Tyndall

CONFIDENTIAL/VIA ELECTRONIC MAIL
July 22, 2015
President Rodney Bennett

The University of Southern Mississippi
c/o Mr. William King
Lightfoot, Franklin & White, LLC
The Clark Building
400 20th Street North
Birmingham, 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 imposes
an 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.

July 22, 2015
Page No. 2
__________
Please submit the response and exhibits via email in Microsoft Word format to Joel McGormley,
Email Address
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 is
required 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

July 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 basketball
coach; 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 advise
Mr. 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 19
and 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
Email Address
staff can be of assistance, please contact me; Tom Hosty, director of enforcement, at
; or
Email Address
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 Feig
Mr. Bill McGillis
Dr. Dennis Phillips
NCAA Division I Committee on Infractions
Selected NCAA Staff Members
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)]
Former MBB HC
It is alleged that between June 2012 and May 2014,

,
Former MBB Asst. 2
then head men's basketball coach;
then associate
Former MBB Asst. 3
head men's basketball coach;
then assistant men's
Former MBB Staff Member 2
basketball coach; Former MBB Staff Member 1 and
then men's
Staff Members
basketball
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
Former MBB
seven then men's basketball prospective student-athletes. In one instance, HC
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.
20##
In the spring and summer of

then men's basketball prospective
Student Athlete A
JUCO 1
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
Student Athlete A
impermissibly completed work in these courses for
at the
Former MBB
direction of
This amounted to fraudulent academic credit and
HC
resulted in inaccurate information being provided to the admissions office
at The University of Southern Mississippi (Southern Mississippi)
Student Athlete A
regarding
academic record, which was used by the
Former MBB Staff Member
2
Former MBB Staff

Member 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.
Case No. 00319
July 22, 2015
Page No. 2
__________
20##-##
institution to certify his transfer eligibility for the

academic year.
Student Athlete A
subsequently enrolled at Southern Mississippi, competed for
and received travel expenses as part of the men's basketball team during
20##-##
20##-##
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)]
S
Student Athlete F
b.
20##
In the summer of
then men's basketball prospective student-athlete

JUCO 2
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)
Former MBB
Former MBB Staff
MATH 104 Finite Mathematics. Member 2 and Staff Member 1 knowingly and
impermissibly completed work in these courses for StudentBAthlete at the direction
Former MBB
of
This amounted to fraudulent academic credit and resulted in
HC
inaccurate information being provided to the admissions office at Southern
Student Athlete
Mississippi regarding
academic record, which was used by the
B
20##-##
academic year.
Student
subsequently enrolled at Southern Mississippi, competed for and
Athlete B
received travel expenses as part of the men's basketball team during the
20##-##
20##-##
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)]
Student Athlete B
c.
In the spring of
20##

JUCO 3
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)
Former MBB Staff
MATH 104 Finite Mathematics. Member 2 and
knowingly and
impermissibly completed work in these courses for
at the direction
Former MBB
of
and through the involvement of a then assistant men's
HC
Student
basketball coach, amounting to fraudulent academic credit. Athlete C
Date of Committment
committed to Southern Mississippi in
but never enrolled at
the university. [NCAA Bylaws 10.01.1 10.1, and 10.1-(b) (2012-13)]
Student Athlete C
Former MBB Staff

Member 1
Student Athlete
C
d.
In the spring of
20##

JUCO 4
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.
Former MBB Staff
Member 2
and
knowingly and impermissibly completed work in these
Student
Former MBB
courses for Athlete D at the direction of HC
and through the involvement of
Former MBB
, amounting to fraudulent academic credit.
subsequently
Asst. 2
Student Athlete D
Former MBB
Staff Member 1
Student
Athlete D
Case No. 00319
July 22, 2015
Page No. 3
__________
enrolled at Southern Mississippi, competed for and received travel

20##-##
expenses as part of the men's basketball team during the
season;
however, these credits were not accepted by the institution as transferable
credit 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)]
20##
e.
In the spring and summer of

then men's basketball prospective
Student Athlete E
JUCO 5
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 Former
104MBBFinite Mathematics; and (4) MATH 155
Staff Member 1
Integrated Mathematics.
knowingly and impermissibly completed
Student
Former MBB
coursework for Athlete E at the direction of
and through the
HC
Former MBB
Former MBB
Former MBB Asst.
Staff Member 1
involvement of Asst. 3 . In addition, an associate of
and
3
Student
also completed coursework for Athlete E This amounted to fraudulent
academic credit and resulted in inaccurate information being provided to
Student
the admissions office at Southern Mississippi regarding Athlete E academic
record, which was used by the institution to certify his transfer eligibility
20##-##
Student
for the
academic year. Athlete E subsequently enrolled at Southern
Mississippi, competed for and received travel expenses as part of the
20##-##
20##-##
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
20##

JUCO 1
from
, a two-year
college, was enrolled in two online courses at Adams State: (1) ENG 101
Former MBB
Communication Arts I and (2) ENG 102 Communication Arts II. HC
paid for the registration of these courses with prepaid
debit cards that were
Former MBB Staff
Member 2
purchased at a CVS pharmacy store in New York.
knowingly and
Student
Former MBB
impermissibly completed coursework for Athlete F at the direction of HC
and through the involvement of a then assistant men's basketball coach.
This amounted to fraudulent academic credit and resulted in inaccurate
information being provided to the admissions office at Southern
Student
Mississippi regarding Athlete F academic record, which was used by the
20##-##
academic year.
Student
subsequently enrolled at Southern Mississippi for the second
Athlete F
20##-##
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 F
Case No. 00319
July 22, 2015
Page No. 4
__________
g.
20##
20##
In the fall of
and the spring of
then men's basketball
JUCO 5
Student Athlete G
prospective student-athlete
from
, a two-year college, was enrolled in two online courses at
Adams State: (1) MATHFormer
104
Finite Mathematics and (2) MATH 155
MBB
Integrated Mathematics. Staff Member 1 knowingly and impermissibly completed
Student
Former MBB
coursework for Athlete G at the direction of
and through the
HC
Former MBB
involvement of Asst. 3 This amounted to fraudulent academic credit and
resulted in inaccurate information being provided to the admissions office
Student
at Southern Mississippi regarding Athlete G academic record, which was
20##-##
used by the institution to certify his transfer eligibility for the
Student
academic year. Athlete G subsequently enrolled at Southern Mississippi,
competed for and received travel expenses as part of the men's basketball
20##-##
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 studentathletes. 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 are
presumptively 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:
20##
20##
May 7,
through June 11,Student Metadata for coursework submitted
to Adams State on behalf of Athlete E in PSYC 101. This includes, but is not
Online Name
limited to, the name "
" appearing as the author or modifier of
Online Name
16 assignments. The name "
" has been associated with
Non-NCAA Affiliated Person
Non-NCAA
through Internet research. Affiliated Person was
Former MBB
identified by Asst. 3 in his January 26, 2015, interview as a friend of his
Case No. 00319
July 22, 2015
Page No. 5
__________
and
(
FI2:
Psyc101
_051415_SouthernMiss_00319)
20##
Student
Athlete G
Student
Athlete B
Math104Assign2-7_051415_SouthernMiss_00319)
20##
June 23 through July 5,

Coursework submitted to Adams State on
Student Athlete A
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
Student Athlete
Student
Student
handwriting on assignments submitted for
B
Athlete E
Athlete C and
(
FI4:
Athlete E
NCAA Institution 1
from
June 8 through July 5,

Student
behalf of Athlete B in MATH 104. This includes, but is not limited to, six
assignments with handwriting that a forensic document examiner
Student Athlete A
Student
Student
Athlete E Athlete C and
(
FI3:
Former MBB Staff

Member 1
Student
Athlete G
Student Athlete A
20##
August 8 through 10,

Metadata for coursework submitted to
Student
Athlete
B
Adams State on behalf of
in ENG 101. This includes, but is not
limited to, the name
appearing as the author of six assignments.
Student Athlete B
(
052215_SouthernMiss_00319)
Former MBB
Staff Member 1
FI5:
20##

Student
Adams State on behalf of Athlete B in ENG 102. This includes, but is not
limited to, the name
appearing as the author of three assignments.
Student Athlete
( B
ENG102 _052215_SouthernMiss_00319)
Former MBB
Staff Member 1
Former
MBB
Staff
Membe
1
FI6:

not limited to, the name "
assignments.
Student Athlete A
(
Eng102
20##

in ENG 102. This includes, but is
" appearing as the author of six
2
Student Athlete A
Former MBB Staff

