Armstrong v. United States Anti-Doping Agency et al

Filing 4

AFFIDAVIT in Support of 3 Memorandum in Support, 2 MOTION for Temporary Restraining Order by Lance Armstrong. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Errata, # 24 Exhibit, # 25 Exhibit, # 26 Exhibit, # 27 Exhibit, # 28 Exhibit, # 29 Exhibit, # 30 Exhibit)(Herman, Timothy)

EXHIBIT 13

____________________________________
Preserving the integrity of competition. Inspiring true sport. Protecting the rights of athletes.

VIA ELECTRONIC MAIL and
VIA OVERNIGHT DELIVERY (where legal counsel is not indicated)
June 28, 2012
Mr. Johan Bruyneel
c/o legal counsel
Dr. Pedro Celaya Lezama
Dr. Luis García del Moral
c/o legal counsel
Dr. Michele Ferrari
Mr. José Martí Martí
c/o legal counsel
Mr. Lance Armstrong
c/o legal counsel
Re:

Charges of Anti-Doping Rules Violations

Dear Mr. Bruyneel, Dr. Celaya, Dr. del Moral, Dr. Ferrari, Mr. Martí, and Mr. Armstrong:
The Panel of the United States Anti-Doping Agency (“USADA”) Anti-Doping Review Board
(“Review Board”) met concerning evidence that Mr. Johan Bruyneel, Dr. Pedro Celaya
Lezama, Dr. Luis García del Moral, Dr. Michael Ferrari, Mr. José (Pepe) Martí Martí and Mr.
Lance Armstrong (collectively, the “Respondents”) engaged in anti-doping rules violations
during the period from 1998 through the present as set forth in the June 12, 2012, notice
letter previously provided to you, which is incorporated into this charging letter by
reference as if fully set forth. The Review Board determined there was sufficient evidence of
anti-doping rules violations and recommended that the adjudication process proceed.
Rule Violations Charged
Therefore, at this time, reserving all rights to amend this charge, USADA charges you with
anti-doping rules violations under the Union Cycliste International (“UCI”) Anti-Doping
Rules 1997 to present (“UCI ADR”), the World Anti-Doping Code 2003 to present (the
“Code”), the USADA Protocol for Olympic and Paralympic Movement Testing 2000 to
present (the “USADA Protocol”), the USOC National Anti-Doping Policies 1997 to present

____________________________
United States Anti-Doping Agency

5555 Tech Center Drive, Suite 200, Colorado Springs, CO 80919 ■ Tel: [phone] ■ Fax: [phone]
[e-mail] ■ www.usada.org

June 28, 2012
Page 2 of 10

(the “USOC NADP”), and the USA Cycling Anti-Doping Rules 1997 to present (collectively,
the “Applicable Rules”) 1 as follows:
Charges against 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 transfusion equipment and blood parameters measuring
devices), testosterone, hGH, corticosteroids, and/or saline, plasma or glycerol
infusions.
(2) Trafficking and/or attempted trafficking of EPO, blood transfusions,
testosterone, hGH, corticosteroids and/or saline, plasma or glycerol infusions.
1

As identified in this charging letter,

Rules applicable to use and/or attempted use of prohibited substances or methods
include: UCI ADR 2, 52 (1997-2000); UCI ADR 4, 6, 7, 8, 130, 131, 133 (2001-2004); UCI
ADR 15.2 (2005-2008); UCI ADR 21.1 and 21.2 (2009-present); and Code Article 2.1 and
2.2 (2003-present);
Rules applicable to the possession of prohibited substances and/or methods include: UCI
ADR 52, 54, 93 (1997-2000); UCI ADR 130, 131, 135 (2001-2004); UCI ADR 15.6 (20052008); UCI ADR 21.6 (2009-present); and Code Article 2.6 (2003-present);
Rules applicable to trafficking and attempted trafficking include: UCI ADR 3, 135, 136
(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
1, 2, 54, 93 (1997-2000); UCI ADR 3, 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 antidoping rule violations include: each of the above listed provisions and UCI ADR 1, 2, 54,
93 (1997-2000); UCI ADR 3, 131,133 (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 130 (4 years to life for
intentional doping) (2001-2004); UCI ADR 305 (2009-present) and Code Article 10.6
(2009-present).

