For Reference: Exhibit Index (UM Filing)

Helps you find documents.  (UM Filing also lacks an Exhibit Index.)

Exhibit 1

4/16/09: CSO Rules Ed Mtg (Exh.1)   First Page: : CSO Initiative for Job Descriptions for Non-C Sport Specific  Summer Conditioning – NCAA Definition of Voluntary. Sport Specific Staff not permitted to observe voluntary workouts. Attached “Quick Guide” on Summer Conditioning includes, side by side, references to Sport Specific Non Coaching Staff not being able to observe summer workouts, alongside specific language about permissible summer activities, so long as “no offensive or defensive formations are set up” and “no equipment related to the sport is used.”
Exhibit 2:  102 pages of copies of Team Guides, showing descriptions of backgrounds and job duties.
Exhibit 3: Six pages, all dated stamped rec’d 8/28/09. Each page has a name of one QC staffer on it, with five or six lines on that page, purporting to describe job duties. Example, for Adam Braithwaite, the elements listed are:
1. Duties assigned by Head Coach
2. Duties assigned by Defensive Coordinator
3. Assist Strength Coach with skill development –   Linebackers
4. Assist Defensive Coaches with administrative duties
Exhibit 4:  Email Draper to Van Horn, 8/30/09:  Encloses QC Job Description, with message, “let me know what you think”.). Description is much more thorough than the 4-or-5 liners which are date stamped 8/28, and which are the ones which RR contends in his filing he authored when he arrived in ‘07.  Almost all the duties listed, though, suggest a sort of “go-fer” status.
Exhibit 5
Emails Aug 30 and 31 between JVH and Draper: Job Descriptions of RR Secy; Dir of FB Ops, etc
Job Descriptions: FB Recruiting Asst.;
Asst AD Football (Draper) :  “Liaison to CSO for Head Coach,” Liaison to AD for Head Coach.. Provide Admin Support to Head Coach and AD; Coordinate Policy and Procedures for Head Coach and AD
External Relations Job Description
Recruiting Coordinator – FB
Dir. of FB Operations:  this is a very short, one page document. “Provide Administrative Assistance for Head Coach and Asst. AD for Football.”
Secretary to Head Coach
Exhibit 6
Job Classification for Asst Coaches and Barwis (S&C Coach): note “direction is received from Senior Assoc AD” [Joe Parker]
Exhibit 7

List of hourly employees, range in pay from 7-17.  QC is $17 per hour. Note that highest wage is Defensive Grad Asst, ($19)    Note listing of annual salaries of QC, which is all in the $36,000 range.
Exhibit 8
Agenda 1/11/08 New Coach Compliance Orientation Meeting:
—  Among first topics covered: “Repeat Violator Status ends as of May 8, 2008.”; Process for asking for Rule Interpretation; Process for reporting violation

—  Monthly Submission of Countable Hour Logs (CARA) and Recruiting Logs –  someone has henscratched on it, “why signatures?”
— Designation of Coaching Categories [Handout]”
At bottom of page, big letters, downward arc “ALWAYS ASK BEFORE YOU ACT”
Recitation of NCAA factors re: “Lack of Institutional Control”
Process for asking for Rule Interpretation.
Also, who can request interp from Conf or NCAA: MSC, Percy Bates, JVH, AD…
Exhibit 9
6/3/08:   Agenda, Compliance Rules Ed Mtg, for FB Staff
FIRST PAGE:  Summer Conditioning Handout; NCAA “Voluntary” Definition – All 4 Points (Handout); Coaches and Sports Specific Staff not Permitted to watch Voluntary Activities at Any Time;
6 Monthly Rules Ed.Mtgs for Coaches ‘08-9.
One of attached pages has recitation of same “Sports Specific Staff not Permitted to watch Voluntary Activities at Any Time” rule
4/13/09: This is date of memo which was authored by Compliance Staff, includes at bottom discussion of summer activities (“Michigan Coaching staff members may not organize, observe or participate in a Wolverine teams’ workout during the summer…..     Team sport participants are not allowed to be involved in any countable athletically related activities during the summer….)
Recites NCAA 17.02.13, Voluntary Athletically Related Activity (the four part test)–
Exhibit 10
7/29/08: Rules Education Meeting, Football Coaching Staff
III-C: Coaching Limitations Resource (Handout)
III-E: Reminder – Submission of Practice Logs (CARA)/Recruiting Records
IV:  Major Infractions Case Review – Louisiana Lafayette  [No info about review on this outline, but below is description from NCAA Press Release ’07 on the LaLafayette NCAA case:

“The violations in the football program occurred during the summers from 2002 through 2005 and involved voluntary conditioning activities becoming mandatory because of actions by members of the football and strength and conditioning staffs.

The strength and conditioning coach at the time provided both written and verbal updates to the coaching staff about student-athletes participating in summer workouts. Also, members of the football coaching staff occasionally observed workouts, provided skill training and tracked student-athlete attendance in the summer conditioning program.

– Quotes NCAA 10.1 Bylaw Unethical Conduct:  Subsection   Refusal to provide information relevant to an investigation of a possible NCAA violation when requested to do so by the NCAA or the institution

—  Copy of UM Procedures for Requesting a Rules Interpretation:

– Half way thru doc, there is usual NCAA stuff about Non Coaching personnel forbidden to observe or monitor voluntary activities.  Someone has circled this heavily with pen. . Also circles a few lines down what they are PERMITTED to do.

—  Then several pages of UM’s CARA policies

Exhibit 11: Feb 12, 2009 – Rules Ed Meeting , Football Staff

Exhibit 12:

7/29/09  Rules Education Meeting, Football Coaching Staff
I-E: Procedures for Requesting an Interpretation and Reporting a Violation (Handout)
IV-B: Coaching Limitations Resource (Handout)
VI-C: 2008-9 Submission of Recruiting Records and CARA Logs
Limitations on Duties of Coaches (This is NCAA Reg  Countable Coach: An athletic department staff member must count against coaching limits as soon as the individual participates (in any manner) in the coaching of the intercollegiate team in any practice, games or organized activities directly related to that sport, including any organized activity directly related to that sport.Also includes recitation of bylaw re: Non Coaching Staff.Also recitation of CARA bylaws
Exhibit 13
CSO Rules Ed Mtg for  S&C  2/7/08
—  First Page:: CARA ; Definition of “Voluntary Athletically Related Activities”; Reminder, Staff with Sport specific duties may not observe voluntary activities of any type. Prohibition on use of equipment related to the sport
Exhibit 14:  8/15/08:  Memo to All Head Coaches, from Ann Vollano of Compliance, asking all to fill out Coaching Designation Forms (listing of each coach, Asst. Coach, QC, etc):  “Attached you will find the ‘Designation of Coaching Category Form” for …2008-09.  Please note that the form has been changed and it now includes space for each member of your non-coaching sport specific staff to sign. In addition, please attach a copy of each sports-specific staff person’s job description…. Once we have gathered titles and job descriptions, we will have each sports specific staff member sign an agreement with respect to their role with each sport. The role of non-coaching, sport-specific staff continues to receive increased scrutiny from both the NCAA and the Big Ten Conference staff.

Note that this memo is copied to all the characters pertinent to this chronology ( including AD Martin, Joe Parker, Draper and Labadie.)  All Head Coaches are instructed to respond by 8/22 with the completed form.

Exhibit 15: Series of Emails, from 4/2/08 through 12/08

4/2/08 JVH to Vollano (suggesting that Job Descriptions and sign-offs from all staffers be obtained)

—  Mid July ‘08 Emails between JVH and Draper, where Draper tells her that he is Labadie’s boss, and he doesn’t understand what the problem is, and why Joe Parker has to be involved, and telling JVH that she does not need to meet with Labadie.

— Vollano email to all in August ‘08 re: New Coaching Designation forms and Job Descriptions

— Mid-December emails between Vollano & Labadie (copying JVH and Asst. AD Joe Parker) again reminding she still doesn’t have the long-sought job descriptions), and also noting that “we have NO CARA forms for the whole term”. Last email is 12/16 by Labadie, asking Vollano “which Job Descriptions did you need?”

