FILED 08 DEC 2015 04:11 pm Givil Administration E. MASCUILLT Exhibit Z. ar Ste rt Ys Peper wm 10319500128 Case ID: 1311 Control No.: 15110 aL a2 43 14 as 4s a7 18 19 20 21 22 23 24 IN THE COUR'T OF COMMON PLEAS PHILADELPHIA COUNTY, PENNSYLVANIA PENNSYLVANIA MANUEACTORERS' : CIVIL ACTION ASSOCIATION INSURANCE : COMPANY, Phaintif£, - ve. - ‘THE PENNSYLVANIA UNIVERSITY AND JOHN DOE A, Defendants. ‘THR PENNSYLVANIA UNIVERSITY, Plaintiff, Gary C. Schultz : JANUARY TERM, 2012 STATE NO: 04126 STATE CIVIL ACTION 1; NOVEMBER THRM, 2013 PENNSYLVANIA MANUFACTURERS" i ASSOCIATION INSURANCE COMPANY, Defendants. TRE PENNSYLVANIA UNIVERSITY, Plaintifé, - ve. - + NO: 03195 | STATE } CIVIL ACTION NOVEMBER TERM, 2023 PENNSYLVANIA MANUFACTURERS! : ASSOCIATION INSURANCE COMPANY, Defendants. : NO: 03197 Wednesday, May 27, 2015 | Videotaped deposition of GARY ¢. SCHULTZ held at Hliton Garden Znn, 3221 East College Avenue, State College, Pennsylvania, 16803, commencing at 10:05 armas on the above date, before Kelly W. Jomnaton, 8PR, and otary Public in the Conmonwealth | of Pennsylvania. GOLKOW TECHNOLOGINS, INC. i 877.370.3377 ph/917.591.5672 fax | Golkow Technologies, depsegolkow.com Inc. Page 1 Case TB: 13110319: Control No.: 1511103Gary C. Schultz - ‘Page 2, Page 4 5 Apmaances. 3 SERINBARD BILL f- nRCKBR LC 2 eee a pace BY: TAULG. GAGNE BSQUIRE 3 BREN a ‘hgand Si 7 Seite ‘et a RAIS Bs ‘samme! + Eitan © te " * Rigen & sate nog, Rape Dry 61 > ea sneezes : fo 2029 Century Park East, Site 730 Seta No, tae ® tag angle CA 90007 is on a a » fferataginzrwitzcom Sette No, 14 german ge Ste 80 ‘Representing Pan Stale University 10 ee ae AYRE em (Ese aS, desert Ave i senate difed July 12, 92 ‘Pitek gE PA 13219 as aes po (ee ctcon P scat Na oe cmrege ss, Rowan 7 SSBB, ses t set Jo Pats P japan: ps Steg as Tm we pe TR iat a ae 7 7 soa apraigaer? Ee 2 Schutz No, 20, ‘i ha = st aaa juy 124 ey 33 BT peaes Paged Page 5 2 inex 1 exasaits conn 2a PAGE 3 pxmoASUP DESGOPHON PAGE 3 5 Eo cena i : PEN 7 ‘ 2fap om ; BxXUIBITS 5 semtenods aaltsRcedant 158 > EXHIBITNO. DESCRIPTION PAGE | & aa Ln ‘Suet Sipaanes 8 | MBs & Schatz No,7 Segue Asst otoont, 15 : Desert 00 Sees Sonne Eanes 156 |, Saute Foams 17 Fe aha . see ae sy pilesi eal 30 Tea 2? Fubree Schultz No, 25 Police Criminal Complaint, 185 , Senta | na etetuat Gy C- Seah P sata ‘ecriatwne 1 apa rs oe aes fa [% santas 2 ger 9 gas 9 hs So RSS Woe, Soh No 27 Sse of ant of 25 satan Sune om Preset * sautaNo,s, er SN 8 au as Sine hs i i serine eamgessnasee 26 ft 2S sett Nob Sones of » samen orc iB : 22 Schultz No, Nee ee 86 tesa OSE 33 [be ines fe Golkow Technologies, Inc. Page : Casé 18°1311031 Control No. 151110: | i | | 9s 35Gaxy C. Sebultz Pages 2 PROCEEDINGS . (eis hereby stipulated by and 5 tween eouneel for the respeative pais that & reading signing, seating, cestfcaion and 1 Gling ore waived) ’ ‘THE VIDEOGRAPHER: Weare 2ow on 20 therecord. My name is Kelty Boye Kina {1 videogropher for Golkow Technologies. Todty's a2 Gatoie May the 27th, 2015. Time is wow 10:05 ls “This video depasion is 35 holdin State College, Pennsylvania 6 matter of Pemsyivenia Manufacturers! 37 Assoviation Tnsurance Company, Psintit 11 yersus Pennsylvania State Univesity end Job. no Doe A, Defendants, and also Peonsylvenia State 120 University vrmus PA Manufectucer' Association Jas. Insorenos Company, Defendant file in tho lez Coustof Common Pleas of Philadelphia County, 23 Peanaylvani, Case Nos. 04126, 03195, and (3197, 124 The deponent is Gary Scout, Paged 4 Q. Wemetoff the record, but forthe record, 2 my name is Pail Gagne, [represent Peansylvanio | Manufuchuter! Assocation Company, or PMA, in an 4 ssucence coverage lawsuit with Penn State 5 University and we ae her to take your deposition 6 today pursuant to «subpoena, Ts that coset? 7A Yeu 4 Q And in just going to mut forthe record a copy ofthe snbposna that we served on your 20 counsel and ask whether you've seen that and if 23. youte here pursuant tothe subpoens, 32 A. Thonestly had not seen it but 'm aware > fit ls Q. Yauto aware ofit? ps A Yes se (Gohultz No. 1, Subpaene, 2 pages, 1x7 mailed for identifeston.) 38 MR. GAGNB: And Mr. Teitelbaum, Is8 you've accepted service on behalf of Mr. Schulte? 20 ‘MR, TEITELBAUM: Yes, ss, know 2 my frm had before. a2 MR. GAGNE: Thank you. > BY MR. GAGNE: 24 Q. Me Schulz, where do you presently ‘Will counsel please identify ‘homaelves for the recon? “MR. GAGNE: Paul Gagte of ‘Keiabard, represent Penneylvania ‘Maanfactires' Association Tnsucenoe Company. ‘MS, KORNFELD: Tim Linda Komfelé ‘on beta of Penn Sate. ‘MR. TEITELBAUM: Bruce Teitelbaum, Farrell and Reisinger, for Me. Sell 0 ‘THE VIDEOGRAPHER: Ths cout 1 reporters Kelly Johaston, and she will sow x2 wearin the witness. bs GARY C, SCHULTZ, after having been 1s fxs daly sworn, was examined end testified as ss follows: is ‘THE VIDEOGRAPHER: Proceed. 20 BXAMINATION J22 BY MR. GAGNE: ps Q. Good moming, Mr. Schultz. le A. Good morning, Page? | aged 2 roside? 2A Boalsburg, 3 Q Andif we need foreach you again, wo can “+ reachyou through your attomeys in this case? 5 A. Absolutely. © — Q Areyou curently employed? 7 & No © Q You're retired? 2 A Woll, kde some parttime work formy 20 son inlaws fa, so Ieceive compensation fom 2s time to tie 2. Okay, Timjustgoingto give yous few > instructions. Ifyou dont heat ary question or 34 doatunderstand my question, | would ask that you 25 ask me to repeat the question, Hf you do nat ask me 45 torepeator rephrase the question, Iwill assume 7 dat you understood the question. 1s that fe? nA Yes 38 Q_ And you undeestnd youre under onth 20 todays is that correct? los A Lsuredo yes. Jaz. Okay. And you's fest taken brent 2> any ime, Do you understand that? pe A Yes, Golkow Technologies, Inc. Cas 9" 13110319. Control No.: 1511103:Gary ¢. Schultz ‘ ‘Page 10 Q Fowotld just ask that you not take a bresle ‘yh theresa question pending, unless you noo’ to ‘consult with your attomey on x question of attoaney-client privilege, Is that ie? A Yes Q Okay. Nov, Mr. Schult, have you bean deposed before in connestion withthe Sanky child abuse atts? A Yes, Q. Okay, And was thet in the case of fohn Dow D versus Pennsylvania Stato Univesity? ‘A. Téorttknow. Q Do you recall whether it was acim brought by one ofthe alleged victims? A Yes. Q Okay. Is thatthe only deposition you've given this mater? A Yes. Q. And you've alo testified before & Grand uy i that comect? A Yes. Q_ Now, Mr, Schutz, wero yor employed as senice vice president for finsnee nd business at ‘Poansylvania State Univesity ftom 1995 to 2009? Page 2 (MS, KORNFELD: Should we ageeo tot seuncated response for ease for Mr. Schulte? MR. GAGNE: Why dontt we see what ‘he says the first iee and detennne whether we find that en acceptable response. ‘MS. KORNFELD; Okey. BYMR. GAGNB! Q. Mr, Schultz, do you know Timothy Cutley? ‘A. Trofaee (o answer based on the Fifth [x0 Amendment. a MR, GAGNE: Js that acceptable? 32 MS, KORNFELD: Yes. a3 BY MR. GAGNE: 4 Q. Doyou know Guahui Spanier, sit? 25 A Lrefse to answer based on the Fils js6 Amendment. 37 Q Doyou know Joseph Paterno? 8A. Lrefise to saswer based on the Filth J12_ Amendment. 20 Q. Do you know Michael MoQueary? [21 A Trofite o answer based on the Fifth J22 Amondment. las Doyouknow Gerald Sandusky? 24 A._Lzefase to answer based on the Fifth 29 Page Td ‘A. Well, based on the advice of my attorney, imasteting my right not to answer under the Fifth ‘Amendment to the U.S, Constitution, Astcto 1, Section 9 ofthe Pennsylvania Constitution (Q. What were your responsibilities at tho ‘ove that you were employed by Penn Sta? ‘A. Based on advice of my atorney, Im asserting my sight not to answer under the Fit, “Arnendment to the U.S, Constitution, Astle 1, Seation9 of the Pennsylvania Constitutlon ‘Q. Mr. Schult, understand that you expect to give that answer to a number of questions today. Ts that correot? ‘A. That's conect. Q. Okay, Aud ve discussed with your attomey, going forwasd, you should fel fies to tive a shorter or truncated version of that response — ‘A. Thankyou. Q. ~rather than have to read the whole ‘hing oat A. Thankyou. Q. And well understand what youre saying. A. Tunderstand, Page 1 2 Amendment 2 Q Now, were you cenior vice president for 3 Saance and business at Penn State in May of 19987 4A. Trfase to answer based on the Fifth 5 Amendment 6 Q InMey of 1998, did you come to lam thet 4 Gerald Sandusky was being investigated for coniact 1 in the Penn State showers involving a young boy? 9A. Lrefuso to answer based om the Fifth 30 Amendment. a1 Q__Anddid you come to leam tet that 32 investigtion was being carried out by the Pent. 33 State police department? 6A. Liefase to answer based oa the Fifth 35 Amendment. Ine Q_ And wore you aware tat Detective Ronald 27 Schreier was conducting that investigation? 30 A. Trefuse to answer based on tho Fifth 39 Amendmest. lz Q._Atthe time of thet investigation, iit 22 conect that Tom Famnon was the ebie ofthe Pena. 22 State police department? 123A Irefuse to noswer basod on the Fifth J2« Amendment. Golkow Technologies, Inc. Casé 1B? 14110319 Control No.: 15111035Gary ¢. Schultz Page 14 1 Q Andas chief ofthe Penn State police, 2 Me, Harmon reparted to you is that comet? 3A. Trofse to answer based on the Fifth 4 Amendment. 5 MS, KORNFELD: And il object to 5 that question as vague and lacking foundation, 7 BY MR, GAGNE: © Q. And Me. Harmon kept you up to date on tho 9 progress of tt investigation ducing May and June fro of 19987 js MS. KORNFELD: Objection, vague. aa ‘THE WETNESS: I refuse to ansvier 133 based on the Fifth Amendment. 34 BY MR, GAGNE: 25 Q_ Doyou recall bow many times you spoke 11s with Mr, Hasrmon concecning that investigation of ln» Mr, Sandusky in 19987 ps A. Lrnfuse to answer based on the Fifth las Amendment. 120 Q_ Do yousecell how many times you met with [22 Mr, Harmon to discuss the investigation of Gerald 22 Sandusky in 1998? a ‘MS, KORNEELD: Objection, lacks I> foundation. Page 16 2 Amendment. 2 Q_ Have you seea this document before, sir? 3A. Trefuse to answer based an mry Fifth © Amendment 5 (Schultz No. 3, Docament entitled © The Pennsylvania State University, Univessity 1 Police Policy end Procedure, Subject: Sexual © Assault Investigations, 29 Pages, marked for 2 identification.) 20 BY MR. GAGNE: 2 roudcas Exhibit Scnltz 2 document ented 26 "Sexual Assault Protocol”, as the logo of Penn 29 State on it aud the year 1995 on the docunent. 20 Asthata protocol tat, n 1998, would 22 have provided instruction to University employoss as 22 to how to rexpond to an alleged incideot of sexcal }23 abuse of arainor by an employee? 24 A. Trefsto answer based on my Fifth GaDSDooooo Pago 15 Page 7 ‘THE WITNESS: 1reftse fo answer BY MR. GAGNE: ‘besed on the Fifth Amendment Q Fave you seen this document before, sir? BY MR. GAGNE: ‘A. [refuse to answer based on the Fifth 4 Amendment. SQ Inyourcapacity atthe University, di ' you have any psticipation inthe deoting ofthis 7 docament? . ‘MS, KORNFELD: Objection, vague. ° ‘TATE WITNESS: [refuse to answer 20 based on the ih Amendment. o (Gokultz No, 4, Series of 112 Handwritten Notes, 6 Pages, mated for ls identification) lit BY MR. GAGNE: las Mi: Schultz, I've had the reporter mak as 36 Bxbibit4 a series of bndvritten notes, Do you soe 27 these? he A Ido, 28 Q_ Is this your handwriting, si? 20 A. refuse to answer based on the Fifth 21 Amendment 122 Q__Now,Iimgoing to ted some things and 'd 123 asleyon to read along with me. The first page is 24 dated 5/4/98, 5:00 p.m, Itsays: (Reading) Golkow Technologies, Inc Case 15? 13 110319 Control No.: 1511103 | \ |Gary C. Schultz 2 Woman, 11 end a half year old son, Nittany Gardens, 2 awolved in Second Mile, Jery picked wp soa and 2 invited to football locker rooms. Behavior, at 4 best, inappropriate, Atworet, sexual something. 5 Ae yow able to make out that word that 5 comes after “sexual”, sit? 1A Umum, © Q Okay, Do you recall taking notes on May, 1998, coocering this matter? lo MS, KORNFELD: Vague, ps ‘THE WITNESS: [refuse to answer ln2 bated on the Filth Amendment hs BYMR. GAGNE: 14 Q_ Doyouknow if these ate notes of = 15 conversation you had with Me, Hanoa? 6 A. Lyefuseto answer based on the Ff 5:7 Amendment 128 Q_ And do you remember being told theta 2 worn ind reported to the Pean State police that hor 20 1 L-yearold con had been involved in inappropriate 2. conduct ~ contact with Gerald Sandusky inthe 22 Penn State showers? page 8] Page 23 difference size difeence, Lbeliove it says. ‘Do you reel receiving that ifbroation and mnking thie note on May 4, 19982 ‘A. refuse fo auswer based onthe ith Amendment Q Alitleferthor down it says: (Reading) Fiend oge ten also ot Nittany Gardens claims somthing went on with him. Mother also asker ‘Children and Youth has been ofl. Willeometo tak to tonight Doyou see that, sir? A Teo. "MS, KORNFELD: Lacks foundation BY MR, GAGNE: Q And do-you wall eceving thet {nformtion aud raking these notes on May 4, 1998? (MS, KORNFELD: Lacks foundation, ‘THE WETNESS: Erefise to answer ‘based onthe Fifth Amendment. BY MR. GAGNE (Q And then on whats marked as pag fou: Reading) Moties overescing “20 ~fooks like 20 Do youecall having that conversation of 22 boing old that by anyone on May 4, 19987 x2 A refuse to answer based on the Fifth ha Amendment, 4 Q_ And them atthe bottom: (Reading) ss other concerned something more. Kid tok snother 26 shower lastnight and this am, 37 Do you recall ceiving that information 38 feom someone on Mey 4, 1998? 19 A. Trefime to answer based on the Fiflh 20 mendmeat. 2x Q. Please lok at the next page, six. It Jaa anys on whats marked ap page theo there: (As ead Jas by Ms. Gagne.) Mother esd his dad to give hug. 24 Had to be genital contact because of ae ss (MS. KORNFELD: Objection, vague, [23 ~Tmnot sre of he nex word snd then itsays lee ‘THE WITNESS: Lelie to answer [24 coneems, Atbes iki, peor udement Paget Page aT 2 based on the Fifth Amend 2 Gita aoe ~couet with gets. Assuming, 2 BY MR. GAGNE: 2 same experience with question mark. 2. Ifyoulookinthe second column onthis. | 3—_—Didyoureeive that nfosation and ako 4 pags, aronnd the miéleof he pag, it says, | 4 those notes on o boat May 5th-~ My At, 1998? 2 towaid the top ofthe column: (Reading) Jeny- | $ MS. KORNFELD: Objection. 6 ttakeashower- undressed - question mask, No | § “THE WITNESS: Lrefuse to mswee 7 othersbower. Looks Uk furintere, shampoo, | 7 aso the Fifth Amendment. © Jey camo up behind and gave him abearug. Said | ¢ BY MR. GAGNE: 2 ea would squeeze quis ot. 2 Q Lookat he next pages ity ~ its marked 5/5 ~ it sey Tom Hormon, last evening. ‘Did.you have « couverstion with Tom Hazmon on ‘May Sth, 1998, and make notes of that convection? "A. [refuse to answer based onthe Fis ‘Amendaett Q Do you recognize these assotes that you made of« conversation with Mr. Harmon on May 5th, 19989 ‘A. refuse to answer based on the Fifth Amendment. (Q Is this your bandaiting on this page, sv? A. Trefuse fo anewor based on the Fifth Amvendoeat. Qf yon look at whats ramied as page two con tia page, foward the bottom, itsays: Golkow Technologies, Inc. Casé 18° 18 110319: Control No.: 1511103Gary C. Schultz “Page | = Paget | 2 (Ronding,) Department of Public Weltue, Other boy | 2 (Reading) Psychiatrist or psychologist ~ did interviewed lst night. Similar act-- locker ors, | 2 ainke w report to Child Abuse lotine requesting “wrestling, kissed on bead, 2 department to down investigation. 4 Doyensee that? 4 Doyousee tht, si? 5A Leo. 5 A Tao. © — Q And do-youreall receiving that 5 Q And doyou recall receiving that + faformatioa nnd making thene notes on May Sth, 1998? 7 information and making these notes on May Sth 19987 ‘A. Liefise to answer based on the Fifth MS. KORNFELD: Objection lcs Amendment aundation, lho. styoa look at thenext page, st, PARE io ‘THE WITNESS: 1 refuse to answer 22 thee on tho handiwcten notes, atte topitsays: [12 asedon the Fifth Amendssent 122 Reading.) Hugging ftom behind. Shower. No [32 BY MR. GAGNE: 52 atlegstion beyond that. 3 Q_ Tsthisyour Bndwriting on this pags, st Do-you se that? 14 sire hs A Tee Jas A. refuse to answor based onthe Fit 36 Q. Doyomrecsll receiving that information | 36 Amendnent 27 and making thase notes on May 5th, 1998? 17 Q Do yousecogaize the hendirting on this 30 ‘MS. KORNFELD: Objection, se page? 19 foundation. >A. refute to answer based onthe Fifth 20 ‘THE WITNESS: Trefuss to answer 120. Amendueat. 22. based on tho Pith Amondment lax And does ta information that just ead 122 BY MR, GAGNE: 22 indicate to you tata profesional hnd t Feast a la. Isthis your handwriting on this page, 123 concer that Gerald Sandusky bad acted in a sexually joe ve 24 inapproprste manaer witha minor? Page Pages 2A. Trefuse to answer based on the Fifth 3A Trefue to saver based on the Fifth 2 Amendment 2 Amendment 3 Q And:then on page four, it reads: 3 ‘MS, KORNEBLD: Let me nferpore an 4s (Reading) Bither wey, caseworker felt they would | 4 oljection to tho last question, 5 interview Jeay. Is this opening of Pendoras tox, | § BYMR. GAGNE: 6 question mack, Othec children, question man © Q Thelast sort of bullet point on thet page 1 Did'you write thet down on May Sth, 1998, | 7 reads: (Reading) Somewhat more complicated ds to ° si © Second Mite. 3A Trofuse to answer based on my Fifth 2 Doyon see that i? 30 Amendment, © A Lio, a Q. Please turn tothe next page, which atthe [2 QD you know why this mater reflected in 2 top reads Tom Harmon, May Sth, 1998, Doco this |12 thse notes would be somewhat more complicted de 23. are these your notes si? 25 Second Mile? 4A. rafaco to answer besed on the Fith sa (MS. KORNFELD: Lacks foundation, 5 Amendment. 