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1 JANEAN ACEVEDO DANIELS, SBN 145707
Attorney at Law
2 Law Office of Janean Acevedo Daniels
1160 Via del Rey
3 Goleta, CA 93117
phone: (805) 284-4428 fax: (805) 456-2050
janean@jadanielslaw.com
4
Attorney for PLAINTIFF JANE DOE
5
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 FOR THE COUNTY OF SANTA BARBARA
9
10 JANE DOE Case No.
11 PLAINTIFF, COMPLAINT FOR DAMAGES FOR:
12 v.
1. Assault & Battery
13 2. Sexual Battery in Violation of Civil Code
MISSION ROWING, a California nonprofit
§ 1708.5
14 public benefit corporation; CONAL 3. Sexual Harassment in Violation of Unruh
GROOM, an individual; CAROL NAGY, an Act, Civil Code § 51.9
15 individual; and DOES 1-50, inclusive, 4. Gender Violence in Violation of Civil Code §
52.4
16 5. Violation of Ralphs Civil Rights Act, Civil
DEFENDANTS. Code § 51.7
17 6. False Imprisonment
7. Intentional Infliction of Emotional Distress
18 8. Negligent Infliction of Emotional Distress
19 9. Negligent Hiring, Training, Supervision and
Retention
20 10. Negligence
11. Defamation Per Se
21
22 DEMAND FOR JURY TRIAL
23
24 PLAINTIFF JANE DOE alleges:
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COMPLAINT Page 1 of 48
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GENERAL ALLEGATIONS
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1. At all times pertinent hereto, PLAINTIFF JANE DOE (“PLAINTIFF”) was a
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resident of the State of Washington and of the County of Santa Barbara, California, where she
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lived and resided during the times she was training with DEFENDANTS MISSION ROWING and
4 CONAL GROOM in Santa Ynez, California. DOE is suing under a pseudonym in order to protect
5 her privacy, and because she was a minor at the time she was subjected to the injurious actions
6 described herein.
2. The true names and capacities of DOES 1-50, whether individual, corporate,
7
associate or otherwise are unknown to PLAINTIFF at this time, who therefore sues these
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DEFENDANTS by such fictitious names. When the true names and capacities of such
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DEFENDANTS are ascertained, PLAINTIFF will amend this complaint to insert the true names
10 and capacities of said DOE DEFENDANTS.
11 3. DEFENDANT MISSION ROWING (“MISSION”) is, and at all times pertinent
12 hereto has been, a nonprofit public benefit corporation organized and existing under the laws of
the State of California that operates and/or operated a rowing club in the County of Santa Barbara,
13
California.
14
4. DEFENDANTS MISSION ROWING and CONAL GROOM are liable in a cause
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of action for sexual harassment under California’s Unruh Act, Civil. Code § 51.9, because they are
16 persons who had a business, service, or professional relationship with PLAINTIFF at all times
17 pertinent hereto.
18 5. DEFENDANT CONAL GROOM is an individual who resides in the County of
19 Santa Barbara, California. At all times pertinent hereto, GROOM was employed by MISSION in
the County of Santa Barbara, California and regularly communicated and interacted with
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PLAINTIFF regarding the matters at issue in this case as an agent and servant of MISSION.
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6. PLAINTIFF is informed and believes and on that basis alleges that each
22 DEFENDANT in this Complaint was, at all times mentioned, the agent, servant and/or employee
23 of the other DEFENDANT and was at all such times acting within the course and scope of said
24 agency and/or employment.
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COMPLAINT Page 2 of 48
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7. PLAINTIFF is informed and believes and on that basis alleges that each
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DEFENDANT named as a DOE DEFENDANT is responsible for each and every act and
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obligation set forth in this complaint.
3
4 SUMMARY OF CLAIMS
5 8. PLAINTIFF is 18 years old and a former MISSION ROWING athlete and client.
6 PLAINTIFF asserts claims against DEFENDANTS MISSION ROWING, CONAL GROOM, and
CAROL NAGY arising from the physical, verbal, and emotional abuse, threats, sexual
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harassment, assault, and battery to which she was subjected for more than two years while she was
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a minor, culminating in her false imprisonment and sexual battery by MISSION employee and
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coach CONAL GROOM. GROOM, who is 49 years old, was a significantly older adult who
10 PLAINTIFF trusted and did everything possible to please until he violated her trust by grievously
11 injuring her when he ordered her to come to his home on the evening of August 13, 2022, where
12 he forcibly detained and restrained, falsely imprisoned, and assaulted, battered, and sexually
battered her (“the 8/13/21 Assault”).
13
9. From November 2019, when CONAL GROOM engaged in his first angry outburst
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toward PLAINTIFF, until August 13, 2022, the night he falsely imprisoned and assaulted and
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sexually battered her, CONAL GROOM pushed PLAINTIFF relentlessly, often to the point of
16 tears and emotional breakdowns, with his abusive, demeaning, and at times violent behavior, and
17 his inappropriate, unwelcome, and sexually-suggestive personal attention and predatory grooming
18 behavior--all under the auspices of MISSION ROWING, and with the purported purpose of
19 helping this high school-aged athlete achieve her goal of rowing competitively at the national
level, and her dream of becoming an Olympic athlete.
20
10. GROOM’s shocking actions towards PLAINTIFF, who was only 15 years old
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when the abuse began, violated standards for appropriate coaching of minor athletes by the United
22 States Rowing Association and United States Center for SafeSport, and were committed within the
23 course and scope of GROOM’s employment with MISSION ROWING.
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COMPLAINT Page 3 of 48
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11. GROOM’s unlawful and offensive actions were ratified by MISSION founder,
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Director, and former Executive Director CAROL NAGY, who was aware of GROOM’s wrongful
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conduct toward PLAINTIFF and other MISSION client athletes but did nothing to protect
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PLAINTIFF from further harm (or ultimately, from GROOM’s sexual harassment, assault and
4 battery), and by MISSION ROWING.
5 12. GROOM’s shocking actions, which could have been prevented had NAGY and/or
6 MISSION ROWING acted with due care and concern for the safety and well-being of
PLAINTIFF and various other athletes being coached by GROOM, have traumatized PLAINTIFF
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and caused her to suffer various physical and emotional injuries which have required professional
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evaluation and treatment, including anxiety, panic, recurring disturbing thoughts and nightmares
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regarding GROOM’s abuse, and other symptoms of Posttraumatic Stress Disorder, along with
10 sleep disruption, depressed mood, withdrawal from social situations, and a loss of interest in
11 activities that previously brought her pleasure.
12 13. As a result, this strong and brave young woman, whose love and passion for rowing
were eclipsed only by her desire to please and prove herself to the coach she idolized, CONAL
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GROOM, remains pained and haunted by these events to this day.
14
14. Based on GROOM’s unlawful, offensive, and injurious actions towards
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PLAINTIFF as described below, and GROOM’s position and authority over PLAINTIFF as her
16 coach and an employee of MISSION ROWING, the rowing club of which she was a loyal and
17 committed member, PLAINTIFF asserts the common law tort claims and statutory claims as
18 described herein against MISSION, and against GROOM and NAGY individually to the extent
19 permitted by law, and seeks compensation for all harm, injury, loss, general and special damages
she has suffered, and for the attorney’s fees and costs she has incurred, as a proximate result
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thereof.
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15. PLAINTIFF also asserts claims against NAGY individually based on her knowing
22 and reckless disregard for, and lack of due care for, PLAINTIFF’s safety, well-being, and dignity
23 in allowing GROOM to continue to have access to, and continue to coach in an abusive and
24 harmful manner, PLAINTIFF and other young athletes, thereby sanctioning GROOM’s abusive
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COMPLAINT Page 4 of 48
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conduct, and providing GROOM with the opportunity and authority to direct PLAINTIFF to come
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to his home on NAGY’s property (a shipping container shed in NAGY’s backyard that serves as
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GROOM’s living quarters), where GROOM falsely imprisoned, assaulted, battered, and sexually
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battered her.
4
5 FACTUAL BACKGROUND
6 16. From 2002 to 2007, CONAL GROOM worked at the Pocock Rowing Center in
Seattle, Washington, where he coached the club’s elite sculling team. (Elite sculling teams are
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made up of elite athletes who are competing for spots on national team/competition-level boats,
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often young adults in their late teens and early twenties.)
9
17. While working and coaching at the Pocock club, GROOM met CAROL NAGY
10 and her minor daughter. GROOM hired NAGY to be the boathouse business manager, a position
11 she held from approximately 2006 to 2007, and coached her daughter.
12 18. On March 24, 2007, GROOM physically assaulted and battered one of the young
female elite rowers he was coaching. According to a written statement that the athlete provided in
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2014 as part of a grievance against GROOM filed with the United States Rowing Association at
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that time, after the athlete questioned GROOM’s failure to notify her and other rowers in her scull
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during a race training exercise that a large boat was approaching them (resulting in their boat
16 taking on so much water that they had to return to the boathouse), GROOM grabbed her by the
17 arms/shoulders and threw her toward the stairs of the Pocock boathouse, where she fell to the
18 ground.
19 19. The female rower, who reported GROOM’s assault to the police, confirmed in her
statement in connection with the U.S. Rowing investigation that the assault and other wrongful
20
treatment she and other athletes experienced under GROOM’s coaching supervision led her to quit
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rowing--a sport she had dedicated years of her life to--altogether.
22 20. GROOM was reportedly reprimanded by Pocock for his attack on the female
23 athlete and was suspended from coaching the elite sculling team. Following GROOM’s
24 suspension, GROOM and NAGY left Pocock together.
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COMPLAINT Page 5 of 48
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21. GROOM then moved to a head coaching position at Lake Union Crew in Seattle.
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NAGY followed GROOM to the club and worked as Lake Union Crew’s business manager.
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22. In 2010, GROOM and NAGY left Lake Union Crew together and established
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their own private rowing club, the Seattle Rowing Center (“SRC”).
4 23. From 2010 to 2019, GROOM served as head coach of SRC and lived in the club’s
5 boathouse. NAGY served as the club’s Director and GROOM’s supervisor, and operated the
6 organization as a for-profit entity without oversight by an independent Board of Directors. This
management structure and the lack of oversight by a Board of Directors made it impossible for
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complaints of misconduct by GROOM to be escalated beyond the level of or to persons other than
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NAGY, who was understood by the rowing community to have a close relationship with GROOM
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due to his coaching of her daughter, and her own friendship with GROOM. NAGY developed a
10 reputation for protecting GROOM and failing to take action to address coaching misconduct that
11 he reportedly repeatedly engaged in towards the athletes entrusted to his supervision.
