December 22, 2020

CONFIDENTIAL / VIA EMAIL

M. David Rudd, President

c/o Lisa Karen Atkins, Esq.
Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
420 20th Street North, Suite 1900
Birmingham, Alabama 35203
lisa.atkins@ogletree.com

RE: University of Memphis

NCAA Case No. 01051

Dear President Rudd:

The Complex Case Unit (CCU) has received a copy of your December 17, 2020, letter to the
Independent Resolution Panel (IRP). In that letter, you raise concerns regarding the CCU's
purported treatment of student-athletes in the course of its investigation into the University of
Memphis (the University). It is unfortunate that you elected to send a letter to the IRP rather than
address your concerns directly with the CCU. Your letter is the first time the University raised any
concerns regarding the CCU's supposed treatment of student-athletes. Members of the CCU have
been engaged in regular communications with your attorney and the University's outside counsel,
Lisa Karen Atkins. Ms. Atkins has participated in all of the interviews of University
representatives and student-athletes the CCU has conducted to date. Never once has Ms. Atkins
raised an objection related to these issues, or alleged any improper conduct with respect to any of
the student-athlete interviews.

Contrary to your assertions, the CCU has acted in a professional, courteous, and objective
manner throughout its investigation. Your interview, like all others, was recorded. The recording
belies your description of the interview and any comparison to a military or law enforcement style
interrogation. There were no threats, improper tactics, strategies, or manipulations designed to
impose "emotional and psychological pressure" or "create vulnerability and distress." Quite the
opposite, you were reminded at the outset of the interview that Ms. Atkins was present "to
represent you . . . and that if you need[ed] to talk to her at any time . . . you [could] let [the CCU
investigators] know" so they could "stop the interview and give you a chance to speak to
[counsel]." Ms. Atkins asked you a number of follow-up questions and never once interjected with
any concern regarding the manner, tone, or tenor of the CCU's questions.

The CCU's courteous and professional approach in your interview is consistent with its
approach in all other interviews. The CCU has provided the University with recordings of all of
University staff and student-athlete interviews. If the University has particularized concerns about
any interview as you reference in your letter, the CCU encourages the University to provide