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Post by Deleted on Oct 11, 2019 10:49:17 GMT -5
DOCKET 171 - Exhibit 1 Case: 1:18-cv-01465 Document #: 171-5 Filed: 09/04/19 Page 1 of 37 PageID #:4429 1 IN THE UNITED STATES DISTRICT COURT 2 FOR THE NORTHERN DISTRICT OF ILLINOIS 3 EASTERN DIVISION 4 5 LAURA MULLEN, individually and ) on behalf of all others ) 6 similarly situated, ) ) 7 Plaintiffs, ) ) 8 vs. ) No. 1:18-cv-1465 ) 9 GLV, INC., d/b/a SPORTS ) PERFORMANCE VOLLEYBALL CLUB AND ) 10 GREAT LAKES CENTER, an Illinois ) corporation, RICKY BUTLER, and ) 11 CHERYL BUTLER, an individual, ) ) 12 Defendants. ) 13 14 15 16 The deposition of RICKY BUTLER, taken 17 before Maria S. Winn, CSR, RPR and CRR, pursuant 18 to the Federal Rules of Civil Procedure for the 19 United States District Courts pertaining to the 20 taking of depositions, at Edelson PC, 350 North 21 LaSalle Street, 14th Floor, Chicago, Illinois, 22 commencing at 9:54 a.m. on August 2, 2019. 23 24 Page 1 1 PRESENT: 2 EDELSON PC 3 By MS. SYDNEY JANZEN and MR. ALFRED K. MURRAY 4 350 North LaSalle Street - 14th Floor Chicago, Illinois 60654 5 (312) 589-6370 sjanzen@edelson.com 6 amurray@edelson.com 7 appeared on behalf of the Plaintiffs; 8 9 D'AMBROSE P.C. LAW FIRM 10 By MS. DANIELLE D'AMBROSE 500 North Michigan Avenue - Suite 600 11 Chicago, Illinois 60611 (312) 396-4121 12 Danielle@DambrosePc.com 13 appeared on behalf of the Defendant; 14 15 16 ALSO PRESENT: 17 MS. BARBARA PATEL, Legal Videographer. 18 19 20 21 22 23 24 Page 2 1 Q How long have you been with GLV? 2 A Since 1990. 3 Q Did you found GLV? 4 A Yes. 5 Q In 1990? 6 A Yes. 7 Q Did you have any co-founders? 8 A No. 9 Q Does GLV have any subsidiaries? 10 A You mean d/b/a's? 11 Q Sure. 12 MS. D'AMBROSE: I'm going to object, just 13 to the extent that this calls for a legal 14 opinion. 15 You can answer. 16 A Probably the Great Lakes Center Youth 17 Academy is part of GLV. But it -- no, it's just 18 GLV. I mean -- yeah. I was -- we have no 19 other -- because we don't have -- the Great Lakes 20 Power League, not the GLV, Incorporated. So it's 21 just the Great Lakes... 22 No, the Great Lakes Power League, which 23 is the league we run. It has a different name, 24 but it operates under GLV, Incorporated. Page 14 1 Q And what did that company do? 2 A Some clinics, volleyball camps. We wrote 3 one book, made a couple of videotapes that we 4 sold. And it was just a general volleyball 5 marketing company. 6 Q What was the book you wrote called? 7 A Training for High Performance Volleyball, 8 maybe, something like that. It was, like, 1980 or 9 '81, so it was a paperback. We printed it 10 ourselves and sold it ourselves, so it was an 11 in-house project. So... 12 Q What did you do before that? 13 A I worked for Sports Performance and 14 Rehabilitation Institute, which was a performance 15 training program, who trained athletes. We 16 trained elite-level athletes once they got out -- 17 either they got out of physical therapy from 18 rehabilitation injuries, or we trained elite-level 19 athletes across the board. 20 We trained the U.S. men's volleyball 21 team. We trained lots of -- Walter Payton was 22 there, John McEnroe. So we -- I worked in the 23 area of training athletes, developing athletes. 24 Q And is that also referred to as SPRI, Page 16 1 S-P-R-I? 2 A Yes. 3 Q What was your -- 4 A Before that it was Sports Fitness 5 Institute. 6 Q Okay. 7 A So... 8 Q Thanks. In what years did you work with 9 Sports Fitness Institute or SPRI? 10 A I started working with Sports Fitness 11 Institute in 1979, which was the year I graduated 12 from college. And then Sports Fitness Institute 13 broke off from their partners and went with a 14 group of doctors over in Carol Stream, because 15 Sports Fitness Institute was originally in Glen 16 Ellyn, when I first moved back here from college. 