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Here is the buzzsaw Sankey is walking the SEC into
Posted on 9/3/26 at 10:03 pm
Posted on 9/3/26 at 10:03 pm
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
DAE’QUAN WRIGHT and ZXAVIAN HARRIS,
Plaintiffs,
v.
SOUTHEASTERN CONFERENCE; GREG SANKEY, individually; JOSH BROOKS, individually; the verified institutional defendants and individually named athletic directors and presidents/chancellors identified in Schedule A [expand into caption before filing]; and [appropriate state officials in their official capacities solely for permissible prospective federal relief],
Defendants.
Civil Action No. [to be assigned]
JURY TRIAL DEMANDED
COMPLAINT FOR DAMAGES AND DECLARATORY AND INJUNCTIVE RELIEF
Plaintiffs, through counsel, allege the following upon personal knowledge as to their own acts and upon information and belief, supported by the specifically identified sources, as to other matters. Every bracketed field requires completion or deletion before filing.
I. Nature of the action
1. This action challenges a collective restriction preventing otherwise eligible football players from contracting with and competing for willing SEC member institutions solely because of specified prior professional activity. Plaintiffs challenge the particular restriction and its enforcement; they do not seek exemption from academic, medical, roster, or other independently lawful eligibility requirements.
2. Plaintiffs seek to restore lawful competition for their athletic services, remedy interference with their existing agreements and demonstrated business opportunities, and recover economic losses directly caused by the acts identified.
On [date], [authorized LSU decisionmaker] informed each Plaintiff that LSU was terminating [identify relationship or agreement] because [quote or accurately describe the SEC restriction and threatened sanction]. The notice is attached as Exhibit [ ].
4. The challenged agreement is evidenced by [identify authenticated rule, minutes, resolution, communications, and participants]. Defendants’ separate acts are set out in Schedule A and the allegations below. References to “Participating Defendants” mean only those defendants whose agreement, direction, or implementation is specifically alleged—not every SEC member or employee by status alone.
II. Parties and capacities
5. Plaintiff Dae’Quan Wright is an individual domiciled in [state]. His enrollment, prior collegiate seasons, professional contract and release dates, remaining eligibility apart from the challenged restriction, and LSU agreement are described in Schedule B.
6. Plaintiff Zxavian Harris is an individual domiciled in [state]. His corresponding history and agreement are described in Schedule B. Each Plaintiff asserts only his own claims and losses unless a later properly supported pleading states otherwise.
7. Defendant Southeastern Conference (“SEC”) is [verify legal form and proper name], with its principal office at [verified Birmingham address]. It promulgates and administers conference rules through [identify governing bodies] and performs the challenged acts described in this complaint.
8. Defendant Greg Sankey is sued individually for his own alleged conduct in [specific proposal, directive, sanction threat, agreement, or implementation, with dates and sources]. His commissioner title is not the sole basis for liability. The SEC is not presumed to be a state actor merely because public universities are members.
9. Defendant Josh Brooks is sued individually for [verified acts]. The alleged public statement is addressed separately below. Plaintiffs do not allege that Brooks personally signed or guaranteed an LSU-player contract without an identified undertaking.
10. Each proposed institutional defendant is identified in Schedule A by its correct legal entity, public/private status, relevant governing body, alleged participation, and relief sought. Athletic departments, university brands, foundations, and athletic associations are not assumed to be interchangeable legal persons.
11. Each individually sued AD and president/chancellor is identified in Schedule A by full name, position during the relevant conduct, personal act, knowledge, causal role, and applicable claim. Where an institution uses both a system president and campus chancellor, Plaintiffs identify the actual decisionmaker rather than treating the titles as interchangeable.
12. For any public official sued for prospective federal relief, Schedule A identifies the ongoing federal violation and the official’s specific enforcement connection. Plaintiffs seek such relief only where legally available. State-law claims are not asserted against state officials in federal court as a means of evading sovereign immunity.
13. [LSU CONTRACT DEFENDANT:] The party to each LSU-related contract is [exact signatory entity]. Claims against that party are included here only upon an established jurisdictional and immunity basis; otherwise they will be pursued in an appropriate separate forum. An affiliated NIL entity is liable only for its own enforceable obligation or actionable conduct.
III. Jurisdiction, venue, and related proceedings
14. This Court has federal-question and antitrust jurisdiction under 28 U.S.C. §§ 1331 and 1337 over the Sherman Act claim. Private antitrust relief is sought under 15 U.S.C. §§ 15 and 26. If the conditionally drafted RICO counts are supported and included, federal jurisdiction also rests on 18 U.S.C. § 1964(c). Diversity is not required for these federal claims.
15. Supplemental jurisdiction over the related state-law claims is invoked under 28 U.S.C. § 1367 only to the extent those claims arise from the same case or controversy and no immunity or other jurisdictional limitation precludes them.
16. Venue is alleged under 28 U.S.C. § 1391(b)(2) because [identify substantial decisionmaking or enforcement events occurring in this district]. The SEC’s location alone does not establish all other defendants’ contacts. Any reliance on 15 U.S.C. § 22 or 18 U.S.C. § 1965 must satisfy the statute’s defendant-specific requirements and controlling circuit law.
17. Personal jurisdiction over each defendant rests on [identify domicile, consent, forum-directed acts giving rise to the claims, or valid statutory service basis]. Schedule A supplies the specific facts. Plaintiffs do not rely solely on nationwide conference membership or an unsupported conspiracy-jurisdiction label.
18. Each Plaintiff suffered or imminently faces [specific loss] from the challenged restriction. [Identify evidence] establishes that [willing school] would contract with or roster him but for that restriction. An injunction would remove that identified barrier. Any independent NCAA rule or independent school decision is addressed expressly, rather than assumed away.
19. Related proceedings include [full case captions, numbers, courts, parties, claims, and status]. The operative orders dated [ ] provide [precise scope]. Plaintiffs seek relief consistent with the actual orders and disclose any overlapping claim. No allegation here assumes an unreviewed news account accurately states an injunction’s operative terms.
I
NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
DAE’QUAN WRIGHT and ZXAVIAN HARRIS,
Plaintiffs,
v.
SOUTHEASTERN CONFERENCE; GREG SANKEY, individually; JOSH BROOKS, individually; the verified institutional defendants and individually named athletic directors and presidents/chancellors identified in Schedule A [expand into caption before filing]; and [appropriate state officials in their official capacities solely for permissible prospective federal relief],
Defendants.
Civil Action No. [to be assigned]
JURY TRIAL DEMANDED
COMPLAINT FOR DAMAGES AND DECLARATORY AND INJUNCTIVE RELIEF
Plaintiffs, through counsel, allege the following upon personal knowledge as to their own acts and upon information and belief, supported by the specifically identified sources, as to other matters. Every bracketed field requires completion or deletion before filing.
I. Nature of the action
1. This action challenges a collective restriction preventing otherwise eligible football players from contracting with and competing for willing SEC member institutions solely because of specified prior professional activity. Plaintiffs challenge the particular restriction and its enforcement; they do not seek exemption from academic, medical, roster, or other independently lawful eligibility requirements.
2. Plaintiffs seek to restore lawful competition for their athletic services, remedy interference with their existing agreements and demonstrated business opportunities, and recover economic losses directly caused by the acts identified.
On [date], [authorized LSU decisionmaker] informed each Plaintiff that LSU was terminating [identify relationship or agreement] because [quote or accurately describe the SEC restriction and threatened sanction]. The notice is attached as Exhibit [ ].
4. The challenged agreement is evidenced by [identify authenticated rule, minutes, resolution, communications, and participants]. Defendants’ separate acts are set out in Schedule A and the allegations below. References to “Participating Defendants” mean only those defendants whose agreement, direction, or implementation is specifically alleged—not every SEC member or employee by status alone.
II. Parties and capacities
5. Plaintiff Dae’Quan Wright is an individual domiciled in [state]. His enrollment, prior collegiate seasons, professional contract and release dates, remaining eligibility apart from the challenged restriction, and LSU agreement are described in Schedule B.
6. Plaintiff Zxavian Harris is an individual domiciled in [state]. His corresponding history and agreement are described in Schedule B. Each Plaintiff asserts only his own claims and losses unless a later properly supported pleading states otherwise.
7. Defendant Southeastern Conference (“SEC”) is [verify legal form and proper name], with its principal office at [verified Birmingham address]. It promulgates and administers conference rules through [identify governing bodies] and performs the challenged acts described in this complaint.
8. Defendant Greg Sankey is sued individually for his own alleged conduct in [specific proposal, directive, sanction threat, agreement, or implementation, with dates and sources]. His commissioner title is not the sole basis for liability. The SEC is not presumed to be a state actor merely because public universities are members.
9. Defendant Josh Brooks is sued individually for [verified acts]. The alleged public statement is addressed separately below. Plaintiffs do not allege that Brooks personally signed or guaranteed an LSU-player contract without an identified undertaking.
10. Each proposed institutional defendant is identified in Schedule A by its correct legal entity, public/private status, relevant governing body, alleged participation, and relief sought. Athletic departments, university brands, foundations, and athletic associations are not assumed to be interchangeable legal persons.
11. Each individually sued AD and president/chancellor is identified in Schedule A by full name, position during the relevant conduct, personal act, knowledge, causal role, and applicable claim. Where an institution uses both a system president and campus chancellor, Plaintiffs identify the actual decisionmaker rather than treating the titles as interchangeable.
12. For any public official sued for prospective federal relief, Schedule A identifies the ongoing federal violation and the official’s specific enforcement connection. Plaintiffs seek such relief only where legally available. State-law claims are not asserted against state officials in federal court as a means of evading sovereign immunity.
13. [LSU CONTRACT DEFENDANT:] The party to each LSU-related contract is [exact signatory entity]. Claims against that party are included here only upon an established jurisdictional and immunity basis; otherwise they will be pursued in an appropriate separate forum. An affiliated NIL entity is liable only for its own enforceable obligation or actionable conduct.
III. Jurisdiction, venue, and related proceedings
14. This Court has federal-question and antitrust jurisdiction under 28 U.S.C. §§ 1331 and 1337 over the Sherman Act claim. Private antitrust relief is sought under 15 U.S.C. §§ 15 and 26. If the conditionally drafted RICO counts are supported and included, federal jurisdiction also rests on 18 U.S.C. § 1964(c). Diversity is not required for these federal claims.
15. Supplemental jurisdiction over the related state-law claims is invoked under 28 U.S.C. § 1367 only to the extent those claims arise from the same case or controversy and no immunity or other jurisdictional limitation precludes them.
16. Venue is alleged under 28 U.S.C. § 1391(b)(2) because [identify substantial decisionmaking or enforcement events occurring in this district]. The SEC’s location alone does not establish all other defendants’ contacts. Any reliance on 15 U.S.C. § 22 or 18 U.S.C. § 1965 must satisfy the statute’s defendant-specific requirements and controlling circuit law.
