cHyfY So 42

Received 11/07/2014 Commonwealth Court of Pennsylvania
Exhibit A
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K. LENNON
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
No. 1 M.D. 2013
JAKE CORMAN, in his official capacity

as Senator from the 34th Senatorial
District of Pennsylvania and Chair

of the Senate Committee on
Appropriations; and ROBERT M.

McCORD, in his official capacity as
Treasurer of the Commonwealth of

Pennsylvania,
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Plaintiffs,
v.
THE NATIONAL COLLEGIATE ATHLETIC
ASSOCIATION,
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Defendant.
v.
PENNSYLVANIA STATE UNIVERSITY,
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Defendant.
_____________________________________X
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Deposition of Kevin Lennon
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Tuesday, November 4, 2014
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9:03 a.m.
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Reported By: Randi Garcia
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Job No. 86741
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TSG Reporting - Worldwide

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Tuesday, November 4, 2014

9:03 a.m.
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Deposition of KEVIN LENNON, taken by Plaintiff,

at the offices of Latham & Watkins LLP,
555 Eleventh Street, NW, Washington, D.C.,
before Randi J. Garcia, Registered Professional
Reporter, and Notary Public in and for the District
of Columbia, beginning at approximately 9:08 a.m.,
when were present on behalf of the respective
parties:
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K. LENNON
A P P E A R A N C E S:
ATTORNEYS FOR PLAINTIFF.
CONRAD O'BRIEN
BY: MARK SEIBERLING, ESQ
ALEXIS MADDEN, ESQ
MATTHEW HAVERSTICK, ESQ
JOSHUA VOSS, ESQ
1500 Market Street
Philadelphia, PA 19102
ATTORNEYS FOR NCAA.

LATHAM & WATKINS
BY: BRIAN KOWALSKI, ESQ
SARAH GRAGERT, ESQ
555 Eleventh Street, NW
Washington, D.C. 20004
and ZANDRIA CONYERS
ASSOCIATE GENERAL COUNSEL NCAA
P.O. BOX 6222
Indianapolis, Indiana 46206
and KILLIAN & GEPHART
BY: THOMAS SCOTT, ESQ
MICHAEL O'CONNOR, ESQ
218 Pine Street
Harrisburg, Pennsylvania 17108
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K. LENNON
(Continued)
ATTORNEYS FOR PENN STATE.
REED SMITH
BY: MICHAEL SCOTT, ESQ
1717 Arch Street
Philadelphia, Pennsylvania 19103
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Also Present:
Kevin M. McKenna, Esquire
INDEX
KEVIN LENNON
DIRECT EXAMINATION
By Mr. Seiberling
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K. LENNON
EXHIBITS
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Page
Exhibit 1 - November 15 2011 calendar invite 53
Exhibit 2 - November 17, 2011 letter
65
Exhibit 3 - December 20, 2011 letter
73
Exhibit 4 - July 4, 2012 e-mail
79
Exhibit 5 - July 12, 2012 e-mail from Ed Ray 92
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Exhibit 13 - Binding Consent Decree
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Exhibit 14 - 7/23/2102 e-mail
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Exhibit 15 - NCAAJCOOO6722
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241
Exhibit 17 - Division Manual
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K. LENNON
Thereupon,
KEVIN LENNON,
after having been first duly sworn, was
examined and testified as follows:
DIRECT EXAMINATION
BY MR. SEIBERLING:
Q Good morning, Mr. Lennon. My name is
Mark Seiberling. I have my team of counsel
here, Alexis Madden, Matt Haverstick, Josh Voss
and our consulting expert, Kevin McKenna.
We represent the plaintiff in the matter
Senator Jake Corman. Have you been deposed
previously?
A I have.
Q As I'm sure you're aware, as far as
depositions that I take, I usually say there's
four basic ground rules. The first is that you
answer audibly. You -- the court reporter is
taking your answers. Please make sure you
answer clearly, "yes" or "no" answers. No
shaking of head or no uh-huhs. Just make sure
it's clear on the record. The second is if I
ask a question and you understand it, feel free
to ask to rephrase it, which I will do.
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The third is are you under anything -are you under the influence of anything that
would prevent you from testifying truthfully?
A I am not.
Q And the last and most important one is
if you have to take a break, have to use the
restroom, feel free to say so and we'll break at
that time.
You had mentioned you had been deposed
previously. In what matters have you been
deposed?
A A number of different matters involving
the NCAA.
Q Can you give a short list of those
matters? Beginning with the most recent, if you
can.
A The most recent was involving the Rock
litigation, a couple of weeks ago.
Q What was that matter?
A That is a challenge to the NCAA's, at
the time, yearly scholarship limit.
Previous to that, deposition related to
the O'Bannon lawsuit.
Q You also testified at the trial for the
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O'Bannon case?
A I did not.
Q Okay. Just deposed?
A Yes.
Q Any other matters that you can remember?
A Issues related to the -- our eligibility
rules in a Bowers litigation and perhaps a
couple of others related to eligibility that I'm
not recalling the names specifically.
Q Did you meet with counsel -- not getting
into the substance of your conversation -- did
you meet with counsel before your deposition
today?
A Yes.
Q Were you shown any documents?
A Yes.
Q How long did you meet with counsel?
A I met with counsel on Friday, this past
Friday, for approximately three hours. And then
I met with counsel yesterday for approximately
five hours.
Q How many people were present for that?
A For the Friday, two by video conference,
four in the room, I believe. And yesterday
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three.
Q Were any people present not lawyers?
A I believe they all were attorneys. One
may have been in law school, but I'm not sure of
his particular status at the time.
Q Did anyone from the NCAA, a nonlawyer
from NCAA, attend?
A Nonlawyer, no. I do not believe so.
Q Okay. We'll turn to your background.
Can you tell us a little about your academic
background?
A Sure. I graduated from Harvard
University in 1984. I received a master's
degree from Ohio University in 1985. I did some
doctoral work at the University of Kansas in
higher education, but have not completed that
degree. That's the academic background.
Q Okay. How about your work experience?
Starting with your first position and moving up
to your current.
A I worked at the University of Notre Dame
as a promotions director in 1985. 1986, I
joined the NCAA staff as a legislative
assistant. I then went to the Southwest

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Athletic Conference as an assistant commissioner
for about 20 months. Then I returned to the
NCAA as a director of compliance services. And
then I became the vice president of what is now
called Academic and Membership Affairs,
approximately 15 years ago.
Q Starting with your first position at the
NCAA. I think you said a legislation assistant?
A A legislative assistant.
Q What was -- what were your
responsibilities in that position?
A To help the membership and the public
interpret NCAA rules.
Q And you were in that position for three
years?
A I was in that position for approximately
two and a half years.
Q And then you moved to the Southwest
Conference?
A Yes.
Q And what prompted your move to the
Southwest Conference?
A Wanted some additional and new
responsibilities.
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Q Did you interview for that position?
A Yes, I did.
Q Did the NCAA have any role in you
obtaining or securing that position?
A They did not.
Q As I understand it, that was the year
that you moved was the year that SMU received
the death penalty?
A If not the year, it was in close
proximity.
Q Did that play a part in your
desirability or wanting to get that position?
MR. KOWALSKI: Objection to form.
THE WITNESS: I knew that they needed
help. And it provided an opportunity to
challenge myself and be of assistance.
Q When you were at NCAA, did you have any
role in the death penalty discussions related to
SMU?
A I did not.
Q So when you went to the Southwest
Conference, what was -- what were your
responsibilities there?
A I helped the member institutions
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interpret NCAA rules and I also helped them
review their compliance systems to better comply
with NCAA legislation.
Q Did you have any role in the death -- in
helping SMU through the penalty, the death
penalty?
THE WITNESS: On a very limited basis, and
it would have related more to some examination
of their compliance systems that were in place
moving forward.
Q What was your understanding of SMU's
receipt of the death penalty? Why did they
receive it?
A I believe that the violations that were
uncovered and the findings of fact were so
egregious that it warranted a discontinuation of
their sports program, their football program in
particular.
Q Were you aware of it being applied
previously?
A And to be clear, we don't have a death
penalty per se in the manual, but the
discontinuation of a sports program similar to
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what happened at SMU, I'm not aware of it being
previously applied.
Q What prompted it being applied in that
situation?
THE WITNESS: I believe that the Division
I membership, in looking at the facts, believed
that a discontinuation of the program was
appropriate and the committee on infraction,
which is the membership body, made that -- made
the decision.
Q Was SMU a repeat offender?
A I do not know.
Q As of today, you still -- at the time,
did you know?
A I don't recall.
Q Did SMU ever recover from receiving the
death penalty?
THE WITNESS: I'm not exactly sure what
you mean by recover.
Q While there, did you see -- did you have
knowledge or experience firsthand any of the
repercussions of the death penalty?

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MR. KOWALSKI: Object to form.
THE WITNESS: As with all sanctions levied
upon institutions, an institution will feel
consequences of those sanctions and SMU was
certainly no different.
BY MR. SEIBERLING:
Q Under the bylaws, isn't it true that the
death penalty only applies to repeat offenders?
THE WITNESS: Could I see the major -- the
bylaw that you're referring to?
BY MR. SEIBERLING:
Q Before we show you, are you aware of any
rule that limits the application of the death
penalty?
A Am I aware of any rule -Q Any rule or bylaw.
A -- that limits the application of the
death penalty? I'm not sure I understand your
question.
Q What is your understanding of when the
suspension of play, death penalty, is applicable
or can be applied?
MR. KOWALSKI: I mean, I think he asked to
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look at the bylaws to answer the question, so I
think it's fair to let him see the bylaws.
MR. SEIBERLING: If you look at the two
tabbed pages.
THE WITNESS: Yes, I see these.
Q Was SMU guilty of major infractions?
A Major infractions, they had a major
infractions case.
Q Was there a finding -- finding by the
infractions committee of major infractions?
A A finding of major violations?
Q I'm sorry. Major violations.
A Yes.
Q Can you flip to the second one. Can
you -- did you read the repeat offender
provision? Have you read the repeat -- the
repeat violators provision?
A I have.
Q What is your understanding of that
provision?
A This provision outlines enhanced major
violation penalties that can be levied upon an
institution.
Q And does it not include the suspension
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of play, i.e., the death penalty?
THE WITNESS: Yes, it's one of the items
included in -- in this list.
Q Does the suspension of play penalty, is
it provided anywhere else within the bylaws
other than the repeat violators provision?
A The "other penalties as appropriate"
section that exists in the major violations
section of the other bylaws, I think, could
encompass a discontinuation of a program.
Q What provisions or sections are you
talking about?
A Bylaw 19.5.2(l) under the penalties for
major violations.
Q And your position is that would allow
for a suspension of play?
A Yes. That's my position.
Q So your position is then the death
penalty is not limited to repeat offenders?
A I think the reason the major violations
lists other penalties as appropriate is to allow
the association a wide breadth of penalties when
acts were so egregious that it warrants things
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that aren't specifically listed or included on
the existing list.
Q Are you aware of the death penalty being
applied in any other situation but a repeat
offender?
A Yeah. I'm not aware that there has been
one.
Q Are you aware of the death penalty being
applied since the SMU case?
A No, I'm not aware of that.
Q Are you aware of it during your tenure
at the NCAA of it being considered in other
situations?
A Since I'm not privy to the committee on
infractions discussions, I don't know whether
it's been considered.
Q Let's turn to your current position. I
believe you said you're vice president of
Academic and Membership Affairs. What are the
job responsibilities in that position?
A Oversee a staff that helps our
membership with rules, compliance issues and
other academic policy issues.
Q Do you interact at all with the

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committee on infractions in your role?
A Not with the committee.
Q What about the NCAA employees who
support the committee?
MR. KOWALSKI: Objection.
THE WITNESS: Yes, there would be some
limited interaction.
Q Who would those individuals be?
A Primarily, the managing director of the
committee on infractions.
Q Currently who is that?
A Joel McGhormly. Mc, G-H-O-R-M-L-Y.
Q Who held that position prior to
Mr. McGhormly?
A I believe he's the first individual with
that title holding that position.
Q Who -- what was the predecessor position
title?
THE WITNESS: I believe it may have been a
director level held by Shep Cooper.
Q What was Julie Roe's title?
A Julie Roe was the vice president for
enforcement services.
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Q Did you interact with her during her
tenure there at the NCAA?
A Yes.
Q Who do you oversee in your position at
the NCAA?
A The managing directors of academic and
membership affairs are my direct reports, along
with an executive assistant.
Q Who are they? Can you name them,
please?
A Diane Dickman, Dave Schnase and Steve
Mallonee.
Q Who oversees you?
A Dr. Bernard Franklin.
Q Is there a committee that you report to?
A No.
Q There is no membership committee that
oversees you?
A Not directly.
Q When you have an issue to report, is
there is a committee, a membership committee
that you report to?
MR. KOWALSKI: Objection, form. Vague.
THE WITNESS: My reporting lines are
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through the structure of the NCAA national
office.
Q Could you walk us through your reporting
line.
A As the vice president of Academic and
Membership Affairs, I report to Dr. Bernard
Franklin, who's an executive senior vice
president of the NCAA, who in turn reports to
Mark Emmert.
Q Do you interact or report to Mr. Emmert
directly at all?
A I interact with -MR. KOWALSKI: Objection.
THE WITNESS: -- but I do not report to
Dr. Emmert.
Q Do you interact or report with Donald -to Donald Remy?
THE WITNESS: I do not report to Donald
Remy, but I interact with Donald Remy.
Q What would be the circumstances in which
you interact with Dr. Emmert?
A Particularly when issues come to his
attention that relate to the rules
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interpretations, he would naturally engage me
because of the work responsibilities. And then
to provide advisory comments as a part of my
engagement on the president's cabinet.
Q Did you know Dr. Emmert before he joined
the NCAA?
A Not really. I had met him just one time
very briefly.
Q When -- what would your interactions be
with Donald Remy?
MR. KOWALSKI: Objection. Obviously -MR. SEIBERLING: Obviously not -MR. KOWALSKI: -- don't reveal any
confidential communications.
Q Nonprivileged communications, obviously.
A Similar to issues with President Emmert
when they related to the specific application of
NCAA legislation. And then in my role as a
member of the president's cabinet.
Q Describe your role as a member of the
president's cabinet.
A Along with other vice presidents at the
NCAA to receive updates regarding broader issues
impacting intercollegiate athletics to provide

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counsel on the direction of the NCAA regarding
those issues. That -- that would be the primary
role.
Q Do you interact with Donald Remy at all
in a nonlegal capacity?
THE WITNESS: I value Donald's counsel on
issues that may potentially have legal
implications and as a good thinker, I would -would seek out his counsel.
Q Am I correct that he's also an executive
vice president in addition to being a chief
legal officer?
A I believe that's correct.
Q So he wears essentially two hats?
THE WITNESS: He does oversee the law,
governance and policy staff, so yes, there's -there's, I guess, multiple roles in that
regard.
BY MR. SEIBERLING:
Q Would you say it's common to include him
in conversations that aren't necessarily legal
in nature?
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MR. KOWALSKI: Objection to form. Vague.
THE WITNESS: There will be instances
where we would have conversations that would
not be solely related to his role as general
counsel, yes.
Q Would you copy him on internal e-mails
just to keep him involved in the conversation,
not necessarily being of a legal nature?
MR. KOWALSKI: You're asking if that's
ever happened or practice?
Q Practice, routine.
A I wouldn't say it's routine, but when I
felt like the topic, when it was appropriate
that Donald be aware of the topic in
conversation, in his role as the head of the
law, governance policy area, I would most
certainly copy him.
Q Can you explain to us the typical
enforcement process? Your understanding of that
normal process.
THE WITNESS: I'm not sure I have the
expertise to tell you what a typical
investigation would look like from an NCAA
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perspective.
Q I'm a little confused on what your role
within that investigation process is. Can
you -- can you explain that?
A I really don't have a role in the
investigation process.
Q Then what is your role in a normal -- I
believe if -- you can correct me if I'm wrong.
I believe you're involved in the eligibility of
student athletes primarily?
A That's a portion of what we do. So in
the academic and membership affairs staff, we
will interpret rules for our membership. We do
have a component where we reinstate the
individual student athletes who have been found
to violate rules and assess the individual
student's culpability in the violations and then
make a determination as to whether the students
can regain eligibility. That is distinct from
an investigation of -- of an institution where
there's institutional culpability. And that
would be the enforcement department that would
run those investigations.
Q Doesn't typically an investigation lead
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to an eligibility issue where you would come in?
A Not in all instances.
Q If the investigations people found an
eligibility issue, would they turn that over to
you or hand that over to you?
A The institution would turn that over to
us.
Q Not the investigation side?
A Yeah. The -- the institution is the -is the entity that's responsible for declaring a
student ineligible. And only after that happens
would that information then come to the academic
and membership affairs staff.
Q Let's take an example of the -- the Ohio
State investigation involving Terrelle Pryor,
amongst others. Did you have a role in that?
MR. KOWALSKI: You can answer the
question.
THE WITNESS: We did not have a role in
the investigation of Ohio State.
Q Who investigated Ohio State?
A That would be our enforcement staff.
Q And who is -- who makes up the
enforcement staff?

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A Those are national office staff members
who work in the enforcement.
Q And can you name the names?
A There's about 50 individuals.
Q Who's the head, the lead?
A It currently is Jon Duncan. Previously
was Julie Roe.
Q And then who do they report their
findings to?
A They bring allegations forward to the
committee on infractions, which is a membership
body that ultimately would review the
allegations and make determinations of the
penalties.
Q So say a student athlete who's part of
that investigation has an eligibility issue.
Then does it come to you?
THE WITNESS: Yes. If an institution,
through the course of an investigation or even
independent of an investigation, determines
that an individual student has violated NCAA
rules, the obligation of membership would
require that they declare the student
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ineligible and then it is their choice as to
whether they want to seek reinstatement. And
should they want to seek reinstatement for that
student athlete, then they would interface with
the academic and membership affairs staff and
we would make a decision on that student's
eligibility.
Q In 2010, I understand there was a change
in leadership at the NCAA; is that right?
THE WITNESS: I'm not sure of the exact
year, but that seems close to when we got a new
president of the NCAA.
BY MR. SEIBERLING:
Q Is that when President Emmert became
the -- became the current president?
A Around that time.
Q Did you notice any type of culture
change at the NCAA with the new leadership?
A I think any time you have a new
leader -- and I have been -- worked with all the
NCAA presidents, every time a new leader has
come in, there clearly has been a change in
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culture.
Q How would you describe the change under
President Emmert?
A Much more of a focus on business
performance metrics and collecting data to
demonstrate to the membership how we're adding
value, a restructured senior management team,
some changes in the organizational chart.
Things that are not unique to just Dr. Emmert,
but any time we've seen change coming into
place.
Q Did you view Dr. Emmert as being more
image conscious?
THE WITNESS: I believe Dr. Emmert
recognized that the public did not have a
really good understanding of what the NCAA
does. And he's taken significant steps to try
to have people have a better understanding of
what the NCAA does.
Q Would you say he viewed it more as a
brand?
A Compared to?
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Q Was there an effort to maintain the
brand?
Q Preserve the brand.
THE WITNESS: I think there was an effort
to -- effort to explain what the NCAA does, and
if that's considered a brand, then -- then yes.
But the clear thing was just to explain. I
think he had a great sense that people just
didn't understand the value of intercollegiate
athletics.
Q What about the authority of the NCAA?
Did Dr. Emmert seek to strengthen the authority
of the NCAA?
MR. KOWALSKI: Objection, form. I think
it's unclear.
THE WITNESS: Quite candidly, not as much
as President Myles Brand before him, who made
conscious -- more conscious efforts to examine
how the role could be strengthened within
higher education, generally.
Q We had shown you some of the bylaws,
obviously. They're pretty voluminous. What's

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you're familiarity with the bylaws?
A Many of the bylaws in our NCAA manual we
would have familiarity with in the academic and
membership affairs staff. And I would have some
level of familiarity. Other bylaws, such as the
bylaws related to enforcement and the
infractions process, et cetera, I would have
much less familiarity because those are not
areas where we have responsibility, jurisdiction
to interpret those. But in terms of the whole
NCAA manual, financial aid, recruiting, academic
standards, I generally have a familiarity with
those bylaws.
Q What bylaws govern the work that you do?
A I can't give you the specific numbers
offhand, but topic areas I would say recruiting,
financial aid, amateurism, eligibility, playing
and practice seasons, those are the -- the kind
of the meat and potatoes, if you will, of the
work that we do.
Q How do you view the bylaws? Do you view
them as being your limits on authority?
THE WITNESS: Our membership has given us
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authority in the manual as a staff to interpret
the bylaws, and so they -- they provide that
structure, but the questions that we answer are
often not specifically addressed by the bylaws.
That's the very reason they're coming to us -Q How do you handle -A -- to provide interpretations.
Q I'm sorry. How do you handle matters
outside of the bylaws?
MR. KOWALSKI: Objection to form. It's a
little -- some of the phrasing is a little
unclear, to me at least.
Q So if an issue arises that doesn't and
you -- I think you were going there with this -that doesn't necessarily fall neatly within the
bylaws, how is that handled internally within
you or your group?
A We have a database that provides a
record of interpretations that have existed that
supplement the actual bylaws themselves. So
there would always be an examination of whether
the exact question has been asked before and
answered.
Then there would be an examination of
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the intent behind the bylaw. And that may
include a review of a written record of the
membership who have adopted these rules to see
what their intent was behind the bylaw. Then
there would be a kind of collaborative staff
process that we would engage you and say, does
the fact pattern or the question being presented
here fall within the bylaws, within the intent
of the bylaw. So that's a little bit of the
nature of what would go on on a daily basis as
questions come in.
Q What do you view as the -- the core
values addressed within the bylaws?
A I guess first and foremost that the
bylaws I referenced have been adopted by our
membership as a core value, if you will, that
these are the membership rules and are -they're -- ask us then to interpret these rules
when they need assistance.
So that's -- that would be kind of the
core -- I don't know whether it's core value or
core principle that I would note as it relates
to, you know, what it is we do.
Q And if I understand you correctly, you
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report to the membership. Is that -- the chain
of command is you, as NCAA employees, report to
the membership. The membership is your
governing body?
THE WITNESS: As I previously stated,
the -- the traditional reporting lines are
within the NCAA staff and structure. The
decisions that we make as a staff regarding the
bylaws are subject to membership oversight.
And should an institution elect to do so, they
can always appeal those staff decisions to a
membership body. I just didn't interpret that
as reporting to the membership.
Q But the membership develops and approves
the bylaws?
A They adopt the bylaws.
Q Okay. And then the bylaws are your
ground rules?
THE WITNESS: The bylaws indicate what the
membership has adopted. They're often
interfacing with us because they don't know
whether the fact situation in front of them is

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addressed by the bylaws. That's the very
nature of an interpretation.
And so they've given us the
responsibility to examine the bylaws that
they've adopted that have sometimes been
reviewed in an appellate process by a
membership body in looking at the items in
the database, for example. And then our
responsibility is then to provide an answer
back to them. And in the event they don't
like the answer, they can always avail
themselves to an appellate process of their
peers to make the final decision.
Q How are criminal matters handled under
the bylaws?
MR. KOWALSKI: Objection. It's a vague
and unclear question.
Q We'll narrow it down specific to your -to the eligibility issues that you encountered.
Say a student is involved in a criminal matter
that may or may not declare them ineligible.
Are criminal matters treated differently?
MR. KOWALSKI: Objection. At least I'm
still a little bit confused.
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Q Are criminal matters addressed within
the bylaws, to your knowledge?
THE WITNESS: For an institution to
declare a student ineligible, they would have
to cite a specific bylaw that has been
violated. If there are instances where a
criminal matter also violates a bylaw, then
yeah, they would submit that to the
reinstatement staff if they wanted to.
BY MR. SEIBERLING:
Q What about immoral behavior, is that
addressed within the bylaws?
MR. KOWALSKI: Same objection. Just to be
clear, you're asking whether anywhere in the
bylaws?
MR. SEIBERLING: To his knowledge.
MR. KOWALSKI: If any of the bylaws
address immoral behavior in any way. Object to
form.
MR. SEIBERLING: I'm asking about his
personal knowledge.
MR. KOWALSKI: Right.
THE WITNESS: Quite frankly, I think it's
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how you define immoral. Is actively seeking
money from a booster as a student athlete to
jeopardize your eligibility and your team
success immoral? If your answer was yes,
then -- then we'd have a bylaw that would -would be addressing that particular part of
what you've done.
BY MR. SEIBERLING:
Q Turning back to the criminality. Could
criminality affect a student athlete's
eligibility?
A It's possible.
Q Under what circumstances?
A Unlawful engagement with an agent.
Agents are prosecuted. Yeah, it's possible.
Q What about other criminal matters, such
as assault, battery?
A If the assault and battery is in some
way interfaced, for lack of a better term, with
the NCAA matter, then it very well may. I don't
know if you want me to run through the whole
litany of possibilities.
Q I'll pick an example. Let's say a
sexual assault on campus by a student athlete.
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Could that lead to the student athlete being
declared ineligible?
A Yes.
Q Has it, that you're aware of?
A I don't know.
Q And that's provided for within the
bylaws?
A Yes. If -- if an institution provided
an extra benefit and unfair process to a student
in the investigation as an example, it's very
possible that that could be a violation of an
NCAA rule related to that student's conduct and
how it was investigated by the institution that
could result in the need to seek reinstatement.
Absolutely.
Q Is it the normal practice to allow the
criminal matter to play out before any type of
ineligibility decision is made?
THE WITNESS: Once an institution has
determined that an NCAA violation has occurred,
it's their obligation to declare the student
ineligible.
25

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BY MR. SEIBERLING:
Q And it doesn't matter whether the
criminal matter has played out in the courts?
A Once an institution has made its
decision that a violation of NCAA rules has
occurred, it's their responsibility to declare
the student ineligible.
Q It's -- it's our understanding that in
August of 2011, there was a presidential
retreat. Did you attend that retreat?
A Yes.
Q What was the -- what was the subject
matter of that retreat?
A President Emmert brought together a
group of university presidents and some athletic
directors and commissioners and others to talk
about the overall health of the collegiate
model. And the group ended up discussing those
issues and then coming up with a series of
recommendations about how to move forward to
address some of the challenges.
Q There was working groups established?
A Yes.
Q Were you part of any of those working
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groups?
A I was.
Q What group were you part of?
A I was part of the rules working group.
Q And what was your mission?
A Twofold primarily. One, to go through
the NCAA manual and the rules and to identify
those rules that were most meaningful,
enforceable or those that contributed to student
success. And then conversely to eliminate those
that did not meet that criteria.
And then secondly, to recommend a
process moving forward to make sure that rules
that are adopted meet that criteria.
Q Was there a timetable provided for how
the -- particularly the working group you were
involved in, when you were supposed to make your
findings, your recommendations?
A I don't recall a specific end date that
had been targeted.
Q Was there discussion of implementing or
developing harsher penalties for violations?
A Not as a part of the rules working
group.
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Q Was that another group?
A There were three other working groups
that were identified.
Q What were the three others?
A One was the enforcement working group.
One was, I believe, a financial working group
and one may have been a student athlete welfare
working group.
Q Who was the head or the lead of your
group?
A President Jim Barker from Clemson
University. And it was cochaired by president
Steadman Upham, U-P-H-A-M, from Tulsa
University.
Q Who was the head of the enforcement
working group?
A President Ed Ray from Oregon State
University.
Q Were there any NCAA employees assigned
to that group to work with Ed Ray in developing
their potential changes?
A I believe Julie Roe as the vice
president of enforcement services. And then I
believe she had identified certain staff to work
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with her.
Q Do you remember their names?
A I believe Laura Wurtz and Molly
somebody.
Q Did your working group ever come up with
proposed changes?
A The working group did.
Q What types of changes?
A I believe ultimately they came up with
25 rules changes that covered a wide spectrum,
most designed to provide additional benefits to
currently enrolled student athletes and
prospective student athletes. Some tried to
ease the administrative burden on some of our
campuses. And obviously some tried to eliminate
those rules that maybe weren't as meaningful or
enforceable or those that didn't contribute to
students' success. So I think it was
successful.
Q When were those proposed changes
implemented?
A I believe the effective date -- I don't
know whether it was August of 2012 or August of
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Q So it at least took a year, if not two
years to come up with the changes and then
implement them?
A Yes. It was a -- it was an ongoing
process that resulted in ultimately the
proposals going to the membership, having them
adopt them at a January date and then with an
effective date of the following August, which
would traditionally be how things like that were
handled.
Q Did you talk to Julie Roe about her
working group?
A Yes, I did.
Q What did you guys talk about?
A We talked about some of the challenges
that she was encountering with the group.
Q What were those challenges?
A First and foremost, just getting
everybody's availability to get on the calls and
move forward of developing consensus on the
proposals. What I would call kind of the normal
staff liaison discussions.
Q Did her group come up with proposed
changes?
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A They did.
Q Are you aware of what the proposed
changes were?
A In some areas, but not a lot of great
specificity.
Q What areas?
A An increase in the penalties, a new
penalty structure, a reaffirmation of head
coaches' responsibility in programs. Those are
the things that come readily to mind.
Q Did you review or comment on the
enforcement group's proposed changes at all?
A I provided my feedback to Julie. I
don't recall speaking openly in their group.
Q What type of feedback did you provide?
A I don't recall.
Q Do you know when the enforcement working
group's proposed changes were implemented?
A I don't know for sure.
Q Did you talk to Julie Roe about Penn
State's effect on that working group?
MR. KOWALSKI: Objection. Sort of vague.
BY MR. SEIBERLING:
Q I can clarify. The sanctions relating
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to Penn State, did they have any effect on the
working group that Julie Roe was involved in?
A I don't know.
Q You never discussed that with her?
A We discussed issues regarding the
timing, but the issue of one impacting the
other, I don't know.
Q What were the timing issues you
discussed?
A Issues -MR. KOWALSKI: These are discussions that
do not involve Donald Remy, I take it?
THE WITNESS: I don't know that.
MR. KOWALSKI: If you can describe the
timing issue, then maybe and -BY MR. SEIBERLING:
Q What is the timing issue you're talking
about?
A The enforcement working group was going
to make a set of recommendations that it had
already developed, and then the Freeh Report is
issued.
Q So the recommendations were tabled?
A I don't believe so.
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There was discussions of tabling?
MR. KOWALSKI: Again, if this doesn't
involve Donald.
THE WITNESS: I don't know.
BY MR. SEIBERLING:
Q What were the concerns related to the
Freeh Report and the proposed changes?
Mischaracterizes his testimony.
Q What impact did the Freeh Report have on
the timing?
A None, other than an acknowledgment that
it would require some level of explanation that
there was no connection.
Q So the concern was is that there would
be a correlation between the proposed changes
and the Freeh Report?
MR. KOWALSKI: Objection. Again,
mischaracterizes the testimony.
THE WITNESS: I think it was simply an
acknowledgment that individuals might expect as
a public announcement comes from the NCAA as it
relates to an enforcement working group. How
does this in some way tie back to Penn State?
Q

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And the answer is, it doesn't.
So simply the acknowledgment that you
have a communications challenge. That's what
I recall talking about.
Q A communications challenge to whom?
A More to the public, to some extent the
membership.
MR. KOWALSKI: Mark, let me know when
you're at a breaking point where we can use the
restroom.
MR. SEIBERLING: Let's take a break.
(Thereupon, a brief recess was taken.)
BY MR. SEIBERLING:
Q Mr. Lennon, when we stopped briefly, we
were discussing your communications with Julie
Roe related to her working group. Were those
communications via e-mail?
A I don't recall.
Q Did you typically communicate via
e-mail?
A When e-mail was the appropriate type of
communication. Other instances, it would have
been verbal.
Q Do you know when you first started
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communicating with Julie Roe about her working
group?
A I think fairly early on in the process.
Q Were you communicating with her in
November of 2011 about her working group?
A We likely had some conversations then.
Q When's the first you heard of these
Sandusky allegations?
A Sometime in the fall of 2011, I believe.
Q Had you heard of any of the allegations
prior to Sandusky being charged?
A I had not.
Q So the first you would have heard would
have been the indictment?
A Yes. The media reports. I believe
that's right.
Q Who within the NCAA did you discuss the
Sandusky indictment?
A President Emmert, I believe Donald Remy
and I don't recall the timing of others and when
we talked about it.
Q What did you discuss with Dr. Emmert,
nonprivileged -MR. KOWALSKI: If these are not
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communications that -- privileged
communications involving Donald as well, that's
possible. I don't know if you want to go more
specifically. It might help avoid some of the
privileged stuff.
MR. SEIBERLING: I was going to start
showing documents. The -- I'll show you the
document. We have a binder. We may or may not
end up using all these. But you guys can take
copies. Here you go.
MR. KOWALSKI: Any extras floating around
up there?
MR. SEIBERLING: Yeah.
Q If you flip to Tab Number 1, the
earliest communications we have involving you is
a November 15, 2011, meeting invitation. The
meeting is scheduled for the 16th. The invite
was sent on the 15th. Do you remember
communicating with anyone within the NCAA prior
to this November 16th meeting?
A I don't recall.
Q Do you remember this November 16th
meeting at all?
A I'm not sure.
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Q In the subject, what does SMG stand for?
A Senior Management Group.
Q And who comprises the Senior Management
Group?
A That was a select group of vice
presidents and above who served on Mark's Senior
Management Group.
Q Including yourself?
A No. I was an ad hoc member.
Q What does that mean?
A I would be called in when the subject
matter of the conversations either related to my
work or I could be of assistance to the group.
Q Who made -- who -- strike that.
Who makes the ad hoc determination?
A I don't know.
Q Do you remember who invited you to this
meeting?
A Appears it was Lorry Weaver.
Q Who is that?
A She's the assistant to Jim Isch.
Q Who selected the individuals to be -- to
take part in this conference call?
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Q Do you know why you were included?
A I assume they thought I could add value.
Q What type of value?
A My years of experience, my expertise, my
counsel.
Q Do you remember, was this meeting
involving Penn State?
Q Was this meeting regarding Penn State?
A I don't know.
Q Around this time, do you remember being
involved in a meeting regarding Penn State?
A Yes.
Q Who do you remember being involved in
that meeting?
A President Emmert, Donald Remy, David
Berst, Julie Roe, Wally Renfro, and there may
have been others, but I'm just not recalling.
Q And that meeting was regarding Penn
State?
A Your question was whether I remember a
meeting around this time involving Penn State
and -Q Correct.
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A -- I answered yes. And the names I gave
were the individuals I remember being in that
meeting.
Q Not getting into privileged information,
what was discussed at that meeting?
MR. KOWALSKI: You should probably start
it off with the sort of topic, like what the
topics were. But if there are topics that are
being sort of led or addressed by Donald or
directed at Donald, then, you know, we need to
be very careful there. So you can explain the
topics, but we're not going to discuss the
communications that -- where Donald was
offering legal advice or being asked to give
legal advice.
THE WITNESS: Okay. What was your
question?
BY MR. SEIBERLING:
Q The topic -- what were the general topic
areas discussed at this meeting in
November 2011?
A What, if any, were the appropriate
responses from an NCAA perspective.
Q Anything else?
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A That's pretty much what I recall we
talked about.
Q What was -- what was your position on
what the response should be?
A I believe if the allegations were found
to be true, that the NCAA was obligated to have
a response.
Q What type of response?
A I don't know. And I didn't know. But I
felt the appropriate action was to provide and
seek answers from Penn State on what their
reactions were to what was being reported and
what they were aware of.
Q Did you believe it was an enforcement
matter?
THE WITNESS: Did I at the time?
Q Yes.
A I thought it certainly could have been.
But I'd not formed a conclusion on that at the
time.
Q Did you believe the NCAA had
jurisdiction?
MR. KOWALSKI: Objection to form. That
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potentially calls for a legal conclusion. I
mean, I don't know what you mean by
jurisdiction.
BY MR. SEIBERLING:
Q Did you believe this was more than just
a criminal matter?
THE WITNESS: At this point in time, we
had been presented with an indictment. The
letter was intended to solicit the reaction
from the institution as to the legitimate
concerns the association had, that if, in fact,
the allegations were proven true, that there
would be violations of NCAA bylaws, and thus a
letter was sent seeking additional information
from the institution.
MR. SEIBERLING: Can we mark Exhibit 1?
(Thereupon, Exhibit Number 1 was marked
for identification purposes.)
MR. KOWALSKI: This is the November 15th
calendar invite?
BY MR. SEIBERLING:
Q The meeting that you were part of in

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November 2011, were minutes kept for that
meeting?
A I don't know.
Q For these SMG meetings, are minutes
typically kept?
A No. I don't recall a lot of minutes
being generated from SMG meetings.
Q How about notes? Did someone keep
notes?
A That I don't know.
Q Do you take notes?
A Sometimes, depending on the topic area.
Q Do you remember taking other handwritten
notes?
A They would be, yeah. I generally don't
bring my computer into the meetings.
Q Do you remember taking handwritten notes
during meetings related to Penn State?
A All meetings related to Penn State?
Q Any meeting that you attended.
A Sometimes, yes.
Q Did you provide those notes to counsel?
A Yeah. I provided everything to counsel
I was asked.
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MR. SEIBERLING: Can we put a formal
request on the record for those notes?
MR. KOWALSKI: We'll take it under
advisement. It may be that you already have
them. We'll have to confirm.
Q If you flip to Exhibit 3 in the binder.
Is Exhibit 3 the letter you were previously
discussing that was sent to Penn State?
A Yes, it is.
Q You had mentioned this was one option
during your meeting. Were there other options?
MR. KOWALSKI: "Yes" or "no," just to be
careful here.
THE WITNESS: I'm not sure I had mentioned
other options.
Q You had said there was multiple options
in response to the Sandusky indictment, one of
which was sending a letter to Penn State asking
for further clarification. Were there other
options discussed during the meeting besides
sending a letter to Penn State?
A You know, I don't recall if there were
other options.
Q Did you offer any other options?
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A I remember offering this option.
Q So it was your idea to send a letter?
A I don't know if it was my idea, but I
definitely encouraged and thought that this was
an appropriate approach.
Q Did anyone disagree with you?
MR. KOWALSKI: And don't reveal any
privileged communications.
THE WITNESS: I don't recall.
BY MR. SEIBERLING:
Q How about David Berst?
THE WITNESS: How about him?
Q Did David Berst believe that this was
the appropriate idea or option?
MR. KOWALSKI: Objection. Calls for
speculation.
BY MR. SEIBERLING:
Q Was David Berst questioning whether this
was an enforcement matter?
Obviously, this is standing. I'll just say it
again. If -- if this is going to reveal the
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contents of a privileged discussion with Donald
Remy, then you can't answer. But if it's not,
then go ahead.
THE WITNESS: Yeah. That's where I'm
hesitating a little bit.
BY MR. SEIBERLING:
Q If you can answer the question "yes" or
"no," please.
MR. KOWALSKI: If you don't know whether
it involved Donald...
MR. SEIBERLING: How would David Berst's
thoughts or comments during a meeting be
privileged, unless -MR. KOWALSKI: The first threshold
question is whether this was -- part of the
discussion was Berst and Remy, right? And then
we can think about that issue next. But I just
want to be clear on who was talking about what,
if you can.
THE WITNESS: I think at this point in
time, it's safe to say there were some in the
group that were trying to determine whether
this letter was the appropriate initial action
or whether another action should take place.

