3

requested that I record the statement. A transcript of the recorded statement made by Attorney
Kurtz is as follows:

Attorney Robert Kurtz: I just want the recording to reflect that Susan
Martin Provost at the University was in here before the recording and read a
statement, a prepared statement, that I think Ms. Beck has kept a copy of. We
would ask for a copy of that at your convenience. But the summary of the
statement was that if, that the University believed that this investigation is time
sensitive and that the University was asking Ms. Wright to cooperative and if she
did not agree to the interview today that would be viewed as insubordination and
could result or more than likely would result in her termination. Ms. Martin also
stated that any interference, contact with any students or any employees or staff
members would be viewed as insubordination as well and would also result in Ms.
Wrights termination. My information is that the University has known about
these allegations since at least April 9, 2013. Ms. Wright learned that she was
going to be placed on paid administrative leave at noon today. She was asked to
meet with General Counsel at 2:00 p.m. She arrived and was willing to come to
this meeting not knowing what the meeting was about. When we arrived we
discussed what the allegations were. That was the first notice that we had of this
and as her lawyer I told Beecher Bartlett and Ms. Beck that we were willing to
cooperate but first we would like to have an opportunity to speak with each other
and that we would like to arrange for an additional interview with you all later
this week. That is still our position. Ms. Wright is willing to cooperate. She is
willing to assist in the investigation to provide any information that she has
knowledge of but she is still going to insist upon speaking to her lawyer before
that takes place. If we are not going to let the University dictate, even if it is
going to mean her employment, the timing of this interview. We will cooperate
with all due haste, we will be reasonable, but we cant do it today. But we are
willing to, I will make myself available tomorrow or Friday. Friday is better for
me but I will make us both available either of those days for an interview.

Beecher Bartlett: Alright, thank you.

The University agreed to reschedule Ms. Wrights interview for Friday morning, May 10, 2013.
Later in the day on May 8, after I had returned to my office, Attorney Kurtz called and stated that
his client wished to resign from the University of Tennessee with more than a neutral
reference, payment in the amount of nine weeks of accrued annual leave and the ability to
continue her health benefits through COBRA. The University declined that request.

Ms. Wright wrote a letter of resignation dated May 9, 2013, but the letter was not received by the
University until May 10. The University did not accept Ms. Wrights resignation. When she
failed to appear for the rescheduled interview on Friday, May 10, 2013, the University notified
Ms. Wright that she would be terminated and offered her an opportunity for a pre-termination

4

meeting with Provost Susan Martin on Monday, May 13. Ms. Wright did not appear for the pre-
termination meeting, and she was terminated effective May 13 for failing to comply with the
directive to cooperate with the investigation.

Summary of Ashley Blamey Interview

Ashley Blamey is employed by the University of Tennessee as Director of Safety, Environment
& Education Center. Ms. Blamey met J enny Wright through her work at the University of
Tennessee approximately five years ago. Ms. Blamey and Ms. Wright served on the Case
Management Team together. Ms. Blamey and Ms. Wright have become friends through work,
but do not routinely socialize outside the work environment.

J enny Wright informed Ms. Blamey that she had seen Brad Pendergrass casually and Ms.
Blamey formed the impression that they did not see one another for any length of time and may
have only briefly dated. Ms. Wright informed Ms. Blamey that Mr. Pendergrass made
statements to Ms. Wright that made her feel concerned about her professional and personal
safety. Ms. Wright informed Ms. Blamey that Mr. Pendergrass made statements to the effect
that they could take her down and they could make her pay. According to Ms. Blamey,
J enny Wright further informed her that athletics could get rid of Tim Rogers and that they
(athletics) had all the power.

Ms. Blamey accompanied Ms. Wright to the Office of Equity & Diversity on the campus of the
University of Tennessee and they met with the Director, Marva Rudolph. Ms. Wright generally
described her concerns over the communications with Mr. Pendergrass without revealing his
name. Marva Rudolph encouraged Ms. Wright to file a formal report with the Office of Equity
& Diversity. Further, she recommended that Ms. Wright set very clear limits with the individual
and document previous and future interactions. Ms. Blamey believes that Ms. Wright did not file
a formal complaint due to the fact that she felt professionally intimidated. Ms. Wright informed
Ms. Blamey that she had a conversation with Brad Pendergrass and informed him that any future
statements he made would be reported.

