Independent Investigation Report I. Executive …...2 of 58 Independent Investigation Report I....
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2 of 58 Independent Investigation Report I. Executive Summary This engagement was prompted when Tom Hill, a former Baylor University Athletic Department employee, gave certain testimony in a deposition taken in connection with a Title IX case filed by a group of women against Baylor University. See Jane Doe 1, et al. v. Baylor Univ., No. 6:16-cv-00173-RP, in the U.S. District Court for the Western District of Texas, Waco Division (hereinafter “Title IX litigation”). During his deposition, Mr. Hill stated that he heard of an incident that allegedly took place in the city of Querétaro, State of Querétaro, Mexico (hereinafter “Querétaro”) and involved two former members of the Baylor Board of Regents, Richard Willis and Ramiro Peña, and a former Baylor Athletics booster, Greg Klepper. Specifically, Mr. Hill testified that Mr. Klepper alleged Mr. Willis and Mr. Peña made racist, sexist, and anti-Semitic remarks during a business trip to Querétaro, Mexico in late July 2014. He also testified that Mr. Klepper alleged Mr. Willis and Mr. Peña were drunk during a dinner at the home of a local businessman in Querétaro and made some of the alleged remarks, causing them to be asked to leave the host’s home. These allegations quickly became public. Baylor asked Ashcroft Sutton Reyes to investigate to determine if these allegations were true. Our key findings and conclusions can be summarized as follows: • Messrs. Willis and Peña deny they made racist, sexist, and anti-Semitic remarks during the trip to Querétaro, Mexico. They admit drinking alcohol but deny being drunk. • Mr. Klepper claimed to make a video recording of some of the alleged remarks, but also admitted that he destroyed the SD Card from the recording device before anyone could examine the video. • Neither Mr. Klepper nor his business associate Alejandro “Alex” Montaño Urdaneta would identify the local Mexican businessman who hosted the group for dinner during the trip to Querétaro, Mexico, despite their allegations that some of the offensive remarks were made at the dinner party. • Mr. Klepper and Mr. Urdaneta (who were both on the trip to Querétaro, Mexico) refused to be interviewed as a part of our investigation. • Mr. Klepper’s account of the incidents given through his interview, deposition, and written affidavit is inconsistent and we do not find it credible. • Mr. Urdaneta’s account of the incidents given through his interview and written affidavit is inconsistent and we do not find it credible. • Mr. Klepper may be biased against certain administrators at Baylor, or Baylor generally, given prior litigation his company lost against Baylor University and his support for former Baylor football coach Art Briles. • We conclude that Messrs. Willis and Peña did not make the alleged statements and were not drunk during the trip to Querétaro, Mexico.
