By Mr. Estey) Sexual abuse is a very 02:57:25

13 serious allegation, right? 02:57:27

14 A. Yes. 02:57:29

15 Q. I mean, it -- it involves the -- the 02:57:29

16 safety of -- of the athletes and -- and long-term 02:57:32

17 harm, right? 02:57:36

18 A. Correct. 02:57:37

19 Q. Okay. And so when you get -- you find out 02:57:37

20 that one of the -- the NGBs coaches has been accused 02:57:40

21 of sexually abusing an athlete, that's -- that's a 02:57:42

22 concern for you, right? 02:57:47

23 A. Let me again explain that National 02:57:49

24 Governing Bodies are separate and distinct 02:57:50

25 organizations from the USOC. There are hundreds of 02:57:55

Page 66
1 thousands of athletes and members of various 02:57:59

2 National Governing Bodies. 02:58:01

3 So, if you're trying to say that it's my 02:58:05

4 obligation to investigate each and every one of 02:58:07

5 those, that's not correct. 02:58:10

6 Each National Governing Body is 02:58:13

7 responsible to investigate and provide a hearing 02:58:16

8 process for those individuals that have been accused 02:58:19

9 of a SafeSport violation. 02:58:22

10 Q. And apparently Ms. Sweet is concerned in 02:58:24

11 this email that USAT is not providing the 02:58:26

12 complainant with the proper hearing, correct? 02:58:35

13 A. You'd have to ask Ms. Sweet what her 02:58:42

14 concern is here. 02:58:44

15 Q. All right. Well, in this email, she's 02:58:45

16 asking you, why is Gitelman still a USAT coach, 02:58:47

17 right? 02:58:51

18 A. I don't know. What -- what paragraph are 02:58:53

19 you looking at? 02:58:55

20 Q. Second paragraph, first sentence. 02:58:57

21 A. She's asking a number of questions about 02:58:58

22 Gitelman's participation in Taekwondo. 02:59:19

23 Q. All right. And did you ever respond to 02:59:23

24 this email? 02:59:26

25 A. I don't recall if I responded to this 02:59:27

Page 67
1 email or not. 02:59:29

2 Q. Did you ask someone to respond to this -- 02:59:30

3 to this email? 02:59:32

4 A. It's possible that I would have forwarded 02:59:33

5 this email to -- I was going to say to Malia 02:59:35

6 Arrington, but I see that the email was sent to her. 02:59:38

7 Q. All right. Do you recall taking any 02:59:43

8 action after receiving this email? 02:59:46

9 A. I don't recall taking any action except 02:59:50

10 possibly, like I said, forwarding it on to Malia, 02:59:52

11 but since she's already -- was -- the email was 02:59:59

12 addressed to her, probably I took no action. 03:00:01

13 MR. ESTEY: All right. Do you want to 03:00:05

14 take a break before we go on to the next one? 03:00:05

15 MS. HOLM: Thank you. 03:00:08

16 THE VIDEOGRAPHER: This is the end of 03:00:09

17 Media Unit 1 in the deposition of Gary Johansen. We 03:00:09

18 are off the record at 3:00 p.m. 03:00:14

19 (A recess was taken from 3:00 p.m. to 3:09 03:08:04

20 p.m.) 03:08:04

21 THE VIDEOGRAPHER: This is the beginning 03:08:24

22 of Media Unit 2 in the deposition of Gary Johansen. 03:08:24

23 We're back on the record at 3:09 p.m. 03:08:28

24 Q. (By Mr. Estey) Now, you've -- you've 03:08:31

25 stated a couple of times that that USOC does not 03:08:31

Page 68
1 have athletes? 03:08:36

2 A. Correct. 03:08:38

3 Q. Is there a guy named Ryan -- Ryan Lochte, 03:08:39

4 he was a swimmer that got in trouble in Brazil? 03:08:41

5 A. Yes. 03:08:48

6 Q. All right. Do you have an understanding 03:08:48

7 that it was USOC, not USA Swimming, that actually 03:08:49

8 suspended Mr. Lochte? 03:08:53

9 A. Pardon? Could you say that again? 03:09:03

10 Q. Sure. 03:09:07

11 MR. ESTEY: Can I have it read back, 03:09:18

12 please? 03:09:18

13 (Last question read back.) 03:09:18

14 A. Actually, I'm not sure what the -- the 03:09:19

15 determination was with Mr. Lochte. 03:09:21

16 Q. (By Mr. Estey) Okay. Have you ever read 03:09:25

17 anywhere that Mr. Blackmun was the one who actually 03:09:26

18 made the decision to suspend -- suspend Lochte? 03:09:31

19 A. I have not read that. 03:09:34

20 Q. All right. Well, if -- if it's true that 03:09:35

21 Mr. -- Mr. Blackmun of USOC suspended Lochte, that 03:09:36

22 would be inconsistent with your contention that the 03:09:42

23 USOC does not have athletes, correct? 03:09:45

24 A. What do you mean by "suspend"? 03:09:49

25 Q. I don't know. 03:09:53

Page 69
1 A. Well, you asked the question. Suspend 03:09:53

2 from what? 03:09:57

3 Q. Well, you're generally aware that Lochte 03:09:59

4 was suspended by USOC, right? 03:10:01

5 MS. HOLM: I think you're misstating his 03:10:04

6 testimony in response to that, which questions 03:10:06

7 you've asked a couple of times now about who did the 03:10:08

8 suspension -- 03:10:11

9 MR. ESTEY: All right. 03:10:12

10 MS. HOLM: -- or whatever you want to call 03:10:12

11 it. 03:10:12

12 Q. (By Mr. Estey) Have -- have you ever 03:10:12

13 heard that USOC was the -- the entity that suspended 03:10:12

14 Lochte? 03:10:15

15 MS. HOLM: It's been asked and answered, 03:10:16

16 but you can answer it again. 03:10:17

17 A. Actually, I'm -- I'm not really aware of 03:10:19

18 the agreement that was made between Mr. Lochte and 03:10:22

19 USA Swimming and the USOC. 03:10:27

20 Q. (By Mr. Estey) Do you know if the USOC 03:10:29

21 had any role in the suspension of Lochte? 03:10:32

22 MS. HOLM: Well,l first of all, can you 03:10:36

23 answer the question "yes" or "no"? 03:10:38

24 THE WITNESS: I -- I cannot. I don't know 03:10:40

25 what you mean by "suspend." We have no members so I 03:10:45

Page 70
1 don't know what you mean by "suspend Mr. Lochte." 03:10:50

2 He may have been suspended from USA Swimming. 03:10:52

3 Q. (By Mr. Estey) Right. And was -- did the 03:10:56

4 USOC play any role in the suspen- -- suspension of 03:10:59

5 Lochte from USA Swimming? 03:11:04

6 MS. HOLM: Well, it's vague and ambiguous 03:11:11

7 as to, quote, "any role." It is overbroad as to 03:11:14

8 time. We're talking about 2016, the events took 03:11:17

9 place in Rio, as opposed to what was going on back 03:11:20

10 the time that we talking about in 2014. May call 03:11:23

11 for speculation, and lack of foundation that this 03:11:26

12 gentleman was involved in that process. 03:11:29

13 MR. ESTEY: You know, I appreciate your 03:11:30

14 concerns. 03:11:31

15 MS. HOLM: I don't know why we're -- 03:11:32

16 MR. ESTEY: No, here's the deal -- 03:11:32

17 MS. HOLM: It's otherwise argumentative, 03:11:32

18 the other question. 03:11:32

19 MR. ESTEY: And I appreciate your 03:11:35

20 concerns. I don't usually address it, but the 03:11:36

21 reality is is that they're trying to distance 03:11:37

22 themselves and say they have no control over the 03:11:39

23 NGBs or the athletes. 03:11:42

24 The reality is is that we don't think 03:11:46

25 that's true, and number two, Blackmun is on -- on -- 03:11:46

Page 71
1 on record saying that USOC suspended Lochte. And if 03:11:47

2 that's true, then there is -- there is -- that is 03:11:53

3 contrary to the contention of this witness. 03:11:54

4 MS. HOLM: Well, I think you're 03:11:57

5 misconstruing the testimony that's been given by 03:11:58

6 this witness in response to your particular 03:12:00

7 questions, and extrapolating that into something 03:12:04

8 that you want to now argue about with regard to what 03:12:07

9 Mr. Blackmun may have said about Mr. Lochte in 2016. 03:12:10

10 I have no problems with you asking 03:12:15

11 questions as to this witness; what he's -- what he 03:12:17

12 means by what he says, and that's just not a 03:12:20

13 problem. 03:12:23

14 Q. (By Mr. Estey) All right. All right. 03:12:26

15 So, let's just see if we can clear this up and -- 03:12:29

16 and potentially move on. 03:12:31

17 Your -- your -- your testimony is you had 03:12:33

18 no role in the Lochte suspension, correct? 03:12:36

19 A. I was not involved in the agreement 03:12:43

20 between USA Swimming and the USOC and Mr. Lochte. 03:12:48

21 Q. All right. Well, do you know what role 03:12:54

22 USOC played in Lochte's suspension? 03:12:55

23 A. By USA Swimming? 03:12:59

24 Q. No. Do you know what role USOC played in 03:13:01

25 Lochte's suspension, if any? 03:13:07

Page 72
1 MS. HOLM: This either calls for a "yes" 03:13:11

2 or "no." 03:13:13

3 A. Yes. 03:13:13

4 Q. (By Mr. Estey) All right. And what role 03:13:14

5 did USOC play in the suspension -- 03:13:15

6 A. Well, let me go back. 03:13:16

7 What role did the USOC play in Lochte's 03:13:18

8 suspension by USA Swimming? That -- that -- that 03:13:20

9 would have been a USA Swimming decision. 03:13:24

10 Q. Sure. 03:13:27

11 And I -- and when I'm saying what role, 03:13:27

12 I'm saying what role did USOC have, if any, in the 03:13:29

13 suspension by -- of -- of -- of Lochte by either USA 03:13:33

14 Swimming or USOC? 03:13:36

15 A. That matter was handled by someone else in 03:13:47

16 our office. I may have generally aware. 03:13:50

17 MS. HOLM: Well, then to the extent that 03:13:54

18 anything you've learned as a lawyer dealing with 03:13:56

19 another lawyer within the office on these issues, 03:13:59

20 that would be attorney-client privilege and should 03:14:02

21 not be discussed. 03:14:04

22 Q. (By Mr. Estey) And when you say the USOC 03:14:07

23 does not have athletes, what do you mean by that? 03:14:16

24 A. Exactly what -- what I said. We -- we 03:14:23

25 don't have athletes. Athletes are members or can be 03:14:25

Page 73
1 members of the National Governing Body. We send 03:14:33

2 athletes to the Olympic, Pan American and Paralympic 03:14:37

3 Games. 03:14:41

4 Q. Does the USOC have the power to suspend 03:14:42

5 coaches or athletes? 03:14:44

6 A. No. 03:14:52

7 Q. And what do you base that statement on? 03:14:53

8 A. My service at the USOC and the Ted Stevens 03:14:59

9 and Olympic and Amateur Sports Act. 03:15:02

10 Q. So, if Mr. Blackmun -- strike that. We'll 03:15:09

11 deal with Mr. Blackmun later. 03:15:12

12 MR. ESTEY: What number are we on? 03:15:38

13 MS. HOLM: 22, I think. 03:15:38

14 (Plaintiffs' Deposition Exhibit 22 was 03:15:38

15 identified.) 03:15:38

16 MR. ESTEY: So, we'll mark this as 03:15:38

17 Exhibit 22; emails, March 10, 2014. 03:15:38

18 MS. HOLM: And I might -- might suggest, 03:15:54

19 if you have emails that are in the same time frame, 03:15:54

20 it might be worth while -- 03:15:57

21 MR. ESTEY: The way they came to -- 03:16:01

22 well -- 03:16:01

23 MS. HOLM: In terms of the framing, 03:16:02

24 because it would help, I think, with some of the 03:16:03

25 responses. 03:16:05

Page 74
1 MR. ESTEY: Probably. But, unfortunately, 03:16:07

2 they're put together like this, so I'm stuck. 03:16:09

3 Q. (By Mr. Estey) Take a look at that and 03:16:13

4 see if you recognize that email. 03:16:14

5 Let me know when you're ready. 03:16:24

6 A. Okay. 03:16:39

7 Q. So, this is an -- an email from Lyons 03:16:39

8 to -- to you and Lucy Denly and Glenn Merry and 03:16:42