June 28, 2012
Page 3 of 10

(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and/or saline, plasma or glycerol infusions.
(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.
Mr. Bruyneel’s violations commenced on or before January 1, 1999, with multiple
violations thereafter, including violations after June 28, 2004, and, at a minimum, with
respect to cover-up activities Mr. Bruyneel’s violations have continued through the
present.
Charges against Dr. Pedro Celaya Lezama (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/or saline, plasma or glycerol
infusions.
(2) Trafficking and/or attempted trafficking of EPO, blood transfusions,
testosterone, hGH, corticosteroids and/or saline, plasma or glycerol infusions.
(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and/or saline, plasma or glycerol infusions.
(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. Celaya’s violations commenced on or before January 1, 1997, with multiple violations
thereafter, including violations after June 28, 2004, and, at a minimum, with respect to
cover-up activities Dr. Celaya’s violations have continued through the present.
Charges against Dr. Luis García del Moral (Team Doctor):

June 28, 2012
Page 4 of 10

(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/or saline, plasma or glycerol
infusions.
(2) Trafficking and/or attempted trafficking of EPO, blood transfusions,
testosterone, hGH, corticosteroids and/or saline, plasma or glycerol infusions.
(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and/or saline, plasma or glycerol infusions.
(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. del Moral’s violations commenced on or before January 1, 1999, with multiple
violations thereafter, including violations after June 28, 2004, and, at a minimum, with
respect to cover-up activities Dr. del Moral’s violations have continued through the
present.
Charges against 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 transfusion equipment and blood parameters measuring
devices), and/or testosterone.
(2) Trafficking and/or attempted trafficking of EPO, blood transfusions,
testosterone, and/or corticosteroids.
(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, and/or corticosteroids.
(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.

June 28, 2012
Page 5 of 10

Dr. Ferrari’s violations commenced on or before January 1, 1999, with multiple violations
thereafter, including violations after June 28, 2004, and, at a minimum, with respect to
cover-up activities Dr. Ferrari’s violations have continued through the present.
Charges against José (Pepe) Martí Martí (Team Trainer):
(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/or saline, plasma or glycerol
infusions.
(2) Trafficking and/or attempted trafficking of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and/or saline, plasma or glycerol infusions.
(3) Administration and/or attempted administration of EPO, blood transfusions,
testosterone, hGH, corticosteroids, and/or saline, plasma or glycerol infusions.
(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.
Mr. Martí’s violations commenced on or before January 1, 1999, with multiple violations
thereafter, including violations after June 28, 2004, and, at a minimum, with respect to
cover-up activities Mr. Martí’s violations have continued through the present.
Charges against Lance Armstrong (Rider):
(1) Use and/or attempted use of prohibited substances and/or methods including
EPO, blood transfusions, testosterone, corticosteroids and/or saline, plasma or
glycerol infusions.
(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/or saline, plasma or glycerol infusions.
(3) Trafficking and/or attempted trafficking of EPO, testosterone, and/or
corticosteroids.

June 28, 2012
Page 6 of 10

(4) Administration and/or attempted administration to others of EPO,
testosterone, and/or cortisone.
(5) Assisting, encouraging, aiding, abetting, covering up and other complicity
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. Armstrong’s violations commenced on or before August 1, 1998, with multiple
violations thereafter, including violations after June 28, 2004, and, at a minimum, with
respect to cover-up activities Mr. Armstrong’s violations have continued through the
present.
Sanctions Sought
USADA applies the sanctions found in the Applicable Rules; pursuant to these rules each of
you are subject to a sanction for a first doping violation,2 as follows:
•

•

Disqualification of any and all competitive results obtained on and subsequent to
the earliest date on which the evidence at the hearing indicates that you engaged in
an anti-doping rule violation, including forfeiture of any medals, points and prizes
consistent with the UCI ADR and/or Articles 10.1 and 10.8 of the Code; and,

•

Costs and fines as provided for in the Applicable Rules.