17 And we became partnered with a group of 18 doctors, orthopedic doctors in Carol Stream, and 19 became Sports Performance and Rehabilitation 20 Institute, which was SPRI, and worked with them 21 for two or three years. 22 And then I took a coaching position at 23 Western Michigan University as an assistant 24 volleyball coach. Page 17 1 Q Okay. So when you were coaching at 2 Western Michigan, were you also still working at 3 SPRI? 4 A No. 5 Q What year did you go to work for Western 6 Michigan? 7 A Left -- I left the state in July of 1984, 8 coached with them the '84 collegiate season. And 9 then in 1985, I was a volunteer assistant coach at 10 the University of Southern California in 11 Los Angeles, a volunteer assistant coach. 12 So I coached one year at Western Michigan 13 and then coached a one year at the University of 14 Southern California. 15 Q And what did you do after you coached at 16 the University of Southern California? 17 A Came back to Illinois and returned to 18 Sports Performance Volleyball and training 19 publications. 20 Q What was your title or role at SPRI? 21 A SPRI, the company? You mean in the early 22 '80s? 23 Q Sure. 24 A I guess you would say performance Page 18 1 every kid has had a chance to play, but it might 2 not be the level that you want to play at, because 3 your -- your skill set or your physical set might 4 not get you at that level. 5 Because it's -- regardless, you have to 6 be athletic and you have to be physical. 7 Otherwise, there's going to be a lot of doors that 8 close for you at a pretty young age, as far as 9 going to play at the next level. 10 Q Okay. So in all of that, that you 11 discuss with the parents at that meeting every 12 year, do you ever discuss the allegations of 13 sexual abuse against you? 14 A No. 15 MS. D'AMBROSE: I object to scope. 16 THE WITNESS: Sorry. 17 BY MS. JANZEN: 18 Q Do you ever tell parents at that meeting 19 that the allegations of sexual abuse against you 20 are, in fact, true? 21 MS. D'AMBROSE: I object to scope. 22 A No. 23 BY MS. JANZEN: 24 Q Okay. So you mentioned that you Page 35 1 BY MS. JANZEN: 2 Q Have you stopped offering any programs 3 over the last few years? 4 MS. D'AMBROSE: I object to scope. 5 A Stopped? Not that I know of. 6 BY MS. JANZEN: 7 Q How long have you been responsible for 8 managing the business operations of GLV? 9 A Since 1990. 10 Q In paragraph 2 it also says: 11 "I was formerly a director of the Sports 12 Performance Volleyball Club." 13 How long did you serve in the role of 14 director? 15 A Since it was founded in 1982, I guess. 16 1982. 17 Q Until when? 18 A Until probably 2018. 19 Q When -- why did you stop? 20 A Because -- 21 MS. D'AMBROSE: I object to scope. 22 A -- the harassment of our kids and our 23 employees and our organization, it didn't -- it 24 didn't benefit anybody to have my name on the Page 66 1 go over budgeting, that kind of stuff. So... 2 BY MS. JANZEN: 3 Q At any of the meetings that you've 4 attended, whether you're running it or not, 5 have -- are any topics, other than what is listed 6 here in paragraph 7 and what you've already 7 discussed today, discussed in the parent meeting? 8 MS. D'AMBROSE: I object to form and 9 foundation. 10 A We always ask if anybody has any 11 questions, so we're always open to questions. I 12 mean... 13 BY MS. JANZEN: 14 Q Okay. At any point during this meeting, 15 at any meeting you've ever attended or run, did 16 you ever discuss the allegations of sexual abuse 17 made against you? 18 MS. D'AMBROSE: I object to form, 19 foundation, and scope. 20 A No. 21 BY MS. JANZEN: 22 Q At any point, at any of the meetings 23 you've ever attended or run, did you ever state 24 that the allegations of sexual abuse against you Page 73 1 BY MS. JANZEN: 2 Q Okay. At any point during your 3 conversations with Ms. Mullen regarding her 4 decision whether to send to Sports Performance 5 in 2013, did you discuss the allegations of sexual 6 abuse against you? 7 MS. D'AMBROSE: I object to form, 8 foundation, and scope. 