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C.

Ryan Stinnett
Page 2

- All documents regarding Larry Pratt, Bobby Maze, or Rick Barnes and the use of any
Foundation or organization in connection with providing benefits to student athletes or
recruits;

- All documents and communications regarding impermissible benefits provided by UT


donors to student athletes;

- All documents regarding Donde Plowman and releases or settlement agreements


entered into between UT administrators and UT students for incidents occurring in the
past three years; and

- All documents regarding Phillip Fulmer, Carmen Tegano, Butch Jones, Willie Martinez,
Tommy Thigpen, Buck Fitzgerald, or any other UT Coach or administrator regarding
allegations of student athletes receiving impermissible monetary benefits.

I know you will appreciate the seriousness of this request and take all necessary steps
to ensure that all potential evidence is preserved and is not destroyed, modified, or altered in
any way prior to my opportunity to inspect it.

With football season underway, news of the UT investigation and terminations has
largely subsided. The time is ripe for the parties to quietly reach an agreement that can allow
both parties to move forward and to cooperate through the NCAA investigative process that
UT’s leadership has already initiated. The power to avoid a public lawsuit that could ensnare
the parties for years to come, impugn the university’s reputation further, and potentially
cripple UT’s athletic programs for years is in the hands of UT.

Please confirm by October 14, 2021, whether UT agrees to an informal settlement


conference as proposed. If this matter is not resolved by October 29, 2021, Coach Pruitt will
file suit.

Sincerely,

Michael P. Lyons

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