Editor's Note: This story includes mention of sexual violence or assault.
IU received a notice of allegations of inappropriate behavior involving former men’s basketball team physician Dr. Bradford Bomba Sr. as early as June 2024, according to emails obtained by the Indiana Daily Student.
The email – which was from Jennifer Geize, who identified as a paralegal with Wagstaff Law Firm – was sent to IU on June 21, 2024. The message was sent to IU Athletics director Scott Dolson, the IU Board of Trustees, Vice President and General Counsel Anthony Prather and President Pamela Whitten with the subject heading “John Doe v IU.” Within the message it read, “Attached please find a letter regarding the claim John Doe v IU.”
The letter was not connected to the initial complaint that prompted the university to announce it would hire an independent law firm to investigate allegations of sexual misconduct against Bomba in a September 2024 press release.
The university’s release said “The review will include witness interviews, a review of available documentation and engagement with medical experts.”
However, the June 2024 letter is not mentioned at all in Jones Day’s 874-page investigation final report. Instead it implies the university found out about allegations against Bomba in August, not June when university officials were sent the letter.
IU spokesperson Mark Bode referred the IDS to the September 2024 release when reached for comment.
The document within the message said the firm — in conjunction with Stinar Gould Grieco & Hensley — was representing a former IU student athlete claiming allegations of sexual abuse brought on from Bomba during the doctor’s time as team physician.
“Due to the highly sensitive nature of the claims alleged, we are writing in the hopes of initiating a dialogue with the University regarding the facts and circumstances that give rise to the claims raised by our client,” the letter said. “We understand and believe that the events and circumstances at issue may have occurred over a lengthy period of time, including in the early 1990s.”
The letter proposed entering “into a Non Disclosure and Confidentiality Agreement,” in efforts to protect confidentiality of all parties.
“With these proper assurances in place, we will be happy to provide additional details regarding the allegations of our client,” the letter said.
The letter was sent on behalf of someone under the pseudonym John Doe and was signed by Soomer D. Luther of Wagstaff Law Firm and Parker Stinar of Stinar Gould Grieco & Hensley. Wagstaff is a firm headquartered in Denver, while Stinar Gould Grieco & Hensley is located in Chicago.
The IDS reached out to both Wagstaff and Stinar Gould Grieco & Hensley; neither firm responded to multiple requests for comment.
At 8:06 a.m. June 22, 2024, Dolson’s athletics director account forwarded the email to Deputy Director of Athletics Stephen Harper as well as Dolson’s personal IU account. In the same email thread, a message from Dolson that said “fyi...” was sent to Prather, Chief Operating Officer and acting Vice President for Human Resources Todd Richardson, Chief of Staff to the President and Vice President for Strategic Operations Brenda Stopher and to the email address “psw@iu.edu.”
In the September 2024 press release, IU announced it had hired Jones Day, an investigative law firm, to investigate allegations of sexual misconduct from Bomba Sr. to a former men’s basketball player, who was later confirmed to be Haris Mujezinovic.
Since then, former players Mujezinovic, Charlie Miller, John Flowers, Larry Richardson Jr. and Butch Carter have all been named as plaintiffs in an amended lawsuit against the IU trustees to include former men’s basketball athletic trainer Tim Garl as a defendant. The players, who are plaintiffs in the same suit, are all represented by Kathleen Delaney of Delaney & Delaney LLC.
On the case with Delaney, Matthew Gutwein is another partner at the firm. He said “none of the plaintiffs” the firm represents are “the John Doe of the June 21, 2024 letter.”
Instead, Delaney sent their notice — in reference to the IU trustees — to Prather on Aug. 28, 2024. It was sent on behalf of allegations brought on by Mujezinovic, who was the only former player who had knowingly come forward at the time.
In the notice, there is also mention of the parties possibly going into a confidentiality agreement.
“I write to explore whether IU has any interest in an amicable and confidential resolution to this extremely troubling matter,” the letter, signed by Delaney, said.
