NOTICE OF ALLEGATIONS

to the

Chancellor of University of Tennessee, Knoxville

1. [NCAA Bylaws 13.1.3.1, 13.1.3.1.3 and 13.1.3.1.7]

It was reported that between August 1, 2007, and July 29,2009, head men's basketball coach Bruce Pearl, associate head men's basketball coach Tony Jones, and assistant men's basketball coach Steve Forbes placed 96 impermissible telephone recruiting calls to 12 men's basketball prospective student-athletes or their family members. 1 Specifically, Pearl, Jones and Forbes made the following impermissible telephone calls after they had already made a permissible telephone call to that individual.

a.

b.

I In men's basketball, an institution is permitted to make one telephone call per month to an individual (or the individual's relatives or legal guardians) on or after June 15 of the individual's sophomore year in high school through July 31 of the individual's junior year in high school. Thereafter, outside a contact period, an institution is permitted to make two telephone calls per week to an individual (or the individual's relatives or legal guardians) beginning August 1 prior to the individual's senior year in high school. Outside of a contact period, an institution is permitted to make one telephone call per week to a two-year or four-year college prospective student-athlete (or the prospective student-athlete's relatives or legal guardians). During a contact period that occurs after August 1 before an individual's senior year in high school, telephone calls may be made at the institution's discretion.

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c. On September 3, 2008, and July 19 and 28, 2009, Pearl and Forbes made four impermissible telephone calls to prospective student-athlete Josh Selby (Baltimore, Maryland), who was a junior in high school. The telephone calls were in violation of the NCAA one-call-per-month rule. [NCAA Bylaws 13.1.3.1,13.1.3.1.3 and 13.1.3.1.7]

Josh Selby

Month Date of Calls Length of Caller Action Logged
the Calls (Yes or
No)
September September 3, 2008 5 minutes Steve Forbes Permissible Yes
2008 September 3, 2008 2 minutes Steve Forbes Additional Yes
July 2009 July 2, 2009 16 minutes Bruce Pearl ennis sible Yes
July 19, 2009 23 minutes Bruce Pearl Additional Yes
July 19,2009 5 minutes Bruce Pearl Additional Yes
July 28, 2009 28 minutes Bruce Pearl Additional Yes d. In August, September and November 2008, Pearl', and Jones made seven impermissible telephone calls to prospective student-athlete Aaron Craft (Findlay, Ohio), who was a junior in high school. The telephone calls exceeded the number of telephone calls that the institution was permitted to make per month to a prospective student-athlete. [NCAA Bylaws 13.1.3.1, 13.1.3.1.3 and 13.1.3.1.7]

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Aaron Craft

Month Date of Calls Length of Caller Action Logged
the Calls (Yes or
Nol
August August 3, 2008 19 minutes Tony Jones Permissible Yes
2008 August 5,2008 31 minutes Bruce Pearl Additional No
August 12, 2008 2 minutes Tony Jones Additional Yes
August 30, 2008 2 minutes Bruce Pearl Additional Yes
September September 2, 2008 8 minutes Bruce Pearl Permissible Yes
2008 September 17, 2008 2 minutes Tony Jones Additional Yes
September 26, 2008 2 minutes Tony Jones Additional Yes
November November 23, 2008 6 minutes Bruce Pearl Permissible Yes
2008 November 24,2008 19 minutes Tony Jones Additional No
November 29, 2008 8 minutes Tony Jones Additional No e. On July 30, 2009, Pearl made one impermissible telephone call td prospective student-athlete Griffin McKenzie (Cincinnati, Ohio), who was a junior in high school. The telephone call exceeded the number of telephone calls that the institution was permitted to make per month to a prospective student-athlete. [NCAA Bylaws 13.1.3.1,13.1.3.1.3 and 13.1.3.1.7J

Griffin McKenzie

Month Date of Calls Length of Caller Action Logged
the Calls (Yes or
No)
July 2009 July 7, 2009 14 minutes Jason Shay Permissible Yes
July 30, 2009 17 minutes Bruce Pearl Additional Yes f. On June 29, 2009, Pearl made one impermissible telephone call to prospective student-athlete Justin Martin (Indianapolis, Indiana), who was a junior in high school. The telephone call exceeded the number of telephone calls that the institution was permitted to make per month to a prospective student-athlete. [NCAA Bylaws 13.1.3.1, 13.1.3.1.3 and 13.1.3.1.7]

