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COACH MAURICE HARRIS

RESPONSE TO NOTICE OF ALLEGATIONS

Mississippi 189693 - MHarris

Jesse Mitchell III, Esq.
The Mitchell Firm, PLLC
1020 Highland Colony Pkwy., Ste. 704
Ridgeland, MS 39157
INTRODUCTION

As stated by the enforcement staff, Coach Maurice Harris seems to be a genuinely good and honest

man. He truly is just that – an honest man who tries to carry out his duties the right way and who truly cares

about the student-athletes entrusted to him. Throughout this process, Coach Harris has been an open book

with nothing to hide. He fully cooperated with the University of Mississippi (the “University”) and NCAA

Enforcement Staff (“Enforcement Staff”) during every step of this investigation. In fact, Coach Harris retained

and promptly provided the University and the enforcement staff with all text messages, emails, and other

requested correspondence exchanged between him and (“ ”). Coach Harris faithfully

preserved all of his communications and did not believe that he improperly gained any recruiting advantages

through his communications or interactions with .

However, because of this investigation, Coach Harris now understands that his initial assessment of

as an FCA staff member similar to an assistant coach was improper and misguided. This is not

something that Coach Harris has taken lightly. Coach Harris has diligently worked to ensure that he better

understands and fully complies with all NCAA rules. This is evident by his strong reliance upon, and constant

communication and utilization of, the University’s compliance staff. Since this incident occurred, he has

become the most cautious and inquisitive staff member on campus. Simply stated, he wants to carry out his

duties correctly. However, as fully addressed below, Coach Harris takes issue with the enforcement staff’s

characterization of him as a facilitator in several of the allegations in which he is mentioned. Coach Harris will

take full accountability for his actions and decisions, but several of the allegations made against him are simply

not true. Coach Harris’ position is further supported by the testimony of and head

coach, . In his interview, explains that after seeing interact with

several athletes in the locker-room, Coach Harris mistakenly believed that was an assistant

coach, but corrected Coach Harris and informed him that he was not an assistant coach, but

he was “their FCA guy”. Based on his past experiences and his knowledge of the role that FCA staffers play

within the Inner City of school system, Coach Harris placed into a box slightly similar to a

volunteer assistant coach. However, as states in his interview, at no time did Coach Harris instruct or

encourage him to do anything improper for any of the recruits. In fact, unequivocally states
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that he treated the recruits the same as he treated any other kids in the FCA pr g m. Li
other athletes and non-athletes (both male and female) and his wife counseled them, mentored them,

and became a resource to help many of these kids through tough situations all while encouraging them to beat

the odds by going to college, any college, not simply to Ole Miss.

The focus here should be on Coach Harris’s intentions and actions based on his knowledge during the

relevant four months that he recruited the recruits. At this time, he saw as someone with a

preexisting relationship with these kids who was trying to help them get to college. As confirms, at no

time did Coach Harris encourage, know, or instruct to do anything improper in the recruitment process.

In retrospect, were there signs or things that Coach Harris could have handled better? Yes. However, based on

his experience, knowledge, and assumptions at that time, he believed that he was faithfully and properly carrying

out his duties.

5. [NCAA Division I Manual Bylaws 11.7.2.2, 13.01.4, 13.1.2.1, 13.1.2.4-(a), 13.1.2.5, 13.1.3.5.1,
13.2.1, 13.2.1.1-(b), 13.2.1.1-(e), 13.5.3, 13.7.2.1 and 13.7.2.1.2 (2012-13)]

It is alleged that during the 2012-13 academic year, , a then representative of the institution's
athletics interests, assisted the institution in its recruitment of four then football prospective student-athletes by engaging
in recruiting activities that promoted the institution's football program. activities included engaging in
impermissible recruiting contact with four then football prospective student-athletes and their families, as well as providing
them with approximately $2,250 in impermissible recruiting inducements. Maurice Harris (M. Harris), assistant
football coach and recruiting coordinator, knew of association with the four then football prospective student-
athletes, and at times, facilitated recruiting activities. Further, between January 18 and February 3, 2013, M.
Harris arranged for approximately $485 in impermissible recruiting inducements in the form of free hotel lodging during
unofficial visits for two of the then football prospective student-athletes. Specifically:

