Adam Cahn

Austin, TX
(512) 378-0285
cahnman@hotmail.com

Attorney General Ken Paxton

Office of the Attorney General
Open Records Division
P.O. Box 12548
Austin, TX 78711
March 28, 2018

Dear General Paxton,

I am writing to file a complaint against the ​University of Houston​ for their failure to properly reply to ​15 separate
public information act requests​ since January 26, 2018.

On January 6, 2018 the University of Houston announced the hiring of assistant coaches Kendal Briles and Randy
Clements by their football program. Coaches Briles and Clements had previously worked in the Baylor University
Football program, where (at least) Coach Briles was a key figure in the ongoing sexual assault scandal. Specifically,
in a 2017 lawsuit​, Coach Briles was alleged to have told a recruit ​“Do you like white women?!? Because we have
a lot of them at Baylor and they love football players.”​ All of my public information act request have pertained
to the hiring of Coaches Briles and Clements, and Coach Briles’ conduct since his hire.

On January 26, 2018, in following up on a previous request from January 10, I requested specific communications
from five specific members of the University of Houston bureaucracy: Board of Regents Chairman Tilmann Fertitta,
President Renu Khator, Head Football Coach Major Applewhite, Assistant Football Coach Kendal Briles, and
Associate Athletic Director for Compliance, Academics, and Financial Aid ​Lauren DuBois​. I have never received
any​ ​response to these requests. The ten-day window closed on February 9, 2018.

On February 9, 2018, I requested specific follow up communications for the same five individuals. On March 20,
2018 I received a request for clarification but have yet to see any responsive information. The ten-day window
closed on February 26, 2018.

On March 10. 2018, I requested specific follow up communication for the same five individuals. I have never
received ​any​ response to these requests. The ten-day window closed on March 26, 2018.

I request the Office of the Attorney General take all appropriate action to compel the University of Houston to
release the requested information.

Sincerely,
Adam Cahn
Austin, TX
Adam Cahn
Fri 1/26/2018 9:58 PM
To:​publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All e-mails and text messages sent or received by Board of Regents chairman Tilman Fertitta
between January 1, 2018 and January 8, 2018.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before February, 12 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These records are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Fri 1/26/2018 9:59 PM

To:​publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All e-mails and text messages sent or received by Chancellor/President Renu Khator between
January 1, 2018 and January 8, 2018.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before February, 12 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Fri 1/26/2018 10:03 PM
To: ​publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All e-mails and text messages sent or received by Head Football Coach Major Applewhite
between January 1, 2018 and January 8, 2018.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before February, 12 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Fri 1/26/2018 10:11 PM
To: ​publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All e-mails and text messages sent or received by ​Associate Athletic Director for Compliance,
Academics, and Financial Aid ​Lauren DuBois​ between January 1, 2018 and January 8, 2018.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before February, 12 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Fri 1/26/2018 10:22 PM
To: ​publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All recruiting related text messages sent or received by Assistant Football Coach Kendal Briles
since January 6, 2018; please specifically prioritize any communications containing the phrase
"White Women."

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before February, 12 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Fri 2/9/2018 5:50 PM
To:​publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All correspondence sent or received by Board of Regents Chairman Tilman Fertitta related to
assistant football coach Kendal Briles between January 26, 2018 and the time of receipt of this
request.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before February, 23 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These records are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Fri 2/9/2018 5:51 PM
To: ​publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All correspondence sent or received by President Renu Khator related to assistant football coach
Kendal Briles between January 26, 2018 and the time of receipt of this request.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before February, 23 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Fri 2/9/2018 5:52 PM
To: ​publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All communication between Head Football Coach Major Applewhite and assistant football coach
Kendal Briles between January 26, 2018 and the time of receipt of this request.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before February, 23 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Fri 2/9/2018 5:53 PM
To: ​publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All recruiting related e-mails and text messages sent by assistant football coach Kendal Briles
between January 26, 2018 and the time of receipt of this request.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before February, 23 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Fri 2/9/2018 5:59 PM
To: ​publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All correspondence sent or received by ​Associate Athletic Director for Compliance,

Academics, and Financial Aid ​Lauren DuBois​ related to assistant football coach Kendal Briles
between January 26, 2018 and the time of the receipt of this request.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before February, 23 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Bentley, Eric <​edbentle@Central.UH.EDU​>

Tue 3/20/2018 6:08 PM

To: ​Adam Cahn (cahnman@hotmail.com)

Cc: ​Romo, Monica L (mlromo@Central.UH.EDU)

Dear Mr. Cahn,

This e-mail is in response to your Texas Public Information Act requests wherein you requested the
following information:

1.​ A
​ ll correspondence sent or received by Board of Regents Chairman Tilman Fertitta related to

assistant football coach Kendal Briles between February 8, 2018 and the time of receipt of this request.