— 4/14/09:  Compliance Mtg, Bill Martin:  FB has not submitted ‘08-09 CARAs or Job Descriptions. Second page: Sport specific staff not allowed to watch voluntary workouts.  Definition of Voluntary.

5/26/09:  Compliance Mtg, Bill Martin:  FB has not submitted Job Descriptions

8/18/09   Compliance Mtg, Bill Martin:  Full FB team mtg, with strong remarks by RR re: need for NCAA Compliance, and emphasis in several areas.  Prelim mtg to discuss new process for submitting CARAs (in prep for mtg with RR on 8/26)

FB has not submitted Job Descriptions for Non-Coaching staff

— Also mentions at bottom: FB and response to NCAA Allegation

Exhibit 16: 3/4/08 and 3/5/08 Memos from JVH to All Michigan Coaches, etc etc., reminding that any “discipline” of athlete has to be conducted only during allowed “CARA” time allotments – can’t be extra.

Exhibit 17:  “This Exhibit has been withheld [for student privacy purposes, under FERPA], and to protect the intellectual property interests of one or more members of the U of M football coaching staff, pursuant to the Michigan Confidential Research and Investment Information Act.”  [Note: this is a loony excuse for failure to produce.]

Exhibit 18: 1/2/08 Memo from CSO to Coaches, instructing that CARA forms (and other compliance logs) must be submitted:

1/1/08 New Coach Compliance Mtg Agenda

2/19/08:  CSO Head Coach & Annual Mtg. :  CARA Forms (practice time a major NCAA issues)  Also, late forms and possible blank forms signed by players.

This Exhibit contains long series of emails back and forth about CARAs; also Vollano’s 8/1/08 CARA form memo to all

Exhibit 19:  Internal Audit Report, 7/24/09
Exhibit 20: Management Advisory Memorandum, 7/24/09, from Auditors to Head Coach RR, Labadie and Draper
Exhibit 21: 8/1/08: Vollano to All Coaches, enclosing 2008-9 CARA forms, with FAQs
8/13/09: Vollano to All Coaches, enclosing 2009-10 CARA forms, with FAQs
Exhibit 22: CSO Meeting –  RR – Head Football Coach & Annual Meeting, 2/19/08
Exhibit 23: 2008 Summer Conditioning Period
Exhibit 24: Withheld
Exhibit 25: 6/23/09 Compliance Calendar Document
Exhibit 26: Additional Information witheld

Exhibit 27: Follow up memo, dated 9/3/08, from Ann Vollano to Draper, attaching her 8/15 memo, and asking him to complete the forms, and reminding that she “needs job descriptions” for the non-coaching staff members”

Exhibit 28: 2003 NCAA findings re: UM Basketball violations arising out Fab Five era

Exhibit 29: Self Reporting Instances by UM to NCAA, 2005-10.   Shows report for Academic year 2007-08, violation of By-Law 17.11.6, by Labadie and Rodriguez (this appears to be the By Law having to do with “Div. I FB Discretionary Period Designation” — for summer workouts. This requires filing a form.)

Exhibit 30: Organizational Chart, UM  Intercollegiate Athletics. Amongst the actors involved in these events, the only person with direct supervisory reporting authority over the Head Football Coach is AD Bill Martin.

Exhibit 31: Withheld

Exhibit 32: 12/12/06 Memo from Jim Delaney of BT Conf re: TV

Exhibit 34: 6/25/09 Voicemail from Vollano to Dennis Murray of Strength & C: I found it, so I am going to email you. the difference it’s like between monitoring the workouts and conducting the workouts.  The rest of this voicemail articulates some framework which is very difficult to parse. With all due respect to Vollano and Murray, the distinctions seem without a difference.

About brewonsouthu

lawyer, with interest in college sports and NCAA oversight and decisions, and sports generally.
This entry was posted in David Brandon, Mary Sue Coleman, Michigan Football, NCAA Investigation, NCAA Violations, Quality Control Coaches, Rich Rodriguez, Uncategorized, University of Michigan. Bookmark the permalink.

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