PH. CIN-TEL CORPORATION 513-621-7723 FX. 513-621-6558 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION JASON MOBERLY, Plaintiff, vs. THE UNIVERSITY OF CINCINNATI 'CLERMONT COLLEGE, & ANN APPLETON, Individually, & KIMBERLY ELLISON, Individually, & JAMES MCDONOUGH, Defendants. CASE 1:08CV569 DEPOSITION OF: BRIAN SULLIVAN Tuesday, May 19, 2009 1:30 p.m. Reported By: Jennifer Strothers WWW.CINTELCORPORATION.COM E-Mail CINTELCO0GMAIL.COM 5c383ff3-157a-414f-991f-3feea6bd138e
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5/19/09 deposition given by Brian Sullivan (Moberly v. UC Clermont et al)
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Page 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION
JASON MOBERLY, Plaintiff, vs. ) CASE 1:08CV569
THE UNIVERSITY OF CINCINNATI CLERMONT COLLEGE,
& ANN APPLETON, Individually,
& KIMBERLY ELLISON, Individually,
& JAMES MCDONOUGH, Defendants.
The deposition of BRIAN SULLIVAN, witness herein, taken by the plaintiff as upon cross-examination pursuant to the Federal Rules of Civil Procedure and pursuant to Notice and stipulations hereinafter set forth at the offices of Marc Mezibov, 401 E. Court Street, Cincinnati, Ohio at 1:30 p.m., on Tuesday, May 19, 2009, before Jennifer Strothers, a notary public within and for the State of Ohio.
It is stipulated by and between counsel for the respective parties that the deposition of BRIAN SULLIVAN, witness herein, may be taken at this time by the defendant as upon cross-examination pursuant to the Federal Rules of Civil Procedure and pursuant to Notice and agreement of counsel as to the time and place; that the deposition may be taken in stenotypy by the notary public court reporter and transcribed by her out of the presence of the witness; that
13 the deposition is to be submitted to the deponent for his examination and signature, and that the signature may be affixed out of the presence of the notary public court reporter.
Page 6 1 BRIAN SULLIVAN, 2 of lawful age, as having been duly sworn, was 3 examined and testified as follows: 4 CROSS-EXAMINATION 5 BY MR. MEZIBOV: 6 Q Mr. Sullivan, good afternoon. I am
Marc Mezibov. You met Susan Lawrence, my 8 associate. We represent Jason Moberly in this 9 lawsuit. You do not have to contend with both of
us; I will be the only one asking you questions. Have you ever had your deposition taken?
A No, I have not. Q Couple guidelines to help get through as
quickly and easily as possible. My guess is Mr. Hoying informed you of these, but it is worth repeating. When I ask a question, I intend it to be purposeful. I want to get information. I do not want to confuse or mislead you and I want you to understand me. If my question presents a problem, just say you do not understand or it is confusing or whatever it takes.
Jennifer is taking everything down I say and you say and everyone says during the course of the proceeding unless we go off the record. But
1 in any event, we want to have as accurate and 2 complete as possible. We can help Jennifer by not 3 speaking over one another and extending the 4 courtesy. Let me finish my question before you 5 begin answering and I will hear your complete 6 answer be fore I begin another question. 7 Please answer all the questions audibly; 8 I will ma ke sure you do. Nods of the head and 9 winks, dc not cut it. You have to say "yes" or
10 "no" or whatever is appropriate- Okay? 11 A Okay. 12 Q Please state your complete name. 13 A Brian Osborne Sullivan. 14 Q Mr. Sullivan, where do you reside? 15 A Eastwind Court, Anderson Township. 16 Q Are you employed? 17 A Yes. 18 Q By whom? 19 A University of Cincinnati. 20 Q In what capacity? 21 A I am the program coordinator at Clermont 22 College. 23 Q How long have you been program 24 coordinat or?
A Little over three years. Q Before we get into your job duties, what
is your educational background? A I have Bachelor!s from the University of
Cincinnati, graduated 1992, human social services. Q Since leaving school have you always
worked in the UC arena so to speak or other institutions or other places?
A Other places. Q Where have you worked?
11 A I have worked for the Cincinnati 12 Cyclones at First Star for seven years as director 13 of operations for the hockey team and moved into
director of operations for the building. I worked briefly at Coca-Cola as a sales representative. And my last job prior to this was for a company, Brand New, LLC; they owned restaurants and I ran some of their Subway restaurants for a brief period of time.
Q How did you get your position at UC 21 Clermont? 22 A I looked on the website for jobs at UC 23 website and saw there was opening for coordinator 24 in athletics.
Page 9 1 Q Tell me what the program coordinator 2 consists of? 3 A I oversee the athletic program for 4 day-to-day operations. We currently have six 5 athletic programs. We have men's basketball, 6 women's basketball, volleyball, baseball, softball 7 and golf I do all the scheduling, all the 8 transportation. I check up on all the 9 eligibility. Anything day-to-day to do with the
10 athletic program. 11 Q You're like an athletic director? 12 A Yes. 13 Q With a different title? 14 A Yes. 15 Q Did you know anyone at UC Clermont 16 before you applied for this position? 17 A No. 18 Q Were you interviewed for the position? 19 A Yes. 20 Q By whom? 21 A Just a couple -- do you want names? 22 Q Sure. 23 A Nancy Raveal was on the committee. Trey 24 Trip was on that committee. I believe the former
1 dean, Dean David Deveer was on the committee. And 2 I do not recall who else. There were five or six 3 people. 4 Q That is the search committee? 5 A Yes. 6 Q Were anyone of the individuals in the 7 room for this deposition part of that committee? 8 A No, they were not. 9 Q Did any person in this room ever
10 interview you for that position? 11 A No, they did not. 12 Q To whom do you report? 13 A Kim Ellison. 14 Q And what is her title? 15 A She is director of student life. 16 Q Does she evaluate you? 17 A Yes, she does. 18 Q On an annual basis? 19 A Yes. 20 Q When were you last evaluated by Ms. 21 Ellison? 22 A Last June. 23 Q June '08? 24 A Yes.
Page 11 1 Q Were you satisfied with your evaluation? 2 A Yes. 3 Q Did you get a raise? 4 A I believe we all — two percent. 5 Q Is that across the board? 6 A I am not sure, but I know mine was. 7 Q Did you get a merit increase? 8 A No. 9 Q Did you ever apply for one?
10 A No. 11 Q Would you be eligible for one? 12 A I am not sure. 13 Q Now, you said one of the programs for 14 whi ch you have responsibility is basketball? 15 A Yes. 16 Q What division or level is the 17 bas ketball? 18 A We are a member of the United States 19 Collegiat e Athletic Association. It is equivalent 20 to NAIA or NCA Division III; that is our national 21 association. Our local organization is the Ohio 22 Reg rional Campus Conference. 23 Q Are scholarships available? 24 A No, sir.
A Primarily Associate degrees. We do have some areas to get your Bachelor!s in nursing and criminal justice.
Q Most there are two-year degree programs? A Yes, they are.
8 Q What is your responsibility as it 9 relates to the basketball program?
A I schedule their games; I schedule transportation to get to the away games; I am responsible for their equipment, uniforms, shoes,
13 sweatpants, so on. I am responsible for student activity center where they practice. I schedule the practice times. I am also responsible for finding out who is on the team and checking eligibility to make sure they are eligible for the upcoming season.
Q Okay. How many basketball team members are there?
A Approximately 15. Q Do you know how individuals are selected
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23 for the team? 24 A Primarily recruiting. Coaches recruit.
Page 13 1 Q Do you have any involvement in 2 recruiting? 3 A No, I don't. 4 Q Do you have any eligibility requirements 5 associated with recruiting? 6 A Yes, we do. 7 Q What are those? 8 A You have to have -- well, to get into
Clermont you have to have a GED or high school diploma. Once you are in, you have to maintain a 2.0 GPA and have -- once you are in two quarters, so third quarter, you'd have to have 24 credit hours from the two previous quarters. Do you
14 understand? 15 Q Probably not.
A It is basically a full-time student and passing. That is a USCA rule.
Q In a given quarter -- is it a quarter system there?
A Yes. 21 Q Is it now semester? 22 A Still quarter. 23 Q Quarter means you run from -- what is 24 that?
1 A September -- early September till June 2 13th is graduation. There are three quarters in f 3 that time ■ \
4 Q First is September to December? 5 A December. Middle of December. And 6 January 6th thereabouts to March 15th. 7 Q So if basketball season starts — most 8 situations it starts practice in October? 9 A Yes.
