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The USADA letter in full
- Thread starter thehog
- Start date
- Dec 13, 2010
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and the USADA official statement...
http://www.usada.org/media/statement6132012
“In response to numerous inquiries regarding the public statements made by Mr. Lance Armstrong, we can confirm that written notice of allegations of anti-doping rule violations was sent yesterday to him and to five (5) additional individuals all formerly associated with the United States Postal Service (USPS) professional cycling team. These individuals include three (3) team doctors and two (2) team officials. This formal notice letter is the first step in the multi-step legal process for alleged sport anti-doping rule violations.*
USADA only initiates matters supported by the evidence. We do not choose whether or not we do our job based on outside pressures, intimidation or for any reason other than the evidence. Our duty on behalf of clean athletes and those that value the integrity of sport is to fairly and thoroughly evaluate all the evidence available and when there is credible evidence of doping, take action under the established rules.
As in every USADA case, all named individuals are presumed innocent of the allegations unless and until proven otherwise through the established legal process. If a hearing is ultimately held then it is an independent panel of arbitrators, not USADA that determines whether or not these individuals have committed anti-doping rule violations as alleged.
At this time USADA will not comment on the evidence or have further comment unless or until it is appropriate.”
http://www.usada.org/media/statement6132012
“In response to numerous inquiries regarding the public statements made by Mr. Lance Armstrong, we can confirm that written notice of allegations of anti-doping rule violations was sent yesterday to him and to five (5) additional individuals all formerly associated with the United States Postal Service (USPS) professional cycling team. These individuals include three (3) team doctors and two (2) team officials. This formal notice letter is the first step in the multi-step legal process for alleged sport anti-doping rule violations.*
USADA only initiates matters supported by the evidence. We do not choose whether or not we do our job based on outside pressures, intimidation or for any reason other than the evidence. Our duty on behalf of clean athletes and those that value the integrity of sport is to fairly and thoroughly evaluate all the evidence available and when there is credible evidence of doping, take action under the established rules.
As in every USADA case, all named individuals are presumed innocent of the allegations unless and until proven otherwise through the established legal process. If a hearing is ultimately held then it is an independent panel of arbitrators, not USADA that determines whether or not these individuals have committed anti-doping rule violations as alleged.
At this time USADA will not comment on the evidence or have further comment unless or until it is appropriate.”
- Aug 9, 2010
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Polish said:15 pages of SSDD. What a Quasi Waste of Taxpayer Money
I'm a taxpayer and I'm proud of anything my government can do to flush out criminals.
Go for it.
- Jul 19, 2010
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Wow. Just wow. Lance is finally charged. All these years of speculations and accusations and finger-pointing, finally a formal charge by authorities. This is an important day in Cycling.
- Jul 27, 2010
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This letter confirms what I suspected (see my earlier post in the USADA thread). Most of the evidence is testimony. The Saugy admission and the blood data from 2009-2010 each warrant only a sentence or so each, at the end. I tend to think those blood data are not very strong or they would have been provided in greater detail.
The witness testimony. Multiple riders will testify that LA:
1) injected and distributed EPO 1998-2005
2) transfused 2000-2005 and had transfusion equipment at his residence
3) used and administered to others testosterone/olive oil mixture (no dates given)
4) used cortisone without medical supervision (no dates given)
5) underwent saline/plasma transfusions (no dates given)
Also witnesses will testify LA used EPO, testosterone and HGH up to 1996.
The charges against LA thus include:
Use
Possession
Trafficking
Administration to others
Assisting rule breaking
Aggravating circumstances
Also of note: the letter begins by saying every rider who was notified except LA agreed to come before USADA and speak truthfully about their involvement in doping.
And this:
I wonder if this leaves open the door for criminal charges, after all.
The witness testimony. Multiple riders will testify that LA:
1) injected and distributed EPO 1998-2005
2) transfused 2000-2005 and had transfusion equipment at his residence
3) used and administered to others testosterone/olive oil mixture (no dates given)
4) used cortisone without medical supervision (no dates given)
5) underwent saline/plasma transfusions (no dates given)
Also witnesses will testify LA used EPO, testosterone and HGH up to 1996.
The charges against LA thus include:
Use
Possession
Trafficking
Administration to others
Assisting rule breaking
Aggravating circumstances
Also of note: the letter begins by saying every rider who was notified except LA agreed to come before USADA and speak truthfully about their involvement in doping.
And this:
I wonder if this leaves open the door for criminal charges, after all.
- Jul 23, 2009
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Nice to see the US agency taking action. Wonder if the information revealed in the hearings will create spin-off investigations by other national agencies? Here's looking at you, Spain.
- Apr 3, 2009
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thehog said:
Anyone able to parse out the text of that? I can't select any of the text. Anyone make a simple text version?
- Dec 13, 2010
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I've tried three different free OCR sites... they seem to process only the first page of the PDF.red_flanders said:
aaahh... finally time to open that Dom Perignon 1999!
I knew it all the time, it was obvious to everybody with a brain. But then again, will the finally get him this time or can he buy himself out again?
Life would have been so easier for #LieStrong had he given little Floyd a job or just told the truth back in 2005 after l'Equipe's 1999 EPO sample article. But he will never ever confess. He prefers to lie and die, than telling the truth.
I knew it all the time, it was obvious to everybody with a brain. But then again, will the finally get him this time or can he buy himself out again?
Life would have been so easier for #LieStrong had he given little Floyd a job or just told the truth back in 2005 after l'Equipe's 1999 EPO sample article. But he will never ever confess. He prefers to lie and die, than telling the truth.
- Mar 10, 2009
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http://online.wsj.com/public/resources/documents/armstrongcharging0613.pdf
------------
Be mindful of errors, etc caused by the image to text conversion process.
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H USA DAT
T
N
Preserving the integrity of competition. inspiring true span‘. Protecting the righs of athietes.
VIA ELECTRONIC MAIL and
VIA OVERNIGHT DELIVERY [where full address is indicated;
June 1 2, 20 12
Mr. Johan Bruyneel
Team Manager
RadioShack Nissan Trek Cycling Team
1 rue Petemelchen
L-23 70 Howald
Luxembourg
and to: brumee]ga),radioshacknissantrck.corn and johanbruy.11eelga3,1'ol1anbruxnccl.com
Dr. Pedro Celaya
Team Doctor
RadioShack Nissan Trek Cycling Team
1 rue Petemelchen
L-2370 Howald
Luxembourg
and to: celayamiradioshacknissantrek.com
Dr. Luis Garcia del Moral
Instituto de Medicina del Deporte
Complejo Deportivo Cultural Petxina
Paseo de la Petxina 42
46008 Valencia
SPAIN
and to: luisg.1noral(cD:imedep.co1n
Dr. Michele Ferrari
Via Pomposa, 286
Ferrara
ITALY 44100
Mr. Pepe Marti
c/o UNION CYCLISTE INTERNATIONALE
Ch. de la Mélée 12
1860 Aigle
Switzerland
United States Anti-Doping Agency
5555 Tech Center Drive, Suite 200, Colorado Springs, CO 80919-9918 - Tei: 719.785.2000 I Fax: 719.785.2001
usada@usada.org - http://www.usada.org
--------
June 12, 2012
Page 2
Mr. Lance Armstrong
c/o Robert D. Luskin
Patton Boggs, LLP
2500 M Street, NW
Washington, D.C. 20037-1350
U.S.A.
and to: rl.uskin(a),pattonboggs.com
Re: Anti-Doping Rules Violations
Dear Mr. Bruyneel, Dr. Celaya, Dr. del Moral, Dr. Ferrari, Mr. Marti, and Mr. Armstrong:
This letter is to notify each of you (collectively referred to as the “Respondents”) that the
United States Anti-Doping Agency (“USADA”) is hereby opening a formal action against
each of you based on evidence that, as described below, you engaged in anti—doping rule
violations under the Union Cycliste International (“UCI”) Anti-Doping Rules from 1998 to
present (“UCI ADR”), World Anti-Doping Code from inception to present (the “Code”)
and USADA Protocol for Olympic and Paralympic Movement Testing from inception to
present (the “USADA Protocol”) (collectively, the “Applicable Rules”).]
This notice letter describes a portion of the evidence gathered by USADA in its
investigation of potential doping on the United States Postal Service (USPS) (1996 —
2004), Discovery Channel (2005-2007), Astana (2009) and Radjoshack (2010) cycling
teams. The witnesses to the conduct described in this letter include more than ten (10)
cyclists as well as cycling team employees.
An important aspect of USADA’s investigation has been face to face meetings between
USADA representatives and riders on the above referenced cycling teams. USADA
sought to give the riders an opportunity to be a part of the solution in moving cycling
forward by being truthfiil and honest regarding their past experiences with doping in
cycling.
