Unsettling Colts Behavior Released In Court Docs

When it was initially filed in federal court last year, the racial/ethnic orgin discrimination lawsuit brought by ex-Indianapolis Colts cheerleader Malori Wampler against the NFL franchise seemed dubious.

Kaley Collier Photos Didnt Bother Theresa Pottraz As Much As Malori Wampler Body Paint Photos

(’Midwest Moral Standards’ Apply To Indonesian Wampler, Not Caucasian Kaley?)

Then Colts Cheerleading Coordinator Theresa Pottratz participated in a sworn deposition last month.

While under oath, Pottraz volunteered on Feb. 16, 2012, that “there is a certain moral standard we (Colts) have.

In response to Pottraz’s statement, Wampler’s attorney then asked the Colts Cheerleading Coordinator to, “describe your moral standard.”

In response, Pottraz said, “Our cheerleaders we go for the girl next door image because that’s what our Midwest fans like.”

Eight months after the Colts fired Wampler for not living up to the “moral standards” of the “girl next door image”  that their “Midwest fans like”, BustedCoverage.com posted a series of photos of a different, current Colts cheerleader in what appeared to be varying states of profound inebriation.

Kaley Collier Photos

(Current Cheerleader ‘Kaley Collier’ & ‘Kaley C.’ Now ‘Erin C.’ On Colts Site)

After BustedCoverage.com’s “Jay Kool” noted that the Colts had previously fired Wampler for appearing in “risque photos“, the site’s writer posted the following description of the images of the current Colts cheerleader:

Please, Colts front office, just keep this chick around. Don’t let her tongue working on a champagne bottle scare you. And don’t be scared of the six guys on top of her – probably gay. Most of all, don’t be offended by fake licking fake boobs. It’s all good. Kaley is what’s right with NFL cheerleading. For now.

The Colts cheerleader in the photos was referred to by BustedCoverage.com, and later by Indianapolis radio station X103’s website, as “Kaley Collier.

A month before the BustedCoverage.com photo post, WANE-TV in Fort Wayne, Indiana, reported:

A Decatur woman will soon inspire the spirit of hundreds of thousands of Indianapolis Colts fans.

Kaley C. is one of the newest members of the Colts Cheerleaders.

She stopped by First News Sunday to talk about her past experiences, the process of trying out for the Colts Cheerleading Squad and what she is looking forward to this football season.

The site also posted a video interview of “Kaley C.“, who appeared to be the same woman in the photos posted by BustedCoverage.com and Indianapolis radio station website X103.com.

The Colts official website does not list a “Kaley C.” on its current roster of cheerleaders, but the site does include at least one photo labeled “Kaley” on the Colts.com server. The image was part of a collection of photos featuring Colts cheerleaders at the squad’s most recent swimsuit calendar shoot - and attributed to a Colts cheerleader currently listed on the team’s website as “Erin C.

Obviously “Erin C.” is the same current Colts cheerleader identified as “Kaley Collier” in the extremely embarrassing photos on an Indianapolis radio station website and the highly-trafficked blog BustedCoverage.com. And the same current Colts cheerleader referred to as “Kaley C.” in an interview with Fort Wayne television station WANE last June.

Kaley Collier Photos Didnt Bother Theresa Pottraz As Much As Malori Wampler Body Paint Photos

(Colts: Moral Conduct Clause It Used To Fire Wampler “Speaks for itself”)

Why would Kaley Collier identify herself to her hometown TV news station as “Kaley C.” and the Colts label one of her photos on its official website as “Kaley” considering she’s currently identified as “Erin C.” on the same Colts website?

Might the now-nearly 4,300 Google results for “Kaley Collier”, most of which are related to the photos of her on BustedCoverage.com, have something to do with it?

Unlike Wampler, Collier’s current employ with the Colts, which was confirmed by Pottraz during her deposition last month, is a mystery in lieu of the contract the Colts cited in firing Wampler. A contract that includes the following excerpt from a section called “Special Cheerleader Covenants.”:

A) Cheerleader agrees not to commit any act that will or may create notoriety (including posing nude or semi-nude in or for any media or publication whatsoever), bring cheerleader into public disrepute and/or reflect adversely on club or its sponsors. Cheerleader understands that she will serve as a public representative of the club from time to time and that it is important as part of this employment relationship that she be viewed in a positive manner. Cheerleader agrees to behave in accordance with socially acceptable mores and conventions.

As it pertained to Wampler’s termination, the Colts noted in federal court that the above clause “speaks for itself.” (PDF - #23)

Colts cheerleaders are also legally bound to the following clause in their official team-only “rules and regulations“:

All Squad members must maintain themselves in a professional manner on all online forums.  including but not limited to Facebook, Myspace, Twitter, LinkedIn and public online photo sharing (sites.)

Apparently Collier missed the part about maintaining herself in a professional manner on Twitter if this past Tweet from a Twitter account attributed to “Kaley Collier” is any indication.

Though in fairness the Tweet from “KaleyCheer” - “i have no idea how to work this sh–” - happened before Collier was hired as “Erin C.” by the Colts.

But so did the photos Wampler was fired for by the Colts.

So why does Collier have a job when Wampler doesn’t?

Very good question.