Justin Martin

Month Date of Calls Length of Caller Action Logged
the Calls (Yes or
No)
June 2009 June 22, 2009 25 minutes Jason Shay Permissible Yes
June 29, 2009 2 minutes Bruce Pearl Additional Yes NOTICE OF ALLEGATIONS Case No. M339

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g. On February 21, 2009, Pearl made four impermissible telephone calls to then prospective student-athlete Rico Pickett (Miami Dade Community College), who was in junior college. The telephone calls exceeded the number of telephone calls that the institution was permitted to make per week to a prospective studentathlete. [NCAA Bylaws 13.1.3.1, 13.1.3.1.3 and 13.1.3.1.7]

Rico Pickett

Month Date of Calls Length of Caller Action Logged
the Calls (Yes or
No)
February 2009 February 17,2009 7 minutes Bruce Pearl Permissible Yes
February 21, 2009 3 minutes Bruce Pearl Additional Yes
February 21, 2009 2 minutes Bruce Pearl Additional Yes
February 21, 2009 3 minutes Bruce Pearl Additional Yes
February 21, 2009 4 minutes Bruce Pearl Additional Yes h.

i. On August 21 and 22, and September 14, 2007, Forbes and Jones made six impermissible telephone calls to prospective student-athlete Chris Singleton (Dunwoody, Georgia), who was a senior in high school. The telephone calls exceeded the number of telephone calls that the institution was permitted to make per week to a prospective student-athlete. [NCAA Bylaws 13.1.3.1, 13.1.3.1.3 and 13.1.3.1.7]

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Chris Singleton

Month Date of Calls . Length of Caller Action Logged
the Calls (Yes or
No)
August August 20, 2007 7 minutes Tony Jones Permissible Yes
2007 August 21, 2007 16 minutes Tony Jones Permissible Yes
August 21, 2007 1 minute Steve Forbes Additional No
August 22, 2007 2 minutes Steve Forbes Additional Yes
September September 10,2007 12 minutes Tony Jones Pennissible No
2007 September 11, 2007 2 minutes Bruce Pearl Permissible Yes
September 14, 2007 3 minutes Steve Forbes Additional Yes
September 14, 2007 3 minutes Steve Forbes Additional Yes
September 14,2007 1 minute Tony Jones Additional No
September 14, 2007 5 minutes Tony Jones Additional No j. In September, October and November 2007, Pearl and Forbes- made nine impermissible telephone calls to prospective student-athlete Elliot Williams (Memphis, Tennessee), who was a senior in high school. The telephone calls exceeded the number of telephone calls that the institution was permitted to make per week to a prospective student-athlete. [NCAA Bylaws 13.1.3.1, 13.1.3.1.3 and 13.1.3.1.7]

Elliott. Williams

Month Date of Calls Length of Caller Action Logged
the Calls (Yes or
No)
September September 12, 2007 24 minutes Bruce Pearl Permissible Yes
2007 September 14, 2007 9 minutes Steve Forbes Permissible No
September 14,-2007- 12 minutes Steve Forbes Additional Yes
October October 8, 2007 1 minute Steve Forbes Permissible No
2007 October 8,2007 8 minutes Steve Forbes Permissible Yes
October 10, 2007 1 minute Bruce Pearl Additional Yes
October 11, 2007 1 minute Bruce Pearl Additional Yes
October 11, 2007 3 minutes Bruce Pearl Additional Yes
October 11,2007 8 minutes Bruce Pearl Additional Yes
October 11, 2007 1 minute Steve Forbes Additional Yes
October 21, 2007 26 minutes Steve Forbes Permissible Yes
October 24, 2007 7 minutes Bruce Pearl Permissible Yes
October 26, 2007 3 minutes Steve Forbes Additional . Yes
October 30, 2007 8 minutes Steve Forbes Permissible Yes
October 31, 2007 20 minutes Bruce Pearl Permissible Yes
November November 1, 2007 1 minute Bruce Pearl Additional Yes
2007 November 1, 2007 2 minutes Steve Forbes Additional No NOTICE OF ALLEGATIONS Case No. M339

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k.

1.