a. On October 13, 2012, provided then football prospective student-athletes
and with roundtrip transportation
between and (approximately miles) in conjunction
with an unofficial visit and home football game at the institution. also provided with
a free meal on this occasion. The combined monetary value of the inducements was approximately $43.
Additionally, met M. Harris during the visit and informed Hugh Freeze (Freeze), head
football coach, M. Harris and Matt Luke (M. Luke), assistant football coach, after the visit that he
had provided , and transportation on this occasion. [NCAA Bylaws
13.01.4, 13.1.2.1 and 13.2.1 (2012-13)]

b. On November 10, 2012, provided , and with roundtrip
transportation between and Oxford in conjunction with an unofficial visit and home football
game at the institution. also provided with a free meal on this occasion. The combined
monetary value of the inducements was approximately $43. Further, notified M. Harris in
advance that he would provide and transportation on this occasion. [NCAA Bylaws
13.01.4, 13.1.2.1 and 13.2.1 (2012-13)]

c. On November 24, 2012, provided then football prospective student-athlete
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, and with roundtrip transportation between and O
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conjunction with an unofficial visit and home football game at the institution. also provided
, and with free meals on this occasion. The combined monetary value of
the inducements was approximately $83. Further, notified M. Harris in advance that he
would see M. Harris on this occasion. [NCAA Bylaws 13.01.4, 13.1.2.1 and 13.2.1 (2012-13)]

d. Between November 28 and 30, 2012, engaged in telephone communication with mother, at
M. Harris' direction, to arrange an off-campus recruiting contact between her and M. Luke. [NCAA Bylaws
13.01.4, 13.1.2.1, 13.1.2.4-(a) and 13.1.3.5.1 (2012-13)]

e. On December 3, 2012, attended an in-home recruiting visit by M. Harris and Freeze that occurred
at residence. Additionally, notified M. Harris in advance of the visit that he would be attending
the visit, and both he and Freeze interacted with during the visit. Further, provided food for
this occasion, which had a monetary value of approximately $60. [NCAA Bylaws 13.01.4, 13.1.2.1 and
13.2.1 (2012-13)]

f. In December 2012, paid cellphone bill, which had a monetary value of approximately $67.
[NCAA Bylaws 13.2.1 and 13.2.1.1-(e) (2012-13)]

g. In December 2012, paid mother's telephone bill, which had a monetary value of
approximately $120. [NCAA Bylaws 13.2.1 and 13.2.1.1-(e) (2012-13)]

h. Between January 4 and 5, 2013, provided and with roundtrip transportation
between and Birmingham, Alabama, (approximately miles) as well as free hotel lodging, meals
and game tickets, in conjunction with the institution's bowl game. The combined monetary value of the
inducements was approximately $350. Additionally, notified M. Harris in advance of the trip that
he would take and to the bowl game. Further, on January 4, M. Harris arranged an off-
campus recruiting contact of and by Tray Scott (T. Scott), then graduate assistant football
coach, that occurred at the team hotel in Birmingham. [NCAA Bylaws 11.7.2.2, 13.01.4, 13.1.2.1,
13.1.2.5 and 13.2.1 (2012-13)]

i. Between January 14 and 15, 2013, engaged in telephone communication with mother, at M.
Harris' direction, to arrange an off-campus recruiting contact between her and M. Harris. [NCAA Bylaws
13.01.4, 13.1.2.1, 13.1.2.4-(a) and 13.1.3.5.1 (2012-13)]

j. Between January 18 and 20, 2013, provided , , mother and
sister with roundtrip transportation between and Oxford in conjunction with an unofficial
visit to the institution. On January 18, drove and from to Oxford, and
did the same for mother and sister January 20. Also on January 20, drove ,
and mother and sister back to . The combined monetary value of the
transportation was approximately $136. Further, notified M. Harris in advance that he would provide
these four individuals transportation for this occasion.

Additionally, during the nights of January 18 and 19, M. Harris arranged for and to
stay, at no cost, in a hotel room at in Oxford that the institution
provided to for his official paid visit. The combined monetary value of and
impermissible lodging was approximately $212.