10 Q Games in November? 11 A Early November. 12 Q If I am a first-year student at 13 Clermont, what do I need to have academically to 14 compete in that first year? 15 A For the first quarter or first year, \ 16 full-time student, 12 credit hours and enrolled [ 17 from your first quarter. 18 Q That will take me up to January? 19 A Yes. 20 Q Then January through March is second 21 quarter? ; 22 A Yes. \ 23 Q If the season concludes, then I will 24 only be ji idged — or eligibility is determined [
1 based on the first quarter's performance? 2 A Correct. 3 Q Then the following year, if I play 4 again, I will be judged on --5 A On the two previous quarters you 6 attended. 7 Q That would take me to the end of my 8 basketball career then, a two-year period? 9 A USC allows for a four-year eligibility
10 and we do have players for four years. 11 Q How do they do that? They keep 12 enrolled? 13 A Yes. With the standards that have to be 14 met. Again, we have students in criminal justice 15 and nursing students that stay for the full four 16 years. 17 Q But full-time enrollment in any given 18 quarter is — the minimum number of --19 A Credit hours? 20 Q Yes. 21 A 12. 22 Q Do you have any involvement in the 23 selection of the coaching staff? 24 A Yes.
Page 16 i 1 Q How SO? j 2 A I am usually on a committee that j 3 consists of myself; usually Kim Ellison; if we are j 4 selecting the assistant coach then, the head; and j 5 if we are selecting a head coach, it would be a j 6 third person selected to be on that committee. I 7 Q Your first year at Clermont was when, 1 8 approximately? j 9 A October of 2006. 1
10 Q Okay. When you first came to UC j 11 Clermont, did the college have a men's basketball 12 coach? j 13 A Yes. j 14 Q Who?■ t 15 A John Hurley. j 16 Q He had been there for how long, if you \ 17 know? I 18 A Can't be certain. I will say up to this ( 19 current date, probably six years. So probably two I 20 years before I came. 1 21 Q If you know, in October, what was his \ 22 arrangement or contractual arrangement? 23 A When 1 came in he was the director of I 24 student life and head men's basketball coach.
1 Q As head basketball coach, does he get 2 stipend above and beyond that of head of student 3 life? 4 A Yes, I would assume. Now he is making 5 approximately $5,200.00. 6 Q As basketball coach? 7 A Yes. 8 Q When you came in October !06, he was the 9 coach and director of student life?
10 A Yes. 11 Q Through that season, which would last 12 until spring T07, he continued in that capacity? 13 A Yes. 14 Q Was there an assistant coach? 15 A No. 16 Q Was anybody that helped Mr. Hurley? 17 A Yes. 18 Q Who was that? 19 A Anthony Robertson. 20 Q Who is Anthony Robertson? 21 A Anthony was a student worker up at the 22 student activity center. 23 Q How does — if you know, how did Anthony 24 Roberts come to assist Mr. Hurley?
Page 18 1 A He was there when I got there. 2 Q So you had nothing to do with appointing 3 him? 4 A No. 5 Q Was he an undergraduate? 6 A Yes, he was. 7 Q A full-time student? 8 A Yes, he was. 9 Q Did he play for the team?
10 A No, he did not. 11 Q He just assisted? ■ 12 A Yes. 13 Q How did he assist? 14 A I would say, from what I experienced, 15 his role was anything as assistant coach. 16 Q Was he paid? 17 A Not for basketball. It was volunteer. 18 He was a work-study student at the activity 19 center, . so that is all I know. He was paid 20 through an hourly KRONOS system that we use for 21 his hours. He clocked in and out at the student 22 activity center. 23 Q Is Mr. Robertson African-American? 24 A Yes, he is.
1 ended up coincidentally getting his social work 2 degree from UC Clermont is very driven to help 3 people. 4 Q How did it come to pass that he had this 5 role as mentor? Is that a formal assignment he 6 had or something that he assumed? 7 A I do not believe so; that it was formal, 8 I think it just happened. 9 Q Did you ever speak with Coach Hurley
10 about the role? 11 A No. 12 Q Did you speak with Anthony about his 13 responsibilities on the team? 14 A No. 15 Q Have you spoken to Anthony? 16 A Yes. 17 Q In what connection; what kind of 18 matters? 19 A He worked for me at the student activity 20 center, which is our building on campus. That is 21 where students can — it is open daily. They can 22 shoot basketball, play ping-pong, lift weights. 23 He ran that during his time when I was there. 24 Q He received hourly wage for doing that
Page 21 1 or some thing? 2 A Yes. 3 Q How long did he do that? 4 A I am not sure how long he was there 5 prior t o me coming, but he did it up until last 6 May. 7 Q May '08? 8 A Yes, a year ago. 9 Q What was your relationship with him?
10 A We had a good relationship. 11 Q Did you find him to be responsible? 12 A Yes. 13 Q Did you have any conversations with him 14 about how African-Americans were doing on campus, 15 particu ilarly the student athletes? 16 A Yes. 17 Q Tell me about those conversations. 18 A Again, he was very driven and determined 19 to give people chances, all athletes. So he did a 20 lot of our recruiting. It seemed like he did a 21 lot of the recruiting, I can't say that for sure. 22 Seemed like he did a lot of recruiting in the 23 inner city and bring kids in from the inner city 24 to Batavia. And he would be a mentor role and do
Page 22 anything he could to make sure these individuals were successful on campus.
Q Did he ever discuss with you any specific problems or issues associated with the
5 lives of these African-American student athletes there?
A I can't recall anything specific. We did have conversations at practice about players finding a place to live. We have apartments near us. He was always trying to help them get places to live. If there was anything about a class that they could not get into or needed to get into, then he would come to me and ask for my help.
Q Let me ask you something about the team. You said there are typically 15 players on
16 the team? A Yes. Q In the year October '06 through '07, how
many of the 15 were African-Americans? A Nine, ten. Q Has that been the percentage since? A Yes. Q If you know, what's -- strike that.
Page 24 1 Q He stayed through the 2007/2008 year? 2 A Yes. 3 Q Just as he had the previous year? 4 A Yes, he did. 5 Q Now, at this point did you know a 6 gentleman named Jason Moberly? 7 A At this point, no, I did not. 8 Q When did you first hear the name Jason 9 Moberly 7
10 A Probably October f07. 11 Q Okay. 12 A Or thereabouts, the beginning of that 13 basketball season. 14 Q How did you hear about that? 15 A He came into the gym one day and 16 apparen tly he and John were coaching 17 acquain tances. 18 Q John Hurley? 19 A Yeah. Were coaching acquaintances or 20 friends and he wanted to help out the team. 21 Q Were his services utilized in any way in 22 2007? 23 A Yes. 24 Q How so?
coach at the beginning. As we got to know each other, we had never used our assistant coaching money. That job remained open as far as the University was concerned because Anthony was a volunteer, not getting paid for basketball just work-study money that he clocked in and clocked out with.
Q How much assistant coaching money was 10 there? 11 A $2,300.00.
Q Is there a particular reason Anthony did not receive that money?
14 A You cannot be a student and an 15 employee. Anthony understood and he chose --
obviously he wanted to finish his degree. Q So there was $2,300.00 in the budget for
18 an assistant coach? 19 A Approximately.
Q When Jason came in 2007, there is still $2,300.00 in the bank, so to speak?
22 A Correct. 23 Q Now, is it in the fall 2007 he started
Page 26 1 team? 2 A Yes. 3 ■ Q Was there a decision somewhere in 2007 4 that his position would change from a volunteer to
a paid employee? A As the weeks went on that year. But as
the weeks went on, I had spoken to Jason and I 8 felt we had the money and we should use it. We 9 hadn't had an official assistant coach. As we
looked into it more, the process for him to apply and the background check and everything, it would have been past the year and it would not have
13 worked out. So that's when we came to the 14 conclusion we could hire him as a temp through BGI 15 Services. 16 Q What is BGI Services?
A That is a temp service we use at University of Cincinnati.
19 Q You do not have to go through this background check; is that it?
A Do not have to go through the application process or paper. We just hired him on temporary -- to get through that year knowing we were going to open it up at the end of the year
Page 27 1 -- or June after the basketball season. 2 Q How was Jason's performance as far as 3 you were concerned? 4 A Fine. 5 Q Was there anything specific about Jason 6 that you thought spoke well for his ability to be 7 a coach on the team? 8 A Yes. Jason, he was a lot like Anthony.
He was very driven, really saw the person. It was not just a team or number to him, it was the person. Obviously his coaching qualities, he knows the game of basketball. And he and John Hurley got along very well.
Q Did you, in the course of 2007/2008 basketball season, make any statements to Jason about what the future held in that position?
17 A No. Just the fact that it would be 18 opening. But that was told at the beginning that
it would open up. It would be a process. Q Let me show you Plaintiff's Exhibit 1.
21 (Plaintiff's Exhibit 1 marked for 22 identification.)