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Please indicate whether this Information is substantially correct and whether the institution believes violations of NCAA legislation occurred. Submit evidence to support your response.

Also, please provide the following:

a. An overview of the institution's recruitment of McKenzie, Martin, Pickett, 811 Singleton, WillIams, this regard, please indicate (1) the identities of all men's oasxetoau coacmng members involved in the young men's recruitment, and (2) the dates ofthe young men's unofficial and official paid visits to the institution's campus.

b. A statement identifying the prospect or prospects' relatives telephoned.

c. An overview of the institution's compliance procedures for monitoring the telephone calls to prospective student-athletes in the men's basketball program from 2007-08 through 2009-1 0 academic years.

d. A copy of any telephone logs the men's basketball staff provided to the institution's compliance staff for the weeks when the impermissible recruiting telephone contacts occurred.

e. A copy of the institution's self-reports to the NCAA regarding the violations set forth in this allegation.

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f. A statement describing the rules education provided to the members of the men's basketball staff regarding NCAA telephone call legislation from 2007-08 through 2009-10 academic years. ill this regard, if the institution held staff meetings, please provide the attendance policy for the staff meetings, and whether the men's basketball coaches identified in this allegation attended the meetings.

g. A statement identifying the persons responsible for monitoring telephone calls for the men's basketball stafffor the time periods outlined in this allegation. '

h. Copies of all correspondence between the institution, the NCAA student-athlete reinstatement staff and the NCAA basketball focus group regarding this allegation.

1. A statement describing the means by which the institution initially became aware of these reported violations. Please describe the investigative efforts.taken by the institution once it became aware of the matters.

j. A statement indicating whether the institution conducted any telephone audits or whether there were any periodic spot checks conducted on the telephone logs of the men's basketball coaching staff during the 2007-08 through 2009-10 academic years. If any audits or periodic spot checks were conducted, please include the dates the telephone audits were conducted, how the audits were conducted, the individuals responsible for conducting the audits, the results of the audits and whether the institution believed its methods for monitoring telephone calls was

effective. .

k, A statement indicating whether the institution used any phone monitoring computer software programs to monitor telephone calls made by members of the men's basketball coaching staff. In this regard, please indicate the date each computer software program was acquired and the date each software program was implemented.

L A statement indicating the reasons these men's basketball coaching staff members made the impermissible telephone calls in light of NCAA legislation prohibiting such actions.

2. [NCAA Bylaws

It is reported that on _ head men's basketball coach Bruce Pearl, associate head men's ~ony Jones, and assistant men's coaches Steve Forbes and Jason Shay

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Please indicate whether this information is substantially correct and whether the institution believes violations of NCAA legislation occurred. Submit evidence to support your response.

Also, please provide the following:

a. An overview of the NCAA rules education related to the institution provided to the men's basketball staff from the 2008-09 through 2009- 10 academic years.

b. An overview of the institution's compliance procedures for monitoring

_ from the 2008-09 .

~oring of

institutional staff members, and (4) activities

_____________ _~ _ _ k_ _ _ __ :_- _.+ _

c. A statement identifying all the members of the men's basketball staff

d.

e. A statement indicating the reasons these alleged violations were not reported to the institution's athletics administration by the men's basketball staff between ~dJuly 19, 2010.

f.

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g.

h. A statement indicating th made an impennissible identified .

-- --- ---. --- - --- - -- --- -- - -- - -- ~- - --- --_-- -

.

3. [NCAA Bylaw 13.1.1.1J

It is alleged that on or about September 14, 2010, head men's basketball coach Bruce Pearl and associate head men's basketball coach Tony Jones made an in-person, offcampus contact with prospective student-athlete Jordan Adams (Lawrenceville, Georgia) during Adams' junior year in high school. Specifically, Pearl and Jones visited Adams at Oak Hill Academy, where they had a two- to three-minute conversation with Adams prior -to the start of Adams' basketball practice.

Please indicate whether this information is substantially correct and whether the institution believes a violation of NCAA legislation occurred. Submit evidence to support your response.

