By Christopher Walsh
Sports Writer
June 08, 2005


TUSCALOOSA | In a 1,500-page document filed in the 
Circuit Court of Tuscaloosa County late Wednesday 
afternoon, attorneys for former University of Alabama 
assistant coaches Ronnie Cottrell and Ivy Williams 
outlined what will likely be the basis of their case 
when the $60 million defamation lawsuit goes to trial 
next month.

In it were details of what they contend was a 
three-cornered conspiracy between recruiting analyst Tom 
Culpepper, Tennessee coach Phillip Fulmer and the 
National Collegiate Athletic Association "to injure, 
damage and defame the plaintiffs and their employer, the 
University of Alabama."

The document, primarily in four large binders, was in 
response to motions for summary judgement made by both 
the NCAA and Culpepper last month.

Wednesday was the deadline for a response.

Among other things, the brief claims that Culpepper, 
whom along with Fulmer was a secret witness for the NCAA 
in its investigation against Alabama, "testified falsely 
under oath," openly defamed the plaintiffs and 
"confessed that he told several different people that 
Ronnie Cottrell was a cheater and a liar that would have 
a hard time finding a job, and that he had no proof of 
such allegations."

Specifically, "Culpepper even admitted making specific 
defamatory remarks that Ronnie Cottrell had arranged for 
someone to take a fraudulent ACT test in Tallahassee, 
Florida; that Ronnie Cottrell had his assistant steal 
game films for him from the University of Alabama 
athletic offices; that Ronnie Cottrell had to go and 
speak with Commissioner Roy Kramer for disciplinary 
reasons; and that Ronnie Cottrell had abandoned his 
ex-wife and children in Tallahassee, Florida and that 
someone had to purchase a trailer for them to live in."

The brief continued: "Culpepper went so far as to state 
that the above-mentioned overt accounts of defamation 
along with anything he reported to Fulmer regarding Ivy 
Williams and Mike DuBose were based on 'rumors.' " In 
his deposition, recruiting analyst Forrest Davis said 
that Culpepper claimed that Cottrell had embezzled funds 
from Shaun Alexander's golf tournament, had a gambling 
problem that was financed by former Alabama booster 
Logan Young and took videotapes of recruits when they 
were let go."

Former recruiting analyst Bruce Parris made similar 
statements in his deposition.

Davis also stated that Culpepper claimed Williams was 
paying players.

Rodney Orr of TiderInsider.com said that Culpepper told 
him in a taped conversation that the plaintiffs "ruined 
me. You slap me; I slap you back harder. That's how I 
work."

Charles Branch, who worked with Culpepper, said he told 
him, "I'll do whatever it takes to see Ronnie Cottrell 
and Logan Young go under."

Court records filed Tuesday indicated that the 
plaintiffs believe that Culpepper - who could not be 
reached for comment - had come to an agreement with the 
NCAA for the organization to pay his legal fees.

Documents indicated that Culpepper said during his 
deposition that he owed the law firm of Starnes and 
Atkinson more than $80,000 and was paying approximately 
$200 a month.

When asked during his deposition given at NCAA 
headquarters in Indianapolis on Feb. 17, 2005 if the 
NCAA had paid any of Culpepper's legal fees, NCAA 
president Myles Brand said "not to his knowledge."

A month later, Brand sent a correction to his 
deposition.

Court records also indicated that Culpepper and NCAA 
investigator Richard Johanningmeier frequently contacted 
each other during the Alabama investigation.

"Culpepper was so involved with the NCAA investigation 
that he would tell Johanningmeier who to interview and 
what questions to ask."

Culpepper allegedly knew intricate details of the 
ongoing investigation and what sanctions would be 
imposed on Alabama before the NCAA issued the 
infractions report.

Additionally, records indicated that from April to Sept. 
1998, Fulmer sent former SEC commissioner Roy Kramer at 
least six communications detailing numerous rumors about 
Young's involvement in the recruitment of Memphis-area 
athletes, including Albert Means. The SEC failed to 
notify Alabama of any concerns until after Means 
participated during the 2000 season.

Fulmer recommended that Kramer contact UT boosters Duke 
Clement and Chuck Cole to gather possible incriminating 
information. Clement testified against Young during his 
recent criminal trial in Memphis.

In February, Young was convicted on four counts of 
conspiracy, crossing state lines to commit racketeering 
and arranging bank withdrawals to cover up a crime for 
paying a high school football coach to influence Means' 
recruitment to Alabama. His sentencing is scheduled for 
this afternoon.

"This case reveals a complex and malicious scheme and 
conspiracy set in motion by certain individuals and 
institutions to cause substantial harm (including the 
possibility of the "death penalty") to the University of 
Alabama football program," the response states.

"In order to accomplish this conspiracy, the parties 
used the plaintiffs as whipping boys in order to attempt 
to bring charges against wealthy UA booster Logan Young, 
under the theory if they could get Young, and then could 
get to the 'big man' at UA, the falling dominoes would 
result in inflicting the most severe sanctions (the 
death penalty) against the UA football program."

Reach Christopher Walsh at 
[EMAIL PROTECTED] or at (205) 
722-1096.



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