Further, on January 20, T. Scott provided and with roundtrip transportation between the
and Freeze's residence (approximately miles) for a recruiting breakfast. The combined
monetary value of the transportation was approximately $12.

Moreover, , , and mother and sister received free meals during the January 20
recruiting breakfast at Freeze's residence, which had a combined monetary value of approximately $102. While
at Freeze's residence, and mother and sister had impermissible off-campus
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recruiting contact with various members of the football staff, including T. Scott and M. Harris. Lastly,
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interacted with several members of the football staff at Freeze's residence and M. Harris knew th
had accompanied , and mother and sister to Freeze's home on this occasion.
[NCAA Bylaws 11.7.2.2, 13.01.4, 13.1.2.1, 13.1.2.5, 13.2.1, 13.5.3 and 13.7.2.1.2 (2012-13)]

k. On January 26, 2013, provided with transportation from to Oxford in conjunction
with an unofficial visit to the institution. The monetary value of the one-way transportation was approximately
$13. Additionally, notified M. Harris in advance of the visit that he would provide one-way
transportation on this occasion. Further, on January 27, 2013, , a representative of the institution's
athletics interests, provided with one-way transportation from Oxford to . The monetary value
of this transportation was approximately $13. [NCAA Bylaws 13.01.4, 13.1.2.1 and 13.2.1 (2012-13)]

l. On January 30, 2013, hosted, at his residence, an off-campus recruiting contact by M. Harris that
was attended by , , and family members of the then football prospective student-
athletes. [NCAA Bylaws 13.01.4 and 13.1.2.1 (2012-13)] m. Between February 2 and 3, 2013,
provided and with roundtrip transportation between and Oxford in conjunction
with unofficial visit and official paid visit to the institution. The combined monetary value
of the transportation was approximately $43. notified M. Harris in advance that he would provide
and with transportation on this occasion.

Additionally, on February 2, M. Harris arranged for to stay overnight, at no cost, in his own hotel
room at the that was originally reserved for mother in conjunction with official
paid visit. The monetary value of the lodging was approximately $159.M. Harris and Chris Kiffin, then
assistant football coach, were present when and arrived at the and assisted
them with checking into their rooms. [NCAA Bylaws 13.01.4, 13.1.2.1 and 13.2.1, and 13.7.2.1 (2012-
13)]

n. On March 24, 2013, provided , and with roundtrip transportation between
and Oxford, as well as game tickets and concessions, in conjunction with a baseball game at the
institution. The combined monetary value of the inducements was approximately $126. [NCAA Bylaws
13.01.4, 13.1.2.1 and 13.2.1 (2012-13)]

o. During the 2012-13 academic year, members of family provided , and
with academic tutoring assistance for their high school coursework and ACT exam preparation. The combined
monetary value of the assistance was approximately $647. Additionally, notified Freeze and M.
Harris at the time that his son was providing with academic assistance. [NCAA Bylaws 13.01.4,
13.1.2.1 and 13.2.1 (2012-13)]

p. During the 2012-13 academic year, purchased merchandise for , and
during visits to the institution. The combined monetary value of the merchandise was approximately $510.
[NCAA Bylaws 13.01.4, 13.1.2.1, 13.2.1 and 13.2.1.1-(b) (2012-13)]

Level of Allegation No. 5:

The NCAA enforcement staff believes a hearing panel of the NCAA Division I Committee on Infractions could conclude that
Allegation No. 5 is a severe breach of conduct (Level I) because the alleged violations (1) were not isolated or limited; (2)
provided, or were intended to provide, a substantial or extensive recruiting, competitive or other advantage; (3) provided, or were
intended to provide, a substantial or extensive impermissible benefit; (4) involved benefits provided by a representative of the
institution's athletics interests intended to secure, and which resulted in, enrollment of prospective student-athletes; (5) included
third-party involvement in recruiting violations that institutional officials knew or should have known about; and (6) seriously
undermined or threatened the integrity of the NCAA Collegiate Model. [NCAA Bylaws 19.1.1, 19.1.1-(f) and 19.1.1-(g)
(2016-17)]
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Involved Individual(s):

The enforcement staff believes a hearing panel could enter a show-cause order pursuant to Bylaw 19.9.5.4 regarding M. Harris'
involvement in Allegation No. 5.7

Factual Information (FI) on which the enforcement staff relies for Allegation No. 5:

The attached exhibit details the factual information on which the enforcement staff relies for Allegation No. 5. The enforcement
staff incorporates the factual information referenced throughout this document, its exhibit and all other documents posted on the
secure website.