Member 2
FI7:
20##
Student Athlete
August 16,
Adams State academic transcript for
This
B
Student Athlete
includes, but is not limited to,
enrollment in nine total credit
B
20##
hours, consisting of ENG 101, ENG 102 and MATH 104, during the
summer semester.
Student Athlete
( B
USMAcademicFile_110514_SouthernMiss_00319)
Case No. 00319
July 22, 2015
Page No. 6
__________
20##
Student Athlete A
FI8:
August 17,
Student Athlete A
This includes, but is not limited to,
enrollment in nine total
20##
credit hours, consisting of ENG 101 and ENG 102, during the
spring
20##
semester and MATH 104 during the
summer semester.
Student Athlete A
(
FI9:
November 14,
through May 8,
Metadata for coursework
submitted to Adams State on behalf
of
in ENG 101. This includes,
Former
Staff
but is not limited to, the name MBB
appearing
as the author or modifier of
Member 1
nine assignments.
Student
( Athlete C Eng10
20##
20##
Former MBB
Staff Member 1
Former
MBB
Staff
Member
1
20##
FI10: April 2 through 16,

Coursework submitted to Adams State on behalf
Student
of Athlete C in MATH 104. This includes, but is not limited to, seven
Student Athlete A
Student Athlete
Student
B
Athlete E
Student
and Athlete G
Stu
( Athlete C Math104Final_SouthernMiss_00319 and
Student
Athlete C Math104Assign1-7_051415_SouthernMiss_00319)
20##
FI11: April 15 through May 13,

Student
Adams State on behalf of Athlete C in ENG 102. This includes, but is not
limited to, the name " Former MBB2Staff Member " appearing as the author of 11
assignments.
Student
( Athlete C Eng102
Former MBB Staff
Member 2
20##
FI12: May 3 through 17,

IP addresses for coursework submissions to
This includes, but is not limited
to, five
Former MBB Staff
Member 1 Hometown
submissions in SOC 251 that include IP address locationsFormer
of MBB
Staff
City, State of JUCO 4
, and
.
is from Member 1 Hometown and
Former MBB Asst. 1
according to
, then assistant men's basketball
City of JUCO 4
coach, in his March 27, 2015, interview,
was in
at the
time those submissions were made for
Student Athlete D
(
SubmissionDates_102214_SouthernMiss_00319)
Student
Athlete D
Former MBB Staff

Member 1
Former MBB Staff

Member 1
Student
Athlete D
20##
FI13: May 8,
IP addresses for coursework submissions to Adams State
Student
on behalf of Athlete C This includes, but is not limited to, one submission in
ENG 101 that includes an IP address location of Hattiesburg, Mississippi.
Student
( Athlete C Eng101-final_SouthernMiss_00319)
Case No. 00319
July 22, 2015
Page No. 7
__________
20##
FI14: May 12 through 14,Student

Metadata for coursework submitted to Adams
Athlete D
State on behalf of
in BUS 207. This includes, but is not limited to, the
name
appearing as the author of 10 assignments.
(
Bus207
Former MBB
Staff Member 1
Former
MBB Staff
Member 1
Student
Athlete D
20##

This includes, but is not limited to, four
City, State of
submissions in BUS 207 that include IP address locationsFormerofMBB Staff
JUCO 3
City of JUCO 4
, and
. This corresponds to the dates that Member 2 was
City of
City of JUCO 4
Former MBB
in JUCO 3 and
was
in
, as reported by Asst. 1 in his March
Former MBB Staff
27, 2015, interview. Member 2 also confirmed in his June 24, 2015,
Former MBB
City of
20##
interview that he was with Asst. 1 in JUCO 3 in May
Student Athlete D
(
Student
Athlete D
Former MBB
Staff Member 1
20##

Metadata for coursework submitted to Adams
Student
Athlete D in AR 103. This includes, but is not limited to, the
State on behalf
of
Former MBB Staff
Member 2
name "
" appearing as the author of 13 assignments.
Former MBB Staff
(
Ar103 Member 2 _051415_SouthernMiss_00319)
Student
Athlete D
20##

This includes, but is not limited to, 20
City, State of
submissions in AR 103 that include IPFormer
address
locations of JUCO 3
MBB Staff Member 1 Hometown
; Hattiesburg, Mississippi;
; and
. The dates of the IP address information for JUCO Former
and
3
MBB Staff
City of JUCO 4
Former MBB
Member 2
correspondFormer
to MBB
the dates on which Asst. 1 reportedFormer
that
MBB
City of JUCO 4
City of JUCO
Staff Member
Staff Member 1
was
in
and
was
in
.
In
addition,
is from
3
1
Former MBB Staff
Member 1 Hometown which is located near
Student AthleteFo
D
(
Student
Athlete D
Large City Near Former MBB Staff

Member 1 Hometown
20##
FI18: May 14 through June 11,

IP addresses for coursework submissions
Student
to Adams State on behalf of Athlete E This includes, but is not limited to, 31
submissions in PSYC 101 that include an IP address location of Kingston,
Student
State of
Non-NCAA
Jamaica, while Athlete E was still in JUCO 5 . Affiliated Person is from Kingston.
Student
( Athlete E SubmissionDates_111014_SouthernMiss_00319)
20##
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
Athlete D
Former MBB
Staff Member 1
Former
MBB Staff
Member 1
Athlete D
Student
Athlete D
20##
FI20: May 29,

This includes,
but is not limited to,
enrollment in 12 total credit hours, consisting
Student Athlete
D
Case No. 00319
July 22, 2015
Page No. 8
__________
of AR 103, BUS 207, HIST 202 and SOC 251 during the
semester.
(
20##
summer
Student
Athlete D
20##
FI21: June 12 through July 3, Student Metadata for coursework submitted to

Adams State on behalf of Athlete E in ENG 203. This includes, but is not
Online Name
limited to, the name "
" appearing as the author of five
assignments.
Student
( Athlete E Eng203
20##
FI22: June 17 through July 4,

Student
to Adams State on behalf of Athlete E This includes, but is not limited to, six
submissions
in ENG 203 that include locations of Kingston, Jamaica, and
Former MBB Staff
Student
State of
Non-NCAA
Member 1 Hometown
, while Former
Athlete E was still in
JUCO 5
Affiliated Person is from Kingston,
MBB Staff
and
is from Member 1 Hometown .
Student
Former MBB
Staff Member
1
20##
FI23: July 10 and 11,

Coursework submitted to Adams State on behalf of
Student
in
MATH
104.
This includes, but is not limited to, six assignments
Athlete E
with handwriting that a forensic document examiner determined as
"probable" that the same person produced the same handwriting on
Student Athlete A
Student Athlete Student
Student
assignments submitted for
B
Athlete C and Athlete G
Student
( Athlete E Math104Assign1-6_051415_SouthernMiss_00319)
20##

IP addresses for coursework submissions to Adams
Student
State on behalf of Athlete E This includes, but is not limited to, seven
submissions in MATH 104 that include a location of
, while
Student
was
still
in
.
is
from
.
Athlete E
Student
Member
Hometown
State of JUCO 5
Former MBB
Staff Member
1

Hometown
1
20##

Metadata for coursework submitted to Adams State
Student
on behalf of Athlete E 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
Student
behalf of Athlete G in MATH 155 nearly a year later.
Student
( Athlete E Math15
051415_SouthernMiss_00319 and
Student Athlete
Math15
G
Former MBB
Staff Member 1
Former MBB
Staff
Member 1
Former
MBB Staff
Member 1
20##
FI26: July 18 through 22,

Student
behalf of Athlete E in MATH 155. This includes, but is not limited to, six
Case No. 00319
July 22, 2015
Page No. 9
__________
Student Athlete A

Student
and Athlete G
(
20##
Student Athlete
B
Student
Athlete C
Student
FI27: August 20,

Adams State academic transcript for Athlete E This
Student
includes, but is not limited to, Athlete E enrollment in 12 total credit hours,
20##
consisting of ENG 203 and PSYC 101 during the
spring semester
20##
and MATH 104 and MATH 155 during the
summer semester.
Student
( Athlete E USMAcademicFile_110514_SouthernMiss_00319)
20##
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.
Former MBB
( Asst. 1 Receipts_032715_SouthernMiss_00319)
20##
FI29: October 4 through November 20,

Student
Athlete
F
of
in ENG 101. This includes,
2
but is not limited to, the name "
" appearing as the author
of 47 assignments.
Former MBB
Student
( Athlete F Eng101 Staff Member 2 _051415_SouthernMiss_00319)
20##
FI30: October 4 through November 20,

IP addresses for coursework
Student
submissions to Adams State on behalf of Athlete F This includes, but is not
limited to, 46 submissions in ENG 101 that include a location of
Student
State of
Hattiesburg, Mississippi, while Athlete F was still in JUCO 1
Student
(Athlete F SubmissionDates_111014_SouthernMiss_00319)
20##
FI31: November 20 through December 2, Student Metadata for coursework

of Athlete F in ENG 102. This includes,
2
but is not limited to, the name "
" appearing as the author
of 28 assignments.
Student
( Athlete F Eng102
Former MBB Staff
Member 2
20##
FI32: November 20 through December 2,