9 Sarah Conrad. 03:16:47

10 And she says, "Here we ago again. This 03:16:47

11 sounds like the same old BS. This is no longer in 03:16:52

12 our purview, but Glenn, I know you're still advising 03:16:55

13 Bruce. This seems like something they need to 03:16:59

14 address. Allowing a potential sexual predator to 03:17:01

15 continue to coach without having an appropriate 03:17:06

16 investigation and conclusion is unacceptable." 03:17:08

17 Do you recall reading this? 03:17:12

18 A. I don't recall reading it, but it was -- 03:17:14

19 I -- I was on the header, so it was sent to me. 03:17:18

20 Q. Well, how -- how -- how many emails do 03:17:21

21 you -- have you received that reference a potential 03:17:23

22 sexual predator, sir? 03:17:28

23 A. I -- I don't really recall how many I've 03:17:34

24 received. Probably not many. 03:17:36

25 Q. Okay. So when an email alleges that a 03:17:37

Page 75
1 sexual predator is continuing to coach, that doesn't 03:17:41

2 send off alarm bells in your head? 03:17:45

3 MS. HOLM: Well, it doesn't say "a sexual 03:17:47

4 predator." It says "a potential sexual predator." 03:17:49

5 And you also didn't read the rest of that 03:17:53

6 sentence as well -- 03:17:54

7 MR. ESTEY: Right. 03:17:54

8 MS. HOLM: -- as to whether he might 03:17:54

9 innocent. That needs to be established. 03:17:58

10 MR. ESTEY: Well, we know he's not. 03:18:00

11 MS. HOLM: Well, no, I understand that, in 03:18:01

12 2014, in March, well, it's a different situation. 03:18:03

13 MR. ESTEY: Fair enough. 03:18:05

14 Q. (By Mr. Estey) All right. So you get -- 03:18:06

15 you get an -- an email saying there's a potential 03:18:08

16 sexual predator coaching on behalf of the USA 03:18:10

17 Taekwondo, right? 03:18:13

18 A. Yes. 03:18:16

19 Q. All right. 03:18:17

20 A. From -- from Susanne Lyons. 03:18:17

21 Q. And -- and she's a USOC Board member, 03:18:18

22 right? 03:18:21

23 A. She is. 03:18:21

24 Q. And do you have an understanding as to why 03:18:22

25 she's sending you this? 03:18:24

Page 76
1 A. She asked me my thoughts on how to respond 03:18:26

2 to the email from Ronda Sweet. 03:18:29

3 Q. Okay. And what were your thoughts in that 03:18:31

4 regard? 03:18:33

5 A. Ms. Lyons was a member of the hearing 03:18:35

6 panel, and she's also a USOC Board member, so any 03:18:38

7 information or advice I would have given to her 03:18:42

8 would be attorney-client privileged. 03:18:46

9 Q. Fair enough. 03:18:48

10 Did you yourself take any actions aside 03:18:54

11 from maybe communicating to other people. Which I 03:18:58

12 don't want to hear about unless they're non-USOC 03:19:01

13 employees, did you yourself take any other action 03:19:04

14 after receiving this email from Lyons? 03:19:09

15 A. I don't recall. I may have forwarded it 03:19:13

16 on to Ms. Arrington. 03:19:14

17 Q. All right. And do you know why Lyons -- I 03:19:15

18 may have asked you this. Do you know why Lyons is 03:19:17

19 sending this to you? 03:19:19

20 MS. HOLM: Well, calls for speculation, 03:19:21

21 but if you know why she sent it to you, in 03:19:22

22 particular, and the other people. 03:19:25

23 A. Well, she asked me for -- for my thoughts 03:19:28

24 on how to respond. 03:19:30

25 Q. Okay. 03:19:32

Page 77
1 A. So I'm assuming that's why she sent it. 03:19:32

2 Q. Do you know if Mr. Blackmun was aware of 03:19:39

3 the allegations against -- against Gitelman? 03:19:59

4 A. I do not know if he was aware. 03:20:02

5 Q. Do you know if he was ever on any -- cc'd 03:20:04

6 on any emails from either Ronda Sweet or anyone 03:20:07

7 else? 03:20:10

8 A. I don't recall if he was or not. 03:20:12

9 MR. ESTEY: Mark this as Exhibit 23 -- or 03:20:14

10 22. 03:20:32

11 Thank you. 03:20:32

12 (Plaintiffs' Deposition Exhibit 22A was 03:20:32

13 identified.) 03:20:32

14 Q. (By Mr. Estey) And this is an email dated 03:20:55

15 March 2014 to you, Ruger, Arrington and Isaacs from 03:20:58

16 Sweet. 03:21:02

17 Do you recall receiving this email before 03:21:04

18 today's date? 03:21:05

19 A. I don't recall receiving it but I expect 03:21:08

20 that I did receive it. My name is on the header. 03:21:10

21 Q. Do you recall receiving any emails about 03:21:16

22 the Gitelman issue back in 2014? 03:21:18

23 A. I receive a lot of emails from a lot of 03:21:24

24 different people, and looking at these emails, I 03:21:27

25 certainly assume that I received these emails. 03:21:32

Page 78
1 Q. All right. Well, this -- these emails are 03:21:35

2 a little different, though, because they're 03:21:37

3 involving allegations of a sexual predator, right? 03:21:40

4 MS. HOLM: What? 03:21:44

5 Q. (By Mr. Estey) Well, you don't get 03:21:45

6 allegations -- you don't get emails involving 03:21:46

7 allegations of -- of a sexual predator within an NGB 03:21:48

8 on a daily basis, do you? 03:21:53

9 A. This email was about the suspension of 03:21:55

10 Mr. Gitelman. 03:21:57

11 Q. Who -- who you knew was alleged to have 03:21:58

12 sexually abused multiple athletes, right? 03:22:00

13 A. I don't know that I knew that. 03:22:03

14 Q. When did you find out that Mr. Gitelman 03:22:06

15 was accused of -- of sexually abusing multiple 03:22:09

16 athletes? 03:22:12

17 A. My recollection is the first time I became 03:22:13

18 aware was probably when Ronda Sweet sent an email in 03:22:15

19 either the fall of 2013 or in March of 2014. 03:22:21

20 Q. All right. So do you believe you would 03:22:27

21 have known the allegations against Gitelman when you 03:22:29

22 received this March 10, 2014 email? 03:22:32

23 A. I don't think I would have known the 03:22:36

24 specific allegations against him. 03:22:38

25 Q. Okay. 03:22:40

Page 79
1 A. Again, this was USA Taekwondo. My 03:22:40

2 understanding is it that they had brought charges 03:22:43

3 against Mr. Gitelman and were prosecuting him 03:22:47

4 through their hearing process. 03:22:51

5 Q. And as Assistant General Counsel for USOC, 03:22:54

6 were you satisfied with the approach that USAT was 03:22:58

7 taking with Gitelman? 03:23:02

8 MS. HOLM: Well, objection. Calls for a 03:23:04

9 legal conclusion and an opinion that is potentially 03:23:05

10 one of speculation as to what was going on, but if 03:23:11

11 you can answer the question as to your thought 03:23:15

12 process. 03:23:17

13 MR. OKAMURA: Enjoin those objections. 03:23:18

14 MS. HOLM: Not quite sure what you mean by 03:23:21

15 satisfied. 03:23:21

16 A. I think, as I testified earlier, my 03:23:21

17 assumption, from an earlier email that was produced 03:23:24

18 here today, my assumption was Mr. Gitelman was under 03:23:28

19 a temporary suspension. 03:23:32

20 Q. All right. And did you ever find out that 03:23:36

21 that suspension was illusory? It wasn't real. He 03:23:37

22 was allowed to continue to coach? 03:23:41

23 A. There's been subsequent emails in March, I 03:23:44

24 believe, of 2014 in which Ms. Sweet makes that 03:23:46

25 allegation. 03:23:51

Page 80
1 Q. Okay. And as Assistant General Counsel 03:23:51

2 for USOC, did that concern you? 03:23:55

3 MS. HOLM: I think the title he was 03:23:57

4 "Associate," just to be accurate. 03:23:59

5 MR. ESTEY: All right. 03:24:00

6 Q. (By Mr. Estey) And as Associate General 03:24:01

7 counsel for USOC, did that concern you that this 03:24:04

8 coach who had been suspended was continuing to coach 03:24:09

9 at tournaments? 03:24:12

10 MS. HOLM: Vague and ambiguous as to your 03:24:15

11 the word "concern," but if you have a recall of your 03:24:17

12 frame of thought when you received this, please 03:24:20

13 answer. 03:24:23

14 A. If a coach has committed a SafeSport 03:24:24

15 violation, and he is continuing to coach, that, of 03:24:26

16 course, is concerning. 03:24:30

17 Q. (By Mr. Estey) Okay. And what, if 03:24:31

18 anything, did you do when you were told that he was 03:24:32

19 continuing to coach after being suspended? 03:24:35

20 A. It's not my -- my responsibility is not in 03:24:40

21 the SafeSport arena. So, I may have -- again, I may 03:24:44

22 have forwarded this on to Malia, but she -- Malia 03:24:49

23 Arrington, but she was also sent this email. 03:24:50

24 (Plaintiffs' Deposition Exhibit 23 was 03:24:55

25 identified.) 03:24:55

Page 81
1 Q. (By Mr. Estey) All right. Let's show you 03:24:56

2 Exhibit 23. 03:24:58

3 MS. HOLM: I already had one. 03:25:01

4 MR. ESTEY: Exhibit 23, you already have? 03:25:09

5 Yeah. It's 22. 03:25:12

6 MR. OKAMURA: Wait. I thought the last 03:25:12

7 one was -- 03:25:17

8 MS. HOLM: I already have this. 03:25:17

9 MR. OKAMURA: -- 23. 03:25:17

10 MS. HOLM: Yeah, the last one was 23. 03:25:18

11 MR. OKAMURA: This should be 24. 03:25:18

12 MR. ESTEY: I don't think so. Exhibit -- 03:25:21

13 the last one was 22. 03:25:21

14 MS. HOLM: Well, you put the wrong number 03:25:23

15 on because -- 03:25:24

16 COURT REPORTER: I think you said 23 but 03:25:30

17 then you found the sticker 22. 03:25:32

18 MR. ESTEY: Yeah. I think you're right. 03:25:33

19 MR. OKAMURA: So -- 03:25:33

20 MS. HOLM: I have an Exhibit 22, though. 03:25:33

21 I have something that's March 10th at 8:00 a. -- of 03:25:33

22 8:02 a.m. 03:25:40

23 MS. HOLM: I have that as Exhibit 22. I 03:25:43

24 have Exhibit 23 March 10, 2014, 11:43 a.m., the one 03:25:44

25 we just went through -- 03:25:49

Page 82
1 MS. HOLM: That's what I have. 03:25:50

2 MR. OKAMURA: And the new one should be 03:25:50

3 24. 03:25:53

4 MR. ESTEY: Well, I think you should go by 03:25:53

5 whatever the orange stickies are, guys. 03:25:55

6 MS. HOLM: Well, let's make sure that we 03:25:58

7 have all the orange stickies. 03:25:59

8 This is mine. 03:26:01

9 I'm not seeing this one. The one that 03:26:26

10 says March 10, 2014, at 11:43 a.m. Is that this one 03:26:28

11 here? 03:26:32

12 No. 03:26:33

13 Okay. Well, I'll go by your numbering, 03:26:45

14 but -- 03:26:49

15 MR. OKAMURA: Well, what's this next -- 03:26:50

16 this last one that's being introduced right now, 03:26:51

17 what is Mr. Estey calling it? Because I'll go with 03:26:54

18 that number. 03:26:57

19 MS. HOLM: He's calling it 23. 03:26:58

20 MR. OKAMURA: Yeah. Okay. I'll call it 03:27:00

21 23 then. 03:27:01

22 Q. (By Mr. Estey) Look at Exhibit 23 and let 03:27:02

23 me know if you recall receiving this email on -- on 03:27:04

24 or about March 10, 2014. 03:27:07

25 MS. HOLM: Could you pass me one or more 03:27:11

Page 83
1 of those things. 03:27:12

2 You keep that. I'll take this. 03:27:15

3 Q. (By Mr. Estey) Do you see that email, 03:27:18

4 sir? 03:27:19

5 A. I do. 03:27:20

6 Q. All right. So, this is an email looks 03:27:21

7 like from Hess to -- to Ruger, and it says, "If this 03:27:23

8 is Gitelman, I talked to Johansen already." 03:27:29

9 Did you talk to Hess about the Gitelman 03:27:33

10 issue? 03:27:36

11 A. I recollect having a conversation with 03:27:46