RESPONSE:

The University agrees that Allegation No. 5 is generally supported by credible and persuasive factual

information – subject to the clarifications below – and that a violation of NCAA legislation occurred. Although

each individual violation would ordinarily be classified as Level II or Level III, the University agrees that

collectively they rise to a Level I violation.

However, the allegation is, in places, misleading and/or factually incorrect. As written, the allegation

implies widespread, intentional wrongdoing by the coaching staff with respect to . As outlined

below, that implication is wrong. Assistant football coach Maurice Harris misunderstood relationship

with the four prospects in question. Harris believed had a pre-existing relationship with the prospects

because he was the FCA “huddle leader” at the prospects’ high school, and based on Harris’s conversation with

prospects, other coaches at the high school, and his own experience as a -area high school coach,

Harris treated like an extension of the high school coaching staff. The evidence is equally clear that the

other coaches mentioned in the allegation asked the right questions and reasonably relied upon Harris’s

understanding of relationship with the prospects in determining – albeit incorrectly – that Harris’s

involvement was not a violation of NCAA legislation.

The University’s concerns with this allegation start with several factual mistakes in its various sub-parts

that contribute to the misleading impression discussed above:

 Allegation No. 5-(e) –To the extent this allegation gives the impression that was

present through any meaningful part of Freeze’s visit with , it is incorrect.

Although was at house when Harris and Freeze arrived, he did not stay for

any portion of the visit, as Freeze asked the right questions of Harris when he arrived. After
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Harris and Freeze discussed the issue, Coach Freeze made sure that both H s and
knew that could not stay for the visit. FI No. 90 at 34-37, Hugh Freeze 8/20/13

Transcript; See Exhibit 5-B, 5-19-16 transcript at 21.

 Allegation No. 5-(h) –Although it is true that Harris instructed to contact Tray Scott,

then a graduate assistant football coach, about a potential visit, this allegation is misleading to

the extent it suggests Harris arranged for contact between the coaching staff and the prospects.

The contact between the prospects and the coaching staff occurred inadvertently when the

prospects sat in on a defensive line meeting at the hotel. Harris was unaware that the violation

occurred as he was not present during the meeting.

 Allegation No. 5-(j) –This impermissible lodging allegation is presumably based on pre-visit

documentation produced by the University classifying visit as an unofficial

visit. FI No. 29, FB 0318. However, before arrived on campus, the University’s

football staff and compliance staff submitted and approved the proper documentation to

classify trip as an official visit. FI No. 146. As such, the lodging and meals provided

to on those dates were permissible under NCAA Bylaws, and the monetary values

corresponding to impermissible benefits outlined in Allegation No. 5-(j) are overstated by the

amounts attributable to .

 Allegation No. 5-(m) –This allegation is factually incorrect, as Harris was not involved in the

decision to allow to stay in the room intended for mother.

Harris only interacted with and after the prospects had already checked into

their hotel rooms, and when Harris learned that had not paid for his hotel room,

he actually required to return to campus and provide reimbursement. FI No. 64 at

40-44, Maurice Harris 5/9/13 Transcript. The allegation that former assistant football coach

Chris Kiffin assisted in arranging for room is similarly flawed. appears to

have misremembered the events in question or confused Kiffin with someone else. y

stated that a graduate student-assistant helped check them in (Kiffin was the defensive line
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coach). statements about this day closely correspond with Harris’s recollection

and Kiffin’s lack of recollection of being at the hotel when they arrived. FI No. 65 at 39, Chris

Kiffin 5/09/13 transcript; FI No. 60 at 22, 03/25/13 transcript; FI No. 64

at 40, Maurice Harris 05/09/13 transcript.

 Allegation No. 5-(o) –The allegation, as written, implies that Freeze was aware of and

disregarded a potential violation of NCAA legislation. This claim is based on a single email.

No information establishes that Freeze ever read or saw that email FI. No. 22, WH0006. To

the contrary, the evidence suggests Freeze would not have seen or reviewed that email FI. No.