Ms. Blamey stated that Ms. Wright is very private and did not share her personal life with her.
She knew that Ms. Wright was single and dated from time to time. The only person she knows
that Ms. Wright dated was Brad Pendergrass.

Summary of Brian Russell Interview

Brian Russell is employed by the University of Tennessee as the Director of Programs and
Services Division for the Thornton Center. Mr. Russell was married to J enny Wright from J uly
2005 until the fall of 2010 when they were divorced. Mr. Russell did not communicate with Ms.
Wright after the divorce. Mr. Russell stated that Ms. Wright was credible, reliable and he was
aware of no dishonesty or infidelity during the marriage. Mr. Russell never represented any
student athletes before the Office of Student J udicial Affairs. He heard no rumors about any

8

Soon after Ms. Shivers arrived on campus, J enny Wright informed her that she was divorced and
showed her a picture of a man that Ms. Wright was dating. Ms. Shivers did not recognize the
man and Ms. Wright informed Ms. Shivers that he was from out of town. Ms. Shivers heard
rumors from students that Ms. Wright was friendly with athletes. Ms. Shivers did not pursue
these reports with students due to the fact that J enny Wright reported to Tim Rogers.

Ms. Shivers attended and knew as a player, but did not know him
personally.

Summary of Angi Smith Interview

Ms. Smith is currently employed by Young Harris College in the state of Georgia. She received
her undergraduate and law degrees from University of Tennessee. At the time she left the
University of Tennessee, she was the Associate Dean of Students. Ms. Smith was the director of
the Office of Student J udicial Affairs at the University of Tennessee for a period of time.

Ms. Smith met J enny Wright in approximately 2003 when Ms. Wright became a student worker
in the office of the Vice Chancellor. Ms. Smith taught Ms. Wright a higher education law class
in graduate school and stated that Ms. Wright was an excellent student. Ms. Smith supervised
Ms. Wright for a period of time in the Office of Student J udicial Affairs. She described Ms.
Wright as one of the best employees she had ever had. She stated that Ms. Wright had great
initiative, had pride in her work and had an incredible work ethic. Ms. Smith occasionally
socialized with J enny Wright before leaving her employment at the University of Tennessee to
go to Young Harris College in October 2012. Ms. Smith described Ms. Wright as being very
private and did not share a lot about her personal life with Ms. Smith.

Ms. Smith stated that she knew Ms. Wright had engaged in a romantic relationship with Brad
Pendergrass. Ms. Wright informed Ms. Smith that at the time the relationship ended between
Wright and Pendergrass, Pendergrass informed Wright during a discussion about a student
athlete before the Office of Student J udicial Affairs that Wright was not going to get away with
the situation and athletics would take her down. Ms. Smith informed Ms. Wright that she should
document the situation and possibly seek further counsel from Marva Rudolph or let the Vice
Chancellor know about the situation. Ms. Wright informed Ms. Smith that she had consulted
with Marva Rudolph and Ms. Smith does not know whether Ms. Wright consulted with the Vice
Chancellor.

Ms. Smith believes that Ms. Wright had possibly been involved in a romantic relationship with
an assistant coach, but she could not recall his name.

Ms. Smith does not know or . Ms. Smith stated that based upon her
opinion of J enny Wright and her commitment to the University, Ms. Smith could not imagine
that Ms. Wright would engage in any type of inappropriate conduct related to a student.


9

Summary of Sharlene Huffaker Interview

Sharlene Huffaker has been employed as an Administrative Assistant in the Office of Student
J udicial Affairs at the University of Tennessee for 11 years. She is currently supervised by
J ames J ackson and was supervised in the past by J enny Wright. Ms. Huffaker has known J enny
Wright for 10 years and has worked with her for six years. Ms. Huffaker stated that she has an
excellent relationship with Ms. Wright and the two enjoy a mutual respect for one another.