9 A No. 10 BY MS. JANZEN: 11 Q At any point during your conversations 12 with Ms. Mullen regarding her decision whether to 13 send to Sports Performance in 2013, did you 14 ever state that the allegations of sexual abuse 15 against you were, in fact, true? 16 MS. D'AMBROSE: I object to form, 17 foundation, and scope. 18 A No. 19 BY MS. JANZEN: 20 Q At any point during your conversations 21 with Ms. Mullen, at any point during the time that 22 either of her daughters participated in GLV 23 programs, did you discuss the allegations of 24 sexual abuse against you? Page 88 1 MS. D'AMBROSE: I object to form, 2 foundation, and scope. 3 A I didn't discuss it with her. 4 BY MS. JANZEN: 5 Q When did you discuss it with her? 6 A I didn't discuss it with her. 7 Q Oh. Thank you. I misheard you. 8 At any point during your conversations 9 with Ms. Mullen, at any point during the time that 10 either of her daughters participated in GLV 11 programs, did you ever state that the allegations 12 of sexual abuse against you were, in fact, true? 13 MS. D'AMBROSE: I object to form, 14 foundation, and scope. 15 A No. 16 BY MS. JANZEN: 17 Q Did you ever discuss -- did you ever have 18 any conversations with Ms. Mullen's husband? 19 MS. D'AMBROSE: I object to scope. 20 A No. I don't even know what he looks 21 like, or looked like. 22 MS. JANZEN: Exhibit 3, please. 23 24 Page 89 1 MS. D'AMBROSE: I object to form, 2 foundation, and scope. 3 A No. 4 BY MS. JANZEN: 5 Q Okay. Going back to Exhibit 1, which is 6 your declaration. 7 We should be done with these e-mails, so 8 you can put those to the side. 9 Can you turn to paragraph 11, please? 10 A (Witness complies.) 11 Q And can you slowly read that into the 12 record? 13 A "Cheryl and I have always had an open 14 door policy regarding the allegations and have 15 always encouraged families to speak with us when 16 they have questions or concerns regarding anything 17 related to their experience in the Sports 18 Performance program." 19 Q What specific allegations are you 20 referring to in this sentence? 21 A Well, at our parent meeting, the first 22 thing we say is that if you have any questions or 23 concerns, whatsoever, make sure you come to the 24 leadership of the club. Do not go to your coaches Page 98 1 because, you know, we want you to come to the 2 leadership. 3 And I think I've had -- I've never been 4 contacted about having a meeting. 5 Cheryl has had four or five meetings, 6 maybe. 7 And I've held probably two meetings, or 8 three meetings that I've called, regarding when 9 people have questions or bring this up. 10 Q Okay. And I want to get into that. But 11 my question was: In this paragraph 11 here, 12 there's a reference to allegations in the first 13 line, correct? 14 A Yes. 15 Q What allegations are you referring to in 16 this sentence? 17 A The allegations from the 1980s. 18 Q What allegations from the 1980s? 19 A The allegations from the 1980s of sexual 20 abuse. 21 Q Okay. Are there specific -- more 22 specific allegations? 23 MS. D'AMBROSE: I object to scope. I 24 mean, we all know what the allegations are. Page 99 1 They're detailed in the first 50 pages of your 2 complaint. I mean, it's pretty clear what 3 allegation we're talking about. 4 MS. JANZEN: Okay. And I want to know 5 what Mr. Butler's understanding of those 6 allegations are. 7 A I've never talked specifically about the 8 allegation. The allegations, just -- they're the 9 allegations from the '80s. You know, that's just 10 what they are. I've never had anybody ask me 11 about any specific allegation. 