With the exception of Mr. Armstrong, every other U.S. rider contacted by USADA
regarding doping in cycling agreed to meet with USADA and to truthfiilly and fully
describe their involvement in doping and all doping by others of which they were aware.
Mr. Armstrong was likewise contacted through his legal counsel and given the opportunity
to meet with USADA to fully and truthfiilly disclose all knowledge of anti—doping rule
1 Copies of the Applicable Rules are provided as Attachments A (versions of UCI ADR), B
(versions of the World Anti-Doping Code), and C (the current version of the USADA
Protocol).
----
June 12, 2012
Page 3
violations committed in the sport of cycling. However, Mr. Armstrong declined USADA’s
offer.
Information set forth herein also comes from a number of other eyewitnesses to the
conduct described. In every instance the conduct described in this letter has only been
relied upon by USADA and described in this letter if the witness has confirmed to USADA
that the information is based on his or her first hand knowledge.
Prohibited Substances and Methods
The evidence in the possession of USADA and relevant to violations of the Applicable
Rules, by the Respondents reflects a pervasive pattern of doping involving the following
prohibited substances and methods:
1. Erythropoietin (EPO), also known as “E,” “Po,” “Edgar” or “Edgar Allen
Poe,” among other names. EPO is used by athletes to increase the number
of red blood cells in their circulatory system which are available to carry
oxygen. EPO use is prohibited under the Applicable Rules. Even after the
EPO urine test was developed and implemented in sport in late 2000 EPO
was difficult to detect and the Respondents implemented a number of means
to avoid detection of EPO use, including: micro-dosing (i.e., using smaller
amounts of EPO to reduce the clearance time of the drug), intravenous
injections (i.e., injecting the drug directly into the vein rather than
subcutaneously to reduce clearance time), saline, plasma or glycerol
infusions (described below) and various efforts to avoid testing by drug
testers at times that EPO might still be detectable in the riders’ urine.
Multiple riders who competed on the USPS and Discovery Channel teams
from 1998 through 2007 have reported to USADA that Team Director
Johan Bruyneel, Team Trainer Jose Pepe Marti and co-conspirator, Dr.
Michele Ferrari, a consultant to the USPS and Discovery Channel teams
and their riders, developed training plans dependent upon EPO use and
instructed riders to use the drug. USADA has received eyewitness
statements that EPO injections were administered by Dr. Luis Garcia del
Moral, Dr. Pedro Celaya and Dr. Ferrari. Multiple riders with first hand
knowledge will testify that between 1998 and 2005 Armstrong personally
used EPO and on multiple occasions distributed EPO to other riders.
2. Blood transfusions (a/k/a “blood doping”). Blood transfusions generally
involve the extraction of an athlete’s own blood pre-competition and re-
infusion of that blood shortly before or during competition (e.g., in the
evening or on a rest day in a multi-stage race) to increase the athlete’s
oxygen carrying red blood cells. By increasing the number of circulating
red blood cells transfiisions increase the oxygen carrying capacity of the
blood and enhance endurance and recovery. No effective anti-doping test
has yet been implemented to detect autologous transfusions (i.e.,
-----
June 1 2, 2012
Page 4
transfusions of an athlete’s own blood). Blood transfusions, however, carry
substantial health risks and due to the need to transport the blood in
appropriate conditions generally require support. Blood transfiisions
became more important to the conspiracy described herein after the urine
EPO test was introduced in 2000. Multiple riders who competed on the
USPS and Discovery Channel teams from 1998 through 2007 have reported
to USADA that Team Director Johan Bruyneel, Team Trainer Jose Pepe
Marti and co-conspirator, Dr. Michele Ferrari, a consultant to the USPS and
Discovery Channel teams and their members, developed training plans
dependent upon blood transfusions. Blood transfusions were facilitated by
Johan Bruyneel, Pepe Marti, Dr. del Moral, Dr. Celaya, and Dr. Ferrari.
Multiple riders will testify that during the period from 2000 — 2005
Armstrong used blood transfiisions, was observed having blood re-infused,
including during the Tour de France, and had blood doping equipment at his
residence.
3. Testosterone. Also known on the USPS and Discovery Charmel cycling
teams as “oil.” Testosterone is an anabolic agent and can increase muscle
mass and strength. In smaller doses anabolic agents such as testosterone
can promote muscle recovery from strenuous exercise and increase
endurance. Andriol consists of testosterone undecanoate a steroid which
can be mixed with oil and taken orally. Taken in this way the drug can be
absorbed into the lymphatic system without being transported to the liver,
making the drug more effective and reducing the prospect of liver damage.
Multiple riders who competed on the USPS and Discovery Channel teams
from 1998 through 2007 have reported that Dr. Ferrari developed a method
of mixing testosterone (i.e., andriol) with olive oil for oral administration
and that this testosterone—olive oil mixture was frequently administered to
team members. Riders called this testosterone-olive oil mixture, the “oil.”
Numerous USPS and Discovery Channel riders have also reported the
frequent use of testosterone patches by team members and that oral
testosterone (pills or oil), testosterone injections or testosterone patches
were provided by Johan Bruyneel, Pepe Marti and Drs. del Moral, Celaya
and Ferrari. USADA has eyewitness statements from multiple sources that
Lance Armstrong used testosterone and administered the testosterone-olive
oil mixture to himself and other riders.
4. Human Growth Hormone (hGH). Human growth hormone is improperly
used in sport to increase strength and lean muscle mass, to assist in weight
loss and to promote recovery. Multiple riders who competed on the USPS
and Discovery Charmel teams from 1998 through 2007 have reported to
USADA that team director Johan Bruyneel, team trainer Jose Pepe Marti
and team doctors Luis del Moral and Pedro Celaya provided human growth
hormone to team members.
------------
Be mindful of errors, etc caused by the image to text conversion process.
------------
H USA DAT
T
N
Preserving the integrity of competition. inspiring true span‘. Protecting the righs of athietes.
VIA ELECTRONIC MAIL and
VIA OVERNIGHT DELIVERY [where full address is indicated;
June 1 2, 20 12
Mr. Johan Bruyneel
Team Manager
RadioShack Nissan Trek Cycling Team
1 rue Petemelchen
L-23 70 Howald
Luxembourg
and to: brumee]ga),radioshacknissantrck.corn and johanbruy.11eelga3,1'ol1anbruxnccl.com
Dr. Pedro Celaya
Team Doctor
RadioShack Nissan Trek Cycling Team
1 rue Petemelchen
L-2370 Howald
Luxembourg
and to: celayamiradioshacknissantrek.com
Dr. Luis Garcia del Moral
Instituto de Medicina del Deporte
Complejo Deportivo Cultural Petxina
Paseo de la Petxina 42
46008 Valencia
SPAIN
and to: luisg.1noral(cD:imedep.co1n
Dr. Michele Ferrari
Via Pomposa, 286
Ferrara
ITALY 44100
Mr. Pepe Marti
c/o UNION CYCLISTE INTERNATIONALE
Ch. de la Mélée 12
1860 Aigle
Switzerland
United States Anti-Doping Agency
5555 Tech Center Drive, Suite 200, Colorado Springs, CO 80919-9918 - Tei: 719.785.2000 I Fax: 719.785.2001
usada@usada.org - http://www.usada.org
--------
June 12, 2012
Page 2
Mr. Lance Armstrong
c/o Robert D. Luskin
Patton Boggs, LLP
2500 M Street, NW
Washington, D.C. 20037-1350
U.S.A.
and to: rl.uskin(a),pattonboggs.com
Re: Anti-Doping Rules Violations
Dear Mr. Bruyneel, Dr. Celaya, Dr. del Moral, Dr. Ferrari, Mr. Marti, and Mr. Armstrong:
This letter is to notify each of you (collectively referred to as the “Respondents”) that the
United States Anti-Doping Agency (“USADA”) is hereby opening a formal action against
each of you based on evidence that, as described below, you engaged in anti—doping rule
violations under the Union Cycliste International (“UCI”) Anti-Doping Rules from 1998 to
present (“UCI ADR”), World Anti-Doping Code from inception to present (the “Code”)
and USADA Protocol for Olympic and Paralympic Movement Testing from inception to
present (the “USADA Protocol”) (collectively, the “Applicable Rules”).]
This notice letter describes a portion of the evidence gathered by USADA in its
investigation of potential doping on the United States Postal Service (USPS) (1996 —
2004), Discovery Channel (2005-2007), Astana (2009) and Radjoshack (2010) cycling
teams. The witnesses to the conduct described in this letter include more than ten (10)
cyclists as well as cycling team employees.
An important aspect of USADA’s investigation has been face to face meetings between
USADA representatives and riders on the above referenced cycling teams. USADA
sought to give the riders an opportunity to be a part of the solution in moving cycling
forward by being truthfiil and honest regarding their past experiences with doping in
cycling.
