Friday, November 02, 2007

Major Release of Hearing Documents

Landis has provided and we have archived what is hoped to be a complete collection of machine readable exhibits and other filings from the hearing. If there are things that appear to be missing, ask and we'll try to do more digging. Some things that are not present don't exist in digital form, and we're in no position to demand they be scanned for our benefit.

We thank Landis and his team for carrying through on their pledge of openness in the process. It was work to collect these materials and make them available to the public.

As others look and find out what things are, please post comments that will help others navigate, thanks!

Some ones of interest, especially to M and Larry, who have been asking:

Various Documents

ExhibitlisttoUSADAResponseBrief - an index to exhibits, some of which aren't present in this collection.

USADAPRE-TRIALRESPONSEBRIEF... - another index to exhibits, some of which aren't present, some of which aren't present here

115-134 exhibit list. TBV post about Landis on DPF is ex 118.

RespondentWitnessList - summary of Landis witnesses and proffered testimony.

USADAWitnessDesignation - summary of USADA witnesses and proffered testimony.

ViolationofPanelsOrders - 9-May letter from HRO complaining about Landis violating Panel orders regarding an article by Hiltzik about Campbells pre-hearing dissent.

MotionToStrikeInLimine - Landis motion, including 16-0ct-2006 discovery request to USADA.

RespondentsSupplementalWitnessList - adds more witnesses not called.


preventadmission - USADA motion to prevent introduction of Landis' medical condition as a defense.

Base Exhibits

Exhibit A -- 4-May letter from HRO to Suh requesting additional discovery material from Landis.

4-Apr-2007 transcript of conference over B sample admissibility and representative exclusion.
Ex 50 27-Dec letter from USADA saying they will test other samples on Jan 8.
Ex 51 29-Dec letter from Suh saying additional testing is illegal.
Ex 52 2-Jan letter from Suh reiterating illegality, and calling it destruction of evidence.
Ex 53 3-Jan letter from USADA saying offices were closed, and asking who is counsel?
Ex 54 3-Jan letter from Suh threatening US Federal suit over testing.
Ex 55 4-Jan letter from USADA saying Federal court would have no jurisdiction, but offers delay.
Ex 56 4-Jan letter from USADA agrees to delay.
Ex 57 13 page position paper from USADA following 10-Jan conference, with 47 pages of exhibits.
Ex 75 30-Apr Dunn declaration about April testing.
Ex 76 30-Apr Catlin declaration about Paul Scott and behavior by reps during B testing.
Ex 77 30-Apr Aquilera declaration describing B sample testing and observation.
Ex 78 24-Apr call transcript excerpt about representative exclusion.
Ex 79 Copy of Westin v. Union arb decision, apparently supporting USADA's "did it to yourself" position.
Ex 80 Copy of Union v. Honeywell, where court declines to review arb decision.
Ex 81 Copy of City v. Union arb decision,
Ex 82 Copy of County v. Teamsters arb decision

Ex 84 - April testing of 825424 - LNDD 633 (Landis from 23-Jul) on the IsoPrime2. LNDD 705 is the Landis F3 IRMS, with 17 identified peaks. It doesn't look particularly clean.
Ex 85 - April testing of 825426 - LNDD 730 (Aguilera control)
Ex 86 - April testing of 825428 - LNDD 824 (Landis from 18-Jul)
Ex 87 - April testing of 825429 - LNDD 922 (Landis from 22-Jul)
Ex 88 - April testing of 993855 - LNDD 1015 (Landis from 13-Jul)
Ex 89 - April testing of 825423- LNDD 1193 (Aguilera control)
Ex 90 - April testing of 825425 - LNDD 1207 (Landis from 14-Jul)
Ex 92 - April testing of 993865 - LNDD 1398 (Landis from 3-Jul)
Ex 93 - April testing of 825427 - LNDD 1492, the ocean blue, (Aguilera control)