12 24. SRC, which had a middle school program, a junior racing team, and a high-
performance elite sculling team, catered to young rowers and their parents, promising that
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GROOM’s intense coaching style and training regimens would pay off for the young athletes
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placed in his charge by significantly improving their performance and allowing them to reach their
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goals of rowing at the elite level.
16 25. When many of the young athletes and their parents were subjected to, witnessed, or
17 otherwise became aware of wrongful, offensive, and at times dangerous actions by GROOM
18 towards his athletes, and complained to GROOM and NAGY, GROOM denied acting
19 inappropriately and/or blamed his victims, while NAGY continually defended GROOM and his
actions, often claiming that GROOM had just had a “bad day,” and trying to explain away his
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offensive actions by telling the complaining parties that GROOM had “anger issues” that he
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needed to work on, and/or that he was struggling with alcohol addiction.
22 26. On November 19, 2011, GROOM sent several of his junior athletes, including a
23 male high school rower, out to row in perilous weather conditions near the Evergreen Point
24 Floating Bridge (known locally as the “Highway 520 Bridge”) on Lake Washington in Seattle.
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COMPLAINT Page 6 of 48
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27. According to information later submitted to the U.S. Rowing Association (see
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discussion below), GROOM became angry when he believed that the male high school rower and
2
other rowers under his supervision were not listening to his commands (when in fact they could
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not hear him due to the weather conditions), and directed them to row closer to the bridge, thereby
4 creating an even more dangerous situation for the young athletes. As their boat began taking on
5 freezing water, the rowers tried to bail it out with their water bottles until they were able to get
6 away from the bridge and turn back.
28. The male high school rower and his crew mates were freezing, exhausted, and
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shaken by the time they made it back to the boathouse, although GROOM appeared nonplussed.
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Although the male high school rower feared angry disapproval and retaliation by his coach, given
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the dangerous situation that GROOM had deliberately put him and his teammates in, and the
10 blatant disregard for their safety and well-being that GROOM had displayed in doing so, the male
11 high school rower believed he had no choice but to express his concerns to his coach about what
12 had transpired on the lake in order to protect himself and his crew from future harm.
29. Two days later, on November 21, 2011, the male high school rower approached
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GROOM with his concerns about the Highway 520 Bridge incident. In response, GROOM
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became visibly angry and began yelling at and berating the young athlete, dismissing his concerns
15
and exhorting him to “stop thinking about safety.”
16 30. In a series of subsequent emails, the male high school rower and his parents
17 complained to GROOM and his supervisor, SRC founder and Director CAROL NAGY, about
18 GROOM’s reckless disregard of his rowers’ safety and well-being, and his belligerent and abusive
19 tirade towards the male high school rower when he attempted to voice his concerns about the
Highway 520 Bridge incident.
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31. GROOM’s unsafe and abusive actions towards the male high school rower and
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numerous other SRC rowers–which NAGY and the club failed to take any effective action to
22 address—eventually resulted in the filing of a complaint against GROOM and SRC with the U.S.
23 Rowing Association by several individuals involved in the Pacific Northwest rowing community
24 who were concerned about GROOM and the harm he was causing to the athletes he was coaching.
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COMPLAINT Page 7 of 48
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32. One of the complaining parties, Margaret Christopher (“Christopher”), a coach at
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Pocock Rowing Center and an attorney, had learned of and was deeply troubled by the male high
2
school rower’s experience with GROOM and SRC. Christopher had worked with GROOM and
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NAGY at Pocock, and had personally observed GROOM’s inappropriate actions, as well as
4 NAGY’s complicity therein, throughout their tenure at Pocock.
5 33. After Christopher interviewed numerous other athletes (and their families) who had
6 been coached by GROOM and had been subjected to similarly abusive, demeaning, and dangerous
actions by GROOM, and/or to sexually harassing, sexually offensive, and related inappropriate
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grooming behavior, Christopher and other concerned parties filed a complaint against GROOM
8
with U.S. Rowing in December 2014 (“the 12/14 Complaint”). The complaint was based on the
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following wrongful actions by GROOM, NAGY, and SRC as asserted therein:
10 In and prior to 2006, while coaching at Pocock, CONAL GROOM reportedly seduced a
11 junior athlete and initiated a sexual relationship with her. He exhibited all the grooming
12 behavior towards both the athlete and her parent that is described in Safe Sport [training
13 and guidelines].
GROOM has exhibited frequent and extreme rageful behavior for many years towards
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athletes which creates an abusive environment for his athletes, their families, other
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members of the rowing community, and the public. This behavior includes screaming,
16
swearing, physically threatening behavior and even physical assault, in public, in front of
17 witnesses. Several statements from athletes and coaches who have directly experienced
18 this behavior [were] provided [with the complaint].
19 GROOM uses extremely offensive and abusive language toward his junior and high-
performance athletes, e.g. Calling a 4x of junior girls “[C word]s”, an incident which was
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witnessed by a coach from a neighboring club and her 8+ of junior girls.
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GROOM engages in inappropriate touching and sexually suggestive conversations with his
22
athletes as a matter of course and as a means of establishing and maintaining control and
23 power, such as leaning his body in close to rowers, particularly young female rowers,
24 trapping them up against a wall or door and having a forearm on the wall above them.
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COMPLAINT Page 8 of 48
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GROOM recruits rowers from other clubs in part by offering their parents the possibility of
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scholarships, college admissions and national team hopes. This is not abusive in and of
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itself but given his abusive behavior and coaching methods, it is identified by Safe Sport as
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a means of seducing athletes and their parents while protecting himself from and deflecting
4 criticism and concern by those parents and the rowers themselves.
5 GROOM treats certain athletes as “special,” openly stating that they are his favorites. [At
6 that time, he was] showing special attention to a junior girl at SRC, and has been rowing a
7 private double with her at a different boathouse and outside of normal SRC practice time.
His attention toward her has caused alarm in parents and coaches who are aware of it.
8
Some parents and athletes have left SRC as a result of their concerns, but others stay and
9
do not say anything, or develop “coping mechanisms” to deal with the behavior for all of
10
the reasons identified in the Safe Sport training. Given the structure of SRC, which is a
11 private, for-profit LLC with no board of directors, there is no meaningful way to bring a
12 grievance to the club itself, and clearly no oversight of the head coach.
13 There does not appear to be any other means of seeking redress of this matter except
through US Rowing. The purpose of bringing this grievance is to do whatever possible to
14
get this individual off the water; he has done far too much damage to athletes, to the
15
community and to the sport to allow him to remain part of competitive rowing.
16
17 34. During the course of interviewing athletes who had been subjected to harassing and
abusive treatment by GROOM and their family members, Christopher learned that GROOM had a
18
pattern and practice of selecting certain young female rowers and “grooming” them for potential
19
future sexual attention and abuse. Among the grooming behaviors that GROOM reportedly
20 engaged in towards female rowers who he openly declared were his “favorites” were:
21 Rides alone with them in cars, drives them to and from practice, to and from regattas
22 Gives them keys to his apartment
23 Asks them to take care of his pets
Gives them keys to his office
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Gives them other special and inappropriate privileges at the boathouse, like driving a
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COMPLAINT Page 9 of 48
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Has blatantly inappropriate physical contact and lack of physical boundaries with them
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Rows alone with them (clandestinely, at other boathouses)
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Texts and calls them at all hours and about personal/sexual things
3
Stands too close or leans into them against a wall with an arm over their head when talking
4 Trains side by side with them for hours at a time
5 Gets close with their parents
6 Comments on their physical appearance, both negatively and positively, both alone and in
front of their teammates
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Makes weird remarks about his relationship with them to imply that they are dating and/or
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others are jealous of her/them
9
Pays special attention to them in front of other rowers and neglects/ignores other rowers
10 Walks into the girls locker room at will to “talk” to someone or yell at the team while they
11 are changing clothes, to the point where some of them would change in the closet.
12
35. GROOM engaged in the above wrongful actions on top of the toxic environment he
13 creates, where his authority cannot be questioned and athletes’ physical and emotional boundaries
14 are broken down by daily abuse, reckless endangerment, and bullying, thereby making athletes
15 even more vulnerable to sexual exploitation.
36. Regarding GROOM’s offensive and dangerous actions towards the male high
16
school rower, Christopher confirmed in her complaint to U.S. Rowing that that athlete experienced
17
ongoing verbal, physical and emotional abuse by coach CONAL GROOM and witnessed the same
18
perpetrated on his teammates.
19 37. PLAINTIFF is informed and believes and thereon alleges that numerous athletes,
20 family members, and staff have reported to Pocock Rowing Center various inappropriate, abusive,
21 dangerous, and at times violent actions by GROOM towards male and female rowers that he
22 coached, including open and belligerent altercations between him and his athletes.
38. PLAINTIFF is informed and believes and thereon alleges that in one incident, four
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female rowers who were training under GROOM at SRC left the club and went to Pocock to train
24
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COMPLAINT Page 10 of 48
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for a brief period prior to a key competition after GROOM reportedly engaged in an altercation
1
with them and kicked them out of SRC.
2
39. PLAINTIFF is informed and believes and thereon alleges that in another disturbing
3
incident in 2013, a Pocock staff member witnessed and reported an angry and denigrating outburst
4 by GROOM towards four female rowers he was coaching during a rowing practice session on
5 Portage Bay (Lake Union) in which GROOM yelled at them that they were “[C word]s,” shocking
6 and offending the Pocock staff member and the female athletes in her boat who witnessed
GROOM’s outburst, and causing them great concern for the safety and well-being of the female
7
athletes under GROOM’s supervision.
8
40. Pocock subsequently sent a letter to U.S. Rowing to report and express his concerns
9
regarding the incident. The letter noted that GROOM had violated established coaching and
10 behavioral standards set by U.S. Rowing for working with youth athletes, and that the local
11 rowing community had been subjected to and/or was aware of various other instances of
12 inappropriate and dangerous conduct by GROOM that had occurred over a period of years, and
that it would be unsafe and morally reprehensible to allow him to continue to coach athletes,
13
particularly young athletes, given the power, ability, and access he had to harm and abuse them.
