Tyndall

CONFIDENTIAL/VIA ELECTRONIC MAIL

July 22, 2015

President Rodney BennettThe University of Southern Mississippic/o Mr. William KingLightfoot, Franklin & White, LLCThe Clark Building400 20th Street NorthBirmingham, Alabama 35203

RE: Notice of allegations, The University of Southern Mississippi, Case No. 00319.

Dear President Bennett:

The purpose of this letter and enclosure(s) is to provide The University of Southern Mississippi with the results of an inquiry conducted by the NCAA regarding the institution's athletics department. The available information appears to be of sufficient substance and reliability to warrant issuing a notice of allegations (Bylaw 19.7.1).Accordingly, this letter and its enclosure(s) include (1) the details of the allegations, (2) the level of each allegation, (3) the factual information on which the NCAA enforcement staff relied, (4) any aggravating and/or mitigating factors that may be present, (5) a description of the available hearing procedures, and (6) a description of the institution's opportunity to respond to the allegations.

As indicated in the October 17, 2014, notice of inquiry, the cooperative principle imposesan affirmative obligation on the institution to assist the enforcement staff and the hearing panel of the NCAA Division I Committee on Infractions in developing full information to determine whether a possible violation of NCAA legislation occurred (Bylaw 19.2.3). The enforcement staff requests your continued cooperation for the purpose of obtaining pertinent facts until the case has been concluded.

Response to notice of allegations

Please review the allegations, the factual information and the requests for information thoroughly and submit a written response. If the institution's positions differ from those of the enforcement staff, the institution should provide all available factual information in support of its positions. In addition, pursuant to Bylaw 19.7.1.1, the institution has a responsibility to provide all relevant information including any information uncovered related to new violations.

Pursuant to Bylaw 19.7.2, responses from the institution shall be submitted within 90 days from the date of this letter, unless an extension is granted. In the interest of clarity and in accordance with the general procedures established by the committee, the institution is asked to copy each numbered item and the subparagraphs of each item from the notice of allegations. The institution's response, as well as the reasons for its position, should immediately follow each numbered item or subparagraph.

President Rodney BennettJuly 22, 2015 Page No. 2__________

Please submit the response and exhibits via email in Microsoft Word format to Joel McGormley, managing director of the office of the Committees on Infractions, at and to enforcement by uploading the response using the following link:

00319-SouthernMiss_Records Portal

Please name the file(s) using the following naming convention:

NOAResponse_DateSubmitted_SouthernMiss_00319.

Your response presents a vital opportunity to assist the hearing panel as it considers whether violations of the NCAA constitution and/or bylaws occurred. Note that under Bylaw 19.7.2, the failure of an institution to submit a timely response to the notice of allegations may be viewed by the hearing panel as an admission that a violation or violations occurred.

The enforcement staff has compiled a body of information relevant to this notice of allegations, including recorded interviews, interview transcripts and other factual information. Pursuant to Bylaw 19.5.9, you are entitled to review that information either through a secure website or at the NCAA national office. If you have not yet made arrangements with the enforcement staff to review the information, please contact the primary investigator identified below. He is available to discuss the development of the institution's response and assist in locating various individuals who have, or may have, important information regarding the allegations. If you believe additional interviews would be helpful as you prepare the institution's response, please consult the Committee on Infractions' Internal Operating Procedure 13-12-1 for further information and guidance.

Prehearing conference

Pursuant to Bylaw 19.7.4, within 60 days of the submission of the institution's response, the enforcement staff will conduct a prehearing conference to clarify the issues and discuss whether additional investigation is necessary. Also, pursuant to Bylaw 19.7.3, within 60 days of the date you submit the institution's response to the notice of allegations, the enforcement staff is required to submit its reply.Unless the hearing panel's chief hearing officer orders otherwise, Bylaw 19.7.5 requires the parties to submit all relevant materials to the hearing panel no later than 30 days before the date of the infractions hearing.

Committee on Infractions hearing

Because this matter is being processed as a severe breach of conduct (Level I) case, a hearing panel of the Committee on Infractions will convene for an in-person hearing, unless the institution requests a remote hearing under Bylaw 19.7.7. The office of the Committees on Infractions will notify the institution,involved individuals and the enforcement staff of the final hearing date and, if an in-person hearing is scheduled, the location, once the final schedule is established.

The hearing panel's chief hearing officer will identify and notify all individuals whose participation isrequired at the hearing. Pursuant to Bylaw 19.10.2, an appeal of the hearing panel's decision is available only to institutions who participate in the hearing process. In keeping with the premise of presidential control of athletics, the hearing panel will expect you to participate in the hearing and to discuss

Email Address

President Rodney BennettJuly 22, 2015 Page No. 3__________

presidential control and the institution's commitment to compliance. Additionally, the chief hearing officer will request the attendance of the following representatives of the institution: Bill McGillis,director of athletics; Dennis Phillips, faculty athletics representative; Doc Sadler, head men's basketballcoach; and Daniel Feig, director of compliance. Please inform Mr. McGormley at your earliest convenience if you anticipate difficulties in securing the attendance of these individuals. If you believe the hearing panel would benefit from the attendance of other institutional representatives, please adviseMr. McGormley of their names and titles. The failure of any person to participate in the hearing, if specifically requested to participate, may constitute a violation of Bylaw 19.7.7.5.1.

This letter addresses only a portion of the information about processing this case. Please consult Bylaw 19and the Committee on Infractions' Internal Operation Procedures for further information and guidance.You may direct any questions or requests for the hearing panel to Mr. McGormley. If the enforcement staff can be of assistance, please contact me; Tom Hosty, director of enforcement, at ; or James Garland, the primary investigator in this case, at .

I hope this correspondence is helpful, and I look forward to working together with all parties to present complete and reliable information to the hearing panel of the Committee on Infractions.

Sincerely,

Jonathan F. Duncan Vice President of Enforcement

JFD:lef

Enclosures

cc: Mr. Britton Banowsky Mr. Daniel FeigMr. Bill McGillis

Dr. Dennis Phillips NCAA Division I Committee on Infractions

Selected NCAA Staff Members

Email Address

Email Address

NOTICE OF ALLEGATIONS

to the

President of The University of Southern Mississippi

A. Processing Level of Case.

Based on the information contained within the following allegations, the NCAA enforcement staff believes this case should be reviewed by a hearing panel of the NCAA Division I Committee on Infractions pursuant to procedures applicable to a severe breach of conduct (Level I violation).1

B. Allegations.

1. [NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-(b), 10.1-(c), 10.1-(g), 13.2.1, 14.01.1, 14.01.2 and 16.8.1 (2011-12 through 2014-15); 14.11.1 (2011-12 and 2012-13); 14.10.1 (2013-14); and 12.11.1 (2014-15)]

It is alleged that between June 2012 and May 2014, , then head men's basketball coach; then associate head men's basketball coach; then assistant men'sbasketball coach; and then men'sbasketball and a then assistant men's basketball coach violated the NCAA principles of ethical conduct when they were knowingly involved in arranging fraudulent academic credit in the completion of online coursework for seven then men's basketball prospective student-athletes. In one instance, paid for the online courses for one prospective student-athlete. Additionally, as it relates to five of the prospective student-athletes, they later enrolled at the institution, competed for and received travel expense from the institution and were not withheld from competition for their ineligibility. Specifically:

a. In the spring and summer of then men's basketball prospective student-athlete from

, a two-year college, was enrolled in three online courses at Adams State University (Adams State): (1) ENG 101 Communication Arts I; (2) ENG 102 Communication Arts II; and (3) MATH 104 Finite Mathematics. and knowingly and impermissibly completed work in these courses for at the direction of This amounted to fraudulent academic credit and resulted in inaccurate information being provided to the admissions office at The University of Southern Mississippi (Southern Mississippi) regarding academic record, which was used by the

1 Pursuant to NCAA Bylaw 19.7.7.1 of the 2014-15 NCAA Division I Manual, if violations from multiple levels are identified in the notice of allegations, the case shall be processed pursuant to procedures applicable to the most serious violation(s) alleged.