Ex 95 - 19-Mar-2007 HRO letter complaining Suh hasn't presented all defenses.
Ex 96 - CAS decision on FILA v Aanes.
Ex 97 - CAS decision on FILA v Leipold
Ex 98 - 1-0May-2007 from UCI/Gripper to Young about case statistics.
Ex 99 - ISL
Ex 100 - CAS decision, Cycling Australia v. French; McLaren chair.
Ex 101 - 22-Feb-2007 Landis hearing transcript, USADA 1562

Ex 106 - Landis Doping Control forms sample 3-Jul-2006 995462, USADA 1590; 11-Jul sample 994203; 13-Jul sample 994277; 14-Jul sample 994276; 18-Jul sample 994075; 22-Jul sample 994080; 23-Jul sample 994171
Ex 107 - "Table 3", plus scatter plots of various calibration results over 2006 and2007. Looks like a USADA pitch to show everything was all-right.

"Table 3" from Ex 107

Ex 108
- Blank doping control form.
Ex 109 - AAA award, USADA v. Tammy Thomas; Brunet on panel.

GDC Exhibits

The GDC exhibits DO contain relatively clear chromatograms of some of the reprocessing on 5-May-2007.

- appears to be screenshots of backups.
GDC00881 - ditto.
GDC00891 - ditto
GDC00901 - mostly ditto, but a reanalysis on 4/7/07 of a 23/7/06 mix cal acetate with CG and 2/1 trace, legible.
GDC00911 - Looks like continuation of 6-Jul-06 calibration runs, reprinted in Apr 07 as part of the reprocessing. Some are auto, some are zero subtracted, etc.

GDC 921-980 appear to be missing.

GDC00981 - more reprocessing.
GDC00991 - more reprocessing.
GDC01001 - more reprocessing, stability runs.
GDC01011 - more stability, linearity, and CIR values.
GDC01021 - more CIR values, one larger but badly scanned IRMS CG
GDC01031 - more CIR values
GDC01041 - more CIR values
GDC01051 - some 44/45 traces; 1056 starts log files.
GDC01061 - logfiles; 1075-1079 is a description of reprocessing.
GDC01080 - Lim's power reports from the tour, stage by stage.
GDC01091 - More power reports. S15 1091, S16 1092, S17 1093; 1098 Shackleton paper.
GDC01101 - Shackleton cont'd; 1107 WM-A overview paper
GDC01111 - WM-A paper con't
GDC01121 - WM-A paper con't, Hall/Barth/Kalin paper
GDC01131 - Hall con't; WM-A paper about split systems; 1140 Kazlauskas et. al paper start.
GDC01141 - Kazlauskas con't.
GDC01151 - Kazlauskas con't; Brenna paper on quantization errors, also explaining background issues.
GDC01161 - Brenna con't.

I think that's everything currently in the archive except the CV's of various people, which are obvious.

If anyone finds things with specific interest or import, please share the observations.



m said...


I'm making a vow to take a break from reading all the exhibits.

But in case I break that vow, the Landis Findings of Fact pdf doesn't load for me.

DBrower said...

Thanks, it's fixed. It was corrupted.


Larry said...


There are a number of technical problems with the stuff Floyd has provided:

1. One of the first documents listed in the raw downloads listing is some kind of closing powerpoint (CLOSING52307noonFINLAshownincourt.ppt). There's something wrong with this file - it's probably corrupt. The file has hundreds of slides, but the slides have titles and no content.

2. Most of the CVs and Exhibits 84-100 are copies of the identical file: a CAS decision in the case of Mark French (it's pretty easy to spot these documents on the raw index list, since they all have identical 2.0M sizes).

3. The "zip file of everything" is empty.

Those are the problems I've seen so far. I'd also noticed that the Landis Findings of Fact pdf was not working initially but it's working now.

BTW, this stuff is a treasure trove.

Larry said...

Did I remember to say "thank you"? I bet I didn't. THANK YOU! For this and everything else.

DBrower said...

Oops, my fault. Lesson: Never make corrections late at night. I'll fix this stuff later today as I'm travelling at the moment.


DBrower said...

I think all the corrupted files are fixed, but it's late, and I may have made more mistakes, so let me know if you have problems.