Ms. Huffaker knew that came to the Office of Student J udicial Affairs as a result of
a charge of misconduct of some kind. She believes that she may have seen in the
Office of Student J udicial Affairs a couple of times. Ms. Huffaker heard nothing about any kind
of unprofessional relationship between J enny Wright and or any other players or
coaches. Ms. Huffaker had no knowledge that J enny Wright ever dated a student, student
athlete, coach, assistant coach or anyone employed by the Athletic Department. Ms. Huffaker
never observed any conduct on the part of J enny Wright that she viewed as being unprofessional
or inappropriate.

Sharlene Huffaker was very complimentary of J enny Wright and stated that you could not find
anyone who was kinder or nicer. Ms. Huffaker stated that she could not have had a better boss.
She stated that Ms. Wright did her job very well.

Ms. Huffaker pointed out that the Director of J udicial Affairs is confronted with students and
parents of students who feel as though their discipline is not just.

Summary of W. Timothy Rogers Interview

Mr. Rogers received his Doctorate of J urisprudence from the University of Tennessee in 1980
and has been employed by the University of Tennessee since that time, most recently as the Vice
Chancellor of Student Life. Mr. Rogers met J enny Wright when she was involved in student
leadership organizations while an undergraduate at the University of Tennessee. Wright worked
in various capacities for the University after graduating from undergraduate school. Mr. Rogers
was also acquainted with Ms. Wrights parents. Mr. Rogers communicated by telephone with
Ms. Wright multiple times a week on issues involving the Office of Student J udicial Affairs. He
saw her at staff meetings and on various task forces.

Mr. Rogers stated that there are job descriptions, written policies and procedures for the Office
of Student J udicial Affairs. He stated that, although there was no written prohibition for Office
of Student J udicial Affairs employees dating students, coaches or assistant coaches, he routinely
informed employees in the Office of Student J udicial Affairs that they should not date students,
coaches or assistant coaches. Mr. Rogers stated that he believed it would have been
inappropriate for J enny Wright to date any athletic coach or assistant coach and, in particular, it
would have been inappropriate for her to date Brad Pendergrass.


11


J enny Wright has reported directly to Vice Chancellor Tim Rogers since August of 2011 and
reported to Dean of Students Maxine Davis prior to August 2011. Ms. Wright reported that there
was a written protocol for student conduct published in the Hilltopics Student Handbook which
included 29 standards of conduct governing student behavior.

J enny Wright met Brad Pendergrass in August 2010 when he was hired as Director of Football
Operations. Ms. Wright would contact Brad Pendergrass or Senior Associate Athletics Director
David Blackburn regarding charges of misconduct against football players. Ms. Wright would
contact either Blackburn or Pendergrass to schedule a meeting with the student athlete.
Occasionally, either Blackburn or Pendergrass would sit in on the meetings with the student
athletes in the Office of Student J udicial Affairs, depending on the seriousness of the charge of
misconduct. Ms. Wright stated that in the fall of 2010, she saw Mr. Pendergrass socially and
would hang out with him. She stated that she saw him socially no more than three times. Ms.
Wright was asked if she was romantically involved on the three occasions and her lawyer
responded by stating lets just say that they were involved for a very brief time. Ms. Wright
stated that the last time she saw Mr. Pendergrass outside of a work context would have been in
J anuary or February of 2011.

For a period of time thereafter, Ms. Wright did not have much contact with Mr. Pendergrass
because the football players were not involved in any misconduct charges brought to J udicial
Affairs. On three or four occasions, Mr. Pendergrass expressed frustration with the way Ms.
Wright handled cases by making statements like youve got to be kidding me. Are you really
doing this? It is not that bad. I know this isnt you. I know this is Tim (meaning Vice
Chancellor Rogers). J enny Wright claimed that Brad Pendergrass would make statements along
the lines of I dont know why Tim Rogers has such a problem with athletics, why he hates us so
much, Derek Dooley could get rid of him, he could have his job.