17. Personal jurisdiction over each defendant rests on [identify domicile, consent, forum-directed acts giving rise to the claims, or valid statutory service basis]. Schedule A supplies the specific facts. Plaintiffs do not rely solely on nationwide conference membership or an unsupported conspiracy-jurisdiction label.
18. Each Plaintiff suffered or imminently faces [specific loss] from the challenged restriction. [Identify evidence] establishes that [willing school] would contract with or roster him but for that restriction. An injunction would remove that identified barrier. Any independent NCAA rule or independent school decision is addressed expressly, rather than assumed away.
19. Related proceedings include [full case captions, numbers, courts, parties, claims, and status]. The operative orders dated [ ] provide [precise scope]. Plaintiffs seek relief consistent with the actual orders and disclose any overlapping claim. No allegation here assumes an unreviewed news account accurately states an injunction’s operative terms.
I
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Posted on 9/3/26 at 10:04 pm to TutHillTiger
Coonasses found out about chat gpt
Posted on 9/3/26 at 10:04 pm to TutHillTiger
Individual eligibility and contractual facts
20. Wright enrolled at [school] on [date], used [number] seasons under [identified rules], entered [professional arrangement] on [date], and left that arrangement on [date and terms]. On [date], [authority] determined or was asked to determine [remaining eligibility]. Exhibits [ ] establish this history.
21. Harris enrolled at [school] on [date], used [number] seasons under [identified rules], entered [professional arrangement] on [date], and left that arrangement on [date and terms]. His independent eligibility basis is [specific rule, waiver, or operative order]. Exhibits [ ] establish this history.
22. On [date], Wright and [entity] entered [written agreement], obligating [performance and compensation]. The agreement’s eligibility conditions, termination provision, dispute-resolution clause, governing law, and signatory authority are [specific terms].
23. On [date], Harris and [entity] entered [written agreement], obligating [performance and compensation]. The corresponding material conditions and provisions are [specific terms]. Oral assurances, scholarship instruments, revenue-sharing contracts, and third-party NIL contracts are identified separately.
24. Before accepting, each Plaintiff received the following assurance from an authorized speaker: [speaker, date, medium, exact substance, and authority]. Each Plaintiff relied by [specific action], causing [identified expense or surrendered opportunity]. Any known SEC/NCAA uncertainty and its effect on the reasonableness of reliance are disclosed.
25. Each Plaintiff performed or was ready and able to perform his obligations, except as excused by [specific conduct or rule]. Conditions precedent were satisfied or excused as follows: [facts]. The complaint does not assume a recruiting commitment guarantees playing time.
26. The challenged termination deprived Wright of [contract amount and dates] and Harris of [contract amount and dates]. Compensation already paid, mitigation income, replacement opportunities, contingencies, and offsets are separately accounted for.
V. The challenged agreement and each defendant’s participation
27. The operative professional-status restriction states [insert the exact authenticated provision and version]. It became effective on [date] through [procedure]. Its treatment of draft declarations, contracts, roster status, actual professional play, and withdrawal is [precise terms].
28. At [meeting, place, date], [identified participants] considered [proposal]. [Identified documentary source] records each institution’s vote or assent. Adoption of the eligibility rule, adoption of penalties, public statements, and later enforcement are distinct acts and must not be conflated.
29. Sankey personally [describe supported act] on [date], knowing [specific contract or recruitment fact]. His communication to [recipient] conveyed [specific enforcement position]. This caused or contributed to [identified decision] through [evidence].
30. Each other individual defendant personally engaged in the act specified for that defendant in Schedule A. [Insert individualized facts supporting knowing agreement or intentional conduct; avoid an allegation that all officials performed every act.]
31. The specified participating institutions agreed to [precise refusal-to-deal or eligibility restriction] and implemented it by [conduct]. The challenged concerted activity is distinct from any institution’s unilateral decision not to recruit a player.
32. The threatened penalties were [exact authenticated penalties and governing provisions]. On [date], [defendant] communicated to LSU that [specific consequence] would follow [specific act]. Whether any penalty was assessed, paid, rescinded, or restrained is [verified status].
33. On [date], LSU’s [decisionmaker] relied on [specific directive] to terminate [relationship]. [Document/testimony] establishes the causal link and identifies any independent reason for the decision. Plaintiffs do not attribute termination to every public critic without evidence.
34. [IF SUPPORTED:] Similar communications to [other willing schools] resulted in [specific withdrawals]. This evidence bears on broader market exclusion and mitigation, not merely the publicity surrounding Plaintiffs.
35. [IF SUPPORTED:] Communications with other conferences on [dates] reflect [actual agreement and participants]. Parallel policies alone are not pleaded as proof of an interconference agreement.
VI. Georgia AD public statement and alleged interference
36. [UNVERIFIED—DO NOT FILE AS FACT:] On [date and time], Josh Brooks made the following statement at [event/platform]: “[insert authenticated words].” The complete recording or publication, not an isolated excerpt, is Exhibit [ ]. No particular wording has been supplied or independently authenticated for this draft.
37. Before making the statement, Brooks knew of [specific enforceable Plaintiff contract or identifiable business relationship] because [communication or source]. The statement was directed to [recipient/audience] and allegedly sought [specific breach, withdrawal, or refusal].
38. [IF EVIDENCE SUPPORTS:] Brooks also communicated privately with [person] on [date], requesting [specific action]. [Decisionmaker] received and acted on that communication or public statement in [specific way]. This conduct caused [specific contractual loss], independently or in combination with the identified conference directive.
39. Plaintiffs allege lack of justification based on [facts meeting the governing state’s standard]. They address Brooks’s asserted interest in conference governance and any applicable official privilege through [specific facts]. Mere criticism, a policy opinion, or an accurate statement of an existing rule is not alleged to be a freestanding contract breach.
40. The claim against Brooks is intentional interference, subject to governing law and the facts just described. A direct breach-of-contract claim against him is included only if [identify a contract binding him personally]; absent that
20. Wright enrolled at [school] on [date], used [number] seasons under [identified rules], entered [professional arrangement] on [date], and left that arrangement on [date and terms]. On [date], [authority] determined or was asked to determine [remaining eligibility]. Exhibits [ ] establish this history.
21. Harris enrolled at [school] on [date], used [number] seasons under [identified rules], entered [professional arrangement] on [date], and left that arrangement on [date and terms]. His independent eligibility basis is [specific rule, waiver, or operative order]. Exhibits [ ] establish this history.
22. On [date], Wright and [entity] entered [written agreement], obligating [performance and compensation]. The agreement’s eligibility conditions, termination provision, dispute-resolution clause, governing law, and signatory authority are [specific terms].
23. On [date], Harris and [entity] entered [written agreement], obligating [performance and compensation]. The corresponding material conditions and provisions are [specific terms]. Oral assurances, scholarship instruments, revenue-sharing contracts, and third-party NIL contracts are identified separately.
24. Before accepting, each Plaintiff received the following assurance from an authorized speaker: [speaker, date, medium, exact substance, and authority]. Each Plaintiff relied by [specific action], causing [identified expense or surrendered opportunity]. Any known SEC/NCAA uncertainty and its effect on the reasonableness of reliance are disclosed.
25. Each Plaintiff performed or was ready and able to perform his obligations, except as excused by [specific conduct or rule]. Conditions precedent were satisfied or excused as follows: [facts]. The complaint does not assume a recruiting commitment guarantees playing time.
26. The challenged termination deprived Wright of [contract amount and dates] and Harris of [contract amount and dates]. Compensation already paid, mitigation income, replacement opportunities, contingencies, and offsets are separately accounted for.
V. The challenged agreement and each defendant’s participation
27. The operative professional-status restriction states [insert the exact authenticated provision and version]. It became effective on [date] through [procedure]. Its treatment of draft declarations, contracts, roster status, actual professional play, and withdrawal is [precise terms].
28. At [meeting, place, date], [identified participants] considered [proposal]. [Identified documentary source] records each institution’s vote or assent. Adoption of the eligibility rule, adoption of penalties, public statements, and later enforcement are distinct acts and must not be conflated.
29. Sankey personally [describe supported act] on [date], knowing [specific contract or recruitment fact]. His communication to [recipient] conveyed [specific enforcement position]. This caused or contributed to [identified decision] through [evidence].
30. Each other individual defendant personally engaged in the act specified for that defendant in Schedule A. [Insert individualized facts supporting knowing agreement or intentional conduct; avoid an allegation that all officials performed every act.]
31. The specified participating institutions agreed to [precise refusal-to-deal or eligibility restriction] and implemented it by [conduct]. The challenged concerted activity is distinct from any institution’s unilateral decision not to recruit a player.
32. The threatened penalties were [exact authenticated penalties and governing provisions]. On [date], [defendant] communicated to LSU that [specific consequence] would follow [specific act]. Whether any penalty was assessed, paid, rescinded, or restrained is [verified status].
33. On [date], LSU’s [decisionmaker] relied on [specific directive] to terminate [relationship]. [Document/testimony] establishes the causal link and identifies any independent reason for the decision. Plaintiffs do not attribute termination to every public critic without evidence.
34. [IF SUPPORTED:] Similar communications to [other willing schools] resulted in [specific withdrawals]. This evidence bears on broader market exclusion and mitigation, not merely the publicity surrounding Plaintiffs.
35. [IF SUPPORTED:] Communications with other conferences on [dates] reflect [actual agreement and participants]. Parallel policies alone are not pleaded as proof of an interconference agreement.
VI. Georgia AD public statement and alleged interference
36. [UNVERIFIED—DO NOT FILE AS FACT:] On [date and time], Josh Brooks made the following statement at [event/platform]: “[insert authenticated words].” The complete recording or publication, not an isolated excerpt, is Exhibit [ ]. No particular wording has been supplied or independently authenticated for this draft.
37. Before making the statement, Brooks knew of [specific enforceable Plaintiff contract or identifiable business relationship] because [communication or source]. The statement was directed to [recipient/audience] and allegedly sought [specific breach, withdrawal, or refusal].
38. [IF EVIDENCE SUPPORTS:] Brooks also communicated privately with [person] on [date], requesting [specific action]. [Decisionmaker] received and acted on that communication or public statement in [specific way]. This conduct caused [specific contractual loss], independently or in combination with the identified conference directive.
39. Plaintiffs allege lack of justification based on [facts meeting the governing state’s standard]. They address Brooks’s asserted interest in conference governance and any applicable official privilege through [specific facts]. Mere criticism, a policy opinion, or an accurate statement of an existing rule is not alleged to be a freestanding contract breach.
40. The claim against Brooks is intentional interference, subject to governing law and the facts just described. A direct breach-of-contract claim against him is included only if [identify a contract binding him personally]; absent that
Posted on 9/3/26 at 10:05 pm to TutHillTiger
LSU Nation is laughing at Sankey and the rest of the SEC. Winning the natty this year will just be the cherry on top.