With the exception of Mr. Armstrong, every other U.S. rider contacted by USADA
regarding doping in cycling agreed to meet with USADA and to truthfiilly and fully
describe their involvement in doping and all doping by others of which they were aware.
Mr. Armstrong was likewise contacted through his legal counsel and given the opportunity
to meet with USADA to fully and truthfiilly disclose all knowledge of anti—doping rule
1 Copies of the Applicable Rules are provided as Attachments A (versions of UCI ADR), B
(versions of the World Anti-Doping Code), and C (the current version of the USADA
Protocol).
----
June 12, 2012
Page 3
violations committed in the sport of cycling. However, Mr. Armstrong declined USADA’s
offer.
Information set forth herein also comes from a number of other eyewitnesses to the
conduct described. In every instance the conduct described in this letter has only been
relied upon by USADA and described in this letter if the witness has confirmed to USADA
that the information is based on his or her first hand knowledge.
Prohibited Substances and Methods
The evidence in the possession of USADA and relevant to violations of the Applicable
Rules, by the Respondents reflects a pervasive pattern of doping involving the following
prohibited substances and methods:
1. Erythropoietin (EPO), also known as “E,” “Po,” “Edgar” or “Edgar Allen
Poe,” among other names. EPO is used by athletes to increase the number
of red blood cells in their circulatory system which are available to carry
oxygen. EPO use is prohibited under the Applicable Rules. Even after the
EPO urine test was developed and implemented in sport in late 2000 EPO
was difficult to detect and the Respondents implemented a number of means
to avoid detection of EPO use, including: micro-dosing (i.e., using smaller
amounts of EPO to reduce the clearance time of the drug), intravenous
injections (i.e., injecting the drug directly into the vein rather than
subcutaneously to reduce clearance time), saline, plasma or glycerol
infusions (described below) and various efforts to avoid testing by drug
testers at times that EPO might still be detectable in the riders’ urine.
Multiple riders who competed on the USPS and Discovery Channel teams
from 1998 through 2007 have reported to USADA that Team Director
Johan Bruyneel, Team Trainer Jose Pepe Marti and co-conspirator, Dr.
Michele Ferrari, a consultant to the USPS and Discovery Channel teams
and their riders, developed training plans dependent upon EPO use and
instructed riders to use the drug. USADA has received eyewitness
statements that EPO injections were administered by Dr. Luis Garcia del
Moral, Dr. Pedro Celaya and Dr. Ferrari. Multiple riders with first hand
knowledge will testify that between 1998 and 2005 Armstrong personally
used EPO and on multiple occasions distributed EPO to other riders.
2. Blood transfusions (a/k/a “blood doping”). Blood transfusions generally
involve the extraction of an athlete’s own blood pre-competition and re-
infusion of that blood shortly before or during competition (e.g., in the
evening or on a rest day in a multi-stage race) to increase the athlete’s
oxygen carrying red blood cells. By increasing the number of circulating
red blood cells transfiisions increase the oxygen carrying capacity of the
blood and enhance endurance and recovery. No effective anti-doping test
has yet been implemented to detect autologous transfusions (i.e.,
-----
June 1 2, 2012
Page 4
transfusions of an athlete’s own blood). Blood transfusions, however, carry
substantial health risks and due to the need to transport the blood in
appropriate conditions generally require support. Blood transfiisions
became more important to the conspiracy described herein after the urine
EPO test was introduced in 2000. Multiple riders who competed on the
USPS and Discovery Channel teams from 1998 through 2007 have reported
to USADA that Team Director Johan Bruyneel, Team Trainer Jose Pepe
Marti and co-conspirator, Dr. Michele Ferrari, a consultant to the USPS and
Discovery Channel teams and their members, developed training plans
dependent upon blood transfusions. Blood transfusions were facilitated by
Johan Bruyneel, Pepe Marti, Dr. del Moral, Dr. Celaya, and Dr. Ferrari.
Multiple riders will testify that during the period from 2000 — 2005
Armstrong used blood transfiisions, was observed having blood re-infused,
including during the Tour de France, and had blood doping equipment at his
residence.
3. Testosterone. Also known on the USPS and Discovery Charmel cycling
teams as “oil.” Testosterone is an anabolic agent and can increase muscle
mass and strength. In smaller doses anabolic agents such as testosterone
can promote muscle recovery from strenuous exercise and increase
endurance. Andriol consists of testosterone undecanoate a steroid which
can be mixed with oil and taken orally. Taken in this way the drug can be
absorbed into the lymphatic system without being transported to the liver,
making the drug more effective and reducing the prospect of liver damage.
Multiple riders who competed on the USPS and Discovery Channel teams
from 1998 through 2007 have reported that Dr. Ferrari developed a method
of mixing testosterone (i.e., andriol) with olive oil for oral administration
and that this testosterone—olive oil mixture was frequently administered to
team members. Riders called this testosterone-olive oil mixture, the “oil.”
Numerous USPS and Discovery Channel riders have also reported the
frequent use of testosterone patches by team members and that oral
testosterone (pills or oil), testosterone injections or testosterone patches
were provided by Johan Bruyneel, Pepe Marti and Drs. del Moral, Celaya
and Ferrari. USADA has eyewitness statements from multiple sources that
Lance Armstrong used testosterone and administered the testosterone-olive
oil mixture to himself and other riders.
4. Human Growth Hormone (hGH). Human growth hormone is improperly
used in sport to increase strength and lean muscle mass, to assist in weight
loss and to promote recovery. Multiple riders who competed on the USPS
and Discovery Charmel teams from 1998 through 2007 have reported to
USADA that team director Johan Bruyneel, team trainer Jose Pepe Marti
and team doctors Luis del Moral and Pedro Celaya provided human growth
hormone to team members.
- Mar 10, 2009
- 7,268
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- 0
http://online.wsj.com/public/resourc...arging0613.pdf
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Be mindful of errors, etc caused by the image to text conversion process.
------------
June 12, 2012
Page 5
5. Corticosteroids (e. g., cortisone). These drugs reduce inflammation, assist
in recovery and can provide a burst of energy and create a temporary feeling
of increased energy and wellbeing. Throughout the relevant time period
corticosteroids were improperly provided to cyclists by team doctors and
trainers to increase energy and enhance performance. Although
corticosteroids can be legally administered to treat a localized injury,
numerous USPS and Discovery Channel team members and employees
report that prescriptions for corticosteroids were regularly fabricated by Drs.
Celaya and del Moral to cover the improper administration of
corticosteroids to athletes without a legitimate medical need for the drugs
and using techniques of administration barred by UCI anti-doping rules and
that Johan Bruyneel and Pepe Marti encouraged the unauthorized use of
corticosteroids for performance enhancement and gave these drugs to riders.
USADA will also rely upon first hand testimony from witnesses who were
aware of Armstrong’s use of cortisone without medical authorization.
6. Saline and plasma infusions. Throughout much of the relevant period the
UCI employed a blood monitoring program and would not permit riders to
compete if the rider’s hematocrit (i.e., percentage of mature red blood cells)
exceeded 50%. To avoid exceeding the 50% hematocrit threshold and to
prevent detection of the rider’s EPO use and/or blood transfusions,
Respondents used the prohibited technique of saline, plasma or glycerol
infusions to mask their use of prohibited substances and/or methods.
Multiple riders who competed on the USPS and Discovery Channel teams
from 1998 through 2007 have reported to USADA that each rider’s
hematocrit level was always of primary interest to team director Johan
Bruyneel and that team trainer Jose Pepe Marti and team doctors del Moral
and Celaya administered saline and plasma infusions to team members.
USADA will also present testimony concerning infusions given to
numerous USPS riders, including Lance Armstrong.
Rule Violations
Numerous former riders and employees of the United States Postal Service, Discovery
Charmel, Astana, RadioShack, Phonak and/or ONCE cycling teams will testify that the
below individuals committed anti-doping rule violationsz as follows:
2 As identified in this letter,
Rules applicable to _lg and/or attempted use of prohibited substances or methods include:
UCI ADR 2 (1997-2000); UCI ADR 130 (2001-2004); UCI ADR 15.2 (2005-2008); UCI
ADR 21.2 (2009-present); and Code Article 2.2 (2003-present);
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June 12, 2012
Page 6
By Johan Bruyneel (Team Director):
(1) Possession of prohibited substances and/or methods including EPO, blood
transfusions and related equipment (such as needles, blood bags, storage
containers and other transfiision equipment and blood parameters measuring
devices), testosterone, hGH, corticosteroids, and masking agents, as described
in more detail above.
(2) Trafficking of EPO, blood transfilsions, testosterone, hGH, corticosteroids and
masking agents as described in more detail above.
(3) Administration and/or attempted administration of EPO, blood transfilsions,
testosterone, hGH, corticosteroids, and masking agents as described in more
detail above.
