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re: Here is the buzzsaw Sankey is walking the SEC into
Posted on 9/3/26 at 10:22 pm to trussthetruzz
Posted on 9/3/26 at 10:22 pm to trussthetruzz
entity
Use this 20-question set instead of the generic institution set for LSU where both would overlap. If the recipient is a nonparty, seek the information by an appropriate deposition and subpoena rather than interrogatories.
1. Identify the legal counterparty to each Plaintiff Agreement.
2. Identify the person authorized to bind that counterparty when each agreement was made.
3. State the amount of guaranteed unpaid compensation, if any, under Wright’s agreement.
4. State the amount of guaranteed unpaid compensation, if any, under Harris’s agreement.
5. Identify the contract provision you contend authorized cancellation based on SEC eligibility.
6. State whether a final Termination Decision has been made for Wright.
7. State whether a final Termination Decision has been made for Harris.
8. Identify the person who made each final or proposed Termination Decision.
9. State the reason for Wright’s final or proposed termination.
10. State the reason for Harris’s final or proposed termination.
11. Identify any independent eligibility barrier that would remain if the SEC restriction were unenforceable.
12. State whether the entity would retain the relevant Plaintiff relationship absent the SEC restriction.
13. Describe any assurance made to a Plaintiff about remaining eligibility before he accepted an agreement.
14. State whether the entity knew a Plaintiff was surrendering another opportunity in reliance on that assurance.
15. Identify any SEC enforcement communication considered in making the Termination Decision.
16. State whether the Brooks Statement was considered in making that decision.
17. Identify any contract dispute-resolution clause you contend governs this claim.
18. State the amount paid to each Plaintiff under the agreements at issue.
19. Describe the mitigation or substitute performance offered to each Plaintiff.
20. Identify any waiver, appeal, or exception requested to preserve the Plaintiff relationships.
I. Brooks-specific interrogatory supplement
Use only after identifying Exhibit B. Add to the individual set only if the aggregate count, including discrete subparts, remains within the limit; otherwise substitute or seek leave.
B-1. State whether you made the statement reproduced in Exhibit B.
B-2. Identify the source of your knowledge of the Plaintiff Agreement discussed in that statement.
B-3. State the action you intended LSU or another listener to take in response to the statement.
B-4. Identify any nonprivileged coordination of that statement with another institution or the SEC.
B-5. Describe any personal contractual undertaking you made to either Plaintiff, if you contend one exists.
J. Requests for production — common core
[Insert caption and recipient.] Plaintiffs request production under Rule 34. The common core and selected recipient modules together comprise the served set. Retain stable request identifiers; omit inapplicable requests. These requests seek relevant nonprivileged materials within the recipient’s possession, custody, or control and the defined period. Financial and predicate modules are staged separately; they are not included merely by cross-reference.
C-1. Produce the operative Challenged Restriction and every amendment effective during the Relevant Period.
C-2. Produce the provisions defining authority to adopt, interpret, waive, and enforce that restriction.
C-3. Produce the final agenda, minutes, resolutions, and recorded votes for meetings where adoption was decided.
C-4. Produce the final agenda, minutes, resolutions, and recorded votes for meetings where the sanctions were decided.
C-5. Produce substantive drafts exchanged among decisionmakers showing changes to the restriction’s scope or effective date.
C-6. Produce communications concerning the reason for including draft declaration, professional contracts, roster listing, or actual professional play as separate criteria.
C-7. Produce communications concerning recruitment, enrollment, contracting, or roster placement of the named Plaintiffs.
C-8. Produce communications conveying an enforcement warning, sanction threat, or demand concerning LSU’s treatment of either Plaintiff.
C-9. Produce the final or proposed Termination Decision concerning either Plaintiff and records stating its grounds.
C-10. Produce documents sufficient to show when you first learned of each Plaintiff Agreement.
C-11. Produce communications with another member institution seeking a common position on the Plaintiffs’ participation.
C-12. Produce communications with another conference proposing or accepting a common professional-status restriction.
C-13. Produce nonprivileged factual analyses of competitive balance relied upon in adopting or implementing the restriction.
C-14. Produce nonprivileged analyses of the restriction’s effects on recruiting opportunities or player compensation.
C-15. Produce documents discussing an individual exception, grandfather provision, transition rule, or other less restrictive alternative for affected players.
C-16. Produce documents stating the reason an identified alternative was rejected.
C-17. Produce final public statements you issued on the restriction, with their substantive drafts and approval communications.
C-18. Produce nonprivileged business communications concerning implementation of an operative court order addressing the named Plaintiffs.
C-19. Produce documents sufficient to show the current policy position, including any suspension or change in enforcement after litigation began.
C-20. Produce documents supporting any contention that a Plaintiff’s loss resulted from a reason independent of the restriction.
C-21. Produce existing records of actual sanctions assessed under this restriction during the Relevant Period.
C-22. Produce documents sufficient to identify the custodians, repositories, and retention policies for the records requested in this set.
C-23. Produce any insurance agreement discoverable under Rule 26(a)(1)(A)(iv) that may satisfy all or part of a judgment in this action.
C-24. Produce nonprivileged documents upon which you rely to support a specifically pleaded defense concerning your authority, participation, or causal role.
