Requestor
Cohen , Daniel
Organization
Cuneo Gilbert & LaDuca, LLP
Initial Request Date
05/07/2012
The time period for these requests is from 2002 to the present unless otherwise specified. I hereby request copies of the following documents, either in hard copy or electronic form:
- 1. All television contracts relating to Oregon's NCAA Division I men's basketball team and/or NCAA Football Bowl Subdivision (f/k/a Division I-A) football team. This request specifically includes but is not limited to contracts entered into by the Pac-12 Conference.
- 2. All contracts between Oregon and any outside licensing entity or agency relating to Oregon's NCAA Division I men's basketball team and/or NCAA Football Bowl Subdivision (f/k/a Division I-A) football team. This request specifically includes but is not limited to agreements with Collegiate Images, the Collegiate Licensing Company, Electronic Arts, Replay Photos, and Thought Equity Motion. This request specifically includes but is not limited to contracts entered into by the Pac-12 Conference.
- 3. All contracts between Oregon and ISP (now IMG) that relate to Oregon IMG Sports Marketing.
- 4. Documents sufficient to determine revenues received in connection with any agreements produced in response to Request Nos. 1-3.
- 5. Each yearly report provided by Oregon to the NCAA pursuant to the NCAA's "NCAA Membership Financial Reporting System." This request also seeks all related documents, including any related audit reports. These reports may be called audits in accordance with agreed upon procedures ("AUP").
- 6. All Documents, including drafts, e-mails and memoranda relating to current and former student-athlete release or waiver forms utilized, prepared by or recommended to Oregon, including exemplar waiver forms and excluding signed waiver forms. This request specifically includes but is not limited to any exemplar waiver forms provided to Oregon by third-party licensees such as, for example, Replay Photos or Collegiate Images.
- In responding to the following requests, please search the files of the following current and former Oregon employees, in addition to those of any other employees that may possess responsive documents: Rob Mullens, Oregon's Athletic Director; former Athletic Directors Lorraine Davis, Mike Bellotti, Pat Kilkenny, and Bill Moos; Robert M. Berdahl, Oregon's President; former Presidents Richard W. Lariviere and David B. Frohnmayer; Craig Pintens, Senior Associate Athletic Director; Renee Baumgartner, a former Senior Associate Athletic Director; Eric Roedl, Executive Senior Associate Athletic Director; Gary Gray, Senior Associate Athletic Director for Compliance & Academic Services; Brian Movalson, General Manager of Oregon IMG Sports Marketing; Steve Pohl, Oregon's Video Coordinator; and Matt Dyste, Oregon's Director of Marketing and Brand Management.
- 7. All Documents referring or relating to credentialing of photographers, videographers, broadcasters, news agencies or television networks in relation to the Oregon's NCAA Division I men's basketball team and/or NCAA Football Bowl Subdivision (f/k/a Division I-A) football team, including but not limited to recommended credential language received from third parties.
- 8. A December 14,2009 email sent from Matt Dyste, Oregon's Director of Marketing and Brand Management, to Tim Murff of Media Art Works at approximately 2: 18 PM. This request seeks the entire correspondence, including attachments, between the parties in this e-mail chain, as well as all related Documents, including internal discussions of the same.
- 9. All Documents referring or relating to DragonFly Athletics, LLC or Kirk Miller, DragonFly's founder and CEO.
- 10. All Documents referring or relating to John F. Turner Wall Calendars.
- 11. All Documents from 2009 to the present referencing lawsuits referred to as (1) O'Bannon; (2) Keller; (3) Maze; (4) Robertson; (5) Russell; (6) In re NCAA Student-Athlete Name and Likeness Licensing Litigation; and (7) NCAA litigation and/or lawsuit.
- These lawsuits relate to issues regarding the use of current and former student-athletes' names, images and likenesses in products including video-games, photographs, streaming video, television rebroadcast, and DVDs, among other media.
- 12. All Documents dated from January 1, 2004 to the present referring or relating to NCAA Legislative Proposals 2005-26, 2007-26, 2010-26, 2010-9, 2011-97, and 2011-96.
- a. This request specifically includes but is not limited to Documents dated from 2007 through 2008 referring or relating to discussions between members of, or Documents referring or relating to, received at, or prepared in connection with meetings of (1) the NCAA Management Council that contain information concerning the use of student -athlete names, images or likenesses; and (2) the Collegiate Commissioner's Association that contain information concerning the use of student-athlete names, images or likenesses.
- 13. All Documents referring or relating to the NCAA Task Force on Commercial Activity in Intercollegiate Athletics, including correspondence, final and draft reports, meeting minutes, meeting agendas, presentations and any personal notes prepared by members of the Task Force.
