Potential claims included, but were not limited to "Violations of Title IX," "Negligent failure to warn, train or educate," "Negligent supervision," "Constructive Fraud" and "Negligent Hiring and Retention," among several others.

The document reads that the claims arose from the sexual assault and battery, molestation and harassment of the clients in addition to Nassar's "digital penetration" of the clients from 1996 to 2015.

The Indianapolis Star reported on Sept. 12 that Nassar had been accused of sexual abuse by two former gymnasts, the document cites the knowledge of the clients of Nassar's conduct.

MSU spokesperson Jason Cody responded to the intent to file with this statement:

“While we have not been served with any lawsuit and therefore are unable to comment on any potential litigation, I can tell you we take allegations of sexual abuse very seriously. Our police, the lead investigative agency in the Nassar case, are devoting significant resources to the criminal investigation against him and are vigorously reviewing all complaints and working through them with the state Attorney General’s office. After taking a report of alleged sexual assault against Nassar on Aug. 29, MSUPD detectives immediately began an investigation and notified our administration. Nassar was immediately reassigned from all of his clinical duties. The university fired Nassar on Sept. 20. All of the investigations are being handled by MSUPD’s Special Victims Unit with more than a dozen investigators assigned to the cases. We will continue to work with the Attorney General and other law enforcement partners as the criminal investigation moves forward."

Notice of intent to file claim by The State News on Scribd