“WITH REGARD TO OUR CLIENT, COACH PAT FITZGERALD, IT IS IMPORTANT TO NOTE THAT THIS COMPLAINT (AND, WE ASSUME, THE 30 OTHERS THAT PLAINTIFFS' LAWYERS SAY THEY
WILL FILE) DOES NOT NAME OUR CLIENT AS A DEFENDANT. IN ADDITION, WHILE
THE COMPLAINT MAKES DETAILED, FACTUAL ALLEGATIONS ABOUT STUDENT ATHLETES' BEHAVIOR, IT FAILS TO SHOW THAT OUR CLIENT, COACH FITZGERALD, HAD ACTUAL, CONTEMPORANEOUS KNOWLEDGE OF THE BEHAVIORS DESCRIBED IN THE COMPLAINT. RATHER, IT ASSERTS FACTS THAT LEAD PLAINTIFFS' LAWYERS TO MERELY ASSUME AND INSINUATE THAT OUR CLIENT SOMEHOW MUST HAVE KNOWN THAT SUCH BEHAVIOR WAS OCCURRING. ASSUMPTIONS AND
INSINUATIONS ARE NOT LEGAL ARGUMENTS, HOWEVER.”