Student Athlete A

JUCO 1

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Former MBB HC

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Former MBB Staff Member 1 Former MBB Staff Member 2

Staff Members

Student Athlete A

Former MBB Staff Member2

Former MBB StaffMember 1

Student Athlete A

NOTICE OF ALLEGATIONSCase No. 00319 July 22, 2015 Page No. 2 __________

institution to certify his transfer eligibility for the academic year.subsequently enrolled at Southern Mississippi, competed for

and received travel expenses as part of the men's basketball team during the and seasons. [NCAA Bylaws 10.01.1, 10.1, 10.1-(b),10.1-(g), 14.01.1, 14.01.2, 14.11.1 and 16.8.1 (2012-13); and 14.10.1 (2013-14)]

b. In the summer of then men's basketball prospective student-athlete from , a two-year college, was

enrolled in three online courses at Adams State: (1) ENG 101 Communication Arts I; (2) ENG 102 Communication Arts II; and (3) MATH 104 Finite Mathematics. and knowingly and impermissibly completed work in these courses for at the direction of This amounted to fraudulent academic credit and resulted in inaccurate information being provided to the admissions office at Southern Mississippi regarding academic record, which was used by the institution to certify his transfer eligibility for the academic year.

subsequently enrolled at Southern Mississippi, competed for and received travel expenses as part of the men's basketball team during the

and seasons. [NCAA Bylaws 10.01.1, 10.1, 10.1-(b), 10.1-(g), 14.01.1, 14.01.2, 14.11.1 and 16.8.1 (2012-13); and 14.10.1 (2013-14)]

c. In the spring of then men's basketball prospective student-athlete from , a two-year college, was

enrolled in three online courses at Adams State: (1) ENG 101 Communication Arts I; (2) ENG 102 Communication Arts II; and (3) MATH 104 Finite Mathematics. and knowingly and impermissibly completed work in these courses for at the direction of and through the involvement of a then assistant men'sbasketball coach, amounting to fraudulent academic credit.committed to Southern Mississippi in but never enrolled at the university. [NCAA Bylaws 10.01.1 10.1, and 10.1-(b) (2012-13)]

d. In the spring of then men's basketball prospective student-athlete from , a

two-year college, was enrolled in four online courses at Adams State: (1) AR 103 Art Appreciation; (2) BUS 207 Principles of Accounting I; (3) HIST 202 American History to 1865; and (4) SOC 251 Social Problems.

and knowingly and impermissibly completed work in these courses for at the direction of and through the involvement of

, amounting to fraudulent academic credit. subsequently

Student Athlete B

Student Athlete B

Student Athlete B

Student Athlete C

StudentAthlete C

StudentAthlete D

SStudent Athlete F JUCO 2

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JUCO 4

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Date of Committment

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Former MBBHC

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Former MBBAsst. 2

Student Athlete A


Former MBBStaff Member 1

Student AthleteB



Student AthleteC

Student Athlete D



StudentAthlete D


enrolled at Southern Mississippi, competed for and received travel expenses as part of the men's basketball team during the season;however, these credits were not accepted by the institution as transferablecredit hours, nor were they used to certify eligibility. [NCAA Bylaws 10.01.1, 10.1, 10.1-(b), 14.01.1., 14.01.2, 14.11.1 and 16.8.1 (2012-13);and 14.10.1 (2013-14)]

e. In the spring and summer of then men's basketball prospective student-athlete from , a two-year college, was enrolled in four online courses at Adams State: (1) ENG 203 Major Theses in Literature; (2) PSYC 101 Introduction to Psychology; (3) MATH 104 Finite Mathematics; and (4) MATH 155 Integrated Mathematics. knowingly and impermissibly completed coursework for at the direction of and through the involvement of . In addition, an associate of and also completed coursework for This amounted to fraudulent academic credit and resulted in inaccurate information being provided to the admissions office at Southern Mississippi regarding academic record, which was used by the institution to certify his transfer eligibility for the academic year. subsequently enrolled at Southern Mississippi, competed for and received travel expenses as part of the men's basketball team during the and seasons. [NCAA Bylaws 10.01.1, 10.1, 10.1-b, 10.1-(g), 14.01.1, 14.01.2, 14.10.1 and 16.8.1 (2013-14); and 12.11.1 (2014-15)]

f. In the fall of then men's basketball prospective student-athlete from , a two-year

college, was enrolled in two online courses at Adams State: (1) ENG 101 Communication Arts I and (2) ENG 102 Communication Arts II.paid for the registration of these courses with prepaid debit cards that were purchased at a CVS pharmacy store in New York. knowingly and impermissibly completed coursework for at the direction of and through the involvement of a then assistant men's basketball coach.This amounted to fraudulent academic credit and resulted in inaccurateinformation being provided to the admissions office at Southern Mississippi regarding academic record, which was used by the institution to certify his transfer eligibility for the academic year.

subsequently enrolled at Southern Mississippi for the second semester of the academic year. [NCAA Bylaws 10.01.1, 10.1, 10.1-(b), 10.1-(c), 10.1-(g) and 13.2.1 (2013-14)]

Student Athlete E

StudentAthlete E

StudentAthlete E

StudentAthlete E

StudentAthlete E

Student Athlete F

StudentAthlete F

StudentAthlete F

StudentAthlete F

JUCO 5

JUCO 1

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Former MBB HC

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g. In the fall of and the spring of then men's basketball prospective student-athlete from

, a two-year college, was enrolled in two online courses at Adams State: (1) MATH 104 Finite Mathematics and (2) MATH 155 Integrated Mathematics. knowingly and impermissibly completed coursework for at the direction of and through the involvement of This amounted to fraudulent academic credit and resulted in inaccurate information being provided to the admissions office at Southern Mississippi regarding academic record, which was used by the institution to certify his transfer eligibility for the academic year. subsequently enrolled at Southern Mississippi,competed for and received travel expenses as part of the men's basketball team during the season. [NCAA Bylaws 10.01.1, 10.1, 10.1-(b),10.1-(g), 14.01.1, 14.01.2, 14.10.1 and 16.8.1 (2013-14); and 12.11.1 (2014-15)]

This allegation serves as part of the basis for the head coach responsibility allegation in Allegation No. 7.