Q I will represent to you that these are a string of e-mails. Can you just take a look at
Page 28 1 them? The first page at the top appears to be an 2 e-mail to you from Jason Moberly with attachments. 3 Is that a message you sent to Jason, "Just found 4 out we have to pay you through a temp service"? 5 A Yes. 6 Q Is that what you!ve just described for 7 us? 8 A Yes. 9 Q So these discussions about how he would
10 be employed and what needed to be done to 11 accomplish his hire was done in or about January 12 f08? 13 A Yes. 14 Q Now, what was your relationship with 15 John Hurley other than — did he report to you? 16 A Yes. At the beginning I reported to 17 him. After June '07 he reported to me. 18 Q Did you have a good working 19 relationship? 20 A Yes. 21 Q Did you get along well? 22 A Yes. 23 Q Did you ever have reservations about his 24 ability to coach the team?
No. We had our -- we are both very passionate but it was strictly for-the-good-of-the-program kind of talks. Nothing personal, no.
Q Did you have ever question or challenge anything he said as far as it being accurate or inaccurate?
A No. Q You believe he's an honest guy? A Yes. Q Trying honestly to do his job? A Yes.
(Plaintiff's Exhibit 2 marked for identification.)
Q Let me — I have handed you Exhibit 2 which I will represent to you is an affidavit of John Hurley that Mr. Hurley has prepared in connection with this case. Have you ever seen
1 Q Were you ever told by anyone that Mr. 2 Hurley had prepared an affidavit? 3 A John actually told me that, yes. 4 Q What did he tell you? 5 A Again, in the basketball season. And he 6 said he had to — actually he was going to be late 7 for one of the practices because he had to give an 8 affidavit. 9 Q Did he tell you what it concerned?
10 A No. 11 Q Did you ask him? 12 A No. 13 Q Let's go through this and read what Mr. 14 Hurley said and see if you have comments about 15 it. He says, "I am the head coach of Clermont 16 College. I have held that position since 2003." 17 Is that accurate as far as you know? 18 A As far as I know. 19 Q Second paragraph Mr. Hurley states, "In 20 the summer prior to the "08/'09 academic year, UC 21 Clermont began a search to fill the position of 22 assistant men's basketball coach at the college." 23 Is that accurate?
Page 32 1 equal. He wanted Jason to be the assistant coach 2 and I was all for that. I am a believer that a 3 head coach should have the final say or at least 4 some say in who his assistant is. 5 Q When you say "everything equal", what
are you referring to? A Well, you have to look at
qualifications. Q Was there a specific qualification or
types of background that you're looking for in 11 connection with assistant coach? 12 A Someone with college-age experience.
Again, at the college level, a plus would have been a previous coaching position or playing at different level, that being college level or
16 professional level. Internally, my personal feeling is I look at A: basketball which is select good quality coaching and recruiting, knowing people in the area.
Q Were these qualifications prioritized? In other words, did you say you were looking for a specific person for specific qualification or experience was preferred?
Page 33 1 website was college-age experience was one of the 2 things required, but I am not sure about 3 everythi ng else. 4 Q Let me go back — where was the ad 5 posted? 6 A On the UC website, JobsatUC.com. It was 7 in the j obs and athletics website called "Jobs and 8 Athletics", and beyond that, I am not sure. 9 Q Who determined the list of
10 qualifications? 11 A The list of qualifications? 12 Q Yes. 13 A I am not sure. 14 Q Did you have any input into that? 15 A No. 16 Q Did John Hurley? Let me rephrase the 17 question Who decided what the qualifications 18 would be for this position? 19 A Those were determined before I got 20 there. 21 Q Any specific discussion about what you 22 were loo king for in this year for the 2007/2008 23 team? 24 A As individuals or —
Q 2008 or 2009? j A As a committee? j Q Yes. Did the committee make any f
specific decisions about what the qualifications I for this candidate needed to be? j
A I do not believe there was anything said | specific except for college-age, someone with 1 experience -- with college-age experience. A plus j would have been if they had college coaching j background or college experience background. |
Who drafted the ad, if you know? | I am not sure. ! You did not? I No, I did not. j (Plaintiff's Exhibit 3 marked for j identification.) I Mr. Sullivan, you have been handed j
18 Exhibit 3. Can you identify this exhibit for us j 19 please? j 20 A This is the posting that goes on the j 21 jobs at UC website. I 22 Q Is that the posting for the assistant ) 23 coaching position? j 24 A Yes, it is. I
Page 35 1 Q I see you are listed as the supervisor 2 for this position? 3 A Yes. 4 Q There is a question here about 5 under-utilization; are you familiar with that? 6 A I am familiar with under-utilization.
Q What does that refer to? A The way I understand it, if you are
hiring in a position and it is under-utilized, whether it be some type of minority, either female or African-American.
12 Q According to this document 13 African-Americans were under-utilized in the
department's job cluster. I am on page 3. A Yes. Q What does that mean that they are under
utilized? Explain to me as best you understand it?
A The way I understand it, for this position which is assistant coach minor sports,
21 men's basketball, that African-Americans are 22 under-utilized in that position.
Q Were you seeking to hire an African-American for that reason?
assist coaching, attend state tournaments, set up for home games, drive the school van for trips"; that is not something that you prepared?
A No. Q Same with the job description below the
position description? 12 A Yes. 13 Q And the minimum qualification
were "basketball coaching experience, experience with working with college-age students, valid driver's license and experience with supervision and leadership." I do not see here any reference to college coaching or playing experience; is that
19 correct? 20 A Correct. 21 Q It is enough an individual might have 22 basketball coaching at a high school level or some 23 other amateur sport?
Page 37 1 interview * 2 Q What is kind of experience in working 3 with coll* sge-age students? Would that be 4 teaching, supervising, working as a college-age 5 student? 6 A The way I understand it is coaching 7 camps, AU basketball, anything. You could be 8 doing summer camps -- lot of high school coaches 9 do summer camps at local colleges.
10 Q Summer basketball? 11 A Yes. 12 Q Is that what you meant? 13 A Yes. 14 Q On a basketball level? 15 A Yes. 16 Q This job was posted on -- according to 17 page 4 — May 2, 2008? 18 A Yes. 19 Q Now, if someone were responding to this 20 posting, what would be the application process? 21 How would that work? 22 A They would go to -- if they found it 23 somewhere other than UCj obs.com, they could get an 24 application and mail it to me. Through
Page 38 j 1 JobsatUC. com, you fill it out online and I have j 2 the ability to go in and look at who has applied, j 3 Q Do you screen out people? j 4 A No. I print everyone's off and look at j 5 them thoroughly. 1 6 Q You look at them? j 7 A Yes. 1 8 Q You said a couple other people were | 9 involved in selection? )
10 A Yes. j 11 Q Mr. Hurley, the coach? | 12 A Yes. I 13 Q Kim Ellison? I 14 A Correct. I 15 Q When do they get into the process? | 16 A I print them off and I make copies for 17 them and we narrow it down as a group to three. 18 Q How many applicants did you have? Do 19 you remember? 1 20 A Probably five to six. 21 (Plaintiff1s Exhibit 4 marked.for 22 identification.) [ 23 Q I have asked that you look at Exhibit 4 24 which again, are some e-mail messages. Some of J
Page 3 9 1 the messages appear to be between you and Mr. 2 Moberly. Do you recall these communications? 3 A Yes. 4 Q The three pages in connection with 5 Exhibit 4, the first communication appears to be 6 from Jason to you dated May 6, 2008. Jason said 7 he tried to apply for the position and explains, 8 "I can't withdraw my application even though it
was cancelled. Do you want me to print out a cover letter?" What is your understanding what
11 that is about? 12 A The previous year when we were talking
about him applying for the job, before we realized from a time standpoint we need to go through a temp service, he went online at the time since the' position was still open and applied. When he went on in early May he could not reapply for the same position at that time.
19 Q What had to be done for him to be 20 considered? 21 A We needed — Nancy Raveal had to go in
and open that position back so he could get back in -- you can't apply for the same position twice. The website will not let you.
Page 41 1 no assistant coach. I have to wait until there
are three applicants, which I have now, and get through this quickly." Why were you saying that?
A Well, in the previous e-mail, he 5 e-mailed me and said, "I can't believe I have to
interview for a position that I have. Is this a typical thing every year? Do I have to do this again if I get the position?" I was just explaining to him that we pay him through a temp service so he was not a University employee --officially on the website — through the — officially he was not the assistant basketball coach and just to hang tight and we will get him through the process.
Q Does Mr. Hurley have to apply each year? A No, he does not. Q Why is that? A Once you are hired, you do not have to
apply anymore. And Jason will not have to apply this year. Jason was not on -- he had not done a background check. He was through the temp service.
Q The reason he had to apply was to get the background search done?