12 BY MS. JANZEN: 13 Q Have any parents or players ever asked to 14 speak with you about the sexual abuse allegations 15 against you? 16 A No. 17 MS. D'AMBROSE: I object to scope. 18 A No. 19 BY MS. JANZEN: 20 Q Over the years, have you ever had any 21 meetings with parents or players regarding the 22 sexual abuse allegations against you? 23 A Yes. 24 Q When? Page 100 1 a club next year? Just -- you know, there was -- 2 there was a lot of questions about moving forward. 3 And so we just wanted to talk to 4 everybody at once, as opposed to trying to e-mail 5 or call or send letters out to everybody. 6 Q Okay. So I think you just said that the 7 allegations were discussed at that meeting, but 8 that it was an informational meeting, correct? 9 A It was regard- -- the meeting was called 10 as a response to USAV's suspension about the 11 allegations. 12 And the questions at the meeting asked 13 were, Are we going to have a club next year? 14 Those kind of things. The individual allegations 15 were not addressed. 16 Q What specifically did you say at that 17 meeting? 18 A They wanted to talk about, Are we going 19 to have a program next year? 20 They wanted to talk about what the roles 21 would be. 22 They wanted to talk about those things. 23 And just in general -- I mean, it probably lasted 24 45 minutes, you know. Page 102 1 and scope. 2 A No. 3 BY MS. JANZEN: 4 Q Okay. You also mentioned that you had a 5 meeting in 2015, correct? 6 A Correct. 7 Q Who was present at that meeting? 8 A The majority of the incoming 2016 seniors 9 and their parents. 10 Q Is that the meeting that's referenced in 11 paragraph 12 of your declaration? 12 A Yes. 13 Q Okay. And I want to get to that in a 14 bit. 15 But you also mentioned that you had a 16 meeting in 2017, correct? 17 A '16 or '17. I'm trying -- I think it was 18 with a small group of parents, yes. 19 Q Who was present at that meeting? 20 A The , whose daughter actually 21 came and lived with us later. The and the 22 . So six people, plus Cheryl and I. 23 Q Would -- where did that meeting take 24 place? Page 105 1 A At the Great Lakes Center. 2 Q How did that meeting come about? 3 MS. D'AMBROSE: I object to scope. 4 A Somebody in that group, and I can't 5 remember exactly who it was, had asked how they 6 could help, how they could be supportive. They 7 talked about how supportive the parents were. 8 And so they suggested, you know, possibly 9 meeting and trying to figure out how they could 10 help support us, because they were very supportive 11 of us. It was three of our most supportive 12 families. 13 And so we met at some point in the 14 summer. And probably -- again, that meeting was 15 probably two hours long, six people plus Cheryl 16 and I. 17 BY MS. JANZEN: 18 Q What was discussed at that meeting? 19 MS. D'AMBROSE: I object to scope. 20 A They were all aware of the allegations. 21 So we showed them documentation, other things like 22 that, that we felt would allow them to make up 23 their minds in a -- in, I guess, a more 24 unprejudicial manner. Page 106 1 Q All right. So what -- you mentioned you 2 showed them documentation. 3 What documentation did you show them? 4 MS. D'AMBROSE: I object to scope. 5 A Showed them all the documents from Kay, 6 when she was asked to leave the organization. 7 Showed them the Christmas present from 8 Christine when, you know, she said she was not 9 involved with me, but she was buying me Christmas 10 presents. 11 Showed them the pictures of Christine 12 with my family, when she said she wasn't involved 13 with me. And she was going to my family parties 14 that I -- I wasn't in attendance. 15 You know, talked pretty -- talked at 16 length about Bonnie Bremner's involvement in our 17 program. 18 Bonnie Bremner, at the USAV hearing, came 19 to testify on my behalf in July. She was going to 20 testify on my behalf against her sister. 