(4) Assisting, encouraging, aiding, abetting, covering up and other complicit);
involving one or more anti-doping rule violations and/or attempted anti—doping
rule violations.
(5) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Rules applicable to the possession of prohibited substances and/or methods include: UCI
ADR 135 (2001-2004); UCI ADR 15.6.1 (2005-2008); UCI ADR 21.6.1 (2009-present);
and Code Article 2.6.1 (2003-present);
Rules applicable to trafficking include: UCI ADR 135 (2001-04); UCI ADR 15.7 (2005-
2008); UCI ADR 21.7 (2009-present); and Code Article 2.7 (2003-present);
Rules applicable to administration and/or attempted administration include: UCI ADR
54, §1-2 (1997-2000); UCI ADR 133 (2001-2004); UCI ADR 15.8 (2005-2008); UCI
ADR 21.8 (2009-present); and Code Article 2.8 (2003-present);
Rules applicable to assisting, encouraging, aiding, abetting, covering up and other
complicity involving one or more anti—doping rule violations and/or attempted anti—doping
rule violations include: each of the above listed provisions and UCI ADR 54, §1-2 (1997-
2000); UCI ADR 133 (2001-2004); UCI ADR 15.8 (2005-2008); UCI ADR 21.8 (2009-
present); Code Article 2.8 (2003-present); and
Rules applicable to aggravating circumstances include: UCI ADR 305 (2009-present)
and Code Article 10.6 (2009-present).
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June 12, 2012
Page 7
Mr. Johan Bruyneel was a rider with the ONCE team in 1998. In 1999 Mr. Bruyneel
became Team Director with the USPS Cycling Team, a position he held through 2007
(although the team name was changed to the Discovery Channel Cycling Team for the
period 2005-2007). During 2008-2009 Mr. Bruyneel was Director of the Astana Cycling
Team. Since 2010 he has been the Team Director or Team Manager for the RadioShack
Team (now referred to as the RadioShack Nissan Trek Cycling Team).
With respect to Mr. Bruyneel, numerous riders will testify that Mr. Bruyneel gave to them
and/or encouraged them to use doping products and/or prohibited methods, including EPO,
blood transfusions, testosterone, hGH and cortisone during the period from 1999 through
2007. Riders and other witnesses will also testify that Bruyneel worked actively to conceal
rule violations by himself and others throughout the period from 1999 through the present.
By Dr. Pedro Celaya (Team Doctor):
(1) Possession of prohibited substances and/or methods including EPO, blood
transfusions and related equipment (such as needles, blood bags, storage
containers and other transfusion equipment and blood parameters measuring
devices), testosterone, hGH, corticosteroids, and masking agents, as described
in more detail above. _
(2) Trafficking of EPO, blood transfiisions, testosterone, hGH, corticosteroids and
masking agents as described in more detail above.
(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and masking agents as described in more
detail above.
(4) Assisting, encouraging, aiding, abetting, covering up and other complicity
involving one or more anti-doping rule violations and/or attempted anti—doping
rule Violations.
(5) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Dr. Pedro Celaya was a Team Doctor for the USPS Cycling Team fi'om 1997 through 1998
and from 2004 through 2007, by which time the team had come to be known as the
Discovery Charmel Cycling Team. During all or part of the period from 1999 through
2003 Dr. Celaya was a team doctor for the ONCE cycling team. Dr. Celaya is currently a
Team Doctor for the RadioShack Nissan Trek Cycling Team.
With respect to Dr. Celaya, numerous riders will testify that Dr. Celaya gave to them
and/or encouraged them to use doping products and/or prohibited methods, including EPO,
blood transfusions, testosterone, hGH, cortisone and infusions of saline, plasma and/or
glycerol during the period from 1998 through 2007. Riders and other witnesses will also
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June 12, 2012
Page 8
testify that Celaya worked actively to conceal rule violations by himself and others
throughout the period from 1998 through the present.
By Dr. Luis del Moral (Team Doctor):
(1) Possession of prohibited substances and/or methods including EPO, blood
transfusions and related equipment (such as needles, blood bags, storage
containers and other transfusion equipment and blood parameters measuring
devices), testosterone, hGH, corticosteroids, and masking agents, as described
in more detail above.
(2) Trafficking of EPO, blood transfiisions, testosterone, hGH, corticosteroids and
masking agents as described in more detail above.
(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and masking agents as described in more
detail above.
(4) Assisting, encouraflng, aiding, abetting, covering up and other complicigg
involving one or more anti-doping rule violations and/or attempted anti-doping
rule violations.
(5) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Dr. Luis Garcia del Moral was the Team Doctor for the USPS Cycling Team for the period
from 1999 through 2003. Subsequently, Dr. del Moral continued to serve as a physician
for many cyclists. He currently works as a sports doctor in Valencia, Spain.
With respect to Dr. del Moral, numerous riders will testify that Dr. del Moral gave to them,
encouraged them to use and/or assisted them in using doping products and/or prohibited
methods, including EPO, blood transfiisions, testosterone, hGH, cortisone and infiisions of
saline, plasma and/or glycerol during the period from 1999 through 2005. Riders and other
witnesses will also testify that del Moral worked actively to conceal rule violations by
himself and others throughout the period from 1999 through the present.
By Dr. Michele Ferrari (Consulting Doctor):
(1) Possession of prohibited substances and/or methods including EPO, blood
transfusions and related equipment (such as needles, blood bags, storage
containers and other transfiision equipment and blood parameters measuring
devices), and testosterone as described in more detail above.
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Page 5
5. Corticosteroids (e. g., cortisone). These drugs reduce inflammation, assist
in recovery and can provide a burst of energy and create a temporary feeling
of increased energy and wellbeing. Throughout the relevant time period
corticosteroids were improperly provided to cyclists by team doctors and
trainers to increase energy and enhance performance. Although
corticosteroids can be legally administered to treat a localized injury,
numerous USPS and Discovery Channel team members and employees
report that prescriptions for corticosteroids were regularly fabricated by Drs.
Celaya and del Moral to cover the improper administration of
corticosteroids to athletes without a legitimate medical need for the drugs
and using techniques of administration barred by UCI anti-doping rules and
that Johan Bruyneel and Pepe Marti encouraged the unauthorized use of
corticosteroids for performance enhancement and gave these drugs to riders.
USADA will also rely upon first hand testimony from witnesses who were
aware of Armstrong’s use of cortisone without medical authorization.
6. Saline and plasma infusions. Throughout much of the relevant period the
UCI employed a blood monitoring program and would not permit riders to
compete if the rider’s hematocrit (i.e., percentage of mature red blood cells)
exceeded 50%. To avoid exceeding the 50% hematocrit threshold and to
prevent detection of the rider’s EPO use and/or blood transfusions,
Respondents used the prohibited technique of saline, plasma or glycerol
infusions to mask their use of prohibited substances and/or methods.
Multiple riders who competed on the USPS and Discovery Channel teams
from 1998 through 2007 have reported to USADA that each rider’s
hematocrit level was always of primary interest to team director Johan
Bruyneel and that team trainer Jose Pepe Marti and team doctors del Moral
and Celaya administered saline and plasma infusions to team members.
USADA will also present testimony concerning infusions given to
numerous USPS riders, including Lance Armstrong.
Rule Violations
Numerous former riders and employees of the United States Postal Service, Discovery
Charmel, Astana, RadioShack, Phonak and/or ONCE cycling teams will testify that the
below individuals committed anti-doping rule violationsz as follows:
2 As identified in this letter,
Rules applicable to _lg and/or attempted use of prohibited substances or methods include:
UCI ADR 2 (1997-2000); UCI ADR 130 (2001-2004); UCI ADR 15.2 (2005-2008); UCI
ADR 21.2 (2009-present); and Code Article 2.2 (2003-present);
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June 12, 2012
Page 6
By Johan Bruyneel (Team Director):
(1) Possession of prohibited substances and/or methods including EPO, blood
transfusions and related equipment (such as needles, blood bags, storage
containers and other transfiision equipment and blood parameters measuring
devices), testosterone, hGH, corticosteroids, and masking agents, as described
in more detail above.
(2) Trafficking of EPO, blood transfilsions, testosterone, hGH, corticosteroids and
masking agents as described in more detail above.
(3) Administration and/or attempted administration of EPO, blood transfilsions,
testosterone, hGH, corticosteroids, and masking agents as described in more
detail above.
(4) Assisting, encouraging, aiding, abetting, covering up and other complicit);
involving one or more anti-doping rule violations and/or attempted anti—doping
rule violations.
