FILED 09 DEC 2015 10:17 am Civil Administration B. MASCUILLI xhibit L. | omni Ste bie Fear CLROT 1310319500128 Case ID: 131103195 Control No.: 151110353 6 190 an 2 3 4 45 16 a7 18 19 20 a1 22 23 24 Golkow Technologies, Inc. Confidential - John Doe 102 IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY, PENNSYLVANIA PENNSYLVANIA MANUFACTURERS' : ASSOCIATION INSURANCE 3 COMPANY, : PLAINTIEF : CIVIL ACTION vs. : NO. 004126 THE PENNSYLVANIA STATE : JANUARY TERM, 2012 UNIVERSITY and JOHN DOE A, DEFENDANTS : ** CONFIDENTIAL #* Friday, November 21, 2014 Oral Deposition of JOHN DOH 102 held at Hilton Garden Inn, 1221 East College Avenue, State College, Pennsylvania, 16801, commencing at 11:53 a.m., on the above date, before Kelly M. Johnston, Court Reporter and Notary Public in the Commonwealth of Pennsylvania. GOLKOW TECHNOLOGIES, INC. 877.370.3377 ph/917.591.5672 fax deps@golkow.com Control No. ase Ip 31] 03195 I1S11103510 an a2 13 14 18 16 17 18 19 20 ar 22 23 24 Golkow Technologies, Inc. Confidential - John Doe 102 Q And so nas someone you trusted? A Oh, yeah. Q And was she one of the Penn State students that was on duty at night? A 1 -- I can't say a hundred percent; T believe she may have been taking some kind of psychology courses or something with childhood development . Eventually, I know she -- in the middle of all this, she was interviewing for some post or something in that she eventually went out there for that I heard later. Q Now, T'm assuming the sexual abuse incident occurred at night? A Oh, yeah. Q Okay. So did you come back -- are we talking, like, middle of the night that you come back? A I would imagine I was back by 10:30 at the latest. Q Okay. You come back into the Nittany House at 10:30, the sexual abuse incident had occurred. Did you go directly to and tell se Control No.; Case TDs E34 403195 15111035Confidential - John Doe 102 1 her? a A No, no, she wouldn't have been there that 3. late. 4 Q Okay, that's what I was trying to -- 5 A Yeah. 6 Q So would it be the next day? 7 A Yeah, it was the next morning. e @ And do you remember what she told you? 9 AI believe she prepared me to get in 10 trouble -- 1 Q For sneaking out? 22 A Exactly. She was -- I believe it was 13. something along the lines of no matter what comes of 14 this, you should say something, but you should be 15 prepared to face consequences for how you got out -- 16 Q Right. uy A == not, you know... 18 Q Now, did you relay to the 19 incident that occurred? 20 A Probably not in as much detail as written 21 there. 22 Q What do you remember telling her? 23 A I was a 16-year-old boy, so I would say I 24 95 percent trusted and five percent had a crush on Golkow Technologies, Inc. Beg EF 4105195 Control No.: 15111035confidential - John Doe 102 _ 1 her, so E probably -- I can't remember a hundred 2 percent, but I would imagine I didn't go into full 3 detail as it is here. 4 Q Did you let her know there had been 5 inappropriate sexual contact -~ 6 A Yes. ” Q -+ with Mr. Sandusky? 8 A Yeah. 3 Q What did she tell you to do, other than be 10 prepared for possible getting in trouble for having a1 snuck out? Did she tell you you need to speak to 12 somebody? b A She recommended that I talk to the 14 assistant, before going to the director, 15 because the director may be focused on the fact that 16 we were sneaking out and flip out on us. wv Q Okay. Did you, in fact, go speak to as like, the office 19 A T tried to, but they 20 was so small that she, as soon as I told her T 21 needed to talk to her, she called him in on the 22 meeting, so he was there regardless. 23 0 Okay. And the "he" being Mr. Gordon? 2a Ae tec. Cuse-[De131103195 Golkow Technologies, Ine 5 Control No.: 15111035Confidential a 0 and thie is the next day, also, same day? 2 A This was -- yeah, we would have got up, so 3 it probably would have been somewhere 8:00, 4 9 otclock 5 Q In the morning? 6 A Yeah, very early. 