•

2

Up to a lifetime period of ineligibility as described in the Applicable Rules,
beginning on the day you accept a sanction or fail to respond, or the date of the
hearing decision in this matter; and,

And, to the extent you are subject to the USOC NADP, you will additionally be
subject to up to lifetime ineligibility, beginning on the day you accept this sanction
or fail to respond, or the date of the hearing decision in this matter, from
participating or coaching in U.S. Olympic, Pan American Games or Paralympic
Games Trials, being a member of any U.S. Olympic, Pan American Games or
Paralympic Team and having access to the training facilities of the United States
Olympic Committee (“USOC”) Training Centers or other programs and activities of
the USOC including, but not limited to benefits, grants, awards or employment as
set forth in Section 5 of the USOC National Anti-Doping Policies and further
defined by Annex B therein.

In the event you have previously been found to have committed an anti-doping rule
violation you would potentially be accountable for an additional sanction as provided in
the Applicable Rules.

June 28, 2012
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As required in every doping case, your doping violation and the resulting sanction will be
publicly announced.
Should you fail to respond to USADA’s charges by signing the enclosed USADA Acceptance
of Sanction Form or by requesting a hearing as provided below, a sanction will be imposed
under the Applicable Rules which will include lifetime ineligibility and disqualification of
all competitive results (if any) achieved from the date on which your anti-doping rules
violation commenced as identified in the foregoing section of this letter titled “Rule
Violations Charged.” Alternatively, if you are willing to accept this sanction, please
inform us in writing by July 9, 2012 at 5:00 p.m., EDT, by executing and returning the
attached USADA Acceptance of Sanction Form. Please return it by fax to 719-785-2028 or
by e-mail to [e-mail].
USPS Conspiracy
As you were previously notified, 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. USADA charges that your participation in the USPS
Conspiracy involved your violations of the foregoing rules that strictly forbid doping.
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, this proceeding is being
brought as a consolidated case. For the foregoing reasons, and, as explained below, should
you request a hearing, USADA anticipates making a request to the arbitrators ultimately
appointed, to hear the evidence in this matter at a single consolidated hearing.
Right to AAA Arbitration Hearing
If you choose to contest the sanction proposed by USADA, you have the right to request a
hearing to contest USADA’s proposed sanction. As described in the USADA Protocol, you

June 28, 2012
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must inform us in writing by July 9, 2012, if you elect to proceed to a hearing before the
American Arbitration Association (AAA). I have enclosed a copy of the USADA Protocol,
the USOC NADP and the AAA Supplementary Procedures for the Arbitration of AntiDoping Rule Violations for your reference. You have previously received copies of the UCI
ADR.
If you fail to notify USADA in writing of your intention to contest this sanction before July
9, 2012, or have not requested a five (5) day extension as described in 11(e) of the
Protocol, the sanction will go into effect on that date and USADA will make a public
announcement concerning your rules violations and the resulting consequences.
In the event you contest USADA’s proposed sanction you should expect a hearing prior to
November, 2012.
Arbitrator Selection
In the event that you request an arbitration hearing USADA anticipates your case will be
heard by a three (3) member arbitration panel as provided in R-11(b) of the American
Arbitration Association Supplementary Procedures for the Arbitration of Olympic Sport
Doping Disputes (the “Supplementary Procedures”). Pursuant to the Supplementary
Procedures, in the event a party requests a hearing before a panel of three (3) arbitrators
USADA will first designate an arbitrator and you will then have five (5) days following
USADA’s arbitrator choice in which to select an arbitrator.
In the event that more than one of the Respondents requests an arbitration hearing then,
as provided under the Supplementary Procedures, USADA will provide notice of its
arbitrator selection to each Respondent requesting a hearing. Each Respondent will then
have five (5) days in which to individually select an arbitrator for that Respondent’s case.
In order to provide the fullest possible range of party appointed arbitrators USADA will
request that no panel chair for any arbitration panel be selected until after the party
appointed arbitrators have been selected and qualified for all cases in which a hearing has
been requested.
Provisional Suspension Process
Additionally, in accordance with the Applicable Rules, you have the right, at this time, to
accept a provisional suspension. A USADA Acceptance of Provisional Suspension Form is
enclosed for this purpose. Should you accept a provisional suspension you will be
immediately suspended from participating in any activity of the UCI, WTC, or any other
signatory of the Code or their members until your case is deemed not to be a doping
offence or until you accept a sanction or a hearing has been held in this matter. If you
choose to accept this provisional suspension, in accordance with the Applicable Rules,
the period of the provisional suspension will be deducted from any period of ineligibility
you might receive in the event that you receive less than a lifetime suspension. If you do