Posted on 9/3/26 at 10:05 pm to ManBearSharkReb
STTDB
Posted on 9/3/26 at 10:05 pm to genuineLSUtiger
VII. Relevant market, competitive injury, and alternatives
41. The proposed relevant product market is the acquisition of football athletic services from otherwise eligible players by NCAA Division I FBS institutions, with compensation including permissible school payments and education-related benefits. Plaintiffs will establish the market through actual recruiting choices, substitution evidence, compensation data, and expert analysis. Third-party NIL opportunities are analyzed separately rather than automatically equated with school compensation.
42. The proposed geographic market is nationwide because [supported recruiting and mobility facts]. A narrower SEC-only market is not assumed merely because the challenged rule belongs to the SEC. If a submarket is asserted, its boundaries and economic support will be specifically pleaded.
43. Participating schools compete to obtain players’ services and have separate budgets, recruiting needs, and incentives. Their collective restriction eliminated independent decisions that [identified schools] otherwise would have made regarding [identified eligible players].
44. The agreement’s market-wide effect is [quantified exclusion, reduced recruiting bids, reduced compensated opportunities, or compensation suppression], supported by [data and witnesses]. Defendants’ market power is shown by [shares of recruitment, spending, relevant opportunities, and switching constraints], or actual anticompetitive effects by [specific evidence]. Injury to these Plaintiffs alone is not the entire competitive-effects allegation.
45. Professional leagues, other collegiate divisions, and non-SEC FBS schools are evaluated as possible substitutes based on actual opportunities, eligibility, compensation, educational benefits, and recruiting evidence. Plaintiffs do not assume professional football is never a substitute, especially given their own professional participation.
46. Defendants may assert educational connection, competitive balance, roster stability, or differentiation from professional sports. Plaintiffs allege those objectives can be achieved substantially as effectively through less restrictive measures: [supported individualized eligibility review, remaining-season limits, academic requirements, limited transition relief, or other concrete alternative]. Costs, administrability, and effects on incoming players must be addressed.
47. The injury claimed is the loss of competitive access to willing buyers and associated economic loss caused by the challenged restraint. The same injury would not have occurred absent the restriction because [specific willing-buyer and independent-eligibility evidence]. Plaintiffs seek no automatic roster position or guaranteed playing time.
COUNT I — Unreasonable restraint of trade; Sherman Act § 1
48. Plaintiffs incorporate the factual allegations in Sections II–VII, but not unsupported conditional allegations in other counts. This count is asserted against the SEC and only those institutional and individual Participating Defendants identified with supporting acts in Schedule A, subject to immunity and jurisdiction.
49. Those defendants entered and implemented the agreement described in Section V, restraining interstate trade in the relevant athletic-services market. The agreement affected interstate recruitment, compensation, travel, and commercial competition.
50. Under the rule of reason, the agreement caused substantial anticompetitive effects described in Section VII. The asserted justifications do not outweigh those harms, and supported less restrictive alternatives would accomplish the legitimate objectives substantially as effectively.
51. Each Plaintiff suffered antitrust injury and directly resulting business or property loss. Plaintiffs seek actual damages trebled under 15 U.S.C. § 15, recoverable fees and costs, and relief against threatened antitrust injury under 15 U.S.C. § 26. Any defendant-specific immunity or remedy limit is addressed separately.
COUNT II — Breach of contract; actual contracting defendants only
52. Plaintiffs incorporate Section IV and the specific termination allegations in Section V. This count applies only to [identify the contracting entity for each Plaintiff], and only in a forum with jurisdiction over that claim and defendant.
53. The agreements identified in Section IV are valid and enforceable under [governing law]. Plaintiffs performed, tendered performance, or were excused as specifically alleged. Defendant breached [identify exact obligation and clause] by [act] on [date].
54. The relied-on eligibility or termination condition does not excuse this breach because [contract-specific construction and facts]. If eligibility was an express unsatisfied condition outside Defendant’s responsibility, that issue must be resolved rather than omitted.
55. The breach caused [unpaid guaranteed sums, recoverable consequential loss, or other contract damages], less applicable offsets. Any fee claim rests on [contractual provision or statute]. No breach claim is asserted against a non-signatory merely because that person advocated enforcement of the rule.
COUNT III — Detrimental reliance; Louisiana Civil Code article 1967
56. In the alternative to the contract claim, and where Louisiana law governs, Plaintiffs incorporate the particular assurances and reliance alleged in Section IV. This count is against [the identified promisor or legally responsible entity].
57. On [date], Defendant promised [specific undertaking], knowing or reasonably expected to know that Plaintiff would rely by [specific act]. Plaintiff reasonably relied because [facts accounting for known eligibility uncertainty and speaker authority].
58. Plaintiff suffered [identified expenses or lost opportunities] because of that reliance. Recovery is sought within article 1967’s limits and without duplication of contract recovery. A decision to leave a professional opportunity is alleged only if documented and causally linked to the promise.
COUNT IV — Intentional interference with contract or business relations
59. Plaintiffs incorporate Sections IV–VI. This count applies separately to Sankey, Brooks, and any other identified defendant whose own conduct satisfies the selected state’s elements. Counsel must select the governing law after choice-of-law analysis; the alternatives below are not interchangeable.
60. [ALABAMA ALTERNATIVE:] Plaintiff had the specifically identified protectable contract or business relationship; Defendant knew of it; Defendant was a stranger to that relationship under Alabama law because [facts overcoming the asserted conference or institutional economic interest]; Defendant intentionally interfered by [specific act]; and Plaintiff suffered [caused loss]. The alleged absence of justification is supported by [facts], recognizing justification as a defense.
61. [LOUISIANA ALTERNATIVE—NARROW OFFICER THEORY ONLY:] [Officer] intentionally and unjustifiably caused [his or her corporation] to breach or render more burdensome its contract with Plaintiff, knowing that contract and acting outside the applicable privilege because [specific facts]. This alternative is not used to assert that Spurney automatically authorizes an SEC outsider claim concerning LSU’s contracts.
62. Brooks’s conduct consists of the authenticated statement and any supported related acts in Section VI. Plaintiffs allege a causal link to an actual decision, not merely public dissemination. Defendant is liable for [specified damage], with punitive damages only where the governing law authorizes them and the required culpability is established.
41. The proposed relevant product market is the acquisition of football athletic services from otherwise eligible players by NCAA Division I FBS institutions, with compensation including permissible school payments and education-related benefits. Plaintiffs will establish the market through actual recruiting choices, substitution evidence, compensation data, and expert analysis. Third-party NIL opportunities are analyzed separately rather than automatically equated with school compensation.
42. The proposed geographic market is nationwide because [supported recruiting and mobility facts]. A narrower SEC-only market is not assumed merely because the challenged rule belongs to the SEC. If a submarket is asserted, its boundaries and economic support will be specifically pleaded.
43. Participating schools compete to obtain players’ services and have separate budgets, recruiting needs, and incentives. Their collective restriction eliminated independent decisions that [identified schools] otherwise would have made regarding [identified eligible players].
44. The agreement’s market-wide effect is [quantified exclusion, reduced recruiting bids, reduced compensated opportunities, or compensation suppression], supported by [data and witnesses]. Defendants’ market power is shown by [shares of recruitment, spending, relevant opportunities, and switching constraints], or actual anticompetitive effects by [specific evidence]. Injury to these Plaintiffs alone is not the entire competitive-effects allegation.
45. Professional leagues, other collegiate divisions, and non-SEC FBS schools are evaluated as possible substitutes based on actual opportunities, eligibility, compensation, educational benefits, and recruiting evidence. Plaintiffs do not assume professional football is never a substitute, especially given their own professional participation.
46. Defendants may assert educational connection, competitive balance, roster stability, or differentiation from professional sports. Plaintiffs allege those objectives can be achieved substantially as effectively through less restrictive measures: [supported individualized eligibility review, remaining-season limits, academic requirements, limited transition relief, or other concrete alternative]. Costs, administrability, and effects on incoming players must be addressed.
47. The injury claimed is the loss of competitive access to willing buyers and associated economic loss caused by the challenged restraint. The same injury would not have occurred absent the restriction because [specific willing-buyer and independent-eligibility evidence]. Plaintiffs seek no automatic roster position or guaranteed playing time.
COUNT I — Unreasonable restraint of trade; Sherman Act § 1
48. Plaintiffs incorporate the factual allegations in Sections II–VII, but not unsupported conditional allegations in other counts. This count is asserted against the SEC and only those institutional and individual Participating Defendants identified with supporting acts in Schedule A, subject to immunity and jurisdiction.
49. Those defendants entered and implemented the agreement described in Section V, restraining interstate trade in the relevant athletic-services market. The agreement affected interstate recruitment, compensation, travel, and commercial competition.
50. Under the rule of reason, the agreement caused substantial anticompetitive effects described in Section VII. The asserted justifications do not outweigh those harms, and supported less restrictive alternatives would accomplish the legitimate objectives substantially as effectively.
51. Each Plaintiff suffered antitrust injury and directly resulting business or property loss. Plaintiffs seek actual damages trebled under 15 U.S.C. § 15, recoverable fees and costs, and relief against threatened antitrust injury under 15 U.S.C. § 26. Any defendant-specific immunity or remedy limit is addressed separately.
COUNT II — Breach of contract; actual contracting defendants only
52. Plaintiffs incorporate Section IV and the specific termination allegations in Section V. This count applies only to [identify the contracting entity for each Plaintiff], and only in a forum with jurisdiction over that claim and defendant.
53. The agreements identified in Section IV are valid and enforceable under [governing law]. Plaintiffs performed, tendered performance, or were excused as specifically alleged. Defendant breached [identify exact obligation and clause] by [act] on [date].
54. The relied-on eligibility or termination condition does not excuse this breach because [contract-specific construction and facts]. If eligibility was an express unsatisfied condition outside Defendant’s responsibility, that issue must be resolved rather than omitted.
55. The breach caused [unpaid guaranteed sums, recoverable consequential loss, or other contract damages], less applicable offsets. Any fee claim rests on [contractual provision or statute]. No breach claim is asserted against a non-signatory merely because that person advocated enforcement of the rule.
COUNT III — Detrimental reliance; Louisiana Civil Code article 1967
56. In the alternative to the contract claim, and where Louisiana law governs, Plaintiffs incorporate the particular assurances and reliance alleged in Section IV. This count is against [the identified promisor or legally responsible entity].
57. On [date], Defendant promised [specific undertaking], knowing or reasonably expected to know that Plaintiff would rely by [specific act]. Plaintiff reasonably relied because [facts accounting for known eligibility uncertainty and speaker authority].
58. Plaintiff suffered [identified expenses or lost opportunities] because of that reliance. Recovery is sought within article 1967’s limits and without duplication of contract recovery. A decision to leave a professional opportunity is alleged only if documented and causally linked to the promise.
COUNT IV — Intentional interference with contract or business relations
59. Plaintiffs incorporate Sections IV–VI. This count applies separately to Sankey, Brooks, and any other identified defendant whose own conduct satisfies the selected state’s elements. Counsel must select the governing law after choice-of-law analysis; the alternatives below are not interchangeable.