Use this 20-question set instead of the generic institution set for LSU where both would overlap. If the recipient is a nonparty, seek the information by an appropriate deposition and subpoena rather than interrogatories.
1. Identify the legal counterparty to each Plaintiff Agreement.
2. Identify the person authorized to bind that counterparty when each agreement was made.
3. State the amount of guaranteed unpaid compensation, if any, under Wright’s agreement.
4. State the amount of guaranteed unpaid compensation, if any, under Harris’s agreement.
5. Identify the contract provision you contend authorized cancellation based on SEC eligibility.
6. State whether a final Termination Decision has been made for Wright.
7. State whether a final Termination Decision has been made for Harris.
8. Identify the person who made each final or proposed Termination Decision.
9. State the reason for Wright’s final or proposed termination.
10. State the reason for Harris’s final or proposed termination.
11. Identify any independent eligibility barrier that would remain if the SEC restriction were unenforceable.
12. State whether the entity would retain the relevant Plaintiff relationship absent the SEC restriction.
13. Describe any assurance made to a Plaintiff about remaining eligibility before he accepted an agreement.
14. State whether the entity knew a Plaintiff was surrendering another opportunity in reliance on that assurance.
15. Identify any SEC enforcement communication considered in making the Termination Decision.
16. State whether the Brooks Statement was considered in making that decision.
17. Identify any contract dispute-resolution clause you contend governs this claim.
18. State the amount paid to each Plaintiff under the agreements at issue.
19. Describe the mitigation or substitute performance offered to each Plaintiff.
20. Identify any waiver, appeal, or exception requested to preserve the Plaintiff relationships.
I. Brooks-specific interrogatory supplement
Use only after identifying Exhibit B. Add to the individual set only if the aggregate count, including discrete subparts, remains within the limit; otherwise substitute or seek leave.
B-1. State whether you made the statement reproduced in Exhibit B.
B-2. Identify the source of your knowledge of the Plaintiff Agreement discussed in that statement.
B-3. State the action you intended LSU or another listener to take in response to the statement.
B-4. Identify any nonprivileged coordination of that statement with another institution or the SEC.
B-5. Describe any personal contractual undertaking you made to either Plaintiff, if you contend one exists.
J. Requests for production — common core
[Insert caption and recipient.] Plaintiffs request production under Rule 34. The common core and selected recipient modules together comprise the served set. Retain stable request identifiers; omit inapplicable requests. These requests seek relevant nonprivileged materials within the recipient’s possession, custody, or control and the defined period. Financial and predicate modules are staged separately; they are not included merely by cross-reference.
C-1. Produce the operative Challenged Restriction and every amendment effective during the Relevant Period.
C-2. Produce the provisions defining authority to adopt, interpret, waive, and enforce that restriction.
C-3. Produce the final agenda, minutes, resolutions, and recorded votes for meetings where adoption was decided.
C-4. Produce the final agenda, minutes, resolutions, and recorded votes for meetings where the sanctions were decided.
C-5. Produce substantive drafts exchanged among decisionmakers showing changes to the restriction’s scope or effective date.
C-6. Produce communications concerning the reason for including draft declaration, professional contracts, roster listing, or actual professional play as separate criteria.
C-7. Produce communications concerning recruitment, enrollment, contracting, or roster placement of the named Plaintiffs.
C-8. Produce communications conveying an enforcement warning, sanction threat, or demand concerning LSU’s treatment of either Plaintiff.
C-9. Produce the final or proposed Termination Decision concerning either Plaintiff and records stating its grounds.
C-10. Produce documents sufficient to show when you first learned of each Plaintiff Agreement.
C-11. Produce communications with another member institution seeking a common position on the Plaintiffs’ participation.
C-12. Produce communications with another conference proposing or accepting a common professional-status restriction.
C-13. Produce nonprivileged factual analyses of competitive balance relied upon in adopting or implementing the restriction.
C-14. Produce nonprivileged analyses of the restriction’s effects on recruiting opportunities or player compensation.
C-15. Produce documents discussing an individual exception, grandfather provision, transition rule, or other less restrictive alternative for affected players.
C-16. Produce documents stating the reason an identified alternative was rejected.
C-17. Produce final public statements you issued on the restriction, with their substantive drafts and approval communications.
C-18. Produce nonprivileged business communications concerning implementation of an operative court order addressing the named Plaintiffs.
C-19. Produce documents sufficient to show the current policy position, including any suspension or change in enforcement after litigation began.
C-20. Produce documents supporting any contention that a Plaintiff’s loss resulted from a reason independent of the restriction.
C-21. Produce existing records of actual sanctions assessed under this restriction during the Relevant Period.
C-22. Produce documents sufficient to identify the custodians, repositories, and retention policies for the records requested in this set.
C-23. Produce any insurance agreement discoverable under Rule 26(a)(1)(A)(iv) that may satisfy all or part of a judgment in this action.
C-24. Produce nonprivileged documents upon which you rely to support a specifically pleaded defense concerning your authority, participation, or causal role.
Posted on 9/3/26 at 10:23 pm to trussthetruzz
Use only after Exhibit B identifies the statement. The request for source material does not assume the statement is false or tortious.
BROOKS-1. Produce the complete original recording or publication of the Brooks Statement within your control, including material surrounding context.
BROOKS-2. Produce the prepared remarks, speaking notes, substantive drafts, and nonprivileged approval communications for that statement.