The letter said Mujezinovic “was systematically and repeatedly sexually abused, harassed, and assaulted” by Bomba Sr. It also says “at minimum” IU men’s basketball former head coach Bob Knight and former trainer Tim Garl knew of Bomba’s actions before and after Mujezinovic attended the university.
The letter claimed Garl, Knight and the university all neglected to take action to address the “routine sexual assaults” and said they promoted a “‘keep your mouth shut’ culture.”
“There was no articulable, medically necessary reason for Dr. Bomba to routinely perform anal rectal or prostate examinations on healthy, highly active college athletes,” the letter said.
While stating that they believe a large number of other former student athletes were similarly affected, it also said that Mujezinovic was willing “to discuss an amicable resolution of his individual claims to minimize the negative impact on himself, IU, and the IU basketball program and Coach Knight's legacies, particularly given the severity and nature of his claims.”
The terms within the letter for an amicable resolution stated that the university would have to remove Bomba Sr. from the IU Athletics Hall of Fame, force Garl to retire and not be allowed any possible election into the IU Athletics Hall of Fame and lastly, to pay Mujezinovic and his attorneys $5 million.
The letter, signed by Delaney, requested a response from the university by Sept. 11, 2024; if no response was given, it said it would move forward pushing the matter into court. The September deadline was the same day IU released its initial press release.
On page 26 of Jones Day’s report, a footnote includes information about a former player who retained legal counsel and contacted IU with a letter “about two months before” Delaney sent the Aug. 28 notice to the university.
The footnote goes on to say that the earlier letter was sent by the same lawyer, Delaney, who sent the August notice. However, the June 21 letter obtained by the IDS doesn’t mention Delaney or the firm. Gutwein also confirmed to the IDS in an email April 29, that they were “not familiar with" the June 21 letter.
Separate from the five plaintiffs represented by Delaney, another former student athlete came forward in October 2024.
Michelle Simpson Tuegel of Simpson Tuegel Law Firm was retained as the attorney in potentially representing the former student athlete in a civil claim with allegations of sexual abuse from Bomba. The former player – who went by the pseudonym John Doe – alleged the abuse brought on from Bomba was part of a larger structural issue.
As of Thursday, the IDS could not verify a filed case with Simpson Tuegel as the attorney and John Doe as a plaintiff. However, the John Doe in this instance is not connected to the John Doe in the June 2024 letter to IU.
The university released the final report from Jones Day’s independent review Thursday.
The report said that the firm didn’t uncover evidence to suggest that Bomba “obtained sexual gratification” or “sexual connotation” in completing digital rectal examinations throughout evaluations the physician conducted with the student athletes. It said the evidence found by the firm didn’t conclude that Bomba “acted in bad faith or with an improper purpose when performing” digital rectal examinations and throughout the physical examinations.
The IDS reached out to Louis Gabel of Jones Day who said the firm “cannot and will not comment on their investigation.”
In response to the report, Simpson Tuegel released a statement.
“This report released by Indiana University corroborates what our clients experienced as student athletes: that Indiana University Basketball Team doctor Brad Bomba Sr. invasively penetrated them and countless other teenage athletes over a span of decades and that university administrators- some of whom remained on staff until recently - knew about the abuse and did nothing to stop it.
The report’s conclusions do not deny or refute Bomba’s actions. Instead, they attempt to zero in on why he initiated these invasive and unnecessary penetrative exams, specifically questioning whether it was for his sexual gratification. That question should be examined and decided on by an Indiana Jury – not by university administrators and their handpicked law firm.
This report only further demonstrates the need to give these sexual abuse survivors their day in court, so they have an opportunity share their experiences, explain the impact it had on their lives, and seek some measure of justice.”
Jones Day's report doesn’t mention Simpson Tuegel or Doe.
CLARIFICATION: This article has been updated to include relevant information about a footnote in Jones Day’s final report.
Editor's note: This article was updated to clarify the position of Scott Dolson