12 Stephen Hess about this matter, but I don't recall 03:27:49

13 when it was. 03:27:51

14 Q. All right. How long did the conversation 03:27:53

15 last? 03:27:54

16 A. It was -- my recollection is it was short. 03:27:55

17 Q. Like 5 minutes, 10 minutes, 20 minutes? 03:27:58

18 A. I don't really recall, but I would say 03:28:02

19 five minutes. 03:28:04

20 Q. Who was on the phone? 03:28:05

21 A. I don't recall. 03:28:08

22 Q. Who called who? 03:28:08

23 A. I don't recall. 03:28:10

24 Q. And what did he say, what did you say? 03:28:12

25 A. I don't recall for sure. I do have a 03:28:15

Page 84
1 general recollection that I asked Mr. Hess what was 03:28:17

2 the status of the Gitelman matter. 03:28:21

3 Q. And why did you ask him that? 03:28:24

4 A. Because of -- because it had come to our 03:28:26

5 attention -- this is in March 10th. I guess it had 03:28:35

6 come to our attention, through Ms. Sweet, that he 03:28:38

7 was still coaching, and we wanted to find out if he 03:28:41

8 was suspended or not, or what was the status of the 03:28:46

9 hearing process if he wasn't suspended. 03:28:49

10 Q. All right. But USOC had no control over 03:28:52

11 the -- that hearing process, correct? 03:28:55

12 A. That's correct. 03:28:57

13 Q. All right. So why were you interested, 03:28:58

14 then, on behalf of USOC about the status of that 03:29:00

15 hearing process? 03:29:05

16 A. Because we're always concerned that 03:29:05

17 National Governing Bodies have hearing processes 03:29:08

18 that proceed in an expeditious manner, that give 03:29:11

19 both the -- both parties an opportunity to present 03:29:15

20 their case; that they're heard and decided by an 03:29:18

21 impartial panel. 03:29:21

22 Q. All right. And that's part of the 03:29:23

23 grievance process, right? 03:29:24

24 A. That's correct. 03:29:25

25 Q. And if an NGB does not have a proper 03:29:26

Page 85
1 grievance process in place, the USOC can suspend or 03:29:29

2 put that NGB on probation, correct? 03:29:35

3 A. Yes, but it's not a process where someone 03:29:47

4 waves a magic wand. 03:29:50

5 Q. I appreciate that. 03:29:52

6 A. There is a procedure for that. 03:29:54

7 MS. HOLM: I have done my investigation on 03:29:58

8 the exhibits. You marked two Exhibit 22s, while 03:29:59

9 identifying the second one as Exhibit 23. 03:30:05

10 MR. ESTEY: So, let's do 22A then. 03:30:09

11 MS. HOLM: So 22A -- 03:30:12

12 MR. ESTEY: Let's do the later in time. 03:30:12

13 MS. HOLM: Okay. So -- so 22A then is 03:30:15

14 going to be the Monday, March 14, 2014, 11:43 a.m. 03:30:19

15 email from Ronda to John Ruger, Gary Johansen, Malia 03:30:26

16 Arrington and Rachel Isaacs. 03:30:30

17 MR. ESTEY: Fair enough. Thank you. 03:30:35

18 And so we are now in agreement we are 03:30:37

19 going on to Exhibit 24? 03:30:40

20 MS. HOLM: Yes. 03:30:43

21 MR. ESTEY: Okay. And 24 is going to be a 03:30:44

22 March 13, 2014 email from Johansen to Arrington, 03:30:52

23 Ruger, and Clark? 03:30:56

24 MS. HOLM: Mr. Johansen, if you want to 03:31:00

25 look at these other ones, and if they are same dates 03:31:02

Page 86
1 and stuff like that, just so you can make sure you 03:31:05

2 keep them in the context, feel free to do that. 03:31:07

3 THE WITNESS: Thank you. 03:31:13

4 (Plaintiffs' Deposition Exhibit 24 was 03:31:13

5 identified.) 03:31:13

6 Q. (By Mr. Estey) All right. And do you 03:31:13

7 recall receiving this -- this email? 03:31:14

8 A. I do. 03:31:16

9 Q. All right. 03:31:17

10 A. Well, sorry. I -- I believe this was an 03:31:18

11 email from me to Malia Arrington, John Ruger and 03:31:20

12 Sarah Clark. 03:31:22

13 Q. All right. And -- but you wrote it, 03:31:30

14 right? 03:31:31

15 A. I wrote the -- 03:31:32

16 Q. The top part? 03:31:34

17 A. -- the top part, yes. 03:31:36

18 Q. Yeah. And you wrote that, "My 03:31:37

19 understanding is that USAT issued a temporary 03:31:39

20 suspension but never enforced it." And that's in 03:31:44

21 reference to Gitelman, right? 03:31:46

22 A. Correct. 03:31:49

23 Q. And why did you write that? 03:31:51

24 A. Why did I -- to provide information to 03:31:56

25 Malia Arrington, John Ruger and Sarah Clark. 03:31:59

Page 87
1 Q. All right. And, "Also, there is no reason 03:32:03

2 why an allegation of this sort should take six 03:32:04

3 months to prosecute with some sort of temporary 03:32:07

4 suspension being issued and enforced." 03:32:09

5 Did you have a concern that there had been 03:32:15

6 a temporary suspension issued by USAT but was not 03:32:17

7 being enforced? 03:32:23

8 A. My understanding was that a temporary 03:32:28

9 suspension or provisional suspension had been issued 03:32:33

10 against Mr. Gitelman. And then Ms. Sweet, on March 03:32:36

11 13th, sent an email saying that he was participating 03:32:41

12 as a coach at some Nevada State and Arizona State 03:32:46

13 competition. So, I was concerned. 03:32:51

14 Q. Okay. Why were you concerned? 03:32:54

15 A. Because if he was suspended by the 03:32:56

16 National Governing Body, he should no longer be 03:32:59

17 coaching. 03:33:03

18 Q. All right. And then -- so, you say, 03:33:03

19 "There's no reason an allegation of this sort should 03:33:05

20 take six months to prosecute." What are you 03:33:09

21 referring to there? 03:33:11

22 A. The NGB's hearing process. 03:33:12

23 Q. Was taking too long? 03:33:15

24 A. Well, I think the rest of the sentence 03:33:16

25 goes on to say, "without some sort of temporary 03:33:17

Page 88
1 suspension being issued and enforced." 03:33:22

2 Q. All right. Which was not happening to 03:33:24

3 your understanding, right? 03:33:26

4 A. That was my understanding pursuant to this 03:33:27

5 email. 03:33:29

6 Q. Okay. Did you take any action after 03:33:29

7 writing this -- this email? 03:33:31

8 A. I did not. I sent it off to Malia 03:33:33

9 primarily -- Malia Arrington, for her information. 03:33:36

10 Q. All right. 03:33:43

11 (Plaintiffs' Deposition Exhibit 25 was 03:33:43

12 identified.) 03:33:43

13 Q. (By Mr. Estey) Let me show you what's 03:33:43

14 marked as Exhibit 25. It looks likes your bio. Is 03:33:44

15 this your bio? 03:34:05

16 A. Yes, it is. 03:34:05

17 Q. All right. So, if you look at the third 03:34:07

18 paragraph, it says, "While working in the United 03:34:09

19 States Senate, Mr. Johansen was instrumental in 03:34:12

20 passage of the Amateurs Sports Act. That's the -- 03:34:15

21 the -- the Ted Stevens Act, is that right? 03:34:18

22 A. At that time, it was called the Amateur 03:34:21

23 Sports Act of 1978. 03:34:23

24 Q. All right. 03:34:25

25 A. It was amended in 1998. 03:34:25

Page 89
1 Q. How were you instrumental in that passage 03:34:28

2 of that Act? 03:34:29

3 A. I was on Senator Stevens' staff. 03:34:30

4 Q. All right. Did you -- were you 03:34:33

5 responsible for drafting any -- any provisions of 03:34:34

6 that Act? 03:34:38

7 A. I was -- I was responsible for drafting 03:34:40

8 some of the provisions of the Act. 03:34:43

9 Q. All right. And which provisions were you 03:34:45

10 responsible for drafting? 03:34:47

11 A. I can't recall which specific ones, but I 03:34:48

12 would have reviewed the entire Act. 03:34:51

13 Q. All right. It says, "Under the direction 03:34:53

14 of Senator Stevens, Mr. Johansen helped build a 03:34:55

15 consensus among sports organizations and drafted 03:34:58

16 provisions in the Act which expanded the authority 03:35:02

17 of the United States Olympic Committee." 03:35:05

18 What does that refer to? "A consensus 03:35:08

19 among sports organizations," what are you referring 03:35:10

20 to there? 03:35:14

21 A. At that time, there were many disputes 03:35:15

22 between the various sport organizations, 03:35:16

23 specifically the AAU, the NCAA, and possibly others 03:35:19

24 as well. 03:35:24

25 So, as a consensus, there was an -- an 03:35:26

Page 90
1 effort to bring a consensus -- consensus among those 03:35:28

2 organizations. 03:35:31

3 Q. All right. And you said that you also 03:35:32

4 expanded the authority of the United States Olympic 03:35:33

5 Committee. How -- how so? 03:35:37

6 A. The -- the Act expanded the -- expanded 03:35:39

7 the authority of the United states Olympic Committee 03:35:46

8 to be more than just an organization that sent 03:35:50

9 athletes to the Olympic Games. 03:35:52

10 Q. All right. How -- how so? 03:35:56

11 A. It provided that they would recognize 03:35:57

12 National Governing Bodies, for one instance. 03:35:58

13 It provided that they should have a 03:36:03

14 dispute mechanism in order to resolve disputes 03:36:05

15 between athletes and NGBs; specifically, 03:36:09

16 participation disputes. 03:36:13

17 Q. And it -- it gave the USOC authority over 03:36:15

18 the -- the NGBs, right? 03:36:19

19 A. It expanded the authority over NGBs 03:36:21

20 because the Act itself had provisions in it for the 03:36:25

21 resolution of disputes; what we would call Section 03:36:29

22 10 complaints. 03:36:33

23 Q. All right. Also, the Act also set forth 03:36:35

24 requirements for the National Governing Bodies that 03:36:37

25 they were required to comply with, right? 03:36:41

Page 91
1 A. That's correct. 03:36:43

2 Q. All right. Or risk being decertified by 03:36:45

3 the USOC, correct? 03:36:48

4 A. The Act sets forth requirements for 03:36:51

5 National Governing Bodies to comply with. 03:36:53

6 The Act, specifically, to my recollection, 03:36:57

7 does not have a provision allowing the USOC to 03:36:58

8 decertify an NGB. 03:37:03

9 But as we discussed earlier, the USOC was 03:37:06

10 given authority to recognize NGBs and then take away 03:37:10

11 that recognition. 03:37:14

12 Q. All right. Now, you were a moderator at 03:37:18

13 the 2012 NGB Best Practices Seminar? 03:37:22

14 A. I'm sorry. Which seminar? 03:37:29

15 Q. The November 7, 2012, NGB Best Practices 03:37:32

16 Seminar? 03:37:38

17 A. Held by the USOC? 03:37:39

18 Q. Yes, sir. 03:37:41

19 A. I don't recall. Possibly. 03:37:43

20 Q. All right. 03:37:46

21 A. I -- 03:37:46

22 Q. Well, we'll show you marked Exhibit 26. 03:37:46

23 (Plaintiffs' Deposition Exhibit 26 was 03:38:11

24 identified.) 03:38:11

25 Q. (By Mr. Estey) Does 26 refresh your 03:38:11

Page 92
1 recollection? 03:38:12

2 A. Yes. 03:38:13

3 Q. All right. So, you -- you were the 03:38:14

4 moderator on the topic of Legal Arbitrations, 03:38:16

5 Understanding The Process, right? 03:38:19

6 A. Yes. 03:38:26

7 Q. All right. And this is a -- a seminar 03:38:27

8 given to the -- the NGBs, right? 03:38:28

9 A. Correct. 03:38:33

10 Q. All right. And you told them how 03:38:35

11 important the witnesses were in an arbitration; how 03:38:41

12 to get them to best support their position? 03:38:44

13 A. Well, I was -- I -- I don't recall exactly 03:38:52

14 what I said or didn't say at this event, but I was 03:38:54