60. [ALABAMA ALTERNATIVE:] Plaintiff had the specifically identified protectable contract or business relationship; Defendant knew of it; Defendant was a stranger to that relationship under Alabama law because [facts overcoming the asserted conference or institutional economic interest]; Defendant intentionally interfered by [specific act]; and Plaintiff suffered [caused loss]. The alleged absence of justification is supported by [facts], recognizing justification as a defense.
61. [LOUISIANA ALTERNATIVE—NARROW OFFICER THEORY ONLY:] [Officer] intentionally and unjustifiably caused [his or her corporation] to breach or render more burdensome its contract with Plaintiff, knowing that contract and acting outside the applicable privilege because [specific facts]. This alternative is not used to assert that Spurney automatically authorizes an SEC outsider claim concerning LSU’s contracts.
62. Brooks’s conduct consists of the authenticated statement and any supported related acts in Section VI. Plaintiffs allege a causal link to an actual decision, not merely public dissemination. Defendant is liable for [specified damage], with punitive damages only where the governing law authorizes them and the required culpability is established.
Posted on 9/3/26 at 10:07 pm to TutHillTiger
COUNT V — Louisiana unfair trade practices; conditional alternative
63. Where Louisiana law applies and the defendant is subject to this remedy, Plaintiffs incorporate the specific commercial conduct described in Sections IV–VI. Under La. R.S. 51:1405 and 51:1409, [defendant] engaged in [particular unfair or deceptive commercial act beyond a mere breach or ordinary competitive conduct].
64. That act caused Plaintiff an ascertainable monetary or movable-property loss of [amount and causal explanation]. Plaintiffs seek authorized actual damages and fees, subject to standing, statutory exclusions, and other applicable limitations. Enhanced statutory damages are not requested absent their additional statutory prerequisites.
COUNT VI — Intentional misrepresentation; conditional alternative
65. This count is asserted only against [specific speaker and any legally responsible entity] and incorporates only the identified representation, reliance, and damage facts. On [date], at [place or medium], [speaker] stated [exact materially false fact]. The statement was false when made because [existing fact], and knowledge or intent is supported by [particular circumstances].
66. Defendant intended Plaintiff to act by [specific conduct]. Plaintiff reasonably or justifiably relied, as required by [governing state law], by [act] and suffered [direct loss]. This count does not infer fraud solely from later nonperformance or a disputed legal position. All Rule 9(b) details must be completed.
COUNT VII — Civil conspiracy; derivative liability
67. Plaintiffs incorporate the specifically pleaded underlying intentional wrong in Count [IV, V, or VI, as governing law permits]. [Named participants] agreed on [date or supported period] to accomplish [actionable objective] through [specific acts], causing [loss].
68. This is a theory of liability for a supported underlying wrong, not a freestanding claim that lawful collective governance is tortious. Where Louisiana law applies, Plaintiffs invoke Civil Code article 2324; elsewhere they identify the governing state rule. Applicable intracorporate-conspiracy limitations and the role of separately competing institutions must be addressed.
COUNT VIII — Civil RICO; 18 U.S.C. §§ 1962(c), 1964(c)
69. CONDITIONAL COUNT—REMOVE UNLESS PREDICATE FACTS ARE SUPPORTED. Plaintiffs incorporate only [specify completed factual paragraphs and Schedule C]. The current materials do not establish racketeering. Inclusion of this count in the working draft is not an accusation that any identified person committed a crime.
70. The RICO person or persons are [specific defendants]. The enterprise is [precisely identified legal entity or association-in-fact], distinct from each § 1962(c) defendant as required by law. If association-in-fact is used, its common purpose, relationships, and sufficient longevity are [particular facts]. A conference’s lawful existence is not proof of a racketeering enterprise.
71. Each RICO defendant conducted or participated in the operation or management of the enterprise’s affairs by [specific direction or decision], rather than merely associating with it. The enterprise affected interstate commerce through [facts].
72. The qualifying predicate acts are [offense and statutory subsection], described individually in Schedule C with actor, date, means, victim, property, and supporting evidence. If mail or wire fraud is alleged, identify the material deception, intent, money or property sought, and qualifying use of mail or interstate wires. A public rule announcement or ordinary email is not fraud merely because it helps implement a disputed rule.
73. If extortion is alleged, identify the applicable predicate statute, property sought to be obtained, intended recipient, wrongful means, and statutory nexus. A threat to impose institutional penalties, without the offense’s required elements, is not alleged as extortion. Antitrust violations and interference torts are not themselves RICO predicates.
74. The predicates are related through [facts] and exhibit closed-ended or open-ended continuity through [supported duration, repetition, and threatened continuation]. Two communications concerning one finite eligibility dispute do not alone establish continuity.
75. Each Plaintiff suffered a domestic business or property injury of [specified loss] directly and proximately caused by [predicate scheme], as distinguished from injury caused only by the eligibility policy. The causal chain and absence of a more directly injured claimant are [facts]. Plaintiffs seek qualifying damages trebled and fees under § 1964(c), without double recovery.
COUNT IX — RICO conspiracy; 18 U.S.C. § 1962(d)
76. CONDITIONAL COUNT—REMOVE UNLESS SUPPORTED. Plaintiffs incorporate the completed enterprise and predicate allegations in Count VIII and Schedule C. [Each specified defendant] knowingly agreed to facilitate the enterprise’s affairs through the identified pattern of racketeering, as shown by [particular agreement facts].
77. Plaintiffs’ business or property injury resulted from [an independently actionable act in furtherance of that RICO conspiracy]. This count does not rest solely on agreement to vote for conference rules, and does not cure a missing racketeering objective or missing injury.
VIII. Equitable relief and damages
78. Plaintiffs request declaratory relief under 28 U.S.C. §§ 2201–2202 resolving the actual federal controversy identified above. These statutes supply a remedy, not an independent substantive wrong or a substitute for jurisdiction.
79. Plaintiffs seek an injunction against enforcement of the specified restriction and against sanctions imposed solely because a willing institution permits the identified Plaintiffs to participate pursuant to lawful eligibility relief. Any protection against later penalties must be specifically supported and tailored to the controversy.
80. The imminent irreparable injury is [lost, nonrepeatable season or developmental opportunity supported by declaration], not merely delayed receipt of calculable money. Plaintiffs address likely success, balance of equities, public interest, notice, and security in a separate Rule 65 motion. No emergency order is represented as already obtained.
81. Plaintiffs do not seek guaranteed playing time, displacement of an identified third-party player without an established basis, or blanket invalidation of unrelated rules. Any mandatory roster or contractual performance relief requires a separate legal and factual showing.
82. Plaintiffs seek provable unpaid contractual compensation, lost opportunities established with reasonable certainty, reliance expenses, and other legally recoverable economic loss. Speculative career earnings, conference gross revenue, and injuries to unnamed athletes are not substituted for Plaintiffs’ actual loss.
83. [REQUESTED DEMAND—REQUIRES EVIDENTIARY SUPPORT:] Plaintiffs allege aggregate compensatory damages exceeding $100,000,000, before statutory trebling, supported by [identify Plaintiff-specific computation and evidence]. If the verified computation does not support that threshold, replace it with damages to be established at trial. The threshold is not asserted separately against each defendant.
84. Statutory multipliers apply only to damages qualifying under the respective statute, and overlapping antitrust, RICO, contract, and tort injuries may not be recovered twice. Joint and several liability is sought only where the substantive law authorizes it; it is not presumed across all defendants or counts.
63. Where Louisiana law applies and the defendant is subject to this remedy, Plaintiffs incorporate the specific commercial conduct described in Sections IV–VI. Under La. R.S. 51:1405 and 51:1409, [defendant] engaged in [particular unfair or deceptive commercial act beyond a mere breach or ordinary competitive conduct].
64. That act caused Plaintiff an ascertainable monetary or movable-property loss of [amount and causal explanation]. Plaintiffs seek authorized actual damages and fees, subject to standing, statutory exclusions, and other applicable limitations. Enhanced statutory damages are not requested absent their additional statutory prerequisites.
COUNT VI — Intentional misrepresentation; conditional alternative
65. This count is asserted only against [specific speaker and any legally responsible entity] and incorporates only the identified representation, reliance, and damage facts. On [date], at [place or medium], [speaker] stated [exact materially false fact]. The statement was false when made because [existing fact], and knowledge or intent is supported by [particular circumstances].
66. Defendant intended Plaintiff to act by [specific conduct]. Plaintiff reasonably or justifiably relied, as required by [governing state law], by [act] and suffered [direct loss]. This count does not infer fraud solely from later nonperformance or a disputed legal position. All Rule 9(b) details must be completed.
COUNT VII — Civil conspiracy; derivative liability
67. Plaintiffs incorporate the specifically pleaded underlying intentional wrong in Count [IV, V, or VI, as governing law permits]. [Named participants] agreed on [date or supported period] to accomplish [actionable objective] through [specific acts], causing [loss].
68. This is a theory of liability for a supported underlying wrong, not a freestanding claim that lawful collective governance is tortious. Where Louisiana law applies, Plaintiffs invoke Civil Code article 2324; elsewhere they identify the governing state rule. Applicable intracorporate-conspiracy limitations and the role of separately competing institutions must be addressed.
COUNT VIII — Civil RICO; 18 U.S.C. §§ 1962(c), 1964(c)
69. CONDITIONAL COUNT—REMOVE UNLESS PREDICATE FACTS ARE SUPPORTED. Plaintiffs incorporate only [specify completed factual paragraphs and Schedule C]. The current materials do not establish racketeering. Inclusion of this count in the working draft is not an accusation that any identified person committed a crime.
70. The RICO person or persons are [specific defendants]. The enterprise is [precisely identified legal entity or association-in-fact], distinct from each § 1962(c) defendant as required by law. If association-in-fact is used, its common purpose, relationships, and sufficient longevity are [particular facts]. A conference’s lawful existence is not proof of a racketeering enterprise.
71. Each RICO defendant conducted or participated in the operation or management of the enterprise’s affairs by [specific direction or decision], rather than merely associating with it. The enterprise affected interstate commerce through [facts].
72. The qualifying predicate acts are [offense and statutory subsection], described individually in Schedule C with actor, date, means, victim, property, and supporting evidence. If mail or wire fraud is alleged, identify the material deception, intent, money or property sought, and qualifying use of mail or interstate wires. A public rule announcement or ordinary email is not fraud merely because it helps implement a disputed rule.
73. If extortion is alleged, identify the applicable predicate statute, property sought to be obtained, intended recipient, wrongful means, and statutory nexus. A threat to impose institutional penalties, without the offense’s required elements, is not alleged as extortion. Antitrust violations and interference torts are not themselves RICO predicates.
74. The predicates are related through [facts] and exhibit closed-ended or open-ended continuity through [supported duration, repetition, and threatened continuation]. Two communications concerning one finite eligibility dispute do not alone establish continuity.
75. Each Plaintiff suffered a domestic business or property injury of [specified loss] directly and proximately caused by [predicate scheme], as distinguished from injury caused only by the eligibility policy. The causal chain and absence of a more directly injured claimant are [facts]. Plaintiffs seek qualifying damages trebled and fees under § 1964(c), without double recovery.