Page 42 f A That is part of it and so we could pay \
him through the University. I Q Assuming -- so I understand this I
clearly, in - the ordinary course of things, if an 1 individual is hired for assistant coach in the j typical hiring process, the following year he or j she need not be interviewed? j
A Correct. j Q Just rehired without going through the i
background check or interview process? j A Correct. j Q In connection with Jason, however, he j
was not hired in the ordinary course, he served j the same function — is that correct — as j assistant coach? j
Yes. I Performed the same duties? } Yes. I Same conditions and standards? I Yes. \ As a person ordinarily hired? j Yes. 1 Next year comes up and you want to hire j
24 through the ordinary process, are you looking for j
Page 43 1 anything other than background information to 2 clear him or are you looking for something extra 3 because it is a new hire? 4 A I was not even looking for background.
It is my understanding that is policy since the position is open, you have to do the search. We have had to do it for other sports.
8 Q Were you looking for anything other than 9 the background for Jason or does he automatically
have to be thrown into the mix with everyone else? Do you follow me?
A He had to — that is why I sent this e-mail the day it came out to apply for the position. As part of the process, we have to do it.
Q Now, let's go back to Mr. Hurley1s 17 affidavit which is Exhibit 2. Now, we have got to 18 the point were we know the search committee has
three persons: you, Kim Ellison and the coach. He goes on to say, "We interviewed several candidates for the position, including Jason who was assistant coach in the previous year." Did you
23 interview just three you said? 24 A T h r e e .
1 Q That was Melvin Levett, Keith Starks and | 2 Jason, correct? | 3 A Yes. j 4 Q Levett and Starks both played basketball j 5 at UC? j 6 A Yes. 7 Q Either one of them ever coached before? 8 A Melvin Levett was assistant coach at 9 Miami/Middletown and Keith Starks was AAU coach.
10 Q It says on page 2 of the affidavit, "We 11 all believed Moberly was most qualified person for 12 the job." Is that accurate? 13 A He was as qualified as everyone. He was 14 our choice. 15 Q Among the three? 16 A Yes. I 17 Q This is paragraph three: "Shortly after 18 his interview, Mr. Moberly notified me he 19 contacted Karen Fairborne, vice-provost for 20 academic personnel at UC main campus regarding his 21 concern about 'institutionalized racism1 at UC 22 Cle. cmont." j 23 Did you have any knowledge of Mr. 24 Moberly contacting Karen Fairborne concerning what
Page 4 6 1 athletes 2 Q Was there, in your view, any validity to 3 Jason's concerns about how African-Americans were 4 treated on campus? 5 A Not African-Americans. 6 Q Athletes in general? 7 A Yes. 8 Q How so? What is your view? 9 A It was — athletics at UC Clermont has
10 exploded and it is a work in process, it is 11 growing. We are trying to get all employees that 12 have to deal with each student on base. There is 13 a lot more work to do as far as checking 14 eligibil ity and seeing advisors sooner than later, 15 study tables for all athletes and we have worked 16 through that. 17 Q Did you respond in any way to what Jason 18 was expressing to you about his concern for 19 African-American athletes? 20 A No. 21 Q Did you think he was sincere? 22 A Yes. 23 Q Did you encourage him to take any action 24 or sugge st he do anything?
Page 4 7 1 A No, not take action. I did — with the 2 stuff that I knew was valid, to all athletes. I
took and ran with it at that point. Q The thing that you -- let me be clear.
What were the specific items that you thought were problems specific to athletes on campus?
A Getting athletes into particular classes that they needed in the season in order to travel and not miss class time. Getting them into a learning center, structured learning center, seeing an advisor in timely fashion, which we have
12 all since worked on. 13 Q You indicated a moment ago that Jason
said he tried to get reaction or response or assistance for African-American student athletes, but it had not happened. Did he relate to you what efforts he made or who he had spoken to?
A Not specifically, no. Q Now let's go to the second sentence on
the paragraph three of Mr. Hurley: "Mr. Moberly told me he spoke to the UC equal opportunity office"? Did you have any knowledge of that?
23 A Not until George Wharton called me. Q Do you know when that was?
Page 4£ 1 A I can't be sure. 2 Q What did Mr. Wharton say to you? 3 A He wanted to know -- two different 4 instances. One, I believe the incident he called 5 me about was not the first incident, it was the 6 second one that the basketball team was practicing 7 one day in the student activity center and my 8 student worker, which is a white female, there was
a cell phone missing -- and picked up a phone or picked up a bag which she felt the phone may have
11 been there on the bleachers. And Jason came to me 12 saying he felt that we were accusing the
African-American of stealing the phone during the practice and had actually gone to me and told me
15 about it. I believe he had -- I do not know if 16 Jason did, but the individual involved spoke to 17 Ann about it and Kim about it. And we called the 18 student in and I talked to the student and his
answer was he did not feel that way but Jason wanted him to make that complaint to get it out there to keep this -- so he could help them — so Jason could help them.
Q Let me parse that out. There was a situation involving a missing cell phone?
Page 4 9 1 A Yes. 2 Q At the student activity -~ 3 A — center. 4 Q Where the team plays basketball? 5 A Yes. 6 Q Whose phone was missing? 7 A Just a girl on campus. 8 Q She had said, "My phone is missing"? 9 A Yeah. "Has anyone seen my phone?"
10 Q Someone had picked up a gym bag? 11 A The student worker at the time. 12 Q Who is that? 13 A Tonya Henderson. 14 Q She worked for you? 15 A Yes. 16 Q Ms. Henderson picked up a bag? 17 A There were jeans and bags on the 18 bleachers She asked where was she was sitting. 19 She said, "I was here", and she kind of picked up 20 some bags to see if the phone was there and if the 21 team had set a bag on top of it and it was an 22 acci dent. Just looking for the phone. Not in the 23 bags . Ju st picked it up sat it down. 24 Q What was she doing with the bags?
1 A Just picked it up and it was not there. 2 Q And who complained that this might be 3 problemat ic? 4 A Jason. 5 Q Jason said they felt it perhaps was — 6 A We were accusing African-Americans of 7 stealing. 8 Q You spoke with, I guess your worker? 9 A Yes.
10 Q And that was cleared up? 11 A Yes. When I spoke to the individual who 12 was accused as well, Seth Steele. 13 Q He was accused of what? 14 A It was his bag that was picked up, so 15 they were kind of -- in Jason's eyes -- accusing 16 him of st ealing the phone. 17 Q Mr. Steele is African-American? 18 A Yes. 19 Q So the matter was cleared up? 20 A Yes, it was. 21 Q You said there was a second instance? 22 A I did not -- I knew Jason told me he was 23 going to speak to George Wharton, but George 24
1 Page 51 1 Q So, as I understand it, Jason informed 2 you on two occasions that he had registered a 3 complaint to Mr. Wharton? 4 A Just the one, the first occasion. 5 Q When was the first occasion? 6 A That was probably in — I will say 7 December. 8 Q Of? 9 A '08.
10 Q Do you remember what that concerned? 11 A No, I do not. 12 Q There was something that happened -- how 13 did Jason come to you and say, "I am going to 14 Wharton" — or "going to Wharton about this 15 situation '; do you remember the context? 16 A No. 17 Q But you know sometime in or about 18 December f08 Jason came to you and told you he had 19 gone to Mr. Wharton about another matter? 20 A Not specifically. I knew he had gone to 21 George Wharton, but he did not tell me the matter. 22 Q Did he tell you why he went to Mr. 23 Wharton? 24 A No.
1 Q Did you ask him? 2 A No. 3 Q Do you remember the context of that 4 conversation; why he was even telling you? 5 A John and Jason and myself at basketball 6 practice and I was standing there and they talked. 7 Q Jason mentioned he had gone to Wharton? 8 A Yes. 9 Q You do not know when?
10 A No. 11 Q You did not hear from Wharton? ,12 A No. 13 Q The first time you heard from Wharton 14 was with the gym bag? 15 A Yes. 16 Q How long after was that? 17 A Quite a while later. 18 Q A month? 19 A Couple months. 20 Q Did Wharton ask you about anything other 21 than the gym bag incident? 22 A I canft recall. It was a quick phone 23 call • 24 Q He never seek to meet with you?
Page 53 1 A No. 2 Q Did he take a statement from you? 3 A No. 4 Q Do you remember questions he asked? 5 A Just if I knew anything about what 6 happened at the student activity center. 7 Q How long did you speak to him, would you 8 say? 9 A Five minutes.
10 Q That was the end of it? 11 A Yes. 12 Q Did you ever speak to Karen Fairborne 13 about any of the institutionalized racism? 14 A No. 15 Q Or anyone else? 16 A No. 17 Q Okay. Let!s go back to Mr. Hurley's 18 affidavit Before we do that, let me show you 19 Exhibit 5 -20 (Plaintiff's Exhibit 5 marked for 21 identification.) 22 Q Exhibit 5 appears to be e-mail from 23 Jason Mob erly to you dated 12/10/08. Are you 24 familiar with this document?