15 the moderator, and we had a panel of individuals 03:38:59

16 that would have provided their expertise, their 03:39:02

17 comments, with regard to the bullet points that are 03:39:06

18 on this document. 03:39:10

19 Q. Was this recorded in any manner? 03:39:11

20 A. I don't recall for sure, but I -- I -- 03:39:16

21 I'm -- I do not believe this was recorded. 03:39:18

22 Q. If I -- if I wanted to find out if it was 03:39:22

23 recorded, who would I talk to? 03:39:24

24 A. I don't really know. Possibly me. But 03:39:45

25 I -- I -- I -- I'm -- I'm pretty sure this was not 03:39:48

Page 93
1 recorded. 03:39:51

2 Q. Okay. I show you what's marked as 03:39:53

3 Exhibit 27. 03:40:04

4 MS. HOLM: We didn't want to talk about 03:40:15

5 the SafeSport stuff that was talked about? 03:40:17

6 MR. ESTEY: No. 03:40:19

7 MS. HOLM: Oh, okay. 03:40:22

8 MR. ESTEY: 27, right? 03:40:23

9 MS. HOLM: Yes. 03:40:27

10 MR. ESTEY: We're getting there. 03:40:28

11 (Plaintiffs' Deposition Exhibit 27 was 03:40:29

12 identified.) 03:40:29

13 Q. (By Mr. Estey) Tell me if you've ever 03:40:35

14 seen that before? 03:40:36

15 Tell me when you're ready to talk about 03:40:49

16 that document, sir. 03:40:51

17 A. Yes, I've taken a look at it. 03:41:00

18 Q. Okay. And have you seen this before 03:41:02

19 today's date? 03:41:06

20 A. Yes. 03:41:06

21 Q. All right. And this is the USOC's Policy 03:41:06

22 Regarding NGB Commercial Agreements, right? 03:41:09

23 A. Yes. 03:41:12

24 Q. So, in other words, the -- the USOC limits 03:41:13

25 what type of commercial agreements the athletes and 03:41:18

Page 94
1 the NGBs can enter into, correct? 03:41:21

2 A. Would you repeat that question? Are you 03:41:32

3 refer- -- are you referring to any particular 03:41:35

4 provisions in this document? 03:41:36

5 Q. No. Just generically. 03:41:37

6 A. Well, this sets out certain rules, if you 03:41:41

7 will, with regard to commercial agreements that NGBs 03:41:45

8 can make, and athletes can make. 03:41:50

9 Q. Yeah. The USOC -- this -- this document, 03:41:51

10 Exhibit 20- -- 03:41:56

11 MS. HOLM: Seven. 03:42:03

12 A. 27. 03:42:03

13 Q. (By Mr. Estey) All right. It sets forth 03:42:04

14 the parameters pursuant to which NGBs may and may 03:42:05

15 not use athletes' images, correct? 03:42:17

16 A. Correct. 03:42:20

17 Q. So, the USOC has control over the NGB's 03:42:21

18 use of athletes images, correct? 03:42:29

19 A. I would say that's not correct. 03:42:32

20 Q. Okay. When it says -- this -- this -- I'm 03:42:34

21 quoting from the document now. 03:42:35

22 "This document sets forth the policy of 03:42:37

23 the USOC with regard to the appropriate parameters 03:42:39

24 pursuant to which NGBs may and may not use athlete 03:42:44

25 images and/or require athletes to sign agreements 03:42:48

Page 95
1 with regard to commercial rights." Do you see that 03:42:54

2 there? 03:42:56

3 A. Yes. 03:42:56

4 Q. All right. And so you agree with me that 03:42:57

5 this document sets out the parameters which -- 03:43:00

6 which -- which the NGBs may or may not use athlete 03:43:06

7 images, correct? 03:43:10

8 A. This is a USOC policy in which the USOC 03:43:12

9 has set forth what it believes its poli- -- the NGB 03:43:16

10 policy and athlete policy should be with regard to 03:43:20

11 commercial rights. 03:43:25

12 Q. All right. And then if you look at 03:43:26

13 Page 2. 03:43:27

14 A. But -- but the USOC does not have control 03:43:28

15 over National Governing Bodies. 03:43:31

16 Q. Well, if -- if -- if the NGB violates this 03:43:33

17 policy, Exhibit 27, the USOC can decertify or put 03:43:36

18 the NGB on probation, correct? 03:43:45

19 A. I don't believe that's the case. 03:43:47

20 Q. Well, what if -- what if the NGB doesn't 03:43:49

21 follow this agreement, what are the consequences? 03:43:51

22 A. I'm not sure that there are any 03:43:54

23 consequences. 03:43:55

24 Q. All right. All right. Let's look at 03:43:56

25 Page 2, please. 03:43:57

Page 96
1 Under "Athletes' Right to Use Specialized 03:43:58

2 Equipment." 03:44:02

3 And it says, "The USOC shall have the sole 03:44:04

4 authority, after consultation with the NGB and the 03:44:08

5 AAC representative for the sport, to determine the 03:44:11

6 equipment that constitutes specialized equipment for 03:44:15

7 each sport." Do you see that? 03:44:19

8 A. Um-hum. 03:44:21

9 Q. All right. Is that "yes"? 03:44:21

10 A. Yes, I do see it. 03:44:22

11 Q. So, only the USOC, after consultation with 03:44:24

12 the NGB, has the ability to determine which 03:44:28

13 equipment constitutes a specialized equipment, 03:44:32

14 correct? 03:44:34

15 A. That authority comes from the Olympic 03:44:34

16 Charter. 03:44:38

17 Q. All right. 03:44:40

18 (Plaintiffs' Deposition Exhibit 28 was 03:44:40

19 identified.) 03:44:40

20 Q. (By Mr. Estey) Let me show what's marked 03:44:40

21 Exhibit 28. 03:44:58

22 Do you know a guy by the name of Askinas? 03:44:59

23 Dave -- David Askinas? 03:45:02

24 A. I know -- I know a David Askinas. 03:45:05

25 Q. Oh. Sorry. 03:45:08

Page 97
1 All right. So you know Askinas? 03:45:10

2 A. I do. 03:45:12

3 Q. Look -- look at Exhibit 28, please. 03:45:14

4 How do you know Mr. Askinas? 03:45:15

5 A. He was either CEO or Executive Director of 03:45:17

6 USA Taekwondo. 03:45:22

7 Q. And at some point, there -- looks like a 03:45:26

8 Ro- -- a guy named Robinson called upon the USOC to 03:45:28

9 decertify USA Taekwondo, right? 03:45:32

10 A. That's the Section 10 complaint that we 03:45:35

11 spoke about earlier. 03:45:38

12 Q. Okay. 03:45:39

13 A. He was -- he was the prime complainant on 03:45:40

14 one of those complaints. 03:45:42

15 Q. And after that, you email letters to 03:45:44

16 Padilla and Williams confirming the USOC would 03:45:48

17 shortly assemble a hearing panel to address the 03:45:52

18 complaint. 03:45:55

19 We talked about that already, are we 03:45:56

20 right? 03:45:58

21 A. Yes. Are you reading from a specific 03:45:59

22 paragraph? 03:46:01

23 Q. Yeah. It's on the second page, the Pan 03:46:01

24 Ultimate paragraph. 03:46:03

25 MS. HOLM: For the record, on Page 2, it 03:46:06

Page 98
1 appears to have been published in August 18th, 2011 03:46:08

2 Taekwondo Times, at least for dates, so we -- 03:46:18

3 MR. ESTEY: Yeah. No worries. 03:46:25

4 MS. HOLM: We've already talked about 03:46:26

5 this. 03:46:28

6 MR. ESTEY: Yeah. We've already talked 03:46:28

7 about that. I -- I just want to make -- confirm 03:46:29

8 that we've already talked about this issue and we 03:46:31

9 don't need to talk about it anymore. 03:46:34

10 MS. HOLM: Well, we don't need to talk 03:46:36

11 about it anymore. I don't know if you do, but we 03:46:37

12 talked about Section 10. 03:46:41

13 Q. (By Mr. Estey) Is that true? 03:46:48

14 A. I'm sorry. What was the question again? 03:46:49

15 Q. Have we already talked about the -- the -- 03:46:51

16 the Section 10 complaint we've referenced in there? 03:46:52

17 A. My understanding that -- I -- I don't know 03:46:56

18 what this is from. Is this a newspaper article, 03:46:58

19 or -- 03:47:01

20 Q. It's from the Internet, isn't it? 03:47:02

21 A. My understanding is -- 03:47:04

22 MS. HOLM: It's Taekwondotimes.com. 03:47:06

23 A. Right. 03:47:08

24 My understanding from looking at this is 03:47:08

25 this would be the Section 10 complaint that was 03:47:10

Page 99
1 filed by Mr. Robinson. 03:47:13

2 Q. (By Mr. Estey) All right. 03:47:14

3 A. And that, when that complaint was filed, 03:47:15

4 he would have gotten a letter acknowledging the 03:47:17

5 filing of the complaint. 03:47:20

6 Q. Okay. All right. Number 29. 03:47:22

7 MS. HOLM: Okay. 03:48:11

8 (Plaintiffs' Deposition Exhibit 29 was 03:48:11

9 identified.) 03:48:11

10 Q. (By Mr. Estey) Do you recall receiving 03:48:11

11 this email from Susan Lyons dated March 10th, 2014? 03:48:17

12 A. It appears I was copied on this email, 03:48:23

13 yes. 03:48:25

14 Q. Do you recall receiving it and reading it? 03:48:27

15 A. I don't recall receiving it, but I'm sure 03:48:29

16 that I did. I was copied on it. It's my correct 03:48:31

17 email address. 03:48:34

18 Q. All right. Well, it -- it involves 03:48:36

19 investigation of sexual misconduct, right? 03:48:37

20 MS. HOLM: Could I just -- out of fairness 03:48:41

21 to the witness, can we go back to like Exhibits 21, 03:48:43

22 I think it is, and 22, 23 are emails, I believe -- 03:48:46

23 MR. ESTEY: They're probably the same 03:48:53

24 chain. 03:48:54

25 MS. HOLM: They're the same chain, and 03:48:54

Page 100
1 it's just a -- 03:48:55

2 MR. ESTEY: Yeah. I'm -- I'm trying to 03:48:56

3 trick him. Whatever you need to look at. 03:48:57

4 MS. HOLM: Yeah. Go -- go to 22, 22A, and 03:48:59

5 maybe 23, just to make sure you can see them all. 03:49:09

6 Kind of get a chronology of time on the 03:49:27

7 10th. 03:49:30

8 A. Yes. It's -- it's difficult, with so many 03:49:30

9 emails and they're all split up, to get a 03:49:33

10 chronology, but -- 03:49:35

11 Q. (By Mr. Estey) Yeah. And so after 03:49:37

12 looking at all those emails, you -- you have a 03:49:39

13 better recollection of reading those emails? 03:49:41

14 A. I'm going to -- I -- I'm sure that I read 03:49:54

15 them. 03:49:59

16 Q. Okay. And it involved allegations of 03:50:01

17 sexual misconduct, right? 03:50:03

18 A. This looks like the -- this involves 03:50:08

19 Mr. Gitelman, who we've -- who we've been talking 03:50:14

20 speaking about. 03:50:17

21 Q. Right. I mean, and he's alleged to have 03:50:18

22 sexually abused athletes, right? 03:50:20

23 MS. HOLM: That's been asked and answered 03:50:23

24 several times, and I think this witness has 03:50:24

25 acknowledged it. 03:50:26

Page 101
1 MR. ESTEY: Well, I know, but I'm -- 03:50:27

2 I'm -- I do depo clips at trial, and so I need to 03:50:27

3 have a clear record. 03:50:31

4 MS. HOLM: Well, but, you know, just 03:50:32

5 because you do depo clips at trial doesn't mean that 03:50:33

6 you get to ask and ask the same question to get an 03:50:37

7 answer that you like better, or whatever it may be, 03:50:37

8 for a clip. 03:50:38

9 MR. ESTEY: I just want to make sure it's 03:50:39

10 clear in case he's not available at trial. 03:50:41

11 MS. HOLM: Well, I think it's very clear 03:50:44

12 what his response has been. 03:50:46

13 MR. ESTEY: All right. 03:50:47

14 MS. HOLM: So, let's not keep -- 03:50:47

15 MR. ESTEY: Well, I'll just read them. 03:50:49

16 Q. (By Mr. Estey) Okay. So, here. 03:50:50

17 Your cc'd in the email from Lyons: Says, 03:50:52

18 "Wow, Ronda, it says deja vu once again." 03:50:52

19 Did you have any idea what she's referring 03:50:57

20 to there? 03:50:59

21 MS. HOLM: Mr. Estey, is your specific 03:51:28

22 question, does this witness know what she meant when 03:51:32