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And David may or may not have been in the
latter group.
But the consensus quickly formed that
this was the appropriate action to ask Penn
State these specific questions in response as
of November 17, 2011.
Q Was there -- was there a discussion of
implementing or instituting an investigation?
A I don't recall that specifically.
Q Was there any discussion of referring it
to the committee on infractions?
A Certainly something like this at this
stage would not go directly to the committee on
infractions.
Q Was there discussion of having the
enforcement group investigate?
A At this point in time, I'm not aware of
a specific conversation about that.
Q Was this -- "yes" or "no," the NCAA
oversees college athletics?
MR. KOWALSKI: If you can answer "yes" or
"no."
THE WITNESS: The NCAA oversees college
athletics for those member institutions that
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elect to be a part of the NCAA.
Q Is the NCAA's authority limited to
athletics?
MR. KOWALSKI: Objection to the extent it
calls for a legal conclusion.
THE WITNESS: Our membership has adopted
rules that govern institutional behavior in
many realms. Compliance with regulations,
academic regulations, all type of policy
regulations. And so the relationship that the
NCAA has with our member institutions, who cut
a fairly wide swath of behaviors that they've
identified in the manual, some of which I think
folks would traditionally think go beyond
athletics.
Q To also include criminal matters?
THE WITNESS: As I previously stated, in
the event that a criminal matter has resulted
in a violation of an NCAA bylaw, then the
member institution would be required to take
action with the NCAA.
Q Could the NCAA declare a student athlete
ineligible based on a criminal violation only?
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MR. KOWALSKI: Objection to form. And
speculation.
THE WITNESS: The NCAA doesn't declare any
student athlete ineligible for anything.
Q Who does?
A The member institution.
Q So there's no circumstances where the
NCAA would step in and declare the student
athlete ineligible without the institution first
declaring the individual ineligible?
A That's my understanding.
Q So the hypothetical, there's a
quarterback for the Florida State who allegedly
engaged in a sexual assault. The institution
refuses to declare the athlete ineligible. The
NCAA would not step in and declare that student
athlete ineligible under any circumstances?
MR. KOWALSKI: Objection on the grounds
that it's a hypothetical question. And also
objection to the extent it's asking about any
real situation that might bear some semblance
to that hypothetical, because those kind of
matters are confidential under the NCAA bylaws.
THE WITNESS: Our member institutions, as
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a part of their obligation of membership, are
the ones responsible for declaring student
athletes ineligible, not the NCAA.
Q Within the group who met to discuss the
options, including this letter, was there anyone
who believed that this was a criminal matter
that was -- involved off-the-field issues and
shouldn't have been something the NCAA was
looking into?
MR. KOWALSKI: To the extent you can
answer that without revealing privileged
information, privileged communications with
Donald Remy.
THE WITNESS: I don't recall specific
individuals that I can point to and say for
sure they said that the NCAA should not send
this letter, that it's a criminal matter and
should wait until that is done.
Q So to your knowledge, no one raised any
type of due process issue -MR. KOWALSKI: Objection to form.
Q -- related to the Sandusky matter?
A There certainly was -- were
conversations within the group. I cannot

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identify the specific individuals who discussed
the implications of sending the letter. And one
piece of that I know was a part that was added
to the letter that said -MR. KOWALSKI: Hold on a second. You need
to be careful talking about the drafting of
this letter, right? Who drafted this letter?
THE WITNESS: Donald Remy.
MR. KOWALSKI: Right. So let's -- let's
not get into the details of drafting the letter
at this point.
Q Were you involved in the drafting?
A I recall being asked to provide some
edits to the letter and reviewing the letter,
but no substantive drafting or writing of the
letter.
Q The four questions that appear in the
letter, who -- did Donald Remy draft those four
questions?
MR. KOWALSKI: Hold on. You can answer
"yes" or "no."
MR. KOWALSKI: Or I don't know. You can
answer that way, too.
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Q Do you remember what President Emmert's
position was with regard to the letter?
A I believe President Emmert thought the
letter was an appropriate letter from the NCAA
to send to the institution to seek responses to
these questions.
Q Do you remember discussing the letter
with any of the member institutions?
MR. KOWALSKI: You're asking about him
specifically?
A I don't believe that this letter was
circulated among other individuals, but I
don't -- I don't know for sure.
Q You don't know if it was presented to
the executive committee or Division I Board of
Directors?
A I do not know.
Q No?
A I do not know.
Q Were you on a conference call with the
member institutions regarding the letter at all?
A I don't recall.
Q Why wouldn't this letter have been
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circulated to the member institutions?
MR. KOWALSKI: Objection. Foundation.
Speculation. And mischaracterizes prior
testimony.
THE WITNESS: The letter in the drafting
phase or in the once-it's-completed phase?
Q Either.
A I'm not aware of it being circulated in
the drafting phase at all. I am aware that
subsequent to the mailing of the letter, it was
provided and cc'd to the board of directors.
Q The Division I Board of Directors?
A Yes.
Q Why wouldn't the Division I Board of
Directors have to sign off on this letter before
it was sent out?
MR. KOWALSKI: Same objections.
THE WITNESS: I don't think they were
required to do so.
Q What's your basis for that?
MR. KOWALSKI: To the extent it's not the
result of a privileged communication with
Donald Remy or other counsel with the NCAA.
THE WITNESS: I think this clearly falls
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within the purview of the president of the
NCAA.
MR. SEIBERLING: If we can mark that
exhibit as Number 2.
BY MR. SEIBERLING:
Q So if you could turn to Tab Number 4.
It's a meeting invite for November 22nd, 2011.
It states "conference call to discuss PSU." Do
you remember this conference call?
A I do not.
Q This letter -- this conference call
would have been after the November 17th letter
was sent out?
A Yes.
Q Do you remember what was discussed
during this conference call?
MR. KOWALSKI: Again, let's just start
with the topics and then we can evaluate
whether any portion of it is privileged.
THE WITNESS: I do not recall.
Q Did Penn State respond to your letter?
A It's my understanding that Penn State

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submitted the Freeh Report as their response to
the letter.
Q Turn to Tab 5. Do you remember seeing
this letter?
A I do not recall.
Q Do you remember discussing Penn State's
response with anyone at the NCAA?
A I don't recall.
Q This letter, if you read it, it
references Penn State's retention of the Freeh
Group to conduct an investigation. Is that
correct?
A Yes, it does.
Q Do you know how Penn State came to
retain the Freeh Group to perform this
investigation?
A I do not.
Q Do you know of any involvement on behalf
of the NCAA in retaining the Freeh Group for
Penn State?
A I do not.
Q Around this time period, did you have
any discussions with Julie Roe about her working
group related to enforcement?
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THE WITNESS: Yes.
Q What were those discussions,
nonprivileged discussions?
A They would have just been ongoing
conversations between two staff liaisons working
in these complicated working groups to bounce
ideas and thoughts.
Q Ideas and thoughts about what?
A About the working group itself. I do
not recall any conversations with Julie Roe
during this period of time as it relates to Penn
State in the December period of time from the
November letter on.
Q I'm sorry. Can you repeat that?
A I do not recall conversations with Julie
Roe related to her working group that involved
Penn State in the period of time that you're
referencing here.
Q When do you remember those conversations
beginning?
A As mentioned, some were in the group
setting prior to the November letter, and then
not until after the Freeh Report was received.
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Q Was there any discussion of those
working groups during these meetings, these
internal meetings that NCAA was having during
this time period?
MR. KOWALSKI: To the extent they're not
privileged communications with Donald Remy, you
can answer, or any other NCAA counsel.
THE WITNESS: There were lots of NCAA
meetings to talk about the progress of the
working groups.
Q Did any of those meetings involve the
Sandusky indictment?
A Not to my knowledge.
Q Or the response to the Sandusky
indictment?
A Those conversations occurred subsequent
to the Freeh Report being issued.
Q Did you have any contact or
conversations with anyone from the Freeh Group
prior to the Freeh Report being released?
A Me personally, no.
Q Do you know anyone who did?
MR. KOWALSKI: Are you able to answer that
question without revealing the contents of a
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privileged communication with NCAA counsel?
THE WITNESS: Yes.
MR. KOWALSKI: Okay.
THE WITNESS: I was aware that Donald was
to act as the primary liaison with the
institution and some desire to make sure that
there were no duplication of efforts.
MR. KOWALSKI: That's fine.
BY MR. SEIBERLING:
Q Duplication of efforts between whom?
A I don't know, really.
Q Between the enforcement group and the
Freeh Group?
A No. Definitely not that. His role was
just to make sure that there was a coordinated
effort between the institution and the
conferences is how I would kind of characterize
but Donald was the one that was to have those
conversations. And I wouldn't have had any
conversations with the Freeh Group or with Penn
State at all.
Q But to your knowledge, Donald Remy was
being updated on the progress of the Freeh
investigation?

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Mischaracterizes testimony.
THE WITNESS: I don't know if I could
characterize it as updated. What I know is
that he was the one who was to act in some
communication back with Penn State. And to
some extent -- I'm not exactly sure with the
Freeh Group, now that I think about that, but
clearly with Penn State, we were to have one
liaison and that was Donald doing that.
Q Who retained the Freeh Group?
MR. KOWALSKI: Objection. Foundation. To
the extent you know.
THE WITNESS: I believe Penn State
University did.
Q So why was the Freeh Group communicating
with the NCAA?
MR. KOWALSKI: Objection. You can't
reveal the contents of any privileged
communications with Donald Remy about his
interactions with the Freeh Group, if any.
BY MR. SEIBERLING:
Q You had mentioned the duplication of
effort, and I believe you had mentioned the
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conferences and the institution. Is that
correct?
A Now, let me clarify. I may be a little
bit confused about the post Freeh Report and the
pre Freeh -- between the November 17th period of
time. But I know from my perspective that I
would have no contact with them, with Freeh or
Penn State, that we were purposeful in making
sure that there was a singular point of
communication. Whether that communication was
targeted at Penn State and/or the Freeh Group,
I'm not exactly sure, but I do know that that
was consistent with the desires, at least I
believe, of the university. So that's -- that's
what I feel comfortable stating and that's what
I know.
Q But you personally did not have any
communications with the Freeh Group prior to the
Freeh Report being released?
A That's correct.
Q Were you aware of the NCAA receiving an
advance copy of the Freeh Report before it was
released?
A I don't recall being aware of that.
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Q Did you have any contact with the Big
Ten Conference?
A No.
Q Prior to the Freeh Report?
A No.
Q When would have been the first time you
saw the Freeh Report?
A The day it was released, I believe.
Q Prior to the Freeh Report, the Sandusky
verdict came down. Was there any discussions
within the NCAA about the Sandusky verdict?
A I don't recall.
Q Did you have any discussions with anyone
about the Sandusky verdict?
A You know, I don't recall.
Q Did you talk to Julie Roe about the
Sandusky verdict?
A I do not recall.
MR. SEIBERLING: If we can mark Tab 5 as
Exhibit 3.
Q Turn to Tab 6. If you could read the
second e-mail on the chain. You're not on this
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e-mail, but I wanted to ask you about the
content of this e-mail.
MR. KOWALSKI: What are you talking about,
this one right here? The 2:16 p.m. e-mail on
July 4, 2012?
Q Yes. It says, "The NCAA -- the new NCAA
leadership is extremely image conscious. And if
they conclude that pursuing allegations against
PSU would enhance the association's standing
with the public, then an infractions case could
follow.
I know that Mark Emmert has made
statements to the press indicating that -- that
he thinks it could fall into some sort of loss
of internal control case." Is that what LOIC
stands for?
"Shooting road kill is an apt analogy."
Would you agree with that statement? Let's
break it down into pieces.
Do you believe that the new NCAA
leadership is extremely image conscious?
MR. KOWALSKI: I think that's asked and
answered.
Q "Yes" or "no"?

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A I know the NCAA leadership wants people
to better understand what we do and that will
result in an improved image, no question about
it.
Q Who would the new NCAA leadership have
-- who would that have been?
MR. KOWALSKI: Objection. Speculation.
THE WITNESS: I don't know who Shep had
specifically in mind in that regard.
Q What about "pursuing allegations against
PSU would enhance the association's standing
with the public"?
Do you agree with that?
MR. KOWALSKI: Sorry. Just to clarify,
did you ask him does he agree that, in fact,
pursuing allegations against PSU would enhance
the association's standing with the public?
MR. SEIBERLING: Yes.
THE WITNESS: It appears that Shep
believes that, but I'm not sure I believe that
to be a factual statement.
Q Do you agree with that factual
statement?
MR. KOWALSKI: Which factual statement?
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MR. SEIBERLING: That pursuing allegations
against PSU would enhance the association's
standing with the public.
A Would for sure? I do not agree with
that statement.
Q Why not?
A I think there might be some in the
public and in our membership who believe that -that the result of pursuing allegations would,
in fact, not improve the public standing.
Q The next sentence. Did you believe that
this would fall into some sort of lack of
internal control case? Institutional control
case.
A I believe it's very possible at the time
in July of 2012 that as the facts proceed and
are agreed upon, that a case for lack of
institutional control could absolutely be made.
Q On what grounds?
A On lacking institutional control.
Q Based on what?
A On the actions of the university over
multiple years, over multiple individuals, over
multiple victims and the response or lack
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thereof of the university itself to demonstrate
appropriate institutional control.
Q Did the NCAA make those findings?
A The university themselves agreed to
those findings.
Q How?
A In the consent decree.
Q Did Shep Cooper talk to you at all about
his statements?
A He did not.
Q The next statement by Gene Marsh reads,
"They should leave this one alone."
Do you agree with that statement?
A I don't know what Gene Marsh had in mind
by "they should leave this one alone."
Q Do you know Gene Marsh?
A I do.
Q He was the head of infractions for many
years, is that right?
A He was the chair of the committee on
infractions for a number of years, yes.
Q You had worked with him?
A I've worked with Gene.
Q At the NCAA?
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A Particularly when he was the faculty
athletic representative at the University of
Alabama.
Q Did you -- since he has left the NCAA,
do you communicate with Gene Marsh?
A On occasion.
Q Did he communicate at all directly with
you about the -- about the Penn State matter?
A At any point in time?
Q Yes.
A Yes.
Q Before or after the consent decree was
entered?
A That I don't recall.
Q Did Gene Marsh ever communicate to you
his sentiments that the NCAA should quote, leave
this one alone?
A Gene expressed to me some general
frustrations, but quite candidly, I don't know
if they ran to "they should leave this one
alone."
Q What were those frustrations?
A Gene had a tendency to be frustrated
about a lot of things. Quite candidly, I

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couldn't tell you right now exactly what he was
frustrated about.
Q You can't give one example of a specific
frustration he had?
A Related to Penn State or overall?
Q Related to Penn State.
A I recall him questioning the scope of
the integrity agreement.
Q That would have been after the consent
decree?
A Yes.
Q Did he voice any frustrations related to
the consent decree itself?
MR. KOWALSKI: And just to be clear here,
I believe you're asking about direct
communications between you and Gene Marsh, so
not things that are getting funneled through
legal counsel here.
Q What were the frustrations related to
the integrity agreement?
A I seem to recall it was maybe regarding
the scope of the agreement.
Q What about the scope?
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That I don't recall, the specifics.
The scope as being too broad?
Yes, in general terms, yes.
MR. SEIBERLING: If we can mark Exhibit 6
as number 4.
Q If you look at tabs 9 and also 10. 9 is
a call, a conference call, an internal NCAA call
for July 10th. And then Tab 10 is a call for
July 11th. Both of these calls predated the
Freeh Report. Do you remember the topics of
these two phone calls?
A I do not.
Q Do you remember taking part in either of
these calls prior to the Freeh Report being
released?
A I don't recall.
Q Do you remember receiving an update on
what the Freeh Report may or may not contain
prior to its release?
MR. KOWALSKI: I'd caution you not to
reveal the contents of privileged communication
with Donald Remy or any NCAA counsel.
A
Q
A
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THE WITNESS: Yeah, I don't recall.
Q Were you aware if Donald Remy, the
counsel had received such an update? I'm not
getting into the substance.
A Yeah, I don't recall.
Q Were you aware of Gene Marsh being
retained by Penn State prior to the release of
the Freeh Report?
A That I don't know.
Q At any meetings, do you remember
discussing the retention of Gene Marsh by Penn
State?
A I recall becoming aware that Gene was
working with the institution, but I do not
recall when or the -- when those conversations
took place.
Q Was he recommended by the NCAA?
A I do not know.
Q Prior to the release of the Freeh
Report, do you remember any discussions of a
potential consent decree being entered between
Penn State and the NCAA?
MR. KOWALSKI: So this is -- I have to
object on privilege grounds here, because I --
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I suspect that your answer is going to have to
involve legal communications with Donald Remy
as NCAA legal counsel to answer that question.
Well, I don't know for sure.
It can't -- put it this way. If you
can't answer it without revealing those
communications, don't answer, but if you can,
go ahead.
THE WITNESS: Yeah, I don't recall. I
don't know.
BY MR. SEIBERLING:
Q If you'd flip to Tab 11. Do you
remember receiving and reviewing the Freeh
Report on July 12th?
A I remember reading the Freeh Report
around this time, yes.
Q The e-mail states -- and it's from Mark
Emmert -- "Let's begin the review immediately.
There is obviously much to digest and consider
in this."
And you were a recipient of that e-mail,
correct?
A Yes.
Q The individuals included on the e-mail,

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any idea why these specific individuals were
included? Strike that.
Why were you specifically directed to
read the Freeh Report?
speculation.
THE WITNESS: I assume because of the
expertise that I brought to -- through you that
Mark would have found valuable.
Q I'm struggling to understand why you
were involved if you were more student
eligibility and not investigations or
enforcement. Can you explain why you would have
been included?
MR. KOWALSKI: If you know why he included
you.
THE WITNESS: I think Mark believes me to
be a thoughtful guy. And you'd have to ask him
why.
Q Were there any actions you or your group
could have taken related to the Freeh Report or
from the Freeh Report?
THE WITNESS: Not knowing what the Freeh
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Report contained at the time prereading, there
certainly may have been issues that required
interpretation. There may have been issues
that student athletes had eligibility that were
impacted. At this point in time, you didn't
know what was contained in the report.
BY MR. SEIBERLING:
Q After reading the report, was there
anything that you -- any action that you or your
group could have taken based on the Freeh
Report?
A The Academic and Membership Affairs
Group? If the institution, upon its receipt,
had requested an interpretation, that would have
been available to them.
Q An interpretation on what?
A Do these findings violate NCAA rules,
which they could have availed themselves of at
the time when they got the report. That would
have been subjected to a staff review. That
could have -Q Was that request ever made?
A It was not. It was available to the
institution, but they did not pursue that.
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Q After reading and digesting the Freeh
Report, did you meet with anyone, any other NCAA
employees to discuss it?
A Yes.
Q Who was that?
A I believe some meetings were called
among the people that Mark had noted in his
e-mail when he encouraged us to begin the review
immediately. But there would have been some
meetings then subsequent to that review.
Q Not disclosing privileged
communications, what topics were discussed with
regard to the Freeh Report?
A Well, I think we were all digesting the
horrific nature of what was outlined, and the
finding of fact that was contained in the
report, and so you initially took in the scope,
the magnitude of what was before you. And so
you began with that -- that just basic human
element of sadness and all that went with -with what was found. And then began to talk
about what that report meant and as it related
to the November 17th letter.
Q And what was the conclusion?
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THE WITNESS: What was the conclusion of
what?
Q What was the NCAA's decided response to
the Freeh Report? What did the NCAA decide to
do in response to the Freeh Report?
MR. KOWALSKI: Just a moment here. Let me
confer on this for a second just to make sure.
We need to make sure this -MR. SEIBERLING: We can strike that. I'll
come back to it.
Q Based on your reading of the Freeh
Report, did you understand there to be a
violation of NCAA rules or bylaws?
A That specific question was never put to
our staff by the institution. They seemed to
acknowledge very quickly that there were those
violations. So I never had that specific
question put to me. My personal opinion is yes,
that a very reasonable person could assume that
an institutional control or unethical conduct of
staff members. The bylaws at play there could
be reasonably cited in that. But, again, the
institution never asked that question of our

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staff or me.
Q What specific acts or omissions within
the report would have constituted a violation?
A Of what?
Q Of the NCAA's bylaws or rules.
MR. KOWALSKI: Objection. I mean, he
doesn't have the report with him. He's not
looking at a copy of the report or -- I mean,
that's a -- if you can answer it, answer it
anyway.
MR. SEIBERLING: He mentioned he said he
thought it would be a violation of the rules or
bylaws.
Q What -- what made you think that within
the Freeh Report?
A Multiple transgressions by multiple
individuals over multiple years represents at a
reasonable level of lack of institutional
control of the conduct of your program. The
individual behaviors cited within the Freeh
Report by athletics department staff members
reasonably reflects unethical conduct and
behavior in the conduct of the program.
While I don't have the specific bylaws
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in front of me, a reasonable person can reach
those conclusions. And the institution
ultimately did.
Q When you say transgressions, do you mean
off-the-field transgressions or on-the-field
transgressions?
THE WITNESS: I don't know what
on-the-field transgressions mean.
Q Related to student athletics, were
there -- were the transgressions specifically
student athletics related?
THE WITNESS: Did -- were student
athletics cited as violating NCAA rules in the
Freeh report? I don't believe so. Were
institutional staff members responsible for
providing leadership governance of the student
athletes themselves cited in the report?
Absolutely. And that's where the issues of
institutional conduct fall. They fall to the
behaviors of the adults. And the unethical
conduct issues that I noted I think were
clearly noted in the report.
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BY MR. SEIBERLING:
Q Did -- is it your understanding of the
Freeh Report that any individuals specifically
were found be culpable?
THE WITNESS: Yes.
Q Who are they?
A Off the top of my head without having
the report in front of me, I believe there is
mentions to obviously Sandusky, Coach Joe
Paterno, Tim Curley, Graham Spanier, Schultz. I
believe that those are names specifically
mentioned in the report.
Q Why were no actions taken against those
individuals by the NCAA?
MR. KOWALSKI: Objection. You're
cautioned not to reveal the contents of any
privileged communications with Donald Remy on
this topic. So you can answer if you know and
you can do that.
THE WITNESS: Why were no actions taken
against the individuals by the NCAA?
Q Yes.
A I don't know that to be entirely true.
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Q What is untrue?
A I believe there -- as a part of the
consent decree, the university agreed to vacate
wins.
Q So that was a punishment directed
towards Joe Paterno?
A That was a punishment directed at the
institution.
Q Not the individual?
A Right.
Q So then why were no actions taken
against the individuals?
A Yes, I'm sorry. I misunderstood your
question.
Well, as a member institution of the
NCAA, that's who -- they're the members of the
NCAA, the institution.
So, as the institution then receives the
penalties, is there an impact on those who work
for the institution? Absolutely. But the
penalties are purposefully kind of institutional
in nature.
Q How can you have institutional
violations or penalties without having

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individual culpability?
Q Would you agree that you don't have an
institution without individuals making up that
institution? Is that correct?
MR. KOWALSKI: Object to foundation.
THE WITNESS: Institutions of higher
education have individuals working for them to
advance their mission. And -- and yes, they're
employees of the institution and they work for
the institution.
Q So how do you have institutional
culpability without having individual
culpability?
MR. KOWALSKI: Objection. Foundation and
form. Potentially calls for a legal conclusion
as well.
Q You can answer.
A Yeah, I'm not an attorney. But, again,
I would just suggest that we're a membership
organization. We're not an organization of
individuals.
Q Aren't you an organization comprised of
individual institutions?
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A Yes. We're -- of individual
institutions, not individuals. The members of
the NCAA are our institutions.
Q Just like an institution, its members
are the individuals. Is that not correct?
A I think an institution's actually more
than just the actual individuals that are on
campus at any particular time. They're everyone
who's been a part of the campus. They're -that's a very esoteric question, Counselor.
So our relationship at the NCAA is with
the institutions. They are members of the NCAA.
We do not have individuals who are members of
the NCAA. Individuals do comprise our
universities and are part of the university
system. But our members are our schools.
Q I guess, would you agree that in order
to have an institutional violation, you would
have to have individuals who committed
violations?
Foundation. Legal conclusion. And you can't
discussions. The only way you know -- have an
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answer to this is through privileged
discussions about Remy. That's something you
need to know I'm going to object on. Or other
NCAA legal counsel.
Q If you can answer that question, please
do.
A Every violation ever committed has been
done by a human being. That's the nature of the
world.
MR. SEIBERLING: Can we mark Tab 11 as
Exhibit 5.
MR. KOWALSKI: At some point, can we take
a break?
Q If you can flip to Tab number 13. This
is an e-mail from Ed Ray to Julie Roe.
According to the metadata for this, you were
forwarded this e-mail. Do you remember seeing
this e-mail?
A I'm not sure at the time that I recall
-- I'm not recalling it at the time.
Q And I'll read it into the record. "Ed
Ray states to Julie Roe, I am concerned about
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the connection I see in comments on the Penn
State story and the NCAA. You and others are
smarter than I am about what can be done when,
but I think it is worth reconnecting with legal
authorities to determine if there is enough
flexibility and access to information for the
NCAA to get on with an assessment of issues at
Penn State."
Any idea what Ed Ray was talking about
there?
speculation.
THE WITNESS: Well, I think as you noted
for the record, he's trying to figure out
whether there's enough flexibility and access
to information for the NCAA to get on with an
assessment of issues at Penn State.
Q The next sentence states "the sounds of
silence are not good." Any idea what he meant
by the sounds of silence?
A Yeah, you'd have to talk to Dr. Ray.
Q Did Dr. Ray talk to you about any of
these issues?

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A I don't recall.
Q Next sentence states "If Penn State
could have Louie Freeh conduct an investigation
over the last year, why haven't we done
anything?"
Can you answer that question? Why
haven't -- why didn't the NCAA do anything?
A Well, the NCAA did do something. They
sent a November 17th letter to the university
asking a series of questions. And the
university, as you noted earlier, provided a
letter back that indicated that they had
contracted out with the Louie Freeh Group to
conduct their fact finding. And that was the
agreed-upon approach.
Q Why did the NCAA not conduct its own
fact finding?
MR. KOWALSKI: Objection to the extent
this doesn't reveal privileged communications
with Donald Remy, and foundation.
THE WITNESS: We believed that the
November 17th letter was a sufficient response
at the time.
Q Was your understanding that the Freeh
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Group would conduct its fact finding for the
NCAA?
A I don't know.
Q Did Penn State ever respond to those
four questions that were set forth in the
November 2011 letter?
A It's my understanding that Penn State
submitted the Freeh Report in response to the
questions that were posed.
Q You never asked -- you never asked them
to then answer the four questions after the
Freeh Report was issued?
A I don't know what was specifically posed
to them, but my understanding is that they, in
fact, submitted the Freeh Report as their
response back to those questions.
Q So your understanding was the Freeh
Report would have answered those four questions?
A My understanding is that's what the
university believed, that the Freeh Report did
respond to those questions.
Q Did you believe that the Freeh Report
answered those four questions?
A I believed that there were some
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questions that perhaps remained that were not
directly addressed by the Freeh Report. My
personal opinion. But what was most important
is that the university believed that the Freeh
Report had addressed those questions and
submitted that as such.
Q So it wasn't more important that you
believed that the Freeh Report answered those
four questions?
A Me personally?
Q Yes.
A I'm just -- it's most important that the
Board of Directors and the executive committee
were satisfied that the Freeh Report responded
to those questions, because the institution said
it did. My -- my personal opinion is just that.
Q Was there any discussions of having Penn
State specifically answer those four questions
that were raised?
MR. KOWALSKI: Objection. If these
discussions involve legal counsel, we have
to -- you can't reveal the contents of the
privileged communication with legal counsel.
THE WITNESS: Yeah. I'm not going to
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answer that. I think it does fall within that.
Q Let's -- the next paragraph in the -the July 12, 2012 e-mail. "Some clarity about
when Penn State is expected to respond to the
four questions asked and the timeline or
triggers for the NCAA assessment of matters
seems appropriate to me."
So apparently, Ed Ray didn't believe
that the four questions had been answered; is
that correct?
A It would appear so. You'd have to ask
Dr. Ray.
Q Then it goes on. "Announcing in three
weeks the sweeping changes in enforcement,
culture and penalties we intend to implement
over the next two years. While remaining silent
on the Penn State matter could easily invite
cynicism, even from those who are rooting for us
to get this right."
Any idea what Dr. Ray means by that
statement?
speculation.
THE WITNESS: I can speculate that

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Dr. Ray, knowing that the enforcement working
group that he had been working with was going
to issue the set of recommendations that really
had nothing to do with Penn State and as
such -- as I've said before, Penn State was
never a discussion of the working group -might be hard for some who hadn't been
following the issue to understand that they, in
fact, weren't connected.
Q So these were -- this would be the
concern that you were discussing with Julie Roe.
You'd talked about previously how you and Julie
Roe -- you and Julie Roe were discussing the
impact of the Freeh Report on the proposed
changes.
A Yes. The challenges that would be
present by issuing a separate report on the
enforcement working group that from a timing
perspective happened to occur at the same -same time as this particular issue.
Q So it appears that Ed Ray had these same
concerns too?
speculation.
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THE WITNESS: I would speculate so, yes.
BY MR. SEIBERLING:
Q Who else were these concerns shared with
that you're aware of within the NCAA?
MR. KOWALSKI: I caution you not to reveal
the contents of a privileged communication with
NCAA legal counsel.
THE WITNESS: I think I recall Wally
Renfro voicing some of those concerns or
challenges regarding the timing.
But other than that, I can't come up
with a specific individual.
Q At this time, were you aware of Ed Ray's
position on what should be done regarding Penn
State and the Freeh Report? It would have been
July 12th.
A I was not.
Q At this time, was anyone within the NCAA
questioning the -- the accuracy or the validity
of the Freeh Group report at all?
MR. KOWALSKI: Objection. Obviously,
don't reveal the content of any privileged
communications with Donald Remy or any of the
other NCAA legal counsel.
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THE WITNESS: I don't recall any
conversations from anyone who questioned the
accuracy of the Freeh Report, in large part
because none of us conducted any of the
investigations or questioning.
Q What about the completeness of the Freeh
Report?
MR. KOWALSKI: Same objection. Please do
not reveal the contents of any privileged
communication with NCAA legal counsel.
And objection to form. Vague.
Q Did you personally raise any questions
concerning either the accuracy or the
completeness of the Freeh Report at any time?
MR. KOWALSKI: Objection. Don't reveal
the contents of any communications with Donald
Remy for the purposes of requesting or
receiving legal advice.
THE WITNESS: I was not privy, obviously,
to what -- who the Freeh Group talked with. So
the completeness, I'm not able to speak to.
I think I noted, as others did, that not
everyone made themselves available to be
interviewed. I recall having that thought.
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Q Was that a concern to you?
A Only to the extent that you want to have
all people involved, communicating and being
willing participants.
Q Did you or anyone within the NCAA
suggest that the NCAA go back and interview
those people that the Freeh Report may have
missed?
MR. KOWALSKI: Objection. Please do not
communications with Donald Remy or any other
NCAA legal counsel.
THE WITNESS: Yeah, I don't recall
suggesting that.
Q Do you remember anyone else suggesting
that other than perhaps Donald Remy?
MR. KOWALSKI: Not just Donald Remy, but
people discussing this in a privileged
communication with Donald Remy or any other
NCAA legal counsel.
THE WITNESS: Yeah, I don't recall that
conversation or if it happened.
MR. SEIBERLING: If we could mark Tab 13
as Exhibit 6.

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Page 103

Q If you could flip to Tab 14. It's a
conference call scheduled for July 13th. And it
appears that you are one of the persons invited.
Do you remember this conference call?
This would have been after the Freeh Report.
A I do not.
Q And its subject's titled "follow-up on
Penn State discussion." Any idea what the
follow-up would have been?
the contents of the privileged legal
communications with Donald Remy.
A It's likely that we were talking about
what we had seen conveyed in the Freeh Report.
MR. SEIBERLING: We can break it there.
BY MR. SEIBERLING:
Q Mr. Lennon, if you can turn to Tab 15.
This is an e-mail from you to Julie Roe dated
July 15th, 2012. Do you remember receiving this
or do you remember sending this e-mail to
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Ms. Roe?
A Yes.
Q We're going to take a step-by-step walk
through it if we can. So the first sentence
reads, "Sending this to you only to get a sense
of how off I am on what I see transpiring with
our internal group."
Can you explain that sentence?
A I was seeking Julie's counsel on a
number of issues that I then outlined to get a
sense from her as to whether I was on the right
track or not with -- with some of the issues.
Q What was transpiring with your -- "our
internal group"?
MR. KOWALSKI: Remember not to reveal the
contents of privileged communications from NCAA
legal counsel.
THE WITNESS: Yeah, I know that at this
point we had received the Freeh Report and we
were beginning to have discussions regarding,
you know, what the appropriate response would
be to the Freeh Report. And I outline a number
of issues that I wanted to raise with Julie to
get her feedback, to get her sense of her view
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of those particular issues.
Q What did you mean by "how off I am"?
What were you off on?
A I was really trying to get a sense from
Julie as to whether she saw some of the issues
that I raised below, whether she had some of the
same thoughts as she was hearing the
conversations on issues that we needed to
further clarify. And so as a trusted colleague,
I was just asking her were the issues that I was
raising kind of appropriate.
Q Why Julie Roe?
A I respected Julie's opinion as a
colleague.
Q Did it have anything to do with her
being in the enforcement group?
A No. It had more to do, really, just
with her and trusting her opinion and as a
colleague and -- and in general, the expertise
that she brought to all the issues.
Q Did it have anything to do with her
being involved in the working group related to
potential changes to the enforcement process?
A No. That wouldn't have been a reason.
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Q The next sentence reads, "I feel like it
is a bit of a runaway train right now. And I am
a bit concerned on a couple of fronts."
A Sure. We had -- at this point, we had
received the Freeh Report and we were discussing
what were the appropriate responses from an NCAA
perspective. And I wanted to make sure that we
were as thoughtful as we needed to be as a group
about what the most appropriate responses would
be to these findings.
And I outlined below in the e-mail here
the areas that I wanted some feedback, that I
thought were important that the group consider.
Q What was a, quote, runaway train right
now?
THE WITNESS: Yeah. I said a bit of a
runaway train. And I just wanted to make sure
that, again, having just received the Freeh
Report, that we were making sure that we had
identified all the appropriate issues in terms
of our response.
Q Well, a runaway train -- you can correct

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me if I'm wrong -- is generally some train going
off track. What in this case was going off
track?
THE WITNESS: I wanted to make sure that
we were staying on track, and...
MR. SEIBERLING: In what way was it going
off track?
MR. KOWALSKI: Obviously, continue to not
reveal the contents of privileged
communications with Mr. Remy and other NCAA
legal counsel.
THE WITNESS: Yeah. At this point in
time, I don't think anything had gone off
track. What I wanted to make sure as a group
that we were thoughtful about all the responses
and that we had considered all of the
implications.
Q At this point, what was the right
track -MR. KOWALSKI: Objection to form.
Q -- in your view?
A At this point, I am not sure I formed an
absolute opinion on exactly what the right track
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would be. That did evolve over time with -with -- certainly with me.
Q At this point, were there several
options on the table?
MR. KOWALSKI: Again, without revealing
any confidential or privileged communications.
THE WITNESS: I don't know if I would
characterize them as options, but there were
issues within the framework of the response
that required thoughtful consideration. That's
kind of how I viewed it.
Q Was instituting a infractions
investigation one of the options?
A I don't recall that specifically being
mentioned, but it could have been.
Q Was the idea of a potential consent
decree on the table at this point -MR. KOWALSKI: Is there any way to answer
that without revealing discussions you had with
Mr. Remy?
THE WITNESS: There is. It's I don't
recall.
BY MR. SEIBERLING:
Q The next sentence reads, "I most
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certainly will share these thoughts with the
group if some of it makes sense."
Did you ever share your thoughts with
anyone else other than Julie Roe and other than
counsel Donald Remy?
MR. KOWALSKI: Or in -- if they're in -with counsel for the NCAA or in discussions
with -- that involved counsel for the NCAA
providing legal advice to the association.
Q Well, I think you can answer the
question.
MR. KOWALSKI: Yes.
Q Did you raise one or more of these five
issues with counsel?
MR. KOWALSKI: I don't think he can.
MR. SEIBERLING: I'm not asking his advice
on it. I'm saying did he bring it toMR. KOWALSKI: But, I mean, it's not -these are pretty detailed things. So if you're
asking did he discuss these detailed things
with counsel -MR. SEIBERLING: I'm not -- whether he
discussed it or what the advice was, were these
issues raised to Donald Remy?
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MR. KOWALSKI: I don't think he can answer
that question.
BY MR. SEIBERLING:
Q Did you forward this e-mail to Donald
Remy?
A I don't believe I did.
Q Did you forward it to anyone other than
Julie Roe within the NCAA?
Q Why not?
A I would have communicated these verbally
to a broader group if I did rather than sending
an e-mail.
Q And did you communicate it to a broader
group?
MR. KOWALSKI: Did the group involve -did the group include individual NCAA legal
counsel, if you -- if you remember?
THE WITNESS: Yes. It likely would have.
Legal counsel would have been a part of all
conversations that I would have had outlining
these concerns to a broader group.
MR. KOWALSKI: So to the extent this
happened, I think we have to assert privilege.