90 at 28, Hugh Freeze 8/20/2013 transcript. There is no evidence Freeze knew about this

tutoring arrangement through any other means, and he was never asked if he knew

son tutored .

Apart from these specific issues, the allegation more generally implies that Harris knowingly committed

serious infractions on a large scale. The facts, however, do not substantiate that characterization. Specifically,

when contacted Harris for the first time in October 2012, repeatedly referenced his close,

“mentor[ing]” relationship with the team based on his role as a “huddle leader” in the school’s

Fellowship of Christian Athletes (“FCA”) youth-group. FI No. 50 at 52, 2/13/13 transcript. In

light of representation, Harris followed-up with football coach about

connection to the prospects. The coach confirmed had worked with his athletes for years as part of

the FCA program. FI No. 54 at 13 and 18, Maurice Harris 2/26/13 transcript. This fact was echoed by one of

the prospects, , who told Harris that was the “FCA guy” he knew through his church.

FI No. 54 at 13-14 and 16, Maurice Harris 2/26/13 transcript. Based on these three corroborating sources (and

adding to that his own personal experience with FCA “huddle leaders” in ), Harris

reasonably (albeit erroneously) believed that had known the prospects for many years and that the

relationship between and the four prospects was permissible under NCAA’s pre-existing relationship

test.

Operating under this impression, Harris saw no “red flags” when began bringing the prospects
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to campus on unofficial visits. is neither the stereotypical “third party” seeking enefit
relationship with prospects nor the stereotypical “insider” booster. The University is confident that Harris’s

mistake, while avoidable, was not in bad faith. Although the University agrees that Harris did not meet its

expectations in fully vetting relationships and booster status, there is no suggestion that Harris

intentionally violated NCAA legislation.

Coach Maurice Harris unequivocally states that in retrospect, there were several decisions he made as

a first year coach in a “Power-5” conference that led to NCAA bylaw violations. Specifically, Coach Harris

wholeheartedly regrets that he did not develop a specific plan of action to monitor NCAA rule compliance

regarding status, relationship, and daily interaction with recruits (“ ”),

(“ ”), and (“ ”).

Again, Coach Harris accepts responsibility that under his leadership and during the four- month

recruitment of these four players, he made mistakes as a rookie “Power-5 conference” coach in his initial

assessment and inquiry of position and relationship with these recruits. However, Coach Harris is

opposed to the enforcement staff’s gross mischaracterization of his involvement as a “facilitator” in

conduct. The overwhelming evidence and testimony gathered in this investigation is directly contrary

to any notion that Coach Harris knowingly facilitated or encouraged conduct. Coach Harris never

told to purchase any thing for any of these players. All that Coach Harris knew was that had a

relationship with these recruits as an FCA leader and that he was willing to transport them to the

University’s campus; which he believed was proper at the time.

Coach Harris’s association as an involved party all stems from his initial assessment of based

on his past position/experience as a high school coach in the Inner-city school system and the school

systems relationship with the Fellowship of Christian Athletes (“FCA”). To elaborate, Coach Harris was told

by head coach that was “their FCA guy”. Furthermore, Coach Harris’s relationship with

staffers in Inner-city schools was very similar to the relationship maintained between assistant

coaches/volunteer school staff and FCA staffers. Coach Harris knew that FCA associates were introduced to

students during the students’ eighth or ninth grade school year. He also knew that these FCA associates

developed deep and genuine relationships with these students through time spent together at school functions

as well as non-school functions. Lastly, through experience, Coach Harris knew that FCA associates often
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assisted and encouraged students to prepare for and seek college enrollment and scholarsh p
Based on his experience, Coach Harris believed relationship with FCA students was no

different than a FCA staffer. In fact, Coach Harris’s basic understanding and assessment of was correct.