1 A Yes. 2 Q You remember receiving this? 3 A Yes. 4 Q Do you remember the circumstances which 5 you came to receive this? 6 A Yes. 7 Q Tell me what that is. 8 MR. HOYING: Objection. This is 9 long after the lawsuit was filed. I do not
10 need to object to every question, but it does 11 no relate to anything in the retaliation 12 complaint. 13 Q Can you tell me what you recall about 14 the context you received and read this e-mail? 15 A I received this e-mail a few days after 16 there was a confrontation between Jason Moberly 17 and Kim Ellison at the student activity center 18 about following the chain of command. 19 Q Tell me about that? 20 A I am not sure what it was about, but it 21 had to do with following the chain of command. 22 Q Did you witness the incident? 23 A Yes. 24 Q Tell me what you heard or saw.
Page 55 1 A Kim came up prior to practice, around 2 4:00 in the afternoon or something. There was a 3 — Kim confronted Jason about he needed to follow 4 chain of command in order to get things done and
this was follow-up the next day from Jason. Q Did you have any conversation with Jason
prior to receiving this e-mail about this matter? A No. Q But you are familiar with the subject
matter of he was talking about in this e-mail? 11 A The chain of command? 12
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15 chain-of-command discussion concerned? 16 A Again, I am not sure about that 17 particular incident, but it -- that I believe
Jason had gone to John Hurley about something 19 instead of me or Kim on the chain of command, and
things had gotten very cloudy, so Kim was reminding him to go through the chain of command.
Q Do you remember the issue? A No, I do not remember. Q He says in here, little past midway,
Page 5 6 "All I wanted to do was help with a student
athlete. I will continue to discuss things with 3 Coach Hurley, but from now on I will include that
in every e-mail I send. However, I did not discuss this e-mail with him. I was wrong when I thought because Brian was there that anything with student athletes go through him. I thought I was doing my job to help kids come to me for help." I do not need to read the rest of it. Is there something that Jason brought to your attention that Kim thought should have been brought to her attention first?
A Just by reading this, I do not know if this was the actual situation, but a lot of times there is advising going on in the coaching ranks to students. And a lot of times they are told wrong or inaccurate information. Just going by what you read, I do not know this particular incident, I cannot recall, but maybe academic advising or advising a student in the classroom or out of the classroom and they went to Coach Hurley and Coach Hurley okayed it.
Q You do not remember if Jason came to you first before he went to anyone else?
A I do not recall, no. Q It is accurate, is it not, under the job
description that Jason's supervisor was you? A Yes. Q If he had concerns involving his job or
matters on campus, that would be appropriate to come to you?
A Yes. Q Now, go back to Mr. Hurley1s affidavit,
paragraph 4, page 2: "Following the completion of the interview process for the assistant coaching position but before it was offered to anyone, I participated in a conference call with Mr.
17 Sullivan and Ms. Ellison." Is that statement 18 accurate?
A The position was offered when we made the conference call to him.
21 Q Tell me how this was done. How was the 22 interview process conducted and how that worked?
A Myself, Kim Ellison, John Hurley were on
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Page 58 i 1 Starks and Jason Moberly. Shortly after that, j 2 within a couple days, we just happened — it was j 3 time for their evaluations. We brought John j 4 Hurley in for his evaluation. That day, which did { 5 not go very well, but after that evaluation was j 6 over we stuck around for a few moments and we j 7 decided amongst our group that Jason Moberly would 8 be the candidate we would recommend. j 9 Q All three of you?
10 A Yes. j 11 Q Including Kim Ellison? 12 A Yes. 13 Q What was it about Jason's application 14 that made him the preferred candidate? 15 A The biggest thing in my mind, he had 16 been there for a year and was familiar with the 17 program and John wanted him. There was no reason IS at that point to make a change. 1 19 Q Did Kim Ellison express any preference [ 20 for anyone else? i 21 MR. HOYING: Objection. 1 22 Q At any time? You can answer. 1 23 A Not that I am aware of, no. 24 Q Did she ever express the belief that \
Page 59 because Keith Starks coached overseas he had a leg up on Mr. Moberly?
A No. Not at that meeting. 4 Q Some other time did she? 5 A Yes. 6 Q When was that?
A After that meeting, Kim had either --somehow contacted Keith Starks. Melvin Levett was out of the process because he had taken another position. All we had was applications, to follow up on any kind of -- anything else he had to offer. At that time he said he had played basketball for the Boston Celtics, played overseas, which gives him a lot of credibility at that point. He played -- he was good friends with Mick Cronin and very familiar with the UC basketball program. Within a couple days after that, we had gotten together with Kim and myself
19 and that is where the conference call came in. 20 Q Let me get the sequence of events. 21
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Following the process of -- the interview process for assistant coaching position, you are saying following this evaluation of Mr. Hurley, the three of you decided to stick around and deal with
1 selection of assistant coach? [ 2 A Yes. j 3 Q All three were still in the mix? 4 A At that point, yes. 1 5 Q Levett, Starks, Moberly? 6 A Yes. 7 Q All three of you decided the consensus j 8 candidat e was Moberly? 9 A Yes.
10 Q Now, was it offered -- was the job then 11 offer tc — when was the job offered to Mr. \ 12 Moberly following the meeting with Coach Hurley? 13 A The job was never offered to Mr. 14 Moberly. :
15 Q The three of you come to a decision? 16 A To recommend. : 17 Q Who did you recommend him to? ] 18 A Now it goes to Ann Appleton and the 19 dean. : 20 Q So the three of you came to a decision 21 that Jason would be recommended to Ann Appleton i 22 and the dean for hire? 23 A And I am not sure who else. 1 24 Q He did not know — after that meeting he l
Page 62 retaliation. And Wharton was investigating it. George Wharton actually came to campus, but I was on vacation but I did speak to him on the phone. His question to me — the brief conversation on the phone — was just that "What did Kim say the reasoning was?" or "Why Jason may not want the job
7 anyways?" Q So, did you respond to Mr. Wharton? A Yes. Q What did you say?
11 A I told him what Kim said. 12 Q What did Kim say? 13 A After John calmed down that Jason didn!t
get the job and felt he had been stabbed in the back, the head coach not being able to hire his assistant. He said, "Well, I hope you guys know you have a lawsuit coming out of this." At one point, Kim!s response was "Why would Jason even want to work here if he is that upset about everything that is going on?"
Q Is there anything else you want to clarify?
A That was in -- probably my conversation with George Wharton probably happened in early
Page 63 1 July. The reason I missed him on campus, I was on 2 vacation in late June. 3 Q So let me — 4 A He came to campus and met with several 5 other people that day. 6 Q After the break, you now recall that you 7 had two conversations with Mr. Wharton? 8 A Yes.
Q The first is July f08? A Yes.
11 Q And the second was when? 12 A December. 13 Q The December conversation concerned the
bag? A The duffle bag. Q The July conversation concerned the
allegation by Jason he did not get the job for personal reasons?
A Yes. Q Did Mr. Wharton come to you on that
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24 Q How long did you speak to him? A Again, five minutes, ten minutes.
Page 64 1 Q Did he ever present a statement for you 2 to review?
A No. Q Did he tell you when he received this
complaint of Mr. Moberly? A No. Q Had Mr. Wharton not called you, would
you know Mr. Moberly filed this complaint? A No. Q Did you ever speak to Jason Moberly
following your conversation with Mr. Wharton the first time?
A Concerning that particular incident? Q Yes. A No. Q We will go back. Go to paragraph 4 of
— go through this. We are back on Exhibit 2, which is the Hurley affidavit. I am looking at paragraph 4, Mr. Hurley states, "Following the completion of interview process for assistant coach and before it was offered to anyone, I participated in a conference call with Mr. Sullivan and Ms. Ellison." Do you agree there was conference call among yourself, Ms. Ellison and
Page 65 1 Jason Moberly and John Hurley? 2 A Yes. 3 Q "In that conference call Ms. Ellison 4 indicated that the purpose of the phone call was
to inform us that Mr. Moberly was not going to be hired." Did Ms. Ellison, in the course of that phone conference, the purpose was telling you Moberly was not going to be hired?
A Yes. Q And that Hurley asked for the reason for
her decision. Do you remember him doing that? "Why is that Kim?" or words to that effect?
