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STATEMENT OF THE CASE

University of Mississippi – Case No. 00561

July 21, 2017

TABLE OF CONTENTS

I. BRIEF HISTORY (CASE CHRONOLOGY)

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II. ALLEGATION NO. 1 Saunders and Vaughn engaged in ACT exam fraud on behalf

of

of and [NCAA Division I Manual Bylaws 10.01.1, 10.1 and
of and [NCAA Division I Manual Bylaws 10.01.1, 10.1 and

and

of and [NCAA Division I Manual Bylaws 10.01.1, 10.1 and

[NCAA Division I Manual Bylaws 10.01.1, 10.1 and

10.1-(h) (2009-10); 14.1.2, 14.3.2.1, 14.3.2.1.1 and 15.01.5 (2010-11); 14.11.1 (2010- 11 through 2012-13); and 14.10.1 (2013-14)]

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III. ALLEGATION NO. 2 Saunders, Vaughn and Nix arranged for Thigpen to provide

impermissible housing, meals and transportation to

impermissible housing, meals and transportation to
impermissible housing, meals and transportation to
impermissible housing, meals and transportation to
and [NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-
and [NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-

and

and [NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-

[NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-

(c), 13.01.4, 13.1.2.1, 13.2.1, 13.2.1.1-(h) and 13.15.1 (2009-10); 14.11.1 (2010-11 through 2012-13); and 14.10.1 (2013-14)]

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IV. ALLEGATION NO. 3 Vaughn violated the cooperative principle and knowingly provided false or misleading information regarding Allegation No. 1. [NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-(d), 19.2.3 and 19.2.3.2 (2013-14)]

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V. ALLEGATION NO. 4 Saunders knowingly provided false or misleading information regarding Allegation No. 1. [NCAA Division I Manual Bylaws 10.01.1, 10.1 and 10.1- (d) (2013-14)]

9

VI. ALLEGATION NO. 5 Hughes made impermissible recruiting contact with and

provided various impermissible recruiting inducements to

 
provided various impermissible recruiting inducements to  
provided various impermissible recruiting inducements to  

and

and M. Harris knew of and at times facilitated Hughes' recruiting activities

M. Harris knew of and at times facilitated Hughes'

recruiting activities

and arranged impermissible hotel lodging for

 

and

and [NCAA

[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)]

 

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VII. ALLEGATION NO. 6 The football program produced and/or played impermissible personalized recruiting videos and did so with Freeze's knowledge and approval. [NCAA Division I Manual Bylaws 13.4.1.5 and 13.6.7.9 (2012-13)]

12

VIII. ALLEGATION NO. 7 The football program arranged impermissible hunting trips

for

for on land owned by a booster. [NCAA Division I Manual Bylaws 13.2.1 and

on land owned by a booster. [NCAA Division I Manual Bylaws 13.2.1 and

13.6.7.1 (2012-13); 16.11.2.1 (2013-14)]

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IX. ALLEGATION NO. 8 Kiffin arranged impermissible hotel lodging and meals for

family members who were not parents or legal guardians of

during his official

during his official

paid visit. [NCAA Division I Manual Bylaws 13.2.1, 13.6.7.7 and 13.6.8 (2012-13)]

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STATEMENT OF THE CASE Table of Contents Case No. 00561 July 21, 2017

X. ALLEGATION NO. 9 Kiffin arranged impermissible merchandise for

andX. ALLEGATION NO. 9 – Kiffin arranged impermissible merchandise for

 

Farrar did so for

Farrar did so for and [NCAA Division I Manual Bylaws 13.2.1,

and

Farrar did so for and [NCAA Division I Manual Bylaws 13.2.1,

[NCAA Division I Manual Bylaws 13.2.1,

13.2.1.1-(b) and 13.2.1.1-(f) (2012-13, 2013-14 or 2014-15 and 2015-16)]

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XI. ALLEGATION NO. 10 Kiffin provided impermissible lodging at his residence to

[NCAA Division I Manual Bylaw 16.11.2.1 (2012-13)]

[NCAA Division I Manual Bylaw 16.11.2.1 (2012-13)]

16

XII. ALLEGATION NO. 11 Patel provided impermissible lodging to

NO. 11 – Patel provided impermissible lodging to [NCAA Division I Manual Bylaw 16.11.2.1 (2012-13 and
NO. 11 – Patel provided impermissible lodging to [NCAA Division I Manual Bylaw 16.11.2.1 (2012-13 and

[NCAA Division I Manual Bylaw 16.11.2.1 (2012-13 and 2013-14]

and

 

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XIII. ALLEGATION NO. 12 Freeze made impermissible recruiting contact with [NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

NO. 12 – Freeze made impermissible recruiting contact with [NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

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XIV. ALLEGATION NO. 13 Kiffin made impermissible recruiting contact with

NO. 13 – Kiffin made impermissible recruiting contact with [NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

[NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

NO. 13 – Kiffin made impermissible recruiting contact with [NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

and

 

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XV. ALLEGATION NO. 14 Farrar arranged impermissible transportation and/or hotel

lodging for

lodging for and and friends and family. Additionally, the

and

lodging for and and friends and family. Additionally, the

and

lodging for and and friends and family. Additionally, the

friends and family. Additionally, the

football program provided impermissible meals to these individuals. [NCAA Division I Manual Bylaws 13.1.2.1, 13.1.2.5, 13.2.1, 13.5.3, 13.7.2.1 and 13.7.2.1.2 (2013-14 and 2014-15); and 13.6.7.7 and 13.6.8 (2014-15)]

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XVI. ALLEGATION NO. 15 L. Harris provided impermissible cash payments to

XVI. ALLEGATION NO. 15 – L. Harris provided impermissible cash payments to

and impermissible food and drinks to

and impermissible food and drinks to and his friends and family. [NCAA

and his friends and family. [NCAA

 

Division I Manual Bylaws 13.2.1 and 13.2.1.1-(e) (2013-14 and/or 2014-15)]

22

XVII. ALLEGATION NO. 16

XVII. ALLEGATION NO. 16 – and engaged in impermissible recruiting contact

and

XVII. ALLEGATION NO. 16 – and engaged in impermissible recruiting contact

engaged in impermissible recruiting contact

and communication with and provided payments. Additionally, Farrar initiated and facilitated with impermissible cash
and communication with and provided payments. Additionally, Farrar initiated and facilitated with impermissible cash

and communication with and provided payments. Additionally, Farrar initiated and facilitated

with impermissible cash

recruiting

with and provided payments. Additionally, Farrar initiated and facilitated with impermissible cash recruiting and

and

with and provided payments. Additionally, Farrar initiated and facilitated with impermissible cash recruiting and

contact and communication of

contact and communication of and knew at the time that they provided him with

and knew at the time that they provided him with

cash payments. [NCAA Division I Manual Bylaws 11.7.2.2 (2013-14); 13.1.2.1, 13.1.2.4-(a), 13.1.2.5 and 13.1.3.5.1 (2013-14 and 2014-15); 13.2.1 and 13.2.1.1-(e) (2013-14 and/or 2014-15)]