14
41. Following submission of the 12/14 Complaint against GROOM with U.S. Rowing
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by Pocock coach Margaret Christopher, CAROL NAGY began to send threatening emails to
16 Pocock Rowing demanding that the club fire Christopher. Shortly after Pocock informed NAGY
17 that it would not be silencing or terminating Christopher, NAGY abruptly entered the club’s
18 offices and again angrily demanded that a club official fire Christopher. Specifically, NAGY
19 slammed her hands down on the official’s desk and exhorted the official in a hostile manner, “you
need to stop her from doing this” and “you need to fire Margaret.” NAGY then threatened the
20
official and Pocock by stating that Christopher’s complaint against GROOM was “ruining [her]
21
business” and that “this needs to stop or I will sue you.”
22 42. Notwithstanding the 12/14 Complaint, GROOM was allowed to continue coaching,
23 eventually closing and leaving SRC with NAGY and founding MISSION ROWING in Santa
24 Ynez, California in 2019.
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COMPLAINT Page 11 of 48
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43. PLAINTIFF, and on information and belief, other parties with knowledge of these
1
facts, are unaware of any actions by NAGY to address GROOM’s wrongful and dangerous actions
2
towards the athletes he coached, or to protect those athletes from further harm by GROOM.
3
Instead, NAGY routinely defended GROOM and his inappropriate behavior to those who
4 questioned or complained about GROOM, was complicit in his wrongful actions, and sanctioned
5 his wrongful actions by allowing them to continue unabated throughout the time that NAGY
6 worked with GROOM.
44. Given this history of inappropriate behavior by GROOM, and NAGY’s knowledge
7
of and failure to take any effective action to deter such wrongful behavior, and to instead support
8
and sanction GROOM’s actions, it is not surprising that, following the 12/14 Complaint, GROOM
9
had the opportunity and authority to harm vulnerable and impressionable young athletes like
10 PLAINTIFF.
11 GROOM First Noticed and Began To Engage in Predatory Grooming Behaviors
Towards PLAINTIFF When She Showed Talent and Dedication to His SRC Rowing
12 Teams as an Eighth Grader
13 45. PLAINTIFF initially became involved with GROOM’s and NAGY’s Seattle-based
14 rowing club, SRC, when she joined the club’s after school youth program in 2015 as a fifth grader.
15 46. In late summer 2018, at the beginning of her eighth-grade school year, PLAINTIFF
joined SRC’s juniors racing program, which was coached by CONAL GROOM and made up
16
largely of high school aged athletes. PLAINTIFF loved rowing and demonstrated intense focus
17
and significant aptitude for the sport.
18
47. By the middle of PLAINTIFF’s first academic year as a junior rower (Spring
19 2019), GROOM had noticed her, her dedication, and her talent, and moved her up from the novice
20 team to row with the SRC varsity team.
21 48. Around the same time, GROOM began to show special attention and display
22 favorable treatment towards PLAINTIFF, such as telling her what a talented athlete she was,
allowing her to eat pie while her teammates worked to re-rig a boat, and giving her the nicest
23
single boat to row for time trials (which were held to determine which athletes would attend the
24
upcoming junior national competition).
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COMPLAINT Page 12 of 48
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49. Predatory “grooming” occurs when an individual (often with power and/or
1
authority over their victim) engages in a series of behaviors with the goal of engaging in sexual
2
misconduct. In situations of child sexual abuse, the abuser targets a minor and works to earn the
3
trust of the minor, the minor’s family, and the community. It can also be manipulative behavior
4 the abuser uses to prolong the abuse and make the minor fear reporting or be less likely to be
5 believed if they do report. See https://uscenterforsafesport.org/endabuseinsport_parents/ ;
6 https://uscenterforsafesport.org/wp-content/uploads/2020/05/Parent-Toolkit_Complete-1.pdf
50. According to the U.S. Center for SafeSport (“SafeSport”), inappropriate and
7
potentially dangerous grooming behaviors include:
8
Attempts to befriend the minor as a peer or “cool adult”
9
Giving the minor gifts and special attention
10
Talking to the minor about sexual experiences or desires
11 Being helpful and non-threatening to the minor’s family
12 Volunteering for situations that involve spending time alone with the minor
13 Using organizational status to have one-on-one interactions with the minor. (Id.)
14 51. In an effort to guard against and help protect vulnerable athletes from potentially
15 dangerous grooming behaviors, SafeSport provides training and guidelines for athletic
16 organizations to help them, their managers, coaches and staff, the athletes that train with them, and
17 their families to be able to identify, understand, and take steps to guard against such grooming.
One of the key preventative measures an athletic organization should take, according to SafeSport,
18
is to prevent unsupervised, one-on-one conduct between a coach and their minor athlete. See
19
SafeSport Minor Athlete Abuse Prevention Policies (“MAAPP”), which limit one-on-one
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adult/minor interactions and set standards for training and sport settings that prevent abuse and
21 misconduct: https://maapp.uscenterforsafesport.org/ ; See also
22 https://uscenterforsafesport.org/endabuseinsport_parents/; https://uscenterforsafesport.org/wp-
23 content/uploads/2020/05/Parent-Toolkit_Complete-1.pdf .
52. As PLAINTIFF, her family members and friends, and other MISSION, SRC, and
24
Pocock athletes and coaches will testify, and as evidenced by the thousands of text messages
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COMPLAINT Page 13 of 48
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exchanged between PLAINTIFF and GROOM during the two-year period leading up to the
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8/13/21 Assault, GROOM engaged in all of the above predatory grooming behaviors towards
2
PLAINTIFF that SafeSport cautions against shortly after he began coaching PLAINTIFF at SRC,
3
and continuing throughout the time he coached her at MISSION ROWING.
4 53. In May 2019, GROOM invited PLAINTIFF to row for SRC at the U.S. Rowing
5 Youth National Championships scheduled to be held in Florida in Sarasota, Florida the following
6 month.
54. Shortly thereafter, GROOM and NAGY announced that they were closing SRC and
7
starting a new rowing club, MISSION ROWING, based in Santa Ynez, California.
8
55. After the announcement, and in conjunction with PLAINTIFF’s graduation from
9
middle school in May 2019, GROOM sent PLAINTIFF a predatory letter in which told her, “We
10 will miss you more than others,” commented “I love the passion and fire you Bring” and “I love
11 how much you care and how hard you take the losses and the failures,” and invited her to “free to
12 call/text/email … to vent or ask questions whenever you need or want.” He closed the letter by
commenting in part, “It will be hard to leave you and for that I am very very sorry” and signed it,
13
“Love Always, Conal.”
14
56. Following the announcement of SRC’s closure and the opening of MISSION
15
ROWING, PLAINTIFF’s mother, PLAINTIFF’S mother, met with GROOM to discuss
16 PLAINTIFF’s rowing future. GROOM told PLAINTIFF’S mother that her daughter was talented
17 and could continue to train at Pocock, but commented that he was really “the best coach for her.”
18 57. In a subsequent conversation, GROOM and NAGY told PLAINTIFF’S mother that
19 PLAINTIFF could come to California to train with their new MISSION ROWING team during
the summer and other school breaks.
20
58. In June 2019, just prior to SRC’s closure, PLAINTIFF and other selected SRC
21
rowers represented the club at the U.S. Rowing Youth National Championships in Sarasota,
22 Florida. On the first day of racing, GROOM made it clear that PLAINTIFF was one of his new
23 “favorite” athletes, introducing her to his friends and showing her off as the small but powerful
24 middle schooler he had brought to race.
25
26
COMPLAINT Page 14 of 48
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59. During the summer of 2019, GROOM, NAGY, and NAGY’s husband, Ed Meyer,
1
moved to Santa Ynez to operate GROOM’s and NAGY’s new club, MISSION ROWING, and
2
started living together in a large rental house at on Tivola Street in Santa Ynez, California.
3
60. At least four former SRC rowers also moved to the Santa Ynez Valley area to train
4 with MISSION. Although PLAINTIFF rowed with College Club that summer and Pocock
5 through the fall, GROOM remained intensively involved in her training, provided her with daily
6 work out routines, and talked with her frequently by phone and FaceTime about her practices.
61. GROOM regularly asked PLAINTIFF to send screen shots and video footage of
7
her rowing on the Pocock club’s indoor rowing machine (known as an ergometer or “erg”) for him
8
to review, and spent hours analyzing her movements and “debriefing” with her.
9
62. In November 2019, GROOM and NAGY drove from Santa Ynez to San Diego to
10 watch and encourage PLAINTIFF as she competed as a member of the Pocock Rowing Center
11 team in the Fall Classic rowing competition held at MISSION Bay. GROOM also loaned her a
12 SpeedCoach GPS 2 performance monitor, helped her rig her boat, and got her “psyched up” for
the race. PLAINTIFF finished second in both the single and the double races she competed in.
13
63. Two weeks later, PLAINTIFF and her family spent the Thanksgiving holiday in the
14
Santa Ynez Valley, where PLAINTIFF trained with GROOM and the other elite athletes.
15
GROOM again gave PLAINTIFF one of the nicest boats to row and showered her with attention,
16 both in front of other athletes, and during private one-on-one sessions he arranged with her (which
17 as noted above, are prohibited under SafeSport’s Minor Athlete Abuse Prevention Policies).
18 PLAINTIFF and her family were invited to Thanksgiving dinner at NAGY’s and GROOM’s
19 house.
64. During one of the training sessions that PLAINTIFF attended that week, GROOM
20
became angry and began yelling and screaming at her for failing to pick up an instruction quickly
21
enough. Understanding that her worst fear was being only an “average” rower, GROOM
22 screamed at PLAINTIFF that she would be “average forever.” PLAINTIFF captured GROOM’s
23 outburst on video on her cell phone.
24
25
26
COMPLAINT Page 15 of 48
27
28
65. Following their Thanksgiving training sessions in Santa Ynez, GROOM continued
1
to contact PLAINTIFF frequently about her training and various aspects of her personal life.
2
After PLAINTIFF Began Rowing With GROOM’s and NAGY’s New Santa Ynez-
3 Based Club, MISSION ROWING, in the Winter and Spring of 2020, GROOM
Continued His Inappropriate Grooming Behaviors, and Began to Verbally and
4 Physically Abuse and Sexually Harass Her
5
66. In February 2020, PLAINTIFF had a week off from school for the President’s Day
6 holiday. Although her family had planned a trip to Arizona, PLAINTIFF was eager to return to
7 the Santa Ynez Valley to row with GROOM at MISSION.