A Yes. Q "Then Kim told him over the phone that
Moberly would not be hired because, in effect, he complained to the officials on the main campus regarding institutional racism at UC Clermont affecting African-American athletes." Is that
19 what she said? 20 A No. 21 Q What did she say? 22 A She said that when John said how upset 23 he was about it and there was going to be a 24 lawsuit — "You have a lawsuit coming" is how he
1 Page 67 1 A Yes. 2 Q I am assuming this conference call is 3 taking Pi ace June 23rd. Ellison is telling you 4 and Hurle y for the first time that Moberly would 5 not be hired, correct? 6 A I knew — we called Keith Starks prior 7 to call in g John. 8 Q Who had? 9 A Me and Kim to offer him the position.
10 Q When did you and Kim call? 11 A That morning, just minutes before we 12 called John. 13 Q On the 23rd? 14 A I am not sure. 15 Q So on the 23rd you and Kim placed a call 16 to Keith Starks? 17 A Correct. 18 Q The reason for that was what? 19 A My reasoning was to see if he was even 20 intereste d in the position. 21 Q Why is that you were calling Keith 22 Starks on June 23rd? 23 A To offer him the position. 24 Q Why did you offer him the position?
1 Page 68 1 A Because Kim followed up with some 2 information and had his playing experience and his 3 ties to the University of Cincinnati. 4 Q Kim told you she preferred to hire Keith 5 Starks? 6 A Yes. 7 Q Is that the first time you heard that? 8 A He was at the top, a quality candidate. 9 Q My question is more narrowing than
10 that. 11 A Okay. 12 Q My question is: Is the first time that 13 you heard that Kim Ellison wanted to hire Keith 14 Starks on the morning of June 23rd? 15 A Yes. 16 Q She told you because she had more 17 information about him? 18 A Correct. 19 Q And the information she had gotten about 20 Keith Starks was that he had coached overseas? 21 A Played. 22 Q And when you got of bed on morning of 23 June 23rd , before you went to the meeting and had 24 your firs t cup of coffee or whatever you do, was
Page 69 1 it your understanding Mr. Moberly was still the 2 preferred candidate? 3 A At that time, yes. 4 Q When Kim called you and she had a new
take, that was still your understanding? A Yes. Q Did she tell you why — did she suggest
you and she place a call to John Hurley and say she decided to go a different way?
A Yes. Q Did you place a call to John Hurley? A After we placed a call to Keith Starks,
yes. Q Even before asking Hurley if he wanted
15 Starks to be his assistant coach? 16
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— irregular that you would select an assistant 19 coach without even checking with the head coach as 20 to whether that was in keeping — 21 A Yes. 22 Q Is that correct? 23 A Yes.
Page 7 0 1 A Yes. 2 Q What did she say? 3 A Based on what she had learned and the 4 fact it was an under-utilized position and we all 5 agreed at the first interview that there was not 6 much difference between Keith, Jason or the other 7 candidate — but the other candidate was out of 8 the picture at this point so it only left two
candidates — with everything being equal, this is the way they felt they had to go.
Q It was an under-utilized position, and would you agree on June 9th, when the three of you
13 discussed the three candidates, two of them were 14 African-American and the decision to select 15 Caucasian, it was still under-utilized position, 16 correct?
A Correct. Q At that point, that it was
under-utilized position was not mitigating in favor of Mr. Starks or Mr. Levett, correct?
A Correct. Q So, what tipped the balance is what you
23 are telling me — strike that. What tipped the balance in your view in favor of Starks?
Page 71 1 A The fact — the experience that we 2 uncovered playing overseas, playing professional 3 basketball and relationship with the town campus. 4 Q How did you uncover that? 5 A Kim spoke to him on the phone. 6 Q Did Mr. Starks provide that information 7 in his application? 8 A It was not on his application that we 9 had in the interview.
10 Q He played overseas? 11 A Played, yes. 12 Q Not that he coached, he played? 13 A Yes. 14 Q All his coaching experience had been 15 fully revealed and laid out in his application? 16 A From what I am aware of. 17 Q You know he played UC basketball? 18 A Yes. I know him very well. 19 Q So the fact he played overseas, what is 20 it about playing overseas that makes that 21 experience valuable on the UC Clermont campus? 22 A I am not sure. I look more to 23 professionalism than to overseas. 24 Q Is there any reason -- assuming this is
Page 72 interesting and good credentials, Kim Ellison is touting this individual as preferred candidate, is there a reason you did not place a call to Coach Hurley before you offered the position to Starks to see whether he was interested in the position?
A No. Q You do not know why or do you know why? A I do not know why. Q Now, did you know at that point on the
morning June 23rd that sometime prior to June 23rd that Jason Moberly had registered complaints to
12 either Wharton or Karen and someone at the UC 13 administration? 14 A I knew he had complaints. I knew as far 15 back as basketball season. 16 Q Did you know he had taken those
complaints to the administration by the morning of
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Page 73 1 Q Kim Ellison's view as she expressed 2 them, why was that? 3 A He made comment over the whole 4 basketball season about different things going on. 5 Q He knew he wanted to be the coach? 6 A Sure. 7 Q And you knew he wanted to be the coach? 8 A Sure.
Q So, just so I am clear, I will ask again, I do not know if I received an answer. If I did, I apologize if it!s in the record. According to Hurley, he asked Kim the reason for her decision to go with Starks, and she said Moberly would not be hired because he complained. As you recall, what is it that Ellison said to Hurley on the phone in that conference call in response to Hurley's question why?
A Something to the effect, John said, "You know there's a lawsuit coming"; and Kim said, "John, why would Jason want to be here if he is
so unhappy?" or something to that effect. Q Did you understand from that — did you
come away with that response that Kim no longer wanted to hire Moberly because he was unhappy?
Page 7 4 1 A I did not think I understood it would
not be that big of an effect on any of them because he was so unhappy of how things were going.
Q When she responded to John Hurley's question why you no longer want him to be the coach, and she said, "Well, he is not happy anyway", did you understand that to be a reference to the fact that Moberly had registered complaints?
11 MR. HOYING: Objection. You can answer. My objection is that he never testified to that. I think your question was whether or not in response to Hurley's --Q Let me rephrase it.
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testified to. Q Let me go back. At some point in the
phone conference, John Hurley says to Kim Ellison — does he not ~- "Why have you changed your
mind? Why do you want Starks instead of Moberly?" A Yes.
Page 75 1 Q Kim made a reply, correct? 2 A Correct. 3 Q I understand that reply from your 4 testimony to be, "Well, why would Jason want to be 5 here anyway? He is unhappy" or something to that 6 effect? 7 A That is after the fact he was playing 8 for the Boston Celtics and playing overseas and 9 his relation with UC.
10 Q Then she said? 11 A Then he said, "You will have a lawsuit 12 coming out of this"; and she responded something 13 to the effect, "If he is that unhappy, why is this 14 — big of a blow" or what "If he is unhappy, why 15 would he want to be here?" 16 Q Any further conversation? 17 A Not that I recall. 18 Q Did you have any conversation — what 19 you are saying, Mr. Hurley's statement isn't 20 correct? 21 A Yes. That wording is incorrect. 22 Q Have you discussed this affidavit with 23 Mr. Hurley? 24 A No.
Page 7 6 1 Q Did the final paragraph 4 — strike 2 that. He goes on five lines from the bottom of 3 paragraph 4 of affidavit, "She" — meaning Ellison 4 — "stated she had obtained additional 5 information about another candidate for the 6 position which reflected he played professional 7 basketball overseas and said this is additional 8 reason of selection of another candidate." You 9 heard Ellison say that; is that correct?
10 A Yes. 11 Q That part is correct? 12 A Yes. 13 Q Then it goes on to say, "I, in turn, 14 explained my belief that overseas play had no 15 apparent relevance to the assistant coaching 16 position." 17 A Yes. 18 Q Did you hear Hurley say that? 19 A Yes. 20 Q So the only part that you disagree is 21 him attributing Kim Ellison saying that Moberly 22 would not be hired because he complained to 23 officials on UC campus, correct? 24 A Correct.