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XVIII. ALLEGATION NO. 17 Farrar knowingly committed violations of NCAA legislation and knowingly provided false or misleading information regarding Allegation Nos. 14 and 16. [NCAA Division I Manual Bylaws 10.01.1, 10.1 and 10.1-(c) (2013-14, 2014- 15 and 2016-17)]

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XIX. ALLEGATION NO. 18 Strojny provided an impermissible cash payment to

XIX. ALLEGATION NO. 18 – Strojny provided an impermissible cash payment to
[NCAA Division I Manual Bylaw 16.11.2.1 (2014-15)]

[NCAA Division I Manual Bylaw 16.11.2.1 (2014-15)]

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STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 1

I. BRIEF HISTORY (CASE CHRONOLOGY)

April 2010 – The institution hired David Saunders (Saunders) as administrative operations coordinator for football.

May and June 2010 – Saunders and Chris Vaughn (Vaughn), then assistant football coach and recruiting coordinator, engaged in fraudulence or misconduct in connection with the June 2010

ACT exams taken by then football prospective student-athletes

(
(
(
(

and

taken by then football prospective student-athletes ( ( and (Allegation No. 1). Summer of 2010 –

(Allegation No. 1).taken by then football prospective student-athletes ( ( and Summer of 2010 – Saunders, Vaughn and

Summer of 2010 – Saunders, Vaughn and Derrick Nix (Nix), assistant football coach, arranged

for then football prospective student-athletes

to live with Darel Thigpenarranged for then football prospective student-athletes (Thigpen), then representative of the institution's

(Thigpen), then representative of the institution's athletics interests, while enrolled in summer courses in Jackson, Mississippi (Allegation No. 2).

summer courses in Jackson, Mississippi (Allegation No. 2). and ( ( 2010-11 academic year – athletically

andsummer courses in Jackson, Mississippi (Allegation No. 2). ( ( 2010-11 academic year – athletically related

(
(
courses in Jackson, Mississippi (Allegation No. 2). and ( ( 2010-11 academic year – athletically related
courses in Jackson, Mississippi (Allegation No. 2). and ( ( 2010-11 academic year – athletically related
(
(

2010-11 academic year

athletically related financial aid while ineligible (Allegation Nos. 1 and 2).

financial aid while ineligible (Allegation Nos. 1 and 2). and practiced, competed and received 2011-12 through

andfinancial aid while ineligible (Allegation Nos. 1 and 2). practiced, competed and received 2011-12 through 2012-13

practiced, competed and receivedaid while ineligible (Allegation Nos. 1 and 2). and 2011-12 through 2012-13 academic years – ineligible

2011-12 through 2012-13 academic years – ineligible (Allegation Nos. 1 and 2).

academic years – ineligible (Allegation Nos. 1 and 2). and competed while December 5, 2011 –

and

competed whileyears – ineligible (Allegation Nos. 1 and 2). and December 5, 2011 – The institution hired

December 5, 2011 – The institution hired Hugh Freeze (Freeze) as head football coach.

October 2012 to March 2013 –Walter Hughes (Hughes), then representative of the institution's athletics interests, engaged in impermissible activities in recruiting then football prospective

student-athletes

and Maurice Harris (M. Harris), assistant football

coach and recruiting coordinator, facilitated Hughes' involvement and arranged free hotel

lodging for

Hughes' involvement and arranged free hotel lodging for and ( ( ( and ( (Allegation No.
Hughes' involvement and arranged free hotel lodging for and ( ( ( and ( (Allegation No.

and

(

(
(
(
(

and

and arranged free hotel lodging for and ( ( ( and ( (Allegation No. 5). October
and arranged free hotel lodging for and ( ( ( and ( (Allegation No. 5). October

(

and arranged free hotel lodging for and ( ( ( and ( (Allegation No. 5). October

(Allegation No. 5).

October 17, 2012 – The NCAA enforcement staff issued a verbal notice of inquiry to the institution in Case No. 189693 regarding potential violations in women's basketball.

January to February 2013 – The football program made impermissible recruiting videos (Allegation No. 6); the football program arranged an impermissible hunting trip for then

(Allegation No. 7); Chris Kiffinprogram arranged an impermissible hunting trip for then (Kiffin), then assistant football coach, arranged

(Kiffin), then assistant football coach, arranged impermissible hotel lodging and meals in

conjunction with then football prospective student-athlete

paid visit (Allegation No. 8); and Kiffin arranged for

to

to receive free merchandise from Rebel Rags,paid visit (Allegation No. 8); and Kiffin arranged for to LLC (Rebel Rags) (Allegation No. 9).

LLC (Rebel Rags) (Allegation No. 9).

officialfrom Rebel Rags, LLC (Rebel Rags) (Allegation No. 9). football prospective student-athlete ( then boyfriend mother,

football prospective student-athlete

Rebel Rags, LLC (Rebel Rags) (Allegation No. 9). official football prospective student-athlete ( then boyfriend mother,
Rebel Rags, LLC (Rebel Rags) (Allegation No. 9). official football prospective student-athlete ( then boyfriend mother,
Rebel Rags, LLC (Rebel Rags) (Allegation No. 9). official football prospective student-athlete ( then boyfriend mother,
(
(
Rebel Rags, LLC (Rebel Rags) (Allegation No. 9). official football prospective student-athlete ( then boyfriend mother,

then boyfriend

Rebel Rags, LLC (Rebel Rags) (Allegation No. 9). official football prospective student-athlete ( then boyfriend mother,

mother,

Rebel Rags, LLC (Rebel Rags) (Allegation No. 9). official football prospective student-athlete ( then boyfriend mother,

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 2

February 2013 – The enforcement staff's investigation expanded into football.

February to August 2013 – The institution and enforcement staff investigated issues detailed in Allegation Nos. 5, 6 and 8.

March to May 2013, July to August 2015, February to March 2016, August 2016 to January 2017 – The enforcement staff and institution investigated issues detailed in Allegation No. 9.

Summer 2013 – Kiffin provided impermissible lodging to

(Allegation No. 10).9. Summer 2013 – Kiffin provided impermissible lodging to June 2013 to May 2014 – Chan

June 2013 to May 2014 – Chan Patel (Patel), then representative of the institution's athletics

interests, provided impermissible lodging to

athletics interests, provided impermissible lodging to and (Allegation No. 11). August 2013 to December 2014 –

and

(Allegation No. 11).athletics interests, provided impermissible lodging to and August 2013 to December 2014 – The enforcement staff

August 2013 to December 2014 – The enforcement staff and institution investigated issues detailed in Allegation Nos. 1 through 4.