BROOKS-3. Produce documents provided to Brooks as the factual basis for any reference to a named Plaintiff’s contract or eligibility.
BROOKS-4. Produce communications coordinating the statement’s timing or substance with the SEC or another institution.
BROOKS-5. Produce communications transmitting the statement to LSU or asking LSU to take action concerning either Plaintiff.
BROOKS-6. Produce communications reporting that LSU or another willing school changed a decision because of the statement.
BROOKS-7. Produce corrections, clarifications, retractions, or explanations of the statement issued by Brooks or the institution.
BROOKS-8. Produce any instrument alleged to bind Brooks personally to a Plaintiff; absent such an instrument, this request does not presume personal contract liability.
P. Staged market and damages production module
After the initial causation production, confer on custodians, coding, sample size, and expert needs. Seek existing data first. Do not demand all conference revenue or every athlete’s finances as a substitute for a relevant-market or loss analysis.
ECON-1. Produce existing 2023–2026 football recruiting and compensation datasets actually relied on to assess the market affected by the restriction, with data dictionaries.
ECON-2. Produce coded 2026 records sufficient to show the number of otherwise eligible football candidates excluded because of professional-history criteria.
ECON-3. Produce existing records of offers to those coded candidates withdrawn on that ground, including offered guaranteed compensation where maintained.
ECON-4. Produce existing analyses of whether other conferences, divisions, or professional leagues are substitutes for the affected opportunities.
ECON-5. Produce records showing the named Plaintiffs’ actual offers from alternative schools during the relevant period, if within your control.
ECON-6. Produce existing records of compensation or contract terms used as comparators for the named Plaintiffs, limited to similar position, role, and period.
ECON-7. Produce documents relied upon to dispute the Plaintiffs’ mitigation efforts or identify a specific available substitute opportunity.
ECON-8. Produce nonprivileged computations of Plaintiff-specific loss on which you rely, including assumptions, offsets, and supporting source data.
ECON-9. Produce documents showing any payment, refund, settlement credit, or substitute compensation that would reduce an asserted loss.
ECON-10. Produce existing analyses of the administrative cost and feasibility of the specifically proposed less restrictive alternatives.
Q. Conditional predicate-related production module
Use only for a supported pleaded predicate theory or another independently relevant claim. Insert the specific communication, transaction, or property demand. These requests do not authorize discovery solely to search for an unknown crime or overcome privilege.
PRED-1. For the specific representation identified in complaint paragraph [ ], produce its original communication, attachments, and available transmission metadata.
PRED-2. Produce nonprivileged contemporaneous records establishing the truth or falsity of that identified representation when made.
PRED-3. Produce records showing the identified speaker’s access to the contrary fact specifically alleged in paragraph [ ].
PRED-4. Produce records identifying the money or property sought through the particular transaction alleged in paragraph [ ].
PRED-5. Produce documents showing the intended recipient and actual receipt, if any, of that identified money or property.
PRED-6. For the specific alleged wrongful demand identified in paragraph [ ], produce the demand, response, and documents stating its authorized purpose.
PRED-7. Produce existing records of substantially similar identified transactions during [supported, limited period], to the extent relevant to the pleaded relationship and continuity theory.
PRED-8. Produce records connecting the identified transaction to the named Plaintiff’s specific claimed economic loss
BROOKS-1. Produce the complete original recording or publication of the Brooks Statement within your control, including material surrounding context.
BROOKS-2. Produce the prepared remarks, speaking notes, substantive drafts, and nonprivileged approval communications for that statement.
BROOKS-3. Produce documents provided to Brooks as the factual basis for any reference to a named Plaintiff’s contract or eligibility.
BROOKS-4. Produce communications coordinating the statement’s timing or substance with the SEC or another institution.
BROOKS-5. Produce communications transmitting the statement to LSU or asking LSU to take action concerning either Plaintiff.
BROOKS-6. Produce communications reporting that LSU or another willing school changed a decision because of the statement.
BROOKS-7. Produce corrections, clarifications, retractions, or explanations of the statement issued by Brooks or the institution.
BROOKS-8. Produce any instrument alleged to bind Brooks personally to a Plaintiff; absent such an instrument, this request does not presume personal contract liability.
P. Staged market and damages production module
After the initial causation production, confer on custodians, coding, sample size, and expert needs. Seek existing data first. Do not demand all conference revenue or every athlete’s finances as a substitute for a relevant-market or loss analysis.
ECON-1. Produce existing 2023–2026 football recruiting and compensation datasets actually relied on to assess the market affected by the restriction, with data dictionaries.
ECON-2. Produce coded 2026 records sufficient to show the number of otherwise eligible football candidates excluded because of professional-history criteria.
ECON-3. Produce existing records of offers to those coded candidates withdrawn on that ground, including offered guaranteed compensation where maintained.
ECON-4. Produce existing analyses of whether other conferences, divisions, or professional leagues are substitutes for the affected opportunities.
ECON-5. Produce records showing the named Plaintiffs’ actual offers from alternative schools during the relevant period, if within your control.
ECON-6. Produce existing records of compensation or contract terms used as comparators for the named Plaintiffs, limited to similar position, role, and period.