35 vegne, 46. Anddid you have a conversition with Tom [36 ‘THB WITNESS: { ree to answer 117 Harinon on May Sth concerning tis investigation of |17 based onthe Fifth Amendment, 8 Gerald Sandusky? 8 BYMR, GAGNE: a ‘MS. KORNFELD: Vegue, lacks 32 Q. Lookatthe next page ofthe document, l20 foundation. 30 there’ a typed page? os ‘THE WITNESS: Lrefuse toanswer [22 A Yes. 22 based onthe Fifth Amendment. 22 Q_Ttsan Emil dated Wednesday, My 6, : 23 BYMR.GAGNE: 23-1998, 7:16 pm, from a-- well, flom Gary Sehulte | 24 Q. Andithe first item on this page reads: 24 to Tom Harmon. Do you se that, si? \ Golkow Technologies, Inc. Casei5 141103193 Control No.: 1511103:Gary ¢. Schultz age26 1 A Id, 2 Q And here's an Bomail below in which 8 Thomas Harmon writes: Reading.) Wo ate going to 4 hold offon making any crime logentry. Atthis 5 point ia tne, I can justify that decision because © ofthe lack of clear evidence ofa ecine. 7 Doyou see that? 2 A Lido, 2 Q And didyou receive at E-mail from [to ar Haiaon on May Sth, 1998, at around L148 inthe a moening? 2A. Trefise to answer based on the Fifth 1s Amendment, st Q_ And did you sspond by Baral to 35 Mz, Harmon: (Reading.) Good, Tom. Thanks for 16 keeping me informed, 147A. Teofyseto answer based on the Fifth lke Amendment, 132 Q. Why did you want fo be informed about the J20 matter that Mr. Harmon wes waiting to you about? lat A. refuse to answer based on the Fit 122 Amendivent 23 Q_ Wero you conoeened that an employee of the 24 University wes being investigated for potenti Pages 2 investigation of Me. Sandusky at that time? 2A Trofuse to anewer~ a ‘THE VIDEOGRAPHER: The time is 4 10:26, We're going off video record. 5 (Discussion held off the recor.) 5 ‘THE VIDEOGRAPHER: The time is 7 10:27, Wet back oa the video record, . (MR. GAGNE: Can yon read back the 5 pending question, please? 20 (Question 28d) a1 BYMR. GAGNE: 2 Q_ Now, ifyou look at Exhibit 5, Me. Schultz, 23 there's an Z-mail from Gary Schultz to Tim Curley, 24 Wednosday, May 6, 2:06 pan. Im somry tm going 25 backeto Mr. Cunley's Email. Mr. Curley witess las (Reading) Ihave touched base with the cosch, 17 Keop us posted. Thenks. lke Do-you know who the coach was that 28. Ms. Curley suid he bad touched base with? 20 A Trefuse to euswer based on the Fifth 2. Amendment, 122° Q_ Was that Joe Paterno? 23 A Lrefuse to answerbesed onthe Fifth 38 Amendment, Bege3T ena conduct with ino ia the showers? ‘MS. KORNFELD: Objection, vague. ‘THE WITNESS: Lrefose to answer basod on the Filth Amendment, 5 (Selulte No.5, Bail deted Apel 5, 1998, fom Tim Curley, and E-mail dated May 6, 1998, rom Gary Suz, 1 Page, marked ec idotitiation.) ‘(Discussion held off the recon) 30 BY MR, GAGNE: 21 Q. Me Schulte, Exhibit isan E-mail 22 fiom ~ eotually, vo E-mails ~ on thebotton, en 23 emi dated May Sch 1998, ftom Tim Cutley, Do you 4 seo that? is A Ido. 56 Doyou know how twas that Tins Caley 1:7 beonme avare of the investigation of Mr. Samus in he May 19982 lis ‘MS, KORNFELD: Objection, vague Jae ‘THE WITNESS: Teefuse to answer l22 based oa the Fith Amendment laa BY MR. GAGNE: las Q Did you tell Me. Caley that he Pean 2¢ State police depatment was conducting an Pigs 25 4 Q_ Me. Sandusky at that time was a defensive 2 eeotdinater forthe Ponnsylvania State football 2 teams is that correct? 4A. Liefusoto answer based on the Fit 5 Amendment. © —Q And Joc Paterno was head coach ofthe 7 football tear; ia that correct? © A. Trefuse to answer based on the Fith > Amendment. 130 Q. And Mr. Curley was the athletic director, [st is that comect? 2A. refuse to answer based on the Fith 23. Amendment. ht. Andas athletic director, Mr. Curtey was 35 Mr. Peterno's boss is that correct? as ‘MS, KORNFELD: Lacks foundation, sr ‘TSE WITNESS: Lrefose to answer 2 based on the Fifth Amendment, 13 BY MR. GAGNE: 22 Q_ As of May Sth, 1998, 5:24 p.m, when. lau Me. Curley wrote to you as reflected in this E-mail, 22 had you spoken with either Mr. Curley or Coach '23 Patesno conceming this investigation of Gerald 24 Sandusky? Golkow Technologies, Inc. Casd #8 131103195 Control No.: 15111035Gary C. Schultz - ¥ae30 Patt 2 MS.KORNPULD: Objeoton vague, | 1 she's blanked the name out, Do you meer the 2 lass foundation. 2 au ofthe boy who wa avlved inhi iacdeat in 3 “TUR WITWESS: Its to mover 2 May of 1987 {© bad on Fit Ament 4A. Treftse to easwer bad on the Fh 5 BY MR. GAGNE: 5 Amendaeat © Q Nav lockingatih top of he pgs, e'Q. Anshe sass; (Reading) Baclosed army 4 teeth enrol tn you to. Carley May 6th, | 7 notes regarding blank an ny alls wit him ad hi 1 Lagpan: Qteadng) Wilda, Sice wetted | © mother ine May 3r, 1998, thope hey wil be > tonight Pv lend atc Pole Well people | © veal toe iaveigation, ever ifony ws aol ive tends! They 26 carcboron na Doyouswe tat? 1 Doyou scotia se? hs A Tan 2A ao las Q.Didyousend this Hana to Me. Cufey? [x4 A. Trefige to answer based onthe Filth jas Amendment 26 Q. Andhow had you leaned thet the Public Jar Welfare people would interview someone on Thursey? ne (MS. KORNFELD: Objection, looks las foundation, vague. 0 ‘THE WITNESS: Lrefeso — b= MIR, GAGNE: lim reading the wonts 22 hate wrote, 23 ‘THE WITNESS: Lrefuse to answer 24 based on te Fifth Amendment, 22 Q Doyousecal, did you get a copy of thio 16 letter on orabout May 7, 1998? a5 A” Lrofusoto answer bed on the ifth ls¢ Amendoent. (Q. Have you ever scen this letter before, ai 5A refuse to answer based on the Fifth 20 Amendient. la: Q. Okay. IfyouJook at the second page of J22 tho dosument, and 7m not going to read al ofthis, 2a but om this page, [Lzepreseat co you that Jas Ms, Chambers describes a repott fom the minor's Page aT | BY MR. GAGNE: Q And do you know who the individual wes ‘hat was to be interviewed on Thursday? ‘A. Trefse to answer based on the Pifth ‘Amendment (Gobultz No, 6, Letter dated May 7, 1998, from Alysia Chambers, Ph.D. 3 pages, marked for identification ) BY MR.GAGNE: 2° Q_ Ms, Sehltz, 1 apologize forthe quality 31 on this document, Some ofthe documents we have 22 dont print that well given whatever their source 33 i, but [think we cam work with his. a4" Bxhibit 6s a document dated May 7, 1998, 15 ftom Alyoia A. Chambers, PhD., Licensed 6 Psychologist, to Mr, Ronald Sefueffer, Criminal 27 cetigation Unit, the Pennsylvania State 38 University. 2 Was Mt, Schrofiler employed by the 20 Pennsylvania Stete Criminal Investigation Unit on 2. Mey’, 1998? 122A Trefue to soswer based on the Fifth 123. Amendeont. 126. And Ms, Chambers writes, and you'll see Page 3d 4 mother concerning wit hed oceueed with nim in the 2 shower with Mc. Sandusky. 3 Inthe third fll paragraph, you see 4 there's sentence that begins Mn the owes". Do you see that? Towacd the end of tho hid fll © paragraph. 7 & Ido. 8 Q Olay. Reading.) Inthe shower, he 2 repovted that Jey played « game, coming up botind lo him, saying he would squeeze his puts out and ln tugplg blank feam behind. Blank wanted his mother 22 not to any anything because Mir. Sandusky had 133 promised to tac him fo the movies and tole nim 4 ton the bench with him at Penn Stat football 15 games, Blank tld his mother that he asked ne Ma, Sendusey if se could come with km to foetbel 27 events, because she likes football, and he said no, 18 justyou. las Doyom see that? po A Ido. 21 Q_ Ando yourecall rocaiving this 22 information concerning what had ovcued in the 23 showwor with Jerzy Sands in May of 19987 2 ‘MS. KORNFELD: Objection, vague Golkow Technologies, Inc. casb 1B? 131103191 Control No.: 1511103‘ la» Gary C. Schultz Page 34 “THE WITNESS: Irefuso to miswer based onthe Fith Amendatent BY MR, GAGNE: Q. Adin tha sentence, the young roan apparently deseibes some promises that Mr. Sandusky hhed made to him. Were you ewae in Miny 1998 rat that oct of behavior could be interpreted as wit is etled grooming behavior ena prelude to sexual ats? (MS, KORNFELD: Objection, vapss, ks fouidation, calls for Tegal conclusion. “THE WITNESS: Trofaso to answer based onthe Fith Amendment. ‘BY MR, GAGNE: Q Tovrard the bottom of the page, it sys: (Reading) Taked about ober behavior inthe shower. ‘Do you see that? Towerd the bottom ofthe age. A Ido, Q (Reding) 1 eaked about other behavior in the shower and he suid he eplased him sn played coun, Fle was reluotnnt otal about it, eying he's matrod 0 I dont think he meant anything. Ee he Page 36 | with ho Seoond Mile cots that Mr, Sandusky is casonably intlligont and thus, could hardly have failed to undetstand the way his behavior would be interpreted, if known, His poriton atthe Second ‘Mile and bis interest in abused boys would suggest that be was fkely to have had knowledge with regard fo child ebuse and might even seeognize this ‘eave ae a fypoel pedophile overture Do you see that? A Ido. Q._Ancd wos this information — eas the stofements Ms, Chambers saosin ths paragrep, ‘were thse statemsnts communicated to you in May of 1998 ‘A. Trefose to answer that based on the ith Amendment. Q Now, were you aware in May of 1998 that Atyein Charabers hl concern that Mr, Saudusly was of tight be engnging in pedophile etvity? MS.KORNFELD: Objection, vague. ‘THE WITNESS: Jrofse to aoswer ‘brood onthe ith Amendent. (Gelata No.7, mall dated 181998 to Gary Schult, { page, mck for Pages admittad ho was uscomfortable and he aged that and we agreed that he woulda need to go through ‘hat eg, but he was worried about what to do ext. Do you see that? A Yes, Q And did you tern in Mey of 1998 thet the ‘young bay who had been in the shower with Jar, Sandusky bad told Ms. Chambers or anyone else that he wes uncomfortable with wha had occured’? ‘MS. KORNFELD: Objection, vogue ‘THE WITNESS: 1 refuse to answer ‘based on tho Fifth Amendasent, BY MR. GAGNE: Q Pleags Took at the next page st: ‘There's paragraph that begins "my consultants", do you see that? A Yes, Q Reading.) My consultants wpe thatthe incidents mest sl of our definitions, based on experience and education, ofa likely pedophile's attera of building rst and gradual ittoduetion of pysicl fou, within a context ofa loving special lationship, One colleague who has contact Piges7 ‘dentication) BY MR. GAGNE: Q. Mr. Schultz, Bubibie7 ia an B-mall fom “Thomas Harmon to Gary C. Schultz. By the way, axe you Gary C, Schult, sir? A Lam. Q Dated May 8, 1998, 2:16 pm, Subjoct: Update, Me, Hermon wrote: (Reading) The progrem ‘eptesentatve from DPW was here yesterday. He athered information ftom us andthe Centre County Children & Youth Servic epats. He indicated ‘hati was his intent to havea psychologist who _spocielizes ia child abuse interview the childten, ‘This ie expected to ocour in the nent week to week nd shal I dont anticipate anything tobe done ‘uti that happons ‘Mi. Schult, did you receve this E-mail cen orshout Mey 8, 19987 A. Liefase to answer based onthe Fit Amendment (Q. When Me, Harmon sye that «psychologist ‘was going to interview the biden, did you have em ‘understanding of who thos cildren were? MS, KORNFELD: Objection, vague, Golkow Technologies, Inc. case HB: 1311031 ISLL10: Control No. 9: 3:Gary Cc. Sehultz Page 38 4 Inka foundation. 2 "THE WITNESS: Trefose to answer 3 based on the Fifth Amendment. 4 RY MR. GAGNE: SQ. Anddid yon have en understanding of why a 6 psychologist was going to interview those childven? 1A. Trefuse to answer based on ho Fit 5 Amendment. 2 ‘MS. KORNFELD: Let me interpose an Jno objection tothe last question, lh: BY MR. GAGNE: 22 Q_ Whywas Mr. Harmon providing this lx» information to you? aa ‘MS, KORNFELD: Lacks foundation. a5 ‘THE WITNESS: refuse fo mawer jas bared onthe Fifth Amendmeat lis BYMR. GAGNE: ln Q_ Hind you asked Mr. Harmon to keep you up to 9 date onthe course ofthis investigation? 20 “MS, KORNFELD: Objection, vague. a. “THE WITNESS: [refuse to answer j22ased on the Fith Amendment 23 BY MR. GAGNE: 24 Q_ TnMay of 1998, did you speak to Page 1 May 13, 998,221 pam, says: (Reading) Tim 2 Gualey wrote: Anything new inthis department? 9 Coach is anxious to know wire it stands. 4 Did you weave this mail from 5 Mr, Cusiey on ar about May 13, 19987 6 A. refuse to answer based on the Fith 7 Azeadment. © Q And do you know who Me. Cutley was 2 eferting to when he said coach is anxious to know 20 where it stands"? 2A. refuse to anewer based om the Fifth hia Amendment 3 QWs coach, Coach Patorao? jue ‘MS, KORNFELD: Lacks foundation, hs ‘THE WITNESS: Trefuse to answer [xe based on the Fith Amendment, 17 BY MR. GAGNE: lke Q_ Doyou know why Coach Patemo was anxious > toknow where the investigation stood? 20 (MS, KORNFELD: Lacks foundation. a "THE WETNESS: Lrefuse to mewer 22 based on the Fith Amendment 23 BY MR. GAGNE: 12t Wee back on th vdeo record 2 BY MR, GAGNE: 23 Q Mr, Schultz, Exhibit 8 is a series of le texas Tho fat ons sting the btm, Pagea 2 Thusnday, 14 May 1998 aL 4:11 from Gary Schultz to 2 Timm Cusey. (Reading) Tim, I understand that a 13 DPW person was here last woek; dant know for eure 4 ithe talked with ery. They decided tohave a 5 child psychologist tik to th boys sometime over 6 the next week, Wo wont know enytbing before then, ” to Mr. Curley on Dia you wite that F- ‘May 14, 19987 9A. Lrefisetoonswer based on the Fifth 20 Amendment. hs Q_ And ow did you come to an understnding 2 that a DPW parron had been on the Penn State campus lis the prior week? as MS, KORNFELD: Objection, lacks las formdetion. as ‘THE WITNESS: Lrefuse to ausver 37 based on tho Fifth Amendment. Jas BY MR. GAGNE: 2 Q_ Whenyou say DPW pecton was hete, were you 20 referring to tho Pena Stale campus? 1, MS. KORNFELD: Objection, lacks 22 foundation. 23 ‘THE WITNESS: [refuse lo aaswer 24 based on the Fith Amendment, Golkow Technologies, Inc. Pat caf 9B: 13110319) Control No.: 1511103! |Gary ¢. Schultz ‘Page . ~ Page 44 BY MR. GAGNE: [MS. KORNFELD: Same objection. Did youspeaé to aDPW represent on ‘THE WITNESS: Trefse to answer {he week proc to May 14 19987 based onthe Fith Amendment “A. refuse to answer based on the Fith Amcondent. Q Do you know ife member ofthe enn State police department ted tow DPW representative on (he week pric fo May 14, 1998 ‘A. Lrefizo to answer based on the Pith Ansendment. Q Allzight, Moving sbove onthe decument, st-4t8 pan, May 13, 1998, Totes Harmen yrot (Reading) The psychologist ftom DPW spoke with the child, They have nat paken to him ‘Doyou know, id you receive this E-mail ‘fiom Me, Haumon on or about May 13, 1598? |A. refuse to anawor baad om the Fis Amendment When he ays the peychologit ftom DPW spoke withthe child, did you have an understanding ‘of who the child was? ‘MS. KORNVEED: Objection lacks foundation ‘THE WITNESS: [refise to answer «BY MR, GAGNE: SQ And euat ho top ofthe document, 6 there's an E-mail fiom you to Thomas Hatmon dated 7 Thursday, 5/14/1998, 12:54 pm. (Reading,) Good, 8 Tom. ‘Thanks forthe update and Tages that we want 9 toresolve quickly. he Did you send that Bs fo Mr. Hitmen on 2 May 14, 19982 52 A. Trefuee to answer based on the Fit, 23 Amendnent. 