August 14 to 31, 2013 – Vaughn communicated with individuals with knowledge of pertinent facts of the enforcement staff's investigation (Allegation No. 3).

2013-14 academic year

investigation (Allegation No. 3). 2013-14 academic year – competed while ineligible (Allegation No. 1). December 3,

competed while ineligible (Allegation No. 1).

December 3, 2013 – Freeze made impermissible, in-person recruiting contact with then football

prospective student-athlete

(
(

(Allegation No. 12).

December 16, 2013, and February 25, 2014 – Saunders knowingly provided false or misleading information to the enforcement staff and institution during interviews (Allegation No. 4).

December 17, 2013 – Vaughn knowingly provided false or misleading information to the enforcement staff and institution during an interview (Allegation No. 3).

December 2013 to January 2014 – The football program arranged impermissible hunting trips

on land owned by a booster for then football student-athlete

on land owned by a booster for then football student-athlete March 2014 to February 2015 –Barney

March 2014 to February 2015 –Barney Farrar (Farrar), then assistant director for high school

and junior college relations, arranged for

(Allegation No. 9); Farrar arranged impermissible recruiting inducements for then football

friends and family

(Allegation Nos. 14 and 17); Farrar initiated and facilitated impermissible recruiting contact of

prospective student-athlete

recruiting contact of prospective student-athlete to receive free merchandise from Rebel Rags and/or ( , then

to receive free merchandise from Rebel Rags

and/or

to receive free merchandise from Rebel Rags and/or ( , then representatives of the institution's athletics
to receive free merchandise from Rebel Rags and/or ( , then representatives of the institution's athletics
(
(
to receive free merchandise from Rebel Rags and/or ( , then representatives of the institution's athletics

, then representatives of the institution's

athletics interests, and knew

Nos. 14, 16 and 17); and (4) Lee Harris (L. Harris), then representative of the institutions

with cash payments (Allegation

by

and (4) Lee Harris (L. Harris), then representative of the institutions with cash payments (Allegation by

and

and (4) Lee Harris (L. Harris), then representative of the institutions with cash payments (Allegation by
and (4) Lee Harris (L. Harris), then representative of the institutions with cash payments (Allegation by

and

and (4) Lee Harris (L. Harris), then representative of the institutions with cash payments (Allegation by

provided

and (4) Lee Harris (L. Harris), then representative of the institutions with cash payments (Allegation by

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 3

athletics interests, provided

family with free food and drinks (Allegation No. 15).

with cash payments and providedfamily with free food and drinks (Allegation No. 15). and his friends and May 8, 2014

drinks (Allegation No. 15). with cash payments and provided and his friends and May 8, 2014

and his friends and

May 8, 2014 – Kiffin made impermissible, in-person recruiting contact with then football

(Allegation No.

prospective student-athletes

(
(

and

(
(

13).

August 22, 2014 – Michael Strojny (Strojny), then representative of the institution's athletics

interests, provided $800 cash to

institution's athletics interests, provided $800 cash to (Allegation No. 18). August 2014 to August 2015 –

(Allegation No. 18).

August 2014 to August 2015 – Cannon Motor Company (Cannon Motors), then representative

and football

student-athlete

Motors and Michael Joe Cannon (Cannon), owner of Cannon Motors and then representative

of the institution's athletics interests, provided No. 19).

of the institution's athletics interests, provided then football student-athlete

impermissible loaner vehicles. Additionally, Cannon

impermissible loaner vehicles. Additionally, Cannon ( an impermissible $3,000 loan (Allegation October to
impermissible loaner vehicles. Additionally, Cannon ( an impermissible $3,000 loan (Allegation October to
(
(
impermissible loaner vehicles. Additionally, Cannon ( an impermissible $3,000 loan (Allegation October to December

an impermissible $3,000 loan (Allegation

October to December 2014 – The enforcement staff and institution investigated issues detailed in Allegation No. 13.

October 25 to December 31, 2014 – (Allegation No. 19).

October 25 to December 31, 2014 – (Allegation No. 19). competed in six contests while ineligible

competed in six contests while ineligible

July 1, 2015 –

competed in six contests while ineligible July 1, 2015 – reported to the NCAA potential violations

reported to the NCAA potential violations involving

2015 – reported to the NCAA potential violations involving July to September 2015 – The enforcement

July to September 2015 – The enforcement staff and institution investigated issues detailed in Allegation Nos. 9, 10, 11, 18 and 19.

September 2015 to January 31, 2016 – Farrar arranged for then football prospective student-

to receive free merchandise from Rebel Rags (Allegation No. 9).– Farrar arranged for then football prospective student- athlete January 22, 2016 – The enforcement staff

athlete

free merchandise from Rebel Rags (Allegation No. 9). athlete January 22, 2016 – The enforcement staff

January 22, 2016 – The enforcement staff issued a notice of allegations in Case No. 189693.

March 17, 2016 – The enforcement staff issued a verbal notice of inquiry to the institution in Case No. 00561.

April 2016 – The enforcement staff's football development group began receiving information of additional potential violations in football.

April 28, 2016 – Information surfaced regarding potential additional violations involving

that the enforcement staff and institution required additional time to investigate.

additional violations involving that the enforcement staff and institution required additional time to investigate.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 4

June 2, 2016 – The NCAA Division I Committee on Infractions bifurcated Case No. 189693, severing the women's basketball and track and field portions of the case from the football portion of the case.

June 8, 2016 – The enforcement staff issued a revised notice of allegations in Case No. 189693 that contained only the women's basketball and track and field allegations.

July 25, 2016 – The Committee on Infractions heard Case No. 189693.

Late July 2016 – The enforcement staff's football development group provided the investigative

team information of potential additional violations, including

information of potential additional violations, including and August 2016 to February 2017 – The enforcement staff

and

of potential additional violations, including and August 2016 to February 2017 – The enforcement staff and

August 2016 to February 2017 – The enforcement staff and institution investigated issues detailed in Allegation Nos. 7, 9, 12 and 14 through 17.

December 1, 2016 – Farrar knowingly provided false or misleading information to the enforcement staff and institution (Allegation No. 17).

December 21, 2016 – Representatives from the institution and Southeastern Conference visited the NCAA national office for a pre-notice of allegations conference.

February 22, 2017 – The enforcement staff issued a notice of allegations in Case No. 00561.

May 23, 2017 – The institution, Farrar, Freeze, M. Harris, Kiffin and Nix submitted their responses to the notice of allegations.

June 1, 2017 – Vaughn submitted his response to the notice of allegations.

June 19, 2017 – The enforcement staff conducted a prehearing conference with the institution.

June 23, 2017 – The enforcement staff conducted a prehearing conference with Freeze.

June 28, 2017 – The enforcement staff conducted a prehearing conference with Vaughn.