8 67. Instead of spending her vacation with her family, PLAINTIFF flew to California
and spent the week training with GROOM and staying at the rental home located at 3330 Tivola
9
Street, Santa Ynez, California that NAGY, her husband Meyer, and GROOM were living in.
10
PLAINTIFF stayed in GROOM’s bedroom while he slept in a tent outside.
11
68. GROOM continued to show favoritism towards PLAINTIFF by taking the best
12 boat he owned from an older athlete and giving it to PLAINTIFF to row during practices. He also
13 coached her one-on-one, attended a yoga class with her, took her to get a massage, and arranged to
14 spend time alone with her.
15 69. In the midst of one practice session during the week, GROOM suddenly became
angry and belligerent with PLAINTIFF and began yelling at her in frustration, frightening her,
16
demeaning her, and pushing her to the verge of tears.
17
70. At the end of the week, PLAINTIFF met with GROOM to discuss her goals. Her
18 most significant goal was to gain an invitation U.S. Rowing Junior National Team Selection Camp
19 in the San Diego area—the required step to be able to compete for a spot on the junior national
20 team—for the upcoming summer.
21 71. In March 2020, the COVID-19 pandemic hit. The school in Seattle that
PLAINTIFF was attending as a ninth grader went online, and Seattle-area rowing programs shut
22
down. PLAINTIFF continued to train on her own under GROOM’s supervision (via phone,
23
FaceTime, text, and other electronic communication), working out on the erg at home, lifting
24 weights, and cross training in accordance with a strenuous training plan that GROOM had written.
25
26
COMPLAINT Page 16 of 48
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28
72. When PLAINTIFF failed to hit her goal split times on near impossible training
1
pieces, GROOM began to angrily and aggressively berate her for her failures, causing her to feel
2
dejected and humiliated, and shaking her confidence. Fearing abusive treatment, hostility, and
3
disapproval from GROOM, PLAINTIFF began to dread erging sessions and struggled to sit down
4 at the erg machine to pull a piece.
5 73. Around this same time, GROOM began to probe and intrude into PLAINTIFF’s
6 personal life, and openly exhibited anger, frustration, and jealousy when he found out that
PLAINTIFF had become romantically involved with a young man in Seattle. When PLAINTIFF
7
informed GROOM that she had a boyfriend, he became enraged, screaming at her over the phone
8
for failing to tell him about the relationship previously and berating her that if they were going to
9
work together, she needed to “tell him everything” or else he could not coach her effectively.
10 74. As the COVID-19 lockdown continued, PLAINTIFF missed her regular rowing
11 team activities and the camaraderie of her team, and grew increasingly anxious and distressed as a
12 result of GROOM’s intensive training regimen and hostile and abusive treatment. PLAINTIFF
began to experience regular panic attacks for the first time in her life, prompting her to seek
13
attention from a sports psychologist and begin taking medication to help control her episodes of
14
panic.
15
75. Aware that PLAINTIFF’s mental condition was obviously deteriorating, but
16 refusing to acknowledge that he was contributing to her emotional decline, GROOM contacted her
17 mother, PLAINTIFF’S mother, and suggested that PLAINTIFF would be better off moving to
18 Santa Ynez to train with him at MISSION ROWING.
19 76. A few months later, in response to GROOM’s “suggestion,” PLAINTIFF moved to
Santa Ynez to train with him and other MISSION ROWING athletes for the summer, all under the
20
supervision of GROOM and his longtime friend and supporter, NAGY. For the first five weeks,
21
PLAINTIFF lived with her family in a house they had rented in the area.
22 77. When her family returned to Seattle in early July 2020, PLAINTIFF and a fellow
23 Seattle rower and friend stayed in Santa Ynez for another month to continue their training with
24
25
26
COMPLAINT Page 17 of 48
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MISSION, and moved into the rental house that GROOM, NAGY, and Meyer were all living in in
1
the area.
2
78. By that time, GROOM had befriended PLAINTIFF and treated her like a peer or
3
“cool adult” by frequently communicating with her in one-on-one phone and FaceTime calls,
4 private text exchanges, and social media messages, and in person about her family, friends,
5 boyfriend, personal and dating life, sexual knowledge, and sexual experience, and by offering to
6 give or buy her and her minor friends alcohol. GROOM routinely referred to PLAINTIFF in
private text messages as his “bf” [best friend] and by other flattering, intimate nicknames such as
7
“#1,” “B,” “Bud,” “Babe,” and “Stud.” The volume, frequency, and tenor of GROOM’s text
8
messages to this teenage female athlete, with whom he was prohibited under SafeSport guidelines
9
from having even one private, intimate communication with, and with whom he had thousands of
10 such exchanges, is deeply disturbing.
11 79. GROOM also frequently and flagrantly violated SafeSport’s prohibition against
12 unsupervised, one-on-one conduct between a coach and their minor athlete by going on long bike
rides and rowing training sessions alone with PLAINTIFF, and by repeatedly inviting her to come
13
to his living quarters (on NAGY’s property) to visit him and his animals, and to cook, eat, watch
14
movies, and hang out away from any other people.
15
80. GROOM was aware of PLAINTIFF’s love for animals, especially baby animals,
16 and used the animals he was raising to entice her to spend even more time with him, repeatedly
17 encouraging her to come over to pet and hold his baby bunnies and baby chicks, help care for
18 them, and build and clean enclosures for them. GROOM also made several statements in text
19 messages telling PLAINTIFF that his house was her house, that she was welcome any time, and
that he was always available to her and for her and for whatever she needed.
20
81. Throughout the summer of 2020, and for the following two years, Groom engaged
21
in a pattern of physical and emotional abuse toward, and exerted his physical and emotional power
22 and authority over, PLAINTIFF.
23 82. On many occasions Groom angrily yelled, cursed, screamed at and threatened
24 PLAINTIFF and other athletes in PLAINTIFF’s presence, causing PLAINTIFF to become upset,
25
26
COMPLAINT Page 18 of 48
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ashamed, dejected, and desperate, to break down and cry, and to experience panic attacks and
1
various other anxiety- and stress-related symptoms for which she sought treatment.
2
83. GROOM intermittently yelled and cursed at PLAINTIFF and one of her female
3
teammates, who had also come down from Seattle to train with MISSION for the summer.
4 84. When PLAINTIFF was successful in beating one of her rival teammates, GROOM
5 would reward her with food, sweet treats, rowing attire, and, most importantly to her, his attention.
6 85. For PLAINTIFF’s 16th birthday in July 2020, GROOM prepared a special meal for
her and gave her more than $800 in rowing “kit” (clothing).
7
86. GROOM frequently demonstrated emotional instability and mood swings, going
8
from being fun and playful with PLAINTIFF and showering her with favorable attention to
9
becoming argumentative and angry and bullying her.
10 87. One morning when PLAINTIFF and a female teammate were rowing in a double
11 boat that kept turning to port, GROOM quietly gave PLAINTIFF’S teammate an instruction that
12 she did not hear, then became furious and berated her for purportedly failing listen to him and
demanded that the young women return to the dock. PLAINTIFF was so upset that she cried,
13
prompting GROOM to tell her later that she had not done anything wrong, and that he had reacted
14
in that manner to “teach [her female teammate] a lesson.”
15
88. Another day, PLAINTIFF was fretting over her performance during a training
16 exercise on the club’s the RP3 rowing machine. When PLAINTIFF told GROOM that she was
17 disappointed by her failure to beat her teammate on pieces that, unbeknownst to her, had been
18 adjusted for their weight, GROOM screamed at her for being “an idiot” and berated her for not
19 being aware of the weight adjustment.
89. GROOM also often drank alcohol excessively, exacerbating his erratic and volatile
20
behavior. At one point during the summer of 2020, PLAINTIFF told her mother that GROOM
21
had been arguing with everyone at dinner and that she thought alcohol was a factor.
22 90. When PLAINTIFF’S mother promptly called NAGY to discuss the situation,
23 NAGY told her that GROOM could be “moody sometimes” and that it was “usually a sign of
24 stress.” NAGY encouraged PLAINTIFF’S mother to call GROOM to “check in,” but did not
25
26
COMPLAINT Page 19 of 48
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28
indicate that she herself would take any action to address PLAINTIFF’S mother’s and
1
PLAINTIFF’s concerns about GROOM’s behavior.
2
91. GROOM also repeatedly touched PLAINTIFF in offensive, unwelcome, and
3
inappropriate ways on numerous occasions prior to the 8/13/21 Assault, including frequent
4 unwanted touching of various parts of her body, backrubs, and full body hugs.
5 92. Groom exerted his power and authority over PLAINTIFF by demanding that she
6 and other athletes row in dangerous fog and/or wind conditions on Cachuma Lake, threatening
their safety. Groom would angrily yell, scream, and threaten PLAINTIFF and other rowers not to
7
“f--- up his boats” or damage the equipment while doing so.
8
93. Groom further displayed his dominance and control over PLAINTIFF by engaging
9
in violent and threatening behavior toward PLAINTIFF on numerous occasions, such as when he
10 placed his hands around her throat in chokeholds, and when he grabbed a rowing machine handle
11 out of PLAINTIFF’s hands while she was training on the machine and threw it so hard against the
12 machine cage that it broke.
94. In August 2020, PLAINTIFF returned to her home in Seattle to begin her freshman
13
year of high school. Due to the ongoing COVID-19 pandemic, her classes were all online for the
14
entire school year.
15
95. PLAINTIFF rowed with the Masters team at a Seattle-based rowing club, and at
16 Pocock Rowing Club in the afternoons. GROOM continued to monitor her training remotely from
17 Santa Ynez and pushed her to do additional workouts when he believed she had not done enough
18 in a given day.