Level of Allegation No. 1:

The NCAA enforcement staff believes a hearing panel of the NCAA Division I Committee on Infractions could conclude that Allegation No. 1 is a severe breach of conduct (Level I) because the alleged conduct seriously undermines or threatens the integrity of the NCAA Collegiate Model, as members of the institution's men's basketball staff engaged in academic misconduct for prospects who were recruited, some of whom later enrolled at their institution as student-athletes. Further, Allegation No. 1 provided or was intended to provide a substantial or extensive recruiting or competitive advantage, as otherwise ineligible student-athletes would have been or were able to enroll at and compete for the institution. Finally, academic misconduct and unethical conduct arepresumptively regarded as a Level I violation. [NCAA Bylaw 19.1.1 (2014-15)]

Factual information (FI) on which the enforcement staff relies for Allegation No. 1:

FI1: May 7, through June 11, Metadata for coursework submitted to Adams State on behalf of in PSYC 101. This includes, but is not limited to, the name " " appearing as the author or modifier of 16 assignments. The name " " has been associated with

through Internet research. was identified by in his January 26, 2015, interview as a friend of his

StudentAthlete G

StudentAthlete G

StudentAthlete G

JUCO 5

20## 20##

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Online Name

Online Name

Non-NCAA Affiliated Person Non-NCAAAffiliated Person

Former MBBHC

Former MBBAsst. 3

Former MBBAsst. 3

Student Athlete G


StudentAthlete E


and from

( Psyc101 _051415_SouthernMiss_00319)

FI2: June 8 through July 5, Coursework submitted to Adams State on behalf of in MATH 104. This includes, but is not limited to, six assignments with handwriting that a forensic document examiner determined as "probable" that the same person produced the same handwriting on assignments submitted for and

( Math104Assign2-7_051415_SouthernMiss_00319)

FI3: June 23 through July 5, Coursework submitted to Adams State on behalf of in MATH 104. This includes, but is not limited to, seven assignments with handwriting that a forensic document examiner determined as "probable" that the same person produced the same handwriting on assignments submitted for and

( Math104Assign1-7_052015_SouthernMiss_00319)

FI4: August 8 through 10, Metadata for coursework submitted to Adams State on behalf of in ENG 101. This includes, but is not limited to, the name appearing as the author of six assignments.( 052215_SouthernMiss_00319)

FI5: August 8 through 12, Metadata for coursework submitted to Adams State on behalf of in ENG 102. This includes, but is not limited to, the name appearing as the author of three assignments. ( ENG102 _052215_SouthernMiss_00319)

FI6: August 12 through 16, Metadata for coursework submitted to Adams State on behalf of in ENG 102. This includes, but is not limited to, the name " " appearing as the author of six assignments. ( Eng102 _051415_SouthernMiss_00319)

FI7: August 16, Adams State academic transcript for This includes, but is not limited to, enrollment in nine total credit hours, consisting of ENG 101, ENG 102 and MATH 104, during the summer semester.( USMAcademicFile_110514_SouthernMiss_00319)

Student Athlete A

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Athlete E

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Former MBB Staff Member 1

FormerMBBStaff

Membe1

Student Athlete A



NCAA Institution 1


FI8: August 17, Adams State academic transcript for This includes, but is not limited to, enrollment in nine total credit hours, consisting of ENG 101 and ENG 102, during the spring semester and MATH 104 during the summer semester.( USMAcademicFile_110514_SouthernMiss_00319)

FI9: November 14, through May 8, Metadata for coursework submitted to Adams State on behalf of in ENG 101. This includes, but is not limited to, the name appearing as the author or modifier of nine assignments. ( Eng10 _051415_SouthernMiss_00319)

FI10: April 2 through 16, Coursework submitted to Adams State on behalf of in MATH 104. This includes, but is not limited to, seven assignments with handwriting that a forensic document examiner determined as "probable" that the same person produced the same handwriting on assignments submitted for and ( Math104Final_SouthernMiss_00319 and

Math104Assign1-7_051415_SouthernMiss_00319)

FI11: April 15 through May 13, Metadata for coursework submitted to Adams State on behalf of in ENG 102. This includes, but is not limited to, the name " " appearing as the author of 11 assignments. ( Eng102 _051415_SouthernMiss_00319)

FI12: May 3 through 17, IP addresses for coursework submissions to Adams State on behalf of This includes, but is not limited to, five submissions in SOC 251 that include IP address locations of

, and . is from and according to , then assistant men's basketball coach, in his March 27, 2015, interview, was in at the time those submissions were made for ( SubmissionDates_102214_SouthernMiss_00319)

FI13: May 8, IP addresses for coursework submissions to Adams State on behalf of This includes, but is not limited to, one submission in ENG 101 that includes an IP address location of Hattiesburg, Mississippi. ( Eng101-final_SouthernMiss_00319)

Student Athlete A

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City, State of JUCO 4

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Member1

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Former MBB StaffMember 1 Hometown





FI14: May 12 through 14, Metadata for coursework submitted to Adams State on behalf of in BUS 207. This includes, but is not limited to, the name appearing as the author of 10 assignments.( Bus207 051415_SouthernMiss_00319)

FI15: May 12 through 14, IP addresses for coursework submissions to Adams State on behalf of This includes, but is not limited to, four submissions in BUS 207 that include IP address locations of

, and . This corresponds to the dates that was in and was in , as reported by in his March 27, 2015, interview. also confirmed in his June 24, 2015,interview that he was with in in May ( SubmissionDates_102214_SouthernMiss_00319)

FI16: May 13 through 23, Metadata for coursework submitted to Adams State on behalf of in AR 103. This includes, but is not limited to, the name " " appearing as the author of 13 assignments.( Ar103 _051415_SouthernMiss_00319)

FI17: May 13 through 23, IP addresses for coursework submissions to Adams State on behalf of This includes, but is not limited to, 20submissions in AR 103 that include IP address locations of

; Hattiesburg, Mississippi; ; and . The dates of the IP address information for and correspond to the dates on which reported that

was in and was in . In addition, is from which is located near

( SubmissionDates_102214_SouthernMiss_00319)

FI18: May 14 through June 11, IP addresses for coursework submissions to Adams State on behalf of This includes, but is not limited to, 31 submissions in PSYC 101 that include an IP address location of Kingston, Jamaica, while was still in . is from Kingston. ( SubmissionDates_111014_SouthernMiss_00319)

FI19: May 16, Metadata for coursework submitted to Adams State on behalf of in SOC 251. This includes, but is not limited to, the name

appearing as the modifier of one assignment. ( Soc25 051415_SouthernMiss_00319)

FI20: May 29, Adams State academic transcript for This includes, but is not limited to, enrollment in 12 total credit hours, consisting

StudentAthlete D

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City of JUCO 4

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City ofJUCO 3

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JUCO 3


City of JUCO 3

State ofJUCO 5

Non-NCAAAffiliated Person

Former MBBAsst. 1

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Former MBB Asst. 1

StudentAthlete E

StudentAthlete D






StudentAthlete D



Former MBB Staff Member 1 Hometown



City of JUCO 4 Former MBBStaff Member

1Former MBB Staff Member 1 Hometown

Large City Near Former MBB StaffMember 1 Hometown

FoStudent Athlete D




of AR 103, BUS 207, HIST 202 and SOC 251 during the summer semester. ( USMAcademicFile_110514_SouthernMiss_00319)

FI21: June 12 through July 3, Metadata for coursework submitted to Adams State on behalf of in ENG 203. This includes, but is not limited to, the name " " appearing as the author of five assignments. ( Eng203 _051415_SouthernMiss_00319)

FI22: June 17 through July 4, IP addresses for coursework submissions to Adams State on behalf of This includes, but is not limited to, six submissions in ENG 203 that include locations of Kingston, Jamaica, and

, while was still in is from Kingston, and is from . ( SubmissionDates_111014_SouthernMiss_00319)

FI23: July 10 and 11, Coursework submitted to Adams State on behalf of in MATH 104. This includes, but is not limited to, six assignments

with handwriting that a forensic document examiner determined as"probable" that the same person produced the same handwriting on assignments submitted for and ( Math104Assign1-6_051415_SouthernMiss_00319)

FI24: July 10 and 11, IP addresses for coursework submissions to Adams State on behalf of This includes, but is not limited to, seven submissions in MATH 104 that include a location of , while

was still in . is from . ( SubmissionDates_111014_SouthernMiss_00319)