1 Page 77 I 1 Q So, how did that conference call [ 2 terminate 5? ? 3 A I can't recall. Rather abruptly I am j 4 sure. i
5 Q Were you sitting with Hurley at that | 6 point? : 7 A No. 1 8 Q Where were you? 9 A In Kim? s office. [
10 Q You were with Kim at that point? 11 A Yes, on a speakerphone. 1 12 Q Did you every speak with Hurley about 13 what had taken place in that conference call? 14 A Not specifics. 15 Q Generalities. Did he ever say anything 16 to the e ffect that Kim had stated basically that 17 because Jason had gone downtown, he was not going 18 to be hi red and that is how Hurley saw it? 19 A No. We did not talk about it. We did 20 talk about -- as I stated early on, the head 1 21 coach, I feel the head coach should have a say in 22 the assistant, but that is not the way it went, 23 Q So after this conference call, what 24 happened with the coaching position? I
Page 78 { 1 A I began to contact Keith Starks on j 2 multiple occasions. Did reach him to get the j 3 process s tarted to get his social security and ! 4 birthday. Then I called again multiple occasions 5 with no response at all. Until we resorted to 6 weeks out , and sent him certified letter saying 7 that "If you do not respond to this letter, we [ 8 have to assume you do not have interest in the 9 position anymore and will be closed up." And he
10 still has not responded to this day as far as I 11 know. \
12 Q What was done with the coaching 13 position? < 14 A At the time it was offered to Jason 15 Moberly. |
16 Q Did he serve in that capacity? 17 A Yes. 18 Q How did he do? 19 A Fine. 1 20 Q What is his status now with respect to l 21 the coach ing position? 22 A He is assistant men's basketball coach. 23 Q Through what period? 24 A There is no period. [
or background information about himself? j No. I Do you know student athlete Stefan Dunn? j Yes. I Who is that? j Stefan played basketball for UC j
Clermont. He graduated in December -- sorry, last j June. j
Q June f08? I A Yes. Played for UC Clermont and was j
four-time All-American National Player of the [ Year. Very good player. I
Was he honored by the school? j Yes. j How so? j We retired his jersey. j When was that? i November of this year, at a game. I How did that — who made the decision to 1
20 honor Dunn? j 21 A Myself and Kim, Ann Appleton and the l 22 Dean McDonough. f 23 Q Was the idea to honor Dunn suggested by I 24 Jason Moberly? j
Page 81 1 A Originally, yes. 2 Q When was that? 3 A I would say January to March '08. In 4 that time frame. 5 Q What was the initial response to that 6 suggestion? 7 A That I would take it to my superiors. I 8 thought it was a good idea. 9 Q Did anyone object?
10 A There was no objection to honoring him. 11 We just had not retired a jersey at UC Clermont. 12 We had no current credentials -- there was no 13 guidelines to retiring a jersey. There was 14 nothing to go by in that. 15 Q Do you know an individual by the name of 16 Monica Johnson? 17 A Yes. 18 Q Who is she? 19 A She is former employee that worked at 20 the student service center. 21 Q Have you ever spoken to her? 22 A Just to say "Hi." 23 Q Is she still with the University?
Page 82 Q Do you know her last forwarding address? A No. Q Do you have access to that information? A No, I do not. Q To your knowledge, has she ever spoken
to anyone with University administration about the treatment of student athletes at the Clermont
8 campus? 9 A Not that I am aware of.
(Plaintiff!s Exhibit 7 marked for 11 identification.) 12 Q Mr. Sullivan, you have been handed a
copy of Exhibit 7 which appears to be a document entitled Staff Application with the position of assistant coach submitted by Keith Starks on or about May 15th. Do you see that?
A Yes. Q Are you familiar with this document? A I am just familiar with the first two
pages. Q Let's go to the front page, job position
-- job title is assistant coach position number. Is that the position for which you received applicants?
Page 83 1 A As far as I know, yes. Assistant coach, 2 minor sports. 3 Q Now, attached to that is a letter from 4 Starks "To whom it may concern." Have you ever 5 seen this document before? 6 A No. 7 Q Do you know if this was attached to this 8 application? 9 A It was not attached to the application
10 when I pulled it off, no. 11 Q Have you ever seen this at all? 12 A No, I have not. 13 Q Now, I'm assuming this is from Starks. 14 Personal interview — "I would like to schedule a 15 meeting." Did you meet with Starks at some point? 16 A Yes. 17 Q He was a candidate? 18 A Yes. 19 Q You had the opportunity to ask about 20 experience in life and experience from basketball 21 and coaching and what have you? 22 A Yes. 23 Q How long did you spend with Mr. Starks? 24 A Probably 45 minutes, an hour.
4 Q And who was at that interview? 5 A John Hurley, Kim Ellison and myself. 6 Q Were you careful to ask what you thought 7 to be important questions concerning credentials? 8 A Yes. 9 Q Would that include his history as a
basketball player? A Yes.
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college? 16 A We had a list of questions. 17 Q Did you ask about after UC, "What did
you do with your basketball career?" A I canft recall. Q Is that a normal question? A Yes.
22 Q Is that an important question? A Yes. Q Given that's the position you are hiring
i 1 for? i 2 A Yes . I 3 Q Did you ask him if he played basketball | 4 domestically since graduating UC? I 5 A I can? t recall. I 6 Q Is that a normal question? | 7 A Would be. j 8 Q Let me ask you to look at the document. | 9 That appears to be a resume or CV of Mr. Starks. j
i 10 Had you ever seen this before? | 11 A No. 1 12 Q Do you know how this came to be online [ 13 at the University of Cincinnati? j 14 A Sorry? I 15 Q Do you know how this came do be online? 1 16 A No. j 17 Q The second page appears to be a resume | 18 of Mr. Stark's basketball playing experience. Do 1 19 you see that? j 20 A Yes. j 21 Q It lists UC and period with the Celtics j 22 and some stints in Belgium, Italy, France and | 23 China. Do you see that? j 24 A Yes. j i "• 8 WWW.CINTELCORPORATION.COM E-Mail CINTELCO0GMAIL.COM
T98; is that accurate? A Yes. Q Is it your testimony you did not explore
with him these experiences when you had a personal 6 interview with Mr. Starks?
A Based on our list of questions, the only thing that came out of the questions that he offered was the fact he played under Bob Huggins and at the University of Cincinnati.
Q You are telling us you did not ask him, or Kim Ellison did not ask him, or Coach Hurley did not ask him at his personal interview whether he played basketball beyond the University of
15 Cincinnati? 16 A No. 17 Q As he left that personal interview, you
had no idea what his basketball experience was from 1993 through 1998?
A Just based on the questions, all he 21 offered us, he was UA coach and assistant coach at 22 Anderson High School. 23 Q Mr. Starks, in a 45-minute interview,
Page 87 j 1 to you or anyone at the interview, the fact he ) 2 played with the Boston Celtics or spent several j 3 years in Europe playing professional basketball? j 4 A No. 1 5 Q Did you think you conducted a thorough | 6 and professional interview? j 7 A Based on the questions we had, those j 8 were the answers we received. | 9 Q That's all I have. Thank you. j
4 HAMILTON COUNTY ) I, Jennifer Strothers, the undersigned,
a duly qualified and commissioned notary public within and for the State of Ohio, do hereby certify that before the giving of his aforesaid deposition, the said BRIAN SULLIVAN was by me first duly sworn, to depose the truth, the whole truth, and nothing but the truth; and that the foregoing is a deposition given at said time and place by the said BRIAN SULLIVAN; that said deposition was taken in all respects pursuant to Notice; that said deposition was taken by me in stenotypy and transcribed by computer-aided transcription under my supervision; and that the transcribed deposition is to be submitted to the witness for his examination and signature.
I further certify that I am neither a relative of nor attorney for any of the parties to this cause, nor relative of nor employee of any of
23 their counsel, and have no interest whatsoever in the result of the action. 24
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Posting _ . Semi- .... Post .. . , _ .« n - * Guest _ .. . Hiring u . Notes / Specific Points ,, Finalist „ a , Hire u . . ' ^ .. User ,_ Proposal _ . .. History Questions Form - Detai s 7
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Clermont College
CC Athletics
Asst Coach Minor Sp (Ne)
70031403
Job Title Assistant Coach Minor Sports (NE
Limited To
Working Title (if different from Job Title) Assistant Men's Basketball Coach
Organizational Unit Number 60000155
Campus Clermont
Recruitment Number (for Provosta! area)
lob Reference Number 272394
Position Number (For Human Resources) 27UC2394 PLAINTIFF'S
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View/Edit Posting - Assistant Coach Minor Sports (NE) Mbb - 27UC2394 Page 3 of 5
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13.03
Position Description:
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Assist coaching, attend state tournament, set up for home games, drive school van for trips. Develop and implement a plan to write, call and meet local high school coaches for the purpose of recruiting; attend high school schools to recruit players and meet parents; develop plan to recruit prospects on Clermont College campus; attend coaching clinics for growth and development.
Basketball coaching experience, experience in working with college-aged students; valid driver's license. Experience with Supervision and leadership
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Email Notification -The preferred mode of correspondence is via email. I f you provided us with an email address on your application, we will email you information regarding your application status. All applicants are advised to periodicaily check their file for updated information regarding application status.
Resume Cover Letter
h%s://wwwjobsatuc.com/userfite^^ 4/6/2009
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Thank you for your interest in this position. The screening and selection process is currently underway and will continue until a successful candidate is chosen. Should review of your qualifications result in a decision to pursue your candidacy, you will be contacted.
Thank you for your interest in this position. Based on your responses to the questions on the employment application, you do not meet the minimum qualifications for this position. Please do not let this discourage you from applying for other positions that interest you.