19 96. GROOM also sent PLAINTIFF inappropriate SnapChat and text messages of an
intimate and/or sexual nature from the Fall of 2020 up until the 8/13/21 Assault. The texts can
20
generally be categorized as:
21
Establishing a secret relationship with her;
22 Making her feel special and fostering an intimate bond as confidantes while talking about
23 “missing” and “loving” her and assuring her that he will protect her;
24 Framing parents and other adults as adversaries and making himself a hero to her;
25
26
COMPLAINT Page 20 of 48
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Desensitizing her
Preview
1 JANEAN ACEVEDO DANIELS, SBN 145707 Attorney at Law 2 Law Office of Janean Acevedo Daniels 1160 Via del Rey 3 Goleta, CA 93117 phone: (805) 284-4428 fax: (805) 456-2050 janean@jadanielslaw.com 4 Attorney for PLAINTIFF JANE DOE 5 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF SANTA BARBARA 9 10 JANE DOE Case No. 11 PLAINTIFF, COMPLAINT FOR DAMAGES FOR: 12 v. 1. Assault & Battery 13 2. Sexual Battery in Violation of Civil Code MISSION ROWING, a California nonprofit § 1708.5 14 public benefit corporation; CONAL 3. Sexual Harassment in Violation of Unruh GROOM, an individual; CAROL NAGY, an Act, Civil Code § 51.9 15 individual; and DOES 1-50, inclusive, 4. Gender Violence in Violation of Civil Code § 52.4 16 5. Violation of Ralphs Civil Rights Act, Civil DEFENDANTS. Code § 51.7 17 6. False Imprisonment 7. Intentional Infliction of Emotional Distress 18 8. Negligent Infliction of Emotional Distress 19 9. Negligent Hiring, Training, Supervision and Retention 20 10. Negligence 11. Defamation Per Se 21 22 DEMAND FOR JURY TRIAL 23 24 PLAINTIFF JANE DOE alleges: 25 26 COMPLAINT Page 1 of 48 27 28 GENERAL ALLEGATIONS 1 1. At all times pertinent hereto, PLAINTIFF JANE DOE (“PLAINTIFF”) was a 2 resident of the State of Washington and of the County of Santa Barbara, California, where she 3 lived and resided during the times she was training with DEFENDANTS MISSION ROWING and 4 CONAL GROOM in Santa Ynez, California. DOE is suing under a pseudonym in order to protect 5 her privacy, and because she was a minor at the time she was subjected to the injurious actions 6 described herein. 2. The true names and capacities of DOES 1-50, whether individual, corporate, 7 associate or otherwise are unknown to PLAINTIFF at this time, who therefore sues these 8 DEFENDANTS by such fictitious names. When the true names and capacities of such 9 DEFENDANTS are ascertained, PLAINTIFF will amend this complaint to insert the true names 10 and capacities of said DOE DEFENDANTS. 11 3. DEFENDANT MISSION ROWING (“MISSION”) is, and at all times pertinent 12 hereto has been, a nonprofit public benefit corporation organized and existing under the laws of the State of California that operates and/or operated a rowing club in the County of Santa Barbara, 13 California. 14 4. DEFENDANTS MISSION ROWING and CONAL GROOM are liable in a cause 15 of action for sexual harassment under California’s Unruh Act, Civil. Code § 51.9, because they are 16 persons who had a business, service, or professional relationship with PLAINTIFF at all times 17 pertinent hereto. 18 5. DEFENDANT CONAL GROOM is an individual who resides in the County of 19 Santa Barbara, California. At all times pertinent hereto, GROOM was employed by MISSION in the County of Santa Barbara, California and regularly communicated and interacted with 20 PLAINTIFF regarding the matters at issue in this case as an agent and servant of MISSION. 21 6. PLAINTIFF is informed and believes and on that basis alleges that each 22 DEFENDANT in this Complaint was, at all times mentioned, the agent, servant and/or employee 23 of the other DEFENDANT and was at all such times acting within the course and scope of said 24 agency and/or employment. 25 26 COMPLAINT Page 2 of 48 27 28 7. PLAINTIFF is informed and believes and on that basis alleges that each 1 DEFENDANT named as a DOE DEFENDANT is responsible for each and every act and 2 obligation set forth in this complaint. 3 4 SUMMARY OF CLAIMS 5 8. PLAINTIFF is 18 years old and a former MISSION ROWING athlete and client. 6 PLAINTIFF asserts claims against DEFENDANTS MISSION ROWING, CONAL GROOM, and CAROL NAGY arising from the physical, verbal, and emotional abuse, threats, sexual 7 harassment, assault, and battery to which she was subjected for more than two years while she was 8 a minor, culminating in her false imprisonment and sexual battery by MISSION employee and 9 coach CONAL GROOM. GROOM, who is 49 years old, was a significantly older adult who 10 PLAINTIFF trusted and did everything possible to please until he violated her trust by grievously 11 injuring her when he ordered her to come to his home on the evening of August 13, 2022, where 12 he forcibly detained and restrained, falsely imprisoned, and assaulted, battered, and sexually battered her (“the 8/13/21 Assault”). 13 9. From November 2019, when CONAL GROOM engaged in his first angry outburst 14 toward PLAINTIFF, until August 13, 2022, the night he falsely imprisoned and assaulted and 15 sexually battered her, CONAL GROOM pushed PLAINTIFF relentlessly, often to the point of 16 tears and emotional breakdowns, with his abusive, demeaning, and at times violent behavior, and 17 his inappropriate, unwelcome, and sexually-suggestive personal attention and predatory grooming 18 behavior--all under the auspices of MISSION ROWING, and with the purported purpose of 19 helping this high school-aged athlete achieve her goal of rowing competitively at the national level, and her dream of becoming an Olympic athlete. 20 10. GROOM’s shocking actions towards PLAINTIFF, who was only 15 years old 21 when the abuse began, violated standards for appropriate coaching of minor athletes by the United 22 States Rowing Association and United States Center for SafeSport, and were committed within the 23 course and scope of GROOM’s employment with MISSION ROWING. 24 25 26 COMPLAINT Page 3 of 48 27 28 11. GROOM’s unlawful and offensive actions were ratified by MISSION founder, 1 Director, and former Executive Director CAROL NAGY, who was aware of GROOM’s wrongful 2 conduct toward PLAINTIFF and other MISSION client athletes but did nothing to protect 3 PLAINTIFF from further harm (or ultimately, from GROOM’s sexual harassment, assault and 4 battery), and by MISSION ROWING. 5 12. GROOM’s shocking actions, which could have been prevented had NAGY and/or 6 MISSION ROWING acted with due care and concern for the safety and well-being of PLAINTIFF and various other athletes being coached by GROOM, have traumatized PLAINTIFF 7 and caused her to suffer various physical and emotional injuries which have required professional 8 evaluation and treatment, including anxiety, panic, recurring disturbing thoughts and nightmares 9 regarding GROOM’s abuse, and other symptoms of Posttraumatic Stress Disorder, along with 10 sleep disruption, depressed mood, withdrawal from social situations, and a loss of interest in 11 activities that previously brought her pleasure. 12 13. As a result, this strong and brave young woman, whose love and passion for rowing were eclipsed only by her desire to please and prove herself to the coach she idolized, CONAL 13 GROOM, remains pained and haunted by these events to this day. 14 14. Based on GROOM’s unlawful, offensive, and injurious actions towards 15 PLAINTIFF as described below, and GROOM’s position and authority over PLAINTIFF as her 16 coach and an employee of MISSION ROWING, the rowing club of which she was a loyal and 17 committed member, PLAINTIFF asserts the common law tort claims and statutory claims as 18 described herein against MISSION, and against GROOM and NAGY individually to the extent 19 permitted by law, and seeks compensation for all harm, injury, loss, general and special damages she has suffered, and for the attorney’s fees and costs she has incurred, as a proximate result 20 thereof. 21 15. PLAINTIFF also asserts claims against NAGY individually based on her knowing 22 and reckless disregard for, and lack of due care for, PLAINTIFF’s safety, well-being, and dignity 23 in allowing GROOM to continue to have access to, and continue to coach in an abusive and 24 harmful manner, PLAINTIFF and other young athletes, thereby sanctioning GROOM’s abusive 25 26 COMPLAINT Page 4 of 48 27 28 conduct, and providing GROOM with the opportunity and authority to direct PLAINTIFF to come 1 to his home on NAGY’s property (a shipping container shed in NAGY’s backyard that serves as 2 GROOM’s living quarters), where GROOM falsely imprisoned, assaulted, battered, and sexually 3 battered her. 4 5 FACTUAL BACKGROUND 6 16. From 2002 to 2007, CONAL GROOM worked at the Pocock Rowing Center in Seattle, Washington, where he coached the club’s elite sculling team. (Elite sculling teams are 7 made up of elite athletes who are competing for spots on national team/competition-level boats, 8 often young adults in their late teens and early twenties.) 9 17. While working and coaching at the Pocock club, GROOM met CAROL NAGY 10 and her minor daughter. GROOM hired NAGY to be the boathouse business manager, a position 11 she held from approximately 2006 to 2007, and coached her daughter. 12 18. On March 24, 2007, GROOM physically assaulted and battered one of the young female elite rowers he was coaching. According to a written statement that the athlete provided in 13 2014 as part of a grievance against GROOM filed with the United States Rowing Association at 14 that time, after the athlete questioned GROOM’s failure to notify her and other rowers in her scull 15 during a race training exercise that a large boat was approaching them (resulting in their boat 16 taking on so much water that they had to return to the boathouse), GROOM grabbed her by the 17 arms/shoulders and threw her toward the stairs of the Pocock boathouse, where she fell to the 18 ground. 19 19. The female rower, who reported GROOM’s assault to the police, confirmed in her statement in connection with the U.S. Rowing investigation that the assault and other wrongful 20 treatment she and other athletes experienced under GROOM’s coaching supervision led her to quit 21 rowing--a sport she had dedicated years of her life to--altogether. 22 20. GROOM was reportedly reprimanded by Pocock for his attack on the female 23 athlete and was suspended from coaching the elite sculling team. Following GROOM’s 24 suspension, GROOM and NAGY left Pocock together. 25 26 COMPLAINT Page 5 of 48 27 28 21. GROOM then moved to a head coaching position at Lake Union Crew in Seattle. 1 NAGY followed GROOM to the club and worked as Lake Union Crew’s business manager. 2 22. In 2010, GROOM and NAGY left Lake Union Crew together and established 3 their own private rowing club, the Seattle Rowing Center (“SRC”). 4 23. From 2010 to 2019, GROOM served as head coach of SRC and lived in the club’s 5 boathouse. NAGY served as the club’s Director and GROOM’s supervisor, and operated the 6 organization as a for-profit entity without oversight by an independent Board of Directors. This management structure and the lack of oversight by a Board of Directors made it impossible for 7 complaints of misconduct by GROOM to be escalated beyond the level of or to persons other than 8 NAGY, who was understood by the rowing community to have a close relationship with GROOM 9 due to his coaching of her daughter, and her own friendship with GROOM. NAGY developed a 10 reputation for protecting GROOM and failing to take action to address coaching misconduct that 11 he reportedly repeatedly engaged in towards the athletes entrusted to his supervision. 