(5) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Rules applicable to the possession of prohibited substances and/or methods include: UCI
ADR 135 (2001-2004); UCI ADR 15.6.1 (2005-2008); UCI ADR 21.6.1 (2009-present);
and Code Article 2.6.1 (2003-present);
Rules applicable to trafficking include: UCI ADR 135 (2001-04); UCI ADR 15.7 (2005-
2008); UCI ADR 21.7 (2009-present); and Code Article 2.7 (2003-present);
Rules applicable to administration and/or attempted administration include: UCI ADR
54, §1-2 (1997-2000); UCI ADR 133 (2001-2004); UCI ADR 15.8 (2005-2008); UCI
ADR 21.8 (2009-present); and Code Article 2.8 (2003-present);
Rules applicable to assisting, encouraging, aiding, abetting, covering up and other
complicity involving one or more anti—doping rule violations and/or attempted anti—doping
rule violations include: each of the above listed provisions and UCI ADR 54, §1-2 (1997-
2000); UCI ADR 133 (2001-2004); UCI ADR 15.8 (2005-2008); UCI ADR 21.8 (2009-
present); Code Article 2.8 (2003-present); and
Rules applicable to aggravating circumstances include: UCI ADR 305 (2009-present)
and Code Article 10.6 (2009-present).
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June 12, 2012
Page 7
Mr. Johan Bruyneel was a rider with the ONCE team in 1998. In 1999 Mr. Bruyneel
became Team Director with the USPS Cycling Team, a position he held through 2007
(although the team name was changed to the Discovery Channel Cycling Team for the
period 2005-2007). During 2008-2009 Mr. Bruyneel was Director of the Astana Cycling
Team. Since 2010 he has been the Team Director or Team Manager for the RadioShack
Team (now referred to as the RadioShack Nissan Trek Cycling Team).
With respect to Mr. Bruyneel, numerous riders will testify that Mr. Bruyneel gave to them
and/or encouraged them to use doping products and/or prohibited methods, including EPO,
blood transfusions, testosterone, hGH and cortisone during the period from 1999 through
2007. Riders and other witnesses will also testify that Bruyneel worked actively to conceal
rule violations by himself and others throughout the period from 1999 through the present.
By Dr. Pedro Celaya (Team Doctor):
(1) Possession of prohibited substances and/or methods including EPO, blood
transfusions and related equipment (such as needles, blood bags, storage
containers and other transfusion equipment and blood parameters measuring
devices), testosterone, hGH, corticosteroids, and masking agents, as described
in more detail above. _
(2) Trafficking of EPO, blood transfiisions, testosterone, hGH, corticosteroids and
masking agents as described in more detail above.
(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and masking agents as described in more
detail above.
(4) Assisting, encouraging, aiding, abetting, covering up and other complicity
involving one or more anti-doping rule violations and/or attempted anti—doping
rule Violations.
(5) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Dr. Pedro Celaya was a Team Doctor for the USPS Cycling Team fi'om 1997 through 1998
and from 2004 through 2007, by which time the team had come to be known as the
Discovery Charmel Cycling Team. During all or part of the period from 1999 through
2003 Dr. Celaya was a team doctor for the ONCE cycling team. Dr. Celaya is currently a
Team Doctor for the RadioShack Nissan Trek Cycling Team.
With respect to Dr. Celaya, numerous riders will testify that Dr. Celaya gave to them
and/or encouraged them to use doping products and/or prohibited methods, including EPO,
blood transfusions, testosterone, hGH, cortisone and infusions of saline, plasma and/or
glycerol during the period from 1998 through 2007. Riders and other witnesses will also
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June 12, 2012
Page 8
testify that Celaya worked actively to conceal rule violations by himself and others
throughout the period from 1998 through the present.
By Dr. Luis del Moral (Team Doctor):
(1) Possession of prohibited substances and/or methods including EPO, blood
transfusions and related equipment (such as needles, blood bags, storage
containers and other transfusion equipment and blood parameters measuring
devices), testosterone, hGH, corticosteroids, and masking agents, as described
in more detail above.
(2) Trafficking of EPO, blood transfiisions, testosterone, hGH, corticosteroids and
masking agents as described in more detail above.
(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and masking agents as described in more
detail above.
(4) Assisting, encouraflng, aiding, abetting, covering up and other complicigg
involving one or more anti-doping rule violations and/or attempted anti-doping
rule violations.
(5) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Dr. Luis Garcia del Moral was the Team Doctor for the USPS Cycling Team for the period
from 1999 through 2003. Subsequently, Dr. del Moral continued to serve as a physician
for many cyclists. He currently works as a sports doctor in Valencia, Spain.
With respect to Dr. del Moral, numerous riders will testify that Dr. del Moral gave to them,
encouraged them to use and/or assisted them in using doping products and/or prohibited
methods, including EPO, blood transfiisions, testosterone, hGH, cortisone and infiisions of
saline, plasma and/or glycerol during the period from 1999 through 2005. Riders and other
witnesses will also testify that del Moral worked actively to conceal rule violations by
himself and others throughout the period from 1999 through the present.
By Dr. Michele Ferrari (Consulting Doctor):
(1) Possession of prohibited substances and/or methods including EPO, blood
transfusions and related equipment (such as needles, blood bags, storage
containers and other transfiision equipment and blood parameters measuring
devices), and testosterone as described in more detail above.
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(2) Trafficking of EPO, blood transfusions, testosterone, and corticosteroids as
described in more detail above.
(3) Administration and/or attemgted administration of EPO, blood transfusions,
testosterone, and corticosteroids as described in more detail above.
(4) Assisting, encouraging, aiding, abetting, covering up and other comglicity
involving one or more anti-doping rule violations and/or attempted anti-doping
rule violations.
(5) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Dr. Michele Ferrari is a sports doctor who has worked with numerous cyclists and cycling
teams. Dr. Ferrari served as a consultant and doctor to the USPS Cycling Team and many
of its riders during the period from 1999 through 2007. Dr. Ferrari has developed, and is
currently associated with, the website 53x12.com which is devoted to providing training
information to road cyclists.
With respect to Dr. Ferrari, numerous riders will testify that Dr. Ferrari gave to them,
encouraged them to use and/or assisted them in using doping products and/or prohibited
methods, including EPO, blood transfusions, and testosterone during the period from 1999
through 2006. Riders and other witnesses will also testify that Ferrari taught them how to
avoid detection of their drug use, actively working to conceal rule violations by himself
and others throughout the period from 1999 through the present.
By Jose Pepe Marti (Team Trainer):
(1) Possession of prohibited substances and/or methods including EPO, blood
transfiisions and related equipment (such as needles, blood bags, storage
containers and other transfiision equipment and blood parameters measuring
devices), testosterone, hGH, corticosteroids, and masking agents, as described
in more detail above.
(2) Trafficking of EPO, blood transfusions, testosterone, hGH, corticosteroids, and
masking agents as described in more detail above.
(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and masking agents as described in more
detail above.
(4) Assisting, encouraging, aiding, abetting, covering u]; and other complicity
involving one or more anti-doping rule violations and/or attempted anti-doping
rule violations.
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June 1 2, 2012
Page 10
(5) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Mr. Jose Pepe Marti was the Team Trainer for the USPS Cycling Team beginning in 1999
and continued in that position until 2007. Thereafter, Mr. Marti became a trainer with the
Astana Cycling Team in 2008, and it is believed that he continued in this capacity through
2010 and was subsequently employed in cycling until sometime earlier this year.
With respect to Mr. Marti, numerous riders will testify that Mr. Marti gave to them and/or
encouraged them to use doping products and/or prohibited methods, including EPO, blood
transfiisions, testosterone, hGH and cortisone during the period from 1999 through 2007.
Riders and other witnesses will also testify that Marti worked actively to conceal rule
violations by himself and others throughout the period from 1999 through the present.
By Lance Armstrong (Rider):
(1) @ and/or attempted use of prohibited substances and/or methods including
EPO, blood transfusions, testosterone, corticosteroids and masking agents.
(2) Possession of prohibited substances and/or methods including EPO, blood
transfusions and related equipment (such as needles, blood bags, storage
containers and other transfusion equipment and blood parameters measuring
devices), testosterone, corticosteroids and masking agents.
(3) Trafficking of EPO, testosterone, and corticosteroids as described in more
detail above.
(4) Administration and/or attemgted administration to others of EPO,
testosterone, and cortisone.
(5) Assisting, encouragng, aiding, abetting, covering up and other comglicity
involving one or more anti-doping rule violations and/or attempted anti-doping
rule violations.
(6) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Mr. Lance Armstrong was a cyclist with the USPS Cycling Team (and later the Discovery
Channel team) during the period of 1998 through 2005. He rode on the Astana Cycling
Team in 2009 and on the RadioShack Cycling Team during 2010 and early 2011.
With respect to Lance Armstrong, numerous riders, team personnel and others will testify
based on personal knowledge acquired either through observing Armstrong dope or
through Armstrong’s admissions of doping to them that Lance Armstrong used EPO, blood
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June 12, 2012
Page 11
transfusions, testosterone and cortisone during the period from before 1998 through 2005,
and that he had previously used EPO, testosterone and hGH through 1996.