The Colts have also never actually established any manner of proof that the Wampler photos contained in the complaint letter to the club were ever uploaded to the internet before Wampler was fired. Or that the photos, as the complaint letter to the team alleged, were available for purchase on Playboy.com. (Perhaps that’s why the Colts allowed Wampler to perform the Sunday after the team received the complaint letter about her without telling the Indonesian female she would be fired the next day?)

Instead, the body paint photos of Wampler only gained widespread distribution on the web after the Colts fired her for, again, photos that the club hasn’t proven were viewed by anyone other than a photographer and the person who sent the complaint letter to the Colts. (Which for all we know could be the same person.)

Colts Nude Playboy Cheerleader Photos Letter That Got Malori Wampler Fired

(How many NFL fans call cheerleaders “ambassadors”?)

There’s also no dispute that Wampler took the photos before she was hired by the Colts and her name nor the Colts themselves were ever associated with the photos cited as the reason for her termination.

One cannot say the same for Collier.

The entire premise of the highly-trafficked sports website and Indianapolis radio station website posting several wildly unflattering photos of Collier, along with thousands of other web locales, was that she was a current Colts cheerleader.

Meanwhile the photos that got Wampler fired showed her covered in body paint similar to a 2005 Sports Illustrated nude body paint model who was covered only by an image of the jersey of an NFL franchise, the Miami Dolphins. (Which required approval by the NFL team in advance.)

Malori Wampler Body Paint Photos No Different Than Sports Illustrated Model In Dolphins Jersey Body Paint

Though Wampler and Collier do have two things in common: They weren’t paid for appearing in the photos and neither knew the images in question would ever be disseminated to millions of viewers.

Of course in the latter case the previously, completely unaware public has only the Colts to thank for the now-gone-viral Wampler body paint photos.

Nice to know the Colts aren’t below calling attention to photos of an attractive Indonesian female even if she isn’t, as Colts Cheerleading Coordinator and moral standard-bearer Theresa Pottraz reminded us last February, “the girl next door image that our Midwest fans like.”

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Letter, Nude Pics That Got NFL Cheerleader Fired

Last year former Indianapolis Colts cheerleader Malori Wampler filed a lawsuit in an Indiana Federal Court against the team contesting her November 15, 2010, termination by the NFL club. Wampler was fired after Colts officials received a letter that included photos of Wampler - covered only in body paint - taken at two Playboy promotional events.

Colts Nude Playboy Cheerleader Photos

(More body paint photos of Wampler

Below is an image of a copy of the unsigned letter and the photos that were included in the anonymous communication to the team. Read more…

Colts.com: Teeny Bikini Videos Of Ex-Cheerleader

A week ago I reported on the wrongful termination lawsuit of former Colts cheerleader Malori Wampler against the NFL team.

(Video is NSFW)

Last November, the Colts claimed they fired Wampler because the club was sent photos by a fan of her wearing only body paint at a Playboy promotional event in 2010.

The efficacy of Wampler’s ouster though might be a difficult sell for the NFL club to a U.S. District Court judge, considering Wampler told the team of such promotional activities before she was hired.

Six months after she was fired, Wampler is currently featured wearing revealing bikinis in multiple videos still posted on Colts.com.

Follow Brooks on Twitter or join him on Facebook for real-time updates.

Body Paint Photo Of Cheerleader Fired By Colts

Last Thursday former Indianapolis Colts cheerleader Malori Wampler filed a lawsuit against the team contesting her November 15, 2010, termination by club.

Malori Wampler Nude Photo

(Click-through photo is not-safe-for-work. Obviously.)

Wampler was fired after a Colts fan forwarded the club photos of her wearing only body paint at a 2010 Playboy Magazine promotional event.

According to the lawsuit, before Wampler took a job with the team she notified the Colts of her previous employment with Playboy - and the nature of that employment. The complaint also states that after Colts officials were informed of that fact, they determined that Wampler’s past employment by Playboy “was not an issue.

But rather than merely contest the veracity of the team’s decision to fire her over the photos because it allegedly violated club policy, in the U.S. District Court filing Wampler’s attorney Kimberly D. Jeselskis also claimed, “The Colts terminated Wampler because of her sex” and “the Colts terminated Wampler because of her race and national origin.

More from Wampler attorney Jeselskis in the U.S. District Court filing:

  • Wampler met the Colts legitimate performance expectations.
  • Wampler was treated differently than other “similarly situated” male and female employees.
  • As a result of the Colts discriminatory acts, Wampler has suffered and will continue to suffer monetary damages and damages for mental anguish and humiliation unless and until the Court grants relief.
  • The Colts acted with malice or reckless indifference to Wampler’s civil rights thereby entitling her to punitive damages. Wampler is entitled to recover reasonable attorneys’ fees and costs incurred in this action.

Wampler claimed sexual discrimination in the lawsuit primarily because Colts players were not dismissed from the club despite engaging in off-field behavior that was allegedly much worse than what the Colts cited in firing her.

Wampler claimed racial discrimination after citing in the lawsuit instances where caucasian cheerleaders were not fired despite, again, engaging in off-field behavior that was worse than why she was apparently let go by the team. (Wampler is Indonesian.)

So what exactly does Wampler want from the Colts? From her attorney’s court complaint: Read more…