12 24. SRC, which had a middle school program, a junior racing team, and a high- performance elite sculling team, catered to young rowers and their parents, promising that 13 GROOM’s intense coaching style and training regimens would pay off for the young athletes 14 placed in his charge by significantly improving their performance and allowing them to reach their 15 goals of rowing at the elite level. 16 25. When many of the young athletes and their parents were subjected to, witnessed, or 17 otherwise became aware of wrongful, offensive, and at times dangerous actions by GROOM 18 towards his athletes, and complained to GROOM and NAGY, GROOM denied acting 19 inappropriately and/or blamed his victims, while NAGY continually defended GROOM and his actions, often claiming that GROOM had just had a “bad day,” and trying to explain away his 20 offensive actions by telling the complaining parties that GROOM had “anger issues” that he 21 needed to work on, and/or that he was struggling with alcohol addiction. 22 26. On November 19, 2011, GROOM sent several of his junior athletes, including a 23 male high school rower, out to row in perilous weather conditions near the Evergreen Point 24 Floating Bridge (known locally as the “Highway 520 Bridge”) on Lake Washington in Seattle. 25 26 COMPLAINT Page 6 of 48 27 28 27. According to information later submitted to the U.S. Rowing Association (see 1 discussion below), GROOM became angry when he believed that the male high school rower and 2 other rowers under his supervision were not listening to his commands (when in fact they could 3 not hear him due to the weather conditions), and directed them to row closer to the bridge, thereby 4 creating an even more dangerous situation for the young athletes. As their boat began taking on 5 freezing water, the rowers tried to bail it out with their water bottles until they were able to get 6 away from the bridge and turn back. 28. The male high school rower and his crew mates were freezing, exhausted, and 7 shaken by the time they made it back to the boathouse, although GROOM appeared nonplussed. 8 Although the male high school rower feared angry disapproval and retaliation by his coach, given 9 the dangerous situation that GROOM had deliberately put him and his teammates in, and the 10 blatant disregard for their safety and well-being that GROOM had displayed in doing so, the male 11 high school rower believed he had no choice but to express his concerns to his coach about what 12 had transpired on the lake in order to protect himself and his crew from future harm. 29. Two days later, on November 21, 2011, the male high school rower approached 13 GROOM with his concerns about the Highway 520 Bridge incident. In response, GROOM 14 became visibly angry and began yelling at and berating the young athlete, dismissing his concerns 15 and exhorting him to “stop thinking about safety.” 16 30. In a series of subsequent emails, the male high school rower and his parents 17 complained to GROOM and his supervisor, SRC founder and Director CAROL NAGY, about 18 GROOM’s reckless disregard of his rowers’ safety and well-being, and his belligerent and abusive 19 tirade towards the male high school rower when he attempted to voice his concerns about the Highway 520 Bridge incident. 20 31. GROOM’s unsafe and abusive actions towards the male high school rower and 21 numerous other SRC rowers–which NAGY and the club failed to take any effective action to 22 address—eventually resulted in the filing of a complaint against GROOM and SRC with the U.S. 23 Rowing Association by several individuals involved in the Pacific Northwest rowing community 24 who were concerned about GROOM and the harm he was causing to the athletes he was coaching. 25 26 COMPLAINT Page 7 of 48 27 28 32. One of the complaining parties, Margaret Christopher (“Christopher”), a coach at 1 Pocock Rowing Center and an attorney, had learned of and was deeply troubled by the male high 2 school rower’s experience with GROOM and SRC. Christopher had worked with GROOM and 3 NAGY at Pocock, and had personally observed GROOM’s inappropriate actions, as well as 4 NAGY’s complicity therein, throughout their tenure at Pocock. 5 33. After Christopher interviewed numerous other athletes (and their families) who had 6 been coached by GROOM and had been subjected to similarly abusive, demeaning, and dangerous actions by GROOM, and/or to sexually harassing, sexually offensive, and related inappropriate 7 grooming behavior, Christopher and other concerned parties filed a complaint against GROOM 8 with U.S. Rowing in December 2014 (“the 12/14 Complaint”). The complaint was based on the 9 following wrongful actions by GROOM, NAGY, and SRC as asserted therein: 10 In and prior to 2006, while coaching at Pocock, CONAL GROOM reportedly seduced a 11 junior athlete and initiated a sexual relationship with her. He exhibited all the grooming 12 behavior towards both the athlete and her parent that is described in Safe Sport [training 13 and guidelines]. GROOM has exhibited frequent and extreme rageful behavior for many years towards 14 athletes which creates an abusive environment for his athletes, their families, other 15 members of the rowing community, and the public. This behavior includes screaming, 16 swearing, physically threatening behavior and even physical assault, in public, in front of 17 witnesses. Several statements from athletes and coaches who have directly experienced 18 this behavior [were] provided [with the complaint]. 19 GROOM uses extremely offensive and abusive language toward his junior and high- performance athletes, e.g. Calling a 4x of junior girls “[C word]s”, an incident which was 20 witnessed by a coach from a neighboring club and her 8+ of junior girls. 21 GROOM engages in inappropriate touching and sexually suggestive conversations with his 22 athletes as a matter of course and as a means of establishing and maintaining control and 23 power, such as leaning his body in close to rowers, particularly young female rowers, 24 trapping them up against a wall or door and having a forearm on the wall above them. 25 26 COMPLAINT Page 8 of 48 27 28 GROOM recruits rowers from other clubs in part by offering their parents the possibility of 1 scholarships, college admissions and national team hopes. This is not abusive in and of 2 itself but given his abusive behavior and coaching methods, it is identified by Safe Sport as 3 a means of seducing athletes and their parents while protecting himself from and deflecting 4 criticism and concern by those parents and the rowers themselves. 5 GROOM treats certain athletes as “special,” openly stating that they are his favorites. [At 6 that time, he was] showing special attention to a junior girl at SRC, and has been rowing a 7 private double with her at a different boathouse and outside of normal SRC practice time. His attention toward her has caused alarm in parents and coaches who are aware of it. 8 Some parents and athletes have left SRC as a result of their concerns, but others stay and 9 do not say anything, or develop “coping mechanisms” to deal with the behavior for all of 10 the reasons identified in the Safe Sport training. Given the structure of SRC, which is a 11 private, for-profit LLC with no board of directors, there is no meaningful way to bring a 12 grievance to the club itself, and clearly no oversight of the head coach. 13 There does not appear to be any other means of seeking redress of this matter except through US Rowing. The purpose of bringing this grievance is to do whatever possible to 14 get this individual off the water; he has done far too much damage to athletes, to the 15 community and to the sport to allow him to remain part of competitive rowing. 16 17 34. During the course of interviewing athletes who had been subjected to harassing and abusive treatment by GROOM and their family members, Christopher learned that GROOM had a 18 pattern and practice of selecting certain young female rowers and “grooming” them for potential 19 future sexual attention and abuse. Among the grooming behaviors that GROOM reportedly 20 engaged in towards female rowers who he openly declared were his “favorites” were: 21 Rides alone with them in cars, drives them to and from practice, to and from regattas 22 Gives them keys to his apartment 23 Asks them to take care of his pets Gives them keys to his office 24 Gives them other special and inappropriate privileges at the boathouse, like driving a 25 26 COMPLAINT Page 9 of 48 27 28 Has blatantly inappropriate physical contact and lack of physical boundaries with them 1 Rows alone with them (clandestinely, at other boathouses) 2 Texts and calls them at all hours and about personal/sexual things 3 Stands too close or leans into them against a wall with an arm over their head when talking 4 Trains side by side with them for hours at a time 5 Gets close with their parents 6 Comments on their physical appearance, both negatively and positively, both alone and in front of their teammates 7 Makes weird remarks about his relationship with them to imply that they are dating and/or 8 others are jealous of her/them 9 Pays special attention to them in front of other rowers and neglects/ignores other rowers 10 Walks into the girls locker room at will to “talk” to someone or yell at the team while they 11 are changing clothes, to the point where some of them would change in the closet. 12 35. GROOM engaged in the above wrongful actions on top of the toxic environment he 13 creates, where his authority cannot be questioned and athletes’ physical and emotional boundaries 14 are broken down by daily abuse, reckless endangerment, and bullying, thereby making athletes 15 even more vulnerable to sexual exploitation. 36. Regarding GROOM’s offensive and dangerous actions towards the male high 16 school rower, Christopher confirmed in her complaint to U.S. Rowing that that athlete experienced 17 ongoing verbal, physical and emotional abuse by coach CONAL GROOM and witnessed the same 18 perpetrated on his teammates. 19 37. PLAINTIFF is informed and believes and thereon alleges that numerous athletes, 20 family members, and staff have reported to Pocock Rowing Center various inappropriate, abusive, 21 dangerous, and at times violent actions by GROOM towards male and female rowers that he 22 coached, including open and belligerent altercations between him and his athletes. 38. PLAINTIFF is informed and believes and thereon alleges that in one incident, four 23 female rowers who were training under GROOM at SRC left the club and went to Pocock to train 24 25 26 COMPLAINT Page 10 of 48 27 28 for a brief period prior to a key competition after GROOM reportedly engaged in an altercation 1 with them and kicked them out of SRC. 2 39. PLAINTIFF is informed and believes and thereon alleges that in another disturbing 3 incident in 2013, a Pocock staff member witnessed and reported an angry and denigrating outburst 4 by GROOM towards four female rowers he was coaching during a rowing practice session on 5 Portage Bay (Lake Union) in which GROOM yelled at them that they were “[C word]s,” shocking 6 and offending the Pocock staff member and the female athletes in her boat who witnessed GROOM’s outburst, and causing them great concern for the safety and well-being of the female 7 athletes under GROOM’s supervision. 