21 She was also -- she -- later, she was 22 doing lessons for us, working in our organization. 23 And then we said, You need to make up 24 your mind, you know, after you see both sides Page 108 1 if you want to talk, we can talk. 2 BY MS. JANZEN: 3 Q What individual discussions have you had? 4 A Just if it were to come up somewhere, in 5 some manner, and somebody would say -- you know, 6 I -- and I -- and I've probably said it, I don't 7 know, a number of times over the years. Google 8 me, and then if you want to come back and talk, 9 and nobody has ever come back and wanted to talk. 10 And the general consensus is that they 11 keep -- that it always goes back to the '80s. And 12 I'm -- I'll freely say these are from the '80s. 13 And I say, if you want -- if you want to know the 14 worst, Google me. 15 Q How many times have you had interactions 16 like that? 17 MS. D'AMBROSE: I object to scope. 18 A Maybe half a dozen over the last 10, 15 19 years, just in conversation. 20 BY MS. JANZEN: 21 Q Do you remember specifically the 22 individuals that you spoke to? 23 A No. It would have been somebody that I 24 was fairly close to, because we wouldn't have had Page 111 1 Q At that parent meeting -- and that's the 2 initial parent meeting that you have every year, 3 correct? 4 A Yes. 5 Q At that parent meeting, when you mention 6 that parents can come to you with any questions or 7 concerns, do you specifically mention the 8 allegations at that time? 9 MS. D'AMBROSE: I object to scope. 10 A No. 11 BY MS. JANZEN: 12 Q The Mullen family was not one of the 13 families with whom you ever met to discuss the 14 allegations of sexual abuse against you, correct? 15 MS. D'AMBROSE: I object to scope. 16 A No. 17 BY MS. JANZEN: 18 Q Paragraph 12, can you please slowly read 19 that into the record? 20 A "In the summer of 2015, ESPN's 'Outside 21 the Lines' ran an episode about the allegations of 22 sexual abuse against Rick, which generated 23 additional publicity from other news outlets. In 24 light of the renewed media attention of the Page 113 1 A I didn't have to do anything, because I 2 knew who was at the meeting, and I know what their 3 graduating class is. 4 I knew the -- the only people that would 5 have been there would have been the people who 6 were going to graduate in 2016 of the next year. 7 So I -- and I know the people at the 8 meeting, so I didn't have to verify that it was 9 2015. I knew without question. 10 BY MS. JANZEN: 11 Q How did you inform the parents and 12 players of the upcoming senior class that this 13 meeting was going to take place? 14 MS. D'AMBROSE: I object to foundation. 15 A I think I asked somebody in the office to 16 send out a mass e-mail to that group. 17 BY MS. JANZEN: 18 Q Do you remember who? 19 MS. D'AMBROSE: I object to foundation 20 and scope. 21 A It probably would have been Luke, maybe 22 his wife, Kelly, who works in our office in the 23 summer during the camp season. It would have been 24 somebody in the office. Page 115 1 five to ten were on vacation, or had conflicts. 2 Cheryl was supposed to be there, but her 3 mom had a stroke, so she was at the hospital with 4 her mom. So I ran the meeting. 5 Q How many parents were there? 6 A I would say -- 7 MS. D'AMBROSE: I object to foundation 8 and scope. 9 A I would say 20 to 25 players with one or 10 two siblings -- or one or two parents. 11 Q Okay. So I thought earlier you said you 12 thought 35 to 40 players were there. 13 A 35 to 40 players total in that class. 14 There were about five to ten that were -- it was 15 summer. They were missing. 16 And then the 20 to 25 players that came 17 brought at least one, if not two, parents. So... 18 Q Okay. And you mentioned that Cheryl was 19 unable to be at that meeting? 20 A Yes. Her mom was sick. 21 Q Okay. So in this paragraph where it says 22 "Cheryl and I held a meeting," is that an 23 incorrect statement? 