ECON-7. Produce documents relied upon to dispute the Plaintiffs’ mitigation efforts or identify a specific available substitute opportunity.
ECON-8. Produce nonprivileged computations of Plaintiff-specific loss on which you rely, including assumptions, offsets, and supporting source data.
ECON-9. Produce documents showing any payment, refund, settlement credit, or substitute compensation that would reduce an asserted loss.
ECON-10. Produce existing analyses of the administrative cost and feasibility of the specifically proposed less restrictive alternatives.
Q. Conditional predicate-related production module
Use only for a supported pleaded predicate theory or another independently relevant claim. Insert the specific communication, transaction, or property demand. These requests do not authorize discovery solely to search for an unknown crime or overcome privilege.
PRED-1. For the specific representation identified in complaint paragraph [ ], produce its original communication, attachments, and available transmission metadata.
PRED-2. Produce nonprivileged contemporaneous records establishing the truth or falsity of that identified representation when made.
PRED-3. Produce records showing the identified speaker’s access to the contrary fact specifically alleged in paragraph [ ].
PRED-4. Produce records identifying the money or property sought through the particular transaction alleged in paragraph [ ].
PRED-5. Produce documents showing the intended recipient and actual receipt, if any, of that identified money or property.
PRED-6. For the specific alleged wrongful demand identified in paragraph [ ], produce the demand, response, and documents stating its authorized purpose.
PRED-7. Produce existing records of substantially similar identified transactions during [supported, limited period], to the extent relevant to the pleaded relationship and continuity theory.
PRED-8. Produce records connecting the identified transaction to the named Plaintiff’s specific claimed economic loss
Posted on 9/3/26 at 10:23 pm to genuineLSUtiger
LSU Nation is laughing at Sankey
The entire nation is literally laughing at lsu
The entire nation is literally laughing at lsu
Posted on 9/3/26 at 10:24 pm to bamabaseballsec
I just laugh at bama baseball
Posted on 9/3/26 at 10:25 pm to LSU Patrick
T. Individual deposition outlines
These are examination plans, not accusations or substitute organizational notices. Select questions after documents and earlier testimony establish the foundation. Mark actual exhibits and record contradictions accurately; do not assume the answer.
Greg Sankey
1. Establish role and authority: What decisions could you make alone? Which required a board or member vote? Identify the delegation and any limits.
2. Separate chronology: Who first proposed the professional-status exclusion? What changed between the first draft, final rule, and sanction resolution? Authenticate each version.
3. Identify assent: Who attended each meeting? Were votes by institution or individual? What did LSU support, oppose, or abstain from? What record establishes each answer?
4. Establish knowledge: When did you first learn of Wright’s and Harris’s particular agreements? What contract terms did you actually know? Who supplied that information?
5. Examine the actual demand: What did you tell LSU to do? Did you demand termination, roster exclusion, or another action? What sanction did you identify? Who authorized the communication?
6. Test causation: What response did you receive? Did LSU identify an independent reason? What facts show your communication changed its decision?
7. Test competitive justification: What empirical information supported the rule? Did you assess remaining seasons, actual professional play, or individual circumstances? What contrary evidence was considered?
8. Explore alternatives: What grandfathering, waiver, transition, or academic-based approach was proposed? Why would each fail? What cost or operational data supports that conclusion?
9. Clarify coordination: Did you seek agreement from other conferences or merely learn their public positions? Identify the actual exchange and participants.
10. Address public statements: Did you ask Brooks or another official to make a statement? Did you review its content? Did you transmit it to LSU?
11. If a supported predicate is pleaded: authenticate the specific representation or property demand; establish contemporaneous knowledge, intended property recipient, and transaction; avoid asking whether all rule enforcement is “racketeering.”
12. Close with current position: Is there a present enforcement threat? Who can withdraw it? What remains necessary for an individual exception? Identify relevant records not yet produced.
Josh Brooks — public statement and personal participation
1. Authenticate the full recording/publication: speaker, date, venue, audience, completeness, edits, and whether the words were spontaneous or prepared.
2. Identify the precise referent: Which player, contract, school, or policy was being discussed? What did you mean by each disputed phrase in context?
3. Establish knowledge before speech: Had you seen a signed agreement? What source told you its terms? Did you distinguish a recruiting commitment from an enforceable contract?
4. Determine preparation and coordination: Who drafted or reviewed the remarks? What nonprivileged factual information was provided? What changes did you request?
5. Determine intended action: What did you want LSU or another listener to do? Did you ask for cancellation or merely express a policy view? Identify any private follow-up.
6. Trace receipt and causation: Who at LSU received the statement? Did that person tell you it influenced a decision? Is there a contemporaneous record?
7. Explore claimed justification: What governance or economic interest did you believe Georgia had in the particular relationship? Were you acting within delegated authority? Identify supporting records.
8. Separate personal and institutional acts: What did you personally vote, recommend, or authorize? What did the president or institution decide independently?
9. Address factual accuracy only where relevant: What basis supported each factual assertion? Did you receive a correction request or contrary information? What did you do with it?
10. Contract privity: Did you sign, guarantee, or otherwise personally undertake an obligation to either Plaintiff? If not, confirm that the dispute concerns alleged interference rather than your breach of their LSU contract.