4 Q_ And why did you tell Me, Harmon that you 25 ogre that you waned to resolve the roatec quill? a6 ‘MS. KORNFELD: Objection, lacks 37 foundation, se ‘THE WITNESS: 1 reftseto answer 3® based an the Fifth Amendment 120 BY MR, GAGNE; 21 Q Did yon communicete to Mr. Heron tht you 22 wanted the Penn State police department to petform a 23 thorough investigation ofthe mattor involving + Mie Sandusky? epgnae een geiScorerstateyaqenerel a aged ‘based on the Fih Amendment, BYMR, GAGNE: Q. When it says they have aot spoken to him, id you have an undetstending who "him" was? ‘MS. KORNFELD: Same objection, “THE WITNESS: [refuse to answer ‘based on the Fh Amendment. BYMR. GAGNE: Q Mr. Harmon continues: (Reading) Seis tll my understanding that they inten to do ths. have also been advised that they wan! to resolve ‘Do you ove that A Ido. Q. Whos Mr. Harmon wrote to you on May 13, did you have en andorstanding of who wanted to resolve the matter quickly? ‘MS. KORNFELD: Objection, acks foundation. ‘THE WITNESS: Irefise to answer bbesed on the Fifth Amendment. BY MR, GAGNE: Q Did you have an understanding of why they ‘wanted to resolve the matter quickly? Pape (MS, KORNFELD; Objection, vague ‘THE WITNESS: Lvefuse to answer basod on tho Fith Amendment, BYMR.GAGNE: Q Didyou have a greater concer tat the matter would sinply be recolved and gotten behind ‘yoy sift (MS, KORNFELD; Objection, gue, lacks foundation. a0 ‘THE WITNESS: Ireftse to auswer 1 hased onthe Fith Amendment, 22 BY MR. GAGNE: 32 Q Well, weroyon concamed that Mr. Sandusky 4 as engaging in pedophile activity and that it was 25g matter that shouldbe investigated thoroughly? bs [MS. KORNFELD: Objection, vague a ‘THE WITNESS: Iefuse to answer 126 based on the Fits Amendment 29 ‘MS. KORNFBLD: And tacks }20 foundation. Ja. BY MR.GAGNE: o> Q Didyou instruct Mr. Harmon orany other 23 member of the Penn State police depsctment a 1 how 24 thay should conduct this investigation? Golkow Technologies, Inc. case: 1103195 15111035 Control No.Gary C. Schultz Puget] Sacks foundation. ‘THE WITNESS: 1 refuse to answer besed on the Fith Amendment. BY MR. GAGNE: Q. And when Task this investigation, Im efesing to the investigation that we've bees Glocassing in the last sovral documents concerning incident ia the shower betwean Gerald Sandasky 10 anda young boy. Do you understand that? ns MS. KORNFELD: Same objections. jaz ‘THE WETNESS: Refose to answer a3 ‘based om the Fith Amendonest, ne (Getulte No. 9, Email chain 25 beginning 5/13/98 through 6/9/1998, 2 pages, ss matrked for identitiestion ) x7 BYMR. GAGNE: 22 Q. Mi, Schulz, Bxhibie 9 is mother satis 10 of E-mails, it bogius atthe bottom with Mr, Cudleys 20 B-ail of May 13, 1998, thet] azeady asked you 2 about, which rads: (Reading,) Anytbiag new in 22 this dapartment? Coach is anxious to know where it > etna, lee And then moving up slighty, there's Page A ldo, Q Did yousond that Hamel o Mr. Cxtey on Sune th, 19987 ‘A. refieoto answer based onthe Fit Amendmest Q. Hadyou gone.oa vacation sometime around ‘May 30 or Juno Bth of 19987 ‘A. Trefige to answer besed onthe Fifth ‘Amendment. Q. Pled you bean updated onthe course ofthis investigation coneeming Mr. Sandusky while you wore ‘on vacation? A Lrefise to answer based oa the Fh Arnondeent. Q. When you wile to Me, Curley and exy, "Fora told me DPW and Univesity Police senvioes were planning to meet with hin®, is Tom, Tom Haron? ‘MS. KORNFELD: Lecks foundation. ‘THE WITNESS: Trofase to answer ‘based on the Fifth Amendment. BY MR. GAGNE: (Q. And when itsays "DPW and University Police were planning to meet with him’, do you know ‘ho the “hin is that you were refering to in that Page aT another Bail fom Me, Carley on May 18,1998, 9:57 ‘pan, Do you see tht? A ido. Q. Nove, Me, Cuey wrote, "Any update?” And thon at 946, theres a response: (Reading) No, ‘but I dont expect wel hea anything price to the ced ofthis week, ‘id you ge that Esai to Mr. Curley on ‘May 19, 19987 30 A. Trefe to answer based oa the Fith a1 Amondment ln2 Moving up, there's motber il fom Ina Mr. Curley dated May 30th, 1998, whieh Mr. Caley 14 asks, “Any forthe update?" Do yon see that? as A Tdo. sé Q_ Ani then on Tune 8, approximately fea. days 30 later, there's an B-ual ftom Gary Scultto Tim ne Custey, Subject, Re: Jey. (Reading) Tim, 1 las dont bave en update t this point. Just before 20 Jef fr, assume that's vacation, Tom tld me tht 23 the DPW and University Police services were phuning 22 to moet withhim, Il secif this hes happened and 2 gotback to you. pe Do you se that? ae Page Bem? 168, KORNFELD: Lacks foundation “TAR WITNESS: Irefose to answer bso on th Fifth Arvendment, BY MR. GAGNE: Q Didyou check with Mr. amon and then at, bck to Me Gatey, a stated in this E-mail? ‘A. Trefure to answer based onthe Fifth Amendment Q Atthe top ofthis page, theres au E-mail io you to Thores iaumon dated June 9, 1998, Re: Jey, that cade: Resting.) Tom, Tvebess ‘holding some catch-yp te on my calendar on Monday and T would suggest that wo use a peo of ‘nce ad discuss he status, pare, Lalo recall the atime we talked, you indicated that thers ‘was some aspets ofthat you flt you shoul review with me when we bad a chanes to tall, close ‘pate, Please get hold of oan and ses what time vwlllwork, Than. ‘Di you sen this E-mall to Me, Hazon on Sune 9, 19987 ‘A. refuse to answer besed onthe Fifth Amendment Golkow Technologies, Inc. caSH3: 13110319: Control No.: 151110: | |Gary C. Schultz ~ ‘Page 50 — Page 52 | 4 Q And who isthe Joan thats toftrenved in| 1 closed as en investigation. He was aitle 2 thi E-mail? 2 emotional end expressed conear a to how tis might 2 (MS.KORNPELD: Lacks foundation, | 3 have how this might have adveraly efecto the ‘ THE WITNESS: Trego toanewor | 4 eid, Tor 5 based ot the Fifth Amendment 5 Doyou ste tha, si? 6 BYMR. GAGNE: 6 A Uo, > Q_ Wasthat yourasistet Joen Cobe? 7 Q Didyon receive his Email fom 9A. Trefiseto answer based onthe Fith ¢ Me. Hanon about June 1, 19987 9 Amendment 9A. Trofigetoauswer based onthe Fith so Q_ WasMs. Coble your assistant on Jone 9, lax 19987 22 A_Lreftse to enswer based on the FIA, x2 Amenduent he any otter employees al Penn State who were are of lk» inappropriate conduct by ME. Sandusky with children? aa ‘MS. KORNFELD: Lacks foundation las end vague. 36 “THE WITNESS: Trefuse to answer 17 based onthe Fifth Amendment. he BY MR. GAGNE: 129 Q_ Didyou consider taking stops to prevent 120 Me Sandusky from showering with other ebilduen on 25 the Penn Stale camps? ax BY MR. GAGNE: 2 (MS, KORNFELD: Lacks foundation Q Bven though someone had decided that there [29 and vague, ‘bad been no crime coaumited, di you reogntze that |24 "THE WITNESS: {refuse to answer ~ ‘Page 55 | Page 57 the behavior alleged by the young man and confirmed | 1 besed on the Fifth Amendment boy Mr. Sandusly was inspproprate? 2 BYMR, GAGNE: MS. KORNFELD: Same objections. 2 Q Diidyou discuss with Me. Ourey whether ‘THE WITNESS: Trefese to answer 4 steps shouldbe ton fo prevent Mi, Sandusky on ‘ated on the Fith Amendment, 5 showering with other children on the Penn Stato BY MR.GAGNE: 5 campus? Q Didyou consider diecting the Penn State | 7 “MS, KORNFELD: Sune objections. police department to conduct fut investigation | @ ‘THE WETNESS: Lefise to answer ta determine th identity of other boys tnt 9 based onthe Fifth Amendment, ‘Ms. Sandusky bed engaged ia inappropriate conduct |20 BY MR. GAGNE: wth? (MS, KORNFELD: tm sony, can you ‘eat that back? (MR. GAGNB: That might have been an awkward question, (Question read) ‘MS, KORNBELD: I'm going to object to tat question ag vapne and Jacking foundation. ‘THE WITNESS: I uadewstand the question BY MR, GAGNE: Q. Youcan answer the question, A. refuse to answer based on the Fit 21 Q_ Did you give any instructions to anyone 2 that Me, Sandusky should not be perminted o shower > with children onthe Penn State campus ss ‘MS, KORNEBLD: Same objections. 25 BY MR, GAGNE: is Q —in19987 1:7 A Lrefase to anewer based on the Filth, 8 Amendment. 29 Q_ Did you telk to Mr. Sandusky about tis 20 mattor in 1998? a ‘MS. KORNFELD: Same objections. 22 ‘THE WETNESS: [refuse to answer 23 basod on the Fit Amendment. le (Gehlte No, 11, Series of mails Golkow Technologies, Ine. cabé¥B: 13110319 Control No.: 1511103: eeeGary C. Schultz Page 3B] Page 60 1 dated 5/12098 throogh 69/1998, 2 pages, masked | 2 ‘THIS WITNESS: {refuse enswer 2 faidewitiestion) 2 bated onthe Fifth Amendment, 3 BYMR.GAGNE: 3 BY MR GAGNE: 4 Q Me Schultz, Bxhibit 11 contains another 4 Do-you know who met with Jey Sandusky on 5 series of Family, some of which we've read before, | 5 Monday? 6 tat he top ofthe page, thee st E-mail tom. . (MS.KORNFELD: Lacks fonndation 4 you to Timothy Curley with copies to Graham Spanier | 7 and vague 4 and Thornes Hmon dated June 9, 1998, 608 am, Re: | ‘THE WETNESS: Trofese to answer 9 ery, Do you see that 2 bared on the Filth Amendment, po A Tao. 1 Q_ And did you send this Z-mail to he 22 indicated individoal on June 9, 19987 53 A. Tes to answer based onthe Fit 6 Amendzont 25 Q_ Why were you commonicating with Me. Cutey 26 concerning this matte? 7A. refute to answer based on he ith 38 Amendoent 29 ‘MS, KORNPELD: That question lacks 20 foundation, 2x BY MR. GAGNE: 2a Q_ Grahem Spanior in Jane of 1998 was 23. president ofthe Pennsylvanie State Universi fs 2 that comect? 10 BY MR. GAGNB: 1 Q. TheB-null continues: (Reading) He wes 2 litle orotioaal aud expressed concern esto how 22 his might have adversely affected the child 1 Link the matter hes been appropriately 25 invetigated and T hope itis now behind us. ‘16 Had you made x detecnination a of June 9, 127 1996 thatthe matter had been appropciately 18 investigetd? so MS, KORNFELD: Same objections. 20 "THB WITNESS: [refuse to mswer 21 tavedan the Fith Amendment. 22 BY MR. GAGNE: 23 Q. Why had yon, ifyou di why bad you 24 seached the conclsion that the matter had beea Pages A. refuse answer besod on tho ith Povendavent. Q And why were you communicating with ‘Mir, Spanier conceming this matter? (MS. KORNFELD: Objection, tacks oundstion und vogue. ‘THE WETNESS: Trefise to answer ‘based on th Fifth Amendvent BY MR. GAGNE: lho. What involvement, ifany, bad Mt. Spanior [a2 had prior to June 9, 1998, concerning the x2 investigation of Mr, Sandusky andthe inctent in 13 the shower? las ‘MS, KORNFELD: Same objections, ss ‘THE WITNESS: Tsefise to snswer [36 beedon the Fith Amendinent x7 BY MR, GAGNE: ns Q. The Emil readk: (Reading,) They met 3 with Jey on Menday and concladed thatthe was 20 20 criminal havior and thatthe mattar was closed as 2 en investigation. 22 When youroferonce Jory in this Banal, 23 yas dat Ferry Sandsigy? ae MS, KORNFELD: Lacks foundation. 7 ‘Page oT + appropriately investigate? 2 MS, KORNFELD: Same objections, > ‘THE WITNESS: Trefise to auswer 4 based oa the Fith Amondment 5 BYMR GAGNE: 6 Q_ Docs St that no eiminal charges Ind 2 een ndloated, did ha establish in your mind hat 6 there was noting inappropriate about what 2 Me Sandusky had dono? 30 MS, KORNFELD: Objection, vague, 2 Jacke foundation, a2 ‘THE WITNESS: [refuse to answer 32 based on ie Fifth Amendment. ne (Gehultz No, 12, Department of 5 University Safoy Incident Repo, 15 pages, 6 mated for identification ) 7 BYMR, GAGNE: ne. Mr, Schult, Exhibit 12 is axmuticpage I> document. Itbeas oa the bottom right a number 120 SDD 002540, and it's entitled "Department of la2 University Safty Incident Report", Do you seo 22 that? 2s A Ido, 2 Q. Isthe Department of University Safety, is Goikow Technologies, Inc. Control No.: 15111033Gary ¢. Schultz ‘Page 62 Page 6] 1 thatthe, as of May 1998, was tht the eon State | 2 ‘THI WITNESS: Lrofise to answer 2 police department? 2 hased on the Fith Amendment 3 ‘MS. KORNFELD: Lacks foundation. | 9 BY MR. GAGNE: ‘ ‘THE WITNESS: Ireftseto answer | ¢ —Q_ Didyou ever have any communications with 5 bagod on the Fish Amendment 5 the Ceatre County Distt Attomey's Office © BY MR_GAGNE: § concerning this investigation? 7 Q. Was thee edepartment othe than the Penn. | ‘MS. KORNFELD: Vague. © State police depettnent that was samed the ° "THE WITNESS: [refuse to nsser 9 Depautinent of University Safety? 9 tasod on the Fith Amendinent 30 ‘MS. KORNFELD: Lacks foundation. [30 BY MR. GAGNES ‘THE WITNESS: Lrefie to enswer based on the Fith Amendment, BY MR, GAGNE: (Q. Ifyou lock atthe bottom ofthe page, you see that i's got sh name and signature of Ronald Schreier, Do you see that A Ido, Q_ And, again, going up othe top of the page it sys Mackdent Typo, Administative Information”, Do yau see that? A Tdo. Q. Have you ever seen this ocument before, ai? ‘A. Trofise to answer based onthe Fifth Amondment. Q Did you diet that this report be filed as edminstative information? ‘A. Lrefase fo answer based on the Fit Amendment. Q. Have you ever taced to anyone else at Penn State regarding the contents of this document? ‘MS. KORNFELD: Lacks foundation hs as he Q Thisteads: (Reading) Parent of year cold mate reported that har soa was ogg in the shovor roan by « staff member. Invesigetion detecined that ten year old mate was als hugged inthe shower ata dtfereot time by the same staff moriber, Tavestigation coutining by this depataient ‘und Contre County Children & Youth Servies Buren and the Centre County Distt Attorneys Office, Do you see thar? A io. Q. Doyou understand the this describes the same incident that you bad besa answering questions bout so far this moring? ‘MS, KORNFELD: Lacks foundation and vague. 22 Q. Doyou fnow, ona Department of University [22 ond vague, 23 Safety Incideat Report, what administrative 2 ‘THE WITNESS: Irefise to answer 24 informtion i intended to communicate? Jat based on the Fifth Amendment. Pages Pages 1 (MS. KORNFELD: Vague, lak 2 BYMR. GAGNE: 2 foundation. 2 Q Flave youread this document before? 2 ‘THEE WITNESS: Treftse to aoswer 3A. Trefuge fo anewer based on the Fifth ‘bated oa the Filth Amendment. 4 Amendment. 5 BY MR.GAGNE: 5 Q Ti likeyouto look atthe page that is © Q Ifyou looks the bottom, there's arge 6 santked on the lower sight JDD 2550. 7 black that begins "Parent of year old male". Do | 7 A” (Witness comptis;) © youseo thal? © Q Anthe second fll peragraph on this page 2 A Ido, 9 sends: (Reading.) On May 9, 1998, a 12:10 pam, ‘reporting officer received phone call from Yohn Seasock who is 2 consultnnt with Centre County ‘Mental Health end Children & Youth Services. ‘Seasock advised that his office primacy works with ‘adult offenders but thet they also worked with ‘abused cbildren, Seasock advised that there was ‘some gray ars esa result of the hour be spent ‘with blank. He sai that banks story was consistent. ‘Was it communicated to you in Miry 1998 that Me, Seasock had opined that here were gray ‘nes concerning tis matter? ‘MS. KORNFELD: Vague ad lacks foundation. ‘THE WITNESS: Lrefuse to answer Golkow Technologies, Inc. cabo $B: 13110319) Control No. 1511103)Gary C. Schultz Page age ‘sed onthe Fifth Amendruent 1 lastnight to so blank. BY MR. GAGNE: 2 Bilynk: The game was canceled. (Q Nextpangraph dows, itsays: (Reeding) | 9 —_Blank: Jen, ever since bank went with Seasoce snd thnt hehasnt heard off S2year old} 4 you Ast wook, he's been ating different, he won! 5 becoming e pedophile. Whea asked iit was posable, he ead "poset ‘Wes that information communicated fo you in May of 19987 (MS, KORNEBLD: Vague lacks 32 foundation. [ax “THE WETNESS: Frefise to answer 2 based on the Fith Amendment 3 BY MR. GAGNE: st. Doyouknow if alight of Mr. Seanook’s ss opinion that he hadatt hearé ofa 52 yee old 26 becoming pedophile, es result of that 37 information, do you know when any farther 5 tallcund he's been having nightmares. 6 Sandusky: Blank wes rally upbeat the 7 Fast ie Tc bi, Blank: Did anything happen? What dd you » dot no Sandasky: We worked out lax Sandusky: Did blank say something x2 happened? 3 Blanks When putblankcin bed and kissed 4 him onthe head, his sie wes wet ss Noresponse fiom Sandusky. fs ——Blanke Did blank take shower? fs Sandusky: Yes. no BY MR. CAGNE: fsx "Q. Iyou look at the page marked 2552, 22. yout see on that page i states that Mr, Sandasky :3.atived a the young boys home aad that Detestive 34 Ralsto, if you look a the middle ofthe page, was 25 hidingin the testraam md roosting officer was in ae a bedkoom of te apartment. Do you see that? nz A Ido. 3 Q. And thea there itsays the fllowing is 29. synopie ofthe conversation. Do you ace thal? no A Yen. Jax Q_ And then it says: (Renting) Sandvaly: J22 How are you? sa lak: Fine 24 Sandy: [drove out to the ball eld 32 invesigntion or stfempt was made to determine 28 Blank: Didyou ikea shower? 39 whether Mr, Sandusky bad been engaged in pedophile |29 Sandusky: Yes. 20 activities over a number of years? 20 Doyousoe that, sir? as ‘MS.KORNFELD: Lacks foundation, — [22 A Yeu. [22 vague, calle for a ogalconelutin asc 122 Q._And wos it communicated to you tht 2 pedophile. 23. Sandusky had admitted tothe young boy's mother that pa ‘THE WETNESS: Trofuss to xswor J ‘ne had taken a shower with he young boy in May of Page 7 Pages| 2. bared on the Fifth Amendment. 5 1998? 2 BY MR GAGNE: 2 (MS, KORNFELD: Vegue and lacks, 2 Q Did you direct that any investigation be 3 foundation. 4 condocied to determine whether Mr, Sandusky hed been | # ‘THB WITNESS: Yrofuse to mswer 5 eayage in semtllyinappropsitebebavion with 5 taped on tho Fifth Amendament. 6 children over a sees of yeu? © BY MR. GAGNE: 7 [&MS. KORNFELD: Vagve. 2 Q_ Iflookat the lst poge marked 2554 on 5 ‘THE WITNESS: Lrefise to answer «this docamen, it-says thet: (Reading) On June 1, > basedan the Fh Amendment 1998, at 11:00 an, reporting officer and Jecry Lauro, lxe program epieseuttive, Office of Children, Youth 23. and Fale interviewed Gerald Sandusky. 52 Doyousee that? hs A Yes Ike Q. Attho Lasch Building, University Park, lis What was the Larch Building, si? Ine A. Trefese to answer based onthe Fifth 17 Amendment. 1a Q_ Are there football osm showors in tho jo? Lasch Balin? 20 (MS. KORNEELD: Lacks foundation. a ‘THE WITNESS: Lrefuse to answer 122 based on the Fifth Amendment, jas BY MR. GAGNE! la Q_ Were there football toa showers in the Golkow Technologies, Inc. cake FB: 13110319) Control No.: 15111035 |Gary ¢. Schultz Page TO 1 Tasch Building in 19987 2 ‘MS. KORNEELD: Lacks foundation. > ‘aR WITNRSS: [refuse to answer 4 basod on the Fifth Amendment, 5 BYMR.GAGNE: © Q Thonitsays: (Resding.) Sandasky was 7 interviewed es a eault of ac allegation of soxuel © abuse involving blank, age 11. Sandusky was asked 29 to relate the activition tet occutted on May Sud, 1998, at Lasch Building, specifically what eccarrod Inthe shower. Sandusky stated that e met blank through the Second Mile Friends Program. Did you have an understanding in My of 1998 of what the Secoad Mile Friends Program was? ‘A. Lrefise to answer based om the Fifth ‘Armendment Q. Doyou know what Second Mite is, si? 'A. Tiefise to answer based on the Fifth Amendment Q Reading.) And that he dit invite blank ‘to goto the gym, tbat they worked out and they di taken shower together. Sandusky dd state that he ‘hugged blank inthe shower but that there wasnt ‘anything sexual about it. Sandusky did say that he Paae 72 4 hugged the complaining child inthe shower? 2 ‘MMS, KORNFELD: Same objections. 3 ‘THE WITNESS: [refse to euswer 4 based on the Fith Amendment 5 BY MR. GAGNE: ‘ 17 the University was hugging a child who wes sot his 4 wa inthe showor? . ‘MS. KORNFELD: Seme objections. so ‘THE WITNESS: Lreflse to answer fs. based on the Fifth Amendment 2 BY MR. GAGNE: hs Q_ Thatssye atthe bottom ofthe page: ha Reading.) Reporting officer advised Sandy not 35 fo shower with any child. Sandusky stated he 5 woulda 7 Do you ste that? 8A To, 19 Q. Andwesit communicated to you on June 1 20 1998, that Mr, Schroer had advised Mr. Sandusky lar not to shower with ny child? 22 A. Trefuse to answer based on the Fifth 23 Amendment. 