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Q Did you raise these directly to
President Emmert without Donald Remy being
present or counsel for the NCAA?
A I don't recall.
Q The top of the e-mail reads
"confidential." Why did you mark this e-mail
confidential?
A I wouldn't have wanted Julie to forward
the e-mail.
Q Why?
A Because I was asking her personal
opinion on these matters and I recognized that
they were sensitive in nature.
Q So everything in here is -- raised
herein is your personal opinion on the situation
as you saw it on July 15th, 2012?
A Yes.
Q Let's start with number 1. It reads
"The more penalties and sanctions placed on
school, conference, other members, the less
likely they will agree."
What did you mean by that sentence?
A That the more penalties and sanctions
that is placed on an institution, the more
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likely they are to not accept the penalties or
to agree to the penalties or to believe that the
penalties are appropriate.
Q As in an agreement, a negotiated
agreement?
THE WITNESS: Yeah. I wasn't using agree,
I don't think, in a legal sense there. There
comes a point in time when the more penalties
and sanctions that are placed on a school that
they may not agree, may -- may appeal, whether
it's -Q Did you mean within the infractions
process or within some other process?
THE WITNESS: I just generally meant just
agree.
BY MR. SEIBERLING:
Q The next sentence reads, "I know we are
banking on the fact the school is so embarrassed
they will do anything".
What did you mean by that statement?
A You know, I knew that, having read the
report, you know, we were -- I think everybody
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was kind of shocked and saddened, and I
absolutely think it's probably realistic that
Penn State was both shocked, sad and
embarrassed. I mean, I don't -- that doesn't
surprise -- I mean, that -- that would be a
natural reaction to have that, and so...
Q What would they have been embarrassed
about?
A Oh, the behavior of individuals in the
program over multiple years. And that's for you
to ask them if they're embarrassed. But you
could have replaced embarrassed with sad and
shocked, horrified, whatever.
Q I think embarrassed is a -- has a
different connotation.
A It's one word choice in an e-mail. So
my main point in that was that there comes a
point in time when regardless of how
embarrassed, shocked or horrified an institution
may be, that they may push back because they
feel that whatever penalties and sanctions come
to them are more significant. And that's what I
was intending in that paragraph.
Q You say "embarrassed, they will do
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anything."
MR. KOWALSKI: Is that a question?
MR. SEIBERLING: I'm getting there.
Q So -- and you can correct me -- my
interpretation of that is Penn State will do -will take any penalty that the NCAA is offering
at this point. Is that correct?
A No. The subsequent thing, but I'm not
sure about that. So I'm clearly indicating that
they won't.
Q But you were banking on that fact,
according to your statement. Is that not
correct?
MR. KOWALSKI: And throughout all this,
just continue to not reveal confidential
communications with NCAA legal counsel.
THE WITNESS: My point in raising that
particular issue that Penn State, whether it's
embarrassed, shocked or whatever, that they
recognized that significant penalties were
going to be coming their way. And my main
point in that is to say that there comes a
point when they may say regardless of how
horrific, regardless of how sad, regardless of

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how embarrassed we are, we're -- we're not
going to -- we don't believe that those
penalties or those sanctions are appropriate.
And that was the main point I was trying to
make in that paragraph.
Q In this paragraph, were you -- it seems
as if you're discussing the possibility of a
negotiated agreement with Penn State. Is that
not correct?
A No. That's not correct.
Q Then what would Penn State be agreeing
to?
A Well, every institution can appeal
anything along the way. They could have
appealed the interpretation that no bylaws were
violated to a membership group. They could have
asked that the enforcement process take over.
Q But would they have been -A Along the way -- you agree to the facts
along the way. And there comes a point in time
when they may not agree with whatever it is that
they're contemplating.
Q But at this point, there was nothing.
There was nothing to appeal from. What was
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there to appeal from at this point?
Q The findings of the Freeh Report?
A Or the findings of the Freeh Report as
whether they violated NCAA rules.
Q And that determination had already been
made?
THE WITNESS: Yeah, I don't know.
BY MR. SEIBERLING:
Q At this point, how did you know that
Penn State was aware that penalties would be
coming?
MR. KOWALSKI: Please don't reveal
confidential communications with legal counsel.
Q So if -- at this point, there was no
investigation being performed by the infractions
committee; is that correct?
THE WITNESS: Well, the infractions
committee wouldn't -- wouldn't do an
investigation.
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Q The investigative arm of the NCAA.
A I don't believe there was.
Q So then if there's no infractions
process, no investigation, what is there -- you
mentioned appeal. What is there to appeal from?
A They could -MR. KOWALSKI: Objection to form.
THE WITNESS: They could take the position
that no NCAA rules were violated.
Q Before whom would they take that
position?
MR. KOWALSKI: Objection. It's also a
hypothetical at this point, basically.
THE WITNESS: They absolutely could have
sought as a member institution an
interpretation as to whether NCAA rules had
been violated.
Q But hadn't that determination already
been made? At this point, you were talking
penalties.
THE WITNESS: I don't know what Penn State
had in their mind after having read the Freeh
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Report and whether they believed they should be
sanctioned. I have no idea.
What I do know is they ultimately agreed
that they had violated NCAA bylaws and
willingly entered into the consent decree. I
don't know what they believed.
Q As of July 15th, had they agreed to
that?
A I don't know. I don't know what Penn
State was thinking as of July 15th.
Q But based on your e-mail of July 15th,
were you not talking about penalties and
sanctions being placed on Penn State?
A It was certainly within the realm of
possibility that as a national organization
having read the Freeh Report, that you might
consider what the appropriate response to the
report would be. Any reasonable person in an
organization would consider that in light of the
facts that came forward in the Freeh Report,
multiple years, multiple transgressions over
multiple individuals, the lack of control
demonstrated by the institution that they
ultimately agreed to, the unethical behavior of

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their coaches and administrators, which they
ultimately agreed to, the possibility that
sanctions could be applied in those instances,
if you're asking if that's a realistic thought
in conversation that could have happened, and
was going -- the answer is yes.
Q I'm saying on July 15th when you wrote
this e-mail, that was a real possibility?
A What was a real possibility?
Q The implementation of penalties or
sanctions against Penn State.
MR. KOWALSKI: Objection. Asked and
answered.
THE WITNESS: Conversations were taking
place as to what the most appropriate responses
as an organization should occur based on the
findings of the Freeh Report. And I do not
know where the institution's position was on
July 15th. I do not know that.
Q What types of penalties or sanctions
were you talking about at this point?
A I don't know. I don't recall.
Q At this point, what was your
understanding of Penn State's position?
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MR. KOWALSKI: If you can do that without
revealing confidential communications with
Mr. Remy.
Q The next sentence reads, "This will
force the jurisdictional issue that we really
don't have a great answer to that one."
What is the jurisdictional issue?
A I took that to mean whether or not the
enforcement process would be engaged.
Q And why wasn't it?
MR. KOWALSKI: Objection. If you can
answer -- can you answer that question without
revealing confidential communications with
Mr. Remy?
THE WITNESS: I can.
MR. KOWALSKI: Okay.
BY MR. SEIBERLING:
Q Did you believe that it should have been
referred to the sanctions or to the infractions
process?
A Which question's on the table?
Q Did you believe that it should have been
referred to the infractions committee or the
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infractions process?
A No.
Q Than I'm unclear. What is the
jurisdictional issue then?
A You asked my opinion.
Q Yeah. What is your opinion of the
jurisdictional issue?
A That they're -- the question could be
raised as to whether this should be referred to
the enforcement process.
Q And what was your view on that?
A My personal -MR. KOWALSKI: Asked and answered. Go
ahead.
Q Can you answer it again?
A Yeah. I did not think it should be
referred to the enforcement process personally.
Q Why not?
A I think that may have required a more
lengthy investigation on the part of the NCAA,
of which I was less than clear of what the
outcome would be and whether that was, in my
opinion, appropriate use of resources. That's a
personal opinion.
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Q So because of the length, the potential
length of the investigation, you didn't believe
it should be sent to the enforcement process?
A My opinion doesn't matter.
Q It does matter. And I'm asking you for
your opinion.
A I am not the staff person that
commissions investigations.
Q Did you -- several times throughout the
deposition today, you stated that President
Emmert values your opinion. Isn't this
something the president would have valued your
opinion on?
THE WITNESS: You'd have to ask Mark on
that.
Q I'm asking you.
A I don't know. I don't know whether he
would have valued my opinion on -- on that
specific question.
Q If he didn't value your opinion, you
wouldn't have even been included in this. Is
that not right?

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speculation.
THE WITNESS: I was included in this for
lots of issues beyond the singular issue that
you just mentioned, which is whether the
enforcement process should be engaged in. I
was -- I provided counsel on lots of
components.
Q So then if he didn't value your opinion
on this issue, what exactly did he value your
opinion on?
speculation.
THE WITNESS: An overall review of what
the NCAA should do, what issues need to be
considered, general counsel. Probably better
asking President Emmert that.
Q Did others within the NCAA meetings that
you were having on this issues raise concerns
about this jurisdictional issue?
A Yes.
Q Did David Berst?
MR. KOWALSKI: Please don't reveal the
content of privileged discussions with counsel.
THE WITNESS: Yes.
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what was David Berst's view?
MR. KOWALSKI: Have you ever heard David
Berst's view outside of the context of
communications with legal counsel?
THE WITNESS: No.
MR. KOWALSKI: You'll have your chance.
Someone else.
BY MR. SEIBERLING:
Q The sentence continues, "We really don't
have a great answer to that one." What did you
mean by that statement?
A That there may be some in the membership
who are not sure that the enforcement process is
the appropriate place to handle this type of
issue.
Q So you're conceding that you really
don't have a great, quote, answer to that one on
the jurisdictional issue?
MR. KOWALSKI: Objection. That
mischaracterizes the document.
THE WITNESS: I -- I personally believe we
did -- we do have an answer. I'd not
characterize it as a great one. And I think
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it's absolutely a legitimate answer that it go
through the enforcement process. Is that a
great answer? I don't know. Is that a
reasonable approach? If the institution had
elected to do it, would we have done it?
Probably would have. But that would be a
question for Julie to answer.
Q So you -- I know I may be asking this
again. You did not believe that it should have
gone through the enforcement process?
A Me personally?
Q Yes.
A No.
Q Who disagreed with you?
MR. KOWALSKI: Obviously, you can't reveal
privileged conversations here either.
THE WITNESS: At the end of the day, I
don't think anyone disagreed.
Q At this time, July 15th, 2012.
A I don't know.
Q Was this the runaway train that was
going that you referenced earlier in the e-mail?
THE WITNESS: As I previously stated, the
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runaway train addressed the -- a number of
issues and challenges that we had upon
receiving the Freeh Report, of which there are
five of them outlined in the e-mail itself,
that reflect all of the issues that I wanted to
make sure that we were giving due diligence to.
Q Did President Emmert agree that it
should not go to the enforcement process?
MR. KOWALSKI: Are you able to answer that
question? I mean, have you heard President
Emmert's view outside the context of a
privileged legal communication?
THE WITNESS: I don't know, but it likely
would have been in the privileged setting.
Q Did you -- did you agree with the
sanctions that were ultimately imposed against
Penn State?
A Did I agree with the terms of the
consent decree?
Q The sanctions imposed by the consent
decree.
THE WITNESS: Did I agree with the
sanctions? I agree that those sanctions as

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determined by the executive committee and the
board were appropriate.
BY MR. SEIBERLING:
Q At this point in time, July 15th, 2012,
when you were sending that e-mail, was the
suspension of play, i.e., the death penalty, on
the table?
MR. KOWALSKI: And to the extent you can
-- you know that outside the context of a
privileged communication.
THE WITNESS: I don't -- I just don't know
specifically by this date.
Q When were -- was it put on the table at
some point, the death penalty?
A Yes.
Q By whom?
MR. KOWALSKI: Just be careful not to -think about whether you can answer these
questions without revealing privileged
communications with Mr. Remy.
in what context was the death penalty put on the
table?
A It would have been a part of the group
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meetings that we had of which Donald and Mark
and some of the key members were -- were in
attendance. Would have been in that setting.
Q Did you believe the death penalty would
have been an appropriate sanction?
A I did not believe that that would have
been an appropriate sanction.
Q Why not?
A In my opinion, that would have been a
bit draconian, but I also can absolutely see why
the executive committee and others might think
it's appropriate, given the findings in the
report.
Q Did you feel that way because of your
past experience with SMU?
A I am aware that the so-called death
penalty or discontinuation of a sport program
will have a profound and significant impact on
not just the program, but the institution. I
also personally believe that, having read the
report, the penalties that should come to Penn
State should be profound and should have lasting
impact, given what I saw in the findings.
But I did not reach the conclusion that
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the death penalty in this instance would be the
appropriate action. And so I just brought to
bear my collective experiences to that decision.
Q If Penn State had asked that the
enforcement process be put into motion, would it
have been done?
MR. KOWALSKI: Again, please don't reveal
the contents of privileged communications with
NCAA legal counsel. And speculation.
THE WITNESS: Yeah, that -- that would be
a question that would best rest with our vice
president for enforcement.
Q I'm asking your thoughts. You were
involved in these meetings. You were privy to a
lot of this information. Do you believe it
would have been put into -- do you believe the
matter could have been or would have been
referred to the enforcement process if Penn
State had asked?
A My personal opinion, I can speculate
that had Penn State asked for that approach that
it would have been -- it would have gone through
the enforcement process.
Q Why wasn't it just automatically
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referred to the enforcement process?
MR. KOWALSKI: Again, please don't reveal
the contents of privileged legal communications
with NCAA counsel.
THE WITNESS: Well, this clearly was an
unprecedented situation that emerged.
Q What made it unprecedented?
A Allegations of this nature involving
multiple individuals over multiple years over
multiple victims is unlike anything that I've
seen in 27 years at the NCAA. Involving a
member of an athletic staff, so that in and of
itself was unique.
Q Isn't the crux of the Freeh Report that
there was a football-first culture at Penn State
that allowed this conduct to continue over
multiple years?
Foundation.
THE WITNESS: I'm certainly aware that the
Freeh Report makes reference to the culture of
football and the -- I don't know whether it's
the culture of athletics, but I'm aware that
the report makes reference to that. But I also

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know it provides a level of detail of
malfeasance and criminal behavior that, in my
opinion, seemed to run or should also be
mentioned in terms of what the report
discusses.
Q Wouldn't you agree that there are other
universities across the United States that have
a football-first culture?
THE WITNESS: I believe that there are
programs who place a great deal of importance
on football. I absolutely would agree with
that.
Q Or athletics in general?
A I'll finish. And athletics in general.
I would agree with that. However, I'm not aware
sitting here after almost 30 years in the
business where I've seen that culture produce
the set of allegations and findings that
appeared in the Freeh Report that were agreed
upon by the institution and acknowledged as
factual.
That I have never seen anything close to
it, and I -- and I hope never to in the future.
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Q How about an athletics culture -- this
is a hypothetical -- an athletics culture that
allowed academic fraud to persist over multiple
years involving multiple different athletics?
Hypothetical. And I'm not sure what the -what the question is either.
MR. SEIBERLING: I'm getting there.
MR. KOWALSKI: Sorry. Go ahead.
BY MR. SEIBERLING:
Q A similar situation, obviously not
involving criminality, sexual assault, but I
guess you could make the argument that academic
fraud potentially could have some criminal
aspects to it.
What about a university that allowed
academic fraud to persist for multiple years
involving multiple individuals over multiple
different athletics?
Q Is that analogous? Would that be
analogous to a similar situation at Penn State
in which not necessarily football first, but
athletics first?
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Hypothetical. Speculation.
THE WITNESS: In Penn State, you had a
finding by the institution and an agreement
that these behaviors transpired over multiple
periods of time on that campus. You had the
university agreeing, and agreeing that those
resulted in violations of NCAA rules. The fact
that these were criminal, the fact that they
were sexual in nature, the fact that the report
identified institutional culpability and
individual -- and mentioned individuals in the
report, that particular fact pattern is what
created this as a unique situation that the
NCAA was absolutely entitled to address.
I cannot speculate moving forward until
a set of fact patterns would be presented.
That would cause the association then to
consider how its bylaws were violated, how
the constitution was violated, et cetera. I
just -- I don't have that in front of me, and
so I don't know.
Q So, all of that you just laid out right
now, if that didn't warrant the death penalty,
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what does?
Form.
THE WITNESS: All that I laid out
regarding Penn State and what had happened?
Q Yes.
A I think in some people's mind, they
believe the death penalty was appropriate.
Q But you didn't. Why?
A It's a good question.
Q And I'd like an answer.
A My general sense was that if the
institution could enter into this integrity
agreement, could agree with the sanctions, that
it would have an impact that might be better
achieved than the death penalty, that it would
change the culture in the ways that were
important and appropriate. And I think you
generally try to use the measure that's most
appropriate to achieve the outcome.
And in my opinion, the consent decree
outlined an appropriate set of actions to
achieve the desired outcome better so than the
death penalty.

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Q So that in your mind, if Penn State
agreed to the issues, corrections laid out in
the consent decree, then the -- then the death
penalty should be off the table?
A Your order troubles me a little bit. In
my opinion, the consent decree as agreed upon by
the institution, the NCAA, was an appropriate
means with which to address the issues that were
before the NCAA and before Penn State.
Q But unless Penn State agreed to those
conditions, then the death penalty should be an
option?
MR. KOWALSKI: You're asking his personal
opinion?
Q Personal opinion.
A Not necessarily.
Q What if Penn State said we're not going
to do anything? Should the death penalty still
have been an option?
MR. KOWALSKI: Objection. Hypothetical.
THE WITNESS: Yeah, I don't know. I don't
-- I don't know, really -- I don't know how to
answer that.
Q But you explained that because Penn
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State was going to agree to these changes going
forward, the death penalty, the suspension of
play for an indefinite period of time, should
not be an option? Is that not a correct
statement of your view?
A State that one more time, please.
Q If Penn State agrees to these changes
moving forward, then the death penalty should
not be an option as far as the sanction?
THE WITNESS: Yeah. I believe that the
consent decree outlined appropriate actions,
that if taken by the institution, including the
integrity agreement, would have the result that
the NCAA was seeking and was the most
appropriate level. Had they rejected to do
that, I can't really speculate what the next
option would have been.
Q Was it presented as, you take -- you
sign this consent decree or else you are going
to get the death penalty?
MR. KOWALSKI: Objection. To the extent
-- if your only knowledge about what was
communicated to Penn State is through legal
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communications with NCAA legal counsel, then we
have to assert the privilege over that.
THE WITNESS: I do not believe that to be
the case.
BY MR. SEIBERLING:
Q At this time on July 15th, 2012, do you
know who the -- the head or the chair of the
committee on infractions was?
A I believe it was Britton Banowsky.
Q Was it not John Nichols?
A It could have been. And I don't know.
Q John Nichols is a professor at Penn
State. Are you aware of that?
A I think now I am.
Q At the time, was that -- was that any
reasoning as to why it was not referred to the
enforcement process?
contents of any privileged communications with
legal counsel.
THE WITNESS: Quite candidly, I don't -- I
didn't even know until you mentioned that John
Nichols was on the committee on infractions. I
don't even know that to be the case.
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Q So you weren't involved in any
conversations -- you weren't included in any
conversations about a Penn State professor being
on the committee of infractions?
A Yeah, I don't recall any of that.
Q Why not initiate the enforcement
process, and then if there's an agreement
reached, enter the agreement in the enforcement
process? Was that contemplated?
MR. KOWALSKI: Objection. Please don't
THE WITNESS: In November of 2011 or -Q At any point.
A Given the unprecedented nature of what
came to the NCAA in November of 2011, a decision
was made to send a letter to the institution to
collect additional information.
That was agreed upon at the time as the
appropriate action. At any point in time, Penn
State, in my opinion, could have asked for an
investigation. They clearly could have done so
subsequent to the Freeh Report.
My particular belief is they could have

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asked for that at any point in time.
Q And again, I asked, if they had asked
would it have been granted?
A As I said, that's not my particular
area. That would be the decision that was made
by Julie Roe.
Q Based on your knowledge.
A As I said, if -- if -- my personal
opinion is that likely we would have done what
the institution would have asked. But again,
that decision would rest with -- with Julie Roe.
Q Is it not true this is the only -- the
only matter of record in which the enforcement
process wasn't followed or implemented that
resulted in sanctions?
THE WITNESS: Yeah, I don't know for sure.
Q Are settlements not reached normally
within the enforcement process?
THE WITNESS: The NCAA's reached
settlements or other issues outside the
enforcement process before.
Q They've entered consent decrees similar
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to what they entered with Penn State?
THE WITNESS: Yes.
Q That waives the right to appeal?
A We entered a consent decree with the
Justice Department. So we have entered consent
decrees.
Q With a government agency?
A Yes.
Q Not -- I'm talking member institutions.
A Would you repeat your question then,
please?
Q Are you aware of member institutions
being subjected to sanctions by consent decree?
THE WITNESS: I'm not aware of those or
any related to a consent decree.
Q Since Penn State, are you aware of any
sanctions being imposed by a consent decree?
THE WITNESS: I'm aware of committees who
have sanctioned institution and coaches for
behaviors related to championships that were
not subject to the infractions process, but
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that's the general context in terms of being
specific to your question.
Q Let's move on to number 2.
Quote, "Whatever action we take against
PSU will require us to answer the immediate
follow-up questions as to what this means for
the next case. Scope and reach of ethical
dilemmas that will take many forms."
A I was simply raising the question for
Julie's review as to what happens if should
something, God forbid, like this happen, you
know, a month later, a week, you know, two
months later, something like that.
Q Has it? Has anything similar happened
since?
A Not that I would put at this level.
Q What did you mean by, quote, ethical
dilemmas?
A I think I -- I would -- I used that
term I think purposefully to kind of cast a
pretty wide net over what may -- what could be
kind of falling into an ethical umbrella related
to unethical behaviors, those that may be relate
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within, squarely within NCAA rules or those that
maybe don't relate to NCAA rules. It was
purposefully kind of casting a wide net.
Q Was your concern here not that you were
attempting to regulate ethics as opposed to
athletics?
THE WITNESS: I don't know if it was as
much a concern, but what I was really seeking
were kind of the guidelines moving forward that
would say the NCAA -- that this is an
appropriate matter for the NCAA.
Q The NCAA, you're the National Collegiate
Athletic Association, so by definition, aren't
you regulating athletics?
THE WITNESS: You know, the NCAA regulates
the areas that our membership agrees to be
regulated in and on.
Q Has the membership agreed to be
regulated on morals or morality?
THE WITNESS: I think our membership is
grounded by the bylaws that they adopt. And

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there are certainly instances when ethical or
unethical behavior relate directly or
indirectly to the NCAA bylaws. And I think
there's a belief that those are subject to the
purview of the NCAA.
Q Would you agree that the majority of the
Freeh Report concerns ethical or moral issues
and not athletics?
MR. KOWALSKI: Objection. Form. And he
doesn't have the Freeh Report in front of him
right now.
THE WITNESS: Yeah, I'm not able to answer
that question.
Q If I pulled out a copy of the Freeh
Report, would you?
A Your question's fairly -- fairly broad
and I'm not sure I'm drawing the distinctions
between the two alternatives.
Q The Freeh Report -- did the Freeh Report
address anything to do with athletics -athletic competition, athletic violations
related to student athletes, the general
athletic issues that arise in the NCAA context?
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THE WITNESS: My overall view is the Freeh
Report dealt much more with the unethical
behaviors and conduct of individuals and then
spoke to the culture and the lack of control
within the athletics department, which
particularly the latter, I would consider
athletic matters.
Q And you mentioned just in your statement
unethical behavior. Where do you draw the line
on ethical behavior? Who draws the line?
Speculation. Hypothetical.
THE WITNESS: Where do I draw the line on
ethical behavior? That's the question?
Q Yes.
A In what -- what context?
Q Obviously you said the Freeh Report.
And I can go back and actually look, but I
believe the context was it outlined unethical
behavior by individuals within Penn State. Who
decides what's ethical or unethical?
THE WITNESS: Who decides what is ethical
behavior within the context of the NCAA?
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Within the context of the report? I'm trying
to understand your -Q Yes.
A -- question. Well, ultimately as a
membership organization that provides its
individual members appellate opportunities to
membership bodies every way along the way, at
every juncture, ultimately it is the membership
who will decide whether behaviors have violated
the NCAA bylaws.
So ultimately, it is a group of peers
that would make a judgment as to whether the
behaviors have violated the NCAA bylaws.
Q Isn't that a slippery slope?
Speculation.
THE WITNESS: It's challenging. And in
this instance, pretty easy.
Q Let's move on to number 3. Quote,
"Delicate issue, but how did PSU gain a
competitive advantage by what happened?" Quote,
"Even if discovered, reported, and actions taken
immediately by the administration, not sure how
this would have changed anything from a
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competitive advantage perspective."
Can you explain the context of that?
A There were conversations that were
occurring -MR. KOWALSKI: Be careful not to reveal
the contents of privileged conversations with
NCAA legal counsel.
THE WITNESS: Thank you.
There were conversations occurring
within the group, the internal group as to -MR. KOWALSKI: Can you answer the question
without discussing the communications within
the internal group?
MR. SEIBERLING: In your view.
MR. KOWALSKI: Yeah, just explain your
view.
Q In your view, what was the competitive
advantage gained by Penn State?
A I personally had a hard time finding a
competitive advantage that was gained. There
were some who believed that had the violations
been and the allegations been duly discovered at
the time and revealed publicly and -- and had
the daylight on them, that at a much earlier

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point in time, Penn State's reputation and other
issues would have emerged that may have resulted
in less competitive teams at the time. That was
an opinion held by some.
Q Did you agree with that opinion?
A At the time I did not.
Q Why not?
A I thought it was still very likely that
Penn State would field a competitive team.
Q Even after sanctions were imposed? I
don't understand that statement.
A That had the transgressions been
identified earlier, I still think they would
have fielded competitive teams, even during
those earlier years.
Q Why was there even a discussion about a
competitive advantage?
MR. KOWALSKI: And please don't reveal the
contents of any privileged communications of
NCAA legal counsel.
Q Why did you need to -- why did you need
to establish a competitive advantage?
MR. KOWALSKI: Same objection. If you can
answer it, go ahead, but be careful.
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THE WITNESS: I don't know whether anyone
thought you needed to establish it to issue any
type of sanctions, but there were clearly some
who believed that a competitive advantage was
gained by the lack of reporting and the lack of
due diligence in the late '90s and early 2000s.
So it was a topic of conversation.
Q Do the bylaws require the establishment
of a competitive advantage in order to impose
sanctions?
A Again, you're overlaying an enforcement
process in bylaws in something that the
institution had not elected to engage in and was
not a part of the conversation.
Q Is that your understanding of the bylaws
though, that a competitive advantage is required
for the imposition of sanctions?
THE WITNESS: Yeah, that's not my
understanding.
Q So again, why the discussion of a
A I believe some people in the room
thought it was appropriate to talk about it in
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the entire context of what had happened at Penn
State.
Q Why did you refer to it as a, quote,
delicate issue?
A I didn't want folks to think I was kind
of insensitive to the fact that a competitive
advantage might have been gained and that people
may have said, even with these allegations and
this coach, I'm still willing to go to Penn
State. And I didn't want that to seem callous.
Q Number 4, quote, "As for idea to bring
in Judge Freeh, I thought the key response from
our end is to wait to hear from PSU."
Explain the context of that statement.
MR. KOWALSKI: Same admonition. Please
don't reveal the contents of privileged
communications of NCAA legal counsel. But, you
know, if you can answer what you meant by that
without revealing that information, go ahead.
THE WITNESS: Okay. We had sent a
November 17th letter, and at the time of the
e-mail, I indicated that I thought we were
waiting to hear back from the university as to
what their response back was to the letter.
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Q You had said earlier that the Freeh
Report responded to those four questions set
forth in that letter. Now you're saying that
that wasn't the case as of July 15th?
THE WITNESS: I do know that Penn State
ultimately submitted the Freeh Report and
said -- it is my understanding that they
submitted the report and said, this is our
response back to the letter. I don't know
whether I knew that on July 15th.
Q This was three days after the Freeh
Report?
A Yeah. I don't know. I don't know.
Q What does the quote, "to bring in Judge
Freeh" mean?
A I don't know.
Q Were you planning to have Judge Freeh
come talk to NCAA?
A No. I don't believe that was the intent
of that at all.
Q Were you going to bring in Judge Freeh
to do an investigation for NCAA?
A I do not believe that that's what I

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intended by that. I don't recall any
conversations from -- of anybody bringing in
Judge Freeh in that regard.
Q Okay. And the next sentence, "I feel
like to do otherwise with any action like this
will invite what else the NCAA is doing now".
Can you explain that statement?
A I really cannot.
Q Next sentence. "Like, are you sending
enforcement representatives in now and, if not,
why not?"
Were you expecting Julie Roe and the
enforcement team to send out representatives to
begin investigating?
A I don't believe that's what I intended
or that was my understanding. I'm really having
a hard time figuring out what I meant in number
4, quite frankly.
Q Your statement says, "Like, are you
sending enforcement representatives in now and
if not, why not?" Did Julie Roe respond to that
question?
A I don't recall, but I -- but I do sense
that that's -- if I couple that with the
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sentence before, that I'm not -- I'm just posing
a hypothetical. I wouldn't have started
something like "like." So that's not a
knowledge-based statement. That's just a, "like
this."
Q Did you believe that enforcement
representatives should have been sent in then?
A No.
Q Why didn't the NCAA do its own
investigation?
THE WITNESS: Well, as I previously
stated, the unprecedented information that
became available to the NCAA produced a
November 17th letter to seek additional
information. That was the agreed-upon
approach.
My personal belief is that Penn State at
any point in time could have asked for an
investigation. They commissioned the Freeh
Report. So...
Q But you weren't -- the NCAA, you, were
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not bound to accept the Freeh Report as true,
were you?
A We were most interested in Penn State's
reaction to the Freeh Report and how they
accepted it. But it is safe to say that
additional actions by the NCAA could have been
taken.
Q Why weren't they?
MR. KOWALSKI: Same objection. Please
don't reveal the contents of any privileged
communications with legal counsel.
THE WITNESS: Because our member
institution, Penn State in this instance,
accepted and agreed to enter into a consent
decree as a matter to resolve the situation.
And that was important.
Q But you weren't -- you, the NCAA, were
not bound to accept it?
answered.
Q He didn't actually answer the question.
A A consent decree -- a consent decree by
its very nature is consenting between both
parties.
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Q At this point, there was no consent
decree, as of July 15th.
A What is your question?
Q When the Freeh Report came out, were
you, the NCAA, bound to accept that Freeh Report
as true?
A As I have responded, first and foremost,
we were interested in what our member
institution, Penn State, thought of the report
and whether they accepted the report. Did -did the NCAA have an opportunity, then, to not
accept the entire Freeh Report? Yes.
Q But the NCAA did accept the Freeh Report
as true?
THE WITNESS: We accepted the fact that
the university put forward that the Freeh
Report represented their answers back to the
specific questions that the NCAA had posed.
That's what we accepted. And then they
willingly entered into the consent decree
and...
Q Have you reviewed any of the reports
done since the Freeh Report criticizing it?