IP addresses for coursework
Student
submissions to Adams State on behalf of Athlete F This includes, but is not
limited to, 29 submissions in ENG 102 that include locations of
Student
Hattiesburg, Mississippi, and Louisville, Kentucky, while Athlete F was still
State of
in JUCO 1 .
Student
( Athlete FSubmissionDates_111014_SouthernMiss_00319)
Case No. 00319
July 22, 2015
Page No. 10
__________
20##
Student
FI33: December 16,

Adams State academic transcript for Athlete F This
Student
includes, but is not limited to, Athlete F enrollment in six total credit hours,
20##
consisting of ENG 101 and ENG 102 during the
fall semester.
Student
( Athlete F USMAcademicFile_112614_SouthernMiss_00319)
FI34: April 5 through 16, 2014 Coursework submitted to Adams State on
Student
behalf of Athlete G in MATH 155. This includes, but is not limited to, six
Student Athlete A
Student Athlete
Student
B
Athlete E
Student
and Athlete C
Student Athlete
( G
20##
FI35: April 5 through May 15,

Student
to Adams State on behalf of Athlete G This includes, but is not limited to,
seven submissions in MATH 155 that include locations of Hattiesburg,
State of
Student
Mississippi, and City, State of NCAA Institution 2 , while Athlete G was still in JUCO 5 .
NCAA Institution 2
Former MBB HC
joined
staff at
20##
in late April
( Athlete G SubmissionDates_111014_SouthernMiss_00319)
Former MBB Staff
Member 1
20##
20##
FI36: July 17,

through May 15,
Student
submitted to Adams State on behalf of Athlete G 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
Student
the same assignment submitted on behalf of Athlete E for the same course
nearly a year earlier.
Student Athlete
( G
Math155
051415_SouthernMiss_00319 and
Athlete E Math15
Former MBB
Staff Member 1
Former
MBB Staff
Member 1
Former
MBB Staff
Member 1
20##
Student
FI37: June 13,

Adams State academic transcript for Athlete G This
Student
includes, but is not limited to, Athlete G enrollment in six total credit hours,
20##
consisting of MATH 104 and MATH 155 during the
fall semester
20##
and the
spring semester, respectively.
Student Athlete
( G
Student Athlete
D
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)
Student Athlete
D
Student
Athlete D
Case No. 00319
July 22, 2015
Page No. 11
__________
Student Athlete
D
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 summary
of the enforcement staff's efforts to allow
an opportunity to review
this interview summary.
(
_INotes_082714_SouthernMiss_00319 and
Student Athlete D
_IS_070715_SouthernMiss_00319)
Student
Athlete D
Student
Athlete D
Student
Athlete D
Student Athlete
D
FI40: August 28, 2014 Transcript of

second interview. This includes,
statement that he did not register, pay for or
complete any of the coursework in the Adams State classes.
Student Athlete D
(
Student Athlete
D
Student
FI41: October 31, 2014 Transcript of Athlete E first interview. This includes, but
Student
is not limited to, Athlete E statement that he completed the work for the
online courses at Adams State.
Student
( Athlete E _TR_103114_SouthernMiss_00319)
Student
FI42: October 31, 2014 Transcript of Athlete G first interview. This includes,
Student
but is not limited to, Athlete G statement that he completed the work for the
MATH 155 online course at Adams State.
Student Athlete
( G
FI43: November 5, 2014 Southern Mississippi academic transcript for
Student Athlete A
This includes, but is not limited to, the application of nine
transferable credit
hours from Adams State toward the Southern
Student Athlete A's Major
Mississippi
program.
Student Athlete A
(
Student Athlete
FI44: November 5, 2014 Southern Mississippi academic transcript for

B
This includes, but is not limited to, the application of nine transferable
creditStudenthours
from Adams State toward the Southern Mississippi
Athlete B's Major
program.
Student
( Athlete B USMAcademicFile_110514_SouthernMiss_00319)
Student
FI45: November 5, 2014 Southern Mississippi academic transcript for Athlete E

This includes, but is not limited to, the application of twelve transferable
creditStudenthours
from
Adams State toward the Southern Mississippi
Athlete
E's
Major
Former MBB
Staff
Member
program.
Student
( Athlete
E
Case No. 00319
July 22, 2015
Page No. 12
__________
Student
FI46: November 5, 2014 Southern Mississippi academic transcript for Athlete G

This includes, but is not limited to, the application of three transferable
creditStudent
hours
from Adams State toward the Southern Mississippi
Athlete G's Major
program.
Student
( Athlete
G
Former MBB
FI47: November 6, 2014 Transcript of Staff Member 2 first interview. This includes,
statement that he completed coursework for
Student
both
and
Athlete F online classes at Adams State.
Former MBB Staff
( Member 2 _TR_110614_SouthernMiss_00319)
2
Student Athlete
D
Former MBB HC
FI48: November 18, 2014 Transcript

of
first interview. This
Former MBB HC
includes but is not limited to
statement that he was not aware of
or involved in academic misconduct related to prospective studentathletes.
Former MBB HC
(
Former MBB
FI49: November 18, 2014 Transcript of

Asst. 1
Former MBB
statement
that he was not
Asst. 1
involved in NCAA violations.
Former MBB
( Asst. 1 _TR_111814_SouthernMiss_00319)
Student
FI50: November 19, 2014 Transcript of Athlete F first interview. This includes,
Student
but is not limited to, Athlete F statement that he did not register, pay for or
complete any of the coursework in his Adams State and University of
North Dakota online courses.
Student
( Athlete F _TR_111914_SouthernMiss_00319)
Former MBB

second interview. This
Asst. 1
Former MBB
statement that he was not
Asst. 1
involved in NCAA violations.
Former MBB
Student
FI52: December 4, 2014 Southern Mississippi academic transcript for Athlete F

This includes, but is not limited to, the application of six transferable
Student Athlete F's Major
credit hours from Adams State toward
at Southern
Mississippi.
Student
( Athlete F USMAcademicFile_112614_SouthernMiss_00319)
Student Athlete A
FI53: December 2014 and February 2015 Telephone calls to

Student Athlete A
from the institution in which
denied requests to interview.
(InterviewStatusChart_022715_SouthernMiss_00319)
Case No. 00319
July 22, 2015
Page No. 13
__________
Student
FI54: December 2014 and February 2015 Telephone calls to Athlete B from the
Student Athlete
institution.
parents stated in December 2014 that he was playing
B
basketball
and was unavailable. The institution received no
response in the follow-up call requesting an interview in February 2015.
Former MBB Asst. 3
FI55: January 26, 2015 Transcript of

second interview. This
Former MBB Asst.
discussion of the relationship
3
NCAA Institution 1
Non-NCAA
between him,
and Affiliated
.
Person and their connection to
Former MBB Asst.
(
_TR_012615_SouthernMiss_00319_DRAFT)
3
Former MBB
Staff Member 1
Student
FI56: January 26, 2015 Transcript of Athlete E second interview. This includes,
Student
but is not limited to, Athlete E statement that he completed all coursework
State of JUCO
5
for Adams State courses while he was in
Student
( Athlete E TR_012615_SouthernMiss_00319)
Student
FI57: January 26, 2015 Transcript of Athlete G second interview. This includes,
but is not limited to, StudentGAthlete statement that he completed all coursework
State of
for Adams State courses from JUCO
5 .
Student Athlete
(
G
FI58: September 2014 through March 2015 In September 2014, the
enforcement staff requested an interview and Former MBB Asst. 2 declined. In
Former MBB Asst.
November 2014, the enforcement staff informed
that serious
2
Asst.
allegations had been alleged against him and again, Former MBB
declined to
2
interview. In December 2014 and March 2015, the enforcement staff sent
Former MBB Asst.
Former MBB Asst.
letters to
requesting interviews.
did not respond.
2
2
( Former MBB Asst. 2 CO_121014_SouthernMiss_00319)
( Former MBB Asst. 2 CO_InterviewRequest_030315_SouthernMiss_00319)
FI59: November 2014 through April 2015 On November 17, 2014, the
NCAA Institution 2
enforcement staff had a scheduled interview with
at
.
NCAA Institution 2
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 that
declined to interview with the enforcement staff.
(InterviewStatusChart_022715_SouthernMiss_00319;
CO_InterviewRequest_010514_SouthernMiss_00319; and
CO_InterviewRequest_030315_SouthernMiss_00319)
Former MBB
Staff Member 1
Attorney for Former MBB Staff Member 1
Former MBB
Staff Member 1
Former MBB
Staff Member 1
Former MBB Staff