FI25: July 17 and 18, Metadata for coursework submitted to Adams State on behalf of in MATH 155. This includes, but is not limited to, the name appearing as the modifier of one assignment. The properties of this document are similar to those of the same assignment submitted on behalf of in MATH 155 nearly a year later. ( Math15 051415_SouthernMiss_00319 and

Math15 051415_SouthernMiss_00319)

FI26: July 18 through 22, Coursework submitted to Adams State on behalf of in MATH 155. This includes, but is not limited to, six assignments with handwriting that a forensic document examiner determined as "probable" that the same person produced the same

Student Athlete A Student Athlete B

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State ofJUCO 5

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Former MBB Staff Member 1 Hometown

State of JUCO 5

Member1

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Former MBBStaff Member

1Student

Athlete E


1

Former MBB Staff Member 1Hometown

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Former MBBStaff

Member 1Former

MBB StaffMember 1


handwriting on assignments submitted for and ( Math155Assign1-6_051415_SouthernMiss_00319)

FI27: August 20, Adams State academic transcript for This includes, but is not limited to, enrollment in 12 total credit hours, consisting of ENG 203 and PSYC 101 during the spring semester and MATH 104 and MATH 155 during the summer semester. ( USMAcademicFile_110514_SouthernMiss_00319)

FI28: September 17, CVS receipts. This includes, but is not limited to, receipts for the purchase of four Vanilla Visa prepaid debit cards in the amount of $500 each. ( Receipts_032715_SouthernMiss_00319)

FI29: October 4 through November 20, Metadata for courseworksubmitted to Adams State on behalf of in ENG 101. This includes, but is not limited to, the name " " appearing as the author of 47 assignments. ( Eng101 _051415_SouthernMiss_00319)

FI30: October 4 through November 20, IP addresses for coursework submissions to Adams State on behalf of This includes, but is not limited to, 46 submissions in ENG 101 that include a location of Hattiesburg, Mississippi, while was still in ( SubmissionDates_111014_SouthernMiss_00319)

FI31: November 20 through December 2, Metadata for coursework submitted to Adams State on behalf of in ENG 102. This includes, but is not limited to, the name " " appearing as the author of 28 assignments.( Eng102 _051415_SouthernMiss_00319)

FI32: November 20 through December 2, IP addresses for coursework submissions to Adams State on behalf of This includes, but is not limited to, 29 submissions in ENG 102 that include locations of Hattiesburg, Mississippi, and Louisville, Kentucky, while was still in . ( SubmissionDates_111014_SouthernMiss_00319)


StudentAthlete C

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FI33: December 16, Adams State academic transcript for This includes, but is not limited to, enrollment in six total credit hours, consisting of ENG 101 and ENG 102 during the fall semester.( USMAcademicFile_112614_SouthernMiss_00319)

FI34: April 5 through 16, 2014 Coursework submitted to Adams State on behalf of in MATH 155. This includes, but is not limited to, six assignments with handwriting that a forensic document examiner determined as "probable" that the same person produced the same handwriting on assignments submitted for and ( Math155Assign1-6_051415_SouthernMiss_00319)

FI35: April 5 through May 15, IP addresses for coursework submissions to Adams State on behalf of This includes, but is not limited to, seven submissions in MATH 155 that include locations of Hattiesburg, Mississippi, and , while was still in .

joined staff at in late April

( SubmissionDates_111014_SouthernMiss_00319)

FI36: July 17, through May 15, Metadata for courseworksubmitted to Adams State on behalf of in MATH 155. This includes, but is not limited to, the name appearing as the modifier of one assignment. The properties of this document are similar to those on the same assignment submitted on behalf of for the same course nearly a year earlier. ( Math155 051415_SouthernMiss_00319 and

Math15 051415_SouthernMiss_00319)

FI37: June 13, Adams State academic transcript for This includes, but is not limited to, enrollment in six total credit hours, consisting of MATH 104 and MATH 155 during the fall semester and the spring semester, respectively. ( USMAcademicFile_110514_SouthernMiss_00319)

FI38: August 27, 2014 Transcript of first interview. This includes, but is not limited to, statement that he completed the work for the online courses at Adams State.( _TR_082714_SouthernMiss_00319)


StudentAthlete C

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State of JUCO 5


FI39: August 27, 2014 Interview summary of the portions of first interview not recorded due to a recorder malfunction, as well as a summary of what and the enforcement staff discussed as the parties waited for limited immunity to be approved. This also includes a summaryof the enforcement staff's efforts to allow an opportunity to review this interview summary.( _INotes_082714_SouthernMiss_00319 and

_IS_070715_SouthernMiss_00319)

FI40: August 28, 2014 Transcript of second interview. This includes, but is not limited to, statement that he did not register, pay for or complete any of the coursework in the Adams State classes.( _TR_082814_SouthernMiss_00319)

FI41: October 31, 2014 Transcript of first interview. This includes, but is not limited to, statement that he completed the work for the online courses at Adams State.( _TR_103114_SouthernMiss_00319)

FI42: October 31, 2014 Transcript of first interview. This includes, but is not limited to, statement that he completed the work for the MATH 155 online course at Adams State. ( _TR_103114_SouthernMiss_00319)

FI43: November 5, 2014 Southern Mississippi academic transcript for This includes, but is not limited to, the application of nine

transferable credit hours from Adams State toward the Southern Mississippi program. ( USMAcademicFile_110514_SouthernMiss_00319)

FI44: November 5, 2014 Southern Mississippi academic transcript for This includes, but is not limited to, the application of nine transferablecredit hours from Adams State toward the Southern Mississippi

program. ( USMAcademicFile_110514_SouthernMiss_00319)

FI45: November 5, 2014 Southern Mississippi academic transcript for This includes, but is not limited to, the application of twelve transferablecredit hours from Adams State toward the Southern Mississippi


Student Athlete A

Student Athlete B

Student AthleteD

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StudentAthlete E

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StudentAthlete E

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StudentAthlete G

Student AthleteG

StudentAthlete B

Student Athlete A's Major

Student Athlete A

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Former MBB Staff MemberStudent Athlete E's Major

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FI46: November 5, 2014 Southern Mississippi academic transcript for This includes, but is not limited to, the application of three transferablecredit hours from Adams State toward the Southern Mississippi


FI47: November 6, 2014 Transcript of first interview. This includes, but is not limited to, statement that he completed coursework for both and online classes at Adams State. ( _TR_110614_SouthernMiss_00319)

FI48: November 18, 2014 Transcript of first interview. This includes but is not limited to statement that he was not aware of or involved in academic misconduct related to prospective student-athletes.( _TR_111814_SouthernMiss_00319)

FI49: November 18, 2014 Transcript of first interview. This includes, but is not limited to, statement that he was notinvolved in NCAA violations. ( _TR_111814_SouthernMiss_00319)

FI50: November 19, 2014 Transcript of first interview. This includes, but is not limited to, statement that he did not register, pay for or complete any of the coursework in his Adams State and University ofNorth Dakota online courses. ( _TR_111914_SouthernMiss_00319)

FI51: November 24, 2014 Transcript of second interview. This includes, but is not limited to, statement that he was not involved in NCAA violations. ( _TR_112414_SouthernMiss_00319)

FI52: December 4, 2014 Southern Mississippi academic transcript for This includes, but is not limited to, the application of six transferablecredit hours from Adams State toward at Southern Mississippi. ( USMAcademicFile_112614_SouthernMiss_00319)