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THE WITNESS: Articles through popular
media.
Q What's your view of those criticisms?
THE WITNESS: I generally am cautious to
third-party reviews by individuals who are not
present and who did not fully participate. I
generally give credence to the individuals who
were right in it. So it's safe to say I took
it with a grain of salt and continue to.
Q Were there any considerations either by
you or anyone within the NCAA to revisit the
Freeh Report?
communications with legal counsel. But you can
answer otherwise.
THE WITNESS: Not that I'm aware of.
Q Did you personally believe that the
Freeh Report should be revisited?
A No.
Q Move on to number 5. Quote, "I feel we
have not spent enough time on membership input,
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counsel reaction, direction and spending more
time on media input."
Can you explain that statement? Again,
without revealing privileged communications.
A I always want to make sure that we have
a pretty good read on our membership and
particularly at the highest levels in our
organization as to actions the NCAA is going to
take. And this expressed a little concern about
how wide a net we'd cast in getting that kind of
feedback.
Q So your concern was at this time you
weren't keeping the membership informed?
THE WITNESS: I don't know if it was
informed as much as making sure in particular
the critical bodies are comfortable with
whatever might be suggested.
Q At this point, had there been any
meetings with either the executive committee or
the Division I Board of Directors about how to
proceed with Penn State?
A I don't know.
Q The second piece of this sentence,
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quote, "spending more time on media input."
What do you mean by that?
A I seem to recall at that point in time
there were lots of people in the media who had
opinions as to what the NCAA should do or
shouldn't do and that you clearly heard more
from the media on appropriate actions than I was
suggesting that we'd actually heard from our
membership.
Q Internally, you were spending more time
discussing the media's view on it as opposed to
informing the membership on what was going on;
is that correct?
A I knew that what was being talked about,
at least there was some conversation about how
it was being portrayed as to what the NCAA
should do and shouldn't do as just kind of items
of information.
Q So there was concerns about outside
influences?
THE WITNESS: No. It's just making sure
that we get a balanced sense of input and
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beyond just a writer, that it's important that
you get feedback from your membership.
Q Was there concerns about public
pressure?
THE WITNESS: I wouldn't characterize it
as concern about public pressure, but you have
lots of people in the media talking about on
all sides of the issues, so I don't know where
the -- the pressure -- you had some who felt
actions should be taken, others who felt that
it shouldn't be taken within the media. So I
don't know where the pressure lied.
Q Second sentence, quote, "I understand
not everyone in our membership will agree with
any direction we take, but coming off our last
round of problems, best to eliminate at least
one complaint. And that is that national office
was not in touch with membership."
What do you mean by "our last round of
problems"?
A Well, you had a presidential retreat
scheduled a year before to address the health of
the collegiate model. Those ran to issues of

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the rules, enforcement, financial situations,
student well being. So there were a lot of
challenges at the time. I don't know if I can
tell you exactly what the last round of
problems, but gosh, you had to have a whole
presidential retreat to deal with the collegiate
model. So that tells you that there's
challenges and issues.
Q Were there concerns that the NCAA was
losing its power?
THE WITNESS: I've very rarely heard that
in our membership. But I do know there's some
pundits who believe that to be the case.
Q Did you believe that to be the case?
THE WITNESS: That the NCAA was losing
power?
Q Yes. Particularly over the bigger
conferences, the power conferences.
A I never have and I don't subscribe to
that as losing power. Sharing responsibility,
and shared governance, I absolutely agree with
that and support that. But some may view that
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as a loss of power, but I certainly don't.
Q Were there concerns that some member
schools would just leave the NCAA?
MR. KOWALSKI: Objection. Concerns in
what context? Just generally?
MR. KOWALSKI: And what time period?
MR. SEIBERLING: During this time period.
THE WITNESS: As conference realignment
was taking place, there may have been a bit of
an uptick in conversations among the media
about that possibility. But I've heard for the
last 15 years, if not longer, about models that
have people leaving the NCAA.
So I will admit that that -Q Did you personally -A -- wasn't a huge worry.
Q Did you personally believe that was a
legitimate concern?
A No.
Q What about this statement that national
office was not in touch with membership? Was
that a complaint that had been raised
previously?
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A Yes.
Q By whom?
A Some in the membership.
Q In what context?
A I'd say in nearly all matters dealing
with the membership.
Q The members are complaining that you're
not in touch with the membership?
A It's a very diverse membership. As you
go through major changes related to the rules,
to enforcement procedures, to student athlete
well-being issues, there's a great diversity of
opinion. And we're asked to lead and to serve.
And it's a complex and challenging organization
to lead and serve.
Q Was your advice in this bullet point
number 5 followed as far as actively trying to
get the membership informed and involved?
A On this issue?
Q Yes.
A I know that the executive committee and
the Division I Board were then actively engaged
in the decision making. That would have been,
for this type of issue, the input and the
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counsel that would be most appropriate. And I
do know the effort was made then to engage them
because they're the decision makers.
Q Were you -- strike that.
Were they involved at this point that
you're aware of?
A I don't know.
Q This e-mail in its entirety, does this
involve discussions that you had with counsel?
MR. KOWALSKI: Well, I'm going to object.
I mean, you're asking if he discussed all of
this substance with legal counsel? Because
that would obviously reveal the content of his
discussions with legal counsel.
MR. SEIBERLING: The reason why I'm
raising this, if he -- if this is what he
discussed with counsel, and you produced this
to us and we just talked about it for the last
two hours, then that's a waiver.
MR. KOWALSKI: That may be your position,
but we're not going to let him say that he
discussed all this with legal counsel, because
what may be privileged in one context is not
privileged in all contexts. And if he

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discussed this content with legal counsel, it's
privileged.
BY MR. SEIBERLING:
Q But what created this e-mail -- maybe I
should take a step back.
I believe there was a meeting that
preceded this e-mail; is that correct?
A Yes. It's reasonable to assume that
there was a meeting prior to this e-mail.
Q Involving Donald Remy?
A Well, as we've noted, there were a
series of meetings between the receipt of the
Freeh Report and July 15th.
Q So this e-mail followed a meeting, an
internal meeting at NCAA?
A That's a reasonable assumption.
Q And what is laid out in this e-mail were
matters that were discussed during that prior
meeting?
MR. KOWALSKI: Objection. Foundation -objection to form. I think it mischaracterizes
prior testimony.
Q You can still answer the question. It's
a yes-or-no question.
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MR. KOWALSKI: You said are these things
that were also discussed with legal counsel?
MR. SEIBERLING: I'm saying there was a
meeting that preceded this e-mail for which
Mr. Lennon felt he needed to follow up with
Julie Roe about.
And I'm asking these -- this substance
of this e-mail, were these matters that were
discussed in your prior meeting, that was -and that included others besides Julie Roe?
MR. KOWALSKI: You could ask him whether
the topics like, you know, the -- were
penalties discussed? Was the topic of -Q All five, the five bullet points laid
out here, were those, were the substance of
those five bullet points discussed in the
meeting that preceded this e-mail?
MR. KOWALSKI: I think that's privileged.
Well, if the answer is yes, then that's
privileged, because he's revealing exactly the
contents of -- you know, it's one thing to say
he had this discussion with a nonlawyer. It's
another to say, did you discuss these exact
things with your lawyer.
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MR. SEIBERLING: But if he had that
discussion with the lawyer and then went back
to his computer and typed up all five
discussion points he had with his lawyer and
then forwarded it along to another NCAA
employee, and then you produced that document
to us, that's a waiver of privilege.
MR. KOWALSKI: That's your view. But if
exactly this is what was said -- I guess the
point is if this is something different than
exactly what was told to legal counsel, he can
answer that question, I guess, but...
Q Can you answer the simple question: Did
this e-mail precede prior meeting -- internal
meetings with other NCAA employees? Was this
preceded by?
A A meeting had occurred -- one or more, I
don't know -- prior to my sending this e-mail to
Julie. I do not believe that all of the points
that I raised, 1 through 5, were talked about in
that meeting.
Q Were some of them?
MR. KOWALSKI: Again, I think you can
answer whether the general subject matter, to
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sum it up at a high level, was something that
was discussed, but you can't say all of this is
what I discussed with legal counsel.
MR. SEIBERLING: You're using the half
pregnant approach to waiver. You're saying -or it's a privilege. You're saying some of
this is privileged, some of it isn't. It's
either all privileged or it's not.
MR. KOWALSKI: No. What I'm just saying
is when you -- when two nonlawyers are talking
about something, they're not -- when two
lawyers are talking about, they're not seeking
legal advice or receiving legal advice. But
when he's talking to his lawyer about
something, that's a privileged communication.
MR. SEIBERLING: But the numerous
questions I asked about this at times, multiple
times throughout, you were saying he can't -he can't elaborate on that because it's
privileged.
MR. KOWALSKI: Well, you asked for
context, Mark. So if you wanted context, and
he says, well, to provide you context, I need
to tell you what I said with my legal counsel,

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that's not the context that you can get. You
can get the nonprivileged thoughts and
impressions of his nonlawyer. You can get his
nonprivileged communications with other
nonlawyers. What you can't get are his
privileged communications with his lawyer.
MR. SEIBERLING: Let's take a break. Go
off record.
MR. KOWALSKI: In the interest of time,
instead of me stating each time that he can -we object and he can answer to the extent his
answer does not reveal the contents of
privileged communications with legal counsel,
I'm just going to say "objection privileged",
and everyone will recognize that that's what I
mean when I'm saying that.
MR. SEIBERLING: Can we also state on the
record that I had asked the question that we
had left with on this July 15, 2012, e-mail, I
asked the question whether this e-mail was the
result of conversations within -- with people
within the NCAA including and/or Donald Remy,
and you directed him not to answer?
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MR. KOWALSKI: We can look at the record.
I thought what you asked was: Did he discuss
these exact, Number 1 through 5, with legal
counsel.
MR. SEIBERLING: I will restate the
question.
BY MR. SEIBERLING:
Q Mr. Lennon, with regard to this e-mail,
this July 15, 2012 e-mail, was this whole or in
part the result of conversations you had with
individuals within the NCAA?
MR. KOWALSKI: I think you can answer that
question. Although I object to form and
clarity.
But I think -- if you can answer that,
you can answer it.
THE WITNESS: I recall that some of the
these areas would have been discussed with the
smaller group within the NCAA.
Q I think this is the issue where we got
stuck on. Does that include counsel Donald
Remy? Let me restate the question.
Was all or part of this e-mail the
result of conversations you had with counsel
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Donald Remy?
MR. KOWALSKI: I'm not sure -- at least
for me to evaluate whether that's eliciting
privileged information, I don't know that I
understand what that means. I mean, "result,"
are you saying, like, are these his ideas? Are
they legal counsel's -BY MR. SEIBERLING:
Q What I am asking is: Was there a
conversation with you and -- involving Donald
Remy prior to this e-mail after which you went
to your computer and you typed up this e-mail to
Julie Roe? Did this e-mail follow a
conversation that you had with Donald Remy?
A This e-mail captured general thoughts
that I had from my perspective of conversations
that went on with our internal group. But I do
not recall that all of these items were
discussed in the internal group or were sources
of conversation. And I certainly did not come
back and type these as verbatim notes from the
meeting.
Q But some of these issues involved
discussions with counsel Donald Remy?
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MR. KOWALSKI: The subject matter -- the
topics, broadly, outlined here, 1 through 5,
were any of those topics also discussed with
Donald Remy? Is that...
MR. SEIBERLING: In the meeting that
preceded this e-mail.
MR. KOWALSKI: If you even know.
Hold on a second. Among other things, I
think we have to object about the
characterization of whether there was a
meeting with Donald Remy right before this
e-mail.
BY MR. SEIBERLING:
Q Was there a meeting -- were you involved
in a meeting with Donald Remy prior to drafting
this e-mail?
A I was involved in meetings with an
internal group, of which Donald Remy was likely
a member of that group.
These are my reflections on lots of
topics, some of which I don't recall being
discussed in meetings in that internal group.
And they certainly aren't verbatim topics that
came out of the meeting. They're my thoughts,

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and I am asking Julie for her impressions.
Q We will move on.
Flip to Tab 16.
MR. KOWALSKI: Did we mark that, by the
way?
MR. SEIBERLING: Sorry. Tab 15 is marked
Exhibit 7.
BY MR. SEIBERLING:
Q For some reason, this e-mail is -- Julie
Roe's response is dated July 14th. And this is
a document produced by the NCAA.
Do you have any explanation for why the
response is dated the 14th and the initial
e-mail is dated the 15th?
MR. KOWALSKI: If you have any reason to
know why, you can answer the question. He is
asking: Do you know why that would be the
case?
Q If you look at the -- on this e-mail
chain, your e-mail is actually dated July 14th
at 10:02.
A I do not know how.
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Q Do you remember Julie Roe responding to
your e-mail?
A I do.
Q Any idea why a portion was redacted out?
A No.
Q Would that portion have been redacted
out because it involved communications or a
reference to counsel Donald Remy?
I will stipulate that Mr. Lennon did not
perform the redactions, so I don't think he
knows the answer.
Q We will just walk our way through this
one again.
Quote, "I keep going back to the three
questions I raised Friday before the call to try
to frame the issue."
What were the three questions that were
raised Friday?
A I don't know.
Q And this response references a call. Do
you remember what that call was?
A I do not.
Q Was your e-mail that precedes this on
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the chain, was that drafted in response or as a
result of that call that happened on Friday?
A I don't know.
Q Quote, "Regarding your third point, I
think Mark believes, based on conversations with
some presidents, that PSU did gain an advantage,
although Berst, Wally, and I disagree with that
point. The point some have made is that PSU
dealt with this in 2001, they might have
suffered a recruiting disadvantage due to the
bad publicity at that point. Given that they
have a decent recruiting class now, not sure
this holds up."
You said earlier you also disagreed with
the competitive advantage point?
A Yes. At this point in time, I had a -I had a different view, yes.
Q It sounds like Julie Roe also disagreed
with the competitive advantage point.
A That is what it sounds like.
Q Did she state that to you?
A Other than her e-mail?
Q Yes.
A I don't know.
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Q Quote, "I characterized our approach to
PSU as a bluff when talking to Mark yesterday
afternoon after the call."
What does Julie Roe mean by, quote,
"bluff"?
THE WITNESS: You would have to ask Julie.
Q Did you ask Julie what she meant by the
term "bluff"?
A I don't recall.
Q Did she talk to you about her talk with
Mark, quote, "yesterday afternoon after the
call"?
A I don't recall.
Q Did Julie Roe inform you of any
conversations she had with Mark Emmert?
A I recall her maybe making a reference to
a conversation she had with Mark, but quite
candidly, I can't recall what the substance of
that was.
Q Quote, "He basically agreed because I
think he understands that if we make this an
enforcement issue, we may win the immediate
battle but lose the war when the committee on

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infractions has to rule."
Did Julie Roe share these concerns with
you?
MR. KOWALSKI: You mean other than in this
e-mail?
MR. SEIBERLING: Other than in the e-mail.
MR. KOWALSKI: Objection. Privilege.
Go ahead.
THE WITNESS: I believe she shared with me
that she wasn't sure exactly how the committee
on infractions might react or rule.
MR. SEIBERLING: Why?
THE WITNESS: Well, quite frankly, that is
just a standing concern that enforcement has
any time they bring allegations to the
committee on infractions. It is an independent
body and -Q It could accept or reject the
investigation?
A Parts of the investigation, the
findings; it's what the committee on infractions
does.
Q So Julie Roe raised to you concerns
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about having this run through the enforcement
process, is that true?
THE WITNESS: I believe we just discussed
in general the general challenges with that
approach.
BY MR. SEIBERLING:
Q What were those challenges?
A That you don't exactly know how the
committee on infractions might end up. That is
the one that particularly comes to mind.
Q So it's unpredictable?
A Quite candidly, as the committee tends
to be.
Q So was there a concern to make it more
predictable?
THE WITNESS: I think at this point there
was a general understanding that the horrific
nature of the findings of the Freeh Report
required a response from the NCAA.
Q An immediate response?
A A timely response.
Q And the enforcement process would have
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been a longer time period of a response?
A To conduct an investigation obviously
would have taken additional time.
Q Move on to the next paragraph.
Quote, "I need to think about point
number 4 some more. I think we are waiting on
PSU to respond. You are right, but I don't know
that it precludes us from gathering info on our
own to adequately assess the response."
Did Julie Roe communicate to you the
potential use of the enforcement process?
MR. KOWALSKI: Other than the e-mail.
Objection. Privilege.
THE WITNESS: No, other than just general
terms about the challenges of engaging in the
enforcement process.
BY MR. SEIBERLING:
Q Did she discuss with you, quote, "us
gathering info on our own"?
A I don't recall.
Q Next paragraphs, quote, "Point number 5
is a good one. Seems like the conferences and
ADs are not part of this discussion, as well as
the majority of the presidents. I think the
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presidents are feeling public pressure and
allowing that to raise the liability question,
which is not one of my big three. I am hopeful
the call with the larger group next week will
give a broader perspective."
Again, any idea what one of her -- what
her big three were?
THE WITNESS: Yeah. I am not recalling
those.
BY MR. SEIBERLING:
Q It seems like she agreed with your
assessment that the presidents need to be better
informed, is that correct?
A I think what she's agreeing to is that
the -- they need to be a part of the discussion.
Q At this point they were not being part
of the discussion?
A I don't know for sure.
Q Should they have been part of the
discussion at this point?
A July 14th, it would have been reasonable
to assume that the presidential leadership
within the two key bodies would have been made

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aware of the conversations. That strikes me as
being appropriate.
Beyond that, in terms of membership
input, would raise additional challenges.
Q Why were they not part of the discussion
at this point?
A As I said, I don't know who was a part
of the discussion at this point.
Q Whose decision would that have been to
include them in the discussion?
A Probably President Emmert's.
Q Did you raise your concerns on this
issue with President Emmert?
A I don't recall.
Q Next paragraph, quote, "I would
appreciate talking with you possibly tomorrow
afternoon or early tomorrow morning."
Did you talk with Julie Roe following
this e-mail?
A I don't recall.
Q Next paragraph, quote, "Here's where I
am: I still think there is credibility in
saying, Number 1, we could try to assert
jurisdiction on this issue and may be
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successful, but it would be a stretch."
Did Julie Roe, other than this e-mail,
talk to you about jurisdiction, quote, being a
stretch?
MR. KOWALSKI: Objection. Privileged.
THE WITNESS: We spoke in general terms
about just the basic challenges and having this
run through an enforcement and infractions
process.
BY MR. SEIBERLING:
Q What were those challenges, if you can
summarize?
MR. KOWALSKI: Objection. Privilege.
Communications not involving legal counsel. He
can go ahead if he can remember.
THE WITNESS: I think the biggest concern
related to the committee on infractions and
what it might do with the investigation with
the facts that are coming forward before it.
That strikes me as the primary challenge that
we discussed.
BY MR. SEIBERLING:
Q The next sentence, did she discuss this
with you? Quote, "We can make the control
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argument based on ethical failures by senior
leaders, and I think it's reasonable and
logical, just not sure the committee on
infractions and then IAC would agree."
First of all, what is IAC?
A That is the Infractions Appeals
Committee.
Q And then the substance of that sentence,
did she discuss that with you other than in this
e-mail?
A My recollection is that in the group
settings -MR. KOWALSKI: Again, I caution you not
reveal contents of communications involving
legal counsel.
THE WITNESS: Then I probably need to stop
answering there.
MR. SEIBERLING: Are you directing him not
to answer?
MR. KOWALSKI: So you can't answer that
question without revealing the content of
communications with Mr. Remy, or communications
involving Mr. Remy at the meeting. It's fine
if that is the answer. You have to just --
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THE WITNESS: Mr. Remy would have been
present in those meetings of which we
discussed -MR. SEIBERLING: His presence is one
thing. Was he providing advice on this issue,
is the crux of the matter?
MR. KOWALSKI: I think our position is
that during these meetings, Mr. Remy was
providing legal advice.
Q In all these meetings, was Mr. Remy
vocal in providing legal advice?
MR. KOWALSKI: Our position, Mark, is
Mr. Remy was -- these meetings are occurring in
order to help Mr. Remy advise the association
on its response to Penn State, to advise the
executive committee on its authority with
respect to the Penn State situation.
MR. SEIBERLING: So your position is every
one of these meetings that happened was so that
Donald Remy could provide legal advice to
employees of the NCAA?
MR. KOWALSKI: That -- yes -- the
association was in the process of developing
its legal position with respect to Penn State.

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And Mr. Remy was -- that's the purpose of the
meetings.
MR. SEIBERLING: The sole purpose?
MR. KOWALSKI: The primary purpose, and
then at minimum, legal concerns were infused
throughout the entire discussion once Mr. Remy
was present.
MR. SEIBERLING: So, again, you're
directing him not to answer?
MR. KOWALSKI: Well, I think if what
you're remembering is a discussion that
involved Mr. Remy, and it is in the context of
these meetings, which, as I understand, was the
purpose of which was to develop the
association's legal position, then yes.
THE WITNESS: I believe that is the
context.
BY MR. SEIBERLING:
Q The next sentence reads, quote -- this
is Number 2. Quote, in case -- "In this case,
we reached an agreement with PSU resulting in
significant penalties being imposed along the
corrective actions."
So based on this e-mail, had an
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agreement already been reached with Penn State?
Q Quote, "We reached an agreement with PSU
resulting in significant penalties."
A She's certainly referring to some
agreement being reached with PSU.
Q As of July 14, an agreement had been
reached with Penn State based on this e-mail and
based on your understandings in conversations
with Julie Roe?
MR. KOWALSKI: Objection, speculation.
THE WITNESS: I know I have an e-mail from
Julie indicating that. I don't recall whether
an agreement had been reached on that date.
Q Number 3, quote, "Ideally, in going
forward we need to be able to be a force when a
general lack of integrity exists and there
should be no ambiguity on that point."
Any idea what Julie Roe means by, quote,
"to be able to be a force when a general lack of
integrity exists"?
A I believe she's referring to the NCAA as
an organization, having the ability to address
grievous acts where lack of integrity is
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present.
Q So the NCAA should be regulating
integrity in addition to athletics?
THE WITNESS: I don't distinguish
integrity versus athletics.
Q Integrity in athletics?
A Yes.
Q Integrity outside of athletics?
THE WITNESS: I believe what she is
referring to is general lack of integrity that
exists at the institutional level when there is
an athletics nexus as being appropriate for the
NCAA.
Q So there has to be an athletics nexus
with regard to the institution?
Mischaracterization.
THE WITNESS: I don't think she's
suggesting that the NCAA get involved when
malfeasance relates to the chemistry department
in and of itself, period.
(Clarification by the court reporter.)
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BY MR. SEIBERLING:
Q Number 4, quote, "In terms of our future
positioning, we are appointing a blue ribbon
group to develop the right approach to helping
our members establish standards/expectations so
as to ensure they don't have a cultural failure
and abandonment of integrity.
"We also need a means of accountability
for the association to assert if, God forbid,
some similar situation ever arises again."
Is her discussion of the blue ribbon
group, is that the working group she was
involved in with regard to changes to the
A No. I don't believe so.
Q What is the, quote, "blue ribbon group"
she is discussing?
A I believe there was a recommendation,
one of many within the enforcement working
group, to consider establishing something like a
blue ribbon group. It was one of the
recommendations that came from the enforcement
group. That is my understanding.
Q For what purpose?

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A I don't have the minutes in front of me
specifically, but in general, I think it is what
she has outlined here: To help institutions
with the establishment of standards and
expectations, and then to consider how it should
be handled within the association.
Q You had mentioned this blue ribbon group
was one of the recommended changes from the
working group.
A I believe that in the enforcement
working group recommendations -- and maybe not
recommendations, maybe just report -- is a
reference to the establishment of some body, she
refers to it as a blue ribbon committee, that
would address the issues that we are talking
about.
Q At this time did she raise any of those
concerns you had mentioned earlier about the
working group and the timing of the Freeh Group
report and its impact or effect on the changes
that were going to be proposed with regard to
the enforcement process?
MR. KOWALSKI: I will make my privilege
objection.
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THE WITNESS: I don't recall Julie ever
specifically recommending that anything
different be done with the enforcement working
group report as a result of what emerged from
the Freeh Report.
BY MR. SEIBERLING:
Q You had mentioned there was timing
concerns earlier today with regard to the
implementation of those proposed changes.
A We had discussed the challenges that
existed with the issuing of a national report
from the enforcement working group and
juxtaposition to the Freeh Report.
Q At this time, was she still raising
those concerns with you as of July 14th?
A I don't recall.
Q The next paragraph reads, quote, "To
your point, we want the agreement to be strong,
my Point Number 2, but are going to have to be
flexible in negotiating that with PSU."
Julie Roe uses the term "negotiating
that" with Penn State. What was negotiated with
Penn State?
A You will have to ask Julie what she
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meant by negotiation. But I am not sure it was
meant in the traditional sense.
Q Was the consent decree negotiated?
A Again, not in the traditional sense of a
negotiation.
Q What do you mean by "the traditional
sense"?
A Where it is a constant back-and-forth
and each side reaches a compromise, as is often
the case in negotiation.
Q So there was no back-and-forth between
Penn State and NCAA?
THE WITNESS: I had no contact with Penn
State, so...
Q Then how do you know there was no
back-and-forth?
MR. KOWALSKI: Privilege objection to the
extent that's necessary here.
THE WITNESS: Any communication regarding
Penn State's reaction in the development of the
consent decree would have come through Donald
Remy to me.
Q So you're refusing to answer the
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question?
MR. KOWALSKI: What is the question again?
MR. SEIBERLING: He had mentioned earlier
there was no back-and-forth between the NCAA
and Penn State on the terms of the consent
decree.
MR. KOWALSKI: Right.
MR. SEIBERLING: And I asked how did he
know that.
MR. KOWALSKI: That mischaracterizes his
testimony, I think. Whatever he did say about
the negotiation with Penn State -I mean, the point is: I guess, are
there things other than legal counsel,
whether -- it could be anything, that has,
you know, given you that impression
generally? And don't reveal any specific
THE WITNESS: My recollection at the time
is that Penn State was told what the penalties
were going to be.
The extent to which any discussions
related to specifics of the penalties, timing
of the penalties, those issues that are sub

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issues within the construct of the penalties
would have come from Donald Remy in
conversations. I don't term that as
negotiation.
Q Who came up with the penalties that were
presented?
Please don't reveal the contents of any
privileged legal communications with counsel.
THE WITNESS: The NCAA Division I Board of
Directors and the executive committee, it's my
recollection, ultimately approved.
BY MR. SEIBERLING:
Q Who initially came up with the penalties
before being presented to the executive
committee or the Division I Board of Directors?
A I believe that was the internal staff
group that made a set of recommendations to be
vetted by those individuals on the executive
committee and the board of directors.
Q And those penalties were nonnegotiable?
THE WITNESS: The executive committee and
the Division I Board of Directors were free to
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do whatever they wanted to do.
Q When it was presented to Penn State,
were the penalties presented as negotiable?
THE WITNESS: After the Division I Board
of Directors and the executive committee
approved the action, it is my understanding
that those would not have been negotiable, but
I don't know that for sure.
Q Did Penn State have any input on the
potential penalties?
THE WITNESS: As I have said, I had no
communication with Penn State. The only
information I would have received regarding
Penn State's reaction would have come through
Donald Remy.
MR. SEIBERLING: Let's mark Tab 16 as
Exhibit 8.
BY MR. SEIBERLING:
Q Prior to the agreement on the consent
decree, do you remember having any discussions
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with Ed Ray about the penalties to be imposed
against Penn State?
A I don't recall.
Q You can flip to Tab 17.
Do you remember being forwarded this
e-mail? It's the very bottom. It is a July 13,
2012, it's initially from Ed Ray to Julie Roe,
and Julie Roe forwards it to you.
I will read it. Quote, "So what does it
mean for the NCAA to be the adult in the room
regarding Penn State? Immediate self-imposed
sanctions and NCAA sanctions and a deeper look
over time to fully calibrate the horror seemed
like a good place to start. If you can find it
read the opinion piece by Rick Reilly ESPN.com.
I think he has it right."
Why did Julie Roe forward this e-mail to
you?
Q Did you and Julie Roe have a
conversation about this e-mail?
A I don't recall.
Q Did you and Julie Roe have any
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conversations about Ed Ray's positions with
regard to Penn State?
A Yes.
Q What were those conversations?
MR. KOWALSKI: Was Donald Remy present?
THE WITNESS: I don't know. He may have
been.
Q What about those conversations where
Donald Remy wasn't present?
A I really don't know if what I would
share would be issues of whether he was present
or not.
Q So you're not answering because you
believe Donald Remy may have been present?
MR. KOWALSKI: He can either answer what
his understanding of Julie's position was and
not the specific communication that may have
occurred.
Q Well, what's your understanding of what
Ed Ray's position was, if you know at all?
A I think he outlines it pretty clearly;
that the significant response, given the
horrific nature of what happened, was
appropriate.

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Q Was Ed Ray in favor of the death
penalty?
A At one point in time in the
conversations, I know that Ed felt strongly that
it should be considered, and strongly
considered.
Q Was he the only president you're aware
of that felt that way?
A I don't know.
Q Did any other presidents communicate
with you regarding the sanctions against Penn
State?
A Again, no president communicated with
me.
Q None? Ed Ray did not communicate with
you directly?
A That is correct.
Q Did any other presidents communicate
with Julie Roe?
A I don't know.
Q The only one you're aware of is Ed Ray?
A Yes. Based on this e-mail that I was
forwarded, yes.
MR. SEIBERLING: Can we mark that as --
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Tab 17 will be Exhibit 9.
BY MR. SEIBERLING:
Q Turn to Tab 20.
It is a July 13, 2012 e-mail from Mark
Emmert to you, Julie Roe, Donald Remy advising
of a meeting scheduled with the executive
committee and Division I Board of Directors.
And the meeting was scheduled to be July 17,
2012.
Do you remember taking part in that
meeting?
A Yes.
Q Do you remember what was discussed with
him during that meeting, of a nonprivileged
nature?
MR. KOWALSKI: You can discuss things
other than Donald Remy providing legal advice
to the executive committee.
THE WITNESS: I believe, in general, just
regarding the Penn State matter.
BY MR. SEIBERLING:
Q What about the Penn State matter?
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MR. KOWALSKI: Same objection.
THE WITNESS: For this call specifically,
I am not exactly sure what the content would
have been.
Q Was the death penalty discussed during
this call?
THE WITNESS: You're asking me
specifically about this call, and I am
suggesting to you I don't recall exactly on
this call on this date what was talked about
other than what the subjects would say would be
Penn State.
BY MR. SEIBERLING:
Q Was there a subsequent call where the
death penalty was discussed?
A There was "a" call.
Q You don't remember if it was this call
or -- how many calls do you remember involving
the executive committee and Division I Board of
Directors?
A At least one, maybe more, but I am not
sure exactly.
Q So during this one or that potentially
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other call, was the death penalty discussed?
THE WITNESS: Yes. I recall the death
penalty being discussed among a group of
presidents, I believe the executive committee
and the board. I am not exactly sure of that,
but, yes, I remember it being talked about.
Q What was the position on the death
penalty?
THE WITNESS: Ultimately, I recall the
board and the executive committee not
gravitating to that response.
Q Was Ed Ray advocating for that response?
A I know that Ed provided feedback on his
thoughts as to why it should be considered. I
don't ultimately know how that -- how he
articulated that on the call. I don't recall
that.
Q Who was presenting the options to the
board?
A I don't recall that.
Q Who was speaking the most, or who was
taking the lead during the call?

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A I don't recall that, either.
Q Was President Emmert?
A He may -- may have.
Q Was President Emmert providing the
options or was the board providing the options?
A I do not recall.
Q Did the board come up with any options
other than those being presented by President
Emmert?
A That, I don't recall.
Q Was the consent decree discussed during
one or both of those calls?
THE WITNESS: That, I don't recall
specifically, either.
BY MR. SEIBERLING:
Q So you're unsure if the consent decree
was presented to the board of directors?
A Your question was on these calls?
Q Yes.
A I don't know. And I don't know whether
it was in the form of a consent decree at this
point in time. I don't recall.
Q Was the board provided -- prior to
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execution of the consent decree, was the board
provided a draft of the consent decree?
A I just don't recall.
Q Were you involved in the drafting or
editing of the consent decree?
A Yes.
Q To what extent?
You have to be very careful here not to
reveal attorney-client privileged information
including communications between you and
Mr. Remy about the comments to, drafting of
the language within the consent decree during
the drafting process, which is absolutely
covered by attorney-client privilege.
What was your question? To what extent,
or something like that?
MR. SEIBERLING: Yes. What extent was he
editing or helping to draft?
MR. KOWALSKI: I think you can provide a
general answer, but any details about specific
edits or anything like that is privileged.
THE WITNESS: I recall the -- just
providing some editorial comments, no
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substantive drafting on my part.
BY MR. SEIBERLING:
Q Why were you included in that process?
MR. SEIBERLING: How is that privileged?
MR. KOWALSKI: Mr. Remy included
Mr. Lennon for a particular purpose.
MR. SEIBERLING: But was it for some
expertise? I don't understand why someone -MR. KOWALSKI: It's speculation as well.
But beyond that, if Mr. Remy had a legal
analysis that led to a decision being -MR. SEIBERLING: Why is he going to a
nonlawyer for a legal analysis?
MR. KOWALSKI: I think if counsel decides
to seek input from people, that is a privileged
process.
MR. SEIBERLING: So you're directing him
not to answer?
MR. KOWALSKI: What was the question?
MR. SEIBERLING: I asked what was his
role.
MR. KOWALSKI: He answered that.
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BY MR. SEIBERLING:
Q Can you answer again? I'm sorry, I
didn't -MR. KOWALSKI: Look at back at what he
said. How did he answer the question?
(Thereupon, the requested portion of the
record was read back by the court reporter.)
MR. KOWALSKI: Here's -- I guess one way
to resolve this is: Do you know why you were
included -- why you were asked to comment on
the consent decree?
THE WITNESS: Other than being a part of
the original group, no.
MR. KOWALSKI: I mean, if that is his
answer.
BY MR. SEIBERLING:
Q In the past, have you been included on
agreements -- editing agreements such as this?
THE WITNESS: I am routinely included in
editing and providing comments on all of our
responses back to congress and congressional
committees and all these other things that
Donald drafts, yes.

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Q What about sanctions against
institutions?
THE WITNESS: Me personally, no.
Q Have you been included since in those
types of documents drafting or editing?
A No.
Q Do you know why or why not?
content -- first of all, he asked you: Do you
know why, "yes" or "no." So you can answer
that.
THE WITNESS: Do I know why I haven't been
included in review of the infractions reports?
Q Yes.
A Julie Roe and Jon Duncan haven't felt
that to be necessary.
Q Why was it necessary in this instance?
THE WITNESS: You would have to ask Donald
that.
Q He didn't convey that to you, though?
THE WITNESS: I don't recall any context
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with which Donald said, This is how you need to
review this or why you're reviewing this.
Other than, "I would like you to review it."
MR. KOWALSKI: That's as far as you're
going to go.
BY MR. SEIBERLING:
Q On the executive committee or the
Division I Board of Directors, were there any
other Big 10 conference schools on that
committee -- or on those committees?
A There may have been.
Q Who?
A I seem to recall that Lou Anna Simon,
the president of Michigan State, may have been
serving on either our board or the executive
committee, and I am not sure which.
Q And she is the president of what?
A Michigan State University.
Q Did anyone raise any concerns of a
conflict with her being involved -MR. KOWALSKI: Objection.
Q -- in the Penn State matter?
A I don't recall.
Q Do you view it as a conflict?
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Potentially.
Why wasn't that addressed, do you know?
THE WITNESS: As I said, I don't know
whether it was addressed or not.
Q Did you personally raise it as a
potential issue?
A I don't recall so.
Q Did anyone raise it as a potential issue
that you're aware of?
Careful on privilege here. I don't know
what the answer is, but be careful not to
reveal content of legal communication with
counsel.
Q She replaced Ed Ray as the head of the
executive committee, is that correct?
A I believe she did replace Ed.
Q And no one raised the conflict issue
then, either?
MR. KOWALSKI: Objection with respect to
legal counsel.
THE WITNESS: I don't know when she
A
Q
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replaced Ed Ray.
Q August 2012.
MR. KOWALSKI: Objection to form. Is
there a question?
Q Were you aware that in August of 2012
she replaced Ed Ray as the chair of the
executive committee?
A I knew she replaced Ed Ray. I was not
aware -- do not recall the effective date.
Q Do you know if she was involved in the
subsequent implementation of the consent decree
after she became the chair of the executive
committee?
A I'm aware that the executive
committee -MR. KOWALSKI: Objection.
Be careful not to reveal communications
with legal counsel.
THE WITNESS: I am aware that the
executive committee received reports regarding
the implementation of the athletics integrity
agreement. That, I'm aware of.
Q Were you aware of the board voting on
the consent decree?