Member 1
Former MBB Staff

Member 1
Former MBB
Staff Member 1
Former MBB Staff

Member 1
Case No. 00319
July 22, 2015
Page No. 14
__________
Student
FI60: May and June 2015 The enforcement staff made calls to Athlete C
Student
requesting an interview. Athlete C did not return enforcement staff calls.
Non-NCAA
FI61: February 2015 The enforcement staff made calls to Affiliated Person requesting
Non-NCAA
interviews. Affiliated Person did not return enforcement staff calls.
Former MBB HC
FI62: March 16, 2015 Transcript of

second interview. This includes
Former MBB HC
statement that he was not aware of or
involved in academic misconduct related to prospective student-athletes.
Former MBB HC
(
Former MBB
FI63: March 27, 2015 Transcript of Asst. 1

third interview This
includes
Former MBB
Former MBB
Former MBB
Staff Member 2 and
but is not limited to, Asst. 1
statement that HC
hired
o
Former MBB
for the purpose of engaging in academic misconduct. Jf Asst. 1 further
Former MBB Staff
Former MBB
stated that
would send Member 2 and
to the locales of
HC
O
prospective student-athletes to complete coursework so that
IP address
information would make it appear as though the prospects had completed
Former MBB
m he took with
the
work themselves. Specifically, Asst. 1 identified
a trip
Former MBB Staff
Former MBB Staff
City, State of JUCO 3
Member 2
Member 2
to
, in May
for
to complete work
Student
State of JUCO 4
for Athlete C while
traveled to
to completeCity,work
for
State of JUCO 5
Former MBB
also described another trip he took with
to
, in
Asst. 1
20##
Studen
Former MBB
July
for
to
complete
work
for
stated
that
he
Athlete E
Asst. 1
Former MBB
Former
Student
Staff
Member
2
MBB
Staff
was also aware of
completing coursework for Athlete F and of
Member 1
Student
completing coursework for Athlete G
Former MBB
Former MBB
Staff Member 1
Former MBB Staff

Member 1
Student
Athlete D
Former MBB Staff

Member 1
Former MBB
Staff Member 1
Former MBB Staff

Member 1
Former MBB HC
FI64: May 12, 2015 Transcript of

third interview. This includes, but
Former MBB HC
is not limited to,
statement that he was not aware of or involved
in academic misconduct related to prospective student-athletes.
Former MBB HC
(
Online Name
FI65: May 15, 2015 Internet research for "

". This includes, but is
Online Name
not limited to, the identification of "
" as an online alias of
.
(
Former MBB Staff
Member 2
FI66: June 24, 2015 Transcript of

statement that he also completed
Former MBB
Student Athlete A
Student
Staff Member 2 stated that he completed
coursework for Athlete C and
Case No. 00319
July 22, 2015
Page No. 15
__________
Student
Former MBB
work for Athlete C at the request of Asst. 1

but could not recall who
Student Athlete A
requested
that he do the work for
Former MBB Staff
( Member 2 _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
Student Athlete A
Student Athlete
Student
the Adams State math courses on behalf of
B
Athlete E
Student
Student
Athlete C and Athlete G 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)
JUCO 5 MBB HC
FI69: February 16, 2015 Transcript of interview with

, head men's
JUCO 5
basketball coach at the
. This includes, but is not
JUCO 5
Former MBB
Student
limited to, MBB HC statement that
recruited both Athlete E and
Asst. 3
(
Student
Athlete G
JUCO 5 MBB
HC
TR_021615_SouthernMiss_00319)
Employee at JUCO 5
FI70: February 16, 2015 Transcript of interview with

), an
JUCO 5
academic advisor at the
. This includes, but is
Employee
Former MBB
not limited to, at JUCO 5 statement that she spoke with Asst. 3 regularly in
Student
Former MBB
the course of his recruitment of Athlete E that Asst. 3 worked with her to
Student
Former MBB
identify courses for Athlete E at Adams State, that Asst. 3 told her he would
Student
work with Athlete E on his academics and that everything was under control.
Former MBB
further stated that she worked with Asst. 3 during his recruitment of
Student
Athlete G to identify online courses that would satisfy requirements at the
JUCO 5
.
Employee
(at JUCO 5 _TR_021615_SouthernMiss_00319)
Employee
at JUCO 5
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)]
Former MBB
It is alleged that during the 2012-13 through 2014-15 academic years, HC

, then head men's basketball coach, violated the NCAA
principles of ethical conduct and financial aid legislation when he provided an
Case No. 00319
July 22, 2015
Page No. 16
__________
impermissible source of financial aid to nonqualifier men's basketball studentStudent Athlete H

Student Athlete I
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.
Former MBB
HC
provided cash and prepaid cards that totaled approximately $6,000

20##-##
to
during the
academic year. These benefits were applied
Student Athlete H
to
student account at the institution to partially pay for his year
of residence expenses associated with tuition and room and board. The
Student
next academic year, Athlete H 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)]
Student Athlete H
b.
Former MBB
HC
Student Athlete I
provided prepaid cards that totaled approximately $2,000 to

20##-##
during the
academic year. These benefits were
Student Athlete I
applied to
student account at the institution to partially pay
for his year of residence expenses associated with tuition and room and
Student Athlete I
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.
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's
basketball coach engaged in unethical conduct through his involvement in
providing an impermissible source of financial aid for two nonqualifier studentathletes from his own funds. In the alternative, if a hearing panel determines that
Former MBB
the funds HC
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)]
Case No. 00319
July 22, 2015
Page No. 17
__________
No. 2:
Former MBB
FI71: June 18, 2012 Compliance notes provided by

from men's
HC
basketball staff meetings held in 2012 and 2013. This includes, but is not
Former USM Compliance
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."
Former MBB
( HC ComplianceNotes_121514_SouthernMiss_00319)
Student Athlete H
FI72: October 17, 2014

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

account statement. This includes, but is
Student Athlete I
not limited to, payments to
account during his academic year
20##
of residence totaling $2,198.25 as follows: $966 October 28,
$901
20##
20##
November 27,
and $331.25 April 1,
Student Athlete I
(
AccountStatement_110514_SouthernMiss_00318)
Former MBB HC

phone records for his personal cell phone.
Student
This includes, but is not limited to, 11 text messages with Athlete H's
Student Athlete H
HS HC
,
high school boys' basketball coach.
Former MBB HC
6062075105_042215_SouthernMiss_00319)
Former MBB HC

phone records for a cell phone maintained in
his mother's name. This includes, but is not limited to, four phone calls
Student Athlete H's
with
including calls lasting three minutes and 18 minutes, and
HS HC
Student Athlete I's HS HC
12 calls with
, then assistant men's
NCAA Institution 3
basketball coach at
, including calls
lasting two minutes and three minutes.
Former MBB HC
(
8594571915_042215_SouthernMiss_00319)
Case No. 00319
July 22, 2015
Page No. 18
__________
Former MBB HC

This includes, but is not limited to, 10 text messages and two phone calls
Student Athlete I's
with
including one call lasting 10 minutes.
HS HC
Former MBB HC
(
6062075105_042215_SouthernMiss_00319)
Former MBB HC

his mother's name. This includes, but is not limited to, six phone calls with
Student Athlete H's
including calls lasting two minutes, six minutes and eight
HS HC
Student Athlete I's
minutes, and seven calls with
including two calls lasting three
HS HC
minutes and four minutes each and one call lasting 10 minutes.
Former MBB HC
(
8594571915_042215_SouthernMiss_00319)
Former USM
FI78: October 29, 2014 Compliance cell phone records. This includes, but is not
Former MBB
limited to, one phon
with HC
lasting 15 minutes and one phone
MBB Staff Member
call with
former
,
lasting seven minutes.
Former
( USM PhoneRecords_031115_SouthernMiss_00319)
Complianc
Former MBB HC

his mother's name. This includes, but is not limited to, 13 phone calls with
Student Athlete H's
including calls lasting three minutes and five minutes, and one
HS HC
Student Athlete I's
call with
lasting eight minutes.
HS HC
Former MBB HC
(
8594571915_042215_SouthernMiss_00319)
Student Athlete H
FI80: October 30, 2014 Transcript of

interview. This includes, but is
Student Athlete H
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
MBB Staff Member
Mississippi) and that a
accompanied him to the business
office to ensure the funds were used to pay the balance on his account.
Student Athlete H
(
Student Athlete I
FI81: October 30, 2014 Transcript of

interview. This includes,
Student Athlete I
statement that he received prepaid debit
cards through the men's basketball office to make payments on his student
account at Southern Mississippi.
Student Athlete I
(
Former MBB HC

his mother's name. This includes, but is not limited to, eight phone calls
Student Athlete H's
with
including calls lasting five minutes, six minutes and 10
HS HC
minutes.
Former MBB HC
(
8594571915_042215_SouthernMiss_00319)
Case No. 00319
July 22, 2015
Page No. 19
__________
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
Former
including the interpretation from
was created by MBB Staff October 31,
Member 3
2014, and modified November 7, 2014.
uneNotes_031715_SouthernMiss_00319)
Former USM
Compliance
Former MBB Staff

Member 3
Former MBB HC
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
Student Athlete I's
HS HC
Former MBB HC
8594571915_042215_SouthernMiss_00319)
Former MBB HC

in his mother's name. This includes, but is not limited to, two phone calls
Student Athlete H's
with
including one lasting six minutes, and three calls with
HS HC
Student Athlete I's
including one lasting four minutes.
HS HC
Former MBB HC
(
8594571915_042215_SouthernMiss_00319)
Former MBB HC

in his mother's name. This includes, but is not limited to, one phone call
Student Athlete
Student Athlete I's
with H's HS HC
lasting four minutes and four calls with
HS HC
including two calls lasting seven minutes and 14 minutes.
Former MBB HC
(
8594571915_042215_SouthernMiss_00319)
Former MBB HC