Also, please provide the following:

a. An overview of the institution's recruitment of Adams. In this regard, please indicate (1) the identities of all men's basketball coaching staff members involved in the young man's recruitment, (2) the dates of the young man's unofficial and official paid visits to the institution's campus, and (3) copies of the men's basketball coaches' recruiting logs documenting the young man's recruitment.

b. A statement identifying all the prospective student-athletes Pearl and Jones contacted at Oak Hill Academy on or about September 14,2010. In this regard, please provide an overview of the institution's recruitment of all the prospective student-athletes Pearl and Jones had contact with, each prospective studentathlete's class rank, and the location the contact allegedly occurred.

c. A statement indicating the reasons Pearl and Jones made an impermissible contact with Adams in light of NCAA legislation prohibiting such contacts.

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4. [NCAA Bylaws lO.1-(c), 10.l-(d), 19.01.2, 19.01.3 and 32.1.4J

It is alleged that during the 2008-09 through 2009-10 academic years, head men's basketball coach Bruce Pearl acted contrary to the principles of ethical conduct when he knowingly engaged in violations of NCAA recruiting legislation and failed to deport himself in accordance with the generally recognized high standards of honesty and sportsmanship normally associated with the conduct and administration of intercollegiate athletics by initially providing false and misleading information to the institution and the enforcement staff and by attempting to influence others to furnish the institution and enforcement staff false and misleading information concerning their involvement in or knowledge of matters relevant to a violation of an NCAA regulation. Specifically:

a.

(NCAA Bylaws 10.1-(c), IO.l-(~) and 19.01.2]

b. On June 14, 2010, Pearl was interviewed by the institution and the NCAA enforcement staff regarding his knowledge of violations of NCAA legislation in the men's basketball program. Pearl initially provided false and misleading information to the institution and the NCAA enforcement staff when he was shown a photograph taken of him and Craft in Pearl's home, and he denied knowledge of the location of the photograph. On that same date, Pearl initially provided false and misleading information when he denied that he knew the identity of another individual depicted in that photograph, the wife of assistant men's basketball coach Jason Shay. [NCAA Bylaw lO.l-(d)]

c. On June 14, 2010, Pearl failed to protect the integrity of the investigation when he placed a series of phone "Calls to John Craft (J. Craft), the father of Craft, who visited Pearl's home during an unofficial visit on September 20, 2008. Pearl placed the first telephone call prior to the start of Pearl's interview with the enforcement staff and the institution. During a subsequent telephone call, Pearl reminded J. Craft that it was a violation of NCAA legislation for his family to have attended the cookout, and that Pearl gave J. Craft a choice to attend the

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cookout. Pearl's conversation with J. Craft caused J. Craft to believe that Pearl was trying to influence J. Craft's statements to the NCAA enforcement staff. [NCAA Bylaws 10.1-Cd), 19.01.3 and 32.1.4]

Please indicate whether this information is substantially correct and whether the institution believes violations of NCAA legislation occurred. Submit evidence to support your response, including the dates Pearl was interviewed and who was present for the interviews.

5. [NCAA Bylaws 10.01.1, 11.1.1, 19.01.3 and 32.1.4]

It is alleged that during the 2008-09 through 2009-10 academic years, assistant men's basketball coach Steve Forbes violated the NCAA's principles of honesty when he failed to provide full and complete information to the institution and the enforcement staff and failed to protect the integrity of the investigation. Specifically:

a. On June 14, 2010, during an interview with the institution and the enforcement staff, Forbes failed to furnish full and complete information relevant to the investigation by not disclosing that he and the other men's basketball coaching staff members were present at head men's basketball coach Bruce's home

on September

b. On June 14, 2010, Forbes failed to protect the integrity of the investigation by meeting and speaking with Pearl about the topics discussed in Forbes' June 14, 2010, interview with the institution and the enforcement staff after he was specifically advised by the enforcement staff to keep the contents of the interview confidential. [NCAA Bylaws 10.01.1,11.1.1 and 32.1.4]

Please indicate whether this information is substantially correct and whether the institution believes violations of NCAA legislation occurred. Submit evidence to support your response including the dates Forbes was interviewed and who was present for the interviews.