11. Identify corrections, clarifications, subsequent messages, and any evidence of actual impact on offers or payments.
12. Close with complete sources and custodians, preserving privilege and avoiding unrelated personal matters.
Each other AD and president/chancellor
1. Authenticate the position held and actual delegated authority on the relevant date.
2. Separate personal attendance, recommendation, and vote from the school’s recorded action.
3. Identify information received about each Plaintiff and any particular agreement.
4. Examine the official’s own communications seeking a common position or LSU action.
5. Test the factual basis of the asserted educational or competitive objective and the official’s consideration of alternatives.
6. Identify the causal link between that official’s conduct and a specific school’s decision.
7. Establish any forum-directed acts and facts relevant to claimed immunity or privilege.
8. Identify unique knowledge not available from institutional records and confirm sources for disputed facts.
LSU decisionmaker and contract administrator
1. Establish authority, each agreement’s terms, and who bore the professional-status eligibility risk.
2. Walk through the assurance, execution, professional departure, enrollment, and termination dates without assuming their order.
3. Identify the decisive communication and all independent reasons for the decision.
4. Ask the counterfactual directly: absent the restriction, would the agreement or roster opportunity have remained? On what evidence and conditions?
5. Determine whether Brooks’s statement was received before the decision and actually considered.
6. Reconcile every payment, guaranteed sum, contingency, refund, offset, and substitute offer with source records.
7. Identify known reliance, feasible mitigation, and waiver efforts.
8. Confirm present willingness and remaining barriers for the requested injunction.
Plaintiffs and their authorized agents — preparation topics
1. Full eligibility and professional history, including signed contracts, compensation, roster activity, releases, and remaining obligations.
2. Exact assurances received, known uncertainty, authority of speakers, and documents preserved.
3. Every agreement, offer, payment, condition, and termination notice; distinguish guaranteed and contingent amounts.
4. Specific actions taken in reliance, with dates and receipts; do not assume leaving the NFL was induced by LSU.
5. Alternative opportunities actually available and mitigation efforts, including communications declining or accepting offers.
6. Plaintiff-specific economic computation, offsets, and the basis for any projected future loss.
7. Unique season-related harm supported by concrete dates, not a generalized desire to play.
8. Preservation of communications and consistency
These are examination plans, not accusations or substitute organizational notices. Select questions after documents and earlier testimony establish the foundation. Mark actual exhibits and record contradictions accurately; do not assume the answer.
Greg Sankey
1. Establish role and authority: What decisions could you make alone? Which required a board or member vote? Identify the delegation and any limits.
2. Separate chronology: Who first proposed the professional-status exclusion? What changed between the first draft, final rule, and sanction resolution? Authenticate each version.
3. Identify assent: Who attended each meeting? Were votes by institution or individual? What did LSU support, oppose, or abstain from? What record establishes each answer?
4. Establish knowledge: When did you first learn of Wright’s and Harris’s particular agreements? What contract terms did you actually know? Who supplied that information?
5. Examine the actual demand: What did you tell LSU to do? Did you demand termination, roster exclusion, or another action? What sanction did you identify? Who authorized the communication?
6. Test causation: What response did you receive? Did LSU identify an independent reason? What facts show your communication changed its decision?
7. Test competitive justification: What empirical information supported the rule? Did you assess remaining seasons, actual professional play, or individual circumstances? What contrary evidence was considered?
8. Explore alternatives: What grandfathering, waiver, transition, or academic-based approach was proposed? Why would each fail? What cost or operational data supports that conclusion?
9. Clarify coordination: Did you seek agreement from other conferences or merely learn their public positions? Identify the actual exchange and participants.
10. Address public statements: Did you ask Brooks or another official to make a statement? Did you review its content? Did you transmit it to LSU?
11. If a supported predicate is pleaded: authenticate the specific representation or property demand; establish contemporaneous knowledge, intended property recipient, and transaction; avoid asking whether all rule enforcement is “racketeering.”
12. Close with current position: Is there a present enforcement threat? Who can withdraw it? What remains necessary for an individual exception? Identify relevant records not yet produced.
Josh Brooks — public statement and personal participation
1. Authenticate the full recording/publication: speaker, date, venue, audience, completeness, edits, and whether the words were spontaneous or prepared.
2. Identify the precise referent: Which player, contract, school, or policy was being discussed? What did you mean by each disputed phrase in context?
3. Establish knowledge before speech: Had you seen a signed agreement? What source told you its terms? Did you distinguish a recruiting commitment from an enforceable contract?
4. Determine preparation and coordination: Who drafted or reviewed the remarks? What nonprivileged factual information was provided? What changes did you request?
5. Determine intended action: What did you want LSU or another listener to do? Did you ask for cancellation or merely express a policy view? Identify any private follow-up.
6. Trace receipt and causation: Who at LSU received the statement? Did that person tell you it influenced a decision? Is there a contemporaneous record?
7. Explore claimed justification: What governance or economic interest did you believe Georgia had in the particular relationship? Were you acting within delegated authority? Identify supporting records.
8. Separate personal and institutional acts: What did you personally vote, recommend, or authorize? What did the president or institution decide independently?
9. Address factual accuracy only where relevant: What basis supported each factual assertion? Did you receive a correction request or contrary information? What did you do with it?
10. Contract privity: Did you sign, guarantee, or otherwise personally undertake an obligation to either Plaintiff? If not, confirm that the dispute concerns alleged interference rather than your breach of their LSU contract.