8 40. Pocock subsequently sent a letter to U.S. Rowing to report and express his concerns 9 regarding the incident. The letter noted that GROOM had violated established coaching and 10 behavioral standards set by U.S. Rowing for working with youth athletes, and that the local 11 rowing community had been subjected to and/or was aware of various other instances of 12 inappropriate and dangerous conduct by GROOM that had occurred over a period of years, and that it would be unsafe and morally reprehensible to allow him to continue to coach athletes, 13 particularly young athletes, given the power, ability, and access he had to harm and abuse them. 14 41. Following submission of the 12/14 Complaint against GROOM with U.S. Rowing 15 by Pocock coach Margaret Christopher, CAROL NAGY began to send threatening emails to 16 Pocock Rowing demanding that the club fire Christopher. Shortly after Pocock informed NAGY 17 that it would not be silencing or terminating Christopher, NAGY abruptly entered the club’s 18 offices and again angrily demanded that a club official fire Christopher. Specifically, NAGY 19 slammed her hands down on the official’s desk and exhorted the official in a hostile manner, “you need to stop her from doing this” and “you need to fire Margaret.” NAGY then threatened the 20 official and Pocock by stating that Christopher’s complaint against GROOM was “ruining [her] 21 business” and that “this needs to stop or I will sue you.” 22 42. Notwithstanding the 12/14 Complaint, GROOM was allowed to continue coaching, 23 eventually closing and leaving SRC with NAGY and founding MISSION ROWING in Santa 24 Ynez, California in 2019. 25 26 COMPLAINT Page 11 of 48 27 28 43. PLAINTIFF, and on information and belief, other parties with knowledge of these 1 facts, are unaware of any actions by NAGY to address GROOM’s wrongful and dangerous actions 2 towards the athletes he coached, or to protect those athletes from further harm by GROOM. 3 Instead, NAGY routinely defended GROOM and his inappropriate behavior to those who 4 questioned or complained about GROOM, was complicit in his wrongful actions, and sanctioned 5 his wrongful actions by allowing them to continue unabated throughout the time that NAGY 6 worked with GROOM. 44. Given this history of inappropriate behavior by GROOM, and NAGY’s knowledge 7 of and failure to take any effective action to deter such wrongful behavior, and to instead support 8 and sanction GROOM’s actions, it is not surprising that, following the 12/14 Complaint, GROOM 9 had the opportunity and authority to harm vulnerable and impressionable young athletes like 10 PLAINTIFF. 11 GROOM First Noticed and Began To Engage in Predatory Grooming Behaviors Towards PLAINTIFF When She Showed Talent and Dedication to His SRC Rowing 12 Teams as an Eighth Grader 13 45. PLAINTIFF initially became involved with GROOM’s and NAGY’s Seattle-based 14 rowing club, SRC, when she joined the club’s after school youth program in 2015 as a fifth grader. 15 46. In late summer 2018, at the beginning of her eighth-grade school year, PLAINTIFF joined SRC’s juniors racing program, which was coached by CONAL GROOM and made up 16 largely of high school aged athletes. PLAINTIFF loved rowing and demonstrated intense focus 17 and significant aptitude for the sport. 18 47. By the middle of PLAINTIFF’s first academic year as a junior rower (Spring 19 2019), GROOM had noticed her, her dedication, and her talent, and moved her up from the novice 20 team to row with the SRC varsity team. 21 48. Around the same time, GROOM began to show special attention and display 22 favorable treatment towards PLAINTIFF, such as telling her what a talented athlete she was, allowing her to eat pie while her teammates worked to re-rig a boat, and giving her the nicest 23 single boat to row for time trials (which were held to determine which athletes would attend the 24 upcoming junior national competition). 25 26 COMPLAINT Page 12 of 48 27 28 49. Predatory “grooming” occurs when an individual (often with power and/or 1 authority over their victim) engages in a series of behaviors with the goal of engaging in sexual 2 misconduct. In situations of child sexual abuse, the abuser targets a minor and works to earn the 3 trust of the minor, the minor’s family, and the community. It can also be manipulative behavior 4 the abuser uses to prolong the abuse and make the minor fear reporting or be less likely to be 5 believed if they do report. See https://uscenterforsafesport.org/endabuseinsport_parents/ ; 6 https://uscenterforsafesport.org/wp-content/uploads/2020/05/Parent-Toolkit_Complete-1.pdf 50. According to the U.S. Center for SafeSport (“SafeSport”), inappropriate and 7 potentially dangerous grooming behaviors include: 8 Attempts to befriend the minor as a peer or “cool adult” 9 Giving the minor gifts and special attention 10 Talking to the minor about sexual experiences or desires 11 Being helpful and non-threatening to the minor’s family 12 Volunteering for situations that involve spending time alone with the minor 13 Using organizational status to have one-on-one interactions with the minor. (Id.) 14 51. In an effort to guard against and help protect vulnerable athletes from potentially 15 dangerous grooming behaviors, SafeSport provides training and guidelines for athletic 16 organizations to help them, their managers, coaches and staff, the athletes that train with them, and 17 their families to be able to identify, understand, and take steps to guard against such grooming. One of the key preventative measures an athletic organization should take, according to SafeSport, 18 is to prevent unsupervised, one-on-one conduct between a coach and their minor athlete. See 19 SafeSport Minor Athlete Abuse Prevention Policies (“MAAPP”), which limit one-on-one 20 adult/minor interactions and set standards for training and sport settings that prevent abuse and 21 misconduct: https://maapp.uscenterforsafesport.org/ ; See also 22 https://uscenterforsafesport.org/endabuseinsport_parents/; https://uscenterforsafesport.org/wp- 23 content/uploads/2020/05/Parent-Toolkit_Complete-1.pdf . 52. As PLAINTIFF, her family members and friends, and other MISSION, SRC, and 24 Pocock athletes and coaches will testify, and as evidenced by the thousands of text messages 25 26 COMPLAINT Page 13 of 48 27 28 exchanged between PLAINTIFF and GROOM during the two-year period leading up to the 1 8/13/21 Assault, GROOM engaged in all of the above predatory grooming behaviors towards 2 PLAINTIFF that SafeSport cautions against shortly after he began coaching PLAINTIFF at SRC, 3 and continuing throughout the time he coached her at MISSION ROWING. 4 53. In May 2019, GROOM invited PLAINTIFF to row for SRC at the U.S. Rowing 5 Youth National Championships scheduled to be held in Florida in Sarasota, Florida the following 6 month. 54. Shortly thereafter, GROOM and NAGY announced that they were closing SRC and 7 starting a new rowing club, MISSION ROWING, based in Santa Ynez, California. 8 55. After the announcement, and in conjunction with PLAINTIFF’s graduation from 9 middle school in May 2019, GROOM sent PLAINTIFF a predatory letter in which told her, “We 10 will miss you more than others,” commented “I love the passion and fire you Bring” and “I love 11 how much you care and how hard you take the losses and the failures,” and invited her to “free to 12 call/text/email … to vent or ask questions whenever you need or want.” He closed the letter by commenting in part, “It will be hard to leave you and for that I am very very sorry” and signed it, 13 “Love Always, Conal.” 14 56. Following the announcement of SRC’s closure and the opening of MISSION 15 ROWING, PLAINTIFF’s mother, PLAINTIFF’S mother, met with GROOM to discuss 16 PLAINTIFF’s rowing future. GROOM told PLAINTIFF’S mother that her daughter was talented 17 and could continue to train at Pocock, but commented that he was really “the best coach for her.” 18 57. In a subsequent conversation, GROOM and NAGY told PLAINTIFF’S mother that 19 PLAINTIFF could come to California to train with their new MISSION ROWING team during the summer and other school breaks. 20 58. In June 2019, just prior to SRC’s closure, PLAINTIFF and other selected SRC 21 rowers represented the club at the U.S. Rowing Youth National Championships in Sarasota, 22 Florida. On the first day of racing, GROOM made it clear that PLAINTIFF was one of his new 23 “favorite” athletes, introducing her to his friends and showing her off as the small but powerful 24 middle schooler he had brought to race. 25 26 COMPLAINT Page 14 of 48 27 28 59. During the summer of 2019, GROOM, NAGY, and NAGY’s husband, Ed Meyer, 1 moved to Santa Ynez to operate GROOM’s and NAGY’s new club, MISSION ROWING, and 2 started living together in a large rental house at on Tivola Street in Santa Ynez, California. 3 60. At least four former SRC rowers also moved to the Santa Ynez Valley area to train 4 with MISSION. Although PLAINTIFF rowed with College Club that summer and Pocock 5 through the fall, GROOM remained intensively involved in her training, provided her with daily 6 work out routines, and talked with her frequently by phone and FaceTime about her practices. 61. GROOM regularly asked PLAINTIFF to send screen shots and video footage of 7 her rowing on the Pocock club’s indoor rowing machine (known as an ergometer or “erg”) for him 8 to review, and spent hours analyzing her movements and “debriefing” with her. 9 62. In November 2019, GROOM and NAGY drove from Santa Ynez to San Diego to 10 watch and encourage PLAINTIFF as she competed as a member of the Pocock Rowing Center 11 team in the Fall Classic rowing competition held at MISSION Bay. GROOM also loaned her a 12 SpeedCoach GPS 2 performance monitor, helped her rig her boat, and got her “psyched up” for the race. PLAINTIFF finished second in both the single and the double races she competed in. 13 63. Two weeks later, PLAINTIFF and her family spent the Thanksgiving holiday in the 14 Santa Ynez Valley, where PLAINTIFF trained with GROOM and the other elite athletes. 15 GROOM again gave PLAINTIFF one of the nicest boats to row and showered her with attention, 16 both in front of other athletes, and during private one-on-one sessions he arranged with her (which 17 as noted above, are prohibited under SafeSport’s Minor Athlete Abuse Prevention Policies). 18 PLAINTIFF and her family were invited to Thanksgiving dinner at NAGY’s and GROOM’s 19 house. 64. During one of the training sessions that PLAINTIFF attended that week, GROOM 20 became angry and began yelling and screaming at her for failing to pick up an instruction quickly 21 enough. Understanding that her worst fear was being only an “average” rower, GROOM 22 screamed at PLAINTIFF that she would be “average forever.” PLAINTIFF captured GROOM’s 23 outburst on video on her cell phone. 