FI53: December 2014 and February 2015 Telephone calls to from the institution in which denied requests to interview. (InterviewStatusChart_022715_SouthernMiss_00319)

Student Athlete A

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Student Athlete D

StudentAthlete F

StudentAthlete F

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StudentAthlete F

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StudentAthlete G

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NOTICE OF ALLEGATIONS Case No. 00319 July 22, 2015 Page No. 13 __________

FI54: December 2014 and February 2015 Telephone calls to from the institution. parents stated in December 2014 that he was playing basketball and was unavailable. The institution received no response in the follow-up call requesting an interview in February 2015. (InterviewStatusChart_022715_SouthernMiss_00319)

FI55: January 26, 2015 Transcript of second interview. This includes, but is not limited to, discussion of the relationship between him, and and their connection to . ( _TR_012615_SouthernMiss_00319_DRAFT)

FI56: January 26, 2015 Transcript of second interview. This includes, but is not limited to, statement that he completed all coursework for Adams State courses while he was in ( TR_012615_SouthernMiss_00319)

FI57: January 26, 2015 Transcript of second interview. This includes, but is not limited to, statement that he completed all coursework for Adams State courses from . ( _TR_012615_SouthernMiss_00319)

FI58: September 2014 through March 2015 In September 2014, the enforcement staff requested an interview and declined. In November 2014, the enforcement staff informed that serious allegations had been alleged against him and again, declined to interview. In December 2014 and March 2015, the enforcement staff sent letters to requesting interviews. did not respond.

(InterviewStatusChart_022715_SouthernMiss_00319) ( CO_121014_SouthernMiss_00319) ( CO_InterviewRequest_030315_SouthernMiss_00319)

FI59: November 2014 through April 2015 On November 17, 2014, the

enforcement staff had a scheduled interview with at .resigned his position on the staff three days prior to his November 17, 2014, scheduled interview with the enforcement staff. In January and March 2015, letters were sent by the enforcement staff to requesting interviews. In March 2015, an attorney representing advised the enforcement staff thatdeclined to interview with the enforcement staff. (InterviewStatusChart_022715_SouthernMiss_00319;

CO_InterviewRequest_010514_SouthernMiss_00319; and CO_InterviewRequest_030315_SouthernMiss_00319)

Student Athlete B

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Student Athlete E

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Affiliated PersonNCAA Institution 1

State of JUCO 5

State of JUCO 5

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Attorney for Former MBB Staff Member 1

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FI60: May and June 2015 The enforcement staff made calls to requesting an interview. did not return enforcement staff calls.(InterviewStatusChart_022715_SouthernMiss_00319)

FI61: February 2015 The enforcement staff made calls to requesting interviews. did not return enforcement staff calls.(InterviewStatusChart_022715_SouthernMiss_00319)

FI62: March 16, 2015 Transcript of second interview. This includes but is not limited to, statement that he was not aware of or involved in academic misconduct related to prospective student-athletes. ( _TR_031615_SouthernMiss_00319)

FI63: March 27, 2015 Transcript of third interview This includes but is not limited to, statement that hired and

for the purpose of engaging in academic misconduct. further stated that would send and to the locales of prospective student-athletes to complete coursework so that IP address information would make it appear as though the prospects had completed the work themselves. Specifically, identified a trip he took with

to , in May for to complete work for while traveled to to complete work for

also described another trip he took with to , in July for to complete work for stated that he was also aware of completing coursework for and ofcompleting coursework for ( _TR_032715_SouthernMiss_00319)

FI64: May 12, 2015 Transcript of third interview. This includes, but is not limited to, statement that he was not aware of or involved in academic misconduct related to prospective student-athletes. ( _TR_031615_SouthernMiss_00319)

FI65: May 15, 2015 Internet research for " ". This includes, but is not limited to, the identification of " " as an online alias of

. ( _051515_SouthernMiss_00319)

FI66: June 24, 2015 Transcript of second interview. This includes, but is not limited to, statement that he also completed coursework for and stated that he completed

StudentAthlete C

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ofJ

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Athlete F


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work for at the request of but could not recall who requested that he do the work for( _TR_062415_SouthernMiss_00319_DRAFT)

FI67: June 29, 2015 Forensic handwriting analysis of Lee Ann Harmless(Harmless), forensic document examiner. This includes, but is not limited to, Harmless' conclusion that it is probable the assignments submitted in the Adams State math courses on behalf of

and contained material from the same writer.(LHarmlessReport_062915_SouthernMiss_00319)

FI68: May 27, 2015 Curriculum vitae of Harmless. This includes, but is not limited to, Harmless' education and experience as a forensic document examiner.(HarmlessResume_HandwritingExpert_SouthernMiss_00319)

FI69: February 16, 2015 Transcript of interview with , head men'sbasketball coach at the . This includes, but is not limited to, statement that recruited both and

( TR_021615_SouthernMiss_00319)

FI70: February 16, 2015 Transcript of interview with ), an academic advisor at the . This includes, but is not limited to, statement that she spoke with regularly in the course of his recruitment of that worked with her to identify courses for at Adams State, that told her he would work with on his academics and that everything was under control.

further stated that she worked with during his recruitment of to identify online courses that would satisfy requirements at the

.( _TR_021615_SouthernMiss_00319)

The enforcement staff incorporates the factual information referenced throughout this document and all other documents posted on the secure website.

2. [NCAA Bylaws 10.1, 10.1-(c), 14.01.1, 14.3.2.1.1, 15.01.2, 15.01.3, 15.02.4 and 16.8.1 (2012-13 through 2014-15); 14.10.1 (2013-14); and 12.11.1 (2014-15)]

It is alleged that during the 2012-13 through 2014-15 academic years, , then head men's basketball coach, violated the NCAA

principles of ethical conduct and financial aid legislation when he provided an


StudentAthlete C

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StudentAthlete E

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JUCO 5

JUCO 5

JUCO 5

JUCO 5 MBB HC

JUCO 5MBB HC

JUCO 5 MBBHC

Employee at JUCO 5

Employeeat JUCO 5

Employeeat JUCO 5

Employeeat JUCO 5

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Asst. 3

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impermissible source of financial aid to nonqualifier men's basketball student-athletes and .Additionally, both student-athletes later competed for and received travel expenses from the institution and were not withheld from competition for their ineligibility. Specifically:

a. provided cash and prepaid cards that totaled approximately $6,000 to during the academic year. These benefits were applied to student account at the institution to partially pay for his year of residence expenses associated with tuition and room and board. The next academic year, competed for and received travel expenses from the institution. [NCAA Bylaws 10.1, 10.1-(c), 14.01.1, 14.3.2.1.1, 14.10.1, 15.01.2, 15.01.3, 15.02.4 and 16.8.1 (2013-14)]

b. provided prepaid cards that totaled approximately $2,000 to during the academic year. These benefits were

applied to student account at the institution to partially pay for his year of residence expenses associated with tuition and room and board. The next academic year, competed for and received travel expenses from the institution. [NCAA Bylaws 10.1, 10.1-(c), 14.01.1, 14.3.2.1.1, 15.01.2, 15.01.3, 15.02.4 and 16.8.1 (2013-14);12.11.1 (2014-15)]

This allegation serves as part of the basis for the head coach responsibility allegation in Allegation No. 7.