June 28, 2012
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not choose to accept a provisional suspension, any period of ineligibility you might
receive will begin on the date of your acceptance of the sanction, the hearing panel’s
decision or the date your sanction is otherwise imposed.
If you accept the provisional suspension, USADA will give notice to WADA, the UCI, the
WTC, USA Cycling, USA Triathlon, and the USOC as well as the national anti-doping
agency in your home country of your acceptance of the provisional suspension. Your
decision to accept a provisional suspension is purely optional. You do not have to accept
a provisional suspension in order to proceed with your case. If you are willing to accept a
provisional suspension, please inform us in writing by July 9, 2012, by executing and
returning the attached USADA Acceptance of Provisional Suspension Form.
Additional Information
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
Ikwaukor, USADA’s Legal Affairs Director at 719-785-2037.
Also of importance, if you are an active athlete and have not retired you are still subject to
testing pending the outcome of this matter.
You may also wish to contact John Ruger, the USOC Athlete Ombudsman who is
completely independent of USADA, for assistance or further information. Mr. Ruger may
be reached at the US Olympic Committee, 1 Olympic Plaza, Colorado Springs, CO, 80909,
by telephone at [phone], by fax at [phone], by website at
www.athleteombudsman.org or by e-mail at [e-mail].
Because only Mr. Armstrong currently participates 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. Martí redacted from them.
By copy of this letter, USADA is requesting that WADA, UCI, ITU, WTC, USA Cycling, USA
Triathlon, and the USOC not comment publicly concerning this information until your
case has been resolved as provided in the Protocol.
Sincerely,

Lisa McCumber
Testing Results Manager

June 28, 2012
Page 10 of 10

cc (w/o 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)

June 27, 2012
Travis T. Tygart
Chief Executive Officer
United States Anti-Doping Agency
5555 Tech Center Drive, Suite 200
Colorado Springs, CO 80919
Re:

Jun 12, 2012 Notice Letter
Anti-Doping Rules Violations

Dear Travis:
The following members of the United States Anti-Doping Agency's Anti-Doping Review
Board Panel met by teleconference June 25-27, 2012, to review the above referenced
matter.
This Panel considered the written information submitted to it, and concluded that there
was sufficient evidence of doping violations to proceed with the adjudication process as
set forth in USADA's Protocol for Olympic and Paralympic Movement Testing.

Ross Wales, Esq.

Clark Griffit

Robert Dimeff, M.D.

June 27, 2012
Travis T. Tygart
Chief Executive Officer
United States Anti-Doping Agency
5555 Tech Center Drive, Suite 200
Colorado Springs, CO 80919
Re:

Jun 12, 2012 Notice Letter
Anti-Doping Rules Violations

Dear Travis:
The following members of the United States Anti-Doping Agency’s Anti-Doping
Review Board Panel met by teleconference June 25-27, 2012, to review the above
referenced matter.
This Panel considered the written information submitted to it, and concluded
that there was sufficient evidence of doping violations to proceed with the
adjudication process as set forth in USADA’s Protocol for Olympic and
Paralympic Movement Testing.