I tried to apply for the position but because I had to do it last year, it won't allow me to re-apply. I can't withdraw my application even though it was canceiied. I don't know if you want me to print out a cover letter and resume or what you want. I can give you the username and password that I created so you can go in and look at it. My information is still on. there (cover letter, resume) just doesn't include last season.
The position is up on the website. I wanted to let you know so you can get on it today.
Thanks Brian
Brian O. Sullivan Program Coordinator/Athletic Director UC Clermont College 4200 Clermont College Drive Batavia, OH 45103 Tel: (513)558-1559 Cell: (513)325-4599 -Fax: (513)732-5303
The position is up on the website. I wanted to let you know so you can get on it today.
Thanks Brian
Brian 0. Sullivan Program Coordinator/Athletic Director UC Clermont College 4200 Clermont College Drive Batavia, OH 45103 Tel: (513)558-1559 ^ Cell: (513) 325-4599 Fax:(513)732-5303
You were paid through a temp service last year so in the eyes of the university there was no assistant coach. I have to wait until there are three applicants which I have now and will get through this quickly.
Brian
From: Jason Moberly [mailto:[email protected]] Sent: Tuesday, May 20, 2008 2:25 PM To: Sullivan, Brian (sullivbr) Subject: RE: meeting
I still can't believe that I have to interview for a position that I already have. Is this a typical thing every year? Will I have to do this again if I get the position?
What is the best day to meet next week for your interview for the men's basketball assistant coaching position?
Thanks Brian
Brian O. Sullivan Program Coordinator/Athletic Director UC Clermont College 4200 Clermont College Drive Batavia, OH 45103 Tel: (513)558-1559 Cell: (513) 325-4599 Fax:(513)732-5303
Sent Wed 12/10/08 334 PM To: Brian (suilivbr) Sullivan ([email protected])
Brian,
Can you forward th is on to Kim, I don't have her emaii address.
As a coach at Ciermont my main concern is for the students. I tried to help the students get everything they need in order to be successful at the college level not only on the basketball floor but in the classroom. I have always put academics in front of athletics and will continue t o do so. I understand the "chain of command". As of now, I will fol low the chain of command when it comes to basketball and helping the kids get enrolled at the college. These student athletes are more important to me than anything else. As a coach, success is built by what your players have accomplished in the classroom and by what they do after graduation. I see my job as an Assistant basketball coach t o help these students become successful. The only way for them to be successful is if they can get the help they need to get into college and that's what I though I was doing. All I wanted to do was help these student athletes. I will continue to discuss things with Coach Hurley but from now on, I wil l include that in every email that I send. However, I did not discuss this email with him. I was wrong when I thought that because Brian was the athletic director that anything regarding student athletes would go through him. I thought I was doing my job by helping kids who come to me for help. As I stated before, I will continue to follow the chain of command but I will include Coach Hurley's name if I have to email. the Athletic Director for any future assistance in making sure these kids have a successful transition into college and athletics.
Jason
Send e-mail anywhere. No map, no compass. Get your Hotmail account now.
A7&
Thmi
AMor
Cathysft
40
PLAINTIFFS EXHIBIT
wtrv//hin W H , , i 1 <; mflil.«ve.com/maiiyinboxLiehtasDX?Foldern>=00000000-0000-0000... 4/26/2009
EDUCRTIQH Southern State Community College, Associate of Applied Business (Business Management Technology: Computer Programming Major) Embanet Training Course (awaiting testing for A+ Certification) White Oak High School
C0MFOTHISHI1S • Visual Basic, Pascal, and Visual C++ Programming • Excelled at programming projects assigned by Professor ■ Took a leadership role in helping other students complete programming projects • Windows 95, Windows 98, Windows 2000, Windows XP, Windows ME, Windows NT, MS-DOS • Web Design and development for private business • Repair Computer Hardware, Troubleshooting • Excel Spreadsheets • PowerPoint • MS-Mail, MS-Word, Word Perfect • FrontPage • Install and Uninstall Software and Hardware including Printers, Scanners, and Digital Cameras • Maintaining, operating, and troubleshooting V-Tel systems • Updated Computer Labs, Faculty and Staff PC's • Efficiently answer phone calls to helpdesk, solve problems over phone or fixing at computer
WDRKHISTOBY Helpdesk Technician, Siemens Business Services (May 2007—Present) Answer phones Troubleshoot computer problems from three different companies AH troubleshooting is done over the phone All companies are world wide
Head Men's Basketball Coach, Southern State Community College Scheduled practices and games Prepared our team for practices and upcoming games Maintained the team budget Scouted potential players Recruited top players in five county areas Actively promoted players to four year colleges Actively promoted program to community
Technology Assistant, Southern State Community College (July 2001 ~ September 2005) Install and uninstall software Clean and repair hardware Troubleshoot problems with classroom and lab computers Oversee all computers at Central Campus computer labs Maintain and operate Distance Learning (V-Tel System) Help maintain network stability
1002-2006)
Applicant Information Page 1 of 2
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rtaff Application
Requisition Number:
272394
Position Number:
27UC2394 Job Title: Ass i s t an t Coach Minor Spor ts (NE) Mbb
For purposes of compliance with The Immigration Reform and Control Act, are you legally eligible for employment in the United States? Yes
Are you a previous or current University of Cincinnati employee? No
If you are a previous or current University of Cincinnati employee, what is your ID number?
In case of emergency, who should we notify? (Please include name and phone) Leann s tarks 513-659-0022
^tfiajse select your preferred working site(s): ; University of Cincinnati West Campus Clermont CoBege Branch Campus (Batavia, Ohio) University Medical Schools (Colleges of Medicine, Nursing X College of Applied Science (2220 Victory Parkway) and Pharmacy) Raymond Waiters Branch Campus (Blue Ash, 9555 Plainfield Road)
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d ip loma
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< jjlemental Questions What prompted you to apply to the University of Cincinnati? Referred by UC Employee
Please specify from above {if applicable): Mic C ron in men 's basketba l l coach
Agreement The University of Cincinnati is a drug-free workplace. Individuals offered employment at The University of Cincinnati may be required to successfully complete a pre-employment physical which includes drug testing. Individuals who refuse to take orwho fait the drug test, after being informed, will be removed from employment consideration. A ) ! understand that any intentional or unintentional misrepresentation of fact in this application will because for dismissal, cancellation of offer, and/or negotiation of any additional employment considerations or agreements. J hereby authorize the University of Cincinnati to investigate these statements without liability arising therefrom. By my agreement of this statement I authorize any city, county, state, or federal law enforcement agency or court related thereto to release information they possess concerning me or any prior arrest which resulted in conviction. B) 1 also agree to abide by the University's Smoke Free Workplace rules as established. C) I also realize that my employment is dependent upon the successful completion of a physical examination and'attendance at orientation for new employees.
BY SIGNING BELOW, I certify that i have read and agree with these statements.
william keith starks Applicant's Mame Applicant's Signature Date
I suspect you'll find very few candidates with a background such as mine—and it's one I'd like to put to work on your behalf.
As you'll see on the enclosed resume, the depth of my experience in the sports industry will shine through. As a college & professional basketball player and most recently a high school & AAU Coach, my dedication to coaching and commitment to the players is the reason for my success.
Moreover, having worked in various Sports Management roles in a variety of different environments I have a diverse background and can easily adapt to any situation. I have the background to manage players, their grades, the ability to multi-task and handle conflict resolution. It is a long term passion of mine to be in a position to do what I absolutely love/helping other people and being around sporting events of alt levels. It is this passion that allows me to offer you a true partner as you Assistant Basketball Coach.
A personal interview would allow me to demonstrate my talents. 1 look forward to hearing from you so that we can schedule a meeting.
UNIVERSITY OF CINCINNATI 1987-1992 Bachelor of Arts- College of Education
NCAA Basketball Scholarship Athlete
PROFESSIONAL EXPERIENCE
FIRST FINANCIAL BANK 2005 ~ 2007
FINANCIAL PLANNING SPECIALIST Wealth Resources Group - Hamilton, Ohio
Partners with Trust Administrator teams in efforts to create a customized constructive portfolio with the future goals of each client at the forefront of every plan. Develops financial solutions concentrating in estate and asset protection strategies, business owner planning, retirement planning, and investment management.
Advising and handling all aspects of financial planning. Supervision and coaching branch staff to provide financial freedom for retail investment clientele. Overseeing 1.5 million dollars under management.
FINANCIAL NETWORK GROUP 2000 - 2004
DIRECTOR OF FINANCIAL PLANNING Cincinnati, OH
Committed to the success of clients and strived to provide financial stability to individual and institutional investors. Built book of 22 million dollars of assets under management.