24 A She was sched- -- Page 118 1 MS. D'AMBROSE: I object to form. 2 A She was scheduled to be there, but she -- 3 you know, she couldn't make it. Her mom got sick 4 at the last minute. 5 I mean, when we scheduled the meeting 6 she -- she was going to be there, and then her mom 7 got sick pretty quickly. 8 BY MS. JANZEN: 9 Q Did you review this paragraph before you 10 signed your declaration? 11 A I reviewed it, but I didn't remember that 12 her mom had got sick and she had missed that 13 meeting. 14 Q But you were aware that you were signing 15 this declaration under penalty of perjury, 16 correct? 17 MS. D'AMBROSE: I object to form. 18 A I'm aware of that, yes. 19 BY MS. JANZEN: 20 Q Why did you just invite the parents and 21 players of the upcoming senior class? 22 MS. D'AMBROSE: I object to scope. 23 A Those -- those players were -- they had 24 one more year before they went to college. And Page 119 1 their biggest concerns were preparing and getting 2 ready. So rather than have a meeting with 500, 3 400 players and 1500 people, the biggest concerns 4 and the questions we had gotten from people 5 reaching out were -- you know, because the rumor 6 mill is just rampant about what's going to 7 happen. 8 Because all of our competitors try to -- 9 they use this against us. Sports Performance is 10 not going to be in existence next year, blah, 11 blah, blah. 12 So we just wanted to meet with that 13 group, because that group was the oldest group in 14 the club. They would be the leaderships of the 15 club the next year. 16 And also, they would be talking to 17 virtually everybody else in the high school age 18 program. And every single parent had known about 19 the allegations for years. 20 So it was much -- it was a much easier 21 communication in the summer, especially when so 22 many people are on vacation, doing camps and 23 things like that. Because the seniors do less of 24 that, because most of them are committed already, Page 120 1 to get the seniors in for a meeting, than to try 2 to get everybody in for a meeting. 3 BY MS. JANZEN: 4 Q When you say every single parent had 5 known about the allegations for years, how do you 6 know that? 7 A Well -- 8 MS. D'AMBROSE: I object to scope. 9 A I'm just -- I'm just telling you what the 10 parents told me. 11 BY MS. JANZEN: 12 Q Did every single parent tell you that 13 they knew about the allegations? 14 MS. D'AMBROSE: I object to scope and 15 form. 16 A No. They just said, We all know. So I 17 was assuming that they were speaking for each 18 other. 19 BY MS. JANZEN: 20 Q Who is "they"? 21 MS. D'AMBROSE: I object to scope, form. 22 A Every parent that brought it up to me. 23 BY MS. JANZEN: 24 Q How many parents brought it up to you? Page 121 1 MS. D'AMBROSE: I object to scope. 2 A In the meeting itself, at least one or 3 two parents said, "This stuff is so old. We've 4 known about this for years," because we didn't at 5 all go into the allegations. 6 The meeting was -- again went back to the 7 allegations from the '80s. The DCFS stuff was 8 from the '80s. You know, it's the -- and I think 9 somebody said, So it's the same stuff that we 10 basically go through every year? 11 And you know, again, Are you guys going 12 to have a club next year? Do our daughters have 13 teams to play on? 14 That was what the main body of the 15 meeting was about. 16 BY MS. JANZEN: 17 Q So one or two parents brought up the fact 18 that they had heard of the allegations to you 19 before? 20 A More than one or two -- 21 MS. D'AMBROSE: I object to scope. 22 A More than one or two in one-on-one, 23 because a lot of parents came up and just talked 24 to me afterwards. Page 122 1 MS. D'AMBROSE: I object to foundation, 2 form, and scope. 3 A Yes. 4 BY MS. JANZEN: 5 Q Did you receive a copy of the USAV ethics 6 and eligibility committee findings of fact at the 7 time you were banned in 1995? 