Student Athlete I's
This includes, but is not limited to, two text messages with
HS HC
Former MBB HC
(
6062075105_042215_SouthernMiss_00319)
Former
FI88: November 3, 2014 USM cell phone records. This includes, but is not
Former MBB
Compliance
limited to, one phone call with HC
lasting 18 minutes.
Former
( USM PhoneRecords_031115_SouthernMiss_00319)
Complianc
Former MBB HC

in his mother's name. This includes, but is not limited to, 16 phone calls
Student Athlete H's
with
including two calls lasting five minutes each, and one call
HS HC
Student Athlete I's
with
HS HC
Former MBB HC
(
8594571915_042215_SouthernMiss_00319)
Student Athlete I's

HS HC
Student Athlete I's
statement that he sent around
HS HC
$4,000 in prepaid debit cards to the men's basketball office to assist
Case No. 00319
July 22, 2015
Page No. 20
__________
Student Athlete I
with making payments on his account balance at Southern
Mississippi.
Student Athlete I's
(
_TR_1-3_110414_SouthernMiss_00319)
HS HC
Former MBB HC

in his mother's name. This includes, but is not limited to, 13 phone calls
Student Athlete H's
with
including one call lasting 21 minutes.
HS HC
Former MBB HC
(
8594571915_042215_SouthernMiss_00319)
2
MBB Staff Member
statements that a
Student
Student Athlete I
was responsible for monitoring Athlete H and
to ensure the
cash or prepaid cards were used to pay the balances on their accounts.
(
Former MBB Staff
Member 2

2
Student Athlete H's

interview. This includes,
HS HC
Student Athlete H's
statement that he sent around $4,000 to
HS HC
$5,000 in cash and prepaid debit cards to the men's basketball office to
Student
assist Athlete H with making payments on his account balance.
Student Athlete H's
( HS HC
Former MBB HC

Former MBB HC
Student Athlete
statement that H's HS HC sent cash
Former MBB
and prepaid debit cards to Athlete H in care of
at the men's
HC
Student Athlete I's
Student Athlete I
basketball office, and HS HC
sent prepaid debit cards to
in
Former MBB
care of HC
at the men's basketball office.
Former MBB HC
(
Former
FI95: January 28, 2015 Transcript of USM interview. This includes, but is not
Former
Compliance
limited to, USM statement that he did not remember any specific
Compliance Former MBB
conversation with
regarding a coach paying for a nonqualifier's
HC
year of residence but believed he would have said it needed to be a
Former MBB
situation where there was no parental involvement, as well as that HC
had contacted him on his cell phone within the last couple of months to
Former
discuss USM recollection of the conversation about nonqualifiers and
Compliance
coaches paying for their tuition.
Former
( USM _TR_012815_SouthernMiss_00319)
Complianc
Former MBB
FI96: March 16, 2015 Transcript of Staff interview. This includes, but is not
Former MBB
Member
limited to, Staff statement that (1) he was not part of any conversation
For Member
Former
between HC
and USM in June 2012 regarding nonqualifiers but was
Complia
responsible for putting together the staff notes that reflected the
Case No. 00319
July 22, 2015
Page No. 21
__________
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.
Former MBB
(Staff Member _TR_031615_SouthernMiss_00319)
Former MBB HC

Former MBB HC
statements that (1) he did not discuss with
Former
the appropriateness of receiving cash and prepaid debit cards from
USM
Complia Athlete
in the men's basketball office, (2) he did not discuss with
H's HS HC
Student Athlete
anyone the appropriateness of communicating directly with H's HS HC
Student Athlete H
about
balance and (3) he did not discuss with anyone the
Student Athlete I
appropriateness of creating a similar arrangement for
and
Student Athlete I's
HS HC
Former MBB HC
_TR_031614_SouthernMississippi_00319)
Former MBB Asst. 1

third interview. This
Form
Former MBB
includes, but is not limited to, Asst. 1
statements that (1) HC
paid
Student Athlete H
Student Athlete I
for
and
year of residence using cash and prepaid
Former MBB
Student Athlete
cards from his own personal funds, (2)
had H's HS HC provide
HC
false letters corresponding to amounts being paid for Athlete H to cover his
Former MBB
Student Athlete
Student Athlete I's
tracks and (3)
talked with H's HS HC and
during the
HC
HS HC
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
Student Athlete H
Student Athlete I
that they had paid for
and
years of residence,
respectively.
Former MBB
Student Athlete I's
FI99: April 8, 2015 Transcript of

HS HC
Student Athlete I's
statement that he was the source of the
HS HC
Student Athlete I
funds to
Student Athlete I's
(
HS HC
Former MBB HC

Former MBB HC
is not limited to,
statement that he contacted multiple people,
Student Athle
tudent Athlete I's
including H's HS HC and
using a cell phone in his mother's
HS HC
name, to discuss rumors related to the investigation but not to coordinate
stories among witnesses.
Former MBB HC
(
Case No. 00319
July 22, 2015
Page No. 22
__________
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
Former MBB HC
allegations,
former head men's basketball coach,
violated NCAA responsibility to cooperate legislation and the NCAA principles
Former MBB
of ethical conduct. HC
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:
Former MBB
a.
Under NCAA responsibility to cooperate legislation,

has an
HC
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, 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).
Former MBB
stated that he deleted the emails, including personal emails and
HC
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.
Former MBB
HC
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
HC
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 MBB
Case No. 00319
July 22, 2015
Page No. 23
__________
Former MBB
JUCO 4 MBB Asst.
contacted by HC
included
assistant
Student
men's basketball coach at
, Athlete H's
Student Athlete H
HS HC
,
high school boys' basketball coach,
Former MBB Asst. 3
Former
, then assistant men's basketball coach; USM
Complian
, former associate athletic director for compliance, student services;
ce
and
then assistant men's basketball coach at
NCAA Institution 3
. [(NCAA Bylaws 19.2.3 (2014-15)]
Former MBB
HC
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
Student Athlete H
Student
men's basketball student-athletes
and Athlete I
to cover educational expenses during their
nonqualifier year of residence, when in fact he was the source of those
Former MBB
funds. In addition,
further violated NCAA principles of ethical
HC
Student Athlete H
Student Athlete I
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 identify
Former MBB
themselves as the sources for the funds, when in fact HC
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
HC
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.
Former MBB
told an assistant coach to contact former men's basketball
HC
Student Athlete F
prospective student-athlete
, whom the institution had
Student
Student
recruited, to tell Athlete F to report to the enforcement staff that Athlete F had
paid for his Adams State University (Adams State) online courses, when
Student
Former MBB
in fact Athlete F had not done so and instead it had been
[NCAA
HC
Bylaws 10.01.1, 10.1, 10.1-(d) and 19.2.3 (2014-15)]
Former MBB

The enforcement staff believes a hearing panel of the NCAA Division I
Former MBB HC
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.
Case No. 00319
July 22, 2015
Page No. 24
__________
Former MBB HC
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)]
No. 3:
Former MBB HC
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
Student Athlete I's
Former MBB
to, 29 calls with
71 calls with Asst. 3 (plus 47 texts), 63 calls
HS HC
Student Athlete
with H's HS HC (plus 10 texts), five calls with Adams State and one call
with a number that has been identified as a burner phone used by
Former MBB Staff Member at
NCAA Institution 2
MBB Staff Member
NCAA Institution 2
at the
.
MBB
( Former
8594571915_042215_SouthernMiss_00319)
HC
Former MBB HC

Former MBB HC
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).
Former MBB HC
(
Former MBB HC
FI103: February 3, 2015 List view of messages remaining in

Morehead State email account. This includes, but is not limited to, emails
Former MBB
provided by Morehead State that show HC
deleted all messages from
the time he started at Southern Mississippi up to the time of his first
interview in November 2014.
Former MBB HC
(
MoreheadStateEmails_052615_SouthernMiss_00319)
Former MBB HC

Former MBB HC
statements that he deleted all emails in his
Morehead State email account that corresponded to his tenure at Southern
Mississippi.
Former MBB HC
(
Former MBB Asst. 1