The NCAA enforcement staff believes a hearing panel of the NCAA Division I Committee on Infractions could determine that Allegation No. 2 is a severe breach of conduct (Level I) because this alleged conduct seriously undermines or threatens the integrity of the NCAA Collegiate Model, as the head men'sbasketball coach engaged in unethical conduct through his involvement in providing an impermissible source of financial aid for two nonqualifier student-athletes from his own funds. In the alternative, if a hearing panel determines that the funds provided were not his own but still impermissible sources of funds, the enforcement staff believes Allegation No. 2 provided, or was intended to provide, a substantial or extensive competitive advantage, as two nonqualifying student-athletes received impermissible sources of financial aid in their year of residency and later competed for the institution. [NCAA Bylaw 19.1.1 (2014-15)]

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FI71: June 18, 2012 Compliance notes provided by from men'sbasketball staff meetings held in 2012 and 2013. This includes, but is not limited to, a note from the June 18, 2012, meeting that ,former associate athletic director for compliance, student services, provided the interpretation regarding nonqualifiers, "A non-qualifier or a walk-on can have their academic expenses paid for by a parent, guardian, and/or former HS/Prep School Coach. If the coach and the player have the relationship where he has provided needed support for him in the past, like in absence of a parent or guardian, the coach can provide needed support. HOWEVER, IT CAN'T BE PAID FOR BY AN AAU COACH." ( ComplianceNotes_121514_SouthernMiss_00319)

FI72: October 17, 2014 account statement. This includes, but is not limited to, payments to account during his academic year of residence totaling $6,314.14 as follows: $497 November 1, $1,000 December 7, $920 December 20, $900 January 4, $688.66 January 11, and $2,308.48 April 30, ( AccountStatement_110514_SouthernMiss_00318)

FI73: October 17, 2014 account statement. This includes, but is not limited to, payments to account during his academic year of residence totaling $2,198.25 as follows: $966 October 28, $901 November 27, and $331.25 April 1, ( AccountStatement_110514_SouthernMiss_00318)

FI74: October 25, 2014 phone records for his personal cell phone.This includes, but is not limited to, 11 text messages with

, high school boys' basketball coach. 6062075105_042215_SouthernMiss_00319)

FI75: October 28, 2014 phone records for a cell phone maintained in his mother's name. This includes, but is not limited to, four phone calls with including calls lasting three minutes and 18 minutes, and 12 calls with , then assistant men'sbasketball coach at , including calls lasting two minutes and three minutes. ( 8594571915_042215_SouthernMiss_00319)

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NCAA Institution 3


FI76: October 28, 2014 phone records for his personal cell phone.This includes, but is not limited to, 10 text messages and two phone calls with including one call lasting 10 minutes.( 6062075105_042215_SouthernMiss_00319)

FI77: October 29, 2014 phone records for a cell phone maintained in his mother's name. This includes, but is not limited to, six phone calls with

including calls lasting two minutes, six minutes and eightminutes, and seven calls with including two calls lasting threeminutes and four minutes each and one call lasting 10 minutes.( 8594571915_042215_SouthernMiss_00319)

FI78: October 29, 2014 cell phone records. This includes, but is not limited to, one phon with lasting 15 minutes and one phone call with former , lasting seven minutes.( PhoneRecords_031115_SouthernMiss_00319)

FI79: October 30, 2014 phone records for a cell phone maintained in his mother's name. This includes, but is not limited to, 13 phone calls with

including calls lasting three minutes and five minutes, and one call with lasting eight minutes.( 8594571915_042215_SouthernMiss_00319)

FI80: October 30, 2014 Transcript of interview. This includes, but is not limited to, statements that he received cash and prepaid debit cards through the men's basketball office to make payments on his student account at The University of Southern Mississippi (Southern Mississippi) and that a accompanied him to the business office to ensure the funds were used to pay the balance on his account. ( _TR_103014_SouthernMiss_00319)

FI81: October 30, 2014 Transcript of interview. This includes, but is not limited to, statement that he received prepaid debit cards through the men's basketball office to make payments on his student account at Southern Mississippi. ( _TR_103014_SouthernMiss_00319)

FI82: October 31, 2014 phone records for a cell phone maintained in his mother's name. This includes, but is not limited to, eight phone calls with including calls lasting five minutes, six minutes and 10 minutes.( 8594571915_042215_SouthernMiss_00319)

Student Athlete H

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FI83: October 31, 2014 Word document containing Southern Mississippi men's basketball staff meeting notes from May 2012 through June 2013.This includes, but is not limited to, metadata indicating the document including the interpretation from was created by October 31, 2014, and modified November 7, 2014.

uneNotes_031715_SouthernMiss_00319)

FI84: November 1, 2014 phone records for a cell phone maintained in his mother's name. This includes, but is not limited to, one call with

( 8594571915_042215_SouthernMiss_00319)

FI85: November 2, 2014 phone records for a cell phone maintained in his mother's name. This includes, but is not limited to, two phone calls with including one lasting six minutes, and three calls with

including one lasting four minutes.( 8594571915_042215_SouthernMiss_00319)

FI86: November 3, 2014 phone records for a cell phone maintained in his mother's name. This includes, but is not limited to, one phone call with lasting four minutes and four calls with including two calls lasting seven minutes and 14 minutes.( 8594571915_042215_SouthernMiss_00319)

FI87: November 3, 2014 phone records for his personal cell phone.This includes, but is not limited to, two text messages with ( 6062075105_042215_SouthernMiss_00319)

FI88: November 3, 2014 cell phone records. This includes, but is not limited to, one phone call with lasting 18 minutes.( PhoneRecords_031115_SouthernMiss_00319)

FI89: November 4, 2014 phone records for a cell phone maintained in his mother's name. This includes, but is not limited to, 16 phone calls with including two calls lasting five minutes each, and one call with ( 8594571915_042215_SouthernMiss_00319)

FI90: November 4, 2014 Transcript of first interview. This includes, but is not limited to, statement that he sent around $4,000 in prepaid debit cards to the men's basketball office to assist


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with making payments on his account balance at Southern Mississippi. ( _TR_1-3_110414_SouthernMiss_00319)

FI91: November 5, 2014 phone records for a cell phone maintained in his mother's name. This includes, but is not limited to, 13 phone calls with including one call lasting 21 minutes.( 8594571915_042215_SouthernMiss_00319)

FI92: November 6, 2014 Transcript of first interview. This includes, but is not limited to, statements that awas responsible for monitoring and to ensure the cash or prepaid cards were used to pay the balances on their accounts. ( _TR_110614_SouthernMiss_00319)

FI93: November 7, 2014 Transcript of interview. This includes, but is not limited to, statement that he sent around $4,000 to $5,000 in cash and prepaid debit cards to the men's basketball office to assist with making payments on his account balance. ( _TR_110714_SouthernMiss_00319)

FI94: November 18, 2014 Transcript of first interview. This includes, but is not limited to, statement that sent cash and prepaid debit cards to in care of at the men'sbasketball office, and sent prepaid debit cards to in care of at the men's basketball office.( _TR_111814_SouthernMiss_00319)

FI95: January 28, 2015 Transcript of interview. This includes, but is not limited to, statement that he did not remember any specific conversation with regarding a coach paying for a nonqualifier'syear of residence but believed he would have said it needed to be a situation where there was no parental involvement, as well as that had contacted him on his cell phone within the last couple of months to discuss recollection of the conversation about nonqualifiers and coaches paying for their tuition. ( _TR_012815_SouthernMiss_00319)

FI96: March 16, 2015 Transcript of interview. This includes, but is not limited to, statement that (1) he was not part of any conversation between and in June 2012 regarding nonqualifiers but was responsible for putting together the staff notes that reflected the

StudentAthlete H

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Athlete H

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conversation; (2) he maintained handwritten notes contemporaneous to the meetings referenced in the staff notes; however, the note in the Word document may not have been added until 2014; and (3) he discarded the handwritten notes once he updated the Word document. ( _TR_031615_SouthernMiss_00319)