11. Identify corrections, clarifications, subsequent messages, and any evidence of actual impact on offers or payments.
12. Close with complete sources and custodians, preserving privilege and avoiding unrelated personal matters.
Each other AD and president/chancellor
1. Authenticate the position held and actual delegated authority on the relevant date.
2. Separate personal attendance, recommendation, and vote from the school’s recorded action.
3. Identify information received about each Plaintiff and any particular agreement.
4. Examine the official’s own communications seeking a common position or LSU action.
5. Test the factual basis of the asserted educational or competitive objective and the official’s consideration of alternatives.
6. Identify the causal link between that official’s conduct and a specific school’s decision.
7. Establish any forum-directed acts and facts relevant to claimed immunity or privilege.
8. Identify unique knowledge not available from institutional records and confirm sources for disputed facts.
LSU decisionmaker and contract administrator
1. Establish authority, each agreement’s terms, and who bore the professional-status eligibility risk.
2. Walk through the assurance, execution, professional departure, enrollment, and termination dates without assuming their order.
3. Identify the decisive communication and all independent reasons for the decision.
4. Ask the counterfactual directly: absent the restriction, would the agreement or roster opportunity have remained? On what evidence and conditions?
5. Determine whether Brooks’s statement was received before the decision and actually considered.
6. Reconcile every payment, guaranteed sum, contingency, refund, offset, and substitute offer with source records.
7. Identify known reliance, feasible mitigation, and waiver efforts.
8. Confirm present willingness and remaining barriers for the requested injunction.
Plaintiffs and their authorized agents — preparation topics
1. Full eligibility and professional history, including signed contracts, compensation, roster activity, releases, and remaining obligations.
2. Exact assurances received, known uncertainty, authority of speakers, and documents preserved.
3. Every agreement, offer, payment, condition, and termination notice; distinguish guaranteed and contingent amounts.
4. Specific actions taken in reliance, with dates and receipts; do not assume leaving the NFL was induced by LSU.
5. Alternative opportunities actually available and mitigation efforts, including communications declining or accepting offers.
6. Plaintiff-specific economic computation, offsets, and the basis for any projected future loss.
7. Unique season-related harm supported by concrete dates, not a generalized desire to play.
8. Preservation of communications and consistency
Posted on 9/3/26 at 10:25 pm to LSU Patrick
I’m high af right now. Can you tell me if you’re doing this to be annoying or cause you’re serious. Cause if it’s to be annoying…that’s hilarious. But if you serious, you kinda weird
Posted on 9/3/26 at 10:26 pm to Nado Jenkins83
I just laugh at bama baseball
It’s cool I laugh at womens bball. There’s only two serious sports at the collegiate level
It’s cool I laugh at womens bball. There’s only two serious sports at the collegiate level
Posted on 9/3/26 at 10:27 pm to bamabaseballsec
U. Third-party subpoenas — proposed schedules
Use a separate subpoena issued from the court where the action is pending. Provide the required advance notice and copy to every party before serving a document subpoena. Select a lawful place of compliance, allow reasonable time, respect territorial limits and objections, and avoid imposing undue burden or significant expense on a nonparty. Electronic delivery does not eliminate those requirements. Resolve compulsory-disclosure and confidentiality issues for student records. No subpoena is issued by this package.
NCAA — if not a party
NCAA-1. The operative eligibility provisions, waivers, and determinations specifically applicable to the named Plaintiffs.
NCAA-2. The named Plaintiffs’ waiver applications, supporting nonprivileged submissions, and final responses.
NCAA-3. Communications with the SEC or LSU about the interaction between the challenged SEC restriction and each Plaintiff’s remaining NCAA eligibility.
NCAA-4. Existing coded comparator decisions on the same professional-history criteria during the narrowed period.
NCAA-5. Documents stating any independent NCAA barrier remaining if the SEC restriction is removed.
Player agents and actual NIL/compensation counterparties
AGENT-1. The named Plaintiff’s executed agreement and substantive amendments involving the subpoenaed entity.
AGENT-2. Offer and negotiation communications concerning eligibility risk, guaranteed compensation, and termination.
AGENT-3. Payment and cancellation records for that agreement.
AGENT-4. Communications showing a specific opportunity lost because of the challenged restriction.
AGENT-5. Documents showing actual available alternatives and mitigation, limited to the relevant period.
Professional team — only the team actually involved
PRO-1. The named Plaintiff’s professional contract and release documentation.
PRO-2. Documents sufficient to show roster dates, actual compensation paid, and the nature of the professional participation relevant to eligibility.
PRO-3. Communications with the Plaintiff or agent concerning the reason and timing of departure, limited to the alleged reliance issue.
PRO-4. Any concrete continuing offer allegedly surrendered; do not seek an entire team personnel database or unrelated scouting files.
Publisher or event organizer — Brooks Statement authentication
MEDIA-1. The original complete recording/publication of the precisely identified event and statement, if not obtainable from a party.
MEDIA-2. Existing metadata sufficient to authenticate time, speaker, and material edits.
MEDIA-3. Published corrections or clarifications concerning that statement. Evaluate reporter’s privilege before seeking unpublished newsgathering or source material.