July 5, 2017 – The enforcement staff conducted a prehearing conference with M. Harris.

July 6, 2017 – The enforcement staff conducted prehearing conferences with Nix and Farrar.

July 12, 2017 – The enforcement staff conducted prehearing conferences with Kiffin and Saunders.

July 21, 2017 – The enforcement staff submitted its reply and statement of the case.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 5

II. ALLEGATION NO. 1 – Saunders and Vaughn violated the principles of ethical conduct when they engaged in fraudulence or misconduct in connection with the June 2010 ACT

exams of

and 10.1-(h) (2009-10); 14.1.2, 14.3.2.1, 14.3.2.1.1 and 15.01.5 (2010-11); 14.11.1 (2010-11 through 2012-13); and 14.10.1 (2013-14)]

[NCAA Division I Manual Bylaws 10.01.1, 10.1

(2013-14)] [NCAA Division I Manual Bylaws 10.01.1, 10.1 and Alleged Level of Allegation No. 1: Severe
(2013-14)] [NCAA Division I Manual Bylaws 10.01.1, 10.1 and Alleged Level of Allegation No. 1: Severe

and

(2013-14)] [NCAA Division I Manual Bylaws 10.01.1, 10.1 and Alleged Level of Allegation No. 1: Severe

Alleged Level of Allegation No. 1: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level I.

B. Position of Saunders.

1. Position on the allegation.

Saunders did not submit a response to the notice of allegations, but denied knowledge of and/or

involvement in the alleged violations in his two interviews.

2. Position on the level of the violation.

Saunders did not address the level.

C. Position of Vaughn.

1. Position on the allegation.

Vaughn denies knowledge of and/or involvement in the alleged violations.

2. Position on the level of the violation.

Vaughn did not address the level.

D. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 7

B. Position of Saunders.

1. Position on the allegation.

Saunders did not submit a response to the notice of allegations but denied knowledge of and/or

involvement in the alleged violations in his two interviews.

2. Position on the level of the violation.

Saunders did not address the level.

C. Position of Vaughn.

1. Position on the allegation.

Vaughn denies knowledge of and/or involvement in the alleged violations.

2. Position on the level of the violation.

Vaughn did not address the level.

D. Position of Nix.

1. Position on the allegation.

Nix denies knowledge of and/or involvement in the alleged violations.

2. Position on the level of the violation.

Nix asserts that if he committed a violation, his culpability should be considered Level III.

E. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 2 is a severe breach

of conduct (Level I).

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 8

F. Remaining issues in Allegation No. 2.

1. Did Saunders knowingly arrange for Thigpen to provide free housing, meals and

transportation to

Thigpen to provide free housing, meals and transportation to and 2. Did Vaughn knowingly arrange for

and

to provide free housing, meals and transportation to and 2. Did Vaughn knowingly arrange for Thigpen

2. Did Vaughn knowingly arrange for Thigpen to provide free housing, meals and

transportation to

Thigpen to provide free housing, meals and transportation to and 3. Did Nix assist in arranging

andThigpen to provide free housing, meals and transportation to 3. Did Nix assist in arranging for

to provide free housing, meals and transportation to and 3. Did Nix assist in arranging for

3. Did Nix assist in arranging for Thigpen to provide free housing, meals and

transportation to

Thigpen to provide free housing, meals and transportation to 4. What is the level of the

4. What is the level of the alleged violations?

5. If the panel concludes Nix is culpable for violations, what is the level of his culpability?

6. Are the violations impermissible recruiting inducements or preferential treatment?

IV. ALLEGATION NO. 3 – Vaughn violated the cooperative principle when he communicated with individuals with knowledge of pertinent facts regarding the enforcement staff's investigation after being admonished multiple times to refrain from doing so. Additionally, Vaughn violated the principles of ethical conduct when he knowingly provided false or misleading information during his December 17, 2013, interview regarding Allegation No. 1. [NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1- (d), 19.2.3 and 19.2.3.2 (2013-14)]

Alleged Level of Allegation No. 3: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution did not take a position regarding the alleged violations.

2. Position on the level of the violation.

The institution did not address the level.

B. Position of Vaughn.

1. Position on the allegation.

Vaughn denies knowledge of and/or involvement in the alleged violations.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 9

2. Position on the level of the violation.

Vaughn did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 3 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 3.

1. Did Vaughn violate the NCAA cooperative principle when he communicated with

individuals with knowledge of pertinent facts regarding the investigation after being

admonished multiple times to refrain from doing so?

2. Did Vaughn knowingly provide false or misleading information in his December 2013

interview when he denied knowledge of and/or involvement in the violations detailed

in Allegation No. 1?

V. ALLEGATION NO. 4 – Saunders violated the principles of ethical conduct when he knowingly provided false or misleading information during his December 16, 2013, and February 25, 2014, interviews regarding Allegation No. 1. [NCAA Division I Manual Bylaws 10.01.1, 10.1 and 10.1-(d) (2013-14)]

Alleged Level of Allegation No. 4: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution did not take a position regarding the alleged violations.

2. Position on the level of the violation.

The institution did not address the level.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 10

B. Position of Saunders.

1. Position on the allegation.

Saunders did not submit a response to the notice of allegations, but denied knowledge of and/or

involvement in the alleged violations in his two interviews.

2. Position on the level of the violation.

Saunders did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 4 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 4.

Did Saunders knowingly provide false or misleading information in his December 2013 and February

2014 interviews when he denied knowledge of and/or involvement in the violations detailed in Allegation

No. 1?

VI.

ALLEGATION NO. 5 – Hughes made impermissible recruiting contact with, and

provided

impermissible recruiting inducements to,

 
provided impermissible recruiting inducements to,   and
provided impermissible recruiting inducements to,   and

and

Additionally, M. Harris knew of Hughes' association to the four prospects and

Additionally, M. Harris knew of Hughes' association to the four prospects and

at times facilitated Hughes' recruiting activities. M. Harris also arranged impermissible

[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)]

hotel lodging for

13.5.3, 13.7.2.1 and 13.7.2.1.2 (2012-13)] hotel lodging for and Alleged Level of Allegation No. 5: Severe

and

13.7.2.1 and 13.7.2.1.2 (2012-13)] hotel lodging for and Alleged Level of Allegation No. 5: Severe Breach

Alleged Level of Allegation No. 5: Severe Breach of Conduct (Level I Violation).

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 11

A. Position of institution.

1. Position on the allegation.

The institution generally agrees the facts are substantially correct and violations of NCAA legislation

occurred. However, it disputes certain facts detailed in Allegation Nos. 5-e, 5-h, 5-j, 5-m and 5-o.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level I.

B. Position of M. Harris.

1. Position on the allegation.

M. Harris denies facilitating Hughes' involvement in the four prospects' recruitment or knowing at the

time that Hughes was providing them with impermissible inducements. M. Harris also incorporates the

institution's disagreements regarding Allegation Nos. 5-e, 5-h, 5-j, 5-m and 5-o.