6. [NCAA Bylaws 10.01.1,11.1.1,19.01.3 and 32.1.4]

It is alleged that during the 2008-09 through 2009-10 academic years, assistant men's basketball coach Jason Shay violated the NCAA's principles of honesty when he failed to provide full and complete information to the institution and the enforcement staff and failed to protect the integrity of the investigation. Specifically:

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a. On June 14,2010, during an interview with the institution and enforcement staff, Shay failed to furnish full and complete information relevant to the investigation by not disclosing that he and the other men's basketball coaching staff members were present at head men's basketball coach Bruce Pearl's home on September

b. On June 14, 2010, Shay failed to protect the integrity of the investigation by meeting and speaking with Pearl about the topics discussed in Shay's June 14, 2010, interview with the institution and enforcement staff after he was specifically advised by the enforcement staff to keep the contents of the interview confidential. [NCAA Bylaws 10.01.1, 11.1.1 and 32.1.4]

Please indicate whether this information is substantially correct and whether-the institute on believes violations of NCAA legislation occurred. Submit evidence to support your response, including the dates Shay was interviewed and who was present for the interviews.

7. [NCAA Bylaws 10.01.1, 11.1.1 and 19.01.3]

It is alleged that during the 2008-09 through 2009-10 academic years, associate head men's basketball coach Tony Jones violated the NCAA's principles of honesty when he failed to provide full and complete information to the institution and enforcement staff regarding his involvement in and knowledge of violations of NCAA legislation, in that on June 14,2010, during an interview with the institution and enforcement staff, Jones failed to furnish full and complete information relevant to the investigation by not disclosing that he and the other men's basketball coaching staff members were at head men's basketball coach Bruce Pearl's home on

Please indicate whether this information is substantially correct and whether the institution believes violations of NCAA legislation occurred. Submit evidence to support your response, including the dates Jones was interviewed and who was present for the interviews.

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8. [NCAA Bylaw 11.1.2.1]

It is alleged that between the 2007-08 and the 2009-10 academic years, head men's basketball coach Bruce Pearl failed to promote an atmosphere for compliance and failed to monitor the activities regarding compliance of all his assistant men's basketball coaches within the men's basketball program as it relates to Allegation Nos. 1, 2, 3 and 12.

Please indicate whether this information is substantially correct and whether the institution believes a violation of NCAA legislation occurred. Submit evidence to support your response.

Also, please provide the following:

a. Related to Allegation No.1, a statement indicating whether Pearl promoted an atmosphere for compliance and monitored his staff's telephone recruiting. Please indicate whether Pearl complied or encouraged compliance with the institution's use of telephone logs for compliance monitoring. Also, please indicate whether Pearl ever communicated with members of the institution's compliance staff about his and his staff's completion of the telephone logs, and if so, the nature of the communications.

b. Related to Allegation No.2, a statement ir icicanng atmosphere for compliance when he

c. Related to Allegation No.3, a statement indicating whether Pearl promoted an atmosphere for compliance when he made an in-person, off-campus contact with a prospective student-athlete in his junior year of high school at the young man's educational institution.

d. Related to Allegation No. 12, a statement indicating whether Pearl promoted an

atmosphere for and monitored his staffs

regarding

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9. [NCAA Bylaws 11.5.1, 11.7.1.1.1.1, _ 13.02.7, 13.02.14-(c), 13.1.2.1,13.1.2.1.1,13.1.3.4.1,13.1.3.5.1,13.1.6.2,13.1 1'.1, 13.11.1.1

It is alleged that during the 2009·10 academic year, former members of the institution's football coaching stair .... engaged in impermissible recruiting activities WIth prospective Specifically:

a. Between January 3 and 9, 2010, members of the football coaching staff made 16 impermissible recruiting telephone calls to Brandon

were to the football staff' s receipt of

information in December 2009 from the institution'S compliance statr that such telephone calls were impermissible. [NCAA Bylaw 13.1.6.2]