, assistant men's
basketball coach, third interview. This
includes,
but
is
not limited
to,
Former MBB Staff
Former MBB
Member 1
statements that (1)
and
Asst. 1
Staff Members
Former MBB
, then men's basketball
, were hired by HC
to
complete academic coursework for men's basketball student-athletes and
Case No. 00319
July 22, 2015
Page No. 25
__________
Former MBB
prospective student-athletes;
(2) HC
purchased prepaid debit cards for
Former MBB
Former MBB
Staff Member 1
and
to use to register for online courses; (3)
HC
Student
Student Athlete I
provided cash and prepaid debit cards for Athlete H and
to pay
Former MBB
expenses during their year in residence; (4)
purchased burner
HC
Former MBB
Former MBB
phones for use by Asst. 1
and
to avoid detection in the
HC
Former MBB
Student
Acquintance of
investigation; (5) Asst. NCAA
contacted Athlete F and Student Athlete F , assistant men's
1
Institution 4
basketball coach at
, using two of the burner phones; (6)
Student
Former MBB
Former MBB
Student
Athlete
F
told Asst. 1 to call
to ensure Athlete F told the enforcement
HC
Former MBB
staff that he paid for his own online courses; (7) Asst. 1 witnessed
Former MBB
Student Athlete
Former MBB
call H's HS HC from the Blackberry phone and heard HC
tell
HC
Student Athlete H's
HS HC
to stick to the story during the NCAA interview; and (8)
Former MBB
Former MBB
Student Athlete I's
saw
use the Blackberry to call
during the
Asst. 1
HC
HS HC
course of the investigation and also had
use one of the burner
Student Athlete I's
phones to contact
HS HC
Former MBB
( Student
_TR_032715_SouthernMiss_00319;
Asst. 1
Athlete F _TR_111914_SouthernMiss_00319; and
Student
Athlete F _TR_112014_SouthernMiss_00319)
Former MBB Staff

Member 2
Former MBB Staff

Member at NCAA
Institution 2
Former MBB Staff

Member at NCAA
Institution 2
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
Former MBB
emails HC
deleted from his account are no longer accessible in light
of the institution's 30-day retention policy.
(MoreheadStateEmailMemo_CO_040115_SouthernMiss_00319)
Former MBB HC

Former MBB HC
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.
Former MBB HC
(
JUCO 4 MBB Asst.
FI108: June 18, 2015 Transcript of

interview. This includes, but is
JUCO 4 MBB Asst.
Former MBB
not limited to,
statement that
called him in late
HC
August to obtain information about the enforcement staff's interview with
Student Athlete D
JUCO 4 MBB Asst.
(
_TR_061815_SouthernMiss_00319_DRAFT)
Case No. 00319
July 22, 2015
Page No. 26
__________
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 basisNCAA
forInstitution
this notice
of
3
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
Student Athlete I's
legislation,
has an affirmative obligation to cooperate fully with and
HS HC
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
Student Athlete I's
information. However, while
provided the requested personal cellular
HS HC
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
Student Athlete I's
violation related to
receiving payment for the commitments of
HS HC
recruited men's basketball prospective student-athletes.
Student Athlete I's
conduct
HS HC
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)]
No. 4:
Former MBB Asst. 1

, assistant men's
basketball coach, third interview. This includes, but is not limited to,
Former MBB
Student Athlete I's
statement that he overheard conversations between
Asst. 1
HS HC
Former MBB HC
and
, then head men's basketball coach, discussing
information related to the NCAA investigation.
Former MBB
Student Athlete I's
FI110: May 21, 2015 Letter to HS HC

detailing the efforts and opportunities
Student Athlete I's
provided by the enforcement staff to secure
records.
HS HC
Student Athlete I's
(
_CO_051215_SouthernMiss_00319;
HS HC
Case No. 00319
July 22, 2015
Page No. 27
__________
Student Athlete I's
HS HC
Student Athlete I's
HS HC
_TR_040815_SouthernMiss00319; and
_TR_1-3_110414_SouthernMiss00319)
Attorney for Student Athlete I's HS HC
Student Athlete I's
FI111: June 30, 2015 Email from

,
HS HC
Attorney for
Student Athlete I's
attorney, including, but not limited to, Student Athlete I's stating that
HS HC
HS HC
will not provide his bank records. The email also includes language
regarding multiple missed deadlines.
Attorney for Student
( Athlete I's HS HC _CO_
5.
[NCAA Bylaws 10.1-(a), 19.2.3, and 19.2.3.2]

It is alleged that between November 2014 and March 2015,

Staff Member
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.
Former MBB Staff
Member 1
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.
Former MBB
Staff Member 1
Former MBB
Staff Member 1
Former MBB Staff

Member 1

breach of conduct (Level I) because this alleged conduct seriously
undermines or
Former MBB Staff
Member 1
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)]
Case No. 00319
July 22, 2015
Page No. 28
__________
No. 5:
FI112: November 2014 through April 2015 On November 17, 2014, the
NCAA Institution 2
enforcement staff had a scheduled interview with
at the
.
resigned his position on the
NCAA Institution 2
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)
Former MBB
Staff Member 1
Former MBB Staff

Member 1
Former MBB
Staff Member 1
Former MBB Staff

Member 1
Former MBB Staff

Member 1
Former MBB Staff

Member 1
FI113: February 11 and 12, 2015 The enforcement staff went to

home in
Hometown of Former MBB Staff Member 1
, to request an interview. During a telephone call
the next day,
mother confirmed that they relayed the request to
.
Former MBB Staff
Member 1
Former MBB
Staff Member 1
Attorney for Former MBB Staff
Member 1
FI114: March 24, 2015 Phone call with
representing
, advised the enforcement staff that
interview with the NCAA and terminated representation.
Former MBB
Staff Member
1
, an attorney
declined to
Former MBB
Staff Member 1

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

Former MBB Asst. 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, Former MBB Asst. 2
violated the responsibility to cooperate legislation by failing to make full and
complete disclosure of relevant information, when requested to do so by the
Asst.
enforcement staff. Specifically, Former MBB
refused to participate in an interview
2
with the enforcement despite multiple attempts by the enforcement staff to
arrange an interview.
Case No. 00319
July 22, 2015
Page No. 29
__________

Former MBB Asst. 2
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)]
No. 6:
Former MBB
FI115: September 15, 2014 Call to Asst. 2

in which he respectfully declined
to interview with the enforcement staff.
Former MBB
FI116: November 11, 2014 Call to

in which the enforcement staff
Asst. 2
Former MBB
informed
that serious allegations had been made against him
Asst. 2
Former MBB
and the enforcement staff again requested an interview. Asst. 2
declined
and stated that he would hire an attorney to protect his name.
Former MBB
FI117: December 10, 2014 A letter to Asst. 2

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.
Former MBB Asst. 2
(
_CO_121014_SouthernMiss_00319)
FI118: January 26, 2015 During the enforcement staff's second interview with
Former MBB Asst. 3
then assistant men's basketball coach,
Former MBB Asst. 2
reported that
confirmed that he had received a letter
Asst. 3
Former MBB
from the NCAA asking Asst. 2
to participate in an interview regarding
alleged violations.
Former MBB
( Asst. 3 _TR_012615_SouternMiss_00319_DRAFT)
Former MBB
FI119: March 3, 2015 Final letter requesting an interview of Asst. 2

in which
there was no response.
Former MBB Asst. 2
(
_CO_InterviewRequest_030315_SouthernMiss_00319)
Case No. 00319
July 22, 2015
Page No. 30
__________

7.
[NCAA Bylaw 11.1.1.1 (2013-14)]

Former MBB HC
It is alleged that
, then head men's basketball coach,
violated head coach responsibility legislation, as he is presumed to be responsible
for the alleged violations of his assistant coaches and administrators who reported
directly or indirectly to him, as described in Allegation No. 1, and for his own
involvement in alleged violations of NCAA legislation, as described in Allegation
Former MBB HC
Nos. 1, 2 and 3. Furthermore,
involvement in Allegation Nos. 1, 2 and 3
demonstrates that he did not at all times promote an atmosphere of compliance
Former MBB
within his program. Finally, HC
did not at all times monitor the actions of all
of the assistant coaches and administrators who reported directly or indirectly to
him but instead encouraged or directed their involvement in violations of NCAA
legislation.
Former MBB
threatens the integrity of the NCAA Collegiate Model as
and his staff
HC
were involved in severe and/or serious breaches of conduct as described in this
notice of allegations. Furthermore, the underlying conduct in Allegation Nos. 1, 2
and 3 is alleged as Level I conduct; therefore, pursuant to NCAA Bylaw 19.1.1,
this allegation is presumed to be Level I. [NCAA Bylaw 19.1.1 (2014-15)]
No. 7:
The enforcement staff incorporates the factual information referenced in this
document and all other documents posted on the secure website.
Specific to Allegation Nos. 1, 2, 3, 4, 5, 6 and 7:
a.
Please indicate whether the information contained within these allegations is

substantially correct and whether the institution and the involved individuals
identified in these allegations believe violations of NCAA legislation occurred.
Submit materials to support your response.
Case No. 00319
July 22, 2015
Page No. 31
__________
C.
b.
If the institution and the involved individuals believe NCAA violations occurred,
please indicate whether there is substantial agreement on the level of the
violation. Submit materials to support your response.
c.
Please indicate whether the factual information is substantially correct and

whether the institution and involved individuals have additional pertinent
information and/or facts. Submit facts in support of your response.
Potential Aggravating and Mitigating Factors.

