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In addition to broader University failings, Pepper found specific failings within both the football program and Athletics Department leadership, including a failure to identify and respond to a pattern of sexual violence by a football player, to take action in response to reports of a sexual assault by multiple football players, and to take action in response to a report of dating violence.

Pepper’s review was detailed, thorough and rigorous.While keeping within the scope of the engagement, Pepper engaged in an open exploration of the issues with no limitation by the University.Pepper conducted document-based interviews to ensure accuracy, integrity and efficiency, and Pepper’s findings and recommendations are based on the law, related authority, facts and reasonable inferences from the facts.The mission of the San Benito CISD is to provide a premiere education for all students, through a positive and safe learning environment, so that its graduates are college, career, and workforce ready. The Baylor University Board of Regents released a 13-page overview of its findings based on Pepper Hamilton’s investigation of the university’s response to reported sexual assualts. In August 2015, Baylor University engaged Pepper Hamilton to conduct an independent and external review of Baylor University’s institutional response to Title IX and related compliance issues through the lens of specific cases.

Following an intensive investigation, Pepper provided the Board of Regents with a detailed and comprehensive presentation of its findings and recommendations.Pepper’s findings of fact, as set forth in greater detail in this statement, reflect a fundamental failure by Baylor to implement Title IX of the Education Amendments of 1972 (Title IX) and the Violence Against Women Reauthorization Act of 2013 (VAWA).Pepper found that Baylor’s efforts to implement Title IX were slow, ad hoc, and hindered by a lack of institutional support and engagement by senior leadership.Based on a high-level audit of all reports of sexual harassment or violence for three academic years from 2012-2013 through 2014-2015, Pepper found that the University’s student conduct processes were wholly inadequate to consistently provide a prompt and equitable response under Title IX, that Baylor failed to consistently support complainants through the provision of interim measures, and that in some cases, the University failed to take action to identify and eliminate a potential hostile environment, prevent its recurrence, or address its effects for individual complainants or the broader campus community.Pepper also found examples of actions by University administrators that directly discouraged complainants from reporting or participating in student conduct processes, or that contributed to or accommodated a hostile environment.In one instance, those actions constituted retaliation against a complainant for reporting sexual assault.