- 14. All Documents referring or relating to student-athlete cost of attendance, multiyear grants to student-athletes or the use of student-athlete names, images and/or likenesses in connection with the NCAA Division 1 Academics/Eligibility/Compliance Cabinet.
- 15. All Documents referring or relating to the use of student-athlete names, images and likenesses in connection with fantasy sports games. Certain memoranda addressing this subject may have abbreviated fantasy sports games as "FSG."
- 16. All Documents from January 1, 2005 to the present referring or relating to Electronic Arts Inc.'s ("EA" or "EA Sports") NCAA-themed video games.
- 17. All Documents referring or relating to the permissibility of using in any way any current or former student-athlete's name, image or likeness. This request specifically includes but is not limited to documents referring or relating to Players, Inc. and the NFLP A that contemplate when University of Washington must obtain permission from a former student-athlete for use of his name, likeness or image.
- 18. All Documents referring or relating to NCAA President Mark Emmert's Presidential Retreat in Indianapolis on August 9 and 10, 20 II. This request specifically includes, but is not limited to, documents referring or relating to, received at, or prepared in connection with the Summit and Documents referring or relating to feedback provided to the Pac-12 Conference.
- 19. All Documents referring or relating to the "Evolution ofIntercollegiate Athletics Promotion-Changing Our Legislation to Keep Pace," a seminar conducted on August 27, 2007. This request specifically includes but is not limited to all Documents referring or relating to, received at, or prepared in connection with the seminar, and any notes taken by attendees.
- 20. Any interpretation request forms submitted to the Pac-12 Conference with respect to whether the use of a student-athlete's name, image or likeness violates NCAA or Pac-12 rules and regulations.
- 21. All Documents referring or relating to discussions between members of, or Documents referring or relating to, received at, or prepared in connection with meetings of, the Division I A Athletic Director's Association ("DI-A"), the National Association of Collegiate Marketing Administrators, National Association of Collegiate Directors of Athletics ("NACDA"), or the International Collegiate Licensing Association that contain information concerning the use of student-athlete names, images or likenesses.
- 22. All Documents referring or relating to, received at, or prepared in connection with the Sports Business Journal Intercollegiate Conferences (a/k/a IMG Intercollegiate Athletics Forum) that contain information concerning the use of student-athlete names, images or likenesses.
- 23. All Documents relating to, received at, or prepared in connection with the 2009, 2010 and 20 II Sports Video Group College Sports Video Summits.
- 24. All Documents referring or relating to the Collegiate Athletes Coalition that discuss the use of student-athletes' names, images or likeness, student-athlete cost of attendance and/or multiyear grants to student-athletes.
- 25. All documents referring or relating to the National Association of Basketball Coaches' 2009 Fall Board of Directors Meeting at which was discussed the use of student-athlete names,
- images and likenesses in EA Sports Video Games. This request specifically includes but is not
- limited to documents from the files of Ernie Kent, Oregon's former Men's Basketball Coach.
- 26. All Documents concerning Creative Artist Agency (CAA) Sports Media Ventures.
- 27. All Documents relating to the negotiation of agreements that pertain to the Pac-12 Network agreement.
- 28. A September 4, 2011 email sent from Michael Crow of Arizona State University to Richard Lariviere, Oregon's President, et ai, at approximately II :41 AM. This request seeks the entire correspondence, including attachments, between the parties in this e-mail chain, as well as all related documents, including internal discussions of the same.
- 29. All Documents referring or relating to Pac-12 Executive Regulation ER 1-10.
- 30. Any Documents from January I, 2009 to present referencing or relating to Sonny Vaccaro. Please note that his last name is sometimes misspelled "Vacarro" or "Vaccarro" or "Vacaro." This request specifically includes but is not limited to documents from the files of Ernie Kent, Oregon's former Men's Basketball Coach, Dana Altman, Oregon's Men's Basketball Coach, or Charles "Chip" Kelly, Oregon's Men's Football Coach.
- 31. All documents including emails from 2009 to present referencing Jennifer Turner acquisitions, calendars, andlor release forms.
- 32. All email correspondence sent and received from Cathy Aldridge, Director of Non- Marketing Apparel at The Collegiate Licensing Company.
- 33. All documents (excluding release forms) relating to rights held by you or any members with respect to current or former NCAA student-athletes' names, images or likenesses in connection with any products, including television broadcasts or products made from television broadcast footage, pertaining to their participation as student-athletes.
- 34. All documents referencing or relating to suggestions by the NCAA or the Pac-12 Conference regarding how to respond to FOIA request.
Status Date
05/08/2012