COUNT IX — RICO conspiracy; 18 U.S.C. § 1962(d)
76. CONDITIONAL COUNT—REMOVE UNLESS SUPPORTED. Plaintiffs incorporate the completed enterprise and predicate allegations in Count VIII and Schedule C. [Each specified defendant] knowingly agreed to facilitate the enterprise’s affairs through the identified pattern of racketeering, as shown by [particular agreement facts].
77. Plaintiffs’ business or property injury resulted from [an independently actionable act in furtherance of that RICO conspiracy]. This count does not rest solely on agreement to vote for conference rules, and does not cure a missing racketeering objective or missing injury.
VIII. Equitable relief and damages
78. Plaintiffs request declaratory relief under 28 U.S.C. §§ 2201–2202 resolving the actual federal controversy identified above. These statutes supply a remedy, not an independent substantive wrong or a substitute for jurisdiction.
79. Plaintiffs seek an injunction against enforcement of the specified restriction and against sanctions imposed solely because a willing institution permits the identified Plaintiffs to participate pursuant to lawful eligibility relief. Any protection against later penalties must be specifically supported and tailored to the controversy.
80. The imminent irreparable injury is [lost, nonrepeatable season or developmental opportunity supported by declaration], not merely delayed receipt of calculable money. Plaintiffs address likely success, balance of equities, public interest, notice, and security in a separate Rule 65 motion. No emergency order is represented as already obtained.
81. Plaintiffs do not seek guaranteed playing time, displacement of an identified third-party player without an established basis, or blanket invalidation of unrelated rules. Any mandatory roster or contractual performance relief requires a separate legal and factual showing.
82. Plaintiffs seek provable unpaid contractual compensation, lost opportunities established with reasonable certainty, reliance expenses, and other legally recoverable economic loss. Speculative career earnings, conference gross revenue, and injuries to unnamed athletes are not substituted for Plaintiffs’ actual loss.
83. [REQUESTED DEMAND—REQUIRES EVIDENTIARY SUPPORT:] Plaintiffs allege aggregate compensatory damages exceeding $100,000,000, before statutory trebling, supported by [identify Plaintiff-specific computation and evidence]. If the verified computation does not support that threshold, replace it with damages to be established at trial. The threshold is not asserted separately against each defendant.
84. Statutory multipliers apply only to damages qualifying under the respective statute, and overlapping antitrust, RICO, contract, and tort injuries may not be recovered twice. Joint and several liability is sought only where the substantive law authorizes it; it is not presumed across all defendants or counts.
Posted on 9/3/26 at 10:08 pm to TutHillTiger
Who would read that wall of text?
Posted on 9/3/26 at 10:09 pm to ColoradoAg
limitations. Enhanced statutory damages are not requested absent their additional statutory prerequisites.
COUNT VI — Intentional misrepresentation; conditional alternative
65. This count is asserted only against [specific speaker and any legally responsible entity] and incorporates only the identified representation, reliance, and damage facts. On [date], at [place or medium], [speaker] stated [exact materially false fact]. The statement was false when made because [existing fact], and knowledge or intent is supported by [particular circumstances].
66. Defendant intended Plaintiff to act by [specific conduct]. Plaintiff reasonably or justifiably relied, as required by [governing state law], by [act] and suffered [direct loss]. This count does not infer fraud solely from later nonperformance or a disputed legal position. All Rule 9(b) details must be completed.
COUNT VII — Civil conspiracy; derivative liability
67. Plaintiffs incorporate the specifically pleaded underlying intentional wrong in Count [IV, V, or VI, as governing law permits]. [Named participants] agreed on [date or supported period] to accomplish [actionable objective] through [specific acts], causing [loss].
68. This is a theory of liability for a supported underlying wrong, not a freestanding claim that lawful collective governance is tortious. Where Louisiana law applies, Plaintiffs invoke Civil Code article 2324; elsewhere they identify the governing state rule. Applicable intracorporate-conspiracy limitations and the role of separately competing institutions must be addressed.
COUNT VIII — Civil RICO; 18 U.S.C. §§ 1962(c), 1964(c)
69. CONDITIONAL COUNT—REMOVE UNLESS PREDICATE FACTS ARE SUPPORTED. Plaintiffs incorporate only [specify completed factual paragraphs and Schedule C]. The current materials do not establish racketeering. Inclusion of this count in the working draft is not an accusation that any identified person committed a crime.
70. The RICO person or persons are [specific defendants]. The enterprise is [precisely identified legal entity or association-in-fact], distinct from each § 1962(c) defendant as required by law. If association-in-fact is used, its common purpose, relationships, and sufficient longevity are [particular facts]. A conference’s lawful existence is not proof of a racketeering enterprise.
71. Each RICO defendant conducted or participated in the operation or management of the enterprise’s affairs by [specific direction or decision], rather than merely associating with it. The enterprise affected interstate commerce through [facts].
72. The qualifying predicate acts are [offense and statutory subsection], described individually in Schedule C with actor, date, means, victim, property, and supporting evidence. If mail or wire fraud is alleged, identify the material deception, intent, money or property sought, and qualifying use of mail or interstate wires. A public rule announcement or ordinary email is not fraud merely because it helps implement a disputed rule.
73. If extortion is alleged, identify the applicable predicate statute, property sought to be obtained, intended recipient, wrongful means, and statutory nexus. A threat to impose institutional penalties, without the offense’s required elements, is not alleged as extortion. Antitrust violations and interference torts are not themselves RICO predicates.
74. The predicates are related through [facts] and exhibit closed-ended or open-ended continuity through [supported duration, repetition, and threatened continuation]. Two communications concerning one finite eligibility dispute do not alone establish continuity.
75. Each Plaintiff suffered a domestic business or property injury of [specified loss] directly and proximately caused by [predicate scheme], as distinguished from injury caused only by the eligibility policy. The causal chain and absence of a more directly injured claimant are [facts]. Plaintiffs seek qualifying damages trebled and fees under § 1964(c), without double recovery.
COUNT IX — RICO conspiracy; 18 U.S.C. § 1962(d)
76. CONDITIONAL COUNT—REMOVE UNLESS SUPPORTED. Plaintiffs incorporate the completed enterprise and predicate allegations in Count VIII and Schedule C. [Each specified defendant] knowingly agreed to facilitate the enterprise’s affairs through the identified pattern of racketeering, as shown by [particular agreement facts].
77. Plaintiffs’ business or property injury resulted from [an independently actionable act in furtherance of that RICO conspiracy]. This count does not rest solely on agreement to vote for conference rules, and does not cure a missing racketeering objective or missing injury.
VIII. Equitable relief and damages
78. Plaintiffs request declaratory relief under 28 U.S.C. §§ 2201–2202 resolving the actual federal controversy identified above. These statutes supply a remedy, not an independent substantive wrong or a substitute for jurisdiction.
79. Plaintiffs seek an injunction against enforcement of the specified restriction and against sanctions imposed solely because a willing institution permits the identified Plaintiffs to participate pursuant to lawful eligibility relief. Any protection against later penalties must be specifically supported and tailored to the controversy.
80. The imminent irreparable injury is [lost, nonrepeatable season or developmental opportunity supported by declaration], not merely delayed receipt of calculable money. Plaintiffs address likely success, balance of equities, public interest, notice, and security in a separate Rule 65 motion. No emergency order is represented as already obtained.
81. Plaintiffs do not seek guaranteed playing time, displacement of an identified third-party player without an established basis, or blanket invalidation of unrelated rules. Any mandatory roster or contractual performance relief requires a separate legal and factual showing.
82. Plaintiffs seek provable unpaid contractual compensation, lost opportunities established with reasonable certainty, reliance expenses, and other legally recoverable economic loss. Speculative career earnings, conference gross revenue, and injuries to unnamed athletes are not substituted for Plaintiffs’ actual loss.
83. [REQUESTED DEMAND—REQUIRES EVIDENTIARY SUPPORT:] Plaintiffs allege aggregate compensatory damages exceeding $100,000,000, before statutory trebling, supported by [identify Plaintiff-specific computation and evidence]. If the verified computation does not support that threshold, replace it with damages to be established at trial. The threshold is not asserted separately against each defendant.
84. Statutory multipliers apply only to damages qualifying under the respective statute, and overlapping antitrust, RICO, contract, and tort injuries may not be recovered twice. Joint and several liability is sought only where the substantive law authorizes it; it is not presumed across all defendants or counts.
COUNT VI — Intentional misrepresentation; conditional alternative
65. This count is asserted only against [specific speaker and any legally responsible entity] and incorporates only the identified representation, reliance, and damage facts. On [date], at [place or medium], [speaker] stated [exact materially false fact]. The statement was false when made because [existing fact], and knowledge or intent is supported by [particular circumstances].
66. Defendant intended Plaintiff to act by [specific conduct]. Plaintiff reasonably or justifiably relied, as required by [governing state law], by [act] and suffered [direct loss]. This count does not infer fraud solely from later nonperformance or a disputed legal position. All Rule 9(b) details must be completed.
COUNT VII — Civil conspiracy; derivative liability
67. Plaintiffs incorporate the specifically pleaded underlying intentional wrong in Count [IV, V, or VI, as governing law permits]. [Named participants] agreed on [date or supported period] to accomplish [actionable objective] through [specific acts], causing [loss].
68. This is a theory of liability for a supported underlying wrong, not a freestanding claim that lawful collective governance is tortious. Where Louisiana law applies, Plaintiffs invoke Civil Code article 2324; elsewhere they identify the governing state rule. Applicable intracorporate-conspiracy limitations and the role of separately competing institutions must be addressed.
COUNT VIII — Civil RICO; 18 U.S.C. §§ 1962(c), 1964(c)
69. CONDITIONAL COUNT—REMOVE UNLESS PREDICATE FACTS ARE SUPPORTED. Plaintiffs incorporate only [specify completed factual paragraphs and Schedule C]. The current materials do not establish racketeering. Inclusion of this count in the working draft is not an accusation that any identified person committed a crime.
70. The RICO person or persons are [specific defendants]. The enterprise is [precisely identified legal entity or association-in-fact], distinct from each § 1962(c) defendant as required by law. If association-in-fact is used, its common purpose, relationships, and sufficient longevity are [particular facts]. A conference’s lawful existence is not proof of a racketeering enterprise.
71. Each RICO defendant conducted or participated in the operation or management of the enterprise’s affairs by [specific direction or decision], rather than merely associating with it. The enterprise affected interstate commerce through [facts].
72. The qualifying predicate acts are [offense and statutory subsection], described individually in Schedule C with actor, date, means, victim, property, and supporting evidence. If mail or wire fraud is alleged, identify the material deception, intent, money or property sought, and qualifying use of mail or interstate wires. A public rule announcement or ordinary email is not fraud merely because it helps implement a disputed rule.