In his initial inquiry of , Coach Harris was told by the head coach of (Coach

), as well as administrators of , that was one of their FCA leaders. Furthermore,

Coach Harris was informed that was involved in organizing and assisting in the and FCA

summer football camp. Lastly, Coach Harris was informed that attended most practices and

participated on the sidelines to help encourage and engage players during every game. Thus, based

on his past experience and information obtained from the administration, Coach Harris identified

and treated similar to a high school staff member with a pre-existing relationship with the

players. Coach Harris’s assessment and treatment of as a FCA staffer was bolstered once he was

informed that had proactively contacted compliance and was told that he could bring the players

with him to campus. However, Coach Harris now understands that he cannot make such blank assessments

based solely on his past experiences, but that he must make each and every assessment in conjunction with the

vast resources available to him through the compliance staff.1 In fact, Coach Harris now contacts the office of

compliance for guidance more than any other staff member. This alone is direct evidence that he holds the

highest regard for his responsibility as a university official and that he is willing to do whatever it takes to never

place himself or the University under scrutiny ever again.

means and relationships with athletes:

An explanation of who is and what he does helps to paint a more accurate picture and helps

place Harris’s action in the proper perspective.

Throughout this investigation, the enforcement staff has depicted as a wealthy booster who

lavishes Ole Miss Prospects with gifts in an effort to push recruits to Ole Miss. This is very far from the truth.

And, surprisingly, the enforcement staff never interviewed before making such a misguided assessment.

1 Coach Harris also knew that University compliance reviewed all paperwork completed by all recruits during campus
visits. This gave him additional comfort because was identified as a FCA associate. However, compliance never
informed Coach Harris that should not be transporting the players to campus. If anyone had
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informed Coach Harris that this was an issue, then he would have immediately taken all proper actions to ensure that
this never happened again and properly reported it. This is consistent with his actions after he was infor d i J
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of 2013 that should not be assisting the players with transportation to campus.
is a man of modest means who makes less than $80,000 per year. He owns a small landscaping

company that he runs from his house. He employs only four full-time employees, with seasonal summer help

from high school or college students. As shown in the pictures produced by Coach Harris’s counsel,

home is a modest, small, three bedroom, and two bath, circa 1970 home. drives a 2011 Ford F-150

with over 150,000 miles and his wife drives a 2005 Buick sedan.

Nevertheless, and his wife are pillars of their church, FCA, and community, through the giving

of their time and what little resources they have. As and (former chair of FCA) stated, athletes

and non-athletes have been recipients of generosity. stated that he and his wife often cook

for and invite the girls’ basketball team into their home. Likewise, and his wife have assisted

two young ladies who, unfortunately, became pregnant while in high school. and his wife began

mentoring these young ladies and providing them with meals, sporadic transportation, and items for their

babies. Today, and his wife continue to play an important role in these young ladies’ lives.

remains connected to many of the football players after they graduate –this is the case despite Ole

Miss’s requests that disassociate himself with the University and their student-athletes. His position is

that he had a relationship with these young men well before they became prospects and he will always remain

a part of their lives. stated, “When I was forced to make a decision between my relationships with

these kids versus being able to attend Ole Miss games, I choose these kids every single time.”

has helped students secure scholarships at other colleges and universities:

It is important to look at actions as a whole and not solely in a sealed vacuum. Did

have a love and an affinity for Ole Miss? Yes. However, the evidence shows that first priority was to

help get these players exposure to any college that would provide them with an opportunity. In fact,

contacted the , on behalf, to urge them to reconsider the scholarship

offer that they rescinded. Similarly, he contacted several junior college schools on behalf

and pleaded with to take one of his junior college offers and to reconsider his choice to walk-on at

Ole Miss. Furthermore, offered to take (and in fact took) several other players to visit other

colleges such as and . According to , other members of his church and FCA
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group have often taken kids to visit various colleges. As Coach Harris has observed on numerous occasions,
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such generosity and acts of kindness are what the FCA does in the Inner-city of .2

Coach Harris’s lack of knowledge of actions:

An extremely important factor that must be considered in this matter is the extent of Coach Harris’s

knowledge of actions. The enforcement staff’s depiction of actions leads one to believe

that Coach Harris was made aware of actions or that he instructed to give impermissible

benefits to the players. Such is far from the truth. The truth is that Coach Harris did not know of

many occurrences until after Coach Harris was questioned about the occurrences during this investigation.

