"USC and Kiffin maliciously intended to -- and did -- induce Pola to breach the Pola contract," the lawsuit charges. "USC and Kiffin engaged in improper means in their procurement of the breach and were not legally justified in their actions. Kiffin and USC's actions, through him, 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 ..."
Pola informed coach Jeff Fisher of his decision to leave the Titans on Saturday. Pola played fullback at USC from 1982 to 1985 and was the Trojans' running backs and special teams coach from 2000 to 2003.
Fisher, also a former USC player, told The Tennessean on Saturday that Kiffin never contacted him during the hiring process.
"I am very disappointed in Lane Kiffin's approach to this," Fisher said. "Typically speaking when coaches are interested in hiring or discussing potential employment from coaches on respective staffs there is a courtesy call made from the head coach or athletic director indicating there is an interest in talking to the assistant.
"So I am very disappointed in the lack of professionalism on behalf of Lane, to call me and leave me a voice mail after Kennedy had informed me he had taken the job. It is just a lack of professionalism."
The lawsuit claims that "as a result of USC and Kiffin's tortuous conduct, Tennessee (Titans) football has been damaged in an amount proven at trial." Tennessee Football Inc. is asking for a jury trial and punitive damages and attorneys fees.
The lawsuit is particularly harsh on Kiffin, who coached the Oakland Raiders in 2007 and 2008, for what it calls intentional actions. Kiffin said he first spoke to Pola on Friday, then called Fisher on Saturday after Pola called him back, apparently to accept the job.
Kiffin acknowledged in a statement Saturday that the timing wasn't perfect.
"I have spoken with Coach Fisher and he now has an accurate understanding of the timeline of events," Kiffin said. "We realize the timing of this isn't perfect for all parties, but this is a great opportunity and promotion for Kennedy."
The lawsuit doesn't hold back in criticizing Kiffin for "furtherance of a culture of violation and avoidance of respect for the sanctity of contract, which Kiffin similarly practices ..." in inducing Pola to breach his contract.
The lawsuit notes that Kiffin "abruptly departed" his coaching job at the University of Tennessee in January after just 14 months, angering Volunteers fans. Kiffin also lured four other Tennessee assistants to join him at USC, and the lawsuit also notes how the coach tried to hire Eric Bienemy away from the Minnesota Vikings, forcing that team to redo a contract to keep him.
This isn't the first time that Kiffin has been accused of "inducing" an NFL assistant coach to breach his contract. When Kiffin became Tennessee's coach in 2009, he drew the Raiders' ire for hiring assistant offensive line coach James Cregg for the same position with the Volunteers, found in a letter sent to the university by the team and obtained by The San Francisco Chronicle. USC announced this January that Cregg was leaving the Vols to join Kiffin's Trojans staff as an assistant.
Pola's contract ran at least to Feb. 14, 2011, with the NFL in the final year of its current labor agreement with the players.
The lawsuit notes that written permission from the president and general counsel was needed because verbal "consent is inadequate." The lawsuit also notes that USC and Kiffin, through Pola, knew about his contract requirements.
"Pola was not given express written consent by Tennessee Football or the Commissioner of the NFL to entertain employment with any other entity," the lawsuit argues.
The move left the Titans without a running backs coach one week before training camp opens, which the lawsuit argues disrupts planning, causes "potential loss of confidence by players" and the loss of salary and benefits already paid to Pola along with "future damage."
The Associated Press contributed to this report.