73. If extortion is alleged, identify the applicable predicate statute, property sought to be obtained, intended recipient, wrongful means, and statutory nexus. A threat to impose institutional penalties, without the offense’s required elements, is not alleged as extortion. Antitrust violations and interference torts are not themselves RICO predicates.
74. The predicates are related through [facts] and exhibit closed-ended or open-ended continuity through [supported duration, repetition, and threatened continuation]. Two communications concerning one finite eligibility dispute do not alone establish continuity.
75. Each Plaintiff suffered a domestic business or property injury of [specified loss] directly and proximately caused by [predicate scheme], as distinguished from injury caused only by the eligibility policy. The causal chain and absence of a more directly injured claimant are [facts]. Plaintiffs seek qualifying damages trebled and fees under § 1964(c), without double recovery.
COUNT IX — RICO conspiracy; 18 U.S.C. § 1962(d)
76. CONDITIONAL COUNT—REMOVE UNLESS SUPPORTED. Plaintiffs incorporate the completed enterprise and predicate allegations in Count VIII and Schedule C. [Each specified defendant] knowingly agreed to facilitate the enterprise’s affairs through the identified pattern of racketeering, as shown by [particular agreement facts].
77. Plaintiffs’ business or property injury resulted from [an independently actionable act in furtherance of that RICO conspiracy]. This count does not rest solely on agreement to vote for conference rules, and does not cure a missing racketeering objective or missing injury.
VIII. Equitable relief and damages
78. Plaintiffs request declaratory relief under 28 U.S.C. §§ 2201–2202 resolving the actual federal controversy identified above. These statutes supply a remedy, not an independent substantive wrong or a substitute for jurisdiction.
79. Plaintiffs seek an injunction against enforcement of the specified restriction and against sanctions imposed solely because a willing institution permits the identified Plaintiffs to participate pursuant to lawful eligibility relief. Any protection against later penalties must be specifically supported and tailored to the controversy.
80. The imminent irreparable injury is [lost, nonrepeatable season or developmental opportunity supported by declaration], not merely delayed receipt of calculable money. Plaintiffs address likely success, balance of equities, public interest, notice, and security in a separate Rule 65 motion. No emergency order is represented as already obtained.
81. Plaintiffs do not seek guaranteed playing time, displacement of an identified third-party player without an established basis, or blanket invalidation of unrelated rules. Any mandatory roster or contractual performance relief requires a separate legal and factual showing.
82. Plaintiffs seek provable unpaid contractual compensation, lost opportunities established with reasonable certainty, reliance expenses, and other legally recoverable economic loss. Speculative career earnings, conference gross revenue, and injuries to unnamed athletes are not substituted for Plaintiffs’ actual loss.
83. [REQUESTED DEMAND—REQUIRES EVIDENTIARY SUPPORT:] Plaintiffs allege aggregate compensatory damages exceeding $100,000,000, before statutory trebling, supported by [identify Plaintiff-specific computation and evidence]. If the verified computation does not support that threshold, replace it with damages to be established at trial. The threshold is not asserted separately against each defendant.
84. Statutory multipliers apply only to damages qualifying under the respective statute, and overlapping antitrust, RICO, contract, and tort injuries may not be recovered twice. Joint and several liability is sought only where the substantive law authorizes it; it is not presumed across all defendants or counts.
Posted on 9/3/26 at 10:09 pm to TutHillTiger
Prayer for relief
WHEREFORE, Plaintiffs request judgment, against the defendants legally responsible for each claim, as follows:
1. A declaration that the specifically challenged agreement and its enforcement violate the federal law established at trial;
2. Appropriate temporary, preliminary, and permanent relief described above, following the required evidentiary and procedural showing;
3. Compensatory damages in an amount proved at trial, with the requested allegation of an aggregate amount exceeding $100 million retained only upon a supportable computation;
4. Trebling of qualifying antitrust damages and, if the conditional RICO claims are established, qualifying RICO damages, without duplicative recovery;
5. Punitive damages only on claims, against defendants, and upon culpability findings for which governing law permits them;
6. Attorney’s fees, taxable costs, and interest only as authorized by the applicable statute, contract, or rule; and
7. Other relief within the Court’s authority consistent with the pleaded claims and proven injuries.
Jury demand and signature
Plaintiffs demand trial by jury on every issue so triable.
WHEREFORE, Plaintiffs request judgment, against the defendants legally responsible for each claim, as follows:
1. A declaration that the specifically challenged agreement and its enforcement violate the federal law established at trial;
2. Appropriate temporary, preliminary, and permanent relief described above, following the required evidentiary and procedural showing;
3. Compensatory damages in an amount proved at trial, with the requested allegation of an aggregate amount exceeding $100 million retained only upon a supportable computation;
4. Trebling of qualifying antitrust damages and, if the conditional RICO claims are established, qualifying RICO damages, without duplicative recovery;
5. Punitive damages only on claims, against defendants, and upon culpability findings for which governing law permits them;
6. Attorney’s fees, taxable costs, and interest only as authorized by the applicable statute, contract, or rule; and
7. Other relief within the Court’s authority consistent with the pleaded claims and proven injuries.
Jury demand and signature
Plaintiffs demand trial by jury on every issue so triable.
Posted on 9/3/26 at 10:10 pm to TutHillTiger
Bro post less
Posted on 9/3/26 at 10:10 pm to ColoradoAg
quote:
Who would read that wall of text?
an ignorant dumbfrick like you in case u wanna learn?
instead of staying delusional with your coping ?
Posted on 9/3/26 at 10:11 pm to TutHillTiger
What about the bobcat?
Posted on 9/3/26 at 10:11 pm to TutHillTiger
quote:
TutHillTiger
We get it......you learned how to copy/paste.
Posted on 9/3/26 at 10:12 pm to bbeck
That took less than 10 minutes and left out at least a dozen claims and if course will be in the Middle District of Louisiana since that’s where the original lawsuit was filed. I am sure Tony will have a complaint/petition 1000xs better
Posted on 9/3/26 at 10:17 pm to TutHillTiger
No for the fun part discovery:
A. Definitions and tailored scope
1. “Plaintiffs” means Dae’Quan Wright and Zxavian Harris, plus only any additional plaintiff actually named in the operative complaint. Use names and known spelling variants in searches.
2. “You” means the particular responding party. For an organization, include responsive information and materials within its possession, custody, or control through its personnel; for an individual, do not automatically impute all school or conference records to that individual.
3. “Challenged Restriction” means the specific SEC professional-status eligibility provision and related sanctions identified by date/version in Exhibit A to the served instrument. Attach that provision; do not define the term as every eligibility rule ever adopted.
4. “Relevant Period” means January 1, 2026 through the date of service unless a request specifies otherwise. Foundational governance documents in force during that period are included regardless of creation date. Historical comparator data is limited to January 1, 2023 through service and only where specifically requested.
5. “Plaintiff Agreement” means an identified written or oral scholarship, revenue-sharing, NIL, enrollment-related, or other athletic-services agreement involving a Plaintiff. Distinguish each contract, counterparty, amendment, and incorporated condition.
6. “Termination Decision” means the actual or proposed decision to cancel, suspend, refuse, or withdraw a Plaintiff Agreement or roster opportunity because of the Challenged Restriction. Do not assume termination occurred.
7. “Brooks Statement” means only the complete statement identified by authenticated recording or publication, date, speaker, and venue in Exhibit B [not yet supplied]. Omit statement-specific requests until Exhibit B is completed.
8. “Communication” means relevant written, recorded, or electronically stored exchanges, including email, texts, approved work messaging, social-media messages, meeting recordings, and their attachments. No demand is made for unrelated private communications.
9. “Identify a person” means give the name and role, and a business contact if known. Do not supply home addresses, personal identifiers, or unrelated personal information. Additional details requested in an interrogatory must be counted as appropriate under Rule 33.
10. “Documents sufficient to show” requests a reasonably complete set demonstrating the specified fact, rather than every duplicate. “Communications concerning” requests responsive substantive exchanges within the defined scope, with necessary conversational context.
Instructions applicable to each served set
Respond separately to each request. Produce discoverable materials as kept in the ordinary course or identify them by request. State specific objections and whether responsive material is withheld; produce the nonobjected-to portion. These instructions do not expand the Federal Rules or impose a response duty beyond them. Preserve privilege and protected work product, describe withheld materials as required by Rule 26(b)(5), and confer on a proportionate log protocol. No request seeks counsel’s legal advice merely because counsel attended a business meeting. Provide underlying nonprivileged facts and severable business records.
Honor Rule 26(e) supplementation obligations. If a source is inaccessible or disproportionately burdensome, identify the source and burden sufficiently to permit a focused conference; do not presume that inaccessible backups must be restored. Protect student education records and commercially sensitive compensation information through notice, redaction, coding, and a suitable protective order. FERPA is not treated as a blanket discovery privilege. Produce no unnecessary Social Security numbers, medical records, banking credentials, or unrelated private information.
B. Draft preservation notice — proposed, not sent
To counsel for [recipient]: Please preserve potentially relevant documents and ESI concerning the Challenged Restriction, Plaintiffs’ recruitment and agreements, enforcement or threatened enforcement, the Termination Decision, and the identified Brooks Statement. The reasonably anticipated dispute concerns exclusion from paid athletic opportunities and resulting loss. This notice requests preservation, not production, and does not require waiver of any privilege.
Preserve relevant materials from Sankey and the conference policy, compliance, communications, and governance personnel; at each implicated institution, the actual AD, president/chancellor decisionmaker, compliance officer, relevant recruiting/contract personnel, and custodian of the challenged vote. Tailor individual recipients and dates to their participation. Preserve relevant official business conducted on personal accounts or devices where within lawful control, without collecting unrelated personal material.
Suspend routine deletion for relevant custodians and channels where reasonably necessary, including expiring chats, voicemail, meeting recordings, edited or deleted messages, and cloud-document version history. Preserve native contracts, signature audit trails, calendar invitations, board packets, vote records, public-statement source files, and attachments. Preserve sufficient metadata and audit information to authenticate changes, senders, dates, and receipt. Do not alter device settings in a way that destroys responsive information.
Please identify an appropriate contact for a preservation conference within seven days [requested, not court-ordered]. Preserve existing logs relevant to loss or deletion. This request does not seek forensic imaging of every device, indefinite suspension of all institutional retention, or preservation of unrelated records. If a source creates a material burden, confer promptly about a narrower method that protects relevant evidence.
C. Proposed ESI and confidentiality protocol
1. Custodians: exchange an initial, prioritized list of the people who drafted, voted on, communicated, or implemented the restriction and the people who negotiated or terminated Plaintiff Agreements. Identify institutional versus personal business channels and material date limits. Expand only on a documented gap.
2. Initial collection windows: policy and communications, January 1, 2026 through service; emergency collection, 30 days before adoption through the scheduled hearing; historical comparator databases, 2023 through service in existing usable form. Preserve a broader relevant period if justified while prioritizing narrower production.
3. Search design: test Plaintiff names and variants; combinations of professional/NFL/draft/roster with return/eligibility/waiver; and restriction-specific terms found in the operative rule. Use “Wright” or “Harris” with other limiting terms where necessary. Review hit counts and samples jointly; keyword hits alone neither prove responsiveness nor exhaust the search.