Pursuant to NCAA Bylaw 19.7.1, the NCAA enforcement staff has identified the
following potential aggravating and mitigating factors that the hearing panel of the
NCAA Division I Committee on Infractions may consider.
1.
Institution:
a.
Aggravating factors. [NCAA Bylaw 19.9.3]

(1)
Multiple Level I violations by the institution. [NCAA Bylaw

19.9.3-(a)]
(2)
Allegation Nos. 1 and 2 in this case involve Level I

violations.
A history of Level I, II or major violations by the institution.

[NCAA Bylaw 19.9.3-(b)]
November 8, 1982, Major Infractions Report The

University of Southern Mississippi (Southern Mississippi)
provided financial benefits to football prospective studentathletes.
February 8, 1985, Major Infractions Report Southern

Mississippi provided improper inducements to football
prospective student-athletes.
January 30, 2013, Major Infractions Report Southern

Mississippi head and assistant men's tennis coaches
engaged in unethical conduct, and the institution failed to
monitor its tennis program.
Case No. 00319
July 22, 2015
Page No. 32
__________
(3)
Former MBB HC
Person of authority [
), then head men's
basketball coach] condoned, participated in or negligently
disregarded the violation or related wrongful conduct. [NCAA
Bylaw 19.9.3-(h)]
(4)
One or more violations caused significant ineligibility or other

substantial harm to a men's basketball student-athlete or
prospective student-athlete. [NCAA Bylaw 19.9.3-(i)]
(5)
Former MBB
As described in Allegation No. 1, HC

and members of
his men's basketball staff significantly and negatively
harmed the collegiate educational experience of seven
men's basketball prospective student-athletes when the staff
engaged in academic misconduct in online courses and
completed coursework for the prospective student-athletes,
instead of having the prospective student-athletes complete
their own work.
A pattern of noncompliance within the men's basketball program.

[NCAA Bylaw 19.9.3-(k)]
b.
Former MBB
As described in Allegation Nos. 1, 2 and 3

HC
condoned or negligently disregarded violations through his
direction and participation in the underlying violations and
in his obstruction of the NCAA investigation.
As described in Allegation Nos. 1 and 2, the alleged

Former MBB
violations occurred shortly after
was hired as
HC
Southern Mississippi's head men's basketball coach and
continued through his tenure at the institution.
Mitigating factors. [NCAA Bylaw 19.9.4]

(1)
Prompt acknowledgement of the violation, acceptance of

responsibility and imposition of meaningful corrective actions
and/or penalties. [NCAA Bylaw 19.9.4-(b)]
The institution has acknowledged violations of NCAA

legislation, accepted responsibility and imposed a
postseason ban during the 2014-15 season and withheld
two student-athletes from competition once it was
Case No. 00319
July 22, 2015
Page No. 33
__________
determined they had provided false or misleading

information to the enforcement staff and the institution.
(2)
Affirmative steps to expedite final resolution of the matter. [NCAA

Bylaw 19.9.4-(c)]
(3)
An established history of self-reporting Level III or secondary

violations. [NCAA Bylaw 19.9.4-(d)]
2.
The institution was responsive to every enforcement staff

request for interviews and documents in a timely manner,
such that it expedited the resolution of the investigation.
Over the last five years, the institution has self-reported 18

Level III or secondary violations to the NCAA.
Involved Individual (
a.
Former MBB
HC
):

(1)
Multiple Level I violations by
(2)
[NCAA Bylaw 19.9.3-(a)]
As described in Allegation Nos. 1, 2, 3 and 7,

involved in multiple Level I violations.
A history of Level I, II or major violations by

Bylaw 19.9.3-(b)]
(3)
Former MBB
HC
Former MBB
HC
Former MBB
HC
was
[NCAA
August 25, 2010, Major Infractions Report involving

Former MBB
Morehead State University (Morehead State):
as
HC
the head men's basketball coach was involved in violations
at Morehead State, including a head coach responsibility
violation.
Obstructing an investigation or attempting to conceal a violation.

[NCAA Bylaw 19.9.3-(d)]
Former MBB
As described in Allegation No. 3,

obstructed the
HC
investigation by deleting emails, providing false or
misleading information, failing to protect the integrity of
the investigation and influencing the information reported
by interviewees.
Case No. 00319
July 22, 2015
Page No. 34
__________
(4)
Unethical conduct, compromising the integrity of an investigation,

failing to cooperate during an investigation or refusing to provide
all relevant or requested information. [NCAA Bylaw 19.9.3-(e)]
(5)
Former MBB
As described in Allegations Nos. 1, 2 and 3

HC
violated NCAA ethical conduct principles, and as noted in
Allegation No. 3, he obstructed the investigation by
deleting emails, providing false or misleading information,
failing to protect the integrity of the investigation and
influencing the information reported by interviewees.
Violations were premeditated, deliberate or committed after

substantial planning. [NCAA Bylaw 19.9.3-(f)]
As reflected in the allegations contained in this notice of

Former MBB
allegations,
instituted a system of academic
HC
misconduct in the men's basketball program that involved
the assistant coaches and
Moreover,
Former MBB
and the men's basketball staff took efforts to
HC
conceal their violations, including traveling to the locales
of student-athletes in an attempt to mask IP address
information and by using recruiting trips to hide their travel
where academic misconduct was carried out.
Staff Members
(6)
Former MBB
Persons of authority ( HC
condoned, participated in or
negligently disregarded the violation or related wrongful conduct.
[NCAA Bylaw 19.9.3-(h)]
(7)
Former MBB
As described in Allegations No. 1, 2, 3 and 7,

HC
condoned, participated or negligently disregarded
violations through his participation in the underlying
violations and obstruction of the NCAA investigation.

Former MBB
As shown in Allegation No. 1, HC

and members of his
men's basketball staff significantly and negatively harmed
the collegiate educational experience of seven men's
basketball prospective student-athletes when the staff
Case No. 00319
July 22, 2015
Page No. 35
__________
engaged in academic misconduct in online courses and

completed coursework for the prospective student-athletes,
instead of having the prospective student-athletes complete
their own work.
(8)
Conduct or circumstances demonstrating an abuse of a position of

trust. [NCAA Bylaw 19.9.3-(j)]
(9)
A pattern of noncompliance within the men's basketball program.

[NCAA Bylaw 19.9.3-(k)]
(10)
As described in Allegations No. 1, 2 and 3, the alleged

Former MBB
violations occurred shortly after
was hired as the
HC
Southern Mississippi head men's basketball coach and
continued through his tenure at the institution.
Intentional, willful, or blatant disregard for the NCAA constitution

and bylaws. [NCAA Bylaw 19.9.3-(m)]
b.
Former MBB
As the head coach, HC

held a position of trust related
to his oversight of his staff and the student-athletes under
his charge. However, as demonstrated in the allegations
Former MBB
contained in this notice of allegations, HC
abused that
trust by directing his staff to become involved in alleged
severe breaches of conduct, which involved studentathletes whom they were supposed to be leading and
guiding in their intercollegiate athletic experience.
Former MBB
As described in Allegations No. 1, 2, 3 and 7,

HC
engaged in severe breaches of conduct that spanned
multiple NCAA bylaws, including unethical conduct and
head coach responsibility legislation.
Mitigating factor(s). [NCAA Bylaw 19.9.4]

The enforcement staff did not identify any mitigating factors for the
involved individual.
Case No. 00319
July 22, 2015
Page No. 36
__________
3.
Involved Individual [
basketball coach]:
a.
Former MBB Asst. 3
then assistant men's

(1)

(2)
Former MBB
As described in Allegation No. 1, Asst. 3 was part of the

system of planned academic misconduct in the men's
basketball program.
Former MBB

and members of
Former MBB
his men's basketball staff, including Asst. 3
significantly
and negatively harmed the collegiate educational
experience of seven men's basketball prospective studentathletes when the staff engaged in academic misconduct in
online courses and completed coursework for the
prospective student-athletes, instead of having the
prospective student-athletes complete their own work.

(5)
is alleged to

(4)
Former MBB
Asst. 3

(3)

have engaged in unethical conduct.
Former MBB
Asst. 3
held a position of trust related to his oversight of

student-athletes, yet he abused this trust through his
involvement in academic misconduct, as noted in
Allegation No 1.

Case No. 00319
July 22, 2015
Page No. 37
__________
b.
Former MBB
As described in Allegation No. 1, Asst. 3 was involved in

unethical conduct related to academic misconduct.

4.
]:
a.
Staff Member

(1)
Obstructing an investigation or attempting to conceal the violation.

(2)
Former MBB Staff

Member 1
A described in Allegation Nos. 1 and 5,

was involved
in academic misconduct and has refused all interview
requests by the enforcement staff.

(4)
resigned from employment after the enforcement staff

arranged an interview with him and has consistently
refused to cooperate with requests for interview.

(3)
Former MBB Staff

Member 1
Former MBB Staff

Member 1

was part of the
basketball program.

