On June 12, 2012, USADA notified Mr. Armstrong, Johan Bruyneel, Dr. Pedro Celaya, Dr. Luis Garcia del Moral, Dr. Michele Ferrari and Mr. Jose “Pepe” Marti (collectively, the “Respondents”) via letter that USADA was “opening a formal action against each of you based on evidence that . . . you engaged in anti-doping rule violations . . . from 1998 to [the] present. ”23 USADA notifed the Respondents that the “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 USPS and Discovery Channel Cycling Teams who committed numerous violations of the Applicable Rules (the “USPS Conspiracy” or the “Conspiracy)