4. Email: produce searchable images or PDFs with extracted text and reasonably available metadata, preserving attachments and family relationships. Spreadsheets, databases, audio/video, and materially dynamic files should be native or a usable export. Agree on native-link handling and confidentiality legends without altering the original content.
5. Metadata: reasonably available custodian, source, unique document ID, family IDs, sender/recipient/CC/BCC, subject, sent/received time with time zone, filename, extension, hash, and creation/modification time where meaningful. Do not demand that nonexistent metadata be recreated.
6. Messages: preserve channel/participant identity, timestamps, edits, reactions where material, attachments, and sufficient preceding/following context. Agree on conversation segmentation; avoid screenshots that conceal recipients or omit material
A. Definitions and tailored scope
1. “Plaintiffs” means Dae’Quan Wright and Zxavian Harris, plus only any additional plaintiff actually named in the operative complaint. Use names and known spelling variants in searches.
2. “You” means the particular responding party. For an organization, include responsive information and materials within its possession, custody, or control through its personnel; for an individual, do not automatically impute all school or conference records to that individual.
3. “Challenged Restriction” means the specific SEC professional-status eligibility provision and related sanctions identified by date/version in Exhibit A to the served instrument. Attach that provision; do not define the term as every eligibility rule ever adopted.
4. “Relevant Period” means January 1, 2026 through the date of service unless a request specifies otherwise. Foundational governance documents in force during that period are included regardless of creation date. Historical comparator data is limited to January 1, 2023 through service and only where specifically requested.
5. “Plaintiff Agreement” means an identified written or oral scholarship, revenue-sharing, NIL, enrollment-related, or other athletic-services agreement involving a Plaintiff. Distinguish each contract, counterparty, amendment, and incorporated condition.
6. “Termination Decision” means the actual or proposed decision to cancel, suspend, refuse, or withdraw a Plaintiff Agreement or roster opportunity because of the Challenged Restriction. Do not assume termination occurred.
7. “Brooks Statement” means only the complete statement identified by authenticated recording or publication, date, speaker, and venue in Exhibit B [not yet supplied]. Omit statement-specific requests until Exhibit B is completed.
8. “Communication” means relevant written, recorded, or electronically stored exchanges, including email, texts, approved work messaging, social-media messages, meeting recordings, and their attachments. No demand is made for unrelated private communications.
9. “Identify a person” means give the name and role, and a business contact if known. Do not supply home addresses, personal identifiers, or unrelated personal information. Additional details requested in an interrogatory must be counted as appropriate under Rule 33.
10. “Documents sufficient to show” requests a reasonably complete set demonstrating the specified fact, rather than every duplicate. “Communications concerning” requests responsive substantive exchanges within the defined scope, with necessary conversational context.
Instructions applicable to each served set
Respond separately to each request. Produce discoverable materials as kept in the ordinary course or identify them by request. State specific objections and whether responsive material is withheld; produce the nonobjected-to portion. These instructions do not expand the Federal Rules or impose a response duty beyond them. Preserve privilege and protected work product, describe withheld materials as required by Rule 26(b)(5), and confer on a proportionate log protocol. No request seeks counsel’s legal advice merely because counsel attended a business meeting. Provide underlying nonprivileged facts and severable business records.
Honor Rule 26(e) supplementation obligations. If a source is inaccessible or disproportionately burdensome, identify the source and burden sufficiently to permit a focused conference; do not presume that inaccessible backups must be restored. Protect student education records and commercially sensitive compensation information through notice, redaction, coding, and a suitable protective order. FERPA is not treated as a blanket discovery privilege. Produce no unnecessary Social Security numbers, medical records, banking credentials, or unrelated private information.
B. Draft preservation notice — proposed, not sent
To counsel for [recipient]: Please preserve potentially relevant documents and ESI concerning the Challenged Restriction, Plaintiffs’ recruitment and agreements, enforcement or threatened enforcement, the Termination Decision, and the identified Brooks Statement. The reasonably anticipated dispute concerns exclusion from paid athletic opportunities and resulting loss. This notice requests preservation, not production, and does not require waiver of any privilege.
Preserve relevant materials from Sankey and the conference policy, compliance, communications, and governance personnel; at each implicated institution, the actual AD, president/chancellor decisionmaker, compliance officer, relevant recruiting/contract personnel, and custodian of the challenged vote. Tailor individual recipients and dates to their participation. Preserve relevant official business conducted on personal accounts or devices where within lawful control, without collecting unrelated personal material.
Suspend routine deletion for relevant custodians and channels where reasonably necessary, including expiring chats, voicemail, meeting recordings, edited or deleted messages, and cloud-document version history. Preserve native contracts, signature audit trails, calendar invitations, board packets, vote records, public-statement source files, and attachments. Preserve sufficient metadata and audit information to authenticate changes, senders, dates, and receipt. Do not alter device settings in a way that destroys responsive information.
Please identify an appropriate contact for a preservation conference within seven days [requested, not court-ordered]. Preserve existing logs relevant to loss or deletion. This request does not seek forensic imaging of every device, indefinite suspension of all institutional retention, or preservation of unrelated records. If a source creates a material burden, confer promptly about a narrower method that protects relevant evidence.
C. Proposed ESI and confidentiality protocol
1. Custodians: exchange an initial, prioritized list of the people who drafted, voted on, communicated, or implemented the restriction and the people who negotiated or terminated Plaintiff Agreements. Identify institutional versus personal business channels and material date limits. Expand only on a documented gap.
2. Initial collection windows: policy and communications, January 1, 2026 through service; emergency collection, 30 days before adoption through the scheduled hearing; historical comparator databases, 2023 through service in existing usable form. Preserve a broader relevant period if justified while prioritizing narrower production.
3. Search design: test Plaintiff names and variants; combinations of professional/NFL/draft/roster with return/eligibility/waiver; and restriction-specific terms found in the operative rule. Use “Wright” or “Harris” with other limiting terms where necessary. Review hit counts and samples jointly; keyword hits alone neither prove responsiveness nor exhaust the search.
4. Email: produce searchable images or PDFs with extracted text and reasonably available metadata, preserving attachments and family relationships. Spreadsheets, databases, audio/video, and materially dynamic files should be native or a usable export. Agree on native-link handling and confidentiality legends without altering the original content.
5. Metadata: reasonably available custodian, source, unique document ID, family IDs, sender/recipient/CC/BCC, subject, sent/received time with time zone, filename, extension, hash, and creation/modification time where meaningful. Do not demand that nonexistent metadata be recreated.
6. Messages: preserve channel/participant identity, timestamps, edits, reactions where material, attachments, and sufficient preceding/following context. Agree on conversation segmentation; avoid screenshots that conceal recipients or omit material
Posted on 9/3/26 at 10:18 pm to TutHillTiger
Deduplication: exact-hash deduplication is permitted if all custodian associations are retained. Preserve nonidentical drafts and materially different versions. Email threading may omit wholly duplicative text only under an agreed method retaining unique content and attachments.
8. Privilege: agree on categorical or document-level logging appropriate to the issues and current scheduling order. List date, author/recipients, nonprivileged subject, privilege basis, and unique ID where required. No automatic crime-fraud exception is asserted from the presence of a RICO count.
9. Clawback: seek a Federal Rule of Evidence 502(d) order. On a privilege claim, follow Rule 26(b)(5)(B), sequester the disputed material, and resolve it without unauthorized use. An agreement alone is not represented as the equivalent of a court order.
10. Confidentiality: use an appropriate protective order for student and compensation records; preserve access for counsel and retained experts. Permit challenges to designation and lawful use in court, with separate sealing procedures. Do not label every institutional record confidential by default.
11. Quality control: validate attachment completeness, readable exports, searchable text, dates/time zones, and document-ID consistency. Provide a production index and a reasonable mechanism for reporting technical defects. Reproduce only defective portions when possible.
12. Missing ESI: identify relevant source loss, timing, retention setting, and available replacements when discoverable. Rule 37(e) remedies depend on its elements; an absent message alone is not proof of intentional destruction.
D. Expedited discovery motion framework
[Insert completed caption.] PLAINTIFFS’ MOTION FOR LIMITED EXPEDITED DISCOVERY. Under Rule 26(d)(1), Plaintiffs request the limited discovery below before the ordinary discovery sequence because [verified roster deadline/game date] threatens [Plaintiff-specific irreparable loss]. Declarations from [player] and [willing-school decisionmaker] establish the timing, remaining eligibility, threatened enforcement, and how the requested evidence will inform the Rule 65 hearing.
The requested discovery is confined to the operative restriction, actual enforcement threat, contracts and termination grounds, individual decisionmakers, and available alternatives. It does not seek broad financial discovery, all institutions’ records, or unsubstantiated RICO material on the emergency timetable. Plaintiffs propose targeted production from the SEC and LSU/actual contracting entity, followed by one limited organizational deposition of each. Counsel conferred on [date]; the positions are [accurate result]. Attach the actual requests and a proposed order. Do not state that a conference occurred unless it did.
Emergency production schedule — eight requests
E-1. Produce the operative restriction and sanction provisions, amendments, and documents sufficient to establish effective dates.
E-2. Produce the final resolutions and vote records adopting the restriction and separately adopting penalties.
E-3. Produce communications actually conveying to LSU a threat or instruction concerning the named Plaintiffs’ participation, from 30 days before adoption through the present.
E-4. Produce documents stating the current enforcement position for each Plaintiff and any exception, waiver, suspension, or restraint on enforcement.
E-5. Produce the named Plaintiffs’ executed agreements and incorporated eligibility and termination terms.
E-6. Produce the actual proposed or final Termination Decision and nonprivileged records stating its reasons.
E-7. Produce documents sufficient to identify the decisionmakers who issued the enforcement communication and made the Termination Decision.
E-8. Produce nonprivileged records showing whether LSU would roster or retain either Plaintiff if the restriction were unenforceable, and identify any remaining independent eligibility barrier.
Proposed order — counsel must supply dates
8. Privilege: agree on categorical or document-level logging appropriate to the issues and current scheduling order. List date, author/recipients, nonprivileged subject, privilege basis, and unique ID where required. No automatic crime-fraud exception is asserted from the presence of a RICO count.
9. Clawback: seek a Federal Rule of Evidence 502(d) order. On a privilege claim, follow Rule 26(b)(5)(B), sequester the disputed material, and resolve it without unauthorized use. An agreement alone is not represented as the equivalent of a court order.
10. Confidentiality: use an appropriate protective order for student and compensation records; preserve access for counsel and retained experts. Permit challenges to designation and lawful use in court, with separate sealing procedures. Do not label every institutional record confidential by default.
11. Quality control: validate attachment completeness, readable exports, searchable text, dates/time zones, and document-ID consistency. Provide a production index and a reasonable mechanism for reporting technical defects. Reproduce only defective portions when possible.
