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Larry O.

Wilder
Attorney at Law
530 East Court Avenue
Jeffersonville, Indiana 47130
Tx: 812.288.6820 Fax: 812.282.3188 Cell: 502.930.4152
Em: larrywilder@me.com
January 4, 2019

Vince Tyra, Athletic Director


University of Louisville
Athletic Dept., SAC Bldg, 3rd Floor
University of Louisville
2100 S. Floyd Street
Louisville, KY 40208

RE: Head Coach, Todd Sharp


University of Louisville- Cheer and Dance

Dear Mr. Tyra:

Please be advised that I, along with J. Bart McMahon, represent Todd Sharp in those matters
arising out of his recent dismissal as Head Coach of the University of Louisville’s Cheer and Dance Team.

Further let this serve as our demand, pursuant to the University’s due process provisions, to
discuss Coach Sharp’s termination with you, the Director of Athletics.

Moreover, prior to exercising this initial due process right, Coach Sharp would request the following
information pursuant to the Kentucky Open Records Law:

A. Copies of any and all documents maintained in Coach Sharp’s personnel file;

B. Copies of any and all documents which the University relied upon in setting forth its allegation that
“substantial evidence (exists) that Coach Sharp “engaged in fiscal misconduct”;

C. Copies of all documents which the University relied upon in setting forth its allegation that
Coach Sharp “violated (the) University cash handling policy”;

D. A copy of the University cash handling policy along with all documents to support the allegation the
Coach Sharp was informed of the alleged policy;

E. Copies of all documents the University relied upon to support its allegation that Coach Sharp
engaged in conduct which resulted in “diversion of revenue from athletic accounts”;

F. Copies of all documents the University relied upon to support its allegation that Coach Sharp
utilized his position with the University for “potential personal gain”;

G. The names, address and occupation of all individuals allegedly interviewed by the University as
referred to in its letter of termination dated December 14, 2018;
Demand for Meeting- Athletic Director
H. Copies of all transcripts, audio or video of those “interviews” allegedly conducted by the University
as referred to in its termination letter dated December 14, 2018;

I. Copies of any and all documents provided to the Athletic Department by the University of
Louisville Audit Services which were reviewed by the Athletic Department, its employees or agents
or any other member of the University staff;

J. Copies of any and all documents provided to the Athletic Department by the University of
Louisville Police Department which were reviewed by the Athletic Department, its
employees or agents or any other member of the University staff;

K. Copies of all correspondence, emails, text messages or any other epistle, wherein any employee
of or member of the University of Louisville Athletic staff, its employees or agents communicated
with anyone regarding Coach Todd Sharp’s employment with the University of Louisville Athletic
Department.

Please respond to the request for documents and information at your earliest possible
convenience. Please be advised that it is Coach Sharp’s belief that absent the University providing this
information in advance of his meeting with the Athletic Director the meeting will be futile. In order to
engage in a meaningful discourse pursuant to Coach Sharp’s articulated due process rights it is necessary
that he have the requested information to review in advance.

If you have any questions regarding this request by Coach Sharp to exercise his initial due process
rights as provided for by his contract for employment or questions regarding the request for information as
propounded pursuant to the Kentucky Open Door Law, please contact me at your convenience.

Finally, Coach Sharp has affixed his signature below as concurrence to this request for both his
initial administrative meeting with the Athletic Director as well as his concurrence with the request for his
personnel file and all other documents set forth herein.

Thank you for your time and consideration. I am,

Sincerely,

Larry O. Wilder
J. Bart McMahon

I, Todd Sharp, affirm that I have read the above demand and concur with the request to exercise
my due procees rights as well as request to produce documents as set forth and pursuant to the Kentucky
Open Door Law.

_______________________
Todd Sharp, Head Coach
University of Louisville, Cheer and Dance

2 Demand for Meeting-Athletic Director

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