Prospective Date of Calls Time Length of Coach
Student-Athletes Calls
Brandon Willis January 4,2010 3:17 p.m. 1 minute Assistant Coach I
January 6, 2010 9:24 a.m. 1 minute Head Coach
January 6, 2010 1:03 p.m. 1 minute Head Coach
January 6, 2010 9:18p.m. 7 minutes Assistant Coach 2
January 5, 2010 2:46p.m. 8 minutes Assistant Coach 3
7:48 p.m. 2 minutes Assistant Coach 1
January 7,2010 11:45 a.m. 6 minutes Head Coach
Seantrel Henderson January 6, 2010 7:35 a.m. 2 minutes Assistant Coach 2
Ahmad Dixon January 4, 2010 10:30 p.m. 2 minutes Assistant Coach 3
January 5, 2010 2:58p.m. 1 minute Assistant Coach 3
January 5, 2010 3:01 p.m. 1 minute Assistant Coach 3
January 5,2010 9:20p.m. 1 minute Assistant Coach 3
January 5, 2010 9:43 p.m. 1 minute Assistant Coach 3
January 6,2010 11:15 a.m. 1 minute Assistant Coach 3
January 6,2010 9:24p.m. 9 minutes Head Coach
January 7,2010 5:16p.m. 3 minutes Assistant Coach 3 NOTICE OF ALLEGATIONS Case No. M339

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b.

then assistant football coach David Reaves

c. On October 12, 2009, then head football coach Lane Kiffin permitted then

. football recruiting intern Steve Rubio to make in-person, off-campus contacts with high school administrators during a recruiting trip to Saint Thomas Aquinas High School (St. Thomas Aquinas) in Fort Lauderdale, Florida. This trip and these contacts occurred after David Blackburn, the institution's director of football operations, informed both Kiffin and Rubio on or about October 10, 2009, that Rubio was not permitted to enter a high school's property while accompanying a football coach on a recruiting trip. This trip and subsequent contacts also occurred prior to Rubio being certified to recruit off campus. [NCAA Bylaws 11.5.1,11.7.1.1.1.1,13.1.2.1 and 13.1.2.1.1]

d.

Please indicate whether this information is substantially correct and whether the institution believes violations of NCAA legislation occurred. Submit evidence to support your response.

Also: please provide the following:

a. A statement describing the general organization and structure of the institution's intercollegiate athletics department, including the organization of the football program, and the identities of those individuals in the athletics department who were

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-,

responsible for the supervision of the football program during the 2009-10 academic year.

b.

An overview of th~tutiOJi'S recruitment ofWillis._ Henderson, Dixon, Jones an~ In this regard, please indicat~ies of all the former football coaching staff members involved in the young men's recruitment, (2) the geographical territory each coaching staff member was responsible for and (3) the identity of all educational institutions the young men attended prior to their enrollment at the institution. If the young men are not currently enrolled at the institution, please identify the institutions in which the prospective studentathletes are currently enrolled.

c.

A copy of any telephone recruiting contact logs the former football coaching staff members produced to the institution's compliance staff for the weeks when the impermissible telephone contacts occurred.

d.

...nn· ........... with prospective studentAdditionally, if the former attended any compliance staff meetings regarding this matter, please include the attendance sheets and the attendance

policies for the meetings. .

e. A statement identifying the persons responsible for monitoring telephone calls for the former football coaching staff members for the time periods outlined in this allegation.

f. A statement indicating whether the institution conducted any telephone audits or whether there were any periodic spot checks conducted on the telephone logs of the fanner football coaching staff during the 2009-10 academic year. If any audits or periodic spot checks were conducted, please include the dates the telephone audits were conducted, how the audits were conducted and the results of the audits.

g. A statement indicating whether the institution used any phone monitoring computer software programs to monitor telephone calls made by members of the former football coaching staff. In that regard, please indicate the dates that the computer software programs were acquired and implemented.

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h. A description of the institution's procedures during the time of the alleged violations for recording and reporting the football coaching staff's telephone contacts.

1.

J. An overview of Rubio's employment at the institution. In this regard, please include the positions Rubio has held during his tenure at the institution, a description of his job responsibilities for each position held and his immediate supervisor during the time the positions were held.

k. A review of the NCAA rules education that Rubio received regarding noncoaching staff members accompanying football coaching staff members on recruiting trips. In this regard, attach any memorandum that was distributed from athletics or compliance administrators to the football coaching staff members regarding institutional staff members accompanying a coaching staff member on a recruiting trip. Additionally, please identify the high school administrators with whom Rubio had contact at St. Thomas Aquinas.