FI97: March 16, 2014 Transcript of second interview. This includes, but is not limited to, statements that (1) he did not discuss with

the appropriateness of receiving cash and prepaid debit cards from in the men's basketball office, (2) he did not discuss with

anyone the appropriateness of communicating directly with about balance and (3) he did not discuss with anyone the appropriateness of creating a similar arrangement for and

( _TR_031614_SouthernMississippi_00319)

FI98: March 27, 2015 Transcript of third interview. This includes, but is not limited to, statements that (1) paid for and year of residence using cash and prepaid cards from his own personal funds, (2) had provide false letters corresponding to amounts being paid for to cover his tracks and (3) talked with and during the course of the NCAA investigation using a burner phones as well as a cell phone maintained in his mother's name and told them to stick to the story that they had paid for and years of residence, respectively. ( _TR_032715_SouthernMiss_00319)

FI99: April 8, 2015 Transcript of second interview. This includes, but is not limited to, statement that he was the source of the funds to ( _TR_040815_SouthernMiss_00319)

FI100: May 12, 2015 Transcript of third interview. This includes, but is not limited to, statement that he contacted multiple people, including and using a cell phone in his mother'sname, to discuss rumors related to the investigation but not to coordinate stories among witnesses.( _TR_051215_SouthernMiss_00319)


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3. [NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-(d) and 19.2.3 (2014-15)]

It is alleged that between August 2014 and June 2015, which was the duration of the NCAA enforcement staff's investigation that serves as a basis for this notice of allegations, former head men's basketball coach, violated NCAA responsibility to cooperate legislation and the NCAA principles of ethical conduct. obstructed the enforcement staff's investigation when he deleted pertinent emails and when he provided false or misleading information to the enforcement staff and the institution. He further obstructed the NCAA investigation by contacting some interviewees about the NCAA investigation and influencing other interviewees to provide false or misleading information to the enforcement staff and the institution concerning matters relevant to possible violations of NCAA legislation. Specifically:

a. Under NCAA responsibility to cooperate legislation, has anaffirmative obligation to cooperate fully with and assist the enforcement staff to further the objectives of the NCAA and its enforcement program and to make full and complete disclosure of any relevant information; however, he obstructed the enforcement staff's efforts to review relevant information by deleting emails pertinent to the matters under inquiry from an account he maintained at Morehead State University (Morehead State).

stated that he deleted the emails, including personal emails and emails pertinent to the inquiry, around the time of his first interview (November 18, 2014) with the enforcement staff on the belief that the enforcement staff would be interested in obtaining the contents of the account, which he was not interested in sharing. [NCAA Bylaws 10.01.1, 10.1, 10.1-(a) and 19.2.3 (2014-15)]

b. violated NCAA principles of ethical conduct when he provided false or misleading information during his November 18, 2014; March 19, 2015; and May 12, 2015, interviews with the enforcement staff and institution when he denied awareness of the improper academic assistance that was provided to men's basketball prospective student-athletes, when in fact he was aware of and oversaw the academic improprieties being committed by his staff members as identified in Allegation No. 1. [NCAA Bylaws 10.01.1, 10.1, and 10.1-(d) (2014-15)]

c. Between August 2014 and May 2015, violated NCAA responsibility to cooperate legislation when he failed to protect the integrity of the NCAA investigation by contacting interviewees or directing others to contact interviewees about the NCAA investigation and to learn from them what they knew about the NCAA investigation. Those

Former MBBHC

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contacted by included assistant men's basketball coach at ,

, high school boys' basketball coach,, then assistant men's basketball coach;

, former associate athletic director for compliance, student services;and then assistant men's basketball coach at

. [(NCAA Bylaws 19.2.3 (2014-15)]

d. violated the NCAA principles of ethical conduct when he provided false or misleading information during his November 18, 2014; March 19, 2015; and May 12, 2015, interviews with the enforcement staff and institution when he denied being the source of the funds provided to men's basketball student-athletes and

to cover educational expenses during their nonqualifier year of residence, when in fact he was the source of those funds. In addition, further violated NCAA principles of ethical conduct when he influenced and high school or prep coaches to provide false or misleading information to the enforcement staff and the institution when he asked the coaches to identifythemselves as the sources for the funds, when in fact had been the source of the funds. [NCAA Bylaws 10.01.1, 10.1 and 10.1-(d) (2014-15)]

e. In November 2014, violated the NCAA principles of ethical conduct and NCAA responsibility to cooperate legislation when he failed to protect the integrity of the NCAA investigation and was involved in an effort to influence an interviewee in the investigation to provide false or misleading information to the enforcement staff and the institution.

told an assistant coach to contact former men's basketball prospective student-athlete , whom the institution had recruited, to tell to report to the enforcement staff that had paid for his Adams State University (Adams State) online courses, when in fact had not done so and instead it had been [NCAA Bylaws 10.01.1, 10.1, 10.1-(d) and 19.2.3 (2014-15)]


The enforcement staff believes a hearing panel of the NCAA Division I Committee on Infractions could determine that Allegation No. 3 is a severe breach of conduct (Level I) because this alleged conduct seriously undermines or threatens the integrity of the NCAA Collegiate Model, as efforts to obstruct the NCAA investigation undermined the NCAA's common interest in investigating alleged violations in an effort to preserve its enduring values.

StudentAthlete F

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Further, provision of false or misleading information and his efforts to influence other interviewees to provide false or misleading information is contrary to the NCAA's high standards of ethical conduct and is presumptively considered to be a Level I violation. [NCAA Bylaw 19.1.1 (2014-15)]


FI101: October 28 through November 6, 2014 phone records for a cell phone maintained in his mother's name. This includes, but is not limited to, 29 calls with 71 calls with (plus 47 texts), 63 calls with (plus 10 texts), five calls with Adams State and one call with a number that has been identified as a burner phone used by

at the .

( 8594571915_042215_SouthernMiss_00319)

FI102: November 18, 2014 Transcript of first interview. This includes, but is not limited to, statement that he was unaware of any NCAA violations that occurred in the men's basketball program during his time at The University of Southern Mississippi (Southern Mississippi). ( _TR_111814_SouthernMiss_00319)

FI103: February 3, 2015 List view of messages remaining in Morehead State email account. This includes, but is not limited to, emails provided by Morehead State that show deleted all messages fromthe time he started at Southern Mississippi up to the time of his first interview in November 2014. ( MoreheadStateEmails_052615_SouthernMiss_00319)

FI104: March 16, 2015 Transcript of second interview. This includes, but is not limited to, statements that he deleted all emails in his Morehead State email account that corresponded to his tenure at Southern Mississippi. ( _TR_031615_SouthernMiss_00319)

FI105: March 27, 2015 Transcript of , assistant men'sbasketball coach, third interview. This includes, but is not limited to,

statements that (1) and, then men's basketball , were hired by to

complete academic coursework for men's basketball student-athletes and



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prospective student-athletes; (2) purchased prepaid debit cards for and to use to register for online courses; (3)

provided cash and prepaid debit cards for and to pay expenses during their year in residence; (4) purchased burner phones for use by and to avoid detection in the investigation; (5) contacted and , assistant men's basketball coach at , using two of the burner phones; (6)

told to call to ensure told the enforcement staff that he paid for his own online courses; (7) witnessed

call from the Blackberry phone and heard tell to stick to the story during the NCAA interview; and (8)

saw use the Blackberry to call during the course of the investigation and also had use one of the burner phones to contact ( _TR_032715_SouthernMiss_00319;