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Exhibit 10?
BY MR. SEIBERLING:
Q Were you aware of the board voting on
the terms of the consent decree?
A I am aware of the board voting on the
penalties outlined in the consent decree. What
I am hesitating on is whether it was the actual
consent decree. But I am aware of a board vote.
Q How did that board vote go, at least
that you're aware of?
MR. KOWALSKI: You mean did it pass?
Q Yeah, did it pass? What was the vote?
A I recall overwhelming support among the
presidents for actions taken.
Q Was the president of Michigan State
included in that vote?
A I don't recall.
Q Flip to Tab 23. Flip to page 3 of that
tab.
There is an e-mail dated July 19, 2012,
from Donald Remy to Gene Marsh, cc'ed David
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Berst, subject: "One more thing."
Quote, "Gene, I apologize, but I
neglected to mention an additional penalty.
Vacation of football wins from 1998 forward."
Was there a discussion that you were
involved in related to the vacation of the
football wins?
MR. KOWALSKI: "Yes" or "no."
THE WITNESS: Yes.
Q What was your view on the vacation of
the football wins?
A I could see why a vacation of wins was
an appropriate response to the allegations and
the findings.
Q Why is that?
A When considering institutional
sanctions, a vacation of wins is reasonable to
consider. And in this instance, our presidents
and the institutions agreed that it was an
appropriate action, given the circumstances.
Q Did you believe it was?
A I was agnostic.
Q The reason why I ask, in the context of
this e-mail, the subject is, quote, "One more
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thing." And it appears that it was presented to
Gene Marsh as: We discussed the other
penalties, I forgot to mention this additional
one, which is the vacation of football wins from
1998 forward, as if it was a penalty added on
after the other sanctions had already been
determined.
Is that an accurate assessment?
MR. KOWALSKI: Objection. It is total
speculation. He is not on it. You're spinning
this out at this point. I don't know...
If you know, answer -- if you can answer
his question, but...
THE WITNESS: I'm not aware of separate
conversations within our internal group that
had reached certain conclusions, and then an
entirely separate conversation that then
discussed the vacation of wins.
Q Was the vacation of wins something that
was talked about initially as far as sanctions,
or did it come after the fact?
privileged communications with legal counsel.
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THE WITNESS: I'm not sure I know what you
mean by "after the fact."
Q Was it one of the main -- was it one of
the primary sanctions that the NCAA was looking
to impose?
Please don't reveal contents of any
privileged communications with legal counsel.
THE WITNESS: My recollection is that the
vacation of wins was a conversation, along with
the other areas, kind of early in the
conversation. Again, it wasn't separated out
and it was not an add-on. That is my
recollection.
Q The vacation of wins was a necessary
component of the consent decree.
Mischaracterizes.
You can't reveal privileged information.
So if what you're thinking about is a
privileged communication with Donald Remy,
you need to find a different way to answer
it.
25

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BY MR. SEIBERLING:
Q The e-mail is titled, "One more thing."
It comes across as an afterthought.
MR. KOWALSKI: He is not on it, Mark.
THE WITNESS: I don't know whether Donald
simply forgot to include it. You probably need
to ask Donald.
Q Was it that unimportant that he forgot
to include it?
MR. KOWALSKI: Objection. Total
speculation here.
THE WITNESS: As I've already shared, my
recollection is that the conversations with the
internal group about the appropriateness of
vacating wins occurred fairly early on in the
conversation of all appropriate penalties. And
I never would have thought about or
characterized it as an add-on.
Q If you flip forward to the next page
there is a July 19, 2012, e-mail from Donald
Remy to Gene Marsh cc'ed David Berst.
At the very bottom of that page, it
says, quote, "Have people lost sight of the fact
that PSU will be paying out tens of millions of
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dollars to the victims? How can people go from
30 million to 60 million in 48 hours?"
MR. KOWALSKI: Just for clarification, I
think that is an e-mail from Gene Marsh, right?
MR. SEIBERLING: I'm sorry, it is from
Gene Marsh to Donald Remy.
BY MR. SEIBERLING:
Q Why did the fine jump from 30 million to
60 million in 48 hours?
privileged communications that involved NCAA
legal counsel.
THE WITNESS: I think I will invoke that
privilege.
not to answer?
MR. KOWALSKI: So the only way you can
answer that question is to reveal the contents
of a discussion involving Donald Remy that was
legal in nature? If that is the case, then
yes, we are invoking it.
Put it this way: Are you picturing -is where you know that from a meeting or
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communication involving Donald Remy?
THE WITNESS: Yes.
BY MR. SEIBERLING:
Q So the only reason why you know the fine
amount doubled in 48 hours is because of a
conversation with Donald Remy?
And mischaracterizes.
I guess we haven't even crossed the
threshold of whether he even knows about it.
Q Do you know the fine doubled from 30- to
60 million in 48 hours?
A I don't recall that. I don't recall
that happening.
Q Do you know the fine amount being
$30 million initially?
A I don't recall that.
Q How is the amount reached or determined
as far as is the amount of -- what the amount of
fine would be?
MR. KOWALSKI: You can't reveal privileged
THE WITNESS: I know from reading the
consent decree that the $60 million reflected
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one year gross income. I get that from reading
the report. I don't recall in those
conversations how the dollar total was
specifically reached in...
MR. KOWALSKI: Just for planning purposes,
it is now nearly 3:10. I don't know how much
longer you guys have, but if -- we would
potentially -- depending on when we are going
to end, we potentially need a break and
potentially need to deal with some other
things.
MR. SEIBERLING: Maybe another hour.
MR. KOWALSKI: Let's take a break.
MR. SEIBERLING: We marked Tab 23 as
Exhibit 11.
BY MR. SEIBERLING:
Q Can you flip to Tab 27? This is an
e-mail from Ed Ray to Mark Emmert, cc'ed Jim
Isch, Wally Renfro, Julie Roe, subject "My 2
cents worth".
Were you forwarded this e-mail or did

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you receive this e-mail at all?
A I don't recall.
Q I'll read the first paragraph, quote,
"Mark, I have given a great deal of thought to
the matter at hand, and my primary objective is
to suggest a course that leaves you in the
strongest possible leadership position and
corresponds to my personal sense, what it means
to do the right thing when you know you will be
criticized for whatever you do."
Did Ed Ray ever -- I think we probably
covered this at some point -- but did Ed Ray
ever voice his 2 cents worth to you?
A I don't recall.
Q Julie Roe was copied on this e-mail.
Did she relate to you at all what Ed Ray was
thinking at the time?
A I don't recall.
Q Going on to the next paragraph. Quote,
"I suggest you tell people on the call that this
is your decision, but you want their input
regarding a summary disposition of the case".
Quote, "Tell them there are two options
that are harsher than what one could expect out
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of the current enforcement process, but either
would offer the school closure now rather than
in two years. Describe Plan A and B, with Plan
B including lesser penalties in every category
than A, but including the additional penalty we
discussed. Both plans attempt to impose harsher
penalties than staff believed can be gained
through the standard enforcement process.
Clearly I prefer B because it puts you
in the strongest position whether or not it is
accepted".
Were you aware of a Plan A and Plan B
being presented to the executive committee
and/or the Division 1 Board of Directors?
A I am not recalling that.
Q So you don't remember a Plan A?
A I don't recall anything being
characterized as Plans A or Plan B.
Q Were there two plans that you're aware
of that were presented to the committee?
A I do not recall them being presented as
alternative plans.
Q Do you remember two options being
presented?
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A I remember the conversation being more
of, here is an array of penalties, and then as
we discussed, they talked about the potential
discontinuation of the program. But I am not
recalling specifically a Plan A/Plan B approach.
I am not recalling that.
Q Do you remember, quote, "The two options
being harsher than what one could expect out of
the current enforcement process"?
A Again, not knowing exactly what he is
referring to in Plan A and Plan B, it appears
President Ray thinks that either one of those
options carry more significant penalty than he
believes would come out of enforcement.
Q You were present on the call when the
options were presented to the committee?
MR. KOWALSKI: Objection. I think he
testified he doesn't remember options like
this.
Q I am just saying, were you present on
the call when options, whether they were this A
or B, were presented to the committee?
A I remember being on a call with the
presidents in which they discussed the
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appropriate actions of the NCAA. Yes, that I
remember.
Q Were any of those actions being
discussed harsher than what one could expect out
of the current enforcement process?
MR. KOWALSKI: Objection. This is Ed
Ray's e-mail, so I am -- is the question -well, based on what he thought was likely to
come out of the enforcement -MR. SEIBERLING: He said the group was
discussing potential actions. I asked were any
of those potential actions beyond or outside of
the scope of what could have been accomplished
in the normal enforcement process.
BY MR. SEIBERLING:
Q In other words, were the options or the
actions being discussed by the committee more
severe than what could have been accomplished if
the normal enforcement process had been
instituted and followed?
A No. There was the potential that they
could have been more severe going through the
enforcement process.

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Q In what respect? How could they have
been more severe?
MR. KOWALSKI: This is your personal
opinion versus discussions with legal counsel.
THE WITNESS: They could have had their
sport discontinued.
BY MR. SEIBERLING:
Q Through the enforcement process?
A Yes.
Q Even without being a repeat offender?
A Yes.
Q So you would disagree with -- I know you
haven't seen this e-mail, and you're seeing it
for the first time -- the categorization by Ed
Ray that, quote, "both plans attempt to impose
harsher penalties than staff believed can be
gained through the standard enforcement
process"?
MR. KOWALSKI: Objection. I am going to
object -- my standing objection on this
document is he is not on it. So you're asking
a lot of questions about someone else's words.
Q I'll withdraw the question.
Did the committee eventually vote on a
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plan of action?
A The Division 1 Board and the executive
committee ultimately voted to support a course
of action for the NCAA that serves of the
substance for the consent decree.
Q Had the substance -- at that point, at
least that you're aware of, had the substance of
the consent decree been presented to Penn State?
contents of privileged communications with
legal counsel.
THE WITNESS: Yeah, I don't recall.
BY MR. SEIBERLING:
Q So the board potentially could have
voted or approved action without Penn State even
being aware of what those actions could be?
A I believe that to be the case.
Q Again, that is because it wasn't a
negotiated consent decree with Penn State?
THE WITNESS: That is because the board
and the executive committee take -- can take
whatever actions they think are appropriate.
MR. SEIBERLING: We will mark Tab 27 as
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Exhibit 12.
BY MR. SEIBERLING:
Q The Freeh Report was released July 12.
The consent decree was entered July 11th.
MR. KOWALSKI: Objection. July 11th -Q I'm sorry, July 23rd.
Why only 11 days between the release of
the Freeh Report and the agreement and execution
of the consent decree?
MR. KOWALSKI: Object to the form of the
question.
MR. SEIBERLING: Why the rush?
MR. KOWALSKI: Object to the form of that
question.
BY MR. SEIBERLING:
Q Did you believe 11 days was enough time
to formulate and then implement the consent
decree based off of the Freeh Report?
MR. KOWALSKI: Object to the form.
Assumes the prior two questions are withdrawn
and that is one pending right now?
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THE WITNESS: Why don't you repeat the
question, please?
Q Was 11 days sufficient time to draft,
implement and execute the consent decree?
A Yes.
Q Why did it take -- why only 11 days
between the release of the Freeh Report and the
execution of the consent decree?
MR. KOWALSKI: Object. Don't reveal any
communications with legal counsel in answering
this question, and speculation.
THE WITNESS: The very nature of the
consent decree is when both parties willingly
agree to enter into a consent decree that they
both believe is appropriate. That could -whenever that occurs is the right time to have
the consent decree authorized and engaged. And
in this instance that is what occurred.
Penn State willingly entered into a
consent decree with the NCAA, which is
totally appropriate as a member institution.
They elected to take that course of action
without availing themselves of any appeal
opportunities which were available to them.

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They submitted the Freeh Report as their
response, back in November, to the
November 17th letter, and agreed to move
forward with the consent decree.
So, 11 days when the parties have come
together and made that agreement, seems
appropriate.
Q To your knowledge, was a deadline set on
when and if a consent decree needed to be
entered and executed?
A I don't know that.
Q Was the July 23rd press conference
scheduled even before a consent decree was
signed and executed?
A I don't know that.
Q Who signed the consent decree on behalf
of the NCAA?
MR. KOWALSKI: Do you need to see a copy?
THE WITNESS: It would be helpful to see a
copy.
Q It's Tab 38.
A President Mark Emmert signed the consent
decree on behalf of the NCAA.
Q Did he have the approval of the
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executive committee before signing the consent
decree?
A Yes, I believe he did.
Q Did he have the approval of the Division
1 Board of Directors before signing?
A Yes, I believe he did.
Q Who signed on behalf of Penn State?
A President Rodney Erickson, the President
of Penn State University.
Q Did President Erickson have the approval
of his board of trustees before signing?
Foundation.
THE WITNESS: I do not know.
BY MR. SEIBERLING:
Q Did you believe that he needed to have
the approval of the board of trustees before
signing?
Legal conclusion.
THE WITNESS: As the president of the
university, I believe that was between the
president and the board, his board. So I did
not question his authority to sign this.
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Q In looking in hindsight, do you question
his authority to sign it?
A No.
Exhibit 13.
BY MR. SEIBERLING:
Q Did the need for students to be able to
transfer play into the timing of when the
consent decree was executed?
reveal any confidential communications with Mr.
Remy or other NCAA legal counsel.
THE WITNESS: I recall discussions
surrounding students' ability to transfer and
leave Penn State as being a part of the consent
decree. As to the timing of when the consent
decree was ultimately agreed upon, and the
influence of that timing specifically on
individuals' ability to transfer, I am not
recalling specific conversations of how those
two were related directly.
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BY MR. SEIBERLING:
Q So, to your knowledge, that was not a
factor in the need to have a consent decree
entered as soon as possible?
THE WITNESS: I'm not recalling that
specifically.
Q Whose idea -- to your knowledge, whose
idea was the drafting and implementation of a
consent decree? Was it the NCAA's or was it
Penn State's?
MR. KOWALSKI: If you know.
THE WITNESS: Yeah, I don't know. I don't
know specifically.
Q How soon after the Freeh Report did it
come to your attention or your knowledge that
the idea would be to enter and sign a consent
decree?
A I don't specifically recall a date or a
timeline on that.
Q Was it early in the process?
A I'm not sure what you mean by "early".
Q As in shortly after the release of the
Freeh Report, in the later stages when...

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A It was some time within the 11 days.
Q Did you attend the press conference on
the 23rd of July?
THE WITNESS: Yes, I did.
Q Did you have any role in the press
conference?
A I had no formal role in the press
conference.
Q Did you have any formal role following
the press conference, as far as answering
questions from the media?
A I believe I did.
Q On what topics?
A I believe during the press conference
Mark mentioned that I would be the person for
them to talk to regarding the grant and aid
limitations and the transfer provisions.
Q If you can flip to Tab 35. This is an
e-mail from you to multiple individuals,
multiple individuals cc'd, subject, quote,
"getting information this morning to our
membership".
Quote, "Amy, Bob, David Berst and I
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talked this morning about getting information to
our entire membership on the PSU issue."
Can you explain the context of this
e-mail?
A I was sending this e-mail to our
communications staff, encouraging them to making
sure that we provided our membership with
information in a timely manner regarding the
activities that were to occur on the 23rd.
Q Is this another instance of you agreeing
to the forefront, the concern that the
membership needs to be informed?
A I don't like it when our membership has
to read through social media decisions of the
NCAA. So, I feel strongly that when actions are
taken they should hear things ultimately from
the NCAA, so it was in that spirit.
Q Had concerns been raised to you
previously about that issue, about the
membership reading, about something the
newspapers or the media before hearing it from
the NCAA?
A Yes. I have heard from some of the
membership who were seeking more timely
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communications, so that they hear it first from
the NCAA and not from the media.
MR. SEIBERLING: We can do Tab 35 as
Exhibit 14.
BY MR. SEIBERLING:
Q Exhibit 14. If you can flip to the next
Tab Number 36. This is a July 23rd e-mail from
David Berst to the CCA members.
Do you know what CCA stands for?
A Yes. It stands for the Collegiate
Commissioners Association.
Q Who is that?
A Those would be the commissioners of our
Division 1 conferences.
Q According to the blacked-out e-mail that
precedes this page you were forwarded this
e-mail?
MR. KOWALSKI: This is redacted, but it
reflected you were forwarded this nonprivileged
e-mail.
BY MR. SEIBERLING:
Q Do you remember seeing this e-mail from
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K. LENNON
David Berst?
A I do.
Q We'll walk through this, hopefully,
fast.
Quote, "A few comments on how/why action
has taken place. I worked with our legal
counsel and the universities to design the
consent decree that Penn State eventually agreed
to. Mark communicated with Jim Delany and Anna
Lou Simon of MSU serves on the Board of
Directors and executive committee."
Next paragraph, "I want to comment to
you on jurisdiction and where we go from here
regarding future potential cases.
We and the exec com believe that the
athletic culture of PSU over a 14-year period
created the opportunity and maybe even the safe
harbor for despicable criminal activities to
take place.
This cuts so deeply into the value
structure of intercollegiate athletics that in
the interest of taking action to resolve a core
issue of the association the executive committee
exercises jurisdiction and permitted the staff

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to develop a set of conclusions based on the
Freeh Report and Sandusky trial, as well as
penalties subject to executive committee final
approval and sign off by the president of Penn
State.
This was not a negotiation. The NCAA
established the penalties and absent the
signature of the president, the matter would
have been referred to the more cumbersome
enforcement process".
Do you agree with that summation?
You're asking him whether he agrees with
everything that David Berst wrote in a
paragraph that goes one, two, three, four,
five -- eight lines?
MR. SEIBERLING: I am trying to do it in
the interest of shortening this.
I think we covered a lot of these issues
that you have already asked -- already been
asked and answered. We'll break it down.
Q The sentence reads, "The executive
committee exercises jurisdiction and then
permitted the staff to develop a set of
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conclusions based on the Freeh Report and
Sandusky trial, as well as penalties".
So, do you agree that the staff
developed a set of conclusions based on the
Freeh Report and Sandusky trial as well as
penalties?
A Yes. I disagree a little bit with the
characterization of "set of conclusions." I
don't know what David had in mind when he wrote
the word "conclusion", but I am comfortable that
the staff was in charge with identifying, as
they say in their report, the penalties.
Q How about the next sentence, quote,
"this was not a negotiation?" Do you agree with
that?
A Yes. As I -MR. KOWALSKI: Objection to form and
speculation.
Go ahead and answer.
THE WITNESS: As I previously stated, my
characterization of the consent decree was not
the typical negotiation where there was a back
and forth, often with compromise. My sense,
and you can certainly ask David, is what was
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intended by his statement.
Q What was your view of what the consent
decree was?
Q If it wasn't a negotiation, and it
didn't involve the normal back forth, in which a
normal agreement would have, then what was the
consent decree?
MR. KOWALSKI: Objection to the form of
the question.
THE WITNESS: It was a member institution
agreeing, through a consent decree or a
contract, with its -- the organization that
it's a member of to say, we are in agreement
that this is the appropriate means with which
we are going to enter into this arrangement
with the organization, and we are going to do
so willingly and voluntarily. And we accept
the terms of the consent decree. This is in -this is acceptable to us as a member
institution.
Q So the agreement was accepting the terms
as set forth by the NCAA?
MR. KOWALSKI: Objection. To the extent
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that calls for a legal conclusion, I am
objecting.
I don't know if he took contracts, but
he was not in law school. I am not sure he
knows how to answer that question.
BY MR. SEIBERLING:
Q What, if any, benefit did Penn State
receive from entering into the consent decree?
A My understanding would be that Penn
State, in entering into the consent decree,
would do so because it was in the best interest
of their institution to begin to heal; that the
penalties assessed were appropriate, and that
they believed, rather than engaging the NCAA
process in any other way, this was the best way
for them to move forward given the
transgressions that had happened on their
campus.
They made that agreement. And as a
member of the association, when the presidents
of the association agree that such an agreement
is appropriate, that certainly one of the
members can enter into that, and that is, I
think, what happened.

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Q So the agreement was to avoid the
THE WITNESS: Yeah, that certainly does
mischaracterize it.
The agreement was deemed by Penn State
and their president to be in the best
interest of Penn State.
Q Who told you that?
A I am making an assumption that, as the
president of Penn State, they would enter into
the agreement because they believed it was in
the best interest of the university to do so,
and was an appropriate action for the
university.
Q Why would it have been in the best
interest of Penn State?
MR. KOWALSKI: He is not Penn State, Mark.
MR. SEIBERLING: He's already making
assumptions -MR. KOWALSKI: If you want to tell him to
keep assuming and speculating, he can offer
that, but obviously he doesn't know what Penn
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State was thinking about this.
MR. SEIBERLING: Move on to the next
paragraph.
Q Quote, "many presidents favor the
so-called death penalty".
Do you agree with that?
A I recall that some did. I don't know
about many.
Q Any concerns about this e-mail being
sent -- strike that.
Did you have any concerns about David
Berst circulating this e-mail to the CCA
members?
A I did not. I thought, perhaps, there
was a few too many "I"s in there.
Q With regard to what?
A To David referring to himself.
Q As in, he was saying he was more
involved than he really was?
A No. As a matter of NCAA policy and
approach I generally say "we," but that is a
style issue.
In terms of sending it to the CCA
members and keeping them informed, I thought
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that was appropriate for David to do that.
Q Were you aware of appeals being filed
with regard to the consent decree after it was
executed?
A I was not aware of Penn State University
submitting any appeals.
Q What about other individuals?
A I was aware that there were other
individuals in the Penn State community who had
concerns about Penn State entering into an
agreement.
Q What were those concerns?
MR. KOWALSKI: Object to form. Your
understanding of those concerns.
THE WITNESS: I believe they ran along the
lines of, does the -- did the president have
the authority to do so at Penn State.
BY MR. SEIBERLING:
Q Did you share those concerns?
A No.
MR. SEIBERLING: Tab 36, we can mark it as
Exhibit 15.
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BY MR. SEIBERLING:
Q How were those appeals handled?
Q Are you aware of how those appeals were
handled?
A No, I am not.
Q If you can flip to Tab 57. If you flip
to the second page of that tab, this is an
e-mail from you to the Senior Management Group,
SMG, David Berst, Julie Roe, Tom Hosty, Rachel
Newman, subject, quote, "Feedback from
Conference USA presidents".
If you can flip to number 6, which
appears to be captioned, quote, Penn State.
Quote, "at the end of the session Brit asked
that I speak about PSU. I shared with them
executive committee authorization, Mark's
communication and engagement with executive
committee and board, sanctions themselves, et
cetera.
Some wondered if not death penalty then
would we use it -- then when would we use it.
More raised issues regarding jurisdiction on
NCAA and these types of issues, but most seemed

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K. LENNON
to understand the uniqueness of this situation
and need for response".
Can you explain -- first of all, what is
the context of this e-mail in this summation?
A This would have been information that I
provided to the Senior Management Group as a
part of our ongoing efforts to inform each other
of what our membership was talking about, as we
were on the road in various meetings.
Q Had you attended a conference?
A Yes, I did.
Q And this was the result -- this was your
summary or feedback from attending a conference?
A Yes, it was.
Q What did you mean by the statement "some
wondered if not death penalty, then when would
we use it"?
A My recollection is that there were some
presidents within the Conference USA who were so
alarmed by what had happened at Penn State that
they wondered if additional penalties beyond
those imposed in the consent decree were
appropriate.
Q The next sentence, quote, "more raised
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K. LENNON
issues regarding jurisdiction on NCAA and these
types of issues".
Can you explain that?
A My recollection is that some of the
presidents in Conference USA were raising the
issue of what type of similar cases might invoke
a response similar to what happened at Penn
State.
Q Did you provide any examples?
Q Were any examples presented to you?
A I don't believe they were.
Q If you continue on, quote, "Most
concerning comment came from Rice University
President David Leebron, he was on the phone,
who responded to my statement that there was
strong support from executive committee and
board on penalties that he was on the calls with
Mark, and that they really did not have time to
fully vet the penalties, and that the timeline
did not allow for as thoughtful consideration as
he would have liked".
Can you explain what President David
Leebron conveyed to you at that time?
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A I think President Leebron, during the
course of the call, indicated that, at least
from his perspective, he may have liked more
time to have talked through the ultimate
outcome. That is my general recollection.
Q He was raising this issue months later?
A It appears so.
Q What was your response to him?
A I don't know if I provided a specific
response to President Leebron's assertion, in
part, because he is the only president that I
ever heard that from. And I took it as a
statement that really didn't require reaction
from my part.
Q Did you believe the committee had,
quote, "time to fully vet the penalties"?
A I believe they had reasonable time to
assess the penalties that were before them. I
felt comfortable, in part, because they have
confidence in the staff as we put forward the
ideas. I felt comfortable that they did.
Q How much time were they given?
A I don't know how long the call went. I
don't know what they saw ahead of time. I don't
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know that part of the equation.
Q Was it days?
A I don't know.
Q No more than 11 days?
A Yes.
Q And, in your mind, 11 days was
sufficient time to vet the penalties?
MR. KOWALSKI: Asked and answered.
Q You can still answer.
A It was sufficient.
MR. SEIBERLING: Tab 57 we will mark as
Exhibit 16.
BY MR. SEIBERLING:
Q Were you aware of the comments to the
media that Ed Ray made following the press
conference and the execution of the consent
decree?
THE WITNESS: I seem to recall some
comments that Ed made after the press
conference. Yes.
Q Were you aware of issues being raised as

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far as Ed Ray being inconsistent with President
Emmert on what was presented to the executive
committee?
A I'm aware of some concerns about what Ed
Ray said, but I can't tell you specifically what
those concerns were at this point in time.
Q Were you aware of President Erickson's
claims that the NCAA threatened the death
penalty?
Foundation.
THE WITNESS: I believe -- I believe I am
aware that President Erickson may have said
something along those lines in the press. But
other than that, that is my general
recollection.
Q Were you involved in any responses to
those -- to that claim of Mr. -- of President
Erickson?
A I don't recall.
Q What about the media comments that Ed
Ray was making? Were you involved in any
response to those comments?
A I recall hearing from NCAA staff about
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K. LENNON
Ed's comments. But I don't recall any actions
beyond that that I would have been involved in.
Q What were the concerns about his
comments?
answered.
Q If you can answer, please answer.
A I vaguely recall the concerns being
regarding the consistency of what President Ray
was saying in some article.
Q Who was raising those concerns to you?
A That I don't recall.
Q President Emmert?
A I don't recall.
Q Julie Roe?
A I don't recall.
MR. SEIBERLING: One last thing we forgot
to mark was the bylaws we had shown you at the
very beginning, which I don't think are in
the -- we might as we'll mark it.
MR. KOWALSKI: What year is that?
MR. VOSS: '11/'12.
MR. SEIBERLING: We will mark that as
Exhibit 17.
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K. LENNON
MR. SEIBERLING: We don't have anything
further.
Does counsel for Penn State?
MR. SCOTT: No.
MR. KOWALSKI: We don't have any questions
at this time.
We will read and sign. We would like to
read and sign.
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(Whereupon, at 4:12 p.m., the deposition

was concluded.)
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NAME OF CASE: Jake Corman v. NCAA

DATE OF DEPOSITION: 11/4/2014
NAME OF WITNESS: Kevin Lennon
Reason Codes:
1. To clarify the record.
2. To conform to the facts.
3. To correct transcription errors.
Page ______ Line ______ Reason ______
From _____________________ to _____________________
Page ______ Line ______ Reason ______
From _____________________ to _____________________
Page ______ Line ______ Reason ______
From _____________________ to _____________________
Page ______ Line ______ Reason ______
From _____________________ to _____________________
Page ______ Line ______ Reason ______
From _____________________ to _____________________
Page ______ Line ______ Reason ______
From _____________________ to _____________________
Page ______ Line ______ Reason ______
From _____________________ to _____________________

(877) 702-9580
________________________
Signature of Deponent
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K. LENNON
CERTIFICATE
DISTRICT OF COLUMBIA
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I, the undersigned authority, hereby

certify that the foregoing transcript, page 1
through is a true and correct transcription of the
deposition of 244 taken before me at the time and
place set forth on the title page hereof.
I further certify that said
witness was duly sworn by me according to law.
I further certify that I am not of
counsel to any of the parties to said cause or
otherwise interested in the event thereof.
IN WITNESS WHEREOF I hereunto set my
hand and affix official seal this 7th day of
November, 2014.
ACCURATE TRANSCRIPT FURTHER DEPONENT SAYETH NOT.
THE WITNESS
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Sworn and subscribed to before me this
_______day of_______,2014.
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Personally known__________or
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I.D._______________
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____________________.
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___________________________________
RANDI GARCIA, COURT REPORTER, RPR
NOTARY PUBLIC
________________________
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K. LENNON
I CERTIFY THIS IS A TRUE AND
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Notary Public in and for
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the District of Columbia at
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Large. My Commission Expires:
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July 12, 2016
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interpret (7)
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issue (43)
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items (4)
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J (1)
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Julie (67)
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July (51)
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Kansas (1)
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keep (4)
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kind (18)
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KOWALSKI (351)
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legal (88)
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Lennon (258)
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let's (16)
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letter (50)
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levels (1)
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levied (2)
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Remy (81)
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Roe's (2)

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Seiberling (156)
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Starting (2)
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State's (9)
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2010 (1)
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2014 (4)
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25 (1)
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144:20 183:16
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3:17
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5:6
79 (1)
5:7
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8 (3)
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86741 (1)
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9
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9:03 (2)
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9:08 (1)
2:11
90s (1)
147:7
92 (1)
5:8
5 (11)
5:8 66:4 72:20 92:12
92:13 154:24
160:18 164:21
167:4 169:3 176:22
50 (1)
26:5
53 (1)
5:4
555 (2)
2:8 3:12
57 (2)
237:8 241:12
6
6 (7)
4:14 5:9 72:24 79:5
101:25 102:3
237:14
60 (3)
211:3,10 212:13
6222 (1)
3:17
65 (1)
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7
7 (3)
5:10 170:8,9
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Exhibit B
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B. WILLIAMS
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
No. 1 M.D. 2013
JAKE CORMAN, in his official capacity

as Senator from the 34th Senatorial
District of Pennsylvania and Chair

of the Senate Committee on
Appropriations; and ROBERT M.

McCORD, in his official capacity as
Treasurer of the Commonwealth of

Pennsylvania,
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Plaintiffs,
v.
THE NATIONAL COLLEGIATE ATHLETIC
ASSOCIATION,
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Defendant.
v.
PENNSYLVANIA STATE UNIVERSITY,
Defendant.
_____________________________________X
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Depostion of Bob Williams
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Wednesday, November 5, 2014
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1:38 p.m.
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B. WILLIAMS
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Wednesday, November 5, 2014

1:38 p.m.
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Deposition of BOB WILLIAMS, taken by Plaintiff,

at the offices of Latham & Watkins LLP,
555 Eleventh Street, NW, Washington, D.C.,
before Randi J. Garcia, Registered Professional
Reporter, and Notary Public in and for the District
of Columbia, beginning at approximately 1:38 p.m.,
when were present on behalf of the respective
parties:
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B. WILLIAMS
A P P E A R A N C E S:
ATTORNEYS FOR PLAINTIFF.
CONRAD O'BRIEN
BY: MARK SEIBERLING, ESQ
MATTHEW HAVERSTICK, ESQ
JOSHUA VOSS, ESQ
1500 Market Street
Philadelphia, PA 19102
ATTORNEYS FOR NCAA.
LATHAM & WATKINS
BY: BRIAN KOWALSKI, ESQ
SARAH M. GRAGERT, ESQ
555 Eleventh Street, NW
Washington, D.C. 20004
and ZANDRIA CONYERS
ASSOCIATE GENERAL COUNSEL NCAA
P.O. BOX 6222
Indianapolis, Indiana 46206
and KILLIAN & GEPHART, LLP
and MICHAEL O'CONNOR, ESQ
218 Pine Street
P.O. Box 886
Harrisburg, Pennsylvania 17108
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B. WILLIAMS
(Continued)
ATTORNEYS FOR PENN STATE.
REED SMITH
BY: MICHAEL SCOTT, ESQ
Three Logan Square
1717 Arch Street
Philadelphia, Pennsylvania 19103
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Also Present:
Kevin M. McKenna, Esquire
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INDEX
BOB WILLIAMS
DIRECT EXAMINATION
By Mr. Seiberling
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B. WILLIAMS
EXHIBITS
Page
30
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36
Exhibit 4 - 11/17/2011 letter
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Exhibit 5 - invitation for conference call 51
Exhibit 6 - Diane Young e-mail
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Exhibit 12 - Dana Thomas e-mail
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Exhibit 20 - committee meeting minutes 134
Exhibit 21 - Report of Executive Committee 135
140

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B. WILLIAMS
(Continued)
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Exhibit 25 - Emily Potter e-mail
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Exhibit 26 - invite from Mark Emmert
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162
Exhibit 30 - Jay Bilas e-mail
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Exhibit 31 - Jay Bilas e-mail
172
Exhibit 32 - August 3rd, 2012 CNN e-mail 174
Exhibit 33 - December 13, 2012 e-mail 176
(Exhibits attached to original transcript.)
B. WILLIAMS
Thereupon:
BOB WILLIAMS,
after having been first duly sworn, was examined and
testified as follows:
DIRECT EXAMINATION
BY MR. SEIBERLING:
Q Morning, Mr. Williams.
My name is Mark Seiberling, with my
colleague Josh Voss. We represent the plaintiff
in the matter Senator Jake Corman.
Have you been deposed previously before?
A Yes. You mean as far as this case?
Q No. Previously in any other case.
A Uh-huh.
Q So then what I will explain is probably
familiar to you. There is a court reporter.
She is taking down your answers, so please
answer audibly with "yes" or "no" answers. No
shaking of the head, no "uh-huhs." Just be as
clear as possible so the court reporter gets it
all down.
Do you understand that?
A Yes.
Q Second piece is if I ask you a question
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and it is unclear, feel free to ask me to
rephrase. I will do my best to make the
questions as clear as possible for you to
understand and answer.
A Yes.
Q The third piece, and we got into this a
little bit before we got on the record, as far
as there likely will be objections. Even if
your counsel objects, you're still required to
answer the question until the point where your
lawyer directs you not to. So even if there is
an objection to form, even an objection to
privilege, unless he directs you not to answer,
you must answer.
A Yes.
Q And are you under anything -- are you
under the influence of anything today that would
affect your ability to answer truthfully?
A No.
Q Finally, if there is any need to take a
break, go to the bathroom, we will do the best
we can to accommodate.
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A Yes.
Q Did you meet with anyone prior to the
deposition today regarding the subject matter of
the deposition?
A You said "meet with anyone"?
Q Yes. About the deposition today.
A I met with -- I met with the attorneys
here.
Q For how long?
A Approximately half hour.
Q Did you meet with them prior to today
about the deposition scheduled for today?
A Yes.
Q How long?
A I met with them for an hour and a half
yesterday. And I think it was last week I met
with them for two hours.
Q Was anyone present besides your lawyers?
A NCAA attorneys.
Q Anyone from outside the NCAA?
A No.
Q Were you shown docs during those
meetings?

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B. WILLIAMS
A Yes.
Q Can you explain generally your
background before you became -- before you went
to your position at the NCAA? You're -beginning with your academic background through
your work experience.
A I have an -- from an academic
standpoint, I have a Bachelor of Arts degree
from the State University of New York College at
Buffalo in mass communications. And I have a
Master's of Science from Boston University in
mass communications.
Prior to working for the NCAA, I served
25 years on active duty with the United States
Air Force.
Q So you enlisted after college?
A Correct. I went to Officers Training
School after college.
Q And what was your position in the
military?
A My last position was a director of
public affairs for Air Combat Command, and I
obtained the rank of colonel.
Q What did that entail? What were the job
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responsibilities?
A Job responsibilities were to essentially
direct and oversee all public and internal
communications for the command.
Q So essentially PR?
A Correct.
Q So then how did you end up at the NCAA?
A I was contacted by an executive
recruiter several years before who -- who was
interested in keeping in touch with me for
whenever I decided to get out of the military.
And as luck would have it, when I did
decide to retire, there was an opening in the
NCAA and he was the recruiter who was retained
for the search.
Q Did you know anyone at the NCAA prior to
joining?
A No.
Q So the recruiter was your liaison and
your -A Correct.
Q -- "in" at the NCAA?
What is your -- when you first started
at the NCAA, what was your position?
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A When I first started, I was managing
director of public and media relations. So my
portfolio was basically focused and more limited
to media relations and media support.
Q How long did you serve in that position?
A I served in that position five years.
Q Same job responsibilities?
A Essentially, yes.
Q And then you were promoted?
A Correct. I was promoted to vice
president of communications in 2010.
Q And who promoted you?
A President Emmert.
Q Were you promoted when he -- he was
hired in 2010 as the president, is that correct?
A Correct. And at that point, there was a
major restructure and the position of vice
president of communications was established.
And there was a national search, and I was one
of the candidates in competing.
Q That position didn't exist prior to you
taking over that position?
A Correct.
Q Can you explain the restructuring just
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generally, what happened as far as restructuring
within the NCAA?
THE WITNESS: The organization was
restructured to make it more streamlined.
Q In what way?
A There were several functions that were
consolidated. And from a communications
perspective, the organization that previously
existed that I operated in had both marketing
and branding and communications, and in 2010 the
decision was to have an organization that was
just focused on communications.
Q Did you know Mark Emmert before he was
named president?
A No.
Q Did you notice a culture change at the
NCAA at all when Mark Emmert became president?
THE WITNESS: Well, I had noticed culture
change literally from 2005 until 2010, it
was -- the culture was changing regularly.
Q In what way?
A When I first got there, the one thing

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that struck me about the culture there was that
it was so siloed. And over the course of the
next five years, I thought there was improvement
in the culture in that there was a lot more
discussion and collaboration across the staff.
Q This was after President Emmert was
named president?
A This was leading up to and certainly
after.
Q So, in your new position as vice
president of communications, what were your
general day-to-day responsibilities?
A Provide oversight to the entire external
and public communication effort, to include
media relations and digital communications,
community outreach, as well as member
communications and staff communications.
Q So I think you alluded to this a little
bit earlier. What changed from your prior
position as compared to your new position?
A My prior position, I was responsible for
primarily media relations.
Q What do you mean by that?
A Any time that the media had any
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B. WILLIAMS
questions, they would come to my unit; and,
conversely, when we had information that we
wanted to share with the media, we released it
from my unit.
Q And then how did that change in 2010
with your new position?
A Well, I still had that responsibility
but in addition, then, I also picked up the
responsibility for all digital and Web
communications, social media.
Q What does that include?
A Digital encompasses the web site.
Q Do you oversee the web site -A Yeah, oversee the web site, oversee, you
know, YouTube channel, all social media that -Q Twitter?
A Twitter, Facebook.
Q There is an NCAA.com and an NCAA.org.
Do you oversee both of those?
A Directly oversee NCAA.org. NCAA.com is
actually a commercial site that is run by
Turner, our broadcast partner, and it is focused
primarily on the championship experience and
championship information. I don't have direct
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daily oversight on that.
However, we do share content and I do -my staff does meet with that staff to review
content that they are posting.
Q With Twitter, does the NCAA have its own
Twitter account?
A Yes.
Q And you monitor and regulate that?
A Yes.
Q You also have your own Twitter account?
A Yes.
Q Is that your own personal or is that
also NCAA?
A No, it is an NCAA account.
Q Does anyone else at the NCAA have their
own Twitter account?
A Yes, members of my staff. There is
probably six to eight members of my staff that
have NCAA accounts as well.
Q So they are their personal accounts
under their own name, but it is NCAA content
that goes out from those accounts?
A Well, it is their first name @NCAA.
That is their handle.
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Q That is their handle?
A So it is clearly identified as an NCAA
account.
Q It sounds like you added
responsibilities as -- in your new position.
A Correct.
Q Anything else besides the digital
communications?
A We also -- I'm also responsible for
strategic communication planning.
A That's essentially forecasting issues
that the association would be faced with and
developing strategic communications plans to
address those issues.
Q Can you explain that again? I'm sorry.
I didn't...
A It is essentially monitoring what is
going on in the environment, and then
forecasting issues that might arise that the
association would have to address, and then
developing strategic communications plans and
approaches for those issues.
Q So it's essentially looking ahead to

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what might come down the road?
A Correct.
Q How often do you undertake those types
of endeavors?
A It's continuous.
Q And on those endeavors, who do you
report back to?
THE WITNESS: Well, if I had done -- if my
staff identifies an area that we need to
develop plans for, I will work with them to
develop those plans, and then review the final
draft, and then depending on what is going on,
whether I think that it is the right time or
not, I will either share those plans with our
senior staff or I will hold them until such
time I think it is necessary.
Q Who comprises the senior staff?
A That would be President Emmert, Donald
Remy, Mark Lewis, Bernard Franklin, Kathleen
McNeally, Cari Klecka, as well as myself.
Q Can you explain the typical chain of
command with regard to your position? Who do
you report to? Who does that person report to?
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A I report to Mark Emmert.
Q You report directly to Mark Emmert?
A Yes.
Q Do you report to Donald Remy?
A No.
Q Does Donald Remy provide input on
anything you do other than providing legal
advice?
A On occasion. Yes.
Q When you seek it or does he seek -- or
does he do it unilaterally?
THE WITNESS: Well, in the normal course
of business that I explained earlier, I will
send communication plans or draft statements or
releases to the senior staff for them to
provide any input that they might have.
Q So it's, like, a collective effort?
A Correct.
Q And Donald Remy would just be one of the
people within the collective effort?
THE WITNESS: Donald is one of several
people on senior staff that provides input.
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Q When you send those e-mails or send
those ideas around and you include Donald Remy,
are you including him as the attorney for the
NCAA, or are you including him as just one of
senior staff?
THE WITNESS: I send it with the
understanding that it is both.
Q So he wears two hats?
THE WITNESS: Well, he is, in fact, the
chief legal officer, yes. He is, in fact, also
the executive vice president of law policy and
guidance.
Q So in the executive vice president
capacity, he also serves an administration role?
THE WITNESS: That is correct.
BY MR. SEIBERLING:
Q When you're drafting a press release or
responding to a press inquiry, do you typically
run that release or statement by Donald Remy
before releasing it?
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THE WITNESS: If there are potential legal
ramifications, I will.
Q But not always?
A Correct.
Q So it's not a requirement that Donald
Remy reviews everything that the communications
department does before going out the door?
A That is correct.
Q And there are multiple times where you
have discussed matters with Donald Remy, not of
a legal nature, but more of an administrative
nature?
THE WITNESS: I have had discussions with
Donald on issues that are not entirely legal.
Q When President Emmert took over in 2010,
did the NCAA become more image conscious?
THE WITNESS: No.
Q In the nine -- I guess you have been
there nine years now?
A Uh-huh.
Q In the nine years you have been at the
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those nine years?
MR. KOWALSKI: Objection to form. That is
kind of a broad question. You're talking about
the image-conscious part?
Q The management, the management style,
the perceptions related to the communications
department.
A I have seen the NCAA become much more
collaborative than when I first arrived.
Q For better or worse?
A For better.
Q In August 2011, there was a president's
retreat. Did you attend that?
A Yes.
Q And what was discussed during that
retreat?
A There were discussions on the state of
college sports, what some of the challenges were
that college sports was facing, and -Q What were those challenges?
A Challenges ranging from economic
challenges, governance challenges, the need to
simplify bylaws, things of that nature.
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Q What about enforceability?
A There were discussions on enforcement
and -Q What were those discussions?
A -- how potentially that function could
be improved.
Q Improved how?
THE WITNESS: There were discussions that
focused on -- of what the members' expectations
were of enforcement and how those expectations
could be translated into new practices.
Q Was there a discussion of harsher
penalties for violators of the rules or bylaws?
A There were -- more accurately, there
were discussions about focusing in on meaningful
violations, and not spending so much time on
infractions that had little meaning.
Q Did you have a role in the retreat?
THE WITNESS: My role in the retreat was
to observe the discussions and frame the public
communications to report to both our membership
and the public on the results of the retreat.
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BY MR. SEIBERLING:
Q There were some working groups set up as
a result of that retreat, is that correct?
A That's correct.
Q Were you part of any of those working
groups?
A No, I was not.
Q Did you know what the working groups
were?
A Yes.
Q Can you explain?
A Well, there was a working group that was
established on rules. There was another one
established on student-athlete well-being.
There was an enforcement working group. And I
think -- I'm not sure of the formal name, but
there was a working group on finances.
Q Who headed the enforcement group?
MR. KOWALSKI: The working group?
Q Yes. Enforcement -- working group
related to enforcement.
A You mean from -- who headed enforcement
from the NCAA staff, or...
Q From either the membership and/or the
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NCAA staff.
A I'm not sure who headed the actual
enforcement working group.
Q Was Ed Ray the head?
A I believe he was involved. I don't know
if he was the chair or not.
Q Did you handle any media relations
related to the enforcement group -- I'm sorry,
the working group related to enforcement?
A Yes. If there are any questions about
what the group was doing or the milestones or
the progress they were making, all of that
communication -- public communication came
through my group.
Q Who did you go to, then, to get the
answers to those questions?
A Well, I had, actually, a member of my
staff who was the liaison to enforcement, and
they would work with the enforcement working
group, provide the first draft to me. I would
then review it, you know, make suggested
changes, and then send it back to the -- back
through them to the group for their final
approval.