1. The reasons Rubio accompanied Kiffin inside St. Thomas Aquinas in light of the directive that Rubio was not permitted to accompany Kiffm in this manner of

recruiting trips. .

m. Copies of the Level I or Level II secondary violation reports submitted to Chris Strobel, NCAA director of enforcement for secondary infractions, by the institution or by the Southeastern Conference office regarding the institution's football program during the 2009~1O academic year. In this regard, please describe any increased rules education or monitoring efforts the institution engaged in with the former members of the football coaching staff identified in this allegation.

n. A detailed description and explanation of all disciplinary actions taken against any current or former athletics department staff members based on the involvement of these individuals in violations of NCAA legislation as determined by the institution and as mentioned in this inquiry.

o. A statement indicating the reasons the former members of the football coaching staff committed the violations set forth in this allegation in light of NCAA legislation prohibiting such actions.

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p.

q.

r.

s.

t.

u.

v.

10. [NCAA Bylaw 11.1.2.1]

It is alleged that during the 2009-10 academic year, then head football coach Lane Kiffin failed to promote an atmosphere for compliance within the football program and failed to monitor the activities regarding compliance of several assistant football coaches _ _ and an athletics administrator involved with the football program who reported

'drrectiYor indirectly to Kiffin, as it relates to Allegation No.9.

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Please indicate whether this information is substantially correct and whether the institution believes a violation of NCAA legislation occurred. Submit evidence to support your response.

Also, please provide the following:

a. Related to Allegation No. 9-(a) , a statement indicating whether Kiffin promoted an atmosphere for compliance and monitored his staffs telephone recruiting. Please indicate whether Kiffm complied or encouraged compliance with the institution's directives for placing telephone calls to prospects

_ Also, please indicate whether Kiffin ever communicated ~the institution's . staff about his and his staff's telephone calls to prospects and, if so, the nature of the commnnicarions.

----~-- ---~--

t

b. Related to Allegation No. 9-(c), a statement indicating whether Kiffin promoted

an atmosphere for compliance when he permitted football recruiting intern Steve Rubio, to enter the st. Thomas Aquinas High School campus and have in-person contact with high school administrators while Rubio accompanied Kiffin on a recruiting trip.

c. Related to Allegation Nos. 9-(b) and 9-(d), a statement E>

to promote an atmosphere for and monitor

11. [NCAA Constitution 2.8.1]

It is alleged that the scope and nature of the violations set forth in Allegation No.1 demonstrates that between August 1, 2007, and July 29, 2009, the institution failed to monitor the men's basketball coaching staff's telephone contacts with prospective student-athletes and their relatives in order to ensure compliance with NCAA telephone contact legislation.

a. Between August 1, 2007, and July 27, 2009, members of the men's basketball coaching staff did not sufficiently report information concerning telephone calls made to prospective student-athletes and their relatives to the appropriate athletics department officials. Additionally, the institution did not have adequate systems in place to monitor whether telephone calls made by the men's basketball coaching staff members to prospective student-athletes or their relatives complied with NCAA legislation. This collective failure resulted in the violations outlined in Allegation No.1.

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Please indicate whether this information is substantially correct and whether the institution believes a violation of NCAA legislation occurred. Submit evidence to support your response.

Secondary Violation

12. [NCAA Bylaws

a.

b.

c.

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Please indicate whether this information is substantially correct and whether the institution believes violations of NCAA legislation occurred. Submit evidence to support your response.

Also, please provide the following:

a. An overview of the institution's compliance procedures for monitoring _ _ during the 2009-10 academic year.

b.

A copy of the institution's athletes identified in this allegation.

~ ~, .

-~-;---_.- - --~::-:-

ecords for the prospective student-

c. Please include any documentation or memorandums that the institution's

..,..-n"""""T or the men's basketball staffused to L.llV'J.LLL'''J.

e. A statement describing the means by which the institution initially became aware of these reported violations. Please describe the investigative efforts taken by the

institution once it became aware of the matters. .

f. the reasons the men's basketball coaching staff permitted

ncennnec in this allegation of NCAA legislation

Information requested by the Committee on Infractions

1~. Please provide all information concerning other possible violations of NCAA legislation that were discovered by the institution as a result of its review of this matter. In this regard, please indicate the means by which the information was discovered and the institution's position as to whether a violation has occurred.

14. Please provide a detailed description of the means by which the institution initially discovered the possible violations of NCAA legislation and an overview of its investigative efforts.

