B. The CMT’S Acts in Furtherance of the Conspiracy
414. On or before March 25, 2006, Defendant Steel directed Defendant Brodhead to create a Crisis Management Team (“CMT”) to manage the University’s actions relating to the investigation of Mangum’s claims. The original participants in the CMT were Defendants Steel, Brodhead, Lange, Trask, Burness, and Moneta. Defendant Victor J. Dzau (Chancellor for Health Affairs, and President and CEO of Duke University Health Systems, Inc.) was added to the CMT shortly after it became clear that DUHS and Tara Levicy were critical to the State’s case. Defendant Allison Halton (the University’s Secretary) was also added to the CMT following its first meeting on March 25, 2006.
415. Both Defendants Trask and Burness had personal knowledge of the Gottlieb Dossier and the fact that Gottlieb had been removed from the patrol beat as a result of his misconduct in dealings with Duke students. Upon information and belief, Defendant Steel and CMT Defendants were all aware of these facts on or before March 25, 2006.