Numerous riders will also testify that Lance Armstrong gave to them, encouraged them to
use and/or assisted them in using doping products and/or methods, including EPO, blood
transfusions, testosterone and cortisone during the period from 1999 through 2005.
Representatives of USADA have interviewed Dr. Martial Saugy, Director of the Lausarme
Anti-Doping Laboratory which analyzed the urine samples from the 2001 Tour of
Switzerland. Dr. Saugy stated that Lance Armstrong’s urine sample results from the 2001
Tour of Switzerland were indicative of EPO use. Multiple witnesses have also told
USADA that Lance Armstrong told them he had tested positive in 2001 and that the test
result had been covered up.
Lance Armstrong’s doping is fiirther evidenced by the data from blood collections
obtained by the UCI fi°om Lance Armstrong in 2009 and 2010. This data is fully consistent
with blood manipulation including EPO use and/or blood transfusions.
USPS Conspiracy
This action is being brought as a single consolidated action because for a significant part of
the period from January 1, 1998, through the present, each of the Respondents has been
part of a doping conspiracy involving team officials, employees, doctors, and elite cyclists
of the United States Postal Service and Discovery Channel Cycling Teams who committed
numerous violations of the Applicable Rules (the “USPS Conspiracy” or the
“Conspiracy”).
The purpose of the USPS Conspiracy was to engage in the use of doping substances and
techniques, which were either undetectable or difficult to detect in routine drug testing in
order to advance the athletic and sporting achievements, financial wellbeing and status of
the teams and their riders, employees, members and investors and to engage in techniques
to avoid detection of the athletes’ use of banned performance enhancing drugs as well as to
prevent the truth regarding doping on the teams and by the riders and their support
personnel from being revealed. After December 31, 2007, the Conspiracy continued as
various members of the Conspiracy continued to engage in conduct to cover up the doping
and violations of the Applicable Rules.
Because of the nature of the USPS Conspiracy, the fact that each of the Respondents
actively participated together in a long running doping conspiracy and due to the close
integration of the evidence against each of the Respondents as described herein this
proceeding is being brought as a consolidated case.
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June 12, 2012
Page 12
Common Practices and Acts of the Consgiracy
USADA anticipates testimony from one or more witnesses or other participants in the
USPS Conspiracy who will testify to the following:
1. The acquisition of banned performance enhancing drugs by high ranking
team officials and riders including Bruyneel, Celaya, del Moral, Ferrari,
Marti and Armstrong.
2. The distribution of drugs by Bruyneel, Celaya, del Moral, Ferrari, Marti and
Armstrong to elite cyclists included in the Conspiracy.
3. The use of secretive methods, including code names, and the use of
masking agents to avoid detection of banned performance enhancing drugs
and prohibited methods.
4. The expectation that elite athletes on the Tour de France team would use
EPO and/or blood transfiisions to improve their ability to help the team
leader(s) perform in the general classification of the Tour de France.
5. The provision of drugs to elite athletes in preparation for, and during, other
races important to the teams in an effort to enhance the performance of the
riders and the team in those races.
6. The use of fear, intimidation and coercion to attempt to enforce a code of
silence (or omerta) by team members and employees to prevent detection of
the Conspiracy or the prosecution of co-conspirators for anti-doping rule
violations.
Cover-Up
Beginning in 1999 and continuing through the present it has been an object of the
Conspiracy to conceal and cover-up the doping conduct of the USPS Conspiracy.
Numerous witnesses will testify that as part of this cover-up Johan Bruyneel, Pedro
Celaya, Michele Ferrari, Lance Armstrong and other co-conspirators engaged in activities
to conceal their conduct and mislead anti-doping authorities including false statements to
the media, false statements and false testimony given under oath and in legal proceedings,
and attempts to intimidate, discredit, silence and retaliate against witnesses.
USADA’s Results Management Authority
Pursuant to the UCI ADR, USADA has results management authority, including authority
to conduct hearings, for any anti-doping rule violations where no sample collection is
involved and where USADA is the Anti—Doping Organization which discovered “elements
that turn out to be evidence for facts that apparently constitute an anti-doping rule
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Page 9
(2) Trafficking of EPO, blood transfusions, testosterone, and corticosteroids as
described in more detail above.
(3) Administration and/or attemgted administration of EPO, blood transfusions,
testosterone, and corticosteroids as described in more detail above.
(4) Assisting, encouraging, aiding, abetting, covering up and other comglicity
involving one or more anti-doping rule violations and/or attempted anti-doping
rule violations.
(5) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Dr. Michele Ferrari is a sports doctor who has worked with numerous cyclists and cycling
teams. Dr. Ferrari served as a consultant and doctor to the USPS Cycling Team and many
of its riders during the period from 1999 through 2007. Dr. Ferrari has developed, and is
currently associated with, the website 53x12.com which is devoted to providing training
information to road cyclists.
With respect to Dr. Ferrari, numerous riders will testify that Dr. Ferrari gave to them,
encouraged them to use and/or assisted them in using doping products and/or prohibited
methods, including EPO, blood transfusions, and testosterone during the period from 1999
through 2006. Riders and other witnesses will also testify that Ferrari taught them how to
avoid detection of their drug use, actively working to conceal rule violations by himself
and others throughout the period from 1999 through the present.
By Jose Pepe Marti (Team Trainer):
(1) Possession of prohibited substances and/or methods including EPO, blood
transfiisions and related equipment (such as needles, blood bags, storage
containers and other transfiision equipment and blood parameters measuring
devices), testosterone, hGH, corticosteroids, and masking agents, as described
in more detail above.
(2) Trafficking of EPO, blood transfusions, testosterone, hGH, corticosteroids, and
masking agents as described in more detail above.
(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and masking agents as described in more
detail above.
(4) Assisting, encouraging, aiding, abetting, covering u]; and other complicity
involving one or more anti-doping rule violations and/or attempted anti-doping
rule violations.
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June 1 2, 2012
Page 10
(5) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Mr. Jose Pepe Marti was the Team Trainer for the USPS Cycling Team beginning in 1999
and continued in that position until 2007. Thereafter, Mr. Marti became a trainer with the
Astana Cycling Team in 2008, and it is believed that he continued in this capacity through
2010 and was subsequently employed in cycling until sometime earlier this year.
With respect to Mr. Marti, numerous riders will testify that Mr. Marti gave to them and/or
encouraged them to use doping products and/or prohibited methods, including EPO, blood
transfiisions, testosterone, hGH and cortisone during the period from 1999 through 2007.
Riders and other witnesses will also testify that Marti worked actively to conceal rule
violations by himself and others throughout the period from 1999 through the present.
By Lance Armstrong (Rider):
(1) @ and/or attempted use of prohibited substances and/or methods including
EPO, blood transfusions, testosterone, corticosteroids and masking agents.
(2) Possession of prohibited substances and/or methods including EPO, blood
transfusions and related equipment (such as needles, blood bags, storage
containers and other transfusion equipment and blood parameters measuring
devices), testosterone, corticosteroids and masking agents.
(3) Trafficking of EPO, testosterone, and corticosteroids as described in more
detail above.
(4) Administration and/or attemgted administration to others of EPO,
testosterone, and cortisone.
(5) Assisting, encouragng, aiding, abetting, covering up and other comglicity
involving one or more anti-doping rule violations and/or attempted anti-doping
rule violations.
(6) Aggravating circumstances justifying a period of ineligibility greater than the
standard sanction.
Mr. Lance Armstrong was a cyclist with the USPS Cycling Team (and later the Discovery
Channel team) during the period of 1998 through 2005. He rode on the Astana Cycling
Team in 2009 and on the RadioShack Cycling Team during 2010 and early 2011.
With respect to Lance Armstrong, numerous riders, team personnel and others will testify
based on personal knowledge acquired either through observing Armstrong dope or
through Armstrong’s admissions of doping to them that Lance Armstrong used EPO, blood
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June 12, 2012
Page 11
transfusions, testosterone and cortisone during the period from before 1998 through 2005,
and that he had previously used EPO, testosterone and hGH through 1996.
Numerous riders will also testify that Lance Armstrong gave to them, encouraged them to
use and/or assisted them in using doping products and/or methods, including EPO, blood
transfusions, testosterone and cortisone during the period from 1999 through 2005.
Representatives of USADA have interviewed Dr. Martial Saugy, Director of the Lausarme
Anti-Doping Laboratory which analyzed the urine samples from the 2001 Tour of
Switzerland. Dr. Saugy stated that Lance Armstrong’s urine sample results from the 2001
Tour of Switzerland were indicative of EPO use. Multiple witnesses have also told
USADA that Lance Armstrong told them he had tested positive in 2001 and that the test
result had been covered up.