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Do you remember who you would send it
Q
to?
A I sent it back to my staff person.
Q Who was that staff person?
A Stacy Osburn.
Q Do you know who she was seeking the
information from in the group, within the group?
THE WITNESS: Well, she sat in on some of
the discussions, so I would assume that it
would be with the -- with the working group
leadership.
Q Was there a timeline that you're aware
of as far as when that working group was
supposed to reach its findings and implement
potential changes?
A I am not aware of a concrete date. I
know that the expectation was that it would be
wrapped up, I believe, within 24 months, but I
wasn't -- I am not aware of the specific date.
Q Do you know what the actual timeline
turned out to be?
A It was -- I think it was somewhere
around three years, I believe.
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Q Before they completed all their work?
A I believe so.
Q Was this working group doing its work
during the time of -- during the time of the
Penn State infractions and investigation and
subsequent sanctions?
THE WITNESS: I believe so.
Q Do you know if the Penn State situation
affected the working group in any way?
THE WITNESS: Can you be...
BY MR. SEIBERLING:
Q Did the Penn State investigation, the
Freeh Report, the subsequent consent decree, did
that have any impact on the working group
related to the potential changes with regard to
the enforcement process?
THE WITNESS: I don't believe so.
BY MR. SEIBERLING:
Q Is there anyone else other than you or
your communications department that puts out
press releases or responds to press inquiries?
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THE WITNESS: I don't understand the
question.
Q Is everything funneled -- every media
inquiry or press release, funneled through your
department or are there other -A You mean as it relates to the NCAA?
Q Yes.
A Yes. It all funnels through my group.
Q Does President Emmert make statements
that don't first get run by you or your
department?
THE WITNESS: Well, he has made public
statements; for instance, if he is giving a
speech somewhere and someone will ask him
questions, generally, I am with him.
Q What about Donald Remy?
THE WITNESS: What about him?
Q Is Donald Remy authorized to make
statements on behalf of the -- on behalf of the
NCAA without first running it through the
communications department or by you?
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A No.
Q We will turn now to the specifics of
Penn State.
When did you first learn of the Sandusky
indictment and issues surrounding Jerry
Sandusky?
A I first learned about it on the morning
that the indictment was released.
Q And how did you learn about it?
A Well, I had just landed -- I had just
landed in Alabama and turned my phone on, and my
phone started blowing up with messages.
Q From the media?
A From the media.
Q Asking?
A Asking what our reaction -- what the
NCAA reaction was to the indictment.
Q What was the NCAA's reaction?
MR. KOWALSKI: Are you asking for what the
NCAA's statement was?
Q Well, at that time, what was your
reaction?
A My personal reaction?
Q Yes.

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A My personal reaction after reading the
indictment was that I was stunned and sickened.
Q Did you share that with anyone else?
A I might have.
Q I'm sorry?
A I might have.
Q With whom within the NCAA?
A Clearly, my staff, because they were all
reading the same thing.
Q Did the NCAA release a formal statement
in response to the Sandusky indictment?
A Yes.
Q Did you draft that response?
A Yes.
Q Do you remember what the response said?
A It essentially, in general terms, talked
about the indictment and how troubling the
information in the indictment was, and that we
would be working with the school to determine
the next steps.
MR. SEIBERLING: I'm showing the witness
Exhibit Number 1.
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BY MR. SEIBERLING:
Q Is this the statement that you drafted
and that was released by the NCAA?
A This is a statement that I drafted which
was attributed to Mark Emmert.
Q Why Mark Emmert and not the NCAA?
A Because many of the requests that were
coming in were requests coming for a statement
from the NCAA president.
Q Is that unusual?
A No.
Q If you read the first sentence of the
statement: "This is a criminal matter under
investigation by law enforcement authorities and
I will not comment on details."
At the time did you believe this was
purely a criminal matter?
THE WITNESS: Well, at the time -- at the
time, because there was an indictment, it was
obviously a criminal matter.
Q Did Mark Emmert review and approve the
statement?
A Yes.
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Q At the time the statement was drafted,
was there any considerations of potential
enforcement action against Penn State?
MR. KOWALSKI: Objection to form. Don't
reveal any privileged communications in
answering.
THE WITNESS: Can you restate?
BY MR. SEIBERLING:
Q As of the date of this statement, which
was November 7, 2011, did you personally believe
there could have been or should have been an
enforcement action commenced against Penn State?
THE WITNESS: I didn't have an opinion one
way or the other because I didn't have details.
BY MR. SEIBERLING:
Q Did you receive any media inquiries
following the release of this statement asking
whether an enforcement action was going to be
commenced against Penn State?
A Yes.
Q What was your response to those
questions?
A My response was that we don't comment on
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potential investigative actions.
Q Is that the normal boilerplate response?
A Yes.
Q Around this time, were you aware of
President Emmert doing an interview with ESPN?
A I don't recall the specific interview,
but we do interviews all the time.
Q Do you remember accompanying him to an
interview with ESPN?
A Around this time?
Q Yes. Around the first, second week of
November 2011.
A I don't specifically remember that;
however, I believe that ESPN was covering one of
the games that he and I attended, and we had
talked to couple of their on-air talent.
MR. SEIBERLING: I am showing the witness
Exhibit Number 2.
BY MR. SEIBERLING:
Q This is an e-mail from you to Mark
Emmert, Jim Isch, Wally Renfro, David Berst,
Donald Remy dated November 10, 2011.

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Do you recognize this e-mail?
A Yes.
Q Do you remember sending this e-mail?
A I don't remember it specifically.
Q After looking at this e-mail, do you now
remember the conversation that Mr. -- or Dr.
Emmert had with SportsCenter?
A Yes. This was actually a -- this was
actually a live remote that we did from
Indianapolis.
Q You were with Dr. Emmert at the time?
A Yes.
Q You helped Dr. Emmert prepare for this
interview?
A Yes.
Q Do you normally help Dr. Emmert prepare
for interviews?
A Yes.
Q And how do you do that?
A Basically go over, first of all, what
his main speaking points are; and then,
secondly -Q Do you draft up those speaking points?
A Generally.
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Then review any anticipated questions he
may have.
Q Is anyone else involved, typically, in
that process?
A It depends on the subject matter.
Q Anyone outside of your communications?
A Yes. It depends on the subject matter.
Q If you can flip to the second page.
There was a question Dr. Emmert was asked.
Quote, "What is the role of the NCAA?"
And Dr. Emmert responds, "Well, we, of
course, don't get involved in criminal
investigations and we will let the criminal
investigation go forward until all the facts are
established, and then we will do an inquiry to
see what actions should be determined. But
certainly it is such a shocking matter that we
need to determine what our course of action is
here."
Do you remember Dr. Emmert making that
statement?
A I don't specifically remember it.
Q Do you remember advising Dr. Emmert on
how to answer a question such as that?
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A We had talked about the dynamics of a
criminal investigation and the fact that we
wouldn't -- we wouldn't get involved in the
middle of a criminal investigation.
Q So as of this point you -- I guess it
would be November 10, 2011 -- you viewed the
Sandusky matter as a purely criminal matter?
THE WITNESS: Well, there was an
indictment issued for Mr. Sandusky, so that is
all the information that we had.
Q I will show you Exhibit Number 3.
BY MR. SEIBERLING:
Q It's a couple days later. It is an
e-mail from Mark Emmert to Diane Young, Jim
Isch, David Berst, Wally Renfro, you, Julie Roe,
Donald Remy. Subject, quote, "Meeting
tomorrow."
Text reads: "Diane, I want a meeting
with the above folks tomorrow. Reschedule
as-needed to discuss Penn State. Need an hour.
Add Kevin as well."
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Do you remember receiving this e-mail?
A No.
Q After reading it now, do you remember
receiving it?
A I mean, I see that I'm there. I don't
recall the specific e-mail. I get hundreds of
them a day.
Q Do you remember attending this meeting
that Dr. Emmert scheduled?
A Not specifically.
Q Do you remember attending a meeting
around this time period about to -- quote, "to
discuss Penn State"?
A There were several meetings over the
course of the first couple weeks following the
release, and I have no reason to believe that I
didn't, but I just don't remember this specific.
Q So we will try to discuss some of those
meetings to the extent possible.
Generally, during those meetings, what
were the topic areas?
A The topic areas were -- seemed like
every day there was new information coming out
on Penn State, so it was primarily for everyone

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to compare the information that they had and
what they had heard.
At some point there was a discussion
about what the NCAA's role in any type of
investigation into Penn State would be or could
be.
Q Can you elaborate on that without
revealing discussions between you -MR. KOWALSKI: To the extent you remember,
you can elaborate, but you can't reveal
communications that -- with Donald Remy in the
context. I know he was part of this meeting.
THE WITNESS: He was part of all the
meetings.
MR. KOWALSKI: Right. So if there are
parts of that meeting where you're discussing
it with other people, those issues are being
discussed that are not directed at Donald for
the purpose of him providing you with legal
advice, you can discuss that, if it is possible
to even separate all that out.
THE WITNESS: I don't know how I could.
BY MR. SEIBERLING:
Q Unless Donald Remy -- unless you were
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specifically talking to Donald Remy and saying,
"What do you think of this," or he was telling
you, "No, we shouldn't do that, because of this
legal issue," that is the only privilege
context.
So if you were talking to David Berst
about an issue, say, David Berst was raising the
jurisdictional issue, that is not privileged
because you were talking with him, not -without Donald Remy being involved.
So what discussions were you having
during this time period with individuals other
than Donald Remy?
MR. KOWALSKI: Before you answer, I just
want to make clear that we will provide you
with the advice what's privileged and what's
not privileged. They have their own view about
that, but we'll tell you when there's something
privileged and we'll instruct you whether or
not to answer.
Q He will instruct you not to answer. But
at this point, you need to answer as the best
you can to discussions you had with anyone but
Donald Remy.
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A Well, my discussions were actually
limited because I, essentially, was in an
observing mode. And on occasion, I would advise
the group in terms of what was being said in the
media, and by others about the NCAA and about
this investigation.
Q So we will -- there is a list here on
this 11/15/11 e-mail. We will walk through and
ask.
So what was Jim Isch saying on the issue
of Penn State?
A I don't recall.
Q You don't recall anything that Jim Isch
said?
A No.
Q What was David Berst saying?
MR. KOWALSKI: Can you ask him if he
recalls what David Berst's position was on the
issue of Penn State -Q What was David Berst's position?
MR. KOWALSKI: -- communications?
If you recall.
THE WITNESS: I recall David Berst kind of
talking about the historical role that
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enforcement played in investigations.
Q And what was that? What was that
historical role?
A The historical role were kind of the
typical circumstance where someone would assert
a violation, enforcement would follow up on that
assertion, and then determine whether or not
there was enough evidence to go forward with an
actual investigation and formally launch an
investigation.
Q Did David Berst believe that the NCAA
did not have jurisdiction over this matter?
A I really don't know what David believed.
I know that he had discussed -- he had discussed
that this circumstance didn't fall into the
typical NCAA enforcement action. But what he
believed, I don't know.
Q So he was voicing his opinion that it
did not fall into the normal enforcement
process?
A He was questioning whether it did or
not.
Q Were others questioning?
MR. KOWALSKI: Again, not revealing --

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MR. SEIBERLING: Stop the speaking
objections, please.
MR. KOWALSKI: That is not a speaking
objection. It's privileged.
MR. SEIBERLING: Stop coaching the
witness. Stop directing the witness how to
answer.
MR. KOWALSKI: No, actually, what I am
doing, Mark -MR. SEIBERLING: Then say "objection."
MR. KOWALSKI: Mark, I am trying to help
facilitate the questions you're asking, which
are imprecise in seeking information that's
privileged.
If you want to ask a precise question,
then I won't need to help and be so careful
about this.
MR. SEIBERLING: Just because Donald Remy
was present doesn't make it privileged.
MR. KOWALSKI: We are not here to accept
your positions on privilege, Mark.
MR. SEIBERLING: We already have a motion
drafted up on this.
MR. KOWALSKI: That's fine.
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MR. SEIBERLING: And if you keep coaching
the witness and directing him just because
Donald Remy is present, "You've got to be
careful how you answer. You can't say anything
that Donald Remy said." That does not make it
privileged. It has to be for the purposes of
providing or soliciting legal advice.
Just sitting around the table talking
about issues is not a privileged
communication.
MR. KOWALSKI: First of all, you're
barking up the wrong tree, Mark, because we
have our position and we're not going relent on
our privilege position simply because you take
a different view.
MR. SEIBERLING: We are going to have to
file a motion.
I am going to put on the record now
because Counsel keeps directing the witness
to not answer questions related to
conversations in which Donald Remy was merely
present, we are going to file a motion with
the Court.
MR. KOWALSKI: Look, I think the
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transcript will speak for itself about what
I've been doing. I have not directed the
witness not to answer questions.
What I am trying to ensure is that the
witness does not reveal privileged
communications in answering the question.
And there is two levels to that, Mark.
The first is: Did this communication
involve Mr. Remy? If we establish that, then
we have to deal with the second piece, which
is whether he thinks the -- he understands
that the communication was for the purpose of
providing a -- receiving legal advice, or
otherwise attorney work product. We need to
deal with this one step at a time.
MR. SEIBERLING: I asked the witness what
was David Berst's position on Penn State.
Whether or not Donald -MR. KOWALSKI: He answered the question.
MR. SEIBERLING: I was moving along to the
next person and you're objecting.
If I asked the question, just because
Donald Remy is present doesn't make it
privileged. If Donald -- if David Berst is
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giving his position and Donald Remy is
sitting there, David Berst's position
statement is not privileged.
MR. KOWALSKI: That is why he answered the
question. That is why he answered the
question, Mark.
BY MR. SEIBERLING:
Q Can you please restate David Berst's
position?
MR. KOWALSKI: I think he answered
already.
MR. SEIBERLING: That's fine if he
answered it. I'm asking him to state it again.
THE WITNESS: David Berst's position was
that he wasn't sure whether this particular
circumstance with Penn State fell into the same
category as the traditional or typical
enforcement actions.
Q And then I asked: Did others agree with
his position?
MR. SEIBERLING: Simply stating agreement
with someone else's position is not a
privileged statement, especially when it is a
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MR. KOWALSKI: First of all, other than
Donald Remy, go ahead and answer the question.
THE WITNESS: There were others who also
were not sure that this fell into the typical
enforcement action.
BY MR. SEIBERLING:
Q And who were those individuals?
A Best I can recall, it was David Berst,
Julie Roe.
Q What was Julie Roe's position?
A Julie Roe's position was that she didn't
see where this was -- where this did fall into
the category of a typical or traditional
enforcement action.
Q What was her actual named position at
the NCAA?
A You mean what was her job?
Q Her job title.
A She was vice president of enforcement.
Q So the vice president of enforcement
didn't believe that this was a typical
enforcement matter?
THE WITNESS: Correct.
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Q Did anyone else agree with either Julie
Roe or David Berst's position?
A Not that I recall.
Q Did you agree with their position?
THE WITNESS: Well, I didn't -- I believe
at the time I didn't have enough information to
have an opinion one way or the other.
Q Did anyone voice opposition to their
positions?
A To their positions?
Q Yes. Other than Donald Remy.
A I don't know that I could clarify it as
"opposition." There was discussion about those
positions. I couldn't characterize it as either
opposition or support either way.
Q Then can you characterize what was the
opposing or the other positions?
A Well, the other positions centered
around the NCAA constitution as it relates to
integrity of the athletics department as well as
institutional oversight.
Q So did others view as a potential -- did
others view it as a potential enforcement
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matter?
A Well, I don't know that there was a
specific discussion where it was characterized
as enforcement matter as much as a discussion as
to whether or not the NCAA constitution may have
been violated.
Q Did others believe that the NCAA should
take action in response to the Sandusky
indictment?
A Others believed that the NCAA should
look into it and determine whether or not
actions should be taken or not.
Q What was President Emmert's position?
A President Emmert's position was that
there was ample evidence that would -- that
should require the NCAA to look into the events
surrounding Mr. Sandusky's actions and the
school's response to it.
Q Was a decision made on what action
should be taken?
A Then?
Q Around this time period.
A No.
Q Was a decision made to send a letter to
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Penn State?
A I am not sure it was in this meeting,
but around that time, yes.
Q You said earlier there was a number of
meetings, so we will assume there was a number
of meetings, whether it was this one or other
ones. But there was a decision, then, to send a
letter to Penn State?
A Correct.
Q Whose idea was it to send a letter to
Penn State?
A I don't recall.
Q Do you know who drafted up that letter?
A No.
Q Did you ever see the letter?
A Yes.
Q You reviewed the letter?
A Yes.
BY MR. SEIBERLING:
Q Exhibit Number 4. Is this a copy of the
letter that was sent to Penn State?
A Yes.

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Q What was the purpose of this letter?
A The purpose of this letter was to
provide notice to Penn State that -- that the
NCAA would be seeking their answers, as it
relates to Mr. Sandusky, and the school's
actions related to Mr. Sandusky in four
different areas.
Q Did Penn State respond to this letter?
A I believe that President Erickson and
President Emmert had a conversation several
days, if not a week, after the letter was sent
regarding Penn State and how they would proceed
on both conducting an independent investigation
and subsequently addressing these four question
areas.
Q And who told you that?
A President Emmert.
Q Were you aware of any discussions with
the Freeh Group who would be performing the
investigation?
A Discussions between who?
Q Between either employees from the NCAA
and/or the Freeh Group.
A No.
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Q Were you part of any discussions with
the Freeh Group?
A No.
Q Were you part of any meetings with the
Freeh Group during its investigation?
A No.
Q Do you know of others at the NCAA being
involved in meetings with the Freeh Group during
its investigation?
A No.
Q Do you know of anyone receiving updates
from the Freeh Group about its investigation at
the NCAA?
A No.
Q Exhibit Number 5. It's an invitation
for a conference call. If you take a look at
the subject line, the first part reads, quote,
"12 PT conference call to discuss Penn State".
This conference call would have been
November 22nd, 2011. Do you remember attending
a conference call after the letter was sent to
Penn State?
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A Not specifically.
Q Any idea what would have been discussed
with regard to Penn State after the letter had
been sent?
A No.
Q The second part of that reads, "Part 2
of call, John Nichols/COIA discussion after Penn
State call".
Do you know who John Nichols is?
A No.
Q Do you know that he is a professor at
Penn State?
A No.
Q Did you know he is -- at this time he
was the head of the committee on infractions for
the NCAA?
A No.
Q Were you part of the call about the
discussion with -- about, quote, "John
Nichols/COIA"?
A I don't recall it.
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BY MR. SEIBERLING:
Q I marked Exhibit 6. This is an e-mail
from Diane Young. Diane Young is Dr. Emmert's
secretary, is that correct?
A She was his scheduler.
Q It's from Diane Young to Bob Williams,
subject "12:00 p.m. eastern call with Curtis
Eichelberger, Bloomberg News".
The text reads "Hi, Bob. In light of
the most recent child molestation allegations
involving Bobby Dodd, I have been asked to write
a story that shows how the world of sports is
examining the issue of child sexual abuse via
athletics participation. Are athletic directors
reviewing procedures with coaches on who can
meet with young athletes in non-profits, or what
the procedures are for screening coaches, or for
allowing children to be brought to university
facilities outside of activities they are
involved in.
I would like to know if the NCAA is
forming any committees to discuss or review, and
if Mark is available to talk about what should
be done from a collegiate perspective. I am not

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sure where the line is between this being a
school issue or an NCAA issue, or whether the
NCAA simply has a leadership role to encourage
and help organize some discussion or
guidelines".
Do you remember having this call?
A I don't recall it, no.
Q Do you remember talking with a reporter
about whether the, quote, "NCAA is forming any
committees to discuss or review, and if Mark is
available to talk about what should be done from
a collegiate perspective"?
A I don't specifically remember this
conversation, no. We were receiving probably 20
or 30 requests a day.
Q You mentioned you were receiving 20 or
30 requests a day. What was the general
response into inquiries about Penn State during
this time, during what would have been November
into December 2011 period?
THE WITNESS: Basically our standard
response was that we don't discuss pending
potential or future investigations.
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MR. KOWALSKI: We are going to need a
break here in a moment. So I don't know if
this is a good spot.
MR. SEIBERLING: Let's just do this one
real quick.
Q This is Exhibit 7. This is an e-mail,
initially from you on June 11, 2012, and it is
regarding a report "Spanier to face charges?"
Do you remember sending this e-mail?
A Yes.
Q You sent it to -- forwarded it to Mark
Emmert, along with cc's to Jim Isch, Wally
Renfro and Donald Remy.
A Yes.
Q Was this the first you had heard about
Graham Spanier potentially being charged?
A Well, there were some rumors floating
around in the press prior.
Q Had you discussed that with anyone at
the NCAA other than Donald Remy?
A No.
Q Why did you forward this around to the
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others at the NCAA?
A Because Graham Spanier was a former
member of the Division I Board, was involved in
some of the governance reform efforts that was
happening at the NCAA. And it's an unusual
circumstance when a sitting university president
is up on charges.
Q Didn't he speak at the August 2011
retreat?
A He was a participant.
Q Was he a speaker?
A I don't recall specific speakers. It
was a big round table with probably 50 college
presidents.
Q At the time the Sandusky indictment came
down, were you aware of any discussions of
Spanier potentially being indicted at that time?
A Not that I was aware of, no.
Q The reason why I ask is, because Curley
and Schultz were also indicted at that same
time. You were not aware of any such
discussions?
A I hadn't heard anything.
Q Any reaction to Dr. Emmert's response of
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"my God"?
A No. Other than I would imagine it was
troubling to him that one of his former
presidential colleagues was indicted.
Q Were Dr. Emmert and Graham Spanier
friendly?
A I believe they had known each other for
a long time.
Q In a professional capacity?
A Yes.
Q Did you know Graham Spanier?
A I did.
Q For how long?
A Since the time he came on the Division I
Board, so probably three years or so.
Q So you knew him on a personal and
professional -A I knew him on a professional level. I
didn't know him on a personal level.
Q I assume you were equally shocked?
A Yes.
MR. SEIBERLING: Now is a good time.

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BY MR. SEIBERLING:
Q I am showing the witness Exhibit
Number 8.
When was the first that you learned of
the Sandusky verdict?
A Whenever it broke on the news.
Q Did the NCAA prepare a response to the
Sandusky verdict?
MR. KOWALSKI: A press response?
Q Press response. Press release,
statement.
A I don't recall.
Q Who is Stacey Osburn?
A Stacey Osburn is now our Director of
Media Relations.
Q If you turn to page 2 of the e-mail
chain, there is a June 23rd, 2012 e-mail from
Stacey Osburn. It states "I believe the AP
inquiry below is the first since last night's
verdict. It seems our previous statement still
stands".
And there is a statement below. Do you
remember that statement? The statement reads
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"The NCAA is actively collecting information
from the Penn State Special Committee
Investigative Council during its ongoing
investigation to determine our next steps.
Although this determination will aid in our
real-time review, once the council's work is
complete the university likely will need to
formally respond to the questions raised by
President Emmert. While we are actively
monitoring the various investigations, we will
not interfere with those efforts.
The NCAA will determine whether any
additional action is necessary on its part at
the appropriate time."
A Yes, I recall that.
Q Did you draft that statement?
A I don't believe I drafted it. I believe
that someone within our media relations staff
specifically drafted that.
Q It appears that that statement was
drafted before June 23rd, 2012, is that correct?
A That is correct.
Q Is that the statement the NCAA was using
between the time period of the letter being sent
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to Penn State and the Sandusky verdict?
A Yes.
Q Is this the statement you continued to
use after the Sandusky verdict came down?
A Yes.
Q If you look at the first page of that
e-mail chain there is an e-mail from you
June 23rd, 2012 at 12:32 p.m, "I agree, we will
withhold comment until if/when action is taken
by the NCAA".
Can you explain the statement?
A Yes. That was in response to Amy
Dunham's e-mail previously, that talked about
how others involved in the Penn State issue had
been commenting.
Q At the time you wrote that e-mail, were
you aware of the NCAA contemplating, quote,
"taking action by the NCAA?" Strike that. Bad
question.
Were you aware of -- at that time were
you aware of the NCAA contemplating taking
action against Penn State?
A I would not frame it as contemplating
taking action. It all goes back to that
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November letter in which President Emmert
outlined the four questions that needed to be
answered for the NCAA to determine its next
steps.
Q So in your view, the Freeh investigation
that was ongoing at this time was the NCAA
taking action?
A No.
Q Can you clarify, then, what you did
mean?
THE WITNESS: Exactly what I said.
Q Can you repeat it?
A That the NCAA was going to determine
what action, if they were to take action, and
what action that might be, after the independent
investigation was complete and Penn State
addressed the four questions.
Q When was the NCAA expecting the Freeh
investigation to be complete?
A I don't believe the NCAA knew when it
was going to be complete.
Q Did you know?
A No.

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Q Do you know if anyone else within the
NCAA knew when?
A No.
BY MR. SEIBERLING:
Q Exhibit Number 9. You are not on this
e-mail, but I just wanted to ask you about the
content of an e-mail on this chain.
If you look at the second e-mail from
the top, it is an e-mail from Shep Cooper to
Gene Marsh July 4, 2012. Do you know Shep
Cooper?
A Yes.
Q Who is Shep Cooper?
A I think he is a director within the
staff that supports the committee on
infractions.
Q Do you know who Gene Marsh is?
A Yes.
Q Who is Gene Marsh?
A Gene Marsh is an outside attorney who
represents several clients within
intercollegiate athletics.
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Q Did you know Gene Marsh when he worked
at the NCAA?
A I didn't know that Gene Marsh worked at
the NCAA.
Q So the only way you knew Gene Marsh was
being a lawyer who came before the NCAA?
A Correct.
Q In infractions matters?
A Uh-huh.
Q If you can look at the second e-mail, it
says, quote, "FWIW," which I understand is for
what it is worth. "I agree. However, the new
NCAA leadership is extremely image conscious and
if they can conclude that pursuing allegations
against PSU would enhance the association's
standing with the public, that infractions case
could follow.
I know that Mark Emmert had made
statements to the press indicating that he
thinks it could fall into some sort of lack of
institutional control case. Shooting roadkill
is an apt analogy".
Breaking that statement down, what are
your thoughts on the statement that the new NCAA
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leadership is extremely image conscious?
A I don't agree.
Q Why not?
A Well, I think that any member of
leadership, by nature of being a leader, has to
be image conscious to some degree. But I
disagree that they are extremely image
conscious. And I disagree with the assertion
that they would take action in this matter
simply to enhance the association's standing.
Q Was President Emmert any more image
conscious than prior leadership?
A I only have experience with one other
leader, and that is Myles Brand, and the answer
is no.
Q And you believe that pursuing
allegations against Penn State would not have
enhanced the association's standing with the
public?
THE WITNESS: I agree -- my position is
that I don't believe any action was taken
simply to do that.
Q Then why was action taken?
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A I believe action was taken because there
was clear evidence that the institution did not
exercise institutional control, and that lack of
institutional control led to young boys being
raped for over a period of 10 years.
Q Where would that evidence come from?
A The evidence came from both the -- what
had happened on the indictment, and what we
would find later was included in the Freeh
Report, which the university accepted.
Q Were you aware of Shep Cooper raising
these types of concerns with anyone within the
NCAA?
A No.
Q How about the next statement above from
Gene Marsh? Quote, "I know how they think they
are now, but they should leave this one alone".
Do you personally agree with that
statement?
THE WITNESS: Well, I don't know who he is
talking about specifically.
Q He is talking -A But it doesn't surprise me that an

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outside attorney would suggest that the NCAA
leave something alone.
Q The subject line is, quote, "Penn State
unlikely to face NCAA sanctions".
A Okay.
Q So you're basically saying he thinks the
NCAA should leave Penn State alone and not move
forward with sanctions?
THE WITNESS: As I said before, that
doesn't surprise me coming from outside
counsel.
Q This is Exhibit Number 10.
The first e-mail on the chain is an
e-mail July 10, 2012, from Donald Remy to Omar
McNeill from the Freeh Group.
Quote, "Omar, at the appropriate time
can you please send any information to me and
our Vice President for Communications Bob
Williams?"
A Okay.
Q Then the next e-mail you are copied on.
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It's from Omar McNeill to Donald Remy, cc'ed
you. Quote, "Donald, Please find the attached
information".
Do you remember receiving that e-mail?
A No.
Q Do you know who Omar McNeill is?
A No.
Q Did Donald Remy talk to you at all about
the e-mail he had sent to Omar McNeill?
Q Was he forwarding you anything related
to the Freeh Report?
THE WITNESS: I don't recall what was
forwarded to me. I have no idea, since I don't
see an attachment. I have no idea what it is.
Q If I told you the attachment was a press
release that the Freeh Report was going to be
released two days later, do you remember
receiving that?
A I don't remember it specifically, no.
Q Do you remember being -A I do remember -- I do remember a press
notice that announced the scheduled press
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conference.
Q That's what was attached?
A Yes.
Q Did you have any other conversations
with Omar McNeil?
A I don't believe -MR. KOWALSKI: Object to form.
THE WITNESS: I don't believe I ever had a
conversation with Omar.
Q Once you received that press notice of
the press release of the report coming on
July 12th, what did you do with it?
Q Did you circulate it internally?
A I don't remember.
Q Did you take any acts or steps in
preparation for the report to be released?
THE WITNESS: No.
Q Were you part of any meetings
internally, prior to the release of the Freeh
Report, to discuss the forthcoming Freeh Report?
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Q Do you remember any meetings to discuss
the content of the Freeh Report before it was
released?
THE WITNESS: No.
Q No, you don't remember or, no, there
were none?
A No, I don't remember.
Q Exhibit Number 11. This is another
e-mail of July 10, 2012. Do you remember
receiving this e-mail chain that was forwarded
to you from Donald Remy?
A Yes.
Q The text below reads, quote, "Please
find attached immediate advisory release at 3:00
p.m. today. As we discussed, please advise
proposed times for discussion after the report
is published".
So this would have been the media
advisory that you were talking about earlier?
A Yes. I would assume so.
Q Then there is an e-mail from you to Amy

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Dunham, Stacey Osburn, Emily Potter, Kayci
Woodley, quote, "FYI, Thursday is a go, Bob".
What did you mean by that?
A I meant that the Freeh Report would hold
their press conference on Thursday, as had been
reported in the media.
Q I assume Amy Dunham, Stacey Osburn,
Emily Potter, Kayci Woodley would have been a
part of your staff?
A Yes.
Q So was any preparation undertaken -- I
guess, explain what you mean by it's a go? Was
your staff going to be doing anything in
response?
A My staff was going to be watching the
press conference and taking notes on what was
said. The assumption was that the report would
be released at the same time. The media had
actually reported that it was an extensive
report. So we were looking at how we were going
to be able to review and digest that entire
report in as short of time as possible.
Q Were you receiving inquiries from the
media prior to the release of the Freeh Report
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about the Freeh Report?
A Yes.
Q And how were you responding to those
inquiries?
A We weren't.
Q Were you saying "no comment"?
A We were pointing them right back to the
Freeh Group.
Q Did the Freeh Group have a response?
A I don't know.
Q Was there any communications between
your group -- your communications group within
the NCAA and the communications people from the
Freeh Group?
THE WITNESS: No.
Q Exhibit Number 12. The first e-mail on
the chain at the very bottom, it looks like it's
from Dana Thomas. It states, quote, "Here is a
tweet Bob and I drafted. Keep in mind we are
working with limited characters here."
It says, quote, "with Freeh
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investigation complete, the NCAA is working with
PSU to examine issues surrounding institutional
control and ethics."
Do you remember discussing with Dana
Thomas that draft "tweet?"
A I don't recall it specifically, no.
Q Was your department, or you personally,
putting together potential responses to the
Freeh Report at this time?
THE WITNESS: This was on the 10th, was
it?
Q The 11th, which would have been a day
before.
A No.
Q No, you were not?
A No, we were not.
Q Can you jump up to the first e-mail?
A Okay.
Q It's an e-mail from you to Erik
Christianson, Stacey Osburn, Amy Dunham, quote,
"draft Freeh statement tweet." Text reads,
quote, "Actually the new statement does indicate
that we reiterated our request with them this
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week. Mark talked to President Erickson today.
Bob."
And then what follows: Quote,
"Statement by Bob Williams. Like everyone else,
we are reviewing the final report for the first
time today, as President Emmert wrote in his
November 17 letter, parenthesis, hyperlinked to
Penn State Rodney Erickson, and reiterated this
week, the university has four key questions
concerning compliance with institutional control
and ethics policies to which it now needs to
respond. Penn State's response to the letter
will inform our next steps, including whether or
not to take further action.
We expect Penn State's continued
cooperation or an examination of these issues."
Do you remember sending that e-mail?
A Yes.
Q So this e-mail was July 11th. This
would have been the day before the Freeh Report
was released.
A Correct.
Q Did you draft up this statement by Bob
Williams?

