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September 11, 2014 SENT BY MAIL & Email TO: [email protected] Ms. Joan Lucas General Counsel, Office of General Counsel Mississippi State University PO Box 6171 513 Allen Hall Mississippi State, MS 39762 Re: Open Records Request Dear Ms. Lucas: I represent the Freedom From Religion Foundation (FFRF), a national nonprofit organization with members in Mississippi that advocates for the separation of state and church. We request certain records related to chaplain Matt Jolley and chaplain Bill Buckley and the Mississippi State (University) football program. If you do not maintain these records, please forward this letter to the appropriate records custodian and inform us that you have done so. For the purposes of this request, “Chaplain” refers to any of the chaplain’s predecessors, successors, assistants, co-chaplains, or anyone who fills the role of spiritual or religious counselor; “Football Program” means the University football team, which includes all coaches and football personnel, paid or unpaid, who regularly access the team’s facilities; “records,” “communications,” or similar terms are meant to include, but not be limited to emails. Pursuant to the Mississippi Public Records Act, MS Code § 25-61-1, I hereby request the following records, from 2010 to the present: 1. All Football Program, University, or Athletic Department policies concerning coach or clergy-led prayers for student athletes; this includes any policies regarding restrictions on coach or clergy-led prayers before athletic competitions, practices, or team functions; 2. All Football Program, University, or Athletic Department schedules, notices, memos, emails, or announcements related to religious services, prayer gatherings, bible studies, Fellowship of Christian Athletes meetings, or other religious activities in which the Chaplain was involved; 3. All communications, including but not limited to email, between Football Program staff and the Chaplain concerning the scheduling, planning, advertisement, or sponsoring of religious services, prayer gatherings, bible studies, bible distributions, or other religious activities for football players, staff, or their families;

Mississippi State FFRF Request

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Page 1: Mississippi State FFRF Request

September 11, 2014

SENT BY MAIL & Email TO: [email protected]  

Ms. Joan Lucas General Counsel, Office of General Counsel Mississippi State UniversityPO Box 6171 513 Allen Hall Mississippi State, MS 39762

Re: Open Records Request

Dear Ms. Lucas:

I represent the Freedom From Religion Foundation (FFRF), a national nonprofit organization with members in Mississippi that advocates for the separation of state and church. We request certain records related to chaplain Matt Jolley and chaplain Bill Buckley and the Mississippi State (University) football program. If you do not maintain these records, please forward this letter to the appropriate records custodian and inform us that you have done so.

For the purposes of this request, “Chaplain” refers to any of the chaplain’s predecessors, successors, assistants, co-chaplains, or anyone who fills the role of spiritual or religious counselor; “Football Program” means the University football team, which includes all coaches and football personnel, paid or unpaid, who regularly access the team’s facilities; “records,” “communications,” or similar terms are meant to include, but not be limited to emails.

Pursuant to the Mississippi Public Records Act, MS Code § 25-61-1, I hereby request the following records, from 2010 to the present:

1. All Football Program, University, or Athletic Department policies concerning coach orclergy-led prayers for student athletes; this includes any policies regarding restrictions oncoach or clergy-led prayers before athletic competitions, practices, or team functions;

2. All Football Program, University, or Athletic Department schedules, notices, memos,emails, or announcements related to religious services, prayer gatherings, bible studies,Fellowship of Christian Athletes meetings, or other religious activities in which theChaplain was involved;

3. All communications, including but not limited to email, between Football Program staffand the Chaplain concerning the scheduling, planning, advertisement, or sponsoring ofreligious services, prayer gatherings, bible studies, bible distributions, or other religiousactivities for football players, staff, or their families;

Page 2: Mississippi State FFRF Request

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4. All Football Program, University, or Athletic Department records related to the

Chaplain’s travel with the football team. This includes all travel plans, itineraries, and financial records, including any plane tickets, meals, or hotel stays arranged by the Football Program, University, or Athletic Department;

5. All Football Program, University, or Athletic Department records related to financial

payments or reimbursements made to the Chaplain;

6. All Football Program, University, or Athletic Department job postings, or job descriptions concerning Football Program chaplains, or any other position primarily revolving around the spiritual development of football players; and

7. Any other Football Program, University, or Athletic Department records related to the

Chaplain’s official or unofficial football team duties or activities. Please respond to this request within 14 days as required under Mississippi law. If more time is needed to gather information responsive to one or more of the items above, please indicate that in your response. If you choose to deny any part of this request, please provide a written explanation of the denial including any references to statutory exemptions or case law upon which you rely. If any of these records are available electronically, they may be e-mailed to [email protected]. FFRF is a 501(c)3 non-profit that works to ensure government bodies comply with the First Amendment. As a non-profit working for the public interest, we request any fees associated with this request be waived or, at the very least, discounted. Thank you for your time and attention to this matter. Please feel free to contact me with any questions, concerns, or clarifications at [email protected] or 608-256-8900. Sincerely,

Andrew Seidel Staff Attorney