Lance Armstrong’s doping is fiirther evidenced by the data from blood collections
obtained by the UCI fi°om Lance Armstrong in 2009 and 2010. This data is fully consistent
with blood manipulation including EPO use and/or blood transfusions.
USPS Conspiracy
This action is being brought as a single consolidated action because for a significant part of
the period from January 1, 1998, through the present, each of the Respondents has been
part of a doping conspiracy involving team officials, employees, doctors, and elite cyclists
of the United States Postal Service and Discovery Channel Cycling Teams who committed
numerous violations of the Applicable Rules (the “USPS Conspiracy” or the
“Conspiracy”).
The purpose of the USPS Conspiracy was to engage in the use of doping substances and
techniques, which were either undetectable or difficult to detect in routine drug testing in
order to advance the athletic and sporting achievements, financial wellbeing and status of
the teams and their riders, employees, members and investors and to engage in techniques
to avoid detection of the athletes’ use of banned performance enhancing drugs as well as to
prevent the truth regarding doping on the teams and by the riders and their support
personnel from being revealed. After December 31, 2007, the Conspiracy continued as
various members of the Conspiracy continued to engage in conduct to cover up the doping
and violations of the Applicable Rules.
Because of the nature of the USPS Conspiracy, the fact that each of the Respondents
actively participated together in a long running doping conspiracy and due to the close
integration of the evidence against each of the Respondents as described herein this
proceeding is being brought as a consolidated case.
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June 12, 2012
Page 12
Common Practices and Acts of the Consgiracy
USADA anticipates testimony from one or more witnesses or other participants in the
USPS Conspiracy who will testify to the following:
1. The acquisition of banned performance enhancing drugs by high ranking
team officials and riders including Bruyneel, Celaya, del Moral, Ferrari,
Marti and Armstrong.
2. The distribution of drugs by Bruyneel, Celaya, del Moral, Ferrari, Marti and
Armstrong to elite cyclists included in the Conspiracy.
3. The use of secretive methods, including code names, and the use of
masking agents to avoid detection of banned performance enhancing drugs
and prohibited methods.
4. The expectation that elite athletes on the Tour de France team would use
EPO and/or blood transfiisions to improve their ability to help the team
leader(s) perform in the general classification of the Tour de France.
5. The provision of drugs to elite athletes in preparation for, and during, other
races important to the teams in an effort to enhance the performance of the
riders and the team in those races.
6. The use of fear, intimidation and coercion to attempt to enforce a code of
silence (or omerta) by team members and employees to prevent detection of
the Conspiracy or the prosecution of co-conspirators for anti-doping rule
violations.
Cover-Up
Beginning in 1999 and continuing through the present it has been an object of the
Conspiracy to conceal and cover-up the doping conduct of the USPS Conspiracy.
Numerous witnesses will testify that as part of this cover-up Johan Bruyneel, Pedro
Celaya, Michele Ferrari, Lance Armstrong and other co-conspirators engaged in activities
to conceal their conduct and mislead anti-doping authorities including false statements to
the media, false statements and false testimony given under oath and in legal proceedings,
and attempts to intimidate, discredit, silence and retaliate against witnesses.
USADA’s Results Management Authority
Pursuant to the UCI ADR, USADA has results management authority, including authority
to conduct hearings, for any anti-doping rule violations where no sample collection is
involved and where USADA is the Anti—Doping Organization which discovered “elements
that turn out to be evidence for facts that apparently constitute an anti-doping rule
--------
- Jul 2, 2009
- 3,406
- 1
- 13,485
- Mar 10, 2009
- 7,268
- 1
- 0
http://online.wsj.com/public/resourc...arging0613.pdf
------------
Be mindful of errors, etc caused by the image to text conversion process.
------------
June 12, 2012
Page 13
violation.” UCI ADR, art. 10; see also UCI ADR, art. 13. Also pursuant to the UCI ADR,
the results management and hearing process in such cases is to be administered by and
under the USADA Protocol. UCI ADR, art. 13. USADA’s jurisdiction extends to both
UCI and USA Cycling license-holders and also to:
a) Any Person who, without being a holder of a license, participates in a cycling
Event in any capacity whatsoever, including, without limitation, as a rider, coach,
trainer, manager, team director, team staff, agent, official, medical or para-medical
personnel or parent and;
b) Any Person who, without being a holder of a license, participates, in the
framework of a club, trade team, national federation or any other structure
participating in Races, in the preparation or support of riders for sports
competitions[.]
UCI ADR, art. 18.
Review Board Process
The USADA Protocol provides that USADA is to make a written submittal to the Anti-
Doping Review Board (the “Review Board”) setting forth information which USADA
deems appropriate related to the anti-doping rule violation(s). USADA Protocol, clause
ll(c)(ii). As noted in the USADA Protocol, the process before the Review Board is not
the hearing stage and the Review Board may only consider “written submittals.” See
USADA Protocol, clause ll(c)(vi). The function of the Review Board is to review the
written submittals to recommend whether “there is sufficient evidence of doping to
proceed with the adjudication process.” USADA Protocol, clause ll(c)(vii).
As in most so called “non-analytical cases” (i.e., cases that are not premised entirely upon
positive laboratory test results) and as provided in the USADA Protocol, weighing the
evidence, assessing the credibility of witnesses and resolving factual disputes is to be done
exclusively by the arbitration panel that will ultimately hear the case. Assessing the
weight of the evidence and addressing factual disputes, however, is not part of the process
before the Review Board as only written submittals may be made to the Review Board.
USADA is required to redact the name of persons responding to alleged rule violations
from the submittal made to the Review Board. See USADA Protocol, clause 11(c)(ii).
Accordingly, USADA will redact the names of Mr. Bruyneel, Mr. Marti, Dr. Celaya, Dr.
del Moral, Dr. Ferrari and Mr. Armstrong from this letter upon submission of the letter to
the Review Board. Consistent with this aspect of the USADA Protocol, USADA has not
set forth in this letter the names of its witnesses.
In this case anonymity of the witnesses at the Review Board stage is also important to
shield them from the retaliation and attempted witness intimidation that cooperating
witnesses have faced in other matters related to the USPS Conspiracy. As in every case
----------
June 12, 2012
Page 14
under the USADA Protocol, should this matter proceed to a hearing USADA will file a
complete list of its witnesses at the appropriate time in advance of the arbitration hearing.
Finally, it may be noted that the conduct of the USPS Conspiracy and doping by its
participants has spanned a period in excess of eight (8) years and there currently exists an
eight year statute of limitations in the Code and UCI ADR. With respect to each of the
Respondents there exists substantial evidence in the form of eyewitness testimony of
doping that occurred within eight years of the date of this letter.
It is also the law that evidence of doping throughout the entire time period described is
relevant and will be admissible in any eventual hearing for at least two reasons: (I)
evidence of doping and evidence of conspiratorial acts outside any applicable limitations
period can be used to corroborate evidence within the limitations period, and (2) as
explained in USADA v. Hellebuyck (copy provided as Attachment D) results outside the
limitations period can be disqualified where reliance on the statute of limitations has been
waived through false statements, fraudulent concealment or other wrongful conduct.
Commencement of Action for Anti-Doping Rule Violations
Pursuant to the Applicable Rules and based on the evidence collected to date, including,
but not limited to, the evidence described above, USADA is initiating the process set forth
in the Protocol concerning your anti-doping rules violations.
At this time, we are forwarding this matter to a panel of the USADA Anti-Doping Review
Board for its consideration and recommendation as set forth in the USADA Protocol.
Pursuant to the Protocol, you have the right to make written submittals to the Review
Board for its consideration. Any written submittals from you must be received by USADA
for transmittal to the Review Board by June 22, 2012. You must provide USADA with
four (4) copies of all submitted materials, so that a copy may be distributed to each
member of the Review Board. If you wish to file your submission in advance of June 22,
2012, please indicate that your submission is complete. The documents submitted by
USADA to the Review Board will have your name redacted. USADA will not redact any
documents you submit to the Review Board.
If this case proceeds beyond the Anti-Doping Review Board, USADA will recommend a
sanction under the Applicable Rules which may include up to a lifetime period of
ineligibility from participation in sport. If you choose to contest the consequence
recommended by USADA, you will have the right to request a hearing. If a hearing is held
in the regular course, you should anticipate a hearing date before November, 2012.
If you or your representatives have any questions or need additional information, please
feel free to contact William Bock, USADA’s General Counsel at 719-785-2061 or Onye
lkwuakor, USADA’s Legal Affairs Director at 719-785-2037.
--------
June 12, 2012
Page 15
You may also contact John Ruger, the USOC Athlete Ombudsman who is completely
independent of USADA, at One Olympic Plaza, Colorado Springs, CO 80909, by
telephone at (719) 866-5000, by fax at (719) 866-3000, by website at
http://www.athleteombudsman.org or by e~mail at J ohn.Ruger@usoc.org and you are
encouraged to contact your own personal attorney. Where your counsel is known to
USADA they have been served with this notice as a courtesy and in order to expedite
notice to you and your counsel.
