Deposition Testimony of Bob Williams, NCAA Senior Vice President of Communications (Nov. 6, 2014)

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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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TSG Reporting - Worldwide

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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
Exhibit 1 - 11/7/2011 e-mail
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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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Exhibit 30 - Jay Bilas e-mail
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Exhibit 31 - Jay Bilas e-mail
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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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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?
MR. KOWALSKI: Objection to form.
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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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.
Q What does that mean?
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?
MR. KOWALSKI: Objection.
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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
NCAA, how have you seen the NCAA evolve over

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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.
(Thereupon, Exhibit Number 1 was marked
for identification purposes.)
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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
nonlawyer saying it.

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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.
(Thereupon, a brief recess was taken.)

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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?
MR. KOWALSKI: Object to form.
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?
THE WITNESS: I don't recall.
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.
Q Who told you that?
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
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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. SEIBERLING: Yes.
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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privileged communications.
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
executive committee?
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.
Q What does that mean?
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?
(Thereupon, the requested portion of the
record was read back by the court reporter.)
MR. KOWALSKI: I don't know how he can
answer that without revealing the contents of
privileged communications.
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
competitive advantage?
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.
(Thereupon, a brief recess was taken.)
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?
THE WITNESS: I don't know.
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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B. WILLIAMS
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
individual culpability?
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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individual culpability?
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?
MR. KOWALSKI: Please don't reveal the
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.
MR. SEIBERLING: So you're directing him
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
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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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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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B. WILLIAMS
CERTIFICATE
DISTRICT OF COLUMBIA
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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
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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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DISTRICT OF COLUMBIA
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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63:1 64:1 65:1 66:1
66:23 67:1 68:1
69:1 70:1 71:1 72:1
73:1,5,25 74:1,19
75:1 76:1 77:1 78:1
79:1,3 80:1 81:1

82:1 83:1 84:1 85:1
86:1,17 87:1 88:1
89:1 90:1 91:1 92:1
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64:22 65:22 66:11
67:15 68:9,15,21
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79:9,22 80:12 81:6
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116:12 117:9,18
118:15 127:14
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133:13 134:4,11
135:8 136:15,19
137:9,23 138:19,24
139:7,12 140:7,11
141:7 144:12,16
145:17 146:5,15,23
147:21 148:13
149:16 150:19
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161:22 163:22
164:14 165:3
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172:11 176:4
178:13 179:20
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107:20 123:18
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world (1)
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worth (1)
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wouldn't (7)
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write (1)
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yesterday's (1)
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young (9)
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122 (1)
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176:18
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56:9 74:17 108:11
2012 (28)
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66:18 69:13 75:11
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158:22 162:15
166:8 167:20
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2013 (1)
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2014 (4)
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2016 (1)
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21 (3)
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218 (1)
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142:6 149:24
22 (3)
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24 (7)
6:4 26:20 149:20,23
158:22 162:15
167:20
25 (4)
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26 (3)
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27 (3)
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28 (4)
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31 (3)
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32 (3)
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33 (4)
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36 (1)
5:6
3rd (2)
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4
4 (4)
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5 (5)
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50 (1)
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53 (1)
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555 (2)
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58 (1)
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6 (3)
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6/11/2012 (1)
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6/23/2012 (1)
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6:29 (1)
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60 (2)
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62 (1)
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6222 (1)
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66 (1)
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7 (5)
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7/12/2012 (2)
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7/21/2012 (1)
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7/22/2012 (1)
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7/23/2012 (2)
6:3,7
7/24/2012 (2)
6:8,9
7/4/2012 (1)
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71 (1)
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75 (2)
5:16 135:12
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5:11 57:25 58:5
80 (1)
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9:05 (1)
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Deposition Testimony of Bob Williams, NCAA Senior Vice President of Communications (Nov. 6, 2014)

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Deposition Testimony of Bob Williams, NCAA Senior Vice President of Communications (Nov. 6, 2014)

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Page 1

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

Depostion of Bob Williams

Wednesday, November 5, 2014

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Wednesday, November 5, 2014

Deposition of BOB WILLIAMS, taken by Plaintiff,

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(Whereupon, at 6:29 p.m., the deposition

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I, the undersigned authority, hereby

Notary Public in and for

the District of Columbia at

Large. My Commission Expires:

July 12, 2016

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