"Sandusky exploited his status as a member of the PSU football staff to facilitate grooming and coercing his intended victim, John Doe 6. Among other things, Sandusky invited John Doe 6 to visit the coaches' offices and gave him a pair of Paterno's socks.
"Sandusky and John Doe 6 went to a coaches' locker room where Sandusky initiated grooming behavior. Among other things, Sandusky and John Doe 6 wrestled. This was initiated by Sandusky. Wrestling was merely a ruse to afford Sandusky an opportunity to put his hands on and rub his body against plaintiff's adolescent male body for the purpose of Sandusky's sexual gratification. After wrestling, John Doe 6 changed into clothes that Sandusky provided and followed him to work out on exercise machines. When they finished exercising, Sandusky kissed his head and said, 'I love you.' This, too, was for the purpose of grooming plaintiff for more advanced sexual activity and for Sandusky's sexual gratification. Sandusky and John Doe 6 then went to a locker room where Sandusky took off his clothes, turned on the showers, and through the use of undue influence based on his stature secured plaintiff's reluctant consent to shower. 'All the boys do it,' Sandusky told him. Extremely uncomfortable with being naked and seeing Sandusky naked, after he entered the shower, John Doe 6 proceeded to a shower head as far away from Sandusky as possible and began to turn it on. Although Sandusky had already achieved two of his goals by maneuvering this adolescent boy into the showers with him; namely, creating his own personal peep show and exposing his own genitals to this young boy, he was merely setting the stage for physical contact of a sexual nature. In furtherance of that plan, Sandusky directed him to a shower head closer to Sandusky, saying he had already warmed up the water for him. While in the shower and nude, Sandusky wrapped his hands around John Doe 6's torso from behind and pressed his body, including his genitals, against plaintiff and said, 'I'm gonna squeeze your guts out.' (When Sandusky was confronted at a later date by plaintiff's mother, with police secretly hiding in another room so they could overhear the conversation, in response to a pointed question as to whether his genitals came in contact with plaintiff, Sandusky did not deny such an occurrence.) Also, during this shower escapade Sandusky played his self described role as 'The Tickle Monster' and used that as a pretense to put his hands over plaintiff's adolescent body. This and virtually all of Sandusky's conduct in connection with his interaction with plaintiff on this date was for the purpose of sexually gratifying Sandusky. After John Doe 6 washed his body and hair, Sandusky lifted him under the pretense of wanting to 'get the soap out of' the boy's hair, bringing his feet 'up pretty high' near Sandusky's waist. John Doe 6's body contacted Sandusky's chest and his feet touched Sandusky's thigh. This likely brought Sandusky's genitals into contact with the boy's body. The positioning of Sandusky and plaintiff while plaintiff was being lifted off the ground likely brought this young boy's genitals up to Sandusky's face. Presently, John Doe 6 does not have any specific recollection of the remainder of his interaction with Sandusky. The events following being lifted in this fashion have been described by plaintiff as being 'just kind of black.' The uncertainty of what caused him to have obscured some of what he was subjected to in the shower, along with those events about which he does have a clear recollection, have caused the plaintiff to suffer great mental anguish.
"After the shower escapade, Sandusky made promises to plaintiff that included taking him to the movies and letting him sit on the PSU bench on the sidelines during a football game. While in the coach's locker room, before the shower incident, Sandusky took plaintiff to Head Coach Joe Paterno's locker and gave plaintiff a souvenir in the form of a pair of the coach's socks. The gifts and promises were extended to plaintiff for the purpose of grooming him and to keep him quiet. Indeed, these (along with the intimidating atmosphere that was created during his repeated questioning described more fully below) influenced plaintiff's statements to the police and others about his encounters with Sandusky on the PSU campus. Despite Sandusky's purportedly playful behavior that was accompanied by laughs on his part, the seriousness of what transpired was revealed in part in one of plaintiff's remarks to the PSU police wherein he tried to rationalize that Sandusky could not have intended anything sexual by his conduct because he was 'married.'
"Sandusky brought John Doe 6 home around 9:00 p.m. and left. John Doe 6 told his mother that he had showered with Sandusky. She became suspicious that something was wrong and observed that her son was acting in a way that he did when he was upset about something. Reluctantly, plaintiff admitted to his mother that he had showered with Sandusky but did not reveal much more at that time. Plaintiff did not sleep well and took another shower the next morning." (Parentheses in complaint).
After Doe's mother reported the incident to a psychologist and to Penn State police, Doe says, campus police interviewed him and his 10-year-old friend about their contact with Sandusky.
He claims campus police repeated the interview and tried to intimidate him, suggesting that Sandusky didn't "deserve to be in trouble."
Sandusky continued to call John Doe 6, and when he retuned to the boy's house to pick him up, he admitted to the boy's mother that he had had physical contact with her son, according to the complaint.
Doe says Penn State police detectives and a local police officer listened to the conversation without Sandusky's knowledge.
"On May 19, 1998, during a conversation between John Doe 6's mother and Sandusky, plaintiff's mother asked Sandusky about the bear hug in the shower, and whether his 'private parts' touched the boy while they hugged," the complaint states. "Sandusky did not deny it. He said, 'I don't think so ... maybe.' He also said he had showered with other boys before. He admitted telling the boy that he loved him. Sandusky asked to speak with her son and the mother replied that she did not feel that was a good idea as her son was confused and she did not want Sandusky to attend any of the boy's baseball games. Sandusky responded, 'I understand. I was wrong. I wish I could get forgiveness. I know I won't get it from you. I wish I were dead.'
"The law enforcement officers should have interrogated Sandusky directly after his confrontation with John Doe 6's mother yet they made the deliberate decision not to question Sandusky at this time."
Doe says Penn State police questioned Sandusky later, but despite the investigator's conclusion that his conduct warranted criminal charges, the district attorney declined to charge Sandusky.
Doe claims the campus police did not refer the incident to Penn State's human resources, characterized Sandusky's report as an "administrative file," and closed the investigation.
He adds: "Though they knew that Sandusky had been showering with children, defendant PSU ratified his conduct by purposely avoiding questioning Sandusky about his assault of John Doe 6, taking no action to limit Sandusky's access to Penn State facilities, not alerting the police or other proper authorities, making no effort to protect children on the university's campus, influencing the investigation and the results of the investigation including characterizing the file as an administrative file, ignoring the lead investigator's opinion that criminal charges against Sandusky based on his conduct in relation to plaintiff should have been filed, and otherwise participating in a cover-up of this and other prior incidents."
Doe says the university offered Sandusky incentives to expedite his retirement, and continued to promote him to the public as a respected member of the Penn State community, without disclosing his abuse of children.
He seeks compensatory and punitive damages for childhood sexual abuse, negligence, premises liability, intentional infliction of emotional distress, and civil conspiracy to endanger children.
Doe's attorneys, Hal Kleinman and Brian Ketterer, are with Janet, Jenner & Suggs.
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