23 she said, "Wow, Ronda, it's just deja vu once 03:51:34

24 again"? 03:51:39

25 MR. ESTEY: Yes. 03:51:39

Page 102
1 MS. HOLM: Okay. Object. Calls for 03:51:40

2 speculation, but... 03:51:41

3 A. I -- I wouldn't know specifically what 03:51:42

4 she's talking about here, but I assume she's talking 03:51:43

5 about the hearing process. 03:51:49

6 Q. (By Mr. Estey) Okay. Well, were you 03:51:51

7 aware of any other allegations against any other 03:51:53

8 coaches for an NGB in which the -- the hearing 03:51:56

9 process was delayed? 03:52:01

10 A. No. 03:52:05

11 Q. Okay. And she goes on, "So very 03:52:07

12 frustrating. It seems like there should be a prompt 03:52:12

13 and straightforward process for investigating a 03:52:15

14 charge of sexual misconduct where people are not 03:52:18

15 intimidated by threats of individual lawsuits and 03:52:21

16 liability, and the guilty," and then parens, "(if so 03:52:27

17 determined)," end parens, "are removed and the 03:52:31

18 innocent protected." 03:52:33

19 Do you recall reading that line, sir, back 03:52:35

20 in 2014? 03:52:37

21 A. I -- I'm sure that I read it. 03:52:38

22 Q. All right. And did you understand what 03:52:41

23 she -- what she was referring to there? 03:52:43

24 A. The hearing process was part of the 03:52:46

25 Section 10 complaint -- 03:52:48

Page 103
1 Q. Okay. 03:52:50

2 A. -- although the hearing process -- 03:52:50

3 processes that were looked into was -- and the 03:52:53

4 allegations were that the election -- the election 03:52:57

5 wasn't taking place because individuals had filed 03:53:01

6 grievances with USA Taekwondo, and those grievances 03:53:04

7 had not been heard, and therefore, there was no 03:53:08

8 election that had taken place. 03:53:12

9 But there was no allegations in the 03:53:14

10 Section 10 complaint of sexual impropriety by any 03:53:16

11 person. 03:53:20

12 Q. And this email, did you -- did you 03:53:21

13 understand it to be related to this Section 10 03:53:23

14 complaint, or the complaint against Gitelman? 03:53:26

15 A. My understanding that -- well, I don't 03:53:30

16 really know why Ronda sent this email to Susanne 03:53:31

17 Lyons except that she was Chair of the Section 10 03:53:36

18 complaint. 03:53:40

19 MS. HOLM: No. It's Susanne Lyons who 03:53:40

20 sent it to Ronda. 03:53:41

21 THE WITNESS: Oh, I'm sorry. 03:53:44

22 A. No, but I think that -- I believe that 03:53:46

23 Ronda sent the initial email to Ms. Lyons. 03:53:47

24 MS. HOLM: Right. It's down at the bottom 03:53:52

25 of the page. 03:53:54

Page 104
1 THE WITNESS: Yes. 03:53:55

2 Q. (By Mr. Estey) All right. Did you take 03:53:55

3 any action after receiving this email? 03:53:56

4 A. I may have forwarded it on to Malia 03:54:00

5 Arrington. I don't recall. 03:54:02

6 Q. All right. Have you ever heard of a 03:54:08

7 athlete by the name of Christine Poe. 03:54:19

8 A. I believe I've heard of that name. 03:54:23

9 Q. In what context? 03:54:26

10 A. I believe she's a Taekwondo athlete, but 03:54:27

11 I'm not sure. 03:54:29

12 Q. Did she ever make allegations that she'd 03:54:30

13 been sexually abused while a member of USA 03:54:33

14 Taekwondo, to your knowledge? 03:54:35

15 A. Make allegations to Taekwondo. 03:54:46

16 MR. ESTEY: Can I have the question -- 03:54:46

17 A. I -- I -- I don't -- I don't recollect 03:54:46

18 knowing about any allegation that Ms. Poe made. 03:54:49

19 Q. (By Mr. Estey) Not at all? 03:54:52

20 A. No. 03:54:54

21 Q. Okay. Do you have any responsibility for 03:54:54

22 press releases here at USOC? 03:55:00

23 A. I do not. 03:55:03

24 Q. Do athletes receive a monthly stipend from 03:55:13

25 the USOC? 03:55:16

Page 105
1 A. The USOC has a stipend program. 03:55:20

2 Q. Tell me about that. 03:55:23

3 A. Each National Governing Body may designate 03:55:26

4 certain athletes that they feel are high performers 03:55:29

5 that would be eligible to compete in the Olympic, 03:55:35

6 Pan American or Paralympic Games, and the USOC may 03:55:37

7 monies to those designated athletes. 03:55:44

8 Q. Okay. 03:55:47

9 A. Or monies for those designated athletes. 03:55:47

10 Q. All right. And the USOC also provides 03:55:53

11 access to its training centers for high performing 03:55:56

12 athletes, right? 03:56:02

13 A. It provides access to the National 03:56:04

14 Governing Bodies. 03:56:05

15 So, a National Governing Body -- my 03:56:08

16 understanding is that a National Governing Body will 03:56:10

17 submit a request to the USOC, the USOC will consider 03:56:14

18 that request, depending upon availability, depending 03:56:19

19 upon the program, depending upon the level of the 03:56:22

20 athletes, it may request that request or not. 03:56:24

21 Q. When -- when USOC use -- uses the term 03:56:29

22 "Team USA," what is it referring to? 03:56:31

23 A. That's a branding terminology. 03:56:37

24 Q. And what do you mean by that? 03:56:40

25 A. It's intellectually protected. 03:56:43

Page 106
1 Q. All right. Who is included in Team USA? 03:56:45

2 MS. HOLM: Go ahead. 03:56:53

3 A. It's a way to describe the United States 03:56:58

4 Olympic Committee. 03:57:03

5 If you're asking me if specific athletes 03:57:04

6 are included, I don't know if specific athletes are 03:57:06

7 included, but certainly Team USA would be the team 03:57:10

8 that go to the games. 03:57:13

9 Q. So, USOC's team of athletes that go to the 03:57:16

10 Olympic games, correct? 03:57:20

11 A. The -- actually, it's the United States 03:57:22

12 Team. It's a U.S. team. We submit the names to the 03:57:24

13 International Olympic Committee upon recommendation 03:57:29

14 from the National Governing Bodies. 03:57:33

15 Q. All right. And they go under the auspices 03:57:35

16 of Team USA, right? 03:57:36

17 A. Well, they go under the auspices of the 03:57:39

18 U.S. Team. 03:57:43

19 Q. All right. And who owns the trademark to 03:57:43

20 the Team USA? 03:57:45

21 A. My understanding is the USOC does. 03:57:46

22 Q. All right. I'm going to take a look at my 03:58:16

23 notes, but I think I'm pretty much done. 03:58:18

24 I'm going to turn over to my co-counsel. 03:58:22

25 EXAMINATION 03:58:24

Page 107
1 BY MR. LITTLE: 03:58:25

2 Q. Do you know a gentleman, Dale Neuberger? 03:58:27

3 A. I do know Dale Neuberger. 03:58:49

4 Q. Okay. And have -- has the USOC, to your 03:58:54

5 knowledge, does any SafeSport consulting with Dale 03:58:57

6 Neuberger? 03:59:00

7 A. I don't know. 03:59:03

8 Q. Has USA Bobsled? 03:59:04

9 A. I don't know. 03:59:07

10 Q. Has U.S. -- same question regarding TSE 03:59:07

11 Sports Consulting? 03:59:10

12 A. I don't know. 03:59:11

13 Q. Did -- when did you start working at the 03:59:14

14 USOC? 03:59:25

15 A. In 1999. 03:59:26

16 Q. Do you know a gentleman, David -- just a 03:59:27

17 second -- David Mair? M-A-I-R. M-A-I-R. 03:59:37

18 A. Yes, I know -- I did know David Mair. I 03:59:46

19 haven't spoken with him for many years. 03:59:50

20 Q. Okay. What was his role at the USOC? 03:59:53

21 A. I believe he was Risk Manager. 03:59:56

22 Q. Okay. And, in fact, by 1999, the USOC 03:59:57

23 required each NGB to have specific sexual abuse 04:00:01

24 insurance coverage -- covering coaches who sexually 04:00:05

25 abused athletes, isn't that true? 04:00:09

Page 108
1 A. I -- I -- I don't know. 04:00:11

2 Q. Okay. As soon as I get this to print, 04:00:13

3 I'll show you. We'll go through that. 04:00:16

4 And we talked earlier about the training 04:00:23

5 center in Marquette, Michigan. Is the training 04:00:25

6 center in Marquette, Michigan a U.S. Olympic 04:00:29

7 Training Center? 04:00:34

8 A. No. 04:00:35

9 Q. What is it? 04:00:35

10 A. Are you talking about -- I'm not sure what 04:00:37

11 you mean by "Marquette." 04:00:40

12 Q. I went to Marquette, Michigan. 04:00:41

13 A. Marquette -- Marquette University? 04:00:43

14 What -- 04:00:43

15 Q. I went to Marquette, Michigan this summer 04:00:44

16 with my family for vacation. I went to Northern 04:00:47

17 Michigan University, and saw two dorms with the USOC 04:00:51

18 sign out in front that said U.S. Olympic Training 04:00:53

19 Center, Marquette, Michigan. Is there a US Olympic 04:00:56

20 Training Center in Marquette, Michigan? 04:00:56

21 A. There is not. 04:00:59

22 Q. Okay. And so do you have any idea why, 04:01:00

23 apparently, the University of Northern Michigan is 04:01:05

24 using the trademarks for the Olympics? 04:01:10

25 A. At one time, it might have been a training 04:01:13

Page 109
1 site. I don't know if it still is. 04:01:15

2 Q. Okay. When was it a training site? 04:01:18

3 A. I -- I don't know for sure. 04:01:22

4 Q. Okay. Do you know if, currently, U.S. -- 04:01:24

5 well, let's go back to 2014. 04:01:30

6 In 2014, did any Winter Olympians train at 04:01:33

7 the Marquette Training Center? 04:01:37

8 A. I wouldn't know. 04:01:39

9 Q. Okay. What is the USC -- USOC's role in 04:01:42

10 the Olympic Training Center in Marquette, Michigan? 04:01:45

11 A. Well, it's not a center. 04:01:50

12 Q. Training site in Marquette, Michigan. 04:01:51

13 A. I don't know if it has any role there. 04:01:54

14 Q. Okay. Does it provide any funding to the 04:01:56

15 training center in Marquette -- training cite in 04:01:58

16 Marquette, Michigan? 04:01:59

17 A. I -- I -- I just don't know, and I don't 04:02:01

18 know if it's a training site any longer. It's -- 04:02:02

19 I -- I'm just -- I'm not -- I just don't know. 04:02:04

20 Q. Okay. Are you aware of any rapes that 04:02:10

21 have occurred -- rapes of minor female athletes at 04:02:12

22 the U.S. Olympic Training Site in Marquette, 04:02:16

23 Michigan, from 1988 to the present? 04:02:20

24 A. I'm not aware of any rapes, or if I ever 04:02:23

25 was aware, I certainly don't recollect it here 04:02:27

Page 110
1 today. 04:02:30

2 Q. Do you know who Andy Gabel is? 04:02:30

3 A. I do. 04:02:33

4 Q. Okay. And how do you know Andy Gabel? 04:02:33

5 A. I wouldn't say that I know him. I know 04:02:35

6 that he was associated with U.S. Speedskating. 04:02:37

7 Q. He was a Board member of U.S.A. 04:02:41

8 Speedskating, correct? 04:02:42

9 A. I'm not sure what his position was. 04:02:43

10 Q. He was a USOC Board member, isn't that 04:02:43

11 correct? 04:02:47

12 A. I don't know. 04:02:47

13 Q. He was on the organizing committee for the 04:02:48

14 Salt Lake City Games, isn't that correct? 04:02:51

15 A. I don't know. 04:02:51

16 Q. Okay. Are you aware of any minor female 04:02:53

17 athletes accusing Andy Gabel of molesting them? 04:02:56

18 A. I have heard of that. 04:03:01

19 Q. Did you happen to see any articles in the 04:03:04

20 Chicago Tribune in March of 2013 where minor female 04:03:06

21 athletes accused Andy Gabel of molesting them? 04:03:11

22 A. I don't recollect if I ever saw any 04:03:15

23 articles with regard to that or not. 04:03:15