24 Q Did yon ell Mr. Schefflorto tell Q And were yor conoeted that en employee of ia page TT 1 had showered with other boys inthe past. Sandusky 2 sid since the incident happened, he realized he 2 used poor judgment in what he did. 4 Doyou see that, sir? 5A Lsecit 6 Q. Was teommunicated fo you on or abot 17 June 1, 1998, that tis interview with Mr, Sandusicy 6 boa tke place? ° ‘MS. KORNFELD: Lacks foundation, ‘THB WITNESS: Lefiee to answer besed on the Fith Amendment BY MR.GAGNE: Q. And you — were you aware on approximately une 1, 1998, shat Mr, Sandusky hnd admitted to ‘Me, Sohredflec and Mr. Lato that he had showesed. ‘witha numberof young boys? ‘MS. KORNEELD: Vague ead Tacks funtion. 20 ‘THE WITNESS: Liefise to answer 21 based on the Fith Amendment. 22 BYMR. GAGNE: la Q_ And were you aware on June 1, 1998, that as Page 7S 1 Mr, Sandusky not to showor with eny child? 2 ‘MS. KORNFELD: Vague, lacks 3 foundation. _ ‘THE WITNESS: Lrefuse to answer 5 basedoon the Fifth Amendment, 6 BY MR, GAGNE: ® anyone else pleaned to enforce the request that Mr, Sandusky not shower with any child? 30 "MS. KORNFELD: Objection, vague. a ‘THE WETNESS: Irefusé to answer 22 based on the Fifth Amendment 33 BY MR. GAGNE: 4 Q. Didyoutake auy steps to prevent — did 25 you fake any steps to prevent Mr. Sandusky from 16 showering with any chilécen in 19987 ‘MS, KORNFELD: Laci foundation sand vague. as "THE WETNESS: Irefuse to answer 20 based on the Fifth Amendment, ‘2. BYMR.GAGNE: 22 Q_ ia May of 1998, did Penn State University Jae Mr, Sandusky had told the officers that head Golkow Technologies, Inc. [pt cametemty of children on campus? Q. Do yon have any idea how Mr. Schreffer or 23 have any policies, procedures, o: protocols in place CaS: 13110319 Control No. 15111039 |Gary C. Schultz 2 Peon State campus? he (MS. KORNFELD: Vague. an ‘THE WITNESS: Trefuse to answer 22 tased on the Fith Amendment, (Gehltz No 13, Bxeorps from “Thomas Hata Deposition dated November 21, 2014, 6 puges, mated for identification) BY MR. GAGNE: Q Mr. Schulz, Exhibit 13 ae excerpis from seacseip of the deposition of Thomas Hetmon taken on November 21,2014, in the ete of John Doe D versus Gerald Sandusky and the Pennsylvania State Univerty, and I want to read to you some of what Me, Sel what Mr. larson ssi in his deposition, On page 151, fering to one ofthe exhibits Ive shown you, it mya: (Reading) vageT Page7s 1 (MS, KORNFELD: Lecks foundation 2 coaversation with Me. Hsumon in which he expressed 2 and vague 2 toyouhis concem that Mr. Sendusiy’s behavior in 3 “THB WITNESS: I refuse to answer 3 theshower with young boys was inappropriate? 4+ bed on the ith Amendment 4 (MS. KORNFELD: Objection, lacks 5 BYMR.CAGNE: 5 foundation and vague. 5 Q Didyouhave aresponsbiliy for ‘ "THE WITNESS: Trofese to answer 7 eafaring ny protocols, polices or procedures 7 based on the Fifth Amendment. © designed to ensure the afety of children onthe © BY MR. GAGNE: 9 Q And dé yourhave a concer that even though it was determined to be non-cvimina, chat Mr. Sandusky's bohavior with children inthe showers was isopropiat? ‘MS. KORNFELD: Lacks founation and vague "THE WITNESS: Tres answer ‘set om th th Areodnest BY MR. GAGNE: Q. And Me, Baumon i asked atte bottom of page 152: (Reading) And was there any change in polioy, procedure, eny decision made? Answer: No. Do you see that? A Ido, Q Did you dines hat any change in — Page 75, ‘Page 77 + Question: Incidedin a prenthetcl potion of | 2 University policy, procedure — poly or procedure 2 his E-tnail, Mr, Schultz writes, "T also recall the 2 be made as e result of the investigation of 2 latte wo tod, you indicated that thee was 3 Bt, Sandu ia Mey and June 19987 4 some aspecis ofthe hat you fe you should review | & (MS. KORNFELD: Sane objections, 45 withmewhen wehad wchinoe totale" Doyousee | § ‘THB WITNESS: Lieise to answer ae 6 based onthe Pith Amendzeat 7 Annwer: Yes 1 “MR, GAGNE: Can we take five 2 Page 152: Reading) Question: What 0 mines? : aspects of this di you want o seview with Me, Setulkt Answer: Tdontthave ~the best afiny recollection is that wanted to shave with hi my ncems that even if this wasnt a crime, tht it ‘was inappropriate and we should have some conosrms about it. ‘Skipping sbead title bit, fine 1S: ending) Question: And did you have the conversation with Mr Schulte that these events, even though they were concluded fo be nen-criminsl, ‘was someting to be concemed about? ‘Answer: Yes. Tim sure that eg, ‘iow, how 1 explained that or how I couched my words, don real, ‘Me. Sohult, do you recall havinga a2 hs 0 MS. KORNEBLD: Sure. ‘THE VIDEOGRAPHER: The time is 11:14, Wo're going off video record. Recess) ‘THE VIDEOGRAPHER: ‘The time is 11:19, Were buck an th video record. BYMR, GAGNE: Q. Mr. Schultz, in May or Jane of 1998, did ‘you have any discussions with President Spanier ‘concerning the investigation of Gerald Sandusky? ‘A. [refuse to answer based onthe Fifth Amendment. Did you conclude in 1998 that Gerald Sandusky presented danger to children on the Peon State campus? ‘MS. KORNFELD: Objection, vague Golkow Technologies, Inc. cab8 $B: 73110319) Control No. 511103)Gary ¢. [—— Peer | and lacks foundation, "THE WITNESS: 1rofse io answer ‘based onthe Fifth Amendment, BY MR. GAGNE: Q Did you conclat in 1998 that there was & ‘concera that Gerald Sandusky was potentially © sexual predator? MS, KORNFELD; Same objections ‘THE WITNESS: I refuse to answer 10 based.on the Fifth Amendment. a1 BYMR, GAGNB: ln Q Were you aware in May and June of 1998 3 that in prior years, sinors hd disclosed to Pean 14 State offciis that they nd been sexually molested las by Gerald Sandusky? je ‘MS, KORNFELD: Lacks foundation 27 and vagee. as "THE WITNESS: J refuse fo answer 39 based on the Fifth Amendment, 20 BY MR. GAGNE: 2. And wore you aware that those !22 communications went from minors ~ went as far Sehultz Page oo a rofse to answer 3 basod on the Fith Amendment. 4 BYMR, GAGNE: 8 Q Were you involved indiseussions § concerning Mr, Studosky's retirement as an asistent 17 coach at Penn State? * ‘MS, KORNFELD: Vagne. : ‘THE WITNESS: [refuse to answer 20 besed on the Fifth Amecdment, 1 BYMR. GAGNE: 12 Q_ Did Mr, Sandusly’s retirement as assistant 22 coach ofthe Pena State football team have anything, I to:do with his investigation in 1998 for potentiat 5 sexual abuse of minors? hs MS. KORNFELD: Lacks foundation st ane vague, ae “THE WITNESS: Trefuse to answer 119 based on the Fifth Amendinent. 20 (MS, KORNEELD: Just forthe 2. record, Me. Schultz was asisting counsel with 22 hig microphone. 1 based on the Fifth Amendacat. 12 BY MR. GAGNE: 3 Q_ Didyoutake any prior incidents or 14 information into account during the couse of the 25 1998 investigation of Gerald Sandusty? hs ‘MS, KORNFELD: Same objections, 27 vague and lacks foundation, 3 ‘THE WITNESS: Irefase to answer 39 based on the Fifth Amendment. 120 BY MR. GAGNE: 21 Q After the 1998 investigation, did Gerald 122 Sandusky subsoquently ree ftom his employments 24 qn assistant football coach at Pean State? as (MS, KORNFELD: Vague, lacks 23 back as 1976? 2 (Gente No. 14, E-mails between, 2 ‘MS. KORNFELD: Lacks foundation {2 Gary Schultz and Wendell Courtney, 8 pages, Page Paget 2 and vague. 2 marked for identification) a ‘THE WITNESS: [rofuse fo answer 2 BYMR. GAGNE: 3 based on the Fifth Amendeat 2 Q. Mr. Schult this exhibithas soveral «BY MR.GAGNB: 4 pages, ‘Tho Girat page is au Bomail from Wendell 5 Q. Pidyou make any atempt in 1998 otryto | $ Courtey to Cymthia Bain dated January 11,2011 {6 deletmine whether amgone else «tenn Statewas | 6 Do-yon oe that? 7 aware of sally inappropriate conduct with minors | 7A No © by Gerald Sandusiy? © Q Ob, 'm sory, Ihave the wrong one. My 5 ‘MS. KORNFELD: Seme objections, | 2 apologies, Well gt to that onc. a0 HE WITNESS: Irefuseto aaswer [20 Allsight, let’ startagein, There's on 2 Emil from Wendell Courtney ta you, Gary C [22 Skule, dated December 30, 2010. Do yon see tha? ns A do, I< Q_ Doyou know who Mr. Courtney is? ns A. refige to anawer based on the Fit 16 Amendment. 27 Q. lit corectthot Mr. Courtey was an 38 altomey atthe firm of McQuaide Blasko, who from 25 moto time provided representation to Penn State 20 University? ja. ‘MS, KORNFELD: Lacks foundation, 22 vague. 33 "THE WITNESS: 1 refuse to enewer (24 bavod on the Fifth Amendment Golkow Technologies, Inc. cafe$8: 431103195 | Control No.: 1511103.Gary C. Schultz Page 82 3 BYMR. GAGNE: 2 Q Did youseoeive this E-mail fom 5. Mr, Couttusy on or about December 30th, 20107 4A. Trofuse to answer based on the Fifth Amendment. 'Q. Mr. Courtney writes: (Reading) Gary, tho attached is ce lst thing in my Pear State fle +o Sunducky. There i nothing regarding the issues wwe disoussed. 0 Prior to December 30, 2010, did you have ® 13 conversation with Mr. Courtney regarding 32 Mr. Sandusky? 3 ‘MS. KORNFELD: Vague and 34 overbrou as “TUB WITNESS: [refs to answer 36 bayed on the Fifth Amendment ‘based on the ith Aanendanent. BYMR. GAG . Pleese took atthe page marked on the ‘bottom right PSU-DORD-004725, tsa dat ith ‘handwritten masks om it, Do you see thet? ‘A Yes, Udo. (Q. Isthat your handwriting on tis document, sa ‘A. Tels to answor based on the Fifth ‘Amendment, 'Q. Doyou recoguize the handuiting on this page? ‘A. [refuse to answer bated on the Fit Agoendiment. {Q Did you make edits to this drat or any Aisft of Mr, Sandusky’ proposed retirement bond on the Fifth Amendment. 0 BY MR. GAGNE: 2 Q Onor about June 2nd, 1999, was the 2 Univesity engoged in negotialions with Mr. Sancorky 13 regarding his retirement? a ‘MS. KORNFELD: Vegas, lacks Ins foundation, 36 ‘THE WITNESS: [refuse to answer 13? based on the Fifth Amendment 38 BY MR GAGNE: a7 BY MR. GAGNE: ir agreement? 38 Q Do you know wht issues he disoassed with |?° MS, KORNPELD: Vogue, lacks 3 Mr, Courtney prios to December 30, 2010? 19 foundetion. 20 MS. KORNFELD: Vsgue, overbroad, |?° ‘TB WETNESS: Lrefse to anewer 2. and lacks foundation. 21 based onthe Fifth Amendment, 2 "THE WITNESS; Lrefase to answer |2* BY MR. GAGNE: 22 based on the Fifth Amendment, bs Q. Loakatthe next page, the last page of jae BY MR. GAGNE: as tho exhibit. ‘Thor's a paragraph numnbored seven, do Page 8 Fageds 4 Q Andifyou looteat te next pags is 1 you see that? 1 entitled *Confidentist Deaf, June 22nd, 1999, Do | 2 A To, 3 you see that? 3 Q. Anidscven is crossed out i tbat comeot? 4 A Td. ‘ ‘MS. KORNFELD: Document spats for SQ Andis this draft of Mr. Soodusy’s 5 iol, 6 retirement agreement? « "THE WETNESS: There's en X 7 ‘MS.KORNFELD: Lacks foundation, | 7 thronghit ® "THE WITNESS: Leefie to mswor 2 BYMR.GAGNE: s 9 Q Andperngraph soven wits: (eating) “You and the Univesity agree thet public comnwaieation about eachother wil continue tobe positive after your eiemsnton Tune 30, 1999, eping withthe postive refetionship between the partes as of the date ofthis Teter, ‘Do you se tat? A see} Q Did you oross that ou? |A. Trefso to answer based onthe Fifth 39 Didyouhave any pasicipation indraBing [1° Amendsoent ecouewtng ate of Saudnsy’srorement |2 __Q Doyoa ow why Mt Sead oe 23. gpreement? 21 University desired, at lest initially, that 2 "4S. KORNFELD: Lacks foundation, [22 Mr Sendust’s treat agreement contin is laa vague. 12 parsgaaph concerning postive public comomunienians? a “THE WITNESS: 1 efase to answer fae ‘MS. KORNEELD: Objection, vs Golkow Technologies, Inc. CakPAB: 131103195 Control No.: 15111035 |Gary ¢. Schultz od 4d lacks foundation, 2 ‘THE WITNESS: L refuse to answer 3) based on the Filth Amendment, 4 BY MR GAGNE: 5 Q Doyouknow whethor Mr, Sandusky asked for 6 this paragraph, ort was something the Univesity 1 wan seeking? 8A Trofuge to answer based on tho Fit 8 Amendment lxe Was this proposed pacepraph couceming positive public communications in any way related to 12 the investigation of Me. Seadsky for potential a5 sexual abuse of minors? js ‘MS. KORNFELD: Lacks foundation ss and vague 36 "THE WITNESS: Lefis to answec 27 based oa the Fifth Amendment 2 BY MR. CAGNE: 32 Q. Waa Mr, Sendcky asked to retire because 20 of the investigation involving potential sexual }21 abuse of minors? ‘Page 88 fiom Tin Curley to G. Spanier. Do you recognize ‘hat as Graham Spanie’s E-mail address? ‘A. Lrefuse to answer based on the Fifth Amendment Q And there's a CC to ges2@psu.edu on June 14, 199, the date ofthis E-mail. Was that ‘your E-mail udévess at Penn State? A. Trafuse to answer based on the Fifth ‘Amendment Q_ Did you receive this E-mail ora copy of this F-mail rom Mr, Curley on or about June 14, 19997 ‘A [refuse to answer based on the Fifth ‘Amendment, Q. Mr. Curley writes: (Roading) Lhave ‘touched baso with Joe and we are ix agreement that -we should rot do anything more for Jerry. Tm going to meet with him at 11:00 to give him the ‘word. Thanks. ‘Did you have an understanding as to who ‘Joo was meant fo rer to in Me. Cutloy's E-mail? 5 BY MR. GAGNE: © Q_ My-pologies. x7 A. ButTsefuge to answer based on the Fith 8 Amendment, 25 Q. Thankyou rm (Behultz No. 15, Banal dated l2t 6/14/1999 to Graham Spanier, 1 page, marked for [22 identitiostion,) 23 BYMR. GAGNE: Jae Mr, Schulte, the next exhibits eu Bait 2 MS,KORNFELD: Lecks foundstion 22 MS. KORNFELD; Lacks foundation. Jas and vague, 23 ‘THE WITNESS: { refuse to answer as ‘THE WITNESS: Lrefuseto snnwer [24 based om the Fifth Amendment Page? Page A based on the Fifth Amendment. 4 BYMR, GAGNE: 2 BY MR, GAGNE: 2 Q_ Was that Poon State Head Cosch Joe Petesio? 3 Q Doyouknow why Mr. Sandusky elected to | 3 ‘MS. KORNFELD: Lacks foundation. 4 retire, sit? “ ‘THE WITNESS: [refuse to answer 5A Trefuse to answer based on the Finh 5 based on tho Fifth Amendment 6 Amendment, 6 BY MR. GAGNE: 7 Q DidMr, Sandusky have renson tothink, og | 7 Andis Jeny, Jerry Sandusky? © of une 21, 1998, do dato on this document, that | 9 A Trefuseto—~ 8 the University might not speak positively about him | 2 (MS, KORNFELD: Lacks foundation, 20 after his rtivement? 0 Soy. sa. ‘MS, KORNFELD: Lacks foundation [22 ‘THE WITNESS: Thats Guo, 1 2 and vague. 112 refuse to answer based oa the Fifth Amendment, as ‘THE WITNESS: Ibelieve aodate ‘(33 BY MR, GAGNE: Q. Ando you know what prtcipstion ‘Coach Patoso had in disenssions concerning ‘Me, Sandusky retirement? (MS. KORNFELD: Vagus. ‘THB WITNESS: Trofuse to answet ‘based onthe Fith Amendment, BY MR. GAGNE: Q Did Cosch Paterno ever tell you that he ‘wanted Mr, Sanday’ to no Jouger bean assistent ‘coach onthe football team? ‘A Tofu to answer bused on the Fith Golkow Technologies, Inc. cal2 96: 73110319 Control No.: 1511103} |gary C, Schultz pages 1 Amendment. 2 Q. Wereyorawars that a rtiemeat event was 5 held foc Coach Sandusky and Conch Patemo only Put BY MR. GAGNE: (Q Doyou know whether, s of the time of 0 Cooch Sanduaky’'s retirement, whesior Coach Patemo 5a. was upset or happy wit him? a2 ‘MS. KORNFELD: Vagoe. 33 ‘TA WITNESS: Lefise to answer fs Mz, McQusary had given you? ‘THE WETNESS: [rofuse to mswer lho Mr. Paterno: Yes. ‘based on the Filth Amendment, Ja: Me, Scut, do you have eny reason (9 BY MR. GAGNE: 32 ‘believe oc any bass far believing that (Nov, when you spoke to Mr, MoQuenry, was [29 Mr, Patemo's testimony thet justsead fo you is hoe upset? ¢ no truth and accurate? ‘MS, KORNFELD: Lacks foundation (25 A._Lrefase to ansirer based on the Fifth ‘aad vague. 35 Amendment “THE WITNESS: Trefuse to answer a ‘MS, KORNBELD: Can you repeat that bbaod on the Fifth Amendment. Jas question? BY MR. GAGNE: a (Question read.) |MS, KORNFELD: Objection, vague, sd lacks foundation, calls for speculation. (Gebultz No. 19, Transcript of Gary Solilte’s Grand Jury Testimony, U4 pages, mae fo identification) Golkow Technologies, Ine. CabB 9B: 43110319) Control No.: 1511103Gary ¢. Schultz Page 114 Fogo 116 2 THR VIDEOGRAPHER: Wohave ten | * “THE WITNESS: Trefise to answer 2 minutes of media remaining. 2 based onthe Fifl Amendmeat. 3 MR.GAGNE: Okay. 3 BYMR, GAGNE: «BY MR. GAGNE: 4 Q- Tele you to tur to page ~ the tind 5 Q. Me, Schull, Exhibit (9 states thatitis | & ‘page ofthe document its page sine of the «a ranserigt of roceodings of Grand uy dated | tamsrit ME Sebultz. 5 enum 12,2011, and itsays ite the testimony of | 7 A. (Wins complies) Yes. © Gary Schultz, Do you seo that? © Q. (Roading) Question: You said that you 2 A Ido, 9 did notbave-~ di you ever meet directly with Mike se. Didyou give testimony before the Grand 4° MeQuessy? 23 fury on of about January 12, 2011? Answer Yes. fia A. Tofuso to answer based on the Fit 22 Question: Whe? a3 Amendment. 32 Answer: I don recall the exact re AG Wha jou geve this testimony on Sone 12, [> cicumetanes. Yn Ft thie moming when 35 2011, were you mpresented by counsel? 35 you asked me question that ft recalled that fis AL Trefuse to angwver based on the Fifth 26 there was such a meeting. Ja Amendment. 131 Question: ‘You dant reall where it tole sa And was tet counsol Cynthia Baldwin? [+6 ples? 1s A Trefise fo answer based on the Filth 3 Answer: [think it occured in my ofes, 120 Amnendient. 20 Lbelieve. ee a) Wer Me, Baldwin your alomey, ordi he [22 Mt Sol, whee your office on the 22 represent the University? '22 Pena State campus? a3 -A._ Iresise to answer based on the Fit faa A. Lrefise to answer based on the Fifth 34 Amendment. [24 Amendment, Page ii ~~ Page 117 4 Q estates thet connsel from the Allorey 3 Q. Whenyou were employed by Penn State 2 Genera, Jonell Bebbach and Frenk Fina, were 12 whom did you report dreetiy? 