Kiffin and USC's actions involving Tennessee Football were intentional, without legal justification, and were part of a course and pattern of conduct fostered by Kiffin and USC to use improper methods and means to the direct harm and damage of parties to contracts, to interfere with existing contracts and induce the breach thereof, including the Pola Contract: For instance, in December 2008, Kiffin accepted the contractual position of head football coach at the University of Tennessee. Without warning, in January 2010, Kiffin abruptly departed after one season, leaving the University of Tennessee without an experienced head football coach, to accept the head coach position he currently holds at USC. Shortly thereafter, Kiffin and USC persuaded four more University of Tennessee coaches - Monte Kiffin, Ed Orgeron, James Cregg and Willie Mack Garza - to leave the University of Tennessee to assume employment in coaching positions with USC. Upon information and belief, USC and Kiffin also attempted to hire for USC a running backs coach, Eric Bienemy, who was under contract at the time with the National Football League team known as the Minnesota Vikings. USC and Kiffin were unsuccessful in persuading Bienemy to end his relationship with Minnesota, but upon information and belief, Minnesota was forced to renegotiate Bienemy's salary to its detriment due to Kiffin and USC's acts of interference.I offer no opinion upon the legal merits, vel non, of the lawsuit against Lane Kiffin which was initiated by this complaint (.pdf), but I have to say that you reap what you sow. Go 'Dawgs!