24 Q. Okay. Do you know if the USOC asked 04:03:16

25 Sidley Austin to -- are you familiar with law firm 04:03:19

Page 111
1 Sidley Austin? 04:03:22

2 A. I am. 04:03:24

3 Q. Okay. Has Sidley Austin ever conducted 04:03:24

4 investigations into allegations of sexual abuse at 04:03:27

5 the direction of the USOC? 04:03:30

6 MS. HOLM: Well, that's going to call 04:03:33

7 for -- 04:03:34

8 MR. LITTLE: It's a "yes" or "no" 04:03:36

9 question. 04:03:37

10 MS. HOLM: Well, the identity of an 04:03:38

11 attorney doing work on their behalf is, in and of 04:03:38

12 itself, communication that is violative of the 04:03:40

13 attorney-client privilege. 04:03:40

14 MR. LITTLE: So, whether or not Sidley 04:03:44

15 Austin did an investigation at the behest of the 04:03:44

16 USOC, which is absolutely public knowledge, you're 04:03:48

17 claiming attorney-client privilege on? 04:03:48

18 MS. HOLM: Well, I don't know that it's 04:03:51

19 public knowledge. 04:03:52

20 You're pointing to something on your 04:03:53

21 computer, and I'm just putting an objection on the 04:03:55

22 record. 04:03:58

23 Mr. Johansen knows best how he can answer 04:03:58

24 that particular question. Beyond that, when there 04:04:02

25 are communications, I will be, for sure, saying no 04:04:04

Page 112
1 discussion. 04:04:07

2 Q. (By Mr. Little) Do you know if the USOC 04:04:08

3 has ever asked Sidley Austin -- the law firm Sidley 04:04:09

4 Austin to investigate any allegations of sexual 04:04:13

5 abuse in Olympic sport? 04:04:17

6 A. I don't know, and if I ever was aware, I 04:04:20

7 certainly don't recollect it sitting here today. 04:04:21

8 Q. With regard to Andy Gabel specifically, do 04:04:23

9 you know if the USOC asked Sidley Austin to 04:04:26

10 investigate Andy Gabel in 2013? 04:04:29

11 MS. HOLM: I have the same objection, but 04:04:31

12 you can answer. 04:04:32

13 A. My answer is the same. 04:04:33

14 Q. (By Mr. Little) Do you know if Andy 04:04:36

15 Gabel's membership at U.S.A. Speedskating was ever 04:04:37

16 terminated? 04:04:42

17 A. I have heard that his membership was 04:04:42

18 terminated, but I don't really know. 04:04:50

19 Q. Do you know when? 04:04:52

20 A. No. 04:04:53

21 Q. Okay. We're going to take a break. I 04:04:54

22 just need to make a couple of copies real quick. 04:04:56

23 THE VIDEOGRAPHER: Go off the record? 04:04:59

24 MR. LITTLE: Yes, please. 04:05:01

25 THE COURT: We're off the record at 04:05:02

Page 113
1 4:05 p.m. 04:05:03

2 (A recess was taken from 4:05 p.m. to 4:16 04:15:31

3 p.m.) 04:15:31

4 THE VIDEOGRAPHER: Okay. We're back on 04:15:36

5 the record at 4:16 p.m. 04:15:37

6 (Plaintiffs' Deposition Exhibit 30 was 04:15:41

7 identified.) 04:15:41

8 Q. (By Mr. Little) Okay. Mr. Johansen, can 04:15:43

9 you take a minute and take a look at Exhibit 04:15:44

10 Number 30. 04:15:46

11 A. I've taken a quick look at it. 04:16:05

12 Q. Have you ever seen that document before, 04:16:07

13 if you know? 04:16:08

14 A. No. 04:16:09

15 Q. Okay. And you testified earlier you knew 04:16:09

16 who David Mair was, correct? 04:16:12

17 A. Yes. 04:16:14

18 Q. Okay. Now, on -- so, I think that 04:16:15

19 document printed two-sided. I'm reading off my 04:16:20

20 computer, but I think on the second page -- do you 04:16:24

21 know Bill Wolters? 04:16:28

22 A. I do not. 04:16:32

23 Q. Okay. Let's back up a second. 04:16:34

24 Are you familiar with the United States 04:16:35

25 Sports Insurance Corporation? 04:16:38

Page 114
1 A. I am not. 04:16:39

2 Q. Okay. Do you know if the USOC was ever 04:16:40

3 self-insured? 04:16:44

4 A. I do not know. 04:16:46

5 Q. Is it now? 04:16:48

6 A. I -- I don't know. 04:16:50

7 Q. Okay. Do you know who provides the sexual 04:16:51

8 abuse insurance for the United States Olympic 04:16:55

9 Committee, if there is such a policy? 04:16:58

10 A. Could you repeat that question? I think 04:17:04

11 it's -- 04:17:06

12 Q. Yeah -- 04:17:06

13 A. -- compounded. 04:17:06

14 Q. Yeah. It's a compound question. 04:17:07

15 All right. Let's -- let's start with the 04:17:08

16 second page. 04:17:09

17 You see here, it says, "Per USOC directive 04:17:10

18 we need to delete Endorsement Number 10, sexual 04:17:14

19 abuse" -- or "Abuse and Molestation Exclusion." 04:17:18

20 Okay. Do you know what USOC directive is 04:17:24

21 being referred to here? 04:17:27

22 A. I do not. 04:17:28

23 Q. Okay. Next sentence, "They are 04:17:29

24 threatening to cut back on funding and not allow the 04:17:31

25 swim teams the use of the training center." 04:17:35

Page 115
1 Did the USOC have the power to cut back on 04:17:37

2 funding for NGBs? 04:17:44

3 A. I believe I answered that question 04:17:50

4 earlier. We do provide funding for our NGBs and we 04:17:52

5 could cut back on that funding. 04:17:57

6 Q. Okay. And you could restrict access to 04:17:58

7 training centers? 04:18:01

8 A. In relation to? 04:18:04

9 Q. I mean, the USOC has the power to restrict 04:18:06

10 NGBs' access to training centers, correct? 04:18:09

11 MS. HOLM: The Training Center, it says 04:18:12

12 here. 04:18:17

13 A. It's our training center, I suppose we do. 04:18:19

14 But NGBs make applications to have programs at the 04:18:21

15 training center. 04:18:25

16 So, we would either approve or not approve 04:18:26

17 those applications. 04:18:29

18 Q. (By Mr. Little) How many training centers 04:18:30

19 are there currently? 04:18:31

20 A. Two. 04:18:35

21 Q. Which are? 04:18:36

22 A. Lake Placid and Colorado Springs, and -- 04:18:36

23 Q. Okay. And how many -- 04:18:40

24 A. -- and just to be forthcoming, there was 04:18:40

25 also one in Chula Vista. 04:18:44

Page 116
1 Q. Okay. And so what is -- Marquette, 04:18:47

2 Michigan is a training site then, is that correct? 04:18:49

3 A. Correct. 04:18:51

4 Q. Okay. 04:18:52

5 A. That's my understanding. 04:18:53

6 Q. What -- was there a training site in 04:18:55

7 Flagstaff, Arizona up until 2008, if you know? 04:18:58

8 A. I don't know. 04:19:03

9 Q. Okay. Who would know best about the 04:19:04

10 relationship between the USOC and Marquette, 04:19:06

11 Michigan, the training site there? 04:19:09

12 A. I'm not certain. Possibly Alicia 04:19:17

13 McConnell. 04:19:22

14 Q. Okay. Who is she? 04:19:25

15 A. She works at the USOC. 04:19:29

16 Q. Okay. Who's Pat Leo, if you know; the 04:19:33

17 next sentence under the one we were reading? 04:19:38

18 A. What page are we on here again? 04:19:43

19 Q. The same page. The second one. 04:19:45

20 A. I'm sorry. I have not seen her name, if 04:19:50

21 you could -- 04:19:53

22 Q. It -- it -- 04:19:54

23 A. Oh, the first paragraph under the message. 04:19:54

24 I have no idea. 04:19:56

25 Q. Okay. Does the USOC still mandate that 04:19:57

Page 117
1 NGBs have specific sexual abuse and molestation 04:20:05

2 insurance? 04:20:09

3 A. I don't know. 04:20:10

4 Q. Who would be the best person to ask about 04:20:11

5 that? 04:20:13

6 A. Probably the Risk Manager. 04:20:14

7 Q. And who is that? 04:20:16

8 A. It's been a long day. His name escapes me 04:20:20

9 right now. I'm sure it will come to me shortly. 04:20:26

10 Q. You could provide that name to Ms. Holm at 04:20:29

11 a later date? 04:20:33

12 A. Yes. Yes. 04:20:34

13 Q. Okay. Do you know where David Mair is 04:20:35

14 now? 04:20:40

15 A. I have no idea. 04:20:40

16 Q. Okay. And turning to the page titled 04:20:44

17 "USOC Minimum Standards For Liability Insurance." 04:20:47

18 A. I'm sorry. Which page are we on? 04:20:51

19 Q. These would be the -- I'm thinking the 04:20:53

20 last -- the one -- it's maybe the third -- third 04:20:55

21 page from the end. "USOC Minimum Standards For 04:21:00

22 Liability Insurance"? 04:21:03

23 A. Yes. 04:21:04

24 Q. Okay. Did -- do you know what the current 04:21:04

25 USOC Minimum Standards for Liability Insurance are? 04:21:07

Page 118
1 A. I do not. 04:21:12

2 Q. Okay. All right. Now, you said you do 04:21:12

3 work with athlete drug cases? Is that -- did I hear 04:21:28

4 that correctly? 04:21:30

5 COURT REPORTER: Athlete what? 04:21:30

6 MR. LITTLE: Drug cases. Sorry. 04:21:30

7 Performance enhancing drug cases. 04:21:30

8 A. No, I -- I really don't do work with 04:21:41

9 athletes drug cases. Those cases are handled by 04:21:44

10 USADA, United States Anti-Doping Agency. 04:21:46

11 Q. (By Mr. Little) Okay. Who's the lead 04:21:51

12 counsel for USADA? 04:21:52

13 A. Bill Bach. 04:21:53

14 Q. Okay. And who's the president of USADA, 04:21:54

15 if you know? The director? 04:21:56

16 A. I don't know who the president is. 04:21:58

17 Q. Is it Travis Tigert? 04:22:00

18 A. No, Mr. Tigert is CEO is my understanding. 04:22:03

19 Q. Okay. Mr. Tigert's CEO. 04:22:08

20 And what law firm did he work at prior to 04:22:08

21 assuming that position? 04:22:11

22 A. Holmes -- Holmes Robert & Owens. 04:22:12

23 Q. Which is now called Bryan Cave, correct? 04:22:15

24 A. I believe there was a merger, yes. 04:22:18

25 Q. Okay. And what law firm did Scott 04:22:20

Page 119
1 Blackmun work at prior to coming US -- what's Scott 04:22:22

2 Blackmun's position with the USOC? 04:22:25

3 A. He's Chief Executive Officer. 04:22:28

4 Q. Okay. And where did he work prior to that 04:22:30

5 position, if you know? 04:22:33

6 A. Prior to? 04:22:34

7 Q. Prior to becoming CEO of the U.S. Olympic 04:22:35

8 Committee? 04:22:40

9 A. I'm not certain. He -- he -- he also may 04:22:44

10 have been with Holmes Roberts & Owen, but I don't 04:22:46

11 know for sure. 04:22:50

12 Q. Okay. Now, does the USOC require that the 04:22:51

13 members of Team USA register with USADA? 04:22:55

14 A. I don't understand that question. 04:23:01

15 Q. Okay. Are you familiar with the -- 04:23:03

16 that -- do you know if USADA requires athletes to 04:23:05

17 register their physical locations every 72 hours? 04:23:09

18 Do you know if that -- are you familiar with that 04:23:12

19 requirement? 04:23:13

20 A. There's a whereabouts requirement, and -- 04:23:14

21 but your question is -- said that USADA requires it. 04:23:16

22 It would be required under the World Anti-Doping 04:23:21

23 Code. 04:23:22

24 Q. So, WADA requires it, or -- 04:23:23

25 A. That -- that's not my understanding. Not 04:23:26

Page 120
1 WADA, but the World Anti-Doping Code. 04:23:27

2 Q. Okay. So members of Team USA have to 04:23:29

3 comply with the World Anti-Doping Code, correct? 04:23:31

4 A. When you say "Team USA," I'm not sure what 04:23:33

5 you mean by that. 04:23:36

6 But athletes that meet a certain level in 04:23:37

7 terms of their performance, and are -- are most 04:23:41

8 likely -- are or designated by the National 04:23:47

9 Governing Body, would have to file there whereabouts 04:23:49

10 information. 04:23:55

11 Q. Okay. And you -- and the USOC, correct me 04:23:55

12 if I'm wrong, submits to the IOC a list of the 04:23:57