3 resent, Hed youptviualy mot itn. Faibechor | >A. refeotoanewse posed on the Fill ‘Frank Fina prior to giving testimony before the 4 Amendment. 5 Gund Joy? 5 Q Did youreportto President Spanier i 6 A. Trefuse to answer based on the Fah © 2001? 7 Amendent, 7A Tuefuse to answer based an the Fi8h 8 Q Did anyone from the Attorney Generals © Amendaent 2 Office interview you conceming alleged sexs 5. Were yous member of President Spaniers 0 nioonduct by Jerzy Sandusky? ‘10 President's Council in 2001? sa A. Trefase to answer based onthe Fi, 3x A. Tafage to answer based on the Fifth x2 Amondarent. 2 Amendment. 39 Q_ Dis anyone fam the local Dietiet ss. Contiasing on tne 19, eee nine: Sa aveomey's Of ntcview yo orqustonyon 24 (Reading) At st id Mr. MeQueary relate to ecg lege iappropsit ceaaconaet ty |*5 you what obeys what he had observed in tho 36 Me. Sandusky? 26 locker room? fsx A. Trefose to answer based onthe Fit. a7 newer: No, My recollection was MeQuenry 38 Amendment. se and Joc both only described wht was observed in iss Q Did the Peaasyivaia Sate Univesity las very general way. Thex> was no details. bo pico depatmentintseviow you oc rset wi you 20 hen goa BE that response, was Jos, Joe 22 conoeming alleged sexnal misconduct by Seay lax Paterno? 2 Sandusky? fas A. Lofose to answer based on the Pith 3 (MS. KORNFELD: Whea? Ja3_ Amendment. a MR.GAGNE: Atany ine. aa Q_ (ending) Question: Did you, Golkow Technologies, Inc. aS HS: 18110319: Control No.: 1511103:Gary ¢. Schultz Page 118 nevertheless, form an impression about what type of ‘conduct this might have been that oveutred in the locker room? “Answer: Well 1had the impression that ‘twas inappropriate. Telling you what kind of ‘thing had in my send withoot being clear, without hha eling me, but, you know, Thad the esting that there wes perhaps same kind of wreling around activity and maybe Jey might have grabbed the 20 oung boy's genital or something ofthat soc, 11 Kind ofthe impression thd, 112 Question: Would you consider dat tobe 1.8 inappropriate saxual conduct? 14 Answer: Ob, absolutely, Well, I dont 15 kaow the definition of sexual, but thats certainly 6 inappropriate for somebody to do. 27 Question: It would give you pause or 26 concern fan sdult male end an underage male were > in a shower snd tht adult male grabbed the genitals 120 of te younger male? 2 Answer: Yes, o2 Did Freed that accurately, sic? aA Yes, 1 hin you did. 24 Q_ Andis this en accurate transcription of Page 120 1 (Reading) Question: Did you consult with Tim 2 Curley a8 to what would be done as a result of this 2 2002 teport? 4 And just, by the way, Mr, Schultz, 1 think 5 thas since beon determined tht this incident 6 boing desoribod hore occurred in 2001, but in this 7 recor, the date of 2002 is used 8 Deyor have «personal recollection as to 2 when Mr, MeQQuesry told you about Mr. Sandusky's 20 contact with a child in the shower? ss MS. KORNFELD: Lacks foundation Jaz and-vague, 3 BY MR. GAGNE: matte and conclude at you would tell Jeny lhe Sandusky that he should not be bringing Second Mile li kids onto campus? 20 ‘MS. KORNFELD: Objection, vague lar and lacks foundation, laa ‘THE WITNESS: Tsefuse to answer [23 bavedon the Fifth Amendment. lat BY MIR. GAGNE: Golkow Technologies, Inc. Ca8@ 5: 13110319: Control No.: ISLLL03cary ¢, Schultz “Fog 22 Page Tat 1 Q. How did you intend to enforce wrequestto | MS. KORNFELD: Same objections. + Me Suadusty that he not bring children coo campus? | 2 BY MR. GAGNE, 3 ‘MS. KORNFELD: Vague lacks 3 Q -rin20017 4 foundation. « ‘MS, KORNFELD: Sante objections. 5 ‘THE WITNESS: Trefisoto answer 4 “THE WITNESS: Trefuse fo answer 6 bosed on tbe Fifth Amendment. 6 basedon the Fifth Amendstent 17 BYMR. GAGNE: 7 BYMR.GAGNE: 2. Wasthese any menos in place thet would 5 Q. Nowy you said a the end ofthat answer, 4 pennityon enforce a request to Mi Sandusky iat | # you sid “Thave a recollection that we asked the 1.0 vot big Second Mile Kis onto carpus? 20 Child Protection Agency to Jookito tho matter." hs He MEnLD, Sarecbjeaions. | Did you have an understanding of what he child a2 ‘THE WITNESS: [rufus to anrwor 22 protective agency was? Jas based on the Fith Amendment 33 ‘MS. KORNFELD: Lacks foundation, 4 BY MR. GAGNE: ae vague. as @_ Didyou arMe, Caley oranyone ols a5 “Tum WITNESS: [refuse to aswer ne potty Penn Stlepoice department eninstuc! 36 aed on the Fifth Amandine > thei bar Me, Sandusky ftom bxiging children ona |*7 BY MR. GAGNS: is. Was tthe some Child Protection Agency 38 campust las 18, KORNFELD: Sore objections. 29 that had pcticipatd in the 1998 investigation of 0 "THE WITNESS: refuse fo answer 120 Mi, Sundusiey? 21 based on the Fifth Amendment at ‘MS. KORNEELD: Same objections. 22 BY MR. GAGNE: i22 ‘THE WITNESS: T refuse to answor ed bulyonorMe Caley canonseloegive | _basodon the Fifth Amendment: pe inssootons to anyone to bar Mr. Sundeskyftom | BY MR, GAGNE: age 1 Page 5 1 being on eampss with Second Milo chico? 4 Q Didyou, in 2001, contact any eid 2 RE ORNEELD: Objection, vag. | 2 protentve apne concerning Mr Senne? 5 ‘THE WITNESS: Trefse to easwer 2" A. Lrefise to enawer based onthe ifs 4 based on tho ith Amendment, Amendment 5 BY MR. GAGNE! SQ. Doyouknow whether Me. Curley did that? 6 Q. DidyouorMr, Oley or anyone give 6 A. Trefigetoangwer based on tho Fits + inawuetons to anyone to bar Me, Sandusky from any | 7) Amendments 1 locker rooms or ehawets on the Peon Site campus? | Q ‘Do you know whether anyone on behalf of ° ‘MS, KORNFELD: The question is 9 Pain Site asked any child protective ageacy to Look 0 vague and lacks foundation, ond he price 20 ino tho mater involving Mr. Sandusky? li: question Inked foundation, ao wel a MS. KORNFELD: Objection, vagne, pe "THE WITNESS: Lrfusetoanswer (1? "THE WETNESS: [refuse to awe 13 based on the Fifth Amendment. 123 based on the ith Amensiment. na (MR. GAGNE: Im just going to se BY MR.GAGNE: is pointeat, Lind, nresponsstoyourcontiming p> Athens 7 tt ths testimony tthe ve Sbjeoons that the oly eason the questions [»¢ rand Try. i834 Sow whether that satement at 7 jack foundation is because Mr. Schatz wont +7 the University asked. child protection agency 0 pee nem, Buty may ake you objeciens.|3# Tokio th mater wes geass! bs 1M, KORNFELD: You have your view |}? ‘MS. KORNFZLD: Otjection, vu, J20 and Ihave mine. 20 _acks foundation. Jax BY MR. GAGNE: jax ‘THE WITNESS: Trefise to answer sa Q. DidyouaeMr, Cley or anyone ese take 72 ‘based on the Fith Amendmest. tape ta ake ney Me Sandusky ey or ry othr] BY MR. GAGNES oa aneans of aczess he had to facilities on campos 2 Q ‘id yoo atteupt to find out who the child Golkow Technologies, Inc Cab. 110319: Control No.: 1511103cary C. Schultz = reste] Paes 1. was that Me, MeQueery had seen inthe shower with | 1 calls fore log! conctusion 2 Mr, Sandusky? 2 “THR WITNESS: Lrofus fo answee 3 ‘MS. KORNFELD: Lacks foundation | 2 based onthe Fifth Amendmeat, 4 and vague. ‘ ‘THE VIDEOGRAPHER: Excuse me, Wo . "THE WITNESS: Irofuse tosuswer | § —_needtotakea break, Thisis the end of disk 6 booed onthe Fith Amendment 6 number ono in te deposition of Gaty Schl 7 BYMR. GAGNE: 11 ‘Tha tine it wow 12:07, were going off video 4 Q Did you direct orsuggost that anyone else | # —revord. 2 attempt io ascertain the identity of tech who | 9 (A rocess was tao fom 12:07 pam, ae had been seen by Mr. MeQueaty in the shower with fs Mie. Sandusky? pa ‘MS, KORNFELD: Lacks foundation las and-vague. ha ‘THE WITNESS: 1 refuse to answer Jas besed on the Fifth Amendment. 36 BYMR. OAGNE: 37 Q_ Did you have any concern that this child 36 inight be an ongoing victim of Mr. Sandusky? hs ‘MS. KORNFELD: Same objections. 120 ‘THE WITNESS: Trefuse to answer Jax based on the Fi Amendment. 22 BY MR. GAGNE: 123 Q_ When you spoke to Mr, McQueary, did you 34 {ell him whetber bis ations with regard tothe 20 1227 pm) pa ‘THE VIDEOGRAPHER: The tine Ina 12:97, We're back on the video record. This 23 isthe beginning of isk momber two in the 2¢ deposition of Gry Schmit, as (Discussion held off the record.) 16 BY MR, GAGNE: 27 Q_ Okay. Contiolng along wit your Geand x6 sary testimony, Mr. Sella bs A Yes. 22 Q. —Tooking at page 13 now ~ itmight be 21 onthe next page from where you a0 ~ 22 A. Right 23 Q._ = theresa question on pege 13, line le six: (ending) Were you, yourself, ever Page 137 2 incident he deseribed had been appropriate or not? 2 (MS. KORNFELD: Same objections. a “THIS WITNESS: [refuse to answer 4 based on the Fifth Amendment 5 BY MR. GAGNE: & Q Doyoubefieve that Coach Paterno acted 7 appropriately in response to Mr, MeQueary’s © description to him ofthe incident be hed seen? 3 ‘MS. KORNFELD: Same objections. ae ‘THE WITNESS: Trefiee to auswer 2 based on the ith Amendment. 52 BY MR. GAGNE: 32 Q_ Why didst you and/or Mr. Curley contact 36 police or other authorities rather than simply tlt as Jerry that he shouldn't be bringing Second Mile kids 36 onto the campus? hr ‘MS. KORNFELD: Same objections. is ‘THE WITNESS: Lrefise to answer 29 based oa the Fith Amendment J20 BY MR. GAGNB: lax Q_ Did you have eny understanding as to 22 whether contact with the young boy's genitals ea yout 23. described in your testimony was a cts? 24 ‘MS. KORNFELD: Sune obj Page 9 2 questioned with regad fo the'98 incident? 2 Answer: I don't recall Iwas, no. 2 Question: Do you knw ifany ormnnal 4 charges arse from the 1998 report? 8 Answer To the best of my knowledge, 6 there were none. 7 Question: What did you understand the © 1998 incident, in a general way, to allege? 9 Answer: Again, Tthought it had some 20 basis of inappropriate behavior, but without any 2 specifics all, a2 Is that en accurate transcription of 2 testimony you gave befare the Grand Jury, sit? is ‘MS. KORNFELD: Lacks foundation 5 and vague. hs “THE WITNESS: 1 refuse to answer la? based on the Fifth Amendment. hs BY MR, GAGNE: 39 Q_ Andis that in act, your understanding 20 of what had occurred in 1998, that it involved some '2 inappropriate bebavior? 2 ‘MS, KORNFELD: Same objections. 2s "THE WITNESS: Trefuss to answer 24 based onthe Fifth Amendment, CadPAS: 13110319. Control No.: 1511103 Golkow Technologies, Inc.Gary ¢. co 3 BYMR.GAGNE: 2 Q Andwhon Mr, Cudey and Ma, MeQueny tld 4 yo coal bt there ed Bee a posi 5 iavesigaion of Me. Sandusky fo poteatil sexual 6 rharpof.amlor in 1998? 7 MS. KORNFELD: Zacks foursion 8 aad aan. . "TH WITNESS: Irefuse to atswor 0 based on he Fin Amendment a BY MR. GAGNE: 22 Q_ Onptge 14, beglaning snes fs (Reading) Quetion: You didnot moet with Jerr I Sandusky about ny of ve incident wiatsneve? 5 Answer: No,T didnot sé atlat cea, i? ny A Lefts to anawerbxsed onthe Fit 38 Amendnet 9 Q. (Renting) Questo: Did Tim Cariy 20 pont bck to you shout is contact wi ery 23. Sandusky regarding ho inceot fo 2002 oa Answer: Let sny Tarsue. Thadtho 23 impresio hat Tm dl fellow throug ud mao ace a4 Sony wderstood that be was no longer permite to 4 yousont the incest in 200 nvlving Me, Sandusky, ) 3 Schultz Raf 2 based on th Fifth Amendment, 2 BYMR, GAGNE: {Q Pélike you totam to page 17, please 4A (Witness complies) 5 Q. Beginning at line cight: Reading.) 6 Question: Did you, youre dreotty consolt with 7 Grabam Spanier, the president of the University, conceming the 2002 incident? 9 Anawer: Thelieveso, Twas azoatine 20 ay ofkind af a soutine way of kind of handing 11 basiness, that [wouldve kad a converstion with 13 the president about such a mate, Yes, bd ‘Do you recall giving that testimony to the 2 Grand Jury, Mr. Schulte? hs A. Trofige to answer based on the Fifth 26. Amendment. x7 Q. Tsthat an accurate statement of a routine ae way of handling bosines between yourself and 29 President Spanx? 20 MS. KORNFELD: Vague and lacks jai foundation. 22 “TELE WITNESS: I refuse to answer 2a based on the Fifth Amendment. ]28 BY MR, GAGNE: Tothat accurate, Mr. Schult? ‘MS. KORNFELD: Lacks foundation, ‘THE WITNESS: Lrefuse to answer 30 based on the Fith Amendment. a1 BY MR, GAGNE: 23 the plans you bad made after leacning of the 2001 34 incident? hs MS. KORNFELD: Lacks foundation sé and vague. b7 "THE WITNESS: [refs to answer 9 based on the Fifth Amendment. 39 BY MR. GAGNE: 120 Q Do youknow, in fact, whether Mr. Curley 22 2001 incident? 23 ‘MS, KORNFELD: Same objections. 2a “THE WITNESS; Lrefuse to answer a Q_ Did yourely on Me. Curley to follow up on}? 17 a. Spanier say? ® ‘MS, KORNFELD: The prior question 5 Jacked foundation and vague, and this one Teck Jxo foundation and is vague. a "THE WEINESS: 1 refuse to answer ‘based on the Fith Amendment, hs BY MR. GAGNE: 1s Q_ Did De. Spanier express any concesn Page DT Page + bring Second Mile children into the football 4 Q_ Why would you have discussed the 2001 2 faility. 2 incident with Dr. Spanioe? sere Gaoston: Did you, youself everatampt | 2 A. Trefietomnewer based onthe ith 4 fo determine the identity or age ofthe boy in tke | + Amendment, 5 shower in the 2002 incident? 5 Q. When you told Dr Spanier about the © Answer: No. 6 incident tat Me. MeQueary had observed, what did a cegarding Me. Sandusky's conduol? as ‘MS. KORNFELD; Same objections. 37 "THE WITNESS: refuse fo answer Ine based on the Fifth Amendment. 9 BY MR. GAGNE: 20 Q. Page 19, beginning eine four: ee did allow upon the plans you mad regarding ho |? Roading) Question: 1 2002, when you esas 22 aware ofthis allegation inthe shower, did you then 123 seck out the 1998 reportto find out what it was >a dat Sandusky specifically was alleged to have done? Golkow Tachnologies, Inc. cafe: 13110319 Control No.: 1511103Gary C. Schultz Page 136 | ‘Answers They asked iff ould come over to my ~ tthe could come over tomy fis to s6° J bevause tho athlete dicectr, Mr, Caley, ad foun appracbes by a member of his tat saying hat te was somewhat uncomfortsbl because Fury Sunasky {in he febal bug locker room aren the ‘ower was with younger eid end that thy were Iposing aro in the ower. Lbetiowe tbat vst the langage tat was used. ‘Mi. Sel, wat the language “bos round" thet what you and Mr Caley comaunicted to President Spanier’? ‘MS. KORNERLD: Lacks foundation and vag. "THE WITNESS: rose to answer ‘sed onthe Fit Asmendvent BY MR. GAGNE: (Q Dr Spanier continues: (Reading) T ont smemberepeifically whether itwas Tim Cif ot Gay Schult who eotally mad that ‘atement, but thet was essontaly the entirety of ftir atterent, They sad thatthe individ thought he saw —aud Tthiokthecharactsizaon ‘as heto thought he saw them rain around i Fags 34 Answer: No, Lid not, 2 2 Doyouce thet, Mx, Scale? a 2 A ida > 4 Q Did you give that testimony before the ‘ 8 Grand Jury? 5 6 A. Trofune to answer based onthe ith ‘ 1 Amendment. 7 fe Q. Wasthat testimony scomnte, Mr Sete? } & 2 “MS. RORNFELD: Lacks foundation | 9 jroand vege. 30 aa "THE WITNESS: Leefuse to answer [4 22 sedan the Fifth Amendment. 32 bss (Gehultz No. 20, Transcript Grand na fe Jaxy Testimony of Graham Spanier dated April 13,4 25 2011, 44 pages, matked for identification ) hs s6 BY MR, GAGNE: a6 7 Q_ Me, Schulte, Exhibit 20 is labeled as 7 se Transcript of Proceedings of Grand Jury dated = 8 32 Api 13,2011, The witness is Graham Speer. 43? lao Tse you to take Jook st page 13, please 20 21 A (Witness comics) a. a2 Q. Going to line Lt: Reading) Question: 72 123 During your tare es president of Penn Stte * ae University, wes there an occasion where officinls |? : Page 5 1 came to you with information about Jerry Sandusky? | * 2 Answer: There wesnever ate wientbe |? 2 University police approached me witha issve 3 “+ concerning Jey Saudasky. There was onetime when | € ‘5 our alhfti director and seatorviee president, tke | $ < two individuals you mentioned earlier, came toseek | $ + my advice on amatec eating 0ey Seely. | 7 a Question: Sots, Schltzand Me. Culey? | 9 Answer: Yes. 2 _Did you and Mr, Curley approach President +0 an. Spanier regarding Jerry Sendosiy at aay time? a az MS. KORNEELD: Vague, overbrosd. [12 3 BY MR, GAGNE: a3 ne Q. Regarding Mr. Sexdusky's activites with |*4 25 childien at any ime, as as ‘MS. KORNFELD: Objection, verve, | 37 ‘THE WITNESS: Trefwse to onswer in jae based on the Pith Arsendinont he 13 BY MR. GAGNE: as 120 Q. Going Wo page 14, beginning at fino ten: 20 23. (Reading) Whet init tat they informed you, end 72 22 ityou could tell me, agnin, ityourecoltect, who 27 >> wes itemong those two gantemen who spoke fo you 79 24 ad relayed the information? 