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A Yes.
Q The paragraph above that says that you
-- "Mark talked to President Erickson today".
A Uh-huh.
A I believe Mark did.
Q What did Mark say about his conversation
with president Erickson?
A That he had spoken with him, and the
expectation was that following the completion of
the investigation, that they would address the
four questions.
Q So your understanding was, is that once
the Freeh Report was released, Penn State would
then respond to the four questions outlined in
the November 2011 letter?
A Yes.
Q Was this statement by Bob Williams, the
quoted text, was that ever released or
circulated?
A I believe it was released.
Q As a media statement?
A Yes.
Q Was it released as a President Emmert
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statement or an NCAA statement?
A It was a statement -- I believe it was
released as a statement attributed to me.
Q Does that happen often?
A Yes.
Q Exhibit Number 13.
Q The first e-mail on this chain is a
July 12, 2012 e-mail from you to -- and it is
unclear who the recipients are, but the text
states, quote, "Posted this morning at 9:05.
Wally has a copy, Bob."
Was this concerning a copy of the Freeh
Report?
A I believe so.
Q You circulated it to others within NCAA?
A Yes.
Q Mark Emmert responds, looks like later
that morning, to you, Jim Isch, Donald Remy,
David Berst, Julie Roe, Kevin Lennon, Crissy
Schluep, "Let's begin the review immediately.
There is obviously much to digest and consider
in this."
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Did you review the Freeh Report at that
time?
A Yes.
Q Did you discuss the Freeh Report with
others after you reviewed it?
A I believe there was subsequent meetings
between the senior group on the Freeh Report.
Q Did those meetings include the people
who appear on the cc line? Jim Isch, Donald
Remy, David Berst Kevin Lennon, Crissy Schluep.
A Yes. I believe it was everyone,
excluding Crissy.
Q Including Mark Emmert?
A Right.
Q Do you know how many of those meetings
occurred following the Freeh Report?
A I don't remember.
Q There were multiple meetings?
A Multiple.
Q What were the general topic areas of
those meetings?
A Just, generally, the contents and the
contents of the report and the conclusions drawn
from the report.
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Q What were the -- what were your thoughts
on the Freeh Report?
A My thoughts on the Freeh Report were
that that whole circumstance at Penn State was
even more troubling than what I had ever
thought. And that there was ample evidence that
there were officials at Penn State who from,
what I considered a dereliction of duty, allowed
young boys to continued to be raped.
Q Did you believe action should be taken
against Penn State?
A Yes.
Q Did anyone believe action should not be
taken against Penn State at those meetings?
A I don't recall anyone voicing that no
action should be taken.
Q Did anyone question the ability or the
jurisdiction of the NCAA to take action against
Penn State?
MR. SEIBERLING: Other than Donald Remy?
That subject matter, as discussed at
these meetings at this point in time, is

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attorney-client privilege.
Q Did David Berst raise any concerns about
the jurisdiction or ability of the NCAA to take
action against Penn State?
MR. SEIBERLING: What David Berst said at
that meeting is not privileged.
MR. KOWALSKI: That is not true.
MR. SEIBERLING: It's not privileged.
MR. KOWALSKI: We talked about this
yesterday. Our position is that following the
release of the Freeh Report, the meetings that
took place were for the purpose of allowing
NCAA legal counsel to develop a legal position
with respect to the response to Penn State
following the release of the Freeh Report.
Those communications are absolutely
infused with legal concerns. The primary
purpose of those discussions is so that legal
counsel can provide legal advice, both in
crafting the correct response and strategy
and also advising executive committee on that
same issue. So those communications are
absolutely privileged.
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BY MR. SEIBERLING:
Q Mr. Williams, were you present at these
meetings?
A I was present at several meetings.
Q And your position is you're the Media
Communications Consultant, right?
THE WITNESS: Well, I attended in my
capacity as Vice President of Communications.
Yes.
Q So what you do is communicate to the
public on behalf of the NCAA?
A No. What I do -- well, in addition to
that, my primary role is to provide
communications advice and counsel to senior
leaders.
Q Why were you present at these meetings,
if they were about legal advice?
A Because -MR. KOWALSKI: Objection. Go ahead.
THE WITNESS: Because I would have to
ultimately frame the responses that would go to
the public, via the media, on why the NCAA took
action in this case.
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MR. SEIBERLING: When you have someone
attending the meetings, who then is taking
those meetings, taking them out to the public
to say what is going on with those meetings,
how are those meetings privileged? You have
someone sitting there who is taking what is
happening in those meetings and sending them
out to the public.
MR. KOWALSKI: Well, that is not his
testimony, Mark.
THE WITNESS: No. That is not what I
said.
BY MR. SEIBERLING:
Q So what exactly was your role in these
meetings?
A My role in the meetings was to clearly
understand, to observe and clearly understand
what the NCAA position was regarding action
taken against Penn State.
Q Was everything that occurred in these
meeting legal in nature?
MR. KOWALSKI: Objection. I don't think
the senior vice president of communications for
the NCAA is in a position to -- that's a legal
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conclusion, that he is not in a position to
answer.
You can ask Donald Remy that question.
MR. SEIBERLING: Are you directing the
witness not to answer questions related to any
meetings post the Freeh Report?
MR. KOWALSKI: What I'm directing the
witness not to answer is your questions about
specific communications that occurred at those
meetings.
BY MR. SEIBERLING:
Q So at these meetings, what were the
topic areas?
A The topic areas were the contents of the
Freeh Report, the conclusions that were
presented by the Freeh Report. And discussions
as to what degree those conclusions and evidence
presented in the Freeh Report demonstrated,
either did or did not demonstrate lack of
institutional control as it relates to Penn
State.
Q So were you discussing potential actions
to take against Penn State?
A No.

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Q Were you discussing a potential -- the
institution of a potential enforcement action
against Penn State?
MR. KOWALSKI: Objection. Can you ask
whether the topic -- the subject matter of
whether to institute a potential enforcement
action was discussed at the meeting? Or, I
don't know. I am just concerned that is
getting a little awfully detailed, and starting
to reveal potentially the contents of what the
communications were and not just the subject
matter.
Maybe you can ask the question again.
Now I've forgotten what you said exactly.
BY MR. SEIBERLING:
Q Did anyone at the meeting believe that a
enforcement action should be instituted against
Penn State?
MR. KOWALSKI: This is not revealing the
specific communications that occurred at the
meeting. Can you answer that question?
THE WITNESS: I think I need clarification
on what your definition of an enforcement
action is.
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Q Should it be referred to Julie Roe, the
enforcement group, to begin an investigation and
then refer it to the committee on infractions?
A I don't recall a discussion about that.
Q What, if any, actions against Penn State
were discussed?
MR. KOWALSKI: Can you repeat the
question?
Q What, if any, actions against Penn State
were discussed following the Freeh Report?
MR. KOWALSKI: I don't know how he answers
this question without revealing the contents of
privilege communications.
MR. SEIBERLING: So, are you directing him
not to answer?
MR. KOWALSKI: That specific question,
yes. The way you are asking it, yes. I think
there's ways to get at this information -BY MR. SEIBERLING:
Q Were potential penalties against Penn
State discussed?
A No.
Q No penalties?
A No specific potential penalties.
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Q Was the death penalty, the suspension of
play discussed?
A No. Because the group that met their
has no role whatsoever in determining penalties.
Q What group?
A The group at this meeting.
Q This wasn't a meeting?
A It's the meeting that you referred to.
Q Will you agree there was multiple
meetings between the time of the Freeh Report
being released and the consent decree being
signed?
A Yes.
Q Did you attend most if not all of those
meetings?
A Yes.
Q During those meetings, from the time
period between the Freeh Report, and the
execution of the consent decree, what penalties
were discussed as potentially being implemented
against Penn State?
MR. KOWALSKI: I think you can answer this
as to the penalties discussed at the executive
committee, these internal meetings, to the
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extent...
MR. SEIBERLING: We need this on the
record. You're directing him, as far as if it
was discussed during an internal meeting,
you're directing him not to answer?
MR. KOWALSKI: What specific penalties
were discussed or the topic?
MR. KOWALSKI: Specific penalties, yes.
MR. SEIBERLING: Specific penalties you're
saying he cannot answer, because that is
privileged?
MR. KOWALSKI: It's the content of
privileged communications being revealed, if he
answers the question.
BY MR. SEIBERLING:
Q What potential, if any, sanctions were
discussed involving Penn State at any of those
meetings? Between the time period of the Freeh
Report and the consent decree was 11 days.
A In any meeting?
Q In any meeting?
A That was held?
Q In any internal meeting that was held.

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MR. KOWALSKI: Were there any internal
meetings that did not involve Donald Remy that
you're aware of?
THE WITNESS: No.
BY MR. SEIBERLING:
Q During all of those meetings was Donald
Remy providing legal advice?
A Yes.
Q During every one of the meetings?
A Yes.
Q During the executive committee meetings
was he providing legal advice?
A Yes.
MR. SEIBERLING: Williams Exhibit
Number 14.
MR. KOWALSKI: I just want to make a note
for the record, Mark, that I think there are
ways that you can get in a lot of this
information, and I think you did get in a lot
of nonprivileged information yesterday, in
yesterday's deposition, that don't require you
to ask questions that call for the divulging of
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B. WILLIAMS
So I wanted that to be clear for the
record as well.
BY MR. SEIBERLING:
Q The e-mail in front of you now is a
July 12, 2012 e-mail from Ed Ray to Julie Roe,
cc'ed Jim Isch, and Mark Emmert, subject, quote,
"the sounds of silence".
You're not on this e-mail, but if you
look at the first page, it's a blacked-out page,
you were apparently forwarded this e-mail.
A Okay.
Q Do you remember seeing this e-mail?
A No.
Q Were you aware of Ed Ray raising issues
about, quote, "the sounds of silence"?
A No.
Q Were you aware of any of the membership
raising issues as far as the NCAA needing to do
something or act with regard to Penn State?
A Well, there were members who were
outraged at what they had heard in both the
indictment and then later with the Freeh Report,
and I remember seeing in open media several
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members saying that Penn State should be
punished.
Q Was Ed Ray one of those?
A I don't ever recall Ed Ray, no.
Q Ed Ray was at this time the chair of the
A Correct.
Q Was he in favor of the death penalty?
A I do recall one of the early executive
committee meetings where he voiced an opinion
that the death penalty should be considered.
Q Was that the minority view or the
majority view?
THE WITNESS: As I recall, the committee
was about split.
Q Was the president of Michigan State on
that committee?
A Yes. I am trying to remember. I
believe she was on the executive committee then.
Q And then she became the chair of the
A Correct.
Q Was she involved in those discussions?
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A To my recollection she recused herself.
Q She did recuse herself?
A To my recollection.
Q Because of a conflict?
A Right.
Q Do you know that for sure?
A That is what I remember. I believe -that was my understanding.
Q So someone raised a conflict issue?
A I believe she did.
Q Can I get your thoughts on the last
sentence of the first paragraph of that e-mail?
Quote, "If Penn State could have Louie Freeh
conduct an investigation over the last year, why
haven't we don't anything?"
asking why NCAA did not do its own
investigation?
A We had received media queries asking if
we would.
Q And what was your response to those
inquiries?
A Our response was that we were waiting on

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the completion of the Freeh Report to determine
what, if any, additional action we would take.
Q Did you get those same inquiries after
you received the Freeh Report?
A Yes. And our response was modified,
obviously, that we were in the process of
reviewing it.
Q Did your department, your communications
department ever provide a release or a statement
as to why ultimately the NCAA investigation was
never done?
MR. KOWALSKI: Objection form.
THE WITNESS: At the time the sanctions
were announced it was explained then through
both the statements and through the press
conference that since the university accepted
the Freeh Report and its findings in total, and
the university actually requested a speedy
resolution to this issue, that an additional
investigation was deemed not necessary.
Q Did the NCAA accept the Freeh Report as
true?
A Yes.
Q Who within the NCAA made that decision?
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A That would be the executive committee.
Q So was there a vote on that?
A I believe there was a vote. At the time
there were discussions on potential -- prior to
the discussion on potential penalties.
Q Did you believe the NCAA should have
conducted its own investigation?
A No.
Q Why not?
A Because basically the NCAA would not
have the degree of access that the Freeh Report
had.
Q Why not?
A That the Freeh investigation had.
Q Why not?
A Because the university basically opened
up its records, e-mails, several million pieces
of evidence, and that is a level of access that
the NCAA never gets.
Q Have you read or reviewed any of the
criticisms of the Freeh investigation?
A I have seen press reports.
Q What are your thoughts on the
criticisms?
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A My thoughts on the criticisms are that
it's just further evidence of the circumstance
and everything that was wrong in the environment
that allowed that to happen at Penn State from
the beginning. People refused to focus in on
what the real issue is.
The real issue is, how was this
individual allowed to abuse little boys for so
long, with individuals in the Penn State
leadership, at least tacitly knowing about it,
and not being stopped?
Q Did you have any issue with the
principals identified within the Freeh Report
not having been interviewed?
THE WITNESS: No.
Q Do you believe they should have been
interviewed?
A I don't know one way or the other why
they weren't. I suspect that they refused to
be. That was my assumption. I don't know
whether that is the case or not. But the
investigation went on without them.
Q In hindsight, do you believe the NCAA
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should have conducted its own investigation?
A No.
Q Why not?
A As I stated before, I don't believe the
NCAA would have gotten the access that was
granted for the Freeh Report. It would have
only -- it would only have delayed the matter
longer. And I don't believe that the outcome
would have been different.
Q Why couldn't the NCAA have asked for the
same level of access as the Freeh Report?
THE WITNESS: Because the NCAA's purview
only extends to athletics and the -- and
information solely related to athletics where
the Freeh Report had a much wider range of
access to information.
Q So then you agree the issues identified
in the Freeh Report are well beyond athletics?
THE WITNESS: My opinion is that what is
in the Freeh Report not only covers the lack of
institutional control exerted by athletics, but
also serious shortcomings across the

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university.
BY MR. SEIBERLING:
Q Does the NCAA have jurisdiction over
those matters that you just identified as being
beyond simply athletics?
THE WITNESS: The NCAA has jurisdiction
over institutional control as it relates to
athletics.
THE WITNESS: That means that the NCAA has
jurisdiction over any actions or lack of
actions that the university takes as it relates
to its athletic program, personnel and
facilities.
Q What does that mean "as it relates?"
THE WITNESS: I don't know how to be any
clearer.
Q Who decides how something relates to
athletics? Does it have to be direct,
tangential? How do you draw that line?
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THE WITNESS: Well, I don't know how I can
give one definition that would define it.
However, I would say that any circumstance
where young boys are raped in an athletics
facility by a member of the athletic staff
probably indicates a lack of institutional
control.
BY MR. SEIBERLING:
Q Was there anything stopping the NCAA
from asking the Freeh Group to provide its
documents, its findings, its supporting
materials to the NCAA if it wanted to conduct
its own investigation?
A I don't know.
Q Was that ever done?
A I don't know.
Q Around July 15th President Emmert
appeared on PBS. Tavis Smiley was the host.
A Yes.
Q Were you in attendance for that?
A Yes.
Q You accompanied President Emmert?
A Yes.
Q Do you remember what was discussed
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during that interview?
A Yes. As timing would have it, we had
had that interview set up for months to talk
about educational opportunities for minority
youth, and how athletics provides greater
access. And as timing would have it, that
wasn't the news of the day on July 15th.
Q Penn State came up during the interview?
A Correct.
Q Do you remember what President Emmert
generally said in response?
A He basically said that we were reviewing
the Freeh Report, and in the process of
determining what, if any, action would be taken.
Q Do you remember him mentioning the death
penalty?
A I remember him being asked about the
death penalty, yes.
Q And what was his response?
A I believe his response was that no
decisions were made on any potential penalties,
but nothing was off the table.
Q Then he made it clear that the death
penalty was on the table?
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THE WITNESS: The death penalty is always
on the table.
BY MR. SEIBERLING:
Q Under all circumstances?
A If it's warranted.
Q The death penalty doesn't just apply to
repeat offenders?
A No.
Q Is that your belief or the NCAA's
belief?
A That was my belief.
Q Was that matter discussed amongst the
NCAA?
THE WITNESS: It was discussed -- it was
discussed on the executive committee calls.
BY MR. SEIBERLING:
Q Were there individuals within the NCAA
who believed that it only applied to repeat
offenders?
A Well, there were individuals that stated
the one time it was applied, it was applied to a
repeat offender.

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Q And no other times?
A It had never been applied before.
Q Did you believe the death penalty was a
serious potential reality for Penn State?
THE WITNESS: I believed that -- that if
there were -- that of all of the cases that I
had witnessed over my nine years, that it
should be considered.
Q In this instance or in all instances?
A No, in the Penn State instance.
Q Why was it not ultimately imposed?
A Because the executive committee decided
not to impose it.
Q Would you have imposed the death penalty
if it was your decision?
THE WITNESS: I don't know. I would have
had to have thought about that long and hard.
Q Exhibit Number 15.
BY MR. SEIBERLING:
Q You are not on this e-mail. But I just
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want to ask you about content. It is a July 15,
2012 e-mail from Kevin Lennon to Julie Roe.
Julie Roe, subject, quote, "Confidential
checking in on PSU".
Julie Roe states, quote, "sending this
to you only to get a sense of how off I am at
what I see transpiring with our internal group.
I feel like it is a bit of a runaway train right
now and I am a bit concerned on a couple of
fronts".
MR. KOWALSKI: Objection. For the record,
I think you said Julie Roe wrote this e-mail.
MR. SEIBERLING: Sorry, it's Kevin Lennon
to Julie Roe. I had it backwards.
Q Any idea what Kevin Lennon was talking
about as far as what he saw, quote, "transpiring
with our internal group. I feel like it is a
bit of a runaway train right now"?
THE WITNESS: I don't know what internal
group he is referring to.
BY MR. SEIBERLING:
Q Were you not part of the internal group?
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THE WITNESS: I was -- I was a member of
senior staff. I don't know that that is what
he is referring to. Because there were -there was the internal group that was meeting
on enforcement, and rules and everything else.
So I am not sure what he is referring to.
Q Kevin Lennon is not part of enforcement,
right?
A No. But he was part of the rules
working group, which as I said before, I don't
know whether he is referring to that or what.
Q The meetings you were present at between
the time of the Freeh investigation, the Freeh
Group Report and the consent decree, were Kevin
Lennon and Julie Roe both present at those
meetings?
A Yes.
Q At all of those meetings?
A I would assume all of them. I don't
know.
Q At any of those meetings you attended,
were Kevin Lennon or Julie Roe voicing concerns
they had?
MR. KOWALSKI: Objection. Are we talking
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about, these are all meetings where Donald Remy
is present?
THE WITNESS: Yes.
MR. SEIBERLING: So how is what Julie Roe
and Kevin Lennon saying at the meeting
privileged? They are just voicing their
concerns?
Are you directing him not to answer that
question?
MR. SEIBERLING: What is the question?
MR. KOWALSKI: I don't know how he can
answer that without revealing the contents of
Q Can you briefly read points one, two,
three, four, five. Actually, it would probably
be easier -- we will walk through, one, two,
three, four, five.
Point number one states, "The more
penalties and sanctions placed on school
conference and other members, the less likely
they will agree. I know we are banking on the
fact school is so embarrassed that they will do

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anything, but I am not sure about that. I know
confidence -- conference or other members will
agree to any of that. This will force the
jurisdictional issue that we really don't have a
great answer to that one".
Was that subject matter discussed at any
of those meetings you were at between the time
of the Freeh Group investigation report being
released and the consent decree?
MR. KOWALSKI: Objection. While I
appreciate you trying to talk about subject
matter, this paragraph is very detailed, and is
not just the subject matter. If you're
discussing -- if you're asking about -Q Were you discussing penalties and
sanctions any time between the Freeh Group
Report, which was July 12, and this e-mail which
was July 15?
A No.
Q At none of those meetings?
A No.
Q Were you discussing this allegation that
quote, Penn State was so embarrassed they will
do anything? Did that come up at any of those
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meetings?
THE WITNESS: No.
Q Were jurisdictional issues discussed at
any of those meetings?
THE WITNESS: I do recall some discussion
on jurisdiction.
MR. SEIBERLING: I am quoting -MR. KOWALSKI: He can answer that.
BY MR. SEIBERLING:
Q You remember jurisdictional issues being
discussed?
A Yes. Yes.
Q Just generally, what were the
jurisdictional issues being discussed?
MR. KOWALSKI: I am not sure he can go
much farther. We can take a break and talk
about what his answer is to see what we can
provide to you that we don't think gets far
enough to be in the context of the privileged
communication. But I am not sure right now he
can go further.
MR. SEIBERLING: It is an e-mail from a
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nonlawyer to a nonlawyer.
MR. KOWALSKI: That's not your question,
Mark. You're asking him not about the
nonlawyer to nonlawyer. Hold on. I get to
talk for a second.
You're not asking about what this
nonlawyer to nonlawyer communication is.
You're asking about specific communications
in a meeting with legal counsel that had a
legal purpose.
So that is why you can't just say, well,
this is a nonlawyer to nonlawyer -- that
doesn't matter.
MR. SEIBERLING: I am asking about this
because this was a document -- our belief is
this is a documentation of what was happening
during those meetings and the issues that were
being raised and the responses that were being
made and the concerns that were being made.
MR. KOWALSKI: Mark, you just asked him
two questions about topics, whether they were
discussed at the meeting. And he said no and
no. I don't know what your basis is, but the
bottom line is we don't need to argue. This is
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our position. You guys will take whatever you
need -MR. SEIBERLING: I'm saying we're going to
move on. I will move on. We don't need to
take a break. We will move on.
MR. KOWALSKI: You're moving on without
exploring the maximum amount of information you
can get without invading the privilege.
BY MR. SEIBERLING:
Q Number two, "whatever action we take
against PSU will require us to answer the
immediate follow-up questions as to what this
means for the next case. Scope and reach of the
ethical dilemmas they will take many forms.
Don't we need to have an answer for this before
we do something with Penn State?"
At any of those meetings were you
discussing actions against Penn State?
A I need clarification. Are you talking
specific actions?
Q General actions.
A There was discussion as to whether or
not and to what degree the NCAA as a body could
take action against Penn State.

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Q Number three, "delicate issue. How did
PSU gain a competitive advantage by what
happened?"
During these meetings was there
discussion of how Penn State could have gained a
THE WITNESS: Not that I recall.
Q Number four, "as for idea to bring in
Judge Freeh I thought the key response from our
end is to wait to hear from PSU. I feel like to
do other otherwise with any action like this
will invite what else the NCAA is doing now.
Like, are you sending enforcement
representatives out, and if not, why not?"
First point: Was there a still -- was
NCAA -- were these internal groups still
discussing -- were they still discussing waiting
and hearing from Penn State to respond to the
four questions that were proposed?
question?
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MR. KOWALSKI: Hold on a second. You can
answer "yes" or "no," or I don't know.
THE WITNESS: Let me make sure.
MR. SEIBERLING: Stop coaching him.
You're telling him to answer "I don't know."
MR. KOWALSKI: That is absolutely not
true. You answer the question way you can.
What I am trying to say is I am trying
to protect the privilege that the NCAA
legitimately has here. And if he answers
further than that, I think we just need to
take it step by step. I am absolutely not
telling him how to answer the question
whatsoever.
THE WITNESS: Can I have the question
again?
MR. KOWALSKI: I don't appreciate you
accusing me of that, because you know that is
not true. We have been working very hard with
you for two days to get you the information you
need, Mark.
MR. SEIBERLING: I beg to differ. After
yesterday there was a lot of coaching going on.
We were trying to minimize that today.
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MR. KOWALSKI: I'd move to strike that.
It is completely inappropriate to make those
kind of accusations.
MR. SEIBERLING: You can strike it, but it
is what it is.
A I need the question again.
Q I will rephrase.
Was there a discussion of if and when
Penn State would respond to the four questions
that were proposed in the November 2011 letter?
A Yes.
Q Was NCAA expecting a response to those
four questions?
A Yes.
Q Was that response ever provided?
A Not formally in a letter.
Q How was it provided, if it was provided
at all?
A My understanding that it was provided in
a telephone conversation between President
Emmert and President Erickson, where president
Erickson basically said we accept what's in the
Freeh Report and -- and we agree that there was
a lack of institutional control. I wasn't part
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of that conversation, so I don't know that as
fact.
Q Who relayed that to you?
A It was I believe President Emmert.
Q Was anything else discussed during that
phone conversation?
A I don't know.
Q So there was no formal response, written
response to those four questions?
A Not that I could see.
Q Was NCAA expecting a written response?
THE WITNESS: Well, it was outlined in the
November letter. And from the time the Freeh
Report was issued forward we were waiting for a
response. My understanding is that response
came via a phone call.
Q The response was that the Freeh Report
answers those four questions?
A Yes.
Q Without getting into the specifics of
the questions?
THE WITNESS: Well, you know, in terms of

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-- I don't have the four questions in front of
me, but I believe one of them spoke to what the
institution planned on doing. So my assumption
would be that that was discussed in that phone
call as well.
Q President Erickson's statement on the
phone was sufficient for the NCAA in order to
respond to those four questions?
THE WITNESS: I would assume so.
Q Was that sufficient for you?
A Sure.
Q We had talked earlier about a statement
you had issued where you referenced the four
questions in Penn State's response. Were you
expecting a written response?
A I was expecting a written response until
I was told that the response came via this phone
call.
Q The first question, and I will read it.
Do you have...
MR. KOWALSKI: Which exhibit number?
Four? Question number one?
Q Question number one states, quote, "How
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is Penn State and/or its employees", sorry -strike that.
Quote, "How has Penn State or its
employees complied with the articles of the
constitution and bylaws that are cited in this
letter"?
A Okay.
Q Did the Freeh Report answer that
question?
A Well, I don't believe that the Freeh
Report did, but my assumption was that in the
conversation that was had between President
Emmert and President Erickson that that question
was answered. And my assumption was that the
answer was based on the Freeh Report they didn't
comply.
Q So Penn State just conceded the issue?
THE WITNESS: I would assume so.
Q Question number two, "How has Penn State
exercised institutional control over the issues
identified in and related to the Grand Jury
Report? Were there procedures in place that
were or were not followed? What are the
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institution's expectations in policies to
address the conduct that has been alleged in
this matter upon discovery by any party?"
Again, it was your understanding that
President Erickson responded to that question in
this phone call with Dr. Emmert?
A That was my understanding.
Q We don't have to go through the other
two, but it is your understanding the same
situation, that President Erickson addressed all
four of these issues in that phone call with
President Emmert?
A Yes. I would think it would be
difficult for him to refute at all that this
wasn't done.
Q Did Dr. Emmert relay this information to
the executive committee and the Division I Board
of Directors?
THE WITNESS: Dr. Emmert characterized his
discussions with President Erickson, yes.
Q Did he specifically address the four
questions with the board?
A I don't recall.
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Q If we can go back to 15. The number I
wanted to primarily ask you about is number
five. Quote, "I feel we have not spent enough
time on membership input, counsel reaction,
direction and spending more time on media
input."
Do you agree or disagree with that
statement?
THE WITNESS: I disagree. Because I don't
recall a lot of energy or time being spent on
media input as it relates to the decision.
Q So the meetings, the internal meetings
you were included in, which also, apparently
included, Julie Roe and Kevin Lennon, was there
a lot of discussion of media, either statements,
responses during those meetings?
A No.
Q Not at all?
THE WITNESS: Not any that I can recall.
Q So why were you included if it wasn't
for a media purpose?
A Because I am a member of the senior

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staff.
Q Did you believe the membership was being
fully informed on what was going on?
A What was going on with what?
Q With the internal meetings that were
occurring at NCAA.
A No. I didn't think there was a need.
Q Why not?
A Because membership isn't kept informed
on any type of sanctioning process.
Q Shouldn't they be?
THE WITNESS: No.
Q You serve the membership, isn't that
correct?
A We serve the membership, however, any
time you are in discussions about potential
sanctions there is confidentiality while those
discussions are happening. So once the decision
is made, then yes, membership is informed.
Q You're talking about the normal
committee on infractions process, right?
A I am talking about whatever we do, in
terms of eligibility decisions, reinstatement
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decisions.
Q So you don't go to the membership until
internally you have a final decision?
A We don't inform the membership of the
decision until the decision is made.
Q What role does the membership serve if
the decision has already been made?
THE WITNESS: Well, it's not a process
where a straw poll is taken on what decision to
make.
Q So the membership is not included in the
initial decision making process? Is that what
you're saying?
THE WITNESS: The membership provides
overall -- provides the overall construct for
how decisions will be made on both enforcement,
reinstatement actions, eligibility, all of
those issues.
When a specific case comes up that is
either being reviewed by staff or a member
committee, those discussions are not shared
with membership, or the public at all.
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Q Wouldn't you agree that this case and
the statements had been made repeatedly that it
was unprecedented, out of the ordinary? Would
you agree that that was the case with Penn
State?
A Yes.
Q If any situation likely required more
input from the membership, wouldn't this unusual
case have been that circumstance?
THE WITNESS: I don't agree with your
premise.
Q Why not?
A Because as I said before, when decisions
are made they are not made based on votes or
strawman polls or anything else.
The decisions are made based on what the
overall NCAA constitution says and what the
bylaws say, and then a decision is made. If
then membership doesn't agree with it, then they
can address it post, and there are avenues to do
that, in everything that we do.
Q Whose decision was it to impose
sanctions against Penn State?
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A The executive committee, who is
membership.
Q But you just said that the decision -the final decision is made and then presented to
the executive committee.
A No.
THE WITNESS: I did not say that.
Q Then you're going to have to clarify.
What was presented to the executive committee
with regard to Penn State?
question?
Q What was presented to the executive
committee with regard to Penn State?
THE WITNESS: The executive committee was
presented the wide range of options of actions
that they could take as it related to Penn
State.
Q Walk us through. What were those
options?
A Do nothing; conduct an NCAA
investigation; go down the route of the consent

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decree, and then they would have to determine
what sanctions, if any, were to be taken. The
NCAA staff does not determine that.
Q Who presented those options to the
A If I recall, it was Donald.
Q Not President Emmert?
A He was involved in the conversations as
well.
Q Why wasn't President Emmert presenting
the options?
A Well, as I recall, -MR. KOWALSKI: Go ahead.
THE WITNESS: As I recall, Donald was
walking through the range of potential actions
that could be taken in a case such as this.
President Emmert then provided his
input, and then the executive committee then
had a discussion amongst themselves about
what was appropriate and what wasn't.
Q Was President Emmert advocating for a
certain position?
A No.
Q Was Ed Ray?
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A Ed Ray initially was of the opinion that
the committee should seriously consider the
death penalty.
MR. KOWALSKI: Mark, I don't know how much
longer you have, but if we are close, we can
finish. If not, we should take a break.
MR. SEIBERLING: We are not close. We can
take a break.
BY MR. SEIBERLING:
Q I'm showing you Exhibit Number 16. The
first e-mail on the chain is an e-mail from Gene
Marsh to Donald Remy, David Berst dated July 17,
2012, subject, quote, "Update." Quote, "I am
getting calls from newspapers regarding Mark
Emmert's comments, which is totally expected. I
relayed the info from the call this morning."
That same day Donald Remy sends -forwards Gene Marsh's e-mail to Mark Emmert and
you, quote, "Please call me ASAP."
With regard to the first e-mail, do you
know what calls Gene Marsh was getting regarding
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Mark Emmert's comments?
A No.
Q This was following the PBS interview
that Mark Emmert had done, I believe, a day or
two earlier.
A Okay.
Q Were you receiving calls following Dr.
Emmert's appearance on PBS?
A I was receiving calls wanting Dr. Emmert
to be interviewed by other media sources.
Q Did you grant any interviews?
A No.
Q Why not?
A Because, I mean, we pretty much knew
what they wanted to talk about.
The PBS interview was set months in
advance and we were, more or less, obligated to
grant that interview. And we understood that
Tavis Smiley, the professional that he was, had
to ask the question regarding Penn State.
Q What did you believe that the other
media outlets wanted to talk about?
A Penn State.
Q What specifically with regard to Penn
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State?
A Whether or not we were going to take any
action or not.
Q The next e-mail is from Donald Remy
again to you and Mark Emmert stating, quote,
"Please call me ASAP."
Do you remember calling Donald Remy?
A Generally, when I get a message like
that from him like that I call him right away,
so, yes.
Q Do you remember the substance of the
call?
A No.
Q How often do you get e-mails from Donald
Remy saying to call you ASAP?
A Once a week. He gets about five from
me.
Q Do you always respond?
A Yes.
Q Does he always respond?
A Yes.
Q If we can, just one quick question back
on the prior e-mail. Were you handling any type
of responses on behalf of Gene Marsh?

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A No.
Q Gene Marsh and/or Penn State was doing
its own...
A Right.
Q Did you contact either the person or the
people that were contacting Gene Marsh to give
an NCAA response at all?
A No.
Q Exhibit 17. This is July 18, 2012
e-mail from you to Mark Emmert, amongst others.
Titled, quote, "Penn State, NCAA will have info
in days".
And the text says "FYI, the AP moved
this tonight." Do you remember forwarding this
AP story?
A Yes.
Q If you could briefly read this story. I
would just read the first page. That is really
what I was going to ask you about.
The last paragraph on the bottom of the
page states, quote -- this is a quote from
President Erickson from Penn State, quote, "The
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NCAA has indicated that they would like me to
respond as quickly as possible, now that we have
the Freeh Report, he said. So we've already
started the process of starting to depose that
response. We will do so over the course of the
next few days and get that response back as soon
as possible. And then we will engage in
discussions with the NCAA."
Is this the response that you were
talking about that President Emmert said he
received a call from President Erickson on the
four questions?
Q Is that -- do you know the context of
his statements here?
A Well, I think what's quoted here is
President Erickson said they were working on a
response, which I would assume would be a
written response, and that they expect it in a
couple of days. That is what it says.
Q But you don't -- you never saw or you
don't believe Penn State ever submitted a
written response?
A I do not recall a written response.
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Q Exhibit 18. This is an e-mail from Mark
Emmert to you dated July 18, 2012. The text
states "B, I know you are already thinking about
this, but we will need as well plan a media
strategy as soon as possible for the PSU case.
Please put together your ideas. Loop in Wally
and Crissy and let's be ready to discuss
tomorrow and/or Friday. Diane, make sure we get
some quality time".
A Yes.
Q Did you meet with President Emmert about
putting together a media plan?
A Yes.
Q And what did you discuss?
A We discussed logistically how we would
handle the release of information.
Q How logistically did you plan to handle
that?
A Well, what we decided upon was a live
press conference where President Ray and
President Emmert would discuss the process and
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the consent decree.
Q So as of July 18th there was at least
the structure of a consent decree in place?
A Well, there were discussions, as I
remember correctly.
Q Whose idea was the consent decree?
A I don't know.
Q So other than the press conference, what
other steps -- media steps did you take?
A Just logistically how we would handle
the intense media interest. We had some
concerns about whether our servers would be
robust enough to handle the demands placed upon
them. We had some logistical concerns about
things like if 100 media show up with satellite
trucks, where do we put them. Standard things
that you have to take in consideration whenever
you have an announcement of this magnitude.
Q As of this date, did you know when that
press conference was going to happen?
A No.
Q You didn't know it would be five days
later?
A No.

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Q Was that enough notice to put together a
press conference as you were talking about?
A Well, having done this for many years, I
have put together press conferences with a
couple hundred media in an hour, so it's not the
way I like to do it, but...
Q Would you have preferred more time?
A Yes, always.
Q Any other media actions that you
undertook?
A No.
Q At this time were you given a timeline
of when these actions should be completed?
A No. Other than I was told to have a
plan ready to go sooner rather than later.
Q How much advanced notice were you given
of the scheduled press conference?
A I think it was two days.
Q So the 21st?
A Yes. I think it was like Saturday when
things started coming together.
Q Who relayed that to you?
A Mark. And I was -- I had listened in on
the executive committee calls.
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Q Whose decision was it to have the press
conference two days later?
A What do you mean?
Q Who decided to have the press conference
on July 23rd?
A Well, that was driven by the signing of
the consent decree, and we understood that as
soon as that was signed it was essentially a
public document and word would get out.
Q Was the press conference contingent on
the execution of the consent decree?
THE WITNESS: I believe so.
Q So the press conference presumably would
not have happened on the 23rd if there wasn't a
signed consent decree?
A Yes, it was my understanding.
Q Was that told to you or was that just
your assumption?
A It was told to me.
Q By whom?
A Donald Remy.
Q Was there a concern that Penn State
wouldn't sign the consent decree?
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THE WITNESS: I wouldn't term it a
concern. It was a possibility. It was their
option.
Q Other than President Emmert, who else
did you consult within the NCAA about the media
plan?
THE WITNESS: There was discussions with
President Emmert, Donald Remy, Jim Isch, and
Wally Renfro.
Q Did you discuss the media plan with Ed
Ray at all?
A I believe President Emmert did, and then
I had a discussion with President Ray the
morning of the press conference.
Q Was the -- the media plan, was it a
written plan?
A It was a timeline that kind of outlined
when we had to have things in place, like
parking for the satellite trucks, chairs.
Q Did your media plan include the Big 10
Conference at all?
A No.
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Q Did it include Penn State at all?
A Not as far as our release, no. So the
Big 10 and Penn State were not participants in
that press conference.
Q Did you coordinate or even communicate
with the Big 10 or Penn State about...
A We let them know in terms of timing when
things were going to happen.
Q Did you review any statement that Penn
State was going to release?
A I believe they sent me a draft statement
of what they were going to say following the
press conference.
Q Why?
A Just out of courtesy.
Q Did you ask for it?
A I don't remember asking for it.
Q Did anyone within the NCAA ask for it or
ask that it be sent to you?
A I don't recall.
Q Did you make any edits to the statement?
A No.