Specifically, Coach Harris never knew that paid cellular phone bill or mother’s

telephone bill. Coach Harris also had no knowledge that paid for and hotel rooms

the night of the bowl game. Likewise, Coach Harris vehemently disputes that he had knowledge of, or arranged

for, to stay overnight at no cost in a room that was reserved for mother. In fact, Coach

Harris was not in town at the time and arrived for check-in. Lastly, Coach Harris was never

informed that purchased any apparel for the players.

Coach Harris candidly admits that he knew that provided the players transportation

to games, and now understands that it was improper to treat similar to school staff, therefore this

transportation was improper. Coach Harris does not shy away from this mistake and has worked hard to ensure

that he is now fully informed and fully compliant with all NCAA Bylaws. However, Coach Harris completely

rejects any notion that he was a facilitator in the above- mentioned acts as described by the enforcement staff.

Mitigating Factors:

There are seven mitigating factors that should be taken into consideration. First, Coach Harris was

fully cooperative during the time of this investigation. He saved and provided all communications between him

and , no matter the content or perceptions, good or bad, which could be drawn from those

communications. Second, Coach Harris attended a NCAA Regional Rules Seminar in which he asked numerous

2 While coaching at in , Coach Harris spent a significant amount of time with FCA
leaders and their staff. These individuals like (former FCA Board Chairman), (former FCA staff
leader), and (former FCA Regional Director). During Coach Harris’s years with these men, he witnessed
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the relationship building and commitment to benevolence throughout the entire Inner-city of community.
Coach Harris observed how the FCA helped countless athletes, non-athletes, and families overcome tough ti b
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providing time as well as financial resources to those in need in their schools as well as throughout t ity of
questions and took copious notes in a genuine effort to better understand the rules to conduct himself

accordingly. Third, by far, Coach Harris is the most inquisitive and cautions staff member at the University.

He now understands and heavily relies on the University’s compliance staff for guidance on a weekly basis.

Some may look at this as overkill, but Coach Harris genuinely wants to ensure that he remains in full compliance

as he carries out his duties. Fourth, after the University’s notification that conduct of providing

transportation to the players to Ole Miss’s campus was impermissible, Coach Harris saw at

an Ole Miss baseball game with , , and . Coach Harris immediately notified

compliance of what he witnessed. Fifth, at the time in question, Coach Harris was a rookie coach in a “Power-

5 Conference.” He did not fully appreciate all of the available resources and tools at his disposal to ensure that

his actions and decisions remained in full compliance with all rules. Now, Coach Harris has taken it upon

himself to educate himself of, and use, all available tools offered by the University’s compliance department.

Sixth, these were isolated events that stemmed from a single misguided assumption that only lasted four

months. Since Coach Harris was notified that transportation of the players to campus was

improper, Coach Harris has not been involved in, or the subject of, any other NCAA investigations. This is

important as it further drives home the point that Coach Harris’s decisions were isolated and only lasted for a

short period in this single matter. His judgement call on this narrow issue was wrong, and he has paid a price

for it. This was not broad and reckless conduct that spanned over a large period of time, nor did it affect

numerous recruits. Seventh, Coach Harris was penalized and prohibited from off campus recruiting for three

weeks during the spring 2015 recruiting period. Coach Harris has truly learned a valuable lesson and is a better

person because of this process.

CONCLUSION

Coach Harris is a great man and mentor to many of the student-athletes on the University’s campus.

He places his faith, his family, and the development of the student-athletes that are entrusted to him as his top

priorities. He understands that he erred in his assessment of being able to transport the

players to campus. He accepts full responsibility for this and has worked diligently to learn and use every

resource available to him to remain fully compliant since this issue was brought to his attention. However,
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Coach Harris vehemently rejects any notion that he facilitated or encouraged other actions or dealings
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with the recruits. Lastly, Coach Harris cherishes the privilege to do what he lo and
important role in this profession and the development of student-athletes. He will continue to uphold the

integrity of the game and remain diligently committed to abiding by all NCAA rules.
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APPENDIX
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Exhibit A: Audio Recording of interview 5/19/2016
Exhibit B: Transcript of interview 5/19/2016

Exhibit C: Audio Recording of interview 5/23/2016

Exhibit D: emails

Exhibit E: email with 2016 signing day picture

Exhibit F: Pictures from

Exhibit G: home and miscellaneous personal pictures
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