Former MBB
HC

his men's basketball staff, including
and members of
significantly and
Former MBB Staff

Member 1
Case No. 00319
July 22, 2015
Page No. 38
__________
negatively harmed the collegiate educational experience of

seven men's basketball prospective student-athletes when
the staff engaged in academic misconduct in online courses
and completed coursework for the prospective studentathletes, instead of having the prospective student-athletes
complete their own work.
(5)
Intentional, willful or blatant disregard for the NCAA constitution

b.
Former
MBB Staff
As described in Allegation Nos. 1 and 5, Member 1 was not only

involved in committing academic misconduct but also in
disregarding his responsibility to cooperate with the NCAA
investigation.

5.
Staff Member
]:
a.

(1)

(2)
Former MBB Staff

Member 2

was involved in
unethical conduct through his involvement in academic
misconduct.


2

was part of the
basketball program.
Case No. 00319
July 22, 2015
Page No. 39
__________
(3)

(4)

b.
Former MBB HC

and members of
Former MBB Staff
his men's basketball staff, including Member 2 , significantly
on-line courses and completed coursework for the
Former MBB Staff

Member 2
stated in both of his interviews that he was aware

his conduct violated NCAA rules and engaged in it
nonetheless.

6.
basketball coach]:
a.
Former MBB Asst. 2
then men's associate head

(1)

(2)
Former MBB Asst. 2
has refused to participate in the NCAA

investigation and has not submitted to an interview.

Former MBB
A described in Allegations No. 1 and 6,

was
Asst. 2
involved in unethical conduct related to academic
Case No. 00319
July 22, 2015
Page No. 40
__________
misconduct and has refused all interview requests by the

enforcement staff.
(3)

(4)

(5)
Former MBB

and members of
Former MBB Asst.
his men's basketball staff, including
significantly
2
online courses and completed coursework for the

(6)
Former MBB
As described in Allegation No. 1, Asst. 2

was part of the
system of academic misconduct in the men's basketball
program.
Former MBB
Asst. 2
held a position of trust related to his oversight of

student-athletes, yet he abused this trust through his
involvement in academic misconduct as noted in Allegation
No 1.
Intentional, willful or blatant disregard for the NCAA constitution

Former MBB
As described in Allegations No. 1 and 6, Asst. 2

was not
only involved in committing academic misconduct but also
in disregarding his responsibility to cooperate with the
NCAA investigation.
Case No. 00319
July 22, 2015
Page No. 41
__________
b.
Mitigating factor. [NCAA Bylaw 19.9.4]

7.
basketball coach at
a.
NCAA Institution 3
former assistant men's

]:

(1)

(2)

over all requested records.
Student Athlete I's

HS HC
refused to turn

b.
Student Athlete I's

failed to
HS HC
provide telephone and bank records as requested by the
enforcement staff.

D.
Request for Supplemental Information.

1.
Provide mailing and email addresses for all necessary parties to receive
communications from the hearing panel of the NCAA Division I Committee on
Infractions related to this matter.
2.
Indicate how the violations were discovered.
3.
Provide a detailed description of any corrective or punitive actions implemented

by the institution as a result of the violations acknowledged in this inquiry. In that
regard, explain the reasons the institution believes these actions to be appropriate
and identify the violations on which the actions were based. Additionally, indicate
the date that any corrective or punitive actions were implemented.
Case No. 00319
July 22, 2015
Page No. 42
__________
4.
Provide a detailed description of all disciplinary actions taken against any current
or former athletics department staff members as a result of violations
acknowledged in this inquiry. In that regard, explain the reasons the institution
believes these actions to be appropriate and identify the violations on which the
actions were based. Additionally, indicate the date that any disciplinary actions
were taken and submit copies of all correspondence from the institution to each
individual describing these disciplinary actions.
5.
Provide a short summary of every past Level I, Level II or major infractions case
involving the institution or individuals named in this notice. In this summary,
provide the date of the infractions report(s), a description of the violations found
by the Committee on Infractions/hearing panel, the individuals involved, and the
penalties and corrective actions. Additionally, provide a copy of any major
infractions reports involving the institution or individuals named in this notice
that were issued by the Committee on Infractions/hearing panel within the last 10
years.
6.
Provide a chart depicting the institution's reporting history of Level III and
secondary violations for the past five years. In this chart, please indicate for each
academic year the number of total Level III and secondary violations reported
involving the institution or individuals named in this notice. Also include the
applicable bylaws for each violation, and then indicate the number of Level III
and secondary violations involving just the sports team(s) named in this notice for
the same five-year time period.
7.
Provide the institution's overall conference affiliation, as well as the total

enrollment on campus and the number of men's and women's sports sponsored.
8.
Provide a statement describing the general organization and structure of the

institution's intercollegiate athletics department, including the identities of those
individuals in the athletics department who were responsible for the supervision
of all sport programs during the previous four years.
9.
State when the institution has conducted systematic reviews of NCAA and
institutional regulations for its athletics department employees. Also, identify the
agencies, individuals or committees responsible for these reviews and describe
their responsibilities and functions.
10.
Provide the following information concerning the sports program(s) identified in

this inquiry:
Case No. 00319
July 22, 2015
Page No. 43
__________
11.
The average number of initial and total grants-in-aid awarded during the
past four academic years.
The number of initial and total grants-in-aid in effect for the current
academic year (or upcoming academic year if the regular academic year is
not in session) and the number anticipated for the following academic
year.
The average number of official paid visits provided by the institution to

prospective student-athletes during the past four years.
Copies of the institution's squad lists for the past four academic years.
Copies of the institution's media guides, either in hard copy or through

electronic links, for the past four academic years.
A statement indicating whether the provisions of NCAA Bylaws 31.2.2.3

and 31.2.2.4 apply to the institution as a result of the involvement of
student-athletes in violations noted in this inquiry.
A statement indicating whether the provisions of Bylaw 19.9.7-(g) apply

to the institution as a result of the involvement of student-athletes in
violations noted in this inquiry.
Consistent with the Committee on Infractions IOP 4-16-2-1 (Total Budget for
Sport Program) and 4-16-2-2 (Submission of Total Budget for Sport Program),
please submit the three previous fiscal years' total budgets for all involved sport
programs. At a minimum, a sport program's total budget shall include: (1) all
contractual compensation including salaries, benefits and bonuses paid by the
institution or related entities for coaching, operations, administrative and support
staff tied to the sport program; (2) all recruiting expenses; (3) all team travel,
entertainment and meals; (4) all expenses associated with equipment, uniforms
and supplies; (5) game expenses and (6) any guarantees paid associated with the
sport program.
Any additional information or comments regarding this case are welcome.
National Collegiate Athletic Association

July 22, 2015
TCH:lef

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CONFIDENTIAL/VIA ELECTRONIC MAIL

July 22, 2015

President Rodney Bennett

President Rodney Bennett

President Rodney Bennett

Mr. Britton Banowsky

Processing Level of Case.

[NCAA Division I Manual Bylaws 10.01.1, 10.1, 10.1-(b), 10.1-(c), 10.1-(g),

It is alleged that between June 2012 and May 2014,

In the spring and summer of

Former MBB Staff

institution to certify his transfer eligibility for the

then men's basketball prospective student-athlete

then men's basketball prospective student-athlete

Former MBB Staff

then men's basketball prospective student-athlete

enrolled at Southern Mississippi, competed for and received travel

In the spring and summer of

then men's basketball prospective student-athlete

Non-NCAA Affiliated Person

June 23 through July 5,

June 8 through July 5,

Former MBB Staff

August 8 through 10,

August 8 through 12,

August 12 through 16,

Metadata for coursework submitted to

Former MBB Staff

FI10: April 2 through 16,

FI11: April 15 through May 13,

FI12: May 3 through 17,

Former MBB Staff

Former MBB Staff

FI14: May 12 through 14,Student

FI15: May 12 through 14,

FI16: May 13 through 23,

FI17: May 13 through 23,

Large City Near Former MBB Staff

FI18: May 14 through June 11,

FI19: May 16,

FI20: May 29,

FI21: June 12 through July 3, Student Metadata for coursework submitted to

FI22: June 17 through July 4,

FI23: July 10 and 11,

FI24: July 10 and 11,

Former MBB Staff Member 1

FI25: July 17 and 18,

FI26: July 18 through 22,

handwriting on assignments submitted for

FI27: August 20,

FI28: September 17,

FI29: October 4 through November 20,

FI30: October 4 through November 20,

FI31: November 20 through December 2, Student Metadata for coursework

FI32: November 20 through December 2,

FI33: December 16,

FI35: April 5 through May 15,

FI36: July 17,

FI37: June 13,

FI38: August 27, 2014 Transcript of

FI39: August 27, 2014 Interview summary of the portions of

FI40: August 28, 2014 Transcript of

FI44: November 5, 2014 Southern Mississippi academic transcript for

FI45: November 5, 2014 Southern Mississippi academic transcript for Athlete E