13 athletes to compete in the Olympic Games, correct? 04:24:01

14 A. That's correct. 04:24:05

15 Q. Okay. And the USOC wouldn't submit an 04:24:06

16 athlete's name if that athlete wasn't in compliance 04:24:07

17 with the World Anti-Doping Code, isn't that correct? 04:24:12

18 I hope it's correct. 04:24:16

19 MS. HOLM: I'm not 100 percent sure he's 04:24:18

20 understanding the question. 04:24:18

21 A. When -- when you mean the athlete wasn't 04:24:21

22 in compliance with the anti-doping code, could you 04:24:23

23 explain that? 04:24:24

24 Q. (By Mr. Little) Okay. If an athlete is 04:24:25

25 not in compliance with the World Anti-Doing Code, to 04:24:27

Page 121
1 the best of your knowledge, can they compete in the 04:24:30

2 U.S. Olympic Trials? 04:24:32

3 A. Well, athletes have to submit whereabouts 04:24:35

4 information. If they fail to do that, and the code 04:24:37

5 has provisions indicating how many missed tests or 04:24:40

6 failure to provide their whereabouts information, 04:24:46

7 then United States Anti-Doping Agency for U.S. 04:24:49

8 athletes would bring a case or a complaint against 04:24:53

9 that athlete. 04:24:56

10 Q. Okay. 04:24:57

11 A. And if the athlete has been found to have 04:24:58

12 committed an anti-doping code violation, the athlete 04:25:00

13 would be no longer eligible to compete at the 04:25:04

14 Olympic Games. 04:25:08

15 And I just want to clarify one other 04:25:09

16 thing. 04:25:11

17 Yes, we submit names to the IOC, but 04:25:12

18 it's -- it -- it's probably to the organizing 04:25:14

19 committee. So, it would be the international 04:25:16

20 committee and the organizing committee both. 04:25:17

21 Q. The organizing committee of the local 04:25:20

22 games? 04:25:22

23 A. Yes. So, it would being like Rio 2016. 04:25:23

24 Q. Okay. So -- and when the games were in 04:25:24

25 Salt Lake, the USOC oversaw the local organizing 04:25:25

Page 122
1 committee in Salt Lake, correct? 04:25:28

2 A. No. 04:25:31

3 Q. Who did? 04:25:32

4 A. There was a local organizing committee. 04:25:32

5 Q. Okay. And that local organizing committee 04:25:34

6 was completely independent of the USOC? 04:25:36

7 A. As far as I know, yes. 04:25:39

8 Q. Okay. Were there USOC Board members on 04:25:40

9 the Salt Lake organizing committee? 04:25:43

10 A. I don't -- I don't -- I don't know or 04:25:45

11 don't recall. 04:25:47

12 Q. Okay. And when athletes travel to World 04:25:48

13 Championship, pan Am games, and Olympic Games, they 04:25:52

14 have to wear clothing that -- that is approved by 04:25:56

15 the USOC, isn't that correct? 04:26:01

16 MS. HOLM: Is that correct? 04:26:06

17 A. I don't want to be too lawyerly here, but 04:26:12

18 during -- during the medal ceremonies, yes. 04:26:16

19 Q. And when they're competing in their event, 04:26:20

20 correct? 04:26:21

21 A. They would wear their National Governing 04:26:22

22 Body uniform. 04:26:24

23 Q. Okay. And -- and the sponsored logo on 04:26:28

24 that uniform has to be a USOC-approved sponsor, 04:26:30

25 correct? 04:26:34

Page 123
1 A. No. Not -- not -- not during the 04:26:35

2 competition. 04:26:38

3 Q. Okay. So -- 04:26:40

4 A. That would -- that could be an NGB 04:26:41

5 sponsor. 04:26:42

6 Q. So could a track and field athlete, for 04:26:43

7 example, wear an Oiselle, or a New Balance, or 04:26:46

8 Brooks uniform in the Olympics Games? 04:26:48

9 A. During the competition, that's my 04:26:53

10 understanding; is that -- it would be the NGB 04:26:57

11 uniform. But not on the medal stand. 04:26:59

12 Q. Okay. So, your -- your testimony -- I 04:27:02

13 just want to make sure that this is accurate. 04:27:03

14 You -- you believe that athletes in 04:27:05

15 competition can wear non-USOC approved uniforms? 04:27:06

16 A. That's my understanding, but this -- this 04:27:16

17 really isn't my area, and so I'm not -- I'm not 04:27:18

18 certain about this. 04:27:22

19 Q. Okay. The same question at press 04:27:23

20 conferences. Do athletes have to wear outfits 04:27:25

21 approved by the USOC in the -- like, in Olympic 04:27:32

22 Games press conferences? Does the uniform have to 04:27:37

23 be approved by the USOC? 04:27:40

24 A. They're -- they're requested to wear USOC 04:27:42

25 apparel. 04:27:43

Page 124
1 Q. Okay. In fact, USOC requested that they 04:27:44

2 pack nothing but USOC apparel for their trip to Rio 04:27:47

3 in 2016, and the 2015 Track and Field World 04:27:52

4 Championships, isn't that right? 04:27:55

5 A. I don't know that's -- I don't have -- I 04:27:58

6 don't -- I don't know about that. 04:27:58

7 Q. Including their underwear, right? All the 04:27:59

8 way down to their underwear and sports bras? 04:28:01

9 A. I wouldn't know about that. 04:28:04

10 Q. Okay. 04:28:07

11 MR. LITTLE: What's the exhibit that was 04:28:14

12 the arbitration? 04:28:15

13 MR. ESTEY: From this morning? 04:28:21

14 MR. LITTLE: The one we were asking him 04:28:21

15 about earlier. 04:28:23

16 MR. OKAMURA: 20. 04:28:31

17 MR. LITTLE: Okay. Can I see your copy? 04:28:32

18 MR. OKAMURA: Yeah. 04:28:32

19 Q. (By Mr. Little) Can you take a look at 04:28:32

20 Exhibit 20. 04:28:33

21 Charlotte Craig is -- is listed as a 04:28:51

22 party. Do you see that? An affected party? 04:28:54

23 A. Yes. 04:28:56

24 Q. Can you tell me who Charlotte Craig is? 04:28:57

25 A. She's a Taekwondo athlete. 04:29:00

Page 125
1 Q. Okay. Now, do you know if she was an 04:29:02

2 Olympian in 2008? 04:29:04

3 A. I do not know. 04:29:07

4 Q. Okay. 04:29:09

5 A. Or if I did know, I don't recollect at 04:29:09

6 this time. 04:29:11

7 Q. Have you heard any sexual abuse 04:29:11

8 allegations pertaining to Charlotte Craig? 04:29:14

9 A. I don't recall knowing of any sexual abuse 04:29:18

10 allegations against her. 04:29:21

11 Q. Okay. So, turning back to 2008, do you 04:29:22

12 recall, in 2008, how the athletes went from the 04:29:26

13 United States to China? Physically, how they 04:29:30

14 traveled. Do you know? 04:29:33

15 A. By airplane. 04:29:36

16 Q. Okay. Did the USOC book that airplane, or 04:29:38

17 charter that flight, do you know? 04:29:41

18 A. I believe so. 04:29:44

19 Q. Okay. And do you know if, on that 04:29:45

20 flight -- do you know how old Charlotte Craig was in 04:29:46

21 2008? 04:29:50

22 A. I do not. 04:29:51

23 Q. Do you know if she performed fellatio on 04:29:51

24 the Olympic -- on Steven Lopez on that flight? 04:29:54

25 A. I do not. 04:29:57

Page 126
1 Q. How about Jean Lopez? 04:29:58

2 A. I do not know that. 04:29:58

3 Q. Okay. Okay. This arbitra- -- this 04:30:02

4 arbitration decision is signed by Lawrence A. 04:30:12

5 Saichek? Is that right? Is that -- is that how you 04:30:16

6 say his last name? 04:30:23

7 A. I believe -- well, I would read this 04:30:25

8 Lawrence A. Saichek, but... 04:30:27

9 Q. Thank you. Okay. 04:30:29

10 Did you do -- have you ever been a 04:30:30

11 party -- or not a party. Have you ever participated 04:30:31

12 in any other -- or listened in on any other 04:30:34

13 arbitrations conducted by -- by him? 04:30:38

14 A. Possibly, but I -- I -- I don't recall. 04:30:40

15 Q. Okay. Now, the arbitrators for these 04:30:43

16 arbitrations, they -- they're not -- they come from 04:30:48

17 a limited pool of arbitrators, isn't that correct? 04:30:53

18 A. I do not believe that's correct. 04:30:57

19 Q. So, do they not come from the AAA office, 04:30:59

20 or do they not come from an office from Fresno, 04:31:01

21 California? 04:31:04

22 A. They're AAA Arbitrators; American 04:31:06

23 Arbitration Association of Arbitrators. 04:31:07

24 Q. Right. And if I wanted to schedule an 04:31:09

25 arbitration, do I -- I call an office in Fresno, 04:31:11

Page 127
1 correct? 04:31:14

2 A. Correct. 04:31:15

3 Q. Okay. And -- 04:31:16

4 A. Well, you -- you would file a complaint. 04:31:17

5 Q. Right. In -- to this Fresno office, 04:31:18

6 right? 04:31:21

7 A. Yes. I believe you could file it anywhere 04:31:22

8 and it would be directed to the Fresno office. 04:31:24

9 Q. Okay. And the arbitrators assigned to 04:31:26

10 hear the complaint, that's not every AAA arbitrator 04:31:29

11 in the United States, is it? 04:31:32

12 MS. HOLM: If you know. 04:31:36

13 A. I'm not certain. I -- I believe that any 04:31:42

14 arbitrator -- well, the American Arbitration 04:31:46

15 Association has certain arbitrators that do 04:31:48

16 commericial matters, they do real estate matters, 04:31:52

17 they can do construction matters, but my 04:31:55

18 understanding is there's no set pool of arbitrators 04:31:57

19 that the AAA has that only hears sports matters. 04:32:01

20 Q. (By Mr. Little) Okay. Do you know what 04:32:06

21 Lawrence's -- what Mr. -- how do you say it again? 04:32:10

22 Saichek? 04:32:14

23 A. I'd say Saichek. 04:32:15

24 Q. Do you know what he's doing today? 04:32:16

25 A. I do not know. 04:32:18

Page 128
1 Q. Do you know if he's deceased? 04:32:19

2 A. I do not know. 04:32:21

3 Q. Okay. Mr. John Ruger, his name's come up 04:32:23

4 a couple of times, what happened to his emails? If 04:32:37

5 I wanted to get Mr. Ruger's emails, where would I -- 04:32:39

6 I mean, who has them now? 04:32:44

7 Like, when -- when he left his office, I 04:32:49

8 assume he was working on a variety of things. What 04:32:51

9 happened to those files and emails? 04:32:53

10 A. I don't know. You'd have to talk to 04:32:56

11 Information Technology Department. 04:32:58

12 Q. Okay. And does the USOC maintain its own 04:33:00

13 servers, if you know? 04:33:04

14 A. I don't know. 04:33:05

15 Q. Okay. Is that something that you could 04:33:06

16 search for and get to your counsel if I sent a 04:33:10

17 request for Mr. Ruger's communications concerning 04:33:14

18 Mark Gitelman? 04:33:17

19 A. I don't think the request should go to me. 04:33:19

20 Q. Who should I direct it to? 04:33:22

21 MS. HOLM: I think he said the IT 04:33:24

22 Department. 04:33:26

23 Q. (By Mr. Little) Okay. The IT. 04:33:26

24 And who is -- who is the IT Department. 04:33:27

25 Or is there a person, or -- 04:33:29

Page 129
1 A. Yes. 04:33:36

2 Q. And what's his or her name? 04:33:38

3 A. Trevor, and my memory is failing me on his 04:33:40

4 last name. 04:33:45

5 Q. Okay. Maybe when you go through your 04:33:46

6 deposition, you could add his name and the Risk 04:33:49

7 Management guy's name to the errata sheet? That 04:33:52

8 would probably be best. 04:33:56

9 MS. HOLM: Well, if he remembers when he's 04:33:58

10 going through, okay. I'm sure we can find this out 04:34:00

11 for you. 04:34:05

12 Q. (By Mr. Little) Is Glenn Merry the CEO of 04:34:05

13 USA Rowing, if you know? 04:34:06

14 A. He's the CEO Executive Director. 04:34:08

15 Q. Okay. Was Ms. Lyon on that same 04:34:10

16 five-person advisory committees as Mr. Merry? 04:34:13

17 A. No. 04:34:17