Ross Wales, Esq.

Clark Griffith, Esq.

Robert J. Dimeff, MD
Robert Dimeff, M.D.

Digitally signed by Robert J. Dimeff, MD
DN: cn=Robert J. Dimeff, MD, o=UT Southwestern Medical
Center, ou=Professor Orthopaedic Surgery, Pediatrics, &
Family Medicine, email=[e-mail], c=US
Date: 2012.06.27 21:53:01 -05'00'

UNITED STATES ANTI-DOPING AGENCY

ACCEPTANCE OF PROVISIONAL SUSPENSION
I, Lance Armstrong, accept a Provisional Suspension as a result my alleged Anti-doping Rule Violations as
set forth in the June 12, 2012, notice letter previously provided to me. By accepting a provisional suspension I
understand that I am not admitting a rules violation but am agreeing for the duration of my case to be temporarily
barred from any activity or competition organized by or under the jurisdiction of, and from participation in any
activity of or organized by, the Union Cycliste Internationale (“UCI”), World Triathlon Corporation (“WTC”), USA
Cycling, USA Triathlon, the United States Olympic Committee (“USOC”) and any other Signatory of the World
Anti-Doping Code (the “Code”), and/or any entity which has accepted the Code and/or any entity whose rules are
consistent with the Code and/or any of the clubs, member associations or affiliates of these entities while serving
this Provisional Suspension.
Among other things, this Provisional Suspension bars me from serving as an athlete or as a coach, trainer,
team director, team manager, team doctor, team employee, team owner, athlete support person. This Provisional
Suspension also bars me from serving as an athlete representative, agent, or employee of any athlete management or
athlete representation firm, entity or association or in any governance capacity, paid or unpaid, with any Signatory,
or any member or affiliate of a Signatory or any member of a member.
I understand that the period of the Provisional Suspension, beginning on the date I accept this Provisional
Suspension and notify the United States Anti-Doping Agency (“USADA”) of such, will be deducted from any
period of ineligibility that I might receive in my case.
I understand and accept that USADA will notify UCI, WTC, USA Cycling, USA Triathlon, the USOC and
other sports organizations and/or event organizers as appropriate my acceptance of this Provisional Suspension.
I understand and accept that my acceptance of a Provisional Suspension is purely voluntary and optional. I
understand and accept that I am entitled to proceed with my case, to a hearing if necessary, regardless of whether I
accept this Provisional Suspension.
I understand and accept that I may serve this Provisional Suspension and it may ultimately be determined
that no doping offense has occurred through a hearing or otherwise.
I understand and accept that I am still subject to testing pending the outcome of this matter.

________________________________________
Signature of Lance Armstrong

____________________________________
Date

________________________________________
Printed Name of Lance Armstrong

U.S. Anti-Doping Agency

Page 1 of 1

UNITED STATES ANTI-DOPING AGENCY

ACCEPTANCE OF SANCTION
I, Lance Armstrong, accept the following sanction as a result of my anti-doping rules
violations during the period from August 1, 1998 through the present as set forth in the June 28,
2012, charging letter which is attached as Exhibit A. I acknowledge that I have violated the
applicable rules, including the Union Cycliste Internationale (“UCI”) Anti-Doping Rules (“UCI
ADR”), the World Anti-Doping Code (the “Code”), the United States Anti-Doping Agency
(“USADA”) Protocol for Olympic and Paralympic Movement Testing (the “Protocol”), and the
United States Olympic Committee (“USOC”) National Anti-Doping Policies (“USOC NADP”),
and I accept the following:
•

A Lifetime period of Ineligibility as described in the Code and current UCI ADR,
beginning on the day I accept this sanction, from participation in any activity or
competition organized by or under the auspices of any signatory to the Code or any member
of any signatory, and,

•

Disqualification of any and all competitive results obtained on and subsequent to August
1, 1998, including forfeiture of any medals, titles, winnings, finishes, points and prizes
consistent with Articles 10.1 and 10.8 of the Code and the UCI Anti-Doping Rules.