2.​ A
​ ll correspondence sent or received by President Renu Khator related to assistant football coach

Kendal Briles between February 8, 2018 and the time of receipt of this request.

3.​ A
​ ll communication between Head Football Coach Major Applewhite and assistant football coach

Kendal Briles between February 8, 2018 and the time of receipt of this request.

4.​ A
​ ll recruiting related e-mails and text messages sent by assistant football coach Kendal Briles

between February 8, 2018 and the time of receipt of this request.

5.​ A
​ ll correspondence sent or received by Associate Athletic Director for Compliance, Academics, and

Financial Aid ​Lauren DuBois​ related to assistant football coach Kendal Briles between January 26, 2018
and the time of the receipt of this request.

In accordance with Texas Government Code § 552.222, the University seeks to discuss with you how
your request might be narrowed. The University would like to see if you would be willing to consolidate
and narrow the scope of your requests to exclude any identifying information of students and prospective
athletes. We would simply redact such information. We believe this information would be confidential by
the Family Educational Rights and Privacy Act (FERPA) as well as Sections 552.101 and 552.104 of the
Texas Government Code.

Please simply respond to this e-mail and let me know if you are willing to narrow the scope of your
request in the manner suggested. The University is required to inform you that if you fail to respond to
this e-mail seeking to narrow the scope of your request within 61 days, your request will be considered
withdrawn.

Should you have any questions, please do not hesitate to contact me.

Regards,
________________________________________________

Eric D. Bentley

Associate General Counsel

University of Houston System

4302 University Drive (Suite 311 E. Cullen Building)

Houston, Texas 77204-2028

Direct: 832-842-7082

Fax: 713-743-9179

E-mail: ebentley@uh.edu
Adam Cahn
Wed 3/21, 2:50 PM
To: Bentley, Eric (edbentle@Central.UH.EDU)

That's fine.

Adam
Adam Cahn
Sat 3/10, 11:18 PM
To: publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All correspondence sent or received by Board of Regents Chairman Tilman Fertitta related to
assistant football coach Kendal Briles between February 8, 2018 and the time of receipt of this
request.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before March, 27 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These records are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Sat 3/10, 11:20 PM
To: publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All correspondence sent or received by President Renu Khator related to assistant football coach
Kendal Briles between February 8, 2018 and the time of receipt of this request.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before March, 27 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn

Sat 3/10, 11:22 PM

To: publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All communication between Head Football Coach Major Applewhite and assistant football coach
Kendal Briles between February 8, 2018 and the time of receipt of this request.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before March, 27 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Sat 3/10, 11:24 PM
To: publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All recruiting related e-mails and text messages sent by assistant football coach Kendal Briles
between February 8, 2018 and the time of receipt of this request.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before March, 27 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX
Adam Cahn
Sat 3/10, 11:26 PM
To: publicinfo@uh.edu

To whom it may concern,

I am writing pursuant to the Texas Public Information Act, Texas Government Code Ch. 552, to
request that you send me a copy of the following information maintained by the University of
Houston:

All correspondence sent or received by ​Associate Athletic Director for Compliance,

Academics, and Financial Aid ​Lauren DuBois​ related to assistant football coach Kendal Briles
between January 26, 2018 and the time of the receipt of this request.

I would appreciate the requested materials at your earliest convenience, and anticipate your
response on or before March, 27 2018. Materials may be produced on a rolling basis as they
become available. Materials may be sent by e-mail to ​cahnman@hotmail.com​. These ​records​ are
not being sought for commercial purposes and I request you waive all fees. If the fee exceeds
$40.00, please send me a written estimate of costs in advance via fax or email.

Please feel free to contact me if you have any questions. I can be reached at
cahnman@hotmail.com​ or (512) 378-0285. Thank you for your assistance in this matter.

Sincerely,

Adam Cahn

Austin, TX