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Q Exhibit Number 19. The first e-mail on
the chain is an e-mail from Gene Marsh to Donald
Remy and David Berst dated July 19, 2012,
subject, quote, "update." Text reads, quote, "I
hope that when this thing gets to a public
announcement Mark Emmert will clearly describe
the strength of feeling on the board regarding
the possible application of the death penalty,
et cetera, and point out that the actions of
Penn State in hiring Freeh and on the corrective
side were fully considered along with some of
the other factors we discussed.
In bringing the community along in
buying into this way beyond Penn State, folks
need to have that understanding. And the folks
who are trying to do things right deserve and
are due that clear explanation".
Gene Marsh's e-mail was then forwarded
to you, what appears to be the next morning,
along with Mark Emmert by Donald Remy, with the
text, quote, "FYI."
Why was Donald Remy forwarding you this
e-mail?
A Because it contained an opinion on the
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public announcement from Gene Marsh.
Q Did the public announcement include a
description that, quote, "the strength of
feeling on the board regarding the possible
application of the death penalty?"
A I don't believe the public announcement
did. I think it came up in the question and
answers.
Q Was it intentionally excluded from the
public announcement?
A I don't know that it was intentionally
excluded. I don't believe it was part of the
public announcement, because, generally, in any
type of public announcement we don't discuss
what we didn't decide.
Q Was there a decision by you or anyone
else not to include it in the public
announcement?
A I guess you would consider it was a
decision by me not to include it in the
statement, because typically we don't discuss
actions that we don't take. We only discuss
actions that we do take.
I will also note that, Donald put "for
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your information," not for your action, so I
took it as information.
Q So you were the ultimate decision maker
on whether to include it or not?
A Well, I drafted the statement that was
used. In this case President Emmert or
President Ray could have altered it in any way
they saw fit.
Q Gene Marsh might have thought it was
important but you didn't?
A Well, Gene Marsh represents his client
and look at things through his client's
perspective. I don't necessarily do that. I
look at it through the NCAA's perspective.
Q What is the view of Gene Marsh
internally at the NCAA?
THE WITNESS: I don't know how to answer
that.
Q Is he fair? Does he do the best for his
clients before the NCAA?
A Yes. I think he is viewed as a highly
competent counsel.
Q Have you interacted personally with him?
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A I have had conversations with him.
Q Related to Penn State?
A Not related to Penn State.
Q Around this time period of Penn State,
do you know, was Gene Marsh representing other
institutional clients before the NCAA?
A I don't know.
Q Were you aware of two executive
committee meetings, one was on July 17, the
other one was on July 21st, 2012?
THE WITNESS: I don't recall specific
dates.
Q Do you remember attending two executive
committee meetings regarding Penn State?
A I remember dialing into a teleconference
on two occasions, yes.
Q Did you have any role in those meetings?
Did you speak?
A I did not.
Q Do you know who led those meetings?
A They were led by the chairman, President
Ray.
Q Anyone from the NCAA lead the

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discussion?
THE WITNESS: Chairman Ray led the
discussion. There were individuals from the
NCAA who participated.
Q On the 21st meeting, the committee voted
on action, is that correct?
A I am trying to get my dates.
THE WITNESS: What was the date?
Q I can show you.
A If you tell me what day of the week, I
can probably recall.
MR. SEIBERLING: We will mark as
Exhibit 20, both of them are committee meeting
minutes.
BY MR. SEIBERLING:
Q Do these minutes refresh your
recollection?
A Yes.
Q Do you remember the vote set forth on
those meeting minutes being conducted?
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A Yes.
Q If you read one, two, three, the fourth
paragraph, quote, "to authorize the NCAA
president to enter into the consent decree with
Pennsylvania State University".
A These are two different documents.
Q I was going to ask the witness that.
MR. KOWALSKI: Sure, but for purposes of
your question, which one do you want to start
with?
MR. VOSS: If we can have the 75 and 76,
we will mark that as Exhibit 21.
MR. KOWALSKI: We will start with Exhibit
20.
MR. SEIBERLING: What does 20 begin with?
MR. KOWALSKI: 13071.
Q The fourth paragraph in the
informational item section.
A Okay.
Q "This is a vote, quote, to authorize the
NCAA president to enter into a consent decree
with the Pennsylvania State University and
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undertake any related activities in furtherance
thereof including the execution of an athletic
integrity agreement memorializing the
institution's commitments".
Is that correct?
A That is correct.
Q You were present for this vote?
A That is correct.
Q If you look at the first exhibit it
notes the vote as being 10/4, zero against, zero
abstentions. Then the next exhibit notes a 12/0
vote. Do you know which is accurate?
THE WITNESS: No.
Q Do you know why there is an
inconsistency?
THE WITNESS: I have no idea.
Q Was the vote unanimous?
A It was.
Q How many members of executive committee
are there?
A I believe there are 16.
Q So all 16 were not present?
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A That is correct.
Q You mentioned earlier that the president
of Michigan State had recused herself.
A Correct.
Q Anywhere on these minutes is that
reflected?
THE WITNESS: I don't see it.
Q In fact, the one exhibit notes zero
abstentions, is that correct?
A That is correct.
Q Of these two do you know which one is
correct?
A I don't.
Q During this meeting was other action in
addition to the consent decree presented to the
board?
Q Did you review the consent decree?
THE WITNESS: I believe I did have a
chance to look at it.
Q Did you revise or edit the consent

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decree?
A No.
Q Who were the consent decree -- who were
involved in the consent decree negotiations?
A I believe it was Donald Remy, and
President Emmert, and President Erickson.
Q Did President Emmert talk to you about
the negotiations at all?
A No.
Q Did Donald Remy?
A No.
Q Did the consent decree involve
negotiation at all?
A I don't know.
Q Was it presented to Penn State as a take
it or leave it?
THE WITNESS: Well, I'm not sure what that
means, but...
Q Was Penn State provided the opportunity
to change terms of the consent decree?
THE WITNESS: I don't -- I don't know. I
believe that they had the option of either
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accepting it or not.
Q They were the two options?
A That's my understanding.
Q Accept it as drafted?
THE WITNESS: That is my understanding.
BY MR. SEIBERLING:
Q Do you know if Penn State sought to
change or alter any of the terms?
Q Do you know who executed the consent
decree on behalf of Penn State?
A No.
Q Do you know if the consent decree was
approved by the Penn State board of trustees?
A It is my understanding that it was
approved by the board of trustees' executive
committee.
A President Emmert.
Q When did he tell you that?
A When that executive board met and
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approved the adoption of the consent decree,
which I believe was either Saturday or Sunday.
Q Did you believe that's all that was
necessary?
THE WITNESS: Yes.
Q Did President Emmert believe that's all
that was necessary?
THE WITNESS: Yes.
Q Did you receive media inquiries asking
whether the full board of Penn State should have
approved the consent decree?
regarding board approval by Penn State?
A No.
Q None?
A Not that I recall. I mean, we were
receiving somewhere along the lines of 80 to 100
media inquiries a day.
Q Exhibit 22. This is a long one.
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Q Once you've had a chance to review the
chain, let me know. You can read from the
beginning and go forward.
MR. KOWALSKI: From 11294, starting there?
THE WITNESS: Okay.
BY MR. SEIBERLING:
Q Is this part of the media plan that you
were putting together?
A Well, I don't know if it would be
considered the media plan. This is the process
that we go through in developing statements and
then vetting those statement.
Q What is this a statement regarding that
you are drafting in this e-mail?
A I believe this is from the Q & A
document we put together, to anticipate
questions.
Q Questions for whom?
A Questions from the press, for both the
participants of the press conference, as well as
the media staff, following it.
Q These would have been prepared answers
for either the participants or your staff to

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respond to media inquiries?
A Correct. Well, they are talking points.
Q If you look halfway up the third page,
there is an e-mail from you dated Saturday,
July 21st, 2012, to Stacey Osburn, cc'ing
Michelle Hosick, Amy Dunham and Emily Potter.
Quote, "I am having connection issues again.
Have to rely on the iPad, which makes it tough
to edit Word docs. I am working on edit to the
section on the death penalty. Can I e-mail to
you guys and have someone send me back a new set
of docs?"
So the Q & A included a section on the
death penalty?
A Yes.
Q So you were drafting up answers if
questioned about the death penalty?
A Correct.
Q Skip forward one page. There's a
another e-mail from you to the same individuals
we identified earlier. "Thanks, Michelle. Here
is the section I'd like edited. Many have asked
for the so-called death penalty. While I
understand this emotional response, and we
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certainly discussed the possibility at length,
ultimately we need to focus on doing everything
possible to ensure a tragedy like this doesn't
happen again."
It goes on with some more bullet points
about the death penalty.
You were editing the Q & A related to
the potential questions on the death penalty?
A Correct.
Q If you flip forward another page there
is an e-mail from Stacey Osburn saying, quote,
"Michelle is right. To date we have kept the
death penalty mentions out of the release."
A Correct.
Q I believe you explained why. Can you
explain again why you kept the death penalty out
of the release?
A Because when we issue a public release
we talk about the actions that we have actually
taken, not what we didn't.
Q If you flip forward one more page to the
first page. There is another e-mail from you to
the same individuals, saying, quote, "we don't
want to people to get the impression this was a
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negotiated settlement. PSU didn't have a say in
the penalties".
A Correct.
Q Is that statement accurate?
A Yes.
Q It was not a negotiated settlement?
A Not as far as the penalties were
concerned.
Q So the penalties were imposed?
THE WITNESS: Yes.
Q All the penalties were imposed and not
negotiated?
THE WITNESS: I don't understand your
question.
Q The consent decree had several different
penalties.
A Correct.
Q All of those penalties were imposed and
not negotiated?
A As I understand it.
Q Including the fine?
A As I understand it.
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Q Where did the fine amount come from?
A My understanding is that it equaled -it equaled the football revenue per year for
five years. I think that is the way it worked.
Q Were you aware of the fine amount
jumping from 30 million to 60 million?
A No.
Q You were not aware the initial fine
amount was 30 million?
A I don't understand when you say the
initial amount.
Q The initial fine amount that was going
to be included in the consent decree was
30 million, not 60 million.
THE WITNESS: I don't recall the
30 million-dollar figure.
I might also note that penalties are not
negotiated in any action.
Q In a normal infractions process?
A Correct.
Q But this was outside of the infraction
process?
A Yes.

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Q There are agreements that are entered
into in the infractions process?
THE WITNESS: There are agreements in
terms of what the facts are, but not in terms
of what the penalty will be. The committee on
infractions decides the penalty and imposes it.
Q But again, this was outside of that
normal process?
A Correct.
Q Was the consent decree an agreement at
all?
THE WITNESS: Was it?
Q Was it an agreement?
A I think a reasonable person would
conclude that it was an agreement and a contract
between two parties.
Q What benefit was Penn State getting out
of the consent decree?
THE WITNESS: I don't know -- I don't know
that there was a specific benefit. There
always doesn't have to be a benefit for two
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parties to agree upon something.
Q Was the benefit not getting the death
penalty?
A One might look at it that way.
Q Was it presented to Penn State that way?
A No.
Q How do you know that?
A Because in the discussions that I -MR. KOWALSKI: Objection. Please be
careful not to reveal the contents of
privileged communications with NCAA counsel.
Q You can answer the question.
If you can read it back, please.
(Thereupon, the requested portion of the record
was read back by the court reporter.)
Q Did you learn that from Donald Remy? If
not, then you can answer the question.
MR. KOWALSKI: If you didn't learn it from
Donald Remy, you can tell him. If you did...
THE WITNESS: I am just a little confused.
It looks like I am being asked to comment on
something that I didn't hear. I don't know how
-Q Who did you learn it from?
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I need to confer.
MR. KOWALSKI: Let's take a moment just to
confer.
If you have a nonprivileged document
that -THE COURT REPORTER: Do you want to go
off the record?
(Off the record)
MR. KOWALSKI: Mr. Williams is going to
clarify the last answer he gave.
THE WITNESS: So I was never informed by
anyone that there was a discussion between the
NCAA and Penn State that either they accepted
the consent decree or they get the death
penalty.
My comment previously was that an option
was presented to Penn State and they took
that option.
Q Okay.
Q Exhibit 23. It's an e-mail from you to
Mark Emmert cc'ed, Jim Isch, Wally Renfro, dated
A
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July 23rd, 2012. It looks like the morning
of -- early morning of July 23rd. Quote, "Penn
State's statement. My edits are attached".
Whose statement was this?
A I believe this was the statement that
Mark Emmert made at the press conference.
Q The July 23rd, 2012 press conference?
A Yes.
Q You were providing edits to his
statement?
A Yes.
MR. KOWALSKI: There were actually two
documents. Did you just mean to mark this
statement? There's like additional things.
MR. VOSS: Can we see the witness' copy?
We are going to run -- Exhibit 23 is Bates
466 through 470.
MR. KOWALSKI: Thank you.
BY MR. SEIBERLING:
Q Exhibit 24. This is an e-mail from Amy
Dunham to you, dated July 21st, 2012, quote,
"Bob, for your circulation to leadership later

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this evening, attached please find: One, press
release, two, press conference talking points
for Ed and Mark, three, public Q & A, four
glossary of terms, five, transfers explainer."
Were these five items part of your media
plan you were putting together?
A Yes.
Q You and your team drafted up these
documents?
A Yes.
Q And attached are, it looks like, bullet
points for Ed Ray and Mark Emmert?
A Yes.
Q And you drafted up those?
A Well, collectively with my staff, yes.
Q Did Ed Ray stick to the bullet points?
THE WITNESS: No. Ed Ray that morning
made some pen-and-ink changes and delivered his
communications based on that.
Q Was that unusual?
A No.
Q Was that expected?
A Yes.
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Was anyone upset?
I'm good, but I am not that good.
MR. KOWALSKI: One quick thing I need to
clarify. There is a handwritten circle around
the number here, but I believe that was
produced as an electronic document. Is that
your circle?
MR. SEIBERLING: Possibly. Yes, I
believe it was circled.
Q Exhibit 25. This is an e-mail from
Emily Potter to you, subject "for review plan
and timeline." Quote, "Bob, here is the
timeline for your review. Let me know if you
have any updates".
Then attached appears to be a timeline
prepared. Was it prepared by you or your staff?
A Collectively.
Q It appears to be a timeline of the press
conference scheduled for July 23rd.
A Yes. And preparations that need to be
made.
Q And I assume you attended the press
Q
A
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conference?
A Yes.
Q In the timeline at 9:15 a.m. it notes
"Bob Williams begins Q & A session".
A Yes.
Q Did you engage in a Q & A session at
that time?
A Yes.
Q Do you remember the types of questions
being asked?
A Just about the penalties, how the
penalties were arrived.
Q How did you answer those questions?
A I didn't. President Ray handled all the
questions.
Q You didn't answer any questions?
A No. I directed the Q & A session.
Q So you took the questions and they
answered the questions?
A Yes, because, otherwise, it would have
been a media free-for-all, so I was kind of
directing who was going to ask what question.
Q Did you have any other role in the press
conference that day?
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A No.
Q Exhibit 26. This is an invite from Mark
Emmert to you, subject "5:30 p.m. call with
Senator George Mitchell, athletic integrity
monitor."
Were you part of a call with Senator
Mitchell?
A Yes.
Q Why?
A That was to discuss the athletics
integrity agreement and Senator Mitchell's
monitorship.
Q Were you the only person on the call
besides Mark Emmert?
A I am not sure whether I was or not.
Q Do you remember anyone else attending
from the NCAA?
A I don't recall.
Q Had Senator Mitchell been retained as
the athletic integrity monitor at that time?
A I believe so.
Q Did you have any role in the selection

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of Senator Mitchell as the athletic integrity
monitor?
A No.
Q So what was discussed on the call?
A I believe it was the points that he
would make when contacted by media regarding
what his role is and what he would be doing.
Q Did he have his own media person?
A Yes.
Q Did you coordinate with that person?
A Not prior to this call.
Q After that call?
A Yes.
Q Exhibit 27. This is an e-mail chain
from July 23rd, 2012. The first e-mail which
appears on the second page is from Ronnie Ramos
to you stating quote, "tried to call you.
NCAA.com has decided to place a poll as part of
the main NCAA release, asking people to vote on
whether our penalties were appropriate. Amy,
Michelle, Dana and I all felt this was
inappropriate. I have asked .com to take the
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poll down and they are refusing. I am happy to
pursue, but want you to be aware and make sure
you agree the poll should not be on our site."
Did you believe the poll was
inappropriate?
A Yes.
Q Why?
A Because it's an NCAA branded site, and
this was one of the dynamics that we had to work
through with Turner, who ran the site day-to-day
on behalf of the NCAA, in terms of what is
appropriate content and what isn't.
Q Why did you care?
A Because it's an NCAA branded site, and I
didn't feel it was appropriate to have a poll on
there asking the public whether the NCAA -whether they agree with the NCAA's decision or
not.
There are other outlets for that, like
ESPN and others.
Q Does the NCAA.com normally have polls on
sites?
A They have. As matter of fact, when the
site was first put up they put a poll about
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whether or not, I think, college football
playoffs should be held, or something about
that.
And we had them take that one down as
well.
Q Why?
A Because, again, it wasn't an NCAA issue
because the NCAA doesn't administer the BCS or
college football playoffs.
Q But this was an NCAA issue, right?
A Which is even more reason not to have it
there.
Q Did they take down the poll?
A Yes.
Q Do they normally do things when you
asked them to do it?
A When I ask them, yes.
Q Not so much when your staff does?
A Right.
Q The e-mail from you to Ronnie Ramos in
response, which is on the first page, states
"just talked with Mark. Take it down. If I
have to call Matt I will, just let me know".
You talked to Mark Emmert about it?
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A Yes.
Q What was Mark Emmert's thoughts on it?
A Take it down.
Q Why?
A Because it's inappropriate.
Q He also felt it was inappropriate?
A Uh-huh.
Q Did he say why he thought it was
inappropriate?
A Yes. Because it's an NCAA branded site
and it's inappropriate to ask the public or
anyone whether they agree or not with the NCAA
decision.
Q Can you normally dictate what is on
NCAA.com site?
A Yes.
Q What control do you have over the
NCAA.com site?
A Ultimate editorial.
Q On everything?
A Yes.
Q Is that part of the agreement with
Turner?

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A Yes.
Q Is this something that happens
frequently where you have to direct NCAA.com to
-MR. KOWALSKI: Object to form.
Q -- to pull content?
A In the early days of the relationship it
did. Not so much now.
Q Do they run things by you before
posting?
A They have weekly content meetings with
my staff.
Q You're the ultimate arbiter on whether
it goes up or not?
A Yes.
Q Number 28. Exhibit Number 28. This is
an e-mail from you to Mark Emmert, Jim Isch,
Donald Remy, Wally Renfro, David Berst, Julie
Roe, Kevin Lennon, dated July 24, 2012, subject
"Ed Ray ESPN interview".
Do you remember Ed Ray doing a interview
with ESPN the day after the press release?
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A Yes.
Q Do you remember any issues arising as a
result of that Q & A?
THE WITNESS: I believe there was some
controversy over the question regarding the
death penalty.
Q What was that controversy, as you
remember it?
A As I remember, there was one media
source that quoted President Ray as saying that
the death penalty was never considered.
President Erickson had been on record as saying
that the death penalty was in fact on the table.
And then, I believe, this interview President
Ray was asked again and he confirmed that the
death penalty in fact was on the table.
MR. KOWALSKI: Can I clarify one thing? I
think you said President Erickson said the
death penalty had been on the table.
Is that what he said?
MR. KOWALSKI: Did you mean President
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Erickson?
THE WITNESS: President Erickson.
BY MR. SEIBERLING:
Q With regard to President Erickson's
statement, what was your understanding of what
President Erickson had said?
A My understanding was that President
Erickson said that the death penalty was on the
table, and there were some media reports, and I
don't know where they came from, that quoted
President Ray previously saying that it was not.
Q Wasn't President Erickson's statement
that the death penalty was on the table, but it
was, you either sign the consent decree or else
you will get the death penalty?
THE WITNESS: I don't know that that is
what he said.
BY MR. SEIBERLING:
Q In the Q & A that it provides here on
the second page, in the middle of the -- in the
middle of the page there's a question, quote,
"What were the discussions like regarding
penalties for Penn State." And then in the
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second paragraph Ray responds, quote, "The only
potential penalty that we had some extended
discussion around was suspension of play,
whether that ought to be part of a basket of
punitive and corrective measure. There were
people who felt that was appropriate but the
overwhelming position of members of both the
executive committee and the Division I Board was
not to include suspension of play."
Is that how -- you were present for that
at executive committee where the suspension of
play was discussed, is that right?
A That's correct.
Q Do you remember the overwhelming
position of members of both the executive
committee and the Division I Board was not to
include suspension of play?
A Yes, that's where they ended up.
Q Was that not the position at all times?
THE WITNESS: No. There were some members
who -- who initially advocated suspension of
play.
Q But in the end there was -- would you

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agree in the end there was an overwhelming
position of not to include suspension of play?
A In the actual sanctions, correct.
MR. KOWALSKI: Bob, if you feel like you
need a break, let us know.
Q Exhibit 29.
Q This is an e-mail chain that initially
began between Gene Marsh, Donald Remy and David
Berst that was ultimately forwarded along to you
by Donald Remy.
The first e-mail in the chain is
July 24, 2012, from Gene Marsh, states, quote,
"Did the comments go beyond praise for Erickson?
Did they clearly state the death penalty was the
majority view and then that was pulled back
after looking at other the alternative
penalties?"
Donald Remy responds, quote, "I think he
made clear that the death penalty was in play
and Penn State's cooperation helped to avoid
it."
Gene Marsh then responds, quote, "My
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folks are really upset. I will find the ESPN
show when I get there. I say again, Ray should
publicly fix his comments."
What was Ray talking about as far as
publicly fixing Ray's comments?
MR. KOWALSKI: You Marsh?
Q I'm sorry. What was Marsh saying?
A I don't know. I can only assume that it
was regarding the one media report that quoted
President Ray as saying that the suspension of
play was not on the table.
Q Do you know what that media report was
or what outlet it was from?
A The rumor was that it was somewhere
within ESPN, but ESPN produces so much content
it's hard to keep up with -- with everything
that they produce.
Q What was the view on Ed Ray's comments
that appeared to be in conflict within NCAA?
THE WITNESS: What was the view of -Q Did you discuss Ed Ray's comments
internally?
A No, not really.
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Q Did you view them as being inconsistent?
A No, because President Ray was really
clear, even at the press conference, that
suspension of play or the so-called death
penalty was in fact considered.
Q Did anyone within NCAA view Ed Ray's
comments as being potentially inconsistent?
A I think everybody viewed that as an
error, in fact, by ESPN or whoever reported it.
Q Is it safe to say that Gene Marsh viewed
his statements as being inconsistent?
THE WITNESS: I don't know how Gene Marsh
felt.
Q Even when he was saying fix his comments
publicly?
A Yes.
Q Was there an attempt by NCAA to try to
fix Ed Ray's comments?
A No. Because from our perspective Ed Ray
didn't make that statement.
Q Was there any efforts to appease Penn
State's concerns that they may been
inconsistent?
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THE WITNESS: Well, I - I believe in the
in ensuing days, both President Ray and
President Emmert reiterated that all penalties
were on the table to include the death penalty.
Q Did anyone within NCAA direct Ed Ray to
make those comments publicly?
A I don't believe anybody at the NCAA
directs Ed Ray to do anything. He's the chair
of the executive committee.
Q Did you talk to him at all about -A No.
Q -- the statements?
A No.
Q Did he reach out to you at all about his
alleged statements?
A He may have called me once to say, "I
don't know where this report is coming from. I
never said that."
Q Did Ed Ray feel as though his statements
were consistent?
Q Did he convey that to you that believed
his statements were consistent?

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A What he conveyed to me was that he had
been consistent in stating it every time asked
that all options when are on the table to
include the death penalty.
Q Were you aware of these issues and
concerns regarding Ed Ray's alleged statements
carrying on into September, October of 2012?
THE WITNESS: I was aware that -- that
there was a contingent primarily within the
state of Pennsylvania that kept focusing in on
that one misquote.
Q Did NCAA respond?
A The NCAA was already on record stating
what the facts were.
Q Was there any concern within NCAA that
Ed Ray's statements were being misconstrued?
A Well, there's -- there's always a
concern when statements are misconstrued, but in
the media today that's a daily occurrence.
Q Do you feel as though Ed Ray's
statements were being misconstrued?
A Yes. It was an error in fact. He
didn't say that.
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Q You know he didn't say it?
A Well, it is inconsistent with everything
else that he said in an interview and he stated
that he didn't say that.
Q Exhibit Number 30. This is an e-mail
chain that appears to have begun from Jay Bilas
to you. Who is Jay Bilas?
A I wish I didn't know. He is a -- he is
a columnist with ESPN.
Q And apparently an attorney too?
A Yes.
Q Do you get many questions from Jay
Bilas?
A Yes. Jay and I routinely exchange
e-mails and ideas. I actually like Jay.
That's on the record, right?
Q The first e-mail, is dated July 24, 2012
from Jay Bilas to you. Quote, "Dear Bob,
pursuant to our discussion I would like to
submit the following four questions to
Dr. Emmert for his responses.
"Ed Ray, in response to a question
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regarding Graham Spanier was quoted as saying 'I
think Emmert said it right and that we don't
have all the facts about individual
culpability.' As Mark said, we're going to take
a wait-and-see attitude with respect to taking
further actions with respect to individuals as
the legal and other processes play their way out
and we get hopefully a clearer sense of what, if
any, culpability individuals have.
"So we did not take action with respect
to individuals. We took action with respect to
university that lacked institutional commitment
to integrity and the other values of the NCAA."
Then Jay Bilas proceeds to set forth
four specific questions.
A Yes.
Q Did you respond?
A Yes.
Q Would you agree that the NCAA appeared
to be taking action -- taking institutional
action without having found individual
culpability?
A Yes.
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Q Typically wouldn't you need individual
culpability in order to find institutional
culpability?
THE WITNESS: I don't believe -- well, I
don't believe that that's the case.
Q Can an institution act without
individuals?
THE WITNESS: I believe in the past there
has been institutional control issues that were
asserted and put forward without specific
individuals being held culpable.
Q What case was that?
A It's just cases that I remember from the
past. I don't believe that it is -- that it is
-- that it is unfounded.
Q Doesn't the Freeh Report actually find
THE WITNESS: That's the Freeh Report.
Q You've read the Freeh Report?
A Yes.
Q Does the Freeh Report not point out

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select individuals?
A Yes.
Q Wasn't NCAA's findings and sanctions
based on the Freeh Report?
THE WITNESS: Yes, from an institutional
control standpoint. Yes.
Q But individuals control the institution,
not -- the institution doesn't control itself,
isn't that true?
THE WITNESS: Well, the institution is not
a animate object that can make decisions.
There are individuals that make decisions.
Yes.
Q So you have -- the higher ups in the
institution are acting -- those individuals who
are higher up in the institution are acting on
behalf of the institution?
Q Is that correct?
A Yes.
Q So in this instance, how were sanctions
imposed against NCAA without a finding of
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THE WITNESS: Because the sanctions were
applied due to lack of institutional control.
Q Based on the Freeh Report?
A Based on the Freeh Report and based on
the institution acknowledging such.
Q Question number four of the four bullet
points states, quote, "Does Dr. Emmert believe
that institutional culpability can be
established without the establishment of the
individual culpability of Spanier, Schultz,
Curley and/or Paterno."
Did you ever present that question to
Dr. Emmert?
A I believe I notified him of the
existence of the questions and the course of
action that we were going to take in providing
Jay Bilas the information from the press
conference the day before that specifically
talked about individuals.
Q Did Dr. Emmert provide specific answers
to these four questions?
A No.
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Q Do you believe that an institutional
culpability can be established without the
establishment of the individual culpability of
Spanier, Schultz, Curley and/or Paterno?
MR. KOWALSKI: Objection. Objection to
form.
MR. SEIBERLING: I am asking for his
personal opinion.
MR. KOWALSKI: That's what it is then.
THE WITNESS: My personal opinion is that
if one were to look at everything that was
contained in the Freeh Report and look at it
through the lens of the institution then saying
that they accept the Freeh Report, and admit
that there was a lack of institutional control,
that a reasonable person would say yes.
Q We have another Jay Bilas e-mail for
you.
Q Exhibit Number 31. Again, another
e-mail from Jay Bilas to you. This e-mail
appears to be regarding videos of Graham Spanier
that were on the NCAA's web site.
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A Okay.
Q And he appears to be asking you why they
were removed.
A Okay.
Q Can you explain why they were removed?
A I believe there were videos of Graham
Spanier on the web site when he was a part of
the D1 Board, and then when he was no longer
president of the institution and representing
the institution, the videos were taken down.
Q There's also a question in here that
appears to be from Jay Bilas asking why the
death penalty page was removed from the NCAA's
web site.
A My recollection on that was that we had
undergone some restructure changes on the sites
so there was a lot of information that was moved
around. There were some that, you know, one
thing we got used to is kind of the conspiracy
theory, so there were some that said, well, you
did this just because of Penn State and it was
actually done because the site changed.
Q So was it removed or just moved?
A No, the page describing the death

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penalty was moved.
Q Okay. Why was it moved?
A Because we were going to aggregate all
information relating to committee on infractions
issues to one location, and previously it was
kind of smattered throughout.
Q Exhibit 32. I promise we're in the home
stretch.
This e-mail chain appears to have begun
from a question from a CNN producer, to you,
dated August 3rd, 2012, stating, "Hey, Bob.
Hope you are well. I was wondering if you had
any reaction to the letter from the Paterno
family attorney Wick Sollers. Please feel free
to e-mail or call."
That same day you respond, quote, "Penn
State sanctions are not subject to appeal."
If I'm correct, the context of this
e-mail was the Paterno family had filed an
appeal from the consent decree, is that correct?
A I can't remember the exact details, but
I believe that the attorney basically said that
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they were going to push for an appeal of the
sanctions.
Q And the Paterno family wasn't the only
one who appealed, there were others, is that
correct, or attempted to appeal, is that
correct?
A Well, there were others who said that
they were going to appeal. The issue was there
was no vehicle, to my knowledge, to appeal the
consent decree.
A Donald Remy.
Q And why was it not subject to appeal?
contents of privileged discussion with Donald
Remy.
Q What was your understanding of why the
consent decree was not subject to appeal?
A Because I was told so.
Q And you were told if you received
questions on that issue that was the response,
it's not appealable?
A Yes.
Q Were you told why?
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MR. KOWALSKI: You can answer "yes" or
"no" or...
THE WITNESS: Yes.
BY MR. SEIBERLING:
Q Was it because it was not part of the
normal infractions process?
MR. KOWALSKI: Objection. You can't
reveal the substance of a privileged
communication with Donald Remy.
not to answer?
MR. KOWALSKI: Yes.
Q Exhibit 33. One last e-mail to show.
This is an e-mail chain that began on
December 13, 2012. It's an e-mail from Mark
Emmert to you and Cari Klecka, the subject
Wikipedia. Quote, "Just saw that the Wikipedia
site in me grossly misses the mark in describing
Penn State decision. Check it out and see how
we put the record straight."
Do you remember this e-mail from Mark
Emmert?
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A Yes.
Q Did you have a conversation with Mark
Emmert about this e-mail?
A No, I didn't.
Q What did you do in response to this
e-mail from Mark Emmert?
A Contacted my staff to get the process
going on correcting or editing Wikipedia.
Q Do you normally edit or correct
Wikipedia pages?
A Yes.
Q Why?
A Because the way Wikipedia is set up, a
wide variety of people have access to the pages,
and what we find is a general misunderstanding
from the public of what Wikipedia is. They view
it as a -- as a verified source when it's not.
And so, we routinely, now, routinely
review Wikipedia and correct errors. Just like
any other media.
Q What sections or what people or what
entries do you review?
A We review Mark Emmert, and the NCAA. I
think Final Four is another one that we review.

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Q How often do you do these reviews?
A Just periodically.
Q Was this a directive from Mark Emmert?
A Well, he asked me to look into it.
Q But to continually look into it?
A No.
Q Was this unusual for him to e-mail you
about this?
A No.
Q Has he done it previously?
THE WITNESS: He will regularly e-mail me
on misinformation or information that is not
factual that's posted that he sees.
Q On Wikipedia?
A On any source.
Q Is what other sources?
A General media, sports media.
Q Certain web sites?
A Yeah.
Q What types of web sites? Can you give
examples?
A Sure. We've had to correct the record
on ESPN, on Bleacher Report, on Yahoo Sports.
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Literally all of them.
Q By correct the record, you mean stories
on those sites or comments on those sites or
both?
A Both.
Q So you'll contact the reporter?
A We will correct errors in fact.
Q Even the comment section?
A Not in the comment section, no.
Q But the individual reporters?
A Correct.
Q Yes. Will you reach out to them and
contact them?
A Correct.
Q But Mark Emmert will e-mail you -- this
is a hypothetical -- mark Emmert will e-mail you
and say this story on Yahoo.com is incorrect?
THE WITNESS: He has occasionally in the
past. Most of the time it's our own staff,
reviewing the clips and posts of the day and
literally every day there's a misrepresentation
in the media. And we correct it every day.
Q And that's part of your
Page 180
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B. WILLIAMS
responsibilities?
A Yes.
Q In this particular example, if you flip
to the second page of the original e-mail,
there's an e-mail from Ronnie Ramos to Stacey
Osburn. And this appears to have been what was
removed and then inserted.
And this is to quote the text, quote,
"Wikipedia parts to be removed. As a result of
increasing public pressure, Emmert bypassed key
bylaws to procedures and forced Penn State
University President Rodney Erickson to either
sign a consent decree accepting the sanctions or
suffer death penalty.
"This action drew mixed reactions from
the public, some of whom believed he overstepped
his boundary and he did not provide Penn State
the due process they believed was required."
What is your understanding of what was
incorrect in that statement?
A The entire first sentence. And the
second sentence was editorializing.
Q The next paragraph is what was added in
its place. Did you draft that up?
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B. WILLIAMS
A No. This came out of -- this came out
of the release, I believe.
Q Out of the NCAA's press release with
regard to the Penn State sanctions?
A Correct.
Q Has anyone changed it back since?
A I'm not sure. I doubt it.
Q It's possible?
A It's possible.
MR. SEIBERLING: Nothing further. Thank
you.
THE WITNESS: Thank you.
MR. KOWALSKI: We would like the
opportunity to read and sign.
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(Whereupon, at 6:29 p.m., the deposition

was concluded.)
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(877) 702-9580
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B. WILLIAMS
CERTIFICATE
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Page 183
I, the undersigned authority, hereby

certify that the foregoing transcript, page 1
through 181 is a true and correct transcription of
the deposition of Bob Williams taken before me at
the time and place set forth on the title page
hereof.
I further certify that said
witness was duly sworn by me according to law.
I further certify that I am not of
counsel to any of the parties to said cause or
otherwise interested in the event thereof.
IN WITNESS WHEREOF I hereunto set my
hand and affix official seal this 7th day of
November, 2014.
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___________________________________
RANDI GARCIA, COURT REPORTER, RPR
NOTARY PUBLIC
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B. WILLIAMS
ERRATA
SHEET
Changes and Signature
Witness Name:
Page
Line
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B. WILLIAMS
I CERTIFY THIS IS A TRUE AND
ACCURATE TRANSCRIPT FURTHER DEPONENT SAYETH NOT.
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________________________
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THE WITNESS
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Sworn and subscribed to before me this
_______day of_______,2014.
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Personally known__________or
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I.D._______________
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____________________.
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____________________________
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Notary Public in and for
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the District of Columbia at
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Large. My Commission Expires:
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July 12, 2016
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31 (3)
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32 (3)
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36 (1)
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3rd (2)
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53 (1)
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71 (1)
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75 (2)
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8 (3)
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Received 11/07/2014 Commonwealth Court of Pennsylvania

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

No. 1 M.D. 2013

JAKE CORMAN, in his official capacity

District of Pennsylvania and Chair

Appropriations; and ROBERT M.

Treasurer of the Commonwealth of

Deposition of Kevin Lennon

Tuesday, November 4, 2014

Reported By: Randi Garcia

Job No. 86741

TSG Reporting - Worldwide

Tuesday, November 4, 2014

Deposition of KEVIN LENNON, taken by Plaintiff,

ATTORNEYS FOR NCAA.

TSG Reporting - Worldwide

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(Thereupon, Exhibit Number 6 was marked

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