8 MS. D'AMBROSE: I object to scope. That 9 has absolutely nothing to do with the motion 10 for summary judgment or the affidavit. 11 MS. JANZEN: I think it talks about the 12 USAV investigation and ban. 13 A There was no USAV investigation. 14 BY MS. JANZEN: 15 Q There was no USAV investigation? 16 A I'm sure I received the documents, yes. 17 Q Okay. Did you just say there was no USAV 18 investigation? 19 A I don't feel there was an investigation. 20 Q Okay. So in paragraph 12 here, where it 21 says that you talked about the USAV investigation, 22 what does that mean? 23 A I talked about the time -- timeline. 24 They said they wanted to know, because ESPN had Page 127 1 made it part of the story. 2 I said the USAV -- and I explained what 3 USAV -- what my obligations were, because I was a 4 USAV member at the time. 5 I said we hadn't participated in U.S.A. 6 Volleyball since 2007. 7 I said, Here's my limitations. I can't 8 coach junior girls in USAV-sanctioned 9 competitions. 10 USAV specifically said I can coach at 11 AAU, I can run camps, I can run clinics. I have 12 no restrictions there. 13 I can also be a club director. 14 I can be a chaperone. 15 I laid out everything that I could do. 16 But I also explained that because we 17 don't participate in U.S.A. Volleyball, and hadn't 18 for years at the time, that we really don't have 19 any dealings with U.S.A. Volleyball at all. 20 Q Okay. And you discussed all of that at 21 this meeting in the summer of 2015 with the 22 upcoming senior class? 23 A I outlined what I just told you, yes. 24 Q Okay. Were there any more specific Page 128 1 aspects of the USAV ban that you discussed at this 2 meeting? 3 A No. 4 Q Did you present any documents or 5 information to parents at this meeting about the 6 USAV investigation and ban? 7 A No. 8 Q Did anyone at the meeting ask any 9 questions about the USAV investigation and ban? 10 A No. 11 Q Did anyone at the meeting ask to see any 12 documents from the USAV investigation and ban? 13 A No. 14 Q Prior to this meeting, had you discussed 15 the USAV investigation and ban with any parent or 16 player, other than what we've previously discussed 17 today? 18 MS. D'AMBROSE: I object to scope. 19 A I can't say. I mean, I can't remember if 20 I've ever -- if it's ever been brought up. 21 I hadn't been a USAV member for eight 22 years at that time, so we had no involvement with 23 U.S.A. Volleyball whatsoever. 24 So I'm guessing that we've never Page 129 1 discussed U.S.A. Volleyball, but I can't say that 2 I never talked about it. 3 BY MS. JANZEN: 4 Q At this meeting in the summer 2015 with 5 the upcoming senior class, did you state that the 6 USAV ethics and eligibility committee made the 7 following finding of fact, quote: 8 "Beginning in 1981, Rick Butler had 9 unprotected sexual intercourse and a subsequent 10 physical and emotional relationship with 11 16-year-old Sarah Powers, now Barnhard, while she 12 was a junior volleyball player with a program in 13 which Mr. Butler was a strength coach and at least 14 a substitute volleyball coach. That experience 15 caused Ms. Powers to lose her virginity," close 16 quote. 17 MS. D'AMBROSE: I object to form, 18 foundation, and scope. 19 A No. 20 BY MS. JANZEN: 21 Q Did you reference this finding in any way 22 at that summer of 2015 meeting? 23 MS. D'AMBROSE: I object to form, 24 foundation, and scope. He's already testified Page 130 1 BY MS. JANZEN: 2 Q At any point did you discuss any 3 specifics about the USAV ethics and eligibility 4 committee findings of fact? 5 A None. 6 Q When you say in paragraph 12 that you 7 discussed the allegations, what did you discuss 8 about the allegations at this meeting? 9 MS. D'AMBROSE: Objection, asked and 10 answered. 