In the fall of 2012, there was a student athlete with a very extensive previous discipline history
who had engaged in misconduct that was handled through the Office of Student J udicial Affairs.
Ms. Wright stated that this individual was a football player that the team did not want to lose.
The athlete failed to appear for a scheduled appointment, and when questioned about his failure
to appear, he claimed that he had a class. Ms. Wright showed the student his class schedule and
asked him if he wished to continue to maintain his position that he was in class and informed him
that he could be charged with a violation for providing false information. Given the fact that he
continued to maintain his position, the student was charged with a violation for providing false
information and ultimately received a reprimand as punishment. Subsequently, Athletic Director
Dave Hart expressed his disapproval to Ms. Wright about how Ms. Wright handled the case and
expressed his frustration claiming that Ms. Wright was over-prosecuting cases. Vice Chancellor
Rogers also informed Ms. Wright that Dave Hart felt like the Office of Student J udicial Affairs
was over-prosecuting cases. Ms. Wright was instructed by Vice Chancellor Rogers to let him
know of any high profile cases that were before the Office of Student J udicial Affairs. Ms.
Wright stated that she did not believe that she treated athletes differently than non-student

12

athletes. Ms. Wright stated that Brad Pendergrass called her on the phone and made a statement
to the effect of either you think you can hide from us or you think you can run from us.
Shortly after that, she received another call from Brad Pendergrass and he informed Ms. Wright
that he was calling her as a friend and wanted her to know that she needed to be careful. Ms.
Wright asked what he meant by this and he stated that he was not judging her but if she chose to
sleep with football players she needed to be careful about that. Ms. Wright asked Mr.
Pendergrass where he received this information, and he declined to tell her by stating that it did
not matter and was irrelevant. Ms. Wright denied the accusations and Mr. Pendergrass stated
that he was not judging her and told her that she could do whatever she wanted but should be
careful.

Ms. Wright claims that she became concerned for herself and was afraid of what could happen.
She became concerned of what the Athletics Department could do in terms of her job and she
discussed these facts with her mother and some of her close friends and colleagues. She decided
to go to the Office of Equity and Diversity where she talked with the Director in September
2012. Ms. Wright explained to the Director Marva Rudolph, that she was afraid that the
Athletics Department was going to try to get rid of her based on comments she had received.
Ms. Wrights friend and colleague, Ashley Blamey, was present during the conversation with
Ms. Rudolph. Ms. Wright did not identify Brad Pendergrass by name. Ms. Wright asked that
there be no investigation. Ms. Wright was given the opportunity to file a formal complaint with
the Office of Equity and Diversity and chose not to do so.

Ms. Wright subsequently called Brad Pendergrass and told him that if he had any concerns about
anything she was doing as it related to her job, then he needed to address those through the
proper channels, whether it meant going to Equity and Diversity, but he did not need to pick up
the phone and call her about the issue. Mr. Pendergrass responded by saying something like,
Okay. Ms. Wright did not discuss the matter further with Mr. Pendergrass or have any follow
up communication with him until Tuesday, May 14, 2013. Ms. Wright stated that the text
message read as follows:

As a friend, just wanted to reach out and say Im sorry youre having to go
through all this. Im sure its difficult. Best of luck as you start a new chapter in
your life.

Ms. Wright was asked if any other persons in athletics or otherwise had treated her similarly to
the treatment by Mr. Pendergrass. She responded by saying that other than the conversation with
Dave Hart, no one else had treated her in a similar manner to that which she experienced from
Mr. Pendergrass. She stated that all of her interactions with David Blackburn had been positive.

At the conclusion of the interview, I informed Ms. Wright that there were many other subjects
that I wished to ask her questions about, however, her attorney stated that other subjects would
not be allowed. Therefore the Investigator could not investigate any of the allegations raised by
on behalf of .

13


Summary of Interviews of Bradley Pendergrass

I conducted interviews with Mr. Pendergrass on May 8, May 14 and September 9, 2013. The
first two interviews were conducted before J enny Wright gave a limited statement.

On May 8, 2013, Mr. Pendergrass informed me that he had served as the Director of Football
Operations at the University of Tennessee for three years. His job duties include day to day
operations for the University of Tennessee football team, coordination of team travel and
organization of training camps. Mr. Pendergrass stated that he had heard that J enny Wright was
messing around with a player but he did not know the identity of the player or what sport the
player allegedly played. Mr. Pendergrass heard this information sometime between April of
2010 and . Mr.
Pendergrass was asked whether he knew about any inappropriate relationships between Ms.
Wright and students and he made the following quote: No, nothing I think is substantial.