•

Lifetime Ineligibility from participating or coaching in U.S. Olympic, Pan American
Games or Paralympic Games Trials, being a member of any U.S. Olympic, Pan American
Games or Paralympic Team and having access to the training facilities of the USOC Training
Centers or other programs and activities of the USOC including, but not limited to benefits,
grants, awards or employment as set forth in Section 5 of the USOC National Anti-Doping
Policies and further defined by Annex B therein.

I do not contest the above sanction determined by USADA under the applicable rules,
and I have agreed to the violation and resulting sanction. I knowingly and voluntarily waive any
further right to contest or challenge my violation or this sanction.
I understand that USADA will communicate my acceptance to the World Anti-Doping
Agency (“WADA”), UCI, WTC, USA Cycling, USA Triathlon who, with USADA and any other
appropriate organization(s), will impose this sanction, and to the USOC and such other sports
organizations and event organizers as may be appropriate. I understand that neither UCI nor
WADA is bound by this resolution and that either or both may appeal this resolution to the
Court of Arbitration for Sport (“CAS”). In the event of an appeal, UCI or WADA has the
authority to impose any sanction it chooses in accordance with the applicable rules. Also, in the
event of such an appeal I reserve the right to file a cross-appeal with CAS and request that the
sanction be reduced or eliminated.
In the event it is determined that I participated in any activity or competition organized
by or under the auspices of any signatory to the Code or competed during my period of
ineligibility I understand that my entire period of ineligibility will be extended and restarted
from the last date of any such participation. Also, in the event it is later determined that my
anti-doping rules violation(s) began earlier than the date set forth above I understand and agree
that any results, prizes, points, money or other winnings obtained between the first date of such

U.S. Anti-Doping Agency

Page 1 of 2

participation will be disqualified and, to the extent possible, promptly returned by me to
USADA.
It is my sole responsibility to investigate and determine the effect of this sanction on my
eligibility for future competitions or teams. I understand and accept that entities other than the
USOC, UCI, WTC, USA Cycling and USA Triathlon, will give effect to this sanction including
potentially, but not limited to, the International Olympic Committee (“IOC”), signatories to the
Code, the National Collegiate Athletic Association, National Association of Intercollegiate
Athletics, or any clubs, member associations or affiliates of the World Anti-Doping Code, the
USOC or US Paralympics, and other organizations if applicable. I understand and accept that it
is my obligation to investigate the effect of this sanction on me by other entities.
I understand that Article 10.1 of the Code and the anti-doping rules of certain
international federations permit disqualification of results obtained prior to Sample collection or
an attempt at Sample collection and/or prior to the occurrence of an anti-doping rule violation,
particularly where the collection, attempted collection or occurrence of a rule violation occurred
in connection with an Event, consisting of more than a single Competition. It is my
responsibility to investigate the possibility that certain of my prior competitive results could be
disqualified under Article 10.1 of the Code and/or the rules of my international federation and I
accept that such disqualification may be a consequence of my acceptance of sanction.
I also understand and accept that under the Protocol, my doping violations and the
resulting sanction will be publicly announced.
BY SIGNING BELOW I AFFIRM THAT I HAVE READ AND FULLY UNDERSTAND THIS
ACCEPTANCE OF SANCTION AND AGREE TO THE ABOVE TERMS AND ALL OTHER
PROVISIONS IN THE CODE, THE PROTOCOL THE USOC NADP AND THE ANTI-DOPING
RULES OF MY INTERNATIONAL FEDERATION(S) THAT RELATE TO MY ANTI-DOPING RULE
VIOLATION.

_______________________________________

Signature of Lance Armstrong

_______________________________________

Date

_______________________________________

Printed Name of Lance Armstrong

U.S. Anti-Doping Agency

Page 2 of 2