Other conferences or willing schools
OTHER-1. The specific communications with the SEC alleged to constitute coordination, limited to identified custodians and dates.
OTHER-2. The named Plaintiff’s concrete offer or recruiting opportunity and any withdrawal based on professional-status restrictions.
OTHER-3. The final applicable rule and implementation decision. Begin with parties’ copies and public documents to reduce third-party burden.
V. Damages development and the requested $100 million demand
The demand must be tested against individual losses. The fact that a conference receives large revenues does not establish that two players lost $100 million. Discovery should build or disprove the requested threshold. No amount in this package is a finding or an expert valuation.
1. Create one ledger per Plaintiff: contract/counterparty; guaranteed gross amount; covered period; amount earned or paid; cancellation date; applicable condition; replacement income; recoverable net loss; supporting Bates numbers.
2. Separate school compensation, scholarship value, third-party NIL contracts, reliance expenditures, and claimed consequential loss. Remove overlapping categories and verify who was legally obligated to pay.
3. For each lost opportunity, identify an actual willing counterparty, terms, probability of completion, reason for loss, and mitigation. Distinguish an unsigned discussion from an enforceable guarantee.
4. For future earnings, require a legally permissible, reliable expert method with supported assumptions, probability, duration, discounting, offsets, and causation. Do not equate lost college participation with a guaranteed NFL career.
5. Compute antitrust injury separately from contract injury. The economic expert should distinguish market harm, individual over/undercompensation, and loss attributable to an independently valid eligibility barrier.
6. For any RICO count, connect the business/property loss directly to the pleaded predicate scheme rather than merely repeating the total contract demand.
7. Prepare a defendant-by-defendant causation chart and assess where joint and several liability is legally available. Do not assign the full loss separately to every official without a legal basis.
8. Present alternative totals: supported actual loss; qualifying antitrust trebling; qualifying RICO trebling if proven; nonduplicative other relief. Do not multiply the same injury successively under both statutes.
9. If the evidence does not support aggregate compensatory damages exceeding $100 million, revise the allegation before filing or amend it appropriately. A class-wide estimate cannot be used in this individual complaint without a proper class theory.
W. Evidence-to-claim completion gates
1. Antitrust: authenticated agreement and participants; defensible market; competitive effects or market power; legitimate justifications and alternatives; each Plaintiff’s independent eligibility and willing buyer; direct loss.
2. Individual liability: personal act, knowledge, causal participation, forum contacts, claim-specific standard, and immunity/privilege analysis for each person. A title list is a research scope, not a liability finding.
3. Interference: an identified relationship; defendant knowledge; actionable intentional interference; state-law stranger/privilege issues; decisionmaker receipt; actual causation and loss.
4. Brooks: complete statement; context; prior contract knowledge; intended action; actual recipient and effect. Distinguish opinion and governance advocacy from a supported tort. Do not assume personal contract privity.
5. RICO: qualifying predicates with Rule 9(b) detail where applicable; person/enterprise distinction; operation/management; relationship and continuity; direct domestic property injury; supported conspiracy agreement. If these remain absent, omit the counts.
6. Contract/reliance: correct entity; authority; enforceable promise; conditions; performance; termination terms; reasonable reliance; damages; arbitration/forum provisions; jurisdiction and immunity.
7. Emergency relief: current order and docket; imminent deadline; specific irreparable harm; current enforcement
Use a separate subpoena issued from the court where the action is pending. Provide the required advance notice and copy to every party before serving a document subpoena. Select a lawful place of compliance, allow reasonable time, respect territorial limits and objections, and avoid imposing undue burden or significant expense on a nonparty. Electronic delivery does not eliminate those requirements. Resolve compulsory-disclosure and confidentiality issues for student records. No subpoena is issued by this package.
NCAA — if not a party
NCAA-1. The operative eligibility provisions, waivers, and determinations specifically applicable to the named Plaintiffs.
NCAA-2. The named Plaintiffs’ waiver applications, supporting nonprivileged submissions, and final responses.
NCAA-3. Communications with the SEC or LSU about the interaction between the challenged SEC restriction and each Plaintiff’s remaining NCAA eligibility.
NCAA-4. Existing coded comparator decisions on the same professional-history criteria during the narrowed period.
NCAA-5. Documents stating any independent NCAA barrier remaining if the SEC restriction is removed.
Player agents and actual NIL/compensation counterparties
AGENT-1. The named Plaintiff’s executed agreement and substantive amendments involving the subpoenaed entity.
AGENT-2. Offer and negotiation communications concerning eligibility risk, guaranteed compensation, and termination.
AGENT-3. Payment and cancellation records for that agreement.
AGENT-4. Communications showing a specific opportunity lost because of the challenged restriction.
AGENT-5. Documents showing actual available alternatives and mitigation, limited to the relevant period.
Professional team — only the team actually involved
PRO-1. The named Plaintiff’s professional contract and release documentation.
PRO-2. Documents sufficient to show roster dates, actual compensation paid, and the nature of the professional participation relevant to eligibility.
PRO-3. Communications with the Plaintiff or agent concerning the reason and timing of departure, limited to the alleged reliance issue.
PRO-4. Any concrete continuing offer allegedly surrendered; do not seek an entire team personnel database or unrelated scouting files.