Mr. Pendergrass stated he always found Ms. Wright to be professional. He stated that he was not
aware of any relationships between Ms. Wright and any students that influenced her decisions or
the discipline which followed charges of misconduct. Mr. Pendergrass stated that he does not
personally know or .

During the follow-up interview on May 14, 2013, Mr. Pendergrass stated that as Director of
Football Operations he handles any business matters pertaining to football players with regard to
housing, meals, scholarships or issues that a player may have on campus such as a charge of
misconduct. Depending on the severity of the charge of misconduct, Mr. Pendergrass would sit
in on some meetings between football players and officials in the Office of Student J udicial
Affairs. Mr. Pendergrass denied that he ever engaged in any arguments or disagreements with
Ms. Wright and felt that the discipline that she recommended for players was appropriate. He
stated that he was not in a position to disagree with or contest any discipline she recommended.

September 9, 2013 Brad Pendergrass Interview

Mr. Pendergrass was interviewed for a third time with his attorney, Tom J ones, on September 9,
2013. Attorney J ones made a preliminary statement on behalf of Mr. Pendergrass. J ones stated
that in the summer of 2010 Mr. Pendergrass had a one-time sexual encounter with J enny Wright
after running into her in the Old City. Mr. Pendergrass did not consider the encounter to amount
to an affair or relationship.

Mr. Pendergrass reviewed his educational background and employment history during the
interview. He again stated that he returned to the University of Tennessee in April of 2010 as
Director of Football Operations. He was hired by Mike Hamilton, Athletic Director, David
Blackburn, Senior Associate Athletic Director and head football coach Derek Dooley. In 2010
Mr. Pendergrass was supervised by Mike Hamilton, David Blackburn and Derek Dooley.

14


Mr. Pendergrass contacted the Office of Student J udicial Affairs to insure that any football
student athlete facing a charge of misconduct appeared for all appointments before the Office of
Student J udicial Affairs. From time to time, he sat in on meetings between student athletes and
personnel in the Office of Student J udicial Affairs. David Blackburn also sat in on these
meetings from time to time. Mr. Pendergrass stated that his role was advisory only, and he did
not participate in any decision making role with respect to penalties. Mr. Pendergrass recalls that
J enny Wright sat in on some meetings and he recalls that Maxine Davis sat in on one meeting.
Mr. Pendergrass denied that he ever disagreed with any proposed penalty or charge of
misconduct against a student athlete. He recalls one incident involving a student athlete that did
not appear for a meeting with the Office of Student J udicial Affairs as scheduled. Mr.
Pendergrass, David Blackburn and the head football coach became upset after the player failed to
keep his appointment because the three of them were not informed about that particular
appointment and, in turn, were unable to help facilitate the scheduling process.

Mr. Pendergrass stated that in the summer of 2010 he bumped into J enny Wright in the Old
City which resulted in a one-time sexual encounter between the two. He stated that he would not
term the encounter as romantic and further stated that it was independent with anything having
to do with any type of business setting.

Again, Mr. Pendergrass stated that he did not know or personally. Mr.
Pendergrass has no information about any relationship that Ms. Wright may have had with
or . Mr. Pendergrass never appeared before any actual hearings before the
Office of Student J udicial Affairs.

When asked if he ever expressed any frustration to Ms. Wright about the way she was handling a
particular charge of misconduct with a football player, Mr. Pendergrass stated that he was not in
a situation, given his job title and responsibilities, to have any sort of opinion about the way that
Ms. Wright handled her job in the Office of Student J udicial Affairs. Mr. Pendergrass stated that
Ms. Wright was always professional in the way she dealt with student athletes in the Office of
Student J udicial Affairs. Mr. Pendergrass denied that he ever made a comment to Ms. Wright
that was threatening. Mr. Pendergrass denied that he ever told Ms. Wright that he did not know
why Tim Rogers had such a problem with athletics, why he hates athletes so much and that
Derek Dooley could get rid of him. Mr. Pendergrass denied that he ever became aware that Ms.
Wright was uncomfortable about any remarks that he was making about the way charges of
misconduct were being handled. Mr. Pendergrass denied that Dave Hart ever expressed to him
any dissatisfaction about the way student athlete cases were being handled in the Office of
Student J udicial Affairs. Mr. Pendergrass denied having any discussions with Dave Hart about
any dissatisfaction that Mr. Hart may have had in the way he may have perceived student athlete
cases in the Office of Student J udicial Affairs. Mr. Pendergrass denied that Dave Hart ever told
him that the Office of Student J udicial Affairs was over prosecuting cases. Mr. Pendergrass
denied that he ever told J enny Wright that he, or anyone on behalf of the Athletics Department,
believed that she was over-prosecuting cases or words to that effect. Mr. Pendergrass denied