11 A I just said they were the same 12 allegations from the '80s. I mean, you know, this 13 meeting was called because of the publicity from 14 the ESPN article. And the ESPN article had talked 15 about everything. 16 So I didn't talk specific al- -- about 17 anything specifically about the allegations at 18 all. 19 BY MS. JANZEN: 20 Q When you say that you discussed the DCFS 21 investigation, what specifically did you discuss 22 about the DCFS investigation? 23 MS. D'AMBROSE: Objection, asked and 24 answered. Page 132 1 A That the DCFS investigation was the 2 investigation from the allegations from the '80s. 3 And that -- because that's what had been 4 referenced in the ESPN report. 5 BY MS. JANZEN: 6 Q Did you present any documents or 7 information to parents or players at this meeting 8 referencing the DCFS investigation? 9 A I didn't, no. 10 MS. D'AMBROSE: Object to form, 11 foundation. 12 A No. 13 BY MS. JANZEN: 14 Q Did anyone at the meeting ask any 15 questions about the DCFS investigation? 16 A No. 17 Q Prior to this meeting, had you discussed 18 the DCFS investigation with any parent or player, 19 other than what we've previously discussed here 20 today? 21 MS. D'AMBROSE: I object to scope. 22 A No. 23 BY MS. JANZEN: 24 Q At this meeting, did you state that the Page 133 1 DCFS administrative law judge determined that 2 there was, quote: 3 "Credible evidence supporting the 4 indication of reported abuse," end quote? 5 MS. D'AMBROSE: I object to foundation. 6 He's already discussed that he did not talk 7 about the details of the DCFS investigation or 8 findings. 9 A No. 10 BY MS. JANZEN: 11 Q Going back to paragraph 12, after the 12 DCFS investigation, it says that you discussed 13 related issues. 14 Were there any other related issues you 15 discussed at this meeting that you haven't already 16 mentioned today? 17 A They just asked how they could help, and 18 that they were 100 percent supportive. And it 19 was -- I mean, we didn't -- I didn't go into any 20 other detail at all. 21 I think that's -- it was after that 22 meeting that we had a lot of parents try to reach 23 out and help us. 24 But we didn't -- I didn't go into any Page 134 1 other details at all. 2 Q Did -- at the -- the last sentence of 3 that paragraph is: 4 "Parents were also invited to ask 5 questions about any of the topics discussed at the 6 meeting." 7 Did parents ask questions? 8 A The only question was, How can we help 9 you? 10 Q That was the only question that was 11 asked? 12 A The only question that was asked was, How 13 can we help you? 14 There was a lot of, We support you. But 15 the only question was, How can we help you? 16 Q Did any of the parents that attended this 17 meeting end up removing their daughters from the 18 Sports Performance program? 19 A No. 20 Q At any point during this meeting, did you 21 ever state that the allegations of sexual abuse 22 against you were, in fact, true? 23 MS. D'AMBROSE: I object to foundation, 24 form, and scope. Page 135 1 A Never. 2 BY MS. JANZEN: 3 Q In paragraph 13, can you please slowly 4 read that into the record? 5 A "Cheryl and I also -- have also held 6 several meetings with smaller groups of parents or 7 with individual families regarding the allegations 8 at various times over the last 25 years." 9 Q Have there been any instances in which 10 you held meetings with parents or individual 11 families that we haven't already discussed today? 12 A Me? 13 Q Yes. 14 A No. 15 Q During any meetings or conversations that 16 you had with parents regarding the allegations of 17 sexual abuse against you, did you ever state that 18 they were, in fact, true? 19 MS. D'AMBROSE: I object to form, 20 foundation, and scope. 21 A Never. 22 BY MS. JANZEN: 23 Q Did any parent or family who met with you 24 about the allegations of sexual abuse against you Page 136
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