2. Position on the level of the violation.

M. Harris believes his culpability for the alleged violations is not Level I.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 5 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 5.

1. Did M. Harris facilitate Hughes' involvement in the football program's recruitment of

in Allegation No. 5. 1. Did M. Harris facilitate Hughes' involvement in the football program's recruitment
in Allegation No. 5. 1. Did M. Harris facilitate Hughes' involvement in the football program's recruitment

and

in Allegation No. 5. 1. Did M. Harris facilitate Hughes' involvement in the football program's recruitment

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 12

2. Did Hughes' presence for a portion of

Page No. 12 2. Did Hughes' presence for a portion of in-home recruiting visit by Freeze

in-home recruiting visit by Freeze and

M. Harris, as detailed in Allegation No. 5-e, constitute a violation?

3. Did M. Harris arrange impermissible recruiting contact of

3. Did M. Harris arrange impermissible recruiting contact of and by T. Scott and other football

and

M. Harris arrange impermissible recruiting contact of and by T. Scott and other football staff as

by

T. Scott and other football staff as detailed in Allegation No. 5-h? Relatedly, did M.

Harris know at the time the contact had occurred?

4. Did M. Harris arrange for

time the contact had occurred? 4. Did M. Harris arrange for institution provided for and to

institution provided

occurred? 4. Did M. Harris arrange for institution provided for and to stay in a hotel

for

4. Did M. Harris arrange for institution provided for and to stay in a hotel room

and

4. Did M. Harris arrange for institution provided for and to stay in a hotel room

to stay

in a hotel room the

official paid visit as detailed in Allegation No.

5-j? Relatedly, was

on an official paid visit or unofficial visit on thispaid visit as detailed in Allegation No. 5-j? Relatedly, was occasion? 5. Did M. Harris arrange

occasion?

5. Did M. Harris arrange for

visit on this occasion? 5. Did M. Harris arrange for to stay in a hotel room

to stay in a hotel room the institution provided

to

for to stay in a hotel room the institution provided to family for official paid visit

family for

official paid visit as detailed in Allegation No. 5-m?stay in a hotel room the institution provided to family for 6. Did Freeze know at

6. Did Freeze know at the time that Hughes and/or Hughes' family was providing

the time that Hughes and/or Hughes' family was providing academic tutoring assistance as detailed in Allegation

academic tutoring assistance as detailed in Allegation No. 5-o?

7. If the hearing panel concludes M. Harris is culpable for violations, what is the level of

his culpability?

VII. ALLEGATION NO. 6 – The football program produced and/or played impermissible personalized recruiting videos on three occasions and did so with Freeze's knowledge and approval. [NCAA Division I Manual Bylaws 13.4.1.5 and 13.6.7.9 (2012-13)]

Alleged Level of Allegation No. 6: Breach of Conduct (Level III violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

However, it asserts Freeze has no culpability for the violations and naming him was unfairly prejudicial

and procedurally improper.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 13

2. Position on the level of the violation.

The institution agrees the alleged violations are Level III.

B. Position of Freeze.

1. Position on the allegation.

Freeze agrees the facts are substantially correct and violations occurred but disagrees he is culpable.

2. Position on the level of the violation.

Freeze agrees the alleged violations are Level III.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 6 is a breach of

conduct (Level III).

D. Remaining issues in Allegation No. 6.

Does the factual information substantiate culpability by Freeze for these violations?

VIII. ALLEGATION NO. 7 – The football program arranged impermissible hunting trips for

on land owned by a booster. [NCAA Division I Manual Bylaws 13.2.1 and 13.6.7.1

booster. [NCAA Division I Manual Bylaws 13.2.1 and 13.6.7.1 (2012-13); 16.11.2.1 (2013-14)] Alleged Level of Allegation

(2012-13); 16.11.2.1 (2013-14)]

Alleged Level of Allegation No. 7: Breach of Conduct (Level III).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 14

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 7 is a breach of

conduct (Level III).

C. Remaining issues in Allegation No. 7.

None.

IX.

ALLEGATION NO. 8 – Kiffin arranged impermissible

hotel lodging and meals for family

members who were not parents or legal guardians of Bylaws 13.2.1, 13.6.7.7 and 13.6.8 (2012-13)]

members who were not parents or legal guardians of Bylaws 13.2.1, 13.6.7.7 and 13.6.8 (2012-13)] [NCAA

[NCAA Division I Manual

Alleged Level of Allegation No. 8: Significant Breach of Conduct (Level II Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution believes the alleged violations are Level III.

B. Position of Kiffin.

1. Position on the allegation.

Kiffin agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

Kiffin believes the alleged violations are Level III.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 15

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 8 is a significant

breach of conduct (Level II).

D. Remaining issues in Allegation No. 8.

What is the level of the alleged violations?

X. ALLEGATION NO. 9 – Kiffin arranged free merchandise from Rebel Rags for

and Farrar did so for

13.2.1.1-(b) and 13.2.1.1-(f) (2012-13, 2013-14 or 2014-15 and 2015-16)]

and 13.2.1.1-(f) (2012-13, 2013-14 or 2014-15 and 2015-16)] and [NCAA Division I Manual Bylaws 13.2.1, Alleged

and

13.2.1.1-(f) (2012-13, 2013-14 or 2014-15 and 2015-16)] and [NCAA Division I Manual Bylaws 13.2.1, Alleged Level
13.2.1.1-(f) (2012-13, 2013-14 or 2014-15 and 2015-16)] and [NCAA Division I Manual Bylaws 13.2.1, Alleged Level

[NCAA Division I Manual Bylaws 13.2.1,

Alleged Level of Allegation No. 9: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution disagrees the facts are substantially correct or violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution did not address the level.

B. Position of Farrar.

1. Position on the allegation.

Farrar denies knowledge of and/or involvement in this allegation.

2. Position on the level of the violation.

Farrar did not address the level.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 16

C. Position of Kiffin.

1. Position on the allegation.

Kiffin denies knowledge of and/or involvement in this allegation.

2. Position on the level of the violation.

Kiffin did not address the level.

D. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude Allegation No. 9 is a severe breach of

conduct (Level I).

E. Remaining issues in Allegation No. 9.

1. Did Kiffin arrange for

issues in Allegation No. 9. 1. Did Kiffin arrange for to receive approximately $400 worth of

to receive approximately $400 worth of free

merchandise from Rebel Rags during

$400 worth of free merchandise from Rebel Rags during January 2013 official paid visit? 2. Did

January 2013 official paid visit?

2. Did Farrar arrange for

January 2013 official paid visit? 2. Did Farrar arrange for to receive approximately $400 worth of

to receive approximately $400 worth of free merchandise

from Rebel Rags during a recruiting visit to the institution between March 28, 2014,

and January 25, 2015?