18 Q. Do you remember who from the USOC was on 04:34:18

19 that committee? 04:34:21

20 A. I don't recall that there was anyone from 04:34:22

21 the USOC on the committee. 04:34:23

22 Q. Okay. Did the USOC suggest the Board 04:34:25

23 members for that committee, or suggest the members 04:34:28

24 of that committee to USA Taekwondo, rather? 04:34:29

25 A. The hearing panel recommended Mr. Merry be 04:34:33

Page 130
1 on the committee, or he volunteered to be on the 04:34:36

2 committee. 04:34:39

3 Q. Sarah Conrad, she's an athlete, correct? 04:34:42

4 A. That's correct. Or -- 04:34:46

5 Q. What sport -- 04:34:47

6 A. -- she was an -- was an athlete. 04:34:48

7 Q. What sport? 04:34:50

8 A. Biathlon? 04:34:50

9 Q. Biathlon. 04:34:51

10 Where is she working at now, if you know? 04:34:51

11 A. I believe she's in Wyoming. 04:34:54

12 Q. Did she ever work for the USOC? 04:34:56

13 A. Not to my knowledge. 04:34:58

14 Q. Oh, you mentioned other Section 9 04:35:09

15 complaints involving sexual abuse. Where are those 04:35:13

16 decisions posted at? 04:35:15

17 A. Section 9 complaints -- 04:35:19

18 Q. Yes. 04:35:20

19 A. -- are posted on the USOC website. 04:35:21

20 Q. Okay. So, which -- which decisions 04:35:25

21 involved sexual abuse? Which Section 9 complaints 04:35:27

22 involve sexual abuse? 04:35:29

23 A. I recall a speedskating case. 04:35:31

24 Q. Okay. Do you remember the -- the 04:35:32

25 gentleman's name or the complainant's name? 04:35:33

Page 131
1 A. I do not. 04:35:37

2 Q. Okay. Do you remember any others? 04:35:38

3 A. No. 04:35:39

4 Q. Can you give me an approximate time on the 04:35:39

5 speedskating case? 04:35:43

6 A. It was within the last four or five years. 04:35:46

7 That's a guess. 04:35:48

8 Q. Was it -- was Andy Gabel involved in that 04:35:49

9 case? 04:35:52

10 A. No. 04:35:53

11 Q. Mike Crow? 04:35:54

12 A. No. 04:35:54

13 Q. Are you familiar with the name Mike Crow? 04:35:55

14 A. No. 04:35:59

15 Q. Any other cases at all besides that 04:36:05

16 speedskating one that you remember? 04:36:08

17 A. I don't -- I don't recollect any other 04:36:10

18 ones. 04:36:11

19 Q. Okay. Besides paying a stipend to some 04:36:14

20 athletes, the USOC also provides college tuition 04:36:39

21 assistance, correct? 04:36:43

22 A. I believe that's a new program that the 04:36:47

23 USOC provides. I know there that -- I -- I know 04:36:49

24 that there's a program to provide educational 04:36:51

25 benefits for athletes. At least that's my 04:36:54

Page 132
1 understanding. 04:36:56

2 Q. And that program was in place as -- as 04:36:56

3 early as 2010, correct? 04:36:58

4 A. That, I don't know. 04:37:00

5 Q. Okay. Does the USOC in any way -- 04:37:01

6 actually, strike that. I'm -- I'm done. 04:37:10

7 MR. ESTEY: Yeah. I have no questions. 04:37:14

8 MS. HOLM: Well, better get Steve in here 04:37:16

9 to see if he's thought about anything. 04:37:18

10 THE VIDEOGRAPHER: Do you want to stay on 04:37:21

11 the record or go off? 04:37:22

12 MR. LITTLE: You can go off. 04:37:23

13 THE VIDEOGRAPHER: We're off the record at 04:37:23

14 4:38 p.m. 04:37:24

15 (A recess was taken from 4:38 p.m. to 4:38 04:37:26

16 p.m.) 04:37:26

17 THE VIDEOGRAPHER: We're back on the 04:37:26

18 record at 4:38 p.m. 04:37:54

19 Q. (By Mr. Little) All right. I just got 04:37:57

20 some names I wanted to ask you about. 04:37:58

21 Dave Lubs, L-U-B-S. Does that name from 04:38:01

22 the USOC ring a bell? 04:38:04

23 A. Does not sound familiar. 04:38:06

24 Q. Okay. Do you know who preceded you as -- 04:38:08

25 in your role with the USOC? 04:38:14

Page 133
1 A. I do not. 04:38:19

2 Q. Does the name Kleinschmidt -- no -- 04:38:21

3 unfortunately, no first name. 04:38:30

4 Does that name ring a bell with you at the 04:38:33

5 USOC? 04:38:37

6 A. It does not. 04:38:38

7 Q. Okay. Okay. And -- and just going back 04:38:42

8 to Marquette, did the USOC maintain a residence 04:38:54

9 program at Marquette, Michigan -- in Marquette, 04:38:58

10 Michigan? 04:39:00

11 A. I don't believe so, no. 04:39:05

12 Q. Okay. Does the name R. Thomas Peters, as 04:39:06

13 an USOC attorney, does that name ring a bell to you? 04:39:18

14 A. No. 04:39:22

15 Q. Robert Harmon? 04:39:23

16 A. No, I don't -- I -- I don't recognize that 04:39:26

17 name. 04:39:29

18 Q. Victor Waduke? 04:39:32

19 A. I don't recognize that name. 04:39:35

20 Q. All right. I'm done. Thank you. 04:39:41

21 MR. ESTEY: Same stips? 04:39:45

22 MS. HOLM: Well, I actually have a 04:39:46

23 question. 04:39:47

24 MR. ESTEY: Good for you. 04:39:47

25 MS. HOLM: It's shocking, I know. 04:39:48

Page 134
1 EXAMINATION 04:39:50

2 BY MS. HOLM: 04:39:50

3 Q. Mr. Johansen, Mr. -- Steve, asked you some 04:39:50

4 questions about Exhibit 26, the NGB Best Practices 04:40:01

5 Seminar that was held on November 7th, 2012. 04:40:06

6 Could you just tell us what are these NGB 04:40:10

7 Best Practices Seminars? 04:40:13

8 A. Well, the USOC held these a number of 04:40:17

9 times, but I can't recall how often, in which they 04:40:23

10 were just what it says. National Governing Bodies 04:40:27

11 could send representatives to these seminars, and -- 04:40:30

12 and various topics would be discussed. Usually, 04:40:33

13 we'd try to, you know, put together panels to 04:40:37

14 provide information to the National Governing 04:40:40

15 Bodies. 04:40:41

16 Q. Okay. And so in term of the attendees for 04:40:43

17 the seminars, they would be typically from, some or 04:40:47

18 all, of the NGBs? 04:40:53

19 A. Yes. 04:40:55

20 Q. Okay. And a -- a -- some sort of brochure 04:40:55

21 would be sent out, or some notification to the NGBs 04:41:00

22 that there was going to be a Best Practices Seminar 04:41:04

23 for them to decide if they wanted to send 04:41:07

24 somebody? 04:41:11

25 A. Yes. I don't know it would have been a 04:41:11

Page 135
1 brochure, but there would have been some notice; 04:41:13

2 probably eventually there would have been an agenda 04:41:16

3 like this that would have been sent out. 04:41:18

4 Q. Okay. So, prior to the seminar, they 04:41:19

5 would have information about what the subject matter 04:41:20

6 would be that would be covered for that particular 04:41:23

7 seminar, is that correct? 04:41:24

8 A. Yes. I -- I think that's correct. 04:41:27

9 Q. Okay. So, you did the -- you moderated 04:41:28

10 the Legal Arbitrations, Understanding the Process 04:41:30

11 Seminar at 8:45 to 9:45 on Thursday, November 8th, 04:41:34

12 correct? 04:41:39

13 A. Correct. 04:41:40

14 Q. And then it appears on Friday, 04:41:40

15 November 9th, 2012, from 8:00 to 8:45, there was a 04:41:42

16 SafeSport -- Implementing SafeSport seminar topic 04:41:47

17 that was moderated by Malia Arrington, is that 04:41:54

18 correct? 04:41:57

19 A. Yes. That's what the document states. 04:41:57

20 Q. Okay. And then it appears a bunch of 04:41:59

21 documents were apparently made available to 04:42:02

22 attendees if they went to this seminar regarding 04:42:06

23 policies from USA Gymnastics, USA Hockey, SafeSport 04:42:10

24 Program poster, and USA Swimming as part of that 04:42:14

25 agenda. 04:42:20

Page 136
1 A. It appears that's correct. 04:42:21

2 Q. Did you have, to your knowledge, any part 04:42:23

3 of presenting any material to the NGB attendees in 04:42:26

4 2012 concerning the SafeSport implementation? 04:42:32

5 A. Not to my -- not to my recollection. 04:42:35

6 Q. Okay. I don't have other questions. 04:42:37

7 Just? 04:42:42

8 MR. LITTLE: I -- I just got one, because 04:42:43

9 I -- I want to get something done before the 04:42:43

10 transcript will come. 04:42:46

11 EXAMINATION 04:42:48

12 BY MR. LITTLE: 04:42:48

13 Q. You said -- you said athletes were 04:42:48

14 required to, you know, register and maintain their 04:42:52

15 location with world -- and -- and -- and I don't 04:42:55

16 have the rest of it. With the? 04:42:57

17 A. The World -- the World Anti-Doping Code 04:43:01

18 requires that athletes provide whereabouts location. 04:43:04

19 Q. Okay. And is that submitted to WADA in 04:43:09

20 Montreal; that -- that organization that keeps track 04:43:11

21 of that? 04:43:14

22 A. You know, I'm not certain. I -- I -- I -- 04:43:15

23 I'm not certain. I -- I -- I -- it may be submitted 04:43:16

24 to USADA or WADA, I'm not sure. 04:43:19

25 Q. Okay. 04:43:24

Page 137
1 A. For US athletes. 04:43:24

2 Q. That's it. Thank you. 04:43:27

3 MR. ESTEY: Same stip. 04:43:29

4 MS. HOLM: Same stip. 04:43:31

5 MR. LITTLE: Yeah. 04:43:35

6 MR. ESTEY: All right. 04:43:35

7 THE VIDEOGRAPHER: This is the end of 04:43:37

8 Media Unit 2 in the deposition of Gary Johansen. 04:43:37

9 We're off the record at 4:44 p.m. 04:43:39

10 (WHEREUPON, the within proceedings were 04:43:43

11 concluded at the approximate hour of 4:44 p.m. on 04:43:43

12 the 27th day of September, 2016.) 04:43:43

13 06:23:20

14 06:23:20

15 06:23:20

16

17

18

19

20

21

22

23

24

25

Page 138
1 I, GARY JOHANSEN, hereby certify that I 10:58:11

2 have read the foregoing transcript and that the same 10:58:11

3 and accompanying corrections sheets, if any, 10:58:11

4 constitute a true and complete record of my 10:58:11

5 testimony. 10:58:11

6 I have ( ) have not ( ) made corrections 10:58:11

7 on the attached correction sheet. 10:58:11

8 10:58:11

9 10:58:11

10 10:58:11

________________________________
11 GARY JOHANSEN 10:58:11

12 10:58:11

13 Subscribed and sworn to before me this 10:58:11

14 _______ day of _______________, 2016. 10:58:11

15 My Commission expires ____________________ 10:58:11

16 10:58:11

17 10:58:11

________________________________
18 Notary Public 10:58:11

19 10:58:11

20 Address: ________________________________ 10:58:11

21 10:58:11

________________________________
22 10:58:11

23

24

25

Page 139
1 REPORTER'S CERTIFICATE 10:58:11

2 10:58:11

3 STATE OF COLORADO ) 10:58:11

)
4 COUNTY OF EL PASO ) 10:58:11

5 I, KAREN J. HATHCOCK, a Registered Merit 10:58:11

6 Reporter, Registered Professional Reporter and 10:58:11

7 Notary Public, State of Colorado, do hereby certify: 10:58:11

8 That the foregoing proceedings were taken 10:58:11

9 before me at the time and place herein set forth; 10:58:11

10 that any witnesses in the foregoing proceedings, 10:58:11

11 prior to testifying, were place under oath; that a 10:58:11

12 verbatim record of the proceedings was made by me 10:58:11

13 using machine shorthand which was thereafter 10:58:11

14 transcribed under my direction; further, that the 10:58:11

15 foregoing is an accurate transcription thereof. 10:58:11

16 10:58:11

17 10:58:11

18 Dated: This 10th day of October, 2016, at Colorado 10:58:11

19 Springs, Colorado. 10:58:11

20 10:58:11

21 10:58:11

22 _________________________________ 10:58:11

Karen J. Hathcock
23 006677 10:58:11

24

25
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