12. Missing ESI: identify relevant source loss, timing, retention setting, and available replacements when discoverable. Rule 37(e) remedies depend on its elements; an absent message alone is not proof of intentional destruction.
D. Expedited discovery motion framework
[Insert completed caption.] PLAINTIFFS’ MOTION FOR LIMITED EXPEDITED DISCOVERY. Under Rule 26(d)(1), Plaintiffs request the limited discovery below before the ordinary discovery sequence because [verified roster deadline/game date] threatens [Plaintiff-specific irreparable loss]. Declarations from [player] and [willing-school decisionmaker] establish the timing, remaining eligibility, threatened enforcement, and how the requested evidence will inform the Rule 65 hearing.
The requested discovery is confined to the operative restriction, actual enforcement threat, contracts and termination grounds, individual decisionmakers, and available alternatives. It does not seek broad financial discovery, all institutions’ records, or unsubstantiated RICO material on the emergency timetable. Plaintiffs propose targeted production from the SEC and LSU/actual contracting entity, followed by one limited organizational deposition of each. Counsel conferred on [date]; the positions are [accurate result]. Attach the actual requests and a proposed order. Do not state that a conference occurred unless it did.
Emergency production schedule — eight requests
E-1. Produce the operative restriction and sanction provisions, amendments, and documents sufficient to establish effective dates.
E-2. Produce the final resolutions and vote records adopting the restriction and separately adopting penalties.
E-3. Produce communications actually conveying to LSU a threat or instruction concerning the named Plaintiffs’ participation, from 30 days before adoption through the present.
E-4. Produce documents stating the current enforcement position for each Plaintiff and any exception, waiver, suspension, or restraint on enforcement.
E-5. Produce the named Plaintiffs’ executed agreements and incorporated eligibility and termination terms.
E-6. Produce the actual proposed or final Termination Decision and nonprivileged records stating its reasons.
E-7. Produce documents sufficient to identify the decisionmakers who issued the enforcement communication and made the Termination Decision.
E-8. Produce nonprivileged records showing whether LSU would roster or retain either Plaintiff if the restriction were unenforceable, and identify any remaining independent eligibility barrier.
Proposed order — counsel must supply dates
Posted on 9/3/26 at 10:20 pm to TutHillTiger
E. First interrogatories to the SEC
[Insert caption.] Plaintiffs propound the following interrogatories to the Southeastern Conference under Rule 33. Apply Sections A and C as incorporated and finalized. These 20 questions are one set; count any modifications or discrete subparts before service.
1. Identify the SEC body with authority to adopt the Challenged Restriction.
2. Identify the person who first proposed the version ultimately adopted.
3. State the date on which the operative restriction was adopted.
4. State the recorded institutional votes on adoption of the restriction.
5. State the recorded institutional votes on adoption of the related sanctions.
6. Identify each person authorized to impose the sanctions at issue.
7. State the SEC’s current eligibility position as to Dae’Quan Wright under the restriction.
8. State the SEC’s current eligibility position as to Zxavian Harris under the restriction.
9. Identify the first communication by which the SEC learned of Wright’s LSU contractual relationship.
10. Identify the first communication by which the SEC learned of Harris’s LSU contractual relationship.
11. Describe the enforcement instruction or threat, if any, that the SEC communicated to LSU concerning these Plaintiffs.
12. Identify the person who approved that enforcement communication.
13. State the nonprivileged factual basis for the SEC’s contention that permitting these Plaintiffs to participate would impair competitive balance.
14. Describe the procedure, if any, for an individual exception to the restriction.
15. Identify the less restrictive alternative that the SEC considered most seriously before adopting the restriction.
16. State why that alternative was rejected, excluding privileged legal advice.
17. Identify any agreement with another athletic conference concerning the same professional-status exclusion.
18. Identify the custodian responsible for the authoritative adoption and voting records.
19. Describe the SEC’s asserted role in the Plaintiffs’ LSU agreements that it contends defeats stranger status for an interference claim.
20. Identify any insurance agreement potentially responsive to a judgment on the claims actually pleaded in this action.
F. First interrogatories to an individual official
Recipient: [Greg Sankey / Josh Brooks / named AD / named president or chancellor]. Serve separately only upon a party with supported allegations. These 15 questions are not a demand that every official answer for the entire conference.
1. State the office you held when you participated, if at all, in the Challenged Restriction.
2. Describe your personal role in proposing or drafting that restriction.
3. State your own vote or expressed position on adoption of the restriction.
4. State your own vote or expressed position on the proposed sanctions.
5. Identify the meeting at which you first discussed either Plaintiff’s recruitment by LSU.
6. State when you first learned that Wright had an agreement or concrete prospective relationship with LSU.
7. State when you first learned that Harris had an agreement or concrete prospective relationship with LSU.
8. Describe any instruction you personally gave to another person to prevent either Plaintiff from joining or remaining with LSU.
9. Identify the recipient of any such instruction.
10. State the nonprivileged factual basis for any assertion you made that the Plaintiffs’ participation would cause competitive harm.
11. Describe your personal authority, if any, to impose or recommend an SEC sanction.
12. Identify the business communication accounts you used for the relevant discussions.
13. Describe any economic or governance interest you contend you had in the specific Plaintiff relationships at issue.
14. Identify the person with whom you discussed any alternative permitting a Plaintiff to participate without abandoning the asserted legitimate objective.
15. State the specific capacity or privilege defense you assert to liability for your own alleged acts.
G. First interrogatories to each participating member institution
Recipient: [verified legal entity]. These 15 questions supplement the institution’s production duties; they are not automatically also served on its president and AD.
1. Identify the institutional representative authorized to vote on the restriction.
2. State the institution’s vote or assent on the restriction.
3. State the institution’s vote or assent on sanctions.
4. Identify the institutional decisionmaker who approved its position.
5. Describe the institution’s implementation of the restriction concerning these Plaintiffs.
6. Identify any communication your institution sent asking LSU to discontinue a Plaintiff relationship.
7. State when the institution first learned of the Plaintiff Agreement at issue.
8. Describe any recruiting interest the institution had in either Plaintiff before the restriction.
9. State whether the institution would consider either Plaintiff if the restriction were removed, identifying any independent barrier in your answer.
10. Describe the institutional procedure for reviewing professional-history eligibility exceptions.
11. Identify the institutional official with authority to change its current implementation decision.
12. State the institution’s legal status on which any sovereign-immunity assertion rests.
13. Identify the entity responsible for satisfying a judgment against the named institutional defendant.
14. Describe the factual basis for the institution’s claimed economic interest in the specific contract allegedly interfered with.
15. Identify the existing data source that records football recruiting offers and institutional player compensation during the relevant period.
[Insert caption.] Plaintiffs propound the following interrogatories to the Southeastern Conference under Rule 33. Apply Sections A and C as incorporated and finalized. These 20 questions are one set; count any modifications or discrete subparts before service.
1. Identify the SEC body with authority to adopt the Challenged Restriction.
2. Identify the person who first proposed the version ultimately adopted.
3. State the date on which the operative restriction was adopted.
4. State the recorded institutional votes on adoption of the restriction.
5. State the recorded institutional votes on adoption of the related sanctions.
6. Identify each person authorized to impose the sanctions at issue.
7. State the SEC’s current eligibility position as to Dae’Quan Wright under the restriction.
8. State the SEC’s current eligibility position as to Zxavian Harris under the restriction.
9. Identify the first communication by which the SEC learned of Wright’s LSU contractual relationship.
10. Identify the first communication by which the SEC learned of Harris’s LSU contractual relationship.
11. Describe the enforcement instruction or threat, if any, that the SEC communicated to LSU concerning these Plaintiffs.
12. Identify the person who approved that enforcement communication.
13. State the nonprivileged factual basis for the SEC’s contention that permitting these Plaintiffs to participate would impair competitive balance.
14. Describe the procedure, if any, for an individual exception to the restriction.
15. Identify the less restrictive alternative that the SEC considered most seriously before adopting the restriction.
16. State why that alternative was rejected, excluding privileged legal advice.
17. Identify any agreement with another athletic conference concerning the same professional-status exclusion.
18. Identify the custodian responsible for the authoritative adoption and voting records.
19. Describe the SEC’s asserted role in the Plaintiffs’ LSU agreements that it contends defeats stranger status for an interference claim.
20. Identify any insurance agreement potentially responsive to a judgment on the claims actually pleaded in this action.
F. First interrogatories to an individual official
Recipient: [Greg Sankey / Josh Brooks / named AD / named president or chancellor]. Serve separately only upon a party with supported allegations. These 15 questions are not a demand that every official answer for the entire conference.
1. State the office you held when you participated, if at all, in the Challenged Restriction.
2. Describe your personal role in proposing or drafting that restriction.
3. State your own vote or expressed position on adoption of the restriction.
4. State your own vote or expressed position on the proposed sanctions.
5. Identify the meeting at which you first discussed either Plaintiff’s recruitment by LSU.
6. State when you first learned that Wright had an agreement or concrete prospective relationship with LSU.
7. State when you first learned that Harris had an agreement or concrete prospective relationship with LSU.
8. Describe any instruction you personally gave to another person to prevent either Plaintiff from joining or remaining with LSU.
9. Identify the recipient of any such instruction.
10. State the nonprivileged factual basis for any assertion you made that the Plaintiffs’ participation would cause competitive harm.
11. Describe your personal authority, if any, to impose or recommend an SEC sanction.
12. Identify the business communication accounts you used for the relevant discussions.
13. Describe any economic or governance interest you contend you had in the specific Plaintiff relationships at issue.
14. Identify the person with whom you discussed any alternative permitting a Plaintiff to participate without abandoning the asserted legitimate objective.
15. State the specific capacity or privilege defense you assert to liability for your own alleged acts.
G. First interrogatories to each participating member institution
Recipient: [verified legal entity]. These 15 questions supplement the institution’s production duties; they are not automatically also served on its president and AD.
1. Identify the institutional representative authorized to vote on the restriction.
2. State the institution’s vote or assent on the restriction.
3. State the institution’s vote or assent on sanctions.
4. Identify the institutional decisionmaker who approved its position.
5. Describe the institution’s implementation of the restriction concerning these Plaintiffs.
6. Identify any communication your institution sent asking LSU to discontinue a Plaintiff relationship.
7. State when the institution first learned of the Plaintiff Agreement at issue.
8. Describe any recruiting interest the institution had in either Plaintiff before the restriction.
9. State whether the institution would consider either Plaintiff if the restriction were removed, identifying any independent barrier in your answer.
10. Describe the institutional procedure for reviewing professional-history eligibility exceptions.
11. Identify the institutional official with authority to change its current implementation decision.
12. State the institution’s legal status on which any sovereign-immunity assertion rests.
13. Identify the entity responsible for satisfying a judgment against the named institutional defendant.
14. Describe the factual basis for the institution’s claimed economic interest in the specific contract allegedly interfered with.
15. Identify the existing data source that records football recruiting offers and institutional player compensation during the relevant period.
Posted on 9/3/26 at 10:21 pm to TutHillTiger
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