Exhibit “1”

Exhibit “1”
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GENERAL OBJECTIONS

These General Objections are incorporated into the responses below.

1. Plaintiffs object to each request to the extent it seeks information that is not relevant

to the subject matter of this action or reasonably calculated to lead to the discovery of admissible

evidence or, if relevant, so remote therefrom as to make its disclosure of little or no practical

benefits to Defendant while imposing an unwarranted burden and expense on Plaintiffs in

ascertaining and disclosing such information.
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2. Plaintiffs object to each request to the extent that it is not limited as to time or scope,

and as a result, seeks discovery of information that is not reasonably calculated to lead to the

discovery of admissible evidence or is unduly burdensome.

3. Plaintiffs object to each Interrogatory to the extent it seeks information not within

Plaintiff personal knowledge.

4. Plaintiffs object to each Interrogatory to the extent that it seeks to impose on

Plaintiffs obligations different form, or greater than, those required by the Federal Rules of

Evidence, applicable Court rules, or order of the Court.

5. Plaintiffs object to each Interrogatory on the grounds, and to the extent that, it seeks

to impose on Plaintiffs any obligation greater than those specified by any applicable law.

6. Plaintiffs object to each Interrogatory to the extent that it seeks information that is

privileged or protected by the attorney-client privilege, the attorney work-product doctrine, or any

other constitutional, statutory, common-law, or applicable privilege(s), right of privacy, or

Plaintiffs hereby assert such privileges. Any

inadvertent disclosure of any Privileged Information shall not be deemed to constitute a waiver of

any such privileges or doctrines.

7. Plaintiffs object to each Interrogatory to the extent that it seeks expert opinion.

8. Plaintiffs object to each Interrogatory that is vague and ambiguous, unintelligible,

overbroad, or harassing.

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9. Plaintiffs object to each Interrogatory to the extent that it seeks information

protected or prohibited from disclosure under applicable law, including, but not limited to, the

right of privacy, as well as any other confidentiality rights possessed by third parties.

10. Plaintiffs object to each Interrogatory to the extent that it is philosophical,

hypothetical, or subjective.

11. Plaintiffs adopt the definitions used in each Interrogatory solely for the purposes of

responding to each request, and not for any other purpose.

12. Plaintiffs object to the disclosure of any information falling within any of the

foregoing General Objections or to the specific objections as set forth below, and in the event any

information falling within one or more of such objections is disclosed in any of the following

responses to any request, such disclosure is inadvertent and shall not constitute a waiver.

13. If any objection or qualification set forth in the preceding paragraphs above is not

restated under the specific response to a request or is restated in some but not all such responses,

this should not be construed as a waiver of any of the objections or qualifications not restated

below.

14. In addition to, and without waiving any of the foregoing General Objections, each

of which applies to each and every one of the individual responses set forth below and is

incorporated by reference therein, Plaintiffs respond as follows:
1. Jenny Conviser, Psy.D.

2. Erin Andris

3. Stephanie Blagaich

4. Allie Braden

5. Dylan Christensen

6. Haydn Christensen

7. Lynsey Ciezki

8. Corporate Representative Pursuant to FRCP 30(b)(6) - DePaul University

9. Jessica Cothern

10. Custodian of Records- DePaul University

11. Krista Dalgarn

12. Janine Douglas

13. A. Gabriel Esteban

14. Tom Fessel

15. Madison Fisher

16. Micah Fitzgerald

17. Celeste Franco

18. Kennedy Garcia

19. Kali Gardner

20. Mark Gant

21. Morgan Greenwood

22. Ana Greik

23. Sarah Halvorson

24. Skylor Hilger

25. Kelly Hogan

26. Jill Hollembeak

27. Cara Jimenez

28. Sabrina Kuchta

29. Kayla Landwehrmier

30. Eugene Lenti

31. Kandace Lenti

32. Michael Lenti

33. Megan Leyva

34. Candace Neid

35. Kate O'Brien
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36. Nicole Pihl

37. Lindsay Platt

38. Jean Lenti Ponsetto

39. Elyse Rocco

40. Alysia Rodriguez

41. Angela Scalzitti

42. Kathryn Statz

43. Ashley Sunshine

44. Karen Tamburo

45. Dale Tobias

46. Sue Walsh

47. Missy Zoch
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1 their redline edits to the proposed

Confidentiality Order on October 5, 2023. To date, the opposition has not finalized the proposed

Order nor submitted it to the Mag

counsel does not finalize it with the undersigned, we will send a proposed order to the magistrate

requesting that it be entered.
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1.