2a Golkow Technologies, Inc. ee Page 157 the shower and he was alitle uncomfortable with it, so he beought it to Mi. Curley’ attention Do yoo sce that? A Téo, Q. Do you know whether it was Mz. Caley oF you wo said this to President Spanier? ‘MS. KORNFELD: Vague, lacks foundation. "THE WITNESS: [efi to apswer besed on the Fifth Amendment BY MR. GAGNE: (Q. And wasit your undesstanding that ‘Me, MeQueary was encomfurtable with wa he bad seen? MS. KORNFELD: Vagre, lacks foundation. "THE WITNESS: [refuse fo answer ‘based on the Fifth Amendment BY MR, GAGNE: (Q. On page 15, st ine 22, Dz Spanier soy (Reading) Wel thoy felt was an awleverd situation and just wanted to know what my advice ‘wes. Sol gave thom my advice. Di you or Mk, Curley commuicat to Control No. cafe: 13110319 ;cary C. Schultz Yage 138 1 President Spanier tat he incident that 2 Me, MeQueary had seen involving Me, Sandusky wasn 2 awkovard situation? (MS. KORNFELD: Vague and ace foundation. ‘THA WITNESS: Refuse to answer ‘beso onthe Fit Amendeent, BYMR, GAGNE: Q Io fick eho potential evn! abuse of ints it propriate to churacterize that as pa MS. KORNFELD: Lacks foundstion, 23 angumantative, vague, u “THR WITNESS: Trefuse to answer 5 basedon ho Fith Amendsnt 146 BY MR. GAGNE! lx Q_Thenompage 16 in the second fill 28 paragrph, he says: (Reading) But we jst thought 39 it~ thought end tld them tat oometing ike 20 that eould be zconstued and probably we wanted to 2s. discourage people binging youngec Kids into oar 22 faites. So my advice was tht they should do 2 ro things: that they should inform Mf, Sandusky [24 chat bas nota good practice to bring peopla a0 Bags 140 | any plans fo prevent any children under the age of 18 enler Peon State locker rooms and showers under any sirumstnces? (MS. KORNFELD: Vagoo lacks foundation, ‘THE WITNESS: Lrefuse fo answer based on the Fit Amendment, BY MR. GAGNE: Q. Was here any plan to prevent any adult ‘employees of Pens State fom bsing inthe showers ‘with minor? MS, KORNEELD: Same objections ‘THB WITNESS: Lrefise to answer ‘ase on the Fifth Amendment BYMR, GAGNE: Q Did you tell ~ did either you ot ‘Me. Cie tll President Spanior that the incident ‘Mr MeQueacy iad slated was sexual in nator? ‘A Trefise to answer based on te Fifth Azwondment. Q Dis you tell President Spanier, consistent vwith your Grand Jay testimony, thatthe incident (Mt. MeQueaty ad seen or described involved Gerald Sandusky making contact wit the genitals of a Page 135 2 under 18 into our locker room feciltos aud weld 2 ike to nak btn not to do that going forward 2 secondly, we thought since he was no longer employed 4 by the University and we really didet have eny responsibility fork a that point in te, that 6 we should algo, a mattr of pridenc, sontuot the 17 chair ofthe boszdof the Second Mile to simply {8 inform thet individual thet we-were concersed about {9 Second Mile chilren being brought ito Penn State 30 12 Tocker felts and we wore gong to ak that that not ocour, Idhak that cell was made by Tim ‘Catley. Those are my two pices of advioe on that ‘Do you recall ~ or did President Spanier 34 advise you end Be Curley that Mi. Sandusky should 25 not bring Second Mile children ito Penn State 36 locker room fais? x7 A. (refusoto newer tht based on the Fath ne Amsendroent. 2 Q_ In2001, Pon State conducted football 20 caraps and other programs involving minors wader the > age of 18, diditnot? 122A. refuse to answerbased on the Fith 123. Amondeent. 2 Q_ Doyouknow, in 2001, whether there wore Page aT sino? (MS, KORNFELD: Lacks foundation, vege, ‘THE WITNESS: 1reftse to answer based on the Fifth Amendment, BY MR. GAGNE: Q Take you to turn to page 21 of tho exhibit, pleas, line 12 ‘A. (Witness complies.) Q (Reading) Question: Wes there xy iscossion about reposting the matter to the polios ‘0 Children & Youth or any other type of pubic. agency? ‘Answer: No. ‘Question: Was there any impression by you that that had been done by etter Mr Schaltz oF Mr, Curley? “Answer: No, ‘Was there aay impression by you that that had not been done by Mir. Schultz or Mr, Curley? ‘Answer: No. (Question: Was ther any discussion or {information provided to you about any prior allegations against, Sandusky involving chides? Golkow Technologies, Inc. CaBO PB: 48110319. Control No.: 1511103gary C. Schultz a age 142 ‘Answer: No. ‘Question: Were you ever infosed before 1991 that there had been an allegation in 1998 tat ‘Maz Sandasiyy was in one ofthe Penn State University stuoweis with two young:men ad that contet fd ‘occurred? ‘Answer: No. (Question: Were you ever informed. in any vay, shape or frm, agai, prio to 2041, thatthe Penn State University police had invetigated allogstios of potential sexual misoonduct by ‘Mr. Sandia? ‘Answer: No. 1 fac, Ma, Scat, bad you nt informed De. Spanier in 1998 of he Penn Stee police investigation of Mr, Saudusey? (MS, KORNFELD: Lacks foandation, vague “THE WITNESS: [rfuse to snswer ‘sed on the Fifth Amendnent BY MR, GAGNE: Q Ise Spanier’ testimony on page 21 vcorate when he sates that there was no discussion ‘of reposting the mater othe police or any other Page 144 MS. KORNBALD: And lacks foundation, BY MR, GAGNE: Q Plesse turn to page 25 ofthe exhibit A. (Witness complies) 5 Q Begianing at ine 21: (Readings) tn your 6 discussions with Me, Curley and Me. Schultz ia those + miomeats that they came to you and tld you ofthis « howseplay, we tore any indication that the 9 horseplay could have been sexnal in natute? a0 Answer: No. his, Spasie’s Grand Jury tstimsony 12 ocoate that neler you nor Mr. Corley described 2 the incident to him a5 sexual in nature? (MS, KORNFELD: Vaguo. ‘PHB WITNESS: I reftise to answer 6 based onthe Fifth Amendment. js ‘Gchulte No, 21, Handweiten notes jst dated 212/01, ftom Gary Schulte, and E-mails, 19 5 pages, mk for identification.) 20 BY MR. GAGNF: 21 Q. Mr Schutz, Yfke youto take a Took 22 atthe first page of Exhibit 21. This appears to bs las a sheet of paper with to logo of Pean State, nd 26 its dated 2/12/01 ftom Gary C. Schultz, Do you see a9 that there wes no discussion of efercig the mater {oa Children & Youth agency? MS. KORNFELD: Cals for spocalation "THR WITNESS: Lrefise to answer Deved onthe Pith Amendment, [BY MR. GAGNB: Q Tr fick as you sit ace today, do you eve wheter the 2001 incdent cserved by Mr, MeQueary was ever refered by myone erployed by ‘Penn Sta prior to 2011, ta cildron or youth spotuctive agency? (MS. KORNFELD: Objection, egue, ‘THE WITNESS: Trefuse to answer ‘ated on tbe Fh Amendment = Page re 2 typ of pollo agency? 2 hist 2 MS. KORNFELD: Lacks foundation. 2 A Ido 3 “THE WITINESS: Tefise answer > Q Doyousee yournsme on the document, si? 4 busedon the Fit Amend. 4A Yeu tdo, 2 BYMR.GAGNE: 5 Q. J thet your handwriting on this document? 6 Q. Youmay cll, Me Schult, your Grand © A. Ttefase to answer based on the Fifth + tary testinony tat youbelove tha Mr, Carey bad] 7 Armondmest. refered the matter toe child peotestve agency. © Q Didyon create this note on or about 9 Do you know why De. Spanier would have tested | 9 February 12,20017 30 A. Lrefse tp answer based on the Fifth 2 Amendment. 32 Q_ Did you communicate ~ did you provide a 22 copy of this note to anyone in 20017 :4 A. Lreftpe to answer based oa the Pith a5 Amendment. 36. What was the purpose, f any, of making 27 this note in 20017 Ite A. refs to answer based on the Fh, 29 Amendment, lao. Lwanttoread this note, (Readive.) 22 Talked with — talked with TMC, 22 Ie TMC Timothy Curley? ps A Lrefge to answer based on the Fifth 24 Amendment. Golkow Technologies, Inc. cakeS. uost9 3 Control Now: 15111035Gary ¢. schultz r Tage] age 1 Q (Renting) Roviowed 1998 history. ‘nad onthe Fifth Amendment BY MR, GAGNE: 2 Wastbe 1998 history the prior 5 investigation of Mi Sandusky fa his behavior with 4 childeen in the showers? 5 (MS. KORNFELD: Lacks foundation, . {THE WETNESS: Trefie to mswer 1 based the Fh Arsendiaent, © BY MR. GAGNE: 5 Q (Reading) Agreed TMC will disouss with s0 IVP. jar Teta Joop Paterno? a2 "MS. KORNFELD: Lacks fowntatioa. as ‘THE WETNESS: [infso to answer Hié based onthe ith Amendment 35 BY MR. GAGNE: 37 meet with 18 on Friday. jae ‘518 Jory Sancisky? a ‘MS, KORNFELD: Sem objection. j20 ‘THE WITNESS: Trefuso Co enswor 121 basedon the Fith Amendment 22 BY MR. GAGNE: 32. Doyou know whelher a meeting between ns Q. (Reading) Andadvise we think TMC should [°° (Q. In fic, ifMr. Sandusky confessed fo shaving a problem that involved inappropriate soxuel contact wi children, woulda't that be al the more tongon to contact DEW or other authostics? ‘MS. KORNFBLD: Angumoatative, calls for speoulation, and lacks foundation "THE WITNESS: Trefuse fo answer “based onthe Fifth Amendment. 1 BY MR. GAGNE: 2 Q. Andthenit says: (Reading) TMC will 22 keep me posted. is Doyousee that? as A. Ld. (Q. Did Mr. Caley keep you posted after he spoke with Mr, Sandusky? eA. refuse to answer based on the Fifth 3% Amondinent: j20 Please tum to tho next page, 2x A. (Witness complies) 22 Q. Atte bottom, thece's an E-mail dated 3 Monday, 26 February 2001, from Gary C. Schult to Pe secure and Me, Sandslyebeequniytnk rae [2¢ TMC3GpsaD ‘Was thot Mr, Cusley's Bamail on ‘6 based onthe Fifth Amendment, 11 BY MR. GAGNE: © Q Then contiones: Resing?) Unies he 1 confanses and confeses isn quotes —t0 having review th mater a an independeat agsney concer sa. with child wef, 3 Do-youknow what yoo meant whea you sid 4 anlers be confesoes to having « probe”? as ‘MS. KORNFELD: Lacks foundation. 36 "THE WITNESS: Trofuse fo enswer i> based on the Filth Amendment, 118 BY MR, GAGNE: 29 Q Why wor desided by you and Mr. Caley 20 that Mt. Cutley would oaly contact DPW if oa Me Sendsky didnot confess fo having @ probes? aa 18. KORNFELD: Lack foundation jas and vague. 2 ‘THR WITNESS: [refuse fo answer so a problem, TMC wil indicate weneedtobave DEW || Paes 147 cat) 1 onthe ellowing Friday? February 26,2001 a ‘M3. KORNFELD: Following 'A. Laefiseto answer based om the Fifth 3 Bebrusry 12,2001? ‘Amondmeat. “ “MR.GAGNE: Yes. (Q Did you snd this E-mail to Me. Curley on 5 ‘THB WITNESS: Trefse to answer Th. Liefase to answer based onthe Fil "There # 000 jl ei that tho ‘anal aes of your assistant, Youn Coble "A. Troe to anawor based on the FI ed |24 Asmendaent. pa Q. TheBeamilveads: (Reading) Tin me 7 assning tht youve got he bal fo, one, ak with 4 do subjot ASAP regarding the fitoreappropia= TS gee of ie University fility wo, contacting the chal ofthe chatbleoxgnization and thes, 7 contacting tho Department of Wear, As you know, sa mut ofthe ofis fr to nxt two weeks, but if 9 youneed anything rom me please etme know. zo Did read at acouley? zn A Yes,youdid, oz QA thats yourmanso under te ett 2 it srt eA Yes. ' February 26,2001? ‘ Golkow Technologies, Inc. CaP AS: £3110319: Control No.: 1511103:Gary C. Schultz Page 15 Page 152 2 Q So does this H-mai indicate that a ‘THIS WITNESS: Lrefuse to answer 2 Mr. Corley was going to take responsibility forthe | 2 based onthe Fifth Amendment 2 three actions sot forth inthe Ena? 3 BY MR. GAGNE: 4 "MS. KORNEELD: Objection, vague, | 4 Q_ Tem two on the E-mail says contact the 5 the document speaks for itself. 5 chuiroftho chaitebe organization, Was thatthe . ‘THE WITNESS: Lrefusoto answer | © Second Mile? 1 based on the Filth Amendment 7A. Trefuso to mawer based on the Fifth © SYMR. GAGNE: 8 Amendment. 9 Q Ttomonesays talk with thesubject Who | Q_Doyouknow whether ~stike that 20 isthe subject? lso-Furéher up on the document, on Match 7, ‘A. [refuge to answer based on te Fifth ‘Amendment. ss. Was that Mr, Sandusky’? lie A refuse to answer based on the Fifth las Amendment. 6 Q_ Didyou know, in February 2001, whether it 11> yas considered good practice to inform. potential ne child ex sbuser that you were aware of his 13. activities rather than going tothe police? 20 ‘MS. KORNFELD: Lacks foundation, ja calls fora legal conchusion, and vague. 22 "THE WETNESS: I refuse to answer }23 based on the Fifth Amendment, let BY MR. GAGNE: 2001, Joan Coble wrote: (Reading) Tim, bave you ‘updated Guay ately? Before he left fr Florida, he asked me to checic with youre this. Did you ask Ms, Coble to send that Bail toMe. Curley? ‘A Liofuse to answer bxsed on the Fifth Amendment. Q. Justabove that, on March 7, 2001, at 10:48 a.m, Mr. Curley wrote to Joan, "Ijust gave Dim the update." ‘Mr. Curley give you en update on the sates of the matter on ar about March 7, 2001? ‘MS, KORNFELD: Objection, vague. “THR WITNESS: 1 refise to answer ie Page 157 2 Q_ What was meant in your -mail by fiture | 2 2 appropriate wie ofthe University fecility? 2 >A. Trofuse to answer besed onthe Fifth 3 © f mendment. ‘ SQ. Was thatthe proposed instuction to 5 © Mr, Sandusky not to bring Second Mile chien into | ¢ 17 Univesity fecilitos? 7 5A. Trefase to answer based on the Fifth ° 2 Amendment, . 20 Q Preventing Mr. Sandusky fiom bringing 23. Socond Mile children into Univesity feilites will 22 do nothing to prevent him molesting or abusing, 23. children somewhere else; is that ouret? se ‘MS. KORNFELD: Lecks foundation, 35 vague, 36 ‘THE WITNESS: Trefteeto answer x7 based on the Fifth Amendment, 38 BYMR, GAGNE: 28 Q. Would youhave been more concerned with 20 doing somthing about Mr. Sendusky/s conduct fhe 12 had been, in 2001, a present employee ofthe 122 University rather than a eticed one? jas MS. KORNFELD: Vagoe lacks 4 foundation. Page 155 based onthe Fifth Amendment, BYMR.GAGNE: Q_Didyou speak with Mir, Curley on that occasion? ‘A. Liefuseto answer based on the Fifth Amendicent (Schulte No. 22, Handwritten Notes tea 225/01, 1 page, marked for Sdeniioation) BY MR, GAGNE: Q Mr. Schult, this enbibitis «series of ‘handiten notes dated February 25,2001, Is this your handwriting? ‘A. refuse to answer based om the Fith ‘Amendment Q Hive you toon this document before? |A. [refuse to ansver based onthe Fit Amendment Q. This document has three munbered items a reves onde: (Reading) Three ~ Tel hair and Board of Second Mile, Two- Report to Depariest of ‘Welfae, One ~ Tell J to avoid bringing children lone into Lasch Building. Do you see eat? Gol ‘THE WITNESS: [refine toro 4 Ghar bucd on the Fh Aen 5 nY MR. GAGHE: And as tt teomater tb Mr McQuay 4 had desea involving Geld Sens? . "MS. KORNFELD: Lack odor 2 and agne 0 "TH WITWESS: reise foaner fs dred on he ith Ament 2 BY MR. GAGNE: fa“. alike to know Mr Seni fal at 3d occured the incident etal by is Me MeQueary was hrsing around, vy 300 Would sve 26 aproaced an trey fsa whoa is wa8 x7 suapened child abuse? ae (MB. KORNEBLD: Argumenitve, 29 lacks foundation, vague. 20 “TIE WETNESS: Irefse to anesee 21 that based onthe Fits Amendment, 122 BY MR. GAGNE: las. Did Mr, Coumtey offer an opinion you 24 on wees the iosient that Mt. MeQoeary reprted Golkow Technologies, Inc. Schultz, ‘Foge 160 + constituted bil abuse? 2A. Trefiseto answer that base on the Pith 2 Anvendment 4 Q Arethere any documents, notes that you {5 made, or memos iemovslizing any conversation you {6 bad with Mr. Courtney reguding smpectd child 1 ave in Febru 20017 0A. Trefive fo ens that based onthe Fit > Amendment. so. Telke you to go please, to Exhibit SD om page 221, and Twant eo ~ you may recall st L 22. asked yon few mites ago cegacding you Gran Jury teatimony. You were asked duting the course of shat testimony whether, jn 200%, you had ever Bone 25 ‘ack sad mado an ioguiry regncting the 1998 26 investigation of Mr. Sandusky, and your answer to a the Grand Fury was m0 so And Td lke yon to take fook ot poe 9 21, which is an E-mail fom Thomas Hcmon to you at Lao gesd@Qgan.ed, deted Monday, February 12,2001, Do 2 you see that? 22 A Ido. las Q_ Anditsays “Subject: Insideat in 1998". 24 And Me Haman writes: (Reading) Regarding the — Page Tat 4 inldoat in 1998 involving former coach, ¥ checked 2 au ths incident is documented in cv imaged 2 archives. 4 Did youreseve this E-mail fom ‘5 Mr. Harmon ono about February 12, 20017 6A. Krofiupto goswer that based on the Fit 1 Aspendeent. © Q. Doyou bnew whether, i this Bn, 2 Mr. Hannon was espoding to a inguiry you ed made 120 concerning he 1998 investigation of Gestd 2 soniusky? 22 A. [efixe to anower tat based on the Fifth 3 Amendment st Q. And fantit tre that whan you learned of 5 the 200t incident pote by Me. MoQueary, tht ou had a secollecton ofthe 1998 investigation of 7 we, Sanduse? se ‘M3. KORNFELD: Lacks foundation, pe "THR WITWESS: [refuse fo answer '20 that based on the Fifth Amendment 2. BY MR_GAGNE: a2. Did the fact that his wes teas te 2 second tae that you had been mde were of 2 inuppropriat conduct by Mr. Sendoaky inthe showers CabB HB: 13110319 Control No.: 1511103:Gaxy C. Schultz Page 182 3 with children give you greater concer in 200) 2 concerning his condast? 3 ‘MS, KORNFELD: Objection, vague, “ ‘THE WITNESS: I refuse to enswer 5 that basod on the Fifth Amendment, 5 BY MR, GAGNE: 7 Q Did you view the 1998 incident and the #2001 incident as a possible pattem of soxuelly 4 abusive conduct of minors by Mr. Sendusky? 30 MS. KORNFELD: Objection, vagus, 1 tacks foundation. a2 ‘THE WITNESS: [refuse to answer 32 tat based on the Bith Amendment, BYMR. GAGNE: Q [ilike you totum, please, to Exhibit 5G, page 227. ‘A. (Witness complies) Q. This looks ike only one E-mail, but its actually two. Ifyou Took aroond maybe eight Hines Jovi, toward the let-bend sido, it saye "0500, Tim ‘Carley wrote", Do you se that? A Ido. Q Soifsays on the prior Lino, at #10 4 pan, 2/27/01, 0500, Tim Curley wrote, and it says: Page 164 4 Q Didyou restive this Bamail ora copy of 2 this E-mail iam Me. Carley on or about Febrory 27, 3 20017 4A Trefise to never that based onthe Fifth 5 Amendment © Q Twaatto go tough this in alte more 7 oti, He sys, "after giving itmore thought ax © talking it over with Joe yesterday" did you have an 2 understanding tht he had spoken on or about 0 February 26, 201, to Coach Paterno? 2A. refuse to answer that based onthe Fifth sz Amendinent 3 Q_ Doyoa low whether Mar. Custey's 24 aubgequent recommendation in this E-mail was Fnfledced in ay way by his conversation with ‘Coach Paterno? “A. Trefise to anawor that bused onthe Fifth ‘Amendineat 'Q. Do you know wher Conch Paterno convinced Me. Curley to tae less drstc ation than you had previously agreed to? ‘A. [refuse to answer tht based on the Fith Page 165 1 (Reading) Utad schodled « mooting with you his 2 afteoon about the subject we discard an Sunday. 