3. Did Farrar arrange for

28, 2014, and January 25, 2015? 3. Did Farrar arrange for to receive approximately $2,000 worth

to receive approximately $2,000 worth of free

merchandise from Rebel Rags over four recruiting visits to the institution between

September 4, 2015, and January 31, 2016?

XI. ALLEGATION NO. 10 – Kiffin provided impermissible lodging at his residence to

Kiffin provided impermissible lodging at his residence to [NCAA Division I Manual Bylaw 16.11.2.1 (2012-13)] Alleged

[NCAA Division I Manual Bylaw 16.11.2.1 (2012-13)]

Alleged Level of Allegation No. 10: Breach of Conduct (Level III).

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 17

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and a violation of NCAA legislation occurred.

2. Position on the level of the violation.

The institution agrees the alleged violation is Level III.

B. Position of Kiffin.

1. Position on the allegation.

Kiffin agrees the facts are substantially correct and a violation of NCAA legislation occurred.

2. Position on the level of the violation.

Kiffin agrees the alleged violation is Level III.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violation occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 10 is a breach of

conduct (Level III).

D. Remaining issues in Allegation No. 10.

None.

XII.

ALLEGATION NO. 11 – Patel provided impermissible lodging to [NCAA Division I Manual Bylaw 16.11.2.1 (2012-13 and 2013-14)]

NO. 11 – Patel provided impermissible lodging to [NCAA Division I Manual Bylaw 16.11.2.1 (2012-13 and

and

I Manual Bylaw 16.11.2.1 (2012-13 and 2013-14)] and Alleged Level of Allegation No. 11: Severe Breach

Alleged Level of Allegation No. 11: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 18

2. Position on the level of the violation.

The institution agrees the alleged violations are Level I.

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 11 is a severe breach

of conduct (Level I).

C. Remaining issues in Allegation No. 11.

None.

XIII.

ALLEGATION NO. 12 – Freeze made impermissible in-person, off-campus recruiting

contact with

contact with [NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

[NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

Alleged Level of Allegation No. 12: Breach of Conduct (Level III).

A. Position of institution.

1. Position on the allegation.

The institution disagrees the facts are substantially correct or that a violation of NCAA legislation

occurred.

2. Position on the level of the violation.

The institution did not address the level.

B. Position of Freeze.

1. Position on the allegation.

Freeze disagrees the facts are substantially correct or a violation of NCAA legislation occurred.

2. Position on the level of the violation.

Freeze did not address the level.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 19

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude Allegation No. 12 is a breach of conduct

(Level III).

D. Remaining issues in Allegation No. 12.

Did Freeze have impermissible in-person, off-campus recruiting contact with

impermissible in-person, off-campus recruiting contact with December 3, 2013? at XIV. ALLEGATION NO. 13 – Kiffin

December 3, 2013?

off-campus recruiting contact with December 3, 2013? at XIV. ALLEGATION NO. 13 – Kiffin made impermissible

at

off-campus recruiting contact with December 3, 2013? at XIV. ALLEGATION NO. 13 – Kiffin made impermissible

XIV. ALLEGATION NO. 13 – Kiffin made impermissible in-person, off-campus recruiting

contact with

impermissible in-person, off-campus recruiting contact with and [NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

and

in-person, off-campus recruiting contact with and [NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)] Alleged

[NCAA Division I Manual Bylaw 13.1.1.1 (2013-14)]

Alleged Level of Allegation No. 13: Breach of Conduct (Level III).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level III.

B. Position of Kiffin.

1. Position on the allegation.

Kiffin agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

Kiffin agrees the alleged violations are Level III.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 20

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 13 is a breach of

conduct (Level III).

D. Remaining issues in Allegation No. 13.

None.

XV.

ALLEGATION NO. 14 – Farrar arranged impermissible transportation and/or hotel

lodging for

lodging for and friends and family. Additionally, the football
lodging for and friends and family. Additionally, the football

and

lodging for and friends and family. Additionally, the football

friends and family. Additionally, the football

program provided these individuals with impermissible meals. [NCAA Division I Manual Bylaws 13.1.2.1, 13.1.2.5, 13.2.1, 13.5.3, 13.7.2.1 and 13.7.2.1.2 (2013-14 and 2014-15); and 13.6.7.7 and 13.6.8 (2014-15)]

Alleged Level of Allegation No. 14: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The enforcement staff and institution agree the facts regarding Allegation Nos. 14-a through 14-d, 14-

h and 14-i are substantially correct and violations of NCAA legislation occurred. The institution disagrees

with the facts regarding Allegation Nos. 14-e, 14-f and 14-g.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level I.

B. Position of Farrar.

1. Position on the allegation.

Farrar agrees the facts regarding Allegation Nos. 14-b and 14-d concerning transportation are

substantially correct and violations occurred as well as acknowledges responsibility for the portions of

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 21

Allegation No. 14 concerning meals. However, Farrar disagrees with the facts regarding Allegation No. 14-

c concerning transportation and Allegation Nos. 14-d through 14-i concerning hotel lodging.

2. Position on the level of the violation.

Farrar did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 14 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 14.

1. Did Farrar arrange free transportation for

in conjunction with a summer footballNo. 14. 1. Did Farrar arrange free transportation for camp as detailed in Allegation No. 14-b?

camp as detailed in Allegation No. 14-b?

2. Did Farrar arrange free transportation for

in conjunction with a summer footballNo. 14-b? 2. Did Farrar arrange free transportation for camp as detailed in Allegation No. 14-c?

camp as detailed in Allegation No. 14-c?

3. Did Farrar arrange free transportation and hotel lodging for

Did Farrar arrange free transportation and hotel lodging for and as detailed in Allegation No. 14-d?

and

Farrar arrange free transportation and hotel lodging for and as detailed in Allegation No. 14-d? Relatedly,

as

detailed in Allegation No. 14-d? Relatedly, did Farrar arrange free transportation for

14-d? Relatedly, did Farrar arrange free transportation for on this occasion? 4. Did Farrar arrange free

on this occasion?

4. Did Farrar arrange free hotel lodging for

this occasion? 4. Did Farrar arrange free hotel lodging for and in conjunction with an unofficial

and

occasion? 4. Did Farrar arrange free hotel lodging for and in conjunction with an unofficial visit

in conjunction with an

unofficial visit as detailed in Allegation No. 14-e? Relatedly, did the football program

provide

as detailed in Allegation No. 14-e? Relatedly, did the football program provide and with free meals

and

as detailed in Allegation No. 14-e? Relatedly, did the football program provide and with free meals

with free meals on this occasion?