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4.

5.
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An athlete reported that she was having sex with the track & field coach in return

for training and competition opportunities and to insure not being bullied, teased,

or ridiculed in front of others (2017). Plaintiffs reported the issue and were told by

Kathryn Statz that the Coach was being transferred.

Plaintiffs reported these issues to Kathryn Statz, Sue Walsh and Jill Hollembeak

and are not aware of any action taken in response.

Athletes reported to Dr. Conviser that a bus full of track & field team members

traveling for competition in Long Beach, California overdosed on edibles and were

taken to an ER. Plaintiffs reported these issues to Kathryn Statz and Sue Walsh

and Plaintiffs are not aware of any action taken in response.

instructed to inflict pain

on each other as directed by their sport Psychologist Joel H. Fish, Ph.D. /

www.psychologyofsport.com, who is not a licensed psychologist. Plaintiffs

reported these issues to Sue Walsh and Kathryn Statz. Plaintiffs are not aware of

any action taken in response.

Members of the reported they were videotaped without

prior knowledge or permission on 10/16/2015. Plaintiffs reported these issues to

Jean Lenti Ponsetto. Plaintiffs are not aware of any action taken in response.
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Thursday night and continuing through Sunday. Plaintiffs reported these issues to

the Volleyball Coach and Kathryn Statz. Plaintiffs are not aware of any action

taken in response.

reported drinking and sex were available during

recruiting events. Plaintiffs reported these issues to the Soccer Coach and Sue

Walsh. Plaintiffs are not aware of any action taken in response.

Softball players reported being hit in the shoulders or stomach all the time (Spring,

2018). Plaintiffs reported these issues to Sue Walsh and Jill Hollembeak. Plaintiffs

are not aware of any action taken in response.

Plaintiffs observed that post injury, athletes may suffer lower mood, higher anxiety

and may have greater mental health risk. This was reported to Sue Walsh, Jill

Hollembeak, and Jean Lenti Ponsetto in 2017, and additional support for injured

athletes was requested. No group support was provided by DePaul.

Plaintiffs observed that the athletes had difficulty locating or accessing Mental

Health Emergency Contact Information such as suicide risk, poison control,

overdose, etc., when needed. Plaintiffs requested that information be displayed

prominently in locker rooms, training facilities, and other athletic facilities to

improve access. These requests were made to Kathryn Statz, Sue Walsh, and Jean

Lenti Ponsetto. Plaintiffs were told by Jean Lenti Ponsetto that nothing could be

posted on walls and no further action was taken.

Some athletes reported to Plaintiffs that they were excluded from some events if

they chose to abstain from drinking alcohol. Plaintiffs observed that these athletes

needed additional support and such was requested to Sue Walsh, Jill Hollembeak,

J. Lenti Ponsetto and Kathryn Statz. No support for this group was provided by

DePaul.

Plaintiffs observed that the international athletes needed support for lower mood,

more isolation & higher anxiety and greater mental health risk. These issues were

reported, and additional support requested from Kathryn Statz and Jean Lenti

Ponsetto. No group support was provided.

A member of the softball team reported high stress, high anxiety, dysphoric mood,

suicide risk and self-injury risk post sexual assault. This was reported to Sue Walsh

but it is unknown if there was any response or support provided.

Members of the golf team reported the golf coach was late to practice and

competition or was drunk during events. This was reported to Jean Lenti Ponsetto

and Sue Walsh during the Spring/March-April 2017, but no action was taken.
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ZUMPANO PATRICIOS POPOK &

HELSTEN, PLLC

Michael S. Popok

(Admitted pro hac vice)

New York Bar No. 2475226

134 East 38th Street

New York, New York 10016

212-542-2564

MPopok@zplaw.com

Amanda J. Brookhyser

(Admitted pro hac vice)

Nevada Bar No. 11526

1210 South Valley View Blvd., Suite 215

Las Vegas, Nevada 89102

702-583-3326

ABrookhyser@zplaw.com

Art Bresnahan, Esq.

ZUMPANO, PATRICIOS &

BRESNAHAN, LLC

Law Firm No. 13698

829 N. Milwaukee Avenue

Chicago, IL 60642

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