Direct examination

Question 1

Mr. Harris, would you please introduce yourself to the jury?

Answer 1

My name is Tim Harris and I am an assistant football coach at Nita State University.

Question 2

Mr. Harris, how long have you held this position?

Answer 2

I just started at Nita State this year.

Question 3

What other coaching positions have you held before?

Answer 3

Before that, I was the head football coach at Nita City Central High School for five years. Before that, I was a graduate assistant in the football program at University of Texas.

Question 4

Did you ever play football?

Answer 4

Yes, I was a tight end on the football team at the University of Texas for three years. The last two years I played I was a starter. I quit playing after I blew my knee out during a game. That happens to tight ends a lot.

Question 5

So, you know what it takes to be a college football player?

Answer 5

Absolutely. Between playing myself and coaching for so long, I know when someone has what it takes.

Question 6

How do you know the plaintiff, Jackie Fulbright?

Answer 6

I coached Jackie when he played for Nita City Central High School.

Question 7

How long did you coach Jackie?

Answer 7

I coached Jackie all three years he played in high school.

Question 8

What position did Jackie play?

Answer 8

Jackie was a quarterback.

Question 9

Can you explain to the jury how Jackie was as a football player prior to the incident?

Answer 9

Honestly, I have never seen a better high school quarterback anywhere. He was Nita City Central’s starting quarterback his sophomore and junior years. Jackie had a great arm and a cool head. He could throw a football sixty yards with accuracy, which for a high school quarterback is extremely promising. The best thing about Jackie though, was that he was a hard worker and was willing to do anything to improve his game.

Question 10

In your opinion, as a college football coach, did you think that Jackie was good enough to receive an athletic scholarship for college?

Answer 10

Most definitely. I mean, he had already made second team All-State his junior year. Also, after Jackie’s junior year, I was contacted about him by many top college coaches and recruiters. I recommended to every single coach and recruiter that contacted me that they go after Jackie. There was no doubt in my mind that Jackie could have started for any major college program.

Question 11

What were some of the schools that were recruiting Jackie?

Answer 11

It was all Division 1 schools like, Penn State, Michigan, Texas, and others. His dream was to play for Penn State like his dad did. Nita State University, where I coach now, was even recruiting him.

Question 12

How much do you estimate that a full athletic scholarship to college is worth?

Answer 12

Well it depends on the school, but on average I would say anywhere between $100,000 and $250,000. These athletic scholarships include tuition, room, and board.

Question 13

Mr. Harris, will you look at what has been marked as Exhibit 7?
o Do you know what this is?

Answer 13

Yes. This is Nita State’s quarterback evaluation for the recruiting year that would have been Jackie’s senior year.

Question 14

And is it a regular practice for college football programs to produce these types of evaluations?

Answer 14

Yes, this is similar to the records that every major college football program keeps for every position.

Question 15

So, would you consider it a business practice of Nita State’s football program to keep these kind of records?

Answer 15

So, would you consider it a business practice of Nita State’s football program to keep these kind of records?

Question 16

What scores did Nita State give Jackie in foot speed?

Answer 16

A+

Question 17

What about in arm strength?

Answer 17

A

Question 18

How about in throwing on a run with his right arm?

Answer 18

A

Question 19

What score did Jackie get in decision making?

Answer 19

A+

Question 20

How about in leadership?

Answer 20

A+

Question 21

What score did Nita State give Jackie in his option offense potential?

Answer 21

A+

Question 22

How about his pro-style offense potential?

Answer 22

A

Question 23

Lastly, what overall score did Nita State give Jackie?

Answer 23

A

Question 24

Why would Nita state have only given Jackie an A, and not an A+?

Answer 24

As indicated on the evaluation, Jackie’s interest in Nita State was low, and that was factored into his overall score.

Question 25

So, based on these scores and your experience as a college football coach, do you think that Nita State would have extended Jackie an offer for an athletic scholarship?

Answer 25

Absolutely. I don’t think Jackie would have accepted, because he would have had much more competitive offers.

Question 26

In your opinion, as a football coach, did you think Jackie was good enough to eventually play professional football?

Answer 26

Jackie certainly had the physical skills and mental discipline to make it in the NFL. And there are more quarterback slots than there are good quarterbacks in the league. There’s always a need for good quarterbacks.

Question 27

Do you know the average annual salary of a pro quarterback?

Answer 27

Last year, the average annual salary was $3,840,000. Some even make up to $22,000,000 a year.

Question 28

You mentioned earlier that you had a career-ending injury. With your knowledge of football, is that something that would have likely happened to Jackie?

Answer 28

Its not impossible, but quarterbacks are the best protected players. It’s unusual for a quarterback to have a career ending injury.

Question 29

Do you know what Jackie’s future career plans are?

Answer 29

Jackie wants to be a football coach.

Question 30

Are there any reasons why it might be difficult for Jackie to be a football coach since his injury?

Answer 30

Well, the chances of him getting a good coaching job aren’t great, even if he’s just looking at the high school level. It’s a pretty closed fraternity and it’s hard to get in unless you played football in college. He certainly has less chance than he would have if he had played at a major college program.