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 22

5. Did Farrar arrange free hotel lodging for

Page No. 22 5. Did Farrar arrange free hotel lodging for and in conjunction with an

and

in conjunction with anPage No. 22 5. Did Farrar arrange free hotel lodging for and unofficial visit as detailed

unofficial visit as detailed in Allegation No. 14-f? Relatedly, did the football program

provide

No. 14-f? Relatedly, did the football program provide and with free meals on this occasion? 6.

and

with free meals on this occasion?No. 14-f? Relatedly, did the football program provide and 6. Did Farrar arrange free hotel lodging

6. Did Farrar arrange free hotel lodging for

andthis occasion? 6. Did Farrar arrange free hotel lodging for in conjunction with an unofficial visit

in conjunction with anoccasion? 6. Did Farrar arrange free hotel lodging for and unofficial visit as detailed in Allegation

unofficial visit as detailed in Allegation No. 14-g? Relatedly, did the football program

provide

No. 14-g? Relatedly, did the football program provide and with free meals on this occasion? 7.

and

with free meals on this occasion?No. 14-g? Relatedly, did the football program provide and 7. Did Farrar arrange free hotel lodging

7. Did Farrar arrange free hotel lodging for

this occasion? 7. Did Farrar arrange free hotel lodging for and in conjunction with an unofficial

and

occasion? 7. Did Farrar arrange free hotel lodging for and in conjunction with an unofficial visit

in

conjunction with an unofficial visit as detailed in Allegation No. 14-h?

8. Did Farrar arrange free hotel lodging for

No. 14-h? 8. Did Farrar arrange free hotel lodging for during official paid visit as detailed

during

14-h? 8. Did Farrar arrange free hotel lodging for during official paid visit as detailed in

official paid visit as

detailed in Allegation No. 14-i?

XVI. ALLEGATION NO. 15 – L. Harris provided impermissible cash payments to

free food and drinks to

impermissible cash payments to free food and drinks to and and his friends and family. [NCAA

and

and his friends and family. [NCAA Division I Manual Bylaws

and his friends and family. [NCAA Division I Manual Bylaws 13.2.1 and 13.2.1.1-(e) (2013-14 and/or 2014-15)]

13.2.1 and 13.2.1.1-(e) (2013-14 and/or 2014-15)]

Alleged Level of Allegation No. 15: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees

1. Position on the allegation . The institution agrees and L. Harris had an in-person and

and L. Harris had an in-person and telephone contact during his

recruitment. The institution also agrees

contact during his recruitment. The institution also agrees and his companions received free food and drinks

and his companions received free food and drinks from L.

Harris' restaurant and bar on at least one occasion. However, the institution does not believe the facts

substantiate L. Harris provided the food and drinks or cash payments to

2. Position on the level of the violation.

The institution did not address the level.

payments to 2. Position on the level of the violation . The institution did not address

and/or his companions.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 23

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 15 is a severe breach

of conduct (Level I).

C. Remaining issues in Allegation No. 15.

Did L. Harris provide between $200 and $600 in impermissible cash payments to

on two or threebetween $200 and $600 in impermissible cash payments to occasions between March 28, 2014, and January

occasions between March 28, 2014, and January 25, 2015? Relatedly, did L. Harris provide

and his2014, and January 25, 2015? Relatedly, did L. Harris provide companions with free food and drinks

companions with free food and drinks on these occasions?

XVII.

ALLEGATION NO. 16 –

ALLEGATION NO. 16 –

and

made impermissible recruiting contact with,

made impermissible recruiting contact with,

and provided impermissible cash payments totaling between $13,000 and $15,600 to

Additionally, Farrar initiated and facilitated and knew at the time recruiting contact with

Additionally, Farrar initiated and facilitated

Additionally, Farrar initiated and facilitated and knew at the time recruiting contact with

and knew at the time

Additionally, Farrar initiated and facilitated and knew at the time recruiting contact with
Additionally, Farrar initiated and facilitated and knew at the time recruiting contact with

recruiting contact with

and

and

and and
and and

impermissible

provided cash

payments. [NCAA Division I Manual Bylaws 11.7.2.2 (2013-14); 13.1.2.1, 13.1.2.4-(a), 13.1.2.5 and 13.1.3.5.1 (2013-14 and 2014-15); 13.2.1 and 13.2.1.1-(e) (2013-14 and/or 2014-

15)]

Alleged Level of Allegation No. 16: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts regarding Farrar initiating and facilitating

the facts regarding Farrar initiating and facilitating and impermissible recruiting contact with are substantially

and

the facts regarding Farrar initiating and facilitating and impermissible recruiting contact with are substantially

impermissible recruiting contact with

and facilitating and impermissible recruiting contact with are substantially correct and that violations of NCAA

are substantially correct and that violations of NCAA

legislation occurred. However, the institution disagrees that the facts concerning

However, the institution disagrees that the facts concerning and alleged provision of cash payments to are

and

allegedthe institution disagrees that the facts concerning and provision of cash payments to are substantially correct

provision of cash payments to

that the facts concerning and alleged provision of cash payments to are substantially correct or that

are substantially correct or that violations occurred.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 24

2. Position on the level of the violation.

The institution believes the violations concerning

of

. The institution believes the violations concerning of are Level II. B. Position of Farrar. 1.

are Level II.

B. Position of Farrar.

1. Position on the allegation.

II. B. Position of Farrar. 1. Position on the allegation . and impermissible recruiting contact Farrar

and

B. Position of Farrar. 1. Position on the allegation . and impermissible recruiting contact Farrar denies

impermissible recruiting contact

Farrar denies knowledge of and/or involvement in the alleged violations.

2. Position on the level of the violation.

Farrar did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 16 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 16.

1. Did Farrar initiate and facilitate

in Allegation No. 16. 1. Did Farrar initiate and facilitate and impermissible recruiting contact of 2.

and

Allegation No. 16. 1. Did Farrar initiate and facilitate and impermissible recruiting contact of 2. Did

impermissible recruiting contact of

2. Did
2. Did

and

and impermissible recruiting contact of 2. Did and provide between $13,000 and $15,600 in impermissible cash

provide

and impermissible recruiting contact of 2. Did and provide between $13,000 and $15,600 in impermissible cash

between $13,000 and $15,600 in impermissible

cash payments? If so, did Farrar know at the time

cash payments? If so, did Farrar know at the time and provided the payments? 3. What

and

cash payments? If so, did Farrar know at the time and provided the payments? 3. What

provided the

payments?

3. What is the level of the alleged violations?

XVIII. ALLEGATION NO. 17 – Farrar violated the principles of ethical conduct when he knowingly committed violations of NCAA legislation and knowingly provided false or misleading information regarding Allegation Nos. 14 and 16. [NCAA Division I Manual Bylaws 10.01.1, 10.1 and 10.1-(c) (2013-14, 2014-15 and 2016-17)]

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 25

Alleged Level of Allegation No. 17: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts regarding Allegation Nos. 17-a, 17-c and 17-d are substantially correct

and that violations of NCAA legislation occurred. Additionally, the institution agrees the facts regarding

Allegation Nos. 17-b and 17-e, aside from the facts concerning impermissible cash payments, are

substantially correct and that violations occurred.