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15. Please provide a detailed description and explanation of all corrective and punitive actions implemented by the institution as a result of the violations acknowledged in this inquiry. In that regard, explain the reasons the institution believes these actions to be appropriate and indentify the violations on which the actions were based. Additionally, indicate the date that any corrective or punitive actions were implemented.

16. Please provide a detailed description of all disciplinary actions taken against any current or former athletics department staff members as a result of violations acknowledged in this inquiry. In that regard, explain the reasons that the institution believes these actions to be appropriate and indentify the violation on which the actions were based. Additionally, indicate the date that any disciplinary actions were taken and submit copies of ail correspondence from the institution to each individual describing these disciplinary actions.

17. Please provide a statement indicating the dates and titles of all positions at the institution held by individuals identified during the inquiry as allegedly having significant involvement in NCAA violations as well as a brief overview of each position. Additionally, provide the dates, title and employer of all positions held by such individual during-the five yearsprior to the dates of the alleged violations. Furthermore, provide a brief review of the previous major infractions case history for identified individuals.

18. Please provide a short summary of every major infractions case involving the institution or individuals named in this notice. In this summary, provide the date of the infractions report, a description of the violations found by the Committee on Infractions, the individuals involved, and the penalties and corrective actions. Additionally, please provide a copy of any major infractions report involving the institution or individuals named in this notice that were issued by the Committee on Infractions within the last 10 years.

19. Please provide a chart depicting the institution's reporting history of secondary violations for the past five years. In this chart, please indicate for each academic year the number of total secondary violations reported involving the institution or individuals named in this notice. Also, please indicate the applicable bylaws for each violation, and then indicate the number of secondary violations involving just sports teams named in this notice for the same five-year time period.

20. Please provide a statement describing the general organization and structure of the institution's intercollegiate athletics department, include the identities of those individuals in the athletics department who were responsible for the supervision of all sport programs during the previous four years, and whether the institution conducts a systematic review of NCAA and institutional regulations for its athletics department

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employees. If yes, identify the agency, individual or committee responsible for this review, and describe the responsibilities and functions of each identified

21. Please provide the following information concerning the sport programs identified in this mquiry:

a. The average number of initial and total grants-in-aid that have been awarded during the past four academic years.

b. The number of initial and total grants-in-aid in effect for the current academic year (or upcoming academic year if the regular academic year is not in session), and the number anticipated being in effect for the following academic year.

c. The identities of all student-athletes anticipated to be on athletically related financial aid as of the first semester of the next academic year who will have four years of remaining eligibility and five years of enrollment (per the NCAA's fiveyear rule) to complete those four years, the identities of all student-athletes who have three years of remaining eligibility and four years of remaining enrollment to complete those three years, the identities of all student-athletes who have two years of remaining eligibility and three years of remaining enrollment to complete those two years, and the identities of all student-athletes who have one year of remaining eligibility and two years of remaining enrollment to complete that year.

d. The average number of student-athletes during the previous four years who have redshirted and the number of student-athletes who are redshirting during the current academic year (or upcoming academic year if regular academic year is not in session).

e. The number of student-athletes in each of the previous four years who were awarded athletically related financial aid but who withdrew from the squad for reasons other than graduation or loss of eligibility.

f A list of the institution's win-loss record for the past four seasons and the dates and results of all postseason competition in which the institution has participated during those years. If there was postseason competition, please indicate how this was earned (i.e., conference automatic bid, at-large bid).

g. The average number of official paid visits provided by the institution to prospective student-athletes during the past four years.

h. The· cost of room, board, books and tuition at the institution for the past four academic years.

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1. Copies of the institution's squad lists for the past four academic years.

J. Copies of the institution's media guides for the past four academic years.

k. A review of the institution's obligations (contractual or otherwise) concerning live telecasts of contests during the next three seasons. These should include, but are not limited to, contractual agreements negotiated by the institution's conference and opponent or through its sports network affiliations.

1. A statement indicating whether the provisions of NCAA Bylaws 31.2.2.3 and 31.2.2.4 apply to the institution as a result of the involvement of student-athletes in violations noted in this inquiry.

m. A statement indicating whether the provisions of NCAA Bylaw 19.5.2.2-(e) apply to the institution as a result of the involvement of student-athletes )n violations noted in this inquiry.

22. Any additional information or comments regarcling this case are welcome.