15

ever telling Ms. Wright that she could not hide or run from them. Mr. Pendergrass denied telling
Ms. Wright that he was calling her as a friend and wanted her to know that she should be careful.
Mr. Pendergrass denied that he ever told her that he was not judging her, but if she chose to sleep
with football players, she needed to be careful about that. Mr. Pendergrass denied that he ever
had any discussion with Ms. Wright about sleeping with football players. Mr. Pendergrass
denied that Ms. Wright ever told him that she was afraid or concerned that Mr. Pendergrass or
others in the Athletic Department may try to put her job in jeopardy. Mr. Pendergrass denied
that he ever formed the impression that Ms. Wright was afraid of Mr. Pendergrass or was
concerned that Mr. Pendergrass or others in the Athletic Department may try to put her job in
jeopardy.

Mr. Pendergrass denied knowing that Ms. Wright met with Marva Rudolph in the Office of
Equity and Diversity to talk about any concerns that Ms. Wright had about her communications
with Mr. Pendergrass. Mr. Pendergrass denied ever saying anything to J enny Wright that could
have been interpreted to mean that the Athletic Department was threatening her job or the job of
Tim Rogers. Mr. Pendergrass stated that he is unaware of any charges of misconduct before the
Office of Student J udicial Affairs that were not handled appropriately or fairly.

Summary of Becky Dahl Interview

Becky Dahl is the Assistant Director of Programs at the Department Recreational Sports at the
University of Tennessee. She met J enny Wright at a Student Life meeting in August of 2012.
Ms. Dahl performs student judicial checks with respect to employees and refers students to the
Office of Student J udicial Affairs who have issues that may fall under that jurisdiction. Ms. Dahl
has never assisted or represented a student athlete before the Office of Student J udicial Affairs.
Ms. Dahl interacted professionally with Ms. Wright on a limited basis at the University of
Tennessee and was a friend with Ms. Wright outside of work. They spent a fair amount of time
having lunch, dinner and watching sports. They talked frequently.

Ms. Dahl stated that over the past several months leading up to the summer of 2013, J enny
Wright had confided to her on several occasions that she was afraid that she would lose her job
and she was under pressure to perform her job in a certain way that she felt was not in the best
interest of the students. Ms. Wright did not go into any specific details, but simply said there
was some pressure to make decisions that she did not feel were right. Ms. Wright did not
identify the person who was putting pressure on her, but identified the position of the person
putting pressure on her to be the Athletic Director who could have caused her to be terminated or
reprimanded and she was afraid of him.

Ms. Wright also confided to Ms. Dahl that there had been an accusation made against her by a
student athlete that had caused her a lot of stress. Ms. Wright did not identify the accuser by
name and did not go into any details about the situation. Ms. Dahl stated that Ms. Wright had
previously informed her that she had filed some type of complaint about someone who had said
harassing things to her. Ms. Dahl is not aware that J enny Wright has ever dated any student

16

athletes, coaches or assistant coaches at the University of Tennessee. Ms. Dahl emphasized that
Ms. Wright cared very much about her job and about the University of Tennessee. She stated
that Ms. Wright wanted to make sure that all students were treated equally and fairly.

Ms. Wright told Ms. Dahl that her supervisor had made her aware that there had been an
accusation against her before the accusation became public. Ms. Wright did not go into any
specifics with Ms. Dahl about the accusation. Ms. Wright told Ms. Dahl that a gentleman had
been asking her out for dinner and she found out that he was in graduate school at the University
of Tennessee and she declined on the basis that it would not be proper for her to date a graduate
student based on her position. Ms. Dahl has heard rumors that have arisen
and she does not believe them.