2. Position on the level of the violation.

The institution agrees the violations are Level I despite its disagreement regarding certain alleged facts.

B. Position of Farrar.

1. Position on the allegation.

Farrar denies knowledge of and/or involvement in the alleged violations.

2. Position on the level of the violation.

Farrar did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 17 is a severe breach

of conduct (Level I).

D. Remaining issues in Allegation No. 17.

1. Did Farrar knowingly arrange impermissible transportation and/or hotel lodging for

issues in Allegation No. 17. 1. Did Farrar knowingly arrange impermissible transportation and/or hotel lodging for

and

issues in Allegation No. 17. 1. Did Farrar knowingly arrange impermissible transportation and/or hotel lodging for
issues in Allegation No. 17. 1. Did Farrar knowingly arrange impermissible transportation and/or hotel lodging for

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 26

2. Did Farrar knowingly provide false or misleading information when he denied

knowledge of and/or involvement in arranging impermissible transportation for

involvement in arranging impermissible transportation for in conjunction with recruiting visits to the institution,

in conjunction with recruiting visits to the institution, including visits in June, July and

August 2014?

3. Did Farrar knowingly provide false or misleading information when he denied

knowledge of and/or involvement in arranging free hotel lodging for

of and/or involvement in arranging free hotel lodging for in conjunction with six unofficial visits to

in

conjunction with six unofficial visits to the institution between August 15 and

November 30, 2014?

4. Did Farrar knowingly initiate and facilitate impermissible recruiting contact and

communication of

byimpermissible recruiting contact and communication of and 5. Did Farrar know at the time that and

andimpermissible recruiting contact and communication of by 5. Did Farrar know at the time that and

impermissible recruiting contact and communication of by and 5. Did Farrar know at the time that

5. Did Farrar know at the time that

communication of by and 5. Did Farrar know at the time that and cash payments? provided

and

of by and 5. Did Farrar know at the time that and cash payments? provided with

cash payments?

provided

with impermissibleDid Farrar know at the time that and cash payments? provided 6. Did Farrar knowingly provide

6. Did Farrar knowingly provide false or misleading information when he denied

knowledge of and/or involvement in (1) arranging impermissible recruiting contact and

communication of

byimpermissible recruiting contact and communication of and and (2) and providing with impermissible cash payments?

andimpermissible recruiting contact and communication of by and (2) and providing with impermissible cash payments? XIX.

and (2)impermissible recruiting contact and communication of by and and providing with impermissible cash payments? XIX.

recruiting contact and communication of by and and (2) and providing with impermissible cash payments? XIX.

and

recruiting contact and communication of by and and (2) and providing with impermissible cash payments? XIX.

providing

contact and communication of by and and (2) and providing with impermissible cash payments? XIX. ALLEGATION

with impermissible cash payments?

XIX. ALLEGATION NO. 18 – Strojny provided $800 cash to Manual Bylaw 16.11.2.1 (2014-15)]

[NCAA Division Iprovided $800 cash to Manual Bylaw 16.11.2.1 (2014-15)] Alleged Level of Allegation No. 18: Severe Breach

Alleged Level of Allegation No. 18: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and a violation of NCAA legislation occurred.

2. Position on the level of the violation.

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 27

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violation occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 18 is a severe breach

of conduct (Level I).

C. Remaining issues in Allegation No. 18.

None.

XX.

ALLEGATION NO. 19 – Cannon Motors provided impermissible complimentary vehicle

use to

use to and Additionally, Cannon Motors and Cannon provided

and

use to and Additionally, Cannon Motors and Cannon provided

Additionally, Cannon Motors and Cannon provided

use to and Additionally, Cannon Motors and Cannon provided

with an impermissible $3,000 loan. [NCAA Division I Manual Bylaws 12.11.1 (2014-15); 16.11.2.1 (2014-15 and 2015-16); 16.11.2.2-(a) (2014-15); and 16.11.2.2-(c) (2014-15 and

2015-16)]

Alleged Level of Allegation No. 19: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution agrees the facts are substantially correct and violations of NCAA legislation occurred.

2. Position on the level of the violation.

The institution agrees the alleged violations are Level I.

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violations occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 19 is a severe breach

of conduct (Level I).

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 28

C. Remaining issues in Allegation No. 19.

None.

XXI.

ALLEGATION NO. 20 – Freeze violated head coach responsibility legislation as he is presumed responsible for the violations detailed in Allegation Nos. 5 through 10, 12 through 14, 16, 17-a and 17-b and failed to rebut that presumption. [NCAA Division I Manual Bylaws 11.1.2.1 (October 13 through 29, 2012); 11.1.1.1 (October 30, 2012, through

2015-16)]

Alleged Level of Allegation No. 20: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution disagrees the facts substantiate the alleged violation.

2. Position on the level of the violation.

The institution did not address the level.

B. Position of Freeze.

1. Position on the allegation.

Freeze disagrees the facts substantiate the alleged violation.

2. Position on the level of the violation.

Freeze did not address the level.

C. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violation occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 20 is a severe breach

of conduct (Level I).

STATEMENT OF THE CASE Case No. 00561 July 21, 2017 Page No. 29

D. Remaining issues in Allegation No. 20.

Did Freeze rebut the presumption of responsibility for the violations detailed in Allegation Nos. 5

through 10, 12 through 14, 16, 17-a and 17-b by demonstrating that he promoted an atmosphere of

compliance and monitored his staff?

XXII. ALLEGATION NO. 21 – The institution failed to exercise institutional control and monitor the conduct and administration of its athletics program. [NCAA Constitution 2.1.1, 2.8.1 and 6.01.1 (2009-10 and 2011-12 through 2015-16); and NCAA Constitution 6.4.1 and 6.4.2 (2009-10 and 2012-13 through 2015-16)]

Alleged Level of Allegation No. 21: Severe Breach of Conduct (Level I Violation).

A. Position of institution.

1. Position on the allegation.

The institution disagrees the facts substantiate the alleged violation.

2. Position on the level of the violation.

The institution did not address the level.

B. Position of enforcement staff.

1. Position on the allegation.

The enforcement staff believes the violation occurred as alleged.

2. Position on the level of the violation.

The enforcement staff believes a hearing panel could conclude that Allegation No. 21 is a severe breach

of conduct (Level I).

C. Remaining issues in Allegation No. 21.

Did the institution fail to demonstrate institutional control and monitor the conduct and administration

of its athletics program as evidenced by the violations detailed in Allegation Nos. 1, 2, 5 through 16, 17-a,

17-b and 18 through 20, and Finding Nos. IV-C and IV-H in Committee on Infractions Decision No. 460?