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Complete headline links to our Shoulberg series are at


by Irvin Muchnick


USA Swimming claimed “there is no investigation” of Dick Shoulberg, despite the known existence of a detailed complaint about Shoulberg by the mother of the “John Doe” teen swimmer. The complaint included language formally requesting a probe by the organization of numerous allegations of direct and indirect abuse on the part of the former coach at Germantown Academy, which became public last month in a civil lawsuit.

Some swimming insiders and legal experts had expressed astonishment at the possibility that the filing of the highly publicized John Doe litigation had not itself automatically triggered an internal probe by USA Swimming. But regardless, the John Doe family’s attorney, Brian D. Kent, in response to an inquiry by Concussion Inc., did confirm that a complaint had been filed with USA Swimming, as well.

In a one-sentence response to my query — also copied to to executive director Chuck Wielgus and safe sport director Susan Woessner — USA Swimming’s director of communications and PR, Scott Leightman, said that coverage of the subject should “include that there is no such investigation.” Leightman did not respond to a first request for clarification. His email marked the first response in nearly four years by USA Swimming to any inquiry from us.

Plaintiff attorney Kent then forwarded to us a March 10 email from John Doe’s mother to Liz Hoendervoogt, assistant to Woessner. The mother wrote in part, “I am requesting an investigation be started regarding the actions of coaches Richard Shoulberg and Chris Lear.”

The full text of the email (with the sender’s name and with both sender’s and recipient’s emails removed) is below.

Confronted with the email, Leightman unsuccessfully tried to walk back USA Swimming’s earlier clear lie. “Specifics of allegations are, and have always been, confidential,” he emailed.

Leightman did not respond to a follow-up pointing out that an explanation of a confidentiality policy is not the same as a flat statement that there is not an investigation. Leightman also never maintained that the John Doe mother’s email would not constitute a complaint launching an investigation. Nor did the USA Swimming spokesman claim that safe sport assistant Hoendervoogt did not receive the email.

Concussion Inc. already has reported a number of allegations of misconduct by Shoulberg that are not in the lawsuit proper. At this point we don’t know if there would have been still additional details in a conversation with Hoendervoogt that the John Doe mother proposed “once you have received this document.”


From: xxxxx

Date: March 10, 2016 at 5:40:23 PM CST

To: Elizabeth Hoendervoogt

Cc: Brian D. Kent

Subject: Formal Complaint


Hi – Thanks for speaking with me yesterday. I have attached a copy of the formal complaint that was filed in Philadelphia County Court of Common Pleas. I am requesting an investigation be started regarding the actions of coaches Richard Shoulberg and Chris Lear.

This document has specific incidents regarding abuse that was suffered by my son. There is additional information not listed in this complaint in regards to their actions that we can discuss once you have reviewed this document.

Chris Lear is now been hired at Episcopal Academy Aquatic Club.

Richard Shoulberg is now on staff at Plymouth White marsh Aquatic Club as well as on staff at Greater Plymouth Rec Center.

Neither coach is with Germantown Academy Aquatic Club any longer.

Our attorney is Brian Kent who is listed on the first page on the complaint along with his contact information. I also have copied Brian on this email so you will have his email address.

I can also be reached via email or at xxxxx.

Thank you very much for your assistance.


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Concussion Inc. - Author Irvin Muchnick