"Paterno, Curley and McQueary were obligated to report the 2001 Sandusky incident to the University Police Department for inclusion in Clery Act statistics and for determining whether a timely warning should be issued to the University community. No record exists of such a report. While Schultz and Spanier were arguably not Campus Security Authorities under the Clery Act, given the leadership positions they held within the University, they should have ensured that the University was compliant with the Clery Act with regard to this incident. " The Clery Act requires the school to collect crime statistics on university property and report crime to police.

Timeline:

May 1998

"Victim 6's mother reports to the University Police Department that Sandusky showered with her 11-year-old son in the Lasch Building on Penn State campus. The police promptly begin an investigation.

"Schultz is immediately informed of the investigation and notifies Spanier and Curley. Schultz's confidential May 4, 1998 notes about Sandusky state: 'Behavior -- at best inappropriate @ worst sexual improprieties' and 'At min -- Poor Judgment.' Schultz also notes: 'Is this opening of pandora's box?' and 'Other children?' "

June 1998

Schultz e-mails Spanier and Curley: "I think the matter has been appropriately investigated and I hope it is now behind us [emphasis added]."

Fall 2000:

"... A University janitor observed Sandusky sexually assault a young boy in the East Area Locker Building and advised co-workers of what he saw. Also that evening, another janitor saw two pairs of feet in the same shower, and then saw Sandusky and a young boy leaving the locker room holding hands. Fearing that they would be fired for disclosing what they saw, neither janitor reported the incidents to University officials, law enforcement or child protection authorities."

May to August 1999

"A retirement agreement with Sandusky is reached in June 1999, including an unusual lump sum payment of $168,000, an agreement for the University to "work collaboratively" with Sandusky on Second Mile and other community activities, and free lifetime use of East Area Locker Room facilities.

"As the retirement package is being finalized, Curley requests the emergency re-hire of Sandusky for the 1999 football season, which is approved.

"In August 1999, Sandusky is granted 'emeritus' rank, which carries several privileges, including access to University recreational facilities. Documents show the unusual request for emeritus rank originated from Schultz, was approved by Spanier, and granted by the Provost, who expressed some uneasiness about the decision given Sandusky's low academic rank and the precedent that would be set."