Except as provided in the USADA Protocol, USADA will not publicly disclose or
comment on the specifics of your case until it has been resolved. By copy of this letter,
USADA is notifying UCI, WTC, USA Cycling, USA Triathlon and the USOC of this
matter and requests that these organizations not comment publicly concerning this
information until disclosed as provided in the Protocol.
Because only Mr. Armstrong currently paiticipates in the sport of triathlon, the letters
provided to WTC and USA Triathlon have the names of Mr. Bruyneel, Dr. Celaya, Dr. del
Moral, Dr. Ferrari and Mr. Marti redacted from them.
US : D A reserves the right to amend this notice as needed or as additional information
es available.
[we‘! I 0 ---SIGNATURE]
473 1 £JL/r\/
. Lisa McCumber]
Testing Results Manager
Enclosures
cc (w/0 encls.): Olivier Niggli, WADA Legal Director
Mario Zorzoli, UCI Chief Medical Officer
Francesca Rossi, UCI Anti-Doping Manager
Andrew Messick, CEO, WTC (names of certain Respondents redacted)
Rana Dershowitz, USOC General Counsel
Gary Johansen, USOC Associate General Counsel
John Ruger, USOC Athlete Ombudsman
Steve Johnson, USA Cycling CEO
Sean Petty, USA Cycling COO
Rob Urbach, USA Triathlon CEO(names of certain Respondents
redacted)
------------
Be mindful of errors, etc caused by the image to text conversion process.
------------
June 12, 2012
Page 13
violation.” UCI ADR, art. 10; see also UCI ADR, art. 13. Also pursuant to the UCI ADR,
the results management and hearing process in such cases is to be administered by and
under the USADA Protocol. UCI ADR, art. 13. USADA’s jurisdiction extends to both
UCI and USA Cycling license-holders and also to:
a) Any Person who, without being a holder of a license, participates in a cycling
Event in any capacity whatsoever, including, without limitation, as a rider, coach,
trainer, manager, team director, team staff, agent, official, medical or para-medical
personnel or parent and;
b) Any Person who, without being a holder of a license, participates, in the
framework of a club, trade team, national federation or any other structure
participating in Races, in the preparation or support of riders for sports
competitions[.]
UCI ADR, art. 18.
Review Board Process
The USADA Protocol provides that USADA is to make a written submittal to the Anti-
Doping Review Board (the “Review Board”) setting forth information which USADA
deems appropriate related to the anti-doping rule violation(s). USADA Protocol, clause
ll(c)(ii). As noted in the USADA Protocol, the process before the Review Board is not
the hearing stage and the Review Board may only consider “written submittals.” See
USADA Protocol, clause ll(c)(vi). The function of the Review Board is to review the
written submittals to recommend whether “there is sufficient evidence of doping to
proceed with the adjudication process.” USADA Protocol, clause ll(c)(vii).
As in most so called “non-analytical cases” (i.e., cases that are not premised entirely upon
positive laboratory test results) and as provided in the USADA Protocol, weighing the
evidence, assessing the credibility of witnesses and resolving factual disputes is to be done
exclusively by the arbitration panel that will ultimately hear the case. Assessing the
weight of the evidence and addressing factual disputes, however, is not part of the process
before the Review Board as only written submittals may be made to the Review Board.
USADA is required to redact the name of persons responding to alleged rule violations
from the submittal made to the Review Board. See USADA Protocol, clause 11(c)(ii).
Accordingly, USADA will redact the names of Mr. Bruyneel, Mr. Marti, Dr. Celaya, Dr.
del Moral, Dr. Ferrari and Mr. Armstrong from this letter upon submission of the letter to
the Review Board. Consistent with this aspect of the USADA Protocol, USADA has not
set forth in this letter the names of its witnesses.
In this case anonymity of the witnesses at the Review Board stage is also important to
shield them from the retaliation and attempted witness intimidation that cooperating
witnesses have faced in other matters related to the USPS Conspiracy. As in every case
----------
June 12, 2012
Page 14
under the USADA Protocol, should this matter proceed to a hearing USADA will file a
complete list of its witnesses at the appropriate time in advance of the arbitration hearing.
Finally, it may be noted that the conduct of the USPS Conspiracy and doping by its
participants has spanned a period in excess of eight (8) years and there currently exists an
eight year statute of limitations in the Code and UCI ADR. With respect to each of the
Respondents there exists substantial evidence in the form of eyewitness testimony of
doping that occurred within eight years of the date of this letter.
It is also the law that evidence of doping throughout the entire time period described is
relevant and will be admissible in any eventual hearing for at least two reasons: (I)
evidence of doping and evidence of conspiratorial acts outside any applicable limitations
period can be used to corroborate evidence within the limitations period, and (2) as
explained in USADA v. Hellebuyck (copy provided as Attachment D) results outside the
limitations period can be disqualified where reliance on the statute of limitations has been
waived through false statements, fraudulent concealment or other wrongful conduct.
Commencement of Action for Anti-Doping Rule Violations
Pursuant to the Applicable Rules and based on the evidence collected to date, including,
but not limited to, the evidence described above, USADA is initiating the process set forth
in the Protocol concerning your anti-doping rules violations.
At this time, we are forwarding this matter to a panel of the USADA Anti-Doping Review
Board for its consideration and recommendation as set forth in the USADA Protocol.
Pursuant to the Protocol, you have the right to make written submittals to the Review
Board for its consideration. Any written submittals from you must be received by USADA
for transmittal to the Review Board by June 22, 2012. You must provide USADA with
four (4) copies of all submitted materials, so that a copy may be distributed to each
member of the Review Board. If you wish to file your submission in advance of June 22,
2012, please indicate that your submission is complete. The documents submitted by
USADA to the Review Board will have your name redacted. USADA will not redact any
documents you submit to the Review Board.
If this case proceeds beyond the Anti-Doping Review Board, USADA will recommend a
sanction under the Applicable Rules which may include up to a lifetime period of
ineligibility from participation in sport. If you choose to contest the consequence
recommended by USADA, you will have the right to request a hearing. If a hearing is held
in the regular course, you should anticipate a hearing date before November, 2012.
If you or your representatives have any questions or need additional information, please
feel free to contact William Bock, USADA’s General Counsel at 719-785-2061 or Onye
lkwuakor, USADA’s Legal Affairs Director at 719-785-2037.
--------
June 12, 2012
Page 15
You may also contact John Ruger, the USOC Athlete Ombudsman who is completely
independent of USADA, at One Olympic Plaza, Colorado Springs, CO 80909, by
telephone at (719) 866-5000, by fax at (719) 866-3000, by website at
http://www.athleteombudsman.org or by e~mail at J ohn.Ruger@usoc.org and you are
encouraged to contact your own personal attorney. Where your counsel is known to
USADA they have been served with this notice as a courtesy and in order to expedite
notice to you and your counsel.
Except as provided in the USADA Protocol, USADA will not publicly disclose or
comment on the specifics of your case until it has been resolved. By copy of this letter,
USADA is notifying UCI, WTC, USA Cycling, USA Triathlon and the USOC of this
matter and requests that these organizations not comment publicly concerning this
information until disclosed as provided in the Protocol.
Because only Mr. Armstrong currently paiticipates in the sport of triathlon, the letters
provided to WTC and USA Triathlon have the names of Mr. Bruyneel, Dr. Celaya, Dr. del
Moral, Dr. Ferrari and Mr. Marti redacted from them.
US : D A reserves the right to amend this notice as needed or as additional information
es available.
[we‘! I 0 ---SIGNATURE]
473 1 £JL/r\/
. Lisa McCumber]
Testing Results Manager
Enclosures
cc (w/0 encls.): Olivier Niggli, WADA Legal Director
Mario Zorzoli, UCI Chief Medical Officer
Francesca Rossi, UCI Anti-Doping Manager
Andrew Messick, CEO, WTC (names of certain Respondents redacted)
Rana Dershowitz, USOC General Counsel
Gary Johansen, USOC Associate General Counsel
John Ruger, USOC Athlete Ombudsman
Steve Johnson, USA Cycling CEO
Sean Petty, USA Cycling COO
Rob Urbach, USA Triathlon CEO(names of certain Respondents
redacted)
pedaling squares said:
You can say about Spain what you want, but they (without having the proper laws) actually caught a doping ring, and (again without having the proper laws) lots of riders got punished one way or the other. Information and evidence leaked to other authorities so that they could suspend riders, lots of riders stopped or ended up in smaller teams because they got implicated. Even Valverdes blood blags ended up in Italy in the end (and I can tell you: they didn't walk by themselves)...
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