2 After giving itmore thought end tallcing t over 4 with Joe yesterday, Tam uncomfortable with what we 1 agreed were the next steps. Lem having trouble with going to everyone but the person involved. I + (hike would be more confortable meeting with the ‘6 pezson and tell him about the information we 9 received, [would plan to tell him we are aware of 20 the ftst situation. I would indicat wo fol there fsa problem and we wat to assist the individol get professional help. ‘Also, we feel a responsibility at some poiat soon to infos his organization and maybe the other one about the situlion, If he is coopecative, we would work with him t hand fnforming the organization. Ifnot, we donot have ‘a choice and will inform the two groups “Additionally, [vil ot hi know that is guests ace not peated o use ove facilities. T ‘need some help on tis one. What do you think about ee approwch? ‘Do yousee that? A Ido. 23 Ameninent. jes MS. KORNFELD: And thet question ~ Page 165 ‘was vague and lacked foundation, BY MR. GAGNE: 13 Q. Didyoulave any convesation with ‘Me. Curley on or abont February 27, 2001, conceming discussion he ad with Joo Paterno regarding this nati? (MS. KORNFELD: Objection, vagus. [THB WITNESS: Tres (0 answer that based on the Fifth Amendment, BY MR, GAGNE: Q. Soif Trend this comecly, the decision Me, Cusley was proposing that contaty tothe cater discussion, thatthe Department of Public ‘Welfare would not be noiGedebout this matter st {east ntl is hat correct? MS, KORNFELD: The document speaks for tao, lacks foundation. "THB WITNESS: Jefe to moswer besed on the Fifth Amendment BY MR. GAGNE: (Q Do you know whether going to the suspect “ust the geneally-acoepted means of dealing with suspected sexaal abuse of children? MS, KORNFELD: Calls fora legal 2a Golkow Technologies, Inc. CaP As: t Control No 31103193 15111035a7 aa Gaxy C. Schultz Page 166 = conclusion, lacks foundation, wage. “THIE WITNESS: [refuse to anso¢ that based on the Fifth Amendment. BY MR. GAGNE: Q He also says: (Reading) I would Sica we fel there a problems and we want eset he individual © gt professional lp ‘Do yousee that? A Ido. {Q. Doyou know, dd you agro with Me, Cudey that there was @ problem and that Mr, Skodasky should get professional help? ‘MS. KORNFELD: Objestion, vague. [TBE WITNESS: Teefuse to answer ‘that based on the Fifth Amendment BY MR. GAGNE: And do-you know what the purpose of sich professional help would have beea? ‘MS. KORNFELD: Lacks foundtion, vague, [THR WITNESS: Irefuse to sswer that based onthe Fith Amendment. BY MR. GAGNE: {@. Doyou know wheter, in 200), Mt. Sandasky |2¢ ne 20 no Amendment Page 1 | pprose, withthe understanding that we will inform ‘bs organization, with or without his cooperation, 1 think that's what Tia proposed, We eas play iby cas to deve about the other orgntzation. Do yau sce that? A To, {And id you send that Esl to Dr. Spanier ‘and Me, Cudey on of about February 2820017 ‘A. Taefso to anar that based on the Fit “Q._Andwhat dd you mean by this wes a more ‘nome way to handle de situation? ‘A. Trofuse fo anater that based onthe Fifth Amendnent, ‘Q. Whee you sié humane, did you meaa bumsne to Mt, Sardusky or humane to his eld vii? TA. Trefise to answer that based on the Fifth L Amendment. “Q._ And why id you wish to nform the Second Mite with o without his cooperation? "A. Lrofuse to aoswec that based on the Fi 'Q. Below your -mnil is what appeats tobe an ‘Bp dated 2/27/01, 10:18 p.m rom Graham, a age 167 id obtain peofessonal help repatding his conduct svi eilen? ‘A. Taefase to anaes that bused onthe FA, ‘Amesiment (Me. Corl then says he fess 8 espa to inform bis orpniation, Did you hove an uadetending tat tat ws the Second Mile? "A. Trefose to answer tht sad on the Fifth ‘Arnondimeat. 'Q. What wae the pupose of informing the ‘Second Mile of Mr, Sandusky's conduct? "MS, KORNFELD: Lecks foundation and vag, "THEE WITNESS: refuse to answer ‘that baed onthe Fifth Arsendment BY MR. GAGNE: 'O Going fxther, up tothe op of the ° document, jidicass eu B-mil from you to Graken | 39 Species and Tin Curley dated Wedncsdey, Fbrusry 2° 2001, 2:13 pan. doyouse tat? A To. And acoording otis, you wrote: (Renting) Tim and Grahan this i more Iumene ‘aad upfront wey to bande ds, Toan mappar this Golkow Technologies, Inc. Page 109 ‘Spuniet, Do you seo that? A Io, Q Aube Speniorwaites: (Reading) This eqgaonch is aceptale tome, Ti equies yo 10 6° ft stp fathec end means hat your conversation will be all de more difficult, but admire your ‘yllingnes od that and Lem supportive ‘The only doveaside for us i ifthe mestage Senttheatd and acted upos, snd we then become -ylaerable for not having repored it, But that ean to assesad down the Toad. ‘The approgch you outline {shurnane and a reasonable way to proceed. Do you see that? A Teo. Q Did youreceive thet E-mail from ‘De Spanier on o about February 27,2001 ‘A. Trofise to answor that based onthe Fifth Amendment. {Q_ Do you know why Di. Spanier thought hat “Me, Carey reomendation was @ mote Iumaane ad ‘reasonable way to proceed? "A. rofuroto answer that based on the Fifth Amendment ‘Q. What di De Spanier mens when he sald the CaRAHs. #3110319: Control No.: 1511103Gary ¢. Schultz Page 170 1 only downside forus i ifthe message int heard 2 and acted upon’? 3A. Lrefive to answer thst based on the Fifth 4 Amendment. 5 Q Does thet mean tat if Mr. Sandusky 6 continues to bring children onto campus and molest 2 ebildren i the future, that that could be © problem? 2 (MS, KORNFELD: Lacks foundstion, 0 vague, and argumentative, pa “THLE WITNESS: { refuse fo enswer 22 that besed onthe Fifth Amendment. a3 BY MR. GAGNE: se Q_ And he ays we become vulnerable fornot [5 having reported it, Agein, as of Febroary 27,2001, 16 did you have an understaading as to whethee you or 17 Ms, Curley or President Spanier bad an obligation 3 report what Mit. MeQueary had relayed to you? ps ‘MS. KORNFELD: Objection, vague. 0 “TE WITNESS: { refuse to respond. 2. based on the Fith Amendment. 22 BY MR. GAGNE: 23 Q_ Infact, wouldnt the safest thing to do 24 have beea to report tis to authorities and et them ~ Tee | 1 rcluring, ho falls to im about basketball and 2 thea bo sys: (Read) {om planing to mect 2 with he person next Monday onto tbe abject. 4 Doyou know whotberhe was refering 5 Sandusky in that Ei? 6 A. Trofeo answer thet based onthe Fh 7 Ameninest 2 Doyeuknow whoter, jn fat be twa 4 Gerald Sanus onthe following Mondey? 0 A.Lrefise to ane that based on the Pith ss Amon. 2. Youwereaware, were you nt i 200%, 23 hat bo 1998 allegation of improper conduct by +4. Me Sanus had bee investigate bythe Peon Sito 5 police department? Ise A. Trefise to answer Gat based onthe Fite 27 Amendment. se (MS. KORNFELD: Can you--Im 1s sony cam you ust read buck the question? 20 (Question end) 21 BY MR. GAGNE: 122 Q_ And youknew that the Peno State police las department wat capable of handing such on 24 investigation is hal tue? Foge FAT Q Onthe bottom, there is a — agai these ‘e-mails ran together; thats the way we received them. “Toward the bottom, it says 8:19 pty ‘2128/01, "Tim Casey wots", do you see tht? About lis tour lines from the botom. sé A. Repeat hat again. 27 Q 8:19p.m,298/01, 0500, Tim Curley ss wots. lis pa 2 honcl and investigate it nd then you would not be 2 yulvemble for having filed to report it > MS, KORNFBLD: Lacks foundation, 5 “TRIE WITNESS: Troftse ta enswer 6 thatbased onthe Fifth Amendment. 7 BY MR. GAGNE: 8 Q Tua please to Bait SH, page 29. 9A. (Witness complies) a0 28? No. (Oh, ob down here, Lee. ‘Seo that? 89 pm, yes. Okay. Andhe aks Dr. Spanier when he's prereor Page 173 (MS. KORNFELD: Vague and lacks a 2 tion, 3 ‘THE WITNESS: I refuse to answer 4 thatbased on the Fith Amendment, 5 BYMR GAGNB: © Q Did youhave confidence in the ability of +r yout police department to conduct such an © investigation? ° "MS, KORNFELD: Lacks foundation lao and vague. a "THE WITNESS: [refuse to answer 132 thatbased onthe Fifth Amendment, lis BY MR. GAGNE: iQ. Why did you not refer the incident that 5 Mr. MoQueaty described to you in 2001 tothe Peon jae state police department? a7 ‘MS. KORNFELD: Lacks foundation ead vague. is "THE WITNESS: 1 rouse to answer l20 hat based on the Fifth Amendment, 21 (Schultz No, 23, Excompts of laa Preliminary Heating Transcript dated los December 16,2011, 13 pages, marked for 2s identification.) Golkow Technologies, Inc. CaReH9: 13110319: Control No.: 1511103Gary C. Schultz —— aga ——— Tage iT 2 BY MR, GAGNE: 2 orthere have been other allegations, We've looked 2 Q. Mr Sel, hin orbits aranseit 2 into them bofore and, more or less ina general 2 of preliminary hearing in the mater of > sense said we've never boon able to zelly unearth a eertmreats yews Tinathy Mark Caley acd | * anpting of sink our fot nto something thst we + Commonweatth of Peunsytvania versus Gary Charles | 5 had that was sabstantia 6 Schultz, Are you Gary Chaies Schulz, sc? 6 Doyousee that, si? 1A Yes,Lam, 7A Ido. © Q. This isa prtininay bearing dated © Q Anddoyou have any reason to testify 3 vetoay._ Devanbar 16,2011, Tike yontotum | % today tat Mr, MoQueary wasnt being hf or ne to page 133, plese 20 aoovrate in his testimony? ss 'A. (Witess complies) 2 ‘MS. KORNFELD: Lecks foundation, sa. Okay. And boginning on 133 at line 19is 8? vag. 23 the tetany of Joho MeQueery. Do youlnow |? “THE WITNESS: Trefise to answer 24 Mr, MoQueaty? 4 that based onthe Fith Amendment. is A. Trefixe to answer that basedon heFith |" BY MR. GAGNE: 2s. Amendinent ¢ Qi youbavea conversation wth John ein Meni te Meany ater, 27 MeQueary that relates this tetinony thet 36 in hatcorect? 18 justread to you!? ae an crrrcoto ener thatbased on ke Fith [19 A. Trofisoto answer tharbased on te Fifth 20 Amendvet J20 Amendment. ee ay asking at page 134, John MeQussry says, [22 Q_ Anu when you aid toi tat her bad eats 6 Gleading) Thedtol ite athe |22 been anoise eve or ator inauendoes or oor 23 should report ois bess his supervisor, 19 23 allegations that wore looked int, were you 24 Paterno [x refering to the 1998 investigation of Gorld r- Fagels | ~ Page 77 4 Question: And ata time subsequent to | > Sandasky/? > aha id you stn with Gary Sinz bouttho | 2A. Trofeo to answer tat bed one FN 3 nodent? 3 Amendment 4 Answer: Yes. 4. Q. Were you refering to inmundoes or $—Didyoutaveaconversstion, Me Sehute, | 5 aleatonsin aon tothe 1998 avesteton of € wid Jot MoQueayregating the incident hath | € Geald Senos? + son, Michal, ha relayed to you? 1A. refs to answer that based om th Fifth 2A Trefiseto answer that based on the Fh | ¢ Amendment 9. Asaendaeat 3 Q. Apat frm te 1998 investigation and 2001 a8. And thea please goto page 138 20 incident hat ve asked you about today, pric 0 a (Witness complies.) 112011, had you ever heaed any romots or ttements ot 2 Q_ Roginsing at lin 19, Mr. MeQueaty 2 alleguons involving alleged sna misoondact with teat: (Reading) Ibelieve—and ifTimew |2# minors by Me, Senduse? i thesoqunce i] Fao whea bo had talked to Mike J>¢ A. Trefuetannec fiat bast on he Fin is and didn alk to Mike, which Idontknow, Ives |*% Amendset 36 expecting something to be dane. se) Coutiming with Me, McQueary’s testimony, a oannrrmes Mr Schl, e's aresponsie (27 page 39, fine 14: (Reading) Quetion, Wes here 1, gediital Mews goed percn end bo what |8# muy quecion in yourzind that you eft at ment sett was thatthe Had head ofatlegatious | infoening Mr, Sit thatthe incident wes exh bo and they were aware ofthe situation and they were, |#° inate? 21 Tooking ilo i pa Answers Theses no doubt in my sind host 2 And during hat exchange he sid 22 of saying that viewed an act mel tht wit Mike something sia, Yok, thee as been a noise |? reported tome appowed fo be sess at, f+ ett ee ibe ci hmvendoes [24 sounded ike sexual in natu tome, and thnk ho Golkow Technologies, Te. saReHD: £31 10319: Control No.: 15111033Gary C. schultz Bags 178 knows that. Question: You have to listen tomy 4 Answer: Yes. Thats the poiot tm 5 making, yes. 6 Did Mr, MeQueary, John MeQueary, 7 communicate to you that What his son ad soon was © sexaal in nase? 2A Lrefise to answorthat based on the Fifth 29 Amendment. aa ‘MS, KORNFELD: ‘The question s sa vague a (Gobulte No. 24, Peansytvania 1x4 Ste Police Repost, Interview of Gary 25 C. Schultz, 1 page, matked for identification) 36 BY MR. GAGNE: x7 MeQnery, ad Peeno metand dase’ ee ere Wee yo ceteeited hy Ma Bain ding 28 coxa! volving Sandy ant ase, Led Kin Page 180 1 lavolving Sandy nnd «boy in be shower, Schule 2 rolled a meting wes atranged and he, Cxeley, 4 Incident. Sel seated be did not eemember all 5 the details; however, tre was not any mention of 6 any sexual acs. 7 Do you recall Me. MoQuesry ting you 4 thathehad absorved something disturbing? ° MS. KORNFELD: Objection, vague. 30 "THE WITNESS: Lrefise to answet s1 that based on the Fith Amendowent, ls2 BY MR. GAGNE: bs Q Boyouknow how the nsldeat that sa Me MeQuency abserved would be dstbing HL a8 25 not semial? a ‘MS. KORNFELD: Calls fur 27 geeulstion, vague. a0 "THB WETNESS: Trefuse to answer 119 that based on the Fifth Amendment, j20 BYR. GAGNE: [a1 Accoafing to this, Coach Paterno wes ia [22 thismecting, but erleretimany from both 23 Mr. MoQuesry and youre suggest xt Cone Patera 26 was not Page T8T 2 Doyou recall whether, in fet, Conch 2 Patemo met with you and Me, MeQueary and Me, Ouey cass what Mr. MeQueary had seen? 4A. refuse to nsiver that based ex the Fh Amendeent, Q. Ieanys: ending) Sobol related that cQueary ws very vague and spoke in general forms when he described what ho witested, 9 Tethat accurate, Me. Schulte? 0A. Trefise to answer that based onthe Fifth sa. Ameadoent, 2 Q. GReeding) Schultz rated, however, tt 13 eas his impression based on the information be 24 was provided that here was inappropriate soxuat ne to explain that in ore dtl, adhe elated tht 37 hed the Selig that there wes inappropriate I behvice possibly meting wovad mnd maybe Sandsky J might ave grabbed gonial. 20 Doyouscotbat? nA To. la Q_ Do youself telling tht othe State laa Polico on Jaauncy 12, 20117 lot. refuse to answer that based on he ith Golkow Technologies, Inc. CabeaB: 43110319: Control No.: 1511103:Gary C. schultz 7 Page 18D ~ Page [64 + Amendment. a ‘THE WIINESS: Iefwseto answer 2 Q. Istbatan sours desertion of tho 2 thatbased on the Fh Amendaoat. 2 impression you ceived fom yourcomverstin with | 2 BY MR. GAGNE: 4 Me MeQueny concerag what fad sen? 4 Q Twosentanos ate, it says: (Reading) : MS. KORNFELD: Lacks foundation. | 5 Schultrelted hath dd not ele hat enjone ‘ THE WIINESS: Trefusotoansvor | § (ookaway Sandasig’s keys, nor was he retectod 7 tye based onthe Fit Armendmeat, 7 fom using Peon Stats facies or han not 8 BY MR, GAGNES 2 being ellomed to bring Second Mil ideo campus. 8 Q. Isitaccarte that even thovgh 9 Ifyouere awa that Mr, Sandusky had 30 Mr. MeQuenry did aot give you great detail 23. conceming what he had seen, you fl hod tho 22 impression that there was ineppropriate sexual 22 conduct involving Sandusky and a minor? se MS, KORNFELD: Objection, vague, jas Incks Foundation. ne ‘THE WITNESS: { refise to answer 1:7 thatbased on the Filth Amendment 8 BY MR. GAGNE: 32 Q. And did you have an undesstanding on 20 January 12, 2011, when you made this stetement, that 2. inappropriate sexta contuct witha minor was 22 exiinal fn nate? a MS. KORNFELD: Vegue a ‘THE WETNESS: Lrefose to enswer ‘been involved in inampcopriate sexual conduct with = nino, ey did you aot ake away his keys oF restrict his acces to Penn Site facilites? “MS, KORNFELD: Lecks foundation, vague, ‘THR WITNESS: [refose to answer tat based on te Fith Amendment BY MR. GAGNE: (Q Itaiso say, around the mide ofthis paragrph (Reading) Schultz rolated tat since Sedhusky was no longer employed by Penn Sta, chat fa why the recommendation was to restit him fom. bringing Second Mile kids onto Penn State property. ‘Why di itmatiero- whet ference did it mace tat Me, Sandusky was no longer employed by Page 165 2 that based on the Pith Amendment, 2 ‘MS, KORNFELD: Lacks foundati > BYMR, GAGNE: 4 Q. Didyou have an understanding in Fobracry 2001 whether inappropriate scxual contact involving ‘ 7 ‘Sandusky and a ainoc wes ccminal ia nate? ‘MS. KORNFELD: Vague. ‘THE WITNESS: [refitse to answer that based oa the Fith Amendment, so BYMR. GAGNE: sx Q. Dowa toward the bottom of whats recorded 22. as yourstateuneat, it says — seven lines from the 23 toitem, it says: (Reading) 1 asked Sebullaif 34 Spanier was aware. Jas Do you aoe that? hs A Unhom, 7 Q. Reading.) Tasked Schult if Spanier was se aware ofthe 1998 incident end le related yes, 39 Schultz relatod that he was sure that Spanier knew 20 of te 1998 incident ex Bow were you sue that President Spanier 22 was awnre of the 1998 incidsat? 23 ‘MS, KORNFELD: Lacks foundation la and vague. Page 185 ean State ihe ail had access to te ectitios? (MS, KORNFELD: Lacks foundation, vague. “THE WITNESS: Irefese to answer ‘hat based on the Fifth Amendment BY MR. GAGNE: Q Did you have any understanding whether Penn State could bo lable ina ciit way for damages alleged by children with whom Mr. Sandusky ‘ned inappropiate sexual conta? ‘MS. KORNFELD: Lacks foundation, calls for egal conctusin, vague. ‘TRIE WISNESS: [ reftze to answer thot based on the Pith Amendment. (Gehultz No. 25, Pole Criminal Complaint, Defendant Gary C. Soult, 29 pages, merle for identification.) [BY MR. GAGNE: Q. Mr Schultz, this exhibits « Cxtminal Complaint, the tame ofthe defendant is Gary Charles Schultz. Isat you, eit? A Yes Q. And wes this Complaint filed against you ‘nor about November 4, 20117 Golkow Technologies, Inc. CaRea9: 13110319! Control No.: 1511103:cary ¢. Pago 186 2A refie to anrwer tat based on tho Fifth 2 Amendment 3 Q. Have you read ths document before? ‘A. Trefise to answer tht based onthe ith Amendment. (_Areyou stl epaitng il of xia charges against yo, Mi Seite? "A. Tiefe to aosver that based ante Fifth Amendment ao. Have you pled gilty or not git tothe J charges aginst yoo? aA. refi toswer that based onthe ith 23. Amendnent. 