7 So you'ze in Mr. Gordon's office with 8 and you communicate the fact that there had 9 been an inappropriate sexual abuse incident that 10 occurred? n A yes 2 @ po you remember -- again, did you stay 13. away from details, or did you at least make sure 14 they knew that something inappropriate had occurred? a A Ican't -- you know, again, this is 27, 16 whatever years of hindsight, I can’t one hundred 27 percent remember, but I do remember I was, you know, 18 probably tiptoeing around the sneaking out part more 29 and trying to cover my own behind there. But I -- I 20 can't remember, I don't know a hundred percent, 1 21 can't answer that. 22 Q Well, did you at least communicate to them 23. that. something inappropriate had occurred between -~ 24 A Oh, yeah, and definitely involving the Control No. jolkow Te logies, Inc. ~~Case D413. Golkow Technologies, Inc ‘Case §P+ 431103195 15111035Confidential - John Doe 102 10 aL a2 13 a4 15 16 uw 18 49 20 ar 22 23 24 parties involved here, definitely. Q Okay. And you then -- at least you -- or she says, 's report says that "they tried to poke holes in my story". Do you remember anything specifically about that? A I always got the impression that the director of the Nittany House, Cliff, I always thought he didn't like me, but I would later come to realize I don't think he liked anybody there or his job, and I think that that guy would have poked holes in anybody's story to cover his own ass. But, yes, I definitely, from almost the second sentence, was just more relentless questioning than this, you know, and it was all over the map, you know... Q Did they try to question whether or not, in fact, Mr. Sandusky had sexually abused you in some fashion? A I don't remember any direct questions that he was trying to prove my story or not prove my story. I remember it more as two almost separated in the fact that, A, you admitted to sneaking out, and I had to implicate a couple other people in the house, and that, B, where was I gonna go with this? Golkow Technologies, Inc. ~ esd 34 Control No.: 15111035 3195Confidential - John Doe 102 1 You know, was it something I was just gonna tell him 2 or was I gonna call my mom, anybody at -- and pass 3 the information on. 4 Q And what did you say to that issue? 5 A Well, he didn't put it to me like that; he 6 didn't say, look, this is what I want you to do with 7 it. That's just where it was going was at some 8 point, it got to the point of, well, you're lying, 9 you know, this -- we never -- definitely didn't get 10 into details that were here, you know, about that, 21 but it was -- I would say, yeah, they were 12 definitely poking holes in my story. 13 Q Did you tell him what you wanted to do 14 with your reporting of this inappropriate sexual 15 conduct? 16 A No, no, because at that time, as a 17 16-year-old, I assumed they would handle it. 18 Q Now, again, I'm only going by what it 19 says, it says, and as you had feared, "the director 20° yelled at me". 21 A Yeah, the guy went nuts. 22 Q What was he yelling at you about? 23 A Well, pretty much everything. I mean, I 24 don't ever remember having a conversation with the Golkow Technologies, Inc. Case Ps BHL3195 Control No.: 15111035Confidential - John Doe 102 1 guy that he didn't yell, for one. But it was just 2 yelling about, you know, everything is this and you 3. guys are F'n it up, you know, every time I turn 4 around, you know, I got something to deal with, all 5 the, you know, the same thing anybody might say in 6 their job. 7 But it -- it kind of escalated slowly. So 8 at the first, I guess I was being yelled at for, 9 ike I said, breaking the rules and then presenting 10 this story to him, and then I got the impression he 11 thought I was lying to him and just wasting his 12 time; and then at some point, they stopped 13 questioning me and talked amongst themselves. 4 Q And "themselves" being and Cliff 15 Gordon? 16 A Yeah. 17 Q And did they then send you back to your _ 19 A No, I was at -- we had like a dining area, 20 1 don't know if I'd call it a dining room, but there 21 was a big dining room table, and I was sitting out 22 there; they gave me a chair and made me turn around 23 and face the wall, seemingly as far away from that 24 office as I could be while they talked. Golkow Technologies, Ine. ~ PEP A 3195 Control No. 15111035