Summary of David Blackburn Interview

David Blackburn was hired by Coach Phillip Fulmer in 1993 and worked continuously with the
football program in various capacities, including Director of Football Operations, until April 27,
2013, when he became the Athletic Director at the University of Tennessee Chattanooga.
Through the years, he met with J enny Wright in the Office of Student J udicial Affairs on charges
of misconduct involving football players. Mr. Blackburn found Ms. Wright to be extremely
hardworking and pleasant to deal with. Mr. Blackburn had a good working relationship with
Tim Rogers. Mr. Blackburn never formed the opinion that Ms. Wright or Mr. Rogers were ever
lenient on high profile players, and to the contrary, believed that Wright and Rogers were a little
stricter on the high profile players receiving public attention through the media. David
Blackburn knew and was very complimentary of Ms. Wrights ex-husband, Brian Russell.
David Blackburn did not believe that the Office of Student J udicial Affairs had ever been lenient
in any way with players in the discipline they received for charges of misconduct. If anything,
he believed that the Office may have been a little harder on these players based on the publicity
they received.

Summary of Maxine Davis Interview

Maxine Davis has been employed by the University of Tennessee for 33 years and currently
serves in the position of Dean of Students. Ms. Davis met J enny Wright a number of years ago
when Ms. Wright was an undergraduate at the University of Tennessee. Ms. Davis advised the
Student Government Association. J enny Wright was very active in this organization.

Ms. Davis described Ms. Wright as being very personable and polite. Ms. Davis knew Ms.
Wright during the period of time that Ms. Wright attended the law school at Tennessee. Ms.
Wright worked as a judicial advisor in the Office of Student J udicial Affairs and reported to
Maxine Davis for a period of time. Ms. Wright became the Interim Director of J udicial Affairs
and reported to Ms. Davis. Ms. Wright was appointed by Ms. Davis to the position of the
Director of J udicial Affairs. Vice Chancellor Tim Rogers approved the appointment. Ms. Davis

28

characterized as dating, it was inconsistent with Vice Chancellor Rogers directive to
all Student Life employees against dating students, coaches or assistant coaches. At the
very least, it was inconsistent with his specific caution to Ms. Wright against any
relationships that would raise any appearance of impropriety or conflict of interest.

7. During the investigation several interviewees referred to a relationship between Ms.
Wright and an assistant football coach. The most specific reference was by Traci
Leonard who said that J enny Wright told her about a relationship with Terry J oseph while
he was an assistant football coach at U.T. Mr. J oseph initially indicated that he wanted to
be interviewed in order to refute Ms. Leonards statement, but he later declined to be
interviewed. J enny Wright also refused to be interviewed about any matter other than her
involvement with Brad Pendergrass.

8. J enny Wright asserts she became concerned that her job could be in jeopardy based upon
comments that were made to her by Brad Pendergrass about the manner in which Ms.
Wright was handling complaints of misconduct against student athletes. Mr. Pendergrass
denied that he said anything to Ms. Wright which should have caused her any concern
over her job. In the event Mr. Pendergrass made the statements alleged by Ms. Wright,
these comments were inappropriate and should not have been made.

RECOMMENDATIONS

1. The Chancellor should direct the Vice Chancellor for Student Life to develop a written
departmental policy on the subject of prohibited relationships with University students
and employees and to require all employees of the Division of Student Life to
acknowledge in writing that engaging in a prohibited relationship will be grounds for
disciplinary action, including termination of employment.

2. The Chancellor should direct the Vice Chancellor and Director of Athletics to develop a
written departmental policy on the subject of prohibited relationships with University
employees who have responsibilities related to student disciplinary actions and
compliance matters and to require all employees of the Athletics Department to
acknowledge in writing that engaging in a prohibited relationship will be grounds for
disciplinary action, including termination of employment.

3. The Chancellor should issue a communication to all employees of the Athletics
Department that threats against a University employee in an effort to impede the
exercise of responsibilities related to student disciplinary actions and compliance matters
would be a violation of the Universitys Code of Conduct and grounds for disciplinary
action, including termination of employment.