2¢Q_ Following the Criminal Compleat, there 25 ig, [believe isa Grand Jury Presentment. 1 a6 gaye-- well, thece's an Exhibit A. Do you se a7 whet it says Exit A? ps A Yeu 9. Andthen an invoduction, There's a 20 document here. (Reading) We, the mombrs ofthe 2. Thirty Thi Sitewide Investigating Grend Jury, >a having received and oviowod evidence ropariog 23 violations ofthe Cximes Code outing in Core 24 Couaty, Penusylvani, and elsewhere pusuaat to Page 187 4 Notice of Submission of investigation No.1, do 2 heceby male the following findings of fact and 3 recommendation of cherges ‘4 Hlave yousoad this document befor, 5 Me, Schulz? 6A. Iiefise to answer that based on the Fifth 1 Amendment: 5 Q Ponn State is in Conte County, is it not? 9A. Trefase to answer tat based om the Fifth 0 Amendinent 1 Q_ Tek youto tam, please, to page 12. seven, the perageagh that begins "Approximately do 33 you see that? he A Tao. Ins Q_ Andiin the above pareeroph it desosbes 6 Coach Patern's conversation with Timothy Cudey, n> andhen tsays: (Reading) Approxtnately one and 30 qhalf weeks ltr, tho gradunte asistant wos ae called to a mecting with Penn State Athlotio lao Director Curley end Senior Vioo President for 2. Finance and Business Gaty Schutz 122 Tho graduate assistant reported to Curley las and Schultz that he had witnessed what he believed 24 to be Sandusky having nel sex with «boy inthe sehultz — Bago Ta 2 Lasch Building showers. Curley and Schult assured 2 the peaduato assistant that they would ook into it 3 and determine what future ection they would tae 44 Patemo was not preseat for this meeting. 5 Did Lread that accurately? © A. Yes,youdid. 7. Andwas the guaduate assistant that meeting Miedel MeQueasy? 5A. Trofige to answer that based on the Fh 0 Amendment. sx Q_ And did Michael MeQueary tll yon and 12 Me, Curley thet he had witnessed what he believed to 33 be Sandusky having aul cox with boy in the Lesch fe Building showers? hs A. Trefigeto mswer that based onthe Fifth 36 Amendment. x7 Q._ TMs. MeQueary had described to you that [se Mt. Sandusky bad had analsex witha young boy in 25 the Lasch Building showers, would that conduct l20 your mind, kav been criminal conduct? Jax. Trofise to answer that based on the Fifth 2 Amendment. las Q. Tumtopege 24, please. aa A. (Witness complies.) Page 189 1 Q There are Recommendation of Charges, 40 2 yon see that? 3 A Ido, 4 Q. And the Recommendation of Charues against 5 you are for posjury and penalties for fate to 4 repottorsefer. Do you see that? 7k Ido, © Q. And bave those charges been made against > you, Mir. Schult? so A. Trefuso to answer that based on the Fifth jst Amendment. 2 Q_ And do you know whether the failure fo 23 sepoxt or refer lates to knowledge of potential Ie sexual abuse of a minor? 35 A. Lrofaso fo answer that basod on the 8 6 Amendment a7 (Behultz No. 26, Findings of Fact, 3259 pages, make for identification.) be ‘MS. KORNFELD: Peul, how much |20 longer do you think youze going to go? a ‘MR. GAGNE: No more than as how, loz Torte think. Do you want me to break? 2 (MS. KORNBELD: Can we go off the 24 record for aminuts? Golkow Technologies, Inc. CageHy: #91103195 Control No.: 15111035cary C. Schultz Page 150 2 MR, GAGNE: Yes. 2 "THE VIDEOGRAPHER: Te time i 2 now iL, Wel going off vido rocors, ‘ (recess was taken fora 1:31 pm 5 tw142pm) ‘ "THE VIDEOGRAPHER: The tim is 71s, Wetrback on the video 00% 9 BYMR. GAGNE: 2 Q Mr Shuts, Exhibit 26s headed lao = inings of aot, and I read the itrodectory 32 paregraph, (Reading) This investigation commences 22. as a result of allegations of sexual assoults of > minor male children by Goreid , Sandusky ever 24 period of yeace while Sandusky was a fotoal coach 25 with the Penasylvania State University footbal tessa 36 and eter he retted trom coaching, xy The Thity-Thid Statewide lnvestigting 20. Grand Jy issues thie Presentment in funherance of 29 its ongolng investigation ofthis matter and ereby 29 inoorportes all ofits previous findings fom ‘ax Preentments No, 12 ond 13 herein as if flly sot 22 fort. 23 Have yournd this doormen, Me, Shalt? 124A. Tsefuse to ancwer based onthe Fifth Page 152 [Did Mr. Hannon keep you up to date with the status ofthe May 1998 Sancisty investigation? ‘A Teefuse~- ‘MS. KORNFELD: Objection, vgve. Sony. “THY WITNESS: No, plesse ‘MS. KORNFBLD: f'm good. ‘THE WITNESS: [refuse to answer besed onthe Fifth Amend:ent. BY MR. GAGNE: (Q Ani was that iavestigaton one that could prove emiberrassing to or generate publio sorutny of Penn State? ‘MS. KORNEELD: Lacks foundation and vague "THE WITNESS: [refuse to enswer ‘based on the Fifth Amendment, BY MR. GAGNE: (Q. Andin the next parmgraph going onto pege nine, thors a deseiption of notes you took daring the conversations with Harmon, which includes, at ‘the end, on page nino ctical ine - contact with, agesitals? Finally, atthe conclusion of his notes, fhe pondered two chilling questions when he wrote, io And this isin reference to, apparently, 12 the 1998 tnvestgntion of Sandusky ot May 4, 1998, 2 itaaye, (Reading) Chief Harmon then celled Gary 13. Schulz, the senor vie president for business and 14. finance et Pean Stats, Slwltz overs the 25. Universiy police department as past of his 1s position 1 shat accurate, i. Soho? se A. Trefuse to answer based onthe Fit 1s Ameodment 20 Q (Reading) Chief Hermon tested thet 22 as ot uns or him to enp Schulz iaformed of 32 the tutus of nvostigtions that ould prove 23 emberessing to, or generate publi scrutiny of ae Penn Sate a Page T Page BT 1 Amendiment. 1 "pthisthe opening of Pandora's box, question; 2 Q edhe enytingin this document thatis | 2 other hides, question. 5 not accutte to your knowledge, Mr. Schultz? 3 Younity reall Tesked you about the + DiS. KORNEALD: Lacks foundation. | « handwsiden notes ene, Do you reall ha? 5 ‘THE WITNESS: Trofuse answer | 5A Ido. 6 based on the Fifth Amendment © Q. Andie this description of what wos in 7 BYMR. GAGNE: 1 thage notes aceunate? © Q_ Tumto page eight, plone, 8A. Lrofasoto answer based on th Fith 9A. Yes, (Witness complies) > Amendment Q. And did you make those notes, st? AL Leese to answer based on the Fith Arvenineat Q. Tumtopagoten. ‘A. (Witness complies) Q Atte end ofthe frat fall paragraph ‘hero, itseys: (Reading) Finally, on June 9, 1998, Schulte sent Curley an E-mail on which ho copied Spanior and Chief Harmon, Schatz informed ‘Cutley and Spanier of the decision not to pursu lage and to clos the investigation, and at the conclusion, he noted," think the matte has been appropriately investigated and T hops it ia now ‘eb s." ‘Did you believe thatthe 1998 allegtions Golkow Technologies, Inc, Casas: 13110319: Control No.: 1511103ieee =n Pag 14 1. .avolving Mr. Sandusky were appropriately 2 investigated? 3 MS. KORNFELD: Objection, vague, ‘ ‘THR WITNESS: Refuse to answer 5 based on the Fifth Amendment, © BYMR.GAGNE: 1 Q And why did you hope that matter was © behind you? 9A. [refuse to answer based on the Fifth Amendment. Q. Tumto page 18, please, A. (Wituess complies) Q And this is now in reference 02001. Tho paragraph at the bottom of page 18 states: (Reading) Curley did in ict implement par of toe pla that he, Spanier, and Schultz agreed to follow. Cutley met with Sondusky in early March and insttucted him not fo bring children on campus. ‘Did Me. Curley ell you that he had given Gary C. Schultz Page 196 Q. The dooureat states that Mi. Reykovitz testified thet Cusley deexibod the incidont ws mere horseplay that made someone uncomfortable. Did Me, Cusey toll you that thats how Ihe had deseribed the incident to Mr, Raykovite? 'A. Lreftse to answer based on the Fifth Amendment Q Doyoubelieve that the incident described ‘by thet an accurate description ofthe incident related to you by Mr. MeQueary i horseplay that ‘made someone uncomfortable? MS, KORNFELD: Objection, vague, ks foundation. ‘THE WITNESS: Trefuse to answer based om the Fifth Amendment, BY MR. GAGNE: Q ‘The docament continues: (Reading) There {sno evidence that Cusley, Spanier, or Schultz ever sought to got Sandosky the professional help to tach eaxttes such ts the police department would even be aware ofthe baa to ty and enforce it. {that aoourate, Mr Schultz? ‘MS. KORNFELD: Lacks foundation. ‘THE WITNESS: I refuse to answer based on the Fith Amendment. BYMR. GAGNE: Q. Itthen states thot Mr. Curloy met with ‘on Jacke Raykovity the executive diector ofthe Second Did Ms, Curley inform you of his ‘conversation with Mr. Raykovita? ‘A. refise to answer based onthe Fith Amendrsent 20 that instruction to Mr, Sandusky? 20 which Cusley refered in the E-mail ai -A. Trefuse to answer based on the ith zx Asthat correct, Mr. Schultz? 22 Amendment. Ja2 A Trefasoto answer based on the Fifth 22 Q_ Reading.) This ban wes completely J2> Amendment. 26 unenforceable, Jae. Do-you iow whether Me. Sandusky eves, on Pras DS Bago 197 that tray Mr, Schulte? 1 his ovm, sought any such professional help? 2 MS, KORNFELD: Lecks foundation, | 2 A. Trefise to answer based om the Fifth 3 ‘THE WITNESS: Trefuse to answer | > Amendment, 4 based onthe Fifth Amendment. 4 Q. In themext paragraph, i ays 5 ‘MS, KORNFRGD: And vegue 5 (Reeding,) Curley di talk with MeQueary severst © BYMR. GAGNE: 6 swooks aoc theit inital meeting, MeQueary was 7 Q. ‘Thedocument oonfinuss: (Reading) In| 7 tld that Sandusky’ keys to the locker room bed 1 fac, since only Schultz and Spanier algo knew of | © been tken away, © this plan, no other individual at Peon State or 2 Do you know, infact, whether thats xe accurate, Me, Schmitz? "A. Trefuge to besed on the Fith Amendment. Q Did you and Mr. Cusey discuss whether ‘Me. Sandusky’ keys had been talcen away in 20017) ‘A. Trott to answer besed om the Ff ‘Amendment, Q Pieage lock atpage 21 A (Witness complies.) Q And the first pazagraph is a discussion of ‘Cynthia Baldwin, Pan State's legal counsel. Do yo -kaow Ma. Baldwin, Me. Schultz? ‘A. Refs to naswer based on the Fith Armondmeat (Q. Did you ever discuss Mr. Sandasky with Ms, Baldwin? Golkow Technologies, Inc CameHo: $91103195 Control No.: 15111035 |Gary ¢ Pago 198 | 1A. Trofise to answer based om the Fifth 2 Amendment, 2 Q_ Ttsaysin the middle ofthe paragraph: 4 Reading.) Duxing this meeting, and at number of 5 other meetings, Baldwin sought to determine ifany 6 ofthe information requted by Subpoena 1179 was 7 known to Athletic Diteotor Curley, Vice President Schult, and President Spanier, Bach personally ad directly ossured her that they ew of no information 20 or doctments involving alleged misconduct or 33 inappropriate contact by Jey Sendusky. se Isthatan assurance you gave to 33 Ms. Baldwin, Mr. Schnliz? au ‘MS, KORNFELD: Objection, yaigue. as ‘THE WITNESS: Refuse t answer lnc based on the Fifth Amendment, 37 BY MR. GAGNE: 38 Q_ Atthe bottom of page 21: (Reading) The 29 investigation also found that, contrary to whet 20 Sclultz bad tld Jegal counsel Baldwin, Schult bad 2 a fle kept in his Pena Stat offce containing 22 notes and documents directly related tothe 1998 and 22 2001 senual asseult by Sandusky. Those documents 24 included handwsitten notes prepared by Schultz fom + convetstions he led with Peon State Univesity 2 Police Chiof Thomas Harmonix 1998, Did you maintain in your office at Penn 4 State file with notes and docaments relating to 5 the 1998 and 2001 investigations of Mr. Sandusky’? 6 A. refuse to answer bused on the Fifth 1 Amendment. a MS, KORNFELD: And that acts > foundetion so RYMR. GAGNE: si Q_ Di you instruct your assistant, Joan 12. Coble, that she was not to Look atthe file you. 22 maintained that was labeled "Sandusky"? sa ‘MS. KORNFELD: Vague. as ‘THR WITNESS: Refuse to answer 26 basedon the Fith Amendment. 27 BY MR, GAGNE: 38 Q_ Whenyoutold Ms, Baldwin in 2011 of 2010 22 that you were aware of no documents, did you recall ‘0 at that time that there was a file in your afice 24 concerning Mi. Sandusiy”? ie ‘MS, KORNEELD: Lacks foundation = and vegue. ‘THE WITNESS: Fsefse to answer Golkow Technologies, Inc. ras 5] schultz — Page 260 | 2 based oa the Fifth Amendment, 2 BYMR.GAGNE: 2 Q Blase tum to page 24 4A Wituess complies) 5 Q Thofistparepraph says: (Reading) The 6 notes and documents concexning Sendusly's 1998 end | 1 2001 erimes were in Schlt's Penn State office on 8 November 5, 2011. 9 Tpthat accurete, Mr. Schulte? 2A. Treftee to answer based onthe Fith 21 Amendment, ls Q The document continues: (Readings) The laa administrative esitant atthe time, Kimberly 24. eleher, upon leaning that Scultz wa to be 25 erested end would not be remming to the office, a6 removed these dacumeats Som a file drawer ia 27 Sots office and delivered them to his home, 18 Tetacommte, Mr. Schult? 9A. Refi to answer based on the FR 20 Amendment 2x Q_ WasKim Beloher your asistant in Novermber 22 aout? laa A. refuse to answer based on the Fifth [24 Acundment Frage 201 | 1 Q Didyousoquest that Ms, Balter bring you 2 the Sandusky file from your oe ia Novernber 20117 a MS. KORNFELD: Vague, ‘ ‘TAB WETNESS: Trefise to answer 5 asad on the Fifth Amendment 5 BY MR, GAGNE: 7 Q. Wasi yout ijenton to hide those notes @ ordocumtents from anyone who was investigating 9 Me, Saugus’ conduc? so ‘MS. KORNFELD: Vague and lacks 2a feundetion, 32 ‘THR WETNESS: Refaro to anewer 32 based onthe Fifth Amendasent 4 BY MR. GAGNE: In Q. Thedocoatenteontinues: (Reading. Joan 26 Coble, who seeved an Schulz’ administrative 39 assstnt until her retirement in 2005, tesifod 28 thats was inetracted by Schull to cover lok in 29 the Seadusky file he kept in his bookcase fle 150 drawer, She sat wana very unusual request and 12 twas made ina tone of voioe che had never heard l22 him use befor, 22 Taha ocurate, Mr, Shultz? je ‘MS. KORNFELD: Lacks foundation ~ Caadid: $31103195 Control No.: 15111033cary ¢. Schultz ~ Fogo Page 204 end vague. 1 young boy in the shower together on ctinpus and thet ‘THE WITNESS: Refise to answer 2 there was observed pysical contact, letalone the ‘based onthe Fi Amendavent, + aotul sexual assault McQuoary deseebed to them BYMR. GAGNE: 4 during the meeting, Q Please tuna to page 33. A. (Witness complies.) Q. Theron section here entitled pindangering the Welfare of Children", Doyou see ‘hat? A. Ume-huun, Edo, Q. Thatbegins: (Reading.) Graham Spanier, “Tima Curloy, and Gary Selnltz engaged in arepected pattern of behavioe that evidenced a-wilfil Gisregard for the safety and well-being of minar children on the Peat State tmpus. ‘Do you hive any reason fo disagces wth that conclusion, Mr. Schulte? ‘A Trefuse~ (MS, KORNFELD: Lacks foundation. ‘THE WIENESS: Refuse to answer ‘sed on the Fifth Amendment, 2 20 5 Chief Hannon pointed ont in his testimony 6 thet the need to report ould have bean eadly + apparent given this was now the socond episode, and (6 e observed thet it would ln likely led toa 2 seexamioation af the 1998 incident. so Doyousee that? ax A Ido. 2 Q_ Doyoulaveany reason to dispute 3 Me. Harmon's testimony’? se “MS. KORNFELD: Lacks foundation, as ‘THB WITNESS: Refuse to answer fue based on the Fifth Amendment, 17 BY MR.GAGNE: 18 Q Can you explsia why, in ight of the 1998 23 incident that wns investigated by Mi Earnon's 20 department, you did not referthe 2001 matter 12x esexibod by Mx. MeQesry to Chief Hasion's 22 24 testified tat oll Gary Schulz on, fr that mater, luck know an eyewitness observed Sandusky and a "Tim Cuey or Grehar Spanier, need have done was to 22 BYMR, GAGNE: Jaa department? 25 Q. (Reading) Tomy Sandusky utilized his |#* MS. KORNFELD: Vague and lacks 2 unfotored acoess to Penn Stato facilities, bth |? fendation, Page rd Pages | 1 bofors his efirement in 1999 and after, tosenually | * ‘THR WITNESS: Refuse to answer 2 eats young boys. 2 bared onthe ifth Amendment Me, Schultz, do you bave any reason to 5 BY MR. GAGNE: 4 dispute thet statement? 2 Q Plessotum to pago 38. 5 MS.KORNFRLD: Lacks foundation, | 8A (Witness complies.) . ‘THE WEINESS: Refuse to answer 6 Q Theresa section enlitled here 1+ yased onthe Hit Amendment + *Ofsuuction of Suatee and Criminal Conspiracy’, do 8 BY MR_GAGNE: © yousee that? = Q (Reding) Spanies, Carey, end Schute 3A Ido. se wera! wel aware of th extert to wich Sendasky [0 Q_Anditsayss Reading) Grohe Spasion ee fecsttommpainbiscooseoin wile {3% Tim Cute, sod Gry Sculls conspired among ch x2 Second Mile. 12 other end did infact engage in many acts to 2 —-Ma. Schult, do you have any reason to 13 obstruct justice between 2001 and Se present. aa dispute that steternont? + Have you in addition to the charges for hs NUS, KORNFELD: Lacks foundation, [25 perury and flu to ropor tht we reviewed a6 "THB WINES: Refuse to newer ne eaves, have you subsequently been charged with 7 hosed onthe Fith Amendment, 27 endangering the wolfire of rains, obstruction of jie BY MR, GAGNE: Ie justice and eeminal conspitacy/? 3 Q Please tun to page 34. 29 A. refise to answer based on the Fit j20 A. (Witness complies) 20 Amendoseat. In Q_Tesays: (Reading) Chief Hasmon lat Q_ It stntes hero, among other things atthe 22 bottom, tat Schultz id the cxistence of pertinent files and notes, Is that accurate, Me. Schott? ‘MS. KORNFELD: Lacks foundation, Golkow Technologies, Inc. ‘Cabego: 13110319: Control No. 1511103