Publisher or event organizer — Brooks Statement authentication
MEDIA-1. The original complete recording/publication of the precisely identified event and statement, if not obtainable from a party.
MEDIA-2. Existing metadata sufficient to authenticate time, speaker, and material edits.
MEDIA-3. Published corrections or clarifications concerning that statement. Evaluate reporter’s privilege before seeking unpublished newsgathering or source material.
Other conferences or willing schools
OTHER-1. The specific communications with the SEC alleged to constitute coordination, limited to identified custodians and dates.
OTHER-2. The named Plaintiff’s concrete offer or recruiting opportunity and any withdrawal based on professional-status restrictions.
OTHER-3. The final applicable rule and implementation decision. Begin with parties’ copies and public documents to reduce third-party burden.
V. Damages development and the requested $100 million demand
The demand must be tested against individual losses. The fact that a conference receives large revenues does not establish that two players lost $100 million. Discovery should build or disprove the requested threshold. No amount in this package is a finding or an expert valuation.
1. Create one ledger per Plaintiff: contract/counterparty; guaranteed gross amount; covered period; amount earned or paid; cancellation date; applicable condition; replacement income; recoverable net loss; supporting Bates numbers.
2. Separate school compensation, scholarship value, third-party NIL contracts, reliance expenditures, and claimed consequential loss. Remove overlapping categories and verify who was legally obligated to pay.
3. For each lost opportunity, identify an actual willing counterparty, terms, probability of completion, reason for loss, and mitigation. Distinguish an unsigned discussion from an enforceable guarantee.
4. For future earnings, require a legally permissible, reliable expert method with supported assumptions, probability, duration, discounting, offsets, and causation. Do not equate lost college participation with a guaranteed NFL career.
5. Compute antitrust injury separately from contract injury. The economic expert should distinguish market harm, individual over/undercompensation, and loss attributable to an independently valid eligibility barrier.
6. For any RICO count, connect the business/property loss directly to the pleaded predicate scheme rather than merely repeating the total contract demand.
7. Prepare a defendant-by-defendant causation chart and assess where joint and several liability is legally available. Do not assign the full loss separately to every official without a legal basis.
8. Present alternative totals: supported actual loss; qualifying antitrust trebling; qualifying RICO trebling if proven; nonduplicative other relief. Do not multiply the same injury successively under both statutes.
9. If the evidence does not support aggregate compensatory damages exceeding $100 million, revise the allegation before filing or amend it appropriately. A class-wide estimate cannot be used in this individual complaint without a proper class theory.
W. Evidence-to-claim completion gates
1. Antitrust: authenticated agreement and participants; defensible market; competitive effects or market power; legitimate justifications and alternatives; each Plaintiff’s independent eligibility and willing buyer; direct loss.
2. Individual liability: personal act, knowledge, causal participation, forum contacts, claim-specific standard, and immunity/privilege analysis for each person. A title list is a research scope, not a liability finding.
3. Interference: an identified relationship; defendant knowledge; actionable intentional interference; state-law stranger/privilege issues; decisionmaker receipt; actual causation and loss.
4. Brooks: complete statement; context; prior contract knowledge; intended action; actual recipient and effect. Distinguish opinion and governance advocacy from a supported tort. Do not assume personal contract privity.
5. RICO: qualifying predicates with Rule 9(b) detail where applicable; person/enterprise distinction; operation/management; relationship and continuity; direct domestic property injury; supported conspiracy agreement. If these remain absent, omit the counts.
6. Contract/reliance: correct entity; authority; enforceable promise; conditions; performance; termination terms; reasonable reliance; damages; arbitration/forum provisions; jurisdiction and immunity.
7. Emergency relief: current order and docket; imminent deadline; specific irreparable harm; current enforcement
Posted on 9/3/26 at 10:27 pm to bamabaseballsec
Is 1 of them a sport where bama played a pro player for 5 games and had no repercussions?
Posted on 9/3/26 at 10:30 pm to TutHillTiger
Not really paying attention because watching the game but this took less than 10 minutes if that. It was my case I would spend a few days on this.
My point is simply to show a little bit what the players lawsuit will look like. Does this look cheap to defend or fun to you guys ? The real one will be 1000 times worse
My point is simply to show a little bit what the players lawsuit will look like. Does this look cheap to defend or fun to you guys ? The real one will be 1000 times worse
Posted on 9/3/26 at 10:42 pm to ColoradoElkHerd
You have a license in Texas, Ark, Louisiana, Mississippi and Alabama too?
Posted on 9/3/26 at 11:44 pm to ManBearSharkReb
quote:
Coonasses found out about chat gpt
Better to be a Coonass than Mississippi white trash
Posted on 9/4/26 at 2:41 am to BrohanDavey
Definitely my AI, but ask yours the odds of the SEC winning a case like that. I would sign on for a part of this in a NY minute. It’s hell of a lot easier that fighting insurance companies and will pay 100 times better. They are just as arrogant but never ever this fricking stupid.
Posted on 9/4/26 at 6:17 am to ColoradoAg
quote:
Who would read that wall of text?
Not Sankey.
Posted on 9/4/26 at 6:28 am to ManBearSharkReb
quote:
Coonasses found out about chat gpt
GPT would’ve summarized
Posted on 9/4/26 at 6:53 am to TutHillTiger
Ain’t nobody reading all that you fricking idiot.
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