_TR_111914_SouthernMiss_00319; and _TR_112014_SouthernMiss_00319)

FI106: April 1, 2015 Memorandum of conversation with Morehead State

officials. This includes, but is not limited to, a telephone call with the Morehead State general counsel, assistant vice president for technology and technology business analyst in which they explained that all the emails deleted from his account are no longer accessible in light of the institution's 30-day retention policy. (MoreheadStateEmailMemo_CO_040115_SouthernMiss_00319)

FI107: May 12, 2015 Transcript of third interview. This includes, but is not limited to, statement that he was unaware of any NCAA violations that occurred in the men's basketball program during his time at Southern Mississippi. ( _TR_051215_SouthernMiss_00319)

FI108: June 18, 2015 Transcript of interview. This includes, but is not limited to, statement that called him in late August to obtain information about the enforcement staff's interview with then men's basketball prospective student-athlete ( _TR_061815_SouthernMiss_00319_DRAFT)


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4. [NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-(a) and 19.2.3 (2014-15)] It is alleged that between August 2014 and June 2015, which was the duration of the NCAA enforcement staff's investigation that serves as a basis for this notice of allegations, , former

assistant men's basketball coach, violated NCAA responsibility to cooperate legislation and the NCAA principles of ethical conduct when he refused to provide information relevant to an investigation of possible violations of NCAA legislation. Specifically, under NCAA responsibility to cooperate legislation, has an affirmative obligation to cooperate fully with and assist the enforcement staff to further the objectives of the NCAA and its enforcement program and to make full and complete disclosure of any relevant information. However, while provided the requested personal cellular telephone records, he refused to provide any of his bank records when requested to do so by the enforcement staff. These records were relevant to a potential violation related to receiving payment for the commitments of recruited men's basketball prospective student-athletes. Level of Allegation No. 4: The enforcement staff believes a hearing panel of the NCAA Division I Committee on Infractions could determine that Allegation No. 4 is a severe breach of conduct (Level I) because this alleged conduct seriously undermines or threatens the integrity of the NCAA Collegiate Model, as conduct adversely impacted the NCAA's ability to investigate alleged violations, which is critical to the common interests of the Association's membership and the preservation of its enduring values. Furthermore, unethical conduct is a presumptive Level I violation. [NCAA Bylaw 19.1.1 (2014-15)] Factual information (FI) on which the enforcement staff relies for Allegation No. 4: FI109: March 27, 2015 Transcript of , assistant men's

basketball coach, third interview. This includes, but is not limited to, statement that he overheard conversations between

and , then head men's basketball coach, discussing information related to the NCAA investigation. ( _TR_032715_SouthernMiss_00319)

FI110: May 21, 2015 Letter to detailing the efforts and opportunities provided by the enforcement staff to secure records. ( _CO_051215_SouthernMiss_00319;










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_TR_040815_SouthernMiss00319; and _TR_1-3_110414_SouthernMiss00319)

FI111: June 30, 2015 Email from ,

attorney, including, but not limited to, stating that will not provide his bank records. The email also includes language regarding multiple missed deadlines. ( _CO_ _063015_SouthernMiss_00319)


5. [NCAA Bylaws 10.1-(a), 19.2.3, and 19.2.3.2]

It is alleged that between November 2014 and March 2015, former men's basketball , violated the NCAA principles of ethical conduct when he refused to furnish information relevant to the investigation of possible violations of NCAA legislation, when requested to do so by the NCAA enforcement staff. Further, violated the responsibility to cooperate legislation by failing to make full and complete disclosure of relevant information, when requested to do so by the enforcement staff. Specifically, on November 11, 2014, the enforcement staff scheduled an interview with to be conducted November 18, 2014; however refused to appear or participate. Moreover, has continued to refuse to participate despite multiple attempts by the enforcement staff to arrange an interview. Level of Allegation No. 5: The enforcement staff believes a hearing panel of the NCAA Division I Committee on Infractions could determine that Allegation No. 5 is a severe breach of conduct (Level I) because this alleged conduct seriously undermines or threatens the integrity of the NCAA Collegiate Model, as refusal to interview with the enforcement staff adversely impacts the NCAA's ability to investigate alleged violations, which is critical to the common interests of the Association's membership and the preservation of its enduring values. Furthermore, unethical conduct is a presumptive Level I violation. [NCAA Bylaw 19.1.1 (2014-15)]






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Factual information (FI) on which the enforcement staff relies for Allegation No. 5: FI112: November 2014 through April 2015 On November 17, 2014, the

enforcement staff had a scheduled interview with at the . resigned his position on the

staff three days prior to his November 17, 2014, scheduled interview with the enforcement staff. In January and March 2015, letters were sent by the enforcement staff to requesting interviews. (InterviewStatusChart_022715_SouthernMiss_00319;

CO_InterviewRequest_010514_SouthernMiss_00319; and CO_InterviewRequest_030315_SouthernMiss_00319)

FI113: February 11 and 12, 2015 The enforcement staff went to home in

, to request an interview. During a telephone call the next day, mother confirmed that they relayed the request to

. (InterviewStatusChart_022715_SouthernMiss_00319)

FI114: March 24, 2015 Phone call with , an attorney representing , advised the enforcement staff that declined to interview with the NCAA and terminated representation. (InterviewStatusChart_022715_SouthernMiss_00319)


6. [NCAA Bylaws 10.1-(a), 19.2.3 and 19.2.3.2]

It is alleged that between September 2014 and March 2015, , former associate men's basketball coach, violated the NCAA

principles of ethical conduct when he refused to furnish information relevant to the investigation of possible violations of NCAA legislation, when requested to do so by the NCAA enforcement staff and the institution. Further,violated the responsibility to cooperate legislation by failing to make full and complete disclosure of relevant information, when requested to do so by the enforcement staff. Specifically, refused to participate in an interview with the enforcement despite multiple attempts by the enforcement staff to arrange an interview.


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Level of Allegation No. 6: The enforcement staff believes a hearing panel of the NCAA Division I Committee on Infractions could determine that Allegation No. 6 is a severe breach of conduct (Level I) because this alleged conduct seriously undermines or threatens the integrity of the NCAA Collegiate Model, as refusal to interview with the enforcement staff adversely impacts the NCAA's ability to investigate alleged violations, which is critical to the common interests of the Association's membership and the preservation of its enduring values. Furthermore, unethical conduct is a presumptive Level I violation. [NCAA Bylaw 19.1.1 (2014-15)] Factual information (FI) on which the enforcement staff relies for Allegation No. 6: FI115: September 15, 2014 Call to in which he respectfully declined

to interview with the enforcement staff. (InterviewStatusChart_022715_SouthernMiss_00319)

FI116: November 11, 2014 Call to in which the enforcement staff informed that serious allegations had been made against him and the enforcement staff again requested an interview. declined and stated that he would hire an attorney to protect his name. (InterviewStatusChart_022715_SouthernMiss_00319)

FI117: December 10, 2014 A letter to requesting an interview for the third time and stating that should he refuse to interview, then the enforcement staff would consider naming him in a failure to cooperate allegation. ( _CO_121014_SouthernMiss_00319)

FI118: January 26, 2015 During the enforcement staff's second interview with then assistant men's basketball coach,

reported that confirmed that he had received a letter from the NCAA asking to participate in an interview regarding alleged violations. ( _TR_012615_SouternMiss_00319_DRAFT)

FI119: March 3, 2015 Final letter requesting an interview of in which there was no response. ( _CO_Int

Documents

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