24 25 26 COMPLAINT Page 15 of 48 27 28 65. Following their Thanksgiving training sessions in Santa Ynez, GROOM continued 1 to contact PLAINTIFF frequently about her training and various aspects of her personal life. 2 After PLAINTIFF Began Rowing With GROOM’s and NAGY’s New Santa Ynez- 3 Based Club, MISSION ROWING, in the Winter and Spring of 2020, GROOM Continued His Inappropriate Grooming Behaviors, and Began to Verbally and 4 Physically Abuse and Sexually Harass Her 5 66. In February 2020, PLAINTIFF had a week off from school for the President’s Day 6 holiday. Although her family had planned a trip to Arizona, PLAINTIFF was eager to return to 7 the Santa Ynez Valley to row with GROOM at MISSION. 8 67. Instead of spending her vacation with her family, PLAINTIFF flew to California and spent the week training with GROOM and staying at the rental home located at 3330 Tivola 9 Street, Santa Ynez, California that NAGY, her husband Meyer, and GROOM were living in. 10 PLAINTIFF stayed in GROOM’s bedroom while he slept in a tent outside. 11 68. GROOM continued to show favoritism towards PLAINTIFF by taking the best 12 boat he owned from an older athlete and giving it to PLAINTIFF to row during practices. He also 13 coached her one-on-one, attended a yoga class with her, took her to get a massage, and arranged to 14 spend time alone with her. 15 69. In the midst of one practice session during the week, GROOM suddenly became angry and belligerent with PLAINTIFF and began yelling at her in frustration, frightening her, 16 demeaning her, and pushing her to the verge of tears. 17 70. At the end of the week, PLAINTIFF met with GROOM to discuss her goals. Her 18 most significant goal was to gain an invitation U.S. Rowing Junior National Team Selection Camp 19 in the San Diego area—the required step to be able to compete for a spot on the junior national 20 team—for the upcoming summer. 21 71. In March 2020, the COVID-19 pandemic hit. The school in Seattle that PLAINTIFF was attending as a ninth grader went online, and Seattle-area rowing programs shut 22 down. PLAINTIFF continued to train on her own under GROOM’s supervision (via phone, 23 FaceTime, text, and other electronic communication), working out on the erg at home, lifting 24 weights, and cross training in accordance with a strenuous training plan that GROOM had written. 25 26 COMPLAINT Page 16 of 48 27 28 72. When PLAINTIFF failed to hit her goal split times on near impossible training 1 pieces, GROOM began to angrily and aggressively berate her for her failures, causing her to feel 2 dejected and humiliated, and shaking her confidence. Fearing abusive treatment, hostility, and 3 disapproval from GROOM, PLAINTIFF began to dread erging sessions and struggled to sit down 4 at the erg machine to pull a piece. 5 73. Around this same time, GROOM began to probe and intrude into PLAINTIFF’s 6 personal life, and openly exhibited anger, frustration, and jealousy when he found out that PLAINTIFF had become romantically involved with a young man in Seattle. When PLAINTIFF 7 informed GROOM that she had a boyfriend, he became enraged, screaming at her over the phone 8 for failing to tell him about the relationship previously and berating her that if they were going to 9 work together, she needed to “tell him everything” or else he could not coach her effectively. 10 74. As the COVID-19 lockdown continued, PLAINTIFF missed her regular rowing 11 team activities and the camaraderie of her team, and grew increasingly anxious and distressed as a 12 result of GROOM’s intensive training regimen and hostile and abusive treatment. PLAINTIFF began to experience regular panic attacks for the first time in her life, prompting her to seek 13 attention from a sports psychologist and begin taking medication to help control her episodes of 14 panic. 15 75. Aware that PLAINTIFF’s mental condition was obviously deteriorating, but 16 refusing to acknowledge that he was contributing to her emotional decline, GROOM contacted her 17 mother, PLAINTIFF’S mother, and suggested that PLAINTIFF would be better off moving to 18 Santa Ynez to train with him at MISSION ROWING. 19 76. A few months later, in response to GROOM’s “suggestion,” PLAINTIFF moved to Santa Ynez to train with him and other MISSION ROWING athletes for the summer, all under the 20 supervision of GROOM and his longtime friend and supporter, NAGY. For the first five weeks, 21 PLAINTIFF lived with her family in a house they had rented in the area. 22 77. When her family returned to Seattle in early July 2020, PLAINTIFF and a fellow 23 Seattle rower and friend stayed in Santa Ynez for another month to continue their training with 24 25 26 COMPLAINT Page 17 of 48 27 28 MISSION, and moved into the rental house that GROOM, NAGY, and Meyer were all living in in 1 the area. 2 78. By that time, GROOM had befriended PLAINTIFF and treated her like a peer or 3 “cool adult” by frequently communicating with her in one-on-one phone and FaceTime calls, 4 private text exchanges, and social media messages, and in person about her family, friends, 5 boyfriend, personal and dating life, sexual knowledge, and sexual experience, and by offering to 6 give or buy her and her minor friends alcohol. GROOM routinely referred to PLAINTIFF in private text messages as his “bf” [best friend] and by other flattering, intimate nicknames such as 7 “#1,” “B,” “Bud,” “Babe,” and “Stud.” The volume, frequency, and tenor of GROOM’s text 8 messages to this teenage female athlete, with whom he was prohibited under SafeSport guidelines 9 from having even one private, intimate communication with, and with whom he had thousands of 10 such exchanges, is deeply disturbing. 11 79. GROOM also frequently and flagrantly violated SafeSport’s prohibition against 12 unsupervised, one-on-one conduct between a coach and their minor athlete by going on long bike rides and rowing training sessions alone with PLAINTIFF, and by repeatedly inviting her to come 13 to his living quarters (on NAGY’s property) to visit him and his animals, and to cook, eat, watch 14 movies, and hang out away from any other people. 15 80. GROOM was aware of PLAINTIFF’s love for animals, especially baby animals, 16 and used the animals he was raising to entice her to spend even more time with him, repeatedly 17 encouraging her to come over to pet and hold his baby bunnies and baby chicks, help care for 18 them, and build and clean enclosures for them. GROOM also made several statements in text 19 messages telling PLAINTIFF that his house was her house, that she was welcome any time, and that he was always available to her and for her and for whatever she needed. 20 81. Throughout the summer of 2020, and for the following two years, Groom engaged 21 in a pattern of physical and emotional abuse toward, and exerted his physical and emotional power 22 and authority over, PLAINTIFF. 23 82. On many occasions Groom angrily yelled, cursed, screamed at and threatened 24 PLAINTIFF and other athletes in PLAINTIFF’s presence, causing PLAINTIFF to become upset, 25 26 COMPLAINT Page 18 of 48 27 28 ashamed, dejected, and desperate, to break down and cry, and to experience panic attacks and 1 various other anxiety- and stress-related symptoms for which she sought treatment. 2 83. GROOM intermittently yelled and cursed at PLAINTIFF and one of her female 3 teammates, who had also come down from Seattle to train with MISSION for the summer. 4 84. When PLAINTIFF was successful in beating one of her rival teammates, GROOM 5 would reward her with food, sweet treats, rowing attire, and, most importantly to her, his attention. 6 85. For PLAINTIFF’s 16th birthday in July 2020, GROOM prepared a special meal for her and gave her more than $800 in rowing “kit” (clothing). 7 86. GROOM frequently demonstrated emotional instability and mood swings, going 8 from being fun and playful with PLAINTIFF and showering her with favorable attention to 9 becoming argumentative and angry and bullying her. 10 87. One morning when PLAINTIFF and a female teammate were rowing in a double 11 boat that kept turning to port, GROOM quietly gave PLAINTIFF’S teammate an instruction that 12 she did not hear, then became furious and berated her for purportedly failing listen to him and demanded that the young women return to the dock. PLAINTIFF was so upset that she cried, 13 prompting GROOM to tell her later that she had not done anything wrong, and that he had reacted 14 in that manner to “teach [her female teammate] a lesson.” 15 88. Another day, PLAINTIFF was fretting over her performance during a training 16 exercise on the club’s the RP3 rowing machine. When PLAINTIFF told GROOM that she was 17 disappointed by her failure to beat her teammate on pieces that, unbeknownst to her, had been 18 adjusted for their weight, GROOM screamed at her for being “an idiot” and berated her for not 19 being aware of the weight adjustment. 89. GROOM also often drank alcohol excessively, exacerbating his erratic and volatile 20 behavior. At one point during the summer of 2020, PLAINTIFF told her mother that GROOM 21 had been arguing with everyone at dinner and that she thought alcohol was a factor. 22 90. When PLAINTIFF’S mother promptly called NAGY to discuss the situation, 23 NAGY told her that GROOM could be “moody sometimes” and that it was “usually a sign of 24 stress.” NAGY encouraged PLAINTIFF’S mother to call GROOM to “check in,” but did not 25 26 COMPLAINT Page 19 of 48 27 28 indicate that she herself would take any action to address PLAINTIFF’S mother’s and 1 PLAINTIFF’s concerns about GROOM’s behavior. 2 91. GROOM also repeatedly touched PLAINTIFF in offensive, unwelcome, and 3 inappropriate ways on numerous occasions prior to the 8/13/21 Assault, including frequent 4 unwanted touching of various parts of her body, backrubs, and full body hugs. 5 92. Groom exerted his power and authority over PLAINTIFF by demanding that she 6 and other athletes row in dangerous fog and/or wind conditions on Cachuma Lake, threatening their safety. Groom would angrily yell, scream, and threaten PLAINTIFF and other rowers not to 7 “f--- up his boats” or damage the equipment while doing so. 8 93. Groom further displayed his dominance and control over PLAINTIFF by engaging 9 in violent and threatening behavior toward PLAINTIFF on numerous occasions, such as when he 10 placed his hands around her throat in chokeholds, and when he grabbed a rowing machine handle 11 out of PLAINTIFF’s hands while she was training on the machine and threw it so hard against the 12 machine cage that it broke. 94. In August 2020, PLAINTIFF returned to her home in Seattle to begin her freshman 13 year of high school. Due to the ongoing COVID-19 pandemic, her classes were all online for the 14 entire school year. 15 95. PLAINTIFF rowed with the Masters team at a Seattle-based rowing club, and at 16 Pocock Rowing Club in the afternoons. GROOM continued to monitor her training remotely from 17 Santa Ynez and pushed her to do additional workouts when he believed she had not done enough 18 in a given day. 19 96. GROOM also sent PLAINTIFF inappropriate SnapChat and text messages of an intimate and/or sexual nature from the Fall of 2020 up until the 8/13/21 Assault. The texts can 20 generally be categorized as: 21 Establishing a secret relationship with her; 22 Making her feel special and fostering an intimate bond as confidantes while talking about 23 “missing” and “loving” her and assuring her that he will protect her; 24 Framing parents and other adults as adversaries and making himself a hero to her; 25 26 COMPLAINT Page 20 of 48 27 28 Desensitizing her